Guo Wengui / Miles Guo — criminal case · ECF #759

## **IN THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF NEW YORK**

## **UNITED STATES OF AMERICA,**

**-v-**

**HO WAN KWOK, a/k/a "Miles Guo," "Miles Kwok," "Guo Wengui," "Brother Seven," or "The Principal,"**

and

**KIN MING JE, a/k/a "William Je,"**

and

**YANPING WANG, a/k/a "Yvette,"**

Defendants.

Restitution of Seized Funds Criminal No.: 23-cr-118 (AT)

UPDATED AND FINAL ENTRY OF APPEARANCE FOR COUNSEL'S 6,512 CLIENTS

Assigned to the Honorable U.S. District Court Judge Analisa Torres, Presiding Judge

## **UPDATED AND FINAL ENTRY OF APPEARANCE FOR COUNSEL'S 6,512 CLIENTS**

Bradford L. Geyer, Esq., of FormerFedsGroup.Com LLC, respectfully enters his appearance on behalf of 6,512 authenticated customers of the Himalaya Exchange ("HEX"), all of whom are identifiable third-party claimants with verified, traceable interests in the seized Himalaya Coin ("HCN") and Himalaya Dollar ("HDO") cryptocurrency, as well as associated reserves.

These claimants were authenticated by HEX as of October 10, 2025, through unique Himalaya Identification Numbers ("HIDs"). This authentication process reflects aggregate holdings totaling \$84,689,498.20 (HDO) and 433,992,619.55 (HCN). The value of HDO total claim being \$84,689,498.20 from the seized funds. Separately, the compensatory loss claim from the government for loss of HCN asset as a result of the seizure of funds, website resulting in the Exchange not able to function being 433,992,619.55 (HCN) x \$ 13.77 per HCN (price at the date of trading paused July 17, 2024 as a result of the government conduct) = \$5,976,051,078 loss This appearance excludes 187 individuals who have voluntarily terminated representation since the initial filing. New clients were not accepted after October 12, 2025. Counsel represents only those HEX clients whose identities and balances have been authenticated via secure, encrypted HEX servers and whose fee agreements expressly authorize representation.[1](#page-1-0) In support, undersigned counsel submits under seal Exhibit A (declaration), Exhibit B (client list), Exhibit C (affidavit).

Counsel enters this appearance for the limited purposes of:

1. Representing the authenticated clients in ancillary forfeiture proceedings under 21 U.S.C. § 853(n) and Fed. R. Crim. P. 32.2(c);

2. Preserving clients' rights under the remission process pursuant to 21 U.S.C. § 853(i), many of whom were unable to file remission claims;

3. Contesting the jurisdiction of the United States over assets seized from HEX and related entities;

<span id="page-1-0"></span>¹ There is one exception for one client who signed up, but was not authenticated by HEX. This client is referenced in Exhibit B filed under seal.

4. Coordinating with the United States and the Court to ensure equitable adjudication consistent

with the Court's Preliminary Order of Forfeiture (ECF No. 720) entered August 11, 2025.

Dated: October 22, 2025

Dated: October 22, 2025 RESPECTFULLY SUBMITTED

/s/ Brad Geyer Bradford L. Geyer, PHV NJ 022751991 Suite 141 Route 130 S. 303 Cinnaminson, NJ 08077 [Brad@FormerFedsGroup.Com](mailto:Brad@FormerFedsGroup.Com) (856) 607-5708

## **CERTIFICATE OF SERVICE**

I hereby certify that on October 22, 2025, a true and accurate copy of the forgoing was electronically filed and served through the ECF system of the U.S. District Court for the Southern District of New York.

> /s/ Brad Geyer Bradford L. Geyer, PHV NJ 022751991 Suite 141 Route 130 S. 303 Cinnaminson, NJ 08077 [Brad@FormerFedsGroup.Com](mailto:Brad@FormerFedsGroup.Com) (856) 607-5708