Guo Wengui / Miles Guo — bankruptcy case · EXHIBIT · ECF #398-1

Transcript of the April 12, 2022 Deposition of Yvette Wang

P.E.

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 In re: UNITED STATES BANKRUPTCY COURT DISTRICT OF CONNECTICUT BRIDGEPORT DIVISION )Case No. ) 22-50073- (JAM) Ho Wan Kwok, Debtor. REMOTE VIDEOTAPED DEPOSITION OF (30(b) (6) CORPORATE REPRESENTATIVE YAN PING WANG Tuesday, April 12, 2022 New York, New York Reported by: B. Suzanne Hull, CSR No. 13495 Page 1

5 HoWanKwok:

MR. KENNETH AULET 4 3 EXAMINATION BY PAGE

10 11 For Creditor Pacific O'Melveny & Myers 10

12 Opporhmity Fund, Attorney at Law 11 EXHIBIT

1625 Eye Street NW Transcript of testimony of

16 MS.

7 Times Square 17 April 26, 2019, one hundred

amurray@ornrn.com 20 Golden Spring (New York)

Cohn Birnbaum Shea 21 Limited, Delaware Coiporation,

100 Pearl Street Affidavit of Yan Ping Wang,

(860) 493-2220 24 dated November 14, 2013, three

2 APPEARANCES (Continued) 1 EXHIBITS (Continued)

5 Trustee:

By MS. HOLLEY L. CLAIBORN 4 (New York)'s Delaware Attorney at Law 5 certificate of incoiporation 6 1100 L Street NW 6 and certificate of revival,

Washington, DC 20005 7 dated March 10, 2015, five

9 holley.l.claiborn@usdoj.gov 9 Exhibit 6 -

10 For the Committee on Pullman & Comley 10 Opportunity Fund L.P. 's notice Secured Creditors: By MR. JONATHAN KAPLAN 11 of deposition of Golden Spring

90 State House Square 12 (New York) Limited pursuant to 12 Hartford, Connecticut 06103 13 Rule 30(b )(6) of the Federal (860) 424-4379 14 Rules of Civil Procedure,

14 jkaplan@pullcom.com 15 dated March 29, 2022, seven

16 The Videographer:

17 The Interpreter:

19 Also Present:

2 MR. ROSEN: Good morning.

Line 18 3 representing Golden Spring (New York).

Line 16 5 Pullman & Comley, representing the Committee of

Line 9 6 Unsecured Creditors.

7 Page 126 Line 20 7 MR. AULET: Kenneth Aulet, of Brown Rudnick, 09:16:40 8 Page 128 Line 18 8 representing the debtor, Ho Wan Kwok.

9 Page 13 0 Line 2 9 MR. SIL VER.BERG: Bennett Silverberg,

10 Page 150 Line 5 10 Brown Rudnick, representing the debtor.

11 Page 157 Line 17 11 MS. RUSSO: Makenzie Russo, with

12 12 O'Melveny & Myers, representing Pacific Alliance.

14 14 Pacific Alliance.

15 15 MS. CLAIBORN: And I am Holley Claiborn, for 09:17:02 16 16 the U.S. Trustee.

17 17 THE VIDEOGRAPHER: Thank you.

18 18 Will the court reporter please swear in both 09: 17:06 19 19 interpreters and then the witness.

20 20 THE REPORTER: Raise your right hand,

21 21 please.

24 24 having been called as an interpreter to interpret 25 25 English into Mandarin and Mandarin into English, was

I New York, New York I duly sworn to interpret the proceedings to the best 2 Tuesday, April 12, 2022; 9:15 a.m. 2 of her abilities and interpreted as follows:

THE INTERPRETER: Yes, I do.

5 THE VIDEOGRAPHER: Good morning. 5 THE REPORTER: Raise your right hand,

6 We are going on the record at 9: 15 a.m. on 09:15:21 6 please, Check Interpreter.

7 April 12th, 2022.

8 This is media unit one of the video-recorded 09: 15:27 8 UNA WILKINSON, 9 deposition of Yvette Wang as a 30(b)(6) witness for 09: 15:31 9 having been called as an interpreter to interpret

09:15:37 10 English into Mandarin and Mandarin into English, was II Creditor Pacific Alliance In Re: Ho Wan Kwok, filed 09:15:39 11 duly sworn to interpret the proceedings to the best 12 in the United States Bankruptcy Court, District of 09: 15:42 12 of her abilities and interpreted as follows: 13 Connecticut, Bridgeport Division. The case number is 09:15:47 13 09:17:42 14 22-50073 (JAM). 09:15:49 14 THE CHECK INTERPRETER: Yes, I do.

15 This deposition is being held virtually via 09: 15 :50 15 THE REPORTER: Raise your right hand please, 16 Zoom. 09: 15:57 16 Witness. 17 My name is Jeff Nichols, from the firm

18 Veritext Legal Solutions, and I am the videographer.

19 The court reporter is Suzanne Hull, from the firm 09: 16:02 19 called as a 30(b)(6) Corporate Representative by 20 Veritext Legal Solutions. 09:16:06 20 counsel for Creditor Pacific Alliance Asia

09:16:07 21 Opportunity Fund, L.P., being first duly sworn, 22 appearances and affiliations for the record. 09:16:10 22 testified as follows: 23 MR. HARBACH: Good morning.

24 I'm David Harbach, with O'Melveny & Myers, 09:16:15 24 THE WITNESS: Yes.

25 and I represent Pacific Alliance. 09:16:19 25 THE REPORTER: Okay. State credentials,

1 please. 09: 18:06 Q. Okay. Super.

THE INTERPRETER: Yes. 09:18:08 So if you would, please wait for me to

Good morning, everyone. 09: 18:09 3 fmish my question before you start answering, and

09: 18: 10 4 I'll do my best to wait for you to stop speaking

09: 18: 13 5 before I ask my next question.

6 Sunny Johnston. Certification number is 301314. 09:18:14 Okay?

A. Yes, sir.

8 credentials, please.

Thank you.

Q. Okay. Super.

10 interpreter for Mandarin and English, and 09: 18:26 And as I said a moment ago, if there is

11 a court-certified interpreter for the Unified Court 09: 18:29 11 a question that you do not understand, please just

12 System in New York state. 09: 18:33 12 let me know, and I'm happy to try and rephrase it.

THE REPORTER: Thank you.

13 13 And if there is a question that you would prefer be

THE VIDEOGRAPHER: Thank you. 09:18:37 14 translated in order to answer it, that is no problem. 09:21:52 You may proceed, Counsel.

15 15 That is what Ms. Johnston is here for.

Okay?

A. Yes, sir.

18 BY MR. HARBACH:

Thank you.

Q. Good morning, Ms. Wang. 09:18:41 Q. Okay. Are you on any medication or --

My name is David Harbach, as you just heard. 09:18:44 20

And a couple housekeeping matters before we

21 21 stipulations as to objections and signing.

22 get started.

What is your preference?

Are you able to hear -- are you able to hear 09: 18:54

24 me okay? 09:18:55 24 Scott.

A. Yes.

I can hear you clearly. 09: 19: 10 I objections reserved to trial except for form?

Q. I'm aware that you had given depositions in 09: 19: 12 2 MR. HARBACH: Yeah. That's okay with me.

3 the past in English.

MR. ROSEN: Okay. The witness is not going 09:22:36

09:19:18 4 to waive tbe signing and reading of the transcript.

5 English today?

MR. HARBACH: I didn't hear you, Scott.

A. Okay. My mother tongue is not English, but 09: 19:37 6 Could you please speak up?

7 I can try to go through the deposition in English;

MR. ROSEN: Yes.

8 however, I do need the interpreter stand by in case

The witness will not waive the signing and

9 I don't understand anything. 09:20:00 9 reading of the transcript.

Q. That -- that sounds perfect, and that is

MR. HARBACH: Okay. Understood.

11 just fine with us; so we can proceed in English. And 09:20:05 11 BY MR. HARBACH:

12 if you have a question or you would like a question 09:20: 10 Q. Ms. Wang,Iwasjustabouttoaskyouifyou 09:22:58

13 translated into Mandarin or if you would like an 09:20: 13 13 are on any medication or under the influence of

14 answer translated into Mandarin, please just say so,

15 and Ms. Johnston can help. 09:20:24 14 any- -- an1thing that might impair your memory or

15 interfere with your ability to answer questions

Is that acceptable to you? 09:20:27 16 truthfully.

A. Okay. Yes.

A. No.

Thank you. 09:20:52 Q. Is there any reason you can think of why you 09:23: 17

Q. Okay. Very good. 09:20:52 19 cannot provide truthful testimony today?

And just a few more things. Because we are

A. I don't think there is any reason, sir.

21 doing this deposition remotely, it is very important 09:20:59 21 Q. Okay. Super.

22 for the court reporter that only one person be

23 speaking at a time. 09:21:08 23 once before in October of2018 in litigation

Do you understand? 09:21 :09 24 involvingPAX.

A. (In English) Yes, Ido. Yeah.

Do you recall that deposition?

A. Correct.

A. I remember I was deposed before, but I don't 09:23 :48 I 2 recollect the -- the dates -- the precise dates. Q. Did you meet with them in person to do that 09:26:52

Q. Understand.

3 3 preparation?

Other than that deposition where PAX A. No.

5 examined you, have you been deposed in any other Due to COVID, I meet our counsels via -- via 09:26:59

6 litigation since then? 6 video call.

A. Sir, since -- since then? You mean since Q. Thank you.

09:24:19 Did you have communications with anyone else 09:27:08

9 9 at Golden Spring -- via telephone, videoconference,

10 deposition that PAX conducted of you was in October 10 or otherwise -- to prepare for today's deposition?

11 of2018. 09:24:26 MR. ROSEN: Objection.

And my question is have you been deposed 12 09:24:30 The witness can answer without disclosing

13 since then? 13 any conversations with either inhouse counsel or

A. I believe so. 09:24:34 14 outside counsel.

Q. And do you recall when? THE WITNESS: Sir, sorry.

A. I don't recall. Can you repeat your question?

Q. In what proceeding? 09:24:45 17 BY MR. HARBACH:

A. It was in a case called Strategic Vision, 18 09:24:49 Q. Yes.

19 Eastern Profits -- or Eastern Profits, Strategic 09:24:57 It was a yes-or-no question that did not

20 Vision. It should be the same case. 20 call for any -- any privileged information.

Q. Okay. And in -- in what course is that The question is did you meet with any

22 case, if you know? 22 personnel at Golden Spring -- via telephone, Zoom,

A. In a court in New York. 09:25:08 23 videoconference or otherwise -- to prepare for your

Q. Okay. Any other depositions, besides that 09:25:11 24 deposition today?

25 one, since October of2018? 09:25:20 A. Yes, I did.

A. Hmmm. No.

Q. Do you understand that you are here today as 09:25:27 2 Golden Spring to prepare for your deposition today?

3 a corporate representative of Golden Spring 3

4 (New York)? A. I communicated with the owner of 09:25:40 4 Golden Spring (New York) Limited, Mr. Qiang Guo. Let 09:28:U

A. Yes, I do. 09:25:40 5 me spell, Q-i-a-n-g, last name G-u-o.

Q. Did you review the topics that we intend to Q. How much time did you spend communicating

7 cover with you today that were contained in the 7 with him?

8 deposition notice before your testimony today?

A. How much time? Like, ten fifteen -- about,

A. Yes. 09:25:55 9 like, fifteen minutes -- ten, fifteen minutes.

I did review the topics. Q. Is there anyone else at Golden Spring with

Q. Okay. What did you do to prepare -- excuse

11 11 whom you communicated to prepare for today's

12 me -- prepare for your deposition today, generally 12 deposition?

13 speaking? 09:26:08 A. No.

A. I prepared with our law firm -- with our Q. Is there anyone else in the world, other

15 attorneys. 09:26:15 15 than attorneys, with whom you communicated to prepare 09:29:01 Q. Okay. Did you review documents?

16 16 for today's deposition?

A. Yes. A. No.

18 Q. What is the name of -- withdrawn.

Q. Did you meet with any other personnel at A moment ago, when you said you met with

20 Golden Spring to prepare for your deposition today? 20 lawyers to prepare for today's deposition, lawyers

A. Meet -- I'm sorry.

21 21 from which firm or firms?

What do you mean? You mean meet in person? 09:26:38 22 A. Attorneys from Mr. Scott Rosen's firm.

23 What do you mean, meet? 09:26:41 23 I couldn't pronounce his law firm's name. It should 09:29:45

Q. Well, a moment ago you said that the law

25 firm assisted you in preparing for today. 09:26:49 24 be -- I mean, it is complicated for me to pronounce

25 his law firm's name; so Mr. Scott Rosen and his

I colleague, Mr. Timothy -- Tim. 09:29:59 1 the -- the second one that says deposition of

Q. Tim Miltenberger? 09:30:01 2 Yvette Wang.

A I believe so. I don't remember his last

MR. ROSEN: Counsel, before you proceed with 09:35: 11 4 name It sounds like it correct. 09:30:07 4 the question, could you please explain to me which of 09:35: 13 Q. Okay. Did you meet or consult with any

09:30:09 5 the 30(b )(6) topics this document pertains to.

6 lawyers from the Brown Rudnick firm to prepare for 09:30: 13 MR. HARBACH: Well, it could be -- it could 09:35:23

7 today's deposition? 09:30:23 7 be any number of them because the document is the

09:30:24 8 transcript of her prior deposition; so it will be

Q. When was Golden Spring (New York)Limited 09:30:27 9 multiple such topics.

10 formed?

MR. ROSEN: I'll reserve the right to object 09:35:36

A Golden Spring (New York) Limited was formed 09:30:40 11 and instruct the witness not to answer if it exceeds

12 in the year of 2015. 09:30:45 12 the scope of the 30(b )(6).

Q. Does March 2015 sound about right to you?

But go ahead and proceed.

A In March, yes.

MR. HARBACH: Understood.

09 30.59 Is there anyone who can't see the exhibit in 09:35:49

16 relationship to Golden Spring (Hong Kong)? 09:31 :03 16 their marked exhibits folder before I go on?

A Golden Spring (New York) Limited is 17 BY MR. HARBACH:

18 100 percent owned by China Golden Spring (Hong Kong). 09 :31 : 15 18 Q. Okay. Ms. Wang, can you see it?

Q. And for purposes of today's deposition, I'm 09:31 :21

A. Sir, I can see a .pd- -- it says .pdffile

20 going to refer to China Golden Spring (Hong Kong) as 09:31 :27 20 with forty-two pages.

21 just Golden Spring (Hong Kong).

Q. You got it?

Is that okay with you?

A. This is the one?

A Yes.

Gotit. Okay.

Q. Okay. Did you ever work at Golden Spring

09:31 :39 Q. Yes, ma'am.

25 (Hong Kong)?

Please open that one up.

A Yes.

Q. Do you recall when you worked there?

2 Yes.

A That was back to 2016 for, like, a couple of 09:31:53 3 Q. So just to refresh your recollection before

4 months. 09:32:05 4 I proceed, the question I put to you concerned the

Q. Okay. I would like to show you what I'm

09:32:07 5 dates that you worked at Golden Spring (Hong Kong).

6 going to mark as Exhibit 1. 09:32:22 6 And I believe you said that it was approximately

7 7 2016. And I just want to show you in the deposition 09:36:36

8 8 in 2018 where you were asked about this. Let me read 09:36:42 MR. HARBACH: And we'll just wait a moment

09:32:32 9 what you said, and then ask the question again.

10 for my colleague to drop it in there. Just sit

So I -- can I direct your attention to page

11 tight, everybody. It will be there in a second. 09:32:56 11 thirty of the transcript.

12 Sorry for the delay. We are working on it. It seems 09:33: 17 12

13 to be a little slow. It is uploading now.

Q. Let me know when you are there.

A. Page thirty, three, zero, sir; right?

15 there, but I don't see it in my marked exhibits 09:34:33 Q. Yes,ma'am. That is right.

16 folder. 09:34:37 And it is the -- you know, page thirty of

Does anyone else? 09:34:38 17 the miniature pages.

MR. KAPLAN: There -- there are two folders. 09:34:42 18 Do you see how each of the miniature pages

19 It looks like it is in the second one. 09:34:45 19 is numbered?

MR. HARBACH: Okay. Got it. 09:34:57 A. I am on page thirty.

What do you mean, miniature pages? I don't 09:37:33

09:35:00 22 understand that.

09:35:00 Q. Well, each-- sure.

MR. HARBACH: That seems to be the way it is 09:35:02 25 on -- on my computer. It is in the second one in 09:35:05 Each page of the document that I just sent

25 you has four pages of the transcript on it.

Do you see that? 09:37:47 1 from 2018, I believe; so before that I don't believe

A. Yes.

2 2 I work for Golden Spring (New York). Technically,

Q. Okay. So those are the page numbers that 09:37:48 3 I work for Golden Spring (Hong Kong) and -- which

4 I am referring to. And on page thirty, at line ten, 09:37:52 4 include the time of the 2016, when I revert because

5 you were asked a question that reads: 09:38:03 5 2015 -- 2016 I revert. 2016, that is a more

"QUESTION: Then you moved to Hong Kong 09:38:05 6 6 consecutive period of time for me to base in

in 2015 to work in September of2015 to work 09:38:07 7 7 Hong Kong; so besides that, I traveled between

09:38: 13 8 Hong Kong/U.S.

And your answer was: 09:38:18 Q. Okay. Solthinkiunderstandyou,but

10 10 I want to make sure.

Do you see that there?

11 In approximately 2015 you started working

A. Sir, which page? It is page thirty, but

09:38:23 12 for Golden Spring (Hong Kong), and you worked for

13 there are four -- four little page number. 09:38:26 13 Golden Spring (Hong Kong) until sometime in 2018, at 09:41:40

09:38:31 14 which point you began working for Golden Spring

A. I'm not sure which one.

15 15 (New York).

Q. Right. 09:38:34 Do I have that right?

A. Is it Page 113 or 14, 15 or 16 9 Which one

09:38:35 A. I officially started to work for

18 you are talking about? 09:38:39 18 Golden Spring (New York) from 2018, yes. You are

Q. I understand. I understand your confusion. 09:38:41 19 correct on that.

Q. Okay. And prior to that, you worked for

21 transcript, I am only talking about the pages -- the 09:38:46 21 Golden Spring (Hong Kong); is that correct?

22 page numbers for the small pages.

A. I believe it is more a mix because I was

A. Oh.

23 23 working for Golden Spring (Hong Kong) and same time

Q. Okay? 09:38:54 24 I was working for Mr. Qiang Guo, his family business

And I know it is confusing. I'm sorry.

Page 22 25 in China also; so that is the reason when I referred 09:42:29

A. All right. Let me go back and find it. 09:38:59 I I was in Hong Kong in 2016. That is a -- as I said, 09 :42 :33 Q. Yeah. Go back to page thirty of the little

09:39:01 2 a penod of consecutive time for me to -- leaving

3 pages. 09:39:04 3 Hong Kong and working Hong Kong -- for Hong Kong.

4 That is my -- that is my representation. Yes.

Q Were you -- at the time you were working for 09:42:51 I'm on the little page, on page thirty right 09:39:14 6 6 Golden Spring (Hong Kong), were you physically in

7 now.

Q. Okay. Yes. Sorry for the confusion.

A Not always.

So take a look at line ten on page thirty,

10 and you will see a question there about when you 09:39:22 10 United States?

11 moved to Hong Kong to work for Golden Spring

A What do you mean, move, sir? 12 (Hong Kong). 09:39:30 Q When did you come to the United States for

Do you see that?

13 the first time? How about that?

A. Yes. 09:39:35 A That was many years ago.

I saw this.

15 Q Did you come to the United States during the 09:43:28

Q. Okay. And so my question for you is --

09:39:55 16 time that you worked for Golden Spring (Hong Kong)?

17 first of all, let's just focus on the date.

A Yes.

09:40:03 During the time I worked for Golden Spring

19 your judgment about when it was that you began to 09:40:09 19 (Hong Kong), I did travel into the United States

20 work for Golden Spring (Hong Kong)? 09:40:12 20 also.

A. My answer, back to this page, which I mean

21 Q Okay When was that?

22 that, yes. I moved to Hong Kong in 2015, and then 09:40:25 A Oh, I couldn't recall. It should -- between 09:43 :49

23 I worked in there. I traveled to -- in U.S. But if 09:40:28 23 2015 to 2017 or '18. I couldn't recall.

24 you have my full Golden Spring (New York) corporation 09:40:34 24 25 records, I officially start work in Golden Spring 09:40:41 Q When you came to the United States in that

25 time period, did you return to China?

Q. Did you move? Do you know what I mean by

2 please show me which of the 30(b)(6) topics this 09:44: 18 2 move?

3 relates to and give me some explanation as to where

A. Yes.

4 you are going here.

Q. Okay. Did there come a time when you moved 09:46:48

MR. HARBACH: Yeah. Sure. 09:44:26 5 to the United States for work?

6 A. Yes.

7 background of the witness' affiliation with the 09:44:29 Q. When was that?

8 company that she represents. It is very basic. I am 09:44:34 8 A. That was started I became to be the officer 09:47:01 9 trying to figure out when she worked, where, and for 09:44:36 9 and director of Golden Spring (New York).

10 whom. That's it. It informs her competency as the

Q. Which was when?

11 30(b)(6) witness, and it gives con- -- it gives 09:44:44 A. Thatwasbeginningof2018,lateof2017.

12 context to her later testimony. 09:44:47 12 I couldn't remember. It should be beginning of 2018. 09:47:25 MR. ROSEN: I -- honestly, I don't see how

13 Q. Okay. I'm going to show you another

14 her travel plans has anything to do with this. 09:44:52 14 document.

15 MR. HARBACH: We'll call this one number

16 this point to simply not answer questions about her 09:44:58 16 two.

17 travel and her whereabouts at various times. If you 09:45:02 17

18 would like to ask questions about her specific duties 09:45:05 18

19 and what she performed and when she performed it, 09:45:08 19 BY MR. HARBACH:

20 I have no objection to that.

21 21 Ms. Wang?

22 object to any question about her physical location

A. Yes.

23 when she performed those duties? Is that what

Q. Okay. It should also be a .pdf. Please

24 I understand? 09:45:18 24 open it up.

MR. ROSEN: You --your questions were going 09:45:20

I way beyond that. If you want to ask her specific 09:45:23 Yes, I did.

2 duty and where she was, then we can address that

Q. Okay. Now, on this one I'm going to ask you 09:48:55 3 question as it comes up. But you are asking about 09:45:28 3 to turn to page -- okay -- forty-nine.

4 general travel plans. You are asking about her--

5 her work for other companies. She is a 30(b)(6)

Q. Tell me when you are on page forty-nine.

6 witness for Golden Spring (New York), and that is

A. Yes, I am.

7 where the questions should be directed.

Q. Okay. Looking at line five, the question

8 BY MR. HARBACH: 09:45:44 8 was put to you:

Q. Ms. Wang, where were you physically located 09:45:45 "QUESTION: And when did you move to

10 when you worked for Golden Spring (Hong Kong)?

A. What do you mean, physically located?

12 I mean, like, stay in hotel or staying-- I mean, 09:45:59 Your answer:

13 I don't understand, sir. 09:46:03 "ANSWER: That was a date I never

Q. What country were you in when you worked for 09:46:04 14

15 Golden Spring (Hong Kong)? 09:46:07 Do you see that there?

A. I was in Hong Kong, and I was -- I traveled 09 :46: 10 A. Yes,ldid.

17 in the U.S. I traveled in UK. I mean, I still don't 09:46: 14 17

18 understand what do you mean physically located, but 09:46: 19 18 the record -- correction.

19 that is the places I had been to.

This testimony, for the record, was given in 09:50:06

09:46:24 20 May of 2019, just under three years ago.

21 merge -- moved to the United States permanently for 09:46:29 21 BY MR. HARBACH:

22 work?

A. Sir, what do you mean permanently? 09:46:35 23 New York to start working for the Guo family in April 09:50:20

Q. Did you move? 09:46:38 24 of2015?

Page 27 A. As I said, English is not my mother

1 language. When you say move, I mean, I understand 09:50:32 1 New York and Hong Kong both. I don't see now where

2 better by now more than two, three -- three, four 09:50:35 2 there is any problem. I said I'll work in New York

3 years ago, and that was right. I left China. I came 09:50:40 3 and Hong Kong -- starting from New York and back to

4 to New York-- I came to New York first. Then I went 09:50:45 4 Hong Kong because I originally need to follow

5 back to Hong Kong. 09:50:49 5 Mr. Qiang Guo, if that makes sense to you, sir.

6 So regarding work for it the Guo family, 09:50:50 Q. Well, I just want to point out that I wasn't 09:54:21

7 which I refer always as my -- my boss -- like, the 09:50:54 7 suggesting there was a problem. I am just trying to

8 owner of Golden Spring, Mr. Qiang Guo -- Q-i-a-n-g 09:51:00 8 understand the facts of what happened; so here is my 09:54:28 9 G-u-o --that is the same Guo family. 09:51:06 9 next question.

10 Q. So did you start working for the Guo family 09: 51:09 When did you start working at Golden Spring 09:54:32

II in New York in April of2015? Is that correct or not 09:51:23 11 (New York)?

12 correct?

A. I believe I replied your question, sir,

13 A. I started to work for the Guo family from 09:51:33 13 about Golden Spring (New York). That was started --

09:51:39 14 I was appointed as officer and director of

15 Q. Yeah. Let me -- let me interrupt and ask my 09:51:43 15 Golden Spring (New York).

16 question again as you may have misunderstood it.

Q. When?

17 Did you start working for the Guo family in

A. 2018.

18 New York in April of2015?

Q. Do you recall when in 2018?

19 A. Start work for the Guo family. I mean, 09:52:00 A. In spring of 2018.

20 again, I don't remember this question many years ago. 09:52: 13 20 Q. Okay. Let's go back to Exhibit I. Let me

09:52:17 21 know when you have got Exhibit I pulled up, Ms. Wang. 09:55:14 22 Q. No.

23 You -- you -- you testified that it was

Yes. I'm here.

24 a date you'll never forget; so that is why I'm

Q. Okay. Page numbers again, I'm talking about 09:55:22 25 pressing you a little bit on it. 09:52:25 25 the little page numbers. If you please go to page

I My question is when did you start working 09:52:27 I thirty-five.

2 for the Guo family in New York? The transcript here

A. 3 seems to suggest that that was in April of 2015, and 09:52:38 Let me know --

Q.

4 I'm asking you whether that is accurate. 09:52:44 A. Yes.

5 Is it accurate? Is it not accurate? Or do

Q. -- when you are there.

6 you not know? 09:52:51 Yes. I'm here.

A. 7 A. April 23rd in 2015. That is the date 09:52:52 Q. Okay. Take a look on page thirty-five of

8 I never forgot because I left China. I was never -- 09:53:00 8 Exhibit 1, line ten.

9 I was never able to go back.

10 Okay? 09:53:06 Q. The question reads:

11 So that is accurate. When I answered this 09:53:07 "QUESTION: You said in February of2018 09:56:07

12 question, I don't believe I have any interpreter help 09:53:10 12

13 me by then; so the question looks like right now

14 reading as when did you move to New York to start

And your answer was:

15 working for the Guo family? I was not quite

16 understanding this question withouttranslation by

17 then; so if you ask me when I start to work for Guo 09:53 :27 17 February of '18 sounds like the correct date to you

18 family, which I can tell you, I started-- my career 09:53:31 18 of when you started working for Golden Spring

19 started from 2008, but I started to work for Guo 09:53:36 19 (New York).

20 family outside of China. That was started from 2015. 09:53:40 A. Sir, I replied as in spring of 2018.

21 That is my correct and truthful answer now.

22 Q. And that was in New York City; correct?

Q. I'm -- I'm not suggesting anything other

23 A. Starting from New York and Hong Kong. 09:53:49 23 than whether February is correct.

25 Q. Okay.

A. I mean, by then Mr. Qiang Guo, he was in

Does that sound about right to you?

A. I don't recall. In spring of 2018. You

1 could check on Golden Spring (New York)'s corporation 09:56:49 1 whether there was a chauffeur employed at

2 book. It should be clearly in there. 09:56:54 2 Golden Spring (New York) when you started there?

3 Q. Was anyone else working at Golden Spring 09:56:56 A. Sir, I am the witness today-- in my

4 (New York) when you started there in the spring of 09:57:07 4 understanding is about bankruptcy. I mean that this

5 2018? 09:57:09 5 is my task -- this was my testimony how many years

6 A. What do you mean, is there anyone working at 09:57: 10 6 ago? Three, four years ago?

7 Golden Spring (New York)?

8 Q. Well, you mentioned that you were, I think 09:57:21 8 that was a relatively closer date. I was deposed in 10:00:32 9 you said, appointed to Golden Spring in the spring of 09:57:24 9 October 2018, as you said. Now it is almost three

10 2018. 09:57:29 10 and a half, four years after. I mean, just so many

11 My question for you is at the time that you 09:57:32 11 years pass by, I couldn't remember that. But since

12 were appointed, were there any other people working 09:57:34 12 my testimony back to 2018 in here said that, that is

13 for Golden Spring (New York)? 09:57:40 13 possible. That reminded me. That's right. But that 10:00:54 14 A. Mr. Qiang Guo, himself. 09:57:44 14 doesn't mean that after three and a half, four years, 10:00:57 15 Q. Okay. Andwhatwashisjob? 09:57:49 15 I still should remember all the details; right? I am 10:01:02 16 A. He is one of the directors of Golden Spring 09:57:55 16 being deposed in here about a bankruptcy.

17 (New York).

Am I correct about this?

18 Q. Anyone else? 09:57:59 Q. Well, you are --you are right about one

19 A. No. 09:58:03 19 part, and that is that I offered you this information 10:01:11 20 Just me and himself, when I was appointed. 09:58:08 20 to see if it would help refresh your memory.

21 Q. So no other employees who worked at

And, indeed, that was the question, whether

22 Golden Spring at that time? 09: 58: 19 22 reading this transcript helps refresh your memory

23 A. I don't recall. 09:58:23 23 about whether there was a chauffeur working at

24 Q. Do you recall whether there was a chauffeur 09:58:23 24 Golden Spring (New York) when you started.

25 who worked for Golden Spring (New York) at that time? 09:58:33 25 A. I --

I A. I don't recall. 09:58:35 MR. ROSEN: At this point, I'm going to

2 Q. Let's take a look at Exhibit 1 again. 09:58:35 2 instruct the witness not to answer any further

09:58:41 3 questions along these lines.

4 Q. And this time let's go to page forty.

This is a deposition in a contested matter

09:58:55 5 for approval ofa DIP financing arrangement in

6 Q. Tell me when you are there. 09:59:02 6 a bankruptcy case. So far, of the list of30(b)(6)

7 A. Yes, I am. 09:59:07 7 topics, these questions barely hit on any of these --

8 Q. Okay. Take a look at line seven. You say: 09:59:08 8 of the topics, maybe a little bit on the ownership

09:59:24 9 structure. You have already covered the officers,

10 a driver. I met a chauffeur, a Korean 09:59:25 10 employees, and directors, and so far nothing about

09:59:30 11 a DIP loan.

12 And then there is a question: 09:59:33 So I would ask you, if you are going to do

09:59:35 13 a fishing expedition or try and extend litigation

14 employee of Golden Spring before February of 09:59:36 14 from other courts here, that! would have to instruct 10:02: 12

09:59:39 15 the witness not to answer.

17 Your answer:

09:59:43 16 BY MR. HARBACH:

Q. Ms. Wang, just a moment ago you said that

18 told me by then. 09:59:46 18 reading this deposition transcript did help you

19 "QUESTION: You met a chauffeur who told 09:59:48 19 remember.

20 you that he was an employee of Golden Spring 09:59:50 And so my question is was there or was there 10:02:26

21 (New York)? 09:59:53 21 not a chauffeur working at Golden Spring (New York)

09:59:54 22 at the time you started there?

23 And then you say that he was the one who

A. As my testimony back to 2018 said so, it is

25 24 picked you up at the airport.

Does that refresh your recollection about 10:00:01 24 possible. You are helpful, sir.

1 New York when you started working at Golden Spring

Q. No problem at all.

2 (New York)?

A. Thank you.

Q. So we'll stick with Qiang Guo.

4 witness not to answer.

A. Thank you.

5 This has no relevance whatsoever to any of

Q. Okay. And you just testified that he is the 10:06:14 6 the 30(b)(6) deposition topics, none. And the 10:03:06 son of Ho Wan Kwok, the debtor; right?

7 purpose of this is strictly to either relitigate or

A. You are right, sir. Yes.

8 extend litigation from other courts or to harass this 10:03: 13 8 Q. So my question is was Qiang Guo living in

9 witness. 10:03:17 9 New York when you started working at Golden Spring

10 BY MR. HARBACH: 10:03:18 10 (New York)?

11 Q. Ms. Wang, do you know who Mileson Kwok is? 10:03:18 11 A. Whatdoyoumean,livinginNewYork,sir?

12 A. Can you spell the name again, sir, please? 10:03:25 12 Like, I mean, I don't understand. Travel in there.

13 Q. Yes. 10:03:28 13 I met him in there, yes. I don't understand what you 10:06:38 14 M-i-1-e-s-o-n Kwok, K-w-o-k. 10:03:29 14 mean, living in New York.

15 Do you know who that is?

16 A. I don't know who you are referring, sir. 10:03:41 16 me. My question in English would be did

17 Q. Okay. You have mentioned someone who was 10:03:43 17 Mr. Qiang Guo live in New York at the time you

18 a director of Golden Spring at the time you became 10:03:47 18 started working at Golden Spring (New York)?

19 a director.

Could you please translate that for me?

20 What is that person's name?

21 A. If you refer to Mr. Qiang Guo, the same 10:03:56 THE WITNESS: (Through the Interpreter)

22 director when I was appointed, his name is Q-i-a-n-g 10:04:01 22 I officially started working for Golden Spring

23 G-u-o. His English name is Mileson, M-i-1-e-s-o-n, 10:04:08 23 (NewYork)in2018. Idon'trecall whether or not

24 and the last name is G-u-o, sir, if that is helpful 10:04:20 24 Mr. Qiang Guo was living in New York at the time.

25 to you.

1 Is this the person you are referring? 10:04:27 1 BY MR. HARBACH:

2 Q. It -- it is. 10:04:29 Q. Did you see him in New York personally

3 A. Okay. 10:04:29 3 around the time that you started working at

10:04:29 4 Golden Spring (New York)?

A. I don't recall.

6 Mileson Kwok. I mean, I never heard about this 10:04:33 Q. Have you ever seen Mr. Qiang Guo personally

7 person. 10:04:36 7 in New York?

8 Q. Okay. How is Mileson Guo related to 10:04:36 A. Yes, I did.

9 Wengui Guo? And that is spelled W-e-n-g-u-i G-u-o.

Q. When was the last time?

10 How are they related, if at all, if you

A. I don't recall.

11 know? 10:05:00 Q. Within the last year?

12 A. Mr. Qiang Guo -- Q-i-a-n-g G-u-o -- he is 10:05:00 A. I don't recall.

13 the son of Mr. H-o W-a-n K-w-o-k. 10:05:07 Q. Within the last five years?

14 Q. And that is H-o W-a-n K-w-o-k; correct?

A. Yes.

15 A. You are right, sir.

It was possible.

16 Q. So for ease of understanding for everyone 10:05:30 Q. Was Mr. Ho Wan Kwok living in New York at

17 who is reading this transcript, can we please refer 10:05:33 17 the time you started working for Golden Spring

18 to Mr. Ho Wan Kwok's son as Mileson? Is that okay 10:05:36 18 (New York)?

19 withyou?

20 A. No, sir. 10:05:46 20 issue.

21 I will prefer to stay with Mr. Qiang Guo. 10:05:47 I think-- Counsel, could you please explain 10:08:55

22 The reason because, again, English is not my mother 10:05:51 22 the relevance of this question to me.

23 language. I do not want to pronounce something which 10:05:54 23

24 was -- which could be misunderstood by everyone here, 10:05:58 25 iflmay. 10:06:03 24 Mr. Ho Wan Kwok is the debtor, and it is certainly

25 with- -- within the scope of appropriate topics, in

1 our view, for me to explore Mr. Ho Wan Kwok's 10:09:13 A. Yes.

2 relationship to Golden Spring (New York), which is

Q. Did you create this document?

3 his putative lender on this DIP loan; so I'm starting 10:09:20 A. I don't recall. It should be prepared by --

4 with the question about where Mr. Kwok lived at the 10:09:29 4 I don't recall.

5 time the witness started working at Golden Spring 10:09:32 Q. Give me just one moment, please.

6 (New York). That is the relevance.

7 BY MR. HARBACH: 10:09:35 7 y'all, buthopefullyl'vejustsavedusalittle

8 Q. Ms. Wang, what is the answer? 10:09:35 8 time.

10:09:37 9 BY MR. HARBACH:

10 witness not to answer this question. This is --

Q. I'm going to ask you to put aside Exhibit 3, 10: 14:05 11 there is no relevance that I can see to disclosing 10:09:42 11 and I'll come back to that a little later.

12 the whereabouts and the present location of parties

Okay?

13 here to a DIP loan funding. This is just -- it is I 0:09:48 A. Yes.

14 just harassment.

10:09:57 15 Golden Spring (Hong Kong), did you have any titles?

16 instructing the witness not to answer, Scott?

A. I don't recall. Too many years ago.

17 MR. ROSEN: Yes, I am.

Q. What were your duties at Golden Spring

18 MR. HARBACH: Okay. 10:10:03 18 (Hong Kong)?

19 BY MR. HARBACH:

20 Q. Ms. Wang, when you started working at 10: 10:04 20 please point to which topic on 30(b)(6) that

21 Golden Spring (New York), what was your title? 10: 10:06 21 a corporate witness of Golden Spring (New York)that

22 A. I was -- I am -- I was the -- the president, 10: 10: 11 22 this would -- this would be appropriate to?

23 secretary, I believe treasurer also, and director.

24 Q. So you said, to make sure I have this right: 10: 10:23 24 competency to testify as a representative of

25 President, secretary, treasurer, and director; is 10:10:27 25 Golden Spring (New York) by reference to her prior

I that correct? 10:10:31 1 experience and its relationship to her current

2 A. Correct.

3 Q. I'm going to show you -- let's call this 10: 10:32 l\1R. ROSEN: I'll let the objection stand.

4 numberthree.

But you can answer the question.

10: 10:43 5 BY l\1R. HARBACH:

Q Thequestion,Ms. Wang, was what were your

7 MR. HARBACH: Wait for it to get populated. 10:10:48 7 duties at Golden Spring (Hong Kong)?

8 I'm told it should be there. I have it.

9 BY MR. HARBACH: 10:11:30 9 company, Mr. Qiang Guo, and worked for him.

10 Q. Ms. Wang, do you have number three?

Q Did you -- domg what?

11 A. Yes, sir. 10:11:34 A Doing the task that he request me to do.

12 I have it. 10:11:35 12 I don't recall. It is too many years ago.

13 Q. Okay. Super. 10:11:36 Q You -- you -- you don't recall what your

14 Open that -- that one up. 10: 11:37 14 tasks were?

A It is pretty diversified.

16 Q. And tell me if you recognize this document.

Q Okay Do you recall whether when you were

17 A. Yes. 10: 11:46 17 working for Golden Spring (Hong Kong) you did any

18 Q. Okay. This is a document that you helped 10:11:50 18 work for Mr. Ho Wan Kwok?

19 create and submitted with an affidavit, isn't it?

A I'm sorry.

20 A. What do you mean I created, sir?

Sir, what is your question?

21 Q. Well, let me withdraw that question. 10:12:08 Q When you were working for Golden Spring

22 You said that you recognized this document. 10:12: 11 22 Hong Kong, did you do any work for Mr. Ho Wan Kwok?

23 What is it?

A I don't recall.

24 A. It is a director and officer register.

1 (NewYork)Limited? 10:16:51 Q. The transcript that! just read from was not 10:20:21

A. I was appointed by Mr. Qiang Guo. 10:16:52 2 a deposition. It was testimony in court, and it was

Q. When he appointed you to those positions, 10: 16:56 3 in May of 2019.

4 what did he tell you your duties would be?

A. Okay.

A. I was appointed, and he -- he requested me

5 Q. But these -- these appear to have been your

6 to operate -- to run Golden Spring (New York), his 10:17:14 6 words, and so that is why I asked the question.

7 company, as general.

Q. Tell me what you mean by as general. 10:17:21 8 testimony was correct. I mean, the entire --

A. I mean any task, assignment as the owner of 10: 17:25 9 9 Mr. Qiang Guo, his family business, including his

10 company, himself, he requested to do that I will work 10:17:34 10 employees, were all persecuted. They are either

11 for him. 10:17:39 11 arrested, kidnapped, or disappeared. I was one of

Q. When you assumed the role of president,

10:17:40 12 the survivor by then. That was correct.

13 secretary, treasurer, and director of Golden Spring 10: 17:56 And then when I testified back to 2019,

14 (New York), did you have any financial professional 10:18:02 14 I said I don't have -- that was -- I am humble;

15 knowledge? 10:18:05 15 right? So that was my testimony-- test- --

A. What do you mean, financial professional

16 16 testimony. And then now in 2022, I mean, I could

17 knowledge, sir? 10:18:14 17 learn lots in three years; right?

Q. Let's go back to Exhibit 1. 10:18:15 Q. Of course.

Q. Correction. Sorry. 10: 18:24 Q. Of course.

Exhibit 2. 10:18:27 A. -- that doesn't mean I don't have anything

Q. Page forty-seven.

23 Q. Of course.

A. -- to testify in this bankruptcy, you know,

Q. Actually, you might need to look a bit 10: 18:51 25 deposition.

I earlier on to forty-six. 10:18:55 Q. Yeah. Iunderstandthat--thatthreeyears 10:21:35

Tell me when you are there. 10: 18:59 2 have passed. My question isn't about today.

A. I am on page forty-six.

My question is about the day when you were

Q. Okay. At the bottom of page forty-six there 10:19:03 4 4 appointed to be president, secretary, treasurer, and

5 is an answer that begins -- and it was in response to 10: 19:07 5 director of Golden Spring (New York). I'm asking

6 a question about some exhibit you were being shown. 10: 19: 11 6 about that day.

7 In the course of your answer, which goes on to page 10:19: 15 And my question is as of that day, did you

8 forty-seven, you say, among other things: 10: 19: 19 8 have any financial professional knowledge?

9 A. What kind of financial professional

Golden Spring. This is not my choice because 10: 19:24 10 10 knowledge you are looking for back to three years

Chinese Communist party, they kidnap almost 10: 19:27 11 ago, sir?

all my colleague, between me and the company; 10: 19:32

Q. They were your words, Ms. Wang. You said,

so my background, I do not have financial

13 13 I do not have financial professional knowledge.

10:19:38 14 I don't know what you meant. That would be a good

American real estate professional knowledge." I 0: 19:41 15 15 question, but it is what you said; so that is why

And your answer goes on.

16 16 I used those words in asking you. It is a simple

But I have just read the two sentences that 10: 19:47 17 question.

All I'm asking is at the time you assumed

19 question to you was when you assumed the roles of 10:19:52 19 all of those titles at Golden Spring (New York), did

20 president, secretary, treasurer, and director of 10: 19:55 20 you have any financial professional knowledge? Yes

21 GoldenSpring(NewYork)Limited,didyouhaveany 10:20:00 21 orno?

22 financial professional knowledge? 10:20:04 A. When I say I didn't-- when I said I don't

What is the answer?

23 23 have, as I repeat again, that is our culture -- our

A. These deposition happened in which year, 10:20:11 24 culture, Chinese culture. I was humble to say

25 sir? 2018 or '19?

Page 47 25 I don't have professional knowledge.

Q. I understand. 10:23:11 1 Mr. Ho Wan Kwok and his family?

2 A. English is not my mother language. I do not I 0: 23: 12 2

3 mean that I know nothing about financial, if that is 10:23: 15 3 conclusion.

4 the answer you are looking for, sir. 10:23:20 You can answer that.

5 Q. All I'm looking for is the truth, first of

THE WITNESS: I need interpreter help me.

6 all. 10:23:25 6 I don't understand your question, sir.

7 Second, I am not asking you to be humble or

MR. HARBACH: Okay. But before we -- before 10:26:01 8 proud. I'm just asking you to be honest. 10:23:31 8 we go there -- actually, let -- let's -- Sunny, if

9 A. I am. 10:23:34 9 you don't mind, I will ask the question again. And

10 Q. So similarly, I mean, you were under oath 10:23:34 10 I'm -- I'm sorry to refer to you by your first name.

11 when you testified in court, and I think the 10:23:38 11 That is unprofessional. Sorry. Ms. Johnston.

12 expectation would have been that you be honest then 10:23:40 12 BY MR. HARBACH:

13 as well. 10:23:43 Q. Ms. Wang, the question is in your capacity

14 A. I was. 10:23:44 14 as president of Golden Spring (New York) Limited,

15 Q. Okay. So I wasn't there that day. All 10:23:45 15 isn't it true that you serve as an administrator for

16 I have is the transcript. And I'm just being -- I'm 10:23:48 16 the interests of Mr. Kwok-- Mr. Ho Wan Kwok and his

17 being honest with you. That is the reason for my 10:23:52 17 family?

18 question is because I saw that you said that you

MR. ROSEN: I'll repeat the objection.

19 don't have any financial professional knowledge.

You can answer the question.

20 So I suppose the question is if you were

21 just being humble back in 2019, do you mean to say 10:24:05 THE CHECK INTERPRETER: The check

22 that you, in fact, did have financial professional 10:24: 10 22 interpreter heard Mr. Kwok and Mr. Ho Wan Kwok and

23 knowledge when you were appointed to all of those 10:24:14 23 his family.

24 positions at Golden Spring? Is that what you were

MR. HARBACH: That is correct.

25 trying to say?

That was the question.

THE CHECK INTERPRETER: Yes.

2 testimony-- back to 2019, that was my testimony, and 10:24:23 2 But not Wengui Guo; right?

3 that -- I stay with that. That is a -- true and

4 accurate information, sir. And regarding right now

THE INTERPRETER: That is his Mandarin name, 10:27:29 5 what are you looking for after three years, I do not 10:24:34 5 Ho Wan Kwok. The Mandarin is Wengui Guo.

6 understand, and I will do my best to help you.

7 Q. Okay. Same question about the next sentence 10:24:40 7 counsel said Ho Wan Kwok.

8 on the transcript, which says:

MR. HARBACH: Yes.

The reason that counsel said Ho Wan Kwok was 10:27:45

10:24:49 10 because the witness said that is how she knows the

11 Was that true when you said those words in 10:24:50 11 debtor. I asked her earlier whether she knew the

12 2019? 10:24:53 12 name Wengui Guo, and she said she knows him as

13 A. It is correct. I am not real -- realtor. 10:24:55 13 Ho Wan Kwok; so that is why I used that name.

14 I am not a licensed realtor; right? That was

THE INTERPRETER: Yes.

15 correct. 10:25:03 MR. HARBACH: But we can clear this -- we

16 Q. Okay. So it is correct that at least as of 10:25:06 16 can clear this up now, Ms. Wilkinson.

17 May of2019 you did not have American real estate

THE CHECK INTERPRETER: Okay.

10:25: 14 18 BY MR. HARBACH:

19 A. Correct. 10:25:15 Q. Ms. Wang,whatnamewouldyouprefertouse

20 Q. -- correct? 10:25: 16 20 going forward to refer to Mr. Qiang Guo's father?

21 A. I don't have a license at all by then. 10:25: 16 A. Mr. Ho Wan Kwok.

22 Q. Next question.

Q. Very good.

A. That is the debtor; right? That is the

24 president of Golden Spring (New York) Limited you

25 serve as an administrator for the interests of 10:25:42 24 debtor's name.

Am I right.

Q. You are right. That is correct. 10:28:24 2 A. Let's go with it, yeah. Uh-huh. 10:28:25 3 Q. So would you like Ms. Johnston to repeat the 10:28:27 4 question in Chinese for you, ma'am? 10:28:30 5 6 A. Yes, please. Q. Okay. 10:28:32 10:28:34 7 THE INTERPRETER: Mr. Harbach, can you just 10:28:37 8 repeat the question one more time, please. 10:28:39 9 MR. HARBACH: Sure. No problem. 10:28:42 10 THE INTERPRETER: Just so you know, the 10:28:46 11 interpreter does not speak Cantonese; so I will just 10:28:48 12 re- -- I will just say the name the way you pronounce 10:28:53 13 it instead of saying the Mandarin name. 14 MR. HARBACH: Okay. That -- that's fine. 15 And, obviously, I speak neither; so I will rely on 10:28:54 10:28:57 10:28:59 16 you all. 10:29:02 17 BY MR. HARBACH: 18 Q. So here is the question. 19 In your capacity as president of 10:29:03 10:29:03 10:29:05 20 Golden Spring (New York) Limited, isn't it true that 10:29:07 21 you serve as an administrator for the interests of 10:29: 12 22 Mr. Ho Wan Kwok and his family? 10:29: 18 MR. ROSEN: Objection. You may answer. 10:29:23 10:29:25 23 24 25 THE WITNESS: (Through Interpreter) Well, 10:29:59 Page 54 1 first of all, I don't know what you meant by the word 10:30:07 2 administrator. 10:30:10 3 And, second, I worked for Mr. Qiang Guo. 10:30: 11 4 MR. HARBACH: Is that the end of the answer, 10:30:22 5 Ms. Johnston? 10:30:23 6 THE INTERPRETER: Yes, it was. 10:30:25 7 MR. HARBACH: Okay. Thank you. 8 BY MR. HARBACH: 9 10 Q. Let's take a look now at Exhibit 4. (Deposition Exhibit Number 4 10:30:27 10:30:28 10:30:28 10:30:31 11 was marked for identification.) 12 THE WITNESS: (Witness complies.) 13 BY MR. HARBACH: 10:30:35 10:30:35 10:30:57 14 Q. Okay. I have got it, Ms. Wang. I hope you 10:30:57 15 do too. 10:31:00 16 A. (InEnglish) Yes. 10:31:01 17 18 19 20 I am here. Q. Very good. Open up Exhibit 4, please. A. Yes. 10:31:03 10:31:04 10:31:05 10:31:07 21 Q. And the first thing I want to do is go to 10:31:07 22 the very last page. 10:31: 10 23 A. (Witness complies.) 10:31: 12 24 Q. Areyouthere? 10:31:14 25 A. Yes. 10:31:15 Page 55 Q. Is that your signature on the top right of 10:31: 15 2 Exhibit 4? 3 A. Sorry, sir. 4 You mean Exhibit 4; right? 10:31:19 10:31:25 10:31:26 5 6 7 8 Q. Yes, sir -- or excuse me. Yes, ma'am. A. Okay. I opened the wrong one. 10:31 :28 10:31:33 Q. Okay. A. So let me go back. 10:31:35 10:31 :35 9 Exhibit 4, you mean the director and officer 10:31:37 10 register? 11 12 Q. No. No. No. A. Okay. That's -- 10:31:40 10:31:41 10:31:44 13 Q. This is the one that says exhibit, and then 10:31:44 14 it has the number next to it, four. A. Okay. 10:31:47 15 10:31:50 16 Q. So when you open that up, the first page 10:31:51 17 says affidavit of Yan Ping Wang. 10 :31: 54 18 Let me know if you have the right document. 10:31:58 19 20 A. Yes. Q. Good. 10:32:01 10:32:01 21 Now go to the last page of it, please. That 10:32:02 22 is page three. 10:32:05 23 A. (Witness complies.) 10:32:06 24 Yes. 10:32:06 25 Q. My question to you is is that signature on 10:32:07 Page 56 1 the top right-hand corner of page three of Exhibit 4 10:32:12 2 yours? 10:32: 16 3 A. Yes. 10:32:17 4 Q. Okay. Nowlet'sgobacktopageone. 10:32:18 5 A. (Witness complies.) 10:32:21 6 Q. And you can see that this is an affidavit 10:32:21 7 that you signed and that was filed in the 10:32:26 8 Supreme Court of the State of New York on May 16th of 10:32:28 9 2018. 10 Do you see that? A. Yes. 10:32:32 10:32:34 11 10:32:35 12 Q. Okay. Now, I also note that on page 10:32:40 10:32:43 10:32:47 13 three -- sorry to keep jerking you around. 14 Could you please go to page three. A. The last page; right? Q. Yes, ma'am. A. (Witness complies.) Yes. I am here. 10:32:50 10:32:54 10:32:55 10:32:55 10:32:56 15 16 17 18 19 20 Q. You will see above the notary public's 21 signature that it indicates that it was sworn on 10:32:56 10:32:59 22 May 15th of 2018. 10:33:02 23 Do you see that there? 10:33:04 24 A. Yes. 10:33:05 25 Q. Okay. Now go back to page one for me. 10:33:08 Page 57

10:33:11 1 information as best of my capacity and as best of my

Q. Tell me when you are there.

A. Yes. 10:33:17 3 BY MR. HARBACH:

Q. The very first sentence of your dep- --

4 Q. Okay.

5 excuse me. Of this affidavit says: 10:33:23 A. -- is what I can say.

6 Q. Okay.

7 A. I don't know what you are looking for.

serve as an administrator for the interests

8 8 I mean, if you are looking for words in the

9 9 dictionary, I don't know what you are looking for.

10 Q. I'm asking you if you know what an affidavit 10:36:24

And then there follows several akas.

11 is. -- "and his family," period.

A. Affidavit is a legal paperwork.

Do you see that sentence?

A. Yes. 10:33:52 14 affidavit is a piece of legal paperwork where

Q. So I'll ask you to tell me what being an

15 15 a person provides testimony that is sworn under oath? 10:36:38 16 administrator of the interests of Mr. Kwok Ho Wan and 10:34:00 16 A. Yes.

17 his family means, because they are your words.

Q. Okay. And you told me a moment ago you --

A. This is drafted by the attorneys also; so in 10:34:16 18 actually, I want to be fair.

19 my understanding, an administrator, these words --

20 as, again, I am not native speaker at all -- means 10:34:25 20 affidavits you may have done in the past; is that

21 that I work for Golden Spring and take instruction 10:34:30 21 correct?

22 from owner of Golden Spring to work out the

A. I don't recall. Like, why should I recall

23 assignment and task Golden Spring request me to do is 10:34:39 23 how many of them? I mean --

24 what I mean in here.

Q. How many affidavits do you think you have

A. I don't work in a law firm; right?

I signed in your lifetime?

A. I don't recall. 10:34:50 A. So why should I recall?

Q. More than five?

Q. I'm not suggesting whether you should or you 10:37: 16

A. I don't recall. 10:34:55 4 shouldn't. All I'm asking is whether you know how

Q. More than twenty-five? 10:34:57 5 many affidavits you have prepared in your life.

A. I don't recall.

And I understood your answer to be that you

Q. Maybe more than fifty? 10:35:01 7 do not know; is that right?

A. Sir, now you are asking in my life. I don't 10:37:31

A. I don't recall.

Q. Do you know what -- what an affidavit is? 10:35:08 9 recall. That is my answer.

A. What do you mean, do I know what affidavit

II is? 10:35:17 11 asking.

Q. Do you know what an affidavit is? Do you

12 You have told me that you understand an

13 know what the word means? 10:35:20 13 affidavit to be a legal document where a person

A. I don't understand your question. 10:35:23 14 provides testimony that is sworn under oath; is that

MR. HARBACH: Ms. Johnston, can you please

15 15 right?

16 translate.

A. The sentence which you read me through, this 10:37:58

Do you know what an affidavit is? 10:35:34 17 was I signed back to 2018. And then now as

10:35:47 18 April 2020 [sic] of course I couldn't remember that,

19 19 like, four years ago almost.

20 question. All I have done in that I work for

21 GoldenSpring(NewYork)Limited. Iamnotnative 10:36:01 A. But I do know that that is a legal

22 speaker. I am definitely not legal person either; 10:36:01 22 paperwork. I gave all my truthful and honest

23 right? 10:36:01 23 information in that paperwork. This I am testifying

So like, I just to be here, and then what

25 being before there to tell the legal all the truthful 10:36:07 24 right now.

Q. Okay. And so when you signed this affidavit 10:38:26

1 in May of 2018, it was truthful when you signed it; 10:38:29 1 is not my native language, yes. I signed affidavit

2 is that correct? 10:38:39 2 back to 2018. That is a truthful information as best 10:41:50 3 A. When I signed and I gave all my truthful 10:38:41 3 ofmy knowledge. By then, when I signed my name in

4 information. 10:38:47 4 there, yes.

5 Q. Was this --this affidavit that is Exhibit 4 10:38:49 I'm testifying right now to explain and let

6 that we're looking at, was it true when you signed it 10:38:53 6 you know all of those yes and no, that is my truthful 10:42:02 7 and swore to it? 10:38:58 7 testimony by now, yes. This is all my yes and no

8 A. I signed affidavit back to 2018 of this 10:39:03 8 answer, sir.

9 one. That is my best and truthful knowledge and 10:39:07 Q. At the time that you signed Exhibit 4, did

10 information I gave. 10:39: 12 10 you understand it?

11 Q. Is that a "yes"? 10:39:14 A. Understand what?

12 A. I answered your question, sir, already.

Q. Did you understand what you were signing?

13 Q. Well, I'm going to ask it one more time.

A. The affidavit.

14 I think you may have, but I want to ask it one more

Q. Were you able to read it and understand what 10:42:24 15 time just to make sure we are clear. 10:39:28 15 it said?

16 Was this affidavit-- that is, Exhibit 4 --

A. I don't understand your question. What --

17 true at the time that you signed it? 10:39:32 17 you are asking my recollection back to 2018?

18 A. What do you mean, at the time when I signed

19 it? I mean, I signed it as true back in 2018. 10:39:46 A. I don't recall.

Q. You don't recall whether when you signed

21 And-- and here's the --here's the problem. 10:39:51 21 this affidavit you understood what it said?

22 Just a few minutes ago, when I asked you about the

A. It is four years ago, sir. I don't recall

23 first sentence of Exhibit 4, you said something about 10:39:59 23 the details by then.

24 this document being prepared by lawyers and that 10:40:02 Q. Do you make a habit of signing affidavits

25 English isn't your first language and that -- and so 10:40:06 25 under oath when you don't understand what they say --

I that is why I'm asking these questions so that I can 10:40: 12 I with- -- withdrawn.

2 understand whether what is written on the page here

3 is your truthful testimony or not. 10:40: 19 3 object.

10:40:27 4 BY MR. HARBACH:

5 Q. All I can do is ask you -- let me finish my 10:40:29 Q. Do you recall whether this affidavit was

6 question. 10:40:33 6 translated for you?

7 I don't know what is in your brain. All 10:40:33 A. I don't recall. Again, like, it is three or 10:43:07

8 I can do is ask questions. You have told me that you 10:40:36 8 four years ago. I don't recall.

9 signed this document. You have told me that you

10 understand it is an affidavit. You have told me what 10:40:41 10 executed, approximately?

11 you understand an affidavit to be. 10:40:45 MR. ROSEN: Objection.

12 And so now all I'm asking you is whether

We -- we have really got to move on, David.

13 this particular affidavit was true when you signed

14 it. That is a yes, no, I don't know, or I don't

15 remember question. 10:41:06 15 nothing personal, obviously. I would love nothing

16 A. This is several questions, sir. I cannot 10:41: 11 16 more than to move on, but I'm just trying to get the

17 only answer one yes or one no. 10:41: 14 17 witness to adopt what she swore to three years ago.

18 Q. Sure you can. Itisasinglequestion. The 10:41:17 MR.ROSEN: Allright. Howisthatrelevant 10:43:51

19 answer can be either yes, it could beno, it could be 10:41:21 19 to the 30(6)(6) deposition topics today?

20 I don't know, or it could be I don't remember.

10:41 :32 21 within what her job is as president of Golden Spring

22 Q. Do you need me to ask the question one more 10:41 :33 22 (New York). That is 100 percent within the scope of 10:44:02 23 time? 10:41:36 23 what we're talking about here. She has told us about 10:44:05 24 A. The affidavit, which I signed back to 2018, I 0:41 :36 24 all the titles that she has, and I'm exploring what

1 her job is what we have read several times, and now 10:44: 16 1 (New York), you served as an administrator for the

2 she doesn't want to answer that. She doesn't want to 10:44:20 2 interests of Mr. Kwok Ho Wan and his family?

3 own that; so I'm going to stop arguing, but it is

A. Yes.

4 plainly relevant. Plainly relevant. 10:44:27 As the language read in my affidavit, yes.

5 You can instruct her not to answer. You can 10:44:30 Q. Do you recall what you meant by an

6 instruct her not to answer any question that mentions 10:44:33 6 administrator for the interests of Mr. Kwok Ho Wan

7 Ho Wan Kwok if you want. But I'm going to stay right 10:44:36 7 and his family?

8 here until I understand what was in this witness'

A. The language in this affidavit was drafted

9 head when she signed this affidavit. 10:44:42 9 by attorney, and, in my understanding,

10 MR. ROSEN: Well, I think you have -- you 10:44:44 10 Golden Spring -- as per Mr. Qiang Guo's instruction,

11 have pretty much established on the record that what 10:44:46 11 Golden Spring, like, pay Mr. Ho Wan Kwok, like, his

12 you are going for has nothing to do with this DIP 10:44:50 12 lifestyle and then et cetera; so that was my

13 loan. 10:44:52 13 understanding.

14 So I am going to instruct the witness not to 10:44:52 Q. That was your understanding of your role?

15 answer this question. 10:44:55 15 Because that was what my question was about.

16 MR. HARBACH: Okay. I think we should take 10:44:56 A. My role as president of Golden Spring or

17 a little break because, among other things, I need to 10:44:59 17 administrator?

18 go to the restroom.

Q. Well, you have stated that as president, you 11:03:36 19 So can we please, Mr. Videographer, take ten 10:45:03 19 served as an administrator of Mr. Kwok

20 minutes. 10:45:06 20 Ho Wan's interests.

21 THE VIDEOGRAPHER: We are going off the 10:45:06 21 And so I'm asking about whether what you

22 record. 10:45:08 22 just described was your role in May of 2018.

23 The time is 10:45.

A. I am the president of Golden Spring. I took 11 :04:0 I

10:45:10 24 instruction from Mr. Qiang Guo and served as an

Page 66 25 administrator -- administrator for his father.

I record.

Q. And was that true from the moment you began

2 The time is 11 :00 o'clock. 11:00:23 2 working at Golden Spring?

3 BY MR. HARBACH:

A. Oh, sir, the moment -- again, you are asking 11:04:21 4 Q. Ms. Wang, before the break I was asking you 11 :00:35 4 the time; right?

5 about Exhibit 4, which is an affidavit that you

Q. Well, I'm asking whether what you just

6 signed in May of 2018. 11:00:43 6 described as your duties as an administrator, was

7 MR. HARBACH: Scott, I confess, I do not 11:00:48 7 that true from the beginning, from when you first

8 recall whether where we left off was with your 11:00:51 8 started working at Golden Spring (New York)?

9 instructing the witness not to answer my question--

A. When I started working for Golden Spring

10 any more questions about this. And let me -- and let 11:01:00 10 (New York), I did take instruction from Mr. Qiang Guo 11:04:52 11 me just -- let me say before you answer that if you 11:01:04 11 to -- to serve, as I said, as administrator for his

12 let me answer one or two -- ask one or two more, I'll 11:01:07 12 father.

13 move on. 11:01:13 Q. And so that would have been in the spring of 11 :05 :00

14 MR. ROSEN: I appreciate that, and yeah. 11:01:14 14 2018, when you started working for Golden Spring

15 Please -- I'll instruct the witness at this time to 11 :01:18 15 (New York); is that right?

16 answer the question.

A. Correct, sir.

17 MR. HARBACH: Okay. Thank you.

Q. And how frequently did you communicate with

18 BY MR. HARBACH: 11:01:25 18 Mr. Qiang Guo during that time, say the spring of

19 Q. So Ms. Wang, do you still have Exhibit 4 in 11:01:25 19 2018?

20 front of you? 11:01:30 A. I don't recall, but I do believe we -- we

21 A. Exhibit4? Yes, sir. Yes. 11:01:32 21 talk as needed.

22 Q. Okay. So again, reminding you that this

Q. Okay. Once a day?

23 affidavit was signed in May 2018.

A. I don't recall.

24 My question for you is is it true that in

Q. Okay. Do you recall whether you talked to

25 May of 2018, as president of Golden Spring

Page 67 25 him once a week?

1 A. I don't recall. As I said, we just talk as 11:05 :43 1 Golden Spring (New York) in New York City in 2018,

2 needed. If, you know, we need to talk, we just talk. 11 :05 :47 2 did you reside in the same location as

3 Q. Okay. 11:05:51 3 Mr. Ho Wan Kwok?

4 A. I don't, like, calculate, yeah. 11:05:52 4 A. I lived in New York.

5 Q. No. I understand. 11:05:54 5 Q. Did you reside -- again, I'm not talking

6 And I don't mean to be asking for a precise 11 :05:56 6 aboutnow.

7 calculation. I'm just trying to get a sense of how 11 :05:58 7 I'm talking about in 2018, when you started

8 often you talked to him. 11:06:02 8 working at Golden Spring (New York), did you reside

11:06:03 9 in the same dwelling as Mr. Ho Wan Kwok?

10 Mr. Qiang Guo, did you speak by phone? in person? 11:06:06 10 A. Sir, what do you mean by dwelling? Do you

11 a mix?

12 A. Both. 11:06:15 12 Q. A house.

13 Q. Okay. Hang on one second, please. Sorry

14 for the holdup. 11:06:58 14 Q. Is it a house? an apartment? It doesn't

11:07:01 15 matter.

16 Mr. Ho Wan Kwok in the spring of2018 to fulfill your 11:07:07 16 Did you live in the same home as

17 role, as you have described it? 11:07:13 17 Mr. Ho Wan Kwok?

18 A. I don't recall. 11:07:17 18 A. No.

19 Q. Did you ever communicate with him? 11:07: 18 19 Q. Have you ever been to the -- withdrawn.

20 A. Yes. 11:07:23 20 Have you ever lived in the eighteenth floor

21 We did communicate. 11:07:26 21 apartment of the Sherry-Netherland?

22 Q. And was that in person? 11:07:27 22 A. I visited there, sir.

23 A. Yes. 11 :07:31 23 Q. Fair enough.

24 In person.

25 Q. Okay. And how frequently? 11 :07:33 25 there.

I A. I don't recall. 11:07:37 A. What do you mean, reside? As in, like,

2 Q. Okay. More than one a week? 11:07:40 2 my -- my home? No.

3 A. Sir, you are asking back to 2018, when 11:07:45 3 Q. Okay. Have you ever stayed there for--

4 I start work for Golden Spring? 11:07:51 4 MR. HARBACH: And, Scott, this is my last

5 lam. Q. Yes. Yes, ma'am. 11:07:54 5 one.

6 A. Oh, I don't recall. 11:07:57 6 BY MR. HARBACH:

7 Q. Okay. Let's see. 11:07:58 7 Q. Haveyoueverstayedthereformorethan

8 Oh, thank you. MR. HARBACH: 11:08:26 8 a couple of weeks?

9 BY MR. HARBACH: 11:08:26 9 A. I don't recall.

10 Q. My colleague reminds me, I meant to ask this 11:08:28 10 Q. Okay. Can we turn now to -- back to

11 question. 11:08:32 11 Exhibit I.

12 When you started working at Golden Spring

13 (New York) in New York City, where did you reside? 11:08:37 13 Q. Tell me when you have got it up, Ms. Wang.

14 I don't mean the --the exact address, but where did 11:08:41 14 A. Yes, I am.

15 you reside? 11 :08:45 15 Q. Okay. The cover page, just to help you

16 MR. ROSEN: Objection. There are security 11:08:47 16 orient yourself, is dated October 11th, 2018, which

17 reasons that Ms. Wang does not want to give 11:08:51 17 was the date of this deposition.

18 a residence address. 11:08:54 18 Okay?

19 Are you talking about a city or -- something 11:08:57 19 A. Yes.

20 as general as a city or are you talking address? 11:09:00 20 Q. All right. And so that is approximately --

21 MR. HARBACH: I'll -- I'll try and ask the 11:09:05 21 I don't know -- six months after you started working

22 question in a way that avoids those concerns, Scott. 11 :09:07 22 at Golden Spring (New York)?

23 MR. ROSEN: Thank you.

25 24 BY MR. HARBACH:

11:09:12 24 Q. You said you started working in the spring

25 of2018; so approximately six months.

1 Is that fair? 11:12:19 1 was accurate.

2 A. Yes. 11: 12:20 2 Q. Okay.

3 Q. Okay. So let's go to page sixty. 11:12:21 3 A. The testimony right now, after I was

4 corrected, is accurate also, sir. 5 Q. And, again, looking at the little pages. 11: 12:33 5 Q. I see.

6 Tell me when you are there. 11: 12:45 6 And so the -- the correction concerned his

7 A. Yes. 11: 12:50 7 name; right?

8 Q. Okay. The very top of page sixty there is 11: 12:50 8 A. Yes.

9 a -- the tail end of a question and then a question 11: 12:54 9 Mr. Qiang Guo's name.

10 that begins on line two: 11: 12:57 10 Q. Okay.

II "QUESTION: Do you know Mileson Kwok?" 11 :13:00 11 A. That is reason why I am insisting calling

12 Your answer is: 11:13:04 12 him Mr. Qiang Guo; right?

11:13:05 13 So that is the accurate -- you know, his

14 The question: 11:13:06 14 official name.

15 "QUESTION: Is that Mr. Kwok's son? 11: 13:06 15 Q. Understood.

16 "ANSWER: Yes. 11:13:09 16 A. That works better for me, yeah.

11:13:11 17 MR.HARBACH: Andwithapologiestothe

18 person? 11:13:12 18 reporter for interrupting. I'll try to do better.

19 "ANSWER: Yes. 11:13:13 19 BY MR. HARBACH:

11:13:14 20 Q. Next question on the deposition transcript

21 Golden Spring? 11:13:17 2] IS:

22 "ANSWER: I don't know. 11:13: 19 22 "QUESTION: Is that Mr. Kwok's son?

24 him in regard to any Golden Spring business? 11: 13:24 24 So there is no question whether it is

Page 74 25 Mileson Kwok or Qiang Guo.

2 Did I read that correctly?

A. Yes. 11:13:38 We are talking about Mr. Kwok Ho Wan's son;

2 correct?

3 Q. Can you explain-- well, first of all, is 11:13:39 3 A. Correct.

4 that true? 11: 13:46 4 Q. And Mr. Ho Wan Kwok has one, and only one,

11:13:52 5 son; correct?

6 Q. Let's go through them-- let's go through 11:13:53 6 A. Correct.

7 them one by one so we can be crystal clear. First 11: 13:57 7 Q. Okay. Next question:

8 question: 11: 14:01 8 "QUESTION: Have you ever met him" --

9 "QUESTION: Do you know Mileson Kwong?" 11: 14:0 I 9 Meaning who we're calling Qiang Guo.

10 Was that true in October 11th, 2018, you

II knew Mileson Kwok? Was that true?

Your answer was: 12 A. I was given a wrong impression back in 2018. 11:14:13 12 "ANSWER: Yes."

13 Like, I was thinking, like, Mileson go with Kwok 11:14:17 13 WasthattruethatyouhadmetQiangGuoin 11:16:01

11:14:22 14 person as of October 11th, 2018?

11:14:22 15 A. Yes.

11:14:24 16 Q. Okay. Next question:

11: 14:24 17 "QUESTION: Does he, Qiang Guo, have any 11:16:17

19 Q. -- interrupt. 11: 14:24 19 Your answer was you don't know.

11: 14:25 20 Now, this is six months after you said you

21 Q. Yeah. 11:14:25 21 started at Golden Spring. Months after what you

22 A. -- I was corrected by Mr. Qiang Guo. 11:14:27 22 claim earlier were conversations with Mr. Qiang Guo

23 He purposely corrected me after -- I forget when. He 11: 14:30 23 about your role and duties.

24 corrected me and said that he always go with

25 Mileson Kwok; so the testimony by then back in 2018 11: 14:37 24 So why, six months after you started at

25 Golden Spring, did you say that you didn't know

1 whether he had any role? 11:16:46 1 frequently-- and that it was -- I believe you said

11: 16:50 2 a mix of by phone and in person.

Q. Isn'tthat--isn'tthatalsotruethatyou 11:16:52

Do you -- does that not count as interaction 11: 19:59 4 didnotknow? 11:16:55 4 in your mind?

A. So sir, you finish your question; so can

A. Interact with him in Golden Spring business. 11:20:03 6 I start to answer or you still have more, sir? I'll 11: 17:06 6 I mean, him and myself, we're friend also along the

7 wait until you finish. 11: 17:09 7 way for so many years; so when you ask me five

Q. You -- thank you for waiting. 11: 17: 11 8 minutes ago, I mean, we do, like, meet and talk as

You can answer if you answer my question.

11: 17: 12 9 needed. But the question back to 2018, it is asking

11: 17: 15 10 about interacted with him in regard to any

11 October 11th, 2018, you did not know whether 11: 17: 19 11 Golden Spring business, which my testify was true.

12 Qiang Guo had any role at Golden Spring? That is the 11: 17:27 12 He was in charge of all the Golden Spring business

13 question. 11:17:30 13 back to then. And I know I'm part of Golden Spring,

A. Back to 2018, I don't know by then in my 11:17:33 14 but, really, like, he -- he was the person running

15 understanding the role means employee or employees; 11:17:38 15 the business.

16 so by then I did not know whether he was employee or

Q. Ms. Wang, isn't it true that, in fact, you

17 not. But I do know he is the boss. He is the owner. 11: 17:47 17 were not interacting with Qiang Guo, certainly not in 11 :20:46 18 I do not know whether he is employee or not because 11: 17:51 18 2018,aboutGoldenSpringbusiness? Isn'tthattrue? 11:20:51 19 he was majorly handling the Golden Spring majority of 11: 17:54 19 A. Can you reframe your question again, sir?

20 work by then. I only work and cooperate with him as

Q. Isn't it true that in 2018 you, in fact,

21 neededbackin2018. 11:18:05 21 were not interacting with Mr. Qiang Guo at all

Q. In 2018 you didn't say he was the boss? Six 11: 18:07 22 related to anything Golden Spring was doing? Isn't

23 months after you claimed to have started working with 11: 18: 13 23 that the truth?

24 him you didn't say he was the boss, did you? 11:18:16 A. I don't recall. It is too long time ago,

A. I was not asked whether he was the boss or 11: 18: 19 25 and this deposition was conducted -- I don't believe

I not. 11:18:24 I Ihadaninterpreterbythen.

Q. You were asked whether he had any role? 11:18:24 Q. Isn't it also true that the boss of

A. Any role, in my understanding back to 2018, 11: 18:27 3 Golden Spring (New York), when you started working

4 as employee. 11: 18:32 4 there, wasn't Qiang Guo; it was Mr. Ho Wan Kwok?

Q. Okay. How about the next question: 11:18:33 5 Isn't that true?

A. Golden Spring (New York)'s boss is always

7 7 Mr. Qiang Guo.

Q. Isn't it true that you have been a long-term 11:21:44

That was the question you were asked, and 11: 18 :46 9 employee of Mr. Ho Wan Kwok?

10 the answer you gave was:

A. I have been working for Mr. Qiang Guo,

11 11 himself, and his family.

13 true-- is it true that as of October 11th, 2018, you 11:18:55 13 Mr. Qiang Guo. I'll ask the question again.

14 had not interacted with Qiang Guo in regard to any

15 Golden Spring business? Is that true or not? 11: 19:08 15 employee of Mr. Ho Wan Kwok?

A. It is a correct answer because back in 2018, 11: 19: 13 16 A. I don't believe so. Mr. Ho Wan Kwok, he

17 Mr. Qiang Guo, he was the major person running 11: 19: 19 17 never pay me or ever pays me or pay me at all.

18 Golden Spring; so I didn't understand -- again,

19 English not my native language -- what is interacted

A. So I always work for Mr. Qiang Guo and his

20 with. My understanding, by then he was running the 11:19:33 20 business.

21 company. I just work for him as he needed. That is 11: 19:35 Q. DoesMr.HoWanKwokevertellyouwhatto

22 my understanding; so -- which is correct. 11: 19:38 22 do?

23 A. What do you mean, ever tell me what to -- if 11:22:38

And you told me five minutes ago that you 11:19:41 24 they ask me for help, of course I will offer my help

25 had contact with him -- you didn't remember how

Page 79 25 to him.

Q. Does -- does Mr. Ho Wan Kwok ever give you 11 :22:46 Q. Okay. And so there is a long answer on page 11 :24:57

2 direction? 2 forty-eight that goes from line twelve to line

3 A He ask for support and help, which I'm 11 :22:49 3 twenty-three. And I'm not going to read the whole

4 always willmg to do that for him. 4 thing, but I want to direct your attention to the

5 Q. Does he ask -- ever ask you to go get 11:22:57 5 second half of that answer. It says:

6 coffee? 11:23:00 "They are arrested and pnt in jail by

7 A I don't recall. 11:23:01 Chinese Communist party. And a lot of his

8 What do you mean? 11:23:03 family member, including his son, his

9 Q. You don't --you don't recall whether 11 :23:05 daughter, niece, nephew, and his

10 Mr. Ho Wan Kwok has ever asked you to get coffee? 11:23:07 sister-in-law, brothers, they were all

II A Sir, I mean, I don't recall. Just, like, 11 :23: 11 threatened, kidnapped, and put in jail

12 why I should recall someone ask me to get coffee: 11 :23:15 without any reason until now, including all

13 right? 11 :23:18 of his, like, long-term employee, just like

14 Q. Well, I don't -- I don't know. Maybe he has 11 :23:19 me."

15 asked you to get coffee hundreds of times Maybe he 11.23.21 So you are talking about Mr. Ho Wan Kwok

16 never has. All I can do is ask the question. 11:23:25 16 here; correct?

A. Can I read the entire from sentence twelve

11 :23:28 18 until twenty-three?

19 Q. -- if Mr. Ho Wan Kwok has ever asked you to

Q. Absolutely. Take your time, read it to

20 go get coffee? 11:23:32 20 yourself, and let me know when you are finished.

21 A I don't recall.

A. Thank you.

22 Q. Okay. What about to translate something for 11 :23:34 22 Okay. I finished it, sir.

23 him, meaning 11r. Ho Wan Kwok? Have you ever done

Q. Thank you.

24 that for him?

25 A Yes, I did.

Page 82 25 talking about in this answer, who you refer to as he

I Q. How frequently? 11:23:42 I and his, is Mr. Ho Wan Kwok; correct?

2 A I don't recall. 11:23:44 A. And reading from the language, of course,

3 Q. More than once? 11:23:48 3 this is by -- by the transcript court recorder.

4 A Yes. 11:23:50 4 Like, it -- reading from the language, it looks like

5 More than once. 11:23:51 5 yes. But I am referring to -- as I am starting from

6 Q. Okay. When was the last time you translated 11 :23:52 6 the Guo family, is not just his immediate family, the 11 :27:47 7 something for Mr. Ho Wan Kwok? 11:23:55 7 entire Guo family.

8 A I don't recall.

Q. Yes.

11 :24:01 And you said on line two:

10 MR. HARBACH: What is 331? I can't see. Is 11:24:08 "Mr. Kwok, Miles Kwok, he is number

11:24:11 seventh son of the whole family."

12 BY MR. HARBACH:

13 Q. Okay. Let's go to Exhibit 2, please. 11 :24: 13 13 Kwok Ho Wan; correct?

A. Correct.

15 Q. And l'll ask you -- do you have Exhibit 2,

Q. Okay. And then you describe all of his

16 Ms. Wang? 11:24:26 16 relatives and the terrible things that happens to

17 A Yes. 11:24:27 17 them. And then you say that the people to whom that

11:24:27 18 happened include all of his, meaning

19 forty-eight. 11 :24:32 19 Mr. Kwok Ho Wan -- all of his long-term employee,

11:24:34 20 just like me; so this is the basis for my question

21 Q. Tell me when you are there. 11:24:46 21 five minutes ago.

22 A I'm working on it, sir. Forty-eight.

23 Q. Yes, ma'am. 11:24:53 23 employee of Mr. Ho Wan Kwok? Is that true or not?

25 A Yes.

I am here.

25 family. I mean, I didn't remember clearly what was

1 recorded in here. Like, obviously, I was never in 11 :29: 12 So it is not Exhibit 2? You want me to go

2 jail. I am under threatened, but I was not kidnapped 11:29: 17 2 back to Exhibit I, sir; right?

3 and in jail. I think it is still blamed to my broken 11:29:21 3 Q. Yes, ma'am.

4 English back there. When I say long-term employee,

5 my real -- my meaning as the Guo family. I am 11:29:30 5 I'm here.

6 a long-term employee of Guo family. 11:29:32 6 Q. Okay. Thank you.

7 Q. Who? 11:29:36 7 Now, could you please scroll forward on the

8 A. Mr. Ho Wan Kwok, he never hired me by 11 :29:37 8 small pages to page forty-six.

9 himself.

10 Q. Well, who -- who -- first, since you brought 11:29:43 10 Yes.

11 it up, who was the person who hired you to work for 11 :29:45 11 Q. Okay. Very good.

12 the Guo family? 11 :29:49 12 Now, on this subject of what administrator

13 A. It was a company. It was a company called 11:29:51 13 means, if you'll look down at line twenty of page

14 Pangu, P-a-n-g-u. Beijing Pangu. 11 :29: 53 14 forty-six, you'll see a question:

15 Q. Yeah. 11:29:58 15 "QUESTION: I'maskingyouwhetheror

16 And who was the boss of Beijing Pangu when 11:29:59 16 not you serve as an administrator for

17 you were hired to work for the Guo family?

18 A. You mean boss, like the owner? 11:30:07 18 That is Ho Wan Kwok-- for his interests.

19 Q. Well, you know, you can ascribe whatever 11 :30: 11 19 And your answer was:

20 meaning you want to boss, Ms. Wang, but you seem to

21 understand that Qiang Guo is the boss of 11:30: 17 21 And then you were asked:

22 Golden Spring; so you tell me. 11:30:19 22 "QUESTION: What does that mean?"

23 A. Oh, understand. 11:30:21 23 And you said:

24 So Beijing Pangu was owned by the Guo 11 :30:22 24 "ANSWER: Translator," comma,

25 families.

11:30:29 I Do you see that there?

2 MR. HARBACH: And -- and, Scott, I won't 11:30:32 2 A. Yes.

3 stay here long, but she brought it up. 11:30:35 3 Q. Now, you have already told us that you --

4 BY MR. HARBACH: 11:30:37 4 you have, in fact, done some translation for

5 Q. Ms. Wang, who was it who told you at the 11:30:38 5 Mr. Kwok-- Mr. Ho Wan Kwok; right?

6 very beginning -- when you first started working for 11:30:41 6 A. I translate for him -- translated for him,

7 the Guo family, who was it who told you you were 11 :30:44 7 yes.

8 Q. Yes. 8 hired? Which person?

9 A. I was advised by the HR department, which 11:30:49 And if--you also said-- it also says that 11:33:53 10 I couldn't recall. That was back in 20- -- 2008. 11:30:57 10 you were his assistant.

11 I couldn't recall. But I was informed by the HR 11 :31 :02 11 Is that true?

12 department! was hired. 11:31:06 12 A. I mean that I -- I testified as an

13 Q. I'm going to apologize for rewinding just 11 :31:07 13 administrator for Mr. Ho Wan Kwok and I help him as

14 for a moment back to an earlier topic. I'll try and 11:31:19 14 per Mr. Qiang Guo's instruction, including, like,

15 make this clear and efficient. 11:31:24 15 help him to translate, make him understand, include,

16 In Exhibit 4, which is your affidavit, you 11: 31:32 16 like, assist as he needs -- right? -- to support him. 11 :34:22 17 recall that -- that I asked you several questions 11:31:46 17 It does not mean I have -- I have a title called

11:31:49 18 assistant; so if that is what you are looking for.

19 Mr. Ho Wan Kwok's interests meant? You with me?

20 A. Yes. 11 :31:58 20 A. My meaning was I help him to understand as

21 Q. Okay. So the reason I'm coming back to this 11:31:58 21 to language and support him as he needed as his son's 11:34:36 22 is because I neglected to point something else out to 11 :32:02 22 instruction.

23 you. And it is Exhibit I; so could you turn to 11:32:07 23 Q. Okay. And so what does that mean, other

25 24 Exhibit I, please.

11:32:17 24 than the translation work, when you say that assisted 11 :34:43 25 means support him as needed? What sorts of things

1 didyoudoforhimbackin2018?

A. I don't understand, sir. I mean, capacity,

11:34:57 2 I am available. I am here. I offer my support as

3 clarify, when you use the word you, are you referring 11 :34:59 3 Mr. Qiang Guo requested me to do. That is my

4 to Golden Spring, or are you referring to the witness 11:35:01 4 understanding about capacity. If that is the

5 personally? 11:35:04 5 capacity you are talking, that is the same, yes.

6 MR. HARBACH: That's fair, Scott.

Q. Well,Ihearyou.

7 I believe when -- when she was deposed in

All I'm trying to confirm is that that was

8 2018, she was testifying in both her capacity as 11:35:11 8 what you were supposed to do, according to you, as

9 a representative of Golden Spring and in her personal 11 :35: 16 9 president of Golden Spring (New York) Limited was

10 capacity; so she is going to have to clarify that for 11 :35:20 10 translate for Mr. Kwok Ho Wan and cater to his

11 me. 11:35:24 11 personal needs; is that right? Is that what you are

12 MR. ROSEN: You can answer. 11:35:26 12 saying?

13 THE WITNESS: I don't recall.

MR. ROSEN: Objection.

14 BY MR. HARBACH:

You -- you can answer.

IS Q. Okay. And in any case, your role as an 11 :35:31 THE WITNESS: Let me repeat again.

16 administrator for Mr. Ho Wan Kwok's interests, that, 11 :35:35 My capacity as president of Golden Spring

17 according to you, was in your capacity as president 11:35:42 17 (New York) is to work as per the owner of company

18 of Golden Spring (New York) Limited; correct? 11:35:46 18 requesting needs to me, including assist his father,

19 A. I was requested by Mr. Qiang Guo to help 11:35:52 19 translate for his father, and that including here I'm 11:38:58 20 backin2018;thatiscorrect. 11:35:57 20 being deposed today; right?

21 Q. Okay. Well, I want to make sure you 11:36:01 And sign the affidavit. Including a lot of 11 :39:05

22 understand my question because since Mr. Rosen 11 :36:04 22 things, I mean, if! may say, not only as you just

23 helpfully raised capacity, I want to make sure we get 11 :36:07 23 tried to describe me as assistant or translator, if

24 this correct. 11:36:11 24 that is helpful to you, sir.

25 Okay?

I So bearing in mind that we are talking about 11 :36: 13 I BY MR. HARBACH:

2 what being an administrator for Mr. Ho Wan K wok's

Q. Well, translator and assistant, again,

3 interests means -- that is what we're talking 11 :36:23 3 Ms. Wang, those were your words, not mine. I just

4 about -- I'm going to direct you back to Exhibit 1 -- 11 :36:26 4 read them to you from a transcript. And so all I'm

5 correction. Exhibit 4 -- sorry. 11 :36:31 5 doing is trying to explore what your job as president 11:39:28 6 A. So Exhibit 4, sir; right? Which one are we

7 talking about? Four? 11:36:41 6 of Golden Spring (New York) Limited was. And you 7 have -- you have explained part of that to us,

8 Q. Yes, ma'am.

The number four. 11:36:46 8 I think. And I'm just trying to understand what

9 assistant means.

10 A. I'mhere.

Besides being a translator, can you tell me

11 Q. And this affidavit, which you have already

12 told us you signed and swore to as being true and 11:36:53 11 any more about that?

A. About what, sir?

13 correct, states that you're serving as an 11:36:57 Q. About what you meant when you said you were

14 administrator for the interests of Mr. Ho Wan Kwok 11:37:02 14 Kwok Ho Wan's assistant.

15 and his family was in your capacity as president of 11 :37:07 A. That is what I -- that is -- that was not,

16 Golden Spring (New York) Limited: isn't that correct? 11:37:14 16 I mean, in my language. I mean, still I don't --

17 A. I was hired by Golden Spring (New York), and 11 :37:23 17 I don't have this as my native language when I named

18 I take instruction from the owner of Golden Spring 11 :37:28 18 that, which means I offered that support and service. 11 :40:23 19 (New York). And I was available to support his 11 :37:32 19 I don't have a title called translator or assistant.

20 family, including his father. That is what the

21 capacity, to me, means in here.

22 Q. And -- and what you just described,

A. -- I don't have it, yeah; so I offered that

23 according to you, was in your capacity as president 11:37:45 23 support.

24 of Golden Spring (New York) Limited; isn't that

25 right?

Q. Okay.

1 helpful. 11:40:37 1 the lifestyle -- I mean, take care of his father.

Q. Got it.

Q. When did he give you that instruction?

A. Oh, I don't recall. I should -- from long

4 right now when you said support. 4 time ago. I mean, son take care of the father.

Besides translation, what else? 5 5 I mean, that is kind of natural to me, so

A. For example, I am being deposed right now in 11 :40:44 6 Q. Well, I'm not going to quarrel with -- with

7 this bankruptcy. 11:40:51 7 whether it is natural or not.

Q. Okay.

My only question is you just said that --

A. This is as per Mr. Qiang Guo's instruction;

9 that Mr. Qiang Guo gave you the instruction that you

10 right? 11:40:57 10 just recited.

11 And my question is when? You said a long

Q. Is your testimony -- I don't think this is 11 :40:58 12 time ago? How long ago?

13 what you are saying, but I'll ask it anyway because 11 :41 :00 A. I don't recall.

14 it is a fair inference from your words. 11:41:03

Q. More than a month ago?

15 A. It should be longerthanmorethanamonth.

Q. Okay. Had he given you that instruction by

17 the time of your deposition in October of2018?

You can answer that. 11 :41:14 A. I don't recall.

THE WITNESS: I am testimony -- I am testify 11:41: 15 19 Q. Had he given you that instruction by the

20 today for a bankruptcy like a-- I believe the topic 20 time of your trial testimony in May of2019?

21 is about DIP loan; right? 11:41:24 A. I don't recall.

Q. Isn't it possible?

Q. And I would love to get there, but we --

A. I don't recall.

24 we're -- well, let me just ask one more time. 11:41:29

Q. Well, did he give you that instruction

25 sometime in 2020?

I saying that assistant was not your title. 11:41:36

A. I really don't recall.

2 I understand that. I understand that your title was 11 :41 :39 Q. How long has Golden Spring (New York) been

3 all those titles I recited several times now at 11:41:42 3 paying for Mr. Kwok's lifestyle, as you just said?

4 Golden Spring (New York) Limited. And I also 11 :41 :46

A. How long? I believe since I was appointed.

5 understand that according to you, in your capacity as 11:41:50 5 I mean, I don't recall clearly. I don't recall. But 11 :45: 13 6 president, you served as an administrator of the 11:41:54 6 a long time.

7 interests of Mr. Ho Wan Kwok and the family. 11:41:58

Q. Okay. Well, you said two things there. You 11:45:19

You were asked at a deposition about what 11:42:04 8 said you believe since you were appointed and you

9 serving as an administrator meant, and you said 11:42:07 9 have said you don't recall; so I have -- I'm going to 11 :45:25 10 translator and assistant. Now, we all know what 11:42: 12 10 have to ask you to tell me which it is.

11 a translator is, and that is clear. It is clear that 11:42:18 A. I don't recall. And I shouldn't speculate

12 you performed that service for Mr. Kwok. 11:42:21 12 or guess because when I was appointed, as

All I'm trying to understand, Ms. Wang, is 13 13 I testified, like, a couple of minutes ago, which was 11 :45 :42

14 what else you did for him, and so far the only thing 11 :42:27 14 true, Mr. Qiang Guo was operating and running his

15 you have said is testify at this deposition. 11:42:31 15 business; so that is the reason I correct my answer

Is there anything else? 11:42:33 16 to be I don't recall because I was not paying that by 11:45:53

A. Yes. 11 :42:37 17 myself. I don't recall the answers.

MR. ROSEN: Objection.

Q. Understood.

20 secretary, treasurer, and director of Golden Spring,

21 what role did you have in making sure that

Q. Okay. What else?

22 22 Mr. Kwok's -- Mr. Ho Wan Kwok's lifestyle needs were

A. For example, Mr. Qiang Guo, obviously, he 11:42:47 23 paid for?

24 instructed Golden Spring to pay his father's, like, 25 food, clothes, and, like, including this -- they call 11 :43:01 11 :42:54

A. Sorry, sir.

Can you please repeat your question?

1 Q. Who do you receive those from?

2 A. Which bill you were talking about, sir? As president, secretary, treasurer, and 11 :50:33

3 director of Golden Spring (New York) Limited, what 11:46:42 Q. Any of the above.

4 role did you have in ensuring that Mr. Ho Wan Kwok's 11:46:47 A. I mean, some of them, they go through from

5 lifestyle needs were paid for? 5 the card. Some of them we received it from the --

A. What role I ensured with? I mean, sorry.

6 6 the vendor.

That's -- that's the question you were Q. Okay. How many of those bills do you

8 asking for; right? 8 receive from Mr. Ho Wan Kwok directly?

Q. Yes, ma'am. A. Directly? I don't recall.

And I'll try one more time in English, and Q. How do you know whether -- any of the

11 then we might need to use Ms. Johnston. 11 expenses that you review to take care of

A. Yes, please.

11:47: 15 12 Mr. Ho Wan Kwok's lifestyle, how do you know or

I feel the same.

13 13 verify, as you said, whether any of them are actually 11:51:19

Q. It's okay. I'll try it one more time. 11:47:17 14 his?

You have stated that Mr. Qiang Guo gave you 15 11:47:21 A. I mean, Mr. Qiang Guo, he requested

16 instruction to take care of his father, I mean, more 16 Golden Spring to take care of both his parents; so

17 orless. You don't remember exactly when he gave you 11:47:35 17 I mean, only, like, is -- is clarified, like this is

18 that instruction, but it was a long time ago. 18 his father's clothes and then we obviously will

Have I got that right so far?

Q. Okay. And I'm asking now, in your role as 21 11 :47:47 A. -- grocery bill, I think it is more, like,

22 president, and all those other titles, of 22 mixed for the mom and that.

23 Golden Spring (New York) Limited, what did you do to 11 :48:03 23 Q. Okay. And, number one, how do you know that 11:51:57 24 ensure that Mr. Ho Wan Kwok and his lifestyle needs 24 it is Mr. Ho Wan Kwok's clothing that is being

25 were taken care of? Do you understand the question? 25 purchased? How do you verify that?

11:48:27 A. I verifying with the vendor directly.

Q. Okay. So what is the answer? Q. And -- huh.

A. For example, like, I communicate with So you -- you ask a vendor whether the

4 Mr. Qiang Guo about the fund, including this depo. 4 clothing was purchased by Mr. Ho Wan Kwok?

5 He take care of the request and then make sure the 11:48:52 A. Yeah. Because the man's clothes, the

6 funds in there to take care of his father. 6 women's clothes are pretty obvious; right?

Q. We're going to -- we're going to talk about But I do need to verify, yes.

8 the fund in just a moment. But you mentioned 11:49:10 Q. Yeah. I get the difference between men's

9 lifestyle needs earlier, things like clothing, food, 9 and women's clothes.

10 transportation -- basics.

11 11 charge that is obviously for men's clothing you

12 Limited, were you involved in paying for or providing 11:49:31 12 assume is Mr. Ho Wan Kwok, and any charge that is for 11:52:53 13 those things for Mr. Ho Wan Kwok? 13 women's clothing you assume is for his wife?

A. Yes. A. I don't assume. I mean, I have to verify

Q. Please tell me what you did.

15 15 because I need to report back the funds; right? --

A. Like, I will review the bills and verify -- 11: 49: 5 2 16 the financials to the owner of the company clearly--

17 if there is any need to verify -- and process the

Q. Absolutely.

18 payment in clothing.

A. -- so I verify.

19 Q. Absolutely.

A. Like, clothes. Like, food -- grocery food. A. So I verify.

Q. And -- and are these credit card bills or Q. Let's -- do you -- do you review any credit

22 are they receipts directly from the vendor or what?

22 card bills as part of that process?

A. I believe they are both. A. Sometimes.

Q. Okay. Q. Okay. And when you re- -- when you review

A. It is a mixed.

Page 99 25 a credit card bill, let's just pretend there is

1 a charge on there for -- yeah, I don't know -- a stay 11:53 :39 1 MR. HARBACH: Sure. Sure.

2 in a hotel. Let's just take that as an example. 11:53:45 I'm sorry to be cute.

3 How do you verify who made the charge? 11:53:48 3 BY MR. HARBACH:

4 A. Like, a hotel, you mean; right? For an 11:53:54 Q. Ms. Wang, can you give us a more precise

5 example. 11:54:02 5 date range during which Mr. Ho Wan Kwok's wife had

6 Q. I'm taking that as an example. 11:54:02 6 access to the Golden Spring (New York) debit card?

7 A. If hotel, we obviously, Golden Spring, will 11 :54:05 A. I don't recall, sir.

8 call the hotel to verify.

Q. Do you recall the last time that she --

9 Q. To verify that the charge was made? 11:54:10 9 meaning Mr. Ho Wan Kwok's wife -- used the

10 A. Yes. 11:54:14 10 Golden Spring (New York) debit card?

II That is part of internal, I mean, audit. 11:54:14 A. I don't recall.

12 It -- it is normal. 11:54:18 Q. Did you, as president and treasurer of

13 Q. Okay. Sohowaboutfiguringoutwhoused 11:54:19 13 Golden Spring (New York) Limited, authorize

14 the credit card? How would you do that? 11:54:23 14 Mr. Ho Wan Kwok's wife to use the Golden Spring

15 A. You -- I don't follow your question, sir. 11:54:26 15 (New York) debit card?

11:54:34 A. Authorized? I believe yes. And

17 Mr. Ho Wan Kwok, how he used credit card; right? 11 :54:36 17 Mr. Qiang Guo requested Golden Spring to do that.

18 Q. Sure.

Q. But you don't recall when that was?

19 That -- that is -- that is a possibility,

A. Correct.

20 but I don't know. I'm asking you.

Q. Okay. And I believe you testified a moment

21 A. No. 11:54:45 21 ago that to your knowledge Mr. Ho Wan Kwok has never

22 He doesn't use Golden Spring's credit cards. 11:54:45 22 used the Golden Spring (New York) debit card; is that 11: 57:38 23 Q. Does Golden Spring have credit cards? 11 :54:48 23 correct?

24 A. We have debit card. 11:54:51 A. HeneverhasGoldenSpring(NewYork)debit

25 Q. Okay. Does Golden Spring have any credit 11:54:53 25 card at all.

1 cards? 11 :54:58 Q. Has he ever used the debit card number to

2 A. As of now, no. 11:55:00 2 purchase anything, to your knowledge?

3 Q. Okay. Does Mr. Kwok have access to the 11 :55:03 A. I don't know.

4 Golden Spring debit card? 11:55:12 Q. Has he ever asked you -- "he" meaning

5 A. No. 11 :55: 15 5 Mr. Ho Wan Kwok.

6 Q. What about his wife? Does he [sic] have 11:55:15 Has he ever asked you to purchase anything

7 access to the Golden Spring debit card? 11:55:18 7 for him in your capacity as president of

8 A. I don't recall. 11:55:21 8 Golden Spring?

9 Q. You are the treasurer of Golden Spring 11:55:25 A. I believe so.

10 (New York) Limited; right? 11:55:33 Q. Okay. Can you give us an example of

II A. Yes. 11:55:36 11 anything he has asked you to purchase for him?

12 Q. You -- you really don't know whether 11:55:38 A. I mean, I don't recall the details, but it

13 Ho Wan Kwok's wife has access to the company debit 11:55:43 13 happened.

14 card?

Q. You don't remember a single thing that

15 A. She had one before, but I'm not sure whether 11:55:49 15 Mr. Ho Wan Kwok has asked you to purchase for him?

16 that one is still activated.

A. I don't recall.

17 Q. When did she have one?

Q. How many times has it happened that he has

18 A. Long time ago. 11:55:58 18 asked you to purchase something for him?

19 Q. Can you do better than that?

A. I don't recall.

20 A. What do you mean, can I do better than that, 11: 56 :0 5 Q. More than once?

21 sir?

A. Correct.

22 Q. You know what I mean.

Q. More than a hundred times?

23 MR. ROSEN: Objection.

A. I don't recall.

24 Can you please ask the witness directly what 11:56:15 24 Q. On the occasions when Mr. Ho Wan Kwok has

25 your question is?

Page 103 25 asked you to purchase something for him, what do you

I do? 11 :59:18 Have I got that right?

A. As per Mr. Qiang Guo's instruction, I help 11 :59:20 A. Yeah. That is the instruction was given to

3 him, yes I go to buy for him.

5 has -- have you ever refused a request from

A. -- we just go buy.

6 J\Ar. Ho Wan Kwok that you purchase something for him? 11 :59:41 6 Q. Is that true, no matter how expensive the

A. Yes. 11 :59:45 7 item is?

Q. When was that?

A. I don't recall. But I obviously need to

10 report it to Mr. Qiang Guo, and ifhe reject it,

12:00:01 11 transportation as an example.

Q. Okay. Is your -- so I want to make sure Are you aware that -- that Mr. Kwok

13 I understand the process. 12:00:06 13 frequently travels in a Maybach limousine?

A. Am I aware? What do you mean am I aware?

15 Mr. Ho Wan Kwok asks you to buy something for him 12.00.10 Q. Do you know -- do you know what a limousine

16 thatyouconsulthissontogetpermission' Isthat 12:00:14 16 is?

17 correct or not?

A. Limo, yes. I do know.

A. Not every time. Like, as you said, for

Q. Okay. And do you know what a Maybach is?

19 example, buy coffee; right?

A. Yes.

12:00:28 Q. Okay. Is it a type of car; right?

21 Mr. Qiang Guo.

A. Correct.

Q. Okay. How do you decide when to consult 12:00:32 Q. Isn't it true that Mr. Ho Wan Kwok

23 with JI.Ar. Kwok Ho Wan's son about a purchase that 12:00:35 23 frequently travels by Maybach?

24 Mr. Kwok Ho Wan wants you to make? 12:00:43 A. Sir-- sir, I know Mileson want his father

A. I don't recall. But that happened.

Page 106 25 to be safe and secured; so that is the thing I know.

Q. Do you have any -- any thoughts about that?

I I But I don't know, like, frequency. I use that

A Like, a legal fee?

2 2 Obviously, I am not following his father every day.

Q. No.

I'm -- I'm just asking you in general. I'm

4 Q. Does -- does Golden Spring-- I'll ask you

5 not asking you about legal fees yet, although 12:01 :00 5 to accept for purposes of this deposition today --

6 hopefully we will get there. 12:01:05 6 just take my word for it that within the last month

7 7 Mr. Kwok has traveled at least once by Maybach.

8 Mr. Ho Wan Kwok says, hey, Yvette, I would like you

Okay?

9 to buy me X, how do you know whether just to buy X or 12:01: 14 9 Let's just assume that.

10 whether to get his son's permission? How do you

12:01:30 11 transportation that Golden Spring (New York) has paid 12:04:17 II decide? A Well, yearly, like, his food and his coffee

12 12 for?

13 and then his transportation, those lifestyle were 12:01:34 A. Golden Spring (New York) pays -- pays the --

14 already approved by Mr. Qiang Guo; so you already -- 12:01:40 14 the gasolines and-- yeah. The gasolines. That

15 Golden Spring just to go ahead to buy or purchase and 12:01:44 [5 IS --

16 then report back to Mr. Qiang Guo; so anything

17 except -- besides -- except which words? Except

A. -- what transportation we are paying.

18 that, we obviously, Golden Spring, need to escalate 12:01:57 Q. Does Golden Spring (New York) own any

19 to Mr. Qiang Guo to get approval. 12:02:02 19 Maybach vehicles?

Q. Understood. 12:02:04 A. Oh, I -- I couldn't remember, like, if

21 21 Maybach owned by Golden Spring or not. I mean,

22 things like food, clothing, transportation -- those 12:02:08 22 Golden Spring owns a couple of cars. They all

23 things do not require specific approval of 12:02: 15 23 ultimately owned by Mr. Qiang Guo.

24 Mr. Qiang Guo and, in your mind, you can just buy

25 them for Mr. Kwok without getting his permission.

Tell me about the cars that Golden Spring

1 owns. You just mentioned that there are a couple. 12:04:59 1 BY MR. HARBACH:

2 \Vhat are they?

Q. Sure.

3 A I'm not car person; so I have to find out. 12:05:07 A. I do need a lunch break, yeah.

12:05:11 Q. If--ifyouwouldliketotakeabreaknow, 12:07:56

5 A I cannot tell. 12:05:14 5 that is no problem at all.

6 Q. And you don't know whether one of the cars 12:05:16 MR HARBACH: I don't know if Suzanne or

7 that Golden Spring (New Yark) owns is a Maybach; is 12:05:20 7 Jeff who takes us off, but I will suggest reconvening 12:08:03 8 thatright? 12:05:24 8 at -- at 1 :00 o'clock.

9 A. I don't know because this is Mr. M1leson,

Is that amenable to folks?

10 like Mr. Qiang Guo, he purchased directly 12:05:31 MR ROSEN: Yes.

11 Q. Yeah. 12:05:34 MR HARBACH: Okay.

THE VIDEOGRAPHER:

13 Q. I -- I -- I understand. 12:05:36 13 record.

The time is 12:08.

15 (New York).

16 Okay?

THE VIDEOGRAPHER:

17 I'm asking about Golden Spring (New York) 12.05.41 17 record.

18 Limited, of which you are the president, treasurer,

The time is 1:01.

19 secretary, and director. I'm asking if you know 12:05:48 19 BY MR. HARBACH:

20 whether Golden Spring (New Yark) Limited owns

Q. Good afternoon, Ms. Wang -- Ms. Wang.

21 a Maybach automobile.

One little loose end that has nothing to do

22 Do you know? 12:05:57 22 with what I was asking you about before lunch.

23 A. I don't recall. I have to find out.

Okay? Do you know someone called Yu Yong?

12:06:02 24 That is Y-u Y-o-n-g.

25 Golden Spnng (New Yark) pays for Mr. Ho Wan Kwok's

A. Yes.

1 transportation; right?

Q. Okay. Who is that person?

2 A Correct. 12:06:15 A. I met her in New York before.

3 Q. And that would include transportation by 12:06:16 Q. Okay. Do you know what she does for

4 car; correct? 12:06:20 4 aliving?

5 A Correct.

6 Q. That would include arranging for a leased 12:06:24 6 together with the family also.

7 vehicle if that is how he wanted to travel; correct? 12:06:32 Q. The -- the Guo family?

8 A We pay the gasoline.

A. Yes.

9 Q. Yeah. I heard that I'm just trying to 12:06:42 Q. With whom specifically?

10 figure out who owns the vehicle, Ms. Wang.

A. With Mr. Qiang Guo.

11 Do you know whether Golden Spring (New York) 12:06:49 Q. Anyone else?

12 Limited has rented or leased a Maybach in order to

A. I believe with -- with Mr. Qiang Guo's

13 transport Mr. Ho Wan Kwok? Do you know?

14 A I don't know.

15 MR HARBACH: So Mr. -- Mr. Rosen, I'll take 12:07:10 A. -- but I don't have the details.

16 the witness up on her offer to get back to us on the

Q. Okay. And approximately when was that that

17 types of cars that Golden Spring (New York) owns, 12:07: 19 17 you met her?

18 and, in particular, whether they own any Maybach

A. 2015.

19 automobiles, if that is okay with you.

Q. Okay. Thank you.

20 MR ROSEN: We'll take it under advisement.

A new subject.

21 MR. HARBACH: Okay.

Who set up Golden Spring (New York) Limited? 13:03:07 22 MR ROSEN: Your request is -- is noted.

23 MR. HARBACH: All right Thank you. 12:07:38 23 Mr. Qiang Guo.

24 THE WITNESS: Sir, can we have a break?

25 I mean, it is 12:00. 12:07:51 Q. Who -- when you say it is your

25 understanding, do you know that or did somebody tell

1 you that?

MR. ROSEN: Objection. What is the -- what

A. This is I learned afterwards. I believe 13:03:27 2 is the relevance of this, David?

3 there will be --there will be law firms supporting 13:03:31 MR. HARBACH: I'm trying to explore the

4 by him, but he set up the company. 13:03:34 4 witness' most recent answer about the business

Q. Why did he set up the company? 13:03:37 5 purpose of Golden Spring. She said that he -- that

A. I got to know later on -- not, like, when he 13:03:39 6 he, Qiang Guo, created it to do X, Y, and Z. And I'm 13:06: 59 7 set up the company -- he was trying to do business 13:03:46 7 trying to inquire about how long he was actually in

8 outside of China, like, mainly in the U.S. here. 13:03:50 8 the country after Golden Spring was created. That is 13:07:09 Q. What sort of business?

13:03:54 9 why I'm asking.

A. Like, business related to real estate,

10 MR. ROSEN: Just note for the record that we 13:07:13

11 investment -- like a diversified business. 13:04:02 11 are all here in different locations at this

Q. Okay. Who funded Golden Spring (New York) 13 :04:06 12 deposition. And in today's world where your -- where 13:07: 18

13 when it was created? 13:04:11 13 your seat is doesn't necessarily mean a whole lot.

A. I learned afterwards Mr. Qiang Guo, he

15 arranged the fund -- fund the Golden Spring. 13:04:22 15 witness to answer.

Q. When you say he arranged it, do you mean 13:04:26 16 BY MR. HARBACH:

17 that he, himself, provided the money? 13:04:29 Q. The --the question was when-- or how long

A. Hmmm. No.

18 18 has Mr. Qiang Guo lived in the UK.

He arranged via his -- another company.

20 I believe it is called Bravo Luck.

Q. Are you finished with your answer?

Q. I see.

You said for years, maybe?

And so your understanding is that the money

A. My -- my answer was not four, f-o-u-r, as

23 that funded Golden Spring (New York) Limited when it 13:04:48 23 years. This is my answer.

24 was created came from Bravo Luck?

Q. All right.

A. That is what I learned.

A. I don't know how many, yeah.

Q. From whom?

Q. You don't know how many years?

A. From Mr. Qiang Guo.

2 A. Correct.

Q. Have you ever spoken to Mr. Ho Wan Kwok 13:05:05 Q. Could it be more than ten years?

4 about Bravo Luck? 13:05: 10 A. I don't think so.

A. Hmmm. I don't recall. 13:05: 13 Q. How long, if -- if you know, how long after

Q. Have you ever spoken to Mr. Ho Wan Kwok 13:05: 16 6 Golden Spring (New York) Limited was created did

7 about the source of money that was used to fund 13:05:20 7 Mr. Guo -- Qiang Guo move to the UK?

8 Golden Spring (New York) Limited when it was created? 13:05:24 8 A. I cannot recall.

A. No.

Q. All right. Do you know -- what can you tell 13:08:40

I don't recall I did that. 13:05:30 10 us about what Golden Spring (New York) Limited has

Q. Do you know how Bravo Luck got the money 13:05:34 11 done to advance the business purposes you just

12 that you say funded Golden Spring (New York) Limited? 13:05:41 12 described? 13:08:55 A. I don't know.

A. Mr. Qiang Guo was in the United States in

13:05:47 14 2015, and then he travels a lot also. And,

15 (New York)'s business purpose when it was created? 13:05:54 15 obviously, he set up the company, and then we develop 13:09:12 A. Oh, Golden Spring was created as a family

16 16 business structure and plan from there; so that is

17 office owned by Mr. Qiang Guo; so Mr. Qiang Guo was 13:06:04 17 still his direction, which we have been doing until

18 planning, as I said, to develop and expand the 13:06:09 18 his father started to do his whistle-blower moment.

19 business in the United States, including, like, as 13:06:14 Q. What was the business plan in the beginning? 13:09:33

20 I said, investment, real estate, and the business

A. Investment.

21 he -- he was doing by then.

Q. Okay. In, I believe, you mentioned real

Q. Where does Mr. Qiang Guo live today? What 13:06:28 22 estate.

23 country?

What else?

A. He lives in UK.

Q. How long has he lived there?

A. We started from real estate. There was real 13:09:49 25 estate, like, investment.

13:09:54 I'd object on the -- on the grounds that I'm 13:13:18

2 besides investing money? 13:09:57 2 not sure that your use of the word client is -- is

3 A. And operate as a family office in New York 13: 10:00 3 being understood.

4 here to support other family projects. 13:10:09 Could you clarify that, please?

5 Q. Okay. You have mentioned earlier the 13:10:15 MR. HARBACH: Sure.

6 support of Mr. Ho Wan Kwok. 13:10:19 6 BY MR. HARBACH:

7 What other family projects has Golden Spring 13: 10:23 Q. Ms. Wang, do you know what I mean by the

8 (New York) Limited supported? 13:10:27 8 word client?

9 A. Including their project -- real estate. 13:10:29 A. Client means that you offer services to get

10 Like, including, like, interviews and handouts. The 13:10:39 10 paid.

11 architecture, designer, like, real estate-related 13:10:45 Q. Okay. A moment ago you said that the client 13: 13 :44

12 vendors, and then we, like, facilitate and coordinate 13:10:50 12 of Golden Spring (New York) Limited was the family.

13 by them. 13:10:54 Did you mean that in the sense that you just 13: 13: 5 5

13:10:55 14 described, or did you mean that in a different way?

15 afor-profitenterprise? 13:10:59 A. I mean the client is the Guo family.

16 A. It is. 13: 11 :03 16 I mean, they -- they are, as I testified before,

17 Q. And what is its source of income? 13:11:03 17 like, a hundred family member. They all could be our 13: 14:12

13:11:08 18 clients. They are all business people.

19 a for-profit company, but we are not turning to,

Q. Okay.

20 like, make revenue yet; so the source of income is 13:11:23 A. So as a client of Golden Spring, which

21 supposed to be, like, a -- we build up the project 13:11:26 21 I mean.

22 under the family plan, and then we start to make 13:11:31 Q. Okay. Doyoumeanthatmembersofthe

23 profit from those projects -- investment projects. 13: 11 :36 23 family pay Golden Spring?

24 Q. Okay. So the -- the company invests money 13: 11 :40 A. I mean if Golden Spring offered a service

25 and hopes to make money from investments. 13: 11 :43 25 and then helped them to invest successfully, yes.

1 Is that it? 13: 11:47 1 Golden Spring would be paid.

2 A. That's part of the source of income, yes. 13:11:48 Q. Okay. So now my question is is

3 Planned. 13:11:52 3 Mr.HoWanKwokpartofthefamilythatisaclient

4 Q. Does the -- does the company, Golden Spring 13:11:52 4 of Golden Spring (New York) Limited?

5 (New York) Limited, have any clients? Or is it just 13:11:57 MR. ROSEN: Objection to form.

6 the family? 13:12:01 It -- the -- is your question is he

7 A. I mean, family office typically, to our 13: 12:02 7 individually a client? Because what you asked is is

8 understanding, is support and serve for the family 13: 12:08 8 he part of the family that is a client.

9 business; so our clients are the family. 13: 12: 13 MR. HARBACH: Well, I'm sorry for-- for--

10 Q. Okay. And that includes Mr. Ho Wan Kwok, 13:12:15 10 I'm really not meaning to be confusing.

11 does it not? 13:12:20 11 BY MR. HARBACH:

12 A. He is the person -- the owner of the company 13: 12:21 12 Q. I understood, Ms. Wang, you to say a moment

13 requesting Golden Spring to support; so Golden Spring 13: 12:28 13 ago that the family -- which is composed of numerous

14 does not, like, plan or, like, having profit from his 13:12:31 14 people, you said.

15 father, which, like, we didn'tthinkaboutthatand 13:12:39 Thatthe family is a client of Golden Spring 13:15:22

16 how; right? 13:12:43 16 (New York) Limited; is that correct?

A. The family and their family member who are

18 Golden Spring (New York) limited's clients was the 13: 12:47 18 the business people; correct?

19 family. And I ask you if that included 13:12:58 They are the Golden Spring's clients. Of

20 Mr. Ho Wan Kwok. 13: 13:00 20 course, I don't mean that like in the minor kids;

21 The reason I asked that question is because 13: 13:01 21 right?

22 Mr. Ho Wan Kwok is a member of the family, is he not? 13:13:04 22 So I made that very clear.

23 A. So this is my answer. Golden Spring -- 13:13:09 Q. Is Mr. Ho Wan Kwok a member of that family?

24 MR. ROSEN: Hold off answering, please, just 13:13:15 25 for a second. 13: 13: 18 A. He is one of the family member, yes.

Q. To your knowledge, has Mr. Ho Wan Kwok ever 13:15:53

1 contributed or paid any money to Golden Spnng I'm asking you whether there was anything

2 (New York) Limited? 2 else.

3 A. As far as I know, like, that is all I know.

To my knowledge. Q. Okay.

Q. To your knowledge, has any business A. That is the plan. I mean, as a family

6 organization that 1Ar. Ho Wan Kwok owns or controls 6 office -- right? -- we are supposed to do investment

7 ever contributed any money to Golden Spring 7 and make revenue -- make revenue. I mean, I am not

8 (New Yark) Limited? 8 a law firm. I am not other, you know, service

l\1R. ROSEN: Objection.

9 9 company. And then any other source of income

You can answer the question.

10 10 I should be expect.

TI-IE WITNESS: To my knowledge, no. Q. Does Golden Spring (New York) Limited have

12 BY l\1R. HARBACH 12 any bank accounts?

Q. And you -- as the treasurer of Golden Spring 13: 16:49

A. You are asking which time apparent, sir?

14 (New York) Limited, would that be something you would 13:16:53 14 Q. I'm asking currently.

15 expect to know ifit had happened?

A. Yes.

A. Since I was -- Q. How many?

l\1R. ROSEN. Object. A. One.

You can answer. Q. At which bank?

TI-IE WITNESS: Since I was appointed of 19 19 MR. ROSEN: Objection. There are security

20 treasurer of Golden Spring, I didn't see any money 20 issues involved here, and we're -- I understand that

21 come from Mr. Ho Wan Kwok And Golden Spring doesn't 13:17:13 21 Golden Spring's bank accounts have been shut down as

22 look at him as a client; so he is a family member, 13: 17: 17 22 part of what has been described to me as a harassment 13:20:09 23 butheisnotourkindoflikeprospectiveclient. 23 scheme; so I would ask at this point not to

24 He is the owner. He is the father of the owner, 24 disclose --the witness not to disclose the location

25 like, it -- that's our understandmg. 25 of the bank account

I BY MR. HARBACH:

13:17:33 MR. HARBACH: Okay. Scott, I'm not meaning

2 to disregard your instruction. I'm going to ask

3 Ms. Wang?

MR. ROSEN: Objection. 3 another question, and if you want to include this 13: 17:37 4 under your objection, please do. But I'm going to

THE WITNESS: He is not the owner at all.

13: 17:38 5 ask this one.

6 BY MR. HARBACH: 6 BY MR. HARBACH:

Q. Ms. Wang, is Golden Spring (New York)'s bank 13:20:35 13:17:53 8 account with a U.S. bank?

8 officer of Golden Spring at the time that it was A. Yes.

13:18:00 Q. What is the approximate current balance in

Q. Yes. 11 that account?

A No.

A. I mean, for the safety, same reason. I am

Q. Returning to my question about Golden Spring 13: 18:06 13 very hesitant to tell you because PAX already, like,

14 (New York) Limited's source of income, is there 14 harassed all Golden Spring's bank account.

15 anything else in that category, other than returns on 13: 18:22 15 So we are talking about DIP loan; right?

16 investment?

Q. Well, yeah.

A What do you mean? Like any other source of 13: 18:28

You know the reasons that the -- that the

18 income besides what I reply to you before? 13:18:38 18 deposition has been noticed, and I'm not going to get 13:21:21 Q. Yes.

19 19 into a debate with you about whether the question is

A Okay. So that would be our major source of 13:18:42 20 proper.

21 income. Like, a family office -- I mean, in my 13: 18:45 My question is what is the approximate

22 understanding you already do investment; so when you 22 balance in Golden Spring's one bank account in the

23 investment, you get revenue, and then we got paid, 23 United States?

Q. I understand that. 13:18:57 25 like, ifit is acceptable to counsel, to take a short 13:21:44

1 recess to discuss this with my client. 13:21:50 1 finance department, they are doing that.

2 MR. HARBACH: Of course. No problem at all. 13:21:52 2 Q. Well, you are the treasurer; right?

3 THE VIDEOGRAPHER: We are going off the

4 record. 13:21:56 4 questions setting aside the bank account. The

5 The time is 1 :21. 13:21 :56 5 question was what is -- what are the values of the

13:22:00 6 liquid assets, setting aside the bank account.

MR. HARBACH: Yeah. I meant -- and I can't 13:36:50 8 record. 13:34:01 8 believe I said -- if! didn't, I'm mistaken. I meant 13 :36: 53 9 The time is 1:34. 13:34:01 9 the identity ofthe bank. I'm not -- I'm not

10 MR. HARBACH: Scott, did you want to put 13:34:06 10 interested in getting the identification of the bank. 13:36:59 11 anything on the record here or no? 13:34: 11 11 I'm just trying to figure out how much money

12 MR. ROSEN: No. 13:34: 14 12 Golden Spring (New York) Limited has. That's it.

13 I did not need to put anything on the 13:34: 15 13 BY MR. HARBACH:

14 record.

Q. How much money does the company have? Do

15 BY MR. HARBACH: 13:34:18 15 you know?

16 Q. Okay. Ms. Wang, did you speak with anyone 13:34: 19 A. The money enough to support all of the daily 13:37: 14

17 else during the break, besides your lawyer? 13:34:21 17 operation.

18 A I only talked with Mr. Scott Rosen.

Q. Are you -- are you unwilling to tell me how

19 Q. Okay. Thank you. 13 :34:25 19 much money Golden Spring has or do you not know how

20 The pending question before the break was 13:34:26 20 much money Golden Spring has?

21 what is the approximate balance in Golden Spring 13:34:31 MR.ROSEN: Yeah. 1--Ihavetoobject

22 (New York) Limited's one U.S. bank account? 13:34:37 22 here. There are concerns about the integrity and

23 MR. ROSEN: I'm going to object and instruct 13:34:45 23 usability of Golden Spring's assets in light of

24 the witness not to answer that specific question 13:34:47 24 creditor activity that has been conducted by PAX; so

25 because of Golden Spring's concerns about maintaining 13:34:50 25 these are --these are sensitive issues. If-- if

I the integrity and usability of the bank account in 13:34:54 I you want to get to questions about where is the loan

2 light of credits' rights actions that have been taken 13:34:58 2 proceeds going to come from, then we can -- we can

3 by -- by PAX. 13:35:03 3 certainly go there. But with respect to its current

4 BY MR. HARBACH: 13:35:05 4 assets, at this point the credit just -- just

5 Q. Leaving aside the identity of the bank, 13:35:06 5 outweighs any -- any -- any relevancy.

6 approximately how much value in liquid assets does 13:35:11 MR.HARBACH: 1--Ithinklunderstandyour 13:38:10

7 Golden Spring (New York) Limited own? 13:35:20 7 objection, and rather than engage it fully, I will

8 A Golden Spring as -- I mean, enough funds to 13:35:23 8 just note that we strongly disagree. But if you are

9 support Golden Spring, the operation. I mean, we 13 :35 :33 9 instructing the witness not to answer, I'll try and

13:35:37 10 move on.

11 Q. All right. And your judgment about what 13:35:40 MR. ROSEN: Thank you.

12 might be a cash flow issue and our judgment about 13:35:44 12 BY MR. HARBACH:

13 what might be a cash flow issue and Judge Manning's 13:35:48 Q. Approximately how much profit did

14 judgment about what might be a cash flow issue could 13:35:54 14 Golden Spring (New York) make in the last year?

15 be three very different things. 13:35:57 A. Because of the -- the entire, like, PAX --

16 And so that is why I'm asking approximately 13:35:59 16 right?-- this case, I mean, PAX obviously subpoenaed 13:38:49 17 how much money in liquid assets does Golden Spring 13 :36:03 17 all Golden Spring's bank. And then in my

18 (New York) Limited own? 13:36:09 18 understanding, my console device, like, PAX didn't

19 A The balance is changing every day because 13:36: 12 19 get anything; so -- because PAX specifically hurt our 13:39:01 20 things happen every day; so I don't want to 13:36: 19 20 bank relationship in the last year, as you said,

21 speculate. Obviously, I did not check the bank 13:36:22 21 I mean, we didn't make profit last year.

22 balance right now; so I cannot say.

Q. You did not make a profit last year?

23 Q. What -- what -- when -- when was the last

A. Correct.

24 time you checked the balance?

MR. ROSEN: Objection.

25 A I don't recall. It is the financial --

1 BY MR. HARBACH: 13:39:17 1 Q. Okay. Do you know what DIP stands for?

2 Q. Was there a -- was there a loss of -- of-- 13:39:18 2 A. Yes.

3 there was a loss of approximately how much last year? 13:39:20 3 Q. What does it stand for?

4 Do you understand the question? 13:39:33 4 A. It is a DIP loan displaying between --

5 A. Of course. 13:39:34 5 I mean, I'm not a lawyer; right?

13:39:37 6 It is a loan between the lender and the

7 A. But I don't know why it is related to this 13:39:38 7 debtor.

8 as well. It is sensitive information, which I have 13:39:42 8 Q. Thirty seconds ago you said to me that you

9 to keep it. 13:39:44 9 know what DIP stands for. It is okay if you don't.

10 Q. You are -- so you are -- you are -- you are 13:39:45 10 I'm just asking for an honest answer.

11 unwilling to answer what the size of Golden Spring 13:39:46 11 Do you know what DIP stands for? It is an

12 (New York) Limited's loss was last year; is that 13:39:51 12 acronym.

13 right? 13:39:57 13 A. It is a loan. It is a loan. That's my

14 MR. ROSEN: Objection. This is not an asset 13:39:57 14 answer.

15 disclosure deposition for Golden Spring. And -- and 13:40:01 15 Q. Okay. It stands for debtor in possession.

16 in light of the pending litigation that is already 13:40:03 16 Okay?

17 out there, questions like this are overstepping what 13:40:05 17 It is not a secret, but -- I'll keep going.

18 the scope of this deposition is supposed to be, 13:40:09 18 Who made the request to Golden Spring

19 which, again, this is a contested matter in 13:40:11 19 (New York) for debtor-in-possession financing that is 13:43:32 20 a bankruptcy case for a DIP loan, which is being 13:40: 15 20 at issue here?

21 granted on a fully subordinated basis; so that's -- 13 :40: 19 21 A. The owner of Golden Spring (New York).

Q. The owner of Golden Spring (New York) made 22 that is what we are here today on, not asset

23 disclosure. 13:40:27 23 a request to Golden Spring (New York) for DIP

24 MR. HARBACH: Is that an instruction not to 13:40:34 24 financing? Is that your testimony?

25 answer, Scott?

Page 130 25 A. I don't understand your question.

MR. ROSEN: Yes, it is. 13:40:37 I Q. Whoaskedfortheloan?

2 BY MR. HARBACH: 13:40:39 2 A. I was not involved in this loan negotiation. 13:44:10 3 Q. Who made the requests to Golden Spring 13:40:39 3 Q. Do you know who made the request for the

4 (New York) for debtor-in-possession financing? 13:40:42 4 loan?

5 A. I -- can I ask a translator to help me 13:40:47 5 A. I was not involved in the negotiation of

6 understand this question? 13:40:53 6 this loan. I just got instruction and advice from

7 Q. Of course. 13:40:55 7 the owner of Golden Spring.

8 MR. HARBACH: Ms. Johnston, I'll repeat it. 13:40:56 8 Q. Okay. Is the answer to this question -- is

13:41:00 9 the answer to my question you don't know?

10 (New York) Limited for debtor-in-possession 13:41:02 10 A. I was not involved.

11 financing? 13:41:09 11 Q. You know what? Let's use the interpreter.

12 THE INTERPRETER: (Interprets question.) 13:41:42 12 MR. HARBACH: Ms. Johnston, can you -- well, 13:44:48 13 THE CHECK INTERPRETER: Can the check 13 :41 :42 13 let's do it this way.

14 interpreter help with that term? 13:41:45 14 BY MR. HARBACH:

15 THE INTERPRETER: Sure. 13:41:48 15 Q. Do you know who made the request to

13:41:55 16 Golden Spring (New York) Limited for the loan that is 13:44:59 17 understanding, it is debtor's loan; right? Debtor's 13:41:57 17 the subject of today's deposition?

18 position. Debtor's loan. 13:42:01 18 A. I don't have personal knowledge.

19 BY MR. HARBACH: 13:42:01 19 Q. Has anyone told you who made the loan-- who 13:45:11 20 Q. Well, Ms. -- Ms. Wang, on several occasions 13:42:01 20 made the request for the loan that is the subject of 13:45: 19 21 today you have pointed out to me that we are here to 13: 42 :03 21 today's deposition?

22 talk about a DIP loan. 13:42:09 22 A. Has anyone told me?

23 Do you know what a DIP loan is? 13:42:10 23 Q. Well, you said you didn't have personal

24 A. Yes. 13:42:15 24 knowledge.

25 It is a loan between the debtor and lender. 13:42: 16 25 A. Yes.

Q. And I know what that -- and I know what that 13:45:35 1

2 means. 13:45:39 2 funding for Mr. Qiang Guo's father, I mean, for

So I am asking you whether you have ever 13:45:39 3 several years. Mr. Qiang Guo made the decision,

4 learned from anyone else who made the request for the 13 :45 :42 4 given the short time apparent. As the president of

5 loan that is the subject of today's deposition. 13:45:45 5 the company, I am aligned with that, and he knew and

A. I heard this from Mr. Qiang Guo about his 6 13:45:53 6 he knows I am going to align with that.

7 DIP loan. 13:45:58 Q. I see.

Q. Who did he say requested the DIP loan?

A. He mentioned his father -- his father's

10 attorney. 13:46:16 A. No need to argue that, yeah, if that is what 13:49: 17

Q. Do you recall that attorney's name? 11 13:46:17 11 you are looking for.

A. I don't recall. He didn't tell me, and 12 13:46:20 Q. I'm -- I'm -- I'm -- you know, I'm not

13 I don't recall. 13:46:23 13 trying to argue with you. I'm just trying to

Q. When was that request made, if you know? 14 13:46:24 14 understand what happened.

A. In March. 15 13:46:33 And so how about this?

Q. Of what year?

You understand that litigation funding in

A. Of this year. 17 13:46:43 17 the past that Golden Spring may have provided to

Q. Were you -- as president, secretary, 13:46:45 18 Mr. Ho Wan Kwok is different from the DIP loan that

19 treasurer, and director of Golden Spring (New York) 13:46:53 19 we are talking about today? You understand that

20 Limited -- involved in the decision about whether to 13 :46: 58 20 those are two different things; right?

21 provide DIP financing to the debtor? 13:47:03 A. Correct.

A. I was advised by Mr. Qiang Guo afterwards. 22 13:47:06 Q. Okay. And so I would like to focus just on

23 That was a quite short time period. And he handled; 13:47:16 23 the DIP loan and not litigation financing that may

24 so the answer to you is I was not involved. 13:47:24 24 have occurred in the past.

Q. Were you consulted by Mr. Guo -- 13:47:27

Do you understand?

I Mr. Qiang Guo on the decision about whether 13:47:32 A. Yes.

2 Golden Spring (New York) would agree to provide DIP 13:47:36 Q. Okay. And so do I have it right that

3 financing to the debtor here? 13:47:40 3 according to you, the decision about whether to agree 13:50: 13

A. What do you mean, consulted? 13:47:42 4 to the DIP loan for the debtor was Mr. Qiang Guo's

Q. Do you know what consulted means? 13:47:45 5 decision? Correct?

A. Of course I know. 6 13:47:48 A. He made a decision, obviously on behalf of

Q. Okay. So were you consulted by 13:47:49 7 Golden Spring, and he is the owner of the company.

8 Mr. Qiang Guo about the decision on whether 13:47:53 8 And we're aligned.

9 Golden Spring (New York) would agree to provide DIP 13:47:59 9 Q. Okay. And you are the president, and all

10 financing to the debtor? 13:48:03 10 those other titles, of Golden Spring (New York)

A. You mean he -- when he was making the 13:48:05 11 Limited; correct?

12 decision? 13:48:08 A. Correct.

Q. Well, we're going to get to who made the 13 13:48:09 Q. Have you ever disagreed with Mr. Qiang Guo

14 decision. I'm trying to figure out whether you were 13:48:14 14 about a decision that he has made?

15 involved and, ifso, how. You told me a couple of 13:48:18 A. Yes, of course.

16 minutes ago that you were not involved with the 13:48:23 16 Q. Okay. And did he solicit your agreement for 13:51:06 17 decision. 13:48:25 17 this decision?

A. For this DIP loan decision, you mean?

Q. Uh-huh.

A. No.

He spoke to me about the decision.

Why?

Q. Before he made it or after? 13:48:36 22

A. Why?

Q. And am I right that the decision was his,

Q. He told you -- he told you about it after he 13:51:22 25 had made a decision; correct?

Case 22-50073 Doc 398-1 Filed 04/27/22 Entered 05/19/22 11:20:43 Page 37 of 95

1 A. He briefed me what happened.

Do you talk to him twenty times a day?

2 Q. What did he tell you?

A. Obviously not.

3 A. About this DIP loan, and then he didn't have 13:51 :31 Q. Well, it is not obvious because you won't

4 enough time within the short limit of time. He took 13:51:38 4 answer the question.

5 care of that. 13:51:42 How often do you speak to him?

6 Q. Okay. 13:51:43 MR. ROSEN: Objection.

7 A. So he always advise me with something in the 13:51:44 THE WITNESS: As needed.

8 short limit of time or urgency kind of like it. 13:51:47 MR. ROSEN: Counsel, please specify a time

9 Q. Okay. 13:51:51 9 frame.

10 A. And then he took it like that. He briefed

MR. HARBACH: Sure.

11 me. That's it. 13:51:56 11 BY MR. HARBACH:

12 Q. Okay. And I will ask you one more time what 13:51 :57 12 Q. From the moment you learned about the DIP

13 he said when he briefed you, and then I'll -- I'll 13:52:01 13 loan from some attorney until today, how frequently

14 try this another way. 13:52:04 14 have you spoken with Mr. Kwok Ho Wan?

15 A. Okay. 13:52:06 A. Oh, I think I met him, like, more than

16 Q. What did he say when he briefed you, if you 13:52:06 16 a week ago -- a week ago.

17 remember? I mean, this was, what, a month ago?

Q. Okay. That's one time.

18 A. So what are you asking about? Like, when 13: 5 2: 14 Any other times you can think of?

19 the brief happened or the DIP loan happened, sir? 13:52:16 A. I don't recall.

20 Q. Fifteen seconds ago you told me a couple of 13:52: 18 20 Q. On that one occasion that you do recall, did 13:55:10 21 times that Mr. Qiang Guo briefed you. 13:52:22 21 you discuss the DIP loan with Mr. Ho Wan Kwok?

22 Do you remember that?

A. No.

23 A. Yes.

Q. When you saw Mr. Kwok most recently-- you

24 Q. What did he say when he briefed you? 13:52:28 24 said it was about a week ago -- was that in the

25 A. He said he retained attorney and worked 13:52:32 25 Golden Spring (New York) offices?

I together with the lenders' attorney and then -- to

A. Yes.

2 take care of the DIP loan. And that is what he told 13:52:48 Q. Okay. Do you recall what you did discuss

3 me. 13:52:53 3 with him on that occasion?

4 Q. Okay. Was that the first time you had heard 13:52:53 A. We just -- like, I send my regards, like,

5 about the DIP loan? 13:52:57 5 social.

6 A. No.

And he asked, are you doing good; right?

7 Q. Who was the first person you heard about it 13:53:01 7 So that's it, yeah.

8 from?

We chat -- and he chat whether I am safe,

9 A. I heard from the attorneys -- our attorneys. 13:53:06 9 and I did the same. That's it. We didn't -- we

10 Q. Okay. Before this conversation with 13:53:10 10 didn't chat about other stuff. I don't -- we didn't. 13:56:20 11 Qiang Guo? 13:53: 13 Q. Okay. And that was it, just -- just, like,

12 A. Correct. Yes. 13:53:14 12 hi, how are you, that sort of thing?

13 Q. Have you ever spoken with Mr. Ho Wan Kwok 13:53:23 A. Yes.

14 about the DIP loan ever?

15 A. I don't recall. 13:53:29 15 meeting his attorneys. And I -- because this is my

16 Q. Is it possible that you have? 13:53:32 16 office; so I arranged the office, like, you know,

17 A. Unlikely. I don't recall. 13:53:36 17 like, take care of them; like, you know, arrange

18 Q. How often do you speak with Mr. Ho Wan Kwok? 13:53:48 18 their food and coffee, those kinds of stuff; so my 13:56:46 19 A. Oh, we meet as needed. 13:53:51 19 office did that for them.

20 Q. A few times a week?

Q. Your office or you?

21 A. As needed. 13:54:00 A. My office. I instructed my office to do

22 Q. More or less than a few times a week? 13:54:02 22 that.

23 A. As needed.

24 Q. I mean, as needed could be twenty times 13:54:11 24 president and so forth of Golden Spring --you know

25 a day, Ms. Wang.

Page 139 25 what I mean by and so forth; right?

I don't really know that.

A. 1 BY MR. HARBACH:

Okay.

Q. Q. Did Mr. Qiang Guo ever tell you how the

What means so forth?

A. 3 \$8 million figure was arrived at?

Q. Sure.

A. (In English) No.

I mean all those other titles, president,

5 Q. Are you familiar with the terms of the DIP

6 secretary, treasurer, director. 13:57:33 6 loan?

You hold all four titles; right?

7 A. You just asked me, yes. Now, yes.

A. Correct. 13:57:37 MR. HARBACH: Let's use the interpreter,

Q. Okay. And you are the only president;

9 9 please.

10 correct? 13:57:40 Ms. Johnston, could you please ask: Are you 14:01: 15

A. Correct.

11 11 familiar with the terms of the DIP loan?

Q. The only treasurer; correct?

A. Yes.

Q. Okay. And what decisions are you empowered

14 14 This was my first time involved in this matter; so

15 to make in those roles without Qiang Guo's 13:58:00 15 I know it was a loan. But! am unfamiliar with the

16 permission? 13:58:06 16 terms.

A. I make most of the daily operation decisions 13:58:06 17 17 BY MR. HARBACH:

18 in here. Of course, I will brief him when we meet or 13:58: 15 Q. Have you read the DIP loan agreement?

19 chat, but I made the, like, daily operation decision 13:58:19 A. (In English) Briefly, I went through, yes.

20 by myself in here.

Q. When was that?

Q. How much is the -- the DIP loan that is at

A. You mean when or what?

22 issue in this case?

Q. I'm sorry.

A. The DIP loan is \$8 million U.S.

When? When did you go through it briefly?

Q. And who did you learn that from?

25 25 counsels, I believe.

I Mr. Qiang Guo. 13:58:46 Q. Okay. And how long ago was that?

Q. Okay. Do you know where the \$8 million

2 A. l'msorry.

3 figure came from?

A. When Mr. Qiang Guo advise me, he advise he 13:58:55 4 that?

5 will take care of that also, as we always did. Like 13:59:06 Q. Yes, ma'am.

6 the fund; like, for example, like, you asked did his 13:59:10 I'm -- I'm -- I'm -- I'm not interested in

7 father ask for buy something, like, he will -- I have 13:59: 14 7 what any of the attorneys told you, but I am

8 to escalate for him. He will make a decision for him 13:59: 17 8 interested in when you met with them.

9 that way.

So when was it that you read the DIP loan

Q. I'm trying to understand, if you know, how

10 10 agreement?

II the figure of\$8 million was arrived at. 13:59:29 A. When, you ask; right?

Q. Correct.

13 interpreter on that? 13:59:35 A. Before this deposition. Yesterday.

I believe the witness may have misunderstood 13:59:36

Q. Yesterday?

15 the question the first time. 13:59:39 A. Yes.

MR. HARBACH: Sure.

16 Q. Was -- was yesterday the first time you saw

Ms. Johnston, do you need me to repeat it? 13:59:42 17 the DIP loan agreement?

THE INTERPRETER: Yes, please.

A. I know it existed before yesterday, but

19 BY MR. HARBACH: 13:59:48 19 I didn't pay too much of attention until my attorney, 14:03:28

Q. Ms. Wang, I'm asking if you know how the

13:59:49 20 like, prepped me.

21 \$8 million figure was arrived at.

Q. Was yesterday the first day you saw the DIP

13:59:55 22 loan agreement?

24 I was not involved in how the \$8 million was arrived; 14:00:22 25 so I do not have any personal knowledge. 14:00:28 24 before, but I couldn't recall.

1 remotely intended to invade the privilege, but I hope 14:03:56 1

2 you will understand why I am asking it. 14:04:01 2 native language.

3 BY MR. HARBACH:

Q. Ms. Wang, when you met with the attorneys 14:04:04 4 taking care of that also. Because this attorney

5 yesterday, was there an interpreter available to help 14:04:06 5 based in UK; so like, where Mr. Qiang Guo is at. He

6 you? 14:04:09 6 will take care. For Golden Spring, we didn't receive 14:07:56

A. No. 14:04: 13 7 invoice yet. Probably will come, but I didn't see

14:04:18 8 thatyet.

9 yesterday, did you understand it? 14:04:21 9 BY MR. HARBACH:

A. I know it is a loan. It is 8 million, and

14:04:31 Q. So when Mr. Qiang Guo told you that he would 14:08:04

11 interest is at 5 percent and subject to the court to 14:04:34 11 take care of it, you understood that to mean that

12 approve by the end. 14:04:38 12 Golden Spring (New York) would pay for her services;

Q. Okay. Do you know anything else about the

13 13 is that right?

14 conditions that are attached to the loan?

A. I learned from the reading it is kind of

14:04:51 15 Golden Spring, like, we didn't receive invoice. If

16 like a 50 percent pay the lender -- no. The debtors 14:04:55 16 we receive that invoice, we will take care of that.

17 professional. Another 50 percent is going to pay

Q. Okay. Are there any other current officers

18 U.S. Trustee and the other attorney related. 14:05:05 18 and directors of Golden Spring (New York) Limited,

14:05:10 19 besides you and Qiang Guo?

20 default?

A. No.

A. You mean in this DIP loan agreement?

Only me and him.

Q. Yes, ma'am.

Q. Okay. Am I right that there was a time,

A. I didn't pay attention about that. 14:05:22 23 a few months in 2020, when you were replaced as

14:05:25 24 president by someone named Daniel Podhaskie,

25 default that are in this DIP loan agreement are? 14:05:29 25 P-o-d-h-a-s-k-i-e? Is that right?

A. Can I have, like, interpreter help me on

I A. Correct.

2 this? Because it is about this DIP loan details. 14:05:40 Q. It looks like Mr. Podhaskie was in those

Q. Ofcourse. Ofcourse. 14:05:44 3 roles for a little less than two months.

Does that sound about right to you?

5 Ms. Johnston.

A. Yes.

6 BY MR. HARBACH:

Q. Okay. And why was it that he replaced you

14:05:51 7 for those couple of months?

8 default in this DIP loan agreement are? 14:05:53 A. Because I -- I was -- I had personal issue

14:05:53 9 by then, which I couldn't perform as my job as duty.

THEWITNESS:Idon'trecall.

Q. I see.

II BY MR. HARBACH: 14:06:10 And when that personal issue was resolved,

Q. Youdon'trecalloryoudon'tknow?

A. I don't recall.

13 A. That's right.

Q. Do you know who Arethusa Forsyth is?

Q. -- is that right?

15 A-r-e-t-h-u-s-a, last name F, like Frank, 14:06:50 A. Yes. That's right.

16 o-r-s-y-t-h.

Do you know who that person is? 14:07:00 17 Mr.Podhaskiewhenyoucamebackonthejob?

A. This is attorney retained by Mr. Qiang Guo

18 A. I don't recall.

19 work on this DIP loan. 14:07:09 Q. Okay. Do you recall, in any conversations

Q. Did you have any -- withdrawn. 14:07:10 20 with Mr. Podhaskie, whether he was in contact with

Do you know how Attorney Forsyth is being

21 21 Mr. Ho Wan Kwok?

22 paid?

A. No.

A. I'm sorry.

I don't recall. We just handed over, like,

Interpreter, can I have some support?

25 24 the daily operation work. I mean, I don't recall

25 anything more than that.

A. Less than two years ago.

2 currently, as of today, working for Golden Spring

Q. Okay.

3 (New York)?

A. Less than -- closer to two years.

4 A. No. 14:11:48 Q. Approximately two years ago?

5 Q. Who is the current general counsel of

A. Yes.

6 Golden Spring (New York)?

About two years ago. A little more or less. 14:15:18 7 MR. ROSEN: I'm going to object to that

Q. Okay. And -- and were you involved in the

8 question, and I have been advised for matters of 14:12:02 8 decision to hire this person?

9 personal security that general counsel does not wish

A. Yes.

10 to disclose general counsel's identity.

14:12:17 11 recruitment as the president of the company.

12 around it, Scott. Just don't hesitate to interrupt 14:12: 19 Q. How many other people did you interview for

13 if -- if you want to, but I'm going to try and work 14:12:23 13 that position?

14 around that.

A. Wow. I mean, when I hire people, I'm pretty 14: 15:47 15 Okay? 14: 12:27 15 much, if! can say, picky; so I did interview, like,

16 MR. ROSEN: Okay. 14:12:27 16 several candidates.

17 BY MR. HARBACH:

Q. Okay. Do you know where the person who is

18 Q. Ms. Wang, your lawyer doesn't want you to 14:12:28 18 currently the general counsel worked immediately

19 say the name, but do you know who the current general 14: 12:31 19 before coming to Golden Spring?

20 counsel of Golden Spring (New York) is? 14:12:35 A. Can you please repeat again?

21 A. Yes, I know.

Q. Yes.

22 Q. Okay. And do you communicate with that

A. Sorry.

23 person? 14: 12:42 Q. The -- the person who is general counsel of 14: 16:25

24 A. Yes, we do. 14: 12:46 24 Golden Spring, who you said you were involved in

25 Q. How regularly? How often do you communicate 14:12:49 25 hiring, where did that person work immediately before 14:16:31

1 with that person? 14:12:52 1 Golden Spring, if you know?

2 A. We communicated -- it is not a daily basis, 14:12:53 A. Idoknow,butldon'tfeelcomfortableto

3 but several times per week. 14:13:03 3 give any details about my current employee --

4 Q. Okay. I find it interesting that you have 14:13:06 Q. Okay.

5 a clear recollection of how often you speak with the

A. -- and including previous employer.

6 general counsel, but no recollection with any clarity 14: 13: 18 Q. How about this?

7 of how often you speak with Mr. Ho Wan Kwok.

A. That safety reason again.

8 Can you explain that?

Q. Give me -- give me the -- give me the first

9 A. Yes, sir. 14:13:31 9 letter of the company where the general counsel

14:13:33 10 worked before coming to Golden Spring.

II Golden Spring, and that is my job to communicate with 14:13:35 MR. ROSEN: Objection. That's -- that is

12 my employee, including my general counsel and the 14:13:38 12 the -- it is the same issue.

13 rest of our employees; so that is my job. I am being 14: 13:42 MR. HARBACH: Because of the first letter?

14 paid to do that; so Mr. Ho Wan Kwok-- I mean, we

15 don't communicate on a regular basis or any -- kind 14: 13 :53 15 twenty questions here. David, c'mon.

16 of like as you said, a regular basis. We just 14:13:56 16 BY MR. HARBACH:

17 communicate as we need. I mean, he is not employee;

Q. Was the general counsel's prior employer --

18 right? 14:14:04 18 was the identity of the general counsel's prior

19 And then I don't report to him; so why 14: 14:04 19 employer a factor in your decision to hire that

20 should I, you know, keep that rhythm and then to talk 14: 14:07 20 person?

21 with someone who is not in my job work? 14:14:10 A. Well, I don't understand your question, sir.

22 Q. Just one moment, please. Hang on one 14:14:14 Can I ask for the interpreter to help me?

23 second. 14: 14:24 23 Sorry.

24 When was the current general counsel of

Q. No problem.

25 Golden Spring hired?

Page 151 MR. HARBACH: Here we go, Ms. Johnston.

1 BY MR. HARBACH: 14:17:55 1 Golden Spring (New York), apart from the general

2 Q. Is the -- was the identity of the general 14:17:55 2 counsel?

3 counsel's provider employer a factor in your decision 14: 17:58 A. Which time period you are asking, sir?

4 to hire that person? 14:18:05 Q. Currently.

5 THE INTERPRETER: (Question interpreted.) 14: 18:24 A. No.

6 THE WITNESS: When I interview and hire

7 people, like the previous employer before me, that 14: 18:33 7 (New York) Limited currently have?

8 does matter also. And, obviously, you know, I want

MR. ROSEN: I believe that information has

9 to hire the high quality oftalent; right? 14:18:44 9 been previously provided. And I believe, David, you

10 Where they are from, that do matter. And, 14: 18:48 10 are aware of the sensitivity to the employee issue.

II plus, I still care about, like, the loyalty with the 14:18:51 11 I -- I don't think we have an objection to answering

12 previous job. You already--! don't like, you know, 14:18:54 12 how many employees there are, but I would ask you

13 employee or the candidate jumping too often from job 14: 18: 59 13 not -- not to get into any personal or identifying

14 to job. But besides that, you know, I do care about, 14: 19:04 14 information with respect to that.

15 like, the interview --the feeling of the interview; 14: 19:09 MR. HARBACH: Yeah. I -- !--thank you,

16 right? 14:19:11 16 Scott.

17 The understanding and the communication and 14:19:12 I do understand the position of

18 the people skill, of course the capability of 14: 19:14 18 Golden Spring (New York) as had been represented to

19 professional, that all matters; so to answer your 14:19:17 19 us by counsel and repeated by counsel for the debtor

20 question, the previous employer does matter, but it 14:19:20 20 in -- in a previous proceeding; so I will respect

21 is not only the -- only one reason for me to make 14: 19:23 21 your request for purposes of this deposition while

22 a decision to send out the offer. 14: 19:27 22 noting that we disagree strongly with the -- the

23 BY MR. HARBACH: 14:19:31 23 basis of it.

24 Q. Did you contact this general counsel's 14:19:31 24 BY MR. HARBACH:

25 previous employer during the hiring process?

Q. So for the moment, Ms. Wang, my question is

I A. I remember my HR department by then, they 14:19:42 I just the number of employees.

2 conducted the background check and reference check.

3 I didn't do that by myself. I have a company do 14: 19:51 3 Golden Spring (New York) Limited?

4 that.

A. Oh, currently I believe it is about fourteen 14:22:45 5 Q. So you did--you, personally, did not speak 14:19:54 5 ofthem, including myself.

6 to anyone at this person's prior employer; correct?

Q. Including you?

7 A. I mean, I manage the entire, like, employee.

A. Yes.

8 I mean, as the president of the company, my 14:20:06 Q. Does that also include Mr. Qiang Guo? Or

9 understanding is you are the -- the HR department 14:20:09 9 no?

10 will do that for me; right? 14:20:12 A. No.

II Q. You know, Ms. Wang, it is a simple question. 14:20:14 Q. Okay. So you and the general counsel --

12 I'm not suggesting you should have. I'm just asking 14:20:17 12 does that include that person?

13 whether you did.

A. Correct.

14 A. No, I didn't.

Q. Okay. So you, the general counsel, and

15 Q. Okay. 14:20:23 15 twelve other people?

16 A. My HR department did that, uh-huh.

A. Yes.

17 Q. Okay. Did you personally conduct any of the 14:20:27 Q. Do all of those people work at the family

18 reference calls for this person? 14:20:30 18 office?

19 A. No.

MR. ROSEN: I object to this. The -- there

14:20:35 20 are issues of physical security that I have been

21 person, my -- personally. 14:20:40 21 alerted to. And if-- if -- if you would like,

22 Q. But your understanding is that somebody in 14:20:43 22 David, I do have a statement from the Golden Spring

23 your HR department did? 14:20:44 23 security team that I could read into the record.

25 A. Correct.

Q. Are there any other inhouse lawyers for 14:20:47 24 If -- if -- if you think it is appropriate. But --

MR. HARBACH: I -- I appreciate that, Scott. 14:23:59

1 I mean, I -- as I said before, we -- we understand 14:24:02 A. He advised me he will take care of that.

2 the position that you are taking. And if your 14:24:05 Q. Did he tell you where the money was coming

3 position is whether all employees work in the same 14:24:08 3 from?

4 location presents a security risk such that you are 14:24:13 A. So far not yet. But he said he will take

5 going to direct the witness not to answer, that is 14:24:16 5 care of that, as he always does.

6 okay. I'll just note for the record that we -- we

Q. Did you ask him where the money was coming

7 disagree and reserve the right to take it up with the 14:24:22 7 from?

8 Judge, like we do just about all of the objections 14:24:26 A. I didn't.

9 that have been made today. But -- but -- but that is 14:24:30 9 Q. Okay.

10 sufficient for present purposes, if that is okay with 14:24:34 A. He said he will take care of that.

11 you.

Q. No.

12 MR. ROSEN: Yes.

I -- I -- I understand that he said he will

13 That -- that is fine. 14:24:38 13 take care of it. I'm just asking if you know where

14 MR. HARBACH: Okay. 14:24:40 14 the money was coming from, and-- and I think I have

15 BY MR. HARBACH: 14:24:41 15 got the answer.

16 Q. Does Golden Spring -- as far as -- as you

A. We have trust between each other for so many 14:27:51 17 are concerned, Ms. Wang, does Golden Spring 14:24:54 17 years. When -- as the owner of the company, he said

18 (New York) Limited expect to be repaid for the DIP 14:24:59 18 he will take care of that, and I will just let him do 14:27:57 19 loan? 14:25:05 19 his part. I am doing my part; right? So

20 A. It is a loan, yes. Golden Spring is going

Q. Listen, that -- that is fine. But you have

21 to expect to be repaid. 14:25:12 21 been tendered as the person at Golden Spring

22 Q. We were speaking earlier about bank accounts 14:25:14 22 (New York) Limited with knowledge about all these

23 and whatnot, and I'm -- and I'm not intending to 14:25:30 23 topics that we have noticed. One of the topics is

24 reopen that can of worms, but I am going to ask this 14:25:33 24 the source of funds used by Golden Spring to finance

25 precise question. 14:25:38 25 the DIP loan agreement. And so I -- I just asked you 14:28:21

I What is the source of the moneys that will 14:25:38 I if you know, and so we are clear, your answer is you

14:25 :41 2 don't know, but Qiang Guo said he would take care of 14:28:31 2 fund the DIP loan if it is approved? 3 A. And it will be arranged by Mr. Qiang Guo 14:25:43 3 it, and that's enough for you.

4 directly.

5 Q. What is the source of the moneys that will 14:25:53 5 mischaracterizes the testimony.

6 fund the DIP loan ifit is approved? 14:25:58 MR. HARBACH: Oh, Scott, how does that

7 A. It will be arranged by Mr. Qiang Guo 14:26:06 7 mischaracterize the testimony?

8 directly.

MR. ROSEN: Because she also testified that

9 Q. Do you know where the money will come from? 14:26:08 9 it could be from his wealth.

10 A. I was not advised it yet, but Mr. Qiang Guo 14:26: 13 10 BY MR. HARBACH:

11 said that he will take care of that, as he always do. 14:26:19 Q. Okay. So did he -- did he say that? My

12 Q. So you are president and treasurer of 14:26:22 12 question is did he say that to you? Did he say that

13 Golden Spring. You are here testifying today about 14:26:25 13 I am -- I'm going to take care of it from my wealth?

14 a DIP loan, as I have been reminded countless times. 14:26:29 14 Is that what he said?

15 And your testimony is that you do not know where the 14:26:35 A. Correct.

16 money to fund the DIP loan is coming from. 14:26:39 Q. He said that to you?

17 Have I got that right?

A. Yes.

19 mischaracterizes the witness' testimony. 14:26:48 19 said, I will take care of that. You don't worry.

20 You can answer the question. 14:26:55 20 And I have place to rent. My understanding, after so 14:29:20

14:26:56 21 many years, that will come from his wealth.

22 Mr. Qiang Guo directly from his or -- his wealth, in

Q. Okay. So he did not say to you, I will take 14:29:26 23 my understanding, as always we do. 14:27:06 23 care of it from my money. He just said, I will take

24 BY MR. HARBACH: 14:27:10 24 care ofit, and based on your experience with him

25 Q. Did he tell you that?

Page 159 25 over the years, you understood that to mean from his

1 wealth. 14:29:42 Q. Okay. And do those bylaws say anything

2 Have I got that right? 14:29:43 2 about decisions of the company and how they are to be 14:33:56 3 A. So you remind me, like, he said I have it. 14:29:45 3 made?

4 I will take care of that. That's his, as we said, 14:29:51 A. Yes.

5 quote to quote. He said that to me. In my 14:29:55 Q. Okay. And do those bylaws include rules

6 understanding, that will come from his -- his wealth. 14:29:58 6 about how the -- the president and treasurer are to

7 Q. Okay. And when was this conversation? 14:30:00 7 be involved?

8 A. That was yesterday also.

A. Yes.

9 Q. Was yesterday the -- the first time you

10 learned what the source of the funds used to finance 14:30:17 10 Golden Spring has operated within the constraints of 14:34:22 11 the DIP loan agreement were coming from? 14:30:24 11 those bylaws properly as long as you have been there? 14:34:27 12 A. There was a -- in order to prep the 14:30:30 A. What do you mean, properly, sir?

13 deposition today, like, he went through this DIP loan 14:30:37 Q. Well, have they-- while you have been at

14 arrangement with me a little bit. 14:30:41 14 Golden Spring (New York), have the rules been

15 Q. Okay. 14:30:43 15 followed as laid out in the bylaws?

16 A. Yeah. He mentioned to me, I have it.

A. I mean, we are family office. I mean, we're 14:34:44

14:30:46 17 private company and family office. I work for

18 Q. All right. 14:30:48 18 Mr. Qiang Guo, himself, for my entire career; so

19 A. -- you know, as a conversation. 14:30:49 19 like, he authorized me to make a decision.

20 Q. Fair enough. 14:30:50 20 I communicated with him. I mean, we don't have

21 My only question for you is when he told you 14: 30: 51 21 issue. If there is missing any paperwork, it doesn't 14:35:08 22 yesterday, I have it. I'll take care of it, is that 14:30: 54 22 mean that anybody purposely do anything wrong; so we

23 the first time you learned what the source of the DIP 14:30:58 23 are a family office.

24 loan funds would be?

25 A. That is the time I heard from him because 14:31:05 25 wrongdoing, certainly not on purpose. I asked you if 14:35:19

1 I need to prep the deposition today. But I know he 14:31: 11 1 the company had bylaws. You said yes.

2 has it for so many years; so it is not, like, the

My next question is has the company abided

3 first time -- right? -- I got -- oh, you have money. 14:31 :20 3 by the bylaws as long as you have been there, as far

4 It is not like that way. I know he had it. 14:31:23 4 as you know?

5 Q. Oh, I got it. I got you. And, believe me,

MR. ROSEN: Objection. That's -- that is --

6 I am not trying to suggest that yesterday was the 14:31 :28 6 that is very broad.

7 first day you learned he had money. Not at all. 14:31:31 What particular aspect of the bylaws are you 14:35:41

8 I get that. 14:31:35 8 looking for?

9 What I'm -- what I'm trying to focus on is

10 was yesterday the first day that you learned that the 14:31:38 10 focused on decision making and the powers of the

II money that would fund the DIP loan was going to come 14:31:44 11 president and treasurer; so I guess I'll ask it that

12 from Qiang Guo? 14:31:47 12 way.

13 A. That was the time I heard from him, yes. 14:31: 52 13 BY MR. HARBACH:

14 Q. Okay. What is your understanding as to how

Q. Have -- have the bylaws about the authority

15 the DIP loan is going to be repaid? If you know. 14:32:04 15 and power of the president and the treasurer been

16 A. I don't know. 14:32:11 16 respected since you have been at Golden Spring?

17 Q. Okay. Give me ten seconds, folks, please.

18 Excuse me. 14:32:31 18 in the record. It-- it is -- the question is -- is

19 Okay. Thanks, everybody. 14:33:24 19 hopelessly vague.

20 Subject change.

But you can answer.

22 (New York) Limited have any kind of company bylaws 14:33:45 22 manage Golden Spring (New York) Limited based on our

23 that you know of? 14:33:49 23 aligned -- aligned-- our aligned agreement and

25 A. Yes.

We do have bylaws. 14:33:50 24 properauthorization.

1 BY MR. HARBACH: 14:36:32 Q. Okay. So this is what I was asking you

2 Q. Okay. Let me ask a different question. 14:36:35 2 about a minute ago. In paragraph three, it says the

14:36:40 3 date of filing of the corporation's original

4 secretary, treasurer of Golden Spring (New York) in 14:36:47 4 certificate of incorporation in Delaware was

5 the spring of 2018 -- that's -- so that is the time 14:36:52 5 03/10/2015.

6 I'm focusing on -- were you aware that the company's 14:36:57 6 Do you see that?

7 charter had been inoperative and void since March I 14:37:01 7 A. Yes.

8 of2017? 14:37:07 8 Q. So that March 10th of 2015 was the --

9 MR. ROSEN: Objection. Assumes facts not on 14:37: 10 9 apparently the date of incorporation of Golden Spring 14:42: 16 10 the record. 14:37:13 10 (New York) Limited.

11 THE WITNESS: I don't recall. 14:37:15 11 And then ifyou look down at paragraph five, 14:42:21

12 BY MR. HARBACH: 14:37:16 12 it says:

13 Q. Do you recall ever executing a revival -- 14:37: 18 13 "The corporation was duly organized and

14 a certificate of revival on behalf of Golden Spring 14:37:23 14 carried on the business authorized by its

15 (New York) Limited to correct that problem? 14:37:27 15 charter until the first day of March AD 2017, 14:42:32 16 A. I don't recall. If you have documents, you 14:37:33 16 at which time its charter became inoperative 14:42:41 17 can remind me, sir. 14:37:36 17 and void for nonpayment of taxes and/or

18 Q. Give me just one second. 14:37:38 18 failure to file a complete annual report and 14:42:49 19 Okay. I think we're going to put up another 14:39: 17 19 the certificate of revival is filed by

20 exhibit here real quick that might help you remember. 14:39:21 20 authority of the duly elected directors of

21 MR. HARBACH: Yeah. Itis 808. Yeah. It 14:39:30 21 the corporation in accordance with the laws

22 is 808.

14:39:43 23 Were you able to follow along with me while

14:39:46 24 I read that?

25 MR. HARBACH: Thanks for your patience. 14:39:46 25 A. Yes.

I I think we have got the document here. 14:39:49 I Q. Okay. So now does this refresh your

2 THE WITNESS: Sorry. 14:40:02 2 recollection about whether when you were hired at

14:40:05 3 Golden Spring in the spring of 2018 the charter had

4 document? 14:40:07 4 been made inoperative and void?

5 BY MR. HARBACH: 14:40:08 5 A. So what is your question, sir? Are you

6 Q. Sure. 14:40:08 6 expecting me to reply?

7 A. Thank you. 14:40:09 7 Q. Yes, ma'am.

8 Q. Okay. So what is fixing to come through is 14:40:18 8 Before I dug up this document, when I asked

9 Exhibit 5. There we go. 14:40:21 9 you that same question, you said I don't remember or

10 All right. I had myself muted. I'm sorry. 14:41:02 10 I don't recall. And you said to me, if you have any

11 Could you please go to the last page of 14:41:04 11 documents, maybe that could help me; so I'm providing 14:44:00 12 Exhibit 5. 14:41:07 12 you a document to try and help you.

14:41:08 13 And the question is whether seeing this

14 Yes. I'm here. 14:41:09 14 document refreshes your recollection about whether at 14:44: 11 15 Q. Okay. You see how this one is captioned 14:41:10 15 the time you assumed your duties at Golden Spring

16 state of Delaware, certificate for revival of 14:41:14 16 (New York) in the spring of2018 the company, in

17 charter? 14:41: 18 17 fact, had become inoperative -- correction.

18 A. Yes. 14:41:18 18 The charter of the company had become

19 Q. And there is a signature at the bottom. 14:41: 19 19 inoperative and void.

20 Is that yours? 14:41 :23 20 A. So you are asking me why? Or what is your

21 A. Yes.

22 Q. And the very bottom right hand of the page 14:41 :27 22 Q. I'm asking whether this is, in fact, true

23 it says -- there is a stamp there that says filed 14:41:30 23 that at the time you were hired in the spring of

25 24 ten -- there is a time of!0:23: 18, I think it says.

A. Yes. 14:41:46 24 2018 -- okay? -- whether at that time the charter of 14:44:58 25 Golden Spring (New York) Limited was inoperative and

1 void. 14:45:12 You recall him being a lawyer at

2 MR. ROSEN: Objection. The -- the document 14:45: 12 2 Williams & Connolly; is that right?

3 speaks for itself. 14:45: 14 A. He is attorney of William Connolly, yes.

4 MR. HARBACH: It-- it does, indeed, Scott. 14:45:16 Q. Okay. And did you say-- make sure I heard

5 And that is quite fair. 14:45:19 5 you correctly.

14:45:21 Did you say that -- that he and

7 litigation is that sometimes documents are challenged 14:45:23 7 Williams & Connolly represented Qiang Guo?

8 as being inauthentic and forgeries when they are

9 plainly not; so I'm afraid I have to ask the 14:45 :31 9 William Connolly, Jerry Shulman -- Jerry represents

10 question. 14:45:34 10 Golden Spring Limited also.

II MR. ROSEN: You can answer the question. 14:45:34 Q. Okay. Did-- did Mr. Shulman represent

12 THE WITNESS: Sir, I don't -- I don't know 14:45:36 12 Qiang Guo?

13 what happened before I was officially hired, but if

14 you read back the entire Golden Spring, including,

Q. Because I believe that is what you said

15 I believe, the corporation, was set up by attorney 14:45:49 15 a few minutes ago. l'mjusttryingtomake sure

16 from William Connolly. The attorney's name is 14:45:52 16 I heard you correctly.

17 addressed on page three, Jerry L. Shulman; so

A. I believe so.

18 I know -- I got to know -- Jerry was Mr. Qiang Guo's 14:46:03 Q. Okay. To your knowledge, did Mr. Shulman of 14:49:14

19 attorney. And William Connolly was, like, a-- what 14:46:07 19 Williams & Connolly represent Ho Wan Kwok?

20 is technically, like, the Golden Spring charters,

A. I don't know that.

21 like, the documentation, you know, all the paperwork; 14:46: 17 21 Q. Okay. The -- the document that is on the

22 so the answer to you was, like, when I was hired -- 14:46:20 22 screen there says that the reason the charter became

23 of course, I don't know what happened before me, but, 14:46:25 23 inoperative and void was for nonpayment of taxes

24 obviously, Jerry Shulman, the attorney by then was -- 14:46:28 24 and/or failure to file a complete annual report.

25 maintained the -- the record here or fix the record

Page 170 Do you know which of those reasons, or both

I somehow, which I am not aware of that before me. 14:46:36 I reasons, were why the charter of Golden Spring became 14:49:55 2 BY MR. HARBACH: 14:46:41 2 inoperative and void?

3 Q. Okay. Just a moment.

A. As I said, before me, what happened I don't

4 Okay. We thought we were having a fire 14:46: 50 4 know. But since I was appointed, Golden Spring never 14:50:14 5 drill in our building, but it is only a test. Sorry 14:46: 53 5 has this problem.

7 6 for the noise.

I understood what you said, Ms. Wang.

Q. Okay. Well, it apparently had the problem

7 for six months after you were appointed because the

8 You--you signed this document, and it was filed in 14:47:03 8 certificate of revival wasn't filed until October; so 14:50:28 9 Delaware in October of 2018. 14:47: 12 9 I'll ask the same question. And maybe you don't

10 Do you remember signing it? 14:47: 18 10 know. It is okay if you don't know, but all I can do 14:50:37 11 A I don't recall. Too many years ago. 14:47:22 11 is ask.

12 Q. I gather, from what you said a moment ago, 14:47:24 Do you know what the reason was why the

13 that ifl were to ask you how you learned that the 14:47:29 13 charter became inoperative and void?

14 charter of Golden Spring had become inoperative and

A. I don't know the reason, but I am not able

15 void, you would say it was -- it was from the 14:47:41 15 to fix everything that happened before me from day

16 attorney you mentioned; is that right? 14:47:45 16 one I was appointed; right?

17 A I read this from the exhibit you present to

So the six months, that is a fair time. But 14:51:02 18 me. And the attorney's name, Jerry Shulman, is on 14:47:56 18 I need to spend on time and then start to catch up

19 that. Obviously, my understanding, he was working on 14:48:02 19 and fix what happened before me.

20 this before.

Q. Yeah. Andthankyou.

You requested a short break.

22 conversations with Mr. Shulman?

23 A I don't recall. 14:48: 11 23 now.

Just so everybody knows -- I hesitate to say 14:51:24

1 a break until 3 :00 o'clock. 14:51:33 I A No.

2 THE VIDEOGRAPHER: We are going off the 14:51:36 2 Q Where did it come from?

3 record. 14:51:37 3 A It come from his own successful investment.

4 The time is 2:51 p.m. 14:51:37 4 Q Okay I'm asking about the money that he

15:02:54 5 originally invested to become successful, didn't that 15 :06:46

15:02:54 6 comefromhisfather?

7 record. 15:02:57 7 A No.

8 The time is 3:02. 15:02:57 8 Q Okay Where did it come from 7

9 MR. HARBACH: Apologies, everyone. There 15:03:28 9 A What I -- what I learned is that it come

10 was a loud announcement on our loudspeakers here. 15:03:30 IO from his family -- his extended family.

11 That is why I remained muted. 15:03:34 II Q Who told you that?

12 BY MR. HARBACH: 15:03:34 12 A I learned from him.

13 Q. One cleanup question, Ms. Wang, before we 15:03:38 13 Q That is what he told you?

14 proceed to the next topic.

15 Could you describe one successful investment 15:03:44 15 Q Okay Next subject, do you remember earlier 15.07.21 16 that Golden Spring (New York) has made since you have 15:03:49 16 in our time today I explained to you that there was 15:07:28 17 been president? 15:03:53 17 a difference between the -- the DIP loan, which we

18 A. Since I was appointed as a president; so the 15:03:55 18 just talked about for some time, and then also loans 15 :07:35 19 first job, of course, is build up the entire team and 15 :04: 10 19 to fund litigation? Do you remember that?

20 then start back to the operation. And then we did 15:04:13 20 A Yes.

21 have some projects in discussion and then develop. 15:04:22 21 Q Okay And so now I want to talk about that 15:07:45 22 But because of a Pacific Alliance branded lawsuit, 15:04:26 22 second category, which is the loans that

23 I mean, our barik balance was very seriously hurt; so 15:04:35 23 Golden Spring (New York) has made to Ho Wan Kwok for

24 we were not able to complete the full investment 15:04:39 24 litigation.

25 project. But we did have some -- very prospective 15:04:43 25 Okay?

I one before. 15:04:49 I A. Yes.

2 Q. Okay. Leaving aside the prospective one, is 15 :04: 50 2 Q. Okay. So I -- for -- for right now I'm not

3 there any investment project that Golden Spring has 15:04:55 3 talking about the DIP loan.

4 done that has succeeded since you have been 15:05:02 4 Do you understand?

5 president? 15:05:05 5 A. Yes.

6 A. As I just explained, because our banking 15:05:06 6 Q. Okay. According to Mr. Ho Wan Kwok,

7 relationship was hurted by Pacific Alliance; so we 15:05: 10 7 Golden Spring (New York) has loaned him approximately 15:08:2 S 8 were not able to complete a full successful 15:05: 16 8 \$21 million to pay for litigation costs.

9 project -- investment project. 15:05:20 9 My question to you is are you aware of that? 15:08:35 10 Q. Okay. So -- so the answer is no? 15:05:22 10 A. Yes.

11 A. Correct. 15:05:25 11 Q. Okay. Who requested those loans?

12 Q. Okay. Did you know Qiang Guo before you 15:05:26 12 A. Who requested those loans? You mean the --

13 became an officer and director of Golden Spring 15:05:37 13 I mean, can you explain more about the question?

14 (New York) Limited? 15:05:42 14 Q. Who requested that Golden Spring (New York)

15 A. Yes. 15:05:42 15 Limited would make those loans to cover

15:05:42 16 Mr. Ho Wan Kwok's litigation costs?

17 successful business enterprise that Qiang Guo has 15:05:48 17 A. I believe they borrowed -- requested from

18 launched since you have known him. 15:05:54 18 Mr. Qiang Guo directly, the owner of Golden Spring.

19 A. I don't want to put his business, any 15:05:57 19 Q. By the borrower, you mean Mr. Ho Wan Kwok?

20 specific name, at any risk for obvious reason. But 15:06:06 20 A. That's right.

21 what I can tell you is that he has been very 15:06: 10 21 Q. Are you cap- -- withdrawn.

22 successful in the investment world for -- in -- in 15:06: 13 22 So father asked son to make the loans.

23 all of -- in different countries. 15:06:19 23 Is that what you understand?

24 Q. And isn't it true that the -- the money that 15:06:21 24 A. Yes.

25 he got to invest came from his father? 15:06:25 25 Q. Okay. Who approved those loans for

1 GoldenSpring(NewYork)? 15:10:03 1 convinced, if that is what you were talking about.

2 A. They were approved by both .vlr. Qiang Guo and 15:10:06 2 Q. Well, I'm not talking about anything in

3 myself, as the president of Golden Spring. 15: 10: 13 3 particular. I'm just asking. And I'm trying to get

4 Q. How did you become aware of the loans that 15:10:18 4 an understanding of what real authority you have as

5 were requested? 15:10:20 5 president and treasurer of Golden Spring (New York)

6 A. I heard from Mr. Qiang Guo. 15:10:22 6 Limited. Because what you have told me thus far is

7 Q. Did you have any conversations with 15: 10:28 7 that the DIP loan was approved by Mr. Qiang Guo

8 Mr. Ho Wan Kwok about those loans? 15: 10:30 8 without your input and that it was enough for you

9 A. No. 15:10:34 9 that he told you that he would take care of it. And

10 I don't recall. 15: 10:37 10 when it comes to the litigation funding, you have

II Q. Okay. You never asked him what the money 15:10:38 11 told me that father asked son and that you have never 15: 13:45 12 was for? 15:10:43 12 spoken to father about it, not even to ask him what

13 A. No. 15:10:44 13 the money was for.

15 Mr. Qiang Guo and Mr. Ho Wan Kwok. 15:10:48 15 exactly your role is. I mean, I know what your

16 Q. Okay. Were any of the litigation loans that 15:10:51 16 titles are, but I'm trying to understand what your

17 Mr. Ho Wan Kwok asked for refused? 15:11:04 17 role is; so that is why I'm asking these questions.

18 A. Yes. 15:11:12 And so my question is is there an occasion

19 Q. Bywhom? 15:11:14 19 you can point to where you disagreed with

20 A. Refused by Mr. Qiang Guo. 15:11:17 20 Mr. Qiang Guo over a decision that involved more than 15:14:18 21 Q. Did you agree, in your capacity as 15:11:20 21 a million dollars?

22 president, that it should have been refused?

A. Yes.

23 A. I am aligned with Mr. Qiang Guo's rejection. 15: 11 :29 23 Q. Okay. Howrecently?

24 Q. Okay. Are you ever not aligned with his

A. What do you mean, how recently? I already

25 decisions about matters involving millions of

Page 178 25 explained, like, regarding when I was appointed

1 dollars?

2 A. Yes.

Q. Okay.

3 Q. Okay. Can you describe occasion on which

A. -- disagreements about investment projects.

4 your opinion prevailed? 15: 11: 51 4 I am talking about real estate or investment project

5 A. For example, I make all the decision on the 15: 11: 56 5 in New York.

7 Q. I'm not asking about -- I'm not asking about 15: 12:04 A. I didn't convince him. I didn't convince

8 daily operations. I'm asking about a decision 15:12:07 8 him. They are all more than a million projects;

9 involving more than a million dollars. 9 right?

15:12:15 And I-- and I just testified this

11 A. I don't understand what you are asking 15:12:17 11 afternoon -- this morning, and he made decision about 15: 14:56 12 about. More than a million dollars is very general. 15: 12:20 12 the vehicles, which I don't align with that. But, of 15:15:00

13 I mean, I don't understand what you are asking, sir. 15: 12:23 13 course, we didn't get agreement, and he purchased the 15: 15 :06 14 Q. Okay. You just told me a moment ago that 15:12:25 14 cars. Because I don't agree with that; so that is

15 there have been occasions when you have disagreed 15: 12:28 15 the reason why I don't want to get too much of

16 with Mr. QiangGuo;right? 15:12:31 16 details, even as the president. We are a family

17 A. That's right. 15: 12:33 17 office;right?

18 Q. Okay. My question to you is has there ever 15:12:34 Ifwedon'tgetalignedand--thatheis

19 been a disagreement between you and him about 15:12:38 19 the owner of the company about the director; right?

20 a decision that involved more than a million dollars? 15: 12:43 20 So he made the decision about the vehicles,

21 A. More than a million dollars? 15:12:48 21 and then I made the decision about the investment

22 Q. Yes. 15:12:52 22 opportunity. And then we did have disagreement. We

23 A. I mean, we did have some disagreements in 15: 12:53 23 take care of -- we take care of the result by the

24 the very beginning about some potential investment

25 project; so we didn't get agreement, and he was 15:13:01 24 end.

Q. Okay. All right. And so there -- I think

1 I understand your answer, but there are two things 15:15:39 Q. Well, then tell me -- tell me another

2 that I just want to clarify and make sure of. 15:15:43 2 example then. Tell me another example of a decision

Number one, examples of disagreement.

3 3 involving more than a million dollars with which you

4 I asked you about timing. You just explained that 15:15:48 4 disagree and your opinion prevailed, besides the real 15: 19 :00 5 one of those examples was when you were appointed in 15:15:52 5 estate project that you have already mentioned three

6 2018the--youmentionedarealestateproject. 15:15:55 6 times.

7 Understood.

Any other example?

A. I answered already.

9 that we were talking about earlier today. 15:16:03 Q. Are any of the \$21 million in litigation

Any other examples that you can think of?

10 10 loans to Golden Spring (New York) expected to be

A. You are asking me about more than a million, 15:16:12 11 11 repaid?

12 which -- I mean, the advisement project, they are

A. Yes.

13 more than a million. 15:16:23 Q. Are any of the loans in writing?

Q. I understand. And I got that.

A. Yes.

15 Q. Have you seen the -- the documents for any

16 examples, besides those two. 15:16:29 16 of the loans?

A. Yes.

Q. Where are they?

18 asking about his father's legal thing, I mean that

19 his father-- as per Mr. Qiang Guo advise me, his

A. They are in my office.

20 father might want to bring some litigation, which he

Q. On East 64th Street or wherever?

21 was asking my advice, which I give him my advice and 15:16:51 A. What do you mean, wherever?

22 then he took it to support his father or not. That

Q. I'm sorry. I'm trying to avoid using the

23 happened also. 15: 16:59 23 exact address.

Q. With respect -- with respect to the -- the

25 vehicles, I believe you said that even though you 15: 17:05 25 New York City?

1 disagreed, Mr. Qiang Guo decided to buy the vehicles 15:17:09 A. I believe in the morning of -- this morning

2 anyway; right? 15: 17:14 2 I already testified my address, which you have it,

A. That's right.

3 3 sir. It is on the 64th Street office, Golden Spring

Q. Okay. Andisn'tthattruethat,ingeneral, 15:17:19 4 (New York)'s office.

5 if you disagree, as you said, Mr. Qiang Guo is going

Q. Okay.

6 to be the one who decides, according to you? 15:17:34 A. You don't need to avoid mentioning the

A. No. 7 address, sir. You have it.

It is -- it happened on his side also. If

15:17:41 Q. Well, forgive me for being extra careful in

9 I don't disagree, he will go with me. 15:17:46 9 light of your security concerns.

Q. Okay. Can you think of an example where you 15: 17:49 10 A. Thank you.

11 have disagreed and your point of view prevailed and 15:17:57 Q. Is that -- is that the address where the

12 the decision at issue involved more than a million 15: 18: 10 12 loan documents are located?

13 dollars?

A. Correct.

A. Sir, Ijustrepliedtoyourquestion. Like, 15:18:17

Q. How many such loan documents are there?

15 the real estate property investment project. 15:18:21 A. Several of them.

Q. Besides -- besides that one.

Q. More than ten?

A. !mean, as I explained, that is our business 15:18:29 17 A. Several of them.

18 plan; right? 15:18:32 Q. Do you know whether it is more than ten or

We do real estate investment.

19 19 not?

Ialreadytestifiedthatasafamilyoffice; 15:18:35 A. I replied, several of them.

21 right? 15:18:38 Q. Did you sign them?

Q. I'm -- I'm going to interpret your answer as 15: 18:39 22 A. Yes.

23 that is the only example you can think of. 15:18:42 Q. Who signed them for the borrower?

A. I don't agree. I don't agree. This is not

25 my answer. I give you my answer very clear.

A. The borrower signed it.

Q. Who is the borrower?

A. Mr. Ho Wan Kwok. 15:21:25 1 specifically do you mean by documented?

Q. Okay. Were you present when he signed them? 15:21:27

MR. HARBACH: Sure.

A. I don't recall.

Q. Okay. How many of the \$21 million in loan 4 4 indicated earlier in her testimony that some of the

5 are undocumented? 15:21 :42 5 loans were in writing and that there were loan

A. I don't recall. I couldn't give you the

6 6 agreements; so that is how I interpreted her answer.

7 precise number. 15:21:50 7 And I -- and I gather that some ofthem were and some 15:24:47

8 8 of them weren't. And so when I say documented loans, 15:24:50

9 request -- Scott, we'll request that Golden Spring 15:21:54 9 I mean the loans for which there is a written loan

10 (New York) Limited immediately produce to us all of 15 :21:59 10 agreement that she signed and that the borrower

11 the documents that the witness has just described, 15:22:02 11 signed.

12 namely, the loan agreements substantiating any 15:22:09 Does that help?

13 portion of the \$21 million in litigation loans that 15:22:13 MR. ROSEN: Yes.

14 the debtor has taken out from Golden Spring 15 :22: 16

Thank you.

15 (New York). 15:22:20 MR. HARBACH: Okay.

MR. ROSEN: I understand the request, and we 15:22:21 16 16 BY MR. HARBACH:

17 will take it under advisement.

MR. HARBACH: Okay. 15:22:25 18 doesn't change any of your answers, I assume.

19 BY MR. HARBACH: 15:22:29 Did you understand what! meant?

Q. Ms. Wang, are you familiar with the terms of 15:22:29 20 A. I replied my question. That is the best of 15:25: 17

21 any of those loans, meaning the litigation loans? 15:22:32 21 my knowledge for this second.

A. They are loans. They have interest. They Q. Okay. So just to make -- just to -- to

23 should be paid back. 15:22:43 23 recap and make sure I understand.

Q. What interest rate?

A. I couldn't remember clearly. I couldn't

25 25 litigation loans that have been made by Golden Spring 15:25:35

I remember clearly. Like, 2, 3 percent. I couldn't 15:22:53 I (New York) to Mr. Ho Wan Kwok; correct?

2 remember.

A. Correct.

Q. Who negotiated the interest rate on those Q. And some ofthose loans are -- are

4 loans for Golden Spring (New York)? 15:22:59 4 documented, by which I mean there is a written loan

A. Me and Mr. Qiang Guo, we designed it. 15:23:01 5 agreement; correct?

Q. Who negotiated with the -- the borrower, 15:23:06

A. Correct.

7 Mr. Ho Wan Kwok, for the interest rate on these 15:23:13

Besides that, we do have notes, like, on our 15:25:59 8 loans? 15:23:16 8 financial book that recorded as a loan also.

A. I don't recall.

9 Q. Okay. And then some of those loans do not

Q. Did you communicate with Mr. Ho Wan Kwok 15:23:21 10 have a -- a loan agreement in writing; correct?

11 about the interest rate on these loans? 15:23:26 A. But in our financial records it is

A. I don't recall. 15:23:29 12 documented as a loan; correct.

Q. Is the interest rate the same on all of the

13 Q. I understand. I understand.

14 loans?

A. As far as I know, I remember, yes.

15 15 a loan agreement that you signed and that

15:23:45 16 Mr. Ho Wan Kwok signed that contains an interest rate 15:26:31 17 \$21 million in litigation loans about correct, to 15:23:50 I 7 and formal terms; right?

18 yourrecollection?

A. Correct.

A. Approximately number -- yes. Correct. 15:23:57

Q. Okay. And approximately how much of that

20 Mr. Qiang Guo and Mr. Ho Wan Kwok also.

21 21 million is in documented loans?

Q. Okay.

A. I don't have it on the top of my head.

A. So financial notes was the loan agreement

MR. ROSEN: Can I ask, David, can you please 15:24:18 23 and then with our loan --

24 clarify.

Q. Okay.

When you say documented loans, what 15:24:22 A. -- agreement.

Q. And so for the ones -- not the ones that 15:26:57 MR. HARBACH: Sure.

2 were oral, but the ones that are in writing, you said 15:26:59 2 BY MR. HARBACH:

3 those documents are currently at the East 64th Street 15:27:04 Q. Was Golden Spring (New York) Limited

4 office; correct? 15:27:12 4 involved in assisting Mr. Kwok in filling out his

A. Correct.

5 5 bankruptcy schedules or his statement of financial

6 6 affairs?

7 documents that we are requesting. 15:27:19 A. No.

MR. ROSEN: I understand.

8 Q. What about Mr. K wok's monthly operating

Thank you.

9 9 reports? Do you know what those are?

10 BY MR. HARBACH:

A. Yes.

Q. Okay. Now, Ms. Wang, with respect to the 15:27:23 Q. Okay. Was anyone at Golden Spring

12 oral loans, who recorded them? 15:27:26 12 (New York) involved in helping prepare

A. What do you mean, who recorded them? For

13 13 Mr. Ho Wan Kwok's monthly operating reports?

14 Golden Spring?

A. We were requested to pull out his lifestyle

Q. Yes, ma'am. 15 expenses. That is, I directed Golden Spring to help. 15:30:40 I think you just mentioned a moment ago that 15:27:35 16 Q. Okay. Who made the request to you?

17 even the loans that were not documented with a loan

A. I couldn't remember. Probably his attorney. 15:30:49 18 agreement were recorded on the books of Golden Spring 15:27:41 18 I couldn't remember.

19 (New York); right? 15:27:46 Q. Okay. And ifl understand you correctly,

A. Correct. 15:27:47 20 you directed one of your employees to assist?

Q. So I'm asking who recorded them on the

21 A. Correct.

22 books?

MR. HARBACH: Okay. And I'll just note for

A. Golden Spring's finance. 15:27:51 23 the record, Scott, that I won't ask who that person

Q. Okay. Was that at your direction? 15:27:55 24 is because I understand that you will object on the

A. Correct. 15:27:59 25 same basis as before. And I'll just note that we

Q. How did you learn about the terms of those

I I continue to disagree with that objection.

2 oral loans?

A. I got to know from Mr. Qiang Guo also.

Is that okay?

Q. Were you personally involved in negotiating

4 MR. ROSEN: Yes.

4 BY MR. HARBACH:

5 any or -- or tendering any oral loans to 15:28:16 Q. Do you know what the firm Verdolino & Lowey 15:31:35

6 Mr. Ho Wan Kwok?

A. I didn't attend the -- the conversation

7 6 is?

A. Verdolino Lowey.

8 between Mr. Qiang Guo and his father, no. I didn't.

15:28:33 Q. Have you ever heard of them?

A. No.

10 a loan from Golden Spring? 15:28:36 I don't recall. A. I don't recall.

Q. Okay. Do you know who Craig Jalbert is?

Q. Does that mean it is possible that he has? 15:28:40 A. I don't know this name.

A. I don't recall.

13 Q. Okay.

Q. With apologies if I asked you this question

A. Craig Jalbert.

15 before. I honestly don't remember.

Q. This may seem obvious from your earlier

15:29:02 16 answer, but please bear with me.

17 about any of the litigation loans, whether oral or

Leaving aside the person's name, is it true

18 written? 15:29:11 18 that there are personnel at Golden Spring (New York)

A. I don't recall. 15:29: 12 19 Limited who could assist in compiling and calculating 15:32:31

Q. Were you personally involved in helping 15:29:13 20 the lifestyle expenses of Mr. Ho Wan Kwok?

21 Mr. Kwok fill out his bankruptcy schedules and his 15:29:33 A. Yes.

22 statement of financial affairs?

Q. Focusing now just for a moment on those

15:29:41 23 lifestyle expenses.

24 here to testify in her personal capacity. I would

Okay?

25 ask you to rephrase the question.

A. Yes.

Q. Has -- has Mr. Kwok ever made any requests 15:33:12 1 safety of his father; so the communication that

2 to you to have Golden Spring (New York) pay for 15:33:21 2 happens between Ho Wan Kwok and the security to

3 expenses related to his lifestyle? 15:33:28 3 arrange the trip to Manhattan; so that one I don't

Excuse me. 4 need to get involved because it is too small for me.

A. I don't recall, but it is possible. 15:33:33 Q. Okay. And then what about other day-to-day

Q. Okay. What I'm asking about is, you know, 15:33:39 6 lifestyle needs, like in a recent proceeding the --

7 hey, Yvette, I need Golden Spring to pay for me to 15:33:46 7 the U.S. Trustee asked about what ifhe needed to buy 15:36:42 8 drive to Manhattan or I need Golden Spring to pay for 15:33:52 8 a pair of shoes?

9 this suit that I need for my trip to court -- things 15:33:57 Just walk us through how that happens.

10 like that.

A. I don't even -- I mean, yes. I review some

Does he make requests to you like that?

11 11 of the credit card bill or the bills, but I do have

A. I don't recall. But there was some requests 15:34:06 12 12 my finance. I mean, I don't need to do finance job.

13 that he made -- he made to me, like, as before, like, 15:34: 15 13 I don't even remember to see very often he buys

14 buy some very expensive, like, furniture, I believe.

15 And I -- obviously, it is more than his lifestyle. 15:34:22 Q. Does he buy anything?

16 I report itto Mr. Qiang Guo, and Mr. Qiang Guo

A. Yes.

He buy -- he buy clothes, yes.

Q. Okay.

Q. Okay. So how does he buy clothes?

A. -- so I reject it to him also.

A. He buy clothes from the shops, I believe.

Q. Right.

Q. Okay. Does he physically go to the shops or 15:37:28 A. Yeah.

21 21 does he shop online?

Q. I'm asking about, you know, day-to-day 15:34:34 MR. HARBACH: Scott, I promise I am just

23 stuff, like the -- however -- you know, I don't mind 15 :34:37 23 trying to understand. I don't -- I won't dwell here

24 telling you it has been a real mystery to all ofus 15:34:43 24 unnecessarily.

25 creditors and, I think, to the U.S. Trustee how

I Mr. Kwok pays for things. We really have had 15:34:52 I BY MR. HARBACH:

2 a difficult time figuring out how that happens. And 15:34:55 Q. Go ahead, Ms. Wang.

3 so I am hoping that you can help me understand 15:34:58 A. I don't get involves in his personal life;

4 a little bit because, according to him, Golden Spring 15 :35:01 4 so I cannot say.

5 (New York) Limited pays for all this stuff. And 15:35:04 Q. So you don't -- you don't know whether he

6 since you are the president and treasurer of 15:35:07 6 likes to go in the stores to shop orhe shops online? 15:37:51 7 Golden Spring (New York) Limited, I'm hoping you can

8 help us understand. 15:35:14 8 !verify. Ihavethefinanceverifythatitwashis

9 9 purchase.

10 review of credit card bills and -- and so forth, but

Q. Okay.

II for something like that, say Mr. -- Mr. Ho Wan Kwok 15:35:21 A. We take care of that; so I don't need to

12 needs to take a trip into Manhattan for some reason

13 and he needs a car. 15:35:30 Q. All right.

A. -- where he goes; right?

15 run the day-to-day operations of Golden Spring.

Q. No.

17 a message and say, hey, I need a car set up? I mean, 15 :35 :42 17

18 how does that work? 15:35:46 18 follow him.

15:35:48 What I'm really just trying to understand is 15:38:20

20 question, as the president of a company, I mean, 15:35:50 20 how does the transaction happen? Mr. Kwok walks into 15:38:23 21 I already don't deal with this kind of very small 15:35:53 21 Saks Fifth Avenue and sees a suit he wants to buy.

22 request from him; so Golden Spring does have 15:35:57 22 Let's just pretend that's what happens.

23 a security which, as you understood probably, sir,

Okay?

24 like as per Mr. Qiang, was a regiment because

And he is in there, and he says, I like that 15:38:38 25 Mr. Qiang would -- does care the most is the life 15:36:13 25 suit. And he tries it on, and it looks good, and so

1 he wants to buy it. 15:38:45 Q. Okay. So I think you do know my question,

15:38:47 2 and it is really not hard. But it seems to be really 15:42:02 3 there to being on a bill that you see? 15:38:49 3 hard to get an answer to it.

A. Oh, that doesn't happen often at all. That

4 How does Mr. Ho Wan Kwok purchase things,

5 is number one. And that did happen before. Like, 15:38:58 5 and how does what -- something that he wants to buy

6 sometimes I can see from the securities credit 15:39:03 6 and buys end up on a bill for you to review? And you 15:42:23 7 card-- debit card -- let me correct -- to see that 15:39:07 7 have given me one example.

8 purchase. And then, obviously, my finance will dive 15:39:10 You said there are times when Mr. Qiang Guo

9 in and verify and confirm that he has purchased. But 15:39:14 9 will purchase something, and it will then end up on

10 that does not happen often at all. 15:39:17 10 a bill for you to review and verify; right?

Q. Okay. Well, you did mention that he buys

11 A. No.

12 clothes; right? 15:39:24 That is not my answer. You misunderstood

A. Yes. 15:39:27 13 me, sir.

Q. Okay. So you give me an example of how he

14 Q. Okay. Please explain.

15 will buy some clothes. 15:39:34 A. I will use my translator since you have been 15:42:49

15:39:36 16 misunderstanding me along the way, which I don't feel 15:42:53 17 happen very often, tell me what does happen. 15:39:40 17 you get this. Sorry.

A. He just doesn't buy clothes very often, not

15:39:43 Like, can I have my interpreter --

19 only the shoes at Saks Fifth Avenue.

Q. Absolutely.

Q. Does Mr. Kwok have a credit card?

A. -- I mean, to help me.

A. As far as I know, he doesn't have. At least 15:40:07

Q. Absolutely.

22 Golden Spring never give him. 15:40:12 MR. HARBACH: So for clarity of the record,

Q. Does he have a debit card? 15:40:14 23 Ms. Johnston, the question is I'm trying to

A. Golden Spring didn't give him. 15:40:17 24 understand how -- when Mr. Ho Wan Kwok wants to

Q. How do the things that he does purchase end 15 :40:20 25 purchase something, how does it get -- from the

1 up on a bill that you review? Tell me how that 15:40:25 I decision by Mr. Ho Wan Kwok to purchase something,

15:4030 2 how does that end up on a bill that Ms. Wang sees?

A. For his clothes, I mean, I know, like, 15:40:31 THE INTERPRETER: (Question interpreted.)

4 Mr. Qiang Guo, he has some shops in Manhattan. When 15:40:36 THE WITNESS: (Through the Interpreter)

5 he ism Manhattan he -- he -- I mean, quite often 15:40:43 5 Okay. First of all, when I say when I review bills,

6 shopping there, and sometimes I saw the bill from the 15:40:49 6 those were only in respect to Mr. Ho Wan Kwok's

7 shop, which I -- obviously finance will need to 15:40:52 7 purchase for clothing and shoes. And Mr. Qiang Guo

8 verify. If not, Mr. Qiang Guo purchase. But, like, 15:40:55 8 has certain shops he goes to on a regular basis; so

9 his father has purchased. That happened before; so 15:40:59 9 if his father were to shop there, then the shop would 15 :44: 57 10 like -- that is, like, in my understanding 15:41:03 10 know to send the bill to New York Golden Spring; so

11 :tvrr. Qiang Guo took care of his father. 15:4106 11 in other words his father's purchase was under

Q. So Mr. QiangGuowillbuysomethingforhis 15:41:08 12 12 Mr. Qiang Guo's profile.

13 dad, finance it.

15:41 :14 14 I meant. That is why I wanted the interpreter to

15 calling :tvrr. Qiang Guo and asking him? 15:41 :16 15 interpret for me.

A. Sometimes we do that, yes.

15:41 :19 16 BY MR. HARBACH:

Q. Okay. And when Mr. Qiang Guo is in the UK,

15:41 :21 Q. Thank you very much.

18 as you have told me is where he lives, how does that 15:41:27 And I do understand that example.

19 changethings? HowdoesMr.--Mr.HoWanKwokbuy

What about for groceries?

20 something while his son is in the UK?

A. (In English) Groceries, I mean, he lives in 15:45:33 A. What do you mean, change things? I mean,

21 21 his wife's house; so ifthere is any grocery needed

22 the shops obviously know Mr. Qiang Guo, whether he is 15:41 :43 22 to be purchased, it is for both of them; so what

23 in New York or not; so the father came and then 15:41:47 23 Golden Spring was requested to pull out, like,

24 shopping there. I mean, I don't know what is your 15 :41 :52 24 Mr. Ho Wan Kwok, his grocery purchase from his wife,

25 question, sir. 25 like a general purchase; so I mean, the husband, the

1 wife live together. He is living in his wife's 15:46:08 1 THE WITNESS: I don't know.

2 house. It doesn't make sense, like, he buy his own 15 :46: 11 2 MR. ROSEN: She testified numerous times

3 stuff, separate account. 15:46:14 3 that he is not authorized as a user of the card, and

4 Q. I understand that. 15:46:15 4 she has answered this question numerous times.

5 I'm just asking how the groceries are paid 15:46:16 5 MR. HARBACH: I don't believe she said -- it 15:48:32 6 for. 15:46:19 6 wasn't a question of whether he was an authorized

7 A. It paid by Golden Spring also. 15:46:21 7 user. I believe she said that he never used it.

8 Q. Same question as before. 15:46:26 8 BY MR. HARBACH:

9 Do they just go to a grocery store and the 15:46:29 9 Q. Does his wife use it?

10 grocery store sends the bill to Golden Spring? Or do 15:46:34 10 A. Usewhat?

11 they buy their groceries online? How does that work? 15:46:38 11 Q. The debit card or the credit card to buy

12 A. Grocery, most of them go with the debit 15:46:42 12 groceries?

13 card. 15:46:46 13 A. It is possible.

14 Q. Okay. 15:46:46 14 Q. Do you know one way or the other?

15:46:47 15 A. I mean, I don't live in their home; right?

15:46:50 16 Who is buying groceries? From my end, I can't see,

17 A. And buy online also, yes. 15:46:52 17 like, an Amazon purchase or, like, a Whole Foods

18 Q. Okay. And so even if the purchase is 15:46:53 18 purchase. Who uses those cards? I need to find out. 15:49:11 19 online, some sort of card, like if it is a debit card 15:46:56 19 Q. Okay. So it sounds like, from what you just 15:49:14 20 or a credit card, needs to be used; right? 15:47:03 20 said, it could have been Mr. Ho Wan Kwok's wife or it 15:49:19 21 A. Correct. 15:47:07 21 could have been Mr. Ho Wan Kwok, couldn't it?

22 Q. Okay. Who uses that card? 15:47:08 22 A. I'm not giving you an answer in here because 15:49:26 23 A. Who use that card? 15:47:10 23 I don't know.

24 They -- people. I mean, his wife use it 15:47:16 24 Q. That is what I'm getting at. You don't

25 also. 15:47:20 25 know.

15:47:20 From what you are looking at on the bill,

15:47:23 2 you don't know who used the card, do you? Do you?

3 Q. Does he ever use the card? 15:47:24 3 A. Youaretalkingaboutgrocery?

4 A. I don't think so. He doesn't read English 15:47:26 4 Q. I'm talking about the examples you just

15:47:30 5 gave, Whole Foods or whatever else.

6 Q. I mean, well, I don't know that you need to 15:47:31 6 When you see that on the bill, you just said 15:49:53 7 read English to use a credit card or a debit card. 15:47:33 7 you don't know who uses the card; correct?

8 Does he ever use the card to make purchases 15:47:37 8 A. The family uses the card. I do know. The

9 himself? 15:47:42 9 family uses the card.

10 A. Which time period you are asking about and 15:47:42 10 Q. Sure. Sure.

11 by what kind of purchase methods? 15:47:44 11 And Mr. Ho Wan Kwok is a member of the

15:47:44 12 family, isn't he?

13 A. If you are asking about online, he doesn't 15:47:47 13 A. Correct.

14 read English. 15:47:50 14 But he does not read English at all.

15 I mean, you have to be able to read English 15:47:51 15 Q. Okay. Does his wife?

16 to shopping online; right? 15:47:53 16 A. His wife what?

15:47:53 17 Q. Does his wife read English?

18 A. So with that, I can confirm he doesn't. 15:47:54 18 A. I don't believe so.

19 Q. Were -- well, number one, I'm pretty sure 15:47:55 19 MR. HARBACH: Okay. Give me just thirty

20 there are Websites in Chinese. 15:48:00 20 seconds, please.

21 And, number two, let's just stick with the 15:48:03 21 BY MR. HARBACH:

22 grocery example. 15:48:06 22 Q. Thank you for your patience. Hopefully

23 Does he ever use the credit card or the 15:48:11 23 I saved us a little time by taking that break. A few 15:53: 14 25 24 debit card to buy groceries?

MR. ROSEN: Objection. 15:48:19 25 24 cleanup questions, and I think we are finished.

1 Mr. Ho Wan Kwok is going to repay the \$21 million in

One -- one -- the famous one more question

2 litigation loans? 15:53:28 2 that we lawyers like to ask.

3 A. I don't have understanding. I mean, he need 15:53:30 3 BY MR. HARBACH:

4 to pay back those loans ifhe win the case and then, 15:53:38 Q. You have mentioned a couple of times that

5 I mean, I assume there will be some success, and then 15:53:42 5 Golden Spring has enough money to carry on its daily

6 he should pay back the loan. That is all my 15:53:46 6 operations.

7 understanding.

8 Q. Is there a Golden Spring (New York) owned 15:53:50 8 Golden Spring (New York) for those daily operations?

9 car that stays at Mr. and Ms. Kwok's residence? 15:53:54 9 The annual budget, say, approximately.

10 A. I don't recall. As I said, I am not a car

11 person. I mean, Mr. Qiang Guo will deal with the car 15:54:09 11 between -- I mean, operating mean paying the lease,

12 at that part. 15:54:13 12 paying the employees and office supplies, furniture,

13 Q. Well, doesn't Golden Spring (New York) 15:54:14 13 everything.

14 Limited pay for a chauffeur for Mr. Ho Wan Kwok?

Q. I'm asking, yeah, everything that you would

15 A. We pay the employees, yes. 15:54:23 15 lump under day-to-day operations, as you said

16 Q. Okay. And my question to you isn't about 15:54:26 16 earlier.

17 what kind of car it is.

A. I'm answering your question, sir.

18 I'm just asking whether there is a car and 15:54:32 It is anything and everything between annual 15:58:10

19 a chauffeur that is available to Mr. Kwok whenever he 15:54:35 19 lease between 2 to 3 million, at least-- at least

20 needs it. 15:54:39 20 the minimal.

21 A. I mean, Mr. Qiang Guo would -- does rent

22 a car for his father, and then Golden Spring pay the 15 :54: 50 22 questions.

23 chauffeur. That is what I can confirm. 15:54:53 MR. HARBACH: I don't know if any of the

24 Q. Okay. Do you have personal knowledge of who 15:54:58 24 other counsel who have endured this to this point

25 owns the residence where they live? 15:55:04 25 want to ask any questions.

I MR. HARBACH: Don't worry, Scott. 15:55:09 THE VIDEOGRAPHER: It doesn't sound like it. 15:58:39

2 I won't stay here long. 15:55:11 MR. HARBACH: All right. Well, Ms. Wang,

15:55:15 3 thank you very much for your time and your patience

4 knowledge? 15:55: 18 4 with my questions today.

5 BY MR. HARBACH: 15:55:19 THE VIDEOGRAPHER: We are offthe record at

6 Q. I'm asking if you know. 15:55:19 6 3:58 p.m.

And this concludes today's testimony given

8 yes-or-no answer. 15:55:26 8 by Yvette Wang as a 30(b)(6) witness for

15:55:26 9 Golden Spring (New York).

10 knowledge. 15:55:28 The total number of media units used was one 15:59:00

15:55:29 11 and will be retained by Veritext Legal Solutions.

12 a request, Scott, to supplement our earlier request 15:55:30 MR. HARBACH: This is David Harbach, of

13 for the loan documents. 15:55:39 13 O'Melveny & Myers, for Pacific Alliance.

14 I'm also going to request that Golden Spring 15:55:40 14

15 (New York) please promptly produce to us the 15:55:43 15 deposition exhibits with one additional exhibit that

16 notations in the books and records that the witness 15: 5 5: 50 16 will be called Exhibit 6.

17 referred to as evidencing the oral loans for

18 litigation.

19 Do you understand what I'm talking about? 15:56:04 MR. HARBACH: And it is the notice of

20 MR. ROSEN: I'm just taking notes right now. 15:56:07 20 deposition for today's witness. I have spoken to the 16:04:21 21 MR. HARBACH: Okay. 15:56:10 21 deponent's counsel, Mr. Rosen, and he does not object 16:04:25 22 MR. ROSEN: I believe I understand your 15:56: 13 22 to it being added as an exhibit.

23 question, and we will take that under advisement. 15:56: 15 MR. ROSEN: Can we put -- put it up on the

24 MR. HARBACH: Okay. Those are -- just -- 15:56:18 24 screen?

25 just one second, please.

MR. HARBACH: Yes. Yes.

My colleague is working on that right now.

2 THE REPORTER: Mr. Rosen, would you like 16:05:30 ) SS. 3 a copy of the transcript?

4 MR. ROSEN: Yes.

5 THE REPORTER: And would you like a rough?

6 MR. ROSEN: Yes. 16:06:14 5 I, B. Suzanne Hull, a Certified Shorthand 7 Copy to be delivered tonight. 16:06:22 6 Reporter in the State of California, holding 8 (4:28 p.m.) 7 Certificate Number 13495, du hereby certify Uial 9 --00000-- 8 YAN PING WANG, the witness named in the foregoing 10 9 deposition, was by me duly sworn; that said II 10 deposition, was taken Tuesday, April 12, 2022, at the 12 11 time and place set forth on the first page hereof. 13 12 That upon the taking of the deposition, the 13 words of the witness were written down hy me in 14 14 stenotypy and thereafter transcribed by computer

16 15 under my supervision; that the foregoing is a true 17 16 and correct transcript of the testimony given by the 17 witness. 18 18 Pursuant to Federal Rule 30( e ), transcript 19 19 review was requested. 20 20 I further certify that I am neither counsel 21 21 for nor in any way related to any party to said 22 22 action, nor in any way interested in the result or 23 23 outcome thereof.

1 STATE OF CALIFORNIA) 1 Dated this 12th day of April, 2022, at ) ss. 2 Bakersfield, California.

4 I, YAN PING WANG, do hereby certify: 4 Jj_ ~uzanne ttllll, L~.K l'W. 13495

7 That I have made such changes in form and/or 7 8 substance to the within deposition, as might be 8 9 necessary to render the same true and correct; 9 10 That having made such changes thereon, I 10 11 hereby subscribe my name to the deposition. 11 12 I declare, under penalty of perjury, that 12 13 the foregoing is true and correct. 13

goldenspringny@protonmail.com 2 YAN PING WANG, JOB NO. 5181285

APRIL 12, 2022, YAN PING WANG, JOB NO. 5181285 5

The above-referenced transcript has been 6 REASON

completed by Veritext Legal Solutions and --

review of the transcript is being handled as follows:

_ Per CA State Code (CCP 2025.520 (a)-(e))- Contact Veritext

to schedule a time to review the original transcript at

a Veritext office.

_ Per CA State Code (CCP 2025.520 (a)-(e))- Locked .PDF

Transcript - The witness should review the transcript and

make any necessary corrections on the errata pages included below, notating the page and line number of the corrections.

The witness should then sign and date the errata and penalty

of perjury pages and return the completed pages to all

appearing counsel within the period of time determined at

the deposition or provided by the Code of Civil Procedure.

_ Waiving the CA Code of Civil Procedure per Stipulation of

Counsel - Original transcript to be released for signature

_ Signature Waived - Reading & Signature was waived at the 23 time of the deposition.

_X_Federal R&S Requested (FRCP 30(e)(l)(B))-Locked .PDF

Transcript - The witness should review the transcript and

make any necessary corrections on the errata pages included below, notating the page and line number of the corrections.

The witness should then sign and date the errata and penalty of perjury pages and return the completed pages to all

appearing counsel within the period of time determined at

the deposition or provided by the Federal Rules.

_ Federal R&S Not Requested - Reading & Signature was not requested before the completion of the deposition.

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(e) Review By the Witness; Changes.

(1) Review; Statement of Changes. On request by the deponent or a party before the deposition is completed, the deponent must be allowed 30 days after being notified by the officer that the transcript or recording is available in which: (A) to review the transcript or recording; and (B) if there are changes in form or substance, to sign a statement listing the changes and the reasons for making them.

(2) Changes Indicated in the Officer's Certificate. The officer must note in the certificate prescribed by Rule 30 (f) (1) whether a review was requested and, if so, must attach any changes the deponent makes during the 30-day period.

DISCLAIMER: THE FOREGOING FEDERAL PROCEDURE RULES ARE PROVIDED FOR INFORMATIONAL PURPOSES ONLY. THE ABOVE RULES ARE CURRENT AS OF APRIL 1, 2019. PLEASE REFER TO THE APPLICABLE FEDERAL RULES OF CIVIL PROCEDURE FOR UP-TO-DATE INFORMATION.

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