`
`Case 1:23-cr-00118-AT
`
`Document595_
`
`Filed 04/04/25
`
`Page 1of57
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`UNITED STATES DISTRICT COURT
`SOUTHERN DISTRICT OF NEW YORK
`i ee x
`
`UNITED STATES OF AMERICA
`
`- y, -
`
`HO WAN KWOK,
`a/k/a “Miles Guo," a/k/a "Miles Kwok,"a/k/a
`"Guo Wengui," a/k/a "Brother Seven," a/k/a "The
`Principal,"
`
`KIN MINGJE, a/k/a “WilliamJe," and
`
`YANPING WANG,a/k/a "Yvette,"
`
`Defendants.
`wee eee eee ee eee ee eee ee x
`
`PETITION UNDERFED. R.
`CRIM. P. 32.2 AND 21
`ULS.C, § 853(n) FOR
`ADJUDICATION OF
`PETITIONER’S RIGHT TO
`SPECIFIC PROPERTY OF
`$467,680.00
`
`23 CR 118 (AT)
`
`L CHUN LIN (the “Petitioner”), appearing pro se, pursuant to 21 U.S.C. § 853(n) and Rule
`
`32.2(c) of the Federal Rules of Criminal Procedure, herby respectfully petitions the Court for a
`
`determination of the Petitioner’s interest in specific property subject to the Court’s Consent
`
`Preliminary Order of Forfeiture as to Specific Property/Money Judgment, signed by Your Honor
`
`on January 6, 2025, Court Case Number 23 CR. 118 (AT), (the “Forfeiture Order”) which includes
`
`various bank accounts, and real and personal properties (“Forfeited Accounts’),
`
`to exclude all
`
`property in whichthe Petitionerhas right, title, and interest, namely, a sum of $467,680.00, or four
`
`hundred sixty-seven thousand six hundred eighty United States Dollars (the “Property”). This sum
`
`comprises of $302,680.00 (three hundred two thousand six hundred eighty USD) in G|CLUBS
`
`Page | of 9
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`

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`Case 1:23-cr-00118-AT Document595_Filed 04/04/25 Page 2 of 57
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`and/or related entities (the “G Clubs Investments”), $150,000.00 (one hundred fifty thousand
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`USD) in Hamilton Opportunity Fund SPC and/orrelated entities (the “Hamilton Investment”), and
`
`$15,000.00 (fifteen thousand USD) in H Coin from Himalaya Exchange via Himalaya Farm,
`
`and/orrelated entities (the “H Coin Investment”). In support hereof, Petitioner states as follows:
`
`I. Background
`
`1. From 2021-2022, Ho Wan Kwok, Kin Ming Je, and Yanping Wang (the “Defendants”) and/or
`
`their associates solicited the Petitioner to invest in their various ventures andentities.
`
`2. Overthis time period, Petitioner invested a total of $467,680.00 (four hundred sixty-seven
`
`thousand six hundred eighty USD), in good faith and unbeknownst of any unlawfulintents,
`
`into three of the various investment vehicles offered by the Defendants: G|CLUBS, Hamilton
`
`Opportunity Fund SPC, and H Coin.
`
`3. On January 7, 2025, Your Honor
`
`signed the Order of Forfeiture as
`
`to Specific
`
`Property/Money Judgment, forfeiting all the assets in the Forfeited Accounts.
`
`4. The Forfeited Accounts contained all of the funds invested by the Petitioner as listed above.
`
`5. For the reasons to follow, Petitioner is seeking the total return of her investment of
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`$467,680.00 USD.
`
`II. G Clubs Investments
`
`6.
`
`In 2021, the Petitioner was solicited, by the Defendants and/or their associates, to invest in
`
`G|CLUBS.
`
`7. Petitioner was promised, by the Defendants and/or their associates,
`
`to receive lucrative
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`financial returns, exclusive membership benefits, and other incentives.
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`Page 2 of 9
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`Case 1:23-cr-00118-AT Document595_Filed 04/04/25 Page 3of 57
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`As a result of these claims and promises, the Petitioner invested a total of $302,680.00 (three
`
`hundred two thousand six hundred eighty USD) towards G|CLUBS, as described below.
`
`On or about March 22, 2021, Petitioner invested $50,000.00 USD through a personal
`
`intermediary. (Wire receipt attached hereto as Exhibit “A”). On March 25 and 26,
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`the
`
`personal
`
`intermediary forwarded this $50,000.00 to G|CLUBS via two wire transfers of
`
`$25,000.00 USD, one on each day, under the Order Number HT2103231204291. (Bank
`
`statement attached hereto as Exhibit “B”)
`
`10.
`
`On or about April 23, 2021, Petitioner invested $50,100.00 USD via a Bank of America
`
`personal check dated April 8, 2021 under the Order Number AG2104030731431. (Bank
`
`statement and check image attached hereto as Exhibit “C’”)
`
`Il.
`
`On or about September 29, 2021, Petitioner invested $50,080.00 USD via a Bank of America
`
`personal check dated August 3, 2021 under the Order Number GK2107290250181. (Bank
`
`statement and check image attached hereto as Exhibit “D’’)
`
`12.
`
`On or about October 13, 2021, Petitioner invested $150,000.00 USD via a Bank of America
`
`personal check dated September 18, 2021 under the Order Number ZS2109180957351. (Bank
`
`statement and check imageattached hereto as Exhibit “D”’)
`
`13.
`
`On or about April 22, 2022, Petitioner invested $2,500.00 USD via a Bank of America
`
`personal check dated April 17, 2022. (Bank statement and check image attached hereto as
`
`Exhibit “E”)
`
`14.
`
`The total amount transferred to GICLUBS is $302,680.00 (three hundred two thousand six
`
`hundred eighty USD). Uponinformationandbelief, these funds were transferred into Account
`
`Number MBI10103-000 at Mercantile Bank International, held in the name of “G Club
`
`International Ltd.” and seized by the Government on or about October 16, 2022 (23-FBI-
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`Page 3 of 9
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`Case 1:23-cr-00118-AT
`
`Document595_
`
`Filed 04/04/25
`
`Page 4of57
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`000287), or another related account held at Mercantile Bank International, as well as among
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`other assets of the Forfeited Accounts.
`
`15.
`
`Petitioner never received any funds, investment, material benefit, or equivalence back from
`
`Defendants or any other party, and suffers a loss of $302,680.00 USD in G|CLUBS and/or
`
`related entities.
`
`16.
`
`Petitioner was not involved in, nor was aware of the the commission of the acts which gave
`
`rise to the forfeiture of the Forfeited Accounts under 21 U.S.C. § 853.
`
`17.
`
`Petitioner was not consulted prior to the entry of the Forfeiture Order. Petitioner had no
`
`knowledge that Defendant Wang consented to forfeit the Property.
`
`18.
`
`Petitioner has a superior and/or vested legal right, title, or interest in the G Clubs Investments
`
`under 21 U.S.C. § 853(n)(6)(A) as an investor and shareholder, which Defendant Wang had
`
`no authority to agree to forfeit, and which renders the Forfeiture Orderinvalid in part.
`
`19,
`
`In the alternative, Petitioner is a bona fide purchaser for value of her interest in the G Clubs
`
`Investments under 21 U.S.C. § 853(n)(6)(B), and was at the time of purchase reasonably
`
`without cause to believe that the property was subject to forfeiture, as she provided the G
`
`Clubs Investments to the Defendants underfalse and fraudulent pretenses.
`
`20,
`
`In the alternative, Petitioner is a victim of the Defendants, having been deprived of her G
`
`Clubs Investments through unlawfully means, andis entitled to their return.
`
`al,
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`Petitioner is entitled under law to have her G Clubs Investments excluded from the Forfeited
`
`Accounts and returned to her custody.
`
`Ill. Hamilton Investment
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`22.
`
`In 2022, the Petitioner was solicited, by the Defendants and/or their associates, to invest in
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`Page 4 of 9
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`Case 1:23-cr-00118-AT
`
`Document595_
`
`Filed 04/04/25
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`Page 5of 57
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`Hamiiton Opportunity Fund SPC,a/k/a Hamilton M&A Fund.
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`23.
`
`Petitioner was promised, by the Defendants and/or their associates,
`
`to receive lucrative
`
`financial returns and other incentives.
`
`24.
`
`As a result of these claims and promises, the Petitioner invested a total of $150,000.00 (one
`
`hundredfifty thousand USD) towards Hamilton Opportunity Fund SPC, as described below.
`
`25.
`
`On or about March 29, 2022, Petitioner invested $150,000.00 USD via wire transfer to the
`
`recipient “Hamilton Opportunity Fund SPC” with the recipient Account Number 5090042770
`
`held at Silvergate Bank. (Wire receipt and statement attached hereto as Exhibit “F’”)
`
`26,
`
`This transfer was facilitated by David Fallon, and receipt was confirmed by Nikhar Garg,
`
`both employees of Hamilton Investment Management Ltd, an entity responsible for managing
`
`subscriptions to the Hamilton Opportunity Fund SPC, via E-mail communication with
`
`Petitioner. (E-mail! attached hereto as Exhibit “G”)
`
`27.
`
`The total amount transferred to Hamilton Opportunity Fund SPC is $150,000.00 USD. Upon
`
`information and belief, these funds were transferred into account number 5090042770 at
`
`Silvergate Bank, held in the name of "Hamilton Opportunity Fund SPC" and seized by the
`
`Government on or about September 18, 2022 (23-FBI-000074), as well as among otherassets
`
`of the Forfeited Accounts.
`
`28.
`
`Petitioner never received any funds, investment, material benefit, or equivalence back from
`
`Defendants or any other party, and suffers a loss of $150,000.00 USD in her Hamilton
`
`Investment.
`
`29,
`
`Petitioner was not involved in, nor was aware of the the commission of the acts which gave
`
`rise to the forfeiture of the Forfeited Accounts under 21 U.S.C. § 853.
`
`30.
`
`Petitioner was not consulted prior to the entry of the Forfeiture Order. Petitioner had no
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`Page 5 of 9
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`Case 1:23-cr-00118-AT Document595_Filed 04/04/25 Page 6 of 57
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`knowledge that Defendant Wang consented to forfeit the Property.
`
`31.
`
`Petitioner has a superior and/orvested legal right, title, or interest in the Hamilton Investment
`
`under 21 U.S.C. § 853(n)(6)(A) as an investor and shareholder, which Defendant Wang had
`
`no authority to agree to forfeit, and which renders the Forfeiture Order invalid in part.
`
`32.
`
`In the alternative, Petitioner is a bona fide purchaser for value of herinterest in the Hamilton
`
`Investment under 21 U.S.C. § 853(n)(6)(B), and was at the time of purchase reasonably
`
`without cause to believe that the property was subject to forfeiture, as she provided the
`
`Hamilton Investment to the Defendants underfalse and fraudulent pretenses.
`
`33.
`
`In the alternative, Petitioner is a victim of the Defendants, having been deprived of her
`
`Hamilton Investment through unlawfully means, andis entitled to its return.
`
`34,
`
`Petitioner is entitled under law to have her Hamilton Investment excluded from the Forfeited
`
`Accounts and returned to her custody.
`
`IV. H Coin Investment
`
`35,
`
`In 2021, the Petitioner was solicited, by the Defendants and/or their associates, to invest in H
`
`Coins from Himalaya Exchange via Himalaya Farm.
`
`36.
`
`In March 2021, Petitioner was told by Defendants and/or their associates that if she makes an
`
`immediate cash deposit, she will earn an exclusive right to purchase a cryptocurrency, H
`
`Coins, at a heavily discountedprice. Petitioner was made to believe that the value of H Coins
`
`will skyrocket in a few years.
`
`37.
`
`As a result of these claims and promises, the Petitioner invested a total of $15,000.00 (fifteen
`
`thousand USD) towards H Coins, as described below.
`
`38.
`
`On or about March 22, 2021, Petitioner wired $15,000.00 USD to a personal intermediary.
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`Page 6 of 9
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`Case 1:23-cr-00118-AT
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`Document595-_
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`Filed 04/04/25
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`Page 7 of 57
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`(Wire receipt and statement attached hereto as Exhibit “H’”’), This intermediary then on March
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`23 forwarded this amount to a recipient operating as “Wonderhome DecorInc.” as instructed
`
`by the Defendants and/or their associates. (Bank statement attached hereto as Exhibit “B”)
`
`39.
`
`On or about October 22, 2021, Petitioner entered into a contract with UK Himalaya Ltd to
`
`apparently convert this $15,000.00 USD investmentinto an undetermined amount of H Coins
`
`for $0.10 per unit. (Contract attached hereto as Exhibit “J’’)
`
`40.
`
`The total amount transferred to purchase H Coins is $15,000.00 USD. Upon information and
`
`belief, these funds were transferred into Forfeited Accounts at FV Bank and/or Mercantile
`
`Bank International belonging to entities associated with Himalaya Exchange and/or H Coins,
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`as well as among otherassets of the Forfeited Accounts.
`
`41,
`
`Petitioner never received access to the H Coins that she purportedly purchased.Petitioner has
`
`never been ableto sell or otherwise trade her H Coins.
`
`42,
`
`Petitioner never received any funds, investment, material benefit, or equivalence back from
`
`Defendants or any other party, and suffers a loss of $15,000.00 USD in H Coins, Himalaya
`
`Exchange, Himalaya Farm, and/or related entities.
`
`43.
`
`Petitioner was not invelved in, nor was aware of the the commission of the acts which gave
`
`rise to the forfeiture of the Forfeited Accounts under 21 U.S.C. § 853.
`
`44,
`
`Petitioner was not consulted prior to the entry of the Forfeiture Order. Petitioner had no
`
`knowledge that Defendant Wang consented to forfeit the Property.
`
`45.
`
`Petitioner has a superior and/or vested legal right, title, or interest in the H Coin Investment
`
`under 21 U.S.C. § 853(n)(6)(A) as an investor and shareholder, which Defendant Wang had
`
`no authority to agree to forfeit, and which renders the Forfeiture Order invalid in part.
`
`46.
`
`In the alternative, Petitioner is a bona fide purchaser for value of herinterest in the H Coin
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`Page 7 of 9
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`Case 1:23-cr-00118-AT
`
`Document595_
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`Filed 04/04/25
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`Page 8 of 57
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`Investment under 21 U.S.C. § 853(n)(6)(B), and was at the time of purchase reasonably
`
`without cause to believe that the property was subject to forfeiture, as she provided the H
`
`Coin Investment to the Defendants underfalse and fraudulent pretenses.
`
`47. In the alternative, Petitioner is a victim of the Defendants, having been deprived of her H
`
`Coin Investment through unlawfully means, andis entitled to its return.
`
`48. Petitioner is entitled under law to have her H Coin Investment excluded from the Forfeited
`
`Accounts and returned to her custody.
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`V. Petition for Relief
`
`49, In sum,Petitioner has invested a total of $467,680 USD into the Defendants’ various ventures,
`
`summarized as follows:
`
`
`
`
`-
`
`
`
`
`
`
`
`ExhibitNumber(s)
`‘Manner ofTransfer
`Amount
`-
`Investment
`;
`|
`A,B
`$50,000.00 Wire transfer
`1 |GicLUuBS
`Cc
`~ $50,100.00]
`Personal check
`-
`2 |GicLUBS
`D
`$50,080.00!
`Personal check |
`3 |GICLUBS _ _ “|
`D>
`$150,000.00]
`Personalcheck
`4
`|GICLUBS
`—
`EB
`$2,500.00]Personalcheck
`5
`|GICLUBS
`-
`E G
`~$150,000.00
`Wiretransfer |
`: 6 Hamilton Opportunity FundSPC
`$15,000.00
`Wiretransfer fp i, B, I
`. 7 HCoins / Himalaya Exchange
`;
`1s
`a
`s+ eaerapo-o0) = -
`
`
`
`
`
`
`
`50. Petitioner was made aware of the Order of Forfeiture by viewing it at www.forfeiture.gov
`
`(which was published from February 6, 2025 through March 7, 2025) noting that: “Any
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`person, other than the defendant(s) in this case, claiming interest in the forfeited property
`
`must file an ancillary petition within 60 daysof the first date of publication (February 06,
`
`2025) of this Notice”.
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`Page 8 of 9
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`Case 1:23-cr-00118-AT
`
`Document595_
`
`Filed 04/04/25
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`Page 9of 57
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`51. Petitioner has filed this petition in a timely manner.
`
`WHEREFORE,Petitioner respectfully requests and petitions this Court:
`
`a)
`
`to amend the Forfeiture Order toe exclude the Property of $467,680.00 USD,or a portion thereof
`
`as the Court deems just and proper, in which Petitioner has a right, title, and interest as an
`
`innocentthird party, superior interest, and/or a bona fide purchaserfor value, and to return the
`
`b)
`
`c)
`
`d)
`
`excluded amountto the Petitioner's custody;
`
`for a hearing pursuant to 21 U.S.C. § 853(n) on any disputed matters;
`
`in the alternative, and in the event that this Petition is denied, Petitioner hereby respectfully
`
`asserts a claim for compensation forher interest in the Property;
`
`in the alternative, and in the event that this Petition is denied, Petitioner hereby respectfully
`
`movesthis Court to be granted restitution and/or paymentof the Property through the remission
`
`process;
`
`€)
`
`for such other and furtherrelief as the Court deems just and proper.
`
`Dated:
`
`March 31, 2025
`
`Respectfully Submitted,
`
`Chun Lin
`
`Petitioner
`
`(267) 979-3503
`
`Page 9 of 9
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`

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`Case 1:23-cr-00118-AT Document595_Filed 04/04/25 Page 10 of 57
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`VERIFICATION
`
`I attest and declare under penalty of perjury that my petition is not frivolous and the information
`provided in support of mypetition is true and correct to the best of my knowledge andbelief.
`
`aa
`
`%
`
`ow iv
`
`Chun Lin
`
`Executed on March 31, 2025 in Coquitlam, British Columbia, Canada
`
`

`

`
`
`Case 1:23-cr-00118-AT Document595_Filed 04/04/25 Page 11 of 57
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`Exhibit “A”
`
`

`

`|j
`;3
`
`Case 1:23-cr-00118-AT Document595_Filed 04/04/25 Page 12 of 57 Page | of |
`
`ROYAL BANK OF CANADA
`CZ
`ROYAL FUNDS TRANSFER
`
`2021 MAR 20
`
`
`
`COQUITLAM BC-COMO LAKE VILLAGE
`
`Branch Ref No...
`ICN. cece eee ee
`
`61240-21079-199998
`From
`
`Value Date.....
`Send Ref....
`
`2021 MAR 22
`
`|
`
`Payment AMOUNC. cree eee eee eS
`Client Rate........ teenies
`Conversion Amount...... aed
`Wire Payment Fee Sep Dr
`$
`Not Present Fee......e.00es $
`IBAN F@@.
`i ccc ete ee eee $
`Total Fe@S. .ccee eee ewes +2728
`Client Pays (Princ)........ $
`Sender Pays (Fees}......... $
`
`Ordering Customer:
`CHUN LIN
`
`50,200.00 USD Charges For... Sender
`1.00000000
`Serial No.....
`
`45.00 CAD
`0,00 CAD
`0.00 CAD
`45.00 CAD
`50,200.00 USD
`45.00 CAD
`
`SRF Client No. 92629
`
`Remittance Information:
`BANK ADRESS 875 SAW MILL RIVER RD
`ARDSLEY,NEW YORK
`
`COQUITLAM BC-COQUITLAM TWN CTR
`Debit Branch Name (Princ)..
`JOINT-OR ...00004-01260 452-277-7
`Debit Branch Name {Fees}...
`BURNABY BC-MAIN BR=-BURNABY
`06880 505-397-0
`
`Account
`
`Intermediary Institution:
`
`Account With Institution:
`FED ABA 021000021
`( ABA 0210 00021 )
`JPMORGAN CHASE BANK, NA
`JPMCHASE
`NEW YORK
`
`Beneficiary Account: M208
`
`Beneficiary Customer:
`TANG
`
`Sender To Receis€
`
`Instruction Code:
`
`from the payment amount by the receiving bank and/or its
`Additional charges may be deducted
`his payment cannot be completed for any reasons beyond the
`intermediaries ("Receiving Bank"). If t
`you may ask RBC for a refund and RBC shall make best efforts
`control of Royal Bank of Canada ("RBC")
`to secure a refund from Receiving Bank and return those amounts to you. If conversion of funds is
`the rate of exchange will be RBC's rate established at the time the refund is converted.
`requested,
`If you need to make an inquiry regarding this payment or if you ask that RBC attempt to amend or
`cancel this payment, additional charges will apply (except
`in cases where an error has been
`established on the part of RBC or the Receiving Bank}. RBC may,
`in its discretion and without notice
`to you, delay in making the payment or decide not proceed with the payment,
`in which case RBC shall
`refund of the payment amount and any applicable fees.
`RBC will not be responsible for any loss or damage suffered by you except where there has been
`negligence on the part of RBC, and in any such case RBC wili not be liable for any indirect,
`consequential or exemplary damages (including but not limited to loss of profits),
`regardless of the
`cause of action.
`In making the payment, your personal or business information and information on the
`recipient, may be revealed to third parties. Since the payment will travel,
`the information related
`to it will be subject to the laws of the jurisdiction in which the information is located or
`processed at that time.
`
`SIGNATURE(S):
`
`

`

`
`
`Case 1:23-cr-00118-AT Document595_Filed 04/04/25 Page 13 of 57
`
`
`
`Exhibit “B”
`
`

`

`Case 1:23-cr-00118-AT Document 595
`
`Filed 04/04/25
`
`Page 14 of 57
`
`
`
`
`
`March 04, 20214 through April 05, 2021
`Account Number:
`SS208
`
`eS
`
`CUSTOMER SERVICE INFORMATION
`
`Website:
`Service Center:
`Deaf and Hard of Hearing:
`Para Espanol
`international Calls:
`
`Chase.com
`1-800-935-9935
`1-800-242-7383
`1-877-312-4273
`1-713-262-1679
`
`CHASE&
`JPMorgan Chase Bank, N.A.
`P © Box 182051
`Columbus, OH 49218 - 2051
`
`00169888 DRE 802 219 09621 NNNNNNNNNNN 1 a00000000 63 G000
`
`JE TANG
`
`ae
`
`e
`
`CHECKING SUMMARY
`
`Chase Total Checking
`
`
`Beginning Balance
`Deposits and Additions
`Electronic Withdrawals
`Fees
`Ending Balance
`
`$1
`135
`-130
`
`AMOUNT
`
`954.64
`
`504.99
`919.41
`-155.00
`
`$6
`
`,385.22
`
`TRANSACTION DETAIL
`
`
`
`DATE
`
`AMOUNT
`
`BALANCE
`DESCRIPTION
`Beginning Balance
`$1,954.64
`
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`
`Page 1 of 4
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`

`

`
`
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`Case 1:23-cr-00118-AT Document595_Filed 04/04/25 Page 15 of 57
`
`/
`C HAS E ~‘s
`
`March 04, 2021 through April 05, 2027
`
`Account Number: [iIG208
`
`
`
`TRANSACTION DETAIL|_“o7nue?)
`DATE
`DESCHIPTION
`
`AMOUNT
`
`BALANCE
`
`Book Transfer Credit B/O: Royal Bank of Canada Payment Centertoronto
`On Canada M5V2Y-1 CA Org:/012604522777 Chun Lin Ret: Bank Adress
`875 Saw Mill River Rd Ardsley,New York/Chgs/USDO,/Chgs/USD
`20,00/Ocmt/USD50200,/ Trn: 1535807082Fs
`Fedwire Credit Via: Bank of America, N.A./026009593 B/O: Mrs ChunLin
`Port Moody, BC, CA Ref: Chase Nyc/Ctr/Bni=J3 Tang
`US/Ac-000000 602006 Rib=T021032289046900 Obi=Hel Ping
`With Property Purchase Bbi=/Ch Gs/USD10,00/Bnf/Up Morgan Chase Ban K
`National A Ssoc875 Saw Mill Riv Imad: 0323B6B/Hut ROO3664 Trn:
`oO= ano3©3anM al
`
`m7 ||
`eee | P|
`03/23
`03/23 Online Domestic Wire Transfer A/C: Wonderhome Decor Inc. Houston
`-15,000.00
`70,240,32
`TX 77054-3163 US Ref: Uk2020N514 Trn: 3354291082Es
`70,215.32
`-25.00
`Online Domestic Wire Fee
`03/23
`70,200.32
`-15.00
`Domestic Incoming Wire Fee
`03/23
`70,185.32
`-15.00
`International Incoming Wire Fee
`03/23
`| 7 P|
`Eee
`7 P|
`03/25
`03/25 Online Domestic Wire Transfer Via: Capital One NA/021 407912
`-25,000.00
`45,410.32
`A/G:/Fw211170363 Branford CT 06405 US Ben: Bsi Group LLC Des Plaines
`IL 60018 US Ref: Mbi 0000100102785809198 Gclub
`
`Gclubht2 103231204291 Imad: 0325B1Qgc03C005141 Trn: 3008151084Es
`
`03/25
`Online Domestic Wire Fee
`-25.00
`45,385.32
`03/26
`03/26 Online Domestic Wire Transfer Via: Capital One NA/021407912 A/C:
`-25,000.00
`20,385, 32
`Aba/211170363 Richmond VA US Ben: Bsi Group LLC Des Plaines IL
`60018 US Ref: Mbi 0000100102785809198 Gclub Gelubhi2 103231204291
`
`Imad: 0326B1Qgc05CG06266 Trn: 31389821085Es
`
`03/26
`Online Domestic Wire Fee
`-25.00
`20,360.32
`
`eee ma ||
`
`eee | P|
`
`Oe az |
`
`
`EE—Oeee m7 |
`
`eee P| ma
`EO Pe
`aa
`
`aaI
`
`Ie——“‘‘CONN
`
`Bw——=—_isi—‘“‘(C(C‘(_‘COOUUUUUUUNTTTLLULULUUDDTLUCULChCU
`O———————-OEE
`OU———ll
`
`na __ a7 mz
`
`nm rr 7||
`
`iE
`
`nding Balance
`
`$6,385.22
`
`Page 2 of 4
`
`03/23
`
`03/23
`
`50,180.00
`
`57,250.32
`
`14,990.00
`
`72,240.32
`
`

`

`Case 1:23-cr-00118-AT Document595_Filed 04/04/25 Page 16 of 57
`
`
`
`
`CHASE &
`
`March 04, 2021 through April 05, 2021
`Account Number:
`!iMEG208
`
`A Monthly Service Fee was not charged to your Chase Total Checking account. Here are the three ways you can avoid
`this fee during any statement period.
`
`*
`
`*
`
`*
`
`Have electronic deposits madeinto this account totaling $500.00 or more, such as payments from payroll
`providers or government benefit providers, by using (i) the ACH network,{ii} the Real Time Payment network,
`or(iii) third party services that facilitate payments to your debit card using the Visa or Mastercard network.
`(Your tore electronic deposits this period were $58,500.00. Note: some deposits maybelisted on your previous
`OR, keep a balanceat the beginning of each day of $1,500.00 or morein this account.
`(Your balance at the beginning of each day was $160.33)
`
`statement
`
`OR, keep an average beginning day baiance of $5,000.00 or more in qualifying linked deposits and
`investments.
`(Your average beginning day balanceof qualifying linked deposits and investments was $29,561.32)
`
`
`
`
`
`IN CASE OF ERRORS OR QUESTIONS ABOUT YOUR ELECTRONIC FUNDS TRANSFERS: Call us at 1-866-564-2262 or write us at the
`address on thefront of this statement (non-personal accounts contact Custorner Service) immediately if you think your statementor receipt is
`incorrector if you need more information about a transferlisted on the statementorreceipt.
`For personal accounts only: We must hearfrom you no later than 60 days after we sent you the FIRST stalement on which the problem or error
`appeared. Be preparedto give us the following information:
`.
`Your name and account number
`*
`The dollar amount of the suspected error
`_.*_Adescription of the error or transfer you are unsure of, why you believe it is an error, or why you need more information.
`Wewill investigate your complaint and will correct any error promptly.
`If we take more than 40 business days(or 20 business days for new
`accounts}to do this, we will credit your accountfor the amount youthinkis in error so that you will have use of the money during the timeit takes
`us to complete our investigation.
`IN CASE OF ERRORS OR QUESTIONS ABOUT NON-ELECTRONIC TRANSACTIONS: Contactthe bank immediately if your statementis
`incorrect or if
`you need more information about any non-electronic transactions (checks or deposits} on this statement.
`If any such error appears,
`you must notify the bank in writing no later than 30 days after the statement was made available to for. For more complete details, see the
`Account Rules and Regulations or other applicable account agreementthat governs your account. Deposit products and services are offered by
`JPMorgan Chase Bank, N.A. Member FD!
`{= JPMorgan Chase Bank, N.A. Member FDIC
`LENDER
`
`
`
`Page 3 of 4
`
`

`

`Case 1:23-cr-00118-AT Document595_Filed 04/04/25 Page 17 of 57
`
`
`~
`
`CHAS E a
`
`March 04, 2021 through April 05, 2021
`
`Account Number: [iiiIG208
`
`This Page Intentionally Left Blank
`
`Page 4 of 4
`
`

`

`
`
`Case 1:23-cr-00118-AT Document595_Filed 04/04/25 Page 18 of 57
`
`Exhibit “C”
`
`

`

`|
`
`
`
`Case 1:23-cr-00118-AT
`
`Document595_
`
`Filed 04/04/25
`
`Page 19 of 57
`
`BANK OF AMERICA “2”
`
`P.O. Box 15284
`Wihnington, DE 19850
`
`LI PING TANG
`CHUN LIN
`fr
`eS
`——9]
`
`vo
`.
`Customerservice information
`
`2 Customer service: 1.800.432.1000
`
`En Espafial: 1.800.688.6086
`
`| bankefamerica.com
`
`i Bank of America, NLA.
`P.O, Box 25118
`Tampa, FL 33622-5118
`
`Your Adv Plus Banking
`for April 22, 2021 to May 19, 2021
`LIPING TANG
`CHUN LIN
`
`Account number:I 3575
`
`Account summary
`Beginning balance on April 22, 2021
`$56,141,62
`
`Deposits and other additions
`:
`0.00
`
`Withdrawals and other subtractions
`1,007.55
`-
`
`Checks
`~50,1600,00
`.
`
`Service fees
`: -0.00
`:
`:
`
`Ending balance on May 19, 2027 7
`$5,034.07
`
`-
`
`:
`
`BANK OF AMERICA PRESENTS
`M a ste rp i eceé
`Mi O mr @ nr C
`
`SSM-01-23-3113.8 | 3414765
`
`Be inspired by art!
`Bank of America’s Masterpiece Momentis a new video series that
`explores great works of art in museurns across the United States.
`Visit bankofamerica.com/MasterpieceMoment to watch the
`
`A new episode will be available every other Monday night.
`
`latest episodes, and sign up for alerts so you never miss a moment!
`
`
`
` “PUT ‘Ro C¥CIF+ 12 SPFO- F OFUIVFRY: F TYPF* IMAGF 1 RG WA Dano ft nf RB
`
`
`
`

`

`Case 1:23-cr-00118-AT Document595_Filed 04/04/25 Page 20 of 57
`
`
`LIPING TANG { Account # HNN 3575 | April 22,2021 to May 19, 2021
`
`
`
`IMPORTANT INFORMATION:
`BANK DEPOSIT ACCOUNTS
`
`How to Contact Us - You maycall us at the telephone numberlisted on the front of this statement.
`
`Updating your contact inforrnation - We encourage you to keep your contact information up-to-date. This includes address,
`email and phone number.If your information has changed, the easiest way to updateit is by visiting the Help & Support tab of
`Online Banking.
`
`Deposit agreement - When you opened your account, you received a deposit agreement and fee schedule and agreed that your
`account would be governed by the terms of these documents, as we may amend them from time to time. These documents are
`part of the contract for your deposit account and govern all transactionsrelating to your account, including ail deposits and
`withdrawals. Copies of both the deposit agreement and fee schedule which contain the current version of the terms and
`conditions of your account relationship may be obtained at our financial centers.
`
`
`
`Electronic transfers: In case of errors or questions about your electronic transfers - If you think your statementor receipt is
`wrong or you need more information about an electronic transfer (e.g., ATM transactions, direct deposits or withdrawals,
`point-of-sale transactions) on the statementor receipt, telephone or write us at the address and numberlisted on the front of
`this statement as soon as you can. We must hear from you no later than 60 days after we sent you the FIRST statement on
`which the error or problem appeared.
`
`Tellus your name and account number.
`-
`- Describe the error or transfer you are unsure about, and explain as clearly as you can why you believe there Is an error
`or why you need more information.
`~ Telus the dollar amount of the suspected error.
`
`For consumer accounts used primarily for personal, family or household purposes, wewill investigate your complaint and will
`correct any error promptly. If we take more than 10 business days (10 calendar days if you are a Massachusetts customer} (20
`business days if you are a new customer, for electronic transfers occurring during the first 30 days after the first deposit is
`made to your account) to do this, we will provisionally credit your account for the amount you think is in error, so that you will
`have use of the money during the time it will take to complete our investigation.
`
`For other accounts, we investigate, and if we find we have madean error, we credit your account at the conclusion of our
`investigation.
`
`Reporting other problems - You must examine your statementcarefully and promptly. You are in the best position to discover
`errors and unauthorized transactions on your account.If you fail to notify us in writing of suspected problems or an
`unauthorized transaction within the time period specified in the deposit agreement (which periods are no more than 60 days
`after we make the statementavailable to you and in some cases are 30 days orless), we are notliable to you and you agree to
`not make a claim against us, for the problems or unauthorized transactions.
`
`Direct deposits - If you have arranged to have direct deposits made to your accountat least once every 60 days from the same
`person or company, you maycall us to find out if the deposit was made as scheduled, You may also review your activity online
`or visit a financial center for information.
`
`© 2021 Bank of America Corporation
`
`Bank ofAmerica, N.A. Member FDIC and {=} Equal Housing Lender
`
`Daan Dark a
`
`

`

`
`
`Case 1:23-cr-00118-AT Document595_Filed 04/04/25 Page 21 of 57
`
`BANK OF AMERICA “=
`LIPING TANG | Account # M3575 | April 22,2021 to May 19, 2021
`
`Withdrawals and other subtractions
`Date
`Description
`Amount
`
`
`EOE
`|
`
`
`Total withdrawals and other subtractions
`
`-$1,007.85
`
`
`
`
`
`Checks
`
`Date
`Check #
`_
`_
`Amount
`
`04/23/21
`.
`-50,100,00
`Total checks
`-§50,100.00
`Total # of checks
`1
`
`
`
`3Estados de cuenta en espanol?
`jPodemoshacerlos para usted!
`Llarne a! 800.688.6086 o visite
`su centro financiero mas cercano.
`Se aplican exclusiones, No se encuentra disponible para cuentas comerciales,
`Meniil, Private Bank y Pequenas Empresas,
`
`Statements in Spanish?
`We can do that for you!
`Call 800.432.1000, or visit
`your nearest Financia? center.
`Exclusions apply. Not available for Commercial, Metzill, Private Bank
`and Small Business accounts.
`
`S5M-07-20-0686B | 3172518
`
`Bana 2 nf iB
`
`

`

`Case 1:23-cr-00118-AT Document595_Filed 04/04/25 Page 22 of 57
`
`
`LIPING TANG | Account # Ee3575 | April 22, 2021 to May 19, 2021 .
`
`This page intentionally lettblarik
`
`Dana A nf GB
`
`

`

`Page 23 of 57
`Case 1:23-cr-00118-AT Document595_~Filed 04/04/25
`
`BANK OF AMERICA “<-*
`
`LIPING TANG | Account # INN 3575 | April 22,2021 to May 19, 2021
`
`Check images
`Account number:a3575
`Amount: $50,100.
`
`
`
`oosz
`eat pa
`
`|
`
`1052
`
`Aeckeb, 2084
`em G Clich Uperctums £60 .$ §6,100.0
`
`Hem Fhousond. oneHundusel ents mth
`
`Ban America"
`orderitey AGQOHOROPHA| =eee,
`4 2500C0 SS S75"
`
`Dada Raf &
`
`

`

`
`
`Case 1:23-cr-00118-AT Document595_Filed 04/04/25 Page 24 of 57
`
`LIPING TANG | Account # IN 3575 | April 22, 2021 to May 19, 2021
`
`
`
`This page intentionally left blank
`
`Dana A anf
`
`

`

`
`
`Case 1:23-cr-00118-AT Document595_Filed 04/04/25 Page 25 of 57
`
`Exhibit “D”
`
`

`

`
`
`
`Case 1:23-cr-00118-AT Document595_Filed 04/04/25 Page 26 of 57
`
`
`
`Customer service information
`
`fl Customer service; 1.800.432.1000
`
`En Espanol: 1.800,688,6086
`
`i) bankofamerica.com
`
`== Bank of America, NLA.
`P.O. Box 25118
`Tampa, FL 33622-5118
`
`Account number: (J 3575
`
`BANK OF AMERICA “=
`
`P.O, Box 1528-4
`Wilmington, DE 19850
`
`Li PING TANG
`CHUN LIN
`a
`___
`a
`
`Your Adv Plus Banking
`for September 22, 2021 to October 20, 2021
`
`LiPING TANG
`
`CHUNLIN
`
`Accourt summary
`Beginning balance on September 22, 2021
`$207,550.43
`
`Deposits and other additions
`=
`0.00
`
`Withdrawals and other subtractions .
`-0,00
`/
`
`Checks
`200,080.00
`:
`
`Service fees
`-0,00
`:
`|
`
`Ending balance on October 20, 2021
`$7,470.43
`
`:
`
`Simply use our Mobile Banking app or sign in to Online Banking at bankofamerica.com.
`
`
`
`‘Mobile Banking requires that you download the Mabile Banking appand is only available for select mobile devices. Message and data rates may apply. SSM-06-21-00668 | 3600544
`
`PUL CVEIF-14 SPEC F FIERY: F TYPE)
`
`IMAGE: 1 RE: wa
`
`Dada 4 Ate
`
`Go paperless today!
`
`« Reduce the risk of lost, delayed