Original Court Transcript(原始庭审记录)
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UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
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UNITED STATES OF AMERICA,
v. 23 Cr. 118 (AT)
MILES GUO,
Defendant. Trial
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New York, N.Y.
May 29, 2024
9:00 a.m.
Before:
HON. ANALISA TORRES,
District Judge
-and a Jury-
APPEARANCES
DAMIAN WILLIAMS
United States Attorney for the
Southern District of New York
BY: MICAH F. FERGENSON
RYAN B. FINKEL
JUSTIN HORTON
JULIANA N. MURRAY
Assistant United States Attorneys
SABRINA P. SHROFF
Attorney for Defendant
PRYOR CASHMAN LLP
Attorneys for Defendant
BY: SIDHARDHA KAMARAJU
MATTHEW BARKAN
ALSTON & BIRD LLP
Attorneys for Defendant
BY: E. SCOTT SCHIRICK
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ALSO PRESENT:
Isabel Loftus, Paralegal Specialist, USAO
Michael Gartland, Paralegal Specialist, USAO
Geoffrey Mearns, Paralegal Specialist, USAO
Robert Stout, Special Agent, FBI
Ruben Montilla, Defense Paralegal
Tuo Huang, Interpreter (Mandarin)
Shi Feng, Interpreter (Mandarin)
Yu Mark Tang, Interpreter (Mandarin)
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(Trial resumed; jury not present)
THE COURT: Good morning.
Please make your appearances.
MR. FINKEL: Good morning, your Honor. Ryan Finkel,
Juliana Murray, Micah Fergenson, and Justin Horton for the
government. We're joined at counsel table by Isabel Loftus,
who's a paralegal in our office.
MR. KAMARAJU: Good morning, your Honor. Sid Kamaraju
and Scott Schirick on behalf of Mr. Guo. And Mr. Guo is with
us here at counsel table.
THE COURT: Please be seated.
On May 27th, 2024, the government submitted a motion
to admit certain exhibits consisting of preserved copies of
online posts to G News and Gettr, ECF No. 352.
Defendant filed opposition papers on May 28th, 2024,
ECF 361.
I've also reviewed the underlying documents the
government seeks to admit, relying principally on Anderson v.
United States, 417 U.S. 211 (1974). The government argues that
it is not offering the posts for the truth of the matters
asserted therein; instead, it states that it is offering the
posts "for the fact that they exist, i.e., that they were made
on media websites created and controlled by the defendant."
I agree with the government that this anticipated use
falls outside the definition of hearsay. In Anderson, the
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court determined that a statement was not hearsay because it
was not offered to "prove the truth of anything asserted
therein," but "to prove that the statements were made so as to
establish a foundation for later showing through other
admissible evidence that they were false." Id. at 220.
Further, to the extent that witnesses viewed the posts
at issue, they are admissible as nonhearsay to show their
effect on the viewer. SEC v. AT&T, Inc., 626 F. Supp. 3d 703,
737 (S.D.N.Y. 2022).
Accordingly, I will not exclude the posts on hearsay
grounds.
I also find that under Federal Rules of Evidence 401
and 403, the posts on G News and Gettr, media organizations
that the government alleges were created and controlled by the
defendant, are relevant as proof of the G Enterprise and is
evidence of defendant's scheme to defraud.
Accordingly, the government's motion is granted.
Are there any further applications at this time?
MR. FERGENSON: Not with respect to that, your Honor.
MR. SCHIRICK: No, your Honor.
MR. FINKEL: Your Honor, I just wanted to place
something on the record, if I may.
After reviewing yesterday's transcript and with the
Court's comments to counsel in the robing room in mind, which
the government took very seriously and takes very seriously,
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Ms. Shroff had flagged something for the government yesterday
which I just want to put on the record for the Court.
Yesterday morning, as the Court knows, Ms. Shroff
indicated that she needed more time to review a victim's 3500
material. And I indicated that that victim was originally set
to testify yesterday, but that we would not call her yesterday,
and this would provide the defense with more time to review
that new 3500.
Looking at the transcript, I wasn't clear in that
moment that the decision not to call the victim was made that
morning, just before your Honor took the bench, just before
your Honor called us into the robing room. In any event, the
reordering decision seemed responsive to Ms. Shroff's request
for more time and that's why I raised it.
To the extent I caused any misimpression with your
Honor, with the parties, I certainly apologize for that. I did
not intend to do so. We will continue to work with defense
counsel and continue to take very seriously and follow the
Court's instruction to conduct this trial in an efficient and
responsible manner.
THE COURT: I did not have a negative impression
yesterday morning, and I'm so glad to see that everyone is
working well together.
MR. FINKEL: Me too. Thank you.
MR. FERGENSON: I'm sorry, your Honor.
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THE COURT: Go ahead.
MR. FERGENSON: I had one related point, another quick
point to put on the record.
We've been working very productively with defense
counsel on a handful of stipulations related to Shamel
Medrano's testimony as a summary witness regarding these G News
and Gettr posts and other videos. We have made video clips of
longer videos.
The defense may seek to offer additional portions of
the longer videos under the rule of completeness. We have
agreed that the government may have substantive objections to
those under the hearsay rules, for example, but we're not going
to object under, you know, timeliness or something like that.
So that the defense has additional time to consider what, if
any, other portions they'd like to offer.
And I just wanted to put that on the record so it's
clear the defense has comfort we're not going to object on that
basis at a later date.
THE COURT: I'm glad to hear that.
MR. FERGENSON: Thank you, your Honor.
THE COURT: Is there anything else?
MR. KAMARAJU: Not from us, your Honor.
THE COURT: So I'd like to have the witness back on
the stand by, say, 9:29, so that he is here when the jurors
come in. Thank you.
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O5TVGUO1 Le Zhou - Cross
MR. FINKEL: Thank you.
MR. KAMARAJU: Thank you, your Honor.
(Recess)
THE COURT: Good morning. Please be seated.
Would you have the jurors brought in.
(Jury present)
THE COURT: Good morning, jurors.
THE JURY: Good morning.
THE COURT: Please be seated.
We are going to continue this morning with the
cross-examination of Mr. Zhou.
Remember that you're still under oath.
You may inquire.
MR. KAMARAJU: Thank you, your Honor.
LE ZHOU,
called as a witness by the Government,
having been previously duly sworn, testified as follows:
CROSS-EXAMINATION (continued)
BY MR. KAMARAJU:
Q. Good morning, Mr. Zhou.
A. Good morning.
Q. Yesterday do you recall testifying about certain G Fashion
items that you purchased?
A. Yes.
Q. Okay. And one of them were these pajamas; correct?
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O5TVGUO1 Le Zhou - Cross
A. Correct.
Q. And then there was the whistle, right?
A. Correct.
Q. The shirt?
A. Yes.
Q. And the hat, right?
A. Yes.
Q. Okay. That's not all the items that you purchased from G
Fashion, right?
A. Correct.
Q. You purchased several more than that, right?
A. Correct.
Q. When you met with the prosecutor, you went over the items
that you purchased; correct?
A. Correct.
Q. And you went through pictures of the items; correct?
A. Correct.
Q. And that was of all the items you had purchased, right?
A. No.
Q. No?
A. No.
Q. How many items did you go over with them?
A. About 20 items.
Q. Sorry?
A. Twenty items.
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O5TVGUO1 Le Zhou - Cross
Q. About 20?
A. Correct.
Q. Okay. And when you were going through these 20 items, who
decided on bringing these to court?
A. I decided.
Q. Okay. So you're the one who chose which items were
introduced as these exhibits?
A. Correct.
Q. Okay. Did you discuss that with the prosecutors?
A. Yes.
Q. Okay. Did they give you suggestions as to which items
should be brought in?
A. They mentioned not a particular item, but in the category.
Q. Okay. Like what kind of categories?
A. Hats, shirts, pants, and what I did jewelry.
Q. Sorry, I didn't hear the last part.
A. No, no. Jewelry. Sorry.
Q. Okay. So they didn't ask you to bring in jewelry?
A. No.
Q. You picked the whistle. Do you consider the whistle to be
jewelry?
A. I picked whistles, two whistles, yes.
Q. Okay. So you picked two whistles to show?
A. Yes.
Q. Okay. But they only asked you about one, right?
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O5TVGUO1 Le Zhou - Cross
A. Correct.
Q. So they did make some decisions --
A. No, they kept one.
Q. Okay. But in court they only showed you one, right?
A. Yes.
Q. So they did make some decisions about what to show here in
court, right?
THE COURT: He cannot testify as to what they were
thinking. He can testify as to whether he made the decision.
MR. KAMARAJU: Okay.
Q. You decided that you would bring two whistles to show to
court; correct?
A. Yes.
Q. Okay. And the prosecutors only showed you one here in
court, right?
A. Correct.
Q. Thank you.
Now, the approximately 20 items or so that you
purchased from G Fashion, did you discuss all of them with the
prosecutors?
A. I purchased more than 20 items.
Q. Okay. I'm sorry. Roughly how many items did you purchase?
A. About 30 items.
Q. Thirty items. Okay.
Remember yesterday you testified about the whistle;
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O5TVGUO1 Le Zhou - Cross
correct?
A. Correct.
Q. And that was the gold whistle, right?
A. Correct.
Q. It was a commemorative item of some sort?
A. I'm sorry?
Q. It was a commemorative item of some sort?
A. It was a limited edition, was only 77 made.
Q. Okay. Sorry. Limited edition.
MR. KAMARAJU: Could we bring up just for the witness,
the Court, and the parties GX VO-67, please.
Your Honor, after conferring with the government, it
seems this is in, so I'm going to ask to publish it to the jury
as well.
THE COURT: Go ahead.
Q. All right. So, Mr. Zhou, do you see the date of this
email?
A. Yes.
Q. All right. It's February 28, 2021; is that right?
A. Correct.
Q. All right. And this is when you -- this is the order
confirmation for when you bought the limited edition whistle;
correct?
A. Correct.
Q. Now, you testified, I believe, that when you received the
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whistle, there was something that made you suspicious about it,
right?
A. Correct.
Q. That's why you weighed it, right?
A. I weighed it, yes.
Q. Okay. And you weighed it because you thought there might
be something wrong with it?
A. When I receive it, when I first opened it, the packaging
inside, it was a little bit of gold dust on it. And, of
course, I pick up the whistle. The craftsmanship, it looked to
me a little bit rough. Because this is a limited edition,
that's collectible items, as the G Fashion promoted, this is a
best, best craftsmanship items, so that's why I had concerns.
Q. Okay. So you were dissatisfied with it; is that right?
A. Not dissatisfied. Because still as advertised, this is a
limited edition — only 77 in the world. I understand that
value itself, it's there. But what it is when I receive it,
it's what I received.
THE COURT: Mr. Kamaraju, would you draw the
microphone closer to you, please.
MR. KAMARAJU: Sorry, your Honor. Yes.
Is that better?
THE COURT: Yes.
MR. KAMARAJU: Okay.
Q. And please let me know if you can't hear me.
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O5TVGUO1 Le Zhou - Cross
A. I hear you.
Q. Thank you.
MR. KAMARAJU: Could we show for the witness and the
parties and the Court GX V0-33 -- sorry, VO-33.
Q. Mr. Zhou, do you recognize this document?
A. Yes.
Q. What is it?
A. This is screenshot I capture of the G Fashion website.
Q. Okay. And what does the screenshot reflect?
A. Reflect my previous order and item dates, the amount paid.
Q. Okay. And the amount paid for what?
A. All the item -- most of item purchased. This is not all of
it.
Q. Okay. So this is most of the items you purchased, but from
G Fashion; is that right?
A. Correct.
MR. KAMARAJU: Okay. Your Honor, I'm going to offer
Government Exhibit VO-33 into evidence.
THE COURT: No objection?
MS. MURRAY: No objection.
THE COURT: It is admitted.
(Government's Exhibit VO-33 received in evidence)
MR. KAMARAJU: Could we publish it, please.
Q. All right. So previously we looked at the order
confirmation for the whistle purchase; correct?
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O5TVGUO1 Le Zhou - Cross
A. Correct.
Q. And that was February 28, 2021; correct?
A. Yes.
Q. Okay. So if you look down at the fifth row from the
bottom, so February 12th, 2021; correct?
A. Correct.
Q. Okay. So after that date --
MR. KAMARAJU: And we can pull that down.
Q. After that date, you made a number of purchases of G
Fashion clothing, right?
A. Correct.
Q. And I believe you testified that this doesn't even reflect
all of the G Fashion purchases that you've made, right?
A. Correct.
Q. So despite your concerns about the craftsmanship of the
whistle, you continued to buy G Fashion, right?
A. Yes.
Q. And you continued to spend a significant amount of money on
G Fashion, right?
A. To spend the money also was towards to help the G Fashion
grow. Because my understanding, I'm part of the G Fashion
stock shareholder. I will contribute as much any way I can,
even by purchasing items.
Q. So you were trying to contribute to the growth of G Fashion
by purchasing these items, right?
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O5TVGUO1 Le Zhou - Cross
A. Correct.
Q. And you believe that G Fashion was -- withdrawn.
You believe that the growth of G Fashion was important
to the movement's goals; correct?
A. Because Miles Guo mentioned G Fashion valuation was
tremendous high, also reach billions dollars.
Q. Right. But I asked you if you understood that the growth
of G Fashion was important to the movement, sir?
A. Yes.
Q. Okay. So you were trying to -- in addition to whatever you
just testified to, you were trying to also help the movement by
purchasing G Fashion wear; is that right?
A. That's correct.
Q. Okay. So you continued to buy G Fashion wear, right?
A. Correct.
Q. Now, you had previously -- withdrawn.
Prior to buying a G Clubs membership, you had also
purchased G Fashion, right?
A. Correct.
Q. Now, after you purchased your G Clubs membership, you
started receiving discounts on your G Fashion wear, right?
A. Correct.
Q. How much -- what percentage discount were you receiving?
A. Fifty percent.
Q. Okay. And so each time you bought one of these items you
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got 50 percent off, right?
A. Not every time.
Q. After you bought the G Clubs membership, right, sir?
A. Correct.
Q. So how much in total discounts did you get, sir?
A. If estimated, the discount -- I'm sorry, I couldn't get
accurate discount on the amount of numbers.
Q. Well, how much of a refund did you ask for, sir?
A. Refund from which --
Q. G Fashion.
A. I ask for over $12,000 refund from G Fashions.
Q. Okay. And $12,000 is what you spent after receiving the 50
percent discount?
A. Also includes nondiscount items.
Q. It also includes nondiscounted items?
A. Correct.
Q. Okay. So would it be fair to say that your discount amount
was in the thousands of dollars, sir?
MS. MURRAY: Objection to form.
THE COURT: Overruled. You may answer.
A. Yes.
Q. It was over $10,000, right, sir?
A. Yes.
Q. Okay. So you paid $50,000 for the membership, right?
A. Yes.
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O5TVGUO1 Le Zhou - Cross
Q. And in the course of a year and a half or so, you earned
more than $10,000 in discounts, right?
MS. MURRAY: Objection. Form.
THE COURT: Overruled. You may answer.
A. Yes.
Q. And those were for products that you were also buying
because you wanted to help the movement, right?
MS. MURRAY: Objection.
THE COURT: Overruled. You may answer.
A. Could you repeat the question, please.
Q. Sure.
MR. KAMARAJU: Could we have it read back please?
THE COURT: Go ahead.
(Record read)
A. Not just help, but also towards to -- to help this company
grow and to get the stock value high.
Q. Right. But, sir, didn't you just testify a few minutes ago
that one of the reasons why you were buying G Fashion was to
help the movement?
MS. MURRAY: Objection, your Honor.
THE COURT: Sustained. Asked and answered.
Q. When did you ask for your refund, sir?
A. I couldn't remember the dates.
Q. Was it after you started talking to the prosecutors?
A. No.
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O5TVGUO1 Le Zhou - Cross
Q. So you requested your refund prior to speaking with the
prosecutors, is that your testimony?
A. Yes.
Q. And that's for G Fashion, sir; is that right?
A. Yes.
Q. What about your G Clubs refund, when did you ask for that?
A. I filed it July 15, 2023.
Q. So you remember the date of the -- so the G Clubs refund
was July 15, 2023; is that right?
A. Correct.
Q. Okay. Was the G Fashion refund request made after that?
A. I don't recall that.
Q. So you don't remember if the G Fashion one was before or
after the G Clubs?
MS. MURRAY: Objection.
THE COURT: Asked and answered.
Q. Now, if you look at GX VO-33, there's a line for March 1st,
2021; correct?
A. Correct.
Q. Okay. The first line there. Do you see that?
A. I see the highlighted, yes.
Q. Right. Okay. So that reflects a column for which you
received a refund for an item, right?
A. Yes.
Q. Okay. So at any point if you were dissatisfied with
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O5TVGUO1 Le Zhou - Cross
something, you could request a refund; correct?
A. This particular item was out of stock.
Q. Okay. So you were dissatisfied with -- you didn't receive
the item, so you got a refund, right?
A. It was out of stock. I never received.
Q. I'm sorry, sir, I'm just asking if you received a refund?
A. Was credit to the credit store.
Q. Now, you spoke a minute ago about the G Clubs membership.
And I believe you testified on direct that you paid for both of
those memberships by check, right?
A. Correct.
MR. KAMARAJU: Could we have GX VO-26, please, which
is in evidence. Bring that up for the jury as well.
Q. So these are the checks, right?
A. Correct.
Q. Okay.
MR. KAMARAJU: And if we could scroll to page 10,
please.
Q. All right. Now, this is -- this is your member page, is
that fair to say?
A. Correct.
Q. All right. So it reflects your name with your Tier 5
membership, right?
A. Correct.
Q. And it lists membership benefits there? It's on the left
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O5TVGUO1 Le Zhou - Cross
side.
A. Yes.
Q. Could you just read what it says there?
A. "G Fashion 50 percent off, G Club brochure."
MR. KAMARAJU: Okay. And could we go to page 12 of
that exhibit, please.
Okay. Sorry, this is the check again, right? Okay.
Sorry. This is the right one.
Q. All right. This is the membership page for the Tier 2
membership that you purchased, right?
A. Correct.
Q. Okay. Now, this you purchased on behalf of your sister,
right?
A. No, at the moment was introduced as we purchase; in the
future we can transfer to the family.
Q. Okay. Could you explain that please, sir.
A. Yes. Miles Guo mentioned the G Club, the membership, the
Tier 1 to Tier 5. The follower, we can purchase, but that was
offered the passport. But my sister doesn't have to -- I don't
need to put her name first. I have the right to transfer to my
directed family members.
Q. So if I understand correctly, sir, the idea was that you
could purchase the membership in your name so that eventually
you could transfer it to a family member if you wanted, right?
A. Correct.
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O5TVGUO1 Le Zhou - Cross
Q. Okay. And was that benefit -- in your mind, was that
benefit particularly useful for family members who are located
in China?
A. Only to the direct family members; doesn't matter if in
China or other countries.
Q. Okay. So anywhere, right?
A. Yes.
Q. Now, you filled out a G Clubs membership agreement;
correct?
A. There's no agreement. I never signed it or received.
MR. KAMARAJU: So can we go to page 8, please. Can we
just blow up the -- that email.
A. This is a payment received confirmation emails.
Q. Right. I was just asking if you could read the first line
of the email, sir.
A. Yes.
"Dear Le Zhou, on 2021 August 25 at 0:47:10, you
submitted your completed and executed application to become a
Tier 5 member of G Clubs. We received your membership fee in
the amount of $50,000. Your application is under review and we
may contact you for additional information. We will email you
confirmation of our decision within 30 days."
Q. Okay. So I just want to make sure I understand correctly,
sir. You said you never submitted a G Clubs application; is
that right?
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MS. MURRAY: Objection, your Honor.
THE COURT: Sustained.
MR. KAMARAJU: Okay.
Q. So you received this email without having submitted that
application; is that right?
MS. MURRAY: Objection, your Honor.
THE COURT: Sustained.
MR. KAMARAJU: We can take that down. Thank you.
Q. Now, on direct you testified that Mr. Guo ultimately gave
you the opportunity to purchase H Coin, right?
A. He mention the H Coin would be offered to followers.
Q. Okay. But there is a point at which H Coin could not be
purchased by U.S. residents, right?
A. Correct.
Q. And so I believe you testified on direct that there came a
point where U.S. residents could purchase H Coin; correct?
A. Not a -- well, he said in the future will expand the H
Himalaya exchange territory by once a proper license acquired.
Q. Okay. So once the proper license is acquired, then U.S.
residents may be able to purchase it, right?
A. Yes.
MR. KAMARAJU: Could we have GX VO-78, please, which
is in evidence.
Q. Okay, sir. Can you just remind us what this is?
A. Yes. This is a nominee shareholder agreement provided to
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me from UK London Club.
MR. KAMARAJU: Okay. And the first line under letter
of agreement, can we just blow that up.
Q. All right. Do you see the line that starts: "I am pleased
to inform you that"?
A. Yes.
Q. And do you see where it says: "In recognition of the
contributions made by you"?
A. Yes.
Q. That's a reference to your contributions to the farm,
right?
A. No, the contribution I understand is all of the previous G
Series investments.
Q. Okay. So your understanding is that the contributions that
are referred to here are the G Series of investments, not the
work that you did on behalf of the farm?
A. Some contributions for volunteer works towards
contributions, donation contributions.
Q. So it all goes together in figuring out the contribution,
right?
A. The work, the time, effort put into it and the donations.
Q. Yes. That's what I was referring to, the work and the
contributions; they all play in together in determining your --
what benefit you receive, right?
MS. MURRAY: Objection, your Honor.
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THE COURT: Overruled. You may continue.
A. At that time, yes, the contribution, I understand it as the
donations and the time and effort put into it.
MR. KAMARAJU: Now, could we go to page 8, please.
I'm sorry, could we scroll back to page 7 quickly.
Q. Do you see the subparagraph there that starts C?
A. Yes.
Q. All right. You see the part that says: "You hereby
consent to not performing the following"?
A. Yes.
Q. And it goes on to say "to allow you to benefit and
continue," do you see that language?
A. Yes.
Q. Okay. So this is telling you things that you should not do
if you want to keep the preferential H Coin allotment, right?
A. I'm sorry?
Q. This provision is talking about things that you should not
do in order to maintain the beneficial H Coin offering you were
getting, right?
A. Yes.
MR. KAMARAJU: Okay. If we could go to the next page
and just blow up No. 3, please.
Q. Could you read that, sir?
A. Yeah.
"You undertake to not demonstrate, whether directly or
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indirectly, or otherwise facilitate in any form, any support or
benefit in any form, to the Chinese Communist Party, CCP,
quote, or any CCP officials."
Q. Okay. So one of the things that you should refrain from
doing is supporting the CCP, right?
A. I'm sorry, referring --
Q. Well, you testified previously that this is talking about
things you shouldn't do to keep your H Coin allotment, right?
A. Correct.
Q. And one of the things is not support the CCP, right?
A. Correct.
Q. Because the movement is anti CCP, right?
A. Correct.
Q. So if you supported the CCP, obviously that would be anti
the movement, right?
A. Not me support, but --
Q. Anyone, sir. I'm not referring to you specifically.
A. Correct.
Q. Now, you talked a little bit about the work that you did on
behalf of the farms, right?
A. Correct.
Q. So you actually did a substantial amount of work for the
farms, right?
A. Yes.
Q. Tell us again what kind of work you did.
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A. Transcripts, reviewing translation, and we did editing and
streamings.
Q. Okay. So is it fair to say that the work you just
described is targeted to disseminating the movement's message?
A. Help to spread the words, yes.
Q. Okay. And you knew that broadcasting was a significant
part of the movement's efforts, right?
A. I will say equal to other informations, other type of work.
Q. Okay. And I'm not asking you to say what's more or not,
I'm just saying it was a big part of what the movement did was
broadcasting, right?
A. No, it's not big part. I say it's equal to other work.
Q. Okay. Well, you first learned of Mr. Guo by watching
online videos that have been posted; correct?
A. Yes.
Q. Okay. And did you first see him on YouTube?
A. Yes.
Q. When was that again?
A. February 2017.
Q. So you saw Mr. Guo -- withdrawn.
Was that on Mr. Guo's YouTube account?
A. No.
Q. Okay. So you saw him being rebroadcast on somebody else's
YouTube account?
A. Not a rebroadcast. He appear on an interview on someone's
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broadcast channels.
Q. Which interview was that?
A. The channel was called Mirror Media.
Q. All right. And in the video he expressed some criticism of
the Chinese Communist Party, is that fair?
A. Yes.
Q. Okay. And subsequently after you became involved with the
movement, the movement also put out broadcasting that was
critical of the Chinese Communist Party, right?
A. Yes.
Q. In fact, that was the goal of GTV, was to be able to
broadcast that kind of --
MS. MURRAY: Objection.
THE COURT: Overruled. You can express your
understanding of the goal of GTV.
MR. KAMARAJU: I'll phrase it that way, your Honor.
THE COURT: Okay.
Q. It was your understanding that the goal of GTV was to be
able to broadcast messages that were critical of the CCP to
people in China; correct?
A. Yes.
Q. Now, there were some people in the movement who appeared in
the broadcast; correct?
A. Yes.
Q. And there were some people who did work for the movement
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who did not appear on the broadcast; correct?
A. Yes.
Q. And did you ever appear in a broadcast?
A. I appeared just by voicing, not appears as physically, like
appearances.
Q. So you only used your voice, you didn't show your face; is
that right?
A. Correct.
Q. Why didn't you show your face?
A. Because I want to keep it just not -- I just decide not to
show my face.
Q. Was there any reason?
A. Well, so I don't want to --
MS. MURRAY: Objection.
THE COURT: Overruled. You may answer.
A. Yeah. Because I also don't want to be target by the CCP.
Q. Sorry. Did you say you didn't want to be targeted by the
CCP; is that right?
A. Correct.
Q. Okay. Thank you.
Now, you also testified on direct about the fact that
farm members used Discord, right?
A. Yes.
Q. What is your understanding of why they used Discord instead
of, you know, text messaging, for example?
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A. The reason I don't know.
Q. And you also testified on direct about WebEx, right?
A. Yes.
Q. Do you have an understanding as to why they chose WebEx?
A. This part of reason I know.
Q. Whatever you know, sir.
A. Is because WebEx has a feature allow over 100 participants
to be online at the same time.
Q. Were you on WebExes that had over 100 participants?
A. Yes.
Q. Okay. So those were large gatherings of movement members?
A. Yes.
Q. Was Mr. Guo part of any of those?
A. Yes.
Q. Okay. And everybody who was on that WebEx could speak if
they wanted to, right?
A. No.
Q. No?
A. No.
Q. Why?
A. Because it was some people muted; there was only have a
speaker allowed to speak.
Q. Okay. So someone would have to recognize the speaker,
right?
A. Yes.
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Q. Okay. Now, you also used a Discord name. I believe it was
Coffee Cantana, do I have that right?
A. Coffee Cantata.
Q. Cantata. Okay. Thank you, sir.
Is there a reason why you picked that name?
A. Yes.
Q. What's that?
A. I personally like to drink coffee. I play the classic
music. Cantata is a piece of the classic music.
Q. So it was related to your interests, right?
A. Correct.
Q. Okay. And you interacted with other movement members who
were also using Discord names, right?
A. Correct.
Q. And even some people who appeared in broadcasts used, I'll
say, pseudonyms, right?
A. I'm sorry?
Q. They used different names than their real names, right,
some people who appeared in broadcasts?
A. Correct.
Q. Like Mulan, for example, right?
A. Correct.
Q. That's not -- do you know somebody named Octopus?
A. Yes.
Q. Okay. That's not Octopus's real name either, right?
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A. That's not.
Q. Did Octopus ever appear in a broadcast?
A. I do not recall that.
Q. Okay. How about Nebula?
A. Yes.
Q. You know somebody who went by the name "Nebula"?
A. Yes.
Q. Okay. And that wasn't that person's real name either?
A. Correct.
Q. Did that person appear in a broadcast?
A. I do not recall that.
Q. Do you have an understanding as to why they were using
different names?
MS. MURRAY: Objection, your Honor.
THE COURT: Sustained.
Q. Now, in addition to doing kind of the video streaming work
that you talked about, right, you also opened bank accounts on
behalf of the farms, right?
A. Correct.
Q. So you were entrusted with receiving the money from other
farm members, right?
A. I don't know what's from other farm members.
Q. Okay. Let me put it this way: You were entrusted with the
money that the UK farm was receiving, right?
A. I cannot make that entrust because that's something someone
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has to say if they entrust me or not, but I didn't receive that
type of --
Q. Okay. You were given authority over the bank account that
contained the money, right?
A. Under authority, I'm sorry?
Q. You were given the authority over the bank account that
received the money, right?
A. I was instructed to open account.
Q. Okay. Was it your name on the account, sir?
A. The account I was a signer.
Q. Okay.
MR. KAMARAJU: Could we show for just the parties, the
Court, and the witness, DX 60476, please.
Q. While that's being pulled up, how many different bank
accounts did you open up, sir?
A. Three.
Q. Three. And were those all in the same name?
A. No.
Q. They were in different companies' names, right?
A. Correct.
Q. And some of those companies you started, right?
A. No, I didn't start a company.
Q. You didn't start any companies?
A. That's not my company.
Q. Well, okay. I'm just asking whether you -- did your name
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appear on any formation documents for one of the companies,
sir?
A. Yes.
Q. Okay. And when you opened those accounts, I think you
testified on direct that you told the banks that they were for
your real estate business, right?
A. I was instructed to tell them that.
Q. Okay. But that is what you told them, right?
A. Yes.
Q. And you told them that, right?
A. Yes.
Q. Okay. And that wasn't true, right?
A. Correct.
Q. Because in reality, you were receiving the money from --
that the farm was taking in, right?
A. I would say not say the farm, because all the wire to me
didn't tell me which one was farm, which farm or individual,
the person's relation. I know -- I know was farm the follower
wanted to invest in G Series.
Q. Yeah. Sorry, sir, I wasn't asking about where the money
came from. I was saying this was the money that the UK farm
was receiving, right?
A. Yes.
Q. The money wasn't going to your real estate business, right?
A. No.
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Q. Okay. So you misrepresented the nature of the account to
the bank, right?
A. Yes.
Q. Okay. And you did that because you were trying to help the
movement, right?
A. Help the followers.
Q. Right. Help the followers, right?
A. Yes.
Q. And help the UK farm, right?
A. Just help the followers.
Q. I'm sorry, sir, maybe I'm not understanding. Could you
explain the distinction that you're drawing there.
A. Yes. My intention help the farm because the UK London farm
leader tell me that -- ask me my help to help the followers,
but didn't specify if the follower was all from the UK London
Club or other farms.
Q. Okay. So how much money would you say came into the bank
accounts that you opened?
A. About $2 million.
Q. About $2 million.
And do you remember from roughly how many recipients
it came in from? Or, sorry, withdrawn.
Do you remember from approximately how many senders it
came in from?
A. Approximately 50.
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Q. Approximately 50, sir? Sorry, is that what you said?
A. Correct.
Q. All right. I think DX 60476 is on your screen now.
Could you just take a look at that, please.
A. Yes.
MR. KAMARAJU: Okay. Maybe we can scroll to the next
page.
Q. Do you recognize this document, sir?
A. Yes.
Q. Okay. Does your signature appear on it?
A. Yes.
Q. What's the date next to your signature?
A. February 24th, 2021.
Q. Okay. And what is this document, sir?
A. Oh, yeah. This is -- Florida, state of Florida business
status. I think it's certifications.
Q. Certification. Okay.
MR. KAMARAJU: Let's go to page 2. Sorry, page 2.
Q. Do you recognize this?
A. Yes.
Q. What's this?
A. This is from IRS about the EIN numbers.
Q. And do you see the name of a company listed in the first
sentence, sir?
A. Yes.
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Q. Okay. Is that one of the companies that you used to open
bank accounts for the UK farm?
A. This name was created by the UK farm, I use to open
account.
MR. KAMARAJU: Your Honor, the government -- I did it
again. The defense is going to offer DX 60476 into evidence.
MS. MURRAY: No objection.
THE COURT: It is admitted.
(Defendant's Exhibit 60476 received in evidence)
MR. KAMARAJU: Thank you. Could we publish to the
jury? I promise I won't do it three times.
Q. So this is the formation documents for one of those
companies; correct?
A. Yes.
MR. KAMARAJU: Could we go to the next page, please.
Page after that, please. Thanks. And just blow up the
signature line.
Q. Do you see where it says "incorporator," sir?
A. Yes.
Q. Whose signature is that?
A. Mine.
Q. So you began this company on February 24th, 2021, right?
A. I registered it myself, but the director was still listed
as the UK leaders.
Q. Okay. I was just -- you registered it on this day, right?
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A. Yes.
Q. All right. So you first started opening bank accounts to
receive the money for the UK farm in 2021, right?
A. Correct.
Q. Now, as part of your work receiving the money, did you also
account for how the money was being spent?
A. I documented, yes.
Q. So you looked at the bank statements to see where the money
was going?
A. The money was only instructed to wire out.
Q. I'm sorry, could you say that again?
A. All the money was instructed to wire out.
Q. All the money was instructed to wire out.
A. Correct.
Q. Right. So you never received any instructions to wire
money to Mr. Guo, right?
A. Not to him.
Q. Okay. Now, we talked a little bit about the volunteer work
that you did for the farm. The farm more broadly did volunteer
work as well, right?
A. Yes.
Q. There was a project in the Ukraine; is that right?
A. That's a farm Himalaya Global Alliance, not just one farm.
Q. Okay. So several farms united in that effort?
A. All farms participated.
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Q. Okay. And what were they doing?
A. There was the Ukraine.
MS. MURRAY: Objection, your Honor. Relevance.
THE COURT: Overruled. You may answer.
A. It was Ukraine, humanitarian missions. They were be called
to the borderline between Poland and the Ukraine. The mission
was to rescue Chinese nationals and to do other humanitarian
works.
THE COURT: Rescue them from where?
THE WITNESS: Between the borderline at Poland and the
Ukraine.
Q. Okay. Thank you.
Now, you testified on direct that you became concerned
about the way some of the money was being spent that had come
into those bank accounts; is that right?
A. Not a concern to those accounts.
Q. So you never had any concern about those accounts; is that
right?
A. There were meetings, private meetings, between Miles Guo
and UK London Club. There were things mentioned just from the
UK London Club financials, status, and province. There were --
misproper used funds was addressed.
Q. Okay. Who was misusing the funds?
A. At the time the meeting, David Dai, the leader of UK London
Club, was accused misused global donation, global foundation
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funds.
Q. So he was -- he was accused -- withdrawn.
David Dai was accused of misusing Rule of Law
Foundation funds at this meeting?
A. At that meeting, yes.
Q. Okay. But that meeting was a meeting of the UK farm?
A. Yes.
Q. So they were discussing misuse of the foundation's money at
the farm meeting, right?
MS. MURRAY: Objection. 401, 403.
THE COURT: You may answer.
A. That was mentioned in the meeting, yes.
Q. Okay. Now, I think you just said Mr. Guo was part of that
meeting, right?
A. Yes.
Q. So he was part of this discussion about these accusations,
right?
A. Yes. He was there.
Q. Okay. And the topic was -- or one of the topics at least
were these accusations, right?
A. Yes.
Q. So you heard Mr. Guo discuss those accusations, right?
A. Yes.
Q. Okay. And it was resolved to look into those accusations,
right, figure out if they were real?
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A. I don't know if they were resolved.
Q. It was decided at the meeting, sir?
A. It wasn't decided; it was just brought it out, the
accusations.
Q. Okay. Did anybody reach a decision as to what to do about
the accusations at that meeting?
A. At a meeting Miles Guo even ask one person from the Rule of
Law Foundations. To my knowledge, the person keeps track of
the funds, Miles Guo personally ask that person about the David
Dai's accusations.
Q. Okay. So Mr. Guo asked that person about the accusations,
right?
A. Yes.
Q. And the accusations were that UK David — that's David Dai,
right?
A. Yes.
Q. — was misusing the funds; correct?
A. Yes.
Q. Were there any other accusations made against UK David of
misappropriating funds?
A. Yes.
Q. How many times did that happen?
MS. MURRAY: Objection.
THE COURT: You can step up.
(Continued on next page)
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(At sidebar)
MS. MURRAY: Your Honor, as an initial matter, this is
hearsay that he's trying to elicit. In addition, the
accusations that there was a misuse of funds is being
introduced and offered for the truth, for the fact that there
was, in fact, misuse of funds and this 403 problem.
MR. KAMARAJU: Well, first of all, any introduction of
a defendant's out-of-court statement is not automatically
hearsay. We're simply eliciting his testimony to show when
there were accusations, they were taken seriously and people
were investigated, including Mr. Guo. So you have to at least
establish that the accusations were made. Whether they are
true or not, we don't know; we're not asking the witness to
opine on whether they are true. We're just saying they wanted
to look into it.
MS. MURRAY: Your Honor, I don't see how they are not
being offered for their truth here.
THE COURT: They are being offered for their truth.
MR. KAMARAJU: But I didn't even ask him if the
accusations were true, your Honor.
THE COURT: You want to use those accusations to make
the argument that Mr. Guo had a legitimate interest in guarding
the funds for the cause.
MR. KAMARAJU: Yes. And so the only relevant fact
there is that there were accusations made, not whether the
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accusations are true or not, which is all I'm trying to elicit.
And that's all I've elicited so far.
MS. SHROFF: In fact, Mr. Kamaraju could ask: You
don't know if these accusations were true or false. We are not
trying to introduce them for their truthfulness.
MS. MURRAY: He's already established the fact that
there were accusations. So the additional line of questioning
into "there were other accusations, weren't there," is leading
into, again, trying to indicate and imply the truth of a fact
that there were accusations of misuse of funds. I don't see
any other purpose for it to come in and it's unduly
prejudicial.
MR. KAMARAJU: The purpose is the same no matter how
many times I ask the question about accusations.
MS. MURRAY: Right. And it's already in evidence now.
THE COURT: So it seems that there are two purposes,
both for the fact of the accusation and for the truth of the
accusation, because you want to portray Mr. Guo as guarding
these funds for his political cause.
MR. KAMARAJU: But I don't believe that the second
point requires the accusations to be true or false.
If the U.S. Attorney's Office investigates somebody
and responds to a victim complaint, that's not a statement of
the victim complaint is true or it's false; it's simply
evidence that the U.S. Attorney's Office took the victim
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complaint seriously. You don't have to have the truth of the
victim complaint in order to establish that they took it
seriously.
MS. MURRAY: I think at bottom, your Honor,
Mr. Kamaraju is saying what he wants to get in is the fact that
there were accusations. That's already in. So there's no
additional line of questioning that would be fruitful unless
it's going to something improper.
MR. KAMARAJU: No, because we're allowed to point out
the fact that it happened more than once. That goes to how
serious they took it.
MS. SHROFF: And that each time the accusation was
addressed, not whether the accusation was true or false. You
are free to elicit on redirect that the accusations were, in
fact, false. Of course that's your prerogative. But that does
not make Mr. Kamaraju's questioning improper or unduly
prejudicial. In fact, that was the whole point of your direct.
Your whole point of the direct was to show that Mr. Guo did
nothing. So we're entitled to show that what you did on direct
was improper.
MS. MURRAY: Your Honor, again, it's hearsay. They
are focusing on what Mr. Guo did and what Mr. Guo said. Here
they are asking this witness with respect to how seriously the
accusations were taken or not. I think we've established this
witness said he didn't know what decision was made or whether
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there was a resolution to take certain action or not.
THE COURT: So you can ask whether there were any
other accusations, but it's going to stop there.
MR. KAMARAJU: Okay, your Honor.
(Continued on next page)
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(In open court)
BY MR. KAMARAJU:
Q. There came a point where the UK farm was dissolved;
correct?
A. Correct.
Q. Why was that?
A. Because there were -- at the time Himalaya Global Alliance
started doing statistical work to gather all the farms'
financial balance sheets, and also at the time to have all the
farms to wire all the balance each farm held to the Himalaya
Global Alliance. And at the time because accusation made it to
David Dai, and also he has some unwired balance, it was quite a
big amount of balance that Miles Guo ask him also provide him a
deadline to wire. He failed that.
Q. What was the -- I think you referred to it as an unwired
balance. What was that?
A. Because there's some funds the farm held. The fund has to
be transferred to the Himalaya Global Alliance, designated
accounts. And a couple other meetings, there were -- Miles Guo
gave David Dai a deadline to wire the balance which he failed
to do that. So that impact dissolving the whole farms, and
also Miles Guo strip his title and he was terminated from
this -- sorry, not terminated, he was removed from the farm and
from the movement.
Q. Was there a reason given for his termination from the farm
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and the movement?
A. That I don't know.
Q. So you weren't privy to any of those reasons?
A. I was in the meeting.
Q. Now, I'd like to talk a little bit about the refunds that
you requested, okay?
A. Sure.
Q. You asked for a refund from G Fashion, right?
A. Yes.
Q. Okay. And you asked for a refund from G Clubs, right?
A. Correct.
Q. Now, when you asked for the refund from G Clubs, did you go
to the company and ask for a refund?
A. Yes, I did email them.
Q. Okay. So you emailed G Clubs for a refund?
A. Yes.
Q. Did you get a response?
A. Only email I was received, just acknowledgment they
received my request. After that, no more response.
Q. And that response -- withdrawn.
That refund request was made, I think you testified,
in July of 2023, right?
A. I can't remember the dates.
Q. You don't remember testifying earlier today that it was
July 2023?
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A. The whole other refund which, I mean, July 15, 2023, was
started, initiated to the Washington, D.C. farms.
Q. Oh, I'm sorry. I misunderstood. The July 15 date is when
you applied to the farms for the refunds?
A. Yes.
Q. Approximately how long before you went to the farms did you
submit the G Clubs request?
A. That I don't remember.
Q. Well, not asking for a specific date, but months, years,
weeks?
A. Months.
Q. Months. Okay.
And it was several months after you had purchased your
G Club membership initially, right?
A. Yes.
Q. Why did you go to the farms to get a refund from G Clubs?
A. Because Miles Guo instructed any follower, any problem,
issues will first contact the farm leaders, which at the time I
was associated with Washington, D.C. farm. So, as instructed,
that is what I did.
Q. But you went to G Clubs first, right?
A. No, I don't remember if went to G Club first.
Q. Sir, I thought you just testified a moment ago that you
went -- months prior to submitting a farm request --
MS. MURRAY: Objection, your Honor.
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Mischaracterizes the testimony.
THE COURT: Sustained.
Q. Okay. So do you remember? Did you go to G Clubs first or
the farms first?
A. I don't remember --
MS. MURRAY: Objection, asked and answered.
THE COURT: Sustained.
Q. Okay. I'm sorry, sir. You said that you went to the farms
because Mr. Guo said you should go there first, right?
A. Not first. You have any issues, we will go to the farm
leader.
Q. And what did you think it was that the farm leader could do
for you with respect to G Clubs?
A. Miles Guo mention the farm leader roles. Leader roles only
to serve the followers. There's no class or underling. Every
follower and the leader are equal.
Q. Okay. I was just asking what you thought that the farms
could do for you with respect to G Clubs?
A. Because that's a rule, which farm you're associated with.
And you only can associate with one farm. So at the time I was
with Washington, D.C. farm. That's only farm I can go to.
Q. I understand, sir, you went to the Washington farm because
that's -- that was your farm, right?
A. At that time, yes.
Q. Okay. I'm just understanding -- I'm just trying to
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understand why you thought the farm could help you out with a G
Clubs problem?
A. Because that's -- Miles Guo stated anything, if it's
related to the movement, G Series, we can go to the leaders of
the farm.
Q. Okay. And what were the farm leaders supposed to do, sir?
A. To help with my request.
Q. Okay. Were you expecting the farms to pay the money back
to you that you had spent on G Clubs?
A. That I didn't expect.
Q. What kind of help were you expecting?
A. My hope was to have the farm leader first to acknowledge
that and for my request. Then the second was I just -- going
to just wait for the answer, but I don't expect what will be
the next. But my ultimate goal was to get a refund.
(Continued on next page)
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BY MR. KAMARAJU:
Q. Okay. And you did ultimately get a refund; is that right?
A. Yes, I received a G/CLUBS refund.
Q. Okay. And prior to getting the G/CLUBS refund, they made a
request that you returned some equipment, right?
A. Correct.
Q. What was that equipment?
A. It was streaming equipment.
Q. Okay. And why did you have that equipment?
A. Because the Washington, DC Farm send it to me for the
streaming, for the farm streaming, to use for the farm
streaming; also, the equipment was used during the protest
streamings, for the Himalaya Global Alliance.
Q. Okay. So it was used to broadcast farm business,
basically?
A. And for the Himalaya Global Alliance.
Q. Was it expensive equipment?
A. To my knowledge, yes.
Q. Did you send the equipment back, sir?
A. Yes.
Q. Who did you send it to?
A. I sent it to Washington, DC Farm. They provided the
address.
Q. Okay. And do you have any knowledge as to what they did
with that once you returned it?
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A. After I returned it, they had one person inspect it, and
then once inspected everything thoroughly, I had a
confirmation, item was received, inspected.
Q. Okay. And then you received your refund after that; is
that right?
A. Correct.
Q. Okay. About how long was it after that that you got your
refund?
A. I got my refund on December 1, 2023.
Q. And when was the inspection?
A. That was in——about October.
Q. Of 2023?
A. 2023.
Q. Okay. Thank you, sir.
MR. KAMARAJU: If I could just have one moment, your
Honor.
Q. Now, sir, you testified on direct about protests, right?
A. Yes.
Q. And you testified that your role in the protests was
helping to stream them, correct?
A. Yes.
Q. How many protests did you stream?
A. Personally stream, about dozens.
Q. Dozens?
A. Yes, personally streamed.
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Q. Okay. Yeah, I'm just talking about the ones that you
streamed.
A. Yes.
Q. Okay. Now the ones that you testified on direct I believe
were in connection to a man named Luc Despins; is that right?
A. Correct.
Q. Okay. And he was the bankruptcy trustee, correct?
A. Correct.
Q. Were all of the streams that you personally participated in
against——sorry. Withdrawn.
Were all of the streams that you personally
participated in of protests involving the bankruptcy trustee?
A. Not all of the streams.
Q. Okay. So there were some that were not that, right?
A. Correct.
Q. What were those other ones about?
A. Other ones about protesting Capitol Hill.
Q. Okay. You were protesting at Capitol Hill? The protests
occurred at Capitol Hill, the one you're talking about?
A. Yes.
Q. What were they protesting?
MS. MURRAY: Objection. Lacks personal knowledge.
THE COURT: If he observed the streaming, he may know
what they were protesting.
If you know.
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THE WITNESS: Yes, your Honor.
A. Yes. At Capitol Hill was——protest was also for Miles Guo.
Q. Okay. But what were they protesting against, sir?
A. It was against persecution against Miles Guo. There were
protests, unfair justice against Miles Guo.
Q. When was this protest?
A. This was in November 2022 to——lasted about a month.
Q. Sorry. You said it lasted about a month, sir?
A. Correct.
Q. And was there any specific group of people they were
protesting?
A. Yes.
Q. Who was that?
A. Mostly followers from Washington, DC Farm.
Q. Okay. So those were the people who were mostly
participating in the protest, right?
A. Yes.
Q. Okay. Were the protests aimed at any particular group of
people?
A. The Capitol one didn't aim any particular people, no.
Q. Okay. Was it targeted at any particular government agency?
MS. MURRAY: Objection. 403.
THE COURT: I'll allow the question.
THE WITNESS: Yes, your Honor.
A. The first, the Chinese Communist Party, and also there
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were——US Justice were mentioned during the protest.
Q. Okay. And when you say the Chinese Communist Party, the
protests were against the CCP, right?
A. Yes.
Q. And you testified on direct that the protests of the
bankruptcy trustee involved——and I wrote it down but I may have
it wrong so correct me, please——CCP running dogs, right?
A. That's what I——yes.
Q. Okay. Was any similar language used during the Capitol
Hill protest?
A. He was at a——the protest called 90 Days Protest for Luc
Despins wasn't at the Capitol.
Q. I understand. I'm asking about the Capitol Hill protests.
A. His name weren't mentioned at the Capitol Hills.
Q. Okay. Did you hear anybody at the Capitol Hill protests
talk about CCP spies?
A. Yes.
Q. Okay. Have you heard Mr. Guo refer to people as CCP spies
before?
A. Yes, he did refer.
Q. Have you heard other movement members refer to people as
CCP spies?
A. I never participated in other——other movements.
Q. Sorry, sir. I was talking about other NFSC movement
members refer to people as CCP spies.
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A. Yes.
Q. What is your understanding of that phrase?
A. Just CCP spies, just a name to those——acquisition to the
people.
Q. So it doesn't have any particular meaning to you?
A. Just CCP spies.
Q. Okay. And when you heard that, you didn't have any
evidence one way or the other as to whether those people were
actually CCP spies, right?
MS. MURRAY: Objection, your Honor.
THE COURT: You may answer.
A. That I don't.
Q. Sorry. You said you don't, right?
A. I don't.
Q. Okay. And you testified on direct that at the time of the
protests of the bankruptcy trustee, you didn't have any
evidence with respect to whether the trustee was working on
behalf of the CCP, right?
A. That I don't.
Q. You just didn't know one way or the other, right?
A. At the time I believed it, but I don't have the evidence to
prove it.
Q. Okay. And because you believed it, you participated in
those protests, right?
A. Yes.
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Q. You streamed them, right?
A. Yes.
Q. You wanted to get the word out, right?
A. Yes.
Q. You wanted other people to hear what was happening, right?
A. Yes.
Q. Because you believed an injustice was happening, right?
A. At the time I believed it.
MR. KAMARAJU: Okay. Your Honor, at this time the
defense would like to read and enter into evidence a
stipulation between the parties.
THE COURT: Go ahead.
MR. KAMARAJU: It's DX Stip 0001. And it reads:
"It is hereby stipulated and agreed by the United
States of America and Miles Guo, the defendant, through their
attorneys of record, that:
"1. The FBI has investigated individuals who, working
at the direction of the government of the People's Republic of
China (the "PRC government") have engaged in an international
campaign, known as "Operation Fox Hunt," to coerce individuals
located in the United States and elsewhere to return to China
to face charges brought by the PRC government or to otherwise
reach financial settlements with the PRC government.
"2. In 2017, a US law enforcement agency assessed
that Mr. Miles Guo was the highest priority of China's
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repatriation efforts.
"3. In 2017, a US law enforcement agency received
information that Chinese officials were paying and providing
food and signs to protestors of Mr. Guo.
"4. In 2018, a US law enforcement agency received
information that the PRC government had established a special
investigative group in China to manage China's investigation
of, and actions against, Mr. Guo.
"5. To carry out some of the objectives of Fox Hunt,
in 2017, the PRC government tasked a specially designated group
of operatives ("the Group") with discrediting and harassing
individuals, including Mr. Guo, by using interactive computer
services and electronic communication systems. The Group is
based out of the Beijing Municipal Public Security Bureau at a
facility in Beijing's Dong Cheng District. The Group was
previously referred to as the "Cyber Investigation Team" and
was later referred to as the 9112 Special Project Working
Group. The Group's tactics aimed at Mr. Guo included using
anonymized social media accounts operated by the Group and by
pressuring US social media companies to remove Mr. Guo and
US-based associates of Mr. Guo from social media platforms.
These efforts were part of the PRC government's broader effort
to prevent, disrupt, and harass Mr. Guo's use of social media
and other online platforms to disseminate and discuss
disfavored content. In or about December 2018, officers of the
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Group were directed to post three videos or posts daily with
YouTube and Facebook accounts, with one of the posts required
to be anti-Mr. Guo. On February 3, 2020, a PRC government
official issued a tasking requirement that every member of the
Group shall write an original article with content related to
targeting Mr. Guo, the COVID pandemic, or Hong Kong. The FBI
investigated the Group's activities, including its activities
aimed at Mr. Guo, and the US government has charged many of the
Group's members with violations of US law.
"6. Since Mr. Guo fled the PRC, the PRC government
has sought his return for prosecution in the PRC and has
employed numerous methods to effect Mr. Guo's capture or
arrest. In May 2017, the PRC government sent four undeclared
agents from the PRC's Ministry of State Security ("MSS") to the
United States to attempt to cause Mr. Guo's coerced
repatriation to the PRC as part of the Fox Hunt initiative.
The US government disrupted the PRC government's efforts to
forcefully repatriate Mr. Guo and Mr. Guo continued to reside
in the United States.
"7. Between May 2017 and January 2018, at least four
individuals, including George Higginbotham, Elliot Broidy,
Nickie Lum Davis, and Prakazrel Michel, never disclosed that
they were actually acting on behalf of foreign actors,
including the PRC government, to lobby officials in the Trump
administration in an effort to cause Mr. Guo's extradition to
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China. Higginbotham, Broidy, Davis, and Michel were each
convicted of violating US law regarding their lobbying efforts.
The efforts of these individuals were not successful, and
Mr. Guo was never extradited at the request of the PRC
government. Instead, and since approximately 2015, Mr. Guo has
been able to reside in the United States with his family.
"8. On October 23, 2018, a court in Hong Kong entered
an order seizing and restraining Mr. Guo's assets in Hong Kong
and elsewhere under the court's jurisdiction.
"It is further stipulated and agreed that this
stipulation may be admitted into evidence."
And your Honor, I would offer DX Stip 0001.
THE COURT: It is admitted.
(Defendant's Exhibit Stip 0001 received in evidence)
MR. KAMARAJU: Thank you, your Honor.
BY MR. KAMARAJU:
Q. So just one question, sir. Prior to hearing me read that
information out, had you heard any of that before?
A. Yes, I heard Miles Guo mentioned it, some of it.
Q. What did you hear him mention?
MS. MURRAY: Objection. Hearsay.
THE COURT: Sustained.
Q. Okay. Other than Miles Guo's statements, did you hear it
anywhere else?
MS. MURRAY: Objection.
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THE COURT: The fact of having heard it, he can
answer. It's that you can't state what you heard.
A. Just from Miles Guo.
MR. KAMARAJU: No further questions at this time, your
Honor.
THE COURT: Redirect?
MS. MURRAY: Yes, your Honor. Thank you.
REDIRECT EXAMINATION
BY MS. MURRAY:
Q. Mr. Zhou, you were asked questions on cross-examination
about the hierarchy of the Himalaya Global Alliance. Do you
recall those questions?
A. Yes.
Q. Who appointed the farm leaders?
A. The farm leaders, beginning will be only appointed by Miles
Guo, but later, once the Himalaya Global Alliance Farm,
especially the Iron group, Iron Blood group farm, it will be
jointly——jointly appoint the leaders.
Q. And who appointed the members of the Iron Blood group?
A. Miles Guo.
Q. Who was the ultimate highest leader of the farms?
MR. KAMARAJU: Objection.
THE COURT: Overruled. You may answer.
A. Well, Miles Guo.
Q. And who was the ultimate highest leader of the Himalaya
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Global Alliance?
A. Miles Guo.
Q. You were asked questions on cross-examination yesterday and
again today about the purposes of the G series investments. Do
you recall those?
A. Yes.
Q. Your understanding that GTV was a social media company was
based on whose statements?
A. Based on Miles Guo's statements.
Q. Your understanding that G/CLUBS was a membership service
was based on whose statements?
A. Miles Guo's statements.
Q. Your understanding that the Himalaya Exchange was a
cryptocurrency platform was based on whose statements?
A. Miles Guo's statements.
Q. Who announced the G series investments?
A. I'm sorry?
Q. Who announced the G series investments?
A. Miles Guo.
Q. Who promoted the G series offerings?
A. Miles Guo.
Q. You were also asked questions about how the GTV private
placement funds were to be used. Do you recall those?
A. Yes.
Q. Did Guo say he was going to send GTV investor funds to a
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hedge fund?
A. No. I don't——I don't recall that.
Q. You were also asked questions about your own GTV investment
through Voice of Guo, or VOG. Do you recall that?
A. Yes.
Q. Who identified Sara Wei as the point of contact for a GTV
investment below a hundred thousand dollars?
A. Miles Guo.
Q. You were asked some questions about what you expected to
receive in exchange for your G/CLUBS membership money. Do you
remember those questions?
A. Yes.
Q. Did you ever receive an NFSC passport for your $70,000
G/CLUBS payment?
A. No.
Q. Did you ever receive any G/CLUBS stock for your $70,000
G/CLUBS payment?
MR. KAMARAJU: Objection, your Honor.
THE COURT: You may answer.
A. No.
Q. Did you ever receive any G Fashion stocks for your $70,000
G/CLUBS payment?
MR. KAMARAJU: Same objection.
THE COURT: You may answer.
A. No.
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Q. Aside from discounts on G Fashion items, did you receive
benefits for your $70,000 G/CLUBS payment?
A. I would not say benefits, but I received small souvenir
items, the mug and a bag of coffee.
Q. A mug and a bag of coffee; is that correct?
A. Yes.
Q. Did you ever receive GTV stock for your $31,300 investment
in GTV through Voice of Guo?
A. No.
Q. Would you have sent money to G/CLUBS if you knew that you
would not get any stock?
A. No.
Q. Would you have loaned money to the UK Farm if you knew you
would not get any stock?
A. No.
Q. You made the choice to invest in a G series offering based
on whose statements?
A. Could you repeat that question, ma'am.
Q. Sure. You made the choice to invest in a G series offering
based on whose statements about those offerings?
A. Miles Guo's.
Q. And how much money did you lose in the G series investment?
A. As the money, because I——there was coin involved, I——even
until this day, I didn't receive the full refund, but the
coins, at the time, for——if I requested at the time, the value
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of the coins' value still added, I believe it estimated about
$10. So for that value, it's also——I will consider that, so
also additional value, but in the dollar, from the investment,
the principal parts, I still didn't receive near $30,000.
Q. And at the time that you participated in G series
offerings, it was your understanding that Miles Guo personally
guaranteed that you wouldn't lose any of your principal; is
that correct?
A. That's correct.
MS. MURRAY: May I have a moment, your Honor.
THE COURT: Yes.
MS. MURRAY: Nothing further, your Honor.
THE COURT: Recross?
MR. KAMARAJU: Just briefly, your Honor.
RECROSS EXAMINATION
BY MR. KAMARAJU:
Q. You were asked a series of questions about who was the
leader of the——the ultimate leader of the farms, correct?
A. Yes.
Q. And you testified it was Miles Guo, right?
A. Correct.
Q. Okay. In connection with the money that you took in as the
bank accounts, did you ever receive a single instruction from
Miles Guo?
A. Not direct from him, no.
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Q. Mr. Guo never reached out to you and said do X with the
money, right?
A. He did.
Q. Mr. Guo reached out directly to you and said send the money
here?
A. No. In a meeting happened, took place with UK Farm, the
part of the meeting, Miles Guo asked not just David Dai to
return all the money, he asked all the member from UK London
Club who, direct or indirect, has the money from followers,
will do the same, by the deadline, to wire all the remaining
balance to those accounts.
Q. Okay. And he gave that direction to everybody, right?
A. Yes.
Q. Now you testified on redirect that you had lost $30,000,
correct?
A. Yes.
Q. Okay. What is that based on?
A. The principals.
Q. But the principal of what, sir?
A. The principal from——there's a portion from the VOG
investments.
Q. Okay.
A. There were a portion from the coins I purchased. There
were parts of the money from farm loan.
Q. How much of the money came from the farm loans?
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A. I invested $21,000 for my farm loans.
Q. Okay. So of the $30,000 that you lost, $21,000 you say is
from the farm loans, right?
A. Part of it.
Q. I'm sorry. I don't understand.
A. It's——you asked the $30,000, the principal. The $21,000 to
the farm loan, that's principal. The VOG investment towards
the GTV, that was also invest $31,000 and $300, but I do
receive reimbursement from the fair funds. I got——there were
about 7 percent loss. Then adding together, that's estimated
about $30,000.
Q. Now your farm loan principal was due to be returned at the
end of the term of the loan, right?
A. The contract stated that, yes.
Q. Okay. And the term of the loan was extended in August of
2023, correct?
A. It was force extended, without my consent.
Q. They didn't need your consent, though, right? They had the
right to do it under the contract, right?
A. That I don't recall if it's their right to do that.
Q. So you don't remember one way or the other.
A. I receive a notice just purely for extension 24
hours——months, without any option to opt out.
Q. Okay. So 24 months from August of 2023, right?
A. Yes.
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Q. Okay. So your farm loan is not actually due to be repaid
until next year, right?
MS. MURRAY: Objection, your Honor. Scope.
THE COURT: Sustained.
MR. KAMARAJU: Your Honor, could we have a sidebar on
that quickly.
THE COURT: Yes.
(Continued on next page)
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(At the sidebar)
THE COURT: Your objection?
MS. MURRAY: Yes, your Honor. So objection to scope
but also objection on 403 grounds. There is an implication
here that the witness could have contracted out of being
defrauded. He just said that he was forced to extend the loan.
He had no consent; it was just given to him. And Mr. Kamaraju
is now suggesting that there was a provision in the original
loan that permitted that. But there's not an ability to
explain what this witness knew. And it also calls for him to
bring a legal conclusion that he is not equipped to make.
THE COURT: Certainly on the grounds of legal
conclusion, he's not a lawyer. He can't interpret a contract.
MR. KAMARAJU: I can ask him what his understanding
is, right?
THE COURT: You could ask what his understanding is.
MR. KAMARAJU: Okay. I'll ask that question.
MS. MURRAY: He can't contract himself out of a fraud,
and that's the 403 basis for the objection.
MR. KAMARAJU: They brought up the idea of the refund,
your Honor, and allowed him to say that. They can allege it's
a fraud; we're allowed to allege that it's not.
MS. MURRAY: And your Honor, I would just note, he
said he didn't recall what was in the contract. So he's
already asked a question that Mr. Kamaraju answered, or Mr. ——
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THE COURT: Was that the testimony? Can you go back
and see?
MS. MURRAY: Regarding the——if this is the regarding
the extension.
THE COURT: You want to first find out whether he
recalled if it's a term of the loan or the fact of the
extension?
MS. MURRAY: The fact of the ability of the
counterparty to require an extension without consent. That——
MR. KAMARAJU: That was not what my question went to.
My question just said simply——and I didn't ask the
understanding, but if I were to ask, I'd say, so your
understanding is that your loan is due to be repaid a year from
now.
MR. FERGENSON: No.
THE COURT: I want to go back to the testimony, if you
wouldn't mind.
(Record read)
MS. MURRAY: Your Honor, he's established what this
witness knew and what he understood at the time, and he's
implying to the jury that he can contract out of the fraud, and
that's clearly impermissible under 403 and under black letter
law.
MR. KAMARAJU: I'm not saying anything whether he can
contract out of the fraud. They asked what his loss was. They
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brought that out, not us. And I'm simply saying that he
received a notice, he understands he received a notice, and is
it his understanding that under the notice, the loan will be
repaid a year from now.
MS. MURRAY: Your Honor, there's no other probative
purpose for this other than to imply he can contract out of the
fraud. He said he wanted a refund of his money. He's speaking
to his losses. That is what he has testified to.
MR. KAMARAJU: Then they didn't need to bring up the
losses. I'm entitled to respond. They put it in issue, your
Honor, not me.
MS. MURRAY: Your Honor, the fraud is complete as soon
as the misrepresentation is made.
THE COURT: His own understanding, that was it?
MR. KAMARAJU: If his losses are relevant. Ms. Murray
just said that the fraud is complete at the time of the
misrepresentation. If that's true, then the actual losses he
suffered are irrelevant. The government nonetheless elicited
it, so I'm entitled to say, that number is wrong, you testified
to an incorrect number, sir.
MS. MURRAY: Your Honor, there's no accounting. He's
asked his understanding, he's given a summary of his
understanding of how much money he put in and how much money he
was not repaid, which was the guarantee that Miles Guo made and
did not follow through on.
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MR. KAMARAJU: This is a summation, your Honor.
That's fine. It can be presented to the jury in summation.
But prior to that we get to attack the very specific things
they elicit.
THE COURT: I'm going to allow what was your
understanding.
MR. KAMARAJU: Okay. So the question I'll ask, just
to make sure I'm complying: So under the notice you received,
what is your understanding as to when you will be paid back, or
when you should be paid back?
MS. MURRAY: And your Honor, we would ask that it go
no further than that because we still maintain our objection
that he's trying to elicit improper implications with this
witness, that it's a 403 problem.
MR. KAMARAJU: All of those implications that they
keep arguing at sidebar can be dealt with by your Honor when
you instruct the jury as to the law.
MS. MURRAY: No. It's confusing the jury now with
respect to this witness's testimony.
MR. KAMARAJU: We had this argument just yesterday.
THE COURT: I'm going to allow the question.
(Continued on next page)
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O5T1GUO2 Le Zhou - Recross
(In open court)
BY MR. KAMARAJU:
Q. Sir, when we paused, we were talking about the extension
notice. Do you remember that?
A. Yes.
Q. Okay. Based on your receipt of that notice, what is your
understanding as to when you should be paid back your farm loan
principal?
A. The notice——I think it's invalid, because my previous
contract signed with two entities, was both established by
David Dai. Since David Dai was terminated and removed by the
farm, and I believe those two entities both dissolved,
automatically, the contract is void.
Q. That's your legal conclusion, sir?
MS. MURRAY: Objection, your Honor.
THE COURT: Overruled. Is that your legal conclusion?
A. Yes.
Q. Where did you go to law school?
MS. MURRAY: Objection, your Honor.
THE COURT: Sustained.
Q. Okay. So your view is that the farm loan contract is null
and void now.
A. It's void.
Q. Okay. So if you were to sue somebody, you'd have nobody to
sue.
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O5T1GUO2 Maistrello - Direct
MS. MURRAY: Objection.
THE COURT: Overruled. You may answer.
A. Could you repeat the question, please.
MR. KAMARAJU: Could you read it back, please.
(Record read)
A. Yes.
MR. KAMARAJU: No further questions, your Honor.
THE COURT: All righty. Thank you, sir. You may step
out.
(Witness excused)
THE COURT: And the prosecution can call its next
witness.
MR. HORTON: The government calls Karin Maistrello.
THE LAW CLERK: Please raise your right hand.
(Witness sworn)
THE LAW CLERK: You may be seated.
THE COURT: Please state your name and spell it.
THE WITNESS: Karin Maistrello. K-A-R-I-N,
M-A-I-S-T-R-E-L-L-O.
THE COURT: You may inquire.
MR. HORTON: Thank you, your Honor.
KARIN MAISTRELLO,
called as a witness by the Government,
having been duly sworn, testified as follows:
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O5T1GUO2 Maistrello - Direct
DIRECT EXAMINATION
BY MR. HORTON:
Q. Good morning, Ms. Maistrello.
A. Good morning.
Q. What state do you live in?
A. New Jersey.
Q. What languages do you speak?
A. English, German, Italian, French, Spanish, and Chinese.
Q. And where do you currently work?
A. I work for Google.
Q. Turning back to 2018, who did you work for then?
A. I was an employee of Golden Spring.
Q. And——
MS. SHROFF: Your Honor, I'm sorry. We're having
trouble hearing the witness.
THE COURT: If you'd draw the microphone closer to you
and speak up.
THE WITNESS: Of course, yes.
Q. Who is Guo Wengui?
A. He was my boss at Golden Spring.
Q. And how long did you work for Guo Wengui?
A. From 2018 to 2020.
Q. What are other names, Ms. Maistrello, if any, does Guo
Wengui use?
A. Miles Kwok.
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MS. SHROFF: Objection to the form of the question,
your Honor.
THE COURT: Overruled. You may answer.
A. Guo Wengui. I used to call him "Boss."
Q. Could you please spell Guo Wengui.
A. G-U-O, W-E-N, G-U-I.
Q. You said Guo Wengui also goes by Miles Kwok. Could you
spell Kwok.
A. K-W-O-K.
Q. Ms. Maistrello, who is Ho Wan Kwok?
A. Go Wengui.
Q. When you worked for Miles Guo, what did you call him?
A. I used to call him Boss, in Chinese.
Q. Do you see Boss here in the courtroom today?
A. Yes, I do.
Q. Could you please point him out and identify him by
something he's wearing.
A. He's wearing glasses and a blue suit, with a blue tie.
MS. SHROFF: Your Honor, I'll stipulate that she's
identified Mr. Miles Guo.
THE COURT: All righty.
Q. Ms. Maistrello, during the two years you worked for Boss,
how many days a week did you work for him?
A. It varied. Sometimes it was six, sometimes it was seven.
Q. And during those six or seven days a week working for Boss,
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what were your hours like?
MS. SHROFF: Objection to the leading and the form of
the question.
THE COURT: Overruled. You may answer. You may
answer.
A. It depended on the work that we had to do, so usually I
would be in the office quite early, around 8, all the way until
8 p.m. If I had any other projects, it could be as early as
4 a.m. or as late as midnight. It depended.
Q. And how much of that time, Ms. Maistrello, did you spend
with Boss?
A. Every day.
Q. And when you worked with Boss, how, if at all, did you
communicate with him?
A. All day long in one way or another.
MR. HORTON: Ms. Loftus, can you please pull up for
the witness what's been marked as GX 141.
Q. Ms. Maistrello, what is this?
A. It's a photo.
Q. And what is it a photo of?
A. There are two people in the photo. One is me and one is
Boss.
MR. HORTON: Government offers Government Exhibit 141.
MS. SHROFF: No objection, your Honor.
THE COURT: It is admitted.
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(Government's Exhibit 141 received in evidence)
MR. HORTON: Ms. Loftus, can you please publish it.
Q. About when was this photo taken, Ms. Maistrello?
A. This photo was taken in 2018.
Q. And when did you start working for Boss?
A. In 2018.
Q. Was there a time that you enjoyed working for Boss,
Ms. Maistrello?
A. Yes.
Q. And what did you enjoy about working for him?
A. It was definitely very challenging. No day was alike. You
definitely had to learn a lot and do it quickly.
Q. Ms. Maistrello, what were the Rule of Law organizations?
A. Rule of Law Society and Rule of Law Foundation were two
nonprofit organizations that were founded in 2018, in November
of 2018, that had the mission of helping Chinese people.
Q. And who founded the Rule of Law organizations in 2018?
A. Boss did.
Q. What title, if any, did you have at Rule of Law,
Ms. Maistrello?
A. I was president and treasurer of Rule of Law Society.
Q. Who gave you those titles at Rule of Law?
A. Boss did.
Q. As president and treasurer of the Rule of Law Society,
Ms. Maistrello, were you in charge of that organization?
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A. No, I wasn't.
Q. Who was in charge of the Rule of Law organizations?
A. Boss was.
Q. You said the purpose was to help people in China. What, if
anything, did Rule of Law do to help people in China?
A. While I was there, nothing.
Q. We'll come back to that.
MS. SHROFF: Objection to the commentary.
THE COURT: You may continue.
Q. Ms. Maistrello, where did you work before you worked for
Boss?
A. In China.
Q. And who did you work for in China?
A. I worked at an oil company, and I was also teaching at
university.
Q. Who owned the oil company you worked for in China?
A. In theory, the company was privately owned, but as
everything in China, it was government owned and backed.
Q. And how long were you working in China?
A. Five years.
Q. When did you move to the United States?
A. In 2017.
Q. How did you first hear about the opportunity to work for
Miles Guo?
A. I was contacted directly by a recruiter.
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Q. Who was that recruiter?
A. His name was, is, Steve Weber.
Q. And after you first heard about the opportunity to work for
Miles Guo from Steve Weber, who did you speak with next?
A. He arranged a meeting, so a first interview, where I met
Yvette Wang.
Q. Who is Yvette Wang?
A. At the time she introduced herself as Boss's assistant.
Q. And where did she introduce herself to you?
A. We met for our interview at the Plaza Hotel.
MR. HORTON: Ms. Loftus, can you please display for
Ms. Maistrello what's been marked as Government Exhibit 102.
Q. Ms. Maistrello, what is Government Exhibit 102?
A. It's a photo.
Q. Who or what is it a photo of?
A. Yvette.
MR. HORTON: Your Honor, government offers Government
Exhibit 102.
MS. SHROFF: No objection, your Honor.
THE COURT: It is admitted.
(Government's Exhibit 102 received in evidence)
MR. HORTON: Please publish it, Ms. Loftus. Thank
you.
BY MR. HORTON:
Q. Ms. Maistrello, in your interview with Yvette Wang, what,
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if anything, did she call Miles Guo?
A. In that interview she called him the principal.
Q. And what questions did Yvette ask you in that interview to
work for the principal?
A. She asked me a few personal questions, so she asked
questions about my family, she asked whether I was married, I
had kids; she also asked me if I had any connection to the CCP,
so to the party.
Q. How did you respond to Yvette Wang's question whether you
had any connections to the CCP?
A. I told her that I knew people who were party members but
that was all of it.
Q. How did Yvette Wang respond to that?
MS. SHROFF: Objection as to the hearsay.
THE COURT: Sustained.
Q. What, if anything, was Yvette's reaction when you said you
had connections to CCP members?
THE COURT: So you need to repeat her words.
MR. HORTON: Can I have one moment, your Honor.
THE COURT: Yes.
MR. HORTON: Thank you, your Honor.
Q. Ms. Maistrello, after Yvette Wang interviewed you for the
job with Boss, what happened next?
A. I got a call from Steve Weber, who told me that the
interview went well and he called me in for another interview.
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Q. And with whom was that next interview?
A. That was with Boss.
MR. HORTON: Ms. Loftus, can you please take down the
exhibit. Thank you.
Q. Where did Boss interview you?
A. At his home.
Q. Where was his home?
A. The Sherry-Netherland.
Q. What is the Sherry-Netherland?
A. The Sherry-Netherland is a luxury residential hotel that
overlooks Central Park.
MR. HORTON: Ms. Loftus, can you please display for
the witness what's been marked as Government Exhibit 130.
Q. Ms. Maistrello, what is Government Exhibit 130?
A. It's a photo.
Q. What is it a photo of?
A. The Sherry-Netherland.
MR. HORTON: Government would offer Government
Exhibit 130.
MS. SHROFF: I have no objection, your Honor.
THE COURT: It is admitted.
(Government's Exhibit 130 received in evidence)
Q. Ms. Maistrello, where is the Sherry-Netherland located?
A. It's between 57th and Fifth Ave.
Q. And where in the Sherry did Boss interview you?
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A. Do you mean which room?
Q. Where in the building was your interview? Where did it
take place?
A. On the 18th floor.
Q. What's on the 18th floor of the Sherry?
A. That was his home.
Q. Who met you when you arrived for the interview with Boss?
A. Yvette did.
Q. What happened first when Yvette met you at Boss's
apartment?
A. When I first arrived, she showed me around a little bit,
just one area of the penthouse, and then we waited for Boss.
Q. Please describe to the jury what that part of Boss's
penthouse looked like.
A. That specific part had various different rooms, so you can
imagine like a corridor, a dining area, a tea room, a library,
a gym, a movie room, and a piano room.
Q. And what happened after Yvette showed you around Boss's
penthouse?
A. We sat down and we waited for him.
Q. What happened next?
A. He arrived.
Q. And did Boss interview you when he arrived?
A. Yes, he did.
Q. What happened after your interview with Boss that day?
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A. I went home, and I believe I received an offer on the same
night.
Q. Did you accept that offer?
A. I did.
MR. HORTON: Ms. Loftus, can you please show the
witness what's marked as GX BR871.
You can enlarge it just a little bit, Ms. Loftus.
Thank you.
Q. Ms. Maistrello, what is this document?
A. This is the offer letter I received.
MR. HORTON: Your Honor, the government would offer
GX BR871.
MS. SHROFF: No objection, your Honor.
THE COURT: It is admitted.
(Government's Exhibit BR871 received in evidence)
MR. HORTON: Could you please publish it, Ms. Loftus.
BY MR. HORTON:
Q. Ms. Maistrello, the top of your accepted job offer says
Golden Spring, New York. What was Golden Spring, New York?
A. Golden Spring was my employer.
Q. What was the business of Golden Spring, New York?
A. It was presented to me on my very first day as an asset
management company.
Q. In your two years of working for Boss, what, if anything,
did you come to understand Golden Spring did?
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A. Golden Spring was a company that took care of Boss's wishes
and desires, so it was the company through which we would
purchase things for Boss, or take care of his things.
MR. HORTON: Ms. Loftus, can you scroll down towards
the bottom of this page, please. Thank you.
Q. Ms. Maistrello, there's a signature on the page over a line
that says Yvette Wang, COO, Golden Spring, New York. What is
COO?
A. Chief operating officer.
Q. When you worked for Boss, how often, if ever, did you work
with Yvette?
A. Every day.
Q. And who did Yvette work for?
A. Golden Spring.
MR. HORTON: Ms. Loftus, can you please show the
witness what's been marked as Government Exhibit UK723.
Q. Ms. Maistrello, what is this?
A. It's a photo.
Q. And who is it a photo of?
A. There are four people in the photo. Boss is one of them,
his wife, daughter——
MS. SHROFF: Objection, your Honor.
THE COURT: If you'll step up.
(Continued on next page)
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(At the sidebar)
THE COURT: What's the objection?
MS. SHROFF: There's no relevance to the photo. She
didn't take the photo, she doesn't know——there's no indication
when this photo was taken, we don't know the year, we don't
know how she would know anything about this photo. The
government is using the photo to introduce people they want to
put into evidence. This is——it has no relevance to the
testimony.
THE COURT: Go ahead.
MR. HORTON: So the people in the photo, as
Ms. Maistrello is about to establish, that she can recognize
them from the photo. They're people who will feature in this
case; they're already featured in this case. You don't have to
take a photo to be able to authenticate it. It's black letter
authentication. And I'm laying a foundation. I think she's
almost there, if she's not there already. I'd ask to have the
photo admitted.
MS. SHROFF: What's the relevance of the photo?
There's no relevance of the photograph to this witness's
testimony. She's not going to testify about any——
THE COURT: He has said that these individuals will
play a part in the prosecution's case.
MS. SHROFF: Right, but not any part of her testimony.
So it may be down the road, if she wants——so that's my first
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objection, your Honor. I didn't object to the photo of Yvette
because she's going to testify about Yvette. That's relevant
because it pertains to some part of her testimony. She's not
going to testify about any of these people.
THE COURT: She can authenticate the photo by
identifying these individuals. Let's see if she does.
Overruled.
MS. SHROFF: Your Honor, while we're at the sidebar,
though, I did have an objection to the government lawyers
constant looping of facts into each question. So each question
adds in a response from the witness, instead of just simply
asking the next question, there are facts baked in. The
looping theory of asking questions, I object to it.
And number two, your Honor, it's improper to refer to
the defendant as "Boss" by the government. If she wants to use
that in the answer, that's one thing, but to perpetuate that by
asking the question and framing it as "Boss," I object to that
as well.
THE COURT: All right. So you'll call him Mr. Guo.
I have overruled your objections with respect to the
form of the question.
MS. SHROFF: Thank you.
THE COURT: Let's go back.
(Continued on next page)
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(In open court)
THE COURT: You may continue.
BY MR. HORTON:
Q. Ms. Maistrello, do you recognize the people in this
photograph?
A. I do.
MR. HORTON: Government would move to offer Government
Exhibit UK723.
THE COURT: She needs to identify the individuals.
MR. HORTON: Oh, okay.
Q. Can you identify——can you say who the people are in the
photograph, left to right.
A. Yes. Boss; his wife; Yvette; and their daughter.
MR. HORTON: Government offers Government Exhibit
UK723.
THE COURT: It is admitted.
(Government's Exhibit UK723 received in evidence)
MR. HORTON: Please publish it, Ms. Loftus.
Q. Ms. Maistrello, where was this photograph taken?
A. In the dining room of the Sherry.
Q. Turning back to Yvette Wang, what exactly did Yvette do for
Mr. Guo?
A. Everything.
Q. What do you mean by everything?
A. She was his right hand.
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MS. SHROFF: Your Honor, I apologize, but I am having
trouble hearing the witness. If you could just ask for her
voice to be——
THE COURT: So you can bring the microphone closer and
also speak up.
THE WITNESS: I'll try, your Honor.
BY MR. HORTON:
Q. Ms. Maistrello, you said that Yvette Wang did everything
for the defendant, was his right-hand person. What do you mean
by that?
MS. SHROFF: Objection to the testifying by the
government, your Honor.
THE COURT: Overruled. You may answer.
A. So I said that she was his right hand.
Q. And my question is: What exactly did that entail?
A. From payments to giving directions to the staff.
Q. And who else besides Mr. Guo, if anybody, did Yvette Wang
report to?
A. Only to Boss.
MR. HORTON: Ms. Loftus, you can please take the
picture down.
Q. By the way, Ms. Maistrello, when you worked for the
defendant, where did you work?
A. Our office was located at 800 Fifth Ave.
Q. And where else, if anywhere, did you work for Mr. Guo?
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A. In 2019, we moved to another office on Lexington and,
whenever it was needed, in his home.
THE COURT: All righty. It's now 11:30, and so we're
going to take our half-hour break.
Members of the jury, remember that you're not
permitted to discuss the case amongst yourselves. Don't permit
anyone to discuss it in your presence.
We will start promptly at noon.
Ma'am, you may step down, but do not discuss the case.
(Continued on next page)
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(Jury not present)
THE COURT: Counsel, is there anything before we
return?
MR. HORTON: Yes, your Honor. Just one matter the
government wishes to raise for efficiency's sake. There was an
objection early in Ms. Maistrello's testimony about hearsay
with respect to a statement that Yvette Wang made. Yvette Wang
is a co-conspirator of Miles Guo. The Court knows she was
charged with Miles Guo. The testimony that was just elicited
made clear that she was also an agent of Miles Guo. I believe
Ms. Maistrello described her as doing everything for him and
his right hand. So we submit that statements made by Yvette
Wang in her capacity as Miles Guo's agent and in her capacity
as a co-conspirator in this case are admissible.
MS. SHROFF: Your Honor, I don't believe the
government has shown the existence——I can't see the Court. I
apologize. But I don't believe that the government has met its
burden under the hearsay rules of having established a
conspiracy with Ms. Yvette Wang and Miles Guo. There may have
been an employer-employee relationship that they've established
so far, but there is no indication that they've established a
co-conspiratorial agreement between those two individuals.
Additionally, your Honor, the evidence that the
government was trying to elicit——and I apologize if I have this
wrong, but I believe there were questions about what she was
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asked during an employment interview, which certainly are not
in furtherance of a conspiracy. They are employment-related
questions.
Finally, your Honor, even if the government is said to
have established a conspiracy here, there is no relevance to
what interview questions she is asked. The government has
clearly established she got a job, and there's no allegation
here that she got a job based on fraudulent pretenses.
So for all those reasons, your Honor, I don't think
that the government's argument is properly made. Thank you.
MR. HORTON: Your Honor, there isn't a more
paradigmatic agency situation than interviewing somebody to
work for somebody else. Yvette Wang was there for Miles Guo to
interview somebody who was hired to work directly with Miles
Guo. If that's not agency, it doesn't exist.
MS. SHROFF: She was not hired to work for Miles Guo,
one, she was hired to work for Golden Spring.
THE COURT: One moment. Did Ms. Wang plead guilty to
conspiracy?
MR. HORTON: Yes.
THE COURT: All right. You may ask questions that
elicit statements from Ms. Wang.
MR. HORTON: Thank you.
THE COURT: We will reconvene at noon.
(Luncheon recess)
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AFTERNOON SESSION
12:00 p.m.
(Jury present)
THE COURT: Please be seated.
Remember that you're still under oath.
THE WITNESS: Yes, your Honor.
THE COURT: You may continue your direct examination.
MR. HORTON: Thank you, your Honor.
BY MR. HORTON:
Q. Ms. Maistrello, when you worked for Guo, how often, if
ever, did Guo tell you to buy things?
A. Quite often.
Q. And what things did Guo tell you to buy?
A. It could be equipment for his media room, it could be
suits, it could be furniture.
Q. Let's talk about the furniture. What's Promemoria?
A. Promemoria is a furniture brand.
Q. And where is Promemoria based?
A. They're based in Italy.
Q. When, if at all, did you deal with Promemoria when you
worked for Guo?
A. All throughout the two years I worked there.
Q. And what did Guo have you do at Promemoria?
A. Sometimes buy furniture. Their furniture is custom made,
so connect with——with the people from Promemoria to design
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certain——certain furniture.
Q. And where would that furniture that you bought for Guo go?
A. That would go either to the office or to his home.
Q. You said you bought suits. What kind of suits did you buy
for Guo?
A. Bespoke, tailored suits.
Q. What do you mean by bespoke?
A. Custom made.
Q. What brand, if any, of suits did you buy for Guo?
A. Mainly two. Brioni was one, and Stefano Ricci was the
other.
Q. And what was the process of buying those suits?
A. So I would get in touch with the manager, for instance, at
Brioni, choose some fabrics, then take them to Boss; he would
choose the fabrics for his next batch of suits; the tailor
would come either to the office or his home, measure him; then
they would make the suit and come back with the delivery.
Q. And how often would that happen during the two years you
worked for him?
A. That happened I would say twice a year. Once definitely
when it was Chinese New Year and one more time.
Q. How many suits were you buying for Guo each time?
MS. SHROFF: Objection. Mischaracterizes her
testimony.
THE COURT: On his behalf.
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Q. How many suits were you buying on Guo's behalf each time?
A. I would say approximately a dozen.
Q. How much did those suits cost, Ms. Maistrello?
A. About 10,000 each.
Q. And what did those suits look like?
A. They had, of course, pants and a jacket; they were, well,
in different colors or different fabrics, depending on the
season or depending on what he wanted; they had his name on the
interior pocket.
Q. And what name was on the interior pocket?
A. Miles Kwok.
MS. SHROFF: I'm sorry. I didn't hear that.
THE WITNESS: Miles Kwok.
Q. Ms. Maistrello, what, if anything, did Guo tell you about
cars he owned in China?
A. He talked a little bit about his cars. He was very——well,
he liked cars. He was very proud of his fleet of cars in
China.
Q. And what, if anything, did Guo ask you to do with those
cars?
MS. SHROFF: Objection. Is this all cars, some cars?
THE COURT: With his cars in China?
MR. HORTON: Yes, your Honor.
THE COURT: Go ahead.
A. He had a few favorite cars that he wanted to import to the
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US.
Q. And what kinds of cars were those?
A. It was definitely a Lamborghini and a Rolls Royce.
Q. And what exactly did Guo ask you to do with the Lamborghini
and the Rolls Royce?
A. To import them into the US.
Q. And ultimately were you able to do that?
A. No.
Q. Why not?
A. Because of import laws on——on cars.
Q. What year did Guo ask you to import his Lamborghini?
A. I think it was 2018.
Q. Ms. Maistrello, what is a hutong?
A. It's a traditional architectural structure, typical of the
capital of China, Beijing, which has a courtyard and then
houses surrounding the three sides of the courtyard.
Q. What, if anything, did Guo tell you about his house in
Beijing?
A. He——well, he was very proud of it. He showed some photos,
mainly of the interior, he showed photos of his artwork.
Everything was custom made in the home.
Q. And what did that property in Beijing look like?
A. Luxury property, like a traditional Beijing home but
luxury——a luxury one.
Q. And how many buildings were on that property?
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A. There were like more buildings attached to one another.
Q. And what, if anything, did he tell you about who lived in
his house in Beijing?
A. He and his family.
Q. What was Chateau Ridge?
A. Chateau Ridge was a property located in Connecticut that he
wanted to purchase.
Q. And what, if anything, did you have to do with Chateau
Ridge?
MS. SHROFF: Objection as to the form of the question.
THE COURT: Overruled. You may answer.
THE WITNESS: Can I answer?
THE COURT: Yes.
A. There was a lot of back-and-forth for that property. I
think I started working on it in 2018, where he first wanted to
purchase it, so there were a lot of talks with the owner of the
property. We went there several times to check the property
itself and all the rooms and all the art that——that was in the
house. Some of it he wanted to keep, some of it he didn't want
it or he didn't need it. It was a quite long process.
Q. You said that "we" went there a few times. Who was "we"?
A. I went there a few times with him. Sometimes other
colleagues tagged along.
Q. And who were those other colleagues who went with you to
Chateau Ridge?
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A. In several instances——in several different instances,
Yvette came once; I believe Hank also came. These are the
people I remember.
Q. What kind of property is Chateau Ridge?
A. I guess the easiest way to describe it is like a castle.
That's what "chateau" means. So it's——it looks like a French
castle. The interior——like, the interior of the rooms are
actually based off Versailles in France.
Q. What, if anything, did Guo tell you about why he was
looking to buy Chateau Ridge?
A. He liked it.
Q. What, if anything, did Guo tell you he was going to do with
the property if he bought it?
A. He was going to live there.
Q. Did Guo ultimately buy Chateau Ridge?
A. No, he did not.
Q. When you were working for Guo between 2018 and 2020, what
house, if any, did he buy?
A. He ended up buying a property in Connecticut.
Q. Now what did the Connecticut house that Guo bought look
like?
A. It was a very big house. I would call it a villa or a
mansion.
Q. And who, if anyone, lived in the mansion in Connecticut?
A. He did, with the family.
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MS. SHROFF: I'm sorry. I just continue to have
difficulty hearing the witness, your Honor.
THE WITNESS: I'm sorry. I'm trying, and this is the
highest I can get.
THE COURT: One moment, please.
Okay. So I'm being told that the volume is at the
highest, and so I'm just going to ask you to be very careful
about speaking as loudly as you can.
THE WITNESS: I will.
THE COURT: Thank you.
BY MR. HORTON:
Q. Ms. Maistrello, who is Qiang Guo?
A. Boss's son.
Q. And can you please spell Qiang Guo.
A. G-U-O, Q-I-A-N-G.
Q. What other names, if any, does Boss's son go by?
MS. SHROFF: Objection.
THE COURT: Overruled. You may answer.
A. Mileson.
Q. What, if anything, did Guo tell you about Mileson's
interests?
A. He also had an interest in motors, so cars, motorbikes.
Q. When you say he had an interest in cars and motorbikes, who
are you referring to?
A. His son.
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Q. Did there come a time that Guo asked you to buy something
for Mileson?
A. Yes.
Q. What did Guo ask you to buy for Mileson?
A. It was a motorbike.
Q. Ms. Maistrello, when Guo told you to buy suits for him or a
motorcycle for his son, how would you pay for these things?
A. It depended on the amount, so it could be either a wire
transfer or a check.
Q. And how would you get those checks?
A. I would ask Yvette.
Q. What would happen when you asked Yvette for a check for a
particular purchase?
A. She would give it to me.
Q. Where did those checks come from?
A. Golden Spring.
Q. Ms. Maistrello, you said that you bought computer equipment
for Guo. How did he pay for that equipment?
A. The big bulk of the payments for media and broadcast
equipment was paid through Saraca.
Q. What was Saraca?
A. Saraca was an entity that we used mainly for media and
tech-related expenses.
Q. Who was in charge of Saraca?
A. I don't know.
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Q. How would you know whether something should be paid for by
Golden Spring or Saraca?
A. I learned with experience, so I knew that certain expenses
would be paid with one company and certain others with another
company.
Q. And who did you learn that from?
A. By working there, or Yvette would tell me, oh, this expense
would go under Saraca or under Golden Spring.
Q. And what other companies, if any, paid for some of the
things you bought?
A. There was another entity called Genever.
Q. What was Genever?
MS. SHROFF: Objection.
THE COURT: You may answer.
A. It was an entity that was——was used mainly for personal
purchases or for personal expenses that related to the Sherry.
Q. And whose personal expenses was Genever used to pay for?
A. Boss's.
Q. Ms. Maistrello, who was in charge of Genever?
A. I don't know.
Q. Where was Golden Spring's office located?
A. When I started working, it was located at 800 Fifth Ave.
Q. And where is Saraca's office located?
A. So the official address, I don't know, but it was operating
from the same office, so 800 Fifth Ave.
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Q. And what do you mean by official address?
A. The one that was, for instance, filed in the official
paperwork. I've never seen that.
Q. Who, if anybody, would you speak with to authorize an
expense from one of the companies that Guo——that you've just
testified about?
MS. SHROFF: Asked and answered.
THE COURT: You may answer.
A. So whenever Boss used to ask me to buy something, I
would——at a certain point I understood where the money
should——should be coming from, and I——and I asked Yvette
directly for a certain amount of money from a certain company.
Q. Who was Max Krasner?
A. Max was my colleague at Golden Spring.
MR. HORTON: Ms. Loftus, can you please pull up for
the witness what's been marked as Government Exhibit SM62.
Q. Ms. Maistrello, what is this?
A. It's a document.
Q. And what is this document?
A. It's a payment request form.
Q. Is your name on this form?
A. Yes.
Q. And what does this form indicate?
A. Being a payment request form, it looks like a purchase was
made or it was about to——to be made and I requested it.
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MR. HORTON: Your Honor, government would offer
Government Exhibit SM62.
THE COURT: No objection?
MS. SHROFF: None, your Honor.
THE COURT: It is admitted.
(Government's Exhibit SM62 received in evidence)
MR. HORTON: Could you please publish it, Ms. Loftus.
Ms. Loftus, can you zoom in on the line that says
Approved by Max Krasner.
BY MR. HORTON:
Q. Ms. Maistrello, what did Max Krasner do for Boss——excuse
me——for Mr. Guo?
A. He was an employee of Golden Spring and he worked in
accounting.
Q. And what did his job entail?
A. A lot of payments. I know he was working on tax forms.
Q. And how often, if ever, did you interact with Max Krasner
at work?
A. Every day.
Q. And what would you go to him about?
A. Well, we——we were very close in——in the office, meaning
that we——we worked together, but whenever I needed something, I
needed a payment to be done, for instance, by Saraca, I would
go to him.
Q. Who was Max Krasner's Boss?
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A. Go Wengui.
Q. Who else, if anybody, did Max report to?
A. Yvette.
MR. HORTON: Ms. Loftus, can you please go to the top
of this page that we're on and highlight what's up top there.
Q. Ms. Maistrello, can you describe what's at the very top of
your payment request form.
A. Do you want me to read, like, the title?
Q. If you could just describe what we're seeing at the very
top of this page.
A. Okay. So there is the company name at the top and then
there are——there is a payment request form, and then there are
a few lines that indicate the payee for this payment, the
street and address and the form of payment, with the amount of
the payment and the purpose of the expense.
MR. HORTON: Ms. Loftus, can you please take the
exhibit down and show the witness what's marked as Government
Exhibit 110.
Q. Ms. Maistrello, who's this?
A. This is Max.
MR. HORTON: Government offers Government Exhibit 110.
MS. SHROFF: We have no objection, your Honor.
THE COURT: It is admitted.
(Government's Exhibit 110 received in evidence)
MR. HORTON: Ms. Loftus, please publish it.
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BY MR. HORTON:
Q. Now which of Guo's companies did Max work with?
A. Golden Spring and Saraca, mainly.
Q. In the two years you worked for Guo, how much, if ever,
were you with Guo and Max at the same time?
A. Definitely a few times a week.
Q. And when, if ever, did Guo tell Max to buy things?
A. About——can you repeat the question.
Q. Sure. When, if ever, did Guo tell Max to buy things?
A. It happened if Max was around him. It usually happened
at——when Boss had an idea and he wanted to buy something, then
he would ask the person he had in front in that very moment.
Q. And who, if anybody, would Max need to go to after that for
permission?
MS. SHROFF: Objection as to personal knowledge.
THE COURT: If you know, you may answer.
A. Yvette.
MR. HORTON: Okay. Thank you, Ms. Loftus. You can
take this down.
Q. Ms. Maistrello, who is Defeng Cao?
A. He was a colleague for the first few months while I was at
Golden Spring.
Q. And what did Defeng Cao do?
A. He would do security, security work.
Q. Who else, if anybody, did security work?
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A. I would say that we had two separate teams, so we had
Chinese team and we had an American team.
Q. And how often, if at all, did you speak with the people on
these security teams?
A. Every day.
Q. What exactly did the security teams do?
A. They were doing a little bit of everything, so from
driving, handiwork, assembling, disassembling furniture,
receiving packages, these things.
Q. What kind of security work did these teams do?
A. Not much, really, in the sense that there was no need for
security, like, for bodyguard in this true sense of the term.
Q. And why do you say that there was no need for security?
A. I believe that there was no danger or threat posed to Boss.
Q. In the two years working for Guo, what makes you say that?
A. Nothing has ever happened in terms of security.
Q. How did you know what those teams were doing all day?
A. They were telling me.
Q. What was your understanding, if any, about why they were
called security teams?
A. I assumed that the word——
MS. SHROFF: Objection to what she assumed.
THE COURT: Sustained.
Q. Do you have an understanding of why they were called
security teams?
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A. Yes.
Q. What is that understanding?
A. The term security, security team, or bodyguard is better
than handyman.
Q. What do you mean it's better?
A. Well, it definitely sounds better when you need to hire
someone.
Q. And who, if anybody——withdrawn.
Turning specifically to Defeng Cao, what kinds of
assignments did Guo give him?
A. So at the very beginning, when we were still setting up the
office, there was a lot of furniture moving. He was taking
furniture from several storage places to the office. He was
sometimes painting the office too.
Q. And how long had Defeng Cao worked for Guo?
A. I don't know the number of years.
Q. And what, if anything, did you understand about how Defeng
Cao came to work for Guo?
A. From China.
Q. And what, if anything, do you understand about Defeng Cao's
relationship with Guo's family?
A. They were in good terms.
MR. HORTON: And Ms. Loftus, if you could please show
the witness what's marked as Government Exhibit UK728.
Q. Who is this a photograph of?
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A. There are three people in the photo. Boss is one, his wife
is the other, and Cao is the other.
MR. HORTON: Your Honor, government moves to admit
Government Exhibit GX UK——pardon me.
MS. SHROFF: Your Honor, we have the same objection as
before. And I believe that the 403 analysis here would be
higher.
THE COURT: It is admitted.
(Government's Exhibit UK728 received in evidence)
MR. HORTON: And it's 728, just so it's clear.
Could you please publish it, Ms. Loftus.
BY MR. HORTON:
Q. Ms. Maistrello, who is the person kneeling in the photo?
A. That's Ho.
Q. And is the name you said the same as Defeng Cao?
A. Yes.
Q. And who are the two people in the right of the photograph?
A. The man is Boss and the woman is his wife.
Q. And what, if anything, was Defeng Cao's relationship with
Guo's daughter?
A. They were together.
MR. HORTON: Ms. Loftus——actually, please leave it up.
Q. What understanding, if any, did you have about why Guo
hired those security teams?
MS. SHROFF: Objection. It's not based on personal
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knowledge, your Honor. Also, may we approach?
THE COURT: Yes.
(At the sidebar)
THE COURT: I suppose that it's the government's
contention that they did not work in a traditional security
role because Mr. Guo did not indeed fear that he was in any
kind of danger; is that your contention?
MR. HORTON: We're trying to elicit——so she worked
with Mr. Guo six, seven days a week for two years. She also
spoke often with the people who were on these so-called
security teams. I'd like to ask——I did ask if she understood
why they were there. And I think the different question is,
did she understand, speaking almost every day with Mr. Guo, why
he had hired them, particularly when their tasks were different
than what the label might suggest if people were hearing this
for the first time.
THE COURT: You asked a question like that before.
MR. HORTON: So your Honor, I did ask if she knew why
they were there, sort of what was her understanding from
interacting with them almost every day for two years, and a lot
of the questions in this testimony are about what Mr. Guo told
her, right? She was working by his side almost all week,
almost all day for two years. I think it's relevant, if he
said anything to her why he had these teams, for the jury to
know why he told her that.
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THE COURT: I agree it could come in. I just thought
it might have already been asked.
MS. SHROFF: Many times.
MR. HORTON: Well, with respect, I do think I was
asking a different question, which was from her own
observations, setting aside what anybody told her, what did she
see them doing. And now I'd like to elicit: Did he ever tell
you why he hired them?
THE COURT: Okay. That's fine.
MS. SHROFF: Your Honor, the security team was not
hired after she took the job. The security team was in place
for years before that. And there's no evidence that she's the
one who had anything to do with them being hired. It's also
very amorphous to say a security team. There's no indication
of who——
MR. HORTON: I didn't mean any disrespect to
Ms. Shroff. I was just trying to——
THE COURT: Go ahead.
MS. SHROFF: ——of who she's referring to.
Thirdly, your Honor, what Mr. Guo said to her about
why they hired a specific person would be also irrelevant.
It's not in furtherance of any conspiracy, so I don't know how
it could even fall under a hearsay exception.
But most important, your Honor, this is cumulative, it
is in fact not quite relevant to any issues here, and if he's
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trying to make the point that this was all a big farce, I
believe the point has been made.
I just have to add one thing, your Honor. I'm
completely deaf in my left ear. I'm not only having trouble
hearing her, I'm also having trouble hearing him, even though
he's standing right next to me, so if you could please ask him
to use the microphone, I would really appreciate it.
THE COURT: Of course. Speak into the microphone. I
have checked with the AV.
MS. SHROFF: I know. It's my problem. I can hear
fine from here. It's this part.
MR. HORTON: I'll do my best to keep it up.
THE COURT: I will ask if there's any way of
amplifying the sound going beyond the equipment that we already
have.
MS. SHROFF: I understand, your Honor. I know you've
tried. I just am having——I didn't want you to think——I want
you to understand why I'm having trouble.
THE COURT: I will continue to try.
But I will permit the question. The objection is
overruled.
(Continued on next page)
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(In open court)
THE COURT: So in order to better hear you, I'd like
to try the handheld microphone and see how that works.
You may continue.
MR. HORTON: Thank you, your Honor.
BY MR. HORTON:
Q. Ms. Maistrello, what, if anything, did Guo tell you about
why he hired these security teams?
A. What he said is that it was for security purposes.
Q. Turning to the exhibit in front of you, can you——looking at
the exhibit that's in front of you, Ms. Maistrello, you
identified the person on the right as Guo's wife. What is her
name?
A. I don't remember it right now.
Q. And can you please spell Defeng Cao.
A. D-E-F-E-N-G, C-A-O.
Q. What was Guo's relationship like with Defeng Cao?
A. It was good.
Q. And what sorts of assignments did you see Guo give to
Defeng Cao?
A. Again, at the very beginning, it was really about setting
up the office, so there was a lot of storage moving, furniture
moving, assembling, painting.
Q. And you said that there were Chinese team and American
team. What differences, if any, were there between the work
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they did?
A. The——the Chinese team was in a way more trusted and closer
to Boss than the American one. The American teams were also
coming and going.
Q. And you said the Chinese teams were closer and more
trusted. What did that mean?
A. So there were things that maybe Boss didn't feel
comfortable sharing with the American team, or he wanted to go
somewhere he didn't want people to know, so he would
definitely——
MS. SHROFF: Objection, your Honor.
THE COURT: Overruled.
You may continue.
A. So he would definitely ask the——the Chinese team to help
him with those.
MR. HORTON: Ms. Loftus, you can please take the
exhibit down.
Q. Ms. Maistrello, who is William Je?
A. William Je was Boss's friend and finance person.
Q. And what does finance person mean?
A. He was the person who would handle the investments and
financing for Boss.
Q. When, if ever, did you meet William Je?
A. Several times over the course of two years.
Q. And where did you meet him?
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A. Mainly at the office.
Q. And when, if ever, did you sit in meetings with William Je?
A. Several times during both 2018 and 2019.
Q. And what were the topics of those meetings?
A. So in 2018, the main topics were Guo Media and also Rule of
Law, so Rule of Law Society and Foundation. In 2019, it was
mainly the same thing.
Q. What was Guo Media?
A. Guo Media was a platform, a social media platform that Boss
started to broadcast——for his broadcasts.
Q. During your two years working for Guo, when, if ever, did
you work on Guo Media?
A. All along in one capacity or another.
Q. We'll come back to that.
What other names, if any, do you know William Je by?
A. Only his——his Chinese or Cantonese name.
Q. What is his Cantonese name?
A. Kin Ming Je.
Q. Could you please spell that.
A. K-I-N, M-I-N-G, G-E.
MR. HORTON: Ms. Loftus, for Ms. Maistrello only, can
you please display GX UK764.
Q. Ms. Maistrello, who is in this photograph?
A. It's William.
MR. HORTON: Thank you, Ms. Loftus. You can take that
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down.
And Ms. Loftus, can you please display what's been
marked as GX 103.
Q. Who is in this photograph?
A. It's William.
MR. HORTON: Government would offer Government
Exhibit 103, your Honor.
MS. SHROFF: No objection, your Honor.
THE COURT: It is admitted.
(Government's Exhibit 103 received in evidence)
MR. HORTON: Please publish it, Ms. Loftus.
BY MR. HORTON:
Q. Ms. Maistrello, did there come a time that William Je asked
you to take a position with another company?
A. Yes.
Q. And what exactly did William Je ask you to do?
A. He asked me to sit on the board of directors of one of his
companies.
Q. What was that company called?
A. ACA Capital.
Q. Where were you when William Je asked you to sit on the
board of ACA Capital?
A. I was at the office.
Q. And what, if anything, did William Je say about why he was
asking you to sit on the board of ACA Capital?
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A. He mentioned——
MS. SHROFF: Objection as to hearsay.
THE COURT: If he gave you an explanation, you may
answer.
A. He told me that they were looking for investments in New
York and in the US. That was the reason.
Q. And what experience, if any, had you had with investments?
A. None.
Q. What experience, if any, had you had serving as a corporate
director?
A. None.
Q. Who introduced you to William Je before he asked you to sit
as a director at that company?
A. We were introduced by Boss.
Q. Did you agree to serve as a director of ACA Capital?
A. Yes.
Q. And why did you agree to take that position at ACA Capital?
A. I trusted William. He——he was asking for it, and I saw no
reason to——to decline.
Q. Why did you trust him?
A. I trusted him as I trusted Boss. He was an extremely kind
person; in my opinion, trustworthy.
Q. For about how long did you serve as a director of ACA
Capital?
A. A few months.
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Q. And what is ACA Capital?
A. I don't know.
Q. What work, if any, did you do at ACA Capital?
A. I didn't do anything.
Q. Did there come a time, Ms. Maistrello, that you had to sit
for a deposition in your role as a director at ACA Capital?
A. Yes, I sat at a deposition, but I had already resigned.
Q. And what is a deposition?
A. A deposition is a legal procedure where an individual
offers sworn evidence.
Q. How did you find out you were going to have to sit for a
deposition as a director at ACA Capital?
A. I was subpoenaed.
Q. And after you were subpoenaed, what did you do?
A. The next day, I went to the office and I asked our counsel
to explain what it was.
(Continued on next page)
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BY MR. HORTON:
Q. And what was the name of the person you asked for an
explanation?
A. Daniel Podhaskie.
MR. HORTON: Ms. Loftus, can you please display for
the witness what has been marked as Government Exhibit 105.
Q. Ms. Maistrello, who's in this photograph?
A. That's Daniel.
MR. HORTON: The government offers Government Exhibit
105.
MS. SHROFF: No objection, your Honor.
THE COURT: It is admitted.
(Government's Exhibit 105 received in evidence)
MR. HORTON: Would you please publish it, Ms. Loftus.
Q. Ms. Maistrello, what did you do after you took the subpoena
to Dan Podhaskie?
A. I told Yvette.
MR. HORTON: Ms. Loftus, you can please take the
exhibit down.
Q. And how did Yvette respond when you told her about the
subpoena?
A. We never spoke about the subpoena itself, but she arranged
counsel for me.
Q. And when, if ever, did you meet with those lawyers?
A. I believe it was July.
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Q. Ms. Maistrello, when you met with those lawyers that Yvette
arranged for you, had you ever seen them before?
A. Yes.
Q. And where had you seen them?
A. At our office.
Q. And what understanding, if any, do you have about why you
had seen them before at your office?
A. They came to the office several times for other lawsuits.
Q. On the day of your deposition, who accompanied you?
A. Yvette did.
Q. What kind of room was your deposition in?
A. It was a meeting room.
Q. And where were you sitting?
A. So there was a long table, and I was sitting almost in the
middle.
THE COURT: One moment, please.
You may continue.
MR. HORTON: Thank you, your Honor.
Q. Was Yvette the only person who accompanied you to the
deposition?
A. Yes.
Q. Ms. Maistrello, was Yvette there as your lawyer?
A. No.
Q. Was there a lawyer there to represent you at the
deposition?
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MS. SHROFF: Objection.
THE COURT: Overruled. You may answer.
A. Yes, the lawyer was already there at the office.
Q. I see. And where with respect to you was Yvette sitting
during your deposition?
A. Two seats to my right.
Q. Where did you go after the deposition ended?
A. We went and had lunch.
Q. And where did you go after lunch?
A. Back to the office.
Q. Who did you have lunch with, by the way?
A. With Yvette.
Q. And what happened when you got back to the office with
Yvette?
A. We went to boss's office and talked to him.
Q. And what did you and Yvette talk to boss about after your
deposition?
A. Yvette told boss how it went.
Q. How did you think it went?
MS. SHROFF: Objection as to relevance.
THE COURT: Overruled. You may answer.
A. It was my first deposition, so I didn't really have an idea
of how it went.
Q. What did Yvette say to boss about how it went?
A. She said it went really well.
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Q. And what, if anything, did Yvette say to you in that
meeting with Guo about how your deposition went?
A. She said I was very good. I did good.
Q. What, if anything, did Yvette call you in that meeting?
A. She referred to me as a person who, like, does the right
thing or does things the right way.
Q. What language did she say that in?
A. In Chinese.
Q. And what is the translation in English of what she called
you?
A. The literal translation would be like a little flute or
something along those lines.
Q. By the way, Ms. Maistrello, in your two years working for
Guo, what language did you speak with him?
A. In Chinese.
THE COURT: Do you mean Mandarin?
THE WITNESS: Yes.
Q. Ms. Maistrello, what month and year was your deposition for
ACA Capital?
A. July of 2019.
Q. You said you had -- you said you were no longer director at
ACA Capital. How did you leave your director position at ACA
Capital?
A. I sent an email to William telling him that I would like to
resign.
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Q. And why did you want to resign from ACA Capital?
A. I wasn't doing anything for the company. I had overheard
that there were, like, some sort of legal troubles. And not
knowing the company and not knowing the role I had in the
company, I just didn't want to be involved in any of it.
Q. Ms. Maistrello, as you sit here today, what's your
understanding of what the purpose was of your deposition in
2019?
MS. SHROFF: Objection to what her understanding is
today. It's not relevant, your Honor.
THE COURT: Overruled. You may answer.
A. I don't have an understanding of that deposition.
Q. Ms. Maistrello, turning back to the Rule of Law
organizations, when did you first hear that Guo was starting
the Rule of Law organizations?
A. That was in the summer of 2018.
Q. How long had you been working for Guo at that point?
A. Several months.
Q. When you first heard that Guo was starting the Rule of Law
organizations, what did you think about it?
A. I was really, really happy.
Q. Why were you really happy?
A. Those two organizations were -- were a step further in what
boss wanted. And I felt that at that point we could really put
things from theory into practice.
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Q. What, if anything, did you donate to the Rule of Law
organizations?
A. I donated $500.
Q. And why did you donate?
A. I believed in the organizations. I was president of one of
them; so if I don't donate, who would? Who does?
Q. And what year did you donate?
A. It was either 2018 or early 2019.
Q. Did the Rule of Law organizations have boards of directors?
A. Yes.
Q. And what role, if any, did you have on the board of
directors?
A. I was a member.
Q. Who else served on that board with you?
A. So on the board of Rule of Law Society, we had Steve
Bannon, who was chair; initially, Sasha Gong, Bill Gertz, and
Jennifer Mercurio.
Q. Who was Steve Bannon?
A. Steve Bannon was the former political adviser of former
president Donald Trump.
Q. And how did Steve Bannon get involved with the Rule of Law
organization?
A. He was very much involved in all the work at the office
around 2018.
Q. Who got Mr. Bannon involved with the work around the
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office?
A. Boss did.
Q. And what exactly did Mr. Bannon do around the office?
A. Whenever he was at the office, he was there for meetings
with boss.
Q. What kind of meetings?
A. So initially in 2018, there was a lot of planning around
the Rule of Law organizations. Later on it was more strategic
meetings about CCP and China -- U.S./China relations.
Q. What exactly did Steve Bannon do with the Rule of Law
organizations?
A. He didn't really do anything.
Q. What, if anything, was Mr. Bannon paid for the work he was
doing at the office?
MS. SHROFF: Objection.
Assumes facts not in evidence.
THE COURT: Overruled. You may answer.
A. He was paid over a million dollars divided in four
installments.
Q. Where did you learn that?
A. I was at the office.
Q. How was Mr. Bannon paid that money?
A. Via check.
Q. Where did those checks come from?
A. I don't remember the entity they came from; it might have
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been Saraca.
Q. Who decided that Mr. Bannon would get paid that money?
A. I don't know.
Q. Ms. Maistrello, what role, if any, did you have in planning
the launch of the Rule of Law organizations?
A. There was a lot of planning that year, so we launched in
November of 2018. We had a pretty big press conference on
November 21st of 2018. So there was a lot of coordination for
people to come into New York City for the conference,
presentations for the keynote speakers, just a few months
really of organizing.
Q. When did that planning begin?
A. Late September 2018.
Q. When was the press conference you just referenced, when did
that take place?
A. November 21st of 2018.
Q. During that planning phase, what, if anything, did Guo say
about how the Rule of Law organizations would be funded?
A. He said that he would be --
MS. SHROFF: Your Honor, are we referring to private
conversations between the two of them? It's an open-ended
question.
THE COURT: What time? When?
MR. HORTON: Well, Ms. Maistrello testified that there
was a planning phase for some period of months before the
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launch; and that she participated in it; and that Mr. Guo did
too; Mr. Bannon did too. I was asking her about conversations
in that planning phase between the three people.
MS. SHROFF: All of them over all these months.
MR. HORTON: Sounded like it was one or two months.
THE COURT: You may answer.
A. Can you repeat the question please?
Q. Yes. During the planning phase, planning for the Rule of
Law organizations, what, if anything, did Mr. Guo say about how
the Rule of Law organizations would be funded?
A. So he said that he would donate the first $100 million as a
first donor or as a sponsor.
Q. Ms. Maistrello, as president and treasurer of the Rule of
Law Society, did Mr. Guo ultimately make $100 million donation?
A. No.
Q. And how was Rule of Law actually funded?
A. It was funded through donations that were coming from
followers.
Q. What do you mean by "followers"?
A. So boss had a pretty huge following, following base. And
those followers donated starting from 2018.
Q. Did there come a time that Rule of Law broadcast a
fundraiser?
A. Yes, that was the one-year anniversary.
Q. And where were you during that broadcast fundraiser?
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A. At the office.
Q. Where was the fundraiser broadcast?
A. When or where?
Q. I'm sorry, where was the fundraiser broadcast?
A. At the office.
Q. And on what outlet, if any, was the fundraiser broadcast?
A. On Guo Media.
Q. What was GTV?
A. GTV was a platform for -- I'm sorry. I'm thinking about
something else. When I was there, GTV and Guo Media were
actually the same thing.
Q. And what, if anything, did the "G" in GTV stand for?
A. Guo.
THE COURT: When you refer to "the office," what
location?
THE WITNESS: So the first office we were at in 2018
and early 2019 was 800 Fifth Ave. Well, in 2019, we moved to
64th and Lex.
Q. Ms. Maistrello, what, if anything, did you do to plan the
fundraiser?
A. Nothing.
Q. And were you present when the fundraiser was being
broadcast?
A. I was.
Q. What, if anything, was Mr. Guo's role in the fundraiser?
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A. He was broadcasting over the course of several hours.
Q. And who were you with when you were at the fundraiser?
A. Initially, at the office I was on the second floor. And
then -- so with a couple of colleagues. And then I moved to
the first floor, where the actual broadcast was happening.
Q. Which colleagues were you with?
A. I was with Melissa, Max, and Yvette.
Q. And what, if anything, were you asked to do during the Rule
of Law fundraiser on Guo Media?
A. So we were asked to transfer money from one company or one
entity to the other so that we could take screenshots of these
money movements and broadcast them live on TV.
Q. And what companies were you asked to move money from during
the Rule of Law telecast?
A. It was mainly Saraca and Golden Spring.
Q. Who asked you to move money from Saraca and Golden Spring's
accounts during the Rule of Law fundraiser?
A. Yvette did.
Q. What, if anything, did Yvette say was the purpose of moving
money from Saraca and Golden Spring's accounts during the Rule
of Law fundraiser?
A. So the final purpose was to have these big amounts of money
shown on screen so that people would see that others were
donating, and we were able to solicit more money this way.
Q. Where did the Saraca and Golden Spring money that you were
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asked to move that day come from?
A. I don't know.
Q. And where were you asked to transfer the Saraca and Golden
Spring money during the Rule of Law fundraiser?
A. At the office.
Q. I'm sorry. Where were you asked to transfer those funds,
from Saraca and Golden Spring to where?
A. Oh, sorry. To Rule of Law.
Q. What was your reaction to the request from Yvette to move
the Saraca and Golden Spring money during the fundraiser?
A. I didn't want to do it.
Q. Why didn't you want to do it?
A. Because those transfers were not real; those were internal
transfers. It was not real money coming in, so I didn't agree
with that.
Q. And what was Yvette's response when you told her that you
didn't agree with moving that money during the fundraiser?
A. She saw that I was upset. And she told me that, Okay,
don't do it; somebody else is going to do it.
Q. Did somebody else do it?
A. Yes.
Q. And who was that?
A. Melissa and Max were doing it.
Q. You said earlier that Rule of Law ultimately did nothing to
help people in China. What happened when the Rule of Law board
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met?
A. We only met once as a board meeting in January of 2020.
And in that occasion, we discussed things to do or to be done.
But prior to that, we never really sat down as board members.
Q. Other than that in-person meeting, how often would you
communicate with other Rule of Law board members?
A. Not too often.
Q. What, if anything, did the board vote on?
A. Nothing really.
Q. Did there ever come a time that you cast a vote as a board
member in Rule of law?
A. Yes.
Q. What was Mr. Guo's title at Rule of Law?
A. He was sponsor.
Q. And what position did he have, if any, on the Rule of Law
board?
A. He didn't have any.
Q. Who was in charge of the Rule of Law board?
A. Boss was.
Q. You said there came a time that you cast a vote as a board
member. What was the subject of that vote?
A. It was in 2020. So after COVID hit, there was like a
proposal to purchase PPE and ship it to China.
Q. You said there was a proposal to purchase PPE. What is
PPE?
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A. In this very case it was masks.
Q. What kind of masks?
A. N95 masks for COVID masks.
Q. Whose proposal was it for Rule of Law to purchase N95
masks?
A. Boss's.
Q. And where in that proposal were the masks? What was to be
done with the masks in that proposal?
A. So they were to be shipped to China.
Q. How did you vote in that proposal?
A. I voted no.
Q. And, Ms. Maistrello, after you voted no on Mr. Guo's
proposal for Rule of Law to ship N95 masks to China, what
happened next?
A. Our paralegal came --
MS. SHROFF: Objection.
THE COURT: Overruled. You may answer.
MS. SHROFF: Your Honor, the government is eliciting
hearsay. We have an objection.
THE COURT: If you'll step up, please.
(Continued on next page)
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(At sidebar)
THE COURT: So I need a ruling that co-conspirator
hearsay could come in. Isn't that what you're asking for?
MR. HORTON: It comes in under that exception, your
Honor; it comes in under the agency exception. She's
testifying about official business, the Rule of Law
organizations. Paralegal is a classic agent.
MS. SHROFF: The paralegal is in a conspiracy with
this witness and with Miles Guo to send PPE masks to China
without having established how that falls within the scope of
this conspiracy.
The statement they want to elicit is the paralegal
asking this lady if it was, in fact, a mistake that the masks
are being in China. Through that statement they want the jury
to conclude, of course, that there would be no reason to send
these masks to China. How the paralegal becomes a participant
in this conspiracy is unclear to me; nor is it clear to me how
this person becomes a member of that conspiracy.
THE COURT: I don't know that they're holding her out
as a co-conspirator.
Go ahead.
MR. HORTON: I would just say set aside the
co-conspirator exception for one moment. Paralegal is an agent
of the organization. The paralegal is also asking a question.
A question is not hearsay; it's not a substantive statement.
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It's black letter that a question is not offered for its truth,
so it's not hearsay.
Setting that aside, this fills in the context of
testimony that's already been elicited that there was a
proposal to a specific thing by a specific person, and there
was a vote on that proposal. This detail is about what
happened at the conclusion of that vote and it completes the
story.
MS. SHROFF: Completing the story does not help the
argument that it is hearsay. She is not an agent of Mr. Guo.
It should be very clear. She is an employee of Rule of Law
Foundation. They have, in fact, established that he had no
position at Rule of Law. She's testifying as an agent of the
Rule of Law Foundation. And therefore, if they want to bring
this out when Rule of Law is part of a criminal action, then
her statement would fall within a hearsay exception. Here, it
would not.
MR. HORTON: Rule of Law is in the indictment.
Second thing is that she -- it's true that the witness
testified that Mr. Guo had a title at Rule of Law; it's also
true that she testified that despite that, he controlled it.
MS. SHROFF: She is not an agent of --
THE COURT: Here's my ruling: The objection is
overruled.
(Continued on next page)
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(In open court)
BY MR. HORTON:
Q. Ms. Maistrello, you said that Mr. Guo did not have a title
at the Rule of Law Foundation?
MS. SHROFF: I believe she's asked and answered that
question several times, your Honor.
THE COURT: We've already established that.
Move forward, please.
Q. Did Mr. Guo have a title at Saraca?
A. No.
Q. Did Mr. Guo have a title at Golden Spring?
A. No.
Q. Why not?
MS. SHROFF: Objection.
THE COURT: Overruled. You may answer.
A. I don't know.
Q. Did Mr. Guo have -- withdrawn.
Turning back to your vote against the proposal to send
the N95 masks to China, you said that after you voted no, a
paralegal asked you a question. What was the question that the
paralegal asked you?
A. She asked me whether it was a typo.
Q. How did Rule of Law pay for those N95 masks that were sent
to China?
A. With the money from Rule of Law.
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Q. Where did that money come from?
A. From donations.
Q. Ms. Maistrello, when else, if ever, did Rule of Law buy N95
masks with donor funds?
A. In 2020, so when COVID hit.
Q. And what did Rule of Law do with those other N95 masks that
it bought with donor funds?
A. So part of it went to boss's house, we kept a couple of
boxes at the office, and another part of it was distributed to
NYPD precincts around the city.
Q. Why did you vote against the proposal to send N95 masks to
China with donor money?
A. Well, because N95 masks were manufactured and produced in
China; so it didn't make any sense to me that we bought them
from China and then we would ship them back to China.
Q. And you said that masks were also sent to Mr. Guo's home.
Which home was that?
A. To the one in Connecticut.
Q. And when were those masks sent to Mr. Guo's home?
A. Around March of 2020.
Q. Who made the decision to use Rule of Law donor money to
send those N95 masks to Mr. Guo's home?
A. Boss did.
Q. You said that Rule of Law donor money was also used to send
masks to the NYPD. What role, if any, did you have in sending
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those masks to the NYPD?
A. I was asked by Yvette to draft a letter to accompany those
masks. The letter should have read something along the lines
of: This is a gift from Miles Kwok.
Q. And what did you do when you were asked to write a letter
saying that those masks were a gift from Miles Kwok?
A. I told her that I could write the letter, but that I
wouldn't sign it with the name of -- with boss's name.
Q. And why wouldn't you sign it with Mr. Guo's name?
A. Well, because it was not discussed with the other members
of the board and it was not a direct gift from him, but it
was -- those masks were paid with Rule of Law money.
Q. And what, if anything, did Yvette say when you said you
wouldn't write a letter that said those masks came from Miles
Guo?
A. She told me that I was being paid to execute orders and not
to think.
Q. How much were you paid a year when you worked for Mr. Guo?
A. 60.
Q. What amount, if any, was listed as your salary on your
offer letter?
A. That was 90.
Q. And what, if anything, explains the difference there?
A. I was told by Yvette that the company preferred to pay a
lower salary on a monthly basis and a higher bonus at the end
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of the year, that it would top it up.
Q. Including your bonus, what was your total pay at the end of
the year?
A. I believe my bonus on January of 2019 was 5,000.
Q. And including that amount, how much did you make in a year
working for Mr. Guo?
A. 65.
MR. HORTON: May I have one moment, your Honor?
THE COURT: Yes.
(Counsel conferred)
MR. HORTON: Thank you, your Honor.
Q. Ms. Maistrello, in your two years working for him, what, if
anything, did Mr. Guo tell you about his lifestyle in China?
A. In China, he had a lot of connections. He knew a lot of
people. When he talked about China, he usually -- he was very
proud of his achievements. He would -- he would often talk
about his hotel, he would talk about the staff there, he would
talk about the design, how he designed it. He was generally
very proud of it.
Q. And what did you understand Mr. Guo to mean when he told
you about his connections in China?
A. When he talked about his connections in China, he knew a
lot people, and so he would sometimes talk about what these
people did. He knew a lot about them.
Q. And who were these people?
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A. All sorts of people really. Businesspeople, ministers. He
knew a lot of people.
Q. And what do you mean by "minister"?
A. So government ministers. It could be the minister of the
interior, minister for development, for education. Various
ministries.
Q. You said he talked to you about his hotel in China. What
did he tell you about it?
A. He described the hotel, the interior, the exterior; he
talked about his staff there, how things were run. He was
generally very, very proud of it.
Q. And what, if anything, did he tell you about the status of
the hotel during the time you were working with him?
A. Can you repeat the question?
Q. Yes. What, if anything, did Mr. Guo tell you about the
status of his hotel in China during the time you were working
with him?
A. The status of the hotel while he was in the U.S.?
Q. Yes.
A. The hotel was still running.
Q. What, if anything, did Mr. Guo tell you about when he came
to the United States?
A. Well, before coming to the United States, he went to Hong
Kong, so he was there first.
Q. And what, if anything, did he tell you about when he came
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from Hong Kong to the United States?
A. He left Hong Kong in 2015 and he relocated to New York.
Q. And what, if anything, did Mr. Guo tell you he was doing in
the period between when he got to New York in 2015 and when you
started working for him a few years later?
A. He was -- what he said is that he was preparing or getting
ready for his fight against the Chinese government.
Q. And what, if anything, did Mr. Guo tell you that getting
ready meant? What did that entail?
A. Mainly, he broadcast. That's what he did.
Q. And what, if anything, Ms. Maistrello, did you observe
about how Mr. Guo's lifestyle changed in the United States?
MS. SHROFF: Assumes facts not in evidence, your
Honor.
MR. HORTON: I can lay a foundation for it.
THE COURT: All right. One moment, please.
Go ahead. The objection is sustained.
MR. HORTON: Thank you, your Honor.
BY MR. HORTON:
Q. Ms. Maistrello, other than the broadcasting, what actions,
if any, did Mr. Guo take while you were working for him for
that fight against the CCP?
A. Nothing really, other than putting together people for his
fight.
Q. You said that Mr. Guo asked you to buy things -- withdrawn.
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O5TVGUO3 Maistrello - Cross
Ms. Maistrello, you said that you donated $500 to the
Rule of Law Society. If you could do that again, would you
have donated your money to Rule of Law?
A. With the knowledge I have today, no.
Q. And why not?
A. Because that money wasn't used for anything that I believed
in really.
MR. HORTON: Can I have one moment, your Honor? I'm
sorry, could I have just one moment, your Honor?
THE COURT: Yes, yes.
MR. HORTON: Thank you.
(Counsel conferred)
MR. HORTON: Thank you, your Honor.
No further questions.
THE COURT: Cross-examination.
MS. SHROFF: May I, your Honor?
THE COURT: You may.
MS. SHROFF: Thank you.
CROSS-EXAMINATION
BY MS. SHROFF:
Q. Ms. Maistrello, where did you go to college?
A. College in Rome, Italy.
Q. Okay. And after you studied in Rome, where did you study
next?
A. In China.
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Q. And you were in China for almost five or more years;
correct?
A. From 2012 to 2017.
Q. And you were working while you were in China; correct?
A. Yes.
Q. And you were there with your husband; correct?
A. No.
Q. Did you get married after you left China?
A. Yes.
Q. And what do you do for a living now?
A. I work for Google.
Q. I'm sorry?
A. I work for Google. Google. Google Search.
Q. You work for Google?
A. Yes.
Q. Okay. And your husband is a professor; correct?
A. That's correct.
Q. And he's a professor at a university in New York; correct?
A. NYU, yes.
Q. And is it fair to say that when you accepted a job at
Golden Springs, part of the reason you were hired is because
you spoke Mandarin; correct?
A. Yes.
Q. Right.
And you were first initially hired as a translator,
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right?
A. Yes.
Q. And it came a point where there was some unhappiness with
your level of translation, so they brought in outside
translators to translate for meetings; correct?
A. No.
Q. Well, you didn't translate at formal meetings; correct?
A. I did.
Q. I really can't hear you. You did not. The answer is you
did not, right?
A. The answer is I did.
Q. The answer is you did translate for formal meetings;
correct? That's your testimony?
A. Yes.
Q. Who's Una Wilkinson?
A. She was hired as an external translator in late 2019.
Q. Right.
And she was brought in then to translate meetings
where other people were present; correct?
A. Yes.
Q. Right.
And you were not used during those meetings for your
translation skills; correct?
A. Correct.
Q. Right.
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Now, you testified that you were an employee of Golden
Springs New York, right?
A. Golden Spring, not springs. But yes.
Q. Okay. Golden Spring New York, right?
A. Golden Spring New York.
Q. And there is an entity called Golden Spring Hong Kong;
correct?
A. Right.
Q. And Golden Spring Hong Kong is the entity above Golden
Spring New York, right?
A. I don't know if it's above.
Q. You don't know if it's above.
Are you aware as to where the funds into Golden Spring
came from?
A. No.
Q. Do you know who put money into the Golden Spring New York
account?
A. Yes.
Q. Who?
A. Yvette did.
Q. You think Yvette put her personal money into the Golden
Spring New York account?
MR. HORTON: Objection.
THE COURT: Overruled. You may answer.
A. Not her personal money, no.
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Q. Okay. My question was whose money was in Golden Springs
New York?
A. I don't know.
Q. Okay. And you certainly don't know whose money was in
Golden Spring Hong Kong; correct?
A. Correct.
Q. And you don't know how many billions of dollars there was
in Golden Spring Hong Kong; correct?
A. I don't know.
Q. And you don't know how many millions or billions or
hundreds of thousands of dollars --
MR. HORTON: Objection, your Honor.
Q. -- that was in Golden Spring New York; correct?
THE COURT: Overruled. You may answer.
A. Can you repeat the question, please.
Q. Sure. You do not know how many billions, millions or
hundreds of thousands of dollars there was in Golden Spring New
York; correct?
A. I don't know.
Q. Now, you heard about Mr. Guo when you worked in China;
correct?
A. Yes.
Q. You worked for an oil company, you testified, right?
A. That's correct.
Q. And did you work there as a translator or did you work for
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the oil company or something else?
A. No, I was working as something else.
Q. And what was that something else?
A. I had several titles. I left as director of
communications.
Q. Director of communications; correct?
A. Yes.
Q. And in your job in China, you socialized; correct?
A. Yes.
Q. You socialized with people who had money; correct?
A. I socialized with people.
Q. And some of them had money, right?
A. That I don't know.
Q. Some of them were rich; correct?
A. I don't know.
Q. Well, you went to parties, did you not?
A. No.
Q. You didn't go to a single party while you were in China?
A. What do you mean by "party"?
Q. A party, a social gathering, an event.
A. I went to dinners.
Q. Right.
And you went to dinners with well-heeled people in
your business field; correct?
MR. HORTON: Objection, your Honor.
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THE COURT: Overruled. You may answer.
A. I went to dinners with my colleagues.
Q. Right.
And when you went to dinners with your colleagues, you
had work-related dinners with people who were working with you
in the oil company; correct?
A. Yes, colleagues.
Q. Right.
And at that time, you had heard of something called
Pangu, right?
A. Yes.
Q. Tell the jury, please, what is Pangu?
A. Pangu is a building in Beijing, in the capital. It's a
Dragon-shaped building that was built around the Beijing
Olympics in 2008.
Q. It's a huge building, right?
A. It's quite big.
Q. It's a hotel, right?
A. Pangu Hotel is a hotel, yes.
Q. Seven-star hotel; correct?
A. It is called Seven Star Hotel. In fact, on the world
ranking it's five.
Q. It's in the world ranking of five out of seven, is that
your testimony?
A. Yes. So the name reads Seven-Star Hotel, but, in fact, due
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to, I don't know, hotel star ranking, it is a five-star hotel.
Q. It's a five-star hotel now. Back then it was a seven-star
hotel?
A. I don't know about now.
Q. Okay. So you know who owned Pangu, right?
A. When?
Q. When you were living in China, who did you think owned
Pangu?
A. I did not know at that time who owned Pangu.
Q. You did not know that Miles Guo's family owned Pangu?
A. When I was in China, no.
Q. Your testimony is when you were in China, you were unaware
of the owner of the Pangu hotel?
A. When I was in China, I knew he was a developer and he
developed the Pangu Hotel, but I did not know who the owner
was.
Q. Okay. So you at least knew he was the developer; correct?
A. I knew that, yes.
Q. Right.
And you testified on direct, did you not, that there
came a time when Mr. Guo showed you pictures of his homes in
China; correct?
A. Yes.
Q. And each home was affluent; correct?
A. I saw one.
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O5TVGUO3 Maistrello - Cross
Q. You only saw one home?
A. I saw -- yes. Correct.
Q. And it was a humongous property; correct?
A. I can't say.
Q. It's a traditional Chinese property that has a courtyard;
correct?
A. Yes.
Q. And alongside the courtyard are different homes; correct?
A. Different structures, yes.
Q. And each structure is for one part of the family; correct?
A. Traditionally, yes.
Q. And traditionally, that's the culture; each brother had a
home around the courtyard. Correct?
MR. HORTON: Objection, your Honor.
THE COURT: Overruled. You may answer if you know.
A. Traditionally, so parents live together with the son and
the family. And then other family members, if any, would be in
the surrounding properties.
Q. Right. And he told you that's how he and his family lived
in China; correct?
A. Yes.
Q. And when he told you that, he was talking nostalgically
about his life in China when he lived there; correct?
A. I wouldn't say nostalgically.
Q. Really. Was it with hatred?
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O5TVGUO3 Maistrello - Cross
MR. HORTON: Objection.
THE COURT: Overruled. You may answer.
A. He was just talking about it.
Q. He was talking about his family, right?
A. He was talking about his home.
Q. Right.
And when he was talking to you about his home, he was
in his office, right?
A. Sometimes in the office, sometimes in his home.
Q. And he was just having a regular employer/employee
conversation with you, right?
A. Yes.
Q. Okay. Your employment, am I correct, was with Golden
Spring.
MS. SHROFF: If I could just have her employment
contract up, please.
Q. Is that correct, ma'am?
A. Can you repeat the question, please?
Q. Sure. You had an employment contract, did you not, with
Golden Spring?
A. Yes.
Q. Okay. And part of that employment contract -- the
government showed it to you on direct, right?
A. Yes.
Q. And it's a one-page contract; is that correct?
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O5TVGUO3 Maistrello - Cross
MS. SHROFF: It's GX B-871. There you go. Thank you
so much.
Q. If I could just have you take a look at the document,
please.
MS. SHROFF: May I also have it published for the
jurors, please.
Q. That was the contract; is that right?
A. This was the offer letter.
MS. SHROFF: Okay. And if you could just scroll down,
all the way down.
Q. And you signed it; correct?
A. Yes.
Q. You signed it on February 13 of 2018; correct?
A. Yes.
Q. And the letter says, of course, that you've reviewed it,
you agree to the terms and conditions, and then you signed it,
right?
A. Yes.
Q. I mean, you read it, right?
A. I did.
Q. Okay. Let's just go back up for a minute, okay?
You picked your own start date, I'm assuming, or you
arrived at a start date that was convenient for you, which was
February 19, right?
A. I don't remember that.
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O5TVGUO3 Maistrello - Cross
Q. Okay. Your title was to be project assistant and
interpreter, remember that?
A. I can see that, yes.
Q. Right. I didn't ask you whether you saw it, I asked you if
you remember that. You remember that's what you were hired
for; correct?
A. I remember that I was hired as an interpreter.
Q. Okay. It says project assistant and interpreter, right?
A. Yes.
Q. Okay. You didn't scratch out project assistant, right?
A. I did not.
Q. Okay. And it said clearly that you were going to be
employed by Golden Spring New York Limited, right?
A. Yes.
Q. And then it tells you a couple of bullet points down, the
offer letter is for employment at will; correct?
A. Yes.
Q. And employment at will is explained to you in this
document, right?
A. Yes.
Q. And, in fact, it tells you right there that you are free to
terminate your employment with them as you see fit; correct?
A. Yes.
Q. Doesn't even tell you you have to give two weeks' notice;
correct?
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O5TVGUO3 Maistrello - Cross
A. It does not.
Q. Right.
You could have walked out of that job any day you felt
like, right?
A. Yes.
Q. Right.
You didn't like something that was going on, you could
have left, right?
A. Yes.
Q. Okay. And you met with these prosecutors how many times to
prepare for your testimony here?
A. I don't remember the number of times.
Q. You don't remember the number of times that you met with
them?
A. No.
Q. And do you remember who you met with?
A. Yes.
Q. Who did you meet with?
A. Do you want the names?
Q. Sure.
A. Justin Horton, Ryan Finkel, Juliana Murray, and Micah
Fergenson.
Q. And the gentleman who asked you the questions today, he
reviewed this document with you to prepare you, right?
A. He showed me this document.
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O5TVGUO3 Maistrello - Cross
Q. Well, he didn't just show it to you, right, he went over it
with you, right?
A. He showed it to me.
Q. He didn't review the terms of the document with you?
A. No.
Q. You were first contacted by the government in August of
2023, remember that?
A. I do.
Q. And then you were contacted again on August 14, remember
that?
A. I don't remember the dates.
Q. How about January 16th?
A. I don't remember the dates.
Q. January 25th?
MR. HORTON: Objection, your Honor.
THE COURT: Overruled. You may continue.
A. I don't remember the dates.
Q. May 24th?
A. I don't remember the dates.
Q. May 15th?
MR. HORTON: Objection, your Honor.
THE COURT: Overruled. You may continue.
A. I don't remember the exact dates.
Q. May 9th?
A. I don't remember the dates.
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O5TVGUO3 Maistrello - Cross
Q. May 20th?
A. I don't remember the dates.
Q. How about yesterday? Do you remember yesterday?
A. Yesterday I was here.
Q. And you met with them, right?
A. Yes.
Q. With Mr. Horton sitting right there, the man who asked you
questions, right?
A. Yes.
Q. How many hours?
A. A few minutes.
Q. Okay. How about the day before?
A. On Monday?
Q. I'm sorry?
A. Are you referring to Monday?
Q. Am I referring to me?
A. Monday, are you referring to Monday?
Q. Yes.
A. We met on Monday.
Q. You met on Monday, right? Monday was a federal holiday?
A. It was.
Q. Right.
Where did you meet?
A. We met at 26 Fed.
Q. They picked you up at the train station?
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O5TVGUO3 Maistrello - Cross
A. No.
Q. Okay. You got to 26 Federal Plaza and you sat down and met
with them, right?
A. Correct.
Q. They went over your testimony?
A. No.
Q. No? They didn't tell you what questions they were going to
ask you?
A. They asked me some questions.
Q. Right.
They went through a whole series of questions, just
like they did in court today, right?
A. Not exactly.
Q. Well, no, not exactly. But they sat down and asked you a
whole bunch of questions, right?
A. They asked me questions.
Q. Right.
And then they took notes, right?
A. They did.
Q. They took -- they showed you photographs, right?
A. They showed me some photographs, yes.
Q. They showed you the same photographs here today; correct?
A. I don't remember exactly.
Q. And did they then tell you how somebody like me would
cross-examine you?
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O5TVGUO3 Maistrello - Cross
A. They explained how it works, yes.
Q. They did, right? They told you what questions would come
at you on cross-examination; correct?
A. No.
Q. They didn't tell you what questions would come, what you
should anticipate at cross?
A. They explained to me how it works.
Q. Right.
They told you that a lawyer for Mr. Guo would ask you
questions, right?
A. Yes.
Q. And they helped you prepare on how to answer, right?
A. No.
MS. SHROFF: Okay. Let's see if we can pull up
Government Exhibit 141.
Q. They showed you this photograph, did they?
A. One time they did.
Q. Right.
I won't ask you which one of the many preps they
showed you the photograph in, but they showed you this
photograph, right?
A. Yes.
Q. And this photograph was taken by whom, ma'am?
A. We had about seven, between photographers and
videographers, for a photo shoot.
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O5TVGUO3 Maistrello - Cross
Q. Right.
And you were not the only person in the photo shoot,
right?
A. No.
Q. There were other people in the photo shoot, right?
A. Yes.
Q. And it was a professional agency that took the photos,
right?
A. Yes.
Q. And the photos was -- they were going to be used for a
particular launch; correct?
A. Correct.
Q. And this was not unusual, right?
A. A photo shoot only happened once, in fact.
Q. It's only happened once while you were working there,
right?
A. Can you repeat the question?
Q. Sure. It only happened once, as far as you know, during
the time you were working there, right?
A. During the time I was working there it happened once.
Q. Right.
And you worked there, all told, how much? About two
years?
A. More than two years.
Q. How many more? Two and a half years?
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A. Approximately.
Q. Approximately two and a half years.
And it's fair to say, right, you correct me if I'm
wrong, you left because of medical reasons, right?
A. That is correct.
Q. Right.
And you decided COVID was coming and you did not feel
well, right?
A. No.
Q. Well, COVID was coming, right, when you quit?
A. COVID hit in February of 2020.
Q. Right.
You think COVID hit in February of 2020 or March of
2020?
A. It was either February or March.
Q. And you quit the month after, right?
A. Yes.
Q. Okay. And the reason you gave for quitting is because you
thought microwaves had attacked you, right? That's what you
told someone at Golden Springs?
A. No.
Q. Okay.
And you then stated that you had been hospitalized; is
that correct?
A. I was about to be.
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Q. Right.
And Yvette responded to you being sick; correct?
A. What do you mean by that?
Q. She sent you flowers, did she?
A. No, she did not.
Q. She did not.
And did she extend your insurance coverage to help you
while you were sick?
A. No, she did not.
Q. She did not provide you with COBRA benefits while you were
sick?
A. COBRA benefits were included, but she did not extend those
personally.
Q. She did not offer to you to extend them personally, is that
your testimony here today?
A. Correct.
Q. Okay. And you were in touch, were you not, with other
people who worked for Mr. Guo; correct?
A. When?
Q. Throughout your time after you quit working at Golden
Springs, right?
A. A few people reached out to me.
Q. Right.
And they reached out to you making sure you were well,
right?
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A. They asked me how I was doing.
Q. Right.
And included in that list is Melissa; correct?
A. Yes.
(Continued on next page)
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BY MS. SHROFF:
Q. A lawyer named Victor Cerda said you should get medical
help and feel better, correct?
A. I don't remember that.
Q. Okay. And Max Krasner reached out to you, correct?
A. Yes, he asked me how I was.
Q. And somebody named Dan Podhaskie also reached out to you,
correct?
A. Yes.
Q. Now these are all people that you knew from working there,
correct?
A. Yes.
Q. Okay. So you knew——let's just go through the list.
Yvette; is that right?
A. Yes.
Q. You knew Dan Krasner, correct?
A. Max.
Q. Max Krasner.
A. Max Krasner.
Q. Sorry. I mix up names all the time.
Max Krasner, correct?
A. Yes.
Q. Dan Podhaskie, correct?
A. Yes.
Q. You don't like Dan Podhaskie, right?
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A. That's not true.
Q. Really? Didn't you complain about him hitting on you one
day?
A. No, I did not.
Q. You did not complain to Yvette Wang that he had hit on you
during a trip to Washington, DC?
MR. HORTON: Objection, your Honor. Asked and
answered.
THE COURT: Sustained.
Q. Did you take a trip with Dan Podhaskie to Washington, DC?
A. No.
Q. You did not take a trip with Dan Podhaskie to Washington,
DC for business; that's your testimony?
MR. HORTON: Objection, your Honor. Asked and
answered.
THE COURT: Sustained.
Q. It's fair to say you didn't like Dan Podhaskie, right?
MR. HORTON: Objection, your Honor. Asked and
answered.
THE COURT: Sustained.
Q. Did you have a positive working relationship with
Mr. Podhaskie?
MR. HORTON: Objection your Honor. Asked and
answered.
MS. SHROFF: I did not ask that.
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THE COURT: You may answer that.
A. We had a good working relationship.
Q. I'm sorry?
A. We had a good working relationship.
Q. What was your working relationship with him?
A. We were colleagues.
Q. Okay. And as colleagues, how did you interact with each
other?
A. We talked.
Q. Okay. Talked about what?
A. Work.
Q. What work?
A. Work at the office.
Q. Work at the office. What work at the office?
A. He would come to me to ask for something, or whenever he
needed a translation, I would help him out. Work-related talk.
Q. And you've testified at great length about your
relationship with Yvette, correct?
A. I didn't testify to great length. I answered questions
that I was asked.
Q. Okay. And Yvette's full name is——did you call her Yvette
or did you call her Ms. Wang or how did you refer to her?
A. I——I used her first name.
Q. You called her Yvette, right?
A. Her Chinese first name.
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Q. And was that?
A. Yanping.
Q. You referred to her as Yanping when you talked to her?
A. Yes.
Q. Okay. But when you talked to the government about her, you
called her Yvette, right?
A. I don't remember.
Q. Okay. Well, let's talk about your interactions with her,
okay?
You testified that she was the one who conducted the
first job interview, right?
A. Yes.
Q. And when she interviewed with you, where were you located?
A. The first interview happened at the Plaza Hotel.
Q. Okay. And no reason was given to you as to why the
interview was at the Plaza Hotel, correct?
A. No.
Q. It was an everyday job interview, correct?
A. It was a job interview.
Q. Right. And you had been sent there by somebody named Steve
Weber, right?
A. Yes.
Q. And Steve Weber is a headhunter, correct?
A. I don't know if he is today. He was at that time.
Q. Right. And you filled out a job——or an application to get
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a job through his company and that's what happened, right?
A. He had reached out to me.
Q. Right. And you testified about the second interview was
with Mr. Guo, correct?
A. Correct.
Q. Now when you went to that second interview, they didn't
send you a memo or a notice saying you have a job interview
with Boss, right?
A. I don't remember that.
Q. They told you you had a job interview and the interview was
with a person named Mr. Guo, right?
A. I don't remember the specific name they used.
Q. So you don't remember if they referred to him as Mr. Kwok,
correct?
A. I don't remember, no.
Q. You don't know if they referred to him as Mr. Guo, correct?
A. I don't remember.
Q. Is it fair to say that they did not refer to you——refer to
him as Boss when they set up the interview?
A. I don't remember.
Q. Okay. You sent out emails as part of your job, correct?
A. Yes.
Q. Internal emails, correct?
A. Yes.
Q. And external emails, correct?
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A. Yes.
Q. And you sent out external emails to agencies, correct?
A. What do you mean by agencies?
Q. Businesses, right? You sent out external emails to
businesses, right?
A. Yes.
Q. Okay. And you referred to Mr. Guo as either Mr. Guo or
Mr. Kwok in your emails, correct?
A. No. I would never refer to him as Mr. Kwok.
Q. Well, if you were emailing with that fancy place in Italy
about the furniture, how would you refer to him?
A. Mr. Guo.
Q. Mr. Guo, right? You wouldn't call him Boss in your email,
right?
A. I——I would definitely call him Mr. Guo.
Q. Right. And when you advertised your past job experience at
Golden Spring, you don't say, I worked for Boss, right, you
say, I worked for a man named Miles Guo, correct?
A. I don't really advertise. I never advertise his name.
Q. How about on LinkedIn? Do you say, I worked for a man
named Boss?
A. No.
Q. Okay. So the only time you consistently referred to him as
Boss is when you're testifying here or when you are talking
internally at the office, correct?
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A. So I would call him Boss in Chinese when I talked to him
directly and Boss when I referred to him with my colleagues.
Q. And this courtroom setting is neither you talking to
Mr. Guo nor you talking to any of your colleagues, correct?
A. That's correct.
Q. This is a formal proceeding, correct?
A. It is.
Q. And you referred to him throughout your testimony as Boss,
correct?
A. Yes.
Q. Okay. Now if I could have you recall your testimony about
Government Exhibit 102, please.
This is Yvette, correct?
A. It is.
Q. Right. And according to you, during your interview with
Yvette, she, Yvette Yanping Wang, asked you what your
connection was to CCP; is that right?
A. Yes.
Q. Right. It's fair to say, right, you cannot be part of the
CCP because you are simply not a Chinese national, correct?
A. That's correct.
Q. You cannot be part of the CCP without being a Chinese
national, correct?
A. That is correct.
Q. And Ms. Wang of all people would most certainly know that
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basic fact, correct?
A. Yes.
Q. There is no way Ms. Wang ever asked you during a job
interview if you belonged to the CCP; isn't that correct?
MR. HORTON: Objection, your Honor.
THE COURT: I'll let you answer. Go ahead.
A. She never asked me if I was a party member. She asked me
if I knew people who were party members.
Q. She asked you if you knew anyone who was a party member; is
that your testimony?
A. She asked me if I knew people who were party members.
Q. Did she explain to you what "knew" means?
A. What do you mean "knew"?
Q. Well, I know you now. That doesn't mean I actually know
you, right?
MR. HORTON: Objection, your Honor.
THE COURT: Don't testify.
MS. SHROFF: I'll move on.
Could you show her Government Exhibit 130, please.
Q. You testified about this building, correct?
A. Yes.
Q. This is the Sherry-Netherland, right?
A. It is.
Q. They showed you this photograph during your preparation,
correct?
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A. I don't remember.
Q. Okay. Mr. Guo lived on the 18th floor of this building,
correct?
A. Yes.
Q. Penthouse, correct?
A. Yes.
Q. It's gigantic; isn't that true?
A. It's big.
Q. Right. It has a recording studio in there, correct?
A. What do you mean by recording studio?
Q. A place from where he broadcast, correct?
A. That was an office.
Q. Right. There was a——there was an actual office set up in
that home, correct?
A. Yes.
Q. Okay. Could you try and keep your voice up. That would
really help me out, please.
A. I'll do my best.
Q. Thank you.
And there was security in that building, correct?
A. The building has staff that lets people in and out.
Q. Right. 24-hour staff that lets people in and out, correct?
A. Yes.
Q. You couldn't go up to that 18th floor unless somebody in
that floor said you could come up, correct?
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A. Yes. My name was on the list.
Q. Exactly. And the only reason you could go up is because
your name was on that list, correct?
A. Yes.
Q. And that was because Mr. Guo wanted to have security for
himself and his family, correct?
A. The security apparatus belongs to the hotel.
Q. And he's the one who puts your name on that security
apparatus, correct?
A. I don't know if he is the one, but my name was there.
Q. Okay. And is it fair to say that there is security
apparatus in that building 24/7?
A. I believe so.
Q. And there's security apparatus in the garage 24/7, correct?
A. That I don't know.
Q. Okay. And sitting here today, you have no idea, do you,
whether or not he picked that building because he wanted to
make sure that he lived in a building with 24-hour security;
you simply don't know, correct?
A. The reasons why he picked that building, he knows.
Q. Exactly. You don't know, right?
A. I do not.
MS. SHROFF: You may take that down. Thank you.
If somebody could show her UK723, please.
Q. You testified about this photograph, correct?
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A. Yes.
Q. Okay. Let's go through them.
You see Mr. Guo seated there, correct?
A. I do.
Q. And who is to his left?
A. His wife.
Q. And do you know for how many years she was held in prison
because she was married to Mr. Guo?
MR. HORTON: Objection, your Honor.
THE COURT: Sustained.
Q. Do you see the person seated to her left?
A. I do.
Q. Who is that?
A. That's Yvette.
Q. And do you know how many years Yvette was held in prison in
China?
MR. HORTON: Objection, your Honor.
THE COURT: Sustained.
Q. And who is the person seated right across from Mr. Guo?
A. His daughter.
Q. Okay. And his daughter now lives in the United States,
correct?
A. Until I was working, so in 2020, she was in the United
States.
Q. And you knew her from work, right?
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A. She came to the office.
Q. She sent you a Christmas gift each Christmas, right?
A. She bought Christmas gifts for all of us at the office.
Q. Every employee, correct?
A. I don't know if every employee got it.
Q. Okay. Mr. Guo got you gifts, right, while you worked for
him?
A. For Chinese New Year.
Q. Your testimony is that the only gift you got from Mr. Guo
was on Chinese New Year?
A. Twice. On two separate Chinese New Years.
Q. Okay. Do you remember getting a gift of an Hermès puffer
jacket?
A. Yes.
Q. That was from him, right?
A. Correct.
Q. You accepted the gift, right?
A. I did.
Q. Where is Hermès, by the way? Where is it located?
A. The headquarters, you mean?
Q. No. I mean just the store.
MR. HORTON: Objection, your Honor.
THE COURT: Overruled. If you know where it is, let
us know.
A. On Madison.
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Q. Madison and what?
A. I don't remember the cross street.
Q. 67th?
A. I don't remember.
Q. How much do you think that puffer jacket cost?
A. I don't know.
Q. You'd agree with me, would you not, ma'am, that Hermès is a
very high-end store, correct?
MR. HORTON: Objection, your Honor. 401.
THE COURT: Overruled. You may answer.
A. Can you repeat the question, please.
Q. Sure. You would agree with me, would you not, that Hermès
is an extremely high-end store?
A. I agree.
MS. SHROFF: You may take that down.
Q. You now you testified, did you not, on direct about a
store——and forgive me, I don't remember the name. Promemoria,
or something like that?
A. Promemoria? Yes.
Q. Correct. Do you remember that store?
A. They don't have a store here.
Q. It's a company in Italy, correct?
A. Correct.
Q. It's a supplier, right; supplies leather, correct?
A. It's a furniture company.
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Q. And you can call them and get yourself some very expensive
furniture, correct?
A. Anybody can call them, yes.
Q. Right. Right. And you placed several orders with that
company, correct?
A. Yes.
Q. Right. And they were orders for furniture, correct?
A. Yes.
Q. And you would place the order, correct?
A. Correct.
Q. Who chose it, the furniture?
A. Boss did.
Q. Mr. Guo, right?
A. Yes.
Q. Okay. And Mr. Guo would choose the furniture and he'd ask
you to place the order, correct?
A. Yes.
Q. Okay. And you would place the order, right?
A. I would.
Q. Sometimes he'd change his mind about the order, right?
A. All the time.
Q. All the time; isn't that true?
A. Yes.
Q. Very frustrating, correct?
A. It was part of the job.
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Q. It was part of the——frustrating part of the job for you,
right?
A. It was part of the job.
Q. He would pick something, have you place the order, and then
have you cancel it, correct?
A. That happened.
Q. He would change his mind, correct?
A. Yes.
Q. He did that with that place, whatever it's called, Chateau
Ridge or something, right?
A. He initially wanted to purchase it and then he didn't.
Q. Right. And you spent a lot of time testifying about, you
know, that it was a palace and it had art and it had all of
this stuff. End of the day, he never bought it, correct?
A. He did not.
Q. Now let's talk about the Brioni suits that you ordered for
him, according to you. Did you order them for him?
A. Yes.
Q. Okay. Do you know how long he had been a customer of
Brioni, whether it had been for a decade or two decades?
A. Close to two decades.
Q. Two decades, right? It's 20 years?
A. Approximately.
Q. Right. So they knew him, correct?
A. They did.
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Q. Right? Because they'd been doing his suits for 20 years,
right?
A. They knew him.
Q. Okay. Who paid his bills 20 years ago; do you know?
A. I do not.
Q. Who paid his bills 10 years ago; do you know?
A. I do not.
Q. Who paid his bills for the suits now; do you know?
A. You mean today?
Q. Well, today you certainly don't know because you don't work
for him anymore, right?
A. That's correct.
Q. Right. So when you worked for him, who paid those bills?
A. Golden Spring.
Q. Golden Spring belonged to whom?
Sitting here today, you don't know whose money was
Golden Spring, right?
A. I know the name of the president, I know the name of the
chief operating officer.
Q. Okay. You don't know whose money went in there, right?
A. I do not.
Q. Right. And certainly you were never on the board when Rule
of Law Foundation put any money in there, correct?
A. What do you mean by that?
Q. You don't know any instance when any money from Rule of Law
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Foundation went into Golden Spring, correct?
A. I don't know that money from Rule of Law ever went to
Golden Spring. I don't know.
Q. I just wanted to make sure.
Now you said that they paid all of this money for his
suits, Golden Spring New York did, correct?
A. Yes.
Q. Okay. And they paid by what, check or transfer; do you
know?
A. It was usually a check.
Q. Okay. But you don't know, right?
A. I do.
Q. You do know, that it was paid by check.
A. Yes.
Q. Who was the check made out to, Brioni New York, Brioni
France, where?
A. Brioni New York on Madison.
Q. Okay. Now you also testified about cars, correct?
A. Yes.
Q. This man doesn't know how to drive, right?
A. He knows how to drive.
Q. You've seen Miles Guo drive a car.
A. Yes.
Q. On the streets of New York.
A. Just outside of New York.
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Q. Outside of New York. Your testimony is you know this man
to have driven a car outside, on a street.
MR. HORTON: Objection. Asked and answered.
THE COURT: Sustained.
Q. Do you know if he has a driver's license?
A. When I worked there, he did not. He only had a Hong Kong
driver's license yes.
Q. He didn't even have a learner's permit, right?
A. Do you mean a US learner's permit?
Q. Yes, ma'am.
A. At that time he did not.
Q. Okay. He was driven to work, correct?
A. Yes.
Q. He was driven from work, correct?
A. That's correct.
Q. And he was driven everywhere he went; he never drove a car
ever on a New York City street, correct?
A. He did once.
Q. Okay. Putting aside this once that you keep referring to,
he was driven back and forth everywhere he went, correct, while
you worked for him?
MR. HORTON: Objection, your Honor. Asked and
answered.
MS. SHROFF: I'll move on, your Honor.
THE COURT: You may answer.
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Q. True?
A. He was driven.
Q. Okay. And you talked about how he was talking about some
Rolls Royce that he had in China, correct?
A. Yes.
Q. He never got that Rolls Royce from China to the United
States, correct?
A. Not that I know of.
Q. I'm sorry. What?
A. Not that I know of.
Q. Exactly. He would talk about it and then he would just
abandon the project, correct?
A. It just wasn't possible to import that car so——
Q. Right. And same for the Lamborghini, right? No Rolls
Royce or Lamborghini was ever imported here, correct?
A. Not to my knowledge.
Q. You could only testify to your knowledge. So the answer is
no?
A. The answer is no.
Q. Okay. Now you also testified about a person named Hank,
correct?
A. Yes.
Q. Now Hank came from China with Mr. Guo, correct?
A. That's correct.
Q. Right. And Mr.——and Hank speaks absolutely no English,
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correct?
A. He does not.
Q. Right. And Hank used to live with Mr. Guo and his family,
correct?
A. They lived separately.
Q. You think Hank lived separately from the Guo family.
MR. HORTON: Objection. Asked and answered.
THE COURT: Sustained.
Q. You testified about Mr. Guo's son named Mileson, correct?
A. Yes.
Q. You've never personally met Mileson, correct?
A. I did.
Q. Where did you meet him?
A. At the office.
Q. At the office where?
A. 800 Fifth.
Q. And what year was that?
A. The first time I met him was 2018.
Q. And when was the second time you met him?
A. Can you repeat the question, please.
Q. When was the——take your time.
A. Thank you.
Q. You're welcome.
When was the second time?
A. In 2019.
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O5T1GUO4 Maistrello - Cross
Q. And you haven't met him since, right?
A. I believe the last time we met was 2019.
Q. Okay. And he didn't ask you to buy him any motorbikes,
right?
A. Not directly, no.
Q. The question was whether Mileson asked you to buy any
motorbike. The answer is no, correct?
MR. HORTON: Objection, your Honor. Asked and
answered.
THE COURT: Sustained.
Q. Mr. Guo didn't ask you to buy any motorbikes for his son,
correct?
MR. HORTON: Objection.
THE COURT: You may answer.
A. He did.
Q. He asked you to buy motorbikes for his son?
A. One specific——
Q. I cannot hear you.
A. One, one time.
Q. One time. And you never bought the bike, right?
A. I believe he bought it himself.
Q. I asked you if you bought the bike.
A. I did not.
Q. Okay. And when you say you believe he bought the bike, you
actually do not know if he ever bought a bike for his son,
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O5T1GUO4 Maistrello - Cross
correct; that's just your belief?
MR. HORTON: Objection, your Honor.
THE COURT: You may answer as to whether you know or
you believe.
A. I do not know.
Q. You would ask Yvette for payment, correct, on things that
Mr. Guo wanted you to buy?
A. For bigger amounts, yes.
Q. And it would be Yvette who would have to authorize the
payments, correct?
A. Yes.
Q. You had no ability to authorize any payment from any
entity, correct?
A. No, I only had a company's credit card.
Q. Right. My question was: You had no ability to authorize
payment at all, correct?
A. Authorize?
Q. Yes.
A. No.
Q. You could not say, Golden Spring is going to pay this bill,
correct?
A. It depended on the amount.
Q. Your testimony is that if it was a small amount from Golden
Spring that was being spent, you could have that paid through
Golden Spring?
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O5T1GUO4 Maistrello - Cross
MR. HORTON: Objection, your Honor. Mischaracterizes
her testimony.
THE COURT: Overruled. You may answer.
A. I placed orders through my company's credit card, so for
smaller amounts, yes.
Q. You would place the order, correct? Right?
A. Yes.
Q. The bill would go to Golden Spring, correct?
A. Yes.
Q. You don't know if it was paid or not, right?
A. Well, payments go through immediately, through the credit
card.
Q. You don't know if it was paid or not, correct?
A. I'm not——
MR. HORTON: Objection, your Honor.
THE COURT: Are you asking whether a transaction was
consummated or whether the credit card bill was paid?
MS. SHROFF: Whether the credit card bill was paid.
A. The credit card bill was always paid because I had the
money available.
Q. You mean the Golden Spring credit card has the money
available.
A. Yes.
Q. It's not your credit card, right?
A. My corporate credit card.
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O5T1GUO4 Maistrello - Cross
Q. Not your credit card, correct?
MR. HORTON: Objection, your Honor.
THE COURT: Sustained.
Q. Could you buy yourself something off that credit card?
A. Personal expenses?
Q. Yes.
A. No.
Q. Okay. Now you've talked about several entities while you
were testifying on direct, correct? We've already covered
Golden Spring, right? So let's talk about Saraca.
Do you have any understanding what Saraca was?
A. What I knew about Saraca was that all the expenses related
to tech or media went to Saraca.
Q. Okay. You don't know if Saraca was a holding company,
correct?
A. I do not.
Q. You don't know if it's a private company, correct?
A. I don't.
Q. You don't know where it's licensed or incorporated,
correct?
A. I do not.
Q. And then they asked you all these questions about some
other company called Genever, correct?
A. Genever?
Q. Sure. Do you remember your testimony about that?
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O5T1GUO4 Maistrello - Cross
A. Yes.
Q. Okay. You don't know anything about that company either,
right?
A. Structurally, no.
Q. Correct. You don't know who owns that company, correct?
A. I do not.
Q. You don't know if there's a board of directors of that
company, correct?
A. I don't.
Q. And you don't know where the money into that company comes
from, correct?
A. I do not.
Q. Only reason you could testify about it is because you
talked to the government about it in your preparation, correct?
MR. HORTON: Objection. Objection, your Honor.
THE COURT: Overruled. You may answer.
A. Can you repeat the question, please.
Q. It's okay. I'll move on.
Now you testified, did you not, that there were times
when you accompanied Mr. Guo and he would decide to purchase
something, correct?
A. Accompany him where?
Q. Well, you two worked together, correct?
A. I did not say that.
Q. Well, didn't you testify on direct that whoever was in
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O5T1GUO4 Maistrello - Cross
front of him would pay, right?
A. What I said is whenever Boss wanted to buy something——it
could be a TV, it could be a screen, it could be a monitor, it
could be a camera——the person Boss had in front of him in that
very moment, he would ask them.
Q. Okay. He would ask them to pay, correct?
A. He would ask them to buy. He wouldn't use the word "pay."
He would just say buy it.
Q. Right. And 30 minutes later he may change his mind,
correct?
A. He may.
Q. Okay. And when that happened, Golden Spring would pay,
correct?
A. Well, when he changed his mind, if he changed his mind,
maybe there was no need to purchase at all.
Q. Okay. Fair enough.
Now one of the other people you testified about on
direct was a person named Cao, correct?
A. Oh, Cao?
Q. Right. Is that right?
A. That's correct.
Q. Okay. And you testified——
MS. SHROFF: If you could just show her UK728, please.
Q. You testified about this photograph, correct?
A. I did.
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O5T1GUO4 Maistrello - Cross
Q. Okay. Do you know when this photograph was taken, by the
way?
A. When?
Q. Yes.
A. I don't.
Q. Do you know who took it?
A. I do not.
Q. You didn't take it, right?
A. I didn't.
Q. So the only way you could testify about this photograph is
because they showed it to you during your preparation?
MR. HORTON: Objection, your Honor.
THE COURT: Sustained.
Q. Did you see this photograph ever before the government
showed it to you?
A. No.
Q. No, right? What's the answer?
A. I've never seen——
MR. HORTON: Objection.
THE COURT: Asked and answered. Let's go.
Q. You've never seen it before, right?
MR. HORTON: Objection, your Honor. Asked and
answered.
THE COURT: Sustained.
Q. This photograph is taken at Chinese New Year, right?
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O5T1GUO4 Maistrello - Cross
MR. HORTON: Objection.
THE COURT: You may answer. If you know.
A. I don't know.
Q. Look at that red envelope in their hands. That's the
envelope given out at Chinese New Year, correct?
A. It could be.
Q. Right. And that's the traditional pose, right, when you're
before your elders in Chinese culture?
A. Yes.
Q. Okay. So that's a young man in a traditional pose getting
the red envelope from his elders, correct?
MR. HORTON: Object to the testifying, your Honor.
MS. SHROFF: It's a question.
THE COURT: You may answer.
A. You see exactly what you see, so you see two people sitting
on a chair and another person kneeling.
Q. And both people having red envelopes in their hand, right?
A. They do.
Q. Right. How many years did you live in China?
A. Five.
Q. Would you say you have some familiarity with the Chinese
culture?
A. Yes.
Q. And could you tell me what that experience of yours with
Chinese culture would lead you to conclude about this
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O5T1GUO4 Maistrello - Cross
photograph.
A. The first thing I would say is respect.
Q. Mm-hmm.
MR. HORTON: Is there a question pending?
MS. SHROFF: Well, her answer was "the first," so I
assumed she had a second point.
THE COURT: Is there anything else you want to say?
THE WITNESS: There isn't.
Q. And you testified about this gentleman who is seated on
his——I guess whatever posture that is, his——what is his
American name, by the way?
A. Wayne.
Q. Okay. And you testified that Wayne is dating Mr. Guo's
daughter; is that correct?
A. Right now, I don't know.
Q. Well, when you were part of the employment circle, he was
dating, according to you, Mr. Guo's daughter, correct?
A. Yes.
Q. And he did work for the company, correct?
A. For a period of time, yes.
Q. He painted——
MS. SHROFF: You can take that down. Thank you.
Q. You testified that he painted, moved furniture, and did all
kinds of handyman work, correct?
A. In 2018, yes.
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O5T1GUO4 Maistrello - Cross
Q. Right. And what about in 2019?
A. He went back to school.
Q. Right. And where did he go to school; do you know?
A. I don't remember.
Q. Do you remember if it was Baruch College?
A. I don't remember.
Q. Do you remember what he was studying?
MR. HORTON: Objection, your Honor.
THE COURT: You may answer, if you remember what he
was studying.
A. I don't remember.
Q. He was polite to you, correct?
A. He was.
Q. He drove Mr. Guo around, correct?
A. Correct.
Q. And when Mr. Guo was being driven around, is it fair to say
that there would always be two cars?
A. No.
Q. No? Could you describe for any one of——could you describe
for the jury what a car would look like in which he was being
driven around?
A. There were several cars.
Q. And each one of them had tinted glasses, correct?
A. Not each one.
Q. Not each one. Okay. And when he was driven around, you
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O5T1GUO4 Maistrello - Cross
said he had two teams, right? According to you, he had a
Chinese security team and an American security team; that was
your testimony?
A. Yes.
Q. And it was your testimony that you really thought, in your
opinion, that it was not a security team at all, correct?
A. That's correct.
Q. Okay. So let's start with the American team, okay?
Do you know how many people were on the American team?
A. The number varied 'cause people were coming and going.
Q. So you don't know.
A. It could be as little as two, up to six——
Q. You don't know if there were ex-NYPD employees or not,
correct?
A. I know.
Q. You do know.
A. I do.
Q. Okay. And how many were ex-NYPD employees?
A. All of them.
Q. All of them were ex-NYPD employees, correct?
A. Yes.
Q. Let's move to the Chinese team, as you called it. And you
said he was closer to them, correct, according to you?
A. Yes.
Q. That man is not fluent in English, right?
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O5T1GUO4 Maistrello - Cross
A. He became fluent.
Q. Really. You think Mr. Guo spoke English fluently in 2018?
A. Not in 2018.
Q. How about 2019?
A. A lot better.
Q. A lot better, right? And you're claiming under oath that
he went from 2018 of not speaking English to fluency in 2019?
MR. HORTON: Objection, your Honor.
THE COURT: Sustained.
Q. He spoke to you, when he spoke to you, in Mandarin,
correct?
A. Yes.
Q. He never spoke in English even though you are bilingual,
correct?
A. He never spoke English to me.
Q. Right. And when he spoke to his daughter, who also speaks
English, he spoke in Mandarin, correct?
A. That's correct.
Q. When he spoke to his wife, he spoke in Mandarin, correct?
A. Yes.
Q. And when he got messages in English, he would come to you
and play them and tell you to translate, correct?
A. Yes.
Q. He did not know how to email, correct?
A. That I don't know.
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O5T1GUO4 Maistrello - Cross
Q. Did you ever get a singular email from this man, in all the
time you worked for him?
A. No.
Q. And when he spoke to people around him, he spoke in
Chinese, right?
A. He spoke Chinese to Chinese people.
Q. The reason you were hired as a translator is because he
didn't speak English, correct?
A. In 2018, yes, correct.
Q. And you continued to work, according to you, for him as a
translator in 2019, correct?
A. That's correct.
Q. Okay. Now you also testified, did you not, about a person
called William Je? Am I pronouncing that correctly?
A. Yes.
Q. Okay. And you liked William Je, right?
A. I did.
Q. You had a good working relationship with him, right?
A. He was not around a lot, but whenever he was at the office,
yes.
Q. You liked talking to him, right?
A. Yes.
Q. And he talked to you, correct?
A. Yes.
Q. And he's the one who invited you to be on some board,
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O5T1GUO4 Maistrello - Cross
correct?
A. Yes.
Q. Mr. Guo didn't invite you, right?
A. That's correct.
Q. Okay. And Mr. Je is the one who talked to you about what
you would be doing on the board, correct?
A. Yes.
Q. And you had a choice, you could have been on the board,
correct?
A. Correct.
Q. Or you could have told him and said, gee, I'm not
interested, correct?
A. That is correct.
Q. Okay. And you decided that William Je's offer sounded
interesting to you so you accepted and you were on the board,
correct?
A. Yes.
Q. Okay. Mr. Je didn't tell you what he wanted you to do on
the board, correct?
A. He briefly mentioned investments, but nothing more than
that.
Q. Okay. And he didn't tell you anything about the
investment, correct?
A. He did not.
Q. He didn't tell you what type of investments they were,
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O5T1GUO4 Maistrello - Cross
correct?
A. That's correct.
Q. He didn't know if the investments were coming from Abu
Dhabi, correct?
A. Not specifically, correct.
Q. You didn't know if the investments were in the billions of
dollars; according to you, you knew nothing, correct?
MR. HORTON: Objection.
THE COURT: Sustained.
Q. Did you know if the investments were in the billions of
dollars?
A. I do not.
Q. And you decided you were going to be on the board anyway,
correct?
A. That's correct.
Q. Okay. And William Je did email people, right, unlike
Mr. Guo?
A. Can you repeat the question.
Q. Sure. William Je emailed about questions he had, right?
MR. HORTON: Object to form.
THE COURT: Did he email you?
A. Possibly.
Q. Well, you knew his email address, right?
A. Yes.
Q. Okay. You didn't email him and ask him any questions about
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O5T1GUO4 Maistrello - Cross
serving on this board, right?
A. No.
Q. Okay. And you decided that you were going to go ahead and
serve on the board, right?
A. Yes.
Q. Okay. And the only reason you decided you didn't want to
serve on the board is because that company got civilly sued,
correct?
A. I was not aware of that at the time.
Q. Right. But once you became aware, you were like, I'm out,
right?
A. I heard something, so I didn't have the details, but I
heard——if you want to call them rumors.
Q. Right. And when you heard, you wanted out, right?
A. That's correct.
Q. Okay. And nobody stopped you, right, from leaving the
board?
A. No one did.
Q. Nobody said you have to stay on, correct?
A. That's correct.
Q. Not Yvette, correct?
A. That's correct.
Q. Not Guo, right?
A. Right.
Q. And certainly not William Je, right?
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O5T1GUO4 Maistrello - Cross
A. That's correct.
Q. Okay. You continued to work there, correct, at Golden
Spring?
A. After——
Q. Resigning from the board, you continued to work, right?
A. Yes.
Q. Zero repercussions to stepping off from that board, right?
A. That is correct.
Q. Okay. Now you testified that you had responsibility at the
Rule of Law Foundation, correct?
A. I was president and treasurer.
Q. I'm sorry?
A. I was president and treasurer of Rule of Law Society.
Q. Okay. And what about Rule of Law Foundation, or are you
using them interchangeably?
A. No. That was a separate entity.
Q. So let's talk about Rule of Law Foundation, okay? For
them, did you take a trip to France?
A. Not——so I took a trip to France, but not for Rule of Law
Foundation.
Q. And who did you take the trip for?
A. I took the trip because Boss asked me to.
Q. Mr. Guo asked you to.
A. Correct.
Q. And he didn't ask you alone, right, to take a trip?
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O5T1GUO4 Maistrello - Cross
A. I was not alone.
Q. Right. There was an entire team that was put together,
correct?
A. Yes. Yes.
Q. Okay. And the team that was put together consisted of you,
right, because you spoke several languages, I'm assuming,
correct?
A. I was one of them, yes.
Q. Right. And who else was on that team, by the way?
A. There were four other people.
Q. Okay.
A. Four other security guys.
Q. Four other security guys; is that how you would describe
them?
A. That's what we called them.
Q. That's what you called them, right?
A. Four colleagues.
Q. Right. And these were all experienced ex-NYPD officers,
correct?
A. They were ex-NYPD officers.
Q. Did you know them to not be experienced NYPD officers?
A. I can't judge as to they are experienced or not.
Q. Well, you talked to them, right, according to you on direct
testimony?
A. I did.
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O5T1GUO4 Maistrello - Cross
Q. Right. And they told you about their experience as NYPD
officers, correct?
A. Sometimes.
Q. Right. And they told you what they did when they were with
the NYPD, correct?
A. They said some things.
Q. Right. And they told you they were investigators with the
NYPD, correct?
MR. HORTON: Objection.
THE COURT: Overruled. You may answer.
A. I believe some of them were detectives. I don't remember
their exact titles.
Q. And these detectives accompanied you on the trip to France,
correct?
A. We went together.
Q. Right. And what was the trip to France for?
A. So in the summer, in July of 2018, a Chinese national died
in France. Boss, Mr. Guo, believed that it was not an
accident; he believed that he may have been murdered. And so
he asked us to go there and find out what happened.
Q. And Mr. Guo thought he had been murdered by the CCP,
correct?
A. Yes.
Q. Okay. And you went on this investigative trip, correct?
A. Yes.
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Q. You, four detectives, and then you went to France and you
met a lawyer in France, correct?
MR. HORTON: Objection. 401.
THE COURT: You may answer.
A. I don't remember.
Q. You don't remember the French lawyer?
A. I don't re——
MR. HORTON: Objection.
MS. SHROFF: I'm sorry. I didn't hear.
MR. HORTON: Objection. The question has been asked
and answered.
THE COURT: Sustained.
Q. And there was a whole investigation into the issue of
whether this man was killed, correct?
MR. HORTON: Objection to form.
THE COURT: Could you step up, please.
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(At the sidebar)
MS. SHROFF: Sorry about that, your Honor. I'm having
a little trouble today with the hearing, so I will apologize.
I really am.
THE COURT: No need to apologize.
Why are we in France?
MS. SHROFF: I think she can hear me.
Thank you.
THE COURT: Okay. So——
MS. SHROFF: I think we're in France because she says
Rule of Law Foundation and Society didn't do any work, so I'm
trying to show they did do work. They investigated the death
of somebody they believed was killed by the CCP, so that the
truth would be told to the world. That's why. And she took
the trip. She translated on the trip. And I'm pretty
sure——and Mr. Schirick can jump in——that the government is
going to seek to introduce an entire video on the subject.
MR. SCHIRICK: Well, it's the Bannon video.
MR. HORTON: So the problem with the argument, your
Honor, is that she didn't testify——she didn't testify that this
trip was done under the auspices of Rule of Law. That's the
proposition that they want to establish, but it's not there.
And everything about this trip, all of the details that we're
hearing, are hearsay.
THE COURT: Did you ask the question whether she went
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in connection with Rule of Law Foundation?
MS. SHROFF: I asked her if she——I'm pretty sure I
did, and I asked her who paid, and she said Miles Guo paid.
And anyway, it doesn't matter if it's Rule of Law Foundation or
Miles Guo paid. I'm not introducing any of it for whether this
man was or was not murdered. I really do not care about this
trip. There is no hearsay problem. And I'm not asking about
any statements she made. I'm asking about what she actually
did in France. That's——so——
THE COURT: If your claim is that the Rule of Law
Foundation carried out work in France——
MS. SHROFF: Mr. Guo also carried out work in France.
Mr. Guo had an interest in his capacity to show that what the
CCP was doing worldwide was problematic, and Mr. Guo worked
towards that. It doesn't matter——
THE COURT: So these are Mr. Guo's good acts.
MS. SHROFF: No, not good. Not good. Good is
immaterial.
Sorry. Go ahead.
MR. SCHIRICK: Your Honor, the factual narrative is
that this investigation precedes the founding of the Rule of
Law Foundation, and it's the work that they started that they
talked about during that launch video that the government
introduced into evidence yesterday, and the defense ought to be
able to argue that Mr. Guo, using his own resources, using
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Golden Spring's resources, began the work of the Rule of Law
Foundation even before its founding. That's what this goes to.
It's relevant to the origin story of the Rule of Law——
MR. HORTON: Your Honor, if I may. I'm——I am
confused, and I think the jury might be too. I heard
Ms. Shroff say at the beginning of the sidebar that this was a
Rule of Law investigation and that's what——
MS. SHROFF: It was Rule of Law——
MR. HORTON: Excuse me, Ms. Shroff. I didn't
interrupt you.
I heard Ms. Shroff say at the beginning of the sidebar
that this was a Rule of Law investigation and then I just heard
Mr. Schirick say it preceded the Rule of Law. It's confusing.
The jury is going to be confused about why this testimony is
being elicited. I think that's reason enough to not elicit it.
MS. SHROFF: Your Honor, that's the pre——as he put it,
predecessor, predecessor steps to the formation of the Rule of
Law Foundation. This is the first step.
THE COURT: So once the Rule of Law Foundation was
formed, did they do anything in connection with an
investigation in France?
MR. SCHIRICK: That is the subject of the Bannon video
which is launch——the announcement of the launch of the Rule of
Law. It is a direct factual connection. They talk about it
extensively in the Bannon video that the government put into
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evidence.
THE COURT: But did they do anything?
MS. SHROFF: They ran the investigation. And then
they publicized what they believed happened as a result of
their findings of the investigation. I really——
THE COURT: So you're saying after the founding of
Rule of Law Foundation, there was work in connection with the
French investigation; that's your representation?
MS. SHROFF: That's not what I'm saying. Not——there
was——I wouldn't call it the French investigation. What I'm
saying is, this guy was murdered. Mr. Guo took his own money,
started this investigation, and as a result of the start of
this investigation, it morphed into the establishing of the
Rule of Law Foundation, which they claim in the indictment is
part and parcel of the racketeering enterprise which is an
entity formed for no reason other than to fleece money, and
what we're trying to show is, this is how it started, this is
how Rule of Law got developed and what else it did. It's a
natural progression. And also it is because they are putting
in the video of Mr. Bannon——
THE COURT: Does Mr. Bannon say that the Rule of Law
Foundation is undertaking work having to do with this
investigation in France?
MR. KAMARAJU: Yes.
MR. SCHIRICK: Yes.
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MR. KAMARAJU: But also, your Honor, the witness on
direct testified about preparatory steps taken to start the
Rule of Law. That's why they elicited it, when they had that
discussion, in order to elicit her statement that Mr. Guo
supposedly said, we're going to need a hundred million dollars.
So again, they already brought the preparation into it. This
completes the narrative.
MR. HORTON: First, her testimony was that she
undertook this preparation in September, consistent with the
representation, one of the two representations that this event
predated the Rule of Law, not that it originally started that
it was a Rule of Law investigation. But I think more
fundamentally, that this is a fraud case and this is now coming
in as he had this money before that he used on this
investigation to do good works looking into a murder.
MS. SHROFF: Not good works.
MR. KAMARAJU: I'm sorry. It's not a fraud case, it's
a racketeering case, at their insistence. Your Honor's already
ruled on this, when your Honor rejected their motion in limine
to preclude the defense from talking about any of the positive
activities of these organizations. Under RICO law, they have
to prove continuity, and if the organization was a legitimate
enterprise, then the test for continuity is different. So in
any speaking of the law, the fact that these institutions had
legitimate origin stories and had legitimate business afterward
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is directly relevant to the racketeering charges that the
government chose to bring.
MS. SHROFF: It's not to the——
MR. FINKEL: May I respond, your Honor. At most,
there might be a question, which Ms. Shroff has already
elicited, about whether she traveled to France for an activity,
but what Ms. Shroff is endeavoring to do, it appears, is to get
into the details of an investigation about a murder of someone
who's completely irrelevant to anything alleged in the
indictment, that happened in Europe. So I think we're very far
afield of what the gravamen of this entire trial is about. And
while there might be a probative purpose for activities that
either predated or are part of the Rule of Law——which, by the
way, this witness says it wasn't under the Rule of Law. But in
any case, your Honor, that's already been elicited, and it's
time to move on. And that's our argument.
THE COURT: What more is it that you want to elicit?
MS. SHROFF: I've actually completely lost track of
the question. I don't remember the question anymore. I'm
telling you very candidly.
But again, what we're trying to show is the issue of
the enterprise that the government charged. We do not care if
this guy was murdered or not. Nobody cares. Right? And——
MR. FINKEL: So why ask the question?
MS. SHROFF: Because you have alleged——can you help me
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out here. I'm sorry.
MR. FINKEL: If they want to ask, did you take a trip
to France as part of the Rule of Law, okay, but getting into
the details of the investigation is completely far afield.
MR. KAMARAJU: First of all, they've already
introduced the details of the investigation; not us, them.
They did it with the Steve Bannon video in evidence.
THE COURT: The Steve Bannon video, what is that going
to say?
MR. KAMARAJU: The Steve Bannon video, which is in
evidence already, through a stipulation that they put in
yesterday, says that Miles Guo launched this investigation; as
a result of that investigation, they are going to publicize the
results of that investigation; they're going to go after
financial institutions that enabled the CCP, and that that is
part of the mission of the Rule of Law Foundation. And that's
why it's been started. And they can say it's not in evidence.
They admitted it, your Honor.
MR. FINKEL: That's not our argument.
MR. KAMARAJU: Hold on. That's not the point.
Whether it's your argument or not, we get to have an argument
also, and our argument is that the Rule of Law Foundation is a
legitimate enterprise that has a legitimate beginning, it has a
legitimate purpose, it has legitimate operations. And if we
can show that, your Honor, then that changes their burden.
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THE COURT: So what I want to understand, though, is:
Exactly what is it that you're trying to bring out right now?
MR. KAMARAJU: Ms. Shroff.
I think it's simply——your Honor, I think it's simply
this is a real endeavor; this witness went on a real endeavor,
they went to conduct an investigation, it was real, it was
funded by Mr. Guo and the enterprise, that enterprise
ultimately culminates in the Rule of Law Foundation. The work
that is done prior becomes the work of the Rule of Law
Foundation.
THE COURT: So——
MS. SHROFF: How about this, your Honor. Maybe I can
answer the question. Mr. Guo funded this trip; Mr. Go funded
the investigation. And this was the precursor to the
establishing of the Rule of Law Foundation. How about those
three questions?
MR. FINKEL: She doesn't have any personal knowledge.
MS. SHROFF: If she doesn't, then she can say no.
THE COURT: If she does not know, she can say no.
They have a good-faith basis to ask the question, and so I'm
going to permit the question.
MR. HORTON: If I could just say one more thing, your
Honor.
THE COURT: Yes. One more thing.
MR. HORTON: I just want to clarify that the question
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is close to one——it's quite close to one that was asked and
answered, which is: Was this done through the Rule of Law? So
if there's a question that comes in that's close to asking her
to try again on that, essentially, we will object to it's asked
and answered.
MR. KAMARAJU: This is not the same, though.
MS. SHROFF: Really we should stop sustaining asked
and answered objections. It's not going to hurt the jury to
hear about that, your Honor.
THE COURT: Okay. All right. Let's go.
(Continued on next page)
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(In open court)
THE COURT: Go ahead.
BY MS. SHROFF:
Q. Mr. Guo funded the trip, correct?
A. He did.
Q. Okay. And after the trip was the start of the Rule of Law
Foundation, correct?
A. That's correct.
Q. Okay. And the Rule of Law Foundation was what we call
colloquially an NGO, correct?
A. It was a nonprofit organization.
Q. Okay. And you at one point were part and parcel of Rule of
Law Foundation's efforts, correct?
A. Rule of Law Society and Foundation, yes.
Q. Okay. And as part of that responsibility, you were
involved in the launch of Rule of Law; is that correct?
A. Correct.
Q. Right. And there were several meetings that were held as
to how the Rule of Law Foundation should be announced, correct?
A. Yes.
Q. There were agendas drafted up, correct?
A. I don't remember that.
Q. Okay. There were meetings, correct?
A. There were.
Q. And people discussed what was the best way to bring this
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forward, right?
A. Yes.
Q. And who was involved in those meetings; do you know?
A. Usually it was Boss, Steve Bannon, William whenever he was
in New York, Yvette was there.
Q. And who else was present?
A. I was there.
Q. Were you there for all of the meetings?
A. Most of them.
Q. Most of them. But there were some meetings to which you
were simply not privy, correct?
A. If they had a meeting that I don't know about, then I——I
don't know.
Q. Right. But there were discussions about who would be in
what meeting, and you were left out of some of the meetings,
correct?
A. I don't know.
Q. Okay. Fair enough.
And you talked about Steve Bannon being present at
some of these meetings, right?
A. Yes.
Q. Fair to say Mr. Bannon is a controversial figure, correct?
MR. HORTON: Objection, your Honor.
THE COURT: You may answer.
A. What do you mean by controversial?
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Q. You know what? Fair enough.
MS. SHROFF: I'll move on, your Honor.
Q. Steve Bannon was part of these meetings, correct?
A. Yes.
Q. Steve Bannon's position, at least on China, is pretty
public, correct?
A. It is.
Q. Right. And you understood Steve Bannon, regardless of all
the other problems the man has, he was against the CCP,
correct?
MR. HORTON: Objection, your Honor.
THE COURT: Overruled. You may answer.
A. He claimed to be against CCP.
Q. Right. And he was vocal about the fact that he was against
the CCP, correct?
A. He shared his opinion.
Q. Okay. And is it fair to say that you——did you not believe
his opinion about the CCP?
A. I——I never said that.
Q. No. I'm asking you. You sound like you disbelieved that
he was anti-CCP. Do you believe he was anti-CCP?
A. I only know what he said, and he said he was against.
Q. Okay. So you took him at face value that he was anti-CCP,
correct?
MR. HORTON: Objection, your Honor.
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THE COURT: Sustained.
Q. And Mr. Bannon was part and parcel of these conversations
as to how to launch the Rule of Law Foundation, correct?
A. Yes.
Q. Okay. And Yvette was part and parcel of this, correct?
A. Yes.
Q. And part of the discussions was what projects Rule of Law
Foundation would undertake, correct?
A. At the very beginning, no.
Q. Okay. You tell me. What was discussed at the very
beginning?
A. At the very beginning, so from July of 2018 to November of
2018, a lot of the discussion was around what happened in
France and the alleged or possible involvement of the CCP in
what happened.
Q. Right. And then there were——there were a lot of
discussions about whether or not CCP was involved in the murder
in France, but then it moved on and started the Rule of Law
Foundation, correct?
A. This was in November.
Q. Right.
A. Yes.
Q. In November there were discussions whether or not——as to
what the Rule of Law Foundation would have as its aims and its
objectives, correct?
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A. Yes.
Q. Okay. And the aims and objectives——and you please correct
me if I'm wrong——was to help those who were the victims, so to
speak, of the CCP, correct?
A. That's correct.
Q. And everybody in that room agreed, right, that the CCP was
a very separate entity than the People's Republic of China,
correct?
MR. HORTON: Objection, your Honor.
THE COURT: Sustained. It's not clear that she can
speak for what the group believed.
Q. Okay. Well, you believed, did you not, that the CCP is
very different from the people of China, correct?
A. Yes.
Q. Okay. And the goal was to help the people of China, right?
A. That's correct.
Q. Right. And whether the people of China now lived in the
United States or elsewhere, the goal was to help the dissidents
as well, correct?
MR. HORTON: Objection, your Honor.
THE COURT: Overruled. You may answer.
A. Yes.
Q. And the goal was to make sure they felt supported, correct?
A. Yes.
Q. And part of the——part of the support system would involve
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helping them with their asylum applications, correct?
A. Also.
Q. Right. Helping them navigate when they couldn't speak the
language, correct?
A. I don't remember this point specifically.
Q. Okay. Well, you tell me. You were there. So you tell me
what the goals and objectives were of the Rule of Law
Foundation.
A. Everything you said is correct, so the goal and mission of
Rule of Law Society and Foundation was to help Chinese people
in various forms. It could be from a legal perspective to
help——they just needed——and it was also to——excuse me——to
educate the public on——on China.
Q. Okay. And there were proposals made on how to educate
people on what was going on in China, correct?
A. Yes.
Q. Okay. And some of the proposals were accepted and some of
the proposals were rejected, correct?
A. All of them were rejected.
Q. Well, all of yours were rejected.
A. Not mine specifically, but proposals that came in.
Q. I'm sorry. Your testimony is that every proposal ever made
for the Rule of Law Foundation was rejected?
A. While I was there, yes.
Q. Okay. So there would be board meetings, correct?
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O5T1GUO4
A. There was one board meeting in January of 2020, yes.
Q. Okay. You were part of that board meeting, correct?
A. Yes.
Q. And you didn't take any notes of that board meeting; is
that true?
A. No. Someone else did.
Q. Someone else took minutes of that board meeting. You
didn't take them, correct?
A. That's correct.
Q. Okay. And——
THE COURT: We're going to stop here. It's 2:45.
So members of the jury, 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.
Please return on time, as you have in the last couple
of days, so that you can walk right through that door at 9:30
and we can get going on time.
Have a good evening.
THE LAW CLERK: Jury exiting.
THE COURT: Don't discuss your testimony.
(Jury not present)
THE COURT: We will return tomorrow for the
continuation of Ms. Maistrello's cross-examination. Is there
anything before we break?
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MR. KAMARAJU: Not from us, your Honor.
MR. FERGENSON: Nothing we can't take up in the
morning, your Honor.
THE COURT: All righty then. Thank you. See you
tomorrow.
ALL COUNSEL: Thank you, your Honor.
(Adjourned to May 30, 2024, at 9:00 a.m.)
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INDEX OF EXAMINATION
Examination of
:
Pag
e
LE ZHOU
353Cross By Mr. Kamaraju . . . . . . . . . . . .
406Redirect By Ms. Murray . . . . . . . . . . . .
410Recross By Mr. Kamaraju . . . . . . . . . . .
KARIN MAISTRELLO
420Direct By Mr. Horton . . . . . . . . . . . . .
485Cross By Ms. Shroff . . . . . . . . . . . . .
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GOVERNMENT EXHIBITS
Exhibit No. Received
VO-33 359 . . . . . . . . . . . . . . . . . . .
SM62 448 . . . . . . . . . . . . . . . . . . .
102 425 . . . . . . . . . . . . . . . . . . . .
103 460 . . . . . . . . . . . . . . . . . . . .
105 463 . . . . . . . . . . . . . . . . . . . .
110 449 . . . . . . . . . . . . . . . . . . . .
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DEFENDANT EXHIBITS
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Original English Content(英文原文)
347
O5TVGUO1
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 29, 2024
9:00 a.m.
Before:
HON. ANALISA TORRES,
District Judge
-and a Jury-
APPEARANCES
DAMIAN WILLIAMS
United States Attorney for the
Southern District of New York
BY: MICAH F. FERGENSON
RYAN B. FINKEL
JUSTIN HORTON
JULIANA N. MURRAY
Assistant United States Attorneys
SABRINA P. SHROFF
Attorney for Defendant
PRYOR CASHMAN LLP
Attorneys for Defendant
BY: SIDHARDHA KAMARAJU
MATTHEW BARKAN
ALSTON & BIRD LLP
Attorneys for Defendant
BY: E. SCOTT SCHIRICK
348 O5TVGUO1 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)
349 O5TVGUO1 (Trial resumed; jury not present) THE COURT: Good morning. Please make your appearances. MR. FINKEL: Good morning, your Honor. Ryan Finkel, Juliana Murray, Micah Fergenson, and Justin Horton for the government. We're joined at counsel table by Isabel Loftus, who's a paralegal in our office. MR. KAMARAJU: Good morning, your Honor. Sid Kamaraju and Scott Schirick on behalf of Mr. Guo. And Mr. Guo is with us here at counsel table. THE COURT: Please be seated. On May 27th, 2024, the government submitted a motion to admit certain exhibits consisting of preserved copies of online posts to G News and Gettr, ECF No. 352. Defendant filed opposition papers on May 28th, 2024, ECF 361. I've also reviewed the underlying documents the government seeks to admit, relying principally on Anderson v. United States, 417 U.S. 211 (1974). The government argues that it is not offering the posts for the truth of the matters asserted therein; instead, it states that it is offering the posts "for the fact that they exist, i.e., that they were made on media websites created and controlled by the defendant." I agree with the government that this anticipated use falls outside the definition of hearsay. In Anderson, the
350 O5TVGUO1 court determined that a statement was not hearsay because it was not offered to "prove the truth of anything asserted therein," but "to prove that the statements were made so as to establish a foundation for later showing through other admissible evidence that they were false." Id. at 220. Further, to the extent that witnesses viewed the posts at issue, they are admissible as nonhearsay to show their effect on the viewer. SEC v. AT&T, Inc., 626 F. Supp. 3d 703, 737 (S.D.N.Y. 2022). Accordingly, I will not exclude the posts on hearsay grounds. I also find that under Federal Rules of Evidence 401 and 403, the posts on G News and Gettr, media organizations that the government alleges were created and controlled by the defendant, are relevant as proof of the G Enterprise and is evidence of defendant's scheme to defraud. Accordingly, the government's motion is granted. Are there any further applications at this time? MR. FERGENSON: Not with respect to that, your Honor. MR. SCHIRICK: No, your Honor. MR. FINKEL: Your Honor, I just wanted to place something on the record, if I may. After reviewing yesterday's transcript and with the Court's comments to counsel in the robing room in mind, which the government took very seriously and takes very seriously,
351 O5TVGUO1 Ms. Shroff had flagged something for the government yesterday which I just want to put on the record for the Court. Yesterday morning, as the Court knows, Ms. Shroff indicated that she needed more time to review a victim's 3500 material. And I indicated that that victim was originally set to testify yesterday, but that we would not call her yesterday, and this would provide the defense with more time to review that new 3500. Looking at the transcript, I wasn't clear in that moment that the decision not to call the victim was made that morning, just before your Honor took the bench, just before your Honor called us into the robing room. In any event, the reordering decision seemed responsive to Ms. Shroff's request for more time and that's why I raised it. To the extent I caused any misimpression with your Honor, with the parties, I certainly apologize for that. I did not intend to do so. We will continue to work with defense counsel and continue to take very seriously and follow the Court's instruction to conduct this trial in an efficient and responsible manner. THE COURT: I did not have a negative impression yesterday morning, and I'm so glad to see that everyone is working well together. MR. FINKEL: Me too. Thank you. MR. FERGENSON: I'm sorry, your Honor.
352 O5TVGUO1 THE COURT: Go ahead. MR. FERGENSON: I had one related point, another quick point to put on the record. We've been working very productively with defense counsel on a handful of stipulations related to Shamel Medrano's testimony as a summary witness regarding these G News and Gettr posts and other videos. We have made video clips of longer videos. The defense may seek to offer additional portions of the longer videos under the rule of completeness. We have agreed that the government may have substantive objections to those under the hearsay rules, for example, but we're not going to object under, you know, timeliness or something like that. So that the defense has additional time to consider what, if any, other portions they'd like to offer. And I just wanted to put that on the record so it's clear the defense has comfort we're not going to object on that basis at a later date. THE COURT: I'm glad to hear that. MR. FERGENSON: Thank you, your Honor. THE COURT: Is there anything else? MR. KAMARAJU: Not from us, your Honor. THE COURT: So I'd like to have the witness back on the stand by, say, 9:29, so that he is here when the jurors come in. Thank you.
353
O5TVGUO1 Le Zhou - Cross
MR. FINKEL: Thank you.
MR. KAMARAJU: Thank you, your Honor.
(Recess)
THE COURT: Good morning. Please be seated.
Would you have the jurors brought in.
(Jury present)
THE COURT: Good morning, jurors.
THE JURY: Good morning.
THE COURT: Please be seated.
We are going to continue this morning with the
cross-examination of Mr. Zhou.
Remember that you're still under oath.
You may inquire.
MR. KAMARAJU: Thank you, your Honor.
LE ZHOU,
called as a witness by the Government,
having been previously duly sworn, testified as follows:
CROSS-EXAMINATION (continued)
BY MR. KAMARAJU:
Q. Good morning, Mr. Zhou.
A. Good morning.
Q. Yesterday do you recall testifying about certain G Fashion
items that you purchased?
A. Yes.
Q. Okay. And one of them were these pajamas; correct?
354 O5TVGUO1 Le Zhou - Cross A. Correct. Q. And then there was the whistle, right? A. Correct. Q. The shirt? A. Yes. Q. And the hat, right? A. Yes. Q. Okay. That's not all the items that you purchased from G Fashion, right? A. Correct. Q. You purchased several more than that, right? A. Correct. Q. When you met with the prosecutor, you went over the items that you purchased; correct? A. Correct. Q. And you went through pictures of the items; correct? A. Correct. Q. And that was of all the items you had purchased, right? A. No. Q. No? A. No. Q. How many items did you go over with them? A. About 20 items. Q. Sorry? A. Twenty items.
355 O5TVGUO1 Le Zhou - Cross Q. About 20? A. Correct. Q. Okay. And when you were going through these 20 items, who decided on bringing these to court? A. I decided. Q. Okay. So you're the one who chose which items were introduced as these exhibits? A. Correct. Q. Okay. Did you discuss that with the prosecutors? A. Yes. Q. Okay. Did they give you suggestions as to which items should be brought in? A. They mentioned not a particular item, but in the category. Q. Okay. Like what kind of categories? A. Hats, shirts, pants, and what I did jewelry. Q. Sorry, I didn't hear the last part. A. No, no. Jewelry. Sorry. Q. Okay. So they didn't ask you to bring in jewelry? A. No. Q. You picked the whistle. Do you consider the whistle to be jewelry? A. I picked whistles, two whistles, yes. Q. Okay. So you picked two whistles to show? A. Yes. Q. Okay. But they only asked you about one, right?
356 O5TVGUO1 Le Zhou - Cross A. Correct. Q. So they did make some decisions -- A. No, they kept one. Q. Okay. But in court they only showed you one, right? A. Yes. Q. So they did make some decisions about what to show here in court, right? THE COURT: He cannot testify as to what they were thinking. He can testify as to whether he made the decision. MR. KAMARAJU: Okay. Q. You decided that you would bring two whistles to show to court; correct? A. Yes. Q. Okay. And the prosecutors only showed you one here in court, right? A. Correct. Q. Thank you. Now, the approximately 20 items or so that you purchased from G Fashion, did you discuss all of them with the prosecutors? A. I purchased more than 20 items. Q. Okay. I'm sorry. Roughly how many items did you purchase? A. About 30 items. Q. Thirty items. Okay. Remember yesterday you testified about the whistle;
357 O5TVGUO1 Le Zhou - Cross correct? A. Correct. Q. And that was the gold whistle, right? A. Correct. Q. It was a commemorative item of some sort? A. I'm sorry? Q. It was a commemorative item of some sort? A. It was a limited edition, was only 77 made. Q. Okay. Sorry. Limited edition. MR. KAMARAJU: Could we bring up just for the witness, the Court, and the parties GX VO-67, please. Your Honor, after conferring with the government, it seems this is in, so I'm going to ask to publish it to the jury as well. THE COURT: Go ahead. Q. All right. So, Mr. Zhou, do you see the date of this email? A. Yes. Q. All right. It's February 28, 2021; is that right? A. Correct. Q. All right. And this is when you -- this is the order confirmation for when you bought the limited edition whistle; correct? A. Correct. Q. Now, you testified, I believe, that when you received the
358 O5TVGUO1 Le Zhou - Cross whistle, there was something that made you suspicious about it, right? A. Correct. Q. That's why you weighed it, right? A. I weighed it, yes. Q. Okay. And you weighed it because you thought there might be something wrong with it? A. When I receive it, when I first opened it, the packaging inside, it was a little bit of gold dust on it. And, of course, I pick up the whistle. The craftsmanship, it looked to me a little bit rough. Because this is a limited edition, that's collectible items, as the G Fashion promoted, this is a best, best craftsmanship items, so that's why I had concerns. Q. Okay. So you were dissatisfied with it; is that right? A. Not dissatisfied. Because still as advertised, this is a limited edition — only 77 in the world. I understand that value itself, it's there. But what it is when I receive it, it's what I received. THE COURT: Mr. Kamaraju, would you draw the microphone closer to you, please. MR. KAMARAJU: Sorry, your Honor. Yes. Is that better? THE COURT: Yes. MR. KAMARAJU: Okay. Q. And please let me know if you can't hear me.
359 O5TVGUO1 Le Zhou - Cross A. I hear you. Q. Thank you. MR. KAMARAJU: Could we show for the witness and the parties and the Court GX V0-33 -- sorry, VO-33. Q. Mr. Zhou, do you recognize this document? A. Yes. Q. What is it? A. This is screenshot I capture of the G Fashion website. Q. Okay. And what does the screenshot reflect? A. Reflect my previous order and item dates, the amount paid. Q. Okay. And the amount paid for what? A. All the item -- most of item purchased. This is not all of it. Q. Okay. So this is most of the items you purchased, but from G Fashion; is that right? A. Correct. MR. KAMARAJU: Okay. Your Honor, I'm going to offer Government Exhibit VO-33 into evidence. THE COURT: No objection? MS. MURRAY: No objection. THE COURT: It is admitted. (Government's Exhibit VO-33 received in evidence) MR. KAMARAJU: Could we publish it, please. Q. All right. So previously we looked at the order confirmation for the whistle purchase; correct?
360 O5TVGUO1 Le Zhou - Cross A. Correct. Q. And that was February 28, 2021; correct? A. Yes. Q. Okay. So if you look down at the fifth row from the bottom, so February 12th, 2021; correct? A. Correct. Q. Okay. So after that date -- MR. KAMARAJU: And we can pull that down. Q. After that date, you made a number of purchases of G Fashion clothing, right? A. Correct. Q. And I believe you testified that this doesn't even reflect all of the G Fashion purchases that you've made, right? A. Correct. Q. So despite your concerns about the craftsmanship of the whistle, you continued to buy G Fashion, right? A. Yes. Q. And you continued to spend a significant amount of money on G Fashion, right? A. To spend the money also was towards to help the G Fashion grow. Because my understanding, I'm part of the G Fashion stock shareholder. I will contribute as much any way I can, even by purchasing items. Q. So you were trying to contribute to the growth of G Fashion by purchasing these items, right?
361 O5TVGUO1 Le Zhou - Cross A. Correct. Q. And you believe that G Fashion was -- withdrawn. You believe that the growth of G Fashion was important to the movement's goals; correct? A. Because Miles Guo mentioned G Fashion valuation was tremendous high, also reach billions dollars. Q. Right. But I asked you if you understood that the growth of G Fashion was important to the movement, sir? A. Yes. Q. Okay. So you were trying to -- in addition to whatever you just testified to, you were trying to also help the movement by purchasing G Fashion wear; is that right? A. That's correct. Q. Okay. So you continued to buy G Fashion wear, right? A. Correct. Q. Now, you had previously -- withdrawn. Prior to buying a G Clubs membership, you had also purchased G Fashion, right? A. Correct. Q. Now, after you purchased your G Clubs membership, you started receiving discounts on your G Fashion wear, right? A. Correct. Q. How much -- what percentage discount were you receiving? A. Fifty percent. Q. Okay. And so each time you bought one of these items you
362 O5TVGUO1 Le Zhou - Cross got 50 percent off, right? A. Not every time. Q. After you bought the G Clubs membership, right, sir? A. Correct. Q. So how much in total discounts did you get, sir? A. If estimated, the discount -- I'm sorry, I couldn't get accurate discount on the amount of numbers. Q. Well, how much of a refund did you ask for, sir? A. Refund from which -- Q. G Fashion. A. I ask for over $12,000 refund from G Fashions. Q. Okay. And $12,000 is what you spent after receiving the 50 percent discount? A. Also includes nondiscount items. Q. It also includes nondiscounted items? A. Correct. Q. Okay. So would it be fair to say that your discount amount was in the thousands of dollars, sir? MS. MURRAY: Objection to form. THE COURT: Overruled. You may answer. A. Yes. Q. It was over $10,000, right, sir? A. Yes. Q. Okay. So you paid $50,000 for the membership, right? A. Yes.
363 O5TVGUO1 Le Zhou - Cross Q. And in the course of a year and a half or so, you earned more than $10,000 in discounts, right? MS. MURRAY: Objection. Form. THE COURT: Overruled. You may answer. A. Yes. Q. And those were for products that you were also buying because you wanted to help the movement, right? MS. MURRAY: Objection. THE COURT: Overruled. You may answer. A. Could you repeat the question, please. Q. Sure. MR. KAMARAJU: Could we have it read back please? THE COURT: Go ahead. (Record read) A. Not just help, but also towards to -- to help this company grow and to get the stock value high. Q. Right. But, sir, didn't you just testify a few minutes ago that one of the reasons why you were buying G Fashion was to help the movement? MS. MURRAY: Objection, your Honor. THE COURT: Sustained. Asked and answered. Q. When did you ask for your refund, sir? A. I couldn't remember the dates. Q. Was it after you started talking to the prosecutors? A. No.
364 O5TVGUO1 Le Zhou - Cross Q. So you requested your refund prior to speaking with the prosecutors, is that your testimony? A. Yes. Q. And that's for G Fashion, sir; is that right? A. Yes. Q. What about your G Clubs refund, when did you ask for that? A. I filed it July 15, 2023. Q. So you remember the date of the -- so the G Clubs refund was July 15, 2023; is that right? A. Correct. Q. Okay. Was the G Fashion refund request made after that? A. I don't recall that. Q. So you don't remember if the G Fashion one was before or after the G Clubs? MS. MURRAY: Objection. THE COURT: Asked and answered. Q. Now, if you look at GX VO-33, there's a line for March 1st, 2021; correct? A. Correct. Q. Okay. The first line there. Do you see that? A. I see the highlighted, yes. Q. Right. Okay. So that reflects a column for which you received a refund for an item, right? A. Yes. Q. Okay. So at any point if you were dissatisfied with
365 O5TVGUO1 Le Zhou - Cross something, you could request a refund; correct? A. This particular item was out of stock. Q. Okay. So you were dissatisfied with -- you didn't receive the item, so you got a refund, right? A. It was out of stock. I never received. Q. I'm sorry, sir, I'm just asking if you received a refund? A. Was credit to the credit store. Q. Now, you spoke a minute ago about the G Clubs membership. And I believe you testified on direct that you paid for both of those memberships by check, right? A. Correct. MR. KAMARAJU: Could we have GX VO-26, please, which is in evidence. Bring that up for the jury as well. Q. So these are the checks, right? A. Correct. Q. Okay. MR. KAMARAJU: And if we could scroll to page 10, please. Q. All right. Now, this is -- this is your member page, is that fair to say? A. Correct. Q. All right. So it reflects your name with your Tier 5 membership, right? A. Correct. Q. And it lists membership benefits there? It's on the left
366 O5TVGUO1 Le Zhou - Cross side. A. Yes. Q. Could you just read what it says there? A. "G Fashion 50 percent off, G Club brochure." MR. KAMARAJU: Okay. And could we go to page 12 of that exhibit, please. Okay. Sorry, this is the check again, right? Okay. Sorry. This is the right one. Q. All right. This is the membership page for the Tier 2 membership that you purchased, right? A. Correct. Q. Okay. Now, this you purchased on behalf of your sister, right? A. No, at the moment was introduced as we purchase; in the future we can transfer to the family. Q. Okay. Could you explain that please, sir. A. Yes. Miles Guo mentioned the G Club, the membership, the Tier 1 to Tier 5. The follower, we can purchase, but that was offered the passport. But my sister doesn't have to -- I don't need to put her name first. I have the right to transfer to my directed family members. Q. So if I understand correctly, sir, the idea was that you could purchase the membership in your name so that eventually you could transfer it to a family member if you wanted, right? A. Correct.
367 O5TVGUO1 Le Zhou - Cross Q. Okay. And was that benefit -- in your mind, was that benefit particularly useful for family members who are located in China? A. Only to the direct family members; doesn't matter if in China or other countries. Q. Okay. So anywhere, right? A. Yes. Q. Now, you filled out a G Clubs membership agreement; correct? A. There's no agreement. I never signed it or received. MR. KAMARAJU: So can we go to page 8, please. Can we just blow up the -- that email. A. This is a payment received confirmation emails. Q. Right. I was just asking if you could read the first line of the email, sir. A. Yes. "Dear Le Zhou, on 2021 August 25 at 0:47:10, you submitted your completed and executed application to become a Tier 5 member of G Clubs. We received your membership fee in the amount of $50,000. Your application is under review and we may contact you for additional information. We will email you confirmation of our decision within 30 days." Q. Okay. So I just want to make sure I understand correctly, sir. You said you never submitted a G Clubs application; is that right?
368 O5TVGUO1 Le Zhou - Cross MS. MURRAY: Objection, your Honor. THE COURT: Sustained. MR. KAMARAJU: Okay. Q. So you received this email without having submitted that application; is that right? MS. MURRAY: Objection, your Honor. THE COURT: Sustained. MR. KAMARAJU: We can take that down. Thank you. Q. Now, on direct you testified that Mr. Guo ultimately gave you the opportunity to purchase H Coin, right? A. He mention the H Coin would be offered to followers. Q. Okay. But there is a point at which H Coin could not be purchased by U.S. residents, right? A. Correct. Q. And so I believe you testified on direct that there came a point where U.S. residents could purchase H Coin; correct? A. Not a -- well, he said in the future will expand the H Himalaya exchange territory by once a proper license acquired. Q. Okay. So once the proper license is acquired, then U.S. residents may be able to purchase it, right? A. Yes. MR. KAMARAJU: Could we have GX VO-78, please, which is in evidence. Q. Okay, sir. Can you just remind us what this is? A. Yes. This is a nominee shareholder agreement provided to
369 O5TVGUO1 Le Zhou - Cross me from UK London Club. MR. KAMARAJU: Okay. And the first line under letter of agreement, can we just blow that up. Q. All right. Do you see the line that starts: "I am pleased to inform you that"? A. Yes. Q. And do you see where it says: "In recognition of the contributions made by you"? A. Yes. Q. That's a reference to your contributions to the farm, right? A. No, the contribution I understand is all of the previous G Series investments. Q. Okay. So your understanding is that the contributions that are referred to here are the G Series of investments, not the work that you did on behalf of the farm? A. Some contributions for volunteer works towards contributions, donation contributions. Q. So it all goes together in figuring out the contribution, right? A. The work, the time, effort put into it and the donations. Q. Yes. That's what I was referring to, the work and the contributions; they all play in together in determining your -- what benefit you receive, right? MS. MURRAY: Objection, your Honor.
370 O5TVGUO1 Le Zhou - Cross THE COURT: Overruled. You may continue. A. At that time, yes, the contribution, I understand it as the donations and the time and effort put into it. MR. KAMARAJU: Now, could we go to page 8, please. I'm sorry, could we scroll back to page 7 quickly. Q. Do you see the subparagraph there that starts C? A. Yes. Q. All right. You see the part that says: "You hereby consent to not performing the following"? A. Yes. Q. And it goes on to say "to allow you to benefit and continue," do you see that language? A. Yes. Q. Okay. So this is telling you things that you should not do if you want to keep the preferential H Coin allotment, right? A. I'm sorry? Q. This provision is talking about things that you should not do in order to maintain the beneficial H Coin offering you were getting, right? A. Yes. MR. KAMARAJU: Okay. If we could go to the next page and just blow up No. 3, please. Q. Could you read that, sir? A. Yeah. "You undertake to not demonstrate, whether directly or
371 O5TVGUO1 Le Zhou - Cross indirectly, or otherwise facilitate in any form, any support or benefit in any form, to the Chinese Communist Party, CCP, quote, or any CCP officials." Q. Okay. So one of the things that you should refrain from doing is supporting the CCP, right? A. I'm sorry, referring -- Q. Well, you testified previously that this is talking about things you shouldn't do to keep your H Coin allotment, right? A. Correct. Q. And one of the things is not support the CCP, right? A. Correct. Q. Because the movement is anti CCP, right? A. Correct. Q. So if you supported the CCP, obviously that would be anti the movement, right? A. Not me support, but -- Q. Anyone, sir. I'm not referring to you specifically. A. Correct. Q. Now, you talked a little bit about the work that you did on behalf of the farms, right? A. Correct. Q. So you actually did a substantial amount of work for the farms, right? A. Yes. Q. Tell us again what kind of work you did.
372 O5TVGUO1 Le Zhou - Cross A. Transcripts, reviewing translation, and we did editing and streamings. Q. Okay. So is it fair to say that the work you just described is targeted to disseminating the movement's message? A. Help to spread the words, yes. Q. Okay. And you knew that broadcasting was a significant part of the movement's efforts, right? A. I will say equal to other informations, other type of work. Q. Okay. And I'm not asking you to say what's more or not, I'm just saying it was a big part of what the movement did was broadcasting, right? A. No, it's not big part. I say it's equal to other work. Q. Okay. Well, you first learned of Mr. Guo by watching online videos that have been posted; correct? A. Yes. Q. Okay. And did you first see him on YouTube? A. Yes. Q. When was that again? A. February 2017. Q. So you saw Mr. Guo -- withdrawn. Was that on Mr. Guo's YouTube account? A. No. Q. Okay. So you saw him being rebroadcast on somebody else's YouTube account? A. Not a rebroadcast. He appear on an interview on someone's
373 O5TVGUO1 Le Zhou - Cross broadcast channels. Q. Which interview was that? A. The channel was called Mirror Media. Q. All right. And in the video he expressed some criticism of the Chinese Communist Party, is that fair? A. Yes. Q. Okay. And subsequently after you became involved with the movement, the movement also put out broadcasting that was critical of the Chinese Communist Party, right? A. Yes. Q. In fact, that was the goal of GTV, was to be able to broadcast that kind of -- MS. MURRAY: Objection. THE COURT: Overruled. You can express your understanding of the goal of GTV. MR. KAMARAJU: I'll phrase it that way, your Honor. THE COURT: Okay. Q. It was your understanding that the goal of GTV was to be able to broadcast messages that were critical of the CCP to people in China; correct? A. Yes. Q. Now, there were some people in the movement who appeared in the broadcast; correct? A. Yes. Q. And there were some people who did work for the movement
374 O5TVGUO1 Le Zhou - Cross who did not appear on the broadcast; correct? A. Yes. Q. And did you ever appear in a broadcast? A. I appeared just by voicing, not appears as physically, like appearances. Q. So you only used your voice, you didn't show your face; is that right? A. Correct. Q. Why didn't you show your face? A. Because I want to keep it just not -- I just decide not to show my face. Q. Was there any reason? A. Well, so I don't want to -- MS. MURRAY: Objection. THE COURT: Overruled. You may answer. A. Yeah. Because I also don't want to be target by the CCP. Q. Sorry. Did you say you didn't want to be targeted by the CCP; is that right? A. Correct. Q. Okay. Thank you. Now, you also testified on direct about the fact that farm members used Discord, right? A. Yes. Q. What is your understanding of why they used Discord instead of, you know, text messaging, for example?
375 O5TVGUO1 Le Zhou - Cross A. The reason I don't know. Q. And you also testified on direct about WebEx, right? A. Yes. Q. Do you have an understanding as to why they chose WebEx? A. This part of reason I know. Q. Whatever you know, sir. A. Is because WebEx has a feature allow over 100 participants to be online at the same time. Q. Were you on WebExes that had over 100 participants? A. Yes. Q. Okay. So those were large gatherings of movement members? A. Yes. Q. Was Mr. Guo part of any of those? A. Yes. Q. Okay. And everybody who was on that WebEx could speak if they wanted to, right? A. No. Q. No? A. No. Q. Why? A. Because it was some people muted; there was only have a speaker allowed to speak. Q. Okay. So someone would have to recognize the speaker, right? A. Yes.
376 O5TVGUO1 Le Zhou - Cross Q. Okay. Now, you also used a Discord name. I believe it was Coffee Cantana, do I have that right? A. Coffee Cantata. Q. Cantata. Okay. Thank you, sir. Is there a reason why you picked that name? A. Yes. Q. What's that? A. I personally like to drink coffee. I play the classic music. Cantata is a piece of the classic music. Q. So it was related to your interests, right? A. Correct. Q. Okay. And you interacted with other movement members who were also using Discord names, right? A. Correct. Q. And even some people who appeared in broadcasts used, I'll say, pseudonyms, right? A. I'm sorry? Q. They used different names than their real names, right, some people who appeared in broadcasts? A. Correct. Q. Like Mulan, for example, right? A. Correct. Q. That's not -- do you know somebody named Octopus? A. Yes. Q. Okay. That's not Octopus's real name either, right?
377 O5TVGUO1 Le Zhou - Cross A. That's not. Q. Did Octopus ever appear in a broadcast? A. I do not recall that. Q. Okay. How about Nebula? A. Yes. Q. You know somebody who went by the name "Nebula"? A. Yes. Q. Okay. And that wasn't that person's real name either? A. Correct. Q. Did that person appear in a broadcast? A. I do not recall that. Q. Do you have an understanding as to why they were using different names? MS. MURRAY: Objection, your Honor. THE COURT: Sustained. Q. Now, in addition to doing kind of the video streaming work that you talked about, right, you also opened bank accounts on behalf of the farms, right? A. Correct. Q. So you were entrusted with receiving the money from other farm members, right? A. I don't know what's from other farm members. Q. Okay. Let me put it this way: You were entrusted with the money that the UK farm was receiving, right? A. I cannot make that entrust because that's something someone
378 O5TVGUO1 Le Zhou - Cross has to say if they entrust me or not, but I didn't receive that type of -- Q. Okay. You were given authority over the bank account that contained the money, right? A. Under authority, I'm sorry? Q. You were given the authority over the bank account that received the money, right? A. I was instructed to open account. Q. Okay. Was it your name on the account, sir? A. The account I was a signer. Q. Okay. MR. KAMARAJU: Could we show for just the parties, the Court, and the witness, DX 60476, please. Q. While that's being pulled up, how many different bank accounts did you open up, sir? A. Three. Q. Three. And were those all in the same name? A. No. Q. They were in different companies' names, right? A. Correct. Q. And some of those companies you started, right? A. No, I didn't start a company. Q. You didn't start any companies? A. That's not my company. Q. Well, okay. I'm just asking whether you -- did your name
379 O5TVGUO1 Le Zhou - Cross appear on any formation documents for one of the companies, sir? A. Yes. Q. Okay. And when you opened those accounts, I think you testified on direct that you told the banks that they were for your real estate business, right? A. I was instructed to tell them that. Q. Okay. But that is what you told them, right? A. Yes. Q. And you told them that, right? A. Yes. Q. Okay. And that wasn't true, right? A. Correct. Q. Because in reality, you were receiving the money from -- that the farm was taking in, right? A. I would say not say the farm, because all the wire to me didn't tell me which one was farm, which farm or individual, the person's relation. I know -- I know was farm the follower wanted to invest in G Series. Q. Yeah. Sorry, sir, I wasn't asking about where the money came from. I was saying this was the money that the UK farm was receiving, right? A. Yes. Q. The money wasn't going to your real estate business, right? A. No.
380 O5TVGUO1 Le Zhou - Cross Q. Okay. So you misrepresented the nature of the account to the bank, right? A. Yes. Q. Okay. And you did that because you were trying to help the movement, right? A. Help the followers. Q. Right. Help the followers, right? A. Yes. Q. And help the UK farm, right? A. Just help the followers. Q. I'm sorry, sir, maybe I'm not understanding. Could you explain the distinction that you're drawing there. A. Yes. My intention help the farm because the UK London farm leader tell me that -- ask me my help to help the followers, but didn't specify if the follower was all from the UK London Club or other farms. Q. Okay. So how much money would you say came into the bank accounts that you opened? A. About $2 million. Q. About $2 million. And do you remember from roughly how many recipients it came in from? Or, sorry, withdrawn. Do you remember from approximately how many senders it came in from? A. Approximately 50.
381 O5TVGUO1 Le Zhou - Cross Q. Approximately 50, sir? Sorry, is that what you said? A. Correct. Q. All right. I think DX 60476 is on your screen now. Could you just take a look at that, please. A. Yes. MR. KAMARAJU: Okay. Maybe we can scroll to the next page. Q. Do you recognize this document, sir? A. Yes. Q. Okay. Does your signature appear on it? A. Yes. Q. What's the date next to your signature? A. February 24th, 2021. Q. Okay. And what is this document, sir? A. Oh, yeah. This is -- Florida, state of Florida business status. I think it's certifications. Q. Certification. Okay. MR. KAMARAJU: Let's go to page 2. Sorry, page 2. Q. Do you recognize this? A. Yes. Q. What's this? A. This is from IRS about the EIN numbers. Q. And do you see the name of a company listed in the first sentence, sir? A. Yes.
382 O5TVGUO1 Le Zhou - Cross Q. Okay. Is that one of the companies that you used to open bank accounts for the UK farm? A. This name was created by the UK farm, I use to open account. MR. KAMARAJU: Your Honor, the government -- I did it again. The defense is going to offer DX 60476 into evidence. MS. MURRAY: No objection. THE COURT: It is admitted. (Defendant's Exhibit 60476 received in evidence) MR. KAMARAJU: Thank you. Could we publish to the jury? I promise I won't do it three times. Q. So this is the formation documents for one of those companies; correct? A. Yes. MR. KAMARAJU: Could we go to the next page, please. Page after that, please. Thanks. And just blow up the signature line. Q. Do you see where it says "incorporator," sir? A. Yes. Q. Whose signature is that? A. Mine. Q. So you began this company on February 24th, 2021, right? A. I registered it myself, but the director was still listed as the UK leaders. Q. Okay. I was just -- you registered it on this day, right?
383 O5TVGUO1 Le Zhou - Cross A. Yes. Q. All right. So you first started opening bank accounts to receive the money for the UK farm in 2021, right? A. Correct. Q. Now, as part of your work receiving the money, did you also account for how the money was being spent? A. I documented, yes. Q. So you looked at the bank statements to see where the money was going? A. The money was only instructed to wire out. Q. I'm sorry, could you say that again? A. All the money was instructed to wire out. Q. All the money was instructed to wire out. A. Correct. Q. Right. So you never received any instructions to wire money to Mr. Guo, right? A. Not to him. Q. Okay. Now, we talked a little bit about the volunteer work that you did for the farm. The farm more broadly did volunteer work as well, right? A. Yes. Q. There was a project in the Ukraine; is that right? A. That's a farm Himalaya Global Alliance, not just one farm. Q. Okay. So several farms united in that effort? A. All farms participated.
384 O5TVGUO1 Le Zhou - Cross Q. Okay. And what were they doing? A. There was the Ukraine. MS. MURRAY: Objection, your Honor. Relevance. THE COURT: Overruled. You may answer. A. It was Ukraine, humanitarian missions. They were be called to the borderline between Poland and the Ukraine. The mission was to rescue Chinese nationals and to do other humanitarian works. THE COURT: Rescue them from where? THE WITNESS: Between the borderline at Poland and the Ukraine. Q. Okay. Thank you. Now, you testified on direct that you became concerned about the way some of the money was being spent that had come into those bank accounts; is that right? A. Not a concern to those accounts. Q. So you never had any concern about those accounts; is that right? A. There were meetings, private meetings, between Miles Guo and UK London Club. There were things mentioned just from the UK London Club financials, status, and province. There were -- misproper used funds was addressed. Q. Okay. Who was misusing the funds? A. At the time the meeting, David Dai, the leader of UK London Club, was accused misused global donation, global foundation
385 O5TVGUO1 Le Zhou - Cross funds. Q. So he was -- he was accused -- withdrawn. David Dai was accused of misusing Rule of Law Foundation funds at this meeting? A. At that meeting, yes. Q. Okay. But that meeting was a meeting of the UK farm? A. Yes. Q. So they were discussing misuse of the foundation's money at the farm meeting, right? MS. MURRAY: Objection. 401, 403. THE COURT: You may answer. A. That was mentioned in the meeting, yes. Q. Okay. Now, I think you just said Mr. Guo was part of that meeting, right? A. Yes. Q. So he was part of this discussion about these accusations, right? A. Yes. He was there. Q. Okay. And the topic was -- or one of the topics at least were these accusations, right? A. Yes. Q. So you heard Mr. Guo discuss those accusations, right? A. Yes. Q. Okay. And it was resolved to look into those accusations, right, figure out if they were real?
386 O5TVGUO1 Le Zhou - Cross A. I don't know if they were resolved. Q. It was decided at the meeting, sir? A. It wasn't decided; it was just brought it out, the accusations. Q. Okay. Did anybody reach a decision as to what to do about the accusations at that meeting? A. At a meeting Miles Guo even ask one person from the Rule of Law Foundations. To my knowledge, the person keeps track of the funds, Miles Guo personally ask that person about the David Dai's accusations. Q. Okay. So Mr. Guo asked that person about the accusations, right? A. Yes. Q. And the accusations were that UK David — that's David Dai, right? A. Yes. Q. — was misusing the funds; correct? A. Yes. Q. Were there any other accusations made against UK David of misappropriating funds? A. Yes. Q. How many times did that happen? MS. MURRAY: Objection. THE COURT: You can step up. (Continued on next page)
387 O5TVGUO1 Le Zhou - Cross (At sidebar) MS. MURRAY: Your Honor, as an initial matter, this is hearsay that he's trying to elicit. In addition, the accusations that there was a misuse of funds is being introduced and offered for the truth, for the fact that there was, in fact, misuse of funds and this 403 problem. MR. KAMARAJU: Well, first of all, any introduction of a defendant's out-of-court statement is not automatically hearsay. We're simply eliciting his testimony to show when there were accusations, they were taken seriously and people were investigated, including Mr. Guo. So you have to at least establish that the accusations were made. Whether they are true or not, we don't know; we're not asking the witness to opine on whether they are true. We're just saying they wanted to look into it. MS. MURRAY: Your Honor, I don't see how they are not being offered for their truth here. THE COURT: They are being offered for their truth. MR. KAMARAJU: But I didn't even ask him if the accusations were true, your Honor. THE COURT: You want to use those accusations to make the argument that Mr. Guo had a legitimate interest in guarding the funds for the cause. MR. KAMARAJU: Yes. And so the only relevant fact there is that there were accusations made, not whether the
388 O5TVGUO1 Le Zhou - Cross accusations are true or not, which is all I'm trying to elicit. And that's all I've elicited so far. MS. SHROFF: In fact, Mr. Kamaraju could ask: You don't know if these accusations were true or false. We are not trying to introduce them for their truthfulness. MS. MURRAY: He's already established the fact that there were accusations. So the additional line of questioning into "there were other accusations, weren't there," is leading into, again, trying to indicate and imply the truth of a fact that there were accusations of misuse of funds. I don't see any other purpose for it to come in and it's unduly prejudicial. MR. KAMARAJU: The purpose is the same no matter how many times I ask the question about accusations. MS. MURRAY: Right. And it's already in evidence now. THE COURT: So it seems that there are two purposes, both for the fact of the accusation and for the truth of the accusation, because you want to portray Mr. Guo as guarding these funds for his political cause. MR. KAMARAJU: But I don't believe that the second point requires the accusations to be true or false. If the U.S. Attorney's Office investigates somebody and responds to a victim complaint, that's not a statement of the victim complaint is true or it's false; it's simply evidence that the U.S. Attorney's Office took the victim
389 O5TVGUO1 Le Zhou - Cross complaint seriously. You don't have to have the truth of the victim complaint in order to establish that they took it seriously. MS. MURRAY: I think at bottom, your Honor, Mr. Kamaraju is saying what he wants to get in is the fact that there were accusations. That's already in. So there's no additional line of questioning that would be fruitful unless it's going to something improper. MR. KAMARAJU: No, because we're allowed to point out the fact that it happened more than once. That goes to how serious they took it. MS. SHROFF: And that each time the accusation was addressed, not whether the accusation was true or false. You are free to elicit on redirect that the accusations were, in fact, false. Of course that's your prerogative. But that does not make Mr. Kamaraju's questioning improper or unduly prejudicial. In fact, that was the whole point of your direct. Your whole point of the direct was to show that Mr. Guo did nothing. So we're entitled to show that what you did on direct was improper. MS. MURRAY: Your Honor, again, it's hearsay. They are focusing on what Mr. Guo did and what Mr. Guo said. Here they are asking this witness with respect to how seriously the accusations were taken or not. I think we've established this witness said he didn't know what decision was made or whether
390 O5TVGUO1 Le Zhou - Cross there was a resolution to take certain action or not. THE COURT: So you can ask whether there were any other accusations, but it's going to stop there. MR. KAMARAJU: Okay, your Honor. (Continued on next page)
391 O5TVGUO1 Le Zhou - Cross (In open court) BY MR. KAMARAJU: Q. There came a point where the UK farm was dissolved; correct? A. Correct. Q. Why was that? A. Because there were -- at the time Himalaya Global Alliance started doing statistical work to gather all the farms' financial balance sheets, and also at the time to have all the farms to wire all the balance each farm held to the Himalaya Global Alliance. And at the time because accusation made it to David Dai, and also he has some unwired balance, it was quite a big amount of balance that Miles Guo ask him also provide him a deadline to wire. He failed that. Q. What was the -- I think you referred to it as an unwired balance. What was that? A. Because there's some funds the farm held. The fund has to be transferred to the Himalaya Global Alliance, designated accounts. And a couple other meetings, there were -- Miles Guo gave David Dai a deadline to wire the balance which he failed to do that. So that impact dissolving the whole farms, and also Miles Guo strip his title and he was terminated from this -- sorry, not terminated, he was removed from the farm and from the movement. Q. Was there a reason given for his termination from the farm
392 O5TVGUO1 Le Zhou - Cross and the movement? A. That I don't know. Q. So you weren't privy to any of those reasons? A. I was in the meeting. Q. Now, I'd like to talk a little bit about the refunds that you requested, okay? A. Sure. Q. You asked for a refund from G Fashion, right? A. Yes. Q. Okay. And you asked for a refund from G Clubs, right? A. Correct. Q. Now, when you asked for the refund from G Clubs, did you go to the company and ask for a refund? A. Yes, I did email them. Q. Okay. So you emailed G Clubs for a refund? A. Yes. Q. Did you get a response? A. Only email I was received, just acknowledgment they received my request. After that, no more response. Q. And that response -- withdrawn. That refund request was made, I think you testified, in July of 2023, right? A. I can't remember the dates. Q. You don't remember testifying earlier today that it was July 2023?
393 O5TVGUO1 Le Zhou - Cross A. The whole other refund which, I mean, July 15, 2023, was started, initiated to the Washington, D.C. farms. Q. Oh, I'm sorry. I misunderstood. The July 15 date is when you applied to the farms for the refunds? A. Yes. Q. Approximately how long before you went to the farms did you submit the G Clubs request? A. That I don't remember. Q. Well, not asking for a specific date, but months, years, weeks? A. Months. Q. Months. Okay. And it was several months after you had purchased your G Club membership initially, right? A. Yes. Q. Why did you go to the farms to get a refund from G Clubs? A. Because Miles Guo instructed any follower, any problem, issues will first contact the farm leaders, which at the time I was associated with Washington, D.C. farm. So, as instructed, that is what I did. Q. But you went to G Clubs first, right? A. No, I don't remember if went to G Club first. Q. Sir, I thought you just testified a moment ago that you went -- months prior to submitting a farm request -- MS. MURRAY: Objection, your Honor.
394 O5TVGUO1 Le Zhou - Cross Mischaracterizes the testimony. THE COURT: Sustained. Q. Okay. So do you remember? Did you go to G Clubs first or the farms first? A. I don't remember -- MS. MURRAY: Objection, asked and answered. THE COURT: Sustained. Q. Okay. I'm sorry, sir. You said that you went to the farms because Mr. Guo said you should go there first, right? A. Not first. You have any issues, we will go to the farm leader. Q. And what did you think it was that the farm leader could do for you with respect to G Clubs? A. Miles Guo mention the farm leader roles. Leader roles only to serve the followers. There's no class or underling. Every follower and the leader are equal. Q. Okay. I was just asking what you thought that the farms could do for you with respect to G Clubs? A. Because that's a rule, which farm you're associated with. And you only can associate with one farm. So at the time I was with Washington, D.C. farm. That's only farm I can go to. Q. I understand, sir, you went to the Washington farm because that's -- that was your farm, right? A. At that time, yes. Q. Okay. I'm just understanding -- I'm just trying to
395 O5TVGUO1 Le Zhou - Cross understand why you thought the farm could help you out with a G Clubs problem? A. Because that's -- Miles Guo stated anything, if it's related to the movement, G Series, we can go to the leaders of the farm. Q. Okay. And what were the farm leaders supposed to do, sir? A. To help with my request. Q. Okay. Were you expecting the farms to pay the money back to you that you had spent on G Clubs? A. That I didn't expect. Q. What kind of help were you expecting? A. My hope was to have the farm leader first to acknowledge that and for my request. Then the second was I just -- going to just wait for the answer, but I don't expect what will be the next. But my ultimate goal was to get a refund. (Continued on next page)
396 O5T1GUO2 Le Zhou - Cross BY MR. KAMARAJU: Q. Okay. And you did ultimately get a refund; is that right? A. Yes, I received a G/CLUBS refund. Q. Okay. And prior to getting the G/CLUBS refund, they made a request that you returned some equipment, right? A. Correct. Q. What was that equipment? A. It was streaming equipment. Q. Okay. And why did you have that equipment? A. Because the Washington, DC Farm send it to me for the streaming, for the farm streaming, to use for the farm streaming; also, the equipment was used during the protest streamings, for the Himalaya Global Alliance. Q. Okay. So it was used to broadcast farm business, basically? A. And for the Himalaya Global Alliance. Q. Was it expensive equipment? A. To my knowledge, yes. Q. Did you send the equipment back, sir? A. Yes. Q. Who did you send it to? A. I sent it to Washington, DC Farm. They provided the address. Q. Okay. And do you have any knowledge as to what they did with that once you returned it?
397 O5T1GUO2 Le Zhou - Cross A. After I returned it, they had one person inspect it, and then once inspected everything thoroughly, I had a confirmation, item was received, inspected. Q. Okay. And then you received your refund after that; is that right? A. Correct. Q. Okay. About how long was it after that that you got your refund? A. I got my refund on December 1, 2023. Q. And when was the inspection? A. That was in——about October. Q. Of 2023? A. 2023. Q. Okay. Thank you, sir. MR. KAMARAJU: If I could just have one moment, your Honor. Q. Now, sir, you testified on direct about protests, right? A. Yes. Q. And you testified that your role in the protests was helping to stream them, correct? A. Yes. Q. How many protests did you stream? A. Personally stream, about dozens. Q. Dozens? A. Yes, personally streamed.
398 O5T1GUO2 Le Zhou - Cross Q. Okay. Yeah, I'm just talking about the ones that you streamed. A. Yes. Q. Okay. Now the ones that you testified on direct I believe were in connection to a man named Luc Despins; is that right? A. Correct. Q. Okay. And he was the bankruptcy trustee, correct? A. Correct. Q. Were all of the streams that you personally participated in against——sorry. Withdrawn. Were all of the streams that you personally participated in of protests involving the bankruptcy trustee? A. Not all of the streams. Q. Okay. So there were some that were not that, right? A. Correct. Q. What were those other ones about? A. Other ones about protesting Capitol Hill. Q. Okay. You were protesting at Capitol Hill? The protests occurred at Capitol Hill, the one you're talking about? A. Yes. Q. What were they protesting? MS. MURRAY: Objection. Lacks personal knowledge. THE COURT: If he observed the streaming, he may know what they were protesting. If you know.
399 O5T1GUO2 Le Zhou - Cross THE WITNESS: Yes, your Honor. A. Yes. At Capitol Hill was——protest was also for Miles Guo. Q. Okay. But what were they protesting against, sir? A. It was against persecution against Miles Guo. There were protests, unfair justice against Miles Guo. Q. When was this protest? A. This was in November 2022 to——lasted about a month. Q. Sorry. You said it lasted about a month, sir? A. Correct. Q. And was there any specific group of people they were protesting? A. Yes. Q. Who was that? A. Mostly followers from Washington, DC Farm. Q. Okay. So those were the people who were mostly participating in the protest, right? A. Yes. Q. Okay. Were the protests aimed at any particular group of people? A. The Capitol one didn't aim any particular people, no. Q. Okay. Was it targeted at any particular government agency? MS. MURRAY: Objection. 403. THE COURT: I'll allow the question. THE WITNESS: Yes, your Honor. A. The first, the Chinese Communist Party, and also there
400 O5T1GUO2 Le Zhou - Cross were——US Justice were mentioned during the protest. Q. Okay. And when you say the Chinese Communist Party, the protests were against the CCP, right? A. Yes. Q. And you testified on direct that the protests of the bankruptcy trustee involved——and I wrote it down but I may have it wrong so correct me, please——CCP running dogs, right? A. That's what I——yes. Q. Okay. Was any similar language used during the Capitol Hill protest? A. He was at a——the protest called 90 Days Protest for Luc Despins wasn't at the Capitol. Q. I understand. I'm asking about the Capitol Hill protests. A. His name weren't mentioned at the Capitol Hills. Q. Okay. Did you hear anybody at the Capitol Hill protests talk about CCP spies? A. Yes. Q. Okay. Have you heard Mr. Guo refer to people as CCP spies before? A. Yes, he did refer. Q. Have you heard other movement members refer to people as CCP spies? A. I never participated in other——other movements. Q. Sorry, sir. I was talking about other NFSC movement members refer to people as CCP spies.
401 O5T1GUO2 Le Zhou - Cross A. Yes. Q. What is your understanding of that phrase? A. Just CCP spies, just a name to those——acquisition to the people. Q. So it doesn't have any particular meaning to you? A. Just CCP spies. Q. Okay. And when you heard that, you didn't have any evidence one way or the other as to whether those people were actually CCP spies, right? MS. MURRAY: Objection, your Honor. THE COURT: You may answer. A. That I don't. Q. Sorry. You said you don't, right? A. I don't. Q. Okay. And you testified on direct that at the time of the protests of the bankruptcy trustee, you didn't have any evidence with respect to whether the trustee was working on behalf of the CCP, right? A. That I don't. Q. You just didn't know one way or the other, right? A. At the time I believed it, but I don't have the evidence to prove it. Q. Okay. And because you believed it, you participated in those protests, right? A. Yes.
402 O5T1GUO2 Le Zhou - Cross Q. You streamed them, right? A. Yes. Q. You wanted to get the word out, right? A. Yes. Q. You wanted other people to hear what was happening, right? A. Yes. Q. Because you believed an injustice was happening, right? A. At the time I believed it. MR. KAMARAJU: Okay. Your Honor, at this time the defense would like to read and enter into evidence a stipulation between the parties. THE COURT: Go ahead. MR. KAMARAJU: It's DX Stip 0001. And it reads: "It is hereby stipulated and agreed by the United States of America and Miles Guo, the defendant, through their attorneys of record, that: "1. The FBI has investigated individuals who, working at the direction of the government of the People's Republic of China (the "PRC government") have engaged in an international campaign, known as "Operation Fox Hunt," to coerce individuals located in the United States and elsewhere to return to China to face charges brought by the PRC government or to otherwise reach financial settlements with the PRC government. "2. In 2017, a US law enforcement agency assessed that Mr. Miles Guo was the highest priority of China's
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O5T1GUO2 Le Zhou - Cross
repatriation efforts.
"3. In 2017, a US law enforcement agency received
information that Chinese officials were paying and providing
food and signs to protestors of Mr. Guo.
"4. In 2018, a US law enforcement agency received
information that the PRC government had established a special
investigative group in China to manage China's investigation
of, and actions against, Mr. Guo.
"5. To carry out some of the objectives of Fox Hunt,
in 2017, the PRC government tasked a specially designated group
of operatives ("the Group") with discrediting and harassing
individuals, including Mr. Guo, by using interactive computer
services and electronic communication systems. The Group is
based out of the Beijing Municipal Public Security Bureau at a
facility in Beijing's Dong Cheng District. The Group was
previously referred to as the "Cyber Investigation Team" and
was later referred to as the 9112 Special Project Working
Group. The Group's tactics aimed at Mr. Guo included using
anonymized social media accounts operated by the Group and by
pressuring US social media companies to remove Mr. Guo and
US-based associates of Mr. Guo from social media platforms.
These efforts were part of the PRC government's broader effort
to prevent, disrupt, and harass Mr. Guo's use of social media
and other online platforms to disseminate and discuss
disfavored content. In or about December 2018, officers of the
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O5T1GUO2 Le Zhou - Cross
Group were directed to post three videos or posts daily with
YouTube and Facebook accounts, with one of the posts required
to be anti-Mr. Guo. On February 3, 2020, a PRC government
official issued a tasking requirement that every member of the
Group shall write an original article with content related to
targeting Mr. Guo, the COVID pandemic, or Hong Kong. The FBI
investigated the Group's activities, including its activities
aimed at Mr. Guo, and the US government has charged many of the
Group's members with violations of US law.
"6. Since Mr. Guo fled the PRC, the PRC government
has sought his return for prosecution in the PRC and has
employed numerous methods to effect Mr. Guo's capture or
arrest. In May 2017, the PRC government sent four undeclared
agents from the PRC's Ministry of State Security ("MSS") to the
United States to attempt to cause Mr. Guo's coerced
repatriation to the PRC as part of the Fox Hunt initiative.
The US government disrupted the PRC government's efforts to
forcefully repatriate Mr. Guo and Mr. Guo continued to reside
in the United States.
"7. Between May 2017 and January 2018, at least four
individuals, including George Higginbotham, Elliot Broidy,
Nickie Lum Davis, and Prakazrel Michel, never disclosed that
they were actually acting on behalf of foreign actors,
including the PRC government, to lobby officials in the Trump
administration in an effort to cause Mr. Guo's extradition to
405 O5T1GUO2 Le Zhou - Redirect China. Higginbotham, Broidy, Davis, and Michel were each convicted of violating US law regarding their lobbying efforts. The efforts of these individuals were not successful, and Mr. Guo was never extradited at the request of the PRC government. Instead, and since approximately 2015, Mr. Guo has been able to reside in the United States with his family. "8. On October 23, 2018, a court in Hong Kong entered an order seizing and restraining Mr. Guo's assets in Hong Kong and elsewhere under the court's jurisdiction. "It is further stipulated and agreed that this stipulation may be admitted into evidence." And your Honor, I would offer DX Stip 0001. THE COURT: It is admitted. (Defendant's Exhibit Stip 0001 received in evidence) MR. KAMARAJU: Thank you, your Honor. BY MR. KAMARAJU: Q. So just one question, sir. Prior to hearing me read that information out, had you heard any of that before? A. Yes, I heard Miles Guo mentioned it, some of it. Q. What did you hear him mention? MS. MURRAY: Objection. Hearsay. THE COURT: Sustained. Q. Okay. Other than Miles Guo's statements, did you hear it anywhere else? MS. MURRAY: Objection.
406 O5T1GUO2 Le Zhou - Redirect THE COURT: The fact of having heard it, he can answer. It's that you can't state what you heard. A. Just from Miles Guo. MR. KAMARAJU: No further questions at this time, your Honor. THE COURT: Redirect? MS. MURRAY: Yes, your Honor. Thank you. REDIRECT EXAMINATION BY MS. MURRAY: Q. Mr. Zhou, you were asked questions on cross-examination about the hierarchy of the Himalaya Global Alliance. Do you recall those questions? A. Yes. Q. Who appointed the farm leaders? A. The farm leaders, beginning will be only appointed by Miles Guo, but later, once the Himalaya Global Alliance Farm, especially the Iron group, Iron Blood group farm, it will be jointly——jointly appoint the leaders. Q. And who appointed the members of the Iron Blood group? A. Miles Guo. Q. Who was the ultimate highest leader of the farms? MR. KAMARAJU: Objection. THE COURT: Overruled. You may answer. A. Well, Miles Guo. Q. And who was the ultimate highest leader of the Himalaya
407 O5T1GUO2 Le Zhou - Redirect Global Alliance? A. Miles Guo. Q. You were asked questions on cross-examination yesterday and again today about the purposes of the G series investments. Do you recall those? A. Yes. Q. Your understanding that GTV was a social media company was based on whose statements? A. Based on Miles Guo's statements. Q. Your understanding that G/CLUBS was a membership service was based on whose statements? A. Miles Guo's statements. Q. Your understanding that the Himalaya Exchange was a cryptocurrency platform was based on whose statements? A. Miles Guo's statements. Q. Who announced the G series investments? A. I'm sorry? Q. Who announced the G series investments? A. Miles Guo. Q. Who promoted the G series offerings? A. Miles Guo. Q. You were also asked questions about how the GTV private placement funds were to be used. Do you recall those? A. Yes. Q. Did Guo say he was going to send GTV investor funds to a
408 O5T1GUO2 Le Zhou - Redirect hedge fund? A. No. I don't——I don't recall that. Q. You were also asked questions about your own GTV investment through Voice of Guo, or VOG. Do you recall that? A. Yes. Q. Who identified Sara Wei as the point of contact for a GTV investment below a hundred thousand dollars? A. Miles Guo. Q. You were asked some questions about what you expected to receive in exchange for your G/CLUBS membership money. Do you remember those questions? A. Yes. Q. Did you ever receive an NFSC passport for your $70,000 G/CLUBS payment? A. No. Q. Did you ever receive any G/CLUBS stock for your $70,000 G/CLUBS payment? MR. KAMARAJU: Objection, your Honor. THE COURT: You may answer. A. No. Q. Did you ever receive any G Fashion stocks for your $70,000 G/CLUBS payment? MR. KAMARAJU: Same objection. THE COURT: You may answer. A. No.
409 O5T1GUO2 Le Zhou - Redirect Q. Aside from discounts on G Fashion items, did you receive benefits for your $70,000 G/CLUBS payment? A. I would not say benefits, but I received small souvenir items, the mug and a bag of coffee. Q. A mug and a bag of coffee; is that correct? A. Yes. Q. Did you ever receive GTV stock for your $31,300 investment in GTV through Voice of Guo? A. No. Q. Would you have sent money to G/CLUBS if you knew that you would not get any stock? A. No. Q. Would you have loaned money to the UK Farm if you knew you would not get any stock? A. No. Q. You made the choice to invest in a G series offering based on whose statements? A. Could you repeat that question, ma'am. Q. Sure. You made the choice to invest in a G series offering based on whose statements about those offerings? A. Miles Guo's. Q. And how much money did you lose in the G series investment? A. As the money, because I——there was coin involved, I——even until this day, I didn't receive the full refund, but the coins, at the time, for——if I requested at the time, the value
410 O5T1GUO2 Le Zhou - Recross of the coins' value still added, I believe it estimated about $10. So for that value, it's also——I will consider that, so also additional value, but in the dollar, from the investment, the principal parts, I still didn't receive near $30,000. Q. And at the time that you participated in G series offerings, it was your understanding that Miles Guo personally guaranteed that you wouldn't lose any of your principal; is that correct? A. That's correct. MS. MURRAY: May I have a moment, your Honor. THE COURT: Yes. MS. MURRAY: Nothing further, your Honor. THE COURT: Recross? MR. KAMARAJU: Just briefly, your Honor. RECROSS EXAMINATION BY MR. KAMARAJU: Q. You were asked a series of questions about who was the leader of the——the ultimate leader of the farms, correct? A. Yes. Q. And you testified it was Miles Guo, right? A. Correct. Q. Okay. In connection with the money that you took in as the bank accounts, did you ever receive a single instruction from Miles Guo? A. Not direct from him, no.
411 O5T1GUO2 Le Zhou - Recross Q. Mr. Guo never reached out to you and said do X with the money, right? A. He did. Q. Mr. Guo reached out directly to you and said send the money here? A. No. In a meeting happened, took place with UK Farm, the part of the meeting, Miles Guo asked not just David Dai to return all the money, he asked all the member from UK London Club who, direct or indirect, has the money from followers, will do the same, by the deadline, to wire all the remaining balance to those accounts. Q. Okay. And he gave that direction to everybody, right? A. Yes. Q. Now you testified on redirect that you had lost $30,000, correct? A. Yes. Q. Okay. What is that based on? A. The principals. Q. But the principal of what, sir? A. The principal from——there's a portion from the VOG investments. Q. Okay. A. There were a portion from the coins I purchased. There were parts of the money from farm loan. Q. How much of the money came from the farm loans?
412 O5T1GUO2 Le Zhou - Recross A. I invested $21,000 for my farm loans. Q. Okay. So of the $30,000 that you lost, $21,000 you say is from the farm loans, right? A. Part of it. Q. I'm sorry. I don't understand. A. It's——you asked the $30,000, the principal. The $21,000 to the farm loan, that's principal. The VOG investment towards the GTV, that was also invest $31,000 and $300, but I do receive reimbursement from the fair funds. I got——there were about 7 percent loss. Then adding together, that's estimated about $30,000. Q. Now your farm loan principal was due to be returned at the end of the term of the loan, right? A. The contract stated that, yes. Q. Okay. And the term of the loan was extended in August of 2023, correct? A. It was force extended, without my consent. Q. They didn't need your consent, though, right? They had the right to do it under the contract, right? A. That I don't recall if it's their right to do that. Q. So you don't remember one way or the other. A. I receive a notice just purely for extension 24 hours——months, without any option to opt out. Q. Okay. So 24 months from August of 2023, right? A. Yes.
413 O5T1GUO2 Le Zhou - Recross Q. Okay. So your farm loan is not actually due to be repaid until next year, right? MS. MURRAY: Objection, your Honor. Scope. THE COURT: Sustained. MR. KAMARAJU: Your Honor, could we have a sidebar on that quickly. THE COURT: Yes. (Continued on next page)
414 O5T1GUO2 Le Zhou - Recross (At the sidebar) THE COURT: Your objection? MS. MURRAY: Yes, your Honor. So objection to scope but also objection on 403 grounds. There is an implication here that the witness could have contracted out of being defrauded. He just said that he was forced to extend the loan. He had no consent; it was just given to him. And Mr. Kamaraju is now suggesting that there was a provision in the original loan that permitted that. But there's not an ability to explain what this witness knew. And it also calls for him to bring a legal conclusion that he is not equipped to make. THE COURT: Certainly on the grounds of legal conclusion, he's not a lawyer. He can't interpret a contract. MR. KAMARAJU: I can ask him what his understanding is, right? THE COURT: You could ask what his understanding is. MR. KAMARAJU: Okay. I'll ask that question. MS. MURRAY: He can't contract himself out of a fraud, and that's the 403 basis for the objection. MR. KAMARAJU: They brought up the idea of the refund, your Honor, and allowed him to say that. They can allege it's a fraud; we're allowed to allege that it's not. MS. MURRAY: And your Honor, I would just note, he said he didn't recall what was in the contract. So he's already asked a question that Mr. Kamaraju answered, or Mr. ——
415 O5T1GUO2 Le Zhou - Recross THE COURT: Was that the testimony? Can you go back and see? MS. MURRAY: Regarding the——if this is the regarding the extension. THE COURT: You want to first find out whether he recalled if it's a term of the loan or the fact of the extension? MS. MURRAY: The fact of the ability of the counterparty to require an extension without consent. That—— MR. KAMARAJU: That was not what my question went to. My question just said simply——and I didn't ask the understanding, but if I were to ask, I'd say, so your understanding is that your loan is due to be repaid a year from now. MR. FERGENSON: No. THE COURT: I want to go back to the testimony, if you wouldn't mind. (Record read) MS. MURRAY: Your Honor, he's established what this witness knew and what he understood at the time, and he's implying to the jury that he can contract out of the fraud, and that's clearly impermissible under 403 and under black letter law. MR. KAMARAJU: I'm not saying anything whether he can contract out of the fraud. They asked what his loss was. They
416 O5T1GUO2 Le Zhou - Recross brought that out, not us. And I'm simply saying that he received a notice, he understands he received a notice, and is it his understanding that under the notice, the loan will be repaid a year from now. MS. MURRAY: Your Honor, there's no other probative purpose for this other than to imply he can contract out of the fraud. He said he wanted a refund of his money. He's speaking to his losses. That is what he has testified to. MR. KAMARAJU: Then they didn't need to bring up the losses. I'm entitled to respond. They put it in issue, your Honor, not me. MS. MURRAY: Your Honor, the fraud is complete as soon as the misrepresentation is made. THE COURT: His own understanding, that was it? MR. KAMARAJU: If his losses are relevant. Ms. Murray just said that the fraud is complete at the time of the misrepresentation. If that's true, then the actual losses he suffered are irrelevant. The government nonetheless elicited it, so I'm entitled to say, that number is wrong, you testified to an incorrect number, sir. MS. MURRAY: Your Honor, there's no accounting. He's asked his understanding, he's given a summary of his understanding of how much money he put in and how much money he was not repaid, which was the guarantee that Miles Guo made and did not follow through on.
417 O5T1GUO2 Le Zhou - Recross MR. KAMARAJU: This is a summation, your Honor. That's fine. It can be presented to the jury in summation. But prior to that we get to attack the very specific things they elicit. THE COURT: I'm going to allow what was your understanding. MR. KAMARAJU: Okay. So the question I'll ask, just to make sure I'm complying: So under the notice you received, what is your understanding as to when you will be paid back, or when you should be paid back? MS. MURRAY: And your Honor, we would ask that it go no further than that because we still maintain our objection that he's trying to elicit improper implications with this witness, that it's a 403 problem. MR. KAMARAJU: All of those implications that they keep arguing at sidebar can be dealt with by your Honor when you instruct the jury as to the law. MS. MURRAY: No. It's confusing the jury now with respect to this witness's testimony. MR. KAMARAJU: We had this argument just yesterday. THE COURT: I'm going to allow the question. (Continued on next page)
418 O5T1GUO2 Le Zhou - Recross (In open court) BY MR. KAMARAJU: Q. Sir, when we paused, we were talking about the extension notice. Do you remember that? A. Yes. Q. Okay. Based on your receipt of that notice, what is your understanding as to when you should be paid back your farm loan principal? A. The notice——I think it's invalid, because my previous contract signed with two entities, was both established by David Dai. Since David Dai was terminated and removed by the farm, and I believe those two entities both dissolved, automatically, the contract is void. Q. That's your legal conclusion, sir? MS. MURRAY: Objection, your Honor. THE COURT: Overruled. Is that your legal conclusion? A. Yes. Q. Where did you go to law school? MS. MURRAY: Objection, your Honor. THE COURT: Sustained. Q. Okay. So your view is that the farm loan contract is null and void now. A. It's void. Q. Okay. So if you were to sue somebody, you'd have nobody to sue.
419
O5T1GUO2 Maistrello - Direct
MS. MURRAY: Objection.
THE COURT: Overruled. You may answer.
A. Could you repeat the question, please.
MR. KAMARAJU: Could you read it back, please.
(Record read)
A. Yes.
MR. KAMARAJU: No further questions, your Honor.
THE COURT: All righty. Thank you, sir. You may step
out.
(Witness excused)
THE COURT: And the prosecution can call its next
witness.
MR. HORTON: The government calls Karin Maistrello.
THE LAW CLERK: Please raise your right hand.
(Witness sworn)
THE LAW CLERK: You may be seated.
THE COURT: Please state your name and spell it.
THE WITNESS: Karin Maistrello. K-A-R-I-N,
M-A-I-S-T-R-E-L-L-O.
THE COURT: You may inquire.
MR. HORTON: Thank you, your Honor.
KARIN MAISTRELLO,
called as a witness by the Government,
having been duly sworn, testified as follows:
420 O5T1GUO2 Maistrello - Direct DIRECT EXAMINATION BY MR. HORTON: Q. Good morning, Ms. Maistrello. A. Good morning. Q. What state do you live in? A. New Jersey. Q. What languages do you speak? A. English, German, Italian, French, Spanish, and Chinese. Q. And where do you currently work? A. I work for Google. Q. Turning back to 2018, who did you work for then? A. I was an employee of Golden Spring. Q. And—— MS. SHROFF: Your Honor, I'm sorry. We're having trouble hearing the witness. THE COURT: If you'd draw the microphone closer to you and speak up. THE WITNESS: Of course, yes. Q. Who is Guo Wengui? A. He was my boss at Golden Spring. Q. And how long did you work for Guo Wengui? A. From 2018 to 2020. Q. What are other names, Ms. Maistrello, if any, does Guo Wengui use? A. Miles Kwok.
421 O5T1GUO2 Maistrello - Direct MS. SHROFF: Objection to the form of the question, your Honor. THE COURT: Overruled. You may answer. A. Guo Wengui. I used to call him "Boss." Q. Could you please spell Guo Wengui. A. G-U-O, W-E-N, G-U-I. Q. You said Guo Wengui also goes by Miles Kwok. Could you spell Kwok. A. K-W-O-K. Q. Ms. Maistrello, who is Ho Wan Kwok? A. Go Wengui. Q. When you worked for Miles Guo, what did you call him? A. I used to call him Boss, in Chinese. Q. Do you see Boss here in the courtroom today? A. Yes, I do. Q. Could you please point him out and identify him by something he's wearing. A. He's wearing glasses and a blue suit, with a blue tie. MS. SHROFF: Your Honor, I'll stipulate that she's identified Mr. Miles Guo. THE COURT: All righty. Q. Ms. Maistrello, during the two years you worked for Boss, how many days a week did you work for him? A. It varied. Sometimes it was six, sometimes it was seven. Q. And during those six or seven days a week working for Boss,
422 O5T1GUO2 Maistrello - Direct what were your hours like? MS. SHROFF: Objection to the leading and the form of the question. THE COURT: Overruled. You may answer. You may answer. A. It depended on the work that we had to do, so usually I would be in the office quite early, around 8, all the way until 8 p.m. If I had any other projects, it could be as early as 4 a.m. or as late as midnight. It depended. Q. And how much of that time, Ms. Maistrello, did you spend with Boss? A. Every day. Q. And when you worked with Boss, how, if at all, did you communicate with him? A. All day long in one way or another. MR. HORTON: Ms. Loftus, can you please pull up for the witness what's been marked as GX 141. Q. Ms. Maistrello, what is this? A. It's a photo. Q. And what is it a photo of? A. There are two people in the photo. One is me and one is Boss. MR. HORTON: Government offers Government Exhibit 141. MS. SHROFF: No objection, your Honor. THE COURT: It is admitted.
423 O5T1GUO2 Maistrello - Direct (Government's Exhibit 141 received in evidence) MR. HORTON: Ms. Loftus, can you please publish it. Q. About when was this photo taken, Ms. Maistrello? A. This photo was taken in 2018. Q. And when did you start working for Boss? A. In 2018. Q. Was there a time that you enjoyed working for Boss, Ms. Maistrello? A. Yes. Q. And what did you enjoy about working for him? A. It was definitely very challenging. No day was alike. You definitely had to learn a lot and do it quickly. Q. Ms. Maistrello, what were the Rule of Law organizations? A. Rule of Law Society and Rule of Law Foundation were two nonprofit organizations that were founded in 2018, in November of 2018, that had the mission of helping Chinese people. Q. And who founded the Rule of Law organizations in 2018? A. Boss did. Q. What title, if any, did you have at Rule of Law, Ms. Maistrello? A. I was president and treasurer of Rule of Law Society. Q. Who gave you those titles at Rule of Law? A. Boss did. Q. As president and treasurer of the Rule of Law Society, Ms. Maistrello, were you in charge of that organization?
424 O5T1GUO2 Maistrello - Direct A. No, I wasn't. Q. Who was in charge of the Rule of Law organizations? A. Boss was. Q. You said the purpose was to help people in China. What, if anything, did Rule of Law do to help people in China? A. While I was there, nothing. Q. We'll come back to that. MS. SHROFF: Objection to the commentary. THE COURT: You may continue. Q. Ms. Maistrello, where did you work before you worked for Boss? A. In China. Q. And who did you work for in China? A. I worked at an oil company, and I was also teaching at university. Q. Who owned the oil company you worked for in China? A. In theory, the company was privately owned, but as everything in China, it was government owned and backed. Q. And how long were you working in China? A. Five years. Q. When did you move to the United States? A. In 2017. Q. How did you first hear about the opportunity to work for Miles Guo? A. I was contacted directly by a recruiter.
425 O5T1GUO2 Maistrello - Direct Q. Who was that recruiter? A. His name was, is, Steve Weber. Q. And after you first heard about the opportunity to work for Miles Guo from Steve Weber, who did you speak with next? A. He arranged a meeting, so a first interview, where I met Yvette Wang. Q. Who is Yvette Wang? A. At the time she introduced herself as Boss's assistant. Q. And where did she introduce herself to you? A. We met for our interview at the Plaza Hotel. MR. HORTON: Ms. Loftus, can you please display for Ms. Maistrello what's been marked as Government Exhibit 102. Q. Ms. Maistrello, what is Government Exhibit 102? A. It's a photo. Q. Who or what is it a photo of? A. Yvette. MR. HORTON: Your Honor, government offers Government Exhibit 102. MS. SHROFF: No objection, your Honor. THE COURT: It is admitted. (Government's Exhibit 102 received in evidence) MR. HORTON: Please publish it, Ms. Loftus. Thank you. BY MR. HORTON: Q. Ms. Maistrello, in your interview with Yvette Wang, what,
426 O5T1GUO2 Maistrello - Direct if anything, did she call Miles Guo? A. In that interview she called him the principal. Q. And what questions did Yvette ask you in that interview to work for the principal? A. She asked me a few personal questions, so she asked questions about my family, she asked whether I was married, I had kids; she also asked me if I had any connection to the CCP, so to the party. Q. How did you respond to Yvette Wang's question whether you had any connections to the CCP? A. I told her that I knew people who were party members but that was all of it. Q. How did Yvette Wang respond to that? MS. SHROFF: Objection as to the hearsay. THE COURT: Sustained. Q. What, if anything, was Yvette's reaction when you said you had connections to CCP members? THE COURT: So you need to repeat her words. MR. HORTON: Can I have one moment, your Honor. THE COURT: Yes. MR. HORTON: Thank you, your Honor. Q. Ms. Maistrello, after Yvette Wang interviewed you for the job with Boss, what happened next? A. I got a call from Steve Weber, who told me that the interview went well and he called me in for another interview.
427 O5T1GUO2 Maistrello - Direct Q. And with whom was that next interview? A. That was with Boss. MR. HORTON: Ms. Loftus, can you please take down the exhibit. Thank you. Q. Where did Boss interview you? A. At his home. Q. Where was his home? A. The Sherry-Netherland. Q. What is the Sherry-Netherland? A. The Sherry-Netherland is a luxury residential hotel that overlooks Central Park. MR. HORTON: Ms. Loftus, can you please display for the witness what's been marked as Government Exhibit 130. Q. Ms. Maistrello, what is Government Exhibit 130? A. It's a photo. Q. What is it a photo of? A. The Sherry-Netherland. MR. HORTON: Government would offer Government Exhibit 130. MS. SHROFF: I have no objection, your Honor. THE COURT: It is admitted. (Government's Exhibit 130 received in evidence) Q. Ms. Maistrello, where is the Sherry-Netherland located? A. It's between 57th and Fifth Ave. Q. And where in the Sherry did Boss interview you?
428 O5T1GUO2 Maistrello - Direct A. Do you mean which room? Q. Where in the building was your interview? Where did it take place? A. On the 18th floor. Q. What's on the 18th floor of the Sherry? A. That was his home. Q. Who met you when you arrived for the interview with Boss? A. Yvette did. Q. What happened first when Yvette met you at Boss's apartment? A. When I first arrived, she showed me around a little bit, just one area of the penthouse, and then we waited for Boss. Q. Please describe to the jury what that part of Boss's penthouse looked like. A. That specific part had various different rooms, so you can imagine like a corridor, a dining area, a tea room, a library, a gym, a movie room, and a piano room. Q. And what happened after Yvette showed you around Boss's penthouse? A. We sat down and we waited for him. Q. What happened next? A. He arrived. Q. And did Boss interview you when he arrived? A. Yes, he did. Q. What happened after your interview with Boss that day?
429 O5T1GUO2 Maistrello - Direct A. I went home, and I believe I received an offer on the same night. Q. Did you accept that offer? A. I did. MR. HORTON: Ms. Loftus, can you please show the witness what's marked as GX BR871. You can enlarge it just a little bit, Ms. Loftus. Thank you. Q. Ms. Maistrello, what is this document? A. This is the offer letter I received. MR. HORTON: Your Honor, the government would offer GX BR871. MS. SHROFF: No objection, your Honor. THE COURT: It is admitted. (Government's Exhibit BR871 received in evidence) MR. HORTON: Could you please publish it, Ms. Loftus. BY MR. HORTON: Q. Ms. Maistrello, the top of your accepted job offer says Golden Spring, New York. What was Golden Spring, New York? A. Golden Spring was my employer. Q. What was the business of Golden Spring, New York? A. It was presented to me on my very first day as an asset management company. Q. In your two years of working for Boss, what, if anything, did you come to understand Golden Spring did?
430 O5T1GUO2 Maistrello - Direct A. Golden Spring was a company that took care of Boss's wishes and desires, so it was the company through which we would purchase things for Boss, or take care of his things. MR. HORTON: Ms. Loftus, can you scroll down towards the bottom of this page, please. Thank you. Q. Ms. Maistrello, there's a signature on the page over a line that says Yvette Wang, COO, Golden Spring, New York. What is COO? A. Chief operating officer. Q. When you worked for Boss, how often, if ever, did you work with Yvette? A. Every day. Q. And who did Yvette work for? A. Golden Spring. MR. HORTON: Ms. Loftus, can you please show the witness what's been marked as Government Exhibit UK723. Q. Ms. Maistrello, what is this? A. It's a photo. Q. And who is it a photo of? A. There are four people in the photo. Boss is one of them, his wife, daughter—— MS. SHROFF: Objection, your Honor. THE COURT: If you'll step up. (Continued on next page)
431 O5T1GUO2 Maistrello - Direct (At the sidebar) THE COURT: What's the objection? MS. SHROFF: There's no relevance to the photo. She didn't take the photo, she doesn't know——there's no indication when this photo was taken, we don't know the year, we don't know how she would know anything about this photo. The government is using the photo to introduce people they want to put into evidence. This is——it has no relevance to the testimony. THE COURT: Go ahead. MR. HORTON: So the people in the photo, as Ms. Maistrello is about to establish, that she can recognize them from the photo. They're people who will feature in this case; they're already featured in this case. You don't have to take a photo to be able to authenticate it. It's black letter authentication. And I'm laying a foundation. I think she's almost there, if she's not there already. I'd ask to have the photo admitted. MS. SHROFF: What's the relevance of the photo? There's no relevance of the photograph to this witness's testimony. She's not going to testify about any—— THE COURT: He has said that these individuals will play a part in the prosecution's case. MS. SHROFF: Right, but not any part of her testimony. So it may be down the road, if she wants——so that's my first
432 O5T1GUO2 Maistrello - Direct objection, your Honor. I didn't object to the photo of Yvette because she's going to testify about Yvette. That's relevant because it pertains to some part of her testimony. She's not going to testify about any of these people. THE COURT: She can authenticate the photo by identifying these individuals. Let's see if she does. Overruled. MS. SHROFF: Your Honor, while we're at the sidebar, though, I did have an objection to the government lawyers constant looping of facts into each question. So each question adds in a response from the witness, instead of just simply asking the next question, there are facts baked in. The looping theory of asking questions, I object to it. And number two, your Honor, it's improper to refer to the defendant as "Boss" by the government. If she wants to use that in the answer, that's one thing, but to perpetuate that by asking the question and framing it as "Boss," I object to that as well. THE COURT: All right. So you'll call him Mr. Guo. I have overruled your objections with respect to the form of the question. MS. SHROFF: Thank you. THE COURT: Let's go back. (Continued on next page)
433 O5T1GUO2 Maistrello - Direct (In open court) THE COURT: You may continue. BY MR. HORTON: Q. Ms. Maistrello, do you recognize the people in this photograph? A. I do. MR. HORTON: Government would move to offer Government Exhibit UK723. THE COURT: She needs to identify the individuals. MR. HORTON: Oh, okay. Q. Can you identify——can you say who the people are in the photograph, left to right. A. Yes. Boss; his wife; Yvette; and their daughter. MR. HORTON: Government offers Government Exhibit UK723. THE COURT: It is admitted. (Government's Exhibit UK723 received in evidence) MR. HORTON: Please publish it, Ms. Loftus. Q. Ms. Maistrello, where was this photograph taken? A. In the dining room of the Sherry. Q. Turning back to Yvette Wang, what exactly did Yvette do for Mr. Guo? A. Everything. Q. What do you mean by everything? A. She was his right hand.
434 O5T1GUO2 Maistrello - Direct MS. SHROFF: Your Honor, I apologize, but I am having trouble hearing the witness. If you could just ask for her voice to be—— THE COURT: So you can bring the microphone closer and also speak up. THE WITNESS: I'll try, your Honor. BY MR. HORTON: Q. Ms. Maistrello, you said that Yvette Wang did everything for the defendant, was his right-hand person. What do you mean by that? MS. SHROFF: Objection to the testifying by the government, your Honor. THE COURT: Overruled. You may answer. A. So I said that she was his right hand. Q. And my question is: What exactly did that entail? A. From payments to giving directions to the staff. Q. And who else besides Mr. Guo, if anybody, did Yvette Wang report to? A. Only to Boss. MR. HORTON: Ms. Loftus, you can please take the picture down. Q. By the way, Ms. Maistrello, when you worked for the defendant, where did you work? A. Our office was located at 800 Fifth Ave. Q. And where else, if anywhere, did you work for Mr. Guo?
435 O5T1GUO2 Maistrello - Direct A. In 2019, we moved to another office on Lexington and, whenever it was needed, in his home. THE COURT: All righty. It's now 11:30, and so we're going to take our half-hour break. Members of the jury, remember that you're not permitted to discuss the case amongst yourselves. Don't permit anyone to discuss it in your presence. We will start promptly at noon. Ma'am, you may step down, but do not discuss the case. (Continued on next page)
436 O5T1GUO2 Maistrello - Direct (Jury not present) THE COURT: Counsel, is there anything before we return? MR. HORTON: Yes, your Honor. Just one matter the government wishes to raise for efficiency's sake. There was an objection early in Ms. Maistrello's testimony about hearsay with respect to a statement that Yvette Wang made. Yvette Wang is a co-conspirator of Miles Guo. The Court knows she was charged with Miles Guo. The testimony that was just elicited made clear that she was also an agent of Miles Guo. I believe Ms. Maistrello described her as doing everything for him and his right hand. So we submit that statements made by Yvette Wang in her capacity as Miles Guo's agent and in her capacity as a co-conspirator in this case are admissible. MS. SHROFF: Your Honor, I don't believe the government has shown the existence——I can't see the Court. I apologize. But I don't believe that the government has met its burden under the hearsay rules of having established a conspiracy with Ms. Yvette Wang and Miles Guo. There may have been an employer-employee relationship that they've established so far, but there is no indication that they've established a co-conspiratorial agreement between those two individuals. Additionally, your Honor, the evidence that the government was trying to elicit——and I apologize if I have this wrong, but I believe there were questions about what she was
437 O5T1GUO2 Maistrello - Direct asked during an employment interview, which certainly are not in furtherance of a conspiracy. They are employment-related questions. Finally, your Honor, even if the government is said to have established a conspiracy here, there is no relevance to what interview questions she is asked. The government has clearly established she got a job, and there's no allegation here that she got a job based on fraudulent pretenses. So for all those reasons, your Honor, I don't think that the government's argument is properly made. Thank you. MR. HORTON: Your Honor, there isn't a more paradigmatic agency situation than interviewing somebody to work for somebody else. Yvette Wang was there for Miles Guo to interview somebody who was hired to work directly with Miles Guo. If that's not agency, it doesn't exist. MS. SHROFF: She was not hired to work for Miles Guo, one, she was hired to work for Golden Spring. THE COURT: One moment. Did Ms. Wang plead guilty to conspiracy? MR. HORTON: Yes. THE COURT: All right. You may ask questions that elicit statements from Ms. Wang. MR. HORTON: Thank you. THE COURT: We will reconvene at noon. (Luncheon recess)
438 O5T1GUO2 Maistrello - Direct AFTERNOON SESSION 12:00 p.m. (Jury present) THE COURT: Please be seated. Remember that you're still under oath. THE WITNESS: Yes, your Honor. THE COURT: You may continue your direct examination. MR. HORTON: Thank you, your Honor. BY MR. HORTON: Q. Ms. Maistrello, when you worked for Guo, how often, if ever, did Guo tell you to buy things? A. Quite often. Q. And what things did Guo tell you to buy? A. It could be equipment for his media room, it could be suits, it could be furniture. Q. Let's talk about the furniture. What's Promemoria? A. Promemoria is a furniture brand. Q. And where is Promemoria based? A. They're based in Italy. Q. When, if at all, did you deal with Promemoria when you worked for Guo? A. All throughout the two years I worked there. Q. And what did Guo have you do at Promemoria? A. Sometimes buy furniture. Their furniture is custom made, so connect with——with the people from Promemoria to design
439 O5T1GUO2 Maistrello - Direct certain——certain furniture. Q. And where would that furniture that you bought for Guo go? A. That would go either to the office or to his home. Q. You said you bought suits. What kind of suits did you buy for Guo? A. Bespoke, tailored suits. Q. What do you mean by bespoke? A. Custom made. Q. What brand, if any, of suits did you buy for Guo? A. Mainly two. Brioni was one, and Stefano Ricci was the other. Q. And what was the process of buying those suits? A. So I would get in touch with the manager, for instance, at Brioni, choose some fabrics, then take them to Boss; he would choose the fabrics for his next batch of suits; the tailor would come either to the office or his home, measure him; then they would make the suit and come back with the delivery. Q. And how often would that happen during the two years you worked for him? A. That happened I would say twice a year. Once definitely when it was Chinese New Year and one more time. Q. How many suits were you buying for Guo each time? MS. SHROFF: Objection. Mischaracterizes her testimony. THE COURT: On his behalf.
440 O5T1GUO2 Maistrello - Direct Q. How many suits were you buying on Guo's behalf each time? A. I would say approximately a dozen. Q. How much did those suits cost, Ms. Maistrello? A. About 10,000 each. Q. And what did those suits look like? A. They had, of course, pants and a jacket; they were, well, in different colors or different fabrics, depending on the season or depending on what he wanted; they had his name on the interior pocket. Q. And what name was on the interior pocket? A. Miles Kwok. MS. SHROFF: I'm sorry. I didn't hear that. THE WITNESS: Miles Kwok. Q. Ms. Maistrello, what, if anything, did Guo tell you about cars he owned in China? A. He talked a little bit about his cars. He was very——well, he liked cars. He was very proud of his fleet of cars in China. Q. And what, if anything, did Guo ask you to do with those cars? MS. SHROFF: Objection. Is this all cars, some cars? THE COURT: With his cars in China? MR. HORTON: Yes, your Honor. THE COURT: Go ahead. A. He had a few favorite cars that he wanted to import to the
441 O5T1GUO2 Maistrello - Direct US. Q. And what kinds of cars were those? A. It was definitely a Lamborghini and a Rolls Royce. Q. And what exactly did Guo ask you to do with the Lamborghini and the Rolls Royce? A. To import them into the US. Q. And ultimately were you able to do that? A. No. Q. Why not? A. Because of import laws on——on cars. Q. What year did Guo ask you to import his Lamborghini? A. I think it was 2018. Q. Ms. Maistrello, what is a hutong? A. It's a traditional architectural structure, typical of the capital of China, Beijing, which has a courtyard and then houses surrounding the three sides of the courtyard. Q. What, if anything, did Guo tell you about his house in Beijing? A. He——well, he was very proud of it. He showed some photos, mainly of the interior, he showed photos of his artwork. Everything was custom made in the home. Q. And what did that property in Beijing look like? A. Luxury property, like a traditional Beijing home but luxury——a luxury one. Q. And how many buildings were on that property?
442 O5T1GUO2 Maistrello - Direct A. There were like more buildings attached to one another. Q. And what, if anything, did he tell you about who lived in his house in Beijing? A. He and his family. Q. What was Chateau Ridge? A. Chateau Ridge was a property located in Connecticut that he wanted to purchase. Q. And what, if anything, did you have to do with Chateau Ridge? MS. SHROFF: Objection as to the form of the question. THE COURT: Overruled. You may answer. THE WITNESS: Can I answer? THE COURT: Yes. A. There was a lot of back-and-forth for that property. I think I started working on it in 2018, where he first wanted to purchase it, so there were a lot of talks with the owner of the property. We went there several times to check the property itself and all the rooms and all the art that——that was in the house. Some of it he wanted to keep, some of it he didn't want it or he didn't need it. It was a quite long process. Q. You said that "we" went there a few times. Who was "we"? A. I went there a few times with him. Sometimes other colleagues tagged along. Q. And who were those other colleagues who went with you to Chateau Ridge?
443 O5T1GUO2 Maistrello - Direct A. In several instances——in several different instances, Yvette came once; I believe Hank also came. These are the people I remember. Q. What kind of property is Chateau Ridge? A. I guess the easiest way to describe it is like a castle. That's what "chateau" means. So it's——it looks like a French castle. The interior——like, the interior of the rooms are actually based off Versailles in France. Q. What, if anything, did Guo tell you about why he was looking to buy Chateau Ridge? A. He liked it. Q. What, if anything, did Guo tell you he was going to do with the property if he bought it? A. He was going to live there. Q. Did Guo ultimately buy Chateau Ridge? A. No, he did not. Q. When you were working for Guo between 2018 and 2020, what house, if any, did he buy? A. He ended up buying a property in Connecticut. Q. Now what did the Connecticut house that Guo bought look like? A. It was a very big house. I would call it a villa or a mansion. Q. And who, if anyone, lived in the mansion in Connecticut? A. He did, with the family.
444 O5T1GUO2 Maistrello - Direct MS. SHROFF: I'm sorry. I just continue to have difficulty hearing the witness, your Honor. THE WITNESS: I'm sorry. I'm trying, and this is the highest I can get. THE COURT: One moment, please. Okay. So I'm being told that the volume is at the highest, and so I'm just going to ask you to be very careful about speaking as loudly as you can. THE WITNESS: I will. THE COURT: Thank you. BY MR. HORTON: Q. Ms. Maistrello, who is Qiang Guo? A. Boss's son. Q. And can you please spell Qiang Guo. A. G-U-O, Q-I-A-N-G. Q. What other names, if any, does Boss's son go by? MS. SHROFF: Objection. THE COURT: Overruled. You may answer. A. Mileson. Q. What, if anything, did Guo tell you about Mileson's interests? A. He also had an interest in motors, so cars, motorbikes. Q. When you say he had an interest in cars and motorbikes, who are you referring to? A. His son.
445 O5T1GUO2 Maistrello - Direct Q. Did there come a time that Guo asked you to buy something for Mileson? A. Yes. Q. What did Guo ask you to buy for Mileson? A. It was a motorbike. Q. Ms. Maistrello, when Guo told you to buy suits for him or a motorcycle for his son, how would you pay for these things? A. It depended on the amount, so it could be either a wire transfer or a check. Q. And how would you get those checks? A. I would ask Yvette. Q. What would happen when you asked Yvette for a check for a particular purchase? A. She would give it to me. Q. Where did those checks come from? A. Golden Spring. Q. Ms. Maistrello, you said that you bought computer equipment for Guo. How did he pay for that equipment? A. The big bulk of the payments for media and broadcast equipment was paid through Saraca. Q. What was Saraca? A. Saraca was an entity that we used mainly for media and tech-related expenses. Q. Who was in charge of Saraca? A. I don't know.
446 O5T1GUO2 Maistrello - Direct Q. How would you know whether something should be paid for by Golden Spring or Saraca? A. I learned with experience, so I knew that certain expenses would be paid with one company and certain others with another company. Q. And who did you learn that from? A. By working there, or Yvette would tell me, oh, this expense would go under Saraca or under Golden Spring. Q. And what other companies, if any, paid for some of the things you bought? A. There was another entity called Genever. Q. What was Genever? MS. SHROFF: Objection. THE COURT: You may answer. A. It was an entity that was——was used mainly for personal purchases or for personal expenses that related to the Sherry. Q. And whose personal expenses was Genever used to pay for? A. Boss's. Q. Ms. Maistrello, who was in charge of Genever? A. I don't know. Q. Where was Golden Spring's office located? A. When I started working, it was located at 800 Fifth Ave. Q. And where is Saraca's office located? A. So the official address, I don't know, but it was operating from the same office, so 800 Fifth Ave.
447 O5T1GUO2 Maistrello - Direct Q. And what do you mean by official address? A. The one that was, for instance, filed in the official paperwork. I've never seen that. Q. Who, if anybody, would you speak with to authorize an expense from one of the companies that Guo——that you've just testified about? MS. SHROFF: Asked and answered. THE COURT: You may answer. A. So whenever Boss used to ask me to buy something, I would——at a certain point I understood where the money should——should be coming from, and I——and I asked Yvette directly for a certain amount of money from a certain company. Q. Who was Max Krasner? A. Max was my colleague at Golden Spring. MR. HORTON: Ms. Loftus, can you please pull up for the witness what's been marked as Government Exhibit SM62. Q. Ms. Maistrello, what is this? A. It's a document. Q. And what is this document? A. It's a payment request form. Q. Is your name on this form? A. Yes. Q. And what does this form indicate? A. Being a payment request form, it looks like a purchase was made or it was about to——to be made and I requested it.
448 O5T1GUO2 Maistrello - Direct MR. HORTON: Your Honor, government would offer Government Exhibit SM62. THE COURT: No objection? MS. SHROFF: None, your Honor. THE COURT: It is admitted. (Government's Exhibit SM62 received in evidence) MR. HORTON: Could you please publish it, Ms. Loftus. Ms. Loftus, can you zoom in on the line that says Approved by Max Krasner. BY MR. HORTON: Q. Ms. Maistrello, what did Max Krasner do for Boss——excuse me——for Mr. Guo? A. He was an employee of Golden Spring and he worked in accounting. Q. And what did his job entail? A. A lot of payments. I know he was working on tax forms. Q. And how often, if ever, did you interact with Max Krasner at work? A. Every day. Q. And what would you go to him about? A. Well, we——we were very close in——in the office, meaning that we——we worked together, but whenever I needed something, I needed a payment to be done, for instance, by Saraca, I would go to him. Q. Who was Max Krasner's Boss?
449 O5T1GUO2 Maistrello - Direct A. Go Wengui. Q. Who else, if anybody, did Max report to? A. Yvette. MR. HORTON: Ms. Loftus, can you please go to the top of this page that we're on and highlight what's up top there. Q. Ms. Maistrello, can you describe what's at the very top of your payment request form. A. Do you want me to read, like, the title? Q. If you could just describe what we're seeing at the very top of this page. A. Okay. So there is the company name at the top and then there are——there is a payment request form, and then there are a few lines that indicate the payee for this payment, the street and address and the form of payment, with the amount of the payment and the purpose of the expense. MR. HORTON: Ms. Loftus, can you please take the exhibit down and show the witness what's marked as Government Exhibit 110. Q. Ms. Maistrello, who's this? A. This is Max. MR. HORTON: Government offers Government Exhibit 110. MS. SHROFF: We have no objection, your Honor. THE COURT: It is admitted. (Government's Exhibit 110 received in evidence) MR. HORTON: Ms. Loftus, please publish it.
450 O5T1GUO2 Maistrello - Direct BY MR. HORTON: Q. Now which of Guo's companies did Max work with? A. Golden Spring and Saraca, mainly. Q. In the two years you worked for Guo, how much, if ever, were you with Guo and Max at the same time? A. Definitely a few times a week. Q. And when, if ever, did Guo tell Max to buy things? A. About——can you repeat the question. Q. Sure. When, if ever, did Guo tell Max to buy things? A. It happened if Max was around him. It usually happened at——when Boss had an idea and he wanted to buy something, then he would ask the person he had in front in that very moment. Q. And who, if anybody, would Max need to go to after that for permission? MS. SHROFF: Objection as to personal knowledge. THE COURT: If you know, you may answer. A. Yvette. MR. HORTON: Okay. Thank you, Ms. Loftus. You can take this down. Q. Ms. Maistrello, who is Defeng Cao? A. He was a colleague for the first few months while I was at Golden Spring. Q. And what did Defeng Cao do? A. He would do security, security work. Q. Who else, if anybody, did security work?
451 O5T1GUO2 Maistrello - Direct A. I would say that we had two separate teams, so we had Chinese team and we had an American team. Q. And how often, if at all, did you speak with the people on these security teams? A. Every day. Q. What exactly did the security teams do? A. They were doing a little bit of everything, so from driving, handiwork, assembling, disassembling furniture, receiving packages, these things. Q. What kind of security work did these teams do? A. Not much, really, in the sense that there was no need for security, like, for bodyguard in this true sense of the term. Q. And why do you say that there was no need for security? A. I believe that there was no danger or threat posed to Boss. Q. In the two years working for Guo, what makes you say that? A. Nothing has ever happened in terms of security. Q. How did you know what those teams were doing all day? A. They were telling me. Q. What was your understanding, if any, about why they were called security teams? A. I assumed that the word—— MS. SHROFF: Objection to what she assumed. THE COURT: Sustained. Q. Do you have an understanding of why they were called security teams?
452 O5T1GUO2 Maistrello - Direct A. Yes. Q. What is that understanding? A. The term security, security team, or bodyguard is better than handyman. Q. What do you mean it's better? A. Well, it definitely sounds better when you need to hire someone. Q. And who, if anybody——withdrawn. Turning specifically to Defeng Cao, what kinds of assignments did Guo give him? A. So at the very beginning, when we were still setting up the office, there was a lot of furniture moving. He was taking furniture from several storage places to the office. He was sometimes painting the office too. Q. And how long had Defeng Cao worked for Guo? A. I don't know the number of years. Q. And what, if anything, did you understand about how Defeng Cao came to work for Guo? A. From China. Q. And what, if anything, do you understand about Defeng Cao's relationship with Guo's family? A. They were in good terms. MR. HORTON: And Ms. Loftus, if you could please show the witness what's marked as Government Exhibit UK728. Q. Who is this a photograph of?
453 O5T1GUO2 Maistrello - Direct A. There are three people in the photo. Boss is one, his wife is the other, and Cao is the other. MR. HORTON: Your Honor, government moves to admit Government Exhibit GX UK——pardon me. MS. SHROFF: Your Honor, we have the same objection as before. And I believe that the 403 analysis here would be higher. THE COURT: It is admitted. (Government's Exhibit UK728 received in evidence) MR. HORTON: And it's 728, just so it's clear. Could you please publish it, Ms. Loftus. BY MR. HORTON: Q. Ms. Maistrello, who is the person kneeling in the photo? A. That's Ho. Q. And is the name you said the same as Defeng Cao? A. Yes. Q. And who are the two people in the right of the photograph? A. The man is Boss and the woman is his wife. Q. And what, if anything, was Defeng Cao's relationship with Guo's daughter? A. They were together. MR. HORTON: Ms. Loftus——actually, please leave it up. Q. What understanding, if any, did you have about why Guo hired those security teams? MS. SHROFF: Objection. It's not based on personal
454 O5T1GUO2 Maistrello - Direct knowledge, your Honor. Also, may we approach? THE COURT: Yes. (At the sidebar) THE COURT: I suppose that it's the government's contention that they did not work in a traditional security role because Mr. Guo did not indeed fear that he was in any kind of danger; is that your contention? MR. HORTON: We're trying to elicit——so she worked with Mr. Guo six, seven days a week for two years. She also spoke often with the people who were on these so-called security teams. I'd like to ask——I did ask if she understood why they were there. And I think the different question is, did she understand, speaking almost every day with Mr. Guo, why he had hired them, particularly when their tasks were different than what the label might suggest if people were hearing this for the first time. THE COURT: You asked a question like that before. MR. HORTON: So your Honor, I did ask if she knew why they were there, sort of what was her understanding from interacting with them almost every day for two years, and a lot of the questions in this testimony are about what Mr. Guo told her, right? She was working by his side almost all week, almost all day for two years. I think it's relevant, if he said anything to her why he had these teams, for the jury to know why he told her that.
455 O5T1GUO2 Maistrello - Direct THE COURT: I agree it could come in. I just thought it might have already been asked. MS. SHROFF: Many times. MR. HORTON: Well, with respect, I do think I was asking a different question, which was from her own observations, setting aside what anybody told her, what did she see them doing. And now I'd like to elicit: Did he ever tell you why he hired them? THE COURT: Okay. That's fine. MS. SHROFF: Your Honor, the security team was not hired after she took the job. The security team was in place for years before that. And there's no evidence that she's the one who had anything to do with them being hired. It's also very amorphous to say a security team. There's no indication of who—— MR. HORTON: I didn't mean any disrespect to Ms. Shroff. I was just trying to—— THE COURT: Go ahead. MS. SHROFF: ——of who she's referring to. Thirdly, your Honor, what Mr. Guo said to her about why they hired a specific person would be also irrelevant. It's not in furtherance of any conspiracy, so I don't know how it could even fall under a hearsay exception. But most important, your Honor, this is cumulative, it is in fact not quite relevant to any issues here, and if he's
456 O5T1GUO2 Maistrello - Direct trying to make the point that this was all a big farce, I believe the point has been made. I just have to add one thing, your Honor. I'm completely deaf in my left ear. I'm not only having trouble hearing her, I'm also having trouble hearing him, even though he's standing right next to me, so if you could please ask him to use the microphone, I would really appreciate it. THE COURT: Of course. Speak into the microphone. I have checked with the AV. MS. SHROFF: I know. It's my problem. I can hear fine from here. It's this part. MR. HORTON: I'll do my best to keep it up. THE COURT: I will ask if there's any way of amplifying the sound going beyond the equipment that we already have. MS. SHROFF: I understand, your Honor. I know you've tried. I just am having——I didn't want you to think——I want you to understand why I'm having trouble. THE COURT: I will continue to try. But I will permit the question. The objection is overruled. (Continued on next page)
457 O5T1GUO2 Maistrello - Direct (In open court) THE COURT: So in order to better hear you, I'd like to try the handheld microphone and see how that works. You may continue. MR. HORTON: Thank you, your Honor. BY MR. HORTON: Q. Ms. Maistrello, what, if anything, did Guo tell you about why he hired these security teams? A. What he said is that it was for security purposes. Q. Turning to the exhibit in front of you, can you——looking at the exhibit that's in front of you, Ms. Maistrello, you identified the person on the right as Guo's wife. What is her name? A. I don't remember it right now. Q. And can you please spell Defeng Cao. A. D-E-F-E-N-G, C-A-O. Q. What was Guo's relationship like with Defeng Cao? A. It was good. Q. And what sorts of assignments did you see Guo give to Defeng Cao? A. Again, at the very beginning, it was really about setting up the office, so there was a lot of storage moving, furniture moving, assembling, painting. Q. And you said that there were Chinese team and American team. What differences, if any, were there between the work
458 O5T1GUO2 Maistrello - Direct they did? A. The——the Chinese team was in a way more trusted and closer to Boss than the American one. The American teams were also coming and going. Q. And you said the Chinese teams were closer and more trusted. What did that mean? A. So there were things that maybe Boss didn't feel comfortable sharing with the American team, or he wanted to go somewhere he didn't want people to know, so he would definitely—— MS. SHROFF: Objection, your Honor. THE COURT: Overruled. You may continue. A. So he would definitely ask the——the Chinese team to help him with those. MR. HORTON: Ms. Loftus, you can please take the exhibit down. Q. Ms. Maistrello, who is William Je? A. William Je was Boss's friend and finance person. Q. And what does finance person mean? A. He was the person who would handle the investments and financing for Boss. Q. When, if ever, did you meet William Je? A. Several times over the course of two years. Q. And where did you meet him?
459 O5T1GUO2 Maistrello - Direct A. Mainly at the office. Q. And when, if ever, did you sit in meetings with William Je? A. Several times during both 2018 and 2019. Q. And what were the topics of those meetings? A. So in 2018, the main topics were Guo Media and also Rule of Law, so Rule of Law Society and Foundation. In 2019, it was mainly the same thing. Q. What was Guo Media? A. Guo Media was a platform, a social media platform that Boss started to broadcast——for his broadcasts. Q. During your two years working for Guo, when, if ever, did you work on Guo Media? A. All along in one capacity or another. Q. We'll come back to that. What other names, if any, do you know William Je by? A. Only his——his Chinese or Cantonese name. Q. What is his Cantonese name? A. Kin Ming Je. Q. Could you please spell that. A. K-I-N, M-I-N-G, G-E. MR. HORTON: Ms. Loftus, for Ms. Maistrello only, can you please display GX UK764. Q. Ms. Maistrello, who is in this photograph? A. It's William. MR. HORTON: Thank you, Ms. Loftus. You can take that
460 O5T1GUO2 Maistrello - Direct down. And Ms. Loftus, can you please display what's been marked as GX 103. Q. Who is in this photograph? A. It's William. MR. HORTON: Government would offer Government Exhibit 103, your Honor. MS. SHROFF: No objection, your Honor. THE COURT: It is admitted. (Government's Exhibit 103 received in evidence) MR. HORTON: Please publish it, Ms. Loftus. BY MR. HORTON: Q. Ms. Maistrello, did there come a time that William Je asked you to take a position with another company? A. Yes. Q. And what exactly did William Je ask you to do? A. He asked me to sit on the board of directors of one of his companies. Q. What was that company called? A. ACA Capital. Q. Where were you when William Je asked you to sit on the board of ACA Capital? A. I was at the office. Q. And what, if anything, did William Je say about why he was asking you to sit on the board of ACA Capital?
461 O5T1GUO2 Maistrello - Direct A. He mentioned—— MS. SHROFF: Objection as to hearsay. THE COURT: If he gave you an explanation, you may answer. A. He told me that they were looking for investments in New York and in the US. That was the reason. Q. And what experience, if any, had you had with investments? A. None. Q. What experience, if any, had you had serving as a corporate director? A. None. Q. Who introduced you to William Je before he asked you to sit as a director at that company? A. We were introduced by Boss. Q. Did you agree to serve as a director of ACA Capital? A. Yes. Q. And why did you agree to take that position at ACA Capital? A. I trusted William. He——he was asking for it, and I saw no reason to——to decline. Q. Why did you trust him? A. I trusted him as I trusted Boss. He was an extremely kind person; in my opinion, trustworthy. Q. For about how long did you serve as a director of ACA Capital? A. A few months.
462 O5TVGUO3 Maistrello - Direct Q. And what is ACA Capital? A. I don't know. Q. What work, if any, did you do at ACA Capital? A. I didn't do anything. Q. Did there come a time, Ms. Maistrello, that you had to sit for a deposition in your role as a director at ACA Capital? A. Yes, I sat at a deposition, but I had already resigned. Q. And what is a deposition? A. A deposition is a legal procedure where an individual offers sworn evidence. Q. How did you find out you were going to have to sit for a deposition as a director at ACA Capital? A. I was subpoenaed. Q. And after you were subpoenaed, what did you do? A. The next day, I went to the office and I asked our counsel to explain what it was. (Continued on next page)
463 O5TVGUO3 Maistrello - Direct BY MR. HORTON: Q. And what was the name of the person you asked for an explanation? A. Daniel Podhaskie. MR. HORTON: Ms. Loftus, can you please display for the witness what has been marked as Government Exhibit 105. Q. Ms. Maistrello, who's in this photograph? A. That's Daniel. MR. HORTON: The government offers Government Exhibit 105. MS. SHROFF: No objection, your Honor. THE COURT: It is admitted. (Government's Exhibit 105 received in evidence) MR. HORTON: Would you please publish it, Ms. Loftus. Q. Ms. Maistrello, what did you do after you took the subpoena to Dan Podhaskie? A. I told Yvette. MR. HORTON: Ms. Loftus, you can please take the exhibit down. Q. And how did Yvette respond when you told her about the subpoena? A. We never spoke about the subpoena itself, but she arranged counsel for me. Q. And when, if ever, did you meet with those lawyers? A. I believe it was July.
464 O5TVGUO3 Maistrello - Direct Q. Ms. Maistrello, when you met with those lawyers that Yvette arranged for you, had you ever seen them before? A. Yes. Q. And where had you seen them? A. At our office. Q. And what understanding, if any, do you have about why you had seen them before at your office? A. They came to the office several times for other lawsuits. Q. On the day of your deposition, who accompanied you? A. Yvette did. Q. What kind of room was your deposition in? A. It was a meeting room. Q. And where were you sitting? A. So there was a long table, and I was sitting almost in the middle. THE COURT: One moment, please. You may continue. MR. HORTON: Thank you, your Honor. Q. Was Yvette the only person who accompanied you to the deposition? A. Yes. Q. Ms. Maistrello, was Yvette there as your lawyer? A. No. Q. Was there a lawyer there to represent you at the deposition?
465 O5TVGUO3 Maistrello - Direct MS. SHROFF: Objection. THE COURT: Overruled. You may answer. A. Yes, the lawyer was already there at the office. Q. I see. And where with respect to you was Yvette sitting during your deposition? A. Two seats to my right. Q. Where did you go after the deposition ended? A. We went and had lunch. Q. And where did you go after lunch? A. Back to the office. Q. Who did you have lunch with, by the way? A. With Yvette. Q. And what happened when you got back to the office with Yvette? A. We went to boss's office and talked to him. Q. And what did you and Yvette talk to boss about after your deposition? A. Yvette told boss how it went. Q. How did you think it went? MS. SHROFF: Objection as to relevance. THE COURT: Overruled. You may answer. A. It was my first deposition, so I didn't really have an idea of how it went. Q. What did Yvette say to boss about how it went? A. She said it went really well.
466 O5TVGUO3 Maistrello - Direct Q. And what, if anything, did Yvette say to you in that meeting with Guo about how your deposition went? A. She said I was very good. I did good. Q. What, if anything, did Yvette call you in that meeting? A. She referred to me as a person who, like, does the right thing or does things the right way. Q. What language did she say that in? A. In Chinese. Q. And what is the translation in English of what she called you? A. The literal translation would be like a little flute or something along those lines. Q. By the way, Ms. Maistrello, in your two years working for Guo, what language did you speak with him? A. In Chinese. THE COURT: Do you mean Mandarin? THE WITNESS: Yes. Q. Ms. Maistrello, what month and year was your deposition for ACA Capital? A. July of 2019. Q. You said you had -- you said you were no longer director at ACA Capital. How did you leave your director position at ACA Capital? A. I sent an email to William telling him that I would like to resign.
467 O5TVGUO3 Maistrello - Direct Q. And why did you want to resign from ACA Capital? A. I wasn't doing anything for the company. I had overheard that there were, like, some sort of legal troubles. And not knowing the company and not knowing the role I had in the company, I just didn't want to be involved in any of it. Q. Ms. Maistrello, as you sit here today, what's your understanding of what the purpose was of your deposition in 2019? MS. SHROFF: Objection to what her understanding is today. It's not relevant, your Honor. THE COURT: Overruled. You may answer. A. I don't have an understanding of that deposition. Q. Ms. Maistrello, turning back to the Rule of Law organizations, when did you first hear that Guo was starting the Rule of Law organizations? A. That was in the summer of 2018. Q. How long had you been working for Guo at that point? A. Several months. Q. When you first heard that Guo was starting the Rule of Law organizations, what did you think about it? A. I was really, really happy. Q. Why were you really happy? A. Those two organizations were -- were a step further in what boss wanted. And I felt that at that point we could really put things from theory into practice.
468 O5TVGUO3 Maistrello - Direct Q. What, if anything, did you donate to the Rule of Law organizations? A. I donated $500. Q. And why did you donate? A. I believed in the organizations. I was president of one of them; so if I don't donate, who would? Who does? Q. And what year did you donate? A. It was either 2018 or early 2019. Q. Did the Rule of Law organizations have boards of directors? A. Yes. Q. And what role, if any, did you have on the board of directors? A. I was a member. Q. Who else served on that board with you? A. So on the board of Rule of Law Society, we had Steve Bannon, who was chair; initially, Sasha Gong, Bill Gertz, and Jennifer Mercurio. Q. Who was Steve Bannon? A. Steve Bannon was the former political adviser of former president Donald Trump. Q. And how did Steve Bannon get involved with the Rule of Law organization? A. He was very much involved in all the work at the office around 2018. Q. Who got Mr. Bannon involved with the work around the
469 O5TVGUO3 Maistrello - Direct office? A. Boss did. Q. And what exactly did Mr. Bannon do around the office? A. Whenever he was at the office, he was there for meetings with boss. Q. What kind of meetings? A. So initially in 2018, there was a lot of planning around the Rule of Law organizations. Later on it was more strategic meetings about CCP and China -- U.S./China relations. Q. What exactly did Steve Bannon do with the Rule of Law organizations? A. He didn't really do anything. Q. What, if anything, was Mr. Bannon paid for the work he was doing at the office? MS. SHROFF: Objection. Assumes facts not in evidence. THE COURT: Overruled. You may answer. A. He was paid over a million dollars divided in four installments. Q. Where did you learn that? A. I was at the office. Q. How was Mr. Bannon paid that money? A. Via check. Q. Where did those checks come from? A. I don't remember the entity they came from; it might have
470 O5TVGUO3 Maistrello - Direct been Saraca. Q. Who decided that Mr. Bannon would get paid that money? A. I don't know. Q. Ms. Maistrello, what role, if any, did you have in planning the launch of the Rule of Law organizations? A. There was a lot of planning that year, so we launched in November of 2018. We had a pretty big press conference on November 21st of 2018. So there was a lot of coordination for people to come into New York City for the conference, presentations for the keynote speakers, just a few months really of organizing. Q. When did that planning begin? A. Late September 2018. Q. When was the press conference you just referenced, when did that take place? A. November 21st of 2018. Q. During that planning phase, what, if anything, did Guo say about how the Rule of Law organizations would be funded? A. He said that he would be -- MS. SHROFF: Your Honor, are we referring to private conversations between the two of them? It's an open-ended question. THE COURT: What time? When? MR. HORTON: Well, Ms. Maistrello testified that there was a planning phase for some period of months before the
471 O5TVGUO3 Maistrello - Direct launch; and that she participated in it; and that Mr. Guo did too; Mr. Bannon did too. I was asking her about conversations in that planning phase between the three people. MS. SHROFF: All of them over all these months. MR. HORTON: Sounded like it was one or two months. THE COURT: You may answer. A. Can you repeat the question please? Q. Yes. During the planning phase, planning for the Rule of Law organizations, what, if anything, did Mr. Guo say about how the Rule of Law organizations would be funded? A. So he said that he would donate the first $100 million as a first donor or as a sponsor. Q. Ms. Maistrello, as president and treasurer of the Rule of Law Society, did Mr. Guo ultimately make $100 million donation? A. No. Q. And how was Rule of Law actually funded? A. It was funded through donations that were coming from followers. Q. What do you mean by "followers"? A. So boss had a pretty huge following, following base. And those followers donated starting from 2018. Q. Did there come a time that Rule of Law broadcast a fundraiser? A. Yes, that was the one-year anniversary. Q. And where were you during that broadcast fundraiser?
472 O5TVGUO3 Maistrello - Direct A. At the office. Q. Where was the fundraiser broadcast? A. When or where? Q. I'm sorry, where was the fundraiser broadcast? A. At the office. Q. And on what outlet, if any, was the fundraiser broadcast? A. On Guo Media. Q. What was GTV? A. GTV was a platform for -- I'm sorry. I'm thinking about something else. When I was there, GTV and Guo Media were actually the same thing. Q. And what, if anything, did the "G" in GTV stand for? A. Guo. THE COURT: When you refer to "the office," what location? THE WITNESS: So the first office we were at in 2018 and early 2019 was 800 Fifth Ave. Well, in 2019, we moved to 64th and Lex. Q. Ms. Maistrello, what, if anything, did you do to plan the fundraiser? A. Nothing. Q. And were you present when the fundraiser was being broadcast? A. I was. Q. What, if anything, was Mr. Guo's role in the fundraiser?
473 O5TVGUO3 Maistrello - Direct A. He was broadcasting over the course of several hours. Q. And who were you with when you were at the fundraiser? A. Initially, at the office I was on the second floor. And then -- so with a couple of colleagues. And then I moved to the first floor, where the actual broadcast was happening. Q. Which colleagues were you with? A. I was with Melissa, Max, and Yvette. Q. And what, if anything, were you asked to do during the Rule of Law fundraiser on Guo Media? A. So we were asked to transfer money from one company or one entity to the other so that we could take screenshots of these money movements and broadcast them live on TV. Q. And what companies were you asked to move money from during the Rule of Law telecast? A. It was mainly Saraca and Golden Spring. Q. Who asked you to move money from Saraca and Golden Spring's accounts during the Rule of Law fundraiser? A. Yvette did. Q. What, if anything, did Yvette say was the purpose of moving money from Saraca and Golden Spring's accounts during the Rule of Law fundraiser? A. So the final purpose was to have these big amounts of money shown on screen so that people would see that others were donating, and we were able to solicit more money this way. Q. Where did the Saraca and Golden Spring money that you were
474 O5TVGUO3 Maistrello - Direct asked to move that day come from? A. I don't know. Q. And where were you asked to transfer the Saraca and Golden Spring money during the Rule of Law fundraiser? A. At the office. Q. I'm sorry. Where were you asked to transfer those funds, from Saraca and Golden Spring to where? A. Oh, sorry. To Rule of Law. Q. What was your reaction to the request from Yvette to move the Saraca and Golden Spring money during the fundraiser? A. I didn't want to do it. Q. Why didn't you want to do it? A. Because those transfers were not real; those were internal transfers. It was not real money coming in, so I didn't agree with that. Q. And what was Yvette's response when you told her that you didn't agree with moving that money during the fundraiser? A. She saw that I was upset. And she told me that, Okay, don't do it; somebody else is going to do it. Q. Did somebody else do it? A. Yes. Q. And who was that? A. Melissa and Max were doing it. Q. You said earlier that Rule of Law ultimately did nothing to help people in China. What happened when the Rule of Law board
475 O5TVGUO3 Maistrello - Direct met? A. We only met once as a board meeting in January of 2020. And in that occasion, we discussed things to do or to be done. But prior to that, we never really sat down as board members. Q. Other than that in-person meeting, how often would you communicate with other Rule of Law board members? A. Not too often. Q. What, if anything, did the board vote on? A. Nothing really. Q. Did there ever come a time that you cast a vote as a board member in Rule of law? A. Yes. Q. What was Mr. Guo's title at Rule of Law? A. He was sponsor. Q. And what position did he have, if any, on the Rule of Law board? A. He didn't have any. Q. Who was in charge of the Rule of Law board? A. Boss was. Q. You said there came a time that you cast a vote as a board member. What was the subject of that vote? A. It was in 2020. So after COVID hit, there was like a proposal to purchase PPE and ship it to China. Q. You said there was a proposal to purchase PPE. What is PPE?
476 O5TVGUO3 Maistrello - Direct A. In this very case it was masks. Q. What kind of masks? A. N95 masks for COVID masks. Q. Whose proposal was it for Rule of Law to purchase N95 masks? A. Boss's. Q. And where in that proposal were the masks? What was to be done with the masks in that proposal? A. So they were to be shipped to China. Q. How did you vote in that proposal? A. I voted no. Q. And, Ms. Maistrello, after you voted no on Mr. Guo's proposal for Rule of Law to ship N95 masks to China, what happened next? A. Our paralegal came -- MS. SHROFF: Objection. THE COURT: Overruled. You may answer. MS. SHROFF: Your Honor, the government is eliciting hearsay. We have an objection. THE COURT: If you'll step up, please. (Continued on next page)
477 O5TVGUO3 Maistrello - Direct (At sidebar) THE COURT: So I need a ruling that co-conspirator hearsay could come in. Isn't that what you're asking for? MR. HORTON: It comes in under that exception, your Honor; it comes in under the agency exception. She's testifying about official business, the Rule of Law organizations. Paralegal is a classic agent. MS. SHROFF: The paralegal is in a conspiracy with this witness and with Miles Guo to send PPE masks to China without having established how that falls within the scope of this conspiracy. The statement they want to elicit is the paralegal asking this lady if it was, in fact, a mistake that the masks are being in China. Through that statement they want the jury to conclude, of course, that there would be no reason to send these masks to China. How the paralegal becomes a participant in this conspiracy is unclear to me; nor is it clear to me how this person becomes a member of that conspiracy. THE COURT: I don't know that they're holding her out as a co-conspirator. Go ahead. MR. HORTON: I would just say set aside the co-conspirator exception for one moment. Paralegal is an agent of the organization. The paralegal is also asking a question. A question is not hearsay; it's not a substantive statement.
478 O5TVGUO3 Maistrello - Direct It's black letter that a question is not offered for its truth, so it's not hearsay. Setting that aside, this fills in the context of testimony that's already been elicited that there was a proposal to a specific thing by a specific person, and there was a vote on that proposal. This detail is about what happened at the conclusion of that vote and it completes the story. MS. SHROFF: Completing the story does not help the argument that it is hearsay. She is not an agent of Mr. Guo. It should be very clear. She is an employee of Rule of Law Foundation. They have, in fact, established that he had no position at Rule of Law. She's testifying as an agent of the Rule of Law Foundation. And therefore, if they want to bring this out when Rule of Law is part of a criminal action, then her statement would fall within a hearsay exception. Here, it would not. MR. HORTON: Rule of Law is in the indictment. Second thing is that she -- it's true that the witness testified that Mr. Guo had a title at Rule of Law; it's also true that she testified that despite that, he controlled it. MS. SHROFF: She is not an agent of -- THE COURT: Here's my ruling: The objection is overruled. (Continued on next page)
479 O5TVGUO3 Maistrello - Direct (In open court) BY MR. HORTON: Q. Ms. Maistrello, you said that Mr. Guo did not have a title at the Rule of Law Foundation? MS. SHROFF: I believe she's asked and answered that question several times, your Honor. THE COURT: We've already established that. Move forward, please. Q. Did Mr. Guo have a title at Saraca? A. No. Q. Did Mr. Guo have a title at Golden Spring? A. No. Q. Why not? MS. SHROFF: Objection. THE COURT: Overruled. You may answer. A. I don't know. Q. Did Mr. Guo have -- withdrawn. Turning back to your vote against the proposal to send the N95 masks to China, you said that after you voted no, a paralegal asked you a question. What was the question that the paralegal asked you? A. She asked me whether it was a typo. Q. How did Rule of Law pay for those N95 masks that were sent to China? A. With the money from Rule of Law.
480 O5TVGUO3 Maistrello - Direct Q. Where did that money come from? A. From donations. Q. Ms. Maistrello, when else, if ever, did Rule of Law buy N95 masks with donor funds? A. In 2020, so when COVID hit. Q. And what did Rule of Law do with those other N95 masks that it bought with donor funds? A. So part of it went to boss's house, we kept a couple of boxes at the office, and another part of it was distributed to NYPD precincts around the city. Q. Why did you vote against the proposal to send N95 masks to China with donor money? A. Well, because N95 masks were manufactured and produced in China; so it didn't make any sense to me that we bought them from China and then we would ship them back to China. Q. And you said that masks were also sent to Mr. Guo's home. Which home was that? A. To the one in Connecticut. Q. And when were those masks sent to Mr. Guo's home? A. Around March of 2020. Q. Who made the decision to use Rule of Law donor money to send those N95 masks to Mr. Guo's home? A. Boss did. Q. You said that Rule of Law donor money was also used to send masks to the NYPD. What role, if any, did you have in sending
481 O5TVGUO3 Maistrello - Direct those masks to the NYPD? A. I was asked by Yvette to draft a letter to accompany those masks. The letter should have read something along the lines of: This is a gift from Miles Kwok. Q. And what did you do when you were asked to write a letter saying that those masks were a gift from Miles Kwok? A. I told her that I could write the letter, but that I wouldn't sign it with the name of -- with boss's name. Q. And why wouldn't you sign it with Mr. Guo's name? A. Well, because it was not discussed with the other members of the board and it was not a direct gift from him, but it was -- those masks were paid with Rule of Law money. Q. And what, if anything, did Yvette say when you said you wouldn't write a letter that said those masks came from Miles Guo? A. She told me that I was being paid to execute orders and not to think. Q. How much were you paid a year when you worked for Mr. Guo? A. 60. Q. What amount, if any, was listed as your salary on your offer letter? A. That was 90. Q. And what, if anything, explains the difference there? A. I was told by Yvette that the company preferred to pay a lower salary on a monthly basis and a higher bonus at the end
482 O5TVGUO3 Maistrello - Direct of the year, that it would top it up. Q. Including your bonus, what was your total pay at the end of the year? A. I believe my bonus on January of 2019 was 5,000. Q. And including that amount, how much did you make in a year working for Mr. Guo? A. 65. MR. HORTON: May I have one moment, your Honor? THE COURT: Yes. (Counsel conferred) MR. HORTON: Thank you, your Honor. Q. Ms. Maistrello, in your two years working for him, what, if anything, did Mr. Guo tell you about his lifestyle in China? A. In China, he had a lot of connections. He knew a lot of people. When he talked about China, he usually -- he was very proud of his achievements. He would -- he would often talk about his hotel, he would talk about the staff there, he would talk about the design, how he designed it. He was generally very proud of it. Q. And what did you understand Mr. Guo to mean when he told you about his connections in China? A. When he talked about his connections in China, he knew a lot people, and so he would sometimes talk about what these people did. He knew a lot about them. Q. And who were these people?
483 O5TVGUO3 Maistrello - Direct A. All sorts of people really. Businesspeople, ministers. He knew a lot of people. Q. And what do you mean by "minister"? A. So government ministers. It could be the minister of the interior, minister for development, for education. Various ministries. Q. You said he talked to you about his hotel in China. What did he tell you about it? A. He described the hotel, the interior, the exterior; he talked about his staff there, how things were run. He was generally very, very proud of it. Q. And what, if anything, did he tell you about the status of the hotel during the time you were working with him? A. Can you repeat the question? Q. Yes. What, if anything, did Mr. Guo tell you about the status of his hotel in China during the time you were working with him? A. The status of the hotel while he was in the U.S.? Q. Yes. A. The hotel was still running. Q. What, if anything, did Mr. Guo tell you about when he came to the United States? A. Well, before coming to the United States, he went to Hong Kong, so he was there first. Q. And what, if anything, did he tell you about when he came
484 O5TVGUO3 Maistrello - Direct from Hong Kong to the United States? A. He left Hong Kong in 2015 and he relocated to New York. Q. And what, if anything, did Mr. Guo tell you he was doing in the period between when he got to New York in 2015 and when you started working for him a few years later? A. He was -- what he said is that he was preparing or getting ready for his fight against the Chinese government. Q. And what, if anything, did Mr. Guo tell you that getting ready meant? What did that entail? A. Mainly, he broadcast. That's what he did. Q. And what, if anything, Ms. Maistrello, did you observe about how Mr. Guo's lifestyle changed in the United States? MS. SHROFF: Assumes facts not in evidence, your Honor. MR. HORTON: I can lay a foundation for it. THE COURT: All right. One moment, please. Go ahead. The objection is sustained. MR. HORTON: Thank you, your Honor. BY MR. HORTON: Q. Ms. Maistrello, other than the broadcasting, what actions, if any, did Mr. Guo take while you were working for him for that fight against the CCP? A. Nothing really, other than putting together people for his fight. Q. You said that Mr. Guo asked you to buy things -- withdrawn.
485 O5TVGUO3 Maistrello - Cross Ms. Maistrello, you said that you donated $500 to the Rule of Law Society. If you could do that again, would you have donated your money to Rule of Law? A. With the knowledge I have today, no. Q. And why not? A. Because that money wasn't used for anything that I believed in really. MR. HORTON: Can I have one moment, your Honor? I'm sorry, could I have just one moment, your Honor? THE COURT: Yes, yes. MR. HORTON: Thank you. (Counsel conferred) MR. HORTON: Thank you, your Honor. No further questions. THE COURT: Cross-examination. MS. SHROFF: May I, your Honor? THE COURT: You may. MS. SHROFF: Thank you. CROSS-EXAMINATION BY MS. SHROFF: Q. Ms. Maistrello, where did you go to college? A. College in Rome, Italy. Q. Okay. And after you studied in Rome, where did you study next? A. In China.
486 O5TVGUO3 Maistrello - Cross Q. And you were in China for almost five or more years; correct? A. From 2012 to 2017. Q. And you were working while you were in China; correct? A. Yes. Q. And you were there with your husband; correct? A. No. Q. Did you get married after you left China? A. Yes. Q. And what do you do for a living now? A. I work for Google. Q. I'm sorry? A. I work for Google. Google. Google Search. Q. You work for Google? A. Yes. Q. Okay. And your husband is a professor; correct? A. That's correct. Q. And he's a professor at a university in New York; correct? A. NYU, yes. Q. And is it fair to say that when you accepted a job at Golden Springs, part of the reason you were hired is because you spoke Mandarin; correct? A. Yes. Q. Right. And you were first initially hired as a translator,
487 O5TVGUO3 Maistrello - Cross right? A. Yes. Q. And it came a point where there was some unhappiness with your level of translation, so they brought in outside translators to translate for meetings; correct? A. No. Q. Well, you didn't translate at formal meetings; correct? A. I did. Q. I really can't hear you. You did not. The answer is you did not, right? A. The answer is I did. Q. The answer is you did translate for formal meetings; correct? That's your testimony? A. Yes. Q. Who's Una Wilkinson? A. She was hired as an external translator in late 2019. Q. Right. And she was brought in then to translate meetings where other people were present; correct? A. Yes. Q. Right. And you were not used during those meetings for your translation skills; correct? A. Correct. Q. Right.
488 O5TVGUO3 Maistrello - Cross Now, you testified that you were an employee of Golden Springs New York, right? A. Golden Spring, not springs. But yes. Q. Okay. Golden Spring New York, right? A. Golden Spring New York. Q. And there is an entity called Golden Spring Hong Kong; correct? A. Right. Q. And Golden Spring Hong Kong is the entity above Golden Spring New York, right? A. I don't know if it's above. Q. You don't know if it's above. Are you aware as to where the funds into Golden Spring came from? A. No. Q. Do you know who put money into the Golden Spring New York account? A. Yes. Q. Who? A. Yvette did. Q. You think Yvette put her personal money into the Golden Spring New York account? MR. HORTON: Objection. THE COURT: Overruled. You may answer. A. Not her personal money, no.
489 O5TVGUO3 Maistrello - Cross Q. Okay. My question was whose money was in Golden Springs New York? A. I don't know. Q. Okay. And you certainly don't know whose money was in Golden Spring Hong Kong; correct? A. Correct. Q. And you don't know how many billions of dollars there was in Golden Spring Hong Kong; correct? A. I don't know. Q. And you don't know how many millions or billions or hundreds of thousands of dollars -- MR. HORTON: Objection, your Honor. Q. -- that was in Golden Spring New York; correct? THE COURT: Overruled. You may answer. A. Can you repeat the question, please. Q. Sure. You do not know how many billions, millions or hundreds of thousands of dollars there was in Golden Spring New York; correct? A. I don't know. Q. Now, you heard about Mr. Guo when you worked in China; correct? A. Yes. Q. You worked for an oil company, you testified, right? A. That's correct. Q. And did you work there as a translator or did you work for
490 O5TVGUO3 Maistrello - Cross the oil company or something else? A. No, I was working as something else. Q. And what was that something else? A. I had several titles. I left as director of communications. Q. Director of communications; correct? A. Yes. Q. And in your job in China, you socialized; correct? A. Yes. Q. You socialized with people who had money; correct? A. I socialized with people. Q. And some of them had money, right? A. That I don't know. Q. Some of them were rich; correct? A. I don't know. Q. Well, you went to parties, did you not? A. No. Q. You didn't go to a single party while you were in China? A. What do you mean by "party"? Q. A party, a social gathering, an event. A. I went to dinners. Q. Right. And you went to dinners with well-heeled people in your business field; correct? MR. HORTON: Objection, your Honor.
491 O5TVGUO3 Maistrello - Cross THE COURT: Overruled. You may answer. A. I went to dinners with my colleagues. Q. Right. And when you went to dinners with your colleagues, you had work-related dinners with people who were working with you in the oil company; correct? A. Yes, colleagues. Q. Right. And at that time, you had heard of something called Pangu, right? A. Yes. Q. Tell the jury, please, what is Pangu? A. Pangu is a building in Beijing, in the capital. It's a Dragon-shaped building that was built around the Beijing Olympics in 2008. Q. It's a huge building, right? A. It's quite big. Q. It's a hotel, right? A. Pangu Hotel is a hotel, yes. Q. Seven-star hotel; correct? A. It is called Seven Star Hotel. In fact, on the world ranking it's five. Q. It's in the world ranking of five out of seven, is that your testimony? A. Yes. So the name reads Seven-Star Hotel, but, in fact, due
492 O5TVGUO3 Maistrello - Cross to, I don't know, hotel star ranking, it is a five-star hotel. Q. It's a five-star hotel now. Back then it was a seven-star hotel? A. I don't know about now. Q. Okay. So you know who owned Pangu, right? A. When? Q. When you were living in China, who did you think owned Pangu? A. I did not know at that time who owned Pangu. Q. You did not know that Miles Guo's family owned Pangu? A. When I was in China, no. Q. Your testimony is when you were in China, you were unaware of the owner of the Pangu hotel? A. When I was in China, I knew he was a developer and he developed the Pangu Hotel, but I did not know who the owner was. Q. Okay. So you at least knew he was the developer; correct? A. I knew that, yes. Q. Right. And you testified on direct, did you not, that there came a time when Mr. Guo showed you pictures of his homes in China; correct? A. Yes. Q. And each home was affluent; correct? A. I saw one.
493 O5TVGUO3 Maistrello - Cross Q. You only saw one home? A. I saw -- yes. Correct. Q. And it was a humongous property; correct? A. I can't say. Q. It's a traditional Chinese property that has a courtyard; correct? A. Yes. Q. And alongside the courtyard are different homes; correct? A. Different structures, yes. Q. And each structure is for one part of the family; correct? A. Traditionally, yes. Q. And traditionally, that's the culture; each brother had a home around the courtyard. Correct? MR. HORTON: Objection, your Honor. THE COURT: Overruled. You may answer if you know. A. Traditionally, so parents live together with the son and the family. And then other family members, if any, would be in the surrounding properties. Q. Right. And he told you that's how he and his family lived in China; correct? A. Yes. Q. And when he told you that, he was talking nostalgically about his life in China when he lived there; correct? A. I wouldn't say nostalgically. Q. Really. Was it with hatred?
494 O5TVGUO3 Maistrello - Cross MR. HORTON: Objection. THE COURT: Overruled. You may answer. A. He was just talking about it. Q. He was talking about his family, right? A. He was talking about his home. Q. Right. And when he was talking to you about his home, he was in his office, right? A. Sometimes in the office, sometimes in his home. Q. And he was just having a regular employer/employee conversation with you, right? A. Yes. Q. Okay. Your employment, am I correct, was with Golden Spring. MS. SHROFF: If I could just have her employment contract up, please. Q. Is that correct, ma'am? A. Can you repeat the question, please? Q. Sure. You had an employment contract, did you not, with Golden Spring? A. Yes. Q. Okay. And part of that employment contract -- the government showed it to you on direct, right? A. Yes. Q. And it's a one-page contract; is that correct?
495 O5TVGUO3 Maistrello - Cross MS. SHROFF: It's GX B-871. There you go. Thank you so much. Q. If I could just have you take a look at the document, please. MS. SHROFF: May I also have it published for the jurors, please. Q. That was the contract; is that right? A. This was the offer letter. MS. SHROFF: Okay. And if you could just scroll down, all the way down. Q. And you signed it; correct? A. Yes. Q. You signed it on February 13 of 2018; correct? A. Yes. Q. And the letter says, of course, that you've reviewed it, you agree to the terms and conditions, and then you signed it, right? A. Yes. Q. I mean, you read it, right? A. I did. Q. Okay. Let's just go back up for a minute, okay? You picked your own start date, I'm assuming, or you arrived at a start date that was convenient for you, which was February 19, right? A. I don't remember that.
496 O5TVGUO3 Maistrello - Cross Q. Okay. Your title was to be project assistant and interpreter, remember that? A. I can see that, yes. Q. Right. I didn't ask you whether you saw it, I asked you if you remember that. You remember that's what you were hired for; correct? A. I remember that I was hired as an interpreter. Q. Okay. It says project assistant and interpreter, right? A. Yes. Q. Okay. You didn't scratch out project assistant, right? A. I did not. Q. Okay. And it said clearly that you were going to be employed by Golden Spring New York Limited, right? A. Yes. Q. And then it tells you a couple of bullet points down, the offer letter is for employment at will; correct? A. Yes. Q. And employment at will is explained to you in this document, right? A. Yes. Q. And, in fact, it tells you right there that you are free to terminate your employment with them as you see fit; correct? A. Yes. Q. Doesn't even tell you you have to give two weeks' notice; correct?
497 O5TVGUO3 Maistrello - Cross A. It does not. Q. Right. You could have walked out of that job any day you felt like, right? A. Yes. Q. Right. You didn't like something that was going on, you could have left, right? A. Yes. Q. Okay. And you met with these prosecutors how many times to prepare for your testimony here? A. I don't remember the number of times. Q. You don't remember the number of times that you met with them? A. No. Q. And do you remember who you met with? A. Yes. Q. Who did you meet with? A. Do you want the names? Q. Sure. A. Justin Horton, Ryan Finkel, Juliana Murray, and Micah Fergenson. Q. And the gentleman who asked you the questions today, he reviewed this document with you to prepare you, right? A. He showed me this document.
498 O5TVGUO3 Maistrello - Cross Q. Well, he didn't just show it to you, right, he went over it with you, right? A. He showed it to me. Q. He didn't review the terms of the document with you? A. No. Q. You were first contacted by the government in August of 2023, remember that? A. I do. Q. And then you were contacted again on August 14, remember that? A. I don't remember the dates. Q. How about January 16th? A. I don't remember the dates. Q. January 25th? MR. HORTON: Objection, your Honor. THE COURT: Overruled. You may continue. A. I don't remember the dates. Q. May 24th? A. I don't remember the dates. Q. May 15th? MR. HORTON: Objection, your Honor. THE COURT: Overruled. You may continue. A. I don't remember the exact dates. Q. May 9th? A. I don't remember the dates.
499 O5TVGUO3 Maistrello - Cross Q. May 20th? A. I don't remember the dates. Q. How about yesterday? Do you remember yesterday? A. Yesterday I was here. Q. And you met with them, right? A. Yes. Q. With Mr. Horton sitting right there, the man who asked you questions, right? A. Yes. Q. How many hours? A. A few minutes. Q. Okay. How about the day before? A. On Monday? Q. I'm sorry? A. Are you referring to Monday? Q. Am I referring to me? A. Monday, are you referring to Monday? Q. Yes. A. We met on Monday. Q. You met on Monday, right? Monday was a federal holiday? A. It was. Q. Right. Where did you meet? A. We met at 26 Fed. Q. They picked you up at the train station?
500 O5TVGUO3 Maistrello - Cross A. No. Q. Okay. You got to 26 Federal Plaza and you sat down and met with them, right? A. Correct. Q. They went over your testimony? A. No. Q. No? They didn't tell you what questions they were going to ask you? A. They asked me some questions. Q. Right. They went through a whole series of questions, just like they did in court today, right? A. Not exactly. Q. Well, no, not exactly. But they sat down and asked you a whole bunch of questions, right? A. They asked me questions. Q. Right. And then they took notes, right? A. They did. Q. They took -- they showed you photographs, right? A. They showed me some photographs, yes. Q. They showed you the same photographs here today; correct? A. I don't remember exactly. Q. And did they then tell you how somebody like me would cross-examine you?
501 O5TVGUO3 Maistrello - Cross A. They explained how it works, yes. Q. They did, right? They told you what questions would come at you on cross-examination; correct? A. No. Q. They didn't tell you what questions would come, what you should anticipate at cross? A. They explained to me how it works. Q. Right. They told you that a lawyer for Mr. Guo would ask you questions, right? A. Yes. Q. And they helped you prepare on how to answer, right? A. No. MS. SHROFF: Okay. Let's see if we can pull up Government Exhibit 141. Q. They showed you this photograph, did they? A. One time they did. Q. Right. I won't ask you which one of the many preps they showed you the photograph in, but they showed you this photograph, right? A. Yes. Q. And this photograph was taken by whom, ma'am? A. We had about seven, between photographers and videographers, for a photo shoot.
502 O5TVGUO3 Maistrello - Cross Q. Right. And you were not the only person in the photo shoot, right? A. No. Q. There were other people in the photo shoot, right? A. Yes. Q. And it was a professional agency that took the photos, right? A. Yes. Q. And the photos was -- they were going to be used for a particular launch; correct? A. Correct. Q. And this was not unusual, right? A. A photo shoot only happened once, in fact. Q. It's only happened once while you were working there, right? A. Can you repeat the question? Q. Sure. It only happened once, as far as you know, during the time you were working there, right? A. During the time I was working there it happened once. Q. Right. And you worked there, all told, how much? About two years? A. More than two years. Q. How many more? Two and a half years?
503 O5TVGUO3 Maistrello - Cross A. Approximately. Q. Approximately two and a half years. And it's fair to say, right, you correct me if I'm wrong, you left because of medical reasons, right? A. That is correct. Q. Right. And you decided COVID was coming and you did not feel well, right? A. No. Q. Well, COVID was coming, right, when you quit? A. COVID hit in February of 2020. Q. Right. You think COVID hit in February of 2020 or March of 2020? A. It was either February or March. Q. And you quit the month after, right? A. Yes. Q. Okay. And the reason you gave for quitting is because you thought microwaves had attacked you, right? That's what you told someone at Golden Springs? A. No. Q. Okay. And you then stated that you had been hospitalized; is that correct? A. I was about to be.
504 O5TVGUO3 Maistrello - Cross Q. Right. And Yvette responded to you being sick; correct? A. What do you mean by that? Q. She sent you flowers, did she? A. No, she did not. Q. She did not. And did she extend your insurance coverage to help you while you were sick? A. No, she did not. Q. She did not provide you with COBRA benefits while you were sick? A. COBRA benefits were included, but she did not extend those personally. Q. She did not offer to you to extend them personally, is that your testimony here today? A. Correct. Q. Okay. And you were in touch, were you not, with other people who worked for Mr. Guo; correct? A. When? Q. Throughout your time after you quit working at Golden Springs, right? A. A few people reached out to me. Q. Right. And they reached out to you making sure you were well, right?
505 O5TVGUO3 Maistrello - Cross A. They asked me how I was doing. Q. Right. And included in that list is Melissa; correct? A. Yes. (Continued on next page)
506 O5T1GUO4 Maistrello - Cross BY MS. SHROFF: Q. A lawyer named Victor Cerda said you should get medical help and feel better, correct? A. I don't remember that. Q. Okay. And Max Krasner reached out to you, correct? A. Yes, he asked me how I was. Q. And somebody named Dan Podhaskie also reached out to you, correct? A. Yes. Q. Now these are all people that you knew from working there, correct? A. Yes. Q. Okay. So you knew——let's just go through the list. Yvette; is that right? A. Yes. Q. You knew Dan Krasner, correct? A. Max. Q. Max Krasner. A. Max Krasner. Q. Sorry. I mix up names all the time. Max Krasner, correct? A. Yes. Q. Dan Podhaskie, correct? A. Yes. Q. You don't like Dan Podhaskie, right?
507 O5T1GUO4 Maistrello - Cross A. That's not true. Q. Really? Didn't you complain about him hitting on you one day? A. No, I did not. Q. You did not complain to Yvette Wang that he had hit on you during a trip to Washington, DC? MR. HORTON: Objection, your Honor. Asked and answered. THE COURT: Sustained. Q. Did you take a trip with Dan Podhaskie to Washington, DC? A. No. Q. You did not take a trip with Dan Podhaskie to Washington, DC for business; that's your testimony? MR. HORTON: Objection, your Honor. Asked and answered. THE COURT: Sustained. Q. It's fair to say you didn't like Dan Podhaskie, right? MR. HORTON: Objection, your Honor. Asked and answered. THE COURT: Sustained. Q. Did you have a positive working relationship with Mr. Podhaskie? MR. HORTON: Objection your Honor. Asked and answered. MS. SHROFF: I did not ask that.
508 O5T1GUO4 Maistrello - Cross THE COURT: You may answer that. A. We had a good working relationship. Q. I'm sorry? A. We had a good working relationship. Q. What was your working relationship with him? A. We were colleagues. Q. Okay. And as colleagues, how did you interact with each other? A. We talked. Q. Okay. Talked about what? A. Work. Q. What work? A. Work at the office. Q. Work at the office. What work at the office? A. He would come to me to ask for something, or whenever he needed a translation, I would help him out. Work-related talk. Q. And you've testified at great length about your relationship with Yvette, correct? A. I didn't testify to great length. I answered questions that I was asked. Q. Okay. And Yvette's full name is——did you call her Yvette or did you call her Ms. Wang or how did you refer to her? A. I——I used her first name. Q. You called her Yvette, right? A. Her Chinese first name.
509 O5T1GUO4 Maistrello - Cross Q. And was that? A. Yanping. Q. You referred to her as Yanping when you talked to her? A. Yes. Q. Okay. But when you talked to the government about her, you called her Yvette, right? A. I don't remember. Q. Okay. Well, let's talk about your interactions with her, okay? You testified that she was the one who conducted the first job interview, right? A. Yes. Q. And when she interviewed with you, where were you located? A. The first interview happened at the Plaza Hotel. Q. Okay. And no reason was given to you as to why the interview was at the Plaza Hotel, correct? A. No. Q. It was an everyday job interview, correct? A. It was a job interview. Q. Right. And you had been sent there by somebody named Steve Weber, right? A. Yes. Q. And Steve Weber is a headhunter, correct? A. I don't know if he is today. He was at that time. Q. Right. And you filled out a job——or an application to get
510 O5T1GUO4 Maistrello - Cross a job through his company and that's what happened, right? A. He had reached out to me. Q. Right. And you testified about the second interview was with Mr. Guo, correct? A. Correct. Q. Now when you went to that second interview, they didn't send you a memo or a notice saying you have a job interview with Boss, right? A. I don't remember that. Q. They told you you had a job interview and the interview was with a person named Mr. Guo, right? A. I don't remember the specific name they used. Q. So you don't remember if they referred to him as Mr. Kwok, correct? A. I don't remember, no. Q. You don't know if they referred to him as Mr. Guo, correct? A. I don't remember. Q. Is it fair to say that they did not refer to you——refer to him as Boss when they set up the interview? A. I don't remember. Q. Okay. You sent out emails as part of your job, correct? A. Yes. Q. Internal emails, correct? A. Yes. Q. And external emails, correct?
511 O5T1GUO4 Maistrello - Cross A. Yes. Q. And you sent out external emails to agencies, correct? A. What do you mean by agencies? Q. Businesses, right? You sent out external emails to businesses, right? A. Yes. Q. Okay. And you referred to Mr. Guo as either Mr. Guo or Mr. Kwok in your emails, correct? A. No. I would never refer to him as Mr. Kwok. Q. Well, if you were emailing with that fancy place in Italy about the furniture, how would you refer to him? A. Mr. Guo. Q. Mr. Guo, right? You wouldn't call him Boss in your email, right? A. I——I would definitely call him Mr. Guo. Q. Right. And when you advertised your past job experience at Golden Spring, you don't say, I worked for Boss, right, you say, I worked for a man named Miles Guo, correct? A. I don't really advertise. I never advertise his name. Q. How about on LinkedIn? Do you say, I worked for a man named Boss? A. No. Q. Okay. So the only time you consistently referred to him as Boss is when you're testifying here or when you are talking internally at the office, correct?
512 O5T1GUO4 Maistrello - Cross A. So I would call him Boss in Chinese when I talked to him directly and Boss when I referred to him with my colleagues. Q. And this courtroom setting is neither you talking to Mr. Guo nor you talking to any of your colleagues, correct? A. That's correct. Q. This is a formal proceeding, correct? A. It is. Q. And you referred to him throughout your testimony as Boss, correct? A. Yes. Q. Okay. Now if I could have you recall your testimony about Government Exhibit 102, please. This is Yvette, correct? A. It is. Q. Right. And according to you, during your interview with Yvette, she, Yvette Yanping Wang, asked you what your connection was to CCP; is that right? A. Yes. Q. Right. It's fair to say, right, you cannot be part of the CCP because you are simply not a Chinese national, correct? A. That's correct. Q. You cannot be part of the CCP without being a Chinese national, correct? A. That is correct. Q. And Ms. Wang of all people would most certainly know that
513 O5T1GUO4 Maistrello - Cross basic fact, correct? A. Yes. Q. There is no way Ms. Wang ever asked you during a job interview if you belonged to the CCP; isn't that correct? MR. HORTON: Objection, your Honor. THE COURT: I'll let you answer. Go ahead. A. She never asked me if I was a party member. She asked me if I knew people who were party members. Q. She asked you if you knew anyone who was a party member; is that your testimony? A. She asked me if I knew people who were party members. Q. Did she explain to you what "knew" means? A. What do you mean "knew"? Q. Well, I know you now. That doesn't mean I actually know you, right? MR. HORTON: Objection, your Honor. THE COURT: Don't testify. MS. SHROFF: I'll move on. Could you show her Government Exhibit 130, please. Q. You testified about this building, correct? A. Yes. Q. This is the Sherry-Netherland, right? A. It is. Q. They showed you this photograph during your preparation, correct?
514 O5T1GUO4 Maistrello - Cross A. I don't remember. Q. Okay. Mr. Guo lived on the 18th floor of this building, correct? A. Yes. Q. Penthouse, correct? A. Yes. Q. It's gigantic; isn't that true? A. It's big. Q. Right. It has a recording studio in there, correct? A. What do you mean by recording studio? Q. A place from where he broadcast, correct? A. That was an office. Q. Right. There was a——there was an actual office set up in that home, correct? A. Yes. Q. Okay. Could you try and keep your voice up. That would really help me out, please. A. I'll do my best. Q. Thank you. And there was security in that building, correct? A. The building has staff that lets people in and out. Q. Right. 24-hour staff that lets people in and out, correct? A. Yes. Q. You couldn't go up to that 18th floor unless somebody in that floor said you could come up, correct?
515 O5T1GUO4 Maistrello - Cross A. Yes. My name was on the list. Q. Exactly. And the only reason you could go up is because your name was on that list, correct? A. Yes. Q. And that was because Mr. Guo wanted to have security for himself and his family, correct? A. The security apparatus belongs to the hotel. Q. And he's the one who puts your name on that security apparatus, correct? A. I don't know if he is the one, but my name was there. Q. Okay. And is it fair to say that there is security apparatus in that building 24/7? A. I believe so. Q. And there's security apparatus in the garage 24/7, correct? A. That I don't know. Q. Okay. And sitting here today, you have no idea, do you, whether or not he picked that building because he wanted to make sure that he lived in a building with 24-hour security; you simply don't know, correct? A. The reasons why he picked that building, he knows. Q. Exactly. You don't know, right? A. I do not. MS. SHROFF: You may take that down. Thank you. If somebody could show her UK723, please. Q. You testified about this photograph, correct?
516 O5T1GUO4 Maistrello - Cross A. Yes. Q. Okay. Let's go through them. You see Mr. Guo seated there, correct? A. I do. Q. And who is to his left? A. His wife. Q. And do you know for how many years she was held in prison because she was married to Mr. Guo? MR. HORTON: Objection, your Honor. THE COURT: Sustained. Q. Do you see the person seated to her left? A. I do. Q. Who is that? A. That's Yvette. Q. And do you know how many years Yvette was held in prison in China? MR. HORTON: Objection, your Honor. THE COURT: Sustained. Q. And who is the person seated right across from Mr. Guo? A. His daughter. Q. Okay. And his daughter now lives in the United States, correct? A. Until I was working, so in 2020, she was in the United States. Q. And you knew her from work, right?
517 O5T1GUO4 Maistrello - Cross A. She came to the office. Q. She sent you a Christmas gift each Christmas, right? A. She bought Christmas gifts for all of us at the office. Q. Every employee, correct? A. I don't know if every employee got it. Q. Okay. Mr. Guo got you gifts, right, while you worked for him? A. For Chinese New Year. Q. Your testimony is that the only gift you got from Mr. Guo was on Chinese New Year? A. Twice. On two separate Chinese New Years. Q. Okay. Do you remember getting a gift of an Hermès puffer jacket? A. Yes. Q. That was from him, right? A. Correct. Q. You accepted the gift, right? A. I did. Q. Where is Hermès, by the way? Where is it located? A. The headquarters, you mean? Q. No. I mean just the store. MR. HORTON: Objection, your Honor. THE COURT: Overruled. If you know where it is, let us know. A. On Madison.
518 O5T1GUO4 Maistrello - Cross Q. Madison and what? A. I don't remember the cross street. Q. 67th? A. I don't remember. Q. How much do you think that puffer jacket cost? A. I don't know. Q. You'd agree with me, would you not, ma'am, that Hermès is a very high-end store, correct? MR. HORTON: Objection, your Honor. 401. THE COURT: Overruled. You may answer. A. Can you repeat the question, please. Q. Sure. You would agree with me, would you not, that Hermès is an extremely high-end store? A. I agree. MS. SHROFF: You may take that down. Q. You now you testified, did you not, on direct about a store——and forgive me, I don't remember the name. Promemoria, or something like that? A. Promemoria? Yes. Q. Correct. Do you remember that store? A. They don't have a store here. Q. It's a company in Italy, correct? A. Correct. Q. It's a supplier, right; supplies leather, correct? A. It's a furniture company.
519 O5T1GUO4 Maistrello - Cross Q. And you can call them and get yourself some very expensive furniture, correct? A. Anybody can call them, yes. Q. Right. Right. And you placed several orders with that company, correct? A. Yes. Q. Right. And they were orders for furniture, correct? A. Yes. Q. And you would place the order, correct? A. Correct. Q. Who chose it, the furniture? A. Boss did. Q. Mr. Guo, right? A. Yes. Q. Okay. And Mr. Guo would choose the furniture and he'd ask you to place the order, correct? A. Yes. Q. Okay. And you would place the order, right? A. I would. Q. Sometimes he'd change his mind about the order, right? A. All the time. Q. All the time; isn't that true? A. Yes. Q. Very frustrating, correct? A. It was part of the job.
520 O5T1GUO4 Maistrello - Cross Q. It was part of the——frustrating part of the job for you, right? A. It was part of the job. Q. He would pick something, have you place the order, and then have you cancel it, correct? A. That happened. Q. He would change his mind, correct? A. Yes. Q. He did that with that place, whatever it's called, Chateau Ridge or something, right? A. He initially wanted to purchase it and then he didn't. Q. Right. And you spent a lot of time testifying about, you know, that it was a palace and it had art and it had all of this stuff. End of the day, he never bought it, correct? A. He did not. Q. Now let's talk about the Brioni suits that you ordered for him, according to you. Did you order them for him? A. Yes. Q. Okay. Do you know how long he had been a customer of Brioni, whether it had been for a decade or two decades? A. Close to two decades. Q. Two decades, right? It's 20 years? A. Approximately. Q. Right. So they knew him, correct? A. They did.
521 O5T1GUO4 Maistrello - Cross Q. Right? Because they'd been doing his suits for 20 years, right? A. They knew him. Q. Okay. Who paid his bills 20 years ago; do you know? A. I do not. Q. Who paid his bills 10 years ago; do you know? A. I do not. Q. Who paid his bills for the suits now; do you know? A. You mean today? Q. Well, today you certainly don't know because you don't work for him anymore, right? A. That's correct. Q. Right. So when you worked for him, who paid those bills? A. Golden Spring. Q. Golden Spring belonged to whom? Sitting here today, you don't know whose money was Golden Spring, right? A. I know the name of the president, I know the name of the chief operating officer. Q. Okay. You don't know whose money went in there, right? A. I do not. Q. Right. And certainly you were never on the board when Rule of Law Foundation put any money in there, correct? A. What do you mean by that? Q. You don't know any instance when any money from Rule of Law
522 O5T1GUO4 Maistrello - Cross Foundation went into Golden Spring, correct? A. I don't know that money from Rule of Law ever went to Golden Spring. I don't know. Q. I just wanted to make sure. Now you said that they paid all of this money for his suits, Golden Spring New York did, correct? A. Yes. Q. Okay. And they paid by what, check or transfer; do you know? A. It was usually a check. Q. Okay. But you don't know, right? A. I do. Q. You do know, that it was paid by check. A. Yes. Q. Who was the check made out to, Brioni New York, Brioni France, where? A. Brioni New York on Madison. Q. Okay. Now you also testified about cars, correct? A. Yes. Q. This man doesn't know how to drive, right? A. He knows how to drive. Q. You've seen Miles Guo drive a car. A. Yes. Q. On the streets of New York. A. Just outside of New York.
523 O5T1GUO4 Maistrello - Cross Q. Outside of New York. Your testimony is you know this man to have driven a car outside, on a street. MR. HORTON: Objection. Asked and answered. THE COURT: Sustained. Q. Do you know if he has a driver's license? A. When I worked there, he did not. He only had a Hong Kong driver's license yes. Q. He didn't even have a learner's permit, right? A. Do you mean a US learner's permit? Q. Yes, ma'am. A. At that time he did not. Q. Okay. He was driven to work, correct? A. Yes. Q. He was driven from work, correct? A. That's correct. Q. And he was driven everywhere he went; he never drove a car ever on a New York City street, correct? A. He did once. Q. Okay. Putting aside this once that you keep referring to, he was driven back and forth everywhere he went, correct, while you worked for him? MR. HORTON: Objection, your Honor. Asked and answered. MS. SHROFF: I'll move on, your Honor. THE COURT: You may answer.
524 O5T1GUO4 Maistrello - Cross Q. True? A. He was driven. Q. Okay. And you talked about how he was talking about some Rolls Royce that he had in China, correct? A. Yes. Q. He never got that Rolls Royce from China to the United States, correct? A. Not that I know of. Q. I'm sorry. What? A. Not that I know of. Q. Exactly. He would talk about it and then he would just abandon the project, correct? A. It just wasn't possible to import that car so—— Q. Right. And same for the Lamborghini, right? No Rolls Royce or Lamborghini was ever imported here, correct? A. Not to my knowledge. Q. You could only testify to your knowledge. So the answer is no? A. The answer is no. Q. Okay. Now you also testified about a person named Hank, correct? A. Yes. Q. Now Hank came from China with Mr. Guo, correct? A. That's correct. Q. Right. And Mr.——and Hank speaks absolutely no English,
525 O5T1GUO4 Maistrello - Cross correct? A. He does not. Q. Right. And Hank used to live with Mr. Guo and his family, correct? A. They lived separately. Q. You think Hank lived separately from the Guo family. MR. HORTON: Objection. Asked and answered. THE COURT: Sustained. Q. You testified about Mr. Guo's son named Mileson, correct? A. Yes. Q. You've never personally met Mileson, correct? A. I did. Q. Where did you meet him? A. At the office. Q. At the office where? A. 800 Fifth. Q. And what year was that? A. The first time I met him was 2018. Q. And when was the second time you met him? A. Can you repeat the question, please. Q. When was the——take your time. A. Thank you. Q. You're welcome. When was the second time? A. In 2019.
526 O5T1GUO4 Maistrello - Cross Q. And you haven't met him since, right? A. I believe the last time we met was 2019. Q. Okay. And he didn't ask you to buy him any motorbikes, right? A. Not directly, no. Q. The question was whether Mileson asked you to buy any motorbike. The answer is no, correct? MR. HORTON: Objection, your Honor. Asked and answered. THE COURT: Sustained. Q. Mr. Guo didn't ask you to buy any motorbikes for his son, correct? MR. HORTON: Objection. THE COURT: You may answer. A. He did. Q. He asked you to buy motorbikes for his son? A. One specific—— Q. I cannot hear you. A. One, one time. Q. One time. And you never bought the bike, right? A. I believe he bought it himself. Q. I asked you if you bought the bike. A. I did not. Q. Okay. And when you say you believe he bought the bike, you actually do not know if he ever bought a bike for his son,
527 O5T1GUO4 Maistrello - Cross correct; that's just your belief? MR. HORTON: Objection, your Honor. THE COURT: You may answer as to whether you know or you believe. A. I do not know. Q. You would ask Yvette for payment, correct, on things that Mr. Guo wanted you to buy? A. For bigger amounts, yes. Q. And it would be Yvette who would have to authorize the payments, correct? A. Yes. Q. You had no ability to authorize any payment from any entity, correct? A. No, I only had a company's credit card. Q. Right. My question was: You had no ability to authorize payment at all, correct? A. Authorize? Q. Yes. A. No. Q. You could not say, Golden Spring is going to pay this bill, correct? A. It depended on the amount. Q. Your testimony is that if it was a small amount from Golden Spring that was being spent, you could have that paid through Golden Spring?
528 O5T1GUO4 Maistrello - Cross MR. HORTON: Objection, your Honor. Mischaracterizes her testimony. THE COURT: Overruled. You may answer. A. I placed orders through my company's credit card, so for smaller amounts, yes. Q. You would place the order, correct? Right? A. Yes. Q. The bill would go to Golden Spring, correct? A. Yes. Q. You don't know if it was paid or not, right? A. Well, payments go through immediately, through the credit card. Q. You don't know if it was paid or not, correct? A. I'm not—— MR. HORTON: Objection, your Honor. THE COURT: Are you asking whether a transaction was consummated or whether the credit card bill was paid? MS. SHROFF: Whether the credit card bill was paid. A. The credit card bill was always paid because I had the money available. Q. You mean the Golden Spring credit card has the money available. A. Yes. Q. It's not your credit card, right? A. My corporate credit card.
529 O5T1GUO4 Maistrello - Cross Q. Not your credit card, correct? MR. HORTON: Objection, your Honor. THE COURT: Sustained. Q. Could you buy yourself something off that credit card? A. Personal expenses? Q. Yes. A. No. Q. Okay. Now you've talked about several entities while you were testifying on direct, correct? We've already covered Golden Spring, right? So let's talk about Saraca. Do you have any understanding what Saraca was? A. What I knew about Saraca was that all the expenses related to tech or media went to Saraca. Q. Okay. You don't know if Saraca was a holding company, correct? A. I do not. Q. You don't know if it's a private company, correct? A. I don't. Q. You don't know where it's licensed or incorporated, correct? A. I do not. Q. And then they asked you all these questions about some other company called Genever, correct? A. Genever? Q. Sure. Do you remember your testimony about that?
530 O5T1GUO4 Maistrello - Cross A. Yes. Q. Okay. You don't know anything about that company either, right? A. Structurally, no. Q. Correct. You don't know who owns that company, correct? A. I do not. Q. You don't know if there's a board of directors of that company, correct? A. I don't. Q. And you don't know where the money into that company comes from, correct? A. I do not. Q. Only reason you could testify about it is because you talked to the government about it in your preparation, correct? MR. HORTON: Objection. Objection, your Honor. THE COURT: Overruled. You may answer. A. Can you repeat the question, please. Q. It's okay. I'll move on. Now you testified, did you not, that there were times when you accompanied Mr. Guo and he would decide to purchase something, correct? A. Accompany him where? Q. Well, you two worked together, correct? A. I did not say that. Q. Well, didn't you testify on direct that whoever was in
531 O5T1GUO4 Maistrello - Cross front of him would pay, right? A. What I said is whenever Boss wanted to buy something——it could be a TV, it could be a screen, it could be a monitor, it could be a camera——the person Boss had in front of him in that very moment, he would ask them. Q. Okay. He would ask them to pay, correct? A. He would ask them to buy. He wouldn't use the word "pay." He would just say buy it. Q. Right. And 30 minutes later he may change his mind, correct? A. He may. Q. Okay. And when that happened, Golden Spring would pay, correct? A. Well, when he changed his mind, if he changed his mind, maybe there was no need to purchase at all. Q. Okay. Fair enough. Now one of the other people you testified about on direct was a person named Cao, correct? A. Oh, Cao? Q. Right. Is that right? A. That's correct. Q. Okay. And you testified—— MS. SHROFF: If you could just show her UK728, please. Q. You testified about this photograph, correct? A. I did.
532 O5T1GUO4 Maistrello - Cross Q. Okay. Do you know when this photograph was taken, by the way? A. When? Q. Yes. A. I don't. Q. Do you know who took it? A. I do not. Q. You didn't take it, right? A. I didn't. Q. So the only way you could testify about this photograph is because they showed it to you during your preparation? MR. HORTON: Objection, your Honor. THE COURT: Sustained. Q. Did you see this photograph ever before the government showed it to you? A. No. Q. No, right? What's the answer? A. I've never seen—— MR. HORTON: Objection. THE COURT: Asked and answered. Let's go. Q. You've never seen it before, right? MR. HORTON: Objection, your Honor. Asked and answered. THE COURT: Sustained. Q. This photograph is taken at Chinese New Year, right?
533 O5T1GUO4 Maistrello - Cross MR. HORTON: Objection. THE COURT: You may answer. If you know. A. I don't know. Q. Look at that red envelope in their hands. That's the envelope given out at Chinese New Year, correct? A. It could be. Q. Right. And that's the traditional pose, right, when you're before your elders in Chinese culture? A. Yes. Q. Okay. So that's a young man in a traditional pose getting the red envelope from his elders, correct? MR. HORTON: Object to the testifying, your Honor. MS. SHROFF: It's a question. THE COURT: You may answer. A. You see exactly what you see, so you see two people sitting on a chair and another person kneeling. Q. And both people having red envelopes in their hand, right? A. They do. Q. Right. How many years did you live in China? A. Five. Q. Would you say you have some familiarity with the Chinese culture? A. Yes. Q. And could you tell me what that experience of yours with Chinese culture would lead you to conclude about this
534 O5T1GUO4 Maistrello - Cross photograph. A. The first thing I would say is respect. Q. Mm-hmm. MR. HORTON: Is there a question pending? MS. SHROFF: Well, her answer was "the first," so I assumed she had a second point. THE COURT: Is there anything else you want to say? THE WITNESS: There isn't. Q. And you testified about this gentleman who is seated on his——I guess whatever posture that is, his——what is his American name, by the way? A. Wayne. Q. Okay. And you testified that Wayne is dating Mr. Guo's daughter; is that correct? A. Right now, I don't know. Q. Well, when you were part of the employment circle, he was dating, according to you, Mr. Guo's daughter, correct? A. Yes. Q. And he did work for the company, correct? A. For a period of time, yes. Q. He painted—— MS. SHROFF: You can take that down. Thank you. Q. You testified that he painted, moved furniture, and did all kinds of handyman work, correct? A. In 2018, yes.
535 O5T1GUO4 Maistrello - Cross Q. Right. And what about in 2019? A. He went back to school. Q. Right. And where did he go to school; do you know? A. I don't remember. Q. Do you remember if it was Baruch College? A. I don't remember. Q. Do you remember what he was studying? MR. HORTON: Objection, your Honor. THE COURT: You may answer, if you remember what he was studying. A. I don't remember. Q. He was polite to you, correct? A. He was. Q. He drove Mr. Guo around, correct? A. Correct. Q. And when Mr. Guo was being driven around, is it fair to say that there would always be two cars? A. No. Q. No? Could you describe for any one of——could you describe for the jury what a car would look like in which he was being driven around? A. There were several cars. Q. And each one of them had tinted glasses, correct? A. Not each one. Q. Not each one. Okay. And when he was driven around, you
536 O5T1GUO4 Maistrello - Cross said he had two teams, right? According to you, he had a Chinese security team and an American security team; that was your testimony? A. Yes. Q. And it was your testimony that you really thought, in your opinion, that it was not a security team at all, correct? A. That's correct. Q. Okay. So let's start with the American team, okay? Do you know how many people were on the American team? A. The number varied 'cause people were coming and going. Q. So you don't know. A. It could be as little as two, up to six—— Q. You don't know if there were ex-NYPD employees or not, correct? A. I know. Q. You do know. A. I do. Q. Okay. And how many were ex-NYPD employees? A. All of them. Q. All of them were ex-NYPD employees, correct? A. Yes. Q. Let's move to the Chinese team, as you called it. And you said he was closer to them, correct, according to you? A. Yes. Q. That man is not fluent in English, right?
537 O5T1GUO4 Maistrello - Cross A. He became fluent. Q. Really. You think Mr. Guo spoke English fluently in 2018? A. Not in 2018. Q. How about 2019? A. A lot better. Q. A lot better, right? And you're claiming under oath that he went from 2018 of not speaking English to fluency in 2019? MR. HORTON: Objection, your Honor. THE COURT: Sustained. Q. He spoke to you, when he spoke to you, in Mandarin, correct? A. Yes. Q. He never spoke in English even though you are bilingual, correct? A. He never spoke English to me. Q. Right. And when he spoke to his daughter, who also speaks English, he spoke in Mandarin, correct? A. That's correct. Q. When he spoke to his wife, he spoke in Mandarin, correct? A. Yes. Q. And when he got messages in English, he would come to you and play them and tell you to translate, correct? A. Yes. Q. He did not know how to email, correct? A. That I don't know.
538 O5T1GUO4 Maistrello - Cross Q. Did you ever get a singular email from this man, in all the time you worked for him? A. No. Q. And when he spoke to people around him, he spoke in Chinese, right? A. He spoke Chinese to Chinese people. Q. The reason you were hired as a translator is because he didn't speak English, correct? A. In 2018, yes, correct. Q. And you continued to work, according to you, for him as a translator in 2019, correct? A. That's correct. Q. Okay. Now you also testified, did you not, about a person called William Je? Am I pronouncing that correctly? A. Yes. Q. Okay. And you liked William Je, right? A. I did. Q. You had a good working relationship with him, right? A. He was not around a lot, but whenever he was at the office, yes. Q. You liked talking to him, right? A. Yes. Q. And he talked to you, correct? A. Yes. Q. And he's the one who invited you to be on some board,
539 O5T1GUO4 Maistrello - Cross correct? A. Yes. Q. Mr. Guo didn't invite you, right? A. That's correct. Q. Okay. And Mr. Je is the one who talked to you about what you would be doing on the board, correct? A. Yes. Q. And you had a choice, you could have been on the board, correct? A. Correct. Q. Or you could have told him and said, gee, I'm not interested, correct? A. That is correct. Q. Okay. And you decided that William Je's offer sounded interesting to you so you accepted and you were on the board, correct? A. Yes. Q. Okay. Mr. Je didn't tell you what he wanted you to do on the board, correct? A. He briefly mentioned investments, but nothing more than that. Q. Okay. And he didn't tell you anything about the investment, correct? A. He did not. Q. He didn't tell you what type of investments they were,
540 O5T1GUO4 Maistrello - Cross correct? A. That's correct. Q. He didn't know if the investments were coming from Abu Dhabi, correct? A. Not specifically, correct. Q. You didn't know if the investments were in the billions of dollars; according to you, you knew nothing, correct? MR. HORTON: Objection. THE COURT: Sustained. Q. Did you know if the investments were in the billions of dollars? A. I do not. Q. And you decided you were going to be on the board anyway, correct? A. That's correct. Q. Okay. And William Je did email people, right, unlike Mr. Guo? A. Can you repeat the question. Q. Sure. William Je emailed about questions he had, right? MR. HORTON: Object to form. THE COURT: Did he email you? A. Possibly. Q. Well, you knew his email address, right? A. Yes. Q. Okay. You didn't email him and ask him any questions about
541 O5T1GUO4 Maistrello - Cross serving on this board, right? A. No. Q. Okay. And you decided that you were going to go ahead and serve on the board, right? A. Yes. Q. Okay. And the only reason you decided you didn't want to serve on the board is because that company got civilly sued, correct? A. I was not aware of that at the time. Q. Right. But once you became aware, you were like, I'm out, right? A. I heard something, so I didn't have the details, but I heard——if you want to call them rumors. Q. Right. And when you heard, you wanted out, right? A. That's correct. Q. Okay. And nobody stopped you, right, from leaving the board? A. No one did. Q. Nobody said you have to stay on, correct? A. That's correct. Q. Not Yvette, correct? A. That's correct. Q. Not Guo, right? A. Right. Q. And certainly not William Je, right?
542 O5T1GUO4 Maistrello - Cross A. That's correct. Q. Okay. You continued to work there, correct, at Golden Spring? A. After—— Q. Resigning from the board, you continued to work, right? A. Yes. Q. Zero repercussions to stepping off from that board, right? A. That is correct. Q. Okay. Now you testified that you had responsibility at the Rule of Law Foundation, correct? A. I was president and treasurer. Q. I'm sorry? A. I was president and treasurer of Rule of Law Society. Q. Okay. And what about Rule of Law Foundation, or are you using them interchangeably? A. No. That was a separate entity. Q. So let's talk about Rule of Law Foundation, okay? For them, did you take a trip to France? A. Not——so I took a trip to France, but not for Rule of Law Foundation. Q. And who did you take the trip for? A. I took the trip because Boss asked me to. Q. Mr. Guo asked you to. A. Correct. Q. And he didn't ask you alone, right, to take a trip?
543 O5T1GUO4 Maistrello - Cross A. I was not alone. Q. Right. There was an entire team that was put together, correct? A. Yes. Yes. Q. Okay. And the team that was put together consisted of you, right, because you spoke several languages, I'm assuming, correct? A. I was one of them, yes. Q. Right. And who else was on that team, by the way? A. There were four other people. Q. Okay. A. Four other security guys. Q. Four other security guys; is that how you would describe them? A. That's what we called them. Q. That's what you called them, right? A. Four colleagues. Q. Right. And these were all experienced ex-NYPD officers, correct? A. They were ex-NYPD officers. Q. Did you know them to not be experienced NYPD officers? A. I can't judge as to they are experienced or not. Q. Well, you talked to them, right, according to you on direct testimony? A. I did.
544 O5T1GUO4 Maistrello - Cross Q. Right. And they told you about their experience as NYPD officers, correct? A. Sometimes. Q. Right. And they told you what they did when they were with the NYPD, correct? A. They said some things. Q. Right. And they told you they were investigators with the NYPD, correct? MR. HORTON: Objection. THE COURT: Overruled. You may answer. A. I believe some of them were detectives. I don't remember their exact titles. Q. And these detectives accompanied you on the trip to France, correct? A. We went together. Q. Right. And what was the trip to France for? A. So in the summer, in July of 2018, a Chinese national died in France. Boss, Mr. Guo, believed that it was not an accident; he believed that he may have been murdered. And so he asked us to go there and find out what happened. Q. And Mr. Guo thought he had been murdered by the CCP, correct? A. Yes. Q. Okay. And you went on this investigative trip, correct? A. Yes.
545 O5T1GUO4 Maistrello - Cross Q. You, four detectives, and then you went to France and you met a lawyer in France, correct? MR. HORTON: Objection. 401. THE COURT: You may answer. A. I don't remember. Q. You don't remember the French lawyer? A. I don't re—— MR. HORTON: Objection. MS. SHROFF: I'm sorry. I didn't hear. MR. HORTON: Objection. The question has been asked and answered. THE COURT: Sustained. Q. And there was a whole investigation into the issue of whether this man was killed, correct? MR. HORTON: Objection to form. THE COURT: Could you step up, please. (Continued on next page)
546 O5T1GUO4 Maistrello - Cross (At the sidebar) MS. SHROFF: Sorry about that, your Honor. I'm having a little trouble today with the hearing, so I will apologize. I really am. THE COURT: No need to apologize. Why are we in France? MS. SHROFF: I think she can hear me. Thank you. THE COURT: Okay. So—— MS. SHROFF: I think we're in France because she says Rule of Law Foundation and Society didn't do any work, so I'm trying to show they did do work. They investigated the death of somebody they believed was killed by the CCP, so that the truth would be told to the world. That's why. And she took the trip. She translated on the trip. And I'm pretty sure——and Mr. Schirick can jump in——that the government is going to seek to introduce an entire video on the subject. MR. SCHIRICK: Well, it's the Bannon video. MR. HORTON: So the problem with the argument, your Honor, is that she didn't testify——she didn't testify that this trip was done under the auspices of Rule of Law. That's the proposition that they want to establish, but it's not there. And everything about this trip, all of the details that we're hearing, are hearsay. THE COURT: Did you ask the question whether she went
547 O5T1GUO4 Maistrello - Cross in connection with Rule of Law Foundation? MS. SHROFF: I asked her if she——I'm pretty sure I did, and I asked her who paid, and she said Miles Guo paid. And anyway, it doesn't matter if it's Rule of Law Foundation or Miles Guo paid. I'm not introducing any of it for whether this man was or was not murdered. I really do not care about this trip. There is no hearsay problem. And I'm not asking about any statements she made. I'm asking about what she actually did in France. That's——so—— THE COURT: If your claim is that the Rule of Law Foundation carried out work in France—— MS. SHROFF: Mr. Guo also carried out work in France. Mr. Guo had an interest in his capacity to show that what the CCP was doing worldwide was problematic, and Mr. Guo worked towards that. It doesn't matter—— THE COURT: So these are Mr. Guo's good acts. MS. SHROFF: No, not good. Not good. Good is immaterial. Sorry. Go ahead. MR. SCHIRICK: Your Honor, the factual narrative is that this investigation precedes the founding of the Rule of Law Foundation, and it's the work that they started that they talked about during that launch video that the government introduced into evidence yesterday, and the defense ought to be able to argue that Mr. Guo, using his own resources, using
548 O5T1GUO4 Maistrello - Cross Golden Spring's resources, began the work of the Rule of Law Foundation even before its founding. That's what this goes to. It's relevant to the origin story of the Rule of Law—— MR. HORTON: Your Honor, if I may. I'm——I am confused, and I think the jury might be too. I heard Ms. Shroff say at the beginning of the sidebar that this was a Rule of Law investigation and that's what—— MS. SHROFF: It was Rule of Law—— MR. HORTON: Excuse me, Ms. Shroff. I didn't interrupt you. I heard Ms. Shroff say at the beginning of the sidebar that this was a Rule of Law investigation and then I just heard Mr. Schirick say it preceded the Rule of Law. It's confusing. The jury is going to be confused about why this testimony is being elicited. I think that's reason enough to not elicit it. MS. SHROFF: Your Honor, that's the pre——as he put it, predecessor, predecessor steps to the formation of the Rule of Law Foundation. This is the first step. THE COURT: So once the Rule of Law Foundation was formed, did they do anything in connection with an investigation in France? MR. SCHIRICK: That is the subject of the Bannon video which is launch——the announcement of the launch of the Rule of Law. It is a direct factual connection. They talk about it extensively in the Bannon video that the government put into
549 O5T1GUO4 Maistrello - Cross evidence. THE COURT: But did they do anything? MS. SHROFF: They ran the investigation. And then they publicized what they believed happened as a result of their findings of the investigation. I really—— THE COURT: So you're saying after the founding of Rule of Law Foundation, there was work in connection with the French investigation; that's your representation? MS. SHROFF: That's not what I'm saying. Not——there was——I wouldn't call it the French investigation. What I'm saying is, this guy was murdered. Mr. Guo took his own money, started this investigation, and as a result of the start of this investigation, it morphed into the establishing of the Rule of Law Foundation, which they claim in the indictment is part and parcel of the racketeering enterprise which is an entity formed for no reason other than to fleece money, and what we're trying to show is, this is how it started, this is how Rule of Law got developed and what else it did. It's a natural progression. And also it is because they are putting in the video of Mr. Bannon—— THE COURT: Does Mr. Bannon say that the Rule of Law Foundation is undertaking work having to do with this investigation in France? MR. KAMARAJU: Yes. MR. SCHIRICK: Yes.
550 O5T1GUO4 Maistrello - Cross MR. KAMARAJU: But also, your Honor, the witness on direct testified about preparatory steps taken to start the Rule of Law. That's why they elicited it, when they had that discussion, in order to elicit her statement that Mr. Guo supposedly said, we're going to need a hundred million dollars. So again, they already brought the preparation into it. This completes the narrative. MR. HORTON: First, her testimony was that she undertook this preparation in September, consistent with the representation, one of the two representations that this event predated the Rule of Law, not that it originally started that it was a Rule of Law investigation. But I think more fundamentally, that this is a fraud case and this is now coming in as he had this money before that he used on this investigation to do good works looking into a murder. MS. SHROFF: Not good works. MR. KAMARAJU: I'm sorry. It's not a fraud case, it's a racketeering case, at their insistence. Your Honor's already ruled on this, when your Honor rejected their motion in limine to preclude the defense from talking about any of the positive activities of these organizations. Under RICO law, they have to prove continuity, and if the organization was a legitimate enterprise, then the test for continuity is different. So in any speaking of the law, the fact that these institutions had legitimate origin stories and had legitimate business afterward
551 O5T1GUO4 Maistrello - Cross is directly relevant to the racketeering charges that the government chose to bring. MS. SHROFF: It's not to the—— MR. FINKEL: May I respond, your Honor. At most, there might be a question, which Ms. Shroff has already elicited, about whether she traveled to France for an activity, but what Ms. Shroff is endeavoring to do, it appears, is to get into the details of an investigation about a murder of someone who's completely irrelevant to anything alleged in the indictment, that happened in Europe. So I think we're very far afield of what the gravamen of this entire trial is about. And while there might be a probative purpose for activities that either predated or are part of the Rule of Law——which, by the way, this witness says it wasn't under the Rule of Law. But in any case, your Honor, that's already been elicited, and it's time to move on. And that's our argument. THE COURT: What more is it that you want to elicit? MS. SHROFF: I've actually completely lost track of the question. I don't remember the question anymore. I'm telling you very candidly. But again, what we're trying to show is the issue of the enterprise that the government charged. We do not care if this guy was murdered or not. Nobody cares. Right? And—— MR. FINKEL: So why ask the question? MS. SHROFF: Because you have alleged——can you help me
552 O5T1GUO4 Maistrello - Cross out here. I'm sorry. MR. FINKEL: If they want to ask, did you take a trip to France as part of the Rule of Law, okay, but getting into the details of the investigation is completely far afield. MR. KAMARAJU: First of all, they've already introduced the details of the investigation; not us, them. They did it with the Steve Bannon video in evidence. THE COURT: The Steve Bannon video, what is that going to say? MR. KAMARAJU: The Steve Bannon video, which is in evidence already, through a stipulation that they put in yesterday, says that Miles Guo launched this investigation; as a result of that investigation, they are going to publicize the results of that investigation; they're going to go after financial institutions that enabled the CCP, and that that is part of the mission of the Rule of Law Foundation. And that's why it's been started. And they can say it's not in evidence. They admitted it, your Honor. MR. FINKEL: That's not our argument. MR. KAMARAJU: Hold on. That's not the point. Whether it's your argument or not, we get to have an argument also, and our argument is that the Rule of Law Foundation is a legitimate enterprise that has a legitimate beginning, it has a legitimate purpose, it has legitimate operations. And if we can show that, your Honor, then that changes their burden.
553 O5T1GUO4 Maistrello - Cross THE COURT: So what I want to understand, though, is: Exactly what is it that you're trying to bring out right now? MR. KAMARAJU: Ms. Shroff. I think it's simply——your Honor, I think it's simply this is a real endeavor; this witness went on a real endeavor, they went to conduct an investigation, it was real, it was funded by Mr. Guo and the enterprise, that enterprise ultimately culminates in the Rule of Law Foundation. The work that is done prior becomes the work of the Rule of Law Foundation. THE COURT: So—— MS. SHROFF: How about this, your Honor. Maybe I can answer the question. Mr. Guo funded this trip; Mr. Go funded the investigation. And this was the precursor to the establishing of the Rule of Law Foundation. How about those three questions? MR. FINKEL: She doesn't have any personal knowledge. MS. SHROFF: If she doesn't, then she can say no. THE COURT: If she does not know, she can say no. They have a good-faith basis to ask the question, and so I'm going to permit the question. MR. HORTON: If I could just say one more thing, your Honor. THE COURT: Yes. One more thing. MR. HORTON: I just want to clarify that the question
554 O5T1GUO4 Maistrello - Cross is close to one——it's quite close to one that was asked and answered, which is: Was this done through the Rule of Law? So if there's a question that comes in that's close to asking her to try again on that, essentially, we will object to it's asked and answered. MR. KAMARAJU: This is not the same, though. MS. SHROFF: Really we should stop sustaining asked and answered objections. It's not going to hurt the jury to hear about that, your Honor. THE COURT: Okay. All right. Let's go. (Continued on next page)
555 O5T1GUO4 Maistrello - Cross (In open court) THE COURT: Go ahead. BY MS. SHROFF: Q. Mr. Guo funded the trip, correct? A. He did. Q. Okay. And after the trip was the start of the Rule of Law Foundation, correct? A. That's correct. Q. Okay. And the Rule of Law Foundation was what we call colloquially an NGO, correct? A. It was a nonprofit organization. Q. Okay. And you at one point were part and parcel of Rule of Law Foundation's efforts, correct? A. Rule of Law Society and Foundation, yes. Q. Okay. And as part of that responsibility, you were involved in the launch of Rule of Law; is that correct? A. Correct. Q. Right. And there were several meetings that were held as to how the Rule of Law Foundation should be announced, correct? A. Yes. Q. There were agendas drafted up, correct? A. I don't remember that. Q. Okay. There were meetings, correct? A. There were. Q. And people discussed what was the best way to bring this
556 O5T1GUO4 Maistrello - Cross forward, right? A. Yes. Q. And who was involved in those meetings; do you know? A. Usually it was Boss, Steve Bannon, William whenever he was in New York, Yvette was there. Q. And who else was present? A. I was there. Q. Were you there for all of the meetings? A. Most of them. Q. Most of them. But there were some meetings to which you were simply not privy, correct? A. If they had a meeting that I don't know about, then I——I don't know. Q. Right. But there were discussions about who would be in what meeting, and you were left out of some of the meetings, correct? A. I don't know. Q. Okay. Fair enough. And you talked about Steve Bannon being present at some of these meetings, right? A. Yes. Q. Fair to say Mr. Bannon is a controversial figure, correct? MR. HORTON: Objection, your Honor. THE COURT: You may answer. A. What do you mean by controversial?
557 O5T1GUO4 Maistrello - Cross Q. You know what? Fair enough. MS. SHROFF: I'll move on, your Honor. Q. Steve Bannon was part of these meetings, correct? A. Yes. Q. Steve Bannon's position, at least on China, is pretty public, correct? A. It is. Q. Right. And you understood Steve Bannon, regardless of all the other problems the man has, he was against the CCP, correct? MR. HORTON: Objection, your Honor. THE COURT: Overruled. You may answer. A. He claimed to be against CCP. Q. Right. And he was vocal about the fact that he was against the CCP, correct? A. He shared his opinion. Q. Okay. And is it fair to say that you——did you not believe his opinion about the CCP? A. I——I never said that. Q. No. I'm asking you. You sound like you disbelieved that he was anti-CCP. Do you believe he was anti-CCP? A. I only know what he said, and he said he was against. Q. Okay. So you took him at face value that he was anti-CCP, correct? MR. HORTON: Objection, your Honor.
558 O5T1GUO4 Maistrello - Cross THE COURT: Sustained. Q. And Mr. Bannon was part and parcel of these conversations as to how to launch the Rule of Law Foundation, correct? A. Yes. Q. Okay. And Yvette was part and parcel of this, correct? A. Yes. Q. And part of the discussions was what projects Rule of Law Foundation would undertake, correct? A. At the very beginning, no. Q. Okay. You tell me. What was discussed at the very beginning? A. At the very beginning, so from July of 2018 to November of 2018, a lot of the discussion was around what happened in France and the alleged or possible involvement of the CCP in what happened. Q. Right. And then there were——there were a lot of discussions about whether or not CCP was involved in the murder in France, but then it moved on and started the Rule of Law Foundation, correct? A. This was in November. Q. Right. A. Yes. Q. In November there were discussions whether or not——as to what the Rule of Law Foundation would have as its aims and its objectives, correct?
559 O5T1GUO4 Maistrello - Cross A. Yes. Q. Okay. And the aims and objectives——and you please correct me if I'm wrong——was to help those who were the victims, so to speak, of the CCP, correct? A. That's correct. Q. And everybody in that room agreed, right, that the CCP was a very separate entity than the People's Republic of China, correct? MR. HORTON: Objection, your Honor. THE COURT: Sustained. It's not clear that she can speak for what the group believed. Q. Okay. Well, you believed, did you not, that the CCP is very different from the people of China, correct? A. Yes. Q. Okay. And the goal was to help the people of China, right? A. That's correct. Q. Right. And whether the people of China now lived in the United States or elsewhere, the goal was to help the dissidents as well, correct? MR. HORTON: Objection, your Honor. THE COURT: Overruled. You may answer. A. Yes. Q. And the goal was to make sure they felt supported, correct? A. Yes. Q. And part of the——part of the support system would involve
560 O5T1GUO4 Maistrello - Cross helping them with their asylum applications, correct? A. Also. Q. Right. Helping them navigate when they couldn't speak the language, correct? A. I don't remember this point specifically. Q. Okay. Well, you tell me. You were there. So you tell me what the goals and objectives were of the Rule of Law Foundation. A. Everything you said is correct, so the goal and mission of Rule of Law Society and Foundation was to help Chinese people in various forms. It could be from a legal perspective to help——they just needed——and it was also to——excuse me——to educate the public on——on China. Q. Okay. And there were proposals made on how to educate people on what was going on in China, correct? A. Yes. Q. Okay. And some of the proposals were accepted and some of the proposals were rejected, correct? A. All of them were rejected. Q. Well, all of yours were rejected. A. Not mine specifically, but proposals that came in. Q. I'm sorry. Your testimony is that every proposal ever made for the Rule of Law Foundation was rejected? A. While I was there, yes. Q. Okay. So there would be board meetings, correct?
561 O5T1GUO4 A. There was one board meeting in January of 2020, yes. Q. Okay. You were part of that board meeting, correct? A. Yes. Q. And you didn't take any notes of that board meeting; is that true? A. No. Someone else did. Q. Someone else took minutes of that board meeting. You didn't take them, correct? A. That's correct. Q. Okay. And—— THE COURT: We're going to stop here. It's 2:45. So members of the jury, 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. Please return on time, as you have in the last couple of days, so that you can walk right through that door at 9:30 and we can get going on time. Have a good evening. THE LAW CLERK: Jury exiting. THE COURT: Don't discuss your testimony. (Jury not present) THE COURT: We will return tomorrow for the continuation of Ms. Maistrello's cross-examination. Is there anything before we break?
562 O5T1GUO4 MR. KAMARAJU: Not from us, your Honor. MR. FERGENSON: Nothing we can't take up in the morning, your Honor. THE COURT: All righty then. Thank you. See you tomorrow. ALL COUNSEL: Thank you, your Honor. (Adjourned to May 30, 2024, at 9:00 a.m.)
563 INDEX OF EXAMINATION Examination of: Page LE ZHOU 353Cross By Mr. Kamaraju . . . . . . . . . . . . 406Redirect By Ms. Murray . . . . . . . . . . . . 410Recross By Mr. Kamaraju . . . . . . . . . . . KARIN MAISTRELLO 420Direct By Mr. Horton . . . . . . . . . . . . . 485Cross By Ms. Shroff . . . . . . . . . . . . .
564 GOVERNMENT EXHIBITS Exhibit No. Received VO-33 359 . . . . . . . . . . . . . . . . . . . SM62 448 . . . . . . . . . . . . . . . . . . . 102 425 . . . . . . . . . . . . . . . . . . . . 103 460 . . . . . . . . . . . . . . . . . . . . 105 463 . . . . . . . . . . . . . . . . . . . . 110 449 . . . . . . . . . . . . . . . . . . . . 130 427 . . . . . . . . . . . . . . . . . . . . 141 423 . . . . . . . . . . . . . . . . . . . . UK723 433 . . . . . . . . . . . . . . . . . . . UK728 453 . . . . . . . . . . . . . . . . . . . BR871 429 . . . . . . . . . . . . . . . . . . . DEFENDANT EXHIBITS Exhibit No. Received 60476 382 . . . . . . . . . . . . . . . . . . . Stip 0001 405 . . . . . . . . . . . . . . . . .
Translated Text(简体中文翻译)
347
O5TVGUO1
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 29 日
上午 9:00
之前：
亲爱的。安娜丽莎·托雷斯，
地区法官
-还有陪审团-
出场
达米安·威廉姆斯
美国检察官
纽约南区
作者：MICAH F. FERGENSON
瑞安·B·芬克尔
贾斯汀霍顿
朱莉安娜·默里
美国助理律师
SABRINA P. SHROFF
被告律师
PRYOR CASHMAN LLP
被告律师
作者：SIDHARDHA KAMARAJU
马修·巴尔坎
ALSTON & BIRD LLP
被告律师
作者：E. SCOTT SCHIRICK
348 O5TVGUO1 还出席： 伊莎贝尔·洛夫特斯，律师助理专家，USAO 迈克尔·加特兰，律师助理专家，USAO Geoffrey Mearns，律师助理专家，USAO 罗伯特·斯托特，联邦调查局特工 鲁本·蒙蒂拉，国防律师助理 黄拓，口译员（普通话） 石峰，口译员（普通话） Yu Mark Tang，口译员（普通话）
349 O5TVGUO1 （审判恢复；陪审团不在场） 法庭：早上好。 请露面。 芬克尔先生：早上好，法官大人。瑞安芬克尔， 朱莉安娜·默里、米卡·费根森和贾斯汀·霍顿参加 政府。伊莎贝尔·洛夫特斯也加入了我们的律师行列， 谁是我们办公室的律师助理。 KAMARAJU 先生：早上好，法官大人。Sid Kamaraju 还有代表郭先生的 Scott Schirick。而且郭先生也在 我们在律师席上。 法庭：请坐下。 2024 年 5 月 27 日，政府提交了一项动议 允许某些由保存的副本组成的证物 在 G 新闻和盖特上发布的在线帖子，ECF 第 352 号。 被告于 2024 年 5 月 28 日提交了反对文件， ECF 361。 我还查看了基础文件 政府试图承认，主要依赖安德森诉案 美国，417 U.S. 211 (1974)。政府辩称 它提供这些职位不是为了了解事情的真相 其中断言；相反，它说它提供的是 帖子 “因为它们存在，即它们是制作的 在被告创建和控制的媒体网站上。” 我同意政府的观点，即这种预期用途 不在传闻的定义范围之内。在安德森，
350 O5TVGUO1 法院裁定一份陈述不是传闻，因为它 没有被提出 “证明任何断言的真实性” 其中”，但是 “是为了证明这些陈述是为了证明这些陈述是为了 为以后通过其他方式展示奠定基础 可接受的证据证明它们是虚假的。”同上 220。 此外，就目击者查看帖子而言 有争议的是，他们可以作为非传闻来证明他们的 对观看者的影响。SEC 诉 AT&T, Inc.，626 F. Supp. 3d 703， 737（纽约州标准时间 2022年）。 因此，我不会排除传闻中的帖子 理由。 我还发现，根据《联邦证据规则》401 以及 403，媒体组织 Gnews 和 Gettr 上的帖子 政府声称是由政府创建和控制的 被告，与 G Enterprise 的证据有关，并且是 被告欺诈计划的证据。 因此，政府的动议获得批准。 目前还有其他申请吗？ FERGENSON 先生：法官大人，这不是这样。 SCHIRICK 先生：不，法官大人。 FINKEL 先生：法官大人，我只是想找个地方 如果可以的话，有一些记录在案。 在查看了昨天的笔录和笔录之后 考虑到了法院在抢劫室对律师的评论， 政府非常认真地对待，也非常认真地对待，
351 O5TVGUO1 施罗夫女士昨天向政府举报了一些东西 我只想把它记录在案, 供法院记录在案. 正如法院所知，昨天上午，施罗夫女士 表示她需要更多时间来审查受害者的3500英镑 材料。而且我表示那个受害者最初是设定的 昨天去作证但我们昨天不会给她打电话 这将为辩方提供更多时间进行审查 那个新的 3500。 看笔录，里面我还不清楚 那一刻决定不给受害者打电话 早上，就在你的Honor坐上替补席之前，就在之前 法官大人叫我们进了抢劫室无论如何， 重新排序的决定似乎回应了施罗夫女士的要求 争取更多时间，这就是我提出这个问题的原因。 在某种程度上，我对你造成了任何误解 法官大人，对于各方，我对此深表歉意。我做到了 不打算这样做。我们将继续与国防合作 咨询并继续非常认真地对待并关注 法院指示以高效、高效的方式进行审判 负责任的态度。 法庭：我没有负面印象 昨天早上，我很高兴看到大家都是 合作得很好。 芬克尔先生：我也是。谢谢。 FERGENSON 先生：对不起，法官大人。
352 O5TVGUO1 法庭：来吧。 FERGENSON 先生：我有一个相关的观点，还有一个简短的观点 要记录在案。 我们在防守方面一直非常富有成效 就与沙梅尔有关的几项规定提供法律顾问 梅德拉诺作为简要证人就这些G新闻所作的证词 还有盖特的帖子和其他视频。我们已经制作了以下视频片段 更长的视频。 辩方可能寻求提供其他部分 在完整性规则下更长的视频。我们有 同意政府可能会对以下问题提出实质性异议 例如，那些遵守传闻规则的人，但我们不去 你知道，反对及时性之类的东西。 这样防守方就有更多时间考虑如果 他们想提供的任何其他部分。 而且我只是想把它记录在案所以是 明确防守很安慰我们不会对此提出异议 以后的基础。 法庭：我很高兴听到这个消息。 FERGENSON 先生：谢谢你，法官大人。 法庭：还有别的吗？ KAMARAJU 先生：不是来自我们，法官大人。 法庭：所以我想让证人回来 比如说 9:29 待命，这样陪审员开会时他就在这里 进来吧。谢谢。
353
O5TVGUO1 周乐-十字架
芬克尔先生：谢谢。
KAMARAJU 先生：谢谢你，法官大人。
（休会）
法庭：早上好。请坐下。
你会让陪审员进来吗。
（陪审团出席）
法庭：陪审员，早上好。
陪审团：早上好。
法庭：请坐下。
今天上午我们将继续
盘问周先生
请记住，你仍在宣誓就职。
你可以查询。
KAMARAJU 先生：谢谢你，法官大人。
周乐，
被政府传唤为证人
此前已正式宣誓就职，作证如下：
盘问（续）
作者：KAMARAJU 先生：
问：早上好，周先生。
答：早上好。
问：你还记得昨天曾就某些 G Fashion 作证吗
你购买的物品？
答：是的。
问：好吧。其中之一是这些睡衣；对吗？
354 O5TVGUO1 周乐-十字架 答：正确。 问：然后是哨声，对吧？ 答：正确。 问：这件衬衫？ 答：是的。 问：还有那顶帽子，对吧？ 答：是的。 问：好吧。这还不是你从 G 购买的所有物品 时尚，对吧？ 答：正确。 问：你还买了好几个，对吧？ 答：正确。 问：当你与检察官会面时，你仔细检查了这些物品 你购买的；对吗？ 答：正确。 问：然后你浏览了物品的照片；对吗？ 答：正确。 问：那是你购买的所有物品中的一部分，对吧？ 答：不是。 问：不是？ 答：不是。 问：你用他们看了多少物品？ 答：大约 20 件物品。 问：对不起？ 答：二十件物品。
355 O5TVGUO1 周乐-十字架 问：大约 20 个？ 答：正确。 问：好吧。当你浏览这 20 件物品时，谁 决定将这些人告上法庭？ 答：我决定了。 问：好吧。所以你是选择哪些物品的人 是作为这些展品介绍的？ 答：正确。 问：好吧。你和检察官讨论过这个问题吗？ 答：是的。 问：好吧。他们有没有给你建议哪些物品 应该带进来吗？ 答：他们提到的不是特定的项目，而是该类别中的项目。 问：好吧。比如什么样的类别？ 答：帽子、衬衫、裤子和我做过的珠宝。 问：对不起，我没有听到最后一部分。 答：不，不是。珠宝。对不起。 问：好吧。所以他们没让你带珠宝？ 答：不是。 问：你选了哨子。你认为口哨是吗 珠宝？ 答：我选了口哨，两个口哨，是的。 问：好吧。所以你选了两个口哨来看？ 答：是的。 问：好吧。但是他们只问你一个问题，对吧？
356 O5TVGUO1 周乐-十字架 答：正确。 问：所以他们确实做了一些决定—— 答：不，他们保留了一个。 问：好吧。但是在法庭上他们只给你看了一个，对吧？ 答：是的。 问：所以他们确实做出了一些决定要在这里展示什么 法庭，对吧？ 法庭：他无法就他们是什么作证 思考。他可以作证说自己是否做出了决定。 KAMARAJU 先生：好吧。 问：你决定带两支口哨来看 法庭；对吗？ 答：是的。 问：好吧。而且检察官只在这里给你看了一个 法庭，对吧？ 答：正确。 问：谢谢。 现在，你有大约 20 件物品 从 G Fashion 购买的，你有没有和他们讨论过所有问题 检察官？ 答：我购买了 20 多件商品。 问：好吧。对不起。你大概购买了多少件物品？ 答：大约 30 件物品。 问：三十件物品。好吧。 记得昨天你曾就哨声作证；
357 O5TVGUO1 周乐-十字架 正确？ 答：正确。 问：那是金口哨，对吧？ 答：正确。 问：这是某种纪念品？ 答：对不起？ 问：这是某种纪念品？ 答：这是限量版，只生产了77个。 问：好吧。对不起。限量版。 KAMARAJU 先生：我们能不能只为证人提起诉讼， 请法院和当事方 GX VO-67。 法官大人，在与政府协商之后， 看来已经出来了，所以我要要求把它公布给陪审团 也是。 法庭：来吧。 问：好吧。那么，周先生，你看到这个日期了吗 电子邮件？ 答：是的。 问：好吧。现在是 2021 年 2 月 28 日；对吗？ 答：正确。 问：好吧。而这时你 —— 这是命令 确认您何时购买了限量版口哨； 正确？ 答：正确。 问：现在，我相信你作证说，当你收到
358 O5TVGUO1 周乐-十字架 吹口哨，有件事让你对此感到怀疑， 对吧？ 答：正确。 问：这就是你权衡的原因，对吧？ 答：我称了一下，是的。 问：好吧。然后你权衡了它是因为你认为可能有 有什么问题吗？ 答：当我收到它时，当我第一次打开它时，包装 在里面，上面有一点金尘。而且，的 当然，我拿起哨子。看上去是精湛的工艺 我有点粗鲁。因为这是限量版， 那是收藏品，正如 G Fashion 所宣传的那样，这是一件 最好的、最好的工艺品，所以这就是我担心的原因。 问：好吧。所以你对此不满意；对吗？ 答：不满意。因为仍然像宣传的那样，这是一个 限量版 — 世界上只有 77 个。我明白 价值本身，就在那里。但是当我收到的时候是什么样子， 这是我收到的。 法庭：Kamaraju 先生，你会画吗 请麦克风离你更近一点。 KAMARAJU 先生：对不起，法官大人。是的。 这样更好吗？ 法院：是的。 KAMARAJU 先生：好吧。 问：如果你听不见我的话，请告诉我。
359 O5TVGUO1 周乐-十字架 答：我听见你了。 问：谢谢。 KAMARAJU 先生：我们能不能为证人和 当事方和法院 GX V0-33 —— 对不起，VO-33。 问：周先生，你认出这份文件吗？ 答：是的。 问：这是什么？ 答：这是我在 G Fashion 网站上截取的屏幕截图。 问：好吧。屏幕截图反映了什么？ 答：反映我之前的订单和商品日期，支付的金额。 问：好吧。而支付的金额是什么？ 答：所有物品——大部分物品已购买。这还不是全部 它。 问：好吧。所以这是你购买的大部分物品，但来自 G Fashion；对吗？ 答：正确。 KAMARAJU 先生：好吧。法官大人，我要提出 政府展品 VO-33 成为证据。 法院：没有异议？ MURRAY 女士：没人反对。 法院：可以接受。 （收到的政府展品 VO-33 作为证据） KAMARAJU 先生：请问我们能不能把它发布出来。 问：好吧。所以之前我们看过订单 确认购买口哨；对吗？
360 O5TVGUO1 周乐-十字架 答：正确。 问：那是 2021 年 2 月 28 日；对吗？ 答：是的。 问：好吧。因此，如果你从第五行往下看 底部，所以是 2021 年 2 月 12 日；对吗？ 答：正确。 问：好吧。所以在那之后—— KAMARAJU 先生：我们可以把它拉下来。 问：在那之后，你购买了多次 G 时尚服装，对吧？ 答：正确。 问：而且我相信你作证说这甚至不能反映 你购买的所有 G Fashion，对吧？ 答：正确。 问：因此，尽管你担心它的工艺 吹口哨，你继续买 G Fashion，对吧？ 答：是的。 问：而且你继续花了大量的钱 G Fashion，对吧？ 答：花钱也是为了帮助 G Fashion 增长。因为据我了解，我是 G Fashion 的一员 股票股东。我会尽我所能做出贡献， 即使是购买物品。 问：所以你想为 G Fashion 的发展做出贡献 通过购买这些物品，对吧？
361 O5TVGUO1 周乐-十字架 答：正确。 问：而且你认为 G Fashion 已经被撤回了。 你认为 G Fashion 的成长很重要 达到运动的目标；对吗？ 答：因为 Miles Guo 提到 G Fashion 的估值是 高得惊人，也达到了数十亿美元。 问：对。但我问你是否明白那种增长 of G Fashion 对这场运动很重要，先生？ 答：是的。 问：好吧。所以你一直在努力 —— 不管你做什么 刚刚作证，你也想通过以下方式帮助该运动 购买 G Fashion 服装；对吗？ 答：没错。 问：好吧。所以你继续买 G Fashion 服装，对吧？ 答：正确。 问：现在，你之前已经退出了。 在购买 G Clubs 会员资格之前，您还有 购买了 G Fashion，对吧？ 答：正确。 问：现在，在您购买 G Clubs 会员资格后，您 开始在你的 G Fashion 服装上获得折扣，对吧？ 答：正确。 问：多少——你获得的折扣百分比是多少？ 答：百分之五十。 问：好吧。因此，每次你购买其中一件物品时
362 O5TVGUO1 周乐-十字架 有 50% 的折扣，对吧？ 答：不是每次。 问：在你购买 G Clubs 会员资格之后，对吧，先生？ 答：正确。 问：那你总共得到了多少折扣，先生？ 答：如果是预估的话，就是折扣 —— 对不起，我没能买到 数字数量的准确折扣。 问：好吧，先生，你要求了多少退款？ A. 退款来自哪里—— 问：G Fashion。 答：我要求G Fashions退款超过12,000美元。 问：好吧。而且 12,000 美元是你在收到 50 美元后所花的钱 百分比折扣？ 答：还包括非折扣商品。 问：它还包括未打折的商品吗？ 答：正确。 问：好吧。那么可以公平地说你的折扣金额吗 有几千美元吗，先生？ MURRAY 女士：对表格提出异议。 法院：驳回。你可以回答。 答：是的。 问：已经超过1万美元了，对吧，先生？ 答：是的。 问：好吧。所以你花了5万美元买了会员，对吧？ 答：是的。
363 O5TVGUO1 周乐-十字架 问：在一年半左右的时间里，你赚了钱 超过10,000美元的折扣，对吧？ MURRAY 女士：反对。表格。 法院：驳回。你可以回答。 答：是的。 问：那些是针对你也在购买的商品的 因为你想为这场运动提供帮助，对吧？ MURRAY 女士：反对。 法院：驳回。你可以回答。 答：你能重复一下这个问题吗。 问：当然。 KAMARAJU 先生：请问我们能不能回读一下？ 法庭：来吧。 （读取记录） 答：不仅是帮助，而且是为了帮助这家公司 增长并提高股票价值。 问：对。但是，先生，你不是在几分钟前作证吗 你购买 G Fashion 的原因之一是 为运动提供帮助？ MURRAY 女士：反对，法官大人。 法院：持续。询问并回答。 问：先生，你什么时候要求退款的？ 答：我记不起日期了。 问：是在你开始和检察官交谈之后吗？ 答：不是。
364 O5TVGUO1 周乐-十字架 问：所以你在与他们交谈之前就申请了退款 检察官，这是你的证词吗？ 答：是的。 问：那是给 G Fashion 准备的，先生；对吗？ 答：是的。 问：你的 G Clubs 退款怎么样，你是什么时候要求的？ 答：我在 2023 年 7 月 15 日提交了申请。 问：所以你还记得日期 —— 所以 G Clubs 会退款 是 2023 年 7 月 15 日；对吗？ 答：正确。 问：好吧。G Fashion 的退款申请是在那之后提出的？ 答：我记不起来了。 问：所以你不记得 G Fashion 是以前的还是 在 G 俱乐部之后？ MURRAY 女士：反对。 法庭：询问并回答。 问：现在，如果你看看 GX VO-33，会有 3 月 1 日的排队， 2021；对吗？ 答：正确。 问：好吧。那里的第一行。你看见了吗？ 答：我看到了突出显示的内容，是的。 问：对。好吧。所以这反映了你的专栏 收到了一件商品的退款，对吧？ 答：是的。 问：好吧。所以无论如何，如果你不满意
365 O5TVGUO1 周乐-十字架 什么，你可以申请退款；对吗？ 答：这件商品缺货。 问：好吧。所以你不满意 —— 你没有收到 这件商品，所以你得到了退款，对吧？ 答：缺货了。我从未收到。 问：对不起，先生，我只是想问你收到退款了吗？ 答：已记入积分商店。 问：现在，你在一分钟前谈到了 G Clubs 会员资格。 而且我相信你直接作证说你为两者都付了钱 那些通过支票获得的会员资格，对吧？ 答：正确。 KAMARAJU 先生：请问我们能不能有 GX VO-26，那个 是明证。也向陪审团提起这个问题。 问：所以这些是支票，对吧？ 答：正确。 问：好吧。 KAMARAJU 先生：如果我们能滚动到第 10 页， 拜托。 问：好吧。现在，这是 —— 这是你的会员页面，是 这么公平地说？ 答：正确。 问：好吧。所以它会在 5 级中反映你的名字 会员，对吧？ 答：正确。 问：它在那里列出了会员权益吗？它在左边
366 O5TVGUO1 周乐-十字架 侧面。 答：是的。 问：你能读一下那里说的吗？ 答：“G Fashion 五折优惠，G 俱乐部宣传册。” KAMARAJU 先生：好吧。我们能不能转到第 12 页 拜托那个展览。 好吧。抱歉，又是这张支票，对吧？好吧。 对不起。这是正确的。 问：好吧。这是 Tier 2 的会员页面 你购买的会员资格，对吧？ 答：正确。 问：好吧。现在，这是你代表姐姐买的， 对吧？ 答：不，目前是在我们购买时推出的；在 将来我们可以转到这个家庭。 问：好吧。你能解释一下吗，先生。 答：是的。郭文亮提到了G|CLUBS、会员资格、 第 1 层到第 5 层。关注者，我们可以购买，但那是 提供了护照。但是我姐姐不必这样做 —— 我不需要 得把她的名字放在第一位我有权转账到我的 定向家庭成员。 问：所以，如果我理解正确的话，先生，我的想法是你 可以用你的名义购买会员资格，这样最终 如果你愿意，你可以把它转移给家庭成员，对吧？ 答：正确。
367 O5TVGUO1 周乐-十字架 问：好吧。那是好处吗 —— 在你看来，是吗 福利对所在地的家庭成员特别有用 在中国？ 答：仅限直系亲属；不管是否在 中国或其他国家。 问：好吧。所以在任何地方，对吧？ 答：是的。 问：现在，您填写了 G Clubs 会员协议； 正确？ 答：没有协议。我从来没有签过也没收到。 KAMARAJU 先生：那么我们能不能转到第 8 页。我们能不能 只要炸掉 —— 那封电子邮件就行了。 答：这是收到的付款确认电子邮件。 问：对。我只是问你能不能读懂第一行 那封电子邮件的内容，先生。 答：是的。 “亲爱的周乐，2021 年 8 月 25 日 0:47:10，你 已提交您已完成并已执行的申请以成为 G 俱乐部的 5 级会员。我们收到了您的会员费 金额为50,000美元。您的申请正在审核中，我们 可能会与您联系以获取更多信息。我们会给你发电子邮件 在 30 天内确认我们的决定。” 问：好吧。所以我只想确保我理解正确， 先生。你说过你从未提交过 G Clubs 的申请；是 对吗？
368 O5TVGUO1 周乐-十字架 MURRAY 女士：反对，法官大人。 法院：持续。 KAMARAJU 先生：好吧。 问：所以你在没有提交的情况下收到了这封电子邮件 应用程序；对吗？ MURRAY 女士：反对，法官大人。 法院：持续。 KAMARAJU 先生：我们可以把它记下来。谢谢。 问：现在，你直接作证说郭先生最终作证了 你有机会购买H币，对吧？ 答：他提到H币将提供给粉丝。 问：好吧。但是有时候H币不可能出现 由美国居民购买，对吧？ 答：正确。 问：所以我相信你直接作证说有一个 美国居民可以在哪里购买喜币；对吗？ 答：不是 —— 好吧，他说将来会扩展 H 一旦获得适当的许可证，喜马拉雅就会交换领土。 问：好吧。因此，一旦获得适当的许可证，那么美国 居民也许可以购买它，对吧？ 答：是的。 KAMARAJU 先生：请问我们能不能有 GX VO-78，那个 是明证。 问：好吧，先生。你能提醒我们这是什么吗？ 答：是的。这是一份提名股东协议，提供给
369 O5TVGUO1 周乐-十字架 我来自英国伦敦俱乐部。 KAMARAJU 先生：好吧。还有字母下的第一行 同意，我们能不能把它搞砸了。 问：好吧。你看到开头的那句话了吗：“我很高兴 来告诉你”？ 答：是的。 问：那你明白它在哪里说吗：“为了认识到 你做出的贡献”？ 答：是的。 问：这是指你对农场的捐款， 对吧？ 答：不，据我所知，贡献是之前的全部捐款 系列投资。 问：好吧。所以你的理解是，这些捐款是 这里指的是G系列投资，而不是 你为农场做了什么？ A. 对志愿者的部分捐款用于 捐款，捐款捐款。 问：因此，在计算出捐款的过程中，这一切都是相互关联的， 对吧？ 答：工作、投入的时间、精力和捐款。 问：是的。这就是我所指的，作品和 贡献；它们共同决定你的—— 你会得到什么好处，对吧？ MURRAY 女士：反对，法官大人。
370 O5TVGUO1 周乐-十字架 法院：驳回。你可以继续。 答：当时，是的，捐款，我的理解是 捐款以及为此投入的时间和精力。 KAMARAJU 先生：现在，我们能不能转到第 8 页。 对不起，我们能不能快速滚回第 7 页。 问：你看到那里 C 开头的分段了吗？ 答：是的。 问：好吧。你会看到上面写着的部分：“你在这里 同意不执行以下行为”？ 答：是的。 问：它接着说：“让你受益而且 继续，” 你看到那种语言了吗？ 答：是的。 问：好吧。所以这是在告诉你一些你不应该做的事情 如果你想保留优先的H币配额，对吧？ 答：对不起？ 问：本条款涉及的是你不应该做的事情 这样做是为了维持你以前提供的有益的H币优惠 明白了，对吧？ 答：是的。 KAMARAJU 先生：好吧。如果我们能转到下一页 然后请把三号炸掉。 问：你能读懂吗，先生？ 答：是的。 “你承诺不进行示威，无论是直接示威还是
371 O5TVGUO1 周乐-十字架 间接或以任何形式促进任何支持或 以任何形式造福于中国共产党，中共， 引用，或者任何中共官员的话。” 问：好吧。所以你应该避免的一件事 这样做就是支持中共，对吧？ 答：对不起，指的是—— 问：好吧，你之前作证说这是在说这个 为了保持你的H币配额，你不应该做的事情，对吧？ 答：正确。 问：其中一件事是不支持中共，对吧？ 答：正确。 问：因为该运动是反中共的，对吧？ 答：正确。 问：所以如果你支持中共，那显然是反的 运动，对吧？ 答：不是我的支持，但是—— 问：任何人，先生。我不是特别指你。 答：正确。 问：现在，你稍微谈了你所做的工作 代表农场，对吧？ 答：正确。 问：所以你实际上为他们做了大量工作 农场，对吧？ 答：是的。 问：再告诉我们你做了什么样的工作。
372 O5TVGUO1 周乐-十字架 A. 笔录、审阅翻译，我们进行了编辑和 直播。 问：好吧。那么，可以公平地说你刚才的工作吗 描述的目标是传播该运动的信息？ 答：帮助传播信息，是的。 问：好吧。而且你知道广播意义重大 这是该运动努力的一部分，对吧？ 答：我要说等同于其他信息，其他类型的工作。 问：好吧。而且我不是要你说什么更重要或不是， 我只是说这是该运动所做工作的很大一部分 广播，对吧？ 答：不，这不是大部分。我说这等于其他工作。 问：好吧。嗯，你首先是通过观看了解郭先生的 已经发布的在线视频；对吗？ 答：是的。 问：好吧。那你第一次在 YouTube 上见到他吗？ 答：是的。 问：又是什么时候？ 答：2017 年 2 月。 问：所以你看见郭先生了 —— 退出了。 那是在郭先生的 YouTube 账户上吗？ 答：不是。 问：好吧。所以你看见他被别人转播了 YouTube 账户？ 答：不是重播。他出现在某人的采访中
373 O5TVGUO1 周乐-十字架 广播频道。 问：那是哪次采访？ 答：该频道名为 Mirror Media。 问：好吧。在视频中，他表达了一些批评 中国共产党，公平吗？ 答：是的。 问：好吧。然后在你参与之后 运动，该运动还播出了广播 批评中国共产党，对吧？ 答：是的。 问：实际上，那是 GTV 的目标，就是能够 广播那种—— MURRAY 女士：反对。 法院：驳回。你可以表达你的 对GTV目标的理解。 KAMARAJU 先生：法官大人，我会这样说的。 法庭：好吧。 问：据你了解 GTV 的目标是 能够将批评中共的消息广播给 中国人；对吗？ 答：是的。 问：现在，该运动中有一些人出现在 广播；对吗？ 答：是的。 问：还有一些人确实为该运动工作过
374 O5TVGUO1 周乐-十字架 谁没有出现在广播中；对吗？ 答：是的。 问：那你有没有出现在广播中？ 答：我只是通过配音出现，没有像身体那样出现，比如 出场。 问：所以你只用了声音，没有露脸；是 对吗？ 答：正确。 问：你为什么不露脸？ 答：因为我想保留它只是不要 —— 我只是决定不这样做 露出我的脸。 问：有什么原因吗？ 答：好吧，所以我不想 — MURRAY 女士：反对。 法院：驳回。你可以回答。 答：是的。因为我也不想成为中共的目标。 问：对不起。你有没有说过你不想成为攻击目标 中共；对吗？ 答：正确。 问：好吧。谢谢。 现在，你还直接作证说了这样一个事实 农场成员使用了 Discord，对吧？ 答：是的。 问：你对他们为什么改用 Discord 的理解如何 例如，你知道短信吗？
375 O5TVGUO1 周乐-十字架 答：我不知道的原因。 问：而且你还直接就 WebEx 作证，对吧？ 答：是的。 问：你了解他们为什么选择 WebEx 吗？ 答：我知道这部分原因。 问：不管你知道什么，先生。 答：这是因为 WebEx 有一项允许超过 100 名参与者的功能 同时上线。 问：你在有 100 多名参与者的 WebEXES 上吗？ 答：是的。 问：好吧。那么这些是运动成员的大型集会吗？ 答：是的。 问：郭先生是否参与其中？ 答：是的。 问：好吧。如果出现以下情况，所有在那个 WebEx 上的人都可以说话 他们想要，对吧？ 答：不是。 问：不是？ 答：不是。 问：为什么？ 答：因为是一些人静音了；只有一个 允许扬声器发言。 问：好吧。所以必须有人认出说话者， 对吧？ 答：是的。
376 O5TVGUO1 周乐-十字架 问：好吧。现在，你还使用了 Discord 的名字。我相信是 Coffee Cantana，我有这个权利吗？ A. 咖啡大合唱。 Q. 康塔塔。好吧。谢谢你，先生。 你选这个名字有什么原因吗？ 答：是的。 问：那是什么？ 答：我个人喜欢喝咖啡。我玩的是经典游戏 音乐。康塔塔是经典音乐中的一首。 问：所以这与你的兴趣有关，对吧？ 答：正确。 问：好吧。然后你与其他运动成员进行了互动 我们也使用了 Discord 的名字，对吧？ 答：正确。 问：即使是一些出现在广播中的人也使用过，我也会 比如说，化名，对吧？ 答：对不起？ 问：他们使用的名字与真实姓名不同，对吧， 一些出现在广播中的人？ 答：正确。 问：比如花木兰，对吧？ 答：正确。 问：那不是 —— 你认识一个叫章鱼的人吗？ 答：是的。 问：好吧。那也不是八爪鱼的真名，对吧？
377 O5TVGUO1 周乐-十字架 答：不是。 问：章鱼曾经出现在广播中吗？ 答：我不记得了。 问：好吧。星云怎么样？ 答：是的。 问：你认识一个叫 “星云” 的人吗？ 答：是的。 问：好吧。那也不是那个人的真名吗？ 答：正确。 问：那个人出现在广播中了吗？ 答：我不记得了。 问：你知道他们为什么使用吗 不同的名字？ MURRAY 女士：反对，法官大人。 法院：持续。 问：现在，除了做一些视频直播工作外 你说过的，对，你还开了银行账户 代表农场，对吧？ 答：正确。 问：所以你受托从别人那里收钱 农场成员，对吧？ 答：我不知道其他农场成员怎么了。 问：好吧。让我这样说吧：你受托负责 英国农场收到的钱，对吧？ 答：我无法委托那种委托，因为那是别人的事情
378 O5TVGUO1 周乐-十字架 得说他们是否委托我，但我没有收到 的类型—— 问：好吧。你被赋予了对银行账户的权限 里面有钱，对吧？ 答：根据授权，对不起？ 问：你被赋予了对银行账户的权限 收到了钱，对吧？ 答：我被指示开设账户。 问：好吧。账号上有你的名字吗，先生？ 答：我曾经是签名者的账户。 问：好吧。 KAMARAJU 先生：我们能不能只为派对表演， 请出庭和证人 DX 60476 问：在撤回的时候，有多少不同的银行 你开户了吗，先生？ 答：三。 问题：三。那些都是同一个名字吗？ 答：不是。 问：他们用不同的公司名字，对吧？ 答：正确。 问：还有一些你创办的公司，对吧？ 答：不，我没有开公司。 问：你没有创办任何公司吗？ 答：那不是我的公司。 问：嗯，没关系。我只是想问你是否 —— 写了你的名字
379 O5TVGUO1 周乐-十字架 出现在其中一家公司的任何成立文件上， 先生？ 答：是的。 问：好吧。当你开设这些账户时，我想你 直接作证说你告诉银行他们是为了 你的房地产业务，对吧？ 答：我被指示告诉他们。 问：好吧。但这就是你告诉他们的，对吧？ 答：是的。 问：然后你告诉了他们，对吧？ 答：是的。 问：好吧。但事实并非如此，对吧？ 答：正确。 问：因为实际上，你收到的钱是从—— 那是农场接纳的，对吧？ 答：我会说不要说农场，因为所有的电线都通向我 没告诉我哪个是农场哪个农场还是个人 该人的关系。我知道 —— 我知道追随者是农场 想投资 G 系列。 问：是的。对不起，先生，我不是在问钱在哪里 来自。我说这是英国农场的钱 正在收到，对吧？ 答：是的。 问：这笔钱不会流向你的房地产业务，对吧？ 答：不是。
380 O5TVGUO1 周乐-十字架 问：好吧。所以你错误地陈述了账户的性质 银行，对吧？ 答：是的。 问：好吧。而你之所以这样做，是因为你想帮助 运动，对吧？ 答：帮助关注者。 问：对。帮助追随者，对吧？ 答：是的。 问：还要帮助英国的农场，对吧？ 答：只要帮助关注者即可。 问：对不起，先生，也许我不明白。你能不能 解释一下你在那里画的区别。 答：是的。我的意图是帮助农场，因为英国伦敦的农场 领导告诉我 —— 请我帮忙帮助追随者， 但没有具体说明关注者是否全部来自英国伦敦 俱乐部或其他农场。 问：好吧。那么你会说有多少钱存入银行 你开的账户？ 答：大约200万美元。 问：大约 200 万美元。 你还记得大概有多少收件人吗 它来自哪里？或者，抱歉，已撤回。 你还记得大概有多少发件人吗 是从？ 答：大约 50 个。
381 O5TVGUO1 周乐-十字架 问：大约 50 个，先生？对不起，你是这么说的吗？ 答：正确。 问：好吧。我觉得 DX 60476 现在出现在你的屏幕上。 你能不能看看这个。 答：是的。 KAMARAJU 先生：好吧。也许我们可以滚动到下一页 页面。 问：先生，你认出这份文件吗？ 答：是的。 问：好吧。上面有你的签名吗？ 答：是的。 问：你签名旁边的日期是什么时候？ 答：2021 年 2 月 24 日。 问：好吧。那这份文件是什么，先生？ 答：哦，是的。这是 —— 佛罗里达州、佛罗里达州的业务 状态。我认为这是认证。 问：认证。好吧。 KAMARAJU 先生：让我们转到第 2 页。抱歉，第 2 页。 问：你认识这个吗？ 答：是的。 问：这是什么？ 答：这是国税局关于EIN号码的。 问：你看到第一张中列出的公司名称了吗 句子，先生？ 答：是的。
382 O5TVGUO1 周乐-十字架 问：好吧。那是你以前开的公司之一吗 英国农场的银行账户？ 答：这个名字是由英国农场创建的，我曾经开过 账户。 KAMARAJU 先生：法官大人，政府 —— 我做到了 再次。辩方将提供DX 60476作为证据。 MURRAY 女士：没人反对。 法院：可以接受。 （作为证据收到的被告附录 60476） KAMARAJU 先生：谢谢。我们可以发布到 陪审团？我保证我不会做三次。 问：所以这是其中一个的组建文件 公司；对吗？ 答：是的。 KAMARAJU 先生：我们能不能转到下一页。 请稍后再写一页。谢谢。然后炸掉就行了 签名线。 问：先生，你明白上面写着 “注册人” 了吗？ 答：是的。 问：那是谁的签名？ 答：我的。 问：所以你在 2021 年 2 月 24 日创办了这家公司，对吧？ 答：我自己注册了，但是导演还在名单上 作为英国领导人。 问：好吧。我只是 —— 你在这一天注册了，对吧？
383 O5TVGUO1 周乐-十字架 答：是的。 问：好吧。所以你首先开始开设银行账户 2021 年收到英国农场的钱，对吧？ 答：正确。 问：现在，作为收款工作的一部分，你是否也是 说明这笔钱是怎么花的？ 答：我记录了，是的。 问：所以你看了银行对账单看看钱在哪里 要去吗？ 答：这笔钱只是被指示汇出去的。 问：对不起，你能再说一遍吗？ 答：所有的钱都被指示汇出。 问：所有的钱都被指示汇出。 答：正确。 问：对。所以你从来没有收到任何电汇指示 钱给郭先生，对吧？ 答：对他不是。 问：好吧。现在，我们聊了聊志愿者工作 你为农场做的。更广泛地说，农场确实做了志愿者 也能工作，对吧？ 答：是的。 问：乌克兰有一个项目；对吗？ 答：那是一个喜马拉雅农场全球联盟，而不仅仅是一个农场。 问：好吧。那么几个农场齐心协力？ 答：所有农场都参与了。
384 O5TVGUO1 周乐-十字架 问：好吧。那他们在干什么？ 答：有乌克兰。 MURRAY 女士：反对，法官大人。相关性。 法院：驳回。你可以回答。 答：这是乌克兰，人道主义任务。他们被叫了 到波兰和乌克兰的边界。使命 是为了营救中国公民和做其他的人道主义活动 作品。 法庭：从哪里救他们？ 目击者：在波兰的边界和波兰之间 乌克兰。 问：好吧。谢谢。 现在，你直接作证说你开始担心了 关于一些已经到来的钱是怎么花的 存入那些银行账户；对吗？ 答：与这些账户无关。 问：所以你从来没有担心过这些账户；是吗 对吧？ 答：郭文贵之间有过会议，非公开会议 和英国伦敦俱乐部。刚才提到了一些东西 英国伦敦俱乐部的财务状况、状态和省份。有—— 不当使用的资金已得到解决。 问：好吧。谁在滥用资金？ 答：会议时，英国伦敦领导人戴维·戴 俱乐部，被指控滥用全球捐款，全球基金会
385 O5TVGUO1 周乐-十字架 资金。 问：因此，他被指控退出了。 戴维被指控滥用法治 这次会议的基金会资金？ 答：在那次会议上，是的。 问：好吧。但是那次会议是英国农场的会议？ 答：是的。 问：因此，他们正在讨论滥用基金会资金的问题 农场会议，对吧？ MURRAY 女士：反对。401、403。 法院：你可以回答。 答：是的，会议上提到了这一点。 问：好吧。现在，我想你刚才说郭先生是其中的一员 会议，对吧？ 答：是的。 问：所以他参与了关于这些指控的讨论， 对吧？ 答：是的。他在那里。 问：好吧。而这个话题是 —— 或者至少是其中一个话题 这些是指控，对吧？ 答：是的。 问：所以你听过郭先生讨论这些指控，对吧？ 答：是的。 问：好吧。于是决定调查这些指控， 对，弄清楚它们是不是真的？
386 O5TVGUO1 周乐-十字架 答：我不知道问题是否得到了解决。 问：这是在会议上决定的，先生？ 答：还没决定；刚刚出来了， 指控。 问：好吧。有人决定该怎么做吗 那次会议上的指控？ 答：在一次会议上，郭迈尔斯甚至问了《规则》中的一个人 法律基金会。据我所知，这个人一直在追踪 资金，郭迈尔斯亲自向那个人询问大卫的情况 戴的指控。 问：好吧。于是郭先生向那个人询问了这些指控， 对吧？ 答：是的。 问：指控是英国的大卫——那是戴维·戴， 对吧？ 答：是的。 问：— 在滥用资金；对吗？ 答：是的。 问：对英国大卫还有其他指控吗 挪用资金？ 答：是的。 问：这种情况发生了多少次？ MURRAY 女士：反对。 法院：你可以加紧努力。 （下一页继续）
387 O5TVGUO1 周乐-十字架 （在侧边栏上） MURRAY 女士：法官大人，首先，这是 他想引起的传闻。此外， 有人指控滥用资金 介绍并提出要说出真相，因为事实是 实际上是滥用资金和这个 403 问题。 KAMARAJU 先生：嗯，首先，任何介绍 被告的庭外陈述不是自动的 传闻。我们只是在听取他的证词以表明何时 有人指控，有人认真对待 接受了调查，包括郭先生。所以你至少必须 证实指控是提出的。不管他们是 对与否，我们不知道；我们不是在要求证人 就它们是否属实发表意见。我们只是说他们想要 去调查一下。 MURRAY 女士：法官大人，我不明白他们怎么不是 在这里被告知他们的真相。 法庭：他们是被告知真相的。 KAMARAJU 先生：但我甚至没问他是否 法官大人，指控是真的 法庭：你想用这些指控来提出 认为郭先生有正当权益的论点 为这项事业筹集资金。 KAMARAJU 先生：是的。因此，唯一相关的事实 有人提出了指控，而不是是否
388 O5TVGUO1 周乐-十字架 指控是否属实，这就是我想引起的全部。 到目前为止，这就是我所说的全部。 SHROFF 女士：事实上，Kamaraju 先生可能会问：你 不知道这些指控是对还是错。我们不是 试图向他们介绍他们的真实性。 MURRAY 女士：他已经证实了这样一个事实 有人指控。因此，额外的提问路线 导致 “还有其他指控，不是吗” 再次试图表明和暗示事实的真相 有人指控滥用资金。我没看见 它有任何其他的用途而且过分了 偏见。 KAMARAJU 先生：不管怎么样，目的都是一样的 我多次问关于指控的问题。 MURRAY 女士：对。现在已经有证据了。 法院：因此，看来有两个目的， 既是为了指控的事实，也是为了指控的真相 指控，因为你想把郭先生描绘成警卫 这些资金用于他的政治事业。 KAMARAJU 先生：但第二天我不这么认为 观点要求指控是对还是错。 如果美国检察官办公室调查某人 并回应受害者的投诉，这不是声明 受害者的投诉是真的还是虚假的；只是 美国检察官办公室抓走受害者的证据
389 O5TVGUO1 周乐-十字架 认真投诉。你不必知道真相 受害者投诉以证实他们接受了申诉 认真地。 MURRAY 女士：我想归根结底，法官大人， Kamaraju 先生说他想说的是这样一个事实 有人指控。已经有了。所以没有 额外的提问线索将富有成效，除非 会有不当之处。 KAMARAJU 先生：不，因为我们可以指出 事实是，它发生过不止一次。顺便说一句 他们认真对待了。 SHROFF 女士：而且每次指控都是这样 解决的，不是指控是对还是错。你 可以自由地在重定向时得出这些指控是在 事实，错误。当然，这是你的特权。但确实如此 不要将对Kamaraju先生的讯问视为不当或不当的讯问 偏见。实际上，这就是你指挥的重点。 你直击的全部目的是证明郭先生做到了 没什么。所以我们有权直接证明你的所作所为 是不恰当的。 MURRAY 女士：法官大人，再说一遍，这是传闻。他们 正在关注郭先生的所作所为和郭先生所说的话。这里 他们在问这名证人有多严重 指控是否被采纳。我想我们已经确定了这一点 目击者说他不知道做出了什么决定或者是否
390 O5TVGUO1 周乐-十字架 有一项决定是否采取某些行动。 法庭：所以你可以问一下有没有有 其他指控，但仅此而已。 KAMARAJU 先生：好的，法官大人。 （下一页继续）
391 O5TVGUO1 周乐-十字架 （在公开法庭上） 作者：KAMARAJU 先生： 问：英国农场曾经解散了； 正确？ 答：正确。 问：为什么？ 答：因为当时有喜马拉雅全球联盟 开始做统计工作来收集所有农场的 财务资产负债表，同时还要有所有 农场将每个农场持有的所有余额汇到喜马拉雅山脉 全球联盟。而当时是因为指控使之成为现实 David Dai，而且他还有一些没有线路的平衡，真是太棒了 郭迈尔斯要求他的大量余额也为他提供了 电汇截止日期。他失败了。 问：那是什么 —— 我想你把它说成是未接线 平衡。那是什么？ 答：因为农场有一些资金。该基金必不可少 移交给喜马拉雅全球联盟，指定 账户。还有其他几次会议，还有 —— 郭文豪 给了戴维·戴最后期限来结清余额，但他失败了 去做。因此，这种影响会解散整个农场，而且 郭迈尔斯还剥夺了头衔然后他被解雇了 这个 —— 对不起，没有被解雇，他被带出了农场而且 来自运动。 问：有没有给出他被农场解雇的理由？
392 O5TVGUO1 周乐-十字架 还有运动？ 答：我不知道。 问：那么你对这些原因一无所知吗？ 答：我当时在开会。 问：现在，我想谈一谈退款的问题 你要求的，好吗？ 答：当然。 问：你要求G Fashion退款，对吧？ 答：是的。 问：好吧。而且你要求G Clubs退款，对吧？ 答：正确。 问：现在，当你向 G Clubs 申请退款时，你去了吗 去公司要求退款？ 答：是的，我确实给他们发了电子邮件。 问：好吧。所以你给G Clubs发了电子邮件要求退款？ 答：是的。 问：你得到回复了吗？ 答：只收到了我的电子邮件，只是确认了他们 收到了我的请求。之后，没有更多的回应。 问：而且那个答复已经撤回了。 我想你已经作证了，那个退款申请已经提出了， 在 2023 年 7 月，对吧？ 答：我记不起日期了。 问：你不记得今天早些时候作证说是这样 2023 年 7 月？
393 O5TVGUO1 周乐-十字架 答：我的意思是 2023 年 7 月 15 日的全部退款是 开始，发起于华盛顿特区的农场。 问：哦，对不起。我误解了。7 月 15 日的日期是 你向农场申请了退款？ 答：是的。 问：你大约在去农场前多久了 提交 G 俱乐部申请？ 答：我记不起来了。 问：嗯，不是问具体日期，而是问几个月、几年， 几周？ 答：几个月。 问：几个月。好吧。 而且是在你购买了几个月之后 最初是 G|CLUBS 会员，对吧？ 答：是的。 问：你为什么要去农场从 G Clubs 那里获得退款？ 答：因为郭文贵指示了任何追随者，所以出现任何问题， 问题将首先联系农场领导，当时我 与华盛顿特区的农场有关。因此，按照指示， 我就是这么做的。 问：但是你先去了 G 俱乐部，对吧？ 答：不，我不记得是不是先去G|CLUBS了。 问：先生，我还以为你刚才作证说你 去了 —— 在提交农场申请前几个月 — MURRAY 女士：反对，法官大人。
394 O5TVGUO1 周乐-十字架 错误地描述了证词。 法院：持续。 问：好吧。那你还记得吗？你是先去 G 俱乐部还是 先是农场？ 答：我不记得了 — MURRAY 女士：反对，问了又回答。 法院：持续。 问：好吧。对不起，先生。你说你去了农场 因为郭先生说你应该先去那里，对吧？ 答：不是第一个。你有任何问题，我们会去农场 领导者。 问：那你认为农场负责人能做什么 你对 G Clubs 有何看法？ 答：郭文贵提到了农场领袖的角色。仅限领导角色 为追随者服务。没有阶级或下属阶级。每个 追随者和领导者是平等的。 问：好吧。我只是问你觉得农场怎么想 在 G Clubs 方面能为你做点什么吗？ 答：因为这是一条规则，你与哪个农场有关联。 而且你只能与一个农场关联。所以当时我是 还有华盛顿特区的农场那是我唯一能去的农场。 问：我明白，先生，你去华盛顿农场是因为 那是 —— 那是你的农场，对吧？ 答：当时，是的。 问：好吧。我只是明白 —— 我只是想知道
395 O5TVGUO1 周乐-十字架 明白你为什么认为农场能帮你做 G 俱乐部有问题？ 答：因为那是 —— 郭文贵说了什么，如果是的话 与运动有关，G系列，我们可以去找领导人 农场。 问：好吧。那农场领袖应该怎么做，先生？ 答：为我的请求提供帮助。 问：好吧。你指望农场还钱吗 你说你在 G Clubs 上花过钱？ 答：我没想到。 问：你期望得到什么样的帮助？ 答：我希望能让农场领袖先承认 那也是为了满足我的要求。然后第二个是我就是 —— 走了 等着答案，但我没想到会发生什么 下一步。但是我的最终目标是获得退款。 （下一页继续）
396 O5T1GUO2 周乐-十字架 作者：KAMARAJU 先生： 问：好吧。而且你最终获得了退款；对吗？ 答：是的，我收到了 G/CLUBS 的退款。 问：好吧。在获得G/CLUBS退款之前，他们退款了 要求你退回一些设备，对吧？ 答：正确。 问：那是什么设备？ 答：那是流媒体设备。 问：好吧。那你为什么有那个装备？ 答：因为华盛顿特区农场把它寄给了我 直播，用于农场直播，用于农场 直播；此外，抗议期间使用了这些设备 直播，供喜马拉雅全球联盟使用。 问：好吧。所以它被用来广播农场生意， 基本上？ 答：还有喜马拉雅全球联盟。 问：这是昂贵的设备吗？ 答：据我所知，是的。 问：你把设备寄回去了吗，先生？ 答：是的。 问：你把它寄给了谁？ 答：我把它寄到了华盛顿特区农场。他们提供了 地址。 问：好吧。你知道他们做了什么吗 你退回后就用这个了？
397 O5T1GUO2 周乐-十字架 答：我退回后，他们让一个人检查了它，而且 然后仔细检查了所有东西后我有一个 确认，商品已收到，已检查。 问：好吧。之后你收到了退款；是 对吗？ 答：正确。 问：好吧。大概过了多久你才拿到自己的 退款？ 答：我在 2023 年 12 月 1 日收到了退款。 问：那检查是什么时候？ 答：那是在十月左右。 问：2023 年？ A. 2023 年。 问：好吧。谢谢你，先生。 KAMARAJU 先生：如果我能稍等片刻，你的 荣誉。 问：现在，先生，你直接就抗议活动作证，对吧？ 答：是的。 问：而且你作证说你在抗议活动中扮演的角色是 帮忙直播它们，对吗？ 答：是的。 问：你直播了多少抗议活动？ 答：亲自直播，大约有几十个。 问：几十个？ 答：是的，亲自直播。
398 O5T1GUO2 周乐-十字架 问：好吧。是的，我只是在说那些你说的 直播。 答：是的。 问：好吧。现在我相信是你直接作证的那些 我们和一个名叫卢克·德斯平斯的人有关系；对吗？ 答：正确。 问：好吧。而且他是破产受托人，对吗？ 答：正确。 问：我们都是你亲自参与的直播 反对——对不起。已撤回。 所有直播都是你个人的吗 参与了涉及破产受托人的抗议活动？ 答：不是所有的直播。 问：好吧。所以有些不是，对吧？ 答：正确。 问：其他那些是关于什么的？ 答：其他关于抗议国会山的消息。 问：好吧。你在国会山抗议？抗议活动 发生在国会山，你说的那个？ 答：是的。 问：他们在抗议什么？ MURRAY 女士：反对。缺乏个人知识。 法庭：如果他观察了直播，他可能会知道 他们在抗议什么。 如果你知道的话
399 O5T1GUO2 周乐-十字架 证人：是的，法官大人。 答：是的。在国会山是——对郭迈尔斯也是抗议活动。 问：好吧。但是他们在抗议什么，先生？ 答：这是反对对郭文亮的迫害。有 抗议，对郭文辉的不公平司法。 问：这次抗议活动是什么时候？ 答：这是在2022年11月——持续了大约一个月。 问：对不起。你说持续了大约一个月，先生？ 答：正确。 问：他们是哪一群特定的人 抗议？ 答：是的。 问：那是谁？ 答：主要是来自华盛顿特区农场的追随者。 问：好吧。所以这些人大多是 参加抗议活动，对吧？ 答：是的。 问：好吧。抗议活动是针对任何特定的群体吗 人们？ 答：国会大厦的目标不是任何特定的人，不是。 问：好吧。它针对的是任何特定的政府机构吗？ MURRAY 女士：反对。403。 法庭：我允许这个问题。 证人：是的，法官大人。 答：第一个是中国共产党，还有那里
400 O5T1GUO2 周乐-十字架 Were——抗议期间提到了美国大法官。 问：好吧。而当你说中国共产党时， 抗议活动是针对中共的，对吧？ 答：是的。 问：而且你直接作证说抗议活动 破产受托人参与了——我把它写下来了但我可能有 错了所以请纠正我—— CCP 跑狗，对吧？ 答：我就是这样——是的。 问：好吧。国会大厦期间使用过任何类似的语言吗 希尔抗议？ 答：他参加了一场名为 “卢克90天抗议活动” 的抗议活动 德斯平斯不在国会大厦。 问：我明白。我在问国会山的抗议活动。 答：国会山没有提及他的名字。 问：好吧。你在国会山抗议活动中听见有人说话了吗 谈论中共的间谍？ 答：是的。 问：好吧。你听说过郭先生称人们为中共间谍吗 之前？ 答：是的，他确实提过。 问：你听说过其他运动成员将人们称为 中共间谍？ 答：我从未参与过其他——其他运动。 问：对不起，先生。我说的是其他 NFSC 运动 成员们称人们为中共间谍。
401 O5T1GUO2 周乐-十字架 答：是的。 问：你对这句话有什么理解？ 答：只是中共的间谍，对那些人来说只是个名字——收购到中共的间谍 人们。 问：那么它对你来说没有任何特别的意义吗？ 答：只是中共的间谍。 问：好吧。当你听到这个的时候，你一点都没有 不管怎样证明这些人是否是 其实是中共的间谍，对吧？ MURRAY 女士：反对，法官大人。 法院：你可以回答。 答：我不知道。 问：对不起。你说不是，对吧？ 答：我不知道。 问：好吧。而且你当时是直接作证的 破产受托人的抗议，你没有任何抗议 关于受托人是否在研究的证据 代表中共，对吧？ 答：我不知道。 问：你只是不知道一种或另一种方式，对吧？ 答：当时我相信了，但我没有证据 证明一下。 问：好吧。而且因为你相信了，所以你参与了 那些抗议活动，对吧？ 答：是的。
402 O5T1GUO2 周乐-十字架 问：你直播了他们，对吧？ 答：是的。 问：你想把消息说出来，对吧？ 答：是的。 问：你想让其他人听到发生了什么，对吧？ 答：是的。 问：因为你认为发生了不公正现象，对吧？ 答：当时我相信了。 KAMARAJU 先生：好吧。法官大人，此时 辩方想阅读和输入证据 双方之间的规定。 法庭：来吧。 KAMARAJU 先生：这是 DX Stip 0001。上面写着： “这是美国特此规定和同意的 美利坚合众国和被告郭迈尔斯通过其 记录在案的律师，即： “1。联邦调查局调查了那些在工作的人 在中华人民共和国政府的指导下 中国（“中华人民共和国政府”）参与了国际活动 名为 “猎狐行动” 的运动，旨在胁迫个人 位于美国和其他地方以返回中国 面对中华人民共和国政府或其他方面的指控 与中华人民共和国政府达成财务和解。 “2。2017年，一家美国执法机构进行了评估 郭文贵先生是中国的重中之重
403 O5T1GUO2 周乐-十字架 遣返工作。 “3。2017年，美国执法机构收到了 中国官员支付和提供的信息 食物和标语给郭先生的抗议者。 “4。2018 年，美国执法机构收到了 有关中华人民共和国政府已设立特别机构的信息 中国调查小组负责管理中国的调查 对郭先生采取行动和对他采取行动。 “5。为了实现 Fox Hunt 的某些目标， 2017年，中华人民共和国政府委派了一个特别指定的小组 诽谤和骚扰的特工（“团体”） 包括郭先生在内的个人使用交互式电脑 服务和电子通信系统。该小组是 总部设在北京市公安局 位于北京东城区的工厂。该小组是 以前被称为 “网络调查小组”，以及 后来被称为 9112 特别项目施工 小组。该集团针对郭先生的策略包括使用 由本集团运营的匿名社交媒体账户，以及 向美国社交媒体公司施压，要求其罢免郭先生和 来自社交媒体平台的郭先生在美国的同事。 这些努力是中华人民共和国政府更广泛努力的一部分 防止、破坏和骚扰郭先生对社交媒体的使用 和其他在线平台进行传播和讨论 不受欢迎的内容。在 2018 年 12 月左右，官员们
404 O5T1GUO2 周乐-十字架 小组被指示每天发布三个视频或帖子 YouTube 和 Facebook 账户，其中一个帖子是必填的 要反磁共振Guo。2020 年 2 月 3 日，中国政府 官员发布了一项任务要求，要求其中的每位成员 小组应撰写一篇原创文章，其内容与以下内容有关 针对的是郭先生、COVID大流行或香港。联邦调查局 调查了专家组的活动，包括其活动 针对郭先生，美国政府已经指控了许多 违反美国法律的团体成员。 “6。自从郭先生逃离中国以来，中华人民共和国政府 已要求将他送回中国接受起诉，并且 使用了多种方法逮捕郭先生或 逮捕。2017年5月，中国政府派出了四份未申报的物品 中华人民共和国国家安全部（“MSS”）的特工到 美国企图对郭先生进行胁迫 作为猎狐计划的一部分，遣返中华人民共和国。 美国政府干扰了中华人民共和国政府的努力 强行遣返郭先生郭先生继续居住 在美国。 “7。在 2017 年 5 月至 2018 年 1 月之间，至少有四个 个人，包括乔治·希金博瑟姆、艾略特·布罗迪， Nickie Lum Davis 和 Prakazrel Michel 从未透露过这一点 他们实际上是在代表外国行为者行事， 包括中国政府，游说特朗普的官员 政府企图将郭先生引渡到
405 O5T1GUO2 Le Zhou-重定向 中国。希金博瑟姆、布罗迪、戴维斯和米歇尔各是 因在游说活动方面违反美国法律而被定罪。 这些人的努力没有成功，而且 郭先生从未应中华人民共和国的要求被引渡 政府。相反，从大约 2015 年起，郭先生就有 得以与家人一起在美国居住。 “8。2018 年 10 月 23 日，香港一家法院进入 一项没收和限制郭先生在香港资产的命令 以及法院管辖范围内的其他地方。 “进一步规定并商定，这是 该规定可以作为证据。” 法官大人，我会提供 DX Stip 0001。 法院：可以接受。 （作为证据收到的被告的证据 Stip 0001） KAMARAJU 先生：谢谢你，法官大人。 作者：KAMARAJU 先生： 问：所以只有一个问题，先生。在听我读那篇文章之前 信息出来了，你以前听说过吗？ 答：是的，我听说郭文贵提过了，其中一些。 问：你听到他提了什么？ MURRAY 女士：反对。传闻。 法院：持续。 问：好吧。除了 Miles Guo 的陈述之外，你还听到了吗 还有别的地方？ MURRAY 女士：反对。
406 O5T1GUO2 Le Zhou-重定向 法庭：事实是，听过这件事，他可以 回答。那是因为你无法说出你所听到的。 答：刚刚来自郭文豪。 KAMARAJU 先生：现在没有其他问题了，你的 荣誉。 法院：重定向？ MURRAY 女士：是的，法官大人。谢谢。 重定向考试 作者：默里女士： 问：周先生，有人问你关于盘问的问题 关于喜马拉雅全球联盟的等级制度。你呢 还记得那些问题吗？ 答：是的。 问：谁任命了农场领导？ 答：农场领导，一开始只能由Miles任命 Guo，但后来，曾经是喜马拉雅全球联盟农场， 特别是 Iron 组、Iron Blood 集团的农场，会是 共同——共同任命领导人。 问：谁任命了铁血组的成员？ 答：郭文豪。 问：谁是农场的最高领导者？ KAMARAJU 先生：反对。 法院：驳回。你可以回答。 答：好吧，郭文豪。 问：谁是喜马拉雅山的终极最高领袖
407 O5T1GUO2 Le Zhou-重定向 全球联盟？ 答：郭文豪。 问：昨天有人问你关于盘问的问题， 今天再次谈谈G系列投资的目的。做 你还记得那些吗？ 答：是的。 问：你对GTV是一家社交媒体公司的理解是 基于谁的陈述？ 答：基于 Miles Guo 的陈述。 问：你理解 G/CLUBS 是一项会员服务 是根据谁的陈述的？ 答：Miles Guo 的声明。 问：你认为喜马拉雅交易所是 加密货币平台是基于谁的陈述？ 答：Miles Guo 的声明。 问：谁宣布了G系列投资？ 答：对不起？ 问：谁宣布了G系列投资？ 答：郭文豪。 问：谁推广了 G 系列产品？ 答：郭文豪。 问：你还被问到关于 GTV 如何私密的问题 将使用配售资金。你还记得那些吗？ 答：是的。 问：郭有没有说过要向 GTV 投资人汇款
408 O5T1GUO2 Le Zhou-重定向 对冲基金？ 答：不是。我不记得了——我记不起来了。 问：你还被问到关于自己投资GTV的问题 通过 Voice of Guo 或 VOG。你还记得吗？ 答：是的。 问：谁认出 Sara Wei 是 GTV 的联系人 投资低于十万美元？ 答：郭文豪。 问：有人问你一些关于你的期望的问题 收到以换取您的 G/CLUBS 会员费。你呢 还记得那些问题吗？ 答：是的。 问：你有没有用7万美元收到过NFSC护照 G/俱乐部付款？ 答：不是。 问：你有没有用 70,000 美元收到任何 G/CLUBS 股票 G/俱乐部付款？ KAMARAJU 先生：反对，法官大人。 法院：你可以回答。 答：不是。 问：你有没有用 70,000 美元收到任何 G Fashion 股票 G/俱乐部付款？ KAMARAJU 先生：同样的反对意见。 法院：你可以回答。 答：不是。
409 O5T1GUO2 Le Zhou-重定向 问：除了 G Fashion 商品的折扣外，你还收到过折扣吗 您的 70,000 美元 G/CLUBS 付款有何好处？ 答：我不会说福利，但我收到了小纪念品 物品、马克杯和一袋咖啡。 问：一个马克杯和一袋咖啡；对吗？ 答：是的。 问：您是否曾经通过31,300美元的投资获得GTV股票 通过 Voice of Guo 在 GTV 上线？ 答：不是。 问：如果你知道你会向 G/CLUBS 汇款吗 不会买到任何股票？ 答：不是。 问：如果你认识你，你会向英国农场贷款吗 不会买到任何股票？ 答：不是。 问：您选择投资基于 G 系列的产品 关于谁的陈述？ 答：你能重复一下这个问题吗，女士。 问：当然。您选择了投资 G 系列产品 根据谁关于这些产品的陈述？ 答：Miles Guo's。 问：那你在G系列的投资中损失了多少钱？ 答：就像钱一样，因为我——涉及硬币，我——甚至 直到今天，我还没有收到全额退款，但是 硬币，当时，用于 —— 如果我当时要求的话，价值
410 O5T1GUO2 Le Zhou-Recross 据我估计，这些硬币的价值仍在增加 10 美元。因此，对于这个价值，也是 —— 我会考虑的，所以 还有额外的价值，但以美元计，来自投资， 主要部分，我还没有收到将近 30,000 美元。 问：当你参加 G 系列的时候 供品，根据你的理解，郭文贵个人是 保证您不会损失任何本金；是 那对吗？ 答：没错。 MURRAY 女士：法官大人，请允许我稍等片刻。 法院：是的。 MURRAY 女士：没什么好说的，法官大人。 法庭：改过自新？ KAMARAJU 先生：简而言之，法官大人。 再交叉检查 作者：KAMARAJU 先生： 问：有人问你一系列关于谁是的问题 领导者——农场的终极领袖，对吗？ 答：是的。 问：而且你作证说是郭迈尔斯，对吧？ 答：正确。 问：好吧。与你收取的钱有关 银行账户，你有没有收到过来自的一条指令 郭文豪？ 答：不是直接从他那里发来的，不是。
411 O5T1GUO2 Le Zhou-Recross 问：郭先生从来没有联系过你说过用 X 钱，对吧？ 答：他做到了。 问：郭先生直接联系你说把钱寄出去 这里？ 答：不是。在与英国农场举行的一次会议上， 在会议中，郭文贵要求的不仅仅是戴大卫 退还所有的钱，他要求所有来自英国伦敦的会员 直接或间接地从粉丝那里获得资金的俱乐部， 在截止日期之前，将采取同样的措施汇出所有剩余的电汇 余额存入这些账户。 问：好吧。然后他给了所有人这个方向，对吧？ 答：是的。 问：现在你在重定向时作证说你损失了3万美元， 正确？ 答：是的。 问：好吧。这是基于什么的？ 答：校长。 问：但是校长是什么，先生？ 答：校长来自 —— 有一部分来自 VOG 投资。 问：好吧。 答：我购买的硬币中有一部分。那里 是来自农场借款项目的部分资金。 问：有多少钱来自农业贷款？
412 O5T1GUO2 Le Zhou-Recross 答：我投资了21,000美元购买了农场贷款。 问：好吧。因此，在你损失的3万美元中，你说的21,000美元是 来自农场贷款，对吧？ 答：其中的一部分。 问：对不起。我不明白。 答：是——你问了3万美元，校长。21,000 至 农场借款项目，那是本金。VOG 的投资方向 GTV，也投资了 31,000 美元和 300 美元，但我确实如此 从公平资金中获得报销。我明白了——有 大约 7% 的损失。然后加起来，估计就是 大约 30,000 美元。 问：现在你的农场借款项目本金本应在那里退还 贷款期限的结束，对吧？ 答：合同规定，是的。 问：好吧。贷款期限于8月延长 2023 年，对吗？ 答：它是在未经我同意的情况下被强制延长的。 问：但是他们不需要你的同意，对吧？他们有 根据合同这样做的权利，对吧？ 答：我不记得他们这样做是否是他们的权利。 问：所以你不记得一种或另一种方式。 答：我收到的通知纯粹是为了延期 24 数小时——数月，没有任何选择退出的选项。 问：好吧。那么距离 2023 年 8 月还有 24 个月，对吧？ 答：是的。
413 O5T1GUO2 Le Zhou-Recross 问：好吧。因此，您的农场借款项目实际上并未偿还 直到明年，对吧？ MURRAY 女士：反对，法官大人。范围。 法院：持续。 KAMARAJU 先生：法官大人，我们能不能开个侧边栏 这么快。 法院：是的。 （下一页继续）
414 O5T1GUO2 Le Zhou-Recross （在侧边栏上） 法院：你的异议？ MURRAY 女士：是的，法官大人。因此，对范围表示异议 但也有基于403条理由的反对.有其含义 在这里，证人本可以逃脱困境 欺诈。他刚才说他被迫延长贷款。 他没有同意；只是给了他一个同意。还有 Kamaraju 先生 现在暗示原文中有一项规定 允许的贷款。但是没有能力 解释这个证人知道了什么这也要求他 得出他没有能力做出的法律结论。 法院：当然是基于法律的理由 结论，他不是律师。他无法解释合同。 KAMARAJU 先生：我可以问一下他理解了什么 是，对吧？ 法庭：你可以问一下他的理解是什么。 KAMARAJU 先生：好吧。我会问这个问题。 MURRAY 女士：他无法将自己从欺诈中解救出来， 这就是反对的403依据。 KAMARAJU 先生：他们提出了退款的想法， 法官大人，并允许他这么说。他们可以声称这是 欺诈；我们可以声称事实并非如此。 MURRAY 女士：法官大人，我只想指出，他 说他不记得合同里有什么。所以他是 已经问过一个问题 Kamaraju 先生回答了，或者先生 ——
415 O5T1GUO2 Le Zhou-Recross 法庭：那是证词吗？你能回去吗 然后看到了吗？ MURRAY 女士：关于 —— 如果是这样的话 扩展。 法庭：你想先看看他是否 回忆起是贷款期限还是事实 延期？ MURRAY 女士：能力的事实 交易对手未经同意要求延期。那个—— KAMARAJU 先生：我的问题不是这样问的。 我的问题刚才说得很简单——但我没问 明白，但如果我要问，我会说，所以你的 可以理解的是，你的贷款将在一年后偿还 现在。 弗根森先生：不。 法庭：如果你想回去听证词 不会介意的。 （读取记录） MURRAY 女士：法官大人，他已经确定了这是什么 目击者知道了他当时明白了什么，而且他是 向陪审团暗示他可以摆脱欺诈行为，以及 在 403 和黑信之下，这显然是不允许的 法律。 KAMARAJU 先生：他能不能我什么也没说 签订合同，摆脱欺诈。他们问他的损失是什么。他们
416 O5T1GUO2 Le Zhou-Recross 是出来的，不是我们。我只是说他 收到了通知，他知道自己收到了通知，而且是 据他了解，根据通知，贷款将是 一年后还款。 MURRAY 女士：法官大人，没有其他证据 除了暗示他可以外包之外，还有其他目的 欺诈。他说他想退款。他在说话 让他蒙受损失这就是他所作证的。 KAMARAJU 先生：那他们就没必要提起了 损失。我有权回应。他们把它当成问题，你的 荣誉，不是我。 MURRAY 女士：法官大人，欺诈行为很快就完成了 因为作出了虚假陈述。 法庭：他自己的理解，是这样吗？ KAMARAJU 先生：他的损失是否相关。默里女士 刚才说欺诈在发生时已经完成 虚假陈述。如果这是真的，那么他的实际损失 遭受的痛苦无关紧要。尽管如此，政府还是引起了 是的，所以我有权说，那个数字是错误的，你作证说 改错号码了，先生。 MURRAY 女士：法官大人，没有会计。他是 问他的理解，他总结了自己的情况 了解他投入了多少钱以及他投入了多少钱 没有得到偿还，这是郭文贵做出的保证，而且 没有坚持下去。
417 O5T1GUO2 Le Zhou-Recross KAMARAJU 先生：这是总结，法官大人。 没关系。可以将其汇总地提交给陪审团。 但在此之前，我们可以攻击非常具体的东西 它们引出。 法庭：我会允许你做的 理解。 KAMARAJU 先生：好吧。所以我要问的问题，就是 为了确保我遵守规定：所以根据你收到的通知， 你对何时能获得回报有何理解，或者 你什么时候应该得到报酬？ MURRAY 女士：法官大人，我们会要求它顺利进行 仅此而已，因为我们仍然坚持反对意见 他想用这个来引起不当影响 目击者，这是一个 403 的问题。 KAMARAJU 先生：所有这些含义都是 继续在侧边栏争论什么时候可以由你的Honor处理 你指示陪审团了解法律。 MURRAY 女士：不。现在这让陪审团感到困惑 尊重这位证人的证词。 KAMARAJU 先生：就在昨天我们有过这样的争论。 法庭：我会允许这个问题的。 （下一页继续）
418 O5T1GUO2 Le Zhou-Recross （在公开法庭上） 作者：KAMARAJU 先生： 问：先生，当我们暂停时，我们在谈论延期 注意。你还记得吗？ 答：是的。 问：好吧。根据你收到的通知，你是什么 了解何时应该偿还农场借款项目 校长？ 答：通知——我认为它无效，因为我之前的 与两个实体签订的合同，均由 戴维·戴。由于 David Dai 被解雇并被免职 农场我相信这两个实体都解散了 自动地，合同无效。 问：这是你的法律结论，先生？ MURRAY 女士：反对，法官大人。 法院：驳回。这是你的法律结论吗？ 答：是的。 问：你在哪里上法学院？ MURRAY 女士：反对，法官大人。 法院：持续。 问：好吧。所以你的看法是农场借款项目合同是无效的 现在无效了。 答：它是空的。 问：好吧。因此，如果你要起诉某人，你就没有人可以起诉了 起诉。
419
O5T1GUO2 Maistrello-Direct
MURRAY 女士：反对。
法院：驳回。你可以回答。
答：你能重复一下这个问题吗。
KAMARAJU 先生：你能不能回读一下。
（读取记录）
答：是的。
KAMARAJU 先生：法官大人，没什么问题了。
法院：好吧。谢谢你，先生。你可以走
出去。
（证人原谅）
法庭：检方可以下次开庭
证人。
霍顿先生：政府给卡琳·迈斯特雷洛打了电话。
法律书记员：请举起右手。
（证人宣誓就职）
法律书记员：你可以坐下。
法院：请说出你的名字并拼出来。
目击者：Karin Maistrello。K-A-R-I-N，
M-A-I-S-T-R-E-L-L-O。
法院：你可以询问。
霍顿先生：谢谢你，法官大人。
卡琳·迈斯特雷洛，
被政府传唤为证人，
经正式宣誓后, 作证如下:
420 O5T1GUO2 Maistrello-Direct 直接检查 作者：霍顿先生： 问：早上好，迈斯特雷洛女士。 答：早上好。 问：你住在哪个州？ 答：新泽西州。 问：你会说什么语言？ 答：英语、德语、意大利语、法语、西班牙语和中文。 问：那你目前在哪里工作？ 答：我在谷歌工作。 问：回到2018年，你当时为谁工作？ 答：我曾是金泉的一名员工。 问。还有—— SHROFF 女士：法官大人，对不起。我们有 难以听取证人的证词。 法庭：如果你想把麦克风拉得离你更近 然后大声说出来。 证人：当然，是的。 问：郭文贵是谁？ 答：他是我在金泉的老板。 问：那你为郭文贵工作了多长时间？ 答：从 2018 年到 2020 年。 问：还有什么名字，Maistrello 女士，如果有的话，还有什么 guo 文贵用？ A. 郭文豪。
421 O5T1GUO2 Maistrello-Direct SHROFF 女士：反对问题的形式， 法官大人。 法院：驳回。你可以回答。 A. Guo Wengui。我曾经叫他 “老板”。 问：你能不能拼出郭文贵。 A. G-U-O、W-E-N、G-U-I。 问：你说郭文贵也是 Miles Kwok。你能不能 拼写 Kwok。 A. K-WO-K。 问：Maistrello 女士，谁是郭云贵？ 答：高文贵。 问：当你为郭文贵工作时，你叫他什么？ 答：我以前常用中文叫他 Boss。 问：你今天在法庭上看见 Boss 吗？ 答：是的，我愿意。 问：你能否指出他并通过以下方式识别他的身份 他穿的东西。 答：他戴着眼镜和蓝色西装，戴着蓝色领带。 SHROFF 女士：法官大人，我会规定她是 认出了郭文贵先生的身份。 法院：好吧。 问：迈斯特雷洛女士，在你为 Boss 工作的两年中， 你每周为他工作多少天？ 答：情况各不相同。有时候是六点，有时候是七点。 问：在每周为 Boss 工作的六七天里，
422 O5T1GUO2 Maistrello-Direct 你的工作时间是什么样的？ SHROFF 女士：反对前导和形式 这个问题。 法院：驳回。你可以回答。你可以 回答。 答：这取决于我们必须做的工作，所以通常我 会很早到 8 点左右到办公室，一直到 晚上 8 点如果我还有其他项目，最早可能是 凌晨 4 点或直到午夜。视情况而定。 问：那么，迈斯特雷洛女士，你花了多少时间 和 boss 在一起？ 答：每天。 问：当你和 Boss 合作时，你是怎么样的（如果有的话） 和他沟通？ 答：以一种或另一种方式整整一天。 霍顿先生：洛夫特斯女士，你能不能停下来 证人被标记为 GX 141 的东西。 问：迈斯特雷洛女士，这是什么？ 答：这是一张照片。 问：那它是一张什么照片？ 答：照片中有两个人。一个是我，一个是 老板。 霍顿先生：政府提供政府展览 141。 SHROFF 女士：不反对，法官大人。 法院：可以接受。
423 O5T1GUO2 Maistrello-Direct （收到的政府附录141作为证据） 霍顿先生：洛夫特斯女士，你能不能把它发布出来。 问：这张照片是什么时候拍摄的，迈斯特雷洛女士？ 答：这张照片是在 2018 年拍摄的。 问：那你是什么时候开始为 Boss 工作的？ 答：在 2018 年。 问：你有没有喜欢在 Boss 工作的时候， 迈斯特雷洛女士？ 答：是的。 问：那你喜欢为他工作吗？ 答：这绝对是非常具有挑战性的。没有哪一天是相同的。你 肯定必须学到很多东西而且要快点做。 问：迈斯特雷洛女士，什么是法治组织？ A. 法治协会和法治基金会是两个 于 2018 年 11 月成立的非营利组织 2018年，它的使命是帮助中国人民。 问：谁在2018年创立了法治组织？ 答：老板做到了。 问：你在《法治》中有什么头衔（如果有的话）， 迈斯特雷洛女士？ 答：我曾是法治协会的主席兼财务主管。 问：谁在《法治》中给了你这些头衔？ 答：老板做到了。 问：作为法治协会的主席兼财务主管， Maistrello 女士，你负责那个组织吗？
424 O5T1GUO2 Maistrello-Direct 答：不，我不是。 问：谁负责法治组织？ 答：老板是。 问：你说的目的是帮助中国人民。什么，如果 什么，法治对中国人民有帮助吗？ 答：当我在那里的时候，什么都没有。 问：我们会回过头来谈这个问题。 施罗夫女士：反对评注。 法庭：你可以继续。 问：Maistrello 女士，在你工作之前你在哪里工作过 老板？ 答：在中国。 问：那你在中国为谁工作？ 答：我曾在一家石油公司工作，也曾在一家石油公司任教 大学。 问：你在中国工作的石油公司是谁所有的？ 答：从理论上讲，该公司是私有的，但是 中国的一切，都是政府拥有和支持的。 问：那你在中国工作了多长时间？ 答：五年。 问：你什么时候移居美国的？ 答：在 2017 年。 问：你是怎么第一次听说有机会工作的 郭文豪？ 答：招聘人员直接联系了我。
425 O5T1GUO2 Maistrello-Direct 问：那个招聘人员是谁？ 答：他的名字叫史蒂夫·韦伯。 问：在你第一次听说有机会工作之后 史蒂夫·韦伯的郭迈尔斯，你接下来和谁谈过？ 答：他安排了一次会议，所以是第一次面试，我在那里见面 王薇平。 问：王伊薇平是谁？ 答：当时她自称是老板的助手。 问：那她是在哪里向你介绍自己的？ 答：我们在广场酒店见面接受采访。 霍顿先生：洛夫特斯女士，你能不能展示一下 Maistrello 女士被标记为 102 号政府展览。 问：迈斯特雷洛女士，什么是政府展览 102？ 答：这是一张照片。 问：这是谁或什么的照片？ A. Yvette。 霍顿先生：法官大人，政府提议政府 展品 102。 SHROFF 女士：不反对，法官大人。 法院：可以接受。 （收到的政府附录102作为证据） 霍顿先生：请把它发布出来，洛夫特斯女士。谢谢 您。 作者：霍顿先生： 问：迈斯特雷洛女士，在你接受王薇平采访时，什么，
426 O5T1GUO2 Maistrello-Direct 如果有的话，她给郭迈尔斯打过电话吗？ 答：在那次采访中，她称他为校长。 问：那次采访中，伊平问了你什么问题 为校长工作？ 答：她问了我几个私人问题，所以她问了 关于我家庭的问题，她问我是否结婚，我 有孩子；她还问我和中共有没有关系， 对派对来说也是如此。 问：你是如何回应伊平王的问题的 和中共有任何关系吗？ 答：我告诉她我认识一些党员但是 仅此而已。 问：王维平对此有何回应？ SHROFF 女士：对传闻表示异议。 法院：持续。 问：当你说你时，伊薇特的反应是什么（如果有的话） 与中共成员有联系吗？ 法庭：所以你需要重复她的话。 霍顿先生：法官大人，我能等一会吗。 法院：是的。 霍顿先生：谢谢你，法官大人。 问：Maistrello 女士，在王薇平对你进行了采访之后 和 Boss 一起工作，接下来发生了什么？ 答：我接到史蒂夫·韦伯的电话，他告诉我 面试进行得很顺利，他又打电话给我接受采访。
427 O5T1GUO2 Maistrello-Direct 问：下次采访的是谁？ 答：那是在 Boss 身上的。 霍顿先生：洛夫特斯女士，你能不能把它记下来 展览。谢谢。 问：Boss 在哪里采访过你？ 答：在他家里。 问：他的家在哪里？ 答：雪莉-荷兰。 问：什么是 Sherry-Netherland？ 答：荷兰雪莉是一家豪华住宅酒店 俯瞰中央公园。 霍顿先生：洛夫特斯女士，你能不能展示一下 证人被标记为政府第 130 号展品。 问：迈斯特雷洛女士，什么是政府展览 130？ 答：这是一张照片。 问：这是什么照片？ 答：雪莉-荷兰。 霍顿先生：政府会提议政府 第 130 号展品。 SHROFF 女士：法官大人，我没有异议。 法院：可以接受。 （收到的政府证据 130 作为证据） 问：迈斯特雷洛女士，雪莉-荷兰在哪里？ 答：它在第 57 大道和第五大道之间。 问：那么 Boss 在 Sherry 的哪个地方采访了你？
428 O5T1GUO2 Maistrello-Direct 答：你的意思是哪个房间？ 问：你的采访在大楼的哪里？它在哪里 发生？ 答：在18楼。 问：雪利酒的 18 楼有什么？ 答：那是他的家。 问：当你来接受 Boss 采访时，谁遇见了你？ 答：伊平做到了。 问：当伊平在 Boss's 见到你的时候第一次发生了什么 公寓？ 答：当我第一次来的时候，她带我参观了一下， 只有顶层公寓的一个区域，然后我们等着老板。 问：请向陪审团描述 Boss 那部分的内容 顶层公寓看起来像。 答：那个特定部分有不同的房间，所以你可以 想象一下走廊，用餐区，茶室，图书馆， 健身房、电影室和钢琴房。 问：那么 Yvette 带你参观 Boss's 之后发生了什么 阁楼？ 答：我们坐下来等着他。 问：接下来发生了什么？ 答：他到了。 问：那么 Boss 来时他有没有采访过你？ 答：是的，他做到了。 问：那天你接受 Boss 采访后发生了什么？
429 O5T1GUO2 Maistrello-Direct 答：我回家了，我相信我收到了同样的报价 晚上。 问：你接受了那个提议吗？ 答：我做到了。 霍顿先生：洛夫特斯女士，你能不能给我看 见证标有 GX BR871 的东西。 你可以稍微放大一点，洛夫特斯女士。 谢谢。 问：迈斯特雷洛女士，这份文件是什么？ 答：这是我收到的录取通知书。 霍顿先生：法官大人，政府会提议的 GX BR871。 SHROFF 女士：不反对，法官大人。 法院：可以接受。 （收到的政府展品 BR871 作为证据） 霍顿先生：你能不能把它发布出来，洛夫特斯女士。 作者：霍顿先生： 问：Maistrello 女士，你接受的工作机会的最上面写着 金泉，纽约。纽约的金春是什么？ 答：金泉是我的雇主。 问：纽约金泉的生意是什么？ 答：它是在我作为资产的第一天赠送给我的 管理公司。 问：在你为 Boss 工作的两年里，如果有的话， 你明白 Golden Spring 是这样做的吗？
430 O5T1GUO2 Maistrello-Direct 答：Golden Spring 是一家满足 Boss 意愿的公司 和欲望，所以我们要通过这个公司 给 Boss 买东西，或者照顾好他的东西。 霍顿先生：洛夫特斯女士，你能向下滚动吗 请到这个页面的底部。谢谢。 问：Maistrello 女士，页面上有一行上有签名 纽约金泉首席运营官王薇平是这样说的。什么是 很酷？ A. 首席运营官。 问：当你为 Boss 工作时，你多久工作一次（如果有的话） 和伊平在一起？ 答：每天。 问：那么 Yvette 为谁工作？ 答：金泉。 霍顿先生：洛夫特斯女士，你能不能给我看 见证被标记为政府展品 UK723 的内容。 问：迈斯特雷洛女士，这是什么？ 答：这是一张照片。 问：那是谁的照片？ 答：照片中有四个人。老板就是其中之一， 他的妻子，女儿—— SHROFF 女士：反对，法官大人。 法庭：如果你愿意加紧努力。 （下一页继续）
431 O5T1GUO2 Maistrello-Direct （在侧边栏上） 法院：反对意见是什么？ SHROFF 女士：这与照片无关。她 没拍照，她不知道 —— 没有迹象 拍这张照片的时候，我们不知道年份，我们不知道 知道她怎么会对这张照片一无所知这个 政府正在用这张照片来介绍他们想认识的人 作为证据。这是 —— 它与 证词。 法庭：来吧。 HORTON 先生：所以照片中的人物，如 Maistrello 女士即将证实她能认出 照片中的他们。他们是将出现在这个节目中的人 案例；它们已经出现在本案例中。你不必这样 拍张照片以便能够对其进行身份验证。这是一封黑信 身份验证。而且我正在奠定基础。我想她是 差不多了，如果她还没到的话。我想要 照片已获承认。 SHROFF 女士：这张照片有什么关系？ 这张照片与这名证人的照片无关 证词。她不会就任何事情作证—— 法庭：他说过这些人会 在检方的案情中发挥作用。 SHROFF 女士：对，但不是她证词的任何部分。 因此，如果她愿意，那可能就在路上 —— 所以这是我的第一次
432 O5T1GUO2 Maistrello-Direct 反对，法官大人。我没有反对伊维特的照片 因为她要为伊平作证。这很重要 因为这与她的证词的某些部分有关。她不是 要为这些人中的任何一个作证。 法庭：她可以通过以下方式对照片进行身份验证 识别这些人。让我们看看她是否这样做。 否决。 SHROFF 女士：法官大人，当我们在侧边栏的时候， 但是，我确实反对政府律师 在每个问题中不断循环播放事实。所以每个问题 添加了证人的回应，而不仅仅是简单的 问下一个问题，有事实依据。这个 循环提问理论，我反对。 第二，法官大人，提及是不恰当的 被告被政府当作 “老板”。如果她想用 在答案中，这是一回事，但要将其延续下去 问这个问题然后把它描述为 “Boss”，我反对 也是。 法庭：好吧。所以你会叫他郭先生。 我已经否决了你对该问题的异议 问题的形式。 SHROFF 女士：谢谢。 法庭：我们回去吧。 （下一页继续）
433 O5T1GUO2 Maistrello-Direct （在公开法庭上） 法庭：你可以继续。 作者：霍顿先生： 问：Maistrello 女士，你认出这里的人吗 照片？ 答：我愿意。 霍顿先生：政府将采取行动向政府提议 展品 UK723。 法庭：她需要查明这些人的身份。 霍顿先生：哦，好吧。 问：你能识别出来吗？你能说出里面的人是谁吗 照片，从左到右。 答：是的。老板；他的妻子；伊平；和他们的女儿。 霍顿先生：政府提供政府展览 UK723。 法院：可以接受。 （收到的政府展品 UK723 作为证据） 霍顿先生：请把它发布出来，洛夫特斯女士。 问：迈斯特雷洛女士，这张照片是在哪里拍摄的？ 答：在雪利酒的餐厅里。 问：回到王维特，伊维特到底做了什么 郭先生？ 答：一切。 问：你所说的一切是什么意思？ 答：她是他的右手。
434 O5T1GUO2 Maistrello-Direct SHROFF 女士：法官大人，我很抱歉，但我有 难以听取证人的证词。如果你能去问她 要发声—— 法庭：所以你可以把麦克风拉近点然后 也要大声说出来。 证人：我会试试的，法官大人。 作者：霍顿先生： 问：迈斯特雷洛女士，你说王维平做了所有事情 对被告来说，是他的得力助手。你是什么意思 靠这个？ SHROFF 女士：反对他们作证 政府，法官大人。 法院：驳回。你可以回答。 答：所以我说她是他的右手。 问：我的问题是：这到底意味着什么？ 答：从付款到向工作人员发出指示。 问：除了郭先生，如果有的话，还有谁是王怡平 向？报告 答：只给 Boss。 霍顿先生：洛夫特斯女士，你可以拿走 向下画面。 问：顺便说一句，迈斯特雷洛女士，当你在 被告，你在哪里工作？ 答：我们的办公室位于第五大道800号。 问：还有哪里（如果有的话）你为郭先生工作过？
435 O5T1GUO2 Maistrello-Direct 答：在2019年，我们搬到了列克星敦的另一个办公室， 只要有需要，就在他家里。 法院：好吧。现在是 11:30，所以我们是 我们要休息半个小时。 陪审团成员，记住你不是 允许你们彼此讨论此案。不要允许 有人可以在你面前讨论这个问题。 我们将在中午立即开始。 女士，你可以下台，但不要讨论这个案子。 （下一页继续）
436 O5T1GUO2 Maistrello-Direct （陪审团不在场） 法庭：律师，我们面前还有什么吗 返回？ 霍顿先生：是的，法官大人。只有一件事 为了提高效率，政府希望提高水平。有一个 在迈斯特雷洛女士关于传闻的证词初期就提出异议 关于王维平发表的声明。王雁平 是郭文贵的同谋。法院知道她是 被指控与郭迈尔斯刚刚得到的证词 明确表示她也是郭文贵的经纪人。我相信 Maistrello 女士形容她为他做了一切而且 他的右手。因此，我们提交了伊维特的声明 Wang 以 Miles Guo 的经纪人身份和身份 作为本案的同谋是可以受理的。 SHROFF 女士：法官大人，我不相信 政府已经证明了存在——我看不到法院。我 道歉。但我不相信政府已经满足了 根据传闻规则确立的负担 与王维平女士和郭迈尔斯密谋。可能有 是他们建立的雇主与雇员的关系 到目前为止，但没有迹象表明他们已经建立了 这两个人之间的共谋协议。 此外，法官大人，有证据表明 政府正试图征集 —— 如果我有这个我深表歉意 错了，但我相信有人质疑她是什么样子
437 O5T1GUO2 Maistrello-Direct 在求职面试中问过，但事实并非如此 助长阴谋。它们与就业有关 问题。 最后，法官大人，即使据说政府会这样做 在这里建立了阴谋，与之无关 她被问了什么面试问题。政府有 明确证实她找到了工作而且没有任何指控 她在这里以欺诈为借口找到了工作。 因此，出于所有这些原因，法官大人，我不这么认为 政府的论点是正确的。谢谢。 霍顿先生：法官大人，没有更多了 与采访某人相比，这是一种典型的代理情况 为别人工作。王薇平是郭迈尔斯在场的 采访受雇直接与 Miles 合作的人 Guo。如果那不是代理机构，那就不存在。 SHROFF 女士：她不是受雇为郭文贵工作的， 第一，她被聘为金泉工作。 法庭：稍等片刻。王女士是否认罪 阴谋？ 霍顿先生：是的。 法庭：好吧。你可以问这样的问题 听取王女士的陈述。 霍顿先生：谢谢。 法庭：我们将在中午再次开会。 （午餐会休会）
438 O5T1GUO2 Maistrello-Direct 下午的会议 下午 12:00 （陪审团出席） 法庭：请坐下。 请记住，你仍在宣誓就职。 证人：是的，法官大人。 法院：你可以继续直接检查。 霍顿先生：谢谢你，法官大人。 作者：霍顿先生： 问：Maistrello 女士，你在 Guo 工作的时候，多久一次，如果 Guo有没有让你买东西？ 答：经常如此。 问：那么 Guo 让你买了什么东西？ 答：这可能是他媒体室的设备，也可能是 西装，可能是家具。 问：让我们来谈谈家具。什么是 Promemoria？ 答：Promemoria 是一个家具品牌。 问：那么 Promemoria 的总部在哪里？ 答：他们的总部设在意大利。 问：当你在什么时候（如果有的话）与 Promemoria 打过交道 为 Guo 工作过？ 答：我在那里工作的两年中。 问：那么 Guo 让你在 Promemoria 做了什么？ 答：有时会买家具。他们的家具是定制的， 所以联系——与从 Promemoria 到设计的人交流
439 O5T1GUO2 Maistrello-Direct 当然——某些家具。 问：那你为郭买的家具会去哪里？ 答：那要么送到办公室，要么送到他家。 问：你说你买了西装。你买了什么样的西装 给 Guo 吗？ 答：量身定制的西装。 问：你所说的定制是什么意思？ A. 定制。 问：你为郭买了什么牌子的西装（如果有的话）？ 答：主要是两个。布里奥尼就是其中之一，斯特凡诺·里奇是 其他。 问：购买这些西装的过程是怎样的？ 答：所以我会联系经理，例如 Brioni，选择一些面料，然后交给 Boss；他会的 为下一批西装选择面料；裁缝 要么到办公室要么到他家，给他测量；然后 他们会做西装然后送货回来。 问：在你的两年中，这种情况会发生多久一次 为他工作？ 答：我会说每年发生两次。肯定有一次 那时是农历新年，又是一次。 问：你每次为 Guo 买了多少套西装？ SHROFF 女士：反对。错误地描述了她 证词。 法院：代表他。
440 O5T1GUO2 Maistrello-Direct 问：你每次代表郭买了多少套西装？ 答：我想说大约十二个。 问：这些西装花了多少钱，迈斯特雷洛女士？ 答：每人大约 10,000 个。 问：那那些西装是什么样子？ 答：当然，他们有裤子和夹克；嗯，确实如此， 有不同的颜色或不同的面料，视具体情况而定 季节或者视他想要什么而定；上面有他的名字 内部口袋。 问：内侧口袋上是什么名字？ A. 郭文辉。 SHROFF 女士：对不起。我没听见。 证人：郭文豪。 问：Maistrello 女士，郭跟你说了什么（如果有的话） 他在中国拥有的车？ 答：他稍微谈了自己的车。他非常 —— 好吧， 他喜欢汽车。他为自己的车队感到非常自豪 中国。 问：如果有的话，Guo 有没有让你处理这些问题 汽车？ SHROFF 女士：反对。这些都是汽车，一些汽车吗？ 法院：他的车在中国？ 霍顿先生：是的，法官大人。 法庭：来吧。 答：他有几辆最喜欢的汽车想进口到
441 O5T1GUO2 Maistrello-Direct 我们。 问：那是什么样的汽车？ 答：这绝对是兰博基尼和劳斯莱斯。 问：那么 Guo 到底要你用兰博基尼做什么 还有劳斯莱斯？ 答：将它们进口到美国。 问：你最终能做到吗？ 答：不是。 问：为什么不呢？ 答：因为关于汽车的进口法。 问：郭是哪一年让你进口他的兰博基尼的？ 答：我想那是 2018 年。 问：迈斯特雷洛女士，什么是胡同？ 答：这是一种传统的建筑结构，典型的是 中国首都北京，那里有个庭院然后 围绕庭院三侧的房屋。 问：郭跟你说了什么（如果有的话）他在那里的房子 北京？ 答：他——嗯，他为此感到非常自豪。他展示了几张照片 主要是室内，他展示了他的作品的照片。 所有东西都是在家里定制的。 问：那北京的房产是什么样子？ 答：豪华物业，就像北京的传统住宅，但是 奢侈——一种奢侈品。 问：那处房产上有多少栋建筑物？
442 O5T1GUO2 Maistrello-Direct 答：好像有更多的建筑物彼此相连。 问：如果有的话，他有没有告诉你关于谁住在哪里 他在北京的房子？ 答：他和他的家人。 问：Chateau Ridge 是什么？ 答：Chateau Ridge 是他位于康涅狄格州的一处房产 想购买。 问：如果有的话，你和城堡有什么关系 岭？ SHROFF 女士：对问题的形式有异议。 法院：驳回。你可以回答。 证人：我能回答吗？ 法院：是的。 答：那处房产有很多来回的经历。我 我想我在 2018 年开始研究这个问题，他第一次想做这件事 买了它，所以和主人聊了很多 财产。我们去过那里好几次检查房产 本身、所有房间以及所有艺术品 —— 那是 房子。有些是他想保留的，有些是他不想要的 要么他不需要。这是一个漫长的过程。 问：你说过 “我们” 去过那里几次。“我们” 是谁？ 答：我和他一起去过那里几次。有时是其他 同事们一起加油。 问：还有其他和你一起去的同事是谁 城堡岭？
443 O5T1GUO2 Maistrello-Direct 答：在几个例子中——在几个不同的例子中， 伊平来过一次；我相信汉克也来过。这些是 我记得的人。 问：Chateau Ridge 是什么样的房产？ 答：我想描述它的最简单方法就像一座城堡。 这就是 “城堡” 的意思。原来是 —— 它看起来像法国人 城堡。内部——就像，房间的内部是 实际上是根据法国的凡尔赛宫改编的。 问：郭跟你说了什么（如果有的话）他为什么会这样 想买 Chateau Ridge？ 答：他很喜欢。 问：Guo 告诉过你他要干什么（如果有的话） 如果他买了房产？ 答：他本来要住在那里。 问：Guo 最终收购了 Chateau Ridge 吗？ 答：不，他没有。 问：当你在 2018 年到 2020 年期间为 Guo 工作时，什么 房子，如果有的话，他买了吗？ 答：他最终在康涅狄格州购买了一处房产。 问：现在 Guo 在康涅狄格州买的房子是什么样子 喜欢？ 答：那是一所非常大的房子。我会称之为别墅或别墅 豪宅。 问：还有谁（如果有的话）住在康涅狄格州的豪宅里？ 答：他和家人一起做了。
444 O5T1GUO2 Maistrello-Direct SHROFF 女士：对不起。我还有 法官大人很难听取证人的证词 目击者：对不起。我正在尝试，这是 我能达到的最高水平。 法庭：请稍等片刻。 好吧。所以有人告诉我音量已经达到了 最高，所以我只想请你非常小心 要尽可能大声说话。 证人：我会的。 法院：谢谢。 作者：霍顿先生： 问：Maistrello 女士，郭强是谁？ 答：老板的儿子。 问：你能不能拼出 Qiang Guo。 A. G-U-O，Q-I-A-N-G。 问：Boss 的儿子还使用什么其他名字（如果有的话）？ SHROFF 女士：反对。 法院：驳回。你可以回答。 A. Mileson。 问：关于迈尔森的事，郭跟你说了什么（如果有的话） 兴趣？ 答：他还对汽车感兴趣，比如汽车、摩托车。 问：当你说他对汽车和摩托车感兴趣时，谁 你指的是吗？ 答：他的儿子。
445 O5T1GUO2 Maistrello-Direct 问：有过郭要你买东西的时候吗 为了迈尔森？ 答：是的。 问：Guo 要你为迈尔森买什么？ 答：那是一辆摩托车。 问：Maistrello 女士，当 Guo 叫你为他买西装或者买西装的时候 给他儿子骑摩托车，你会怎么花钱买这些东西？ 答：这取决于金额，所以可以是电汇 转账或支票。 问：那你将如何得到这些支票？ 答：我会问伊平。 问：当你向伊平索要一张支票时会发生什么 特别购买？ 答：她会把它交给我的。 问：这些支票来自哪里？ 答：金泉。 问：Maistrello 女士，你说你买了电脑设备 对于 Guo 来说。他是怎么买那件设备的？ A. 为媒体和广播支付的很大一部分 设备是通过 Saraca 支付的。 问：萨拉卡是什么？ 答：萨拉卡是我们主要用于媒体和媒体的实体 与技术相关的费用。 问：谁负责萨拉卡？ 答：我不知道。
446 O5T1GUO2 Maistrello-Direct 问：你怎么知道某件事是否应该由以下机构支付 金泉还是萨拉卡？ 答：我凭经验学习，所以我知道某些开支 将由一家公司支付，某些其他公司将由另一家公司支付 公司。 问：那你是从谁那里学到的？ 答：在那里工作，或者伊维特会告诉我，哦，这笔费用 将属于萨拉卡或金泉之下。 问：还有哪些其他公司（如果有的话）为其中一些支付了费用 你买的东西？ 答：还有另一个名为 Genever 的实体。 问：什么是 Genever？ SHROFF 女士：反对。 法院：你可以回答。 答：这个实体曾经——主要用于个人 购买或用于支付与雪利酒有关的个人开支。 问：那么 Genever 用来支付谁的个人开支？ 答：老板的。 问：迈斯特雷洛女士，谁负责 Genever？ 答：我不知道。 问：金泉的办公室在哪里？ 答：当我开始工作时，它位于第五大道800号。 问：萨拉卡的办公室在哪里？ 答：所以我不知道官方地址，但它正在运行 来自同一个办公室，所以是第五大道800号
447 O5T1GUO2 Maistrello-Direct 问：那你所说的官方地址是什么意思？ 答：例如，向官员提交的那个 文书工作。我从来没见过。 问：如果有人的话，你会和谁交谈以授权 来自 GUO 的其中一家公司的费用——那你刚刚有 作证了？ SHROFF 女士：问了又回答。 法院：你可以回答。 答：所以每当 Boss 要我买东西时，我 会 —— 在某个时候我明白钱在哪里 应该 —— 应该来自，然后我 —— 然后我问了伊平 直接从某家公司那里获得一定数额的钱。 问：谁是马克斯·克拉斯纳？ 答：Max 是我在 Golden Spring 的同事。 霍顿先生：洛夫特斯女士，你能不能停下来 证人被标记为政府展品SM62。 问：迈斯特雷洛女士，这是什么？ 答：这是一份文件。 问：那这个文件是什么？ 答：这是一份付款申请表。 问：这张表格上有你的名字吗？ 答：是的。 问：这张表格表明了什么？ 答：作为付款申请表，它看起来像是一次购买 要么已经做了，要么就要做了，我要求了。
448 O5T1GUO2 Maistrello-Direct 霍顿先生：法官大人，政府会提议 政府展览 SM62。 法院：没有异议？ SHROFF 女士：没有，法官大人。 法院：可以接受。 （收到的政府SM62号展品作为证据） 霍顿先生：你能不能把它发布出来，洛夫特斯女士。 洛夫特斯女士，你能放大一下上面写着的线条吗 由 Max Krasner 批准。 作者：霍顿先生： 问：迈斯特雷洛女士，马克斯·克拉斯纳为老板做了什么——对不起 我——为了郭先生？ 答：他曾是金泉的一名员工，曾在 会计。 问：那他的工作意味着什么？ 答：很多付款。我知道他在写纳税申报表。 问：以及你与 Max Krasner 互动的频率（如果有的话） 在工作中？ 答：每天。 问：那你会去找他说什么？ 答：好吧，我们 —— 我们离得很近 —— 在办公室里，意思是 我们 —— 我们一起工作过，但是每当我需要一些东西时，我 例如，需要由 Saraca 付款，我会的 去找他。 问：谁是马克斯·克拉斯纳的老板？
449 O5T1GUO2 Maistrello-Direct 答：高文贵。 问：Max 还向谁报告（如果有的话）？ A. Yvette。 霍顿先生：洛夫特斯女士，你能不能登顶 我们正在浏览的这个页面，重点介绍上面的内容。 问：Maistrello 女士，你能描述一下最重要的内容吗 您的付款申请表。 答：你想让我读标题吗？ 问：如果你能描述一下我们当时所看到的情况 本页顶部。 答：好吧。所以顶部有公司名称然后 有 —— 有一份付款申请表，然后有 几行标明了这笔付款的收款人， 街道和地址以及付款方式，金额为 支出的付款和目的。 HORTON 先生：Loftus 女士，你能不能拿走 向下展示并向证人展示标有政府的内容 展品 110。 问：Maistrello 女士，这是谁？ 答：这是马克斯。 霍顿先生：政府提供政府展览 110。 SHROFF 女士：法官大人，我们没有异议。 法院：可以接受。 （收到政府的证物 110 作为证据） 霍顿先生：洛夫特斯女士，请发表。
450 O5T1GUO2 Maistrello-Direct 作者：霍顿先生： 问：现在 Max 与郭的哪家公司合作过？ 答：主要是金泉和萨拉卡。 问：在你为Guo工作的两年里，多少钱，如果有的话， 你同时和 Guo 和 Max 在一起吗？ 答：肯定每周有几次。 问：郭在什么时候（如果有的话）让 Max 买东西？ 答：关于——你能重复一下这个问题吗。 问：当然。郭在什么时候（如果有的话）让 Max 去买东西？ 答：如果 Max 在他身边，就会发生这种情况。它通常会发生 在—— 当 Boss 有了想法想买东西的时候， 他会在那一刻问他面前的那个人。 问：那么，如果有人的话，Max 需要去找谁 许可？ SHROFF 女士：对个人知识的异议。 法庭：如果你知道，你可以回答。 A. Yvette。 霍顿先生：好吧。谢谢你，洛夫特斯女士。你可以 把这个记下来。 问：迈斯特雷洛女士，谁是曹德峰？ 答：在我任职的最初几个月里他是一名同事 金泉。 问：那曹德丰做了什么？ 答：他会做保安、保安工作。 问：还有谁（如果有的话）起了安全作用？
451 O5T1GUO2 Maistrello-Direct 答：我想说我们有两支独立的队伍，所以我们有 中国队和我们有一支美国队。 问：以及你与人们交谈的频率（如果有的话） 这些安全小组？ 答：每天。 问：安全团队到底做了什么？ 答：他们正在做所有事情，所以从 驾驶、手工制作、组装、拆卸家具， 收到包裹，这些东西。 问：这些团队做了什么样的安全工作？ 答：实际上，不多，因为没有必要 安全，比如保镖这个真正意义上的保镖。 问：那你为什么说不需要安全保障？ 答：我相信 Boss 没有受到任何危险或威胁。 问：在为Guo工作的两年里，你为什么这么说？ 答：在安全方面从未发生过任何事情。 问：你怎么知道那些团队整天都在做什么？ 答：他们在告诉我。 问：你对它们的原因有何理解（如果有的话） 叫了安全小组？ 答：我猜是那个词—— SHROFF 女士：反对她的假设。 法院：持续。 问：你明白为什么叫他们吗 安全小组？
452 O5T1GUO2 Maistrello-Direct 答：是的。 问：这是什么理解？ 答：保安、保安小组或保镖这个词比较好 比杂工。 问：你说它更好是什么意思？ 答：嗯，当你需要招聘的时候听起来肯定更好 某人。 问：还有谁，如果有人退出了。 具体来谈曹德峰，什么样的 guo 给他的任务了吗？ 答：所以一开始，当我们还在设置 办公室，有很多家具在移动。他正在服用 从几个存储空间到办公室的家具。他是 有时也会粉刷办公室。 问：曹德丰为郭工作多久了？ 答：我不知道多少年。 问：那你对德丰的了解了什么（如果有的话） 曹来为 Guo 工作？ 答：来自中国。 问：如果有的话，你对曹德丰的作品有何了解 与郭家人的关系？ 答：他们相处得很好。 霍顿先生：还有洛夫特斯女士，如果你可以的话请出示 证人被标记为政府展品 UK728。 问：这是谁的照片？
453 O5T1GUO2 Maistrello-Direct 答：照片中有三个人。老板是其中之一，他的妻子 是另一个，曹是另一个。 霍顿先生：法官大人，政府开始承认 英国政府展览 GX ——对不起。 SHROFF 女士：法官大人，我们有同样的反对意见 之前。而且我相信这里的403分析会是 更高。 法院：可以接受。 （收到的政府展品 UK728 作为证据） 霍顿先生：很明显，现在是 728。 你能不能把它发布出来，洛夫特斯女士。 作者：霍顿先生： 问：迈斯特雷洛女士，照片中跪下的人是谁？ 答：没错。 问：你说的名字和曹德丰一样吗？ 答：是的。 问：照片右边的两个人是谁？ 答：男人是老板，女人是他的妻子。 问：如果有的话，曹德丰与什么关系 郭的女儿？ 答：他们在一起了。 霍顿先生：洛夫特斯女士——实际上，请把它关掉。 问：你对郭为何有何理解（如果有的话） 雇了那些安全小组？ SHROFF 女士：反对。它不是基于个人的
454 O5T1GUO2 Maistrello-Direct 知识，法官大人。另外，我们可以接近吗？ 法院：是的。 （在侧边栏上） 法院：我想这是政府的 辩称它们在传统证券中不起作用 角色是因为郭先生其实并不担心自己会出演任何角色 有点危险；这是你的论点吗？ HORTON 先生：我们正在努力招聘 —— 所以她工作了 和郭先生在一起两年，每周七天。她也是 经常和那些参加这些所谓的人交谈 安全小组。我想问一下 —— 我确实问过她是否明白 他们为什么在那里。而且我认为不同的问题是， 她明白吗，几乎每天都和郭先生交谈，为什么 他雇用了他们，尤其是在他们的任务不同的时候 比人们听到这个标签可能暗示的要多 这是第一次。 法庭：你以前问过这样的问题。 HORTON 先生：法官大人，我确实问过她是否知道为什么 他们在那里，有点像她的理解 两年来几乎每天都与他们互动，而且很多 这份证词中的问题与郭先生所说的话有关 她，对吧？她几乎整周都在他身边工作 两年来几乎一整天。我认为这很重要，如果他 对她说了他为什么有这些小组，让陪审团去做 知道他为什么这么告诉她的
455 O5T1GUO2 Maistrello-Direct 法院：我同意它可能会出现。我只是想 可能已经有人问过了。 SHROFF 女士：很多次。 霍顿先生：嗯，恕我直言，我确实以为我是 问另一个问题，这与她自己的问题不一样 观察，把别人告诉她的话放在一边，她做了什么 看看他们怎么做。现在我想说的是：他有没有说过 你为什么他雇用他们？ 法庭：好吧。没关系。 SHROFF 女士：法官大人，安全小组不是 她上任后被录用。安全小组已经到位 在那之前的几年里。而且没有证据表明她是 一个与雇用他们有关系的人。它也是 说一个安全小组简直是无定论。没有迹象 谁的—— HORTON 先生：我不是故意不尊重 施罗夫女士。我只是想做—— 法庭：来吧。 SHROFF 女士：——她指的是谁。 第三，法官大人，郭先生对她说的话 他们为什么雇用特定的人员也无关紧要。 这不是为了助长任何阴谋，所以我不知道该怎么做 它甚至可能属于传闻例外情况。 但最重要的是，法官大人，这是累积性的， 实际上与这里的任何问题都不太相关，如果他是
456 O5T1GUO2 Maistrello-Direct 我想说这完全是一场大闹剧，我 相信这个观点已经说过了。 法官大人，我只需要补充一件事。我是 我的左耳完全充耳不闻。我不仅遇到了麻烦 听见她的话，但我也很难听见他的话，尽管如此 他正站在我旁边，如果你可以的话请问他 要使用麦克风，我将不胜感激。 法院：当然。对着麦克风说话。我 已经向 AV 检查过了。 SHROFF 女士：我知道。这是我的问题。我能听见 从这里开始没问题。这是这部分。 HORTON 先生：我会尽我所能坚持下去。 法庭：我要问一下有没有办法 放大我们已经无法使用的设备范围内的声音 有。 SHROFF 女士：法官大人，我明白了。我知道你有 尝试过。我只是 —— 我不想让你想 —— 我想要 你要明白我为什么遇到麻烦。 法庭：我会继续努力。 但我允许这个问题。反对意见是 否决。 （下一页继续）
457 O5T1GUO2 Maistrello-Direct （在公开法庭上） 法庭：所以为了更好地听取你的意见，我想要 试试手持式麦克风，看看它是如何工作的。 你可以继续。 霍顿先生：谢谢你，法官大人。 作者：霍顿先生： 问：Maistrello 女士，郭跟你说了什么（如果有的话） 他为什么雇用这些安全小组？ 答：他说的是出于安全目的。 问：转向你面前的展览，你能不行——看看 摆在你面前的展览，迈斯特雷洛女士，你 认定右边的人是郭的妻子。她是什么 名字？ 答：我现在记不起来了。 问：你能不能拼出曹德锋。 A. D-E-F-E-N-G，C-A-O。 问：郭和曹德丰的关系是什么样的？ 答：很不错。 问：那你看见 Guo 做了什么样的任务？ 曹德锋？ 答：再说一遍，一开始，这实际上是关于设定 在办公室里，所以有大量的存储物在移动，家具 移动、组装、绘画。 问：你说有中国队和美国队 球队。这部作品之间有什么区别（如果有的话）
458 O5T1GUO2 Maistrello-Direct 他们做到了？ 答：——从某种意义上说，中国队更值得信任，更亲密 对老板来说比美国人更重要美国队也是 来来去去。 问：你说中国队离得更近了 值得信赖的。那是什么意思？ 答：所以有些事情可能是 Boss 感觉不到的 很高兴和美国队分享，或者他想去 他不想让别人知道的地方，所以他会 当然—— SHROFF 女士：反对，法官大人。 法院：驳回。 你可以继续。 答：所以他一定会请——中国队来帮忙 他和那些。 霍顿先生：洛夫特斯女士，你可以拿走 向下展出。 问：迈斯特雷洛女士，谁是 William Je？ 答：William Je 是 Boss 的朋友和财务人员。 问：财务人员是什么意思？ 答：他是负责投资的人而且 为老板融资。 问：你在什么时候（如果有的话）见过 William Je 的？ 答：在两年内有好几次。 问：那你在哪里见到他的？
459 O5T1GUO2 Maistrello-Direct 答：主要在办公室。 问：你是什么时候（如果有的话）和威廉·杰一起开会的？ 答：在 2018 年和 2019 年都曾多次。 问：这些会议的主题是什么？ 答：所以在 2018 年，主要话题是 Guo Media 和 Rule of 法律，也就是法治协会和基金会。在 2019 年，那是 主要是同一回事。 问：Guo Media 是什么？ 答：Guo Media 是一个平台，Boss 的社交平台 开始播出——用于他的广播。 问：在你为郭工作的两年中，如果有的话，什么时候 你在 Guo Media 工作吗？ 答：一直以一种或另一种身份行事。 问：我们会回过头来谈这个问题。 你还认识威廉·杰还有什么名字（如果有的话）？ 答：只有他——他的中文或广东话名字。 问：他的广东话名字是什么？ 答：余建明。 问：你能不能把它拼出来。 A. K-I-N、M-I-N-G、G-E。 霍顿先生：洛夫特斯女士，仅限迈斯特雷洛女士，可以 请显示 GX UK764。 问：迈斯特雷洛女士，这张照片里有谁？ 答：是威廉。 霍顿先生：谢谢你，洛夫特斯女士。你可以接受
460 O5T1GUO2 Maistrello-Direct 向下。 还有 Loftus 女士，你能不能展示一下发生了什么 标记为 GX 103。 问：这张照片里有谁？ 答：是威廉。 霍顿先生：政府会提议政府 附录 103，法官大人。 SHROFF 女士：不反对，法官大人。 法院：可以接受。 （收到的政府附录103作为证据） 霍顿先生：请把它发布出来，洛夫特斯女士。 作者：霍顿先生： 问：Maistrello 女士，有没有那个时候 William Je 问过 你要去另一家公司工作？ 答：是的。 问：那么 William Je 到底要你做什么？ 答：他让我加入他的一个公司的董事会 公司。 问：那家公司叫什么？ A. ACA Capital。 问：当 William Je 让你坐下时你在哪里 ACA Capital 董事会？ 答：我当时在办公室。 问：那么 William Je 对自己的存在原因说了什么（如果有的话） 要你加入 ACA Capital 的董事会？
461 O5T1GUO2 Maistrello-Direct 答：他提到—— SHROFF 女士：对传闻表示异议。 法庭：如果他给了你一个解释，你可以 回答。 答：他告诉我他们在新州寻找投资 约克和美国。这就是原因。 问：那你在投资方面有什么经验（如果有的话）？ 答：没有。 问：你在公司工作过什么经历（如果有的话） 导演？ 答：没有。 问：在他让你坐下之前谁向你介绍了 William Je 作为那家公司的董事？ 答：我们是由 Boss 介绍的。 问：你同意担任ACA Capital的董事吗？ 答：是的。 问：那你为什么同意在ACA Capital担任这个职位？ 答：我信任威廉。他——他要的，但我没看见 理由——拒绝。 问：你为什么信任他？ 答：我信任他，就像我信任 Boss 一样。他是一个非常善良的人 人；在我看来，值得信赖。 问：你担任ACA董事大约多长时间了 资本？ 答：几个月。
462 O5TVGUO3 Maistrello-Direct 问：那么 ACA 资本是什么？ 答：我不知道。 问：你在ACA Capital做了哪些工作（如果有的话）？ 答：我什么也没做。 问：Maistrello 女士，有时候你必须坐下吗 想为你在ACA Capital担任董事的职务作证吗？ 答：是的，我坐在证词旁边，但我已经辞职了。 问：那什么是沉积？ 答：证词是一种法律程序，其中个人 提供宣誓证据。 问：你是怎么发现自己得坐下来的 出任ACA Capital的董事职务？ 答：我被传唤了。 问：在你被传唤之后，你做了什么？ 答：第二天，我去办公室问了我们的律师 来解释那是什么。 （下一页继续）
463 O5TVGUO3 Maistrello-Direct 作者：霍顿先生： 问：那你要的人叫什么名字 解释？ 答：丹尼尔·波德哈斯基。 霍顿先生：洛夫特斯女士，你能不能展示一下 证人被标记为政府105号展品。 问：迈斯特雷洛女士，这张照片里有谁？ 答：那是丹尼尔。 霍顿先生：政府提供政府展览 105。 SHROFF 女士：不反对，法官大人。 法院：可以接受。 （收到的政府附录105作为证据） 霍顿先生：你能不能把它发布出来，洛夫特斯女士。 问：Maistrello 女士，你接到传票后做了什么 给 Dan Podhaskie？ 答：我告诉了伊平。 霍顿先生：洛夫特斯女士，你可以拿走 向下展出。 问：当你告诉她这件事时，伊平是如何回应的 传票？ 答：我们从来没有谈过传票本身，但她安排了 为我辩护 问：你什么时候（如果有的话）会见过那些律师？ 答：我相信那是七月。
464 O5TVGUO3 Maistrello-Direct 问：迈斯特雷洛女士，当你见到那些像伊维特这样的律师时 为你安排的，你以前见过他们吗？ 答：是的。 问：那你在哪里见过他们？ 答：在我们的办公室。 问：那你对自己为什么有何理解（如果有的话） 以前在你的办公室见过他们吗？ 答：他们多次来办公室提起其他诉讼。 问：在你作证当天，谁陪同你？ 答：伊平做到了。 问：你的证词是在什么样的房间里？ 答：那是一个会议室。 问：那你坐在哪里？ 答：所以有一张长桌子，我差点就坐在桌子里 中间。 法庭：请稍等片刻。 你可以继续。 霍顿先生：谢谢你，法官大人。 问：是唯一陪同你去的人吗 沉积？ 答：是的。 问：迈斯特雷洛女士，伊平是作为你的律师在场的吗？ 答：不是。 问：那里有律师代表你出庭吗 沉积？
465 O5TVGUO3 Maistrello-Direct SHROFF 女士：反对。 法院：驳回。你可以回答。 答：是的，律师已经在办公室了。 问：我明白了。而对你来说，伊平坐在哪里 在你作证的时候？ 答：我右边有两个座位。 问：证词结束后你去了哪里？ 答：我们去吃了午饭。 问：午饭后你去了哪里？ 答：回到办公室。 问：顺便说一句，你和谁共进午餐？ 答：和伊平在一起。 问：那当你和我一起回到办公室时发生了什么 伊平？ 答：我们去了老板办公室和他谈过话。 问：那你和伊平在你之后和老板谈了什么 沉积？ A. Yvette 告诉老板进展如何。 问：你觉得进展如何？ SHROFF 女士：对相关性提出异议。 法院：驳回。你可以回答。 答：这是我的第一次证词，所以我真的不知道 关于进展如何。 问：关于进展情况，伊平对老板说了什么？ 答：她说进展非常顺利。
466 O5TVGUO3 Maistrello-Direct 问：那么，伊平在其中对你说了什么（如果有的话） 和Guo会面谈你的证词进展如何？ 答：她说我很好。我做得很好。 问：伊平在那次会议上给你打了什么（如果有的话）？ 答：她称我为一个做对的人 以正确的方式做事或做事。 问：她用什么语言说的？ 答：中文。 问：那她所说的英文译文是什么 你？ 答：直译就像一把小长笛或 大致如此。 问：顺便说一句，迈斯特雷洛女士，在你工作的两年里 Guo，你跟他说什么语言？ 答：中文。 法院：你的意思是普通话吗？ 目击者：是的。 问：Maistrello 女士，你的证词是哪个月和哪一年 ACA 资本？ 答：2019 年 7 月。 问：你说你有 —— 你说你不再是导演了 ACA 资本。你是怎么离开ACA的董事职位的 资本？ 答：我给 William 发了一封电子邮件告诉他我想要 辞职。
467 O5TVGUO3 Maistrello-Direct 问：那你为什么要辞去ACA Capital的职务？ 答：我没有为公司做任何事情。我无意中听见了 比如说有某种法律问题。而且不是 认识公司却不知道我在公司中扮演的角色 公司，我只是不想参与其中。 问：Maistrello 女士，当你今天坐在这里时，你的是什么 了解你作证的目的是什么 2019 年？ SHROFF 女士：反对她的理解 今天。这无关紧要，法官大人。 法院：驳回。你可以回答。 答：我对那份证词一无所知。 问：迈斯特雷洛女士，回过头来谈法治 组织，你第一次听说 Guo 是从什么时候开始的 法治组织？ 答：那是在2018年夏天。 问：那时你在 Guo 工作多久了？ 答：几个月。 问：当你第一次听说 Guo 开始实行法治时 组织，你对此有何看法？ 答：我真的很开心。 问：你为什么真的很开心？ 答：这两个组织是 —— 在哪些方面又向前迈进了一步 老板想要。而且我觉得那时我们真的可以把 从理论到实践的东西。
468 O5TVGUO3 Maistrello-Direct 问：你向法治组织捐款了什么（如果有的话） 组织？ 答：我捐了500美元。 问：那你为什么捐款？ 答：我相信这些组织。我曾是其中一个的总裁 他们；那么如果我不捐款，谁会捐款？谁做？ 问：那你是哪一年捐款的？ 答：那要么是 2018 年，要么是 2019 年初。 问：法治组织有董事会吗？ 答：是的。 问：那你在董事会中担任过什么角色（如果有的话） 导演？ 答：我曾经是会员。 问：还有谁和你一起在那个董事会任职？ 答：因此，在法治协会的董事会中，我们有史蒂夫 班农，曾任主席；最初是 Sasha Gong、Bill Gertz 和 詹妮弗·默库里奥。 问：谁是史蒂夫·班农？ 答：史蒂夫·班农曾是前任政治顾问 唐纳德·特朗普总统。 问：史蒂夫·班农是如何参与法治的 组织？ 答：他积极参与了办公室的所有工作 2018 年左右。 问：谁让班农先生参与了这方面的工作
469 O5TVGUO3 Maistrello-Direct 办公室？ 答：老板做到了。 问：那么 Bannon 先生在办公室里到底做了什么？ 答：每当他在办公室时，他都会去那里开会 和老板在一起。 问：什么样的会议？ 答：所以最初在2018年，有很多计划 法治组织。后来它更具战略性 关于中共与中美关系的会议。 问：史蒂夫·班农在法治方面到底做了什么 组织？ 答：他真的什么也没做。 问：班农先生的工作报酬是多少（如果有的话） 在办公室做？ SHROFF 女士：反对。 假设事实不是证据。 法院：驳回。你可以回答。 答：他获得了超过一百万美元的报酬，一分为四 分期付款。 问：你从哪里学到的？ 答：我当时在办公室。 问：班农先生是怎么付这笔钱的？ 答：通过支票。 问：这些支票来自哪里？ 答：我不记得他们来自哪个实体了；可能有
470 O5TVGUO3 Maistrello-Direct 是萨拉卡。 问：谁决定让班农先生得到这笔钱？ 答：我不知道。 问：Maistrello 女士，你在规划中扮演了什么角色（如果有的话） 法治组织的启动？ 答：那年有很多计划，所以我们启动了 2018 年 11 月。我们举行了一场相当大的新闻发布会 2018 年 11 月 21 日。因此，进行了大量的协调 人们来纽约参加会议， 为主讲嘉宾做演讲，短短几个月 真的是组织的。 问：那个计划是什么时候开始的？ 答：2018 年 9 月下旬。 问：你刚才提到的新闻发布会是什么时候，什么时候 那发生了？ 答：2018 年 11 月 21 日。 问：在那个规划阶段，郭说了什么（如果有的话） 关于如何为法治组织提供资金？ 答：他说他会 — SHROFF 女士：法官大人，我们指的是私人吗 他们两个之间的对话？这是一个开放式的 问题。 法庭：什么时候？什么时候？ 霍顿先生：嗯，迈斯特雷洛女士在那里作证说 在之前是几个月的规划阶段
471 O5TVGUO3 Maistrello-Direct 发射；而且她参与了；郭先生也参与了 也是；班农先生也是。我在问她谈话的事 在这三个人之间的规划阶段。 SHROFF 女士：所有这些都持续了几个月。 霍顿先生：听起来像是一两个月。 法院：你可以回答。 答：你能重复一下这个问题吗？ 问：是的。在规划阶段，规划《规则》 法律组织，如果有的话，郭先生说了什么 法治组织将获得资助？ 答：所以他说他将捐出第一笔1亿美元作为 第一捐赠者或作为赞助商。 问：作为《规则》总裁兼财务主管的迈斯特雷洛女士 律师协会，郭先生最终捐款了1亿美元吗？ 答：不是。 问：法治实际上是如何获得资金的？ 答：它是通过来自的捐款资助的 追随者。 问：你所说的 “关注者” 是什么意思？ 答：所以 boss 有相当多的追随者，追随者基地。而且 这些追随者从2018年开始捐款。 问：《法治》有没有播出 筹款人？ 答：是的，那是一周年。 问：那次广播筹款活动期间你在哪里？
472 O5TVGUO3 Maistrello-Direct 答：在办公室。 问：筹款活动在哪里播出？ 答：何时何地？ 问：对不起，筹款活动在哪里播出？ 答：在办公室。 问：筹款活动是在哪个媒体（如果有的话）播出的？ 答：在 Guo Media 上。 问：GTV 是什么？ 答：GTV 曾经是一个平台 —— 对不起。我在想 别的东西。当我在那里的时候，GTV 和 Guo Media 是 其实是一回事。 问：那么 GTV 中的 “G” 代表什么（如果有的话）？ A. Guo。 法庭：当你提到 “办公室” 时，什么 位置？ 目击者：所以我们在 2018 年进入的第一个办公室 2019 年初是第五大道 800 号。好吧，在 2019 年，我们搬到了 第 64 名和 Lex。 问：Maistrello 女士，你做了什么（如果有的话）来规划 筹款人？ 答：没什么。 问：筹款活动的时候你在场吗？ 广播？ 答：我是。 问：如果有的话，郭先生在筹款活动中扮演了什么？
473 O5TVGUO3 Maistrello-Direct 答：他在广播了几个小时。 问：当你参加筹款活动时，你和谁在一起？ 答：起初，我在办公室二楼。而且 然后 —— 和几个同事一样。然后我搬到了 一楼，实际广播发生的地方。 问：你和哪些同事在一起？ 答：我和梅利莎、马克斯和伊维特在一起。 问：在《规则》期间，你被要求做什么（如果有的话） Guo Media 上的 Law 筹款活动？ 答：所以我们被要求从一家或一家公司转账 将实体移到另一个实体这样我们就可以截取这些内容的屏幕截图 资金流动，并在电视上直播。 问：在此期间，你被要求从哪些公司转移资金 法治电视直播？ 答：主要是萨拉卡和金泉。 问：谁让你从 Saraca 和 Golden Spring's 转移钱 法治筹款活动期间的账户？ 答：伊平做到了。 问：如果有的话，伊维特说了搬家的目的是什么 规则期间来自萨拉卡和金泉账户的资金 of Law 的筹款人？ 答：所以最终目的是拥有这么大笔钱 显示在屏幕上这样人们就能看到其他人是 捐款，我们得以通过这种方式筹集更多的钱。 问：Saraca 和 Golden Spring 像你一样的钱在哪里
474 O5TVGUO3 Maistrello-Direct 那天被要求搬家是怎么来的？ 答：我不知道。 问：那你被要求在哪里转移 Saraca 和 Golden 法治筹款活动期间的春季资金？ 答：在办公室。 问：对不起。你被要求将这些资金转移到哪里， 从萨拉卡和金泉到哪里？ 答：哦，对不起。走向法治 问：你对伊维特的搬迁要求有何反应 筹款活动期间的萨拉卡和金泉钱？ 答：我不想这样做。 问：你为什么不想做？ A. 因为这些转账不是真实的；那些是内部的 转移。流入的不是真钱，所以我不同意 有了那个。 问：当你告诉伊薇特你时，她的回应是什么 在筹款活动期间不同意转移这笔钱？ 答：她看见我很沮丧。然后她告诉我，好吧， 别做；别人会干的。 问：是别人干的吗？ 答：是的。 问：那是谁？ 答：梅利莎和马克斯正在做。 问：你之前说过，法治最终无济于事 帮助中国人们。法治委员会成立时发生了什么
475 O5TVGUO3 Maistrello-Direct 遇见了？ 答：我们在 2020 年 1 月只举行过一次董事会会议。 当时，我们讨论了要做或要做的事情。 但在此之前，我们从未真正以董事会成员的身份坐下来。 问：除了那次面对面会议之外，你还会多久举行一次 与其他法治委员会成员沟通？ 答：不太频繁。 问：董事会对什么（如果有的话）进行了投票？ 答：真的没什么。 问：有过你作为董事会投票的时候吗 法治成员？ 答：是的。 问：郭先生在《法治》中的头衔是什么？ 答：他是赞助商。 问：他在法治问题上持什么立场（如果有的话） 董事会？ 答：他没有。 问：谁负责法治委员会？ 答：老板是。 问：你说过有时候你以董事会身份投票 会员。那次投票的主题是什么？ 答：那是在2020年。因此，在COVID袭击之后，就好像有一个 提议购买个人防护装备并将其运送到中国。 问：你说有人提议购买个人防护装备。什么是 PPE？
476 O5TVGUO3 Maistrello-Direct 答：在本例中是口罩。 问：什么样的口罩？ 答：用于 COVID 口罩的 N95 口罩。 问：法治公司收购 N95 是谁的提议 口罩？ 答：老板的。 问：那个提案中的口罩在哪里？本来会是什么样子 那个提案中的口罩用完了吗？ 答：所以它们要运往中国。 问：你是如何对该提案进行投票的？ 答：我投了反对票。 问：而且，迈斯特雷洛女士，在你对郭先生的投反对票之后 向中国运送N95口罩的法治提案，什么 接下来发生了？ 答：我们的律师助理来了—— SHROFF 女士：反对。 法院：驳回。你可以回答。 SHROFF 女士：法官大人，政府正在招聘 传闻。我们有异议。 法庭：如果你愿意加紧努力，拜托。 （下一页继续）
477 O5TVGUO3 Maistrello-Direct （在侧边栏上） 法院：所以我需要对那个同谋作出裁决 传闻可能会出现。这不就是你要的吗？ HORTON 先生：属于这个例外情况，你的 荣誉；它属于机构例外情况。她是 就公务、法治作证 组织。律师助理是经典的代理人。 SHROFF 女士：律师助理正在密谋 这位证人与郭文贵一起将个人防护装备口罩送到中国 但尚未确定这如何属于其范围 这个阴谋。 他们想引起的声明是律师助理 问这位女士戴口罩是不是真的错误 正在中国。通过那份声明，他们想要陪审团 当然，得出结论，没有理由发送 这些口罩送到中国。律师助理如何成为参与者 我不清楚在这个阴谋中；我也不清楚该怎么做 此人成为该阴谋的成员。 法庭：我不知道他们在把她拒之门外 作为同谋。 来吧。 霍顿先生：我只想说放在一边 共谋者暂时例外。律师助理是代理人 该组织的。律师助理也在问一个问题。 问题不是传闻；它不是实质性陈述。
478 O5TVGUO3 Maistrello-Direct 没有为其真相提出问题是黑信， 所以这不是传闻。 除此之外，这填补了以下上下文 已经得到的证词表明有一个 由特定的人向某件事提出建议，然后 是对该提案的表决。这个细节是关于什么的 发生在那次投票结束时，它完成了 故事。 SHROFF 女士：完成故事无济于事 争辩说这是传闻。她不是郭先生的代理人。 应该很清楚。她是法治的员工 基金会。事实上，他们已经确定他没有 在法治领域的地位。她是作为特工作证的 法治基金会。因此，如果他们想带来 当法治是刑事诉讼的一部分时，就会出现这种情况，那么 她的陈述属于传闻例外情况。在这里，它 不会。 霍顿先生：起诉书中有法治。 第二件事是她 —— 的确，证人 作证说郭先生有法治头衔；也是 的确，她作证说，尽管如此，他还是控制了局面。 SHROFF 女士：她不是 —— 的代理人 法院：这是我的裁决：异议是 否决。 （下一页继续）
479 O5TVGUO3 Maistrello-Direct （在公开法庭上） 作者：霍顿先生： 问：迈斯特雷洛女士，你说郭先生没有头衔 在法治基金会？ SHROFF 女士：我相信她问过这个问题并回答了这个问题 多次提问，法官大人。 法院：我们已经确定了这一点。 请向前移动。 问：郭先生在萨拉卡有头衔吗？ 答：不是。 问：郭先生在金泉有头衔吗？ 答：不是。 问：为什么不呢？ SHROFF 女士：反对。 法院：驳回。你可以回答。 答：我不知道。 问：郭先生有没有 —— 退出了。 回过头来投票反对要发送的提案 给中国的 N95 口罩，你说在你投了反对票之后， 律师助理问你一个问题。问题是什么 律师助理问过你？ 答：她问我这是否是错字。 问：法治是如何支付寄出的 N95 口罩的 去中国？ 答：用法治的钱。
480 O5TVGUO3 Maistrello-Direct 问：那笔钱从哪里来？ 答：来自捐款。 问：迈斯特雷洛女士，如果有的话，法治何时收购了 N95 用捐款的口罩？ 答：在2020年，也就是COVID来袭的时候。 问：那么《法治》对其他N95口罩做了什么 是用捐款买的？ 答：所以其中一部分送到了老板家，我们保留了几个 办公室的箱子，还有一部分被分发给 纽约警察局辖区遍布城市各处。 问：你为什么对向其发送 N95 口罩的提议投反对票 中国有捐款吗？ 答：嗯，因为 N95 口罩的制造和生产于 中国；所以我们买它们对我来说没有任何意义 从中国运回中国，然后我们会把它们运回中国。 问：你说口罩也被送到郭先生家中。 那是哪个家？ 答：去康涅狄格州那个。 问：那些口罩是什么时候寄到郭先生家里的？ 答：在 2020 年 3 月左右。 问：谁决定将法治捐款用于 把那些 N95 口罩送到郭先生家里？ 答：老板做到了。 问：你说法治捐款也被用来汇款 给纽约警察局戴口罩。你在派遣中扮演了什么角色（如果有的话）
481 O5TVGUO3 Maistrello-Direct 纽约警察局的那些口罩？ 答：伊维特请我起草一封信作为附件 口罩。这封信应该读一些大致的东西 of: 这是郭文贵送的礼物。 问：当你被要求写信时你做了什么 说那些口罩是郭文贵送的礼物？ 答：我告诉她我可以写信，但是我 不会用 —— 用 boss 的名字签名。 问：那你为什么不用郭先生的名字在上面签名呢？ 答：嗯，因为没有与其他成员讨论过这个问题 董事会成员这不是他直接赠送的礼物，但是 是 —— 这些口罩是用法治的钱支付的。 问：那么，当你说你的时候伊平说了什么（如果有的话） 不会写信说那些口罩来自 Miles Guo？ 答：她告诉我我得到报酬是为了执行命令，而不是为了执行命令 想一想。 问：当你为郭先生工作时，你一年的工资是多少？ A. 60。 问：你的工资中列出了多少金额（如果有的话） 录取通知书？ 答：那是 90。 问：如果有的话，什么可以解释那里的区别？ 答：伊维特告诉我，公司更愿意支付 每月工资较低，最终奖金更高
482 O5TVGUO3 Maistrello-Direct 这一年中，它会达到最高水平。 问：包括您的奖金在内，您在年底的总工资是多少 那一年？ 答：我相信我在2019年1月的奖金为5,000美元。 问：包括这笔钱，你一年赚了多少 为郭先生工作？ A. 65。 霍顿先生：法官大人，我可以等一会吗？ 法院：是的。 （已聘请律师） 霍顿先生：谢谢你，法官大人。 问：Maistrello 女士，在你为他工作的两年里，会怎样，如果 有没有，郭先生跟你讲过他在中国的生活吗？ 答：在中国，他有很多人脉。他知道很多 人们。当他谈到中国时，他通常 —— 他非常 为他的成就感到自豪。他会 —— 他会经常说话 关于他的酒店，他会谈那里的工作人员，他会 谈谈设计，他是如何设计的。他总的来说是 为此感到非常自豪。 问：那你理解郭先生说话时的意思是什么 你说他在中国的人脉吗？ 答：当他谈到自己在中国的人际关系时，他知道一个 很多人，所以他有时会谈这些东西 人们做到了。他对他们了解很多。 问：这些人是谁？
483 O5TVGUO3 Maistrello-Direct 答：确实是各种各样的人。商人，部长。他 认识很多人。 问：那你所说的 “部长” 是什么意思？ 答：政府部长们也是如此。可能是部长 内政部，发展部长，教育部长。各种各样 部委。 问：你说他和你谈过他在中国的旅馆。什么 他有没有告诉你这件事？ 答：他描述了酒店、内部、外观；他 谈到了他在那里的员工，事情是如何运作的。他是 总的来说，为此感到非常非常自豪。 问：如果有的话，他跟你说了什么 你和他一起工作期间的旅馆？ 答：你能重复这个问题吗？ 问：是的。如果有的话，郭先生跟你说了什么 你工作期间他在中国的酒店状况 和他在一起？ 答：他在美国期间的酒店状况如何？ 问：是的。 答：酒店仍在运营。 问：郭先生来的时候跟你说了什么（如果有的话） 去美国？ 答：好吧，在来美国之前，他去了香港 Kong，所以他先到了。 问：如果有的话，他来的时候跟你说了什么
484 O5TVGUO3 Maistrello-Direct 从香港到美国？ 答：他在2015年离开香港，搬到了纽约。 问：如果有的话，郭先生告诉你他在干什么 从他在 2015 年到纽约的那段时间 几年后开始为他工作？ 答：他是 —— 他说的是他正在准备或获得 准备好与中国政府作战。 问：如果有的话，郭先生告诉你了什么 准备好了是什么意思？那意味着什么？ 答：主要是他在广播。他就是这么做的。 问：如果有的话，迈斯特雷洛女士，你观察到了什么 关于郭先生在美国的生活方式是如何改变的？ SHROFF 女士：假设事实没有证据，你的 荣誉。 霍顿先生：我可以为此奠定基础。 法庭：好吧。请稍等片刻。 来吧。反对意见仍然有效。 霍顿先生：谢谢你，法官大人。 作者：霍顿先生： 问：迈斯特雷洛女士，除了广播，还有什么行动， 如果有的话，郭先生有没有在你为他工作的时候服过的 那场对抗中共的斗争？ 答：除了为他召集人手之外什么都没有 战斗。 问：你说郭先生要你买东西 —— 撤回了。
485 O5TVGUO3 Maistrello-Cross Maistrello 女士，你说你向... 捐了 500 美元 法治协会。如果你能再做一次，你会吗 你把钱捐给法治了吗？ 答：根据我今天的知识，不是。 问：为什么不呢？ 答：因为那笔钱没用来做任何我相信的事情 真的进来了 霍顿先生：法官大人，我能等一会吗？我是 对不起，我能不能等一会儿，法官大人？ 法院：是的，是的。 霍顿先生：谢谢。 （已聘请律师） 霍顿先生：谢谢你，法官大人。 没有其他问题了。 法院：盘问。 SHROFF 女士：法官大人，我可以吗？ 法院：你可以。 SHROFF 女士：谢谢。 盘问 作者：SHROFF 女士： 问：迈斯特雷洛女士，你在哪里上大学？ A. 意大利罗马的学院。 问：好吧。在罗马学习之后，你在哪里学习 下一步？ 答：在中国。
486 O5TVGUO3 Maistrello-Cross 问：而且你在中国待了将近五年或更长时间； 正确？ 答：从 2012 年到 2017 年。 问：而且你在中国的时候正在工作；对吗？ 答：是的。 问：而且你和你丈夫在一起；对吗？ 答：不是。 问：你离开中国后结婚了吗？ 答：是的。 问：那你现在以什么为生？ 答：我在谷歌工作。 问：对不起？ 答：我在谷歌工作。谷歌。谷歌搜索。 问：你在谷歌工作吗？ 答：是的。 问：好吧。而且你丈夫是教授；对吗？ 答：没错。 问：而且他是纽约一所大学的教授；对吗？ 答：纽约大学，是的。 问：当你接受一份工作时，可以这样说是否公平 Golden Springs，你被录用的部分原因是因为 你说的是普通话；对吗？ 答：是的。 问：对。 而你最初是被聘为翻译员的，
487 O5TVGUO3 Maistrello-Cross 对吧？ 答：是的。 问：到了有人不满意的地步 你的翻译水平，所以他们引进了外面 翻译人员要为会议翻译；对吗？ 答：不是。 问：嗯，你没有在正式会议上翻译；对吗？ 答：我做到了。 问：我真的听不见你的声音。你没有。答案是你 没有，对吧？ 答：答案是我做到了。 问：答案是你确实为正式会议做了翻译； 正确？那是你的证词？ 答：是的。 问：谁是乌娜·威尔金森？ 答：她在2019年底被聘为外部翻译。 问：对。 然后她被邀请来翻译会议 其他人在哪里；对吗？ 答：是的。 问：对。 而且在那些会议中，你没有被用来做你的事 翻译技巧；对吗？ 答：正确。 问：对。
488 O5TVGUO3 Maistrello-Cross 现在，你作证说你是Golden的员工 纽约斯普林斯，对吧？ 答：金泉，不是春天。但是，是的。 问：好吧。纽约金泉，对吧？ 答：纽约金泉。 问：还有一个名为香港金泉的实体； 正确？ 答：对。 问：而香港金泉是金泉之上的实体 春季纽约，对吧？ 答：我不知道是不是在上面。 问：你不知道它是否在上面。 你知道资金流向了金泉吗 来自？ 答：不是。 问：你知道谁向纽约金春节投入了资金吗 账户？ 答：是的。 问：谁？ 答：伊平做到了。 问：你以为伊平把自己的钱存进了金币里 纽约春季账户？ 霍顿先生：反对。 法院：驳回。你可以回答。 答：不是她的私人钱，不是。
489 O5TVGUO3 Maistrello-Cross 问：好吧。我的问题是谁的钱在金泉 纽约？ 答：我不知道。 问：好吧。而且你当然不知道谁的钱 金泉香港；对吗？ 答：正确。 问：而且你不知道有多少亿美元 在香港金泉城；对吗？ 答：我不知道。 问：而且你不知道有多少百万或数十亿或 数十万美元—— 霍顿先生：反对，法官大人。 问：那是在纽约金春时节；对吗？ 法院：驳回。你可以回答。 答：你能重复一下这个问题吗。 问：当然。你不知道有多少十亿、几百万或 Golden Spring New 里有数十万美元 约克；对吗？ 答：我不知道。 问：现在，你在中国工作时听说过郭先生； 正确？ 答：是的。 问：你作证说，你在一家石油公司工作，对吧？ 答：没错。 问：那你是在那里当过翻译还是在那里工作
490 O5TVGUO3 Maistrello-Cross 石油公司还是别的？ 答：不，我当时在做别的事情。 问：那又是什么东西？ 答：我有好几本书。我以导演的身份离开了 通信。 问：传播总监；对吗？ 答：是的。 问：在中国的工作中，你进行了社交活动；对吗？ 答：是的。 问：你和有钱的人交往；对吗？ 答：我与人交往。 问：他们中有些人有钱，对吧？ 答：我不知道。 问：他们中的一些人很富有；对吗？ 答：我不知道。 问：嗯，你去参加聚会，不是吗？ 答：不是。 问：你在中国的时候没有参加任何聚会？ 答：你所说的 “派对” 是什么意思？ 问：派对、社交聚会、活动。 答：我去吃晚饭了。 问：对。 然后你去和富裕的人共进晚餐 你的业务领域；对吗？ 霍顿先生：反对，法官大人。
491 O5TVGUO3 Maistrello-Cross 法院：驳回。你可以回答。 答：我和同事一起吃晚饭。 问：对。 当你去和同事共进晚餐时，你 和你一起工作的人共进了与工作相关的晚餐 在石油公司；对吗？ 答：是的，同事们。 问：对。 那时，你听说过一个叫做 盘古，对吧？ 答：是的。 问：请告诉陪审团，盘古是什么？ A. Pangu 是位于首都北京的一座建筑。这是一个 围绕北京建造的龙形建筑 2008 年奥运会。 问：这是一座巨大的建筑，对吧？ 答：它很大。 问：这是一家酒店，对吧？ 答：盘古酒店是一家酒店，是的。 问：七星酒店；对吗？ 答：它被称为七星酒店。事实上，在世界上 排名是五。 问：在世界排名中，七分之五，是吗 你的证词？ 答：是的。所以名字叫七星酒店，但事实上，到期
492 O5TVGUO3 Maistrello-Cross 到，我不知道，酒店星级排名，这是一家五星级酒店。 问：现在是五星级酒店。当时是七星级 酒店？ 答：我现在不知道。 问：好吧。所以你知道谁拥有盘古，对吧？ 答：什么时候？ 问：当你生活在中国的时候，你认为谁是所有者 盘古？ 答：我当时不知道谁拥有盘古。 问：你不知道 Miles Guo 的家族拥有盘古？ 答：我在中国的时候，不是。 问：你的证词是当你在中国的时候，你没有意识到 盘古酒店老板的？ 答：当我在中国的时候，我知道他是一名开发人员而且他 开发了盘古酒店，但我不知道谁是老板 是。 问：好吧。所以你至少知道他是开发者；对吗？ 答：我知道，是的。 问：对。 而且你在那里直接作证，不是吗 是郭先生给你看了他在家的照片的时候 中国；对吗？ 答：是的。 问：而且每个家庭都很富裕；对吗？ 答：我看见了一个。
493 O5TVGUO3 Maistrello-Cross 问：你只看见一所房子？ 答：我看见了 —— 是的。正确。 问：那是一处巨大的财产；对吗？ 答：我没法说。 问：这是一座有庭院的中国传统房产； 正确？ 答：是的。 问：庭院旁边有不同的房屋；对吗？ 答：不同的结构，是的。 问：而且每种结构都适用于家庭的一部分；对吗？ 答：传统上，是的。 问：传统上，这就是文化；每个兄弟都有一个 家在院子周围。对吗？ 霍顿先生：反对，法官大人。 法院：驳回。如果你知道的话你可以回答。 答：传统上，父母与儿子同住 家庭。然后其他家庭成员（如果有的话）就会进来 周围的财产。 问：对。然后他告诉你他和他的家人就是这样生活的 在中国；对吗？ 答：是的。 问：当他这么说的时候，他在怀旧地说话 关于他在中国生活时在中国的生活；对吗？ 答：我不会怀旧地说。 问：真的。是出于仇恨吗？
494 O5TVGUO3 Maistrello-Cross 霍顿先生：反对。 法院：驳回。你可以回答。 答：他只是在说这件事。 问：他在说他的家人，对吧？ 答：他在说自己的家。 问：对。 当他和你谈论他的家时，他是 在他的办公室里，对吧？ 答：有时在办公室，有时在他家。 问：而且他刚刚有一位正式的雇主/员工 和你谈谈，对吧？ 答：是的。 问：好吧。我说得对吗，你的工作是在 Golden 春天。 SHROFF 女士：如果我能给她找工作 请签订合同。 问：对吗，女士？ 答：你能重复一下这个问题吗？ 问：当然。你有雇佣合同，对吧 金泉？ 答：是的。 问：好吧。还有那份雇佣合同的一部分—— 政府直接给你看了，对吧？ 答：是的。 问：这是一份长达一页的合同；对吗？
495 O5TVGUO3 Maistrello-Cross SHROFF 女士：是 GX B-871。你走吧。谢谢 太多了。 问：如果我能让你看看文件， 拜托。 SHROFF 女士：我可以把它也发布给我吗 请陪审员。 问：那是合同；对吗？ 答：这是录取通知书。 SHROFF 女士：好吧。如果你能向下滚动， 一直往下。 问：然后你签了字；对吗？ 答：是的。 问：你在 2018 年 2 月 13 日签了字；对吗？ 答：是的。 问：当然，这封信说你已经审阅过了， 您同意条款和条件，然后签署了条款和条件， 对吧？ 答：是的。 问：我的意思是，你读过了，对吧？ 答：我做到了。 问：好吧。我们回去一会儿，好吗？ 我猜你自己选了开始日期，或者你 到达的起始日期对你来说很方便，那是 2 月 19 日，对吧？ 答：我记不起来了。
496 O5TVGUO3 Maistrello-Cross 问：好吧。你的头衔是项目助理而且 口译员，还记得吗？ 答：我能看出来，是的。 问：对。我没问你有没有看见，我问你是否 你记得的。你记得那是你被录用的 对于；对吗？ 答：我记得我被聘为口译员。 问：好吧。上面写的是项目助理和口译员，对吧？ 答：是的。 问：好吧。你没选出项目助理，对吧？ 答：我没有。 问：好吧。而且它清楚地表明你将成为 受雇于纽约金泉有限公司，对吧？ 答：是的。 问：然后它告诉你几个要点， 录取通知书是随意录用的；对吗？ 答：是的。 问：本文向你解释了随意就业 文档，对吧？ 答：是的。 问：而且，事实上，它告诉你你可以自由 在你认为合适的情况下终止你在他们的工作；对吗？ 答：是的。 问：甚至没有告诉你必须提前两周发出通知； 正确？
497 O5TVGUO3 Maistrello-Cross 答：不是。 问：对。 你觉得，任何一天你都可以辞掉那份工作 比如，对吧？ 答：是的。 问：对。 你不喜欢正在发生的事情，你可以 已经离开了，对吧？ 答：是的。 问：好吧。然后你和这些检察官见了多少次 为你在这里作证做准备？ 答：我不记得有多少次了。 问：你不记得见过多少次了 他们？ 答：不是。 问：你还记得你遇见了谁吗？ 答：是的。 问：你和谁见过面？ 答：你想要名字吗？ 问：当然。 答：贾斯汀·霍顿、瑞安·芬克尔、朱莉安娜·默里和米卡 弗根森。 问：还有今天问你问题的那位先生，他 和你一起阅读了这份文件是为了做好准备，对吧？ 答：他给我看了这份文件。
498 O5TVGUO3 Maistrello-Cross 问：嗯，他不只是给你看，对吧，他仔细检查了 和你在一起，对吧？ 答：他给我看了。 问：他没有和你一起审查文件的条款吗？ 答：不是。 问：政府在2007年8月首次联系了你 2023 年，还记得吗？ 答：我知道。 问：然后在 8 月 14 日又联系了你，记住 那个？ 答：我不记得日期了。 问：1 月 16 日怎么样？ 答：我不记得日期了。 问：1 月 25 日？ 霍顿先生：反对，法官大人。 法院：驳回。你可以继续。 答：我不记得日期了。 问：5 月 24 日？ 答：我不记得日期了。 问：5 月 15 日？ 霍顿先生：反对，法官大人。 法院：驳回。你可以继续。 答：我不记得确切的日期了。 问：5 月 9 日？ 答：我不记得日期了。
499 O5TVGUO3 Maistrello-Cross 问：5 月 20 日？ 答：我不记得日期了。 问：昨天怎么样？你还记得昨天吗？ 答：昨天我在这里。 问：然后你见过他们，对吧？ 答：是的。 问：霍顿先生坐在那里，那个问你的人 问题，对吧？ 答：是的。 问：多少小时？ 答：几分钟。 问：好吧。前一天怎么样？ 答：星期一？ 问：对不起？ 答：你指的是星期一吗？ 问：我指的是我吗？ 答：星期一，你指的是星期一吗？ 问：是的。 答：我们在星期一见面。 问：你在星期一见面，对吧？星期一是联邦假日吗？ 答：确实如此。 问：对。 你在哪里见面的？ 答：我们在美联储26日开会。 问：他们在火车站接你？
500 O5TVGUO3 Maistrello-Cross 答：不是。 问：好吧。你到了联邦广场 26 号然后坐下来见面 和他们在一起，对吧？ 答：正确。 问：他们查阅了你的证词？ 答：不是。 问：不是？他们没有告诉你他们要问什么问题 问你？ 答：他们问了我一些问题。 问：对。 他们经历了一系列的问题，只是 就像他们今天在法庭上所做的那样，对吧？ 答：不完全是。 问：嗯，不，不完全是。但是他们坐下来问你一个 一大堆问题，对吧？ 答：他们问了我问题。 问：对。 然后他们做了笔记，对吧？ 答：他们做到了。 问：他们拍了 —— 他们给你看了照片，对吧？ 答：是的，他们给我看了一些照片。 问：他们今天在这里给你看了同样的照片；对吗？ 答：我不记得确切了。 问：然后他们有没有告诉过你像我这样的人会怎么样 盘问你？
501 O5TVGUO3 Maistrello-Cross 答：他们解释了它是如何工作的，是的。 问：他们做到了，对吧？他们告诉你会出现什么问题 在盘问时对着你；对吗？ 答：不是。 问：他们没有告诉你会出现什么问题，你怎么回事 应该在十字路口预测吗？ 答：他们向我解释了它是如何工作的。 问：对。 他们告诉你郭先生的律师会问你 问题，对吧？ 答：是的。 问：他们还帮你准备了如何回答，对吧？ 答：不是。 SHROFF 女士：好吧。让我们看看我们能不能停下来 政府展览 141。 问：他们给你看了这张照片，对吗？ 答：有一次他们这样做了。 问：对。 我不会问你他们在做准备的众多准备工作中哪一个 给你看了照片但他们给你看了这个 照片，对吧？ 答：是的。 问：那张照片是谁拍的，女士？ 答：我们有大约七个，有摄影师和 摄像师，用于拍照。
502 O5TVGUO3 Maistrello-Cross 问：对。 而且你不是照片中唯一的人， 对吧？ 答：不是。 问：照片中还有其他人，对吧？ 答：是的。 问：而且是专业机构拍的照片， 对吧？ 答：是的。 问：这些照片是 —— 它们本来要用于 特别的发射；对吗？ 答：正确。 问：这并不罕见，对吧？ 答：事实上，一张照片只拍过一次。 问：你在那里工作时只发生过一次， 对吧？ 答：你能重复这个问题吗？ 问：当然。据你所知，它只发生过一次 你在那里工作的时间，对吧？ 答：在我在那里工作的时候，曾经发生过一次。 问：对。 总而言之，你在那里工作了多少？大约两个 年份？ 答：两年以上。 问：还有多少？两年半？
503 O5TVGUO3 Maistrello-Cross 答：大约。 问：大约两年半。 可以公平地说，对吧，如果我是，你纠正我 错了，你离开是因为医疗原因，对吧？ 答：没错。 问：对。 然后你决定 COVID 要来了，但你没有感觉 好吧，对吧？ 答：不是。 问：好吧，COVID就要来了，对吧，当你戒烟的时候？ 答：COVID在2020年2月袭击。 问：对。 你认为COVID是在2020年2月或3月发生的 2020 年？ 答：要么是二月，要么是三月。 问：然后你在接下来的一个月就退出了，对吧？ 答：是的。 问：好吧。而你给出的戒烟的原因是因为你 我以为是微波炉攻击了你，对吧？你就是这样 告诉过金泉的人吗？ 答：不是。 问：好吧。 然后你说你已经住院了；是 那对吗？ 答：我正要成为。
504 O5TVGUO3 Maistrello-Cross 问：对。 然后伊平回应你生病了；对吗？ 答：你这样说是什么意思？ 问：她给你送了花，对吗？ 答：不，她没有。 问：她没有。 她有没有延长你的保险范围来帮助你 当你生病的时候？ 答：不，她没有。 问：你在的时候她没有为你提供 COBRA 福利 生病了？ 答：COBRA的福利包括在内，但她没有延长这些福利 就个人而言。 问：她没有向你主动提出要亲自延期，是吗 你今天在这里作证？ 答：正确。 问：好吧。而且你曾经和其他人保持过联系，不是吗 为郭先生工作的人；对吗？ 答：什么时候？ 问：在你辞去 Golden 工作后的整个时期 弹簧，对吧？ 答：有几个人联系了我。 问：对。 然后他们联系了你，确保你身体健康， 对吧？
505 O5TVGUO3 Maistrello-Cross 答：他们问我过得怎么样。 问：对。 那份清单中包括梅利莎；对吗？ 答：是的。 （下一页继续）
506 O5T1GUO4 Maistrello-Cross 作者：SHROFF 女士： 问：一位名叫维克多·塞尔达的律师说你应该去看病 有所帮助，感觉好多了，对吗？ 答：我记不起来了。 问：好吧。然后 Max Krasner 联系了你，对吗？ 答：是的，他问我过得怎么样。 问：还有一个叫丹·波德哈斯基的人也联系了你， 正确？ 答：是的。 问：现在这些都是你在那里工作时认识的人， 正确？ 答：是的。 问：好吧。所以你知道了——让我们来看看这份清单。 伊平；是这样吗？ 答：是的。 问：你认识丹·克拉斯纳，对吗？ 答：马克斯。 问：马克斯·克拉斯纳。 答：马克斯·克拉斯纳。 问：对不起。我一直在混名字。 Max Krasner，对吗？ 答：是的。 问：丹·波德哈斯基，对吗？ 答：是的。 问：你不喜欢 Dan Podhaskie，对吧？
507 O5T1GUO4 Maistrello-Cross 答：事实并非如此。 问：真的吗？你没抱怨过他打你的吗 天？ 答：不，我没有。 问：你没有向王维平抱怨他打了你 去华盛顿特区旅行时？ 霍顿先生：反对，法官大人。问了还有 回答。 法院：持续。 问：你和丹·波德哈斯基一起去过华盛顿特区吗？ 答：不是。 问：你没有和丹·波德哈斯基一起去华盛顿旅行， 华盛顿特区做生意；这是你的证词？ 霍顿先生：反对，法官大人。问了还有 回答。 法院：持续。 问：可以公平地说你不喜欢 Dan Podhaskie，对吧？ 霍顿先生：反对，法官大人。问了还有 回答。 法院：持续。 问：你与... 有积极的工作关系吗 波德哈斯基先生？ 霍顿先生：反对法官大人。问了还有 回答。 SHROFF 女士：我没问这个问题。
508 O5T1GUO4 Maistrello-Cross 法院：你可以回答这个问题。 答：我们有良好的工作关系。 问：对不起？ 答：我们有良好的工作关系。 问：你和他的工作关系如何？ 答：我们曾经是同事。 问：好吧。作为同事，你们是如何与他们互动的 其他？ 答：我们谈过了。 问：好吧。谈了什么？ 答：工作。 问：什么有效？ 答：在办公室工作。 问：在办公室工作。在办公室干什么？ 答：他会来找我要东西，或者随时随地 需要翻译，我会帮他的。与工作相关的讲座。 问：而且你已经作了很长时间的证词 和伊平的关系，对吗？ 答：我作证的时间不长。我回答了问题 有人问过我。 问：好吧。而伊薇特的全名是 —— 你叫她伊维特吗 还是你叫她王女士或者你是怎么称呼她的？ 答：我——我用了她的名字。 问：你叫她伊平，对吧？ 答：她的中文名字。
509 O5T1GUO4 Maistrello-Cross 问：那是吗？ A. 延平。 问：你和她说话的时候称她为燕平？ 答：是的。 问：好吧。但是当你和政府谈起她时，你 叫她为伊平，对吧？ 答：我不记得了。 问：好吧。好吧，让我们来谈谈你和她的互动， 好吗？ 你作证说她是指挥者 第一次求职面试，对吧？ 答：是的。 问：当她接受你的采访时，你在哪里？ 答：第一次采访发生在广场酒店。 问：好吧。而且没有给你任何理由说明为什么 采访是在广场酒店进行的，对吗？ 答：不是。 问：这是一次每天的求职面试，对吗？ 答：那是一次求职面试。 问：对。而且你是被一个叫史蒂夫的人送到那里的 韦伯，对吧？ 答：是的。 问：史蒂夫·韦伯是个猎头，对吗？ 答：我不知道他今天是否在场。他当时在。 问：对。然后你填写了一份工作——或者一份申请表来获得
510 O5T1GUO4 Maistrello-Cross 在他的公司找到一份工作就是这样发生的，对吧？ 答：他已经联系过我了。 问：对。你作证说第二次采访是 和郭先生在一起，对吗？ 答：正确。 问：现在当你去第二次面试时，他们没有 给你发备忘录或通知说你正在面试 和 Boss 在一起，对吧？ 答：我记不起来了。 问：他们告诉你你接受了求职面试但面试是 跟一个叫郭先生的人在一起，对吧？ 答：我不记得他们使用的具体名字了。 问：所以你不记得他们有没有称他为郭先生， 正确？ 答：我不记得了，不是。 问：你不知道他们是否称他为郭先生，对吗？ 答：我不记得了。 问：说他们没有提及你是否公平——请参阅 他们安排面试的时候他是老板？ 答：我不记得了。 问：好吧。作为工作的一部分，你发出了电子邮件，对吗？ 答：是的。 问：内部电子邮件，对吗？ 答：是的。 问：还有外部电子邮件，对吗？
511 O5T1GUO4 Maistrello-Cross 答：是的。 问：而且你向各机构发送了外部电子邮件，对吗？ 答：你所说的机构是什么意思？ 问：企业，对吧？您向发送了外部电子邮件 企业，对吧？ 答：是的。 问：好吧。然后你称郭先生要么是郭先生要么是 你电邮里有郭先生，对吗？ 答：不是。我永远不会称他为郭先生。 问：好吧，如果你给意大利那个漂亮的地方发电子邮件 关于家具，你会怎么称呼他？ 答：郭先生。 问：郭先生，对吧？你不会在电子邮件里称他为 Boss， 对吧？ 答：我——我一定会叫他郭先生。 问：对。当你在广告你过去的工作经历时 Golden Spring，你没说，我在 Boss 工作过，对吧，你 比如说，我为一个叫郭文贵的人工作，对吗？ 答：我真的没做广告。我从不宣传他的名字。 问：在 LinkedIn 上怎么样？你是说我为一个男人工作吗 叫老板？ 答：不是。 问：好吧。所以你唯一一次一直称他为 老板是你在这里作证或者说话的时候 在办公室内部，对吗？
512 O5T1GUO4 Maistrello-Cross 答：所以当我和他说话时我会用中文称他为 Boss 当我向我的同事介绍老板时，他会直接联系他。 问：而且这个法庭环境既不是你在说话 郭先生或者你在跟同事说话，对吗？ 答：没错。 问：这是一项正式程序，对吗？ 答：确实如此。 问：而且你在作证时都称他为 Boss， 正确？ 答：是的。 问：好吧。现在如果我能让你回想起你的证词 拜托了 102 号政府展览。 这是伊平，对吗？ 答：确实如此。 问：对。根据你的说法，在你接受采访时 Yvette，她，Yvette Yanping Wang，问你你什么 与中共有联系；对吗？ 答：是的。 问：对。可以公平地说，对，你不能成为其中的一员 中共因为你根本不是中国国民，对吗？ 答：没错。 问：如果不是中国人，你就不可能成为中共的一员 全国性的，对吗？ 答：没错。 问：在所有人中，王女士肯定会知道的
513 O5T1GUO4 Maistrello-Cross 基本事实，对吗？ 答：是的。 问：王女士在工作期间不可能问过你 如果你属于中共就面试；那不是吗？ 霍顿先生：反对，法官大人。 法庭：我会让你回答。来吧。 答：她从来没有问过我是否是党员。她问我 如果我认识党员的话 问：她问你是否认识任何曾经是党员的人；是 那是你的证词？ 答：她问我是否认识党员。 问：她有没有向你解释过 “知道” 是什么意思？ 答：“知道” 是什么意思？ 问：好吧，我现在认识你了。那并不意味着我真的知道 你，对吧？ 霍顿先生：反对，法官大人。 法庭：不要作证。 SHROFF 女士：我会继续的。 你能不能给她看看 130 号政府展品。 问：你为这座建筑作证，对吗？ 答：是的。 问：这是 Sherry-Netherland，对吧？ 答：确实如此。 问：他们在你准备的时候给你看了这张照片， 正确？
514 O5T1GUO4 Maistrello-Cross 答：我不记得了。 问：好吧。郭先生住在这栋大楼的十八楼， 正确？ 答：是的。 问：阁楼，对吗？ 答：是的。 问：它太巨大了；不是真的吗？ 答：它很大。 问：对。里面有个录音室，对吗？ 答：你所说的录音室是什么意思？ 问：他是从哪里广播的，对吗？ 答：那是一个办公室。 问：对。有一个 —— 有一个实际的办公室设立在 那个家，对吗？ 答：是的。 问：好吧。你能试着保持声音吗。那会 请真的帮帮我。 答：我会尽力的。 问：谢谢。 而且那栋大楼里有保安，对吗？ 答：大楼有工作人员可以让人们进出。 问：对。24 小时工作人员，让人们进出，对吗？ 答：是的。 问：除非有人进来否则你无法上那个 18 楼 那个楼层说你可以上来，对吗？
515 O5T1GUO4 Maistrello-Cross 答：是的。我的名字在名单上。 问：没错。而你能上升的唯一原因是因为 你的名字在名单上，对吗？ 答：是的。 问：那是因为郭先生想要安全保障 他自己和他的家人，对吗？ 答：安全设备属于酒店。 问：而且是他把你的名字写在那张证券上 设备，对吗？ 答：我不知道他是否是那个人，但我的名字在那里。 问：好吧。可以公平地说有安全保障吗 那栋大楼里有全天候的设备？ 答：我相信是这样。 问：车库里有全天候的安全设备，对吗？ 答：我不知道。 问：好吧。而今天坐在这里，你不知道，对吧， 不管他选择那栋大楼是否是因为他想 确保他住在一栋有24小时保安的大楼里； 你根本不知道，对吗？ 答：他知道他选择那栋大楼的原因。 问：没错。你不知道，对吧？ 答：我不知道。 SHROFF 女士：你可以把它记下来。谢谢。 如果有人能给她看 UK723，拜托。 问：你为这张照片作证，对吗？
516 O5T1GUO4 Maistrello-Cross 答：是的。 问：好吧。让我们来看看它们。 你看见郭先生坐在那里，对吗？ 答：我知道。 问：谁在他的左边？ 答：他的妻子。 问：你知道她在监狱里关了多少年吗 因为她嫁给了郭先生？ 霍顿先生：反对，法官大人。 法院：持续。 问：你看到坐在她左边的人了吗？ 答：我知道。 问：那是谁？ 答：那是伊平。 问：你知道伊维特在监狱里被关押了多少年吗 中国？ 霍顿先生：反对，法官大人。 法院：持续。 问：坐在郭先生对面的人是谁？ 答：他的女儿。 问：好吧。而他的女儿现在住在美国， 正确？ 答：在我工作之前，所以在 2020 年，她在美国 各州。 问：而且你在工作中认识她，对吧？
517 O5T1GUO4 Maistrello-Cross 答：她来到了办公室。 问：她每年圣诞节都会给你寄一份圣诞礼物，对吧？ 答：她在办公室为我们所有人买了圣诞礼物。 问：每个员工，对吗？ 答：我不知道是否每个员工都明白了。 问：好吧。对吧，在你工作的时候郭先生给你买了礼物 他？ 答：农历新年。 问：你的证词是你从郭先生那里得到的唯一礼物 是农历新年吗？ 答：两次。在两个不同的农历新年上。 问：好吧。你还记得收到过爱马仕河豚的礼物吗 夹克？ 答：是的。 问：那是他写的，对吧？ 答：正确。 问：你接受了礼物，对吧？ 答：我做到了。 问：顺便问一下，爱马仕在哪里？它在哪里？ 答：你的意思是总部？ 问：不是。我的意思就是商店。 霍顿先生：反对，法官大人。 法院：驳回。如果你知道它在哪里，请告诉我 我们知道。 答：在麦迪逊。
518 O5T1GUO4 Maistrello-Cross 问：麦迪逊之类的？ 答：我不记得十字路口了。 问。第 67 个？ 答：我不记得了。 问：你认为那件羽绒夹克多少钱？ 答：我不知道。 问：你会同意我的看法吗，女士，爱马仕是 很高端的商店，对吗？ 霍顿先生：反对，法官大人。401。 法院：驳回。你可以回答。 答：你能重复一下这个问题吗。 问：当然。你会同意我的看法，不是吗，爱马仕 是一家极其高端的商店吗？ 答：我同意。 SHROFF 女士：你可以把它记下来。 问：你现在作证了，不是吗，直接说了一个 商店——请原谅我，我不记得名字了。Promemoria， 或者类似的东西？ A. Promemoria？是的。 问：正确。你还记得那家商店吗？ 答：他们这里没有商店。 问：这是一家位于意大利的公司，对吗？ 答：正确。 问：这是供应商，对吧；供应皮革，对吗？ 答：这是一家家具公司。
519 O5T1GUO4 Maistrello-Cross 问：你可以给他们打电话然后给自己买一些非常昂贵的东西 家具，对吗？ 答：任何人都可以给他们打电话，是的。 问：对。对。而且你用它下了好几个订单 公司，对吗？ 答：是的。 问：对。而且它们是家具订单，对吗？ 答：是的。 问：然后你会下订单，对吗？ 答：正确。 问：谁选择了它，家具？ 答：老板做到了。 问：郭先生，对吧？ 答：是的。 问：好吧。然后郭先生会选择家具然后他会问 你来下订单，对吗？ 答：是的。 问：好吧。然后你会下订单，对吧？ 答：我会的。 问：有时候他会改变对订单的看法，对吧？ 答：一直如此。 问：一直如此；难道不是这样吗？ 答：是的。 问：非常令人沮丧，对吗？ 答：这是工作的一部分。
520 O5T1GUO4 Maistrello-Cross 问：对你来说，这是工作中令人沮丧的部分的一部分， 对吧？ 答：这是工作的一部分。 问：他会选点东西，让你下订单，然后 你取消了吗，对吗？ 答：那件事发生了。 问：他会改变主意的，对吗？ 答：是的。 问：他在那个地方就是这样做的，不管它叫什么，城堡 Ridge 之类的，对吧？ 答：他最初想购买，但后来没有。 问：对。而且你花了很多时间作证， 我知道，那是一座宫殿里有艺术品而且什么都有 这些东西。归根结底，他从来没有买过，对吗？ 答：他没有。 问：现在让我们来谈谈你订购的 Brioni 西装 根据你的说法，他。你为他订购了吗？ 答：是的。 问：好吧。你知道他做客户多久了吗 布里奥尼，无论是十年还是二十年？ 答：将近二十年。 问：二十年，对吧？已经20年了？ 答：大约。 问：对。所以他们认识他，对吗？ 答：他们做到了。
521 O5T1GUO4 Maistrello-Cross 问：对吧？因为他们做他的西装已经20年了 对吧？ 答：他们认识他。 问：好吧。谁在 20 年前付了账单；你知道吗？ 答：我不知道。 问：谁在 10 年前付了账单；你知道吗？ 答：我不知道。 问：现在谁为诉讼付了账单；你知道吗？ 答：你的意思是今天？ 问：嗯，今天你肯定不知道，因为你不工作 为了他了，对吧？ 答：没错。 问：对。那么，当你为他工作时，谁付了账单？ 答：金泉。 问：金泉属于谁？ 今天坐在这里，你不知道谁的钱 金泉，对吧？ 答：我知道总统的名字，我知道总统的名字 首席运营官。 问：好吧。你不知道谁的钱进去了，对吧？ 答：我不知道。 问：对。当然，当规则时你从来没有加入过董事会 法律基金会往里面存了钱，对吗？ 答：你这样说是什么意思？ 问：你不知道有任何来自 Rule of Law 的钱
522 O5T1GUO4 Maistrello-Cross 基金会进入了金泉，对吗？ 答：我不知道来自法治的钱曾经流向过 金泉。我不知道。 问：我只是想确定一下。 现在你说他们把所有这些钱都付给了他 西装，纽约金春套装了，对吗？ 答：是的。 问：好吧。然后他们用什么付款，支票或转账；你呢 知道吗？ 答：通常是一张支票。 问：好吧。但是你不知道，对吧？ 答：我知道。 问：你确实知道，它是用支票支付的。 答：是的。 问：开给谁的支票，纽约布里奥尼，布里奥尼 法国，在哪里？ A. Brioni 纽约麦迪逊。 问：好吧。现在你也作了关于汽车的证词，对吗？ 答：是的。 问：这个人不知道怎么开车，对吧？ 答：他知道怎么开车。 问：你见过郭文贵开车。 答：是的。 问：在纽约街头。 答：就在纽约郊外。
523 O5T1GUO4 Maistrello-Cross 问：在纽约以外。你的证词是你认识这个人 在外面的街道上开车。 霍顿先生：反对。询问并回答。 法院：持续。 问：你知道他有没有驾照吗？ 答：当我在那里工作时，他没有。他只有一个香港 驾驶执照是的。 问：他甚至没有学习许可证，对吧？ 答：你的意思是美国学习许可吗？ 问：是的，女士。 答：当时他没有。 问：好吧。他被开车去工作，对吗？ 答：是的。 问：他被赶下班了，对吗？ 答：没错。 问：而且无论走到哪里，他都会被开车；他从来没有开过车 曾经在纽约市的街道上走过，对吗？ 答：他曾经做过一次。 问：好吧。把你一直提到的这个放在一边， 没错，无论他走到哪里，他都会来回开车，而 你为他工作过？ 霍顿先生：反对，法官大人。问了还有 回答。 SHROFF 女士：法官大人，我会继续前进的。 法院：你可以回答。
524 O5T1GUO4 Maistrello-Cross 问：真的吗？ 答：他被开车了。 问：好吧。然后你谈到了他是怎么说的 他在中国买的劳斯莱斯，对吗？ 答：是的。 问：他从来没有把劳斯莱斯从中国带到美国 各州，对吗？ 答：据我所知不是。 问：对不起。什么？ 答：据我所知不是。 问：没错。他会谈这件事然后他会 放弃这个项目，对吗？ 答：就是不可能进口那辆车所以—— 问：对。兰博基尼也一样，对吧？没有劳斯莱斯 这里曾经进口过罗伊斯或兰博基尼，对吗？ 答：据我所知不是。 问：你只能证明自己的知识。所以答案是 没有？ 答：答案是否定的。 问：好吧。现在你还为一个叫汉克的人作证 正确？ 答：是的。 问：现在汉克和郭先生一起从中国过来了，对吗？ 答：没错。 问：对。而且先生——而且汉克绝对不会说英语，
525 O5T1GUO4 Maistrello-Cross 正确？ 答：他没有。 问：对。而汉克曾经和郭先生及其家人住在一起， 正确？ 答：他们分开生活。 问：你认为汉克和郭家族是分开生活的。 霍顿先生：反对。询问并回答。 法院：持续。 问：你为郭先生的儿子叫迈尔森作证，对吗？ 答：是的。 问：你从未亲自见过迈尔森，对吗？ 答：我做到了。 问：你在哪里见到他的？ 答：在办公室。 问：在办公室在哪里？ 答：800 第五。 问：那是哪一年？ 答：我第一次见到他是在2018年。 问：那你第二次见到他是什么时候？ 答：你能重复一下这个问题吗。 问：什么时候——慢慢来。 答：谢谢。 问：不客气。 第二次是什么时候？ 答：在 2019 年。
526 O5T1GUO4 Maistrello-Cross 问：从那以后你再也没有见过他，对吧？ 答：我相信我们最后一次见面是在2019年。 问：好吧。而且他没让你给他买摩托车， 对吧？ 答：不是直接的，不是。 问：问题是 Mileson 有没有让你买任何东西 摩托车。答案是否定的，对吗？ 霍顿先生：反对，法官大人。问了还有 回答。 法院：持续。 问：郭先生没有让你给他儿子买摩托车， 正确？ 霍顿先生：反对。 法院：你可以回答。 答：他做到了。 问：他让你给他儿子买摩托车？ 答：一个具体的—— 问：我听不见你的声音。 答：一次，一次。 问：一次。而且你从来没有买过自行车，对吧？ 答：我相信是他自己买的。 问：我问你有没有买自行车。 答：我没有。 问：好吧。当你说你相信他买了自行车时，你 其实不知道他有没有为儿子买过自行车，
527 O5T1GUO4 Maistrello-Cross 正确；那只是你的信念？ 霍顿先生：反对，法官大人。 法庭：你可以回答你是否知道或 你相信。 答：我不知道。 问：没错，你会要求伊平付款 郭先生要你买？ 答：如果金额更大，是的。 问：而且必须由伊维特授权 付款，对吗？ 答：是的。 问：你无法授权任何人的任何付款 实体，对吗？ 答：不，我只有公司的信用卡。 问：对。我的问题是：你没有权限授权 完全付款，对吗？ 答：授权？ 问：是的。 答：不是。 问：你不能说，金泉会支付这笔账单， 正确？ 答：这取决于金额。 问：你的证词是，如果是来自 Golden 的少量款项 春天已经过去了，你本可以付出代价 金泉？
528 O5T1GUO4 Maistrello-Cross 霍顿先生：反对，法官大人。描述不正确 她的证词。 法院：驳回。你可以回答。 答：我通过公司的信用卡下了订单，所以对于 是的，金额较小。 问：你会下订单，对吗？对吧？ 答：是的。 问：该账单将交给金泉，对吗？ 答：是的。 问：你不知道是否付了钱，对吧？ 答：好吧，通过信贷立即付款 卡。 问：你不知道是否付了钱，对吗？ 答：我不是—— 霍顿先生：反对，法官大人。 法庭：你在问交易是否是 已完成或者信用卡账单是否已支付？ SHROFF 女士：信用卡账单是否已支付。 答：一直用信用卡账单支付，因为我有 可用资金。 问：你的意思是金泉信用卡有钱 可用。 答：是的。 问：这不是你的信用卡，对吧？ 答：我的公司信用卡。
529 O5T1GUO4 Maistrello-Cross 问：不是你的信用卡，对吗？ 霍顿先生：反对，法官大人。 法院：持续。 问：你能用那张信用卡给自己买点东西吗？ 答：个人开支？ 问：是的。 答：不是。 问：好吧。现在你已经讨论了几个实体 是直接作证的，对吗？我们已经介绍过了 金泉，对吧？因此，让我们来谈谈萨拉卡。 你知道萨拉卡是什么吗？ 答：我对萨拉卡的了解是，所有费用都与之相关 去科技或媒体去了萨拉卡。 问：好吧。你不知道萨拉卡是否是一家控股公司， 正确？ 答：我不知道。 问：你不知道这是否是私营公司，对吗？ 答：我不知道。 问：你不知道它是在哪里获得许可或注册的， 正确？ 答：我不知道。 问：然后他们问了你所有这些关于一些的问题 另一家叫Genever的公司，对吗？ 答：Genever？ 问：当然。你还记得你在这方面的证词吗？
530 O5T1GUO4 Maistrello-Cross 答：是的。 问：好吧。你对那家公司也一无所知， 对吧？ 答：从结构上讲，不是。 问：正确。你不知道谁拥有那家公司，对吗？ 答：我不知道。 问：你不知道有没有这样的董事会 公司，对吗？ 答：我不知道。 问：而且你不知道那家公司的钱从哪里来 来自，对吗？ 答：我不知道。 问：你能就此作证的唯一原因是因为你 在你准备的时候和政府谈过这件事，对吗？ 霍顿先生：反对。反对，法官大人。 法院：驳回。你可以回答。 答：你能重复一下这个问题吗。 问：没关系。我会继续前进的。 现在你作证了，不是吗，有时候吗 当你陪着郭先生时，他会决定购买 什么，对吗？ 答：陪他在哪里？ 问：好吧，你们两个一起工作了，对吗？ 答：我没那么说。 问：好吧，你没有直接作证说无论谁在里面
531 O5T1GUO4 Maistrello-Cross 在他面前会付出代价的，对吧？ 答：我说的是每当 Boss 想买东西的时候 —— 可能是电视，可能是屏幕，可能是显示器，它 可能是摄像机 —— 那个是 Boss 在他面前的那个人 每时每刻，他都会问他们。 问：好吧。他会要求他们付钱，对吗？ 答：他会要求他们购买。他不会使用 “付款” 这个词。 他只会说买它。 问：对。30分钟后他可能会改变主意， 正确？ 答：他可能会。 问：好吧。当那件事发生时，金泉会付出代价， 正确？ 答：好吧，当他改变主意时，如果他改变了主意， 也许根本没有必要购买。 问：好吧。足够公平。 现在是你作证的另外一个人 direct 是一个叫曹的人，对吗？ 答：哦，Cao？ 问：对。是这样吗？ 答：没错。 问：好吧。然后你作证了—— SHROFF 女士：如果你能给她看 UK728，拜托了。 问：你为这张照片作证，对吗？ 答：我做到了。
532 O5T1GUO4 Maistrello-Cross 问：好吧。你知道这张照片是什么时候拍的吗 方式？ 答：什么时候？ 问：是的。 答：我不知道。 问：你知道谁拿走了吗？ 答：我不知道。 问：你没拿过，对吧？ 答：我没有。 问：所以你能就这张照片作证的唯一方法是 因为他们在你准备的时候给你看了？ 霍顿先生：反对，法官大人。 法院：持续。 问：你在政府之前看过这张照片吗 给你看了？ 答：不是。 问：不，对吧？答案是什么？ 答：我从来没见过—— 霍顿先生：反对。 法庭：询问并回答。我们走吧。 问：你以前从未见过，对吧？ 霍顿先生：反对，法官大人。问了还有 回答。 法院：持续。 问：这张照片是在农历新年拍摄的，对吧？
533 O5T1GUO4 Maistrello-Cross 霍顿先生：反对。 法院：你可以回答。如果你知道的话 答：我不知道。 问：看看他们手中的那个红包。那是 农历新年时发出的信封，对吗？ 答：可能是。 问：对。那是传统的姿势，对吧，当你在 在中国文化的长辈面前？ 答：是的。 问：好吧。所以那是一个摆着传统姿势的年轻人变得 他长辈寄来的红包，对吗？ 霍顿先生：反对作证，法官大人。 SHROFF 女士：这是个问题。 法院：你可以回答。 答：你看到的正是你所看到的，所以你会看到两个人坐着 坐在椅子上，另一个人跪下。 问：而且两个人手里都拿着红包，对吧？ 答：他们确实如此。 问：对。你在中国生活了多少年？ 答：五。 问：你会说你对中国人有点熟悉吗 文化？ 答：是的。 问：你能不能告诉我你的经历是什么 中国文化会引导你得出结论
534 O5T1GUO4 Maistrello-Cross 照片。 答：我要说的第一件事是尊重。 问。嗯嗯。 霍顿先生：有问题要问吗？ SHROFF 女士：嗯，她的回答是 “第一个”，所以我 我以为她有第二点。 法庭：你还有什么想说的吗？ 目击者：没有。 问：然后你作证说这位坐在上面的绅士 他——我猜不管是什么姿势，他的——他是什么 顺便问一下，美国名字？ A. Wayne。 问：好吧。而且你作证说韦恩正在和郭先生约会 女儿；对吗？ 答：现在，我不知道。 问：好吧，当你加入就业圈时，他是 约会，你说郭先生的女儿，对吗？ 答：是的。 问：而且他确实在公司工作过，对吗？ 答：在一段时间内，是的。 问：他画了—— SHROFF 女士：你可以把它记下来。谢谢。 问：你作证说他画画、搬运家具然后做了所有事情 杂工的种类，对吗？ 答：在2018年，是的。
535 O5T1GUO4 Maistrello-Cross 问：对。那么 2019 年呢？ 答：他回学校了。 问：对。还有他在哪里上学；你知道吗？ 答：我不记得了。 问：你还记得是不是巴鲁克学院吗？ 答：我不记得了。 问：你还记得他在学什么吗？ 霍顿先生：反对，法官大人。 法庭：如果你记得他的话，你可以回答 正在学习。 答：我不记得了。 问：他对你很有礼貌，对吗？ 答：他是。 问：他开车送郭先生四处走动，对吗？ 答：正确。 问：当郭先生开车四处走动时，可以公平地说吗 总会有两辆车？ 答：不是。 问：不是？你能不能为其中任何一个描述一下——你能描述一下吗 对于陪审团来说，他所在的汽车会是什么样子 开车四处走动？ 答：有几辆车。 问：而且他们每个人都有有色眼镜，对吗？ 答：不是每一个。 问：不是每一个。好吧。而当他开车四处走动时，你
536 O5T1GUO4 Maistrello-Cross 说他有两支球队，对吧？根据你的说法，他有一个 中国安全小组和美国安全小组；那是 你的证词？ 答：是的。 问：在你的证词中，你真正想到的是你的证词 观点，那根本不是一个安全小组，对吗？ 答：没错。 问：好吧。那么让我们从美国队开始，好吗？ 你知道美国队有多少人吗？ 答：数量各不相同，因为人们来来去去。 问：所以你不知道。 答：可能只有两个，最多六个—— 问：你不知道是否有前纽约警察局员工， 正确？ 答：我知道。 问：你确实知道。 答：我知道。 问：好吧。还有多少是前纽约警察局员工？ 答：所有这些。 问：他们都是前纽约警察局员工，对吗？ 答：是的。 问：让我们转到你所说的中国队吧。而你 你说他离他们更近，对吗？ 答：是的。 问：那个人英语不流利，对吧？
537 O5T1GUO4 Maistrello-Cross 答：他变得流利了。 问：真的。你认为郭先生在 2018 年英语说得流利吗？ 答：不是 2018 年。 问：2019年怎么样？ 答：好多了。 问：好多了，对吧？而且你在宣誓时声称 他从 2018 年不说英语变成了 2019 年的流利程度？ 霍顿先生：反对，法官大人。 法院：持续。 问：当他和你说话时，他用普通话和你说话， 正确？ 答：是的。 问：尽管你会说双语，但他从来没有说过英语， 正确？ 答：他从来没有对我说过英语。 问：对。当他和女儿说话时，女儿也在说话 英语，他说的是普通话，对吗？ 答：没错。 问：当他和妻子说话时，他说的是普通话，对吗？ 答：是的。 问：当他收到英语消息时，他会来找你 然后播放它们然后叫你翻译，对吗？ 答：是的。 问：他不知道怎么发电子邮件，对吗？ 答：我不知道。
538 O5T1GUO4 Maistrello-Cross 问：总的来说，你有没有收到过这个人发来的单封电子邮件 你为他工作了多少时间？ 答：不是。 问：当他和周围的人说话时，他说话 中国人，对吧？ 答：他对中国人说中文。 问：你之所以被聘为翻译，是因为他 没说英语，对吗？ 答：在2018年，是的，没错。 问：根据你的说法，你继续为他工作 2019 年的翻译，对吗？ 答：没错。 问：好吧。现在你还作证了关于一个人的证词，不是吗 叫威廉·杰？我发音正确吗？ 答：是的。 问：好吧。而且你喜欢 William Je，对吧？ 答：我做到了。 问：你和他的工作关系很好，对吧？ 答：他在身边的次数不多，但是每当他在办公室时， 是的。 问：你喜欢和他说话，对吧？ 答：是的。 问：然后他和你说话了，对吗？ 答：是的。 问：他是邀请你加入某个董事会的人，
539 O5T1GUO4 Maistrello-Cross 正确？ 答：是的。 问：郭先生没有邀请你，对吧？ 答：没错。 问：好吧。而且 Je 先生是那个和你谈过什么的人 你会在黑板上做，对吗？ 答：是的。 问：而且你有一个选择，你本可以加入董事会， 正确？ 答：正确。 问：或者你可以告诉他然后说，哎呀，我不是 感兴趣，对吗？ 答：没错。 问：好吧。然后你决定 William Je 的提议听起来像是 你很感兴趣所以你接受了然后你加入了董事会， 正确？ 答：是的。 问：好吧。Je 先生没告诉你他想让你做什么 董事会，对吗？ 答：他简短地提到了投资，但仅此而已 那个。 问：好吧。而且他没有告诉你任何关于 投资，对吗？ 答：他没有。 问：他没有告诉你它们是什么类型的投资，
540 O5T1GUO4 Maistrello-Cross 正确？ 答：没错。 问：他不知道这些投资是否来自阿布 扎比，对吗？ 答：不是特别的，没错。 问：你不知道投资额是否达到数十亿美元 美元；根据你的说法，你什么都不知道，对吗？ 霍顿先生：反对。 法院：持续。 问：你知道投资额是否达到数十亿美元吗 美元？ 答：我不知道。 问：然后你决定无论如何都要加入董事会， 正确？ 答：没错。 问：好吧。而且 William Je 确实给别人发了邮件，对吧，不一样 郭先生？ 答：你能重复这个问题吗。 问：当然。William Je 通过电子邮件询问了他的问题，对吧？ 霍顿先生：从对象到形态。 法庭：他给你发过电子邮件吗？ 答：有可能。 问：嗯，你知道他的电子邮件地址，对吧？ 答：是的。 问：好吧。你没有给他发电子邮件也没有问他任何有关的问题
541 O5T1GUO4 Maistrello-Cross 在这个董事会任职，对吧？ 答：不是。 问：好吧。然后你决定继续前进 在董事会任职，对吧？ 答：是的。 问：好吧。也是你决定不想的唯一原因 在董事会任职是因为那家公司被民事起诉了， 正确？ 答：我当时没有意识到这一点。 问：对。但是一旦你意识到我就出局了 对吧？ 答：我听到了一些东西，所以我没有细节，但是我 听见了——如果你想称他们为谣言。 问：对。当你听到的时候，你想出去，对吧？ 答：没错。 问：好吧。没人阻止你离开，对 董事会？ 答：没有人这样做。 问：没人说你必须坚持下去，对吗？ 答：没错。 问：不是伊平，对吗？ 答：没错。 问：不是 Guo，对吧？ 答：对。 问：当然不是 William Je，对吧？
542 O5T1GUO4 Maistrello-Cross 答：没错。 问：好吧。没错，你继续在 Golden 工作 春天？ 答：之后—— 问：辞去董事会职务，你继续工作，对吧？ 答：是的。 问：退出董事会不会产生任何影响，对吧？ 答：没错。 问：好吧。现在你作证说你对此负有责任 法治基金会，对吗？ 答：我曾是总裁兼财务主管。 问：对不起？ 答：我曾是法治协会的主席兼财务主管。 问：好吧。那法治基金会呢，还是你 可以互换使用它们？ 答：不是。那是一个独立的实体。 问：那么让我们来谈谈法治基金会，好吗？对于 他们，你去过法国吗？ 答：不是——所以我去了法国，但不是为了法治 基金会。 问：那你是为谁旅行的？ 答：我去旅行是因为 Boss 让我去。 问：郭先生让你这么做。 答：正确。 问：而且他没有让你一个人去旅行，对吧？
543 O5T1GUO4 Maistrello-Cross 答：我并不孤单。 问：对。组建了一整支队伍， 正确？ 答：是的。是的。 问：好吧。组建的团队由你组成， 对，我猜因为你会说几种语言， 正确？ 答：是的，我就是其中之一。 问：对。顺便说一句，那支队伍里还有谁？ 答：还有另外四个人。 问：好吧。 答：另外四名保安人员。 问：另外四个保安人员；你会这样描述吗 他们？ 答：我们就是这样称呼他们的。 问：你就是这么叫他们的，对吧？ 答：四位同事。 问：对。而且这些都是经验丰富的前纽约警察局官员， 正确？ 答：他们是前纽约警察局官员。 问：你知道他们不是经验丰富的纽约警察局官员吗？ 答：我无法判断他们是否有经验。 问：好吧，你和他们谈过，对，据你直接说 证词？ 答：我做到了。
544 O5T1GUO4 Maistrello-Cross 问：对。然后他们向你讲述了他们作为纽约警察局的经历 警官，对吗？ 答：有时候。 问：对。然后他们告诉你他们在一起时做了什么 纽约警察局，对吗？ 答：他们说了一些话。 问：对。然后他们告诉你他们是调查员 纽约警察局，对吗？ 霍顿先生：反对。 法院：驳回。你可以回答。 答：我相信其中一些人是侦探。我不记得了 他们的确切标题。 问：这些侦探陪同你去法国旅行， 正确？ 答：我们一起去了。 问：对。那这次法国之行是为了什么？ 答：因此，在夏天，即2018年7月，一名中国公民死亡 在法国。老板郭先生认为这不是 意外；他认为自己可能被谋杀了。所以 他让我们去那里看看发生了什么。 问：郭先生还以为自己被中共谋杀了， 正确？ 答：是的。 问：好吧。然后你去了这次调查之旅，对吗？ 答：是的。
545 O5T1GUO4 Maistrello-Cross 问：你，四名侦探，然后你去了法国然后你 在法国见过律师，对吗？ 霍顿先生：反对。401。 法院：你可以回答。 答：我不记得了。 问：你不记得那个法国律师了吗？ 答：我不重复—— 霍顿先生：反对。 SHROFF 女士：对不起。我没听见。 霍顿先生：反对。有人问了这个问题 并回答。 法院：持续。 问：对这个问题进行了全面调查 这个人是不是被杀了，对吗？ 霍顿先生：对表格提出异议。 法庭：请你加紧努力。 （下一页继续）
546 O5T1GUO4 Maistrello-Cross （在侧边栏上） SHROFF 女士：对不起，法官大人。我有 今天听证会有点麻烦，所以我会道歉的。 我真是。 法院：没必要道歉。 我们为什么在法国？ SHROFF 女士：我想她能听见我的声音。 谢谢。 法庭：好吧。所以—— SHROFF 女士：我想我们在法国是因为她说 法治基金会和社会没有做任何工作，所以我是 试图证明他们确实有效。他们调查了死亡事件 他们认为有人被中共杀害，所以 真相将被告知世界。这就是为什么。然后她拿了 这次旅行。她在旅途中翻译。而且我很漂亮 当然 —— 而且席里克先生可以加入 —— 政府是 打算介绍一段关于这个主题的完整视频。 SCHIRICK 先生：嗯，这是班农的视频。 霍顿先生：那么争论的问题在于 荣誉，是因为她没有作证 —— 她没有作证这个 此行是在法治的主持下进行的。那是 他们想确立的主张，但事实并非如此。 还有关于这次旅行的一切，我们所有的细节 听见，是传闻。 法庭：你有没有问过她有没有去
547 O5T1GUO4 Maistrello-Cross 与法治基金会有关吗？ SHROFF 女士：我问她是否 —— 我敢肯定我 做到了，我问她谁付了钱，她说郭迈尔斯付了钱。 无论如何，无论是法治基金会还是 郭文贵付了钱。我不会介绍任何关于这是否是这样 人被谋杀或不被谋杀。我真的不在乎这个 旅行。没有传闻问题。而且我不是在问 她发表的任何声明。我在问她到底在干什么 在法国做过。那是——所以—— 法院：如果你主张的是法治 基金会在法国开展工作—— 施罗夫女士：郭先生还在法国工作。 郭先生的兴趣在于他有能力证明这一点 中共在世界范围内的所作所为是有问题的，郭先生工作了 朝着这个方向前进。没关系—— 法院：因此，这些都是郭先生的良好行为。 SHROFF 女士：不，不好。不好。不错是 非物质的。 对不起。来吧。 SCHIRICK 先生：法官大人，事实叙述是 这项调查是在《规则》成立之前进行的 法律基金会，正是他们开始的工作 在那段发布视频中谈到了政府 昨天被引入证据，辩方应该是 能够争辩说郭先生利用自己的资源，使用
548 O5T1GUO4 Maistrello-Cross 金泉的资源，开启了法治工作 基金会甚至在成立之前。这就是它的用途。 这与法治的起源故事有关—— 霍顿先生：法官大人，如果可以的话。我是—— 困惑，我认为陪审团可能也是。我听说了 Shroff 女士在侧边栏的开头说这是一个 法治调查仅此而已—— SHROFF 女士：那是法治—— 霍顿先生：对不起，施罗夫女士。我没有 打断你。 我听见 Shroff 女士在侧栏开头说过 说这是一项法治调查然后我才听说 席里克说，它早于法治。这很令人困惑。 陪审团会对为什么要作证感到困惑 被引诱的。我认为这足以成为不引起它的理由。 SHROFF 女士：法官大人，这是前言 —— 正如他所说， 前任，前任迈向形成法则的步骤 法律基金会。这是第一步。 法院：因此，法治基金会曾经成立 成立，他们做了什么与之有关的事情吗 在法国调查？ SCHIRICK 先生：那是 Bannon 视频的主题 哪个是启动——发布规则的公告 法律。这是一种直接的事实联系。他们谈论这件事 大量出现在政府发布的班农视频中
549 O5T1GUO4 Maistrello-Cross 证据。 法庭：但是他们做了什么吗？ SHROFF 女士：他们进行了调查。然后 他们公布了他们认为由此发生的事情 他们的调查结果。我真的—— 法院：所以你是在法院成立之后说的 法治基金会，开展了与 法国的调查；这是你的陈述？ SHROFF 女士：我不是这么说的。不是——那里 是——我不会称之为法国的调查。我是什么 我的意思是，这家伙被谋杀了。郭先生自己拿了钱 开始了这项调查，结果是 这项调查，它演变为建立 他们在起诉书中声称的法治基金会是 这是敲诈企业的重要组成部分 成立的实体除了为了骗钱之外没有其他原因，而且 我们想展示的是，它是这样开始的，这是 法治是如何发展的，还做了什么。这是一个 自然进步。这也是因为他们在放 在班农先生的视频中—— 法庭：班农先生有没有这么说法治 基金会正在开展与此有关的工作 在法国调查？ KAMARAJU 先生：是的。 SCHIRICK 先生：是的。
550 O5T1GUO4 Maistrello-Cross KAMARAJU 先生：但是，法官大人，证人也是 直接作证说为启动而采取的准备措施 法治。这就是为什么他们在有那个的时候就激发了它 讨论，以引出她关于郭先生的说法 据说，我们将需要一亿美元。 再说一遍，他们已经准备好了。这个 完成了叙事。 霍顿先生：首先，她的证词是她 根据以下规定，在9月份进行了这项准备工作 表示，此事件的两种表示形式之一 早于法治，并不是说它最初是这样开始的 这是一项法治调查。但我觉得更多 从根本上讲，这是一起欺诈案而且现在就要发生了 因为他之前有这笔钱，所以他用过这个 调查是为了好好调查一起谋杀案。 SHROFF 女士：效果不好。 KAMARAJU 先生：对不起。这不是欺诈案而是欺诈案 在他们的坚持下，这是一起敲诈勒索的案件。法官已经到了 法官大人一审驳回了他们的动议时对此作出了裁决 阻止辩方谈论任何积极的方面 这些组织的活动。根据RICO法律，他们有 以证明连续性，以及该组织是否合法 企业，那么对连续性的测试就不同了。所以在 不管从法律上讲，这些机构有 合法的起源故事，之后有合法的生意
551 O5T1GUO4 Maistrello-Cross 与敲诈勒索指控直接相关 政府选择带来。 SHROFF 女士：不是—— 芬克尔先生：法官大人，我可以回应一下吗。充其量， 可能有一个问题，施罗夫女士已经问过这个问题了 询问她是否去法国参加某项活动， 但看来，施罗夫女士正在努力做的是获得 深入了解有关谋杀某人的调查的细节 谁与其中所指控的任何内容完全无关 起诉书，那件事发生在欧洲。所以我认为我们已经很远了 不知道整个审判的剧情是怎么回事。而且 而以下活动可能有证明的目的 要么早于法治，要么是法治的一部分，根据 顺便说一句，这位证人说这不在法治之下。但是在 不管怎样，法官大人，这已经被引出来了，而且是 是时候继续前进了。这就是我们的论点。 法庭：你还想揭露什么？ SHROFF 女士：其实我完全忘记了 这个问题。我不记得这个问题了。我是 坦率地告诉你。 但再说一遍，我们要展示的问题是 政府收取费用的企业。我们不在乎是否 不管这个人是不是被谋杀了没人在乎。对吧？而且—— 芬克尔先生：那为什么要问这个问题呢？ SHROFF 女士：因为你指控过 —— 你能帮我吗
552 O5T1GUO4 Maistrello-Cross 在这里。对不起。 芬克尔先生：如果他们想问的话，你去旅行了吗 作为法治的一部分去法国，好吧，但是要进入 调查的细节完全遥不可及。 KAMARAJU 先生：首先，他们已经有 介绍了调查的细节；不是我们，是他们。 他们用史蒂夫·班农的视频作为证据。 法庭：史蒂夫·班农的视频，这是怎么回事 要说？ KAMARAJU 先生：史蒂夫·班农的视频，正在播出 通过他们提出的规定，已经有证据了 昨天，说郭文贵发起了这项调查；如 作为那次调查的结果，他们将公布 那次调查的结果；他们要去追查 为中共提供支持的金融机构，那就是 法治基金会使命的一部分。那是 为什么它开始了。他们可以说这不是证据。 法官大人他们承认了 芬克尔先生：那不是我们的论点。 KAMARAJU 先生：等等。这不是重点。 不管是不是你的论点，我们都有争论 另外，我们的论点是，法治基金会是一个 合法的企业有合法的起点，它有一个 合法目的，它有合法的运作。如果我们 法官大人可以证明这会改变他们的负担
553 O5T1GUO4 Maistrello-Cross 法庭：但是我想理解的是： 你现在到底想带出什么？ KAMARAJU 先生：施罗夫女士。 我想很简单 —— 法官大人，我想很简单 这是一项真正的尝试；这位证人进行了真正的努力， 他们去调查了，这是真的，确实如此 由郭先生和企业，即那个企业资助 最终形成了法治基金会。这部作品 先做的事情变成了法治的工作 基金会。 法庭：所以—— SHROFF 女士：这个怎么样，法官大人。也许我可以 回答这个问题。郭先生资助了这次旅行；郭先生资助了这次旅行 调查。而这是... 的前身 设立法治基金会。那些怎么样 三个问题？ 芬克尔先生：她没有任何个人知识。 SHROFF 女士：如果她不这样做，那么她可以说不。 法庭：如果她不知道，她可以说不。 他们有诚意的依据来问这个问题，所以我是 会允许这个问题的。 HORTON 先生：如果我能再说一句话，你的 荣誉。 法院：是的。还有一件事。 霍顿先生：我只想澄清一下这个问题
554 O5T1GUO4 Maistrello-Cross 接近一个 —— 它与被问到的非常接近 答案是：这是通过法治完成的吗？所以 如果有问题差不多要问她 再试一次，本质上，我们会反对这个问题 并回答。 KAMARAJU 先生：但这不一样。 SHROFF 女士：确实我们应该停止被问到 并回答了异议。这样做不会伤害陪审团 听我说，法官大人。 法庭：好吧。好吧。我们走吧。 （下一页继续）
555 O5T1GUO4 Maistrello-Cross （在公开法庭上） 法庭：来吧。 作者：SHROFF 女士： 问：郭先生资助了这次旅行，对吗？ 答：他做到了。 问：好吧。旅行之后是法治的开始 基金会，对吗？ 答：没错。 问：好吧。我们称之为法治基金会 通俗地说是一个非政府组织，对吗？ 答：它是一个非营利组织。 问：好吧。而且你曾经是法则的重要组成部分 法律基金会的努力，对吗？ 答：法治协会和基金会，是的。 问：好吧。作为责任的一部分，你是 参与了法治的启动；对吗？ 答：正确。 问：对。还有几次会议是这样举行的 应该如何宣布法治基金会，对吗？ 答：是的。 问：已经起草了议程，对吗？ 答：我记不起来了。 问：好吧。有会议，对吗？ 答：有。 问：然后人们讨论了实现这个的最佳方法是什么
556 O5T1GUO4 Maistrello-Cross 向前，对吧？ 答：是的。 问：谁参与了这些会议；你知道吗？ 答：通常每当他在 Boss、Steve Bannon、William 时都是他 在纽约，伊平在场。 问：还有谁在场？ 答：我当时在场。 问：所有会议你都在场吗？ 答：其中大多数。 问：其中大多数。但是有些会议是你参加的 我们根本不知情，对吗？ 答：如果他们开了个我不知道的会议，那我——我 不知道。 问：对。但是有人讨论谁会参加 什么会议，而你却被排除在一些会议之外， 正确？ 答：我不知道。 问：好吧。足够公平。 你还说过史蒂夫·班农在场 其中一些会议，对吧？ 答：是的。 问：可以公平地说，班农先生是一个有争议的人物，对吗？ 霍顿先生：反对，法官大人。 法院：你可以回答。 答：你所说的有争议是什么意思？
557 O5T1GUO4 Maistrello-Cross 问：你知道吗？足够公平。 SHROFF 女士：法官大人，我会继续前进的。 问：史蒂夫·班农参与了这些会议，对吗？ 答：是的。 问：史蒂夫·班农的立场不错，至少在中国问题上是如此 公开，对吗？ 答：确实如此。 问：对。无论如何你都明白史蒂夫·班农的意思 这个人遇到的其他问题，他是反对中共的， 正确？ 霍顿先生：反对，法官大人。 法院：驳回。你可以回答。 答：他声称自己是反对中共的。 问：对。而且他直言不讳地说自己反对这一事实 中共，对吗？ 答：他分享了自己的观点。 问：好吧。还有，你这样说公平吗？——你不相信吗 他对中共的看法？ 答：我——我从来没这么说过。 问：不是。我在问你。你听起来好像不相信 他是反共党的。你相信他是反共的吗？ 答：我只知道他说了什么，他说他反对。 问：好吧。所以你从表面上看待他是反共的， 正确？ 霍顿先生：反对，法官大人。
558 O5T1GUO4 Maistrello-Cross 法院：持续。 问：班农先生是这些对话的重要组成部分 至于如何启动法治基金会，对吗？ 答：是的。 问：好吧。而且 Yvette 是其中的一部分，对吗？ 答：是的。 问：讨论的一部分是法治的项目 基金会会承担，对吗？ 答：一开始，不是。 问：好吧。你告诉我。当时讨论了什么 开始？ 答：一开始，所以从 2018 年 7 月到 11 月 2018 年，很多讨论都围绕着发生的事情 法国以及中共涉嫌或可能参与其中 发生了什么。 问：对。然后有 —— 有很多 关于中共是否参与谋杀的讨论 在法国，但随后它继续发展并开始了法治 基金会，对吗？ 答：那是在十一月。 问：对。 答：是的。 问：11月有人讨论是否——至于 法治基金会将以什么为目标及其 目标，对吗？
559 O5T1GUO4 Maistrello-Cross 答：是的。 问：好吧。还有目标和宗旨——请你更正 如果我错了我——是为了帮助那些受害者，所以 说说中共吧？ 答：没错。 问：那个房间里的所有人都同意，对，中共是 一个与中华人民共和国非常分离的实体， 正确？ 霍顿先生：反对，法官大人。 法院：持续。目前尚不清楚她是否可以 说出该团体的信念。 问：好吧。好吧，你相信，不是吗，中共是 和中国人民有很大的不同，对吗？ 答：是的。 问：好吧。目标是帮助中国人民，对吧？ 答：没错。 问：对。以及中国人民现在是否生活在 美国或其他地方，目标是帮助持不同政见者 也一样，对吗？ 霍顿先生：反对，法官大人。 法院：驳回。你可以回答。 答：是的。 问：目标是确保他们感到支持，对吗？ 答：是的。 问：还有一部分——部分支持系统将涉及
560 O5T1GUO4 Maistrello-Cross 帮助他们申请庇护，对吗？ 答：还有。 问：对。在他们无法说话时帮助他们导航 语言，对吗？ 答：我记不起这点了。 问：好吧。好吧，你告诉我。你在那里。所以你告诉我 法治的宗旨和目标是什么 基金会。 答：你说的一切都是正确的，所以目标和使命 法治协会和基金会旨在帮助中国人民 以各种形式。从法律的角度来看，可能是 帮忙——他们只是需要——还有——对不起—— 对公众进行关于中国的教育。 问：好吧。还有关于如何教育的提案 人们知道中国发生了什么，对吗？ 答：是的。 问：好吧。还有一些提案被接受了，还有一些 提案被拒绝了，对吗？ 答：所有这些都被拒绝了。 问：好吧，你们都被拒绝了。 答：不是我的具体情况，而是提出的提案。 问：对不起。你的证词是，有史以来提出的每一项提议 因为法治基金会被拒绝了？ 答：当我在那里的时候，是的。 问：好吧。所以会有董事会会议，对吗？
561 O5T1GUO4 答：是的，2020年1月有一次董事会会议。 问：好吧。你参加了那次董事会会议，对吗？ 答：是的。 问：而且你没有记下那次董事会会议的任何笔记；是 那是真的吗？ 答：不是。其他人做到了。 问：其他人记下了那次董事会的会议记录。你 没拿走它们，对吗？ 答：没错。 问：好吧。而且—— 法庭：我们要到此为止。现在是 2:45。 所以陪审团成员记住你不是 允许你们彼此或与任何人讨论此案 否则。不要允许任何人在你的网站上讨论这个案子 存在。 请像前几次一样准时回来 好几天，这样你就可以在 9:30 直接穿过那扇门 而且我们可以准时开始。 晚上好。 法律书记员：陪审团退出。 法庭：不要讨论你的证词。 （陪审团不在场） 法庭：我们明天会回来参加 继续对迈斯特雷洛女士进行盘问。有没有 在我们休息之前有什么？
562 O5T1GUO4 KAMARAJU 先生：不是来自我们，法官大人。 FERGENSON 先生：没有什么是我们无法接受的 早上好，法官大人 法院：那就好了。谢谢。再见 明天。 所有法律顾问：谢谢你，法官大人。 （延期至 2024 年 5 月 30 日上午 9:00）
563 考试索引 考试：页面 周乐 353Cross By Kamaraju 先生。。。。 406重定向作者：Murray 女士。....... 410Recross 作者：Kamaraju 先生。。。。 卡琳·迈斯特雷洛 420Direct 作者：霍顿先生。。。。。 485Cross By Shroff 女士。。。。。
564 政府展品 展品编号已收到 VO-33 359......... SM62 448........... 102 425.......... 103 460........... 105 463.......... 110 449.......... 130 427........... 141 423.......... UK723 433.......... UK728 453......... BR871 429......................... 被告证物 展品编号已收到 60476 382........................ Stip 0001 405..............