Court Case Documents

Miles Guo

Case 1:23-cr-00118-AT

• • Doc 294 PROTECTIVE ORDER as to Ho Wan Kwok, Yanping Wang…regarding procedures to be followed that shall govern the handling of confidential material… The Court GRANTS the Government’s motion for a protective order. The Government is authorized to withhold the classified materials identified with particularity in its motion. The Government shall produce to defense counsel the proposed substitutions described herein and in the Court’s ex parte orders. The Government’s CIPA submissions are hereby sealed, and shall remain preserved in the custody of the Classified Information Security Officer, in accordance with established court security procedures, until further order of this Court.
  • 293 SEALED DOCUMENT placed in vault
  • Doc 292 DECLARATION of Brendan F. Quigley in Opposition as to Yanping Wang re: 273 MOTION in Limine
    • • •  292-1 Exhibit 1
        •  292-2 Exhibit 2
        •  292-3 Exhibit 3
  • Doc 291 MEMORANDUM in Opposition by Yanping Wang re 273 MOTION in Limine
  • Doc 290 MEMORANDUM in Opposition by USA as to Ho Wan Kwok, Kin Ming Je, Yanping Wang re 266 MOTION in Limine ., 269 MOTION in Limine ., 272 MOTION to Exclude Testimony of Defendant’s Expert Witnesses
  • Doc 289 DECLARATION of Matthew S. Barkan in Opposition as to Ho Wan Kwok re: 273 MOTION in Limine ., 272 MOTION to Exclude Testimony of Defendant’s Expert Witnesses
    • • •  289-1 Exhibit A – 2019-11-20 Wall Street Journal Article
        • 289-2 Exhibit B-J – FILED UNDER SEAL 密封提交
        •  289-3 Exhibit K – Easton Disclosure
        •  289-4 Exhibit L – Seru Disclosure
        •  289-5 Exhibit M – US v Phillips Disclosures
        •  289-6 Exhibit N – Wedeman Disclosure
  • Doc 288 MEMORANDUM in Opposition by Ho Wan Kwok re 272 MOTION to Exclude Testimony of Defendant’s Expert Witnesses
  • Doc 287 MEMORANDUM in Opposition by Ho Wan Kwok re 273 MOTION in Limine
  • Doc 286 Response in Opposition by USA as to Yanping Wang re: 196 Motion to Suppress. MOTION for Bill of Particulars. MOTION to Sever Defendant. MOTION to Dismiss.. Response to Defendant Wang’s Post-Hearing Submission
  • Doc 285 Letter Response in Support of Motion by Yanping Wang re: 196 MOTION to Suppress. MOTION for Bill of Particulars. MOTION to Sever Defendant. MOTION to Dismiss
  • Doc 284 Memo Endorsement as to Ho Wan Kwok By Judge Torres
  • Doc 283 Letter by USA as to Ho Wan Kwok  re: Reply to Kwok’s April 14, 2024 Letter (Dkt. 282)
  • Doc 282 Letter by Ho Wan Kwok re: Response to DOJ Submissions Regarding Kwok’s Rule 17 Application
    • • • 282-1 Exhibit 1 – Filed Under Seal 密封提交
        • 282-2 Exhibit 2 – Filed Under Seal 密封提交
        •  282-3 Exhibit 3 – Saipov Letter
        •  282-4 Exhibit 4 – Perryman Letter
  • Doc 281 Consent Motion to Adjourn April 16, 2024 deadline by one day for all parties.. Document filed by Ho Wan Kwok. / (中文)
  • Doc 280 Motion to Adjourn April 16, 2024 deadline by one day. Filed by Ho Wan Kwok / (中文)
  • Doc 279 Letter by USA as to Yanping Wang re: Post-Hearing Opposition to Defendant Yanping Wang’s Suppression Motion
  • Doc 278 Response in Support of Motion by Yanping Wang re: 196 MOTION to Suppress 
  • Doc 277 Order as to Ho Wan Kwok and Yanping Wang: Jury Selection Schedule / (中文)
  • Doc 276 Letter by USA as to Ho Wan Kwok  re: Response to Kwok’s Rule 17 Application / (中文)
  • Doc 275 Order as to Ho Wan Kwok and Yanping Wang / (中文)
  • Doc 274 Sealed Document 密封提交
  • Doc 273 Motion in Limine Filed by USA as to Ho Wan Kwok, Yanping Wang
    • • •  273-1 Exhibit A – Miller Declaration
        •  273-2 Exhibit B – GTV PPM
        •  273-3 Exhibit C – Farm Loan Agreement
        •  273-4 Exhibit D – GCLUBS Document
        •  273-5 Exhibit E – HDO Whitepaper
        •  273-6 Exhibit F – Bank Records
  • Doc 272 Motion to Exclude Testimony of Defendant’s Expert Witnesses Filed by USA as to Ho Wan Kwok
    • • •  272-1 Exhibit Notice of Maggie Sklar
        •  272-2 Exhibit Notice of Paul Doran
        •  272-3 Exhibit Notice of Thomas Bishop
        •  272-4 Exhibit Notice of Raymond Dragon
  • Doc 271 Memorandum in Support by Ho Wan Kwok re 269 Motion in Limine
  • Doc 270 Declaration of Sidhardha Kamaraju in Support as to Ho Wan Kwok re: 269 Motion in Limine / (中文)
    • • •  270-1 Exhibit A – Excerpts of 3-22-2022 Bankruptcy Transcript
        •  270-2 Exhibit B-C – Filed Under Seal
        •  270-3 Exhibit D – Prof Shams Rule 16 Disclosure
  • Doc 269 Motion in Limine by Ho Wan Kwok. / (中文)
  • Doc 268 Declaration of Brendan F. Quigley in Support as to Yanping Wang re: 266 Motion in Limine / (中文)
    • • •  268-1 Exhibit A
        •  268-2 Exhibit B
        •  268-3 Exhibit C
        •  268-4 Exhibit D
        • 268-5 Exhibit E
        • 268-6 Exhibit F
        • 268-7 Exhibit G
• Doc 267 Memorandum in Support by Yanping Wang re 266 Motion in Limine / (中文)
• Doc 266 Motion in Limine by Yanping Wang. / (中文)
• Doc 265 Joint Letter by USA as to Kwok and Wang re: Proposed Verdict Form / (中文)
  • • •  265-1 Exhibit, Proposed Verdict Form / (中文)
• Doc 264 Request to Charge by USA as to Kwok and Wang
• Doc 263 Proposed Examination of Jurors by USA as to Kwok and Wang / (中文)
• Doc 262 Order as to Yanping Wang re: Suppression Hearing / (中文)
• Doc 261 Letter by USA re: April 9 Suppression Hearing / (中文) 
• Doc 260 Letter by Yanping Wang re: Response to the Governments March 31, 2024 Letter / (中文)
  • • •  260-1 Exhibit A Email Conversation / (中文)
      •  260-2 Exhibit B, Filed Under Seal 
      •  260-3 Exhibit C, Filed Under Seal 
      •  260-4 Exhibit D, Filed Under Seal 
      • 260-5  Exhibit E , Filed Under Seal 
      • 260-6 Exhibit F, Filed Under Seal 
      • 260-7 Exhibit G, Filed Under Seal 
      • 260-8 Exhibit H Proposed Order / (中文)
• Doc 259 Letter by Ho Wan Kwok re: Response to Government Letter / (中文)
  • • • 259-1 Exhibit A-D, K – Filed Under Seal
      • 259-2 Exhibit E – US v Jones Indictment / (中文)
      • 259-3 Exhibit F – US v Bilal Indictment
      • 259-4 Exhibit G – US v Garcia Superseding Indictment
      • 259-5 Exhibit H – Jones Protective Order
      • 259-6 Exhibit I – Bilal Protective Order
      • 259-7 Exhibit J – Garcia Protective Order
      • 259-8 Exhibit L – US v Trump Proposed Protective Order
• Doc 258 Order as to Ho Wan Kwok, Yanping Wang: Motion to Dismiss S2 is Denied / (中文)
• Doc 257 Sealed Document
• Doc 256 Order as to Ho Wan Kwok and Yanping Wang / (中文)
• Doc 255 Letter by USA in Response to Dkt 253 and Request for Pretrial Scheduling Order Document filed by USA / (中文)
  • • •  #1 Exhibit A (Proposed Order) / (中文)
      •  #2 Exhibit B (Kwok Attorney List)
      •  #3 Exhibit C (Wang Attorney List)
      •  #4 Exhibit D (Wang Signal Message)
      •  #5 Exhibit E (Wang Signal Message)
      •  #6 Exhibit F (Wang Signal Message)
      •  #7 Exhibit G (Wang Signal Message)
• Doc 254 Order as to Yanping Wang’s Letter Motion in 253 / (中文)
• Doc 253 Letter Motion by Yanping Wang to Request The Courts Assistance Regarding Issues with The Government Discovery / (中文)
• Doc 252 Letter by USA: Filing of Classified Motion Pursuant to Section 4 of CIPA / (中文)
• Doc 251 Order As to Yanping Wang: Motion for a Bill in Particulars is Granted in Part / (中文)
• Doc 250 Order As to Ho Wan Kwok: Renewed Motion to Stay The Bankruptcy Proceedings is Denied / (中文)
• Doc 249 Motion of HEX For Expedited Hearings And Motions For Court Order on Their Motions to Intervene And For Return of Their Property And For Limited Discovery / (中文)
• Doc 248 Sealed Document
• Doc 247 Order As to Himalaya Exchange Customers’ Motion / (中文)
• Doc 246 Letter by Luc A. Despins as to Ho Wan Kwok, Kin Ming Je, Yanping Wang / (中文)
• Doc 245 Memorandum of Law in Further Support of Defendant’s Motion to Dismiss The Superseding Indictment / (中文)
• Doc 244 Sealed Document
• Doc 243 Order as to Kwok’s Motion to Compel (Granted in Part, Denied in Part) / (中文)
• Doc 242 The Government’s Memorandum of Law in Opposition to Defendant Kwok’s Motion to Dismiss / (中文)
• Doc 241 Letter Motion by Yanping Wang to Join Defendant Ho Wan Kwok’s Motion to Dismiss / (中文)
• Doc 240 Memorandum of Law in Support of Defendant’s Motion to Dismiss The Superseding Indictment / (中文)
• Doc 239 Declaration of Sidardha Kamaraju, esq. Accompanying Defendant’s Motion to Dismiss the Superseding Indictment / (中文)
• Doc 238 Notice of Motion to Dismiss The Superseding Indictment / (中文)
• Doc 237 Declaration Sarah Reeves in Further Support of Defendant’s Pre-trial Motions / (中文)
  • •  #1 EXHIBIT A Filed Under Seal / #1 附件 A 密封提交
    • #2 EXHIBIT B Filed Under Seal / #2 附件 B 密封提交
    •  #3 EXHIBIT C Filed Under Seal / #3 附件 C 密封提交
• Doc 236 Reply Memorandum of Law in Further Support of Defendant Yanping Wang’s Pre-trial Motions 
• Doc 235 Ho Wan Kwok’S Reply In Further Support Of His Renewed Motion For A Stay And Motion For Reconsideration / (中文)
• Doc 234 RESPONSE in Opposition by Luc A. Despins as to Ho Wan Kwok
• Doc 233 LETTER by USA as to Ho Wan Kwok addressed to Judge Analisa Torres from AUSA Ryan B. Finkel dated Jan. 19, 2024 / (中文)
• Doc 232 The Government’s Memorandum of Law in Opposition to Defendant Yanping Wang’s Pretrial Motions / (中文)
• Doc 231 Motion Schedule Document Filed by Yanping Wang / (中文)
• Doc 230 Order as to Ho Wan Kwok and Yanping Wang re: 227, 228 / (中文)
• Doc 229 NOTICE of Response to Government Motion as to Ho Wan Kwok, Kin Ming Je, Yanping Wang re: 223 Letter / (中文)
  • • •  #1 Exhibit Exchange letter to customers
      •  #2 Exhibit Exchange letter to customers
      •  #3 Exhibit Exchange letter to customers
      •  Affidavit Customer Declarations
• Doc 228 Government’s Proposed Motions and Trial Schedule / (中文)
• Doc 227 Defendants’ Position on Scheduling for Motion to Dismiss and Trial / (中文)
• Doc 226 Minute Entry for proceedings held before Magistrate Judge Robyn F. Tarnofsky: Arraignment as to Yanping Wang
• Doc 225 Minute Entry for proceedings held before Magistrate Judge Robyn F. Tarnofsky: Arraignment as to Ho Wan Kwok
• Doc 224 Notice Of Attorney Appearance: Sarah Reeves appearing for Yanping Wang / (中文)
• Doc 223 Letter by USA as to Ho Wan Kwok, Kin Ming Je, Yanping Wang / (中文)
• Doc 222 Notice of Appearance of Counsel and Demand for Service of Papers as Interested Party / (中文)
• Doc 221 Order as to Ho Wan Kwok, Kin Ming Je, Yanping Wang / (中文)
• Doc 220 Affirmation of Matthew S. Barkan in Support as to Ho Wan Kwok’s Motion to Stay and Motion for Reconsideration / (中文)
  • • •  Exhibit A Chapter 11, Bankruptcy Document / (中文)
      •  Exhibit B Filed Under Seal
• Doc 219 Memorandum of Law in Support of Defendant’s Renewed Motion For a Stay and Motion for Reconsideration / (中文)
• Doc 218 Motion to Stay Bankruptcy Cases and for Reconsideration / (中文)
• Doc 217 Sealed Document Placed in Vault
• Doc 216 Order as to Ho Wan Kwok’s Renewed Motion For Bail Pending Trial / (中文)
• Doc 215 Superseding Indictment (S2) as to Ho Wan Kwok, Kin Ming Je, Yanping Wang / (中文)
• Doc 214 Reply Affirmation of Matthew S. Barkan in Support as to Ho Wan Kwok re: 170 MOTION to Compel Discovery / (中文)
• Doc 213 Reply Memorandum of Law in Support as to Ho Wan Kwok re: 170 MOTION to Compel Discovery
• Doc 212 Notice of update on number of clients to 5,242 as to Ho Wan Kwok, Kin Ming Je, Yanping Wang (Geyer, Bradford) / (中文)
• Doc 211 Notice of Reply to ECF 202 as to Ho Wan Kwok, Kin Ming Je, Yanping Wang (Geyer, Bradford) / (中文)
• Doc 210 Letter by USA as to Ho Wan Kwok, Kin Ming Je, Yanping Wang addressed to Judge Analisa Torres from USA / (中文)
• Doc 209 Notice of Appendices and 3 of 3 as to Ho Wan Kwok, Kin Ming Je, Yanping Wang
• Doc 208 Notice of Filing Exhibits with Appendices
• Doc 207 Notice of Supplemental Filing as to Ho Wan Kwok, Kin Ming Je, Yanping Wang
• Doc 206 The Clerk Of Court Is Directed To Permanently Seal The Docket Entry At ECF No. 201 / (中文)
• Doc 205 The Government’s Memorandum Of Law In Opposition To The Defendant’s Motion To Compel
• Doc 204 Order As to Ho Wan Kwok / (中文)
• Doc 203 The Government requests a one-week extension of the filing date for its motion / (中文)
• Doc 202 Luc Despins’ letter to Judge Torres of bankruptcy Court / (中文)
• Doc 201 The Government’s Memorandum of Law in Opposition to  The Defendant’s Motion to Compel/ (中文)
• Doc 200 Government’s Letter Motion For One-Week Extension of CIPA Motion Filing Date / (中文)
• Doc 199 Declaration of Brendan F. Quigley in Support of Defendant’s Pre-Trial Motions / (中文)
• Doc 198 Reply of Third Party Customers of The Himalaya Exchange on Their Motion For Return of Property Seized by Complaint Customers / (中文)
• Doc 197 Memorandum of Law in Support of Defendant’s Notice of Pre-Trial Motion Filed by Yanping Wang / (中文)
• Doc 196 Defendant’s Notice of Pre-Trial Motion Filed by Yanping Wang (English) / (中文)
• Doc 195 Memorandum in Support of Defendant’s Motion to Dismiss The Superseding Indictment / (中文)
• Doc 194 Declaration of Sidhardha Kamaraju, esq. Accompanying Defendant’s Motion to Dismiss The Superseding Indictment / (中文)
  • Doc 194-1 Exhibit A – GTV Confidential Information Memorandum
• Doc 193 Motion to Dismiss The Superseding Indictment / (中文)
• Doc 192 Memorandum of Law of The United States of America in Opposition to Defendant Ho Wan Kwok’s Second Motion For Pretrial Release / (中文)
• Doc 191 Ho Wan Kwok’s Reply Memorandum of Law in Further Support of His Renewed Motion For Pretrial Release / (中文)
• Doc 190 Motion Granted For Response to Motion for Return of Property Filed by Luc A. Despins / (中文)
• Doc 189 Response to Motion for Return of Property Filed by Luc A. Despins  / (中文)
• Doc 188 USA’s Letter in Opposition to Motion for Return of Seized Property / (中文)
• Doc 187 The Court is in Receipt of a Motion For Return of Seized Property Filed by “3,345 Customers of the Himalaya Exchange” / (中文)
• Doc 186 Notice of Motion, Memo in Support and Proposed Order Demanding Return of Funds by Customers of Himalaya Exchange as to Ho Wan Kwok, Kin Ming Je, Yanping Wang / (中文)
  • • • Doc 186-1 Memorandum in Support of Motion For Return of Property / (中文)
      • Doc 186-2 Proposed Order / (中文)
• Doc 185 Notice of Appearance of Bradford L. Geyer (pending PHV approval) to represent 3,345 customers of the Himalaya Exchange as to Ho Wan Kwok, Kin Ming Je, Yanping Wang / (中文)
• Doc 184 Notice of Pro Hac Vice Submission by Bradford L Geyer to represent 3,345 customers of the Himalaya Exchange as to Ho Wan Kwok, Kin Ming Je, Yanping Wang / (中文)
• Doc 183 Notice of Jamie Scher Notice of Appearance for 3,345 Customers of Himalaya Exchange as to Ho Wan Kwok, Kin Ming Je, Yanping Wang / (中文)
• Doc 182 Memo Endorsement as to Ho Wan Kwok Granting in Part 180 Letter Motion / (中文)
• Doc 181 Letter Response in Opposition by Ho Wan Kwok addressed to Judge / (中文)
• Doc 180 The Government Letter Motion to Ho Wan Kwok Requesting One-week Extension on Kwok’s Second Motion / (中文)
• Doc 179 Notice Of Appearance And Request For Electronic Notification / (中文）
• Doc 178 Motion for Release from Custody Memorandum in Support of Renewed Motion for Pretrial Release of Ho Wan Kwok / (中文）
• Doc 177 Notice of Renewed Motion For Pretrial Release /(中文)
• Doc 176 Notice of Attorney Appearance: E. Scott Schirick appearing for Ho Wan Kwok /（中文）
• Doc 175 ORDER as to Ho Wan Kwok / (中文)
• Doc 174 Order Establishing Reply Deadlines for Defendant’s Motion to Compel Discovery in United States against Ho Wan Kwok (English) / (中文)
• Doc 172 Memorandum of Law in Support by Ho Wan Kwok’s Motion to Compel Discovery (English) / (中文)
• Doc 171 Declaration of Matthew Barkan Accompanying Defendant’s Motion to Compel Discovery (English) / (中文)
• Doc 170 Notice of Motion to Compel Discovery by Ho Wan Kwok (English) / (中文)
• Doc 163 Defendant Ho Wan Kwok’s Reply in Further Support of His Motion to Compel (English) / (中文)
• Doc 160 Government’s Memorandum of Law in Opposition to Motion to Compel in United States v. Kwok, Je, and Wang (English) / (中文)
  • Doc 160-1 Assistant U.S. Attorney Affirmation on SEC Coordination in United States v. Kwok, Je, and Wang, Exhibit A
  • Doc 160-2 Transcript of Bankruptcy Court Proceedings Involving Ho Wan Kwok and Genever Holdings, Exhibit B
• Doc 156 Granted Adjournment Request for Discovery Motion Deadlines in United States v. Kwok
• Doc 154 Government’s Request for Adjournment of Discovery Deadlines in United States v. Kwok
• Doc 153 Letter in Further Support of Motion to Stay Bankruptcy Proceedings in United States v. Yanping Wang, et al.
• Doc 152 Reply in Further Support of Ho Wan Kwok’s Stay Motion and Response to Government’s Opposition
  • Doc 152-2 Transcript of Bankruptcy Court Proceedings in Case Involving Ho Wan Kwok and Genever Holdings Corporation
  • Doc 152-3 Transcript of Bankruptcy Court Proceedings Against Bravo Luck, Limited and Taurus Fund, LLC in Ho Wan Kwok’s Case
• Doc 151 Sidhardha Kamaraju’s Reply Declaration in Support of Ho Wan Kwok’s Motion to Stay Against Trustee’s, UCC’s, and Sherry’s Opposition
• Doc 150 Defendant Ho Wan Kwok’s Reply to Trustee’s, UCC’s, and Sherry-Netherland’s Opposition to Stay Motion in Bankruptcy Case / (中文)
• Doc 149 The Sherry-Netherland’s Representation Letter in Genever Holdings and Ho Wan Kwok’s Chapter 11 Case
• Doc 148 Government’s Letter Brief in Response to Ho Wan Kwok’s Motion for Bankruptcy Stay and Alternative Requests
• Doc 147 Unsecured Creditors’ Committee Joinder Supporting Trustee’s Opposition to Ho Wan Kwok’s Stay Motion in Bankruptcy
• Doc 146 Nicholas Bassett’s Declaration Supporting the Opposition to Ho Wan Kwok’s Stay Motion in Bankruptcy Cases
• Doc 145 Chapter 11 Trustee and Genever Debtors’ Opposition to Defendant Ho Wan Kwok’s Motion to Stay Bankruptcy Cases
• Doc 143 Memorandum of Law in Support of Defendant Ho Wan Kwok’s Motion to Compel Discovery (English) / (中文)
• Doc 142 Sidhardha Kamaraju’s Sealed Declaration for Discovery Motion in United States v. Ho Wan Kwok
  • Doc 142-1 Bankruptcy Court Proceedings Transcript in Adversary Cases Involving Ho Wan Kwok
  • Doc 142-2 Second Interim Fee Application Cover Sheet for Paul Hastings LLP in Ho Wan Kwok’s Bankruptcy Case No. 22-50073 (JAM)
  • Doc 142-3 Filed Under Seal in Case
  • Doc 142-4 Agent Affidavit for Search Warrant on Electronic Communications in Himalaya Exchange and Google Account Case, Filed Under Seal
  • Doc 142-7 Filed Under Seal in Case
  • Doc 142-8 Filed Under Seal in Case
  • Doc 142-10 Filed Under Seal in Case
  • Doc 142-15 Email on Government Coordination and Discovery Obligations in U.S. v. Kwok, Exhibit 15
• Doc 141 Notice of Motion to Compel Discovery by Ho Wan Kwok / (中文)
• Doc 137 Trustee Luc A. Despins’ Letter on Jurisdiction Matters Regarding Stay Motion in United States v. Ho Wan Kwok, et al. (English) / (中文)
• Doc 136 Defendant Ho Wan Kwok’s Response to Trustee’s Letter Regarding Constitutional Issues in Bankruptcy Cases
• Doc 135 Yanping Wang’s Letter Requesting Joining Stay of Proceedings in United States v. Yanping Wang, et al. (English) / (中文)
• Doc 134 Notice of Appearance by John M. Kilgard for Defendant Ho Wan Kwok
• Doc 133 Appearance of Co-Counsel Sabrina P. Shroff in United States v. Ho Wan Kwok
• Doc 132 Order on Defendant Ho Wan Kwok’s Motion to Stay Bankruptcy Cases (English) / (中文)
• Doc 131 Legal Memorandum for Stay of Bankruptcy Proceedings in United States vs. Ho Wan Kwok (English) / (中文)
• Doc 130 Sidhardha Kamaraju’s Declaration Supporting Motion to Stay Bankruptcy Cases in U.S. vs. Ho Wan Kwok
• Doc 129 Motion for Order to Stay Bankruptcy Cases in Criminal Case Involving Ho Wan Kwok (English) / (中文)
• Doc 126 ORDER 117 LETTER MOTION addressed to Judge Analisa Torres from AUSA Ryan B. Finkel dated July 28, 2023 re: 112 Notice of Attorney Appearance – Defendant, 114 Letter, 113 Letter re: Motion to set Briefing Schedule for Motion to Disqualify Emil Bov as to Yanping Wang.
• Doc 117 LETTER MOTION addressed to Judge Analisa Torres from AUSA Ryan B. Finkel dated July 28, 2023 re: 112 Notice of Attorney Appearance – Defendant, 114 Letter, 113 Letter re: Motion to set Briefing Schedule for Motion to Disqualify Emil Bove as counsel to Yanping Wang
• Doc 115 Government’s Obligations for Brady Material Disclosure in U.S. v. Ho Wan Kwok et al.
• Doc 111 Request for Ex Parte Conference Under CIPA by Ho Wan Kwok’s Counsel (English) / (中文)
• Doc 93 Order Setting Trial Date and Excluding Time Under Speedy Trial Act in U.S. v. Ho Wan Kwok and Yanping Wang
• Doc 89 RESPONSE in Opposition by USA as to Yanping Wang re: 81 MOTION Motion for an Order Revoking the Magistrate Judge’s Order of Detention and Authorizing Pretrial Release
  • Doc 89-1 Exhibit A – Transcript of 4/4/2023 Bail Hearing
  • Doc 89-2 Exhibit B – Bankruptcy Partial Resolution Order re: Ace Decade
  • Doc 89-3 Exhibit C – Bankruptcy Trustee Complaint re: HCHK
  • Doc 89-4 Exhibit D – Bankruptcy Contempt Order
  • Doc 89-5 Exhibit E – Bankruptcy TRO re: HCHK
• Doc 88 Transcript of Court Decision on Trial Dates for Ho Wan Kwok and Yanping Wang, June 6, 2023 – Hearing 06/06/23
• Doc 87 ORDER of USCA (Certified Copy) as to Ho Wan Kwok re: 62 Notice of Appeal – Interlocutory. USCA Case Number 23-6421. Ho Wan Kwok appeals a district court order denying him pre-trial release on the basis that he posed a serious risk of flight and obstruction of justice, that he posed a danger to the community, and that “no condition or combination of conditions [would] reasonably assure the appearance of [Kwok] as required and the safety of any other person and the community[.]” 18 U.S.C. § 3142(e)(1). In reviewing a detention challenge, we examine the district court’s factual determinations for clear error.” United States v. Abuhamra, 389 F.3d 309, 317 (2d Cir. 2004). We will find clear error only where “on the entire evidence we are left with the definite and firm conviction that a mistake has been committed.” United States v. Sabhnani, 493 F.3d 63, 75 (2d Cir. 2007) (internal quotation marks omitted). We cannot say that we are left with a “definite and firm conviction” that the district court erred in determining that Kwok posed a serious risk of flight, obstruction of justice, and danger to the community, and that no conditions would reasonably ensure Kwok’s appearance in court. Accordingly, we AFFIRM the order of the district court. It is further ORDERED that Kwok’s contemporaneously filed “Motion for Relief from Order Denying Pre-Trial Release” is DENIED as unnecessary in view of our order affirming the district court’s decision. Catherine O’Hagan Wolfe, Clerk USCA for the Second Circuit, Clerk USCA. Certified: 6/14/2023.
• Doc 86 ORDER as to Ho Wan Kwok, Yanping Wang: IT IS HEREBY ORDERED that 1. KWOK and WANG may each have access to his or her own “air-gapped” laptop computer (each, the “Laptop”) that is disabled from accessing the internet, local area networks, or other electronic devices; 2. Upon receipt of an acceptable laptop computer from counsel for each defendant, the Government shall (a) ensure that each the laptop is appropriately “air gapped” and compatible with the MDC Brooklyn’s security requirements; (b) load each Laptop with the non-sensitive discove1y in this case; and (c) deliver each Laptop to the proper authorities at the MDC Brooklyn; 3. Each Laptop shall be password-protected and maintained in a location acceptable to Bureau of Prisons personnel; 4. Bureau of Prisons personnel will provide each defendant with access to the Laptop each weekday in the visiting room, Monday to Friday; 5. This Order remains in effect until the trial in this matter is completed and a copy of this Order shall be made available to any unit where KWOK or WANG is housed; 6. Each defendant shall execute an agreement setting forth his or her understanding that he or she may use the Laptop for the sole purpose of reviewing discovery and legal materials that relate to the above-captioned criminal case, that he or she shall not share the Laptop or the materials loaded onto the Laptop with other inmates or with any attorney not appointed to this case without an order of this Court, that he or she will not access or attempt to access the internet or any form of wireless communication, and that he or she will forfeit his or her right under this Order to use the Laptopand that each defendant may expose himself or herself to criminal prosecution for possessing or distributing a prohibited object as that term is defined in 18 U.S.C. § 1791(d) in the futureshould he or she violate any of these understandings; and 7. Within seventy-two hours of MDC Brooklyn’s receipt of each Laptop from the Government, each defendant shall receive access to his or her Laptop subject to the following conditions: a. Upon request to his or her unit, each defendant will be brought to the visiting room during the weekday (with an effort to provide access on a daily basis, if requested); and b. Each defendant shall not have possession of any charging apparatus or cord that connects to the Laptop. SO ORDERED.
• Doc 84 LETTER MOTION addressed to Judge Analisa Torres from Juliana Murray dated 6/13/2023 re: Proposed Order for MDC Laptops
  • Doc 84-1 Text of Proposed Order re: MDC Laptops
• Doc 80 Request for Laptop Access for Ho Wan Kwok at MDC for Discovery Review
• Doc 79 ORDER as to Ho Wan Kwok: It is hereby ORDERED that counsel for Defendant Ho Wan Kwok, as well as any retained investigators and defense expert(s), in the above-captioned action be given access to the Sherry-Netherland Apartment, which is cmTently in the control of the bankruptcy trustee, Luc A. Despins, in In re Ho Wan Kwok, et al., Debtor, Case No. 22-50073 (JAM) (Bankr. D. Conn.), prior to the sale of the prope1iy in order to conduct a non-destructive inspection of the property and to document by video and photographic equipment the property’s current condition. SO ORDERED.
• Doc 78 LETTER RESPONSE to Motion by USA as to Ho Wan Kwok addressed to Judge Analisa Torres from Juliana Murray dated 6/2/2023 re: 72 LETTER MOTION addressed to Judge Analisa Torres from Stephen R. Cook dated May 26, 2023 re: Request for Court Order to Access Property
• Doc 77 MOTION for Natasha M. Ertzbischoff to Appear Pro Hac Vice . Filing fee $ 200.00, receipt number ANYSDC-27818458. Motion and supporting papers to be reviewed by Clerk’s Office staff.
  • Doc 77-1 Affidavit Declaration of Natasha M. Ertzbischoff
  • Doc 77-2 Exhibit A – NY Bar Certificate of Good Standing
  • Doc 77-3 Proposed Order
• Doc 76 NOTICE OF ATTORNEY APPEARANCE: Tiffany Brook Lietz appearing for Ho Wan Kwok. Appearance Type: Retained.
• Doc 75 MEMO ENDORSEMENT as to Yanping Wang on re: 74 LETTER by Yanping Wang addressed to Judge Analisa Torres from Alex Lipman dated May 31, 2023 re: Permission for memorandum to exceed thirty pages. ENDORSEMENT: GRANTED.
• Doc 74 LETTER by Yanping Wang addressed to Judge Analisa Torres from Alex Lipman dated May 31, 2023 re: Permission for memorandum to exceed thirty pages
• Doc 73 ORDER as to Ho Wan Kwok: The Court has reviewed Defendant’s letter dated May 26, 2023. ECF No. 71
• Doc 71 LETTER MOTION addressed to Judge Analisa Torres from Stephen R. Cook dated May 26, 2023 re: Request for Court Order to Access Property . Document filed by Ho Wan Kwok as to Ho Wan Kwok, Kin Ming Je, Yanping Wang.
  • Doc 71-1 Exhibit A – 4/20/23 Bankruptcy Order
  • Doc 71-2 Text of Proposed Order Proposed Order
• Doc 69 ORDER as to Yanping Wang. The Court has reviewed the parties letters dated April 27 and May 11, 2023. ECF Nos. 59, 67. Defendant’s request for a court order requiring Pretrial Services to provide certain information is GRANTED in part, and DENIED in part.
• Doc 63 Protective Order for Discovery in United States vs. Ho Wan Kwok and Others
• Doc 62 Notice of Appeal by Ho Wan Kwok Against Denial of Release Pending Trial
• Doc 59 LETTER by Yanping Wang as to Ho Wan Kwok, Kin Ming Je, Yanping Wang addressed to Judge Analisa Torres from Priya Chaudhry dated April 27, 2023 re: Request for Court Order for Pretrial Services Information
• Doc 57 TRANSCRIPT of Proceedings as to Yanping Wang re: Hearing held on 4/4/2023 before Magistrate Judge Robert W. Lehrburger.
• Doc 55 MEMO ENDORSEMENT as to Ho Wan Kwok, Kin Ming Je, Yanping Wang re: 52 Letter Relevant Legal Framework under the Classified Information Procedures Act… ENDORSEMENT: GRANTED. SO ORDERED.
• Doc 54 MEMO ENDORSEMENT as to Ho Wan Kwok, Kin Ming Je, Yanping Wang re: 49 LETTER MOTION Motion for Protective Order… ENDORSEMENT: By April 28, 2023, Defendants shall file their response, if any, to the Government’s proposed protective order, explaining which portions of the proposed order Defendants object to, the reason for the objection, and Defendants’ proposed alternative. SO ORDERED.
• Doc 53 Joint Letter on Discovery Timeline and Protective Order in U.S. v. Kwok et al. (English) / (中文)
• Doc 52 Government’s Letter on CIPA Framework and Motion Schedule in U.S. v. Ho Wan Kwok et al.
• Doc 51 District Court Order on Charges Against Ho Wan Kwok (English) / (中文)
• Doc 50 Supplement to Ho Wan Kwok’s Bail Application Concerning UAE Citizenship Surrender
  • Doc 50-1 Complaint and Affidavit in Support of Application for Arrest Warrants in United States against Bai YunPeng, Chen Zhichen, Gao CaiNan and Others, Exhibit A
  • Doc 50-2 Victor X. Cerda’s Declaration on Ho Wan Kwok’s UAE Citizenship and Passport Surrender, Exhibit B
• Doc 49 Government’s Request for Protective Order in Discovery of U.S. v. Ho Wan Kwok et al.
  • Doc 49-1 [Proposed] Protective Order Regarding Discovery Material in U.S. v. Ho Wan Kwok et al.
• Doc 48 RESPONSE in Support of Motion by Yanping Wang re: 8 MOTION for Bond Determination that Bond Conditions Have Been Met
• Doc 47 Clarification on Evidence Recovery in Yanping Wang’s Bail Application in U.S. v. Yanping Wang
• Doc 45 Bail Hearing Transcript for Ho Wan Kwok and Yanping Wang – Hearing 04/04/23
• Doc 43 Government’s Letter on Status of Yanping Wang’s Bank Accounts in United States v. Yanping Wang
• Doc 41 MOTION requesting permission from the Court for Mr. Kwok’s counsel to bring Personal Electronic Devices and General Purpose Computing Devices into the Courthouse for the duration of the case
  • Doc 41-1 Text of Proposed Order Proposed Order re Use of Electronics
• Doc 40 ORDER as to Yanping Wang: In light of the Court’s order today, and as requested by the Government via call to Chambers, the Government may include its response concerning Defendant’s submission of proposed security from financially responsible persons in the Government’s response to the order due April 12, 2023
• Doc 39 Court Order for Follow-Up Information on Bail Hearing in United States v. Yanping Wang
• Doc 38 Government’s Forfeiture Bill of Particulars in United States v. Ho Wan Kwok et al.
• Doc 36 Government’s Request for Scheduling and Exclusion of Time Under the Speedy Trial Act
• Doc 35 Appointment of Classified Information Security Officer for United States v. Ho Wan Kwok, et al.
• Doc 31 TRANSCRIPT of Proceedings as to Yanping Wang re: Hearing held on 3/31/2023 before Magistrate Judge Robert W. Lehrburger.
• Doc 29 Order Confirming Government’s Disclosure Obligations in United States v. YanPing Wang
• Doc 27 LETTER by Yanping Wang as to Ho Wan Kwok, Kin Ming Je, Yanping Wang addressed to Judge Analisa Torres from Priya Chaudhry dated April 4, 2023 re: Clarifying Government’s Misstatements
• Doc 26 Government Opposition to Ho Wan Kwok’s Pretrial Release Memorandum
  • Doc 26-1 Cash found in Mahwah mansion
  • Doc 26-2 A copy of Ho Wan Kwok’s expired United Arab Emirates passport
  • Doc 26-3 A cellphone that was found underneath Kwok’s mattress
  • Doc 26-4 Gold pins with symbols of the Chinese Communist Party
  • Doc 26-5 Ho Wan Kwok’s expired Republic of Vanuatu Passport and Vanuatu non-citizen identification card
  • Doc 26-6 Communication on Ho Wan Kwok’s Legal Call Restrictions
  • Doc 26-7 Bankruptcy Court Order Granting Preliminary Injunction on Assets
• Doc 25 Government Update to Judge Torres on Pretrial Release Proceedings for Yanping Wang in U.S. v. Yanping Wang
• Doc 24 Ho Wan Kwok’s Memorandum for Bail Application (English) / (中文)
  • Doc 24-1 Warden’s Memorandum on Planned Lockdown and Safety Measures at MDC Brooklyn
• Doc 23 Notice of Motion for Ho Wan Kwok’s Release on Bail Pending Trial
• Doc 22 Government’s Supplemental Opposition to Bail Conditions Compliance by Yanping Wang
  • Doc 22-1 Exhibit A
• Doc 19 Indictment of United States v. Ho Wan Kwok, Kin Ming Je, and Yanping Wang (English) / (中文)
• Doc 16 MOTION for Stephen A. Best to Appear Pro Hac Vice . Filing fee $ 200.00, receipt number ANYSDC-27525141. Motion and supporting papers to be reviewed by Clerk’s Office staff. Document filed by Ho Wan Kwok.
  • Doc 16-1 Affidavit Declaration of Stephen A. Best
  • Doc 16-2 Exhibit A – VA Bar Certificate of Good Standing
  • Doc 16-3 Exhibit B – DC Bar Certificate of Good Standing
  • Doc 16-4 Text of Proposed Order Proposed Order
• Doc 14 United States v. Ho Wan Kwok Court Transcript – Hearing 03/15/23 (English) / (中文)
• Doc 12 MOTION for Stephen R. Cook to Appear Pro Hac Vice . Filing fee $ 200.00, receipt number NYSDC-27503417. Motion and supporting papers to be reviewed by Clerk’s Office staff. Document filed by Ho Wan Kwok as to Ho Wan Kwok, Kin Ming Je.
  • Doc 12-1 Affidavit Declaration of Stephen R. Cook in Support of Motion for Admission Pro Hac Vice
  • Doc 12-2 Exhibit A – CA Bar Certificate of Good Standing
  • Doc 12-3 Exhibit B – DC Bar Certificate of Good Standing
  • Doc 12-4 Text of Proposed Order Proposed Order
• Doc 11 Court Order on Victim Notification Procedures in United States v. Ho Wan Kwok and Kin Ming Je (English) / (中文)
• Doc 10 Government Motion for Victim Notification Procedures in United States v. Ho Wan Kwok and Kin Ming Je (English) / (中文)
  • Doc 10-1 Order Establishing Victim Notification Procedures in United States v. Ho Wan Kwok and Kin Ming Je (English) / (中文)
• Doc 9 Order Confirming Government’s Disclosure Obligations in United States v. Ho Wan Kwok
• Doc 9 MEMORANDUM in Support by Yanping Wang re 8 MOTION for Bond Determination that Bond Conditions Have Been Met
  • Doc 9-1 Exhibit Exhibit Index
  • Doc 9-2 Exhibit A (Redacted)
  • Doc 9-3 Exhibit B (Redacted)
  • Doc 9-4 Exhibit C (Redacted)
  • Doc 9-5 Exhibit D (Redacted)
  • Doc 9-6 Exhibit E (Redacted)
  • Doc 9-7 Exhibit F (Redacted)
  • Doc 9-8 Exhibit G (Redacted)
  • Doc 9-9 Exhibit H (Redacted)
• Doc 8 Minute Entry for proceedings held before Magistrate Judge Katharine H. Parker
• Doc 7 Government’s Request for Pretrial Detention on Charges of Billion-Dollar Fraud and Money Laundering Against Ho Wan Kwok (English) / (中文)
• Doc 6 ORDER as to Ho Wan Kwok, Kin Ming Je for the limited unsealing of this matter. (Signed by Magistrate Judge Gabriel W. Gorenstein on 3/7/23)
• Doc 4 Notice of Pretrial Conference for United States v. Ho Wan Kwok (中文)
• Doc 3 Order to Unseal Indictment as to Sealed Defendant 1, Sealed Defendant 2. (Signed by Magistrate Judge Katharine H. Parker on 3/14/23)
• Doc 2 SEALED INDICTMENT as to Sealed Defendant 1
• Doc 1 United States v. Ho Wan Kwok Indictment (English) / (中文)
• Doc 1 COMPLAINT as to Yanping Wang (1). (Signed by Magistrate Judge Gabriel W. Gorenstein)

Case 1:23-cv-02200

• Doc 46 SEC’s Request to Continue Service and Investigation During Stay in SEC v. Ho Wan Kwok, et al.
• Doc 44 Government’s Request to Stay SEC Civil Action Pending Outcome of Parallel Criminal Case in United States v. Ho Wan Kwok et al.
• Doc 35 Affidavit of Service for Summons and Complaint
• Doc 34 Waiver of Service of Summons by G Club Operations LLC in SEC v. Kwok et al.
• Doc 4 Notice of Pretrial Conference in SEC v. Kwok et al. (English) / (中文)
• Doc 3 Civil Cover Sheet for SEC v. Kwok et al.
• Doc 2 Appearance of Counsel by Daniel Loss for the SEC
• Doc 1 SEC Complaint Against Ho Wan Kwok and Associates for Securities Violations (English) / (中文)
• SEC released (English) / (中文)

Case 2:23-06421

• Doc 36 (English) / (中文)
• Doc 1 Filed 05/05/23 (English) / (中文)
• Oral Argument (English) / (中文)