Guo Wengui / Miles Guo — bankruptcy case · EXHIBIT · ECF #913-5

Case 22-50073 Doc 913-5 Filed 10/04/22 Entered 10/04/22 11:50:18 Page 2 of 134

UNITED STATES BANKRUPTCY COURT DISTRICT OF CONNECTICUT In Re \* Chapter 11 \* \* HO WAN KWOK, \* Case 22-50073(JAM) \* Debtor. \* \* \* \* \* \* \* \* \* \* \* \* \* \* \* \* \* \* TRANSCRIPT OF CONTINUED 341 MEETING OF CREDITORS APRIL 6, 2022 Electronically Recorded by the Office of the United States Trustee Transcript Prepared By: Christine Fiore, CERT Fiore Reporting and Transcription Service, Inc. 4 Research Drive, Suite 402 Shelton, CT 06484 (203)929-9992

APPEARANCES:

For the Debtor: WILLIAM R. BALDIGA, ESQ. BEN SILVERBERG, ESQ.

For the U.S. Trustee: HOLLEY E. CLAIBORN, ESQ. STEVEN MACKEY, ESQ.

Creditor: JAY MARSHALL WOLMAN, ESQ.

LP, Creditors: DAVID V. HARBACH, II, ESQ.

STUART SARNOFF, ESQ.

ANNECCA SMITH, ESQ.

Creditors: KRISTEN MAYHEW, ESQ.

Creditors: STEVEN STAFSTROM, ESQ.

Case 22-50073 Doc 913-5 Filed 10/04/22 Entered 10/04/22 11:50:18 Page 4 of

1 MS. CLAIBORN: Good morning.

2 Wednesday, April 6th, 2022.

3 continued meeting of creditors in the Chapter 11 4 case of Ho Wan Kwok, case no. 22-50073. 5 My name is Holley Claiborn. I'm a trial 6 attorney in the Office of the United States Trustee 7 and I will be conducting today's meeting.

8 meeting is being recorded on a digital recorder and 9 is also available for parties to participate on the 10 phone. And there are parties, including the debtor 11 and counsel and other professionals, gathered here 12 in person. 13 Today's meeting is being interpreted, as 14 you can hear and our interpreter today is Jeff and 15 I'm going to ask Jeff to respond to this oath.

17 THE COURT:

18 William Baldiga and Ben Silverberg.

20 financial professionals Craig Gelbert and Matthew 21 Flynn.

23 Committee of Unsecured Creditors is Steven Stafstrom 24 from Pullman and Comley.

Case 22-50073 Doc 913-5 Filed 10/04/22 Entered 10/04/22 11:50:18 Page 5 of

2 Official Committee of Unsecured Creditors.

4 Stuart Sarnoff, David Harbach and MacKenzie Russo. 5 They represent PAACS. 6 On behalf of certain creditors, including 7 Rui Ma, we have Kristen Mayhew. 8 On behalf of creditor, Logan Cheng, we 9 have Jay Wolman. 10 Also on behalf of PAACS we have Annecca 11 Smith, from Robinson and Cole. 12 And then also for the debtor today we have 13 Josh Klein and Aaron Mitchell. 14 Today's meeting will feature me asking 15 questions first, followed by the opportunity for 16 creditors to come up and ask questions. 17 Is anyone on the telephone conference 18 line? 19 MR. MACKEY: Steven Mackey from the U.S. 20 Trustee's Office is on the conference line. 21 Thank you, Mr. Mackey.

22 besides Mr. Mackey. 23 Hearing none, I'm going to proceed to 24 swearing in Mr. Kwok.

1 MS. CLAIBORN:

2 today's meeting is being recorded and Mr. Jeff here 3 is our official interpreter for today. 4 Jeff will be interpreting the questions 5 that I ask and your answers, and I ask that you wait 6 until Jeff has made a full translation before you 7 answer my questions. 8 EXAMINATION BY MS. CLAIBORN:

Mr. Kwok, we're going to pick up today in 10 an area that we left off in general from the last 11 meeting of creditors that was held back on March 12 21st, 2022. 13 Has anything changed in your employment 14 status since March 21st, 2022?

No.

Has anything changed with respect to your 17 residence?

No.

20 2022 I asked you about the accuracy of your 21 bankruptcy schedules and your bankruptcy statement 22 of financial affairs.

No change.

Q Thank you.

Case 22-50073 Doc 913-5 Filed 10/04/22 Entered 10/04/22 11:50:18 Page 7 of

1 questions I'm going to be following the documents 2 that are in front of you. When I say schedules, it's 3 this document.

4 statement of financial affairs. Okay?

5 refer to an ECF number, it's at the top of the page. 6 THE OFFICIAL INTERPRETER: ECF number. 7 Okay. 8 MS. CLAIBORN: Okay?

9 you to follow along and start on this page. 10 EXAMINATION BY MS. CLAIBORN:

Okay.

12 make sure you have in front of you, which you appear 13 to do, Schedules A-B through J. 14 THE PRIVATE INTERPRETER:

15 translations in front of him. 16 BY MS. CLAIBORN:

I see that Mr. Baldiga, who is seated next 18 to you, has English versions.

19 Mr. Kwok, appear to be translations.

20 accurate?

Just on Schedule A-B.

Okay.

23 my questions today, you're going to be taking a look 24 at your own translated versions of the bankruptcy 25 schedules.

Okay.

Okay. 3 THE PRIVATE INTERPRETER:

4 Your Honor. 5 MS. CLAIBORN: Yes. 6 THE PRIVATE INTERPRETER:

7 little difficulty hearing the interpreter when he 8 interprets the witness's answers. 9 MS. CLAIBORN: Okay.

10 could speak up. I'm going to move the microphone. 11 THE OFFICIAL INTERPRETER: Oh, okay. 12 MS. CLAIBORN: See if that works. 13 BY MS. CLAIBORN:

Okay. Mr. Kwok, starting at Question No. 15 1 on Schedule A-B.

16 Question No. 1, that asks if you own any legal or 17 equitable interest in any real estate residence or 18 building or similar property.

19 Question No. 1 was no, Mr. Kwok.

20 accurate answer?

Yes.

23 between the year 2018 and your bankruptcy filing in 24 February of 2022? 25 THE OFFICIAL INTERPRETER:

Case 22-50073 Doc 913-5 Filed 10/04/22 Entered 10/04/22 11:50:18 Page 9 of

1 that one? 2 BY MS. CLAIBORN:

Have you owned any real estate between the 4 year 2018 and your bankruptcy filing in February 5 2022? 6 THE OFFICIAL INTERPRETER:

7 that one? He said he didn't hear that. 8 BY MS. CLAIBORN:

10 MR. BALDIGA: I'm sorry. I couldn't hear. 11 THE OFFICIAL INTERPRETER:

12 didn't understand the translation.

13 make sure I understand first. 14 MS. CLAIBORN: I'll repeat the question. 15 THE OFFICIAL INTERPRETER: Yes. 16 BY MS. CLAIBORN:

18 between 2018 and February of 2022?

No.

21 February 2022, did you have any equitable interest 22 in any real estate anywhere in the world?

No.

25 February 2022, did you have any legal interest in

1 any real estate anywhere in the world?

No.

4 estate in Hong Kong?

No. 6 THE PRIVATE INTERPRETER:

7 answer? 8 THE OFFICIAL INTERPRETER: No. 9 BY MS. CLAIBORN:

Mr. Kwok, have you ever owned the property 11 located at 16A South Bay Road, Hong Kong?

No.

14 apartment at the Sherry Netherland in New York City? 15 THE OFFICIAL INTERPRETER:

16 it. Can I ask him repeat the -- repeat the answer? 17 MR. BALDIGA:

18 you're going to say, you have to -- you're talking 19 to everybody, not just Holley, so I need to hear 20 what you're saying. 21 THE OFFICIAL INTERPRETER: Okay.

22 - I just want to ask him to repeat -- repeat the 23 answer. 24 MR. BALDIGA: Okay. 25 THE OFFICIAL INTERPRETER: Okay? Case 22-50073 Doc 913-5 Filed 10/04/22 Entered 10/04/22 11:50:18 Page 11 of

1 THE WITNESS:

2 in New York, the Sharon -- the Sharons -- at that 3 address I don't remember, and I own -- I own 50

5 THE PRIVATE INTERPRETER: No. 6 THE OFFICIAL INTERPRETER: No? 7 THE PRIVATE INTERPRETER: No. 8 THE OFFICIAL INTERPRETER: Okay. 9 THE WITNESS: For the family. 10 MS. CLAIBORN:

11 interrupt?

13 THE PRIVATE INTERPRETER: Okay. 14 MS. CLAIBORN:

15 it is you want to say? 16 THE PRIVATE INTERPRETER: Okay. 17 MS. CLAIBORN:

18 translate Mr. Kwok's answer again? 19 THE OFFICIAL INTERPRETER: Yeah.

20 want to repeat, make sure -- and I said it right, 21 you know, what he said. 22 THE WITNESS:

23 owe -- I own 50 percent of the -- 50 percent, but I 24 don't own the whole real estate, but I just 25 represent the family.

1 BY MS. CLAIBORN: 2 Q Mr. Kwok, what do you own 50 percent of? 3 A Bravo Luck, 50 percent of the stock powder 4 -- power. I don't know. I don't understand. 5 THE PRIVATE INTERPRETER:

6 THE OFFICIAL INTERPRETER:

7 said he owns the 50 percent of it. 8 THE PRIVATE INTERPRETER:

9 you fine, Holley. 10 MS. CLAIBORN: Okay.

12 THE PRIVATE INTERPRETER:

13 the microphone is connected to anything. 14 MS. CLAIBORN: It is. It is.

15 you can speak up? 16 THE OFFICIAL INTERPRETER:

17 he owe -- he owns 50 percent of -- of the stock.

18 it like the stock of the real estate or something? 19 I don't know. I don't get it.

20 she wants to help.

21 bit? 22 MS. CLAIBORN: I'd rather not. 23 THE OFFICIAL INTERPRETER: Okay. 24 MS. CLAIBORN:

25 follow-up questions.

1 THE OFFICIAL INTERPRETER: Okay. 2 MR. BALDIGA: All right.

3 hear if it's a misinterpretation, so -- 4 MS. CLAIBORN:

5 clarifying question, if I could. 6 BY MS. CLAIBORN:

8 company called Bravo Luck?

10 of the stock.

12 MR. BALDIGA: Could I hear that back? 13 Could you repeat that? 14 THE OFFICIAL INTERPRETER: Yeah.

15 represent my family to hold 50 percent of the stock 16 of the -- of the company. 17 MR. BALDIGA: Okay. 18 BY MS. CLAIBORN:

Mr. Kwok, when you say family, what do you 20 mean?

22 includes a lot of people.

23 laws, and all people together. A lot of people.

25 MR. BALDIGA: Excuse me.

Case 22-50073 Doc 913-5 Filed 10/04/22 Entered 10/04/22 11:50:18 Page 14 of

Ho Wan Kwok - April 6, 2022 interpretation question. THE PRIVATE INTERPRETER: I just want to ask that, is there supposed to be summary of the (indiscernible) the interpretation? MS. CLAIBORN: To the best of Mr. Jeff's ability, it should be verbatim. THE PRIVATE INTERPRETER: Right. So if Mr. Kwok said, my son, my daughter, my brother, my sister-in-law, my nephew, my niece, many people, then if the interpreter say, well, a lot of my families and my brother, many people, then should it be correct or not? MS. CLAIBORN: I would prefer that Mr. Jeff translate as literally as possible. So with that instruction, can we -- THE OFFICIAL INTERPRETER: Yeah. MS. CLAIBORN: -- do a specific job as best we can going forward? Thank you. MR. BALDIGA: Thank you. BY MS. CLAIBORN: Q So, Mr. Kwok, who owns the company called Bravo Luck? A My son. Q And what is your son's name? A Cheng Wu.

How long has your son owned Bravo Luck?

I don't remember. 3 THE PRIVATE INTERPRETER:

4 please. 5 THE OFFICIAL INTERPRETER:

6 remember. 7 BY MS. CLAIBORN:

9 of when you explained your ownership interest in the 10 Southern Sherry Netherland? 11 MR. BALDIGA: Objection.

12 interpret. 13 THE OFFICIAL INTERPRETER:

14 that one again, Holley? 15 BY MS. CLAIBORN:

Mr. Kwok, you testified that you owned 50 17 percent of some company, and that was in response to 18 my question if you owned the Sherry Netherland 19 apartment. Can you please explain what you meant?

Sherry is a co-op.

21 it doesn't have the -- it doesn't have the 22 ownership. 23 THE PRIVATE INTERPRETER: May I, Ms. 24 Holley? 25 MR. BALDIGA: Yes, of course.

1 THE PRIVATE INTERPRETER:

2 speak louder. 3 MS. CLAIBORN: Okay.

4 ourselves on pause for a second here.

6 MS. CLAIBORN: All right.

7 the record after a short break, and, Mr. Kwok, you 8 remain under oath. 9 Jeff, could you please retranslate? 10 THE OFFICIAL INTERPRETER: Yeah. 11 MS. CLAIBORN: The last question.

12 want me to ask it again? 13 THE OFFICIAL INTERPRETER: Yeah.

14 you ask it again? 15 MS. CLAIBORN: All right.

16 again. 17 BY MS. CLAIBORN:

Mr. Kwok, you testified today that you own 19 50 percent of an interest in some company, and that 20 was the answer you gave me in response to my 21 question if you own an apartment at the Sherry 22 Netherland. Can you please explain your answer? 23 MR. BALDIGA: Objection. 24 THE WITNESS:

25 it. He said the Sherry Netherland is a co-op.

Case 22-50073 Doc 913-5 Filed 10/04/22 Entered 10/04/22 11:50:18 Page 17 of

1 don't have a deed on that property and I just

2 represent my family to own 50 percent of the right. 3 MR. BALDIGA: Excuse me. Go ahead. 4 THE PRIVATE INTERPRETER:

5 Mr. Kwok did mention the company name Bravo Luck, so 6 Mr. Interpreter did not say the word Bravo Luck, the 7 company that holds the interest of Sherry 8 Netherland, and Mr. Kwok represents the family owns 9 50 percent of Bravo Luck, which is the holding 10 company of owning the Sherry Netherland. The Sherry 11 Netherland is a co-op. 12 MR. BALDIGA:

13 continuing objection to the extent that the 14 interpreter is not providing the exact words used by 15 the witness.

16 anything, but obviously that's critical to the 17 quality of the testimony and that's necessary. 18 MS. CLAIBORN:

19 MR. BALDIGA:

20 used by the witness. 21 MS. CLAIBORN:

22 to do his best job today to try to translate 23 everything literally. 24 MR. BALDIGA: Thank you. 25 MS. CLAIBORN:

Case 22-50073 Doc 913-5 Filed 10/04/22 Entered 10/04/22 11:50:18 Page 18 of

1 there is a familiarity with terms in this room that 2 Mr. Jeff does not have.

3 people are answering questions with shorthand 4 versions of company names or just one words, the 5 answer should be as specific as possible -- 6 THE OFFICIAL INTERPRETER:

7 MS. CLAIBORN:

8 that. 9 THE OFFICIAL INTERPRETER:

10 probably that interpreter honestly, Holley, the 11 interpreter probably know the case more, the 12 details. 13 MS. CLAIBORN: I agree.

14 THE OFFICIAL INTERPRETER:

15 MS. CLAIBORN:

16 just said to Mr. Kwok, because I want to make sure

18 THE OFFICIAL INTERPRETER: Oh.

MS. CLAIBORN: -- he answers questions in a way that are easily translatable.

THE OFFICIAL INTERPRETER: I just tell him and the answer let -- you know short and clear, but I pretty much understand what he says and -- MS. CLAIBORN: And can you please translate Mr. Kwok's answers or comments to your Case 22-50073 Doc 913-5 Filed 10/04/22 Entered 10/04/22 11:50:18 Page 19 of

1 comments?

2 THE OFFICIAL INTERPRETER:

3 try to make it a shorter and clear and -- but he 4 needs to explain the details as much as he can 5 because it's a -- it's related to his lifeline. 6 MS. CLAIBORN: Mr. Sarnoff? 7 MR. SARNOFF: Yeah.

8 clear that to the extent there is a discrepancy 9 between the interpreter -- the translator, the 10 official translator and Mr. Kwok's interpreter, that 11 the translator is the final arbiter and that unless 12 the translator agrees with the translation 13 difference that the interpreter is putting forth, 14 they have to work that out before we can defer to 15 the -- to Mr. Kwok's personal interpreter as what 16 Mr. Kwok said. 17 MR. BALDIGA: I don't accept that. 18 MR. SARNOFF: That's fine. 19 MR. BALDIGA: That can be your position. 20 MR. SARNOFF: Okay.

21 be that the translator has to agree with the 22 interpreter about what Mr. Kwok said for the record 23 to be accurate. 24 MR. BALDIGA:

25 position.

Case 22-50073 Doc 913-5 Filed 10/04/22 Entered 10/04/22 11:50:18 Page 20 of

1 THE OFFICIAL INTERPRETER:

2 I miss anything that his personal interpreter wants 3 to make up whatever I'm missing, some of the detail 4 information, and is it okay for her to add on and if 5 I agree what -- you know, what I'm missing or what 6 he said, maybe I'm missing some detail information

8 MS. CLAIBORN:

10 THE OFFICIAL INTERPRETER: Yeah. 11 MS. CLAIBORN:

12 clear translation and a clear record -- 13 THE OFFICIAL INTERPRETER: Okay. 14 MS. CLAIBORN:

16 THE OFFICIAL INTERPRETER: Uh-huh. 17 MS. CLAIBORN:

18 interpret Mr. Kwok's answers. 19 THE OFFICIAL INTERPRETER: Okay. 20 MS. CLAIBORN:

21 based on your interpretation, that you have not 22 translated properly, then he can testify again and 23 you can try again.

25 interaction that happens between translators and Case 22-50073 Doc 913-5 Filed 10/04/22 Entered 10/04/22 11:50:18 Page 21 of

1 between Mr. Kwok's personal translator so that we

2 have an official record where the person asking the 3 question is me, it's being officially translated, 4 and Mr. Kwok is giving the answers, and that also is 5 being officially translated. 6 MR. BALDIGA:

7 with that is the witness doesn't know whether Jeff's 8 English report is in fact accurate.

9 it up to the witness.

10 interpreter.

11 need any interpreters. He can't do that. 12 MS. CLAIBORN:

13 matter, Mr. Kwok speaks enough English to know 14 whether or not he's answered his question. 15 MR. BALDIGA: No, he doesn't. I object. 16 MS. CLAIBORN:

17 that has been what I have seen from my own personal 18 experience. 19 That said, we're going to try and do the

21 MR. BALDIGA: I agree. 22 MS. CLAIBORN:

23 go. 24 MR. BALDIGA: Okay. 25 MS. CLAIBORN: Okay?

1 BY MS. CLAIBORN:

So back to questions and answers. Mr. 3 Kwok, do you own an interest in Genever Holdings 4 Corporation?

I just have -- in reality, I don't, but I 6 just held -- I just represent my family to hold some 7 interest.

9 Genever Holdings Corporation aside from you?

My son.

Is there a document that memorializes your 12 ownership interest, whatever it is, in Genever 13 Holdings Corporation? 14 MR. BALDIGA: Objection.

15 answer. 16 THE WITNESS: No. 17 THE PRIVATE INTERPRETER:

18 I -- first of all, the last time that -- when he was 19 saying -- instructing the witness about his 20 testimony, what should it be, I don't think the 21 interpreter -- the official interpreter interpreted 22 your instruction.

23 should be doing, but not what you were saying. 24 And then, now that the witness is saying 25 that he asked the interpreter twice that -- you were

Case 22-50073 Doc 913-5 Filed 10/04/22 Entered 10/04/22 11:50:18 Page 23 of

talking about ownership, you were talking about ownership interest. Now he used twice these words, and then at the end, Mr. Jeff said, yes. And then, so he answered no, but then the interaction was not interpreted. MS. CLAIBORN: Mr. Jeff, could you translate? THE OFFICIAL INTERPRETER: I don't know what she just said. I don't know. I didn't understand what she's saying. THE PRIVATE INTERPRETER: I mean, every word should be interpreted. The witness -- every word the witness says should be interpreted. Ms. Holley's words should be interpreted, right? MS. CLAIBORN: Yes. THE PRIVATE INTERPRETER: Right. But he will -- not interpreted Ms. Holley's -- and you did not interpret everything Mr. Kwok said. THE OFFICIAL INTERPRETER: Okay. Maybe -- maybe we should have her to interpret. I'm going to excuse myself. I don't know -- MS. CLAIBORN: I'm going to put the -- THE OFFICIAL INTERPRETER: -- I'm not familiar with -- MS. CLAIBORN: -- I'm going to put the

1 matter on pause for a moment. 2 THE OFFICIAL INTERPRETER:

3 yeah.

5 MS. CLAIBORN: All right.

6 the record after a short break. 7 Mr. Kwok, you remain under oath. 8 BY MS. CLAIBORN:

10 currency with you today?

No.

13 you have any United States currency?

No.

Mr. Kwok, do you own any foreign currency?

No.

Mr. Kwok, do you own any digital currency?

No.

20 accounts of any kind in the United States?

No.

23 accounts of any kind outside of the United States?

No.

Case 22-50073 Doc 913-5 Filed 10/04/22 Entered 10/04/22 11:50:18 Page 25 of

1 job and no source of income.

2 household expenses?

4 sometimes my other family member.

Do you have access to any credit cards?

No.

8 attached to a bank account?

No.

How do you pay for groceries?

12 company pay for.

Where does your son live?

London.

How does your son send you money?

17 York.

Does the family office give you money?

They pay the expenses above.

What does the term family office mean? 21 MR. BALDIGA: Objection. You may answer. 22 THE OFFICIAL INTERPRETER:

23 ask him to repeat? 24 MS. CLAIBORN: Yes. 25 THE OFFICIAL INTERPRETER: Okay.

Case 22-50073 Doc 913-5 Filed 10/04/22 Entered 10/04/22 11:50:18 Page 26 of

2 MR. BALDIGA: Right.

3 interpret for the witness what I say. 4 MS. CLAIBORN:

5 yet and he's going to ask him to repeat his answers 6 so then he's going to translate, and then we can 7 have whatever discussion you want to have. 8 THE PRIVATE INTERPRETER:

9 raised objection.

10 the objection. 11 MS. CLAIBORN:

12 question, but we are not going to get anywhere today 13 in a meaningful fashion if people are interrupting 14 on basic questions. 15 MR. BALDIGA:

17 MS. CLAIBORN: So let me try again. 18 MR. BALDIGA: Okay. But hold on.

19 object or if I say anything else, that has to be 20 interpreted. 21 MS. CLAIBORN:

22 space to interpret.

23 that exchange that just happened? 24 THE OFFICIAL INTERPRETER: Okay.

25 know. It's just too much interruption.

1 MS. CLAIBORN: Right. 2 THE OFFICIAL INTERPRETER:

3 do -- keep doing this.

4 don't know.

6 MS. CLAIBORN:

7 THE OFFICIAL INTERPRETER:

8 these people involved. 9 MS. CLAIBORN: Correct.

10 THE OFFICIAL INTERPRETER:

11 anywhere. 12 MS. CLAIBORN:

13 again. 14 BY MS. CLAIBORN:

16 family office? 17 MR. BALDIGA: Objection. You may answer. 18 MS. CLAIBORN:

19 all over the papers. Can you repeat -- translate? 20 THE OFFICIAL INTERPRETER:

21 going anywhere. Holley, I just excuse myself.

22 sorry.

23 MS. CLAIBORN:

24 pause, please. 25 THE OFFICIAL INTERPRETER:

Case 22-50073 Doc 913-5 Filed 10/04/22 Entered 10/04/22 11:50:18 Page 28 of

1 much.

3 MS. CLAIBORN:

4 after a short break. 5 Mr. Kwok, you remain under oath.

6 the break, I spoke with Attorney Baldiga and we have 7 agreed that all objections as to form of the 8 question are reserved. 9 I'm going to go back to my questions. 10 BY MS. CLAIBORN:

12 was what do you mean by the term family office?

They are representing my big family.

14 a company my son, my daughter, my wife, and it's a 15 company representing my family for investment.

What is the name of the company?

Golden Spring Europe.

Do you mean Golden Spring New York?

Roughly the name.

Who pays for the meals that you eat?

Sometimes my wife's company, sometimes my 22 family office, my son's company.

24 office, are you referring to the company known as 25 Golden Spring New York Limited?

1 THE OFFICIAL INTERPRETER:

2 of the company? Can I -- can you repeat it? 3 MS. CLAIBORN:

4 New York Limited. 5 THE WITNESS: Yes. 6 BY MS. CLAIBORN: 7 Q In your bankruptcy case, you filed a 8 report covering your expenses for the month of 9 February. 10 THE OFFICIAL INTERPRETER:

11 again? 12 MS. CLAIBORN: Maybe I'll try it again. 13 THE OFFICIAL INTERPRETER: Thank you. 14 BY MS. CLAIBORN: 15 Q Mr. Kwok, you filed a monthly operating 16 report covering the month of February 2022, and that 17 report shows you spent approximately \$160,000. 18 MR. BALDIGA: Objection. I object. 19 BY MS. CLAIBORN: 20 Q Who funded the disbursements of \$160,000? 21 A Some from the Golden Spring family office 22 and the company, some were paid by my wife and my 23 wife's company. 24 Q What is the name of your wife's company? 25 A Greenwich, in Connecticut.

134 Entered 10/04/22 11:50:18 Page 30 of

1 Q Are you referring to the company? 2 A Yes, the company name. 3 Q What expenses does your wife company, 4 Greenwich, pay for? 5 A Mostly food, because I live in my wife's 6 house. We share the cleaning, the expenses because 7 -- and also the garden maintenance expenses. 8 UNIDENTIFIED SPEAKER: Okay. Can we take 9 a quick time out so I can speak with my co-counsel? 10 Or with my partner. 11 MR. BALDIGA: No, let's just wait. 12 BY MS. CLAIBORN: 13 Q Where does your wife's company, Greenwich, 14 get its money from? 15 A I don't know. 16 Q Did your wife's company, Greenwich, pay 17 for any professional expenses? 18 A I don't know. 19 Q Is your wife the person who actually makes 20 the payments? 21 A Yes. 22 Q Does your wife have a checking account? 23 A I don't know. 24 Q Does your wife have a debit card? 25 A I don't know.

134 Entered 10/04/22 11:50:18 Page 31 of

1 Q When you eat in a restaurant with your 2 wife, who pays the bill? 3 A I never went to a restaurant with my wife. 4 Q Ever? 5 A I think I was chased by these people and I 6 never went. Thinks I -- you know, I think I was 7 chased by these people. 8 Q Does your wife buy groceries? 9 A Sometimes. 10 Q How does she pay for them? 11 A I don't know. 12 Q Why does Golden Spring New York pay for 13 some of your personal expenses? 14 A Because I'm one of the family member, and 15 my son is very successful and he loves me very much. 16 Q Is there any other reason? 17 A I don't know. 18 Q What personal living expenses of yours 19 does Golden Spring pay for? 20 A The expense from security because I was 21 chased by the people in the back, and the 22 transportation, clothing, and some items for living. 23 Q Who is the person at Golden Spring New

25 MS. CLAIBORN: Wait a minute. I'm going

1 to ask a full question. 2 BY MS. CLAIBORN: 3 Q So who is the person at Golden Spring New 4 York who authorizes the payment of your personal 5 living expenses? 6 A My son. 7 Q Please explain how your son authorizes 8 those payments. 9 A I usually communicate with Golden Spring, 10 the company's manager and CEO. 11 THE PRIVATE INTERPRETER:

12 director, not manager. 13 THE OFFICIAL INTERPRETER:

14 okay. Director, not a manager. 15 MR. BALDIGA: Thank you. 16 BY MS. CLAIBORN: 17 Q Mr. Kwok, who is the director or manager 18 that you just referred to? 19 A Wang Yanping. 20 Q Is Ms. Ping a officer of Golden Spring New 21 York? 22 A She is a Miss. She's a lady. 23 Q Is Ms. Ping a corporate officer of Golden 24 Spring New York? 25 A Yes.

1 Q What is her title? 2 A She is a officer or director. 3 Q Does she have a position title? 4 A I don't know. 5 Q Mr. Kwok, are you a corporate officer of 6 Golden Spring New York? 7 A Now? 8 Q Yes. 9 A No. 10 Q Mr. Kwok, have you ever been in the past, 11 a corporate officer of Golden Spring New York? 12 A I seem to hold a title when the company 13 was established in 2015.

14 then. 15 Q Mr. Kwok, do you own any interest in 16 Golden Spring New York? 17 A No. 18 Q In the past, have you ever had any kind of 19 ownership interest in Golden Spring New York? 20 A No. 21 Q Were you involved in the formation of 22 Golden Spring New York? 23 A Yes. 24 Q What was your role in the formation of 25 Golden Spring New York?

134 Entered 10/04/22 11:50:18 Page 34 of

1 A Consultant and giving advice, suggestions. 2 Q Was your son involved in the formation of 3 Golden Spring New York? 4 A He is the main person. He -- he was the 5 main person. 6 Q When Golden Spring New York was created, 7 who had the ownership interest in New York -- Golden 8 New -- Golden Spring New York? 9 A My son. 10 Q Did Golden Spring Hong Kong have any 11 ownership interest in Golden Spring New York? 12 A I don't know the detail of the interest 13 and because this -- these two combined, it's 14 considered one thing. 15 Q Is Golden Spring Hong Kong a separate 16 company from Golden Spring New York? 17 A I don't know. 18 Q Who owns Golden Spring Hong Kong? 19 A My son. 20 Q In 2015, when Golden Spring New York was 21 formed, who owned Golden Spring Hong Kong? 22 A I don't know. 23 Q Are you a corporate officer of Golden 24 Spring Hong Kong? 25 A I don't remember.

1 Q Have you ever been a cooperate officer of 2 Golden Spring Hong Kong? 3 A I don't remember. 4 Q Do you have any ownership interest in 5 Golden Spring Hong Kong? 6 A No.

8 ownership interest in Golden Spring Hong Kong? 9 A No. 10 Q What type of business is Golden Spring New 11 York engaged in? 12 A I don't know. 13 Q How does Golden Spring New York generate 14 revenue? 15 A I don't know. 16 THE PRIVATE INTERPRETER:

17 don't know if this -- the (indiscernible) he said, 18 how does Golden Spring New York generate revenue, 19 not how does Golden Spring New York making money, 20 right? 21 MS. CLAIBORN:

22 question. 23 THE PRIVATE INTERPRETER:

24 interpreter should not say -- interpret it in such a 25 way that Golden Spring New York -- how does Golden

1 Spring New York make money, to the -- to the -- to 2 Mr. Kwok. 3 THE OFFICIAL INTERPRETER:

4 yeah. Generate revenue, generate money. 5 THE PRIVATE INTERPRETER:

7 MS. CLAIBORN:

8 specifically. 9 BY MS. CLAIBORN:

11 money?

I don't know.

14 Golden Spring New York's business?

I don't remember.

17 Golden Spring New York?

No.

20 Spring New York?

No.

Have you ever transferred any property of 23 any kind to Golden Spring New York?

No.

134 Entered 10/04/22 11:50:18 Page 37 of

1 York in any way? 2 A No. 3 Q Have you ever loaned money to Golden 4 Spring New York? 5 A No. 6 Q Have you ever invested any of your own 7 money in Golden Spring New York? 8 A No. 9 Q What corporate position does Yanping Wang 10 Hold? 11 A Officer and director. 12 Q Is Yanping Wang the president of Golden 13 Spring New York? 14 A Yes. 15 Q Does Golden Spring New York have any other 16 corporate officers? 17 A Yes. 18 Q Who are they? 19 A I don't remember clearly about their 20 names. 21 Q Please tell me what you remember. 22 A What -- I don't remember their names 23 clearly and -- because I don't even remember 24 attorney's names. I don't want to misleading you, 25 Holley.

1 Q How many officers does Golden Spring New 2 York have? 3 A I don't remember. Oh, I don't know. 4 Sorry. I don't know. 5 Q Does Golden Spring New York have any 6 directors? 7 A Yanping Wang. 8 Q Is Ms. Wang the only director of Golden 9 Spring New York? 10 A I don't know. 11 Q Where does Golden Spring New York get the 12 money that it uses to pay your personal expenses? 13 A I don't know. 14 Q Does Golden Spring New York have any 15 employees? 16 A Yes. 17 Q How many? 18 A I don't know. 19 Q Are you currently involved in any way in 20 the business of Golden Spring New York? 21 A No. 22 Q What does Golden Spring New York own? 23 A I don't know. 24 Q Golden Spring New York is willing to loan 25 you the sum of \$8 million.

1 \$8 million from? 2 A I don't know. 3 Q Are you the person who asked Golden Spring 4 New York to loan you \$8 million? 5 A No. 6 Q Who asked Golden Spring New York to loan 7 you \$8 million? 8 A My attorney. 9 Q Which attorney? 10 A Aaron Mitchell here. 11 Q Are you referring to Aaron Mitchell? 12 A Now I remember his name now. 13 UNIDENTIFIED SPEAKER:

14 record, I'm not sure Mr. Mitchell has registered an 15 appearance yet. It would be appropriate if he's 16 going to be here representing the debtor, if he 17 (indiscernible) his appearance. 18 MS. CLAIBORN: I believe I did read Mr. 19 Mitchell's name earlier today. 20 UNIDENTIFIED SPEAKER:

21 MS. CLAIBORN:

22 UNIDENTIFIED SPEAKER:

23 this matter. 24 MS. CLAIBORN: Thank you.

25 translate that?

1 THE OFFICIAL INTERPRETER:

2 totally clearly. I know it's some distance.

4 BY MS. CLAIBORN: 5 Q Does Golden Spring New York have any bank 6 accounts? 7 A I don't know. 8 Q Do you have access to Golden Spring New 9 York's financial accounts? 10 A No. 11 Q Do you have authority to enter into 12 financial transactions on behalf of Golden Spring 13 New York? 14 A No. 15 THE PRIVATE INTERPRETER: No.

16 not the question. 17 THE OFFICIAL INTERPRETER: What was it? 18 MS. CLAIBORN:

19 question. 20 BY MS. CLAIBORN: 21 Q Do you have authority to enter into 22 financial transactions on behalf of Golden Spring 23 New York? Mr. Kwok, if you don't answer -- if you

25 THE OFFICIAL INTERPRETER:

1 he -- if I was asking if he has the right to use the 2 -- the Golden Spring New York, the accounts for 3 transactions. You know. 4 MS. CLAIBORN: That was not my question. 5 BY MS. CLAIBORN:

Mr. Kwok, are you authorized to enter into 7 any kind of financial transactions on behalf of 8 Golden Spring New York?

No. 10 MR. BALDIGA:

11 might have a comment. 12 MS. CLAIBORN:

13 please? 14 THE OFFICIAL INTERPRETER: Yeah.

15 that it's the trading -- trading of the financial

17 THE PRIVATE INTERPRETER: Transaction. 18 THE OFFICIAL INTERPRETER:

20 THE PRIVATE INTERPRETER: Not trading. 21 THE OFFICIAL INTERPRETER:

22 no, he was not -- I was not authorized to do the 23 transactions, financial transactions. 24 BY MS. CLAIBORN:

What, if anything, do you currently do for

1 Golden Spring New York?

No.

4 son's personal living expenses?

I don't know.

7 daughter's personal living expenses?

I don't know.

Do you owe any money to Golden Spring New 10 York?

Yes.

How much?

Like more than \$21 million.

15 Golden Spring New York?

17 sued by a lot of creditors.

19 MS. CLAIBORN: I apologize. 20 THE OFFICIAL INTERPRETER:

21 to repeat. 22 THE WITNESS:

23 was chased by Chinese Communist Party. 24 THE OFFICIAL INTERPRETER:

25 it. Ask -- I'm asking him to repeat it one more Case 22-50073 Doc 913-5 Filed 10/04/22 Entered 10/04/22 11:50:18 Page 42 of

1 time.

2 MR. BALDIGA: Short -- short answer. 3 THE WITNESS:

4 trapped -- trapped by some of the cases from Chinese 5 Communist Party, designed by the Chinese Communist 6 Party, including the case past, that case.

7 to -- need to pay a large amount of legal fees so 8 that's why I got the support from the Golden Spring 9 New York.

10 million. 11 THE PRIVATE INTERPRETER:

12 missed that, the legal -- legal fee. 13 THE OFFICIAL INTERPRETER:

14 the legal fee. I said that. Did I say legal fee? 15 THE PRIVATE INTERPRETER:

16 so, but as long as you say that. 17 BY MS. CLAIBORN:

How much of the \$21 million is comprised 19 of legal fees? 20 THE OFFICIAL INTERPRETER:

21 that one again? 22 BY MS. CLAIBORN:

24 THE OFFICIAL INTERPRETER: Okay. 25 BY MS. CLAIBORN:

1 Q -- is comprised of legal fees? 2 A I think most of it is legal fee. 3 Q Why is Golden Spring New York paying your 4 legal fees? 5 A Because the Golden Spring New York is my 6 son and my family's company and they love me very 7 much. They hope -- they hoping me to live, not be 8 killed by the people behind me. 9 Q Do you have any written agreement with 10 Golden Spring New York? 11 A Yes. 12 Q What legal -- sorry.

13 agreements do you have with Golden Spring New York? 14 A It's agreement for borrowing -- borrowing 15 money. 16 Q When did you enter into that agreement to 17 borrow money? 18 A A few years ago.

19 rough time. 20 THE PRIVATE INTERPRETER: I don't recall. 21 MS. CLAIBORN:

22 THE OFFICIAL INTERPRETER:

23 don't remember the time. 24 BY MS. CLAIBORN: 25 Q What are the terms of the legal agreement

1 with Golden Spring New York? Sorry.

2 rephrase that.

3 agreement with Golden Spring New York?

I don't remember. 5 UNIDENTIFIED SPEAKER: Sorry.

6 repeat the English, please? 7 MS. CLAIBORN:

8 repeat. 9 THE OFFICIAL INTERPRETER:

10 remember. 11 BY MS. CLAIBORN:

13 agreement with Golden Spring New York to pay back 14 all of the money?

Yes. 16 MR. BALDIGA:

17 question. 18 BY MS. CLAIBORN:

That Golden Spring paid to lawyers on your 20 behalf.

Yes. 22 THE PRIVATE INTERPRETER:

23 (indiscernible) of a difference in the interpreting. 24 For example, the interpreter did not interpret under 25 the agreement, are you obligated to make them all --

134 Entered 10/04/22 11:50:18 Page 46 of

1 to pay back all the money. All the money that is,

3 MR. BALDIGA: Okay. 4 THE PRIVATE INTERPRETER: -- spent on the 5 lawyer. 6 MR. BALDIGA: Maybe Holley can clarify 7 that. 8 THE PRIVATE INTERPRETER: Yeah. 9 BY MS. CLAIBORN: 10 Q I'm going to ask a long question. I'm 11 going to break it into parts. 12 Mr. Kwok, are you obligated to pay back 13 Golden Spring New York for all of the money that 14 Golden Spring New York paid to lawyers on your 15 behalf? 16 A Yes. 17 Q Is that agreement with Golden Spring New 18 York in writing? 19 A Yes. 20 Q Is that the same written agreement you 21 mentioned a few minutes ago? 22 A Yes.

24 agreement with Golden Spring New York? 25 A Yes.

2 with Golden Spring New York?

In the past week, I had a case with Logan 4 Cheng. The settlement with Logan Cheng, the money 5 from -- for the settlement is the money I borrow 6 from Golden Spring New York.

8 with Golden Spring New York?

I don't remember.

11 agreement with any of the attorneys who represent 12 you in litigation? 13 Can you -- can you answer, Mr. Kwok? 14 THE OFFICIAL INTERPRETER:

15 with -- can you repeat one more time? 16 BY MS. CLAIBORN:

Does Golden Spring New York have a -- any 18 kind of a fee agreement with any of the lawyers who 19 represent Mr. Kwok in litigation?

I don't know.

22 litigation you filed against UBS in London?

Attorney -- attorney office in London.

What is the name?

1 English name. 2 Q Does Golden Spring New York have a fee 3 agreement with that attorney in London? 4 A There should be. 5 MR. BALDIGA: I'm sorry.

6 answer? 7 THE OFFICIAL INTERPRETER: Should have. 8 BY MS. CLAIBORN: 9 Q Do you know if it does have enough -- have 10 a fee agreement? 11 A I'm not sure. 12 Q Who is the person at Golden Spring New 13 York who authorized payment of your litigation 14 expenses? 15 A My son. 16 Q Does your son have to speak with anyone 17 else in order to use Golden Spring New York money 18 for your benefit? 19 A Yes. 20 Q Who does your son need to speak with? 21 A He needs to talk to my family member, 22 which includes more than 100 family members, and 23 that because they have a fund. 24 THE PRIVATE INTERPRETER:

25 number is 181.

134 Entered 10/04/22 11:50:18 Page 49 of

1 BY MS. CLAIBORN: 2 Q Mr. Kwok, if your son wanted to give you 3 \$100, would he have to seek authority from someone 4 at Golden Spring New York? 5 A I don't know. 6 Q When you say your son has to speak with 7 someone at Golden Spring New York, how many people 8 does he need to speak with? 9 A I don't know details. 10 Q With respect to the \$8 million that Golden 11 Spring New York is willing to loan you, did your son 12 have to obtain consent of other people at Golden 13 Spring New York for that transaction? 14 A I don't know. 15 Q Have you ever been to the office of Golden 16 Spring New York in New York City? 17 A Yes. 18 Q How often do you go to the Golden Spring 19 New York office in New York City? 20 A Not -- not fixed. Sometimes I go there a 21 few times a month. Sometimes I haven't -- I haven't 22 gone there for a few months. 23 Q When was the last time you went to the 24 Golden Spring New York office? 25 A Yesterday.

1 Q Why did you go? 2 A For preparing today's meeting. 3 Q Did your son speak with Yanping Wang about 4 the \$8 million loan? 5 A I don't know. 6 Q Did you negotiate the terms of the \$8 7 million loan from Golden Spring New York? 8 A No. 9 Q Who was the person who negotiated the \$8 10 million loan on your behalf? 11 A My attorney. 12 Q Which attorney? 13 A Aaron Mitchell. 14 Q Who did Attorney Aaron Mitchell negotiate 15 with at Golden Spring New York? 16 THE OFFICIAL INTERPRETER:

17 one? 18 BY MS. CLAIBORN: 19 Q Who did Attorney Aaron Mitchell negotiate 20 with at Golden Spring New York? 21 A I don't know. My son. 22 Q Did you borrow the sum of \$1 million from 23 Lamp Capital, LLC in February 2022? 24 A Yes. 25 Q Is that loan from Lamp Capital, LLC in

1 writing? 2 A No. 3 Q What are the loan terms of the loan from 4 Lamp Capital? 5 A I don't know detail. 6 Q Who are the members of Lamp Capital, LLC? 7 A My son. 8 Q Are there any other members of Lamp 9 Capital, LLC? 10 A I don't know. 11 Q Who is the managing member of Lamp 12 Capital, LLC? 13 A I don't know. 14 Q Who was the person at Lamp Capital who 15 authorized the loan? 16 A My son. 17 Q What are the assets of Lamp Capital, LLC? 18 A I don't know. 19 Q What does Lamp Capital own? 20 A I don't know. 21 Q Have you ever funded Lamp Capital in any 22 way? 23 A No. 24 Q Have you ever invested any money in Lamp 25 Capital, LLC?

134 Entered 10/04/22 11:50:18 Page 52 of

1 A No. 2 Q Why did Lamp Capital loan you the \$1 3 million and not Golden Spring New York? 4 A I don't know. 5 Q What is the source of the \$1 million that 6 Lamp Capital loaned to you? 7 A I don't know. 8 MS. CLAIBORN: Why don't we take a five 9 minute break for the restroom? We'll reconvene 10 actually, at 12:10.

12 MS. CLAIBORN: We are back on the record 13 after a short break. 14 Mr. Kwok, you remain under oath. 15 BY MS. CLAIBORN: 16 Q Mr. Kwok, were you involved in the 17 selection of the lawyers who represent you in your 18 action in London? 19 A Yes. 20 Q Did your counsel in London request a 21 retainer? 22 A Yes. 23 Q And did you pay your counsel in London a 24 retainer? 25 A Yes.

1 Q How much? 2 A 300,000 pound. 3 Q And when was that 300,000 pound retainer 4 paid? 5 A Roughly two years ago. 6 Q Who funded the retainer? 7 A My son helped to pay -- pay that. 8 Q Did your son pay all of the retainer? 9 A Yes. 10 Q Did your son pay the retainer out of his 11 personal funds? 12 A Should be from the company, England. 13 Q What was the name of the company who paid 14 the retainer? 15 A I don't remember. 16 Q Did Golden Spring New York pay the 17 retainer to your London counsel? 18 A I don't remember details because other 19 than the retainer and the other -- a few more 20 payments in -- you know, after. 21 Q Mr. Kwok, if you wanted to go buy a pair 22 of shoes, how would you pay for a pair of shoes? 23 A I will ask Golden Spring New York to pay 24 for it. 25 Q And how would that process work?

134 Entered 10/04/22 11:50:18 Page 54 of

1 A And I will talk to the director and E Wa 2 Wang (ph) and ask her to contact -- talk to my son 3 and to pay for the shoes. 4 Q How does the shoe company get the money? 5 The shoe store. 6 A I don't know. Usually, it's E Wa Wang and 7 communicate, because my English ability is not 8 capable to communicate. 9 Q If you went to a store, tried on shoes, 10 and wanted to take them home from the store, how 11 would you pay for the shoes? 12 A In the recent few years I basically never 13 bought a pair of shoes. 14 Q What was the last thing you paid for? 15 A Recently, I didn't go to buy anything. 16 MR. BALDIGA: I'm sorry. Could you repeat 17 that? 18 THE OFFICIAL INTERPRETER: Recently, I 19 didn't go to buy anything. 20 BY MS. CLAIBORN: 21 Q My question wasn't recently. My question 22 was, what was the last thing that you purchased? 23 A I don't remember. 24 Q Do you ever eat in a restaurant? 25 A Recent years, I didn't.

Case 22-50073 Doc 913-5 Filed 10/04/22 Entered 10/04/22 11:50:18 Page 55 of

2 restaurants?

4 killed by the people behind me, because I was always 5 in the process getting chased.

When you ate in a restaurant, were you the 7 person who paid the bill?

I don't have money to pay, so that's why I 9 don't go there.

Mr. Kwok, if you wanted to go buy a cup of 11 coffee, how would you pay for it?

I never bought a cup of coffee.

13 I'm afraid the people behind me might poison me in 14 the coffee.

16 you're out and about and you want to buy water, how 17 would you pay for it?

19 out to buy water outside. 20 THE PRIVATE INTERPRETER:

21 (indiscernible) difference in the nuance. 22 THE OFFICIAL INTERPRETER:

24 THE WITNESS:

25 outside, walk around, and then buy water or coffee.

1 BY MS. CLAIBORN: 2 Q Mr. Kwok, do you have any interest in any 3 mutual funds? 4 A No. 5 Q Do you own any bonds? 6 A No. 7 Q Do you own any publically traded stock in 8 any company? 9 A No. 10 Q Do you own any cars? 11 A No. 12 Q Do you have access to any cars? 13 A Yes. 14 Q And whose cars do you have access to? 15 A My son's and Golden Springs. 16 Q Does Golden Spring provide you with a car 17 that's yours to use? 18 A Yes. 19 Q What kind of car is that?

21 THE PRIVATE INTERPRETER: Maybach. 22 THE OFFICIAL INTERPRETER: Huh? 23 THE PRIVATE INTERPRETER: Maybach. 24 THE OFFICIAL INTERPRETER: Maybach? Okay. 25 I don't know the name of it.

1 THE WITNESS: Maybach. 2 BY MS. CLAIBORN: 3 Q Mr. Kwok, do you have a driver's license? 4 A I have a Hong Kong's driver's license. 5 Q Do you drive in the United States? 6 A Almost no. 7 Q When you do drive, whose car do you drive? 8 A Golden Spring's. 9 Q Do you keep a car at your Greenwich 10 residence? 11 A Yes. 12 Q And what car is that? 13 A Maybach. 14 Q Do you own any aircraft? 15 A No. 16 Q Have you ever owned any aircraft? 17 A Before, yes. 18 Q When did you own aircraft? 19 A Probably 2010 to 2016. 20 Q How many air craft did you own? 21 A One. 22 Q And what was it? 23 A Airbus 319. 319. 24 Q And what happened to the Airbus 319? 25 A It was confiscated by UBS and the Chinese

1 Communist Party. 2 Q Okay. Do you own any water craft? 3 A No. 4 Q Who owns the yacht known as the Lady May? 5 A My daughter. 6 Q Does your daughter own the Lady May in her 7 personal name? 8 A Should be from a company. 9 Q And what is the name of the company that 10 owns the Lady May? 11 A I don't know. 12 Q Where is the Lady May currently? 13 A I don't know. 14 Q Since the bankruptcy filing, have you 15 asked your daughter to return the Lady May to New 16 York? 17 A I did ask her and asked her to talk to her 18 attorney to return the boat back to New York. 19 Q When did you have that conversation? 20 A Last month, after the court date.

21 met with you. 22 Q And what did your daughter say? 23 A She said that she would talk to her 24 attorney and then talk to my attorney. 25 Q Did your daughter agree to have the Lady

134 Entered 10/04/22 11:50:18 Page 59 of

1 May return to New York? 2 A She was not willing to talk to me in any 3 detail. She want -- she wanted to talk to her 4 attorney. 5 Q Did your daughter say no to your request 6 that she return the Lady May to New York? 7 A No, he didn't -- she didn't. 8 THE PRIVATE INTERPRETER: The question was 9 not completely interpreted. 10 THE OFFICIAL INTERPRETER: I know, but she 11 -- she already -- he already answered and -- 12 MR. BALDIGA: Wait until he finishes. 13 THE WITNESS: No, he -- no. 14 BY MS. CLAIBORN: 15 Q Mr. Kwok, do you own or have an interest 16 in any trust? 17 A No. 18 Q Are you the beneficiary of any trusts? 19 A No. 20 Q This is a long question. Mr. Kwok, where 21 is the \$12,000 check paid to you in connection with 22 your lawsuit against Baosheng Guo? 23 A It's in attorney's escrow account. 24 Q What is the name of the attorney who is 25 holding the check?

134 Entered 10/04/22 11:50:18 Page 60 of

1 A I can't pronounce the attorney's name 2 completely. 3 Q What is the attorney's first name? 4 A I cannot -- I'm not able to read out the - 5 - the pronounce his name. 6 Q Is the attorney who's holding the check 7 the same attorney who represented you in that 8 lawsuit? 9 A It should be. 10 Q On your Schedule A-B, you did not disclose 11 that \$12,000 check. Why? 12 MR. BALDIGA: Wait for a question. No. 13 Could he interpret that? 14 BY MS. CLAIBORN: 15 Q Why did you not disclose that \$12,000 16 check? 17 A My attorney thinks because the money is 18 not in my account, so I'm not allowed to -- we're 19 not -- I'm not supposed to disclose that. 20 Q Okay. Mr. Kwok, do you have any patents? 21 A No. 22 Q Do you have any copyrights? 23 A No. 24 Q Do you have any intellectual property of 25 any kind?

No. 2 MR. BALDIGA: Excuse me.

3 sure if you're going to come back to it, but there 4 is a reference to the \$12,000. 5 MS. CLAIBORN: I did see that. 6 MR. BALDIGA:

7 disclose it. 8 MS. CLAIBORN: He did not.

9 response to the questions on Schedule A-B. 10 MR. BALDIGA: It's right there. 11 MS. CLAIBORN:

12 whether or not it's disclosed, but it's my position 13 that it's not disclosed.

14 take a different position. 15 BY MS. CLAIBORN:

17 company called Ace Decade Holdings Limited?

Yes.

20 interest in Ace Decade Holdings Limited?

So I have the interest and ask for UBS to 22 pay back \$500 million. That kind of interest.

Are you the only legal owner of Ace Decade 24 Holdings Limited? 25 THE OFFICIAL INTERPRETER:

1 only -- can you repeat that question? 2 BY MS. CLAIBORN:

4 Decades?

I am a legal representing owner.

Are there any other owners of Ace Decade?

No.

When did you become an owner of Ace Decade 9 Holdings Limited?

At the end of 2014.

This is a long question.

12 litigation in London against UBS, you are an 13 individual plaintiff.

14 claim as an individual plaintiff?

Because I'm the 100 percent representative 16 for Ace Decade.

18 there is an allegation that Ace Decade gave \$500 19 million to Dawn State Limited.

20 get the \$500 million?

I loan from my family.

Did you borrow money from your family and 23 give it to Ace Decade?

Yes. 25 MS. CLAIBORN:

1 let's start over, because I don't think that was --

3 THE PRIVATE INTERPRETER:

5 MS. CLAIBORN:

6 because it didn't involve Dawn State -- 7 THE PRIVATE INTERPRETER: Yes. 8 MS. CLAIBORN:

9 over. 10 BY MS. CLAIBORN:

Where did you get the money to give to Ace 12 Decade, the 500 million? 13 MR. BALDIGA:

14 that. I think he said his family did that, but you

16 THE WITNESS: From my family. 17 BY MS. CLAIBORN:

19 money that you then gave to Ace Decade?

John Way (ph).

Who is John Way?

A member from my family.

Is he a relative of yours?

25 THE PRIVATE INTERPRETER: Son-in-law.

1 THE OFFICIAL INTERPRETER: Son-in-law? 2 Okay. Sorry. 3 BY MS. CLAIBORN:

On your Schedule A-B, you list a possible 5 malpractice claim against Boise Schiller.

6 please explain what that is?

8 represented me in New York to have a lawsuit against 9 UBS. He gave a lot of forced documents to the Court 10 and without my permission.

11 family. He also threaten myself after drinking.

12 brought a lot of loss to us, including providing any 13 English/Chinese translated documents to me before 14 present them to the -- to the lawyer, or to the 15 judge. That's why I -- that's why we sue him.

17 you in that malpractice action?

19 that.

21 your malpractice claim?

Because I need to borrow money from him.

Has a lawyer been selected?

Not yet.

Case 22-50073 Doc 913-5 Filed 10/04/22 Entered 10/04/22 11:50:18 Page 65 of

Ho Wan Kwok - April 6, 2022 company aside from Ace Decade? A No, but the -- I own the Bravo Luck, the apartment, only for a few months, some of the interest. And because the apartment is a co-op, so they used my name to buy the apartment after I -- after we bought apartment, and then we returned the stock interest back. UNIDENTIFIED SPEAKER: I'm sorry. He must have spoken for 30, 40 seconds. Clearly said more than that. Is there a more fulsome translation? THE OFFICIAL INTERPRETER: Did I miss anything? MS. CLAIBORN: Let me see if I can follow up. BY MS. CLAIBORN: Q Mr. Kwok, do you own, currently, an interest in Bravo Luck? A No. Q Mr. Kwok, do you own an interest in any limited liability company? A No. Q Mr. Kwok, do you own an interest in any partnership? A I used to own the plane company called the Orange or Shiny Time, but that was before and

1 doesn't exist anymore.

Mr. Kwok, do you currently own an interest 3 in any partnership?

No.

Mr. Kwok, do you currently own an interest 6 in any joint venture?

No.

9 interest in any other company right now?

No.

11 Time before, but not right now.

13 security interest in any of your litigation?

I owe them money.

16 York, any interest in any of your assets, anything 17 that you own?

No.

20 Golden Spring -- sorry. Wrong name.

21 to win a lawsuit against UBS, would any of the money 22 that you win have to be paid to Golden Spring?

Yes.

And how much would that be?

134 Entered 10/04/22 11:50:18 Page 67 of

1 THE PRIVATE INTERPRETER: 21 million. 2 THE WITNESS: 21 million. 21 million and 3 plus now. Probably it's about 300 million. 30 4 million. Or 30 million. Yeah. 5 BY MS. CLAIBORN: 6 Q Is there a document that says that any 7 litigation winnings you receive need to be paid to 8 Golden Spring? 9 A Yes. 10 Q What is the name of that document? 11 THE OFFICIAL INTERPRETER: I'm going to 12 ask him to repeat it. 13 I didn't get it. I just ask him to break

15 THE WITNESS: I have a case in DC. There 16 is a attorney office representing me for political 17 asylum and it was attacked by the cyber attack from 18 the Chinese Communists, and so they -- the attorney 19 office was closed, and they gave my personal 20 information to the communist party, and then I sue 21 them. And that litigation fee, attorney fee, came 22 from Golden Spring New York. 23 I ask for the settlement for 50,000 -- \$50 24 million. If I won that money, I will give the money 25 back to Golden Springs for the money they supported Case 22-50073 Doc 913-5 Filed 10/04/22 Entered 10/04/22 11:50:18 Page 68 of

1 me for attorney fees. 2 THE PRIVATE INTERPRETER:

3 say settlement.

4 a settlement. 5 THE OFFICIAL INTERPRETER:

6 for \$50 million. Yeah.

7 that lawsuit, and if he win -- if he wins the money, 8 then he will return the money back to the Golden 9 Spring New York. 10 BY MS. CLAIBORN:

My question was, what was the name of the 12 document under which you would be repaying Golden 13 Spring for your litigation?

15 THE OFFICIAL INTERPRETER:

16 that one? 17 THE WITNESS:

18 agreement, I borrowed the money from Golden Spring 19 New York to sue the attorney office. 20 BY MS. CLAIBORN:

And what is the name of the agreement?

I don't remember.

Is it a promissory note?

I don't remember.

Is it a contract?

1 A I don't remember clearly. 2 Q Who prepared the document? 3 A Attorney. 4 Q What was the name of the attorney who 5 prepared the document? 6 A Melissa. 7 Q What is Melissa's last name? 8 A I don't know. 9 Q Did Melissa the attorney represent you in 10 drafting that document? 11 A Yes. 12 Q And who represented Golden Spring in 13 drafting that document? 14 A I don't know. 15 Q Did Golden Spring have any attorney? 16 A Yes. 17 Q You just don't remember who it was? 18 A They have a lot of attorneys. 19 Q Is there more than one written agreement 20 under which you owe money to Golden Spring New York? 21 A Yes. 22 Q How many agreements are there? 23 A Kind of two or three, or three or four.

24 don't remember clearly. 25 Q And does someone keep track of the money

1 that you borrow from Golden Spring New York?

My attorney will write it down.

3 it.

What's the name of that attorney?

Aaron Mitchell.

Did you say Aaron Mitchell?

Oh, yes.

And how does Aaron Mitchell keep track of 9 the monies that you borrow from Golden Spring New 10 York?

In detail, I don't know.

13 Spring New York keep track of the money that you 14 borrow from Golden Spring New York?

I don't know.

17 Attorney Aaron Mitchell showing how much you owe to 18 Golden Spring New York?

20 between me and my attorney I shouldn't answer. 21 MR. BALDIGA:

22 MS. CLAIBORN:

24 MR. BALDIGA:

25 MS. CLAIBORN: -- a privileged answer.

1 MR. BALDIGA: That's -- give me a second. 2 You could answer that last question yes or no, so if 3 you ask again, I think he will say yes or no, and 4 then we can take it step by step. 5 BY MS. CLAIBORN:

Have you ever seen a document prepared by 7 Attorney Mitchell that shows you how much money you 8 have borrowed from Golden Spring? 9 MR. BALDIGA: Wait.

10 needs to be interpreted. 11 THE OFFICIAL INTERPRETER: What? 12 MS. CLAIBORN:

13 MR. BALDIGA:

14 MS. CLAIBORN:

15 he'll reinterpret. 16 MR. BALDIGA:

17 what -- I am telling the witness he may answer yes 18 or no only. 19 THE WITNESS: Yes. 20 MS. CLAIBORN:

21 given the hour of the day, I thought that we could 22 take a short break and then reconvene with creditors 23 being given the opportunity to ask questions. 24 I suggest we reconvene at 1:15. 25 MR. BALDIGA: Is that okay?

1 MS. CLAIBORN: Okay. Thank you.

2 reconvene at 1:15.

4 MS. CLAIBORN:

5 reconvened. We are back in session after a short 6 break and Mr. Kwok, you remain under oath. 7 And that this point, Mr. Wolman has some 8 questions for you, Mr. Kwok. 9 EXAMINATION BY MR. WOLMAN: 10 Q Good afternoon, Mr. Kwok.

12 questions about a prior deposition, specifically 13 about the times you had invoked your rights under 14 the Fifth Amendment of the U.S. Constitution.

16 investigated for any crime? 17 THE OFFICIAL INTERPRETER: April 21st? 18 MR. WOLMAN: April 1st, 2021. 19 THE OFFICIAL INTERPRETER:

20 that question, sir? 21 Q Were you being investigated for any crime?

23 investigating GTV and they can communicate with our 24 attorney. 25 Q Are you referring to the Securities and

1 Exchange Commission?

Yes.

And what exactly were they investigating? 4 MR. BALDIGA: Objection. 5 I need to ask whether this would reveal 6 privileged information. 7 Would your answer to the last question be 8 information from your attorneys? 9 THE PRIVATE INTERPRETER:

10 THE OFFICIAL INTERPRETER:

11 help. 12 THE PRIVATE INTERPRETER:

14 MS. CLAIBORN:

15 again. Mr. Baldiga, maybe you can just repeat 16 yourself and Mr. Jack, you can try again. 17 THE OFFICIAL INTERPRETER:

18 what you want to say? 19 MR. BALDIGA:

20 you were being investigated for.

21 that you know, was that provided to you by your 22 attorneys? 23 THE WITNESS: Yes. 24 MR. BALDIGA:

25 would you have to divulge what you were told by your

Case 22-50073 Doc 913-5 Filed 10/04/22 Entered 10/04/22 11:50:18 Page 74 of

1 attorneys? 2 THE OFFICIAL INTERPRETER: Have to be what? 3 Divulged? 4 MR. BALDIGA:

5 you were told by your attorneys? 6 THE WITNESS: Yes. 7 MR. BALDIGA:

8 not to answer on the basis of the attorney/client 9 privilege. 10 MR. WOLMAN:

11 information. 12 MR. BALDIGA: Hold on.

13 interpreted. 14 MR. WOLMAN:

15 attorney that is not specifically a communication 16 for the purpose of giving advice or receiving 17 information is not privileged information.

18 attorneys says the sky is blue, that is not a 19 privileged communication. 20 MR. BALDIGA: His is arguing with me. 21 There is not question to you. 22 MR. WOLMAN:

23 continue to instruct your client to improperly 24 invoke the attorney/client privilege? 25 MR. BALDIGA:

1 by question basis. 2 MR. WOLMAN:

3 maintain the instruction? 4 Mr. Kwok, are you refusing to answer my 5 question? 6 THE WITNESS: Yes. 7 MR. WOLMAN:

8 refusing to answer my question? 9 MR. BALDIGA:

10 from counsel on account of attorney/client 11 privilege. 12 THE WITNESS:

13 question because of the privilege between the 14 attorney and me. 15 BY MR. WOLMAN:

17 Securities and Exchange Commission?

No.

Has the Securities and Exchange Commission 20 closed its investigation of you? 21 MR. BALDIGA:

22 answer that yes or no, if you know.

No.

Has the Securities and Exchange Commission 25 brought any charges against GTV?

1 A I don't know. 2 Q Have you been in the past five years 3 subject to an audit by the U.S. Internal Revenue 4 Service? 5 A No. 6 Q In the last five years have you been 7 subject to an audit by the New York State taxing 8 authority? 9 A No.

11 Connecticut? On what date? 12 A The beginning of March, 2020, roughly. 13 Q To be clear, you say you were a resident 14 of Connecticut in March of 2020? 15 A Yes. 16 Q So how come in Mr. Cheng, my client's, 17 lawsuit against you you signed a statement under 18 oath indicating that you were a resident of the 19 Sherry Netherlands Hotel? 20 THE OFFICIAL INTERPRETER:

21 that, counsel? 22 Q If you were a resident of Connecticut in 23 March of 2020, you signed a statement under oath in 24 Mr. Cheng's lawsuit against you that you resided at 25 the Sherry Netherlands Hotel.

1 A I don't 100 percent live in Connecticut, 2 but sometimes I live in New York also. 3 Q When did you start living in Connecticut 4 more than 50 percent of the time? 5 A Since March, 2020. 6 Q You had some assets you claim seized by 7 China, correct? 8 A It's not mine. It's from my family.

9 my family's. 10 Q Have you ever had assets seized by China? 11 A You're talking about under my name? 12 Q Yes. 13 A No. 14 Q All right.

15 personal net worth? 16 A No. 17 Q That wasn't a yes or no question. 18 THE OFFICIAL INTERPRETER:

19 your question again? 20 MR. WOLMAN: Yes. 21 Q In 2010 what was your personal net worth? 22 A I didn't have any property. 23 Q Have you ever had property in your name 24 over \$1 million and by that I include where you 25 owned an interest in a company that interest,

1 therefore, contributes to your work? 2 A Before 2000, yes. 3 Q Okay. What was your net worth in 1999? 4 A I never calculate in detail. 5 Q What would you estimate it as? 6 A Roughly around 100 million. 7 Q And what happened to that \$100 million 8 worth of assets? 9 A Because in 2000 I got a Hong Kong passport 10 and in China and they don't allow me to have any 11 property, asset. 12 Q Have you abandoned all claims to whatever 13 assets you had in 1999? 14 A Yes. 15 Q Why have you abandoned your claims? 16 THE OFFICIAL INTERPRETER: Abandoned what? 17 Q Your claim to those assets? 18 A Because I was not allowed to have any 19 assets in China. 20 Q If China changed its policy, would you 21 have any right or ability to get those assets back? 22 MR. BALDIGA: Objection.

23 can answer. 24 A I don't know. 25 Q What was your largest asset in 1999?

1 A There was the assets from a hotel, equity 2 interest of a hotel in China. 3 Q And who holds that interest now? 4 A Chinese Community Party. 5 Q Is it held in the name of the Party? 6 A China only has one autocrat government, 7 the party, and our family's assets were taken -- 8 were seized by them. 9 Q How did your son become wealthy enough to 10 fund Golden Spring and Lamp Capital? 11 A Because he started very early to do 12 investment and also bring brand names to China. 13 Q Where did he get the money for his 14 investment? 15 A I don't know. 16 Q Ms. Claiborn asked you about agreements 17 with Golden Spring and you could not identify who 18 the lawyer was for Golden Spring.

19 that? 20 A True. 21 Q I'd like to try to refresh -- to ask you 22 potentially to refresh your memory was it a lawyer 23 named Daniel? 24 THE OFFICIAL INTERPRETER:

25 Daniel?

Yes, Daniel Pedolsky.

3 Spring attorney and my personal attorney.

5 interest with Mr. Pedolsky? 6 THE OFFICIAL INTERPRETER:

7 that?

9 interest with Attorney Daniel Pedolsky?

I don't remember.

You mentioned two or three -- or three or 12 four agreements with Golden Spring. Can you identify 13 each of those agreements?

I'm not sure.

16 those agreements?

That loan from Golden Spring is to have a 18 settlement with Logan Cheng.

20 lawyers to sue Logan Cheng?

I don't remember.

And what were the other agreements, other 23 than with Mr. Cheng?

Case 22-50073 Doc 913-5 Filed 10/04/22 Entered 10/04/22 11:50:18 Page 81 of

Ho Wan Kwok - April 6, 2022 name. MR. WOLMAN: All right. Thank you and this time I have to go but thank you. I'll try to dial in. MS. CLAIBORN: Thank you. Can I ask whoever is on the line if they could mute themselves, because they can hear you typing. All right. Who else would like to ask questions? Mr. Harbach. Go ahead, Mr. Harbach. MR. HARBACH: Thank you. For the record, I'm David Harbach with O'Melveny and Meyers and I represent PAACS. EXAMINATION BY MR. HARBACH: Q Mr. Kwok, I'd like to ask some clarifying questions based on questions that Ms. Claiborn asked you today. Earlier today she asked you if you owned any foreign currency and you said no. She also asked you if you owned any digital currency and you said no. My question is have you ever ordered or directed the purchase of either foreign currency or digital currency on behalf of any entity?

1 THE OFFICIAL INTERPRETER:

2 that? 3 MR. HARBACH: Sure.

My question is whether you have ordered or 5 directed the purchase of any foreign currency or any 6 digital currency on behalf of any entity?

What you mean direct?

9 foreign currency or digital currency?

No.

12 questions about access to credit cards and debit 13 cards. And I want to make sure that we have your 14 answer clear, because she asked you not whether you 15 had any credit cards but whether you had any access 16 to credit cards. I want to make sure that you 17 understand the difference. 18 THE OFFICIAL INTERPRETER: He's just asking 19 why you want to represent Ms. Holley's asked 20 questions. 21 MR. HARBACH:

22 you of a question she asked you earlier today, sir. 23 THE PRIVATE INTERPRETER:

24 understand the question. 25 MR. BALDIGA: Mr. Baldiga's right.

134 Entered 10/04/22 11:50:18 Page 83 of

1 There's not a question pending. 2 Q The question is do you understand the 3 difference between having a credit card and having 4 access to a credit card? 5 A I believe I don't have. 6 Q You don't understand the difference? 7 A I don't know much. 8 Q Okay. Well, let me give you an example. 9 Let's talk about the Maybach. 10 I believe that you represented to us today 11 that you have access to the Maybach for 12 transportation. Is that correct? 13 A Yes. 14 Q But I believe it's also your position that 15 you do not own the Maybach. Isn't that right? 16 A Yes. 17 Q In other words, your position is the 18 Maybach is not yours, right? 19 A Yes. 20 Q Okay. So I use that example to illustrate 21 the example between owning something and having 22 access to something. Does that help you? Do you 23 understand the difference? 24 A Now I understand you. 25 Q Okay. Thank you.

Case 22-50073 Doc 913-5 Filed 10/04/22 Entered 10/04/22 11:50:18 Page 84 of

Ho Wan Kwok - April 6, 2022 question about credit cards and debit cards. Do you have access to any credit cards or debit cards, whether or not they are yours? A I don't understand the difference what he means, access like if I use it myself or if I have somebody else use it. Q Well, let's take those one at a time. Let's begin with using it yourself. Has any member of your family ever provided you a credit card or a credit card number to use for yourself? A I never used. Q The other example you mentioned was perhaps a member of your family using a credit card on your behalf. Is that something that has happened? A What do you mean represent me to use? Q I'm asking about whether to your knowledge any member of your family has ever used a credit card or a debit card to purchase things for you? A My son, my daughter, my wife. They all have credit card to buy things for me. THE PRIVATE INTERPRETER: The witness did not say that, use the credit card to buy things for me. The witness said that my son, my wife bought things for me.

134 Entered 10/04/22 11:50:18 Page 85 of

1 THE OFFICIAL INTERPRETER: Yeah, they used 2 their card and they both -- they all have it. They 3 all have the cards. That's what he said.

5 THE OFFICIAL INTERPRETER: Yes, I did it 6 right. 7 THE WITNESS: And so my wife and my son 8 and my daughter have their own cards and also other 9 family members use their cards to buy things for me. 10 Q Is that ever at your direction? 11 A No. 12 Q Never. 13 A No. 14 Q Is it at your request? 15 A No. 16 Q Is Yan Ping Wang, the same as Yvette Wang? 17 A Yes. 18 Q Earlier Ms. Claiborn asked you about 19 Golden Spring Hong Kong. 20 You told her that your son owns it. Do 21 you recall that? 22 A Yes. 23 Q My question for you is since when has your 24 son owned Golden Spring Hong Kong? 25 A I don't know.

2 owned an interest in Golden Spring Hong Kong?

I don't remember.

5 whether you were ever a corporate officer of Golden 6 Spring Hong Kong? 7 THE OFFICIAL INTERPRETER:

8 that one?

10 whether you were ever a corpora officer of Golden 11 Spring Hong Kong?

12 possible that you were and you're just not certain?

I don't remember.

Ms. Claiborn asked you in a few different 15 ways about whether you know how Golden Spring New 16 York is funded or makes money. 17 Since when has Golden Spring been paying 18 your personal living expenses?

2015.

So six or seven years approximately?

22 called Bruno Wu from Mainland China and called my 23 family, my son, daughter and wife and so since then 24 I start spending money coming from Golden Spring New 25 York.

1 THE PRIVATE INTERPRETER:

2 the witness says some. 3 THE OFFICIAL INTERPRETER: What? 4 THE PRIVATE INTERPRETER:

5 the witness said some. 6 THE WITNESS:

7 they caught, my wife and daughter and a lot of my 8 family members, but not my son.

10 Golden Spring has been paying your personal 11 expenses. Is that right?

Yes.

14 never discuss with any of your family members where 15 the money was coming from?

17 caught by -- were arrested by your client, Bruno Wu, 18 and so I have no communication. I cannot communicate 19 with him. 20 THE PRIVATE INTERPRETER:

21 partner of PAACS -- the partner who the counsel was 22 represented, PAACS -- partner of PAACS -- 23 THE OFFICIAL INTERPRETER: I don't know. 24 He didn't mention anything about PAACS. 25 THE WITNESS:

Case 22-50073 Doc 913-5 Filed 10/04/22 Entered 10/04/22 11:50:18 Page 88 of

1 representing the client, Bruno Wu, arrested a lot of 2 your family members.

4 arrested a lot of your family members so you can't 5 communicate with them.

7 communication with your daughter, or your wife, or 8 your son?

Yes.

11 communication with any of those three individuals 12 did you ever ask them about where Golden Spring's 13 money was coming from?

Yes, I asked.

And who did you ask?

I asked all three of them.

And what did they say?

They told me because I was in the position 19 of being chased so don't ask our own financial 20 information.

21 help you to -- we will help you as much as we can.

When was that?

After 2017.

How long after 2017?

I don't remember.

2 your family were the three of them together or where 3 these separate conversations?

Separate.

And each of the three of them said more or 6 less the same thing?

Similar.

9 correct.

10 Springs money was coming from and each of them said 11 to you don't ask me about that because -- finish the 12 sentence for me.

14 understand.

16 understand.

17 your family members told you not to ask why your 18 family members told you not to ask about where 19 Golden Spring got the money. 20 MR. BALDIGA: Let him ask you a question.

22 members told you not to ask them about where Golden 23 Spring money came from? 24 MR. BALDIGA: Objection. If you know. 25 THE OFFICIAL INTERPRETER:

1 to object the question? 2 MR. BALDIGA: I objected. 3 THE OFFICIAL INTERPRETER:

4 objected. 5 MR. BALDIGA:

6 knows. 7 THE OFFICIAL INTERPRETER: Okay. 8 THE WITNESS:

9 arrested by his partner and got released 2017 and 10 released to New York.

11 tremendously by communist party.

12 tortured them is this attorney's partner.

13 have their own attorneys.

14 or communicate with me about their own financial and 15 personal information.

16 better go through attorneys. 17 This is the doctrine, the thing, my family 18 members told them before they came to New York.

19 just want to tell you it's the meaning, very similar 20 meanings, but I can't tell you word by word. 21 So I don't want this counsel make any 22 stories about my daughter -- about my daughter's 23 forgery, giving false testimony.

24 story. 25 The last time when we were here with Ms. Case 22-50073 Doc 913-5 Filed 10/04/22 Entered 10/04/22 11:50:18 Page 91 of

1 Holley and he was making false lies and saying I'm

2 using my Twitter account and saying that the judge 3 in New York was communist party and I didn't even 4 have a Twitter account. 5 MR. HARBACH:

6 today is the first that I've uttered a word in 7 connection with this litigation in court.

8 don't think you're talking about me, sir. 9 THE WITNESS:

10 from attorney in your office.

11 before you called Andy Morse (ph) and was kicked out 12 by the judge because he was making false claims for 13 five years and was kicked out by the judge.

14 law office was always making false claims. 15 MR. BALDIGA:

16 because I can't know whether to object unless you're 17 just trying to answer his question. 18 THE WITNESS:

19 daughter and wife individually to say the same 20 thing. If I say the same thing, same words, that 21 will be making false story. 22 MR. HARBACH: I understand. 23 THE WITNESS:

24 imagination and put it into my head.

25 the New York South District and the judge was

Case 22-50073 Doc 913-5 Filed 10/04/22 Entered 10/04/22 11:50:18 Page 92 of

Ho Wan Kwok - April 6, 2022 (indiscernible) by them and they give me the wrong sentencing. UNIDENTIFIED: Can you say that last -- THE WITNESS: Because of their false claims, so that's why the judge from the south district of New York, the judge, gave me the wrong sentencing. THE PRIVATE INTERPRETER: And also the interpreter did not interpret fully counsel's instruction to the witness previously about his objection. MS. CLAIBORN: If you want to repeat it, go ahead. MR. BALDIGA: I think you just have to listen to these questions and answer just these questions. MR. HARBACH: Sorry. Counsel will move to a different topic. BY MR. HARBACH: Q Mr. Kwok, Ms. Claiborn asked you today about a \$21 million debt that you owe to Golden Spring. She asked you how much of that 21 million was legal fees and your answer was I think most of it. I'd like to know what you meant by most of it.

Case 22-50073 Doc 913-5 Filed 10/04/22 Entered 10/04/22 11:50:18 Page 93 of

1 Did you mean \$11 million or do you mean close to \$21 2 million.

I don't remember.

5 for legal fees?

I don't remember.

8 settlement and that there was money borrowed from 9 Golden Spring in connection with that.

Yes.

How much money was that loan for?

I don't remember exactly.

13 200. Two -- \$300,000.

15 Golden Spring?

I don't remember.

18 ever been to Golden Spring's offices in New York, 19 you said yes. 20 What's the address of those offices?

Yes.

What is the address of those offices?

64th Street, 162.

You also mentioned that the last time you 25 were there was yesterday and that the reason you

134 Entered 10/04/22 11:50:18 Page 94 of

1 went there was to prepare for today's meeting. 2 Who did you meet with there? 3 A My attorney. 4 Q Did you meet with anyone else besides your 5 attorney to prepare for today's meeting while you 6 were at the office? 7 A I don't know what you mean, the other 8 people. 9 Q Well, did you meet with anyone who works 10 for Golden Spring? 11 A Yes, I met Yvonne Wang. 12 Q And this was yesterday? 13 A Yes, I met her yesterday.

15 yesterday? 16 A No. 17 Q And tell me about your conversation with 18 Ms. Wang? 19 A What do you mean? 20 Q Well, I'd like to know what you talked 21 about with her. 22 A I ask her to arrange the food to eat and 23 the coffee. 24 Q Is that all?

A And also we talked about how to abolish

1 communist party. 2 Q I want to make sure I get this right. I

4 MR. BALDIGA:

5 last thing again. 6 THE WITNESS:

7 communist party. 8 MR. BALDIGA: Thank you. 9 Q Ms. Wang is an officer of Golden Spring, 10 correct? 11 A Yes. 12 Q And you directed her to bring coffee, 13 right? 14 A No, I didn't direct her. I'm just hoping 15 her to bring some coffee. 16 Q You were hoping or helping? 17 A Help. 18 Q You were helping.

19 you was what you talked about with Ms. Wang.

20 thought you said you asked her to bring some coffee 21 or maybe even told her to bring some coffee. 22 A No, your attorney office -- you attorney 23 office making and imagining things again. 24 Q I'll ask the question again. 25 MR. BALDIGA:

134 Entered 10/04/22 11:50:18 Page 96 of

1 put words in his mouth.

3 yesterday? 4 A Do you want me to talk about in detail? I 5 can talk about this for hours. 6 Q Well, no, not if the detail concerns how 7 to overthrow the Chinese Communist Party. So I'll be 8 more precise. 9 A So you don't want us to abolish Chinese 10 Community Party. Our job is to abolish Chinese 11 Communist Party. 12 MR. BALDIGA: Just answer the question. 13 THE WITNESS: You don't have a question. 14 You're just directing something. 15 Q Sometimes I speak in segments to allow the 16 interpreter to translate. 17 MR. BALDIGA: I think it would be helpful 18 if you just ask question and then the witness -- 19 I'll instruct him to answer your questions. That 20 would be helpful.

22 yesterday anything related to preparing for the 23 meeting today? 24 A Yes. 25 Q What did you discuss?

1 A I ask her to bring those documents here. 2 Q Anything else? 3 A I don't remember. 4 Q When was Lamp Capital created? 5 A I don't know. 6 Q Why was Lamp Capital created? 7 A I don't know. 8 Q Who created Lamp Capital? 9 A My son. 10 Q How do you know that? 11 A Because I borrow money from my son to pay 12 attorney fee. 13 Q The question is how do you know that your 14 son created Lamp Capital? 15 A Because my son said it. 16 Q He told you himself. 17 A Yes. 18 Q Did he ask for any advice from you about 19 whether to create Lamp Capital? 20 A No. 21 Q Did he ask you your opinion on whether he 22 should create Lamp Capital? 23 A No. 24 Q Did he tell you why he was creating Lamp 25 Capital?

134 Entered 10/04/22 11:50:18 Page 98 of

1 A No.

3 malpractice claim against Boise Schiller, you 4 mentioned someone you kept referring to as he. I'd 5 like to know who that person is? 6 A I don't know what you mean. 7 Q Yes, that was a bad question. I apologize. 8 You stated that there was someone who gave 9 false documents to the court without your 10 permission. That this person threatened your 11 family, that this person threatened you after 12 drinking and that this person brought lots of loss 13 to you and your family, including not providing 14 translated documents before presenting them to the 15 judge. 16 My question is who is that person? 17 A Schiller. The Attorney Schiller. 18 Q So Mr. Schiller of the Boise Schiller law 19 firm. Have I got that right? 20 A Yes. 21 Q Thank you. Do you have an understanding of 22 what business Lamp Capital is engaged in, if any? 23 A No. 24 Q Different subject. You said several times 25 today in connection with your answers that the Case 22-50073 Doc 913-5 Filed 10/04/22 Entered 10/04/22 11:50:18 Page 99 of

1 people behind me have done certain things. 2 Who are you talking about?

4 called Bruno Wu.

rape case.

6 a creditor here and that also was paid by Bruno Wu. 7 That attorney fee was paid by Bruno Wu.

8 Wu is also his partner and he invested \$800 million. 9 Bruno Wu's partner is also (indiscernible)

10 officer and they were investigating and they 11 combined a partner with them to investigate my case. 12 So April 18, 2017, so this (indiscernible) 13 start suing me, bring the lawsuit.

14 hours Bruno Wu is sending me the red note and they 15 start bringing the lawsuit. 16 MR. HARBACH:

17 THE WITNESS: The Chinese Communist Party 18 stopped the interview, the VOA interview with me. 19 They happened at the same time. 20 MR. HARBACH: Or I can let him go. 21 THE WITNESS:

22 this attorney firm were all false.

23 false document to the South District of New York 24 court.

25 yacht. The boat is mine.

Case 22-50073 Doc 913-5 Filed 10/04/22 Entered 10/04/22 11:50:18 Page 100 of

Ho Wan Kwok - April 6, 2022 from the South District Court and I file the bankrupt -- personal bankruptcy case twice and the day -- they (indiscernible) twice including Ms. Holley. And Ms. Holley was present. The first time when Ms. Holley was present in the court and they false testified saying -- and they said my daughter was giving false testimony for the Sherry bankruptcy case because my daughter never participated in that case. And Ms. Holley was there, was present the second co date and Ms. Holley was there also. The attorney from the firm was telling the judge and they said that I used the Twitter account to -- and they said on the Twitter and I was saying on the Twitter the south district judge was communist party member. You can see here all the people behind me and one is Bruno Wu and one person paid in many cases -- MR. HARBACH: I'd like to ask another question. BY MR. HARBACH: Q Are you aware one way or the other whether your bankruptcy counsel, the Brown Rudnick law firm,

has ever previously represented Bruno Wu?

1 THE OFFICIAL INTERPRETER:

2 little break? I just can't concentrate as much. 3 Just too much. Can I take a break? 4 MS. CLAIBORN:

5 question and then we'll take a break? 6 THE OFFICIAL INTERPRETER: Yes.

7 repeat that question? 8 MR. HARBACH: I'd be happy to.

10 whether your bankruptcy counsel, the Brown Rudnick 11 law firm, previously represented Bruno Wu? 12 THE OFFICIAL INTERPRETER:

13 somebody else you said? 14 MR. HARBACH: Yes. Bruno Wu.

No. 16 MS. CLAIBORN:

17 break. We're going to be back here at 2:45.

19 MS. CLAIBORN: All right.

20 the record after a short break. 21 Mr. Harbach, the floor is yours. 22 MR. HARBACH: Thank you. 23 BY MR. HARBACH:

Ms. Kwok, among the documents in front of 25 you, document 78 filed in this case. Case 22-50073 Doc 913-5 Filed 10/04/22 Entered 10/04/22 11:50:18 Page 102 of

1 THE OFFICIAL INTERPRETER: Which document? 2 This one? 3 MR. HARBACH:

4 advises me that your copies are not stamped.

I'm talking about your official from 106. 6 So my question for you starts on page 9, which 7 contains a heading that says Schedule D, creditors

by the property. 9 Are you with me? 10 You checked the box yes.

11 directed to Schedule D, so that's where I would like 12 you to flip to, please. And it's at page 18. 13 MR. BALDIGA: What's the title?

14 maybe find it better with the title. 15 MR. HARBACH:

16 that is Schedule D, which is a list of creditors 17 with secured claims. 18 BY MR. HARBACH:

20 separate entries for Golden Spring New York Limited. 21 The data in each column is identical for all five 22 rows.

24 identical entries on this schedule?

1 identical entries on this schedule?

Well, each row is exactly the same.

4 I'm just asking why there are five rows with the 5 same information?

I don't know.

8 some specific notes and one of those notes discusses 9 the residence on Taconic Road. 10 MR. HARBACH:

11 document 77, page 4. 12 THE OFFICIAL INTERPRETER: Which page? 13 MR. HARBACH: Page 4. 14 THE OFFICIAL INTERPRETER: 84? 15 MR. HARBACH: No, Page 4. 16 THE OFFICIAL INTERPRETER: Oh, page 4. 17 Okay. 18 BY MR. HARBACH:

My question really isn't so much about the 20 exact test as it is the substance. 21 So first question, is it true that all expenses 22 related to the Taconic Road House are paid directly 23 by family and family controlled enterprises?

Yes.

Okay. Which family members?

1 A My wife, sometimes by my son. 2 Q Which family controlled enterprises? 3 A Which country -- my wife. 4 Q Your wife's not an enterprise.

5 to ask which family controlled enterprises pay the 6 expenses for the Taconic House? 7 A Greenwich LLC. 8 Q Okay.

9 your wife and sometimes you son pay these expenses? 10 A Because I live there. 11 Q Do you observe them pay the expenses? 12 A Yes. 13 Q Is that ever at your request? 14 A I don't remember I request anything. 15 Q Does Greenwich Land LLC -- yes Greenwich 16 Land LLC own any other real estate besides 373 17 Taconic Road? 18 A I don't know. 19 Q Do you know anything about the property 20 located at 33 Ferncliff in Cos Cob, Connecticut? 21 THE OFFICIAL INTERPRETER:

22 that? 23 MR. HARBACH: Yes. 24 Q 33 Ferncliff in Cos Cob, Connecticut. 25 THE OFFICIAL INTERPRETER: 31, right?

1 MR. HARBACH: No, 33. 2 A Yes, now I remember it. It's also owned by 3 my wife's company. 4 Q That being Greenwich Land? 5 A Maybe. 6 Q Do you know? 7 A I'm not sure. 8 Q Have you ever been to 33 Ferncliff? 9 A Yes. 10 Q How recently? 11 A No. Not recently. 12 Q Do you know when Greenwich Land purchased 13 33 Ferncliff? 14 A I don't remember. 15 Q Do you know approximately how much money 16 it cost? 17 A Probably more that \$1 million. 18 Q Does \$1.37 million sound about right? 19 A I'm not sure. 20 Q And does the approximate purchase date of 21 September, 2019 sound about right to you? 22 A Not sure. 23 Q Turning back to 373 Taconic for a moment. 24 How much was that property purchased for? 25 A Probably 400 to 500,000.

1 THE PRIVATE INTERPRETER: No, no, no. 2 THE OFFICIAL INTERPRETER: 4 to 5 million. 3 I'm sorry. 4 Q Approximate time of purchase of 373 5 Taconic, if you know? 6 A I don't know. 7 Q Have you ever resided at 33 Ferncliff? 8 A No. 9 Q Do you know whether anyone currently lives 10 there? 11 A Before there is another comrade maybe, you 12 know, for disjoined Chinese Communist Party and he 13 was to live there. 14 Q How long ago? 15 A Probably one to two years ago. 16 Q DO you remember that person's name? 17 A Yes. 18 Q What is it? 19 A Wong Din Gong (ph). 20 Q Does anyone currently live there, if you 21 know? 22 A I don't know. 23 Q Talking about 373 Taconic, where did the 24 money come from to purchase that property? 25 A I don't know.

2 purchased with cash or financing? 3 A I don't know. 4 Q Same questions for 33 Ferncliff.

5 know where the money came from to purchase that 6 house? 7 A I heard it was purchased by cash. 8 Q From whom -- sorry. From whom did you hear 9 that? 10 A I don't remember. 11 Q Do you know where that money came from? 12 A I don't know. 13 Q Do you know what Saraca Media Group is? 14 A Saraca? 15 Q Saraca. 16 A Saraca Media Group. I do. 17 Q What is Sirraca Media Group? 18 A Just Saraca. It's a company. 19 Q What kind of company? 20 A I'm not sure. 21 Q Have you ever had any relationship with 22 Saraca personally? 23 A No. 24 Q Do you know anything about the type of 25 business that Saraca conducts?

1 A I remember they are related to GTV Media 2 platform, or they invested on the GTV Media 3 platform. 4 Q How do you know that? 5 A Because I was their consultant, who owned 6 the consultant. And also I was the GTV host.

7 also this is one of the input and platform for 8 disjoined communist party. 9 Q When you said you were a consultant a 10 moment ago was that for Saraca or for GTV? 11 A GTV. 12 Q Has Saraca ever been -- ever had the 162 13 East 64th Street address associated with it? 14 THE OFFICIAL INTERPRETER: Which address? 15 Can you repeat that one. 16 Q Yes. 162 East 64th Street.

17 is whether Saraca has ever been associated with that 18 address? 19 A I don't know. 20 Q That is the family office address, 21 correct? 22 A It's one of them. 23 Q Where are the other ones? 24 A I don't know. 25 Q Are there any others in New York City?

1 A I just want to clarify.

2 one of the companies in this building, 162. 3 Q Understood and thank you. 4 We've referred to the family office during 5 your questioning and I just want to be clear.

6 we talk about the family office are we referring to 7 that address on East 64th Street? 8 A Yes. 9 Q Has GTV ever been associated with the 10 family office address? 11 A I don't know. 12 Q Who owns Saraca? 13 A My son. 14 Q Since when? 15 A I don't know. 16 Q Does Saraca currently exist? 17 A I don't know. 18 Q Do you have any idea how many -- do you 19 know anything about the value of Saraca's assets? 20 A I don't know. 21 Q Do you know anything about payments Saraca 22 has made to GTV? 23 A No, I don't know. 24 Q Has your wife ever told you about any 25 multi-million dollar payments from Saraca to

1 Greenwich Land? 2 A I don't know. 3 Q You don't know whether he's ever told you 4 or you don't know about the payments? 5 A She never told me and I don't even know 6 how much. 7 Q Do you know a company called Ziba Limited, 8 Z-I-B-A? 9 THE OFFICIAL INTERPRETER: Ziba, Z-I-B-A? 10 MR. HARBACH: Yes. 11 A I don't know. 12 Q I'm sorry if I've already asked this. 13 What is the relationship, if any, between Saraca and 14 GTV? 15 A Saraca is the investor for GTV. 16 Q Do you know how much money Saraca invested 17 in GTV? 18 A I don't know. 19 Q When was GTV founded? 20 A 2020. Maybe 2019. Not very sure. 21 Q Do you know the names of any of the 22 officers or directors of Saraca? 23 A I don't know. 24 Q Do you know whether Yvette Wang is an 25 officer or director of Saraca?

1 A I don't know. 2 Q Do you know someone called Hong Chung 3 Wang? 4 A Yes. 5 Q Who is that? 6 A He's my partner and also comrade for 7 disjoined Communist Party. 8 Q Is he a friend of yours? 9 A Friend, comrade and a partner. 10 Q What do you mean by partner? 11 A Because we had a business corporation. 12 Q Tell me about that. 13 A Well, I don't remember the name of that 14 company. It's a company for investigating Communist 15 Party in USA doing money laundering and committing 16 crimes. 17 Q Was it a for profit company? 18 A I don't know. 19 Q You don't know? 20 A I don't know. 21 Q What was the name of the company? 22 A I don't remember when getting to English. 23 I don't remember the name. 24 Q Approximately what time frame where you 25 partners with Hong Chung Wang in this company?

1 A I don't remember. 2 Q Within the last three years? 3 A It must be more than three years ago. 4 Q More than ten years? 5 A No.

7 connection to Saraca? 8 A I don't know. 9 Q Was he ever an officer or director of 10 Saraca? 11 A I don't know. 12 Q What does the G in GTV stand for? 13 A God. The Goal, like in -- G-O-A-L. 14 Q The English word "goal"? 15 A Yea. Goal or God. 16 Q Okay.

17 Wang? 18 A I don't remember. 19 Q More than ten years? 20 A Roughly. 21 Q And do you still consider him a friend 22 today? 23 A Yes. 24 MR. HARBACH: Just a moment, please. 25 Q There's been many questions today about

1 Golden Spring funding your living expenses. 2 Is it correct that as far as your living 3 expenses are concerned that none of that is expected 4 to be repaid? 5 A Yes, true. 6 Q And so those monies are not the subject of 7 any formal agreement, correct? 8 A No. 9 Q And those monies essentially then are a 10 gift to you, correct? 11 A Yes. 12 Q What's the Rule of Law Foundation? 13 A What does that mean? 14 Q The question is what is it? 15 THE OFFICIAL INTERPRETER:

16 Foundation? 17 MR. HARBACH: Yes, sir. 18 THE OFFICIAL INTERPRETER:

19 it. Can you ask it another way?

21 THE OFFICIAL INTERPRETER: Oh. 22 Q -- the Rule of Law Foundation. 23 THE OFFICIAL INTERPRETER: Okay. 24 MR. HARBACH:

25 time by just asking this question instead.

1 Q Are you familiar with the Rule of Law 2 Foundation? 3 A Yes. 4 Q Were you involved in its establishment? 5 A Yes. 6 Q Did you contribute any money to it when it 7 was formed? 8 A Not myself. 9 Q Did you direct any entity to contribute to 10 the Rule of Law Foundation? 11 A Suggestion in a direct and suggesting any

13 Q If there was a suggestion, please tell me 14 it was a suggestion. 15 A I didn't direct anybody or order anybody. 16 I just always suggest people to make donations for 17 the Foundation. 18 THE PRIVATE INTERPRETER:

19 interpreter, I think that if the witness is asking 20 the interpreter questions, the interpreter should 21 interpret the question asked by the witness instead 22 of answer that question. 23 THE OFFICIAL INTERPRETER:

24 anything. 25 THE PRIVATE INTERPRETER:

Case 22-50073 Doc 913-5 Filed 10/04/22 Entered 10/04/22 11:50:18 Page 115 of

1 are you talking about the (indiscernible)

2 THE OFFICIAL INTERPRETER:

3 relayed the questions to the attorney. 4 THE PRIVATE INTERPRETER:

5 yes, and then you say that. 6 THE OFFICIAL INTERPRETER:

7 sake. I didn't say -- did I miss anything?

9 THE OFFICIAL INTERPRETER: Okay.

10 question. He said no question was not answered. 11 BY MR. HARBACH:

13 family members that they donate to the Rule of Law 14 Foundation?

Yes, I did suggest.

17 family controlled enterprises contribute money to 18 the Rule of Law Foundation?

Yes.

How much money?

For cash there is one -- over \$1 million. 22 From Hong Kong, Japan and Mainland -- in 23 China and all combined it should be more than 30 24 million.

1 contributions from your family at your suggestion. 2 Approximately, how much money is that? 3 A I don't know the details.

4 security reasons they don't want me to know. 5 Q Did you say a moment ago that your family 6 contributed over a million dollars? 7 A One million cash is in New York here. 8 Q When was that? 9 A I don't remember. 10 Q Is the reason -- well, let me ask it this 11 way. Did you suggest an amount to your family 12 members that they should contribute to the Rule of 13 Law Foundation? 14 A I want them to donate the more the better. 15 Q Is that what you told them? 16 A Yes. 17 Q Do you know whether the Rule of Law 18 Foundation is associated with the family office

address on 64th Street?

A Yes.

Q Did you ever make a \$100 million donation to the Rule of Law Foundation in November of 2018? THE OFFICIAL INTERPRETER: Can you repeat that again?

Q Did you ever make a \$100 million donation

1 to the Rule of Law Foundation in November, 2018?

3 tried to collect the funds, in the live stream show.

5 MR. BALDIGA: Wait.

6 answer? 7 THE OFFICIAL INTERPRETER:

8 wrong? 9 THE PRIVATE INTERPRETER:

10 exactly what the witness said.

broadcasting is okay. 12 Live stream is okay.

13 THE OFFICIAL INTERPRETER:

14 donation, right?

16 THE PRIVATE INTERPRETER:

17 THE WITNESS:

18 donations.

19 thing, or whatever, you know, asking for donations 20 to -- you know, to raise funds, to raise money.

Did you ever promise to donate \$1 billion 22 to the Rule of Law Fund? 23 THE OFFICIAL INTERPRETER:

24 said? 25 MR. HARBACH: No, sir. 1 billion.

1 THE OFFICIAL INTERPRETER:

2 billion. 3 A I don't remember. I don't remember. 4 Q Do you mean that it's possible that you 5 made that promise? 6 A So we could reach that goal if we combine 7 the organizations all over the world. 8 Q Understand.

9 just don't know the answer. 10 Did you yourself ever promise to donate \$1 11 billion to the Rule of Law fund? 12 A In the past five years I did the live 13 stream over 5,000 times.

14 could have reached four or five hours.

15 for me to remember every sentence I said. 16 Q Well, I understand that, but I'm only 17 asking about one issue.

18 promised publicly, or privately or anyhow to donate 19 \$1 billion to the Rule of Law Fund? 20 THE PRIVATE INTERPRETER:

21 invest. 22 MR. HARBACH:

23 THE OFFICIAL INTERPRETER: Yeah, donate. 24 A I don't remember. 25 Q I'll ask this one one more time. Case 22-50073 Doc 913-5 Filed 10/04/22 Entered 10/04/22 11:50:18 Page 119 of

1 Are you saying that it is possible that

2 you made such a promise. You just can't be sure?

4 anything is possible but this is a very serious 5 issue. Now they start the scheme again.

7 breakfast three days ago.

8 to donate \$1 billion and if the answer is you don't 9 know, that's okay. 10 MR. BALDIGA:

11 answer has been. 12 MR. HARBACH:

13 don't remember. 14 MR. BALDIGA: Don't remember. 15 MR. HARBACH:

16 different.

So the answer might be no, but you're not 18 saying no. You're saying you don't remember.

I said it three times, I don't remember. 20 MR. BALDIGA:

23 for me so that's why the judge from the South 24 District were fooled by you and you started again --

I'll move on. Case 22-50073 Doc 913-5 Filed 10/04/22 Entered 10/04/22 11:50:18 Page 120 of

Ho Wan Kwok - April 6, 2022 A In the South District court I only met judge 20 seconds. I didn't say one sentence within this five years and I was fined a total about \$300 million because that's what they did. MR. BALDIGA: All right. Let's stop it. Let's wait for a question and we'll answer the question. MR. HARBACH: Bill, I appreciate your patience. I'll move on. MR. BALDIGA: Translate what I said, please. THE OFFICIAL INTERPRETER: Can you repeat that? Everybody's saying at the time. MR. BALDIGA: Ask a question and he'll answer a question. Q Have you made any donations to the Rule of Law Foundation in the last two years? A Myself, right? Q Yes, sir. A No. Q Have you suggested to any of your family that they make donations to the Rule of Law Foundation within the last two years? A I don't remember. Q Would you ever have made a promise to Case 22-50073 Doc 913-5 Filed 10/04/22 Entered 10/04/22 11:50:18 Page 121 of

1 donate \$1 billion to the Rule of Law Foundation if 2 you did not actually have that money? 3 MR. BALDIGA: Objection to form. 4 THE OFFICIAL INTERPRETER:

5 it. Can you repeat one more time.

7 donate \$1 billion to the Rule of Law Foundation if 8 you did not actually have that money. 9 MR. BALDIGA: And I objected. 10 MR. HARBACH: And then Bill objected. 11 THE OFFICIAL INTERPRETER:

12 -- want to sentencing me to death sentence?

14 worth?

I don't know.

17 the Lady May, approximately how many times have you 18 invited friends to join you? 19 THE OFFICIAL INTERPRETER:

20 that question one more time? 21 MR. HARBACH: Yes.

23 the Lady May, approximately how many times have you 24 invited friends out to join you? 25 MR. BALDIGA: Hold on.

1 MR. HARBACH: Sorry, Bill. 2 MR. BALDIGA:

3 on the Lady May issues coming up.

4 today or then. Either one is fine. 5 MR. HARBACH: That's a fair point.

6 move on. 7 MR. BALDIGA: Okay. No question. 8 MR. HARBACH:

9 attention again to document 77.

10 on question 19.

12 that question. It's no. 19.

Finished.

Okay.

16 the question says within ten years before you filed 17 for bankruptcy did you transfer any property to a 18 self settled trust or similar device of which you 19 are a beneficiary?

No.

And that is indeed what you checked on the 22 form.

23 changed the word you to a family member as the 24 beneficiary, what would the answer be? 25 MR. BALDIGA: Objection.

I cannot answer questions with if.

I'll ask it a different way. 3 MR. HARBACH:

4 bear with me.

6 bankruptcy did you transfer any property to a self 7 settled trust or similar device of which a member of 8 your family is a beneficiary?

No.

11 forward to question 27.

12 you're read it, sir.

Okay. I'm finished.

So you see there you have checked the box 16 next to the word yes.

17 check all that apply above and fill in the details 18 below for each business. 19 MR. HARBACH:

20 Jack? 21 THE OFFICIAL INTERPRETER:

22 that. 23 MR. HARBACH: Next -- Holley can show you.

25 MR. HARBACH:

1 to the witness -- for the benefit of the translator 2 I'll say it again. 3 Q Next to the box that is checked yes, the 4 instructions say check all that apply above and fill 5 in the details below for each business.

6 boxes above is checked and that's my question. 7 Which box or boxes should be checked for 8 each of those three entities that you have listed? 9 A I cannot determine which one. 10 Q Is that something you would need more time 11 to figure out or you just don't know the answer? 12 A I could answer one by one. 13 Q Okay. Let's do that.

14 Genever. 15 A Which Genever? 16 Q Well, the one that's listed is Genever 17 Holdings Corporation. 18 Which of those boxes would you check for 19 Genever Holdings Corporation, if any? 20 A It was one time -- it was a member of LLC. 21 The above don't apply and should transfer to no. 12 22 -- transfer to 12. 23 It used to be an LLC. 24 Q Are you saying that you would check the 25 box for a member of an LLC but it should be in the

1 past tense? 2 A Yes. Used to be. 3 Q Do any of the other boxes apply to your 4 relationship to Genever Holdings Corporation? 5 A The last row seems like appropriate for 6 me. I'm not very sure. 7 Q The last row being an owner of at least 8 five percent of the voting or equity securities of a 9 corporation? 10 A I owned 50 percent for a very short period 11 of time. 12 Q Okay. What about for Shiny Time? 13 A Shiny Time already went away. 14 Q I understand.

15 which of those boxes was accurate? 16 A Number one. 17 Q A sole proprietor? 18 A Yes. 19 Q Any of the others? 20 A Not sure. 21 Q Okay. What about for Well Origin Limited? 22 A It went away. 23 Q Okay. Same question though.

24 those boxes applied when it was in existence? 25 A Number one.

1 Q Any of the others? 2 A Not sure. 3 Q One last point about this question. 4 For Genever Holdings Corporation the block 5 for the dates that the business existed is blank. 6 Do you know what those dates should be? 7 A 2015.

8 July. 9 Q Of which year? 10 A 2015. 11 Q So from approximately March or April until 12 approximately July all in 2015? 13 A Yes. 14 Q Okay.

15 that that corporation existed? 16 A I was in the company for a few months, for 17 this period of time, a few months and with holding - 18 - in stock holding.

19 after I left. 20 Q I understand.

21 today? 22 A I believe it still exists. 23 Q Okay. In what year did you get married? 24 A 1918 -- or 1985. 25 Q What year was your son born?

1 A 1986. 2 Q And how old are you, sir? 3 A 54. 4 Q How old was your son when your family 5 began working with Uda Property Company? 6 A 11. Oh, five years -- five years old.

8 approximately 1991 that your family began working 9 with Uda? 10 A Yes. 11 Q When was the Henan Uda Hotel completed? 12 A In 1997. 13 Q And what about the Uda International Trade 14 Center. When was it completed? 15 A At pretty much the same time. 16 Q In your declaration in this case you 17 stated that both of those were successful ventures. 18 A Yes. 19 Q That allowed your family to start amassing 20 significant wealth. 21 A Yes. 22 Q So recognizing that this is in the early 23 '90's how much money approximately did those 24 ventures bring to your family? 25 A I don't remember.

1 Q More than \$50 million? 2 THE OFFICIAL INTERPRETER: 50 or 15? 3 MR. HARBACH: 5-0. 4 THE OFFICIAL INTERPRETER: Oh, okay. 5 A I don't remember. 6 Q What about the Pengu Plaza?

7 completed? 8 A July 2008. 9 Q So between the early '90's and 2008 what 10 other projects of significant did the Guo family 11 invest in or participate in? 12 THE OFFICIAL INTERPRETER:

14 A Between the early 1990's and 2008. 15 Q Do you remember any of them?

16 significant ventures? 17 A Beijing Golden Spring. 18 Q What was that? 19 A It's a property company. Real estate. 20 It's a real estate company. 21 Q Was this a development company or a -- 22 like a buying and selling agency? 23 A Developing company. 24 Q When was the Pangu Plaza project started, 25 approximately?

1 A Roughly 1999. 2 Q Okay. So let's use that as a point in 3 time.

5 project approximately how much had the family 6 amassed in wealth? 7 THE PRIVATE INTERPRETER:

8 question again? 9 MR. HARBACH: Sure. 10 Q As of 1999, which was the beginning of the 11 Pangu Plaza project, approximately how much wealth 12 had the family earned or amassed by that time? 13 THE OFFICIAL INTERPRETER:

14 about after 1999? 15 MR. HARBACH:

16 1999? 17 THE OFFICIAL INTERPRETER: Oh, as of 1999. 18 Q How much money had the family made by 19 1999? 20 A I don't remember. 21 Q More than \$100 million? 22 A I don't remember. 23 Q More than \$500 million? 24 A I don't remember. 25 Q More than a billion dollars?

1 A I don't remember. 2 Q Were you personally involved in the work 3 with Uda Property Company? 4 A Yes. 5 Q Were you personally involved in the 6 development of the Henan Uda Hotel? 7 A Yes. 8 Q Were you personally involved in the Uda 9 International Trade Center in Zhengzhou? 10 A Yes. 11 Q Were you personally involved in the 12 development of the Pengu Plaza? 13 A Yes. 14 Q Who was in charge of the Beijing Golden 15 Spring Real Estate Development firm? 16 A A professional group. 17 Q Were you a member of that group? 18 A At that time I was a consultant. 19 Q For Beijing Golden Spring? 20 A Yes.

22 approximately that you were a consultant for them? 23 A After 2000. 24 Q After 2000. Okay. 25 MS. CLAIBORN:

1 note that it is 4:18 and I know we've had a long day 2 -- and I wanted to give -- I apologize for 3 interrupting you, first of all. 4 MR. HARBACH: That's all right. 5 MS. CLAIBORN:

6 counsel for the committee a chance to ask a few 7 questions today before we conclude. 8 MR. HARBACH: Of course. Sure. 9 MR. STAFSTROM: I'll be very brief. 10 EXAMINATION BY MR. STAFSTROM: 11 Q I noticed your hair is very short. I like 12 it. Have you gotten a haircut recently? 13 A Yes. I had a haircut. 14 Q Where did you get it cut? 15 A My wife. 16 Q Oh, your wife. Okay. 17 Does she always cut your hair? 18 A After the virus until now. 19 Q Okay.

20 questions then. 21 MS. CLAIBORN:

22 recording on pause while we work on selecting a new 23 date.

25 MS. CLAIBORN:

134 Entered 10/04/22 11:50:18 Page 132 of

1 after a short break. We have selected a continuance 2 date of April 29th, beginning at 10:00 a.m. We are 3 concluded for today. Thank you.

Ho Wan Kwok - April 6, 2022 I, CHRISTINE FIORE, court-approved transcriber and certified electronic reporter and transcriber, certify that the foregoing is a correct transcript from the official electronic sound recording of the proceedings in the above-entitled matter. 9 April 15, 2022 10 Christine Fiore, CERT 11 Transcriber Case 22-50073 Doc 913-5 Filed 10/04/22 Entered 10/04/22 11:50:18 Page 133 of