Guo Wengui / Miles Guo — criminal case · ECF #848
METADATA
- Defendant
- Guo Wengui / Miles Guo / Ho Wan Kwok
- Court
- SDNY
- Case No.
- 1:23-cr-00118
- ECF #
- 848
- Type
- DOC
- Filed
- 2026-05-11
Emergency mandamus petition — United States v. Ho Wan Kwok (Miles Guo / Guo Wengui), SDNY 1:23-cr-00118, ECF #848 (filed 2026-05-11). Third-party petitioner Bao Chu files an emergency petition for a writ of mandamus with the Second Circuit, alleging the SDNY Clerk and presiding Judge Analisa Torres failed to docket numerous submissions, and alleging misconduct by the prosecution and bankruptcy trustee Luc Despins in verifying forfeiture creditors, asking the appellate court to compel immediate docketing and an evidentiary hearing.
FULL TEXT
In re: BAO CHU, Petitioner. Source Case No.: 1:23-cr-00118-AT (S.D.N.Y.)
EMERGENCY PETITION FOR A WRIT OF MANDAMUS TO COMPEL MINISTERIAL DUTIES AND REMEDY STRUCTURAL DEPRIVATION OF DUE
TO THE HONORABLE JUDGES OF THE UNITED STATES COURT OF APPEALS FOR THE SECOND CIRCUIT: Pursuant to the All Writs Act, 28 U.S.C. § 1651, and Federal Rule of Appellate Pro- cedure 21, Petitioner Bao Chu (S.D.N.Y. HID: F56BDDZ), a bona fide third-party prop- erty owner asserting exclusive statutory standing under 21 U.S.C. § 853(n), hereby files this Emergency Petition for a Writ of Mandamus. Petitioner respectfully requests that this Court issue a Mandamus compelling the Clerk of the United States District Court for the Southern District of New York (SDNY) and the Honorable Judge Analisa Torres to cease their structural depriva- tion of Petitioner’s Fifth Amendment Due Process rights, and to immediately docket eighteen (18) unlawfully suppressed legal filings.
Case: 26-1296, 05/11/2026, DktEntry: 7.1, Page 1 of 65
I. STATEMENT OF FACTS: THE CLERK’S BLATANT VIOLATION OF FED. R. CIV.
The factual basis for this Petition is documented, objective, and irrefutable. Be- tween April 17, 2026, and May 7, 2026, Petitioner lawfully transmitted over eigh- teen (18) separate emergency motions, supplemental memoranda, and objective evidentiary exhibits to the SDNY Pro Se Office and the Chambers of Judge Torres. Furthermore, Petitioner successfully delivered physical copies of critical motions and 29 exhibits via international EMS (Tracking Nos: 1000250003756541000001 and 1000250003756551000008), which were received and signed for by the SDNY. Despite these lawful and saturated services, the SDNY Clerk has orchestrated an unconstitutional ”pocket veto.” As of the filing of this Petition, not a single one of these eighteen submissions has been uploaded to the CM/ECF public docket. This constitutes a direct and egregious violation of Federal Rule of Civil Proce- dure 5(d)(4), which mandates: ”The clerk must not refuse to file a paper solely be- cause it is not in the form prescribed by these rules or by a local rule or practice.” The docketing of submissions by the Clerk is a purely Ministerial Duty devoid of substantive review authority. The SDNY’s continuous administrative blockade is an ultra vires act designed to silence a verified property owner. II. THE MOTIVE FOR SUPPRESSION: CONCEALING FRAUD ON THE COURT The SDNY is deliberately risking severe procedural violations to suppress these 18 filings because they contain fatal, physical evidence that destroys the legitimacy of the Government’s $1.4 billion forfeiture action. Specifically, Petitioner’s unlawfully suppressed “Emergency Motion for a Mandatory Rule 104 Hearing” (submitted May 4, 2026) exposes the following coordinated Fraud on the Court: 1. AUSA Ryan Finkel’s Receipt of Manufactured Perjury: The suppressed ex-
Case: 26-1296, 05/11/2026, DktEntry: 7.1, Page 2 of 65
hibits provide incontrovertible written proof that an extrajudicial RICO syndi- cate (known as the ”Alliance/Qingteng”) established a perjury-manufacturing assembly line. This syndicate pre-filled ”victim” remission forms and coerced thousands of investors internationally to mail these fabricated claims directly to Assistant United States Attorney (AUSA) Ryan Finkel. The Government’s re- liance on this fruit of the poisonous tree constitutes systemic prosecutorial misconduct. 2. Trustee Luc Despins’s Unlawful Data Transfer: The suppressed exhibits (specifically a sworn declaration) confirm that Chapter 11 Bankruptcy Trustee Luc Despins unlawfully transferred the data of 1,600 unverified bankruptcy creditors to the Prosecution to artificially manufacture the initial criminal ”victim pool.” When genuine investors disclaimed their status under the Crime Victims’ Rights Act (CVRA), the Government became entirely dependent on the aforementioned RICO syndicate to fabricate replacement claims. The SDNY’s refusal to docket this evidence of collusion and ”evidence launder- ing” actively facilitates the wrongful confiscation of assets belonging to over 6,500 bona fide investors, stripping them of Article III judicial remedies.
Having exhausted all available remedies at the district court level due to the SDNY’s structural blockade, Petitioner respectfully urges this Court to intervene and issue a Writ of Mandamus ordering the following immediate relief: 1. Compel Ministerial Duty: Order the Clerk of the SDNY to immediately and fully docket all eighteen (18) suppressed filings and physical EMS submissions (including the May 4th Rule 104 Motion and Exhibits FF-NN) onto the public CM/ECF docket for Case No. 1:23-cr-00118-AT within twenty-four (24) hours.
Case: 26-1296, 05/11/2026, DktEntry: 7.1, Page 3 of 65
2. Compel Judicial Review: Order the Honorable Judge Analisa Torres to con- vene a mandatory evidentiary hearing pursuant to Federal Rule of Evidence 104 to review the suppressed evidence of the Government’s reliance on co- erced, unverified, and fabricated data. 3. Compel Subpoenas: Order the SDNY to issue mandatory subpoenas com- pelling AUSA Ryan Finkel and Trustee Luc Despins to testify under penalty of perjury regarding their coordinated receipt of bulk fabricated evidence and the unverified transfer of 1,600 creditor files.
I declare under penalty of perjury that the foregoing is true and correct, and that the accompanying Exhibit Index of 18 suppressed emails and EMS receipts accu- rately reflects the SDNY’s structural deprivation of my constitutional rights. The intervention of this Court is the only remaining safeguard against a catastrophic failure of procedural justice. Respectfully submitted this 7th day of May, 2026.
Pro Se / Bona Fide Third-Party Property Owner Standing Confirmed via S.D.N.Y. HID: F56BDDZ
Case: 26-1296, 05/11/2026, DktEntry: 7.1, Page 4 of 65
Case: 26-1296, 05/11/2026, DktEntry: 7.1, Page 5 of 65 UNITED STATES COURT OF APPEALS FOR THE SECOND CIRCUIT Thurgood Marshall U.S. Courthouse 40 Foley Square, New York, NY 10007 Telephone: 212-857-8500
Docket Number(s):
Set forth below precise, complete statement of relief sought:
docket 18 unlawfully suppressed Pro Se fillings (Violating Fed. R. Civ. P. 5(d)(4) and compel Judge Torres to convene a mandatory Fed. R. Evid. 104 hearing regarding the Prosecution's re- liance on fabricated evidence and extrajudicial RICO coordination.
OPPOSING ATTORNEY: Ryan Finkel, Juliana Murray (AUSAS) [name of attorney, with firm, address, phone number and e-mail] Bao Chu, Postfach 888, 1010 Wien, Austria U.S. Attorney's Office. SDNY, One St. Andrew's
Court- Judge/ Agency appealed from: U.S. District Court, SONY/Hon. Analisa Torres Please check appropriate boxes: Has movant notified opposing counsel (required by Local Rule 27.1):
Opposing counsel's position on motion;
Does opposing counsel intend to file a response:
Is oral argument on motion requested?
No (requests for oral argument will not necessarily be granted) Has argument date of appeal been set?
No If yes, enter date: Signature of Moving Attorney:
Date:May 7th, 2026; Service by:
FOR EMERGENCY MOTIONS, MOTIONS FOR STAYS AND INJUCTIONS PENDING APPEAL: Has this request for relief been made below? Has this relief been previously sought in this court?
Requested return date and explanation of emergency: Immediate. The SONY's structural suppression of physical evidence enables ongoing fraud on the court and deprives 6.500+ investors of toarticle III/Fifth Amendment rights ahead of criminal sentencing. Case: 26-1296, 05/11/2026, DktEntry: 7.1, Page 5 of 65
URGENT PRO SE NOTICE: Supplement to Incoming Physical Mail via EMS (Case
I have dispatched an urgent physical package (Pro Se Emergency Motion and 29 Exhibits) to the Honorable Judge Analisa Torres via EMS from Austria on April 17, 2026. The EMS Tracking Number is: [ 1000250003756541000001] ,
In connection with that incoming physical submission, please accept this formal notice regarding my Pro Se status to ensure proper docketing and to prevent any misunderstanding regarding hybrid representation: NOTICE OF PRO SE STATUS & STRICTLY LIMITED SCOPE OF REPRESENTATION (Regarding Case No. 1:23-cr-
To the Honorable Judge Analisa Torres and the Clerk of Court: Please note that while I am concurrently listed as a client of Bradford L. Geyer, his representation of me is strictly limited to the recovery of assets within the ancillary forfeiture proceedings (21 U.S.C. § 853(n)) and/or DOJ Remission. Attorney Geyer does NOT represent me in the underlying criminal proceedings, nor is his mandate authorized to challenge the prosecution's sentencing enhancements, expose prosecutorial misconduct, or present evidence of Fraud on the Court. Because the physical package I just mailed contains 29 substantive exhibits proving that the Government’s Sentencing Memorandum (Dkt. 833) relies heavily on AI-forged evidence and witness perjury, this filing falls entirely outside the scope of Attorney Geyer’s financial recovery mandate. Therefore, I am compelled to submit this Emergency Motion Pro Se under Fed. R. Civ. P. 60(d)(3) and my statutory rights under the Crime Victims' Rights Act (18 U.S.C. § 3771) to ensure the integrity of the sentencing process. Because these two tracks (criminal sentencing integrity vs. ancillary asset recovery) are legally distinct, this Pro Se filing does not constitute improper hybrid representation. Please docket this submission accordingly upon its physical arrival.
Movant Anonymous (Verified by HID: [F56BDDZ] )
Notice_of_Pro_Se_Status_and_Limited_Representation.pdf
EMS_Tracking_Receipt_Exhibits_and_USB.pdf
Gmail - URGENT PRO SE NOTICE: Supplement to Incoming Physical Mail via EMS (Case 1:23-cr-00118-AT)
Case: 26-1296, 05/11/2026, DktEntry: 7.1, Page 6 of 65
Pro Se Filing <pro_se_filing@nysd.uscourts.gov>
Your email has been received by the Pro Se Intake Unit of the United States District Court for the Southern District of New York. (This is not the United States Bankruptcy Court.) Documents from pro se litigants that meet the required standards for electronic filing will be filed and will appear on the ECF docket within two business days of receipt (see required standards below). If you send your document by email and it is accepted for filing, you should not deliver a hard copy version to the court. Requirements for Filing a New Action by Email: · Documents must be attached to the email in PDF format, no larger than 15 megabytes; · The complaint must be signed by the filing party; Fee requirements and instructions: Please note that your complaint will not be reviewed until the court receives payment of the filing fees. · Payment must be made within 30 days of the date your case is assigned a docket number. If mailing payment, please send a certified check, bank check, or money order to: Cashiers Room 260, 500 Pearl Street, New York, NY 10007. · Your payment must include the docket number, which you can learn by calling (212) 805-0175. · If you have not consented to e-service, your docket number will also be mailed to you, at the address provided on the complaint, in a form order that will include payment instructions. If you do not make payment within 30 days of the date a docket number is assigned to your case, the action will be dismissed without prejudice. · If you cannot pay the filing fees and want to request that the court waive the filing fees, you must email an application to proceed in forma pauperis. Filing Documents in an Existing Case by Email: · Documents must be attached to the email in PDF format, no larger than 10 megabytes; · The email and attached document must contain the docket number, filer’s name, address, and telephone number; · Documents must be signed by the filing party; · Any additional comments, questions, or other messages in the email will be disregarded; · Any additional correspondence included in the email will be disregarded.
Gmail - IMPORTANT INFORMATION, PLEASE REVIEW
Case: 26-1296, 05/11/2026, DktEntry: 7.1, Page 7 of 65
For any submission, if your document does not appear on the ECF docket within two business days, it has not met the required standards for electronic filing. If so, you must submit your document to the court in paper form by (a) sending your document by mail, or overnight delivery service, to the appropriate courthouse listed below; or (b) delivering your document in-person to the appropriate courthouse listed below between the hours of 9:30 AM to 1:30 PM; or (c) depositing your document after hours in the court’s night depository box at the 500 Pearl Street, NY, NY courthouse.
Additional resources:
Consent to accept service of documents electronically. Please note that, by consenting to electronic service, you will no longer receive documents by postal mail. For free legal advice, you may make an appointment with the City Bar Justice Center Legal Clinic for Pro Se Litigants by completing the intake form to make an appointment. If a litigant has questions about the intake form or needs to highlight an urgent deadline already disclosed in the form, the clinic can be contacted by phone (212- 382-4794) or email (fedprosdny@nycbar.org). Alternatively, you may leave a message with 212-659-6190.
Gmail - IMPORTANT INFORMATION, PLEASE REVIEW
Case: 26-1296, 05/11/2026, DktEntry: 7.1, Page 8 of 65
URGENT SUPPLEMENT TO PRO SE EMERGENCY MOTION (Case 1:23-cr-00118- AT) - Notice of Structural Defect and Fraud on the Court
Please find attached a Supplemental Memorandum (PDF) to be docketed in Case No. 1:23-cr-00118-AT. This document directly supplements the physical Pro Se Emergency Motion package (including 29 Exhibits) that I dispatched via EMS on April 17, 2026. This PDF attachment contains time-sensitive legal assertions regarding prosecutorial misconduct and Fraud on the Court, submitted pursuant to my statutory rights under the Crime Victims' Rights Act (18 U.S.C. § 3771). Filer Name: Movant Anonymous (Verified by HID: [ F56BDDZ ]) Address: [Currently residing in Europe] Telephone:
Case_1-23-cr-00118_Supplemental_Notice_Fraud_on_the_Court.pdf
Gmail - URGENT SUPPLEMENT TO PRO SE EMERGENCY MOTION (Case 1:23-cr-00118-AT) - Notice of Structural Defect an…
Case: 26-1296, 05/11/2026, DktEntry: 7.1, Page 9 of 65
Pro Se Filing <pro_se_filing@nysd.uscourts.gov>
Your email has been received by the Pro Se Intake Unit of the United States District Court for the Southern District of New York. (This is not the United States Bankruptcy Court.) Documents from pro se litigants that meet the required standards for electronic filing will be filed and will appear on the ECF docket within two business days of receipt (see required standards below). If you send your document by email and it is accepted for filing, you should not deliver a hard copy version to the court. Requirements for Filing a New Action by Email: · Documents must be attached to the email in PDF format, no larger than 15 megabytes; · The complaint must be signed by the filing party; Fee requirements and instructions: Please note that your complaint will not be reviewed until the court receives payment of the filing fees. · Payment must be made within 30 days of the date your case is assigned a docket number. If mailing payment, please send a certified check, bank check, or money order to: Cashiers Room 260, 500 Pearl Street, New York, NY 10007. · Your payment must include the docket number, which you can learn by calling (212) 805-0175. · If you have not consented to e-service, your docket number will also be mailed to you, at the address provided on the complaint, in a form order that will include payment instructions. If you do not make payment within 30 days of the date a docket number is assigned to your case, the action will be dismissed without prejudice. · If you cannot pay the filing fees and want to request that the court waive the filing fees, you must email an application to proceed in forma pauperis. Filing Documents in an Existing Case by Email: · Documents must be attached to the email in PDF format, no larger than 10 megabytes; · The email and attached document must contain the docket number, filer’s name, address, and telephone number; · Documents must be signed by the filing party; · Any additional comments, questions, or other messages in the email will be disregarded; · Any additional correspondence included in the email will be disregarded.
Gmail - IMPORTANT INFORMATION, PLEASE REVIEW
Case: 26-1296, 05/11/2026, DktEntry: 7.1, Page 10 of 65
For any submission, if your document does not appear on the ECF docket within two business days, it has not met the required standards for electronic filing. If so, you must submit your document to the court in paper form by (a) sending your document by mail, or overnight delivery service, to the appropriate courthouse listed below; or (b) delivering your document in-person to the appropriate courthouse listed below between the hours of 9:30 AM to 1:30 PM; or (c) depositing your document after hours in the court’s night depository box at the 500 Pearl Street, NY, NY courthouse.
Additional resources:
Consent to accept service of documents electronically. Please note that, by consenting to electronic service, you will no longer receive documents by postal mail. For free legal advice, you may make an appointment with the City Bar Justice Center Legal Clinic for Pro Se Litigants by completing the intake form to make an appointment. If a litigant has questions about the intake form or needs to highlight an urgent deadline already disclosed in the form, the clinic can be contacted by phone (212- 382-4794) or email (fedprosdny@nycbar.org). Alternatively, you may leave a message with 212-659-6190.
Gmail - IMPORTANT INFORMATION, PLEASE REVIEW
Case: 26-1296, 05/11/2026, DktEntry: 7.1, Page 11 of 65
URGENT ELECTRONIC FILING: Case No. 1:23-cr-00118-AT (Second Supplemental
Please find attached the "Second Supplemental Memorandum to Pro Se Emergency Motion" to be formally docketed in United States v. Ho Wan Kwok, Case No. 1:23-cr-00118-AT . This document is submitted pursuant to my statutory rights as a protected rights-holder under the Crime Victims'
. Please note that this electronic filing is directly correlated with and incorporates by reference the physical exhibits and USB drives previously delivered to the Court (EMS Tracking Nos: 1000250003756541000001 and
. Pursuant to the required standards for Pro Se electronic filing, my identifying information is provided below:
Filer Name: Movant Anonymous (Verified by HID: F56BDDZ) Address: [Currently residing in Europe - Protected Status] Telephone: [N/A - Protected Status]
Case_1-23-cr-00118_Second_Supplemental_Memo_Spoliation_of_Brady_Evidence.pdf
Gmail - URGENT ELECTRONIC FILING: Case No. 1:23-cr-00118-AT (Second Supplemental Memorandum
Case: 26-1296, 05/11/2026, DktEntry: 7.1, Page 12 of 65
Pro Se Filing <pro_se_filing@nysd.uscourts.gov>
Your email has been received by the Pro Se Intake Unit of the United States District Court for the Southern District of New York. (This is not the United States Bankruptcy Court.) Documents from pro se litigants that meet the required standards for electronic filing will be filed and will appear on the ECF docket within two business days of receipt (see required standards below). If you send your document by email and it is accepted for filing, you should not deliver a hard copy version to the court. Requirements for Filing a New Action by Email: · Documents must be attached to the email in PDF format, no larger than 15 megabytes; · The complaint must be signed by the filing party; Fee requirements and instructions: Please note that your complaint will not be reviewed until the court receives payment of the filing fees. · Payment must be made within 30 days of the date your case is assigned a docket number. If mailing payment, please send a certified check, bank check, or money order to: Cashiers Room 260, 500 Pearl Street, New York, NY 10007. · Your payment must include the docket number, which you can learn by calling (212) 805-0175. · If you have not consented to e-service, your docket number will also be mailed to you, at the address provided on the complaint, in a form order that will include payment instructions. If you do not make payment within 30 days of the date a docket number is assigned to your case, the action will be dismissed without prejudice. · If you cannot pay the filing fees and want to request that the court waive the filing fees, you must email an application to proceed in forma pauperis. Filing Documents in an Existing Case by Email: · Documents must be attached to the email in PDF format, no larger than 10 megabytes; · The email and attached document must contain the docket number, filer’s name, address, and telephone number; · Documents must be signed by the filing party; · Any additional comments, questions, or other messages in the email will be disregarded; · Any additional correspondence included in the email will be disregarded.
Gmail - IMPORTANT INFORMATION, PLEASE REVIEW
Case: 26-1296, 05/11/2026, DktEntry: 7.1, Page 13 of 65
For any submission, if your document does not appear on the ECF docket within two business days, it has not met the required standards for electronic filing. If so, you must submit your document to the court in paper form by (a) sending your document by mail, or overnight delivery service, to the appropriate courthouse listed below; or (b) delivering your document in-person to the appropriate courthouse listed below between the hours of 9:30 AM to 1:30 PM; or (c) depositing your document after hours in the court’s night depository box at the 500 Pearl Street, NY, NY courthouse.
Additional resources:
Consent to accept service of documents electronically. Please note that, by consenting to electronic service, you will no longer receive documents by postal mail. For free legal advice, you may make an appointment with the City Bar Justice Center Legal Clinic for Pro Se Litigants by completing the intake form to make an appointment. If a litigant has questions about the intake form or needs to highlight an urgent deadline already disclosed in the form, the clinic can be contacted by phone (212- 382-4794) or email (fedprosdny@nycbar.org). Alternatively, you may leave a message with 212-659-6190.
Gmail - IMPORTANT INFORMATION, PLEASE REVIEW
Case: 26-1296, 05/11/2026, DktEntry: 7.1, Page 14 of 65
URGENT PRO SE FILING: Case No. 1:23-cr-00118 (AT) - Third Supplemental Memorandum (Fraud on the Court) & Exhibits
To the Office of the Clerk and the Honorable Analisa Torres: I am writing to formally submit an urgent Pro Se filing in the matter of United States v. Ho Wan Kwok, et al., Case No. 1:23-cr-00118 (AT). This filing brings to the Court’s immediate attention newly discovered material evidence and official records demonstrating structural Fraud on the Court, requiring judicial notice prior to the upcoming sentencing proceedings. Please find the following four (4) files attached for immediate entry onto the public docket: 1. Case_1-23-cr-00118_Pro_Se_Third_Supplemental_Memorandum_Fraud_on_the_Court.pdf 2. Exhibit_AA_Declaration_of_Good_Faith_Translation_and_Newly_Discovered_Evidence.pdf 3. BOP_TRUVIEW_Inmate_Center_Report_USAO_00297003.pdf 4. Exhibit_Extra_Judicial_ Admission_by_Yongbing_Zhang_Apr_10_2026.mp3 Procedural Notice Regarding Media Exhibit: Pursuant to the Court's 10MB electronic filing size limitation, Exhibit No. 4 is submitted as an extracted .mp3 audio file. This media exhibit constitutes an integral part of the evidentiary submission as detailed in the attached Declaration. Pursuant to the Federal Rules of Criminal Procedure and the fundamental principles of Due Process, I respectfully request that these attached documents and the media exhibit be docketed immediately to ensure proper judicial review.
Movant Anonymous Verified by Court-assigned HID: F56BDDZ Pro Se / Protected Third-Party Rights-Holder
Case_1-23-cr-00118_Pro_Se_Third_Supplemental_Memorandum_Fraud_on_the_Court.pdf.pdf
Exhibit_AA_Declaration_of_Good_Faith_Translation_and_Newly_Discovered_Evidence.pdf.pdf
Exhibit_AA_Proffer_of_Newly_Discovered_Evidence.pdf.pdf
Exhibit_Extra_Judicial_Admission_by_Yongbing_Zhang.mp3.mp3
BOP_TRUVIEW_Inmate_Center_Report_USAO_00297003.pdf.pdf
Gmail - URGENT PRO SE FILING: Case No. 1:23-cr-00118 (AT) - Third Supplemental Memorandum (Fraud on the Court) & Exh…
Case: 26-1296, 05/11/2026, DktEntry: 7.1, Page 15 of 65
Pro Se Filing <pro_se_filing@nysd.uscourts.gov>
Your email has been received by the Pro Se Intake Unit of the United States District Court for the Southern District of New York. (This is not the United States Bankruptcy Court.) Documents from pro se litigants that meet the required standards for electronic filing will be filed and will appear on the ECF docket within two business days of receipt (see required standards below). If you send your document by email and it is accepted for filing, you should not deliver a hard copy version to the court. Requirements for Filing a New Action by Email: · Documents must be attached to the email in PDF format, no larger than 15 megabytes; · The complaint must be signed by the filing party; Fee requirements and instructions: Please note that your complaint will not be reviewed until the court receives payment of the filing fees. · Payment must be made within 30 days of the date your case is assigned a docket number. If mailing payment, please send a certified check, bank check, or money order to: Cashiers Room 260, 500 Pearl Street, New York, NY 10007. · Your payment must include the docket number, which you can learn by calling (212) 805-0175. · If you have not consented to e-service, your docket number will also be mailed to you, at the address provided on the complaint, in a form order that will include payment instructions. If you do not make payment within 30 days of the date a docket number is assigned to your case, the action will be dismissed without prejudice. · If you cannot pay the filing fees and want to request that the court waive the filing fees, you must email an application to proceed in forma pauperis. Filing Documents in an Existing Case by Email: · Documents must be attached to the email in PDF format, no larger than 10 megabytes; · The email and attached document must contain the docket number, filer’s name, address, and telephone number; · Documents must be signed by the filing party; · Any additional comments, questions, or other messages in the email will be disregarded; · Any additional correspondence included in the email will be disregarded.
Gmail - IMPORTANT INFORMATION, PLEASE REVIEW
Case: 26-1296, 05/11/2026, DktEntry: 7.1, Page 16 of 65
For any submission, if your document does not appear on the ECF docket within two business days, it has not met the required standards for electronic filing. If so, you must submit your document to the court in paper form by (a) sending your document by mail, or overnight delivery service, to the appropriate courthouse listed below; or (b) delivering your document in-person to the appropriate courthouse listed below between the hours of 9:30 AM to 1:30 PM; or (c) depositing your document after hours in the court’s night depository box at the 500 Pearl Street, NY, NY courthouse.
Additional resources:
Consent to accept service of documents electronically. Please note that, by consenting to electronic service, you will no longer receive documents by postal mail. For free legal advice, you may make an appointment with the City Bar Justice Center Legal Clinic for Pro Se Litigants by completing the intake form to make an appointment. If a litigant has questions about the intake form or needs to highlight an urgent deadline already disclosed in the form, the clinic can be contacted by phone (212- 382-4794) or email (fedprosdny@nycbar.org). Alternatively, you may leave a message with 212-659-6190.
Gmail - IMPORTANT INFORMATION, PLEASE REVIEW
Case: 26-1296, 05/11/2026, DktEntry: 7.1, Page 17 of 65
URGENT PRO SE FILING: Case No. 1:23-cr-00118 (AT) - Fourth Supplemental Memo & Letter Motion to Compel (Sixth Amendment Interference)
To the Office of the Clerk and the Honorable Analisa Torres: I am writing to formally submit an urgent Pro Se filing in the matter of United States v. Ho Wan Kwok, et al., Case No. 1:23-cr-00118 (AT). This filing brings to the Court’s immediate attention newly discovered audio evidence demonstrating systemic and continuing interference with the Defendant's Sixth Amendment Right to Counsel, along with undisclosed Brady/Giglio material. This requires immediate judicial notice and compels government disclosure prior to the upcoming sentencing proceedings. Please find the following three (3) files attached for immediate entry onto the public docket: 1. Case_1-23-cr-00118_Pro_Se_Fourth_Supplemental_Memo_Sixth_Amendment_Interference.pdf 2. Exhibit_BB_Transcript_and_Translation_Yongbing_Zhang_Admission_of_Sixth_Amendment_Interference.pdf 3. Exhibit_Audio_Yongbing_Zhang_Confession_of_18_USC_1001_Violation_Feb_2024.mp3 Procedural Notice Regarding Media Exhibit: Due to the Court's 10MB electronic filing size limitation for email submissions, Exhibit No. 3 is submitted as an extracted .mp3 audio file. This media exhibit constitutes the ultimate evidentiary truth of the extra-judicial admission detailed in the attached filings, and it is an integral part of this Motion to Compel. Pursuant to the Federal Rules of Criminal Procedure and the fundamental principles of Due Process, I respectfully request that these attached documents and the media exhibit be docketed immediately to ensure proper and timely judicial review.
Movant Anonymous Verified by Court-assigned HID: F56BDDZ Pro Se / Protected Third-Party Rights-Holder
Exhibit_BB_Transcript_and_Translation_Yongbing_Zhang_Admission_of_Sixth_Amendment_
Case_1-23-cr-00118_Pro_Se_Fourth_Supplemental_Memo_Sixth_Amendment_Interference.pdf
Exhibit_Audio_Yongbing_Zhang_Confession_of_18_USC_1001_Violation_Feb_2024.mp3.mp3
Gmail - URGENT PRO SE FILING: Case No. 1:23-cr-00118 (AT) - Fourth Supplemental Memo & Letter Motion to Compel (Sixth …
Case: 26-1296, 05/11/2026, DktEntry: 7.1, Page 18 of 65
Pro Se Filing <pro_se_filing@nysd.uscourts.gov>
Your email has been received by the Pro Se Intake Unit of the United States District Court for the Southern District of New York. (This is not the United States Bankruptcy Court.) Documents from pro se litigants that meet the required standards for electronic filing will be filed and will appear on the ECF docket within two business days of receipt (see required standards below). If you send your document by email and it is accepted for filing, you should not deliver a hard copy version to the court. Requirements for Filing a New Action by Email: · Documents must be attached to the email in PDF format, no larger than 15 megabytes; · The complaint must be signed by the filing party; Fee requirements and instructions: Please note that your complaint will not be reviewed until the court receives payment of the filing fees. · Payment must be made within 30 days of the date your case is assigned a docket number. If mailing payment, please send a certified check, bank check, or money order to: Cashiers Room 260, 500 Pearl Street, New York, NY 10007. · Your payment must include the docket number, which you can learn by calling (212) 805-0175. · If you have not consented to e-service, your docket number will also be mailed to you, at the address provided on the complaint, in a form order that will include payment instructions. If you do not make payment within 30 days of the date a docket number is assigned to your case, the action will be dismissed without prejudice. · If you cannot pay the filing fees and want to request that the court waive the filing fees, you must email an application to proceed in forma pauperis. Filing Documents in an Existing Case by Email: · Documents must be attached to the email in PDF format, no larger than 10 megabytes; · The email and attached document must contain the docket number, filer’s name, address, and telephone number; · Documents must be signed by the filing party; · Any additional comments, questions, or other messages in the email will be disregarded; · Any additional correspondence included in the email will be disregarded.
Gmail - IMPORTANT INFORMATION, PLEASE REVIEW
Case: 26-1296, 05/11/2026, DktEntry: 7.1, Page 19 of 65
For any submission, if your document does not appear on the ECF docket within two business days, it has not met the required standards for electronic filing. If so, you must submit your document to the court in paper form by (a) sending your document by mail, or overnight delivery service, to the appropriate courthouse listed below; or (b) delivering your document in-person to the appropriate courthouse listed below between the hours of 9:30 AM to 1:30 PM; or (c) depositing your document after hours in the court’s night depository box at the 500 Pearl Street, NY, NY courthouse.
Additional resources:
Consent to accept service of documents electronically. Please note that, by consenting to electronic service, you will no longer receive documents by postal mail. For free legal advice, you may make an appointment with the City Bar Justice Center Legal Clinic for Pro Se Litigants by completing the intake form to make an appointment. If a litigant has questions about the intake form or needs to highlight an urgent deadline already disclosed in the form, the clinic can be contacted by phone (212- 382-4794) or email (fedprosdny@nycbar.org). Alternatively, you may leave a message with 212-659-6190.
Gmail - IMPORTANT INFORMATION, PLEASE REVIEW
Case: 26-1296, 05/11/2026, DktEntry: 7.1, Page 20 of 65
URGENT PRO SE FILING: Case No. 1:23-cr-00118 (AT) - Amended Fifth
Dear Clerk of Court and Chambers of the Honorable Judge Analisa Torres, Please find attached the "Pro Se Fifth Supplemental Memorandum (Amended & Consolidated)" submitted by the Movant Anonymous. The Movant is acting Pro Se as a bona fide Third-Party Property Owner protected under the Crime Victims' Rights Act (18 U.S.C. § 3771), officially verified by Court-assigned HID: F56BDDZ. This urgent filing serves as a Judicial Notice presenting incontrovertible physical evidentiary leads and on-the-record trial contradictions (including Timeline Perjury and Undisclosed Conflicts of Interest) that fundamentally destroy the factual basis relied upon by the Government in its Sentencing Memorandum (Dkt. 833). The motion formally demands the issuance of Fed. R. Crim. P. 17(c) subpoenas and the convening of an evidentiary hearing to protect the constitutional rights of third-party property owners. Please be advised that the physical printed copy of this motion, along with the corresponding exhibits and USB drive, have been officially dispatched to the Court via EMS. The physical tracking numbers are as follows: Pro Se Motion EMS Tracking No: 1000250003756541000001 Exhibits and USB EMS Tracking No: 1000250003756551000008 We respectfully request that this attached memorandum be immediately reviewed and entered into the official docket to ensure the preservation of the Movant's Due Process rights under the Fifth Amendment, and to preserve the record for potential appellate review.
Movant Anonymous Verified by HID: F56BDDZ Pro Se / Third-Party Property Owner Case_1-23-cr-00118_Pro_Se_Fifth_Supplemental_Memo_Timeline_Perjury_and_Rule_17c.pdf
Gmail - URGENT PRO SE FILING: Case No. 1:23-cr-00118 (AT) - Amended Fifth Supplemental Memorandum (HID: F56BDDZ)
Case: 26-1296, 05/11/2026, DktEntry: 7.1, Page 21 of 65
Pro Se Filing <pro_se_filing@nysd.uscourts.gov>
Your email has been received by the Pro Se Intake Unit of the United States District Court for the Southern District of New York. (This is not the United States Bankruptcy Court.) Documents from pro se litigants that meet the required standards for electronic filing will be filed and will appear on the ECF docket within two business days of receipt (see required standards below). If you send your document by email and it is accepted for filing, you should not deliver a hard copy version to the court. Requirements for Filing a New Action by Email: · Documents must be attached to the email in PDF format, no larger than 15 megabytes; · The complaint must be signed by the filing party; Fee requirements and instructions: Please note that your complaint will not be reviewed until the court receives payment of the filing fees. · Payment must be made within 30 days of the date your case is assigned a docket number. If mailing payment, please send a certified check, bank check, or money order to: Cashiers Room 260, 500 Pearl Street, New York, NY 10007. · Your payment must include the docket number, which you can learn by calling (212) 805-0175. · If you have not consented to e-service, your docket number will also be mailed to you, at the address provided on the complaint, in a form order that will include payment instructions. If you do not make payment within 30 days of the date a docket number is assigned to your case, the action will be dismissed without prejudice. · If you cannot pay the filing fees and want to request that the court waive the filing fees, you must email an application to proceed in forma pauperis. Filing Documents in an Existing Case by Email: · Documents must be attached to the email in PDF format, no larger than 10 megabytes; · The email and attached document must contain the docket number, filer’s name, address, and telephone number; · Documents must be signed by the filing party; · Any additional comments, questions, or other messages in the email will be disregarded; · Any additional correspondence included in the email will be disregarded.
Gmail - IMPORTANT INFORMATION, PLEASE REVIEW
Case: 26-1296, 05/11/2026, DktEntry: 7.1, Page 22 of 65
For any submission, if your document does not appear on the ECF docket within two business days, it has not met the required standards for electronic filing. If so, you must submit your document to the court in paper form by (a) sending your document by mail, or overnight delivery service, to the appropriate courthouse listed below; or (b) delivering your document in-person to the appropriate courthouse listed below between the hours of 9:30 AM to 1:30 PM; or (c) depositing your document after hours in the court’s night depository box at the 500 Pearl Street, NY, NY courthouse.
Additional resources:
Consent to accept service of documents electronically. Please note that, by consenting to electronic service, you will no longer receive documents by postal mail. For free legal advice, you may make an appointment with the City Bar Justice Center Legal Clinic for Pro Se Litigants by completing the intake form to make an appointment. If a litigant has questions about the intake form or needs to highlight an urgent deadline already disclosed in the form, the clinic can be contacted by phone (212- 382-4794) or email (fedprosdny@nycbar.org). Alternatively, you may leave a message with 212-659-6190.
Gmail - IMPORTANT INFORMATION, PLEASE REVIEW
Case: 26-1296, 05/11/2026, DktEntry: 7.1, Page 23 of 65
URGENT PRO SE FILING: Case 1:23-cr-00118-AT - Emergency Motion (Rule 12.4 Disclosure & Fifth Amendment) - HID: F56BDDZ
Dear Clerk of Court and Chambers of the Honorable Judge Analisa Torres, Please find attached the document titled "Emergency_Motion_Rule_12.4_and_Fifth_Amendment_HID_ F56BDDZ.pdf". This Emergency Motion is submitted by the Movant Anonymous, acting Pro Se as a bona fide Third-Party Property Owner protected under the Crime Victims' Rights Act (18 U.S.C. § 3771), officially verified by Court-assigned HID: F56BDDZ. This urgent filing serves as a Judicial Notice to compel the newly added interested party, "1328777 B.C. Ltd." (Dkt. 840), to strictly comply with the mandatory corporate disclosure requirements of Fed. R. Crim. P. 12.4. Furthermore, it formally demands that the Court apply the exact same procedural standard established in Dkt. 839 to the thousands of bona fide investors who have lawfully filed 21 U.S.C. § 853(n) petitions, in strict compliance with the Equal Protection and Due Process clauses of the Fifth Amendment. Please be advised that the physical printed copy of this motion, along with the corresponding exhibits and USB drive, have been officially dispatched to the Court via EMS. The physical tracking numbers are as follows: Pro Se Emergency Motion EMS Tracking No: 1000250003756541000001 Exhibits and USB EMS Tracking No: 1000250003756551000008 We respectfully request that this attached Emergency Motion be immediately reviewed and entered into the official docket to ensure transparency regarding potential conflicts of interest, to safeguard the Movant's constitutional rights, and to preserve the record for potential appellate review (Writ of Mandamus).
Movant Anonymous Verified by HID: F56BDDZ Pro Se / Third-Party Property Owner Case_1-23-cr-00118_Pro_Se_Emergency_Motion_Rule_12.4_and_Fifth_Amendment_HID_F56BDDZ.pdf
Gmail - URGENT PRO SE FILING: Case 1:23-cr-00118-AT - Emergency Motion (Rule 12.4 Disclosure & Fifth Amendment) - HID…
Case: 26-1296, 05/11/2026, DktEntry: 7.1, Page 24 of 65
Pro Se Filing <pro_se_filing@nysd.uscourts.gov>
Your email has been received by the Pro Se Intake Unit of the United States District Court for the Southern District of New York. (This is not the United States Bankruptcy Court.) Documents from pro se litigants that meet the required standards for electronic filing will be filed and will appear on the ECF docket within two business days of receipt (see required standards below). If you send your document by email and it is accepted for filing, you should not deliver a hard copy version to the court. Requirements for Filing a New Action by Email: · Documents must be attached to the email in PDF format, no larger than 15 megabytes; · The complaint must be signed by the filing party; Fee requirements and instructions: Please note that your complaint will not be reviewed until the court receives payment of the filing fees. · Payment must be made within 30 days of the date your case is assigned a docket number. If mailing payment, please send a certified check, bank check, or money order to: Cashiers Room 260, 500 Pearl Street, New York, NY 10007. · Your payment must include the docket number, which you can learn by calling (212) 805-0175. · If you have not consented to e-service, your docket number will also be mailed to you, at the address provided on the complaint, in a form order that will include payment instructions. If you do not make payment within 30 days of the date a docket number is assigned to your case, the action will be dismissed without prejudice. · If you cannot pay the filing fees and want to request that the court waive the filing fees, you must email an application to proceed in forma pauperis. Filing Documents in an Existing Case by Email: · Documents must be attached to the email in PDF format, no larger than 10 megabytes; · The email and attached document must contain the docket number, filer’s name, address, and telephone number; · Documents must be signed by the filing party; · Any additional comments, questions, or other messages in the email will be disregarded; · Any additional correspondence included in the email will be disregarded.
Gmail - IMPORTANT INFORMATION, PLEASE REVIEW
Case: 26-1296, 05/11/2026, DktEntry: 7.1, Page 25 of 65
For any submission, if your document does not appear on the ECF docket within two business days, it has not met the required standards for electronic filing. If so, you must submit your document to the court in paper form by (a) sending your document by mail, or overnight delivery service, to the appropriate courthouse listed below; or (b) delivering your document in-person to the appropriate courthouse listed below between the hours of 9:30 AM to 1:30 PM; or (c) depositing your document after hours in the court’s night depository box at the 500 Pearl Street, NY, NY courthouse.
Additional resources:
Consent to accept service of documents electronically. Please note that, by consenting to electronic service, you will no longer receive documents by postal mail. For free legal advice, you may make an appointment with the City Bar Justice Center Legal Clinic for Pro Se Litigants by completing the intake form to make an appointment. If a litigant has questions about the intake form or needs to highlight an urgent deadline already disclosed in the form, the clinic can be contacted by phone (212- 382-4794) or email (fedprosdny@nycbar.org). Alternatively, you may leave a message with 212-659-6190.
Gmail - IMPORTANT INFORMATION, PLEASE REVIEW
Case: 26-1296, 05/11/2026, DktEntry: 7.1, Page 26 of 65
URGENT PRO SE FILING: Case 1:23-cr-00118-AT - Sixth Supplemental Memo (Mahwah Settlement & Fraud on the Court) - HID: F56BDDZ
Dear Clerk of Court and Chambers of the Honorable Judge Analisa Torres, Please find attached the following three (3) critical legal documents submitted by the Movant Anonymous, acting Pro Se as a bona fide Third-Party Property Owner protected under the Crime Victims' Rights Act (18 U.S.C. § 3771), officially verified by Court-assigned HID: F56BDDZ: 1. Main Motion: Case_1-23-cr-00118_Pro_Se_Sixth_Supplemental_Memo_Mahwah_Fraud_HID_F56BDDZ.pdf 2. Supporting Evidence I: Official_BOP_Logs_Proving_Phone_Call_Fabrication_Dkt_312-3.pdf 3. Supporting Evidence II: Evidence_of_Identity_Theft_and_Fabricated_Narratives_May_to_Aug_2023.pdf This urgent filing serves as a Judicial Notice demanding the Court to VACATE the "Mahwah Settlement" (Dkt. 204). The attached memorandum and corresponding objective physical evidence irrefutably prove that the foundation of the Mahwah Settlement is fundamentally tainted. Specifically, the Government's own disclosed Federal Bureau of Prisons (BOP) TRUVIEW official logs (Dkt. 312-3) confirm that the phone contact authorization for "May Goo" remained strictly "Inactive" until August 29, 2023, at 6:07:21 PM. This renders the five months of external "family narratives" (from May to August 2023) an absolute physical impossibility, establishing incontrovertible proof of continuous Identity Theft and systemic wire fraud perpetrated by an unauthorized external entity. The Government's knowing concealment of these official timeline contradictions to procure the Court's approval in Dkt. 204 constitutes a textbook Fraud upon the Court. The Movant formally demands the issuance of Fed. R. Crim. P. 17(c) subpoenas to investigate this procedural collusion and spoliation of the Mahwah Property. Please be advised that the physical printed copy of this motion, along with the corresponding exhibits and USB drive, have been officially dispatched to the Court via EMS. The physical tracking numbers are as follows: Pro Se Motion EMS Tracking No: 1000250003756541000001 Exhibits and USB EMS Tracking No: 1000250003756551000008 We respectfully request that this Sixth Supplemental Memorandum and its supporting evidence be immediately reviewed and entered into the official docket. Failure to vacate the tainted settlement agreement upon receipt of such incontrovertible physical evidence shall constitute a Structural Deprivation of the Movant's Due Process rights under the Fifth Amendment, and the Movant explicitly preserves this record for an immediate petition for a Writ of Mandamus to the United States Court of Appeals for the Second Circuit.
Movant Anonymous Verified by HID: F56BDDZ Pro Se / Third-Party Property Owner
Official_BOP_Logs_Proving_Phone_Call_Fabrication_Dkt_312-3.pdf
Case_1-23-cr-00118_Pro_Se_Sixth_Supplemental_Memo_Mahwah_Fraud_HID_F56BDDZ.pdf
Evidence_of_Identity_Theft_and_Fabricated_Narratives_May_to_Aug_2023.pdf
Gmail - URGENT PRO SE FILING: Case 1:23-cr-00118-AT - Sixth Supplemental Memo (Mahwah Settlement & Fraud on the Co…
Case: 26-1296, 05/11/2026, DktEntry: 7.1, Page 27 of 65
Pro Se Filing <pro_se_filing@nysd.uscourts.gov>
Your email has been received by the Pro Se Intake Unit of the United States District Court for the Southern District of New York. (This is not the United States Bankruptcy Court.) Documents from pro se litigants that meet the required standards for electronic filing will be filed and will appear on the ECF docket within two business days of receipt (see required standards below). If you send your document by email and it is accepted for filing, you should not deliver a hard copy version to the court. Requirements for Filing a New Action by Email: · Documents must be attached to the email in PDF format, no larger than 15 megabytes; · The complaint must be signed by the filing party; Fee requirements and instructions: Please note that your complaint will not be reviewed until the court receives payment of the filing fees. · Payment must be made within 30 days of the date your case is assigned a docket number. If mailing payment, please send a certified check, bank check, or money order to: Cashiers Room 260, 500 Pearl Street, New York, NY 10007. · Your payment must include the docket number, which you can learn by calling (212) 805-0175. · If you have not consented to e-service, your docket number will also be mailed to you, at the address provided on the complaint, in a form order that will include payment instructions. If you do not make payment within 30 days of the date a docket number is assigned to your case, the action will be dismissed without prejudice. · If you cannot pay the filing fees and want to request that the court waive the filing fees, you must email an application to proceed in forma pauperis. Filing Documents in an Existing Case by Email: · Documents must be attached to the email in PDF format, no larger than 10 megabytes; · The email and attached document must contain the docket number, filer’s name, address, and telephone number; · Documents must be signed by the filing party; · Any additional comments, questions, or other messages in the email will be disregarded; · Any additional correspondence included in the email will be disregarded.
Gmail - IMPORTANT INFORMATION, PLEASE REVIEW
Case: 26-1296, 05/11/2026, DktEntry: 7.1, Page 28 of 65
For any submission, if your document does not appear on the ECF docket within two business days, it has not met the required standards for electronic filing. If so, you must submit your document to the court in paper form by (a) sending your document by mail, or overnight delivery service, to the appropriate courthouse listed below; or (b) delivering your document in-person to the appropriate courthouse listed below between the hours of 9:30 AM to 1:30 PM; or (c) depositing your document after hours in the court’s night depository box at the 500 Pearl Street, NY, NY courthouse.
Additional resources:
Consent to accept service of documents electronically. Please note that, by consenting to electronic service, you will no longer receive documents by postal mail. For free legal advice, you may make an appointment with the City Bar Justice Center Legal Clinic for Pro Se Litigants by completing the intake form to make an appointment. If a litigant has questions about the intake form or needs to highlight an urgent deadline already disclosed in the form, the clinic can be contacted by phone (212- 382-4794) or email (fedprosdny@nycbar.org). Alternatively, you may leave a message with 212-659-6190.
Gmail - IMPORTANT INFORMATION, PLEASE REVIEW
Case: 26-1296, 05/11/2026, DktEntry: 7.1, Page 29 of 65
URGENT PRO SE FILING: Case 1:23-cr-00118-AT - Emergency Motion (Statutory Standing & Trustee Disqualification) - HID: F56BDDZ
Dear Clerk of Court and Chambers of the Honorable Judge Analisa Torres, Please find attached the document titled "Case_1-23-cr-00118_Pro_Se_Emergency_Motion_Standing_and_ Trustee_Disqualification.pdf". This document is submitted by the Movant Anonymous, acting Pro Se as a bona fide Third-Party Property Owner protected under the Crime Victims' Rights Act (18 U.S.C. § 3771) and asserting exclusive statutory standing under 21 U.S.C. § 853(n), officially verified by Court-assigned HID: F56BDDZ. This urgent filing serves as a Judicial Notice demanding the immediate disqualification of the Bankruptcy Trustee and a STAY of all asset forfeiture and liquidation proceedings currently delegated to him. The attached motion presents specific, verifiable records establishing that the Government engaged in an extra- judicial disposition of criminal forfeiture assets (specifically the Mahwah Property) via a secret agreement dated July 13, 2023, signed by AUSAs Murray, Ferguson, and Finkel. Furthermore, the motion details severe undisclosed financial conflicts of interest involving the Trustee and designated DOJ fugitives, constituting potential perjury under 28 U.S.C. § 1746 and structural violations of 11 U.S.C. § 324. The Government's simultaneous concealment of these extra-judicial agreements while attempting to strip the Movants' statutory standing constitutes an egregious Fraud upon the Court. The Movant formally demands the issuance of Fed. R. Crim. P. 17(c) subpoenas to compel the disclosure of the July 13, 2023 agreement and related conflict-waiver documents. We respectfully request that this Emergency Motion be immediately reviewed and entered into the official docket. Failure to uphold the Movants' indefeasible statutory rights under 21 U.S.C. § 853(n) and investigate these documented procedural violations shall constitute a Structural Deprivation of Due Process. The Movant explicitly preserves this record for an immediate petition for a Writ of Mandamus to the United States Court of Appeals for the Second Circuit.
Movant Anonymous Verified by HID: F56BDDZ Pro Se / Third-Party Property Owner Case_1-23-cr-00118_Pro_Se_Emergency_Motion_Standing_and_Trustee_Disqualification.pdf
Gmail - URGENT PRO SE FILING: Case 1:23-cr-00118-AT - Emergency Motion (Statutory Standing & Trustee Disqualification) - …
Case: 26-1296, 05/11/2026, DktEntry: 7.1, Page 30 of 65
Pro Se Filing <pro_se_filing@nysd.uscourts.gov>
Your email has been received by the Pro Se Intake Unit of the United States District Court for the Southern District of New York. (This is not the United States Bankruptcy Court.) Documents from pro se litigants that meet the required standards for electronic filing will be filed and will appear on the ECF docket within two business days of receipt (see required standards below). If you send your document by email and it is accepted for filing, you should not deliver a hard copy version to the court. Requirements for Filing a New Action by Email: · Documents must be attached to the email in PDF format, no larger than 15 megabytes; · The complaint must be signed by the filing party; Fee requirements and instructions: Please note that your complaint will not be reviewed until the court receives payment of the filing fees. · Payment must be made within 30 days of the date your case is assigned a docket number. If mailing payment, please send a certified check, bank check, or money order to: Cashiers Room 260, 500 Pearl Street, New York, NY 10007. · Your payment must include the docket number, which you can learn by calling (212) 805-0175. · If you have not consented to e-service, your docket number will also be mailed to you, at the address provided on the complaint, in a form order that will include payment instructions. If you do not make payment within 30 days of the date a docket number is assigned to your case, the action will be dismissed without prejudice. · If you cannot pay the filing fees and want to request that the court waive the filing fees, you must email an application to proceed in forma pauperis. Filing Documents in an Existing Case by Email: · Documents must be attached to the email in PDF format, no larger than 10 megabytes; · The email and attached document must contain the docket number, filer’s name, address, and telephone number; · Documents must be signed by the filing party; · Any additional comments, questions, or other messages in the email will be disregarded; · Any additional correspondence included in the email will be disregarded.
Gmail - IMPORTANT INFORMATION, PLEASE REVIEW
Case: 26-1296, 05/11/2026, DktEntry: 7.1, Page 31 of 65
For any submission, if your document does not appear on the ECF docket within two business days, it has not met the required standards for electronic filing. If so, you must submit your document to the court in paper form by (a) sending your document by mail, or overnight delivery service, to the appropriate courthouse listed below; or (b) delivering your document in-person to the appropriate courthouse listed below between the hours of 9:30 AM to 1:30 PM; or (c) depositing your document after hours in the court’s night depository box at the 500 Pearl Street, NY, NY courthouse.
Additional resources:
Consent to accept service of documents electronically. Please note that, by consenting to electronic service, you will no longer receive documents by postal mail. For free legal advice, you may make an appointment with the City Bar Justice Center Legal Clinic for Pro Se Litigants by completing the intake form to make an appointment. If a litigant has questions about the intake form or needs to highlight an urgent deadline already disclosed in the form, the clinic can be contacted by phone (212- 382-4794) or email (fedprosdny@nycbar.org). Alternatively, you may leave a message with 212-659-6190.
Gmail - IMPORTANT INFORMATION, PLEASE REVIEW
Case: 26-1296, 05/11/2026, DktEntry: 7.1, Page 32 of 65
URGENT PRO SE FILING: Case 1:23-cr-00118-AT - Emergency Motion (Statutory Standing & Trustee Disqualification) - HID: F56BDDZ
Dear Clerk of Court and Chambers of the Honorable Judge Analisa Torres, Please find attached the document titled "Case_1-23-cr-00118_Pro_Se_Emergency_Motion_Standing_and_ Trustee_Disqualification.pdf". This document is submitted by the Movant Anonymous, acting Pro Se as a bona fide Third-Party Property Owner protected under the Crime Victims' Rights Act (18 U.S.C. § 3771) and asserting exclusive statutory standing under 21 U.S.C. § 853(n), officially verified by Court-assigned HID: F56BDDZ. This urgent filing serves as a Judicial Notice demanding the immediate disqualification of the Bankruptcy Trustee and a STAY of all asset forfeiture and liquidation proceedings currently delegated to him. The attached motion presents specific, verifiable records establishing that the Government engaged in an extra- judicial disposition of criminal forfeiture assets (specifically the Mahwah Property) via a secret agreement dated July 13, 2023, signed by AUSAs Murray, Ferguson, and Finkel. Furthermore, the motion details severe undisclosed financial conflicts of interest involving the Trustee and designated DOJ fugitives, constituting potential perjury under 28 U.S.C. § 1746 and structural violations of 11 U.S.C. § 324. The Government's simultaneous concealment of these extra-judicial agreements while attempting to strip the Movants' statutory standing constitutes an egregious Fraud upon the Court. The Movant formally demands the issuance of Fed. R. Crim. P. 17(c) subpoenas to compel the disclosure of the July 13, 2023 agreement and related conflict-waiver documents. We respectfully request that this Emergency Motion be immediately reviewed and entered into the official docket. Failure to uphold the Movants' indefeasible statutory rights under 21 U.S.C. § 853(n) and investigate these documented procedural violations shall constitute a Structural Deprivation of Due Process. The Movant explicitly preserves this record for an immediate petition for a Writ of Mandamus to the United States Court of Appeals for the Second Circuit.
Movant Anonymous Verified by HID: F56BDDZ Pro Se / Third-Party Property Owner Case_1-23-cr-00118_Pro_Se_Emergency_Motion_Standing_and_Trustee_Disqualification.pdf
Gmail - URGENT PRO SE FILING: Case 1:23-cr-00118-AT - Emergency Motion (Statutory Standing & Trustee Disqualification) - …
Case: 26-1296, 05/11/2026, DktEntry: 7.1, Page 33 of 65
Pro Se Filing <pro_se_filing@nysd.uscourts.gov>
Your email has been received by the Pro Se Intake Unit of the United States District Court for the Southern District of New York. (This is not the United States Bankruptcy Court.) Documents from pro se litigants that meet the required standards for electronic filing will be filed and will appear on the ECF docket within two business days of receipt (see required standards below). If you send your document by email and it is accepted for filing, you should not deliver a hard copy version to the court. Requirements for Filing a New Action by Email: · Documents must be attached to the email in PDF format, no larger than 15 megabytes; · The complaint must be signed by the filing party; Fee requirements and instructions: Please note that your complaint will not be reviewed until the court receives payment of the filing fees. · Payment must be made within 30 days of the date your case is assigned a docket number. If mailing payment, please send a certified check, bank check, or money order to: Cashiers Room 260, 500 Pearl Street, New York, NY 10007. · Your payment must include the docket number, which you can learn by calling (212) 805-0175. · If you have not consented to e-service, your docket number will also be mailed to you, at the address provided on the complaint, in a form order that will include payment instructions. If you do not make payment within 30 days of the date a docket number is assigned to your case, the action will be dismissed without prejudice. · If you cannot pay the filing fees and want to request that the court waive the filing fees, you must email an application to proceed in forma pauperis. Filing Documents in an Existing Case by Email: · Documents must be attached to the email in PDF format, no larger than 10 megabytes; · The email and attached document must contain the docket number, filer’s name, address, and telephone number; · Documents must be signed by the filing party; · Any additional comments, questions, or other messages in the email will be disregarded; · Any additional correspondence included in the email will be disregarded.
Gmail - IMPORTANT INFORMATION, PLEASE REVIEW
Case: 26-1296, 05/11/2026, DktEntry: 7.1, Page 34 of 65
For any submission, if your document does not appear on the ECF docket within two business days, it has not met the required standards for electronic filing. If so, you must submit your document to the court in paper form by (a) sending your document by mail, or overnight delivery service, to the appropriate courthouse listed below; or (b) delivering your document in-person to the appropriate courthouse listed below between the hours of 9:30 AM to 1:30 PM; or (c) depositing your document after hours in the court’s night depository box at the 500 Pearl Street, NY, NY courthouse.
Additional resources:
Consent to accept service of documents electronically. Please note that, by consenting to electronic service, you will no longer receive documents by postal mail. For free legal advice, you may make an appointment with the City Bar Justice Center Legal Clinic for Pro Se Litigants by completing the intake form to make an appointment. If a litigant has questions about the intake form or needs to highlight an urgent deadline already disclosed in the form, the clinic can be contacted by phone (212- 382-4794) or email (fedprosdny@nycbar.org). Alternatively, you may leave a message with 212-659-6190.
Gmail - IMPORTANT INFORMATION, PLEASE REVIEW
Case: 26-1296, 05/11/2026, DktEntry: 7.1, Page 35 of 65
URGENT PRO SE FILING: Case 1:23-cr-00118-AT - Motion to Strike Dkt. 841 & Compel Rule 12.4 Disclosures - HID: F56BDDZ
Dear Clerk of Court and Chambers of the Honorable Judge Analisa Torres, Please find attached the document titled "Case_1-23-cr-00118_Pro_Se_Emergency_Motion_to_Strike_ Dkt_841_and_Compel_KYC_Tracing.pdf". This document is submitted by the Movant Anonymous, acting Pro Se as a bona fide Third-Party Property Owner asserting Article III standing and absolute statutory rights under 21 U.S.C. § 853(n), officially verified by Court- assigned HID: F56BDDZ. This urgent filing serves as a formal motion to STRIKE the Verified Petition filed by "1328777 B.C. Ltd." (Dkt. 841) from the record due to incurable procedural, jurisdictional, and statutory defects. As detailed in the attached motion, Dkt. 841 presents severe identity discrepancies and potential evasion of mandatory Anti-Money Laundering (AML) and KYC protocols. The execution of the petition in California by a US resident on behalf of a Canadian entity—claiming $6,000,000 from an exchange that strictly banned US and Canadian residents—creates a legal and technical impossibility. Permitting this opaque entity to proceed without a Fed. R. Crim. P. 12.4 Corporate Disclosure Statement raises severe concerns under Rule 11 and 18 U.S.C. § 1001. Furthermore, the Petitioner's failure to provide strict forensic tracing, combined with its explicit, preemptive request to surrender its claims to the Government's administrative remission process (Dkt. 785), constitutes a Constructive Waiver of its § 853(n) judicial rights. We respectfully demand that this Emergency Motion be immediately reviewed and entered into the official ECF docket. Allowing an unverified, legally deficient entity to dilute the finite forfeiture pool while simultaneously paralyzing verified Pro Se investors constitutes a Structural Deprivation of Due Process under the Fifth Amendment. The Movant expressly preserves this record for an immediate petition for a Writ of Mandamus to the United States Court of Appeals for the Second Circuit should the Court fail to docket and act upon this motion.
Movant Anonymous Verified by HID: F56BDDZ Pro Se / Third-Party Property Owner Case_1-23-cr-00118_Pro_Se_Emergency_Motion_to_Strike_Dkt_841_and_Compel_KYC_Tracing.pdf
Gmail - URGENT PRO SE FILING: Case 1:23-cr-00118-AT - Motion to Strike Dkt. 841 & Compel Rule 12.4 Disclosures - HID: F5…
Case: 26-1296, 05/11/2026, DktEntry: 7.1, Page 36 of 65
Pro Se Filing <pro_se_filing@nysd.uscourts.gov>
Your email has been received by the Pro Se Intake Unit of the United States District Court for the Southern District of New York. (This is not the United States Bankruptcy Court.) Documents from pro se litigants that meet the required standards for electronic filing will be filed and will appear on the ECF docket within two business days of receipt (see required standards below). If you send your document by email and it is accepted for filing, you should not deliver a hard copy version to the court. Requirements for Filing a New Action by Email: · Documents must be attached to the email in PDF format, no larger than 15 megabytes; · The complaint must be signed by the filing party; Fee requirements and instructions: Please note that your complaint will not be reviewed until the court receives payment of the filing fees. · Payment must be made within 30 days of the date your case is assigned a docket number. If mailing payment, please send a certified check, bank check, or money order to: Cashiers Room 260, 500 Pearl Street, New York, NY 10007. · Your payment must include the docket number, which you can learn by calling (212) 805-0175. · If you have not consented to e-service, your docket number will also be mailed to you, at the address provided on the complaint, in a form order that will include payment instructions. If you do not make payment within 30 days of the date a docket number is assigned to your case, the action will be dismissed without prejudice. · If you cannot pay the filing fees and want to request that the court waive the filing fees, you must email an application to proceed in forma pauperis. Filing Documents in an Existing Case by Email: · Documents must be attached to the email in PDF format, no larger than 10 megabytes; · The email and attached document must contain the docket number, filer’s name, address, and telephone number; · Documents must be signed by the filing party; · Any additional comments, questions, or other messages in the email will be disregarded; · Any additional correspondence included in the email will be disregarded.
Gmail - IMPORTANT INFORMATION, PLEASE REVIEW
Case: 26-1296, 05/11/2026, DktEntry: 7.1, Page 37 of 65
For any submission, if your document does not appear on the ECF docket within two business days, it has not met the required standards for electronic filing. If so, you must submit your document to the court in paper form by (a) sending your document by mail, or overnight delivery service, to the appropriate courthouse listed below; or (b) delivering your document in-person to the appropriate courthouse listed below between the hours of 9:30 AM to 1:30 PM; or (c) depositing your document after hours in the court’s night depository box at the 500 Pearl Street, NY, NY courthouse.
Additional resources:
Consent to accept service of documents electronically. Please note that, by consenting to electronic service, you will no longer receive documents by postal mail. For free legal advice, you may make an appointment with the City Bar Justice Center Legal Clinic for Pro Se Litigants by completing the intake form to make an appointment. If a litigant has questions about the intake form or needs to highlight an urgent deadline already disclosed in the form, the clinic can be contacted by phone (212- 382-4794) or email (fedprosdny@nycbar.org). Alternatively, you may leave a message with 212-659-6190.
Gmail - IMPORTANT INFORMATION, PLEASE REVIEW
Case: 26-1296, 05/11/2026, DktEntry: 7.1, Page 38 of 65
URGENT PRO SE FILING: Case 1:23-cr-00118-AT - Supplemental Notice of Evidence (Witness Tampering) & Exhibit 1 - HID: F56BDDZ
Dear Clerk of Court and Chambers of the Honorable Judge Analisa Torres, Please find concurrently attached two documents for immediate filing in Case No. 1:23-cr-00118-AT: "Case_1-23-cr-00118_Pro_Se_Supplemental_Notice_Witness_Tampering.pdf" (The Main Supplemental Notice) "Case_1-23-cr-00118_Supplemental_Exhibit_1_Alliance_Translations.pdf" (The Evidentiary Exhibit containing original
These documents are submitted by the Movant Anonymous, acting Pro Se as a bona fide Third-Party Property Owner, officially verified by Court-assigned HID: F56BDDZ. This urgent filing serves as a Supplemental Notice of Filing and Proffer of Newly Discovered Evidence. It substantiates the Movant’s prior emergency motions regarding coordinated witness tampering, the Unauthorized Practice of Law (UPL), and structural Fraud upon the Court. As detailed in the Supplemental Notice and unequivocally proven by Supplemental Exhibit 1, an unregistered syndicate is unlawfully soliciting and coordinating 1,800 individuals across international borders in direct violation of Giglio v. United States and 18 U.S.C. § 371. The Court cannot entertain mass-produced claims orchestrated by an illegal proxy designed to dilute the lawful forfeiture pool. We respectfully demand that this Supplemental Notice and its accompanying Exhibit 1 be immediately reviewed and entered into the official ECF docket to preserve the integrity of the judicial process. The Movant expressly preserves this record for appellate review should the Court fail to docket and act upon this indisputable evidence of witness coordination.
Movant Anonymous Verified by HID: F56BDDZ Pro Se / Third-Party Property Owner
Case_1-23-cr-00118_Pro_Se_Supplemental_Notice_Witness_Tampering.pdf
Case_1-23-cr-00118_Supplemental_Exhibit_1_Alliance_Translations.pdf
Gmail - URGENT PRO SE FILING: Case 1:23-cr-00118-AT - Supplemental Notice of Evidence (Witness Tampering) & Exhibit 1 -…
Case: 26-1296, 05/11/2026, DktEntry: 7.1, Page 39 of 65
Pro Se Filing <pro_se_filing@nysd.uscourts.gov>
Your email has been received by the Pro Se Intake Unit of the United States District Court for the Southern District of New York. (This is not the United States Bankruptcy Court.) Documents from pro se litigants that meet the required standards for electronic filing will be filed and will appear on the ECF docket within two business days of receipt (see required standards below). If you send your document by email and it is accepted for filing, you should not deliver a hard copy version to the court. Requirements for Filing a New Action by Email: · Documents must be attached to the email in PDF format, no larger than 15 megabytes; · The complaint must be signed by the filing party; Fee requirements and instructions: Please note that your complaint will not be reviewed until the court receives payment of the filing fees. · Payment must be made within 30 days of the date your case is assigned a docket number. If mailing payment, please send a certified check, bank check, or money order to: Cashiers Room 260, 500 Pearl Street, New York, NY 10007. · Your payment must include the docket number, which you can learn by calling (212) 805-0175. · If you have not consented to e-service, your docket number will also be mailed to you, at the address provided on the complaint, in a form order that will include payment instructions. If you do not make payment within 30 days of the date a docket number is assigned to your case, the action will be dismissed without prejudice. · If you cannot pay the filing fees and want to request that the court waive the filing fees, you must email an application to proceed in forma pauperis. Filing Documents in an Existing Case by Email: · Documents must be attached to the email in PDF format, no larger than 10 megabytes; · The email and attached document must contain the docket number, filer’s name, address, and telephone number; · Documents must be signed by the filing party; · Any additional comments, questions, or other messages in the email will be disregarded; · Any additional correspondence included in the email will be disregarded.
Gmail - IMPORTANT INFORMATION, PLEASE REVIEW
Case: 26-1296, 05/11/2026, DktEntry: 7.1, Page 40 of 65
For any submission, if your document does not appear on the ECF docket within two business days, it has not met the required standards for electronic filing. If so, you must submit your document to the court in paper form by (a) sending your document by mail, or overnight delivery service, to the appropriate courthouse listed below; or (b) delivering your document in-person to the appropriate courthouse listed below between the hours of 9:30 AM to 1:30 PM; or (c) depositing your document after hours in the court’s night depository box at the 500 Pearl Street, NY, NY courthouse.
Additional resources:
Consent to accept service of documents electronically. Please note that, by consenting to electronic service, you will no longer receive documents by postal mail. For free legal advice, you may make an appointment with the City Bar Justice Center Legal Clinic for Pro Se Litigants by completing the intake form to make an appointment. If a litigant has questions about the intake form or needs to highlight an urgent deadline already disclosed in the form, the clinic can be contacted by phone (212- 382-4794) or email (fedprosdny@nycbar.org). Alternatively, you may leave a message with 212-659-6190.
Gmail - IMPORTANT INFORMATION, PLEASE REVIEW
Case: 26-1296, 05/11/2026, DktEntry: 7.1, Page 41 of 65
URGENT PRO SE FILING : Case 1:23-cr-00118-AT - Emergency Motion to Disqualify Witness Yoe Zhou (RICO & Extortion) & Exhibits 2A-2D - HID: F56BDDZ
Dear Clerk of Court and Chambers of the Honorable Judge Analisa Torres, Please find concurrently attached FIVE (5) documents for immediate filing and review in Case No. 1:23-cr-00118-AT. These documents are submitted by the Movant Anonymous, acting Pro Se as a bona fide Third-Party Property Owner, officially verified by Court-assigned HID: F56BDDZ. The attached five files comprise a single, integrated legal filing: The Main Motion: A Pro Se Emergency Motion to Disqualify Compromised Government Witness Yoe Zhou (Forest Zhou) based on a continuous pattern of Racketeering, AI Evidence Fabrication, Extortion against 6,512 verified investors, and ongoing Cross-Jurisdictional Court Tampering. Supplemental Exhibit 2A (MP3 Audio): Original evidence of the illicit livestream broadcast (1m39s). Supplemental Exhibit 2B (PDF Translation): Certified English translation of Exhibit 2A containing the witness's explicit Consciousness of Guilt. Supplemental Exhibit 2C (MP3 Audio): Original evidence of the illicit livestream broadcast (4m13s). Supplemental Exhibit 2D (PDF Translation): Certified English translation of Exhibit 2C containing directives to circumvent a federal court order. This Emergency Motion exposes that the Government's registered star witness is actively operating a criminal syndicate (the "Alliance") to defraud multiple federal courts, execute Hobbs Act Extortion (18 U.S.C. § 1951), and engage in Aggravated Identity Theft targeting confidential Court HID codes. Relying on this witness constitutes an egregious Giglio violation and suborns structural perjury. We respectfully demand that the Clerk's Office immediately enter ALL FIVE attached files (the Main Motion PDF and the four Supplemental Exhibits) into the official ECF docket to preserve the integrity of the judicial process. The Movant expressly preserves this email transmission and its timestamps for appellate review. Should the Court or the Clerk's Office fail to docket these materials or ignore this smoking-gun evidence of witness criminality, it will constitute a Structural Deprivation of Due Process and trigger an immediate petition for a Writ of Mandamus to the United States Court of Appeals for the Second Circuit. Respectfully submitted on this 29th day of April, 2026, at 16:45 EST, Movant Anonymous Verified by HID: F56BDDZ Pro Se / Third-Party Property Owner
Case_1-23-cr-00118_Pro_Se_Emergency_Motion_Disqualify_YoeZhou_RICO_Extortion.pdf
Supplemental_Exhibit_2A_Audio_Livestream_1m39s.mp3
Supplemental_Exhibit_2B_Transcript_Translation_1m39s.pdf
Supplemental_Exhibit_2C_Audio_Livestream_4m13s.mp3
_Supplemental_Exhibit_2D_Transcript_Translation_4m13s.pdf
Gmail - URGENT PRO SE FILING : Case 1:23-cr-00118-AT - Emergency Motion to Disqualify Witness Yoe Zhou (RICO & Extorti…
Case: 26-1296, 05/11/2026, DktEntry: 7.1, Page 42 of 65
Pro Se Filing <pro_se_filing@nysd.uscourts.gov>
Your email has been received by the Pro Se Intake Unit of the United States District Court for the Southern District of New York. (This is not the United States Bankruptcy Court.) Documents from pro se litigants that meet the required standards for electronic filing will be filed and will appear on the ECF docket within two business days of receipt (see required standards below). If you send your document by email and it is accepted for filing, you should not deliver a hard copy version to the court. Requirements for Filing a New Action by Email: · Documents must be attached to the email in PDF format, no larger than 15 megabytes; · The complaint must be signed by the filing party; Fee requirements and instructions: Please note that your complaint will not be reviewed until the court receives payment of the filing fees. · Payment must be made within 30 days of the date your case is assigned a docket number. If mailing payment, please send a certified check, bank check, or money order to: Cashiers Room 260, 500 Pearl Street, New York, NY 10007. · Your payment must include the docket number, which you can learn by calling (212) 805-0175. · If you have not consented to e-service, your docket number will also be mailed to you, at the address provided on the complaint, in a form order that will include payment instructions. If you do not make payment within 30 days of the date a docket number is assigned to your case, the action will be dismissed without prejudice. · If you cannot pay the filing fees and want to request that the court waive the filing fees, you must email an application to proceed in forma pauperis. Filing Documents in an Existing Case by Email: · Documents must be attached to the email in PDF format, no larger than 10 megabytes; · The email and attached document must contain the docket number, filer’s name, address, and telephone number; · Documents must be signed by the filing party; · Any additional comments, questions, or other messages in the email will be disregarded; · Any additional correspondence included in the email will be disregarded.
Gmail - IMPORTANT INFORMATION, PLEASE REVIEW
Case: 26-1296, 05/11/2026, DktEntry: 7.1, Page 43 of 65
For any submission, if your document does not appear on the ECF docket within two business days, it has not met the required standards for electronic filing. If so, you must submit your document to the court in paper form by (a) sending your document by mail, or overnight delivery service, to the appropriate courthouse listed below; or (b) delivering your document in-person to the appropriate courthouse listed below between the hours of 9:30 AM to 1:30 PM; or (c) depositing your document after hours in the court’s night depository box at the 500 Pearl Street, NY, NY courthouse.
Additional resources:
Consent to accept service of documents electronically. Please note that, by consenting to electronic service, you will no longer receive documents by postal mail. For free legal advice, you may make an appointment with the City Bar Justice Center Legal Clinic for Pro Se Litigants by completing the intake form to make an appointment. If a litigant has questions about the intake form or needs to highlight an urgent deadline already disclosed in the form, the clinic can be contacted by phone (212- 382-4794) or email (fedprosdny@nycbar.org). Alternatively, you may leave a message with 212-659-6190.
Gmail - IMPORTANT INFORMATION, PLEASE REVIEW
Case: 26-1296, 05/11/2026, DktEntry: 7.1, Page 44 of 65
URGENT PRO SE FILING: Supplemental Memorandum and Exhibit CC (Case No.
Attached please find a "PRO SE SUPPLEMENTAL MEMORANDUM" and its corresponding physical evidence "Exhibit CC" for immediate filing and docketing in the matter of United States v. Ho Wan Kwok, Case No. 1:23-cr- 00118 (AT), before the Honorable Judge Analisa Torres. I am submitting these documents Pro Se as a bona fide Third-Party Property Owner (Court-assigned HID: F56BDDZ). The attached filings contain critical judicial notices and physical evidence regarding ongoing RICO violations and structural defects impacting the current 21 U.S.C. § 853(n) ancillary proceedings. Attached Documents (2): Case_1-23-cr-00118_Pro_Se_Supplemental_Memo_RICO_Violations_HID_F56BDDZ.pdf (Main Document) Exhibit_CC_Physical_Evidence_and_Translation_Feb_2025.pdf (Exhibit) Please ensure both the Memorandum and Exhibit CC are docketed accordingly on the public docket and routed to Judge Torres's chambers for immediate review. Thank you for your prompt assistance in ensuring my Fifth Amendment due process rights are protected.
Bao Chu Pro Se / Bona Fide Third-Party Property Owner Verified Court-Assigned HID: F56BDDZ
Case_1-23-cr-00118_Pro_Se_Supplemental_Memo_RICO_Violations_HID_F56BDDZ.pdf
Exhibit_CC_Physical_Evidence_and_Translation_Feb_2025.pdf
Gmail - URGENT PRO SE FILING: Supplemental Memorandum and Exhibit CC (Case No. 1:23-cr-00118-AT) - HID: F56BDDZ
Case: 26-1296, 05/11/2026, DktEntry: 7.1, Page 45 of 65
Pro Se Filing <pro_se_filing@nysd.uscourts.gov>
收件人:bao chu <huangkeke2185@gmail.com>
Your email has been received by the Pro Se Intake Unit of the United States District Court for the Southern District of New York. (This is not the United States Bankruptcy Court.) Documents from pro se litigants that meet the required standards for electronic filing will be filed and will appear on the ECF docket within two business days of receipt (see required standards below). If you send your document by email and it is accepted for filing, you should not deliver a hard copy version to the court. Requirements for Filing a New Action by Email: · Documents must be attached to the email in PDF format, no larger than 15 megabytes; · The complaint must be signed by the filing party; Fee requirements and instructions: Please note that your complaint will not be reviewed until the court receives payment of the filing fees. · Payment must be made within 30 days of the date your case is assigned a docket number. If mailing payment, please send a certified check, bank check, or money order to: Cashiers Room 260, 500 Pearl Street, New York, NY 10007. · Your payment must include the docket number, which you can learn by calling (212) 805-0175. · If you have not consented to e-service, your docket number will also be mailed to you, at the address provided on the complaint, in a form order that will include payment instructions. If you do not make payment within 30 days of the date a docket number is assigned to your case, the action will be dismissed without prejudice. · If you cannot pay the filing fees and want to request that the court waive the filing fees, you must email an application to proceed in forma pauperis. Filing Documents in an Existing Case by Email: · Documents must be attached to the email in PDF format, no larger than 10 megabytes; · The email and attached document must contain the docket number, filer’s name, address, and telephone number; · Documents must be signed by the filing party; · Any additional comments, questions, or other messages in the email will be disregarded;
Gmail - IMPORTANT INFORMATION, PLEASE REVIEW
Case: 26-1296, 05/11/2026, DktEntry: 7.1, Page 46 of 65
· Any additional correspondence included in the email will be disregarded. For any submission, if your document does not appear on the ECF docket within two business days, it has not met the required standards for electronic filing. If so, you must submit your document to the court in paper form by (a) sending your document by mail, or overnight delivery service, to the appropriate courthouse listed below; or (b) delivering your document in-person to the appropriate courthouse listed below between the hours of 9:30 AM to 1:30 PM; or (c) depositing your document after hours in the court’s night depository box at the 500 Pearl Street, NY, NY courthouse.
Additional resources:
Consent to accept service of documents electronically. Please note that, by consenting to electronic service, you will no longer receive documents by postal mail. For free legal advice, you may make an appointment with the City Bar Justice Center Legal Clinic for Pro Se Litigants by completing the intake form to make an appointment. If a litigant has questions about the intake form or needs to highlight an urgent deadline already disclosed in the form, the clinic can be contacted by phone (212- 382-4794) or email (fedprosdny@nycbar.org). Alternatively, you may leave a message with 212-659-6190.
Gmail - IMPORTANT INFORMATION, PLEASE REVIEW
Case: 26-1296, 05/11/2026, DktEntry: 7.1, Page 47 of 65
[URGENT PRO SE FILING & NOTICE OF CLERK'S MINISTERIAL DUTY] Case No. 1:23-cr-00118-AT - Motion for Mandatory Rule 104 Hearing & Exhibits
抄送:Ryan.Finkel@usdoj.gov, Juliana.Murray@usdoj.gov, Micah.Fergenson@usdoj.gov, Justin.Horton@usdoj.gov Dear Clerk of Court and the Honorable Analisa Torres, Re: United States v. Ho Wan Kwok, et al., Case No. 1:23-cr-00118-AT I. URGENT NOTICE TO THE CLERK REGARDING PENDING DOCKET ENTRIES AND MINISTERIAL DUTY TO
The Applicant formally brings to the Clerk’s and the Court’s immediate attention that over the past 14 days, the Applicant has transmitted fourteen (14) separate legal emails and urgent motions to this Court. As of this hour, none of these critical submissions have been docketed on the CM/ECF system. Pursuant to Federal Rule of Civil Procedure 5(d)(4), the Clerk possesses a strictly ministerial duty to file submissions and must not refuse or delay filing. The continuous administrative delay of over 10 days functions as an unconstitutional "pocket veto," severely prejudicing the Applicant and actively depriving bona fide third-party property owners of their Fifth Amendment Due Process rights while the Government's forfeiture proceedings continue to advance. Given the imminent and ongoing Fraud on the Court detailed in the attached Emergency Motion, the Applicant respectfully, yet firmly, demands the expedited docketing of this specific email, the main motion, and all attached exhibits onto the public ECF docket within forty-eight (48) hours of receipt. Any further refusal or administrative delay in docketing these critical physical exhibits will constitute a deliberate structural error, serving as absolute documentary evidence of procedural deprivation ripe for an immediate Writ of Mandamus (28 U.S.C. § 1361) before the Second Circuit Court of Appeals. II. SUBMISSION OF EMERGENCY MOTION FOR RULE 104 HEARING Pursuant to the Federal Rules of Criminal Procedure and the Court's guidelines for Pro Se litigants, the Applicant hereby formally submits to the United States District Court for the Southern District of New York this emergency motion and the accompanying physical exhibits for the record. The attached "Emergency Motion for a Mandatory Rule 104 Evidentiary Hearing and Burden-Shifting" and its exhibits provide irrefutable prima facie evidence of a systemic Fraud on the Court. Physical dockets and written communications prove that the Prosecution and Chapter 11 Trustee Luc Despins relied upon an extrajudicial RICO syndicate to execute witness tampering and the unauthorized practice of law (UPL). Furthermore, they unlawfully transferred unverified bankruptcy data to artificially manufacture a "victim" pool, intending to bypass the Court's Article III gatekeeping duties. Under the Federal Rules of Evidence, the Court must convene a Rule 104 evidentiary hearing and issue compulsory subpoenas to Assistant United States Attorney Ryan Finkel and Trustee Luc Despins. Should the Court refuse to investigate this explicit documentary evidence of collusion between government officials and extrajudicial criminals, such refusal will constitute a Structural Error and Complicity in Fraud on the Court. III. ATTACHMENTS TO BE DOCKETED: Main Motion: PRO_SE_EMERGENCY_MOTION_FOR_MANDATORY_RULE_104_HEARING_
Exhibit FF: Physical_Evidence_of_RICO_Syndicate_Coordinating_with_Prosecution_to_Bypass_Judicial_Scrutiny.pdf Exhibit GG: Certified_English_Transcript_Exposing_Extortion_and_UPL_via_DOJ_Remission_Process.pdf Exhibit HH: Excerpt_from_Sworn_Declaration_Confirming_Trustee_Unverified_Transfer_of_Bankruptcy_Creditors.pdf Exhibit KK: Certified_Official_Himalaya_Exchange_Directive_and_Syndicate_Admission_of_Non_Involvement.pdf Exhibit MM: Certified_Internal_Meeting_Minutes_and_Directives_of_Qingteng_Syndicate.pdf Exhibit NN: The_Syndicates_Perjury_Manufacturing_Assembly_Line_and_Direct_Pipeline_to_AUSA_Finkel.pdf The Clerk is respectfully requested to fulfill their ministerial duty, confirm receipt of this email, and formally docket the aforementioned main motion and all physical exhibits within forty-eight (48) hours. The Applicant declares under penalty of perjury that the attached documents and evidence are submitted truthfully and accurately.
Date: May 4, 2026 [Bao Chu] (s/Bao Chu) Verified by Court-assigned HID: [F56BDDZ]
PRO SE EMERGENCY MOTION FOR A MANDATORY RULE 104 EVIDENTIARY HEARING, INVOCATION OF ADVERSE INFERENCE, AND BURDEN SHIFTING.pdf
Gmail - [URGENT PRO SE FILING & NOTICE OF CLERK'S MINISTERIAL DUTY] Case No. 1:23-cr-00118-AT - Motion for Mand…
Case: 26-1296, 05/11/2026, DktEntry: 7.1, Page 48 of 65
Exhibit FF Physical Evidence of the RICO Syndicate Coordinating with the Prosecution to Bypass §
Exhibit GG Certified English Transcript of March 7, 2025 Broadcast Exposing Extortion and UPL via the
Exhibit HH Excerpt from Sworn Declaration (Dkt. 844) Confirming Trustee Luc Despins’s Unverified Transfer of 1,600 Bankruptcy Creditors.pdf
Exhibit KK Certified Official Himalaya Exchange Legal Directive and the Syndicate’s Extrajudicial Admission of Non-Involvement (July 2023).pdf
Exhibit MMCertified Internal Meeting Minutes and Directives of the Qingteng Syndicate (Feb-Apr
Exhibit NNThe Syndicate's Perjury Manufacturing Assembly Line and Direct Pipeline to AUSA Finkel.pdf
Gmail - [URGENT PRO SE FILING & NOTICE OF CLERK'S MINISTERIAL DUTY] Case No. 1:23-cr-00118-AT - Motion for Mand…
Case: 26-1296, 05/11/2026, DktEntry: 7.1, Page 49 of 65
Pro Se Filing <pro_se_filing@nysd.uscourts.gov>
收件人:bao chu <huangkeke2185@gmail.com>
Your email has been received by the Pro Se Intake Unit of the United States District Court for the Southern District of New York. (This is not the United States Bankruptcy Court.) Documents from pro se litigants that meet the required standards for electronic filing will be filed and will appear on the ECF docket within two business days of receipt (see required standards below). If you send your document by email and it is accepted for filing, you should not deliver a hard copy version to the court. Requirements for Filing a New Action by Email: · Documents must be attached to the email in PDF format, no larger than 15 megabytes; · The complaint must be signed by the filing party; Fee requirements and instructions: Please note that your complaint will not be reviewed until the court receives payment of the filing fees. · Payment must be made within 30 days of the date your case is assigned a docket number. If mailing payment, please send a certified check, bank check, or money order to: Cashiers Room 260, 500 Pearl Street, New York, NY 10007. · Your payment must include the docket number, which you can learn by calling (212) 805-0175. · If you have not consented to e-service, your docket number will also be mailed to you, at the address provided on the complaint, in a form order that will include payment instructions. If you do not make payment within 30 days of the date a docket number is assigned to your case, the action will be dismissed without prejudice. · If you cannot pay the filing fees and want to request that the court waive the filing fees, you must email an application to proceed in forma pauperis. Filing Documents in an Existing Case by Email: · Documents must be attached to the email in PDF format, no larger than 10 megabytes; · The email and attached document must contain the docket number, filer’s name, address, and telephone number; · Documents must be signed by the filing party; · Any additional comments, questions, or other messages in the email will be disregarded; · Any additional correspondence included in the email will be disregarded.
Gmail - IMPORTANT INFORMATION, PLEASE REVIEW
Case: 26-1296, 05/11/2026, DktEntry: 7.1, Page 50 of 65
For any submission, if your document does not appear on the ECF docket within two business days, it has not met the required standards for electronic filing. If so, you must submit your document to the court in paper form by (a) sending your document by mail, or overnight delivery service, to the appropriate courthouse listed below; or (b) delivering your document in-person to the appropriate courthouse listed below between the hours of 9:30 AM to 1:30 PM; or (c) depositing your document after hours in the court’s night depository box at the 500 Pearl Street, NY, NY courthouse.
Additional resources:
Consent to accept service of documents electronically. Please note that, by consenting to electronic service, you will no longer receive documents by postal mail. For free legal advice, you may make an appointment with the City Bar Justice Center Legal Clinic for Pro Se Litigants by completing the intake form to make an appointment. If a litigant has questions about the intake form or needs to highlight an urgent deadline already disclosed in the form, the clinic can be contacted by phone (212- 382-4794) or email (fedprosdny@nycbar.org). Alternatively, you may leave a message with 212-659-6190.
Gmail - IMPORTANT INFORMATION, PLEASE REVIEW
Case: 26-1296, 05/11/2026, DktEntry: 7.1, Page 51 of 65
Case: 26-1296, 05/11/2026, DktEntry: 7.1, Page 52 of 65
...
Pursuant to the applicable Federal Rules of Civil and Criminal Procedure, Movant (S.D.N.Y. HID: F56BDDZ), a bona fide third-party property owner, hereby submits the attached Pro Se Motion and its corresponding evidentiary exhibits for immediate filing and entry onto the official docket in Case No. 1:23-cr-00118-AT. Please find the following four (4) files strictly formatted and attached to this transmission: 1.Case_1-23-cr-00118-AT_Pro_Se_Motion_Regarding_Dkt_841_and_18_USC_1512_Hearing.pdf (The Principal Motion) 2.Exhibit_C_Certified_Translation_Alliance_Statement_on_Dkt_841.pdf (Certified Translation under 28 U.S.C. § 1746) 3.Exhibit_D_Certified_Translation_Yoe_Zhou_Broadcast_Transcript_May_4.pdf (Certified Translation under 28 U.S.C. § 1746) 4.Exhibit_D_Original_Audio_Yoe_Zhou_Broadcast_May_4_2026.mp3 (Original Best Evidence Audio File) This submission addresses critical statutory and procedural conflicts regarding Docket No. 841. It presents documented evidence of extrajudicial conduct involving registered prosecution witness Yoe Zhou (Forest Zhou, Qingteng), necessitating immediate judicial review under 18 U.S.C. § 1621 (Perjury) or 18 U.S.C. § 1512 (Witness Tampering). By copy of this email, all relevant parties, including the Prosecution and Defense Counsel of record, are simultaneously served. I respectfully request the Clerk to process this filing without delay to preserve the integrity of the judicial process.
/s/ Bao Chu Pro Se / Bona Fide Third-Party Property Owner Standing Confirmed via S.D.N.Y. HID: F56BDDZ
..........
PDF Case_1-23-cr-00 ... POF Exhibit_C_Certifie ... PDF Exhibit_D_Certifie ... Exhibit_D_Origina ... URGENT PRO SE FILING - Case No. 1:23-cr-00118-AT: Motion Regarding Dkt. 841 and Request for 18 U.S.C. § 1512 Hearing (HID: F56BDDZ)
发送至 ProSe, Torres_NYSDChambers, CAO2db, ryan.finkel, jkaley ▼ Dear Clerk of Court and Chambers of the Honorable Judge Analisa Torres,
Case: 26-1296, 05/11/2026, DktEntry: 7.1, Page 52 of 65
Pro Se Filing <pro_se_filing@nysd.uscourts.gov>
收件人:bao chu <huangkeke2185@gmail.com>
Your email has been received by the Pro Se Intake Unit of the United States District Court for the Southern District of New York. (This is not the United States Bankruptcy Court.) Documents from pro se litigants that meet the required standards for electronic filing will be filed and will appear on the ECF docket within two business days of receipt (see required standards below). If you send your document by email and it is accepted for filing, you should not deliver a hard copy version to the court. Requirements for Filing a New Action by Email: · Documents must be attached to the email in PDF format, no larger than 15 megabytes; · The complaint must be signed by the filing party; Fee requirements and instructions: Please note that your complaint will not be reviewed until the court receives payment of the filing fees. · Payment must be made within 30 days of the date your case is assigned a docket number. If mailing payment, please send a certified check, bank check, or money order to: Cashiers Room 260, 500 Pearl Street, New York, NY 10007. · Your payment must include the docket number, which you can learn by calling (212) 805-0175. · If you have not consented to e-service, your docket number will also be mailed to you, at the address provided on the complaint, in a form order that will include payment instructions. If you do not make payment within 30 days of the date a docket number is assigned to your case, the action will be dismissed without prejudice. · If you cannot pay the filing fees and want to request that the court waive the filing fees, you must email an application to proceed in forma pauperis. Filing Documents in an Existing Case by Email: · Documents must be attached to the email in PDF format, no larger than 10 megabytes; · The email and attached document must contain the docket number, filer’s name, address, and telephone number; · Documents must be signed by the filing party; · Any additional comments, questions, or other messages in the email will be disregarded;
Gmail - IMPORTANT INFORMATION, PLEASE REVIEW
Case: 26-1296, 05/11/2026, DktEntry: 7.1, Page 53 of 65
· Any additional correspondence included in the email will be disregarded. For any submission, if your document does not appear on the ECF docket within two business days, it has not met the required standards for electronic filing. If so, you must submit your document to the court in paper form by (a) sending your document by mail, or overnight delivery service, to the appropriate courthouse listed below; or (b) delivering your document in-person to the appropriate courthouse listed below between the hours of 9:30 AM to 1:30 PM; or (c) depositing your document after hours in the court’s night depository box at the 500 Pearl Street, NY, NY courthouse.
Additional resources:
Consent to accept service of documents electronically. Please note that, by consenting to electronic service, you will no longer receive documents by postal mail. For free legal advice, you may make an appointment with the City Bar Justice Center Legal Clinic for Pro Se Litigants by completing the intake form to make an appointment. If a litigant has questions about the intake form or needs to highlight an urgent deadline already disclosed in the form, the clinic can be contacted by phone (212- 382-4794) or email (fedprosdny@nycbar.org). Alternatively, you may leave a message with 212-659-6190.
Gmail - IMPORTANT INFORMATION, PLEASE REVIEW
Case: 26-1296, 05/11/2026, DktEntry: 7.1, Page 54 of 65
URGENT PRO SE FILING - Case No. 1:23-cr-00118-AT: Emergency Motion for Brady/Giglio Disclosures and 18 U.S.C. §§ 1512 & 242 Investigation (HID:
收件人:ProSe@nysd.uscourts.gov, Torres_NYSDChambers@nysd.uscourts.gov 抄送:CA02db ProSeCases <prosecases@ca2.uscourts.gov>, ryan.finkel@usdoj.gov, Juliana.Murray@usdoj.gov,
Dear Clerk of Court and Chambers of the Honorable Judge Analisa Torres, Pursuant to the applicable Federal Rules of Civil and Criminal Procedure, Movant (S.D.N.Y. HID: F56BDDZ), a bona fide third-party property owner, hereby submits the attached Pro Se Emergency Motion and its corresponding evidentiary exhibits for immediate filing and entry onto the official docket in Case No. 1:23-cr-00118-AT. Please find the following three (3) files strictly formatted and attached to this transmission: Case_1-23-cr-00118-AT_Pro_Se_Emergency_Motion_Brady_Giglio_Immigration_Extortion.pdf (The Principal Motion) Exhibit_E_Certified_Translation_Yoe_Zhou_Asylum_Extortion_Audio.pdf (Certified Translation under 28 U.S.C. §
Exhibit_E_Original_Audio_Yoe_Zhou_Asylum_Threat_May_4_2026.mp3 (Original Best Evidence Audio File) This submission addresses critical constitutional and statutory conflicts. It presents documented evidence that a registered Prosecution witness, Yoe Zhou (Forest Zhou, Qingteng), has publicly asserted the authority to review and revoke U.S. federal political asylum applications to compel witness compliance. This necessitates immediate judicial review regarding potential inter-agency coordination (DOJ/USCIS) under Giglio v. United States, 405 U.S. 150 (1972), or an investigation into extrajudicial witness extortion and deprivation of rights under color of law pursuant to 18 U.S.C. § 1512(b) and § 242. By copy of this email, all relevant parties, including the Prosecution and Defense Counsel of record, are simultaneously served. I respectfully request the Clerk to process this filing without delay to preserve the constitutional integrity of the ongoing proceedings.
/s/ Bao Chu Bao Chu Pro Se / Bona Fide Third-Party Property Owner Standing Confirmed via S.D.N.Y. HID: F56BDDZ Mailing Address: Postfach 888, 1010 Wien, Austria (Notice: Physical residential address is explicitly withheld from the public docket to ensure physical safety and to prevent documented threats of transnational repression and witness intimidation related to the Chinese Communist Party's "Operation Fox Hunt".) Telephone: +43 1 23456789 Email: huangkeke2185@gmail.com
Exhibit_E_Original_Audio_Yoe_Zhou_Asylum_Threat_May_4_2026.mp3
Case_1-23-cr-00118-AT_Pro_Se_Emergency_Motion_Brady_Giglio_Immigration_Extortion.pdf
Exhibit_E_Certified_Translation_Yoe_Zhou_Asylum_Extortion_Audio.pdf
Gmail - URGENT PRO SE FILING - Case No. 1:23-cr-00118-AT: Emergency Motion for Brady/Giglio Disclosures and 18 U.S.C. …
Case: 26-1296, 05/11/2026, DktEntry: 7.1, Page 55 of 65
Pro Se Filing <pro_se_filing@nysd.uscourts.gov>
收件人:bao chu <huangkeke2185@gmail.com>
Your email has been received by the Pro Se Intake Unit of the United States District Court for the Southern District of New York. (This is not the United States Bankruptcy Court.) Documents from pro se litigants that meet the required standards for electronic filing will be filed and will appear on the ECF docket within two business days of receipt (see required standards below). If you send your document by email and it is accepted for filing, you should not deliver a hard copy version to the court. Requirements for Filing a New Action by Email: · Documents must be attached to the email in PDF format, no larger than 15 megabytes; · The complaint must be signed by the filing party; Fee requirements and instructions: Please note that your complaint will not be reviewed until the court receives payment of the filing fees. · Payment must be made within 30 days of the date your case is assigned a docket number. If mailing payment, please send a certified check, bank check, or money order to: Cashiers Room 260, 500 Pearl Street, New York, NY 10007. · Your payment must include the docket number, which you can learn by calling (212) 805-0175. · If you have not consented to e-service, your docket number will also be mailed to you, at the address provided on the complaint, in a form order that will include payment instructions. If you do not make payment within 30 days of the date a docket number is assigned to your case, the action will be dismissed without prejudice. · If you cannot pay the filing fees and want to request that the court waive the filing fees, you must email an application to proceed in forma pauperis. Filing Documents in an Existing Case by Email: · Documents must be attached to the email in PDF format, no larger than 10 megabytes; · The email and attached document must contain the docket number, filer’s name, address, and telephone number; · Documents must be signed by the filing party; · Any additional comments, questions, or other messages in the email will be disregarded; · Any additional correspondence included in the email will be disregarded.
Gmail - IMPORTANT INFORMATION, PLEASE REVIEW
Case: 26-1296, 05/11/2026, DktEntry: 7.1, Page 56 of 65
For any submission, if your document does not appear on the ECF docket within two business days, it has not met the required standards for electronic filing. If so, you must submit your document to the court in paper form by (a) sending your document by mail, or overnight delivery service, to the appropriate courthouse listed below; or (b) delivering your document in-person to the appropriate courthouse listed below between the hours of 9:30 AM to 1:30 PM; or (c) depositing your document after hours in the court’s night depository box at the 500 Pearl Street, NY, NY courthouse.
Additional resources:
Consent to accept service of documents electronically. Please note that, by consenting to electronic service, you will no longer receive documents by postal mail. For free legal advice, you may make an appointment with the City Bar Justice Center Legal Clinic for Pro Se Litigants by completing the intake form to make an appointment. If a litigant has questions about the intake form or needs to highlight an urgent deadline already disclosed in the form, the clinic can be contacted by phone (212- 382-4794) or email (fedprosdny@nycbar.org). Alternatively, you may leave a message with 212-659-6190.
Gmail - IMPORTANT INFORMATION, PLEASE REVIEW
Case: 26-1296, 05/11/2026, DktEntry: 7.1, Page 57 of 65
URGENT PRO SE FILING - Case No. 1:23-cr-00118-AT: Emergency Motion Under 21 U.S.C. § 853(n) to Reject Tainted Forfeiture Pool and Oppose Any Redaction of
收件人:ProSe@nysd.uscourts.gov, Torres_NYSDChambers@nysd.uscourts.gov 抄送:CA02db ProSeCases <prosecases@ca2.uscourts.gov>, ryan.finkel@usdoj.gov, Juliana.Murray@usdoj.gov,
Dear Clerk of Court and Chambers of the Honorable Judge Analisa Torres, Pursuant to the applicable Federal Rules of Civil and Criminal Procedure, Movant (S.D.N.Y. HID: F56BDDZ), a bona fide third-party property owner proceeding exclusively under 21 U.S.C. § 853(n), hereby submits the attached Pro Se Emergency Motion for immediate filing and entry onto the official docket in Case No. 1:23-cr-00118-AT. Please find the following file strictly formatted and attached to this transmission: Case_1-23-cr-00118-AT_Pro_Se_Motion_853n_Fraud_and_Dkt_847_Objection.pdf This submission addresses critical constitutional and statutory conflicts threatening the integrity of the forfeiture proceedings. It presents objective, on-the-record evidence from Dkt. 846 that a key Prosecution witness managing the subject funds explicitly admitted under oath to deceiving federal banks to open accounts (a violation of 18 U.S.C. § 1344). Furthermore, this motion serves as a formal Notice of Objection under Dkt. 847, opposing any attempt by the Prosecution to redact or conceal these felony admissions outside the strict personal data identifier limitations of Fed. R. Crim. P. 49.1. The Prosecution cannot lawfully seize third-party assets utilizing a forfeiture pool contaminated by witnesses who actively engaged in bank fraud (18 U.S.C. § 1344) and extrajudicial extortion (18 U.S.C. § 1512). Movant demands a Rule 104 Evidentiary Hearing to protect the constitutional property rights of bona fide investors. By copy of this email, all relevant parties are simultaneously served.
/s/ Bao Chu Bao Chu Pro Se / Bona Fide Third-Party Property Owner Standing Confirmed via S.D.N.Y. HID: F56BDDZ Mailing Address: Postfach 888, 1010 Wien, Austria (Notice: Physical residential address is explicitly withheld from the public docket to ensure physical safety and to prevent documented threats of transnational repression and witness intimidation related to the Chinese Communist Party's "Operation Fox Hunt".) Telephone: +43 1 23456789 Email: huangkeke2185@gmail.com
Case_1-23-cr-00118-AT_Pro_Se_Motion_853n_Fraud_and_Dkt_847_Objection.pdf
Gmail - URGENT PRO SE FILING - Case No. 1:23-cr-00118-AT: Emergency Motion Under 21 U.S.C. § 853(n) to Reject Tainted …
Case: 26-1296, 05/11/2026, DktEntry: 7.1, Page 58 of 65
Pro Se Filing <pro_se_filing@nysd.uscourts.gov>
收件人:bao chu <huangkeke2185@gmail.com>
Your email has been received by the Pro Se Intake Unit of the United States District Court for the Southern District of New York. (This is not the United States Bankruptcy Court.) Documents from pro se litigants that meet the required standards for electronic filing will be filed and will appear on the ECF docket within two business days of receipt (see required standards below). If you send your document by email and it is accepted for filing, you should not deliver a hard copy version to the court. Requirements for Filing a New Action by Email: · Documents must be attached to the email in PDF format, no larger than 15 megabytes; · The complaint must be signed by the filing party; Fee requirements and instructions: Please note that your complaint will not be reviewed until the court receives payment of the filing fees. · Payment must be made within 30 days of the date your case is assigned a docket number. If mailing payment, please send a certified check, bank check, or money order to: Cashiers Room 260, 500 Pearl Street, New York, NY 10007. · Your payment must include the docket number, which you can learn by calling (212) 805-0175. · If you have not consented to e-service, your docket number will also be mailed to you, at the address provided on the complaint, in a form order that will include payment instructions. If you do not make payment within 30 days of the date a docket number is assigned to your case, the action will be dismissed without prejudice. · If you cannot pay the filing fees and want to request that the court waive the filing fees, you must email an application to proceed in forma pauperis. Filing Documents in an Existing Case by Email: · Documents must be attached to the email in PDF format, no larger than 10 megabytes; · The email and attached document must contain the docket number, filer’s name, address, and telephone number; · Documents must be signed by the filing party; · Any additional comments, questions, or other messages in the email will be disregarded;
Gmail - IMPORTANT INFORMATION, PLEASE REVIEW
Case: 26-1296, 05/11/2026, DktEntry: 7.1, Page 59 of 65
· Any additional correspondence included in the email will be disregarded. For any submission, if your document does not appear on the ECF docket within two business days, it has not met the required standards for electronic filing. If so, you must submit your document to the court in paper form by (a) sending your document by mail, or overnight delivery service, to the appropriate courthouse listed below; or (b) delivering your document in-person to the appropriate courthouse listed below between the hours of 9:30 AM to 1:30 PM; or (c) depositing your document after hours in the court’s night depository box at the 500 Pearl Street, NY, NY courthouse.
Additional resources:
Consent to accept service of documents electronically. Please note that, by consenting to electronic service, you will no longer receive documents by postal mail. For free legal advice, you may make an appointment with the City Bar Justice Center Legal Clinic for Pro Se Litigants by completing the intake form to make an appointment. If a litigant has questions about the intake form or needs to highlight an urgent deadline already disclosed in the form, the clinic can be contacted by phone (212- 382-4794) or email (fedprosdny@nycbar.org). Alternatively, you may leave a message with 212-659-6190.
Gmail - IMPORTANT INFORMATION, PLEASE REVIEW
Case: 26-1296, 05/11/2026, DktEntry: 7.1, Page 60 of 65
Kontaktperson [Telefon_nummer oder E·樞uL八
Handelsrechnung mit Beschreibung und Wert des Sendungsinhalts muss bei Warensendungen - in ein Bestimmungstand auBerhalb der EU - beiliegen!
iJ. ..
arabischen Ziffern ausfiillen.
unter der Nummer 0800 010 100. DerAbsenderakzepnert dIeAGB Post Express in derzum Zeitpunkt desVertragsabschlusses geItenden Fassung. DerAbsender 笠巴E三巴5三百i'声dneas;555;芷笠三三三王2三三c;閾:l:;;SeZden
Case: 26-1296, 05/11/2026, DktEntry: 7.1, Page 61 of 65
l l.
111111 llilliiliilllill丨|ll|lI丨11111111
Der Absender akzeptiert die AGB Post Ex;;;;;; ln.derzum Zeltpunkt des Vertragsabschlusses geltenden Fassung. Der Abs 氐函`gt zudem die Richtigkeit und 1/otlst鉫叱.e,t der in diesem Express-Frachtbrief gegebenen Auskunfte sow,e class d Sendung kemeNICHTzugelassen窋6iite,澤尹denAGBGefahrcut mderzumZenpunkt desVe rtragsabschIussesceIte
t zurKenn所5,dassdIe 訌ndung aus Sicherheitsgriinden geoffnet w,rd
Ill :,r ll.
Osterreichische Post AG I Rechtsform: Aktiengesellschaft I Sitz in potit心her Gerneinde 闐en I FN 180219d des Handelsgerichts Wien I Materialnummer 7662040261 Case: 26-1296, 05/11/2026, DktEntry: 7.1, Page 62 of 65
Case: 26-1296, 05/11/2026, DktEntry: 7.1, Page 63 of 65
Tracking number:
Original tracking number:
Sender:
Destination postcode:
found.
wählen!
delivery options in your Post Account.
for this?
inspection to determine if duties will be charged or if all import regulations were complied with. This might take a few days.
download?
sticker.
Case: 26-1296, 05/11/2026, DktEntry: 7.1, Page 63 of 65
Case: 26-1296, 05/11/2026, DktEntry: 7.1, Page 64 of 65
Tracking number:
Original tracking number:
Sender:
Destination postcode:
found.
wählen!
delivery options in your Post Account.
for this?
inspection to determine if duties will be charged or if all import regulations were complied with. This might take a few days.
download?
sticker.
Case: 26-1296, 05/11/2026, DktEntry: 7.1, Page 64 of 65
Case: 26-1296, 05/11/2026, DktEntry: 7.1, Page 65 of 65 UNITED STATES COURT OF APPEALS FOR THE SECOND CIRCUIT CAPTION:
V.
hereby certify under penalty of perjury that
, I served a copy of Emergency Petitionfor
on the following parties:
Analisa Torres (District Court, SONY, 500 Pearl Street
Address U.S. Attorney's City New York State NYZip Code Juliana Murray, Micah Rehy Office, SONY, One St.
Name John F. Kalay Address 217 Broadway City New York State NY
*A party must serve a copy of each paper on the other parties, or their counsel, to the appeal or proceeding. The Court will reject papers for filing if a certificate of service is not simultaneously filed. ** If different methods of service have been used on different parties, please complete a separate certificate of service for each party.
Certificate of Service Form (Last Revised 12/2015) Case: 26-1296, 05/11/2026, DktEntry: 7.1, Page 65 of 65
SUBSCRIBE
New filings added to this archive go out in the weekly brief.
No email-open or email-link tracking. One-click unsubscribe. or use RSS · details