Miles Trial Day 4 - 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

------------------------------x

UNITED STATES OF AMERICA,

v. 23 Cr. 118 (AT)

MILES GUO,

Defendant. Trial

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New York, N.Y.

May 28, 2024

9:10 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

CLARE TILTON

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)

Yu Mark Tang, Interpreter (Mandarin)

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(In the robing room)

THE COURT: I called you in this morning because

during jury selection and the first day of trial, I have

observed a troubling pattern of discord between the attorneys

in this case. In your interactions with each other, there have

been a number of instances of discourteous behavior, including

snippiness, bickering, sarcasm, eye rolling, and heavy sighs.

The tenor of the proceedings has been diminished by this

negative emotionalism.

As officers of the court, I expect that you will

observe courtroom decorum and abide by standards of

professionalism. If you deal with each other in an

unprofessional manner in the presence of the jury, I will stop

the proceedings and direct that you only address the Court and

not each other, which will slow down the trial considerably.

You have an ethical obligation to advocate zealously,

but that zealousness must never cross the line into disrespect

of your adversaries. Such conduct is an affront to the court's

dignity and may potentially disrupt and frustrate the trial.

I urge you to review the Supreme Court's decision in

Pounders v. Watson

, 521 U.S. 982, 988 (1997), as well as 18,

United States Code, Section 401. In other words, you need to

nip it in the bud. Don't test me.

I received a letter from the prosecution this morning.

They seek to admit certain exhibits that are preserved copies

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of online posts on G News and Gettr. When do you want to use

those exhibits?

MR. FERGENSON: Your Honor, we expect those will be

offered tomorrow.

THE COURT: All righty. So I will need a response

from the defense today. When do you think you can get that to

me?

MR. SCHIRICK: By 3:00, your Honor?

THE COURT: All right then. So I will address that

after I receive your response. You're excused.

MS. SHROFF: Your Honor, may we raise a matter that I

wish to raise prior to the start of the witness testimony?

THE COURT: Go ahead.

MS. SHROFF: Thank you, your Honor.

Your Honor, in the cross-examination last week, the

Court might recall I had difficulty with the exhibit numbering;

when I tried to pull up an exhibit from the defense side for

cross-examination purposes, it did not match up to the

numbering on the government's side. I have reviewed 3500

materials in this case that is being given to the defense with

constantly changing 3500 numbers, so what used to be 3519-57

three days ago is a different document than what it is today.

I raise this as a seasoned lawyer to inform the Court that I'm

having trouble keeping up with the constant——I've never had a

case where the 3500 numbers change. So that's one matter. And

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I hope that we can have a set of documents——and I think

Ms. Tilton can speak to this more if need be. But we are

having trouble reconciling the 3500 material being produced

with new Bates stamp numbers——with new 3500 numbers. That's

one issue.

The second issue is, we're getting 3500 material, and

I know this is normal, but for example, I just walked in this

morning and there is a two-page, single-spaced 3500 production

of the witness that's about to take the stand. So

respectfully, I know you don't take a break before lunch, but

either I need 20 minutes now to review it or I will need 20

minutes after the witness testifies to review it. I did not

even have a second copy to go over it with Mr. Guo. I imposed

upon your court to either run to the fifth floor to make a

copy, but I see that your law clerk helped me out and made an

extra copy. But I need at least 20 minutes to just go over

that. I'm sorry to raise this now, but it's——

MR. FINKEL: Your Honor, over the weekend our

paralegal Ms. Loftus sent the defense, in response to questions

from the defense, updated exhibits and exhibit list that we

audited, which should resolve the issues that Ms. Shroff just

mentioned. The 3500 that Ms. Shroff is mentioning just now is

3500 material that was generated this morning, so we gave it to

the defense as soon as it was completed. But to help

Ms. Shroff out, we will call that witness later on and we'll

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call Le Zhou first so Ms. Shroff will have plenty of time to

review that 3500 material in advance of that witness testimony.

THE COURT: So this is precisely the type of issue

that I should not be hearing about. In 24 years I've never had

lawyers come to me and tell me that they can't agree on the

numbering of exhibits. For goodness sakes, you have got to

cooperate on these purely ministerial matters.

So you'll have the break to review that document.

MS. SHROFF: Yes, your Honor, but there's nothing we

can do about the numbering system. We're happy to cooperate.

I believe Ms. Tilton is in constant contact with them. This is

really her bailiwick. She has, and I have, I think Ms. Loftus

has done the same. But I don't think that this is a lack of

cooperation problem. I don't know what the problem is.

Honestly, I've never had a case——I agree with you——where 3500

numbering is changed. I've never had that. A document that's

marked number 19 remains 19.

THE COURT: Ms. Shroff, I've heard enough. You know

how to fix this. Fix it.

You're excused.

ALL COUNSEL: Thank you, your Honor.

(Recess)

(In open court; jury not present)

THE COURT: Good morning. Would you make your

appearances, please.

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(Appearances noted)

THE COURT: Please be seated.

Please have the jurors brought in.

(Jury present)

THE COURT: Please be seated.

Good morning, jurors.

THE JURORS: Good morning.

THE COURT: Welcome back. Thank you for arriving on

time. This way, you can walk into the courtroom at 9:30 and we

can get going and proceed in an efficient manner. Thank you.

Would the prosecution call its next witness.

MS. MURRAY: Thank you, your Honor. We call Le Zhou.

THE LAW CLERK: Please raise your right hand.

(Witness sworn)

THE COURT: Please state your name and spell it.

THE WITNESS: My name is Le Zhou, L-E, Z-H-O-U.

THE COURT: You may inquire.

MS. MURRAY: Thank you, your Honor.

LE ZHOU,

called as a witness by the Government,

having been duly sworn, testified as follows:

DIRECT EXAMINATION

BY MS. MURRAY:

Q. Good morning, Mr. Zhou.

A. Good morning.

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Q. In what state do you live?

A. Florida.

Q. What do you do for work?

A. I'm a licensed realtor.

Q. Have you ever been a follower of Miles Guo?

A. Yes.

Q. Do you see anyone in the courtroom today that you recognize

from your time following Miles Guo?

A. Yes.

Q. Who?

A. I see Miles Guo.

Q. Can you describe him by where he's seated and an item of

clothing he's wearing.

MR. KAMARAJU: We'll stipulate to identity, your

Honor.

THE COURT: He has indicated the defendant. Go ahead.

MS. MURRAY: Thank you, your Honor.

Q. Do you see anyone else that you recognize from your time

following Miles Guo in the courtroom here today?

A. Yes. A few.

Q. Can you identify them by their names or the names you know

them by?

A. There's a few followers sitting in the court on the

audience side, left side. The name? Yes. Rachel Eva, Miles

7, Yongbing Zhang. There's a nickname, "Heaven Spare No One."

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That's all I see.

Q. Thank you. Mr. Zhou, where were you born?

A. China.

Q. When did you come to the United States?

A. 1998.

Q. Why did you come to the United States?

A. I came here to study, in——for college.

Q. After you moved to the US, where did you go to school?

A. I went to Miami-Dade College.

Q. And what did you study there?

A. I was a major in music education, and I played piano and

the trombone.

Q. Mr. Zhou, are you a supporter of the Chinese Communist

Party, or the CCP?

A. No.

Q. What experience, if any, has your family had in the past

with the CCP?

A. Our family suffered tremendously from the Chinese

government, both family on my mother and my father's side.

My——my maternal grandparents, they went abroad to

study. My grandfather was soil engineer. He worked building

roads, and at the time he worked for the Chinese government.

After he finished building road, he become a professor at a

university. During cultural revolution and the Red Guards,

some of his students came to their houses, physically and

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verbally abused my both parents——grandparents. So my maternal

grandmother couldn't take the shame of it, so she committed

suicide. Before she did that, and she took my great

grandmother's life, because she thought no one would take care

her. And so that, my maternal parents just——the families fall

apart. My mother was only 16 at the time.

My father's, my grandparents' side——we used to own

business as regular grocery store. We have a small plaza. The

government, during Second Sino-Japanese War, they came to ask,

they would take our assets to help the country. They said

they're going to borrow it, but it took majority of the assets,

left little bit for the family to survive. My father has nine

sisters and brothers, but that is not enough to feed all the

family. So two of the children, was forced to give away.

That's——that's my both parents, how they suffered from

this government.

And there's also one big impact, almost not to have me

to live, was one child, one——one child, one policy in China.

It was implemented in 1980. At the time, my mother was already

seven months' pregnant, and my parents wanted to have me

and——but the government wanted to do a forced abortion. So my

parents——my mom went hiding while my dad was reasoning with the

government. In the end, he made a deal that by lowering my

both father's salaries and also to give up the newborn baby's

welfare, which is food, milk, I don't get that, so they would

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spare my life.

So——and also one experience I personally witnessed,

when I was 9 years old——that's 1989——the student protests

happened Beijing, also happening in my hometown as well. At

the time we lived in apartment, very close to our hometown, the

government square, where the student protests happened. So we

were quarantined at the house, not allowed to leave the

community, and we were——at a time we heard outside shouting,

very loud. So I used to live on the first floor. That day,

when we heard outside a lot of protests, shouting, and I went

up to the eighth floor to my parents' friends' house. Their

balconies are facing directly to the streets. When I walked,

walk up to there, at a balcony, I saw, right near a bus stop, a

female student was covered, someone——riot police used a sandbag

cover her, just yank her away, and two other just jump up and

beat her up. Then later, I move my——aside to nearby, very

close, just looked down; there's a mall, one-story mall. There

were some protestors climb up the first floor of the roof. And

they were throwing some objects into the crowd. Then we hear

loud bangs, then I saw the tip of the concrete wall, with the

rooftop, the dust just smashing, shooting the air. We heard

people shouting, "Shots fired, shots fired." We were all

scared. We just quickly got inside our house.

So that's——that's the fear we felt for——and we know

the regime is cruel.

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Q. And how, if at all, did those experiences affect your view

of the Chinese government?

A. The government is not——is untrustworthy. Their cruelty and

brutality, it's unimaginable.

Q. Mr. Zhou, you mentioned that you had been a follower of

Miles Guo. When did you first learn about Miles Guo?

A. Back in 2017, earlier, February.

Q. And how did you learn about him?

A. I watched YouTube, while he's broadcast.

Q. What did you see on YouTube about Miles Guo in 2017?

A. At the beginning, Miles Guo was doing a broadcast called

Safety Announcement. So I was just curious who this person

was. Then I——that's how I first watched the videos.

Q. And before watching that video had you heard of Miles Guo?

A. No.

Q. Did you continue to watch his videos after that first time

that you saw him in 2017?

A. Yes.

Q. What, if anything, caught your attention about his

broadcast?

A. Miles Guo introduced himself, then we learned he's a

self-made billionaire. But he escaped the Chinese government's

persecutions, and he escaped to the United States, looking for

protection. And he also started talking about corruption, the

Chinese high official corruptions. He has classified

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information; he will expose their corruptions.

And I also learned that he living New York, Manhattan.

He has——he bought his luxury hotel in New York called

Sherry-Netherland Hotel. And also he introduced his family

back home. He has a big family, near a hundred people in his

family; and his wealth, the family owns $20 billion networks

and he owns private jets, luxury yachts, over hundred race

car——luxury cars. Also, at the time, he's well dressed in his

broadcast, seemed very knowledgeable, well spoken, and he talk

about a lot, his knowledge on cultural. And even sometimes a

lot of time impressed me was he mentioned he has bodyguards,

24/7, and he has a legal team. Sometimes he mentioned

he's——the information he holds, or he has, he will bear the

legal responsible for what he talk about.

Q. The information that you just provided, was the source of

that information Miles Guo himself during those broadcasts?

A. Yes.

Q. Did there come a time when Miles Guo launched a

whistleblower movement?

A. Yes.

Q. How did you learn about that movement?

A. Because I started watching his videos, and I know the

movement 'cause he called himself a whistleblower.

Q. What, if anything, was the purpose of Guo's whistleblower

movement?

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A. Whistleblower movement was to expose Chinese officials'

corruptions.

Q. What actions, if any, did Guo encourage whistleblower

followers to take to combat the CCP corruption?

A. At the time he used——using social media, we become

followers of his social accounts. Of course I learned some of

the corruption he mentioned in his broadcasts. He encouraged

us to spread words. Beginning, my action was just following

everyone else, retweets, or sometimes repost while he talk

about it, just spread into other——I had created a Twitter

account to help to spread the words.

Q. What, if anything, did Guo say about how people could join

the whistleblower movement and become followers?

A. Beginning, he has——had his Twitter accounts, people can

follow him, and also, at the time, there were few very activist

followers appear on the social media. There would also reveal

their identity, face, and join Miles's broadcasts. At the time

there were one follower named Sara Wei. She created a group

called Voice of Guo. Then there was a——people can also join

there, also that means join the movement. So I joined that

group.

Q. Was Voice of Guo also called VOG at times?

A. Yes.

Q. How, if at all, did the followers communicate with one

another?

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A. At the time we have software we used for everyone to

communicate. It's called Discord.

Q. Can you describe for the jury what Discord is.

A. Discord is a free software, allow user to create channels,

which is like chat rooms. The chat room then also you can

create subchannels for any other categorized purposes. The

software, you're able to let users to join using link, and you

can send messages, share messages, pictures, videos, files.

And you can also start voice meetings in the——in the group. So

when I joined, it was categorized, and the part I remember was,

there's subchannels as a——so they create a subchannel as a

working group, as a task——task force, for certain things we

want to do.

Q. Did you and the other followers use your real names in

those Discord chats?

A. No.

Q. How, if at all, did you identify yourselves?

A. I had created my user name as Coffee Cantata, then use

Chinese two words, Wen Lu (ph). That was my hashtag.

Q. And did other followers similarly use aliases or handles

when they communicated with one another?

A. Yes, mostly at the time everyone has their own nickname.

Q. By the way, what other names, if any, do you know Miles Guo

by?

A. Seven Brothers, and also Ho Wan Guo; that's the Cantonese

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pronunciation.

Q. Mr. Zhou, are you familiar with the Rule of Law

organizations?

A. Yes.

Q. What are those?

A. Rule of Law was created by Miles for——it was a charitable

organization.

Q. Around when were those Rule of Law organizations launched?

A. In 2018.

Q. And how did you hear about them?

A. It was publicly announced during press conference.

MS. MURRAY: Your Honor, at this time I would like to

offer a stipulation between the parties. This is Government

Exhibit Stip 2.

THE COURT: So I just want to remind the jurors what a

stipulation is. A stipulation is an agreement between both

sides to present evidence to the jury without calling a witness

to testify about the subject matter.

You may read the stipulation.

MS. MURRAY: Thank you, your Honor. This is a

stipulation regarding web pages and videos.

The parties stipulate that in the chart that is

contained within this exhibit, which is Government Exhibit Stip

2, columns A, B, and C accurately list the following

information:

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The government exhibits listed in column A are

authentic copies of web pages that were preserved from the

internet. If a web page contained a video that was also

preserved, the associated video is designated with a V in the

government exhibit name. For example, GX C20 is a preservation

of a web page, and GX C20-V is a preservation of the video that

was on that web page.

Column B in the stipulation lists the web address or

url of the web page that was preserved.

And column C lists the date on which the web page was

preserved.

And at this time, your Honor, there is a chart

contained within this exhibit which is now admitted. I would

like to just note two of the exhibits noted within this chart.

One is GX C26 and corresponding GX C26-V. Those are YouTube

videos that were preserved, and they are dated July 15, 2020.

And then GX C63 and GX C63-V; again, YouTube video from a web

page, and that's dated November 25, 2020.

THE COURT: And you're moving to admit that.

MS. MURRAY: Moving to admit those two exhibits from

within this chart and moving to admit the stipulation at this

time.

THE COURT: They're all admitted.

MS. MURRAY: Thank you.

(Government's Exhibits Stip 2, C26, C26-V, C63, C63-V

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received in evidence)

BY MS. MURRAY:

Q. Mr. Zhou, directing your attention to November of 2018, did

there come a time when you watched a livestream of an

announcement relating to the Rule of Law?

A. Yes.

Q. Do you recall on what website you watched that

announcement?

A. It was on a livestream.

Q. The website is named Livestream?

A. That was a link. It's a——livestream will push out the

channel, the broadcast, but the channel was under Rule of Law

Foundation. The livestream, I believe the website associated

was Vimeo.

MS. MURRAY: Your Honor, we would move to admit one

more exhibit from GX Stip 2. That's GX W1005 and GX W1005-V,

and that's YouTube, and it was preserved on February 9, 2024.

THE COURT: They're admitted.

(Government's Exhibits W1005, W1005-V received in

evidence)

MS. MURRAY: Thank you.

Ms. Loftus, could we now publish what's admitted in

evidence GX W1005-V.

BY MS. MURRAY:

Q. Mr. Zhou, do you recognize this video?

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A. Yes.

Q. Have you viewed it before?

A. I watched it earlier and live.

Q. And there's an insignia on the top left here.

MR. KAMARAJU: Your Honor, I apologize. Could we have

a brief sidebar on this.

THE COURT: All right.

(Continued on next page)

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(At the sidebar)

MR. SCHIRICK: Your Honor, the defense just wanted to

be clear that the stipulation was just to the online

preservation. We hadn't stipped to moving it into evidence.

So we have an objection to hearsay. It's going to——they're

going to play a video of Mr. Bannon speaking at this press

conference.

THE COURT: So I don't understand what you're saying

was not admitted through the stipulation.

MR. SCHIRICK: The stipulation, your Honor, was just

to authenticity. It was to the video having been pulled down

from the source. The stip did not go to the admissibility.

THE COURT: Go ahead.

MR. FERGENSON: That's correct, your Honor. It's just

authenticity in the stip. I understand the objection is to

hearsay. We're not offering this video clip for the truth of

what Mr. Bannon is saying in it; we're offering it for the

falsity of what he's saying. And it's a clip from the joint

announcement of the Rule of Law Fund, where both Mr. Guo and

then Mr. Bannon speak, and this is a clip from Mr. Bannon's

speech.

THE COURT: So are you seeking to admit it because

it's an admission?

MR. FERGENSON: No, because it's not offered for its

truth. We're offering it for the fact that it was said.

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MR. SCHIRICK: Your Honor——

THE COURT: For the effect on the listener?

MR. FERGENSON: Correct, your Honor. These are launch

videos that victims watched and believed.

MR. SCHIRICK: And your Honor, what Mr. Bannon is

going to say in that video that the government is going to show

the witness and the jury is a statement by Mr. Bannon that

Mr. Guo was going to start the Rule of Law Foundation with a

hundred million dollars. They contend that that was a

representation that it was his own money. So it is in fact

offered for the truth of that statement, that that's in fact

what Mr. Bannon said and that that was, in effect, a

misrepresentation. So I'm not sure that there is not——there

are nonhearsay issues here. And——

THE COURT: Are you suggesting a curative instruction?

MR. SCHIRICK: I think we do need a limiting

instruction, your Honor. But I think there is a risk of 403

with the jury here as well.

THE COURT: I would expect that numbers of these types

of statements, video or otherwise, are going to be propounded

by the prosecution; am I correct?

MR. FERGENSON: Yes, your Honor.

THE COURT: So I'm looking for an application for a

limiting instruction.

MR. SCHIRICK: We would ask, your Honor, that the jury

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be given a limiting instruction that this is not a

statement——that Mr. Bannon's statement is not a statement

attributable to Mr. Guo.

MR. FERGENSON: We would object to that. That's not

necessary for the admission of the statement. We would be fine

with a limiting instruction that said these statements are not

being offered to prove the truth of the matter asserted.

That's the definition——

MR. KAMARAJU: Your Honor, since this is just an

authenticity stip, I think the prosecution has to lay the

foundation in order to introduce this through the witness. I

know this one has already come in, but I think as these videos

are coming in, I think the proper format is to do that first.

THE COURT: Absolutely.

MR. KAMARAJU: Thank you, your Honor.

THE COURT: Okay.

(Continued on next page)

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(In open court)

BY MS. MURRAY:

Q. Mr. Zhou, there's a logo on the top left of this

screenshot. Do you see that?

A. Yes.

Q. What does that read?

A. Guo Media.

Q. What is Guo Media, or what was Guo Media at the time?

A. It was earliest symbol that was created for this movement.

There was a media channel. That's the name for it.

Q. And what type of content, if any, was posted on Guo Media

at this time?

A. At this time, this was that press conference happening in

New York.

MS. MURRAY: Ms. Loftus, if we could please play this

video. This is Government Exhibit W1005-V1.

THE COURT: Is it now that you're looking for me to

give the limiting instruction?

MR. KAMARAJU: Yes, your Honor.

THE COURT: Members of the jury, this video is not

being offered by the government for the truth of what is stated

in the video. Keep that in mind as you watch it.

MS. MURRAY: Thank you, your Honor.

(Video played)

BY MS. MURRAY:

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Q. Mr. Zhou, do you recognize the individual depicted in this

video?

A. Yes, I do.

Q. Who is it?

A. Steve Bannon.

Q. What role, if any, did Steve Bannon have with the Rule of

Law?

A. He was the co-founder of the Rule of Law Foundation.

Q. What, if anything, did you learn from the Rule of Law

livestream that you saw in 2018 about whether Miles Guo was

donating money to the Rule of Law?

A. The video I learned from was the conference that talk about

this announcement and also talk about this fund will use to

help Chinese dissidents and to have them to financially help,

and also help them with legal support, and to also use the fund

to investigate mysterious business deaths.

THE COURT: I'm sorry. Investigate mysterious what?

THE WITNESS: Business——persons' deaths.

THE COURT: Deaths. All right. Go ahead.

Q. Did you have an understanding of whether the Rule of Law

Fund would be funded with a certain amount of money at its

inception?

A. Yes. There was hundred million dollars.

Q. Now you said from your viewing of Miles Guo's broadcast

that at that time you had the impression that Miles Guo was

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wealthy; is that correct?

A. Yes.

Q. At the time that you viewed this launch video in 2018, did

you believe that Miles Guo could donate a hundred million

dollars to the Rule of Law charity?

A. Yes.

MS. MURRAY: We can take that down, Ms. Loftus. Thank

you.

Q. Did there come a time when you donated to the Rule of Law?

A. Yes, I did.

MS. MURRAY: Your Honor, may I approach the witness?

THE COURT: You may.

MS. MURRAY: Thank you.

I've handed the witness a binder that contains

exhibits that are marked for identification as GX C26,

GX C63-V1 and V4, GX CT209 and 211, GX VI150-160 and their

corresponding translations, GX VI180 through 190 and their

corresponding translations, GX V02, 13, 15-16, 18-19, 22-23,

25-29, 31, 59, 67-69, 77-78, 81-82, and 84, as well as

GX W1005, GX W56-57 and GX W59.

BY MS. MURRAY:

Q. And Mr. Zhou, I'd ask if you would briefly flip through

that binder and let me know if you recognize the exhibits that

are in that binder.

A. Yes.

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Q. Are those documents——are some of those documents, documents

that you provided to the government in connection with your

time when you were a follower of Miles Guo?

A. Correct, yes.

Q. Have you reviewed all of the exhibits that are contained

within that binder?

A. Sorry. At this moment?

Q. Previously, before today.

A. Before, yes, all.

MS. MURRAY: Your Honor, at this time the government

would move to admit Government Exhibits GX V2, 13, 15-16,

18-19, 22-23, 25-29, 31, 59, 67-69, 77-78, 81-82, and 84.

THE COURT: They are admitted.

MR. KAMARAJU: No objection.

MS. MURRAY: Thank you.

(Government's Exhibits V2, 13, 15-16, 18-19, 22-23,

25-29, 31, 59, 67-69, 77-78, 81-82, and 84 received in

evidence)

MS. MURRAY: Ms. Loftus, can you please publish what's

now in evidence as Government Exhibit VO27.

If we could zoom in on the top portion.

BY MS. MURRAY:

Q. Mr. Zhou, what is this?

A. That's my receipt, donation receipt.

Q. And what date is this document?

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A. May 18, 2019.

Q. What donation does this reflect?

A. This is donation to Rule of Law Foundations in $500, my

first donation.

Q. Why did you donate to the Rule of Law in 2019?

A. Yes, because I'm part of the follower, I want to help any

of the dissidents, as many as I can, not just follow Miles Guo

to help them, so that's the same goal I wanted to help.

Q. If Miles Guo had not donated a hundred million dollars to

the Rule of Law, if you had known that at the time, would that

have been important to you?

MR. KAMARAJU: Objection to form.

THE COURT: Overruled. You may answer.

A. Yes.

Q. Why would it have been important to you at that time if you

had known that Miles Guo had not donated a hundred million

dollars to the Rule of Law?

A. Because there's a lot of people that need help, Chinese

people, there's a lot of dissidents. Me alone, 500——I can do

as much as I can, but a hundred million dollars, that can help

a lot of people.

MS. MURRAY: We can take that down, Ms. Loftus. Thank

you.

Q. Mr. Zhou, did there come a time when you volunteered for

Miles Guo and his whistleblower movement?

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A. Yes, I did.

Q. Around when did you begin to volunteer?

A. In 2017, couple months I followed, I start following, just

retweeting when Miles Guo started, and later I also volunteered

to transcribe Miles Guo's videos. I also did translation and

video editing, and I also helped the streaming services for the

movement.

Q. Who, if anyone, assigned that volunteer work to you?

A. From beginning, from the VOG, there were some volunteer

groups, they give me the transcript work to do; then later, the

work assigned from farm management teams.

THE COURT: What do you mean by transcript work?

THE WITNESS: Yes, your Honor. Transcript means, most

of Miles Guo's video, it's in Chinese speaking. Now there's

not a subtitle. So we would have to create the subtitles.

That's transcript. I would listen the video, take down what

Miles Guo said in Chinese, then type it into a Chinese, become

a subtitle.

Q. And when you say farm, you mentioned that some of the work

was assigned to you by farm leaders. Can you explain to the

jury what you mean by farm.

A. Farm is a adjective. It's quotation for work, but the real

meaning is refer to offices, and Miles Guo mentioned, when the

whistleblower established, he wanted to have 50 farms, in

different regions in——throughout the world, become the

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subdivisions, offices.

Q. In what way, if any, were the farms kind of organized under

one unit?

A. The farm organized——there are person we call farm leader.

Most of the people were——beginning were very active as a

follower, follow the movement, follow movement. Those people

are some——most of them are designated by Miles Guo to become

the farm leaders. So there were farm, once it's created, in

different countries, regions, then also gather people locally

or online to have their own groups, but all under one of the

headquarter, which is farm called Himalaya Global Alliance to

managing those farms.

Q. Who, if anyone, was in charge of the Himalaya Global

Alliance?

A. At the time Global Alliance was only a few people and Miles

Guo was one. There are two——few peoples. Then they call

themself Iron Blood, a group.

Q. Why, if at all, did the leaders of the Himalaya Global

Alliance, Miles Guo and the others, call themselves the Iron

Blood group?

A. There were individuals selected by Miles, to give titles,

because Himalaya Global Alliance form with a designated

chairman, secretary general, and there's a few people that

Miles Guo designated those people. Miles Guo said, those are

brothers because those brothers are willing to sacrifice for

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him and shed the blood with him and for this movement. So that

name was formed from that.

Q. Returning to your volunteer work that you did for the

movement, were you paid for that work?

A. No.

Q. You mentioned that you were involved in, among other

things, streaming. On what website or websites did you stream

content?

A. On streaming, I did YouTube, and also on Gettr and GTV.

Q. What is Gettr?

A. Gettr is a——a social platform created by Miles Guo. It's

similar to Twitter. It's just like Twitter features. You

share your posts and people can follow, retweet.

Q. What is GTV?

A. GTV, it's a website that similar act as YouTube, allow you

to post and the livestreams, post videos.

Q. And who, if anyone, was in charge of GTV?

A. In charge of GTV, I don't know.

Q. Whose company, if anyone's, was GTV?

A. Oh, GTV was owned by Guo Media.

Q. And who owned, in turn, Guo Media?

A. That, I don't know who owned the company.

Q. Focusing on GTV for a moment, what, if anything, at that

time, in 2018, 2019, did Miles Guo say about GTV?

A. Miles——GTV here introduced, and he called out for

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investment that asked people who like to invest into GTV.

Q. Around when did Miles Guo offer an investment opportunity

into GTV?

A. Earlier 2020.

Q. Directing your attention to March of 2020, did you

participate in a Guo broadcast regarding that GTV investment

opportunity?

A. Yes, I did.

Q. What, if anything, did Guo ask his followers about their

interest in investing in GTV during that broadcast?

A. I remember I watched the video live when it was broadcast.

Miles Guo was calling people who like to invest in GTV. He

mentioned if you like to invest in $10,000, raise your hand in

the chat group by posting of the emoji, icon, as your intent.

He also asked, let me see who wanted to invest hundred thousand

dollars using two of the emoji as your intent.

Q. And during that broadcast what level of interest, if any,

was there from the followers in investing in GTV?

A. I sent one emoji as for intent for $10,000.

Q. From your viewing of that live broadcast did other

followers similarly indicate their interest in investing in

GTV?

A. Yes, there were a lot of one emoji for 10,000 and also few

a hundred thousand dollars investment that people putting two

emojis.

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BY MS. MURRAY:

Q. Now, directing your attention to April 21st of 2020, did

you watch a pre-recorded broadcast that Guo streamed about the

GTV investment opportunity?

MR. KAMARAJU: Objection to form, your Honor. She's

testifying.

THE COURT: You can restate the question.

Q. Directing your attention to April 21st of 2020, did you

watch any broadcasts on that day that were relevant to GTV?

A. Yes.

Q. Did those include a broadcast of Miles Guo?

A. Yes.

Q. What, if anything, was the subject of what Miles Guo was

discussing during that broadcast?

A. Yes. I remember I got a share link for that. Miles Guo

mentioned the GTV. First he mention any investment has risk.

Then for any investor you will make your own judgment. Then he

talk about the GTV. We know that's the mention based on his

part to talk about GTV investment. He mention about the GTV

how become today. There's a breakthrough because GTV has been

targeted, he mentioned target by CCP, hacking, a lot of hackers

trying to take down. The GTV was pulled us off, it's not easy.

But he mentioned that GTV future forecasts, this is a

platform that's intended for Chinese dissidents have a voice,

freedom of speech. We're the only one; no other platform.

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And he mentioned this, as we all see, GTV future

growths. From the current six people online at the same time,

but eventually will grow to thousands people doing the

broadcast together, the skill of it. And so I remember that

video also post contact information, his personal contact

information for the investment. If anyone want to invest, can

direct contact.

Q. When you say his personal contact information, to whom are

you referring?

A. Miles Guo.

Q. So in that video, Miles Guo provided his information for

people to contact regarding an investment?

A. Yes.

Q. What, if anything, did Miles Guo say in that video about

what you would get in exchange for investing in GTV?

A. Will get stocks, GTV stocks.

MS. MURRAY: Your Honor, at this time I would like to

offer a stipulation between the parties. This is Government

Exhibit STIP-9.

The stipulation reads that the parties stipulate and

agree that in the below chart which is contained in this

exhibit, the exhibits listed under column A contain audio or

text in a foreign language; and in the chart that's contained

within this stipulation, the exhibits listed under column B are

true and accurate translations of the audio or text contained

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in the exhibits listed under column A. The stipulation further

stipulates and agrees that the stipulation, as well as the

government exhibits listed under column B — those are the

translation and transcript stipulations — may be received into

evidence as government exhibits at trial.

THE COURT: The stipulation is admitted.

(Government's Exhibit STIP-9 received in evidence)

MS. MURRAY: And with respect to the particular items

contained within the chart, at this time the government would

move to admit GX C-26-V and its corresponding GX C-26-T, which

is the translation and transcription; as well as GX C-63-V, and

its corresponding GX C-63-T, which is the transcription and

translation.

THE COURT: No objection?

MR. KAMARAJU: No. I would just ask the government to

go ahead and just admit all the exhibits that are in the stip

for efficiency.

MS. MURRAY: Sure. We would then move to admit all of

the exhibits contained within the chart that's in Government

Exhibit STIP-9.

THE COURT: They are admitted.

MS. MURRAY: Thank you.

Ms. Loftus, can you please pull up Government Exhibit

GX C-26.

Just a moment, your Honor.

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(Counsel conferred)

MS. MURRAY: Your Honor, I would like to withdraw the

request to admit all of the items contained within this

stipulation. The parties' agreement was to admit certain of

the translations, but not the full videos listed in column A.

So I would like to withdraw the request to admit

everything that's noted within the chart. At this time I would

just move to admit the two particular exhibits that I had

mentioned.

THE COURT: All right, then. So those items that were

admitted are not admitted, and what you're requesting to admit

now is admitted.

MS. MURRAY: Thank you, your Honor.

So just for clarity for the record, what I'm seeking

to admit is Government Exhibit STIP-9, which is the

stipulation; Government Exhibit C-26-V and C-26-T, and

Government Exhibit C-63-V and C-63-T.

THE COURT: They are admitted.

MS. MURRAY: Thank you.

(Government's Exhibits C-26-V, C-26-T, C-63-V, C-63-T

received in evidence)

MS. MURRAY: All right. Ms. Loftus, if we could

please put up Government Exhibit C-26.

BY MS. MURRAY:

Q. Mr. Zhou, looking at this, do you recognize this video?

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A. Yes.

Q. And up in the top left there is a logo and insignia. Do

you recognize that?

A. Yes, I do.

Q. What is it?

A. GTV logos.

Q. Did you watch this video when it was posted online in April

2020?

A. No, it wasn't posted online when I watch it, so I share a

link.

Q. And who, if anyone, shared the link with you to the video?

A. One of the farm members.

Q. When you say the link was shared, how was it shared with

you?

A. I shared it on the telegram, our working -- the farm

working channels.

Q. So that's over phone application; is that correct?

A. Yes.

THE COURT: What do you mean by "telegram"?

THE WITNESS: Yes, your Honor.

Telegram is another social media software. It's more

like you can allow you instant message, you can do it as

individual one-on-one or you can also have a group chat. And

there you able -- also you can share your files, pictures,

links, videos, etc.

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MS. MURRAY: Ms. Loftus, can you please play this

video from the beginning up until 41 seconds.

(Video played)

MS. MURRAY: Thank you. We can take that down.

BY MS. MURRAY:

Q. Mr. Zhou, what, if anything, did Guo say during that video

that was broadcast about the amount of stock that one would

receive in exchange for their GTV investment?

A. I remember was the GTV stock in total was about to issue 20

million to 200 million stocks.

Q. And what, if anything, did he say about how much stock

somebody would get for the money that they invested personally?

A. One dollar per share.

Q. Did there come a time when you invested in GTV?

A. I'm sorry, would you -- could you please repeat the

question.

Q. Sure. Did there come a time when you invested in GTV?

A. Yes, I did.

Q. When was that?

A. I invested end of the May 2020.

Q. And how much did you invest?

A. I send two payments total for $31,300.

Q. Where did you send your money for that GTV investment?

A. I send it through VOG, Voice of Guo, the channel which

control by Sara Wei.

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Q. Why did you send your GTV investment to VOG or Voice of

Guo?

A. Because my investment is less than $100,000, and also Sara

was designated person also can take the GTV placement, private

placement.

Q. Can you explain for the jury how, if at all, it was

relevant that your investment was below $100,000?

A. Could you please be more specific.

Q. Sure. So I believe that you said because your investment

was below $100,000, you sent it to VOG; is that correct?

A. Yes.

Q. Who, if anyone, directed you to send your investment which

was below $100,000 to VOG?

A. Because the first GTV Miles Guo mentioned about the GTV

placement, they were giving out only 2,000 seats. There is a

head count, it's limitation on there. The limitation then the

people can -- minimum you can invest $100,000 up to all the way

to millions, million dollar. But it's limited seats. And if a

lot of people, especially not qualified for the seats or less

$100,000, but we can have this other company to invest on our

behalf to acquire the GTV stocks. So that was -- I was -- I

understand myself my investment is not qualified with the

seats. And it's not exceeds over $100,000, so I just went

through the VOG, ask for the investment.

Q. So at that time was it your understanding that VOG invested

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on your behalf and on behalf of others in GTV?

A. No, they are --

MR. KAMARAJU: Objection, your Honor, to form.

THE COURT: Sustained. Don't lead.

Q. Did you have an understanding at the time in whose name

your money was being invested?

A. GTV Media.

Q. And for purposes of the shares, whose names, if anyone's,

would be on the shares that you spent your money to invest in?

MR. KAMARAJU: Objection to form.

THE COURT: If you'd rephrase, please.

MS. MURRAY: Sure.

Q. Mr. Zhou, you mentioned that you invested your money

through VOG; is that correct?

A. Yes.

Q. What arrangement or legal agreement, if any, did you enter

into with VOG?

MR. KAMARAJU: Objection to form.

THE COURT: Did you enter into a legal agreement?

MS. MURRAY: Thank you.

Q. Did you enter into a legal agreement with VOG?

A. Yes.

Q. Can you describe that legal agreement to the jury, please.

A. It was agent agreement. Sara Wei would act as my agent to

take my investment for the GTV investment.

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MS. MURRAY: Ms. Loftus, can we please publish

Government Exhibit VO-81.

Q. Mr. Zhou, what is this?

A. This is wire instruction I received.

Q. And who, if anyone, sent this to you?

A. Sent by Sara Wei, the Voice of Guo channel leader.

Q. I think you mentioned previously that Sara Wei had some

role within the Himalaya Global Alliance. Can you just

describe that for the jury.

A. Yes. She was very active follower before. She reveal

herself and joined the movement as well. Then she had some

meeting with Miles Guo, even publicly, live broadcast together.

So at the time she was with another person that she

was very active and designated. And because she also gather

some followers and fall through the whistleblower movement.

She form a group; she was the whistleblower movement.

So at the time Miles Guo was also designate her as the

followers, the group leaders. And she can also have

authorization from Miles Guo to collect GTV investment for us.

MS. MURRAY: Ms. Loftus, can we please publish

Government Exhibit VO-82. Zoom in on the top.

Q. Mr. Zhou, what is this?

A. That's my wire confirmations.

Q. And looking at this, what was the date of this wire

transfer?

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A. May 28, 2020.

Q. And it was a wire sent to where?

A. It was sent to Voice of Guo Media.

Q. And what was the amount of this particular wire?

A. $20,000.

MS. MURRAY: We can take that down. Thank you.

Q. Why did you want to invest in GTV at that time in May of

2020?

A. Because first I want to get a GTV stock. And the GTV, I

was also the user. And this is a platform. GTV website also

is for the freedom of voice for other Chinese people

dissidents. And I was follower myself. I really a believer

for this movement. I want to just be part of it and also to

help grow this GTV. The GTV was just like any other tech

companies started.

There's also about Miles Guo mention we also will grow

this to become the world number one social media platform,

surpass YouTube. We have all the features, we'll combine Zoom,

combine YouTube, we'll have the best top technology implemented

into this GTV. So for that I want to be part of it. So I

invested.

Q. When Miles Guo said at the time in 2020 that GTV would

surpass YouTube, did you believe him then?

A. Yes. Eventually.

Q. Did you, in fact, receive stock or any shares in exchange

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for your GTV investment?

A. No.

Q. At that time in 2020, what, if anything, did Miles Guo say

about whether there was a risk of losing your principal

investment in GTV?

A. He made a personal guarantee that for other people invested

in GTV would not lose their money; he made personal guarantee

on that.

Q. Can you explain what you mean by "personal guarantee."

A. During his broadcast, he mentioned all the money we

invested, that principal would never lose, lost even a cent.

He will pay -- personally pay back.

Q. And at that time, in 2020, did you believe that Miles Guo

was capable of paying or guaranteeing your investment?

A. Yes.

Q. At that time, 2020, did you have an understanding from

Guo's broadcasts about the value of GTV stock?

A. Yes.

Q. What was your understanding?

A. There is another broadcast lively on Miles Guo broadcast

that I watch live on that day, where successfully closeout the

placement, GTV private placement was announcement. Miles Guo

mention have a receive -- GTV alone received $335 million; from

VOG received 117 million. And combine, that's near -- he said

near $500 million investment.

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And the valuation at the time of GTV, he gave out the

statement about the value was $2 billion. Then he added from

his legal team and from his financial experts the valuation

should be $10 billion. So just that moment he explained the

investment we did, from 7 point time -- jumped to estimate made

about 30 times.

Q. And at the time that you watched that broadcast in 2020,

did you believe Miles Guo regarding the valuation of GTV?

A. Yes, I did.

MS. MURRAY: Ms. Loftus, can we please pull up

Government Exhibit C-63-V, which is in evidence. If we could

just publish it to the jury, please.

Q. Mr. Zhou, do you recognize this video?

A. Yes.

Q. Is this a broadcast that you watched at the time that it

was posted on the internet in 2020?

A. Yes.

MS. MURRAY: Ms. Loftus, if we could go to the

12-minute-and-40-second mark, please, and start playing.

(Video played)

MS. MURRAY: We can pause for a moment please.

Your Honor, we've also admitted Government Exhibit

C-63-T, which is the translation and transcript of this video.

I'm going to play this portion and then I'm going to ask

Mr. Zhou to read portions of that transcript.

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Thank you, Ms. Loftus. We can continue.

(Video played)

MS. MURRAY: You can stop there. Thank you.

Ms. Loftus, if you could please now publish for the

jury what's in evidence as Government Exhibit C-63-T. And if

we could go down to the time stamp of 12:40, please. And zoom

in on the right.

Q. Mr. Zhou, this is a translation and transcription of the

video clip that we just watched. If you could just read in the

right column there the English for the jury.

A. Sure.

We had an initial valuation of 200 million for GTV,

and the private placement required a minimum investment of 20

million. The private placement exceeded the highest

expectations and raised 350 million. This is up to now, this,

this figure, ah, is about 360 million, let's say 350 million.

350 million does not include the 117 million from VOG. If 117

million plus 350 million, it's more than 400 million -- sorry,

480 million, which is almost, almost, almost, almost 500

million, almost 500 million.

But the figure we have now is the 350 million

received, which is just for the contracts with GTV. This turn

out to be a conservative estimate and 17.5 times the valuation.

Given the tremendous demand for GTV shares and the good capital

position of GTV going forward, my lawyers and financial experts

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mutually agree that a $2 billion valuation is probably too low,

and that the actual value of the company is probably closer to

10 billion given the tremendous demand for GTV shares.

MS. MURRAY: Thank you. We can take that down.

Q. Mr. Zhou, at the time that you watched this broadcast in

2020, did you believe Miles Guo that the value of GTV was

approximately $10 billion?

A. Yes.

Q. At the time that you invested in GTV in 2020, what, if

anything, did you understand that your investment would be used

for?

A. Yes. The money first will use to enhance the GTV's

features, purchasing top tiers companies and to expand GTV to

become -- to take over the YouTube, become world number one

social media.

Q. At that time in May of 2020, if you'd believed that Guo

would use GTV investment money for his own personal expenses,

would you have invested in GTV?

MR. KAMARAJU: Objection to form, your Honor.

THE COURT: If you'll step up, please.

(Continued on next page)

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(At sidebar)

THE COURT: I'll hear your objection.

MR. KAMARAJU: Your Honor, Ms. Murray continues to

just embed facts that are not in evidence, asking questions,

then asking the jury to infer -- asking the witness to agree

with them. That's, in essence, putting her own testimony in

front of the jury. If she wants to elicit those questions, she

can ask open-ended questions. That was our objection to the

form.

MS. MURRAY: Your Honor, I believe that the Court

ruled that hypotheticals could come in in questioning of

witnesses and, in particular, victim witnesses. And that is

what I'm posing to this witness.

THE COURT: I don't see how she gets at it without

asking hypothetical questions.

MR. KAMARAJU: She could still lay the foundation

prior to asking a hypothetical.

THE COURT: So I think that he's asking you to state

whether it's his understanding — the witness's understanding —

that -- or whether he knows whether Mr. Guo invested the money

that he claimed that he had invested.

MR. FERGENSON: Your Honor, you had ruled in pretrial

rulings that to prove materiality, we can ask the hypothetical

question such as, If you had known X, would you have invested?

And that's, you know, standard in fraud cases like this.

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THE COURT: Of course. Of course.

I don't think that it's improper though for her to ask

whether --

MR. FERGENSON: To establish he doesn't, in fact, know

how it was used -- I'm sorry.

THE COURT: The fact that she's assuming is that

Mr. Guo did not invest the $100 million. And so do you know

whether the witness knows whether Mr. Guo invested the $100

million?

MS. MURRAY: So this is with respect in particular to

the witness's GTV investment and other GTV investment money. I

don't believe the witness has any personal knowledge of how

that money was used, except to say that, sitting here today,

the witness has an understanding that it was not all used for

GTV's business and instead was used for personal expenses.

MR. KAMARAJU: Understanding based on the government's

allegations, your Honor, not on any evidence --

MS. MURRAY: And just to be clear, that's why I asked

the question in the manner that I did.

THE COURT: I don't know that it is detrimental for

her to ask it this way as opposed to asking whether he knows if

the money was used by Mr. Guo to invest.

MR. KAMARAJU: To me, your Honor, the problem is your

Honor definitely ruled that they can ask a hypothetical. So

the question is is what, if any, foundation they have to lay

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prior to asking a hypothetical.

THE COURT: Exactly.

MR. KAMARAJU: So to me, maybe it's just a form point

on this particular hypothetical. I suspect they are going to

ask many more, so that's why I think it's appropriate to raise

it now. To me, she can just establish the basic foundation for

it, and then she can say -- she can ask her hypothetical if she

wants.

THE COURT: Okay.

MS. MURRAY: I will do that. I did ask if he had an

understanding of how the money was used; but I can ask that

question again if that would be sufficient foundation.

MR. KAMARAJU: That's the distinction.

MS. SHROFF: The question is whether he had knowledge,

not what his understanding is. Because his understanding could

come from your prep of him during his preparation for his

testimony here. The question is what knowledge he had at that

time, not the knowledge he has now.

MR. FINKEL: At the time his understanding would

address all these concerns and be consistent with the Court's

ruling.

MS. SHROFF: Not understanding knowledge.

THE COURT: You can ask about knowledge and then ask

your hypothetical.

MS. MURRAY: Thank you, your Honor.

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MR. KAMARAJU: Thank you, your Honor.

(In open court)

THE COURT: You may continue.

MS. MURRAY: Thank you, your Honor.

BY MS. MURRAY:

Q. Mr. Zhou, in May of 2020, when you invested in GTV, did you

have any knowledge of how your investment was going to be used?

A. Yes.

Q. And what did you believe your investment would be used for,

again, in May of 2020.

A. Yes, at the time I believe my investment will use to

enhance the GTV, to bring this GTV platform to number one

leading social media platform.

Q. At that time, in May of 2020, if you had believed that

Miles Guo would use your GTV investment money for his personal

expenses, would you have invested in GTV?

MR. KAMARAJU: Objection, your Honor.

We just addressed this at side bar.

THE COURT: If you'll step up again.

(Continued on next page)

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(At sidebar)

THE COURT: Are you asking for -- stating that she

needs to ask whether Mr. Guo used the money? I mean, what is

the question that you're looking for?

MR. KAMARAJU: No, I thought -- my understanding when

we left the sidebar was that she was going to ask questions do

you know how the money was used. She has not asked it.

MS. MURRAY: I believe I did ask that.

MR. KAMARAJU: No, the question that I heard — if I

got it wrong, I apologize — was how did he believe he thought

the money was going to be used. She never asked the follow-up

question of do you know how the money was used in May of 2020.

THE COURT: So you're going to ask the "do you know"

question.

MS. MURRAY: Your Honor, what's relevant is his

understanding and his knowledge; that goes to the reason that

he invested. That's the materiality point. I don't think that

it's necessary to establish whether he, as an investor, knew

what was happening with the money that was being invested into

this company in order for him to say what his motivation was

for investing.

MR. KAMARAJU: If you don't ask, if you don't

establish that he doesn't know, then how do you ask a

hypothetical that says: If you had known, then how would that

change your opinion?

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THE COURT: Okay.

MR. KAMARAJU: Thank you, your Honor.

(In open court)

THE COURT: You may continue.

BY MS. MURRAY:

Q. Mr. Zhou, in May of 2020, after you invested $31,300 in

GTV, at that time did you have personal knowledge of how your

investment was used?

A. The money invested to GTV, my understanding was intended to

enhance the GTV, purchase top-tier company or software to make

it enhancement and to overcome -- become the world number one

platform, surpass YouTube.

Q. And what is that understanding that you had in May 2020,

what is that understanding based on?

A. Miles Guo mention his broadcast.

Q. Aside from what Miles Guo mentioned, do you have personal

knowledge? Do you know how your money was used or did you know

in May 2020 how your money was used?

A. That I don't know.

Q. If you had believed that Guo would use your GTV investment

money for his own personal expenses in May of 2020, would you

have invested in GTV at that time?

A. No.

Q. Have you heard the phrase "G Series"?

A. Yes.

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Q. What is G Series?

A. G Series is investments including GTV, G News, G Fashion, G

Mall, G Clubs, etc., which were all created by Miles Guo. And

this is one of a financial system for the whistleblower

movement as their ecosystem.

Q. Do you have an understanding of what, if anything, the "G"

in G Series stands for?

A. Yes.

Q. What's your understanding?

A. G is the English letter reference Miles Guo's last name

initial, first initial.

MS. MURRAY: Ms. Loftus, can we please pull up for the

witness only what's been marked for identification as

Government Exhibit VI-151.

Q. Mr. Zhou, do you recognize this?

A. Yes.

Q. At a high level, what is it?

A. Miles Guo's broadcast.

Q. Do you see the date on the top left?

A. Yes.

Q. Did you watch this particular broadcast at the time that it

was posted on the internet on or about that date?

A. Yes.

MS. MURRAY: Your Honor, the government would move to

admit Government Exhibit VI-151.

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MR. KAMARAJU: No objection.

THE COURT: It is admitted.

(Government's Exhibit VI-151 received in evidence)

MS. MURRAY: If we could play that, please,

Ms. Loftus. We can publish it to the jury first and then we'll

play it.

(Video played)

MS. MURRAY: We can stop there, please.

We can take it down.

Q. Mr. Zhou, there was a reference in the first video clip to

Sara's VOG. What does that refer to?

A. Sara Wei.

Q. And "VOG," what does that reference?

A. Voice of Guo.

Q. There was also a reference to a Guo Wengui. Did you see

and hear that?

A. Yes.

Q. Who is that?

A. Miles Guo.

Q. Generally speaking, what, if anything, did Miles Guo say

during those broadcasts we just viewed?

A. Personally guarantee that investors' money will not lose,

only gain. If any ten cents loss, he'll personally pay.

Q. And did you view those videos at the time that they were

posted in 2021?

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A. Yes.

Q. And at that time, when you viewed those videos, did you

believe Miles Guo that he would personally guarantee any

investments in the G Series?

A. Yes.

Q. I want to turn your attention now to June of 2020.

Did there come a time when Miles Guo announced the

launch of a new organization?

A. Yes.

Q. What was the name of that organization?

A. It's called New Federal State of China.

Q. Was that also referred to as the NFSC?

A. Yes.

Q. What was the New Federal State of China?

A. It's a supervisory organization for the whistleblower

movement.

Q. Can you describe how Miles Guo announced the launch of the

NFSC?

A. Yes. That was June 4th, 2020. He announced this

establishment of NFSC on his private yacht and was lively

broadcasted.

Q. Did you watch that broadcast when it was broadcast on June

4th, 2020?

A. Yes, I watched.

Q. How, if at all, is the NFSC -- or at the time was the NFSC

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associated with the G Series?

A. G Series were already launched before; then it was for the

other whistleblower movement. And NFSC was established because

NFSC is a supervisory organization on top of all the movement,

that's the name that will be used in the future to as a

legitimate government. So that's ultimately a name that -- for

this movement.

Q. What do you mean when you say that the NFSC is going to be

a government?

A. Because the movement is -- will take down the China

Communist Party. Once Chinese CCP falls, then this

organization will try to replace the CCP; give the people one

person, one vote.

Q. And how was it your understanding that the NFSC -- let me

put it in timing. In June of 2020, how was it your

understanding that the NFSC was going to take over for the

Chinese Communist Party?

A. At that time my understanding was just to expose the

Chinese corruptions. Miles Guo has three tactics. He

mentioned that by eliminate CCP using by law; by eliminate CCP,

using America power, American powers; by eliminate CCP by using

CCP itself, that's he mention it.

Q. So at that time, in June 2020, was your understanding that

the NFSC was going to be a government, was that based on

statements by Miles Guo?

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A. Correct.

MS. MURRAY: Ms. Loftus, can we please publish what's

in evidence as Government Exhibit CT-209.

Q. Mr. Zhou, looking at the item?

MS. MURRAY: If we could zoom in, Ms. Loftus, in the

middle of this.

Q. The figure that's depicted in those two posters or

pictures, do you recognize that shape?

A. Yes, I do.

Q. What is it?

A. That's the star from the NFSC flag.

Q. How many points does that star have?

A. Total, 49 stars.

Q. Can you explain for the jury how you get 49 points from

that star?

A. It's a seven times seven equal 49.

Q. And what is the significance, if any, of seven points on

that star?

A. Seven, we all use call Miles Guo seven brothers. There's a

lot of seven he's associated with. So he was also was part of

the flag creations, participated. And so I think that's -- I

believe that's a flag that represents seven is Miles, the

sevens.

MS. MURRAY: We can take that down, Ms. Loftus.

Q. Mr. Zhou, did there come a time after the GTV private

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placement closed in June 2020, when Miles Guo announced a

farm-related investment opportunity?

A. Yes.

Q. What was that opportunity?

A. That's called a farm loan.

Q. Can you describe for the jury what the nature of the farm

loan investment opportunity was.

A. Farm loan was to have investors lend money to the -- call

it farms, which is the NFSC offices in different divisions

throughout the world. Then there was a term lend the money to

the farm to use to operate for hirings, expand, and recruit.

Q. And based on the farm loan opportunity, what, if anything,

would a lender get in exchange for the loan?

A. There is a term for three-year term. And there is also

interest rate for annual interest rate placed on that.

Q. And at the end of that three-year term, what options, if

any, did lenders have to either get their principal and their

interest rate or something else?

A. You have choice to get your money, interest plus your

principal, plus interest back, and also you can get stocks.

Q. What type stocks?

A. GTV stocks.

Q. How was it your understanding at that time, in June 2020,

that the farm loan investment opportunity offered either return

on your money or stock?

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A. I'm sorry, could you just repeat it one more time.

Q. Yeah. In June of 2020 or thereabouts, how was it your

understanding that by giving a loan to the farm, three years

later you could either receive your money back with interest or

you could receive stock?

A. We have agreements.

Q. What type of agreements?

A. Loan agreements signed with the farms.

Q. And who, if anyone, announced the farm loan program?

A. Miles Guo announced.

Q. At that time, in 2020, were you a member of any farm?

A. Yes, I am.

Q. Which farm were you a member of at that time?

A. The first farm on social is called UK London Club.

Q. Did you participate in the farm loan program?

A. Yes, I did.

Q. With which farm did you participate in the farm loan

program?

A. UK London Club.

MS. MURRAY: Ms. Loftus, can you publish Government

Exhibit VO-22, which is in evidence.

Q. Mr. Zhou, do you recognize this?

A. Yes.

Q. What is this?

A. This a farm loan agreement.

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Q. What is the name of the borrower listed on this agreement?

A. It's U.S. Himalaya Capital Inc.

Q. What farm, if any, is U.S. Himalaya Capital, Inc.

associated with?

A. This is a farm -- UK London Club farm.

Q. And the lender listed there, whose name is that?

A. That's my name.

Q. What date did you enter into this loan agreement, the UK

farm?

A. August 24, 2020.

Q. And under the terms of this loan agreement, what was the

stated use of the loan that you provided to the UK London Club?

A. It's for the general working capital purpose for the farm.

Q. How much did you invest in the farm loan program?

A. $21,000.

MS. MURRAY: We could take this down, Ms. Loftus.

Q. Mr. Zhou, at the time that you signed the loan agreement in

August of 2020, what was your understanding of how your money

would be used?

A. For the farm to establish offices, hiring staffs, and other

corporated operation expenses.

Q. And at that time in August 2020, what was your

understanding of what you would get, if anything, in exchange

for your loan to the UK farm?

A. It was eight percent for three years' term.

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Q. At that time, in August 2020, why did you participate in

the farm loan program?

A. Because I want to help the farm and I want to get the

stocks.

Q. And what type of stock did you expect you would get in

exchange for your loan to the UK farm?

A. The GTV common stocks.

Q. Why did you believe that you would get GTV stock in

exchange for making a loan to the farm?

A. Because that was part of what Miles Guo introduced this

project, as investment opportunities.

Q. Did there come a time when Miles Guo announced another

investment opportunity that was called G Clubs?

A. Yes.

Q. When was that?

A. It was same year, 2020 introduced.

Q. At that time, in 2020, what did you understand G Clubs to

be?

A. G Club is -- is to -- as other exclusive club for high net

worth people, individual to have, to show your status. But as

we are already investing to GTV, our wealth in the future will

be tremendous big. So this club is created to also to serve

additional as a financed project will have another features to

give to those members. So that's a club was created.

THE COURT: What do you mean by "exclusive club"?

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THE WITNESS: Yes, your Honor.

Exclusive -- this Miles Guo mention about other

society has those club, like Royal Family. This particular

club, for example, Masons, there's other clubs. So he want

create some similar clubs for particular individuals, which is

this is among the NFSC members.

BY MS. MURRAY:

Q. At that time, in 2020, did you understand that G Club had

any physical locations, any actual club location?

A. No.

Q. At that time, in 2020, what, to your understanding, would

you get in exchange for investing in G Clubs?

MR. KAMARAJU: Objection to form, your Honor.

THE COURT: Rephrase, please.

MS. MURRAY: Yes, your Honor.

Q. In 2020, what did you understand the G Club investment

opportunity to be?

MR. KAMARAJU: Your Honor, I'm going to continue to

object. I can explain at sidebar.

MS. MURRAY: If I may have a moment, your Honor.

(Counsel conferred)

MS. MURRAY: May I try again, your Honor?

THE COURT: Go ahead.

MS. MURRAY: Thank you.

Q. Mr. Zhou, in 2020, what did you understand that paying

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money to G Clubs would give you?

A. Yes.

There was offer the members we'll give stocks, the G

Club stocks.

Second, we'll get passports.

Third, we'll get another investments called exchange

of coins.

Fourth, we'll get discount rated deals from travel

agencies or even shoppings, like luxury air jets, Bombardier.

And the last one was for discount shopping on G

Fashion.

Q. Taking those in turn, starting with the last, what was G

Fashion?

A. G Fashion is part of the G Series. It's clothing for

fashion where you can shop luxury clothes.

Q. Where were G Fashion items sold, if anywhere?

A. Was sold in the states, United States.

Q. You mentioned that you had an understanding at that time in

2020 that you could get other benefits in exchange for paying

money to G Clubs; is that right?

A. Yes.

Q. What was that understanding based on at that time?

A. That was introduced by Miles Guo.

Q. What was the cost of a G Clubs membership in 2020?

A. G Club membership has five tiers. The first tier is

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$10,000, with each 10,000 increasement to top five tiers.

Q. So for the top tier, what was the cost of a top-tier

membership at that time?

A. That would be $50,000.

Q. Did there come a time when you purchased any G Clubs

memberships?

A. Yes, I did.

Q. When was that?

A. That in September 2021.

Q. And how many memberships did you purchase?

A. I purchase two, Tier 2 and Tier 5.

Q. What was the cost of the Tier 2 membership?

A. That's $20,000.

Q. And what was the cost of the Tier 5 membership?

A. $50,000.

MS. MURRAY: Ms. Loftus, can we please publish what's

in evidence as Government Exhibit VO-25. Zoom in on the top

portion. Actually, the body of this.

Q. Mr. Zhou, what is this?

A. That's my G Club membership notification after the

application was approved.

Q. And looking at the initial line, it's addressed to someone,

can you read what that reads?

A. I'm sorry, could you please --

Q. Sure. Starting with the word "my" at the beginning of this

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notification, what does that line say?

A. "My dear fellow fighters."

Q. And then looking down at the bottom of this, who signed --

or who is this notification from, according to body of this

email?

A. The name signed, Guo Wengui. That's Miles Guo.

Q. And how is he described here?

A. G Clubs' official spokesperson.

Q. How did you pay for your G Clubs memberships?

A. I paid by checks.

MS. MURRAY: Ms. Loftus, can we please take this down

and publish Government Exhibit VO-26, which is in evidence.

Q. Mr. Zhou, do you recognize these?

A. Yes.

Q. Are these the checks that you sent to become a G Clubs

member?

A. Yes.

Q. What is the date of each of these checks?

A. The first check, August 24, 2021.

Q. And the second?

A. August 25th, 2021.

Q. And looking at the memo line, there is some text in the

memo line of each of these checks. What, if anything, does

that text indicate?

A. That's indicate my application numbers.

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THE COURT: Sir, other than the payment of money, was

there any other requirement or criteria in order to join the

club?

THE WITNESS: Yes, your Honor. To join the club, you

have to be a follow members, which is the I have receive

members. And to purchase at a beginning, it wasn't required

for the only members, and it has previously investing the GTVs,

and also donated to Rule of Law Foundation.

BY MS. MURRAY:

Q. So in submitting an application for a G Clubs membership,

what information, if any, were you required to provide about

prior donations to Rule of Law or prior investment in GTV?

A. We have to include input our assigned the investment IDs

and which farm we were associated with into applications.

MS. MURRAY: And if we could go back, Ms. Loftus, to

Government Exhibit VO-25. If we could zoom in on the first

paragraph, please, that starts with "Congratulations."

Q. Mr. Zhou, can you just read the text here starting with

"Congratulations."

A. Yes.

"Congratulations. I am pleased to announce that your

Tier 5 membership to G Clubs has been approved. As a spokesman

for G Clubs, I extend a warm welcome to your membership to the

future."

MS. MURRAY: We can take that down.

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Q. Mr. Zhou, did you receive any stock shares in exchange for

your G Clubs membership payment?

A. No.

Q. You mentioned that there were discounts that you could use

as a G Clubs member. Where could you use those discounts?

A. Mean I use on GFashion.com.

Q. Did you purchase any items from GFashion.com?

A. Yes.

Q. Did you purchase some of those items before you became a G

Clubs member?

A. Yes.

Q. Did you purchase some items after you became a G Clubs

member?

A. Yes.

Q. Can you describe the quality of the items that you

purchased from G Fashion?

A. The quality itself is very ordinary, normal, compared to

what we -- I think the clothes we normally get.

Q. I'd like to look at a few of the items that you purchased

from G Fashion.

MS. MURRAY: Your Honor, may I approach?

THE COURT: Yes.

MS. MURRAY: Your Honor, I'm handing the witness

what's been marked for identification as Government Exhibits

32, 33, 34, and 35.

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Q. Mr. Zhou, do you recognize Government Exhibits 32, 33, 34,

and 35?

A. Yes.

Q. What are they?

A. Those are my purchase item from GFashion.com.

Q. Are those just some of the items that you purchased from G

Fashion?

A. Yes.

MS. MURRAY: Your Honor, the government would move to

admit Government Exhibits 32, 33, 34, and 35.

MR. KAMARAJU: No objection.

THE COURT: They are admitted.

(Government's Exhibits 32, 33, 34, 35 received in

evidence)

Q. If you could start with Government Exhibit 32, please,

Mr. Zhou, and hold that up for the jury.

Q. What is Government Exhibit 32?

A. That's a baseball cap.

Q. And where did you purchase that?

A. GFashion.com.

Q. What was the approximate cost of that baseball cap?

A. This I remember cost close to $200.

Q. If you could please hold up Government Exhibit 34.

What is that item?

A. Just a regular shirt.

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Q. And is that one of the items that you purchased from G

Fashion?

A. Yes.

Q. What was the approximate cost of that T-shirt?

A. This one was about $150.

Q. And now if you can please pull up or hold up Government

Exhibit 33.

A. Yes.

Q. What is Government Exhibit 33?

A. This is silk pants, ladies' wear.

Q. What was the approximate price of those pants on G Fashion?

A. It was listed about $800.

MS. MURRAY: Your Honor, if we could show the witness

what's been marked for identification as Government Exhibit

W-58.

THE COURT: All right.

MS. MURRAY: While we're waiting, your Honor, may I

publish Government Exhibits 32, 33, and 34 to the jury?

THE COURT: You may.

MS. MURRAY: Thank you.

Q. Mr. Zhou, do you recognize Government Exhibit W-58?

A. Yes.

MS. MURRAY: If we could scroll down a bit,

Ms. Loftus.

Q. Have you visited the website that's depicted in Government

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Exhibit 58 before?

A. Yes, I did.

MS. MURRAY: We would move to admit Government Exhibit

W-58.

MR. KAMARAJU: No objection.

THE COURT: It is admitted.

(Government's Exhibit W-58 received in evidence)

MS. MURRAY: If we'd please publish that, Ms. Loftus.

We could start up at the top.

Q. Mr. Zhou, what website is shown in Government Exhibit 58?

A. This is a G Fashion website.

MS. MURRAY: Ms. Loftus, if we could scroll down a

bit, please.

Q. Looking at the right there, do you see "G Fashion silk

pant"?

A. Yes.

Q. What is the listed price of that item?

A. $880.

Q. And is that the same item that is in Government Exhibit 33?

A. Correct.

MS. MURRAY: We can take that down, Ms. Loftus.

Q. One more physical exhibit that you have, Mr. Zhou,

Government Exhibit 35. If you could take that out.

What is Government Exhibit 35?

A. Yes. This is a gold limited edition whistles.

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Q. How was that item advertised on the G Fashion website?

A. Advertise as only was 77 made and it's 24K.

Q. What was the cost of that whistle?

A. I paid about $3200 for it.

MS. MURRAY: Ms. Loftus, if we could please publish

what's in evidence as Government Exhibit VO-67.

Q. Mr. Zhou, what is Government Exhibit VO-67?

A. That's paid receipt confirmation email.

Q. And that's for the whistle that is Government Exhibit 35?

A. Correct.

Q. What material did you say that the whistle was advertised

as?

A. 24K gold.

Q. Do you have an understanding or an impression of whether

that whistle was, in fact, gold?

MR. KAMARAJU: Objection, your Honor.

THE COURT: Sustained.

Q. Mr. Zhou, have you weighed that whistle?

A. I did.

Q. How much did it weigh approximately?

MR. KAMARAJU: Objection, your Honor.

THE COURT: Overruled. You may answer.

A. 0.7 ounce.

MS. MURRAY: Your Honor, permission to publish

Government Exhibit 35 to the jury.

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THE COURT: You may.

Q. Mr. Zhou, why, if at all, did you weigh the whistle after

you purchased it?

A. I was just curious about if -- if real or not.

Q. What do you mean if it was real or not?

MR. KAMARAJU: Objection.

THE COURT: Overruled. You may answer.

A. When I first received, the packaging, when I first opened,

was -- I saw little bit dust go on it. The gold itself was --

the craftsmanship was little bit rough. My knowledge, this is

a limited edition as collectible items, that made me little bit

concern.

Q. Mr. Zhou, returning to --

MS. MURRAY: Ms. Loftus, we can take that down.

Thank you.

Q. Returning to what you expected or understood that you would

receive in exchange for paying money to G Clubs, I think you

mentioned a currency; is that correct?

A. Yes.

Q. What was that? Can you explain that to the jury?

A. It is currency introduced called G dollar and the G coins.

It was digital currency and also digital cryptocurrencies that

also will be launched from exchange.

Q. And when you say "exchange," what are you referring to?

A. At the time we have a change is called Himalaya Exchange.

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Q. At that time in 2021, when you invested in -- or, excuse

me, when you paid for a G Clubs memberships, what was your

understanding of what the Himalaya Exchange was?

A. Himalaya Exchange was another part of G Series for

financial freedom created by Miles Guo. And it gave people

much better opportunity to transfer monies instantly. Also no

boundaries. And also for the most securities you will get.

Q. And at that time, in 2021, what was your understanding

about the Himalaya Exchange based on?

A. The G dollar was equal to one U.S. dollar values, and will

have gold standards for the H coins. The full name, it's

Himalaya coins, it's backed by 20 percent gold. So that adds

all the value to it.

Q. Why, if at all, did you believe in the time, in 2021, that

the Himalaya currencies were backed 20 percent by gold?

A. Miles Guo personally announced that.

Q. To your knowledge, at that time, in 2021, who was in charge

of the Himalaya Exchange?

A. The person, I don't know.

Q. At that time, in 2021, who, if anyone, promoted the

Himalaya Exchange?

A. Miles Guo promoted Himalaya Exchange.

Q. Did there come a time when you purchased any of the digital

currencies that were available on the Himalaya Exchange?

A. No.

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Q. Why not?

A. Because there's a policy, it's not a -- it's restricted to

sell to the residents in the states.

Q. And how was it your understanding at that time, in 2021,

that it was restricted?

A. Also Miles Guo mention that.

Q. Did there come a time when you sent money to purchase

Himalaya coin or Himalaya dollars?

A. I didn't send money to get Himalaya dollars, but I was

given opportunity to purchase H coins.

Q. And what was that opportunity?

A. That opportunity is based on my previous G Series

investments and donations for the previous investment. Also,

I'm a follower of this movement; the opportunity was given to

me.

Q. Who, if anyone, gave you the opportunity to purchase H

coins?

A. Miles Guo gave us the opportunity.

MS. MURRAY: Ms. Loftus, if we could please pull up

for the witness what's marked for identification as Government

Exhibits VO-107 and VO-108.

Q. Mr. Zhou, do you recognize these?

A. Yes.

Q. Generally speaking, what are they?

A. On the right side --

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Q. Sorry. Just a moment, sir. If you could, just at a

general level, what type of document or item is this?

A. That's my personal investment summary.

Q. And are these -- are these contents that were taken from

your phone?

A. From my computers.

Q. Did you provide these to the government?

A. Yes, I did.

MS. MURRAY: Your Honor, the government moves to admit

Government Exhibits VO-107 and VO-108.

MR. KAMARAJU: No objection to their admission, your

Honor.

THE COURT: They are admitted.

(Government's Exhibits VO-107, VO-108 received in

evidence)

THE COURT: It's now 11:30, members of the jury, so

we're going to take our half-hour break.

Remember that I need for you to be ready to walk

through that door at noon. Remember also that you're not

allowed to discuss this case amongst yourselves or with anyone

else. Don't permit anyone to discuss the case in your

presence.

Sir, you are not to discuss your testimony.

(Jury not present)

THE COURT: You may be seated.

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Counsel, anything before we come back for our break?

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

MS. MURRAY: Not from the government, your Honor.

THE COURT: All right, then. You may step down.

THE WITNESS: Thank you, your Honor.

(Luncheon recess)

(Continued on next page)

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AFTERNOON SESSION

12:00 p.m.

THE COURT: Please be seated.

Please have the jurors brought in. And please have

the witness resume the stand.

MS. MURRAY: Yes, your Honor.

(Jury present)

THE COURT: Please be seated.

Remember, sir, that you are still under oath.

THE WITNESS: Yes, your Honor.

THE COURT: You may proceed with the direct

examination.

MS. MURRAY: Thank you, your Honor.

Mr. Gartland, if you could please publish for the

jury, alongside one another, Government Exhibits V0107 and

V0108.

BY MS. MURRAY:

Q. Mr. Zhou, before we took a break, I believe we were talking

about the Himalaya Exchange. We're going to pull up Government

Exhibits V0107 and V0108.

MS. MURRAY: Mr. Gartland, if you could just unpublish

while you're pulling those up. Thank you.

Q. I guess, Mr. Zhou, while we're waiting, you had mentioned

that there were certain restrictions on purchasing Himalaya

Coin. Can you explain those to the jury, please, your

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understanding in 2021 on what those restrictions were.

A. Yes. To allow to purchase H Coin, you have to have——first

you got to be a member of the farms, which you have to join the

movement. Then based on that, it's all based on your previous

investment, including donations. So once all that been

counted, then you were able to get a prelaunch of the coins and

at a discounted rate.

Q. What do you mean by prelaunch?

A. Because this coin was launched on November 1, 2021, all the

investments was previously invested was counted towards to how

much coin you could get.

Q. And who, if anyone, calculated the amount of investment

that you had prelaunch of the Himalaya Coins?

A. The rule of guidance was set by Himalaya Alliance. For

previous GTV there was deadline also, made that draw line. For

September 31st [sic], anything donate investment, you place it

before, you will get a dollar investment for 0.5 coins. Any

investments after that deadline, it's counted as 1 dollar

investment for 0.2 coins.

Q. And who, if anyone, set those deadlines?

A. The deadline was announced by Miles Guo.

Q. Where was that announced?

A. During his broadcast.

Q. At the time of the Himalaya Coin launch in November of

2021, were you a member of any farms?

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A. Yes.

Q. Which farms?

A. UK London Club.

Q. Did you communicate with anybody from the UK London Club

regarding the Himalaya Coin?

A. Yes.

Q. With whom did you communicate about Himalaya Coin?

A. I contacted the farm leaders.

Q. Who was the farm leader of the UK farm at that time?

A. His name is David Dai.

Q. How do you spell that last name?

A. D-A-I.

Q. Can you describe what communications or conversations you

had with David Dai at that time about Himalaya Coin?

A. There were one for the resident in the States and other

prohibited country couldn't purchase the Himalaya Coin

directly. That Global Alliance, Himalaya Alliance, established

a business as nominee shareholdings to held those people's

coins. Besides that, the farm also established business act as

a nominee shareholdings to held those people's coins, which was

I was included.

Q. What business are you referring to that the farm

established——or the Alliance? Excuse me.

A. From the Alliance, the company created called Freedom Media

Venture Ltd.

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Q. And can you explain for the jury what you mean when you

describe Freedom Media Venture as a nominee.

A. Nominees act as——on your behalf to hold your——your coins,

for example.

Q. And at that time, in the fall of 2021, how was it your

understanding that Freedom Media Venture was a nominee?

A. It was public announced by Miles Guo.

Q. And what role, if any, did Freedom Media Venture have with

respect to money that you paid for Himalaya Coins?

A. The Freedom Media Venture, that company was a new company

created for the GTV, so was announced that for those people who

are in the restricted countries, then they will able to sign a

contract and also offer——there was also fee will be charged was

announced to us. He explained it to us.

Q. Who explained that to you?

A. Miles Guo mentioned it and also the other farm leader

mentioned it.

Q. What was the nature of the fee?

A. The fee I got was a 5 percent.

THE COURT: What do you mean by restricted country?

THE WITNESS: Yes, your Honor. The Himalaya Exchange

has a policy, and the policy laid out, there were countries not

on their list, a permitted list to purchase or do any business

or even become a user. The country were United States, Canada,

Japan, North Korea, and other essential countries.

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THE COURT: You may continue.

MS. MURRAY: Thank you, your Honor.

BY MS. MURRAY:

Q. Mr. Zhou, for those restricted countries that you just

mentioned, did you have an understanding of whether people who

were located in those countries could invest in Himalaya Coin?

A. Yes.

Q. What was that understanding at that time, in 2021?

A. So that this create a nominee shareholding companies that

were able to have them as our shareholders, to——to obtain the

coins.

Q. And did you in fact send money to purchase Himalaya Coins

through that nominee shareholder?

A. I didn't send the money direct to the shareholder. I send

money to the farm.

Q. Which farm?

A. UK London Club.

Q. Did you enter into any kind——was there any understanding

between you and the UK London Farm of what the purpose of the

money that you sent was for?

A. Yes.

Q. What was that understanding?

A. There were agreement, I signed it, with the farm leader,

David Dai. He created a company act as the nominee

shareholding company.

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Q. And generally speaking, what were the terms of that

agreement that you entered into with the UK Farm leader?

A. The term were just, they will hold my coins and also I have

to pay the fee, annual fee to it. But in the future, once the

Himalaya Exchange acquired legal license, was able to expand

the territory, which the restriction related to those

countries, especially to the United States, then I would be

able to use my own user name accounts that would transfer the

coins back to me.

Q. And how was it your understanding at that time in 2021 that

that's how the nominee shareholder kind of investment would

work?

A. I'm sorry. Just one more time repeat the question.

Q. Yeah, of course. So in 2021, how was it your understanding

that at some point in the future you would be able to register

your own account on the Himalaya Exchange?

A. Yes, mentioned by Miles Guo, yes.

Q. So at the time that you sent money to the UK Farm for the

purchase of Himalaya Coins, what assets, if any, did you have

to the Himalaya Exchange?

A. I don't.

Q. At that time in 2021, how, if at all, were you able to

check the number of Himalaya Coins that you held, that you had

paid for?

A. Because the farm has my investment summaries and the

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summary document, all the investment I have previously

invested; and also, there were ratios for the coins was

calculated. It was——the information was provided to me.

Q. Provided to you by whom?

A. By one of the members, from UK London Club.

Q. After you purchased Himalaya Coin in 2021 through the UK

Farm, how, if at all, were you able to use that digital

currency to purchase things?

A. I——'cause I don't have access, so I don't know how you

spend that.

Q. Between your investment in 2021 and today, the present,

have you had access to the Himalaya Exchange?

A. No.

MR. KAMARAJU: Objection to form.

THE COURT: Overruled.

Q. Between your investment in 2021 and today, did there come a

time when you were able to spend your Himalaya Coin to purchase

anything?

A. No.

Q. I want to turn back for a moment, Mr. Zhou, to the

volunteer work that you did for the whistleblower movement.

Can you just remind the jury generally what types of services

you provided.

A. Yes. I did video transcript, also translations, videos

editing, and also streaming services, for the Himalaya

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Alliance, and the farm members.

Q. In connection with your volunteer work, did there come

times when you participated in meetings with other volunteers?

A. Yes.

Q. What types of meetings?

A. Those are private meeting with Miles Guo, with the farm

members.

Q. What was the nature of the meeting? Where did you all

meet?

A. We used the social platform called Webex.

Q. And what, if anything, was discussed during meetings among

the volunteers over Webex?

A. These meeting include briefing of the farm movements,

activities, also the followers' investments, and also some

other issues, among just farm and the Global Alliance, and

also, there were——at the time, the Global Alliance, one wanted

to create a central data center to centralize all the

investors' investment informations, and those meeting was

conducted, and also Global Alliance asked each farm, come to

the farm meetings. Give them guidelines, have them to turn

over all their bookkeepings, and also the balance to the

designated accounts by the Himalaya Global Alliance.

Q. Mr. Zhou, in the course of your volunteer work, you said

you were involved with streaming broadcasts. Did that include

broadcasts relating to activities by the NFSC?

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A. Yes.

Q. Did that include broadcasts relating to protests?

A. Yes.

Q. What types of protests did you stream broadcasts of, in

your volunteer work?

A. In late 2022, there were protests, a name called 90 Days

Protest was protesting one of Miles Guo attorneys, and their

attorney firms.

Q. What, generally, was the subject matter of the 90 Days

Protest?

A. There was involved with Miles Guo's bankruptcy cases, and

so the protest was because Miles Guo announced he was being

extorted by one of the attorneys for the amount of

$250 million.

Q. Taking a step back for a moment, did there come a time when

you learned that Miles Guo had filed for bankruptcy?

A. Yes.

Q. Around when did you learn that?

A. Miles Guo personally did on his broadcast, on February 15,

2022.

Q. What, if anything, did Miles Guo say during his broadcast

about having filed for bankruptcy?

A. He just mentioned, I'm signing today my bankruptcy, and

because I'm being persecuted.

Q. By whom, if anyone, did Miles Guo claim that he was being

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persecuted?

A. He mentioned the persecution from CCP and also he mentioned

some of the CCP penetrated US justice.

Q. At the time that Miles Guo said that in February of 2022,

did you believe that he was filing bankruptcy in part because

he was being persecuted by the CCP?

A. At that time I believed it.

Q. Returning to the 90 Days Protest, around when did the 90

Days Protests begin?

A. The 90 days started towards to end of October 2022, and

last——

Q. Sorry. Go ahead.

A. And last until end of January.

Q. And why, if at all, were NFSC members protesting during

that time period?

A. Because Miles Guo announced that extortion from the

bankruptcy cases, and the——so there were protests started at

multiple locations.

Q. Can you explain what you mean when you say that Miles Guo

announced extortion.

A. During his broadcast he mentioned he was being extorted by

this attorney, and also he mentioned the amount, $250 million.

Q. And which attorney?

A. The attorney name is Luc Despins.

Q. Based on Miles Guo's broadcast, what was your understanding

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of Luc Despins' role, if any, in the bankruptcy?

A. He was court-appointed trustee for Miles Guo.

Q. And at that time in 2022 what, if anything, did Miles Guo

say about the $250 million that you mentioned?

A. He said, that's unbelievable, outrageous; he was mad about

that.

THE COURT: When you say court-appointed trustee, what

court are you referring to?

THE WITNESS: Yes, your Honor. I believe that's New

York Southern District bankruptcy court.

Q. Mr. Zhou, against whom were the protests directed, the 90

Days Protests in 2022?

A. There were protests at the attorney Luc, attorney's home,

his daughters' universities, his ex-wife's home, his law firm

office, and one of his associates attorneys' home, and one of

Luc second daughter's workplace.

Q. Who, if anyone, directed the protests?

A. Right after Miles mentioned about this extortion, then the

Himalaya Global Alliance initiate, launch all the protests.

Q. Can you describe how the Himalaya Global Alliance launched

the protests.

A. It was organized so the recording of sending out the form

to the farms, asking who willing to come to the protests, and

we also received information that this protest will last 90

days, so the farm leader started gathering the information,

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putting people in place, and was also printing materials for

the protests.

Q. Which farm leader are you referring to?

A. At the time I'm associated with the new farm, it's called

the Washington, DC Farm.

Q. And what types of materials did the farm leader print in

connection with the 90 Days Protests?

A. There were posters, banners, and flyers.

Q. Can you describe for the jury some of the posters that were

created for the protests.

A. Yes. Some poster have the attorney's Luc's image, his

photos on it, but was altered, was also added with titles,

especially some offensive, some kind of meaningful——very mean

labels on that posters.

Q. What are some examples of the language that was added to

those posters that were used in connection with the protests?

A. Mostly they called him CCP running dog, evil.

Q. At the time of the 90 Days Protests in 2022, did you

believe that Luc Despins was——and I'm quoting the language——a

CCP running dog?

A. At that time I believed it.

Q. Why did you believe it?

A. Because Miles Guo mentioned the extortion and Miles Guo

mentioned Luc Despins' firms was bribed by the CCP.

Q. At the time in 2022, did you have any personal knowledge of

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whether Luc Despins had extorted or attempted to extort Miles

Guo?

A. No.

Q. At the time in 2022 did you have any personal knowledge of

whether Luc Despins' firm had been influenced by the CCP?

A. No.

Q. Sitting here today, do you believe that Luc Despins was

operating on behalf of the CCP?

MR. KAMARAJU: Objection, your Honor.

THE COURT: If you'll step up, please.

(Continued on next page)

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(At the sidebar)

THE COURT: Why would his belief today be relevant?

MS. MURRAY: Your Honor, because it goes to the fact

that at the time he was operating on——his intent to behave and

participate in the protest was what he was told by Mr. Guo.

THE COURT: So you've established that.

MS. MURRAY: Yes.

THE COURT: But then you've asked what he believes

now, and I'm trying to understand why that would be relevant.

MS. MURRAY: I think it goes, your Honor, to the——what

I'm going to be getting to at the end, which is when he came to

the realization that this was all fraudulent. He was a

believer in Miles Guo up until basically after the arrest, and

then at some point he came to realize that what Miles Guo was

telling him about the CCP's influence, about, you know, the

closing bank accounts because of the CCP, about all these

activities was not in fact true, and that was the moment when

he kind of came to the realization, and I expect that

Mr. Kamaraju is going to be cross-examining him on what his

belief was at the time and what, you know——why he is now

testifying for the government. And I'm just trying to

establish that.

MR. KAMARAJU: Well, I don't think his belief sitting

here today on the stand as to whether Mr. Despins is an agent

of the CCP has any relevance to the line of inquiry that

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Ms. Murray is talking about. If she wants to ask him questions

like, you know, when did you become suspicious, that's still at

a point back in time, has nothing to do with what he's saying

now, what he's getting at now.

THE COURT: So stick to that sort of question.

MS. MURRAY: Okay.

MR. KAMARAJU: Thank you, your Honor.

(Continued on next page)

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(In open court)

THE COURT: You may continue.

MS. MURRAY: Thank you, your Honor.

BY MS. MURRAY:

Q. Mr. Zhou, what, if anything, was your role with respect to

the 90 Days Protest?

A. My role was streaming technician. I used software to push

out the broadcast. I connect the farm and the guests. Also, I

make schedule for the technician parts, who do that daily

streamings.

Q. And who, if anyone, gave you instructions regarding how to

stream the 90 Days Protests?

A. There were guidelines provided by the Himalaya Global

Alliance, some guidelines specific, during the protests, if we

hear any the guests, or the farm guests, that mention Miles Guo

or if they say something that was organized, we'll cut the

streaming.

Q. Can you just explain that guideline a little bit more so

that the jury understands. What was the instruction that was

given regarding streaming if someone mentioned Miles Guo?

A. Yes. Because all the streaming was conduct lively, there

were people at the protest locations linked to remote guests.

As technician on the back end, so we would receive these

instructions: If either one inside the streaming, the image,

or guests spoke that, I'm here protest today, it's because

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Miles told me, or the organization told me come, if that words

said, we'll automatic cut the streamings.

Q. And did there come a time when you were streaming the 90

Days Protests that you had to cut the transmission because of a

reference to Miles Guo?

A. I personally did once.

Q. I'd like to return for a moment to the Himalaya Coin

investment.

MS. MURRAY: Ms. Loftus, if you could please publish

what's in evidence as Government Exhibit V0107 and V0108.

All right. Actually, we'll move along for a moment.

Ms. Loftus, if you could please publish Government

Exhibit V0105.

A. Sorry. My——oh, got it.

Q. Mr. Zhou, do you recognize Government Exhibit V0105?

A. Yes.

Q. What is it?

A. This is a meeting attended on Webex with Miles Guo and the

UK London Club members.

Q. Starting at the top left, who is that in the screen that's

shown on the top left?

A. That's me.

Q. And just to the right of you, who is that?

A. Miles Guo.

Q. In the image next to Miles Guo, on the other side of you,

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it appears that there's a poster. Can you read what that

poster says.

A. Yes, thank you. Speaking Himalaya London Club UK. Host.

Q. Sorry. Just to the left of that, there's a screen with

just a white wall and a poster. What does that poster say?

A. Oh, on the——I'm sorry. Okay. Got it.

New Federal State of China.

Q. And now going one further to the right, which you just

read, what is it indicating about the person who's depicted in

that screen?

A. That's UK London Club leader David Dai, and he hosts the

Webex software. The meeting was launched by his account.

Q. And do you recognize the flag behind David Dai?

A. Yes.

Q. What is it?

A. That's NFSC flag.

MS. MURRAY: Ms. Loftus, if we could take that down

and put up for the witness what's marked as Government Exhibit

V0106.

Your Honor, just in an abundance of caution, the

government moves to admit the prior exhibit, which is

Government Exhibit V0105.

MR. KAMARAJU: No objection, your Honor.

THE COURT: It is admitted.

(Government's Exhibit V0105 received in evidence)

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MS. MURRAY: And this is Government Exhibit V0106.

This is shown just to the witness right now.

BY MS. MURRAY:

Q. Mr. Zhou, do you recognize Government Exhibit V0106?

A. Yes.

Q. Generally speaking, what is it?

A. It's another meeting I participated. This meeting was with

Miles Guo and——and it was Iron Blood members with other farm

members.

MS. MURRAY: Your Honor, the government moves to admit

Government Exhibit V0106.

MR. KAMARAJU: No objection.

THE COURT: It is admitted.

(Government's Exhibit V0106 received in evidence)

MS. MURRAY: Could we please publish.

BY MS. MURRAY:

Q. Mr. Zhou, starting at the top left here, who is depicted

there on the top left of this screenshot?

A. It's another farm leader.

Q. The leader of which farm?

A. Japan, Tokyo Stellar IS Farm.

Q. On the top right, who is depicted in the screen that's

shown there?

A. He's NFSC chairman.

Q. And then looking at the bottom left, who is the person

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standing in what's depicted there?

A. Miles Guo was standing.

MS. MURRAY: Ms. Loftus, if we could zoom in on that

bottom left screen, please.

Q. Mr. Zhou, do you recognize anyone else who is depicted in

that particular screenshot?

A. Yes.

Q. Who?

A. All of them.

Q. All of them?

A. Yes.

Q. Can you describe, generally speaking, who these people are

and what their roles were.

A. Right next to the Miles Guo, this lady, her name is called

Justice Sara.

Q. And then the male depicted seated kind of in the back on

the left side?

A. Yeah. His name Long Island David.

Q. What farm, if any, is Long Island David associated with?

A. He was associated with Mountain Spice New York.

Q. And then to the right, the individual who is second from

the right in the back of the table here?

A. Her name was Fay Fay.

Q. And then finally, the person who's farthest right in this

photo?

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A. Her name was Ruth Ray.

Q. Generally speaking, what was discussed during this meeting

that you participated in?

A. This meeting was gathered a lot of other farms management

team, farm leaders, and some even invited members, discuss

about some issues reported to the Himalaya Global Alliance.

MS. MURRAY: You can take that down, Ms. Loftus.

Thank you.

Q. Mr. Zhou, did there come a time when the UK Farm asked for

your assistance with certain banking activities?

A. Yes.

Q. Around when was that?

A. That's February 2022.

Q. And who was the leader of the UK Farm at the time?

A. David Dai.

Q. Can you describe for the jury what, if anything, David Dai

asked you to do.

A. Yes. He called me personally, asked me if I could help

this farm and help all the followers to receive money and to

help them to invest into the G series.

Q. And what, if anything, did David Dai say about why he

wanted your assistance?

A. Because he had few other people established business and

open banking accounts, but they were shut down, and they needed

still people to open more accounts to help the followers.

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Q. What, if anything, did David Dai say about why those

accounts had been shut down?

A. Some accounts, they were just mentioned because of CCP

don't want those people to invest, and all CCP is doing, those

accounts were being shut down.

Q. At that time in February of 2022, did you believe that bank

accounts had been closed because of the CCP?

A. Yes, at that time I believed.

Q. What, if anything, did David Dai direct you to do with

respect to opening bank accounts?

A. Yes. We talked about how to open an account, what to tell

the bank, and also gave me instruction with open business, will

have him as hundred percent owner.

Q. And what, if anything, did David Dai tell you to tell the

bank as the purpose of those accounts?

A. Because of course David Dai also knows about my personal

life as also my occupancy

[sic]

as a realtor, so he instructed

that he mentioned it will be easier if I mention this account

when we establish it's for real estate development. They're

also matching my current occupancy so that will not trigger

much of the flak, that will be more susceptible to open the

account.

Q. Did you follow David Dai's instructions and in fact open

bank accounts?

A. Yes, I did.

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Q. After you opened those bank accounts did money come into

the accounts?

A. Yes.

Q. Approximately how much money, in total?

A. Estimate about $2 million.

Q. Were you able to determine the source of the money that

came into your bank accounts that you opened?

A. I only able to see the wire, if it's from individual, or

some of the wires, it's from business accounts.

Q. Do you know how those individuals knew to send money to

your bank accounts?

MR. KAMARAJU: Objection, your Honor.

THE COURT: Sustained.

Q. Mr. Zhou, you mentioned that you saw incoming wires into

the accounts; is that correct?

A. Yes.

Q. Did you provide the account information to any of the

individuals who wired money into your accounts?

A. No.

Q. Do you know who, if anyone, provided your bank account

information to those individuals?

A. Yes.

Q. Who?

A. One of the member from UK London Club.

Q. What, if anything, did you do with the money that came into

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your bank accounts that you had set up?

A. When I see the money, I will bookkeep, document it with a

spreadsheet created by the UK leader. Once reached certain

amount, I would receive instruction to where to send the money

to.

Q. From whom, if anyone, did you receive instructions

regarding where to send the money?

A. The farm, the UK leader, and also other few the UK members.

Q. Were you paid for opening those accounts?

A. No.

Q. Did you keep any of the money that came through those

accounts?

A. No.

Q. I want to return for a moment to the Himalaya Exchange.

MS. MURRAY: I'm going to try to do this old school.

Your Honor, these are, again, V0107 and 108. I

believe just before the break these were admitted, but again,

in an abundance of caution, if they weren't formally admitted,

we would move to admit.

THE COURT: No objection?

MR. KAMARAJU: No, your Honor.

THE COURT: They are admitted.

(Government's Exhibits V0107 and V0108 received in

evidence)

MS. MURRAY: So this is Government Exhibit V0107. If

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we could publish to the jury.

Can we publish that, please. Thank you.

BY MS. MURRAY:

Q. Mr. Zhou, before we took the break, we were looking at

this. This was something that was sent, I believe you said it

was in your computer; is that correct?

A. Yes.

Q. Did you prepare this spreadsheet?

A. No.

Q. Do you know who prepared this spreadsheet?

A. I don't know.

Q. Who sent this to you?

A. One of the UK member.

Q. I want to just talk through a couple of the different

columns here and what's reflected.

First of all, there is a column——the second column

says Discord Discord. Do you see that?

A. Yes.

Q. What information is shown there?

A. Coffee Cantata, then two Chinese words.

Q. Do you know who, if anyone, uses the Discord user name

Coffee Cantata?

A. I used it.

Q. Looking across the rows here, can you explain for the jury

what information is reflected in the top portion of this

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spreadsheet.

A. Sure. Under the Member ID Number, Member, UK2020H170, it's

unique ID assigned to me for investment.

Move to the right, after the Discord Discord, on top

account called A005, that's the investment account calls

created by the Himalaya Global Alliance.

Right next to it, Coin Rates. That's reflects to

Himalaya Coins, as 0.5.

Then right after, it's the Chinese translate to

investment a month.

Then right after, next column, it's Chinese reflect to

translate to welfare coins numbers, which reflect to H Coins

numbers.

Q. So focusing on the different rows, and is it correct that

the second-to-the-most-right column, the one with the little

emoji or the icon, that column reflects investment amounts; is

that correct?

A. Yes.

Q. So taking the first row, what investment, if any, is

reflected there at 59.93?

A. That reflected to an investment called Apple Coins.

Q. And was that an investment that you made in connection with

the G series offerings?

A. Yes.

Q. Looking at the next row, 31,300, what investment, if any,

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does that reflect?

A. That reflect to VOG investments.

Q. And that was in connection with which company's private

placement?

A. Guo Media's, GTV placement.

Q. Looking at the next two rows, both of them have account

code 8142. 50,000 and 20,000. What investment, if any, does

that relate to?

A. The $50,000 reflect to my G club tier 5 investments;

$20,000 reflect to G club tier 2 investments.

Q. And then the next row, the 21,000, what investment, if any,

does that reflect?

A. That reflect to my UK Farm loan agreement investments.

Q. And finally, the row that's 1500, what, if anything, does

that reflect?

A. That reflected to my donations.

Q. And so looking at the rightmost column, what information is

in the rightmost column that was relevant to your Himalaya Coin

purchase?

A. So that's using the coin rates calculation, 0.5, multiplied

by my investment, how much coin I will receive.

Q. And how much coin did you receive based on your prior

investments?

A. 40,935 coins.

MS. MURRAY: We can take this down.

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Q. Mr. Zhou, did there come a time when you requested a refund

of any of the money that you had invested in the G series?

A. Yes, I did.

Q. Approximately when was that?

A. July 15, 2023.

Q. And which money, if any, did you request to have refunded?

A. I request my G Club investment refund.

Q. How did you request a refund of your G Club investment?

A. As instructed, for all the matters, I shall contact the

farm leader first, so I contact Washington, DC farm leader to

request the refund.

Q. And what, if anything, was the response to your refund

request?

A. It wasn't a pleasant——first they just provide a request

form, asked me to fill it out.

Q. Did you complete that form?

A. Yes, I did.

Q. What happened next?

A. Then for a very long period of time I didn't get any

response, so I have to contact them back and do a follow-up,

multiple follow-ups. But they were trying to verify my

investments.

Then later, they asked me to fill out my request form.

They asked me they only will return HDO to me, not as fiat

currency to me.

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Q. And just to be clear, when you say HDO, what are you

referring to?

A. Himalaya dollars.

THE COURT: And what do you mean by fiat currency?

THE WITNESS: Because all my investment originally

send it to investment——G series investment using wires, paid in

the dollar.

THE COURT: So you're saying dollars are fiat

currency?

THE WITNESS: Correct.

BY MS. MURRAY:

Q. And Mr. Zhou, at the time that the farm offered to refund

your G/CLUBS money in HDO, did you have access to a Himalaya

Exchange account?

A. I don't.

Q. Did you have access to any of the Himalaya Coins that you

had sent money to the farm to purchase?

A. I don't.

Q. At that time that you requested the refund and it was

offered in HDO, did you have personal knowledge whether you in

fact owned Himalaya Coins or Himalaya dollars?

A. I addressed that. I——

Q. What do you mean by that?

A. I told them that this request to return my investment in

HDO is not acceptable because I don't have HDO accounts,

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Himalaya Exchange accounts, so I said I will only receive in

the currency which is fiat currency.

Q. And what, if anything, was the response to your saying that

you wouldn't accept HDO for your refund?

A. So there's another long period of waiting time. They just

asked me to wait.

Q. Did there come a time when you received a refund of your

G/CLUBS money?

A. Yes, I did.

Q. Around when was that?

A. December 1, 2023.

Q. And what were the circumstances of your receiving that

refund?

A. I have to sign a forfeit H Coin agreement and I also have

to return some equipments to them, so that's all the terms I

have to agree to.

Q. Taking the equipment, what type of equipment were you

required to return?

A. Just because I was——as a streaming technician, Washington,

DC Farm sent over certain equipment for the broadcast

equipments I at the time was holding. So in a month, once I

request my refund, they would ask me to also return the

equipment as well.

Q. You also mentioned you had to sign something forfeiting

your Himalaya Coin for the refund. Can you explain that to the

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jury, please.

A. Yes. Since I made a refund request, then they also send me

agreement that I have to forfeit all the H Coin was previously

acquired from investments.

Q. And how much had you paid for that H Coin that you had to

forfeit?

A. Total, I paid 5500 for the coins.

Q. Did you in fact sign that agreement to forfeit the $5,500

worth of H Coin?

A. I have no choice. I was forced to sign that.

Q. At some point after you requested a refund of your G Club

money, how, if at all, did the whistleblower movement respond?

A. From——

MR. KAMARAJU: Objection, your Honor.

THE COURT: As to form, sustained.

Q. Mr. Zhou, did anyone within the whistleblower movement, to

your knowledge, become aware that you'd requested a refund?

MR. KAMARAJU: Objection, your Honor. Same.

THE COURT: Sustained.

Q. Mr. Zhou, did there come a time when you were removed from

the UK Farm?

A. Yes.

Q. Can you describe what happened.

A. Right after I returned equipment, the farm leader just

remove me out of the Discord server, cut all the

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communications, and also they removed me out of all the working

channels, either the farm, Discord, WhatsApp, I was completely

removed.

Q. Around when did that happen that you were removed from the

farm Discord channel?

A. That was in September 2023.

Q. Directing your attention to January of 2024, did there come

a time when your information was posted on Gettr?

MR. KAMARAJU: Objection to form, your Honor. What

information?

THE COURT: Sustained.

MS. MURRAY: Why don't we just pull up Government

Exhibit V02, which is in evidence.

Q. Mr. Zhou, do you recognize this?

A. Yes.

Q. What is it?

A. This is a post on gettrsocialmedia.com.

Q. And can you just remind the jury what Gettr is.

A. Yes, Gettr was of the G series. It's a social platform

created by Miles Guo and it's similar as the Twitter's.

Q. Looking at the English translation that was associated with

this post, can you read the title of this announcement.

A. Global Himalayan Farm Alliance Blacklist Announcement.

Q. What, if anything, do you understand a blacklist to be with

respect to the Himalaya Farm Alliance?

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A. For anyone accused who are against this movement, or Miles

Guo personally, would be put on the blacklist.

Q. Looking at item 2 that's listed here, can you please read

that.

A. I'm sorry. One more time, please.

Q. Yes. Can you read item 2 that's listed here.

A. Yes. On January 21, 2024, Washington, DC Farm and the

collations made the following blacklist decision: Blacklisted,

Coffee Cantata, Wen Lu, in Chinese. No. 5082-Coffee Cantata.

Reason for exclusion, malicious attack on whistleblower

revolution and the G series. Blacklist persons have the right

to submit an appeal within five days of the day of

announcement, and appeal will be ignored.

Q. Mr. Zhou, Coffee Cantata, is that——that's the user name

that you used?

A. Yes.

Q. Were you given any notice in advance of this blacklist

announcement being posted on Gettr?

A. No.

Q. What was your reaction, if any, to being posted publicly on

the blacklist?

A. First, I saw this afterwards. That just not the truth. I

never attacked the whistleblower movement, or the G series.

Q. Did you appeal this blacklist decision?

A. Because what I saw was already after the appeal dates,

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allowance dates.

MS. MURRAY: We can take this down, Ms. Loftus. Thank

you.

THE COURT: What is your answer, sir? She asked

whether you appealed.

THE WITNESS: I couldn't because I saw this post was

after this appealing allowance dates.

THE COURT: You may continue.

MS. MURRAY: Thank you.

BY MS. MURRAY:

Q. Did there come a time when you stopped supporting Miles

Guo?

A. Yes.

Q. Around when was that?

A. That's around June 2023.

Q. Why did you stop supporting Miles Guo around June of 2023?

A. Because there's a lot of the movement, the actions, I

personally seen is wrong, I——I don't want to be part of it, so

that's why I made the decision to stop.

Q. Can you describe some of the actions that you're referring

to.

A. Because there's also province within the farms and the

Global Alliance. Especially the UK London Club, the leader was

accused of misproper use the Rule of Law Foundation monies.

There's a lot of problems never get really solved. And we——I

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have personally reported a lot, a lot of the problems, never

got answer or solved.

Q. Mr. Zhou, in total, how much money did you spend on the G

series offering we've been discussing?

A. Total about $120,000.

Q. And how did you pay for those investments or those costs of

the G series?

MR. KAMARAJU: Objection, your Honor.

THE COURT: Sustained as to form.

Q. Mr. Zhou, what was the source of the money that you spent

on the G series offering?

MR. KAMARAJU: Same objection.

THE COURT: Step up, please.

(Continued on next page)

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(At the sidebar)

THE COURT: So are you objecting on the basis that it

isn't established that there was an offering?

MR. KAMARAJU: No, I'm objecting on the basis that the

source of the money to pay for the offering is irrelevant.

THE COURT: Overruled.

(Continued on next page)

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(In open court)

THE COURT: Overruled. You may answer.

THE WITNESS: Yes, your Honor.

A. The source of the money was from my personal earnings, and

also I sold my properties, condominium I sold, and I also took

out my wife's life insurance.

Q. Why did you sell your condos, your personal real estate

property?

A. Because I——at the time I need to cash the Himalaya Exchange

coin launch, but I invest into G Club, so at the time I don't

have enough capital, but I——only thing I had was my

condominium. I have to——and I sold it.

Q. What about your wife's life insurance? Why, if at all, did

you cash out the life insurance policy?

A. That money, she agreed to put it into the farm loan.

Q. Mr. Zhou, how much profit, if any, did you make from the

120,000 or so that you spent on the G series offerings?

A. Zero profit.

Q. How much money in total did you lose, if any, through those

offerings?

A. I lost about $30,000.

Q. $30,000?

A. Or more.

Q. At the time that you invested in the G series offerings,

did you believe that they would be profitable?

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A. Yes.

Q. At the time that you invested in the G series offerings,

did you believe that Miles Guo would personally pay for any

losses that you sustained from those investments?

A. At that time I believed it.

Q. Did Guo in fact repay you for the approximately $30,000

that you lost through the G series investments?

A. No.

MS. MURRAY: May I have a moment, your Honor.

Nothing further.

THE COURT: Cross-examination.

MR. KAMARAJU: Yes. Thank you, your Honor.

CROSS EXAMINATION

BY MR. KAMARAJU:

Q. Good afternoon.

A. Good afternoon, sir.

Q. I just want to make sure I'm pronouncing your last name

correctly. Mr. Zhou?

A. Correct.

Q. Okay. Thank you.

Now you just testified that Mr. Guo has never repaid

you the amount that you say that you lost, correct?

A. Correct.

Q. You've never spoken with Mr. Guo, right?

A. I spoke to him.

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Q. You spoke to him about getting the money back?

A. No.

Q. You've never asked him to get any money back, correct?

A. I mailed it to him.

Q. You mailed it to Mr. Guo?

A. Yes.

Q. Mr. Guo doesn't use email, correct?

A. I mailed it to——

MS. MURRAY: Objection.

THE COURT: Sustained.

Q. You've never emailed Mr. Guo before, have you?

A. I didn't email to him.

Q. Okay. So he's never responded to an email that you've

sent, correct?

A. Never responded.

Q. And he's never sent you personally an email, correct?

A. Correct.

Q. Okay. Now I want to start with the Rule of Law Foundation.

Do you remember testifying about that?

A. Yes.

Q. And you testified that you first heard about it at a press

conference in November 2018, correct?

A. Correct.

Q. And your testimony was that you left that press conference

with the impression that Mr. Guo was going to fund the Rule of

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Law Foundation to a hundred million dollars, correct?

A. Correct.

Q. And that's what the prosecutors asked you here today,

right?

A. Yes.

MR. KAMARAJU: Could we have Government Exhibit

W1005V, please. It's in evidence, so we can publish it.

If we can just play it a little bit.

(Video played)

MR. KAMARAJU: Okay. We can pause right there.

Q. Now they asked you about this clip earlier, correct?

A. Yes.

Q. They asked you whether you had an understanding that

Mr. Guo had made a representation about funding a hundred

million dollars to the Rule of Law Foundation, correct?

A. Correct.

Q. Okay. That's not Mr. Guo, right?

A. That's not.

Q. That's Steve Bannon, right?

A. Correct.

Q. Steve Bannon looks nothing like Mr. Guo, right?

A. No.

MS. MURRAY: Objection, your Honor.

THE COURT: Overruled. Go ahead.

Q. This is Steve Bannon talking, correct?

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A. Correct.

Q. So they asked you a question about representations Mr. Guo

made, but they showed you a clip of Mr. Bannon, correct?

A. Correct.

Q. But then you answered that your expectation was Mr. Guo was

going to fund the payment, right?

A. Correct.

Q. Now this isn't the first time that you've seen this video

clip, right?

A. Correct.

Q. You've seen it when you prepared with them before, right?

A. I saw it at the live——when this press conference live.

Q. Okay. We'll come back to that. But you've also seen it

with the prosecutors, right?

A. Yes.

Q. They've showed it to you before today, right?

A. Yes.

Q. They showed it to you when you prepared your testimony with

them, right?

A. Not prepared the testimony, but they showed it to me.

Q. Okay. Well, you've met with the prosecutors multiple

times, right?

A. Yes.

Q. These prosecutors sitting at the table here, right?

A. Not all.

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Q. Some of them, right?

A. Yes.

Q. Which ones?

A. Four of them.

Q. Okay. So the four people sitting here at the front of the

table?

A. Not the left four but——

Q. Okay. Some set of those people, correct?

A. Correct.

Q. And there was an FBI agent there, right?

A. No. I don't know.

Q. There wasn't an FBI agent there the first time you met with

the prosecutors?

A. I don't know if the FBI. I don't know.

Q. Was there a translator there the first time you met with

the prosecutors?

A. No.

Q. There was no translator when you first met with them?

A. No translator.

Q. So you've never used a translator to speak with the

prosecutors; is that right?

A. I didn't use translators.

Q. Okay. Now you testified that they showed you this clip

during one of those meetings, right?

A. Correct.

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Q. How many meetings would you say you had with the

prosecutors?

A. About seven.

Q. About seven, right?

A. Yes.

Q. So that's seven times where you've met with the prosecutors

to discuss the testimony that you gave today, right?

A. Not discuss.

Q. Okay. What did you talk about for seven meetings then?

A. So I was being just asked the answer.

Q. Okay. Well, what were they asking you about?

A. Asked related to the cases.

Q. Right. They asked you the same questions they asked today,

right?

A. Correct.

Q. And you gave the answers, right?

A. Yes, I did.

Q. Okay. And sometimes if they didn't like one of your

answers, they asked a different question, right?

A. No.

Q. So you're telling me during seven meetings there was no

point where they asked you a follow-up question; is that your

testimony?

A. They asked follow-up——

MS. MURRAY: Objection.

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THE COURT: Sustained. Sustained as to what they were

thinking.

MR. KAMARAJU: Oh. My apologies, your Honor.

THE COURT: You may ask whether they asked follow-up

questions.

MR. KAMARAJU: Oh, sorry. I thought that's what I

asked.

BY MR. KAMARAJU:

Q. So over the course of seven meetings, it's your testimony

that the prosecutors never asked you a follow-up question?

MS. MURRAY: Objection. Mischaracterizing the

witness's testimony.

THE COURT: Sustained.

Q. Okay. Now you testified that you have seen this clip both

during a meeting with the prosecutors but you also saw it live,

correct?

A. Correct.

Q. Okay. Now this clip is not everything that even Mr. Bannon

has to say at that press conference, right?

A. That's correct.

Q. He gives much longer remarks, right?

A. Yes.

Q. He takes questions from the press, right?

A. Yes.

Q. Okay. He talks about efforts that Mr. Guo has made in

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support of the anti-CCP movement, right?

A. Yes.

Q. He talks about Guo Media, correct?

A. Yes.

Q. In fact, Mr. Bannon was even asked a question about whether

the Trump administration was involved, right?

MS. MURRAY: Objection, your Honor.

THE COURT: Overruled. You may answer.

A. No.

Q. You don't recall that?

A. Never asked.

Q. Okay. So your testimony was Mr. Bannon was never asked

that question, right?

A. Could you repeat that one more time, please.

Q. Yeah. Was Mr. Bannon asked by a reporter whether the Trump

administration would be involved with the Rule of Law

Foundation?

A. No. Mr. Bannon never mentioned about Trump.

Q. Okay. And he was never asked, right?

A. In that conference, no.

Q. Okay. Now Mr. Guo did speak at that conference, correct?

A. Yes.

Q. Okay. And I think you talked about a few of the topics

that he discussed during your direct testimony. Do you

remember that?

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A. Which topics?

Q. Well, and forgive me if I get it wrong, but I believe one

of the things you said was that he discussed investigating

business deaths. Do you remember testifying about that?

A. I'm sorry. Not invest——business stats,

investigate——Mr. Bannon said investigate mysterious Chinese

businessmen's deaths.

Q. Okay. What is that a reference to?

A. That reference to how this Rule of Law Foundation fund will

be used.

Q. Okay. Well, Mr. Bannon also talks about the fact that

there had been an investigation into the death of a Chinese

businessman, correct?

A. Correct.

Q. It was a chairman of a company called HNA, correct?

MS. MURRAY: Objection.

THE COURT: Overruled. You may answer.

A. Yes.

Q. And Mr. Guo had previously predicted the death of the

chairman of HNA, correct?

MS. MURRAY: Objection, your Honor. Hearsay and

relevance.

THE COURT: Sustained.

MR. KAMARAJU: I'm not offering it for the truth, your

Honor.

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THE COURT: If you'll step up.

(At the sidebar)

THE COURT: The question was: And Mr. Guo had

previously predicted the death of——

MR. KAMARAJU: Yes. I'm not offering it for the truth

of the man's death, just simply that he predicted it, that he

heard him say it.

THE COURT: During the conference?

MR. KAMARAJU: No. Prior to the conference, your

Honor.

THE COURT: Well, how is it relevant?

MR. KAMARAJU: Because the witness testified that

Mr. Guo had revealed what he referred to as classified

information and that's one of the things that attracted the

witness. I don't mean classified in the setting that American

government uses it. I mean confidential information about the

Chinese government, and that was what attracted him. I'm just

following up. I don't intend to spend a long time on it. I

have two more questions.

MS. MURRAY: I don't see how it's not hearsay. I

don't see how it's relevant.

THE COURT: I just don't recall this testimony that

you're referring to, that you're saying this witness said that

one of the reasons he was attracted to Mr. Guo was because he

mentioned the death of a businessman?

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MR. KAMARAJU: No. He said that he knew that Mr. Guo

had unknown details. He referred to it as classified

information. I'm not calling it that. But he referred to

secret information about Chinese government officials, and

that's what Mr. Guo was revealing; that's one of the things

that attracted him.

THE COURT: I have to say I don't recall that

particular testimony. Is that what he said?

MS. MURRAY: He indicated that it was one of the

topics that Miles Guo had covered in his broadcast. But first

of all, I think that the statement that Mr. Kamaraju is

referring to is not even covered in this broadcast. It's an

out-of-court statement by Miles Guo. I also don't think that

the alleged prediction of the death of a Chinese businessman

falls within this broad category of potentially classified

information about Chinese government officials. I just don't

see the connection.

THE COURT: So this prediction does not occur at the

conference.

MR. KAMARAJU: No. Before the conference Mr. Guo

predicts that it will happen. The death happens prior to the

conference. Mr. Bannon then notes at the conference that one

of the things that Mr. Guo has done is an investigation into

the death of the businessman.

THE COURT: Okay. I'm going to allow the question.

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MR. KAMARAJU: Thank you, your Honor.

(In open court)

THE COURT: Overruled.

BY MR. KAMARAJU:

Q. Sir, do you remember the question?

A. Could you please repeat it, please.

Q. Yes.

MR. KAMARAJU: I'm sorry to do this, but would the

court reporter mind reading back the question, please.

(Record read)

THE COURT: You may answer.

THE WITNESS: Yes, your Honor.

A. Yes.

Q. And Mr. Bannon discussed that at the press conference,

correct?

A. Yes.

Q. He talked about that Mr. Guo will send people to

investigate the death, correct?

MS. MURRAY: Objection.

THE COURT: Overruled. You may answer.

A. That part I don't remember.

Q. Okay. What do you——you don't remember Mr. Bannon talking

about Mr. Guo sending investigators——

MS. MURRAY: Objection. Asked and answered, your

Honor.

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THE COURT: Sustained. Go ahead.

Q. Now you testified on direct about your understanding of

what the NFSC is, correct?

A. Correct.

Q. And just remind us, what does NFSC stand for?

A. New Federal State of China.

Q. All right. And it's comprised of individuals who would

like to take down the Chinese Communist Party, fair?

A. Yes.

Q. And you were one of those people, right?

A. Yes.

Q. And so you shared that goal, right?

A. Yes.

Q. And now the NFSC, that's the New Federal State of China,

right? We're talking about the same thing?

A. Yes.

Q. The NFSC was founded on June 4, 2020, correct?

A. Correct.

Q. You watched the video about that founding, right?

A. Yes.

Q. Mr. Guo was there, correct?

A. Correct.

Q. He was in front of the Statue of Liberty, right?

A. Not in front of it. He was on his boat.

Q. Okay. So the boat was in front of the Statue of Liberty,

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right?

A. Close to it.

Q. And there were other people who appeared in the video,

correct?

A. Yes.

Q. One was a famous Chinese soccer star, right?

A. He appeared on stream, online.

Q. Okay. So you could see him during the broadcast, right?

A. Yes.

Q. Mr. Bannon was there also, right?

A. Correct.

Q. And they were talking about the founding of this

alternative government, right?

A. Yes.

Q. Okay. And this is during the COVID pandemic, correct?

A. Yes.

Q. Okay. Now you talked a little bit about this on direct,

but the idea is that the NFSC would be an alternative

government to the Chinese Communist Party, right?

A. Yes.

Q. And so you used the word on direct "ecosystem," there were

various businesses that comprised the ecosystem of the NFSC,

correct?

A. Yes.

Q. So you talked about GTV, right? You testified about GTV.

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That was one of the companies that would be in the ecosystem?

A. Yes.

Q. And G/CLUBS, that was another company that would be in the

ecosystem, right?

A. Yes.

Q. And the Himalaya Exchange, that was another company that

would be in there, right?

A. Yes.

Q. And each of these different components had a role to play

as part of that ecosystem, correct?

A. The goal was the same.

Q. They had a different purpose is what I'm trying to get at,

right?

A. Purpose is all the same.

Q. Okay. Well, let me try it this way. So GTV was a social

media company, right?

A. Yes.

Q. Himalaya Exchange was a cryptocurrency exchange, right?

A. Yes.

Q. And they both do different things, right?

A. Correct.

Q. But they're both——they were both intended to be part of the

larger NFSC goal, right?

MS. MURRAY: Objection.

THE COURT: Overruled. You may answer.

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A. Yes.

Q. So in terms of purpose, GTV was intended to be sort of a

social media platform that was devoid of CCP censorship,

correct?

A. Yes.

Q. And G/CLUBS was a way for NFSC members to associate with

each other, correct?

A. No. It's for investments.

Q. It's for investments.

A. Yes.

Q. Didn't you testify on direct that you were going to get a

passport as part of G/CLUBS, right?

A. Yes.

Q. And that passport was going to be an NFSC passport, right?

A. Yes.

Q. Okay. So G/CLUBS was for NFSC members, among other

reasons, to associate with each other, correct?

MS. MURRAY: Objection, your Honor. Asked and

answered.

THE COURT: I'm going to allow the question.

A. Not to socialize with other members, because each investor

is individually. We don't know their informations.

Q. So you joined G/CLUBS, right?

A. Yes.

Q. Okay. When you joined G/CLUBS, were you proud of joining

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G/CLUBS?

A. Yes.

Q. Okay. You were showing your commitment to the NFSC; that

was one of the reasons why you bought a G/CLUBS membership,

right?

A. I want to get stock and also get a passport, which was

promised.

Q. Okay. I didn't ask you what was promised. I just asked

why you did it, right?

MS. MURRAY: Objection, your Honor.

THE COURT: So don't testify.

Q. Okay. You mentioned that you wanted to get a passport,

right?

A. Yes.

Q. And that was the NFSC passport, right?

A. Yes.

Q. All right. You also testified about the farm loans, right?

A. Yes.

Q. And the farm loans were intended to provide funding for the

farms' work, right?

A. That was the fund, what will be used for.

Q. Right. And you testified on direct, you said it would be

used for the working capital of the farms, right?

A. Correct.

Q. So that's the farms' business, right?

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A. Farm can use it as operation capitals.

Q. Okay. So the farm has discretion to use it on its

operations, right?

A. Yes.

Q. So if the farm decides they want to spend it on this, they

can spend it on this; if they want to spend it on that, they

can spend it on that, right?

A. There's also restriction.

Q. Okay. And that restriction was found in the loan

agreement; is that right?

A. I don't remember that.

Q. Okay. So you don't remember where this restriction is

located, right?

A. Where located, I don't remember.

Q. Okay. Now I believe you lived in China until 1998,

correct?

A. Correct.

Q. And the political goals of the NFSC, is it fair to say

they're easier to support in the United States than in China?

A. Yes.

Q. Here you had the choice to spend your money on those

products, right?

A. On which products?

Q. Well, just take G/CLUBS, right? That was your choice; you

could spend on it, right?

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A. Yes.

Q. Like there was no government agency that stopped you from

spending on it, right?

A. Correct.

Q. And like this hat that you testified about, this was your

choice, right? You could buy this hat if you wanted to, right?

A. Yes.

Q. And the whistle that you talked about, your choice, right?

A. But all the purchases was also towards to grow the G

Fashions as one of the investments. I treated it as not just

purely purchase items but to support the growth together.

Q. Okay. To support the growth of the company, right?

A. As the shareholders.

Q. Okay. But you weren't actually a shareholder in G Fashion,

right?

A. No. Miles Guo mentioned our investment will including G

Fashion stocks.

(Continued on next page)

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BY MR. KAMARAJU:

Q. You never had a share of G Fashion shares; correct, sir?

A. I don't have the shares.

Q. Okay. You have no idea -- you have no idea how many shares

you even think you were promised, right?

A. Promised a dollar per shares.

Q. Okay. So a dollar for everything you spent on G Fashion?

A. Not spend. It was -- G Fashion was in the future, the G

Fashion's gross was towards to the G Series investments.

Q. Okay. So going back to my original question though, that

was your choice to spend on that, right?

MS. MURRAY: Objection.

THE COURT: Overruled. You may answer.

A. Yes.

Q. Now, sir, you testified on direct you're in the real estate

business; is that right?

A. Yes.

Q. And you've been in the real estate business for more than

ten years, right?

A. Correct.

Q. So you're pretty experienced in the business, right?

A. Yes.

Q. Your company is called East West Luxury Group; is that

right?

A. No, that's my small group.

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Q. I'm sorry?

A. That's my inner group.

Q. That's your inner group. Okay.

What's the name of your company, I'm sorry?

A. United Realty Group.

Q. And do you specialize in any particular kind of property?

A. Yes.

Q. What's that?

A. Residential.

Q. Okay. Do you have a particular type of clientele?

A. What you mean by --

MS. MURRAY: Objection, your Honor.

THE COURT: Overruled. You may answer.

A. I'm sorry, what do you mean by "particular"?

Q. Well, for example, do you specialize in high-end

residential properties?

MS. MURRAY: Objection, your Honor. 402. 403.

THE COURT: Overruled. You may answer.

A. I just the residential. I don't consider particular, if

it's a high-end or it's low-income or it's affordable housing.

Q. Okay. So you run the gamut, basically?

A. Yes.

Q. Okay. Now, you advise your clients in connection with

those transactions, right?

A. I'm sorry, which transactions?

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Q. Just your real estate business, right?

A. I'm only show the houses, provide informations on the

houses, but I don't control monies or receive the monies.

Q. No. Sir, I'm not trying to trick you. I'm not asking you

if you receive the money or don't receive the money. All I'm

asking is, is you advise your clients in connection with the

purchase of their homes, right?

A. Yes.

Q. Okay. And part of that advice is to tell them to pay

attention to the deal they're entering into, right?

A. Correct.

MS. MURRAY: Your Honor, objection. Sidebar.

(Continued on next page)

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(At sidebar)

MS. MURRAY: Your Honor, the Court previously ruled

that you can't get into the details of the decisions that

people made in the investments. It's veering into negligence,

it's prejudicial, it's not relevant, this line of questioning.

And it's, I think, over the line of -- and the argument that

there was negligence associated with the investments that this

witness testified to.

MR. KAMARAJU: I do not intend at all to argue

negligence. The determination, one, it goes to materiality,

which the government has to prove. Two, your Honor also said

that as part of materiality, we were allowed to inquire into

the sophistication of the potential investors' particular

trades that might make that a reasonable investor.

I'm not arguing that he should have done this or he

should have done that. I'm just saying that part of

materiality turns on what representations you're focused on.

And sophistication is something that your Honor has already

explicitly said is fair game.

MS. MURRAY: Your Honor, these questions aren't going

to sophistication of him as an investor; it's victim-blaming,

asking him whether he advised clients in the course of his real

estate transactions and whether those clients were high-end

individuals. I don't see how that is remotely relevant to this

individual's understanding of what the investment opportunities

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were or his motivation for investing in them.

THE COURT: So he's asked whether he advises the

client to --

MR. KAMARAJU: Pay attention.

THE COURT: -- pay attention to the details.

MS. SHROFF: Read a contract of sale.

MR. FINKEL: That's not appropriate.

This is a fraud case. There's no reliance defense.

You can't say to a victim of fraud, You should have read all

these details, sir. This is victim-blaming through another

word, they are using "materiality." And the jury is going to

draw the wrong conclusion. It's a 403 problem.

MR. KAMARAJU: Your Honor is going to instruct the

jury as to the elements of the offense. I'm sure the

government will ask as to that instruction. Reliance is not

relevant. I'm not sure I see --

THE COURT: Well, I think that you're trying to get

him to say that I advise my clients to use good judgment, and

the implication is that he didn't follow his own advice.

MR. KAMARAJU: No, your Honor. What I'm eventually

going to set up is to the extent that he did not read documents

when entering into these investments, is because the

information in those documents was not material to him, which

is directly as a joinder to the government's allegations of

specific recommendations in those documents are material. It

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didn't matter to him what's in the farm loan agreement, to

enter into the farm loan agreement. Then how it can be

material?

THE COURT: Did he actually discuss the specifics of

agreements?

MR. KAMARAJU: He also told the FBI that he didn't

read them.

THE COURT: But he testified today about the specific

agreements. So I don't think you can argue that he said that

he did not rely on the agreements at all.

MR. KAMARAJU: I'm allowed to impeach him on that,

your Honor.

THE COURT: Well, I'm saying you can't say he didn't

testify about examining the agreements.

MR. KAMARAJU: No, no, no. You're right, your Honor.

What I'm saying is I'm allowed to impeach that testimony to

suggest that he didn't read those.

THE COURT: You can challenge him on that. What I'm

saying is you can't imply that he did not say today that he

read the agreements.

MR. KAMARAJU: No, absolutely, your Honor. I'm not

intending --

THE COURT: So I am going to sustain the objection at

this point because I do think that you're going down that road

of the blaming of the victim.

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MR. KAMARAJU: Okay, your Honor.

MR. FINKEL: Thank you.

(In open court)

THE COURT: Sustained.

BY MR. KAMARAJU:

Q. Now, you testified on direct that you were interested in

investing in GTV; correct?

A. Yes.

Q. And you understood that the purpose of GTV was to be a

social media platform, right?

A. Yes.

Q. And that it was to broadcast material that was critical of

the Chinese government, right?

A. Yes.

Q. So that was one of the goals that the movement had, was to

set up a social media network like that, right?

A. For all people to use, yes.

Q. Right. And the NFSC was actually -- the public

announcement of the NFSC was actually just two days after the

GTV private placement closed; correct?

A. Yes.

Q. Now, you testified that you were hoping to earn a profit on

GTV, right?

A. I'm sorry?

Q. You testified that you were hoping to earn a profit on GTV;

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correct?

A. Yes.

Q. But you understood it was a risky business, right?

A. Yeah. Miles more mentioned it, investment has risk.

Q. Mr. Guo said investment has risk, right?

A. Also he made a guarantee.

Q. Well, I asked you if he said that it --

MS. MURRAY: Objection, your Honor.

THE COURT: Sustained.

Continue your questions.

Q. Now, you testified that Mr. Guo told people who wanted to

make an investment less than $100,000, that they had to contact

Sara Wei, right?

A. At the time, yes.

Q. At the time. What do you mean by that?

A. Because the first announcement he mention who like to

invest, he didn't mention that.

Q. Okay. So there came a point at which Mr. Guo said, If you

want to invest less than $100,000, you should go to Ms. Wei,

right?

A. He didn't mention 100,000, less 100,000. He mention for

other people that don't have that much can contact other farm

leaders to invest. He will not let the followers left behind.

Q. He didn't want the followers to be left behind, right?

A. Yeah.

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Q. Okay. So your testimony is he didn't mention $100,000, he

just said smaller investments go to your farm leaders; is that

right?

A. No. He mention 100,000 is two tiers; 100,000 for a certain

limited head counts. It was 2,000 head counts.

Q. Okay. So there were 2,000 head counts, to use your word,

for people who wanted to invest $100,000 or more, right?

A. That's a minimum.

Q. Right. So $100,000 or more, right?

A. Correct.

Q. And then if you wanted to invest less than $100,000, he

told you to go talk to people in the farms; is that right?

A. Yes.

Q. Okay. And that was the only dividing line, right, it was

more than $100,000 or less than 100,000, right?

A. Yes.

Q. And you personally decided that you wanted to invest less

than $100,000, right?

A. Not decide, just I don't have $100,000 at the time.

Q. Okay. Fair enough. You didn't have the $100,000, so you

ended up investing less, right?

A. Correct.

Q. All right. Now, you testified on direct that you watched a

broadcast that Mr. Guo did on April 21st, 2020, right?

A. April 20th.

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Q. This is the one that's announcing the GTV private

placement; is that right?

A. Yes.

Q. Okay. And you watched that, right?

A. Yes.

Q. Okay. You watched the whole thing?

A. Yes.

MR. KAMARAJU: Could we bring up Government Exhibit GX

C-26-T and go to page 1, please.

Q. The prosecutors, when they asked you about this, they only

showed you one clip from the --

THE COURT: One moment, please. It seems that one of

our jurors, No. 12, does not have the image on the screen.

MR. KAMARAJU: I think it may be a problem with that

one screen, your Honor.

THE COURT: Can you look on to Juror No. 11's screen?

Juror No. 12, are you able to look at Juror No. 11's

screen?

Okay. Go ahead, please.

MR. KAMARAJU: Maybe we can blow up the paragraph

that's -- great. Thank you. Is that better? Okay.

BY MR. KAMARAJU:

Q. Now, on direct, the prosecutors asked you about one clip

from this broadcast; correct?

A. Yes.

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Q. They didn't show you the whole broadcast to testify about,

right?

A. Correct.

Q. So you see here where it says: "This video is just a brief

introduction." Do you see that?

A. I saw the English text, yes.

Q. Could you read that, please, the highlighted portion?

A. "This video is just a brief introduction to friends and

fellow fighters who have the intention to invest in GTV so that

you can understand the documents to be signed in the investment

and during investment, as well as some basic procedures."

MR. KAMARAJU: Okay. Can we go to page 5, please.

Q. Do you see the highlighted portion here?

A. Yes.

Q. Could you read that, please.

A. "Within 24 hours after you received this video, you will

receive the following documents from the law firm about the

so-called private equity of GTV."

MR. KAMARAJU: Okay. Could we go to page 2, please.

Q. Do you see the highlighted section here?

A. Yes.

Q. Could you read that, please.

A. "Please carefully read through all the documents to be

signed for investment."

Q. Okay.

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MR. KAMARAJU: Could we go to page 16, please.

Q. Could you read that highlighted portion, please.

A. "I just would like to make a brief explanation, but I will

stress this one more time: Please be sure to read the

prospectus, subscription letter, shareholder agreement, and

confidentiality agreement that are sent to you. Those will

prevail."

Q. Okay. So on repeated instances during the April 20th

broadcast, Mr. Guo urged listeners to read the documents;

correct?

MS. MURRAY: Your Honor, same objection that we raised

at sidebar.

THE COURT: The objection is sustained.

Move on.

Q. Do you know what he means when he says "prospectus"?

A. He didn't speak that broadcast in English; his original

words were in Chinese.

MR. KAMARAJU: I think we can take it down. We have

the Chinese next to it. That's helpful.

Your Honor, I'm sorry, could we have a 20-second

sidebar?

THE COURT: Yes.

(Continued on next page)

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(At sidebar)

MR. KAMARAJU: Just before I continue, I just want to

make sure I understand. Am I not permitted to ask him if he's

read the prospectus?

THE COURT: I want to first hear the objection of the

prosecution.

MR. KAMARAJU: Okay.

MS. MURRAY: That question is not objectionable. But

the questions that Mr. Kamaraju has been asking are going again

to kind of victim-blaming and picking apart very specific

details about what this victim did or didn't do in a way that

is prejudicial, is intended to kind of muddy the waters for

this victim. If he wants to ask if he read the prospectus, he

can ask if he read the prospectus.

MR. KAMARAJU: All I elicited was that Mr. Guo

directed investors to the prospectus where there is information

surrounding the representations that the government is relying

on. I want to be able to ask him if he read the prospectus.

If he didn't, he didn't. That's what the entire line of

questioning before was when I showed him the various parts, was

that Mr. Guo is directing them to the document.

THE COURT: So it's not a "don't you think you should

have done that," you're not going to follow up with that.

MR. KAMARAJU: I don't intend to ask him "shouldn't

you have read it," no.

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THE COURT: Just did you. That's it. And then you're

done with that line of questioning?

MR. KAMARAJU: I mean, if he says yes, he read it,

then I'm going to show him the document, I'm going to ask about

specific representations about the document.

THE COURT: See, that's the problem. You can't go to

those representations.

MR. KAMARAJU: Actually, your Honor, your Honor ruled

in the motion

in limine

under the

Weaver

case that we are

allowed to show different representations in the PPM to go to

materiality.

The government explicitly argued that it only went to

reliance. They cited Weaver. Weaver, in fact, says the

disclaimers are relevant to the idea of materiality. So if you

read the disclaimers, then I'm allowed to elicit them.

Otherwise, I don't know how to elicit that other than through a

witness who read the document.

MS. MURRAY: Your Honor, the representations that were

made weren't only contained within the document. There is the

broadcasts, there are other statements that he made. So to the

extent that they want to inquire and find out what caused the

witness to invest or what induced him to invest, they can ask

that question without tying it to the language of the

prospectus and going to this line of questioning.

Then with respect to the specific question did he read

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the prospectus, we don't object to that question. But it's the

20 questions that have led up to it and then the questions that

would follow.

THE COURT: If he answers yes, then what questions do

you feel are appropriate?

MS. MURRAY: I think it would be questions regarding

the materiality of -- I believe this is where Mr. Kamaraju is

going, the materiality of the guarantee that Guo made that he

would personally guarantee any losses.

If the line of questioning is, Here's what was stated

in the prospectus. Were Guo's statements that he would

personally guarantee your money, were those immaterial to your

decision to invest because it's not listed in the prospectus

anywhere, I don't think that's --

MR. KAMARAJU: Well, first of all, I will note that

the indictment alleges that the misrepresentation related to

the securities fraud count and the wire fraud count related to

GTV to be statements in the prospectus. So the idea that he

made statements elsewhere that affected that, that's fine.

They can argue that. But there's no universe in which the

prospectus statements are not relevant, and the information

surrounding those representations are not relevant unless

they're dropping the count, which I don't think they are.

MS. MURRAY: Your Honor, this is not the only victim

who invested in the GTV offering. It's very clear that what

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they're trying to do is back into the sophistication. And a

topic that your Honor already ruled doesn't come in through

this. Again, if they want to ask --

THE COURT: If you're relying on the representations

in the indictment, how is it that it would not be proper to ask

the witness about these representations mentioned in the

indictment?

MS. MURRAY: Well, I think first we would establish

whether he read the prospectus.

MR. KAMARAJU: Sure. I'm going to do that.

THE COURT: Yes. But if he answers yes, that's where

I'm asking.

MS. MURRAY: If he answers yes, it's fair game to ask

questions about certain of the language in the prospectus and

determine whether he had read it at the time. But what we're

concerned about is kind of the slippery slope of then going

into the sophistication and victim-blaming.

THE COURT: Well, did you read it? Let's say he says

yes. Then the next question is: Did you consider the risk

that was set out in the prospectus?

MR. FINKEL: One way that your Honor might want to

contend with this, and I know it's been done in other fraud

cases, is through a limiting instruction, which is simply

telling the jury that whether the witness or the victims were

sophisticated or not, were aware of risks that they avoided or

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relied on various disclaimers or not is not what's at issue

here. The questions are being asked only for the purpose of

assessing whether the representations that the witness

testified about, here, the representations about the guarantee

and the use of GT funds, whether those are material. I have

seen that done in other fraud cases.

THE COURT: Okay. We're going to take a pause, and I

want you to draft this instruction.

MR. KAMARAJU: I'll just note, your Honor, that

everything he just said is a proper subject of a jury

instruction, not a limiting instruction in the middle of

testimony.

THE COURT: I don't know that I agree with that.

MR. KAMARAJU: Well, your Honor, I'm not sure -- first

of all, your Honor did say that we can acquire the

sophistication of the investors because it goes into the

materiality analysis. So I just want to make sure that we're

clear on that.

I get the idea that we can't argue that the victims

are negligent or they should have done more. We're not

precluded from arguing or eliciting testimony that these are

sophisticated people. That's black-letter Second Circuit law.

That's the

Litvak

case. The

Litvak

case says sophistication of

the investors plays into it.

MR. FINKEL: That's a civil case.

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MR. KAMARAJU: No, it's U.S. v. Litvak.

So I don't -- because you have to judge the reasonable

investor standard by the investors who are in the market.

That's what the law is. So that's one point.

Two, I don't know how you get away from determining

the materiality of any individual statement taken outside of

the context of the larger document. There's no principle of

law that supports that. If a guy says he read -- not this

witness, but generally. If a person says they read a document,

and document -- one section of the document says this is how we

might use the money, and the other section of the document says

those are just examples of how we use the money, it goes to the

materiality analysis, your Honor.

MR. FINKEL: Your Honor, the

Weaver

case, which we

briefed and which your Honor ruled on directly addresses this.

And it prevents defense counsel from eliciting this sort of

testimony.

What happened in

Weaver

, if I recall correctly, was

essentially the defendant, the fraudster, was saying to

victims, You're going to make millions of dollars, all that

kind of stuff, right. Then they would receive documents that

would say something to the effect of, Don't listen to anything

I just said. A disclaimer.

And so the defense wanted to put in a disclaimer to

say, Look, you should have looked at that disclaimer, victim.

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You should have known, victim, that you shouldn't have listened

to the guy, the defendant, as to what he said.

Second Circuit said you can't do that. Why can't you

do that? Because fraud in a criminal context, there's no

reliance on it. There's an objective reasonable standard which

the jury will assess. But you can't -- defense counsel is

asking questions about -- this all came about because they are

asking questions about, Are you a good real estate broker? Do

you point your clients to specific details in the contracts?

Do you look over things?

That goes to whether or not they were assessing

disclaimers. That's not the issue. The issue is whether Guo's

statements made in these broadcasts were lies and whether,

based on those lies, they were material to the victims, and so

they sent money to Guo, and they did.

THE COURT: What does the prospectus say?

MR. FINKEL: The prospectus says a number of things.

One of the things that I think defense counsel is referring to

with respect to the indictment is how the money would be used.

For example, the prospectus doesn't say that the money

would be sent to a hedge fund in the name of Mr. Guo's son. It

says that the money would be used to essentially invest in GTV.

There is no guarantee in the prospectus, and I think that's

kind of what defense counsel is getting at, which is exactly on

all fours with the Weaver case. Because in the Weaver case,

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again, the defendant was saying things that victims relied on,

and were the reasons why the victim invested, and then later

got disclaimers. And so the Second Circuit -- sorry, your

Honor.

THE COURT: But do these documents contain

disclaimers?

MR. FINKEL: The prospectus?

THE COURT: Yes.

MR. FINKEL: I believe there are some disclaimers in

that document, yes, your Honor.

THE COURT: Like what?

MR. KAMARAJU: Like I'll give you an example. There's

a chart that they rely on that they put into the indictment

that said these are the contemplated use of proceeds. And then

there's language that says this list is illustrative, right,

which means it's examples, right. I'm allowed to elicit that

to materiality.

I'll just say one point on the

Weaver

case, your

Honor. Respectfully, you've already addressed this and you've

already noted that the government's description of

Weaver

precisely wrong. Because what they said in

Weaver

is that

while there is no reliance element and the defense cannot make

a reliance argument, they can point to those disclaimers for

purposes of the materiality analysis, which is what your Honor

has already found. So I don't know why we're revisiting the

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context in Weaver.

MR. FINKEL: And that's why too to obviate any

potential juror confusion, a limiting instruction would be

appropriate. And we'll draft one for the Court's

consideration.

THE COURT: All right. So that's what you'll do.

You'll draft and we'll pause.

MR. FINKEL: Thank you.

(Continued on next page)

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(In open court)

THE COURT: Members of the jury, we're going to take a

brief pause.

Remember that you're not allowed to discuss the case

amongst yourselves or with anyone else. Don't permit anyone to

discuss the case in your presence.

I'll call you back shortly.

(Jury not present)

THE COURT: You can step down.

Don't discuss the testimony.

THE WITNESS: Sure, your Honor.

(Witness not present)

THE COURT: Please be seated.

(Recess)

THE COURT: Please be seated.

Are the documents in evidence? The prospectus, the

other --

MR. KAMARAJU: I don't believe so, your Honor, no.

THE COURT: They are not in evidence. Okay.

So on the issue of materiality, it is certainly

material whether or not the witness read the documents. But

where you cannot go is into a question like: Shouldn't you

have heeded the warnings.

MR. KAMARAJU: Understood, your Honor. I don't intend

to ask any question like that.

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THE COURT: The proposed instruction is: When

considering witness testimony, please note that negligence,

carelessness, or gullibility on the part of the victims is no

defense to a charge of fraud.

MR. KAMARAJU: I'm sorry, your Honor. I should have

noted this. If you're going to use the word "victims," we

would at least ask you use the word "alleged victims."

THE COURT: I have not even stated whether I'm going

to use the instruction.

MR. KAMARAJU: No, I know, your Honor, and I apologize

for jumping in. I just -- when I heard you read it again, it

occurred to me that I missed that.

THE COURT: Clearly if I were to read the instruction,

I would use "witness" instead of "victims."

But why is it necessary to give this instruction now

as opposed to when I'm instructing the jury at the end of the

case?

MR. FINKEL: Your Honor, it's a correct statement of

law, and it absolves the jury from any confusion. And I think

the jury would reasonably be confused. They might be thinking,

I wouldn't have invested in this. I would have known that this

didn't make any sense. I would have known to read the

disclaimer and look at all the language. And that's what

laypeople who don't understand the fraud law that we all do

would expect.

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So this instruction, which is a correct statement of

law, resolves that issue, and I think appropriately

contextualizes the line of questioning that defense counsel has

advanced.

MR. KAMARAJU: Well, your Honor --

MR. FINKEL: It's also a long trial.

MR. KAMARAJU: Well, it is a long trial.

So your Honor is going to instruct the jury that they

should begin deliberations at the close of all evidence.

You're going to instruct them, I presume, as to the proper

elements of the law.

And so when they are considering this witness's

testimony, as long as anybody else, they will have the

appropriate law to guide them. There's no need to preview

government arguments about the law to the jury now, when this

is not a question, for example, of like is evidence being

offered for this purpose or this purpose. It ultimately goes

to the elements of the offense. And your Honor can address it

at the time that you address all the other elements of the

offense, which is when you instruct the jury as to the law, at

the close of evidence.

MR. FINKEL: It exactly is the kind of issue where the

evidence is being offered for a particular purpose. It's being

offered for the purpose of materiality. And a jury doesn't

know what all of this means.

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So what your Honor is doing is delivering to them a

correct statement of law so they can understand the evidence as

they sit through the trial. As I understand, looking back on

the briefing on this issue, defense counsel doesn't object

generally to the concept that negligence is not a defense. And

so we think your Honor instructing the jury of that is

appropriate so they understand how to use the evidence that

defense counsel is seeking to educe.

THE COURT: So I agree with Mr. Kamaraju that it is

not appropriate to give the instruction at this time.

But I want to talk about what you can and cannot ask.

You can ask whether he has read those documents. If

you get a no, it stops there. The inquiry stops there.

There's no "shouldn't you have."

MR. KAMARAJU: 100 percent, your Honor. I do not

intend -- if he says no, I'm not going to ask him more

questions about the document or should he have read it or

shouldn't he have read it.

THE COURT: Now, if he says yes, then you can ask:

Did you consider the statements made in those documents? But

you can't go on and then say: Well, shouldn't you have heeded

that warning.

MR. KAMARAJU: I do not intend -- and the questions

that your Honor is formulating, like "shouldn't you have," I

have no intention -- that was not -- I don't think I've asked

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one of those questions, but that was not my intention.

THE COURT: "Wouldn't a reasonable person have,"

"wouldn't you advise your client to," nothing like that.

MR. KAMARAJU: Okay, your Honor.

MR. FINKEL: Your Honor, if I may. And I understand

the Court's ruling. The problem is, is a victim saying that

they didn't read the documents, the implication that's left for

the jury is potentially, Well, they should have. And that's

not the correct statement of how -- that's not a correct

statement of law as to how this evidence should be considered.

THE COURT: People don't even read the instructions on

their iPhones.

MR. FINKEL: I know.

THE COURT: And so I think that average jurors would

not necessarily have the expectation that someone would read a

prospectus.

MR. FINKEL: So, your Honor, we don't know what the

jury is thinking obviously. And so the government's request is

just that the jury be instructed as to the law so they know how

to contextualize this evidence, that's all.

THE COURT: I think an instruction on this discrete

aspect of the law, this particular defense or lack of a

defense, is drawing attention to or supporting an argument of

the government instead of truly clarifying.

So let's bring the witness back and the jurors back.

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MR. KAMARAJU: Your Honor, I'm sorry, can I just have

one last verification?

THE COURT: Yes.

MR. KAMARAJU: If he says yes and I ask him, Did you

consider statements in the prospectus, am I allowed to point

him to particular statements in the prospectus?

THE COURT: Yes.

MR. KAMARAJU: Okay. Thank you, your Honor.

THE COURT: To the extent that he said he read them,

you may point him to those particular statements.

MR. KAMARAJU: Okay. So I --

THE COURT: And you may ask if you've considered them.

MR. KAMARAJU: I can put up a statement and say, Did

you read this?

THE COURT: Yes.

MR. KAMARAJU: And if he says yes, I can say, Did you

consider it? And if he says no, move on.

THE COURT: Right. But if he says, I did not read the

prospectus, then you cannot bring up those --

MR. KAMARAJU: Understood.

THE COURT: Yes.

Anything further, Mr. Finkel?

MR. FINKEL: No, your Honor. Rising because I think

the jury is about to enter.

THE COURT: Okay.

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(Jury present)

THE COURT: Would you have the witness return to the

stand, please.

(Witness present)

THE COURT: Remember, sir, that you're still under

oath. And please be seated.

And you may continue the cross-examination.

MR. KAMARAJU: Thank you, your Honor.

BY MR. KAMARAJU:

Q. Sir, I think when we broke, we were discussing a document

called the prospectus. Do you remember that?

A. Which document? Sorry.

Q. I think we referred to it as the prospectus. Do you

remember that?

A. Yes.

Q. Prior to sending money to VOG, did you read the prospectus?

A. I never received that.

Q. So you never received a copy of the prospectus. Okay.

Thank you.

Now, you testified on direct -- well, I'm sorry.

MR. KAMARAJU: Could we pull up Government Exhibit GX

C-63-T, please; June 2nd, 2020 video translation.

Could we go to page 9, please.

Q. I believe you testified about some part of this.

MR. KAMARAJU: But if we could blow up the box on the

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right that starts "We had an initial valuation of 200 million."

A. Yes, I see that.

Q. See that? All right.

And you see where it says: "the private placement

exceeded the highest expectations and raised $350 million";

correct?

A. Yes.

Q. So the private placement, in fact, raised more money than

was originally being sought, right?

A. That was part of VOG, yes.

Q. Well, the VOG money you testified was separate, right?

A. No, is part of this. Private placement.

Q. So the $350 million that's being referred to, that's part

of -- VOG is part of that?

A. No.

Q. Okay. It's separate, right?

A. Yes.

MR. KAMARAJU: Okay. And if we can go down on -- just

a little bit further down in that box. No, I'm sorry. If you

could just -- the sentence that starts: This is up to now this

figure and through, yeah. Thank you. Thanks very much.

Q. Okay. So you see it says: Let's say 350 million. 350

million does not include the 117 million from VOG, right? See

that?

A. The 350 doesn't include the 117, that's correct.

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Q. Right. The 117 million, which is coming in through VOG, is

separate from the 350 million that was raised as part of the

private placement, right?

A. No, it's not separate from the private placement; it was

included in the private placement. It's just separate fund,

350.

Q. Well, you testified on direct that there were a certain

number of seats, right?

A. Yes.

Q. There were 2,000 seats, right?

A. That was previously Miles mentioned it, yes.

Q. Well, I'm asking what your understanding was, sir.

A. When was introduced it to us as including me, Miles Guo

mentioned it private placement and also public placement, the

differences, then he explained it.

Private placement, if there were limitations, there

seats, 2,000 seats. Then if it exceeds that limitations, then

it will be kind of different placement.

Q. Okay. So the private placement could have had 2,000 seats.

Can I just ask you, when you say "seats," what do you

mean?

A. His original words translate to English called long chair

owe chair (ph).

Q. Well, sir, I'm sorry, I'm not asking for a translation.

I'm just asking what your understanding of the word "seat" is

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when you use it.

A. My understanding is called long position.

Q. Your understanding is it's a long position?

A. Yes.

Q. I'm sorry, I'm not familiar with that. What does that

mean?

A. That's a financial term for investment. People before the

private investments, those are people will invest and hold

their stocks for certain periods.

Q. Okay. So the seats are people who buy and hold their stock

for a certain period?

A. Yeah. And also they are considered as the first

investment, investors.

Q. Okay. So they are the first set of investors, right?

A. Correct.

Q. And that's -- there were 2,000 of seats available in the

private placement; correct?

A. Correct.

Q. And then there was a separate set of money that came in

related to VOG, right?

A. The separate money, the VOG, was for the people's

investment that was under certain amounts.

Q. I'm sorry, sir, but that wasn't my question, right. My

question is, is the money that came in through VOG is separate

from the money that you're talking about that comes in through

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the seats, right?

A. That I don't know.

Q. Okay. But you invested through VOG, that was your

understanding, right?

A. Correct.

Q. And you testified that you got the wire information from

Sara Wei; is that right?

A. That's correct.

Q. But you never directly corresponded with Sara Wei, right?

A. I messaged her; she replied.

Q. With the wire information?

A. Yes. So the emails.

Q. Now, we talked about how you had met with prosecutors

before, right?

A. Yes.

Q. Do you remember telling the prosecutors that you never had

direct communication with Ms. Wei?

A. I told them I contacted Sara Wei, yes.

Q. I'm sorry.

A. I told them I contacted Sara Wei direct.

Q. Okay. So there was somebody taking notes during that

interview, right?

A. I didn't take notes.

Q. I said there was somebody taking notes, right?

A. I didn't see who was taking notes.

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Q. I'm not asking if you saw who, I'm asking did you see

somebody taking notes, sir?

A. I don't know.

MR. KAMARAJU: All right. Can we bring up Government

Exhibit GX VO-80, please. I believe this is in evidence. So

we can publish it. And can we just blow up that first

paragraph.

Q. Okay. And do you see there's a name there, Lihong Wei

Lafrenz? It's in the fourth line down.

MR. KAMARAJU: There you go. Thank you, sir.

Q. Do you see that?

A. Yes.

Q. That's Sara Wei, right?

A. That's her legal name, right.

Q. Do you recognize this? This is the limited purpose agency

agreement that you signed with Ms. Wei; correct?

A. Yes.

Q. Okay. And this is in connection with your GTV investment?

A. Correct.

MR. KAMARAJU: Okay. The government offers GX -- I'm

sorry, the government. Apologies, your Honor.

The defense -- long afternoon already.

The defense offers GX VO-80 into evidence.

THE COURT: No objection?

MS. MURRAY: No objection.

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THE COURT: It is admitted.

(Government's Exhibit VO-80 received in evidence)

MR. KAMARAJU: Sorry about that.

BY MR. KAMARAJU:

Q. So just to clear it up, the name that's highlighted, that's

Sara Wei; correct?

A. Correct.

Q. And through this agreement you're designating Ms. Wei to be

your agent for purposes of buying GTV shares; correct?

A. Correct.

Q. You don't designate Mr. Guo for those purposes, right?

A. No.

Q. You don't have any contract designating any authority to

Mr. Guo over your purchases, right?

A. Not with him, no.

Q. I was just asking about him. Not with him, right?

A. Not with him.

Q. You don't have a farm loan agreement with Mr. Guo, right?

A. No.

Q. You don't have a G Clubs agreement with Mr. Guo, right?

A. I never receive a G Club agreement.

Q. Okay. So then you don't have one with him, right?

A. No.

Q. You don't have an agreement to buy H coin with Mr. Guo,

right?

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A. No.

Q. Okay. And you, in fact, never spoke directly with Mr. Guo

about buying H coin, right?

A. No.

Q. You never spoke directly with Mr. Guo about buying G Clubs,

right?

A. No.

Q. You never spoke directly with Mr. Guo about buying GTV

shares, right?

A. No.

Q. Now, there comes a point when there's a disagreement

between Mr. Guo and Ms. Wei; correct?

A. I'm not sure if it's a disagreement, words would be

accurate.

Q. You understood that they had a bit of a falling out, right?

A. Yes.

Q. And Mr. Guo made public statements about Ms. Wei; correct?

A. Yes.

Q. He encouraged supporters to contact law enforcement about

Ms. Wei, right?

MS. MURRAY: Objection, your Honor. Hearsay.

THE COURT: If you'll step up.

(Continued on next page)

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(At sidebar)

THE COURT: So why is it that these statements could

come in?

MR. KAMARAJU: Well, I'm not offering them for their

truth at all, I'm offering them for the fact that he said them

and the fact that he's inviting scrutiny from law enforcement

and public law filings, which is inconsistent with the idea

that he had a guilty intent at the time. If he was trying to

hide what he was doing, he wouldn't have told people to bring

the FBI in. They are not being offered for their truth;

they're just being offered for the fact that he's inviting that

to happen.

THE COURT: What was it that he said about Ms. Wei?

MR. KAMARAJU: He said a number of things about

Ms. Wei. But what I have in the 3500 material is that he asked

supporters to contact law enforcement, including the FBI, about

what Ms. Wei had done.

THE COURT: What was it that he claims she did.

MR. KAMARAJU: Stolen money from the farm loan

program.

MS. MURRAY: Your Honor, the defendant is welcome to

testify about that. We can't -- it's just not permissible to

back-door in the defendant's statements through this manner

about what he may or may not have said to people about Ms. Wei.

MR. KAMARAJU: It has to be offered for the truth to

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be hearsay. That's foundational. We're not offering it for

the truth.

THE COURT: What is it that if Mr. -- if the witness

is aware that the statement was made, how is it relevant to his

testimony?

MR. KAMARAJU: Well, he testified about the fact that

the money went -- he gave his money to Sara Wei so that Sara

Wei would make a GTV investment on his behalf. He just

testified he had an agency agreement with Ms. Wei to do that

for him.

Mr. Guo and many other people think that Sara Wei —

who, our understanding is, is going to be a witness at this

trial — stole the money. And my point simply is, is that if a

person who's involved in a fraud or is alleged to be involved

in a fraud says, Hey, FBI, come look at what I'm doing, that

suggests that they don't have a guilty conscience, your Honor.

And much of their --

THE COURT: I don't understand why it is this witness

has to testify about having heard that statement.

MR. KAMARAJU: Because he told the prosecutors about

it, your Honor. It's not as if I'm planning --

THE COURT: But what is the purpose -- how is it

relevant? Did he act upon the statement?

MR. KAMARAJU: He did actually act upon the statement.

THE COURT: How so?

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MR. KAMARAJU: He filed complaints with various local

law enforcement agencies.

THE COURT: And how is it relevant to whether or not

your client is guilty?

MR. KAMARAJU: Whether he filed them, I'm not arguing

that is relevant. What I'm arguing is the fact that Mr. Guo is

asking people to look at what's happening here is the exact

opposite of consciousness of guilt.

THE COURT: Right. But you're just trying to get that

statement in through this witness. The objection is sustained.

MR. KAMARAJU: Can I ask for the basis, your Honor?

Is it relevance or is it hearsay?

THE COURT: There's no question that it's hearsay.

MR. KAMARAJU: I don't mean to argue with the Court.

I just want to understand how it's being offered for the truth.

THE COURT: You want to get the statement in to show

that your client had an adverse relationship with Ms. Wei.

MR. KAMARAJU: No. I'm asking to get the statement in

to show that my client is not afraid of the FBI looking at what

he was doing.

MS. SHROFF: It's a state of mind.

THE COURT: Examining what she was doing.

MR. KAMARAJU: No. Because their allegation is that

Ms. Wei is a part and parcel of the GTV conspiracy.

THE COURT: Okay. So I don't know what the -- I don't

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know what her role is.

MS. MURRAY: So Ms. Wei operated a company; she was

one of the farm leaders. And that particular farm was used to

aggregate nonaccredited investors' money. So Miles Guo made it

available in violation of securities law to people who had less

than $100,000. And he said, Why don't you go to Ms. Wei, and

she'll aggregate all of your money, and it will look like a

legitimate investment from Voice of Guo that's above the

threshold. So another way to kind of evaded the securities

regulations.

We agree with your Honor this is not the witness to

bring in what Mr. Kamaraju is trying to bring in.

MR. KAMARAJU: But I still don't understand.

If their allegation is that Ms. Wei was part of

conduct that they're alleging is criminal on behalf of Mr. Guo,

the statement is not being offered for the truth and the

defense argument is, is that he's asking from sunlight to be

put on the conduct, which is inconsistent --

THE COURT: But why does it come in through this

witness?

MR. KAMARAJU: I'm not sure why it can't come in

through this witness, your Honor. I understand that there are

other witnesses that (indiscernible) may prefer that it comes

through the defendant. But I'm not aware of an evidentiary

objection that says it can't come in through this witness as

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opposed to some other witness.

MS. SHROFF: Or through multiple witnesses. That's

not an evidentiary objection.

MS. MURRAY: Your Honor, it's our view the Court has

ruled on this matter. I understand Mr. Kamaraju is just

continuing to litigate it. But we agree with your ruling on

this. The objection should be sustained. We should move on.

THE COURT: I'm going to sustain the objection.

(Continued on next page)

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(In open court)

THE COURT: Sustained. Go ahead.

BY MR. KAMARAJU:

Q. Now, sir, you testified before about the Himalaya Farms;

correct?

A. Yes.

Q. And there's a structure to those farms, right?

A. Yes.

Q. There are different positions within the farms, right?

A. Correct.

Q. So there's a farm leader, right?

A. Yes.

Q. And then the farm leader may have others who sort of assist

them; correct?

A. Correct.

Q. Did you have a position in any farm, sir?

A. My position was OBS streamer for the farm.

Q. OBS streamer for the farm.

A. Yes.

Q. Okay. What does "OBS" stand for?

A. It's a software platform name. It's used -- it's open

software, allow you to connect your computer and the cameras,

broadcast to designated location, like YouTube push it out to

it, or push it to other sources.

Q. Okay. And then above the farms comes the alliance, right?

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A. Yes.

Q. So all the farm leaders are part of the alliance, that's

your understanding, right?

A. Yes.

Q. And so they set policy for the farms, is that your

understanding?

A. Yes.

Q. And then above them is something called the Iron Blood

Group; is that right?

A. No, not above.

Q. Okay. I'm sorry. You explain it to me. I may have it.

Wrong.

A. Iron Blood Group was launched by Miles Guo. There were

three members at the beginning. Eventually expanded to a

larger group. All the member was selected by Miles Guo.

Q. Okay. But the group had some authority, right?

A. They have their roles.

Q. Sir, I'm not trying to trick you, but didn't you tell the

prosecutors that the Iron Blood Group had full authority to run

the farms?

A. Not run the farm.

Q. Okay. So what kind of authority did they have over the

farm, sir?

A. Iron Blood member will act as higher management group to

managing the farm leaders, and also they have the designated

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roles.

Q. Okay. So they each may have designated roles within the

Iron Blood Group, is that what you're saying?

A. Yes.

Q. So one of the members of the Iron Blood Group was called

Mulan, right?

A. Yes.

Q. Mulan is not her real name, right?

A. No.

Q. What's her real name?

A. Liya.

Q. And Ms. Wei was a member of the Iron Blood Group at one

point; correct?

A. Excuse me. You mean Sara Wei.

Q. Yes.

A. I don't recall that.

Q. Okay. How about the leader of the UK farm, he was a member

of the Iron Blood Group?

A. Yes.

Q. Okay. Now, you did more for the UK farm than just do

streaming; correct?

A. Correct.

MR. KAMARAJU: Actually, your Honor, I am about to

turn to a different subject. I just wanted to note the time

and see if your Honor wanted to continue.

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THE COURT: Well, if you're going to another subject,

then this would be an appropriate time to stop, even though

it's only 2:40 p.m.

MR. KAMARAJU: I will take credit for the five-minute

break, your Honor.

THE COURT: All righty.

So, members of the jury, we will stop our work for

today. You'll return tomorrow on time, as you did today, so

that you'll be able to walk through this door at 9:30 a.m.

Remember that you're not allowed to discuss the case

amongst yourselves or with anyone else. Don't permit anyone to

have any discussions in your presence. Have a good evening.

(Jury not present)

THE COURT: Sir, you may step out.

Don't discuss the testimony.

THE WITNESS: Yes, your Honor.

(Witness not present)

THE COURT: And you may be seated.

Is there anything that the parties want to raise

before we continue tomorrow morning?

MS. MURRAY: May we have a brief sidebar, your Honor?

THE COURT: Yes.

MS. MURRAY: Thank you.

(Continued on next page)

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(At sidebar)

THE COURT: I forgot to mention that the note that I

received from Alternate No. --

MS. SHROFF: Five.

THE COURT: Five yesterday, I made Court Exhibit No.

1. It came in at 12:10 p.m., and I dated the exhibit Friday,

May 23rd, 2024.

What's the issue?

MS. MURRAY: Yes, your Honor.

XXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXX

XXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXX

XXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXX

XXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXX

XXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXX

XXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXX

XXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXX

XXXXXXXXXXXX

XXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXX

XXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXX

XXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXX

XXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXX

XXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXX

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XXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXX

THE COURT: Fine with me.

MS. SHROFF: We have no objection.

MR. KAMARAJU: Yeah, that's fine, your Honor.

THE COURT: Anything further?

MS. MURRAY: We just ask to seal this part of sidebar.

THE COURT: And it is sealed.

MS. MURRAY: Thank you.

MS. SHROFF: Your Honor, does the Court want to do

anything with Juror No. 5? I know when we broke before the

weekend, the thought was to excuse him.

THE COURT: Oh, you're talking about Alternate No. 5?

MS. SHROFF: Yes, your Honor.

THE COURT: Oh, I don't recall our decision to excuse

him. Am I not recalling it correctly?

MR. KAMARAJU: That was at least my understanding. I

thought your Honor was -- because I thought we had a discussion

about how to excuse him without alerting the rest of the jury,

which is why we thought you had brought him back instead to not

tip off the jury. We may have misunderstood. That was our

understanding.

THE COURT: So is he even still here?

MS. SHROFF: He is here, your Honor.

THE COURT: All right. I'll excuse him.

MS. SHROFF: Thank you, your Honor.

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(In open court)

THE COURT: Just a reminder, counsel, I have

proceedings after this matter, so you'll need to clear the

tables.

(Juror present)

THE COURT: You're Alternate No. 5.

You may be seated.

JUROR: I am Alternate 5.

THE COURT: In light of your scheduling issues, I am

excusing you from jury service. Thank you for your willingness

to serve.

JUROR: Thank you, your Honor.

(Juror not present)

THE COURT: Anything further?

MR. FINKEL: Not from the government.

MR. KAMARAJU: Not from us, your Honor.

THE COURT: Thank you.

(Adjourned to May 29, 2024 at 9:00 a.m.)

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INDEX OF EXAMINATION

Examination of: Page

LE ZHOU

174Direct By Ms. Murray . . . . . . . . . . . . .

280Cross By Mr. Kamaraju . . . . . . . . . . . .

GOVERNMENT EXHIBITS

Exhibit No. Received

184 Stip 2, C26, C26-V, C63, C63-V . . . . . . .

185 W1005, W1005-V . . . . . . . . . . . . . . .

193 V2, 13, 15-16, 18-19, 22-23, 25-29, 31, . . .

59, 67-69, 77-78, 81-82, and

202 C-26-V, C-26-T, C-63-V, C-63-T . . . . . . .

234 32, 33, 34, 35 . . . . . . . . . . . . . . .

241 VO-107, VO-108 . . . . . . . . . . . . . . .

266 V0107 and V0108 . . . . . . . . . . . . . .

STIP-9 201 . . . . . . . . . . . . . . . . . .

W-58 236 . . . . . . . . . . . . . . . . . . .

VO-80 332 . . . . . . . . . . . . . . . . . . .

V0105 260 . . . . . . . . . . . . . . . . . . .

V0106 261 . . . . . . . . . . . . . . . . . . .

VI-151 220 . . . . . . . . . . . . . . . . . .

Original English Content(英文原文)

168
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O5S1GUO1                 
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 28, 2024 
                                        9:10 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 
     CLARE TILTON 
 
ALSTON & BIRD LLP 
     Attorneys for Defendant  
BY:  E. SCOTT SCHIRICK

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O5S1GUO1                 
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) 
Yu Mark Tang, Interpreter (Mandarin)

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O5S1GUO1                 
(In the robing room) 
THE COURT:  I called you in this morning because
during jury selection and the first day of trial, I have
observed a troubling pattern of discord between the attorneys
in this case.  In your interactions with each other, there have
been a number of instances of discourteous behavior, including
snippiness, bickering, sarcasm, eye rolling, and heavy sighs.
The tenor of the proceedings has been diminished by this
negative emotionalism.
As officers of the court, I expect that you will
observe courtroom decorum and abide by standards of
professionalism.  If you deal with each other in an
unprofessional manner in the presence of the jury, I will stop
the proceedings and direct that you only address the Court and
not each other, which will slow down the trial considerably.
You have an ethical obligation to advocate zealously,
but that zealousness must never cross the line into disrespect
of your adversaries.  Such conduct is an affront to the court's
dignity and may potentially disrupt and frustrate the trial.
I urge you to review the Supreme Court's decision in
Pounders v. Watson, 521 U.S. 982, 988 (1997), as well as 18,
United States Code, Section 401.  In other words, you need to
nip it in the bud.  Don't test me.
I received a letter from the prosecution this morning.
They seek to admit certain exhibits that are preserved copies

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O5S1GUO1                 
of online posts on G News and Gettr.  When do you want to use
those exhibits?
MR. FERGENSON:  Your Honor, we expect those will be
offered tomorrow.
THE COURT:  All righty.  So I will need a response
from the defense today.  When do you think you can get that to
me?
MR. SCHIRICK:  By 3:00, your Honor?
THE COURT:  All right then.  So I will address that
after I receive your response.  You're excused.
MS. SHROFF:  Your Honor, may we raise a matter that I
wish to raise prior to the start of the witness testimony?
THE COURT:  Go ahead.
MS. SHROFF:  Thank you, your Honor.
Your Honor, in the cross-examination last week, the
Court might recall I had difficulty with the exhibit numbering;
when I tried to pull up an exhibit from the defense side for
cross-examination purposes, it did not match up to the
numbering on the government's side.  I have reviewed 3500
materials in this case that is being given to the defense with
constantly changing 3500 numbers, so what used to be 3519-57
three days ago is a different document than what it is today.
I raise this as a seasoned lawyer to inform the Court that I'm
having trouble keeping up with the constant——I've never had a
case where the 3500 numbers change.  So that's one matter.  And

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I hope that we can have a set of documents——and I think
Ms. Tilton can speak to this more if need be.  But we are
having trouble reconciling the 3500 material being produced
with new Bates stamp numbers——with new 3500 numbers.  That's
one issue.
The second issue is, we're getting 3500 material, and
I know this is normal, but for example, I just walked in this
morning and there is a two-page, single-spaced 3500 production
of the witness that's about to take the stand.  So
respectfully, I know you don't take a break before lunch, but
either I need 20 minutes now to review it or I will need 20
minutes after the witness testifies to review it.  I did not
even have a second copy to go over it with Mr. Guo.  I imposed
upon your court to either run to the fifth floor to make a
copy, but I see that your law clerk helped me out and made an
extra copy.  But I need at least 20 minutes to just go over
that.  I'm sorry to raise this now, but it's——
MR. FINKEL:  Your Honor, over the weekend our
paralegal Ms. Loftus sent the defense, in response to questions
from the defense, updated exhibits and exhibit list that we
audited, which should resolve the issues that Ms. Shroff just
mentioned.  The 3500 that Ms. Shroff is mentioning just now is
3500 material that was generated this morning, so we gave it to
the defense as soon as it was completed.  But to help
Ms. Shroff out, we will call that witness later on and we'll

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call Le Zhou first so Ms. Shroff will have plenty of time to
review that 3500 material in advance of that witness testimony.
THE COURT:  So this is precisely the type of issue
that I should not be hearing about.  In 24 years I've never had
lawyers come to me and tell me that they can't agree on the
numbering of exhibits.  For goodness sakes, you have got to
cooperate on these purely ministerial matters.
So you'll have the break to review that document.
MS. SHROFF:  Yes, your Honor, but there's nothing we
can do about the numbering system.  We're happy to cooperate.
I believe Ms. Tilton is in constant contact with them.  This is
really her bailiwick.  She has, and I have, I think Ms. Loftus
has done the same.  But I don't think that this is a lack of
cooperation problem.  I don't know what the problem is.
Honestly, I've never had a case——I agree with you——where 3500
numbering is changed.  I've never had that.  A document that's
marked number 19 remains 19.
THE COURT:  Ms. Shroff, I've heard enough.  You know
how to fix this.  Fix it.
You're excused.
ALL COUNSEL:  Thank you, your Honor.
(Recess) 
(In open court; jury not present) 
THE COURT:  Good morning.  Would you make your
appearances, please.

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(Appearances noted) 
THE COURT:  Please be seated.
Please have the jurors brought in.
(Jury present)
THE COURT:  Please be seated.
Good morning, jurors.
THE JURORS:  Good morning.
THE COURT:  Welcome back.  Thank you for arriving on
time.  This way, you can walk into the courtroom at 9:30 and we
can get going and proceed in an efficient manner.  Thank you.
Would the prosecution call its next witness.
MS. MURRAY:  Thank you, your Honor.  We call Le Zhou.
THE LAW CLERK:  Please raise your right hand.
(Witness sworn) 
THE COURT:  Please state your name and spell it.
THE WITNESS:  My name is Le Zhou, L-E, Z-H-O-U.
THE COURT:  You may inquire.
MS. MURRAY:  Thank you, your Honor.
 LE ZHOU, 
     called as a witness by the Government, 
     having been duly sworn, testified as follows: 
DIRECT EXAMINATION 
BY MS. MURRAY:  
Q. Good morning, Mr. Zhou.
A. Good morning.

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Q. In what state do you live?
A. Florida.
Q. What do you do for work?
A. I'm a licensed realtor.
Q. Have you ever been a follower of Miles Guo?
A. Yes.
Q. Do you see anyone in the courtroom today that you recognize
from your time following Miles Guo?
A. Yes.
Q. Who?
A. I see Miles Guo.
Q. Can you describe him by where he's seated and an item of
clothing he's wearing.
MR. KAMARAJU:  We'll stipulate to identity, your
Honor.
THE COURT:  He has indicated the defendant.  Go ahead.
MS. MURRAY:  Thank you, your Honor.
Q. Do you see anyone else that you recognize from your time
following Miles Guo in the courtroom here today?
A. Yes.  A few.
Q. Can you identify them by their names or the names you know
them by?
A. There's a few followers sitting in the court on the
audience side, left side.  The name?  Yes.  Rachel Eva, Miles
7, Yongbing Zhang.  There's a nickname, "Heaven Spare No One."

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That's all I see.
Q. Thank you.  Mr. Zhou, where were you born?
A. China.
Q. When did you come to the United States?
A. 1998.
Q. Why did you come to the United States?
A. I came here to study, in——for college.
Q. After you moved to the US, where did you go to school?
A. I went to Miami-Dade College.
Q. And what did you study there?
A. I was a major in music education, and I played piano and
the trombone.
Q. Mr. Zhou, are you a supporter of the Chinese Communist
Party, or the CCP?
A. No.
Q. What experience, if any, has your family had in the past
with the CCP?
A. Our family suffered tremendously from the Chinese
government, both family on my mother and my father's side.
My——my maternal grandparents, they went abroad to
study.  My grandfather was soil engineer.  He worked building
roads, and at the time he worked for the Chinese government.
After he finished building road, he become a professor at a
university.  During cultural revolution and the Red Guards,
some of his students came to their houses, physically and

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verbally abused my both parents——grandparents.  So my maternal
grandmother couldn't take the shame of it, so she committed
suicide.  Before she did that, and she took my great
grandmother's life, because she thought no one would take care
her.  And so that, my maternal parents just——the families fall
apart.  My mother was only 16 at the time.
My father's, my grandparents' side——we used to own
business as regular grocery store.  We have a small plaza.  The
government, during Second Sino-Japanese War, they came to ask,
they would take our assets to help the country.  They said
they're going to borrow it, but it took majority of the assets,
left little bit for the family to survive.  My father has nine
sisters and brothers, but that is not enough to feed all the
family.  So two of the children, was forced to give away.
That's——that's my both parents, how they suffered from
this government.
And there's also one big impact, almost not to have me
to live, was one child, one——one child, one policy in China.
It was implemented in 1980.  At the time, my mother was already
seven months' pregnant, and my parents wanted to have me
and——but the government wanted to do a forced abortion.  So my
parents——my mom went hiding while my dad was reasoning with the
government.  In the end, he made a deal that by lowering my
both father's salaries and also to give up the newborn baby's
welfare, which is food, milk, I don't get that, so they would

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spare my life.
So——and also one experience I personally witnessed,
when I was 9 years old——that's 1989——the student protests
happened Beijing, also happening in my hometown as well.  At
the time we lived in apartment, very close to our hometown, the
government square, where the student protests happened.  So we
were quarantined at the house, not allowed to leave the
community, and we were——at a time we heard outside shouting,
very loud.  So I used to live on the first floor.  That day,
when we heard outside a lot of protests, shouting, and I went
up to the eighth floor to my parents' friends' house.  Their
balconies are facing directly to the streets.  When I walked,
walk up to there, at a balcony, I saw, right near a bus stop, a
female student was covered, someone——riot police used a sandbag
cover her, just yank her away, and two other just jump up and
beat her up.  Then later, I move my——aside to nearby, very
close, just looked down; there's a mall, one-story mall.  There
were some protestors climb up the first floor of the roof.  And
they were throwing some objects into the crowd.  Then we hear
loud bangs, then I saw the tip of the concrete wall, with the
rooftop, the dust just smashing, shooting the air.  We heard
people shouting, "Shots fired, shots fired."  We were all
scared.  We just quickly got inside our house.
So that's——that's the fear we felt for——and we know
the regime is cruel.

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Q. And how, if at all, did those experiences affect your view
of the Chinese government?
A. The government is not——is untrustworthy.  Their cruelty and
brutality, it's unimaginable.
Q. Mr. Zhou, you mentioned that you had been a follower of
Miles Guo.  When did you first learn about Miles Guo?
A. Back in 2017, earlier, February.
Q. And how did you learn about him?
A. I watched YouTube, while he's broadcast.
Q. What did you see on YouTube about Miles Guo in 2017?
A. At the beginning, Miles Guo was doing a broadcast called
Safety Announcement.  So I was just curious who this person
was.  Then I——that's how I first watched the videos.
Q. And before watching that video had you heard of Miles Guo?
A. No.
Q. Did you continue to watch his videos after that first time
that you saw him in 2017?
A. Yes.
Q. What, if anything, caught your attention about his
broadcast?
A. Miles Guo introduced himself, then we learned he's a
self-made billionaire.  But he escaped the Chinese government's
persecutions, and he escaped to the United States, looking for
protection.  And he also started talking about corruption, the
Chinese high official corruptions.  He has classified

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information; he will expose their corruptions.
And I also learned that he living New York, Manhattan.
He has——he bought his luxury hotel in New York called
Sherry-Netherland Hotel.  And also he introduced his family
back home.  He has a big family, near a hundred people in his
family; and his wealth, the family owns $20 billion networks
and he owns private jets, luxury yachts, over hundred race
car——luxury cars.  Also, at the time, he's well dressed in his
broadcast, seemed very knowledgeable, well spoken, and he talk
about a lot, his knowledge on cultural.  And even sometimes a
lot of time impressed me was he mentioned he has bodyguards,
24/7, and he has a legal team.  Sometimes he mentioned
he's——the information he holds, or he has, he will bear the
legal responsible for what he talk about.
Q. The information that you just provided, was the source of
that information Miles Guo himself during those broadcasts?
A. Yes.
Q. Did there come a time when Miles Guo launched a
whistleblower movement?
A. Yes.
Q. How did you learn about that movement?
A. Because I started watching his videos, and I know the
movement 'cause he called himself a whistleblower.
Q. What, if anything, was the purpose of Guo's whistleblower
movement?

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A. Whistleblower movement was to expose Chinese officials'
corruptions.
Q. What actions, if any, did Guo encourage whistleblower
followers to take to combat the CCP corruption?
A. At the time he used——using social media, we become
followers of his social accounts.  Of course I learned some of
the corruption he mentioned in his broadcasts.  He encouraged
us to spread words.  Beginning, my action was just following
everyone else, retweets, or sometimes repost while he talk
about it, just spread into other——I had created a Twitter
account to help to spread the words.
Q. What, if anything, did Guo say about how people could join
the whistleblower movement and become followers?
A. Beginning, he has——had his Twitter accounts, people can
follow him, and also, at the time, there were few very activist
followers appear on the social media.  There would also reveal
their identity, face, and join Miles's broadcasts.  At the time
there were one follower named Sara Wei.  She created a group
called Voice of Guo.  Then there was a——people can also join
there, also that means join the movement.  So I joined that
group.
Q. Was Voice of Guo also called VOG at times?
A. Yes.
Q. How, if at all, did the followers communicate with one
another?

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A. At the time we have software we used for everyone to
communicate.  It's called Discord.
Q. Can you describe for the jury what Discord is.
A. Discord is a free software, allow user to create channels,
which is like chat rooms.  The chat room then also you can
create subchannels for any other categorized purposes.  The
software, you're able to let users to join using link, and you
can send messages, share messages, pictures, videos, files.
And you can also start voice meetings in the——in the group.  So
when I joined, it was categorized, and the part I remember was,
there's subchannels as a——so they create a subchannel as a
working group, as a task——task force, for certain things we
want to do.
Q. Did you and the other followers use your real names in
those Discord chats?
A. No.
Q. How, if at all, did you identify yourselves?
A. I had created my user name as Coffee Cantata, then use
Chinese two words, Wen Lu (ph).  That was my hashtag.
Q. And did other followers similarly use aliases or handles
when they communicated with one another?
A. Yes, mostly at the time everyone has their own nickname.
Q. By the way, what other names, if any, do you know Miles Guo
by?
A. Seven Brothers, and also Ho Wan Guo; that's the Cantonese

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pronunciation.
Q. Mr. Zhou, are you familiar with the Rule of Law
organizations?
A. Yes.
Q. What are those?
A. Rule of Law was created by Miles for——it was a charitable
organization.
Q. Around when were those Rule of Law organizations launched?
A. In 2018.
Q. And how did you hear about them?
A. It was publicly announced during press conference.  
MS. MURRAY:  Your Honor, at this time I would like to
offer a stipulation between the parties.  This is Government
Exhibit Stip 2.
THE COURT:  So I just want to remind the jurors what a
stipulation is.  A stipulation is an agreement between both
sides to present evidence to the jury without calling a witness
to testify about the subject matter.
You may read the stipulation.
MS. MURRAY:  Thank you, your Honor.  This is a
stipulation regarding web pages and videos.
The parties stipulate that in the chart that is
contained within this exhibit, which is Government Exhibit Stip
2, columns A, B, and C accurately list the following
information:

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The government exhibits listed in column A are
authentic copies of web pages that were preserved from the
internet.  If a web page contained a video that was also
preserved, the associated video is designated with a V in the
government exhibit name.  For example, GX C20 is a preservation
of a web page, and GX C20-V is a preservation of the video that
was on that web page.
Column B in the stipulation lists the web address or
url of the web page that was preserved.  
And column C lists the date on which the web page was
preserved.  
And at this time, your Honor, there is a chart
contained within this exhibit which is now admitted.  I would
like to just note two of the exhibits noted within this chart.
One is GX C26 and corresponding GX C26-V.  Those are YouTube
videos that were preserved, and they are dated July 15, 2020.
And then GX C63 and GX C63-V; again, YouTube video from a web
page, and that's dated November 25, 2020.
THE COURT:  And you're moving to admit that.
MS. MURRAY:  Moving to admit those two exhibits from
within this chart and moving to admit the stipulation at this
time.
THE COURT:  They're all admitted.
MS. MURRAY:  Thank you.
(Government's Exhibits Stip 2, C26, C26-V, C63, C63-V

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received in evidence) 
BY MS. MURRAY:  
Q. Mr. Zhou, directing your attention to November of 2018, did
there come a time when you watched a livestream of an
announcement relating to the Rule of Law?
A. Yes.
Q. Do you recall on what website you watched that
announcement?
A. It was on a livestream.
Q. The website is named Livestream?
A. That was a link.  It's a——livestream will push out the
channel, the broadcast, but the channel was under Rule of Law
Foundation.  The livestream, I believe the website associated
was Vimeo.
MS. MURRAY:  Your Honor, we would move to admit one
more exhibit from GX Stip 2.  That's GX W1005 and GX W1005-V,
and that's YouTube, and it was preserved on February 9, 2024.
THE COURT:  They're admitted.
(Government's Exhibits W1005, W1005-V received in 
evidence) 
MS. MURRAY:  Thank you. 
Ms. Loftus, could we now publish what's admitted in
evidence GX W1005-V.
BY MS. MURRAY:  
Q. Mr. Zhou, do you recognize this video?

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A. Yes.
Q. Have you viewed it before?
A. I watched it earlier and live.
Q. And there's an insignia on the top left here.
MR. KAMARAJU:  Your Honor, I apologize.  Could we have
a brief sidebar on this.
THE COURT:  All right.
(Continued on next page)

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(At the sidebar) 
MR. SCHIRICK:  Your Honor, the defense just wanted to
be clear that the stipulation was just to the online
preservation.  We hadn't stipped to moving it into evidence.
So we have an objection to hearsay.  It's going to——they're
going to play a video of Mr. Bannon speaking at this press
conference.
THE COURT:  So I don't understand what you're saying
was not admitted through the stipulation.
MR. SCHIRICK:  The stipulation, your Honor, was just
to authenticity.  It was to the video having been pulled down
from the source.  The stip did not go to the admissibility.
THE COURT:  Go ahead.
MR. FERGENSON:  That's correct, your Honor.  It's just
authenticity in the stip.  I understand the objection is to
hearsay.  We're not offering this video clip for the truth of
what Mr. Bannon is saying in it; we're offering it for the
falsity of what he's saying.  And it's a clip from the joint
announcement of the Rule of Law Fund, where both Mr. Guo and
then Mr. Bannon speak, and this is a clip from Mr. Bannon's
speech.
THE COURT:  So are you seeking to admit it because
it's an admission?
MR. FERGENSON:  No, because it's not offered for its
truth.  We're offering it for the fact that it was said.

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MR. SCHIRICK:  Your Honor——
THE COURT:  For the effect on the listener?
MR. FERGENSON:  Correct, your Honor.  These are launch
videos that victims watched and believed.
MR. SCHIRICK:  And your Honor, what Mr. Bannon is
going to say in that video that the government is going to show
the witness and the jury is a statement by Mr. Bannon that
Mr. Guo was going to start the Rule of Law Foundation with a
hundred million dollars.  They contend that that was a
representation that it was his own money.  So it is in fact
offered for the truth of that statement, that that's in fact
what Mr. Bannon said and that that was, in effect, a
misrepresentation.  So I'm not sure that there is not——there
are nonhearsay issues here.  And——
THE COURT:  Are you suggesting a curative instruction?
MR. SCHIRICK:  I think we do need a limiting
instruction, your Honor.  But I think there is a risk of 403
with the jury here as well.
THE COURT:  I would expect that numbers of these types
of statements, video or otherwise, are going to be propounded
by the prosecution; am I correct?
MR. FERGENSON:  Yes, your Honor.
THE COURT:  So I'm looking for an application for a
limiting instruction.
MR. SCHIRICK:  We would ask, your Honor, that the jury

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be given a limiting instruction that this is not a
statement——that Mr. Bannon's statement is not a statement
attributable to Mr. Guo.
MR. FERGENSON:  We would object to that.  That's not
necessary for the admission of the statement.  We would be fine
with a limiting instruction that said these statements are not
being offered to prove the truth of the matter asserted.
That's the definition——
MR. KAMARAJU:  Your Honor, since this is just an
authenticity stip, I think the prosecution has to lay the
foundation in order to introduce this through the witness.  I
know this one has already come in, but I think as these videos
are coming in, I think the proper format is to do that first.
THE COURT:  Absolutely.
MR. KAMARAJU:  Thank you, your Honor.
THE COURT:  Okay.
(Continued on next page)

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(In open court) 
BY MS. MURRAY:  
Q. Mr. Zhou, there's a logo on the top left of this
screenshot.  Do you see that?
A. Yes.
Q. What does that read?
A. Guo Media.
Q. What is Guo Media, or what was Guo Media at the time?
A. It was earliest symbol that was created for this movement.
There was a media channel.  That's the name for it.
Q. And what type of content, if any, was posted on Guo Media
at this time?
A. At this time, this was that press conference happening in
New York.
MS. MURRAY:  Ms. Loftus, if we could please play this
video.  This is Government Exhibit W1005-V1.
THE COURT:  Is it now that you're looking for me to
give the limiting instruction?
MR. KAMARAJU:  Yes, your Honor.
THE COURT:  Members of the jury, this video is not
being offered by the government for the truth of what is stated
in the video.  Keep that in mind as you watch it.
MS. MURRAY:  Thank you, your Honor.
(Video played) 
BY MS. MURRAY:

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Q. Mr. Zhou, do you recognize the individual depicted in this
video?
A. Yes, I do.
Q. Who is it?
A. Steve Bannon.
Q. What role, if any, did Steve Bannon have with the Rule of
Law?
A. He was the co-founder of the Rule of Law Foundation.
Q. What, if anything, did you learn from the Rule of Law
livestream that you saw in 2018 about whether Miles Guo was
donating money to the Rule of Law?
A. The video I learned from was the conference that talk about
this announcement and also talk about this fund will use to
help Chinese dissidents and to have them to financially help,
and also help them with legal support, and to also use the fund
to investigate mysterious business deaths.
THE COURT:  I'm sorry.  Investigate mysterious what?
THE WITNESS:  Business——persons' deaths.
THE COURT:  Deaths.  All right.  Go ahead.
Q. Did you have an understanding of whether the Rule of Law
Fund would be funded with a certain amount of money at its
inception?
A. Yes.  There was hundred million dollars.
Q. Now you said from your viewing of Miles Guo's broadcast
that at that time you had the impression that Miles Guo was

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wealthy; is that correct?
A. Yes.
Q. At the time that you viewed this launch video in 2018, did
you believe that Miles Guo could donate a hundred million
dollars to the Rule of Law charity?
A. Yes.
MS. MURRAY:  We can take that down, Ms. Loftus.  Thank
you.
Q. Did there come a time when you donated to the Rule of Law?
A. Yes, I did.
MS. MURRAY:  Your Honor, may I approach the witness?
THE COURT:  You may.
MS. MURRAY:  Thank you.
I've handed the witness a binder that contains
exhibits that are marked for identification as GX C26,
GX C63-V1 and V4, GX CT209 and 211, GX VI150-160 and their
corresponding translations, GX VI180 through 190 and their
corresponding translations, GX V02, 13, 15-16, 18-19, 22-23,
25-29, 31, 59, 67-69, 77-78, 81-82, and 84, as well as
GX W1005, GX W56-57 and GX W59.
BY MS. MURRAY:  
Q. And Mr. Zhou, I'd ask if you would briefly flip through
that binder and let me know if you recognize the exhibits that
are in that binder.
A. Yes.

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Q. Are those documents——are some of those documents, documents
that you provided to the government in connection with your
time when you were a follower of Miles Guo?
A. Correct, yes.
Q. Have you reviewed all of the exhibits that are contained
within that binder?
A. Sorry.  At this moment?
Q. Previously, before today.
A. Before, yes, all.
MS. MURRAY:  Your Honor, at this time the government
would move to admit Government Exhibits GX V2, 13, 15-16,
18-19, 22-23, 25-29, 31, 59, 67-69, 77-78, 81-82, and 84.
THE COURT:  They are admitted.
MR. KAMARAJU:  No objection.
MS. MURRAY:  Thank you.
(Government's Exhibits V2, 13, 15-16, 18-19, 22-23, 
25-29, 31, 59, 67-69, 77-78, 81-82, and 84 received in 
evidence) 
MS. MURRAY:  Ms. Loftus, can you please publish what's
now in evidence as Government Exhibit VO27.
If we could zoom in on the top portion.
BY MS. MURRAY:  
Q. Mr. Zhou, what is this?
A. That's my receipt, donation receipt.
Q. And what date is this document?

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A. May 18, 2019.
Q. What donation does this reflect?
A. This is donation to Rule of Law Foundations in $500, my
first donation.
Q. Why did you donate to the Rule of Law in 2019?
A. Yes, because I'm part of the follower, I want to help any
of the dissidents, as many as I can, not just follow Miles Guo
to help them, so that's the same goal I wanted to help.
Q. If Miles Guo had not donated a hundred million dollars to
the Rule of Law, if you had known that at the time, would that
have been important to you?
MR. KAMARAJU:  Objection to form.
THE COURT:  Overruled.  You may answer.
A. Yes.
Q. Why would it have been important to you at that time if you
had known that Miles Guo had not donated a hundred million
dollars to the Rule of Law?
A. Because there's a lot of people that need help, Chinese
people, there's a lot of dissidents.  Me alone, 500——I can do
as much as I can, but a hundred million dollars, that can help
a lot of people.
MS. MURRAY:  We can take that down, Ms. Loftus.  Thank
you.
Q. Mr. Zhou, did there come a time when you volunteered for
Miles Guo and his whistleblower movement?

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A. Yes, I did.
Q. Around when did you begin to volunteer?
A. In 2017, couple months I followed, I start following, just
retweeting when Miles Guo started, and later I also volunteered
to transcribe Miles Guo's videos.  I also did translation and
video editing, and I also helped the streaming services for the
movement.
Q. Who, if anyone, assigned that volunteer work to you?
A. From beginning, from the VOG, there were some volunteer
groups, they give me the transcript work to do; then later, the
work assigned from farm management teams.
THE COURT:  What do you mean by transcript work?
THE WITNESS:  Yes, your Honor.  Transcript means, most
of Miles Guo's video, it's in Chinese speaking.  Now there's
not a subtitle.  So we would have to create the subtitles.
That's transcript.  I would listen the video, take down what
Miles Guo said in Chinese, then type it into a Chinese, become
a subtitle.  
Q. And when you say farm, you mentioned that some of the work
was assigned to you by farm leaders.  Can you explain to the
jury what you mean by farm.
A. Farm is a adjective.  It's quotation for work, but the real
meaning is refer to offices, and Miles Guo mentioned, when the
whistleblower established, he wanted to have 50 farms, in
different regions in——throughout the world, become the

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subdivisions, offices.
Q. In what way, if any, were the farms kind of organized under
one unit?
A. The farm organized——there are person we call farm leader.
Most of the people were——beginning were very active as a
follower, follow the movement, follow movement.  Those people
are some——most of them are designated by Miles Guo to become
the farm leaders.  So there were farm, once it's created, in
different countries, regions, then also gather people locally
or online to have their own groups, but all under one of the
headquarter, which is farm called Himalaya Global Alliance to
managing those farms.
Q. Who, if anyone, was in charge of the Himalaya Global
Alliance?
A. At the time Global Alliance was only a few people and Miles
Guo was one.  There are two——few peoples.  Then they call
themself Iron Blood, a group.
Q. Why, if at all, did the leaders of the Himalaya Global
Alliance, Miles Guo and the others, call themselves the Iron
Blood group?
A. There were individuals selected by Miles, to give titles,
because Himalaya Global Alliance form with a designated
chairman, secretary general, and there's a few people that
Miles Guo designated those people.  Miles Guo said, those are
brothers because those brothers are willing to sacrifice for

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him and shed the blood with him and for this movement.  So that
name was formed from that.
Q. Returning to your volunteer work that you did for the
movement, were you paid for that work?
A. No.
Q. You mentioned that you were involved in, among other
things, streaming.  On what website or websites did you stream
content?
A. On streaming, I did YouTube, and also on Gettr and GTV.
Q. What is Gettr?
A. Gettr is a——a social platform created by Miles Guo.  It's
similar to Twitter.  It's just like Twitter features.  You
share your posts and people can follow, retweet.
Q. What is GTV?
A. GTV, it's a website that similar act as YouTube, allow you
to post and the livestreams, post videos.
Q. And who, if anyone, was in charge of GTV?
A. In charge of GTV, I don't know.
Q. Whose company, if anyone's, was GTV?
A. Oh, GTV was owned by Guo Media.
Q. And who owned, in turn, Guo Media?
A. That, I don't know who owned the company.
Q. Focusing on GTV for a moment, what, if anything, at that
time, in 2018, 2019, did Miles Guo say about GTV?
A. Miles——GTV here introduced, and he called out for

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investment that asked people who like to invest into GTV.
Q. Around when did Miles Guo offer an investment opportunity
into GTV?
A. Earlier 2020.
Q. Directing your attention to March of 2020, did you
participate in a Guo broadcast regarding that GTV investment
opportunity?
A. Yes, I did.
Q. What, if anything, did Guo ask his followers about their
interest in investing in GTV during that broadcast?
A. I remember I watched the video live when it was broadcast.
Miles Guo was calling people who like to invest in GTV.  He
mentioned if you like to invest in $10,000, raise your hand in
the chat group by posting of the emoji, icon, as your intent.
He also asked, let me see who wanted to invest hundred thousand
dollars using two of the emoji as your intent.
Q. And during that broadcast what level of interest, if any,
was there from the followers in investing in GTV?
A. I sent one emoji as for intent for $10,000.
Q. From your viewing of that live broadcast did other
followers similarly indicate their interest in investing in
GTV?
A. Yes, there were a lot of one emoji for 10,000 and also few
a hundred thousand dollars investment that people putting two
emojis.

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BY MS. MURRAY:  
Q. Now, directing your attention to April 21st of 2020, did
you watch a pre-recorded broadcast that Guo streamed about the
GTV investment opportunity?
MR. KAMARAJU:  Objection to form, your Honor.  She's
testifying.
THE COURT:  You can restate the question.
Q. Directing your attention to April 21st of 2020, did you
watch any broadcasts on that day that were relevant to GTV?
A. Yes.
Q. Did those include a broadcast of Miles Guo?
A. Yes.
Q. What, if anything, was the subject of what Miles Guo was
discussing during that broadcast?
A. Yes.  I remember I got a share link for that.  Miles Guo
mentioned the GTV.  First he mention any investment has risk.
Then for any investor you will make your own judgment.  Then he
talk about the GTV.  We know that's the mention based on his
part to talk about GTV investment.  He mention about the GTV
how become today.  There's a breakthrough because GTV has been
targeted, he mentioned target by CCP, hacking, a lot of hackers
trying to take down.  The GTV was pulled us off, it's not easy.
But he mentioned that GTV future forecasts, this is a 
platform that's intended for Chinese dissidents have a voice, 
freedom of speech.  We're the only one; no other platform.

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And he mentioned this, as we all see, GTV future 
growths.  From the current six people online at the same time, 
but eventually will grow to thousands people doing the 
broadcast together, the skill of it.  And so I remember that 
video also post contact information, his personal contact 
information for the investment.  If anyone want to invest, can 
direct contact. 
Q. When you say his personal contact information, to whom are
you referring?
A. Miles Guo.
Q. So in that video, Miles Guo provided his information for
people to contact regarding an investment?
A. Yes.
Q. What, if anything, did Miles Guo say in that video about
what you would get in exchange for investing in GTV?
A. Will get stocks, GTV stocks.
MS. MURRAY:  Your Honor, at this time I would like to
offer a stipulation between the parties.  This is Government
Exhibit STIP-9.
The stipulation reads that the parties stipulate and 
agree that in the below chart which is contained in this 
exhibit, the exhibits listed under column A contain audio or 
text in a foreign language; and in the chart that's contained 
within this stipulation, the exhibits listed under column B are 
true and accurate translations of the audio or text contained

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in the exhibits listed under column A.  The stipulation further 
stipulates and agrees that the stipulation, as well as the 
government exhibits listed under column B — those are the 
translation and transcript stipulations — may be received into 
evidence as government exhibits at trial. 
THE COURT:  The stipulation is admitted.
(Government's Exhibit STIP-9 received in evidence) 
MS. MURRAY:  And with respect to the particular items
contained within the chart, at this time the government would
move to admit GX C-26-V and its corresponding GX C-26-T, which
is the translation and transcription; as well as GX C-63-V, and
its corresponding GX C-63-T, which is the transcription and
translation.
THE COURT:  No objection?
MR. KAMARAJU:  No.  I would just ask the government to
go ahead and just admit all the exhibits that are in the stip
for efficiency.
MS. MURRAY:  Sure.  We would then move to admit all of
the exhibits contained within the chart that's in Government
Exhibit STIP-9.
THE COURT:  They are admitted.
MS. MURRAY:  Thank you.
Ms. Loftus, can you please pull up Government Exhibit 
GX C-26. 
Just a moment, your Honor.

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(Counsel conferred) 
MS. MURRAY:  Your Honor, I would like to withdraw the
request to admit all of the items contained within this
stipulation.  The parties' agreement was to admit certain of
the translations, but not the full videos listed in column A.
So I would like to withdraw the request to admit 
everything that's noted within the chart.  At this time I would 
just move to admit the two particular exhibits that I had 
mentioned. 
THE COURT:  All right, then.  So those items that were
admitted are not admitted, and what you're requesting to admit
now is admitted.
MS. MURRAY:  Thank you, your Honor.
So just for clarity for the record, what I'm seeking 
to admit is Government Exhibit STIP-9, which is the 
stipulation; Government Exhibit C-26-V and C-26-T, and 
Government Exhibit C-63-V and C-63-T. 
THE COURT:  They are admitted.
MS. MURRAY:  Thank you.
(Government's Exhibits C-26-V, C-26-T, C-63-V, C-63-T 
received in evidence) 
MS. MURRAY:  All right.  Ms. Loftus, if we could
please put up Government Exhibit C-26.
BY MS. MURRAY:  
Q. Mr. Zhou, looking at this, do you recognize this video?

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A. Yes.
Q. And up in the top left there is a logo and insignia.  Do
you recognize that?
A. Yes, I do.
Q. What is it?
A. GTV logos.
Q. Did you watch this video when it was posted online in April
2020?
A. No, it wasn't posted online when I watch it, so I share a
link.
Q. And who, if anyone, shared the link with you to the video?
A. One of the farm members.
Q. When you say the link was shared, how was it shared with
you?
A. I shared it on the telegram, our working -- the farm
working channels.
Q. So that's over phone application; is that correct?
A. Yes.
THE COURT:  What do you mean by "telegram"?
THE WITNESS:  Yes, your Honor.  
Telegram is another social media software.  It's more 
like you can allow you instant message, you can do it as 
individual one-on-one or you can also have a group chat.  And 
there you able -- also you can share your files, pictures, 
links, videos, etc.

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MS. MURRAY:  Ms. Loftus, can you please play this
video from the beginning up until 41 seconds.
(Video played) 
MS. MURRAY:  Thank you.  We can take that down.
BY MS. MURRAY:  
Q. Mr. Zhou, what, if anything, did Guo say during that video
that was broadcast about the amount of stock that one would
receive in exchange for their GTV investment?
A. I remember was the GTV stock in total was about to issue 20
million to 200 million stocks.
Q. And what, if anything, did he say about how much stock
somebody would get for the money that they invested personally?
A. One dollar per share.
Q. Did there come a time when you invested in GTV?
A. I'm sorry, would you -- could you please repeat the
question.
Q. Sure.  Did there come a time when you invested in GTV?
A. Yes, I did.
Q. When was that?
A. I invested end of the May 2020.
Q. And how much did you invest?
A. I send two payments total for $31,300.
Q. Where did you send your money for that GTV investment?
A. I send it through VOG, Voice of Guo, the channel which
control by Sara Wei.

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Q. Why did you send your GTV investment to VOG or Voice of
Guo?
A. Because my investment is less than $100,000, and also Sara
was designated person also can take the GTV placement, private
placement.
Q. Can you explain for the jury how, if at all, it was
relevant that your investment was below $100,000?
A. Could you please be more specific.
Q. Sure.  So I believe that you said because your investment
was below $100,000, you sent it to VOG; is that correct?
A. Yes.
Q. Who, if anyone, directed you to send your investment which
was below $100,000 to VOG?
A. Because the first GTV Miles Guo mentioned about the GTV
placement, they were giving out only 2,000 seats.  There is a
head count, it's limitation on there.  The limitation then the
people can -- minimum you can invest $100,000 up to all the way
to millions, million dollar.  But it's limited seats.  And if a
lot of people, especially not qualified for the seats or less
$100,000, but we can have this other company to invest on our
behalf to acquire the GTV stocks.  So that was -- I was -- I
understand myself my investment is not qualified with the
seats.  And it's not exceeds over $100,000, so I just went
through the VOG, ask for the investment.
Q. So at that time was it your understanding that VOG invested

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on your behalf and on behalf of others in GTV?
A. No, they are --
MR. KAMARAJU:  Objection, your Honor, to form.
THE COURT:  Sustained.  Don't lead.
Q. Did you have an understanding at the time in whose name
your money was being invested?
A. GTV Media.
Q. And for purposes of the shares, whose names, if anyone's,
would be on the shares that you spent your money to invest in?
MR. KAMARAJU:  Objection to form.
THE COURT:  If you'd rephrase, please.
MS. MURRAY:  Sure.
Q. Mr. Zhou, you mentioned that you invested your money
through VOG; is that correct?
A. Yes.
Q. What arrangement or legal agreement, if any, did you enter
into with VOG?
MR. KAMARAJU:  Objection to form.
THE COURT:  Did you enter into a legal agreement?
MS. MURRAY:  Thank you.
Q. Did you enter into a legal agreement with VOG?
A. Yes.
Q. Can you describe that legal agreement to the jury, please.
A. It was agent agreement.  Sara Wei would act as my agent to
take my investment for the GTV investment.

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MS. MURRAY:  Ms. Loftus, can we please publish
Government Exhibit VO-81.
Q. Mr. Zhou, what is this?
A. This is wire instruction I received.
Q. And who, if anyone, sent this to you?
A. Sent by Sara Wei, the Voice of Guo channel leader.
Q. I think you mentioned previously that Sara Wei had some
role within the Himalaya Global Alliance.  Can you just
describe that for the jury.
A. Yes.  She was very active follower before.  She reveal
herself and joined the movement as well.  Then she had some
meeting with Miles Guo, even publicly, live broadcast together.
So at the time she was with another person that she 
was very active and designated.  And because she also gather 
some followers and fall through the whistleblower movement.  
She form a group; she was the whistleblower movement.   
So at the time Miles Guo was also designate her as the 
followers, the group leaders.  And she can also have 
authorization from Miles Guo to collect GTV investment for us. 
MS. MURRAY:  Ms. Loftus, can we please publish
Government Exhibit VO-82.  Zoom in on the top.
Q. Mr. Zhou, what is this?
A. That's my wire confirmations.
Q. And looking at this, what was the date of this wire
transfer?

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A. May 28, 2020.
Q. And it was a wire sent to where?
A. It was sent to Voice of Guo Media.
Q. And what was the amount of this particular wire?
A. $20,000.
MS. MURRAY:  We can take that down.  Thank you.
Q. Why did you want to invest in GTV at that time in May of
2020?
A. Because first I want to get a GTV stock.  And the GTV, I
was also the user.  And this is a platform.  GTV website also
is for the freedom of voice for other Chinese people
dissidents.  And I was follower myself.  I really a believer
for this movement.  I want to just be part of it and also to
help grow this GTV.  The GTV was just like any other tech
companies started.
There's also about Miles Guo mention we also will grow 
this to become the world number one social media platform, 
surpass YouTube.  We have all the features, we'll combine Zoom, 
combine YouTube, we'll have the best top technology implemented 
into this GTV.  So for that I want to be part of it.  So I 
invested. 
Q. When Miles Guo said at the time in 2020 that GTV would
surpass YouTube, did you believe him then?
A. Yes.  Eventually.
Q. Did you, in fact, receive stock or any shares in exchange

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for your GTV investment?
A. No.
Q. At that time in 2020, what, if anything, did Miles Guo say
about whether there was a risk of losing your principal
investment in GTV?
A. He made a personal guarantee that for other people invested
in GTV would not lose their money; he made personal guarantee
on that.
Q. Can you explain what you mean by "personal guarantee."
A. During his broadcast, he mentioned all the money we
invested, that principal would never lose, lost even a cent.
He will pay -- personally pay back.
Q. And at that time, in 2020, did you believe that Miles Guo
was capable of paying or guaranteeing your investment?
A. Yes.
Q. At that time, 2020, did you have an understanding from
Guo's broadcasts about the value of GTV stock?
A. Yes.
Q. What was your understanding?
A. There is another broadcast lively on Miles Guo broadcast
that I watch live on that day, where successfully closeout the
placement, GTV private placement was announcement.  Miles Guo
mention have a receive -- GTV alone received $335 million; from
VOG received 117 million.  And combine, that's near -- he said
near $500 million investment.

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And the valuation at the time of GTV, he gave out the 
statement about the value was $2 billion.  Then he added from 
his legal team and from his financial experts the valuation 
should be $10 billion.  So just that moment he explained the 
investment we did, from 7 point time -- jumped to estimate made 
about 30 times. 
Q. And at the time that you watched that broadcast in 2020,
did you believe Miles Guo regarding the valuation of GTV?
A. Yes, I did.
MS. MURRAY:  Ms. Loftus, can we please pull up
Government Exhibit C-63-V, which is in evidence.  If we could
just publish it to the jury, please.
Q. Mr. Zhou, do you recognize this video?
A. Yes.
Q. Is this a broadcast that you watched at the time that it
was posted on the internet in 2020?
A. Yes.
MS. MURRAY:  Ms. Loftus, if we could go to the
12-minute-and-40-second mark, please, and start playing.
(Video played) 
MS. MURRAY:  We can pause for a moment please.
Your Honor, we've also admitted Government Exhibit
C-63-T, which is the translation and transcript of this video.
I'm going to play this portion and then I'm going to ask
Mr. Zhou to read portions of that transcript.

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Thank you, Ms. Loftus.  We can continue.
(Video played) 
MS. MURRAY:  You can stop there.  Thank you.
Ms. Loftus, if you could please now publish for the
jury what's in evidence as Government Exhibit C-63-T.  And if
we could go down to the time stamp of 12:40, please.  And zoom
in on the right.
Q. Mr. Zhou, this is a translation and transcription of the
video clip that we just watched.  If you could just read in the
right column there the English for the jury.
A. Sure.
We had an initial valuation of 200 million for GTV, 
and the private placement required a minimum investment of 20 
million.  The private placement exceeded the highest 
expectations and raised 350 million.  This is up to now, this, 
this figure, ah, is about 360 million, let's say 350 million.  
350 million does not include the 117 million from VOG.  If 117 
million plus 350 million, it's more than 400 million -- sorry, 
480 million, which is almost, almost, almost, almost 500 
million, almost 500 million. 
But the figure we have now is the 350 million
received, which is just for the contracts with GTV.  This turn
out to be a conservative estimate and 17.5 times the valuation.
Given the tremendous demand for GTV shares and the good capital
position of GTV going forward, my lawyers and financial experts

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mutually agree that a $2 billion valuation is probably too low,
and that the actual value of the company is probably closer to
10 billion given the tremendous demand for GTV shares.
MS. MURRAY:  Thank you.  We can take that down.
Q. Mr. Zhou, at the time that you watched this broadcast in
2020, did you believe Miles Guo that the value of GTV was
approximately $10 billion?
A. Yes.
Q. At the time that you invested in GTV in 2020, what, if
anything, did you understand that your investment would be used
for?
A. Yes.  The money first will use to enhance the GTV's
features, purchasing top tiers companies and to expand GTV to
become -- to take over the YouTube, become world number one
social media.
Q. At that time in May of 2020, if you'd believed that Guo
would use GTV investment money for his own personal expenses,
would you have invested in GTV?
MR. KAMARAJU:  Objection to form, your Honor.
THE COURT:  If you'll step up, please.
(Continued on next page)

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(At sidebar) 
THE COURT:  I'll hear your objection.
MR. KAMARAJU:  Your Honor, Ms. Murray continues to
just embed facts that are not in evidence, asking questions,
then asking the jury to infer -- asking the witness to agree
with them.  That's, in essence, putting her own testimony in
front of the jury.  If she wants to elicit those questions, she
can ask open-ended questions.  That was our objection to the
form.
MS. MURRAY:  Your Honor, I believe that the Court
ruled that hypotheticals could come in in questioning of
witnesses and, in particular, victim witnesses.  And that is
what I'm posing to this witness.
THE COURT:  I don't see how she gets at it without
asking hypothetical questions.
MR. KAMARAJU:  She could still lay the foundation
prior to asking a hypothetical.
THE COURT:  So I think that he's asking you to state
whether it's his understanding — the witness's understanding —
that -- or whether he knows whether Mr. Guo invested the money
that he claimed that he had invested.
MR. FERGENSON:  Your Honor, you had ruled in pretrial
rulings that to prove materiality, we can ask the hypothetical
question such as, If you had known X, would you have invested?
And that's, you know, standard in fraud cases like this.

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THE COURT:  Of course.  Of course.
I don't think that it's improper though for her to ask 
whether -- 
MR. FERGENSON:  To establish he doesn't, in fact, know
how it was used -- I'm sorry.
THE COURT:  The fact that she's assuming is that
Mr. Guo did not invest the $100 million.  And so do you know
whether the witness knows whether Mr. Guo invested the $100
million?
MS. MURRAY:  So this is with respect in particular to
the witness's GTV investment and other GTV investment money.  I
don't believe the witness has any personal knowledge of how
that money was used, except to say that, sitting here today,
the witness has an understanding that it was not all used for
GTV's business and instead was used for personal expenses.
MR. KAMARAJU:  Understanding based on the government's
allegations, your Honor, not on any evidence --
MS. MURRAY:  And just to be clear, that's why I asked
the question in the manner that I did.
THE COURT:  I don't know that it is detrimental for
her to ask it this way as opposed to asking whether he knows if
the money was used by Mr. Guo to invest.
MR. KAMARAJU:  To me, your Honor, the problem is your
Honor definitely ruled that they can ask a hypothetical.  So
the question is is what, if any, foundation they have to lay

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prior to asking a hypothetical.
THE COURT:  Exactly.
MR. KAMARAJU:  So to me, maybe it's just a form point
on this particular hypothetical.  I suspect they are going to
ask many more, so that's why I think it's appropriate to raise
it now.  To me, she can just establish the basic foundation for
it, and then she can say -- she can ask her hypothetical if she
wants.
THE COURT:  Okay.  
MS. MURRAY:  I will do that.  I did ask if he had an
understanding of how the money was used; but I can ask that
question again if that would be sufficient foundation.
MR. KAMARAJU:  That's the distinction.
MS. SHROFF:  The question is whether he had knowledge,
not what his understanding is.  Because his understanding could
come from your prep of him during his preparation for his
testimony here.  The question is what knowledge he had at that
time, not the knowledge he has now.
MR. FINKEL:  At the time his understanding would
address all these concerns and be consistent with the Court's
ruling.
MS. SHROFF:  Not understanding knowledge.
THE COURT:  You can ask about knowledge and then ask
your hypothetical.
MS. MURRAY:  Thank you, your Honor.

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MR. KAMARAJU:  Thank you, your Honor.
(In open court) 
THE COURT:  You may continue.
MS. MURRAY:  Thank you, your Honor.
BY MS. MURRAY:  
Q. Mr. Zhou, in May of 2020, when you invested in GTV, did you
have any knowledge of how your investment was going to be used?
A. Yes.
Q. And what did you believe your investment would be used for,
again, in May of 2020.
A. Yes, at the time I believe my investment will use to
enhance the GTV, to bring this GTV platform to number one
leading social media platform.
Q. At that time, in May of 2020, if you had believed that
Miles Guo would use your GTV investment money for his personal
expenses, would you have invested in GTV?
MR. KAMARAJU:  Objection, your Honor.  
We just addressed this at side bar. 
THE COURT:  If you'll step up again.
(Continued on next page)

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(At sidebar) 
THE COURT:  Are you asking for -- stating that she
needs to ask whether Mr. Guo used the money?  I mean, what is
the question that you're looking for?
MR. KAMARAJU:  No, I thought -- my understanding when
we left the sidebar was that she was going to ask questions do
you know how the money was used.  She has not asked it.
MS. MURRAY:  I believe I did ask that.
MR. KAMARAJU:  No, the question that I heard — if I
got it wrong, I apologize — was how did he believe he thought
the money was going to be used.  She never asked the follow-up
question of do you know how the money was used in May of 2020.
THE COURT:  So you're going to ask the "do you know"
question.
MS. MURRAY:  Your Honor, what's relevant is his
understanding and his knowledge; that goes to the reason that
he invested.  That's the materiality point.  I don't think that
it's necessary to establish whether he, as an investor, knew
what was happening with the money that was being invested into
this company in order for him to say what his motivation was
for investing.
MR. KAMARAJU:  If you don't ask, if you don't
establish that he doesn't know, then how do you ask a
hypothetical that says:  If you had known, then how would that
change your opinion?

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THE COURT:  Okay.
MR. KAMARAJU:  Thank you, your Honor.
(In open court) 
THE COURT:  You may continue.
BY MS. MURRAY:  
Q. Mr. Zhou, in May of 2020, after you invested $31,300 in
GTV, at that time did you have personal knowledge of how your
investment was used?
A. The money invested to GTV, my understanding was intended to
enhance the GTV, purchase top-tier company or software to make
it enhancement and to overcome -- become the world number one
platform, surpass YouTube.
Q. And what is that understanding that you had in May 2020,
what is that understanding based on?
A. Miles Guo mention his broadcast.
Q. Aside from what Miles Guo mentioned, do you have personal
knowledge?  Do you know how your money was used or did you know
in May 2020 how your money was used?
A. That I don't know.
Q. If you had believed that Guo would use your GTV investment
money for his own personal expenses in May of 2020, would you
have invested in GTV at that time?
A. No.
Q. Have you heard the phrase "G Series"?
A. Yes.

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Q. What is G Series?
A. G Series is investments including GTV, G News, G Fashion, G
Mall, G Clubs, etc., which were all created by Miles Guo.  And
this is one of a financial system for the whistleblower
movement as their ecosystem.
Q. Do you have an understanding of what, if anything, the "G"
in G Series stands for?
A. Yes.
Q. What's your understanding?
A. G is the English letter reference Miles Guo's last name
initial, first initial.
MS. MURRAY:  Ms. Loftus, can we please pull up for the
witness only what's been marked for identification as
Government Exhibit VI-151.
Q. Mr. Zhou, do you recognize this?
A. Yes.
Q. At a high level, what is it?
A. Miles Guo's broadcast.
Q. Do you see the date on the top left?
A. Yes.
Q. Did you watch this particular broadcast at the time that it
was posted on the internet on or about that date?
A. Yes.
MS. MURRAY:  Your Honor, the government would move to
admit Government Exhibit VI-151.

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MR. KAMARAJU:  No objection.
THE COURT:  It is admitted.
(Government's Exhibit VI-151 received in evidence) 
MS. MURRAY:  If we could play that, please,
Ms. Loftus.  We can publish it to the jury first and then we'll
play it.
(Video played) 
MS. MURRAY:  We can stop there, please.
We can take it down. 
Q. Mr. Zhou, there was a reference in the first video clip to
Sara's VOG.  What does that refer to?
A. Sara Wei.
Q. And "VOG," what does that reference?
A. Voice of Guo.
Q. There was also a reference to a Guo Wengui.  Did you see
and hear that?
A. Yes.
Q. Who is that?
A. Miles Guo.
Q. Generally speaking, what, if anything, did Miles Guo say
during those broadcasts we just viewed?
A. Personally guarantee that investors' money will not lose,
only gain.  If any ten cents loss, he'll personally pay.
Q. And did you view those videos at the time that they were
posted in 2021?

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A. Yes.
Q. And at that time, when you viewed those videos, did you
believe Miles Guo that he would personally guarantee any
investments in the G Series?
A. Yes.
Q. I want to turn your attention now to June of 2020.
Did there come a time when Miles Guo announced the 
launch of a new organization? 
A. Yes.
Q. What was the name of that organization?
A. It's called New Federal State of China.
Q. Was that also referred to as the NFSC?
A. Yes.
Q. What was the New Federal State of China?
A. It's a supervisory organization for the whistleblower
movement.
Q. Can you describe how Miles Guo announced the launch of the
NFSC?
A. Yes.  That was June 4th, 2020.  He announced this
establishment of NFSC on his private yacht and was lively
broadcasted.
Q. Did you watch that broadcast when it was broadcast on June
4th, 2020?
A. Yes, I watched.
Q. How, if at all, is the NFSC -- or at the time was the NFSC

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associated with the G Series?
A. G Series were already launched before; then it was for the
other whistleblower movement.  And NFSC was established because
NFSC is a supervisory organization on top of all the movement,
that's the name that will be used in the future to as a
legitimate government.  So that's ultimately a name that -- for
this movement.
Q. What do you mean when you say that the NFSC is going to be
a government?
A. Because the movement is -- will take down the China
Communist Party.  Once Chinese CCP falls, then this
organization will try to replace the CCP; give the people one
person, one vote.
Q. And how was it your understanding that the NFSC -- let me
put it in timing.  In June of 2020, how was it your
understanding that the NFSC was going to take over for the
Chinese Communist Party?
A. At that time my understanding was just to expose the
Chinese corruptions.  Miles Guo has three tactics.  He
mentioned that by eliminate CCP using by law; by eliminate CCP,
using America power, American powers; by eliminate CCP by using
CCP itself, that's he mention it.
Q. So at that time, in June 2020, was your understanding that
the NFSC was going to be a government, was that based on
statements by Miles Guo?

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A. Correct.
MS. MURRAY:  Ms. Loftus, can we please publish what's
in evidence as Government Exhibit CT-209.
Q. Mr. Zhou, looking at the item?
MS. MURRAY:  If we could zoom in, Ms. Loftus, in the
middle of this.  
Q. The figure that's depicted in those two posters or
pictures, do you recognize that shape?
A. Yes, I do.
Q. What is it?
A. That's the star from the NFSC flag.
Q. How many points does that star have?
A. Total, 49 stars.
Q. Can you explain for the jury how you get 49 points from
that star?
A. It's a seven times seven equal 49.
Q. And what is the significance, if any, of seven points on
that star?
A. Seven, we all use call Miles Guo seven brothers.  There's a
lot of seven he's associated with.  So he was also was part of
the flag creations, participated.  And so I think that's -- I
believe that's a flag that represents seven is Miles, the
sevens.
MS. MURRAY:  We can take that down, Ms. Loftus.
Q. Mr. Zhou, did there come a time after the GTV private

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placement closed in June 2020, when Miles Guo announced a
farm-related investment opportunity?
A. Yes.
Q. What was that opportunity?
A. That's called a farm loan.
Q. Can you describe for the jury what the nature of the farm
loan investment opportunity was.
A. Farm loan was to have investors lend money to the -- call
it farms, which is the NFSC offices in different divisions
throughout the world.  Then there was a term lend the money to
the farm to use to operate for hirings, expand, and recruit.
Q. And based on the farm loan opportunity, what, if anything,
would a lender get in exchange for the loan?
A. There is a term for three-year term.  And there is also
interest rate for annual interest rate placed on that.
Q. And at the end of that three-year term, what options, if
any, did lenders have to either get their principal and their
interest rate or something else?
A. You have choice to get your money, interest plus your
principal, plus interest back, and also you can get stocks.
Q. What type stocks?
A. GTV stocks.
Q. How was it your understanding at that time, in June 2020,
that the farm loan investment opportunity offered either return
on your money or stock?

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A. I'm sorry, could you just repeat it one more time.
Q. Yeah.  In June of 2020 or thereabouts, how was it your
understanding that by giving a loan to the farm, three years
later you could either receive your money back with interest or
you could receive stock?
A. We have agreements.
Q. What type of agreements?
A. Loan agreements signed with the farms.
Q. And who, if anyone, announced the farm loan program?
A. Miles Guo announced.
Q. At that time, in 2020, were you a member of any farm?
A. Yes, I am.
Q. Which farm were you a member of at that time?
A. The first farm on social is called UK London Club.
Q. Did you participate in the farm loan program?
A. Yes, I did.
Q. With which farm did you participate in the farm loan
program?
A. UK London Club.
MS. MURRAY:  Ms. Loftus, can you publish Government
Exhibit VO-22, which is in evidence.
Q. Mr. Zhou, do you recognize this?
A. Yes.
Q. What is this?
A. This a farm loan agreement.

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Q. What is the name of the borrower listed on this agreement?
A. It's U.S. Himalaya Capital Inc.
Q. What farm, if any, is U.S. Himalaya Capital, Inc.
associated with?
A. This is a farm -- UK London Club farm.
Q. And the lender listed there, whose name is that?
A. That's my name.
Q. What date did you enter into this loan agreement, the UK
farm?
A. August 24, 2020.
Q. And under the terms of this loan agreement, what was the
stated use of the loan that you provided to the UK London Club?
A. It's for the general working capital purpose for the farm.
Q. How much did you invest in the farm loan program?
A. $21,000.
MS. MURRAY:  We could take this down, Ms. Loftus.
Q. Mr. Zhou, at the time that you signed the loan agreement in
August of 2020, what was your understanding of how your money
would be used?
A. For the farm to establish offices, hiring staffs, and other
corporated operation expenses.
Q. And at that time in August 2020, what was your
understanding of what you would get, if anything, in exchange
for your loan to the UK farm?
A. It was eight percent for three years' term.

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Q. At that time, in August 2020, why did you participate in
the farm loan program?
A. Because I want to help the farm and I want to get the
stocks.
Q. And what type of stock did you expect you would get in
exchange for your loan to the UK farm?
A. The GTV common stocks.
Q. Why did you believe that you would get GTV stock in
exchange for making a loan to the farm?
A. Because that was part of what Miles Guo introduced this
project, as investment opportunities.
Q. Did there come a time when Miles Guo announced another
investment opportunity that was called G Clubs?
A. Yes.
Q. When was that?
A. It was same year, 2020 introduced.
Q. At that time, in 2020, what did you understand G Clubs to
be?
A. G Club is -- is to -- as other exclusive club for high net
worth people, individual to have, to show your status.  But as
we are already investing to GTV, our wealth in the future will
be tremendous big.  So this club is created to also to serve
additional as a financed project will have another features to
give to those members.  So that's a club was created.
THE COURT:  What do you mean by "exclusive club"?

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THE WITNESS:  Yes, your Honor.
Exclusive -- this Miles Guo mention about other 
society has those club, like Royal Family.  This particular 
club, for example, Masons, there's other clubs.  So he want 
create some similar clubs for particular individuals, which is 
this is among the NFSC members. 
BY MS. MURRAY:  
Q. At that time, in 2020, did you understand that G Club had
any physical locations, any actual club location?
A. No.
Q. At that time, in 2020, what, to your understanding, would
you get in exchange for investing in G Clubs?
MR. KAMARAJU:  Objection to form, your Honor.
THE COURT:  Rephrase, please.
MS. MURRAY:  Yes, your Honor.
Q. In 2020, what did you understand the G Club investment
opportunity to be?
MR. KAMARAJU:  Your Honor, I'm going to continue to
object.  I can explain at sidebar.
MS. MURRAY:  If I may have a moment, your Honor.
(Counsel conferred) 
MS. MURRAY:  May I try again, your Honor?
THE COURT:  Go ahead.
MS. MURRAY:  Thank you.
Q. Mr. Zhou, in 2020, what did you understand that paying

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money to G Clubs would give you?
A. Yes.
There was offer the members we'll give stocks, the G 
Club stocks.   
Second, we'll get passports.   
Third, we'll get another investments called exchange 
of coins.   
Fourth, we'll get discount rated deals from travel 
agencies or even shoppings, like luxury air jets, Bombardier.   
And the last one was for discount shopping on G 
Fashion.   
Q. Taking those in turn, starting with the last, what was G
Fashion?
A. G Fashion is part of the G Series.  It's clothing for
fashion where you can shop luxury clothes.
Q. Where were G Fashion items sold, if anywhere?
A. Was sold in the states, United States.
Q. You mentioned that you had an understanding at that time in
2020 that you could get other benefits in exchange for paying
money to G Clubs; is that right?
A. Yes.
Q. What was that understanding based on at that time?
A. That was introduced by Miles Guo.
Q. What was the cost of a G Clubs membership in 2020?
A. G Club membership has five tiers.  The first tier is

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$10,000, with each 10,000 increasement to top five tiers.
Q. So for the top tier, what was the cost of a top-tier
membership at that time?
A. That would be $50,000.
Q. Did there come a time when you purchased any G Clubs
memberships?
A. Yes, I did.
Q. When was that?
A. That in September 2021.
Q. And how many memberships did you purchase?
A. I purchase two, Tier 2 and Tier 5.
Q. What was the cost of the Tier 2 membership?
A. That's $20,000.
Q. And what was the cost of the Tier 5 membership?
A. $50,000.
MS. MURRAY:  Ms. Loftus, can we please publish what's
in evidence as Government Exhibit VO-25.  Zoom in on the top
portion.  Actually, the body of this.
Q. Mr. Zhou, what is this?
A. That's my G Club membership notification after the
application was approved.
Q. And looking at the initial line, it's addressed to someone,
can you read what that reads?
A. I'm sorry, could you please --
Q. Sure.  Starting with the word "my" at the beginning of this

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notification, what does that line say?
A. "My dear fellow fighters."
Q. And then looking down at the bottom of this, who signed --
or who is this notification from, according to body of this
email?
A. The name signed, Guo Wengui.  That's Miles Guo.
Q. And how is he described here?
A. G Clubs' official spokesperson.
Q. How did you pay for your G Clubs memberships?
A. I paid by checks.
MS. MURRAY:  Ms. Loftus, can we please take this down
and publish Government Exhibit VO-26, which is in evidence.
Q. Mr. Zhou, do you recognize these?
A. Yes.
Q. Are these the checks that you sent to become a G Clubs
member?
A. Yes.
Q. What is the date of each of these checks?
A. The first check, August 24, 2021.
Q. And the second?
A. August 25th, 2021.
Q. And looking at the memo line, there is some text in the
memo line of each of these checks.  What, if anything, does
that text indicate?
A. That's indicate my application numbers.

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THE COURT:  Sir, other than the payment of money, was
there any other requirement or criteria in order to join the
club?
THE WITNESS:  Yes, your Honor.  To join the club, you
have to be a follow members, which is the I have receive
members.  And to purchase at a beginning, it wasn't required
for the only members, and it has previously investing the GTVs,
and also donated to Rule of Law Foundation.
BY MS. MURRAY:  
Q. So in submitting an application for a G Clubs membership,
what information, if any, were you required to provide about
prior donations to Rule of Law or prior investment in GTV?
A. We have to include input our assigned the investment IDs
and which farm we were associated with into applications.
MS. MURRAY:  And if we could go back, Ms. Loftus, to
Government Exhibit VO-25.  If we could zoom in on the first
paragraph, please, that starts with "Congratulations."
Q. Mr. Zhou, can you just read the text here starting with
"Congratulations."
A. Yes.
"Congratulations.  I am pleased to announce that your 
Tier 5 membership to G Clubs has been approved.  As a spokesman 
for G Clubs, I extend a warm welcome to your membership to the 
future." 
MS. MURRAY:  We can take that down.

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Q. Mr. Zhou, did you receive any stock shares in exchange for
your G Clubs membership payment?
A. No.
Q. You mentioned that there were discounts that you could use
as a G Clubs member.  Where could you use those discounts?
A. Mean I use on GFashion.com.
Q. Did you purchase any items from GFashion.com?
A. Yes.
Q. Did you purchase some of those items before you became a G
Clubs member?
A. Yes.
Q. Did you purchase some items after you became a G Clubs
member?
A. Yes.
Q. Can you describe the quality of the items that you
purchased from G Fashion?
A. The quality itself is very ordinary, normal, compared to
what we -- I think the clothes we normally get.
Q. I'd like to look at a few of the items that you purchased
from G Fashion.
MS. MURRAY:  Your Honor, may I approach?
THE COURT:  Yes.
MS. MURRAY:  Your Honor, I'm handing the witness
what's been marked for identification as Government Exhibits
32, 33, 34, and 35.

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Q. Mr. Zhou, do you recognize Government Exhibits 32, 33, 34,
and 35?
A. Yes.
Q. What are they?
A. Those are my purchase item from GFashion.com.
Q. Are those just some of the items that you purchased from G
Fashion?
A. Yes.
MS. MURRAY:  Your Honor, the government would move to
admit Government Exhibits 32, 33, 34, and 35.
MR. KAMARAJU:  No objection.
THE COURT:  They are admitted.
(Government's Exhibits 32, 33, 34, 35 received in 
evidence) 
Q. If you could start with Government Exhibit 32, please,
Mr. Zhou, and hold that up for the jury.
Q. What is Government Exhibit 32?
A. That's a baseball cap.
Q. And where did you purchase that?
A. GFashion.com.
Q. What was the approximate cost of that baseball cap?
A. This I remember cost close to $200.
Q. If you could please hold up Government Exhibit 34.
What is that item? 
A. Just a regular shirt.

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Q. And is that one of the items that you purchased from G
Fashion?
A. Yes.
Q. What was the approximate cost of that T-shirt?
A. This one was about $150.
Q. And now if you can please pull up or hold up Government
Exhibit 33.
A. Yes.
Q. What is Government Exhibit 33?
A. This is silk pants, ladies' wear.
Q. What was the approximate price of those pants on G Fashion?
A. It was listed about $800.
MS. MURRAY:  Your Honor, if we could show the witness
what's been marked for identification as Government Exhibit
W-58.
THE COURT:  All right.
MS. MURRAY:  While we're waiting, your Honor, may I
publish Government Exhibits 32, 33, and 34 to the jury?
THE COURT:  You may.
MS. MURRAY:  Thank you.
Q. Mr. Zhou, do you recognize Government Exhibit W-58?
A. Yes.  
MS. MURRAY:  If we could scroll down a bit,
Ms. Loftus.
Q. Have you visited the website that's depicted in Government

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Exhibit 58 before?
A. Yes, I did.
MS. MURRAY:  We would move to admit Government Exhibit
W-58.
MR. KAMARAJU:  No objection.
THE COURT:  It is admitted.
(Government's Exhibit W-58 received in evidence) 
MS. MURRAY:  If we'd please publish that, Ms. Loftus.
We could start up at the top. 
Q. Mr. Zhou, what website is shown in Government Exhibit 58?
A. This is a G Fashion website.
MS. MURRAY:  Ms. Loftus, if we could scroll down a
bit, please.
Q. Looking at the right there, do you see "G Fashion silk
pant"?
A. Yes.
Q. What is the listed price of that item?
A. $880.
Q. And is that the same item that is in Government Exhibit 33?
A. Correct.
MS. MURRAY:  We can take that down, Ms. Loftus.
Q. One more physical exhibit that you have, Mr. Zhou,
Government Exhibit 35.  If you could take that out.
What is Government Exhibit 35? 
A. Yes.  This is a gold limited edition whistles.

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Q. How was that item advertised on the G Fashion website?
A. Advertise as only was 77 made and it's 24K.
Q. What was the cost of that whistle?
A. I paid about $3200 for it.
MS. MURRAY:  Ms. Loftus, if we could please publish
what's in evidence as Government Exhibit VO-67.
Q. Mr. Zhou, what is Government Exhibit VO-67?
A. That's paid receipt confirmation email.
Q. And that's for the whistle that is Government Exhibit 35?
A. Correct.
Q. What material did you say that the whistle was advertised
as?
A. 24K gold.
Q. Do you have an understanding or an impression of whether
that whistle was, in fact, gold?
MR. KAMARAJU:  Objection, your Honor.
THE COURT:  Sustained.
Q. Mr. Zhou, have you weighed that whistle?
A. I did.
Q. How much did it weigh approximately?
MR. KAMARAJU:  Objection, your Honor.
THE COURT:  Overruled.  You may answer.
A. 0.7 ounce.
MS. MURRAY:  Your Honor, permission to publish
Government Exhibit 35 to the jury.

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THE COURT:  You may.
Q. Mr. Zhou, why, if at all, did you weigh the whistle after
you purchased it?
A. I was just curious about if -- if real or not.
Q. What do you mean if it was real or not?
MR. KAMARAJU:  Objection.
THE COURT:  Overruled.  You may answer.
A. When I first received, the packaging, when I first opened,
was -- I saw little bit dust go on it.  The gold itself was --
the craftsmanship was little bit rough.  My knowledge, this is
a limited edition as collectible items, that made me little bit
concern.
Q. Mr. Zhou, returning to --
MS. MURRAY:  Ms. Loftus, we can take that down.
Thank you. 
Q. Returning to what you expected or understood that you would
receive in exchange for paying money to G Clubs, I think you
mentioned a currency; is that correct?
A. Yes.
Q. What was that?  Can you explain that to the jury?
A. It is currency introduced called G dollar and the G coins.
It was digital currency and also digital cryptocurrencies that
also will be launched from exchange.
Q. And when you say "exchange," what are you referring to?
A. At the time we have a change is called Himalaya Exchange.

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Q. At that time in 2021, when you invested in -- or, excuse
me, when you paid for a G Clubs memberships, what was your
understanding of what the Himalaya Exchange was?
A. Himalaya Exchange was another part of G Series for
financial freedom created by Miles Guo.  And it gave people
much better opportunity to transfer monies instantly.  Also no
boundaries.  And also for the most securities you will get.
Q. And at that time, in 2021, what was your understanding
about the Himalaya Exchange based on?
A. The G dollar was equal to one U.S. dollar values, and will
have gold standards for the H coins.  The full name, it's
Himalaya coins, it's backed by 20 percent gold.  So that adds
all the value to it.
Q. Why, if at all, did you believe in the time, in 2021, that
the Himalaya currencies were backed 20 percent by gold?
A. Miles Guo personally announced that.
Q. To your knowledge, at that time, in 2021, who was in charge
of the Himalaya Exchange?
A. The person, I don't know.
Q. At that time, in 2021, who, if anyone, promoted the
Himalaya Exchange?
A. Miles Guo promoted Himalaya Exchange.
Q. Did there come a time when you purchased any of the digital
currencies that were available on the Himalaya Exchange?
A. No.

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Q. Why not?
A. Because there's a policy, it's not a -- it's restricted to
sell to the residents in the states.
Q. And how was it your understanding at that time, in 2021,
that it was restricted?
A. Also Miles Guo mention that.
Q. Did there come a time when you sent money to purchase
Himalaya coin or Himalaya dollars?
A. I didn't send money to get Himalaya dollars, but I was
given opportunity to purchase H coins.
Q. And what was that opportunity?
A. That opportunity is based on my previous G Series
investments and donations for the previous investment.  Also,
I'm a follower of this movement; the opportunity was given to
me.
Q. Who, if anyone, gave you the opportunity to purchase H
coins?
A. Miles Guo gave us the opportunity.
MS. MURRAY:  Ms. Loftus, if we could please pull up
for the witness what's marked for identification as Government
Exhibits VO-107 and VO-108.
Q. Mr. Zhou, do you recognize these?
A. Yes.
Q. Generally speaking, what are they?
A. On the right side --

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Q. Sorry.  Just a moment, sir.  If you could, just at a
general level, what type of document or item is this?
A. That's my personal investment summary.
Q. And are these -- are these contents that were taken from
your phone?
A. From my computers.
Q. Did you provide these to the government?
A. Yes, I did.
MS. MURRAY:  Your Honor, the government moves to admit
Government Exhibits VO-107 and VO-108.
MR. KAMARAJU:  No objection to their admission, your
Honor.
THE COURT:  They are admitted.
(Government's Exhibits VO-107, VO-108 received in 
evidence) 
THE COURT:  It's now 11:30, members of the jury, so
we're going to take our half-hour break.
Remember that I need for you to be ready to walk 
through that door at noon.  Remember also that you're not 
allowed to discuss this case amongst yourselves or with anyone 
else.  Don't permit anyone to discuss the case in your 
presence.   
Sir, you are not to discuss your testimony. 
(Jury not present) 
THE COURT:  You may be seated.

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Counsel, anything before we come back for our break?
MR. KAMARAJU:  Not from the defense, your Honor.
MS. MURRAY:  Not from the government, your Honor.
THE COURT:  All right, then.  You may step down.
THE WITNESS:  Thank you, your Honor.
(Luncheon recess) 
(Continued on next page)

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AFTERNOON SESSION 
12:00 p.m. 
THE COURT:  Please be seated.
Please have the jurors brought in.  And please have
the witness resume the stand.
MS. MURRAY:  Yes, your Honor.
(Jury present) 
THE COURT:  Please be seated.
Remember, sir, that you are still under oath.
THE WITNESS:  Yes, your Honor.
THE COURT:  You may proceed with the direct
examination.
MS. MURRAY:  Thank you, your Honor.
Mr. Gartland, if you could please publish for the
jury, alongside one another, Government Exhibits V0107 and
V0108.
BY MS. MURRAY:  
Q. Mr. Zhou, before we took a break, I believe we were talking
about the Himalaya Exchange.  We're going to pull up Government
Exhibits V0107 and V0108.
MS. MURRAY:  Mr. Gartland, if you could just unpublish
while you're pulling those up.  Thank you.
Q. I guess, Mr. Zhou, while we're waiting, you had mentioned
that there were certain restrictions on purchasing Himalaya
Coin.  Can you explain those to the jury, please, your

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understanding in 2021 on what those restrictions were.
A. Yes.  To allow to purchase H Coin, you have to have——first
you got to be a member of the farms, which you have to join the
movement.  Then based on that, it's all based on your previous
investment, including donations.  So once all that been
counted, then you were able to get a prelaunch of the coins and
at a discounted rate.
Q. What do you mean by prelaunch?
A. Because this coin was launched on November 1, 2021, all the
investments was previously invested was counted towards to how
much coin you could get.
Q. And who, if anyone, calculated the amount of investment
that you had prelaunch of the Himalaya Coins?
A. The rule of guidance was set by Himalaya Alliance.  For
previous GTV there was deadline also, made that draw line.  For
September 31st [sic], anything donate investment, you place it
before, you will get a dollar investment for 0.5 coins.  Any
investments after that deadline, it's counted as 1 dollar
investment for 0.2 coins.
Q. And who, if anyone, set those deadlines?
A. The deadline was announced by Miles Guo.
Q. Where was that announced?
A. During his broadcast.
Q. At the time of the Himalaya Coin launch in November of
2021, were you a member of any farms?

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A. Yes.
Q. Which farms?
A. UK London Club.
Q. Did you communicate with anybody from the UK London Club
regarding the Himalaya Coin?
A. Yes.
Q. With whom did you communicate about Himalaya Coin?
A. I contacted the farm leaders.
Q. Who was the farm leader of the UK farm at that time?
A. His name is David Dai.
Q. How do you spell that last name?
A. D-A-I.
Q. Can you describe what communications or conversations you
had with David Dai at that time about Himalaya Coin?
A. There were one for the resident in the States and other
prohibited country couldn't purchase the Himalaya Coin
directly.  That Global Alliance, Himalaya Alliance, established
a business as nominee shareholdings to held those people's
coins.  Besides that, the farm also established business act as
a nominee shareholdings to held those people's coins, which was
I was included.
Q. What business are you referring to that the farm
established——or the Alliance?  Excuse me.
A. From the Alliance, the company created called Freedom Media
Venture Ltd.

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Q. And can you explain for the jury what you mean when you
describe Freedom Media Venture as a nominee.
A. Nominees act as——on your behalf to hold your——your coins,
for example.
Q. And at that time, in the fall of 2021, how was it your
understanding that Freedom Media Venture was a nominee?
A. It was public announced by Miles Guo.
Q. And what role, if any, did Freedom Media Venture have with
respect to money that you paid for Himalaya Coins?
A. The Freedom Media Venture, that company was a new company
created for the GTV, so was announced that for those people who
are in the restricted countries, then they will able to sign a
contract and also offer——there was also fee will be charged was
announced to us.  He explained it to us.
Q. Who explained that to you?
A. Miles Guo mentioned it and also the other farm leader
mentioned it.
Q. What was the nature of the fee?
A. The fee I got was a 5 percent.
THE COURT:  What do you mean by restricted country?
THE WITNESS:  Yes, your Honor.  The Himalaya Exchange
has a policy, and the policy laid out, there were countries not
on their list, a permitted list to purchase or do any business
or even become a user.  The country were United States, Canada,
Japan, North Korea, and other essential countries.

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THE COURT:  You may continue.
MS. MURRAY:  Thank you, your Honor.
BY MS. MURRAY:  
Q. Mr. Zhou, for those restricted countries that you just
mentioned, did you have an understanding of whether people who
were located in those countries could invest in Himalaya Coin?
A. Yes.
Q. What was that understanding at that time, in 2021?
A. So that this create a nominee shareholding companies that
were able to have them as our shareholders, to——to obtain the
coins.
Q. And did you in fact send money to purchase Himalaya Coins
through that nominee shareholder?
A. I didn't send the money direct to the shareholder.  I send
money to the farm.
Q. Which farm?
A. UK London Club.
Q. Did you enter into any kind——was there any understanding
between you and the UK London Farm of what the purpose of the
money that you sent was for?
A. Yes.
Q. What was that understanding?
A. There were agreement, I signed it, with the farm leader,
David Dai.  He created a company act as the nominee
shareholding company.

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Q. And generally speaking, what were the terms of that
agreement that you entered into with the UK Farm leader?
A. The term were just, they will hold my coins and also I have
to pay the fee, annual fee to it.  But in the future, once the
Himalaya Exchange acquired legal license, was able to expand
the territory, which the restriction related to those
countries, especially to the United States, then I would be
able to use my own user name accounts that would transfer the
coins back to me.
Q. And how was it your understanding at that time in 2021 that
that's how the nominee shareholder kind of investment would
work?
A. I'm sorry.  Just one more time repeat the question.
Q. Yeah, of course.  So in 2021, how was it your understanding
that at some point in the future you would be able to register
your own account on the Himalaya Exchange?
A. Yes, mentioned by Miles Guo, yes.
Q. So at the time that you sent money to the UK Farm for the
purchase of Himalaya Coins, what assets, if any, did you have
to the Himalaya Exchange?
A. I don't.
Q. At that time in 2021, how, if at all, were you able to
check the number of Himalaya Coins that you held, that you had
paid for?
A. Because the farm has my investment summaries and the

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summary document, all the investment I have previously
invested; and also, there were ratios for the coins was
calculated.  It was——the information was provided to me.
Q. Provided to you by whom?
A. By one of the members, from UK London Club.
Q. After you purchased Himalaya Coin in 2021 through the UK
Farm, how, if at all, were you able to use that digital
currency to purchase things?
A. I——'cause I don't have access, so I don't know how you
spend that.
Q. Between your investment in 2021 and today, the present,
have you had access to the Himalaya Exchange?
A. No.
MR. KAMARAJU:  Objection to form.
THE COURT:  Overruled.
Q. Between your investment in 2021 and today, did there come a
time when you were able to spend your Himalaya Coin to purchase
anything?
A. No.
Q. I want to turn back for a moment, Mr. Zhou, to the
volunteer work that you did for the whistleblower movement.
Can you just remind the jury generally what types of services
you provided.
A. Yes.  I did video transcript, also translations, videos
editing, and also streaming services, for the Himalaya

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Alliance, and the farm members.
Q. In connection with your volunteer work, did there come
times when you participated in meetings with other volunteers?
A. Yes.
Q. What types of meetings?
A. Those are private meeting with Miles Guo, with the farm
members.
Q. What was the nature of the meeting?  Where did you all
meet?
A. We used the social platform called Webex.
Q. And what, if anything, was discussed during meetings among
the volunteers over Webex?
A. These meeting include briefing of the farm movements,
activities, also the followers' investments, and also some
other issues, among just farm and the Global Alliance, and
also, there were——at the time, the Global Alliance, one wanted
to create a central data center to centralize all the
investors' investment informations, and those meeting was
conducted, and also Global Alliance asked each farm, come to
the farm meetings.  Give them guidelines, have them to turn
over all their bookkeepings, and also the balance to the
designated accounts by the Himalaya Global Alliance.
Q. Mr. Zhou, in the course of your volunteer work, you said
you were involved with streaming broadcasts.  Did that include
broadcasts relating to activities by the NFSC?

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A. Yes.
Q. Did that include broadcasts relating to protests?
A. Yes.
Q. What types of protests did you stream broadcasts of, in
your volunteer work?
A. In late 2022, there were protests, a name called 90 Days
Protest was protesting one of Miles Guo attorneys, and their
attorney firms.  
Q. What, generally, was the subject matter of the 90 Days
Protest?
A. There was involved with Miles Guo's bankruptcy cases, and
so the protest was because Miles Guo announced he was being
extorted by one of the attorneys for the amount of
$250 million.
Q. Taking a step back for a moment, did there come a time when
you learned that Miles Guo had filed for bankruptcy?
A. Yes.
Q. Around when did you learn that?
A. Miles Guo personally did on his broadcast, on February 15,
2022.
Q. What, if anything, did Miles Guo say during his broadcast
about having filed for bankruptcy?
A. He just mentioned, I'm signing today my bankruptcy, and
because I'm being persecuted.
Q. By whom, if anyone, did Miles Guo claim that he was being

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persecuted?
A. He mentioned the persecution from CCP and also he mentioned
some of the CCP penetrated US justice.
Q. At the time that Miles Guo said that in February of 2022,
did you believe that he was filing bankruptcy in part because
he was being persecuted by the CCP?
A. At that time I believed it.
Q. Returning to the 90 Days Protest, around when did the 90
Days Protests begin?
A. The 90 days started towards to end of October 2022, and
last——
Q. Sorry.  Go ahead.
A. And last until end of January.
Q. And why, if at all, were NFSC members protesting during
that time period?
A. Because Miles Guo announced that extortion from the
bankruptcy cases, and the——so there were protests started at
multiple locations.
Q. Can you explain what you mean when you say that Miles Guo
announced extortion.
A. During his broadcast he mentioned he was being extorted by
this attorney, and also he mentioned the amount, $250 million.
Q. And which attorney?
A. The attorney name is Luc Despins.
Q. Based on Miles Guo's broadcast, what was your understanding

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of Luc Despins' role, if any, in the bankruptcy?
A. He was court-appointed trustee for Miles Guo.
Q. And at that time in 2022 what, if anything, did Miles Guo
say about the $250 million that you mentioned?
A. He said, that's unbelievable, outrageous; he was mad about
that.
THE COURT:  When you say court-appointed trustee, what
court are you referring to?
THE WITNESS:  Yes, your Honor.  I believe that's New
York Southern District bankruptcy court.
Q. Mr. Zhou, against whom were the protests directed, the 90
Days Protests in 2022?
A. There were protests at the attorney Luc, attorney's home,
his daughters' universities, his ex-wife's home, his law firm
office, and one of his associates attorneys' home, and one of
Luc second daughter's workplace.
Q. Who, if anyone, directed the protests?
A. Right after Miles mentioned about this extortion, then the
Himalaya Global Alliance initiate, launch all the protests.
Q. Can you describe how the Himalaya Global Alliance launched
the protests.
A. It was organized so the recording of sending out the form
to the farms, asking who willing to come to the protests, and
we also received information that this protest will last 90
days, so the farm leader started gathering the information,

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putting people in place, and was also printing materials for
the protests.
Q. Which farm leader are you referring to?
A. At the time I'm associated with the new farm, it's called
the Washington, DC Farm.
Q. And what types of materials did the farm leader print in
connection with the 90 Days Protests?
A. There were posters, banners, and flyers.
Q. Can you describe for the jury some of the posters that were
created for the protests.
A. Yes.  Some poster have the attorney's Luc's image, his
photos on it, but was altered, was also added with titles,
especially some offensive, some kind of meaningful——very mean
labels on that posters.
Q. What are some examples of the language that was added to
those posters that were used in connection with the protests?
A. Mostly they called him CCP running dog, evil.
Q. At the time of the 90 Days Protests in 2022, did you
believe that Luc Despins was——and I'm quoting the language——a
CCP running dog?
A. At that time I believed it.
Q. Why did you believe it?
A. Because Miles Guo mentioned the extortion and Miles Guo
mentioned Luc Despins' firms was bribed by the CCP.
Q. At the time in 2022, did you have any personal knowledge of

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whether Luc Despins had extorted or attempted to extort Miles
Guo?
A. No.
Q. At the time in 2022 did you have any personal knowledge of
whether Luc Despins' firm had been influenced by the CCP?
A. No.
Q. Sitting here today, do you believe that Luc Despins was
operating on behalf of the CCP?
MR. KAMARAJU:  Objection, your Honor.
THE COURT:  If you'll step up, please.
(Continued on next page)

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(At the sidebar) 
THE COURT:  Why would his belief today be relevant?
MS. MURRAY:  Your Honor, because it goes to the fact
that at the time he was operating on——his intent to behave and
participate in the protest was what he was told by Mr. Guo.
THE COURT:  So you've established that.
MS. MURRAY:  Yes.
THE COURT:  But then you've asked what he believes
now, and I'm trying to understand why that would be relevant.
MS. MURRAY:  I think it goes, your Honor, to the——what
I'm going to be getting to at the end, which is when he came to
the realization that this was all fraudulent.  He was a
believer in Miles Guo up until basically after the arrest, and
then at some point he came to realize that what Miles Guo was
telling him about the CCP's influence, about, you know, the
closing bank accounts because of the CCP, about all these
activities was not in fact true, and that was the moment when
he kind of came to the realization, and I expect that
Mr. Kamaraju is going to be cross-examining him on what his
belief was at the time and what, you know——why he is now
testifying for the government.  And I'm just trying to
establish that.
MR. KAMARAJU:  Well, I don't think his belief sitting
here today on the stand as to whether Mr. Despins is an agent
of the CCP has any relevance to the line of inquiry that

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Ms. Murray is talking about.  If she wants to ask him questions
like, you know, when did you become suspicious, that's still at
a point back in time, has nothing to do with what he's saying
now, what he's getting at now.
THE COURT:  So stick to that sort of question.
MS. MURRAY:  Okay.
MR. KAMARAJU:  Thank you, your Honor.
(Continued on next page)

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(In open court) 
THE COURT:  You may continue.
MS. MURRAY:  Thank you, your Honor.
BY MS. MURRAY:  
Q. Mr. Zhou, what, if anything, was your role with respect to
the 90 Days Protest?
A. My role was streaming technician.  I used software to push
out the broadcast.  I connect the farm and the guests.  Also, I
make schedule for the technician parts, who do that daily
streamings.
Q. And who, if anyone, gave you instructions regarding how to
stream the 90 Days Protests?
A. There were guidelines provided by the Himalaya Global
Alliance, some guidelines specific, during the protests, if we
hear any the guests, or the farm guests, that mention Miles Guo
or if they say something that was organized, we'll cut the
streaming.
Q. Can you just explain that guideline a little bit more so
that the jury understands.  What was the instruction that was
given regarding streaming if someone mentioned Miles Guo?
A. Yes.  Because all the streaming was conduct lively, there
were people at the protest locations linked to remote guests.
As technician on the back end, so we would receive these
instructions:  If either one inside the streaming, the image,
or guests spoke that, I'm here protest today, it's because

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Miles told me, or the organization told me come, if that words
said, we'll automatic cut the streamings.
Q. And did there come a time when you were streaming the 90
Days Protests that you had to cut the transmission because of a
reference to Miles Guo?
A. I personally did once.
Q. I'd like to return for a moment to the Himalaya Coin
investment.
MS. MURRAY:  Ms. Loftus, if you could please publish
what's in evidence as Government Exhibit V0107 and V0108.
All right.  Actually, we'll move along for a moment.
Ms. Loftus, if you could please publish Government
Exhibit V0105.
A. Sorry.  My——oh, got it.
Q. Mr. Zhou, do you recognize Government Exhibit V0105?
A. Yes.
Q. What is it?
A. This is a meeting attended on Webex with Miles Guo and the
UK London Club members.
Q. Starting at the top left, who is that in the screen that's
shown on the top left?
A. That's me.
Q. And just to the right of you, who is that?
A. Miles Guo.
Q. In the image next to Miles Guo, on the other side of you,

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it appears that there's a poster.  Can you read what that
poster says.
A. Yes, thank you.  Speaking Himalaya London Club UK.  Host.
Q. Sorry.  Just to the left of that, there's a screen with
just a white wall and a poster.  What does that poster say?
A. Oh, on the——I'm sorry.  Okay.  Got it.
New Federal State of China.
Q. And now going one further to the right, which you just
read, what is it indicating about the person who's depicted in
that screen?
A. That's UK London Club leader David Dai, and he hosts the
Webex software.  The meeting was launched by his account.
Q. And do you recognize the flag behind David Dai?
A. Yes.
Q. What is it?
A. That's NFSC flag.
MS. MURRAY:  Ms. Loftus, if we could take that down
and put up for the witness what's marked as Government Exhibit
V0106.
Your Honor, just in an abundance of caution, the
government moves to admit the prior exhibit, which is
Government Exhibit V0105.
MR. KAMARAJU:  No objection, your Honor.
THE COURT:  It is admitted.
(Government's Exhibit V0105 received in evidence)

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MS. MURRAY:  And this is Government Exhibit V0106.
This is shown just to the witness right now.
BY MS. MURRAY:  
Q. Mr. Zhou, do you recognize Government Exhibit V0106?
A. Yes.
Q. Generally speaking, what is it?
A. It's another meeting I participated.  This meeting was with
Miles Guo and——and it was Iron Blood members with other farm
members.
MS. MURRAY:  Your Honor, the government moves to admit
Government Exhibit V0106.
MR. KAMARAJU:  No objection.
THE COURT:  It is admitted.
(Government's Exhibit V0106 received in evidence) 
MS. MURRAY:  Could we please publish.
BY MS. MURRAY:  
Q. Mr. Zhou, starting at the top left here, who is depicted
there on the top left of this screenshot?
A. It's another farm leader.
Q. The leader of which farm?
A. Japan, Tokyo Stellar IS Farm.
Q. On the top right, who is depicted in the screen that's
shown there?
A. He's NFSC chairman.
Q. And then looking at the bottom left, who is the person

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standing in what's depicted there?
A. Miles Guo was standing.
MS. MURRAY:  Ms. Loftus, if we could zoom in on that
bottom left screen, please.
Q. Mr. Zhou, do you recognize anyone else who is depicted in
that particular screenshot?
A. Yes.
Q. Who?
A. All of them.
Q. All of them?
A. Yes.
Q. Can you describe, generally speaking, who these people are
and what their roles were.
A. Right next to the Miles Guo, this lady, her name is called
Justice Sara.
Q. And then the male depicted seated kind of in the back on
the left side?
A. Yeah.  His name Long Island David.
Q. What farm, if any, is Long Island David associated with?
A. He was associated with Mountain Spice New York.
Q. And then to the right, the individual who is second from
the right in the back of the table here?
A. Her name was Fay Fay.
Q. And then finally, the person who's farthest right in this
photo?

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A. Her name was Ruth Ray.
Q. Generally speaking, what was discussed during this meeting
that you participated in?
A. This meeting was gathered a lot of other farms management
team, farm leaders, and some even invited members, discuss
about some issues reported to the Himalaya Global Alliance.
MS. MURRAY:  You can take that down, Ms. Loftus.
Thank you.
Q. Mr. Zhou, did there come a time when the UK Farm asked for
your assistance with certain banking activities?
A. Yes.
Q. Around when was that?
A. That's February 2022.
Q. And who was the leader of the UK Farm at the time?
A. David Dai.
Q. Can you describe for the jury what, if anything, David Dai
asked you to do.
A. Yes.  He called me personally, asked me if I could help
this farm and help all the followers to receive money and to
help them to invest into the G series.
Q. And what, if anything, did David Dai say about why he
wanted your assistance?
A. Because he had few other people established business and
open banking accounts, but they were shut down, and they needed
still people to open more accounts to help the followers.

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Q. What, if anything, did David Dai say about why those
accounts had been shut down?
A. Some accounts, they were just mentioned because of CCP
don't want those people to invest, and all CCP is doing, those
accounts were being shut down.
Q. At that time in February of 2022, did you believe that bank
accounts had been closed because of the CCP?
A. Yes, at that time I believed.
Q. What, if anything, did David Dai direct you to do with
respect to opening bank accounts?
A. Yes.  We talked about how to open an account, what to tell
the bank, and also gave me instruction with open business, will
have him as hundred percent owner.
Q. And what, if anything, did David Dai tell you to tell the
bank as the purpose of those accounts?
A. Because of course David Dai also knows about my personal
life as also my occupancy [sic] as a realtor, so he instructed
that he mentioned it will be easier if I mention this account
when we establish it's for real estate development.  They're
also matching my current occupancy so that will not trigger
much of the flak, that will be more susceptible to open the
account.
Q. Did you follow David Dai's instructions and in fact open
bank accounts?
A. Yes, I did.

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Q. After you opened those bank accounts did money come into
the accounts?
A. Yes.
Q. Approximately how much money, in total?
A. Estimate about $2 million.
Q. Were you able to determine the source of the money that
came into your bank accounts that you opened?
A. I only able to see the wire, if it's from individual, or
some of the wires, it's from business accounts.
Q. Do you know how those individuals knew to send money to
your bank accounts?
MR. KAMARAJU:  Objection, your Honor.
THE COURT:  Sustained.
Q. Mr. Zhou, you mentioned that you saw incoming wires into
the accounts; is that correct?
A. Yes.
Q. Did you provide the account information to any of the
individuals who wired money into your accounts?
A. No.
Q. Do you know who, if anyone, provided your bank account
information to those individuals?
A. Yes.
Q. Who?
A. One of the member from UK London Club.
Q. What, if anything, did you do with the money that came into

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your bank accounts that you had set up?
A. When I see the money, I will bookkeep, document it with a
spreadsheet created by the UK leader.  Once reached certain
amount, I would receive instruction to where to send the money
to.
Q. From whom, if anyone, did you receive instructions
regarding where to send the money?
A. The farm, the UK leader, and also other few the UK members.
Q. Were you paid for opening those accounts?
A. No.
Q. Did you keep any of the money that came through those
accounts?
A. No.
Q. I want to return for a moment to the Himalaya Exchange.
MS. MURRAY:  I'm going to try to do this old school.
Your Honor, these are, again, V0107 and 108.  I
believe just before the break these were admitted, but again,
in an abundance of caution, if they weren't formally admitted,
we would move to admit.
THE COURT:  No objection?
MR. KAMARAJU:  No, your Honor.
THE COURT:  They are admitted.
(Government's Exhibits V0107 and V0108 received in 
evidence) 
MS. MURRAY:  So this is Government Exhibit V0107.  If

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we could publish to the jury.
Can we publish that, please.  Thank you.
BY MS. MURRAY:  
Q. Mr. Zhou, before we took the break, we were looking at
this.  This was something that was sent, I believe you said it
was in your computer; is that correct?
A. Yes.
Q. Did you prepare this spreadsheet?
A. No.
Q. Do you know who prepared this spreadsheet?
A. I don't know.
Q. Who sent this to you?
A. One of the UK member.
Q. I want to just talk through a couple of the different
columns here and what's reflected.
First of all, there is a column——the second column
says Discord Discord.  Do you see that?
A. Yes.
Q. What information is shown there?
A. Coffee Cantata, then two Chinese words.
Q. Do you know who, if anyone, uses the Discord user name
Coffee Cantata?
A. I used it.
Q. Looking across the rows here, can you explain for the jury
what information is reflected in the top portion of this

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spreadsheet.
A. Sure.  Under the Member ID Number, Member, UK2020H170, it's
unique ID assigned to me for investment.
Move to the right, after the Discord Discord, on top
account called A005, that's the investment account calls
created by the Himalaya Global Alliance.
Right next to it, Coin Rates.  That's reflects to
Himalaya Coins, as 0.5.
Then right after, it's the Chinese translate to
investment a month.
Then right after, next column, it's Chinese reflect to
translate to welfare coins numbers, which reflect to H Coins
numbers.
Q. So focusing on the different rows, and is it correct that
the second-to-the-most-right column, the one with the little
emoji or the icon, that column reflects investment amounts; is
that correct?
A. Yes.
Q. So taking the first row, what investment, if any, is
reflected there at 59.93?
A. That reflected to an investment called Apple Coins.
Q. And was that an investment that you made in connection with
the G series offerings?
A. Yes.
Q. Looking at the next row, 31,300, what investment, if any,

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does that reflect?
A. That reflect to VOG investments.
Q. And that was in connection with which company's private
placement?
A. Guo Media's, GTV placement.
Q. Looking at the next two rows, both of them have account
code 8142.  50,000 and 20,000.  What investment, if any, does
that relate to?
A. The $50,000 reflect to my G club tier 5 investments;
$20,000 reflect to G club tier 2 investments.
Q. And then the next row, the 21,000, what investment, if any,
does that reflect?
A. That reflect to my UK Farm loan agreement investments.
Q. And finally, the row that's 1500, what, if anything, does
that reflect?
A. That reflected to my donations.
Q. And so looking at the rightmost column, what information is
in the rightmost column that was relevant to your Himalaya Coin
purchase?
A. So that's using the coin rates calculation, 0.5, multiplied
by my investment, how much coin I will receive.
Q. And how much coin did you receive based on your prior
investments?
A. 40,935 coins.
MS. MURRAY:  We can take this down.

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Q. Mr. Zhou, did there come a time when you requested a refund
of any of the money that you had invested in the G series?
A. Yes, I did.
Q. Approximately when was that?
A. July 15, 2023.
Q. And which money, if any, did you request to have refunded?
A. I request my G Club investment refund.
Q. How did you request a refund of your G Club investment?
A. As instructed, for all the matters, I shall contact the
farm leader first, so I contact Washington, DC farm leader to
request the refund.
Q. And what, if anything, was the response to your refund
request?
A. It wasn't a pleasant——first they just provide a request
form, asked me to fill it out.
Q. Did you complete that form?
A. Yes, I did.
Q. What happened next?
A. Then for a very long period of time I didn't get any
response, so I have to contact them back and do a follow-up,
multiple follow-ups.  But they were trying to verify my
investments.
Then later, they asked me to fill out my request form.
They asked me they only will return HDO to me, not as fiat
currency to me.

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Q. And just to be clear, when you say HDO, what are you
referring to?
A. Himalaya dollars.
THE COURT:  And what do you mean by fiat currency?
THE WITNESS:  Because all my investment originally
send it to investment——G series investment using wires, paid in
the dollar.
THE COURT:  So you're saying dollars are fiat
currency?
THE WITNESS:  Correct.
BY MS. MURRAY:  
Q. And Mr. Zhou, at the time that the farm offered to refund
your G/CLUBS money in HDO, did you have access to a Himalaya
Exchange account?
A. I don't.
Q. Did you have access to any of the Himalaya Coins that you
had sent money to the farm to purchase?
A. I don't.
Q. At that time that you requested the refund and it was
offered in HDO, did you have personal knowledge whether you in
fact owned Himalaya Coins or Himalaya dollars?
A. I addressed that.  I——
Q. What do you mean by that?
A. I told them that this request to return my investment in
HDO is not acceptable because I don't have HDO accounts,

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Himalaya Exchange accounts, so I said I will only receive in
the currency which is fiat currency.
Q. And what, if anything, was the response to your saying that
you wouldn't accept HDO for your refund?
A. So there's another long period of waiting time.  They just
asked me to wait.
Q. Did there come a time when you received a refund of your
G/CLUBS money?
A. Yes, I did.
Q. Around when was that?
A. December 1, 2023.
Q. And what were the circumstances of your receiving that
refund?
A. I have to sign a forfeit H Coin agreement and I also have
to return some equipments to them, so that's all the terms I
have to agree to.
Q. Taking the equipment, what type of equipment were you
required to return?
A. Just because I was——as a streaming technician, Washington,
DC Farm sent over certain equipment for the broadcast
equipments I at the time was holding.  So in a month, once I
request my refund, they would ask me to also return the
equipment as well.
Q. You also mentioned you had to sign something forfeiting
your Himalaya Coin for the refund.  Can you explain that to the

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jury, please.
A. Yes.  Since I made a refund request, then they also send me
agreement that I have to forfeit all the H Coin was previously
acquired from investments.
Q. And how much had you paid for that H Coin that you had to
forfeit?
A. Total, I paid 5500 for the coins.
Q. Did you in fact sign that agreement to forfeit the $5,500
worth of H Coin?
A. I have no choice.  I was forced to sign that.
Q. At some point after you requested a refund of your G Club
money, how, if at all, did the whistleblower movement respond?
A. From——
MR. KAMARAJU:  Objection, your Honor.
THE COURT:  As to form, sustained.
Q. Mr. Zhou, did anyone within the whistleblower movement, to
your knowledge, become aware that you'd requested a refund?
MR. KAMARAJU:  Objection, your Honor.  Same.
THE COURT:  Sustained.
Q. Mr. Zhou, did there come a time when you were removed from
the UK Farm?
A. Yes.
Q. Can you describe what happened.
A. Right after I returned equipment, the farm leader just
remove me out of the Discord server, cut all the

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communications, and also they removed me out of all the working
channels, either the farm, Discord, WhatsApp, I was completely
removed.
Q. Around when did that happen that you were removed from the
farm Discord channel?
A. That was in September 2023.
Q. Directing your attention to January of 2024, did there come
a time when your information was posted on Gettr?
MR. KAMARAJU:  Objection to form, your Honor.  What
information?
THE COURT:  Sustained.
MS. MURRAY:  Why don't we just pull up Government
Exhibit V02, which is in evidence.
Q. Mr. Zhou, do you recognize this?
A. Yes.
Q. What is it?
A. This is a post on gettrsocialmedia.com.
Q. And can you just remind the jury what Gettr is.
A. Yes, Gettr was of the G series.  It's a social platform
created by Miles Guo and it's similar as the Twitter's.
Q. Looking at the English translation that was associated with
this post, can you read the title of this announcement.
A. Global Himalayan Farm Alliance Blacklist Announcement.
Q. What, if anything, do you understand a blacklist to be with
respect to the Himalaya Farm Alliance?

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A. For anyone accused who are against this movement, or Miles
Guo personally, would be put on the blacklist.  
Q. Looking at item 2 that's listed here, can you please read
that.
A. I'm sorry.  One more time, please.
Q. Yes.  Can you read item 2 that's listed here.
A. Yes.  On January 21, 2024, Washington, DC Farm and the
collations made the following blacklist decision:  Blacklisted,
Coffee Cantata, Wen Lu, in Chinese.  No. 5082-Coffee Cantata.
Reason for exclusion, malicious attack on whistleblower
revolution and the G series.  Blacklist persons have the right
to submit an appeal within five days of the day of
announcement, and appeal will be ignored.
Q. Mr. Zhou, Coffee Cantata, is that——that's the user name
that you used?
A. Yes.
Q. Were you given any notice in advance of this blacklist
announcement being posted on Gettr?
A. No.
Q. What was your reaction, if any, to being posted publicly on
the blacklist?
A. First, I saw this afterwards.  That just not the truth.  I
never attacked the whistleblower movement, or the G series.
Q. Did you appeal this blacklist decision?
A. Because what I saw was already after the appeal dates,

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allowance dates.
MS. MURRAY:  We can take this down, Ms. Loftus.  Thank
you.
THE COURT:  What is your answer, sir?  She asked
whether you appealed.
THE WITNESS:  I couldn't because I saw this post was
after this appealing allowance dates.
THE COURT:  You may continue.
MS. MURRAY:  Thank you.
BY MS. MURRAY:  
Q. Did there come a time when you stopped supporting Miles
Guo?
A. Yes.
Q. Around when was that?
A. That's around June 2023.
Q. Why did you stop supporting Miles Guo around June of 2023?
A. Because there's a lot of the movement, the actions, I
personally seen is wrong, I——I don't want to be part of it, so
that's why I made the decision to stop.
Q. Can you describe some of the actions that you're referring
to.
A. Because there's also province within the farms and the
Global Alliance.  Especially the UK London Club, the leader was
accused of misproper use the Rule of Law Foundation monies.
There's a lot of problems never get really solved.  And we——I

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have personally reported a lot, a lot of the problems, never
got answer or solved.
Q. Mr. Zhou, in total, how much money did you spend on the G
series offering we've been discussing?
A. Total about $120,000.
Q. And how did you pay for those investments or those costs of
the G series?
MR. KAMARAJU:  Objection, your Honor.
THE COURT:  Sustained as to form.
Q. Mr. Zhou, what was the source of the money that you spent
on the G series offering?
MR. KAMARAJU:  Same objection.
THE COURT:  Step up, please.
(Continued on next page)

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(At the sidebar) 
THE COURT:  So are you objecting on the basis that it
isn't established that there was an offering?
MR. KAMARAJU:  No, I'm objecting on the basis that the
source of the money to pay for the offering is irrelevant.
THE COURT:  Overruled.
(Continued on next page)

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(In open court)
THE COURT:  Overruled.  You may answer.
THE WITNESS:  Yes, your Honor.
A. The source of the money was from my personal earnings, and
also I sold my properties, condominium I sold, and I also took
out my wife's life insurance.
Q. Why did you sell your condos, your personal real estate
property?
A. Because I——at the time I need to cash the Himalaya Exchange
coin launch, but I invest into G Club, so at the time I don't
have enough capital, but I——only thing I had was my
condominium.  I have to——and I sold it.
Q. What about your wife's life insurance?  Why, if at all, did
you cash out the life insurance policy?
A. That money, she agreed to put it into the farm loan.
Q. Mr. Zhou, how much profit, if any, did you make from the
120,000 or so that you spent on the G series offerings?
A. Zero profit.
Q. How much money in total did you lose, if any, through those
offerings?
A. I lost about $30,000.
Q. $30,000?
A. Or more.
Q. At the time that you invested in the G series offerings,
did you believe that they would be profitable?

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A. Yes.
Q. At the time that you invested in the G series offerings,
did you believe that Miles Guo would personally pay for any
losses that you sustained from those investments?
A. At that time I believed it.
Q. Did Guo in fact repay you for the approximately $30,000
that you lost through the G series investments?
A. No.
MS. MURRAY:  May I have a moment, your Honor.
Nothing further.
THE COURT:  Cross-examination.
MR. KAMARAJU:  Yes.  Thank you, your Honor.
CROSS EXAMINATION 
BY MR. KAMARAJU:  
Q. Good afternoon.
A. Good afternoon, sir.
Q. I just want to make sure I'm pronouncing your last name
correctly.  Mr. Zhou?
A. Correct.
Q. Okay.  Thank you.
Now you just testified that Mr. Guo has never repaid
you the amount that you say that you lost, correct?
A. Correct.
Q. You've never spoken with Mr. Guo, right?
A. I spoke to him.

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Q. You spoke to him about getting the money back?
A. No.
Q. You've never asked him to get any money back, correct?
A. I mailed it to him.
Q. You mailed it to Mr. Guo?
A. Yes.
Q. Mr. Guo doesn't use email, correct?
A. I mailed it to——
MS. MURRAY:  Objection.
THE COURT:  Sustained.
Q. You've never emailed Mr. Guo before, have you?
A. I didn't email to him.
Q. Okay.  So he's never responded to an email that you've
sent, correct?
A. Never responded.
Q. And he's never sent you personally an email, correct?
A. Correct.
Q. Okay.  Now I want to start with the Rule of Law Foundation.
Do you remember testifying about that?
A. Yes.
Q. And you testified that you first heard about it at a press
conference in November 2018, correct?
A. Correct.
Q. And your testimony was that you left that press conference
with the impression that Mr. Guo was going to fund the Rule of

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Law Foundation to a hundred million dollars, correct?
A. Correct.
Q. And that's what the prosecutors asked you here today,
right?
A. Yes.
MR. KAMARAJU:  Could we have Government Exhibit
W1005V, please.  It's in evidence, so we can publish it.
If we can just play it a little bit.
(Video played)
MR. KAMARAJU:  Okay.  We can pause right there.
Q. Now they asked you about this clip earlier, correct?
A. Yes.
Q. They asked you whether you had an understanding that
Mr. Guo had made a representation about funding a hundred
million dollars to the Rule of Law Foundation, correct?
A. Correct.
Q. Okay.  That's not Mr. Guo, right?
A. That's not.
Q. That's Steve Bannon, right?
A. Correct.
Q. Steve Bannon looks nothing like Mr. Guo, right?
A. No.
MS. MURRAY:  Objection, your Honor.
THE COURT:  Overruled.  Go ahead.
Q. This is Steve Bannon talking, correct?

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A. Correct.
Q. So they asked you a question about representations Mr. Guo
made, but they showed you a clip of Mr. Bannon, correct?
A. Correct.
Q. But then you answered that your expectation was Mr. Guo was
going to fund the payment, right?
A. Correct.
Q. Now this isn't the first time that you've seen this video
clip, right?
A. Correct.
Q. You've seen it when you prepared with them before, right?
A. I saw it at the live——when this press conference live.
Q. Okay.  We'll come back to that.  But you've also seen it
with the prosecutors, right?
A. Yes.
Q. They've showed it to you before today, right?
A. Yes.
Q. They showed it to you when you prepared your testimony with
them, right?
A. Not prepared the testimony, but they showed it to me.
Q. Okay.  Well, you've met with the prosecutors multiple
times, right?
A. Yes.
Q. These prosecutors sitting at the table here, right?
A. Not all.

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Q. Some of them, right?
A. Yes.
Q. Which ones?
A. Four of them.
Q. Okay.  So the four people sitting here at the front of the
table?
A. Not the left four but——
Q. Okay.  Some set of those people, correct?
A. Correct.
Q. And there was an FBI agent there, right?
A. No.  I don't know.
Q. There wasn't an FBI agent there the first time you met with
the prosecutors?
A. I don't know if the FBI.  I don't know.
Q. Was there a translator there the first time you met with
the prosecutors?
A. No.
Q. There was no translator when you first met with them?
A. No translator.
Q. So you've never used a translator to speak with the
prosecutors; is that right?
A. I didn't use translators.
Q. Okay.  Now you testified that they showed you this clip
during one of those meetings, right?
A. Correct.

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Q. How many meetings would you say you had with the
prosecutors?
A. About seven.
Q. About seven, right?
A. Yes.
Q. So that's seven times where you've met with the prosecutors
to discuss the testimony that you gave today, right?
A. Not discuss.
Q. Okay.  What did you talk about for seven meetings then?
A. So I was being just asked the answer.
Q. Okay.  Well, what were they asking you about?
A. Asked related to the cases.
Q. Right.  They asked you the same questions they asked today,
right?
A. Correct.
Q. And you gave the answers, right?
A. Yes, I did.
Q. Okay.  And sometimes if they didn't like one of your
answers, they asked a different question, right?
A. No.
Q. So you're telling me during seven meetings there was no
point where they asked you a follow-up question; is that your
testimony?
A. They asked follow-up——
MS. MURRAY:  Objection.

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THE COURT:  Sustained.  Sustained as to what they were
thinking.
MR. KAMARAJU:  Oh.  My apologies, your Honor.
THE COURT:  You may ask whether they asked follow-up
questions.
MR. KAMARAJU:  Oh, sorry.  I thought that's what I
asked.
BY MR. KAMARAJU:  
Q. So over the course of seven meetings, it's your testimony
that the prosecutors never asked you a follow-up question?
MS. MURRAY:  Objection.  Mischaracterizing the
witness's testimony.
THE COURT:  Sustained.
Q. Okay.  Now you testified that you have seen this clip both
during a meeting with the prosecutors but you also saw it live,
correct?
A. Correct.
Q. Okay.  Now this clip is not everything that even Mr. Bannon
has to say at that press conference, right?
A. That's correct.
Q. He gives much longer remarks, right?
A. Yes.
Q. He takes questions from the press, right?
A. Yes.
Q. Okay.  He talks about efforts that Mr. Guo has made in

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support of the anti-CCP movement, right?
A. Yes.
Q. He talks about Guo Media, correct?
A. Yes.
Q. In fact, Mr. Bannon was even asked a question about whether
the Trump administration was involved, right?
MS. MURRAY:  Objection, your Honor.
THE COURT:  Overruled.  You may answer.
A. No.
Q. You don't recall that?
A. Never asked.
Q. Okay.  So your testimony was Mr. Bannon was never asked
that question, right?
A. Could you repeat that one more time, please.
Q. Yeah.  Was Mr. Bannon asked by a reporter whether the Trump
administration would be involved with the Rule of Law
Foundation?
A. No.  Mr. Bannon never mentioned about Trump.
Q. Okay.  And he was never asked, right?
A. In that conference, no.
Q. Okay.  Now Mr. Guo did speak at that conference, correct?
A. Yes.
Q. Okay.  And I think you talked about a few of the topics
that he discussed during your direct testimony.  Do you
remember that?

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A. Which topics?
Q. Well, and forgive me if I get it wrong, but I believe one
of the things you said was that he discussed investigating
business deaths.  Do you remember testifying about that?
A. I'm sorry.  Not invest——business stats,
investigate——Mr. Bannon said investigate mysterious Chinese
businessmen's deaths.
Q. Okay.  What is that a reference to?
A. That reference to how this Rule of Law Foundation fund will
be used.
Q. Okay.  Well, Mr. Bannon also talks about the fact that
there had been an investigation into the death of a Chinese
businessman, correct?
A. Correct.
Q. It was a chairman of a company called HNA, correct?
MS. MURRAY:  Objection.
THE COURT:  Overruled.  You may answer.
A. Yes.
Q. And Mr. Guo had previously predicted the death of the
chairman of HNA, correct?
MS. MURRAY:  Objection, your Honor.  Hearsay and
relevance.
THE COURT:  Sustained.
MR. KAMARAJU:  I'm not offering it for the truth, your
Honor.

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THE COURT:  If you'll step up.
(At the sidebar) 
THE COURT:  The question was:  And Mr. Guo had
previously predicted the death of——
MR. KAMARAJU:  Yes.  I'm not offering it for the truth
of the man's death, just simply that he predicted it, that he
heard him say it.
THE COURT:  During the conference?
MR. KAMARAJU:  No.  Prior to the conference, your
Honor.
THE COURT:  Well, how is it relevant?
MR. KAMARAJU:  Because the witness testified that
Mr. Guo had revealed what he referred to as classified
information and that's one of the things that attracted the
witness.  I don't mean classified in the setting that American
government uses it.  I mean confidential information about the
Chinese government, and that was what attracted him.  I'm just
following up.  I don't intend to spend a long time on it.  I
have two more questions.
MS. MURRAY:  I don't see how it's not hearsay.  I
don't see how it's relevant.
THE COURT:  I just don't recall this testimony that
you're referring to, that you're saying this witness said that
one of the reasons he was attracted to Mr. Guo was because he
mentioned the death of a businessman?

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MR. KAMARAJU:  No.  He said that he knew that Mr. Guo
had unknown details.  He referred to it as classified
information.  I'm not calling it that.  But he referred to
secret information about Chinese government officials, and
that's what Mr. Guo was revealing; that's one of the things
that attracted him.
THE COURT:  I have to say I don't recall that
particular testimony.  Is that what he said?
MS. MURRAY:  He indicated that it was one of the
topics that Miles Guo had covered in his broadcast.  But first
of all, I think that the statement that Mr. Kamaraju is
referring to is not even covered in this broadcast.  It's an
out-of-court statement by Miles Guo.  I also don't think that
the alleged prediction of the death of a Chinese businessman
falls within this broad category of potentially classified
information about Chinese government officials.  I just don't
see the connection.
THE COURT:  So this prediction does not occur at the
conference.
MR. KAMARAJU:  No.  Before the conference Mr. Guo
predicts that it will happen.  The death happens prior to the
conference.  Mr. Bannon then notes at the conference that one
of the things that Mr. Guo has done is an investigation into
the death of the businessman.
THE COURT:  Okay.  I'm going to allow the question.

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MR. KAMARAJU:  Thank you, your Honor.
(In open court) 
THE COURT:  Overruled.
BY MR. KAMARAJU:  
Q. Sir, do you remember the question?
A. Could you please repeat it, please.
Q. Yes.
MR. KAMARAJU:  I'm sorry to do this, but would the
court reporter mind reading back the question, please.
(Record read) 
THE COURT:  You may answer.
THE WITNESS:  Yes, your Honor.
A. Yes.
Q. And Mr. Bannon discussed that at the press conference,
correct?
A. Yes.
Q. He talked about that Mr. Guo will send people to
investigate the death, correct?
MS. MURRAY:  Objection.
THE COURT:  Overruled.  You may answer.
A. That part I don't remember.
Q. Okay.  What do you——you don't remember Mr. Bannon talking
about Mr. Guo sending investigators——
MS. MURRAY:  Objection.  Asked and answered, your
Honor.

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THE COURT:  Sustained.  Go ahead.
Q. Now you testified on direct about your understanding of
what the NFSC is, correct?
A. Correct.
Q. And just remind us, what does NFSC stand for?
A. New Federal State of China.
Q. All right.  And it's comprised of individuals who would
like to take down the Chinese Communist Party, fair?
A. Yes.
Q. And you were one of those people, right?
A. Yes.
Q. And so you shared that goal, right?
A. Yes.
Q. And now the NFSC, that's the New Federal State of China,
right?  We're talking about the same thing?
A. Yes.
Q. The NFSC was founded on June 4, 2020, correct?
A. Correct.
Q. You watched the video about that founding, right?
A. Yes.
Q. Mr. Guo was there, correct?
A. Correct.
Q. He was in front of the Statue of Liberty, right?
A. Not in front of it.  He was on his boat.
Q. Okay.  So the boat was in front of the Statue of Liberty,

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right?
A. Close to it.
Q. And there were other people who appeared in the video,
correct?
A. Yes.
Q. One was a famous Chinese soccer star, right?
A. He appeared on stream, online.
Q. Okay.  So you could see him during the broadcast, right?
A. Yes.
Q. Mr. Bannon was there also, right?
A. Correct.
Q. And they were talking about the founding of this
alternative government, right?
A. Yes.
Q. Okay.  And this is during the COVID pandemic, correct?
A. Yes.
Q. Okay.  Now you talked a little bit about this on direct,
but the idea is that the NFSC would be an alternative
government to the Chinese Communist Party, right?
A. Yes.
Q. And so you used the word on direct "ecosystem," there were
various businesses that comprised the ecosystem of the NFSC,
correct?
A. Yes.
Q. So you talked about GTV, right?  You testified about GTV.

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That was one of the companies that would be in the ecosystem?
A. Yes.
Q. And G/CLUBS, that was another company that would be in the
ecosystem, right?
A. Yes.
Q. And the Himalaya Exchange, that was another company that
would be in there, right?
A. Yes.
Q. And each of these different components had a role to play
as part of that ecosystem, correct?
A. The goal was the same.
Q. They had a different purpose is what I'm trying to get at,
right?
A. Purpose is all the same.
Q. Okay.  Well, let me try it this way.  So GTV was a social
media company, right?
A. Yes.
Q. Himalaya Exchange was a cryptocurrency exchange, right?
A. Yes.
Q. And they both do different things, right?
A. Correct.
Q. But they're both——they were both intended to be part of the
larger NFSC goal, right?
MS. MURRAY:  Objection.
THE COURT:  Overruled.  You may answer.

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A. Yes.
Q. So in terms of purpose, GTV was intended to be sort of a
social media platform that was devoid of CCP censorship,
correct?
A. Yes.
Q. And G/CLUBS was a way for NFSC members to associate with
each other, correct?
A. No.  It's for investments.
Q. It's for investments.
A. Yes.
Q. Didn't you testify on direct that you were going to get a
passport as part of G/CLUBS, right?
A. Yes.
Q. And that passport was going to be an NFSC passport, right?
A. Yes.
Q. Okay.  So G/CLUBS was for NFSC members, among other
reasons, to associate with each other, correct?
MS. MURRAY:  Objection, your Honor.  Asked and
answered.
THE COURT:  I'm going to allow the question.
A. Not to socialize with other members, because each investor
is individually.  We don't know their informations.
Q. So you joined G/CLUBS, right?
A. Yes.
Q. Okay.  When you joined G/CLUBS, were you proud of joining

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G/CLUBS?
A. Yes.
Q. Okay.  You were showing your commitment to the NFSC; that
was one of the reasons why you bought a G/CLUBS membership,
right?
A. I want to get stock and also get a passport, which was
promised.
Q. Okay.  I didn't ask you what was promised.  I just asked
why you did it, right?
MS. MURRAY:  Objection, your Honor.
THE COURT:  So don't testify.
Q. Okay.  You mentioned that you wanted to get a passport,
right?
A. Yes.
Q. And that was the NFSC passport, right?
A. Yes.
Q. All right.  You also testified about the farm loans, right?
A. Yes.
Q. And the farm loans were intended to provide funding for the
farms' work, right?  
A. That was the fund, what will be used for.  
Q. Right.  And you testified on direct, you said it would be
used for the working capital of the farms, right?
A. Correct.
Q. So that's the farms' business, right?

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A. Farm can use it as operation capitals.
Q. Okay.  So the farm has discretion to use it on its
operations, right?
A. Yes.
Q. So if the farm decides they want to spend it on this, they
can spend it on this; if they want to spend it on that, they
can spend it on that, right?
A. There's also restriction.
Q. Okay.  And that restriction was found in the loan
agreement; is that right?
A. I don't remember that.
Q. Okay.  So you don't remember where this restriction is
located, right?
A. Where located, I don't remember.
Q. Okay.  Now I believe you lived in China until 1998,
correct?
A. Correct.
Q. And the political goals of the NFSC, is it fair to say
they're easier to support in the United States than in China?
A. Yes.
Q. Here you had the choice to spend your money on those
products, right?
A. On which products?
Q. Well, just take G/CLUBS, right?  That was your choice; you
could spend on it, right?

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A. Yes.
Q. Like there was no government agency that stopped you from
spending on it, right?
A. Correct.
Q. And like this hat that you testified about, this was your
choice, right?  You could buy this hat if you wanted to, right?
A. Yes.
Q. And the whistle that you talked about, your choice, right?
A. But all the purchases was also towards to grow the G
Fashions as one of the investments.  I treated it as not just
purely purchase items but to support the growth together.
Q. Okay.  To support the growth of the company, right?
A. As the shareholders.
Q. Okay.  But you weren't actually a shareholder in G Fashion,
right?
A. No.  Miles Guo mentioned our investment will including G
Fashion stocks.
(Continued on next page)

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BY MR. KAMARAJU:  
Q. You never had a share of G Fashion shares; correct, sir?
A. I don't have the shares.
Q. Okay.  You have no idea -- you have no idea how many shares
you even think you were promised, right?
A. Promised a dollar per shares.
Q. Okay.  So a dollar for everything you spent on G Fashion?
A. Not spend.  It was -- G Fashion was in the future, the G
Fashion's gross was towards to the G Series investments.
Q. Okay.  So going back to my original question though, that
was your choice to spend on that, right?
MS. MURRAY:  Objection.
THE COURT:  Overruled.  You may answer.
A. Yes.
Q. Now, sir, you testified on direct you're in the real estate
business; is that right?
A. Yes.
Q. And you've been in the real estate business for more than
ten years, right?
A. Correct.
Q. So you're pretty experienced in the business, right?
A. Yes.
Q. Your company is called East West Luxury Group; is that
right?
A. No, that's my small group.

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Q. I'm sorry?
A. That's my inner group.
Q. That's your inner group.  Okay.
What's the name of your company, I'm sorry? 
A. United Realty Group.
Q. And do you specialize in any particular kind of property?
A. Yes.
Q. What's that?
A. Residential.
Q. Okay.  Do you have a particular type of clientele?
A. What you mean by --
MS. MURRAY:  Objection, your Honor.
THE COURT:  Overruled.  You may answer.
A. I'm sorry, what do you mean by "particular"?
Q. Well, for example, do you specialize in high-end
residential properties?
MS. MURRAY:  Objection, your Honor.  402.  403.
THE COURT:  Overruled.  You may answer.
A. I just the residential.  I don't consider particular, if
it's a high-end or it's low-income or it's affordable housing.
Q. Okay.  So you run the gamut, basically?
A. Yes.
Q. Okay.  Now, you advise your clients in connection with
those transactions, right?
A. I'm sorry, which transactions?

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Q. Just your real estate business, right?
A. I'm only show the houses, provide informations on the
houses, but I don't control monies or receive the monies.
Q. No.  Sir, I'm not trying to trick you.  I'm not asking you
if you receive the money or don't receive the money.  All I'm
asking is, is you advise your clients in connection with the
purchase of their homes, right?
A. Yes.
Q. Okay.  And part of that advice is to tell them to pay
attention to the deal they're entering into, right?
A. Correct.
MS. MURRAY:  Your Honor, objection.  Sidebar.
(Continued on next page)

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(At sidebar) 
MS. MURRAY:  Your Honor, the Court previously ruled
that you can't get into the details of the decisions that
people made in the investments.  It's veering into negligence,
it's prejudicial, it's not relevant, this line of questioning.
And it's, I think, over the line of -- and the argument that
there was negligence associated with the investments that this
witness testified to.
MR. KAMARAJU:  I do not intend at all to argue
negligence.  The determination, one, it goes to materiality,
which the government has to prove.  Two, your Honor also said
that as part of materiality, we were allowed to inquire into
the sophistication of the potential investors' particular
trades that might make that a reasonable investor.
I'm not arguing that he should have done this or he 
should have done that.  I'm just saying that part of 
materiality turns on what representations you're focused on.  
And sophistication is something that your Honor has already 
explicitly said is fair game. 
MS. MURRAY:  Your Honor, these questions aren't going
to sophistication of him as an investor; it's victim-blaming,
asking him whether he advised clients in the course of his real
estate transactions and whether those clients were high-end
individuals.  I don't see how that is remotely relevant to this
individual's understanding of what the investment opportunities

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were or his motivation for investing in them.
THE COURT:  So he's asked whether he advises the
client to --
MR. KAMARAJU:  Pay attention.
THE COURT:  -- pay attention to the details.
MS. SHROFF:  Read a contract of sale.
MR. FINKEL:  That's not appropriate.
This is a fraud case.  There's no reliance defense.  
You can't say to a victim of fraud, You should have read all 
these details, sir.  This is victim-blaming through another 
word, they are using "materiality."  And the jury is going to 
draw the wrong conclusion.  It's a 403 problem. 
MR. KAMARAJU:  Your Honor is going to instruct the
jury as to the elements of the offense.  I'm sure the
government will ask as to that instruction.  Reliance is not
relevant.  I'm not sure I see --
THE COURT:  Well, I think that you're trying to get
him to say that I advise my clients to use good judgment, and
the implication is that he didn't follow his own advice.
MR. KAMARAJU:  No, your Honor.  What I'm eventually
going to set up is to the extent that he did not read documents
when entering into these investments, is because the
information in those documents was not material to him, which
is directly as a joinder to the government's allegations of
specific recommendations in those documents are material.  It

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didn't matter to him what's in the farm loan agreement, to
enter into the farm loan agreement.  Then how it can be
material?
THE COURT:  Did he actually discuss the specifics of
agreements?
MR. KAMARAJU:  He also told the FBI that he didn't
read them.
THE COURT:  But he testified today about the specific
agreements.  So I don't think you can argue that he said that
he did not rely on the agreements at all.
MR. KAMARAJU:  I'm allowed to impeach him on that,
your Honor.
THE COURT:  Well, I'm saying you can't say he didn't
testify about examining the agreements.
MR. KAMARAJU:  No, no, no.  You're right, your Honor.
What I'm saying is I'm allowed to impeach that testimony to
suggest that he didn't read those.
THE COURT:  You can challenge him on that.  What I'm
saying is you can't imply that he did not say today that he
read the agreements.
MR. KAMARAJU:  No, absolutely, your Honor.  I'm not
intending --
THE COURT:  So I am going to sustain the objection at
this point because I do think that you're going down that road
of the blaming of the victim.

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MR. KAMARAJU:  Okay, your Honor.
MR. FINKEL:  Thank you.
(In open court) 
THE COURT:  Sustained.
BY MR. KAMARAJU:  
Q. Now, you testified on direct that you were interested in
investing in GTV; correct?
A. Yes.
Q. And you understood that the purpose of GTV was to be a
social media platform, right?
A. Yes.
Q. And that it was to broadcast material that was critical of
the Chinese government, right?
A. Yes.
Q. So that was one of the goals that the movement had, was to
set up a social media network like that, right?
A. For all people to use, yes.
Q. Right.  And the NFSC was actually -- the public
announcement of the NFSC was actually just two days after the
GTV private placement closed; correct?
A. Yes.
Q. Now, you testified that you were hoping to earn a profit on
GTV, right?
A. I'm sorry?
Q. You testified that you were hoping to earn a profit on GTV;

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correct?
A. Yes.
Q. But you understood it was a risky business, right?
A. Yeah.  Miles more mentioned it, investment has risk.
Q. Mr. Guo said investment has risk, right?
A. Also he made a guarantee.
Q. Well, I asked you if he said that it --
MS. MURRAY:  Objection, your Honor.
THE COURT:  Sustained.
Continue your questions. 
Q. Now, you testified that Mr. Guo told people who wanted to
make an investment less than $100,000, that they had to contact
Sara Wei, right?
A. At the time, yes.
Q. At the time.  What do you mean by that?
A. Because the first announcement he mention who like to
invest, he didn't mention that.
Q. Okay.  So there came a point at which Mr. Guo said, If you
want to invest less than $100,000, you should go to Ms. Wei,
right?
A. He didn't mention 100,000, less 100,000.  He mention for
other people that don't have that much can contact other farm
leaders to invest.  He will not let the followers left behind.
Q. He didn't want the followers to be left behind, right?
A. Yeah.

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Q. Okay.  So your testimony is he didn't mention $100,000, he
just said smaller investments go to your farm leaders; is that
right?
A. No.  He mention 100,000 is two tiers; 100,000 for a certain
limited head counts.  It was 2,000 head counts.
Q. Okay.  So there were 2,000 head counts, to use your word,
for people who wanted to invest $100,000 or more, right?
A. That's a minimum.
Q. Right.  So $100,000 or more, right?
A. Correct.
Q. And then if you wanted to invest less than $100,000, he
told you to go talk to people in the farms; is that right?
A. Yes.
Q. Okay.  And that was the only dividing line, right, it was
more than $100,000 or less than 100,000, right?
A. Yes.
Q. And you personally decided that you wanted to invest less
than $100,000, right?
A. Not decide, just I don't have $100,000 at the time.
Q. Okay.  Fair enough.  You didn't have the $100,000, so you
ended up investing less, right?
A. Correct.
Q. All right.  Now, you testified on direct that you watched a
broadcast that Mr. Guo did on April 21st, 2020, right?
A. April 20th.

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Q. This is the one that's announcing the GTV private
placement; is that right?
A. Yes.
Q. Okay.  And you watched that, right?
A. Yes.
Q. Okay.  You watched the whole thing?
A. Yes.
MR. KAMARAJU:  Could we bring up Government Exhibit GX
C-26-T and go to page 1, please.
Q. The prosecutors, when they asked you about this, they only
showed you one clip from the --
THE COURT:  One moment, please.  It seems that one of
our jurors, No. 12, does not have the image on the screen.
MR. KAMARAJU:  I think it may be a problem with that
one screen, your Honor.
THE COURT:  Can you look on to Juror No. 11's screen?
Juror No. 12, are you able to look at Juror No. 11's
screen?
Okay.  Go ahead, please. 
MR. KAMARAJU:  Maybe we can blow up the paragraph
that's -- great.  Thank you.  Is that better?  Okay.
BY MR. KAMARAJU:  
Q. Now, on direct, the prosecutors asked you about one clip
from this broadcast; correct?
A. Yes.

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Q. They didn't show you the whole broadcast to testify about,
right?
A. Correct.
Q. So you see here where it says:  "This video is just a brief
introduction."  Do you see that?
A. I saw the English text, yes.
Q. Could you read that, please, the highlighted portion?
A. "This video is just a brief introduction to friends and
fellow fighters who have the intention to invest in GTV so that
you can understand the documents to be signed in the investment
and during investment, as well as some basic procedures."
MR. KAMARAJU:  Okay.  Can we go to page 5, please.
Q. Do you see the highlighted portion here?
A. Yes.
Q. Could you read that, please.
A. "Within 24 hours after you received this video, you will
receive the following documents from the law firm about the
so-called private equity of GTV."
MR. KAMARAJU:  Okay.  Could we go to page 2, please.
Q. Do you see the highlighted section here?
A. Yes.
Q. Could you read that, please.
A. "Please carefully read through all the documents to be
signed for investment."
Q. Okay.

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MR. KAMARAJU:  Could we go to page 16, please.
Q. Could you read that highlighted portion, please.
A. "I just would like to make a brief explanation, but I will
stress this one more time:  Please be sure to read the
prospectus, subscription letter, shareholder agreement, and
confidentiality agreement that are sent to you.  Those will
prevail."
Q. Okay.  So on repeated instances during the April 20th
broadcast, Mr. Guo urged listeners to read the documents;
correct?
MS. MURRAY:  Your Honor, same objection that we raised
at sidebar.
THE COURT:  The objection is sustained.
Move on. 
Q. Do you know what he means when he says "prospectus"?
A. He didn't speak that broadcast in English; his original
words were in Chinese.
MR. KAMARAJU:  I think we can take it down.  We have
the Chinese next to it.  That's helpful.
Your Honor, I'm sorry, could we have a 20-second 
sidebar? 
THE COURT:  Yes.
(Continued on next page)

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(At sidebar) 
MR. KAMARAJU:  Just before I continue, I just want to
make sure I understand.  Am I not permitted to ask him if he's
read the prospectus?
THE COURT:  I want to first hear the objection of the
prosecution.
MR. KAMARAJU:  Okay.
MS. MURRAY:  That question is not objectionable.  But
the questions that Mr. Kamaraju has been asking are going again
to kind of victim-blaming and picking apart very specific
details about what this victim did or didn't do in a way that
is prejudicial, is intended to kind of muddy the waters for
this victim.  If he wants to ask if he read the prospectus, he
can ask if he read the prospectus.
MR. KAMARAJU:  All I elicited was that Mr. Guo
directed investors to the prospectus where there is information
surrounding the representations that the government is relying
on.  I want to be able to ask him if he read the prospectus.
If he didn't, he didn't.  That's what the entire line of
questioning before was when I showed him the various parts, was
that Mr. Guo is directing them to the document.
THE COURT:  So it's not a "don't you think you should
have done that," you're not going to follow up with that.
MR. KAMARAJU:  I don't intend to ask him "shouldn't
you have read it," no.

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THE COURT:  Just did you.  That's it.  And then you're
done with that line of questioning?
MR. KAMARAJU:  I mean, if he says yes, he read it,
then I'm going to show him the document, I'm going to ask about
specific representations about the document.
THE COURT:  See, that's the problem.  You can't go to
those representations.
MR. KAMARAJU:  Actually, your Honor, your Honor ruled
in the motion in limine under the Weaver case that we are
allowed to show different representations in the PPM to go to
materiality.
The government explicitly argued that it only went to 
reliance.  They cited Weaver.  Weaver, in fact, says the 
disclaimers are relevant to the idea of materiality.  So if you 
read the disclaimers, then I'm allowed to elicit them.  
Otherwise, I don't know how to elicit that other than through a 
witness who read the document. 
MS. MURRAY:  Your Honor, the representations that were
made weren't only contained within the document.  There is the
broadcasts, there are other statements that he made.  So to the
extent that they want to inquire and find out what caused the
witness to invest or what induced him to invest, they can ask
that question without tying it to the language of the
prospectus and going to this line of questioning.
Then with respect to the specific question did he read

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the prospectus, we don't object to that question.  But it's the 
20 questions that have led up to it and then the questions that 
would follow. 
THE COURT:  If he answers yes, then what questions do
you feel are appropriate?
MS. MURRAY:  I think it would be questions regarding
the materiality of -- I believe this is where Mr. Kamaraju is
going, the materiality of the guarantee that Guo made that he
would personally guarantee any losses.
If the line of questioning is, Here's what was stated 
in the prospectus.  Were Guo's statements that he would 
personally guarantee your money, were those immaterial to your 
decision to invest because it's not listed in the prospectus 
anywhere, I don't think that's -- 
MR. KAMARAJU:  Well, first of all, I will note that
the indictment alleges that the misrepresentation related to
the securities fraud count and the wire fraud count related to
GTV to be statements in the prospectus.  So the idea that he
made statements elsewhere that affected that, that's fine.
They can argue that.  But there's no universe in which the
prospectus statements are not relevant, and the information
surrounding those representations are not relevant unless
they're dropping the count, which I don't think they are.
MS. MURRAY:  Your Honor, this is not the only victim
who invested in the GTV offering.  It's very clear that what

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they're trying to do is back into the sophistication.  And a
topic that your Honor already ruled doesn't come in through
this.  Again, if they want to ask --
THE COURT:  If you're relying on the representations
in the indictment, how is it that it would not be proper to ask
the witness about these representations mentioned in the
indictment?
MS. MURRAY:  Well, I think first we would establish
whether he read the prospectus.
MR. KAMARAJU:  Sure.  I'm going to do that.
THE COURT:  Yes.  But if he answers yes, that's where
I'm asking.
MS. MURRAY:  If he answers yes, it's fair game to ask
questions about certain of the language in the prospectus and
determine whether he had read it at the time.  But what we're
concerned about is kind of the slippery slope of then going
into the sophistication and victim-blaming.
THE COURT:  Well, did you read it?  Let's say he says
yes.  Then the next question is:  Did you consider the risk
that was set out in the prospectus?
MR. FINKEL:  One way that your Honor might want to
contend with this, and I know it's been done in other fraud
cases, is through a limiting instruction, which is simply
telling the jury that whether the witness or the victims were
sophisticated or not, were aware of risks that they avoided or

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relied on various disclaimers or not is not what's at issue
here.  The questions are being asked only for the purpose of
assessing whether the representations that the witness
testified about, here, the representations about the guarantee
and the use of GT funds, whether those are material.  I have
seen that done in other fraud cases.
THE COURT:  Okay.  We're going to take a pause, and I
want you to draft this instruction.
MR. KAMARAJU:  I'll just note, your Honor, that
everything he just said is a proper subject of a jury
instruction, not a limiting instruction in the middle of
testimony.
THE COURT:  I don't know that I agree with that.
MR. KAMARAJU:  Well, your Honor, I'm not sure -- first
of all, your Honor did say that we can acquire the
sophistication of the investors because it goes into the
materiality analysis.  So I just want to make sure that we're
clear on that.
I get the idea that we can't argue that the victims 
are negligent or they should have done more.  We're not 
precluded from arguing or eliciting testimony that these are 
sophisticated people.  That's black-letter Second Circuit law.  
That's the Litvak case.  The Litvak case says sophistication of 
the investors plays into it. 
MR. FINKEL:  That's a civil case.

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MR. KAMARAJU:  No, it's U.S. v. Litvak.
So I don't -- because you have to judge the reasonable 
investor standard by the investors who are in the market.  
That's what the law is.  So that's one point. 
Two, I don't know how you get away from determining
the materiality of any individual statement taken outside of
the context of the larger document.  There's no principle of
law that supports that.  If a guy says he read -- not this
witness, but generally.  If a person says they read a document,
and document -- one section of the document says this is how we
might use the money, and the other section of the document says
those are just examples of how we use the money, it goes to the
materiality analysis, your Honor.
MR. FINKEL:  Your Honor, the Weaver case, which we
briefed and which your Honor ruled on directly addresses this.
And it prevents defense counsel from eliciting this sort of
testimony.  
What happened in Weaver, if I recall correctly, was 
essentially the defendant, the fraudster, was saying to 
victims, You're going to make millions of dollars, all that 
kind of stuff, right.  Then they would receive documents that 
would say something to the effect of, Don't listen to anything 
I just said.  A disclaimer.   
And so the defense wanted to put in a disclaimer to 
say, Look, you should have looked at that disclaimer, victim.

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You should have known, victim, that you shouldn't have listened 
to the guy, the defendant, as to what he said.   
Second Circuit said you can't do that.  Why can't you 
do that?  Because fraud in a criminal context, there's no 
reliance on it.  There's an objective reasonable standard which 
the jury will assess.  But you can't -- defense counsel is 
asking questions about -- this all came about because they are 
asking questions about, Are you a good real estate broker?  Do 
you point your clients to specific details in the contracts?  
Do you look over things?   
That goes to whether or not they were assessing 
disclaimers.  That's not the issue.  The issue is whether Guo's 
statements made in these broadcasts were lies and whether, 
based on those lies, they were material to the victims, and so 
they sent money to Guo, and they did. 
THE COURT:  What does the prospectus say?
MR. FINKEL:  The prospectus says a number of things.
One of the things that I think defense counsel is referring to
with respect to the indictment is how the money would be used.  
For example, the prospectus doesn't say that the money 
would be sent to a hedge fund in the name of Mr. Guo's son.  It 
says that the money would be used to essentially invest in GTV.  
There is no guarantee in the prospectus, and I think that's 
kind of what defense counsel is getting at, which is exactly on 
all fours with the Weaver case.  Because in the Weaver case,

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again, the defendant was saying things that victims relied on, 
and were the reasons why the victim invested, and then later 
got disclaimers.  And so the Second Circuit -- sorry, your 
Honor. 
THE COURT:  But do these documents contain
disclaimers?
MR. FINKEL:  The prospectus?
THE COURT:  Yes.
MR. FINKEL:  I believe there are some disclaimers in
that document, yes, your Honor.
THE COURT:  Like what?
MR. KAMARAJU:  Like I'll give you an example.  There's
a chart that they rely on that they put into the indictment
that said these are the contemplated use of proceeds.  And then
there's language that says this list is illustrative, right,
which means it's examples, right.  I'm allowed to elicit that
to materiality.  
I'll just say one point on the Weaver case, your 
Honor.  Respectfully, you've already addressed this and you've 
already noted that the government's description of Weaver is 
precisely wrong.  Because what they said in Weaver is that 
while there is no reliance element and the defense cannot make 
a reliance argument, they can point to those disclaimers for 
purposes of the materiality analysis, which is what your Honor 
has already found.  So I don't know why we're revisiting the

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context in Weaver. 
MR. FINKEL:  And that's why too to obviate any
potential juror confusion, a limiting instruction would be
appropriate.  And we'll draft one for the Court's
consideration.
THE COURT:  All right.  So that's what you'll do.
You'll draft and we'll pause.
MR. FINKEL:  Thank you.
(Continued on next page)

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(In open court) 
THE COURT:  Members of the jury, we're going to take a
brief pause.
Remember that you're not allowed to discuss the case 
amongst yourselves or with anyone else.  Don't permit anyone to 
discuss the case in your presence.   
I'll call you back shortly. 
(Jury not present) 
THE COURT:  You can step down.
Don't discuss the testimony. 
THE WITNESS:  Sure, your Honor.
(Witness not present) 
THE COURT:  Please be seated.
(Recess) 
THE COURT:  Please be seated.
Are the documents in evidence?  The prospectus, the 
other -- 
MR. KAMARAJU:  I don't believe so, your Honor, no.
THE COURT:  They are not in evidence.  Okay.
So on the issue of materiality, it is certainly 
material whether or not the witness read the documents.  But 
where you cannot go is into a question like:  Shouldn't you 
have heeded the warnings. 
MR. KAMARAJU:  Understood, your Honor.  I don't intend
to ask any question like that.

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THE COURT:  The proposed instruction is:  When
considering witness testimony, please note that negligence,
carelessness, or gullibility on the part of the victims is no
defense to a charge of fraud.
MR. KAMARAJU:  I'm sorry, your Honor.  I should have
noted this.  If you're going to use the word "victims," we
would at least ask you use the word "alleged victims."
THE COURT:  I have not even stated whether I'm going
to use the instruction.
MR. KAMARAJU:  No, I know, your Honor, and I apologize
for jumping in.  I just -- when I heard you read it again, it
occurred to me that I missed that.
THE COURT:  Clearly if I were to read the instruction,
I would use "witness" instead of "victims."
But why is it necessary to give this instruction now 
as opposed to when I'm instructing the jury at the end of the 
case? 
MR. FINKEL:  Your Honor, it's a correct statement of
law, and it absolves the jury from any confusion.  And I think
the jury would reasonably be confused.  They might be thinking,
I wouldn't have invested in this.  I would have known that this
didn't make any sense.  I would have known to read the
disclaimer and look at all the language.  And that's what
laypeople who don't understand the fraud law that we all do
would expect.

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So this instruction, which is a correct statement of 
law, resolves that issue, and I think appropriately 
contextualizes the line of questioning that defense counsel has 
advanced. 
MR. KAMARAJU:  Well, your Honor --
MR. FINKEL:  It's also a long trial.
MR. KAMARAJU:  Well, it is a long trial.  
So your Honor is going to instruct the jury that they 
should begin deliberations at the close of all evidence.  
You're going to instruct them, I presume, as to the proper 
elements of the law.   
And so when they are considering this witness's 
testimony, as long as anybody else, they will have the 
appropriate law to guide them.  There's no need to preview 
government arguments about the law to the jury now, when this 
is not a question, for example, of like is evidence being 
offered for this purpose or this purpose.  It ultimately goes 
to the elements of the offense.  And your Honor can address it 
at the time that you address all the other elements of the 
offense, which is when you instruct the jury as to the law, at 
the close of evidence. 
MR. FINKEL:  It exactly is the kind of issue where the
evidence is being offered for a particular purpose.  It's being
offered for the purpose of materiality.  And a jury doesn't
know what all of this means.

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So what your Honor is doing is delivering to them a 
correct statement of law so they can understand the evidence as 
they sit through the trial.  As I understand, looking back on 
the briefing on this issue, defense counsel doesn't object 
generally to the concept that negligence is not a defense.  And 
so we think your Honor instructing the jury of that is 
appropriate so they understand how to use the evidence that 
defense counsel is seeking to educe. 
THE COURT:  So I agree with Mr. Kamaraju that it is
not appropriate to give the instruction at this time.
But I want to talk about what you can and cannot ask.   
You can ask whether he has read those documents.  If 
you get a no, it stops there.  The inquiry stops there.  
There's no "shouldn't you have." 
MR. KAMARAJU:  100 percent, your Honor.  I do not
intend -- if he says no, I'm not going to ask him more
questions about the document or should he have read it or
shouldn't he have read it.
THE COURT:  Now, if he says yes, then you can ask:
Did you consider the statements made in those documents?  But
you can't go on and then say:  Well, shouldn't you have heeded
that warning.
MR. KAMARAJU:  I do not intend -- and the questions
that your Honor is formulating, like "shouldn't you have," I
have no intention -- that was not -- I don't think I've asked

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one of those questions, but that was not my intention.
THE COURT:  "Wouldn't a reasonable person have,"
"wouldn't you advise your client to," nothing like that.
MR. KAMARAJU:  Okay, your Honor.
MR. FINKEL:  Your Honor, if I may.  And I understand
the Court's ruling.  The problem is, is a victim saying that
they didn't read the documents, the implication that's left for
the jury is potentially, Well, they should have.  And that's
not the correct statement of how -- that's not a correct
statement of law as to how this evidence should be considered.
THE COURT:  People don't even read the instructions on
their iPhones.
MR. FINKEL:  I know.
THE COURT:  And so I think that average jurors would
not necessarily have the expectation that someone would read a
prospectus.
MR. FINKEL:  So, your Honor, we don't know what the
jury is thinking obviously.  And so the government's request is
just that the jury be instructed as to the law so they know how
to contextualize this evidence, that's all.
THE COURT:  I think an instruction on this discrete
aspect of the law, this particular defense or lack of a
defense, is drawing attention to or supporting an argument of
the government instead of truly clarifying.
So let's bring the witness back and the jurors back.

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MR. KAMARAJU:  Your Honor, I'm sorry, can I just have
one last verification?
THE COURT:  Yes.
MR. KAMARAJU:  If he says yes and I ask him, Did you
consider statements in the prospectus, am I allowed to point
him to particular statements in the prospectus?
THE COURT:  Yes.
MR. KAMARAJU:  Okay.  Thank you, your Honor.
THE COURT:  To the extent that he said he read them,
you may point him to those particular statements.
MR. KAMARAJU:  Okay.  So I --
THE COURT:  And you may ask if you've considered them.
MR. KAMARAJU:  I can put up a statement and say, Did
you read this?
THE COURT:  Yes.
MR. KAMARAJU:  And if he says yes, I can say, Did you
consider it?  And if he says no, move on.
THE COURT:  Right.  But if he says, I did not read the
prospectus, then you cannot bring up those --
MR. KAMARAJU:  Understood.
THE COURT:  Yes.
Anything further, Mr. Finkel? 
MR. FINKEL:  No, your Honor.  Rising because I think
the jury is about to enter.
THE COURT:  Okay.

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(Jury present) 
THE COURT:  Would you have the witness return to the
stand, please.
(Witness present) 
THE COURT:  Remember, sir, that you're still under
oath.  And please be seated.
And you may continue the cross-examination. 
MR. KAMARAJU:  Thank you, your Honor.
BY MR. KAMARAJU:  
Q. Sir, I think when we broke, we were discussing a document
called the prospectus.  Do you remember that?
A. Which document?  Sorry.
Q. I think we referred to it as the prospectus.  Do you
remember that?
A. Yes.
Q. Prior to sending money to VOG, did you read the prospectus?
A. I never received that.
Q. So you never received a copy of the prospectus.  Okay.
Thank you.
Now, you testified on direct -- well, I'm sorry.
MR. KAMARAJU:  Could we pull up Government Exhibit GX
C-63-T, please; June 2nd, 2020 video translation.
Could we go to page 9, please. 
Q. I believe you testified about some part of this.
MR. KAMARAJU:  But if we could blow up the box on the

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right that starts "We had an initial valuation of 200 million."
A. Yes, I see that.
Q. See that?  All right.
And you see where it says:  "the private placement 
exceeded the highest expectations and raised $350 million"; 
correct? 
A. Yes.
Q. So the private placement, in fact, raised more money than
was originally being sought, right?
A. That was part of VOG, yes.
Q. Well, the VOG money you testified was separate, right?
A. No, is part of this.  Private placement.
Q. So the $350 million that's being referred to, that's part
of -- VOG is part of that?
A. No.
Q. Okay.  It's separate, right?
A. Yes.
MR. KAMARAJU:  Okay.  And if we can go down on -- just
a little bit further down in that box.  No, I'm sorry.  If you
could just -- the sentence that starts:  This is up to now this
figure and through, yeah.  Thank you.  Thanks very much.
Q. Okay.  So you see it says:  Let's say 350 million.  350
million does not include the 117 million from VOG, right?  See
that?
A. The 350 doesn't include the 117, that's correct.

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Q. Right.  The 117 million, which is coming in through VOG, is
separate from the 350 million that was raised as part of the
private placement, right?
A. No, it's not separate from the private placement; it was
included in the private placement.  It's just separate fund,
350.
Q. Well, you testified on direct that there were a certain
number of seats, right?
A. Yes.
Q. There were 2,000 seats, right?
A. That was previously Miles mentioned it, yes.
Q. Well, I'm asking what your understanding was, sir.
A. When was introduced it to us as including me, Miles Guo
mentioned it private placement and also public placement, the
differences, then he explained it.
Private placement, if there were limitations, there 
seats, 2,000 seats.  Then if it exceeds that limitations, then 
it will be kind of different placement. 
Q. Okay.  So the private placement could have had 2,000 seats.
Can I just ask you, when you say "seats," what do you 
mean? 
A. His original words translate to English called long chair
owe chair (ph).
Q. Well, sir, I'm sorry, I'm not asking for a translation.
I'm just asking what your understanding of the word "seat" is

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when you use it.
A. My understanding is called long position.
Q. Your understanding is it's a long position?
A. Yes.
Q. I'm sorry, I'm not familiar with that.  What does that
mean?
A. That's a financial term for investment.  People before the
private investments, those are people will invest and hold
their stocks for certain periods.
Q. Okay.  So the seats are people who buy and hold their stock
for a certain period?
A. Yeah.  And also they are considered as the first
investment, investors.
Q. Okay.  So they are the first set of investors, right?
A. Correct.
Q. And that's -- there were 2,000 of seats available in the
private placement; correct?
A. Correct.
Q. And then there was a separate set of money that came in
related to VOG, right?
A. The separate money, the VOG, was for the people's
investment that was under certain amounts.
Q. I'm sorry, sir, but that wasn't my question, right.  My
question is, is the money that came in through VOG is separate
from the money that you're talking about that comes in through

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the seats, right?
A. That I don't know.
Q. Okay.  But you invested through VOG, that was your
understanding, right?
A. Correct.
Q. And you testified that you got the wire information from
Sara Wei; is that right?
A. That's correct.
Q. But you never directly corresponded with Sara Wei, right?
A. I messaged her; she replied.
Q. With the wire information?
A. Yes.  So the emails.
Q. Now, we talked about how you had met with prosecutors
before, right?
A. Yes.
Q. Do you remember telling the prosecutors that you never had
direct communication with Ms. Wei?
A. I told them I contacted Sara Wei, yes.
Q. I'm sorry.
A. I told them I contacted Sara Wei direct.
Q. Okay.  So there was somebody taking notes during that
interview, right?
A. I didn't take notes.
Q. I said there was somebody taking notes, right?
A. I didn't see who was taking notes.

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Q. I'm not asking if you saw who, I'm asking did you see
somebody taking notes, sir?
A. I don't know.
MR. KAMARAJU:  All right.  Can we bring up Government
Exhibit GX VO-80, please.  I believe this is in evidence.  So
we can publish it.  And can we just blow up that first
paragraph.
Q. Okay.  And do you see there's a name there, Lihong Wei
Lafrenz?  It's in the fourth line down.  
MR. KAMARAJU:  There you go.  Thank you, sir.  
Q. Do you see that?
A. Yes.
Q. That's Sara Wei, right?
A. That's her legal name, right.
Q. Do you recognize this?  This is the limited purpose agency
agreement that you signed with Ms. Wei; correct?
A. Yes.
Q. Okay.  And this is in connection with your GTV investment?
A. Correct.
MR. KAMARAJU:  Okay.  The government offers GX -- I'm
sorry, the government.  Apologies, your Honor.
The defense -- long afternoon already.   
The defense offers GX VO-80 into evidence. 
THE COURT:  No objection?
MS. MURRAY:  No objection.

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THE COURT:  It is admitted.
(Government's Exhibit VO-80 received in evidence) 
MR. KAMARAJU:  Sorry about that.
BY MR. KAMARAJU:  
Q. So just to clear it up, the name that's highlighted, that's
Sara Wei; correct?
A. Correct.
Q. And through this agreement you're designating Ms. Wei to be
your agent for purposes of buying GTV shares; correct?
A. Correct.
Q. You don't designate Mr. Guo for those purposes, right?
A. No.
Q. You don't have any contract designating any authority to
Mr. Guo over your purchases, right?
A. Not with him, no.
Q. I was just asking about him.  Not with him, right?
A. Not with him.
Q. You don't have a farm loan agreement with Mr. Guo, right?
A. No.
Q. You don't have a G Clubs agreement with Mr. Guo, right?
A. I never receive a G Club agreement.
Q. Okay.  So then you don't have one with him, right?
A. No.
Q. You don't have an agreement to buy H coin with Mr. Guo,
right?

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A. No.
Q. Okay.  And you, in fact, never spoke directly with Mr. Guo
about buying H coin, right?
A. No.
Q. You never spoke directly with Mr. Guo about buying G Clubs,
right?
A. No.
Q. You never spoke directly with Mr. Guo about buying GTV
shares, right?
A. No.
Q. Now, there comes a point when there's a disagreement
between Mr. Guo and Ms. Wei; correct?
A. I'm not sure if it's a disagreement, words would be
accurate.
Q. You understood that they had a bit of a falling out, right?
A. Yes.
Q. And Mr. Guo made public statements about Ms. Wei; correct?
A. Yes.
Q. He encouraged supporters to contact law enforcement about
Ms. Wei, right?
MS. MURRAY:  Objection, your Honor.  Hearsay.
THE COURT:  If you'll step up.
(Continued on next page)

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(At sidebar) 
THE COURT:  So why is it that these statements could
come in?
MR. KAMARAJU:  Well, I'm not offering them for their
truth at all, I'm offering them for the fact that he said them
and the fact that he's inviting scrutiny from law enforcement
and public law filings, which is inconsistent with the idea
that he had a guilty intent at the time.  If he was trying to
hide what he was doing, he wouldn't have told people to bring
the FBI in.  They are not being offered for their truth;
they're just being offered for the fact that he's inviting that
to happen.
THE COURT:  What was it that he said about Ms. Wei?
MR. KAMARAJU:  He said a number of things about
Ms. Wei.  But what I have in the 3500 material is that he asked
supporters to contact law enforcement, including the FBI, about
what Ms. Wei had done.
THE COURT:  What was it that he claims she did.
MR. KAMARAJU:  Stolen money from the farm loan
program.
MS. MURRAY:  Your Honor, the defendant is welcome to
testify about that.  We can't -- it's just not permissible to
back-door in the defendant's statements through this manner
about what he may or may not have said to people about Ms. Wei.
MR. KAMARAJU:  It has to be offered for the truth to

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be hearsay.  That's foundational.  We're not offering it for
the truth.
THE COURT:  What is it that if Mr.  -- if the witness
is aware that the statement was made, how is it relevant to his
testimony?
MR. KAMARAJU:  Well, he testified about the fact that
the money went -- he gave his money to Sara Wei so that Sara
Wei would make a GTV investment on his behalf.  He just
testified he had an agency agreement with Ms. Wei to do that
for him.
Mr. Guo and many other people think that Sara Wei — 
who, our understanding is, is going to be a witness at this 
trial — stole the money.  And my point simply is, is that if a 
person who's involved in a fraud or is alleged to be involved 
in a fraud says, Hey, FBI, come look at what I'm doing, that 
suggests that they don't have a guilty conscience, your Honor.  
And much of their -- 
THE COURT:  I don't understand why it is this witness
has to testify about having heard that statement.
MR. KAMARAJU:  Because he told the prosecutors about
it, your Honor.  It's not as if I'm planning --
THE COURT:  But what is the purpose -- how is it
relevant?  Did he act upon the statement?
MR. KAMARAJU:  He did actually act upon the statement.
THE COURT:  How so?

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MR. KAMARAJU:  He filed complaints with various local
law enforcement agencies.
THE COURT:  And how is it relevant to whether or not
your client is guilty?
MR. KAMARAJU:  Whether he filed them, I'm not arguing
that is relevant.  What I'm arguing is the fact that Mr. Guo is
asking people to look at what's happening here is the exact
opposite of consciousness of guilt.
THE COURT:  Right.  But you're just trying to get that
statement in through this witness.  The objection is sustained.
MR. KAMARAJU:  Can I ask for the basis, your Honor?
Is it relevance or is it hearsay?
THE COURT:  There's no question that it's hearsay.
MR. KAMARAJU:  I don't mean to argue with the Court.
I just want to understand how it's being offered for the truth.
THE COURT:  You want to get the statement in to show
that your client had an adverse relationship with Ms. Wei.
MR. KAMARAJU:  No.  I'm asking to get the statement in
to show that my client is not afraid of the FBI looking at what
he was doing.
MS. SHROFF:  It's a state of mind.
THE COURT:  Examining what she was doing.
MR. KAMARAJU:  No.  Because their allegation is that
Ms. Wei is a part and parcel of the GTV conspiracy.
THE COURT:  Okay.  So I don't know what the -- I don't

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know what her role is.
MS. MURRAY:  So Ms. Wei operated a company; she was
one of the farm leaders.  And that particular farm was used to
aggregate nonaccredited investors' money.  So Miles Guo made it
available in violation of securities law to people who had less
than $100,000.  And he said, Why don't you go to Ms. Wei, and
she'll aggregate all of your money, and it will look like a
legitimate investment from Voice of Guo that's above the
threshold.  So another way to kind of evaded the securities
regulations.  
We agree with your Honor this is not the witness to 
bring in what Mr. Kamaraju is trying to bring in. 
MR. KAMARAJU:  But I still don't understand.
If their allegation is that Ms. Wei was part of 
conduct that they're alleging is criminal on behalf of Mr. Guo, 
the statement is not being offered for the truth and the 
defense argument is, is that he's asking from sunlight to be 
put on the conduct, which is inconsistent -- 
THE COURT:  But why does it come in through this
witness?
MR. KAMARAJU:  I'm not sure why it can't come in
through this witness, your Honor.  I understand that there are
other witnesses that (indiscernible) may prefer that it comes
through the defendant.  But I'm not aware of an evidentiary
objection that says it can't come in through this witness as

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opposed to some other witness.
MS. SHROFF:  Or through multiple witnesses.  That's
not an evidentiary objection.
MS. MURRAY:  Your Honor, it's our view the Court has
ruled on this matter.  I understand Mr. Kamaraju is just
continuing to litigate it.  But we agree with your ruling on
this.  The objection should be sustained.  We should move on.
THE COURT:  I'm going to sustain the objection.
(Continued on next page)

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(In open court) 
THE COURT:  Sustained.  Go ahead.
BY MR. KAMARAJU:  
Q. Now, sir, you testified before about the Himalaya Farms;
correct?
A. Yes.
Q. And there's a structure to those farms, right?
A. Yes.
Q. There are different positions within the farms, right?
A. Correct.
Q. So there's a farm leader, right?
A. Yes.
Q. And then the farm leader may have others who sort of assist
them; correct?
A. Correct.
Q. Did you have a position in any farm, sir?
A. My position was OBS streamer for the farm.
Q. OBS streamer for the farm.
A. Yes.
Q. Okay.  What does "OBS" stand for?
A. It's a software platform name.  It's used -- it's open
software, allow you to connect your computer and the cameras,
broadcast to designated location, like YouTube push it out to
it, or push it to other sources.
Q. Okay.  And then above the farms comes the alliance, right?

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A. Yes.
Q. So all the farm leaders are part of the alliance, that's
your understanding, right?
A. Yes.
Q. And so they set policy for the farms, is that your
understanding?
A. Yes.
Q. And then above them is something called the Iron Blood
Group; is that right?
A. No, not above.
Q. Okay.  I'm sorry.  You explain it to me.  I may have it.
Wrong.
A. Iron Blood Group was launched by Miles Guo.  There were
three members at the beginning.  Eventually expanded to a
larger group.  All the member was selected by Miles Guo.
Q. Okay.  But the group had some authority, right?
A. They have their roles.
Q. Sir, I'm not trying to trick you, but didn't you tell the
prosecutors that the Iron Blood Group had full authority to run
the farms?
A. Not run the farm.
Q. Okay.  So what kind of authority did they have over the
farm, sir?
A. Iron Blood member will act as higher management group to
managing the farm leaders, and also they have the designated

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roles.
Q. Okay.  So they each may have designated roles within the
Iron Blood Group, is that what you're saying?
A. Yes.
Q. So one of the members of the Iron Blood Group was called
Mulan, right?
A. Yes.
Q. Mulan is not her real name, right?
A. No.
Q. What's her real name?
A. Liya.
Q. And Ms. Wei was a member of the Iron Blood Group at one
point; correct?
A. Excuse me.  You mean Sara Wei.
Q. Yes.
A. I don't recall that.
Q. Okay.  How about the leader of the UK farm, he was a member
of the Iron Blood Group?
A. Yes.
Q. Okay.  Now, you did more for the UK farm than just do
streaming; correct?
A. Correct.
MR. KAMARAJU:  Actually, your Honor, I am about to
turn to a different subject.  I just wanted to note the time
and see if your Honor wanted to continue.

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THE COURT:  Well, if you're going to another subject,
then this would be an appropriate time to stop, even though
it's only 2:40 p.m.
MR. KAMARAJU:  I will take credit for the five-minute
break, your Honor.
THE COURT:  All righty.
So, members of the jury, we will stop our work for
today.  You'll return tomorrow on time, as you did today, so
that you'll be able to walk through this door at 9:30 a.m.
Remember that you're not allowed to discuss the case 
amongst yourselves or with anyone else.  Don't permit anyone to 
have any discussions in your presence.  Have a good evening. 
(Jury not present) 
THE COURT:  Sir, you may step out.
Don't discuss the testimony. 
THE WITNESS:  Yes, your Honor.
(Witness not present) 
THE COURT:  And you may be seated.
Is there anything that the parties want to raise 
before we continue tomorrow morning? 
MS. MURRAY:  May we have a brief sidebar, your Honor?
THE COURT:  Yes.
MS. MURRAY:  Thank you.
(Continued on next page)

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(At sidebar) 
THE COURT:  I forgot to mention that the note that I
received from Alternate No. --
MS. SHROFF:  Five.
THE COURT:  Five yesterday, I made Court Exhibit No.
1.  It came in at 12:10 p.m., and I dated the exhibit Friday,
May 23rd, 2024.
What's the issue? 
MS. MURRAY:  Yes, your Honor.
XXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXX
XXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXX
XXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXX
XXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXX
XXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXX
XXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXX
XXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXX
XXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXX
XXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXX
XXXXXXXXXXXX 
XXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXX
XXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXX
XXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXX
XXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXX
XXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXX
XXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXX

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XXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXX 
THE COURT:  Fine with me.
MS. SHROFF:  We have no objection.
MR. KAMARAJU:  Yeah, that's fine, your Honor.
THE COURT:  Anything further?
MS. MURRAY:  We just ask to seal this part of sidebar.
THE COURT:  And it is sealed.
MS. MURRAY:  Thank you.
MS. SHROFF:  Your Honor, does the Court want to do
anything with Juror No. 5?  I know when we broke before the
weekend, the thought was to excuse him.
THE COURT:  Oh, you're talking about Alternate No. 5?
MS. SHROFF:  Yes, your Honor.
THE COURT:  Oh, I don't recall our decision to excuse
him.  Am I not recalling it correctly?
MR. KAMARAJU:  That was at least my understanding.  I
thought your Honor was -- because I thought we had a discussion
about how to excuse him without alerting the rest of the jury,
which is why we thought you had brought him back instead to not
tip off the jury.  We may have misunderstood.  That was our
understanding.
THE COURT:  So is he even still here?
MS. SHROFF:  He is here, your Honor.
THE COURT:  All right.  I'll excuse him.
MS. SHROFF:  Thank you, your Honor.

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(In open court) 
THE COURT:  Just a reminder, counsel, I have
proceedings after this matter, so you'll need to clear the
tables.
(Juror present) 
THE COURT:  You're Alternate No. 5.
You may be seated. 
JUROR:  I am Alternate 5.
THE COURT:  In light of your scheduling issues, I am
excusing you from jury service.  Thank you for your willingness
to serve.
JUROR:  Thank you, your Honor.
(Juror not present) 
THE COURT:  Anything further?
MR. FINKEL:  Not from the government.
MR. KAMARAJU:  Not from us, your Honor.
THE COURT:  Thank you.
(Adjourned to May 29, 2024 at 9:00 a.m.)

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INDEX OF EXAMINATION 
Examination of:                               Page 
 LE ZHOU 
174Direct By Ms. Murray . . . . . . . . . . . . . 
280Cross By Mr. Kamaraju  . . . . . . . . . . . . 
GOVERNMENT EXHIBITS 
Exhibit No.                                    Received 
184 Stip 2, C26, C26-V, C63, C63-V  . . . . . . . 
185 W1005, W1005-V  . . . . . . . . . . . . . . . 
193 V2, 13, 15-16, 18-19, 22-23, 25-29, 31, . . . 
59, 67-69, 77-78, 81-82, and 
84  
202 C-26-V, C-26-T, C-63-V, C-63-T  . . . . . . . 
234 32, 33, 34, 35  . . . . . . . . . . . . . . . 
241 VO-107, VO-108  . . . . . . . . . . . . . . . 
266 V0107 and V0108   . . . . . . . . . . . . . . 
 STIP-9 201   . . . . . . . . . . . . . . . . . . 
 W-58 236   . . . . . . . . . . . . . . . . . . . 
 VO-80 332  . . . . . . . . . . . . . . . . . . . 
 V0105 260  . . . . . . . . . . . . . . . . . . . 
 V0106 261  . . . . . . . . . . . . . . . . . . . 
 VI-151 220   . . . . . . . . . . . . . . . . . .

Translated Text(简体中文翻译)

168
          南区记者，P.C.
            (212) 805-0300
O5S1GUO1                 
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 28 日 
                                        上午 9:10 
 
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 
     克莱尔·蒂尔顿 
 
ALSTON & BIRD LLP 
     被告律师  
作者：E. SCOTT SCHIRICK

169
          南区记者，P.C.
            (212) 805-0300
O5S1GUO1                 
还出席：   
伊莎贝尔·洛夫特斯，美国律师助理专家 
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） 
Yu Mark Tang，口译员（普通话）

170
          南区记者，P.C.
            (212) 805-0300
O5S1GUO1                 
（在抢劫室里） 
法庭：我今天早上给你打电话是因为
在陪审团甄选和开庭的第一天我有
观察到律师之间出现了一种令人不安的不和谐模式
在这种情况下。在你们彼此的互动中，有
出现了许多不礼貌的行为，包括
尖刻、争吵、讽刺、翻白眼睛和沉重的叹息。
这削弱了诉讼的主旨
负面情绪主义。
作为法庭官员，我希望你能做到
遵守法庭礼节并遵守以下标准
专业精神。如果你们互相打交道
在陪审团在场的情况下采取不专业的方式，我会停下来
诉讼程序并指示你只向法庭陈述以及
互不相干，这将大大减缓审判的速度。
你有道德义务大力宣传，
但是这种热情决不能越界变成不尊重
你的对手。这种行为是对法院的冒犯
尊严，并可能破坏和阻碍审判。
我敦促你审查最高法院的裁决
Pounders 诉沃森案，521 U.S. 982、988（1997）以及 18
《美国法典》，第 401 条。换句话说，你需要
把它扼杀在萌芽状态。别考验我。
今天上午我收到了检方的来信。
他们试图允许某些保存完好的副本的展品

171
          南区记者，P.C.
            (212) 805-0300
O5S1GUO1                 
关于G新闻和盖特的在线帖子.你想什么时候使用
那些展品？
FERGENSON 先生：法官大人，我们预计会如此
明天提供。
法院：好吧。所以我需要回复
从今天的国防部那边出发你认为什么时候能把它拿到
我？
SCHIRICK 先生：在 3:00 之前，法官大人？
法庭：那好吧。所以我会解决这个问题
在我收到你的回复之后。对不起。
SHROFF 女士：法官大人，请允许我们提出一个问题
想在证人作证开始之前提问？
法庭：来吧。
SHROFF 女士：谢谢你，法官大人。
法官大人，在上周的盘问中，
法院可能记得我在证物编号方面遇到了困难；
当我试图从国防方面拿出一个展品来
盘问的目的，不符合
站在政府一边。我已经评论了 3500
在本案中向辩方提供的材料
不断更改 3500 个数字，原来是 3519-57
三天前的文件与今天的文件不同。
我以经验丰富的律师的身份提出这个问题是为了告诉法庭我是
很难跟上常量——我从来没有
这是 3500 个数字发生变化的情况。所以这是一回事。而且

172
          南区记者，P.C.
            (212) 805-0300
O5S1GUO1                 
我希望我们能有一套文件——我想
如果需要的话，蒂尔顿女士可以多谈这个问题。但是我们是
在调和正在生产的 3500 种材料时遇到问题
使用新的贝茨邮票编号——使用新的 3500 个号码。那是
一个问题。
第二个问题是，我们将获得 3500 份材料，而且
我知道这很正常，但举个例子，我刚才走进去
早上还有一部长达两页的单行间隔的 3500 部作品
即将出庭作证的证人。所以
恭敬地我知道你在午饭前不会休息，但是
要么我现在需要 20 分钟才能审阅，要么我需要 20 分钟
几分钟后，证人作证复审。我没有
甚至还有第二份副本可以和郭先生一起审阅。我强加了
在你的球场上要么跑到五楼做一个
副本，但我看见你的法律书记员帮了我做了一个
额外的副本。但我至少需要 20 分钟才能看完
那个。很抱歉现在提出这个问题，但这是——
芬克尔先生：法官大人，周末我们的
律师助理洛夫特斯女士在回答问题时派出了辩护
从国防部、我们最新的证物和展品清单中可以看出
审计，这应该可以解决 Shroff 女士刚才的问题
提到。施罗夫女士刚才提到的3500是
今天早上生成了 3500 份材料，所以我们把它交给
辩护一完成。但是要帮忙
Shroff 女士出去，稍后我们会传唤那个证人然后我们会

173
          南区记者，P.C.
            (212) 805-0300
O5S1GUO1                 
先打电话给 Le Zhou 这样 Shroff 女士就有足够的时间了
在证人作证之前审查那3500份材料。
法院：所以这正是问题类型
我不应该听到的。24 年来我从来没有
律师来找我，告诉我他们无法达成共识
展品编号。看在天哪，你必须
在这些纯粹的部长级事务上进行合作。
因此，您将有休息时间来查看该文档。
SHROFF 女士：是的，法官大人，但我们什么都没有
我可以解决编号系统的问题。我们很乐意合作。
我相信蒂尔顿女士一直与他们保持联系。这是
真的是她的辖区。她有，我想我也有，洛夫特斯女士
也做了同样的事情。但我不认为这是缺乏
合作问题。我不知道问题出在哪里。
说实话，我从来没有遇到过这样的案例 —— 我同意你的看法 —— 3500
编号已更改。我从来没有这样过。这份文件
标记的数字 19 仍然是 19。
法庭：施罗夫女士，我已经听够了。你知道的
如何解决这个问题。修复它。
对不起。
所有法律顾问：谢谢你，法官大人。
（休会） 
（在公开法庭上；陪审团不在场） 
法庭：早上好。你会做你的
请露面。

174
          南区记者，P.C.
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O5S1GUO1 Le Zhou-直播
（注明出场次数） 
法庭：请坐下。
请让陪审员进来。
（陪审团出席）
法庭：请坐下。
早上好，陪审员。
陪审员：早上好。
法庭：欢迎回来。谢谢你的到来
时间。这样，你可以在 9:30 走进法庭然后我们
可以高效地开始并继续前进。谢谢。
检方会传唤下一个证人吗。
MURRAY 女士：谢谢你，法官大人。我们打电话给 Le Zhou。
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：我叫周乐，Le，Z-H-O-U。
法院：你可以询问。
MURRAY 女士：谢谢你，法官大人。
 周乐， 
     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：早上好，周先生。
答：早上好。

175
          南区记者，P.C.
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O5S1GUO1 Le Zhou-直播
问：你住在哪个州？
答：佛罗里达州。
问：你在工作中做什么？
答：我是一名持牌房地产经纪人。
问：你曾经是郭文贵的追随者吗？
答：是的。
问：你今天在法庭上看到任何你认识的人吗
从你关注 Miles Guo 的时间开始？
答：是的。
问：谁？
答：我看见郭文亮了。
问：你能不能用他的座位和一件物品来描述他
他穿的衣服。
KAMARAJU 先生：我们会规定身份，你的
荣誉。
法院：他指出了被告的身份。来吧。
MURRAY 女士：谢谢你，法官大人。
问：你看到其他人是你那个时代认识的人吗
今天在法庭上关注郭迈尔斯？
答：是的。一些。
问：你能通过他们的名字或你知道的名字来识别他们吗
他们过来了？
答：有几个追随者坐在法庭上
观众一边，左边。这个名字？是的。Rachel Eva，Miles
7，张永兵。有一个昵称，“Heaven Sale No One One”。

176
          南区记者，P.C.
            (212) 805-0300
O5S1GUO1 Le Zhou-直播
我所看到的就是这些。
问：谢谢。周先生，你在哪里出生？
答：中国。
问：你什么时候来美国的？
A. 1998 年。
问：你为什么来美国？
答：我来这里学习——读大学。
问：你移居美国后，你在哪里上学？
答：我去了迈阿密戴德学院。
问：那你在那里学了什么？
答：我主修音乐教育，弹钢琴和
长号。
问：周先生，你是中国共产党的支持者吗
党，还是中共？
答：不是。
问：你的家人过去有过什么经历（如果有的话）
和中共在一起？
答：我们的家庭遭受了中国人的巨大痛苦
政府，两个家庭都站在我母亲一边，我父亲一边。
我的——我的外祖父母，他们出国了
学习。我的祖父是土壤工程师。他在建房工作
道路，当时他在中国政府工作。
修完路后，他成为了一名教授
大学。在文化大革命和红卫队期间
他的一些学生亲自来到他们家

177
          南区记者，P.C.
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O5S1GUO1 Le Zhou-直播
口头虐待了我的双亲——祖父母。所以我的母亲
祖母无法忍受这件事的耻辱，所以她下定决心了
自杀。在她那样做之前，她拿走了我的好东西
祖母的生活，因为她以为没人会照顾
她的。所以，我的母父母只是 —— 家庭倒下了
分开。我妈妈当时只有 16 岁。
我父亲那边，我祖父母那边——我们曾经拥有
像普通杂货店一样经营。我们有一个小广场。这个
政府，在第二次中日战争期间，他们来问，
他们会拿走我们的资产来帮助这个国家。他们说
他们打算借钱，但它占用了大部分资产，
留下了一点钱让这个家庭活下去我父亲有九个
兄弟姐妹，但这还不足以养活所有人
家庭。因此，其中两个孩子被迫捐赠。
那是 —— 那是我的双亲，他们是怎么受苦的
这个政府。
还有一个很大的影响，我几乎没有
生活就是一个孩子，一个孩子——一个孩子，一个政策。
它于 1980 年实施。当时，我妈妈已经
怀孕七个月了我父母想生我
而且——但是政府想强制堕胎。所以我的
父母—— 我妈妈躲起来了，而我爸正在推理
政府。最后，他通过降低我的权限达成了协议
既是父亲的工资，也是为了放弃新生儿的工资
福利，就是食物、牛奶，我不明白，所以他们会的

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饶了我的命
所以——还有我亲眼目睹的一次经历，
当我 9 岁的时候——那是 1989 年——学生抗议
发生在北京，也发生在我的家乡。在
我们住在离家乡很近的公寓里的时候
政府广场，学生抗议活动发生的地方。所以我们
被隔离在家里，不允许离开
社区，而我们 —— 当时我们听见外面的喊叫，
声音很大。所以我以前住在一楼。那一天，
当时我们在外面听到很多抗议活动，大喊大叫，然后我走了
到八楼到我父母的朋友家。他们的
阳台正对街道。当我走路的时候
走到那里，在阳台上，我看见，就在公交车站附近，
女学生被掩护了，有人——防暴警察用了沙袋
掩护她，把她拉开，然后另外两个人跳起来然后
把她打得屁滚尿流然后我把我的—— 一边移到附近，非常
靠近，往下看；有一个购物中心，一层楼的购物中心。那里
是一些抗议者爬上屋顶的一楼。而且
他们在向人群中扔一些物体。然后我们听见
一声巨响，然后我看见了混凝土墙的尖端，
屋顶，灰尘刚刚粉碎，向空中喷射。我们听说了
人们大喊：“开枪，开枪。”我们都是
害怕。我们很快就进入了我们的房子。
所以那是 —— 这就是我们所感受到的恐惧 —— 而且我们知道
该政权很残酷。

179
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问：如果有的话，这些经历是如何影响你的观点的
中国政府的？
答：政府不是 —— 不可信。他们的残酷和
残忍，这是不可想象的。
问：周先生，你提到过你曾经是的关注者
郭文豪。你第一次认识郭文贵是什么时候？
答：早在2017年，也就是2月。
问：那你是怎么知道他的？
答：他在直播的时候我看了 YouTube。
问：2017 年，你在 YouTube 上看到了哪些关于郭文贵的内容？
答：一开始，郭文贵正在做一个名为的广播
安全公告所以我很好奇这个人是谁
是。然后我——这就是我第一次看视频的方式。
问：在看那段视频之前，你听说过郭文贵吗？
答：不是。
问：第一次之后你还继续看他的视频吗
你在 2017 年见过他吗？
答：是的。
问：关于他的什么（如果有的话）引起了你的注意
广播？
答：郭文贵自我介绍了，然后我们得知他是
白手起家的亿万富翁但是他逃脱了中国政府的
迫害，然后他逃到了美国，寻找
保护。他还开始谈论腐败，
中国高级官员腐败。他已经保密了

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信息；他将揭露他们的腐败行为。
我还了解到他住在纽约，曼哈顿。
他有 —— 他在纽约买了名为
雪莉荷兰酒店.他还介绍了他的家人
回家。他有一个大家庭，有将近一百人
家庭；他的财富，这个家族拥有200亿美元的网络
而且他拥有私人飞机、豪华游艇、一百多场比赛
汽车——豪华车。另外，当时，他穿着漂亮的衣服
广播，看上去知识渊博，说得好，而且他能说话
差不多，他对文化的了解。甚至有时候是
经常给我留下深刻印象的是他提到自己有保镖
24/7，而且他有一个法律团队。有时候他会提到
他是 —— 他所掌握或拥有的信息，他将承担
对他所说的话负法律责任。
问：你刚才提供的信息是
那些广播中郭迈尔斯本人的信息？
答：是的。
问：有没有曾经有过郭文贵推出过
举报人运动？
答：是的。
问：你是如何得知那场运动的？
答：因为我开始看他的视频，而且我知道
运动是因为他自称是举报人
问：郭举报人的目的是什么（如果有的话）
运动？

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答：举报人运动旨在揭露中国官员
腐败。
问：郭鼓励举报人采取了哪些行动（如果有的话）
追随者可以用来打击中共的腐败？
答：当时他使用——使用社交媒体，我们变成
他的社交账户的关注者。当然，我学到了一些
他在广播中提到的腐败行为。他鼓励
我们来传播信息。一开始，我的行动紧随其后
其他所有人，转推，有时在他说话时转发
关于它，就传播到其他人了——我创建了一个推特
账户来帮助传播信息。
问：关于人们如何加入，郭说了什么（如果有的话）
举报人运动并成为追随者？
答：一开始，他有 —— 有自己的推特账户，人们可以
关注他，而且，当时，很少有人非常活跃
关注者出现在社交媒体上。还会透露
他们的身份、面孔并加入 Miles 的广播。当时
有一位名叫莎拉·韦的追随者。她创建了一个小组
叫做 “郭之声”。然后出现了——人们也可以加入
在那里，这也意味着加入这个运动。所以我加入了
组。
问：郭之音有时也被称为 VOG 吗？
答：是的。
问：关注者是如何与一个人交流的（如果有的话）
另一个？

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答：当时我们有软件供所有人使用
沟通。它叫做 Discord。
问：你能否向陪审团描述一下 Discord 是什么。
答：Discord 是一款免费软件，允许用户创建频道，
就像聊天室一样。聊天室然后你也可以
为任何其他分类目的创建子频道。这个
软件，你可以让用户使用链接加入，而你
可以发送消息、共享消息、图片、视频、文件。
而且你还可以在群组中发起语音会议。所以
当我加入的时候，它被分类了，我记得的部分是，
有子频道作为 a——所以他们创建了一个子频道作为
工作组，作为一个任务——工作组，对于某些事情，我们
想做。
问：你和其他关注者是否使用了你的真实姓名
那些 Discord 聊天？
答：不是。
问：如果有的话，你是如何认同自己的身份的？
答：我已经将用户名创建为 Coffee Cantata，然后使用
中文两个字，Wen Lu（ph）。那是我的话题标签。
问：其他关注者是否同样使用了别名或账号
他们什么时候互相沟通？
答：是的，大多数时候每个人都有自己的昵称。
问：顺便问一下，你还认识郭文贵还有哪些名字（如果有的话）
通过？
答：七兄弟，还有郭万国；那是广东话

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发音。
问：周先生，你熟悉法治吗
组织？
答：是的。
问：那些是什么？
答：法治是由 Miles 为——它是一家慈善机构
组织。
问：这些法治组织大约在什么时候成立的？
答：在 2018 年。
问：那你是怎么得知他们的？
答：它是在新闻发布会上公开宣布的。  
MURRAY 女士：法官大人，此时我想要
在双方之间提出一项规定。这是政府
展台 2.
法庭：所以我只想提醒陪审员们真是
规定是。规定是两者之间的协议
双方无需传唤证人即可向陪审团提供证据
就该主题作证。
你可以阅读规定。
MURRAY 女士：谢谢你，法官大人。这是一个
关于网页和视频的规定。
双方在图表中规定
包含在本展览中，即政府展览 Stip
2、A、B、C 列准确列出以下内容
信息：

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A栏中列出的政府展品是
从网站上保存的网页的真实副本
互联网。如果网页包含的视频也是
保留后，关联视频以 V 指定
政府展品名称。例如，GX C20 是一款防腐剂
一个网页，而 GX C20-V 是保存的视频
在那个网页上。
规定中的B列列出了网址或
保留的网页的网址。  
C列列出了网页的发布日期
保存。  
法官大人此时有一张图表
包含在此展览中，现已获准入场。我会的
我只想举一下这张图表中提到的两件证物。
一个是 GX C26 和相应的 GX C26-V。那些是 YouTube
这些视频已保存，日期为 2020 年 7 月 15 日。
然后是 GX C63 和 GX C63-V；再一次，来自网络的 YouTube 视频
页面，日期为 2020 年 11 月 25 日。
法庭：而且你要承认这一点。
MURRAY 女士：想承认这两件展品来自
在这张图表中，并开始承认这里的规定
时间。
法院：他们都被录取了。
MURRAY 女士：谢谢。
（政府展品 2、C26、C26-V、C63、C63-V

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作为证据收到） 
作者：默里女士：  
问：周先生将你的注意力引向了 2018 年 11 月，他确实这样做了
有时候你会看一个的直播
与法治有关的公告？
答：是的。
问：你还记得你在哪个网站上看过吗
公告？
答：那是在直播中。
问：这个网站被命名为 Livestream？
答：那是一个链接。这是 —— 直播将推出
频道，广播，但该频道受法治管辖
基金会。我相信这个网站是直播相关的
是 Vimeo。
MURRAY 女士：法官大人，我们将着手接纳一个
更多来自 GX Stip 2 的展品。那是 GX W1005 和 GX W1005-V，
那是 YouTube，它于 2024 年 2 月 9 日被保存。
法院：他们被录取了。
（政府的展品 W1005、W1005-V 已收到 
证据） 
MURRAY 女士：谢谢。 
洛夫特斯女士，我们现在能不能公布其中承认的内容
证据 GX W1005-V。
作者：默里女士：  
问：周先生，你认出这个视频吗？

186
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答：是的。
问：你以前看过吗？
答：我之前看过并现场直播。
问：这里的左上角有一个徽章。
KAMARAJU 先生：法官大人，我很抱歉。我们能不能有
关于这个的简短侧边栏。
法庭：好吧。
（下一页继续）

187
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（在侧边栏上） 
SCHIRICK 先生：法官大人，辩方只是想要
明确规定只适用于网上
保存。我们没有停下来把它当作证据。
因此，我们反对传闻。会的 —— 他们是
要播放班农先生在这家媒体上讲话的视频
会议。
法庭：所以我不明白你在说什么
没有通过该规定被录取。
SCHIRICK 先生：法官大人，这项规定只是
为了真实性。原来是视频被删掉了
来自来源。不涉及可否受理问题。
法庭：来吧。
FERGENSON 先生：没错，法官大人。只是
真实性不言自明。我知道反对意见是
传闻。我们提供这个视频片段不是为了真相
班农先生在里面说了什么；我们是为他们提供的
他说的话是虚假的。而且这是一段来自联席的片段
法治基金的公告，郭先生和
然后班农先生讲话，这是班农先生的片段
演讲。
法庭：那你想承认是因为
这是入场证吗？
FERGENSON 先生：不，因为它不是为它提供的
真相。我们之所以提供它，是因为有人这么说。

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SCHIRICK 先生：法官大人——
法院：对听众有何影响？
FERGENSON 先生：没错，法官大人。这些是发布会
受害者观看并相信的视频。
SCHIRICK 先生：法官大人，班农先生是什么样子
要在那段视频中说政府要展示的
证人和陪审团是班农先生的声明
郭先生本来打算创办法治基金会
一亿美元。他们争辩说那是
声称这是他自己的钱。事实上是这样
这是为了证明那句话的真实性，事实上是这样
班农先生说了什么，那实际上是
虚假陈述。所以我不确定是否有 —— 有
这里不是传闻问题。而且——
法庭：你在建议治疗性教学吗？
SCHIRICK 先生：我认为我们确实需要限制
指示，法官大人。但我认为 403 是有风险的
陪审团也在这里。
法院：我预计会有这样的数字
将发表任何声明，无论是视频还是其他内容
控方提出；我说得对吗？
FERGENSON 先生：是的，法官大人。
法院：所以我在找一份申请
限制指令。
SCHIRICK 先生：法官大人，我们要问的是陪审团

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给出限制性指令，说明这不是
声明——班农先生的声明不是声明
归因于郭先生。
费根森先生：我们会反对的。那不是
是承认声明所必需的。我们会没事的
并附有限制性指示，说这些陈述不是
被提议证明所断言的事实真相。
这就是定义——
KAMARAJU 先生：法官大人，因为这只是一个
断绝真实性，我认为检方必须下定决心
基金会，以便通过证人介绍这一点。我
我知道这个已经上线了，但是我想就像这些视频一样
即将到来，我认为正确的格式是先这样做。
法院：绝对可以。
KAMARAJU 先生：谢谢你，法官大人。
法庭：好吧。
（下一页继续）

190
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（在公开法庭上） 
作者：默里女士：  
问：周先生，这个的左上角有一个标志
屏幕截图。你看见了吗？
答：是的。
问：那是什么意思？
A. Guo Media。
问：Guo Media 是什么，或者当时的 Guo Media 是什么？
答：这是为该运动创建的最早标志。
有一个媒体频道。这就是它的名字。
问：Guo Media 上发布了什么类型的内容（如果有的话）
此时？
答：此时，这是在举行的新闻发布会
纽约。
MURRAY 女士：Loftus 女士，如果可以的话请玩这个
视频。这是政府展览 W1005-V1。
法庭：你现在是不是在找我
给出限制指令？
KAMARAJU 先生：是的，法官大人。
法庭：陪审团成员，这段视频不是
是政府为了解所说内容的真实性而提出的
在视频中。观看时请记住这一点。
MURRAY 女士：谢谢你，法官大人。
（视频已播放） 
作者：默里女士：

191
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问：周先生，你认得这篇文章中描绘的人吗
视频？
答：是的，我愿意。
问：是谁？
答：史蒂夫·班农。
问：史蒂夫·班农在《规则》中扮演了什么角色（如果有的话）
法律？
答：他是法治基金会的联合创始人。
问：你从法治中学到了什么（如果有的话）
你在 2018 年看到的关于郭文贵是否在的直播
为法治捐款？
答：我从中学到的视频是关于这个问题的会议
这个公告以及关于这个基金的讨论将用于
帮助中国持不同政见者并让他们获得经济上的帮助，
并帮助他们提供法律支持，并使用这笔资金
调查神秘的商业死亡事件。
法庭：对不起。调查神秘什么？
证人：生意——人的死亡。
法庭：死亡。好吧。来吧。
问：你是否了解法治是否
该基金将由一定数额的资金提供资金
起源？
答：是的。有一亿美元。
问：现在你在看 Miles Guo 的广播时说过
那个时候你的印象是郭文贵是

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富有；对吗？
答：是的。
问：当你在 2018 年观看这段发布视频时，确实如此
你相信郭文贵能捐一亿
向法治慈善机构捐款？
答：是的。
MURRAY 女士：我们可以把它记下来，洛夫特斯女士。谢谢
您。
问：你曾经向法治组织捐款过吗？
答：是的，我做到了。
MURRAY 女士：法官大人，我可以接近证人吗？
法院：你可以。
MURRAY 女士：谢谢。
我已经递给证人一个活页夹，里面装有
标明为GX C26的证物，
GX C63-V1 和 V4、GX CT209 和 211、GX VI150-160 及其他
相应的翻译，GX VI180 到 190 以及他们的
相应的翻译，GX V02，13，15-16，18-19，22-23，
25-29、31、59、67-69、77-78、81-82 和 84，以及
GX W1005、GX W56-57 和 GX W59。
作者：默里女士：  
问：还有周先生，我想问你能不能简要地翻一遍
那个活页夹如果你认出那些展品，请告诉我
在那个活页夹里。
答：是的。

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问：这些文件是不是——是其中一些文档，文档
你向政府提供的与你有关的信息
你是郭迈尔斯的追随者的时候？
答：没错，是的。
问：你是否查看了所含的所有证物
在那个活页夹里？
答：对不起。此时此刻？
问：以前，今天之前。
答：以前，是的，全部。
MURRAY 女士：法官大人，此时是政府
将开始接纳政府展品 GX V2、13、15-16
18-19、22-23、25-29、31、59、67-69、77-78、81-82 和 84。
法院：他们被接纳了。
KAMARAJU 先生：没有异议。
MURRAY 女士：谢谢。
（政府的展品 V2、13、15-16、18-19、22-23， 
收到了 25-29、31、59、67-69、77-78、81-82 和 84 
证据） 
MURRAY 女士：Loftus 女士，你能不能发布什么
现在作为政府展品VO27作为证据。
如果我们可以放大最上面的部分。
作者：默里女士：  
问：周先生，这是什么？
答：那是我的收据，捐款收据。
问：那这份文件是什么日期？

194
          南区记者，P.C.
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答：2019 年 5 月 18 日。
问：这反映了什么捐款？
答：这是向法治基金会捐款的500美元，我的
第一次捐款。
问：你为什么在2019年向法治组织捐款？
答：是的，因为我是关注者的一员，所以我想帮助任何人
尽可能多的持不同政见者，而不仅仅是关注郭文豪
帮助他们，所以这与我想帮助的目标相同。
问：如果 Miles Guo 没有向 Miles Guo 捐款一亿美元
法治，如果你当时知道的话，会不会这样
对你很重要吗？
KAMARAJU 先生：对表格提出异议。
法院：驳回。你可以回答。
答：是的。
问：如果你，为什么那时对你很重要
知道郭文贵没有捐出一亿美元
美元用于法治？
答：因为有很多人需要帮助，中国人
人们，有很多持不同政见者。我一个人，500——我能做到
尽我所能，但是一亿美元，这可以提供帮助
很多人。
MURRAY 女士：我们可以把它记下来，洛夫特斯女士。谢谢
您。
问：周先生，你有没有做过志愿者
郭文贵和他的举报人运动？

195
          南区记者，P.C.
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答：是的，我做到了。
问：你大约是什么时候开始做志愿者的？
答：在2017年，我关注了几个月，我开始关注，只是
郭迈尔斯刚开始时转推，后来我也做了志愿者
转录 Miles Guo 的视频。我也做了翻译而且
视频编辑，我还为流媒体服务提供了帮助
运动。
问：是谁（如果有的话）将志愿者工作分配给了你？
答：从一开始，从 VOG 开始，就有一些志愿者
群组，他们把要做的笔录交给我；然后再说
农场管理团队分配的工作。
法庭：你所说的笔录工作是什么意思？
证人：是的，法官大人。笔录意味着，大多数
在 Miles Guo 的视频中，是用中文写的。现在有
不是字幕。因此，我们必须创建字幕。
那是笔录。我会听视频，记下什么
郭迈尔斯用中文说，然后把它打成中文，变成
副标题。  
问：当你说农场时，你提到了其中一些工作
是农场领袖指派给你的。你能解释一下吗
陪审团你说的农场是什么意思
答：农场是一个形容词。这是工作的报价，但却是真实的
意思是指办公室，郭迈尔斯提到，当
举报人证实，他想在印度建50个农场
在世界各地的不同地区，成为

196
          南区记者，P.C.
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O5S1GUO1 Le Zhou-直播
分支机构，办公室。
问：农场是以什么方式组织的（如果有的话）
一个单位？
答：农场组织了——有人我们称之为农场领袖。
大多数人从一开始就非常活跃
跟随者，跟随动作，跟随动作。那些人
是一些——他们中的大多数都是郭文贵指定成为
农场领袖。因此，农场一旦建成，就在
不同的国家、地区，然后还会在当地聚集人们
或者在线组建自己的群组，但都在其中一个群组之下
总部，这是一个名为喜马拉雅全球联盟的农场
管理这些农场。
问：谁是喜马拉雅环球的负责人（如果有的话）
联盟？
答：当时全球联盟只有几个人，而且 Miles
Guo 就是其中之一。有两个——很少的人。然后他们打电话
他们自己是 Iron Blood，一群人。
问：喜马拉雅全球的领导人为什么（如果有的话）
Alliance、郭文贵等人自称 “铁人”
血型？
答：有些人是由 Miles 选出来授予头衔的，
因为喜马拉雅全球联盟是用指定的
董事长、秘书长，还有几个人说
郭文贵指定了这些人。郭迈尔斯说，那些是
兄弟，因为那些兄弟愿意为之牺牲

197
          南区记者，P.C.
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他和他一起流血，为这场运动流血。原来如此
名字就是由此形成的。
问：回到你为志愿者所做的志愿者工作中
运动，你为那份工作付了报酬吗？
答：不是。
问：除其他外，你提到自己参与过
东西，直播。你在哪个或多个网站上直播
内容？
答：在直播时，我做了 YouTube，也在 Gettr 和 GTV 上做了。
问：盖特是什么？
答：盖特是一个由郭文贵创建的社交平台。它是
类似于推特。就像 Twitter 的功能一样。你
分享你的帖子，人们可以关注、转发。
问：什么是 GTV？
答：GTV，这是一个与 YouTube 类似的网站，允许你
发布和直播，发布视频。
问：谁负责 GTV（如果有的话）？
答：我不知道 GTV 的负责人。
问：GTV 是谁的公司（如果有的话）？
答：哦，GTV归郭传媒所有。
问：谁又拥有 Guo Media？
答：那个，我不知道谁拥有这家公司。
问：暂时关注 GTV，那会怎样（如果有的话）
时间，在 2018 年、2019 年，郭文贵有没有谈过 GTV？
A. Miles——这里介绍了 GTV，他大声疾呼

198
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这需要那些喜欢投资GTV的人的投资。
问：郭文贵是什么时候提供投资机会的
进入 GTV？
答：2020 年早些时候。
问：你是否将注意力引向了 2020 年 3 月
参与Guo关于GTV投资的广播
机会？
答：是的，我做到了。
问：如果有的话，郭向他的粉丝询问了什么
有兴趣在那次广播期间投资GTV吗？
答：我记得视频播出时我看过直播。
郭文贵给喜欢投资GTV的人打电话。他
提到了如果你想投资1万美元，举手吧
通过发布表情符号图标来进行聊天群组，以此作为您的意图。
他还问，让我看看谁想投资十万
使用两个表情符号作为您的意图来赚钱。
问：在那次广播中，兴趣程度如何，如果有的话，
有粉丝投资GTV吗？
答：我发送了一个表情符号，意图是 10,000 美元。
问：从你看那场直播来看，还有其他东西
追随者同样表示有兴趣投资
GTV？
答：是的，有很多 10,000 个表情符号但也很少
人们投入的十万美元投资
表情符号。

199
          南区记者，P.C.
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作者：默里女士：  
问：现在，将你的注意力转移到 2020 年 4 月 21 日，确实如此
你在看 Guo 直播的预先录制的关于这个的广播
GTV 的投资机会？
KAMARAJU 先生：法官大人，反对表格。她是
作证。
法院：你可以重申这个问题。
问：你是否将注意力引向了 2020 年 4 月 21 日
那天有看过任何与 GTV 相关的广播吗？
答：是的。
问：其中是否包括郭文贵的广播？
答：是的。
问：郭文贵的主题是什么（如果有的话）
在那次广播中讨论？
答：是的。我记得我有个分享链接。郭文贵
提到了GTV。首先，他提到任何投资都有风险。
然后，对于任何投资者，您都可以做出自己的判断。然后他
谈谈 GTV。根据他的说法，我们知道是这样说的
部分是为了谈谈GTV的投资。他提到了GTV
今天怎么会变成这样。有突破是因为 GTV 已经实现了
攻击目标，他提到了中共的目标，黑客入侵，很多黑客
试图击倒。GTV让我们失望了，这并不容易。
但他提到，GTV的未来预测，这是一个 
专为中国持不同政见者设计的平台有发言权， 
言论自由。我们是唯一的；没有其他平台。

200
          南区记者，P.C.
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他提到了这一点，众所周知，GTV的未来 
生长。从目前的六个人同时在线， 
但最终会发展到成千上万的人在做 
一起广播，其中的技巧。所以我记得那个 
视频还发布了联系信息，他的个人联系方式 
投资信息。如果有人想投资，可以 
直接接触。 
问：当你说出他的个人联系信息时，对谁是
你指的是？
答：郭文豪。
问：因此，在那段视频中，郭文贵提供了他的信息
就投资事宜可以联系的人？
答：是的。
问：郭迈尔斯在那段视频中说了什么（如果有的话）
投资GTV你会得到什么？
答：会买股票，GTV股票。
MURRAY 女士：法官大人，此时我想要
在双方之间提出一项规定。这是政府
展品 STIP-9。
该规定写道，当事各方规定和 
同意下表中包含的这一观点 
展品，A列下列出的展品包含音频或 
外语文本；以及所含图表中的文本 
在这项规定中，B栏所列的证物是 
所含音频或文本的真实准确翻译

201
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在A栏所列的证物中，该规定还有 
规定并同意该规定以及 
B栏中列出的政府展品——这些是 
翻译和成绩单规定——可能会被收到 
作为政府在审判中的证据。 
法院：该规定被接受。
（收到的政府展品 STIP-9 作为证据） 
MURRAY 女士：关于这些特定物品
包含在图表中，此时政府将
开始接纳 GX C-26-V 及其相应的 GX C-26-T，
是翻译和转录；还有 GX C-63-V，以及
它对应的 GX C-63-T，这是转录和
翻译。
法院：没有异议？
KAMARAJU 先生：不。我只想请政府
来吧，把所有悬而未决的展品都放进去
为了提高效率。
MURRAY 女士：当然。然后我们将开始承认所有
政府部门清单中包含的证物
展品 STIP-9。
法院：他们被接纳了。
MURRAY 女士：谢谢。
洛夫特斯女士，你能不能把政府展品拿出来 
GX C-26。 
稍等片刻，法官大人。

202
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（已聘请律师） 
MURRAY 女士：法官大人，我想撤回
请求承认其中包含的所有物品
规定。双方的协议是承认某些
翻译，但不是 A 列中列出的完整视频
所以我想撤回录取请求 
图表中注明的所有内容。这个时候我会 
动手承认我有两个特别的展品就行了 
提到。 
法庭：那好吧。所以那些曾经的物品
被录取不被录取，以及你要求承认的内容
现在被录取了。
MURRAY 女士：谢谢你，法官大人。
所以为了记录的清晰起见，我在找什么 
承认的是政府展览 STIP-9，这是 
规定；政府展品 C-26-V 和 C-26-T，以及 
政府展览 C-63-V 和 C-63-T。 
法院：他们被接纳了。
MURRAY 女士：谢谢。
（政府的展品 C-26-V、C-26-T、C-63-V、C-63-T 
作为证据收到） 
MURRAY 女士：好吧。洛夫特斯女士，如果可以的话
请张贴政府展品 C-26。
作者：默里女士：  
问：周先生，看着这个，你认出这个视频吗？

203
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答：是的。
问：左上角有一个徽标和徽章。做
你认得出来吗？
答：是的，我愿意。
问：这是什么？
答：GTV 徽标。
问：这段视频在四月份上线时你看过吗
2020 年？
答：不，我看的时候不是在网上发布的，所以我分享了一个
链接。
问：谁与你分享了视频的链接（如果有的话）？
答：其中一位农场成员。
问：当你说链接已共享时，它是如何与之共享的
你？
答：我在电报上分享了，我们的工作 —— 农场
工作渠道。
问：那是通过电话申请的；对吗？
答：是的。
法庭：你所说的 “电报” 是什么意思？
证人：是的，法官大人。  
Telegram 是另一款社交媒体软件。还有更多 
就像你可以允许你发送即时消息一样，你可以这样做 
个人一对一或者你也可以进行群聊。而且 
在那里你可以——你也可以分享你的文件、图片， 
链接、视频等

204
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MURRAY 女士：Loftus 女士，你能不能玩这个游戏
视频从一开始一直持续到 41 秒。
（视频已播放） 
MURRAY 女士：谢谢。我们可以把它记下来。
作者：默里女士：  
问：周先生，郭在那段视频中说了什么（如果有的话）
那是关于一个人能拥有多少股票的广播的
收到以换取他们的GTV投资？
答：我记得 GTV 股票总共即将发行 20
百万至2亿只股票。
问：关于有多少股票，他说了什么（如果有的话）
有人会用他们个人投资的钱来赚钱吗？
答：每股一美元。
问：你曾经投资过GTV吗？
答：对不起，你能不行 —— 你能不能重复一遍
问题。
问：当然。你曾经投资过GTV吗？
答：是的，我做到了。
问：那是什么时候？
答：我在2020年5月底投资了。
问：那你投资了多少？
答：我汇了两笔款项，总金额为 31,300 美元。
问：你把钱寄到哪里去了 GTV 投资？
答：我通过 VOG、Voice of Guo 这个频道发来的
由 Sara Wei 控制。

205
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问：你为何将你的GTV投资汇给VOG或Voice of of
Guo？
答：因为我的投资不到10万美元，还有莎拉
被指定的人也可以参加GTV的配股，私密的
放置。
问：你能否向陪审团解释一下（如果有的话）是怎么回事
与你的投资低于10万美元有关吗？
答：你能说得更具体一点吗。
问：当然。所以我相信你这么说是因为你的投资
低于 100,000 美元，你把它发给了 VOG；对吗？
答：是的。
问：是谁（如果有的话）指示你汇出你的投资
对于 VOG 来说低于 100,000 美元？
答：因为郭迈尔斯提到的第一部GTV是关于GTV的
放置位置，他们只发放了2,000个座位。有一个
人数，这是有限制的。那么限制是
人们可以 —— 你至少可以一直投资 100,000 美元
到数百万，百万美元。但是座位有限。而且，如果
很多人，尤其是没有资格获得座位或更少的席位
100,000 美元，但我们可以让另一家公司投资我们的
代表收购GTV股票。所以那是 —— 我是 —— 我
我自己明白我的投资不符合条件
座位。而且还不超过 100,000 美元，所以我就去了
通过 VOG 申请投资。
问：那你当时的理解是 VOG 投资了吗

206
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代表你还是代表GTV中的其他人？
答：不，它们是——
KAMARAJU 先生：法官大人，提出异议。
法院：持续。不要领导。
问：你当时以谁的名义理解了吗
你的钱被投资了？
答：GTV 媒体。
问：就股票而言，如果有人姓名，
会不会是你花钱投资的股票？
KAMARAJU 先生：对表格提出异议。
法庭：如果你想改一下措辞，拜托了。
MURRAY 女士：当然。
问：周先生，你提到你投资了钱
通过 VOG；对吗？
答：是的。
问：你签订了什么安排或法律协议（如果有）
加入 VOG？
KAMARAJU 先生：对表格提出异议。
法院：你签订了法律协议吗？
MURRAY 女士：谢谢。
问：您是否与 VOG 签订了法律协议？
答：是的。
问：你能否向陪审团描述一下那份法律协议。
答：这是代理协议。Sara Wei 会充当我的经纪人
拿我的投资去投资GTV。

207
          南区记者，P.C.
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MURRAY 女士：Loftus 女士，我们能不能发表
政府展览 VO-81。
问：周先生，这是什么？
答：这是我收到的电汇指令。
问：谁把这个寄给你（如果有的话）？
答：由《郭之声》频道负责人Sara Wei发送。
问：我想你之前提到过 Sara Wei 有一些
在喜马拉雅全球联盟中的角色。你能不能
向陪审团描述一下。
答：是的。她以前是非常活跃的追随者。她透露
她自己也加入了这场运动。然后她吃了一些
与郭文亮会面，甚至是公开场合，一起直播。
所以当时她和另一个人在一起 
非常活跃并被指定。而且因为她也在聚集 
一些追随者并落入了举报人运动。  
她组成了一个团体；她是举报人运动。   
因此，当时郭文贵也被指定为她 
追随者，小组负责人。而且她也可以有 
郭文贵的授权为我们收取GTV的投资。 
MURRAY 女士：Loftus 女士，我们能不能发表
政府展览 VO-82。放大顶部。
问：周先生，这是什么？
答：这是我的电汇确认。
问：看看这个，这封电报的日期是什么时候
转移？

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          南区记者，P.C.
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答：2020年5月28日。
问：那是一封电汇寄到哪里？
答：它已发送给郭之音传媒。
问：那这条特殊电汇的金额是多少？
A. 20,000 美元。
MURRAY 女士：我们可以把它记下来。谢谢。
问：你为什么要在5月份投资GTV
2020 年？
答：因为首先我想买一只GTV股票。还有 GTV，我
也是用户。这是一个平台。GTV网站也是
是为了其他中国人的话语自由
持不同政见者。而且我自己也是追随者。我真的是一个信徒
为了这场运动。我只想成为其中的一员，也想成为其中的一员
帮助发展这个 GTV。GTV 就像任何其他科技一样
公司开始了。
还有郭文亮提到我们也会成长 
这将成为世界排名第一的社交媒体平台， 
超越YouTube。我们拥有所有功能，我们将结合 Zoom， 
结合 YouTube，我们将实施最好的顶级技术 
进入这个 GTV。因此，为此，我想成为其中的一员。所以我 
投资的。 
问：当郭迈尔斯在 2020 年说过 GTV 将
超越 YouTube，那你相信他吗？
答：是的。最终。
问：实际上，您是否收到了股票或任何股票作为交换

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          南区记者，P.C.
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为了你的GTV投资？
答：不是。
问：在 2020 年的那个时候，郭文贵说了什么（如果有的话）
关于是否存在损失本金的风险
投资GTV？
答：他为其他投资人做了个人保证
在 GTV 里他们不会赔钱；他做了个人担保
在那上。
问：你能解释一下你所说的 “个人担保” 是什么意思吗。
答：在他的广播中，他提到了我们所有的钱
投资了，这笔本金永远不会亏损，甚至损失一分钱。
他会付出代价 —— 亲自还钱。
问：当时，也就是 2020 年，你相信郭文贵吗
有能力支付或担保您的投资吗？
答：是的。
问：当时，也就是 2020 年，你有理解吗
郭关于GTV股票价值的广播？
答：是的。
问：你的理解是什么？
答：郭迈尔斯的广播中还有另一场直播直播
那天我正在现场直播，成功结束了
配售，GTV私募已宣布。郭文贵
提及有收款——仅GTV就收到了3.35亿美元；来自
VOG 获得了 1.17 亿英镑。然后结合起来，差不多了 —— 他说
近5亿美元的投资。

210
          南区记者，P.C.
            (212) 805-0300
O5SVGUO2 Le Zhou-直播
而GTV时的估值，他给出了 
关于该价值的声明为20亿美元。然后他添加了 
他的法律团队和他的金融专家的估值 
应该是100亿美元。所以就在那一刻他解释了 
我们所做的投资，从 7 点开始 —— 跃升至估计 
大约 30 次。 
问：当你在 2020 年观看那个广播时，
关于GTV的估值，你相信郭文贵吗？
答：是的，我做到了。
MURRAY 女士：Loftus 女士，我们能不能停下来
政府展品 C-63-V，这是显而易见的。如果可以的话
请把它发布给陪审团就行了
问：周先生，你认出这个视频吗？
答：是的。
问：这是你当时看的广播吗
是在 2020 年发布在互联网上的？
答：是的。
MURRAY 女士：洛夫特斯女士，如果我们能去
请记住 12 分 40 秒，然后开始游戏。
（视频已播放） 
MURRAY 女士：请我们暂停片刻。
法官大人，我们还允许参观 “政府展览”
C-63-T，这是该视频的翻译和笔录。
我要去玩这个部分然后我去问
周先生将阅读部分笔录。

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          南区记者，P.C.
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谢谢你，洛夫特斯女士。我们可以继续。
（视频已播放） 
MURRAY 女士：你可以就此停下来。谢谢。
Loftus 女士，如果你可以的话，现在请发表
陪审团作为政府展品 C-63-T 的证据。而且，如果
请把时间缩短到 12:40。然后变焦
在右边。
问：周先生，这是该书的翻译和转录
我们刚刚看过的视频片段。如果你能读进去
右栏是陪审团的英语。
答：当然。
我们对GTV的初始估值为2亿美元， 
而私募需要的最低投资额为20％ 
百万。私募超过最高水平 
预期并筹集了3.5亿美元。到目前为止，这个， 
这个数字啊，大概是三亿六千万，比方说三亿五千万。  
3.5亿不包括来自VOG的1.17亿。如果是 117 
百万加上3.5亿，超过4亿——对不起， 
4.8 亿，差不多，差不多，将近 500 个 
百万，将近5亿。 
但是我们现在的数字是3.5亿
已收到，这仅适用于与GTV签订的合同。这个回合
这是一个保守的估计，是估值的17.5倍。
鉴于对GTV股票的巨大需求和充足的资本
GTV未来的立场，我的律师和金融专家

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          南区记者，P.C.
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双方都同意20亿美元的估值可能太低了，
而且公司的实际价值可能更接近
鉴于对GTV股票的巨大需求，100亿美元。
MURRAY 女士：谢谢。我们可以把它记下来。
问：周先生，当你看这个广播的时候
2020 年，你相信郭文贵认为 GTV 的价值是
大约 10 亿美元？
答：是的。
问：当你在 2020 年投资 GTV 时，如果
什么都行，你知道你的投资会被动用吗
为了？
答：是的。首先这笔钱将用于增强 GTV
功能，收购顶级公司并将GTV扩展到
成为 — 接管 YouTube，成为世界第一
社交媒体。
问：在 2020 年 5 月的那个时候，如果你相信 Guo 的话
会用GTV的投资资金来支付自己的个人开支，
你会投资GTV吗？
KAMARAJU 先生：法官大人，反对表格。
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.
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（在侧边栏上） 
法庭：我会听取你的反对意见。
KAMARAJU 先生：法官大人，Murray 女士继续
只要嵌入没有证据的事实，问问题，
然后让陪审团推断 —— 要求证人同意
和他们在一起。从本质上讲，那是她自己的证词
在陪审团面前。如果她想问这些问题她
可以问开放式问题。这是我们反对的
表格。
MURRAY 女士：法官大人，我相信法院
裁定可以用假设来质疑
证人, 特别是受害者证人.那是
我对这个证人摆的是什么。
法庭：没有法庭，我看不出她怎么能做到
问假设问题。
KAMARAJU 先生：她还能打下基础
在问一个假设之前。
法庭：所以我想他在要求你陈述
不管是他的理解——证人的理解——
那个 —— 或者他是否知道郭先生是否投资了这笔钱
他声称自己已经投资了。
FERGENSON 先生：法官大人，你在审前作出了裁决
裁决，为了证明实质性，我们可以问假设
诸如，如果你认识X，你会投资吗？
你知道，这是此类欺诈案件的标准。

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          南区记者，P.C.
            (212) 805-0300
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法院：当然。当然。
但是我认为她问这个问题并不不合适 
是否—— 
FERGENSON 先生：证实他实际上不知道
它是怎么用的 —— 对不起。
法庭：她假设的事实是
郭先生没有投资这1亿美元。那你知道吗
证人是否知道郭先生是否投资了这100美元
百万？
MURRAY 女士：所以这特别是
证人的GTV投资和其他GTV投资资金。我
不要相信证人对怎么做有任何个人了解
今天坐在这里，除了这么说之外，那些钱都被用了，
证人知道这并非全部用于
相反，GTV的业务被用于个人开支。
KAMARAJU 先生：谅解基于政府的理解
指控，法官大人，没有任何证据——
MURRAY 女士：需要明确的是，这就是我问的原因
这个问题就像我一样。
法院：我不知道这是否不利
她用这种方式问而不是问他是否知道
这笔钱被郭先生用来投资。
KAMARAJU 先生：对我来说，法官大人，问题出在你身上
Honor明确裁定他们可以提出一个假设。所以
问题是他们必须奠定什么基础（如果有的话）

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          南区记者，P.C.
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在问一个假设之前。
法院：没错。
KAMARAJU 先生：所以对我来说，也许这只是一个表现
基于这个特殊的假设。我怀疑他们会
再问很多，所以这就是为什么我认为加薪是合适的
现在就是。对我来说，她可以为以下方面奠定基本的基础
然后她可以说 —— 她可以问她假设是否
想要。
法庭：好吧。  
MURRAY 女士：我会那样做的。我确实问过他有没有有
明白这笔钱是如何使用的；但我可以问这个问题
再次质疑这是否足以作为基础。
KAMARAJU 先生：这就是区别。
SHROFF 女士：问题在于他是否有知识，
不是他的理解。因为他的理解可以
在他为他做准备的时候你给他做准备
在这里作证。问题是他在这方面有什么知识
时间，不是他现在所拥有的知识。
芬克尔先生：当时他的理解是
解决所有这些问题并与法院的规定保持一致
裁决。
SHROFF 女士：不懂知识。
法庭：你可以询问知识然后再问
你的假设。
MURRAY 女士：谢谢你，法官大人。

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          南区记者，P.C.
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KAMARAJU 先生：谢谢你，法官大人。
（在公开法庭上） 
法庭：你可以继续。
MURRAY 女士：谢谢你，法官大人。
作者：默里女士：  
问：周先生，在 2020 年 5 月，当你投资 GTV 时，你是否
知道你的投资将如何使用吗？
答：是的。
问：那你认为你的投资会被用来做什么，
再一次，在 2020 年 5 月。
答：是的，当时我相信我的投资将用于
增强 GTV，让这个 GTV 平台名列第一
领先的社交媒体平台。
问：当时，也就是 2020 年 5 月，如果你相信的话
郭迈尔斯会把你的GTV投资资金用于个人投资
开支，你会投资GTV吗？
KAMARAJU 先生：反对，法官大人。  
我们刚刚在侧栏上解决了这个问题。 
法庭：如果你愿意再次加紧努力。
（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：你在问吗 —— 说她
需要问一下郭先生有没有用过钱？我的意思是，什么是
你要找的问题？
KAMARAJU 先生：不，我想 —— 我什么时候能理解
我们左边的侧边栏是她要问问题
你知道这笔钱是怎么用的。她没有问过。
MURRAY 女士：我相信我确实问过这个问题。
KAMARAJU 先生：不，我听到的问题 —— 如果我
我错了，我很抱歉 —— 他怎么相信自己的想法
这笔钱本来要用的。她从来没有问过后续情况
问题是你知道这笔钱在2020年5月是如何使用的。
法庭：所以你要问 “你知道吗”
问题。
MURRAY 女士：法官大人，重要的是他
理解和他的知识；这就是原因
他投资了。这就是实质性问题。我不这么认为
有必要确定他作为投资者是否知道
投资的钱怎么了
这家公司是为了让他说出他的动机是什么
用于投资。
KAMARAJU 先生：如果你不问，如果你不问
确定他不知道，那你该怎么问
假设的意思是：如果你知道，那怎么会
改变你的看法？

218
          南区记者，P.C.
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法庭：好吧。
KAMARAJU 先生：谢谢你，法官大人。
（在公开法庭上） 
法庭：你可以继续。
作者：默里女士：  
问：周先生，在 2020 年 5 月，在你投资了 31,300 美元之后
GTV，那时你有没有亲身了解自己的情况
使用了投资？
答：据我了解，投资于GTV的钱是用于
增强GTV，购买顶级公司或软件来制作
增强和克服——成为世界第一
平台，超越YouTube。
问：那你在 2020 年 5 月的理解是什么，
这种理解的依据是什么？
答：郭文贵提到了他的广播。
问：除了郭文贵提到的内容之外，你还有个人信息吗
知识？你知道你的钱是怎么用的，还是你知道的
2020 年 5 月，你的钱是如何使用的？
答：我不知道。
问：如果你相信郭会用你的GTV投资
你愿意在 2020 年 5 月为他自己支付个人开支的钱
当时投资过GTV吗？
答：不是。
问：你听过 “G 系列” 这句话吗？
答：是的。

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          南区记者，P.C.
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问：什么是 G 系列？
答：G 系列的投资包括 GTV、G 新闻、G Fashion、G
商城、G Clubs等，都是郭文贵创立的。而且
对于举报人来说，这是一种金融体系
运动是他们的生态系统。
问：你了解 “G” 是什么（如果有的话）吗
在 G 系列中代表什么？
答：是的。
问：你的理解是什么？
A. G 是英文字母引用 Miles Guo 的姓氏
初始，第一个首字母。
MURRAY 女士：Loftus 女士，我们能不能停下来去
只见证标有待识别的内容
政府展览 VI-151。
问：周先生，你认识这个吗？
答：是的。
问：总的来说，这是什么？
答：Miles Guo 的广播。
问：你看到左上角的日期了吗？
答：是的。
问：你当时看过这个特别的广播吗
是在那个日期或前后在互联网上发布的？
答：是的。
MURRAY 女士：法官大人，政府将采取行动
进入政府展览 VI-151。

220
          南区记者，P.C.
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KAMARAJU 先生：没有异议。
法院：可以接受。
（收到的政府展品 VI-151 作为证据） 
MURRAY 女士：如果我们能玩那个，拜托，
洛夫特斯女士。我们可以先把它发布给陪审团然后我们会
玩吧。
（视频已播放） 
MURRAY 女士：请到此为止吧。
我们可以把它记下来。 
问：周先生，第一个视频片段中有人提到
萨拉的 VOG。那指的是什么？
A. Sara Wei。
问：还有 “VOG”，它指的是什么？
答：郭之声。
问：还有人提到了郭文贵。你看见了吗
然后听见了吗？
答：是的。
问：那是谁？
答：郭文豪。
问：总的来说，郭文贵说了什么（如果有的话）
在我们刚才看的那些广播中？
答：亲自保证投资者的资金不会损失，
只会获得。如果有十美分的损失，他将亲自支付。
问：那你当时看过那些视频吗
发布于 2021 年？

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          南区记者，P.C.
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答：是的。
问：当时，当你观看这些视频时，你是否
相信郭文贵他会亲自保证任何
对 G 系列的投资？
答：是的。
问：我现在想把你的注意力转到2020年6月。
有过郭文贵宣布的时候吗 
成立新组织？ 
答：是的。
问：那个组织叫什么名字？
答：它被称为中国新联邦州。
问：那也被称为 NFSC 吗？
答：是的。
问：中国的新联邦州是什么？
答：这是举报人的监督组织
运动。
问：你能否描述一下郭迈尔斯是如何宣布推出的
新中国联邦？
答：是的。那是 2020 年 6 月 4 日。他宣布了这个
在他的私人游艇上成立了新中国联邦并且非常活跃
广播。
问：那个广播在 6 月播出的时候你看过吗
2020 年 4 日？
答：是的，我看了。
问：如果有的话，NFSC怎么样，或者当时是NFSC

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          南区记者，P.C.
            (212) 805-0300
O5SVGUO2 Le Zhou-直播
与 G 系列有关吗？
答：G 系列之前已经推出；当时是针对
其他举报人运动。而新中国联邦之所以成立，是因为
NFSC是所有运动的监督组织，
这个名字将来会被用作
合法政府。所以这个名字归根结底是 —— 对于
这个运动。
问：当你说NFSC将成为时，你的意思是什么
政府？
答：因为该运动是 —— 将摧毁中国
共产党。一旦中国中共倒台，那么这个
组织将努力取代中共；给人民一个
人，一票。
问：那你怎么理解新中国联邦 —— 让我来吧
把它放在时机上。2020 年 6 月，你怎么样
我知道新中国联邦将接管
中国共产党？
答：当时我的理解只是为了揭露
中国的腐败。郭文贵有三种战术。他
提到，通过依法取缔中共的使用；通过消除中共的使用，
使用美国的力量，美国的权力；通过使用消灭中共
中共本身，他就是这么说的。
问：所以当时，也就是 2020 年 6 月，你的理解是
NFSC 本来要成为政府，这是否基于
郭文贵的声明？

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          南区记者，P.C.
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答：正确。
MURRAY 女士：Loftus 女士，我们能不能发布什么
作为政府展品 CT-209 作证。
问：周先生，在看这件商品？
MURRAY 女士：洛夫特斯女士，如果我们能放大
中间。  
问：那两张海报中描绘的人物或
图片，你认出那个形状吗？
答：是的，我愿意。
问：这是什么？
答：那是 NFSC 旗帜上的那颗星。
问：那颗星有多少积分？
答：总共有 49 颗星。
问：你能不能向陪审团解释一下你是如何获得49分的
那颗星？
答：这是七乘以七等于 49。
问：那么，七点的意义是什么（如果有的话）
那颗星？
答七，我们都用叫郭文贵的七个兄弟。有一个
有七个和他有关系所以他也是其中的一员
国旗创作，参与了。所以我想那是 —— 我
相信那面代表七的旗帜是 Miles，
七人制。
MURRAY 女士：我们可以把它记下来，洛夫特斯女士。
问：周先生，GTV私密之后有过一段时间吗

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          南区记者，P.C.
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配售于 2020 年 6 月结束，当时 Miles Guo 宣布了
与农场相关的投资机会？
答：是的。
问：那个机会是什么？
答：这叫做农场借款项目。
问：你能向陪审团描述一下农场的性质吗
贷款投资机会是。
答：农业贷款是为了让投资者向电话会议借钱
它是农场，这是新中国联邦金融服务委员会在不同部门的办事处
在世界各地。然后有个术语把钱借给
该农场用于招聘、扩张和招聘。
问：根据农场借款项目的机会，如果有的话，
贷款人会换取贷款吗？
答：任期为三年。而且还有
以年利率为基础的利率。
问：在那三年任期结束时，有哪些选择，如果
有没有，贷款人必须要么拿到本金
利率还是别的？
答：你可以选择拿钱、利息和你的
本金，再加上利息返还，你也可以买到股票。
问：什么类型的股票？
答：GTV 股票。
问：当时，也就是 2020 年 6 月，你的理解如何，
农场借款项目的投资机会提供了两种回报
用你的钱还是股票？

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答：对不起，你能再重复一次吗。
问：是的。在 2020 年 6 月左右，你怎么样
我明白，通过向农场提供贷款，三年
稍后你可以收到带利息的退款或者
你能收到股票吗？
答：我们有协议。
问：什么类型的协议？
A. 与农场签订的贷款协议。
问：谁宣布了农场借款项目（如果有的话）？
答：郭文亮宣布。
问：当时，也就是 2020 年，你是任何农场的成员吗？
答：是的，我是。
问：你当时是哪个农场的成员？
答：社交上的第一个农场叫做英国伦敦俱乐部。
问：你参与农场借款项目了吗？
答：是的，我做到了。
问：你在哪个农场参与了农场借款项目
程序？
答：英国伦敦俱乐部。
MURRAY 女士：洛夫特斯女士，你能不能出版《政府》
VO-22 展品，这是显而易见的。
问：周先生，你认识这个吗？
答：是的。
问：这是什么？
答：这是一项农场借款项目。

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问：本协议中列出的借款人叫什么名字？
答：这是美国喜马拉雅资本公司
问：美国喜马拉雅资本公司是哪个农场（如果有的话）
与？相关联
答：这是一个农场——英国伦敦俱乐部农场。
问：还有在那里列出的贷款机构，那是谁的名字？
答：那是我的名字。
问：你是在什么日期签订这份贷款协议的，英国
农场？
答：2020 年 8 月 24 日。
问：根据这份贷款协议的条款，什么是
你向英国伦敦俱乐部提供的贷款有何用途？
答：这是用于农场的一般营运资金用途。
问：你在农场借款项目上投资了多少？
A. 21,000 美元。
MURRAY 女士：我们可以把这个记下来，洛夫特斯女士。
问：周先生，当你签署贷款协议时
2020 年 8 月，你对自己的资金状况有何理解
会被使用吗？
A. 让农场设立办公室、雇用员工等
公司运营费用。
问：那在 2020 年 8 月的那个时候，你是什么
了解你会得到什么（如果有的话）作为交换
为了给英国农场贷款？
答：三年任期为百分之八。

227
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问：当时，也就是 2020 年 8 月，你为什么参加
农场借款项目？
答：因为我想帮助农场也想买
股票。
问：那你预计你会买入哪种类型的股票？
换成你给英国农场的贷款？
答：GTV普通股。
问：你为何相信自己能买到 GTV 股票
换成向农场贷款？
答：因为那是郭文贵介绍这个的部分内容
项目，作为投资机会。
问：有没有过郭文贵宣布另一篇报道
那个叫做 G Clubs 的投资机会？
答：是的。
问：那是什么时候？
答：同年，2020年推出。
问：当时，也就是 2020 年，你对 G Clubs 的理解是什么
是？
答：G Club 是 —— 现在也是 —— 其他高净值专属俱乐部
值得人们拥有，值得个人拥有，可以展示自己的身份。但是作为
我们已经在投资GTV，我们未来的财富将
大放异彩。因此，创建这个俱乐部也是为了提供服务
另外，由于资助的项目将具有其他特征
给那些成员。所以这是一个俱乐部成立了。
法庭：你所说的 “专属俱乐部” 是什么意思？

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证人：是的，法官大人。
独家 —— 郭文贵提到的这篇文章是关于其他的 
社会有这样的俱乐部，比如王室。这个特别的 
俱乐部，例如，梅森斯，还有其他俱乐部。所以他想要 
为特定个人创建一些类似的俱乐部，即 
这是新中国联邦的成员之一。 
作者：默里女士：  
问：当时，也就是 2020 年，你是否明白 G|CLUBS 有
任何实际地点，任何实际的俱乐部位置吗？
答：不是。
问：那时，也就是 2020 年，据你了解，会发生什么
投资 G Clubs 是用来换取的？
KAMARAJU 先生：法官大人，反对表格。
法院：请改写。
MURRAY 女士：是的，法官大人。
问：在 2020 年，你对 G|CLUBS 的投资有何理解
有机会吗？
KAMARAJU 先生：法官大人，我会继续
对象。我可以在侧边栏解释。
MURRAY 女士：请允许我稍等片刻，法官大人。
（已聘请律师） 
MURRAY 女士：法官大人，我可以再试一次吗？
法庭：来吧。
MURRAY 女士：谢谢。
问：周先生，在2020年，你对付钱的理解是什么

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给 G Clubs 的钱会给你吗？
答：是的。
我们向会员提供了股票，G 
俱乐部股票。   
其次，我们会拿到护照。   
第三，我们将进行另一项名为交易所的投资 
的硬币。   
第四，我们将从旅行中获得折扣等级优惠 
代理商甚至购物场所，例如豪华飞机，庞巴迪。   
最后一个是在 G 上享受折扣购物 
时尚。   
问：依次来看，从最后一个开始，G 是什么
时尚？
答：G Fashion 是 G 系列的一部分。这是一件衣服
时尚，您可以在这里购买奢华服装。
问：G Fashion 的商品在哪里出售，如果有的话？
A. 在美国各州出售。
问：你提到你当时已经达成了谅解
2020年，你可以获得其他福利以换取付款
给 G Clubs 钱；对吗？
答：是的。
问：当时的理解是基于什么？
答：这是郭文贵介绍的。
问：2020 年 G Clubs 会员的费用是多少？
答：G|CLUBS 会员有五个等级。第一层是

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1万美元，每增加1万美元到前五个等级。
问：那么对于顶层来说，顶级的成本是多少
当时的会员资格？
答：那将是5万美元。
问：你有没有购买过任何 G Clubs
会员资格？
答：是的，我做到了。
问：那是什么时候？
答：那是在2021年9月。
问：你购买了多少会员资格？
答：我购买了两个，第 2 层和第 5 级。
问：二级会员的费用是多少？
答：那是 20,000 美元。
问：那么 5 级会员的费用是多少？
A. 50,000 美元。
MURRAY 女士：Loftus 女士，我们能不能发布下什么
作为政府展品 VO-25 作证。放大顶部
部分。实际上，这是它的本体。
问：周先生，这是什么？
答：那是之后我的G|CLUBS会员资格通知
申请已获批准。
问：看看最初的台词，它是写给某人的，
你能读懂上面写的吗？
答：对不起，你能不能拜托——
问：当然。以开头的 “我的” 一词开头

231
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通知，那句话说什么？
答：“亲爱的战士们。”
问：然后往下看，谁签了字——
或者根据本文的正文，这份通知是谁发来的
电子邮件？
答：签名的名字，郭文贵。那是 Miles Guo。
问：这里是如何描述他的？
A. G 俱乐部的官方发言人。
问：你是如何支付你的 G Clubs 会员费的？
答：我用支票付款。
MURRAY 女士：Loftus 女士，我们能不能把这个记下来
并出版政府展品 VO-26，这是明证。
问：周先生，你认识这些吗？
答：是的。
问：这些是你为成为 G Clubs 而寄来的支票吗
会员？
答：是的。
问：每张支票的日期是什么时候？
答：第一张支票，2021 年 8 月 24 日。
问：还有第二个？
答：2021 年 8 月 25 日。
问：看看备忘录，里面有一些文字
每张支票的备忘录。如果有的话，会做什么
那段文字表明？
答：这表明了我的申请号。

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法院：先生，除了付钱之外，还是
还有其他要求或标准才能加入
俱乐部？
证人：是的，法官大人。要加入俱乐部，你
必须是关注会员，这是我收到的
成员。而且一开始就购买，并不是必需的
对于唯一的会员，而且它之前曾投资过GTV，
还向法治基金会捐款。
作者：默里女士：  
问：因此，在提交 G Clubs 会员资格申请时，
你需要提供哪些信息（如果有的话）
之前向法治捐款还是之前对GTV的投资？
答：我们必须输入我们分配的投资ID
以及我们与哪个农场关联到应用程序中。
MURRAY 女士：如果我们能回去，洛夫特斯女士，
政府展览 VO-25。如果我们能放大第一个
请以 “恭喜” 开头的段落。
问：周先生，你能不能先读一下这里的文字
“恭喜你。”
答：是的。
“恭喜。我很高兴地宣布你的 
G Clubs 的 5 级会员资格已获得批准。作为发言人 
对于 G Clubs，我热烈欢迎你的加入 
未来。” 
MURRAY 女士：我们可以把它记下来。

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问：周先生，你有没有收到任何股票作为交换
你的 G Clubs 会员费？
答：不是。
问：你提到有折扣可以使用
作为 G 俱乐部会员。你可以在哪里使用这些折扣？
答：我的意思是我在 GFashion.com 上使用的。
问：你从 GFashion.com 购买过任何物品吗？
答：是的。
问：在成为 G 之前你是否购买了其中一些物品
俱乐部会员？
答：是的。
问：成为 G Clubs 之后你是否购买了一些物品
会员？
答：是的。
问：你能描述一下你购买的物品的质量吗
从 G Fashion 购买的？
答：与之相比，质量本身很普通，正常
我们什么 —— 我想是我们平时能买到的衣服。
问：我想看看你购买的几件物品
来自 G Fashion。
MURRAY 女士：法官大人，我可以接近吗？
法院：是的。
MURRAY 女士：法官大人，我要把证人交给我
被标记为政府展品的物品
32、33、34 和 35。

234
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问：周先生，你认得政府展品32、33、34吗
还有 35？
答：是的。
问：它们是什么？
答：这些是我从 GFashion.com 购买的物品。
问：这些只是你从 G 购买的部分物品吗
时尚？
答：是的。
MURRAY 女士：法官大人，政府将采取行动
允许进入政府展品 32、33、34 和 35。
KAMARAJU 先生：没人反对。
法院：他们被接纳了。
（收到的政府展品32、33、34、35 
证据） 
问：如果你能从第 32 号政府展品开始，
周先生，把这个留给陪审团。
问：什么是政府展品 32？
答：那是一顶棒球帽。
问：那你在哪里买的？
A. gfashion.com。
问：那顶棒球帽的大概成本是多少？
答：我记得这个花了将近 200 美元。
问：如果可以的话，请举起 34 号政府展览。
那件物品是什么？ 
答：只是一件普通的衬衫。

235
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问：那是你从 G 那里购买的物品之一吗
时尚？
答：是的。
问：那件 T 恤的大概成本是多少？
答：这个大约是 150 美元。
问：现在如果你可以的话请停下来或者推迟政府
第 33 号展品。
答：是的。
问：什么是政府展品 33？
答：这是真丝长裤，女士装。
问：G Fashion 上那些裤子的大致价格是多少？
答：它的上市价格约为800美元。
MURRAY 女士：法官大人，如果我们能让证人出庭作证
被标记为政府展品的物品
W-58。
法庭：好吧。
MURRAY 女士：在我们等待的时候，法官大人，我可以吗
向陪审团发布政府展品32、33和34？
法院：你可以。
MURRAY 女士：谢谢。
问：周先生，你认识政府展品 W-58 吗？
答：是的。  
MURRAY 女士：如果我们能向下滚动一点，
洛夫特斯女士。
问：你访问过《政府》中描述的网站吗

236
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之前的第 58 号展品？
答：是的，我做到了。
MURRAY 女士：我们将着手接纳政府展览
W-58。
KAMARAJU 先生：没人反对。
法院：可以接受。
（收到政府的W-58号展品作为证据） 
默里女士：如果我们愿意的话，洛夫特斯女士。
我们可以从顶部开始。 
问：周先生，政府展览58中展示了哪个网站？
答：这是一个 G Fashion 网站。
MURRAY 女士：Loftus 女士，如果我们能向下滚动
拜托了。
问：往右看，你看见 “G Fashion silk” 了吗
裤子”？
答：是的。
问：该商品的上市价格是多少？
A. 880 美元。
问：那和政府展览33中的物品是同一件吗？
答：正确。
MURRAY 女士：我们可以把它记下来，洛夫特斯女士。
问：周先生，你还有一个实物展览，
政府展览 35.如果你能把它拿出来。
什么是政府展览 35？ 
答：是的。这是一款金色限量版口哨。

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问：那件商品是如何在 G Fashion 网站上做广告的？
答：广告只制作了 77 个，现在是 24K。
问：那个哨子的代价是多少？
答：我花了大约 3200 美元买了它。
MURRAY 女士：Loftus 女士，如果可以的话请发表
政府展品 VO-67 就是明证。
问：周先生，什么是政府展品 VO-67？
答：那是已付款收据确认电子邮件。
问：那是吹口哨的那是政府展览 35？
答：正确。
问：你说了什么材料来宣传口哨
如？
答：24K 金。
问：你对是不是有理解或印象吗
那个哨子其实是金子？
KAMARAJU 先生：反对，法官大人。
法院：持续。
问：周先生，你权衡过那个哨子了吗？
答：我做到了。
问：它大约重多少？
KAMARAJU 先生：反对，法官大人。
法院：驳回。你可以回答。
A. 0.7 盎司。
MURRAY 女士：法官大人，允许出版
政府展品35交给陪审团。

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法院：你可以。
问：周先生，你为什么（如果有的话）之后还要权衡哨子
你买了吗？
答：我只是好奇是否 —— 是否真实。
问：如果是真的，你是什么意思？
KAMARAJU 先生：反对。
法院：驳回。你可以回答。
答：当我第一次收到时，包装，当我第一次打开时，
是 —— 我看见上面有一点灰尘。黄金本身是——
工艺有点粗糙。据我所知，这是
作为收藏品的限量版，这让我大吃一惊
关注。
问：周先生，回到——
MURRAY 女士：洛夫特斯女士，我们可以把它记下来。
谢谢。 
问：回到你所期望或理解的状态
我猜你是用付钱给 G Clubs 的钱来换取的
提到了一种货币；对吗？
答：是的。
问：那是什么？你能向陪审团解释一下吗？
答：它是引入的货币，称为G美元和G硬币。
是数字货币，还有数字加密货币
也将从交易所推出。
问：当你说 “交换” 时，你指的是什么？
答：当时我们有一个叫做喜马拉雅交易所的零钱。

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          南区记者，P.C.
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O5SVGUO2 周乐-直播
问：在 2021 年的那个时候，当你投资的时候，或者对不起
我，当你支付 G Clubs 会员资格时，你的是什么
了解喜马拉雅交易所是什么吗？
答：喜马拉雅交易所是G系列的另一部分
由郭文贵创造的财务自由。它给了人们
立即汇款的机会要好得多。也没有
边界。而且，对于大多数证券，您也会获得。
问：当时，也就是 2021 年，你的理解是什么
关于喜马拉雅交易所的依据？
答：G美元等于一美元的价值，并且将
H币有黄金标准。全名，是
喜马拉雅硬币，由20％的黄金支持。所以这增加了
它的所有价值。
问：在 2021 年，你为什么（如果有的话）相信那个时候
喜马拉雅货币有 20% 由黄金支持？
答：郭文贵亲自宣布了这一点。
问：据你所知，当时，即2021年，谁负责
喜马拉雅交易所的？
答：这个人，我不认识。
问：当时，也就是 2021 年，谁推广了
喜马拉雅交易所？
答：郭文亮推广了喜马拉雅交易所。
问：你有没有购买过任何数字版
喜马拉雅交易所可用的货币？
答：不是。

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          南区记者，P.C.
            (212) 805-0300
O5SVGUO2 周乐-直播
问：为什么不呢？
答：因为有政策，所以不是，它仅限于
卖给各州的居民。
问：那么，在 2021 年，你当时的理解如何，
它受到了限制？
答：郭迈尔斯也提到了这一点。
问：有过你汇款购买的时候吗
喜马拉雅硬币还是喜马拉雅美元？
答：我不是为了买喜马拉雅币而寄钱的，但我是
有机会购买 H 币。
问：那是什么机会？
答：这个机会是基于我之前的 G 系列
先前投资的投资和捐款。另外，
我是这个运动的追随者；机会是
我。
问：谁给了你购买 H 的机会（如果有的话）
硬币？
答：郭文贵给了我们机会。
MURRAY 女士：Loftus 女士，如果可以的话请停下来
对于证人来说，什么标记为政府
展出 VO-107 和 VO-108。
问：周先生，你认识这些吗？
答：是的。
问：总的来说，它们是什么？
答：在右边——

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          南区记者，P.C.
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O5SVGUO2 周乐-直播
问：对不起。稍等片刻，先生。如果可以的话，就在
一般层面，这是什么类型的文件或物品？
答：这是我的个人投资摘要。
问：还有这些吗 —— 这些内容是从中提取的吗
你的手机？
答：来自我的电脑。
问：你把这些提供给政府了吗？
答：是的，我做到了。
MURRAY 女士：法官大人，政府开始承认
政府展品 VO-107 和 VO-108。
KAMARAJU 先生：对他们的入学没有异议，你的
荣誉。
法院：他们被接纳了。
（政府的展品 VO-107、VO-108 已收到 
证据） 
法庭：现在是 11:30，陪审团成员，所以
我们要休息半个小时。
记住我需要你做好走路的准备 
中午穿过那扇门还要记住你不是 
允许你们彼此或与任何人讨论这个案子 
否则。不要允许任何人在你的网站上讨论这个案子 
存在。   
先生，你不能讨论你的证词。 
（陪审团不在场） 
法庭：你可以坐下。

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          南区记者，P.C.
            (212) 805-0300
O5SVGUO2 周乐-直播
律师，在我们回来休息之前有事吗？
KAMARAJU 先生：不是来自辩方，法官大人。
MURRAY 女士：不是来自政府，法官大人。
法庭：那好吧。你可以下台。
证人：谢谢你，法官大人。
（午餐会休会） 
（下一页继续）

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          南区记者，P.C.
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O5S1GUO3 Le Zhou-直播
下午的会议 
下午 12:00 
法庭：请坐下。
请让陪审员进来。而且请有
证人恢复出庭作证。
MURRAY 女士：是的，法官大人。
（陪审团出席） 
法庭：请坐下。
请记住，先生，你仍在宣誓就职。
证人：是的，法官大人。
法院：你可以直接行事
检查。
MURRAY 女士：谢谢你，法官大人。
Gartland 先生，如果你可以的话请发表文章
陪审团除其他外，还有政府展品 V0107 和
V0108。
作者：默里女士：  
问：周先生，在我们休息之前，我相信我们在说话
关于喜马拉雅交易所。我们要撤出政府
展出 V0107 和 V0108。
MURRAY 女士：加特兰先生，如果你能取消发布的话
当你把它们抬起来的时候。谢谢。
问：我猜，周先生，在我们等待的时候，你曾提过
购买喜马拉雅山有一定的限制
硬币。你能不能向陪审团解释一下，你的

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          南区记者，P.C.
            (212) 805-0300
O5S1GUO3 Le Zhou-直播
了解2021年这些限制是什么。
答：是的。要允许购买H币，你必须拥有——首先
你必须是农场的一员，你必须加入农场
运动。那么在此基础上，一切都是基于你之前的
投资，包括捐款。所以从前这一切都是
算在内，然后你就能获得硬币的预发行然后
以折扣价出售。
问：你所说的预发布是什么意思？
答：由于这枚硬币是在2021年11月1日推出的，所以所有
先前投资的投资计入如何计算
你可以得到很多硬币。
问：谁计算了投资金额（如果有的话）
你已经预发行了喜马拉雅硬币吗？
答：指导规则由喜马拉雅联盟制定。对于
之前的GTV也有最后期限，划清了界限。对于
9 月 31 日 [原文如此]，任何捐赠投资，你都要投入
以前，您将获得0.5枚硬币的美元投资。任何
截止日期之后的投资，计为1美元
投资0.2枚硬币。
问：谁来设定这些最后期限（如果有的话）？
答：最后期限是由郭文贵宣布的。
问：那是在哪里宣布的？
答：在他播出期间。
问：在喜马拉雅硬币于11月发行时
2021 年，你是任何农场的成员吗？

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          南区记者，P.C.
            (212) 805-0300
O5S1GUO3 Le Zhou-直播
答：是的。
问：哪些农场？
答：英国伦敦俱乐部。
问：你有没有和英国伦敦俱乐部的人沟通
关于喜马拉雅硬币？
答：是的。
问：关于喜马拉雅硬币，你和谁进行了沟通？
答：我联系了农场领导。
问：当时谁是英国农场的农场负责人？
答：他的名字叫戴维·戴。
问：你怎么拼写那个姓氏？
A. D-A-I。
问：你能描述一下你的沟通或对话吗
当时和戴大卫谈过喜马拉雅硬币吗？
答：有一个是针对美国居民的，还有一个
禁制国家无法购买喜马拉雅硬币
直接。那个全球联盟，即喜马拉雅联盟委员会，成立了
以名义持股的企业来持有这些人的股份
硬币。除此之外，该农场还建立了商业行为
被提名人持有这些人的硬币的股份，那是
我被包括在内。
问：你指的是农场什么生意
成立了——还是联盟？对不起。
答：由联盟创立的名为Freedom Media的公司
创业有限公司

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          南区记者，P.C.
            (212) 805-0300
O5S1GUO3 Le Zhou-直播
问：你能不能向陪审团解释一下你的意思
将自由媒体创业公司描述为提名人。
答：被提名人代表你持有你的硬币，
例如。
问：当时，也就是 2021 年秋季，你的情况如何
明白自由媒体创业公司是提名人吗？
答：这是郭文贵公开宣布的。
问：那么 Freedom Media Venture 扮演了什么角色（如果有的话）
尊重你为喜马拉雅硬币支付的钱？
答：自由媒体风险投资公司，那家公司是一家新公司
专为 GTV 创作，因此宣布是为那些 GTV 的人设计的
在受限制的国家，那么他们将能够签署
合同还有报价——还会收取费用
向我们宣布。他向我们解释了这一点。
问：谁向你解释的？
答：郭文贵提到了这件事，还有另一位农场领袖
提到了它。
问：这笔费用的性质是什么？
答：我得到的费用是 5%。
法院：你所说的限制国家是什么意思？
证人：是的，法官大人。喜马拉雅交易所
有政策，而制定的政策，没有国家
在他们的清单上，有一份允许购买或开展任何业务的清单
甚至成为用户。这个国家是美国, 加拿大,
日本、朝鲜和其他重要国家。

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          南区记者，P.C.
            (212) 805-0300
O5S1GUO3 Le Zhou-直播
法庭：你可以继续。
MURRAY 女士：谢谢你，法官大人。
作者：默里女士：  
问：周先生，对于那些受限制的国家，你只是
提到，你知道人们是否
位于这些国家可以投资喜马拉雅硬币吗？
答：是的。
问：当时，也就是 2021 年，这种理解是什么？
答：因此，这会创建提名持股公司
我们能够让他们成为我们的股东，以获得
硬币。
问：你真的寄钱购买喜马拉雅硬币吗
通过那个被提名股东？
答：我没有直接把钱寄给股东。我发送
给农场的钱。
问：哪个农场？
答：英国伦敦俱乐部。
问：你有没有参与任何形式的——有什么理解吗？
你和英国伦敦农场之间的目的是什么
你寄的钱是为了什么？
答：是的。
问：那是什么理解？
答：我和农场负责人签了协议，
戴维·戴他以提名人的身份创建了一家公司
控股公司。

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          南区记者，P.C.
            (212) 805-0300
O5S1GUO3 Le Zhou-直播
问：总的来说，其中的条款是什么
你与英国农场领袖签订了协议？
答：这个词很公正，他们会存放我的硬币，我也有
要支付费用，向其支付年费。但将来，一旦
喜马拉雅交易所获得合法许可，得以扩张
领土，该限制与这些领土有关
国家，尤其是美国，那我就是
能够使用我自己的用户名账户来转移
硬币还给我。
问：那么，在 2021 年的那个时候，你是怎么理解的
被提名股东的投资就是这样
工作？
答：对不起。再重复一次这个问题。
问：是的，当然。那么在 2021 年，你的理解如何
在将来的某个时候你可以注册
你自己在喜交所的账户？
答：是的，郭文贵提到过，是的。
问：所以当你向英国农场汇款时
购买喜马拉雅硬币，你有哪些资产（如果有）
去喜马拉雅交易所？
答：我不知道。
问：在 2021 年的那个时候，如果有的话，你是怎么做到的
查看你持有的喜马拉雅硬币的数量
付了钱？
答：因为农场有我的投资摘要和

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          南区记者，P.C.
            (212) 805-0300
O5S1GUO3 Le Zhou-直播
摘要文件，我之前的所有投资
投资了；而且，硬币的比率是
计算的。是 —— 信息是提供给我的。
问：由谁提供给你？
答：由来自英国伦敦俱乐部的其中一位成员撰写。
问：在你于2021年通过英国购买喜马拉雅硬币之后
农场，如果有的话，你是怎么能使用这个数字的
用来买东西的货币？
答：我——因为我没有访问权限，所以我不知道你怎么样
把那个花掉。
问：从你在2021年的投资到今天，现在，
你有机会进入喜马拉雅交易所吗？
答：不是。
KAMARAJU 先生：对表格提出异议。
法院：驳回。
问：在你2021年的投资到今天之间，有没有出现过
你能够花喜马拉雅硬币购买的时候
任何东西？
答：不是。
问：周先生，我想回过头来一会儿
你为举报人运动所做的志愿者工作。
你能不能大致提醒陪审团什么类型的服务
你提供了。
答：是的。我做了视频笔录，还有翻译、视频
喜马拉雅山的编辑和流媒体服务

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          南区记者，P.C.
            (212) 805-0300
O5S1GUO3 Le Zhou-直播
联盟和农场成员。
问：关于你的志愿者工作，有没有来过
你参加其他志愿者会议的次数？
答：是的。
问：什么类型的会议？
答：这些是与郭文豪、农场的私下会面
成员。
问：会议的性质是什么？你们都去哪儿了
遇见？
答：我们使用了名为 Webex 的社交平台。
问：在会议期间讨论了什么（如果有的话）
Webex 上的志愿者？
答：这些会议包括简要介绍农场运动，
活动，还有追随者的投资，还有一些
其他问题，包括正义农场和全球联盟，以及
另外，还有 —— 当时的全球联盟，一个通缉犯
创建一个中央数据中心来集中所有
投资者的投资信息，这些会议是
进行了，全球联盟还要求每个农场来
农场会议。给他们指导，让他们转向
总的来说，他们的所有账目还有余额
喜马拉雅全球联盟的指定账户。
问：周先生，在志愿者工作的过程中，你说过
你参与了流媒体广播。那是否包括在内
与新中国联邦委员会活动有关的广播？

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          南区记者，P.C.
            (212) 805-0300
O5S1GUO3 Le Zhou-直播
答：是的。
问：这包括与抗议活动有关的广播吗？
答：是的。
问：你在直播中直播了哪些类型的抗议活动
你的志愿者工作？
答：2022年底，发生了抗议活动，这个名字叫做 90 天
抗议活动是抗议郭文贵的一位律师和他们
律师事务所。  
问：总的来说，90 天的主题是什么
抗议？
答：有人参与了 Miles Guo 的破产案件，而且
所以抗议是因为郭文贵宣布他是
被一名律师勒索，金额为
2.5 亿美元。
问：向后退一步，有过什么时候吗
你知道郭文贵已经申请破产了吗？
答：是的。
问：你是什么时候学到的？
答：郭迈尔斯在2月15日的广播中亲自做了，
2022年。
问：郭迈尔斯在广播中说了什么（如果有的话）
关于申请破产？
答：他刚才提到，我今天要签署破产协议，而且
因为我受到了迫害。
问：郭文贵声称自己是谁（如果有的话）

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          南区记者，P.C.
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迫害？
答：他提到了来自中共的迫害，他还提到
一些中共渗透到美国司法系统中。
问：当郭迈尔斯在 2022 年 2 月说这句话时，
你相信他申请破产的部分原因吗
他被中共迫害了？
答：当时我相信了。
问：回到 90 天抗议活动，大概在什么时候
抗议活动开始了吗？
答：这90天从2022年10月底开始，
最后——
问：对不起。来吧。
答：一直持续到一月底。
问：如果有的话，为什么 NFSC 成员在此期间抗议
那个时期？
答：因为郭文贵宣布了那次勒索
破产案件，还有——所以抗议活动开始于
多个地点。
问：你能解释一下你这么说的意思吗
宣布勒索。
答：他在广播中提到自己被勒索了
这位律师，他还提到了这笔款项，即2.5亿美元。
问：还有哪位律师？
答：律师的名字叫卢克·德斯平斯。
问：根据 Miles Guo 的广播，你的理解是什么

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          南区记者，P.C.
            (212) 805-0300
O5S1GUO3 Le Zhou-直播
卢克·德斯平斯在破产中的作用（如果有的话）？
答：他是郭文贵被法院任命的受托人。
问：在2022年的那个时候，郭文贵做了什么（如果有的话）
比如你提到的2.5亿美元？
答：他说，这太不可思议了，太离谱了；他很生气
那个。
法院：当你说法院任命的受托人时，什么
你指的是法庭？
证人：是的，法官大人。我相信这是新的
约克南区破产法院。
问：周先生，抗议活动针对的是谁，90
2022年的抗议天数？
答：律师卢克在律师家中发生了抗议活动，
他女儿的大学、前妻的家、律师事务所
办公室，还有他的一位同事律师的住所，还有一个
Luc 第二个女儿的工作场所。
问：谁指挥了抗议活动？
答：在 Miles 提到这起勒索事件之后，
喜马拉雅全球联盟发起，发起所有抗议活动。
问：你能描述一下喜马拉雅全球联盟是如何成立的吗
抗议活动。
答：它是这样组织的，所以录制了寄出表格的记录
去农场，询问谁愿意参加抗议活动，然后
我们还得知这次抗议活动将持续90％
好几天，所以农场负责人开始收集信息，

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          南区记者，P.C.
            (212) 805-0300
O5S1GUO3 Le Zhou-直播
派人到位，也在印刷材料
抗议活动。
问：你指的是哪位农场领袖？
答：当我加入新农场时，它叫做
华盛顿特区农场。
问：农场负责人打印了哪些类型的材料？
与 90 天抗议活动有关吗？
答：有海报、横幅和传单。
问：你能为评审团描述一些海报吗
为抗议活动而创建。
答：是的。有些海报上有律师卢克的照片，他的
上面的照片，但经过了修改，还添加了标题，
尤其是一些攻击性，某种意义——非常刻薄
海报上的标签。
问：添加的语言有哪些示例
那些在抗议活动中使用的海报？
答：他们大多称他为中共跑狗，邪恶。
问：在2022年90天抗议活动时，你有没有
我相信卢克·德斯平斯是 —— 我引用的是那句话 ——
中共的跑狗？
答：当时我相信了。
问：你为什么相信？
答：因为 Miles Guo 提到了勒索，而 Miles Guo 提到了勒索
提到卢克·德斯平斯的公司受到了中共的贿赂。
问：在 2022 年时，你对以下方面有任何个人了解吗

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卢克·德斯平斯是否曾勒索或企图勒索 Miles
Guo？
答：不是。
问：2022年时，你对以下方面有任何个人了解？
卢克·德斯宾斯的公司是否受到中共的影响？
答：不是。
问：今天坐在这里，你相信卢克·德斯平斯是
代表中共运作？
KAMARAJU 先生：反对，法官大人。
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.
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（在侧边栏上） 
法庭：为什么他今天的信念有意义？
MURRAY 女士：法官大人，因为事实如此
当时他正在做手术 —— 他的行为意图和
郭先生告诉他参加抗议活动。
法院：所以你已经证实了这一点。
MURRAY 女士：是的。
法庭：但是你问了他相信什么
现在，我想理解为什么这很重要。
MURRAY 女士：法官大人，我想这是 —— 什么
我要走到尽头，那是他来的时候
意识到这一切都是欺诈性的。他是一个
在被捕之前基本上一直信仰郭文豪，而且
然后在某个时候他开始意识到郭文贵是什么
告诉他中共的影响力，你知道，
因为中共而关闭银行账户，差不多
活动实际上是不正确的，那时正是这样
他有点意识到了，我也预料到了
Kamaraju 先生将盘问他，看看他做了什么
当时的信念怎么样，你知道的——他现在是为什么
为政府作证。而且我只是想试图
确定这一点。
KAMARAJU 先生：嗯，我认为他的信念不成立
今天就德斯平斯先生是否是特工出庭作证
中共的调查线索有任何关系

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默里女士在说。如果她想问他问题
比如，你知道，你什么时候变得可疑了，现在还在
时光倒流，与他所说的无关
现在，他现在在说什么。
法院：所以继续问这样的问题。
MURRAY 女士：好吧。
KAMARAJU 先生：谢谢你，法官大人。
（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） 
法庭：你可以继续。
MURRAY 女士：谢谢你，法官大人。
作者：默里女士：  
问：周先生，如果有的话，你在这方面的角色是什么
90 天抗议活动？
答：我的角色是直播技术员。我用软件来推送
退出广播。我把农场和客人联系起来。另外，我
为技术人员制定时间表，他们每天都要这样做
直播。
问：如果有人的话，谁给了你指示
直播 90 天抗议活动？
答：喜马拉雅全球组织提供了指导方针
联盟，一些具体的指导方针，在抗议期间，如果我们
听见任何客人或农场客人提及郭迈尔斯的话
或者如果他们说的是有组织的话，我们会削减
直播。
问：你能不能再解释一下这个指导方针
陪审团明白。那是什么指令
如果有人提到郭文豪，有关于直播的吗？
答：是的。因为所有的直播都是现场直播，所以有
是抗议地点与远程客人有关的人。
作为后端的技术人员，所以我们会收到这些
说明：如果有任何一个在直播中，则该图像，
或者客人这么说，我今天来抗议，那是因为

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如果是这样的话，Miles 告诉我，或者组织叫我来吧
说，我们会自动切断直播。
问：还有你在直播 90 的时候吗
Days 抗议说你不得不切断传输，因为
指的是郭文豪？
答：我个人曾经做过一次。
问：我想暂时回到喜马拉雅硬币上
投资。
MURRAY 女士：Loftus 女士，如果你可以的话请发表
政府展品 V0107 和 V0108 就是明证。
好吧。实际上，我们将继续前进一会儿。
洛夫特斯女士，如果你可以的话请公布政府
展品 V0105。
答：对不起。我的——哦，明白了。
问：周先生，你认出政府展品 V0105 吗？
答：是的。
问：这是什么？
答：这是在 Webex 上与郭文贵和... 一起参加的会议
英国伦敦俱乐部会员。
问：从左上角开始，屏幕里那个是谁
显示在左上角？
答：那是我。
问：就在你的右边，那是谁？
答：郭文豪。
问：在郭迈尔斯旁边的照片中，在你的另一边，

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看来有一张海报。你能读懂那是什么吗
海报说。
答：是的，谢谢。讲英国喜马拉雅伦敦俱乐部。主机。
问：对不起。就在它的左边，有一个屏幕
只是一堵白墙和一张海报。那张海报说了什么？
答：哦，对不起。好吧。明白了。
中国新联邦州。
问：现在再往右走，你只是
阅读，它对中描绘的人有什么启示
那个屏幕？
答：那是英国伦敦俱乐部领袖戴维·戴，他主持了
Webex 软件。会议由他的账户发起。
问：你认出戴维·戴身后的旗帜吗？
答：是的。
问：这是什么？
答：那是 NFSC 的旗帜。
MURRAY 女士：洛夫特斯女士，如果我们能把它记下来
然后把标有政府展品的东西放在证人面前
V0106。
法官大人，谨慎起见，
政府开始承认先前的展品，即
政府展览 V0105。
KAMARAJU 先生：不反对，法官大人。
法院：可以接受。
（收到的政府展品 V0105 作为证据）

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MURRAY 女士：这是政府展览 V0106。
现在只向证人展示了这一点。
作者：默里女士：  
问：周先生，你认出政府展品 V0106 吗？
答：是的。
问：总的来说，它是什么？
答：这是我参加的又一次会议。这次会议是
郭文辉和——还有其他农场的铁血成员
成员。
MURRAY 女士：法官大人，政府开始承认
政府展览 V0106。
KAMARAJU 先生：没人反对。
法院：可以接受。
（收到的政府展品 V0106 作为证据） 
MURRAY 女士：我们能不能发布一下。
作者：默里女士：  
问：周先生，从这里的左上角开始，描绘的是谁
这个屏幕截图的左上角有吗？
答：这是另一位农场领袖。
问：哪个农场的负责人？
答：日本，东京恒星IS农场。
问：在右上角，屏幕上描绘的是谁
显示在那里？
答：他是新中国联邦金融服务委员会主席。
问：然后看看左下角，这个人是谁

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站在那里描绘的东西里？
答：郭文贵站着。
MURRAY 女士：Loftus 女士，如果我们能放大一下这个问题
请在屏幕左下角。
问：周先生，你认出里面还有其他人吗
那个特定的屏幕截图？
答：是的。
问：谁？
答：所有这些。
问：所有这些？
答：是的。
问：总的来说，你能描述一下这些人是谁吗
以及他们的角色是什么。
答：就在郭迈尔斯旁边，这位女士，她的名字叫做
萨拉大法官。
问：然后描绘的雄性有点像坐在后面
左边？
答：是的。他的名字叫长岛大卫。
问：大卫长岛与哪个农场（如果有的话）有关系？
答：他曾与纽约山香料公司有过联系。
问：然后在右边，第二个人
桌子后面的右边？
答：她的名字叫 Fay Fay。
问：最后是在这件事中最右边的人
照片？

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答：她的名字叫露丝·雷。
问：总的来说，这次会议讨论了什么
你参与了吗？
答：这次会议聚集了许多其他农场管理人员
团队、农场领导，甚至还有一些受邀成员，进行讨论
关于向喜马拉雅全球联盟报告的一些问题。
MURRAY 女士：你可以把它记下来，洛夫特斯女士。
谢谢。
问：周先生，有过英国农场要求的时候吗
您在某些银行活动方面的协助？
答：是的。
问：那是什么时候？
答：那是 2022 年 2 月。
问：当时谁是英国农场的负责人？
答：戴维·戴。
问：你能否向陪审团描述一下，戴维·戴有什么（如果有的话）
要求你做。
答：是的。他亲自给我打电话，问我能不能帮忙
这个农场，帮助所有追随者获得金钱和
帮助他们投资G系列。
问：戴维对他的原因说了什么（如果有的话）
需要你的帮助吗？
答：因为他几乎没有其他人创办企业而且
开设银行账户，但它们被关闭了，他们需要
仍然有人要开设更多账户来帮助关注者。

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问：戴维对这些原因说了什么（如果有的话）
账户被关闭了吗？
答：有些账号，之所以提起是因为中共
不想让那些人投资，而中共正在做的一切，那些
账户被关闭了。
问：2022年2月，那个时候，你相信那家银行吗
账户因为中共而被关闭？
答：是的，当时我相信。
问：戴维指示你做什么（如果有的话）
关于开设银行账户？
答：是的。我们讨论了如何开户，该说些什么
银行，还给了我关于开放业务的指示，将
让他成为百分之百的所有者。
问：如果有的话，戴维让你告诉了什么
银行是这些账户的用途？
答：因为 David Dai 当然也知道我的个人
生活也是我作为房地产经纪人的占有率 [原文如此]，所以他指示了
他提到的如果我提这个账户会更容易
当我们确定它用于房地产开发时。他们是
还要匹配我目前的入住率这样就不会触发
很多防弹片，那更容易被打开
账户。
问：你是否听从了戴维的指示，实际上是开门的
银行账户？
答：是的，我做到了。

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问：你开设这些银行账户之后有钱流入吗
账户？
答：是的。
问：总共大约有多少钱？
答：估计约为200万美元。
问：你能确定这笔钱的来源吗
存入了你开的银行账户？
答：我只能看到电线，如果是个人发来的，或者
有些电汇，来自企业账户。
问：你知道这些人是怎么知道要汇款的吗
你的银行账户？
KAMARAJU 先生：反对，法官大人。
法院：持续。
问：周先生，你提到你看到电线进入了
账户；对吗？
答：是的。
问：您是否向任何人提供了账户信息
向你的账户汇款的人？
答：不是。
问：你知道谁提供了你的银行账户吗（如果有的话）
向这些人提供信息？
答：是的。
问：谁？
答：来自英国伦敦俱乐部的成员之一。
问：如果有的话，你用流入的钱做了什么

266
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你开的银行账户？
答：当我看到钱时，我会记账，用账单记录下来
英国领导人创建的电子表格。一旦确定了
金额，我会收到汇款到哪里去的指示
到。
问：你从谁那里收到指令（如果有的话）
关于把钱寄到哪里？
答：农场，英国领袖，还有其他几个英国成员。
问：你开设这些账户的报酬了吗？
答：不是。
问：你有没有保留通过那些赚来的钱
账户？
答：不是。
问：我想暂时回到喜马拉雅交易所。
MURRAY 女士：我要试着读这所老派了。
法官大人，又是 V0107 和 108。我
我相信在休息前这些都被承认了但再说一遍
谨慎起见，如果他们没有被正式接纳，
我们要承认了
法院：没有异议？
KAMARAJU 先生：不，法官大人。
法院：他们被接纳了。
（政府的展品 V0107 和 V0108 已收到 
证据） 
MURRAY 女士：所以这是政府展览 V0107。如果

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我们可以向陪审团公布
请问我们能不能把它发布出来。谢谢。
作者：默里女士：  
问：周先生，在我们休息之前，我们在看
这个。这是发来的东西，我相信你说过了
曾在你的电脑里；对吗？
答：是的。
问：你准备好这个电子表格了吗？
答：不是。
问：你知道谁准备了这个电子表格吗？
答：我不知道。
问：谁把这个寄给你的？
答：英国成员之一。
问：我只想谈几个不同的问题
这里的专栏以及所反映的内容。
首先，有一列——第二列
Discord Discord 说。你看见了吗？
答：是的。
问：那里显示了什么信息？
A. Coffee Cantata，然后是两个中文单词。
问：你知道谁在使用 Discord 用户名吗（如果有的话）
咖啡康塔塔？
答：我用过了。
问：看看这里的两排，你能不能为陪审团解释一下
这篇文章的顶部反映了什么信息

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          南区记者，P.C.
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电子表格。
答：当然。在会员 ID 号 “会员 UK2020H170” 下方，是
分配给我用于投资的唯一身份证。
在 Discord Discord 之后向右移动，在顶部
名为A005的账户，那是投资账户的电话
由喜马拉雅全球联盟创建。
就在它旁边，硬币汇率。这反映了
喜马拉雅硬币，作为 0.5。
然后紧接着，是中文翻译成
一个月的投资。
然后就在下一专栏之后，是中国人的反思
转换为福利币的数字，这些数字反映在H币上
数字。
问：那么专注于不同的行，这是正确的吗
最右边第二的专栏，那个有小号的专栏
表情符号或图标，该列反映了投资金额；是
那对吗？
答：是的。
问：那么以第一行为例，什么是投资（如果有的话）
反映在 59.93？
答：这反映在一项名为苹果币的投资中。
问：那是你所做的与之相关的投资吗
G 系列产品？
答：是的。
问：看看下一行，31,300，投资多少，如果有的话，

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这反映了吗？
答：这反映了VOG的投资。
问：这与哪家公司的私人有关
放置？
答：Guo Media在GTV上的投放。
问：看接下来的两行，两行都有账户
代码 8142。50,000 和 20,000。投资（如果有的话）有什么作用
这与？
答：这5万美元反映了我的G|CLUBS五级投资；
20,000美元反映了G|CLUBS二级投资。
问：然后是下一行，21,000，什么投资，如果有的话，
这反映了吗？
答：这反映了我在英国农业贷款协议中的投资。
问：最后，那行 1500，有什么作用（如果有的话）
这反映？
答：这反映在我的捐款中。
问：那么看看最右边的栏目，信息是什么
在与你的喜马拉雅硬币相关的最右栏中
购买？
答：那是使用硬币汇率计算得出的，0.5，乘以
通过我的投资，我将获得多少硬币。
问：根据之前的计算，你收到了多少硬币
投资？
A. 40,935 枚硬币。
MURRAY 女士：我们可以把这个记下来。

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问：周先生，你有过申请退款的时候吗
你在 G 系列上投资了多少钱吗？
答：是的，我做到了。
问：那大约是什么时候？
答：2023 年 7 月 15 日。
问：你要求退还哪笔钱（如果有的话）？
答：我申请我的G|CLUBS投资退款。
问：你是如何申请退还你的 G|CLUBS 投资的？
答：按照指示，对于所有问题，我将联系
首先是农场负责人，所以我联系华盛顿特区的农场负责人
申请退款。
问：如果有的话，对退款的回应是什么
请求？
答：这不愉快——首先他们只是提出了一个请求
表格，让我填写。
问：你填写了那张表格吗？
答：是的，我做到了。
问：接下来发生了什么？
答：然后在很长一段时间内我一无所获
回复，所以我必须回复他们并进行后续跟进，
多次后续行动。但是他们想验证我的
投资。
然后，他们要求我填写申请表。
他们问我他们只会把 HDO 退还给我，不能以法定货币的形式退还给我
对我来说是货币。

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问：需要明确的是，当你说 HDO 时，你是什么
指的是？
答：喜马拉雅美元。
法院：那你所说的法定货币是什么意思？
证人：因为我最初所有的投资都是
将其发送给投资——使用电汇进行G系列投资，已付款
美元。
法庭：所以你说美元是法定货币
货币？
证人：没错。
作者：默里女士：  
问：还有周先生，当时农场提出退款
你在 HDO 里的 G/CLUBS 钱，你有机会进入喜马拉雅山吗
交易所账户？
答：我不知道。
问：你有机会获得任何喜马拉雅硬币吗
已经寄钱到农场去买了吗？
答：我不知道。
问：当时你申请了退款，但确实如此
在 HDO 中提供，无论你是否在 HDO 中，你都有个人知识吗
事实上拥有的喜马拉雅硬币还是喜马拉雅美元？
答：我解决了这个问题。我——
问：你这样说是什么意思？
答：我告诉他们这个要求退还我的投资
HDO 不可接受，因为我没有 HDO 账户，

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喜马拉雅交易所账户，所以我说我只会收到
这种货币是法定货币。
问：对你这么说的回应是什么（如果有的话）
你不会接受 HDO 的退款吗？
答：所以还有很长的等待时间。他们只是
让我等。
问：你有没有收到退款
G/CLUBS 钱？
答：是的，我做到了。
问：那是什么时候？
答：2023 年 12 月 1 日。
问：那你收到那是什么情况
退款？
答：我必须签署一份没收H币的协议，我也有
把一些设备退还给他们，这就是我的全部条款
必须同意。
问：拿走装备，你是什么类型的装备
需要退货？
答：就因为我曾经是 —— 作为一名流媒体技术员，华盛顿，
DC Farm 派出了某些设备进行广播
我当时手里拿着的设备。所以一个月后，有一次我
申请退款，他们还会要求我退货
设备也一样。
问：你还提到你必须在没收的东西上签名
您的喜马拉雅硬币可获得退款。你能解释一下吗

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请陪审团。
答：是的。既然我申请了退款，那么他们也给我发了
之前已经同意我必须没收所有喜币了
从投资中获得。
问：那你花了多少钱购买了那枚H币
没收？
答：总的来说，我花了5500美元买了硬币。
问：你真的签署了没收 5,500 美元的协议吗
H币的价值？
答：我别无选择。我被迫在那上面签字。
问：在你申请 G 俱乐部退款之后的某个时候
钱，举报人运动的反应如何（如果有的话）？
答：来自——
KAMARAJU 先生：反对，法官大人。
法院：至于形式，维持不变。
问：周先生，举报人运动中有谁去了
你知道了，知道你已经申请退款了吗？
KAMARAJU 先生：反对，法官大人。相同。
法院：持续。
问：周先生，你有没有被除名
英国农场？
答：是的。
问：你能描述一下发生了什么吗。
答：在我归还设备之后，农场负责人就是
把我从 Discord 服务器中移出去，把所有东西都删掉

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通信，而且他们还把我拒之门外
频道，要么是农场、Discord、WhatsApp，我完全没问题
已移除。
问：你被移除出境的大概是什么时候发生的
农场 Discord 频道？
答：那是在2023年9月。
问：把注意力转移到 2024 年 1 月，有没有
你的信息曾在盖特上发布过吗？
KAMARAJU 先生：法官大人，反对表格。什么
信息？
法院：持续。
MURRAY 女士：为什么我们不干脆解散政府
附录 V02，这是显而易见的。
问：周先生，你认识这个吗？
答：是的。
问：这是什么？
答：这是 gettrsocialmedia.com 上的一篇文章。
问：你能不能提醒陪审团盖特是什么。
答：是的，盖特是 G 系列的。这是一个社交平台
由 Miles Guo 创建，与推特的类似。
问：看看与之相关的英文翻译
这篇文章，你能看一下这个公告的标题吗。
答：全球喜马拉雅农场联盟黑名单公告。
问：如果有的话，你能理解黑名单的含义是什么
尊重喜马拉雅农场联盟？

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答：适用于任何反对该运动的被告，或者 Miles
郭个人将被列入黑名单。  
问：看看这里列出的第 2 项，你能不能读一读
那个。
答：对不起。请再来一次。
问：是的。你能阅读这里列出的第 2 项吗。
答：是的。2024 年 1 月 21 日，华盛顿特区农场和
归类做出了以下黑名单决定：列入黑名单，
Coffee Cantata，Wen Lu，中文版。第 5082-Coffee Cantata。
排除原因，对举报人的恶意攻击
革命和 G 系列。列入黑名单的人有权利
在当天起的五天内提出上诉
公告和申诉将被忽略。
问：Coffee Cantata 的周先生，是不是——那是用户名
你用过的？
答：是的。
问：在这份黑名单发布之前，你有没有收到任何通知
盖特上发布了公告？
答：不是。
问：你对公开发布的反应是什么（如果有的话）
黑名单？
答：首先，我之后看到了这个。那不是事实。我
从未攻击过举报人运动或 G 系列。
问：你对这个黑名单决定提出上诉了吗？
答：因为我已经在上诉日期之后看到了，

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津贴日期。
MURRAY 女士：我们可以把这个记下来，洛夫特斯女士。谢谢
您。
法庭：先生，你的答案是什么？她问
你是否上诉。
目击者：我做不到，因为我看到这篇文章是
在这个吸引人的津贴日期之后.
法庭：你可以继续。
MURRAY 女士：谢谢。
作者：默里女士：  
问：你有没有停止支持 Miles
Guo？
答：是的。
问：那是什么时候？
答：那是 2023 年 6 月左右。
问：你为何在 2023 年 6 月左右停止支持郭文豪？
答：因为有很多动作，动作，我
亲眼所见是错误的，我——我不想参与其中，所以
这就是为什么我决定停下来。
问：你能描述一下你所指的一些动作吗
到。
答：因为农场内还有一个省份和
全球联盟。尤其是英国伦敦俱乐部，领导者是
被指控不当使用法治基金会的资金。
有很多问题永远无法真正得到解决。还有我们——

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亲自报告了很多，很多问题，从来没有
得到答案或解决了。
问：周先生，你在G上总共花了多少钱
我们一直在讨论的系列产品？
答：总额约为12万美元。
问：那你是如何支付这些投资或这些成本的
G 系列？
KAMARAJU 先生：反对，法官大人。
法院：维持原状。
问：周先生，你花的钱的来源是什么
关于 G 系列的产品？
KAMARAJU 先生：同样的反对意见。
法庭：请加紧努力。
（下一页继续）

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（在侧边栏上） 
法院：那么你是否以此为由提出异议
没有确定有报价吗？
KAMARAJU 先生：不，我之所以反对，理由是
支付此次发行的资金来源无关紧要。
法院：驳回。
（下一页继续）

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（在公开法庭上）
法院：驳回。你可以回答。
证人：是的，法官大人。
答：这笔钱的来源是我的个人收入，而且
我还卖了我的房产，我卖了公寓，我还拿了
把我妻子的人寿保险拿出来
问：你为什么要出售公寓，你的个人房地产
财产？
答：因为我——当时我需要向喜马拉雅交易所兑现
代币发行，但我投资了G|CLUBS，所以当时我没有
有足够的资金，但我——我唯一拥有的就是我的
共管。我必须这样做 —— 而且我把它卖掉了。
问：你妻子的人寿保险呢？为什么（如果有的话）
你兑现了人寿保险单？
答：那笔钱，她同意把它存入农场借款项目。
问：周先生，你从中赚了多少钱（如果有的话）
你在 G 系列产品上花了大约 120,000 美元？
答：零利润。
问：你总共损失了多少钱（如果有的话）
报价？
答：我损失了大约 30,000 美元。
问。30,000 美元？
答：或者更多。
问：在您投资 G 系列产品时，
你相信他们会盈利吗？

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答：是的。
问：在您投资 G 系列产品时，
你相信郭文贵会亲自为任何东西付出代价吗
你因这些投资而蒙受的损失？
答：当时我相信了。
问：Guo 是否真的向你偿还了大约 30,000 美元
你在G系列的投资中损失了吗？
答：不是。
MURRAY 女士：法官大人，请允许我稍等片刻。
没有别的了。
法院：盘问。
KAMARAJU 先生：是的。谢谢你，法官大人。
交叉检查 
作者：KAMARAJU 先生：  
问：下午好。
答：下午好，先生。
问：我只想确保说出你的姓氏
正确地。周先生？
答：正确。
问：好吧。谢谢。
现在你刚刚作证说郭先生从来没有还过钱
你说的损失金额，对吗？
答：正确。
问：你从来没有和郭先生说过话，对吧？
答：我和他说过话。

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问：你和他谈过要回钱吗？
答：不是。
问：你从来没有要求他退款，对吗？
答：我把它邮寄给他了。
问：你把它邮寄给了郭先生？
答：是的。
问：郭先生不使用邮箱，对吗？
答：我把它邮寄到——
MURRAY 女士：反对。
法院：持续。
问：你以前从未给郭先生发过电子邮件，对吗？
答：我没有给他发电子邮件。
问：好吧。所以他从来没有回复过你的电子邮件
已发送，对吗？
答：从未回复。
问：而且他从来没有亲自给你发过电子邮件，对吗？
答：正确。
问：好吧。现在我想从法治基金会开始。
你还记得为此作证吗？
答：是的。
问：而且你作证说你第一次在媒体上听说过这件事
2018 年 11 月的会议，对吗？
答：正确。
问：你的证词是你离开了那场新闻发布会
给人的印象是郭先生要为法治提供资金

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法律基金会到一亿美元，对吗？
答：正确。
问：这就是检察官今天在这里问你的，
对吧？
答：是的。
KAMARAJU 先生：我们可以举办政府展览吗
拜托 W1005V。这是证据，所以我们可以发布它。
如果我们能玩一会儿。
（视频已播放）
KAMARAJU 先生：好吧。我们可以在那里停下来。
问：现在他们之前问过你这个片段，对吗？
答：是的。
问：他们问你是否明白
郭先生曾就拨款一百美元作过陈述
百万美元捐给法治基金会，对吗？
答：正确。
问：好吧。那不是郭先生，对吧？
答：那不是。
问：那是史蒂夫·班农，对吧？
答：正确。
问：Steve Bannon 长得一点也不像郭先生，对吧？
答：不是。
MURRAY 女士：反对，法官大人。
法院：驳回。来吧。
问：这是史蒂夫·班农在说话，对吗？

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答：正确。
问：所以他们问了你一个关于陈述的问题郭先生
制作了，但他们给你看了班农先生的片段，对吗？
答：正确。
问：但是后来你回答说你对郭先生的期望是
要为付款提供资金，对吧？
答：正确。
问：现在这不是你第一次看这个视频
剪辑，对吧？
答：正确。
问：你以前和他们一起准备的时候已经看过了，对吧？
答：我是在直播的时候看到的，就是这个新闻发布会直播的时候。
问：好吧。我们会回过头来谈这个问题。但是你也看过了
和检察官在一起，对吧？
答：是的。
问：他们已经在今天之前给你看了，对吧？
答：是的。
问：当你准备证词时，他们给你看了
他们，对吧？
答：没有准备证词，但他们给我看了。
问：好吧。好吧，你已经多次见过检察官
时间，对吧？
答：是的。
问：这些检察官坐在这里，对吧？
答：不是全部。

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问：其中一些，对吧？
答：是的。
问：哪些？
答：其中四个。
问：好吧。所以坐在前面的四个人
桌子？
答：不是左边的四个，但是——
问：好吧。其中一些人，对不对？
答：正确。
问：那里有联邦调查局特工，对吧？
答：不是。我不知道。
问：你第一次见面时那里没有联邦调查局特工
检察官？
答：我不知道是不是联邦调查局。我不知道。
问：你第一次见面时那里有翻译吗
检察官？
答：不是。
问：你第一次见到他们的时候没有翻译？
答：没有翻译。
问：所以你从来没有用过翻译器来和他们说话
检察官；对吗？
答：我没有使用翻译器。
问：好吧。现在你作证说他们给你看了这个片段
在其中一次会议上，对吧？
答：正确。

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问：你会说你和他们开了多少次会
检察官？
答：大约七个。
问：大约七点，对吧？
答：是的。
问：那是你与检察官会面的七次了
来讨论你今天的证词，对吧？
答：不讨论。
问：好吧。那你在七次会议上谈了什么？
答：所以我刚才被问到答案。
问：好吧。好吧，他们在问你什么？
答：被问及与案件有关的问题。
问：对。他们问了你和今天一样的问题，
对吧？
答：正确。
问：然后你给出了答案，对吧？
答：是的，我做到了。
问：好吧。有时候如果他们不喜欢你的那个
答案，他们问了另一个问题，对吧？
答：不是。
问：所以你是在告诉我七次会议中没有
指出他们问你后续问题的地方；那是你的吗
证词？
答：他们要求采取后续行动——
MURRAY 女士：反对。

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法院：持续。保持原来的样子
思考。
KAMARAJU 先生：哦。很抱歉，法官大人。
法庭：你可以问他们是否要求采取后续行动
问题。
KAMARAJU 先生：哦，对不起。我以为我就是这样
问。
作者：KAMARAJU 先生：  
问：所以在七次会议中，这是你的证词
检察官从来没有问过你后续问题？
MURRAY 女士：反对。错误地描述了
证人的证词。
法院：持续。
问：好吧。现在你作证说你都看过这个片段
在与检察官会面时但你也看到了现场直播，
正确？
答：正确。
问：好吧。现在，即使是班农先生，这个片段也不是全部
在那次新闻发布会上不得不说，对吧？
答：没错。
问：他的讲话要长得多，对吧？
答：是的。
问：他向媒体提问，对吧？
答：是的。
问：好吧。他谈到了郭先生所做的努力

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支持反共运动，对吧？
答：是的。
问：他说的是郭传媒，对吗？
答：是的。
问：实际上，班农先生甚至被问到一个问题，即是否
特朗普政府参与其中，对吧？
MURRAY 女士：反对，法官大人。
法院：驳回。你可以回答。
答：不是。
问：你不记得了吗？
答：从来没问过。
问：好吧。所以你的证词是：从来没有人问过班农先生
那个问题，对吧？
答：请你再重复一遍。
问：是的。记者问班农是不是特朗普
行政部门将参与法治
基金会？
答：不是。班农从未提及过特朗普。
问：好吧。而且从来没有人问过他，对吧？
答：在那次会议上，不是。
问：好吧。现在郭先生确实在那次会议上发言了，对吗？
答：是的。
问：好吧。而且我想你谈了几个话题
他在你直接作证时讨论过的。你呢
还记得吗？

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答：哪些话题？
问：好吧，如果我弄错了请原谅我，但我相信一个
你说的话中有他讨论过调查
企业死亡。你还记得为此作证吗？
答：对不起。不是投资——商业数据，
调查——班农先生说要调查神秘的中国人
商人的死亡。
问：好吧。这是指什么？
A. 提及该法治基金会基金将如何运作
可以使用。
问：好吧。好吧，班农先生还谈到了这样一个事实
已经对一名中国人的死亡进行了调查
商人，对吗？
答：正确。
问：那是一家名为海航的公司的董事长，对吗？
MURRAY 女士：反对。
法院：驳回。你可以回答。
答：是的。
问：郭先生此前曾预言过他的死亡
海航董事长，对吗？
MURRAY 女士：反对，法官大人。传闻和
相关性。
法院：持续。
KAMARAJU 先生：我不是为了说实话，你的
荣誉。

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法庭：如果你愿意加紧努力。
（在侧边栏上） 
法院：问题是：郭先生有
此前曾预言过——
KAMARAJU 先生：是的。我不是为了说实话而说的
关于那个人的死亡，只要他预料到了，他就知道了
听见他说了
法庭：会议期间？
KAMARAJU 先生：不。在会议之前，你的
荣誉。
法院：嗯，它有什么关系？
KAMARAJU 先生：因为证人作证了这一点
郭先生透露了他所说的机密信息
信息，这是吸引人们的原因之一
证人。我的意思不是在那个美国人的环境中归类
政府使用它。我的意思是有关的机密信息
中国政府，这就是吸引他的原因。我只是
跟进。我不打算在这上面花很长时间。我
还有两个问题。
MURRAY 女士：我不明白这怎么不是传闻。我
不明白它有多重要。
法庭：我只是不记得这个证词了
你指的是，你说的是这个证人这么说的
他被郭先生吸引的原因之一是因为他
提到了一个商人的死亡？

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KAMARAJU 先生：不。他说他知道郭先生
有未知的细节。他称其为机密
信息。我不是这么称呼的。但是他提到
有关中国政府官员的秘密信息，以及
这就是郭先生透露的；这是其中一件事
这吸引了他。
法庭：我不得不说我记不起来了
特别的证词。他就是这么说的吗？
MURRAY 女士：他表示这是其中之一
郭文贵在他的广播中报道过的话题。但首先
总而言之，我认为卡马拉朱先生的说法是
本次广播中甚至没有提及任何内容。它是一个
郭迈尔斯的庭外声明。我也不这么认为
据称对一名中国商人死亡的预测
属于潜在机密的这一大类
有关中国政府官员的信息。我就是不知道
查看连接。
法院：因此，这个预测不发生在
会议。
KAMARAJU 先生：不。会议开始前，郭先生
预言它会发生。死亡发生在
会议。然后，班农先生在会议上指出了那个
郭先生所做的事情之一是调查
商人的死亡。
法庭：好吧。我会允许这个问题的。

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KAMARAJU 先生：谢谢你，法官大人。
（在公开法庭上） 
法院：驳回。
作者：KAMARAJU 先生：  
问：先生，你还记得这个问题吗？
答：请你再说一遍。
问：是的。
KAMARAJU 先生：很抱歉这么做，但是
请法庭记者考虑回读这个问题。
（读取记录） 
法院：你可以回答。
证人：是的，法官大人。
答：是的。
问：班农先生在新闻发布会上讨论了这个问题，
正确？
答：是的。
问：他说郭先生会派人去
调查死亡情况，对吗？
MURRAY 女士：反对。
法院：驳回。你可以回答。
答：那部分我不记得了。
问：好吧。你怎么了——你不记得班农先生说话了
关于郭先生派出调查人员——
MURRAY 女士：反对。问了又回答，你的
荣誉。

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法院：持续。来吧。
问：现在你直接作证说你理解了
什么是新中国联邦，对吗？
答：正确。
问：提醒我们，新中国联邦代表什么？
A. 中国新联邦国。
问：好吧。而且它由愿意的人组成
喜欢推翻中国共产党，公平吗？
答：是的。
问：而你就是其中之一，对吧？
答：是的。
问：所以你有共同的目标，对吧？
答：是的。
问：现在是NFSC，那就是中国的新联邦州，
对吧？我们在说同样的事情？
答：是的。
问：NFSC 成立于 2020 年 6 月 4 日，对吗？
答：正确。
问：你看了关于那次创始的视频，对吧？
答：是的。
问：郭先生在场，对吗？
答：正确。
问：他当时在自由女神像前，对吧？
答：不在前面。他在船上。
问：好吧。所以船就在自由女神像前，

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对吧？
答：差不多了。
问：还有其他人出现在视频中，
正确？
答：是的。
问：其中一位是中国著名的足球明星，对吧？
答：他出现在网络直播中。
问：好吧。所以你可以在广播中看到他，对吧？
答：是的。
问：班农先生也在场，对吧？
答：正确。
问：他们正在谈论这个的创立原因
替代政府，对吧？
答：是的。
问：好吧。这是在COVID大流行期间，对吗？
答：是的。
问：好吧。现在你直接谈了这个问题，
但这个想法是，新中国联邦将是另一种选择
政府归中国共产党，对吧？
答：是的。
问：所以你在直接 “生态系统” 上使用了这个词，有
构成新中国联邦金融服务委员会生态系统的各种企业，
正确？
答：是的。
问：所以你说过 GTV，对吧？你为GTV作证。

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那是将进入生态系统的公司之一？
答：是的。
问：还有 G/CLUBS，那是另一家将加入的公司
生态系统，对吧？
答：是的。
问：还有喜马拉雅交易所，那是另一家公司
会在里面，对吧？
答：是的。
问：每个不同的组件都可以发挥作用
作为该生态系统的一部分，对吗？
答：目标是一样的。
问：我想说的是他们有不同的目的，
对吧？
答：目的都是一样的。
问：好吧。好吧，让我用这种方式试试吧。所以 GTV 是个社交场所
媒体公司，对吧？
答：是的。
问：喜马拉雅交易所是一家加密货币交易所，对吧？
答：是的。
问：而且他们都做不同的事情，对吧？
答：正确。
问：但它们都是 —— 他们本来都想成为其中的一部分
更大的 NFSC 目标，对吧？
MURRAY 女士：反对。
法院：驳回。你可以回答。

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答：是的。
问：因此，就目的而言，GTV本来是想成为一个
没有中共审查制度的社交媒体平台，
正确？
答：是的。
问：而且 G/CLUBS 是 NFSC 成员联系的一种方式
彼此，对吗？
答：不是。这是用来投资的。
问：这是用于投资的。
答：是的。
问：你没有直接作证说你会得到一个
护照是G/CLUBS的一部分，对吧？
答：是的。
问：那本护照本来是新中国联邦的护照，对吧？
答：是的。
问：好吧。因此 G/CLUBS 是针对 NFSC 成员等的
理由，相互交往，对吗？
MURRAY 女士：反对，法官大人。问了还有
回答。
法庭：我会允许这个问题的。
答：不要与其他成员交往，因为每个投资者
是单独的。我们不知道他们的信息。
问：所以你加入了 G/CLUBS，对吧？
答：是的。
问：好吧。当你加入 G/CLUBS 时，你为加入感到自豪吗

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G/CLUBS？
答：是的。
问：好吧。你在表现出对新中国联邦的承诺；
是你购买 G/CLUBS 会员资格的原因之一，
对吧？
答：我想买股票还想买护照，那是
许诺。
问：好吧。我没问你承诺了什么。我刚才问了
你为什么这么做，对吧？
MURRAY 女士：反对，法官大人。
法庭：所以不要作证。
问：好吧。你说过你想拿护照，
对吧？
答：是的。
问：那是新中国联邦的护照，对吧？
答：是的。
问：好吧。你还就农场贷款作证，对吧？
答：是的。
问：农业贷款旨在为农业提供资金
农场的工作，对吧？  
答：那是基金，将用来做什么。  
问：对。然后你直接作证，你说会的
用于农场的营运资金，对吧？
答：正确。
问：那是农场的事，对吧？

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答：农场可以将其用作运营资金。
问：好吧。因此，农场可以自行决定在其上使用它
操作，对吧？
答：是的。
问：因此，如果农场决定要把钱花在这上面，他们
可以把它花在这上面；如果他们想把它花在那上，他们
我可以把它花在上面，对吧？
答：还有限制。
问：好吧。而且这种限制是在贷款中发现的
协议；对吗？
答：我不记得了。
问：好吧。所以你不记得这个限制在哪里
位于，对吧？
答：在哪里，我不记得了。
问：好吧。现在我相信你在中国生活到1998年
正确？
答：正确。
问：那么 NFSC 的政治目标，可以公平地说吗
他们在美国比在中国更容易获得支持？
答：是的。
问：在这里，你可以选择把钱花在这些上
产品，对吧？
答：在哪些产品上？
问：好吧，以 G/CLUBS 为例，对吧？那是你的选择；你
可以花钱，对吧？

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答：是的。
问：就像没有政府机构阻止你一样
花在上面，对吧？
答：正确。
问：就像你作证的那顶帽子一样，这是你的
选择，对吧？如果你愿意，你可以买这顶帽子，对吧？
答：是的。
问：还有你说的哨子，你的选择，对吧？
答：但是所有的购买也是为了增长 G
时尚是投资之一。我把它当作不只是
纯粹是购买物品，但要共同支持增长。
问：好吧。为了支持公司的发展，对吧？
答：作为股东。
问：好吧。但你实际上并不是 G Fashion 的股东，
对吧？
答：不是。郭文亮提到，我们的投资将包括G
时装股。
（下一页继续）

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作者：KAMARAJU 先生：  
问：你从来没有 G Fashion 的股票；对吗，先生？
答：我没有股票。
问：好吧。你不知道 —— 你不知道有多少股票
你甚至以为你被许诺了，对吧？
答：承诺每股一美元。
问：好吧。那么你花在 G Fashion 上的所有钱都要花一美元？
答：不花钱。是 —— G Fashion 在未来，G
时装的总收入用于G系列的投资。
问：好吧。所以回到我最初的问题，那个
是你选择花钱买的，对吧？
MURRAY 女士：反对。
法院：驳回。你可以回答。
答：是的。
问：现在，先生，你直接作证说你进入房地产业
生意；是这样吗？
答：是的。
问：而且你从事房地产行业的时间不止一年
十年，对吧？
答：正确。
问：所以你在这方面很有经验，对吧？
答：是的。
问：你的公司叫东西方奢侈品集团；是吗
对吧？
答：不，那是我的小团体。

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问：对不起？
答：那是我的内心小组。
问：那是你的内心群体。好吧。
对不起，你的公司叫什么名字？ 
A. 联合地产集团。
问：那你专门研究任何特定类型的房产吗？
答：是的。
问：那是什么？
A. 住宅。
问：好吧。你有特定类型的客户吗？
答：你的意思是——
MURRAY 女士：反对，法官大人。
法院：驳回。你可以回答。
答：对不起，你所说的 “特定” 是什么意思？
问：好吧，举个例子，你专攻高端吗
住宅物业？
MURRAY 女士：反对，法官大人。402. 403。
法院：驳回。你可以回答。
答：我只是住宅。我不认为特别，如果
它是高端住房，或者是低收入住房，或者是经济适用房。
问：好吧。所以你基本上是全域的？
答：是的。
问：好吧。现在，您可以向客户提供与以下方面相关的建议
那些交易，对吧？
答：对不起，哪些交易？

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问：只是你的房地产业务，对吧？
答：我只给房子看看，提供有关信息
房屋，但我无法控制金钱或收钱。
问：不是。先生，我不是想欺骗你。我不是在问你
如果你收到了钱还是没有收到钱。我只是
问的是，你是否向客户提供与之相关的建议
购买他们的房屋，对吧？
答：是的。
问：好吧。其中一部分建议是让他们付钱
注意他们正在达成的协议，对吧？
答：正确。
MURRAY 女士：法官大人，反对。侧边栏。
（下一页继续）

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（在侧边栏上） 
MURRAY 女士：法官大人，法院此前曾裁定
你无法透露决定的细节
投资中的人。现在转向疏忽了
这种质疑是偏见，无关紧要。
我认为，这超出了界限 —— 还有那个论点
这与投资相关的疏忽大意
目击者作证。
KAMARAJU 先生：我根本不打算争论
疏忽。决心，第一，它取决于实质性，
政府必须证明这一点。二，法官大人还说
作为重要性的一部分，我们被允许调查
潜在投资者特殊性的复杂性
这些交易可能会使它成为一个合理的投资者。
我不是在争辩他应该这样做或者他 
应该那样做。我只是说那一部分 
实质性决定了你所关注的表现形式。  
而你的Honor已经具备了精致感 
明确表示这是公平的游戏。 
MURRAY 女士：法官大人，这些问题不成问题
对他作为投资者来说太老练了；这是对受害者的指责，
问他在真实生活中是否为客户提供过建议
房地产交易以及这些客户是否是高端客户
个人。我不明白这与这有什么关系
个人对投资机会的理解

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是他投资他们的动机。
法庭：所以有人问他是否提供建议
客户到——
KAMARAJU 先生：注意。
法庭：— 注意细节。
SHROFF 女士：阅读销售合同。
芬克尔先生：那不合适。
这是一起欺诈案件。没有依赖防御。  
你不能对欺诈的受害者说，你应该读完所有内容 
这些细节，先生。这是通过另一个人指责受害者 
换句话说，他们使用的是 “实质性”。而且陪审团将 
得出错误的结论。这是一个 403 的问题。 
KAMARAJU 先生：法官大人会指示
陪审团决定罪行的内容。我敢肯定
政府将询问该指示。依赖不是
相关的。我不确定我明白了——
法庭：嗯，我想你想明白
他说我建议我的客户运用良好的判断力，而且
这意味着他没有听从自己的建议。
KAMARAJU 先生：不，法官大人。我最终会变成什么样子
要去设置的程度是他没看过文件
进行这些投资时，是因为
这些文件中的信息对他来说并不重要，
直接与政府的指控相提并论
这些文件中的具体建议是实质性的。它

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对他来说，农场借款项目中有什么都不重要
签订农场借款项目协议。那怎么可能
材料？
法庭：他真的讨论过的细节吗
协议？
KAMARAJU 先生：他还告诉联邦调查局他没有
阅读它们。
法庭：但是他今天就具体情况作证
协议。所以我想你没法争辩说他是这么说的
他根本不依赖这些协议。
KAMARAJU 先生：我可以就此弹劾他，
法官大人。
法庭：嗯，我的意思是你不能说他没有
作证说要审查协议。
KAMARAJU 先生：不，不，不。你说得对，法官大人。
我的意思是我可以弹劾那份证词
暗示他没读那些。
法庭：你可以就此向他提出质疑。我是什么
说的是你不能暗示他今天没有说过他
阅读协议。
KAMARAJU 先生：不，绝对是，法官大人。我不是
打算——
法院：所以我将支持反对意见
这一点是因为我确实认为你要走那条路
对受害者的指责。

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KAMARAJU 先生：好的，法官大人。
芬克尔先生：谢谢。
（在公开法庭上） 
法院：持续。
作者：KAMARAJU 先生：  
问：现在，你直接作证说你感兴趣
投资GTV；对吗？
答：是的。
问：而且你明白 GTV 的目的是成为
社交媒体平台，对吧？
答：是的。
问：而且是为了播出批评的材料
中国政府，对吧？
答：是的。
问：所以这是该运动的目标之一，是
建立这样的社交媒体网络，对吧？
答：是的，可供所有人使用。
问：对。而新中国联邦委员会实际上是 —— 公众
NFSC的宣布实际上是在两天之后
GTV私募已关闭；对吗？
答：是的。
问：现在，你作证说你希望从中获利
GTV，对吧？
答：对不起？
问：你作证说你希望在GTV上获利；

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正确？
答：是的。
问：但是你知道这是一项冒险的生意，对吧？
答：是的。Miles更多地提到了这一点，投资有风险。
问：郭先生说投资有风险，对吧？
答：他还做了保证。
问：好吧，我问你他是不是这么说的 —
MURRAY 女士：反对，法官大人。
法院：持续。
继续提问。 
问：现在，你作证说郭先生告诉了那些想这样做的人
投资少于100,000美元，他们必须联系
Sara Wei，对吧？
答：当时，是的。
问：当时。你这样说是什么意思？
答：因为他在第一个公告中提到了谁喜欢
投资，他没有提过。
问：好吧。于是有时候郭先生说：“如果你们
想投资不到10万美元，你应该去找魏女士，
对吧？
答：他没有提到 10 万，更少 10 万个。他提到
其他没有那么多钱的人可以联系其他农场
领导者可以投资。他不会让追随者掉队。
问：他不希望追随者被抛在后面，对吧？
答：是的。

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问：好吧。所以你的证词是他没有提到10万美元，他
刚才说过小额投资会流向你的农场领导人；是吗
对吧？
答：不是。他提到 100,000 是两个等级；肯定是 100,000
人数有限。这是 2,000 人数。
问：好吧。所以用你的话说，有 2,000 人数，
对于那些想投资 100,000 美元或更多的人来说，对吧？
答：这是最低限度。
问：对。所以 100,000 美元或更多，对吧？
答：正确。
问：然后，如果你想投资不到10万美元，他
叫你去和农场里的人说话；对吗？
答：是的。
问：好吧。那是唯一的分界线，对吧，确实如此
超过 100,000 美元或低于 100,000 美元，对吧？
答：是的。
问：而且你亲自决定要减少投资
超过 100,000 美元，对吧？
答：没决定，只是我当时没有 100,000 美元。
问：好吧。足够公平。你没有 100,000 美元，所以你
最终减少了投资，对吧？
答：正确。
问：好吧。现在，你直接作证说你看了
是郭先生在 2020 年 4 月 21 日播出的，对吧？
答：4月20日。

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问：这是宣布GTV私有化的那个
放置；对吗？
答：是的。
问：好吧。然后你看了，对吧？
答：是的。
问：好吧。你看了整件事吗？
答：是的。
KAMARAJU 先生：我们可以举出政府展览 GX 吗
C-26-T 然后转到第 1 页。
问：检察官，当他们问你这个问题时，他们只是
给你看了一段来自——
法庭：请稍等片刻。看来是其中之一
我们的12号陪审员屏幕上没有画面。
KAMARAJU 先生：我认为这可能是个问题
一个屏幕，你的法官大人。
法庭：你能看看 11 号陪审员的屏幕吗？
12 号陪审员，你能看看 11 号陪审员吗
屏幕？
好吧。请继续。 
KAMARAJU 先生：也许我们可以炸掉这段话
太棒了。谢谢。这样更好吗？好吧。
作者：KAMARAJU 先生：  
问：现在，检察官直接向你询问了一个片段
来自这个广播；对吗？
答：是的。

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问：他们没有给你看整个广播来作证，
对吧？
答：正确。
问：所以你可以在这里看到它在说：“这段视频只是一个简短的视频
简介。”你看见了吗？
答：是的，我看到了英文文本。
问：请问你能读一下突出显示的部分吗？
答：“这段视频只是对朋友的简要介绍，
那些打算投资GTV的战士们
你可以理解投资中要签署的文件
以及投资期间，还有一些基本程序。”
KAMARAJU 先生：好吧。请问我们能转到第 5 页吗。
问：你看到这里突出显示的部分了吗？
答：是的。
问：请你读一读吗。
答：“在收到此视频后 24 小时内，您将
从律师事务所收到以下有关以下内容的文件
所谓的GTV私募股权。”
KAMARAJU 先生：好吧。我们能不能转到第 2 页。
问：你看到这里的重点部分了吗？
答：是的。
问：请你读一读吗。
答：“请仔细阅读所有待处理的文件
签署了投资协议。”
问：好吧。

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KAMARAJU 先生：请问我们能不能转到第 16 页。
问：你能读一下重点部分吗。
答：“我只想做一个简短的解释，但我会的
再强调一遍：请务必阅读
招股说明书、认购信、股东协议和
发送给您的保密协议。那些会
占上风。”
问：好吧。因此，在4月20日期间反复出现这种情况
广播中，郭先生敦促听众阅读文件；
正确？
MURRAY 女士：法官大人，和我们提出的反对意见一样
在侧边栏上。
法院：反对意见成立。
继续前进。 
问：你知道他说 “招股说明书” 是什么意思吗？
答：他在那个广播中说的不是英语；他的原文
文字是用中文写的。
KAMARAJU 先生：我想我们可以把它记下来。我们有
旁边是中国人。这很有帮助。
法官大人，对不起，我们能不能有 20 秒钟 
侧边栏？ 
法院：是的。
（下一页继续）

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O5SVGUO4 周乐-十字架
（在侧边栏上） 
KAMARAJU 先生：就在我继续之前，我只想
确保我明白。难道我不能问他是不是吗
阅读招股说明书？
法院：我想先听听法院的反对意见
起诉。
KAMARAJU 先生：好吧。
MURRAY 女士：这个问题并不令人反感。但是
Kamaraju 先生一直在问的问题又出现了
有点像是指责受害者，批评得很具体
以这种方式详细说明这名受害者做了什么或没做什么
有偏见，意在混淆视听
这个受害者。如果他想问他有没有看过招股说明书，他
可以问他有没有看过招股说明书。
KAMARAJU 先生：我得到的只是郭先生
引导投资者查看有信息的招股说明书
围绕政府所依赖的陈述
上。我希望能够问他是否阅读了招股说明书。
如果他没有，他就没有。整条线就是这样
以前的询问是我给他看各个部分的时候，是
郭先生指引他们去看文件。
法庭：所以这不是 “你不认为应该吗”
我已经这样做了，” 你不会跟进的。
KAMARAJU 先生：我本来不打算问他 “不应该
你已经读过了，” 没有。

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法庭：你就是这么做的。仅此而已。然后你是
那一行提问完了吗？
KAMARAJU 先生：我的意思是，如果他说 “是”，他就会读懂，
然后我要给他看文件，我要问一下
有关该文档的具体陈述。
法院：看，这就是问题所在。你不能去
那些陈述。
KAMARAJU 先生：实际上，法官大人，法官大人掌权
在 Weaver 案的动作中，我们是
允许在 PPM 中显示不同的表示形式
实质性。
政府明确辩称它只用于 
依赖。他们引用了韦弗的话。实际上，韦弗说 
免责声明与实质性概念有关。所以如果你 
阅读免责声明，然后我就可以引出它们了。  
否则，除了通过 a 之外，我不知道该怎么做 
阅读文件的证人。 
MURRAY 女士：法官大人，那些陈述是
制作的不仅包含在文件中。有
广播，他还发表了其他声明。所以对于
他们想调查的程度并找出是什么原因造成的
见证人投资或者是什么促使他投资，他们可以问
这个问题不把它与语言联系起来
招股说明书然后去问这个问题。
那么关于具体问题，他读了吗

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招股说明书，我们不反对这个问题。但这是 
20 个问题导致了这个问题，然后是那些问题 
会紧随其后。 
法庭：如果他回答 “是”，那么问题会怎样
你觉得合适吗？
MURRAY 女士：我想这将是关于以下方面的问题
重要性 —— 我相信这就是卡马拉朱先生的所在
顺便说一句，郭对他做出的保证的实质性
将亲自担保任何损失。
如果问题是，以下是所说的 
在招股说明书中。郭的说法是他会吗 
亲自担保你的钱，那些对你来说无关紧要吗 
之所以决定投资，是因为它未在招股说明书中列出 
不管在哪里，我都不这么认为—— 
KAMARAJU 先生：嗯，首先，我要指出
起诉书称，虚假陈述涉及
证券欺诈罪和与之相关的电汇欺诈罪
GTV将成为招股说明书中的声明。所以他的想法是
在其他地方发表了影响这一点的声明，没关系。
他们可以争辩说。但是没有一个宇宙可以容纳
招股说明书陈述不相关，信息也无关紧要
围绕这些陈述无关紧要，除非
他们正在减少计数，但我认为事实并非如此。
MURRAY 女士：法官大人，这不是唯一的受害者
谁投资了GTV产品。很明显那是什么

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他们想要做的是回到复杂的状态。还有一个
你的法官已经裁决的话题不成问题
这个。再说一遍，如果他们想问——
法院：如果你依赖陈述
在起诉书中，问这个问题怎么不恰当
中提到的有关这些陈述的证人
起诉书？
MURRAY 女士：嗯，我想我们首先要建立
他是否阅读了招股说明书。
KAMARAJU 先生：当然。我要去做。
法院：是的。但是如果他回答 “是”，那就在这里
我在问。
MURRAY 女士：如果他回答 “是”，那么问是公平的
关于招股说明书中某些措辞的问题以及
确定他当时是否读过。但是我们是什么
担心的是那时走的坡度有点滑
转变为复杂和指责受害者。
法庭：嗯，你读过吗？假设他说
是的。那么下一个问题是：你考虑过风险吗
那是在招股说明书中规定的？
芬克尔先生：法官阁下可能想要的一种方式
与之抗衡，而且我知道这是在其他欺诈中发生的
案例，是通过限制指令，这很简单
告诉陪审团无论证人还是受害者是
无论是否复杂，都意识到自己避免的风险或

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是否依赖各种免责声明不是有争议的
这里。提问的目的仅为
评估证人的陈述是否
在这里就有关担保的陈述作证
以及GT资金的使用，无论这些资金是实质性的。我有
在其他欺诈案件中也是如此。
法庭：好吧。我们要停顿一下，而我
想让你起草这份指令。
KAMARAJU 先生：法官大人，我要注意的是，
他刚才所说的一切都是陪审团的恰当议题
指令，不是中间的限制性指令
证词。
法院：我不知道我是否同意。
KAMARAJU 先生：嗯，法官大人，我不确定 —— 首先
总而言之，法官大人确实说过我们可以收购
投资者的复杂性，因为它涉及
实质性分析。所以我只想确保我们
对此很清楚。
我知道我们不能争辩说受害者是谁 
是疏忽大意或者他们应该做得更多。我们不是 
不得争辩或征求证词证明这些是 
老练的人。那是黑字第二巡回法院法。  
利特瓦克就是这样。利特瓦克案表明了复杂性 
投资者参与其中。 
芬克尔先生：那是一起民事案件。

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KAMARAJU 先生：不，这是美国诉利特瓦克案。
所以我不知道 —— 因为你必须判断合理 
以市场上的投资者为投资者设定标准。  
法律就是这样。所以这是一点。 
二，我不知道你是怎么逃避决定的
以外的任何个人陈述的实质性
较大文档的上下文。没有原则
支持这一点的法律。如果一个人说他读过 —— 不是这个
证人，但总的来说。如果一个人说他们读了文件
还有文件 —— 文件中有一部分说我们就是这样的
可能会用这笔钱，文件的另一部分说
这些只是我们如何使用这笔钱的例子，它用于
重要性分析，法官大人。
芬克尔先生：法官大人，Weaver 案子，我们
简要介绍了法官大人的裁决直接解决了这个问题。
而且它阻止了辩护律师提出这种说法
证词。  
如果我没记错的话，在 Weaver 中发生的事情是 
本质上是被告，即欺诈者，是这样说的 
受害者，你会赚到数百万美元，仅此而已 
之类的东西，对吧。然后他们会收到以下文件 
会说些大意是，什么都别听 
我刚才说过。免责声明。   
因此，辩方想发表免责声明 
比如说，你看，你应该看看那个免责声明，受害者。

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受害者，你应该知道自己不应该听 
告诉那个人，即被告，他说了什么。   
第二巡回法院说你不能那样做。你为什么不能 
那样做？因为犯罪背景下的欺诈，没有 
对它的依赖。有一个客观合理的标准 
陪审团将进行评估。但是你不能 —— 辩护律师是 
问关于 —— 这一切都是因为它们是 
问一些问题，你是一个优秀的房地产经纪人吗？做 
你向客户介绍合同中的具体细节？  
你在看东西吗？   
这取决于他们是否在评估 
免责声明。这不是问题所在。问题在于郭是否 
这些广播中的言论是谎言, 
基于这些谎言，它们对受害者来说是物质的，所以 
他们给郭汇了钱，他们做到了。 
法院：招股说明书怎么说？
芬克尔先生：招股说明书说了很多话。
我认为辩护律师指的是其中一件事
就起诉书而言，这笔钱将如何使用。  
例如，招股说明书没有说这笔钱 
将以郭先生儿子的名义被派往一家对冲基金。它 
说这笔钱基本上将用于投资GTV。  
招股说明书中没有保证，我认为是 
就像辩护律师在说什么，这正是正确的 
用 Weaver 手机壳全是四分之一。因为在 Weaver 的案例中

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再一次，被告说的是受害者所依赖的话， 
也是受害者投资的原因，然后是后来 
有免责声明。所以是第二巡回法庭 —— 对不起，你的 
荣誉。 
法院：但是这些文件是否包含
免责声明？
芬克尔先生：招股说明书？
法院：是的。
芬克尔先生：我相信里面有一些免责声明
那份文件，是的，法官大人。
法庭：比如什么？
KAMARAJU 先生：比如我给你举个例子。有
他们在起诉书中依据的图表
也就是说，这些是收益的预期用途。然后
有语言说这个清单是说明性的，对吧，
这意味着这是例子，对吧。我可以说出来
转为实质性。  
我只想就韦弗案说一句话，你的 
荣誉。恭敬地说，你已经解决了这个问题而且你已经 
已经注意到政府对韦弗的描述是 
完全是错误的。因为他们在 Weaver 中所说的就是这样 
虽然没有依赖要素而且国防也无法做到 
信赖论点，他们可以指出这些免责声明 
重要性分析的目的，法官大人 
已经找到了。所以我不知道我们为什么要重温

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Weaver 中的上下文。 
芬克尔先生：这也是避免任何原因的原因
陪审员可能会感到困惑，限制性指示是
适当的。然后我们将为法院起草一份文件
考虑。
法庭：好吧。所以这就是你要做的。
你要起草然后我们暂停。
芬克尔先生：谢谢。
（下一页继续）

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（在公开法庭上） 
法庭：陪审团成员，我们将采取行动
短暂的停顿。
请记住，不允许你讨论这个案子 
彼此之间或与其他人一起。不要允许任何人 
在你面前讨论这个案子。   
我会尽快给你回电话。 
（陪审团不在场） 
法院：你可以下台。
不要讨论证词。 
证人：当然，法官大人。
（证人不在场） 
法庭：请坐下。
（休会） 
法庭：请坐下。
这些文件是证据吗？招股说明书， 
其他—— 
KAMARAJU 先生：我不这么认为，法官大人，不是。
法院：他们没有证据。好吧。
因此，在实质性问题上，当然是 
无论证人是否阅读了文件。但是 
你不能去的地方会遇到一个问题，比如：你不应该这样做 
我注意到了警告。 
KAMARAJU 先生：明白了，法官大人。我没打算
可以问任何这样的问题。

321
          南区记者，P.C.
            (212) 805-0300
O5SVGUO4 周乐-十字架
法院：拟议的指令是：什么时候
考虑到证人的证词，请注意这种疏忽，
受害者的粗心大意或轻率不是
对欺诈指控进行辩护。
KAMARAJU 先生：对不起，法官大人。我应该有
注意到了这一点。如果你要用 “受害者” 这个词，我们
至少会要求你使用 “所谓的受害者” 这个词。
法庭：我甚至没有说明自己是否要去
使用该指令。
KAMARAJU 先生：不，我知道，法官大人，我很抱歉
用于跳入。我只是 —— 当我听见你再读一遍的时候，它
我想到我错过了那个。
法庭：显然，如果我要读指令，
我会用 “证人” 而不是 “受害者”。
但是为什么现在需要下这样的指令 
而不是我最后指示陪审团的时候 
案例？ 
芬克尔先生：法官大人，这是正确的陈述
法律，它免除了陪审团的任何混乱。而且我觉得
陪审团理所当然会感到困惑。他们可能在想，
我本来不会投资这个。我本来会知道的
没有任何意义。我本来知道能读的
免责声明并查看所有语言。那就是什么
不了解我们所有人一样了解欺诈法的外行人
会期望的。

322
          南区记者，P.C.
            (212) 805-0300
O5SVGUO4 周乐-十字架
所以这个指令，这是正确的陈述 
法律，解决了这个问题，我认为是恰当的 
为辩护律师的询问线索提供背景信息 
高级。 
KAMARAJU 先生：嗯，法官大人——
芬克尔先生：这也是一场漫长的审判。
KAMARAJU 先生：嗯，这是一场漫长的审判。  
因此，法官大人将指示陪审团他们 
应在所有证据结束后开始审议。  
我想你会指示他们正确行事 
法律的要素。   
因此，当他们考虑这个证人的证人时 
证词，只要有其他人，他们就会有 
适当的法律来指导他们。无需预览 
政府现在就法律问题向陪审团争论什么时候 
不是问题，例如，证据是否存在 
为此目的或此目的而提供。它最终会消失 
到罪行的要素。而且你的法官可以解决这个问题 
当你讨论所有其他要素时 
违法行为，即你在法律方面指示陪审团 
证据的结束。 
芬克尔先生：这正是这样的问题
正在为特定目的提供证据。是存在的
以实质性为目的而提供。而且陪审团没有
知道这一切意味着什么。

323
          南区记者，P.C.
            (212) 805-0300
O5SVGUO4 周乐-十字架
所以你的法官正在做的是向他们交付 
正确的法律陈述，这样他们就可以将证据理解为 
他们坐视审判。据我所知，回头看 
关于这个问题的简报，辩护律师没有反对 
一般是指疏忽不是辩护的概念.而且 
所以我们认为法官大人指示陪审团这件事是 
恰当这样他们才能明白如何使用证据 
辩护律师正在设法推断。 
法院：所以我同意卡马拉朱先生的看法
此时不适合下指示。
但是我想谈谈你能问什么和不能问什么。   
你可以问他是否读过那些文件。如果 
你得到 “不”，到此为止。调查到此为止。  
没有 “你不应该有”。 
KAMARAJU 先生：百分之百，法官大人。我没有
打算 —— 如果他拒绝，我就不会再问他了
对文件有疑问或者他应该读过或者
他不应该读吗。
法庭：现在，如果他说是，那么你可以问：
你考虑过那些文件中的陈述吗？但是
你不能继续然后说：嗯，你不应该注意吗
那个警告。
KAMARAJU 先生：我没打算 —— 还有问题
法官大人正在制定，比如 “你不应该这样做”，我
我没打算 —— 那不是 —— 我想我没问过

324
          南区记者，P.C.
            (212) 805-0300
O5SVGUO4 周乐-十字架
其中一个问题，但这不是我的意图。
法院：“一个有理智的人难道不会有吗，”
“你不会建议你的客户这样做吗” 之类的。
KAMARAJU 先生：好的，法官大人。
芬克尔先生：法官大人，如果可以的话。而且我明白
法院的裁决。问题是，是受害者这么说的吗
他们没有读文件，其含义留待解决
陪审团可能是，嗯，他们应该这样做。那是
不是关于如何做的正确陈述 —— 那不是正确的
关于应如何考虑这些证据的法律声明。
法庭：人们甚至不看说明书
他们的 iPhone。
芬克尔先生：我知道。
法庭：所以我认为普通陪审员会
不一定指望有人会读
招股说明书。
芬克尔先生：所以，法官大人，我们不知道会发生什么
陪审团显然在想。因此，政府的要求是
只要指示陪审团了解法律让他们知道该怎么做
用背景来说明这些证据，仅此而已。
法院：我认为关于这个问题的指示是分开的
法律方面，这种特殊的辩护或缺乏
辩护，正在提请注意或支持以下论点
政府没有真正澄清。
因此，让我们把证人带回来，让陪审员回来。

325
          南区记者，P.C.
            (212) 805-0300
O5SVGUO4 周乐-十字架
KAMARAJU 先生：法官大人，对不起，我能不能不要
最后一次验证？
法院：是的。
KAMARAJU 先生：如果他说 “是” 然后我问他，你有没有
考虑一下招股说明书中的陈述，我可以指出吗
他对招股说明书中的特定陈述有何看法？
法院：是的。
KAMARAJU 先生：好吧。谢谢你，法官大人。
法庭：就他说他读过这些内容而言，
你可以向他指出那些特别的陈述。
KAMARAJU 先生：好吧。所以我——
法庭：你可能会问你是否考虑过它们。
KAMARAJU 先生：我可以发表声明然后说：“确实如此
你读过这个吗？
法院：是的。
KAMARAJU 先生：如果他说是，我可以说，你吗
考虑一下吗？如果他说不，那就继续吧。
法院：对。但如果他说，我没看过
招股说明书，那你就提不出那些——
KAMARAJU 先生：明白了。
法院：是的。
还有什么要说的吗，芬克尔先生？ 
芬克尔先生：不，法官大人。上升是因为我觉得
陪审团即将入场。
法庭：好吧。

326
          南区记者，P.C.
            (212) 805-0300
O5SVGUO4 周乐-十字架
（陪审团出席） 
法庭：你能让证人回到法庭吗
请站起来。
（证人在场） 
法庭：请记住，先生，你还在地下
誓言。然后请坐下。
而且你可以继续盘问。 
KAMARAJU 先生：谢谢你，法官大人。
作者：KAMARAJU 先生：  
问：先生，我想我们分手的时候，我们正在讨论一份文件
叫招股说明书。你还记得吗？
答：哪份文件？对不起。
问：我想我们把它称为招股说明书。你呢
还记得吗？
答：是的。
问：在向VOG汇款之前，你看过招股说明书吗？
答：我从来没有收到。
问：所以你从未收到招股说明书的副本。好吧。
谢谢。
现在，你直接作证了——好吧，对不起。
KAMARAJU 先生：我们能不能拉出政府展览 GX
C-63-T，拜托；2020 年 6 月 2 日视频翻译。
请问我们能不能转到第 9 页。 
问：我相信你已经就其中的某些部分作证了。
KAMARAJU 先生：但是如果我们能炸掉那个箱子

327
          南区记者，P.C.
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O5SVGUO4 周乐-十字架
对，开头是 “我们的初始估值为2亿美元。”
答：是的，我明白了。
问：看见了吗？好吧。
然后你就会明白它在哪里说：“私募股权 
超出了最高预期，筹集了3.5亿美元”； 
正确？ 
答：是的。
问：因此，实际上，私募筹集的资金超过
最初是被追捕的，对吧？
答：是的，那是 VOG 的一部分。
问：嗯，你作证的VOG钱是分开的，对吧？
答：不，是其中的一部分。私募配售。
问：所以所提到的3.5亿美元，这是其中的一部分
of —— VOG 是其中的一部分？
答：不是。
问：好吧。它是分开的，对吧？
答：是的。
KAMARAJU 先生：好吧。如果我们能继续下去——
在那个盒子里再往下走一点。不，对不起。如果你
可以 —— 开头的句子：到目前为止这个
想办法再说一遍，是的。谢谢。非常感谢。
问：好吧。所以你看到它说：比方说 3.5 亿。350
百万不包括来自VOG的1.17亿，对吧？参见
那个？
答：350 不包括 117，没错。

328
          南区记者，P.C.
            (212) 805-0300
O5SVGUO4 周乐-十字架
问：对。通过 VOG 流入的 1.17 亿美元是
与作为其中一部分筹集的3.5亿美元分开
私募股权，对吧？
答：不，它与私募不是分开的；确实如此
包含在私募中。这只是单独的基金，
350。
问：好吧，你直接作证说有一定的
座位数，对吧？
答：是的。
问：有 2,000 个座位，对吧？
答：是的，这是迈尔斯之前提到的。
问：好吧，我想问你的理解是什么，先生。
答：当我把它介绍给我们的时候，郭文
提到了私募和公共配售，
差异，然后他解释了。
私募配售，如果有限制的话 
座位，2,000 个座位。那么如果它超过了这个限制，那么 
位置会有所不同。 
问：好吧。因此，私募股本可以有2,000个席位。
我能问你吗，当你说 “座位” 时，你会怎么做 
意思？ 
答：他的原话翻译成英文，叫做长椅
owe 椅子 (ph)。
问：嗯，先生，对不起，我不是在要求翻译。
我只是想问你对 “座位” 这个词的理解是什么

329
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O5SVGUO4 周乐-十字架
当你使用它时。
答：我的理解称为多头头寸。
问：你的理解是多头头寸吗？
答：是的。
问：对不起，我对此不熟悉。那是什么意思
意思？
答：这是投资的财务期限。之前的人
私人投资，这些是人们会投资和持有
他们在某些时期内的库存。
问：好吧。因此，座位是买入并持有股票的人
在一段时间内？
答：是的。而且它们也被认为是第一个
投资，投资者。
问：好吧。所以他们是第一批投资者，对吧？
答：正确。
问：那是 — 有 2,000 个座位可用
私募配售；对吗？
答：正确。
问：然后又有一组钱进来了
与 VOG 有关，对吧？
答：单独的资金，即 VOG，是给人民的
低于一定金额的投资。
问：对不起，先生，但那不是我的问题，对吧。我的
问题是，通过 VOG 赚的钱是分开的吗
从你所说的钱中流出来的

330
          南区记者，P.C.
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O5SVGUO4 周乐-十字架
座位，对吧？
答：我不知道。
问：好吧。但是你通过 VOG 进行了投资，那是你的
明白，对吧？
答：正确。
问：而且你作证说你从那里得到了电报信息
Sara Wei；对吗？
答：没错。
问：但是你从来没有和莎拉·魏直接通信，对吧？
答：我给她发了消息；她回答。
问：有电报信息吗？
答：是的。电子邮件也是如此。
问：现在，我们谈到了你是如何与检察官会面的
之前，对吧？
答：是的。
问：你还记得告诉检察官你从来没有告诉过吗
与魏女士直接沟通？
答：我告诉他们我联系了 Sara Wei，是的。
问：对不起。
答：我告诉他们我直接联系了 Sara Wei。
问：好吧。所以在那段时间有人在做笔记
面试，对吧？
答：我没做笔记。
问：我说有人在做笔记，对吧？
答：我没看见谁在做笔记。

331
          南区记者，P.C.
            (212) 805-0300
O5SVGUO4 周乐-十字架
问：我不是在问你有没有看见谁，我是在问你看见了吗
有人在做笔记吗，先生？
答：我不知道。
KAMARAJU 先生：好吧。我们能提起政府吗
请提供展品 GX VO-80。我相信这是明证。所以
我们可以发布它。我们能不能先把它炸掉
段落。
问：好吧。你看见那里有名字了吗，魏丽红
拉弗伦兹？它在向下第四行。  
KAMARAJU 先生：开始吧。谢谢你，先生。  
问：你看见了吗？
答：是的。
问：那是 Sara Wei，对吧？
答：那是她的法定名字，对吧。
问：你认识这个吗？这是有限目的机构
你和魏女士签订的协议；对吗？
答：是的。
问：好吧。这与你的GTV投资有关吗？
答：正确。
KAMARAJU 先生：好吧。政府提供 GX —— 我是
对不起，政府。对不起，法官大人。
辩方 —— 已经是漫长的下午了。   
辩方提供了 GX VO-80 作为证据。 
法院：没有异议？
MURRAY 女士：没人反对。

332
          南区记者，P.C.
            (212) 805-0300
O5SVGUO4 周乐-十字架
法院：可以接受。
（收到的政府展品 VO-80 作为证据） 
KAMARAJU 先生：很抱歉。
作者：KAMARAJU 先生：  
问：所以澄清一下，突出显示的名字，那就是
Sara Wei；对吗？
答：正确。
问：通过这份协议，你指定魏女士为
你的代理人是为了购买GTV股票；对吗？
答：正确。
问：你不是为了这些目的指定郭先生，对吧？
答：不是。
问：你没有任何合同指定任何权限
郭先生超额购买了你的商品，对吧？
答：不在他身边，不是。
问：我只是在问他的情况。不在他身边，对吧？
答：不在他身边。
问：你和郭先生没有农场借款项目协议，对吧？
答：不是。
问：你和郭先生没有 G Clubs 协议，对吧？
答：我从未收到 G|CLUBS 协议。
问：好吧。那你就没在他身上了，对吧？
答：不是。
问：你没有与郭先生签订购买H币的协议，
对吧？

333
          南区记者，P.C.
            (212) 805-0300
O5SVGUO4 周乐-十字架
答：不是。
问：好吧。而且，实际上，你从来没有直接和郭先生说过话
关于购买H币，对吧？
答：不是。
问：你从来没有直接和郭先生谈过收购 G Clubs 的问题，
对吧？
答：不是。
问：你从来没有直接和郭先生谈过购买 GTV 的问题
股票，对吧？
答：不是。
问：现在，有时候出现了分歧
在郭先生和魏女士之间；对吗？
答：我不确定这是否是分歧，可以说是分歧
准确。
问：你知道他们有点失控了，对吧？
答：是的。
问：郭先生对魏女士发表了公开声明；对吗？
答：是的。
问：他鼓励支持者就以下问题联系执法部门
魏女士，对吧？
MURRAY 女士：反对，法官大人。传闻。
法庭：如果你愿意加紧努力。
（下一页继续）

334
          南区记者，P.C.
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O5SVGUO4 周乐-十字架
（在侧边栏上） 
法院：那为什么这些陈述可以
进来吗？
KAMARAJU 先生：嗯，我不是在为他们提供它们
说实话，我之所以提供它们，是因为他说了这些话
而且他正在邀请执法部门进行审查这一事实
还有公法文件，这与想法不一致
他当时有犯罪意图。如果他想这么做
隐瞒他在做什么，他不会叫别人带来
联邦调查局进来了他们不是为自己的真理而接受的；
他们之所以被邀请是因为他邀请他们
要发生。
法庭：他对魏女士说了什么？
KAMARAJU 先生：他说了很多关于
魏女士。但我在 3500 的材料中看到的是他问的
支持者可以联系包括联邦调查局在内的执法部门
魏女士做了什么。
法庭：他声称她做了什么。
KAMARAJU 先生：从农场借款项目中偷来的钱
程序。
MURRAY 女士：法官大人，欢迎被告来到
为此作证。我们不能 —— 只是不允许
通过这种方式在被告的陈述中进行后门
关于魏女士，他可能对别人说过什么，也可能没说过什么。
KAMARAJU 先生：必须将其提供给真相

335
          南区记者，P.C.
            (212) 805-0300
O5SVGUO4 周乐-十字架
成为传闻。这是基础。我们提供的不是为了
真相。
法庭：如果先生 —— 如果是证人，那会怎么样
知道这个声明是发表的，它与他的关系如何
证词？
KAMARAJU 先生：嗯，他作证说这样一个事实
钱花了 —— 他把钱交给了 Sara Wei 这样 Sara
魏将代表他进行GTV投资。他只是
作证说他与魏女士签订了代理协议来做这件事
为了他。
郭先生和其他许多人认为 Sara Wei — 
据我们了解，谁将成为这方面的见证人 
审判—偷了钱。我的意思很简单，那就是如果 
参与欺诈或被指控参与的人 
在骗局里说：“嘿，联邦调查局，来看看我在干什么，那个 
法官大人，暗示他们没有良心。  
还有他们中的大部分—— 
法庭：我不明白为什么是这个证人
必须作证说听过那句话。
KAMARAJU 先生：因为他告诉了检察官
是，法官大人。好像我不是在计划——
法庭：但是目的是什么 —— 怎么样
相关的？他对声明采取了行动吗？
KAMARAJU 先生：他确实根据这份声明采取了行动。
法院：怎么样？

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KAMARAJU 先生：他向多家当地人提出了申诉
执法机构。
法院：以及它与否有何关系
你的委托人有罪？
KAMARAJU 先生：无论他是否提起诉讼，我都不是在争论
这很重要。我争论的是郭先生是
让人们看看这里发生的事情才是正确的
与罪恶意识相反。
法院：对。但是你只是想明白
通过这名证人作证。反对意见仍然有效。
KAMARAJU 先生：法官大人，我能问一下依据吗？
是相关性还是传闻？
法庭：毫无疑问，这是传闻。
KAMARAJU 先生：我不是故意要和法院争论。
我只想了解它是如何提供的，以了解真相。
法庭：你想让陈述进来出示
你的客户与魏女士有不利关系。
KAMARAJU 先生：不。我想把声明写进去
以表明我的委托人不怕联邦调查局在看什么
他在做。
SHROFF 女士：这是一种心态。
法庭：正在调查她的所作所为。
KAMARAJU 先生：不。因为他们的指控是
魏女士是GTV阴谋的重要组成部分。
法庭：好吧。所以我不知道那是什么 —— 我不知道

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知道她的角色是什么。
MURRAY 女士：所以魏女士经营了一家公司；她是
一位农场领袖。那个特定的农场已经习惯了
汇总未经认证的投资者的资金。所以 Miles Guo 成功了
在违反证券法的情况下，向收入较少的人提供
超过 100,000 美元。然后他说：“你为什么不去找魏女士，然后
她会把你所有的钱汇总起来，看起来像一个
来自郭之音的合法投资高于
阈值。因此，另一种逃避证券的方式
法规。  
我们同意法官大人的看法，这不是见证人 
把 Kamaraju 先生想带进来的东西带进来。 
KAMARAJU 先生：但我还是不明白。
如果他们的指控是魏女士参与其中 
他们以郭先生的名义指控的行为是犯罪行为， 
陈述不是为了说明真相而且 
辩方的论点是，他在阳光下要求成为 
放任这种行为，这是不一致的—— 
法院：但是它为什么会通过这种方式出现
证人？
KAMARAJU 先生：我不确定为什么它不能进来
通过这个证人，法官大人我知道有
其他（难以辨认的）目击者可能希望它来了
通过被告。但我不知道有证据
反对意见说无法通过这个证人提出

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反对其他证人。
SHROFF 女士：或者通过多个证人。那是
不是证据异议。
MURRAY 女士：法官大人，这是我们的观点
就此事作出裁决。我明白 Kamaraju 先生只是
继续提起诉讼。但是我们同意你的裁决
这个。反对意见应得到维持。我们应该继续前进。
法院：我将支持异议。
（下一页继续）

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（在公开法庭上） 
法院：持续。来吧。
作者：KAMARAJU 先生：  
问：现在，先生，你之前曾就喜马拉雅农场作证；
正确？
答：是的。
问：而且这些农场有结构，对吧？
答：是的。
问：农场内部有不同的职位，对吧？
答：正确。
问：所以有一位农场领袖，对吧？
答：是的。
问：然后农场领袖可能会有其他人提供协助
他们；对吗？
答：正确。
问：先生，你在任何农场都有职位吗？
答：我的职位是农场的OBS主播。
问：农场的 OBS 主播。
答：是的。
问：好吧。“OBS” 代表什么？
答：这是一个软件平台的名称。它被使用了 —— 它是开放的
软件，允许您连接计算机和相机，
广播到指定地点，比如 YouTube 将其推送到
它，或者将其推送到其他来源。
问：好吧。然后农场上方是联盟，对吧？

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答：是的。
问：所以所有的农场领导人都是联盟的一员，也就是说
你的理解，对吧？
答：是的。
问：所以他们为农场制定了政策，那是你的吗
理解？
答：是的。
问：然后在它们上方有一个叫做 Iron Blood 的东西
群组；是这样吗？
答：不，不在上面。
问：好吧。对不起。你向我解释一下。我可能有。
错了。
答：铁血组是由郭文贵发起的。曾经有
一开始有三个成员。最终扩展到
更大的群体。所有成员都是由郭文亮选出的。
问：好吧。但是这个团体有一定的权力，对吧？
答：他们有自己的角色。
问：先生，我不是想欺骗你，但你没告诉你吗
铁血组完全有权管理的检察官
农场？
答：不经营农场。
问：好吧。那么他们对这个问题有什么样的权力
农场，先生？
答：Iron Blood 成员将充当上级管理小组
管理农场领导，他们也有指定的

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角色。
问：好吧。因此，他们每个人都可能在其中扮演指定的角色
铁血组，你是这么说的吗？
答：是的。
问：所以铁血组的一名成员被叫做
花木兰，对吧？
答：是的。
问：花木兰不是她的真名，对吧？
答：不是。
问：她的真名是什么？
A. Liya。
问：魏女士曾经是铁血组的成员
观点；对吗？
答：对不起。你的意思是莎拉·薇。
问：是的。
答：我记不起来了。
问：好吧。英国农场的负责人怎么样，他是会员
铁血组的？
答：是的。
问：好吧。现在，你为英国农场所做的不仅仅是这样
直播；对吗？
答：正确。
KAMARAJU 先生：实际上，法官大人，我马上就要去了
转向另一个话题。我只想记下时间
然后看看你的法官是否想继续。

342
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法庭：好吧，如果你要谈另一个话题，
那么现在是停止的合适时机，尽管如此
现在才下午 2 点 40 分
KAMARAJU 先生：我将把这五分钟的功劳归功于我
休息一下，法官大人。
法院：好吧。
所以，陪审团成员，我们将停止工作
今天。你明天会像今天一样准时回来，所以
这样你就能在早上 9:30 穿过这扇门
请记住，不允许你讨论这个案子 
彼此之间或与其他人一起。不要允许任何人 
在你面前进行任何讨论。晚上好。 
（陪审团不在场） 
法庭：先生，你可以走出去。
不要讨论证词。 
证人：是的，法官大人。
（证人不在场） 
法庭：而且你可以坐下。
各方想提出什么吗 
在我们明天早上继续之前？ 
MURRAY 女士：法官大人，我们能简要介绍一下边栏吗？
法院：是的。
MURRAY 女士：谢谢。
（下一页继续）

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O5SVGUO4 周乐-十字架
（在侧边栏上） 
法庭：我忘记提那张纸条了
从备用号码收到--
SHROFF 女士：五个。
法庭：昨天五点，我做了法庭证据 No.
1。它是在下午 12:10 送来的，我星期五在展览上注明了日期，
2024 年 5 月 23 日。
问题出在哪里？ 
MURRAY 女士：是的，法官大人。
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O5SVGUO4 周乐-十字架
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法庭：我没问题。
SHROFF 女士：我们没有异议。
KAMARAJU 先生：是的，没关系，法官大人。
法院：还有什么吗？
MURRAY 女士：我们只要求封住侧边栏的这一部分。
法院：而且是密封的。
MURRAY 女士：谢谢。
SHROFF 女士：法官大人，法院想做吗
和五号陪审员有关系吗？我知道我们之前什么时候分手了
周末，当时的想法是原谅他。
法庭：哦，你说的是 5 号候补球员？
SHROFF 女士：是的，法官大人。
法庭：哦，我不记得我们做过借口的决定
他。我记得不对吗？
KAMARAJU 先生：至少这是我的理解。我
我以为法官大人是 —— 因为我以为我们在讨论过
关于如何在不提醒陪审团其他成员的情况下为他辩解
这就是为什么我们以为你已经把他带回来了
向陪审团举报。我们可能误解了。那是我们的
理解。
法庭：那他还在这里吗？
SHROFF 女士：法官大人，他在这里。
法庭：好吧。我会原谅他的
SHROFF 女士：谢谢你，法官大人。

345
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（在公开法庭上） 
法庭：律师提醒一下，我有
此事之后的诉讼程序，所以你需要清除
桌子。
（陪审员在场） 
法庭：你是五号候补球员。
你可以坐下。 
陪审员：我是候补球员 5.
法庭：鉴于你的日程安排问题，我是
原谅你担任陪审团。谢谢你的意愿
来服务。
陪审员：谢谢你，法官大人。
（陪审员不在场） 
法院：还有什么吗？
芬克尔先生：不是来自政府。
KAMARAJU 先生：不是来自我们，法官大人。
法院：谢谢。
（延期至 2024 年 5 月 29 日上午 9:00）

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考试索引 
考试：页面 
 周乐 
174Direct 作者：Murray 女士。。。。 
280Cross By Kamaraju 先生。。。。 
政府展品 
展品编号已收到 
184 Stip 2、C26、C26-V、C63、C63-V。。。 
185 W1005，W1005-V............. 
193 V2, 13, 15-16, 18-19, 22-23, 25-29, 31,. 
59、67-69、77-78、81-82 和 
84  
202 C-26-V、C-26-T、C-63-V、C-63-T。。。 
234 32, 33, 34, 35.................. 
241 VO-107、VO-108................... 
266 V0107 和 V0108............. 
 STIP-9 201......... 
 W-58 236........... 
 VO-80 332.......... 
 V0105 260.......... 
 V0106 261......... 
 VI-151 220........