---
type: court_doc
id: "court_sdny_229_4"
court: "SDNY"
case_no: "23-cr-00118"
doc_number: 229
doc_type: "LETTER"
filed_date: "2024-01-09"
lang: "en"
machine_translated: false
url: "https://mubeitech.com/en/court/court_sdny_229_4"
json_url: "https://mubeitech.com/api/court/court_sdny_229_4"
---
# Guo Wengui / Miles Guo — criminal case · Letter · ECF #229-4

**Letter with client declarations — United States v. Ho Wan Kwok (Guo Wengui / Miles Guo), SDNY 1:23-cr-00118, ECF #229 (filed 2024-01-09). Submitted to Judge Torres by attorney Bradford Geyer on behalf of multiple Himalaya Exchange account holders, each declarant states they hold an active account with crypto stablecoin holdings, have not been defrauded by or unduly influenced by the charged defendants, and requests that their funds be unencumbered and returned.**


Re: United States v. Kwok, et al., Case No. 1:23-cr-118 (AT)

Dear Judge Torres:

IMXIVUL . hereby declare:

- My name is IMXIVUL and I have an active account with the Himalaya Exchange.
- 2. I hereby confirm that I have signed up to be represented by Bradford Geyer to represent me for the recovery of my funds from my Himalaya exchange account.
- 3. I confirm my account is currently active and it contains crypto stable coin holdings and an associated reserve.
- 4. To the best of my knowledge and belief, I have not been defrauded by the charged defendants in the above captioned case.
- 5. I have not been unduly influenced by the Exchange or any of the charged defendants.
- 6. I have made this decision on my own free will and I respectfully request that my funds be immediately unencumbered so that they can be returned.

Dated: January 9, 2024
RESPECTFULLY SUBMITTED

Name

Js/Brad Gever BY:

Bradford L. Geyer Attorney for Defendant Pennsylvania Bar ID #: 62998 NJ Bar ID # 022751991 2006 Berwick Drive Cinnaminson, NJ 08077 Email: Bradford@formerfedsgroup.com P: (856)-607-5708

Re: United States v. Kwok, et al., Case No. 1:23-cr-118 (AT)

Dear Judge Torres:

I Xivchan lu, hereby declare:

- 1. My name is Xiushan Ly and I have an active account with the Himalaya Exchange.
- 2. I hereby confirm that I have signed up to be represented by Bradford Geyer to represent me for the recovery of my funds from my Himalaya exchange account.
- 3. I confirm my account is currently active and it contains crypto stable coin holdings and an associated reserve.
- 4. To the best of my knowledge and belief, I have not been defrauded by the charged defendants in the above captioned case.
- 5. I have not been unduly influenced by the Exchange or any of the charged defendants.
- 6. I have made this decision on my own free will and I respectfully request that my funds be immediately unencumbered so that they can be returned.

Dated: January 9, 2024

RESPECTFULLY SUBMITTED
Xiushun Lu

Name

BY: /s/Brad Geyer Bradford L. Geyer

Attorney for
Defendant
Pennsylvania Bar ID #: 62998
NJ Bar ID # 022751991
2006 Berwick Drive
Cinnaminson, NJ 08077
Email:
Bradford@formerfedsgroup.com
P: (856)-607-5708

Re: United States v. Kwok, et al., Case No. 1:23-cr-118 (AT)

Dear Judge Torres:

16 card Axerereby declare:

- 1. My name is Google and I have an active account with the Himalaya Exchange.
- 2. I hereby confirm that I have signed up to be represented by Bradford Geyer to represent me for the recovery of my funds from my Himalaya exchange account.
- 3. I confirm my account is currently active and it contains crypto stable coin holdings and an associated reserve.
- 4. To the best of my knowledge and belief, I have not been defrauded by the charged defendants in the above captioned case.
- 5. I have not been unduly influenced by the Exchange or any of the charged defendants.
- 6. I have made this decision on my own free will and I respectfully request that my funds be immediately unencumbered so that they can be returned.

Dated: January 9, 2024

RESPECTFULLY SUBMITTED

Labels　Values

Name　Gerhard Aken

BY: /s/Brad Gever Bradford L. Geyer

Attorney for
Defendant
Pennsylvania Bar ID #: 62998
NJ Bar ID # 022751991
2006 Berwick Drive
Cinnaminson, NJ 08077
Email:
Bradford@formerfedsgroup.com
P: (856)-607-5708
Re: United States v. Kwok, et al., Case No. 1:23-cr-118 (AT)

Dear Judge Torres:

SHENG YUAN, CHEN

hereby declare:
SHENG YUAN, CHEN

1. My name is and I have an active account with the Himalaya Exchange.

2. I hereby confirm that I have signed up to be represented by Bradford Geyer to represent me for the recovery of my

funds from my Himalaya exchange account.

- 3. I confirm my account is currently active and it contains crypto stable coin holdings and an associated reserve.
- 4. To the best of my knowledge and belief, I have not been defrauded by the charged defendants in the above captioned case.
- 5. I have not been unduly influenced by the Exchange or any of the charged defendants.
- 6. I have made this decision on my own free will and I respectfully request that my funds be immediately unencumbered so that they can be returned.

Dated: January 9, 2024

RESPECTFULLY SUBMITTED

Labels　Values　|---|---|　Name　Chen Sheng Yuan

/s/Brad Gever BY: Bradford L. Geyer

Attorney for Defendant Pennsylvania Bar ID #: 62998 NJ Bar ID # 022751991 2006 Berwick Drive Cinnaminson, NJ 08077 Email: Bradford.geyer@formerfedsgroup.com Phone: (856)-607-5708
Re: United States v. Kwok, et al., Case No. 1:23-cr-118 (AT)

Dear Judge Torres:

I \_\_\_\_\_\_\_\_\_\_\_\_\_, hereby declare: Lazzat

- 1. My name is \_\_\_\_\_\_\_\_\_\_\_\_\_ and I have an active account with the Himalaya Exchange. Lazzat
- 2. I hereby confirm that I have signed up to be represented by Bradford Geyer to represent me for the recovery of my funds from my Himalaya exchange account.
- 3. I confirm my account is currently active and it contains crypto stable coin holdings and an associated reserve.
- 4. To the best of my knowledge and belief, I have not been defrauded by the charged defendants in the above captioned case.
- 5. I have not been unduly influenced by the Exchange or any of the charged defendants.
- 6. I have made this decision on my own free will and I respectfully request that my funds be immediately unencumbered so that they can be returned.

Dated: January 9, 2024

Dated: January 9, 2024 RESPECTFULLY SUBMITTED

\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_

Name Lazzat

BY: \_\_/s/Brad Geyer Bradford L. Geyer

Attorney for Defendant Pennsylvania Bar ID #: 62998 NJ Bar ID # 022751991 2006 Berwick Drive Cinnaminson, NJ 08077 Email: Bradford.geyer@formerfedsgroup.com Phone: (856)-607-5708
Re: United States v. Kwok, et al., Case No. 1:23-cr-118 (AT)

Dear Judge Torres:

- I \_\_\_\_\_\_\_\_\_\_\_\_\_, hereby declare: Xiue Zhang
- 1. My name is \_\_\_\_\_\_\_\_\_\_\_\_\_ and I have an active account with the Himalaya Exchange. Xiue Zhang
- 2. I hereby confirm that I have signed up to be represented by Bradford Geyer to represent me for the recovery of my funds from my Himalaya exchange account.
- 3. I confirm my account is currently active and it contains crypto stable coin holdings and an associated reserve.
- 4. To the best of my knowledge and belief, I have not been defrauded by the charged defendants in the above captioned case.
- 5. I have not been unduly influenced by the Exchange or any of the charged defendants.
- 6. I have made this decision on my own free will and I respectfully request that my funds be immediately unencumbered so that they can be returned.

Dated: January 9, 2024

Dated: January 9, 2024 RESPECTFULLY SUBMITTED

\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_

Name

BY: \_\_/s/Brad Geyer Bradford L. Geyer

Attorney for Defendant Pennsylvania Bar ID #: 62998 NJ Bar ID # 022751991 2006 Berwick Drive Cinnaminson, NJ 08077 Email: Bradford.geyer@formerfedsgroup.com Phone: (856)-607-5708
Re: United States v. Kwok, et al., Case No. 1:23-cr-118 (AT)

Dear Judge Torres:

I \_\_\_\_\_\_\_\_\_\_\_\_\_, hereby declare:

- 1. My name is \_\_\_\_\_\_\_\_\_\_\_\_\_ and I have an active account with the Himalaya Exchange.
- 2. I hereby confirm that I have signed up to be represented by Bradford Geyer to represent me for the recovery of my funds from my Himalaya exchange account.
- 3. I confirm my account is currently active and it contains crypto stable coin holdings and an associated reserve.
- 4. To the best of my knowledge and belief, I have not been defrauded by the charged defendants in the above captioned case.
- 5. I have not been unduly influenced by the Exchange or any of the charged defendants.
- 6. I have made this decision on my own free will and I respectfully request that my funds be immediately unencumbered so that they can be returned.

Dated: January 9, 2024
Dated: January 9, 2024 RESPECTFULLY SUBMITTED

\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_

Name

BY: \_\_/s/Brad Geyer Bradford L. Geyer

Attorney for Defendant Pennsylvania Bar ID #: 62998 NJ Bar ID # 022751991 2006 Berwick Drive Cinnaminson, NJ 08077 Email: Bradford.geyer@formerfedsgroup.com Phone: (856)-607-5708

Re: United States v. Kwok, et al., Case No. 1:23-cr-118 (AT)

Dear Judge Torres:

- I LEPTSEM , hereby declare:
- 1. My name is LSPTSEM and I have an active account with the Himalaya Exchange.
- 2. I hereby confirm that I have signed up to be represented by Bradford Geyer to represent me for the recovery of my funds from my Himalaya exchange account.
- 3. I confirm my account is currently active and it contains crypto stable coin holdings and an associated reserve.
- 4. To the best of my knowledge and belief, I have not been defrauded by the charged defendants in the above captioned case.
- 5. I have not been unduly influenced by the Exchange or any of the charged defendants.
- 6. I have made this decision on my own free will and I respectfully request that my funds be immediately unencumbered so that they can be returned.

Dated: January 9, 2024

RESPECTFULLY SUBMITTED

Labels　Values

Name　Do chongy

BY: /s/Brad Gever
Bradford L. Geyer

Attorney for Defendant Pennsylvania Bar ID #: 62998 NJ Bar ID # 022751991 2006 Berwick Drive Cinnaminson, NJ 08077 Email: Bradford.geyer@formerfedsgroup.com Phone: (856)-607-5708