Miles Guo Court Documents · Doc 709
摘要
Nonparty Motion · To Hold Bradford L. Geyer Accountable for Unauthorized Representation
A four-page motion dated June 26, 2025, submitted on behalf of the interests of Himalaya Exchange customer Beibei Zhu, titled "Motion to Hold Bradford L. Geyer Accountable for Unauthorized and Fraudulent Representation and to Seek Monetary Sanctions in the Amount of $100,000."
The three requests
- To hold attorney Bradford L. Geyer accountable for fraudulently obtaining client representation rights over the customer without proper authority or informed consent;
- To declare that Geyer lacked pro hac vice admission or any other admission before the U.S. District Court for the Southern District of New York to appear on behalf of the customer or any Himalaya customer at any time relevant to his purported representation;
- To impose sanctions and order restitution in the amount of $100,000 to redress the reputational, legal, and financial harm the customer is said to have suffered.
The factual assertions made by the filer
The motion states that Geyer represented himself to the Court and related parties as authorized counsel for the customer; that he did not obtain her voluntary, informed, written consent and was never retained by her, directly or indirectly; and that he did not obtain pro hac vice admission. All of the above are the filer's assertions.
Background that belongs alongside it
- The filer, Beibei Zhu, is one of the two nonparties addressed in the Court's orders of April 3 and April 4, 2025: the Court denied the motion to intervene and the motion to unseal the victim list, and the following day found this filer and one other to be vexatious nonparties who had abused the public's right of access to the Court, imposing a pre-filing screening requirement (Dkts. 528, 596).
- Motions to revoke the representation agreement with Geyer and to expel him were filed in the same direction by a nonparty (Dkts. 508, 519, 524) — the filer there being Chunk Chyi, the other of the two found vexatious.
- The Government had also filed a letter on January 5, 2024 stating that Geyer does not represent any party to this criminal action yet has filed unsolicited submissions on the criminal docket, and inviting the Court to take appropriate action (Dkt. 223).
The other side of the record
Geyer has appeared on this docket as counsel for Himalaya Exchange customers since December 2023: first for 3,345 customers (Dkts. 185, 186), rising to 5,242 in January 2024 (Dkt. 212), and in October 2025 filing on behalf of 6,512 members who expressly disclaimed victim status (Dkt. 761). The defense subsequently relied on that group's position in its sentencing submission.