Miles Guo Court Documents · Doc 478
Notice of Request to Protect Funds as to Miles Guo, Kin Ming Je, Yvette Wang (Geyer, Bradford) / (中文)
摘要
Renewed Motion · Bradford Geyer for Financial Victims' Return of Property
This 13-page document, dated November 25, 2024 from Bradford L. Geyer, Esq. of FormerFedsGroup.Com LLC, is a renewed motion on behalf of multiple cohorts of victim-claimants for return of funds the government has seized in United States v. Miles Guo, Kin Ming Je, Yanping Wang, 23-cr-118 (AT).
Cohorts Represented
Claimants represented by counsel are customers or investors in:
- (A) Himalaya Exchange (HEX) — HCN and HDO holders;
- (B) G|CLUBS — the membership-club fundraising program;
- (C) Farm Loan Program — the volunteer-network funding mechanism;
- (D) GTV Private Placement — the equity offering for GTV Media Group.
In addition to the Himalaya Exchange cohort, the filing represents five additional individual victims alongside thousands of Himalaya Exchange customers.
Statutory Bases
The motion is filed under multiple authorities:
- 18 U.S.C. § 983(a)(1)(A)(i) (civil forfeiture procedures);
- The Bank Robbery Act (18 U.S.C. § 2113);
- Common law larceny by trick and false pretenses;
- 21 U.S.C. §§ 853(i) and (n) (criminal forfeiture);
- 18 U.S.C. § 3771 (Crime Victims' Rights Act);
- Rule 41(g) (Federal Rules of Criminal Procedure — return of property);
- 42 U.S.C. § 10607 (services to victims);
- Federal Rule of Criminal Procedure 32.2(b);
- Principles of unjust enrichment.
Relief Sought
The motion demands the return of funds illegally seized by the U.S. Government, identified by the government as belonging to victims of the defendants. The argument is that the funds should be fully restored to the rightful owner-claimants represented by undersigned counsel.