Guo Wengui / Miles Guo — bankruptcy case · ORDER · ECF #404-28

Declaration of Laura Aronsson in Further Support of PAX's Motion to Dismiss Chapter 11 Case or, in the Alternative, Partial Joinder to United States Trustee's Motion for an Order Directing the Appointment of a Chapter 11 Trustee UNITED STATES BANKRUPTCY COURT DISTRICT OF CONNECTICUT BRIDGEPORT DIVISION

In re:

Chapter 11 Case No.

Debtor.

**DECLARATION OF LAURA S. ARONSSON IN FURTHER SUPPORT OF PACIFIC ALLIANCE ASIA OPPORTUNITY FUND L.P.'S MOTION TO DISMISS CHAPTER 11 CASE OR, IN THE ALTERNATIVE, PARTIAL JOINDER TO UNITED STATES TRUSTEE'S MOTION FOR AN ORDER DIRECTING THE APPOINTMENT OF A CHAPTER 11 TRUSTEE**

I, Laura S. Aronsson, declare:

1. I am an attorney admitted to practice law in the States of New York and California and am Counsel at the law firm of O'Melveny & Myers, 7 Times Square, New York, NY 10036, counsel for Pacific Alliance Asia Opportunity Fund L.P. ("PAX"). I respectfully submit this Declaration in support of PAX's Motion to Dismiss Chapter 11 Case, or in the

Alternative, Partial Joinder to United States Trustee ("Motion to Dismiss") [ECF 183].

2. In connection with these proceedings, PAX served discovery requests on several parties, including Golden Spring (New York) Limited ("Golden Spring") and Lamp Capital LLC ("Lamp Capital"). As relevant here, PAX sought documents and communications relating to the Debtor's Motion for Entry of Interim and Final DIP Orders (I) Authorizing the Debtor to Obtain Unsecured, Subordinated Postpetition Financing and (II) Scheduling Interim and Final Hearings, and (III) Granting Related Relief (the "DIP Motion") [ECF No. 117] and other litigation loans on

1 The last four digits of the Debtor's taxpayer identification number are 9595.

3. On March 29, 2022, PAX served document requests on Golden Spring seeking, among other things, "[a]ll Documents and Communications relating to Golden Spring's funding of any litigation in which the Debtor is a party." 3

4. Also on March 29, 2022, PAX served document requests on Lamp Capital seeking, among other things, "[a]ll Documents and Communications relating to any actual or contemplated transactions, transfers, distributions, or conveyances (including without limitation payments, loans, benefits, gifts, compensation, and income) made by Lamp Capital to, at the direction of, or for the benefit of the Debtor."4

5. In response to PAX's requests, Golden Spring made productions on April 8, 2022 and April 11, 2022, totaling approximately 25 documents. Counsel for PAX reviewed all documents Golden Spring produced, and Golden Spring did not produce any loan agreements between Golden Spring and the Debtor.

6. Lamp made productions on April 8, 2022 and May 9, 2022, totaling five pages. Counsel for PAX reviewed all documents Lamp Capital produced, and Lamp Capital did not produce any loan agreements between Lamp Capital and the Debtor.

7. On April 12, 2022, PAX deposed Golden Spring's Rule 30(b)(6) designee, Yanping Wang, in connection with the DIP Motion. At her deposition, Ms. Wang testified that she signed the debtor-in-possession financing loan agreement on behalf of Golden Spring and

2 See Debtor's Schedule F, ECF 78 (\$1,000,000 "litigation loan" from Lamp Capital LLC); id. (listing \$21 million "litigation funding" from Golden Spring).

3 See Request 1h, PAX's First Request for Production of Documents Directed to Golden Spring (New York) Limited dated March 29, 2022, attached hereto as Exhibit A.

4 See Request 1d, PAX's First Request for Production of Documents Directed to Lamp Capital LLC dated March 29, 2022, attached hereto as Exhibit B.

had it in her possession. 5 She also testified that she possessed documents and notes concerning litigation loans from Golden Spring to Kwok that totaled approximately \$21 million.6

8. During Ms. Wang's deposition, PAX requested that Golden Spring promptly produce the documents Ms. Wang referenced, 7 but PAX never received them.

/s/ Laura S. Aronsson Laura S. Aronsson laronsson@omm.com O'MELVENY & MYERS LLP 7 Times Square New York, NY 10036 Telephone: (212) 728-5841

Attorney for Pacific Alliance Asia Opportunity Fund L.P.

5 April 12, 2022 Dep. Tr. of Golden Spring Rule 30(b)(6) Corporate Representative Yanping Wang ("Wang Dep. Tr."), attached hereto as Exhibit C, at 185:8-17; 207:14-23.

6 Wang Dep. Tr. 185:8-17; 207:14-23.

7 Wang Dep. Tr. 185:8-17; 207:14-23.

UNITED STATES BANKRUPTCY COURT DISTRICT OF CONNECTICUT BRIDGEPORT DIVISION

------------------------------------------------------------ x

In re:

Debtor.

: ------------------------------------------------------------ x PACIFIC ALLIANCE ASIA OPPORTUNITY FUND L.P.'S FIRST REQUEST FOR PRODUCTION OF DOCUMENTS DIRECTED TO GOLDEN SPRING (NEW YORK) LIMITED

In response to the relief sought in the Debtor's *Motion for Entry of Interim and Final DIP Orders (I) Authorizing the Debtor to Obtain Unsecured, Subordinated Postpetition Financing and (II) Scheduling Interim and Final Hearings, and (III) Granting Related Relief* [ECF 117] (the "Debtor's DIP Motion"), Pacific Alliance Asia Opportunity Fund L.P. ("PAX") hereby requests the production of documents (the "Document Request") by Friday, April 1, 2022, and that the request be answered or responded to in writing by Golden Spring (New York) Limited ("Golden Spring") by Thursday, March 31, 2022.

- a. "Bankruptcy Code" means Title 11 of the United States Code. - b. "Communication" means the transmittal of information (in the form of facts, ideas, inquiries, or otherwise) and/or any other communicative contact between two or more Persons and/or entities, and shall include, without limitation: written contacts by such means as any Document as defined herein, and oral contact by such means as face-to-face or in-person meetings, telephone conversation, e-mail, and any other form of electronic communication such as telecopy transmissions, telexes, telegrams, and video

transmissions, and the originals, drafts, copies, and all non-identical copies of all Documents.

- c. "Debtor" refers to Miles Kwok a/k/a Kwok Ho Wan, a/k/a Kwok Ho, a/k/a Gwo Wen Gui, a/k/a Guo Wengui, a/k/a Guo Wen-Gui, a/k/a Wan Gue Haoyun, a/k/a Haoyun Guo. - d. The "Debtor's DIP Motion" refers to the Debtor's Motion for Entry of Interim and Final DIP Orders (I) Authorizing the Debtor to Obtain Unsecured, Subordinated Postpetition Financing and (II) Scheduling Interim and Final Hearings, and (III) Granting Related Relief filed by the Debtor on March 22, 2022 [ECF 117]. - e. The "Debtors' Proposed DIP Facility" refers to the debtor in possession financing proposed in the Debtors' Motion for Entry of Interim and Final DIP Orders (I) Authorizing the Debtor to Obtain Unsecured, Subordinated Postpetition Financing and (II) Scheduling Interim and Final Hearings, and (III) Granting Related Relief [ECF 117]. - f. The "Debtor's Schedules" refers to Debtor's bankruptcy Schedules AB, C, D, EF, G, H, I, and J, filed by the Debtor on March 9, 2022 [ECF 78]. - g. The "Debtor's Voluntary Bankruptcy Petition" refers to the Chapter 11 Voluntary Petition filed by the Debtor on February 15, 2022 [ECF 1]. - h. The "DIP Loan Agreement" refers to the Debtor-in-Possession Credit Agreement between Debtor and Golden Spring, filed as Exhibit C to Debtor's Motion for Entry of Interim and Final DIP Orders (I) Authorizing the Debtor to Obtain Unsecured, Subordinated Postpetition Financing and (II) Scheduling Interim and Final Hearings, and (III) Granting Related Relief [ECF 117]. - i. "Director," "officers," "member," "partner," "limited partner" or "agent" means any individual or entity serving as such presently or who served in such capacity at any relevant time, even though no longer serving in such capacity. - j. "Document" as used herein shall mean the original and all drafts and all copies, including copies with notations or marks not found on the original, of any writing or printed, graphic or electronic materials of any nature whatsoever, including, but not limited to, records, reports, memoranda, notes, calendar or diary entries, letters, envelopes, telegrams, telexes, e-mails, electronic mail messages, computer files, computerized records, telephone bills, checks, other written communications, messages (including, but not limited to, reports of telephone conversations and conferences), studies, summaries, tabulations, analyses, printed matter, minutes, photographs, tapes, tape recordings, correspondence, computer stored information, financial statements, worksheets, other communications, contracts, agreements, promissory notes, loan agreements, security agreements, guaranties, pledges, deeds of trust, mortgages, security interests filings, loan documents, other official documents and legal instruments, journals, manuals, technical releases, employment applications, agreements, orders, statements, checks, bank account statements, loan account statements, bills, invoices, receipts, vouchers, notebooks, data sheets and records kept or maintained by any means including electronically or by computer. In all cases where originals and/or non-identical copies are not available, the term "Document" also means identical copies of original documents and copies of non-identical copies. - k. "Document Request" refers to this First Request for Production of Documents directed to Golden Spring New York Limited. - l. "Golden Spring" or "You" refers to Golden Spring (New York) Limited.

i. as to a person (as defined): name, business and residence address(es), occupation, job title, and dates so employed; and, if not an individual, state the type of entity and the address of its principal place of business.

ii. as to a document: the type of document (letter, memo. etc.), the identity of the author or originator, the date authored or originated, the identity of each person to whom the original or copy was addressed or delivered, the identity of such person known or reasonably believed by you to have present possession, custody, or control thereof, and a brief description of the subject matter thereof, all with sufficient particularity to request its production under Rule 34 of the Federal Rules of Civil Procedure.

iii. as to a communication: the date of the communication, the type of communication (telephone conversation, meeting, etc.), the place where the communication took place, the identity of the person who made the communication, the identity of each person who received the communication, and of each person present when it was made, and the subject matter discussed.

iv. as to a meeting: the date of the meeting, the place of the meeting, each person invited to attend, each person who attended, and the subject matter discussed.

- n. "Including" means including, but not limited to. - o. "Or" means "and/or" and is used in the inclusive sense. - p. "Person" includes natural persons, as well as corporations, proprietorships, limited liability companies, partnerships, joint ventures, associations, combinations, unions, governmental bodies and agencies, and any and all other entities. - q. The "Petition Date" means February 15, 2022. - r. "Referring to" as used herein shall mean commenting on, responding to, mentioning, containing, constituting, showing, memorializing, describing, analyzing, reflecting, pertaining to, identifying, or discussing. - s. "Relating to" as used herein shall mean concerning, being connected to, commenting on, responding to, containing, constituting, showing, memorializing, describing, analyzing,

reflecting, pertaining to, compromising, identifying, discussing or otherwise establishing reasonable, logical or causal connection to.

- t. This Document Request is propounded in response to the Debtor's Motion for Entry of Interim and Final DIP Orders (I) Authorizing the Debtor to Obtain Unsecured, Subordinated Postpetition Financing and (II) Scheduling Interim and Final Hearings, and (III) Granting Related Relief [ECF 117]. - a. Each response to each separately numbered Document Request is to be set forth separately. Document Requests should not be combined for the purpose of supplying a common response, but responses may be supplied by reference to the response to another Document Request. - b. This Document Request is continuing in character so as to require Golden Spring to make supplementary production of Documents if they obtain further or different information or Documents. - c. Where a Document Request cannot be answered to in full, state why and furnish all available information. If any Document responsive to a request has been lost, discarded, destroyed or is otherwise unavailable identify the Document as completely as possible, including if the Document has been lost, the last known location of the Document and the Person who had last possession, custody, access or control over the Document, or, if the Document has been discarded or destroyed, the date of such action, the Person authorizing such action, the Person actually destroying or disposing of the Document and the reason for the destruction or disposal of the Document. - d. Production of Documents pursuant to the Document Request must include all Documents available to Golden Spring and Golden Spring's members, agents, attorneys, investment bankers, consultants, accountants, insurers or others who have Documents available to it upon inquiry of them. - e. If Golden Spring does not have any Documents in its possession, custody, access or control that are responsive to a particular Document Request, Golden Spring's response to that Document Request should indicate unambiguously that they do not have any Documents responsive to the Document Request, or that there are not any Documents responsive to that Document Request. - f. Where knowledge, information, or Documents in the possession of a party or entity is requested, such Document Request includes any knowledge, information, or Documents of Golden Spring's members, agents, representatives, accountants, advisors, investment bankers, employees, and, unless privileged, its attorneys. - g. Where the name or identity of a Person is requested, state the Person's full name, home address, business address, home telephone number and business telephone number and include the Person's title or occupation and each of the positions held by such Person during the applicable time covered by any answer referring to such Persons. - h. Where the identity of a Document is requested, state the date of the Document, its author and addressee, the present location and custodian of said Document and give a description of the general contents of the Document. - i. Where the identity of a Communication is requested, identify the Person generating the Communication, the recipient of the Communication, the date and location of the

Communication, and give a description of the general contents of the Communication. Also, identify all Persons present when the Communication was made.

- j. The plural of any word shall include the singular form of that word and vice versa. - k. The masculine form of a word shall include the feminine form of that word and vice versa. - l. The use of the past tense includes the present tense and the use of the present tense includes the past tenses so as to make each request inclusive rather than exclusive. - m. If a privilege is claimed with respect to any Document Request, state the nature of the privilege claimed, basis for the claim, and for Documents, a summary of the Documents' contents, their location and custodian and the identity of Persons having access or having had access to such Documents. - n. If You do not produce any Document because of a claim of privilege, set forth the privilege claimed, the facts upon which You rely to support the claim of privilege, and identify all documents for which such privilege is claimed. - o. Unless otherwise agreed by both PAX and Golden Spring, the production of documents shall be made at the offices of O'Melveny & Myers LLP, Times Square Tower, 7 Times Square, New York, New York 10036, on Friday, April 1, 2022. - p. Unless otherwise specified, this Document Request seeks all Documents from February 10, 2022 to the date of this Document Request.

1. PAX demands that Golden Spring produce at the date and location stated above, or at a time and location mutually agreeable to the parties, all (whether in hard copy or digital) books, records, communications, (including, but not limited to, e-mail, text message, electronic messaging, mail, fax and the like), and papers as follows:

a. All Documents and Communications relating to the DIP Loan Agreement.

b. All Documents relied upon by Golden Spring when negotiating and executing the DIP Loan Agreement.

c. All Documents and Communications with the Debtor or any of the Debtor's agents relating to the Debtor's Voluntary Bankruptcy Petition.

d. All Documents and Communications relating to any actual or contemplated transactions, transfers, distributions, or conveyances (including without limitation payments, loans, benefits, gifts, compensation, and income) made by Golden Spring to, at the direction of, or for the benefit of the Debtor.

e. All Documents and Communications relating to any security interest pledged by the Debtor to Golden Spring.

f. All Documents and Communications relating to the anticipated sources of repayment of the DIP Loan Agreement.

g. All Documents and Communications relating to the anticipated use of the proceeds of the DIP Loan Agreement.

h. All Documents and Communications relating to Golden Spring's funding of any litigation in which the Debtor is a party.

i. Documents sufficient to identify ownership of Golden Spring.

j. Documents sufficient to identify all employees, officers and directors of Golden Spring.

k. Documents sufficient to identify the source of any funds being used to fund the DIP

Loan Agreement.

> /s/ Peter Friedman O'MELVENY & MYERS LLP Peter Friedman (pfriedman@omm.com) Stuart Sarnoff (ssarnoff@omm.com) Times Square Tower 7 Times Square New York, New York 10036 Telephone: (212) 326-2000

Attorneys for Pacific Alliance Asia Opportunity Fund L.P.

UNITED STATES BANKRUPTCY COURT DISTRICT OF CONNECTICUT BRIDGEPORT DIVISION

------------------------------------------------------------ x In re: : : :

Debtor.

: ------------------------------------------------------------ x PACIFIC ALLIANCE ASIA OPPORTUNITY FUND L.P.'S FIRST REQUEST FOR PRODUCTION OF DOCUMENTS DIRECTED TO LAMP CAPITAL LLC

In connection with Pacific Alliance Asia Opportunity Fund L.P.'s Motion to Dismiss

: :

Chapter 11 Case or, in the Alternative, Partial Joinder to United States Trustee's Motion for an

Order Directing the Appointment of a Chapter 11 Trustee [ECF 183] (the "Motion to Dismiss"),

Pacific Alliance Asia Opportunity Fund L.P. ("PAX") hereby requests the production of

documents (the "Document Request"), and that the request be answered or responded to in

writing by Lamp Capital LLC ("Lamp Capital"), by Monday, May 2, 2022.

- a. "Bankruptcy Code" means Title 11 of the United States Code. - b. The "Chapter 11 Proceedings" means In re Ho Wan Kwok, Case No. 22-50073 (Bankr. D. Conn.) - c. "Communication" means the transmittal of information (in the form of facts, ideas, inquiries, or otherwise) and/or any other communicative contact between two or more Persons and/or entities, and shall include, without limitation: written contacts by such means as any Document as defined herein, and oral contact by such means as face-to-face or in-person meetings, telephone conversation, e-mail, and any other form of electronic

communication such as telecopy transmissions, telexes, telegrams, and video transmissions, and the originals, drafts, copies, and all non-identical copies of all Documents.

- d. "Debtor" refers to Miles Kwok a/k/a Kwok Ho Wan, a/k/a Kwok Ho, a/k/a Gwo Wen Gui, a/k/a Guo Wengui, a/k/a Guo Wen-Gui, a/k/a Wan Gue Haoyun, a/k/a Haoyun Guo. - e. "Director," "officers," "member," "partner," "limited partner" or "agent" means any individual or entity serving as such presently or who served in such capacity at any relevant time, even though no longer serving in such capacity. - f. "Document" as used herein shall mean the original and all drafts and all copies, including copies with notations or marks not found on the original, of any writing or printed, graphic or electronic materials of any nature whatsoever, including, but not limited to, records, reports, memoranda, notes, calendar or diary entries, letters, envelopes, telegrams, telexes, e-mails, electronic mail messages, computer files, computerized records, telephone bills, checks, other written communications, messages (including, but not limited to, reports of telephone conversations and conferences), studies, summaries, tabulations, analyses, printed matter, minutes, photographs, tapes, tape recordings, correspondence, computer stored information, financial statements, worksheets, other communications, contracts, agreements, promissory notes, loan agreements, security agreements, guaranties, pledges, deeds of trust, mortgages, security interests filings, loan documents, other official documents and legal instruments, journals, manuals, technical releases, employment applications, agreements, orders, statements, checks, bank account statements, loan account statements, bills, invoices, receipts, vouchers, notebooks, data sheets and records kept or maintained by any means including electronically or by

computer. In all cases where originals and/or non-identical copies are not available, the term "Document" also means identical copies of original documents and copies of nonidentical copies.

- g. "Document Request" refers to this First Request for Production of Documents directed to Lamp Capital.

- i. as to a person (as defined): name, business and residence address(es), occupation, job title, and dates so employed; and, if not an individual, state the type of entity and the address of its principal place of business. - ii. as to a document: the type of document (letter, memo. etc.), the identity of the author or originator, the date authored or originated, the identity of each person to whom the original or copy was addressed or delivered, the identity of such person known or reasonably believed by you to have present possession, custody, or control thereof, and a brief description of the subject matter thereof, all with sufficient particularity to request its production under Rule 34 of the Federal Rules of Civil Procedure. - iii. as to a communication: the date of the communication, the type of communication (telephone conversation, meeting, etc.), the place where the communication took place, the identity of the person who made the communication, the identity of each person who received the communication, and of each person present when it was made, and the subject matter discussed. - iv. as to a meeting: the date of the meeting, the place of the meeting, each person invited to attend, each person who attended, and the subject matter discussed. - i. "Including" means including, but not limited to. - j. "Lamp Capital", "You", and "Your" means Lamp Capital LLC and each of its members,

directors, officers, employees, agents, representatives and advisors.

- k. "Or" means "and/or" and is used in the inclusive sense. - l. "Person" includes natural persons, as well as corporations, proprietorships, limited liability companies, partnerships, joint ventures, associations, combinations, unions, governmental bodies and agencies, and any and all other entities. - m. "Proposed Plan of Reorganization" refers to The Proposed Chapter 11 Plan of Ho Wan Kwok [ECF 197]. - n. "Relating to" as used herein shall mean concerning, being connected to, commenting on, responding to, containing, constituting, showing, memorializing, describing, analyzing, reflecting, pertaining to, compromising, identifying, discussing or otherwise establishing reasonable, logical or causal connection to. - o. The "Sherry Netherland" refers to Unit 1801 of the Sherry-Netherland Hotel, located at 781 5th Avenue, New York, New York, 10022, including the corresponding ownership interest in shares of The Sherry-Netherland and the assignment of the proprietary lease agreement for Unit 1801.

- a. This Document Request is propounded in furtherance of Pacific Alliance Asia Opportunity Fund L.P.'s *Motion to Dismiss Chapter 11 Case or, in the Alternative, Partial Joinder to United States Trustee's Motion for an Order Directing the Appointment of a Chapter 11 Trustee* [ECF 183]. - b. Each response to each separately numbered Document Request is to be set forth separately. Document Requests should not be combined for the purpose of supplying a common response, but responses may be supplied by reference to the response to another Document Request. - c. This Document Request is continuing in character so as to require Lamp Capital to make supplementary production of Documents if they obtain further or different information or Documents. - d. Where a Document Request cannot be answered to in full, state why and furnish all available information. If any Document responsive to a request has been lost, discarded, destroyed or is otherwise unavailable identify the Document as completely as possible, including if the Document has been lost, the last known location of the Document and the Person who had last possession, custody, access or control over the Document, or, if the Document has been discarded or destroyed, the date of such action, the Person authorizing such action, the Person actually destroying or disposing of the Document and the reason for the destruction or disposal of the Document. - e. Production of Documents pursuant to the Document Request must include all Documents available to Lamp Capital and Lamp Capital's members, agents, attorneys, investment bankers, consultants, accountants, insurers or others who have Documents available to it upon inquiry of them. - f. If Lamp Capital does not have any Documents in its possession, custody, access or control that are responsive to a particular Document Request, Lamp Capital's response to that Document Request should indicate unambiguously that they do not have any Documents responsive to the Document Request, or that there are not any Documents responsive to that Document Request. - g. Where knowledge, information, or Documents in the possession of a party or entity is requested, such Document Request includes any knowledge, information, or Documents of Lamp Capital's members, agents, representatives, accountants, advisors, investment bankers, employees, and, unless privileged, its attorneys. - h. Where the name or identity of a Person is requested, state the Person's full name, home address, business address, home telephone number and business telephone number and

include the Person's title or occupation and each of the positions held by such Person during the applicable time covered by any answer referring to such Persons.

- i. Where the identity of a Document is requested, state the date of the Document, its author and addressee, the present location and custodian of said Document and give a description of the general contents of the Document. - j. Where the identity of a Communication is requested, identify the Person generating the Communication, the recipient of the Communication, the date and location of the Communication, and give a description of the general contents of the Communication. Also, identify all Persons present when the Communication was made. - k. The plural of any word shall include the singular form of that word and vice versa. - l. The masculine form of a word shall include the feminine form of that word and vice versa. - m. The use of the past tense includes the present tense and the use of the present tense includes the past tenses so as to make each request inclusive rather than exclusive. - n. If a privilege is claimed with respect to any Document Request, state the nature of the privilege claimed, basis for the claim, and for Documents, a summary of the Documents' contents, their location and custodian and the identity of Persons having access or having had access to such Documents. - o. If You do not produce any Document because of a claim of privilege, set forth the privilege claimed, the facts upon which You rely to support the claim of privilege, and identify all documents for which such privilege is claimed.

- p. Unless otherwise agreed by both PAX and Lamp Capital, the production of documents shall be made at the offices of O'Melveny & Myers LLP, Times Square Tower, 7 Times Square, New York, New York 10036, on May 2, 2022 at 12:00pm. - q. Unless otherwise specified, this Document Request seeks all Documents from January 1, 2014 to the date of this Document Request.

1. PAX demands that Lamp Capital produce at the date and location stated above, or at a time and location mutually agreeable to the parties, all (whether in hard copy or digital) books, records, communications, (including, but not limited to, e-mail, text message, electronic messaging, mail, fax and the like), and papers as follows:

a. Documents sufficient to identify ownership of Lamp Capital.

b. All Documents and Communications relating to the initial funding of Lamp Capital.

c. All Documents and Communications relating to any payments made in connection with the Sherry Netherland from January 1, 2015 until the present.

d. All Documents and Communications relating to any actual or contemplated transactions, transfers, distributions, or conveyances (including without limitation payments, loans, benefits, gifts, compensation, and income) made by Lamp Capital to, at the direction of, or for the benefit of the Debtor.

e. All Communications between Lamp Capital and the Debtor relating to the Proposed Plan of Reorganization.

> /s/ Peter Friedman O'MELVENY & MYERS LLP Peter Friedman (pfriedman@omm.com) Stuart Sarnoff (ssarnoff@omm.com) Times Square Tower 7 Times Square New York, New York 10036 Telephone: (212) 326-2000

Attorneys for Pacific Alliance Asia Opportunity Fund L.P.

In re: )Case No.

Debtor.

25 Reported by:

5 Ho Wan Kwok: By MR. BENNETT S. SILVERBERG MR. KENNETH AULET 6 Attorneys at Law Times Square Tower 7 7 Times Square New York, New York 10036 8 (212) 209-4924 (212) 209-4950 9 bsilverberg@brownrudnick.com kaulet@brownrudnick.com 11 For Creditor Pacific O'Melveny & Myers

Alliance Asia By MR. DAVID V. HARBACH II 12 Opportunity Fund, Attorney at Law L.P.: 1625 Eye Street NW 13 Washington, DC 20006 (202) 383-5127 14 dharbach@omm.com - and - 15 By MR. STUART M. SARNOFF MS. AISLING MURRAY 16 Attorneys at Law Times Square Tower 17 7 Times Square New York, New York 10036 18 (212) 326-2293 (212) 728-5831 19 ssarnoff@omm.com amurray@omm.com 20 21 For Creditor Cohn Birnbaum Shea

Golden Spring By MR. SCOTT D. ROSEN 22 (New York) Limited: Attorney at Law 100 Pearl Street 23 Hartford, Connecticut 06103 (860) 493-2220 24 srosen@cbshealaw.com

4 For United States United States Department of

7 Washington, DC 20005 (202) 514-2000 8 holley.l.claiborn@usdoj.gov 10 For the Committee on Pullman & Comley Secured Creditors: By MR. JONATHAN KAPLAN 11 Attorney at Law 90 State House Square 12 Hartford, Connecticut 06103 (860) 424-4379

16 The Videographer: Jeffrey Nichols 17 The Interpreter: Sunny Johnston (Mandarin) 18 The Check Una Wilkinson (Mandarin) Interpreter:

12 Exhibit 1 - Transcript of testimony of 19

16 Exhibit 2 - Trial transcript, dated 28

19 Exhibit 3 - Director and officer register, 43

23 Exhibit 4 - Affidavit of Yan Ping Wang, 55

3 Exhibit 5 - Exhibit B, Golden Spring 166

9 Exhibit 6 - Pacific Alliance Asia 209

2 ANSWER:

2 Tuesday, April 12, 2022; 9:15 a.m.

5 THE VIDEOGRAPHER: Good morning. 6 We are going on the record at 9:15 a.m. on 09:15:21

8 This is media unit one of the video-recorded 09:15:27 9 deposition of Yvette Wang as a 30(b)(6) witness for 09:15:31 10 Golden Spring (New York), taken by 09:15:37 11 Creditor Pacific Alliance In Re: Ho Wan Kwok, filed 09:15:39 12 in the United States Bankruptcy Court, District of 09:15:42 13 Connecticut, Bridgeport Division.

15 This deposition is being held virtually via 09:15:50

17 My name is Jeff Nichols, from the firm 09:15:57 18 Veritext Legal Solutions, and I am the videographer. 09:15:59 19 The court reporter is Suzanne Hull, from the firm 09:16:02

21 Counsel will now please state their 09:16:07 22 appearances and affiliations for the record. 09:16:10 23 MR. HARBACH:

24 I'm David Harbach, with O'Melveny & Myers, 09:16:15 25 and I represent Pacific Alliance. 09:16:19

1 MR. ROSEN:

2 Scott Rosen, Cohn Birnbaum & Shea, 09:16:24 3 representing Golden Spring (New York). 09:16:28 4 MR. KAPLAN:

5 Pullman & Comley, representing the Committee of 09:16:36

7 MR. AULET: Kenneth Aulet, of Brown Rudnick, 09:16:40 8 representing the debtor, Ho Wan Kwok. 09:16:43 9 MR. SILVERBERG:

10 Brown Rudnick, representing the debtor. 09:16:49 11 MS. RUSSO:

12 O'Melveny & Myers, representing Pacific Alliance. 09:16:56 13 MR. SARNOFF:

15 MS. CLAIBORN:

17 THE VIDEOGRAPHER:

18 Will the court reporter please swear in both 09:17:06 19 interpreters and then the witness. 09:17:09 20 THE REPORTER:

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

1 duly sworn to interpret the proceedings to the best 2 of her abilities and interpreted as follows: 3 09:17:20 4 THE INTERPRETER: Yes, I do. 09:17:20 5 THE REPORTER: Raise your right hand, 09:17:25 6 please, Check Interpreter. 09:17:27 7 8 UNA WILKINSON, 9 having been called as an interpreter to interpret 10 English into Mandarin and Mandarin into English, was 11 duly sworn to interpret the proceedings to the best 12 of her abilities and interpreted as follows: 13 09:17:42 14 THE CHECK INTERPRETER: Yes, I do. 09:17:42 15 THE REPORTER: Raise your right hand please, 16 Witness. 17 18 YAN PING WANG, 19 called as a 30(b)(6) Corporate Representative by 20 counsel for Creditor Pacific Alliance Asia 21 Opportunity Fund, L.P., being first duly sworn, 22 testified as follows: 23 09:17:59 24 THE WITNESS: Yes. 09:17:59 25 THE REPORTER: Okay. State credentials, 09:18:02 Page 9

2 THE INTERPRETER:

4 Court certified Mandarin interpreter, 09:18:10 5 California State Certified Interpreter 09:18:13 6 Sunny Johnston. Certification number is 301314. 09:18:14 7 THE REPORTER:

9 THE CHECK INTERPRETER:

10 interpreter for Mandarin and English, and 09:18:26 11 a court-certified interpreter for the Unified Court 09:18:29

13 THE REPORTER:

14 THE VIDEOGRAPHER:

19 Q.

20 My name is David Harbach, as you just heard. 09:18:44 21 And a couple housekeeping matters before we 09:18:50

6 Sunny Johnston. Certification number is 301314. 09:18:14 7 THE REPORTER: Check Interpreter, 09:18:18 8 credentials, please. 09:18:22 9 THE CHECK INTERPRETER: I am the check 09:18:25 10 interpreter for Mandarin and English, and 09:18:26 11 a court-certified interpreter for the Unified Court 09:18:29 12 System in New York state. 09:18:33 13 THE REPORTER: Thank you. 09:18:36 14 THE VIDEOGRAPHER: Thank you. 09:18:37 15 You may proceed, Counsel. 09:18:37 16 09:18:37 17 EXAMINATION 09:18:40 18 BY MR. HARBACH: 09:18:40 19 Q. Good morning, Ms. Wang. 09:18:41 20 My name is David Harbach, as you just heard. 09:18:44 21 And a couple housekeeping matters before we 09:18:50 22 get started. 09:18:53 23 Are you able to hear -- are you able to hear 09:18:54 24 me okay? 09:18:55 25 A. Yes. 09:19:09 Page 10

2 Q. I'm aware that you had given depositions in 09:19:12

4 Would you be comfortable proceeding in 09:19:18

6 A. Okay. My mother tongue is not English, but 09:19:37 7 I can try to go through the deposition in English; 09:19:54 8 however, I do need the interpreter stand by in case 09:19:57 9 I don't understand anything. 09:20:00 10 Q. That -- that sounds perfect, and that is 09:20:02 11 just fine with us; so we can proceed in English.

12 if you have a question or you would like a question 09:20:10 13 translated into Mandarin or if you would like an 09:20:13 14 answer translated into Mandarin, please just say so, 09:20:20

17 A. Okay.

19 Q. Okay.

20 And just a few more things.

21 doing this deposition remotely, it is very important 09:20:59 22 for the court reporter that only one person be 09:21:03

25 A.

Yes, I do.

2 So if you would, please wait for me to 09:21:18

3 finish my question before you start answering, and 09:21:21

4 I'll do my best to wait for you to stop speaking 09:21:24

5 before I ask my next question. 09:21:28

Okay.

A. Q.

10 And as I said a moment ago, if there is 09:21:35

11 a question that you do not understand, please just 09:21:40 12 let me know, and I'm happy to try and rephrase it. 09:21:43 13 And if there is a question that you would prefer be 09:21:48 14 translated in order to answer it, that is no problem. 15 That is what Ms. Johnston is here for. 09:21:56

17 A.

19 Q. Okay. Are you on any medication or -- 09:22:02 20 MR. ROSEN:

21 stipulations as to objections and signing. 09:22:13

23 MR. HARBACH:

25 MR. ROSEN: The usual stipulations?

1 objections reserved to trial except for form? 09:22:27

2 MR. HARBACH: Yeah. That's okay with me. 09:22:32

2 MR. HARBACH: Yeah.

3 MR. ROSEN: Okay.

4 to waive the signing and reading of the transcript. 09:22:38 5 MR. HARBACH:

7 MR. ROSEN:

8 The witness will not waive the signing and 09:22:46

10 MR. HARBACH: Okay.

12 Q. Ms. Wang, I was just about to ask you if you 09:22:58 13 are on any medication or under the influence of 09:23:01 14 any- -- anything that might impair your memory or 09:23:05 15 interfere with your ability to answer questions 09:23:09

17 A.

18 Q. Is there any reason you can think of why you 09:23:17 19 cannot provide truthful testimony today? 09:23:20 20 A. I don't think there is any reason, sir. 09:23:24 21 Q. Okay.

22 I believe you have been deposed at least 09:23:30 23 once before in October of 2018 in litigation 09:23:37

25 Do you recall that deposition? 09:23:46

1 A. I remember I was deposed before, but I don't 09:23:48

2 recollect the -- the dates -- the precise dates. 09:23:56

4 Other than that deposition where PAX 09:24:00 5 examined you, have you been deposed in any other 09:24:09 6 litigation since then? 09:24:13 7 A. Sir, since -- since then? You mean since 09:24:15 8 when? 09:24:19 9 Q. Well, I'll represent to you that the 09:24:20 10 deposition that PAX conducted of you was in October 09:24:23 11 of 2018. 09:24:26 12 And my question is have you been deposed 09:24:30 13 since then? 09:24:33 14 A. I believe so. 09:24:34 15 Q. And do you recall when? 09:24:37 16 A. I don't recall. 09:24:44 17 Q. In what proceeding? 09:24:45 18 A. It was in a case called Strategic Vision, 09:24:49 19 Eastern Profits -- or Eastern Profits, Strategic 09:24:57 20 Vision. It should be the same case. 09:25:02 21 Q. Okay. And in -- in what course is that 09:25:04 22 case, if you know? 09:25:07 23 A. In a court in New York. 09:25:08 24 Q. Okay. Any other depositions, besides that 09:25:11 25 one, since October of 2018? 09:25:20 Page 14

2 Q. Do you understand that you are here today as 09:25:27

3 a corporate representative of Golden Spring 09:25:35

5 A.

6 Q. Did you review the topics that we intend to 09:25:42 7 cover with you today that were contained in the 09:25:48 8 deposition notice before your testimony today? 09:25:51 9 A.

11 Q. Okay. What did you do to prepare -- excuse 09:26:01 12 me -- prepare for your deposition today, generally 09:26:05

14 A. I prepared with our law firm -- with our 09:26:09

16 Q. Okay.

17 A.

19 Q. Did you meet with any other personnel at 09:26:24 20 Golden Spring to prepare for your deposition today? 09:26:29 21 A.

22 What do you mean?

24 Q. Well, a moment ago you said that the law 09:26:43 25 firm assisted you in preparing for today. 09:26:49

1 A.

2 Q. Did you meet with them in person to do that 09:26:52

4 A.

5 Due to COVID, I meet our counsels via -- via 09:26:59

7 Q.

8 Did you have communications with anyone else 09:27:08 9 at Golden Spring -- via telephone, videoconference, 09:27:11 10 or otherwise -- to prepare for today's deposition? 09:27:17 11 MR. ROSEN:

12 The witness can answer without disclosing 09:27:25 13 any conversations with either inhouse counsel or 09:27:28

15 THE WITNESS:

16 Can you repeat your question? 09:27:37

18 Q.

19 It was a yes-or-no question that did not 09:27:41 20 call for any -- any privileged information. 09:27:43 21 The question is did you meet with any 09:27:46 22 personnel at Golden Spring -- via telephone, Zoom, 09:27:50 23 videoconference or otherwise -- to prepare for your 09:27:57

25 A.

1 Q. With whom did you communicate at 09:28:05

2 Golden Spring to prepare for your deposition today? 09:28:08 3 A. I communicated with the owner of 09:28:11 4 Golden Spring (New York) Limited, Mr. Qiang Guo.

5 me spell, Q-i-a-n-g, last name G-u-o. 09:28:25 6 Q. How much time did you spend communicating 09:28:32

8 A. How much time?

9 like, fifteen minutes -- ten, fifteen minutes. 09:28:49 10 Q. Is there anyone else at Golden Spring with 09:28:52 11 whom you communicated to prepare for today's 09:28:55

13 A.

14 Q. Is there anyone else in the world, other 09:28:58 15 than attorneys, with whom you communicated to prepare 09:29:01

17 A.

18 Q. What is the name of -- withdrawn. 09:29:09 19 A moment ago, when you said you met with 09:29:26 20 lawyers to prepare for today's deposition, lawyers 09:29:29

22 A. Attorneys from Mr. Scott Rosen's firm. 09:29:37 23 I couldn't pronounce his law firm's name.

24 be -- I mean, it is complicated for me to pronounce 09:29:49 25 his law firm's name; so Mr. Scott Rosen and his 09:29:55

1 colleague, Mr. Timothy -- Tim. 09:29:59 2 Q. Tim Miltenberger? 09:30:01 3 A. I believe so. I don't remember his last 09:30:05 4 name. It sounds like it correct. 09:30:07 5 Q. Okay. Did you meet or consult with any 09:30:09 6 lawyers from the Brown Rudnick firm to prepare for 09:30:13 7 today's deposition? 09:30:23 8 A. No, I didn't. 09:30:24 9 Q. When was Golden Spring (New York) Limited 09:30:27 10 formed? 09:30:40 11 A. Golden Spring (New York) Limited was formed 09:30:40 12 in the year of 2015. 09:30:45 13 Q. Does March 2015 sound about right to you? 09:30:47 14 A. In March, yes. 09:30:54 15 Q. What is Golden Spring (New York)'s 09:30:59 16 relationship to Golden Spring (Hong Kong)? 09:31:03 17 A. Golden Spring (New York) Limited is 09:31:09 18 100 percent owned by China Golden Spring (Hong Kong). 09:31:15 19 Q. And for purposes of today's deposition, I'm 09:31:21 20 going to refer to China Golden Spring (Hong Kong) as 09:31:27 21 just Golden Spring (Hong Kong). 09:31:33 22 Is that okay with you? 09:31:36 23 A. Yes. 09:31:37 24 Q. Okay. Did you ever work at Golden Spring 09:31:39 25 (Hong Kong)? 09:31:45 Page 18

1 A.

2 Q. Do you recall when you worked there? 09:31:50 3 A. That was back to 2016 for, like, a couple of 09:31:53

5 Q. Okay. I would like to show you what I'm 09:32:07

7 (Deposition Exhibit Number 1 09:32:29 8 was marked for identification.) 09:32:29 9 MR. HARBACH:

10 for my colleague to drop it in there.

11 tight, everybody.

12 Sorry for the delay. We are working on it.

13 to be a little slow.

14 Ms. Russo is telling me it should be in 09:34:30 15 there, but I don't see it in my marked exhibits 09:34:33

18 MR. KAPLAN: There -- there are two folders. 09:34:42 19 It looks like it is in the second one. 09:34:45 20 MR. HARBACH: Okay.

21 MR. ROSEN:

22 MR. HARBACH:

23 MR. ROSEN:

24 MR. HARBACH:

25 on -- on my computer.

1 the -- the second one that says deposition of 09:35:07 2 Yvette Wang. 09:35:11 3 MR. ROSEN: Counsel, before you proceed with 09:35:11 4 the question, could you please explain to me which of 09:35:13 5 the 30(b)(6) topics this document pertains to. 09:35:17 6 MR. HARBACH: Well, it could be -- it could 09:35:23 7 be any number of them because the document is the 09:35:25 8 transcript of her prior deposition; so it will be 09:35:29 9 multiple such topics. 09:35:33 10 MR. ROSEN: I'll reserve the right to object 09:35:36 11 and instruct the witness not to answer if it exceeds 09:35:38 12 the scope of the 30(b)(6). 09:35:42 13 But go ahead and proceed. 09:35:43 14 MR. HARBACH: Understood. 09:35:46 15 Is there anyone who can't see the exhibit in 09:35:49 16 their marked exhibits folder before I go on? 09:35:51 17 BY MR. HARBACH: 09:35:59 18 Q. Okay. Ms. Wang, can you see it? 09:36:00 19 A. Sir, I can see a .pd- -- it says .pdf file 09:36:03 20 with forty-two pages. 09:36:07 21 Q. You got it? 09:36:09 22 A. This is the one? 09:36:11 23 Got it. Okay. 09:36:12 24 Q. Yes, ma'am. 09:36:13 25 Please open that one up. 09:36:15 Page 20

1 A.

3 Q. So just to refresh your recollection before 09:36:19 4 I proceed, the question I put to you concerned the 09:36:22 5 dates that you worked at Golden Spring (Hong Kong). 09:36:25 6 And I believe you said that it was approximately 09:36:31 7 2016. And I just want to show you in the deposition 09:36:36 8 in 2018 where you were asked about this.

9 what you said, and then ask the question again. 09:36:49 10 So I -- can I direct your attention to page 09:36:52

12 A.

13 Q. Let me know when you are there. 09:37:02 14 A. Page thirty, three, zero, sir; right? 09:37:09 15 Q. Yes, ma'am.

16 And it is the -- you know, page thirty of 09:37:18

18 Do you see how each of the miniature pages 09:37:23

20 A.

21 What do you mean, miniature pages?

23 Q.

24 Each page of the document that I just sent 09:37:41 25 you has four pages of the transcript on it. 09:37:44

2 A.

2 A.

3 Q. Okay. So those are the page numbers that 09:37:48 4 I am referring to. And on page thirty, at line ten, 09:37:52 5 you were asked a question that reads: 09:38:03 6 "QUESTION:

7 in 2015 to work in September of 2015 to work 09:38:07 8 for Golden Spring (Hong Kong)?" 09:38:13

10 "ANSWER:

12 A. Sir, which page?

13 there are four -- four little page number. 09:38:26 14 Q.

15 A.

16 Q.

17 A. Is it Page 113 or 14, 15 or 16?

19 Q. I understand.

20 When I refer to page numbers of this 09:38:44 21 transcript, I am only talking about the pages -- the 09:38:46 22 page numbers for the small pages. 09:38:51 23 A.

24 Q.

25 And I know it is confusing.

1 A. All right.

2 Q. Yeah. Go back to page thirty of the little 09:39:01

4 A.

6 I'm on the little page, on page thirty right 09:39:14

8 Q. Okay. Yes.

9 So take a look at line ten on page thirty, 09:39:19 10 and you will see a question there about when you 09:39:22 11 moved to Hong Kong to work for Golden Spring 09:39:26

14 A.

16 Q. Okay. And so my question for you is -- 09:39:55 17 first of all, let's just focus on the date. 09:40:00 18 Okay? Having read this, does that inform 09:40:03 19 your judgment about when it was that you began to 09:40:09 20 work for Golden Spring (Hong Kong)? 09:40:12 21 A. My answer, back to this page, which I mean 09:40:16 22 that, yes. I moved to Hong Kong in 2015, and then 09:40:25 23 I worked in there. I traveled to -- in U.S.

24 you have my full Golden Spring (New York) corporation 09:40:34 25 records, I officially start work in Golden Spring 09:40:41

1 from 2018, I believe; so before that I don't believe 09:40:44

2 I work for Golden Spring (New York).

3 I work for Golden Spring (Hong Kong) and -- which 09:40:56 4 include the time of the 2016, when I revert because 09:41:01 5 2015 -- 2016 I revert.

6 consecutive period of time for me to base in 09:41:12 7 Hong Kong; so besides that, I traveled between 09:41:16

9 Q. Okay. So I think I understand you, but 09:41:22

11 In approximately 2015 you started working 09:41:28 12 for Golden Spring (Hong Kong), and you worked for 09:41:33 13 Golden Spring (Hong Kong) until sometime in 2018, at 09:41:40 14 which point you began working for Golden Spring 09:41:46

17 A. I officially started to work for 09:41:53 18 Golden Spring (New York) from 2018, yes.

20 Q. Okay. And prior to that, you worked for 09:42:04 21 Golden Spring (Hong Kong); is that correct? 09:42:10 22 A. I believe it is more a mix because I was 09:42:14 23 working for Golden Spring (Hong Kong) and same time 09:42:20 24 I was working for Mr. Qiang Guo, his family business 09:42:23 25 in China also; so that is the reason when I referred 09:42:29

1 I was in Hong Kong in 2016.

2 a period of consecutive time for me to -- leaving 09:42:42 3 Hong Kong and working Hong Kong -- for Hong Kong. 09:42:46 4 That is my -- that is my representation. 09:42:49 5 Q. Were you -- at the time you were working for 09:42:51 6 Golden Spring (Hong Kong), were you physically in 09:42:55

8 A.

9 Q. Okay.

11 A.

12 Q. When did you come to the United States for 09:43:17 13 the first time?

14 A.

15 Q. Did you come to the United States during the 09:43:28 16 time that you worked for Golden Spring (Hong Kong)? 09:43:34 17 A.

18 During the time I worked for Golden Spring 09:43:39 19 (Hong Kong), I did travel into the United States 09:43:43

21 Q. Okay.

22 A. Oh, I couldn't recall.

23 2015 to 2017 or '18.

24 Q. When you came to the United States in that 09:44:07 25 time period, did you return to China? 09:44:10

1 MR. ROSEN: Objection.

2 please show me which of the 30(b)(6) topics this 09:44:18 3 relates to and give me some explanation as to where 09:44:21

5 MR. HARBACH: Yeah.

6 I am really just trying to get basic 09:44:26 7 background of the witness' affiliation with the 09:44:29 8 company that she represents. It is very basic.

9 trying to figure out when she worked, where, and for 09:44:36 10 whom. That's it. It informs her competency as the 09:44:40 11 30(b)(6) witness, and it gives con- -- it gives 09:44:44 12 context to her later testimony. 09:44:47 13 MR. ROSEN:

14 her travel plans has anything to do with this. 09:44:52 15 And I'm going to instruct the witness at 09:44:56 16 this point to simply not answer questions about her 09:44:58 17 travel and her whereabouts at various times.

18 would like to ask questions about her specific duties 09:45:05 19 and what she performed and when she performed it, 09:45:08 20 I have no objection to that. 09:45:11 21 MR. HARBACH:

22 object to any question about her physical location 09:45:13 23 when she performed those duties?

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

1 way beyond that. If you want to ask her specific 09:45:23

2 duty and where she was, then we can address that 09:45:25 3 question as it comes up.

4 general travel plans.

5 her work for other companies.

6 witness for Golden Spring (New York), and that is 09:45:38 7 where the questions should be directed. 09:45:41

9 Q. Ms. Wang, where were you physically located 09:45:45 10 when you worked for Golden Spring (Hong Kong)? 09:45:47 11 A. What do you mean, physically located? 09:45:55 12 I mean, like, stay in hotel or staying -- I mean, 09:45:59

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

16 A. I was in Hong Kong, and I was -- I traveled 09:46:10 17 in the U.S. I traveled in UK.

18 understand what do you mean physically located, but 09:46:19 19 that is the places I had been to. 09:46:22 20 Q. Okay.

21 merge -- moved to the United States permanently for 09:46:29

23 A. Sir, what do you mean permanently? 09:46:35 24 Q.

25 A.

1 Q. Did you move? Do you know what I mean by 09:46:42 2 move? 09:46:47 3 A. Yes. 09:46:47 4 Q. Okay. Did there come a time when you moved 09:46:48 5 to the United States for work? 09:46:51 6 A. Yes. 09:46:59 7 Q. When was that? 09:47:00 8 A. That was started I became to be the officer 09:47:01 9 and director of Golden Spring (New York). 09:47:09 10 Q. Which was when? 09:47:11 11 A. That was beginning of 2018, late of 2017. 09:47:17 12 I couldn't remember. It should be beginning of 2018. 09:47:25 13 Q. Okay. I'm going to show you another 09:47:29 14 document. 09:47:36 15 MR. HARBACH: We'll call this one number 09:47:38 16 two. 09:47:41 17 (Deposition Exhibit Number 2 09:47:41 18 was marked for identification.) 09:48:39 19 BY MR. HARBACH: 09:48:39 20 Q. Do you see Exhibit 2 in your folder, 09:48:40 21 Ms. Wang? 09:48:42 22 A. Yes. 09:48:44 23 Q. Okay. It should also be a .pdf. Please 09:48:46 24 open it up. 09:48:51 25 A. (Witness complies.) 09:48:52 Page 28

2 Q. Okay. Now, on this one I'm going to ask you 09:48:55 3 to turn to page -- okay -- forty-nine. 09:49:01 4 A.

5 Q. Tell me when you are on page forty-nine. 09:49:27 6 A.

7 Q. Okay. Looking at line five, the question 09:49:35

9 "QUESTION:

10 New York to start working for the Guo 09:49:43

13 "ANSWER:

14 forget.

16 A.

17 MR. HARBACH: Okay.

19 This testimony, for the record, was given in 09:50:06 20 May of 2019, just under three years ago. 09:50:09

22 Q. So is that accurate that you moved to 09:50:16 23 New York to start working for the Guo family in April 09:50:20

25 A. As I said, English is not my mother 09:50:26

1 language. When you say move, I mean, I understand 09:50:32

2 better by now more than two, three -- three, four 09:50:35 3 years ago, and that was right. I left China.

4 to New York -- I came to New York first.

6 So regarding work for it the Guo family, 09:50:50 7 which I refer always as my -- my boss -- like, the 09:50:54 8 owner of Golden Spring, Mr. Qiang Guo -- Q-i-a-n-g 09:51:00 9 G-u-o -- that is the same Guo family. 09:51:06 10 Q. So did you start working for the Guo family 09:51:09 11 in New York in April of 2015?

13 A. I started to work for the Guo family from 09:51:33 14 2000 -- end of 2008.

15 Q. Yeah. Let me -- let me interrupt and ask my 09:51:43 16 question again as you may have misunderstood it. 09:51:46 17 Did you start working for the Guo family in 09:51:49

19 A. Start work for the Guo family.

20 again, I don't remember this question many years ago. 09:52:13

22 Q.

23 You -- you -- you testified that it was 09:52:18 24 a date you'll never forget; so that is why I'm 09:52:20 25 pressing you a little bit on it. 09:52:25

1 My question is when did you start working 09:52:27

2 for the Guo family in New York?

3 seems to suggest that that was in April of 2015, and 09:52:38 4 I'm asking you whether that is accurate. 09:52:44 5 Is it accurate? Is it not accurate?

7 A. April 23rd in 2015.

8 I never forgot because I left China.

9 I was never able to go back. 09:53:03

11 So that is accurate.

12 question, I don't believe I have any interpreter help 09:53:10 13 me by then; so the question looks like right now 09:53:14 14 reading as when did you move to New York to start 09:53:18 15 working for the Guo family?

16 understanding this question without translation by 09:53:24 17 then; so if you ask me when I start to work for Guo 09:53:27 18 family, which I can tell you, I started -- my career 09:53:31 19 started from 2008, but I started to work for Guo 09:53:36 20 family outside of China.

21 That is my correct and truthful answer now. 09:53:44 22 Q. And that was in New York City; correct? 09:53:47 23 A. Starting from New York and Hong Kong. 09:53:49 24 Q.

25 A. I mean, by then Mr. Qiang Guo, he was in 09:54:06

1 New York and Hong Kong both.

2 there is any problem.

3 and Hong Kong -- starting from New York and back to 09:54:11 4 Hong Kong because I originally need to follow 09:54:13 5 Mr. Qiang Guo, if that makes sense to you, sir. 09:54:18 6 Q. Well, I just want to point out that I wasn't 09:54:21 7 suggesting there was a problem.

8 understand the facts of what happened; so here is my 09:54:28

10 When did you start working at Golden Spring 09:54:32

12 A. I believe I replied your question, sir, 09:54:40 13 about Golden Spring (New York).

14 I was appointed as officer and director of 09:54:46

16 Q.

17 A.

18 Q.

19 A.

20 Q. Okay. Let's go back to Exhibit 1.

21 know when you have got Exhibit 1 pulled up, Ms. Wang. 09:55:14 22 A.

23 Yes.

24 Q. Okay. Page numbers again, I'm talking about 09:55:22 25 the little page numbers.

2 A.

3 Q.

4 A.

5 Q.

6 A. Yes.

7 Q. Okay. Take a look on page thirty-five of 09:55:55

9 A.

10 Q.

11 "QUESTION:

12 you came to work for Golden Spring 09:56:09

15 "ANSWER:

16 Now, my only focus here is on whether 09:56:16 17 February of '18 sounds like the correct date to you 09:56:18 18 of when you started working for Golden Spring 09:56:22

20 A. Sir, I replied as in spring of 2018. 09:56:28

22 Q. I'm -- I'm not suggesting anything other 09:56:36 23 than whether February is correct. 09:56:39 24 Does that sound about right to you? 09:56:42 25 A. I don't recall. In spring of 2018.

1 could check on Golden Spring (New York)'s corporation 09:56:49

2 book.

3 Q. Was anyone else working at Golden Spring 09:56:56 4 (New York) when you started there in the spring of 09:57:07

6 A. What do you mean, is there anyone working at 09:57:10

8 Q. Well, you mentioned that you were, I think 09:57:21 9 you said, appointed to Golden Spring in the spring of 09:57:24

11 My question for you is at the time that you 09:57:32 12 were appointed, were there any other people working 09:57:34 13 for Golden Spring (New York)? 09:57:40 14 A.

15 Q. Okay.

16 A. He is one of the directors of Golden Spring 09:57:55

18 Q.

19 A.

20 Just me and himself, when I was appointed. 09:58:08 21 Q. So no other employees who worked at 09:58:14 22 Golden Spring at that time? 09:58:19 23 A.

24 Q. Do you recall whether there was a chauffeur 09:58:23 25 who worked for Golden Spring (New York) at that time? 09:58:33

2 Q. Let's take a look at Exhibit 1 again. 09:58:35

4 Q. And this time let's go to page forty. 09:58:51

6 Q. Tell me when you are there. 09:59:02

8 Q. Okay. Take a look at line seven.

9 "ANSWER:

10 a driver.

12 And then there is a question: 09:59:33 13 "QUESTION:

14 employee of Golden Spring before February of 09:59:36

17 "ANSWER:

19 "QUESTION:

20 you that he was an employee of Golden Spring 09:59:50

22 "ANSWER:

23 And then you say that he was the one who 09:59:55 24 picked you up at the airport. 09:59:58 25 Does that refresh your recollection about 10:00:01

1 whether there was a chauffeur employed at 10:00:03

2 Golden Spring (New York) when you started there? 10:00:07 3 A. Sir, I am the witness today -- in my 10:00:12 4 understanding is about bankruptcy.

5 is my task -- this was my testimony how many years 10:00:21 6 ago?

7 I mean, I could remember by then because 10:00:29 8 that was a relatively closer date.

9 October 2018, as you said.

10 and a half, four years after.

11 years pass by, I couldn't remember that.

12 my testimony back to 2018 in here said that, that is 10:00:50 13 possible. That reminded me. That's right.

14 doesn't mean that after three and a half, four years, 10:00:57 15 I still should remember all the details; right?

16 being deposed in here about a bankruptcy. 10:01:02

18 Q. Well, you are -- you are right about one 10:01:09 19 part, and that is that I offered you this information 10:01:11 20 to see if it would help refresh your memory. 10:01:14 21 And, indeed, that was the question, whether 10:01:19 22 reading this transcript helps refresh your memory 10:01:22 23 about whether there was a chauffeur working at 10:01:25 24 Golden Spring (New York) when you started. 10:01:30 25 A.

1 MR. ROSEN:

2 instruct the witness not to answer any further 10:01:33 3 questions along these lines. 10:01:36 4 This is a deposition in a contested matter 10:01:37 5 for approval of a DIP financing arrangement in 10:01:41 6 a bankruptcy case. So far, of the list of 30(b)(6) 10:01:49 7 topics, these questions barely hit on any of these -- 10:01:52 8 of the topics, maybe a little bit on the ownership 10:01:55 9 structure. You have already covered the officers, 10:01:58 10 employees, and directors, and so far nothing about 10:02:02

12 So I would ask you, if you are going to do 10:02:07 13 a fishing expedition or try and extend litigation 10:02:10 14 from other courts here, that I would have to instruct 10:02:12

17 Q. Ms. Wang, just a moment ago you said that 10:02:18 18 reading this deposition transcript did help you 10:02:22

20 And so my question is was there or was there 10:02:26 21 not a chauffeur working at Golden Spring (New York) 10:02:29 22 at the time you started there? 10:02:32 23 A. As my testimony back to 2018 said so, it is 10:02:37 24 possible.

25 Q. Okay.

1 New York when you started working at Golden Spring 10:03:01 2 (New York)? 10:03:03 3 MR. ROSEN: Objection. I instruct the 10:03:03 4 witness not to answer. 10:03:05 5 This has no relevance whatsoever to any of 10:03:06 6 the 30(b)(6) deposition topics, none. And the 10:03:06 7 purpose of this is strictly to either relitigate or 10:03:12 8 extend litigation from other courts or to harass this 10:03:13 9 witness. 10:03:17 10 BY MR. HARBACH: 10:03:18 11 Q. Ms. Wang, do you know who Mileson Kwok is? 10:03:18 12 A. Can you spell the name again, sir, please? 10:03:25 13 Q. Yes. 10:03:28 14 M-i-l-e-s-o-n Kwok, K-w-o-k. 10:03:29 15 Do you know who that is? 10:03:39 16 A. I don't know who you are referring, sir. 10:03:41 17 Q. Okay. You have mentioned someone who was 10:03:43 18 a director of Golden Spring at the time you became 10:03:47 19 a director. 10:03:51 20 What is that person's name? 10:03:52 21 A. If you refer to Mr. Qiang Guo, the same 10:03:56 22 director when I was appointed, his name is Q-i-a-n-g 10:04:01 23 G-u-o. His English name is Mileson, M-i-l-e-s-o-n, 10:04:08 24 and the last name is G-u-o, sir, if that is helpful 10:04:20 25 to you. 10:04:25

1 Is this the person you are referring? 10:04:27 2 Q.

3 A.

4 Q.

5 A. I never heard about someone called 10:04:30 6 Mileson Kwok. I mean, I never heard about this 10:04:33

8 Q. Okay.

9 Wengui Guo? And that is spelled W-e-n-g-u-i G-u-o. 10:04:45 10 How are they related, if at all, if you 10:04:57

12 A. Mr. Qiang Guo -- Q-i-a-n-g G-u-o -- he is 10:05:00 13 the son of Mr. H-o W-a-n K-w-o-k. 10:05:07 14 Q. And that is H-o W-a-n K-w-o-k; correct? 10:05:23 15 A.

16 Q. So for ease of understanding for everyone 10:05:30 17 who is reading this transcript, can we please refer 10:05:33

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

21 I will prefer to stay with Mr. Qiang Guo. 10:05:47

22 The reason because, again, English is not my mother 10:05:51

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

24 was -- which could be misunderstood by everyone here, 10:05:58

1 Q.

2 A.

3 Q.

4 A.

5 Q. Okay. And you just testified that he is the 10:06:14 6 son of Ho Wan Kwok, the debtor; right? 10:06:17 7 A. You are right, sir.

8 Q. So my question is was Qiang Guo living in 10:06:22 9 New York when you started working at Golden Spring 10:06:26

11 A. What do you mean, living in New York, sir? 10:06:30 12 Like, I mean, I don't understand.

13 I met him in there, yes.

15 MR. HARBACH:

16 me. My question in English would be did 10:06:48 17 Mr. Qiang Guo live in New York at the time you 10:06:52 18 started working at Golden Spring (New York)? 10:06:56 19 Could you please translate that for me? 10:06:59 20 THE INTERPRETER:

21 THE WITNESS:

22 I officially started working for Golden Spring 10:07:36 23 (New York) in 2018.

24 Mr. Qiang Guo was living in New York at the time. 10:07:41

2 Q. Did you see him in New York personally 10:07:46 3 around the time that you started working at 10:07:54

5 A.

6 Q. Have you ever seen Mr. Qiang Guo personally 10:08:02

8 A.

9 Q.

10 A.

11 Q.

12 A.

13 Q.

14 A.

16 Q. Was Mr. Ho Wan Kwok living in New York at 10:08:38 17 the time you started working for Golden Spring 10:08:47

19 MR. ROSEN: Objection.

21 I think -- Counsel, could you please explain 10:08:55 22 the relevance of this question to me. 10:08:56 23 MR. HARBACH:

24 Mr. Ho Wan Kwok is the debtor, and it is certainly 10:09:03 25 with- -- within the scope of appropriate topics, in 10:09:07

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

2 relationship to Golden Spring (New York), which is 10:09:17 3 his putative lender on this DIP loan; so I'm starting 10:09:20 4 with the question about where Mr. Kwok lived at the 10:09:29 5 time the witness started working at Golden Spring 10:09:32 6 (New York).

8 Q.

9 MR. ROSEN:

10 witness not to answer this question.

11 there is no relevance that I can see to disclosing 10:09:42 12 the whereabouts and the present location of parties 10:09:44 13 here to a DIP loan funding.

15 MR. HARBACH:

16 instructing the witness not to answer, Scott? 10:09:58 17 MR. ROSEN:

18 MR. HARBACH:

20 Q. Ms. Wang, when you started working at 10:10:04 21 Golden Spring (New York), what was your title? 10:10:06 22 A. I was -- I am -- I was the -- the president, 10:10:11 23 secretary, I believe treasurer also, and director. 10:10:16 24 Q. So you said, to make sure I have this right: 10:10:23 25 President, secretary, treasurer, and director; is 10:10:27

3 Q. I'm going to show you -- let's call this 10:10:32

5 (Deposition Exhibit Number 3 10:10:43 6 was marked for identification.) 10:10:48 7 MR. HARBACH:

8 I'm told it should be there.

10 Q. Ms. Wang, do you have number three? 10:11:30

13 Q. Okay.

16 Q. And tell me if you recognize this document. 10:11:42

18 Q. Okay. This is a document that you helped 10:11:50 19 create and submitted with an affidavit, isn't it? 10:11:57 20 A. What do you mean I created, sir? 10:12:01 21 Q. Well, let me withdraw that question. 10:12:08 22 You said that you recognized this document. 10:12:11

24 A. It is a director and officer register. 10:12:14 25 Q. For Golden Spring (New York) Limited? 10:12:19

1 A.

2 Q.

3 A. I don't recall.

5 Q. Give me just one moment, please. 10:12:37 6 MR. HARBACH:

7 y'all, but hopefully I've just saved us a little 10:13:58

10 Q. I'm going to ask you to put aside Exhibit 3, 10:14:05 11 and I'll come back to that a little later. 10:14:08

13 A.

14 Q. When -- when you were working for 10:14:13 15 Golden Spring (Hong Kong), did you have any titles? 10:14:28 16 A. I don't recall.

17 Q. What were your duties at Golden Spring 10:14:42

19 MR. ROSEN: Objection.

20 please point to which topic on 30(b)(6) that 10:14:50 21 a corporate witness of Golden Spring (New York) that 10:14:55 22 this would -- this would be appropriate to? 10:14:59 23 MR. HARBACH:

24 competency to testify as a representative of 10:15:04 25 Golden Spring (New York) by reference to her prior 10:15:07

1 experience and its relationship to her current 10:15:10

3 MR. ROSEN:

4 But you can answer the question. 10:15:19

6 Q. The question, Ms. Wang, was what were your 10:15:23 7 duties at Golden Spring (Hong Kong)? 10:15:25 8 A. I took instruction from the owner of 10:15:28 9 company, Mr. Qiang Guo, and worked for him. 10:15:34 10 Q.

11 A. Doing the task that he request me to do. 10:15:46 12 I don't recall.

13 Q. You -- you -- you don't recall what your 10:15:54

15 A.

16 Q. Okay. Do you recall whether when you were 10:16:04 17 working for Golden Spring (Hong Kong) you did any 10:16:15

19 A.

20 Sir, what is your question? 10:16:22 21 Q. When you were working for Golden Spring 10:16:24 22 Hong Kong, did you do any work for Mr. Ho Wan Kwok? 10:16:30 23 A.

24 Q. Who appointed you to be president, 10:16:33 25 secretary, treasurer, and a director of Golden Spring 10:16:45

2 A. I was appointed by Mr. Qiang Guo. 10:16:52

3 Q. When he appointed you to those positions, 10:16:56

4 what did he tell you your duties would be? 10:17:00

5 A. I was appointed, and he -- he requested me 10:17:03

6 to operate -- to run Golden Spring (New York), his 10:17:14

8 Q. Tell me what you mean by as general. 10:17:21 9 A. I mean any task, assignment as the owner of 10:17:25 10 company, himself, he requested to do that I will work 10:17:34

12 Q. When you assumed the role of president, 10:17:40

13 secretary, treasurer, and director of Golden Spring 10:17:56 14 (New York), did you have any financial professional 10:18:02

16 A. What do you mean, financial professional 10:18:07

18 Q.

19 A.

20 Q. Correction.

22 A.

23 Q.

24 A. (Witness complies.) 10:18:39 25 Q. Actually, you might need to look a bit 10:18:51

3 A.

4 Q. Okay. At the bottom of page forty-six there 10:19:03 5 is an answer that begins -- and it was in response to 10:19:07 6 a question about some exhibit you were being shown. 10:19:11 7 In the course of your answer, which goes on to page 10:19:15 8 forty-seven, you say, among other things: 10:19:19 9 "ANSWER:

10 Golden Spring.

11 Chinese Communist party, they kidnap almost 10:19:27 12 all my colleague, between me and the company; 10:19:32 13 so my background, I do not have financial 10:19:35 14 professional knowledge.

15 American real estate professional knowledge." 10:19:41

17 But I have just read the two sentences that 10:19:47 18 I am interested in for my question because my 10:19:49 19 question to you was when you assumed the roles of 10:19:52 20 president, secretary, treasurer, and director of 10:19:55 21 Golden Spring (New York) Limited, did you have any 10:20:00 22 financial professional knowledge? 10:20:04

24 A. These deposition happened in which year, 10:20:11 25 sir?

1 Q. The transcript that I just read from was not 10:20:21

2 a deposition. It was testimony in court, and it was 10:20:23

4 A.

5 Q. But these -- these appear to have been your 10:20:32 6 words, and so that is why I asked the question. 10:20:35 7 A. So back to 2019, my testifying -- my 10:20:39 8 testimony was correct.

9 Mr. Qiang Guo, his family business, including his 10:20:50 10 employees, were all persecuted.

11 arrested, kidnapped, or disappeared.

12 the survivor by then.

13 And then when I testified back to 2019, 10:21:07 14 I said I don't have -- that was -- I am humble; 10:21:10 15 right? So that was my testimony -- test- -- 10:21:18 16 testimony. And then now in 2022, I mean, I could 10:21:21 17 learn lots in three years; right? 10:21:26 18 Q.

19 A.

20 Q.

21 A. -- that doesn't mean I don't have anything 10:21:29

23 Q.

24 A. -- to testify in this bankruptcy, you know, 10:21:32

1 Q. Yeah. I understand that -- that three years 10:21:35

2 have passed.

3 My question is about the day when you were 10:21:43 4 appointed to be president, secretary, treasurer, and 10:21:47 5 director of Golden Spring (New York).

7 And my question is as of that day, did you 10:21:59 8 have any financial professional knowledge? 10:22:03 9 A. What kind of financial professional 10:22:08 10 knowledge you are looking for back to three years 10:22:13

12 Q. They were your words, Ms. Wang.

13 I do not have financial professional knowledge. 10:22:21 14 I don't know what you meant.

15 question, but it is what you said; so that is why 10:22:28 16 I used those words in asking you.

18 All I'm asking is at the time you assumed 10:22:38 19 all of those titles at Golden Spring (New York), did 10:22:41 20 you have any financial professional knowledge?

22 A. When I say I didn't -- when I said I don't 10:22:54 23 have, as I repeat again, that is our culture -- our 10:22:58 24 culture, Chinese culture.

25 I don't have professional knowledge. 10:23:09

2 A. English is not my mother language. I do not 10:23:12

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

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

5 Q. All I'm looking for is the truth, first of 10:23:22 6 all. 10:23:25 7 Second, I am not asking you to be humble or 10:23:26

8 proud. I'm just asking you to be honest. 10:23:31 9 A. I am. 10:23:34 10 Q. So similarly, I mean, you were under oath 10:23:34 11 when you testified in court, and I think the 10:23:38 12 expectation would have been that you be honest then 10:23:40 13 as well. 10:23:43 14 A. I was. 10:23:44 15 Q. Okay. So I wasn't there that day. All 10:23:45 16 I have is the transcript. And I'm just being -- I'm 10:23:48 17 being honest with you. That is the reason for my 10:23:52

18 question is because I saw that you said that you 10:23:54 19 don't have any financial professional knowledge. 10:23:58 20 So I suppose the question is if you were 10:24:01

just being humble back in 2019, do you mean to say 10:24:05 that you, in fact, did have financial professional 10:24:10 knowledge when you were appointed to all of those 10:24:14 positions at Golden Spring? Is that what you were 10:24:16 trying to say? 10:24:20

1 A. I am not trying to say anything.

2 testimony -- back to 2019, that was my testimony, and 10:24:23 3 that -- I stay with that.

4 accurate information, sir.

5 what are you looking for after three years, I do not 10:24:34 6 understand, and I will do my best to help you. 10:24:38 7 Q. Okay. Same question about the next sentence 10:24:40 8 on the transcript, which says: 10:24:44 9 "I do not have American real estate 10:24:46

11 Was that true when you said those words in 10:24:50

13 A. It is correct.

14 I am not a licensed realtor; right?

16 Q. Okay. So it is correct that at least as of 10:25:06 17 May of 2019 you did not have American real estate 10:25:09

19 A.

20 Q.

21 A. I don't have a license at all by then. 10:25:16 22 Q.

23 Is it true that in your capacity as 10:25:29 24 president of Golden Spring (New York) Limited you 10:25:36 25 serve as an administrator for the interests of 10:25:42

1 Mr. Ho Wan Kwok and his family? 10:25:46

2 MR. ROSEN: Objection.

5 THE WITNESS:

6 I don't understand your question, sir. 10:25:59 7 MR. HARBACH: Okay.

8 we go there -- actually, let -- let's -- Sunny, if 10:26:03 9 you don't mind, I will ask the question again.

10 I'm -- I'm sorry to refer to you by your first name. 10:26:12 11 That is unprofessional. Sorry.

13 Q. Ms. Wang, the question is in your capacity 10:26:20 14 as president of Golden Spring (New York) Limited, 10:26:23 15 isn't it true that you serve as an administrator for 10:26:30 16 the interests of Mr. Kwok -- Mr. Ho Wan Kwok and his 10:26:35

18 MR. ROSEN:

19 You can answer the question. 10:26:46 20 MR. HARBACH:

21 THE CHECK INTERPRETER:

22 interpreter heard Mr. Kwok and Mr. Ho Wan Kwok and 10:27:16

24 MR. HARBACH:

4 THE INTERPRETER: That is his Mandarin name, 10:27:29

5 Ho Wan Kwok. The Mandarin is Wengui Guo. 10:27:36

6 THE CHECK INTERPRETER: But, I mean, the 10:27:42

7 counsel said Ho Wan Kwok. 10:27:43 8 MR. HARBACH: Yes. 10:27:45 9 The reason that counsel said Ho Wan Kwok was 10:27:45 10 because the witness said that is how she knows the 10:27:48

11 debtor. I asked her earlier whether she knew the 10:27:51 12 name Wengui Guo, and she said she knows him as 10:27:56 13 Ho Wan Kwok; so that is why I used that name. 10:28:01 14 THE INTERPRETER: Yes. 10:28:03 15 MR. HARBACH: But we can clear this -- we 10:28:05 16 can clear this up now, Ms. Wilkinson. 10:28:06 17 THE CHECK INTERPRETER: Okay. 10:28:08 18 BY MR. HARBACH: 10:28:08 19 Q. Ms. Wang, what name would you prefer to use 10:28:08 20 going forward to refer to Mr. Qiang Guo's father? 10:28:12 21 A. Mr. Ho Wan Kwok. 10:28:18 22 Q. Very good. 10:28:19 23 A. That is the debtor; right? That is the 10:28:20 24 debtor's name. 10:28:21 25 Am I right. 10:28:23

1 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 A.

6 Q.

7 THE INTERPRETER:

8 repeat the question one more time, please. 10:28:39 9 MR. HARBACH: Sure.

10 THE INTERPRETER:

interpreter does not speak Cantonese; so I will just 10:28:48 re- -- I will just say the name the way you pronounce 10:28:53 it instead of saying the Mandarin name. 10:28:54 14 MR. HARBACH: Okay. That -- that's fine. 10:28:57

15 And, obviously, I speak neither; so I will rely on 10:28:59 16 you all. 10:29:02 17 BY MR. HARBACH: 10:29:03 18 Q. So here is the question. 10:29:03 19 In your capacity as president of 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 23 MR. ROSEN: Objection. 10:29:23 24 You may answer. 10:29:25 25 THE WITNESS: (Through Interpreter) Well, 10:29:59

1 first of all, I don't know what you meant by the word 10:30:07

3 And, second, I worked for Mr. Qiang Guo. 10:30:11 4 MR. HARBACH:

6 THE INTERPRETER:

7 MR. HARBACH: Okay.

9 Q. Let's take a look now at Exhibit 4. 10:30:28 10 (Deposition Exhibit Number 4 10:30:31 11 was marked for identification.) 10:30:35 12 THE WITNESS:

14 Q. Okay. I have got it, Ms. Wang.

16 A.

18 Q.

20 A.

21 Q. And the first thing I want to do is go to 10:31:07

23 A.

24 Q.

25 A.

1 Q. Is that your signature on the top right of 10:31:15

5 Q. Yes, sir -- or excuse me.

6 A. Okay.

9 Exhibit 4, you mean the director and officer 10:31:37

11 Q. No. No.

12 A. Okay.

13 Q. This is the one that says exhibit, and then 10:31:44 14 it has the number next to it, four. 10:31:47

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

21 Now go to the last page of it, please.

25 Q. My question to you is is that signature on 10:32:07

1 the top right-hand corner of page three of Exhibit 4 10:32:12

3 A.

4 Q. Okay.

5 A.

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

11 A.

12 Q. Okay.

13 three -- sorry to keep jerking you around. 10:32:43 14 Could you please go to page three. 10:32:47 15 A.

16 Q.

17 A.

20 Q. You will see above the notary public's 10:32:56 21 signature that it indicates that it was sworn on 10:32:59

25 Q. Okay. Now go back to page one for me. 10:33:08

1 A.

2 Q.

3 A.

4 Q. The very first sentence of your dep- -- 10:33:18 5 excuse me.

6 "I am the president of Golden Spring 10:33:26 7 (New York) Limited, and in that capacity 10:33:28 8 serve as an administrator for the interests 10:33:32 9 of the defendant sued herein as Kwok Ho 10:33:35

11 And then there follows several akas. 10:33:42 12 -- "and his family," period. 10:33:46

14 A.

15 Q. So I'll ask you to tell me what being an 10:33:52 16 administrator of the interests of Mr. Kwok Ho Wan and 10:34:00 17 his family means, because they are your words. 10:34:12 18 A. This is drafted by the attorneys also; so in 10:34:16 19 my understanding, an administrator, these words -- 10:34:20 20 as, again, I am not native speaker at all -- means 10:34:25 21 that I work for Golden Spring and take instruction 10:34:30 22 from owner of Golden Spring to work out the 10:34:32 23 assignment and task Golden Spring request me to do is 10:34:39

25 Q. How many affidavits do you think you have 10:34:44

2 A.

3 Q.

4 A.

5 Q.

6 A.

7 Q.

8 A.

9 Q. Do you know what -- what an affidavit is? 10:35:08 10 A. What do you mean, do I know what affidavit 10:35:12

12 Q. Do you know what an affidavit is?

14 A. I don't understand your question. 10:35:23 15 MR. HARBACH:

17 Do you know what an affidavit is? 10:35:34 18 THE INTERPRETER:

19 THE WITNESS:

20 question. All I have done in that I work for 10:35:58 21 Golden Spring (New York) Limited.

22 speaker. I am definitely not legal person either; 10:36:01

24 So like, I just to be here, and then what 10:36:06 25 being before there to tell the legal all the truthful 10:36:07

1 information as best of my capacity and as best of my 10:36:11

4 Q.

5 A.

6 Q.

7 A. I don't know what you are looking for. 10:36:18 8 I mean, if you are looking for words in the 10:36:20 9 dictionary, I don't know what you are looking for. 10:36:22 10 Q. I'm asking you if you know what an affidavit 10:36:24

12 A. Affidavit is a legal paperwork. 10:36:28 13 Q. Okay.

14 affidavit is a piece of legal paperwork where 10:36:34 15 a person provides testimony that is sworn under oath? 10:36:38 16 A.

17 Q. Okay. And you told me a moment ago you -- 10:36:47 18 actually, I want to be fair. 10:36:51 19 You don't -- you don't know how many 10:36:54 20 affidavits you may have done in the past; is that 10:36:56

22 A. I don't recall.

23 how many of them?

24 Q. I'm not -- I'm not suggesting -- 10:37:10 25 A. I don't work in a law firm; right? 10:37:12

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

4 shouldn't. All I'm asking is whether you know how 10:37:19

5 many affidavits you have prepared in your life. 10:37:23

6 And I understood your answer to be that you 10:37:26

8 A. Sir, now you are asking in my life.

9 recall.

10 Q. Okay. That is fine.

12 You have told me that you understand an 10:37:43 affidavit to be a legal document where a person 10:37:46 provides testimony that is sworn under oath; is that 10:37:51 right? 10:37:55 16 A. The sentence which you read me through, this 10:37:58 was I signed back to 2018. And then now as 10:38:01 April 2020 [sic] of course I couldn't remember that, 10:38:08 like, four years ago almost. 10:38:15 20 Q. But -- 10:38:17 21 A. But I do know that that is a legal 10:38:17 paperwork. I gave all my truthful and honest 10:38:19 information in that paperwork. This I am testifying 10:38:22 right now. 10:38:25 25 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

3 A. When I signed and I gave all my truthful 10:38:41

5 Q. Was this -- this affidavit that is Exhibit 4 10:38:49 6 that we're looking at, was it true when you signed it 10:38:53

8 A. I signed affidavit back to 2018 of this 10:39:03 9 one. That is my best and truthful knowledge and 10:39:07

11 Q.

12 A. I answered your question, sir, already. 10:39:17 13 Q. Well, I'm going to ask it one more time. 10:39:20 14 I think you may have, but I want to ask it one more 10:39:24 15 time just to make sure we are clear. 10:39:28 16 Was this affidavit -- that is, Exhibit 4 -- 10:39:30 17 true at the time that you signed it? 10:39:32 18 A. What do you mean, at the time when I signed 10:39:37 19 it? I mean, I signed it as true back in 2018. 10:39:46 20 Q.

21 And -- and here's the -- here's the problem. 10:39:51 22 Just a few minutes ago, when I asked you about the 10:39:55 23 first sentence of Exhibit 4, you said something about 10:39:59 24 this document being prepared by lawyers and that 10:40:02 25 English isn't your first language and that -- and so 10:40:06

1 that is why I'm asking these questions so that I can 10:40:12

2 understand whether what is written on the page here 10:40:15 3 is your truthful testimony or not. 10:40:19 4 A.

5 Q. All I can do is ask you -- let me finish my 10:40:29

7 I don't know what is in your brain.

8 I can do is ask questions.

9 signed this document.

10 understand it is an affidavit.

11 you understand an affidavit to be. 10:40:45 12 And so now all I'm asking you is whether 10:40:50 13 this particular affidavit was true when you signed 10:40:53 14 it. That is a yes, no, I don't know, or I don't 10:40:59

16 A. This is several questions, sir.

17 only answer one yes or one no. 10:41:14 18 Q. Sure you can. It is a single question.

19 answer can be either yes, it could be no, it could be 10:41:21 20 I don't know, or it could be I don't remember. 10:41:25 21 A.

22 Q. Do you need me to ask the question one more 10:41:33

24 A. The affidavit, which I signed back to 2018, 10:41:36 25 was drafted by attorney, yes.

1 is not my native language, yes.

2 back to 2018. That is a truthful information as best 10:41:50 3 of my knowledge. By then, when I signed my name in 10:41:53

5 I'm testifying right now to explain and let 10:41:58 6 you know all of those yes and no, that is my truthful 10:42:02 7 testimony by now, yes.

9 Q. At the time that you signed Exhibit 4, did 10:42:11

11 A.

12 Q. Did you understand what you were signing? 10:42:19 13 A.

14 Q. Were you able to read it and understand what 10:42:24

16 A. I don't understand your question.

17 you are asking my recollection back to 2018? 10:42:35 18 Q.

19 A.

20 Q. You don't recall whether when you signed 10:42:38 21 this affidavit you understood what it said? 10:42:41 22 A. It is four years ago, sir.

24 Q. Do you make a habit of signing affidavits 10:42:51 25 under oath when you don't understand what they say -- 10:42:55

with- -- withdrawn. 10:42:58 2 MR. HARBACH: Scott, you don't have to 10:43:01 object. 10:43:02 BY MR. HARBACH: 10:43:03 5 Q. Do you recall whether this affidavit was 10:43:04 translated for you? 10:43:06 7 A. I don't recall. Again, like, it is three or 10:43:07 four years ago. I don't recall. 10:43:11 9 Q. When was the last affidavit that you 10:43:16 executed, approximately? 10:43:26 11 MR. ROSEN: Objection. 10:43:28 12 We -- we have really got to move on, David. 10:43:30 This is -- 10:43:34 14 MR. HARBACH: Listen, now, Scott. This is 10:43:35 nothing personal, obviously. I would love nothing 10:43:38 more than to move on, but I'm just trying to get the 10:43:40 witness to adopt what she swore to three years ago. 10:43:44 18 MR. ROSEN: All right. How is that relevant 10:43:51 to the 30(b)(6) deposition topics today? 10:43:53 20 MR. HARBACH: Oh, because it is squarely 10:43:56 within what her job is as president of Golden Spring 10:43:58 (New York). That is 100 percent within the scope of 10:44:02 what we're talking about here. She has told us about 10:44:05 all the titles that she has, and I'm exploring what 10:44:09 she does. And she has filed an affidavit saying that 10:44:13

1 her job is what we have read several times, and now 10:44:16

2 she doesn't want to answer that.

3 own that; so I'm going to stop arguing, but it is 10:44:23 4 plainly relevant.

5 You can instruct her not to answer.

6 instruct her not to answer any question that mentions 10:44:33 7 Ho Wan Kwok if you want.

8 here until I understand what was in this witness' 10:44:39 9 head when she signed this affidavit. 10:44:42 10 MR. ROSEN:

11 have pretty much established on the record that what 10:44:46 12 you are going for has nothing to do with this DIP 10:44:50

14 So I am going to instruct the witness not to 10:44:52

16 MR. HARBACH: Okay.

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

19 So can we please, Mr. Videographer, take ten 10:45:03

21 THE VIDEOGRAPHER:

25 THE VIDEOGRAPHER:

record. 11:00:23 2 The time is 11:00 o'clock. 11:00:23 BY MR. HARBACH: 11:00:31 4 Q. Ms. Wang, before the break I was asking you 11:00:35 about Exhibit 4, which is an affidavit that you 11:00:37 signed in May of 2018. 11:00:43 7 MR. HARBACH: Scott, I confess, I do not 11:00:48 recall whether where we left off was with your 11:00:51 instructing the witness not to answer my question -- 11:00:54 any more questions about this. And let me -- and let 11:01:00 me just -- let me say before you answer that if you 11:01:04 let me answer one or two -- ask one or two more, I'll 11:01:07 move on. 11:01:13 14 MR. ROSEN: I appreciate that, and yeah. 11:01:14 Please -- I'll instruct the witness at this time to 11:01:18 answer the question. 11:01:22 17 MR. HARBACH: Okay. Thank you. 11:01:24 BY MR. HARBACH: 11:01:25 19 Q. So Ms. Wang, do you still have Exhibit 4 in 11:01:25 front of you? 11:01:30 21 A. Exhibit 4? Yes, sir. Yes. 11:01:32 22 Q. Okay. So again, reminding you that this 11:01:38 affidavit was signed in May 2018. 11:01:41 24 My question for you is is it true that in 11:01:45 May of 2018, as president of Golden Spring 11:01:51 Page 67

1 (New York), you served as an administrator for the 11:01:57

2 interests of Mr. Kwok Ho Wan and his family? 11:02:01 3 A.

4 As the language read in my affidavit, yes. 11:02:13 5 Q. Do you recall what you meant by an 11:02:16 6 administrator for the interests of Mr. Kwok Ho Wan 11:02:45

8 A. The language in this affidavit was drafted 11:02:51 9 by attorney, and, in my understanding, 11:02:57 10 Golden Spring -- as per Mr. Qiang Guo's instruction, 11:03:03 11 Golden Spring, like, pay Mr. Ho Wan Kwok, like, his 11:03:10 12 lifestyle and then et cetera; so that was my 11:03:17

14 Q. That was your understanding of your role? 11:03:22 15 Because that was what my question was about. 11:03:27 16 A. My role as president of Golden Spring or 11:03:31

18 Q. Well, you have stated that as president, you 11:03:36 19 served as an administrator of Mr. Kwok 11:03:42

21 And so I'm asking about whether what you 11:03:50 22 just described was your role in May of 2018. 11:03:54 23 A. I am the president of Golden Spring.

24 instruction from Mr. Qiang Guo and served as an 11:04:05 25 administrator -- administrator for his father. 11:04:09

1 Q. And was that true from the moment you began 11:04:13

3 A. Oh, sir, the moment -- again, you are asking 11:04:21

5 Q. Well, I'm asking whether what you just 11:04:27 6 described as your duties as an administrator, was 11:04:31 7 that true from the beginning, from when you first 11:04:38 8 started working at Golden Spring (New York)? 11:04:40 9 A. When I started working for Golden Spring 11:04:42 10 (New York), I did take instruction from Mr. Qiang Guo 11:04:52 11 to -- to serve, as I said, as administrator for his 11:04:54

13 Q. And so that would have been in the spring of 11:05:00 14 2018, when you started working for Golden Spring 11:05:04

16 A.

17 Q. And how frequently did you communicate with 11:05:11 18 Mr. Qiang Guo during that time, say the spring of 11:05:16

20 A. I don't recall, but I do believe we -- we 11:05:24

22 Q. Okay.

23 A.

24 Q. Okay. Do you recall whether you talked to 11:05:36

1 A. I don't recall.

2 needed. If, you know, we need to talk, we just talk. 11:05:47

4 A. I don't, like, calculate, yeah. 11:05:52 5 Q. No.

6 And I don't mean to be asking for a precise 11:05:56 7 calculation. I'm just trying to get a sense of how 11:05:58

9 When you talked to him, meaning 11:06:03 10 Mr. Qiang Guo, did you speak by phone? in person? 11:06:06

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

15 How often did you communicate with 11:07:01 16 Mr. Ho Wan Kwok in the spring of 2018 to fulfill your 11:07:07 17 role, as you have described it? 11:07:13

19 Q. Did you ever communicate with him? 11:07:18

22 Q. And was that in person? 11:07:27

25 Q. Okay.

2 Q. Okay.

3 A. Sir, you are asking back to 2018, when 11:07:45

4 I start work for Golden Spring? 11:07:51

5 Q. Yes. Yes, ma'am.

6 A.

7 Q. Okay.

8 MR. HARBACH:

10 Q. My colleague reminds me, I meant to ask this 11:08:28

12 When you started working at Golden Spring 11:08:32 13 (New York) in New York City, where did you reside? 11:08:37 14 I don't mean the -- the exact address, but where did 11:08:41

16 MR. ROSEN: Objection.

17 reasons that Ms. Wang does not want to give 11:08:51

19 Are you talking about a city or -- something 11:08:57 20 as general as a city or are you talking address? 11:09:00 21 MR. HARBACH:

22 question in a way that avoids those concerns, Scott. 11:09:07 23 MR. ROSEN:

25 Q. Ms. Wang, when you started working at 11:09:12

1 Golden Spring (New York) in New York City in 2018, 11:09:15 2 did you reside in the same location as 11:09:21 3 Mr. Ho Wan Kwok? 11:09:24 4 A. I lived in New York. 11:09:33 5 Q. Did you reside -- again, I'm not talking 11:09:34 6 about now. 11:09:41 7 I'm talking about in 2018, when you started 11:09:41 8 working at Golden Spring (New York), did you reside 11:09:46 9 in the same dwelling as Mr. Ho Wan Kwok? 11:09:51 10 A. Sir, what do you mean by dwelling? Do you 11:10:00 11 mean -- 11:10:03 12 Q. A house. 11:10:03 13 A. Is it -- 11:10:04 14 Q. Is it a house? an apartment? It doesn't 11:10:05 15 matter. 11:10:09 16 Did you live in the same home as 11:10:09 17 Mr. Ho Wan Kwok? 11:10:12 18 A. No. 11:10:12 19 Q. Have you ever been to the -- withdrawn. 11:10:19 20 Have you ever lived in the eighteenth floor 11:10:22 21 apartment of the Sherry-Netherland? 11:10:29 22 A. I visited there, sir. 11:10:33 23 Q. Fair enough. 11:10:36 24 I'm asking whether you have ever resided 11:10:36 25 there. 11:10:40 Page 72

1 A. What do you mean, reside?

2 my -- my home?

3 Q. Okay. Have you ever stayed there for -- 11:10:47 4 MR. HARBACH:

7 Q. Have you ever stayed there for more than 11:10:55

9 A.

10 Q. Okay.

12 A.

13 Q. Tell me when you have got it up, Ms. Wang. 11:11:28 14 A.

15 Q. Okay. The cover page, just to help you 11:11:36 16 orient yourself, is dated October 11th, 2018, which 11:11:44 17 was the date of this deposition. 11:11:49

19 A.

20 Q. All right. And so that is approximately -- 11:11:54 21 I don't know -- six months after you started working 11:12:00 22 at Golden Spring (New York)? 11:12:03 23 A. And -- yes.

24 Q. You said you started working in the spring 11:12:13 25 of 2018; so approximately six months. 11:12:16

2 A.

3 Q. Okay.

4 A.

5 Q. And, again, looking at the little pages. 11:12:33

7 A.

8 Q. Okay. The very top of page sixty there is 11:12:50 9 a -- the tail end of a question and then a question 11:12:54

11 "QUESTION:

13 "ANSWER:

15 "QUESTION:

16 "ANSWER:

17 "QUESTION:

19 "ANSWER:

20 "QUESTION:

22 "ANSWER:

23 "QUESTION:

24 him in regard to any Golden Spring business? 11:13:24 25 "ANSWER:

2 A.

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

5 A.

6 Q. Let's go through them -- let's go through 11:13:53 7 them one by one so we can be crystal clear.

9 "QUESTION:

10 Was that true in October 11th, 2018, you 11:14:09 11 knew Mileson Kwok?

12 A. I was given a wrong impression back in 2018. 11:14:13 13 Like, I was thinking, like, Mileson go with Kwok 11:14:17 14 also.

15 Q.

16 A.

17 Q.

18 A.

19 Q.

20 A.

21 Q.

22 A. -- I was corrected by Mr. Qiang Guo. 11:14:27 23 He purposely corrected me after -- I forget when.

24 corrected me and said that he always go with 11:14:33 25 Mileson Kwok; so the testimony by then back in 2018 11:14:37

2 Q.

3 A. The testimony right now, after I was 11:14:43 4 corrected, is accurate also, sir. 11:14:45 5 Q.

6 And so the -- the correction concerned his 11:14:49

8 A.

10 Q.

11 A. That is reason why I am insisting calling 11:14:56

13 So that is the accurate -- you know, his 11:15:00

15 Q.

16 A. That works better for me, yeah. 11:15:05 17 MR. HARBACH:

18 reporter for interrupting.

20 Q. Next question on the deposition transcript 11:15:13

22 "QUESTION:

23 "ANSWER:

24 So there is no question whether it is 11:15:22

1 We are talking about Mr. Kwok Ho Wan's son; 11:15:27

3 A.

4 Q. And Mr. Ho Wan Kwok has one, and only one, 11:15:35

6 A.

7 Q. Okay.

8 "QUESTION:

9 Meaning who we're calling Qiang Guo. 11:15:51

12 "ANSWER:

13 Was that true that you had met Qiang Guo in 11:16:01 14 person as of October 11th, 2018? 11:16:05 15 A.

16 Q. Okay.

17 "QUESTION:

19 Your answer was you don't know. 11:16:19 20 Now, this is six months after you said you 11:16:22 21 started at Golden Spring.

22 claim earlier were conversations with Mr. Qiang Guo 11:16:31 23 about your role and duties. 11:16:35 24 So why, six months after you started at 11:16:39 25 Golden Spring, did you say that you didn't know 11:16:42

2 A.

3 Q. Isn't that -- isn't that also true that you 11:16:52

5 A. So sir, you finish your question; so can 11:17:02 6 I start to answer or you still have more, sir?

8 Q.

9 You can answer if you answer my question. 11:17:12 10 The question is is it true that as of 11:17:15 11 October 11th, 2018, you did not know whether 11:17:19 12 Qiang Guo had any role at Golden Spring?

14 A. Back to 2018, I don't know by then in my 11:17:33 15 understanding the role means employee or employees; 11:17:38 16 so by then I did not know whether he was employee or 11:17:43 17 not. But I do know he is the boss.

18 I do not know whether he is employee or not because 11:17:51 19 he was majorly handling the Golden Spring majority of 11:17:54 20 work by then. I only work and cooperate with him as 11:18:00

22 Q. In 2018 you didn't say he was the boss?

23 months after you claimed to have started working with 11:18:13 24 him you didn't say he was the boss, did you? 11:18:16 25 A. I was not asked whether he was the boss or 11:18:19

2 Q. You were asked whether he had any role? 11:18:24 3 A. Any role, in my understanding back to 2018, 11:18:27

5 Q. Okay.

6 "QUESTION:

7 him in regards to any Golden Spring 11:18:39

9 That was the question you were asked, and 11:18:46

11 "ANSWER:

12 My question for you right now is is it 11:18:52 13 true -- is it true that as of October 11th, 2018, you 11:18:55 14 had not interacted with Qiang Guo in regard to any 11:19:01 15 Golden Spring business?

16 A. It is a correct answer because back in 2018, 11:19:13 17 Mr. Qiang Guo, he was the major person running 11:19:19 18 Golden Spring; so I didn't understand -- again, 11:19:22 19 English not my native language -- what is interacted 11:19:29 20 with. My understanding, by then he was running the 11:19:33 21 company. I just work for him as he needed.

22 my understanding; so -- which is correct. 11:19:38 23 Q.

24 And you told me five minutes ago that you 11:19:41 25 had contact with him -- you didn't remember how 11:19:44

1 frequently -- and that it was -- I believe you said 11:19:47

2 a mix of by phone and in person. 11:19:51 3 Do you -- does that not count as interaction 11:19:59

5 A. Interact with him in Golden Spring business. 11:20:03 6 I mean, him and myself, we're friend also along the 11:20:06 7 way for so many years; so when you ask me five 11:20:11 8 minutes ago, I mean, we do, like, meet and talk as 11:20:14 9 needed. But the question back to 2018, it is asking 11:20:18 10 about interacted with him in regard to any 11:20:23 11 Golden Spring business, which my testify was true. 11:20:26 12 He was in charge of all the Golden Spring business 11:20:29 13 back to then. And I know I'm part of Golden Spring, 11:20:32 14 but, really, like, he -- he was the person running 11:20:36

16 Q. Ms. Wang, isn't it true that, in fact, you 11:20:40 17 were not interacting with Qiang Guo, certainly not in 11:20:46 18 2018, about Golden Spring business?

19 A. Can you reframe your question again, sir? 11:20:56 20 Q. Isn't it true that in 2018 you, in fact, 11:21:01 21 were not interacting with Mr. Qiang Guo at all 11:21:05 22 related to anything Golden Spring was doing?

24 A. I don't recall.

25 and this deposition was conducted -- I don't believe 11:21:21

1 I had an interpreter by then. 11:21:25

2 Q. Isn't it also true that the boss of 11:21:27 3 Golden Spring (New York), when you started working 11:21:30 4 there, wasn't Qiang Guo; it was Mr. Ho Wan Kwok? 11:21:32

6 A. Golden Spring (New York)'s boss is always 11:21:38

8 Q. Isn't it true that you have been a long-term 11:21:44 9 employee of Mr. Ho Wan Kwok? 11:21:53 10 A. I have been working for Mr. Qiang Guo, 11:22:00

12 Q. Yeah.

13 Mr. Qiang Guo.

14 Isn't it true that you were a long-term 11:22:13 15 employee of Mr. Ho Wan Kwok? 11:22:18 16 A. I don't believe so.

17 never pay me or ever pays me or pay me at all. 11:22:25 18 Q.

19 A. So I always work for Mr. Qiang Guo and his 11:22:31

21 Q. Does Mr. Ho Wan Kwok ever tell you what to 11:22:35

23 A. What do you mean, ever tell me what to -- if 11:22:38 24 they ask me for help, of course I will offer my help 11:22:42

1 Q. Does -- does Mr. Ho Wan Kwok ever give you 11:22:46 2 direction? 11:22:48 3 A. He ask for support and help, which I'm 11:22:49 4 always willing to do that for him. 11:22:55 5 Q. Does he ask -- ever ask you to go get 11:22:57 6 coffee? 11:23:00 7 A. I don't recall. 11:23:01 8 What do you mean? 11:23:03 9 Q. You don't -- you don't recall whether 11:23:05 10 Mr. Ho Wan Kwok has ever asked you to get coffee? 11:23:07 11 A. Sir, I mean, I don't recall. Just, like, 11:23:11 12 why I should recall someone ask me to get coffee; 11:23:15 13 right? 11:23:18 14 Q. Well, I don't -- I don't know. Maybe he has 11:23:19 15 asked you to get coffee hundreds of times. Maybe he 11:23:21 16 never has. All I can do is ask the question. 11:23:25 17 Do you recall -- 11:23:28 18 A. I don't recall that. 11:23:28 19 Q. -- if Mr. Ho Wan Kwok has ever asked you to 11:23:29 20 go get coffee? 11:23:32 21 A. I don't recall. 11:23:34 22 Q. Okay. What about to translate something for 11:23:34 23 him, meaning Mr. Ho Wan Kwok? Have you ever done 11:23:37 24 that for him? 11:23:40 25 A. Yes, I did. 11:23:41 Page 82

6 Q. Okay. When was the last time you translated 11:23:52 7 something for Mr. Ho Wan Kwok? 11:23:55

9 Q. Okay.

10 MR. HARBACH: What is 331?

13 Q. Okay.

15 Q. And I'll ask you -- do you have Exhibit 2, 11:24:23

18 Q. Okay.

21 Q. Tell me when you are there. 11:24:46 22 A. I'm working on it, sir.

1 Q. Okay. And so there is a long answer on page 11:24:57

2 forty-eight that goes from line twelve to line 11:25:02 3 twenty-three. And I'm not going to read the whole 11:25:06 4 thing, but I want to direct your attention to the 11:25:10 5 second half of that answer.

6 "They are arrested and put in jail by 11:25:19 7 Chinese Communist party.

8 family member, including his son, his 11:25:26 9 daughter, niece, nephew, and his 11:25:28 10 sister-in-law, brothers, they were all 11:25:32 11 threatened, kidnapped, and put in jail 11:25:37 12 without any reason until now, including all 11:25:40 13 of his, like, long-term employee, just like 11:25:43

15 So you are talking about Mr. Ho Wan Kwok 11:25:50

17 A. Can I read the entire from sentence twelve 11:25:58

19 Q. Absolutely.

20 yourself, and let me know when you are finished. 11:26:08 21 A.

22 Okay.

23 Q.

24 My question is the person who you were 11:27:15 25 talking about in this answer, who you refer to as he 11:27:18

1 and his, is Mr. Ho Wan Kwok; correct? 11:27:22

2 A. And reading from the language, of course, 11:27:28 3 this is by -- by the transcript court recorder. 11:27:33 4 Like, it -- reading from the language, it looks like 11:27:39 5 yes. But I am referring to -- as I am starting from 11:27:43 6 the Guo family, is not just his immediate family, the 11:27:47

8 Q.

10 "Mr. Kwok, Miles Kwok, he is number 11:27:56 11 seventh son of the whole family." 11:28:06 12 You are talking about the debtor, 11:28:07

14 A.

15 Q. Okay. And then you describe all of his 11:28:12 16 relatives and the terrible things that happens to 11:28:16 17 them. And then you say that the people to whom that 11:28:21 18 happened include all of his, meaning 11:28:29 19 Mr. Kwok Ho Wan -- all of his long-term employee, 11:28:34 20 just like me; so this is the basis for my question 11:28:41

22 Isn't it true that you are a long-term 11:28:51 23 employee of Mr. Ho Wan Kwok?

24 A. I am a long-term employee for the Guo 11:29:01 25 family. I mean, I didn't remember clearly what was 11:29:09

1 recorded in here. Like, obviously, I was never in 11:29:12

2 jail. I am under threatened, but I was not kidnapped 11:29:17 3 and in jail. I think it is still blamed to my broken 11:29:21 4 English back there.

5 my real -- my meaning as the Guo family.

6 a long-term employee of Guo family. 11:29:32 7 Q.

8 A. Mr. Ho Wan Kwok, he never hired me by 11:29:37

10 Q. Well, who -- who -- first, since you brought 11:29:43 11 it up, who was the person who hired you to work for 11:29:45

13 A. It was a company.

14 Pangu, P-a-n-g-u.

15 Q.

16 And who was the boss of Beijing Pangu when 11:29:59 17 you were hired to work for the Guo family? 11:30:03 18 A.

19 Q. Well, you know, you can ascribe whatever 11:30:11 20 meaning you want to boss, Ms. Wang, but you seem to 11:30:14 21 understand that Qiang Guo is the boss of 11:30:17 22 Golden Spring; so you tell me. 11:30:19 23 A.

24 So Beijing Pangu was owned by the Guo 11:30:22

1 Q. Okay.

2 MR. HARBACH:

3 stay here long, but she brought it up. 11:30:35

5 Q. Ms. Wang, who was it who told you at the 11:30:38 6 very beginning -- when you first started working for 11:30:41 7 the Guo family, who was it who told you you were 11:30:44 8 hired?

9 A. I was advised by the HR department, which 11:30:49 10 I couldn't recall.

11 I couldn't recall.

13 Q. I'm going to apologize for rewinding just 11:31:07 14 for a moment back to an earlier topic.

15 make this clear and efficient. 11:31:24 16 In Exhibit 4, which is your affidavit, you 11:31:32 17 recall that -- that I asked you several questions 11:31:46 18 about what being an administrator for 11:31:49 19 Mr. Ho Wan Kwok's interests meant?

20 A.

21 Q. Okay. So the reason I'm coming back to this 11:31:58 22 is because I neglected to point something else out to 11:32:02 23 you. And it is Exhibit 1; so could you turn to 11:32:07

25 A.

1 So it is not Exhibit 2?

2 back to Exhibit 1, sir; right? 11:32:26 3 Q.

4 A.

6 Q. Okay.

7 Now, could you please scroll forward on the 11:32:35 8 small pages to page forty-six. 11:32:38 9 A.

11 Q. Okay.

12 Now, on this subject of what administrator 11:32:54 13 means, if you'll look down at line twenty of page 11:32:59 14 forty-six, you'll see a question: 11:33:06 15 "QUESTION:

16 not you serve as an administrator for 11:33:12

18 That is Ho Wan Kwok -- for his interests. 11:33:18

20 "ANSWER:

22 "QUESTION:

24 "ANSWER:

2 A.

3 Q. Now, you have already told us that you -- 11:33:38 4 you have, in fact, done some translation for 11:33:41 5 Mr. Kwok -- Mr. Ho Wan Kwok; right? 11:33:45 6 A. I translate for him -- translated for him, 11:33:48

8 Q.

9 And if -- you also said -- it also says that 11:33:53

12 A. I mean that I -- I testified as an 11:34:03 13 administrator for Mr. Ho Wan Kwok and I help him as 11:34:09 14 per Mr. Qiang Guo's instruction, including, like, 11:34:13 15 help him to translate, make him understand, include, 11:34:17 16 like, assist as he needs -- right? -- to support him. 11:34:22 17 It does not mean I have -- I have a title called 11:34:27 18 assistant; so if that is what you are looking for. 11:34:30 19 Q.

20 A. My meaning was I help him to understand as 11:34:33 21 to language and support him as he needed as his son's 11:34:36

23 Q. Okay. And so what does that mean, other 11:34:41 24 than the translation work, when you say that assisted 11:34:43 25 means support him as needed?

1 did you do for him back in 2018? 11:34:51

2 MR. ROSEN: Objection.

3 clarify, when you use the word you, are you referring 11:34:59 4 to Golden Spring, or are you referring to the witness 11:35:01

6 MR. HARBACH:

7 I believe when -- when she was deposed in 11:35:08 8 2018, she was testifying in both her capacity as 11:35:11 9 a representative of Golden Spring and in her personal 11:35:16 10 capacity; so she is going to have to clarify that for 11:35:20

12 MR. ROSEN:

13 THE WITNESS:

15 Q. Okay. And in any case, your role as an 11:35:31 16 administrator for Mr. Ho Wan Kwok's interests, that, 11:35:35 17 according to you, was in your capacity as president 11:35:42 18 of Golden Spring (New York) Limited; correct? 11:35:46 19 A. I was requested by Mr. Qiang Guo to help 11:35:52 20 back in 2018; that is correct. 11:35:57 21 Q. Okay.

22 understand my question because since Mr. Rosen 11:36:04 23 helpfully raised capacity, I want to make sure we get 11:36:07

1 So bearing in mind that we are talking about 11:36:13

2 what being an administrator for Mr. Ho Wan Kwok's 11:36:18

3 interests means -- that is what we're talking 11:36:23

4 about -- I'm going to direct you back to Exhibit 1 -- 11:36:26

5 correction.

6 A. So Exhibit 4, sir; right?

7 talking about?

8 Q.

10 A. I'm here. 11:36:48 11 Q. And this affidavit, which you have already 11:36:49 told us you signed and swore to as being true and 11:36:53 correct, states that you're serving as an 11:36:57 administrator for the interests of Mr. Ho Wan Kwok 11:37:02 and his family was in your capacity as president of 11:37:07 Golden Spring (New York) Limited; isn't that correct? 11:37:14 17 A. I was hired by Golden Spring (New York), and 11:37:23 I take instruction from the owner of Golden Spring 11:37:28 (New York). And I was available to support his 11:37:32 family, including his father. That is what the 11:37:36 capacity, to me, means in here. 11:37:40 22 Q. And -- and what you just described, 11:37:43 according to you, was in your capacity as president 11:37:45 of Golden Spring (New York) Limited; isn't that 11:37:50 right? 11:37:54

1 A. I don't understand, sir.

2 I am available. I am here.

3 Mr. Qiang Guo requested me to do.

4 understanding about capacity.

5 capacity you are talking, that is the same, yes. 11:38:10 6 Q.

7 All I'm trying to confirm is that that was 11:38:15 8 what you were supposed to do, according to you, as 11:38:19 9 president of Golden Spring (New York) Limited was 11:38:23 10 translate for Mr. Kwok Ho Wan and cater to his 11:38:30 11 personal needs; is that right?

13 MR. ROSEN:

15 THE WITNESS:

16 My capacity as president of Golden Spring 11:38:46 17 (New York) is to work as per the owner of company 11:38:49 18 requesting needs to me, including assist his father, 11:38:55 19 translate for his father, and that including here I'm 11:38:58 20 being deposed today; right? 11:39:02 21 And sign the affidavit.

22 things, I mean, if I may say, not only as you just 11:39:08 23 tried to describe me as assistant or translator, if 11:39:12 24 that is helpful to you, sir. 11:39:17

2 Q. Well, translator and assistant, again, 11:39:18 3 Ms. Wang, those were your words, not mine.

4 read them to you from a transcript.

5 doing is trying to explore what your job as president 11:39:28 6 of Golden Spring (New York) Limited was.

7 have -- you have explained part of that to us, 11:39:34 8 I think. And I'm just trying to understand what 11:39:38

10 Besides being a translator, can you tell me 11:39:53

12 A.

13 Q. About what you meant when you said you were 11:39:59

15 A. That is what I -- that is -- that was not, 11:40:09 16 I mean, in my language.

17 I don't have this as my native language when I named 11:40:19 18 that, which means I offered that support and service. 11:40:23 19 I don't have a title called translator or assistant. 11:40:26

21 Q.

22 A. -- I don't have it, yeah; so I offered that 11:40:32

24 Q.

25 A. This is what I'm meaning, if that is 11:40:34

1 helpful. 11:40:37 2 Q. Got it. 11:40:37 3 Tell me what -- now, what you just meant 11:40:38 4 right now when you said support. 11:40:40 5 Besides translation, what else? 11:40:42 6 A. For example, I am being deposed right now in 11:40:44 7 this bankruptcy. 11:40:51 8 Q. Okay. 11:40:53 9 A. This is as per Mr. Qiang Guo's instruction; 11:40:53 10 right? 11:40:57 11 And so.... 11:40:57 12 Q. Is your testimony -- I don't think this is 11:40:58 13 what you are saying, but I'll ask it anyway because 11:41:00 14 it is a fair inference from your words. 11:41:03 15 Is your testimony today in support of 11:41:06 16 Mr. Ho Wan Kwok? 11:41:08 17 MR. ROSEN: Objection. 11:41:11 18 You can answer that. 11:41:14 19 THE WITNESS: I am testimony -- I am testify 11:41:15 20 today for a bankruptcy like a -- I believe the topic 11:41:19 21 is about DIP loan; right? 11:41:24 22 BY MR. HARBACH: 11:41:27 23 Q. And I would love to get there, but we -- 11:41:27 24 we're -- well, let me just ask one more time. 11:41:29 25 I understand that you are not -- you are 11:41:32 Page 94

1 saying that assistant was not your title. 11:41:36

2 I understand that. I understand that your title was 11:41:39

3 all those titles I recited several times now at 11:41:42

4 Golden Spring (New York) Limited.

5 understand that according to you, in your capacity as 11:41:50 6 president, you served as an administrator of the 11:41:54 7 interests of Mr. Ho Wan Kwok and the family. 11:41:58 8 You were asked at a deposition about what 11:42:04

serving as an administrator meant, and you said 11:42:07 translator and assistant. Now, we all know what 11:42:12 a translator is, and that is clear. It is clear that 11:42:18 you performed that service for Mr. Kwok. 11:42:21

13 All I'm trying to understand, Ms. Wang, is 11:42:24 14 what else you did for him, and so far the only thing 11:42:27 15 you have said is testify at this deposition. 11:42:31 16 Is there anything else? 11:42:33 17 A. Yes. 11:42:37 18 MR. ROSEN: Objection. 11:42:38 19 You can answer. 11:42:40 20 THE WITNESS: Yes. 11:42:42 21 BY MR. HARBACH: 11:42:43 22 Q. Okay. What else? 11:42:44 23 A. For example, Mr. Qiang Guo, obviously, he 11:42:47 24 instructed Golden Spring to pay his father's, like, 11:42:54 25 food, clothes, and, like, including this -- they call 11:43:01

1 the lifestyle -- I mean, take care of his father. 11:43:10

2 Q. When did he give you that instruction? 11:43:13 3 A. Oh, I don't recall.

4 time ago. I mean, son take care of the father. 11:43:22 5 I mean, that is kind of natural to me, so 11:43:25 6 Q. Well, I'm not going to quarrel with -- with 11:43:28 7 whether it is natural or not. 11:43:32 8 My only question is you just said that -- 11:43:34 9 that Mr. Qiang Guo gave you the instruction that you 11:43:39

11 And my question is when?

12 time ago?

13 A.

14 Q.

15 A. It should be longer than more than a month. 11:43:57 16 Q. Okay. Had he given you that instruction by 11:44:00 17 the time of your deposition in October of 2018? 11:44:03 18 A.

19 Q. Had he given you that instruction by the 11:44:08 20 time of your trial testimony in May of 2019? 11:44:12 21 A.

22 Q.

23 A.

24 Q. Well, did he give you that instruction 11:44:24

1 A.

2 Q. How long has Golden Spring (New York) been 11:44:40 3 paying for Mr. Kwok's lifestyle, as you just said? 11:44:57 4 A. How long? I believe since I was appointed. 11:45:03 5 I mean, I don't recall clearly. I don't recall.

7 Q. Okay. Well, you said two things there.

8 said you believe since you were appointed and you 11:45:22 9 have said you don't recall; so I have -- I'm going to 11:45:25 10 have to ask you to tell me which it is. 11:45:29 11 A. I don't recall.

12 or guess because when I was appointed, as 11:45:37 13 I testified, like, a couple of minutes ago, which was 11:45:42 14 true, Mr. Qiang Guo was operating and running his 11:45:46 15 business; so that is the reason I correct my answer 11:45:50 16 to be I don't recall because I was not paying that by 11:45:53 17 myself.

18 Q.

19 What role did you have -- as president, 11:46:01 20 secretary, treasurer, and director of Golden Spring, 11:46:13 21 what role did you have in making sure that 11:46:18 22 Mr. Kwok's -- Mr. Ho Wan Kwok's lifestyle needs were 11:46:24

24 A.

25 Can you please repeat your question? 11:46:33

1 Q.

2 As president, secretary, treasurer, and 11:46:36 3 director of Golden Spring (New York) Limited, what 11:46:42 4 role did you have in ensuring that Mr. Ho Wan Kwok's 11:46:47 5 lifestyle needs were paid for? 11:46:53 6 A. What role I ensured with?

7 That's -- that's the question you were 11:47:05

9 Q.

10 And I'll try one more time in English, and 11:47:08 11 then we might need to use Ms. Johnston. 11:47:11 12 A.

14 Q. It's okay.

15 You have stated that Mr. Qiang Guo gave you 11:47:21 16 instruction to take care of his father, I mean, more 11:47:25 17 or less. You don't remember exactly when he gave you 11:47:35 18 that instruction, but it was a long time ago. 11:47:37 19 Have I got that right so far? 11:47:41 20 A.

21 Q. Okay. And I'm asking now, in your role as 11:47:47 22 president, and all those other titles, of 11:48:00 23 Golden Spring (New York) Limited, what did you do to 11:48:03 24 ensure that Mr. Ho Wan Kwok and his lifestyle needs 11:48:13 25 were taken care of? Do you understand the question? 11:48:20

2 Q. Okay. So what is the answer? 11:48:29

3 A. For example, like, I communicate with 11:48:34

4 Mr. Qiang Guo about the fund, including this depo. 11:48:42 5 He take care of the request and then make sure the 11:48:52 6 funds in there to take care of his father. 11:49:01 7 Q. We're going to -- we're going to talk about 11:49:04

8 the fund in just a moment. But you mentioned 11:49:10 9 lifestyle needs earlier, things like clothing, food, 11:49:14 10 transportation -- basics. 11:49:22 11 As president of Golden Spring (New York) 11:49:29 12 Limited, were you involved in paying for or providing 11:49:31 13 those things for Mr. Ho Wan Kwok? 11:49:39 14 A. Yes. 11:49:45 15 Q. Please tell me what you did. 11:49:46 16 A. Like, I will review the bills and verify -- 11:49:52 17 if there is any need to verify -- and process the 11:50:03 18 payment in clothing. 11:50:07 19 Q. What types of bills? 11:50:08 20 A. Like, clothes. Like, food -- grocery food. 11:50:11 21 Q. And -- and are these credit card bills or 11:50:19 22 are they receipts directly from the vendor or what? 11:50:21 23 A. I believe they are both. 11:50:26 24 Q. Okay. 11:50:28 25 A. It is a mixed. 11:50:29

1 Q.

2 A. Which bill you were talking about, sir? 11:50:33 3 Q.

4 A. I mean, some of them, they go through from 11:50:41 5 the card. Some of them we received it from the -- 11:50:45

7 Q. Okay.

8 receive from Mr. Ho Wan Kwok directly? 11:50:56 9 A. Directly?

10 Q. How do you know whether -- any of the 11:51:06 11 expenses that you review to take care of 11:51:10 12 Mr. Ho Wan Kwok's lifestyle, how do you know or 11:51:14 13 verify, as you said, whether any of them are actually 11:51:19

15 A. I mean, Mr. Qiang Guo, he requested 11:51:25 16 Golden Spring to take care of both his parents; so 11:51:32 17 I mean, only, like, is -- is clarified, like this is 11:51:38 18 his father's clothes and then we obviously will 11:51:45 19 verify from that.

20 Q.

21 A. -- grocery bill, I think it is more, like, 11:51:52 22 mixed for the mom and that. 11:51:55 23 Q. Okay. And, number one, how do you know that 11:51:57 24 it is Mr. Ho Wan Kwok's clothing that is being 11:52:01 25 purchased?

1 A. I verifying with the vendor directly. 11:52:07

2 Q.

3 So you -- you ask a vendor whether the 11:52:19 4 clothing was purchased by Mr. Ho Wan Kwok? 11:52:22 5 A. Yeah.

6 women's clothes are pretty obvious; right? 11:52:32 7 But I do need to verify, yes. 11:52:35 8 Q. Yeah. I get the difference between men's 11:52:38

10 So is it the case that any -- any -- any 11:52:44 11 charge that is obviously for men's clothing you 11:52:49 12 assume is Mr. Ho Wan Kwok, and any charge that is for 11:52:53 13 women's clothing you assume is for his wife? 11:52:59 14 A. I don't assume.

15 because I need to report back the funds; right?

16 the financials to the owner of the company clearly -- 11:53:15 17 Q.

18 A.

19 Q.

20 A.

21 Q. Let's -- do you -- do you review any credit 11:53:22 22 card bills as part of that process? 11:53:25 23 A.

24 Q. Okay. And when you re- -- when you review 11:53:30 25 a credit card bill, let's just pretend there is 11:53:35

1 a charge on there for -- yeah, I don't know -- a stay 11:53:39

2 in a hotel. Let's just take that as an example. 11:53:45 3 How do you verify who made the charge? 11:53:48 4 A. Like, a hotel, you mean; right?

6 Q. I'm taking that as an example. 11:54:02 7 A. If hotel, we obviously, Golden Spring, will 11:54:05

9 Q. To verify that the charge was made? 11:54:10

11 That is part of internal, I mean, audit. 11:54:14

13 Q. Okay. So how about figuring out who used 11:54:19 14 the credit card?

15 A. You -- I don't follow your question, sir. 11:54:26 16 Who used credit cards?

17 Mr. Ho Wan Kwok, how he used credit card; right? 11:54:36

19 That -- that is -- that is a possibility, 11:54:41 20 but I don't know.

22 He doesn't use Golden Spring's credit cards. 11:54:45 23 Q. Does Golden Spring have credit cards? 11:54:48

25 Q. Okay. Does Golden Spring have any credit 11:54:53

2 A.

3 Q. Okay. Does Mr. Kwok have access to the 11:55:03

5 A.

6 Q. What about his wife?

7 access to the Golden Spring debit card? 11:55:18 8 A.

9 Q. You are the treasurer of Golden Spring 11:55:25

11 A.

12 Q. You -- you really don't know whether 11:55:38 13 Ho Wan Kwok's wife has access to the company debit 11:55:43

15 A. She had one before, but I'm not sure whether 11:55:49 16 that one is still activated. 11:55:53 17 Q.

18 A.

19 Q.

20 A. What do you mean, can I do better than that, 11:56:05

22 Q.

23 MR. ROSEN:

24 Can you please ask the witness directly what 11:56:15

1 MR. HARBACH: Sure.

4 Q. Ms. Wang, can you give us a more precise 11:56:23 5 date range during which Mr. Ho Wan Kwok's wife had 11:56:28 6 access to the Golden Spring (New York) debit card? 11:56:32 7 A.

8 Q. Do you recall the last time that she -- 11:56:42 9 meaning Mr. Ho Wan Kwok's wife -- used the 11:56:46 10 Golden Spring (New York) debit card? 11:56:49 11 A.

12 Q. Did you, as president and treasurer of 11:56:54 13 Golden Spring (New York) Limited, authorize 11:56:59 14 Mr. Ho Wan Kwok's wife to use the Golden Spring 11:57:04

16 A. Authorized? I believe yes.

17 Mr. Qiang Guo requested Golden Spring to do that. 11:57:17 18 Q. But you don't recall when that was? 11:57:20 19 A.

20 Q. Okay. And I believe you testified a moment 11:57:27 21 ago that to your knowledge Mr. Ho Wan Kwok has never 11:57:34 22 used the Golden Spring (New York) debit card; is that 11:57:38

24 A. He never has Golden Spring (New York) debit 11:57:46

1 Q. Has he ever used the debit card number to 11:57:55

2 purchase anything, to your knowledge? 11:57:58 3 A.

4 Q. Has he ever asked you -- "he" meaning 11:58:03

6 Has he ever asked you to purchase anything 11:58:09 7 for him in your capacity as president of 11:58:12

9 A.

10 Q. Okay.

11 anything he has asked you to purchase for him? 11:58:25 12 A. I mean, I don't recall the details, but it 11:58:29

14 Q. You don't remember a single thing that 11:58:34 15 Mr. Ho Wan Kwok has asked you to purchase for him? 11:58:37 16 A.

17 Q. How many times has it happened that he has 11:58:44 18 asked you to purchase something for him? 11:58:49 19 A.

20 Q.

21 A.

22 Q.

23 A.

24 Q. On the occasions when Mr. Ho Wan Kwok has 11:59:03 25 asked you to purchase something for him, what do you 11:59:15

2 A. As per Mr. Qiang Guo's instruction, I help 11:59:20 3 him, yes.

4 Q. Okay. Have -- has -- have you ever -- 11:59:32 5 has -- have you ever refused a request from 11:59:37 6 Mr. Ho Wan Kwok that you purchase something for him? 11:59:41 7 A.

8 Q.

9 A. I don't recall.

10 report it to Mr. Qiang Guo, and if he reject it, 11:59:56

12 Q. Okay. Is your -- so I want to make sure 12:00:03

14 Is it your testimony that every time 12:00:07 15 Mr. Ho Wan Kwok asks you to buy something for him 12:00:10 16 that you consult his son to get permission?

18 A. Not every time.

19 example, buy coffee; right? 12:00:27 20 Obviously I don't need to consult with 12:00:28

22 Q. Okay. How do you decide when to consult 12:00:32 23 with Mr. Kwok Ho Wan's son about a purchase that 12:00:35 24 Mr. Kwok Ho Wan wants you to make? 12:00:43 25 A. I don't recall.

1 Q. Do you have any -- any thoughts about that? 12:00:49

2 A.

3 Q.

4 I'm -- I'm just asking you in general.

5 not asking you about legal fees yet, although 12:01:00 6 hopefully we will get there. 12:01:05 7 I'm asking you about in general if 12:01:06 8 Mr. Ho Wan Kwok says, hey, Yvette, I would like you 12:01:08 9 to buy me X, how do you know whether just to buy X or 12:01:14 10 whether to get his son's permission?

12 A. Well, yearly, like, his food and his coffee 12:01:30 13 and then his transportation, those lifestyle were 12:01:34 14 already approved by Mr. Qiang Guo; so you already -- 12:01:40 15 Golden Spring just to go ahead to buy or purchase and 12:01:44 16 then report back to Mr. Qiang Guo; so anything 12:01:49 17 except -- besides -- except which words?

18 that, we obviously, Golden Spring, need to escalate 12:01:57 19 to Mr. Qiang Guo to get approval. 12:02:02 20 Q.

21 And so if I -- if I have you correctly, 12:02:05 22 things like food, clothing, transportation -- those 12:02:08 23 things do not require specific approval of 12:02:15 24 Mr. Qiang Guo and, in your mind, you can just buy 12:02:19 25 them for Mr. Kwok without getting his permission. 12:02:26

2 A. Yeah. That is the instruction was given to 12:02:31

6 Q. Is that true, no matter how expensive the 12:02:40

8 A. Sir, what -- what is your range about 12:02:44

10 Q. Well, let's take -- let's take 12:02:50 11 transportation as an example. 12:02:53 12 Are you aware that -- that Mr. Kwok 12:02:54 13 frequently travels in a Maybach limousine? 12:02:57 14 A. Am I aware?

15 Q. Do you know -- do you know what a limousine 12:03:09

17 A. Limo, yes.

18 Q. Okay. And do you know what a Maybach is? 12:03:15

20 Q. Okay.

22 Q. Isn't it true that Mr. Ho Wan Kwok 12:03:22 23 frequently travels by Maybach? 12:03:27 24 A. Sir -- sir, I know Mileson want his father 12:03:32 25 to be safe and secured; so that is the thing I know. 12:03:38

1 But I don't know, like, frequency.

2 Obviously, I am not following his father every day. 12:03:48

4 Q. Does -- does Golden Spring -- I'll ask you 12:03:51 5 to accept for purposes of this deposition today -- 12:03:54 6 just take my word for it that within the last month 12:03:59 7 Mr. Kwok has traveled at least once by Maybach. 12:04:02

10 My question for you is is that Maybach 12:04:11 11 transportation that Golden Spring (New York) has paid 12:04:17

13 A. Golden Spring (New York) pays -- pays the -- 12:04:21 14 the gasolines and -- yeah. The gasolines.

16 Q.

17 A. -- what transportation we are paying. 12:04:32 18 Q. Does Golden Spring (New York) own any 12:04:35

20 A. Oh, I -- I couldn't remember, like, if 12:04:38 21 Maybach owned by Golden Spring or not.

22 Golden Spring owns a couple of cars.

23 ultimately owned by Mr. Qiang Guo. 12:04:53 24 Q. Yeah.

25 Tell me about the cars that Golden Spring 12:04:57

1 owns. You just mentioned that there are a couple. 12:04:59

3 A. I'm not car person; so I have to find out. 12:05:07 4 Q. Okay.

5 A.

6 Q. And you don't know whether one of the cars 12:05:16 7 that Golden Spring (New York) owns is a Maybach; is 12:05:20

9 A. I don't know because this is Mr. Mileson, 12:05:26 10 like Mr. Qiang Guo, he purchased directly. 12:05:31 11 Q.

12 A.

13 Q.

14 But I'm asking about Golden Spring 12:05:37

17 I'm asking about Golden Spring (New York) 12:05:41 18 Limited, of which you are the president, treasurer, 12:05:44 19 secretary, and director.

20 whether Golden Spring (New York) Limited owns 12:05:52

23 A. I don't recall.

24 Q. Okay.

25 Golden Spring (New York) pays for Mr. Ho Wan Kwok's 12:06:07

2 A.

3 Q. And that would include transportation by 12:06:16

5 A.

6 Q. That would include arranging for a leased 12:06:24 7 vehicle if that is how he wanted to travel; correct? 12:06:32 8 A.

9 Q. Yeah. I heard that.

10 figure out who owns the vehicle, Ms. Wang. 12:06:45 11 Do you know whether Golden Spring (New York) 12:06:49 12 Limited has rented or leased a Maybach in order to 12:06:52 13 transport Mr. Ho Wan Kwok?

14 A.

15 MR. HARBACH:

16 the witness up on her offer to get back to us on the 12:07:15 17 types of cars that Golden Spring (New York) owns, 12:07:19 18 and, in particular, whether they own any Maybach 12:07:24 19 automobiles, if that is okay with you. 12:07:28 20 MR. ROSEN: We'll take it under advisement. 12:07:31 21 MR. HARBACH:

22 MR. ROSEN:

23 MR. HARBACH: All right.

24 THE WITNESS:

2 Q.

3 A.

4 Q. If -- if you would like to take a break now, 12:07:56

6 MR. HARBACH:

7 Jeff who takes us off, but I will suggest reconvening 12:08:03

10 MR. ROSEN:

11 MR. HARBACH:

12 THE VIDEOGRAPHER:

11 MR. HARBACH:

12 THE VIDEOGRAPHER:

16 THE VIDEOGRAPHER:

20 Q. Good afternoon, Ms. Wang -- Ms. Wang. 13:01:46 21 One little loose end that has nothing to do 13:01:48 22 with what I was asking you about before lunch. 13:01:53 23 Okay? Do you know someone called Yu Yong? 13:01:56

25 A.

1 Q. Okay.

2 A.

3 Q. Okay.

5 A. When I met with her, she was working 13:02:26 6 together with the family also. 13:02:29 7 Q.

8 A.

9 Q.

10 A.

11 Q.

12 A. I believe with -- with Mr. Qiang Guo's 13:02:45

14 Q.

15 A. -- but I don't have the details. 13:02:52 16 Q. Okay. And approximately when was that that 13:02:54

18 A.

19 Q. Okay.

21 Who set up Golden Spring (New York) Limited? 13:03:07 22 A. In my understanding, it was set up by 13:03:13

24 Q.

25 understanding, do you know that or did somebody tell 13:03:23

2 A. This is I learned afterwards. I believe 13:03:27 3 there will be -- there will be law firms supporting 13:03:31

4 by him, but he set up the company. 13:03:34

5 Q.

6 A. I got to know later on -- not, like, when he 13:03:39 7 set up the company -- he was trying to do business 13:03:46 8 outside of China, like, mainly in the U.S. here. 13:03:50 9 Q.

10 A. Like, business related to real estate, 13:03:56 11 investment -- like a diversified business. 13:04:02 12 Q. Okay. Who funded Golden Spring (New York) 13:04:06

14 A. I learned afterwards Mr. Qiang Guo, he 13:04:12 15 arranged the fund -- fund the Golden Spring. 13:04:22 16 Q. When you say he arranged it, do you mean 13:04:26 17 that he, himself, provided the money? 13:04:29 18 A. Hmmm.

19 He arranged via his -- another company. 13:04:35 20 I believe it is called Bravo Luck. 13:04:40 21 Q.

22 And so your understanding is that the money 13:04:45 23 that funded Golden Spring (New York) Limited when it 13:04:48 24 was created came from Bravo Luck? 13:04:55 25 A.

1 Q.

2 A.

3 Q. Have you ever spoken to Mr. Ho Wan Kwok 13:05:05

5 A. Hmmm.

6 Q. Have you ever spoken to Mr. Ho Wan Kwok 13:05:16 7 about the source of money that was used to fund 13:05:20 8 Golden Spring (New York) Limited when it was created? 13:05:24 9 A.

11 Q. Do you know how Bravo Luck got the money 13:05:34 12 that you say funded Golden Spring (New York) Limited? 13:05:41 13 A.

14 Q. What is -- what was Golden Spring 13:05:47 15 (New York)'s business purpose when it was created? 13:05:54 16 A. Oh, Golden Spring was created as a family 13:05:57 17 office owned by Mr. Qiang Guo; so Mr. Qiang Guo was 13:06:04 18 planning, as I said, to develop and expand the 13:06:09 19 business in the United States, including, like, as 13:06:14 20 I said, investment, real estate, and the business 13:06:21 21 he -- he was doing by then. 13:06:25 22 Q. Where does Mr. Qiang Guo live today?

24 A.

25 Q.

1 MR. ROSEN: Objection.

2 is the relevance of this, David? 13:06:46 3 MR. HARBACH:

4 witness' most recent answer about the business 13:06:52 5 purpose of Golden Spring.

6 he, Qiang Guo, created it to do X, Y, and Z.

7 trying to inquire about how long he was actually in 13:07:05 8 the country after Golden Spring was created.

10 MR. ROSEN: Just note for the record that we 13:07:13 11 are all here in different locations at this 13:07:14 12 deposition. And in today's world where your -- where 13:07:18 13 your seat is doesn't necessarily mean a whole lot. 13:07:23 14 But with that said, I would instruct the 13:07:26

17 Q. The -- the question was when -- or how long 13:07:30 18 has Mr. Qiang Guo lived in the UK. 13:07:36 19 A. For years.

20 Q. Are you finished with your answer? 13:07:51

22 A. My -- my answer was not four, f-o-u-r, as 13:08:04 23 years.

24 Q.

25 A.

1 Q.

2 A.

3 Q. Could it be more than ten years? 13:08:09 4 A.

5 Q. How long, if -- if you know, how long after 13:08:13 6 Golden Spring (New York) Limited was created did 13:08:24 7 Mr. Guo -- Qiang Guo move to the UK? 13:08:28 8 A.

9 Q. All right. Do you know -- what can you tell 13:08:40 10 us about what Golden Spring (New York) Limited has 13:08:47 11 done to advance the business purposes you just 13:08:50

13 A. Mr. Qiang Guo was in the United States in 13:08:55 14 2015, and then he travels a lot also.

15 obviously, he set up the company, and then we develop 13:09:12 16 business structure and plan from there; so that is 13:09:16 17 still his direction, which we have been doing until 13:09:22 18 his father started to do his whistle-blower moment. 13:09:28 19 Q. What was the business plan in the beginning? 13:09:33 20 A.

21 Q. Okay. In, I believe, you mentioned real 13:09:41

24 A. We started from real estate.

1 Q. Okay.

3 A. And operate as a family office in New York 13:10:00 4 here to support other family projects. 13:10:09 5 Q. Okay.

7 What other family projects has Golden Spring 13:10:23 8 (New York) Limited supported? 13:10:27 9 A. Including their project -- real estate. 13:10:29 10 Like, including, like, interviews and handouts.

11 architecture, designer, like, real estate-related 13:10:45 12 vendors, and then we, like, facilitate and coordinate 13:10:50

14 Q. Is Golden Spring (New York) Limited a -- 13:10:55

16 A.

17 Q. And what is its source of income? 13:11:03 18 A. Source of income?

19 a for-profit company, but we are not turning to, 13:11:16 20 like, make revenue yet; so the source of income is 13:11:23 21 supposed to be, like, a -- we build up the project 13:11:26 22 under the family plan, and then we start to make 13:11:31 23 profit from those projects -- investment projects. 13:11:36 24 Q. Okay. So the -- the company invests money 13:11:40 25 and hopes to make money from investments. 13:11:43

2 A. That's part of the source of income, yes. 13:11:48

4 Q. Does the -- does the company, Golden Spring 13:11:52 5 (New York) Limited, have any clients?

7 A. I mean, family office typically, to our 13:12:02 8 understanding, is support and serve for the family 13:12:08 9 business; so our clients are the family. 13:12:13 10 Q. Okay. And that includes Mr. Ho Wan Kwok, 13:12:15

12 A. He is the person -- the owner of the company 13:12:21 13 requesting Golden Spring to support; so Golden Spring 13:12:28 14 does not, like, plan or, like, having profit from his 13:12:31 15 father, which, like, we didn't think about that and 13:12:39

17 Q. Well, you just said a moment ago that 13:12:45 18 Golden Spring (New York) limited's clients was the 13:12:47 19 family.

21 The reason I asked that question is because 13:13:01 22 Mr. Ho Wan Kwok is a member of the family, is he not? 13:13:04 23 A. So this is my answer.

24 MR. ROSEN: Hold off answering, please, just 13:13:15

1 I'd object on the -- on the grounds that I'm 13:13:18

2 not sure that your use of the word client is -- is 13:13:23

4 Could you clarify that, please? 13:13:25 5 MR. HARBACH:

7 Q. Ms. Wang, do you know what I mean by the 13:13:33

9 A. Client means that you offer services to get 13:13:39

11 Q. Okay. A moment ago you said that the client 13:13:44 12 of Golden Spring (New York) Limited was the family. 13:13:51 13 Did you mean that in the sense that you just 13:13:55 14 described, or did you mean that in a different way? 13:13:59 15 A. I mean the client is the Guo family. 13:14:02 16 I mean, they -- they are, as I testified before, 13:14:06 17 like, a hundred family member.

18 clients.

19 Q.

20 A. So as a client of Golden Spring, which 13:14:19

22 Q. Okay. Do you mean that members of the 13:14:23

24 A. I mean if Golden Spring offered a service 13:14:31 25 and then helped them to invest successfully, yes. 13:14:34

1 Golden Spring would be paid. 13:14:39

2 Q. Okay.

3 Mr. Ho Wan Kwok part of the family that is a client 13:14:45 4 of Golden Spring (New York) Limited? 13:14:50 5 MR. ROSEN:

6 It -- the -- is your question is he 13:14:58

7 individually a client? Because what you asked is is 13:15:01 8 he part of the family that is a client. 13:15:05 9 MR. HARBACH: Well, I'm sorry for -- for -- 13:15:08

I'm really not meaning to be confusing. 13:15:11 BY MR. HARBACH: 13:15:14 12 Q. I understood, Ms. Wang, you to say a moment 13:15:14 ago that the family -- which is composed of numerous 13:15:17 people, you said. 13:15:22 15 That the family is a client of Golden Spring 13:15:22 (New York) Limited; is that correct? 13:15:26

17 A. The family and their family member who are 13:15:29 18 the business people; correct? 13:15:36 19 They are the Golden Spring's clients. Of 13:15:37 20 course, I don't mean that like in the minor kids; 13:15:40 21 right? 13:15:44 22 So I made that very clear. 13:15:44 23 Q. Is Mr. Ho Wan Kwok a member of that family? 13:15:46

24 A. He is one of the family member, yes. 13:15:50 25 Q. To your knowledge, has Mr. Ho Wan Kwok ever 13:15:53

1 contributed or paid any money to Golden Spring 13:16:06

3 A.

5 Q. To your knowledge, has any business 13:16:17 6 organization that Mr. Ho Wan Kwok owns or controls 13:16:26 7 ever contributed any money to Golden Spring 13:16:32

9 MR. ROSEN:

10 You can answer the question. 13:16:40 11 THE WITNESS:

13 Q. And you -- as the treasurer of Golden Spring 13:16:49 14 (New York) Limited, would that be something you would 13:16:53 15 expect to know if it had happened? 13:16:56 16 A.

17 MR. ROSEN:

19 THE WITNESS:

20 treasurer of Golden Spring, I didn't see any money 13:17:11 21 come from Mr. Ho Wan Kwok.

22 look at him as a client; so he is a family member, 13:17:17 23 but he is not our kind of like prospective client. 13:17:21 24 He is the owner.

25 like, it -- that's our understanding. 13:17:31

2 Q. He, in fact, is the owner, isn't he, 13:17:33

4 MR. ROSEN:

5 THE WITNESS:

7 Q. Were you an employee or a director or 13:17:46 8 officer of Golden Spring at the time that it was 13:17:53

10 A.

11 Q.

12 A.

13 Q. Returning to my question about Golden Spring 13:18:06 14 (New York) Limited's source of income, is there 13:18:16 15 anything else in that category, other than returns on 13:18:22

17 A. What do you mean?

18 income besides what I reply to you before? 13:18:38 19 Q.

20 A. Okay. So that would be our major source of 13:18:42 21 income. Like, a family office -- I mean, in my 13:18:45 22 understanding you already do investment; so when you 13:18:51 23 investment, you get revenue, and then we got paid, 13:18:54

25 Q.

1 I'm asking you whether there was anything 13:18:58

3 A. As far as I know, like, that is all I know. 13:19:03 4 Q.

5 A. That is the plan.

6 office -- right? -- we are supposed to do investment 13:19:12 7 and make revenue -- make revenue.

8 a law firm. I am not other, you know, service 13:19:18 9 company. And then any other source of income 13:19:20

11 Q. Does Golden Spring (New York) Limited have 13:19:24

13 A. You are asking which time apparent, sir? 13:19:30 14 Q.

15 A.

16 Q.

17 A.

18 Q.

19 MR. ROSEN: Objection.

20 issues involved here, and we're -- I understand that 13:19:59 21 Golden Spring's bank accounts have been shut down as 13:20:06 22 part of what has been described to me as a harassment 13:20:09 23 scheme; so I would ask at this point not to 13:20:13 24 disclose -- the witness not to disclose the location 13:20:16

1 MR. HARBACH: Okay.

2 to disregard your instruction.

3 another question, and if you want to include this 13:20:28 4 under your objection, please do.

7 Q. Ms. Wang, is Golden Spring (New York)'s bank 13:20:35

9 A.

10 Q. What is the approximate current balance in 13:20:43

12 A. I mean, for the safety, same reason.

13 very hesitant to tell you because PAX already, like, 13:21:05 14 harassed all Golden Spring's bank account. 13:21:09 15 So we are talking about DIP loan; right? 13:21:14 16 Q.

17 You know the reasons that the -- that the 13:21:19 18 deposition has been noticed, and I'm not going to get 13:21:21 19 into a debate with you about whether the question is 13:21:26

21 My question is what is the approximate 13:21:30 22 balance in Golden Spring's one bank account in the 13:21:33

24 MR. ROSEN:

25 like, if it is acceptable to counsel, to take a short 13:21:44

1 recess to discuss this with my client. 13:21:50

2 MR. HARBACH: Of course.

3 THE VIDEOGRAPHER:

7 THE VIDEOGRAPHER:

10 MR. HARBACH:

11 anything on the record here or no? 13:34:11 12 MR. ROSEN:

13 I did not need to put anything on the 13:34:15

16 Q. Okay. Ms. Wang, did you speak with anyone 13:34:19 17 else during the break, besides your lawyer? 13:34:21 18 A. I only talked with Mr. Scott Rosen. 13:34:23 19 Q. Okay.

20 The pending question before the break was 13:34:26 21 what is the approximate balance in Golden Spring 13:34:31 22 (New York) Limited's one U.S. bank account? 13:34:37 23 MR. ROSEN: I'm going to object and instruct 13:34:45 24 the witness not to answer that specific question 13:34:47 25 because of Golden Spring's concerns about maintaining 13:34:50

1 the integrity and usability of the bank account in 13:34:54

2 light of credits' rights actions that have been taken 13:34:58

5 Q. Leaving aside the identity of the bank, 13:35:06 6 approximately how much value in liquid assets does 13:35:11 7 Golden Spring (New York) Limited own? 13:35:20 8 A. Golden Spring as -- I mean, enough funds to 13:35:23 9 support Golden Spring, the operation.

10 don't have cash flow issue, so 13:35:37 11 Q. All right.

12 might be a cash flow issue and our judgment about 13:35:44 13 what might be a cash flow issue and Judge Manning's 13:35:48 14 judgment about what might be a cash flow issue could 13:35:54 15 be three very different things. 13:35:57 16 And so that is why I'm asking approximately 13:35:59 17 how much money in liquid assets does Golden Spring 13:36:03

19 A. The balance is changing every day because 13:36:12 20 things happen every day; so I don't want to 13:36:19 21 speculate. Obviously, I did not check the bank 13:36:22 22 balance right now; so I cannot say. 13:36:25 23 Q. What -- what -- when -- when was the last 13:36:27 24 time you checked the balance? 13:36:29 25 A. I don't recall.

1 finance department, they are doing that. 13:36:34

2 Q. Well, you are the treasurer; right? 13:36:37 3 MR. ROSEN: Excuse me.

4 questions setting aside the bank account.

5 question was what is -- what are the values of the 13:36:45 6 liquid assets, setting aside the bank account. 13:36:47 7 MR. HARBACH: Yeah.

8 believe I said -- if I didn't, I'm mistaken.

9 the identity of the bank.

10 interested in getting the identification of the bank. 13:36:59 11 I'm just trying to figure out how much money 13:37:02 12 Golden Spring (New York) Limited has.

14 Q. How much money does the company have?

16 A. The money enough to support all of the daily 13:37:14

18 Q. Are you -- are you unwilling to tell me how 13:37:18 19 much money Golden Spring has or do you not know how 13:37:23 20 much money Golden Spring has? 13:37:27 21 MR. ROSEN: Yeah.

22 here. There are concerns about the integrity and 13:37:31 23 usability of Golden Spring's assets in light of 13:37:36 24 creditor activity that has been conducted by PAX; so 13:37:41 25 these are -- these are sensitive issues.

1 you want to get to questions about where is the loan 13:37:50

2 proceeds going to come from, then we can -- we can 13:37:52 3 certainly go there. But with respect to its current 13:37:56 4 assets, at this point the credit just -- just 13:38:00 5 outweighs any -- any -- any relevancy. 13:38:06 6 MR. HARBACH:

7 objection, and rather than engage it fully, I will 13:38:13 8 just note that we strongly disagree.

9 instructing the witness not to answer, I'll try and 13:38:20

11 MR. ROSEN:

13 Q. Approximately how much profit did 13:38:32 14 Golden Spring (New York) make in the last year? 13:38:35 15 A. Because of the -- the entire, like, PAX -- 13:38:41 16 right? -- this case, I mean, PAX obviously subpoenaed 13:38:49 17 all Golden Spring's bank.

18 understanding, my console device, like, PAX didn't 13:38:57 19 get anything; so -- because PAX specifically hurt our 13:39:01 20 bank relationship in the last year, as you said, 13:39:05 21 I mean, we didn't make profit last year. 13:39:07 22 Q. You did not make a profit last year? 13:39:10 23 A.

24 MR. ROSEN:

2 Q. Was there a -- was there a loss of -- of -- 13:39:18 3 there was a loss of approximately how much last year? 13:39:20 4 Do you understand the question? 13:39:33 5 A.

6 Q.

7 A. But I don't know why it is related to this 13:39:38 8 as well. It is sensitive information, which I have 13:39:42

10 Q. You are -- so you are -- you are -- you are 13:39:45 11 unwilling to answer what the size of Golden Spring 13:39:46 12 (New York) Limited's loss was last year; is that 13:39:51

14 MR. ROSEN: Objection.

15 disclosure deposition for Golden Spring.

16 in light of the pending litigation that is already 13:40:03 17 out there, questions like this are overstepping what 13:40:05 18 the scope of this deposition is supposed to be, 13:40:09 19 which, again, this is a contested matter in 13:40:11 20 a bankruptcy case for a DIP loan, which is being 13:40:15 21 granted on a fully subordinated basis; so that's -- 13:40:19 22 that is what we are here today on, not asset 13:40:23

24 MR. HARBACH:

1 MR. ROSEN:

3 Q. Who made the requests to Golden Spring 13:40:39 4 (New York) for debtor-in-possession financing? 13:40:42 5 A. I -- can I ask a translator to help me 13:40:47

7 Q.

8 MR. HARBACH:

9 Who made the request to Golden Spring 13:41:00 10 (New York) Limited for debtor-in-possession 13:41:02

12 THE INTERPRETER:

13 THE CHECK INTERPRETER:

14 interpreter help with that term? 13:41:45 15 THE INTERPRETER:

16 THE WITNESS:

17 understanding, it is debtor's loan; right?

18 position.

20 Q. Well, Ms. -- Ms. Wang, on several occasions 13:42:01 21 today you have pointed out to me that we are here to 13:42:03

23 Do you know what a DIP loan is? 13:42:10 24 A.

25 It is a loan between the debtor and lender. 13:42:16

1 Q. Okay. Do you know what DIP stands for? 13:42:19

2 A.

3 Q.

4 A. It is a DIP loan displaying between -- 13:42:31 5 I mean, I'm not a lawyer; right? 13:42:42 6 It is a loan between the lender and the 13:42:43

8 Q. Thirty seconds ago you said to me that you 13:42:49 9 know what DIP stands for.

10 I'm just asking for an honest answer. 13:43:00 11 Do you know what DIP stands for?

13 A. It is a loan. It is a loan.

15 Q. Okay. It stands for debtor in possession. 13:43:13

17 It is not a secret, but -- I'll keep going. 13:43:19 18 Who made the request to Golden Spring 13:43:26 19 (New York) for debtor-in-possession financing that is 13:43:32

21 A. The owner of Golden Spring (New York). 13:43:39 22 Q. The owner of Golden Spring (New York) made 13:43:44 23 a request to Golden Spring (New York) for DIP 13:43:52 24 financing?

25 A. I don't understand your question. 13:44:00

1 Q.

2 A. I was not involved in this loan negotiation. 13:44:10 3 Q. Do you know who made the request for the 13:44:15

5 A. I was not involved in the negotiation of 13:44:22 6 this loan. I just got instruction and advice from 13:44:28

8 Q. Okay. Is the answer to this question -- is 13:44:34 9 the answer to my question you don't know? 13:44:39 10 A.

11 Q. You know what?

12 MR. HARBACH:

15 Q. Do you know who made the request to 13:44:57 16 Golden Spring (New York) Limited for the loan that is 13:44:59 17 the subject of today's deposition? 13:45:03 18 A. I don't have personal knowledge. 13:45:09 19 Q. Has anyone told you who made the loan -- who 13:45:11 20 made the request for the loan that is the subject of 13:45:19

22 A.

23 Q. Well, you said you didn't have personal 13:45:31

25 A.

1 Q. And I know what that -- and I know what that 13:45:35

3 So I am asking you whether you have ever 13:45:39 4 learned from anyone else who made the request for the 13:45:42 5 loan that is the subject of today's deposition. 13:45:45 6 A. I heard this from Mr. Qiang Guo about his 13:45:53

8 Q. Who did he say requested the DIP loan? 13:45:59 9 A. He mentioned his father -- his father's 13:46:05

11 Q. Do you recall that attorney's name? 13:46:17 12 A. I don't recall.

14 Q. When was that request made, if you know? 13:46:24 15 A.

16 Q.

17 A.

18 Q. Were you -- as president, secretary, 13:46:45 19 treasurer, and director of Golden Spring (New York) 13:46:53 20 Limited -- involved in the decision about whether to 13:46:58 21 provide DIP financing to the debtor? 13:47:03 22 A. I was advised by Mr. Qiang Guo afterwards. 13:47:06 23 That was a quite short time period.

24 so the answer to you is I was not involved. 13:47:24 25 Q. Were you consulted by Mr. Guo -- 13:47:27

1 Mr. Qiang Guo on the decision about whether 13:47:32

2 Golden Spring (New York) would agree to provide DIP 13:47:36 3 financing to the debtor here? 13:47:40 4 A.

5 Q. Do you know what consulted means? 13:47:45 6 A.

7 Q. Okay.

8 Mr. Qiang Guo about the decision on whether 13:47:53 9 Golden Spring (New York) would agree to provide DIP 13:47:59

11 A. You mean he -- when he was making the 13:48:05

13 Q. Well, we're going to get to who made the 13:48:09 14 decision. I'm trying to figure out whether you were 13:48:14 15 involved and, if so, how.

16 minutes ago that you were not involved with the 13:48:23

18 I'm asking if Mr. Qiang Guo spoke to you 13:48:26

20 A.

21 He spoke to me about the decision. 13:48:34 22 Q.

23 A.

24 Q. And am I right that the decision was his, 13:48:41 25 not yours?

1 A. Golden Spring has been the litigation 13:48:49

2 funding for Mr. Qiang Guo's father, I mean, for 13:48:56 3 several years. Mr. Qiang Guo made the decision, 13:49:01 4 given the short time apparent.

5 the company, I am aligned with that, and he knew and 13:49:09 6 he knows I am going to align with that. 13:49:13 7 Q.

8 A.

9 Q.

10 A. No need to argue that, yeah, if that is what 13:49:17

12 Q. I'm -- I'm -- I'm -- you know, I'm not 13:49:21 13 trying to argue with you.

16 You understand that litigation funding in 13:49:31 17 the past that Golden Spring may have provided to 13:49:37 18 Mr. Ho Wan Kwok is different from the DIP loan that 13:49:46 19 we are talking about today?

20 those are two different things; right? 13:49:51 21 A.

22 Q. Okay. And so I would like to focus just on 13:49:54 23 the DIP loan and not litigation financing that may 13:49:58

1 A.

2 Q. Okay.

3 according to you, the decision about whether to agree 13:50:13 4 to the DIP loan for the debtor was Mr. Qiang Guo's 13:50:20 5 decision?

6 A. He made a decision, obviously on behalf of 13:50:34 7 Golden Spring, and he is the owner of the company. 13:50:41

9 Q. Okay. And you are the president, and all 13:50:45 10 those other titles, of Golden Spring (New York) 13:50:49

12 A.

13 Q. Have you ever disagreed with Mr. Qiang Guo 13:50:59 14 about a decision that he has made? 13:51:02 15 A.

16 Q. Okay. And did he solicit your agreement for 13:51:06

18 A. For this DIP loan decision, you mean? 13:51:09 19 Q.

20 A.

22 Q.