Miles Trial Day 3 - Court transcript and translation, version 1

Original Court Transcript(原始庭审记录)

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UNITED STATES DISTRICT COURT

SOUTHERN DISTRICT OF NEW YORK

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UNITED STATES OF AMERICA,

v. 23 Cr. 118 (AT)

MILES GUO,

Defendant. Trial

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New York, N.Y.

May 24, 2024

10:15 a.m.

Before:

HON. ANALISA TORRES,

District Judge

-and a Jury-

APPEARANCES

DAMIAN WILLIAMS

United States Attorney for the

Southern District of New York

BY: MICAH F. FERGENSON

RYAN B. FINKEL

JUSTIN HORTON

JULIANA N. MURRAY

Assistant United States Attorneys

SABRINA P. SHROFF

Attorney for Defendant

PRYOR CASHMAN LLP

Attorneys for Defendant

BY: SIDHARDHA KAMARAJU

MATTHEW BARKAN

ALSTON & BIRD LLP

Attorneys for Defendant

BY: E. SCOTT SCHIRICK

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ALSO PRESENT:

Isabel Loftus, Paralegal Specialist, USAO

Michael Gartland, Paralegal Specialist, USAO

Geoffrey Mearns, Paralegal Specialist, USAO

Robert Stout, Special Agent, FBI

Ruben Montilla, Defense Paralegal

Tuo Huang, Interpreter (Mandarin)

Shi Feng, Interpreter (Mandarin)

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(A jury of 12 and six alternates was duly impaneled

and sworn)

THE COURT: Counsel, would you approach, please.

(At the sidebar)

THE COURT: Who's opening for the government?

MR. FERGENSON: I am, your Honor.

THE COURT: And for the defense.

MS. SHROFF: I am.

THE COURT: All right. You may step back.

MS. SHROFF: Thank you.

(In open court)

THE COURT: Good morning.

THE JURORS: Good morning.

THE COURT: Members of the jury, the case is

officially on trial, and you are the jurors in the case. As

you can see, the jury is composed of 12 members. In addition,

there are six alternates. If you are an alternate, you need to

pay as close attention to the evidence as the jury. If for any

reason any one of the members of the jury is unable to serve,

an alternate will be required to step into the place of that

juror.

I now will give you some preliminary instructions to

guide you in your participation in the trial.

The second part of the trial is about to start. This

part is the opening statement by the prosecution. In the

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opening statement by the government, he's required to indicate

to you what the prosecution intends to prove by way of evidence

to support the charges against the defendant. Once the

government's opening statement has been completed, defense

counsel has the option to make an opening statement.

Now what attorneys say in an opening statement is not

evidence. An opening statement is, in a sense, a preview of

what the attorney expects that the evidence will show.

Next, the government will present a witness and will

ask the witness questions. This is called direct examination.

Once the government completes those questions, the defense will

then be given an opportunity to question the witness. This is

called cross-examination. This process will continue for each

witness the prosecution will present to give testimony.

When the government finishes calling all of its

witnesses, the defense will be given the opportunity to present

witnesses also. Remember, the defense need not prove anything.

Therefore, they do not have to cross-examine the government's

witnesses or offer their own witnesses.

Once both sides have finished presenting witnesses,

the defense and the prosecution will be given the opportunity

to make closing remarks to you. These closing arguments will

not be evidence. They are just arguments made by the attorneys

to discuss the facts and circumstances in the case, and they

should be confined to the evidence and to reasonable inferences

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to be drawn from the evidence. So again, neither opening

statements nor closing remarks are evidence, and you should

disregard any statement or argument made by the attorney that

is not based on the evidence.

After closing arguments, I will give you detailed

instructions on the law that relates to this particular case.

When I finish my instructions, you will then retire to

deliberate to reach a verdict.

Now I'm going to instruct you on evidence. First let

me tell you what evidence is.

Basically, evidence consists of oral testimony under

oath, any stipulations of the parties, and physical exhibits

during the trial that are introduced by either the prosecution

or the defense and allowed into evidence. If an exhibit is

given to you to examine, you should examine it carefully,

individually, and without comment.

There are two types of evidence——direct and

circumstantial. Direct evidence is direct proof of a fact such

as testimony of an eyewitness. Circumstantial evidence is

proof of facts from which you may infer or conclude that other

facts exist. There's a simple example of circumstantial

evidence that is often used in this courthouse. Assume that

when you came into the courthouse this morning, the sun was

shining and it was a nice day. Assume that the courtroom

shades were down and you could not look outside. As you were

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sitting here, someone walked in with an umbrella that was

dripping wet. Then a few minutes later, another person also

entered with a wet umbrella. Now you cannot look outside the

courtroom and you cannot see whether or not it is raining, so

you have no direct evidence of that fact, but on the

combination of facts that I have asked you to assume, it would

be reasonable and logical for you to conclude that it had been

raining. That is all there is to circumstantial evidence. You

infer, on the basis of reason and experience and common sense,

from one established fact the existence or nonexistence of some

other fact.

Not all circumstantial evidence presents clear,

compelling inference. The strength of the inferences arising

from circumstantial evidence is for you to decide. I will give

you further instructions on these as well as other matters at

the end of the case, but have in mind that you may consider

both kinds of evidence.

If you're instructed that some evidence is received

for a limited purpose only, you must follow that instruction.

Questions asked by either attorney or even myself are

not in and of themselves evidence. Only questions coupled with

answers are evidence. Therefore, you may not infer any fact

from the mere asking of a question. The reason that I point

this out to you is simple. During the course of questioning,

the prosecution and the defense may exercise their right to

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object to the other's question, to an answer given to a

question, or to introduction of an exhibit on the ground that

the attorney believes it is somehow legally improper or

inadmissible. At that point I will sustain or overrule the

objection. If I sustain an objection to a question, you must

disregard the question and any answer, if one has been given.

You must also draw no inference from the question or from any

answer. Nor are you to speculate as to what the witness would

have said if permitted to answer.

Evidence stricken from the record must likewise be

disregarded.

Conversely, if I overrule the objection, the question

will be allowed and the answer will stand, and it remains as

evidence. When I overrule an objection to any evidence, you

must not give such evidence any more weight than if the

objection had not been made.

Please bear in mind that my rulings on the law are

simply that, and under no circumstance are such rulings to be

considered by you as indicating that I have any opinion as to

the guilt or innocence of the defendant. Under our law, the

judge may not and will not entertain any opinion as to the

guilt or innocence of the accused. Members of the jury, you

and you alone are the sole and exclusive judges of the facts.

Now I want you to understand that objections may come

rather quickly, and at times either party may seem worried.

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Please do not resent this or penalize either party for this.

Understand that they are just doing their job and this is part

of it.

As I stated at the beginning, you are the triers of

fact. Therefore, it is up to you to decide which witness to

believe and which witness not to believe. Furthermore, you

will decide how much of every witness's testimony to accept and

how much to reject.

How do you decide what to believe and what not to

believe? Listen to the witnesses, watch them, and observe

them, then decide whether you believe or disbelieve them in the

same way that you decide such questions in your everyday life.

Did they know what they were talking about? Were they candid,

honest, open, and truthful? Do they have a reason to falsify,

exaggerate, or distort their testimony? Just use your common

sense in evaluating all testimony. All that is asked of you is

that you apply the same common sense you would apply in your

everyday lives to determine who is telling you the truth, who

is not, and who is telling you something less than the full

truth.

Please remember that it is the quality of the evidence

that controls, not the quantity of the evidence, or the number

of witnesses called by either side.

You must decide the case solely on the evidence and

law before you, and must not be influenced by any personal

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likes or dislikes, opinions, prejudices, sympathy, or biases,

including unconscious bias. Unconscious or implicit biases are

stereotypes, attitudes, or preferences that people may

consciously reject but which may be expressed without conscious

awareness, control, or intention. Like conscious bias,

unconscious bias too can affect how we evaluate information to

make decisions. All of us, no matter how hard we try, tend to

look at others and tend to weigh what they have to say through

the lens of our own experience and background. We each have a

tendency to stereotype others and to make assumptions about

them. Often we see lights and evaluate evidence through a

clouded filter that tends to favor those like ourselves. You

must do your best to put aside such stereotypes, for all

litigants and witnesses are entitled to a level playing field

in which we do the best that we can to put aside stereotypes

and prejudices. You are to be guided solely by the evidence in

the case and my instructions on the law.

Although you are the sole judges of the facts, my job

is to be the sole judge of the law. You must accept the law as

I give it to you, without any hesitation or reservation. You

must accept the law as I give it even if you privately disagree

with me or the law.

There are three basic principles of law that apply to

this and all criminal cases——the presumption of innocence, the

prosecution's burden, and the standard of proof.

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First, the presumption of innocence. A defendant is

presumed innocent, and that presumption remains with the

defendant throughout the trial and is not removed unless and

until the defendant's guilt is proven beyond a reasonable

doubt. The indictment containing the charges against the

defendant is only an accusation, nothing more. It is not proof

of guilt or anything else. Therefore, because no evidence has

been presented to you as of yet, if you were to deliberate

right now, you would have to find the defendant not guilty.

Second is the prosecution's burden. The burden of

proof is on the government. The defense has no burden and is

not required to do anything to prove his innocence. The

defense has the option of just sitting back and doing nothing.

Why? Because the defense has no burden of proof, and the

defendant is presumed innocent. The defendant is not required

to put on a defense or call any witnesses because of the

presumption of innocence. If the defendant chooses not to take

the stand, to testify on his behalf, you may not draw any

negative inference from that; in other words, you cannot hold

that against the defendant.

Third is the standard of proof. The prosecution is

required to prove the defendant's guilt beyond a reasonable

doubt. This standard does not require the prosecution to prove

the defendant's guilt beyond all doubt or to a mathematical

certainty. The prosecution does, however, have to prove the

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defendant's guilt beyond a reasonable doubt. The doubt is not

reasonable if, instead of being based on the nature and quality

of the evidence or the insufficiency of the evidence, it is

based on some guess or whim or speculation unrelated to the

evidence.

In my final instructions to you at the end of the

trial, I will give you detailed instructions on the law as to

the specific charges against the defendant. Those instructions

are intended to guide you through your deliberations and to

enable you to reach your decision.

Finally, I'm now going to instruct you on how you must

conduct yourselves during the trial.

You must keep an open mind during the trial.

You must keep your eyes open during the trial.

You may not ask the witnesses questions.

Do not converse, either amongst yourselves or with

anyone else, about anything related to the case. You may tell

the people with whom you live and your employer that you are a

juror and give them information about when you'll be required

to be in court, but you may not talk with them or anyone else

about anything related to the case. Do not at any time during

the trial request, accept, agree to accept, or discuss with any

person the receipt or acceptance of any payment or benefit in

return for supplying information about the trial. You must

promptly report directly to me any incident within your

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knowledge involving an attempt by any person to improperly

influence you or any other member of the jury.

Do not visit or view the premises or place where the

charged crimes were allegedly committed or any other premises

or place involved in the case. And you may not use internet

maps or Google Earth or any other program or device to search

for and view any location stated in the testimony.

Do not read, view, or listen to any accounts or

discussions of the case reported by newspapers, television,

radio, the internet, social media, or any other form of news

media. Do not attempt to research any fact, issue, or law

related to this case, whether by discussion with others, by

research in a library, or on the internet, or by any other

means or source.

In this age of instant electronic communication and

research, I want to emphasize that in addition to not

conversing face to face with anyone about the case, you must

not communicate with anyone about the case by any other means,

including by telephone, text messages, email, internet chat or

chat rooms, blogs, or social websites, such as Facebook and X.

You must not provide any information about the case to anyone

by any means whatsoever, and that includes the posting of

information about the case or what you are doing in the case,

on any device or internet site, including blogs, chat rooms,

social websites, or any other means.

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You must also not Google or otherwise search for any

information about the case or the law that applies to the case

or the people involved in the case, including the defendant,

the witnesses, the lawyers, and myself.

Now, ladies and gentlemen, I want you to understand

why these rules are so important. Our law does not permit

jurors to converse with anyone else about the case or for

anyone to talk to them about the case because only jurors are

authorized to render a verdict, only you have been found to be

fair, and only you have promised to be fair. No one else has

been so qualified.

Our law also does not permit jurors to converse among

themselves about the case until the judge tells them to begin

deliberations, because premature discussion can lead to a

premature final decision.

Our law also does not permit you to visit a place

discussed in the testimony. First, you cannot always be sure

that the place is in the same condition as it was on the day in

question; second, even if it were in the same condition, once

you go to a place discussed in the testimony to evaluate the

evidence in light of what you see, you become a witness, not a

juror. As a witness, you may now have an erroneous view of the

scene that may not be subject to correction by either party.

That is not fair.

Finally, our law requires that you not read or listen

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to any news accounts of the case and that you not attempt to

research any fact, issue, or law related to the case. Your

decision must be based solely on the testimony and other

evidence presented in the courtroom. It would not be fair to

the parties for you to base your decision on some reporter's

view or opinion or upon information you acquire outside of the

courtroom.

These rules are designed to help guarantee a fair

trial, and our law accordingly sets forth serious consequences

if the rules are not followed. I trust you understand and

appreciate the importance of following the rules, and in accord

with your oath and promise, I know you will do so.

During the trial, it may be necessary for me to confer

with the lawyers out of your hearing with regard to questions

of law or procedure. On some occasions you may be excused from

the courtroom for that reason. I will try to limit these

interruptions as much as possible, but you should remember the

importance of the matter you are here to determine, and should

be patient even though the case may seem to go slowly.

Finally, I permit jurors to take notes, but you do not

have to take notes. Notes are just an aid in your own

recollection. The court reporters in this case record

everything that is said in the courtroom, and any portion of

the testimony can be read back to you here in open court during

your deliberations.

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If you do take notes, be aware that note-taking might

distract you from something important that is happening on the

witness stand. Whether or not you take notes, rely on your own

recollection, and don't be influenced by the fact that another

juror has taken notes.

I just told you that you are to report any attempt by

anyone to improperly influence you. Lawyers are not permitted

to have any contact with you other than what takes place on the

record in this courtroom. If you see an attorney, for an

example, in the hallway or outside and the attorney does not

say hello or acknowledge your presence, please don't think that

the attorney is being rude. The attorneys simply are not

permitted to have that type of contact with you.

Now Assistant United States Attorney Micah Fergenson

will make his opening statement.

MR. FERGENSON: This case is about how the defendant,

Miles Guo, conned thousands of investors out of $1 billion, and

it's about how he spent millions of dollars of victim money on

himself.

In online videos, the defendant pitched investments in

a series of companies. In these videos, the defendant said

many false and misleading things. But at its core, the

defendant's fraud was simple. He promised his victims they'd

get rich, that their investments were safe, and they would not

lose any money. He told them that, as an ultra-rich

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billionaire, he would personally guarantee and pay back any

losses. He assured them he would never, ever let their

investments be stolen. These were lies. The truth is that the

defendant took investor money and spent it on

himself——million-dollar cars, yachts, a mansion. Miles Guo ran

a simple con, on a grand scale. He lived a billionaire's

lifestyle using money he stole from people he tricked and

cheated.

Now the defendant couldn't run a con this size alone.

You'll learn that the defendant and his partners in crime built

a criminal enterprise of different companies to carry out this

fraud. Some of the companies had offices right here in New

York City. The employees called the defendant the boss, and

the principal. And the defendant and his inner circle used

these businesses to steal money from their victims and to spend

it on themselves. And that's why we're here today, because

when the defendant conned people out of their money, he

committed several crimes involving fraud. When he and his

partners moved around investor money to hide that they were

spending it on themselves, they committed money laundering

crimes. And because the defendant committed these crimes,

using a criminal enterprise, a group of people and companies he

controlled, he committed a racketeering offense, a RICO

conspiracy.

Ladies and gentlemen, in this opening statement, I'm

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going to tell you what the evidence at this trial will show and

how the government is going to prove it——prove beyond a

reasonable doubt that the defendant is guilty.

So first, what will the evidence show? For years the

defendant deceived thousands of people and stole their money to

pay for a lifestyle he could no longer afford. You see, the

defendant used to be a wealthy real estate developer in China.

But he left China and came to the United States. Eventually

the defendant spoke out against China's government, the Chinese

Communist Party, or the CCP for short. He began giving

interviews and broadcasting his own videos.

And he didn't talk just about the CCP. The defendant

also talked about how rich he was. He showed off his

$70 million apartment on Central Park, or his $30 million

yacht.

And the defendant's mix of showing off wealth and

criticizing the CCP was popular. He became an internet

celebrity in the Chinese community. He had thousands of

followers. And you're going to learn that the CCP didn't like

this, that the CCP tried to silence the defendant, even tried

to have him brought back to China. And you'll learn that the

governments of China and Hong Kong seized the defendant's

assets shortly before the schemes began. So the defendant

needed money.

Now you're going to learn that the defendant pitched

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many different investment schemes to his victims, but each one

was just a new spin on the same simple fraud. The defendant

told his followers that their money would be used for an

investment, and they could not lose any money. And instead,

the defendant stole the victims' money and spent it on himself.

He did that through four main schemes——GTV; the farm loans;

G/CLUBS; and the Himalaya Exchange. I'm going to talk about

each of those schemes in turn.

So the first business that the defendant raised money

for was GTV. What was GTV? It was an online media company

with a website and an app that had the defendant's videos, his

broadcasts on it. What did the defendant tell his followers

about GTV? He told them it was their special opportunity to

get rich without any risk. In 2020, the defendant announced,

in his online broadcast, that he would let his followers buy

GTV stock. The defendant told his followers that investing in

GTV had no risk. He told them he would personally pay back any

losses. He told them that investing in GTV could only make

them money. These were lies. And the defendant even lied

about the most basic part of the GTV investment——that the money

raised from GTV investors would be used for GTV, to grow the

business of GTV. Even that basic promise was a lie.

But the defendant's followers trusted him, and money

poured in. In months, victims invested over $400 million in

GTV.

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What did the defendant actually do with that money?

Almost immediately, just days after the fundraising for GTV

closed, the defendant took $100 million of GTV investor money

and used it for a high-risk investment on behalf of his son.

He essentially made a bet using $100 million of GTV investor

money, sent it to a hedge fund for an extremely risky

investment. This bet wasn't even made on behalf of GTV; it was

made in the name of a company owned by the defendant's son.

And guess what? The hedge fund bet didn't pay out. This hedge

fund bet lost $30 million. The defendant told GTV investors

that he would personally guarantee their money and pay back any

losses. Did he pay back the $30 million loss? No. That was

just a lie.

What was GTV? It was one way that Miles Guo lied to

take other people's money. But it wasn't the only way.

There's GTV and then the farm loan scheme.

Now farms, these farms didn't have anything to do with

farming or agriculture. The defendant used the word "farms" to

refer to online groups of his followers in different cities or

countries. And the farm loan scheme was just a way to continue

the GTV scheme. You see, almost right away, US regulators

began investigating what GTV was doing. Funds were frozen, and

GTV's bank accounts were shut down. But the defendant, he

didn't stop. Instead, in his broadcasts, the defendant blamed

these problems on the Chinese government. He claimed that

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victims who were complaining about their money being stolen

were traitors and CCP spies.

And the defendant told his followers they could still

buy GTV stock; they just couldn't call it stock. Instead,

investors could use "loans" that would be organized through the

farms. You see, each farm opened bank accounts that were used

to collect and pool money from farm members, the investors.

The defendant told his followers that to get GTV stock, they

could enter a "loan agreement" with a farm and send their money

to that farm. He said the farm would then enter a loan

agreement with GTV, and after a few years, the defendant's

followers, the farm members, could choose whether to get GTV

stock or cash. But that was another lie. The defendant and

his money launderer stole the farm loan money for themselves,

and the victims got nothing.

GTV, then the farm loan scheme. What were the farm

loans? They were another way that Miles Guo lied to take other

people's money.

The next scam was G/CLUBS. Now G/CLUBS was supposedly

a high-end lifestyle membership club, but really, it was

another way for the defendant to sell stock without calling it

stock. The defendant told his followers that by paying

G/CLUBS' initial membership fee, they would get stock in GTV or

G Fashion, the defendant's clothing company. How much was the

initial membership fee? The initial fee started at $10,000 and

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went up to $50,000 on the high end. Thousands of the

defendant's followers paid this fee, sending G/CLUBS hundreds

of millions of dollars and expecting to receive stock in

return. But G/CLUBS members did not get stock. That was

another lie.

Did members get anything for their membership costing

tens of thousands of dollars? The main thing they got was a

discount at G Fashion, which sold expensive clothing to the

defendant's followers, like an $800 pair of sweatpants. You

could get 10 percent off that price if you paid $10,000 for a

G/CLUBS membership. And while G/CLUBS members did not get

stock or any benefit worth tens of thousands of dollars, the

defendant spent the G/CLUBS membership money on himself and his

family.

GTV, farm loans, G/CLUBS. What was G/CLUBS? It was

another way that Miles Guo lied to take other people's money.

Now the defendant didn't just pitch stock to his

followers; he also pitched a pair of cryptocurrencies sold on

the Himalaya Exchange. At first he called them G Coin and G

Dollar, then they became H Coin and H Dollar——H Coin for

Himalaya Coin, H Dollar for Himalaya Dollar. These

cryptocurrencies were another scam. In his broadcast, the

defendant told his typical lies about this cryptocurrency,

guaranteeing investors would not lose money. He told his

followers that H Coin was backed 20 percent by gold. Ladies

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and gentlemen, H Coin was not backed by gold.

The defendant tricked his followers into buying H Coin

and H Dollar because he wanted more money. You see, the only

place you could buy H Coin or H Dollar was a supposed

cryptocurrency exchange called the Himalaya Exchange. But the

Himalaya Exchange was run by the defendant's money launderer;

same one who helped him steal the farm loan money. You're

going to learn that when the defendant was in a bind and needed

money, the defendant's money launderer sent $37 million of

Himalaya Exchange money—-real dollars, not H dollars——to get

the defendant out of the bind he was in. $37 million of money

that victims sent to the Himalaya Exchange used for his

benefit.

GTV, farm loans, G/CLUBS, the Himalaya Exchange.

What was the Himalaya Exchange? It was one more way

that Miles Guo lied to take other people's money.

These four schemes were really just different versions

of the same con, where the defendant tricked people out of

their money so he could spend it on himself and his family.

And he did it for greed. He used investor money to pay for a

luxury yacht, for private jets, to buy luxury cars, a

Lamborghini that cost nearly a million dollars, a Bugatti that

cost $4 million, a $4 million Ferrari for his son, a second

luxury yacht, a 50,000-square-foot mansion that he paid

millions more to renovate for himself and his family, and to

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buy things like a $35,000 mattress, and a $60,000 TV. And the

victims, the investors whose funds were stolen by the defendant

to fund these spending sprees? They got nothing. They just

lost money——money they had saved, money they had borrowed,

their family money, money they thought was safe. And he just

stole it.

MS. SHROFF: Your Honor, objection.

THE COURT: Overruled.

MS. SHROFF: This is opening statement.

THE COURT: Overruled.

MR. FERGENSON: That's what the evidence is going to

show.

Now how is the government going to prove it, prove to

you that the defendant is guilty? You're going to see and hear

several different types of evidence. You will hear the

defendant's own words. You will see the defendant lie on video

over and over. You'll see him lie and say that his victims

can't lose money, that he would pay back any losses, that he

would never spend investor money on himself. And you'll hear

him lie about what he did with investor money, saying that he

has not touched even a penny of it, and admitting that if he

did, it would be a crime.

You'll also hear what the defendant and his

co-conspirators said on phone calls when they didn't know they

were being recorded by a concerned employee. You will hear the

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defendant order his co-conspirators to transfer $100 million of

investor money that he later used to buy his mansion. And

you're going to see records related to each of the four main

frauds, about how the investor money was supposed to be used,

and then you'll see records showing how it was actually used,

bank records showing how the defendant and his co-conspirators

used dozens of shell companies and hundreds of bank accounts to

conceal the fact they were spending investor money on

themselves.

You'll see the GTV investment document that says GTV

investor money would be used to grow GTV's business, and then

you'll see the records showing $100 million of GTV investor

money going instead to a hedge fund bet for the defendant's

son.

You'll see the farm loan contracts given to victims,

pieces of paper that were ultimately worth nothing to them.

You'll see the bank records showing that farm loan money was

just stolen.

And you'll see photographs of the things the defendant

bought with G/CLUBS membership money, all while promising in

his recorded broadcast that G/CLUBS memberships were a way to

invest in GTV or G Fashion. You'll see photographs of the

G/CLUBS Lamborghini that was parked in the defendant's garage,

at his Connecticut home; photographs of the defendant's mansion

in New Jersey, paid for with G/CLUBS money. You'll see

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photographs of the defendant's custom Italian suits hanging in

his bedroom closet at that mansion.

You'll see the bank records showing the $37 million

transfer of Himalaya Exchange money for the defendant's

personal benefit, all while the defendant told investors in

recorded broadcasts that he had no ownership in the Himalaya

Exchange and that H Coin and H Dollar money was secure.

Now you'll also hear the testimony of witnesses. You

will hear from people who used to work for and used to trust

the defendant. You'll hear from former employees of the

defendant's G businesses. They will tell you that the

defendant and his co-conspirators ran and controlled those

businesses, and made the decisions about how money was spent

and where it was transferred.

Now some of these former employees are testifying

pursuant to what's called non-prosecution agreements, in which

the government has agreed not to prosecute them in exchange for

their testifying at this trial. So you should listen carefully

to the testimony of these witnesses. When you do, you'll see

it's consistent with all the other evidence in the case.

Ladies and gentlemen, you will also hear from victims

of the defendant's fraud, people who were drawn into Miles

Guo's online world, people who trusted Miles Guo, who believed

the lies he told them, and who lost money, sometimes their life

savings, as a result, people who eventually realized they were

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being scammed.

Now the evidence, it's not going to come in all at

once. You'll see it witness by witness, document by document,

one piece at a time. But at the end of this trial, after

you've heard the testimony and you've seen the evidence, you

will see the full picture. This man conned thousands of

investors and stole $1 billion.

At the end of the trial, we'll have a chance to speak

with you again. Between now and then, I'm going to ask you

just to do three things——first, pay close attention to the

evidence; second, follow Judge Torres's instructions on the

law; and third, use your common sense——the same common sense

and good judgment that you use every day in your lives as New

Yorkers. If you do those three things, you will reach the only

verdict that is consistent with the evidence and the law——the

defendant is guilty.

THE COURT: Now we will have the opening statement on

behalf of the defendant, Mr. Guo, by Ms. Sabrina Shroff.

MS. SHROFF: Thank you, your Honor.

Good morning, ladies and gentlemen of the jury. It

was not a bet. It was not a scheme. It was not a con. It was

none of those things. And the reason we are here today is not

because the government brought an indictment; the reason we are

here today is because Mr. Guo has pleaded not guilty to the

indictment, and the evidence in this case will show——all of the

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evidence——the witnesses that they bring in, as government

counsel noted, one by one, the documents that come in one by

one, will lead you to only one conclusion, and the conclusion

is that Mr. Guo is not guilty of the 12 counts brought in this

indictment.

I am here to tell you why there is no conspiracy, RICO

or otherwise, and there is no enterprise. Mr. Guo is not

guilty of the charges in this indictment.

Before I do that, and before I speak more to what the

evidence will show in this case, please allow me to introduce

myself. My name is Sabrina Shroff. And I, along with my

colleagues, represent Miles Guo.

Miles Guo is one of eight children who started life

with very little, born and raised in China, and that is in fact

where he and his brothers and his family made a fortune in real

estate. The evidence in this case will show that the fortune

was humungous. And yes, the government would like you to draw

many, many negative inferences from a person who, according to

them, spent thousands of dollars on a TV or on a mattress. I

ask you please, when you consider the evidence, consider the

evidence within the context and not to be drawn in by the

government's invitation to make judgment calls about people who

have money and spend it in a way that you and I simply

wouldn't.

So let's talk about what the evidence in this case

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will show. The evidence in this case will show how Miles Guo,

filled with a determination to accomplish a goal, he had a

goal, and how he worked on that goal over a period of years,

and the goal was to establish, to set up, to form, and to move

forward a movement——a movement that would allow the people of

China, the Chinese people, to know that there was an

alternative, an alternative to the Chinese Communist Party, and

how the Chinese Communist Party could be removed so that

everybody could live in a way that they chose to live.

Mr. Guo, the evidence will show, did not have criminal

intent, and when the evidence in this case is complete, you

will see that what the government is trying to string together

is not just a group of people to try and prove to you an

existence of a conspiracy that really doesn't exist, but also

asking you to make value judgments about how money is made and

how money is spent.

So let me start where the government had started. Let

me talk about what the government spent the majority of the

time today, and what the government will spend a majority of

the time throughout this case on, the one person they ask you

to convict——Miles Guo.

He was raised in China, one of eight boys, and each

one of them grew up from nothing and made a fortune in real

estate. The real estate fortune of the eight brothers in China

was not just worth millions, it was worth hundreds and hundreds

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of millions of dollars. And you will hear that despite this

incredible success, financial fortune that he had in China,

Mr. Guo left China and came eventually and settled down in New

York. And you will ask yourself and the evidence will show why

Mr. Guo left China. He left China because he'd taken on the

CCP, the Chinese Communist Party, and they were not pleased

with him at all. The Chinese Communist Party also had a goal,

and they were very determined to make sure their goal was met.

Their goal was to make sure Miles Guo stopped speaking about

the CCP.

Now you've heard from government counsel earlier

today, and he has certainly invited you to make moral

judgments, value judgments, all sorts of judgments, but what he

has asked you to do at his core, he's asked you to receive from

him almost a fiat that Mr. Guo lied. He wants you to accept

that Mr. Guo lied so that people would give him money and then

wants you to accept that the only thing he did with that money

is spent it on himself and his family. That is not this case,

and that is not true.

You are going to hear that, like almost every one of

us, there's more than one aspect to Miles Guo, and some of the

aspects and some of the things you will hear during the

testimony in this case will be both surprising and eye opening.

So when you evaluate the evidence that comes in through the

witnesses, when you think about Miles Guo's story, when you

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think about who Miles Guo is, I ask you, keep in mind and

conceptualize the world that he lived in because it is not our

world. Our world is not filled with surveillance, constant

harassment, and constant oversight and disruption by the

Chinese Communist Party.

You will hear testimony in this case from government

witnesses that Mr. Guo was forced to leave China. He was

forced to leave behind his wife and his daughter. Both were

arrested and detained in prisons in China for almost two years.

You will learn and you will have evidence that shows

you that once Mr. Guo got to New York, instead of focusing on

all the negatives that were before him and all the hurdles he

had to face, what he did is, he started to and continued over

time to speak out against the Chinese Communist party, and that

is what he did all the time, all day long. That was his goal,

to get that story out. And repeatedly he said——and you will

hear it through the trial——that the people of China are not the

Communist party. That is what he wanted to tell the people

that were here in the United States and the good-thinking

people that he had to leave behind in China.

What is it that he set out to do? He set out to start

a movement and tell the truth about the CCP. And with that, he

started to speak, he started to write, and he started to

broadcast, and soon that came to be known amongst those who

believed him and amongst those who followed him to be the

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Whistleblower Movement.

And what did he talk about? He talked about things

that he knew. He knew of the corruption in the CCP, and that's

what he talked about. He knew certain secrets of corrupt

government officials, and that's what he talked about,

specifically. What else did he know? He knew the many ways in

which the CCP worked, and he knew of the many, many ways that

the CCP could make one's life hell, and one's professional life

and one's business life and one's personal life.

Now once Mr. Guo started talking about the CCP, the

reaction to it was immediate and strong, and the reaction

wasn't just from the people who were enthralled by what he had

to say. There was another reaction too. There was a reaction

by the CCP, the Chinese Communist Party, and they too had a

goal. Their goal was to make sure that he stopped.

So you see that most vividly when Mr. Guo, and the

evidence will show, had a broadcast on April of 2017,

April 19th of 2017, when he starts and gives a live interview

on Voice of America. In face of relentless bullying by the CCP

to stop, to be quiet, Mr. Guo decided to have a live-feed

interview on April 19th. The interview was, and his goal was,

to broadcast in an uncensored, live manner so that nobody could

doctor what he had to say. And what happened to this live

interview? While he's still speaking, in mid-speech, the feed

is cut off, the line is cut off, and the interview is stopped.

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There is no warning. There is no notice. All of a sudden, all

of the work he had put in to make sure this interview goes

through, it's cut off. And what happens after that? What

happens after that also gives you a context about the world in

which Mr. Guo has to live and do business.

Immediately after the April 19th interview, the

Chinese Communist Party issues what is called a red notice.

That is——a red notice is a warrant through the Interpol,

seeking Mr. Guo's immediate arrest and extradition back to

China.

After that interview with Voice of America, his wife

and his daughter are arrested in China by the Chinese police.

He loses all access to social media. His YouTube account is

cut off. His Twitter is cut off. And he has no access

whatsoever to any methodology by which he can get his word out.

What else do they cut off access to? They cut off

access to any method by which he could get himself or his

businesses any help. The CCP hacked his phones. Every

cellphone he has, they hacked. They hacked his computers——his

home computers and his work computers. They even hacked the

home and work computers of other people who are either

assisting him or doing business with him. And this pattern of

harassment by the CCP——and the evidence will show all of this

pattern——escalates and becomes more and more sophisticated.

So let me give you an example of how sophisticated

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this harassment can get.

At one point the CCP is so determined to shut down any

and every bank account that the CCP starts to send money into

these accounts in the names of people who are on the OFAC list.

The OFAC list is a list set by the United States government

that lists the names of people who have engaged in criminal

conduct and are not allowed to use our banking system. The CCP

uses those names to send in money, triggers a reaction from the

compliance people in the bank, the bank shuts down all of his

accounts, because the monies being wired, they think, are in

the name of known criminals on the OFAC list.

You will hear all of this evidence from the government

witnesses, and you will know that the CCP has a thousand

different ways to mess with Miles Guo and to try and stop the

political movement that was really the essence of his entire

being.

The evidence will show why Mr. Guo continued,

continued in this movement, and why he endeavored to overcome

each and every one of these hurdles. He was determined to make

sure the movement survived, and he wanted to make sure others

who wanted to join the movement were able to do so.

So what did Mr. Guo do? He set up the Rule of Law

Foundation and he set up the Rule of Law Society. He dedicated

both those entities to make sure that they provided people with

support to fight the propaganda given by the CCP. To give

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voice to the movement, he created a social media company. The

government lawyer has spoken endlessly about it. GTV. What

was GTV? GTV was a real company set up to spread the message

of the Whistleblower Movement. The point of GTV was to get an

uncensored voice out, not to just the people of Chinese beliefs

and systems who lived in the United States, but also the many,

many people who were left behind in China, who also wanted to

be part of that movement. And that is what GTV offered them.

Yes, GTV was the first of multiple business opportunities that

aimed to spread the voice of the Whistleblower Movement.

Mr. Guo participated in GTV, the farm loan program, G/CLUBS,

and the Himalaya Exchange, and its currencies, H Coin and H

Dollar. These businesses were at the heart of the movement,

and the government is simply wrong when it argues that they

were not real businesses. The evidence in this trial will show

that GTV was, unlike many, many others, a citizen-based

journalism website. It allowed for people to speak openly and

talk to each other without repercussions from the CCP.

The farm loan program. The farm loan program, the

evidence will show, not what this prosecutor has just told you,

but it will show that the farm loan program was a way for

people to give their money at an interest rate to support the

movement——the movement that they were interested in. And it

was a way for people to earn money from these loans. I remind

you, keep an eye on the time frame when all of this happened.

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United States and most of the world is in the midst of a

pandemic, and people are eager to interact with each other

online.

What was G/CLUBS? G/CLUBS was what the government

lawyer here mocks whether or not one should spend X amount of

dollars on a sweatshirt or sweatpants——I think he said

sweatpants. That is a person's choice, and that is exactly

what China didn't want people to have and what the movement did

want people to have——choice. You want to spend your money that

way, that is entirely up to you. And what did G/CLUBS

membership allow? It allowed a person, if they wanted, to

support the movement, at whatever price they wanted to support

it. If you wanted to support it at the $10,000 level, you

could, and if you wanted to support it at the $50,000 level,

you could. The evidence will show——and I ask you, when the

evidence comes in, do not take that invitation to make a moral

or value judgment on what and how people should spend their

money. The question is, does the evidence show the existence

of real companies, the existence of real employees, the

existence of people who did actual, real good work, the

existence of people who dealt with the same problems you and I

deal with at our jobs, trying to do the best job we can because

we're chosen by people and bosses, because we have talent,

expertise, and hard work, and those are the people that worked

in each one of these companies.

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There is no denying at all that all of these entities

were built around Mr. Guo's celebrity. Yes. And he was the

one who started speaking as early as 2017 and continued

speaking against the CCP.

You know what else the evidence will show? That not

just other people were the ones who invested. Mr. Guo's

friends invested, Mr. Guo's family members invested. Why?

Because they too——they too believed in the movement. So they

invested. They invested in GTV, they invested in the farm,

they invested in G/CLUBS, and they invested on the Himalaya

Exchange. They believed. The evidence will show that these

companies were built, were put together, just like any other

business; maybe not with the same level of infrastructure, but

people believed. And Mr. Guo, like many, many of us, had a

vision, had an idea. What he did not quite have is the

infrastructure that you and I bring to our daily lives. When

he first started, he spoke very little or no English. He was

new to this country. He wasn't familiar with the way things

are done. And yes, you will hear recordings in which he speaks

in a demanding voice, one instant, for work to get completed,

and at some times even appears to be extremely pigheaded in a

way that many a person is. Does that mean he's a criminal?

No. Does that mean he committed these crimes? The evidence

will show it does not. What the evidence, again, will show is

that the people who he hired were people who were able to

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contribute to each one of these businesses.

Now the government, I suppose, will spend some amount

of time introducing evidence about two individuals, Yvette Wang

and William Je, and I ask you, as you hear the evidence the

government puts in, to pay some and close attention to what

roles each one of these people played. The testimony will show

that Ms. Wang was the head of operations. She ran the

day-to-day of each business. She was in charge of hiring. She

did the best to hire people, and her hiring practices were the

same as yours or mine. She hired people that she met along the

way in her business, she hired people through a headhunter when

she needed a person or a spot filled. And she was no more or

no less committed and no more or no less demanding than any

other chief executive officer that works.

William Je is another name that the evidence will

show, and William Je was the finance guy. He's a well-regarded

investment banker who had managed the fortune not just of the

Guo family fund but he had managed the fortunes of many another

companies. He had expertise, he had skill, and that is why he

was the finance guy.

And I've already talked at length about Mr. Guo, who

was the ideas man. He came up with the ideas and he put

together the thought and the vision of what the movement that

he believed in would look like.

So you see, he wasn't alone in the movement. He

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wasn't moving all on his own. In fact, that's why it was

called the Whistleblower Movement. The point of it was to have

others join and participate.

So what will the evidence show at the end of the day?

The evidence will show that each one of these companies hired

and had people working towards the existence of a real

business. They believed and Mr. Guo believed. Mr. Guo

believed in this movement. So when the government lawyer asks

you and tells you to believe that Mr. Guo defrauded the members

of this movement, what the government is saying to you is that

he intentionally misled supporters to steal money, the same

money that they had given to the movement, the movement that he

had devoted almost his entire life to, the movement for which

he fled China, the movement for which he put up with being

followed every day, the movement for which his phones were

hacked, the movement for which his wife and his daughter sat in

prison for two years, and the movement for which he was not

allowed to leave and travel outside the United States, the

movement for which he risked his very existence. That's what

they're saying he set out to harm. They're saying that he set

out to harm the very thing that was almost an extension, a

symbiotic extension of who he was. And he did all of that even

though he had a fortune from a family fund that allowed him to

live in luxury. What the government is asking you to believe

is not just illogical; it defies common sense.

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I ask you to consider this. All of the evidence that

the government lawyer talked about——the wealth, the millions of

dollars' worth of luxury hotel in Manhattan where he lived, the

yacht, the mattress, whatever it is that he talked about——you

know what the evidence is going to show? The evidence is going

to show that no matter what else these witnesses say to you,

Mr. Guo had that lifestyle long before the government even

alleges that he committed this fraud.

The suits, sweatpants, the house, the evidence will

clearly show, that has been his lifestyle for decades, well

before the government says he lost money and well, well before

any of this was even a thought in the government's mind. And

it certainly continues today and continued for days after

because the family fund will always support Mr. Guo.

And I ask you to consider this, because the government

does invite you to make this value judgment. It is easy for a

person to judge another as either shallow or rich, but shallow

or rich does not make for a criminal. That does not mean that

the government's inference is a proper one.

The evidence will clearly show that Mr. Guo did not

need to steal money to buy the Brioni suits. None of that

would be worth all of the hardship he went through to keep the

CCP at bay. What the evidence will show here is that Mr. Guo

did not steal money from GTV, he did not steal money from the

farm loans program, he did not steal money from G/CLUBS, and he

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did not steal money from the Himalaya Exchange.

The government will also invite you to think, and

invite you to conclude, that the reason Mr. Guo did certain

things are because he was engaged in criminal activity.

(Continued on next page)

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MS. SHROFF: So what else is the government going to

elicit in terms of evidence? The government is going to seek

to elicit that Mr. Guo had constant telephones that he changed;

he had almost hundreds and hundreds of telephones. And that he

had these telephones, and he changed his number constantly

because he didn't want people to know what he was doing.

I ask you to consider this: If you have been the

target of constant hacking by the CCP, and if you have been the

target of people listening in on your phones, using your voice

recordings to impersonate you, wouldn't you also change your

phones that often?

If you were in constant fear of being threatened,

kidnapped, killed, moved, would you also not have a car that

does not tell people where and when you're going to be taken?

It's logical that that is what a person who is being surveilled

would live in that manner. If you were Mr. Guo and you were

being constantly targeted, wouldn't you want a safe and secure

place to have business meetings? Wouldn't you establish a base

where people you wanted to do business with could come and meet

with you without the interference and the distortion from the

CCP?

For every piece of evidence of wealth that they put

in, you will have an equally fair inference that he took those

steps not to cheat, not to indulge, but to make sure that the

movement survived despite the distortions of the CCP.

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I ask you to keep in mind when they talk to you about

bank accounts, Mahwah, homes, ask yourself, why would a person

have to open a bank account, unless, of course, each time a

bank account was owned, somebody from the OFAC list deposited

money into your account and had compliance to them. That's the

reason why Mr. Guo's actions must be evaluated in the context

and the lifestyle in which he was supposed to exist.

So the government will introduce the evidence. And I

ask you to keep in mind that for each piece of evidence that

comes into them, the necessary inference from them is not the

accurate one. They ask you to infer from the filing of a

bankruptcy that Mr. Guo simply did not have money.

Now, whether we think it's fair or whether we think it

unfair, the rich often declare bankruptcy. Personal bankruptcy

does not mean poverty. None of that inference is correct. And

I ask you, when you hear evidence of that, to consider how it

is that Mr. Guo, who did not have any personal assets at that

time, because the CCP was the one that had seized his property.

There was a time — and you will hear evidence coming

in — that Mr. Guo was to pay a fine of almost $100 million

within a few days. And that is what leads to a filing of

bankruptcy. But the government's request that from that you

draw the conclusion of guilt, again, is a misplaced request.

The government will argue throughout this case that

what Mr. Guo did was simply unlawful. They will ask you to say

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O5OVGUO2

you can be persecuted and you can still be a fraud. And when

they ask you that, I ask you to think about how the evidence

shows them to be wrong. The government isn't just saying that

there is a fraud. What the government is asking you to do is

to conclude that Mr. Guo defrauded essentially himself because

he is the movement, and the movement him.

So when they ask you to take a look at the evidence

that comes in — the evidence of wealth, the evidence of

spending, the evidence of luxury — I ask you to evaluate all of

that evidence in the context which I have described. And if

you do so, and if you evaluate the evidence, understanding how

difficult it was for these entities to survive, and how each

one of the people who worked for these entities worked hard to

maintain and forward a movement, you will reach the only

logical conclusion in this case: That Mr. Guo is not guilty of

the 12 counts of the indictment. Thank you.

THE COURT: Members of the jury, I want to remind you

about our trial schedule. Every day, every weekday, you'll be

entering the courtroom at 9:30 in the morning. By 9 o'clock,

you'll have a light breakfast available to you, so you can come

early. But you must be ready to enter the courtroom at 9:30.

So, in general, we'll take a half-hour break between

11:30 and 12; and I will also have a light lunch for you. And

then we'll go until 2:45. By condensing the schedule this way,

I don't take up your entire day until 5 p.m. I'm very aware

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O5OVGUO2

that you have other important things to do during the day, and

so that is why I've designed the schedule in this way.

So at this time we will take our half-of-an-hour

break.

(Jury not present)

THE COURT: You may be seated. Counsel, is there

anything before we return in half of an hour?

MR. FERGENSON: No, your Honor.

THE COURT: You're ready with your first witness?

MR. FERGENSON: Yes, your Honor.

MR. KAMARAJU: Not from the defense, your Honor.

THE COURT: All righty.

(Luncheon recess)

(Continued on next page)

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A F T E R N O O N S E S S I O N

12:10 P.M.

(At sidebar)

THE COURT: I have a note from Juror No. 192. I don't

remember his number, his actual number on the jury.

MR. KAMARAJU: It makes sense that he's an alternate.

MR. BARKAN: 192 is Alternate 5, your Honor.

THE COURT: Okay. Alternate 5.

To the Honorable A. Torres:

I am profoundly disappointed that my excuse for

dismissal wasn't granted. My request began with I am a working

single father. My child will have field trips, Father's Day,

tea ceremony, and graduation. And I will now not be able to

attend. When school ends on June 18th, I will not be able to

take her to camp. My family is far away and not able to assist

regularly. I am a widower. My wife passed away in childbirth.

So being able to something my child is very important.

I've just learned about the need to gather at a

location at an agreed-upon time. I dropped my child off at 8

a.m. Any adjustments brought in will cost me, my family, and

job gravely, not to mention thousands of dollars. I did not

detail my work position and how I am required to be at my job.

I thought my reasonable request based on my home and living

situation would have been sufficient.

To the attorneys, I appreciate the confidence you have

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O5OVGUO2

in my selection. You have royally screwed me over.

Juror No. 192.

MS. SHROFF: He's the gentlemen who served on Judge

McMahon's jury. I think he said that when he was being voir

dired.

THE COURT: What would you like me to do?

MS. SHROFF: I say we let him go. We have six; we can

live with five.

MR. FINKEL: So, your Honor, the government is fine

with five alternates. However, we defer to the Court on the

appropriateness on how to deliver the message. And the

government's concern would be sending a message to the rest of

the jury that merely sending a letter to the Court would allow

them to be excused from service.

The government has no objection to proceeding with

five alternates; and just ask the Court to use its discretion

and its experience on how to -- the timing of how to deliver

the message.

THE COURT: So I am also told that the jurors are not

pleased with the arrangement that they meet at a pick-up point

and be taken by car to the courthouse. XXXXXXXXXXXXXXXXXXXX

XXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXX

XXXXXXXXXXXXXXXXXXXXXXXXXXXXXwhich I think is acceptable.

MR. KAMARAJU: Fine with us, your Honor.

THE COURT: So this juror, Alternate No. 5, does not

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O5OVGUO2

know about that offered alternative yet. I could always bring

him in and ask him if that change would make it acceptable to

him, see what he says.

MS. SHROFF: We leave it up to the Court, if the Court

wants to ask him. But he seems royally, as he puts it, pissed

off. So my inclination would be to let him go. But perhaps

the Court could consider if we just let him sit through the day

and then we let him know just not to come on Monday, and then

assume that -- either tell the jury that, you know, this is the

new pool and provide no explanation, so that they don't think

somebody got away with something.

THE COURT: I definitely will have him sit through the

day, and I will speak with him after we're finished for the

day. Okay.

MR. FINKEL: Your Honor, one application before we

leave. Just that the location where the jurors are going to

meet be sealed in public record for the reasons that the

government stated in its motion, and that the location where

the jurors are going to meet not be shared with the defendant.

THE COURT: I think that that is totally appropriate.

MS. SHROFF: We don't even know where they were going

to meet, so we have nothing to share.

THE COURT: Okay. So those items will be sealed.

MR. FINKEL: Thank you, your Honor.

(Continued on next page)

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(In open court)

THE COURT: Would you have the jurors return to the

courtroom please.

(Jury present)

THE COURT: Please be seated.

Will the government call its first witness.

MR. FINKEL: Yes, your Honor.

The government calls Erin McNamara.

ERIN McNAMARA,

called as a witness by the Government,

having been duly sworn, testified as follows:

THE COURT: Please state your name and spell it.

THE WITNESS: Erin, E-R-I-N; McNamara,

M-C-N-A-M-A-R-A.

THE COURT: Please draw the microphone towards you.

You can bend it if you like.

You may inquire.

MR. FINKEL: Thank you, your Honor.

DIRECT EXAMINATION

BY MR. FINKEL:

Q. Good afternoon.

A. Good afternoon.

Q. Where do you work?

A. I'm a special agent with the FBI in the New Haven field

office.

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Q. How long have you been with the FBI?

A. 26 years.

Q. What, if anything, did you do before you were an FBI agent?

A. I was an auto underwriter with State Farm.

Q. Special Agent McNamara, what is ERT?

A. It's an evidence response team.

Q. Can you please describe to the members of the jury what the

evidence response team does.

A. Sure. Evidence response teams, they are bureau-wide. They

are people who are additionally trained in crime scene

management and forensic evidence collection.

Q. Special Agent McNamara, what role, if any, do you have with

ERT?

A. I'm the senior team leader for the New Haven team.

Q. What is a search warrant?

A. A search warrant is a document that's obtained from a

judge, usually an investigator gets it. It explains what it is

that you are allowed to search and what it is that you are

allowed to search for and seize.

Q. Special Agent McNamara, I want to direct your attention to

March 15th, 2023. In connection with your role at ERT, what,

if anything, did you do that day?

A. We executed a search warrant at 373 Taconic Road in

Greenwich, Connecticut.

Q. What sort of neighborhood is Greenwich, Connecticut?

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A. It's a very affluent neighborhood.

Q. How would you describe 373 Taconic Road?

A. It's beautiful, beautiful mansion. Very large, beautiful

yard, pool, tennis courts. And I believe it even bordered a

golf course.

MR. FINKEL: Ms. Loftus, we can display for the

witness what's been marked for identification as GX 133.

Q. Special Agent McNamara, what is GX 133?

A. That's an aerial view of 373 Taconic Road in Greenwich.

Q. Is that a fair and accurate photograph of 373 Taconic Road

in Greenwich?

A. Yes.

MR. FINKEL: Government offers 133.

THE COURT: No objection?

MS. SHROFF: No, your Honor.

THE COURT: Admitted.

(Government's Exhibit 133 received in evidence)

MR. FINKEL: If we could publish it, please,

Ms. Loftus.

Q. Special Agent McNamara, was the weather the day that you

were at 373 Taconic the same as what we see on the screen?

A. No, there was snow on the ground.

Q. Approximately what time did you arrive at 373 Taconic on

March 15th?

A. Around 7 a.m.

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Q. And when you arrived, did the FBI have a search warrant?

A. Yes.

Q. For what?

A. For 373 Taconic Road and its grounds.

Q. Did the FBI have an arrest warrant that day?

A. Yes.

Q. For who?

A. Miles Guo.

Q. Was Miles Guo present at 373 Taconic?

A. No.

Q. Were there individuals besides FBI personnel present at 373

Taconic?

A. Yes, there were three residents. There were an older

female, a younger female, and a male. And my understanding was

it was the wife, daughter, and the daughter's boyfriend.

Q. Wife, daughter, and daughter's boyfriend of whom?

A. Of Mr. Guo.

Q. What were their names?

MS. SHROFF: Objection.

THE COURT: Overruled. You may state that. You may

answer.

A. The daughter was Mei --

MS. SHROFF: May we approach for a moment, please?

THE COURT: All right.

MS. SHROFF: Thank you.

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(At sidebar)

MS. SHROFF: Your Honor, the daughter's name is

immaterial. She has been the subject of a lot of online and

offline harassment. She's not even in court today because she

does not want to be identified. She has made no court

appearances, even though she's dedicated to her father, because

she is constantly harangued.

We have not once raised an objection to their

witnesses names not being disclosed. And there is no relevance

to what her name is. It's not pertinent at all to any

questioning here. Her name could be Sonia Gandhi, for all I

care, but her real name does not need to be used.

MR. FINKEL: It is pertinent because her name is on

documents, as is the name of the wife, as is the name of the

daughters, boyfriend or fiancé.

In addition, I should note it is relevant here.

Ms. Shroff opened on the fact of the wife and the daughter and

their relationship with him. Her name is on documents. We

need to explain who she is. It's relevant.

THE COURT: The harassers already know her name.

MS. SHROFF: She's not here in court. She didn't come

to court to support her father because she's being harassed,

your Honor. And I did not refer to her by name in my opening

for a specific reason, which is obvious why I didn't use the

wife's name and the daughter's name. And I think the record

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speaks for itself on that point.

THE COURT: So the fact that these names are on

documents makes her name relevant. But also, the Chinese

Communist Party jailed the wife and daughter. I'm sure they

know the name, plus a lot of other information.

The objection is overruled.

MS. SHROFF: Your Honor, it's not the Chinese

Communist Party, it's quote/unquote victims.

THE COURT: Overruled, Ms. Shroff.

MS. SHROFF: Thank you.

(Continued on next page)

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O5OVGUO2 McNamara - Direct

(In open court)

THE COURT: You may answer.

A. The daughter was Mei, M-E-I; Guo, G U O. The mother, I

only recall her last name was Ngok, N-G-O-K. And the male, it

was Cao, C-A-O.

Q. Do you remember the male's first name?

A. I do not.

MR. FINKEL: Ms. Loftus, if we can display for the

witness 3514-48. If you can please go to page 2 of that.

Actually, your Honor, may I approach?

THE COURT: You may.

Q. Special Agent McNamara, can you look at your screen towards

the bottom. And the question is whether that refreshes your

recollection as to the daughter's boyfriend's first name?

A. Yes.

MR. FINKEL: Ms. Loftus, can you bring that down,

please.

Q. Special Agent McNamara, what is the daughter's boyfriend's

first name?

A. Defeng, D-E-F-E-N-G.

Q. Special Agent McNamara, what was your role with respect to

the search at 373 Taconic?

A. I was a coordinator. I made sure we had the materials we

needed, assignments as to who would photograph, answer

questions; just sort of made sure that the search kept moving

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and that everything was completed.

Q. And what were the sort of items that the team was looking

for?

A. Electronics like cell phones, computers, business records,

financial records, photographs, things of that nature.

Q. By the way, Special Agent McNamara, aside from your

involvement in this search on March 15th, were you involved in

the investigation concerning Miles Guo?

A. No.

Q. If you were not involved in the Miles Guo investigation,

can you explain to the members of the jury why, if at all, you

were participating in a search that day?

A. Sure. It was a request by New York. They had multiple

search warrants, so they needed assistance conducting this one.

And since it's in Greenwich, it's in our territory in

Connecticut, so they asked us for assistance. They asked us to

provide people and supplies and things that were needed to

conduct the search.

Q. Does that happen somewhat commonly within the FBI?

A. Yes.

MR. FINKEL: Your Honor, at this time I'd like to read

a stipulation to the parties.

THE COURT: Go ahead.

Before you read the stipulation though, I'd like to

let the jurors know what a stipulation is.

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A stipulation is an agreement between both sides to

present evidence to the jury without calling a witness for the

purpose of discussing the subject matter.

Go ahead.

MR. FINKEL: It is hereby stipulated and agreed by the

United States of America and Miles Guo, the defendant:

If called as a witness at trial, a special agent of

the Federal Bureau of Investigation, FBI, would testify as

follows:

On March 15, 2023, special agents and other FBI

employees executed a judicially authorized search of 373

Taconic Road, Greenwich, Connecticut. During the course of

that search, FBI personnel took photographs of exterior and

interior spaces of 373 Taconic Road, Greenwich, Connecticut,

and also lawfully seized documents and electronic devices.

Government Exhibits GX CT-20 through GX CT-30, GX

CT-35 through GX CT-72, GX CT-74 through GX CT-105 are fair and

accurate photographs of interior and exterior spaces of 373

Taconic Road, Greenwich, Connecticut, that were lawfully

captured by an FBI photographer on March 15, 2023, when

conducting the search.

Following the March 15, 2023 search, FBI personnel

scanned and photographed documents that were lawfully seized

during the search. GX CT-101 through GX CT-129, GX CT-157

through GX CT-187, GX CT-190 through GX CT-202, and GX CT-204

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through GX CT-207 are true and correct copies of documents that

were seized during the March 15, 2023 search of 373 Taconic

Road, Greenwich, Connecticut.

It is further stipulated and agreed that this

stipulation, which is GX STIP-1, may be received into evidence

as a government exhibit at trial. And it's signed by the

parties.

With that, your Honor, the government offers GX

STIP-1.

THE COURT: It is admitted.

(Government's Exhibit STIP-1 received in evidence)

MR. FINKEL: And the government offers GX CT-20

through GX CT-30, GX CT-35 through 72, GX CT-74 through 105, GX

CT-101 through 129, GX CT-157 through 187, GX CT-190 through

202, and GX CT-204 through 207.

THE COURT: They are admitted.

(Government's Exhibits CT-20 through CT-30, CT-35

through 72, CT-74 through 105, CT-101 through 129, CT-157

through 187, CT-190 through 202, CT-204 through 207 received in

evidence)

MR. FINKEL: Thank you.

BY MR. FINKEL:

Q. Special Agent McNamara, did you see every aspect of 373

Taconic on March 15, 2023?

A. I did not.

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O5OVGUO2 McNamara - Direct

Q. How long did the search take?

A. Just under four hours.

MR. FINKEL: We can please display what's in evidence

as Government Exhibit GX CT-87.

Q. Special Agent McNamara, what is the jury looking at in GX

CT-87?

A. That's an exterior photo of 373 Taconic Road.

MR. FINKEL: If we can pull up, please, Ms. Loftus, GX

CT-25. It's not on your screen? If you can publish that,

please, Ms. Loftus. It wasn't published. Thank you. Sorry

about that.

Q. Special Agent McNamara, what is GX CT-25?

A. That's another exterior photo of 373 Taconic Road, the rear

of the house.

MR. FINKEL: Ms. Loftus, if we can please publish GX

CT-91.

Q. Special Agent McNamara, what is GX CT-91?

A. This is a side of the house, the side with the two garages.

Q. Did there come a time during the search of 373 Taconic when

you entered the garages that we're looking at in GX CT-91?

A. Yes.

Q. Which garage?

A. Both.

Q. What, if anything, were in the garages?

A. In the garage to the right in the photo as you're looking

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at it was a red Lamborghini.

MR. FINKEL: If you can please display GX CT-95.

Q. Special Agent McNamara, is this the garage that you went

inside and saw the red Lamborghini?

A. Yes.

MR. FINKEL: If we can please display GX CT-38.

Sorry. It looks like our computer froze. Bear with

us. Apologies.

Q. While we're waiting for the computer to wake up, which

happens, sorry, Special Agent McNamara, what, if anything,

happened to the Lamborghini on March 15, 2023?

A. It was seized.

Q. And was that pursuant to a warrant?

A. A seizure warrant, yes.

Q. And was the FBI able to locate the keys to the Lamborghini?

A. Yes.

Q. And where were they?

A. Inside the house.

Q. Did you see the keys that day?

A. I did.

Q. Special Agent McNamara, what is a VIN number?

A. It's a vehicle identification number. It's a number that's

unique to each vehicle.

MR. FINKEL: If we can please display GX CT-42.

Q. Special Agent McNamara, approximately how many FBI

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personnel participated in the search?

A. Around 40.

Q. And did you walk from one side of the home to the other?

A. I did not -- no, not on every floor no, I did not.

Q. On any of the floors did you?

A. The first floor.

Q. How long did it take to get from one side to the other?

A. I don't know. I was stopped multiple times from one end to

the other.

MR. FINKEL: If we can please display, Ms. Loftus, GX

CT-41.

Q. Special Agent McNamara, did the 373 Taconic appear to be a

home that was lived in?

A. Yes.

Q. Why was that?

A. There were clothes, shoes, food, toiletries, dogs. They

had two dogs. Dog beds.

MR. FINKEL: Just going to wait for our computer to

cooperate so we can continue.

Q. All right. Special Agent McNamara, what are we looking at

in GX CT-41?

A. That's the VIN number on the Lamborghini in the garage.

Q. Does ERT have any practices or procedures with respect to

VIN numbers on cars?

A. Yes, we always photo the VIN number because it's a unique

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identifier, like a serial number on a computer.

MR. FINKEL: Your Honor, may I approach?

THE COURT: You may.

MR. FINKEL: I've handed the witness what's been

marked for identification as Government Exhibit 36.

Q. Special Agent McNamara, can you look at Government Exhibit

36, please.

A. It's keys to a Lamborghini.

Q. And do those keys have any uniquely identifying marks?

A. There's a partial VIN number on the tag.

Q. And what is the end of the partial VIN number?

A. 10393.

Q. Does that match the VIN number in GX CT-41?

A. It does.

MR. FINKEL: Government offers 36.

THE COURT: It is admitted.

(Government's Exhibit 36 received in evidence)

MR. FINKEL: Your Honor, may I publish it to the jury?

THE COURT: You may.

MR. FINKEL: If we can display for the witness,

please, Government Exhibit GX CT-209. Just for the witness.

Q. Special Agent McNamara, from where were the keys recovered?

A. There was a -- it was a room, I would call it like an

office/security room. There were monitors for the security

cameras in there. And a desk.

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MR. FINKEL: One moment, please.

MR. FINKEL: GX CT-209, please, for the witness.

Q. Special Agent McNamara what is GX CT-209?

A. That's another photograph from the search.

Q. Is that a fair and accurate photograph of what you saw on

March 15, 2023?

A. Yes.

MR. FINKEL: Government offers CT-209.

THE COURT: It is admitted.

(Government's Exhibit CT-209 received in evidence)

MR. FINKEL: Can you please publish that.

The jury can see it? No? Now you can. Okay. Great.

Q. Special Agent McNamara, do you know what those flags are?

A. No.

MR. FINKEL: We can now please display what's in

evidence as Government Exhibit CT-58.

Q. Special Agent McNamara, what are we looking at in GX CT-58?

A. A photograph of one of the rooms in the house at 373

Taconic Road.

Q. And what, if anything, was in that room besides what we're

looking at?

A. Oh, cameras. Like a video cameras.

Q. Do you know why there are video cameras in there?

A. No.

MR. FINKEL: Please look at, Ms. Loftus, GX CT-59.

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Q. What is GX CT-59?

A. That's another photo of that room, that same room.

MR. FINKEL: If we can please, Ms. Loftus, show just

the witness GX CT-208. This is just for the witness, please.

Q. Special Agent McNamara, what are we looking at in GX

CT-208?

A. That's another photograph from the search. That's what I

would call the living room.

MR. FINKEL: Government offers GX CT-208.

THE COURT: It is admitted.

(Government's Exhibit CT-208 received in evidence)

MR. FINKEL: Publish that please, Ms. Loftus.

If we can please display Government Exhibit GX CT-83,

which is in evidence.

Q. Do you know what those insignias on the clothing are?

A. No.

MR. FINKEL: Ms. Loftus, if we can display GX CT-80.

80, please. Eight zero. This is in evidence.

Jury able to see that? No?

Can we publish that to the jury, please.

Q. Are these some of the closets that you mentioned before?

A. Yes.

Q. Special Agent McNamara, you said some documents were

recovered that day; is that correct?

A. Yes.

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Q. Did you review the documents?

A. No.

Q. Did other members of the team?

A. No.

Q. What happened to the documents after they were collected on

March 15, 2023, do you know?

A. They were collected, they were packaged, and they were

handed over to New York.

Q. And the New York field office was running this

investigation; is that correct?

A. Yes.

MS. SHROFF: Objection to the leading.

THE COURT: You can ask who was leading the

investigation.

BY MR. FINKEL:

Q. Special Agent McNamara, which field office, if any, was

leading the investigation in this matter to your understanding?

A. New York.

MR. FINKEL: We can please display what's in evidence

and for the witness and the jury GX CT-201. If you can go to

the second page, please.

Q. Special Agent McNamara, can you read what it says at the

top?

A. Brioni, 688 Madison Ave., New York, New York, 10065.

Telephone number: 212-376-5777.

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Q. What does it say in that green cell at the top of the

chart?

A. Invoice from Mr. Miles Kwok bespoke order.

Q. Do you know what Brioni is?

A. No.

MR. FINKEL: If we can go to the next page please,

Ms. Loftus. Page 4, rather. Can you zoom in on that. We can

go to page 5, please. And if you can please pull up what's in

evidence as GX CT-205. I'm sorry, 207. Excuse me.

This should be published so the jury can see it. If

we can go to the next page, please. And can you zoom in at the

top please, Ms. Loftus.

Q. Special Agent McNamara, can you read up to "background"?

A. Execution version. Loan agreement. This agreement (this

agreement) is made on the 3rd day of June 2020, between GTV

Media Group, Inc. (the lender), a Delaware corporation with

office address at 162 East 64th Street, New York, New York,

10065, and Saraca Media Group Incorporated (the borrower), a

Delaware corporation with office address at 162 East 64th

Street, New York, New York, 10065. Each a "party together"

parties.

MR. FINKEL: Ms. Loftus, if you can go to the last

page of this document, please. Can you zoom in on that.

Q. And who is the authorized signatory according to this

document, Special Agent McNamara, for Saraca Media Group Inc.?

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A. I'm going to mispronounce this. Qiang, Q-I-A-N-G, Guo.

MR. FINKEL: Thank you, Ms. Loftus.

If we can bring up, please, GX CT-198 for the parties

and the jury. And if you can go to the next page of that

please.

Q. Special Agent McNamara, can you read this document, please.

A. Dear Mr. Harry Eccles-Williams, I am writing this letter to

request and to put into consent for the release of all my files

from your firm to Qiang Guo as soon as possible. Most

importantly, the relationship between me and Appleby, the

relationship between Well Origin and Appleby. Thank you.

Yours sincere, Ho Wan Kwok.

MR. FINKEL: Ms. Loftus, if we can bring up, please,

GX CT-157 for the jury and the parties.

That's fine. Right there as you have it.

Q. Special Agent McNamara, can you read the top of that,

please.

A. G talks-program.

Q. Can you read down where it says 7:48 a.m.?

A. Welcome by host, Limarie Reyes.

Q. Who's Limarie Reyes?

A. I have no idea.

MR. FINKEL: We can display, please, GX CT-172.

That's fine, Ms. Loftus.

Q. Special Agent McNamara, can you read the top of GX CT-172.

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O5OVGUO2 McNamara - Direct

A. List of do-not words dash -- slash, I'm sorry, ideas.

MR. FINKEL: Ms. Loftus, can you scroll down a little

bit.

Q. Special Agent McNamara, do you see where it says "loans"?

A. Yes.

Q. Can you read the words that follow "loans."

A. Partner or partners, growth, growth projections, venture,

partnership, future investment benefits, future opportunities,

participate/participation in business or profits, GTV, Saraca,

voice of Guo/voice of good (VOG), Rule of Law Foundation, Rule

of Law Society, Canada Himalaya, Jang Yun Fu, lewd, Yvette Wang

Yvette, Sarah, Mulan, SEC, investigation, litigations, golden

spring, regulators, DOJ.

Q. What is DOJ?

A. Department of Justice.

Q. What is SEC?

A. Securities Exchange Commission.

MR. FINKEL: Ms. Loftus, if we can bring up, please,

GX CT-174.

Q. Can you read where it says 8:20 a.m.

A. Live Q&A by Mr. Miles Guo, preselected questions.

MR. FINKEL: Ms. Loftus, if you can display for the

witness only GX CT-210.

Q. Special Agent McNamara, what is GX CT-210?

A. It's one of the photographs from the search.

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MR. FINKEL: Government offers GX CT-210.

MS. SHROFF: Objection, your Honor.

THE COURT: If you'll step up, please.

MR. FINKEL: I can lay an additional foundation.

Q. How do you recognize this photograph as one of the

photographs from the search?

A. I reviewed the photographs.

Q. Okay. Did you see this particular area of 373 Taconic on

the day that the search was conducted?

A. I don't recollect.

Q. Okay. Does the FBI maintain photographs that are taken

during a search in the regular course of FBI's business?

MS. SHROFF: Objection. What the FBI generally does

is not relevant.

THE COURT: Overruled. You may answer.

A. Yes.

Q. And you said that you reviewed the photographs from the

search. Can you explain what you mean by that?

MS. SHROFF: Objection to the leading.

THE COURT: Overruled. You may continue.

A. So we had -- we maintained a copy of photographs from the

search. When I was asked to come here, I reviewed this to

refresh my memory of the search.

Q. And the photographs that were part of the search, are they

maintained in FBI's records and kept that way?

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A. Yes.

MS. SHROFF: Objection. She has no personal

knowledge.

THE COURT: Step up.

(Continued on next page)

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(At sidebar)

THE COURT: So she is familiar with the photographs

from the search.

MR. FINKEL: So, your Honor, she was the team lead and

she's familiar with the ERT, including its recordkeeping

practices. For one, I think she recognizes parts of the

photograph, but that's neither here nor there. She can lay an

803(6) foundation as a photograph that was taken at the search.

She knows it was stored with the other photographs of the

search.

I'll lay that foundation that it was taken by someone

with knowledge of the matter at the time it occurred and kept

in the course of the FBI's business.

It's one photograph. We can lay the foundation.

MS. SHROFF: The government knows full well it has a

problem here. They asked me this morning to stipulate to it

coming into evidence and I declined because they are unable to

lay a foundation. The fact that --

THE COURT: What is wanting in the foundation?

MS. SHROFF: Your Honor, number one, she didn't take

the photograph; number two, she didn't view the evidence;

number three, she didn't view that particular scene; number

four, the only reason she's table to testify this way is

because of the government giving her the photos that they took

from other members of the FBI team and showed it to her.

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She has zero personal knowledge of this particular

photograph. And nothing about a photograph being in an FBI

file falls under the exception of a business record. Either

she has personal knowledge of this or she doesn't, and clearly

she doesn't, your Honor.

Additionally --

THE COURT: Isn't this kept in the regular course of

business?

MS. SHROFF: It doesn't fall within that exception,

because the exception is supposed to capture something that is,

one, a business record, which this is not; this is evidence

gathering. And documents gathered by the FBI are by definition

self-serving because they are prepared in the course of a

litigation. But they do not technically fall within the

business records exception.

Number two, the way this photograph is taken, it is

not a photograph of a scene that is in the home. So what

they've done is they've gone through the entire house, pulled

out all the sunglasses, laid them on a table, and then taken a

photograph. You can see that clearly from the photograph and

from the cases that are stacked up next to them.

So this particular person did not do the underlying

search for the sunglasses, did not place the sunglasses there,

and she has zero personal knowledge of any of this.

THE COURT: But the photograph was taken during the

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course of the search.

MS. SHROFF: She wouldn't know that. It could have

been this search, it could have been another search, it could

have been a search before that. She doesn't know when this

photograph was taken.

MR. FINKEL: If I may just make a few points.

First of all, if necessary, we can bring another

person to simply authenticate one photograph. The parties have

worked quite well in good faith on stipulating authenticity,

suddenly that changed this morning.

Number one, I believe if I ask the witness, Do you

recognize any components of this photograph, she will say: I

know the door and that was from the room.

A witness does not have to be the one to take a

photograph to get it into evidence. The witness does not have

to be the one to move things around if that's, in fact, what

happened to get it into evidence. If Ms. Shroff wants to cross

her on how the sunglasses were arranged, if that is, in fact,

correct, I don't know, she can do that. It's just an

admissibility question.

THE COURT: So she may be able to testify as to the

door, but she certainly can't testify as to the rest of the

room and how these sunglasses were positioned.

MS. SHROFF: We would have no objection --

MR. FINKEL: Excuse me.

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MS. SHROFF: -- to the photo of the door.

MR. FINKEL: Excuse me.

That would be appropriate cross.

This goes to the weight of the document. Excuse me.

This goes to the weight of the document, not to admissibility.

In either case, I can lay an 803(6) foundation. She's familiar

with the case file and she's familiar with how the records are

stored. That's one photograph. I'll just leave it at that.

THE COURT: So she can identify the room, but she

cannot identify these objects.

MR. FINKEL: Okay. So I'll lay an 803(6) foundation.

THE COURT: Okay.

MS. SHROFF: Your Honor?

THE COURT: We're done.

(Continued on next page)

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O5OVGUO2 McNamara - Direct

(In open court)

BY MR. FINKEL:

Q. Special Agent McNamara, when a search is conducted by the

FBI, what happens to the photographer's photos?

A. The photographer brings the -- takes the SD card out of the

camera, places it into a tower. It's not a computer, it's a

tower where you just burn -- you can do like four copies at a

time. So that they place that in there. We burn the copies.

The first copy is the original, and that goes into

original envelope of -- original evidence envelope, a 1A

envelope we call it. It gets attached to the file.

The second is the backup copy; that also gets put into

the file.

The third copy is one we would send to the case agent

for a working copy so they wouldn't have to go and remove those

physically from the file to review it.

And if there were items that were being sent to the

lab, we would also burn a copy to send with those items to the

lab for review.

THE COURT: I'd like you to get closer to the

microphone. You can bring it closer, you can sit closer. And

speak up.

Q. And the copies of photographs, which field office, if any,

were they sent to?

A. New York.

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MR. FINKEL: We can please display, Ms. Loftus,

Government Exhibit GX CT-129. This is in evidence. And if we

can please go to page 17. I just want to make sure it's

published for the jury. If you can zoom in just for the top

half, please, Ms. Loftus.

(Continued on next page)

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BY MR. FINKEL:

Q. Can you read that, please, Special Agent McNamara.

A. "Declaration of Trust and Agreement. The Declaration of

Trust and Agreement (this Trust and Agreement) is made on

December blank 2020, between Qiang Guo, the beneficiary, an

individual holding Cyprus passport number blank, residing at

blank, London, United Kingdom, and Kin Min Je, the Trustee, an

individual holding Hong Kong passport No. KJ0168411, residing

at 87 Balmoral House, Earls Way, London, United Kingdom, each a

party, together parties."

Q. And you can continue reading, please.

A. "Background. The Trustee agrees to hold the shares of the

following companies (each, the company, together, the

companies) registered in the name of the Trustee for and on

behalf of the Beneficiary: (1) Himalaya Currency Clearing Pty.

Ltd., a company registered in Australia with the company number

642418684; (2) Himalaya Reserves Pty. Ltd., a company

registered in Australia with company number 642487232,

Himalaya——sorry; (3) Himalaya Currency——I think it's Party——I'm

sorry——Ltd., a company registered in Australia, with company

number 643817449; (4) Major Lead International, Ltd., a company

registered in British Virgin Islands with company number

1976621."

MR. FINKEL: Can you zoom in, please, Ms. Loftus.

Q. Can you read No. 3, please, Special Agent McNamara.

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MR. FINKEL: Ms. Loftus, if you can zoom in on No. 3.

A. "The Trustee further covenants with the beneficiary: (3.1)

to keep the company at all times solvent unless instructed

otherwise by the beneficiary, and to comply with all applicable

rules and regulations that the company requires; (3.2) to keep

the company active on the——on the relevant registry at all

times, and pay on time all applicable fees which will be

reimbursed by the beneficiary; (3.3) not to assign or part with

possession of the company to any third party without the prior

written approval of the beneficiary."

MR. FINKEL: Ms. Loftus, you can zoom out of that,

please, and go to the next page.

And the next page, please.

Q. And can you read the sign names, next to where it says

Signed.

A. Signed by Qiang Guo. Signed by Kin Min Je. Witnessed by

blank.

MR. FINKEL: Thank you. Ms. Loftus, you can take that

down.

Just one moment, your Honor.

Can you please display, Ms. Loftus, Government Exhibit

GX CT176.

Q. And Special Agent McNamara, can you read starting where it

says "Draw."

A. "Draw G——I'm sorry——G Fashion items, Designer 1 Whistle,

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pants, 100, hat, 200."

MR. FINKEL: If you can please go, Ms. Loftus,

GX CT184.

Next page, please.

Keep going. Stop right there.

Q. What sort of document is it?

A. It's a vehicle title.

Q. What's a vehicle title?

A. It's——it's something that you have to——it's——shows your

ownership and it's registered with the state.

Q. What's the name of the owner listed on this?

A. It's Cao, C-A-O, Defeng, D-E-F-E-N-G.

Q. Did you see Cao Defeng or Defeng Cao on March 15, 2023?

A. Yes.

Q. And what type of car is this?

A. Lamborghini.

Q. What's the model?

A. Aventador.

Q. And what is the last four digits of the VIN, or vehicle

identification number?

A. 0393.

MR. FINKEL: Ms. Loftus, if you can please display

GX CT41.

Q. What are the last four digits of this vehicle

identification number on the Lamborghini?

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O5O1GUO3 McNamara - Cross

A. 0393.

MR. FINKEL: Nothing further at this time. Thank you.

THE COURT: Cross-examination?

MS. SHROFF: Thank you, your Honor.

CROSS EXAMINATION

BY MS. SHROFF:

Q. Good afternoon, Special Agent.

A. Good afternoon.

Q. Ms. McNamara, before March 15th, did you know anything

about Mr. Miles Guo?

A. No.

Q. And you prepared, I take it, right, to execute the search

on March 15th?

A. Prepared the search supplies and things of that nature,

yes.

Q. Right. And you had a plan in place, correct?

A. Yes.

Q. And prior to executing the search, you met with or emailed

with the members of the team that were going to accompany you,

correct?

A. Yes.

Q. You discussed where Mr. Guo might be on March 15th,

correct?

A. I don't believe so.

Q. You did not discuss where——which one of the three homes you

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O5O1GUO3 McNamara - Cross

thought he might be in?

A. I don't recall that.

Q. Do you recall, sitting here today, on what date you started

preparing to execute the search?

A. It was either earlier that week or late the prior week. I

believe.

Q. And you emailed, did you not, with other members, including

somebody named Robin, correct?

A. I don't know who Robin is.

Q. Robin Cartwright?

A. Rachel Cartwright.

Q. I'm sorry?

A. Rachel.

Q. Rachel, Robin, you emailed with her, right?

A. Yes. She's the one that requested our assistance.

Q. And in emailing with her, the plan was for her to exchange

information with you and you to exchange information with her,

correct?

A. Information about how we were going to conduct the search,

yes.

Q. Right. And you knew you were going to search a home,

correct?

A. Yes.

Q. And you knew it was a large home, correct?

A. Yes.

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Q. And you knew the home could have Mr. Guo in it, correct?

A. Yes.

Q. And you were planning to arrest Mr. Guo, correct?

A. I was not.

Q. Well, somebody on your team was going to arrest Mr. Guo,

correct?

A. No one on my team does arrests. We simply do searches.

Q. Okay. And you testified earlier that you didn't recall

whether or not you anticipated where Mr. Guo would be, so let

me approach with something that might refresh your

recollection. That would be 3514-24.

Does that refresh your recollection, ma'am, that you

were anticipating Mr. Guo not being in the Connecticut home?

A. No.

Q. And it is fair to say that you interacted via email with

several individuals, all coordinating the search of this place,

right?

A. Yes.

Q. And that's 373——I have trouble pronouncing the

street——Taconic Road; is that correct?

A. Yes.

Q. And you wanted to go there early in the morning, correct?

A. Yeah. I did not choose the time.

Q. Okay. But in any event, you were there before 7:00; is

that fair to say?

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A. No. We arrived around 7:00.

Q. And it's fair to say that the home itself is not one that

you had access to, correct?

MR. FINKEL: Objection.

A. I don't understand.

THE COURT: Overruled.

MS. SHROFF: I'll rephrase, your Honor.

Q. You couldn't get in through the gate, right? Your team

couldn't get in through the gate, correct?

A. Yes, we could. The gate was open when we arrived.

Q. The gate to the home was open.

A. Yes. When my team arrived, the gate was open.

Q. And how many teams preceded you?

A. The——the team that was doing the entry.

Q. The team that was doing the entry, correct?

A. Yes.

Q. And the team that was doing the entry was coordinating with

the team that was following, which is your team, correct?

A. When——when they finished their entry and it was secured,

they let us know that we can then proceed to the location.

Q. Right. And did the team that was doing the entry tell you

that it was Mr. Guo's daughter who let them in?

MR. FINKEL: Objection.

THE COURT: Sustained.

Q. When you——

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THE COURT: You don't need to answer.

Q. When you entered the home, did you see Mr. Guo's daughter

and wife seated outside on a bench?

A. No.

Q. When was the first time you saw Mr. Guo's daughter and wife

in that home?

A. Inside the house.

Q. Where were they seated inside the house?

A. I would call it like a family room.

Q. And they were put there by the——by the team that entered

before you, correct?

A. I don't know. I was not there.

Q. You don't know because you weren't there. And when you

entered the house, did you go from room to room in the home?

A. When I first entered the house?

Q. Yes.

A. When I first entered the house, I went towards where the

residents were to find Supervisory Special Agent Cartwright to

let her know that we were there.

Q. Because she was the first entry team, right?

A. I don't know.

Q. You don't know who the first entry team was?

A. I don't know who was on the entry team. I followed the

entry team. That was not part of the search.

Q. So you followed the entry team, correct, and the entry team

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told you that the location was secure, correct?

A. We were at a staging location. When the entry team told us

it was secure, then we drove to the residence.

Q. And how many of you drove together?

A. I can only speak for my team. There were probably a dozen

of us or so.

Q. You just said you can only speak for your team, correct?

A. Right. You asked who drove together; that's who I drove

with, my team.

Q. Okay. Did any members of your team take any of the

photographs you testified to?

A. Yes.

Q. Okay. So we'll get to the photographs in a minute. But

let's just stay with your entry into the home, okay? When you

entered the home, it looked, as you said, like a home that was

lived in, correct?

A. Yes.

Q. There was food on the kitchen table, correct?

A. There was food, yes.

Q. Yes. And there were three people in the home, correct?

A. Yes.

Q. And the three people were Mr. Guo's wife, correct?

A. Yes.

Q. His daughter, correct?

A. Yes.

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Q. And his daughter's fiancé, correct?

A. I was told boyfriend, but yes.

Q. Okay. And did you see the boyfriend who was in crutches in

the bedroom or did somebody tell you about that?

A. I'm sorry. Can you repeat that.

Q. Sure. During your search did you see his daughter's

boyfriend?

A. Yes. They were all in that room together.

Q. Okay. And he was on crutches, correct?

A. Oh, crutches, yes. I'm sorry. I misunderstood you.

Q. That's okay. A lot of people misunderstand me.

But he was on crutches, right?

A. Yes, he had crutches with him.

Q. Right. And there were two dogs, two small poodle-like dogs

in the home, correct?

A. Yes.

Q. And they had all been placed in that one room, correct?

A. No. I took the daughter upstairs to go get the dogs.

Q. Okay. So you took the daughter upstairs so that she could

retrieve the dogs, and you brought his daughter back down and

put her back in that room, correct?

A. Correct.

Q. Okay. And you had them stay there while the rest of your

team searched the whole home, correct?

A. Yes.

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Q. Okay. You gave her a copy of the search warrant, I'm

assuming?

A. I did not.

Q. Okay. But she didn't stand in the way of you searching the

home, right?

A. No, she did not.

Q. Neither did the boyfriend who was on crutches, correct?

A. Correct.

Q. And certainly the wife didn't stand in the way, correct?

A. Correct.

Q. His wife is about 60 years old; is that right?

A. I have no idea.

Q. Wasn't she nervous when you watched her?

A. I didn't watch her. I——I saw her for——briefly. I spoke

with the daughter, I took her to get the dogs, brought them

back down, I let her know that, you know, if she needed to

bring them out, to feed them, it's not a problem, just let us

know, and then we proceeded.

Q. And then you started to search the house. You said there

were at least about 20 other people, correct?

A. Yeah. Oh, at least.

Q. Okay. And when you say at least, were there more than 20?

A. I think we had approximately 40 people searching.

Q. Okay. So you had 40 people searching, three residents in

the home, right?

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A. Yes.

Q. And nobody interfered with your search.

A. No.

Q. Okay. At the time that you executed the search at

373——that's what I'm going to call it, okay——did you know how

many other homes Mr. Guo had?

A. No.

Q. Did you know he had a home in New York City?

A. I know that they were doing other warrants at the same

time. I'm not sure which homes he owned or where he lived.

Q. Okay. At the time that you executed the search did you

know Mr. Guo to have a lawyer?

A. I have no idea.

MR. FINKEL: Objection.

THE COURT: Overruled.

Q. At the time that you went to search Mr. Guo's home, did you

know anything about his status in the United States?

MR. FINKEL: Objection.

THE COURT: If you'll step up, please.

(Continued on next page)

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(At the sidebar)

THE COURT: So this is beyond the direct.

MS. SHROFF: I'm happy to call her as my own witness

then, your Honor. But I'm allowed to have some latitude about

what she knew when she executed the search warrant. I'd be

happy to be more constrained, your Honor, but——

THE COURT: So whether he had a lawyer, I allowed

that, but now going into his immigration status, I think that's

just going beyond.

MS. SHROFF: Well, she took——she took hundreds of

documents from his home. I'm entitled to ask what other

documents she took and what other documents he elicited

testimony about.

THE COURT: Are there documents that relate to his

immigration status?

MR. FINKEL: I don't know, but I understood from their

response to our letter the other night that his immigration

status is not at issue and it isn't——it's irrelevant. And I

also understood from your Honor's ruling the presence of

lawyers is not something that the defense was going to dwell

on, nor should they suggest, by implying to the jury that

Mr. Guo had a lawyer, somehow the search was improper. The

search was proper. It was judicially authorized.

MS. SHROFF: Your Honor, asking if somebody has a

lawyer does not imply that a search is improper, number one.

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Number two, she recovered documents. If they want to

cherry pick as to what they put in, I'm allowed to explore what

else was out there. We have no interest, and, you know, the

immigration issue——

THE COURT: You can ask whether or not there were

documents related to immigration status.

MS. SHROFF: Right. And that shows that a person

lived in their home; personal documents were in his home.

My——the point of my cross is to show that's his residential

home. I'm not seeking to present a defense that he has an

immigration consequence through this conviction, which is what

the brief was about, so I don't know why that's being brought

up here. Totally irrelevant.

THE COURT: So there's no dispute as to whether or not

it was used as a home, is there?

MS. SHROFF: Oh, yes. Their argument is that Mahwah

was also a home, and I'm trying to show this was his home

alone, nothing that is recovered here is anywhere comparable to

anything recovered in Mahwah. I am entitled to show that.

THE COURT: So you're saying this is his principal

home?

MS. SHROFF: His only residential home.

THE COURT: Okay. Well, she can bring out some

evidence on that issue.

MR. FINKEL: Certainly. It shouldn't suggest

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immigration status. Immigration status is not something that's

relevant.

MS. SHROFF: We're not talking about a status. I have

a status, you have a status. I'm an American passport holder.

That's my status. If my passport is in my home, it's more

likely it's my home, it's less likely it's your home, right?

MR. FINKEL: I completely agree the passport is——

THE COURT: Sure. But you were asking about his

immigration status.

MS. SHROFF: I'll move from there and ask him if she

found some immigration-related document or his immigration

paperwork, his identity card, his wallet. I'm entitled to ask

all of that.

MR. FINKEL: Your Honor, no objection to identity

card, no objection to wallet. My objection is for 402, 403

reasons to immigration documents and immigration status.

That's not appropriate. It's not relevant. I have no issue

with them exploring personal effects that were there. That's

fine. But——

MS. SHROFF: We're not arguing he's going to be

deported or anything like that. We're just trying to show that

he had immigration paperwork at his home.

THE COURT: But ask for a passport as opposed to, do

you know what his immigration status was.

MS. SHROFF: Sure. I'd be happy to rephrase.

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THE COURT: Thank you.

(In open court)

THE COURT: Objection is overruled.

BY MS. SHROFF:

Q. Agent McNamara, how many hours did you spend searching the

home?

A. None. I didn't search.

Q. Okay. You simply supervised the search, correct?

A. Correct, mm-hmm.

Q. And you were directly supervising how many people?

A. Approximately 40.

Q. 40 people, correct?

A. Mm-hmm.

Q. And 40 people were given the task of searching different

parts of the home, correct?

A. Yes.

Q. Every bedroom was searched, correct?

A. Yes.

Q. Every living room was searched, correct?

A. Yes.

Q. Closets were searched, correct?

A. Yes.

Q. Bathrooms were searched, correct?

A. Yes.

Q. Okay. So in the closets, and it's——if I could please

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have——actually, I rephrase that.

You were shown pictures of the closet, correct?

A. Yes.

Q. And in the closet there were white shirts hanging, correct?

A. Yes.

Q. Shoes?

A. Yes.

Q. Other men's clothing, correct?

A. Yes.

Q. And did you know who those clothing belonged to?

A. No.

Q. Did you make any effort to find out whose clothing they

were?

A. No, that's not part of the search.

Q. Okay. And then you searched the kitchen, correct?

A. Yes.

Q. The kitchen was an average kitchen with kitchen-related

things in it, correct?

A. It was a very nice kitchen with kitchen-related things in

it, yes.

Q. Okay. But there was food there on the counter, correct?

A. There was food. I don't recall specifically what the food

was.

Q. Okay. And after you searched the kitchen, you searched the

other rooms, correct?

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A. I did not search.

Q. Well, you testified to a lot of photographs during the

search, so I apologize.

You supervised the search where those rooms were

searched, correct?

A. Yes, ma'am, yes.

Q. Okay. Let's take a look at the photographs of the garage,

shall we, so that we can talk about that red Lamborghini.

Did you enter the garage to look for the red

Lamborghini?

A. I entered through the garage but not to look for the

Lamborghini.

Q. And is it fair to say that you had emailed with your team

about a search warrant for that particular Lamborghini,

correct?

A. The seizure warrant for the Lamborghini was included, yes.

Q. You emailed about the seizure warrant, correct?

A. I emailed the entire team, the search warrant and the

seizure warrant.

Q. Okay. And you had the seizure warrant for the car

separately discussed, right? It was an important issue for

you, correct?

MR. FINKEL: Objection. Vagueness.

THE COURT: What is the question?

Q. Sure. You were specifically told to look for a red

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Lamborghini, correct?

A. No. It was——we had a seizure warrant for the Lamborghini,

but nobody said: Make sure you find the Lamborghini.

Q. Okay. So there was a specific seizure warrant for the car,

the Lamborghini, right?

A. Yes.

Q. You were told it was red, correct?

A. I don't recall.

Q. Okay.

A. I know it had the VIN number on the seizure warrant. I

don't recall if it had the color.

MS. SHROFF: Okay. If I could just have 95 pulled up,

please.

Q. And that's the car. Did you actually view the car in this

state?

A. I'm sorry. I don't understand. The state? In

Connecticut, is it?

Q. No. I mean covered.

A. Oh, no.

Q. You didn't see it when it was covered, correct?

A. No, I did not. That's one of the entry photos.

Q. Okay. And the person who took this photo, this is how they

found the car, correct?

A. Yes.

Q. The car was covered with this black thing on the top,

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correct?

A. Yes.

Q. And it's plugged into——there's a wire going into the car,

correct?

A. Yes.

Q. And then the wire is plugged in, correct?

A. Yeah, it looks plugged in.

Q. Right. I don't drive so I don't know, but does that mean

the car is charging?

A. I would——I believe that's to keep the battery charged.

Q. To keep the battery charged, correct?

A. Yes.

Q. Okay. And this was one of many garages that was there,

correct?

A. There were two garages.

Q. Right. And in this garage then there's somebody who's

obviously working out so there's some kind of workout equipment

on the right, correct?

A. Yes.

Q. And then this is usual stuff you would find in somebody's

home, right?

MR. FINKEL: Objection as to the form.

THE COURT: Overruled. You may answer.

A. Yes, it's typical items from a garage.

Q. The garage wasn't locked, correct?

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A. I don't know that.

MS. SHROFF: Okay. And then if I could have the

uncovered version of the car, please.

Q. And that's what the car looked like, correct?

A. Yes.

Q. Okay. And you see that little white thing on the hoodie

part?

A. Yes.

Q. What's that for?

A. I don't know.

Q. Okay. Did you search the car at all?

A. I did not.

Q. Did you talk to or——talk to the person who you were

supervising that was searching the car?

A. Yes.

Q. Okay. And did they tell you if they found a driver's

license in the car?

A. They did not.

Q. Did they tell you if they found anything related to Miles

Guo in the car?

A. No.

Q. Did they tell you they found his clothing in the car?

A. No.

Q. Did they tell you they found anything in the car?

A. No.

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MS. SHROFF: And let me see if I could just get those

keys, please.

Q. This is Government Exhibit 36, correct? You testified

about these keys?

A. Yes.

Q. Okay. You didn't recover the keys, right?

A. I did not.

Q. You don't know who recovered the keys, correct?

A. I——there were two searchers in that room. I don't recall

which one recovered the keys.

Q. Okay. So somebody gave you the keys and here they are in

the courtroom, correct?

A. Yes.

Q. Okay. And you testified to these keys, right?

A. Yes.

Q. Okay. And you testified to them because the government

showed them to you when you were preparing for your testimony

here today, correct?

A. I don't understand the question. I'm sorry.

Q. Sure. They showed you these keys when they prepped you,

right?

A. They showed me these keys, yes.

Q. And they prepped you, right, for your testimony here today?

A. Sure, yes.

Q. You met with them several times, right?

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A. Yes.

Q. You met with them this morning, correct?

A. Yes.

Q. Twice this morning, or once? How many times?

A. Once, I believe.

Q. You believe once?

A. I believe once, yes.

Q. Okay. And then they told you to come in early so that they

could prep you, right?

A. I believe so.

Q. They sent you a text?

A. Text or an email. I'm not sure.

Q. All right. Well, here, let me help you out.

A. Okay.

Q. Did you keep a note of how many times it is you met with

these prosecutors to prepare for your testimony here today?

A. No.

Q. Do you know if it was more than five times?

A. I don't know.

Q. How many times in the last two days did you meet with them;

do you remember?

A. I don't know if I met with them yesterday.

Q. Let me talk to you a little bit about these keys.

A. Mm-hmm.

Q. I'm going to leave them right here.

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There's an evidence tag on those keys, correct?

A. There's a tag. I'm not sure what——what kind of tag this

is.

Q. Okay. But it's a tag put on by your people, right? That

tag wasn't on the keys when you first——when you got the keys,

right?

A. I have no idea who put this tag on. They were not on the

keys at the time.

Q. Okay. And the keys were just exactly like the way you see

them in their envelope, right?

A. I——I don't know.

Q. You don't know if it had a keychain on it, correct?

A. I don't know.

Q. You don't know if it had a nametag on it, correct?

A. I don't know.

Q. When was the first time the prosecutor showed you those

keys?

A. Today.

Q. This morning.

A. Yes.

Q. Okay. And he showed you those keys and he told you you

were going to testify to them, correct?

A. He asked me about the keys.

MS. SHROFF: Okay. See if this refreshes your

recollection.

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MR. FINKEL: Your Honor, there's no failure of

recollection. Objection.

MS. SHROFF: I believe she couldn't remember——

THE COURT: No, she did not say she could not recall.

Sustained.

BY MS. SHROFF:

Q. You testified earlier that you couldn't recall, right,

whether it was by email or by text that they asked you to come

in this morning?

A. Yes.

Q. Okay. Does that refresh your recollection, ma'am?

A. Yes, it looks like a text.

Q. Okay. And they texted you to come in early so they could

prepare you, correct?

A. Yes.

Q. Okay. And you came in early 'cause you wanted to be

prepared for testimony here today, right?

A. That, and it's two——it's two and a half hours to get here

from Connecticut, so I had to be here before the traffic.

Q. Okay. But you met with them, right?

A. Yes.

Q. Okay. And they asked you about those keys, correct?

A. Yes.

Q. They asked you who recovered them and you said, I don't

know, correct?

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A. Correct.

Q. And they asked you where they were recovered and you said,

I don't know, correct?

A. I know which room they were in. I said it was the room

that——where it had——it's like an office and it had cam——display

monitors with——for the security cameras.

Q. And the security, that's where you were told that the keys

were put, correct?

A. That's where the keys were found.

Q. Okay. So the keys were not found in the garage where the

car was, correct?

A. Correct.

Q. They were not found inside the car where one would leave

them if they used the car every day, correct?

MR. FINKEL: Objection, as to form.

THE COURT: Sustained.

Q. Were they found inside the car?

A. No.

MS. SHROFF: If you could just show her, please, and

the jury, No. 95.

Q. Did somebody actually drive the car out of the garage when

they seized it?

A. I don't know.

MS. SHROFF: If somebody could please put up 58.

Q. You testified as to this photograph, correct?

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A. Yes.

Q. And could you tell me, please——on the right side you see a

flag, correct?

A. Yes.

Q. Did you know what that flag was for?

A. No. I have no idea.

Q. Was there a nametag on the flag?

A. I don't know.

Q. Was there a notation New Federal State of China anywhere

telling you about that flag?

A. I don't know anything about this flag.

Q. Okay. Look on the left side of that photograph, please.

Do you see that big yellow——the big white round thing?

A. Yes.

Q. What was that?

A. I don't know.

Q. That's something that was used to broadcast with; is that

correct?

A. I don't know.

MS. SHROFF: Okay. Could you zoom out, please.

Q. Did you conclude that this was an office space or a working

space?

A. It looks to me like some type of studio-type setup.

Q. It looked like a recording studio, correct?

A. Something like that, yes.

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Q. It looked like a place from where someone would broadcast,

correct?

A. Yes.

MS. SHROFF: May I please have No. 59.

Q. Okay. This is a better picture, perhaps.

So there's recording equipment right there, correct?

A. Yes.

Q. There's a computer monitor, correct?

A. Yes.

Q. A chair?

A. Yes.

Q. And during your search did you try to find out if these

were working equipment?

A. No.

Q. Okay. Thank you very much.

MS. SHROFF: May I have 83, please.

Q. Now you testified about certain documents that the

government had you read, right?

A. I read them.

Q. Right. You read them out loud, the loan agreements,

correct?

A. Yes.

Q. Okay. How much paperwork did your team recover from that

home?

A. Printed paper?

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Q. Yes.

A. Not a lot.

Q. Not a lot?

A. No.

Q. Okay. There was a loan agreement that you read out loud

for him, correct?

A. Yes.

Q. Okay. Did you know what the loan agreement was about?

A. No.

Q. Do you know where the loan agreement was kept?

A. No.

Q. Do you know who kept the loan agreement in which room?

A. No.

Q. Do you know if it was Mr. Guo's room?

A. No.

Q. Do you know if it was even in the kitchen or the toilet,

you have no idea where it was, right?

A. We could——you could go back to the——the evidence log.

Q. Do you know?

A. Do I know? No. I did not search.

Q. Okay. And you testified and read documents that the

government asked you to read, correct?

A. Yes.

Q. You'd never read them before, correct?

A. Correct.

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Q. You didn't choose which documents to read to the jury,

correct?

A. I did not.

Q. You don't know what other documents were recovered in the

home 'cause you didn't do the search, correct?

A. That's correct.

Q. Okay. You didn't recover Mr. Guo's wallet in there,

correct?

A. I don't recall a wallet being found.

Q. Passport?

A. No.

Q. Sitting here today, do you recall if there was even a

driver's license in his name?

A. I don't know.

Q. How about a learner's permit?

A. No, I did not see any of that.

Q. So your memory is basically limited to what the government

showed you to prepare you for the trial here today.

MR. FINKEL: Object to form.

THE COURT: You may answer.

A. No. I remember what I did when I was there.

Q. Right. But all you did was supervise, right?

A. That's correct.

Q. You're not the one who searched for anything at all,

correct?

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A. That's correct.

Q. You recovered none of the things that you've testified to

today, including the keys, correct?

A. That's correct.

Q. You testified about a suit with the name Brioni on it,

correct?

A. I think it was a paper, piece of paper.

Q. Do you remember testifying about a hanger with the name

Brioni on it?

A. I saw the picture. I don't think I was asked about that.

Q. Okay. Do you know what Brioni is?

A. I have no idea.

Q. Do you know if there were suits recovered in that home,

men's suits?

A. Suits were not on the list of items to be seized. We

didn't take any clothing.

Q. My question was in——okay. Did you see any of the suits?

A. Yes.

Q. Okay. Did you know how old they were?

A. No.

Q. Do you know if they were from 2010, versus 2020?

A. No.

Q. Do you know if they were his suits or somebody else's

suits?

A. No.

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Q. Now you remember reading a document from which they made

you read names and then you read something called Voice of Guo,

Voice of Good, correct?

A. Yes.

Q. Okay. Do you know what that meant?

A. No.

Q. Do you know what Voice of Guo is?

A. No.

Q. Do you know what Voice of Good is?

A. No.

Q. Do you know what Saraca is?

A. No.

Q. This is the hanger I'm talking about. You testified as to

this hanger, right, this photograph?

A. I saw the photograph. I——yes.

Q. Right. You never saw the hanger, though, right?

A. I did not.

Q. Okay. So you're only testifying here about the photographs

that somebody else took and gave to you, correct?

A. Yes.

MS. SHROFF: Okay. May I have, please, No. 176.

Q. Okay. You testified about this document, correct?

A. Yes.

Q. Mr. Finkel asked you to read it out loud and you read it

out loud to the jury, correct?

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A. Correct.

Q. Okay. What does it mean Designer No. 1 Whistle?

A. I have no idea.

Q. Pants 100, do you know what it means?

A. I do not.

Q. Hat 200, do you know what it means?

A. I do not.

Q. Sitting here today, do you know if these pants and hats

were supposed to be part of a swag bag?

A. No.

Q. You don't know anything about what you read to the jury,

correct?

A. That's correct.

Q. All you can tell them is that there was this piece of paper

found by somebody in your team and they took a photograph, and

you recited that to the jury.

MR. FINKEL: Objection as to form.

THE COURT: Overruled. You may answer.

A. I apologize. I've already forgotten the question.

Q. All you know is that somebody took a photograph, they took

that photograph that you then looked at, the government had you

read out loud to this jury and you did that, correct?

A. Yes.

Q. Okay. Could I have 184, please.

You see that yellow sticky on this exhibit that you

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testified about?

A. Yes.

Q. "For Matthew, new insurance cards for all four vehicles

effective," or "effect 4/1/20," correct?

A. Yes.

Q. Do you know who wrote that Post-it?

A. No.

MS. SHROFF: And if you scroll down, please.

Q. That's the entire document, right?

A. I don't know.

Q. You don't know if these documents were recovered together,

correct?

A. I don't know.

Q. You don't know if they were in one place together, correct?

A. I don't know.

Q. You don't know who filled out the documents, correct?

A. Who filled out——I don't understand, who filled out.

Q. You don't know whose handwriting is anywhere on these

documents.

A. Oh, no.

Q. Somebody showed you a photograph, you're testifying about

the photograph, right?

A. Yes.

MS. SHROFF: Okay. You can take that down.

If I could just have 393.

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MR. FINKEL: I don't believe 393 is in evidence.

MS. SHROFF: Okay. 174.

Q. You see this document? You also testified to this,

correct?

A. Yes.

Q. Lies told by Miles Guo. You have no idea what date they're

talking about, correct?

A. Correct.

Q. You don't know what questions and answers this is about,

right?

A. Right.

Q. You don't know who has preselected questions or what they

are, right?

A. Correct.

Q. You just got up there and read it to the jury because he

told you to, right?

A. That's what I was asked to do, read it.

MS. SHROFF: Okay. And could we scroll down.

Q. This is the full page, right? Do you know where it was

recovered from?

A. No.

MS. SHROFF: Okay. You may take that down.

If I could have 129.

Q. You testified to this document?

A. I don't recall.

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Q. Okay. Then we can take it down.

Is it fair to say, Agent McNamara, that your job was

limited to receiving whatever other people in that house were

looking for and giving to you?

MR. FINKEL: Object as to form.

THE COURT: I did not hear that.

MR. FINKEL: Objection as to form.

THE COURT: Overruled. You may answer.

A. Nobody gave me anything. I managed the search. The

searchers searched, the photographers took the photographs,

they entered the items into our evidence list so we had a list

of what was taken, and they packaged it. They didn't hand them

to me to do that.

Q. Okay. Fair enough. And the search you said took four

hours, right?

A. Approximately four hours, yes.

Q. Nobody bothered you during your search, correct?

A. No.

Q. And then the search was complete, you left?

A. Completely?

Q. When the search was complete, you left, right?

A. Yes.

MS. SHROFF: Okay. Thank you very much.

THE COURT: Redirect?

MR. FINKEL: Very briefly.

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REDIRECT EXAMINATION

BY MR. FINKEL:

Q. Special Agent McNamara, what was the role of you and your

team on March 15, 2023?

A. To help execute the search warrant.

Q. And when documents or physical items are recovered from a

search, what, if anything, does the FBI do to keep track of

where those materials come from?

A. So they're seized by the seizing agent, and then it starts

a chain of custody.

Q. And can you explain a little bit about how it's tracked

where particular materials are recovered from.

Like which room, for example.

A. Oh, sure. So when someone finds an item in a room, we send

the photographer, they take a photo in place. When we do our

photos, we give each room a letter, so when that item is

recovered, we'll say, give a description of the item, say, you

know, cellphone serial number so and so was located in room B

on desk. And then we put the people who——the two people who

actually found and witnessed that item.

Q. And was that procedure followed on March 15, 2023?

A. Yes.

Q. And Special Agent McNamara, when the FBI leaves, what

precautions or what's the policy and procedures right before

leaving? What does the FBI do?

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A. With the evidence?

Q. The evidence and the photographs.

A. Oh. So there is a seizing agent, so there's one person

that takes custody of the evidence, and they start the chain of

custody, and they bring that evidence to the evidence room,

where it gets logged in and put into the case file. The

photographs, like I——I believe I said earlier, the photographer

takes the SD card and burns it directly to disks, so we don't

put it in a computer first, and then we make an original copy

that goes into the case file, a backup of the original copy

into the case file, a copy for the case agent, and then, should

we need another copy for the lab, or for sending stuff to

forensics, for forensics, then we make a fourth copy.

Q. Special Agent McNamara, do you know what stats FBI, the New

York FBI investigative team, took prior to the search on

March 15, 2023, with respect to this case?

A. No.

Q. Do you know what steps FBI——what investigative steps they

took after March 15th of 2023?

A. No.

Q. Do you know if the case agent——what's a case agent?

A. It's usually——there's usually one, sometimes more, assigned

as the——the responsible person for that case.

Q. And do you know if the case agents——are you a case agent on

this case?

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A. No.

Q. Do you know if the case agents know what Saraca means?

A. I have no idea.

Q. Do you know if the case agents have reviewed those

documents?

A. I don't know.

Q. And discussed them with the U.S. Attorney's Office?

A. I don't know.

Q. Whether the case agents have gotten other search warrants?

MS. SHROFF: Your Honor, the case agent isn't

testifying here today.

THE COURT: He's asked whether she knows what the case

agent has done or not done. She may answer.

A. I do not know.

Q. And Special Agent McNamara, aside from the search March 15,

2023, do you have any other involvement in this matter?

A. No.

MR. FINKEL: Thank you, Special Agent McNamara.

THE COURT: Recross?

MS. SHROFF: Very briefly.

RECROSS EXAMINATION

BY MS. SHROFF:

Q. You took every precaution to make sure that the evidence

was properly documented, correct?

A. Yes.

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Q. And you made sure to take photographs of the evidence,

correct?

A. Yes.

Q. Or had the photographs taken, correct?

A. Yes.

Q. And then you made sure those photographs were properly kept

in a file, correct?

A. Yes.

Q. And after taking all of those steps, when you reviewed the

evidence, there was nothing with a singular name tied to that

Lamborghini that involved Miles Guo, correct?

MR. FINKEL: Objection.

THE COURT: If you know the answer, you may answer.

A. I do not know.

Q. There was not a single title to the Lamborghini in Miles

Guo's name, correct?

A. I don't know.

Q. You read the title, didn't you?

A. I read that title. I don't know if there were other

titles. I don't know.

Q. So you are only——your knowledge for this jury is only

limited to what he told you to testify about.

A. No.

Q. Well, you tell me. If you know more and you took all these

detailed steps, could you tell this jury if you recovered any

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singular document linking the Lamborghini to Miles Guo?

A. I do not know.

Q. You didn't find anything linking the cars to the

Lamborghini to Miles Guo.

A. The cars to the Lambor——

Q. The keys.

A. Oh, the keys. I thought you said cars. No.

Q. And nothing in the car, not a single piece of clothing, not

a driver's license, linked that car to Miles Guo, correct?

A. Not that I'm aware of.

Q. Well, you can only testify to what you're aware of, ma'am.

A. Right.

Q. That's a no. The answer is no? Is the answer no?

A. I've forgotten the question now.

Q. There is nothing that you found linking that Lamborghini to

Miles Guo, correct?

A. Nothing of the search of 373, correct.

Q. That's where the car was, correct?

A. Yes.

Q. Thank you.

MR. FINKEL: One question.

THE COURT: Re-redirect?

REDIRECT EXAMINATION

BY MR. FINKEL:

Q. Special Agent McNamara, do you know if the FBI New York

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team has a video, or recovered a video of Miles Guo driving the

Lamborghini that was found at 373 Taconic on March 15, 2023?

A. I do not know.

MR. FINKEL: Nothing further.

THE COURT: Re-recross?

RECROSS EXAMINATION

BY MS. SHROFF:

Q. Driving a car doesn't mean you own a car, correct? As a

Special Agent you'd be able to testify to that, right?

A. Yes.

MS. SHROFF: Thank you.

THE COURT: Thank you. You may step out. And the

government may call its next witness.

(Witness excused)

MS. MURRAY: Thank you, your Honor. The government

calls Louie Bonsukan.

THE LAW CLERK: Please raise your right hand.

(Witness sworn)

THE COURT: Please state your name and spell it.

THE WITNESS: My name is Louie Bonsukan. It's

L-O-U-I-E, last name, Bonsukan, B-O-N-S-U-K-A-N.

THE COURT: You may inquire.

MS. MURRAY: Thank you, your Honor.

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LOUIE BONSUKAN,

called as a witness by the Government,

having been duly sworn, testified as follows:

DIRECT EXAMINATION

BY MS. MURRAY:

Q. Good afternoon, Mr. Bonsukan.

A. Hello.

Q. What kind of work do you do?

A. I'm the finance director for Lamborghini Dallas.

Q. And what are your duties and responsibilities as the

finance director at Lamborghini Dallas?

A. I help facilitate the paperwork on a sale of a vehicle.

Q. How long have you worked at Lamborghini Dallas?

A. A little over 13 years.

Q. Approximately how many Lamborghinis does Lamborghini Dallas

sell in a given month, on average?

A. Probably an average of 35 cars a month.

Q. I'd like to direct your attention to September of 2021.

Were you involved with the sale of a Lamborghini in that month

to a customer known as G/CLUBS?

A. Yes.

Q. What was your role in that sale?

A. I helped facilitate the paperwork on that sale with the

customer.

MS. MURRAY: Ms. Loftus, if you could please show the

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witness what's been marked as Government Exhibit BR460. And

scroll through page 2 and beyond.

Q. Mr. Bonsukan, do you recognize Government Exhibit BR460?

A. Yes.

Q. Have you reviewed this exhibit before?

A. Yes.

Q. Generally speaking, what is in Government Exhibit BR460?

A. It's a motor vehicle buyer's order. It basically shows the

sale of the vehicle and who sold it.

MS. MURRAY: And just scrolling through a couple of

the other pages of this exhibit, Ms. Loftus.

Q. At a high level, Mr. Bonsukan, are these business records

of Lamborghini Dallas?

A. Yes.

Q. Are you familiar with these types of documents?

A. Yes.

Q. Fair to say it's a regular part of your business to receive

and maintain these documents?

A. Yes.

MS. MURRAY: Your Honor, the government offers

Government Exhibit BR460.

MS. SHROFF: We have no objection, your Honor.

THE COURT: It is admitted.

(Government's Exhibit BR460 received in evidence)

MS. MURRAY: Ms. Loftus, can you please publish

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page 2.

THE COURT: And Mr. Bonsukan, if you would raise your

voice and speak into the microphone.

THE WITNESS: Yes, ma'am. Yes, your Honor.

MS. MURRAY: And if we could zoom in on the top

portion, please, Ms. Loftus.

BY MS. MURRAY:

Q. All right. Mr. Bonsukan, this is one of the business

records of Lamborghini Dallas. What is this particular

document?

A. The motor vehicle buyer's order.

Q. And looking on the left, who was the seller for this

particular car?

A. Lamborghini Dallas.

Q. And the buyer?

A. The buyer is G Club International Ltd.

Q. What is the date of this buyer's order?

A. September 13, 2021.

Q. I want to look now on the left, the Description of Sale

Unit. Can you describe for the jury what type of Lamborghini

this was.

A. It's a Lamborghini Aventador SVJ Roadster.

Q. Looking to the right, what color was that Lamborghini

Aventador?

A. It's red.

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Q. And there's a field call Stock No., or stock number. What

information is reflected there?

A. The stock number is a number that we give a——as a

dealership to a particular vehicle that we're selling rather

than using a VIN number.

Q. So you mentioned VIN number. What's a VIN number?

A. The vehicle identification number, which identifies the

vehicle.

Q. Looking a bit further down on Description of Sale Unit, is

there a VIN number listed here for this particular Lamborghini?

A. Yes.

Q. And what are the last three digits of that VIN number?

A. Last three is 393.

Q. What year was this Lamborghini?

A. 2021.

MS. MURRAY: Ms. Loftus, if we could zoom out and then

zoom in on the box on the right, Price of Unit, down to the

bottom, please.

Q. Mr. Bonsukan, at the top, what is the price of this

particular Lamborghini?

A. $829,999.

Q. And then looking down toward the bottom, what is the total

price when you add in taxes and fees?

A. $832,075.

Q. Sorry. Could you read that amount again, please, sir.

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A. $832,000.75.

Q. Thank you.

MS. MURRAY: And Ms. Loftus, if we could go to the

bottom of this page where there's a signature line, please.

Q. Mr. Bonsukan, do you recognize the seller's signature here?

A. Yes, that's mine.

Q. And what was the date that you signed this particular

contract of sale?

A. September 13, 2021.

MS. MURRAY: We can take that down, Ms. Loftus.

And let's pull up what's in evidence as Government

Exhibits CT38, 37, and 40.

Q. Mr. Bonsukan, starting here on the left, top left, with

Government Exhibit CT38, do you recognize the car depicted in

this photograph?

A. Yes, that's a Lamborghini Aventador.

Q. And what color is it?

A. It's red.

MS. MURRAY: Ms. Loftus, we can take those down, and

let's put up Government Exhibits CT42 and 43, please, which are

in evidence.

Q. Starting here on the left, Mr. Bonsukan, Government Exhibit

CT42, can you describe for the jury, please, what it is we're

looking at in that photograph.

A. This is the driver's side of the vehicle; the door, which

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is the scissor door, which raises up, shows the VIN plate on

the vehicle.

Q. Can you just describe a bit more about how the scissor door

operates, please.

A. So it hinges, as——the scissor door normally hinges up and

raises the door in this particular manner, just like this one,

rather than a normal door on a vehicle, which swings out, like

if you're opening and closing a door.

Q. And the VIN plate that you mentioned, where in the photo on

the left do we see that?

A. It's the black plate that's right on the——the scissor door.

MS. MURRAY: And Ms. Loftus, on the right where we

have a zoomed-in portion of that black plate, that VIN plate,

can we zoom in on that even further, please, the VIN number.

Q. Mr. Bonsukan, what are the last three digits of the VIN

number of this Lamborghini?

A. 393.

MS. MURRAY: Ms. Loftus, if we could now, on the left

side, pull up Government Exhibit BR460 at page 2, and zoom in

on the VIN field.

And then on the right photo, similarly, zoom in on the

VIN field.

Q. All right. Mr. Bonsukan, so on the top here is a zoomed-in

version of the VIN of the car we were just looking at

photographs of. Could you please read that VIN number, the

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vehicle identification number, into the record.

A. Z as in zebra, H as in Henry, W as in William, U as in

umbrella, N as in Nancy, Z as in zebra, D as in David, 2, M as

in Mary, L as in Lima, A as in alpha, 10393.

Q. And then looking at the one on the bottom here,

Mr. Bonsukan, which is from the contract of sale from

Lamborghini Dallas to G Club International, is that the same

VIN number that was on the car depicted in the photograph?

A. Yes.

Q. And based on your work at Lamborghini Dallas for the past

13 years or so, do you have an understanding whether VIN

numbers are unique to a particular vehicle?

A. They are.

MS. MURRAY: Ms. Loftus, we can take those down.

And let's please show the witness what's been marked

as Government Exhibit GX GC295, at page 10.

Q. Mr. Bonsukan, are you able to see what's in Government

Exhibit GC295 here, page 10?

A. Yes.

Q. Do you recognize it?

A. I do.

Q. How do you recognize it?

A. It's a——it has my name on it. It's a normal letter that I

send out to a client along with the documents that we send out

to them for signature.

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MS. MURRAY: Your Honor, the government offers

Government Exhibit GC295.

THE COURT: Any objection?

MS. SHROFF: No, your Honor.

THE COURT: It is admitted.

(Government's Exhibit GC295 received in evidence)

MS. MURRAY: Can we please publish that.

BY MS. MURRAY:

Q. Mr. Bonsukan, what is the date of this particular letter?

A. September 14, 2021.

Q. And to whom is it addressed?

A. Mr. Horan.

Q. Looking at the signature block here, is that your signature

or your electronic signature on this letter?

A. Yes.

Q. And generally speaking, what was the purpose of this

letter?

A. It basically explains, thanking the client for purchasing a

vehicle and then things that's needed to be done in order to

facilitate the paperwork and then to instruct them to FedEx the

documents back.

Q. And does this particular letter relate to the contract of

sale dated September 13, 2021, that we just looked at for G

Club International?

A. Yes.

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MS. MURRAY: Ms. Loftus, let's take that down and put

up Government Exhibit BR460 again, at page 5, please.

Q. What type of document is this, Mr. Bonsukan?

A. This is internal record for our dealership when a——when

funds are received, from a client.

Q. And what is the date listed on the top right of this

particular document?

A. September 14, 2021.

Q. Looking over on the left side, it indicates Cash Received

From, do you see that?

A. Yes.

Q. Who sent the money to Lamborghini Dallas, as reflected

here?

A. It shows G Club Hold Co. 1, LLC.

(Continued on next page)

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BY MS. MURRAY:

Q. And then is that crossed out in part and there is something

written over it?

A. Yes.

Q. What is the corrected name listed here?

A. G Club International LLC.

Q. Looking at the payment amount here just below, what is the

total amount of the electronic transfer from G Club

International?

A. $832,000.75.

Q. And the wire detail that's in bold below, wire from, do you

see that?

A. Yes.

Q. Can you read what that reflects?

A. Wire from Mercantile Bank for G Club International Ltd.

MS. MURRAY: Let's go to the next page please,

Ms. Loftus.

Q. What is this, Mr. Bonsukan?

A. This is a wire confirmation that's emailed to me from

JPMorgan Chase Bank, which is our bank, that notifies when a

wire was received.

Q. And what is the date of this wire notification?

A. Monday, September 13th, 2021.

Q. Looking down at the body of this email, what bank was this

wire received from?

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A. Received from the Reserve Trust Co, Greenwood Village,

Colorado.

Q. And then a few lines down, there's a beneficiary and then a

B/O customer. What does that reflect?

A. Mercantile Bank International, 644 Fernandez Juncos Avenue,

Third Flo, San Juan, Puerto Rico.

MS. MURRAY: Ms. Loftus, let's go to page 8, please.

If we could zoom in on the text. Thank you.

Q. It's a little hard to read, Mr. Bonsukan, but what kind of

information is reflected on this business record?

A. This is looks like wire instructions.

Q. And can you read the bank name listed at the top here?

A. Bank name is Reserve Trust Company.

Q. What about the beneficiary account name?

A. Mercantile Bank International.

Q. And finally, for further credit down at the bottom, what's

listed under MBI client account?

A. G Club International Limited.

Q. And if you could read the last five digits of that MBI

client account number for G Club International Limited?

A. 10103.

MS. MURRAY: All right. Ms. Loftus, can we please go

to page -- starting on page 19 of BR-460.

Q. Mr. Bonsukan, do you see this email that is reflected here?

A. Yes.

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MS. MURRAY: If we could scroll down, Ms. Loftus.

This is part of a chain. We're going to start with some of the

earlier messages in this chain. Looking here -- thank you,

Ms. Loftus.

Q. This is an email, September 9, 2021. Can you tell us who

that's sent from?

A. It's sent from Max.

Q. And to whom was it sent?

A. To Mike Durkey.

Q. Who is Mike Durkey?

A. Previous salesperson for Lamborghini Dallas.

Q. After the bracket external, what is the subject line of

this email?

A. G Club Hold Co. LC732-Lambo SVJ Roadster.

Q. And LC 732, what does that indicate?

A. That's the stock number in our inventory for this

particular vehicle.

Q. Can you please read the body of this email from Max to Mike

Durkey at Dallas Lamborghini?

A. "Hi, Mike. How much is the delivery to Connecticut?"

Q. And there's an indication of the type of email account that

Max sent the email from. Can you please read that?

A. Sent from ProtonMail Secure Email.

MS. MURRAY: All right. Ms. Loftus, let's scroll up a

bit, please, so we go later in time in this email chain.

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Q. All right. Starting with the email at the top there from

Max to Mike Durkey, can you read the content of this email,

please, Mr. Bonsukan?

A. It says: "Can you help arrange a delivery? Also, I should

have the resolution and driver's license tomorrow. Please hold

the vehicle. Thank you."

Q. Mr. Bonsukan, do you know what the reference to

"resolution" reflects?

A. Yes. It basically -- the resolution is it shows who the

directors or officers or members of a particular business.

Q. And in the course of a sale to a corporate entity or a

company, is that the type of document that Lamborghini Dallas

typically collects in connection with a sale?

A. Yes.

Q. Why?

A. We want to make sure whoever is buying the vehicle is the

one that's able to sign off for the vehicle.

MS. MURRAY: All right. Ms. Loftus, let's keep going

in this email chain, please. So we'll focus in from exactly

that through to the bottom of that email.

Q. So if you kind of start in the middle here, Mr. Bonsukan,

because this is forwarded. Start with the email from Max

again. This is September 10, 2021. Can you read the content

of that email to Mike Durkey, please.

A. "Hi, Mike. Attached is the passport which I'll text you

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the password separately. Also, attached is the correct entity

name. Please reissue the documents with the corrected name.

Thank you. Kind regards, Max."

Q. And that email is forwarded to you which we can see at the

top of this portion. Do you see that, Mike Durkey to you?

A. Yes.

Q. And what does he -- what does Mike Durkey write to you?

A. "Passport secured by top secret password: 123456."

MS. MURRAY: Thank you, Ms. Loftus. If we could keep

going up in the chain. All right. And now I'd like to focus

on this bottom half from Mr. Bonsukan to a Max Krasner account.

Q. All right. Mr. Bonsukan, this is about a month later

October 19, 2021?

MS. SHROFF: Objection to the testifying.

THE COURT: You can ask him what date he sees.

Q. Mr. Bonsukan, can you please read the date of this email?

A. The date is October 19, 2021.

Q. Thank you. And who sent this email?

A. It was sent from me to Max Krasner.

Q. And what is the email address to which it was sent?

A. Max -- M-A-X-K-R-A-S-N-E-R at ProtonMail.com.

Q. Who's Max Krasner?

A. Probably one of the agents for -- that helped in regards to

negotiating with Mike Durkey.

Q. And negotiating with respect to what sale, if any?

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A. The Aventador SVJ Roadster.

Q. And that was the sale to G Club; is that correct?

A. To G Club.

Q. Did you ever speak personally with Max Krasner?

A. No.

Q. Did there come a time when you communicated with Max

Krasner regarding the sale?

A. Through email.

Q. You could read this email that you sent to Max Krasner,

please.

A. "Hi, Max. Here are the signed copies of the buyer's order,

odometer, and dealer reassignment form I have received with the

Wilmington, Delaware address. This was the address Mike gave

to me. Once we have title in hand, then we will send it to you

at the 162 East 64th, New York, New York, 10065 address with

signature required on the FedEx. We will be on the lookout

tomorrow for the title. If we do not receive, then we will

apply for a duplicate. Best regards," and my signature.

Q. Mr. Bonsukan, what is a title as it's indicated here?

A. A title is a form given for a particular vehicle; basically

it's the ownership papers of that particular vehicle.

Q. And what, if anything, does Lamborghini Dallas do with a

title to a car when it sells a car?

A. We reassign the title to the new owner.

MS. MURRAY: Ms. Loftus, if we could take that down.

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Let's go to page 9 actually of BR-460. We can zoom in

on the top half so it's a bit larger.

Q. Mr. Bonsukan, what is this document, which is part of the

Lamborghini Dallas records we've been looking at?

A. Shows register of directors for G Club International

Limited.

Q. And on this document, who is listed as the named director

of G Club International Limited?

A. It shows Haoran He.

Q. Looking to the right column, personal details, what was

Haoran He's place of birth?

A. China.

Q. And nationality?

A. British.

Q. And further right, on what date was Haoran He appointed

director of G Club International Limited?

A. October 16, 2020.

Q. Mr. Bonsukan, have you ever spoken with Haoran He?

A. No.

Q. Have you ever communicated with Haoran He?

A. No.

MS. MURRAY: Ms. Loftus, let's now go to page 12,

please.

Q. What is this, Mr. Bonsukan?

A. This looks like to be a British passport.

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Q. For what individual?

A. For Haoran He.

MS. MURRAY: And let's go to page 18, please,

Ms. Loftus.

Q. Again, part of the business records relating to this sale,

what type of document is this, Mr. Bonsukan?

A. This is a shipment received from FedEx.

Q. And what information or what documents would have been

shipped using this shipping receipt in relation to the sale of

that Lamborghini?

A. The title to the vehicle, the Lamborghini Aventador, as

well as odometer statement, some of the other title documents

that's required to transfer.

Q. Now, the "shipping from" field here indicates a certain

company. Can you read what company that indicates?

A. Yes. Boardwalk Auto Group.

Q. What affiliation, if any, does Boardwalk Auto Group have

with Lamborghini Dallas?

A. Boardwalk Auto Group is our parent company. Under that

group we have a number of dealerships, Lamborghini Dallas is

one of them.

Q. Looking on the left, can you please read the "ship to"

information reflected on this FedEx receipt.

A. Ship to attention Max, G Club International.

Q. And the address?

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A. 162 East 64th, New York, New York, 10065.

MS. MURRAY: And if we could zoom out a little bit,

Ms. Loftus, to see the ship date, please. Actually, the whole

center portion of this.

Q. What is the ship date of this FedEx package, Mr. Bonsukan?

A. October 27, 2021.

Q. And then looking at billing information here, can you read

what is reflected under "bill transportation to" on the bottom?

A. Bill transportation to: Lambo-340. Your reference number,

LC 732.

Q. And that reference number, have we seen that on other

documents we've been looking at today?

A. Yes.

Q. What information is reflected in that reference number as

it's relevant to the G Club Lamborghini?

A. That's the stock number of the Lamborghini Aventador sold

to G Club International.

MS. MURRAY: We can take that down, Ms. Loftus. Thank

you.

Q. Mr. Bonsukan, in your role at Lamborghini Dallas, after

you've confirmed a successful wire transfer or transfer of

money and receive requested documents, what, if anything, do

you do next?

A. I package everything up and send it to my accounting office

for processing of the title.

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Q. And how, if at all, are the vehicles delivered to the

customers?

A. Excuse me?

Q. How, if at all, are the vehicles delivered to the

customers, the vehicles?

A. They are normally transported via vehicle transport.

Q. Does Lamborghini Dallas facilitate in the shipment of

vehicles to customers at times?

A. Yes.

MS. MURRAY: Ms. Loftus, if we could please show the

witness what's marked as Government Exhibit GC-504.

Q. Mr. Bonsukan, at a high level, what type of document is

this?

A. This is a dispatch sheet from -- for the carrier that

transported the Aventador.

Q. Is this the type of record that is maintained in the

ordinary course of business for Lamborghini Dallas?

A. Yes.

MS. MURRAY: Your Honor, the government offers

Government Exhibit GC-504.

THE COURT: It is admitted.

(Government's Exhibit GC-504 received in evidence)

MS. MURRAY: Thank you.

Can we please publish, Ms. Loftus. We could zoom in

on the top half, first going through order information.

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Q. All right, Mr. Bonsukan. Looking on the right, what is the

business name that's listed there on the right?

A. Boardwalk Motor Sports LLC.

Q. And again, if you could just remind the jury the

affiliation between that company and your store, Lamborghini

Dallas?

A. When they created this account for central dispatch, it's

the parent company of Lamborghini Dallas.

Q. And looking on the left on carrier, what role, if any, does

the carrier have in the shipment of a vehicle?

A. That's the company that actually transported the vehicle.

Q. Under order information here, there's a dispatch date.

What is the dispatch date?

A. September 22nd, 2021.

Q. And the pickup estimate?

A. Pickup estimated date is September 25th, 2021.

Q. And what was the delivery estimate for this particular

shipment?

A. Delivery estimated, September 30th, 2021.

Q. Looking at the top there, order ID, can you read what the

order ID was for this shipment?

A. LC 732.

MS. MURRAY: Ms. Loftus, we can zoom out and then

focus on the next portion, please.

Q. Now, the vehicle information for this particular vehicle,

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if you could read the year and the car type and model?

A. 2021 Lamborghini Aventador.

Q. And then looking on the right, delivery information, what

is the name for the recipient of that Lamborghini?

A. Max (G Club International).

Q. And to what address was that Lamborghini for G Club

International shipped?

A. 373 Taconic Road, Greenwich, Connecticut, 06831.

MS. MURRAY: May I have a minute, your Honor, please?

THE COURT: Yes.

(Counsel conferred)

Q. Mr. Bonsukan, do you know what G Club is?

A. No.

MS. MURRAY: Nothing further, your Honor.

THE COURT: Cross-examination.

CROSS-EXAMINATION

BY MS. SHROFF:

Q. How are you doing, Mr. Bonsukan?

A. Good.

Q. You work at Lamborghini Dallas; is that right?

A. I do.

Q. Okay. Sorry about that. I can't see you.

And you were the one in charge of this particular

sale; correct?

A. I helped facilitate the paperwork on the particular sale.

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Q. Okay. Is it fair to say that you don't remember anybody

coming to like view the car, like you buy an average car,

right?

A. Yes.

Q. Nobody came to see it, right?

A. Not that I'm aware.

Q. Okay. And you said that, is it -- did I get it right that

Dallas Lamborghini sells about 35 of these cars a month?

A. Yes.

Q. Okay. And is it like an everyday car or is it like a

sporting car or a racing car?

A. It's, in the car world, called an exotic car. So there's

not very many made. Enthusiasts that love the brand buy the

car.

Q. Okay. And people generally buy the car because it could be

fun to ride in the car; is that right?

A. Yes.

MS. MURRAY: Objection.

THE COURT: Sustained.

Q. It's not an everyday-use car, right?

A. Not normally.

Q. Not normally. Okay.

And you've been doing this for 13 years; correct?

A. Yes.

Q. And this was one of many sales you made during the course

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of your employment in Dallas; correct?

A. Yes.

Q. Okay. So let me just walk -- just ask you a couple of

questions about the documents that you were shown by Ms. Murray

over here, okay?

MS. SHROFF: If I could just have first CT-39, please.

Q. You recognize this car, right?

A. Yes, this is a Lamborghini Aventador.

Q. What does "Aventador" even mean, can you tell us?

A. Aventador is the name of a model of a particular

Lamborghini that was built. Normally they're named after a

bull or a famous bull or a bullfighter.

Q. Okay. And this is the car that you sold, right?

A. It appears to be, yes.

Q. Okay. Could you tell us please what is this wire thing

that comes out of the car for?

A. It's a battery tender. Basically, maintaining the battery

as it sits in a garage, so it's fresh whenever the client wants

to drive it the next time.

Q. So do you normally do this if you're using the car every

day or do you charge up a battery when the car is not used

frequently?

A. It varies. The car is -- even when it's off, the computer

systems are still working. So a lot of owners always want to

keep a fresh battery, so they plug it up.

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Q. Okay. And you wouldn't -- you can't tell how often the car

is used; correct?

A. No.

Q. Okay.

MS. SHROFF: Could I have please -- I could have that

taken down. And if I could please have put up BR-460.

Q. And 460 is the document that you received from Ms. Murray

right here who did your direct testimony; correct?

A. Yes.

Q. Okay. And she asked you for documents and you sent them to

her; correct?

A. Correct.

Q. You've never spoken to me, right?

A. No.

Q. And you've never spoken to anybody else on the defense

table?

A. No. No, ma'am.

Q. Okay. And I never asked you for any documents; correct?

A. No.

MS. SHROFF: Okay. So let's look at the next

document. Could we look at CT-38.

Q. And all of the documents pertain to this car; correct?

A. Yes.

Q. And Ms. Murray asked you some questions about the type of

door that this car has, right?

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A. Yes.

Q. And it's a scissor door; is that right?

A. Yes.

Q. Does that mean anything? I mean, it's just a door, right,

a straight door, a scissor door?

A. On a Lamborghini --

MS. MURRAY: Objection, your Honor.

A. On a Lamborghini, it is a particular characteristic of the

particular model, which would be the Aventador.

Q. It's just like a gimmick, right?

A. Not necessarily a gimmick. It's just a particular type of

door that they have.

Q. Okay. And on this car there is what is called a VIN

number, right?

A. Yes.

Q. And the VIN number is the vehicle identification number;

correct?

A. Yes, ma'am.

Q. And it's fair to say, right, every car has a VIN number?

A. Yes.

Q. A Subaru has a VIN number?

A. Yes.

Q. And Ford has a VIN number?

A. Yes.

Q. So as opposed to this fancy car, if I just went and bought

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myself a regular old car, it would have a VIN number, right?

A. Yes, it would.

Q. Okay. So nothing special about the VIN number on this car?

A. No, just the identifying mark of that particular car.

Q. Okay. Great.

MS. SHROFF: So let's look at, please, 295, GC-295.

And if you could just scroll down.

Q. These are email exchanges you had about the sale of this

car; correct?

A. Are you still scrolling? It looks like from Max to a

number of people.

Q. Right. And you never -- you've testified you never spoke

to Max Krasner, right?

A. No, not -- not physically or -- it's just through email.

Q. Okay. And you just emailed back and forth because you

wanted the sale to go through; correct?

A. Yes.

Q. That's part of the reason you have a dealership, right, you

want to sell the car?

A. Yes.

Q. And there was nothing untoward about the sale of this car;

correct?

A. No.

Q. You had no red flags while you were selling this car;

correct?

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A. No.

Q. Okay. You testified on direct testimony about an email

that said Proton; correct?

A. Yes.

Q. Okay. You get emails from gmail; correct?

A. Yes.

Q. Yahoo; correct?

A. Yes.

Q. Proton; correct?

A. Yes, sometimes.

Q. Okay. So it's just like an any old email address, right?

A. Yes.

Q. Okay. And you also testified, did you not, about a top

secret password; correct?

A. Yes.

Q. The top secret password was 123456; correct?

A. Yes.

MS. SHROFF: Okay. And if I could have that taken

down and please show 295. Would you scroll down. I'm sorry.

Q. And these emails go back and forth all through you -- all

through your dealership until September, right?

MS. MURRAY: Your Honor, objection. I think

Ms. Shroff is asking about a different document than the one

that's displayed for the jury right now.

MS. SHROFF: 460 is what I want, please.

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THE COURT: Is this the correct document?

MS. MURRAY: It is, your Honor, pages 19 to 22.

BY MS. SHROFF:

Q. So let's start with page 19. You see that email that's

right there says: "Hi Max, we have -- "

MS. SHROFF: There you go. Thank you.

Q. "We have signed copies of the buyer's order." Correct?

A. Yes.

Q. Odometer and dealer reassignment form, right?

A. Yes.

Q. By the way, sitting here today, do you recall if this was a

used car that you were reselling?

A. It is a pre-owned vehicle.

Q. Right. So it's -- by "pre-owned," you mean it was used

before, right?

A. Yes.

Q. It's not a brand-new Lamborghini, right?

A. No.

Q. Okay. So this is a used car that is being resold to

somebody, right?

A. Yes.

Q. Okay. Sitting here today, do you know how old that car

was?

A. During that time?

Q. Yeah.

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A. In 2021? So it was a 2021 model for Lamborghini and we

sold it in 2021.

Q. Okay. So how many owners had there been before it, do you

know?

A. I'm not sure.

Q. Do you know if it was more than one?

A. Possibly.

Q. Okay. You don't really know, right? It could have been

one, two, three, you just don't know?

A. Correct.

Q. Okay. And sorry about that. And at this point in this

email chain, which is October 19 of 2021, right? Somebody is

giving you an address of where the -- do you read this email as

telling you where to send the paperwork or where to send the

car?

A. To send the title.

Q. To send the title, right?

A. Yes.

Q. Okay. And do you send the title to that address?

A. I don't. My title clerk does.

Q. Okay. And do you know what is located at 162 East 64th

Street?

A. No.

Q. Do you know what business is located there?

A. No.

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Q. Do you know who works there?

A. No.

Q. Have you ever heard of a person named Miles Guo? Have you

ever heard of a person named Miles Guo?

A. No.

Q. Okay.

MS. SHROFF: If we could just scroll down, please.

Q. And there is a conversation here about the passport;

correct?

A. Yes.

Q. And you get a copy of a passport, do you not?

A. Yes.

Q. And why do you need the passport, sir?

A. Gives identification of who the person that would be

signing off for the company when they buy a particular vehicle.

Q. Okay. And you got -- you got a copy of the passport;

correct?

A. Yes.

Q. And, of course, you did whatever you needed to do to verify

that that was a correct passport, right?

A. Yes.

Q. Okay. And then after that --

MS. SHROFF: If you could close that, please.

Q. You have an email that asks you if you can assist with

transport. And then they said that assistance for transport

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can be provided; correct?

A. Yes.

Q. Okay. And when you're transporting the car, you would only

transport the car out of your dealership after the things on

your checklist have been met; correct?

A. Yes.

Q. You want to make sure title passes correctly, right?

A. Yes.

Q. Registration, right?

A. Yes. We don't do the registration on a cash deal, but we

make sure that the title is signed over to the correct buyer.

Q. Okay. And you also want to make sure that the buyer has a

driver's license, right?

A. Not necessarily a driver's license, just identification.

Q. Okay. So you want to make sure that the person is properly

identified, right?

A. Yes.

Q. And you did that; correct?

A. Yes.

Q. Okay. And after you took all of those steps, you were

going to ship the car out to whatever address they told you,

right?

A. Yes.

Q. Sitting here today, do you recall if the car was originally

supposed to go to a different address?

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A. No.

Q. You don't recall?

A. I don't recall, no.

Q. Okay. And is it fair to say that where a car goes also

determines the cost of the insurance of a car?

A. Well, the shipping carrier -- when we set up shipping for

our client, we want to make sure that the shipping carrier, A,

might be familiar with the vehicle in transporting a vehicle of

this amount; and making sure that we have ample insurance to

cover if something were to happen during transport for a

client.

Q. Right. But that is the insurance on the transport part of

the car, right?

A. Correct.

Q. Would you agree with me, as a person who's been in the car

business for 13 years, that each state has a certain cost for

maintaining insurance on the car?

A. I'm vaguely familiar.

Q. Some states are more expensive than others; correct?

A. Probably, yeah.

Q. Insurance depends on whether the car is placed in a garage

or parked on the street; correct?

MS. MURRAY: Objection, your Honor.

THE COURT: Sustained.

The witness has said that he is vaguely familiar.

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MS. SHROFF: He might know the answer, your Honor.

THE COURT: With that understanding, he can answer.

Q. Do you know if insurance rates differ state to state?

A. No.

Q. Do you know if insurance is higher if you park the car on a

street versus if you park the car in the garage?

A. It depends on the insurance company.

Q. Okay. Fair enough.

MS. SHROFF: Could I have number 504, please. It's

okay, actually.

Q. When you were getting ready to ship the car, you were given

an address; correct?

A. I wasn't given the address. I have a sales assistant that

actually does our transportation for us that works with the

dealership.

Q. Okay. So once you finish of the sale of the car, somebody

else takes over to make sure the car gets to where it's

supposed to get, right?

A. Yes. Normally, the salesperson and our sales assistant.

Q. And would you know what is the markup on a used car?

A. The markup on a used car?

Q. Yes, sir.

A. It could vary.

Q. Do you know how much the markup on this car was?

A. In that particular instance, a Lamborghini Aventador,

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brand-new 2021 model would be, MSRP — manufacturer's suggested

retail price — at $650,000.

Q. Okay. And you don't know how long this car was sitting on

the parking lot before it was brought out, right?

A. Not -- no, not in particular. I could find out, but no.

Not long.

Q. When you were interacting with this person named Max,

correct, he was telling you or at least somebody in your office

where the car was going to go; correct?

A. Yes.

Q. And Max you understood was part of G Clubs; correct?

A. Yes.

Q. And he represented G Clubs' interest to you when he was

emailing with you; correct?

A. Yes.

Q. And Max Krasner from the emails, you can conclude, knew

that the car was going to go to Connecticut; correct?

A. Yes.

MS. SHROFF: Okay. Could I have one moment, your

Honor?

THE COURT: Yes.

(Counsel conferred)

Q. Who did you talk to when trying to figure out the final

price sale of the car?

A. I didn't speak with anyone.

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Q. I'm sorry, I cut you off.

A. Normally, the salesperson negotiates the price with the

particular client.

Q. So you have no idea how many times Max Krasner talked to

the salesperson and went back and forth before arriving at the

final purchase price?

A. No.

Q. You do not know how long those negotiations lasted;

correct?

A. No.

Q. And do you know if Mr. Krasner or anyone else from G Clubs

did an inspection of the car before it was shipped?

A. I don't recall. It could be possible.

MS. SHROFF: I have nothing further, your Honor.

Thank you.

THE COURT: Redirect.

MS. MURRAY: Yes, your Honor. Briefly.

REDIRECT EXAMINATION

BY MS. MURRAY:

Q. Mr. Bonsukan, you were just asked some questions about how

long that Lamborghini that we've been talking about was on the

lot. Do you recall those?

A. Yes.

Q. And you indicated it was not long; is that correct?

A. Yes.

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Q. What do you recall about the volume of sales that

Lamborghini Dallas was doing during this time period, fall of

2021?

A. Fall of 2021, obviously in the COVID times, vehicle sales

were -- on a naturally aspirated engine, which would be this

Aventador, were going like crazy because Lamborghini announced

that they were going to start doing hybrid engines on their

vehicles. So collectors and people that loved this car would

try buying it, even if they're buying it for more than what the

original MSRP is.

Q. And you mentioned that the MSRP on this car was

approximately what?

A. Approximately 650,000.

MS. MURRAY: And Ms. Loftus, if we could pull up,

please, Government Exhibit BR-460 at page 2.

Q. And focusing on the final sale price of this car here, what

was the final sale price of this particular car, this used car?

A. The unpaid balance is $832,000.75.

Q. That's nearly $200,000 more than the manufacturer's

suggested retail price; is that correct?

A. Yes.

Q. And this was a used car, but it was the same year as it was

ultimately sold to G Clubs, right?

A. Yes.

MS. MURRAY: Ms. Loftus, if we could zoom out on this

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and go to the left and look at the mileage listed for this

particular car. It's on the top left description of sale unit.

Q. Mr. Bonsukan, how many miles were on this car when it was

sold to G Club International?

A. 317 Miles.

MS. MURRAY: All right, Ms. Loftus. We can zoom out

of that and go to the top again to the seller and the buyer

names listed.

Q. Now, Mr. Bonsukan, you testified on cross-examination that

you didn't know a person named Miles Guo; is that right?

A. Yes.

Q. Do you know what the "G" in G Club International Limited

stands for?

A. No.

MS. MURRAY: Just a moment please, your Honor.

(Counsel conferred)

MS. MURRAY: Nothing further.

THE COURT: Recross.

MS. SHROFF: Yes, your Honor.

Could you just leave that exhibit. Thank you.

RECROSS EXAMINATION

BY MS. SHROFF:

Q. The Lamborghini that was sold, the red Lamborghini, right?

A. Yes.

Q. That was almost a collector's car; correct?

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A. Yes, could be.

Q. It was actually an investment; correct?

MS. MURRAY: Objection, your Honor.

MS. SHROFF: She brought it out.

THE COURT: Sustained.

Q. The price was higher than a brand-new car, right? You

testified for Ms. Murray about that, right?

A. Yes.

Q. And why was that?

A. Why is the price higher? Because it's a popular vehicle in

terms of the Lamborghini world, when a lot of people were

trying to buy these cars.

Q. And they were going to change the model; correct? You

testified to it on direct, something about it going hybrid;

correct?

A. Yes, eventually.

Q. Right. And the model G Clubs bought would only go up in

value because they were going to stop making those Lamborghinis

that way; correct?

MS. MURRAY: Objection, your Honor.

THE COURT: You may answer.

A. Possibly.

Q. Well, you testified on direct that if the price was going

to go up, people were going crazy, they wanted to keep that

model, right?

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A. It would be a risk, yeah, possibility where it could go up.

But it also could go down.

Q. Right. But that is why people were buying it, right?

A. Yes.

Q. You testified that they were literally hot off the parking

lot because everybody thought this would be a collector's

model, right?

MS. MURRAY: Objection, your Honor.

THE COURT: That's a mischaracterization of his

testimony. Sustained.

Q. People were buying it during the pandemic nonstop; correct?

MS. MURRAY: Objection, your Honor.

THE COURT: Sustained.

Q. Did the sales go up during the pandemic?

A. Sales did go up, yes.

Q. Of that red model, right?

A. Amongst a lot of other models as well.

Q. Right. But the red model was included in the one where the

sales are going up, right?

A. That's correct. It's a rare car of Lamborghini.

Q. Exactly. Thank you.

MS. SHROFF: Could I just have this exhibit made

bigger.

Q. And you see on the left-hand side where the description of

the sale unit is listed?

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A. Yes.

Q. And it says used; correct?

A. Yes.

Q. Okay. And when you go down, if you read further down on

this document, right?

A. Yes.

Q. Okay. The salesperson's name is Mr. Durkey. And that's

the person on the email chain that Ms. Murray had you read

about; correct?

A. Correct. Yes.

Q. And he's the person who finalized the sale, right?

A. He would be the one point of contact of negotiating with

the customer.

MS. SHROFF: Okay. And if I could just have that

shrunk and the next page of the document shown, please.

Q. And this page shows you just an average sale of a car no

different --

MS. MURRAY: Objection, your Honor. Scope.

THE COURT: Sustained.

Q. The car that was driven off the lot was insured, right?

A. Probably, yeah.

Q. Okay. And it was dropped off in Connecticut; correct?

MS. MURRAY: Objection.

THE COURT: Sustained.

MS. SHROFF: I'm done, your Honor. Thank you.

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THE COURT: Thank you, sir. You may step out.

THE WITNESS: Thank you, your Honor.

(Witness excused)

THE COURT: Is that the last witness for today?

MS. MURRAY: We have another witness ready, your

Honor. But given the time, we defer to the Court whether you'd

like us to start a few minutes or whether we should stop for

today.

THE COURT: All right. I think we should stop for

today. You may step out.

One moment.

Members of the jury, we have finished our work for

today. Monday is Memorial Day, and so you're going to be

returning to court according to the instructions that have been

given to you so that you'll be able to walk into the courtroom

at 9:30 sharp. It's very, very important that you follow those

instructions closely and that you get here on time.

Remember that you're not allowed to discuss the case

amongst yourselves. Don't permit anyone to discuss the case in

your presence. It's always tempting, once you start to hear

witness testimony, to want to discuss the case, but that is

absolutely prohibited.

I wish you a wonderful long weekend, and I look

forward to seeing you on Tuesday.

(Jury not present)

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THE COURT: Please be seated.

I'm going to ask that Alternate No. 5 be brought in.

Is there anything that the parties wanted to raise?

MS. SHROFF: No, your Honor.

MS. MURRAY: No, your Honor.

(Juror present)

THE COURT: Hi. You're Alternate No. 5, right?

JUROR: I am. Yes.

THE COURT: I received a note from you and you raised

certain concerns. But now with the understanding of the

transportation arrangements, my sense is that your schedule can

work with the second option that was discussed; is that

correct?

JUROR: Correct. Up until the point of where my child

is finished school June 18th.

THE COURT: And then?

JUROR: The summer plans will now have to be changed

in order for me to continue to be a juror.

THE COURT: And so that you can do that, you can make

those changes?

JUROR: I haven't even begun to figure out what that

would entail.

THE COURT: Well, I ask that you work on that and that

you return on Tuesday. Thank you.

JUROR: Thank you.

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(Juror not present)

THE COURT: All right. If there's nothing further,

then I wish everyone a good holiday weekend.

MS. MURRAY: Thank you, your Honor. You as well.

(Adjourned to May 28, 2024 at 9:30 a.m.)

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INDEX OF EXAMINATION

Examination of: Page

ERIN McNAMARA

53Direct By Mr. Finkel . . . . . . . . . . . . . .

84Cross By Ms. Shroff . . . . . . . . . . . . . .

117Redirect By Mr. Finkel . . . . . . . . . . . .

119Recross By Ms. Shroff . . . . . . . . . . . .

121Redirect By Mr. Finkel . . . . . . . . . . . .

122Recross By Ms. Shroff . . . . . . . . . . . .

LOUIE BONSUKAN

123 Direct By Ms. Murray . . . . . . . . . . . . .

143Cross By Ms. Shroff . . . . . . . . . . . . .

157 Redirect By Ms. Murray . . . . . . . . . . . .

159Recross By Ms. Shroff . . . . . . . . . . . .

167

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GOVERNMENT EXHIBITS

Exhibit No. Received

62 CT-20 through CT-30, CT-35 through 72, . . . .

CT-74 through 105, CT-101

through 129, CT-157 through

187, CT-190 through 202,

CT-204 through 207

STIP-1 62 . . . . . . . . . . . . . . . . . . .

36 66 . . . . . . . . . . . . . . . . . . . . .

133 55 . . . . . . . . . . . . . . . . . . . . .

CT-208 68 . . . . . . . . . . . . . . . . . . .

CT-209 67 . . . . . . . . . . . . . . . . . . .

GC295 130 . . . . . . . . . . . . . . . . . . .

BR460 124 . . . . . . . . . . . . . . . . . . .

GC-504 141 . . . . . . . . . . . . . . . . . .

Original English Content(英文原文)

6
          SOUTHERN DISTRICT REPORTERS, P.C.
            (212) 805-0300
O5O1GUO1                 
UNITED STATES DISTRICT COURT 
SOUTHERN DISTRICT OF NEW YORK 
------------------------------x 
UNITED STATES OF AMERICA,                
 
           v.                           23 Cr. 118 (AT) 
 
MILES GUO, 
 
               Defendant.          Trial     
------------------------------x 
                                        New York, N.Y. 
                                        May 24, 2024 
                                        10:15 a.m. 
 
Before: 
 
HON. ANALISA TORRES, 
                                        District Judge 
                                         -and a Jury- 
 
APPEARANCES 
 
DAMIAN WILLIAMS  
     United States Attorney for the 
     Southern District of New York 
BY:  MICAH F. FERGENSON 
     RYAN B. FINKEL 
     JUSTIN HORTON 
     JULIANA N. MURRAY 
     Assistant United States Attorneys 
 
SABRINA P. SHROFF 
     Attorney for Defendant  
 
PRYOR CASHMAN LLP 
     Attorneys for Defendant  
BY:  SIDHARDHA KAMARAJU 
     MATTHEW BARKAN 
 
ALSTON & BIRD LLP 
     Attorneys for Defendant  
BY:  E. SCOTT SCHIRICK

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ALSO PRESENT:   
Isabel Loftus, Paralegal Specialist, USAO 
Michael Gartland, Paralegal Specialist, USAO 
Geoffrey Mearns, Paralegal Specialist, USAO 
Robert Stout, Special Agent, FBI  
Ruben Montilla, Defense Paralegal 
Tuo Huang, Interpreter (Mandarin) 
Shi Feng, Interpreter (Mandarin)

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(A jury of 12 and six alternates was duly impaneled 
and sworn) 
THE COURT:  Counsel, would you approach, please.
(At the sidebar)  
THE COURT:  Who's opening for the government?
MR. FERGENSON:  I am, your Honor.
THE COURT:  And for the defense.
MS. SHROFF:  I am.
THE COURT:  All right.  You may step back.
MS. SHROFF:  Thank you.
(In open court) 
THE COURT:  Good morning.
THE JURORS:  Good morning.
THE COURT:  Members of the jury, the case is
officially on trial, and you are the jurors in the case.  As
you can see, the jury is composed of 12 members.  In addition,
there are six alternates.  If you are an alternate, you need to
pay as close attention to the evidence as the jury.  If for any
reason any one of the members of the jury is unable to serve,
an alternate will be required to step into the place of that
juror.
I now will give you some preliminary instructions to
guide you in your participation in the trial.
The second part of the trial is about to start.  This
part is the opening statement by the prosecution.  In the

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opening statement by the government, he's required to indicate
to you what the prosecution intends to prove by way of evidence
to support the charges against the defendant.  Once the
government's opening statement has been completed, defense
counsel has the option to make an opening statement.
Now what attorneys say in an opening statement is not
evidence.  An opening statement is, in a sense, a preview of
what the attorney expects that the evidence will show.
Next, the government will present a witness and will
ask the witness questions.  This is called direct examination.
Once the government completes those questions, the defense will
then be given an opportunity to question the witness.  This is
called cross-examination.  This process will continue for each
witness the prosecution will present to give testimony.
When the government finishes calling all of its
witnesses, the defense will be given the opportunity to present
witnesses also.  Remember, the defense need not prove anything.
Therefore, they do not have to cross-examine the government's
witnesses or offer their own witnesses.
Once both sides have finished presenting witnesses,
the defense and the prosecution will be given the opportunity
to make closing remarks to you.  These closing arguments will
not be evidence.  They are just arguments made by the attorneys
to discuss the facts and circumstances in the case, and they
should be confined to the evidence and to reasonable inferences

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to be drawn from the evidence.  So again, neither opening
statements nor closing remarks are evidence, and you should
disregard any statement or argument made by the attorney that
is not based on the evidence.
After closing arguments, I will give you detailed
instructions on the law that relates to this particular case.
When I finish my instructions, you will then retire to
deliberate to reach a verdict.
Now I'm going to instruct you on evidence.  First let
me tell you what evidence is.
Basically, evidence consists of oral testimony under
oath, any stipulations of the parties, and physical exhibits
during the trial that are introduced by either the prosecution
or the defense and allowed into evidence.  If an exhibit is
given to you to examine, you should examine it carefully,
individually, and without comment.
There are two types of evidence——direct and
circumstantial.  Direct evidence is direct proof of a fact such
as testimony of an eyewitness.  Circumstantial evidence is
proof of facts from which you may infer or conclude that other
facts exist.  There's a simple example of circumstantial
evidence that is often used in this courthouse.  Assume that
when you came into the courthouse this morning, the sun was
shining and it was a nice day.  Assume that the courtroom
shades were down and you could not look outside.  As you were

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sitting here, someone walked in with an umbrella that was
dripping wet.  Then a few minutes later, another person also
entered with a wet umbrella.  Now you cannot look outside the
courtroom and you cannot see whether or not it is raining, so
you have no direct evidence of that fact, but on the
combination of facts that I have asked you to assume, it would
be reasonable and logical for you to conclude that it had been
raining.  That is all there is to circumstantial evidence.  You
infer, on the basis of reason and experience and common sense,
from one established fact the existence or nonexistence of some
other fact.
Not all circumstantial evidence presents clear,
compelling inference.  The strength of the inferences arising
from circumstantial evidence is for you to decide.  I will give
you further instructions on these as well as other matters at
the end of the case, but have in mind that you may consider
both kinds of evidence.
If you're instructed that some evidence is received
for a limited purpose only, you must follow that instruction.
Questions asked by either attorney or even myself are
not in and of themselves evidence.  Only questions coupled with
answers are evidence.  Therefore, you may not infer any fact
from the mere asking of a question.  The reason that I point
this out to you is simple.  During the course of questioning,
the prosecution and the defense may exercise their right to

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object to the other's question, to an answer given to a
question, or to introduction of an exhibit on the ground that
the attorney believes it is somehow legally improper or
inadmissible.  At that point I will sustain or overrule the
objection.  If I sustain an objection to a question, you must
disregard the question and any answer, if one has been given.
You must also draw no inference from the question or from any
answer.  Nor are you to speculate as to what the witness would
have said if permitted to answer.
Evidence stricken from the record must likewise be
disregarded.
Conversely, if I overrule the objection, the question
will be allowed and the answer will stand, and it remains as
evidence.  When I overrule an objection to any evidence, you
must not give such evidence any more weight than if the
objection had not been made.
Please bear in mind that my rulings on the law are
simply that, and under no circumstance are such rulings to be
considered by you as indicating that I have any opinion as to
the guilt or innocence of the defendant.  Under our law, the
judge may not and will not entertain any opinion as to the
guilt or innocence of the accused.  Members of the jury, you
and you alone are the sole and exclusive judges of the facts.
Now I want you to understand that objections may come
rather quickly, and at times either party may seem worried.

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Please do not resent this or penalize either party for this.
Understand that they are just doing their job and this is part
of it.
As I stated at the beginning, you are the triers of
fact.  Therefore, it is up to you to decide which witness to
believe and which witness not to believe.  Furthermore, you
will decide how much of every witness's testimony to accept and
how much to reject.
How do you decide what to believe and what not to
believe?  Listen to the witnesses, watch them, and observe
them, then decide whether you believe or disbelieve them in the
same way that you decide such questions in your everyday life.
Did they know what they were talking about?  Were they candid,
honest, open, and truthful?  Do they have a reason to falsify,
exaggerate, or distort their testimony?  Just use your common
sense in evaluating all testimony.  All that is asked of you is
that you apply the same common sense you would apply in your
everyday lives to determine who is telling you the truth, who
is not, and who is telling you something less than the full
truth.
Please remember that it is the quality of the evidence
that controls, not the quantity of the evidence, or the number
of witnesses called by either side.  
You must decide the case solely on the evidence and
law before you, and must not be influenced by any personal

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likes or dislikes, opinions, prejudices, sympathy, or biases,
including unconscious bias.  Unconscious or implicit biases are
stereotypes, attitudes, or preferences that people may
consciously reject but which may be expressed without conscious
awareness, control, or intention.  Like conscious bias,
unconscious bias too can affect how we evaluate information to
make decisions.  All of us, no matter how hard we try, tend to
look at others and tend to weigh what they have to say through
the lens of our own experience and background.  We each have a
tendency to stereotype others and to make assumptions about
them.  Often we see lights and evaluate evidence through a
clouded filter that tends to favor those like ourselves.  You
must do your best to put aside such stereotypes, for all
litigants and witnesses are entitled to a level playing field
in which we do the best that we can to put aside stereotypes
and prejudices.  You are to be guided solely by the evidence in
the case and my instructions on the law.
Although you are the sole judges of the facts, my job
is to be the sole judge of the law.  You must accept the law as
I give it to you, without any hesitation or reservation.  You
must accept the law as I give it even if you privately disagree
with me or the law.
There are three basic principles of law that apply to
this and all criminal cases——the presumption of innocence, the
prosecution's burden, and the standard of proof.

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First, the presumption of innocence.  A defendant is
presumed innocent, and that presumption remains with the
defendant throughout the trial and is not removed unless and
until the defendant's guilt is proven beyond a reasonable
doubt.  The indictment containing the charges against the
defendant is only an accusation, nothing more.  It is not proof
of guilt or anything else.  Therefore, because no evidence has
been presented to you as of yet, if you were to deliberate
right now, you would have to find the defendant not guilty.
Second is the prosecution's burden.  The burden of
proof is on the government.  The defense has no burden and is
not required to do anything to prove his innocence.  The
defense has the option of just sitting back and doing nothing.
Why?  Because the defense has no burden of proof, and the
defendant is presumed innocent.  The defendant is not required
to put on a defense or call any witnesses because of the
presumption of innocence.  If the defendant chooses not to take
the stand, to testify on his behalf, you may not draw any
negative inference from that; in other words, you cannot hold
that against the defendant.
Third is the standard of proof.  The prosecution is
required to prove the defendant's guilt beyond a reasonable
doubt.  This standard does not require the prosecution to prove
the defendant's guilt beyond all doubt or to a mathematical
certainty.  The prosecution does, however, have to prove the

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defendant's guilt beyond a reasonable doubt.  The doubt is not
reasonable if, instead of being based on the nature and quality
of the evidence or the insufficiency of the evidence, it is
based on some guess or whim or speculation unrelated to the
evidence.
In my final instructions to you at the end of the
trial, I will give you detailed instructions on the law as to
the specific charges against the defendant.  Those instructions
are intended to guide you through your deliberations and to
enable you to reach your decision.
Finally, I'm now going to instruct you on how you must
conduct yourselves during the trial.
You must keep an open mind during the trial.
You must keep your eyes open during the trial.
You may not ask the witnesses questions.
Do not converse, either amongst yourselves or with
anyone else, about anything related to the case.  You may tell
the people with whom you live and your employer that you are a
juror and give them information about when you'll be required
to be in court, but you may not talk with them or anyone else
about anything related to the case.  Do not at any time during
the trial request, accept, agree to accept, or discuss with any
person the receipt or acceptance of any payment or benefit in
return for supplying information about the trial.  You must
promptly report directly to me any incident within your

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knowledge involving an attempt by any person to improperly
influence you or any other member of the jury.
Do not visit or view the premises or place where the
charged crimes were allegedly committed or any other premises
or place involved in the case.  And you may not use internet
maps or Google Earth or any other program or device to search
for and view any location stated in the testimony.
Do not read, view, or listen to any accounts or
discussions of the case reported by newspapers, television,
radio, the internet, social media, or any other form of news
media.  Do not attempt to research any fact, issue, or law
related to this case, whether by discussion with others, by
research in a library, or on the internet, or by any other
means or source.
In this age of instant electronic communication and
research, I want to emphasize that in addition to not
conversing face to face with anyone about the case, you must
not communicate with anyone about the case by any other means,
including by telephone, text messages, email, internet chat or
chat rooms, blogs, or social websites, such as Facebook and X.
You must not provide any information about the case to anyone
by any means whatsoever, and that includes the posting of
information about the case or what you are doing in the case,
on any device or internet site, including blogs, chat rooms,
social websites, or any other means.

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You must also not Google or otherwise search for any
information about the case or the law that applies to the case
or the people involved in the case, including the defendant,
the witnesses, the lawyers, and myself.
Now, ladies and gentlemen, I want you to understand
why these rules are so important.  Our law does not permit
jurors to converse with anyone else about the case or for
anyone to talk to them about the case because only jurors are
authorized to render a verdict, only you have been found to be
fair, and only you have promised to be fair.  No one else has
been so qualified.
Our law also does not permit jurors to converse among
themselves about the case until the judge tells them to begin
deliberations, because premature discussion can lead to a
premature final decision.
Our law also does not permit you to visit a place
discussed in the testimony.  First, you cannot always be sure
that the place is in the same condition as it was on the day in
question; second, even if it were in the same condition, once
you go to a place discussed in the testimony to evaluate the
evidence in light of what you see, you become a witness, not a
juror.  As a witness, you may now have an erroneous view of the
scene that may not be subject to correction by either party.
That is not fair.
Finally, our law requires that you not read or listen

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to any news accounts of the case and that you not attempt to
research any fact, issue, or law related to the case.  Your
decision must be based solely on the testimony and other
evidence presented in the courtroom.  It would not be fair to
the parties for you to base your decision on some reporter's
view or opinion or upon information you acquire outside of the
courtroom.
These rules are designed to help guarantee a fair
trial, and our law accordingly sets forth serious consequences
if the rules are not followed.  I trust you understand and
appreciate the importance of following the rules, and in accord
with your oath and promise, I know you will do so.
During the trial, it may be necessary for me to confer
with the lawyers out of your hearing with regard to questions
of law or procedure.  On some occasions you may be excused from
the courtroom for that reason.  I will try to limit these
interruptions as much as possible, but you should remember the
importance of the matter you are here to determine, and should
be patient even though the case may seem to go slowly.
Finally, I permit jurors to take notes, but you do not
have to take notes.  Notes are just an aid in your own
recollection.  The court reporters in this case record
everything that is said in the courtroom, and any portion of
the testimony can be read back to you here in open court during
your deliberations.

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O5O1GUO1                 Opening - Mr. Fergenson
If you do take notes, be aware that note-taking might
distract you from something important that is happening on the
witness stand.  Whether or not you take notes, rely on your own
recollection, and don't be influenced by the fact that another
juror has taken notes.
I just told you that you are to report any attempt by
anyone to improperly influence you.  Lawyers are not permitted
to have any contact with you other than what takes place on the
record in this courtroom.  If you see an attorney, for an
example, in the hallway or outside and the attorney does not
say hello or acknowledge your presence, please don't think that
the attorney is being rude.  The attorneys simply are not
permitted to have that type of contact with you.
Now Assistant United States Attorney Micah Fergenson
will make his opening statement.
MR. FERGENSON:  This case is about how the defendant,
Miles Guo, conned thousands of investors out of $1 billion, and
it's about how he spent millions of dollars of victim money on
himself.
In online videos, the defendant pitched investments in
a series of companies.  In these videos, the defendant said
many false and misleading things.  But at its core, the
defendant's fraud was simple.  He promised his victims they'd
get rich, that their investments were safe, and they would not
lose any money.  He told them that, as an ultra-rich

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billionaire, he would personally guarantee and pay back any
losses.  He assured them he would never, ever let their
investments be stolen.  These were lies.  The truth is that the
defendant took investor money and spent it on
himself——million-dollar cars, yachts, a mansion.  Miles Guo ran
a simple con, on a grand scale.  He lived a billionaire's
lifestyle using money he stole from people he tricked and
cheated.
Now the defendant couldn't run a con this size alone.
You'll learn that the defendant and his partners in crime built
a criminal enterprise of different companies to carry out this
fraud.  Some of the companies had offices right here in New
York City.  The employees called the defendant the boss, and
the principal.  And the defendant and his inner circle used
these businesses to steal money from their victims and to spend
it on themselves.  And that's why we're here today, because
when the defendant conned people out of their money, he
committed several crimes involving fraud.  When he and his
partners moved around investor money to hide that they were
spending it on themselves, they committed money laundering
crimes.  And because the defendant committed these crimes,
using a criminal enterprise, a group of people and companies he
controlled, he committed a racketeering offense, a RICO
conspiracy.
Ladies and gentlemen, in this opening statement, I'm

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going to tell you what the evidence at this trial will show and
how the government is going to prove it——prove beyond a
reasonable doubt that the defendant is guilty.
So first, what will the evidence show?  For years the
defendant deceived thousands of people and stole their money to
pay for a lifestyle he could no longer afford.  You see, the
defendant used to be a wealthy real estate developer in China.
But he left China and came to the United States.  Eventually
the defendant spoke out against China's government, the Chinese
Communist Party, or the CCP for short.  He began giving
interviews and broadcasting his own videos.
And he didn't talk just about the CCP.  The defendant
also talked about how rich he was.  He showed off his
$70 million apartment on Central Park, or his $30 million
yacht.
And the defendant's mix of showing off wealth and
criticizing the CCP was popular.  He became an internet
celebrity in the Chinese community.  He had thousands of
followers.  And you're going to learn that the CCP didn't like
this, that the CCP tried to silence the defendant, even tried
to have him brought back to China.  And you'll learn that the
governments of China and Hong Kong seized the defendant's
assets shortly before the schemes began.  So the defendant
needed money.
Now you're going to learn that the defendant pitched

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O5O1GUO1                 Opening - Mr. Fergenson
many different investment schemes to his victims, but each one
was just a new spin on the same simple fraud.  The defendant
told his followers that their money would be used for an
investment, and they could not lose any money.  And instead,
the defendant stole the victims' money and spent it on himself.
He did that through four main schemes——GTV; the farm loans;
G/CLUBS; and the Himalaya Exchange.  I'm going to talk about
each of those schemes in turn.
So the first business that the defendant raised money
for was GTV.  What was GTV?  It was an online media company
with a website and an app that had the defendant's videos, his
broadcasts on it.  What did the defendant tell his followers
about GTV?  He told them it was their special opportunity to
get rich without any risk.  In 2020, the defendant announced,
in his online broadcast, that he would let his followers buy
GTV stock.  The defendant told his followers that investing in
GTV had no risk.  He told them he would personally pay back any
losses.  He told them that investing in GTV could only make
them money.  These were lies.  And the defendant even lied
about the most basic part of the GTV investment——that the money
raised from GTV investors would be used for GTV, to grow the
business of GTV.  Even that basic promise was a lie.
But the defendant's followers trusted him, and money
poured in.  In months, victims invested over $400 million in
GTV.

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O5O1GUO1                 Opening - Mr. Fergenson
What did the defendant actually do with that money?
Almost immediately, just days after the fundraising for GTV
closed, the defendant took $100 million of GTV investor money
and used it for a high-risk investment on behalf of his son.
He essentially made a bet using $100 million of GTV investor
money, sent it to a hedge fund for an extremely risky
investment.  This bet wasn't even made on behalf of GTV; it was
made in the name of a company owned by the defendant's son.
And guess what?  The hedge fund bet didn't pay out.  This hedge
fund bet lost $30 million.  The defendant told GTV investors
that he would personally guarantee their money and pay back any
losses.  Did he pay back the $30 million loss?  No.  That was
just a lie.
What was GTV?  It was one way that Miles Guo lied to
take other people's money.  But it wasn't the only way.
There's GTV and then the farm loan scheme.
Now farms, these farms didn't have anything to do with
farming or agriculture.  The defendant used the word "farms" to
refer to online groups of his followers in different cities or
countries.  And the farm loan scheme was just a way to continue
the GTV scheme.  You see, almost right away, US regulators
began investigating what GTV was doing.  Funds were frozen, and
GTV's bank accounts were shut down.  But the defendant, he
didn't stop.  Instead, in his broadcasts, the defendant blamed
these problems on the Chinese government.  He claimed that

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victims who were complaining about their money being stolen
were traitors and CCP spies.
And the defendant told his followers they could still
buy GTV stock; they just couldn't call it stock.  Instead,
investors could use "loans" that would be organized through the
farms.  You see, each farm opened bank accounts that were used
to collect and pool money from farm members, the investors.
The defendant told his followers that to get GTV stock, they
could enter a "loan agreement" with a farm and send their money
to that farm.  He said the farm would then enter a loan
agreement with GTV, and after a few years, the defendant's
followers, the farm members, could choose whether to get GTV
stock or cash.  But that was another lie.  The defendant and
his money launderer stole the farm loan money for themselves,
and the victims got nothing.
GTV, then the farm loan scheme.  What were the farm
loans?  They were another way that Miles Guo lied to take other
people's money.
The next scam was G/CLUBS.  Now G/CLUBS was supposedly
a high-end lifestyle membership club, but really, it was
another way for the defendant to sell stock without calling it
stock.  The defendant told his followers that by paying
G/CLUBS' initial membership fee, they would get stock in GTV or
G Fashion, the defendant's clothing company.  How much was the
initial membership fee?  The initial fee started at $10,000 and

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went up to $50,000 on the high end.  Thousands of the
defendant's followers paid this fee, sending G/CLUBS hundreds
of millions of dollars and expecting to receive stock in
return.  But G/CLUBS members did not get stock.  That was
another lie.
Did members get anything for their membership costing
tens of thousands of dollars?  The main thing they got was a
discount at G Fashion, which sold expensive clothing to the
defendant's followers, like an $800 pair of sweatpants.  You
could get 10 percent off that price if you paid $10,000 for a
G/CLUBS membership.  And while G/CLUBS members did not get
stock or any benefit worth tens of thousands of dollars, the
defendant spent the G/CLUBS membership money on himself and his
family.
GTV, farm loans, G/CLUBS.  What was G/CLUBS?  It was
another way that Miles Guo lied to take other people's money.
Now the defendant didn't just pitch stock to his
followers; he also pitched a pair of cryptocurrencies sold on
the Himalaya Exchange.  At first he called them G Coin and G
Dollar, then they became H Coin and H Dollar——H Coin for
Himalaya Coin, H Dollar for Himalaya Dollar.  These
cryptocurrencies were another scam.  In his broadcast, the
defendant told his typical lies about this cryptocurrency,
guaranteeing investors would not lose money.  He told his
followers that H Coin was backed 20 percent by gold.  Ladies

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O5O1GUO1                 Opening - Mr. Fergenson
and gentlemen, H Coin was not backed by gold.
The defendant tricked his followers into buying H Coin
and H Dollar because he wanted more money.  You see, the only
place you could buy H Coin or H Dollar was a supposed
cryptocurrency exchange called the Himalaya Exchange.  But the
Himalaya Exchange was run by the defendant's money launderer;
same one who helped him steal the farm loan money.  You're
going to learn that when the defendant was in a bind and needed
money, the defendant's money launderer sent $37 million of
Himalaya Exchange money—-real dollars, not H dollars——to get
the defendant out of the bind he was in.  $37 million of money
that victims sent to the Himalaya Exchange used for his
benefit.
GTV, farm loans, G/CLUBS, the Himalaya Exchange.
What was the Himalaya Exchange?  It was one more way
that Miles Guo lied to take other people's money.
These four schemes were really just different versions
of the same con, where the defendant tricked people out of
their money so he could spend it on himself and his family.
And he did it for greed.  He used investor money to pay for a
luxury yacht, for private jets, to buy luxury cars, a
Lamborghini that cost nearly a million dollars, a Bugatti that
cost $4 million, a $4 million Ferrari for his son, a second
luxury yacht, a 50,000-square-foot mansion that he paid
millions more to renovate for himself and his family, and to

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O5O1GUO1                 Opening - Mr. Fergenson
buy things like a $35,000 mattress, and a $60,000 TV.  And the
victims, the investors whose funds were stolen by the defendant
to fund these spending sprees?  They got nothing.  They just
lost money——money they had saved, money they had borrowed,
their family money, money they thought was safe.  And he just
stole it.
MS. SHROFF:  Your Honor, objection.
THE COURT:  Overruled.
MS. SHROFF:  This is opening statement.
THE COURT:  Overruled.
MR. FERGENSON:  That's what the evidence is going to
show.
Now how is the government going to prove it, prove to
you that the defendant is guilty?  You're going to see and hear
several different types of evidence.  You will hear the
defendant's own words.  You will see the defendant lie on video
over and over.  You'll see him lie and say that his victims
can't lose money, that he would pay back any losses, that he
would never spend investor money on himself.  And you'll hear
him lie about what he did with investor money, saying that he
has not touched even a penny of it, and admitting that if he
did, it would be a crime.
You'll also hear what the defendant and his
co-conspirators said on phone calls when they didn't know they
were being recorded by a concerned employee.  You will hear the

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          SOUTHERN DISTRICT REPORTERS, P.C.
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O5O1GUO1                 Opening - Mr. Fergenson
defendant order his co-conspirators to transfer $100 million of
investor money that he later used to buy his mansion.  And
you're going to see records related to each of the four main
frauds, about how the investor money was supposed to be used,
and then you'll see records showing how it was actually used,
bank records showing how the defendant and his co-conspirators
used dozens of shell companies and hundreds of bank accounts to
conceal the fact they were spending investor money on
themselves.
You'll see the GTV investment document that says GTV
investor money would be used to grow GTV's business, and then
you'll see the records showing $100 million of GTV investor
money going instead to a hedge fund bet for the defendant's
son.
You'll see the farm loan contracts given to victims,
pieces of paper that were ultimately worth nothing to them.
You'll see the bank records showing that farm loan money was
just stolen.
And you'll see photographs of the things the defendant
bought with G/CLUBS membership money, all while promising in
his recorded broadcast that G/CLUBS memberships were a way to
invest in GTV or G Fashion.  You'll see photographs of the
G/CLUBS Lamborghini that was parked in the defendant's garage,
at his Connecticut home; photographs of the defendant's mansion
in New Jersey, paid for with G/CLUBS money.  You'll see

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          SOUTHERN DISTRICT REPORTERS, P.C.
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O5O1GUO1                 Opening - Mr. Fergenson
photographs of the defendant's custom Italian suits hanging in
his bedroom closet at that mansion.
You'll see the bank records showing the $37 million
transfer of Himalaya Exchange money for the defendant's
personal benefit, all while the defendant told investors in
recorded broadcasts that he had no ownership in the Himalaya
Exchange and that H Coin and H Dollar money was secure.
Now you'll also hear the testimony of witnesses.  You
will hear from people who used to work for and used to trust
the defendant.  You'll hear from former employees of the
defendant's G businesses.  They will tell you that the
defendant and his co-conspirators ran and controlled those
businesses, and made the decisions about how money was spent
and where it was transferred.
Now some of these former employees are testifying
pursuant to what's called non-prosecution agreements, in which
the government has agreed not to prosecute them in exchange for
their testifying at this trial.  So you should listen carefully
to the testimony of these witnesses.  When you do, you'll see
it's consistent with all the other evidence in the case.
Ladies and gentlemen, you will also hear from victims
of the defendant's fraud, people who were drawn into Miles
Guo's online world, people who trusted Miles Guo, who believed
the lies he told them, and who lost money, sometimes their life
savings, as a result, people who eventually realized they were

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          SOUTHERN DISTRICT REPORTERS, P.C.
            (212) 805-0300
O5O1GUO1                 Opening - Ms. Shroff
being scammed.
Now the evidence, it's not going to come in all at
once.  You'll see it witness by witness, document by document,
one piece at a time.  But at the end of this trial, after
you've heard the testimony and you've seen the evidence, you
will see the full picture.  This man conned thousands of
investors and stole $1 billion.
At the end of the trial, we'll have a chance to speak
with you again.  Between now and then, I'm going to ask you
just to do three things——first, pay close attention to the
evidence; second, follow Judge Torres's instructions on the
law; and third, use your common sense——the same common sense
and good judgment that you use every day in your lives as New
Yorkers.  If you do those three things, you will reach the only
verdict that is consistent with the evidence and the law——the
defendant is guilty.
THE COURT:  Now we will have the opening statement on
behalf of the defendant, Mr. Guo, by Ms. Sabrina Shroff.
MS. SHROFF:  Thank you, your Honor.
Good morning, ladies and gentlemen of the jury.  It
was not a bet.  It was not a scheme.  It was not a con.  It was
none of those things.  And the reason we are here today is not
because the government brought an indictment; the reason we are
here today is because Mr. Guo has pleaded not guilty to the
indictment, and the evidence in this case will show——all of the

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O5O1GUO1                 Opening - Ms. Shroff
evidence——the witnesses that they bring in, as government
counsel noted, one by one, the documents that come in one by
one, will lead you to only one conclusion, and the conclusion
is that Mr. Guo is not guilty of the 12 counts brought in this
indictment.
I am here to tell you why there is no conspiracy, RICO
or otherwise, and there is no enterprise.  Mr. Guo is not
guilty of the charges in this indictment.
Before I do that, and before I speak more to what the
evidence will show in this case, please allow me to introduce
myself.  My name is Sabrina Shroff.  And I, along with my
colleagues, represent Miles Guo.
Miles Guo is one of eight children who started life
with very little, born and raised in China, and that is in fact
where he and his brothers and his family made a fortune in real
estate.  The evidence in this case will show that the fortune
was humungous.  And yes, the government would like you to draw
many, many negative inferences from a person who, according to
them, spent thousands of dollars on a TV or on a mattress.  I
ask you please, when you consider the evidence, consider the
evidence within the context and not to be drawn in by the
government's invitation to make judgment calls about people who
have money and spend it in a way that you and I simply
wouldn't.
So let's talk about what the evidence in this case

33
          SOUTHERN DISTRICT REPORTERS, P.C.
            (212) 805-0300
O5O1GUO1                 Opening - Ms. Shroff
will show.  The evidence in this case will show how Miles Guo,
filled with a determination to accomplish a goal, he had a
goal, and how he worked on that goal over a period of years,
and the goal was to establish, to set up, to form, and to move
forward a movement——a movement that would allow the people of
China, the Chinese people, to know that there was an
alternative, an alternative to the Chinese Communist Party, and
how the Chinese Communist Party could be removed so that
everybody could live in a way that they chose to live.
Mr. Guo, the evidence will show, did not have criminal
intent, and when the evidence in this case is complete, you
will see that what the government is trying to string together
is not just a group of people to try and prove to you an
existence of a conspiracy that really doesn't exist, but also
asking you to make value judgments about how money is made and
how money is spent.
So let me start where the government had started.  Let
me talk about what the government spent the majority of the
time today, and what the government will spend a majority of
the time throughout this case on, the one person they ask you
to convict——Miles Guo.
He was raised in China, one of eight boys, and each
one of them grew up from nothing and made a fortune in real
estate.  The real estate fortune of the eight brothers in China
was not just worth millions, it was worth hundreds and hundreds

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          SOUTHERN DISTRICT REPORTERS, P.C.
            (212) 805-0300
O5O1GUO1                 Opening - Ms. Shroff
of millions of dollars.  And you will hear that despite this
incredible success, financial fortune that he had in China,
Mr. Guo left China and came eventually and settled down in New
York.  And you will ask yourself and the evidence will show why
Mr. Guo left China.  He left China because he'd taken on the
CCP, the Chinese Communist Party, and they were not pleased
with him at all.  The Chinese Communist Party also had a goal,
and they were very determined to make sure their goal was met.
Their goal was to make sure Miles Guo stopped speaking about
the CCP.
Now you've heard from government counsel earlier
today, and he has certainly invited you to make moral
judgments, value judgments, all sorts of judgments, but what he
has asked you to do at his core, he's asked you to receive from
him almost a fiat that Mr. Guo lied.  He wants you to accept
that Mr. Guo lied so that people would give him money and then
wants you to accept that the only thing he did with that money
is spent it on himself and his family.  That is not this case,
and that is not true.
You are going to hear that, like almost every one of
us, there's more than one aspect to Miles Guo, and some of the
aspects and some of the things you will hear during the
testimony in this case will be both surprising and eye opening.
So when you evaluate the evidence that comes in through the
witnesses, when you think about Miles Guo's story, when you

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          SOUTHERN DISTRICT REPORTERS, P.C.
            (212) 805-0300
O5O1GUO1                 Opening - Ms. Shroff
think about who Miles Guo is, I ask you, keep in mind and
conceptualize the world that he lived in because it is not our
world.  Our world is not filled with surveillance, constant
harassment, and constant oversight and disruption by the
Chinese Communist Party.
You will hear testimony in this case from government
witnesses that Mr. Guo was forced to leave China.  He was
forced to leave behind his wife and his daughter.  Both were
arrested and detained in prisons in China for almost two years.
You will learn and you will have evidence that shows
you that once Mr. Guo got to New York, instead of focusing on
all the negatives that were before him and all the hurdles he
had to face, what he did is, he started to and continued over
time to speak out against the Chinese Communist party, and that
is what he did all the time, all day long.  That was his goal,
to get that story out.  And repeatedly he said——and you will
hear it through the trial——that the people of China are not the
Communist party.  That is what he wanted to tell the people
that were here in the United States and the good-thinking
people that he had to leave behind in China.
What is it that he set out to do?  He set out to start
a movement and tell the truth about the CCP.  And with that, he
started to speak, he started to write, and he started to
broadcast, and soon that came to be known amongst those who
believed him and amongst those who followed him to be the

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          SOUTHERN DISTRICT REPORTERS, P.C.
            (212) 805-0300
O5O1GUO1                 Opening - Ms. Shroff
Whistleblower Movement.
And what did he talk about?  He talked about things
that he knew.  He knew of the corruption in the CCP, and that's
what he talked about.  He knew certain secrets of corrupt
government officials, and that's what he talked about,
specifically.  What else did he know?  He knew the many ways in
which the CCP worked, and he knew of the many, many ways that
the CCP could make one's life hell, and one's professional life
and one's business life and one's personal life.
Now once Mr. Guo started talking about the CCP, the
reaction to it was immediate and strong, and the reaction
wasn't just from the people who were enthralled by what he had
to say.  There was another reaction too.  There was a reaction
by the CCP, the Chinese Communist Party, and they too had a
goal.  Their goal was to make sure that he stopped.
So you see that most vividly when Mr. Guo, and the
evidence will show, had a broadcast on April of 2017,
April 19th of 2017, when he starts and gives a live interview
on Voice of America.  In face of relentless bullying by the CCP
to stop, to be quiet, Mr. Guo decided to have a live-feed
interview on April 19th.  The interview was, and his goal was,
to broadcast in an uncensored, live manner so that nobody could
doctor what he had to say.  And what happened to this live
interview?  While he's still speaking, in mid-speech, the feed
is cut off, the line is cut off, and the interview is stopped.

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          SOUTHERN DISTRICT REPORTERS, P.C.
            (212) 805-0300
O5O1GUO1                 Opening - Ms. Shroff
There is no warning.  There is no notice.  All of a sudden, all
of the work he had put in to make sure this interview goes
through, it's cut off.  And what happens after that?  What
happens after that also gives you a context about the world in
which Mr. Guo has to live and do business.
Immediately after the April 19th interview, the
Chinese Communist Party issues what is called a red notice.
That is——a red notice is a warrant through the Interpol,
seeking Mr. Guo's immediate arrest and extradition back to
China.
After that interview with Voice of America, his wife
and his daughter are arrested in China by the Chinese police.
He loses all access to social media.  His YouTube account is
cut off.  His Twitter is cut off.  And he has no access
whatsoever to any methodology by which he can get his word out.
What else do they cut off access to?  They cut off
access to any method by which he could get himself or his
businesses any help.  The CCP hacked his phones.  Every
cellphone he has, they hacked.  They hacked his computers——his
home computers and his work computers.  They even hacked the
home and work computers of other people who are either
assisting him or doing business with him.  And this pattern of
harassment by the CCP——and the evidence will show all of this
pattern——escalates and becomes more and more sophisticated.
So let me give you an example of how sophisticated

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          SOUTHERN DISTRICT REPORTERS, P.C.
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O5O1GUO1                 Opening - Ms. Shroff
this harassment can get.
At one point the CCP is so determined to shut down any
and every bank account that the CCP starts to send money into
these accounts in the names of people who are on the OFAC list.
The OFAC list is a list set by the United States government
that lists the names of people who have engaged in criminal
conduct and are not allowed to use our banking system.  The CCP
uses those names to send in money, triggers a reaction from the
compliance people in the bank, the bank shuts down all of his
accounts, because the monies being wired, they think, are in
the name of known criminals on the OFAC list.
You will hear all of this evidence from the government
witnesses, and you will know that the CCP has a thousand
different ways to mess with Miles Guo and to try and stop the
political movement that was really the essence of his entire
being.
The evidence will show why Mr. Guo continued,
continued in this movement, and why he endeavored to overcome
each and every one of these hurdles.  He was determined to make
sure the movement survived, and he wanted to make sure others
who wanted to join the movement were able to do so.
So what did Mr. Guo do?  He set up the Rule of Law
Foundation and he set up the Rule of Law Society.  He dedicated
both those entities to make sure that they provided people with
support to fight the propaganda given by the CCP.  To give

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            (212) 805-0300
O5O1GUO1                 Opening - Ms. Shroff
voice to the movement, he created a social media company.  The
government lawyer has spoken endlessly about it.  GTV.  What
was GTV?  GTV was a real company set up to spread the message
of the Whistleblower Movement.  The point of GTV was to get an
uncensored voice out, not to just the people of Chinese beliefs
and systems who lived in the United States, but also the many,
many people who were left behind in China, who also wanted to
be part of that movement.  And that is what GTV offered them.
Yes, GTV was the first of multiple business opportunities that
aimed to spread the voice of the Whistleblower Movement.
Mr. Guo participated in GTV, the farm loan program, G/CLUBS,
and the Himalaya Exchange, and its currencies, H Coin and H
Dollar.  These businesses were at the heart of the movement,
and the government is simply wrong when it argues that they
were not real businesses.  The evidence in this trial will show
that GTV was, unlike many, many others, a citizen-based
journalism website.  It allowed for people to speak openly and
talk to each other without repercussions from the CCP.
The farm loan program.  The farm loan program, the
evidence will show, not what this prosecutor has just told you,
but it will show that the farm loan program was a way for
people to give their money at an interest rate to support the
movement——the movement that they were interested in.  And it
was a way for people to earn money from these loans.  I remind
you, keep an eye on the time frame when all of this happened.

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          SOUTHERN DISTRICT REPORTERS, P.C.
            (212) 805-0300
O5O1GUO1                 Opening - Ms. Shroff
United States and most of the world is in the midst of a
pandemic, and people are eager to interact with each other
online.
What was G/CLUBS?  G/CLUBS was what the government
lawyer here mocks whether or not one should spend X amount of
dollars on a sweatshirt or sweatpants——I think he said
sweatpants.  That is a person's choice, and that is exactly
what China didn't want people to have and what the movement did
want people to have——choice.  You want to spend your money that
way, that is entirely up to you.  And what did G/CLUBS
membership allow?  It allowed a person, if they wanted, to
support the movement, at whatever price they wanted to support
it.  If you wanted to support it at the $10,000 level, you
could, and if you wanted to support it at the $50,000 level,
you could.  The evidence will show——and I ask you, when the
evidence comes in, do not take that invitation to make a moral
or value judgment on what and how people should spend their
money.  The question is, does the evidence show the existence
of real companies, the existence of real employees, the
existence of people who did actual, real good work, the
existence of people who dealt with the same problems you and I
deal with at our jobs, trying to do the best job we can because
we're chosen by people and bosses, because we have talent,
expertise, and hard work, and those are the people that worked
in each one of these companies.

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          SOUTHERN DISTRICT REPORTERS, P.C.
            (212) 805-0300
O5O1GUO1                 Opening - Ms. Shroff
There is no denying at all that all of these entities
were built around Mr. Guo's celebrity.  Yes.  And he was the
one who started speaking as early as 2017 and continued
speaking against the CCP.
You know what else the evidence will show?  That not
just other people were the ones who invested.  Mr. Guo's
friends invested, Mr. Guo's family members invested.  Why?
Because they too——they too believed in the movement.  So they
invested.  They invested in GTV, they invested in the farm,
they invested in G/CLUBS, and they invested on the Himalaya
Exchange.  They believed.  The evidence will show that these
companies were built, were put together, just like any other
business; maybe not with the same level of infrastructure, but
people believed.  And Mr. Guo, like many, many of us, had a
vision, had an idea.  What he did not quite have is the
infrastructure that you and I bring to our daily lives.  When
he first started, he spoke very little or no English.  He was
new to this country.  He wasn't familiar with the way things
are done.  And yes, you will hear recordings in which he speaks
in a demanding voice, one instant, for work to get completed,
and at some times even appears to be extremely pigheaded in a
way that many a person is.  Does that mean he's a criminal?
No.  Does that mean he committed these crimes?  The evidence
will show it does not.  What the evidence, again, will show is
that the people who he hired were people who were able to

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          SOUTHERN DISTRICT REPORTERS, P.C.
            (212) 805-0300
O5O1GUO1                 Opening - Ms. Shroff
contribute to each one of these businesses.
Now the government, I suppose, will spend some amount
of time introducing evidence about two individuals, Yvette Wang
and William Je, and I ask you, as you hear the evidence the
government puts in, to pay some and close attention to what
roles each one of these people played.  The testimony will show
that Ms. Wang was the head of operations.  She ran the
day-to-day of each business.  She was in charge of hiring.  She
did the best to hire people, and her hiring practices were the
same as yours or mine.  She hired people that she met along the
way in her business, she hired people through a headhunter when
she needed a person or a spot filled.  And she was no more or
no less committed and no more or no less demanding than any
other chief executive officer that works.
William Je is another name that the evidence will
show, and William Je was the finance guy.  He's a well-regarded
investment banker who had managed the fortune not just of the
Guo family fund but he had managed the fortunes of many another
companies.  He had expertise, he had skill, and that is why he
was the finance guy.
And I've already talked at length about Mr. Guo, who
was the ideas man.  He came up with the ideas and he put
together the thought and the vision of what the movement that
he believed in would look like.
So you see, he wasn't alone in the movement.  He

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          SOUTHERN DISTRICT REPORTERS, P.C.
            (212) 805-0300
O5O1GUO1                 Opening - Ms. Shroff
wasn't moving all on his own.  In fact, that's why it was
called the Whistleblower Movement.  The point of it was to have
others join and participate.
So what will the evidence show at the end of the day?
The evidence will show that each one of these companies hired
and had people working towards the existence of a real
business.  They believed and Mr. Guo believed.  Mr. Guo
believed in this movement.  So when the government lawyer asks
you and tells you to believe that Mr. Guo defrauded the members
of this movement, what the government is saying to you is that
he intentionally misled supporters to steal money, the same
money that they had given to the movement, the movement that he
had devoted almost his entire life to, the movement for which
he fled China, the movement for which he put up with being
followed every day, the movement for which his phones were
hacked, the movement for which his wife and his daughter sat in
prison for two years, and the movement for which he was not
allowed to leave and travel outside the United States, the
movement for which he risked his very existence.  That's what
they're saying he set out to harm.  They're saying that he set
out to harm the very thing that was almost an extension, a
symbiotic extension of who he was.  And he did all of that even
though he had a fortune from a family fund that allowed him to
live in luxury.  What the government is asking you to believe
is not just illogical; it defies common sense.

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          SOUTHERN DISTRICT REPORTERS, P.C.
            (212) 805-0300
O5O1GUO1                 Opening - Ms. Shroff
I ask you to consider this.  All of the evidence that
the government lawyer talked about——the wealth, the millions of
dollars' worth of luxury hotel in Manhattan where he lived, the
yacht, the mattress, whatever it is that he talked about——you
know what the evidence is going to show?  The evidence is going
to show that no matter what else these witnesses say to you,
Mr. Guo had that lifestyle long before the government even
alleges that he committed this fraud.
The suits, sweatpants, the house, the evidence will
clearly show, that has been his lifestyle for decades, well
before the government says he lost money and well, well before
any of this was even a thought in the government's mind.  And
it certainly continues today and continued for days after
because the family fund will always support Mr. Guo.
And I ask you to consider this, because the government
does invite you to make this value judgment.  It is easy for a
person to judge another as either shallow or rich, but shallow
or rich does not make for a criminal.  That does not mean that
the government's inference is a proper one.
The evidence will clearly show that Mr. Guo did not
need to steal money to buy the Brioni suits.  None of that
would be worth all of the hardship he went through to keep the
CCP at bay.  What the evidence will show here is that Mr. Guo
did not steal money from GTV, he did not steal money from the
farm loans program, he did not steal money from G/CLUBS, and he

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          SOUTHERN DISTRICT REPORTERS, P.C.
            (212) 805-0300
O5O1GUO1                 Opening - Ms. Shroff
did not steal money from the Himalaya Exchange.
The government will also invite you to think, and
invite you to conclude, that the reason Mr. Guo did certain
things are because he was engaged in criminal activity.
(Continued on next page)

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          SOUTHERN DISTRICT REPORTERS, P.C.
            (212) 805-0300
O5OVGUO2                 Opening - Ms. Shroff
MS. SHROFF:  So what else is the government going to
elicit in terms of evidence?  The government is going to seek
to elicit that Mr. Guo had constant telephones that he changed;
he had almost hundreds and hundreds of telephones.  And that he
had these telephones, and he changed his number constantly
because he didn't want people to know what he was doing.
I ask you to consider this:  If you have been the 
target of constant hacking by the CCP, and if you have been the 
target of people listening in on your phones, using your voice 
recordings to impersonate you, wouldn't you also change your 
phones that often?   
If you were in constant fear of being threatened, 
kidnapped, killed, moved, would you also not have a car that 
does not tell people where and when you're going to be taken?  
It's logical that that is what a person who is being surveilled 
would live in that manner.  If you were Mr. Guo and you were 
being constantly targeted, wouldn't you want a safe and secure 
place to have business meetings?  Wouldn't you establish a base 
where people you wanted to do business with could come and meet 
with you without the interference and the distortion from the 
CCP?   
For every piece of evidence of wealth that they put 
in, you will have an equally fair inference that he took those 
steps not to cheat, not to indulge, but to make sure that the 
movement survived despite the distortions of the CCP.

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          SOUTHERN DISTRICT REPORTERS, P.C.
            (212) 805-0300
O5OVGUO2                 Opening - Ms. Shroff
I ask you to keep in mind when they talk to you about
bank accounts, Mahwah, homes, ask yourself, why would a person
have to open a bank account, unless, of course, each time a
bank account was owned, somebody from the OFAC list deposited
money into your account and had compliance to them.  That's the
reason why Mr. Guo's actions must be evaluated in the context
and the lifestyle in which he was supposed to exist.
So the government will introduce the evidence.  And I
ask you to keep in mind that for each piece of evidence that
comes into them, the necessary inference from them is not the
accurate one.  They ask you to infer from the filing of a
bankruptcy that Mr. Guo simply did not have money.
Now, whether we think it's fair or whether we think it 
unfair, the rich often declare bankruptcy.  Personal bankruptcy 
does not mean poverty.  None of that inference is correct.  And 
I ask you, when you hear evidence of that, to consider how it 
is that Mr. Guo, who did not have any personal assets at that 
time, because the CCP was the one that had seized his property.   
There was a time — and you will hear evidence coming 
in — that Mr. Guo was to pay a fine of almost $100 million 
within a few days.  And that is what leads to a filing of 
bankruptcy.  But the government's request that from that you 
draw the conclusion of guilt, again, is a misplaced request.   
The government will argue throughout this case that 
what Mr. Guo did was simply unlawful.  They will ask you to say

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          SOUTHERN DISTRICT REPORTERS, P.C.
            (212) 805-0300
O5OVGUO2                  
you can be persecuted and you can still be a fraud.  And when 
they ask you that, I ask you to think about how the evidence 
shows them to be wrong.  The government isn't just saying that 
there is a fraud.  What the government is asking you to do is 
to conclude that Mr. Guo defrauded essentially himself because 
he is the movement, and the movement him. 
So when they ask you to take a look at the evidence
that comes in — the evidence of wealth, the evidence of
spending, the evidence of luxury — I ask you to evaluate all of
that evidence in the context which I have described.  And if
you do so, and if you evaluate the evidence, understanding how
difficult it was for these entities to survive, and how each
one of the people who worked for these entities worked hard to
maintain and forward a movement, you will reach the only
logical conclusion in this case:  That Mr. Guo is not guilty of
the 12 counts of the indictment.  Thank you.
THE COURT:  Members of the jury, I want to remind you
about our trial schedule.  Every day, every weekday, you'll be
entering the courtroom at 9:30 in the morning.  By 9 o'clock,
you'll have a light breakfast available to you, so you can come
early.  But you must be ready to enter the courtroom at 9:30.
So, in general, we'll take a half-hour break between
11:30 and 12; and I will also have a light lunch for you.  And
then we'll go until 2:45.  By condensing the schedule this way,
I don't take up your entire day until 5 p.m.  I'm very aware

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that you have other important things to do during the day, and
so that is why I've designed the schedule in this way.
So at this time we will take our half-of-an-hour
break.
(Jury not present) 
THE COURT:  You may be seated.  Counsel, is there
anything before we return in half of an hour?
MR. FERGENSON:  No, your Honor.
THE COURT:  You're ready with your first witness?
MR. FERGENSON:  Yes, your Honor.
MR. KAMARAJU:  Not from the defense, your Honor.
THE COURT:  All righty.
(Luncheon recess) 
(Continued on next page)

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A F T E R N O O N   S E S S I O N 
12:10 P.M. 
(At sidebar) 
THE COURT:  I have a note from Juror No. 192.  I don't
remember his number, his actual number on the jury.
MR. KAMARAJU:  It makes sense that he's an alternate.
MR. BARKAN:  192 is Alternate 5, your Honor.
THE COURT:  Okay.  Alternate 5.  
To the Honorable A. Torres:   
I am profoundly disappointed that my excuse for 
dismissal wasn't granted.  My request began with I am a working 
single father.  My child will have field trips, Father's Day, 
tea ceremony, and graduation.  And I will now not be able to 
attend.  When school ends on June 18th, I will not be able to 
take her to camp.  My family is far away and not able to assist 
regularly.  I am a widower.  My wife passed away in childbirth.  
So being able to something my child is very important.   
I've just learned about the need to gather at a 
location at an agreed-upon time.  I dropped my child off at 8 
a.m.  Any adjustments brought in will cost me, my family, and 
job gravely, not to mention thousands of dollars.  I did not 
detail my work position and how I am required to be at my job.  
I thought my reasonable request based on my home and living 
situation would have been sufficient.   
To the attorneys, I appreciate the confidence you have

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in my selection.  You have royally screwed me over.   
Juror No. 192. 
MS. SHROFF:  He's the gentlemen who served on Judge
McMahon's jury.  I think he said that when he was being voir
dired.
THE COURT:  What would you like me to do?
MS. SHROFF:  I say we let him go.  We have six; we can
live with five.
MR. FINKEL:  So, your Honor, the government is fine
with five alternates.  However, we defer to the Court on the
appropriateness on how to deliver the message.  And the
government's concern would be sending a message to the rest of
the jury that merely sending a letter to the Court would allow
them to be excused from service.  
The government has no objection to proceeding with 
five alternates; and just ask the Court to use its discretion 
and its experience on how to -- the timing of how to deliver 
the message. 
THE COURT:  So I am also told that the jurors are not
pleased with the arrangement that they meet at a pick-up point
and be taken by car to the courthouse.  XXXXXXXXXXXXXXXXXXXX
XXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXX
XXXXXXXXXXXXXXXXXXXXXXXXXXXXXwhich I think is acceptable.
MR. KAMARAJU:  Fine with us, your Honor.
THE COURT:  So this juror, Alternate No. 5, does not

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know about that offered alternative yet.  I could always bring
him in and ask him if that change would make it acceptable to
him, see what he says.
MS. SHROFF:  We leave it up to the Court, if the Court
wants to ask him.  But he seems royally, as he puts it, pissed
off.  So my inclination would be to let him go.  But perhaps
the Court could consider if we just let him sit through the day
and then we let him know just not to come on Monday, and then
assume that -- either tell the jury that, you know, this is the
new pool and provide no explanation, so that they don't think
somebody got away with something.
THE COURT:  I definitely will have him sit through the
day, and I will speak with him after we're finished for the
day.  Okay.
MR. FINKEL:  Your Honor, one application before we
leave.  Just that the location where the jurors are going to
meet be sealed in public record for the reasons that the
government stated in its motion, and that the location where
the jurors are going to meet not be shared with the defendant.
THE COURT:  I think that that is totally appropriate.
MS. SHROFF:  We don't even know where they were going
to meet, so we have nothing to share.
THE COURT:  Okay.  So those items will be sealed.
MR. FINKEL:  Thank you, your Honor.
(Continued on next page)

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(In open court) 
THE COURT:  Would you have the jurors return to the
courtroom please.
(Jury present) 
THE COURT:  Please be seated.
Will the government call its first witness.
MR. FINKEL:  Yes, your Honor.  
The government calls Erin McNamara. 
 ERIN McNAMARA, 
     called as a witness by the Government, 
     having been duly sworn, testified as follows: 
THE COURT:  Please state your name and spell it.
THE WITNESS:  Erin, E-R-I-N; McNamara,
M-C-N-A-M-A-R-A.
THE COURT:  Please draw the microphone towards you.
You can bend it if you like.
You may inquire. 
MR. FINKEL:  Thank you, your Honor.
DIRECT EXAMINATION 
BY MR. FINKEL:  
Q. Good afternoon.
A. Good afternoon.
Q. Where do you work?
A. I'm a special agent with the FBI in the New Haven field
office.

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Q. How long have you been with the FBI?
A. 26 years.
Q. What, if anything, did you do before you were an FBI agent?
A. I was an auto underwriter with State Farm.
Q. Special Agent McNamara, what is ERT?
A. It's an evidence response team.
Q. Can you please describe to the members of the jury what the
evidence response team does.
A. Sure.  Evidence response teams, they are bureau-wide.  They
are people who are additionally trained in crime scene
management and forensic evidence collection.
Q. Special Agent McNamara, what role, if any, do you have with
ERT?
A. I'm the senior team leader for the New Haven team.
Q. What is a search warrant?
A. A search warrant is a document that's obtained from a
judge, usually an investigator gets it.  It explains what it is
that you are allowed to search and what it is that you are
allowed to search for and seize.
Q. Special Agent McNamara, I want to direct your attention to
March 15th, 2023.  In connection with your role at ERT, what,
if anything, did you do that day?
A. We executed a search warrant at 373 Taconic Road in
Greenwich, Connecticut.
Q. What sort of neighborhood is Greenwich, Connecticut?

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A. It's a very affluent neighborhood.
Q. How would you describe 373 Taconic Road?
A. It's beautiful, beautiful mansion.  Very large, beautiful
yard, pool, tennis courts.  And I believe it even bordered a
golf course.
MR. FINKEL:  Ms. Loftus, we can display for the
witness what's been marked for identification as GX 133.
Q. Special Agent McNamara, what is GX 133?
A. That's an aerial view of 373 Taconic Road in Greenwich.
Q. Is that a fair and accurate photograph of 373 Taconic Road
in Greenwich?
A. Yes.
MR. FINKEL:  Government offers 133.
THE COURT:  No objection?
MS. SHROFF:  No, your Honor.
THE COURT:  Admitted.
(Government's Exhibit 133 received in evidence) 
MR. FINKEL:  If we could publish it, please,
Ms. Loftus.
Q. Special Agent McNamara, was the weather the day that you
were at 373 Taconic the same as what we see on the screen?
A. No, there was snow on the ground.
Q. Approximately what time did you arrive at 373 Taconic on
March 15th?
A. Around 7 a.m.

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Q. And when you arrived, did the FBI have a search warrant?
A. Yes.
Q. For what?
A. For 373 Taconic Road and its grounds.
Q. Did the FBI have an arrest warrant that day?
A. Yes.
Q. For who?
A. Miles Guo.
Q. Was Miles Guo present at 373 Taconic?
A. No.
Q. Were there individuals besides FBI personnel present at 373
Taconic?
A. Yes, there were three residents.  There were an older
female, a younger female, and a male.  And my understanding was
it was the wife, daughter, and the daughter's boyfriend.
Q. Wife, daughter, and daughter's boyfriend of whom?
A. Of Mr. Guo.
Q. What were their names?
MS. SHROFF:  Objection.
THE COURT:  Overruled.  You may state that.  You may
answer.
A. The daughter was Mei --
MS. SHROFF:  May we approach for a moment, please?
THE COURT:  All right.
MS. SHROFF:  Thank you.

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(At sidebar) 
MS. SHROFF:  Your Honor, the daughter's name is
immaterial.  She has been the subject of a lot of online and
offline harassment.  She's not even in court today because she
does not want to be identified.  She has made no court
appearances, even though she's dedicated to her father, because
she is constantly harangued.
We have not once raised an objection to their 
witnesses names not being disclosed.  And there is no relevance 
to what her name is.  It's not pertinent at all to any 
questioning here.  Her name could be Sonia Gandhi, for all I 
care, but her real name does not need to be used. 
MR. FINKEL:  It is pertinent because her name is on
documents, as is the name of the wife, as is the name of the
daughters, boyfriend or fiancé.
In addition, I should note it is relevant here.  
Ms. Shroff opened on the fact of the wife and the daughter and 
their relationship with him.  Her name is on documents.  We 
need to explain who she is.  It's relevant. 
THE COURT:  The harassers already know her name.
MS. SHROFF:  She's not here in court.  She didn't come
to court to support her father because she's being harassed,
your Honor.  And I did not refer to her by name in my opening
for a specific reason, which is obvious why I didn't use the
wife's name and the daughter's name.  And I think the record

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speaks for itself on that point.
THE COURT:  So the fact that these names are on
documents makes her name relevant.  But also, the Chinese
Communist Party jailed the wife and daughter.  I'm sure they
know the name, plus a lot of other information.  
The objection is overruled. 
MS. SHROFF:  Your Honor, it's not the Chinese
Communist Party, it's quote/unquote victims.
THE COURT:  Overruled, Ms. Shroff.
MS. SHROFF:  Thank you.
(Continued on next page)

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(In open court) 
THE COURT:  You may answer.
A. The daughter was Mei, M-E-I; Guo, G U O.  The mother, I
only recall her last name was Ngok, N-G-O-K.  And the male, it
was Cao, C-A-O.
Q. Do you remember the male's first name?
A. I do not.
MR. FINKEL:  Ms. Loftus, if we can display for the
witness 3514-48.  If you can please go to page 2 of that.
Actually, your Honor, may I approach? 
THE COURT:  You may.
Q. Special Agent McNamara, can you look at your screen towards
the bottom.  And the question is whether that refreshes your
recollection as to the daughter's boyfriend's first name?
A. Yes.
MR. FINKEL:  Ms. Loftus, can you bring that down,
please.
Q. Special Agent McNamara, what is the daughter's boyfriend's
first name?
A. Defeng, D-E-F-E-N-G.
Q. Special Agent McNamara, what was your role with respect to
the search at 373 Taconic?
A. I was a coordinator.  I made sure we had the materials we
needed, assignments as to who would photograph, answer
questions; just sort of made sure that the search kept moving

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and that everything was completed.
Q. And what were the sort of items that the team was looking
for?
A. Electronics like cell phones, computers, business records,
financial records, photographs, things of that nature.
Q. By the way, Special Agent McNamara, aside from your
involvement in this search on March 15th, were you involved in
the investigation concerning Miles Guo?
A. No.
Q. If you were not involved in the Miles Guo investigation,
can you explain to the members of the jury why, if at all, you
were participating in a search that day?
A. Sure.  It was a request by New York.  They had multiple
search warrants, so they needed assistance conducting this one.
And since it's in Greenwich, it's in our territory in
Connecticut, so they asked us for assistance.  They asked us to
provide people and supplies and things that were needed to
conduct the search.
Q. Does that happen somewhat commonly within the FBI?
A. Yes.
MR. FINKEL:  Your Honor, at this time I'd like to read
a stipulation to the parties.
THE COURT:  Go ahead.
Before you read the stipulation though, I'd like to 
let the jurors know what a stipulation is.

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A stipulation is an agreement between both sides to
present evidence to the jury without calling a witness for the
purpose of discussing the subject matter.
Go ahead. 
MR. FINKEL:  It is hereby stipulated and agreed by the
United States of America and Miles Guo, the defendant:  
If called as a witness at trial, a special agent of 
the Federal Bureau of Investigation, FBI, would testify as 
follows: 
On March 15, 2023, special agents and other FBI
employees executed a judicially authorized search of 373
Taconic Road, Greenwich, Connecticut.  During the course of
that search, FBI personnel took photographs of exterior and
interior spaces of 373 Taconic Road, Greenwich, Connecticut,
and also lawfully seized documents and electronic devices.
Government Exhibits GX CT-20 through GX CT-30, GX
CT-35 through GX CT-72, GX CT-74 through GX CT-105 are fair and
accurate photographs of interior and exterior spaces of 373
Taconic Road, Greenwich, Connecticut, that were lawfully
captured by an FBI photographer on March 15, 2023, when
conducting the search.
Following the March 15, 2023 search, FBI personnel 
scanned and photographed documents that were lawfully seized 
during the search.  GX CT-101 through GX CT-129, GX CT-157 
through GX CT-187, GX CT-190 through GX CT-202, and GX CT-204

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through GX CT-207 are true and correct copies of documents that 
were seized during the March 15, 2023 search of 373 Taconic 
Road, Greenwich, Connecticut.   
It is further stipulated and agreed that this 
stipulation, which is GX STIP-1, may be received into evidence 
as a government exhibit at trial.  And it's signed by the 
parties.   
With that, your Honor, the government offers GX 
STIP-1. 
THE COURT:  It is admitted.
(Government's Exhibit STIP-1 received in evidence) 
MR. FINKEL:  And the government offers GX CT-20
through GX CT-30, GX CT-35 through 72, GX CT-74 through 105, GX
CT-101 through 129, GX CT-157 through 187, GX CT-190 through
202, and GX CT-204 through 207.
THE COURT:  They are admitted.
(Government's Exhibits CT-20 through CT-30, CT-35 
through 72, CT-74 through 105, CT-101 through 129, CT-157 
through 187, CT-190 through 202, CT-204 through 207 received in 
evidence) 
MR. FINKEL:  Thank you.
BY MR. FINKEL:  
Q. Special Agent McNamara, did you see every aspect of 373
Taconic on March 15, 2023?
A. I did not.

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Q. How long did the search take?
A. Just under four hours.
MR. FINKEL:  We can please display what's in evidence
as Government Exhibit GX CT-87.  
Q. Special Agent McNamara, what is the jury looking at in GX
CT-87?
A. That's an exterior photo of 373 Taconic Road.
MR. FINKEL:  If we can pull up, please, Ms. Loftus, GX
CT-25.  It's not on your screen?  If you can publish that,
please, Ms. Loftus.  It wasn't published.  Thank you.  Sorry
about that.
Q. Special Agent McNamara, what is GX CT-25?
A. That's another exterior photo of 373 Taconic Road, the rear
of the house.
MR. FINKEL:  Ms. Loftus, if we can please publish GX
CT-91.
Q. Special Agent McNamara, what is GX CT-91?
A. This is a side of the house, the side with the two garages.
Q. Did there come a time during the search of 373 Taconic when
you entered the garages that we're looking at in GX CT-91?
A. Yes.
Q. Which garage?
A. Both.
Q. What, if anything, were in the garages?
A. In the garage to the right in the photo as you're looking

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at it was a red Lamborghini.
MR. FINKEL:  If you can please display GX CT-95.
Q. Special Agent McNamara, is this the garage that you went
inside and saw the red Lamborghini?
A. Yes.
MR. FINKEL:  If we can please display GX CT-38.
Sorry.  It looks like our computer froze.  Bear with 
us.  Apologies. 
Q. While we're waiting for the computer to wake up, which
happens, sorry, Special Agent McNamara, what, if anything,
happened to the Lamborghini on March 15, 2023?
A. It was seized.
Q. And was that pursuant to a warrant?
A. A seizure warrant, yes.
Q. And was the FBI able to locate the keys to the Lamborghini?
A. Yes.
Q. And where were they?
A. Inside the house.
Q. Did you see the keys that day?
A. I did.
Q. Special Agent McNamara, what is a VIN number?
A. It's a vehicle identification number.  It's a number that's
unique to each vehicle.
MR. FINKEL:  If we can please display GX CT-42.
Q. Special Agent McNamara, approximately how many FBI

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personnel participated in the search?
A. Around 40.
Q. And did you walk from one side of the home to the other?
A. I did not -- no, not on every floor no, I did not.
Q. On any of the floors did you?
A. The first floor.
Q. How long did it take to get from one side to the other?
A. I don't know.  I was stopped multiple times from one end to
the other.
MR. FINKEL:  If we can please display, Ms. Loftus, GX
CT-41.
Q. Special Agent McNamara, did the 373 Taconic appear to be a
home that was lived in?
A. Yes.
Q. Why was that?
A. There were clothes, shoes, food, toiletries, dogs.  They
had two dogs.  Dog beds.
MR. FINKEL:  Just going to wait for our computer to
cooperate so we can continue.
Q. All right.  Special Agent McNamara, what are we looking at
in GX CT-41?
A. That's the VIN number on the Lamborghini in the garage.
Q. Does ERT have any practices or procedures with respect to
VIN numbers on cars?
A. Yes, we always photo the VIN number because it's a unique

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identifier, like a serial number on a computer.
MR. FINKEL:  Your Honor, may I approach?
THE COURT:  You may.
MR. FINKEL:  I've handed the witness what's been
marked for identification as Government Exhibit 36.
Q. Special Agent McNamara, can you look at Government Exhibit
36, please.
A. It's keys to a Lamborghini.
Q. And do those keys have any uniquely identifying marks?
A. There's a partial VIN number on the tag.
Q. And what is the end of the partial VIN number?
A. 10393.
Q. Does that match the VIN number in GX CT-41?
A. It does.
MR. FINKEL:  Government offers 36.
THE COURT:  It is admitted.
(Government's Exhibit 36 received in evidence) 
MR. FINKEL:  Your Honor, may I publish it to the jury?
THE COURT:  You may.
MR. FINKEL:  If we can display for the witness,
please, Government Exhibit GX CT-209.  Just for the witness.
Q. Special Agent McNamara, from where were the keys recovered?
A. There was a -- it was a room, I would call it like an
office/security room.  There were monitors for the security
cameras in there.  And a desk.

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MR. FINKEL:  One moment, please.
MR. FINKEL:  GX CT-209, please, for the witness.
Q. Special Agent McNamara what is GX CT-209?
A. That's another photograph from the search.
Q. Is that a fair and accurate photograph of what you saw on
March 15, 2023?
A. Yes.
MR. FINKEL:  Government offers CT-209.
THE COURT:  It is admitted.
(Government's Exhibit CT-209 received in evidence) 
MR. FINKEL:  Can you please publish that.
The jury can see it?  No?  Now you can.  Okay.  Great. 
Q. Special Agent McNamara, do you know what those flags are?
A. No.
MR. FINKEL:  We can now please display what's in
evidence as Government Exhibit CT-58.
Q. Special Agent McNamara, what are we looking at in GX CT-58?
A. A photograph of one of the rooms in the house at 373
Taconic Road.
Q. And what, if anything, was in that room besides what we're
looking at?
A. Oh, cameras.  Like a video cameras.
Q. Do you know why there are video cameras in there?
A. No.
MR. FINKEL:  Please look at, Ms. Loftus, GX CT-59.

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Q. What is GX CT-59?
A. That's another photo of that room, that same room.
MR. FINKEL:  If we can please, Ms. Loftus, show just
the witness GX CT-208.  This is just for the witness, please.
Q. Special Agent McNamara, what are we looking at in GX
CT-208?
A. That's another photograph from the search.  That's what I
would call the living room.
MR. FINKEL:  Government offers GX CT-208.
THE COURT:  It is admitted.
(Government's Exhibit CT-208 received in evidence) 
MR. FINKEL:  Publish that please, Ms. Loftus.
If we can please display Government Exhibit GX CT-83, 
which is in evidence. 
Q. Do you know what those insignias on the clothing are?
A. No.
MR. FINKEL:  Ms. Loftus, if we can display GX CT-80.
80, please.  Eight zero.  This is in evidence.
Jury able to see that?  No?   
Can we publish that to the jury, please. 
Q. Are these some of the closets that you mentioned before?
A. Yes.
Q. Special Agent McNamara, you said some documents were
recovered that day; is that correct?
A. Yes.

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Q. Did you review the documents?
A. No.
Q. Did other members of the team?
A. No.
Q. What happened to the documents after they were collected on
March 15, 2023, do you know?
A. They were collected, they were packaged, and they were
handed over to New York.
Q. And the New York field office was running this
investigation; is that correct?
A. Yes.
MS. SHROFF:  Objection to the leading.
THE COURT:  You can ask who was leading the
investigation.
BY MR. FINKEL:  
Q. Special Agent McNamara, which field office, if any, was
leading the investigation in this matter to your understanding?
A. New York.
MR. FINKEL:  We can please display what's in evidence
and for the witness and the jury GX CT-201.  If you can go to
the second page, please.
Q. Special Agent McNamara, can you read what it says at the
top?
A. Brioni, 688 Madison Ave., New York, New York, 10065.
Telephone number:  212-376-5777.

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Q. What does it say in that green cell at the top of the
chart?
A. Invoice from Mr. Miles Kwok bespoke order.
Q. Do you know what Brioni is?
A. No.
MR. FINKEL:  If we can go to the next page please,
Ms. Loftus.  Page 4, rather.  Can you zoom in on that.  We can
go to page 5, please.  And if you can please pull up what's in
evidence as GX CT-205.  I'm sorry, 207.  Excuse me.
This should be published so the jury can see it.  If 
we can go to the next page, please.  And can you zoom in at the 
top please, Ms. Loftus. 
Q. Special Agent McNamara, can you read up to "background"?
A. Execution version.  Loan agreement.  This agreement (this
agreement) is made on the 3rd day of June 2020, between GTV
Media Group, Inc. (the lender), a Delaware corporation with
office address at 162 East 64th Street, New York, New York, 
10065, and Saraca Media Group Incorporated (the borrower), a
Delaware corporation with office address at 162 East 64th
Street, New York, New York, 10065.  Each a "party together"
parties.
MR. FINKEL:  Ms. Loftus, if you can go to the last
page of this document, please.  Can you zoom in on that.
Q. And who is the authorized signatory according to this
document, Special Agent McNamara, for Saraca Media Group Inc.?

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A. I'm going to mispronounce this.  Qiang, Q-I-A-N-G, Guo.
MR. FINKEL:  Thank you, Ms. Loftus.
If we can bring up, please, GX CT-198 for the parties 
and the jury.  And if you can go to the next page of that 
please. 
Q. Special Agent McNamara, can you read this document, please.
A. Dear Mr. Harry Eccles-Williams, I am writing this letter to
request and to put into consent for the release of all my files
from your firm to Qiang Guo as soon as possible.  Most
importantly, the relationship between me and Appleby, the
relationship between Well Origin and Appleby.  Thank you.
Yours sincere, Ho Wan Kwok.
MR. FINKEL:  Ms. Loftus, if we can bring up, please,
GX CT-157 for the jury and the parties.
That's fine.  Right there as you have it. 
Q. Special Agent McNamara, can you read the top of that,
please.
A. G talks-program.
Q. Can you read down where it says 7:48 a.m.?
A. Welcome by host, Limarie Reyes.
Q. Who's Limarie Reyes?
A. I have no idea.
MR. FINKEL:  We can display, please, GX CT-172.
That's fine, Ms. Loftus. 
Q. Special Agent McNamara, can you read the top of GX CT-172.

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A. List of do-not words dash -- slash, I'm sorry, ideas.
MR. FINKEL:  Ms. Loftus, can you scroll down a little
bit.
Q. Special Agent McNamara, do you see where it says "loans"?
A. Yes.
Q. Can you read the words that follow "loans."
A. Partner or partners, growth, growth projections, venture,
partnership, future investment benefits, future opportunities,
participate/participation in business or profits, GTV, Saraca,
voice of Guo/voice of good (VOG), Rule of Law Foundation, Rule
of Law Society, Canada Himalaya, Jang Yun Fu, lewd, Yvette Wang
Yvette, Sarah, Mulan, SEC, investigation, litigations, golden
spring, regulators, DOJ.
Q. What is DOJ?
A. Department of Justice.
Q. What is SEC?
A. Securities Exchange Commission.
MR. FINKEL:  Ms. Loftus, if we can bring up, please,
GX CT-174.
Q. Can you read where it says 8:20 a.m.
A. Live Q&A by Mr. Miles Guo, preselected questions.
MR. FINKEL:  Ms. Loftus, if you can display for the
witness only GX CT-210.
Q. Special Agent McNamara, what is GX CT-210?
A. It's one of the photographs from the search.

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MR. FINKEL:  Government offers GX CT-210.
MS. SHROFF:  Objection, your Honor.
THE COURT:  If you'll step up, please.
MR. FINKEL:  I can lay an additional foundation.
Q. How do you recognize this photograph as one of the
photographs from the search?
A. I reviewed the photographs.
Q. Okay.  Did you see this particular area of 373 Taconic on
the day that the search was conducted?
A. I don't recollect.
Q. Okay.  Does the FBI maintain photographs that are taken
during a search in the regular course of FBI's business?
MS. SHROFF:  Objection.  What the FBI generally does
is not relevant.
THE COURT:  Overruled.  You may answer.
A. Yes.
Q. And you said that you reviewed the photographs from the
search.  Can you explain what you mean by that?
MS. SHROFF:  Objection to the leading.
THE COURT:  Overruled.  You may continue.
A. So we had -- we maintained a copy of photographs from the
search.  When I was asked to come here, I reviewed this to
refresh my memory of the search.
Q. And the photographs that were part of the search, are they
maintained in FBI's records and kept that way?

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A. Yes.
MS. SHROFF:  Objection.  She has no personal
knowledge.
THE COURT:  Step up.
(Continued on next page)

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(At sidebar) 
THE COURT:  So she is familiar with the photographs
from the search.
MR. FINKEL:  So, your Honor, she was the team lead and
she's familiar with the ERT, including its recordkeeping
practices.  For one, I think she recognizes parts of the
photograph, but that's neither here nor there.  She can lay an
803(6) foundation as a photograph that was taken at the search.
She knows it was stored with the other photographs of the
search.  
I'll lay that foundation that it was taken by someone 
with knowledge of the matter at the time it occurred and kept 
in the course of the FBI's business.   
It's one photograph.  We can lay the foundation. 
MS. SHROFF:  The government knows full well it has a
problem here.  They asked me this morning to stipulate to it
coming into evidence and I declined because they are unable to
lay a foundation.  The fact that --
THE COURT:  What is wanting in the foundation?
MS. SHROFF:  Your Honor, number one, she didn't take
the photograph; number two, she didn't view the evidence;
number three, she didn't view that particular scene; number
four, the only reason she's table to testify this way is
because of the government giving her the photos that they took
from other members of the FBI team and showed it to her.

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She has zero personal knowledge of this particular 
photograph.  And nothing about a photograph being in an FBI 
file falls under the exception of a business record.  Either 
she has personal knowledge of this or she doesn't, and clearly 
she doesn't, your Honor.   
Additionally -- 
THE COURT:  Isn't this kept in the regular course of
business?
MS. SHROFF:  It doesn't fall within that exception,
because the exception is supposed to capture something that is,
one, a business record, which this is not; this is evidence
gathering.  And documents gathered by the FBI are by definition
self-serving because they are prepared in the course of a
litigation.  But they do not technically fall within the
business records exception.
Number two, the way this photograph is taken, it is 
not a photograph of a scene that is in the home.  So what 
they've done is they've gone through the entire house, pulled 
out all the sunglasses, laid them on a table, and then taken a 
photograph.  You can see that clearly from the photograph and 
from the cases that are stacked up next to them.   
So this particular person did not do the underlying 
search for the sunglasses, did not place the sunglasses there, 
and she has zero personal knowledge of any of this. 
THE COURT:  But the photograph was taken during the

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course of the search.
MS. SHROFF:  She wouldn't know that.  It could have
been this search, it could have been another search, it could
have been a search before that.  She doesn't know when this
photograph was taken.
MR. FINKEL:  If I may just make a few points.
First of all, if necessary, we can bring another 
person to simply authenticate one photograph.  The parties have 
worked quite well in good faith on stipulating authenticity, 
suddenly that changed this morning.   
Number one, I believe if I ask the witness, Do you 
recognize any components of this photograph, she will say:  I 
know the door and that was from the room.   
A witness does not have to be the one to take a 
photograph to get it into evidence.  The witness does not have 
to be the one to move things around if that's, in fact, what 
happened to get it into evidence.  If Ms. Shroff wants to cross 
her on how the sunglasses were arranged, if that is, in fact, 
correct, I don't know, she can do that.  It's just an 
admissibility question. 
THE COURT:  So she may be able to testify as to the
door, but she certainly can't testify as to the rest of the
room and how these sunglasses were positioned.
MS. SHROFF:  We would have no objection --
MR. FINKEL:  Excuse me.

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MS. SHROFF:  -- to the photo of the door.
MR. FINKEL:  Excuse me.
That would be appropriate cross.   
This goes to the weight of the document.  Excuse me.  
This goes to the weight of the document, not to admissibility.  
In either case, I can lay an 803(6) foundation.  She's familiar 
with the case file and she's familiar with how the records are 
stored.  That's one photograph.  I'll just leave it at that. 
THE COURT:  So she can identify the room, but she
cannot identify these objects.
MR. FINKEL:  Okay.  So I'll lay an 803(6) foundation.
THE COURT:  Okay.
MS. SHROFF:  Your Honor?
THE COURT:  We're done.
(Continued on next page)

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(In open court) 
BY MR. FINKEL:  
Q. Special Agent McNamara, when a search is conducted by the
FBI, what happens to the photographer's photos?
A. The photographer brings the -- takes the SD card out of the
camera, places it into a tower.  It's not a computer, it's a
tower where you just burn -- you can do like four copies at a
time.  So that they place that in there.  We burn the copies.
The first copy is the original, and that goes into 
original envelope of -- original evidence envelope, a 1A 
envelope we call it.  It gets attached to the file.   
The second is the backup copy; that also gets put into 
the file.   
The third copy is one we would send to the case agent 
for a working copy so they wouldn't have to go and remove those 
physically from the file to review it.   
And if there were items that were being sent to the 
lab, we would also burn a copy to send with those items to the 
lab for review. 
THE COURT:  I'd like you to get closer to the
microphone.  You can bring it closer, you can sit closer.  And
speak up.
Q. And the copies of photographs, which field office, if any,
were they sent to?
A. New York.

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MR. FINKEL:  We can please display, Ms. Loftus,
Government Exhibit GX CT-129.  This is in evidence.  And if we
can please go to page 17.  I just want to make sure it's
published for the jury.  If you can zoom in just for the top
half, please, Ms. Loftus.
(Continued on next page)

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BY MR. FINKEL:  
Q. Can you read that, please, Special Agent McNamara.  
A. "Declaration of Trust and Agreement.  The Declaration of
Trust and Agreement (this Trust and Agreement) is made on
December blank 2020, between Qiang Guo, the beneficiary, an
individual holding Cyprus passport number blank, residing at
blank, London, United Kingdom, and Kin Min Je, the Trustee, an
individual holding Hong Kong passport No. KJ0168411, residing
at 87 Balmoral House, Earls Way, London, United Kingdom, each a
party, together parties."
Q. And you can continue reading, please.
A. "Background.  The Trustee agrees to hold the shares of the
following companies (each, the company, together, the
companies) registered in the name of the Trustee for and on
behalf of the Beneficiary:  (1) Himalaya Currency Clearing Pty.
Ltd., a company registered in Australia with the company number
642418684; (2) Himalaya Reserves Pty. Ltd., a company
registered in Australia with company number 642487232,
Himalaya——sorry; (3) Himalaya Currency——I think it's Party——I'm
sorry——Ltd., a company registered in Australia, with company
number 643817449; (4) Major Lead International, Ltd., a company
registered in British Virgin Islands with company number
1976621."
MR. FINKEL:  Can you zoom in, please, Ms. Loftus.
Q. Can you read No. 3, please, Special Agent McNamara.

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MR. FINKEL:  Ms. Loftus, if you can zoom in on No. 3.
A. "The Trustee further covenants with the beneficiary: (3.1)
to keep the company at all times solvent unless instructed
otherwise by the beneficiary, and to comply with all applicable
rules and regulations that the company requires; (3.2) to keep
the company active on the——on the relevant registry at all
times, and pay on time all applicable fees which will be
reimbursed by the beneficiary; (3.3) not to assign or part with
possession of the company to any third party without the prior
written approval of the beneficiary."
MR. FINKEL:  Ms. Loftus, you can zoom out of that,
please, and go to the next page.
And the next page, please.
Q. And can you read the sign names, next to where it says
Signed.
A. Signed by Qiang Guo.  Signed by Kin Min Je.  Witnessed by
blank.
MR. FINKEL:  Thank you.  Ms. Loftus, you can take that
down.
Just one moment, your Honor.
Can you please display, Ms. Loftus, Government Exhibit
GX CT176.
Q. And Special Agent McNamara, can you read starting where it
says "Draw."
A. "Draw G——I'm sorry——G Fashion items, Designer 1 Whistle,

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pants, 100, hat, 200."
MR. FINKEL:  If you can please go, Ms. Loftus,
GX CT184.
Next page, please.
Keep going.  Stop right there.
Q. What sort of document is it?
A. It's a vehicle title.
Q. What's a vehicle title?
A. It's——it's something that you have to——it's——shows your
ownership and it's registered with the state.
Q. What's the name of the owner listed on this?
A. It's Cao, C-A-O, Defeng, D-E-F-E-N-G.
Q. Did you see Cao Defeng or Defeng Cao on March 15, 2023?
A. Yes.
Q. And what type of car is this?
A. Lamborghini.
Q. What's the model?
A. Aventador.
Q. And what is the last four digits of the VIN, or vehicle
identification number?
A. 0393.
MR. FINKEL:  Ms. Loftus, if you can please display
GX CT41.
Q. What are the last four digits of this vehicle
identification number on the Lamborghini?

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A. 0393.
MR. FINKEL:  Nothing further at this time.  Thank you.
THE COURT:  Cross-examination?
MS. SHROFF:  Thank you, your Honor.
CROSS EXAMINATION 
BY MS. SHROFF:  
Q. Good afternoon, Special Agent.
A. Good afternoon.
Q. Ms. McNamara, before March 15th, did you know anything
about Mr. Miles Guo?
A. No.
Q. And you prepared, I take it, right, to execute the search
on March 15th?
A. Prepared the search supplies and things of that nature,
yes.
Q. Right.  And you had a plan in place, correct?
A. Yes.
Q. And prior to executing the search, you met with or emailed
with the members of the team that were going to accompany you,
correct?
A. Yes.
Q. You discussed where Mr. Guo might be on March 15th,
correct?
A. I don't believe so.
Q. You did not discuss where——which one of the three homes you

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thought he might be in?
A. I don't recall that.
Q. Do you recall, sitting here today, on what date you started
preparing to execute the search?
A. It was either earlier that week or late the prior week.  I
believe.
Q. And you emailed, did you not, with other members, including
somebody named Robin, correct?
A. I don't know who Robin is.
Q. Robin Cartwright?
A. Rachel Cartwright.
Q. I'm sorry?
A. Rachel.
Q. Rachel, Robin, you emailed with her, right?
A. Yes.  She's the one that requested our assistance.
Q. And in emailing with her, the plan was for her to exchange
information with you and you to exchange information with her,
correct?
A. Information about how we were going to conduct the search,
yes.
Q. Right.  And you knew you were going to search a home,
correct?
A. Yes.
Q. And you knew it was a large home, correct?
A. Yes.

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Q. And you knew the home could have Mr. Guo in it, correct?
A. Yes.
Q. And you were planning to arrest Mr. Guo, correct?
A. I was not.
Q. Well, somebody on your team was going to arrest Mr. Guo,
correct?
A. No one on my team does arrests.  We simply do searches.
Q. Okay.  And you testified earlier that you didn't recall
whether or not you anticipated where Mr. Guo would be, so let
me approach with something that might refresh your
recollection.  That would be 3514-24.
Does that refresh your recollection, ma'am, that you
were anticipating Mr. Guo not being in the Connecticut home?
A. No.
Q. And it is fair to say that you interacted via email with
several individuals, all coordinating the search of this place,
right?
A. Yes.
Q. And that's 373——I have trouble pronouncing the
street——Taconic Road; is that correct?
A. Yes.
Q. And you wanted to go there early in the morning, correct?
A. Yeah.  I did not choose the time.
Q. Okay.  But in any event, you were there before 7:00; is
that fair to say?

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A. No.  We arrived around 7:00.
Q. And it's fair to say that the home itself is not one that
you had access to, correct?
MR. FINKEL:  Objection.
A. I don't understand.
THE COURT:  Overruled.
MS. SHROFF:  I'll rephrase, your Honor.
Q. You couldn't get in through the gate, right?  Your team
couldn't get in through the gate, correct?
A. Yes, we could.  The gate was open when we arrived.
Q. The gate to the home was open.
A. Yes.  When my team arrived, the gate was open.
Q. And how many teams preceded you?
A. The——the team that was doing the entry.
Q. The team that was doing the entry, correct?
A. Yes.
Q. And the team that was doing the entry was coordinating with
the team that was following, which is your team, correct?
A. When——when they finished their entry and it was secured,
they let us know that we can then proceed to the location.
Q. Right.  And did the team that was doing the entry tell you
that it was Mr. Guo's daughter who let them in?
MR. FINKEL:  Objection.
THE COURT:  Sustained.
Q. When you——

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THE COURT:  You don't need to answer.
Q. When you entered the home, did you see Mr. Guo's daughter
and wife seated outside on a bench?
A. No.
Q. When was the first time you saw Mr. Guo's daughter and wife
in that home?
A. Inside the house.
Q. Where were they seated inside the house?
A. I would call it like a family room.
Q. And they were put there by the——by the team that entered
before you, correct?
A. I don't know.  I was not there.
Q. You don't know because you weren't there.  And when you
entered the house, did you go from room to room in the home?
A. When I first entered the house?
Q. Yes.
A. When I first entered the house, I went towards where the
residents were to find Supervisory Special Agent Cartwright to
let her know that we were there.
Q. Because she was the first entry team, right?
A. I don't know.
Q. You don't know who the first entry team was?
A. I don't know who was on the entry team.  I followed the
entry team.  That was not part of the search.
Q. So you followed the entry team, correct, and the entry team

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told you that the location was secure, correct?
A. We were at a staging location.  When the entry team told us
it was secure, then we drove to the residence.
Q. And how many of you drove together?
A. I can only speak for my team.  There were probably a dozen
of us or so.
Q. You just said you can only speak for your team, correct?
A. Right.  You asked who drove together; that's who I drove
with, my team.
Q. Okay.  Did any members of your team take any of the
photographs you testified to?
A. Yes.
Q. Okay.  So we'll get to the photographs in a minute.  But
let's just stay with your entry into the home, okay?  When you
entered the home, it looked, as you said, like a home that was
lived in, correct?
A. Yes.
Q. There was food on the kitchen table, correct?
A. There was food, yes.
Q. Yes.  And there were three people in the home, correct?
A. Yes.
Q. And the three people were Mr. Guo's wife, correct?
A. Yes.
Q. His daughter, correct?
A. Yes.

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Q. And his daughter's fiancé, correct?
A. I was told boyfriend, but yes.
Q. Okay.  And did you see the boyfriend who was in crutches in
the bedroom or did somebody tell you about that?
A. I'm sorry.  Can you repeat that.
Q. Sure.  During your search did you see his daughter's
boyfriend?
A. Yes.  They were all in that room together.
Q. Okay.  And he was on crutches, correct?
A. Oh, crutches, yes.  I'm sorry.  I misunderstood you.
Q. That's okay.  A lot of people misunderstand me.
But he was on crutches, right?
A. Yes, he had crutches with him.
Q. Right.  And there were two dogs, two small poodle-like dogs
in the home, correct?
A. Yes.
Q. And they had all been placed in that one room, correct?
A. No.  I took the daughter upstairs to go get the dogs.
Q. Okay.  So you took the daughter upstairs so that she could
retrieve the dogs, and you brought his daughter back down and
put her back in that room, correct?
A. Correct.
Q. Okay.  And you had them stay there while the rest of your
team searched the whole home, correct?
A. Yes.

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Q. Okay.  You gave her a copy of the search warrant, I'm
assuming?
A. I did not.
Q. Okay.  But she didn't stand in the way of you searching the
home, right?
A. No, she did not.
Q. Neither did the boyfriend who was on crutches, correct?
A. Correct.
Q. And certainly the wife didn't stand in the way, correct?
A. Correct.
Q. His wife is about 60 years old; is that right?
A. I have no idea.
Q. Wasn't she nervous when you watched her?
A. I didn't watch her.  I——I saw her for——briefly.  I spoke
with the daughter, I took her to get the dogs, brought them
back down, I let her know that, you know, if she needed to
bring them out, to feed them, it's not a problem, just let us
know, and then we proceeded.
Q. And then you started to search the house.  You said there
were at least about 20 other people, correct?
A. Yeah.  Oh, at least.
Q. Okay.  And when you say at least, were there more than 20?
A. I think we had approximately 40 people searching.
Q. Okay.  So you had 40 people searching, three residents in
the home, right?

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A. Yes.
Q. And nobody interfered with your search.
A. No.
Q. Okay.  At the time that you executed the search at
373——that's what I'm going to call it, okay——did you know how
many other homes Mr. Guo had?
A. No.
Q. Did you know he had a home in New York City?
A. I know that they were doing other warrants at the same
time.  I'm not sure which homes he owned or where he lived.
Q. Okay.  At the time that you executed the search did you
know Mr. Guo to have a lawyer?
A. I have no idea.
MR. FINKEL:  Objection.
THE COURT:  Overruled.
Q. At the time that you went to search Mr. Guo's home, did you
know anything about his status in the United States?
MR. FINKEL:  Objection.
THE COURT:  If you'll step up, please.
(Continued on next page)

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(At the sidebar) 
THE COURT:  So this is beyond the direct.
MS. SHROFF:  I'm happy to call her as my own witness
then, your Honor.  But I'm allowed to have some latitude about
what she knew when she executed the search warrant.  I'd be
happy to be more constrained, your Honor, but——
THE COURT:  So whether he had a lawyer, I allowed
that, but now going into his immigration status, I think that's
just going beyond.
MS. SHROFF:  Well, she took——she took hundreds of
documents from his home.  I'm entitled to ask what other
documents she took and what other documents he elicited
testimony about.
THE COURT:  Are there documents that relate to his
immigration status?
MR. FINKEL:  I don't know, but I understood from their
response to our letter the other night that his immigration
status is not at issue and it isn't——it's irrelevant.  And I
also understood from your Honor's ruling the presence of
lawyers is not something that the defense was going to dwell
on, nor should they suggest, by implying to the jury that
Mr. Guo had a lawyer, somehow the search was improper.  The
search was proper.  It was judicially authorized.
MS. SHROFF:  Your Honor, asking if somebody has a
lawyer does not imply that a search is improper, number one.

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          SOUTHERN DISTRICT REPORTERS, P.C.
            (212) 805-0300
O5O1GUO3                 McNamara - Cross
Number two, she recovered documents.  If they want to
cherry pick as to what they put in, I'm allowed to explore what
else was out there.  We have no interest, and, you know, the
immigration issue——
THE COURT:  You can ask whether or not there were
documents related to immigration status.
MS. SHROFF:  Right.  And that shows that a person
lived in their home; personal documents were in his home.
My——the point of my cross is to show that's his residential
home.  I'm not seeking to present a defense that he has an
immigration consequence through this conviction, which is what
the brief was about, so I don't know why that's being brought
up here.  Totally irrelevant.
THE COURT:  So there's no dispute as to whether or not
it was used as a home, is there?
MS. SHROFF:  Oh, yes.  Their argument is that Mahwah
was also a home, and I'm trying to show this was his home
alone, nothing that is recovered here is anywhere comparable to
anything recovered in Mahwah.  I am entitled to show that.
THE COURT:  So you're saying this is his principal
home?
MS. SHROFF:  His only residential home.
THE COURT:  Okay.  Well, she can bring out some
evidence on that issue.
MR. FINKEL:  Certainly.  It shouldn't suggest

95
          SOUTHERN DISTRICT REPORTERS, P.C.
            (212) 805-0300
O5O1GUO3                 McNamara - Cross
immigration status.  Immigration status is not something that's
relevant.
MS. SHROFF:  We're not talking about a status.  I have
a status, you have a status.  I'm an American passport holder.
That's my status.  If my passport is in my home, it's more
likely it's my home, it's less likely it's your home, right?
MR. FINKEL:  I completely agree the passport is——
THE COURT:  Sure.  But you were asking about his
immigration status.
MS. SHROFF:  I'll move from there and ask him if she
found some immigration-related document or his immigration
paperwork, his identity card, his wallet.  I'm entitled to ask
all of that.
MR. FINKEL:  Your Honor, no objection to identity
card, no objection to wallet.  My objection is for 402, 403
reasons to immigration documents and immigration status.
That's not appropriate.  It's not relevant.  I have no issue
with them exploring personal effects that were there.  That's
fine.  But——
MS. SHROFF:  We're not arguing he's going to be
deported or anything like that.  We're just trying to show that
he had immigration paperwork at his home.
THE COURT:  But ask for a passport as opposed to, do
you know what his immigration status was.
MS. SHROFF:  Sure.  I'd be happy to rephrase.

96
          SOUTHERN DISTRICT REPORTERS, P.C.
            (212) 805-0300
O5O1GUO3                 McNamara - Cross
THE COURT:  Thank you.
(In open court) 
THE COURT:  Objection is overruled.
BY MS. SHROFF:  
Q. Agent McNamara, how many hours did you spend searching the
home?
A. None.  I didn't search.
Q. Okay.  You simply supervised the search, correct?
A. Correct, mm-hmm.
Q. And you were directly supervising how many people?
A. Approximately 40.
Q. 40 people, correct?
A. Mm-hmm.
Q. And 40 people were given the task of searching different
parts of the home, correct?
A. Yes.
Q. Every bedroom was searched, correct?
A. Yes.
Q. Every living room was searched, correct?
A. Yes.
Q. Closets were searched, correct?
A. Yes.
Q. Bathrooms were searched, correct?
A. Yes.
Q. Okay.  So in the closets, and it's——if I could please

97
          SOUTHERN DISTRICT REPORTERS, P.C.
            (212) 805-0300
O5O1GUO3                 McNamara - Cross
have——actually, I rephrase that.
You were shown pictures of the closet, correct?
A. Yes.
Q. And in the closet there were white shirts hanging, correct?
A. Yes.
Q. Shoes?
A. Yes.
Q. Other men's clothing, correct?
A. Yes.
Q. And did you know who those clothing belonged to?
A. No.
Q. Did you make any effort to find out whose clothing they
were?
A. No, that's not part of the search.
Q. Okay.  And then you searched the kitchen, correct?
A. Yes.
Q. The kitchen was an average kitchen with kitchen-related
things in it, correct?
A. It was a very nice kitchen with kitchen-related things in
it, yes.
Q. Okay.  But there was food there on the counter, correct?
A. There was food.  I don't recall specifically what the food
was.
Q. Okay.  And after you searched the kitchen, you searched the
other rooms, correct?

98
          SOUTHERN DISTRICT REPORTERS, P.C.
            (212) 805-0300
O5O1GUO3                 McNamara - Cross
A. I did not search.
Q. Well, you testified to a lot of photographs during the
search, so I apologize.
You supervised the search where those rooms were
searched, correct?
A. Yes, ma'am, yes.
Q. Okay.  Let's take a look at the photographs of the garage,
shall we, so that we can talk about that red Lamborghini.
Did you enter the garage to look for the red
Lamborghini?
A. I entered through the garage but not to look for the
Lamborghini.
Q. And is it fair to say that you had emailed with your team
about a search warrant for that particular Lamborghini,
correct?
A. The seizure warrant for the Lamborghini was included, yes.
Q. You emailed about the seizure warrant, correct?
A. I emailed the entire team, the search warrant and the
seizure warrant.
Q. Okay.  And you had the seizure warrant for the car
separately discussed, right?  It was an important issue for
you, correct?
MR. FINKEL:  Objection.  Vagueness.
THE COURT:  What is the question?
Q. Sure.  You were specifically told to look for a red

99
          SOUTHERN DISTRICT REPORTERS, P.C.
            (212) 805-0300
O5O1GUO3                 McNamara - Cross
Lamborghini, correct?
A. No.  It was——we had a seizure warrant for the Lamborghini,
but nobody said:  Make sure you find the Lamborghini.
Q. Okay.  So there was a specific seizure warrant for the car,
the Lamborghini, right?
A. Yes.
Q. You were told it was red, correct?
A. I don't recall.
Q. Okay.
A. I know it had the VIN number on the seizure warrant.  I
don't recall if it had the color.
MS. SHROFF:  Okay.  If I could just have 95 pulled up,
please.
Q. And that's the car.  Did you actually view the car in this
state?
A. I'm sorry.  I don't understand.  The state?  In
Connecticut, is it?
Q. No.  I mean covered.
A. Oh, no.
Q. You didn't see it when it was covered, correct?
A. No, I did not.  That's one of the entry photos.
Q. Okay.  And the person who took this photo, this is how they
found the car, correct?
A. Yes.
Q. The car was covered with this black thing on the top,

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          SOUTHERN DISTRICT REPORTERS, P.C.
            (212) 805-0300
O5O1GUO3                 McNamara - Cross
correct?
A. Yes.
Q. And it's plugged into——there's a wire going into the car,
correct?  
A. Yes.
Q. And then the wire is plugged in, correct?
A. Yeah, it looks plugged in.
Q. Right.  I don't drive so I don't know, but does that mean
the car is charging?
A. I would——I believe that's to keep the battery charged.
Q. To keep the battery charged, correct?
A. Yes.
Q. Okay.  And this was one of many garages that was there,
correct?
A. There were two garages.
Q. Right.  And in this garage then there's somebody who's
obviously working out so there's some kind of workout equipment
on the right, correct?
A. Yes.
Q. And then this is usual stuff you would find in somebody's
home, right?
MR. FINKEL:  Objection as to the form.
THE COURT:  Overruled.  You may answer.
A. Yes, it's typical items from a garage.
Q. The garage wasn't locked, correct?

101
          SOUTHERN DISTRICT REPORTERS, P.C.
            (212) 805-0300
O5O1GUO3                 McNamara - Cross
A. I don't know that.
MS. SHROFF:  Okay.  And then if I could have the
uncovered version of the car, please.
Q. And that's what the car looked like, correct?
A. Yes.
Q. Okay.  And you see that little white thing on the hoodie
part?
A. Yes.
Q. What's that for?
A. I don't know.
Q. Okay.  Did you search the car at all?
A. I did not.
Q. Did you talk to or——talk to the person who you were
supervising that was searching the car?
A. Yes.
Q. Okay.  And did they tell you if they found a driver's
license in the car?
A. They did not.
Q. Did they tell you if they found anything related to Miles
Guo in the car?
A. No.
Q. Did they tell you they found his clothing in the car?
A. No.
Q. Did they tell you they found anything in the car?
A. No.

102
          SOUTHERN DISTRICT REPORTERS, P.C.
            (212) 805-0300
O5O1GUO3                 McNamara - Cross
MS. SHROFF:  And let me see if I could just get those
keys, please.
Q. This is Government Exhibit 36, correct?  You testified
about these keys?
A. Yes.
Q. Okay.  You didn't recover the keys, right?
A. I did not.
Q. You don't know who recovered the keys, correct?
A. I——there were two searchers in that room.  I don't recall
which one recovered the keys.
Q. Okay.  So somebody gave you the keys and here they are in
the courtroom, correct?
A. Yes.
Q. Okay.  And you testified to these keys, right?
A. Yes.
Q. Okay.  And you testified to them because the government
showed them to you when you were preparing for your testimony
here today, correct?
A. I don't understand the question.  I'm sorry.
Q. Sure.  They showed you these keys when they prepped you,
right?
A. They showed me these keys, yes.
Q. And they prepped you, right, for your testimony here today?
A. Sure, yes.
Q. You met with them several times, right?

103
          SOUTHERN DISTRICT REPORTERS, P.C.
            (212) 805-0300
O5O1GUO3                 McNamara - Cross
A. Yes.
Q. You met with them this morning, correct?
A. Yes.
Q. Twice this morning, or once?  How many times?
A. Once, I believe.
Q. You believe once?
A. I believe once, yes.
Q. Okay.  And then they told you to come in early so that they
could prep you, right?
A. I believe so.
Q. They sent you a text?
A. Text or an email.  I'm not sure.
Q. All right.  Well, here, let me help you out.
A. Okay.
Q. Did you keep a note of how many times it is you met with
these prosecutors to prepare for your testimony here today?
A. No.
Q. Do you know if it was more than five times?
A. I don't know.
Q. How many times in the last two days did you meet with them;
do you remember?
A. I don't know if I met with them yesterday.
Q. Let me talk to you a little bit about these keys.
A. Mm-hmm.
Q. I'm going to leave them right here.

104
          SOUTHERN DISTRICT REPORTERS, P.C.
            (212) 805-0300
O5O1GUO3                 McNamara - Cross
There's an evidence tag on those keys, correct?
A. There's a tag.  I'm not sure what——what kind of tag this
is.
Q. Okay.  But it's a tag put on by your people, right?  That
tag wasn't on the keys when you first——when you got the keys,
right?
A. I have no idea who put this tag on.  They were not on the
keys at the time.
Q. Okay.  And the keys were just exactly like the way you see
them in their envelope, right?
A. I——I don't know.
Q. You don't know if it had a keychain on it, correct?
A. I don't know.
Q. You don't know if it had a nametag on it, correct?
A. I don't know.
Q. When was the first time the prosecutor showed you those
keys?
A. Today.
Q. This morning.
A. Yes.
Q. Okay.  And he showed you those keys and he told you you
were going to testify to them, correct?
A. He asked me about the keys.
MS. SHROFF:  Okay.  See if this refreshes your
recollection.

105
          SOUTHERN DISTRICT REPORTERS, P.C.
            (212) 805-0300
O5O1GUO3                 McNamara - Cross
MR. FINKEL:  Your Honor, there's no failure of
recollection.  Objection.
MS. SHROFF:  I believe she couldn't remember——
THE COURT:  No, she did not say she could not recall.
Sustained.
BY MS. SHROFF:  
Q. You testified earlier that you couldn't recall, right,
whether it was by email or by text that they asked you to come
in this morning?
A. Yes.
Q. Okay.  Does that refresh your recollection, ma'am?
A. Yes, it looks like a text.
Q. Okay.  And they texted you to come in early so they could
prepare you, correct?
A. Yes.
Q. Okay.  And you came in early 'cause you wanted to be
prepared for testimony here today, right?
A. That, and it's two——it's two and a half hours to get here
from Connecticut, so I had to be here before the traffic.
Q. Okay.  But you met with them, right?
A. Yes.
Q. Okay.  And they asked you about those keys, correct?
A. Yes.
Q. They asked you who recovered them and you said, I don't
know, correct?

106
          SOUTHERN DISTRICT REPORTERS, P.C.
            (212) 805-0300
O5O1GUO3                 McNamara - Cross
A. Correct.
Q. And they asked you where they were recovered and you said,
I don't know, correct?
A. I know which room they were in.  I said it was the room
that——where it had——it's like an office and it had cam——display
monitors with——for the security cameras.
Q. And the security, that's where you were told that the keys
were put, correct?
A. That's where the keys were found.
Q. Okay.  So the keys were not found in the garage where the
car was, correct?
A. Correct.
Q. They were not found inside the car where one would leave
them if they used the car every day, correct?
MR. FINKEL:  Objection, as to form.
THE COURT:  Sustained.
Q. Were they found inside the car?
A. No.
MS. SHROFF:  If you could just show her, please, and
the jury, No. 95.
Q. Did somebody actually drive the car out of the garage when
they seized it?
A. I don't know.
MS. SHROFF:  If somebody could please put up 58.
Q. You testified as to this photograph, correct?

107
          SOUTHERN DISTRICT REPORTERS, P.C.
            (212) 805-0300
O5O1GUO3                 McNamara - Cross
A. Yes.
Q. And could you tell me, please——on the right side you see a
flag, correct?
A. Yes.
Q. Did you know what that flag was for?
A. No.  I have no idea.
Q. Was there a nametag on the flag?
A. I don't know.
Q. Was there a notation New Federal State of China anywhere
telling you about that flag?
A. I don't know anything about this flag.
Q. Okay.  Look on the left side of that photograph, please.
Do you see that big yellow——the big white round thing?
A. Yes.
Q. What was that?
A. I don't know.
Q. That's something that was used to broadcast with; is that
correct?
A. I don't know.
MS. SHROFF:  Okay.  Could you zoom out, please.
Q. Did you conclude that this was an office space or a working
space?
A. It looks to me like some type of studio-type setup.
Q. It looked like a recording studio, correct?
A. Something like that, yes.

108
          SOUTHERN DISTRICT REPORTERS, P.C.
            (212) 805-0300
O5O1GUO3                 McNamara - Cross
Q. It looked like a place from where someone would broadcast,
correct?
A. Yes.
MS. SHROFF:  May I please have No. 59.
Q. Okay.  This is a better picture, perhaps.
So there's recording equipment right there, correct?
A. Yes.
Q. There's a computer monitor, correct?
A. Yes.
Q. A chair?
A. Yes.
Q. And during your search did you try to find out if these
were working equipment?
A. No.
Q. Okay.  Thank you very much.
MS. SHROFF:  May I have 83, please.
Q. Now you testified about certain documents that the
government had you read, right?
A. I read them.
Q. Right.  You read them out loud, the loan agreements,
correct?
A. Yes.
Q. Okay.  How much paperwork did your team recover from that
home?
A. Printed paper?

109
          SOUTHERN DISTRICT REPORTERS, P.C.
            (212) 805-0300
O5O1GUO3                 McNamara - Cross
Q. Yes.
A. Not a lot.
Q. Not a lot?
A. No.
Q. Okay.  There was a loan agreement that you read out loud
for him, correct?
A. Yes.
Q. Okay.  Did you know what the loan agreement was about?
A. No.
Q. Do you know where the loan agreement was kept?
A. No.
Q. Do you know who kept the loan agreement in which room?
A. No.
Q. Do you know if it was Mr. Guo's room?
A. No.
Q. Do you know if it was even in the kitchen or the toilet,
you have no idea where it was, right?
A. We could——you could go back to the——the evidence log.
Q. Do you know?
A. Do I know?  No.  I did not search.
Q. Okay.  And you testified and read documents that the
government asked you to read, correct?
A. Yes.
Q. You'd never read them before, correct?
A. Correct.

110
          SOUTHERN DISTRICT REPORTERS, P.C.
            (212) 805-0300
O5O1GUO3                 McNamara - Cross
Q. You didn't choose which documents to read to the jury,
correct?
A. I did not.
Q. You don't know what other documents were recovered in the
home 'cause you didn't do the search, correct?
A. That's correct.
Q. Okay.  You didn't recover Mr. Guo's wallet in there,
correct?
A. I don't recall a wallet being found.
Q. Passport?
A. No.
Q. Sitting here today, do you recall if there was even a
driver's license in his name?
A. I don't know.
Q. How about a learner's permit?
A. No, I did not see any of that.
Q. So your memory is basically limited to what the government
showed you to prepare you for the trial here today.
MR. FINKEL:  Object to form.
THE COURT:  You may answer.
A. No.  I remember what I did when I was there.  
Q. Right.  But all you did was supervise, right?
A. That's correct.
Q. You're not the one who searched for anything at all,
correct?

111
          SOUTHERN DISTRICT REPORTERS, P.C.
            (212) 805-0300
O5O1GUO3                 McNamara - Cross
A. That's correct.
Q. You recovered none of the things that you've testified to
today, including the keys, correct?
A. That's correct.
Q. You testified about a suit with the name Brioni on it,
correct?
A. I think it was a paper, piece of paper.
Q. Do you remember testifying about a hanger with the name
Brioni on it?
A. I saw the picture.  I don't think I was asked about that.
Q. Okay.  Do you know what Brioni is?
A. I have no idea.
Q. Do you know if there were suits recovered in that home,
men's suits?
A. Suits were not on the list of items to be seized.  We
didn't take any clothing.
Q. My question was in——okay.  Did you see any of the suits?
A. Yes.
Q. Okay.  Did you know how old they were?
A. No.
Q. Do you know if they were from 2010, versus 2020?
A. No.
Q. Do you know if they were his suits or somebody else's
suits?
A. No.

112
          SOUTHERN DISTRICT REPORTERS, P.C.
            (212) 805-0300
O5O1GUO3                 McNamara - Cross
Q. Now you remember reading a document from which they made
you read names and then you read something called Voice of Guo,
Voice of Good, correct?
A. Yes.
Q. Okay.  Do you know what that meant?
A. No.
Q. Do you know what Voice of Guo is?
A. No.
Q. Do you know what Voice of Good is?
A. No.
Q. Do you know what Saraca is?
A. No.
Q. This is the hanger I'm talking about.  You testified as to
this hanger, right, this photograph?
A. I saw the photograph.  I——yes.
Q. Right.  You never saw the hanger, though, right?
A. I did not.
Q. Okay.  So you're only testifying here about the photographs
that somebody else took and gave to you, correct?
A. Yes.
MS. SHROFF:  Okay.  May I have, please, No. 176.
Q. Okay.  You testified about this document, correct?
A. Yes.
Q. Mr. Finkel asked you to read it out loud and you read it
out loud to the jury, correct?

113
          SOUTHERN DISTRICT REPORTERS, P.C.
            (212) 805-0300
O5O1GUO3                 McNamara - Cross
A. Correct.
Q. Okay.  What does it mean Designer No. 1 Whistle?
A. I have no idea.
Q. Pants 100, do you know what it means?
A. I do not.
Q. Hat 200, do you know what it means?
A. I do not.
Q. Sitting here today, do you know if these pants and hats
were supposed to be part of a swag bag?
A. No.
Q. You don't know anything about what you read to the jury,
correct?
A. That's correct.
Q. All you can tell them is that there was this piece of paper
found by somebody in your team and they took a photograph, and
you recited that to the jury.
MR. FINKEL:  Objection as to form.
THE COURT:  Overruled.  You may answer.
A. I apologize.  I've already forgotten the question.
Q. All you know is that somebody took a photograph, they took
that photograph that you then looked at, the government had you
read out loud to this jury and you did that, correct?
A. Yes.
Q. Okay.  Could I have 184, please.
You see that yellow sticky on this exhibit that you

114
          SOUTHERN DISTRICT REPORTERS, P.C.
            (212) 805-0300
O5O1GUO3                 McNamara - Cross
testified about?
A. Yes.
Q. "For Matthew, new insurance cards for all four vehicles
effective," or "effect 4/1/20," correct?
A. Yes.
Q. Do you know who wrote that Post-it?
A. No.
MS. SHROFF:  And if you scroll down, please.
Q. That's the entire document, right?
A. I don't know.
Q. You don't know if these documents were recovered together,
correct?
A. I don't know.
Q. You don't know if they were in one place together, correct?
A. I don't know.
Q. You don't know who filled out the documents, correct?
A. Who filled out——I don't understand, who filled out.
Q. You don't know whose handwriting is anywhere on these
documents.
A. Oh, no.
Q. Somebody showed you a photograph, you're testifying about
the photograph, right?
A. Yes.
MS. SHROFF:  Okay.  You can take that down.
If I could just have 393.

115
          SOUTHERN DISTRICT REPORTERS, P.C.
            (212) 805-0300
O5O1GUO3                 McNamara - Cross
MR. FINKEL:  I don't believe 393 is in evidence.
MS. SHROFF:  Okay.  174.
Q. You see this document?  You also testified to this,
correct?
A. Yes.
Q. Lies told by Miles Guo.  You have no idea what date they're
talking about, correct?
A. Correct.
Q. You don't know what questions and answers this is about,
right?
A. Right.
Q. You don't know who has preselected questions or what they
are, right?
A. Correct.
Q. You just got up there and read it to the jury because he
told you to, right?
A. That's what I was asked to do, read it.
MS. SHROFF:  Okay.  And could we scroll down.
Q. This is the full page, right?  Do you know where it was
recovered from?
A. No.
MS. SHROFF:  Okay.  You may take that down.
If I could have 129.
Q. You testified to this document?
A. I don't recall.

116
          SOUTHERN DISTRICT REPORTERS, P.C.
            (212) 805-0300
O5O1GUO3                 McNamara - Redirect
Q. Okay.  Then we can take it down.
Is it fair to say, Agent McNamara, that your job was
limited to receiving whatever other people in that house were
looking for and giving to you?
MR. FINKEL:  Object as to form.
THE COURT:  I did not hear that.
MR. FINKEL:  Objection as to form.
THE COURT:  Overruled.  You may answer.
A. Nobody gave me anything.  I managed the search.  The
searchers searched, the photographers took the photographs,
they entered the items into our evidence list so we had a list
of what was taken, and they packaged it.  They didn't hand them
to me to do that.
Q. Okay.  Fair enough.  And the search you said took four
hours, right?
A. Approximately four hours, yes.
Q. Nobody bothered you during your search, correct?
A. No.
Q. And then the search was complete, you left?
A. Completely?
Q. When the search was complete, you left, right?
A. Yes.
MS. SHROFF:  Okay.  Thank you very much.
THE COURT:  Redirect?
MR. FINKEL:  Very briefly.

117
          SOUTHERN DISTRICT REPORTERS, P.C.
            (212) 805-0300
O5O1GUO3                 McNamara - Redirect
REDIRECT EXAMINATION 
BY MR. FINKEL:  
Q. Special Agent McNamara, what was the role of you and your
team on March 15, 2023?
A. To help execute the search warrant.
Q. And when documents or physical items are recovered from a
search, what, if anything, does the FBI do to keep track of
where those materials come from?
A. So they're seized by the seizing agent, and then it starts
a chain of custody.
Q. And can you explain a little bit about how it's tracked
where particular materials are recovered from.
Like which room, for example.
A. Oh, sure.  So when someone finds an item in a room, we send
the photographer, they take a photo in place.  When we do our
photos, we give each room a letter, so when that item is
recovered, we'll say, give a description of the item, say, you
know, cellphone serial number so and so was located in room B
on desk.  And then we put the people who——the two people who
actually found and witnessed that item.
Q. And was that procedure followed on March 15, 2023?
A. Yes.
Q. And Special Agent McNamara, when the FBI leaves, what
precautions or what's the policy and procedures right before
leaving?  What does the FBI do?

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A. With the evidence?
Q. The evidence and the photographs.
A. Oh.  So there is a seizing agent, so there's one person
that takes custody of the evidence, and they start the chain of
custody, and they bring that evidence to the evidence room,
where it gets logged in and put into the case file.  The
photographs, like I——I believe I said earlier, the photographer
takes the SD card and burns it directly to disks, so we don't
put it in a computer first, and then we make an original copy
that goes into the case file, a backup of the original copy
into the case file, a copy for the case agent, and then, should
we need another copy for the lab, or for sending stuff to
forensics, for forensics, then we make a fourth copy.
Q. Special Agent McNamara, do you know what stats FBI, the New
York FBI investigative team, took prior to the search on
March 15, 2023, with respect to this case?
A. No.
Q. Do you know what steps FBI——what investigative steps they
took after March 15th of 2023?
A. No.
Q. Do you know if the case agent——what's a case agent?
A. It's usually——there's usually one, sometimes more, assigned
as the——the responsible person for that case.
Q. And do you know if the case agents——are you a case agent on
this case?

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A. No.
Q. Do you know if the case agents know what Saraca means?
A. I have no idea.
Q. Do you know if the case agents have reviewed those
documents?
A. I don't know.
Q. And discussed them with the U.S. Attorney's Office?
A. I don't know.
Q. Whether the case agents have gotten other search warrants?
MS. SHROFF:  Your Honor, the case agent isn't
testifying here today.
THE COURT:  He's asked whether she knows what the case
agent has done or not done.  She may answer.
A. I do not know.
Q. And Special Agent McNamara, aside from the search March 15,
2023, do you have any other involvement in this matter?
A. No.
MR. FINKEL:  Thank you, Special Agent McNamara.
THE COURT:  Recross?
MS. SHROFF:  Very briefly.
RECROSS EXAMINATION 
BY MS. SHROFF:  
Q. You took every precaution to make sure that the evidence
was properly documented, correct?
A. Yes.

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Q. And you made sure to take photographs of the evidence,
correct?
A. Yes.
Q. Or had the photographs taken, correct?
A. Yes.
Q. And then you made sure those photographs were properly kept
in a file, correct?
A. Yes.
Q. And after taking all of those steps, when you reviewed the
evidence, there was nothing with a singular name tied to that
Lamborghini that involved Miles Guo, correct?
MR. FINKEL:  Objection.
THE COURT:  If you know the answer, you may answer.
A. I do not know.
Q. There was not a single title to the Lamborghini in Miles
Guo's name, correct?
A. I don't know.
Q. You read the title, didn't you?
A. I read that title.  I don't know if there were other
titles.  I don't know.
Q. So you are only——your knowledge for this jury is only
limited to what he told you to testify about.
A. No.
Q. Well, you tell me.  If you know more and you took all these
detailed steps, could you tell this jury if you recovered any

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singular document linking the Lamborghini to Miles Guo?
A. I do not know.
Q. You didn't find anything linking the cars to the
Lamborghini to Miles Guo.
A. The cars to the Lambor——
Q. The keys.
A. Oh, the keys.  I thought you said cars.  No.
Q. And nothing in the car, not a single piece of clothing, not
a driver's license, linked that car to Miles Guo, correct?
A. Not that I'm aware of.
Q. Well, you can only testify to what you're aware of, ma'am.
A. Right.
Q. That's a no.  The answer is no?  Is the answer no?
A. I've forgotten the question now.
Q. There is nothing that you found linking that Lamborghini to
Miles Guo, correct?
A. Nothing of the search of 373, correct.
Q. That's where the car was, correct?
A. Yes.
Q. Thank you.
MR. FINKEL:  One question.
THE COURT:  Re-redirect?
REDIRECT EXAMINATION 
BY MR. FINKEL:  
Q. Special Agent McNamara, do you know if the FBI New York

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team has a video, or recovered a video of Miles Guo driving the
Lamborghini that was found at 373 Taconic on March 15, 2023?
A. I do not know.
MR. FINKEL:  Nothing further.
THE COURT:  Re-recross?
RECROSS EXAMINATION 
BY MS. SHROFF:  
Q. Driving a car doesn't mean you own a car, correct?  As a
Special Agent you'd be able to testify to that, right?
A. Yes.
MS. SHROFF:  Thank you.
THE COURT:  Thank you.  You may step out.  And the
government may call its next witness.
(Witness excused) 
MS. MURRAY:  Thank you, your Honor.  The government
calls Louie Bonsukan.
THE LAW CLERK:  Please raise your right hand.
(Witness sworn) 
THE COURT:  Please state your name and spell it.
THE WITNESS:  My name is Louie Bonsukan.  It's
L-O-U-I-E, last name, Bonsukan, B-O-N-S-U-K-A-N.
THE COURT:  You may inquire.
MS. MURRAY:  Thank you, your Honor.

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 LOUIE BONSUKAN, 
     called as a witness by the Government, 
     having been duly sworn, testified as follows: 
DIRECT EXAMINATION 
BY MS. MURRAY:  
Q. Good afternoon, Mr. Bonsukan.
A. Hello.
Q. What kind of work do you do?
A. I'm the finance director for Lamborghini Dallas.
Q. And what are your duties and responsibilities as the
finance director at Lamborghini Dallas?
A. I help facilitate the paperwork on a sale of a vehicle.
Q. How long have you worked at Lamborghini Dallas?
A. A little over 13 years.
Q. Approximately how many Lamborghinis does Lamborghini Dallas
sell in a given month, on average?
A. Probably an average of 35 cars a month.
Q. I'd like to direct your attention to September of 2021.
Were you involved with the sale of a Lamborghini in that month
to a customer known as G/CLUBS?
A. Yes.
Q. What was your role in that sale?
A. I helped facilitate the paperwork on that sale with the
customer.
MS. MURRAY:  Ms. Loftus, if you could please show the

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witness what's been marked as Government Exhibit BR460.  And
scroll through page 2 and beyond.
Q. Mr. Bonsukan, do you recognize Government Exhibit BR460?
A. Yes.
Q. Have you reviewed this exhibit before?
A. Yes.
Q. Generally speaking, what is in Government Exhibit BR460?
A. It's a motor vehicle buyer's order.  It basically shows the
sale of the vehicle and who sold it.
MS. MURRAY:  And just scrolling through a couple of
the other pages of this exhibit, Ms. Loftus.  
Q. At a high level, Mr. Bonsukan, are these business records
of Lamborghini Dallas?
A. Yes.
Q. Are you familiar with these types of documents?
A. Yes.
Q. Fair to say it's a regular part of your business to receive
and maintain these documents?
A. Yes.
MS. MURRAY:  Your Honor, the government offers
Government Exhibit BR460.
MS. SHROFF:  We have no objection, your Honor.
THE COURT:  It is admitted.
(Government's Exhibit BR460 received in evidence) 
MS. MURRAY:  Ms. Loftus, can you please publish

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page 2.
THE COURT:  And Mr. Bonsukan, if you would raise your
voice and speak into the microphone.
THE WITNESS:  Yes, ma'am.  Yes, your Honor.
MS. MURRAY:  And if we could zoom in on the top
portion, please, Ms. Loftus.
BY MS. MURRAY:  
Q. All right.  Mr. Bonsukan, this is one of the business
records of Lamborghini Dallas.  What is this particular
document?
A. The motor vehicle buyer's order.
Q. And looking on the left, who was the seller for this
particular car?
A. Lamborghini Dallas.
Q. And the buyer?
A. The buyer is G Club International Ltd.
Q. What is the date of this buyer's order?
A. September 13, 2021.
Q. I want to look now on the left, the Description of Sale
Unit.  Can you describe for the jury what type of Lamborghini
this was.
A. It's a Lamborghini Aventador SVJ Roadster.
Q. Looking to the right, what color was that Lamborghini
Aventador?
A. It's red.

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Q. And there's a field call Stock No., or stock number.  What
information is reflected there?
A. The stock number is a number that we give a——as a
dealership to a particular vehicle that we're selling rather
than using a VIN number.
Q. So you mentioned VIN number.  What's a VIN number?
A. The vehicle identification number, which identifies the
vehicle.
Q. Looking a bit further down on Description of Sale Unit, is
there a VIN number listed here for this particular Lamborghini?
A. Yes.
Q. And what are the last three digits of that VIN number?
A. Last three is 393.
Q. What year was this Lamborghini?
A. 2021.
MS. MURRAY:  Ms. Loftus, if we could zoom out and then
zoom in on the box on the right, Price of Unit, down to the
bottom, please.
Q. Mr. Bonsukan, at the top, what is the price of this
particular Lamborghini?
A. $829,999.
Q. And then looking down toward the bottom, what is the total
price when you add in taxes and fees?
A. $832,075.
Q. Sorry.  Could you read that amount again, please, sir.

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A. $832,000.75.
Q. Thank you.
MS. MURRAY:  And Ms. Loftus, if we could go to the
bottom of this page where there's a signature line, please.
Q. Mr. Bonsukan, do you recognize the seller's signature here?
A. Yes, that's mine.
Q. And what was the date that you signed this particular
contract of sale?
A. September 13, 2021.
MS. MURRAY:  We can take that down, Ms. Loftus.
And let's pull up what's in evidence as Government
Exhibits CT38, 37, and 40.
Q. Mr. Bonsukan, starting here on the left, top left, with
Government Exhibit CT38, do you recognize the car depicted in
this photograph?
A. Yes, that's a Lamborghini Aventador.
Q. And what color is it?
A. It's red.
MS. MURRAY:  Ms. Loftus, we can take those down, and
let's put up Government Exhibits CT42 and 43, please, which are
in evidence.
Q. Starting here on the left, Mr. Bonsukan, Government Exhibit
CT42, can you describe for the jury, please, what it is we're
looking at in that photograph.
A. This is the driver's side of the vehicle; the door, which

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is the scissor door, which raises up, shows the VIN plate on
the vehicle.
Q. Can you just describe a bit more about how the scissor door
operates, please.
A. So it hinges, as——the scissor door normally hinges up and
raises the door in this particular manner, just like this one,
rather than a normal door on a vehicle, which swings out, like
if you're opening and closing a door.
Q. And the VIN plate that you mentioned, where in the photo on
the left do we see that?
A. It's the black plate that's right on the——the scissor door.
MS. MURRAY:  And Ms. Loftus, on the right where we
have a zoomed-in portion of that black plate, that VIN plate,
can we zoom in on that even further, please, the VIN number.
Q. Mr. Bonsukan, what are the last three digits of the VIN
number of this Lamborghini?
A. 393.
MS. MURRAY:  Ms. Loftus, if we could now, on the left
side, pull up Government Exhibit BR460 at page 2, and zoom in
on the VIN field.
And then on the right photo, similarly, zoom in on the
VIN field.
Q. All right.  Mr. Bonsukan, so on the top here is a zoomed-in
version of the VIN of the car we were just looking at
photographs of.  Could you please read that VIN number, the

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vehicle identification number, into the record.
A. Z as in zebra, H as in Henry, W as in William, U as in
umbrella, N as in Nancy, Z as in zebra, D as in David, 2, M as
in Mary, L as in Lima, A as in alpha, 10393.
Q. And then looking at the one on the bottom here,
Mr. Bonsukan, which is from the contract of sale from
Lamborghini Dallas to G Club International, is that the same
VIN number that was on the car depicted in the photograph?
A. Yes.
Q. And based on your work at Lamborghini Dallas for the past
13 years or so, do you have an understanding whether VIN
numbers are unique to a particular vehicle?
A. They are.
MS. MURRAY:  Ms. Loftus, we can take those down.
And let's please show the witness what's been marked
as Government Exhibit GX GC295, at page 10.
Q. Mr. Bonsukan, are you able to see what's in Government
Exhibit GC295 here, page 10?
A. Yes.
Q. Do you recognize it?
A. I do.
Q. How do you recognize it?
A. It's a——it has my name on it.  It's a normal letter that I
send out to a client along with the documents that we send out
to them for signature.

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MS. MURRAY:  Your Honor, the government offers
Government Exhibit GC295.
THE COURT:  Any objection?
MS. SHROFF:  No, your Honor.
THE COURT:  It is admitted.
(Government's Exhibit GC295 received in evidence) 
MS. MURRAY:  Can we please publish that.
BY MS. MURRAY:  
Q. Mr. Bonsukan, what is the date of this particular letter?
A. September 14, 2021.
Q. And to whom is it addressed?
A. Mr. Horan.
Q. Looking at the signature block here, is that your signature
or your electronic signature on this letter?
A. Yes.
Q. And generally speaking, what was the purpose of this
letter?
A. It basically explains, thanking the client for purchasing a
vehicle and then things that's needed to be done in order to
facilitate the paperwork and then to instruct them to FedEx the
documents back.
Q. And does this particular letter relate to the contract of
sale dated September 13, 2021, that we just looked at for G
Club International?
A. Yes.

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MS. MURRAY:  Ms. Loftus, let's take that down and put
up Government Exhibit BR460 again, at page 5, please.
Q. What type of document is this, Mr. Bonsukan?
A. This is internal record for our dealership when a——when
funds are received, from a client.
Q. And what is the date listed on the top right of this
particular document?
A. September 14, 2021.
Q. Looking over on the left side, it indicates Cash Received
From, do you see that?
A. Yes.
Q. Who sent the money to Lamborghini Dallas, as reflected
here?
A. It shows G Club Hold Co. 1, LLC.
(Continued on next page)

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BY MS. MURRAY:  
Q. And then is that crossed out in part and there is something
written over it?
A. Yes.
Q. What is the corrected name listed here?
A. G Club International LLC.
Q. Looking at the payment amount here just below, what is the
total amount of the electronic transfer from G Club
International?
A. $832,000.75.
Q. And the wire detail that's in bold below, wire from, do you
see that?
A. Yes.
Q. Can you read what that reflects?
A. Wire from Mercantile Bank for G Club International Ltd.
MS. MURRAY:  Let's go to the next page please,
Ms. Loftus.
Q. What is this, Mr. Bonsukan?
A. This is a wire confirmation that's emailed to me from
JPMorgan Chase Bank, which is our bank, that notifies when a
wire was received.
Q. And what is the date of this wire notification?
A. Monday, September 13th, 2021.
Q. Looking down at the body of this email, what bank was this
wire received from?

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A. Received from the Reserve Trust Co, Greenwood Village,
Colorado.
Q. And then a few lines down, there's a beneficiary and then a
B/O customer.  What does that reflect?
A. Mercantile Bank International, 644 Fernandez Juncos Avenue,
Third Flo, San Juan, Puerto Rico.
MS. MURRAY:  Ms. Loftus, let's go to page 8, please.
If we could zoom in on the text.  Thank you.  
Q. It's a little hard to read, Mr. Bonsukan, but what kind of
information is reflected on this business record?
A. This is looks like wire instructions.
Q. And can you read the bank name listed at the top here?
A. Bank name is Reserve Trust Company.
Q. What about the beneficiary account name?
A. Mercantile Bank International.
Q. And finally, for further credit down at the bottom, what's
listed under MBI client account?
A. G Club International Limited.
Q. And if you could read the last five digits of that MBI
client account number for G Club International Limited?
A. 10103.
MS. MURRAY:  All right.  Ms. Loftus, can we please go
to page -- starting on page 19 of BR-460.
Q. Mr. Bonsukan, do you see this email that is reflected here?
A. Yes.

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MS. MURRAY:  If we could scroll down, Ms. Loftus.
This is part of a chain.  We're going to start with some of the
earlier messages in this chain.  Looking here -- thank you,
Ms. Loftus.
Q. This is an email, September 9, 2021.  Can you tell us who
that's sent from?
A. It's sent from Max.
Q. And to whom was it sent?
A. To Mike Durkey.
Q. Who is Mike Durkey?
A. Previous salesperson for Lamborghini Dallas.
Q. After the bracket external, what is the subject line of
this email?
A. G Club Hold Co. LC732-Lambo SVJ Roadster.
Q. And LC 732, what does that indicate?
A. That's the stock number in our inventory for this
particular vehicle.
Q. Can you please read the body of this email from Max to Mike
Durkey at Dallas Lamborghini?
A. "Hi, Mike.  How much is the delivery to Connecticut?"
Q. And there's an indication of the type of email account that
Max sent the email from.  Can you please read that?
A. Sent from ProtonMail Secure Email.
MS. MURRAY:  All right.  Ms. Loftus, let's scroll up a
bit, please, so we go later in time in this email chain.

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Q. All right.  Starting with the email at the top there from
Max to Mike Durkey, can you read the content of this email,
please, Mr. Bonsukan?
A. It says:  "Can you help arrange a delivery?  Also, I should
have the resolution and driver's license tomorrow.  Please hold
the vehicle.  Thank you."
Q. Mr. Bonsukan, do you know what the reference to
"resolution" reflects?
A. Yes.  It basically -- the resolution is it shows who the
directors or officers or members of a particular business.
Q. And in the course of a sale to a corporate entity or a
company, is that the type of document that Lamborghini Dallas
typically collects in connection with a sale?
A. Yes.
Q. Why?
A. We want to make sure whoever is buying the vehicle is the
one that's able to sign off for the vehicle.
MS. MURRAY:  All right.  Ms. Loftus, let's keep going
in this email chain, please.  So we'll focus in from exactly
that through to the bottom of that email.
Q. So if you kind of start in the middle here, Mr. Bonsukan,
because this is forwarded.  Start with the email from Max
again.  This is September 10, 2021.  Can you read the content
of that email to Mike Durkey, please.
A. "Hi, Mike.  Attached is the passport which I'll text you

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the password separately.  Also, attached is the correct entity
name.  Please reissue the documents with the corrected name.
Thank you.  Kind regards, Max."
Q. And that email is forwarded to you which we can see at the
top of this portion.  Do you see that, Mike Durkey to you?
A. Yes.
Q. And what does he -- what does Mike Durkey write to you?
A. "Passport secured by top secret password:  123456."
MS. MURRAY:  Thank you, Ms. Loftus.  If we could keep
going up in the chain.  All right.  And now I'd like to focus
on this bottom half from Mr. Bonsukan to a Max Krasner account.
Q. All right.  Mr. Bonsukan, this is about a month later
October 19, 2021?
MS. SHROFF:  Objection to the testifying.
THE COURT:  You can ask him what date he sees.
Q. Mr. Bonsukan, can you please read the date of this email?
A. The date is October 19, 2021.
Q. Thank you.  And who sent this email?
A. It was sent from me to Max Krasner.
Q. And what is the email address to which it was sent?
A. Max -- M-A-X-K-R-A-S-N-E-R at ProtonMail.com.
Q. Who's Max Krasner?
A. Probably one of the agents for -- that helped in regards to
negotiating with Mike Durkey.
Q. And negotiating with respect to what sale, if any?

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A. The Aventador SVJ Roadster.
Q. And that was the sale to G Club; is that correct?
A. To G Club.
Q. Did you ever speak personally with Max Krasner?
A. No.
Q. Did there come a time when you communicated with Max
Krasner regarding the sale?
A. Through email.
Q. You could read this email that you sent to Max Krasner,
please.
A. "Hi, Max.  Here are the signed copies of the buyer's order,
odometer, and dealer reassignment form I have received with the
Wilmington, Delaware address.  This was the address Mike gave
to me.  Once we have title in hand, then we will send it to you
at the 162 East 64th, New York, New York, 10065 address with
signature required on the FedEx.  We will be on the lookout
tomorrow for the title.  If we do not receive, then we will
apply for a duplicate.  Best regards," and my signature.
Q. Mr. Bonsukan, what is a title as it's indicated here?
A. A title is a form given for a particular vehicle; basically
it's the ownership papers of that particular vehicle.
Q. And what, if anything, does Lamborghini Dallas do with a
title to a car when it sells a car?
A. We reassign the title to the new owner.
MS. MURRAY:  Ms. Loftus, if we could take that down.

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Let's go to page 9 actually of BR-460.  We can zoom in 
on the top half so it's a bit larger. 
Q. Mr. Bonsukan, what is this document, which is part of the
Lamborghini Dallas records we've been looking at?
A. Shows register of directors for G Club International
Limited.
Q. And on this document, who is listed as the named director
of G Club International Limited?
A. It shows Haoran He.
Q. Looking to the right column, personal details, what was
Haoran He's place of birth?
A. China.
Q. And nationality?
A. British.
Q. And further right, on what date was Haoran He appointed
director of G Club International Limited?
A. October 16, 2020.
Q. Mr. Bonsukan, have you ever spoken with Haoran He?
A. No.
Q. Have you ever communicated with Haoran He?
A. No.
MS. MURRAY:  Ms. Loftus, let's now go to page 12,
please.
Q. What is this, Mr. Bonsukan?
A. This looks like to be a British passport.

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Q. For what individual?
A. For Haoran He.
MS. MURRAY:  And let's go to page 18, please,
Ms. Loftus.
Q. Again, part of the business records relating to this sale,
what type of document is this, Mr. Bonsukan?
A. This is a shipment received from FedEx.
Q. And what information or what documents would have been
shipped using this shipping receipt in relation to the sale of
that Lamborghini?
A. The title to the vehicle, the Lamborghini Aventador, as
well as odometer statement, some of the other title documents
that's required to transfer.
Q. Now, the "shipping from" field here indicates a certain
company.  Can you read what company that indicates?
A. Yes.  Boardwalk Auto Group.
Q. What affiliation, if any, does Boardwalk Auto Group have
with Lamborghini Dallas?
A. Boardwalk Auto Group is our parent company.  Under that
group we have a number of dealerships, Lamborghini Dallas is
one of them.
Q. Looking on the left, can you please read the "ship to"
information reflected on this FedEx receipt.
A. Ship to attention Max, G Club International.
Q. And the address?

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A. 162 East 64th, New York, New York, 10065.
MS. MURRAY:  And if we could zoom out a little bit,
Ms. Loftus, to see the ship date, please.  Actually, the whole
center portion of this.
Q. What is the ship date of this FedEx package, Mr. Bonsukan?
A. October 27, 2021.
Q. And then looking at billing information here, can you read
what is reflected under "bill transportation to" on the bottom?
A. Bill transportation to:  Lambo-340.  Your reference number,
LC 732.
Q. And that reference number, have we seen that on other
documents we've been looking at today?
A. Yes.
Q. What information is reflected in that reference number as
it's relevant to the G Club Lamborghini?
A. That's the stock number of the Lamborghini Aventador sold
to G Club International.
MS. MURRAY:  We can take that down, Ms. Loftus.  Thank
you.
Q. Mr. Bonsukan, in your role at Lamborghini Dallas, after
you've confirmed a successful wire transfer or transfer of
money and receive requested documents, what, if anything, do
you do next?
A. I package everything up and send it to my accounting office
for processing of the title.

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Q. And how, if at all, are the vehicles delivered to the
customers?
A. Excuse me?
Q. How, if at all, are the vehicles delivered to the
customers, the vehicles?
A. They are normally transported via vehicle transport.
Q. Does Lamborghini Dallas facilitate in the shipment of
vehicles to customers at times?
A. Yes.
MS. MURRAY:  Ms. Loftus, if we could please show the
witness what's marked as Government Exhibit GC-504.
Q. Mr. Bonsukan, at a high level, what type of document is
this?
A. This is a dispatch sheet from -- for the carrier that
transported the Aventador.
Q. Is this the type of record that is maintained in the
ordinary course of business for Lamborghini Dallas?
A. Yes.
MS. MURRAY:  Your Honor, the government offers
Government Exhibit GC-504.
THE COURT:  It is admitted.
(Government's Exhibit GC-504 received in evidence) 
MS. MURRAY:  Thank you.
Can we please publish, Ms. Loftus.  We could zoom in 
on the top half, first going through order information.

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Q. All right, Mr. Bonsukan.  Looking on the right, what is the
business name that's listed there on the right?
A. Boardwalk Motor Sports LLC.
Q. And again, if you could just remind the jury the
affiliation between that company and your store, Lamborghini
Dallas?
A. When they created this account for central dispatch, it's
the parent company of Lamborghini Dallas.
Q. And looking on the left on carrier, what role, if any, does
the carrier have in the shipment of a vehicle?
A. That's the company that actually transported the vehicle.
Q. Under order information here, there's a dispatch date.
What is the dispatch date?
A. September 22nd, 2021.
Q. And the pickup estimate?
A. Pickup estimated date is September 25th, 2021.
Q. And what was the delivery estimate for this particular
shipment?
A. Delivery estimated, September 30th, 2021.
Q. Looking at the top there, order ID, can you read what the
order ID was for this shipment?
A. LC 732.
MS. MURRAY:  Ms. Loftus, we can zoom out and then
focus on the next portion, please.
Q. Now, the vehicle information for this particular vehicle,

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if you could read the year and the car type and model?
A. 2021 Lamborghini Aventador.
Q. And then looking on the right, delivery information, what
is the name for the recipient of that Lamborghini?
A. Max (G Club International).
Q. And to what address was that Lamborghini for G Club
International shipped?
A. 373 Taconic Road, Greenwich, Connecticut, 06831.
MS. MURRAY:  May I have a minute, your Honor, please?
THE COURT:  Yes.
(Counsel conferred) 
Q. Mr. Bonsukan, do you know what G Club is?
A. No.
MS. MURRAY:  Nothing further, your Honor.
THE COURT:  Cross-examination.
CROSS-EXAMINATION 
BY MS. SHROFF:  
Q. How are you doing, Mr. Bonsukan?
A. Good.
Q. You work at Lamborghini Dallas; is that right?
A. I do.
Q. Okay.  Sorry about that.  I can't see you.
And you were the one in charge of this particular 
sale; correct? 
A. I helped facilitate the paperwork on the particular sale.

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Q. Okay.  Is it fair to say that you don't remember anybody
coming to like view the car, like you buy an average car,
right?
A. Yes.
Q. Nobody came to see it, right?
A. Not that I'm aware.
Q. Okay.  And you said that, is it -- did I get it right that
Dallas Lamborghini sells about 35 of these cars a month?
A. Yes.
Q. Okay.  And is it like an everyday car or is it like a
sporting car or a racing car?
A. It's, in the car world, called an exotic car.  So there's
not very many made.  Enthusiasts that love the brand buy the
car.
Q. Okay.  And people generally buy the car because it could be
fun to ride in the car; is that right?
A. Yes.
MS. MURRAY:  Objection.
THE COURT:  Sustained.
Q. It's not an everyday-use car, right?
A. Not normally.
Q. Not normally.  Okay.
And you've been doing this for 13 years; correct? 
A. Yes.
Q. And this was one of many sales you made during the course

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of your employment in Dallas; correct?
A. Yes.
Q. Okay.  So let me just walk -- just ask you a couple of
questions about the documents that you were shown by Ms. Murray
over here, okay?
MS. SHROFF:  If I could just have first CT-39, please.
Q. You recognize this car, right?
A. Yes, this is a Lamborghini Aventador.
Q. What does "Aventador" even mean, can you tell us?
A. Aventador is the name of a model of a particular
Lamborghini that was built.  Normally they're named after a
bull or a famous bull or a bullfighter.
Q. Okay.  And this is the car that you sold, right?
A. It appears to be, yes.
Q. Okay.  Could you tell us please what is this wire thing
that comes out of the car for?
A. It's a battery tender.  Basically, maintaining the battery
as it sits in a garage, so it's fresh whenever the client wants
to drive it the next time.
Q. So do you normally do this if you're using the car every
day or do you charge up a battery when the car is not used
frequently?
A. It varies.  The car is -- even when it's off, the computer
systems are still working.  So a lot of owners always want to
keep a fresh battery, so they plug it up.

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Q. Okay.  And you wouldn't -- you can't tell how often the car
is used; correct?
A. No.
Q. Okay.
MS. SHROFF:  Could I have please -- I could have that
taken down.  And if I could please have put up BR-460.
Q. And 460 is the document that you received from Ms. Murray
right here who did your direct testimony; correct?
A. Yes.
Q. Okay.  And she asked you for documents and you sent them to
her; correct?
A. Correct.
Q. You've never spoken to me, right?
A. No.
Q. And you've never spoken to anybody else on the defense
table?
A. No.  No, ma'am.
Q. Okay.  And I never asked you for any documents; correct?
A. No.
MS. SHROFF:  Okay.  So let's look at the next
document.  Could we look at CT-38.
Q. And all of the documents pertain to this car; correct?
A. Yes.
Q. And Ms. Murray asked you some questions about the type of
door that this car has, right?

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A. Yes.
Q. And it's a scissor door; is that right?
A. Yes.
Q. Does that mean anything?  I mean, it's just a door, right,
a straight door, a scissor door?
A. On a Lamborghini --
MS. MURRAY:  Objection, your Honor.
A. On a Lamborghini, it is a particular characteristic of the
particular model, which would be the Aventador.
Q. It's just like a gimmick, right?
A. Not necessarily a gimmick.  It's just a particular type of
door that they have.
Q. Okay.  And on this car there is what is called a VIN
number, right?
A. Yes.
Q. And the VIN number is the vehicle identification number;
correct?
A. Yes, ma'am.
Q. And it's fair to say, right, every car has a VIN number?
A. Yes.
Q. A Subaru has a VIN number?
A. Yes.
Q. And Ford has a VIN number?
A. Yes.
Q. So as opposed to this fancy car, if I just went and bought

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myself a regular old car, it would have a VIN number, right?
A. Yes, it would.
Q. Okay.  So nothing special about the VIN number on this car?
A. No, just the identifying mark of that particular car.
Q. Okay.  Great.
MS. SHROFF:  So let's look at, please, 295, GC-295.
And if you could just scroll down.
Q. These are email exchanges you had about the sale of this
car; correct?
A. Are you still scrolling?  It looks like from Max to a
number of people.
Q. Right.  And you never -- you've testified you never spoke
to Max Krasner, right?
A. No, not -- not physically or -- it's just through email.
Q. Okay.  And you just emailed back and forth because you
wanted the sale to go through; correct?
A. Yes.
Q. That's part of the reason you have a dealership, right, you
want to sell the car?
A. Yes.
Q. And there was nothing untoward about the sale of this car;
correct?
A. No.
Q. You had no red flags while you were selling this car;
correct?

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A. No.
Q. Okay.  You testified on direct testimony about an email
that said Proton; correct?
A. Yes.
Q. Okay.  You get emails from gmail; correct?
A. Yes.
Q. Yahoo; correct?
A. Yes.
Q. Proton; correct?
A. Yes, sometimes.
Q. Okay.  So it's just like an any old email address, right?
A. Yes.
Q. Okay.  And you also testified, did you not, about a top
secret password; correct?
A. Yes.
Q. The top secret password was 123456; correct?
A. Yes.
MS. SHROFF:  Okay.  And if I could have that taken
down and please show 295.  Would you scroll down.  I'm sorry.
Q. And these emails go back and forth all through you -- all
through your dealership until September, right?
MS. MURRAY:  Your Honor, objection.  I think
Ms. Shroff is asking about a different document than the one
that's displayed for the jury right now.
MS. SHROFF:  460 is what I want, please.

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THE COURT:  Is this the correct document?
MS. MURRAY:  It is, your Honor, pages 19 to 22.
BY MS. SHROFF:  
Q. So let's start with page 19.  You see that email that's
right there says:  "Hi Max, we have -- "
MS. SHROFF:  There you go.  Thank you.
Q. "We have signed copies of the buyer's order."  Correct?
A. Yes.
Q. Odometer and dealer reassignment form, right?
A. Yes.
Q. By the way, sitting here today, do you recall if this was a
used car that you were reselling?
A. It is a pre-owned vehicle.
Q. Right.  So it's -- by "pre-owned," you mean it was used
before, right?
A. Yes.
Q. It's not a brand-new Lamborghini, right?
A. No.
Q. Okay.  So this is a used car that is being resold to
somebody, right?
A. Yes.
Q. Okay.  Sitting here today, do you know how old that car
was?
A. During that time?
Q. Yeah.

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A. In 2021?  So it was a 2021 model for Lamborghini and we
sold it in 2021.
Q. Okay.  So how many owners had there been before it, do you
know?
A. I'm not sure.
Q. Do you know if it was more than one?
A. Possibly.
Q. Okay.  You don't really know, right?  It could have been
one, two, three, you just don't know?
A. Correct.
Q. Okay.  And sorry about that.  And at this point in this
email chain, which is October 19 of 2021, right?  Somebody is
giving you an address of where the -- do you read this email as
telling you where to send the paperwork or where to send the
car?
A. To send the title.
Q. To send the title, right?
A. Yes.
Q. Okay.  And do you send the title to that address?
A. I don't.  My title clerk does.
Q. Okay.  And do you know what is located at 162 East 64th
Street?
A. No.
Q. Do you know what business is located there?
A. No.

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Q. Do you know who works there?
A. No.
Q. Have you ever heard of a person named Miles Guo?  Have you
ever heard of a person named Miles Guo?
A. No.
Q. Okay.
MS. SHROFF:  If we could just scroll down, please.
Q. And there is a conversation here about the passport;
correct?
A. Yes.
Q. And you get a copy of a passport, do you not?
A. Yes.
Q. And why do you need the passport, sir?
A. Gives identification of who the person that would be
signing off for the company when they buy a particular vehicle.
Q. Okay.  And you got -- you got a copy of the passport;
correct?
A. Yes.
Q. And, of course, you did whatever you needed to do to verify
that that was a correct passport, right?
A. Yes.
Q. Okay.  And then after that -- 
MS. SHROFF:  If you could close that, please.
Q. You have an email that asks you if you can assist with
transport.  And then they said that assistance for transport

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can be provided; correct?
A. Yes.
Q. Okay.  And when you're transporting the car, you would only
transport the car out of your dealership after the things on
your checklist have been met; correct?
A. Yes.
Q. You want to make sure title passes correctly, right?
A. Yes.
Q. Registration, right?
A. Yes.  We don't do the registration on a cash deal, but we
make sure that the title is signed over to the correct buyer.
Q. Okay.  And you also want to make sure that the buyer has a
driver's license, right?
A. Not necessarily a driver's license, just identification.
Q. Okay.  So you want to make sure that the person is properly
identified, right?
A. Yes.
Q. And you did that; correct?
A. Yes.
Q. Okay.  And after you took all of those steps, you were
going to ship the car out to whatever address they told you,
right?
A. Yes.
Q. Sitting here today, do you recall if the car was originally
supposed to go to a different address?

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A. No.
Q. You don't recall?
A. I don't recall, no.
Q. Okay.  And is it fair to say that where a car goes also
determines the cost of the insurance of a car?
A. Well, the shipping carrier -- when we set up shipping for
our client, we want to make sure that the shipping carrier, A,
might be familiar with the vehicle in transporting a vehicle of
this amount; and making sure that we have ample insurance to
cover if something were to happen during transport for a
client.
Q. Right.  But that is the insurance on the transport part of
the car, right?
A. Correct.
Q. Would you agree with me, as a person who's been in the car
business for 13 years, that each state has a certain cost for
maintaining insurance on the car?
A. I'm vaguely familiar.
Q. Some states are more expensive than others; correct?
A. Probably, yeah.
Q. Insurance depends on whether the car is placed in a garage
or parked on the street; correct?
MS. MURRAY:  Objection, your Honor.
THE COURT:  Sustained.
The witness has said that he is vaguely familiar.

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MS. SHROFF:  He might know the answer, your Honor.
THE COURT:  With that understanding, he can answer.
Q. Do you know if insurance rates differ state to state?
A. No.
Q. Do you know if insurance is higher if you park the car on a
street versus if you park the car in the garage?
A. It depends on the insurance company.
Q. Okay.  Fair enough.
MS. SHROFF:  Could I have number 504, please.  It's
okay, actually.
Q. When you were getting ready to ship the car, you were given
an address; correct?
A. I wasn't given the address.  I have a sales assistant that
actually does our transportation for us that works with the
dealership.
Q. Okay.  So once you finish of the sale of the car, somebody
else takes over to make sure the car gets to where it's
supposed to get, right?
A. Yes.  Normally, the salesperson and our sales assistant.
Q. And would you know what is the markup on a used car?
A. The markup on a used car?
Q. Yes, sir.
A. It could vary.
Q. Do you know how much the markup on this car was?
A. In that particular instance, a Lamborghini Aventador,

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brand-new 2021 model would be, MSRP — manufacturer's suggested
retail price — at $650,000.
Q. Okay.  And you don't know how long this car was sitting on
the parking lot before it was brought out, right?
A. Not -- no, not in particular.  I could find out, but no.
Not long.
Q. When you were interacting with this person named Max,
correct, he was telling you or at least somebody in your office
where the car was going to go; correct?
A. Yes.
Q. And Max you understood was part of G Clubs; correct?
A. Yes.
Q. And he represented G Clubs' interest to you when he was
emailing with you; correct?
A. Yes.
Q. And Max Krasner from the emails, you can conclude, knew
that the car was going to go to Connecticut; correct?
A. Yes.
MS. SHROFF:  Okay.  Could I have one moment, your
Honor?
THE COURT:  Yes.
(Counsel conferred) 
Q. Who did you talk to when trying to figure out the final
price sale of the car?
A. I didn't speak with anyone.

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O5OVGUO4                 Bonsukan - Redirect
Q. I'm sorry, I cut you off.
A. Normally, the salesperson negotiates the price with the
particular client.
Q. So you have no idea how many times Max Krasner talked to
the salesperson and went back and forth before arriving at the
final purchase price?
A. No.
Q. You do not know how long those negotiations lasted;
correct?
A. No.
Q. And do you know if Mr. Krasner or anyone else from G Clubs
did an inspection of the car before it was shipped?
A. I don't recall.  It could be possible.
MS. SHROFF:  I have nothing further, your Honor.
Thank you. 
THE COURT:  Redirect.
MS. MURRAY:  Yes, your Honor.  Briefly.
REDIRECT EXAMINATION 
BY MS. MURRAY:  
Q. Mr. Bonsukan, you were just asked some questions about how
long that Lamborghini that we've been talking about was on the
lot.  Do you recall those?
A. Yes.
Q. And you indicated it was not long; is that correct?
A. Yes.

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Q. What do you recall about the volume of sales that
Lamborghini Dallas was doing during this time period, fall of
2021?
A. Fall of 2021, obviously in the COVID times, vehicle sales
were -- on a naturally aspirated engine, which would be this
Aventador, were going like crazy because Lamborghini announced
that they were going to start doing hybrid engines on their
vehicles.  So collectors and people that loved this car would
try buying it, even if they're buying it for more than what the
original MSRP is.
Q. And you mentioned that the MSRP on this car was
approximately what?
A. Approximately 650,000.
MS. MURRAY:  And Ms. Loftus, if we could pull up,
please, Government Exhibit BR-460 at page 2.
Q. And focusing on the final sale price of this car here, what
was the final sale price of this particular car, this used car?
A. The unpaid balance is $832,000.75.
Q. That's nearly $200,000 more than the manufacturer's
suggested retail price; is that correct?
A. Yes.
Q. And this was a used car, but it was the same year as it was
ultimately sold to G Clubs, right?
A. Yes.
MS. MURRAY:  Ms. Loftus, if we could zoom out on this

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and go to the left and look at the mileage listed for this
particular car.  It's on the top left description of sale unit.
Q. Mr. Bonsukan, how many miles were on this car when it was
sold to G Club International?
A. 317 Miles.
MS. MURRAY:  All right, Ms. Loftus.  We can zoom out
of that and go to the top again to the seller and the buyer
names listed.
Q. Now, Mr. Bonsukan, you testified on cross-examination that
you didn't know a person named Miles Guo; is that right?
A. Yes.
Q. Do you know what the "G" in G Club International Limited
stands for?
A. No.
MS. MURRAY:  Just a moment please, your Honor.
(Counsel conferred) 
MS. MURRAY:  Nothing further.
THE COURT:  Recross.
MS. SHROFF:  Yes, your Honor.
Could you just leave that exhibit.  Thank you. 
RECROSS EXAMINATION 
BY MS. SHROFF:  
Q. The Lamborghini that was sold, the red Lamborghini, right?
A. Yes.
Q. That was almost a collector's car; correct?

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A. Yes, could be.
Q. It was actually an investment; correct?
MS. MURRAY:  Objection, your Honor.
MS. SHROFF:  She brought it out.
THE COURT:  Sustained.
Q. The price was higher than a brand-new car, right?  You
testified for Ms. Murray about that, right?
A. Yes.
Q. And why was that?
A. Why is the price higher?  Because it's a popular vehicle in
terms of the Lamborghini world, when a lot of people were
trying to buy these cars.
Q. And they were going to change the model; correct?  You
testified to it on direct, something about it going hybrid;
correct?
A. Yes, eventually.
Q. Right.  And the model G Clubs bought would only go up in
value because they were going to stop making those Lamborghinis
that way; correct?
MS. MURRAY:  Objection, your Honor.
THE COURT:  You may answer.
A. Possibly.
Q. Well, you testified on direct that if the price was going
to go up, people were going crazy, they wanted to keep that
model, right?

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A. It would be a risk, yeah, possibility where it could go up.
But it also could go down.
Q. Right.  But that is why people were buying it, right?
A. Yes.
Q. You testified that they were literally hot off the parking
lot because everybody thought this would be a collector's
model, right?
MS. MURRAY:  Objection, your Honor.
THE COURT:  That's a mischaracterization of his
testimony.  Sustained.
Q. People were buying it during the pandemic nonstop; correct?
MS. MURRAY:  Objection, your Honor.
THE COURT:  Sustained.
Q. Did the sales go up during the pandemic?
A. Sales did go up, yes.
Q. Of that red model, right?
A. Amongst a lot of other models as well.
Q. Right.  But the red model was included in the one where the
sales are going up, right?
A. That's correct.  It's a rare car of Lamborghini.
Q. Exactly.  Thank you.
MS. SHROFF:  Could I just have this exhibit made
bigger.
Q. And you see on the left-hand side where the description of
the sale unit is listed?

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A. Yes.
Q. And it says used; correct?
A. Yes.
Q. Okay.  And when you go down, if you read further down on
this document, right?
A. Yes.
Q. Okay.  The salesperson's name is Mr. Durkey.  And that's
the person on the email chain that Ms. Murray had you read
about; correct?
A. Correct.  Yes.
Q. And he's the person who finalized the sale, right?
A. He would be the one point of contact of negotiating with
the customer.
MS. SHROFF:  Okay.  And if I could just have that
shrunk and the next page of the document shown, please.
Q. And this page shows you just an average sale of a car no
different --
MS. MURRAY:  Objection, your Honor.  Scope.
THE COURT:  Sustained.
Q. The car that was driven off the lot was insured, right?
A. Probably, yeah.
Q. Okay.  And it was dropped off in Connecticut; correct?
MS. MURRAY:  Objection.
THE COURT:  Sustained.
MS. SHROFF:  I'm done, your Honor.  Thank you.

163
          SOUTHERN DISTRICT REPORTERS, P.C.
            (212) 805-0300
O5OVGUO4                   
THE COURT:  Thank you, sir.  You may step out.
THE WITNESS:  Thank you, your Honor.
(Witness excused) 
THE COURT:  Is that the last witness for today?
MS. MURRAY:  We have another witness ready, your
Honor.  But given the time, we defer to the Court whether you'd
like us to start a few minutes or whether we should stop for
today.
THE COURT:  All right.  I think we should stop for
today.  You may step out.
One moment.
Members of the jury, we have finished our work for
today.  Monday is Memorial Day, and so you're going to be
returning to court according to the instructions that have been
given to you so that you'll be able to walk into the courtroom
at 9:30 sharp.  It's very, very important that you follow those
instructions closely and that you get here on time.
Remember that you're not allowed to discuss the case
amongst yourselves.  Don't permit anyone to discuss the case in
your presence.  It's always tempting, once you start to hear
witness testimony, to want to discuss the case, but that is
absolutely prohibited.
I wish you a wonderful long weekend, and I look 
forward to seeing you on Tuesday. 
(Jury not present)

164
          SOUTHERN DISTRICT REPORTERS, P.C.
            (212) 805-0300
O5OVGUO4                   
THE COURT:  Please be seated.
I'm going to ask that Alternate No. 5 be brought in.
Is there anything that the parties wanted to raise? 
MS. SHROFF:  No, your Honor.
MS. MURRAY:  No, your Honor.
(Juror present) 
THE COURT:  Hi.  You're Alternate No. 5, right?
JUROR:  I am.  Yes.
THE COURT:  I received a note from you and you raised
certain concerns.  But now with the understanding of the
transportation arrangements, my sense is that your schedule can
work with the second option that was discussed; is that
correct?
JUROR:  Correct.  Up until the point of where my child
is finished school June 18th.
THE COURT:  And then?
JUROR:  The summer plans will now have to be changed
in order for me to continue to be a juror.
THE COURT:  And so that you can do that, you can make
those changes?
JUROR:  I haven't even begun to figure out what that
would entail.
THE COURT:  Well, I ask that you work on that and that
you return on Tuesday.  Thank you.
JUROR:  Thank you.

165
          SOUTHERN DISTRICT REPORTERS, P.C.
            (212) 805-0300
O5OVGUO4                   
(Juror not present) 
THE COURT:  All right.  If there's nothing further,
then I wish everyone a good holiday weekend.
MS. MURRAY:  Thank you, your Honor.  You as well.
(Adjourned to May 28, 2024 at 9:30 a.m.)

166
          SOUTHERN DISTRICT REPORTERS, P.C.
            (212) 805-0300
INDEX OF EXAMINATION 
Examination of:                               Page 
 ERIN McNAMARA 
53Direct By Mr. Finkel . . . . . . . . . . . . . .
84Cross By Ms. Shroff  . . . . . . . . . . . . . .
117Redirect By Mr. Finkel . . . . . . . . . . . . 
119Recross By Ms. Shroff  . . . . . . . . . . . . 
121Redirect By Mr. Finkel . . . . . . . . . . . . 
122Recross By Ms. Shroff  . . . . . . . . . . . . 
 LOUIE BONSUKAN 
123 Direct By Ms. Murray . . . . . . . . . . . . . 
143Cross By Ms. Shroff  . . . . . . . . . . . . . 
157 Redirect By Ms. Murray . . . . . . . . . . . . 
159Recross By Ms. Shroff  . . . . . . . . . . . .

167
          SOUTHERN DISTRICT REPORTERS, P.C.
            (212) 805-0300
GOVERNMENT EXHIBITS 
Exhibit No.                                    Received 
62 CT-20 through CT-30, CT-35 through 72,  . . . .
CT-74 through 105, CT-101 
through 129, CT-157 through 
187, CT-190 through 202, 
CT-204 through 207  
 STIP-1 62   . . . . . . . . . . . . . . . . . . .
 36 66   . . . . . . . . . . . . . . . . . . . . .
 133 55  . . . . . . . . . . . . . . . . . . . . .
 CT-208 68   . . . . . . . . . . . . . . . . . . .
 CT-209 67   . . . . . . . . . . . . . . . . . . .
 GC295 130  . . . . . . . . . . . . . . . . . . . 
 BR460 124  . . . . . . . . . . . . . . . . . . . 
 GC-504 141   . . . . . . . . . . . . . . . . . .

Translated Text(简体中文翻译)

6
          南区记者，P.C.
            (212) 805-0300
O5O1GUO1                 
美国地方法院 
纽约南区 
--------------------------------------x 
美利坚合众国，                
 
           v. 23 Cr. 118 (AT) 
 
MILES GUO， 
 
               被告。试用     
--------------------------------------x 
                                        纽约，纽约 
                                        2024 年 5 月 24 日 
                                        上午 10:15 
 
之前： 
 
亲爱的。安娜丽莎·托雷斯， 
                                        地区法官 
                                         -还有陪审团- 
 
出场 
 
达米安·威廉姆斯  
     美国检察官 
     纽约南区 
作者：MICAH F. FERGENSON 
     瑞安·B·芬克尔 
     贾斯汀霍顿 
     朱莉安娜·默里 
     美国助理律师 
 
SABRINA P. SHROFF 
     被告律师  
 
PRYOR CASHMAN LLP 
     被告律师  
作者：SIDHARDHA KAMARAJU 
     马修·巴尔坎 
 
ALSTON & BIRD LLP 
     被告律师  
作者：E. SCOTT SCHIRICK

7
          南区记者，P.C.
            (212) 805-0300
O5O1GUO1                 
还出席：   
伊莎贝尔·洛夫特斯，律师助理专家，USAO 
迈克尔·加特兰，律师助理专家，USAO 
Geoffrey Mearns，律师助理专家，USAO 
罗伯特·斯托特，联邦调查局特工  
鲁本·蒙蒂拉，国防律师助理 
黄拓，口译员（普通话） 
石峰，口译员（普通话）

8
          南区记者，P.C.
            (212) 805-0300
O5O1GUO1                 
（由12名和6名候补成员组成的陪审团已正式组成） 
并宣誓了） 
法庭：律师，请你接近吗。
（在侧边栏上）  
法庭：谁在向政府开放？
费根森先生：我是，法官大人。
法庭：也是为了辩护。
SHROFF 女士：我是。
法庭：好吧。你可以退后一步。
SHROFF 女士：谢谢。
（在公开法庭上） 
法庭：早上好。
陪审员：早上好。
法院：陪审团成员，案情是
正式接受审判，而你们是该案的陪审员。如
你可以看到，陪审团由12名成员组成。此外，
有六个候补球员。如果你是候补者，你需要
像陪审团一样密切关注证据。如果有的话
陪审团任何成员无法任职的原因，
将需要一名候补人员来取而代之
陪审员。
我现在要给你一些初步指示
指导您参与试用。
审判的第二部分即将开始。这个
部分是检方的开场白。在

9
          南区记者，P.C.
            (212) 805-0300
O5O1GUO1                 
政府的开幕词，他必须表明
控方打算通过证据向你证明什么
以支持对被告的指控。曾经
政府的开幕词已经完成，辩护
律师可以选择致开幕词。
现在，律师在开幕词中所说的不是
证据。从某种意义上说，开幕词是对以下内容的预览
律师期望证据能显示什么。
接下来，政府将出庭作证，并将
向证人提问。这称为直接检查。
政府完成这些问题后，辩方将
然后有机会询问证人。这是
叫做交叉盘问。这个过程将持续到每一个人
控方将出庭作证的证人。
当政府拨完所有电话时
证人，辩方将有机会出庭
还有目击者。记住，辩方不需要证明任何事情。
因此，他们不必盘问政府的
证人或提供自己的证人。
当双方都出示完证人之后
辩方和控方将有机会
向你致闭幕词。这些闭幕辩论将
不是证据。它们只是律师提出的论点
讨论该案的事实和情况，他们
应仅限于证据和合理的推断

10
          南区记者，P.C.
            (212) 805-0300
O5O1GUO1                 
可以从证据中得出。再说一遍，两者都不开放
陈述或闭幕词都是证据，你应该
无视律师提出的任何陈述或论点
不是以证据为依据的。
辩论结束后，我会给你详细介绍
与本案相关的法律指示。
当我完成指示后，你就会退到
故意作出裁决。
现在我要指导你提供证据。先让开
我告诉你什么是证据。
基本上，证据包括以下方面的口头证词
誓言、双方的任何规定和实物证物
在审判期间，由控方提出的
或辩方，并允许其作为证据。如果展品是
交给你检查，你应该仔细检查，
个别对待，不加评论。
有两种类型的证据——直接证据和
间接的。直接证据是这样的事实的直接证据
作为目击者的证词。间接证据是
事实的证据，你可以从中推断出或得出其他结论
事实是存在的。有一个简单的间接例子
该法院经常使用的证据。假设那个
当你今天早上来到法院时，太阳是
闪闪发光，今天真是美好的一天。假设法庭
阴影向下，你无法向外看。和你一样

11
          南区记者，P.C.
            (212) 805-0300
O5O1GUO1                 
坐在这里，有人拿着一把雨伞走进来
滴得湿透了。然后几分钟后，另一个人也是
带着一把湿伞进入。现在你不能往外看
法庭，你看不出是否在下雨，所以
你没有直接的证据证明这个事实，但是在
综合我请你假设的事实，会的
要合理合乎逻辑地得出结论
下雨。间接证据仅此而已。你
根据理性、经验和常识，推断
从一个既定事实来看，某些人的存在或不存在
其他事实。
并非所有间接证据都清晰可见
令人信服的推论。推论的力量正在浮出水面
根据间接证据由你来决定。我会给
有关这些问题以及其他事项的进一步指示，请访问
案子到此结束，但请记住，你可以考虑
两种证据。
如果你被指示接收一些证据
仅出于有限的目的，您必须遵循该指示。
律师甚至我自己问的问题是
本身不是证据。只有问题再加上
答案就是证据。因此，你可能无法推断出任何事实
仅仅是问一个问题。我指出的原因
告诉你这个很简单。在讯问过程中
控方和辩方可以行使权利

12
          南区记者，P.C.
            (212) 805-0300
O5O1GUO1                 
反对对方的问题，反对给出的答案
问题，或者介绍展览，理由是
律师认为这在法律上不当或
不可接受。那时我将维持或否决
反对。如果我支持对一个问题的反对意见，你必须
如果已经给出答案，则忽略这个问题和任何答案。
你也不能从问题或任何问题中得出任何推论
回答。你也不能猜测证人会怎么做
如果允许我回答，我已经说过了。
从记录中删除的证据也必须如此
不理会。
相反，如果我否决反对意见，问题是
将被允许，答案将成立，并且保持不变
证据。当我否决对任何证据的异议时，你
提供此类证据的权重不得超过
没有人提出异议。
请记住，我对法律的裁决是
仅此而已，在任何情况下都不是这样的裁决
你认为这表明我对此有任何看法
被告有罪或无罪。根据我们的法律，
法官可能不会也不会就此发表任何意见
被告有罪或无罪。陪审团成员，你
只有你是事实的唯一和专属的判断者。
现在我想让你明白，反对意见可能会出现
相当快，有时任何一方似乎都很担心。

13
          南区记者，P.C.
            (212) 805-0300
O5O1GUO1                 
请不要对此感到不满，也不要因此而惩罚任何一方。
明白他们只是在做好自己的工作，这是其中的一部分
其中。
正如我一开始所说，你们是试用者
事实。因此，由您决定向哪个证人作证
相信，哪个证人不相信。此外，你
将决定接受每位证人的证词的多少以及
要拒绝多少。
你如何决定该相信什么和不该相信什么
相信？听取目击者的心声，观察他们，观察
他们，然后决定你是相信还是不相信他们
就像你在日常生活中决定这样的问题一样。
他们知道他们在说什么吗？他们是坦率的吗，
诚实、开放、真实？他们有理由伪造吗，
夸大或歪曲他们的证词？只要用你的常用就行了
评估所有证词的意义。对你的要求只是
你运用的常识与你的常识相同
日常生活要决定谁在告诉你真相，谁
不是，谁在告诉你一些不完整的事情
真相。
请记住，这是证据的质量
这控制的不是证据的数量或数量
双方传唤的证人。  
你必须仅根据证据来裁定案情
法律摆在你面前，不得受任何个人影响

14
          南区记者，P.C.
            (212) 805-0300
O5O1GUO1                 
喜欢或不喜欢、观点、偏见、同情或偏见，
包括潜意识偏见。潜意识或隐性偏见是
人们可能的陈规定型观念、态度或偏好
有意识地拒绝，但可以在没有意识的情况下表达
意识、控制或意图。就像有意识的偏见一样
潜意识偏见也会影响我们评估信息的方式
做出决定。无论我们多么努力，我们所有人往往会
看看别人，倾向于权衡他们所说的话
我们自己的经历和背景的镜头。我们每个人都有一个
倾向于对他人进行刻板印象，并对他人做出假设
他们。我们通常会看到灯光并通过以下方式评估证据
阴云密布的过滤器往往会偏爱像我们这样的人。你
必须尽最大努力为所有人抛开这样的陈规定型观念
诉讼当事人和证人有权享有公平的竞争环境
在这方面我们会尽最大努力抛开陈规定型观念
和偏见。您只能以以下证据为指导
这个案子和我的法律指示
尽管你是事实的唯一判断者，但我的工作
将是唯一的法律法官。你必须接受法律
我毫不犹豫或保留地把它交给你。你
即使你私下里不同意，也必须接受我给的法律
要么和我在一起，要么听法律。
有三项基本法律原则适用于
这个以及所有的刑事案件——无罪推定，
检方的责任和举证标准。

15
          南区记者，P.C.
            (212) 805-0300
O5O1GUO1                 
首先，无罪推定。被告是
推定无罪，这一假设仍然适用于
在整个审判过程中，被告不会被免职，除非和
直到被告的罪行被证明不合理
怀疑。起诉书中载有对该人的指控
被告只是一项指控，仅此而已。这不是证据
有罪之类的因此，因为没有证据
如果你要考虑的话，到目前为止已经呈现给你了
现在，你必须认定被告无罪。
其次是检方的负担。的负担
证据就在政府身上。防守没有负担而且是
不需要做任何事情来证明他的清白。这个
防守可以选择袖手旁观。
为什么？因为辩方没有举证责任，而且
被告被推定无罪。不需要被告
进行辩护或传唤任何证人，因为
无罪推定。如果被告选择不采取
证词，为了代表他作证，你不能出庭作证
由此推断出负面推断；换句话说，你无法忍受
那是针对被告的。
第三是举证标准。起诉是
必须证明被告的罪行超出合理范围
怀疑。该标准不要求检方证明
被告的罪行不容置疑，或者从数学角度来看
确定性。但是，检方必须证明

16
          南区记者，P.C.
            (212) 805-0300
O5O1GUO1                 
被告的罪行不容置疑。疑问不是
如果是合理的，而不是以性质和质量为依据
无论是证据还是证据不足，都是
基于一些与之无关的猜测或异想天开的推测
证据。
在我最后给你的指示中
审判，我会给你详细的法律指示
对被告的具体指控。那些指令
旨在指导你完成审议并且
使您能够做出决定。
最后，我现在要指导你该怎么做
在审判期间表现得体。
在试用期间，你必须保持开放的心态。
在审判期间你必须睁大眼睛。
你不能向证人提问。
不要交谈，无论是在彼此之间还是与他人交谈
其他任何人，关于此案的任何事情。你可以分辨出来
与你同住的人和你的雇主
陪审员，让他们知道何时需要你
出庭，但你不得与他们或其他任何人交谈
关于与案子有关的任何事情。期间任何时候都不要做
试用请求、接受、同意接受或与任何人讨论
个人收到或接受的任何款项或福利
退货以提供有关试用版的信息。你必须
立即直接向我报告你发生的任何事件

17
          南区记者，P.C.
            (212) 805-0300
O5O1GUO1                 
涉及任何人企图不当行为的知识
影响你或陪审团的任何其他成员。
请勿访问或查看其所在的场所或地点
据称犯下了被指控的罪行或任何其他场所
或案件所涉地点。而且你可能不使用互联网
地图或谷歌地球或任何其他要搜索的程序或设备
查看和查看证词中所述的任何地点。
不要阅读、查看或收听任何账号或
报纸、电视台对该案的讨论
广播、互联网、社交媒体或任何其他形式的新闻
媒体。不要试图研究任何事实、问题或法律
与本案有关，无论是通过与其他人讨论，还是通过
在图书馆、互联网上或通过任何其他方式进行研究
手段或来源。
在这个即时电子通信的时代
研究，我想强调的是，除了不是
就此案与任何人面对面交谈，你必须
不要通过任何其他方式与任何人就此案进行沟通，
包括通过电话、短信、电子邮件、互联网聊天或
聊天室、博客或社交网站，例如 Facebook 和 X。
您不得向任何人提供有关此案的任何信息
不管怎样，这包括发布
有关案件或您在该案中所做的事情的信息，
在任何设备或互联网站点上，包括博客、聊天室，
社交网站或任何其他方式。

18
          南区记者，P.C.
            (212) 805-0300
O5O1GUO1                 
你也不得在谷歌或以其他方式搜索任何内容
有关案件或适用于该案的法律的信息
或者包括被告在内的涉案人员，
证人、律师和我自己。
现在，女士们、先生们，我想让你明白
为什么这些规则如此重要。我们的法律不允许
陪审员与其他人讨论此案或
有人可以和他们谈谈这个案子因为只有陪审员才是
有权作出判决，只有你被认定是
公平，只有你承诺要公平。没有其他人有
太有资格了。
我们的法律也不允许陪审员相互交谈
在法官要求他们开始之前，亲自了解案件
审议，因为过早的讨论可能导致
过早做出最终决定。
我们的法律也不允许您参观某个地方
在证词中讨论过。首先，你不能总是确定
那个地方的状况和当天一样
问题；其次，即使处于相同状态，也只有一次
你去证词中讨论的地方进行评估
根据你所看到的证据，你成为证人，而不是证人
陪审员。作为证人，你现在可能有错误的看法
任何一方都可能无法更正的场景。
这不公平。
最后，我们的法律要求你不要阅读或听

19
          南区记者，P.C.
            (212) 805-0300
O5O1GUO1                 
转到任何有关该案的新闻报道，而且你没有尝试
研究与案件相关的任何事实、问题或法律。你的
决定必须完全基于证词和其他证词
在法庭上出示的证据。这样做是不公平的
各方让你根据某些记者的意见做出决定
查看或发表意见或根据您在外部获得的信息
法庭。
这些规则旨在帮助保证公平
审判，我们的法律因此规定了严重后果
如果不遵守规则。我相信你能理解而且
意识到遵守规则的重要性，并保持一致
有了你的誓言和承诺，我知道你会这样做的。
在审判期间，我可能需要协商
让律师不在你的听证范围之内
法律或程序。在某些情况下，你可能会被原谅
出于这个原因，法庭。我会尽量限制这些
尽可能地中断，但你应该记住
你来这里要决定的问题的重要性，而且应该
即使案情似乎进展缓慢，也要耐心等待。
最后，我允许陪审员做笔记，但你不能
必须记笔记。笔记只是你自己的辅助手段
回忆。本案的法庭记者记录
法庭上所说的一切以及其中的任何部分
在此期间，可以在公开法庭上向你宣读证词
你的审议。

20
          南区记者，P.C.
            (212) 805-0300
O5O1GUO1 开幕——费根森先生
如果你确实做了笔记，请注意，记笔记可能会
分散你对正在发生的重要事情的注意力
证人席位。不管你是否做笔记，都要靠自己
回忆，不要受另一个事实的影响
陪审员做了笔记。
我刚才告诉过你你要举报任何企图
任何人对你施加不当影响。不允许律师
除了发生的事情外，还要与您进行任何接触
在这个法庭上录音如果你去找律师，那就是
例如，在走廊里或外面，律师没有
打个招呼或者承认你的存在，请不要这么想
律师很粗鲁。律师根本不是
允许与您进行此类联系。
现为助理美国检察官米卡·费根森
将致开幕词。
费根森先生：这个案子是关于被告如何，
郭文豪，骗走了数千名投资者，骗走了10亿美元，而且
这是关于他是如何将数百万美元的受害者钱花在上面的
他自己。
在在线视频中，被告投资于
一系列公司。在这些视频中，被告说
许多虚假和误导性的东西。但从本质上讲，
被告的欺诈行为很简单。他向受害者保证他们会
致富，他们的投资是安全的，但他们不会
损失任何钱。作为超级富豪，他这样告诉他们

21
          南区记者，P.C.
            (212) 805-0300
O5O1GUO1 开幕——费根森先生
亿万富翁，他会亲自担保并偿还任何费用
损失。他向他们保证，他永远不会让他们
投资被盗。这些都是谎言。事实是
被告拿走了投资者的钱然后花了
他自己——价值百万美元的汽车、游艇、豪宅。郭文贵跑了
一个大规模的简单骗局。他过着亿万富翁的生活
生活方式用他从他欺骗的人那里偷来的钱
被骗。
现在被告无法独自搞这么大的骗局。
你会了解到被告及其犯罪伙伴建造
由不同公司组成的犯罪集团来进行此项活动
欺诈。其中一些公司在新州设有办事处
约克城。员工称被告为老板，
校长。然后被告和他的内心圈子使用了
这些企业是为了从受害者那里偷钱然后花钱
它自己动手。这就是我们今天来这里的原因，因为
当被告骗取人们的钱时，他
犯下了几起涉及欺诈的罪行。当他和他的
合伙人四处转移投资者的资金以掩盖自己的身份
把钱花在自己身上，他们犯了洗钱罪
犯罪。而且因为被告犯下了这些罪行，
他利用犯罪集团、一群人和公司
受到控制，他犯下了敲诈勒索罪，一个 RICO
阴谋。
女士们、先生们，在这场开幕词中，我是

22
          南区记者，P.C.
            (212) 805-0300
O5O1GUO1 开幕——费根森先生
我会告诉你这次审判的证据将显示什么而且
政府将如何证明这一点——证明的不仅仅是
合理怀疑被告有罪。
那么首先，证据会显示什么？多年来
被告欺骗了成千上万的人并偷走了他们的钱
为他再也负担不起的生活方式付出代价。你看，
被告曾经是中国的一位富有的房地产开发商。
但是他离开了中国，来到了美国。最终
被告大声疾呼反对中国政府，中国人
共产党，简称中共。他开始捐款
采访并播放自己的视频。
而且他谈的不仅仅是中共。被告
还谈到了他有多富有。他炫耀了自己的
位于中央公园的7000万美元公寓，或他的3000万美元
游艇。
还有被告将炫耀财富和
批评中共很受欢迎。他变成了互联网
华人社区的名人。他有成千上万的
追随者。而且你会知道中共不喜欢
这个，中共试图让被告保持沉默，甚至尝试过
把他带回中国。而且你会明白
中国和香港政府没收了被告的
计划开始前不久的资产。所以被告
需要钱。
现在你要知道被告投案了

23
          南区记者，P.C.
            (212) 805-0300
O5O1GUO1 开幕——费根森先生
他的受害者有许多不同的投资计划，但每种计划都有
只是对同样的简单欺诈行为的新翻版。被告
告诉他的追随者他们的钱将用于
投资，他们不会损失任何钱。相反，
被告偷走了受害者的钱，并把钱花在了自己身上。
他通过四个主要计划来做到这一点——GTV；农业贷款；
G/CLUBS；和喜马拉雅交易所。我要谈谈
这些计划依次进行。
因此，被告筹集资金的第一笔生意
因为是 GTV。GTV 是什么？那是一家在线媒体公司
通过一个网站和一个包含被告视频的应用程序，他的
在上面广播。被告告诉了他的追随者什么
关于 GTV？他告诉他们这是他们的特殊机会
毫无风险地致富。2020年，被告宣布，
在他的在线广播中，他会让粉丝购买
GTV 股票。被告告诉他的追随者，投资
GTV 没有风险。他告诉他们他会亲自偿还任何钱
损失。他告诉他们，投资GTV只会赚钱
他们的钱。这些都是谎言。而且被告甚至撒了谎
关于GTV投资中最基本的部分——那笔钱
投资者从GTV筹集的资金将用于GTV，以增长
GTV的业务。即使是那个基本的承诺也是谎言。
但是被告的追随者信任他和金钱
涌入。在几个月内，受害者投资了超过4亿美元
GTV。

24
          南区记者，P.C.
            (212) 805-0300
O5O1GUO1 开幕——费根森先生
被告究竟用这笔钱做了什么？
在为GTV筹款几天后，几乎是立竿见影的
结案后，被告拿走了1亿美元的GTV投资资金
并代表儿子将其用于高风险投资。
他基本上是用1亿美元的GTV投资者下注的
钱，把它寄给了对冲基金，因为风险极大
投资。这个赌注甚至不是代表GTV下的；确实如此
以被告儿子拥有的一家公司的名义制作。
你猜怎么着？对冲基金的赌注没有兑现。这个对冲
基金投注损失了3000万美元。被告告诉GTV投资者
他会亲自担保他们的钱然后还钱
损失。他偿还了3000万美元的损失吗？没有。那是
只是个谎言。
GTV 是什么？这是郭迈尔斯撒谎的一种方式
拿走别人的钱。但这不是唯一的方法。
有GTV，然后是农场借款项目。
现在是农场，这些农场与之无关
农业或农业。被告使用 “农场” 一词来
提及他在不同城市的在线粉丝群组或
国家。而农场借款项目只是延续的一种方式
GTV 计划。你几乎立刻就会看到美国监管机构
开始调查 GTV 在做什么。资金被冻结，而且
GTV的银行账户被关闭。但是被告，他
没有停下来。相反，被告在广播中指责
这些问题落在中国政府身上。他声称

25
          南区记者，P.C.
            (212) 805-0300
O5O1GUO1 开幕——费根森先生
抱怨钱财被盗的受害者
是叛徒和中共间谍。
然后被告告诉他的追随者他们还可以
购买GTV股票；他们就是不能称之为股票。相反，
投资者可以使用通过以下方式组织的 “贷款”
农场。你看，每个农场都开设了曾经使用的银行账户
向农场成员，投资者那里收集和汇集资金。
被告告诉他的追随者，要获得GTV股票，他们
可以与农场签订 “贷款协议” 并汇款
去那个农场。他说农场随后将发放贷款
与GTV达成协议，几年后，被告的
追随者，农场成员，可以选择是否获得 GTV
股票或现金。但这是另一个谎言。被告和
他的洗钱者自己偷走了农场借款项目的钱
而受害者却一无所获。
GTV，然后是农场借款项目。那是什么农场
贷款？他们是郭文贵撒谎的另一种方式
人们的钱。
下一个骗局是 G/CLUBS。现在 G/CLUBS 据说是
一个高端生活方式会员俱乐部，但实际上，确实如此
被告不打电话就卖出股票的另一种方式
股票。被告告诉他的追随者，通过支付
G/CLUBS 的初始会员费，他们将获得 GTV 的股票或
G Fashion，被告的服装公司。多少钱
初始会员费？初始费用起价为10,000美元，

26
          南区记者，P.C.
            (212) 805-0300
O5O1GUO1 开幕——费根森先生
高端股价上涨至5万美元。成千上万的
被告的粉丝支付了这笔费用，向G/CLUBS发送了数百美元
数百万美元，预计将收到库存
返回。但是 G/CLUBS 会员没有获得股票。那是
另一个谎言。
会员的会员费用能得到什么吗
数万美元？他们得到的主要东西是
G Fashion 的折扣，该公司向 G Fashion 出售了昂贵的服装
被告的追随者，比如一条价值800美元的运动裤。你
如果你花 10,000 美元购买，可以享受这个价格的10％的折扣
G/CLUBS 会员虽然 G/CLUBS 成员没有得到
股票或任何价值数万美元的福利，
被告将G/CLUBS的会员费花在了自己和他身上
家庭。
GTV、农场贷款、G/CLUBS。G/CLUBS 是什么？原来是
郭迈尔斯撒谎的另一种方式是拿走别人的钱。
现在被告不只是向他推销股票
追随者；他还推销了两种出售的加密货币
喜马拉雅交易所。起初他称他们为 G Coin 和 G
美元，然后它们变成了H币和H美元——H硬币用于
喜马拉雅硬币，H美元代表喜马拉雅元。这些
加密货币是另一个骗局。在他的广播中，
被告讲了他关于这种加密货币的典型谎言，
保证投资者不会蒙受损失。他告诉他的
追随者认为H币得到了20％的黄金支持。女士们

27
          南区记者，P.C.
            (212) 805-0300
O5O1GUO1 开幕——费根森先生
先生们，H币没有黄金支持。
被告欺骗其追随者购买H币
还有 H Dollar 因为他想要更多的钱。你看，唯一的
你可以买 H 币或者 H Dollar 的地方应该是这样
名为喜马拉雅交易所的加密货币交易所。但是
喜马拉雅交易所由被告的洗钱者经营；
同一个人帮他偷了农场借款项目。你是
当被告陷入困境需要时，我会知道的
钱，被告的洗钱者寄来了3,700万澳元
用喜交所的钱 —— 真实的美元，不是 H 美元 —— 来获得
被告摆脱了困境。3,700 万美元的钱
被送到喜马拉雅交易所的被害人是用来给他的
好处。
GTV、农场贷款、G/CLUBS、喜马拉雅交易所。
喜马拉雅交易所是什么？这是另一种方式
郭迈尔斯撒谎是为了拿走别人的钱。
这四个方案实际上只是不同的版本
同样的骗局，被告把人们骗出去
他们的钱这样他就可以把钱花在自己和家人身上。
而他这样做是出于贪婪。他用投资者的钱来支付
豪华游艇，私人飞机，购买豪华车，
花了将近一百万美元的兰博基尼，一辆布加迪那个
花了400万美元，一秒钟给了他的儿子一辆价值400万美元的法拉利
豪华游艇，一座由他支付的占地5万平方英尺的豪宅
还有数百万美元需要为自己和家人进行翻新，以及

28
          南区记者，P.C.
            (212) 805-0300
O5O1GUO1 开幕——费根森先生
购买诸如35,000美元的床垫和6万美元的电视之类的东西。还有
受害者，被告偷走资金的投资者
为这些疯狂的消费提供资金？他们什么都没有。他们只是
损失了钱——他们存的钱，他们借的钱，
他们家里的钱，他们认为安全的钱。而且他只是
偷了它。
SHROFF 女士：法官大人，反对。
法院：驳回。
SHROFF 女士：这是开幕词。
法院：驳回。
FERGENSON 先生：证据就是这么说的
节目。
现在政府将如何证明这一点，证明一下
你说被告有罪？你会看到和听见
几种不同类型的证据。你会听见
被告自己的话。你会看到被告在视频中撒谎
一遍又一遍。你会看到他撒谎然后说是他的受害者
不可能亏钱，他会偿还任何损失，他
永远不会把投资者的钱花在自己身上。而且你会听见
他撒谎说自己用投资者的钱做了什么，说他
连一分钱都没碰过，他承认如果他
确实如此，那将是犯罪。
你还会听到被告和他的话
同谋们在电话中说，当时他们不认识他们
正在被一名有关雇员录音。你会听见

29
          南区记者，P.C.
            (212) 805-0300
O5O1GUO1 开幕——费根森先生
被告命令其同谋转移1亿美元的
他后来用来购买豪宅的投资资金。而且
你会看到与四个主要内容相关的记录
欺诈，关于应该如何使用投资者的资金，
然后你会看到显示实际使用情况的记录，
显示被告及其同谋的银行记录
使用了数十家空壳公司和数百个银行账户
隐瞒他们花投资者的钱的事实
他们自己。
你会看到写着GTV的GTV投资文件
投资者的资金将用于发展GTV的业务，然后
你会看到显示1亿美元GTV投资者的记录
相反，钱流向了对冲基金为被告下注
儿子。
你会看到发给受害者的农场借款项目合同，
这些纸最终对他们来说一文不值。
你会看到银行记录显示农场借款项目是
刚刚被偷了。
然后你会看到被告的东西的照片
用 G/CLUBS 会员费购买，同时承诺进入
他录制的广播说 G/CLUBS 会员资格是这样做的一种方式
投资 GTV 或 G Fashion。你会看到的照片
停在被告车库里的 G/CLUBS 兰博基尼，
在他在康涅狄格州的家中；被告豪宅的照片
在新泽西州，用 G/CLUBS 的钱支付。你会明白的

30
          南区记者，P.C.
            (212) 805-0300
O5O1GUO1 开幕——费根森先生
挂在被告的意大利定制西装的照片
他在那栋豪宅的卧室壁橱。
你会看到显示这3,700万美元的银行记录
向被告转移喜交所的钱
个人利益，而被告一直告诉投资者
录制了他在喜马拉雅山没有所有权的广播
交易所，H币和H美元货币是安全的。
现在你还将听到证人的证词。你
将听取曾经为之工作和曾经信任的人的来信
被告。你会听到前雇员的来信
被告的G业务。他们会告诉你
被告及其同谋逃跑并控制了他们
企业，并就如何花钱做出了决定
以及它被转移到哪里。
现在，其中一些前雇员正在作证
根据所谓的不起诉协议，其中
政府已同意不起诉他们以换取
他们在这次审判中作证。所以你应该仔细听
听从这些证人的证词。当你这样做的时候，你会看到
这与该案的所有其他证据一致。
女士们、先生们，你们还将听到受害者的来信
被告的欺诈行为中，那些被吸引到Miles的人
郭的网络世界，信任郭迈尔斯的人，他们相信
他对他们说的谎言，还有谁损失了钱，有时甚至是他们的生命
结果，人们最终意识到储蓄是

31
          南区记者，P.C.
            (212) 805-0300
O5O1GUO1 开幕——施罗夫女士
被骗。
现在有证据，根本不会出来的
一次。你会看到一个个证人，一个个文件，
一次一件。但在这次审判结束后
你听过证词也看到了证据，你
将看到全图。这个人骗了成千上万
投资者并偷走了10亿美元。
在审判结束时，我们将有机会发言
又和你在一起。从现在到那时，我要问你
只想做三件事——首先，密切关注
证据；其次，听从托雷斯法官的指示
法律；第三，运用你的常识——同样的常识
以及你在生活中每天都像新人一样使用的良好判断力
约克人。如果你做了这三件事，你将达到唯一的
符合证据和法律的判决——
被告有罪。
法院：现在我们将听取开幕词
萨布丽娜·施罗夫女士代表被告郭先生。
SHROFF 女士：谢谢你，法官大人。
早上好，陪审团的女士们、先生们。它
不是赌注。这不是一个计划。这不是骗局。原来是
这些都没有。而我们今天来到这里的原因不是
因为政府提起了起诉；我们之所以这样做
今天来这里是因为郭先生对该案不认罪
起诉书，本案中的证据将显示——所有

32
          南区记者，P.C.
            (212) 805-0300
O5O1GUO1 开幕——施罗夫女士
证据 —— 他们作为政府引进的证人
律师一个接一个地注意到文件是由
一，只会引导你得出一个结论，而这个结论
是郭先生对这12项罪名无罪吗
起诉书。
我来告诉你为什么没有阴谋，RICO
否则，就没有企业。郭先生不是
犯了这份起诉书中的指控。
在我这样做之前，在我进一步谈论什么之前
本案将显示证据，请允许我介绍
我自己。我叫萨布丽娜·施罗夫。还有我，还有我的
同事们，代表郭文豪。
郭文贵是开始生命的八个孩子之一
很少，在中国出生和长大，事实上是这样
他和他的兄弟们以及他的家人在这里发了大财
财产。本案的证据将表明这笔财富
太棒了。是的，政府想让你画画
一个人做了很多负面推论，据说
他们，在电视或床垫上花了数千美元。我
请问你，当你考虑证据时，考虑
背景下的证据，不得由他人引用
政府邀请他们对以下人员做出判断
有钱然后用你我简单的方式花钱
不会。
那么让我们来谈谈这个案子的证据

33
          南区记者，P.C.
            (212) 805-0300
O5O1GUO1 开幕——施罗夫女士
将显示。本案的证据将显示郭文贵如何，
他充满了实现目标的决心，有一个
目标，以及他多年来是如何实现这个目标的，
目标是建立、建立、组建和移动
向前迈进——一场能让人们走向前进的运动
中国，中国人民，要知道有一个
替代方案，中国共产党的替代方案，以及
怎样才能罢免中国共产党
每个人都可以按照自己选择的生活方式生活。
证据将表明，郭先生没有罪犯
意图，当本案的证据完整时，你
会明白政府正在努力拼凑出来的
不只是一群可以试着向你证明的人
存在一个真正不存在的阴谋，但也是
要求你对赚钱的方式做出价值判断以及
钱是如何花的。
因此，让我从政府的起点开始。让
我来谈谈政府花了大部分的钱
今天的时间，以及政府将花费的大部分时间
在本案的整个过程中，他们问你的那个人
定罪——郭迈尔斯。
他在中国长大，是八个男孩中的一个，每个孩子都是
其中一人从无到有，真正发了大财
财产。中国八兄弟的房地产财富
不仅价值数百万美元，而且价值成百上千

34
          南区记者，P.C.
            (212) 805-0300
O5O1GUO1 开幕——施罗夫女士
数百万美元。尽管如此，你还是会听到的
令人难以置信的成功，他在中国的财富，
郭先生离开了中国，最终来到新西安顿下来
约克。然后你会问自己，证据会说明原因
郭先生离开了中国。他离开中国是因为他参加了
中共，中国共产党，他们不高兴
完全和他在一起。中国共产党也有一个目标，
而且他们下定决心要确保自己的目标得以实现。
他们的目标是确保 Miles Guo 停止谈论
中共。
现在你已经收到了政府律师的来信
今天，他肯定邀请你讲道德观
判断，价值判断，各种判断，但他是什么
他要求你从根本上做，他要求你收到
他几乎是郭先生撒谎的法定货币。他想让你接受
郭先生撒谎是为了让人们给他钱然后
想让你接受他用那笔钱做的唯一一件事
是花在自己和家人身上的情况并非如此，
但事实并非如此。
你会听到的，就像几乎所有人一样
我们，郭文贵有不止一个方面，还有一些
方面以及在此期间你会听到的一些东西
本案的证词既令人惊讶又令人大开眼界。
因此，当你评估通过以下途径获得的证据时
目击者，当你想起 Miles Guo 的故事时，当你

35
          南区记者，P.C.
            (212) 805-0300
O5O1GUO1 开幕——施罗夫女士
想想郭迈尔斯是谁，我问你，记住然后
将他所生活的世界概念化，因为这不是我们的
世界。我们的世界没有持续不断的监视
骚扰，以及持续的监督和干扰
中国共产党。
在本案中，你将听取政府的证词
目击者证明郭先生被迫离开中国。他是
被迫离开他的妻子和女儿。两者都是
在中国监狱中被捕和关押了将近两年。
你会学习，你会有证据表明
你刚才郭先生到纽约，与其专注于
摆在他面前的所有负面因素以及他遇到的所有障碍
不得不面对，他所做的是，他开始并继续
是时候大声疾呼反对中国共产党了
这是他整天都在做的事情。那是他的目标，
为了把这个故事讲出来。然后他反复说——而且你会的
在审判中听一听——中国人民不是
共产党。这就是他想告诉人们的
那些在美国的还有那些善于思考的人
他不得不把这些人留在中国。
他打算做什么？他开始了
一场运动，讲述中共的真相。有了这个，他
开始说话，他开始写作，然后他开始说
广播，很快这在那些人中广为人知
相信他和跟随他的人中是

36
          南区记者，P.C.
            (212) 805-0300
O5O1GUO1 开幕——施罗夫女士
举报人运动。
那他说了什么？他谈了些事情
他知道的。他知道中共的腐败，那是
他说了什么。他知道腐败的某些秘密
政府官员，他就是这么说的，
具体而言。他还知道什么？他知道很多方法
中共是这样运作的，而且他知道很多方法
中共可以把一个人的生活和职业生涯搞得一团糟
以及一个人的商业生活和个人生活。
现在，一旦郭先生开始谈论中共，
对它的反应是立竿见影的，而且反应也很强烈
不只是来自那些被他所拥有的一切所迷住的人
可以说。还有另一种反应。有反应
由中共、中国共产党创作，他们也有一个
目标。他们的目标是确保他停下来。
所以当郭先生的时候你能最清楚地看到这一点，而且
证据将显示，已经在2017年4月播出了，
2017 年 4 月 19 日，他开始接受现场采访
在美国之音上。面对中共的无情欺凌
为了停下来，保持安静，郭先生决定进行直播
4月19日接受采访。那次采访是，他的目标是，
以未经审查的直播方式进行直播，这样任何人都不能
医生他要说什么那这个直播怎么了
面试？当他还在说话的时候，在演讲中间，提要
被切断，线路被切断，面试也停止了。

37
          南区记者，P.C.
            (212) 805-0300
O5O1GUO1 开幕——施罗夫女士
没有警告。没有通知。突然之间
他为确保这次面试顺利进行所做的工作
通过，它被切断了。之后会发生什么？什么
之后发生的还为你提供了一个关于世界的背景信息
郭先生必须生活和做生意。
在4月19日的采访结束后，
中国共产党发布了所谓的红色通缉令。
那就是——红色通缉令是通过国际刑警组织发出的逮捕令，
要求立即逮捕郭先生并将其引渡回国
中国。
在接受美国之音采访后，他的妻子
他的女儿在中国被中国警方逮捕。
他失去了访问社交媒体的所有权限。他的 YouTube 账户是
切断。他的推特被切断了。而且他没有访问权限
不管他能用什么方法说出自己的话
他们还切断了访问权限？他们切断了联系
有机会获得他自己或他自己的任何方法
企业可以提供任何帮助。中共入侵了他的手机。每个
他有手机，他们入侵了。他们入侵了他的电脑——他的
家用电脑和他的工作计算机。他们甚至入侵了
其他人的家用和工作计算机
协助他或与他做生意。还有这种模式
CCP的骚扰——而证据将证明所有这些
模式——不断升级并变得越来越复杂。
所以让我举一个例子来说明有多复杂

38
          南区记者，P.C.
            (212) 805-0300
O5O1GUO1 开幕——施罗夫女士
这种骚扰可能发生。
中共曾经下定决心要封锁任何人
以及中共开始汇款的每个银行账户
这些账户是以外国资产管制处名单上的人的名义开设的。
OFAC清单是由美国政府制定的清单
其中列出了参与犯罪的人的姓名
进行且不允许使用我们的银行系统。中共
使用这些名字汇款，引发人们的反应
银行的合规人员，银行关闭了他的所有人
账户，因为他们认为汇出的钱已经进去了
OFAC名单上已知罪犯的名字。
你会从政府那里听到所有这些证据
目击者，你就会知道中共有一千个
用不同的方法来和郭迈尔斯混为一谈然后试着阻止
政治运动这确实是他整个运动的精髓
存在。
证据将显示郭先生为何继续，
继续参与这场运动，以及他为何努力克服
这些障碍中的每一个。他下定决心要做
当然，这场运动幸存了下来，他想确保其他人
想加入该运动的人都能这样做。
那么郭先生做了什么？他建立了法治
基金会，他成立了法治协会。他奉献了
这两个实体都是为了确保他们为人们提供了
支持打击中共的宣传。给

39
          南区记者，P.C.
            (212) 805-0300
O5O1GUO1 开幕——施罗夫女士
他创建了一家社交媒体公司，为该运动发声。这个
政府律师对此发表了无休止的讲话。GTV。什么
是 GTV 吗？GTV是一家为传播信息而成立的真实公司
举报人运动的。GTV 的重点是买一个
未经审查的声音，不只是向信奉中国信仰的人发声
还有生活在美国的系统，还有很多，
很多留在中国的人，他们也想
成为这场运动的一部分。这就是GTV为他们提供的。
是的，GTV是众多商机中的第一个
旨在传播举报人运动的声音。
郭先生参与了GTV、农场借款项目、G/CLUBS、
和喜马拉雅交易所及其货币，H币和H
美元。这些企业是该运动的核心，
而政府辩称他们是完全错误的
不是真正的企业。本次审判中的证据将显示
与许多其他GTV不同，那台GTV是以公民为基础的
新闻网站。它允许人们公开讲话
在不受中共影响的情况下互相交谈。
农场借款项目。农场借款项目，
证据会显示的不是检察官刚才告诉你的那样
但这将表明农场借款项目是一种方式
人们可以按利率捐钱来支持
运动——他们感兴趣的运动。还有它
是人们从这些贷款中赚钱的一种方式。我提醒
你，留意所有这一切发生的时间框架。

40
          南区记者，P.C.
            (212) 805-0300
O5O1GUO1 开幕——施罗夫女士
美国和世界大部分地区正处于危机之中
疫情，人们渴望彼此互动
在线。
G/CLUBS 是什么？G/CLUBS 就是政府
这里的律师嘲笑是否应该花 X
美元买一件运动衫或运动裤——我想他说过
运动裤。那是一个人的选择，而这正是
中国不希望人们拥有什么以及该运动做了什么
希望人们有——选择。你想把钱花在那里
顺便说一句，这完全取决于你。那 G/CLUBS 做了什么
允许会员资格？如果一个人愿意，它允许他们
不管他们想支持什么代价，都支持这场运动
它。如果你想将其维持在1万美元的水平，你
可以，如果你想把它维持在5万美元的水平，
你可以。证据会显示——我问你，什么时候
证据来了，不要接受那个邀请来道德的
或者重视对人们应该花什么和如何花钱的判断
钱。问题是，证据是否表明了它的存在
真正的公司，真正的员工的存在，
有做过实际的、真正出色工作的人，
我和你遇到同样问题的人的存在
处理好我们的工作，尽我们所能把工作做得最好，因为
我们是由员工和老板选择的，因为我们有天赋，
专业知识和辛勤工作，而这些人就是工作过的人
在每家公司中。

41
          南区记者，P.C.
            (212) 805-0300
O5O1GUO1 开幕——施罗夫女士
不可否认的是，所有这些实体
是围绕郭先生的名人建造的。是的。而他是
一个早在 2017 年就开始发言并继续发言的人
说话反对中共。
你知道证据还能显示什么吗？那不是
只有其他人是投资者。郭先生的
朋友投资，郭先生的家人投资。为什么？
因为他们也是 —— 他们也相信这个运动。所以他们
投资的。他们投资了GTV，他们投资了农场，
他们投资了G/CLUBS，也投资了喜马拉雅山
交易所。他们相信了。证据将表明这些
公司像其他公司一样建立、组建在一起
业务；基础架构水平可能不一样，但是
人们相信。郭先生和我们许多人一样，有一个
愿景，有了一个主意。他没有完全拥有的是
你我为我们的日常生活带来的基础设施。什么时候
他刚开始，几乎不会说英语。他是
这个国家的新手。他对事情的态度不熟悉
完成了。是的，你会听到他说话的录音
用要求很高的声音，一瞬间完成工作，
有时甚至会显得非常笨拙
一个人就是这么多。这是否意味着他是罪犯？
没有。这是否意味着他犯下了这些罪行？证据
会显示不是。再一次，证据将显示的是
他雇用的人是有能力的人

42
          南区记者，P.C.
            (212) 805-0300
O5O1GUO1 开幕——施罗夫女士
为这些业务中的每一项做出贡献。
我想现在政府会花一些钱
是时候引入有关两个人的证据，王维平
还有 William Je，我问你，当你听到证据时
政府投入一些精力，密切关注什么
这些人每个人都扮演的角色。证词将显示
那就是王女士是运营主管。她跑了
每项业务的日常。她负责招聘。她
尽了最大努力雇用人员，而她的招聘做法是
和你或我一样。她雇用了她在那段时间遇到的人
在她的生意中，她通过猎头雇人
她需要一个人或一个空位来填补。而且她已经不在了或
承诺不亚于任何人，要求不低于或不亚于任何人
另一位在职的首席执行官。
William Je 是证词的另一个名字
节目，而威廉·杰是财务专家。他是一个备受推崇的人
投资银行家，他管理的不仅仅是财富
Guo 家族有资金但他管理了其他许多人的财富
公司。他有专业知识，有技巧，这就是为什么他
是财务专家。
而且我已经详细谈到了郭先生，他
是那个主意的人。他想出了主意然后他提出了
将该运动的思想和愿景结合在一起
他相信会是什么样子。
所以你看，在这场运动中，他并不孤单。他

43
          南区记者，P.C.
            (212) 805-0300
O5O1GUO1 开幕——施罗夫女士
不是全靠他自己动的。事实上，这就是为什么
叫做 “举报人运动”。关键是要有
其他人加入并参与。
那么，归根结底证据会显示什么？
证据将表明，这些公司都雇用了
并让人们为真实存在而努力
商业。他们相信了，郭先生也相信了。郭先生
相信这场运动。所以当政府律师问的时候
你并让你相信郭先生诈骗了会员
在这场运动中，政府对你说的是
他故意误导支持者偷钱，同样
他们捐给该运动的钱，他给的运动
他几乎把一生都献给了这个运动
他逃离了中国，他所忍受的运动是
每天都在关注他手机的动作
被黑客入侵，他的妻子和女儿参与的动作
入狱两年，以及他没有参加的运动
获准离开美国并在美国境外旅行，
他冒着生存的风险去运动。就是这样
他们说他打算造成伤害。他们说他设定了
出去伤害那个差不多是延期的东西，a
他是谁的共生延伸。而且他甚至做了所有这些
尽管他从家庭基金中获得了一笔财富，这使他能够
过着奢华的生活。政府要你相信什么
不仅不合逻辑；它违背常识。

44
          南区记者，P.C.
            (212) 805-0300
O5O1GUO1 开幕——施罗夫女士
我请你考虑一下。所有的证据都表明
政府律师谈到了——财富，数百万人
他居住的曼哈顿价值一美元的豪华酒店，
游艇，床垫，不管他说的是什么 —— 你
知道证据会显示什么吗？证据已经出来了
为了证明不管这些证人还对你说了什么
早在政府执政之前，郭先生就有这样的生活方式
声称他犯下了这种欺诈行为。
西装、运动裤、房子、证据都会
清楚地表明，这是他几十年来的生活方式，好吧
在政府说他赔钱之前，好吧，早在之前
所有这些甚至是政府心目中的一个想法。而且
它肯定持续到今天，并且持续了好几天
因为家族基金将永远支持郭先生。
我请你考虑一下，因为政府
确实邀请你做出这样的价值判断。对于一个人来说很容易
一个人判断他人要么肤浅，要么富有，但很肤浅
或者富人不等于罪犯。那并不意味着
政府的推断是正确的。
证据将清楚地表明郭先生没有
需要偷钱才能购买 Brioni 西装。这些都不是
他为保住自己所经历的所有困难是值得的
中共被拒之门外。这里的证据将显示的是，郭先生
没从 GTV 偷钱，他没有从 GTV 偷钱
农场贷款计划，他没有从G/CLUBS偷钱，而且他

45
          南区记者，P.C.
            (212) 805-0300
O5O1GUO1 开幕——施罗夫女士
没有从喜马拉雅交易所偷钱。
政府还将邀请你思考，
请你得出结论，郭先生这样做的原因是肯定的
事情是因为他参与了犯罪活动。
（下一页继续）

46
          南区记者，P.C.
            (212) 805-0300
O5OVGUO2 开幕——施罗夫女士
SHROFF 女士：那政府还能做什么
从证据的角度引出？政府要寻找
得出郭先生经常换电话；
他有将近成百上千部电话。而且他
有这些电话，而且他经常换号码
因为他不想让人们知道他在做什么。
我请你考虑一下：如果你曾经是 
中共不断黑客攻击的目标，如果你曾经是 
目标是人们用你的声音监听你的手机 
模仿你的录音，难道你不也改一下你的 
经常打电话？   
如果你一直害怕受到威胁 
被绑架、杀害、移动，难道你也没有这样的车吗 
不告诉别人你将在何时何地被带走？  
合乎逻辑的是，被监视的人就是这样 
会以这种方式生活。如果你是郭先生而你是 
经常成为攻击目标，难道你不想要一个安全的吗 
举行商务会议的地方？你不会建立基地吗 
你想与之做生意的人可以来这里见面 
与你同在，不受干扰和失真 
中共？   
对于他们投入的每一份财富证据 
在，你会同样公平地推断出他拿了那些 
步骤不是作弊，不是沉迷，而是要确保 
尽管中共扭曲了局面，但运动还是得以幸存。

47
          南区记者，P.C.
            (212) 805-0300
O5OVGUO2 开幕——施罗夫女士
当他们和你谈话时，我请你记住
银行账户，哈哈，房屋，问问自己，一个人为什么会
必须开一个银行账户，当然，除非每次
银行账户已拥有，OFAC 名单上有人存款
资金存入您的账户并遵守了规定。那是
为什么必须在上下文中评估郭先生的行为的原因
以及他本应存在的生活方式。
因此，政府将提出证据。还有我
请你记住，对于每份证据
进入他们体内，从他们那里得到的必要推断不是
准确的。他们要求你从提交的文件中推断出来
破产，郭先生根本没有钱。
现在，不管我们认为这是公平的还是我们认为的 
不公平，富人经常宣布破产。个人破产 
并不意味着贫困。这些推断都不正确。而且 
当你听到这方面的证据时，我请你考虑一下情况如何 
是那个郭先生，他当时没有任何个人资产 
时间，因为中共是没收他的财产的人。   
曾经有一段时间 —— 你会听到证据 
在 —— 郭先生将被处以将近1亿美元的罚款 
几天之内。这就是导致申报的原因 
破产。但是政府要求你这样做 
再说一遍，得出有罪结论是错误的要求。   
在本案中，政府将争辩说 
郭先生的所作所为简直是非法的。他们会让你说

48
          南区记者，P.C.
            (212) 805-0300
O5OVGUO2                  
你可能会受到迫害，但你仍然可以成为骗子。以及什么时候 
他们问你这个问题，我请你考虑一下证据是怎么回事 
表明他们错了。政府不只是这么说 
有欺诈行为。政府要你做的是 
得出结论，郭先生欺诈本质上是因为 
他是运动，运动是他。 
所以当他们要你看看证据时
这就进来了 —— 财富的证据，财富的证据
消费，奢侈品的证据 — 我请你评估一切
我所描述的背景下的证据。而且，如果
你这样做，如果你评估证据，明白是怎么做的
这些实体很难生存，以及每个实体是如何生存的
在这些实体工作的一位人努力工作
保持并向前移动，你将达到唯一的动作
本案的合乎逻辑的结论：郭先生无罪
起诉书中的12项罪名。谢谢。
法庭：陪审团成员，我想提醒你
关于我们的试用时间表。每天，每个工作日，你都会
早上 9:30 进入法庭。到九点钟，
你可以吃一顿清淡的早餐，这样你就可以来了
早期。但是你必须准备好在 9:30 进入法庭。
因此，总的来说，我们将在两者之间休息半个小时
11:30 和 12 点；我还会为你准备一顿简便的午餐。而且
然后我们会一直持续到 2:45。通过这样压缩日程安排，
直到下午 5 点我才会占用你一整天。我很清楚

49
          南区记者，P.C.
            (212) 805-0300
O5OVGUO2                  
你白天还有其他重要的事情要做，以及
所以这就是我用这种方式设计时间表的原因。
因此，此时我们将花半个小时
打破。
（陪审团不在场） 
法庭：你可以坐下。律师，有没有
在我们半小时后回来之前有任何东西吗？
费根森先生：不，法官大人。
法庭：你准备好第一位证人了吗？
弗根森先生：是的，法官大人。
KAMARAJU 先生：不是来自辩方，法官大人。
法院：好吧。
（午餐会休会） 
（下一页继续）

50
          南区记者，P.C.
            (212) 805-0300
O5OVGUO2                  
A F T E R N O O N S E S S S I O N 
下午 12:10 
（在侧边栏上） 
法院：我有一封192号陪审员的照会。我不知道
记住他的号码，他在陪审团中的实际号码。
KAMARAJU 先生：他是候补者是有道理的。
BARKAN 先生：法官大人，192 是备选方案 5。
法庭：好吧。备选方案 5.  
致尊敬的 A. Torres：   
我对自己的借口深感失望 
未获准解雇。我的请求是从 “我正在工作” 开始的 
单身父亲。父亲节我的孩子会去实地考察 
茶道和毕业典礼。而且我现在将无法 
出席。当学校在 6 月 18 日结束时，我将无法 
带她去露营。我的家人离得很远，无法提供帮助 
定期地。我是个鳏夫。我的妻子在分娩时去世了。  
因此，能够为我的孩子做点什么非常重要。   
我刚刚得知需要聚会 
在约定时间的位置。我在 8 点送孩子下车 
上午进行的任何调整都会使我、我的家人付出代价， 
工作很认真，更不用说数千美元了。我没有 
详细说明我的工作职位以及如何要求我完成工作。  
根据我的家和生活，我认为我的要求是合理的 
情况就足够了。   
对于律师们，我很感激你们的信心

51
          南区记者，P.C.
            (212) 805-0300
O5OVGUO2                  
在我的选择中。你真的把我搞砸了。   
第 192 号陪审员。 
SHROFF 女士：他是那些在法官任职的绅士
麦克马洪的陪审团。我想他在旁观的时候是这么说的
死了。
法庭：你想让我做什么？
SHROFF 女士：我说我们放开了他。我们有六个；我们可以
和五个人一起生活。
芬克尔先生：所以，法官大人，政府没事
有五名候补。但是，我们听从法院的意见
如何传递信息的恰当性。还有
政府的担忧将是向其他人传达信息
陪审团只要给法院发一封信就会允许
他们将被免职。  
政府不反对继续下去 
五名候补委员；请法院行使自由裁量权即可 
及其在如何交付时机方面的经验 
消息。 
法庭：所以我还被告知陪审员不是
对他们在接送点会面的安排感到满意
然后乘车去法院。XXXXXXXXXXXXXXXXXXXXX
XXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXX
xxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxx
KAMARAJU 先生：法官大人，我们没问题。
法院：因此，这位5号候补陪审员不是

52
          南区记者，P.C.
            (212) 805-0300
O5OVGUO2                  
还知道所提供的替代方案。我随时可以带
他进来问问他这种改变是否可以接受
他，看看他在说什么。
SHROFF 女士：如果法院的话，我们把它留给法院
想问他。但是正如他所说，他似乎很生气
关闭。所以我倾向于放开他。但也许
法院可以考虑我们是否让他坐一整天
然后我们让他知道星期一不要来，然后
假设 —— 要么告诉陪审团，你知道，这是
新池但没有提供任何解释，这样他们就不想了
有人偷了点什么逃脱了
法庭：我一定会让他坐下来的
一天，我们结束之后我会和他谈谈
天。好吧。
芬克尔先生：法官大人，我们面前有一份申请
离开。就是陪审员要去的地点
会议应在公开记录中盖章，原因是
政府在议案中指出，地点是
陪审员将不与被告同席开会。
法院：我认为这是完全恰当的。
SHROFF 女士：我们甚至不知道他们要去哪里
要见面，所以我们没什么可分享的。
法庭：好吧。因此，这些物品将被密封。
芬克尔先生：谢谢你，法官大人。
（下一页继续）

53
          南区记者，P.C.
            (212) 805-0300
O5OVGUO2 McNamara-Direct
（在公开法庭上） 
法庭：你能让陪审员回来吗
拜托法庭。
（陪审团出席） 
法庭：请坐下。
政府会传唤第一位证人吗。
芬克尔先生：是的，法官大人。  
政府给艾琳·麦克纳马拉打电话。 
 艾琳·麦克纳马拉， 
     被政府传唤为证人 
     经正式宣誓后, 作证如下: 
法院：请说出你的名字并拼出来。
证人：艾琳，E-R-I-N；McNamara，
M-C-N-A-M-A-R-A。
法庭：请把麦克风拉向你。
如果你愿意，你可以把它弯曲。
你可以询问。 
芬克尔先生：谢谢你，法官大人。
直接检查 
作者：芬克尔先生：  
问：下午好。
答：下午好。
问：你在哪里工作？
答：我是联邦调查局纽黑文战场的特工
办公室。

54
          南区记者，P.C.
            (212) 805-0300
O5OVGUO2 McNamara-Direct
问：你在联邦调查局工作多久了？
A. 26 岁。
问：在你成为联邦调查局特工之前，你做了什么（如果有的话）？
答：我曾是State Farm的汽车承销商。
问：特工麦克纳马拉，什么是 ERT？
答：这是一个证据响应小组。
问：你能否向陪审团成员描述一下
证据响应小组确实如此。
答：当然。证据响应小组，他们是全局性的。他们
是接受过犯罪现场额外培训的人
管理和法医证据收集.
问：特工麦克纳马拉，你扮演什么角色（如果有的话）
ERT？
答：我是纽黑文团队的高级组长。
问：什么是搜查令？
答：搜查令是从搜查令获得的文件
法官，通常调查员会明白。它解释了它是什么
你被允许搜索以及你是什么样子
允许搜查和扣押。
问：特工麦克纳马拉，我想提请你注意
2023 年 3 月 15 日。关于你在ERT的角色，什么，
如果有的话，那天你做了吗？
答：我们在美国塔科尼克路373号执行了搜查令
康涅狄格州格林威治。
问：康涅狄格州格林威治是什么样的社区？

55
          南区记者，P.C.
            (212) 805-0300
O5OVGUO2 McNamara-Direct
答：这是一个非常富裕的社区。
问：你会如何描述塔科尼克路 373 号？
答：这是一座漂亮、漂亮的豪宅。很大，很漂亮
院子，游泳池，网球场。而且我相信它甚至接近
高尔夫球场。
芬克尔先生：洛夫特斯女士，我们可以为... 展示一下
见证被标记为 GX 133 的物品。
问：特工麦克纳马拉，什么是 GX 133？
答：这是格林威治塔科尼克路373号的鸟瞰图。
问：那是一张塔科尼克路 373 号的公平而准确的照片吗？
在格林威治？
答：是的。
芬克尔先生:政府的提议133.
法院：没有异议？
SHROFF 女士：不，法官大人。
法院：承认。
（收到的政府证据 133 作为证据） 
FINKEL 先生：如果我们能发布的话，
洛夫特斯女士。
问：特工麦克纳马拉，是你当天的天气
在 373 Taconic 和我们在屏幕上看到的一样吗？
答：不，地上有雪。
问：你大约是什么时候到达塔科尼克的 373 号的
3 月 15 日？
答：早上 7 点左右

56
          南区记者，P.C.
            (212) 805-0300
O5OVGUO2 McNamara-Direct
问：当你到达时，联邦调查局有搜查令吗？
答：是的。
问：为了什么？
答：用于塔科尼克路 373 号及其场地。
问：联邦调查局当天有逮捕令吗？
答：是的。
问：为了谁？
答：郭文豪。
问：郭迈尔斯是否在 373 Taconic 出席？
答：不是。
问：373 岁时除了联邦调查局人员之外还有其他人在场吗
Taconic？
答：是的，有三名居民。有一个更年长的
女性、年轻女性和男性。我的理解是
是妻子、女儿和女儿的男朋友。
问：谁的妻子、女儿和女儿的男朋友？
答：郭先生。
问：他们叫什么名字？
SHROFF 女士：反对。
法院：驳回。你可以这样说。你可以
回答。
答：那个女儿是 Mei —
SHROFF 女士：请问我们能靠近一会吗？
法庭：好吧。
SHROFF 女士：谢谢。

57
          南区记者，P.C.
            (212) 805-0300
O5OVGUO2 McNamara-Direct
（在侧边栏上） 
SHROFF 女士：法官大人，女儿的名字是
非实质性的。她一直是许多在线评论的主题
离线骚扰。她今天甚至没出庭因为她
不想被识别。她没有出庭
尽管她是为父亲献身的，但还是露面，因为
她经常受到骚扰。
我们从来没有对他们提出过异议 
未透露证人姓名。而且没有相关性 
改成她的名字。它与任何人都无关 
在这里提问。尽管如此，她的名字可能是索尼娅·甘地 
小心，但不需要使用她的真实姓名。 
FINKEL 先生：这很重要，因为上面有她的名字
文件，妻子的名字也是，妻子的名字也是如此
女儿，男朋友或未婚夫。
此外，我应该指出它与这里有关。  
Shroff 女士公开了妻子和女儿的事实 
他们与他的关系。她的名字在文件上。我们 
需要解释她是谁。这很重要。 
法庭：骚扰者已经知道她的名字了。
SHROFF 女士：她不在法庭上。她没来
上法庭支持她父亲因为她受到了骚扰
法官大人。而且我在开场白中没有提到她的名字
出于特定的原因，这很明显我没有使用
妻子的名字和女儿的名字。而且我认为这张唱片

58
          南区记者，P.C.
            (212) 805-0300
O5OVGUO2 McNamara-Direct
在这一点上不言自明。
法庭：那么这些名字上面的事实是
文件使她的名字很重要。但是，中国人
共产党监禁了妻子和女儿。我敢肯定他们
知道这个名字，还有很多其他信息。  
该异议被驳回。 
SHROFF 女士：法官大人，不是中国人
共产党，是引用/取消引用的受害者。
法院：驳回了裁决，施罗夫女士。
SHROFF 女士：谢谢。
（下一页继续）

59
          南区记者，P.C.
            (212) 805-0300
O5OVGUO2 McNamara-Direct
（在公开法庭上） 
法院：你可以回答。
答：女儿是 Mei，M-E-I；Guo，G U O。妈妈，我
只记得她的姓是 Ngok，N-G-O-K。而那个雄性，它
是 Cao，Cao。
问：你还记得那个男性的名字吗？
答：我不知道。
芬克尔先生：洛夫特斯女士，如果我们能为之展示的话
证人 3514-48。如果可以的话，请转到其中的第 2 页。
其实，法官大人，我可以靠近吗？ 
法院：你可以。
问：特工麦克纳马拉，你能不能看着屏幕
底部。问题是这是否能让你精神焕发
回想起女儿男朋友的名字？
答：是的。
芬克尔先生：洛夫特斯女士，你能不能把它记下来，
拜托。
问：特工麦克纳马拉，女儿的男朋友是什么
名字？
A. Defeng，D-E-F-E-N-G。
问：特工麦克纳马拉，你在这方面扮演了什么角色
在 373 Taconic 搜寻？
答：我曾经是一名协调员。我确保我们有我们需要的材料
需要，关于谁来拍照的任务，回答
问题；只要确保搜索持续进行即可

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          南区记者，P.C.
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而且一切都完成了。
问：那团队正在寻找什么样的物品
为了？
答：手机、计算机、业务记录等电子产品
财务记录，照片，类似性质的东西。
问：顺便说一句，特工麦克纳马拉，除了你之外
参与了 3 月 15 日的搜查，你参与了吗
关于郭文亮的调查？
答：不是。
问：如果你没有参与郭文亮的调查，
你能不能向陪审团成员解释一下，如果有的话，你为什么
那天正在参与搜查吗？
答：当然。这是纽约的要求。他们有多个
搜查令，所以他们需要协助才能执行搜查令。
而且既然在格林威治，它就在我们的领土上
康涅狄格州，所以他们向我们寻求帮助。他们要求我们
提供所需的人员、物资和物品
进行搜索。
问：这种情况在联邦调查局内部是否经常发生？
答：是的。
芬克尔先生：法官大人，此时我想读一读
对当事人的规定。
法庭：来吧。
不过，在你阅读规定之前，我想先了解一下 
让陪审员知道什么是规定。

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          南区记者，P.C.
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规定是双方达成的协议
在不传唤证人的情况下向陪审团提供证据
讨论主题的目的。
来吧。 
芬克尔先生：特此规定和同意
美国和被告郭文豪：  
如果在审判中被传唤为证人，特工 
联邦调查局FBI将作证为 
如下： 
2023 年 3 月 15 日，特工和其他联邦调查局
员工对373人进行了司法授权的搜查
康涅狄格州格林威治塔科尼克路。在此过程中
那次搜查，联邦调查局人员拍了外面的照片和
康涅狄格州格林威治市塔科尼克路373号的内部空间
还合法没收了文件和电子设备。
政府展品 GX CT-20 至 GX CT-30、GX
CT-35 到 GX CT-72，GX CT-74 到 GX CT-105 都是公平的
373 个内部和外部空间的准确照片
康涅狄格州格林威治的塔科尼克路是合法的
由 FBI 摄影师于 2023 年 3 月 15 日拍摄，当时
进行搜索。
在 2023 年 3 月 15 日的搜查之后，联邦调查局的工作人员 
扫描和拍照合法没收的文件 
在搜索过程中。GX CT-101 到 GX CT-129，GX CT-157 
通过 GX CT-187、GX CT-190 到 GX CT-202，以及 GX CT-204

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          南区记者，P.C.
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通过 GX CT-207 是真实而正确的文档副本 
在 2023 年 3 月 15 日搜查 373 个 Taconic 时被查获 
路，格林威治，康涅狄格州。   
还进一步规定并同意 
规定是 GX STIP-1，可以作为证据 
作为政府在审判中的展品。而且它是由... 签名的 
派对。   
法官大人这样政府就提供了 GX 
STIP-1。 
法院：可以接受。
（收到的政府展品 STIP-1 作为证据） 
芬克尔先生：而且政府提供了 GX CT-20
通过 GX CT-30，GX CT-35 到 72，GX CT-74 到 105，GX
CT-101 到 129，GX CT-157 到 187，GX CT-190 直到
202，以及 GX CT-204 到 207。
法院：他们被接纳了。
（政府的展品 CT-20 至 CT-30、CT-35 
直到 72，CT-74 到 105，CT-101 到 129，CT-157 
直到 187，CT-190 到 202，CT-204 到 207 已接收 
证据） 
芬克尔先生：谢谢。
作者：芬克尔先生：  
问：特工麦克纳马拉，你看过 373 的各个方面了吗
2023 年 3 月 15 日的 Taconic？
答：我没有。

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          南区记者，P.C.
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问：搜索花了多长时间？
答：不到四个小时。
芬克尔先生：我们可以出示证据中的证据
如政府展览 GX CT-87。  
问：特工麦克纳马拉，陪审团在 GX 中在看什么
CT-87？
答：那是塔科尼克路373号的外部照片。
芬克尔先生：如果我们能停下来，请停下来，GX Loftus 女士
CT-25。它不在你的屏幕上？如果你能发布那个
拜托，洛夫特斯女士。它没有出版。谢谢。对不起
关于那个。
问：特工麦克纳马拉，什么是 GX CT-25？
答：那是塔科尼克路373号的另一张外观照片，后方
房子的。
芬克尔先生：洛夫特斯女士，如果可以的话请发布 GX
CT-91。
问：特工麦克纳马拉，什么是 GX CT-91？
答：这是房子的一面，有两个车库的一边。
问：在搜寻 373 Taconic 的过程中，有没有发生过什么时候
你进入了我们在 GX CT-91 中正在看的车库？
答：是的。
问：哪个车库？
答：两者都是。
问：车库里有什么（如果有的话）？
答：在你看的时候在照片右边的车库里

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          南区记者，P.C.
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那是一辆红色的兰博基尼。
芬克尔先生：如果可以的话请显示 GX CT-95。
问：特工麦克纳马拉，这是你去的车库吗
进去看见了红色的兰博基尼？
答：是的。
芬克尔先生：如果可以的话请展示 GX CT-38。
对不起。看来我们的电脑冻结了。忍受 
我们。道歉。 
问：当我们等待电脑醒来时，
发生了，对不起，特工麦克纳马拉，什么，如果有的话，
2023 年 3 月 15 日的兰博基尼发生了什么？
答：它被没收了。
问：那是根据逮捕令的吗？
答：没错，有扣押令。
问：联邦调查局能否找到兰博基尼的钥匙？
答：是的。
问：那他们在哪里？
答：在屋子里。
问：那天你看到钥匙了吗？
答：我做到了。
问：特工麦克纳马拉，什么是 VIN 号码？
答：这是车辆识别码。这个数字是
每辆车都是独一无二的。
芬克尔先生：如果可以的话请展示 GX CT-42。
问：特工麦克纳马拉，大约有多少联邦调查局

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人员参与了搜查？
答：大约 40 岁。
问：那你有没有从家的一侧走到另一边？
答：我没有 —— 不，不是在每个楼层都不是，我没有。
问：你在任何一层楼上吗？
答：一楼。
问：从一侧到另一侧花了多长时间？
答：我不知道。我从一端多次被拦住了
另一个。
芬克尔先生：如果可以的话请展示一下，Loftus 女士，GX
CT-41。
问：特工麦克纳马拉，373 Taconic 看起来像是不是一个
曾经住过的家？
答：是的。
问：为什么？
答：有衣服、鞋子、食物、洗漱用品、狗。他们
有两只狗。狗床。
FINKEL 先生：等着我们的电脑开机就行了
合作这样我们才能继续。
问：好吧。特工麦克纳马拉，我们在看什么
在 GX CT-41 中？
答：那是车库里兰博基尼的VIN号码。
问：ERT 在以下方面有任何做法或程序吗
汽车上的 VIN 号码？
答：是的，我们总是拍照 VIN 号码，因为它是唯一的

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          南区记者，P.C.
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标识符，例如计算机上的序列号。
芬克尔先生：法官大人，我可以靠近吗？
法院：你可以。
芬克尔先生：我已经把发生的事情交给了证人
标记为政府展品36，以供鉴定。
问：特工麦克纳马拉，你能看看政府展览吗
36，拜托。
答：这是兰博基尼的钥匙。
问：这些钥匙有唯一的识别标记吗？
答：标签上有部分的 VIN 号码。
问：那部分 VIN 号的结尾是什么？
A. 10393。
问：这与 GX CT-41 中的 VIN 号相匹配吗？
答：确实如此。
芬克尔先生:政府的提议36.
法院：可以接受。
（收到的政府证物36作为证据） 
芬克尔先生：法官大人，我可以把它公布给陪审团吗？
法院：你可以。
芬克尔先生：如果我们能为证人出示，
拜托，政府展览 GX CT-209。只为证人准备的
问：特工麦克纳马拉，密钥是从哪里找回的？
答：有一个 —— 那是一个房间，我会这样称呼它
办公室/保安室。有保安监视器
里面有摄像头。还有一张桌子。

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芬克尔先生：请稍等片刻。
芬克尔先生：请给证人看 GX CT-209。
问：特工 McNamara 什么是 GX CT-209？
答：那是搜查中的另一张照片。
问：这是你在上面看到的一张公平而准确的照片吗
2023 年 3 月 15 日？
答：是的。
芬克尔先生：政府提供 CT-209。
法院：可以接受。
（收到的政府展品 CT-209 作为证据） 
芬克尔先生：你能不能把它发布出来。
陪审团能看见吗？不是？现在你可以了。好吧。太棒了。 
问：特工麦克纳马拉，你知道那些旗帜是什么吗？
答：不是。
FINKEL 先生：我们现在可以展示里面的内容了
作为政府展品 CT-58 的证据。
问：特工麦克纳马拉，我们在 GX CT-58 中看的是什么？
答：373 号房子里一间房间的照片
塔科尼克路。
问：除了我们现在的样子，那个房间里还有什么（如果有的话）
看着？
答：哦，相机。就像摄像机一样。
问：你知道为什么里面有摄像机吗？
答：不是。
芬克尔先生：请看看，洛夫特斯女士，GX CT-59。

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问：什么是 GX CT-59？
答：那是那个房间，同一个房间的另一张照片。
FINKEL 先生：如果可以的话，洛夫特斯女士，尽情展示一下
证人 GX CT-208。拜托，这只是给证人的。
问：特工麦克纳马拉，我们在 GX 中在看什么
CT-208？
答：那是搜查中的另一张照片。我就是这样
会给客厅打电话。
芬克尔先生：政府提供 GX CT-208。
法院：可以接受。
（收到的政府展品 CT-208 作为证据） 
芬克尔先生：请把这个发布出来，洛夫特斯女士。
如果可以的话请展示政府展品GX CT-83, 
这是显而易见的。 
问：你知道衣服上的那些徽章是什么吗？
答：不是。
芬克尔先生：洛夫特斯女士，如果我们能展示 GX CT-80。
拜托 80。八个零。这是明证。
陪审团能看出来吗？不是？   
请问我们能不能把它公布给陪审团。 
问：这些是你之前提到的壁橱吗？
答：是的。
问：特工麦克纳马拉，你说有些文件是
那天康复了；对吗？
答：是的。

69
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问：你看过文件了吗？
答：不是。
问：还有其他团队成员吗？
答：不是。
问：这些文件在收集后发生了什么
2023 年 3 月 15 日，你知道吗？
答：它们是收集的，经过包装的，而且是
移交给纽约。
问：纽约外地办事处正在管理这个
调查；对吗？
答：是的。
SHROFF 女士：反对领导。
法庭：你可以问一下谁在领导这件事
调查。
作者：芬克尔先生：  
问：特工麦克纳马拉，哪个外地办事处（如果有的话）是
引导对此事的调查使你明白？
答：纽约。
芬克尔先生：我们可以出示证据中的证据
也适用于证人和陪审团 GX CT-201。如果你能去
请看第二页。
问：特工麦克纳马拉，你能读懂它在上面说的话吗
顶部？
A. Brioni，麦迪逊大道 688 号，纽约，纽约，10065。
电话号码：212-376-5777。

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          南区记者，P.C.
            (212) 805-0300
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问：它在顶部的绿色单元格里说了什么
图表？
答：郭文贵先生定制订单的发票。
问：你知道布里奥尼是什么吗？
答：不是。
芬克尔先生：如果我们能转到下一页，
洛夫特斯女士。更确切地说，是第 4 页。你能放大一下吗。我们可以
请转到第 5 页。如果可以的话请把里面的东西拿出来
证据是 GX CT-205。对不起，207。对不起。
应该将其公布，以便陪审团看到。如果 
我们可以转到下一页。而且你能放大吗 
拜托了，洛夫特斯女士。 
问：特工麦克纳马拉，你能读懂 “背景” 吗？
A. 执行版本。贷款协议。本协议（这个
协议）于 2020 年 6 月 3 日在 GTV 之间签订
Media Group, Inc.（贷款机构），一家特拉华州公司
办公地址位于纽约州纽约市东 64 街 162 号 
10065，以及萨拉卡媒体集团公司（借款人），a
特拉华州公司，办公地址在东 64 号 162 号
街，纽约，纽约，10065。每个人都是 “一起聚会”
派对。
芬克尔先生：洛夫特斯女士，如果你能走到最后一刻
请查看本文档的页面。你能放大一下吗。
问：根据这个，谁是授权签字人
Saraca Media Group Inc. 的文件，特工麦克纳马拉？

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答：我会把这个发错音的。强，Qiang，Qiang，Guo。
芬克尔先生：谢谢你，洛夫特斯女士。
如果我们能为派对提出 GX CT-198 
还有陪审团。如果你能转到下一页 
拜托。 
问：特工麦克纳马拉，你能读一下这份文件吗。
答：亲爱的哈里·埃克尔斯-威廉姆斯先生，我写这封信给
请求并同意发布我的所有文件
尽快从你的公司到郭强。大多数
重要的是，我和 Appleby 之间的关系，
Well Origin 和 Appleby 之间的关系。谢谢。
你真诚地说，郭文贵。
芬克尔先生：洛夫特斯女士，如果我们能提起的话，
GX CT-157 适用于陪审团和当事方。
没关系。照原样就在那里。 
问：特工麦克纳马拉，你能读懂其中的最重要部分吗，
拜托。
A.G talks 节目。
问：你能读下上面写的是早上 7:48 吗？
答：主持人利玛丽·雷耶斯欢迎你。
问：谁是 Limarie Reyes？
答：我不知道。
芬克尔先生：请允许我们展示 GX CT-172。
没关系，洛夫特斯女士。 
问：特工麦克纳马拉，你能读懂 GX CT-172 的顶部吗。

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          南区记者，P.C.
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答：不准用词清单破折号 —— 对不起，是想法。
芬克尔先生：洛夫特斯女士，你能向下滚动一点吗
位。
问：特工麦克纳马拉，你明白上面写着 “贷款” 了吗？
答：是的。
问：你能读懂 “贷款” 之后的字吗。
A. 一个或多个合作伙伴、增长、增长预测、合资企业
伙伴关系，未来的投资收益，未来的机会，
参与/参与业务或利润，GTV，Saraca，
郭之声/善良之声（VOG）、法治基金会、规则
加拿大喜马拉雅律师协会、张云富、淫荡、王怡平
伊平、莎拉、花木兰、美国证券交易委员会、调查、诉讼、黄金
弹簧，监管机构，司法部。
问：什么是司法部？
A. 司法部。
问：什么是美国证券交易委员会？
A. 证券交易委员会。
芬克尔先生：洛夫特斯女士，如果我们能提起的话，
GX CT-174。
问：你能读出上午 8:20 在哪里吗
答：郭文亮先生的现场问答，预选问题。
FINKEL 先生：Loftus 女士，如果你能展示的话
仅见证 GX CT-210。
问：特工麦克纳马拉，什么是 GX CT-210？
答：这是搜索中的一张照片。

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芬克尔先生：政府提供 GX CT-210。
SHROFF 女士：反对，法官大人。
法庭：如果你愿意加紧努力，拜托。
芬克尔先生：我可以再打一个基础。
问：你如何认出这张照片是其中一张
搜索中的照片？
答：我查看了照片。
问：好吧。你看见 373 Taconic 的这个特殊区域了吗
搜查的那一天？
答：我不记得了。
问：好吧。联邦调查局是否保留拍摄的照片
在联邦调查局正常业务过程中进行搜查时？
SHROFF 女士：反对。联邦调查局的通常所作所为
不相关。
法院：驳回。你可以回答。
答：是的。
问：而且你说你查看了照片中的照片
搜索。你能解释一下你的意思吗？
SHROFF 女士：反对领导。
法院：驳回。你可以继续。
答：所以我们有 —— 我们保留了一份照片的副本
搜索。当我被要求来这里时，我对此进行了审查
刷新我对搜索的记忆。
问：还有搜查中的照片，是吗
保存在联邦调查局的记录中并以这种方式保存？

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答：是的。
SHROFF 女士：反对。她没有个人信息
知识。
法院：加紧努力。
（下一页继续）

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          南区记者，P.C.
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（在侧边栏上） 
法庭：所以她对这些照片很熟悉
从搜索结果来看。
芬克尔先生：所以，法官大人，她是团队负责人而且
她熟悉 ERT，包括其记录保存
实践。首先，我想她能认出其中的一部分
照片，但这无关紧要。她可以放一个
803（6）基金会是搜查时拍摄的照片。
她知道这张照片是和那张照片一起存放的
搜索。  
我会为有人拿走它打下基础 
在事件发生时已知并予以保存 
在联邦调查局的业务过程中。   
这是一张照片。我们可以奠定基础。 
SHROFF 女士：政府非常清楚自己有一个
这里有问题。他们今天早上要我为此作出规定
出庭作证但我拒绝了，因为他们无法
奠定基础。事实是——
法院：基金会缺什么？
SHROFF 女士：法官大人，第一，她没拿
照片；第二，她没有看证据；
第三，她没看过那个特别的场景；数字
四，她坐下来用这种方式作证的唯一原因是
因为政府把他们拍的照片给了她
来自联邦调查局小组的其他成员并给她看。

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          南区记者，P.C.
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她对这个特别的个人了解为零 
照片。更不用说联邦调查局里的一张照片了 
文件属于业务记录的例外情况。要么 
她对此有个人了解或者不知道，而且很明显 
她没有，法官大人。   
此外—— 
法庭：这不是正常的吗
生意？
SHROFF 女士：不属于这个例外，
因为异常应该捕捉到一些东西，也就是说，
第一，商业记录，但事实并非如此；这是证据
聚会。顾名思义，联邦调查局收集的文件是
自私自利，因为他们已经做好了准备
诉讼。但是从技术上讲，它们不属于
业务记录例外。
第二，这张照片的拍摄方式是 
不是家中场景的照片。那又怎样 
他们做的就是把整栋房子都拆了 
把所有的太阳镜都拿出来，放在桌子上，然后拿了一个 
照片。你可以从照片中清楚地看出这一点 
来自堆在它们旁边的箱子。   
所以这个人没有做底层事情 
搜索太阳镜，没有把太阳镜放在那里， 
而且她对这一切的个人了解为零。 
法庭：但是这张照片是在法庭期间拍摄的

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          南区记者，P.C.
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搜索过程。
SHROFF 女士：她不会知道的。它本来可以有
是这个搜索，可能是又一次搜索，可能是
在那之前一直在搜寻。她不知道这是什么时候
照片是拍的。
芬克尔先生：请允许我提出几点看法。
首先，如有必要，我们可以再带一个 
人只需验证一张照片即可。各方有 
在规定真实性方面表现良好， 
今天早上突然发生了变化。   
第一，我相信如果我问证人，你会吗 
认出这张照片的任何组成部分，她会说：我 
我知道门那是房间里的   
证人不一定是证人才能出庭作证 
拍照让它成为证据。证人没有 
如果真是这样，那就成为一个可以移动事物的人 
碰巧把它当作证据。如果 Shroff 女士想过马路 
她说太阳镜是怎么排列的，如果是的话， 
没错，我不知道，她能做到。这只是一个 
可否受理问题。 
法庭：所以她也许能够就此作证
门，但她肯定无法就其余部分作证
房间以及这些太阳镜的放置方式。
SHROFF 女士：我们不会反对 —
芬克尔先生：对不起。

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          南区记者，P.C.
            (212) 805-0300
O5OVGUO2 McNamara-直播
SHROFF 女士：— 去看门的照片。
芬克尔先生：对不起。
那将是合适的十字架。   
这体现了文档的重量。对不起。  
这取决于文件的重量，而不是可否受理性。  
无论哪种情况，我都可以奠定803（6）个基础。她很熟悉 
有案卷而且她很熟悉记录是怎么回事 
已存储。那是一张照片。我就这样吧。 
法庭：这样她就能辨认出房间，但她
无法识别这些对象。
芬克尔先生：好吧。因此，我将奠定803（6）个基础。
法庭：好吧。
SHROFF 女士：法官大人？
法庭：我们完成了。
（下一页继续）

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          南区记者，P.C.
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（在公开法庭上） 
作者：芬克尔先生：  
问：特工麦克纳马拉，当特工进行搜查时
联邦调查局，摄影师的照片怎么了？
答：摄影师带了--从 SD 卡里拿出来
相机，把它放到塔里。这不是一台电脑，而是一台
你只要烧掉的塔 —— 你一次可以做大约四份副本
时间。所以他们把它放在那里。我们烧掉副本。
第一个副本是原件，然后进入 
原始信封 —— 原始证据信封，1A 
我们称之为信封。它被附加到文件中。   
第二个是备份副本；它也会被放入 
该文件。   
第三份是我们要寄给案件代理人的副本 
获取工作副本这样他们就不必去删除那些副本了 
亲自从文件中进行审查。   
以及是否有物品要发送到 
实验室，我们还会烧录一份副本然后连同这些物品一起发送到 
实验室供审查。 
法庭：我想让你更接近法庭
麦克风。你可以把它拉得更近，你可以坐得更近。而且
大声说出来。
问：还有照片的副本，哪个外地办事处，如果有的话，
他们被派去了吗？
答：纽约。

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          南区记者，P.C.
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芬克尔先生：洛夫特斯女士，我们可以展示一下，
政府展览 GX CT-129。这是明证。而且，如果我们
可以转到第 17 页。我只想确保是
为陪审团出版。如果你能只放大顶部
求你一半，洛夫特斯女士。
（下一页继续）

81
          南区记者，P.C.
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作者：芬克尔先生：  
问：你能读懂吗，特工麦克纳马拉。  
A. “信托和协议声明。《宣言》
信托和协议（本信托和协议）订立于
2020 年 12 月的空白，在受益人郭强之间
持有塞浦路斯护照号码空白的个人，居住在
blank，英国伦敦，以及受托人 Kin Min Je，
持有香港护照号码的个人KJ0168411，居住
位于英国伦敦伯爵路巴尔莫勒尔故居 87 号，每间
聚会，一起聚会。”
问：请继续阅读。
A. “背景。受托人同意持有该公司的股份
以下公司（每家公司，合计
公司）以受托人的名义注册时及以信托人的名义注册
代表收款人：（1）喜马拉雅货币清算有限公司。
Ltd.，一家在澳大利亚注册的公司，公司编号为
642418684; (2) 喜马拉雅保护区 Pty.Ltd.，一家公司
在澳大利亚注册，公司编号为 642487232，
喜马拉雅——对不起；(3) 喜马拉雅货币——我想这是派对——我是
抱歉——LTD.，一家在澳大利亚注册的公司，旗下公司
编号 643817449；(4) Major Lead International, Ltd.，一家公司
使用公司编号在英属维尔京群岛注册
1976621。”
芬克尔先生：洛夫特斯女士，你能放大吗。
问：你能读出第 3 号吗，特工麦克纳马拉。

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芬克尔先生：洛夫特斯女士，如果你能放大三号的话。
答：“受托人还与受益人签订了协议：（3.1）
除非有指示，否则应始终保持公司的偿付能力
否则由受益人承担，并遵守所有适用的规定
公司要求的规章制度；(3.2) 要遵守的
活跃在相关登记处的公司
次数，并按时支付所有适用的费用
由受益人偿还；(3.3) 不得转让或放弃
在没有事先通知的情况下将公司归任何第三方所有
受益人的书面批准。”
芬克尔先生：洛夫特斯女士，你可以缩小这个范围，
请，然后转到下一页。
还有下一页。
问：你能读出标牌名称吗，旁边写着的地方
已签署。
答：由郭强签名。由 Kin Min Je 签名。目击者
空白。
芬克尔先生：谢谢。洛夫特斯女士，你可以接受
向下。
等一下，法官大人。
洛夫特斯女士，你能不能展示政府展览
GX CT176。
问：还有特工麦克纳马拉，你能从哪里开始读懂吗
说 “画画。”
A. “Draw G——对不起——G 时尚单品，设计师 1 Whistle，

83
          南区记者，P.C.
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裤子，100，帽子，200。”
芬克尔先生：如果可以的话，洛夫特斯女士，
GX CT184。
请转到下一页。
继续前进。停在那里。
问：这是什么样的文件？
答：这是车辆所有权。
问：什么是车辆所有权？
答：这是 —— 这是你必须做的事情 —— 它是 —— 显示你的
所有权并在国家注册。
问：上面列出的所有者叫什么名字？
答：是 Cao、Ca-O、Defeng、D-E-F-E-N-G。
问：你在 2023 年 3 月 15 日见到曹德丰或曹德丰了吗？
答：是的。
问：那这是什么类型的汽车？
A. 兰博基尼。
问：模型是什么？
A. Aventador。
问：那么 VIN 或车辆的后四位数字是多少
识别号码？
A. 0393。
芬克尔先生：洛夫特斯女士，如果可以的话请展示
GX CT41。
问：这辆车的最后四位数是多少
兰博基尼的识别码？

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          南区记者，P.C.
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A. 0393。
芬克尔先生：现在没什么好说的。谢谢。
法院：盘问？
SHROFF 女士：谢谢你，法官大人。
交叉检查 
作者：SHROFF 女士：  
问：下午好，特工。
答：下午好。
问：麦克纳马拉女士，在 3 月 15 日之前，你知道什么吗
关于郭文辉先生？
答：不是。
问：而且你已经做好了执行搜索的准备，我猜对了
在 3 月 15 日？
A. 准备了搜查用品和类似性质的东西，
是的。
问：对。而且你已经制定了计划，对吗？
答：是的。
问：在执行搜索之前，您会见了或发了电子邮件
还有将要陪同你的团队成员，
正确？
答：是的。
问：你讨论了郭先生可能在3月15日去哪里，
正确？
答：我不这么认为。
问：你没有讨论在哪里 —— 你在三所房子中哪一间

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          南区记者，P.C.
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我以为他可能会进来吗？
答：我记不起来了。
问：你还记得今天坐在这里，你是几天开始工作的吗
准备执行搜索了吗？
答：要么是那周早些时候，要么是前一周晚些时候。我
相信。
问：而且你给其他成员发了电子邮件，对不对，包括
有人叫罗宾，对吗？
答：我不知道罗宾是谁。
问：罗宾·卡特赖特？
答：雷切尔·卡特赖特。
问：对不起？
答：雷切尔。
问：瑞秋，罗宾，你给她发了电子邮件，对吧？
答：是的。她是请求我们帮助的人。
问：在给她发电子邮件时，计划是让她交流
向你和你提供信息，以便与她交换信息，
正确？
答：有关我们将如何进行搜索的信息，
是的。
问：对。而且你知道你要去搜房，
正确？
答：是的。
问：而且你知道那是一个大房子，对吗？
答：是的。

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问：而且你知道家里可能有郭先生，对吗？
答：是的。
问：而且你本来打算逮捕郭先生，对吗？
答：我不是。
问：好吧，你的团队中有人要逮捕郭先生，
正确？
答：我的团队中没有人会逮捕任何人。我们只是进行搜索。
问：好吧。而且你之前作证说你不记得了
不管你有没有预料到郭先生会去哪里，那就让我们吧
我用一些可能会让你精神焕发的东西来接近
回忆。那将是 3514-24。
女士，这是否会刷新你的记忆
我以为郭先生不在康涅狄格州的家中吗？
答：不是。
问：可以公平地说，你通过电子邮件与之进行了互动
有几个人都在协调对这个地方的搜寻
对吧？
答：是的。
问：那是 373——我在发音时遇到了麻烦
街道——Taconic Road；对吗？
答：是的。
问：而且你想一大早去那里，对吗？
答：是的。我没有选择时间。
问：好吧。但无论如何，你在 7:00 之前到过那里；是
这么公平地说？

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答：不是。我们在 7:00 左右到达
问：可以公平地说，房屋本身不是那样的
你有权访问，对吗？
芬克尔先生：反对。
答：我不明白。
法院：驳回。
SHROFF 女士：法官大人，我会改写的。
问：你无法通过大门进入，对吧？你的团队
无法通过大门进入，对吗？
答：是的，我们可以。我们到达时大门是开着的。
问：家的大门是开着的。
答：是的。当我的团队到达时，大门是开着的。
问：在你之前有多少支队伍？
答：——正在参赛的团队。
问：参与参赛的团队，对吗？
答：是的。
问：参与参赛的团队正在与之协调
关注的球队，你的队伍是哪个，对吗？
答：什么时候——当他们完成参赛并获得安全保护时，
他们告诉我们，然后我们可以前往该地点。
问：对。还有写参赛作品的团队有没有告诉你
是郭先生的女儿让他们进来的？
芬克尔先生：反对。
法院：持续。
问：当你——

88
          南区记者，P.C.
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法庭：你不需要回答。
问：当你进家时，你看到郭先生的女儿了吗
还有妻子坐在外面的长椅上？
答：不是。
问：你第一次见到郭先生的女儿和妻子是什么时候
在那个家里？
答：在屋子里。
问：他们在屋里坐在哪里？
答：我会把它当作家庭活动室。
问：他们是被进入的团队放到那里的
在你之前，对吗？
答：我不知道。我当时不在场。
问：你不知道，因为你不在场。而当你
进入房子，你在家里从一个房间走到另一个房间了吗？
答：我第一次进屋是什么时候？
问：是的。
答：当我第一次进入房子时，我去了那里
居民们要找监督特别探员卡特赖特
让她知道我们在那里。
问：因为她是第一支参赛队伍，对吧？
答：我不知道。
问：你不知道第一支参赛队伍是谁？
答：我不知道谁在参赛队伍中。我关注了
参赛队伍。那不是搜索的一部分。
问：所以你关注了参赛队伍，对了，还有参赛队伍

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告诉过你位置很安全，对吗？
答：我们当时在集结地点。当参赛队告诉我们时
很安全，然后我们开车去了住所。
问：你们当中有多少人一起开车？
答：我只能代表我的团队说话。可能有十几个
我们左右。
问：你刚才说只能代表你的团队说话，对吗？
答：对。你问谁一起开车；那是我开车的人
和，我的队伍。
问：好吧。你的团队中有任何成员拿走了吗
你作证的照片？
答：是的。
问：好吧。因此，我们过一分钟就可以看照片了。但是
我们就等着你进入家里吧，好吗？当你
进入了家，正如你所说，它看起来像一个曾经的家
住过，对不对？
答：是的。
问：厨房的桌子上有食物，对吗？
答：是的，有食物。
问：是的。而且家里有三个人，对吗？
答：是的。
问：这三个人是郭先生的妻子，对吗？
答：是的。
问：他的女儿，对吗？
答：是的。

90
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问：还有他女儿的未婚夫，对吗？
答：我被告知是男朋友，但是是的。
问：好吧。你看见那个用拐杖进来的男朋友了吗
卧室还是有人告诉过你的？
答：对不起。你能再说一遍吗。
问：当然。在你搜寻的时候你看到他女儿的了吗
男朋友？
答：是的。他们一起在那个房间里。
问：好吧。而且他是用拐杖的，对吗？
答：哦，拐杖，是的。对不起。我误解了你的意思。
问：没关系。很多人误解了我的意思。
但是他是用拐杖的，对吧？
答：是的，他身上有拐杖。
问：对。还有两只狗，两只像贵宾犬一样的小狗
在家里，对吗？
答：是的。
问：而且它们都被安置在那个房间里，对吗？
答：不是。我带女儿上楼去找狗。
问：好吧。所以你带女儿上楼是为了让她能
找回狗，然后你把他的女儿带回来然后
把她放回那个房间，对吗？
答：正确。
问：好吧。然后你让他们待在那里，而你的其余部分
团队搜查了整个房子，对吗？
答：是的。

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问：好吧。你给了她搜查令的副本，我是
假设？
答：我没有。
问：好吧。但是她没有阻碍你搜寻
回家，对吧？
答：不，她没有。
问：那个用拐杖的男朋友也没有，对吗？
答：正确。
问：当然，妻子没有挡路，对吗？
答：正确。
问：他的妻子大约60岁；对吗？
答：我不知道。
问：你看着她的时候她不紧张吗？
答：我没看她。我 —— 我见过她很短一段时间。我说话了
带着女儿，我带她去拿狗，把它们带过来了
回去，如果她需要的话我会告诉她的
带他们出来，喂它们，这不是问题，让我们来吧
知道，然后我们继续前进。
问：然后你开始搜查房子。你说过
至少还有大约 20 个人，对吗？
答：是的。哦，至少。
问：好吧。而当你至少说，有超过20个吗？
答：我想我们有大约 40 个人在搜索。
问：好吧。所以你有 40 个人在搜寻，里面有三名居民
家，对吧？

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          南区记者，P.C.
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答：是的。
问：而且没有人干扰你的搜索。
答：不是。
问：好吧。在您执行搜索时
373——我就是这么称呼的，好吧——你知道怎么做吗
郭先生还有很多其他的房子？
答：不是。
问：你知道他在纽约市有家吗？
答：我知道他们同时在执行其他逮捕令
时间。我不确定他拥有哪些房子或住在哪里。
问：好吧。在你执行搜索的时候你有
认识郭先生有律师吗？
答：我不知道。
芬克尔先生：反对。
法院：驳回。
问：当你去搜查郭先生家的时候，你有没有
你知道他在美国的身份吗？
芬克尔先生：反对。
法庭：如果你愿意加紧努力，拜托。
（下一页继续）

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          南区记者，P.C.
            (212) 805-0300
O5O1GUO3 McNamara-Cross
（在侧边栏上） 
法院：因此，这超出了直接范围。
SHROFF 女士：我很高兴传唤她作为自己的证人
那么，法官大人。但我可以有一定的自由度
她在执行搜查令时所知道的。我会的
法官大人，很高兴受到更多限制，但是——
法庭：所以不管他有律师，我都允许
那个，但现在要谈他的移民身份，我想那是
只是超越了。
SHROFF 女士：嗯，她拿了 —— 她拿了数百个
他家里的文件。我有权问还有什么
她拿了什么文件以及他还拿了什么其他文件
关于的证词。
法庭：有与他有关的文件吗
移民身份？
芬克尔先生：我不知道，但我从他们那里明白了
前几天晚上回复我们写的关于他的移民的信
状态不存在问题，也不是，这无关紧要。还有我
从法官大人的裁决中我也明白了他的存在
律师不是辩方要讨论的问题
向陪审团暗示，他们也不应暗示
郭先生有律师，不知怎么搜查是不恰当的。这个
搜索是正确的。它是经过司法授权的。
SHROFF 女士：法官大人，问有没有人有
首先，律师并不暗示搜查不当。

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          南区记者，P.C.
            (212) 805-0300
O5O1GUO3 McNamara-Cross
第二，她找回了文件。如果他们愿意
精挑细选他们放了什么，我可以探索什么
还有其他人在那里。我们没有兴趣，而且，你知道，
移民问题——
法庭：你可以问一下是否有
与移民身份有关的文件。
SHROFF 女士：对。这表明一个人
住在他们家里；个人证件在他家里。
我的——我十字架的重点是表明那是他的住所
家。我不是想为他辩护
这种定罪会带来移民后果，这就是什么
简报是关于的，所以我不知道为什么要这么做
在这里。完全无关紧要。
法院：因此，关于是否没有争议
它曾被用作房屋，对吗？
SHROFF 女士：哦，是的。他们的论点是 Mahwah
也是个家，我想证明这是他的家
光是这样，这里找回的任何东西都无法与之相提并论
在 Mahwah 里什么都找回来了我有权证明这一点。
法庭：所以你说这是他的校长
家？
SHROFF 女士：他唯一的住宅。
法庭：好吧。好吧，她可以带出一些
关于这个问题的证据。
芬克尔先生：当然。它不应该暗示

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          南区记者，P.C.
            (212) 805-0300
O5O1GUO3 McNamara-Cross
移民身份。移民身份不是那回事
相关的。
SHROFF 女士：我们说的不是身份。我有
一种状态，你有一种状态。我是美国护照持有者。
那是我的状态。如果我的护照在我家里，那就更重要了
可能是我的家，不太可能是你的家，对吧？
芬克尔先生：我完全同意护照是——
法院：当然。但是你在问他的事
移民身份。
SHROFF 女士：我会从那里搬过来问问他她是否
找到了一些与移民有关的证件或他的移民
文件，他的身份证，他的钱包。我有权问
所有这些。
芬克尔先生：法官大人，不反对身份
卡，对钱包没有异议。我的反对意见是 402、403
申请移民文件的原因和移民身份。
那不合适。这不相关。我没问题
他们正在探索那里的个人物品。那是
精细。但是——
SHROFF 女士：我们并不是在争辩他会成为
被驱逐出境之类的。我们只是想证明这一点
他家里有移民证件。
法庭：但是要护照而不是
你知道他的移民身份是什么。
SHROFF 女士：当然。我很乐意改写。

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          南区记者，P.C.
            (212) 805-0300
O5O1GUO3 McNamara-Cross
法院：谢谢。
（在公开法庭上） 
法院：异议被驳回。
作者：SHROFF 女士：  
问：麦克纳马拉探员，你花了多少小时搜寻
家？
答：没有。我没有搜索。
问：好吧。你只是监督了搜查，对吗？
答：没错，嗯嗯。
问：而且你直接监督了多少人？
答：大约 40 个。
问：40 个人，对吗？
答：嗯嗯。
问：而且 40 个人被赋予了搜索不同内容的任务
房屋的一部分，对吗？
答：是的。
问：每个卧室都被搜查了，对吗？
答：是的。
问：每个起居室都被搜查了，对吗？
答：是的。
问：壁橱被搜查了，对吗？
答：是的。
问：浴室被搜查了，对吗？
答：是的。
问：好吧。所以在壁橱里，如果可以的话

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          南区记者，P.C.
            (212) 805-0300
O5O1GUO3 McNamara-Cross
有 —— 实际上，我改写一下。
你看了壁橱的照片，对吗？
答：是的。
问：壁橱里挂着白衬衫，对吗？
答：是的。
问：鞋子？
答：是的。
问：其他男装，对吗？
答：是的。
问：你知道那些衣服属于谁吗？
答：不是。
问：你有没有努力找出他们的衣服
是？
答：不，这不是搜索的一部分。
问：好吧。然后你搜查了厨房，对吗？
答：是的。
问：厨房是一个普通的厨房，与厨房有关
里面的东西，对吗？
答：那是一个非常漂亮的厨房，里面有与厨房相关的东西
它，是的。
问：好吧。但是柜台上有食物，对吗？
答：有食物。我记不起来具体是什么食物了
是。
问：好吧。在你搜查了厨房之后，你搜查了
其他房间，对吗？

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          南区记者，P.C.
            (212) 805-0300
O5O1GUO3 McNamara-Cross
答：我没有搜索。
问：好吧，你在这期间为很多照片作证
搜索，所以我很抱歉。
你监督了搜查那些房间在哪里
搜索了，对吗？
答：是的，女士，是的。
问：好吧。让我们来看看车库的照片，
好吧，这样我们就可以谈谈那辆红色的兰博基尼了。
你进入车库是为了找红色的吗
兰博基尼？
答：我通过车库进入但不是为了找
兰博基尼。
问：可以公平地说你已经给团队发了电子邮件吗
关于那辆兰博基尼的搜查令，
正确？
答：是的，兰博基尼的扣押令包括在内。
问：你通过电子邮件发送了扣押令，对吗？
答：我给整个小组、搜查令和
扣押令。
问：好吧。而且你有那辆车的扣押令
分开讨论，对吧？这是一个重要的问题
你，对吗？
芬克尔先生：反对。模糊。
法院：问题是什么？
问：当然。你被特别告知要去找红色

99
          南区记者，P.C.
            (212) 805-0300
O5O1GUO3 McNamara-Cross
兰博基尼，对吗？
答：不是。是 —— 我们有兰博基尼的扣押令，
但是没有人说：一定要找到兰博基尼。
问：好吧。因此，对这辆车有专门的扣押令，
兰博基尼，对吧？
答：是的。
问：有人告诉你它是红色的，对吗？
答：我不记得了。
问：好吧。
答：我知道扣押令上有 VIN 号码。我
不记得它有没有颜色。
SHROFF 女士：好吧。如果我能把95拉出来
拜托。
问：那就是汽车。你真的看过这个车吗
州？
答：对不起。我不明白。国家？在
康涅狄格州，是吗？
问：不是。我的意思是掩护。
答：哦，不是。
问：它被报道的时候你没看见，对吗？
答：不，我没有。那是参赛照片之一。
问：好吧。而拍这张照片的人，他们就是这样的
找到车了，对吗？
答：是的。
问：这辆车的顶部覆盖着这个黑色的东西，

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          南区记者，P.C.
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正确？
答：是的。
问：而且它插上了电线——车里有一根电线，
正确？  
答：是的。
问：然后电线就插好了，对吗？
答：是的，它看起来已插上电源。
问：对。我不开车所以我不知道，但这是否意味着
汽车正在充电？
答：我会的——我相信这是为了让电池保持充电。
问：为了保持电池充电，对吗？
答：是的。
问：好吧。这是那里的众多车库之一，
正确？
答：有两个车库。
问：对。然后在这个车库里有人是
显然是在锻炼身体所以有某种健身器材
在右边，对吗？
答：是的。
问：然后这是你在别人家里能找到的常用东西
回家，对吧？
芬克尔先生：对表格有异议。
法院：驳回。你可以回答。
答：是的，这是车库里的典型物品。
问：车库没锁，对吗？

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          南区记者，P.C.
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答：我不知道。
SHROFF 女士：好吧。然后如果我能有
请帮我揭开这辆车的版本。
问：那辆车就是这个样子，对吗？
答：是的。
问：好吧。然后你会看到连帽衫上那个白色的小东西
部分？
答：是的。
问：那是干什么用的？
答：我不知道。
问：好吧。你到底搜过车吗？
答：我没有。
问：你有没有和你说过话或者——和你以前的人说过话
监督那是在搜车？
答：是的。
问：好吧。他们有没有告诉你他们有没有找到司机
车上的牌照？
答：他们没有。
问：他们有没有告诉你他们有没有发现任何与 Miles 相关的东西
Guo 在车里？
答：不是。
问：他们有没有告诉你他们在车里找到了他的衣服？
答：不是。
问：他们有没有告诉你他们在车里发现了什么？
答：不是。

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          南区记者，P.C.
            (212) 805-0300
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SHROFF 女士：让我看看能不能拿到那些
请给我钥匙。
问：这是政府第 36 号展品，对吗？你作证了
关于这些钥匙？
答：是的。
问：好吧。你没找回钥匙，对吧？
答：我没有。
问：你不知道谁找回了钥匙，对吗？
答：我——那个房间里有两个搜索者。我不记得了
哪一个找回了密钥。
问：好吧。所以有人给了你钥匙然后钥匙就在这里
法庭，对吗？
答：是的。
问：好吧。而且你为这些钥匙作证，对吧？
答：是的。
问：好吧。而且你向他们作证是因为政府
在你准备作证的时候给你看
今天在这里，对吗？
答：我不明白这个问题。对不起。
问：当然。他们在给你做准备的时候给你看了这些钥匙
对吧？
答：是的，他们给我看了这些钥匙。
问：他们为你今天在这里作证做好了准备，对吧？
答：当然，是的。
问：你和他们见过好几次，对吧？

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答：是的。
问：你今天早上会见了他们，对吗？
答：是的。
问：今天早上两次，还是一次？多少次？
答：我相信有一次。
问：你曾经相信过吗？
答：我曾经相信过，是的。
问：好吧。然后他们叫你早点过来这样他们
可以让你做好准备，对吧？
答：我相信是这样。
问：他们给你发了短信？
答：短信或电子邮件。我不确定。
问：好吧。好吧，在这里，让我来帮你。
答：好吧。
问：你有没有记下你见过多少次面
这些检察官要为你今天在这里作证做准备？
答：不是。
问：你知道是不是超过五次吗？
答：我不知道。
问：在过去的两天里，你与他们会面了多少次；
你还记得吗？
答：我不知道我昨天有没有见过他们。
问：让我和你聊一聊这些钥匙。
答：嗯嗯。
问：我要把它们留在这里。

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          南区记者，P.C.
            (212) 805-0300
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那些钥匙上有证据标签，对吗？
答：有一个标签。我不确定是什么——这是什么样的标签
是。
问：好吧。但这是你的人贴的标签，对吧？那个
当你第一次拿到钥匙时，钥匙上没有标签，
对吧？
答：我不知道谁贴了这个标签。他们不在
当时的钥匙。
问：好吧。而且钥匙就像你看到的那样
他们在信封里，对吧？
答：我——我不知道。
问：你不知道它上面是否有钥匙扣，对吗？
答：我不知道。
问：你不知道上面有没有名牌，对吗？
答：我不知道。
问：检察官第一次给你看那些是什么时候
钥匙？
答：今天。
问：今天早上。
答：是的。
问：好吧。然后他给你看了那些钥匙然后他告诉你了
本来要向他们作证的，对吗？
答：他问了我关于钥匙的问题。
SHROFF 女士：好吧。看看这能不能让你精神焕发
回忆。

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          南区记者，P.C.
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芬克尔先生：法官大人，没有失败
回忆。反对。
SHROFF 女士：我相信她记不起来了——
法庭：不，她没有说自己记不起来了。
持续。
作者：SHROFF 女士：  
问：你之前作证说你记不起来了，对吧，
无论是通过电子邮件还是发短信，他们都要你来
今天早上？
答：是的。
问：好吧。这会刷新你的回忆吗，女士？
答：是的，它看起来像文字。
问：好吧。然后他们发短信让你早点过来这样他们就可以
做好准备，对吗？
答：是的。
问：好吧。而且你很早就来了因为你想成为
为今天在这里作证做好了准备，对吧？
答：那个，现在是两个 —— 要花两个半小时才能到这里
来自康涅狄格州，所以我必须在交通之前到这里。
问：好吧。但是你见过他们，对吧？
答：是的。
问：好吧。然后他们问你那些钥匙的问题，对吗？
答：是的。
问：他们问你谁找回了它们然后你说，我不知道
知道，对吗？

106
          南区记者，P.C.
            (212) 805-0300
O5O1GUO3 McNamara-Cross
答：正确。
问：然后他们问你在哪里找回了然后你说，
我不知道，对吗？
答：我知道他们在哪个房间里。我说这是房间
那个 —— 它有的地方 —— 就像办公室还有摄像头 —— 显示屏
带有——用于安全摄像机的显示器。
问：还有保安，那就是你被告知钥匙的地方
被放了，对吗？
答：那是找到钥匙的地方。
问：好吧。所以在车库里找不到钥匙
车是，对吗？
答：正确。
问：他们没有被发现在要离开的车内
如果他们每天都用车，对吗？
芬克尔先生：就形式而言，异议。
法院：持续。
问：他们在车内被发现了吗？
答：不是。
SHROFF 女士：如果你能给她看，拜托，然后
陪审团，第 95 号。
问：真的有人把车开出车库的时候吗
他们没收了吗？
答：我不知道。
SHROFF 女士：如果有人能请提出 58。
问：你为这张照片作证，对吗？

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          南区记者，P.C.
            (212) 805-0300
O5O1GUO3 McNamara-Cross
答：是的。
问：你能不能告诉我——在右边你会看到一个
标志，对吗？
答：是的。
问：你知道那面旗帜是干什么的吗？
答：不是。我不知道。
问：国旗上有名牌吗？
答：我不知道。
问：任何地方都有 “中国新联邦州” 的注释吗
告诉你那面旗帜的事？
答：我对这面旗帜一无所知。
问：好吧。请看那张照片的左边。
你看见那个黄色的大圆形了吗？
答：是的。
问：那是什么？
答：我不知道。
问：那是用来广播的东西；是吗
正确？
答：我不知道。
SHROFF 女士：好吧。你能不能缩小一点。
问：你是否得出结论，这是办公空间还是工作场所
空间？
答：在我看来，它像是某种工作室类型的设置。
问：它看起来像录音室，对吗？
答：像这样的东西，是的。

108
          南区记者，P.C.
            (212) 805-0300
O5O1GUO3 McNamara-Cross
问：它看起来像有人会广播的地方，
正确？
答：是的。
SHROFF 女士：请问我能拿到 59 号吗。
问：好吧。也许这是一张更好的画面。
所以那里有录音设备，对吗？
答：是的。
问：有电脑显示器，对吗？
答：是的。
问：一把椅子？
答：是的。
问：在你搜索的过程中，你有没有试着找出这些东西
是工作设备吗？
答：不是。
问：好吧。非常感谢。
SHROFF 女士：请允许我有 83 个。
问：现在你就某些文件作证了
你读过政府的，对吧？
答：我读过了。
问：对。你大声朗读了贷款协议
正确？
答：是的。
问：好吧。你的团队从中找回了多少文书
家？
答：印刷纸？

109
          南区记者，P.C.
            (212) 805-0300
O5O1GUO3 McNamara-Cross
问：是的。
答：不多。
问：不是很多？
答：不是。
问：好吧。你大声宣读了一份贷款协议
对他来说，对吗？
答：是的。
问：好吧。你知道贷款协议是关于什么的吗？
答：不是。
问：你知道贷款协议保存在哪里吗？
答：不是。
问：你知道谁把贷款协议放在哪个房间吗？
答：不是。
问：你知道这是否是郭先生的房间吗？
答：不是。
问：你知道它是在厨房还是在厕所里吗，
你不知道它在哪里，对吧？
答：我们可以——你可以回到——证据日志。
问：你知道吗？
答：我知道吗？不是。我没有搜索。
问：好吧。然后你作证并阅读了文件
政府让你读书，对吗？
答：是的。
问：你以前从未读过它们，对吗？
答：正确。

110
          南区记者，P.C.
            (212) 805-0300
O5O1GUO3 McNamara-Cross
问：你没有选择向陪审团宣读哪些文件，
正确？
答：我没有。
问：你不知道还找回了哪些其他文档
回家因为你没搜查对不对？
答：没错。
问：好吧。你没在里面找回郭先生的钱包，
正确？
答：我不记得有人找到钱包了。
问：护照？
答：不是。
问：今天坐在这里，你还记得有没有有
用他的名字开的驾照？
答：我不知道。
问：学习许可证怎么样？
答：不，我什么也没看见。
问：所以你的记忆基本上仅限于政府的记忆
让你为今天的审判做准备。
芬克尔先生：反对形态。
法院：你可以回答。
答：不是。我记得我在那里的时候做了什么。  
问：对。但是你所做的只是监督，对吧？
答：没错。
问：你根本不是那个搜索任何东西的人，
正确？

111
          南区记者，P.C.
            (212) 805-0300
O5O1GUO3 McNamara-Cross
答：没错。
问：你没有找回任何你作证的东西
今天，包括钥匙，对吗？
答：没错。
问：你就一件上面写着布里奥尼的诉讼作证，
正确？
答：我想那是一张纸，一张纸。
问：你还记得作证说过一个有名字的衣架吗
布里奥尼在上面？
答：我看见照片了。我想没有人问过我这个问题。
问：好吧。你知道布里奥尼是什么吗？
答：我不知道。
问：你知道那所房子里有没有找回西装吗，
男士西装？
答：诉讼不在要扣押的物品清单上。我们
没带任何衣服。
问：我的问题出现了 —— 好吧。你看见西装了吗？
答：是的。
问：好吧。你知道他们几岁吗？
答：不是。
问：你知道它们是从 2010 年还是从 2020 年开始吗？
答：不是。
问：你知道它们是他的西装还是别人的西装吗
西装？
答：不是。

112
          南区记者，P.C.
            (212) 805-0300
O5O1GUO3 McNamara-Cross
问：现在你记得读过他们制作的文档
你读名字然后读一本叫做《郭之声》的东西，
善良之声，对吗？
答：是的。
问：好吧。你知道那是什么意思吗？
答：不是。
问：你知道郭之声是什么吗？
答：不是。
问：你知道什么是善良之声吗？
答：不是。
问：你知道萨拉卡是什么吗？
答：不是。
问：这是我说的衣架。你作证说
这个衣架，对吧，这张照片？
答：我看见照片了。我——是的。
问：对。但是你从来没见过衣架，对吧？
答：我没有。
问：好吧。所以你只是在这里为照片作证
那是别人拿给你的对不对？
答：是的。
SHROFF 女士：好吧。请问可以给我176号吗
问：好吧。你为这份文件作证，对吗？
答：是的。
问：芬克尔先生让你大声朗读然后你读出来
向陪审团大声说话，对吗？

113
          南区记者，P.C.
            (212) 805-0300
O5O1GUO3 McNamara-Cross
答：正确。
问：好吧。设计师一号哨子是什么意思？
答：我不知道。
问：Pants 100，你知道这意味着什么吗？
答：我不知道。
问：Hat 200，你知道这意味着什么吗？
答：我不知道。
问：今天坐在这里，你知道这些裤子和帽子是不是吗
本来应该是礼品袋的一部分吗？
答：不是。
问：你对你读给陪审团的内容一无所知，
正确？
答：没错。
问：你只能告诉他们有这张纸
被你的团队中的某人找到然后他们拍了张照片，然后
你向陪审团背诵了这句话。
芬克尔先生：对形式有异议。
法院：驳回。你可以回答。
答：我很抱歉。我已经忘记了这个问题。
问：你只知道有人拍了张照片，他们拍了
你当时看的那张照片，政府有你
向陪审团大声朗读然后你就做到了，对吗？
答：是的。
问：好吧。请问我能不能有 184 个。
你看到这个展品上有那个黄色的粘稠物

114
          南区记者，P.C.
            (212) 805-0300
O5O1GUO3 McNamara-Cross
作证了？
答：是的。
问：“对马修来说，所有四辆车都有新的保险卡
有效” 或 “效果 4/1/20”，对吗？
答：是的。
问：你知道那张便利贴是谁写的吗？
答：不是。
SHROFF 女士：如果你向下滚动，请向下滚动。
问：这就是整个文档，对吧？
答：我不知道。
问：你不知道这些文件是否一起找回，
正确？
答：我不知道。
问：你不知道他们是否一起在一个地方，对吗？
答：我不知道。
问：你不知道谁填写了文件，对吗？
答：谁填写了——我不明白，谁填写的。
问：你不知道这些上面有谁的笔迹
文件。
答：哦，不是。
问：有人给你看了一张照片，你在作证
那张照片，对吧？
答：是的。
SHROFF 女士：好吧。你可以把它记下来。
如果我能有 393 个。

115
          南区记者，P.C.
            (212) 805-0300
O5O1GUO3 McNamara-Cross
芬克尔先生：我不相信 393 是证据。
SHROFF 女士：好吧。174。
问：你看到这个文件了吗？你也作证了这一点，
正确？
答：是的。
问：郭文贵讲的谎言。你不知道他们是什么日期
在说什么，对吗？
答：正确。
问：你不知道这是关于什么问题和答案的，
对吧？
答：对。
问：你不知道谁预先选择了问题，也不知道他们问了什么
是，对吧？
答：正确。
问：你刚到那里读给陪审团是因为他
告诉过你的，对吧？
答：这就是我被要求做的，读一读。
SHROFF 女士：好吧。我们可以向下滚动吗。
问：这是整页，对吧？你知道它在哪里吗
从？中恢复
答：不是。
SHROFF 女士：好吧。你可以把它记下来。
如果我能有 129 个。
问：你为这份文件作证了吗？
答：我不记得了。

116
          南区记者，P.C.
            (212) 805-0300
O5O1GUO3 McNamara-重定向
问：好吧。然后我们可以把它记下来。
可以公平地说吗，麦克纳马拉探员，你的工作是
仅限于接收那所房子里其他人的任何东西
正在寻找并赠送给你？
芬克尔先生：物体就是形态。
法庭：我没听见。
芬克尔先生：对形式有异议。
法院：驳回。你可以回答。
答：没有人给我任何东西。我管理了搜索。这个
搜索者搜寻，摄影师拍了照片，
他们把这些物品输入了我们的证据清单所以我们有了清单
拿走了什么，然后他们把它打包起来。他们没有把它们交给他们
让我去做。
问：好吧。足够公平。而且你说的搜查花了四次
几个小时，对吧？
答：是的，大约四个小时。
问：搜索时没有人打扰你，对吗？
答：不是。
问：然后搜索完成了，你离开了吗？
答：完全？
问：搜索完成后，你向左，对吗？
答：是的。
SHROFF 女士：好吧。非常感谢。
法院：重定向？
芬克尔先生：非常简短。

117
          南区记者，P.C.
            (212) 805-0300
O5O1GUO3 McNamara-重定向
重定向考试 
作者：芬克尔先生：  
问：特工麦克纳马拉，你和你的角色是什么
2023 年 3 月 15 日的队伍？
答：帮助执行搜查令。
问：当文件或实物物品从中恢复时
搜索，联邦调查局做了什么（如果有的话）来追踪
这些材料来自哪里？
答：所以他们被扣押人员抓获了，然后就开始了
监管链。
问：你能解释一下它是如何追踪的吗
从那里回收特定的材料。
比如说哪个房间。
答：哦，当然。因此，当有人在房间里发现物品时，我们会发送
摄影师，他们在原地拍照。当我们做我们的
照片，我们会给每个房间一封信，所以当那件物品出现时
已恢复，我们会说，描述一下物品，比如说，你
知道，手机序列号某某位于 B 房间
在桌子上。然后我们把那些人 —— 两个人
实际上发现并目睹了那件物品。
问：2023 年 3 月 15 日是否遵循了这个程序？
答：是的。
问：还有特工麦克纳马拉，当联邦调查局离开时，会怎样
预防措施或者之前的政策和程序是什么
离开？联邦调查局是做什么的？

118
          南区记者，P.C.
            (212) 805-0300
O5O1GUO3 McNamara-重定向
答：有证据吗？
问：证据和照片。
答：哦。所以有缉毒剂，所以只有一个人
它负责保管证据，然后他们开始了连锁行动
监护然后他们把证据带到证物室
它在哪里登录并放入案例档案。这个
照片，就像我——我相信我之前说过，摄影师
拿走 SD 卡并将其直接烧录到磁盘上，所以我们不会
先把它放到电脑里，然后我们制作一份原始副本
那是存入案件档案的，是原始副本的备份
把一份副本放到案件档案里，交给案件代理人，然后，应该
我们需要另一份副本给实验室，或者用来寄东西到
取证，用于取证，然后我们制作第四份副本。
问：特工麦克纳马拉，你知道联邦调查局的新闻统计数据是什么吗
约克联邦调查局调查小组在搜查前采取了行动
2023 年 3 月 15 日，关于这个案子？
答：不是。
问：你知道联邦调查局采取了哪些步骤吗？他们采取了哪些调查步骤
2023 年 3 月 15 日之后拍的？
答：不是。
问：你知道案件代理人——什么是案件代理人吗？
答：通常是——通常会分配一个，有时甚至更多
作为 —— 该案的责任人。
问：还有你知道案件代理人吗？你是不是案件代理人
这个案子？

119
          南区记者，P.C.
            (212) 805-0300
O5O1GUO3 McNamara-Recross
答：不是。
问：你知道案件代理人是否知道萨拉卡的意思吗？
答：我不知道。
问：你知道案件代理人是否审查过这些吗
文件？
答：我不知道。
问：并与美国检察官办公室讨论了这些问题？
答：我不知道。
问：案件代理人是否获得了其他搜查令？
SHROFF 女士：法官大人，案件代理人不是
今天在这里作证。
法庭：有人问她是否知道案情
代理做过或没做。她可能会回答。
答：我不知道。
问：还有特工麦克纳马拉，除了3月15日的搜查外，
2023 年，你还有其他人参与这件事吗？
答：不是。
芬克尔先生：谢谢你，特工麦克纳马拉。
法庭：改过自新？
SHROFF 女士：非常简短。
再交叉检查 
作者：SHROFF 女士：  
问：你采取了一切预防措施来确保证据
有正确的记录，对吗？
答：是的。

120
          南区记者，P.C.
            (212) 805-0300
O5O1GUO3 McNamara-Recross
问：而且你一定要为证据拍照，
正确？
答：是的。
问：或者照片是拍的，对吗？
答：是的。
问：然后你确保这些照片得到妥善保存
在文件中，对吗？
答：是的。
问：在采取了所有这些步骤之后，当你查看
证据，没有任何与之相关的单一名字
涉及郭文辉的兰博基尼，对吗？
芬克尔先生：反对。
法庭：如果你知道答案，你可以回答。
答：我不知道。
问：《Miles》中没有兰博基尼的单一标题
郭的名字，对吗？
答：我不知道。
问：你读过标题，不是吗？
答：我读过那个标题。我不知道还有其他吗
标题。我不知道。
问：所以你只是 —— 你对这个陪审团的了解只是
仅限于他让你作证的内容。
答：不是。
问：好吧，你告诉我。如果你知道更多然后你把所有这些都拿走了
详细步骤，你能不能告诉陪审团你有没有找回任何东西

121
          南区记者，P.C.
            (212) 805-0300
O5O1GUO3 McNamara-重定向
将兰博基尼与郭文辉联系起来的单一文件？
答：我不知道。
问：你没有找到任何将汽车与汽车联系起来的东西
兰博基尼致郭文豪。
A. 开往兰博尔的汽车——
问：钥匙。
答：哦，钥匙。我还以为你说的是车。没有。
问：车里什么都没有，没有一件衣服，不是
驾照，把那辆车和郭迈尔斯联系起来，对吗？
答：据我所知。
问：好吧，女士，你只能作证你所知道的。
答：对。
问：那不是。答案是否定的？答案是否定吗？
答：我现在忘记这个问题了。
问：你没有发现任何与兰博基尼相关的信息
郭文豪，对吗？
答：没有 373 的搜索结果，没错。
问：那是汽车所在的地方，对吗？
答：是的。
问：谢谢。
芬克尔先生：有一个问题。
法院：重定向？
重定向考试 
作者：芬克尔先生：  
问：特工麦克纳马拉，你知道纽约联邦调查局是不是吗

122
          南区记者，P.C.
            (212) 805-0300
O5O1GUO3 Bonsukan-直播
团队有一段视频，或者找回了郭文贵开车的视频
2023 年 3 月 15 日在 Taconic 373 号被发现的兰博基尼？
答：我不知道。
芬克尔先生：没什么了。
法庭：重新穿越？
再交叉检查 
作者：SHROFF 女士：  
问：开车并不意味着你拥有一辆车，对吗？作为
特工你可以为此作证，对吧？
答：是的。
SHROFF 女士：谢谢。
法院：谢谢。你可以走出去。还有
政府可能会传唤下一位证人。
（证人原谅） 
MURRAY 女士：谢谢你，法官大人。政府
打电话给 Louie Bonsukan。
法律书记员：请举起右手。
（证人宣誓就职） 
法院：请说出你的名字并拼出来。
证人：我叫路易·邦苏坎。它是
L-O-U-I-E，姓氏，Bonsukan，B-O-N-S-U-K-A-N。
法院：你可以询问。
MURRAY 女士：谢谢你，法官大人。

123
          南区记者，P.C.
            (212) 805-0300
O5O1GUO3 Bonsukan-直播
 路易·邦苏坎， 
     被政府传唤为证人 
     经正式宣誓后, 作证如下: 
直接检查 
作者：默里女士：  
问：下午好，Bonsukan 先生。
答：你好。
问：你做什么样的工作？
答：我是兰博基尼达拉斯的财务总监。
问：那你的职责和责任是什么
兰博基尼达拉斯的财务总监？
答：我帮助简化车辆销售的文书工作。
问：你在兰博基尼达拉斯工作了多长时间？
答：13年多一点。
问：兰博基尼达拉斯大约有多少兰博基尼
平均在给定月份卖出？
答：大概平均每月有35辆汽车。
问：我想把你的注意力引到2021年9月。
那个月你参与了兰博基尼的销售吗？
致一个名为 G/CLUBS 的客户？
答：是的。
问：你在那次销售中扮演了什么角色？
答：我帮忙简化了那笔交易的文书工作
顾客。
MURRAY 女士：Loftus 女士，如果你可以的话请出示

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见证被标记为政府展品 BR460 的内容。而且
滚动浏览第 2 页及以后。
问：Bonsukan 先生，你认出政府展览 BR460 吗？
答：是的。
问：你之前看过这个展览吗？
答：是的。
问：一般而言，政府展品 BR460 中有什么？
答：这是机动车买家的订单。它基本上显示了
车辆的销售以及谁出售的。
MURRAY 女士：然后滚动浏览几个
这个展览的其他页面，洛夫特斯女士。  
问：Bonsukan 先生，从高层次来看，这些业务记录是否
兰博基尼达拉斯？
答：是的。
问：你熟悉这些类型的文件吗？
答：是的。
问：可以说，收款是您业务的常规部分
并维护这些文件？
答：是的。
MURRAY 女士：法官大人，政府提议
政府展览 BR460。
SHROFF 女士：法官大人，我们没有异议。
法院：可以接受。
（收到的政府展品 BR460 作为证据） 
MURRAY 女士：Loftus 女士，你能不能发表

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第 2 页。
法庭：还有 Bonsukan 先生，如果你愿意提出你的问题
对着麦克风发声和说话。
目击者：是的，女士。是的，法官大人。
MURRAY 女士：如果我们能放大顶部
请分一份，洛夫特斯女士。
作者：默里女士：  
问：好吧。Bonsukan 先生，这是生意之一
兰博基尼达拉斯的记录。这有什么特别之处
文档？
答：机动车买家的订单。
问：再往左看，这个卖家是谁
特定的车？
答：兰博基尼达拉斯。
问：买家呢？
答：买家是G|CLUBS International Ltd。
问：这个买家下单的日期是什么时候？
答：2021 年 9 月 13 日。
问：我现在想看看左边的销售描述
单位。你能不能向陪审团描述一下兰博基尼是什么类型
这是。
答：这是一辆兰博基尼 Aventador SVJ Roadster。
问：向右看，那辆兰博基尼是什么颜色的
Aventador？
答：是红色的。

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问：还有一个实地考察库存编号或库存号。什么
信息反映在那里吗？
答：库存号是我们给出的数字——作为
我们更愿意销售的特定车辆的经销商
而不是使用 VIN 号码。
问：所以你提到了 VIN 号码。VIN 号码是什么？
答：车辆识别码，用于识别
车辆。
问：再往下看销售单位的描述，是
这里列出了这款兰博基尼的 VIN 号码吗？
答：是的。
问：那个 VIN 号码的最后三位数是多少？
答：最后三个是 393。
问：这辆兰博基尼是哪一年？
A. 2021 年。
MURRAY 女士：Loftus 女士，如果我们能缩小范围然后
放大右侧方框 “单位价格”，向下放到
底部，拜托。
问：Bonsukan 先生，排在最前面，这个价格是多少
特别的兰博基尼？
A. 829,999 美元。
问：然后往下看，总数是多少
加上税费时的价格？
A. 832,075 美元。
问：对不起。先生，你能再读一遍那笔钱吗

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A. 832,000.75 美元。
问：谢谢。
MURRAY 女士：还有洛夫特斯女士，如果我们能去
请在这个页面的底部有一条签名线。
问：Bonsukan 先生，你认出卖家的签名吗？
答：是的，那是我的。
问：那你签署这份特别信的日期是什么时候
销售合同？
答：2021 年 9 月 13 日。
MURRAY 女士：我们可以把它记下来，洛夫特斯女士。
作为政府，让我们拿出有证据的东西
参展 CT38、37 和 40。
问：Bonsukan 先生，从左上角开始，从
政府展品 CT38，你认得里面描绘的汽车吗
这张照片？
答：是的，那是一辆兰博基尼 Aventador。
问：那是什么颜色的？
答：是红色的。
MURRAY 女士：洛夫特斯女士，我们可以把它们记下来，而且
请把政府展出 CT42 和 43 号展品，它们是
作为证据。
问：从左边开始，邦苏坎先生，政府展览
CT42，你能不能向陪审团描述一下，我们到底是什么样子
看着那张照片。
答：这是车辆的驾驶员侧；车门，

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是剪刀门，它向上抬起，上面显示了 VIN 牌照
车辆。
问：你能不能再描述一下剪刀门是怎么回事
请操作。
答：所以它是铰链的，比如——剪刀门通常是向上铰链的
用这种特殊的方式开门，就像这个一样，
而不是车辆上的普通门，它会向外摆动，比如
如果你正在打开和关闭一扇门。
问：还有你提到的 VIN 牌照，照片中的哪里
左边我们看见了吗？
答：正是黑板就在剪刀门上。
MURRAY 女士：还有洛夫特斯女士，在我们右边
在那个黑板上放大一部分，那个 VIN 牌照，
我们能否进一步放大 VIN 号码。
问：Bonsukan 先生，VIN 的最后三位数是多少
这个兰博基尼的号码？
A. 393。
MURRAY 女士：如果可以的话，洛夫特斯女士，在左边
一边，拉出第 2 页的政府展览 BR460，然后放大
在 VIN 字段上。
然后在右边的照片上，同样放大
VIN 字段。
问：好吧。Bonsukan 先生，所以这里的顶部是放大镜头
我们刚才看的汽车的 VIN 版本
的照片。你能不能读一下那个 VIN 号码，

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车辆识别号码，记入记录。
A. Z 就像斑马，H 和亨利一样，W 和威廉一样，U 也是
雨伞，N 像南希一样，Z 像斑马，D 像大卫一样，2，M 是
在路易斯安那州玛丽市就像在利马一样，在 alpha 版本中，10393。
问：然后看看这里底部的那个，
Bonsukan 先生，来自销售合同
兰博基尼达拉斯到 G|CLUBS International，是一样的吗
照片中描绘的汽车上的 VIN 号码？
答：是的。
问：根据你过去在兰博基尼达拉斯的工作
13 年左右，你知道是否 VIN
数字是特定车辆所独有的？
答：他们是。
MURRAY 女士：洛夫特斯女士，我们可以把它们记下来。
让我们向目击者展示标记了什么
如政府展览 GX GC295，第 10 页。
问：Bonsukan 先生，你能看到政府的内容吗
这里是展品 GC295，第 10 页？
答：是的。
问：你认出来吗？
答：我知道。
问：你是怎么认出来的？
答：它是 —— 上面有我的名字。这是一封普通的信
连同我们寄出的文件一起发送给客户
给他们签名。

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MURRAY 女士：法官大人，政府提议
政府展览 GC295。
法院：有人反对吗？
SHROFF 女士：不，法官大人。
法院：可以接受。
（收到的政府展品 GC295 作为证据） 
MURRAY 女士：我们能不能把它发布出来。
作者：默里女士：  
问：Bonsukan 先生，这封信的日期是什么时候？
答：2021 年 9 月 14 日。
问：它是寄给谁的？
答：霍兰先生。
问：看看这里的签名区块，那是你的签名吗
还是你在这封信上的电子签名？
答：是的。
问：总的来说，这样做的目的是什么
信？
答：这基本上可以解释一下，感谢客户购买了
车辆，然后是需要做的事情
为文书工作提供便利，然后指示他们去联邦快递
文件返回。
问：这封特别的信函是否与合同有关
促销日期为 2021 年 9 月 13 日，我们刚刚看过 G
国际俱乐部？
答：是的。

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MURRAY 女士：洛夫特斯女士，让我们把它记下来然后放下
请再次登上政府展览 BR460，第 5 页。
问：这是什么类型的文件，Bonsukan 先生？
答：这是我们经销商的内部记录，当 a——when
资金是从客户那里收到的。
问：那么这个右上角列出的日期是什么时候
特定的文件？
答：2021 年 9 月 14 日。
问：往左看，它显示已收到现金
来自，你看见了吗？
答：是的。
问：正如所反映的那样，谁把钱寄给了达拉斯兰博基尼
这里？
答：它显示的是G|CLUBS Hold Co. 1, LLC。
（下一页继续）

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作者：默里女士：  
问：那是不是部分划掉了还有什么
写在上面？
答：是的。
问：此处列出的更正名称是什么？
答：G|CLUBS International LLC。
问：看看下面的付款金额，金额是多少
从 G|CLUBS 进行电子转账的总金额
国际？
A. 832,000.75 美元。
问：还有下面粗体显示的电线细节，电线来自，你呢
看见了吗？
答：是的。
问：你能读懂它所反映的内容吗？
答：商业银行为G|CLUBS International Ltd提供的电汇
MURRAY 女士：请转到下一页，
洛夫特斯女士。
问：这是什么，Bonsukan 先生？
答：这是一封电汇确认信，是通过电子邮件发送给我的
摩根大通银行，即我们的银行，会在发生以下情况时发出通知
已收到电汇。
问：那这个电汇通知的日期是什么时候？
答：2021 年 9 月 13 日星期一。
问：低头看这封电子邮件的正文，这是哪家银行
电汇来自？

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A. 从格林伍德村储备信托公司收到
科罗拉多。
问：然后往下排几行，有一个受益人然后是
B/O 客户。这反映了什么？
A. 费尔南德斯·容科斯大道644号国际商业银行，
Third Flo，波多黎各圣胡安。
MURRAY 女士：洛夫特斯女士，请看第 8 页。
如果我们可以放大文本。谢谢。  
问：有点难读，Bonsukan 先生，但是什么样的
信息反映在此业务记录中？
答：这看起来像电线指令。
问：你能读懂这里顶部列出的银行名称吗？
答：银行名称是储备信托公司。
问：收款人账户名呢？
A. 国际商业银行。
问：最后，为了进一步了解底部的信用，那是什么
在 MBI 客户账户下列出？
答：G|CLUBS 国际有限公司。
问：如果你能读出那个 MBI 的最后五位数字
G|CLUBS 国际有限公司的客户账号？
A. 10103。
MURRAY 女士：好吧。洛夫特斯女士，我们能走吗
转到第 1 页 — 从 BR-460 的第 19 页开始。
问：Bonsukan 先生，你看到这里反映的这封电子邮件了吗？
答：是的。

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MURRAY 女士：如果我们能向下滚动，洛夫特斯女士。
这是连锁店的一部分。我们将从其中的一些开始
此链中较早的消息。看这里 —— 谢谢，
洛夫特斯女士。
问：这是一封电子邮件，2021 年 9 月 9 日。你能告诉我们是谁吗
是从哪里发来的？
答：它是由 Max 寄来的。
问：它寄给了谁？
答：致迈克·德基。
问：谁是迈克·德基？
答：兰博基尼达拉斯的前销售人员。
问：在支架外部之后，主题是什么
这封电子邮件？
A. G|CLUBS Hold Co.LC732-Lambo SVJ 跑车。
问：还有 LC 732，这意味着什么？
答：这是我们这件商品库存中的库存号
特定的车辆。
问：你能看看 Max 给 Mike 的这封电子邮件的正文吗
达拉斯兰博基尼的 Durkey？
答：“嗨，迈克。运送到康涅狄格州的费用是多少？”
问：还有一个迹象表明了电子邮件账户的类型
Max 发送了来自的电子邮件。你能读一读吗？
答：从 ProtonMail 安全电子邮件发送。
MURRAY 女士：好吧。Loftus 女士，让我们向上滚动
拜托了，所以我们稍后再来这个电子邮件链。

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问：好吧。从顶部的电子邮件开始
Max 给 Mike Durkey，你能看一下这封电子邮件的内容吗？
拜托，Bonsukan 先生？
答：上面写着：“你能帮忙安排送货吗？另外，我应该
明天有分辨率和驾照。请稍等
车辆。谢谢。”
问：Bonsukan 先生，你知道这里指的是什么吗
“分辨率” 反映了什么？
答：是的。基本上 —— 分辨率是它显示了谁
特定企业的董事或高级管理人员或成员。
问：在向公司实体或公司出售的过程中
公司，兰博基尼达拉斯就是那种文件吗
通常与销售相关的收款？
答：是的。
问：为什么？
答：我们要确保无论谁购买车辆，都是
一个能够为车辆签字的车辆。
MURRAY 女士：好吧。洛夫特斯女士，我们继续吧
请在此电子邮件链中。因此，我们将从头开始集中精力
一直到那封电子邮件的底部。
问：所以如果你从中间开始，Bonsukan 先生，
因为这是转发的。从 Max 的电子邮件开始
再次。现在是 2021 年 9 月 10 日。你能读懂内容吗
请把那封电子邮件发给迈克·德基。
答：“嗨，迈克。随函附上护照，我会发短信给你

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分别输入密码。另外，附上的是正确的实体
名字。请使用更正后的姓名重新签发文件。
谢谢。亲切的问候，Max。”
问：然后该电子邮件将转发给您，我们可以在此处看到
这部分的顶部。你看见了吗，迈克·德基对你来说吗？
答：是的。
问：那他做了什么 —— 迈克·德基给你写了什么？
答：“护照由绝密密码保护：123456。”
MURRAY 女士：谢谢你，洛夫特斯女士。如果我们能保持
在链条中向上移动。好吧。现在我想集中精力
在下半部分从 Bonsukan 先生到 Max Krasner 的账户。
问：好吧。Bonsukan 先生，大约一个月后的事了
2021 年 10 月 19 日？
SHROFF 女士：反对作证。
法庭：你可以问他见到什么日期。
问：Bonsukan 先生，你能阅读一下这封电子邮件的日期吗？
答：日期是2021年10月19日。
问：谢谢。谁发了这封电子邮件？
答：它是我寄给马克斯·克拉斯纳的。
问：那它被发送到的电子邮件地址是什么？
A. Max — Protonmail.com 上的 M-A-X-K-R-A-S-N-E-R。
问：谁是 Max Krasner？
答：可能是其中一个代理人，这在以下方面有所帮助
与迈克·德基谈判。
问：还要就什么销售（如果有的话）进行谈判？

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答：Aventador SVJ Roadster。
问：那是向G|CLUBS的出售；对吗？
答：到 G|CLUBS。
问：你曾经亲自和马克斯·克拉斯纳谈过吗？
答：不是。
问：你有没有和 Max 沟通过
克拉斯纳关于此次出售？
答：通过电子邮件。
问：你可以阅读你发给 Max Krasner 的这封电子邮件，
拜托。
答：“嗨，马克斯。以下是买家订单的签名副本，
我收到的里程表和经销商重新分配表
特拉华州威尔明顿地址。这是迈克给的地址
对我来说。一旦我们有了标题，我们就会把它发送给你
位于 162 号东 64 号，纽约，纽约，10065 地址
联邦快递需要签名。我们会注意的
明天要看标题。如果我们没有收到，那么我们会
申请副本。最诚挚的问候，” 还有我的签名。
问：Bonsukan 先生，这里显示的标题是什么？
答：标题是为特定车辆提供的表格；基本上
这是那辆特定车辆的所有权文件。
问：如果有的话，兰博基尼达拉斯会用什么来做
卖车时汽车的所有权？
答：我们将所有权重新分配给新所有者。
MURRAY 女士：洛夫特斯女士，如果我们能把它记下来。

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实际上，让我们来看看 BR-460 的第 9 页。我们可以放大 
在上半部分所以要大一点。 
问：Bonsukan 先生，这份文件是什么，它是其中的一部分
我们一直在看的兰博基尼达拉斯唱片？
A. 显示 G Club International 的董事名单
有限。
问：在这份文件中，谁被列为指定导演
G|CLUBS 国际有限公司的？
答：它显示了何浩然。
问：看看右列，个人信息，是什么
浩然他是出生地？
答：中国。
问：还有国籍？
答：英国人。
问：再往右看，浩然是在哪一天任命的
G|CLUBS 国际有限公司的董事？
答：2020 年 10 月 16 日。
问：Bonsukan 先生，你曾经和何浩然谈过吗？
答：不是。
问：你曾经和何浩然沟通过吗？
答：不是。
MURRAY 女士：洛夫特斯女士，现在让我们转到第 12 页，
拜托。
问：这是什么，Bonsukan 先生？
答：这看起来像是英国护照。

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问：适合什么人？
答：对何浩然来说。
MURRAY 女士：请让我们转到第 18 页，
洛夫特斯女士。
问：再说一遍，与本次销售相关的部分业务记录，
这是什么类型的文件，邦苏坎先生？
答：这是从联邦快递收到的货物。
问：那本来会是什么信息或什么文件
使用此发货收据配送与以下商品相关的销售
那个兰博基尼？
答：兰博基尼Aventador这辆车的标题是
还有里程表声明，其他一些标题文件
这是转移所必需的。
问：现在，这里的 “发货人” 字段表示某个
公司。你能读出什么公司说的吗？
答：是的。浮桥汽车集团。
问：Boardwalk Auto Group有哪些隶属关系（如果有）
和兰博基尼达拉斯在一起？
答：浮桥汽车集团是我们的母公司。在那之下
集团我们有许多经销商，兰博基尼达拉斯是
其中之一。
问：往左看，你能不能看看 “配送至”
此联邦快递收据上反映的信息。
答：发货给 G|CLUBS International 的 Max。
问：地址呢？

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          南区记者，P.C.
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A. 162 East 64th，纽约，纽约，10065。
MURRAY 女士：如果我们能缩小一点，
Loftus 女士，请查看发货日期。实际上，整个
其中心部分。
问：Bonsukan 先生，这个联邦快递包裹的发货日期是什么时候？
答：2021 年 10 月 27 日。
问：然后看看这里的账单信息，你能读懂吗
底部的 “账单运送至” 下方反映了什么？
答：将账单运送至：Lambo-340。你的参考号码，
LC 732。
问：还有那个参考编号，我们在其他地方看到过吗
我们今天一直在看的文件？
答：是的。
问：该参考编号中反映了哪些信息
这和 G|CLUBS 兰博基尼有关系吗？
答：这是出售的兰博基尼Aventador的库存编号
去国际G|CLUBS。
MURRAY 女士：我们可以把它记下来，洛夫特斯女士。谢谢
您。
问：Bonsukan 先生，之后你在达拉斯兰博基尼任职
您已确认成功进行电汇或转账
金钱和收到要求的文件，如果有的话，该怎么做
你接下来要做什么？
答：我把所有东西都打包好然后寄到我的会计办公室
用于标题的处理。

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          南区记者，P.C.
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问：如果有的话，车辆是如何运送到的
顾客？
答：对不起？
问：如果有的话，车辆是如何交付到的
客户，车辆？
答：它们通常通过车辆运输。
问：兰博基尼达拉斯是否为货物的运输提供便利
有时会向客户提供车辆？
答：是的。
MURRAY 女士：Loftus 女士，如果可以的话请给我看
见证标为政府展览 GC-504 的内容。
问：Bonsukan 先生，总的来说，文件是什么类型
这个？
答：这是一份发货单，供承运人使用
运送了 Aventador。
问：这是保留在中的记录类型吗
兰博基尼达拉斯的正常业务流程？
答：是的。
MURRAY 女士：法官大人，政府提议
政府展览 GC-504。
法院：可以接受。
（收到的政府展品 GC-504 作为证据） 
MURRAY 女士：谢谢。
我们可以发表吗，洛夫特斯女士。我们可以放大 
在上半部分，首先浏览订单信息。

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          南区记者，P.C.
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O5OVGUO4 Bonsukan-直播
问：好吧，Bonsukan 先生。往右看，那是什么
右边列出的公司名称？
答：浮桥赛车运动有限责任公司。
问：再说一遍，如果你能提醒陪审团
那家公司和你的店铺兰博基尼之间的关系
达拉斯？
答：当他们为中央调度创建这个账户时，是
兰博基尼达拉斯的母公司。
问：再看看运营商的左边，会扮演什么角色（如果有的话）
承运人在装运车辆时有吗？
答：那是实际运送车辆的公司。
问：这里的订单信息下有发货日期。
发货日期是什么时候？
答：2021 年 9 月 22 日。
问：那提货估算值呢？
答：预计提货日期为 2021 年 9 月 25 日。
问：这个特定的预计送达量是多少
装运？
答：预计送达时间为 2021 年 9 月 30 日。
问：看看上面的订单编号，你能看懂什么吗
这个货件的订单编号是？
A. LC 732。
MURRAY 女士：Loftus 女士，我们可以缩小然后
请专注于下一部分。
问：现在，这辆特定车辆的车辆信息，

143
          南区记者，P.C.
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O5OVGUO4 Bonsukan-十字架
你能不能读懂年份、汽车类型和型号？
A. 2021 年兰博基尼 Aventador。
问：然后往右看，配送信息，什么
是那辆兰博基尼的收件人的名字吗？
A. Max（G|CLUBS International）。
问：G|CLUBS 的兰博基尼到底去了哪个地址
国际发货？
答：康涅狄格州格林威治市塔科尼克路373号，06831。
MURRAY 女士：法官大人，我可以等一会吗？
法院：是的。
（已聘请律师） 
问：Bonsukan 先生，你知道 G|CLUBS 是什么吗？
答：不是。
MURRAY 女士：没什么好说的，法官大人。
法院：盘问。
交叉检查 
作者：SHROFF 女士：  
问：你怎么样，Bonsukan 先生？
答：很好。
问：你在兰博基尼达拉斯工作；对吗？
答：我知道。
问：好吧。很抱歉。我看不见你。
而你是这个特别的负责人 
销售；对吗？ 
答：我帮助简化了特定销售的文书工作。

144
          南区记者，P.C.
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问：好吧。说你不记得任何人是公平的吗
来喜欢看车，就像你买一辆普通的车一样，
对吧？
答：是的。
问：没人来看，对吧？
答：我不知道。
问：好吧。然后你这么说，是吗 —— 我说对了吗
达拉斯兰博基尼每月售出大约35辆这样的汽车？
答：是的。
问：好吧。它像一辆普通的汽车还是像一辆车
跑车还是赛车？
答：在汽车世界中，它被称为异国情调的汽车。所以有
制作的不是很多。喜欢这个品牌的发烧友购买
车。
问：好吧。而且人们之所以购买汽车，通常是因为它可能是
开车很有趣；对吗？
答：是的。
MURRAY 女士：反对。
法院：持续。
问：它不是一辆日常使用的汽车，对吧？
答：通常不是。
问：通常不是。好吧。
而且你已经这样做了 13 年了；对吗？ 
答：是的。
问：这是你在课程中取得的众多销售之一

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          南区记者，P.C.
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O5OVGUO4 Bonsukan-十字架
你在达拉斯的工作情况；对吗？
答：是的。
问：好吧。所以让我走走 —— 问你几个就行了
关于 Murray 女士向你出示的文件的问题
在这里，好吗？
SHROFF 女士：如果我能买第一个 CT-39，拜托了。
问：你认得这辆车，对吧？
答：是的，这是一辆兰博基尼 Aventador。
问：你能告诉我们，“Aventador” 到底是什么意思吗？
答：Aventador 是特定模型的名称
那是建造的兰博基尼。通常它们是以一个名字命名的
公牛或著名的公牛或斗牛士。
问：好吧。这是你卖的车，对吧？
答：看来是，是的。
问：好吧。你能告诉我们这是什么电线吗
那是从车里出来的？
答：这是一次电池招标。基本上，维护电池
因为它位于车库里，所以只要客户想要，它就会很新鲜
下次再开车。
问：那么，如果你每次都用车，你通常会这样做吗
一天还是在不使用汽车的时候给电池充电
经常？
答：情况各不相同。汽车是 —— 即使关机了，电脑也是如此
系统仍在运行。所以很多业主总是想要
保留一块新电池，这样他们就可以插上电源。

146
          南区记者，P.C.
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O5OVGUO4 Bonsukan-十字架
问：好吧。而且你不会 —— 你无法分辨汽车多久开一次
已使用；对吗？
答：不是。
问：好吧。
SHROFF 女士：我能给我吗 —— 我本可以的
下架。如果可以的话，请放出 BR-460。
问：460 是你从 Murray 女士那里收到的文件
就在这里，你直接作证的是谁；对吗？
答：是的。
问：好吧。然后她要求你提供文件然后你把它们寄给
她；对吗？
答：正确。
问：你从来没有和我说过话，对吧？
答：不是。
问：而且你从来没有和任何人谈过辩护
桌子？
答：不是。不，女士。
问：好吧。而且我从来没有要求你提供任何文件；对吗？
答：不是。
SHROFF 女士：好吧。那么让我们来看看接下来的
文档。我们可以看看 CT-38 吗。
问：而且所有文件都与这辆车有关；对吗？
答：是的。
问：然后 Murray 女士问了你一些关于这种类型的问题
这辆车有门，对吧？

147
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O5OVGUO4 Bonsukan-十字架
答：是的。
问：而且这是一扇剪刀门；对吗？
答：是的。
问：这有什么意义吗？我的意思是，这只是一扇门，对吧，
一扇直门，一扇剪刀门？
A. 在兰博基尼上——
MURRAY 女士：反对，法官大人。
答：在兰博基尼上，这是兰博基尼的一个特殊特征
特别的型号，那就是 Aventador。
问：这就像一个花招，对吧？
答：不一定是花招。这只是一种特殊类型的
他们拥有的门。
问：好吧。在这辆车上有所谓的 VIN
数字，对吧？
答：是的。
问：VIN 号是车辆识别码；
正确？
答：是的，女士。
问：可以公平地说，对吧，每辆车都有VIN号吗？
答：是的。
问：斯巴鲁有 VIN 号吗？
答：是的。
问：福特有 VIN 号码吗？
答：是的。
问：与这辆高档车相反，如果我去买的话

148
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O5OVGUO4 Bonsukan-十字架
我自己是一辆普通的旧车，它会有 VIN 号码，对吧？
答：是的，会的。
问：好吧。那么这辆车上的 VIN 号码没什么特别的吗？
答：不，只是那辆特定汽车的识别标记。
问：好吧。太棒了。
SHROFF 女士：那么，请让我们来看看 295，GC-295。
如果你能向下滚动。
问：这些是你就此商品的销售进行过电子邮件往来
车；对吗？
答：你还在滚动吗？看起来像从 Max 到 a
人数。
问：对。而且你从来没有 —— 你作证过你从来没有说过话
给 Max Krasner，对吧？
答：不，不是——不是身体上的，也不是——只是通过电子邮件。
问：好吧。而且你只是来回发电子邮件是因为你
想让这笔交易顺利进行；对吗？
答：是的。
问：这就是你有经销商的部分原因，对吧，你
想卖车吗？
答：是的。
问：而且这辆车的销售并没有什么不愉快之处；
正确？
答：不是。
问：你在出售这辆车时没有遇到任何危险信号；
正确？

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          南区记者，P.C.
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O5OVGUO4 Bonsukan-十字架
答：不是。
问：好吧。你在关于一封电子邮件的直接证词中作证
质子是这么说的；对吗？
答：是的。
问：好吧。你会收到来自 gmail 的电子邮件；对吗？
答：是的。
问：雅虎；对吗？
答：是的。
问：质子；对吗？
答：是的，有时候。
问：好吧。所以它就像任何旧的电子邮件地址一样，对吧？
答：是的。
问：好吧。而且你还作证了关于一件上衣，不是吗
秘密密码；对吗？
答：是的。
问：最高机密密码是 123456；对吗？
答：是的。
SHROFF 女士：好吧。如果我能把它拿出来
向下请显示 295。你会向下滚动吗。对不起。
问：这些电子邮件在你身上来回传播——
在九月之前通过你的经销商，对吧？
MURRAY 女士：法官大人，反对。我想
Shroff 女士询问的文件与那份文件不同
现在是为陪审团展示的。
SHROFF 女士：拜托，我想要的是 460。

150
          南区记者，P.C.
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O5OVGUO4 Bonsukan-十字架
法院：这是正确的文件吗？
MURRAY 女士：法官大人，这是第 19 至 22 页。
作者：SHROFF 女士：  
问：那么让我们从第 19 页开始。你看到那封电子邮件是
就在那边说：“嗨 Max，我们有——”
SHROFF 女士：开始吧。谢谢。
问：“我们已经签署了买家订单的副本。”对吗？
答：是的。
问：里程表和经销商重新分配表，对吧？
答：是的。
问：顺便问一下，今天坐在这里，你还记得这是否是
你转售的二手车？
答：这是一辆二手车。
问：对。原来是—— “二手车”，你的意思是它被使用了
之前，对吧？
答：是的。
问：这不是一辆全新的兰博基尼，对吧？
答：不是。
问：好吧。所以这是一辆二手车，正在转售给
有人，对吧？
答：是的。
问：好吧。今天坐在这里，你知道那辆车有多旧吗
是？
答：在那段时间里？
问：是的。

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O5OVGUO4 Bonsukan-十字架
答：在 2021 年？所以这是兰博基尼的 2021 年车型，我们
它在 2021 年卖掉了。
问：好吧。那么在此之前有多少业主，对吗
知道吗？
答：我不确定。
问：你知道是不是不止一个吗？
答：有可能。
问：好吧。你真的不知道，对吧？本来可以是
一、二、三，你就是不知道？
答：正确。
问：好吧。对此很抱歉。而在这一点上
电子邮件链，那是 2021 年 10 月 19 日，对吧？有人是
给你一个地址 —— 你读这封电子邮件的位置是
告诉你将文件寄到哪里或寄到哪里
车？
答：发送标题。
问：要发送标题，对吗？
答：是的。
问：好吧。你把标题发到那个地址了吗？
答：我不知道。我的职务员确实如此。
问：好吧。而且你知道在东 64 号 162 号有哪些吗
街？
答：不是。
问：你知道那里有哪些企业吗？
答：不是。

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O5OVGUO4 Bonsukan-十字架
问：你知道谁在那里工作吗？
答：不是。
问：你听说过一个叫郭文贵的人吗？你有没有
听说过一个叫郭文贵的人吗？
答：不是。
问：好吧。
SHROFF 女士：如果我们能向下滚动的话。
问：这里还有一段关于护照的对话；
正确？
答：是的。
问：而且你会得到一份护照的复印件，不是吗？
答：是的。
问：那你为什么需要护照，先生？
A. 确定该人是谁
当他们购买特定车辆时为公司签字。
问：好吧。然后你有 —— 你有一份护照的复印件；
正确？
答：是的。
问：当然，你做了所有你需要做的事情来验证
那是一本正确的护照，对吧？
答：是的。
问：好吧。然后在那之后—— 
SHROFF 女士：如果你能把它关掉，拜托。
问：你有一封电子邮件询问你是否可以提供帮助
运输。然后他们说了交通援助

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          南区记者，P.C.
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可以提供；对吗？
答：是的。
问：好吧。而且，当你运送汽车时，你只会
东西开启后把车运出你的经销商
您的清单已得到满足；对吗？
答：是的。
问：你想确保标题正确通过，对吧？
答：是的。
问：注册，对吧？
答：是的。我们不注册现金交易，但我们
确保将所有权签发给正确的买家。
问：好吧。而且你还要确保买家有
驾照，对吧？
答：不一定是驾照，只是身份证。
问：好吧。所以你要确保这个人是正确的
已识别，对吧？
答：是的。
问：然后你做到了；对吗？
答：是的。
问：好吧。在你采取了所有这些步骤之后，你是
他们要把车运到他们告诉你的任何地址
对吧？
答：是的。
问：今天坐在这里，你还记得那辆车最初是不是吗
应该去另一个地址吗？

154
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O5OVGUO4 Bonsukan-十字架
答：不是。
问：你不记得了吗？
答：我不记得了，不是。
问：好吧。可以公平地说，汽车也要去哪里
决定汽车保险的成本？
答：嗯，承运人 —— 当我们设置配送时
我们的客户，我们要确保承运人 A，
可能熟悉运送车辆时的车辆
这个金额；并确保我们有足够的保险
掩护在运输过程中是否发生任何事情
客户。
问：对。但那是运输方面的保险
车，对吧？
答：正确。
问：作为一个上过车的人，你会同意我的看法吗
经营13年，每个州都有一定的成本
为汽车保险？
答：我隐约熟悉。
问：有些州比其他州更昂贵；对吗？
答：可能，是的。
问：保险取决于汽车是否放在车库里
或者停在街上；对吗？
MURRAY 女士：反对，法官大人。
法院：持续。
目击者说，他隐约熟悉。

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          南区记者，P.C.
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O5OVGUO4 Bonsukan-十字架
SHROFF 女士：法官大人，他可能知道答案。
法庭：有了这样的理解，他就可以回答。
问：你知道各州的保险费率是否不同吗？
答：不是。
问：如果你把车停在车上，你知道保险是否更高吗
街头对比你把车停在车库里？
答：这取决于保险公司。
问：好吧。足够公平。
SHROFF 女士：请问我能给个号码 504 吗。它是
好吧，其实。
问：当你准备运送汽车时，你得到了
地址；对吗？
答：我没有收到地址。我有个销售助理
实际上，我们的交通工具是为我们提供的
经销商。
问：好吧。因此，一旦你完成了汽车的销售，就会有人
否则会接手确保汽车到达原处
应该得到的，对吧？
答：是的。通常，销售人员和我们的销售助理。
问：你知道二手车的加价是多少？
答：二手车的加价？
问：是的，先生。
答：可能会有所不同。
问：你知道这辆车的加价多少吗？
答：在那个特殊的例子中，一辆兰博基尼 Aventador，

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          南区记者，P.C.
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O5OVGUO4 Bonsukan-十字架
制造商建议，建议零售价为2021年全新车型
零售价——65万美元。
问：好吧。而且你不知道这辆车开了多久
它出来之前的停车场，对吧？
答：不是，不是，特别不是。我能找到答案，但不是。
不久了。
问：当你与这个名叫 Max 的人互动时，
没错，他在告诉你或者至少告诉你办公室里的人
汽车要去哪里；对吗？
答：是的。
问：而且 Max 你知道是 G 俱乐部的一员；对吗？
答：是的。
问：当他还在的时候，他代表了 G Clubs 的利益
给你发电子邮件；对吗？
答：是的。
问：你可以得出结论，电子邮件中的马克斯·克拉斯纳知道
那辆车要去康涅狄格州；对吗？
答：是的。
SHROFF 女士：好吧。我能不能等一会儿，你的
荣誉？
法院：是的。
（已聘请律师） 
问：你在试图弄清楚决赛时和谁谈过
汽车的售价？
答：我没有和任何人说话。

157
          南区记者，P.C.
            (212) 805-0300
O5OVGUO4 Bonsukan-重定向
问：对不起，我切断了你的联系。
答：通常，销售人员会与销售人员协商价格
特定的客户。
问：所以你不知道和马克斯·克拉斯纳谈过多少次
销售人员来回走动，然后才到达
最终购买价格？
答：不是。
问：你不知道这些谈判持续了多长时间；
正确？
答：不是。
问：你知道克拉斯纳先生还是 G Clubs 的其他人吗
在汽车发货之前对它进行了检查吗？
答：我不记得了。这可能是可能的。
SHROFF 女士：法官大人，我没有别的了。
谢谢。 
法院：重定向。
MURRAY 女士：是的，法官大人。简而言之。
重定向考试 
作者：默里女士：  
问：Bonsukan 先生，刚才有人问你一些关于怎么做的问题
我们一直在谈论的兰博基尼已经上线了很长时间
很多。你还记得那些吗？
答：是的。
问：而且你表示时间不长；对吗？
答：是的。

158
          南区记者，P.C.
            (212) 805-0300
O5OVGUO4 Bonsukan-重定向
问：你还记得那样的销量吗
兰博基尼达拉斯在这段时间做了, 秋天
2021 年？
答：2021年秋季，显然是在COVID时代，汽车销量
是 —— 在自然吸气的发动机上，就是这样
Aventador，我们疯了因为兰博基尼宣布了
他们打算开始在他们身上安装混合动力发动机
车辆。因此，收藏家和喜欢这辆车的人都会喜欢
尝试购买它，即使他们购买的价格超过了实际价格
原始建议零售价是。
问：你提到这辆车的建议零售价是
大约什么？
答：大约 650,000。
MURRAY 女士：还有洛夫特斯女士，如果我们能停下来，
请，第 2 页的政府展览 BR-460。
问：这里重点是这辆车的最终销售价格，什么
是这辆特殊汽车，这辆二手车的最终销售价格吗？
答：未付余额为832,000.75美元。
问：这比制造商的要高出将近 200,000 美元
建议零售价；对吗？
答：是的。
问：这是一辆二手车，但当时是同一年
最终卖给了 G Clubs，对吧？
答：是的。
MURRAY 女士：洛夫特斯女士，如果我们能重点讨论这个问题

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          南区记者，P.C.
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O5OVGUO4 Bonsukan-Recross
然后向左走，看看为此列出的里程
特定的汽车。它位于销售单位的左上角描述中。
问：Bonsukan 先生，这辆车当时行驶了多少英里
卖给了G|CLUBS International？
答：317 Miles。
MURRAY 女士：好吧，洛夫特斯女士。我们可以缩小
然后再回到卖家和买家的顶部
列出了名字。
问：现在，邦苏坎先生，你在盘问中作证说
你不认识一个叫郭文贵的人；对吗？
答：是的。
问：你知道 G Club International Limited 里的 “G” 是什么吗
代表？
答：不是。
MURRAY 女士：法官大人，请稍等片刻。
（已聘请律师） 
MURRAY 女士：没什么了。
法院：重审。
SHROFF 女士：是的，法官大人。
你能不能离开那个展览。谢谢。 
再交叉检查 
作者：SHROFF 女士：  
问：卖掉的兰博基尼，红色的兰博基尼，对吧？
答：是的。
问：那几乎是一辆收藏车；对吗？

160
          南区记者，P.C.
            (212) 805-0300
O5OVGUO4 Bonsukan-Recross
答：是的，可能是。
问：这实际上是一项投资；对吗？
MURRAY 女士：反对，法官大人。
SHROFF 女士：她把它拿出来了。
法院：持续。
问：价格比一辆全新的汽车高，对吧？你
就此为默里女士作证，对吧？
答：是的。
问：那是为什么？
答：为什么价格更高？因为它是美国的热门车辆
从兰博基尼世界的角度来看，当时很多人是
想买这些车。
问：他们本来打算更改模型的；对吗？你
直接作证，说它是混合动力的；
正确？
答：是的，最终。
问：对。而且 G Clubs 购买的型号只能上涨
价值因为他们本来打算停止生产那些兰博基尼的
那样；对吗？
MURRAY 女士：反对，法官大人。
法院：你可以回答。
答：有可能。
问：好吧，你直接作证说如果价格上涨
往上走，人们快疯了，他们想保留那个
模型，对吧？

161
          南区记者，P.C.
            (212) 805-0300
O5OVGUO4 Bonsukan-Recross
答：这是一种风险，是的，有可能上涨。
但它也可能下降。
问：对。但这就是人们购买它的原因，对吧？
答：是的。
问：你作证说他们在停车场外真的很热
很多，因为每个人都以为这是一件收藏品
模型，对吧？
MURRAY 女士：反对，法官大人。
法庭：这是对他的错误描述
证词。持续。
问：疫情期间，人们一直在不停地购买它；对吗？
MURRAY 女士：反对，法官大人。
法院：持续。
问：疫情期间销量上升了吗？
答：是的，销售额确实上升了。
问：那个红色模特，对吧？
答：还有许多其他模型。
问：对。但是红色模型包含在其中的
销量在上升，对吧？
答：没错。这是兰博基尼的稀有汽车。
问：没错。谢谢。
SHROFF 女士：我能不能做这个展览
更大。
问：你会在左边看到的描述在哪里
销售单位已列出？

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          南区记者，P.C.
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O5OVGUO4 Bonsukan-Recross
答：是的。
问：它说已使用；对吗？
答：是的。
问：好吧。当你往下走，如果你往下看
这个文件，对吧？
答：是的。
问：好吧。销售人员的名字叫杜尔基先生。那是
Murray 女士让你读过的电子邮件链上的那个人
关于；对吗？
答：正确。是的。
问：而且他是完成销售的人，对吧？
答：他将是与之谈判的唯一联系人
客户。
SHROFF 女士：好吧。如果我能有那个
请缩小并显示文档的下一页。
问：这个页面只显示了汽车的平均销量，不是
不同——
MURRAY 女士：反对，法官大人。范围。
法院：持续。
问：开出停车场的汽车有保险，对吧？
答：可能，是的。
问：好吧。而且它是在康涅狄格州送来的；对吗？
MURRAY 女士：反对。
法院：持续。
SHROFF 女士：我受够了，法官大人。谢谢。

163
          南区记者，P.C.
            (212) 805-0300
O5OVGUO4                   
法庭：谢谢你，先生。你可以走出去。
证人：谢谢你，法官大人。
（证人原谅） 
法庭：那是今天的最后一位证人吗？
MURRAY 女士：我们还有另一位证人准备好了，你们
荣誉。但考虑到时间，我们会考虑你是否愿意
比如我们开始几分钟或者我们是否应该停下来
今天。
法庭：好吧。我想我们应该停下来
今天。你可以走出去。
稍等片刻。
陪审团成员，我们已经完成了我们的工作
今天。星期一是阵亡将士纪念日，所以你一定会是
按照已有的指示重返法庭
给你的这样你就能走进法庭
9:30 准时。遵循这些内容非常非常重要
仔细指示，确保你准时到达。
请记住，不允许你讨论这个案子
彼此之间。不要允许任何人讨论此案
你的存在。一旦你开始听见，总是很诱人的
证人证词，想讨论这个案子，但那是
绝对禁止。
祝你度过一个愉快的长周末，我看 
期待在星期二见到你。 
（陪审团不在场）

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          南区记者，P.C.
            (212) 805-0300
O5OVGUO4                   
法庭：请坐下。
我要请五号候补队员进来。
各方想提出什么吗？ 
SHROFF 女士：不，法官大人。
MURRAY 女士：不，法官大人。
（陪审员在场） 
法院：你好。你是 5 号候补球员，对吧？
陪审员：我是。是的。
法庭：我收到了你的来信然后你提出了
某些担忧。但是现在有了理解
交通安排，我的感觉是你的日程安排可以
使用已经讨论的第二个选项；是吗
正确？
陪审员：正确。直到我的孩子去哪里
已于 6 月 18 日完成学业。
法庭：然后呢？
陪审员：现在必须修改夏季计划
这样我才能继续当陪审员。
法庭：为了让你能做到，你可以做到
那些变化？
陪审员：我还没开始弄清楚那是什么
会导致。
法庭：嗯，我请你努力解决这个问题
你星期二回来。谢谢。
陪审员：谢谢。

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          南区记者，P.C.
            (212) 805-0300
O5OVGUO4                   
（陪审员不在场） 
法庭：好吧。如果没有其他的了
那我祝大家周末愉快。
MURRAY 女士：谢谢你，法官大人。你也是。
（延期至 2024 年 5 月 28 日上午 9:30）

166
          南区记者，P.C.
            (212) 805-0300
考试索引 
考试：页面 
 艾琳·麦克纳马拉 
53由芬克尔先生执导。..........
84Cross 作者：Shroff 女士。。。。。
117重定向作者：芬克尔先生........... 
119Recross 作者：Shroff 女士。。。。 
121重定向作者：芬克尔先生。..... 
122Recross 作者：Shroff 女士。。。。 
 路易·邦苏坎 
123 由 Murray 女士直接撰写。。。。。 
143Cross By Shroff 女士。。。。 
157 重定向作者：Murray 女士。....... 
159Recross 作者：Shroff 女士。。。。

167
          南区记者，P.C.
            (212) 805-0300
政府展品 
展品编号已收到 
62 CT-20 到 CT-30，CT-35 到 72，。
CT-74 到 105，CT-101 
直到 129，CT-157 通过 
187，CT-190 到 202， 
CT-204 到 207  
 STIP-1 62........
 36 66..........
 133 55.........
 CT-208 68........
 CT-209 67.......
 GC295 130.......... 
 BR460 124..................... 
 GC-504 141........................