---
type: court_doc
id: "court_sdny_841_0"
court: "SDNY"
case_no: ""
doc_number: 841
doc_type: "DOC"
filed_date: "2026-04-27"
lang: "en"
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url: "https://mubeitech.com/en/court/court_sdny_841_0"
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# Guo Wengui / Miles Guo — criminal case · ECF #841

**Petition for Third-Party Property Interest (Forfeiture) — United States v. Ho Wan Kwok (Miles Guo / Guo Wengui), SDNY 1:23-cr-00118, ECF #841 (docketed 4/27/2026). Third-party petitioner 1328777 B.C. Ltd. seeks amendment of preliminary forfeiture order to exclude property in which it claims superior title interest, or alternatively, requests hearing under 21 U.S.C. § 853(n) with discovery regarding defendants' fraudulent conduct in Himalaya Exchange, or relief through government asset forfeiture remission process.**


a.
amend the Preliminary Forfeiture Order to exclude the property ($6,000,000, plus
interest) in which Petitioner has a superior right, title, and interest as an innocent third
party or a bona fide purchaser for value;
b. alternatively, grant Petitioner a hearing pursuant to 21 U.S.C. § 853(n), along with
such discovery, including but not limited to discovery pertaining to Defendants'
fraudulent conduct in connection with the Himalaya Exchange and Petitioner's
investment in the Exchange, as may be appropriate;
c.
alternatively, in the event that this Petition is denied, order that the Petitioner be
compensated through the MNF's remission process, as set forth in the Government's
submission to the Court, Dkt. 785, letter; and
d. order such other and further relief as the Court deems just and proper.
Dated: April 27, 2026
Respectfully Submitted,
FORD O'BRIEN LANDY LLP
By/-0-
Kevin J. O'Brien
275 Madison Avenue, 24th Floor
New York, NY 10016
Tel: (212) 858-0040 (main)
kobrien@fordobrien.com
Attorney for Petitioner 1328777 B.C. Ltd

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