Guo Wengui / Miles Guo — bankruptcy case · EXHIBIT · ECF #250-17

Transcript of the 341 Meeting of Creditors, dated March 21, 2022

In Re UNITED STATES BANKRUPTCY COURT DISTRICT OF CONNECTICUT \* Chapter 11 \* \* HO WAN KWOK, \* Case 22-50073(JAM) \* Debtor. \* \* \* \* \* \* \* \* \* \* \* \* \* \* \* \* \* \* TRANSCRIPT OF TELEPHONIC 341 MEETING OF CREDITORS MARCH 21, 2022 Electronically Recorded by the Office of the United States Trustee Transcript Prepared By: Christine Fiore, CERT Fiore Reporting and Transcription Service, Inc. 4 Research Drive, Suite 402 Shelton, CT 06484 (203) 929-9992

Ho Wan Kwok - March 21, 2022 APPEARANCES: For the Debtor: For the U.S. Trustee: For Logan Cheng, Creditor: For Pacific Alliance Asia Opportunity Fund, LP, Creditors: For Bruno Wu, Weican Meng and Rui Ma, Creditors: For Xiaodan Wang, Rong Zhang and Chong Shen Raphanella, Creditors: WILLIAM R. BALDIGA, ESQ. BEN SILVERBERG, ESQ. URI PINELO, ESQ. Brown Rudnick, LLP Seven Times Square New York, NY 10036 HOLLEY E. CLAIBORN, ESQ. Office of the U.S. Trustee 150 State Street New Haven, CT 06510 JAY MARSHALL WOLMAN, ESQ. Randazza Legal Group 100 Pearl Street, 14th Floor Hartford, CT 06103 DAVID V. HARBACH, II, ESQ. O'Melveny & Myers, LLP 1625 I Street NW Washington, DC 20006 STUART SARNOFF, ESQ. LAURA ARONSSON, ESQ. CRAIG McALLISTER, ESQ. MAKENZIE RUSSO STEVEN WARREN O'Melveny & Myers, LLP Times Square Tower 7 Times Square New York, NY 10036 KAREN WARSHAUER McElroy, Deutsch, Mulvaney & Carpenter One State Street Hartford, CT 06103 LILLIAN GRINNELL, ESQ. Wolf Haldenstein Adler Freeman & Herz 270 Madison Avenue New York, NY 10016

For Samuel Nunberg, Creditor:

For the Sherry Netherland, Creditor: AMY ZAMIR, ESQ. Nesenoff & Miltenberg, LLP 363 Seventh Avenue New York, NY 10001 EMILY KUZNICK, ESQ. Stroock, Stroock and Lavan 180 Maiden Lane New York, NY 10038 Case 22-50073 Doc 250-17 Filed 04/22/22 Entered 04/22/22 16:59:37 Page 5 of

MS. CLAIBORN:

apologize. 4 I'm going to basically start this meeting 5 over again and we're going to go very quickly and

7 go.

9 are gathered for the Section 341 meeting in the

11 and Miles Kwok.

13 attorney in the Office of the United States Trustee 14 will be conducting today's meeting.

15 am recording this meeting and also we

16 have the presence of an interpreter on the line 17 whose name is Bin, B-I-N.

19 third time about her oath.

21 For purposes of speeding this up on the 22 record we have appearances today by Jay Wolman,

23 behalf of Logan Cheng.

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Aronsson, Craig McAllister and Mackenzie Russo, 2 on behalf of Pacific Alliance.

4 a paralegal at McElroy.

INTERPRETER:

6 those names at once.

MS. CLAIBORN: 8 of the names for the Pacific Alliance?

INTERPRETER:

10 translation. repeat of the pronunciation.

11 Thank you.

MS. CLAIBORN:

13 it on mute? Thank you.

Okay.

16 Weican Meng and Rui Ma.

18 any other creditors on the line who have counsel 19 who'd like to put their appearance on the record?

MS. GRINNELL:

MS. CLAIBORN: 22 translation.

MS. GRINNELL: 24 the firm Wolf Haldenstein Adler Freeman and Herz and

Case 22-50073 Doc 250-17 Filed 04/22/22 Entered 04/22/22 16:59:37 Page 7 of cannot hear you clearly.

INTERPRETER:

MS.

4 5 6 has been kind of off. Can you hear me now? THE INTERPRETER: Yes. MS. GRINNELL: Okay. I'll repeat what I

said. My name is Lillian Grinnell. I'm an attorney at Wolf Haldenstein Adler Freeman and Herz and we represent the creditors, Rong Zhang, Xiaodan Wang, and Chong Sheen Raphanella.

12 13 THE INTERPRETER: The names you pronounced I could not get them.

14 15 16 17 MS. GRINNELL: I'll spell them. I'll start with the creditor's names. The creditor's names are Rong Zhang, and that's -- the first name is Rong, R-O-N-G, Z-H-A-N-G.

18 19 20 The second creditor's name is Xiaodan Wang. And her first name is spelled X-I-A-O-O-A-N. And her last name is spelled W-A-N-G.

21 22 23 24 And then the third creditor, Chong Shen Raphanella. And her first name is C-H-O-N-G. And then the second name is S-H-E-N. And the third name is R-A-P-H-A-N-E-L-L-A.

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1 and R-A-P-H-A-L. 2 I'm sorry.

MS. GRINNELL: 3 to spell the third name again?

apologize. Sorry?

very bad.

7 again? 8 think I'm okay. INTERPRETER:

9 repeat it to Mr. Kwok already. 10 Okay. MS. GRINNELL:

MS. CLAIBORN: 12 creditors on the line or parties on the line?

MS. ZAMIR:

I'm spell that. Nessenoff & Miltenberg.

Z-A-M-I-R. 16 and Miltenberg, M-I-L-T-E-N-B-E-R-G.

17 represent creditor Sam Nunberg, N-U-N-B-E-R-G.

MS. CLAIBORN: 19 would like to put their appearance on the record.

Yes. MS. KUZNICK:

23 and Stroock, and Lavan is L-A-V-A-N. And we 24 represent the Sherry Netherland.

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1 E-T-H-E-R-L-A-N-D.

INTERPRETER:

3 said.

INTERPRETER:

6 clarifying what was yelled out just now.

8 I'm sorry.

INTERPRETER: 9 interpreter cannot get that.

10 don't know.

11 Bin.

MS. CLAIBORN: 12 Any other creditors or parties in interest

go back to the debtor?

MR. HARBACH:

representing PACS.

16 wanted to clarify that is it correct that we have 17 not gotten an answer from the debtor about what he 18 just said? 19 have not heard any interpretation of it

20 understand the interpreter was attempting to

21 clarify what was said but the debtor did not

23 what he said.

This is Bill Baldiga. MR. BALDIGA: 25 accept your apologies.

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1 accept your apology for that inference.

MS. CLAIBORN:

in minute.

Okay. MR. HARBACH: 5 should apologize, but can we inquire then

who made the outburst? 7 attempting to clarify and so are we.

8 inference.

INTERPRETER:

you requested.

with sentences.

not get those sentences. 13 to clarify who talked and what those words are, but 14 nobody picked up the interpreter's question. 15 This is Holley Claiborn. MS. CLAIBORN: 16 Could the person who spoke up please answer the 17 interpreter's question and identify themselves? 18 Sorry about that.

INTERPRETER:

19 now it was it was just a video tape.

20 someone talked. 21 This is Bill Baldiga. Mr. BALDIGA: MR.

what Mr. 23 someone playing back an audio of his voice and we do 24 want to know everyone who is on the phone and we 25 would like identified who played that audio clip.

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1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Ho Wan Kwok - March 21, 2022 10 Thank you. UNIDENTIFIED: Sorry, it was me. I played Mr. Kwok's video just now. MS. CLAIBORN: Could the person who just spoke identify themselves? THE INTERPRETER: The interpreter needs to clarify. (Interpreter inquires) MR. YAN: My name is Xingyu Yan. I'm one of Mr. Kwok's creditors. MR. BALDIGA: Can we have the spelling, please? Could we obtain the spelling of that name please? MR. YAN: The spelling is X, for Xray, I, as India, N, as in Nancy, Gas in George, Yasin Yes, U as in umbrella. in Nancy. Last name Y, A as in apple, N as MR. BALDIGA: Ms. Claiborn, Bill Baldiga again. Could you please exhaust the names of everyone else on the line, just so we know who is participating, whether or not they intend to ask questions? MS. CLAIBORN: I'm trying to get there. That was my -- okay. Is anyone else on the line? If you are on

Case 22-50073 Doc 250-17 Filed 04/22/22 Entered 04/22/22 16:59:37 Page 12 of G-R-E-I-F.

(indiscernible).

Myers.

Rudnick. Ho Wan Kwok - March 21, 2022 11 the line, and you could please identify yourself? MR. GREIF: Hello. My name is Steven Greif, MR. WARREN: Steven Warren of O'Melveny & MR. JALBERT: Craig Jalbert of INDISCERNIBLE: (Indiscernible) from Robinson and Cole. INDISCERNIBLE: (Indiscernible) from Stroock, Stroock and Lavan. MS. DEERING: Alexandra Deering of Brown

14 15 16 17 18 19 20 21 22 23 24 25 MS. CLAIBORN: This is Holley Claiborn again. Thank you all for putting your appearances on the record. And if I could go back to debtor's camp, Mr. Baldiga, could you put your appearance on the record and note everybody who's with you at your location. MR. BALDIGA: Yes. We're in our -- I'm sorry. I missed what was just said. MS. CLAIBORN: Mr. Baldiga, could you go ahead, please? Mr. Baldiga, could you go ahead, please? MR. BALDIGA: Yes. Thank you. We are at

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our offices at 7 Times Square in New York.

Mr. Baldiga, of who is present with you?

Mr. MS. CLAIBORN: state the names of the people who are with you? Ben Silverberg and Uri Pinelo. MR. BALDIGA:

Okay. MS. CLAIBORN:

interpreter, and Attorney Aaron Mitchell. That's right. Yes. BALDIGA: MR.

Okay. Ms. CLAIBORN:

Mr. phones on mute.

Mr.

MS. CLAIBORN:

interpreter, Bin, who's interpreting my questions and the comments of others and will also be interpreting your answers. Please wait to answer any questions you are asked today until the official interpreter has made full translation.

ask that you do not communicate with your

25 own interpreter who is present with you before you

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2 ask the official interpreter to translate that 3 discussion.

Sorry. INTERPRETER:

5 repeat?

Mr.

MS. CLAIBORN:

7 not communicate with your own interpreter who is 8 with you today before you answer my questions or the 9 questions of others.

INTERPRETER:

11 interpreter.

MS. CLAIBORN: 13 instruction for Mr. Kwok. 14 This is Bill Baldiga. BALDIGA: MR.

Mr. MS. CLAIBORN: 17 wait for Bin to interpret that instruction for me 18 and then you can make your comment.

things. BALDIGA:

MR. 20 Baldiga.

22 to the extent that Mr.

23 talk to his interpreter to better understand what 24 was said or the interpreter in the room with us 25 believes that there was a misinterpretation, we will

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1 tell you that so that you do know if there is a 2 further conversation. 3 Thank you. MS. CLAIBORN:

5 EXAMINATION BY MS. CLAIBORN:

Mr.

7 to file your Chapter 11 bankruptcy case? 8 Sorry? UNIDENTIFIED:

Mr.

10 your decision to file your Chapter 11 bankruptcy 11 case? 12 This is David Harbach.

HARBACH: MR. 13 having trouble understanding you again. 14 apologize.

MS. CLAIBORN:

15 is new and I'm yelling into the phone, but unless I

17 it. Does yelling improve your ability to hear me?

MR. HARBACH: 19 understand your questions because they're so

muffled.

21 blunt. 22 will try to speak slowly. MS. CLAIBORN:

23 Is that any better?

yes.

BALDIGA: MR. 25 you. Case 22-50073 Doc 250-17 Filed 04/22/22 Entered 04/22/22 16:59:37 Page 16 of

2 We're going to try this again. Okay.

Mr.

4 reasons behind filing your Chapter 11 bankruptcy 5 case?

cannot understand you.

7 you mean by filing Chapter 11 of bank.

Mr.

9 case?

INTERPRETER:

11 to clarify the word he said. 12 I'm not filing any bankruptcy certificate.

13 Let me try again.

Mr.

15 bankruptcy proceeding here in the United States.

Mr.

17 decision to file your bankruptcy case? 18 So you're asking me why I'm applying for

19 right?

20 Yes.

22 my second trial, or second appearance in Southern

24 was ordered to pay it off within five days.

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1 application at Connecticut state and Chapter 11.

Mr.

3 lawyer about filing a bankruptcy case?

BALDIGA: MR. 5 approximate date. Not the substance of the advice.

13.

7 Can you please provide the month and the

8 year? 9 It was February the 12th of 2002.

10 Did you say 2002 or 2021?

11 February the 12th or 13. 2022.

Mr.

13 bankruptcy petition that was filed with the 14 bankruptcy court at ECF 1.

Mr.

16 that petition. Is that your handwritten signature?

second.

look.

19 This is Bill Baldiga.

MR. BALDIGA:

20 with us the petition with the electronic signature 21 as filed.

the handwritten signature. 23 it, we could get it at a break.

Mr.

25 document that your counsel has, which is the

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1 bankruptcy petition with your printed name on it and 2 confirm that you signed that document prior to it 3 being filed with the court? 4 Please hold on one second.

5 look.

MR. BALDIGA: 7 want to hear the translation of what you please.

8 said.

MR. BALDIGA: 11 us? 12 are you on the line?

MS. CLAIBORN:

14 are you there?

16 It seems that Bin has left us so I'm going 17 to put everybody on hold and I'm going to try to 18 reconnect her. apologize.

19 That's okay.

BALDIGA: MR. 20 short break?

MS. CLAIBORN:

22 minutes to do that, so go ahead and we'll reconvene 23 can get her on the line.

24 Thank you very much. MR. BALDIGA:

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MS. CLAIBORN:

3 difficulties. 4 BY MS. CLAIBORN: 5 The pending question was asking Mr.

6 confirm that he signed the bankruptcy petition that 7 was filed at ECF 1. 8 have finished looking at it, yes.

Mr.

10 bankruptcy petition and information it contains 11 before you signed it? 12 understood.

Mr.

14 another language for you before you signed it? 15 it was translated into Chinese for me.

16 translated the bankruptcy petition?

17 My lawyer did.

18 don't think that Mr.

Mr.

19 speaks Chinese. 20 So who was the company or the person that 21 you used to translate the petition for you? 22 don't know.

Mr.

24 bankruptcy petition true and accurate to the best of 25 your knowledge? Case 22-50073 Doc 250-17 Filed 04/22/22 Entered 04/22/22 16:59:37 Page 20 of

1 it is accurate and true.

Mr.

3 declaration and about individual debtor's schedules 4 that was filed with the court docket at ECF No. 79.

INTERPRETER:

6 repeat?

Mr.

8 declaration about an individual debtor's schedules 9 that was filed with the bankruptcy court at ECF 79.

Mr.

11 that declaration.

12 signature?

The document in my hand.

14 by me. 15 And are you looking at ECF no. 79?

16 Yes.

Mr.

18 at ECF 79 translated into another language for you 19 before you signed it? 20 Yes.

21 What language was it translated into?

22 Chinese.

Mr.

24 translation of ECF no. 79? 25 Yes.

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1 And who was that person who translated ECF

2 79 into Chinese for you? 3 The lawyer.

the name of the lawyer?

5 Bill.

6 This is Bill Baldiga.

BALDIGA: MR. 7 witness is not distinguishing between what I

8 personally and what we had commissioned,

9 clarify. do not obviously do translations myself.

MS. CLAIBORN:

12 worked for you or the name of the company? 13 I'll have to get that.

BALDIGA:

MR. 14 have it here.

Mr.

16 declaration filed at ECF no.

17 it? 18 understood.

Mr.

20 bankruptcy schedules that were filed with the 21 bankruptcy court at ECF 78.

And Mr.

23 used the term schedules, either collectively or by a

25 that were filed at ECF 78.

Case 22-50073 Doc 250-17 Filed 04/22/22 Entered 04/22/22 16:59:37 Page 22 of

Mr.

2 translated for you? 3 it was translated.

Mr.

5 responses and the answers to the questions in the 6 schedules? 7 was.

Mr.

9 the responses and the answers to the questions in 10 the schedules before you signed the declaration that 11 was filed at ECF 79. 12 Yes.

Mr.

14 preparation of your bankruptcy schedules? 15 The lawyer.

Mr.

17 helped you? 18 Bill.

Mr.

20 Baldiga? 21 Yes.

Mr.

23 preparing your bankruptcy schedules? 24 Yes.

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1 other lawyers who assisted you? 2 don't know how to say their names.

3 cannot read English well.

MR. BALDIGA: 5 happy to add that, of course, other of our 6 colleagues here at Brown Rudnick assisted. But I'm

not sure Mr. 8 exactly assisted on what part of it, but you could

of course.

Mr.

lawyer at Brown Rudnick?

Excuse me. BALDIGA:

MR.

Kwok for one second. Mr. 14 on mute for one second.

MS. CLAIBORN: 16 question before you have your conference, Mr. 17 Baldiga. 18 Because the whole bankruptcy application,

19 the whole stuff was arranged by this lawyer.

20 don't know all the other details.

MS. CLAIBORN:

22 your client? 23 I'll clarify only that Mr. MR. BALDIGA: 24 Kwok likely does not know of all of the 25 conversations that we've had with others, but this

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2 ask that but we don't want to be misleading. 3 aside from Mr.

Mr.

4 at Brown Rudnick did you speak with any other 5 lawyers about preparing your bankruptcy schedules? 6 Yes.

7 did you speak with?

8 Another law firm called Ari and my personal

9 (indiscernible).

10 What is the name of your personal lawyer?

MR. BALDIGA: 12 able to answer that question? 13 ahead. MS. CLAIBORN:

BALDIGA: MR. 15 confer, please? 16 Yes. MS. CLAIBORN:

18 Thank you. BALDIGA: MR.

Mr.

20 lawyer?

(indiscernible).

Mr.

23 discussed your bankruptcy schedules with Guy 24 Petrillo and Aaron Mitchell? 25 Yes.

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Mr.

2 schedules with any other lawyers that you haven't

about today? 4 don't remember.

Mr.

6 in your bankruptcy schedules? 7 don't see anything like that now.

Mr.

9 schedules true and accurate to the best of your 10 knowledge? 11 Yes.

Mr.

13 your bankruptcy statement of financial affairs that 14 was filed with the court at ECF no. 77.

Mr.

16 the document can you please go to page 20 where you 17 will find a handwritten signature. 18 Sorry?

INTERPRETER: 19 Where you will find a handwritten signature.

Mr.

21 page 20 of the statement of financial affairs your 22 own? 23 Yes.

Mr.

25 affairs translated for you before you signed it?

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1 Yes.

Mr.

3 of the responses and the answers to the questions in 4 the statement of financial affairs? 5 Yes.

Mr.

7 the responses and answers to the questions in the 8 statement of financial affairs before you signed it? 9 understood all.

Mr.

11 in your statement of financial affairs? 12 No.

Mr.

15 question? 16 I'm sorry.

BALDIGA: MR. 17 We didn't get the interpretation here in the that? 18 room for some reason. 19 I'll ask the question again. MS. CLAIBORN: 20 Are there any errors or omissions in your

21 statement of financial affairs?

23 omissions.

Mr.

25 financial affairs true and accurate to the best of

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1 your knowledge? 2 Yes.

Mr.

4 preparation of your statement of financial affairs? 5 My lawyer, Bill, and my financial advisor,

6 Matt.

Mr.

8 Baldiga? 9 Yes.

11 financial advisor? 12 don't know how to spell it.

MR. BALDIGA: 14 at Verdolino and Lowey.

15 is that correct? Mr.

17 my lawyer Baldiga to clarify for you. ask for Mr. 18 can move on.

19 This is Bill Baldiga. MR. BALDIGA: 20 Kwok simply does not know the full name Mr. 21 of Matt Flynn or Matt's colleagues at Verlino and

23 Flynn next to him when he answers the question. 24 Thank you. MS. CLAIBORN:

Mr.

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1 statement of financial affairs? 2 No.

Mr.

4 United States? 5 Nearly seven years.

6 This is David Harbach. HARBACH: MR.

7 didn't get the translation of the answer.

MS. CLAIBORN: 9 your translation. 10 Nearly 7 years. INTERPRETER:

Mr.

12 Road property in Greenwich? 13 Yes.

14 owns that property in Greenwich?

15 My wife.

owns that company? LLC.

18 My wife.

19 What is your wife's name?

MS. CLAIBORN:

spelling?

INTERPRETER:

25 it for you.

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she's from Hong Kong.

3 spelling is different from Mainland and I

4 how to spell her name.

Mr.

6 last name? 7 don't know how to spell.

8 Does anyone else have a membership interest

9 in Greenwich Land LLC aside from your wife? 10 don't know.

12 company? 13 2020.

Mr.

LLC? 16 No.

18 purchase of the Greenwich property on Taconic Road? 19 don't know specifically but approximately

20 5 million. 21 And how was that purchase funded?

22 don't know.

23 Who would know the answer, Mr. Kwok?

24 Sorry? INTERPRETER:

25 Who would know the answer to that, Mr. Kwok?

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1 My wife knows.

HARBACH: MR. 3 apologize for the interruption. 4 We missed the translation by the number of 5 that Mr.

6 Could that please be repeated? property would cost.

INTERPRETER:

8 cannot hear you clearly.

Mr. MS. CLAIBORN:

10 question again. 11 Thank you. MR. HARBACH: 12 How much was the Taconic Road property in

13 Greenwich purchased for? 14 don't know clearly but approximately 4

15 million to 5 million. 16 When did Greenwich Land LLC purchase the

17 property on Taconic Road in Greenwich? 18 don't know the specific time.

19 you know the year?

20 don't remember clearly. 2019 or 2020.

MS. CLAIBORN: 23 identify themselves? 24 just for one second.

MR. BALDIGA:

translation issue.

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1 put you on mute for one second.

3 This is Bill Baldiga. BALDIGA: MR.

4 believe that the answer by Mr.

5 2019 or 2020, but the translator may have said 2020 6 obviously don't know. without a mention of 2019.

8 sure that there's clarity around that?

Mr.

10 purchase the Taconic Road property in Greenwich? 11 Maybe it's 2020 or maybe it's 2019.

12 remember clearly. don't know.

Mr.

14 connection with the purchase of the Taconic Road 15 Property in Greenwich? 16 No.

Mr.

18 property in Greenwich? 19 Sorry? INTERPRETER:

20 lives at the Taconic Road property in

21 Greenwich? 22 My wife and I.

23 lives in New York will come back.

Mr.

25 anyone?

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1 Are you what? INTERPRETER:

2 Are you currently employed by anyone or any

3 company? 4 No.

Mr.

6 job with an employer since you started living in the 7 United States? 8 don't remember clearly.

9 clearly but approximately in 2015 at Golden Spring I

worked for some time.

11 left and nothing else.

12 What work did you do for Golden Spring in

13 2015? 14 don't remember quite clearly but it seems

17 remember clearly.

Mr.

19 Golden Spring? 20 just one second.

MR. BALDIGA:

second.

23 translation.

We may.

BALDIGA: MR.

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2 Springs, it was to develop investment opportunities 3 not to develop investors.

Mr.

5 Golden Spring? 6 don't remember clearly.

Mr.

8 you referring to the company known as Golden Spring, 9 Limited?

10 Yes.

Mr.

12 work that you for Golden Spring? 13 Yes.

14 How much were you paid?

Approximately 200,000.

16 specifically.

Mr.

18 your work at Golden Spring?

20 specifically.

Mr.

22 were paid by Golden Spring into a bank account?

24 account at Morgan Stanley.

Mr.

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Do you still have a bank account at Morgan

When did you close your accounts at Morgan

account at Morgan Stanley?

Yes, once I had.

Stanley?

A Around April, 2017 when (indiscernible) the Chinese Communist Party stated chasing me

10 11 (indiscernible) closed. me. So all my bank accounts were

12 13 MR. BALDIGA: mistranslation there. Hold on. There's a

Stanley?

No.

15 16 17 18 MR. BALDIGA: The prior misstatement or mistranslation was just the interpretation of the word. But here the entire crux of the answer was left out. And I'm not sure what happened.

19 20 MS. CLAIBORN: Maybe I can ask a different question. We can try again.

21 22 23 24 25 MR. BALDIGA: No, I think -- no, I think the answer -- I'm concerned with the accuracy of the translation because there was specific mention of names that were simply not produced in the answer. And I'll guess, Bin, did you not hear the mention of

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1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Ho Wan Kwok - March 21, 2022 PACS and Bruno Wu, or was there a sound issue, or what happened? (Interpreter translates) MS. CLAIBORN: Mr. Kwok, did you -- MR. KWOK: So Bruno Wu, (indiscernible) 34 Airlines and also Chinese Communist party, they all chased me and wanted to kill me. So I (indiscernible) closed. -- all my bank accounts were PAC, PACS. (Indiscernible) all the people are present today at today's meeting. MR. BALDIGA: Could we have on the record the entirety of what Mr. Kwok said. That's a very small part of what he said, obviously. what he said but that's much shorter. (Interpreter translates) I don't know THE INTERPRETER: him to (indiscernible) The interpreter is asking every two names so that I can maintain the integrity of his meaning. MR. KWOK: At today's meeting there are PAC, one of the major creditors. And also (indiscernible). And also (indiscernible) member. All the money that had to be paid went into an account of the Communist Party under the name of Bruno Wu. So since that day when all the -- all the 83

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1 representatives of the Chinese Communist party --

3 bank accounts. 4 This is David Harbach.

MR. HARBACH: 5 could you please repeat that? 6 Sorry? INTERPRETER:

7 This is David Harbach. HARBACH:

MR. 8 just translated an answer that began with since that 9 Can you please repeat the answer in English? day.

INTERPRETER:

11 people who are representatives of Chinese Communist 12 lost all my bank accounts.

13 BY MS. CLAIBORN:

Mr.

15 Morgan Stanley account when you closed it? 16 Yes.

17 And where did you move that money to?

19 the account was closed.

Mr.

21 the money to?

BALDIGA: MR. 23 This is Bill Baldiga. sorry. 24 Could you ask if perhaps you're inferring or 25 implying that he moved it as opposed to something

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happened to it? 2 way and you may get a more full answer?

Mr.

4 behalf close the Morgan Stanley account?

7 party.

Mr.

9 the United States? 10 Yes.

Mr.

12 or someone acting on your behalf close a bank 13 account in your name?

INTERPRETER:

15 question, the interpretation of the question.

17 It's the core control of the Communist

18 Party, like what's happening today. The same thing.

happened on me.

Ms. MR. BALDIGA: 21 that you ask whether Morgan Stanley closed the 22 just so we could be more efficient here?

Mr.

24 Morgan Stanley? 25 Sorry? INTERPRETER:

Case 22-50073 Doc 250-17 Filed 04/22/22 Entered 04/22/22 16:59:37 Page 38 of

Mr.

2 Morgan Stanley?

I'm sorry. INTERPRETER:

4 quite get the question actually.

Mr.

6 account at Morgan Stanley? 7 No.

Mr.

9 Stanley to close your account? 10 No.

Mr.

12 bank account at Morgan Stanley was closed?

wanted list of the Chinese government. 15 Bruno Wu who was representing (indiscernible)

16 on the wanted list so the account was closed.

Mr.

18 account, what happened to the money in the account?

Ms. MR. HARBACH:

Harbach. 21 question.

22 lost you.

my question.

Mr.

25 bank account, what happened to the money in the bank

Case 22-50073 Doc 250-17 Filed 04/22/22 Entered 04/22/22 16:59:37 Page 39 of

1 account?

Chinese government. 6 don't know really.

Mr.

BALDIGA: MR. 9 Baldiga?

Mr. MS. CLAIBORN:

MR. BALDIGA:

13 But if you want to finish this line, certain soon. 14 do that.

16 with the Morgan name and so you may want to ask the 17 witness whether it's, in fact, Morgan Stanley or JP 18 Morgan Chase.

remember.

MR. KWOK:

Morgan Chase.

21 confused with Morgan Stanley or JP Morgan Chase.

Mr.

23 whatever it is you're calling it, be it JP Morgan 24 Chase or Morgan Stanley?

Case 22-50073 Doc 250-17 Filed 04/22/22 Entered 04/22/22 16:59:37 Page 40 of

1 account.

3 approximately when it was closed? 4 dollars. A few thousand U.S.

MR. HARBACH:

6 the English, please?

MS. CLAIBORN: 8 the answer?

MS. CLAIBORN: 11 the answer? 12 This is David Harbach. HARBACH:

MR. 13 missed the translation before the word thousand.

14 did not hear the number.

15 it?

INTERPRETER:

17 dollars. U.S.

Mr.

an idea of what you mean? 20 Was it under \$10,000? 21 don't remember.

Mr.

23 that you were working for Golden Spring developing 24 investment opportunities. Can you explain more? 25 Sorry? INTERPRETER:

Case 22-50073 Doc 250-17 Filed 04/22/22 Entered 04/22/22 16:59:37 Page 41 of

MS. CLAIBORN:

2 I'll try again. question. apologize.

Mr.

4 that you were working for Golden Spring developing 5 investment opportunities.

6 what you mean by that? 7 don't remember.

8 When you were working for Golden Spring,

9 were you working in the United States? 10 Yes.

11 When you were working with Golden Spring did

12 job title?

13 don't remember.

14 When you were working for Golden Spring, did

15 you do any other work aside from developing 16 investment opportunities?

Communist Party of China.

18 Can you please explain that?

20 all my time and my energy on collecting information 21 about corruption and also human rights issues and 22 assassinations of the Community Party.

23 target and my work.

Mr.

25 of income?

Case 22-50073 Doc 250-17 Filed 04/22/22 Entered 04/22/22 16:59:37 Page 42 of

1 didn't get you.

INTERPRETER:

2 you please repeat?

Mr.

4 income? 5 No.

Mr.

7 for the year 2021 with the Internal Revenue Service 8 in the United States? 9 No.

Mr.

11 states for the tax year 2021? 12 Sorry? INTERPRETER:

13 Have you filed any tax returns for any

14 states for the tax year 2021? 15 No.

16 What tax returns will you need to file for

17 what states for the year 2021? 18 Individual tax file in Connecticut.

20 State of New York for the year 2021? 21 No.

Mr.

23 office tax returns for the years 2019 and 2020.

24 those tax returns the same as the tax returns you 25 filed with the Internal Revenue Service in the State

Case 22-50073 Doc 250-17 Filed 04/22/22 Entered 04/22/22 16:59:37 Page 43 of 83

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Ho Wan Kwok - March 21, 2022 of New York? THE INTERPRETER: Sorry, the date of what? MS. CLAIBORN: 2019 and 2020. THE INTERPRETER: Yes, I got that. What's the later part? A Q A MS. CLAIBORN: The State of New York. No, I filed them in Connecticut, 2020. Mr. Kwok -- I in (indiscernible) for 2019 and 2020. 2020 I filed in Connecticut. MR. BALDIGA: Holley, can we take a break soon? 42 MS. CLAIBORN: Unfortunately, I'm going to suggest that we can't really take a break because we only have the interpreter until 2:00. So if we do, it needs to be a very, very short one. MR. BALDIGA: Okay. Five minutes? MS. CLAIBORN: Yeah, let me just ask one question before we do that. Q Mr. Kwok, please confirm that the tax returns that you provided to the United States Trustee for the year 2020 and 2019 were the same as those filed with the taxing authorities? THE INTERPRETER: The what? Sorry, the last word. Case 22-50073 Doc 250-17 Filed 04/22/22 Entered 04/22/22 16:59:37 Page 44 of

1 Authorities. MS. CLAIBORN:

3 Could you please repeat? INTERPRETER:

4 Sorry.

Mr.

6 tax returns that you provided to the Office of the 7 United States Trustee for the tax years 2019 and 8 2020 are the same as those that you provided to the 9 Internal Revenue Service and to the State of 10 Connecticut and to the State of New York? 11 Yes.

Mr.

13 want to clarify.

MR. BALDIGA:

14 there were very limited redactions as to

16 points. I'm not sure if the witness knows what we 17 did by way of that data protection, but you do.

18 just wanted to not leave the record ambiguous in 19 that regard. 20 Thank you. MS. CLAIBORN:

Mr.

22 interest income only and no other source of income. 23 Did you have any other source of income in 2020? 24 No.

Okay. MS. CLAIBORN:

Case 22-50073 Doc 250-17 Filed 04/22/22 Entered 04/22/22 16:59:37 Page 45 of

1 It is now 12:30.

very short break.

2 everyone to reconvene at 12:35. I'm not going to

disconnect the call. 4 put your phones on hold. 5 We will reconvene at 12:35. Thank you.

Okay. MS. CLAIBORN:

short break.

Mr.

10 Golden Spring, New York. 11 you currently work for Golden Spring in

12 any capacity? 13 No.

14 When was Golden Spring New York Limited

15 formed? 16 Sorry? INTERPRETER:

17 When was Golden Spring New York Limited

18 formed?

INTERPRETER:

20 later half. Golden New York what?

MS. CLAIBORN: 22 refer to it as Golden Spring.

23 referring to Golden Spring New York.

company?

25 don't know.

Case 22-50073 Doc 250-17 Filed 04/22/22 Entered 04/22/22 16:59:37 Page 46 of

1 The address on the petition is 162 East 64th

2 Street. owns that property?

3 can ask the question again.

4 The address for Golden Spring is listed as 5 162 East 64th Street in New York.

6 property? 7 don't know.

8 What is the nature of that property at 162

9 East 64th Street? 10 don't know which property you're talking

11 about.

MR. BALDIGA: 14 just try again.

MS. CLAIBORN:

16 translation issue.

BALDIGA: MR. 17 Could we confer for one second because 18 obviously there's a misunderstanding. So could Mr. 19 Kwok talk to his translator because that obviously 20 didn't come through.

MS. CLAIBORN:

try again. try again, please.

24 bankruptcy petition is listed as 162 East 64th 25 Street in New York.

Case 22-50073 Doc 250-17 Filed 04/22/22 Entered 04/22/22 16:59:37 Page 47 of

1 Is it 54 or 64?

INTERPRETER:

2 4? 3 64. MS. CLAIBORN:

INTERPRETER:

6 mistake and reinterpret again. 7 that's the address of Golden Spring.

8 Does Golden Spring own that building that's

9 located at that address? 10 don't know.

11 Have you ever been to that address?

12 Yes.

13 What type of building is it?

14 there?

building.

17 commercial building? 18 Business building.

I'm sorry, Bin. MS. CLAIBORN:

20 your translation.

INTERPRETER:

22 business building. 23 Does anyone live at that address?

24 don't know.

25 What type of business does Golden Spring do?

Case 22-50073 Doc 250-17 Filed 04/22/22 Entered 04/22/22 16:59:37 Page 48 of

2 don't know specifically what categories of

3 business it has.

Mr.

family office owned by my son.

6 don't know.

Mr.

8 business or family office, what do you mean by those 9 terms?

family members. 12 and help each other.

13 can you explain it in more detail? Mr.

14 don't know how to explain.

15 Does Golden Spring have any employees?

16 Yes.

17 How many?

18 don't know.

19 Does Golden Spring own any real estate?

20 don't know.

21 Does Golden Spring own any other business?

22 don't know.

23 Does Golden Spring have any bank accounts?

24 don't know.

Mr.

Case 22-50073 Doc 250-17 Filed 04/22/22 Entered 04/22/22 16:59:37 Page 49 of

1 documents filed with the bankruptcy court that 2 Golden Spring pays for you personal living expenses. 3 Can you please explain how they do that? 4 don't know what you mean by they pay me.

5 In what regard?

Mr.

7 in your bankruptcy documents that Golden Spring pays 8 for your clothing, your food and your housing. 9 My question is how do they do that?

10 they pay other people directly? give you money?

11 How does it work?

13 talk to my son and he will tell his office

14 to give to me. 15 are the owners of Golden Spring?

16 This is David Harbach. HARBACH:

MR.

missed the end of that question.

that answer.

19 lost it.

20 English again?

INTERPRETER:

22 gentleman?

Mr. MS. CLAIBORN: 24 you could repeat the translation of Mr.

25 answer about how the money flows from Golden Spring.

Case 22-50073 Doc 250-17 Filed 04/22/22 Entered 04/22/22 16:59:37 Page 50 of

INTERPRETER:

2 interpretation.

4 tell my son.

Mr.

6 Spring? 7 My son.

8 Are there any owners of Golden Spring other

9 than your son? 10 No.

Mr.

12 Golden Spring? 13 No.

14 are the officers and directors of Golden

15 Spring? 16 This is Bill Baldiga. BALDIGA: MR. 17 This is something for which there are very 18 serious physical security concerns and it's not that 19 if he knows.

20 line like this where it's open to the

public and who else knows. hold on.

23 we'd like to give you as much as possible, but we 24 don't want to cause severe security issues.

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1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Ho Wan Kwok - March 21, 2022 with the witness? MS. CLAIBORN: Yes. (Pause.) MR. BALDIGA: This is Bill Baldiga, again. The witness believes that he may know who the directors and officers are and is prepared to testify as to the best of his knowledge in that regard. And if we could take it one question at a time we'll go from there. 50 If you could interpret that, because I want to be sure that the witness understands what I just said as well, please. (Int e rp re tat ion) BY MS. CLAIBORN: Q Mr. Kwok, as of today, who are the officers of Golden Spring? A (Indiscernible) Q I'm going to repeat that name so everyone understands what I thought I heard. What I heard was Yan Ping, also known as Yvonne Wang. accurate? Yes. Is that A Q Is Yvonne Wang the only officer of Golden Spring? A I don't know. 83

Case 22-50073 Doc 250-17 Filed 04/22/22 Entered 04/22/22 16:59:37 Page 52 of

1 As of today, who are the directors of Golden

2 Spring? 3 don't know.

Mr.

5 direct or Golden Spring? 6 don't remember.

7 who is Max Krazner? Mr.

8 don't know. don't know.

INTERPRETER:

10 the name again? 11 who is Max Krazner? Mr.

13 can you please answer? Mr.

BALDIGA: MR. 15 witness for one second. Hold on please?

Mr. MS. CLAIBORN:

17 he would answer the question before you make a 18 confer.

BALDIGA: MR. 21 opportunity. The witness could answer. 22 He has to double check with you because I

23 cannot read and cannot remember English names well.

you said Max.

know Max.

Case 22-50073 Doc 250-17 Filed 04/22/22 Entered 04/22/22 16:59:37 Page 53 of

1 it, I'm not sure. don't know.

2 Q you know a Max with respect to Golden

3 Spring? 4 A Yes. know.

5 Q And what is Max's role with Golden Spring? 6 A don't know.

7 Q Well, how do you know Max? 8 A don't remember.

9 Q you know more than one person by the name

10 of Max? 11 A For me English name is very complicated. 12 Like I can't remember the last name of my lawyer. If

don't know.

Mr.

15 the person to whom the mail for Golden Spring is 16 directed to. you know why that is?

17 Sorry? INTERPRETER:

18 Q you know why that is?

19 A only remember there is a Max at Golden

20 Spring. only know this one thing.

21 Q And what is Max's job at Golden Spring? 22 A I'm not sure what role.

23 know he is in charge of finance, but I'm not sure. 24 Q What does he do for Golden Spring with 25 respect to finances? Case 22-50073 Doc 250-17 Filed 04/22/22 Entered 04/22/22 16:59:37 Page 54 of

1 was not involved in the management so I

2 don't know.

4 come through Max Krazner's efforts?

5 make that happen?

don't know.

7 person.

Mr.

Spring how do you get money? 10 form of cash or something else?

I'm sorry, Bin. MS. CLAIBORN:

understand your translation. 14 again?

INTERPRETER:

16 (indiscernible). 17 My question was how do you get money from

18 Does it come in the form of cash or some your son? 19 other form? 20 don't understand what you mean by how,

21 never get money directly from them. word how.

22 If you don't get money directly from your

23 son, how do you get the money from your son?

24 does it go?

Case 22-50073 Doc 250-17 Filed 04/22/22 Entered 04/22/22 16:59:37 Page 55 of

cards.

pay my expenses for me.

4 account. Any bank accounts.

Mr.

6 card that was taken out by Golden Spring?

BALDIGA: MR.

sorry.

9 the prior question.

10 be sure that the witness understood the question 11 correctly? Hold on for one second.

12 put it on mute.

MR. BALDIGA:

16 that Golden Spring does not give him cash, but

17 simply pays certain bills for his living expenses. 18 If that's what came through the translation, great. 19 If not, we clarify accordingly.

Mr.

21 debit card provided to you by or through

22 Golden Spring? 23 No.

Mr.

25 Spring back for the monies that it pays on your

Fiore Reporting and Transcription Service, Inc. Case 22-50073 Doc 250-17 Filed 04/22/22 Entered 04/22/22 16:59:37 Page 56 of

1 behalf for your living expenses? 2 No need. No.

MS. CLAIBORN: 4 the meeting to creditors, given that we have a 5 limited amount of time for today.

6 all my questions. 7 We will need to reconvene on another day, 8 but for purposes of today's examination I'm now 9 going to open it up to creditors who may wish to 10 examine. 11 would ask that you identify yourself when

12 you speak and to be mindful of the need for 13 interpretation.

MR. BALDIGA:

the record. 16 the petition and asked whether anyone lived at 162 17 East 64th Street. 18 And as we told you informally when we filed 19 the petition there was great concern over the 20 debtor's physical security and so he used that

22 record that he lives in the Greenwich house that you 23 asked about earlier today.

25 confusing in that regard. Thank you. Case 22-50073 Doc 250-17 Filed 04/22/22 Entered 04/22/22 16:59:37 Page 57 of

CLAIBORN: MS. 2 wish to inquire or examine of the debtor?

Yes. HARBACH: MR. 4 for PACS.

some questions.

6 now or if there are others who would like to ask 7 questions that's fine. However you want to proceed. 8 obviously will not finish before 2 o'clock

9 either. 10 cannot hear you clearly. INTERPRETER:

MR. HARBACH: 12 was just saying that we do have some questions

13 are happy to proceed and ask them or if the

14 trustee would like. we can proceed with others 15 asking questions but we will certainly not finish 16 before 2 o'clock either.

BALDIGA: MR. 18 please?

INTERPRETER:

20 get him completely.

MS. CLAIBORN: Mr. 22 ability to pick up a hand held and speak into a hand

speaker phone?

MR. HARBACH: 25 move to see if this is any better.

Case 22-50073 Doc 250-17 Filed 04/22/22 Entered 04/22/22 16:59:37 Page 58 of

1 little better now?

2 Not really. sorry.

INTERPRETER:

Not really.

HARBACH: MR.

you what.

phone.

6 okay? 7 Yes. MS. CLAIBORN:

MR. BALDIGA: 9 please, so he knows that. dialogue for Mr.

11 Hello? MR. HARBACH:

Hello. MS. CLAIBORN: 13 Claiborn.

MR. HARBACH: 15 just wanted to know if you could hear me better. 16 Much better.

MS. CLAIBORN: 17 hear Mr. Harbach? 18 can hear him now.

INTERPRETER:

19 Thank you. 20 ahead, Mr. Harbach. MS. CLAIBORN:

HARBACH:

MR. 22 more so that the interpreter can interpret it.

24 PACS does have some questions we would like to ask, 25 but we certainly will not finish by 2 o'clock and so

Case 22-50073 Doc 250-17 Filed 04/22/22 Entered 04/22/22 16:59:37 Page 59 of

1 if Ms. Claiborn would like to proceed with giving 2 other creditors an opportunity to ask questions 3 it's entirely up to her or we can start now.

BALDIGA: MR. 5 extended our own translator until 2 o'clock so we 6 certainly encourage whoever wants to ask questions 7 to use the time. 8 This is Jay Wolman.

MR. WOLMAN: 9 to ask some questions now.

INTERPRETER:

11 name.

MR. WOLMAN: 13 Logan Chang. 14 EXAMINATION BY MR. WOLMAN: 15 Good afternoon, Mr. Kwok.

year ago?

INTERPRETER:

20 in the background.

have too many depositions.

22 remember specifically.

24 questions and you invoked your rights under the 25 Fifth Amendment of the U.S. Constitution.

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1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Ho Wan Kwok - March 21, 2022 59 understand that? THE INTERPRETER: You and your wife what? Sorry. Q You invoked your right under the Fifth Amendment of the U.S. Constitution. that? Do you remember MR. BALDIGA: We have a translation issue. Hold on for one second, please. (Pause.) MR. BALDIGA: I think -- our interpreter is hearing this translation. The question as we understand is do you remember having invoked the Fifth Amendment privilege at a prior deposition. That's what we are hearing. Could that be interpreter for Mr. Kwok in that way please? THE INTERPRETER: Sorry, I can I hear the question again. MR. WOLMAN: Sure. Q Do you remember at a prior deposition invoking the Fifth Amendment of the U.S. Constitution? THE INTERPRETER: Sorry, I did not hear you clearly. Q Do you remember at a prior deposition invoking the Fifth Amendment of the U.S.

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1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Ho Wan Kwok - March 21, 2022 60 Constitution? THE INTERPRETER: At a prior what? Sorry. MR. WOLMAN: Deposition. D-E-P-O-S-I-T-I-O-N. THE INTERPRETER: Deposition. Sorry, just one sec. (Pause.) THE INTERPRETER: Okay. In the prior deposition what? Q Do you remember invoking your Fifth Amendment rights? THE INTERPRETER: Invoking what? MR. WOLMAN: Can everybody else hear me or is it just the interpreter? MS. CLAIBORN: This is Holley. I can hear you. MR. HARBACH: This is David Harbach. We can hear you fine. MR. BALDIGA: The debtor can hear you. not a volume issue. It's MR. WOLMAN: Is it a diction issue? I can try to THE INTERPRETER: The interpreter just didn't get the word. (Indiscernible) rewording. MR. WOLMAN: I cannot reword that. I need

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1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 Ho Wan Kwok - March 21, 2022 61 you to hear the words in English and translate them, ma'am. THE INTERPRETER: Okay. Could you please speak slowly? Q Do you remember at a prior deposition invoking your rights under the Fifth, number five that is -- Fifth Amendment, ordinal number -- of the U.S. Constitution? Holley. THE INTERPRETER: Invoke or evoke? MR. WOLMAN: Invoke, I-N-V-O-K-E. Okay, we still have an issue. UNIDENTIFIED: Hold on. UNIDENTIFIED: Did someone just drop out? MS. CLAIBORN: Bin, are you there? This is MR. WOLMAN: Bin? MS. CLAIBORN: Bin, are you there? THE INTERPRETER: Hello. MS. CLAIBORN: Bin, this is Holley Claiborn. THE INTERPRETER: Okay. I'm back. MS. CLAIBORN: Okay. THE INTERPRETER: happened. I don't know what MS. CLAIBORN: Go ahead. 83

24 25 MR. BALDIGA: Is the interpreter -- we're

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1 2 Ho Wan Kwok - March 21, 2022 not sure what's going on. us or not? Is the interpreter with 62 83

3 4 THE INTERPRETER: Yes, the interpreter is here now.

MR. BALDIGA: Okay. Thank you.

6 7 8 9 10 11 My client just said something and I don't know what he said and I don't know whether you were on for what he said. If you were, I'd like to know I'd like you to interpret it. If not, could you let us confer for a second so we could try to figure that out, because there was a lot of confusion.

12 13 MR. WOLMAN: Bill, can you just ask your client to repeat what he just said?

15 16 17 18 THE INTERPRETER: The interpreter would like him to repeat what he said because just now all of a sudden I'm not (indiscernible) sometimes. all the voices

19 20 I'm asking the gentleman to repeat what he said just now.

21 22 23 24 MR. KWOK: Just now in your question you mentioned that -- you asked me whether my wife used something under the law or under the Constitution. I don't remember that.

MR. WOLMAN: I said nothing about his wife.

Case 22-50073 Doc 250-17 Filed 04/22/22 Entered 04/22/22 16:59:37 Page 64 of

MR. KWOK: So did you say just now my wife

MR. BALDIGA: Could I suggest, Mr. Wolman,

MR. WOLMAN: Well, I'm going to re-ask him

every question relative to finances where he invoked

the Fifth and I wanted to make sure he had that in

maybe you could just go right to whatever you want

to ask him instead of what happened a year ago

because this is not getting anywhere.

his mind as he answers here today. use any kind of law or what? sort.

question? BALDIGA: MR.

MR. WOLMAN:

representing to you that is exactly what I'm doing. 15 16 17 18 19 20 21 22 23 24 25 aware of what I'm about to do. At this point, I have no idea, but I am representing to you that is exactly what I'm doing. So I want to make sure your client is appropriately advised. BY MR. WOLMAN: Q So a year ago -- this is a lengthy one, Bin, so please just write it down, or do what you need to do. Let me finish and then translate. that piecemeal. THE INTERPRETER: Okay. Do not do

Case 22-50073 Doc 250-17 Filed 04/22/22 Entered 04/22/22 16:59:37 Page 65 of

MR. BALDIGA:

Hold on. MR.

WOLMAN: 3 of that and we'll take this in small pieces.

4 Bin, please translate that for the witness because 5 he has to hear everything.

7 Yes. INTERPRETER:

8 Thank you. MR. WOLMAN: 9 BY MR. WOLMAN: 10 asked you are you employed.

12 asked you what? Sorry. INTERPRETER:

13 Are you employed?

14 lot of background noise.

15 knock that off, please.

asked you are you employed? 17 You employed?

INTERPRETER:

asked you are you employed?

21 Sorry.

INTERPRETER:

22 The answer is what? you are you employed?

INTERPRETER:

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2 the broadcasting and to take down the Chinese

Communist Party. 4 then asked you how much do you get paid for that. 5 I'm re-asking that question now.

6 do you get paid for that?

INTERPRETER:

employed? 11 after is.

13 lot of companies and my current employment is

he paused.

15 Is what? Sorry? INTERPRETER:

17 Sorry.

INTERPRETER: 18 am in the broadcasting and to take down

the Chinese Communist Party. 20 revolution.

Excuse me. INTERPRETER:

23 I'm not done. Excuse me. MR.

WOLMAN: 24 not?

INTERPRETER:

Case 22-50073 Doc 250-17 Filed 04/22/22 Entered 04/22/22 16:59:37 Page 67 of

1 Why not? MR. WOLMAN:

INTERPRETER: 3 know it's simple but it's too long. get.

5 interpretation. I'm highly concentrating.

6 human brain.

MR. WOLMAN: 8 things down as they go. 9 Sorry about that. INTERPRETER:

11 ask you the rest. Is that okay? 12 Yes. MR. WOLMAN: 13 Okay.

INTERPRETER:

Okay.

INTERPRETER:

16 then asked you how much do you get paid

18 invoked the Fifth, how much do you get paid for 19 that?

Okay. BALDIGA: MR.

23 And you can answer that. getting paid for that?

No. MR.

WOLMAN: 25 how much do you get paid for that. He

Case 22-50073 Doc 250-17 Filed 04/22/22 Entered 04/22/22 16:59:37 Page 68 of

1 Fifth. I'm asking it now again. 2 How much do you get paid for that?

3 No money at all.

New York. company.

7 your relationship to that company and so I'm asking

that question again. 9 that company? 10 don't know what you mean by relationship.

12 question, why did you invoke the Fifth last year? 13 Objection.

MR. BALDIGA: 14 allow the witness to describe the legal advice a 15 year ago as to the Fifth Amendment. 16 is prepared to answer whatever questions

you may have. You are confusing the witness a 18 in each question having three things, some reference

20 question as to now.

23 productively. That's your choice.

No. MR. WOLMAN:

Case 22-50073 Doc 250-17 Filed 04/22/22 Entered 04/22/22 16:59:37 Page 69 of

sophisticated person.

2 simple questions. 3 Proceed as you'd like. MR. BALDIGA:

6 Wait. Hold on. Mr.

MR. BALDIGA:

translation that needs to be done.

8 The witness needs to understand what's hold on. 9 being said.

11 ahead. Okay. INTERPRETER:

12 What is your relationship to Golden Spring?

13 don't understand what you mean by your

14 don't know how to answer your question. question?

16 means? 17 Relationship means love of things in China.

18 It could be between husband and wife.

20 relationship, money and it could be a lot of things.

don't know which one you mean?

22 man/woman relationship or a money relationship or 23 what?

Any relationship?

Case 22-50073 Doc 250-17 Filed 04/22/22 Entered 04/22/22 16:59:37 Page 70 of

Sorry? INTERPRETER:

2 sentence again, because there was talking. 3 Any relationship, what is yours to Golden

4 Spring?

INTERPRETER:

6 interpretation first.

8 owe money to him. He helps me. lends me money.

9 And why does he do this?

11 family. 12 This is David Harbach.

HARBACH: MR. 13 you please repeat that English answer?

INTERPRETER:

15 member of Guo family. 16 Does Golden Spring pay the expenses of any

17 other member of the Guo family? 18 Yes.

19 Which other members of the Guo family?

20 don't know.

Spring pay Mr.

23 services rendered to you in your individual 24 capacity. I'm asking that again now.

Golden Spring pay Mr.

Case 22-50073 Doc 250-17 Filed 04/22/22 Entered 04/22/22 16:59:37 Page 71 of

rendered to you in your individual capacity?

MR. BALDIGA: understand that Mr.

lawyer.

just need to confer with the client to make sure he

doesn't disclose the substance of legal advice. take one second to do that.

MR. WOLMAN: any answer of that sort.

BALDIGA: MR. answer the question. don't know.

MR. KWOK: Have you ever asked anyone why they pay for

him to advise you? don't remember.

asked you last year why did Golden Spring

New York pay that judgment on your behalf, and I

referring to the one my client, Mr.

against you. I'm asking you again why did Golden Spring

20 21 22 23 24 25 New York pay that judgment on your behalf? A Q A them. It was money lended. Why did Golden Spring loan you that money? I don't have any thing so I borrowed from

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1 Q Where did Golden Spring get the money from? 2 A don't know.

3 Q Where does Golden Spring get any money from? 4 A don't know.

5 Q correct?

6 A Yes. 7 Q Does your son owe you any money? 8 A No. 9 Q How did your son get the money that funds 10 Golden Spring? 11 A don't know.

12 Q Did you ever provide your son with any seed 13 capital? 14 A No. 15 Q Have you ever invested in any of your son's 16 businesses? 17 A No. 18 Q When did Connecticut become your residence? 19 A End of February or early March of 2020. 20 Q And you're sure about that here? Okay. 21 A Yes. 22 Q And was that your primary residence since

2020? 24 A Yes.

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1 interest in Golden Spring New York.

2 that again.

3 Spring New York? 4 No.

6 Golden Spring New York Limited.

7 Are you an officer of Golden Spring New York again. 8 Limited? 9 No.

11 Spring pay Attorney Aaron, meaning Aaron Mitchell, 12 on your behalf. 13 I'm asking you again, why would Golden 14 Spring pay Attorney Aaron Mitchell on your behalf?

INTERPRETER:

16 I'll do that for him. interpretation. 17 A loan. A loan or borrowed money.

18 Why did they make you that loan?

19 have been borrowing from them all the time

20 was a member of the family.

21 Did you ever have any of your loans from

22 Golden Spring put in writing?

some no.

24 Which ones have been put in writing? Okay.

25 don't remember.

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1 How many loans have you had from Golden

2 Spring? 3 don't remember.

4 Were any of the loans that were put in

5 writing in English? 6 don't remember.

7 Were any of them in Chinese?

8 don't remember.

9 Did you ever pledge any security interest in

10 exchange for any of these loans?

12 (indiscernible).

BALDIGA: MR. 14 answer in English?

INTERPRETER:

16 don't remember.

18 don't remember how many loans you took out, how are 19 you able to identify how much they --

20 on your bankruptcy schedules? 21 didn't quite get you.

22 If you don't know how many times you took

23 out loans from Golden Spring, not all of which were 24 in writing, how do you know how much you owe them? 25 My lawyer and the lawyer of Golden Spring

Case 22-50073 Doc 250-17 Filed 04/22/22 Entered 04/22/22 16:59:37 Page 75 of

1 they communicate with each other.

2 amount they can define is 21 million. 3 So Golden Spring's lawyers helped prepare

4 your bankruptcy petition? Is that correct? 5 I'm sorry to interrupt. MR. BALDIGA: 6 two things.

7 No.

8 So how did the information get from Golden

9 Spring to your bankruptcy petition? 10 Objection to the question. BALDIGA: MR. 11 Sorry? INTERPRETER:

12 object to the question. BALDIGA:

MR.

MR. WOLMAN: 14 how this information he doesn't know wound up in his 15 bankruptcy petition?

BALDIGA:

MR. 17 that his lawyer and Golden Spring's lawyer discussed 18 it. you have another question?

Yes.

20 right?

Okay. BALDIGA: MR. 22 first and then ask another question, please. 23 ahead. Okay. INTERPRETER:

24 How did you know that number was right?

25 Number of what? Sorry? INTERPRETER:

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1 The number that was put into your bankruptcy

2 petition for what you purportedly owe to Golden 3 Spring, how did you know that was right? 4 believe the professionalism of my lawyers.

5 They will review and check all the figures.

MS. CLAIBORN:

8 reviewed? 9 apologize for interrupting. MS. CLAIBORN:

10 It's now 2 o'clock. BALDIGA: MR. 11 apologize for interrupting. MS. CLAIBORN:

12 It's Holley Claiborn.

MR. WOLMAN: 14 Appreciate it. filibustering to use up the time.

BALDIGA: MR.

addressed to? 17 comment.

You. MR. WOLMAN: 19 that to you.

MS. CLAIBORN:

BALDIGA: MR.

the next date.

MS. CLAIBORN:

23 going to suggest that we reconvene April 4th at 24 in person at the U.S.

10:00 a.m. 25 New Haven. Case 22-50073 Doc 250-17 Filed 04/22/22 Entered 04/22/22 16:59:37 Page 77 of

1 We'll look at schedules.

Mr. BALDIGA:

second.

MS. CLAIBORN: 4 translate that?

INTERPRETER:

6 you whether you still need me on the line for a 7 to log off?

MS. CLAIBORN:

second.

10 you to translate that so the debtor understands. 11 Okay. INTERPRETER:

12 I'm sorry.

BALDIGA: MR.

I'm sorry.

15 Bridgeport?

MS. CLAIBORN: 17 Haven at the U.S. Trustee's Office.

Okay. BALDIGA: MR. 19 very quick on that.

MS. CLAIBORN:

21 that right now because we need to be able to notify

23 conclude today. 24 I'll put you on hold. Okay. MR. BALDIGA:

Ms. HARBACH: MR.

Case 22-50073 Doc 250-17 Filed 04/22/22 Entered 04/22/22 16:59:37 Page 78 of

1 I'm afraid that that day will not work for Harbach. 2 us? 3 is that you?

Mr. MS. CLAIBORN:

ma'am.

HARBACH: MR.

6 any day after that.

7 5th. 8 How about Friday, April 8th? MS. CLAIBORN: 9 This is David. can do that. MR. HARBACH:

10 can do that.

11 This is Jay Wolman.

MR.

WOLMAN: 12 that.

MS. CLAIBORN: 14 check on April 8th, please?

HARBACH: MR. 17 Just anticipating that they're coming back again.

(indiscernible).

19 for whatever it's worth.

20 if that's better.

21 This is Bill Baldiga.

BALDIGA: MR. 22 and 8th are Buddhist holidays so for religious 23 Kwok can't do it those days.

reasons Mr. 24 clear the 4th.

25 (indiscernible). I'm wondering who could make it.

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1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Ho Wan Kwok - March 21, 2022 MS. CLAIBORN: How about March 28th, next Monday? MR. HARBACH: Holley, I didn't get the second part of what you said about the 28th. 78 MS. CLAIBORN: I only offered the 28th as a new date. MR. BALDIGA: This is Bill Baldiga. 28, 29 and 30 Mr. Kwok has a medical issue that he (indiscernible) during those days. MS. CLAIBORN: How about Friday, April 15th? MR. HARBACH: This is David Harbach. That's good by us. MR. BALDIGA: It's Good Friday. Good Friday for me and Passover for many. Can I suggest (indiscernible)? MS. CLAIBORN: I didn't hear your suggestion. I'm sorry. MR. BALDIGA: I respectfully ask that we go back to April 4. One lawyer among a dozen and one creditor should not MR. WOLMAN: This is Jay Wolman. I already have something for that day as well. MR. BALDIGA: (indiscernible) I know, but there are MR. WOLMAN: Two lawyers, including myself, 83

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1 who is in the middle of questioning.

MR. BALDIGA: 3 then. 4 Does April 6th work? MS. CLAIBORN: 5 What was that date? MR. WOLMAN: 6 April 6th? MS. CLAIBORN: 7 This is David Harbach.

MR. HARBACH:

8 do April 6th. 9 The debtor can as well. BALDIGA: MR. 10 As can I. UNIDENTIFIED:

Okay. MS. CLAIBORN: 12 It's in person.

6th 10:00 a.m. The U.S. 13 Office in New Haven.

15 security. I'd like to start at 10:00.

MR. BALDIGA:

18 interpreter, just so we can plan?

MS. CLAIBORN:

21 an understanding about an interpreter and I

22 have that at my fingertips right now.

Okay. MR. BALDIGA: 24 o'clock?

Case 22-50073 Doc 250-17 Filed 04/22/22 Entered 04/22/22 16:59:37 Page 81 of

finish this. obviously.

Okay. MS. CLAIBORN:

3 concluded for purposes of Bin's translation services 4 for today. 5 Thank you. INTERPRETER:

Bin. MS. CLAIBORN: 7 nice day.

INTERPRETER: 8 Thank you. MS. CLAIBORN: 9 I'm going to stop the recording, but we can 10 stay on the line. I'm going to stop the recording. 11 Thank you.

Case 22-50073 Doc 250-17 Filed 04/22/22 Entered 04/22/22 16:59:37 Page 82 of

I, CHRISTINE FIORE, court-approved transcriber and certified electronic reporter and transcriber, certify that the foregoing is a correct transcript from the official electronic sound recording of the proceedings in the above-entitled matter.