Guo Wengui / Miles Guo — criminal case · EXHIBIT · ECF #312-1

IN RE:

7 Debtor. 8 ------------------------------------------------------------------------------------------------------------------------------------------------------------------------------

a.m.

20 This transcript portions contains information subject 21 to a Protective Order and shall be used only in 22 accordance therewith.

24 Reported By:

୍ୟ UNITED STATES BANKRUPTCY COURT 2 APPEARANCES :

125 COUNSEL FOR DEBTOR AND THE WITNESS: ZEISLER & ZEISLER, P.C. ਤੇ BRIDGEPORT DIVISION BY: ERIC HEMZY, ESQ. ച്ച് ****************************************************************************************************************************************************************************** ് 10 Middle Street

HO WAN KWOK, Case No. 22-50073 (JAB) ഒ COUNSEL FOR CHAPTER 11 TRUSTEE :

Debtor. AVRAM LUFT, ESQ. BY: 7 1 (1 BY: NICHOLAS BASSETT, ESQ. ****************************************************************************************************************************************************************************** 1 i LUC DESPINS, ESQ. BY: BY: NEWLONG ZHUGE, ESQ.

offices of Brown Rudnick, LLP, located at Seven Times held at the 1 में COUNSEL FOR PACIFIC ALLIANCE: 12 13 Square, New York, New York, before Cheryll Kerr, CSR, a 15 14 Certified Shorthand Reporter and a Notary Public, on ОТЕГЛЕМУ & МЛЕКС. ГГР 15 Friday, November 11, 2022, at 9:23 a.m. 1 6 BY: STUART SARNOFF, ESQ.

1 ਕੇ Also Present :

21 22 Jingyi Wang, Chinese interpreter;

3 EXAMINATION BY PAGE 4 REQUESTS FOR INFORMATION ਪ੍ਰੋ Direct examination by Mr. Luft ି ്വ DESCRIPTION PAGE ് Cross-examination by Mr. Henzy 138 టి Production of audio and email Ms. Francis sent 55 ్ Redirect examination by Mr. Luft 140 ్ witness with the electronic transcript

10 Exhibit 1 Debtor's Objection to Motion 21 1 İ with regard to her opinions as well 1.1. of Chapter 11 Trustee for Entry 12 1.2 of Order Holding Debtor in Civil Production of emails witness described between 137

1.3 Contempt for Failure to Comply herself and Ms. Francis and any other counsel 1. 4 with Corporate Governance Rights 1 4

1. ប Exhibit 2 Transcript of Telephonic 341 104 15

19 Exhibit 3 Transcript of Continued 104 ી. કે

Page 6 Page 7 l - Highly Confidential 1 Highly Confidential 2 THE VIDEOGRAPHER: Good morning. This is 2 trustee. 3 3 the start of media labeled No. 1 of the video MR. HENZY: Eric Henzy, Zeisler & 4 recorded deposition of 4 Zeisler. I'm at this deposition on behalf of 5 5 matter In Re: Ho Wan Kwok. 5 5 This deposition is being held at Brown THE VIDEOGRAPHER: Will the court 7 7 Rudnick, LLP, Seven Times Square, Floor 47, reporter please swear in the witness? 8 ్రా New York, New York, on November 11, 2022 at MR. HENZY: Can first may I make a 9 ్ర approximately 9:23 a.m. statement on the record? 10 10 My name is Edwin Arlequin. I am the Pursuant to paragraph 15 of the legal video specialist from TSG Reporting, 11 11 protective order entered in this case, I am 12 Inc., headquartered at 228 East 45th Street, 12 designating this deposition transcript and all 13 13 Suite 810, New York, New York 10017. exhibits as designated material and, given the 14 14 The court reporter is Cheryll Kerr, in timeline, as highly confidential. 15 association with TSG Reporting. Counsel, 15 MR. LUFT: Sorry, We do not concede that 15 please introduce yourselves. ો ર this material will be highly confidential or 17 17 MR. LUFT: Avi Luft, of Paul Hastings, on properly designated. 18 18 behalf of the Chapter 11 trustee in In Re: Ho After the deposition, an assessment can 19 Wan Kwok. 19 be made based on what is actually testified 20 20 MR. BASSETT: Nick Bassett, from Paul to. 21 Hastings, also on behalf of the Chapter 11 21 22 22 trustee. 23 MR. ZHUGE: Wenlong Zhuge, Paul Hastings, 23 called as a witness, having been duly 24 24 also on behalf of the Chapter 11 trustee. sworn, was examined and testified 25 25 MR. DESPINS: Luc Despins, Chapter 11 as follows: Page 8 Page 9 1 1 - Highly Confidential - Highly Confidential 2 2 THE SHORTHAND REPORTER: Thank you. ್ಲ. I am going to ask you a question. 3 3 Please proceed, Counsel. A. Uh-huh . 4 4 ੁੰ. If for any reason you don't understand the 5 5 DIRECT EXAMINATION question I've asked, please let me know if it's unclear. ్ర BY MR. LUFT: రు Is that okay? 7 7 A. Okay. B ි Good morning, I wow are you? If you don't tell me something's unclear, I 0. ். 9 Good morning. Fine, thank you. ్ర will assume that you understand my question. Is that ri 10 10 ். My name is Avi Luft. I am an attorney for okay? 11 the Chapter 11 trustee. Have you ever been deposed 11 A. Okay. 12 before? 12 Periodically, Mr. Henzy may decide he has an ੋ. 13 ri, No. 13 a objection to one of my questions. He may interpose an 14 Okay, so the first thing I'm going to । ਪੈ objection. ். 15 mention, just so you know, is you just shook your head, 15 That's fine. Okay? 16 ો ર and the court reporter needs all answers to be audible. Д. Okay. 17 17 માં Uh-huh . ു. Unless Mr. Henzy instructs you not to answer 18 ਂ. So even if I can see you, she may ask you or 18 my question, despite the fact he may have made an 19 15 I may ask you to repeat and answer if there's not an objection, you may proceed to answer my question. 20 20 audible answer. A. Yes . Is that okay? 21 21 ्. Is that okay? 22 22 A. ਕੇ, Okay. Okay. 23 23 So why don't we go over some limit flares ். Have you attended depositions before? ਂ. 24 about how a deposition works? 24 д. Yes. 25 25 A. Okay. ். So you have some familiarity, and I apologize

1 - Highly Confidential 1 Highly Confidential న if this is redundant. 2 to review. 3 It's fine. ri 3 THE SHORTHAND REPORTER: Okay. 4 Okay. If for some reason today you need to ் 4 MR. HENZY: Thank you. 5 take a break, I'd ask that you let me know, and if it's 5 MR. LUFT: Great. ్ a convenient time, we will do so. 5 BY MR. LUFT: 7 A. Okay. ﻟﺴﺎ Is there any reason you can't give truthful

8 If not, I'll try to get one to you as quickly ్రా testimony today?

as I can. 9 A. No.

10 Is that okay? Terrific. And you understand that you're ். 11 A. Okay . 11 under oath? 12 The one thing I ask is that if I have a ் 12 A. Yes . 13 question pending to you, that you answer the question 13 ்.

। ਹੈ before we take any break. ાં તે record?

Yes. 15 A.

Okay? 16 ू. And your address?

Okay . 17 A.

Great. 18 ू .

19 I will also do my best not to talk over you or at 19 today? 20 the same time you're talking, and I'll ask you to do the 20 A. res. 21 same, because it's very hard for the court reporter. Is 21 Who is that? ். 22 that okay? 22 A. Mr. Eric Henzy. 23 A.

24 ू . Okay . ਟ ਕੇ BY MR. LUFT: 25 MR. HENZY: The last thing is we do want 25 Okay. Do you know if Mr. Henzy represents

1 - Highly Confidential 1 - Highly Confidential 2 anyone else in this matter? 2 MR. LUFT: What is the privilege? 3 ਸ . I am not entirely sure. રે MR. HENZY: It -- how became -- came 4 Are you paying for Mr. Henzy's service today? ুট 4 to be represented by me was based on

్ర Who is paying for Mr. Henzy's service? ું. 5 MR. LUFT: But they are not legal advice, 7 I have no idea. ি . 7 right? B (Thereupon, an informal discussion was ു BY MR. LUFT: ੀ। held off the record with the shorthand 150 ்.

11 THE WITNESS: I said I really have no 11 MR. HENZY: A client's decision to be 12 idea. 12 represented or not represented involves legal 13 BY MR. LUFT: 13 advice. । पे How did Mr. Henzy come to represent you? ் । ਪੈ MR. LUFT: Okay.

I was -- 15 MR. HENZY: Okay. 16 MR. HENZY: I'm going to, actually, ો છ BY MR. LUFT: 17 object. That -- 17 When was the first time you spoke to

18 Objection, based on privilege, so you ાં કે Mr. Henzy? । ਕੇ don't need to answer the question. । ਤੇ MR. LUFT: I don't -- 20 THE WITNESS: Okay. 20 By the way, my "okay" was not agreement 21 MR. LUFT: I'm sorry. 21 with you. I'm just moving on. 22 22 MR. HENZY: Okay. 23 So you're instructing -- are you 23 BY MR. LUFT:

answer. 25 When did you first speak to Mr. Henzy? ्रं .

న THE WITNESS: I'm not exactly sure about 2 BY MR. INFT: 3 the date. 3 How did you first contact Mr. Henzy? By what

4 (Pause . ) 4 means? 5 THE WITNESS: You know, I actually cannot (JT A. I did not contact Mr. Henzy.

Okay. Did Mr. Henzy contact you? 7 BY MR. LUFT: 1 MR. HENZY: So objection on privilege. ్రం Q. What's your best recollection of when you ్రం MR. LUFT: It's a "yes" or "no" question. 9 first spoke to Mr. Henzy? 9 MR. HENZY: You can arque, Avi. 10 A. I cannot be sure whether it is within this 10 I get it, but I'll instruct the witness 11 week or last week. 11 not to answer.

: Ci 12 MR. LUFT: But I don't want to have a 13 representation initially? 13 deposition where I have -- it's an improper । ਹੈ MR. HENZY: Objection. 14 objection. 15 Same objection. Attorney-client 15 MR. HENZY: Okay. That's fine. 16 privilege. How came to be represented? 15 BY MR. LUFT: 17 THE WITNESS: No. 17 Did Mr. Henzy contact you? 18 18 ું. 19 MR. HENZY: You can -- you can -- you can 1 9 MR. HENZY: Okay. claim it with the judge. BY MR. LUFT: 20 And objection. I'm going to instruct you 20 not to answer. 21 Q. All I'm asking is: Did you call Mr. Henzy or 21 BY MR. LUFT: 22 did Mr. Henzy call you initially? 22 ்.

23 A. No -- ਨਤੇ Are you going to follow your counsel's instruction? 24 MR. HENZY: You can answer. ੇ ਪੈ I think I should. র্নাট্মান বিষয়ে বিশ্ববিদ্যালয়ের প্রায় প্রতিষ্ঠান কর্মকর্তার প্রতিষ্ঠান কর্মকর্তার প্রতিষ্ঠান করে বিশ্বের প্রায় প্রতিষ্ঠান করে পারে পারে পারে পারে পারে পারে পারে পারে পারে পা 25 THE WITNESS: No telephone calls. 25 MR. HENZY: Are -- are you going to ask

1 - Highly Confidential 1 Highly Confidential 2 not to follow her counsel's instruction? 2 Henzy's firm. 3 Are you going to give her advice? 3 BY MR. LUFT: دلو MR. LUFT: No, Eric. The way it works is 4 Who from Mr. Henzy's firm contacted you? ். 5 if you give an instruction, I have to ask 5 MR. HENZY: Objection. I -- same ్ర if going to follow it. ் objection. 7 MR. HENZY: And :- said -- and ﻟﻤﺴﺎﺣﺔ ﺍﻟﻤﺴﺘﻮﻯ ﺍﻟﻤﺴﺘﻮﻯ ﺍﻟﻤﺴﺘﻮﻯ ﺍﻟﻤﺴﺘﻮﻯ ﺍﻟﻤﺴﺘﻮﻯ ﺍﻟﻤﺴﺘﻮﻯ ﺍﻟﻤﺴﺘﻮﻯ ﺍﻟﻤﺴﺘﻮﻯ ﺍﻟﻤﺴﺘﻮﻯ ﺍﻟﻤﺴﺘﻮﻯ ﺍﻟﻤﺴﺘﻮﻯ ﺍﻟﻤﺴﺘﻮﻯ ﺍﻟﻤﺴﺘﻮﻯ ﺍﻟﻤﺴﺘﻮﻯ ﺍﻟﻤﺴﺘﻮﻯ ﺍﻟﻤﺴﺘﻮﻯ ﺍﻟﻤﺴﺘﻮﻯ ﺍﻟﻤﺴﺘﻮﻯ ﺍﻟﻤﺴﺘﻮﻯ ﺍﻟﻤﺴﺘﻮﻯ ﺍﻟﻤﺴﺘﻮ MR. LUFT: I'm just asking for a name. B answered -- 8 MR. HENZY: Understand. Understand. 9 (Thereupon, an informal discussion was 15 Objection, privilege. I'm going to 10 held off the record with the shorthand 10 instruct and not to answer. 11 reporter. ) 11 BY MR. LUFT: 12 MR. HENZY: Okay. 12 Are you going to follow your counsel's ું. 13 MR. LUFT: I didn't give any advice. 13 instruction? 1 पें Please don't mischaracterize what I said. । ਪੈ A. les. 15 MR. HENZY: Okay. 15 Was it someone from Mr. Henzy's firm who ું. 16 BY MR. LUFT: ો છ initially contacted you or someone else? 17 So I'll ask you again: ் 17 Mr. Henzy's firm. A. 18 Are you going to follow your counsel's instruction 18 ். Was it a lawyer at Mr. Henzy's firm? 19 not to answer? 1 ਤੇ I think so. I'm not sure.

20 A.

21 ். Okay. Did Mr. Henzy contact you by phone? 21 BY MR. LUFT:

No. 22 Did they offer to represent you? ू.

Did he contact you by email? 23 MR. HENZY: Objection, attorney-client 24 (Pause.) 24 privilege. I'm instructing you not to answer. 25 THE WITNESS: I was contacted by Mr. 25

1 Highly Confidential 1 Highly Confidential 2 (Indistinguishable crosstalk.) 2 BY MR. LUFT: 3 MR. LUFT: I'm speaking before you have 3 Q. Do you have any idea who is paying for 4 any relationship with the witness. I'm just 4 Mr. Henzy's services today? 5 asking if you approached wand offered to 5 MR. HENZY: Objection, asked and ా represent . That's not giving advice. రా answered. 7 MR. HENZY: I've objected and instructed 〜J THE WITNESS: No. 8 not to answer. ్రా BY MR. LUFT: 9 BI MR. LUFT: 9 Do you know if Mr. Henzy's client, Miles

10 Q. Are you going to follow your counsel's 10 Kwok, is paying for his services today? 11 instruction? 11 I don't know. A. 12 A. Yes. 12 Do you know if a member of Mr. Kwok's family

13 Did Mr. Henzy's firm tell you who would pay رُ 13 is paying for Mr. Henzy's services today? । ਹੈ for his services? । चै I don't know. ਕਿ . 15 A.

16 Do you know if you are responsible for paying ் 16 BY MR. LUFT: 17 for his services today? 17 How did you first come to be involved in this

18 I don't know if I'm responsible. I'm not প্রায় প্রতিষ্ঠান কর্ম 18 issue? 19 going to pay. ો કે MR. HENZY: Objection. 20 Did you tell Mr. Henzy? ். 20 THE WITNESS: What issue?

res. 21 MR. HENZY: Vague, ambiguous.

Okay . 22 MR. LUFT: That's fine. ೭3 I don't think I should pay. A. ਨੌਤੇ BY MR. LUFT: ੇ ਹੋ (Pause.) ਡ ਕੇ Q. Is it your intention to give testimony at the 25 25 contempt hearing next week?

1 - Highly Confidential l - Highly Confidential 2 A. I don't know. 2 a copy of Debtor's Objection to Motion of 3 MR. HENZY: Objection. Objection. (ఎ Chapter 11 Trustee for Entry of Order Holding 4 Vague, ambiguous, but -- 4 Debtor in Civil Contempt for Failure to Comply 5 THE WITNESS: I don't know. 5 with Corporate Governance Rights Order. ్ర MR. HENZY: Is it it intention? ు (Thereupon, a document was marked by the 7 I'm not -- I'm not -- I don't -- I'm not ﻟﺘﻨﺎ Exhibit 1 for

B trying to make speaking objections, Avi. I'm ్రె identification.) ੀ। not, but I think it's vague. 15 (An informal discussion was held off the

11 Do you know what the word "intention" means? ं 11 MR. HENZY: One second, Avi. I don't

ਕਿ . 12 think there's any question. 13 ু . Okay. 13 MR. LUFT: Do you want to go off the

A. । ਉ record? 15 ். Please. 15 MR. HENZY: I want to go off the record. 16 -- for the question you just asked. I didn't તે. 16 MR. LUFT: I'm good. 11 know there was a hearing. 17 Just let me lay this foundation, and we 18 Okay. Has anyone spoken to you about giving ે. । ਉ can go. We can take a break. I just want to 19 testimony before the court? । ਤੇ ask quick question, just to finish my 20 A. About? 20 thought. 21 Q. In connection with the contempt motion that 21 MR. HENZY: Okay. There's no question 22 we are here about today. 22 pending, and I want to talk to my client.

No. 23 There's no question pending.

25 No? Okay.

MR. LUFT: I'm going to mark as Exhibit 1 24

న question. I'm in the middle of a question. 2 answer, if you can. 3 MR. HENZY: Go ahead. 3 THE WITNESS: It might be. I'm not 100 4 (Pause . ) 4 percent sure. 5 BY MR. LUFT: 5 BY MR. LUFT:

Okay. Okay and on the 5 Okay. Are you planning to offer testimony at ். 1 turn to page 11 of the Debtor's Objection to Motion of 7 the hearing on this contempt motion as to the "many 8 Chapter 11 Trustee for Entry of Order Holding Debtor in ರ್ material deficiencies" in the official translation of ੀ। Civil Contempt for Failure to Comply with Corporate ್ತಾ the 341 meeting? 10 Governance Rights Order, which is marked as Exhibit 1. 10 A. As far as I know, that I'm only here to be 11 Do you see the first full sentence on the top of 11 deposed today. 12 page II says: 12 No one has spoken to you about offering any

। ਤੇ "At any hearing on the motion, debtor will put on 13 other testimony at the hearing? । ਜੋ testimony from an interpreter as to the many material । ਪੈ র্না No, I don't think so. 15 deficiencies in the official translation of the 341 15 ू.

17 Do you see that? 17 ్ర.

। 8 res. ् द् 18 Hang on. I don't think so, but maybe my

1 9 Q. Are you the interpreter referenced in this 19 memory is at fault. 20 paragraph? 20 Well, the hearing's Tuesday. ். 21 (Pause.) 21 A. Yeah. 22 MR. HENZY: Objection. 22 Has anyone asked you to give testimony -- be

23 THE WITNESS: I -- ਨ ਤੋਂ ਤੇ in Connecticut to give testimony in court on Tuesday? ਨ ਹੈ MR. HENZY: Well, objection. 24 I can't remember. I don't think so, but -- A. 25 It's vaque and ambiquous, but you can 25 you know. Like I said, maybe my memory is at fault.

1 Highly Confidential 1 - Highly Confidential 2 Do you have other plans on Tuesday?

Okay . 3 I'm going to be the interpreter. I don't ಕೆ. స్త A. That is -- that I was not testifying. 4 know whether I'll be asked to give testimony. 4 Sorry. I don't -- I didn't mean it to be a

5 You don't recall if anyone's asked you to do ว่ 5 negative. Sorry. ్ర that? ் I'm just asking if you are going to testify on 7 I can't exactly remember. ি : ﻟﺴ behalf of Mr. Kwok on Tuesday. B MR. LUFT: Okay. Why don't we take -- రం 4. res. 9 give you your break right now? ್ 0.

10 MR. HENZY: Okay. 10 page. 11 MR. LUFT: We can go off the record. 11 MR. HENZY: got the -- got the -- got it. I 12 THE VIDEOGRAPHER: The time is 9:39 a.m. 12 didn't, but it's good. We're okay. 13 We're going off the record. 13 BY MR. LUFT: । पै (Recess taken at 9:40 a.m.) । पै I'm going to ask you to look ். 15 (Resumed at 9:45 a.m.) 15 back at Exhibit 1, same page, page 11. 16 THE VIDEOGRAPHER: The time is 9:45 a.m. ો રે A. Uh-huh . 17 We're back on the record. 17 When did you first tell counsel for Mr. Kwok 2. 18 BY MR. LUFT: 1 8 that there are many material deficiencies in the

्र , । ਤੇ translation of the 341 meeting? 20 chance to speak with your counsel. 20 (Pause.) 21 Yes . A. 21 THE WITNESS: Do you mind if I ask you to 22 Is it your understanding that you will not be . 2 22 clarify one thing for me? 23 testifying at the hearing on Tuesday on behalf of 23 BY MR. LUFT:

25 Mr. Kwok? No, that is not my understanding.

25 Of course. ू . This is asking about -- you're asking me when A.

1 Highly Confidential 1 Highly Confidential న I was -- when I first time told Mr. Kwok about the 2 (Pause.) 3 deficiencies on the material of the translation -- ప్ THE WITNESS: I cannot be exact on the 4 Sorry, Let me try it again. ் 4 time or the date.

Okay. 5 BY MR. LUFT: 5 Okay, so the first sentence of the debtor's 5 ் 〜J What's your best recollection?

1 pleading on page 11 is "At any hearing on the motion, (Pause . ) 8 the debtor will put on testimony from an interpreter as ్రం THE WITNESS: I really cannot remember. 9 to the many material deficiencies in the official 9 I'm sorry. 10 translation of the 341 meeting." 10 BY MR. LUFT: 11 My understand is that you are that interpreter. Is 11 ் Was it within the past week? 12 that your understanding? 12 The first time, probably not. A.

Yes. 13 Was it before someone from Mr. Henzy's firm ். । ਹੈ ू . Okay. My question is: । पै contact you about representing you? 15 When did you first tell counsel for the debtor that 15 Prior to that.

TP there were many material deficiencies in the official 16 (Pause . ) 17 translation of the 341 meeting? 17 BY MR. LUFT:

At that 341 meeting, 18 How did you let Mr. Kwok's counsel at the --

1 9 Okay. You told counsel for the debtor at the ﺰ 19 at the time of the 341 hearing know that there were many 20 time that there were many material deficiencies? 20 material deficiencies in the translation? 21 ి. res. 21 In the first place, I was raising dispute to यं कि वर्ष के साथ संस्था कि में में में में में में में में में में में में में में में में में में में में में में में में में में में में में में में में में में में में म 22 Okay. When did you first tell debtor's ். 22 the interpreting at the time when the official 23 current counsel that there were many material ਨੌਤੇ interpreter was interpreting. 24 deficiencies in the official translation of the 341 24 Okay. So when you heard a material

25 meeting? 25 deficiency, you let the official translator know?

1 Highly Confidential 1 - Highly Confidential 2 Everyone -- you know, just everyone in the

3 room would know, yes. Q. Okay. 4 Okay. I'll make it broader. ું. Right.

5 A.

5 Q. When you heard a material deficiency in the Un-nun .

translation of the 341, you let everyone at the 341 ्र

8 meeting know, including -- B Barrantal A. W Un-hun.

10 --- Q. -- the official translator? 10 counsel for Mr. Kwok at the time, to make a comment?

12 Q Q Okay. Is there any other way -- 12 Q Q Okay. 13 - 1 - 1 - 1 MR. LUFT: Let me strike that. 13 -- A. -- noping he would. 14 BI MR. IUFI: 14 - Q. Q. And at the times where I can see your 15 Q Q Were there material deficiencies in the 15 "private interpreter" reference in the transcript -- 16 transcript that you heard that you said nothing about? 15 - A. A. Rigar, 17 Super ------------------------------------------------------------------------------------------------ (Fause . ) - 17 Q. Q. - those were the times when you were making

18 18 statements? "material" is for me -- probably is different 19 A. A. Right. 20 - 1 - 1 - Ircm what you chink material, but for me 20 = Q. Okay. Then the periods where I don't see you 21 There were a number of things happening 21 making statements, it's possible you were passing 22 at that that meeting, and at some point, I switched 22 notes -- 23 to telling out loud about the -- my dispute to 23 - A. Right, 24 how handing a note to the counsel about my 25 dispute. 24 Q -- Q. -- to Mr. Baldiga? 25 - A. A. Right.

Page 30 Fage 31 1 - Highly Confidential 1 - Highly Confidential 2 Q. And when did that switch happen? 2 A. A. Yes. 3 ( 3 = Q Q. Okay, so it wasn't == 4 THE WITNESS: I think at one point, a 4 It is not the case that you were going back and 5 . . . . . . . . comment was made that there were too many 5 forth? 6 6 interruptions -6 You just made a decision at one point, and then 7 BY MR. LUFT: 7 - once that happened, you switched to the notes? 8 - - - - Q. - Un-huh. 8 9 to A. A. -- as my purpose in court was to check, not 9 the majority of times, 10 - to disrupt or interrupt, then I thought perhaps that I 10 . . But when there was something that I really cannot, 11 hold onto -ll should be a bit more discrete about my disputes, so I 12 switched to handing notes. 12 ------- uh-hua. 13 13 14 - what exact action, I don't remember. 14 - that I need to say, perhaps really critical, I would --15 Q. Okay. Just so I'm clear abcut it --15 and like I -- like what is described here, permaps is 16 A A. Un-huh. 16 material, then I probably would just raise it out loud. 17 -- Q. -- there was a point where you made the 17 Okay. That's helpful. ். 18 18 decision to switch --Okay. What did you do to prepare for this । ਰੇ 19 deposition? 20 20 A. I spoke with my counsel. 21 - A. A. Yes. 21 When did you meet with your counsel? ். 22 22 Q - Q. - to passing notes? A. We did not meet. 23 - 1. 1. Yes. 23 0. When did you speak to your counsel? 24 24 A. Yesterday. 25 was? 25 How long did you speak to him? 2. Page 32 Page 33 - Highly Confidential 1 1 - Highly Confidential 2 2 MR. HENZY: Objection, privilege. BY MR. LUFT: 3 3 MR. LUFT: How long you met is not ं are you going to follow your 4 4 privileged. counsel's advice not to answer? 5 5 MR. HENZY: I'm going to instruct you not Yes. Counsel, do you mind if I add one more A. ్ర రు to answer. thing from my previous answer? 7 7 MR. LUFT: On what grounds? 0. Sure. B ြိ MR. HENZY: Attorney-client privilege. MR. HENZY: Do --9 MR. INFT: How long you met is ్ర THE WITNESS: I'm sorry. 10 10 privileged? MR. LUFT: That's okay. 11 MR. HENZY: Could be, yeah, absolutely. 11 MR. HENZY: Which answer? 12 Yep. What -- I have no idea why you want to 12 I don't think on that answer. I think on 13 know that. 13 the question you asked before. 14 But I'm claiming the privilege, Avi, and । ਹੈ MR. LUFT: I'm fine with I answering whatever ====wants to. 15 I'm instructing the witness not to answer, and 15 16 MR. HENZY: That's fine. you can --ોર 17 THE WITNESS: When I said that -- you MR. LUFT: Okay. 17 18 18 - - - - -MR. HENZY: You can pursue whatever you asked me about switching from notes to verbal 19 19 to dispute, and I said that when I really -need to pursue. 20 20 - there was schething that I cannot hold onto, MR. LUFT: Okay. I'll make a statement 21 if it's something material, I would probably 21 that I think these privilege objections, 22 22 say it out loud. especially this one, are completely proper --23 23 But that is not to say that I won't MR. HENZY: Okay. 24 MR. LUFT: -- and just obstructing the 24 - Bometimes maybe find a situation four 25 25 = appropriate for ne to hand a note to deposition.

1 Highly Confidential 1 - Highly Confidential న Mr. Baldiga that could be material as well -- N A number of things happened at one time,

4 - Q. Q. Okay. 4 4 mm exactly remember. 5 = (၂) BY MR. LUFT: 6 Q. Q. Was there ever an instance where you thought 5 How clear is your recollection of the 341

7 there was a material deficiency in the translation where ﻟﺴﻨﺔ meetings? 8 - you dicht tell Mr. Baltiga or say scmething? 00 A. Not -- I don't remember everything, but I 9 A . I don't think so, but -- 9 remember some significant moment.

That day was a little bit confusing, chactic at ். What was that significant moment? Il times, so I cannot be sure, but I don't think so. 11 A. Significant moments would be a certain point 12 . Do you recall times where you asked 12 that was -- like I said, there was -- there was a 13 Mr. Baldiga to make an objection and he refused? 13 chactic moment. I remember that, but I don't remember 1 में कर A. It was not my position to ask anyone to make ાં તે everything said. lo an objection. I handed nim the note. He's the counsel. 15 I remember there was such a moment, and I remember 16 -- He could decide when and where -- when and -- when 1 p certain disputes that I raised. I don't remember every 12 to make that objection or whether he's going to make an 17 dispute I raised, but I remember some -- some such 18 - objection. I handed him the note -- you know. 18 moments. 1999 . Q. . Do you recall any times when you handed 1 9 Q. Can you tell me your best recollection of the 20 Mr. Baldiga a note that schething was mistranslated and 20 chaotic moment you described? 21 he dian't make an objection on the record about it? 21 The chaotic moment was that the official

Pause.) 22 interpreter made an error in his interpreting and it was 23 . THE WITNESS: I can't quite remember ਨ ਤੇ so apparent that even Ms. Claiborne noticed that, and -- 24 = exactly, and as I was saying, that day -- at ੇ ਕੇ But during that -- the interpretation and 25 some point, it was a bit chactic, so 25 Ms. Claiborne's raising the issue, there were a number

1 Highly Confidential 1 Highly Confidential 67 of things said in between and -- and still there was 2 a chaotic moment? 3 some interpretation made, so -- you know, that -- that ్ర A. Yes . ਪ੍ਰੈ was the chaotic moment, I thought. 4 Okay. You don't recall which date it was ். న Q. Was that at the March 21st hearing or the 5 on --- ్రా April 6th 341 hearing? ు Right.

1 I don't remember the date. ्द्र 7 -- so I'm asking other than there -- I

B Okay. Was it at the first hearing or the ு. 00 believe you told me that there was some error -- 9 second hearing? ್ತಾ Uh-huh . A. 10 A. I actually don't remember which time either, 10 -- that Ms. Claiborne was able to pick up on? ். 11 but I just remember there was a meeting and there was 11 A. Yes. 12 some such moment. 12 ். 13 Do you recall anything else specifically Do you remember anything else about what was ാ 13 about that moment that you're describing? ੀ ਜੋ said about this chaotic moment that you remember? । ਪੈ ri Yes. I remember Ms. Claiborne was able to 15 (Pause . ) 15 pick up because it's -- the name the interpreter was 16 THE WITNESS: Specifically the words ો છ using in English so he interpreted the name wrong, so he 17 you're asking -- sorry. Can you ask that J J interpret -- 18 question again? । The question was asked about a company name in 19 BY MR. LUFT: । ਤੇ English and interpreted back to Mr. Kwok in Chinese, but

் 20 using a different English name. So that is why 21 I asked you what you can recall and you mentioned 21 Ms. Claiborne was able to pick up the interpreting was 22 one of the things that you -- that you don't have a 22 wrong and I remember that -- you know. 23 clear recollection of everything -- 23 Anything else you recall?

ਨ ਚੋ A. Yes, yes. ੰ 4 A. Say that again? 25 Q. -- but that one of the things you remember is 25 ். Anything else you recall about that chaotic

Page 38 Fage 39 1 1 - Highly Confidential - Highly Confidential 2 moment? 2 Like I said, the interpreter -- the 3 3 A. Yes. Like I said, there were a number of question was asked using one name and the 4 back and forth in interpreting and Mr. Baldiga's asking 4 interpreter was interpreting in another name. 5 5 questions, and I'm not sure whether I said something. Now, I cannot remember which is which. 5 5 BY MR. LUFT: I probably did not, because I saw that 7 7 Ms. Claiborne was picking up, but there were a number of Okay. Can you just tell me the two names ். ్రం ರಂ things going in between. I just cannot remember that were used? 9 9 specific -- specifically the words. Okay. I think one was Ace Decade, and then A. 1 D Terrific. 10 the other one ... I think it was Dawn State. I cannot ். 11 I should -- I should have mentioned 11 be sure. 12 this at the beginning of the deposition. If I ask you 12 (Thereupon, an informal discussion was 13 13 what you recall --held off the record with the shorthand 14 14 rij Uh-huh. reporter.) 15 ். -- I just want you to tell me what you 15 THE WITNESS: And I cannot remember । ਇ actually recall. I'm not asking you to speculate --ાં ર whether the question was raised with which 17 Uh-huh . 17 name and whether the interpreter's යේ 18 -- as to what you think it would be unless I 18 interpreting the other. I cannot remember ். 19 19 ask you something or I specifically do that. the --20 20 BY MR. LUFT: rit Okay. 21 21 Do you remember the name of the English ్లు Okav. ့ 22 22 -- which one is which. company or the -- sorry -- the name of the company that A. 23 was said in English? 23 But you recall for this dispute that sticks ். 24 24 (Pause.) out in your mind --25 THE WITNESS: There were two names used. 25 A. Yes. Page 40 Page 41 - Highly Confidential 1 - Highly Confidential 1 2 2 » with other interpreter disregarding the interpresing ਂ. -- the names that were at issue were Ace 3 Decade and Dawn State? 3 etiquette of witness testimonies. 4 I think so. 4 So I -- at one point, I said something to the A. 5 So if I looked in the transcript, I should 5 interpreter in court. ्रं .

उं ్ర 6 Q. Do you remember what you said to him? see a transcription of a dispute in which the names Ace 7 Decade and Dawn State are used? 7 Jul A. Yes. I can't remember exactly what he B I think so. 8 interpreted, but then he put a word in. He assumed it A Okay. You said you -- the other things that 9 9 was there, but it wasn't there. and the provinsion of the first of the first of the first of the first of the first of the first and 10 wou recall --ID So I said to him that there was no such word in the 11 - A. A. Un-huh. ll - witness word -- statement -- the statement the witness |12 Q. -- from the 341 hearings are some "disputes," |12 made. You assume it was there. So something I said 13 I believe was your word? 13 that --14 There were a number of disputes, yes. 14 I don't know whether it was reflected in the 15 Q Q. Q Okay. Could you tell me specifically what 15 - transcript. In fact, I can't remember whether I said it 16 - disputes you have an actual recollection of in the 341 16 - in English or Chinese, but I said something like that at 17 hearings? 17 che point. 18 . A. There were a number of them. I cannot 18 @ Q. Q. Qkay. Any other specific disputes that you 19 remember all the disputes. 19 have an actual recollection from the 341 hearings 20 As I said, there were some disputes that I raised 20 sitting here today? 21 out loud and there were some disputes I wrote down and 21 A A Not specifically. 22 - handed notes to Ms. -- to the counsel. 22 Okay. Did you review any documents to ुं -23 But one thing I remember, and it's because T 23 prepare for this deposition? 24 usually took issues with -- it may not be a material to 24 д. No. 25 25 the case here, but as an interpreser that I took issue ். Have you reviewed any material that has

న refreshed your recollection with regard to the 341 N BY MR. LUFT: 3 hearings? 3 How did you get a copy of the transcript?

4 No. I don't have those. এই 4 I didn't have a copy of the transcript. A.

். 5 How did you read the transcript, if you ੁ. ్ర debtor's objection. Did you ever read that document -- 5 didn't have a copy of it? 7 A.

I was e-mailed a section of the transcript. ్రం -- prior to today? ੂ. ్రా Who e-mailed you a section of the transcript? ். 3 A. No. 9 Counsel of -- Melissa Francis. ਜੋ . 10 Were you consulted with regard to information ். 10 Is that the first time you ever received ു. II to include in that document? 11 communication from Ms. Francis? 12 A. No. 12 A. No. 13 Have you ever read a transcript of the 341 13 ். How often do you hear from Ms. Francis?

Not often.

15 hearing? res. 15 So tell me about this email from Ms. Francis. ra, ். 16 When did you read a transcript of the 341

17 hearing? 17 A. - Ms. Francis sent a section of the transcript 18 I did not read the entire transcript. ্র 18 to me and sent an audio to me and asked me to listen and 19 I read a section of the transcript, but I cannot 19 then to check the transcript. 20 remember when. 20 Q. What was on the section of the transcript and 21 What's your best recollection? ر 21 the audio that Ms. Francis sent you? 22 (Pause.) 22 A.

23 THE WITNESS: One month ago, at least, I 23 The audio was capturing the moment -- the chaotic ਨ ਕੋ think. ੇ 4 moment that I just described to you, and there was some 25 25 prior lines and subsequent lines I don't quite remember,

1 Highly Confidential l Highly Confidential 2 and the transcript was also capturing that -- that time, 2 BY MR. LUFT: 3 but not everything that reflected in the audio. (ఎ Okay. This is the same chaotic moment you ं. ੍ਰੀ Q. I'm sorry. Can you clarify? The transcript 4 described for me? 5 was 5 Yes, but it wasn't moment I was telling the

్ర A. The transcript reflecting some of the verbals ் interpreter he was wrong. It was -- actually, 1 in the audic, but not everything. That's what I'm - Ms. Claiborne caught what was wrong, and like I said, ങ sayında ്ട between the interpretation -- ਭ Okay. You say the transcript was -- was the ். ﺪﻳﻨﺔ Between the interpreter's misinterpretation and Ms. ID portion of the transcript addressing the chaotic moment? 10 Claiborne catching up with that mistake, there were a 11 Is that right? 11 number of back and forth questioning and answering 12 Yes, corresponding part of the audio and the વ્યું 12 conversation happening which was not recorded in the 13 transcript. I -- yes. 13 transcript, and that's what I'm saying. 14 So this was a portion of the transcript and ; ; । At that point, in fact, I was not able to raise my 15 audio in which the translator is mis- -- mistranslating 15 dispute because there were so many back and forth going 16 something, in your opinion, and you are telling him that ો મે on, and also, at that point, Ms. Claiborne was also 17 he is doing it wrong? 17 attaching up, so it wasn't the moment I raised dispute. 18 MR. HENZY: I'll object. I don't think 18 Can you describe for me what was included in

। ਕੇ that was to testimony. । ਤੇ this transcript? 20 MR. LUFT: Well, that was my 20 A. The -- what was include in the transcript was 21 understanding of the what the chaotic moment 21 very abbrieved [sic], kind of -- 22 was. 22 Because the -- because what's happening in the 23 THE WITNESS: No. 23 audio was that the interpreter has said -- has said ਨ ਕੇਂ MR. HENZY: Sorry. I think we're a 24 things in Chinese and to Mr. Kwok and Mr. Kwok was 25 little confused here. 25 answering in Chinese and -- but it not being interpreted

Highly Confidential 1 - Highly Confidential 6 in English so the court reporter could not have recorded 2 that -- at that meeting. It's hard for me to 3 that, and between those conversations -- 3 gauge exactly how long that was. 4 And Ms. Claiborne caught -- Ms. Claiborne was aware 4 BY MR. LUFT: 5 that there was a mistake, because the names was 5 Okay. Which date of the 341 hearing was ். 0 interpreted wrong and -- and she is already saying -- 5 this? 7 She's addressing that problem, and so there were a -- J I can't remember.

8 lot of aside things going on which were not captured in ్రా Approximately -- I'm asking just about the ్ర . 9 the transcript, and so that's all -- that's all I'm 9 transcript. 10 saying. 10 A. les. 11 Q. So the portion of transcript you saw has Ms. 11 Was it like five lines that she sent you?

12 Claiborne catching and making a comment -- 12 Was it a page that she sent you? What's your best 13 में . les. 13 estimate? । ਹੈ ். -- that the person is using the names of Ace । ये I think there were two pages, I think.

15 Decade and Dawn State incorrectly? 15 And what was -- what was on the --

16 ন .

17 17 To the best of your recollection, can you describe ். Ukay, so -- 18 what was on those two pages that you reviewed at

That made the question wrong all together. Ms. Francis' request? 19 Okay. Can you tell me what else was said and ் 19 A. I wasn't only doing that part. That part 20 how long was this portion of the transcript? 20 stuck out to me, and that was the major thing. 21 (Pause.) 21 Like I said, that was the main chaos, and there 22 THE WITNESS: It wasn't that long. I 22 were lines before and after deriving from that chaotic 53 don't think that chaotic moment was that long, ਨਤੇ moment, and the content of those, I -- I can't recall. 24 but there were many prior lines and subsequent ੇ 4 Q. Other than having read what Ms. Francis sent 25 lines of questioning derived from that at 25 you ---

1 - Highly Confidential 1 Highly Confidential 2 A. Uh-huh . 2 So whatever memory I have today is aided by that -- 3 Q. -- can you give me your best independent 3 aided by that audio and that correspond with what I 4 recollection of that moment? 4 recall at that time. 5 Apart from what I just said? A. 5 Q. Okay, so I just need to know what you recall ్ర Q. Apart from what you saw from listening to the ் from that time other than from that audio. audio and speaking to -- and reading the transcript, ﻟــــــــــــــــــــــــــــــــــــــــــــــــــــــــــــــــــــــــــــــــــــــــــــــــــــــــــــــــــــــــــــــــــــــــــــــــــــــــــــــــــــــــــــ MR. HENZY: I -- just objection, vague, what is your -- what was your -- 8 ambiquous, but you can answer. 9 First of all, let me ask you: Sitting here 150 THE WITNESS: Right. You mean just that 10 today -- 10 moment or that day? 11 ਕ: Yes. 11 BY MR. LUFT: 12 ். -- other than what you read -- 12 Just with regard to the -- the section of the ું. 13 Uh-huh . ां 13 transcript that Ms. Francis chose to send you. 14 -- that Ms. Francis sent you and the audio ुं. । ਪੈ A. Okay. 15 you listened to, can you please tell me your best 15 MR. HENZY: Can I just ask a question? I 16 recollection of what happened at that moment? ો રે don't -- because I want to make sure --- I 17 (Pause.) 17 don't want to answer your question. 18 THE WITNESS: But -- you know, my memory । ਉ You're asking to separate to memory । ਕੇ today was aided by that audio. । ਤੇ of the meeting, kind of almost block out what 20 BY MR. LUFT: 20 heard on the audio --

22 You now have a clear memory of it because of the 22 MR. HENZY: -- which is kind of hard? 23 audio or your -- you listened to the audio? 23 MR. LUFT: Well, I think it's -- 24 Right. I listened to the audio -- you know,

25 when it was sent to me. 25 MR. HENZY: I am going to make an

Faqe 51 Page 50 1 Highly Confidential 1 Highly Confidential 2 objection just to -- you know. 2 -- did you then have a clear memory in your 3 3 Vague, ambiguous. I just want to be head apart from what you just read and heard of that 4 clear what you're asking her to do. 4 moment or is it just that you read it and heard it and 5 5 BY MR. LUFT: your recollection now is based on having listened to it 5 5 ். Why don't we do this in parts? Prior to and read it again? 7 7 Ms. Francis --After I read and listened, it reminded me of A. 8 ్ర 员。 Un-huh . what happened and more specifically what happened, 9 9 exchanged in words. -- sending you the transcript and the audio, ். 10 what was your -- can you give me your -- what was your 10 So it wasn't just based on that record. It did 11 best recollection of that portion --11 remind me what actually happened, yes. 12 A. Uh-huh . 12 0. I'm going to ask you now to please tell me 13 13 ੁ. -- of the hearing that she sent you before --what is now your recollection of that moment, not as । ਪੈਂ 14 refreshed -rij Uh-huh . 15 ். -- listening to the transcript and reading 15 A. Uh-huh . । ਇ ો ર ್ತ. -- by the transcript -the portion of the transcript? 17 Before I read and listened to the record, I 17 A. Uh-huh . යේ 18 18 only remembered there was a chaotic moment and there -- and the audio, but not repeating to me ्. 19 19 were disputes I raised, and -- you know, the issues with what you've read on the transcript --20 20 A. the interpreting, but I don't remember specifics. Right. 21 After you read the portion of the 21 -- of the audio, if that makes sense. ் ். 22 22 transcript --Right. I understand what you're saying. A. 23 A. Uh-huh . 23 I -- if I don't based on that audio and things, 24 -- and listened to the audio --24 today, I would -- I would remember that was this --್ತ. 25 25 A. Uh-huh . there was this kerfuffle happening at the time, chaotic Page 52 Page 53 1 1 - Highly Confidential - Highly Confidential 2 2 moments. question to the witness to -- maybe asking a 3 3 And I remember the exchange that was happening and clarifying question, and so therefore that he 4 4 did not think that it should -- it needed to the disputes, but probably not every specific word. 5 5 Other than what you've told me about the be translated or interpreted back into English ். ర్ 5 dispute -for everyone else in the room to know. 7 7 And that kind of sideline conversation Ar Uh-huh . B ြိ -- that there was an issue with regard to the was not captured in the transcript, and that's ். 9 name Ace Decade or Dawn State was used --్ర why that -- that happen -- that happened, and 10 10 A. Uh-huh . I think at one point I was about to raise that 11 --- do you recall anything specific about that 11 and, in fact, Mr. Baldiga, I think, he said ू. 12 12 something like "Can you please interpret moment? 13 (Pause.) 13 that?" 14 THE WITNESS: That moment wasn't just 14 But by that point, I think Ms. Claiborne 15 about Dawn State and Ace Decade. That was the 15 also caught on with the error of Ace Decade 16 moment that Ms. Claiborne picked up the error, ાં ર and Dawn State, so that had put aside -- I 17 but that was the moment continued from a 17 think that was put aside, so there were a 18 series of mistakes, minor or major, so it's --18 number of these things happening ... that --19 15 that is --That's what I recall, and -- and 20 20 particularly what -- what happened was that That is not exactly the interpreting 21 the interpreter would use Chinese to ask the 21 problem that is really about the interpreter's 22 22 witness questions and then the witness would etiquette -- professional etiquette -- you 23 answer in Chinese and -- and because of that 23 know, so at one point, I raised an issue out 24 kind of exchange, it's --24 loud. That's what I remember. 25 25 It's like the interpreter is asking

2 BY MR. LUFT: 2 A. No. 3 Q. Do you recall anything else specifically with 3 ं

ಗಿ regard to what was said for the portion of the 4 either March 21st or April 6th? റ transcript that you reviewed at Ms. Francis' request? 5 I have not reviewed any other part of নি। বাংলাদেশের মাধ্যমে বাংলাদেশের প্রশ্ন করে আমার প্রশ্ন করে আমাকে বিশ্বকাপে পারে পারে পারে পারে পারে পারে পারে পারে পারে পারে পারে পারে পারে পারে পারে পারে পারে পারে পারে প

A. రా transcript for any day except that part that's sent to 7 recollection. 7 me by Ms. Francis. ్రం Okay. ch ్రం Ms. Francis tell you why she was sending you

9 (Thereupon, an informal discussion was 9 that portion, other than she wanted you to check it? 10 held off the record.) 10 No. She said to me, "Listen to the audio and A. A. 11 BY MR. LUFT: 11 check the transcript." 12 Q. Had Ms. Francis talked to you about this 12 Okay.

13 issue prior to sending you this portion of the 13 And to see whether it's accurate. A. । ਹੱ transcript? । चै Do you have a copy of that audio and email ু. 15 No. A. 15 Ms. Francis sent you? JE Was there a cover note in connection with the ूं. 16 It was sent to us with the attachment and the 17 transcript? 17 email, so it would be with the email. 18 A. The email was just asking me to -- in fact, 18 MR. LUFT: Okay. 1 એ I'm not sure what's said on the email, now, but no, 1 9 Eric, I'm going to ask that those be 20 there was no cover note. 20 produced immediately, yeah. 21 Okay. ्। 21 MR. HENZY: There's no production 22 (Pause.) 22 request. 23 BY MR. LUFT: ਨਤੇ MR. LUFT: I'm asking you right now. ੇ ਹੋ Q. Did you -- have you reviewed any other ਡ ਕੇ MR. HENZY: I -- then you need to give me 25 portion of the 341 transcript? 25 a formal production request. There's no --

2 - Highly Confidential 1 - Highly Confidential 3 In the federal rules, there's no such 2

4 thing as verbal production requests, okay? If there's something in the rules I don't know 4 request.

్ర about, you guys should tell me. MR. BASSETT: Eric, there's such a thing ರಾ be produced during this deposition, please. BY MR. LUFT: 1 as cooperating and providing documents that 7 Did you ever share this email from

B you're obligated to produce under a request in ಕ Ms. Francis and audio file with the Zeisler firm? 9 light of the hearing that is -- ್ತಾ A. No. 10 MR. HENZY: Do you want to argue about it 10 How did you respond to Ms. Francis? ். 11 now? 11 I said -- I suppose I wrote an email back

12 (Pause.) 12 saying "Yes, I'll listen and I'll check." 13 MR. HENZY: The schedule's your schedule. 13 And did you do that? ். 1 में You certainly have enough people. You । ਪੈ A. Yes. 15 certainly know how to ask for things when you 15 Do you have a copy of that email? ूं. 16 want them. ો ન It should be with my email, I think.

17 (Pause.) 17 MR. LUFT: Do you want me to put an S on 18 MR. LUFT: Okay. Let the record reflect । ਉ "email." or -- 19 I'm handing Mr. Henzy a note in writing that । ਤੇ MR. HENZY: You can do whatever you want. 20 says "Please produce the email and electronic 20 BY MR. LUFT:

transcript 21 Okay. I'm requesting that email. ். 22 about." 22 And how did you tell Ms. Francis the results of 23 It's dated today, and it has my name on 23 checking that portion of the transcript? 24 lt. 24 A. I just sent the file back. 25 MR. HENZY: Thank you. 25 Did you ever speak to Ms. Francis about this? ்.

1 Highly Confidential 1 - Highly Confidential న I sent -- I sent my work product back. . ជុ 2 sandbagged us by not producing the exhibits

What was your work product? (1) you intend to put at trial. 4 It's record of the audio. वां 4 MR. HENZY: It's your schedule, Avi. 5 It's a transcription of the audio file from my own (JT It's your -- ్ listening. 5 MR. LUFT: What do you mean, it's my 7 So you made a transcript of the audio file ் -- J schedule? ్రం where you -- ్రా MR. HENZY: You didn't ask us for any 9 A. Uh-huh . 9 production. It's -- it's -- I'm sorry. It's

Explain to me. 10 the judge's schedule. 11 I don't understand. Is it you translated -- you -- 11 MR. BASSETT: Eric, that's also not true. 12 most of it's in English, so what's going on? 12 MR. LUFT: Yes. 13 And also translated the parts spoken in यूं में भी में में में में में में में में में में में में में में में में में में में में में में में में में में में में में में में में में में में में में में में में मे 13 MR. BASSETT: We asked you and your । ਹੈ Chinese, yes. । चै colleagues in advance for this exact purpose 15 Do you have a copy of that? ். 15 for copies of the exhibits that you intended

17 I have a copy of that, yes. 17 MR. HENZY: Yep. 18 ். Can I have a copy of it? MR. HENZY: No. I mean -- no. 18 MR. BASSETT: -- and for the identities

20 You're going to see it filed as an 20 exhibit before noon today. MR. HENZY: Yep. 21 MR. LUFT: Okay. 21 MR. BASSETT: -- and you refused to 22 BY MR. LUFT: 22 provide them. 23 this isn't on you.

24 MR. LUFT: I think it's completely ਨ ਜੋ complying with the court's order, and if you 25 improper that you have a witness and you've 25 didn't like the court's order, Nick, you quys

1 Highly Confidential 1 Highly Confidential W definitely know how to go back and ask for 2 MR. LUFT: When on Friday are we getting 3 relief. (ఎ this? دلو MR. BASSETT: Okay. 4 MR. BASSETT: Noon. 5 MR. HENZY: This is your schedule. 5 MR. LUFT: Why don't we go off the ్ర You're bringing this on for hearing on an ் record? Because we may need to wait until you 1 expert basis. ﻟــــــــــــــــــــــــــــــــــــــــــــــــــــــــــــــــــــــــــــــــــــــــــــــــــــــــــــــــــــــــــــــــــــــــــــــــــــــــــــــــــــــــــــ hand it over. B MR. BASSETT: Eric. ్రం MR. HENZY: I quess that's up to you. I 9 MR. HENZY: We could have done this a 150 mean, you can't -- you can't -- actually, it's 10 very different way. You quys chose the 10 not up to you. 11 schedule. If you didn't like -- 11 You can't say now this witness has to 12 What Jim said back to you was if you -- 12 wait around for an hour and a half because you 13 we're going to comply with the Court's order. 13 guys didn't -- 1 4 That's what we're doing. । (Indistinguishable crosstalk.) 15 MR. BASSETT: What I said back to Jim, 15 MR. LUFT: If you tell Judge Manning that 16 which is correct, is that regardless of the ો ક this is how you're -- you want to practice, 17 court's order which set a final deadline for 17 you can talk about it. We're going to go off 18 the exchange of witness exhibit list, we had । ਉ the record right now -- । ਕੇ the right to request discovery from you, which । ਤੇ MR. HENZY: That's fine. 20 we were doing in the form of requesting all 20 MR. LUFT: -- and we'll see where we are. 21 exhibits and witnesses that you then knew you 21 THE VIDEOGRAPHER: The time is 10:30 a.m. 22 anticipated using at the hearing. 22 We're going off the record. 23 And the response was "We're not going to 23 (Recess taken at 10:30 a.m.) 24 give that to you. We're going to wait until ੰ 4 (Resumed at 10:57 a.m.) 25 Friday." 25 THE VIDEOGRAPHER: The time is 10:57 a.m.

2 We're back on the record. 2 A. No. 3 BY MR. LUFT: 3 After you sent Ms. Francis -- by the way, who ू .

ुं. is Ms. Francis representing? 5 Ms. Francis work product where you translated from the (၂) I don't know. A.

7 A. Uh-huh, yes. 7 BY MR. LUFT: 00 Q. Do you have -- were there any drafts you made ్రం Did you ask her who she's representing?

9 of that document? 9 A. No. 10 A. No. 10 Why did you do it, if you had no idea who ു. 11 Did -- do you have any internal drafts of the ். 11 Ms. Francis was asking you to do it for? 12 cocument? 12 She's API client. A. 13 No. धां, 13 So your client -- Ms. Francis is -- is your ੂ. । ਹੈ Did you make any notes when you were creating ్లు । चै client? 15 that document? 15 A. No. I mean, if she asks me to do a job, then 16 ন . No. 15 I will do a job and I will give it back to her.

Did you ask Ms. Francis for what purpose you 17 Did Ms. Francis pay you for this work?

18 were making this document? 18 (Pause.) 1 9 A. No. ી કે THE WITNESS: No. 20 Q. - Did you ask Ms. Francis why she wanted 20 BY MR. LUFT: 21 specifically this portion of the two days of testimony 21 All right. Who paid you for the work?

22 translated? 22 Counsel's firm. A. 23 23 Which counsel? I don't think so. A. ். ਨ ਹੈ ੁ . Did you have any communication with ੇ 4 Mr. Zeisler's firm. A. 25 Ms. Francis after you sent her the document? 25 ்

1 Highly Confidential l Highly Confidential 2 translation? 2 BY MR. LUFT: 3 A.

4 But Ms. Francis was the one who asked you? ্র 4 How long did it take you to get back to Ms. Francis 5 A. Uh-huh, yes. 5 with your work product?

1 translation? 7 THE WITNESS: Can you ask the question

ri, ్రాం again?

Okay. 5 BY MR. LUFT: 10 ি, 10 Sure. You said Ms. Francis sent you this ു.

11 You do. I'm sorry. ੋ. portion of the transcript about a month ago -- Yes. A. 12 MR. HENZY: It's not very relevant. 12 13 But yeah, you have to, if he really wants 13 ்.

1 में to know. । A. res. 15 THE WITNESS: As an interpreter, my cay 15 -- with the request that you translate it, ். ો ક rate is a thousand dollars a day. ો ર how long did it take you to get back to her with your 11 BY MR. LUFT: J 7 work product? 18 Is that how much you were paid to do this

19 translation? 1 ਤੇ THE WITNESS: I think a couple of days or 20 les. A. 20 several days. Within several days.

How long did it take you to do the 21 BY MR. LUFT: 22 translation? 22 ். Okay, so -- but within a week? 23 About a day. A. 23 A. Yes. I think so, yeah.

Fage 67 Page 66 1 Highly Confidential 1 - Highly Confidential 2 Uh-huh . 2 covered by the privilege. That's --না 3 3 ू . -- did you have any other conversations with That's a classic case of a third party 4 4 Ms. Francis about this translation? being covered by privilege, Avi. I can't -- I 5 5 MR. HENZY: I'm going to actually object can't do my job because I don't understand 5 5 now, based on attorney-client privilege. I'm Chinese. There's an audio that's in Chinese. 7 7 going to instruct you not to answer. I need an interpreter to tell me what's in the 8 ్ర MR. LUFT: Based on whose attorney-client audio, okay? 9 ్ర privilege? BY MR. LUFT: 10 I'm sorry. Just -- Eric, just so I 10 ್. Who retained you to do this job? 11 understand, who -- who's the relationship 11 A. I don't know. 12 between? 12 ். Who were you translating on behalf of? 13 MR. HENZY: It's between Melissa Francis 13 (Pause.) 14 and Ho Wan Kwok. 14 THE WITNESS: I don't really know. 15 BY MR. LUFT: 15 Mechanically -- you know. 15 ੁ. Okay. Is Ms. Francis your attorney? 16 I'm only given the job and then I listen 17 17 යි. No. to the file and then I produce the work 18 MR. LUFT: So I don't understand what the 18 product. I send it back and I get paid. To 19 privilege assertion is. 19 me, that's the end of it. 20 20 THE WITNESS: But anyway, no. BY MR. LUFT: 21 MR. HENZY: It's a privilege on Mr. Kwok. 21 ். Okay. So Mr. Henzy's firm was not 22 22 You can't violate attorney-client privilege. representing you at the time, correct? I mean, ====================================================================================================================================================================== 23 23 A. No, that's correct. 24 24 was acting as an interpreter at the ু. Okay. Can you please tell me about any 25 25 direction of counsel for Mr. Kwok, so communications you had with Ms. Francis with regard to Page 68 Page 69 1 1 - Highly Confidential - Highly Confidential 2 this communication other than the document she sent? 2 BY MR. LUFT: 3 3 MR. HENZY: Objection, privilege. I Do you know if you're testifying as a fact ं 4 4 instruct you not to answer. witness or an expert? 5 MR. LUFT: Eric, you can't introduce an 5 . ה I don't. 5 exhibit and put 5 MR. LUFT: Mr. Henzy, is & being put 7 of it and then say, "But I won't tell you 7 forward as an expert or as a fact witness in B ි anything said about it." You made the this matter? 9 choice. ్ర MR. HENZY: -------------------------------------------------------------------------------------------------------------------------------------------------------------------10 MR. HENZY: But you're not asking 10 witness, I think, primarily a fact witness. 11 question --11 I'm not going to say exclusively as a fact 12 MR. LUFT: Okay. 12 witness. 13 MR. HENZY: -- about what === said about 13 MR. LUFT: Well, we are entitled under 14 it or what ' did. the federal rules to know if 14 You're asking area question about what a 15 15 forward as an expert. 16 lawyer said to ો ર So I need you to tell me, because it's 17 17 communication. going to impact the questioning I have. 18 BY MR. LUFT: 18 MR. HENZY: They are going to be aspects 19 19 Let me ask you this, of testimony that maybe deemed to be ். 20 20 Are you here to -- are you testifying as a fact expert testimony. 21 witness or an expert witness in this matter? 21 MR. LUFT: In that case, there is no 22 MR. HENZY: Objection, asks for a legal 22 privilege and I'm entitled to ask 23 23 this. conclusion. I don't know how would know 24 that. 24 a testifying witness. I'm entitled 25 25 to know about opinions, what relied

1 Highly Confidential l Highly Confidential 2 upon, and the communications 2 What expert opinions are you prepared to ു. 3 connection with those opinions. 3 offer in this case? 4 MR. HENZY: That's not the question you 4 MR. HENZY: Objection, asks for a legal 5 asked, though. 5 conclusion. ு MR. LUFT: It 100 percent is. రా MR. LUFT: I'm entitled to know what -- 7 MR. HENZY: You didn't ask ﻟﺴﺎ going to be put forth as an expert,

్రం you rely upon. ్రం I'm entitled to know --

10 MR. HENZY: I mean, ask that, Avi, 10 BY MR. LUFT: 11 and then we can go from there. 11 Q. What expert opinions are you going to put 12 BY MR. ICFT: 12 forward in this case? 13 13 MR. HENZY: Objection, asks for a legal । ਹੈ ੇ.

். -- are you going to be offering expert she's going to be offering. 16 testimony in this case? 15 MR. LUFT: No, Eric. 17 MR. HENZY: Objection, asks for a legal 17 MR. HENZY: I'm not going to -- 18 conclusion. 18 I'm not -- you're right. I shouldn't 1 9 BY MR. LUFT: 1 9 tell you what question to ask. You're right. 20 You can answer. ். 20 MR. LUFT: More importantly, if you're 21 If the court wants me to say something, at 21 putting forward an expert witness, you have to 22 answer a question, I will answer a question. 22 disclose what expert opinions they have 23 I don't know whether I'm asked to -- to be an ਨ ਤੇ before -- at their deposition. 24 expert witness or whatever witness. I'm just here to ਨ ਜੋ MR. HENZY: So -- so you can ask

1 - Highly Confidential 1 - Highly Confidential

can 2 A. Well, that is to prepare for the case, right? 3 answer the question. 3 ੋ.

4 BY MR. LUFT: 4 ਕ . The court? 5 Q. Do you know what expert opinions you're going 5 ं. ్ర to be prepared to offer to the court in this case? ా Uh-huh . 4.

্রা 7 -- please tell me all expert opinions you ್ತ. interpreter/translator, and I've been in -- working as വ intend to offer at the hearing on Tuesday. ਜੋ an interpreter in court cases for over 20 years. 5 MR. HENZY: Objection, asks for a legal 10 So for that, if the court asks me questions about 10 conclusion. 11 interpretation, I would tell them what I think as an 11 THE WITNESS: I don't know. I am -- 12 experienced court certified interpreter. 12 whatever Court is asking me -- whatever -- 13 Q. And if the court chooses not to ask you any 13 Whatever question is asked of me at the 1 वें questions -- । Court hearing on Tuesday, I would answer them. 15 Uh-huh . ri, 15 BY MR. LUFT: 16 -- you're not prepared to offer any expert ्र ો ર So sitting here today you're not aware of any ். 17 testimony in this case? 17 expert opinions that you're planning to offer at the 18 MR. HENZY: Objection. । ਉ hearing -- 19 Asks for a legal conclusion. It's also । ਤੇ That's correct.

20 vague and ambiguous. 20 -- with respect to this contempt motion?

21 THE WITNESS: If the Court is not asking 21 That's correct. A. 22 me questions, why would I say anything? 22 MR. HENZY: Objection, asks for a legal 23 BY MR. LUFT: 23 conclusion. 24 Because I believe Mr. Henzy wants you to

Page 74 Fage 75 1 - Highly Confidential 1 Highly Confidential 2 BY MR. LUFT: 2 (Pause.) 3 3 Has Mr. Henzy asked you to offer any expert BY MR. LUFT: ். 4 opinions at the hearing on Tuesday? 4 Q. And sitting here today, you cannot identify 5 5 MR. HENZY: Objection, asks for a legal any expert opinions that you plan to offer to this Court 5 conclusion. 5 as testimony as the context hearing on Tuesday, correct? 7 7 THE WITNESS: Not specifically. MR. HENZY: Same objection. ు 8 ్ర BY MR. LUFT: THE WITNESS: That's correct. 9 ్ర BY MR. LUFT: Q. Has anyone from are Mr. Henzy's firm asked 10 you to offer any expert opinions at the hearing on 10 Okay. Other than the portion of the 0. transcript that Ms. Francis sent you, have you reviewed 11 11 Tuesday? 12 MR. HENZY: Same objection. 12 any other portions of the two days of 341 testimony? 13 THE WITNESS: No. 13 A. No. । ਪੈਂ 14 (Pause.) ू . Did you ever ask to review any other portions 15 BY MR. LUFT: 15 of it? । ਇ Has Ms. Francis asked you to offer any expert ાં ર A. ். No. 17 17 opinions --Have you ever listened to the audio of the ू. 18 18 ri No. rest of the 341 hearing? 19 19 д. ं। -- at the hearing on Tuesday? No. 20 20 MR. HENZY: Same objection. (Pause.) 21 THE WITNESS: No. 21 BY MR. LUFT: 22 22 BY MR. LUFT: ். Did anyone ever ask you to listen to any 23 ं. Has any counsel for Mr. Kwok asked you to 23 other portions of the audio of the 341 hearing? 24 offer any expert opinions? 24 A. No. 25 25 A. No. 0. Anyone ever ask you to look at any other Page 76 Page 77 1 1 - Highly Confidential - Highly Confidential 2 2 See, I work for cases, and -- and there are a portions of the transcript of the 341 hearing other than A. ധ 3 number of courts ... the portion that Ms. Francis had selected for you? 4 4 A. No. (Pause.) 5 5 THE WITNESS: Once a month. A case a (Pause.) ్ర 5 BY MR. LUFT: month. 7 7 BY MR. LUFT: 0. Have you ever acted as a Court interpreter? B Yes. ్రా When was the first time you worked with 料 0. 9 When? ું Mr. Kwok? 0. 10 10 (Pause.) (Pause.) 11 BY MR. LUFT: 11 THE WITNESS: I can't remember when was 12 And by that, I mean acting as the interpreter 12 the last hearing that I appeared as check ். 13 for a court. 13 interpreter for Mr. Kwok. 14 A. Yes. । ਪੈ BY MR. LUFT: 15 ். Yes? So I meant --15 ். Do you recall the first time you acted as an 16 ો ર র . Yes. interpreter for Mr. Kwok? 17 17 ் -Just clarifying. Sorry. A. That I remember, yes. 18 । ਉ A. Yes, throughout the past 20 to 30 years. 0. When was that? 19 1 કે I don't recall the specific time. It would ू . Okay. How often? ध्ये 20 20 More often 20 years ago, and less often the be ranging between 2016 to 2017. That was the first A. 21 recent 10 years, and less often the last year. 21 time. 22 ੁ. How often have you acted as interpreter for 22 Q. Okay, and other than serving as a check 23 23 the Court in the past 10 years? interpreter for Mr. Kwok in court proceedings, have you 24 A. How often? It's really hard to say. 24 ever worked as -- on behalf of Mr. Kwok in any other 25 25 ். Give me your best recollection. capacity?

At the early days, yeah. 2 MR. LUFT: Okay. 3 The first time I was -- I was referred to be an ు MR. HENZY: Work for him in any other ಗಿ interpreter for his conference. 4 capacity? You mean as an employee or 5 What conference is that? ் (JI MR. LUFT: Worked for him. I don't care ్ It was a conference supposed to happen -- A. 5 how characterizes it. 7 supposed to happen in Washington, D.C. However, it did -- J MR. HENZY: Okay. 8 not happen, but that was the first time I met him. ్రం THE WITNESS: Just conferences. 9 Are there any other times you've worked for ्र. 9 BY MR. LUFT: TD Mr. Kwok other than -- other than as a check interpreter 10 Q. What conferences have you worked for 11 in connection with court proceedings? 11 Nr. Kwok? 12 A. Yes. 12 A.

13 ். Please tell me about them. 13 Once a year, in the past, he had those । ਹੈ I worked as an interpreter for Mr. Kwok in a য় । चै anti-Communist Party conferences, and there would be 15 court case -- in a case regarding defamation. 15 kind of like several interpreters interpreting for those 16 Other than in connection with a court case -- ्रं 15 conterences simultaneously.

Uh-huh . 17 We would -- we would -- we would do those 18 -- have you ever acted as a -- worked for ः 18 conference interpreting -- simultaneous interpreting in 1 Mr. Kwok in any capacity -- 1 9 a conference setting. 20 A. As an -- 20 Anything eise?

21 Q. -- with the exception of the conference you 21 And the court defamation case and check A. 22 mentioned? 22 interpreting. 23 MR. HENZY: I'm just going to object. 23 Anything else?

24 Vague and ambiguous. I'm not trying -- ੇ 4 That's about it. A. 25 just -- 25 (Thereupon, an informal discussion was

1 - Highly Confidential l Highly Confidential 2 held off the record.) 2 A. res. 3 BY MR. LUFT: 3 Q. - When you say they hired you, they hired you 4 Q. What's your best estimate of how many times 4 to work on behalf of their boss, Mr. Kwok? న you've been hired by Mr. Kwok? 5 They hired me to work in an event, and those

I was never hired by Mr. Kwok. ರಾ event -- whatever it is, then that's the event.

Who hired you, then? 7 So let's take the defamation case.

B His office. rt, ్రాం Uh-huh . A. 9 What's Mr. Kwok's office? ் 5 Mr. Kwok is a party to that case? ்.

Say that again? 10 That's right. A. 11 What do you mean when you say, "Mr. Kwok's ். 11 And you were being hired by Mr. Kwok's staff ू. 12 office"? 12 to work on their boss' behalf?

His staff. 13 A. As an interpreter. 14 ். Who is on Mr. Kwok's staff? । ். Right. On behalf their boss, Mr. Kwok?

તાં 15 For Mr. Kwok.

16 Ms. Francis, and at the beginning of the conference, it ો રે Okay, and who paid you for your work on ். 11 was Ms. Wang. 17 behalf of Mr. Kwok? 18 Anyone else on Mr. Kwok's staff besides ் ાં કે A. In those time, Golden Spring. 19 Ms. Francis and Ms. Wang? । ਤੇ Did you have a contract with Golden Spring? ूँ. 20 That I have no idea. A. 20 A. No. No.

Are you aware of any other people who work 21 ். So how did you know that Golden Spring was 22 for Mr. Kwok other than Ms. Francis and Ms. Wang? 22 going to pay you for the work that you did on behalf of 23 I don't know them. ri 23 Mr. Kwok?

25 Q. When you say, "Ms. Wang," are you referring

25 I think it was the first time I was referred A. to by a fellow interpreter to work for Mr. Kwok's

న conference and -- because I was referred to and from a N Spring? 3 fellow interpreter, so if my colleague worked for him ు "Other work" meaning

ಗಿನ and got paid, then I think I will get paid. 4 Meaning like the defamation case for -- that ். 5 So when Mr. Kwok would have Golden Spring pay ﺮ ﺍ (၂) Mr. Kwok is involved in, right? ్ you -- న That was requested by Golden Spring, so

7 Uh-huh . A. 7 Golden Spring paid me. 00 -- for your work, how did they send you that ై. ్రం Q. Have you ever been paid for work you have 9 money? ್ತ done on behalf of Mr. Kwok by any entity other than 10 A. They mailed it to me. 10 Golden Spring?

By check? 11 A.

12 A. Uh-huh, yes. 12 Uh-huh . ். 13 ੇ. And whose account was that check from? 13 --- the court hearing, serve as check A.

Golden Spring. । पै interpreter, I was paid by counsel's firm. 15 Was there any ever -- any entity Mr. Kwok had

Are you being paid for your time today? TP you paid by other than Golden Spring for any of the work 15 Not -- not -- not here now.

17 that you did for him? 17 How about for Tuesday? Are you being ్ర. 18 (Pause . ) 18 compensated? 1 9 THE WITNESS: If I was contracted by or 1 9 A. les. 20 if I was requested by Golden Spring to do the 20 ੁ. Who is paying that? 21 work for an event, then I was paid by Golden 21 I expect to be, as you A.

And who is paying you for that? 23 BY MR. LUFT: ਨੌਤੇ Because it was requested by Zeisler, so I A. ਨ ਹੈ Q. And for other work you did for Mr. Kwok, cid ਨ ਜੋ will be sending my invoice to Zeisler, and I will expect 25 anyone ever pay you for that work other than Golden 25 Mr. Zeisler to pay me.

1 - Highly Confidential 1 - Highly Confidential

2 How about in connection for the work 2 ्रः More than \$50,000? 3 Ms. Francis sent you the translation work, who will pay 3 That I cannot be sure. A. 4 you for that? 4 More than \$50,000, potentially? ். 5 I send the invoice to Zeisler, too. A. 5 See, the thing is I have to ask you make a

్ర ். Can you give -- ் division. Fifty thousand divide by one thousand, how 7 Can you tell me how much money you've earned work ﻟﺴﺎ many events? ന്ന for Mr. Kwok since the first time you started working 8 Because I remember events. I don't really remember ਿੰ for him up through today? 5 the number -- you know.

I have not tallied up. 10 From 2016 until today -- ். 11 What's your best estimate? ू - 11 Uh-huh .

12 (Pause . ) 12 -- anyone you've worked with more often than ். 13 THE WITNESS: It was hard to say, really. 13 Mr. Kwok? 1 पे I -- I -- । Much more. A. les. 15 I can't, because at the early days, I did 15 ूं. How many other clients do you have? 16 a number of conferences for him, and that was ો રે A. I have a lot of clients. 17 good. Nowadays, not that many, so 17 2. Do you ever serve as interpreter for Mr. Kwok 18 BY MR. LUFT: 1 8 in connection with his business meetings? 19 Do you think you've earned more than \$10,000

No. 20 work for Mr. Kwok? 20 How about when Mr. Kwok is talking to

21 A. From -- since 2016 or 2017? 21 Ms. Francis? Who is interpreting for them? 22 ੰ. les. 22 A. I have no idea.

24 More than \$20,000? ్లు ટેને Ms. Francis? Have you ever seen him talking to 25 Yes . A. 25 Ms. Francis?

I may have. I can't remember specifically. 2 ். How often?

Did you have to interpret for them? 3 He spoke with his counsel sometimes with ዳ .

No. 4 broken English. 5 Were they just talking in English, so it ు 5 For how -- and they would be talking about

్ర wasn't necessary? 5 legal matters? 7 (Pause . ) -- J No, I don't think so. When talking in legal ् प्रदेश के साथ की में बाद में कि में बाद में कि में में में में में में में में में में में में में में में में में में में में में में में में में में में में में में में ్రం THE WITNESS: I'm trying to remember ్రం matters, I would be interpreting. 9 whether I was there any time. I don't know. 9 But otherwise, he speaks to counsel in broken ். 10 BY MR. LUFT: 10 English? II Q. How about when Mr. Kwok talks to other people 11 Like "How are you?" That kind of thing. 4. 12 in English? Does he ask you to help him out with words? 12 ் How conversant is he in English? 13 A. When he met with counsel, then I interpret 13 A. I have no idea. । ਹੱ for him. । चै ੁੰ. From -- based on your observations? 15 Okay, but when he's talking to other people

16 15 answered. in English, does he ever ask you to help him with words 17 1 / that he doesn't know in English? (Pause . ) 18 MR. HENZY: Object. I'm not sure 18 THE WITNESS: He's okay, 1 9 testified -- 1 9 conversationally, with casual matters. 20 BY MR. LCFT: 20 BY MR. LUFT: 21 You can go ahead. Please answer. ் 21 Have you ever received a check from any

22 A. I don't interpret for him in English outside 22 entity other than Golden Spring or the Zeisler firm in 23 from court cases. ਨਤੇ connection with your work on behalf of Mr. Kwck? 24 Have you ever heard Mr. Kwok speak English?

25 A. Yes. 25 THE WITNESS: Golden Spring and Zeisler.

1 Highly Confidential 1 Highly Confidential 2 Brown Rudnick, most recently. That's it. 2 Krasner? 3 BY MR. LUFT: (ఎ A. Max Krasner? No.

્ર . 4 How about Aaron Mitchell? ੁ. 5 Mr. Kwok? 5 I saw him in court, and he would tell me if

No. ் Mr. Kwok is going to be there late or he's there or 7 Okay. When Mr. Kwok has a job for you -- ાં આવેલા ગુજરાત રાજ્યના ગુજરાત રાજ્યના ગુજરાત રાજ્યના ભ ﻟﻪ، ﺍ something like that.

A. ్రాం Daniel Podclski?

9 -- how does he communicate that to you? ं 5 He was around when there was -- when I was A. 10 Mr. Kwok never communicated with me and it में . म्प्र, मिमी, में में में में में में में में में में में में में में में में में में में में में में में में में में में में में में में में में में में में में में मे 10 working in those conference. 11 is -- it's not his job. Ms. Wang would tell me to 11 What's the relationship like

12 interpret for Mr. Kwok's conference. 12 MR. LUFT: Let me strike that. 13 Q. When you say it's not Mr. Kwok's "job," what 13 BY MR. LUFT: 1 में do you mean by that? । What's Ms. Wang's job for her boss, Mr. Kwok?

15 I mean I don't -- at conferences, I don't વ્યું 15 A.

16 really interpret for -- by his side. It's a conference. ો મે MR. HENZY: Objection, lack of 17 You know, it's an event, so I would interpret in that 17 foundation. 18 conference. । ਉ THE WITNESS: I don't really know. I 19 ြဲ 19 only get the request to interpret. Okay. How about when you're acting as a 20 BY MR. LUFT:

Right, and Ms. Francis would tell me the time and the date and the venue -- 22 Q. But you understand that Ms. Wang works for

22 Un-huh . 23 A. Yes.

25 -- and I would be there. A. Q. Did you ever have any communications with Max 24 25 ू . -- correct? A. Yes.

1 - Highly Confidential l Highly Confidential 2 Do you ever see Mr. Kwok give her directions? ् . 2 If I were the check interpreter, yes, I will A.

I did not see personally. 3 expect to be paid. 4 Have you ever worked for any other members of ் 4 Are you going to be Mr. Kwok's check ். 5 Mr. Kwok's family as an interpreter? (11 interpreter at the hearing on Tuesday?

That's what I thought I was going to be. 7 (Pause . ) ﻟﺴﺎ When you say that's what you thought you were

్రం BY MR. LUFT: ్రా going to be, what do you mean?

ు ್ತ Because before you ask me the question

10 What compensation have you been told you will 10 whether I'm going to be testifying on Tuesday, and I did not know that I was. 11 receive for any testimony you give in this case? 11

You mean here, now? For this -- 12 So I -- my whole -- my whole understanding was that 13 ੋਂ. For -- 13 I would be the check interpreter for that hearing.

-- or anything? । पै So this is pretty surprising to you today,

15 ్ర. For anything -- 15 huh?

No. ો ક Like I said, it may not have registered with

17 -- related to this contempt motion. ் 17 me. Maybe it was mentioned. It's -- it's just I did 1 8 No. I give testimony in court or I -- a 18 not catch it. I thought that's only today, so yeah. 1 When I'm deposed, when it is a court case, I don't 1 9 Q. - Will you be paid a thousand dollars for your 20 know that should be compensated. 20 work on Tuesday?

் 21 Well, it depends on the time. If it is a A. A. A. A. 22 Yeah. A. 22 whole day, yes. ട്ടെ -- you are not expecting to be compensated? ். ਨ ਤੇ If not, do you have an hourly rate?

24 A. Not as a witness. ਨ ਜੋ If it is falling into -- within four hours, A. 25 ். What are you expecting to be compensated as? 25 that will be a half day rate.

2 Which is \$500? 2 A. ्रं Uh-huh, yes.

3 A. No. 3 ें. Where? 4 ੋ.

England. 5 Do you have to ask me my rate? Really? A. 5 And what did you study? ू . ్ర ்.

I got a bachelor degree in translation in 7 Do I have to say that? র্ম - Westminster University, England. ട്ട് MR. HENZY: You have to say it, yeah. ಕಿ In connection with the work you've done in

9 THE WITNESS: Money should not be talked ੋਂ this matter -- 10 about in public. Anyway, 600. 10 Uh-huh . A. 11 BY MR. LUFT: 11 -- what -- what scholarly texts did you

12 Q. Okay. Are you owed any money by Mr. Kwok on 12 consult in forming -- in performing your work? 13 behalf of the work you've done for him to date? 13 I haven't consulted any scholarly work.

1 में I haven't sent any invoice for today, so no. Air and Air Air Air Air Air Air Air Air Air Air Air Air Air Air Air Air Air Air Air Air Air Air Air Air Air Air Air Air Air Air Air Air Air Air Air Air Air Air Air Air Air A । ் Have you reached out to any other experts in 15 Q. How about for the work you've been doing up 15 the field to consult with regard to any opinions you may JE until today? ો રે have in this matter? 17 I was not owed any money. में . 17 A. No. 18 ੇ.

Can you describe for me the methodclogy you । ਉ (Pause.) । ਤੇ used in connection with your work in this matter? 20 BY MR. LUFT: 20 A. .

21 Q. Do you have any -- can you tell me what your 21 transcribed the English part of the statements word by 22 highest -- 22 word, and then I translate the Chinese words into 23 MR. LUFT: Let me strike that. 23 English and recorded them in my work product.

25 BY MR. LUFT: Q. Can you tell me -- did you go to college? 24 25 Do you have copies of that work product that

you created?

l Highly Confidential 1 Highly Confidential న No. I don't have it with me. යු 2 preparation for that hearing? 3 Do you have it at home? ू . 3 The 341? ዳ . 4 I have it at home. র . 4 I attended some meetings between Mr. Kwok and the 5 MR. LUFT: Okay. 5 counsels, but I cannot recall specifically what -- what

I would like to request copies of that meetings -- you know, what subject matters were

work ---------- -- J discussed. ్రం her opinions as well. ్రా Do you recall if there was any discussion of ुं. 9 THE WITNESS: Sorry. But -- didn't -- 9 Ace Decade -- 10 Wasn't that the one that you were talking 10 MR. HENZY: Objection. 11 about before? Are you talking about something 11 THE WITNESS: No. 12 else? I haven't done any -- 12 BY MR. LUFT: 13 BY MR. LUFT: 13 -- at that meeting? ்.

No. 15 You're referring to just the documents you provided 15 MR. HENZY: Objection. Move to strike. 16 to Ms. Francis? 15 Objection, attorney-client privilege. I 17 ਕਿ . Right. 17 instruct her not to answer.

Okay. There's no other drafts? 18 MR. LUFT: Mr. Kwok's privilege now 1 A. No. 19 belongs to Mr. Despins on that issue. 20 There's no other work product? ్ర. 20 (Thereupon, an informal discussion was 21 ਕਿ . No. 21 held off the record with the shorthand

22 Okay. Prior to the 341 hearing, were you

23 involved in the preparation for it? ਨਤੇ MR. LUFT: Mr. Kwok's privilege with ਨ ਹੈ A. No. ੇ ਪੈ regard to any work in connection with his 25 ். Did you meet with counsel and Mr. Kwok in 25 bankruptcy proceeding with Brown Rudnick now

2 belongs to Mr. Despins. 2 Probably between counsel's meeting. A. 3 (ఎ What's your best recollection of what you ু. 4 MR. HENZY: I answered the question.

BY MR. LUFT: heard discussed about Ace Decade prior to the 341 5 5 hearing? ్ర Q. Do you recall any discussion at the UBS ் I don't recall. 4. 7 litigation? 7 After the -- immediately after the 341

9 Any discussion about lawsuit in the United ां ್ತಾ A. Uh-huh . 10 Kingdom? 10 -- did you have any discussion with anyone ்.

What? 11 with regard to the topic of Ace Decade? 12 ். A lawsuit in the United Kingdom? 12 द्वों No. 13 (Pause.) 13 Did you have any conversation with anyone ू. 1 वें THE WITNESS: Counsel, my memory at the । ਉ with regard to the question of mistranslation with 15 moment is quite muddled. 15 regard to any questions about Ace Decade? JE I remember a lawsuit in the United ો ર Not after departing from the courtroom.

17 Kingdom mentioned, but probably in court, so I 17 Upon leaving the 341 hearing, did you tell

18 cannot recall exactly -- you know. 18 anyone that there were material misstatements made in 19 BY MR. LUFT: । ਤੇ the translation with regard to Ace Decade? 20 Okay. Prior to hearing the name Ace Decade

Un-huh . ra, MR. HENZY: Objection. Ambiguous, vaque.

23 ੂ. -- had you ever heard that name before? 23 I probably would have said something

25 A. I might have.

25 like -- like -- like a tirade -- you know.

Page 98 Fage 99 1 - Highly Confidential 1 - Highly Confidential 2 BY MR. LUFT: 2 Do you have any of the notes that you took 0. 3 3 I'm asking you if you have a specific during Mr. Kwok's 341 hearing? ं 4 recollection now of what you think you might have said. 4 A. No. 5 5 Do you recall anything --ू . What happened to those notes? 5 5 A. No. Just discarded it. A. 7 7 --- about any mistakes with regard to any When did you get rid of them? ். ். ు ్ర testimony as to Ace Decade? When the book is finished. Then I'll just --ત્વં 9 9 No. I might have said something, but I don't I use steno pad, so when the pad is full, then I'll just A. 10 recall what I said. 10 discard them. 11 11 Do you know when you discarded your notes (Pause.) ः 12 BY MR. LUFT: 12 with regard to the 341 hearing? 13 13 Okay. When you're translating, do you wait (Pause.) : । ਪੈਂ 14 until the speaker is done with their question to start THE WITNESS: It could be that day or it 15 translating, or if it's a long question, do you make 15 could be out of the next meeting, because --। ਇ them pause a translate a portion of the question and ો ર because --17 then do another portion? 17 I don't use one notepad for one case, so 18 ାସ୍ I usually wait until the question's asked 18 it's continuous, so I actually can't recall 19 19 completely. Then I start to -- to interpret it. when I discarded that. 20 BY MR. LUFT: 20 Q. Do you take notes while the questioner is 21 21 Did anyone from Mr. Kwok's counsel ask you speaking? ् 22 22 科。 Yes. for copies of your notes with regard to any 23 ். When you're acting as a check interpreter, do 23 translations? 24 you take notes? 24 A. No. 25 25 A. Yes. ். Did anyone from Mr. Kwok's counsel tell you Page 100 Page 101 1 1 - Highly Confidential - Highly Confidential 2 2 that after the 341 hearing, that they wanted to see your want me to give you examples? 3 3 notes because they were concerned about the issue of You want me to tell you what kind of 4 4 mistranslations? context -- give -- like lay out a scenario or 5 No. 5 A. what ? ర్ రు BY MR. LUFT: ं Did Mr. Kwok tell you that he wanted you to 7 7 speak with his counsel with regard to the issue of 0. Let me ask it a different way. B ြိ mistranslations? Uh-huh . A. 9 网 No. ్ర You said you have to consider context. 0. 10 10 0. Did anyone acting on behalf of Mr. Kwok talk A. Yes . 11 to you about the fact there were mistranslations at the 11 ू . Why do you have to consider context? 12 hearing that action should be taken about after the 12 科 Well, if it's just a line of questions, then 13 hearing concluded? 13 you have already interpreted previous questions and 14 A. No. । ਹੈ then -- so the context is naturally following, right? 15 ். Okay. When you're translating --15 I mean, but if they are stand-alone questions, 16 ો ર র . Uh-huh . then -- then there is no context involved. 17 17 ੋ • -- do you consider the context of the ਂ At the 341 hearing --18 । ਉ cuestion? A. Uh-huh . 19 1 કે -- the translator was sworn in to tell the 网 Yes . ें • 20 20 truth, correct? How so? ். 21 Well, I think it has to be considered, right? 21 A. Yes. A. 22 But you're asking me -- I don't know how to answer this 22 0. As the check interpreter, you are not sworn 23 question, actually. 23 in, correct? 24 (Pause.) 24 д. I think we were. I think all interpreters 25 THE WITNESS: When you say, "How so," you 25 are sworn.

Page 102 Page 103 1 - Highly Confidential 1 Highly Confidential 2 Okay. I guess we can look at the transcript 2 @question, you would neither pass a note nor make a 3 later, but your recollection is you were sworn in as a 3 statement, correct? 4 translator at the 341 hearings? 4 5 decident THE WITNESS: Most probably, that's 5 A. I don't recall, but because there are times 5 6 come a correct. that -- as check interpreters, we would be sworn in, 7 too, at court and at depositions. 7 BY MR. LUFT: 8 So I may not have a clear recollection whether I 8 Q. Okay, and then here, Mr. Kwok would give an 9 was sworn in at that specific court hearing, but as an 9 answer in Chinese -10 interpreter, we -- we -- we know we're always acting 10 Land A. H. Yes. 11 under oath of our professional oath. 11 ---- Q. " -- and then the translator would translate 12 Q. Okay, and at the 341 hearing, a question 12 Mr. Kwok's answer to English --13 would be asked in English -13 - A. A. Yes. 14 Q Q -- correct? 14 - 15 - Q. - -- correct? 15 - A. Yes. 16 A. A. Yes. 16 - Q. And if you believed the translator made an 17 Q Q -- and then you would hear the Chinese ll "error in connection with translating Mr. Kwok's answer 18 translation? 18 into English --19 News A. A. 19 - A. A. Yes. |20 Q. And as the check interpreter, if there was a |20 Q. -- you would again either make a statement on 21 problem with that question, you would either let 21 the record or pass Mr. Baldiga a note telling him that 22 - Mr. Baldiga know through a note or you would make a 22 - there was an error, correct? 23 statement, correct? 23 A. A. Most probably, yes. 24 - A. A. Yes. 24 Q. I'm going to hand you copies of what I am going to mark as Exhibit 2 and 25 - Q. And if there was no problem with the 25 Page 104 Page 105 1 1 - Highly Confidential Highly Confidential 2 2 Exhibit 3. transcripts? 3 3 (Thereupon, two documents were marked by I don't know. A 4 4 the shorthand reporter as ूं. Okay. Do you want to take a second to look 5 5 and through the documents and see if you've seen any portion 5 రు MR. LUFT: Exhibit 2 will be a transcript of these documents before? 7 7 MR. HENZY: Do you want to point of telephonic 341 meeting of creditors, March B 21, 2022 In Re: Ho Wan Kwok. ్రా the portion that you're probably --9 At the same time, I will also ask to mark ్ర MR. LUFT: What I'm interested in is if 10 a copy of Exhibit 3, which is a transcript of 10 seen -- look, if you want to --11 continued 341 Meeting of Creditors, April 6, 11 I'm trying to give your witness the 12 2022 In Re: Ho Wan Kwok. 12 opportunity to look at it. If you don't want 13 MR. HENZY: Thank you. 13 to, she doesn't have to. 14 BY MR. LUFT: । ਪੈ MR. HENZY: 15 ். do you have what has been 15 (Pause . ) 16 marked as [REDACTED] Exhibit 2 and [REDACTED] Exhibit 3 in 16 THE WITNESS: Right. I think it's the --17 front of you? T T I have seen a portion of the transcript 18 A. Yes. 18 of the April 6th meeting. 19 19 BY MR. LUFT: ਼. Have you ever seen either of these documents 20 20 before? Okay, and what portion of that have you seen? ் 21 A No. 21 (Pause.) 22 22 THE WITNESS: Sixty-one. Page 61. Let ਂ. Have you ever seen portions of these 23 23 documents before? me see. 24 A. I have seen a portion of a transcript before. 24 (Pause.) 25 25 ். Do you know if it's one of these two THE WITNESS: Page 60, 61.

l Highly Confidential l Highly Confidential న (Pause.) 2 From the few pages that Ms. Francis shared ું. 3 THE WITNESS: Sixty-two. I think it's 3 with you -- 4 about that. 4 A. Right. 5 BY MR. LUFT: 5 -- what else do you have a clear recollection ். ్ Q. Okay, so page 60 through 62 are the cnly 5 of from the 341 hearing? 7 pages of the transcript that you've seen before? Pages 7 I don't have any specific recollection of the

్రం 60 to 62 -- ్రం 341 meeting except there were a lot of chaotic moments 9 I think so. A. 9 and my dis- -- dissatisfaction of the situation caused 10 And those are the portions Ms. Francis shared

11 with you? 11 There is a general recollection of what -- what -- 12 A. Yes. 12 what that day -- of that day, but I don't have any other 13 Other than the -- those portions of the ﺰﻳ 13 specific recollection. । ਜੋ transcript -- । चै Okay. Let's look at Exhibit 2. I will ask

15 Uh-huh . A. 15 you to first turn to page 31 and 32. 16 -- can you tell me what else where your ੁੰ. 16 31 and 32?

17 memory's been refreshed, what else you recall about the 17 And I'll direct you specifically to the ్ర. । questioning from the 341 hearings? 18 bottom of page 31 that carries over to 32. 19 MR. HENZY: Objection, vague and 1 9 Do you see, on the bottom, it says "Mr. Baldiga: 20 ambiguous. 20 Our interpreter believes that the response was that if 21 THE WITNESS: So you're asking me apart 21 he had a role at Golden Spring" -- do you see that? 22 from the -- 22 A. Uh-huh, yes. ನಿತ BY MR. LUFT: ਨਤੇ Are you the interpreter Mr. Baldiga is

Apart -- ੇ 4 referring to there? 25 A. 25 I believe so. A. -- from the transcript?

1 Highly Confidential 1 Highly Confidential 2 Q. Would this have been an instance where you 2 page 45. 3 passed Mr. Baldiga a note and that's how he knew you had (ఎ Do you see in the middle of the page, line 16, دلار an issue? 4 Mr. Baldiga says, "There's a translation issue"? 5 (Pause.) 5 Page 35?

్ర THE WITNESS: Probably. ు ். Page 45. 1 BY MB, IUFT: 7 র্ন . On. ട് Q. Okay. If I turn to page 33, turn to line 12, 8 Line 16 ். ் Mr. Baldiga says, "Hold on. There's a mistranslation 5 (Pause . ) 10 there." 10 THE WITNESS: Yes. 11 Do you think that's another instance of you passing 11 BY MR. LUFT: 12 Mr. Baldiga a note? 12 And again, do you believe that's one of the

13 (Several people enter the conference 13 instances where you passed Mr. Baldiga a note to express 1 में room.) । your concern about the translation? 15 MR. BASSETT: Let's go off the record. 15 A. Yes. 16 MR. HENZY: Sorry about that. ો ર Okay. Page 54. If you look at line 7, ். 17 THE VIDEOGRAPHER: The time is 11:15 a.m. 17 Mr. Baldiga -- this is Bill Baldiga. 18 We're going off the record. ાં કે "I'm sorry. I think there was a translation 19 (Recess taken at 11:15 a.m.) । ਤੇ issue." He goes on. 20 (Resumed at 12:03 p.m.) 20 Is this another instance where you would have 21 THE VIDEOGRAPHER: The time is 12:03 p.m. 21 passed Mr. Baldiga a note where you had a concern that 22 We're back on the record. 22 there was a translation issue? 23 BY MR. LUFT: 23 A. Yes.

் 24 And to be clear, I don't mean to imply that ். 25 showed you was on page 33. I will ask you to turn to 25 I'm being comprehensive here with regard to all of

1 Highly Confidential l Highly Confidential న these. I'm just citing examples to understand. N Q. -- I cid not -- I didn't find any -- that's 3 Un-huh . кі n not to say there is not -- there may not be one, but

4 Turn to page 59. ் ਲ ਕੀ I -- I welcome you to look. I did not see any 5 (Pause . ) 5 references to private interpreter speaking or someone ్ BY MR. LUFT: 5 with your name speaking. 7 Q. Do you see, line 7, "Mr. Baldiga: We have a -- J Does that comport with your recollection that at 8 translation issue. Hold on one second. I think our 00 the first 341 hearing, Mr. Baldiga was making the 9 interpreter is hearing this translation." 9 objections and you were not speaking?

11 ਕੇ . les. 11 THE WITNESS: I have no recollection of

You are the interpreter he's referring to? 12 what happened --

les. 13 BY MR. LUFT: । ਹੈ And you would have passed Mr. Baldiga a note? ू . ાં તે ू. Okay. 15 દિ. les. 15 -- and I assume when he said the A. 16 And this deposition was -- this -- sorry. ू. 16 interpreter's -- you know, raising issue, and since I 17 This hearing was conducted remotely? 17 did not speak, I assume that I was handing him the note, 18 নি .

19 ्. I'm asking. 19 That is my assumption -- 20 I don't. A. 20 ੂੰ . Okay.

Do you recall? 21 -- but I have no recollection one way or the A. 22 I don't remember. A. 22 other what happened.

். 23 Can I take you -- ask you to take a moment --

ਨ ਹੈ transcript -- ੰ ਜੋ A. Right. 25 Uh-huh . A. 25 -- and look at Exhibit 2 and see if you can

1 Highly Confidential 1 Highly Confidential ಿ find any reference to you actually speaking on the 2 there was a portion of the transcript of the 341 3 record as opposed to Mr. Baldiga just making objections 3 hearing, excuse me, where you were passing Mr. Baldiga

Probably. ్ర THE WITNESS: Counsel, you're asking me ు -- in connection as opposed to when you made ். 7 to look through the document to see whether - a decision to start making -- speaking verbally B there was any part of it that where it ్రార yourself? 9 mentions "private interpreter"? Is that what 5 A.

11 BY MR. LUFT: 11 It's quite puzzling to me because it's quite unlike 12 Q. Correct. When I looked through this 12 me that I would not raise any oral issue, just handing 13 document, I didn't see any reference to you. I could 13 him notes without -- you know, ever at one minute raise 14 have missed one. । ਪੈ a dispute. 15 I'm asking for you -- not that you have to look 15 It could be that I was just not recorded. I don't 16 line listened by line -- ો છ know. Sometimes it was a decision made by court 17 Uh-huh . র্ম 17 reporting. 18 -- but if you could just give a quick ் । ਉ Q. So you believe you may have spoken but the 19 once-over and see if it -- if you see any reference to 1 ਤੇ court reporter just didn't take down what you said on 20 statements by yourself in the transcript from March 20 the record? 21 Sometimes decisions were made that since the A.

21 21st. 22 A. Right. I flipped through it briefly, and I 22 private interpreter is not an official interpreter, so 23 don't see myself mentioned. 23 the dispute raised was not recorded.

25 Okay, so based on that and your -- do you

think -- does this comport with your recollection that 24 25 Sometimes like that. It could be like that. I don't know. I don't see myself there (indicating). It

న could be that I just hand him notes. 2 BY MR. INCET: 3 But I just find that sometimes that if I handed him ప Do you see, in the middle of the page and on

ಗಿ so many notes, it would be quite unlike me that I did 4 next page, there are multiple references to "the private 5 not raise any verbal dispute -- oral dispute, yeah. 5 interpreter"? ్ర Do you see on the front cover of this

les. / document, it says "Transcript prepared by Christine ﻟﺴﺎ Is that you?

00 Fiori"? ్రం MR. HENZY: Sorry. You're -- 9 Uh-huh . A. 9 MR. LUFT: Six and seven, Eric, middle of 10 THE SHORTHAND REPORTER: "Yes" or "no"? 10 the page and then the next page. 11 THE WITNESS: Yes. 11 MR. BASSETT: Exhibit 3. It might be 2. 12 BY MR. LUFT: 12 MR. HENZY: Oh, I'm on Exhibit 2. Sorry. 13 Q. Let's take a look at Exhibit 3, which is the 13 THE WITNESS: Yes. । ਹੈ April 6th hearing. । ने BY MR. LUFT: 15 Do you see on the front cover of this transcript it 15 Okay. Are you the private interpreter that

16 was also prepared by Christine Fiori? 18 is being referenced? 17 යි. Right. 17 A. res.

். 1 9 Yes. A. 19 Where it says "the private interpreter, " those are 20 ു. Same person, correct? 20 your statements, correct? 21 A. res. 21 A. Yes. 22 Okay. Now, if we turn to page 10 of this

Okay, and if I turn to page 10, do you see 23 transcript -- or let's first go to page 6. ਨੌਤੇ there is a back and forth with regard to a translation ਨ ਹੈ (Pause.) ੰ ਜੋ between you and the official interpreter? 25 25 A. Yes.

1 Highly Confidential 1 Highly Confidential

் 2 A. res.

And you want to correct it? دلو A.

les. 5 ். And you agree, correct? 5 Another example, page 39. Do you see page

్ర A. । ਦਿੰਦੇ : ் 39, line 15? 7 Then if you go to page 16 -- to page 13,

Are. B again, at the top of the page, you raise an objection ్రం ு. ஒ

ਿੰ with regard to the interpreter? 150 authority to enter into financial transactions on behalf 10 Yes .

11 And then, if we go to page 16, you have ्र. 11 And you raise an issue, saying, "No, no. That's 12 another lengthy objection? 12 not the question, " correct?

Yes. 13 It appears so.

1 वे So clearly, on this day the court reporter ुं. । ਪੈ Q. So where you thought that there was a problem 15 was taking down your statements, correct? 15 with the cuestion, you let the court reporter know that 1 P les. મે 16 it had -- and the translator that it had been

And to the extent you had objections, you 17. mistranslated, correct? 18 were saying them on the record, correct? 13: I believe so.

19 res.

ू . 20 Okay, and if we go to pages 21 through 22, ் 20 Did you say 52 or 62? A. 21 same thing? You're making objections on the record? 21 Sixty-two, ਂ.

les. 22 We see, again, when you had an issue with a 23 And the reason you're making these objections ் 23 question, you raised it on the record and it's recorded

25 is because you think there's been a mistake made in the

ವಿನ as "the private interpreter, " correct? A. Based on what it appear [sic] here, yes.

Q. If I turn to page 60, there is no reference 2

to any statements by you taking the issue - with taking

BY MR. LUFT: 4 Issue with any translations, correct? 4

A. A. Un-huh. That's correct, here. This is the 5

part that is the chacs.

-- if you heard on the audio recording things

anything, correct?

that were said that were not included in the record,

would you have included them?

A. Yes. and a record. 1875 Q. So to the extent on your translation there is

BY MR. ILFT:

no reference to any objection coming from you, that's

13 C. And if I turn to page 61, again, no reference 13 based on your listening to the audio and finding in fact to you raising any objection to any translation issues, । मै you made no oblection, correct?

A. Can you repeat that question? 16 Not on the record here on this transcript. 15 Sure. If I was to look at the document you ू. Q. And as we talked about on page 62, when you 17

lo had an objection, it was recorded on the record, 18 A. Yes.

contect? Let me be clear.

ू . A. A. On this record of this page, yes.

A. res.

(Pause.) To the extent you heard something on the

audio that was not accurately recorded on the

transcript, you would have included it in the document

you created for Ms. Francis, correct?

A. Yes.

Q. So to the extent I look at the document you 2 Would you look at page 61? Mr. Baldiga make

3 created for Ms. Francis and there is no reference to you 3 any objection with regard to the translation at your making an objection with regard to the translation, it's ਹੈਂ behest?

safe to say that when you listened to the audio, you did

Not in here.

not hear yourself make any such objection, correct? ్ర Did he make any objection to the translation

்.

at all?

A. Not that appears here.

I may have handed a note, though.

Q. Okay. In your translation that you did for

So on this page, you may have reversed course

Ms. Francis, if there is no reference to Mr. Baldiga and all of a sudden started handing Mr. Baldiga a note

in the middle of this?

Uh-huh . A.

MR. HENZY: Objection to the form of the -- is it safe to say that when you listened

ूं.

question. It's argumentative. to the audio, you did not hear Mr. Baldiga make any

THE WITNESS: Probably. objection?

BY MR. LUFT:

If I did not recall that, that's correct, प्रदर्शन की में बाद में कि में बाद में कि में बाद में कि में बाद में कि में बाद में कि में बाद में कि में बाद में कि में बाद में कि में बाद में कि में बाद में कि में बाद मे

Q. - You recall handing Mr. Baldiga a note? 17 then he did not make any.

I actually recall that I handed in notes to

Mr. Baldiga around that time. I don't know exactly

BY MR. LUFT:

Q. If I could ask you to pull back Exhibit 1 --

Exhibit 1 -- which is the debtor's objection,

turn again to page 11 and go back to that first

sentence.

"At any hearing on the motion, the debtor will put

No.

on testimony from an interpreter as to the many material

1 Highly Confidential l - Highly Confidential న deficiencies in the official translation of the 341 2 . And if we look at pages 60 and 61 of the 341

3 meeting." hearing, you made no objection to any material 4 Do you see that? deficiency in the translation, correct? 5 Uh-huh, yes. ব, Can you say that again?

్ Okay. I believe you've testified that other ့ Sure. / 7 = If you turn to Exhibit 3 and look at pages 60 and than the portion of the transcript that Ms. Francis sent ్రా you, you have not looked at the reference the 341 8 61 -- 3 hearing; is that correct? A. Page 60 to 61? 10 That's correct.

11 Q. I believe you testified with the exception of 11 - WH THE WITNESS: Yes. 12 the transcript that Ms. Francis sent you where she 12 BI FF. DOHY 13 refreshed your recollection, you have no specific 13 There is no record of you making any । ਜੋ recollection of any specific mistakes made in the 14 - statement or objection to any purported material 15 translation from the 341 hearing, correct? lo deficiency in the translation on page 60 or 61, correct of

ਸ਼੍ਰ 15. 15 A. Not purportedly. 17 Not specifically, but I remember there were 1978 - Q. All right. 18 mistakes made. 18 There's no reference to you making any such 19 Q. But you don't recall what they were? 19 cobjection at all, correct? 20 That's correct. में . 20 A A. Not on this record. 21 So other than those pages that Ms. Francis ் 21 Q. And if I looked at your transcript and there 22 sent you, which is 60 to 62, you have no recollection, 22 is no reference to you making such an objection, that 23 sitting here today, of any specific material deficiency ನಿತ means -- when I say, "your transcript," I mean the one 24 in the official translation of the 341 meeting? ੇ ਜੋ you prepared for Ms. Francis. 25 Not specifically. A. 25 If there is no reference to you making any such

1 Highly Confidential 1 Highly Confidential 2 objections on pages 60 and 61, then based on your 2 ் Okay. 17 re-listening to the hearing, you did not hear yourself 3 (Pause.) ਪ੍ਰ make any objection to any alleged material deficiency -- 4 BY MR. IUFT: 5 A. Not -- 5 Q. Now, if we look back at Exhibit 1, on the ్ర -- in the transcript?

7 A. -- verbally. 7 MR. LUFT: Actually, strike that.

Right. ﻟﻠﺘﺮﺍ BY MR. IUFT:

-- what do you mean? 10 Can you look at Exhibit 3? ್ತು.

ਸ਼ੁੰ 11 Other than pages 60 and 61 and 62, sitting here 12 transcript. 12 today, can you tell me of any other material deficiency 13 I don't hear myself, so I could not transcribe 13 in the translation that you're aware of other than in an 1 ने what -- motions or actions -- you know, so no, I did not 14 instance where you made an objection on the record or

15 record any oral objection that I raised, because I did asked Mr. Baldiga to do so? 16 not make any oral objection or disputes. ો રે As I'm sitting here today, I have not looked A. 17 Okay, and if there is no reference to ் 17 through any pages except page 60 to 62. 18 Mr. Baldiga making any objection to any translation for ાં કે I cannot say specifically what material mistake 19 any reason, including because you've told him to do so । ਤੇ that was -- that were recorded or that were made. 20 as we saw him do multiple times previously -- 20 ் Okav. 21 Uh-huh .

22 -- then you did not hear any objection by Mr. ். 22 BY MR. LUFT: 23 Baldiga with regard to any of the testimony on pages 60 ನ ನ Can I ask you to turn to Exhibit 2?

That's correct.

1 Highly Confidential 1 - Highly Confidential

3 First, turn to page 12. ं 3 Did I read that correctly? 4 Do you see on line 8, it says "Other names I 4 A. les.

who is an 5 And there's no objection to the translation ். ్ర interpreter. 5 by you there? 7 Do you believe that is a reference to you? ﻟﺴﺎ र्य, No. ్రి Yes. Can -- am I looking at the same page? ్రా No objection by Mr. Baldiga? ். 3 MR. HENZY: Go ahead, Avi. Go ahead. 9 ਕਿ . No. 10 Page 12? 10 Do you have any reason to believe that any ു. 11 BY MR. LUFT: II portion of that transcript was mistranslated by the 12 It's Exhibit 2. ੰ. 12 translator? 13 MR. HENZY: Exhibit 2. 13 A. No. । ਹੈ BY MR. LUFT: । चै ੁ. Okay . 15 Page 12, line 8 through 10.

16 મ .

17 Great. Okay. Can you turn to page 49? Do

18 you see, starting at line 5, it says: 18 question. It's okay. 19 "Mr. Kwok, who are the owners of Golden Spring? 19 (Pause.) 20 "Answer: My son. 20 BY MR. LUFT: 21 "Are there any owners of Golden Spring other than 21 Something else you wanted to add?

22 your son? 22 A.

23 "No. ਨੌਤੇ MR. HENZY: Well, now he's asked a 24 "Mr. Kwok, have you ever owned an interest in ੰ ਕੇ question, so you can. 25 Golden Spring? 25 THE WITNESS: No. I mean, he --

3 Mr. Baldiga was -- some -- saying 2 but not too far. I'm going to ask you to turn back to 4 something on line 16, right?

A. OI? 5 Q. Right. He's talking about some type of 5 -- of Exhibit 1. Sorry, ma'am. ूं. ్ర physical security concerns -- 5 (Pause . ) 7 On. ি : 1 BY MR. LUFT:

-- right? ్రి Q. Do you see it says, second line of the --

Right. 5 complete line of the page: 10 ். It's not any objection to the translation -- 10 "As an example, while the 'official' translation of 11 ਕ: Okay . 11 the April 6, 2022 341 meeting has the debtor answer "no" 12 -- correct? ੂ. 12 in response to the U.S. trustee's question, are there 13 Okay.

14 ुं. Do you agree with me? । ਪੈ Just prior to that question, according to the 15 产。 Agreed. 15 official translation, the debtor reportedly answered the 16 Okay, so you have no reason to believe that ां 16 U.S. trustee's question "Are you the only legal owner of 17 the translator did not translate the portion I read to 17 Ace Decade?" by stating that he was a legal representing 18 you perfectly, correct? । ਉ owner.

Correct . 1 ਤੇ Do you see that?

Okay. 20 A. res. 21 (Pause.) 21 I'm just asking you about the translation,

22 BY MR. LUFT: 22 when you went over that part. This is part of the

் ನ ನ portion you looked over for Ms. Francis, correct? 24 I'm going to ask you to keep out Exhibit 3 and 24 res. A. 25 Exhibit 1. You can put Exhibit 2 to the side for now, 25 The question was correctly translated to the ்.

న debtor. "Are there any other owners of Ace Decade, " 2 When you say, "purportedly, " what do you ். 3 correct? That was correctly translated? 3 mean? 4 (Pause . ) 4 A. Because it's written in here (indicating) . 5 BY MR. LUFT: ("U Okay, but when you did your analysis -- ். ా If you want, I can turn you to Exhibit 3, if

Right. 7 it's helpful. This is coming from page 61, I believe. -- J ்.

్రం Say that again. What page, again? ਸ . ్రా Okay. If that appears on -- on mine, yes.

9 ். I believe this is page 61. ್ರ ்.

10 A. Sixty-one . 10 (Thereupon, an informal discussion was 11 I believe we're looking at -- lines 6 and 7, ். 11 held off the record with the shorthand 12 I believe, is what the debtor's counsel was cuoting. 12 reporter. ) 13 (Pause . ) 13 BY MR. LUFT: । ਹੈ BY MR. LUFT: । चै Sitting here today, do you recall if that ். 15 Sorry. Not six and seven. ். 15 line was correctly translated? 16 No, that's correct. Six and seven, I believe is 15 I don't recall when I'm sitting here that

17 what's being referenced in that paragraph. 17 that line was correctly translated.

Sixty-one? 18 Sitting here today, do you have a

19 2. Do you see line 6, "Are there any other 19 recollection of the translation you did with regard to 20 owners of Ace Decade ? 20 page 60 and 61? 21 "Answer: No." 21 A. No. 22 Do you see that? 22 So it I was to look over pages 60 and 61,

23 A. I see that. ਨੌਤੇ sitting here today, Icoking at the transcript, you could 24 ். And that was correctly translated, right? 24 not tell me which lines were correctly translated in 25 A. Purportedly, yes. 25 your opinion and which lines were not?

2 A.

Sitting here today, I -- I am unable to say A. 3 ். Okay . 3 whether it was properly translated. 4 (Pause.) 4 Q. So you cannot tell me if you are offering any న BY MR. LUFT: 5 expert opinion with regard to whether that line was ్ర The next line on Exhibit 1 says "The debtor's ் ் properly translated? 【 interpreter will testify, however, that the proper ﻟﻤﺪﻳﻨﺔ ﺍﻟﻤﺘﺤﺪﺓ ﺍﻟﻤﺘﺤﺪﺓ ﺍﻟﻤﺘﺤﺪﺓ ﺍﻟﻤﺘﺤﺪﺓ ﺍﻟﻤﺘﺤﺪﺓ ﺍﻟﻤﺘﺤﺪﺓ ﺍﻟﻤﺘﺤﺪﺓ ﺍﻟﻤﺘﺤﺪﺓ ﺍﻟﻤﺘﺤﺪﺓ ﺍﻟﻤﺘﺤﺪﺓ ﺍﻟﻤﺘﺤﺪﺓ ﺍﻟﻤﺘﺤﺪﺓ ﺍﻟﻤﺘﺤﺪﺓ ﺍﻟﻤﺘﺤﺪﺓ ﺍﻟﻤﺘﺤﺪﺓ ﺍﻟﻤﺘﺤﺪﺓ ﺍﻟﻤﺘﺤﺪﺓ ﺍﻟﻤﺘﺤﺪﺓ ﺍﻟﻤﺘﺤﺪﺓ ﺍﻟﻤﺘﺤﺪﺓ ﺍﻟﻤﺘﺤﺪ MR. HENZY: Objection. That's -- that ി interpretation of the debtor's response to U.S. ്വാ was not testimony. ் trustee's question 'Are you the only legal owner of Ace 5 BY MR. INFT: 10 Decade?' was 'I am legally representing the owner.' '" 10 That's my question to you. ். 11 did you tell counsel for the debtor 11 Without any material help me, I cannot just

12 that that is what you were going to testify to the 12 rely on my recollection to tell you that that was 13 court? 13 properly translated or not. 1 पें I did not tell that to anyone. No one asked A. । ਪੈ Okay. I have provide you the transcript,

15 me that question. 15 correct? 16 Okay. ्र ો ર This is a transcript, yes (indicating). You A. 17 (Pause.) 17 have provided me with this transcript, yes, appeared 18 BY MR. LUFT: ાં કે before me. । ਕੇ Now, I believe that is a reference to lines 3 City 19 I'm asking: ू . 20 through 5 of page 61. Do you see that? 20 Sitting here today, can you tell me if you're 21 Yes. A. 21 planning to offer any opinion with regard to whether the 22 It says "Are you the only legal owner of Ace ் 22 question "Are you the only legal owner of Ace Decade?" 23 Decade ?!! 23 was properly translated into Chinese at the time by the 24 Sitting here today, do you recall if that question 24 official interpreter? 25 was properly translated into Chinese? 25 MR. HENZY: Objection, argumentative.

1 Highly Confidential 1 Highly Confidential 2 THE WITNESS: I cannot offer an expert N ደር

3 opinion or professional opinion whether this ప without, I should say. 4 was properly translated (indicating) just 4 MR. HENZY: I think you said not without. 5 based on this transcript before me, without 5 MR. LUFT: That's what I heard.

్ any other audio file or to -- to -- to -- to help. MR. HENZY: That's what I heard, too. 7 BY MR. LUFT: 7 MR. LUFT: I'm not following along with ్రం Q. Okay, and if I look at next line, the answer ్రం the realtime. Okay. ੇ "I am a legal representing owner," sitting here today, 9 (Pause . ) TD can you tell -- tell me if you're offering any expert 10 BY MR. LUFT: IT opinion with regard to whether that sentence was 11 Sitting here today, can you tell me, if I was

12 properly translated into -- by the official interpreter? 12 to look at lines 3 through 10, what you believe in your 13 MR. HENZY: Objection. Vague, ambiguous. 13 opinion the proper translation of those lines should । ਹੈ THE WITNESS: No, I cannot, without any । पै have been? 15 audio file to assist. 15 A. No, I can't. 16 BY MR. LUFT: ો ક ू. Okay. 17 Q. So sitting here today, you cannot tell me if 17 (Pause.) । ਉ you plan to offer any expert opinion with regard to 18 BY MR. LUFT: 1 lines 3 through 5 of page 61 of the April 6th 341 ો કે Q. It I ask you to look at page 60, line 16, do 20 transcript? 20 you see it says: 21 Not without the audio file to cross-reference A. . 21 "Question: Mr. Kwok, do you own any interest in a 22 with this transcript. 22 company called Ace Decade Holdings Limited?

ਨ ਹੋ BY MR. LUFT: ੇ ਹੋ Do you see that? 25 ். Okay. 25 I see that. A.

1 Highly Confidential 1 Highly Confidential 2 And there's no objection from you to that ் 2 And sitting here today, to your knowledge,

3 question? న you cannot tell me if you know that there is anything 4 A. Not appear to be. 4 wrong with the question and answer at line 16 through 18 5 ். No objection from Mr. Baldiga, correct? 5 on page 60? ్ర A. Not appeared to be, yes. ் I'm unable -- I am unable to tell you whether

7 Sitting here today, can you tell me if you ાં આવેલા ગુજરાત રાજ્યના ગુજરાત રાજ્યના ગુજરાત રાજ્યના ભ 1 there is anything wrong with it. ന്ന plan to offer any expert opinion as to whether that ു Q. And same thing with regard to lines 3 through ੀ question and answer on page 60 of the transcript that is ﻟﻠﺘﺮﺍ 10 on page 61? 10 Exhibit 3 was correctly translated? 10 A. Same thing happen with those lines. 11 (Pause.) 11 MR. LUFT: Okay. Let's take a break real 12 THE WITNESS: I can't without the audio 12 quick and see where we are. 13 file. 13 THE VIDEOGRAPHER: The time is 12:39 p.m. । पै (Pause.) । We're going off the record.

17 Q. Okay. When was the last time you listened to the audio file? 17 (Resumed at 12:48 p.m.) THE VIDEOGRAPHER: The time is 12:48 p.m. 18 A. । ਉ We're back on the record. That portion of the audio file that was given 1 ਤੇ 大 19 to me by Ms. Francis -- MR. LUFT: Okay. 20 The last time I listened to it was the date I 20 I am going to renew my 21 worked on it and it would be the day or several days 21 request for the emails you described between 22 before I sent it back to her. 22 yourself and Ms. Francis and any other counsel 23 Q. Did anyone play that audio file for you in 23 representative of Mr. Kwok.

25 preparation for this deposition? No.

25 And I'm going to reserve right to ask you additional questions if I'm provided those

న documents, which I should be, but other than 2 MR. LUFT: Objection, foundation. 3 that, I have no further questions for you at 3 BY MR. HENZY: 4 this time. 4 Okay, but -- you can answer, but -- ு. 5 THE WITNESS: You are asking me -- 5 A. I don't know. ్ MR. HENZY: You don't need to answer. న Okay. Okay. Did -- ್ತ. 7 THE WITNESS: Okay. I just have a couple ﻟﺴﺎ Do you know whether she ever was, in fact, an 8 questions. ్రా employee of Mr. Kwok? 9 MR. LUFT: Okay. 9 MR. LUFT: Objection, leading. 10 10 THE MITNESS: I don't. I only assume. 11 CROSS-EXAMINATION 11 MR. HENZY: Okay. I -- okay. That's

13 13 BY MR. HENZY: । ਹੈ Q. Mr. Luft asked you some questions about । चै Just -- can you look at Exhibit 2 and Exhibit

15 whether Yvette Wanq was an employee of Mr. Kwok. When 15 37 16 was the last time Yvette Wang called you about a job? 15 (Pause . )

වි අධි 17 BY MR. HENZY: 18 े. More than two years ago? 18 Q. On Exhibit 2, on the very first page, if you 19 A. Probably. 19 go to the -- where it says -- do you see where it says 20 Okay. More than three years ago? ். 20 "Transcript of Telephonic 341 Meeting of Creditors"? 21 I cannot be certain. A. 21 Yes, I see it. A. 22 Okay, but -- but -- okay. ் 22 Okay. Do you see where it says "Telephonic"? ். 23 Do you have any knowledge of whether or not ਨ ਤੋਂ A. Yes. 24 Ms. Wang is an employee of Mr. Kwok today? ਟ ਕੇ ् . Okay. Then, go to Exhibit 3. 25 I don't know. A. 25 Uh-huh . A.

1 Highly Confidential 1 Highly Confidential 2 It says "Transcript of Continued 341 Meeting c 2 job, then you assume she's the staff of that office, 3 of Creditors"? રે right? 4 A.

That office is Golden Spring?

At the time, I believe so. ్ర A. les. రు And Mr. Kwok's the head of Golden Spring, so ். 7 It doesn't say "telephonic" there, correct? ್ತು. ri it makes sense, right?

Correct. 00 I don't know. ને . 9 MR. LUFT: Leading. 9 But you said she works for Mr. Kwok. Is the ். 10 MR. HENZY: Okay. I don't have anything 10 job for him? 11 further. 11 Because that conference was a conference

12 MR. IUFT: Okay. 12 of -- of a subject that is Mr. Kwok's. It -- it -- 13 13 that -- the conference is about anti-Chinese Communist 1 पे REDIRECT EXAMINATION । ਉ Party, so that is Mr. Kwok's subject. 15 BY MR. LUFT: 15 And then I was engaged to be his interpreter, so I 16 ો છ assumed she was from his office, and I don't know 17 2. Ms. Wang, why did you assume -- sorry. 17 anything other than that. 18 why did you assume Ms. Wang is an । ਉ Q. At the conference, who else did you meet from 19 employee of Mr. Kwok? । ਤੇ Mr. Kwok's office? 20 She called me for -- to be -- to do the A. 20 But that conference did not take place. A. 21 interpreting for the event, so -- 21 At any of the other conferences you worked,

22 Q. Why -- why did that lead you to believe that 22 who else from Mr. Kwok's office did you meet? 23 she worked for Mr. Kwok? 23 I don't meet with anyone.

25 Well, she's in that office, I assume. So A. she's calling for -- well, when someone calls you for a 24 25 ்.

A.

2 -- from Mr. Kwok's office? ் 2 Mr. Kwok, correct?

A. 3 A. At the time, yes. 4 I met with some other people, but I don't know ಿ

5 whether they are from his office. I went to conference. questions. ్ I went to my booth. I sat down. I did my job. రా THE VIDEOGRAPHER: This concludes today's 7 Q. Who sent you the checks from Golden Spring ﻟﺴﻨﺔ ﺍﻟﻤﺴﺘﻮﻯ ﺍﻟﻤﺴﺘﻮﻯ ﺍﻟﻤﺴﺘﻮﻯ ﺍﻟﻤﺴﺘﻮﻯ ﺍﻟﻤﺴﺘﻮﻯ ﺍﻟﻤﺴﺘﻮﻯ ﺍﻟﻤﺴﺘﻮﻯ ﺍﻟﻤﺴﺘﻮﻯ ﺍﻟﻤﺴﺘﻮﻯ ﺍﻟﻤﺴﺘﻮﻯ ﺍﻟﻤﺴﺘﻮﻯ ﺍﻟﻤﺴﺘﻮﻯ ﺍﻟﻤﺴﺘﻮﻯ ﺍﻟﻤﺴﺘﻮﻯ ﺍﻟﻤﺴﺘﻮﻯ ﺍﻟﻤﺴﺘﻮﻯ ﺍﻟﻤﺴﺘﻮﻯ ﺍﻟﻤﺴﺘﻮﻯ ﺍﻟﻤﺴﺘﻮﻯ ﺍﻟﻤﺴﺘﻮﻯ ﺍﻟﻤﺴﺘﻮﻯ deposition of 00 when you worked for these conferences? ్రం The time is 12:53 p.m. We're off the 9 You know, I actually did not look at the A. A. ್ರಿ record. 10 signature. 10 (Thereupon, the deposition concluded at 11 And when you had a job -- needed a job, it

12 was always Ms. Wang who would contact you? 12 (The exhibits were retained by the 13 At the beginning, for the conferences. स्वं, 13 shorthand reporter to be attached to the । ਹੈ ். So if it was a legal matter, Ms. Francis -- ાં તે transcript.) 15 A.

-- the general counsel of Golden Spring, 16

19 -- to act on -- to act on behalf of Mr. Kwok?

20 To be the interpreter for the -- for the

21 deposition or for the court hearing. 21 22 For -- for Mr. Kwok?

A. For Mr. Kwok, yes. 24 And if it was nonlegal work, then Ms. Wang

25 was the one who would make the request on behalf 25

ACKNOWLEDGMENT OF DEFONENT i--- Highly Confidential

4 do hereby certify that 3 I, CHERYLL KERR, CSR, a Certified Shorthand 5 the foregoing testimony given by me on ಿನ್ Reporter and Notary Public, do hereby certify November 11, 2022 is true and accurate, ﻨﺎ that the witness whose deposition is hereinbefore 0 including any corrections noted on the ೆ set forth was duly sworn by me, and that such 7 7 deposition is a true record of the testimony given ്റാ corrections page, to the best of my knowledge 8 by such withess. and belief. ੈ। I further certify that I am not related to

10 10 any of the parties to this action by blood or 11 marriage; and that I am in no way interested in 11 12 - the outcome of this matter. 12 1 3 IN WITNESS WHEREOF, I have bergunto set my

1 ਹੋ 14 - hand this 12th day of November, 2022. At =========================================================================================================================================================================== 15

17 of --------------------------------------------------------------------------------------------------------------------------------------------------------------------------- 17 CHERYLL KERR, CSR

18 truth of the foregaing corrections by her subscribed. 19

21 Betore me, ------------------------------------------------------------------------------------------------------------------------------------------------------------------- 22

2 ERRATA SHEET FOR THE TRANSCRIPT OF:

Deponent: 6 - Reason codes: 7 1. To clarify the record. రూ 2. To conform to the facts. 3. To correct transcription errors. 10 Pg.

25 (Notary Public) My Commission Expires:

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aware 46:4 73:16 believes 107:20 casual 87:19 Claiborne's 35:25 80:21 125:13 belongs 95:19 96:2 catch 91:18 claim 14:19 Bill 109:17 catching 45:10 claiming 32:14 ్రామ bit 30:11 34:10,25 46:12 clarify 25:22 44:4 bachelor 93:6 block 49:19 caught 45:7 46:4

back 24:17 25:15 book 99:8 caused 107:9 classic 67:3

45:11.15 53:5 57:11. booth 142:6 certified 72:7,12 clear 30:15 35:6 24 58:2 60:2,12,15 boss 81:4,14 89:14 chance 24:20 36:23 48:22 50:4

24 67:18 108:22 boss 81:12 chaos 47:21 118:6 109:24 119:19 115:23 121:20,22 bottom 107:18.19 chaotic 34:10,25 client 19:9 21:22

136:22 137:18 break 10:5,14 21:18 35:13,20,21 36:4,14 63:12,13,14

63:12,13,14 73:10.

confidential 6:1 7:1.

100:17 101:4.9.11.

confusing 34:10 correct 60:16 67:22.

discarded 99:6,11, electronic 56:20 examii

discussed 95:7 97:4 employee 79:4 60:18

disregarding 41:2 enter 108:13 117:9 13 128

11 62:9,12,15,18,25 Entry 21:3 22:8 expert

24 71:

134:2.

earlier 126:5 events 85:7,8 fact 9:

filed :

25 117:3,12,17,24 118:4,5,8,15,19 119:14,24 120:6,7 121:16 122:9,10,15, 20 123:4,15,19 124:25 128:12,18,19 129:23 130:3.16 133:15 136:5 140:7,8 143.2

correctly 127:3 129:25 130:3,24 131:15,17,24 136:10

counsel 6:15 8:3 11:18 24:20 25:17 26:15,19,23 27:18 28:24 29:10 31:20, 21,23 33:5 34:15 40:22 43:9 63:23 66:25 74:23 86:13 87:3,9 94:25 96:14 99:21,25 100:7 112:6 130:12 132:11 137:22 142:16

counsel's 15:23 16:2.18 17:12 18:10 33:4 63:22 83:14 97:2

court 6:14 7:6 8:16 10:21 20:19 23:23 30:9 41:5 46:2 70:21 72:6,7,9,10,12,13,21 73:4,12,14 75:5 76:7, 13,23 77:23 78:11, 15,16 79:21 80:15 83:13 86:23 89:5 90:18,19 96:17 102:7,9 113:16,19 116:14 117:15 132:13 142:21

current 26.23 D D.C. 78:7 Daniel 89:8 date 14:3 27:4 36:7 37:4 47:5 88:22 92:13 136:20 dated 56:23 Dawn 39:10 40:3,7

day 34:10,24 49:10 55:6 64:8,15,16,23 91:22,25 92:4 99:14 107:12 116:14 136:21

days 62:21 65:19,20 75:12 78:2 84:15 136-21

debtor 21:4 22:8,13 26:8,15,19 121:24 129:11,15 130:2 132-11

debtor's 21:2 22:7 26:6,22 42:6 121:21 130:12 132:6,8

Decade 39:9 40:3,7 46:15 52:9,15 53:15 95:9 96:20 97:4.11. 15,19 98:8 129:13,17

deficiencies 22:15 23:8 25:18 26:3,9,16, 20,24 27:20 28:15 127.7

deficiency 27:25 28:6 34:7 122:23 123:4,15 124:4 125:12

deposition 6:4,6 7:4, 12,18 8:24 15:13 31:19 32:25 38:12 41:23 57:5 71:23 110:16 136:24 142:21 143:7,10

e 21:4 22:9 ්‍ර 91:24 iarity 9:25 y 19:12 90:5 23:19,25 al 56:2 69:14 31:13 v 81:25 82:3 93:15 85:6 7:8,24 58:5,7 7 134:6,15,21 13,17,18,23 58:19 60:17 cial 117:9 33:24 111:2 2 114:3 ig 119:13 8:9 9:15 10:3 5 19:22 33:14,16 ග 21:19 ed 99:8 114:8,16 17:2,4,15,17,18 3 27:13 57:8 2,24,25 67:21 83:14 87:22 8:23 d 112:22 6:7 v 15:23 16:2,6, 7:12 18:10 33:3 t 11:17

grounds 32:7 102:9,12 107:6 highly 6:1 7:1,14,16 hourly 91:23 instructed 18:7 quess 61:8 102:2 110:9,17 111:8 113:3 8:1 9:1 10:1 11:1 hours 91.24 instructing 12:22, 114:14 121:24 122:9, 12:1 13:1 14:1 15:1 23,24 17:24 32:15 guys 56:5 59:25 15 123:3 124:3 16:1 17:1 18:1 19:1 60:10 61:13 142:21 20:1 21:1 22:1 23:1 anda instruction 15:23

ﺍﻟﻤﺘﺤﺪﺓ ﺍﻟﻤﺘﺤﺪﺓ ﺍﻟﻤﺘﺤﺪﺓ ﺍﻟﻤﺘﺤﺪﺓ ﺍﻟﻤﺘﺤﺪﺓ ﺍﻟﻤﺘﺤﺪﺓ ﺍﻟﻤﺘﺤﺪﺓ ﺍﻟﻤﺘﺤﺪﺓ ﺍﻟﻤﺘﺤﺪﺓ ﺍﻟﻤﺘﺤﺪﺓ ﺍﻟﻤﺘﺤﺪﺓ ﺍﻟﻤﺘﺤﺪﺓ ﺍﻟﻤﺘﺤﺪﺓ ﺍﻟﻤﺘﺤﺪﺓ ﺍﻟﻤﺘﺤﺪﺓ ﺍﻟﻤﺘﺤﺪﺓ ﺍﻟﻤﺘﺤﺪﺓ ﺍﻟﻤﺘﺤﺪﺓ ﺍﻟﻤﺘﺤﺪﺓ ﺍﻟﻤﺘﺤﺪﺓ ﺍﻟﻤﺘﺤﺪﺓ ﺍﻟﻤﺘﺤ 32:1 33:1 34:1 35:1 idea 12:7,12 19:3 18:11

41:19 42:3 102:4 36:1 37:1 38:1 39:1 32:12 63:10 80:20 instructs 9:17 half 61:12 91:25 92:4 106:18 40:1 41:1 42:1 43:1 85:22 87:13 intend 59:3 73:8

103:24 114:2 held 6:6 12:9 16:10 48:1 49:1 50:1 51:1 104:5 intended 59:15 21:9 39:13 54:10 52:1 53:1 54:1 55:1 identify 75:4 intention 19:24 20:6, handed 34:15,18,19 80:2 95:21 131:11 56:1 57:1 58:1 59:1 11,12 40:22 114:3 120:9,18 helpful 31:17 130:7 60:1 61:1 62:1 63:1 identities 59:18 handing 28:24 30:12 64:1 65:1 66:1 67:1 immediately 55:20 interest 126:24

10:25 11:4,22,25 68:169:1 70:1 71:1 97:7 135:21 120:11,17 12:14,16,24 13:3,11, 72:1 73:1 74:1 75:1 interested 105:9 15,18,22,24 14:9,12, 76:1 77:1 78:1 79:1 impact 69:17 internal 62:11 Hang 23:16,18 14,18,21,22,24 15:3, 80:1 81:1 82:1 83:1 imply 109:24 happen 30:2 53:9 5,6,7,9,15,17,18,25 84:1 85:1 86:1 87:1 interpose 9:13 78:6,7,8 137:10 16:7,12,15,21 17:5,8, 88:1 89:1 90:1 91:1 92:1 93:1 94:1 95:1 importantly 71:20 interpret 37:17 53:12 happened 31:7 35:2 23 18:7,20 19:5,19, 96:1 97:1 98:1 99:1 improper 15:13 86:3,13,22 88:12,16, 48:16 51:8,11 52:20 21 20:3,6 21:11,15, 100:1 101:1 102:1 58:25 17 89:19 98:19 53:9 99:5 111:12,22 21 22:3,22,24 24:10 103:1 104:1 105:1 include 42:11 45:20 25:11 32:2,5,8,11,18, 106:1 107:1 108:1 interpretation 35:24

happening 28:21 23 33:8,11,16 44:18, 109:1 110:1 111:1 included 45:18 132:8

53:18 24 49:7,15,22,25 112:1 113:1 114:1 119:8,9,23 55:21,24 56:10,13, 115:1 116:1 117:1 including 28:8 Interpreted 37:16,19 hard 10:21 35:3 47:2 19,25 57:19 58:18 59:4,8,17,20,23 60:5, 118:1 119:1 120:1 124:19 41:8 45:25 46:6 53:5 49:22 76:24 84:13 9 61:8, 19 64:12 66:5, 121:1 122:1 123:1 incorrectly 46:15 101:13 Hastings 6:17,21,23 13,21 68:3,10,13,22 124:1 125:1 126:1 interpreter 22:14,19 69:6,9,18 70:4,7,10, 127:1 128:1 129:1 Independent 48:3 24:3 26:8,11 27:23 head 8:15 51:3 141:6 17 71:4,9,13,17,24 130:1 131:1 132:1 133:1 134:1 135:1 54:6 29:15 35:22 37:15 headquartered 6:12 72:18,24 73:9,22 136:1 137:1 138:1 indicating 113:25 39:2,4 40:25 41:2,5 hear 43:13 102:17 74:3,5,12,20 75:7 139:1 140:1 141:1 131:4 133:16 134:4 45:6,23 52:21,25 120:6 121:14 124:3, 78:23 79:3,7 86:18 142:1 143:1 indistinguishable 64:15 66:24 67:7 13,22 87:15 89:16 92:8 18:2 49:24 61:14 72:9,12 76:7,12,22

95:10.15 96:3 97:21 Hills 11:17 14 81:13,25 82:3 heard 27:24 28:6, 16 104:13 105:7,14 hired 80:5,6,7 81:3,5, informal 12:8 16:9 83:14 85:17 88:20 49:20 51:3,4 86:24 106:19 108:16 115:8, 11 21:9 39:12 54:9 90:5 91:2,5,13 98:23

126:9,13 127:17,23 Ho 6:5,18 66:14 79:25 95:20 131:10 101:22 102:10,20 126:5 135:5,6 133:7,25 134:13 104:8,12 information 42:10 107:20,23 110:9,12 hearing 19:25 20:17 135:4,6 138:6,12 initially 14:13,22 111:5 112:9 113:22 22:13 23:7,13 24:23 139:3,11,13,17 hold 31:11 33:20 17:16 115:5,15,19,24 116:9 26:7 27:19 29:7 36:5, 140:10 66:23 108:9 110:8 117:24 121:25 126:6 6,8,9 42:14,17 47:5 Holding 21:3 22:8 instance 34:6 108:2, 132:7 133:24 134:12 50:13 56:9 60:6,22 Henzy's 12:4,6 17:2, Holdings 135:22 11 109:20 125:14 141:15 142:20

19:4,9,13 27:13 instances 109:13 interpreter's 39:17 77:12 83:13 91:5,13 67:21 74:9 home 94:3.4 45:9 53:21 111:16 94:22 95:2 96:20,21 hoping 29:13 Instruct 15:10,19

97:5,8,17 99:3,12 highest 92:22 95:17 interpreter/ 100:2,12,13 101:17 hour 61:12 translator 72:8

55:18.23 56:18 57:2.

135:5,7,10,18 136:15 20 31:16 33:21 34:2,

ﺔ ﺍﻟﻤﺴﺘﻘﻠﺔ ﺍﻟﻤﺘﺤﺪﺓ ﺍﻟﻤﺘﺤﺪﺓ ﺍﻟﻤﺘﺤﺪﺓ ﺍﻟﻤﺘﺤﺪﺓ ﺍﻟﻤﺘﺤﺪﺓ ﺍﻟﻤﺘﺤﺪﺓ ﺍﻟﻤﺘﺤﺪﺓ ﺍﻟﻤﺘﺤﺪﺓ ﺍﻟﻤﺘﺤﺪﺓ ﺍﻟﻤﺘﺤﺪﺓ ﺍﻟﻤﺘﺤﺪﺓ ﺍﻟﻤﺘﺤﺪﺓ ﺍﻟﻤﺘﺤﺪﺓ ﺍﻟﻤﺘﺤﺪﺓ ﺍﻟﻤﺘﺤﺪﺓ ﺍﻟﻤﺘﺤﺪﺓ ﺍﻟﻤﺘﺤﺪﺓ ﺍﻟﻤﺘﺤﺪﺓ ﺍﻟﻤﺘﺤﺪﺓ ﺍﻟﻤﺘﺤﺪﺓ ﺍﻟ lay 21:17 101:4

49:19 95:13 97:2 99:15 104:7.11 105:18 107:8 122:3, 24 129:11 139:20 140:2

mentioned 36:20,21 38:11 62:4 78:22 91:17 96:17 112:23

mistranslated 34:20 note 28:24 29:9 117:17 127:11 54:16,20 56:19 mistranslating 102:22 103:2,21 mistranslation

37:2.13 38:2 43:23.

16 49:10 50:18 51:4.

notes 29:22 30:12.22 31:7,8 33:18 40:22 62:14 98:20,24 99:2, 5,11,22 100:3 113:4, 13 114:2,4 120:18

number 28:21 35:2, 25 38:3,7 40:14,18 45:11 53:18 77:3 84:16 85:9

objection 9:13,14,19 12:18 14:14.15 15:7, 14,19 17:5,6,9,23 19:5,19 20:3 21:2 22:7,22,24 32:2 34:13,15,17,18,21 42:6 49:7 50:2 68:3, 22 70:17 71:4,13 72:2,18 73:9,22 74:5, 12,20 75:7 87:15 89:16 95:10,15,16 97:21 106:19 116:8, 12 118:14,18 119:12, 14 120:4,6,13,23 121:3,6,11,15,21 123:3,14,19,22 124:4,15,16,18,22 125:14 127:5,8 128:10 133:7,25 134:13 136:2,5 139:2,9

objections 20:8 owners 126:19,21 33:25 34:15,18,20 32:21 111:9 112:3 129:13 130:2,20 116:17,21,23 124:2 P obligated 56:8 108:3,12 109:13,21 110:14 111:17 120:9, observations 87:14 p.m. 108:20,21 obstructing 32:24 137:13,15,16,17 notepad 99:17 143:8,11 offer 17:22 23:6 71:3 72:6,16 73:8,17 74:3, pad 99:9 10,16,24 75:5 133:21 pages 47:14,17 134:2,18 136:8 106:7 107:2 116:20 offered 18:5 122:21 123:2,7 124:2,23 125:11,17 offering 23:12 70:15 131:22 71:15 133:4 134:10 paid 63:21,25 64:18 office 80:8,9,12 67:18 81:16 82:4,16, 140:24 141:2,4,16, 21 83:7,8,14,15 91:3, 19,22 142:2,5 19 official 22:15 23:8 paragraph 7:10 26:9,16,24 27:22,25 22:20 130:17 28:10 35:21 113:22 115:24 122:2.24 part 44:12 47:19 129:10,15 133:24 55:5,6 93:21 112:8 134:12 118:6 129:22 once-over 112:19 parts 50:6 58:13 opinion 44:16 71:14 party 67:3 79:14 81:9 131:25 133:5,21 141:14 134:3,11,18 135:13 pass 103:2,21 136:8 passed 29:9 108:3 opinions 69:25 70:3 109:13,21 110:14 71:2,11,22 72:5 73:7, 17 74:4,10,17,24 passing 29:21 30:22 75:5 93:15 94:8 108:11 113:3 opportunity 105:12 past 27:11 76:18,23 79:13 opposed 112:3 113:6 Paul 6:17.20.23 oral 113:12 114:5 pause 11:23 13:25 124:15,16 14:4 16:24 17:20 18:24 19:15 22:4,21 order 7:11 21:3,5 25:20 27:2,7,16 22:8,10 59:24,25 28:17 30:3 34:22 60:13,17 36:15 38:24 42:22 owed 92:12,17 46:21 48:17 52:13 54:22 56:12,17 63:6, owned 126:24 18 64:24 65:6,18 owner 129:16,18 67:13 73:24 74:14 132:9.22 133:22 75:2,20 76:5,10 77:4, 134:9 10 82:18 84:12 86:7 87:17,24 90:7 92:19 owner.' 132:10 96:13 97:20 98:11,16

99:13 100:24 103:4 17,24 31:6 34:25 proceeding 95:25 rate 64:16 91:23,25 105:15,21,24 106:2 35:11 41:4,17 45:14, proceedings 77:23 Q 92:4.5 108:5 109:9 110:5 16 53:10,14,23 105:7 78:11 re-listening 124:3

118:9,21 119:2 portion 44:10,14 question 9:2,5,9,18, reach 14:12 121:18 123:10 125:3. 46:11,20 50:11,16,21 produce 56:8,20

8,21,24 127:15,19 54:4.13,25 55:9 20:14.16 21:12.19.

75:10 76:3 98:16.17 produced 55:20 57:5 33:13 36:18 37:18 read 42:6.13.16.18. 13 132:4,17 134:23 104:24 105:5,8,17,20 119:17 39:3,16 46:18 49:15, 19 43:5 47:24 48:12 135:9,17 136:11,14 113:2 122:7 127:11 producing 59:2 17 53:2,3 65:7 68:11, 50:17.21 51:3.4.6.7. 139:12.16 128:17 129:23 product 58:2,3 62:5 15 70:4,22 71:9,19, 19 127:3 128:17 pay 18:13,19,23 136:18 65:5,17,25 67:18 25 72:3 73:13 91:9

63:17 64:6 81:22 portions 75:12,14,23 93:23,24 94:20 16 100:18,23 102:12, real 137:11 82:5,25 83:25 84:3 76:2 104:22 106:10, production 55:21,25 21 103:2 112:10 paying 12:4,6 18:16 13 56:3 59:9 117:8.12.15.23 realtime 135:8 19:3,10,13 83:20,22 position 34:14 professional 53:22 118:24 119:15 reason 9:4 10:4 11:7 pending 10:13 potentially 85:4 102:11 134:3 120:14 127:18.24 116:23 124:19 21:22,23 proper 32:22 132:7 129:12,14,16,25

people 56:14 80:21 practice 61:16 135:13 22 135:21 136:3,9 recall 24:5 34:12,19 86:11,15 108:13 preparation 94:23 137:4 36:21 37:4,12,23,25

133:3,6,13,23 134:4, question's 98:18 38:13,16 39:23 40:10

percent 23:4 70:6 prepare 31:18 41:23 12 19 54:3 77:15,19 perfectly 128:18 73:2 protective 7:11 questioner 98:20 95:5,8 96:6,18,25 prepared 71:2 72:6, questioning 45:11 97:6 98:5, 10 99:18 performing 93:12 16 114:7,16 123:24 provide 59:22 46:25 69:17 106:18 102:5 106:17 110:21 Periodically 9:12 pretty 91:14 133:14 questions 9:13 38:5 120:17.18 121:16

periods 29:20 provided 94:15 52:22 70:25 72:10, 132:24

101:13 133:17 137:25 14,22,25 97:15 receive 90:11

personally 90:3 previously 124:20 public 92:10 received 43:10 87:21 phone 16:21 primarily 69:10 pull 121:20 quick 21:19 112:18

physical 128:6 prior 27:15 42:8 purported 123:14 quickly 10:8 recent 76:21

picked 52:16 97:4 129:14 purportedly 123:16 130:25 131:2 quoting 130:12 recess 24:14 61:23 picking 38:7 private 29:15 111:5 purpose 30:9 59:14 ર્ 108:19 137:15 112:9 113:22 115:4, 62:17 recollection 14:8 place 27:21 141:20 15.19 117:24 Pursuant 7:10 raise 31:16 34:5 27:6 35:6,19 36:23 plan 75:5 134:18 privilege 12:18 13:2 45:14 53:10 113:12. 40:16 41:19 42:2,21 136:8 14:16 15:7 17:9,24 pursue 32:18,19 13 114:5 116:8 47:16 48:4,16 50:11 planning 23:6 73:17 32:2,8,14,21 66:6,9, put 21:24 22:13 26:8 117:11 51:5.13 54:7 76:25

133:21 19,21,22 67:2,4 68:3 41:8 53:16,17 57:17 raised 35:16,17 107:5,7,11,13 111:7, plans 24:2 69:22 95:16,18,23 59:3 68:6 69:6,9,14 39:16 40:20 45:17 11,21 112:25 122:13,

128:25 50:19 53:23 113:23 14.22 131:19 133:12 play 136:23 68:16 117:23 124:15 record 7:9 11:14 pleading 26:7 problem 46:7 53:21 putting 71:21 raising 27:21 35:25 12:9 16:10 21:10,14, Podolski 89:8 102:21,25 117:14 puzzling 113:11 111:16 118:14 15 24:11,13,17 34:21 point 28:22 30:4,13, proceed 8:39:19 ranging 77:20 39:13 50:17 51:10

relationship 18:4 61:6,18,22 62:2 80:2 95:21 103:21 108:15, 66:11 89:11 18,22 112:3 113:20 relevant 64:12 116:18,21 117:23 118:11,16,18,20 relied 69:25 119:8 123:13,20 relief 60:3 124:15 125:14 131:11 137:14.18 rely 70:8 133:12 143-9 remember 23:24 recorded 6:4 45:12 24:7 27:8 30:14,24 46:2 93:23 113:15,23 34:23 35:4,8,9,13,15, 117:23 118:18 16,17 36:7,10,11,13, 119:22 125:19 14,25 37:14,22 38:8, 21 39:5,15,18 40:19, recording 119:7 23 41:6,7,15 42:20 REDIRECT 140:14 43:25 47:7 50:20 51:24 52:3 53:24 redundant 10:2 77:11,17 85:8 86:2,8 reference 29:15 96:16 110:22 122:17 112:2,13,19 118:2,7, remembered 50:18 13 119:12 120:3 121:10 122:8 123:18. remind 51:11 22,25 124:17 126:7 reminded 51:7 132:19 remotely 110:17 referenced 22:19 115:16 130:17 renew 137:20 references 111:5 repeat 8:19 119:15 115-4 repeating 51:18 referred 78:3 81:24 reportedly 129:15 82.2 reporter 6:14 7:7 referring 80:24 8:2,16 10:21 11:3 94:15 107:24 110:12 12:10 16:11 21:7 reflect 56:18 39:14 46:2 95:22 104:4 113:19 114:10 reflected 41:14 44:3 116:14 117:15 reflecting 44:6 131:12 143:13 refreshed 42:251:14 reporting 6:11,15 106:17 122:13 113:17 refused 34:13 59:21 represent 12:14 17:22 18:6 regard 42:2,10 49:12 52:8 54:4 67:25 representation 93:15 94:7 95:24 14-13 97:11,14,15,19 98:7 representative 99:12.22 100:7 137:23 109:25 115:23 116:9 120:4,24 121:3 represented 11:18 124:23 131:19 133:5, 13:4.12 14:16 21 134:11,18 137:8 representing 27:14 registered 91:16 63:4,8 67:22 129:17 132:10 134:9 related 90:17

represents 11:25 request 47:18 54:5 55:22,25 56:8 57:3 60:19 65:15 89:19 94:6 137:21 142:25 83:6.23 60:20 requests 56:3 respect 73:20 respond 57:10 18 rest 75:18 results 57:22 retained 67:10 143:12 75:14 75:11 rid 99:7 role 107:21 108:14 95:25 ు safe 120:5 121:13

requested 82:20 requesting 57:21 reserve 137:24 response 60:23 107:20 129:12 132:8 responsible 18:16, resumed 24:15 61:24 108:20 137:16 reversed 120:10 review 11:2 41:22 reviewed 41.25 47:17 54:5,24 55:5

scenario 101.4 schedule 56:13 59:4,7,10 60:5,11

shorthand 8:2 11:3 12:9 16:10 21:7 39:13 95:21 104:4 114:10 131:11 143:13

sitting 41:20 48:9 73:16 75:4 122:23 125:11,16 131:14,16, 18,23 132:24 133:2, 20 134:9,17 135:11 136:7 137:2

speak 13:24 24:20 31:23.25 57:25 86:24 100:7 111:17

speaking 18:3 20:8 48:7 98:21 111:5,6,9 112:2 113:7

specific 38:9 41:18 52:4,11 77:19 98:3 102:9 107:7,13 122:13,14,16,23

specifically 36:16 37:12 38:9,19 40:15 41:21 51:8 54:3 62:21 74:7 86:2 95:5 107:17 122:17,25 125:18

Spring 81:18,19,21 82:5,14,16,20,22 83:2,6,7,10 87:22,25 107:21 117:10

126:19,21,25 141:4,6 30:12 31:7.8 45:24 46:8 51:23 28:16 29:15 40:5 translator 27:25 142:7,16 switching 33:18 53:18 56:15 119:7 41:15 42:13,16,18,19 28:10 44:15 101:19 Square 6:7 thought 21:20 30:10 43:3,4,5,7,8,17,19,20 102:4 103:11.16 staff 80:13.14.18 sworn 7:24 101:19, 34:6 36:4 91:6,7,18 44:2,4,6,9,10,13,14

81:11 141:2 22,25 102:3,6,9 117:14 131:7 20 47:9 48:7 49:13 thousand 64:16 85:6 50:9,15,16,22 51:16, travel 88:4 stand-alone 101:15 T 91:19 19 53:8 54:5,14,17, trial 59:3 start 6:3 98:14,19 time 10:6,20 13:17 25 55:6,11 56:21 triggered 30:13 113:7 taking 116:15 118:3 24:12.16 26:2.20 57:23 58:7 65:11 started 84:8 120:11 talk 10:19 21:22 27:4,12,19,22 29:10 75:11 76:2 102:2 true 59:11 61:17 85:23 100:10 35:2 36:10 43:10 104:6,10,24 105:17

starting 126:18 talked 54:12 92:9 44:2 49:4,6 51:25 112:20 113:2 114:7, 7:2 8:11 21:3 22:8 state 11:13 39:10 118:17 61:21,25 67:22 77:8, 15,23 118:10,16 trustee's 129:12.16 40:3,7 46:15 52:9,15 talking 10:20 85:20, 15,19,21 78:3,8 119:23 122:7.12 132:9 53:16 24 86:5,15 87:5,7 81:18,24 83:15 84:8

statement 7:9 29:5 94:10,11 128:5 104:9 108:17,21 127:11 131:23 truth 101:20 32:20 41:11 102:23 talks 86:11 120:19 133:23 133:14,16,17 134:5, truthful 11:7 103:3,20 123:14 136:16.20 137:13.17 20,22 136:9 139:20

statements 29:18,21 tallied 84:10 138:4,16,17 141:5 30:20 93:21 112:20 telephone 14:25 143:3.8 transcription 40:6 Tuesday 23:20,23

115:20 116:15 118:3 timeline 7:14 58:5 74:4.11,19 75:6

139:20,22 140:7 transcripts 105:2 83:17 90:21 91:5,10,

steno 99:9 telling 28:23 44:16 78:9 80:4 102:5 93:22 98:16 103:11 turn 22:7 107:15 sticks 39:23 45:5 103:21 124:20 128:17 108:8,25 110:4 stop 116:2 Terrific 11:10 38:10 tirade 97:24 translated 53:5 114:22 115:22 testified 7:19.24 58:11,13 62:5,22 117:19 118:2.13 Street 6:12 11:17 56:21 86:19 122:6,11 today 10:4 11:8,19 129:25 130:3,24 121:22 123:7 125:23 strike 28:13 89:12 12:4 18:17 19:4,10, 131:15,17,24 132:25 126:3.17 129:2 130:6 92:23 95:15 125:7 testify 25:6 132:7,12 13 20:22 23:11 41:20 42:8 48:10,19 49:2 133:3,6,13,23 134:4, type 128:5 stuck 47:20 testifying 24:23 25:3 51:24 56:23 58:20 12 136:10 study 93:5 68:20 69:3,24 91:10 73:16 75:4 83:15 translating 67:12 ப testimonies 41:3 84:9 85:10 91:14,18 98:13,15 100:15 subject 95:6 141:12, testimony 11:8 92:14,16 122:23 103:17 U.S. 129:12,16 132:8 14 19:24 20:19 22:14 125:12,16 131:14,18, translation 22:15 subsequent 43:25 23:6.13.22.23 24:4 23 132:24 133:2,20 23:8 25:19 26:3,10, UBS 96:6

136:7 137:2 138:24 17,24 27:20 28:7 un-huh 8:17 9:3 sudden 120:11 69:19,20 70:16 72:17 34:7 64:2.7.19.22 25:16 29:6,8 30:8,16, 75:6,12 90:11,18 today's 143:6 66:4 84:3 93:6 97:19 19 31:12 37:9 38:14, suggestion 112:4 98:8 121:25 124:23 told 26:2.19 37:8 102:18 109:4,14,18, 17 40:11 48:2,13

Suite 6:13 133:8 52:5 90:10 124:19 22 110:8,9 115:23

suppose 57:11 texts 93:11 top 22:11 116:8 11 120:4,24 121:3,6, 58:9 62:7 64:5 66:2 thing 8:14 10:12,25 9 122:2,15,24 123:4, 70:14 72:15 73:6 supposed 78:6,7 25:22 33:6 40:23 topic 97:11 15 124:18 125:13 78:17 81:8 82:7,12 surprising 91:14 47:20 56:3,6 85:5 transactions 117:9 127:5 128:10 129:10, 83:12 85:11 88:8,23 swear 7:7 87:11 113:9 116:21 transcribe 124:13 15,21 131:19 135:13 93:2,10 96:22 97:9 137:8.10 translations 99:23 100:16 101:8,18

switch 30:2,18 things 28:21 35:2 transcribed 93:21 118:4 106:15 107:22 110:3, switched 28:22 36:2,22,25 38:8 40:9 transcript 7:12 25 112:17 114:9 Index: =======================================================================================================================================================================

110:2 Westminster 93:7 63:17,21 65:5,17,24

80:21 81:4.5.12.16.