---
type: court_doc
id: "court_ctb_2292_53"
court: "CTB"
case_no: "22-50073"
doc_number: 2292
doc_type: "EXHIBIT"
filed_date: "2023-10-26"
lang: "en"
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url: "https://mubeitech.com/en/court/court_ctb_2292_53"
json_url: "https://mubeitech.com/api/court/court_ctb_2292_53"
---
# Guo Wengui / Miles Guo — bankruptcy case · EXHIBIT · ECF #2292-53



Exhibit 53
EXHIBIT B
Exhibit 21
Case 22-50073 Doc 2292-53 Filed 10/26/23 Entered 10/26/23 20:46:12 Page 4 of Case 23-05005 Doc 85-1 Filed 10/16/23 Entered 10/16/23 19:44:19 Page 3 of 51 52

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HING CHI NGOK· Highly Confidential

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1　VIDEOGRAPHER: This is Tape No. 1 to the　1
2　ECHO LIM, having first been duly
sworn, interpreted as follows:
2　videotaped deposition of Hing Chi Ngok in the　3　HING CHI NGOK, having first been duly
3　matter of Despins, Kwok (sic) v. Greenwich　4　sworn, was deposed and testified as follows:

5　Land, et al., being heard before the United
States Bankruptcy Court, District of　5
6　Connecticut, Bridgeport Division, Case　6　DIRECT EXAMINATION
7　No. 22-50073.　7　BY MR. LUFT:
8　This deposition is being held at Meister　8　Q Good morning, Ms. Ngok. How are you?
9　Seelig & Fein on 9/11/2023 at 10:22 a.m. My　9　A Good. Thank you.
10　name is Debbie O'Toole. I'm the videographer.　10　Q Ms. Ngok, I wanted to confirm that you
11　The court reporter is Debbie Gentile.　11　understood you're appearing both as an individual
12　Counsel, will you please introduce　12　deponent today and as the corporate representative
13　yourselves and affiliations? And the witness　13　for Greenwich Land, correct?
14　will be sworn.　14　A Yes.
15　MR. LUFT: Good morning. My name is　15　MR. LUFT: And I'll ask the court reporter
16　Avi Luft. I'm with the law firm of　16　to mark as Exhibit 1 a Chapter -- a copy of the
17　Paul Hastings. I represent the Chapter 11　17　Chapter 11 trustee's notice of deposition to
18　trustee, Luc A. Despins. With me are my　18　Hing Chi Ngok.
19　colleagues, Doug Barron and Luyi Song.　19　(Exhibit 1 was marked for I.D.)
20　MR. MAJOR: Good morning. Chris Major,　20　(A discussion was held off the
21　Meister Seelig & Fein. We represent the　21　stenographic record.)
22　defendants in this adversary proceeding,　22　THE WITNESS: I am not able to read this.
23　Ms. Guo and Greenwich Land, LLC, and we're　23　BY MR. LUFT:
24　representing the witness in this deposition.　24　Q I understand.
25　MR. INTRATER: Good morning.　25　Ms. Ngok, I've handed you what is a copy

Page 6　Page 8
1　Zach Intrater, Brafman & Associates. I　1　of the Chapter 11's notice of deposition to Hing Chi
2　represent Ms. Guo in this deposition.　2　Ngok. Have you ever seen this document before?
3　COURT REPORTER:
Usual stips?　3　MR. MAJOR: Objection to form.
4　MR. LUFT:
I don't know what they are, so　4　THE WITNESS: I am not able to recognize
5　we're going to just go until we figure it out.　5　it. I cannot read English and I don't
6　MR. MAJOR:
Well, I'd like to, just for --　6
7　understand the content of this document.
BY MR. LUFT:
7　so we can get through this deposition, I'd like　8　Q Okay.
8　to have a stipulation that all objections　9　MR. LUFT: I'm going to mark as Ngok
9　except as to the form of the question are　10　Deposition Exhibit 2 a copy of the Chapter 11
10　reserved.
This way we don't have to hash out　11　trustee's notice of deposition of Greenwich
11　every potential objection.　12　Land, LLC, pursuant to Federal Rule of Civil
12　MR. LUFT:
That's fine.
That's my　13　Procedure 30(b)(6).
13　understanding of the rules anyway.
My point　14　(Exhibit 2 was marked for I.D.)
14　was not that there were none, just it's what　15　BY MR. LUFT:
15　they are.　16　Q Ms. Ngok, I've handed you what has been
16　MR. MAJOR:
Okay.　17　marked as Exhibit 2, which is a copy of the notice

18　MR. LUFT:
And --
COURT REPORTER:
Please raise your　18　of deposition for Greenwich Land, LLC. Have you
19　ever seen this document before?

20　right --
MR. LUFT:
Sorry.　20　MR. MAJOR: Objection to form.
21　Just so it's clear for the record, this　21　THE WITNESS: I do not know what you mean.
22　deposition is of Ms. Hing Chi Ngok and of　22　INTERPRETER: Can the interpreter
23　Greenwich Land.
So it's both defendants.　23　reinterpret the question? That's what Ms. Ngok
24　24　is requesting.
25　25　MR. LUFT: Okay. My only question is

Page 9　Page 11

1　whether she has seen this document before.
2　(Interpreter speaking Mandarin.)
3　MR. MAJOR: Objection to form.
4　THE WITNESS: I don't understand this
5　document.
6　BY MR. LUFT:

7　Q Ms. Ngok, were you provided a translation
8　of the notice of deposition by your counsel setting
9　out in Chinese what the deposition topics were for
10　today's deposition on behalf of Greenwich Land, LLC?
11　MR. MAJOR: Objection to form. Instruct
12　the witness not to answer on the grounds of
13　privilege.　13　BY MR. LUFT:
14　THE WITNESS: Okay.　14　Q Ms. Ngok, I am going to ask you a series
15　BY MR. LUFT:　15　of questions, just like I did last time. If for any
16　Q Are you going to follow your counsel's　16　reason you do not understand my question, will you
17　instruction?　17　let me know?
18　A Correct.　18　A Okay.
19　Q Ms. Ngok, are you prepared to testify on　19　Q If for -- and if -- can we have an
20　the 17 topics listed in the Greenwich Land　20　agreement that if you do not tell me that you don't
21　deposition notice?　21　understand my question, then I can assume you did
22　A Yes.　22　understand it?
23　Q Okay. You can put that aside.　23　MR. MAJOR: Objection to form.
24　Ms. Ngok, as you know, I took your　24　THE WITNESS: I don't quite understand
25　deposition on January 5, 2023, correct?　25　what you mean by that. Can you explain?

1　Page 10
A In January, yes. I remember.　1　Page 12
BY MR. LUFT:
2　Q The rules are the same for this　2　Q Sure. If for -- if I ask you a question
3　deposition. But if you'll indulge me, I'll just go　3　and you don't tell me that you don't understand it,

4　over a couple of them, okay?　4　is it fair for me to assume that you do understand
5　A Yes, please.　5　it?
6　Q Ms. Ngok, you understand that you're　6　A No. If I didn't understand a question,
7　testifying under oath today?　7　you can't assume that I understand a question.
8　A Of course.　8　Q Thank you. That's not what I was saying,
9　Q You understand that means you have to　9　so this is a perfect example. Let's start again.
10　testify truthfully?　10　If you don't understand my question, will
11　A Correct.　11　you tell me?
12　Q And you understand that you may not omit　12　A I will not. If I don't understand your
13　information that you know that is called for by the　13　question, I will not tell you, because I didn't
14　question, correct?　14　understand.
15　A Of course.　15　Q Will you tell me that you don't understand
16　my question?
17　A Yes, of course.
18　Q And if I ask you a question and you do not
19　tell me that you don't understand, can I assume that
20　you do understand my question?
21　MR. MAJOR: Objection to form.
22　THE WITNESS: Of course. That works.
23　BY MR. LUFT:
24　Q Great. Okay.
25　Ms. Ngok, as we've discussed, you're

Page 13　Page 15

1　appearing on behalf of yourself and for the entity
2　Greenwich Land today?
3　A Yes.
4　Q If in answering a question your answer
5　would differ from what -- your answer as an
6　individual, as opposed to your answer on behalf of
7　Greenwich Land, will you let me know?
8　Q Other than Mr. Major and Mr. Intrater,
8　A Yes.
9　Q Ms. Ngok, what did you do to prepare for　9　have you discussed this deposition with anyone else?
10　your deposition today?　10　MR. MAJOR: Objection to form.
11　A I did. I prepared with my attorneys.　11　THE WITNESS: No.
12　Q And who are your attorneys today?　12　BY MR. LUFT:
13　THE WITNESS: I'm sorry, Gentlemen. I　13　Q Other than Mr. Intrater and Mr. Major,
14　can't pronounce your names.　14　have you discussed this case with anyone else?
15　But these two gentlemen sitting right here　15　MR. MAJOR: Objection to form.
16　(indicating).　16　THE WITNESS: No.
17　BY MR. LUFT:　17　BY MR. LUFT:
18　Q Mr. Major and --　18　Q In preparing for this deposition, did you
19　MR. LUFT: Intrater? Is that　19　review any documents?
20　MR. INTRATER: That's great. Perfect.　20　A I did.
21　THE WITNESS: I'm sorry. I don't have any　21　Q What documents did you review?
22　mental note of any English name. Sorry about　22　A The same documents I review for the last
23　that.　23　deposition.
24　MR. LUFT: That's fine.　24　Q Can you remind me what documents those
25　For the record can we agree that she has　25　were?

1　Page 14
pointed to Mr. Major and Mr. Intrater as her　1　Page 16
A Some -- something like some sort of bank
2　counsel who she met with?　2　documents. But to be very frank with you, I don't

3　MR. MAJOR: Yes.　3　even understand them.
4　MR. LUFT: Okay.　4　Q Do you recall what bank documents they
5　THE WITNESS: (In English) Sorry about　5　were?
6　that.　6　A I can't remember.
7　MR. LUFT: That's okay.　7　Q Other than preparing for this deposition,
8　THE WITNESS: Okay.　8　had you ever seen these bank documents before?
9　BY MR. LUFT:　9　A No.
10　Q How many times did you meet with them in　10　Q Were they bank documents related to your
11　preparation for this deposition?　11　personal bank accounts?
12　A Twice.　12　MR. MAJOR: Objection to form.
13　Q When did you meet with them?　13　THE WITNESS: No.
14　A I can't remember specifically when, but it　14　BY MR. LUFT:
15　happens within a month.　15　Q Were they bank accounts related to
16　Q How long did you meet with them?　16　Greenwich Land's bank accounts?
17　A It could range from one to two hours or　17　MR. MAJOR: Objection to form.
18　two to three hours.　18　THE WITNESS: They are not statements. I
19　Q When you met with your attorney,　19　don't know what they are. I am not even -- I'm
20　Mr. Intrater or Mr. Major, was there anyone else　20　not able to tell what they are.
21　present?　21　BY MR. LUFT:
22　A Interpreters -- interpreter.　22　Q Can you give me your best description of
23　INTERPRETER: Sorry.　23　those bank documents?
24　BY MR. LUFT:　24　A Okay. I don't know if they are even a
25　document -- they are even a document. I have seen

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them. I can't recall. I can't tell the content of　1　Page 19
MR. MAJOR: Objection to form. Instruct

2　it.　2　the witness not to answer on the grounds of
3　Q But they were documents that you looked at　3　privilege.
4　to prepare for this deposition?　4　MR. LUFT: On what grounds can that be
5　MR. MAJOR: Objection to form.　5　privileged? I'm asking just the name of who's
6　THE WITNESS: Correct.　6　the person who made the decision.
7　MR. LUFT: Mr. Major, I don't believe　7　MR. MAJOR: The decision that you're
8　we've received any bank documents. Have they　8　referring to -- first of all, you're
9　been -- the documents the witness is referring　9　presupposing that the decision was the decision
10　to, have they been produced to us?　10　of Greenwich Land. But the contemplation of
11　MR. MAJOR: I don't know what documents　11　hiring or separating from counsel is
12　the witness is specifically referring to, but　12　privileged.
13　we have produced bank records to you,　13　MR. LUFT: I'm not asking about the
14　specifically from The Bank of Princeton. I　14　content; I just want to know who was the person
15　know that my firm handled that production. I　15　who made the decision. That's not privileged.
16　know the law firm of Updike, Kelly & Spellacy,　16　It doesn't call for legal advice or anything
17　I believe, produced some bank records to you in　17　else.
18　advance of the just closed Rule 2004 exam. I　18　MR. MAJOR: The decision of either hiring
19　assume that's what the witness is referring to,　19　or separating from counsel is a privileged
20　but I don't know.　20　matter.
21　MR. LUFT: Okay. I'll just ask that on a　21　MR. LUFT: Correct, but the person who --
22　break you confer with her, and if there are　22　the name of the person who decided that is not

24　documents that we haven't received yet, if you
just let us know and produce them, okay?　23
24　privileged.
MR. MAJOR: To the extent it -- the
25　MR. MAJOR: Yes. And I do not think there　25　question necessarily calls for discussions with

Page 18　Page 20
1　are documents that we have that you don't have　1　counsel.

3　yet, but I will certainly triple-check that
during a break.　2
3　MR. LUFT: No, it just calls for the name,
the name of the person. She is here as
4　MR. LUFT: Terrific.　4　Greenwich Land's representative; I'm free to
5　BY MR. LUFT:　5　ask her who's the person who made the decision.
6　Q Other than the documents you've referred　6　That's not a privileged question.
7　to as the "bank documents," are there any other　7　MR. MAJOR: You can ask questions about
8　documents you looked at to prepare for this　8　decisions that Greenwich Land made on other
9　deposition?　9　matters, but not on counsel.
10　A There must be some, but I can't remember　10　MR. LUFT: Okay. I disagree with you, I
11　what they are.　11　think you're obstructing, and you haven't given
12　Q When was the last time you reviewed these　12　me any explanation why the name of an
13　documents?　13　individual calls for the provision of legal
14　A Probably approximately three weeks ago,　14　advice.
15　but I don't remember specifically when.　15　BY MR. LUFT:
16　Q Okay. Ms. Ngok, when I deposed you in　16　Q Ms. Ngok, are you going to follow your
17　January, you were represented by a different lawyer　17　counsel's instruction?
18　from a different law firm, correct?　18　A Correct.
19　A Correct.　19　Q Ms. Ngok, were you the person who made the
20　Q And that was Mr. Goldstein from the Updike　20　decision to replace Updike Kelly with Mr. Major's
21　Kelly firm, correct?　21　firm?
22　A I don't remember.　22
23　MR. MAJOR: Objection to form. Instruct
the witness not to answer on the grounds of

24　Q Who made the decision at Greenwich Land to
change counsel from Updike Kelly to Mr. Major's　24　privilege.
25　firm?　25

Page 21　Page 23

1　BY MR. LUFT:　1　before you signed the supplemental responses to the
2　Q Ms. Ngok, are you going to follow your　2　interrogatories?
3　counsel's direction?　3　A I did.
4　A Correct.　4　Q And before signing did you agree that all
5　Q Ms. Ngok, I'm going to ask the court　5　the information included in the document was
6　reporter to mark as Ngok Deposition Exhibit 3 a copy　6　accurate and true?
7　of defendant Greenwich Land, LLC's supplemental　7　MR. MAJOR: Objection to form.
8　responses and objections to the first set of　8　THE WITNESS: I believe so.
9　interrogatories by plaintiff Luc Despins, the　9　BY MR. LUFT:
10　Chapter 11 trustee.　10　Q Ms. Guo, if we look at response to
11　(Exhibit 3 was marked for I.D.)
11　Interrogatory No. 1 --
12　BY MR. LUFT:　12　INTERPRETER: Ms. -- did you say,
13　Q Ms. Ngok --　13　"Ms. Guo"?
14　(A discussion was held off the　14　MR. LUFT: Sorry. Ms. Ngok.
15　stenographic record.)　15　INTERPRETER: Sorry. Okay.
16　BY MR. LUFT:　16　THE WITNESS: Okay.
17　Q Ms. Ngok, I've put in front of you as　17　BY MR. LUFT:
18　marked as Exhibit 3 a document titled "Defendant　18　Q -- there's a sentence that says "Greenwich
19　Greenwich Land, LLC's Supplemental Responses and　19　Land's sole purpose is to own a residential property
20　Objections to the First Set of Interrogatories by　20　in Greenwich, Connecticut."
21　Plaintiff Luc Despins," the Chapter 11 trustee. Do　21　A Correct.
22　you see that?　22　Q Is that true?
23　MR. MAJOR: Objection to form.　23　A Correct.
24　THE WITNESS: Yes, I see it.　24　Q So when you say "Greenwich Land's sole
25　25　purpose is to own a residential property in

Page 22　Page 24
1　BY MR. LUFT:　1　Greenwich, Connecticut," what do you mean?
2　Q If you turn to the last page of the　2　MR. MAJOR: Objection to form.
3　document, you'll see a signature line for Greenwich　3　THE WITNESS: I don't understand this
4　Land. It says by Hing Chi Ngok, "Title: Sole　4　question. Can you please clarify?
5　Member."　5　BY MR. LUFT:
6　INTERPRETER: Sorry.　6　Q My question is simply there's a statement
7　THE WITNESS: Yes.　7　in the interrogatory, and I just want to understand
8　BY MR. LUFT:　8　what Greenwich Land meant by that statement.
9　Q Do you see that, Ms. Ngok?　9　MR. MAJOR: Objection to form.
10　A I see it.　10　THE WITNESS: Can you please tell me which
11　Q And whose signature is that?　11　statement?
12　A It looks like my signature, but I cannot　12　BY MR. LUFT:
13　be certain that it is mine.　13　Q Sure. It is on the response to
14　Q The date of this document is September 9,　14　Interrogatory No. 1. There's a sentence that says
15　2023, two days ago.　15　"Greenwich Land's sole purpose is to own a
16　A Two days ago?　16　residential property in Greenwich, Connecticut."
17　Q Yes.　17　A Correct.
18　Do you recall signing responses --　18　Q And my under -- my question is what does
19　interrogatory responses two days ago?　19　Greenwich Land mean by that statement?
20　A I believe so.　20　MR. MAJOR: Objection to form.
21　Q And the document indicates that you were　21　THE WITNESS: I don't know what you mean
22　provided a translation of this English document into　22　by that. This company owns properties, isn't
23　Mandarin; is that correct?　23　it?
24　A Correct.
25　Q Did you read that Mandarin translation
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THE WITNESS: I don't know about that too.　1　Page 31
discussing?

2　BY MR. LUFT:　2　MR. MAJOR: Objection to form.
3　Q Since Greenwich Land has been founded,　3　THE WITNESS: I do not know.
4　who -- what individuals have had the right to spend　4　BY MR. LUFT:
5　money on behalf of Greenwich -- or let me strike　5　Q Do you have any idea where Greenwich Land
6　that.　6　gets the money from that you use to pay for personal
7　Since Greenwich Land has been founded,　7　expenses unrelated to the two houses we've been
8　what individuals have had the right to spend money　8　discussing?
9　from Greenwich Land accounts?　9　MR. MAJOR: Objection to form.
10　MR. MAJOR: Objection to form.　10　THE WITNESS: I do not know.
11　THE WITNESS: I don't know.　11　BY MR. LUFT:
12　BY MR. LUFT:　12　Q Where does Greenwich Land get the money
13　Q Ms. Ngok, do you have the right to spend　13　from that it uses to pay for expenses related to the
14　Greenwich Land's money?　14　two houses we've been discussing?
15　MR. MAJOR: Objection to form.　15　MR. MAJOR: Objection to form.
16　THE WITNESS: I believe I do.　16　INTERPRETER: Can the interpreter
17　BY MR. LUFT:　17　reinterpret?
18　Q What are you allowed to spend Greenwich　18　THE WITNESS: I do not know.
19　Land's money on?　19　BY MR. LUFT:
20　MR. MAJOR: Objection to form.　20　Q Who at Greenwich Land would know where it
21　THE WITNESS: It's just like the family　21　gets the money it spends?
22　day-to-day expenditures.　22　MR. MAJOR: Objection to form.
23　BY MR. LUFT:　23　THE WITNESS: I do not know.
24　Q Related to the properties or any　24　BY MR. LUFT:
25　expenditures related to the family?　25　Q Who at Greenwich Land would know who

Page 30　Page 32
1　MR. MAJOR: Objection to form.　1　provides the money that goes into Greenwich Land's
2　THE WITNESS: It's like the family　2　bank accounts?
3　expenditure. For instance, like landscaping,　3　MR. MAJOR: Objection to form.
4　utilities.　4　THE WITNESS: I'm not clear about that.
5　BY MR. LUFT:　5　BY MR. LUFT:
6　Q How about personal expenses not related to　6　Q Do you know who provides the funds that
7　upkeep of the house for -- let me just stop there.　7　have been placed into Greenwich Land's bank accounts
8　MR. MAJOR: Objection to form.　8　since its -- since they've been open till today?
9　THE WITNESS: Sometime, yes.　9　MR. MAJOR: Objection to form.
10　BY MR. LUFT:　10　THE WITNESS: I do not know.
11　Q What personal expenses not related to the　11　BY MR. LUFT:
12　house do you spend Greenwich Land money on?　12　Q Ms. Guo, do any -- sorry. Let me strike
13　MR. MAJOR: Objection to form.　13　that. Let's get some clarity.
14　THE WITNESS: Nothing too specific.　14
15　Ms. Ngok, my understanding is that your
last name is spelled N-G-O-K; is that correct?

16　BY MR. LUFT:
Q Give me your best recollection of personal　16　A Correct.
17　expenses not related to the upkeep of the two houses　17　Q In response -- if we look at Exhibit 3, in
18　you've mentioned for which you've used Greenwich　18　response to our interrogatories, all the references
19　Land money.　19　are either to a "Ms. Guo" or a "Mrs. Guo." So my
20　MR. MAJOR: Objection to form.　20　first question is are you -- is the references to
21　THE WITNESS: I don't remember.　21　"Mrs. Guo" to be understood to be a reference to
22　BY MR. LUFT:　22　you, Ms. Ngok?
23　Q What's the source of Greenwich Land's　23　A Correct.
24　money that is used to pay for personal expenses not　24　Q And are the references to "Ms. Guo" also
25　related to the upkeep of the two houses we've been　25　intended to be a reference to you, Ms. Ngok?
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Page 33 1 A Correct. 2 Q Ms. Guo -- sorry. Let me strike that. 3 (Witness speaking Mandarin.) 4 INTERPRETER: She said she couldn't hear 5 me clear. 6 You okay? 7 (A discussion was held off the 8 stenographic record.) 9 BY MR. LUFT: 10 Q Ms. Ngok, have you ever received money 11 from an entity called Hudson Diamond New York? 12 A I don't remember. 13 Q I'm going to ask the court reporter to 14 mark as Ngok Deposition Exhibit 4 a document Bates 15 stamped 19 (Exhibit 4 was marked for I.D.) 20 MR. MAJOR: Objection to form. To the 21 extent that the question is to ask the witness 22 to read the document and state whether she can 23 identify it, I just want to note for the 24 record, she does not read English so would not 25 have the ability to answer that question. Page 34 1 MR. LUFT: Why don't you let me ask my 2 question and then object to it? 3 MR. MAJOR: Okay. I just didn't know if 4 you -- if your statement was a question. It's not a 7 question, right? 8 BY MR. LUFT: 17 BY MR. LUFT: 18 Q Ms. Ngok -- 19 A Yes. 20 Q -- 22 MR. MAJOR: Objection to form. 23 THE WITNESS: I do not know. 24 BY MR. LUFT: 25 Q Page 35 1 2 MR. MAJOR: Objection to form. 3 THE WITNESS: I do not know. 4 BY MR. LUFT: 5 Q Tell me everything you know about Hudson 6 Diamond New York. 7 A I've never heard of this company before. 8 Q 11 MR. MAJOR: Objection to form. 16 BY MR. LUFT: 19 A Yes. 20 Q 22 MR. MAJOR: Objection to form. 23 THE WITNESS: Page 36 1 MR. LUFT: Okay. Why don't we take a 2 short break? 'Cause I'm going to go for a 3 while after that. 4 MR. MAJOR: Sure. 5 VIDEOGRAPHER: Okay. We're off the 6 record. The time is 11:25. 7 (A recess was taken.) 8 VIDEOGRAPHER: We're back on the record. 9 The time is 11:46. 10 (A discussion was held off the 11 stenographic record.) 12 BY MR. LUFT: 22 MR. LUFT: The document's upside-down for 23 the witness. 24 BY MR. LUFT: 25 Q Ms. Ngok, before you Exhibit 5, as I said,
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Page 41　Page 43

BY MR. LUFT:

BY MR. LUFT:

BY MR. LUFT:

Q Ms. Ngok, what address does Greenwich Land

use for its banking?

MR. MAJOR: Objection to form.

THE WITNESS: I do not know.

BY MR. LUFT:

Page 42　Page 44

INTERPRETER: She's asking a question.　1
THE WITNESS: I do not remember.

THE WITNESS: I am unable to tell.　2
BY MR. LUFT:

BY MR. LUFT:

Q Ms. Ngok, what is the name of the company

that owns your home?

A Let me think about it.

Okay. I -- I struggle with spelling out

the name of the company, so I used to use some

Chinese similar pronunciation to write in Chinese

character. It's called Guan Lei Chi.

INTERPRETER: G-U-A-N L-E-I C-H-I.

BY MR. LUFT:

Q Is that in pinyin? Is that in pinyin?

A Yes, it is pinyin.

INTERPRETER: Ms. Guo -- Ms. Guo recorded

it down in Chinese character; the interpreter

made into pinyin.

MR. LUFT: Okay.

THE WITNESS: (In English) Sorry.

BY MR. LUFT:

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MR. MAJOR: There's no question.

BY MR. LUFT:

BY MR. LUFT:

Q

MR. MAJOR: Objection to form.

THE WITNESS: I do not know.

MR. LUFT: Let's mark as Exhibit 8 a

document bearing the Bates Stamp
22　22
MR. LUFT: Okay. Let's mark as Exh bit 9

(Exhibit 8 was marked for I.D.)　23
a document

INTERPRETER: Thank you.

MR. LUFT: Of course.

BY MR. LUFT:　Page 46

Q And I'll represent to you that this is

anothe　3
(Exhibit 9 was marked for I.D.)

BY MR. LUFT:

A Okay.

BY MR. LUFT:

Q

Q

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Page 53　Page 55

MR. LUFT: Let's mark as Exhibit 11 a　1
MR. MAJOR: Objection to form.

document bearing the Bates stamp　2
THE WITNESS: I can't tell. I can't read.

BY MR. LUFT:

Q

MR. MAJOR: Objection to form.

THE WITNESS: I do not know why.

(Exhibit 11 was marked for I.D.)　9
BY MR. LUFT:

BY MR. LUFT:　10
Q

Q

MR. MAJOR: Objection to form.

MR. MAJOR: Objection to form.　16
THE WITNESS: I do not know.

THE WITNESS: I don't know. I can't -- I　17
BY MR. LUFT:

don't recognize this document.　18
Q

BY MR. LUFT:

Q

MR. MAJOR: Objection to form and assumes

a fact not established.

A I don't remember.　23
MR. LUFT: What fact is that?

Q　24
MR. MAJOR: Multiple facts in your

question -- alleged facts in your question.
Page 54　Page 56
1　1

MR. MAJOR: Objection to form.

THE WITNESS:　6
MR. LUFT: We just walked through all the

BY MR. LUFT:　7
documents, Mr. Major, showing that transfer,

Q Okay.

right? What more foundation could we have?

MR. MAJOR: You're questioning a witness

using English language documents even though

you know she only reads Mandarin and trying to

ask questions off of these documents. So I

objected to the question; I didn't instruct the

MR. MAJOR: Objection to form.　14
witness not to answer. But it's an improper

THE WITNESS: I -- I can't read these　15
question, so I object to it.

words.　16
MR. LUFT: Mr. Major, these are the bank

BY MR. LUFT:　17
records and the statements of your client.

Q　18
That they happen to be in English and you put

up a witness that doesn't speak English is your

choice, but I can only use the records of the

company.

MR. MAJOR: I don't think these are

documents we produced to you, based on the

Bates numbering.

MR. LUFT: You're right, Mr. Major. Some

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1　Page 67

reason for the objection.
The other reason is

she is the only person left at Greenwich Land,

so if she doesn't know, the answer is obvious.

But I can't -- I mean, I guess if you want

me to, I could try to go back if you're asking

MR. MAJOR: Objection to form.　6
me the basis for all of my objections.

THE WITNESS: This one (indicating),　7
MR. LUFT:
No.

right?　8
MR. MAJOR:
I'd have to -- there have been

BY MR. LUFT:　9
a lot of questions.

Q Yes, ma'am. The first line and then the　10
MR. LUFT:
I don't think objecting to

second line.　11
questions because you think the answer is

A Yes, I see it.　12
obvious is a basis for objecting to a

question --

MR. MAJOR:
But the main reason for the

objections is it was a nonsensical question:

You're asking a witness who didn't know a fact

if she knew who knew that fact so --

MR. LUFT:
Well, she's the corporate

representative for the company; this is a house

that the company alleges that it owns.
I don't

think there's anything crazy about asking them

who would know what law firm -- who hired the

law firm that represented them.

So we'll move on.
I understand -- I'm

aware that you made an objection --
Page 66　Page 68

MR. MAJOR: I wasn't instructing the

witness not to answer, and I try to be

extremely judicious when I object so that I

don't interfere with your transcript. And

that's why I've been, as I said, very

circumspect in my objections.

MR. LUFT: Okay.

MR. MAJOR: Or I should say "concise" in

my objections.

BY MR. LUFT:

Q Ms. Ngok, what homes have you lived in

since you've come to the United States? Meaning the

addresses.

the witness answered the question that she did　14
A When I first came to the United States, I

not know. We've given you interrogatory　15
live in town.

responses explaining that Mrs. Guo is the only　16
Q "In town" meaning Manhattan?

person left at Greenwich Land, and then your　17
A Correct.

next question was who at Greenwich Land would　18
Q At the Sherry Netherland hotel?

know what the law firm was?　19
INTERPRETER: Sheraton?

And I objected to that question on a　20
MR. LUFT: Sherry Netherland.

number of grounds, including you're asking a　21
THE WITNESS: Correct.

witness who doesn't -- who just said she　22
BY MR. LUFT:

doesn't know a fact if she knows who knows that

fact that she doesn't know. So the question

doesn't make a lot of sense to me. That's one

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Page 81　Page 83

Q

MR. MAJOR: Objection to form.

THE WITNESS: I do not know why.

BY MR. LUFT:

Q

MR. MAJOR: Objection to form.

THE WITNESS: I do not know.

BY MR. LUFT:

MR. LUFT: And I will mark as Exhibit 14 a

copy of a document Bates

Page 82　Page 84

(Exhibit 14 was marked for I.D.)

BY MR. LUFT:

Q

MR. MAJOR: Objection to form.

THE WITNESS:

Okay.

BY MR. LUFT:　11
BY MR. LUFT:

Q　12
Q And if I ask you to turn to page ending in

Bates number 42 --

MR. MAJOR: I don't think she'll know what

a Bates number is. I can flip it for her or --

okay.

MR. MAJOR: Objection to form.　17
INTERPRETER: I can help her.

THE WITNESS: This one (indicating),　18
MR. MAJOR: Okay, please.

right?　19
THE WITNESS: I'm on it.

BY MR. LUFT:　20
BY MR. LUFT:

Q Yes, ma'am, the third one.　21
Q

A No, it's this (indicating) --

Q Oh, sorry. Yes, correct, ma'am. You're　23
MR. MAJOR: Objection to form. The

right.

A Okay. I see it.　24
witness can't read the words.

THE WITNESS: I'm not -- I can't read. I
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1　Page 85
really can't read.　1
if Greenwich Land holds any ownership interest in　Page 87

2　MR. LUFT: I understand. Not a problem.　2
Saraca Media.
3　BY MR. LUFT:　3
A I do not know.

Q

MR. MAJOR: Objection to form.

THE WITNESS: I am not sure about that.

BY MR. LUFT:

Q

A I do not know.

Q

19　BY MR. LUFT:
20　Q Ms. Ngok, do you have any ownership
21　interest in Saraca Media?
22　A No. I don't know.
23　Q Ms. Ngok, do you have any ownership
24　interest in Hudson Diamond New York?
25　A What do you mean by that?　25
MR. MAJOR: Objection to form.
Page 86　Page 88
1　Q My question, I'll ask it in two ways: Do　1
THE WITNESS: I don't know.
2　you personally, Ms. Ngok, have any ownership　2
BY MR. LUFT:
3　interest in the entity named Hudson Diamond New
4　York?
5　A I don't remember. I don't even understand
6　what he means by that.
7　Q Ms. Ngok, does Greenwich Land have any
8　ownership interest in Hudson Diamond New York?
9　A I do not know.
10　Q Does Greenwich Land have any ownership
11　interest in Saraca Media?
12　A I'm a little confused. I really don't
13　know.
14　Q That's okay. That's no worries.
15　MR. MAJOR: If she's not well, she
16　should -- you can take her out.
17　MR. LUFT: Okay. Let's take a break. Off
18　the record. Let's go off the record before --
19　VIDEOGRAPHER: The time is 3:20. Off the
20　record.　20
(Exhibit 15 was marked for I.D.)
21　(A recess was taken.)　21
MR. LUFT: And would it be okay for us to
22　VIDEOGRAPHER: We're back on the record.　22
just email a copy of it?
23　The time is 3:50.　23
COURT REPORTER: Sure.
24　BY MR. LUFT:　24
MR. LUFT: All right. So that's what
Q Ms. Ngok, before we broke, I had asked you　25
we'll do.

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Page 89　Page 91

1　MR. MAJOR: I could also print it for you　1　MR. MAJOR: Objection to form.
2　today.　2　THE WITNESS: I don't remember.
3　MR. LUFT: That would be great too. I'm　3　BY MR. LUFT:
4　happy to do it either way.　4　Q Okay. No problem.
5　MR. MAJOR: Email it to me and I'll print　5
6　it.
7　MR. LUFT: Perfect. Okay.
8　BY MR. LUFT:　8　A I don't remember.

9　Q Ms. Ngok, earlier you told me that　9　Q
10　Greenwich Land sold the house at 33 Ferncliff Road
11　in Greenwich, Connecticut. Do you recall that?
12　A Yes, I remember.
13　Q Okay. And do you -- and do you recall　13　A I don't remember.
14　that that　14　Q

17　A I don't remember clearly.　17
18　Q

off the record.)

22　THE WITNESS: I don't remember.　22　BY MR. LUFT:
23　MR. LUFT: Okay. Let's mark as　23　Q That's okay.
24　Exhibit 16,　24

Page 90　Page 92
1　1
2　A I don't remember.
3　Q

6　A I have gone to view the house before.

were marked for I.D.)　7　Q I appreciate -- that's helpful.
8　BY MR. LUFT:　8
9　Q Ms. Ngok, my first question is simple:
13　A Where is the dates?　13　A It was me.
14　Q　14　Q Okay. And when did you make that
15　decision?
16　A I don't remember very clearly.

17　MR. MAJOR: Objection to form.　17　Q Okay.
18　BY MR. LUFT:
19　Q

25　A I don't remember.
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Page 93　Page 95

1　Q　1
2　BY MR. LUFT:
3　Q Okay. And do you see --
4　A I don't.　4　A
5　Q　5　Q Understood.
9　A I do not remember.
10　Q Okay. I'm going to show you a document　10　MR. MAJOR: Objection to form.
11　that I'll ask the court reporter to mark as　11　THE WITNESS: Okay.
12　BY MR. LUFT:
12　Exhibit 18, which has a control number on it of
13　00016119. That number is the number for the entire　13　Q
14　document. It was produced to us without Bates
15　stamps, so just for clarity, we put a control number
16　on it.　16　MR. MAJOR: Objection to form.
17　17　THE WITNESS: I really do not remember.
18　BY MR. LUFT:
19　Q Okay. Let me show you another document.
20　MR. LUFT: Let's mark as Exhibit 19 --
21　(Exh bit 18 was marked for I.D.)　21　COURT REPORTER: Sorry.
22　THE WITNESS: Okay.　22　MR. LUFT: Sorry.
23　BY MR. LUFT:　23　-- a document bearing the control stamp
24　Q Ms. Ngok, do you recognize this document?　24　CTRL00016119, which purports to be
25　MR. MAJOR: Objection to form.
Page 94　Page 96
1　THE WITNESS: I -- I'm sure I'm not able　1
2　to recognize it.
3　BY MR. LUFT:　3　(Exhibit 19 was marked for I.D.)
4　Q Okay. Well, let's see if we can find　4　THE WITNESS: Okay.
5　something you recognize.　5　MR. MAJOR: Object
6　6　BY MR. LUFT:
7　Q

12　A Can you point it out to me which page it

is?
14　Q Of course, ma'am. I can show you on mine.
15　I'm about eight pages in --

16　MR. LUFT:

18　THE WITNESS: You mean this page
19　(indicating)?
20　BY MR. LUFT:
21　Q
22　INTERPRETER: Sorry.
23　BY MR. LUFT:
24　MR. MAJOR: Objection to form.　24　Q
25　THE WITNESS:
,

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A I don't remember.

Q Okay. You can put that aside.

A Okay.

Q Let me show you, then --

MR. LUFT: Let's mark as Exhibit 20 --

(A discussion was held off the

stenographic record.)

MR. LUFT: We'll mark as Exhibit 20 a

document with the control number CTRL00016119.

Again, this is a multipage document that was

produced to us without Bates stamps, so we just

put it on there.
15　Page 99

THE WITNESS: No, it's not.

MR. LUFT: It's -- I don't want to say it,

'cause I assume you don't want her social

security number in the record so

MR. MAJOR:

MR. LUFT: Well

BY MR. LUFT:

Q

A You mean this one (indicating)?

Q Yes, ma'am.

A

(Exhibit 20 was marked for I.D.)

THE WITNESS: Okay.

BY MR. LUFT:

Q

of you.

A Where did you see page No. 7?

Q　23
MR. LUFT: Completely fair.

THE WITNESS: I do not -- I don't speak

English, I don't understand English, and I

BY MR. LUFT:

Q

MR. MAJOR: Can I just flip to it for her?

MR. LUFT: I -- I did. She has it.

THE WITNESS: I am on it, but I don't know

if that's the correct one.

BY MR. LUFT:

Q That's the correct -- you're on the same

page as me.

A　don't remember. I really don't

remember.

Q Okay.

THE WITNESS: No, it is not either.

MR. LUFT: No, it's not -- it's　25
A It's an apartment? It's an apartment?
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MR. MAJOR: Objection to form.

THE WITNESS: Okay. I see it.

BY MR. LUFT:

Q

MR. MAJOR: Objection to form.

THE WITNESS: Yes.

BY MR. LUFT:

Q

MR. MAJOR: Objection to form.

THE WITNESS: I do not know.

BY MR. LUFT:

Q

MR. MAJOR: Objection.

THE WITNESS: I don't know.

BY MR. LUFT:
reporter to mark as Exhibit 21 another document

BY MR. LUFT:

Q Does anyone at Greenwich Land know the

answer to that question?

MR. MAJOR: Objection to form.

THE WITNESS: Can you repeat?

MR. LUFT: Sure.

BY MR. LUFT:

Q Does anyone at Greenwich Land know the

answer to that question?

MR. MAJOR: Objection to form.

THE WITNESS: Me too don't know.

MR. LUFT: Okay. Ms. Ngok, I want to

be -- it's warm in here. How are you feeling?

And do you need a break?

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Page 113　Page 115

1　Ms. Ngok, do you know what Bento　1
THE WITNESS: I don't remember.
2　Technologies is?　2
BY MR. LUFT:
3　A I do not know.　3
Q
4　Q Ms. Ngok, you previously told me you have
5　a debit card for Greenwich Land -- for a Greenwich
6　Land account?
7　A I don't know what it is. It's -- I call
8　it the "consumer" card. I can use it to consume
9　things, but I don't know what you call it.
10　Q Ms. Ngok, that card is issued by Bento　10
MR. MAJOR: Objection to form.
11　Technologies, correct?　11
THE WITNESS: I don't remember clearly.
12　MR. MAJOR: I've just been advised that　12
BY MR. LUFT:
13　there may have been a part missing from the　13
Q Okay.
14　translation. She said something about not

15　taking money out of the card.
16　(Ms. Song speaking Mandarin.)
17　(The reporter requested clarification.)
18　MS. SONG: So she just mentioned that she　18
A I do not know.
19　never tried to take money out using that Bento　19
Q Okay. In the interest of trying to save
20　card and that she just used it to make some　20
some time, I'm going to ask you a question that
21　consumptions. So the part of --　21
consolidates a number of these exhibits. But if you
22　MR. LUFT: You can't take down her　22
need me to break any of it up, please let me know.
23　testimony.
24　INTERPRETER: Can the interpreter
25　reinterpret?
Page 114　Page 116
1　MR. LUFT: That's perfectly fine.
2　INTERPRETER: Yeah, that's the proper way
3　to do it.
4　(Interpreter speaking Mandarin.)
5　THE WITNESS: Okay. I don't know what it
6　is called. I call it the "consumer" card. I
7　can use it to consume -- buy things, but I
8　never withdrawal any cash out of it. But I
9　don't know what you call it.
10　MR. LUFT: Okay. Everyone good with that?
11　That's okay? Okay.
12　BY MR. LUFT:
13　Q Okay.

24　INTERPRETER: I'm sorry.
25　MR. MAJOR: Objection to form.

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Page 121　Page 123

the record; you don't have to do anything with them　1

right now.

MR. LUFT: I marked a document bearing --

as Exhibit 34 bearing the Bates stamp
5　5
Chris, do you want her to translate all

that or?

MR. MAJOR: I'm okay not translating all

that.

As Exhibit 35, the next in that series,　9
MR. LUFT: Okay.
10　10
THE WITNESS: Okay. I'll just give a gist

of it.

MR. LUFT: You can just tell her that I --

INTERPRETER: Oh, sorry. Just give me one

(A discussion was held off the　14
second.

stenographic record.)　15
(Interpreter speaking Mandarin.)

MR. LUFT: Exh bit -- we've marked as　16
THE WITNESS: Okay.

Exhibit 36 another　17
BY MR. LUFT:

Q Ms. Ngok, I'll ask you to turn to -- if

you could just pull out Exhibit 22 and Exhibit 33.

We marked as Exhibit 37 a

INTERPRETER: Sorry.

MR. LUFT: Go ahead.

THE WITNESS: Yes.

Page 122　Page 124

Exhibit -- we marked as Exhibit 38　1
BY MR. LUFT:

Q

We marked as Exhibit 39

MR. MAJOR: Objection to form.

THE WITNESS: I see it.

BY MR. LUFT:

Q

We marked as Exhibit 40

And we marked as Exhibit 41　16
MR. MAJOR: Objection to form.

THE WITNESS: Which date?

MR. LUFT:

THE WITNESS: Yes, I see it.

We marked as Exhibit 42　20
BY MR. LUFT:

Q Okay. In the interest of trying to save

time

And as Exhibit 43,

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Page 125　Page 127

1　1
BY MR. LUFT:

Q Ms. Ngok, who had the authority to write

checks on behalf of Greenwich Land's bank account at

The First Bank of Greenwich?

MR. MAJOR: Objection to form.

INTERPRETER: Thank you.　6
THE WITNESS: I do not know.

MR. LUFT: Thank you.　7
BY MR. LUFT:

THE WITNESS: I understand.　8
Q Who at -- who at Greenwich Land had to

BY MR. LUFT:　9
authorize the writing of checks from Greenwich

Q　10
Land's bank account at The First Bank of Greenwich?

MR. MAJOR: Objection to form.

THE WITNESS: I do not know.

BY MR. LUFT:

Q Ms. Ngok, are you familiar with a company

called Gypsy Mei -- M-E -- "Mei" is spelled M-E-I,

A Yes.　16
same as your daughter's -- Food Service, LLC?

Q　17
A I am not familiar with this.

MR. LUFT: Okay. So let's mark as

Exhibit 45 a document bearing the Bates stamp

HR0003000 through 32, titled "Minute Book of

Gypsy Mei Food Services, Hodgson Russ,

Attorneys."

(Exhibit 45 was marked for I.D.)

BY MR. LUFT:

MR. MAJOR: Objection to form.
Page 126　Page 128

THE WITNESS: I do not know.

BY MR. LUFT:

Q Okay. We're going to come back to these,

but for now you can put them to the side for a

second.

(A discussion was held off the

stenographic record.)

BY MR. LUFT:

Q Ms. Ngok, I'm going to ask the court

reporter to mark as Exhibit 44 a document produced

to us by

The document bears the Bates stamp -- or

control number CTRL00016116.　24
BY MR. LUFT:

(Exhibit 44 was marked for I.D.)

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Page 145　Page 147

1　MR. MAJOR: That's fine.　1　Max Krasner resigned from his position at Greenwich
2　BY MR. LUFT:　2　Land. Are you aware of those statements to the
3　Q Okay. And specifically, Interrogatory　3　court?
4　No. 6 asks Greenwich Land to "Identify all employees　4　A I do not know.
5　of Greenwich Land, including directors and officers,　5　MR. MAJOR: Just objection. I just want
6　and the role of each identified individual."　6　to -- it's fine, the answer is out. But just
7　And in response Greenwich Land stated that　7　because it dealt with the court, I was going to
8　you are presently the sole member of Greenwich Land　8　put in an objection regarding privilege. But
9　and Greenwich Land presently has no separate　9　she's already answered it and it didn't reveal
10　manager, officers, or employees. And then it says　10　any privileged communication. So I pardon the
11　Greenwich Land previously had officers. Yvette　11　interruption, but I just wanted to note that
12　Wang, Daniel Podhaskie, and Max Krasner previously　12　since I had already interrupted, just telling
13　served in the roles of vice president of Greenwich　13　you why.
14　Land. All of them resigned before the end of 2022?　14　(A discussion was held off the
15　INTERPRETER: End of 2022?　15　stenographic record.)
16　MR. LUFT: Yes, that's what it says.　16　THE WITNESS: Okay.
17　BY MR. LUFT:　17　BY MR. LUFT:
18　Q Ms. Ngok, was that information correct　18　Q Ms. Ngok, if it helps refresh your
19　when you signed and verified these interrogatories?　19　recollection, if you look at page 6 of your
20　MR. MAJOR: Objection to form.　20　interrogatories, under "Right to Supplement," it
21　THE WITNESS: Yes.　21　references language related to Max Krasner resigning
22　BY MR. LUFT:　22　on November 5, 2022. Does that refresh your
23　Q Okay. So is it fair to say that, to　23　recollection that someone by the name of Max Krasner
24　Greenwich Land's knowledge, Chunguang Han was never　24　resigned from Greenwich Land on November 5, 2022?
25　a manager, officer, or employee of Greenwich Land?　25　MR. MAJOR: Objection to form.

1　Page 146
MR. MAJOR: Objection to form.　1　Page 148
(A discussion was held off the
2　THE WITNESS: I've never heard about it.　2　stenographic record.)
3　BY MR. LUFT:　3　THE WITNESS: Which page?
4　Q Okay. Is it also fair to say that your　4　BY MR. LUFT:
5　daughter, Mei Guo, has also never been a manager,　5　Q Page 6.
6　director, or officer of Greenwich Land -- or　6　A I can't read it.
7　employee.　7　Q That's okay.
8　MR. LUFT: Sorry.
9　INTERPRETER: Sorry.
10　THE WITNESS: How do I put it? Well, I
11　don't know.
12　BY MR. LUFT:
13　Q Okay. Well, when you signed the
14　interrogatory -- certified -- signed the
15　interrogatories to certify the answer, did Greenwich
16　Land have any reason to believe that Mei Guo has
17　been an employee, director, or officer of Greenwich
18　Land, such that she should be included in the
19　answer?
20　MR. MAJOR: Objection to form.
21　THE WITNESS: I'm not sure about that.　21　BY MR. LUFT:
22　BY MR. LUFT:　22　Q Okay. Do you see if, when we look at the
23　Q Okay. And, Ms. Ngok, Greenwich Land has　23　exhibits --
24　filed documents with the court in this case stating　24　INTERPRETER: Okay. The interpreter would
25　that on November 5, 2022, a person by the name of　25　like to rectify the answer. The answer is "I'm

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Page 153　Page 155

(Exhibit 47 was marked for I.D.)

MR. LUFT: I'm going to ask the court

reporter to mark as Exhibit 48　6
MR. MAJOR: Objection to form.

THE WITNESS:

(Exhibit 48 was marked for I.D.)

MR. LUFT: I'm going to ask the court

reporter to mark as Exhibit 49　12
BY MR. LUFT:

(Exhibit 49 was marked for I.D.)　16
MR. MAJOR: Objection to form.

MR. LUFT: And I'll ask the court reporter　17
THE WITNESS:

to mark Exhibit 50

BY MR. LUFT:

(Exhibit 50 was marked for I.D.)　22
Q Okay. Well, Ms. Ngok, let's just go to

MR. LUFT:　23
our most recent one, which is from -- well, let me

strike that. Let me find one that may stick out a

bit more.

1　Page 156

And -- well, let me first -- let me strike

that.

(The following testimony was deemed highly

confidential.)

BY MR. LUFT:

MR. MAJOR: Objection to form.　6
Q

THE WITNESS: I'm not able to read this

document.

BY MR. LUFT:

Q　10
(The reporter requested clarification.)

BY MR. LUFT:

INTERPRETER: Can I have the question

again, sir?

MR. LUFT: You could just strike it.

BY MR. LUFT:

Q

MR. MAJOR: Hold on. Hold on. I don't

want to have any attorney-client privileged

A Yes.　21
communications put on the record. So I just

Q　22
want to -- I don't know what the best thing to

do is, but I'd like to maybe -- and I have no

idea what the rest of the answer was, so I

don't know if it just a passing reference or

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Page 161　Page 163

BY MR. LUFT:

24　BY MR. LUFT:
25　Q Ms. Ngok, are you familiar with the

Page 162　Page 164

THE WITNESS: I don't know.　1　restaurant Henry Cipriani, which is in the same
BY MR. LUFT:　2　building as the Sherry Netherland apartment?
3　A I am not familiar.

13　BY MR. LUFT:
14　Q Ms. Ngok, have you personally ever eaten
15　at Henry Cipriani [sic], which is located in the
16　same building as the Sherry Netherland hotel?
17　A Yes, I have dined in the same -- in that

18　restaurant before, but that was years back when I
19　first came to the United States, probably in the
20　year of 2017.

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Page 165　Page 167

THE WITNESS: I only have breakfast in the

restaurant when I first came to the United

States back in 2017.

BY MR. LUFT:

Q But he is a person who has signed --

opened bank accounts and signed documents on behalf

of Greenwich Land, correct?

MR. MAJOR: Just objection to form.

I'm sorry.

THE WITNESS: I don't know about that.

BY MR. LUFT:

(Exhibit 51 was marked for I.D.)

BY MR. LUFT:

Q

Page 166　Page 168

A I don't remember.

Q Okay. Let me show you -- let's mark as

Exhibit 52 a

(Exhibit 52 was marked for I.D.)

BY MR. LUFT:

Q

form.

THE WITNESS:

BY MR. LUFT:

Q

MR. MAJOR: Objection to form.

THE WITNESS: I don't remember.

MR. LUFT: Okay. Let's mark as --

MR. MAJOR: Can I just ask a question on

Exhibit 52?

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Page 173　Page 175

BY MR. LUFT:　1
later?

Q What if -- please tell me --　2
MR. MAJOR: Objection to form.

A I do not know who.　3
THE WITNESS: I do not know.

INTERPRETER: Sorry.　4
BY MR. LUFT:

MR. LUFT: Okay.　5
Q

BY MR. LUFT:

A I do not know.

Q Ms. Ngok, are you familiar with someone by

MR. LUFT: Okay. Let's mark as Exhibit 55　10
the name of Dinggang Wang?

a　11
INTERPRETER: Can I have the spelling of

the name, sir?

MR. LUFT: D-I-N-G-G-A-N-G, space, Wang,

(Exhibit 55 was marked for I.D.)　14
W-A-N-G.

BY MR. LUFT:　15
THE WITNESS: I am not familiar.

BY MR. LUFT:

Q

A I do not know.

Q Okay. Ms. Ngok, I'm going to have marked

as Exhibit -- what are we up to, 56? -- 56 documents

entitled "Residential Lease Renewal Agreement,"

between Greenwich Land, LLC, and Wang Dinggang.

(Exhibit 56 was marked for I.D.)

A I don't know. I don't know why.　25
Page 174　Page 176

(A discussion was held off the record.)　1
BY MR. LUFT:

BY MR. LUFT:

Q　2
Q Ms. Ngok, do you recognize this document?

A I don't remember.

Q Did you ever authorize Greenwich Land to

lease 33 Ferncliff to a man named Dinggang Wang?

A I don't remember.

Q Ms. Ngok, I'm going have the court

reporter mark as Exhibit 57 a copy of a document

entitled "Residential Lease Renewal Waiver

MR. MAJOR: Objection to form.　10
Agreement," which is an agreement between, again,

THE WITNESS: I really do not know why.　11
Greenwich Land, LLC, and Mr. Wang Dinggang dated

BY MR. LUFT:　12
October 9, 2020.

Q　13
(Exhibit 57 was marked for I.D.)

BY MR. LUFT:

Q Ms. Ngok, who authorized Greenwich Land to

enter into this agreement with Mr. Dinggang Wang

related to he and his family living at 33 Ferncliff?

MR. MAJOR: Objection.　18
MR. MAJOR: Objection to form.

THE WITNESS: I do not understand your　19
THE WITNESS: I'm not sure.

question.　20
BY MR. LUFT:

BY MR. LUFT:　21
Q Okay. Ms. Ngok, is part of Greenwich

Q　22
Land's business to do media consulting?

A I'm not sure.

Q You're the sole member of Greenwich Land.

Are you aware of any media business that Greenwich

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Page 181　1　Page 183
INTERPRETER: Can the interpreter clarify?

2　I was still interpreting the first question;
3　MR. LUFT: Let's mark as Exhibit 59 a　3　you asked a second question. Can the
4　document titled "Retail Fuel Delivery and
4　interpreter reinterpret?
5　Service Agreement," dated February 6, 2020,　5　MR. LUFT: And then she answered the
6　under the name of Ho Wan Kwok for the address　6　question, correct?
7　of 30 Ferncliff Road [sic].　7　INTERPRETER: Yes, she answered the
8　(Exhibit 59 was marked for I.D.)　8　question. She said yes.
9　(A discussion was held off the　9　MR. LUFT: To my first question, and
10　stenographic record.)　10　then --
11　MR. LUFT: Guys, I have to ask for a copy　11　MR. MAJOR: I don't know -- I disagree
12　back. Sorry. Thank you.　12　with that.
13　BY MR. LUFT:　13　MR. LUFT: You can't disagree. She's the
14　Q Ms. Ngok, this is a fuel delivery　14　interpreter, Chris. She's telling you that's
15　agreement --　15　what happened.
16　MR. MAJOR: Wait. Hold on. The -- you　16　MR. MAJOR: I'm talking about the order of
17　just took our copies back and --　17　the questions.
18　MR. LUFT: I didn't take your copies. You　18　MR. LUFT: Do you speak Chinese?
19　have two lawyers; I gave you one. You guys　19　MR. MAJOR: First of all, that's not a
20　still have one, right?　20　language but -- and you've been saying that all
21　MR. MAJOR: No, we gave them both back.　21　day but
22　You said it was the wrong document.　22　MR. LUFT: It's not? No, there are two
23　MR. LUFT: No, I just needed a copy.　23　dialects I think you're referring to, but
24　MR. MAJOR: Ah, okay.　24　there's obviously a language of Chinese, and
25　25　Mandarin is commonly referred to as "Chinese."

Page 182　Page 184
1　BY MR. LUFT:　1　Let's not waste time.
2　Q Ms. Ngok, this is a retail fuel delivery　2　MR. MAJOR: Hold on.
3　and service agreement dated February 6, 2020, for　3　MR. LUFT: Chris, I understand there's ten
4　the address 33 Ferncliff Road, Cos Cob, Connecticut,　4　minutes; I understand you're trying to run it
5　under the name of Ho Wan Kwok.　5　out all of a sudden with all these --
6　MR. MAJOR: Objection to form.　6　MR. MAJOR: I'm not trying to run it out.
7　BY MR. LUFT:　7　You asked a compound question; I'm objecting to
8　Q 33 Ferncliff Road is the house Greenwich　8　the compound question.
9　Land owned, correct? And Ho Wan Kwok is the name of　9　MR. LUFT: Okay.
10　your husband, correct?　10　Ms. Interpreter, can you please explain
11　MR. LUFT: She just answered something,　11　what happened?
12　echo. You got to translate it.　12　(The reporter requested clarification.)
13　MR. MAJOR: Hold on. I have -- it's a　13　INTERPRETER: Can -- the interpreter was
14　compound question. You asked her what the　14　still interpreting the first question and
15　document was --　15　Ms. -- Ms. Guo actually answered the second
16　MR. LUFT: She answered and it wasn't　16　question while I was interpreting them.
17　translated, Chris.　17　Can the interpreter reinterpret both the
18　MR. MAJOR: No, but you asked two　18　questions?
19　questions at once.　19　MR. LUFT: Why don't I just withdraw it
20　MR. LUFT: No, Chris, it just wasn't　20　and we'll just do it very quick?
21　translated. She answered.　21　INTERPRETER: Okay, then.
22　MR. MAJOR: I'm looking at the realtime,　22　BY MR. LUFT:
23　and I heard you --　23　Q Exhibit 59 says 33 Ferncliff Road, which
24　MR. LUFT: Whatever the -- 'cause Echo　24　is a house you had previously told me was owned by
25　didn't translate it, Chris.　25　Greenwich Land, the name on the account of -- is Ho
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Page 185　Page 187

1　Wan Kwok. That is your husband, correct?　1　BY MR. LUFT:
2　MR. MAJOR: Objection to form, including
3　compound.
4　THE WITNESS: I never said that the
5　33 Ferncliff Road house is under my husband's
6　name.
7　BY MR. LUFT:　7　BY MR. LUFT:
8　Q No, I understand that. The document --
9　but Exhibit 59, which is the fuel agreement, states
10　that 33 Ferncliff Road is under your husband's name,
11　correct?
12　MR. MAJOR: Objection to form.
13　THE WITNESS: I still do not know what
14　this document means, even right now.
15　BY MR. LUFT:
16　Q Ms. Ngok, do you have any involvement with

17　paying the fuel bill for -- did you have any　17　MR. LUFT: Ms. Ngok, I have no further
18　involvement with paying the fuel bill for　18　questions at this time. Thank you very much
19　33 Ferncliff Road?　19　for what has been long and a very hot day in
20　A You mean fuel? What is it?　20　this room.
21　Q Yes.　21　THE WITNESS: Thank you, everybody. It
22　A It's like gasoline?　22　has been a hard day for everyone. Thank you so
23　Q The fuel that heats the home.　23　much.
24　A And then? Then what?　24　MR. MAJOR: Actually, I just want to put
25　Q My question is did you have any　25　two -- I'll be very, very quick. I'd like to
Page 186　Page 188
1　involvement in paying for the fuel bill for　1　mark the video and then the still images
2　33 Ferncliff Road?　2　thereof highly confidential for security
3　A I don't remember.　3　reasons.
4　Q Let me show you another document.　4　I'd like to reserve the right, as
5　MR. LUFT: We're going to mark as　5　ridiculous as it may sound, to read and sign.
6　Exhibit 60 a copy of a Petro Home Services bill　6　I just don't want to let that go. I know it's
7　to Ho Wan Kwok at 33 Ferncliff Road, Cos Cob,　7　a logistical situation and we may well not do
8　Connecticut.　8　that, but I just want to reserve that right.
9　(Exhibit 60 was marked for I.D.)　9　MR. LUFT: Okay.
10　BY MR. LUFT:　10　COURT REPORTER: And can I just get the
11　Q Ms. Ngok, do you see that this a copy of a　11　orders on the record?
12　fuel bill for 33 Ferncliff Road in the name of your　12　MR. LUFT: Sure. We'd like the rough and
13　husband, Ho Wan Kwok?　13　expedited.
14　MR. MAJOR: Objection to form.　14　MR. MAJOR: And I just ask that the
15　THE WITNESS: I see his name, yes, but I　15　transcript be marked "Confidential" except
16　don't recognize any other information on this　16　where we marked it "Highly confidential," and
17　page.　17　then we'll give it a review. And if there are
18　MR. LUFT: Let's go off the record for a　18　spots that don't need to be marked, we'll deal
19　minute.　19　with that then.
20　VIDEOGRAPHER: We're off the record. The　20　MR. LUFT: I will -- I don't agree that
21　time is 8:53.　21　everything on the record should be
22　(A recess was taken.)　22　confidential. And that's going to create a
23　VIDEOGRAPHER: We're back on the record.　23　major headache for the court when they have to
24　The time is 9:01.　24　use this, including the fact that we all have
25　25　to make any use of it and any filings, both in

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Page 189　Page 191

1　court and in briefs, confidential. I don't　1　C E R T I F I C A T E
2　think there's any basis, other than where we　2　I hereby certify that I am a Notary Public,
3　have specified that things should be marked　3　in and for the State of Connecticut, duly
4　"Confidential" or "Highly confidentially," to　4　commissioned and qualified to administer oaths.
5　say that the rest of the record needs to be　5　I further certify that the deponent named in
6　marked "Confidential" for the entire　6　the foregoing deposition was by me duly sworn, and
7　deposition.　7　thereupon testified as appears in the foregoing
8　MR. MAJOR: I was just saying it for a　8　deposition; that said deposition was taken by me
9　period of time, to allow us to review the　9　stenographically in the presence of counsel and
10　reduced to typewriting under my direction, and the
10　transcript to see if there's anything we want　11　foregoing is a true and accurate transcript of the
11　to mark "Confidential." We can deal with that　12　testimony.
12　off the record.　13　I further certify that I am neither of
13　And then, in terms of the order, I'll take　14　counsel nor attorney to either of the parties to
14　a -- I think regular delivery will be fine.　15　said suit, nor am I an employee of either party to
15　And I'm sure it includes it, but a mini as　16　said suit, nor of either counsel in said suit, nor
16　well.　17　am I interested in the outcome of said cause.
17　COURT REPORTER: And did you want a rough?　18　Witness my hand and seal as Notary Public
18　Sorry.　19　this 13th day of September, 2023.
19　MR. MAJOR: I don't think we need a rough,　20
20　but if we do, we'll reach out to you. Is that　21　_______________________________
21　okay?　Deborah Gentile
22　COURT REPORTER: Sure.　22　Notary Public
23　THE WITNESS: Thank you.　23
24　MR. LUFT: Thank you, everyone.　24　My commission expires:
October 31, 2026
25　MS. SONG: Thank you.　25
Page 190　Page 192
1　VIDEOGRAPHER: This is concludes today's　1
2　deposition. We're off the record at 9:05 p.m.　2　INDEX OF EXAMINATIONS
3　(The deposition concluded at 9:05 p.m.)　3
4　PAGE
DIRECT EXAMINATION BY MR. LUFT

4　5
5　6
7　INDEX OF EXHIBITS
TRUSTEE'S EXHIBITS MARKED FOR I.D.
6　8　Exhibit 1
- Notice of Deposition, Ms. Ngok

7　9　Exhibit 2 - Notice of Deposition, Greenwich

Land, LLC
8　10
9　Exhibit 3 - Greenwich Land's Supplemental

10　11　Responses to Interrogatories,
9/9/23
11　12
12　Exhibit 4 -
13　14　Exhibit 5 -

15　15　Exhibit 6 -

17　17　Exhibit 7 -
18　18
19　Exhibit 8 -
20　20　Exhibit 9 -

21　21　Exhibit 10 -

23　23　Exhibit 11 -
24　24
25　25

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Page 193　Page 195

INDEX OF EXHIBITS (CONT'D)　1

INDEX OF EXHIBITS (CONT'D)

TRUSTEE'S EXHIBITS MARKED FOR I.D.
4　3
TRUSTEE'S EXHIBITS MARKED FOR I.D.

Exhibit 12 -　Exhibit 35 -

Exhibit 13 -　Exhibit 36 -

Exhibit 14 -　1
Exhibit 37
Exhibit 15
ਰੇ　Exhibit 38
ਰੇ
10　10
Exhibit 16　Exhibit 39
Exhibit 17 -
12　Exhibit 40

13　13
Exhibit 41 -
Exhibit 18 -　15
Exhibit 42

Exhibit 19　16

Exhibit 20　Exhibit 43 -
Exhibit 21 -
18　Exhibit 44 -

19　Exhibit 45 - "Minute Book of Gypsy Mei Food

Services "
Exhibit 22 -　21
Exhibit 46 - TRO and Preliminary Injunction,

3/28/23

Exhibit 23 -　22
Exhibit 47 -

23　Exhibit 48 -

25　25
Page 194　Page 196

INDEX OF EXHIBITS (CONT'D)　1

INDEX OF EXHIBITS (CONT'D)

TRUSTEE'S EXHIBITS MARKED FOR I.D.
4　3
TRUSTEE'S EXHIBITS MARKED FOR I.D.

Exhibit 24 -　Exhibit 49
Exhibit 25 -
6　Exhibit 50

Exhibit 26 -
8　7
Exhibit 51 -
Exhibit 52
ರಿ

Exhibit 27 -
10　10
Exhibit 53 -
Exhibit 28
12　12
Exhibit 54
Exhibit 29 -
। ব　13
Exhibit 55 -

Exhibit 56 - Residential Lease Renewal
Agreement, Mr. Wang
Exhibit 31
18　16
Exhibit 57 - Residential Lease Renewal Waiver

Agreement, Mr. Wang, 10/9/20

Exhibit 58

Exhibit 32 -　19
21　Exhibit 59 - Retail Fuel Delivery and Service

Agreement, 2/6/20
Exhibit 33 -　Exhibit 60 - Petro Home Services Bill, 33

Ferncliff Road

Exhibit 34　22
(Reporter's note:  Exhibits attached to original.)

25　24

A FOOTTIDE