Miles Guo Court Documents · 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)
摘要
HEX Customers' Motion for Return of Property
This two-page filing, dated December 6, 2023 from Bradford L. Geyer (pending PHV approval) of FormerFedsGroup.Com, is the Notice of Motion, Memorandum in Support, and Proposed Order Demanding Return of Funds by 3,345 Himalaya Exchange customers in United States v. Ho Wan Kwok, Kin Ming Je, Yanping Wang, 23 Cr. 118 (AT).
Petitioners
Undersigned counsel represents 3,345 customers of the Himalaya Exchange who hold Himalaya Dollar (HDO) and Himalaya Coin (HCN) cryptocurrency ("petitioners"). This is the inaugural Geyer cohort filing in the criminal docket.
Relief Sought
Pursuant to Federal Rule of Criminal Procedure 41(g), petitioners move for return of their property seized by the United States in United States v. Kwok et al. The petitioners argue they have a distinct interest in HCN/HDO holdings — as direct cryptocurrency holders rather than general creditors — warranting return of property outside the typical fraud-proceeds analysis.