Guo Wengui / Miles Guo — criminal case · MOTION · ECF #770

Case 1:23-88862283949; 13/83/2888877865127699951 of 40

Clerk of Court United States Court of Appeals for the Second Circuit 40 Foley Square New York, NY 10007 USA Re: In re Jason Zen - Petition for Writ of Mandamus and Motion to Proceed In Forma Pauperis (Case No. 1:23-cr-00118-AT)

Pursuant to the Court's instruction(Exhibit H\, lam submitt'.ng the enclcsed

documents in paper form for filing in the above-captioned case. These materials are mailed timely for review and docketing. Exhibit list:

Exhibit C-Motion to Proceed In Forma Pauperis

Exhibit D-Form 4 Affidavit with motion to proceed in forma pauperis

Exhibit E-Expianation of my financial hardship

Exhibit F- Copy of Emergency Motion to Compel Uploading and Hearing of Third-Party Petitions Under 21 U.S.C. §853(n), and to Recognize Victim Rights Under 18 U.S.C. §3771 (CVRA)

Exhibit H-Reply email from the Second Circuit

Exhibit J -MOTION TO SEAL PERSONAL IDENTIFYING INFORMATION

I respectfully request confirmation of receipt and docketing. Thank you for your attention. Respectfully submitted,

Email:

In re:

(Under 28 U.S.C. §1651 and Fed. R. App. P. 21)

I, ,(English name:Jason Zen), am a third-party petitioner and financial victim in the criminal case United States v. Ho Wan Kwok, No. 1:23-cr-00118-AT (S.D.N.Y.).

Between August 30 and October 21, 2025, I timely submitted seven motions pursuant to 21 U.S.C. §853(n) and 18 U.S.C. §3771. However, only the first motion (Docket No. 729)was uploaded to the court docket, and even that filing has received no response from the district court.

All subsequent motions have not been docketed or cknowledged{Exhibit B, G).

This petition seeks a Writ of Mandamus ordering the United States District Court for the Southern District of New York to properly docket and consider my motions in accordance with the law.

Due to my limited financial means and inability to afford the filing and appellate fees, I am concurrently submitting an Application to Proceed In Forma Pauperis pursuant to 28 U.S.C. §191S(a). I respectfully request that this Court grant me permission to proceed with this appeal as an indigent litigant. I have attached an "Motion to Proceed In Forma

Pauperis," (Exhibit C) and I declare that the information contained therein is true and correct to the best of my knowledge. **\*\Request for Sealed or Redacted Filing\\***

In the interest of personal security and to prevent potential persecution by the Chinese Communist Party (CCP), Petitioner respectfully requests that the Court **redact all personal or identifying information from any filings prior to public release. Only documents bearing the designation "Public Version" in their title are authorized for direct public disclosure(Exhibit J).**

My initial §853(n) filings sought to protect the rights of lawful investors and property owners whose assets were unlawfully managed or dissipated during the forfeiture process in U.S. v. Kwok. Specifically, my motions raised the following concerns:

- 1. Allegations that the prosecution may have conspired with certain third parties to unlawfully seize or misappropriate investor assets. - 2. The prosecution has repeatedly violated the Brady rule by withholding evidence that is favorable and material to the defendant. - 3. Mismanagement and potential unlawful dissipation of forfeited property by court-appointed trustee Luc A. Despins. - 4. I have provided the Court with my personal identification and investment information, and I have respectfully requested that this information be filed under seal and not made available for public disclosure. - 5. A request that the court immediately restore normal filing access for third-party Third-party investors under §853(n) and victims under CVRA.

My Motions except the first one(Docket No. 729) were not docketed or heard.

Since September 12,2025 till now, there are no individual third-party petitions have been uploaded to the Court's docket. During this period, I submitted six additional motions to the District Court through the Pro Se electronic filing email system. All filings were properly formatted and duly signed. Despite my having emailed the Court and the Government, as well as mailed hard copies with confirmed delivery, the Southern District of New York has failed to docket these submissions to date(Exhibit G).

The Court has restricted the filing of further motions exclusively to attorneys with access to the Electronic Case Filing (ECF) system. This unprecedented act of suppression violates the Crime Victims' Rights Act (CVRA) and the constitutional due process rights of the victims and 853(n) Third-party investors.This ongoing inaction reflects a systematic suppression of the lawful rights of third-party investors and victims to be heard and to participate meaningfully in these proceedings.

Many other third parties and victims in this case have experienced situations similar to mine. Encouragingly, the case No. 25-2726 before the Second Circuit indicates that the systemic suppression by the Southern District of New York has already drawn the attention of the higher court, further demonstrating that my appeal is not an isolated incident.

In light of the prosecution's refusal to recognize legitimate investors as victims and the Court's continued inaction, i subsequently invoked 13 U.S.C. § 3771 (CVRA) to exercise my statutC1r,/ r,ghts as a flnanci21 victim, seeking fair process, the right to be heard, and the right to participate in forfeiture proceedings (Exhibit F).

This dual standing - as both a third-party claimant under §853(n) and a victim under §3771 - arises directiy from Cong,essional intent, not personal assertion.

Ill. VIOLATION OF MY RIGHTS UNDER §853(n) AND §3771

The district court's failure to docket or act upon my motions has effectively deprived me of access to justice and silenced my lawful claims.

This ongoing suppression:

- Denies me the right to be heard (§3771(a)(4)); - Prevents participation in forfeiWre proceedings (§853(n)(2)); - Delays the resolution of my lawful property and victim claims; - Undermines fundamental fairness and procedural due process.

Such inaction is not a matter of judicial discretion but a violation of mandatory statutory duties imposed under §§853(n) and 3771. Therefore, relief under a writ of mandamus is warranted.

This petition is brought under 28 U.S,C. §165:l.(aJ (All V,Jrits Act) and Fed. R. App. P. 21, which authorize the Co;1rt of Appeals to issue writs of mandamus to compel lower courts to perform their nondiscretionary duties.

Mandamus is appropriate when:

- l. The petitioner has no other adequate means to obtain relief; - 2. The petitioner's right to relief is clear and indisputable; and - 3. The writ is appropriate under the circumstances. (See Cheney v. U.S. Dist. Court, 542 U.S. 367, 380 (2004)).

Here, the district court's persistent refusal to doci<et or consider my motions meets all three conditions.

Petitioner respectfully requests that this Court:

- 1. Issue a writ of mandamus directing the U.S. District Court for the Southern District of New York to immediately docket all previously submitted motions listed in the attached (Exhibit G); - 2. Order the presiding judge to promptly review and adjudicate those motions; - 3. Direct the district court to restore normal filing access for both third-party invstors under 21 U.S.C. §853(n) and victims exercising their rights under 18 U.S.C. §3771 (CVRA), and to cease anv unlawful obstruction or suppression of such filings. - 4. Issue a protective order to ensure that all personal or identifying information in Petitioner's filings is redacted before any public release, - 5. Grant any further relief deemed just and proper.

This petition is not intended to challenge judicial discretion, but rather to restore it. When a lower court suppresses filings that seek to reveal the truth, refuses to docket duly served motions, and thereby prevents third parties and victims from exercising their statutory rights, a writ of mandamus becomes the only mechanism available to preserve the rule of law.

For the reasons stated above, I respectfully urge this Honorable Court to grant this Petition for Writ of Mandamus, comi:el the district court to docket and hear my pending motions, and er.sure that third-party and victim filings are no longer unlawfully suppressed.

In view of the extensive attachments inC:uoc'•:l with m•{ motions submitted to the U.S. District Court for the Southern District of New York between August 30, 2025, and October 21, 2025, this filing contains only the email submission records of the unuploaded motions(Exhibit G) and my most recent motion(Exhibit F).

Exhibit C-Motion to Proceed In Forma Pauperis

Exhibit D-Form 4 Affidavit with motion to proceed in forma pauperis

Exhibit E-Explanation of my financial hardship

Exhibit F-Emergency Motion to Compel Uploading and Hearing of Third-Party Petitions Under 21 U.S.C. §853(r'1, and to Recognize Victim Rights Under 18 U.S.C. §3771 (CVRA)

Exhibit H-Reply email from the Second Circui'.

Exhibit J-MOTION TO SEAL PERSONAL IDENTIFYING INFORMATION

\*\Onlv documents bearing the designation "Public Version" in their title are authorized for direct public disclosure.\\*

Should the Court require access to any ~:pedfi c cfocwnent or correspondence, I stand ready to provide them promptly upon the Court's request.

Petitioner, prose Email:

Case 1:23-388622533946, 13683/3225777616112/689511 0f 40 1. EMS voucher for mailing motion documents to the court

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21:48:00 US-USJFKA Приспела 12.10.2025

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08:21:29 11003 EXCHANGE MAIL Transportation

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20:26:57 25200 ПЦ СОМБОР Отпрема 22:52:38

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08:32-19 25274 КОЛУТ Пријем 16.10.2025

UNITED STATES COURT OF APPEALS FOR THE SECOND CIRCUIT

In re: United States v. Ho /fan Kwok Case No. : *1 :23-cr-00118-AT*

I, -• (English name Jason Zen), a third-party petitioner under 21 U.S. C. § 853 (n) and a recognized financial victim under 18 U.S. C. § 3771 (CVRA), respectfully move this Court for leave to proceed in forma pauperis in the above-captioned matter.

This petition arises from my previous attempts to file several motions in the under lying criminal forfeiture case (Case No. 1: 23-cr-OOi 18-AT), some of which have not been docketed or addressed by the District Court. However, this motion is submitted solely to request permission to proceed in forma pauperis due to financial hardship.

In 2023, to avoid the COVID-19 pandemic in Chic.a, I relocated 'co Serbia with my child and my parents. I am div:irced, unemployed, and currently rely entirely on my parents' retirement pension from China for basic living expenses. My child is 12 years old, and beth of my parents are over 70 years old.

I have no additional financial or related costs. Accordingly, pauperi s pursuant to 28 U.S. C. resources to pay appellate fiiing fees I request leave to proceed in Jonna § 1915.

For the foregoing reasons, I respectfully request that the Court:

- 1. Grant this Motion to Proceed In Forma Pauperis; - 2. Permit me to file my appeal without prepayment of fees.

Form 4 Affidavit with motion to proceed in forma pauperis

FOR PERMISSION TO APPEAL IN FORMA PAUPERIS Affidavit in Support of Motion Instructions I swear or affirm under penalty of perjury that, because of my poverty, I cannot prepay the docket fees of my appeal or post a bond for them. I believe I am entitled to redress. I swear or affirm under penalty of perjury under United Comi,l~te al' ~t:est'ons in this application and tJ-,rn s;gn it. 0) not leave any blanks: if the answer to a question is "0," "none," or "not applicable (NIA)," write that response. If you need more space to answer a question or to

need more space to answer a question or to explain your answer, attach a separate sheet of paper identified with your name, your case's docket number, and the question number.

States laws that my answers on this form are true and correct. (28 U.S.C. § 1746; 18 U.S.C.

My issues on appeal are: The appeal seeks review of the District Court's failure to process or respond

to my timely third-party and victim petitions under 21 U.S.C. §853(n) and 18 U.S.C. §3771, which

deprived me of the right to be heard and to participate in forfeiture proceedings.

I. *For both you and your spouse estimate the avemge amow1! of money received.from each of the following sources during the past 12 1r,011ths. Adj,,st any a,nouni that was received weekly, biweekly, quarterly, semiannually, or annually to show the monthly rate. Use gross amounts, that is, amounts before any deductions for taxes or otherwise.*

Interest and dividends \$0 !

pensions, annuities, insurance) \$0 So 1S0 ·• So ' !

Unemployment payments \$0 :\$0 \$0 • \$0 Public-assistance (such as welfare) \$0 ~o £a '

Other (specify):

Total monthly income: 1\$0 ·\$0 \$1} So

2. *List your employment history for the past two years, most recent employer firs/. (Gross monthly pay is before taxes or other deductions.}*

Case 1:23-88863283946, 13633/20225777616112/8899919 Page 19 of 40

3. (Gross monthly pay is before taxes or other deductions.)

Employer Address Dates of employment Gross

4.

Below, state any money you or your spouse have in bank accounts or in any other financial institution.

Financial Institution Type of Account Amount you have Amount your

Postal Saving Bank Personal Bank Account \$ 0 \$ 0

If you are a prisoner seeking to appeal a judgment in a civil action or proceeding, vous must attach a statement certified by the appropriate institutional officer showing all receipts, expenditures, and balances during the last six months in your institutional accounts. If you have multiple accounts, perhaps because you have been in multiple institutions, attach one certified statement of each account.

5. and ordinary household furnishings.

Home Other real estate Moter vehicle #1

Value) \$ 19000 (Value) \$ 0 (Value) \$ 4000 a house in serbia none Make and year: 2008

Model: none none !

6. State every person, business, or organizalion owing you or your spouse money, and the amount owed.

money Amount owed to you Am,11nt owed to your

7. State the persons who rely on you or your spouse for suppon

Name [or, if under 18, initials only] Age

8. *Estimate the average monthly expenses ofyou and yourfCiini!v. S!uw separatelv the amounts paid by your spouse. Adjust any payments that are made weekly, biweekly, quarterly, semiannually, or annually to show the monthly rate.*

Rent or home-mortgage payment (including lot rented for

Are real estate taxes included? Is property insurance included?

Utilities ( electricity, heating fuel, water, sewer, and telephone) i ~115 so

Home maintenance (repairs and upkeep) ·\$15 !

Clothing !

Transportation (not including motor vehicle payments) SC• :2;0 Recreation, entertainment, newspapers, magazines, etc S200 :

Insurance (not deducted from wages or included in mortgage payments)

Taxes (not deducted from wages or included in mortgage

J ,_; :,v .

Alimony, maintenance, and support paid to others \$ a £ C

Regular expenses for operation of business, profession, or farm ( attach detailed statement) \$ C \$ C

9. *Do you expect any major changes to your monthly income or expenses or in your assets or liabilities during the next 12 months?*

If yes, describe on an attached sheet.

10. Have you spent - or will you b~end~ - any monr::yfcr- expenses or attorne\_\_·;. fees in connection with this lawsuit?LJYes li'.".'.JNo

IL Provide any other information that will help exp/am why you cannot pay the docketfees for your appeal.

A detailed explanation of my financial hardship is attached.(Exhibit E)

12. State the city and state of your legal residence

Your daytime phone number:

Your age:- Your years of schooling:

Attachment to In Forma Pauperis Application Statement of Financial Hardship

Case Title: United States v. Ho Wan Kwok Case No. : *1: 23-cr-00 118-A T* Applicant: - /Jason Zen

I, , English name Jason Zen, respectfully submit this statement in support of my Application to Proceed In Forma Pauperis.

In 2023, in order to escape the COVID-19 pandemic in China, I came to Serbia with my child and my parents. I am divorced and currently unemployed. Our basic living expenses are supported by my parents' retirement pension from China. My child is 12 years old, ar,d both of my parents are over 70 years old.

At present, I have no additional financial means or resources to pay the filing or appellate fees required by the Court. Therefore, I respectfully request permission to proceed in fonna pauperis in this matter.

Signature: Date:

Emergency Motion to Compel Uploading and Hearing of Third-Party Petitions Under 21 LJ.5.C. §853{n), and to Recognize Victln1 flights. UL1der 13 U.S.C. §37'.ll {CVriA}

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF

Defendants.

Emergency Motion to Compel Uploading and Hearing of Third-Party Petitions Under 21 U.S.C. §853(n), and to Recognize Victim Rights Under 18 U.S.C. §3771 (CVRA) Honorable Judge Torres:

I.Jason Zen, appearing prose, a~ a third-party claimant under 21 U.S.C. §853(n) and a recognized financial victim under 18 U.S.C. §3771 (CVRA), respectfully submits this Emergency Motion and states as follows:

Petitioner previously filed multiple third-party petitions under 21 U.S.C. §853(n) in connection with the above-captioned case, asserting legitimate ownership and equitable interests ;n assets subject to criminal forfeitui·e.

Despite timely mailing and service upon the Court, only one petition(Document No. 729) was up,oaded to the docket, while subsequent filings remain unprocessed and unacknowledged.

The continued inaction of the Court and the government' s neglect toward third-party and victim submissions have deprived Petitioner and similarly situated investors of their statutory right to be heard.

Accordingly, Petitioner brings ·£his ErnE,9e11cy Motion to compel the uploading and hear:ng CJf a:; ;c,2nd;ng §8S3(n)

petitions and to invoke the procedural pr:,tect:ons afforded to victims under the Crime Victims' Rights Act (CVRA), 18 u.s.c. §3771. II. STATEMENT OF STANDING AND LEGAL BASIS

Petitioner originally appeared under 21 Li.S.C. §853(n), asserting a legitimate property interes, m assets subject to criminal forfeiture(Document No. 729).

However, due to the governrnent' s failure to recognize numerous investors as victims and the Court \_:-; continued inaction regarding third-party petitions,

Petitioner now additionally invokes the protections afforded by the Cr·1me v·1ct·1ms' R·1ghf·, 'c '· •1 '3 '1'" 1- .,--.--7-' , , ... I'\ .. i\_ I C L . -~. -· 3 :, ' • • ) •

This dual standing is not self-pr:xla:rned but arises from Congress' s intent that both proper~y claimants and financial victims must be provided fair process,

including the right "to be hearD'. ro ,J,? /r;'ci.-rne,l aod to be treated with fairness" unde;- §377 l (a;.

Accordingly, Petitioner seeks th:s Co,:,·t' s recognition of his CVRA rights alongside his §853ii-,) d2,,ry;\_

1. Failure to Upload and Process Third-Party Filings

Despite Petitioner' s timely submission of multiple §853(n) motions within the statutory period, the Court' s electronic system has railed to upload or gocket several of them, effectively silencing lawful third-party claims and violating the principles of transparency and fairness. 2. Ongoing Prejudice to Victims and the Defendant

This inaction has deprived Petitioner and other victims of any opportunity to be heard within the 60-day statutory window, resulting in irreparable procedural harm.

Such neglect contravenes both §853(n) and the CVRA, as victims are guaranteed the right to participate meaningfully in forfeiture-related proceedings. 3. Evidence of Brady Violations and Collusion Revealed in Court Fillings

Furthermore, as reflected in the Court' s publicly available docket, particularly in Document Nos. 723, 733, and 733-1, serious allegations have been raised indicating that the prosecution may have engaged in multiple Brady violations, by withholding exculpatory

and material evidence from both the defense and the victims.

These filings further suggest potential collusive conduct between the prosecution and the Court-appointed trustee, Luc A. Despins, resulting in the deception of the Southern District of New York and even the Second Circuit Court of Appeals, thereby inflicting substantial harm upon poth victims/investors and the defendant.

Such misconduct, if substantiated, constitutes a grave breach of the principles of due process and judicial integrity, directly infringing upon the rights guaranteed to victims and innocent third parties under both 21 U.S.C. 5853 and 18 U.S.C. §377'l (CVRA).

The continued suppression of third-party and victim voices risks eroding public confidence in the integrity of this Court.

Petitioner respectfully requests that this Honorable Court:

- 1. Order the immediate uptoadin~1 and docketing of all §853(n) petitions that have been duly mailed or delivered to the Court but remain uriorocessed (c:x;1ibit B) - 32.2(b)(2)(A) to review the conduct of tne government and the court-appointed t•:..Jstee; - CVRA, and ensure that victims voices are afforded due consideration and procedd,-ai fairness in ali subsequent proceedings.

Justice delayed is justice denied.

For over a year, victims and 1nvEs,ors 11e1ve sought noth:ng more than a fair opportunity to be heard and to protect their lawfully acquired interests.

The government' s inaction 2:111,j ;JE Cou,·t' s d,-clay ha,1e undermined those rights, contra;y to both ~853(n) and ~he CVRA.

Petitioner respectfully urges this Court to act without further delay to restore transparency, in these proceedings.

Email:

2025.9.20 I MOTION TO INTERVENE BY [Jason Zen] (Pro Se/ Interested Party under 21 U.S.C. § 853(n)

202S.9.30 I Emergency Motion to Protect Forfeited Assets -

MOTION TO FILE PERSONAL AND INVESTMENT INFORMATION UNDER SEAL-Case No. 1:23-cr-00118 (AT) 2025.10.9 I (Attention: I respectfully requests that the Court order that the entire contents of this filing remain fully sealed, for the Court' s internal use only, and prohibit any public display or access.) MOTION TO OPPOSE PREMATURE CLOSURE OF THIRD-PARTY PETITIONS AND TO EXTEND FILING DEADLINE FOR PRO SE

Emergency Motion to Compel Uploading and Hearing of Third-Party Petitions Under 21 U.S.C. §853(n), and to Recognize 2025.10.21 • Victim Rights Under 18 U.S.C. §3771 (CVRA)-1:23-cr-00118-AT

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Case No.

8J{ij 2025ti,:9R208 ~!El JimmyHansen Jh2920411@grnall.com

8){ij 20254:9_1;!258 ».~ Jimmy Hansen jh2920411@gm~il.com

13:07.

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My name ls Jason Zen, and I am an interested J"Immy Han\$en jh2920411@gmail.com

jkaley@doarlaw.com ~13 Jimmy Hansen jh2920411@gmall.com

third-party petitioner in the case United States v. Ho Wan Kwok, Case No. 1:23-cr-00118-AT. BM 2025\$10.f:J 19

United States Court of Appeals for the Second Circuit

Case: United States v. Kwok, et al. 1 :23-CR-118-1 (AT)

I, Jason Zen (aka. ), certify that on November I 2-. 2025, true and correct copies of the Petition for Writ of Mandamus, along with authentic copies of the relevant documents, were served on the following parties registered mail from Serbian Post by Jason Zen, acting solely as sender on my behalf and not in any legal capacity:

1. The Honorable Analisa Torres, United States District Judge United States District Court

for the Southern District of New York 500 Pearl Street, New York, NY 10007 -1312

2. Ryan 8. Finkel, Assistant United States Attorney United States Attorney's Office,

Southern District of New York One St. Andrew's Plaza, New York, NY 10007

Executed on November --~2025.

c:J'~>cY\·~ Signature \_\_\_\_\_\_\_\_\_\_\_ \_

Jason Zen (aka.

MOTION TO SEAL PERSONAL IDENTIFYING INFORMATION Public Version UNITED STATES COURT OF APPEALS FOR THE SECOND CIRCUIT

In re Jason Zen - Petition for Writ of Mandamus Case No. 1:23-cr-00118-AT MOTION TO REQUEST REDACTION OF PERSONAL INFORMATION

Petitioner, Jason Zen (a.k.a. \_), appearing prose, respectfully moves this Honorable Court to redact and protect from public access any personally identifying information contained in the documents submitted in connection with the above-captioned matter.

In support of this motion, Petitioner states as follows:

- l. The filings include personal data such as name,contact information, residential details, and other identifiers that, if publicly disclosed, could expose Petitioner and family members to security or retaliation from the Chinese Communist Party (CCP) risks. - 2. Petitioner currently resides outside the United States and faces potential political and personal safety threats related to this case. - 3. Pursuant to Federal Rule of Criminal Procedure 49.1 and the Court's inherent authority to protect privacy and safety, redaction of such sensitive information is both necessary and appropriate. - 4. Petitioner requests that the Court permit the filings to remain publicly available only in redacted form, with unredacted copies maintained for internal judicial use only.

WHEREFORE, Petitioner respectfully requests that this Court order the redaction of all personal identifiers and sensitive information from the public docket and maintain sealed versions for Court use.

/s/ Jason Zen/- Pro Se Petitioner Email: 2025.11.6

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