Miles Guo Court Documents · Doc 761
Counsel for 6,512 Himalaya Exchange investors argues they are not fraud victims but lawful crypto holders harmed by government seizures, seeking fair return of their funds.
摘要
Response of 6,512 HEX Claimants · To Individual Investor Motions
This eight-page document, dated October 22, 2025 from Bradford L. Geyer of FormerFedsGroup.Com LLC, responds on behalf of 6,512 Himalaya Exchange (HEX) investors to motions filed by individual investors in United States v. Ho Wan Kwok et al., 23-cr-118 (AT).
Filings Addressed
The response addresses motions filed at:
- ECF No. 733;
- ECF No. 734;
- ECF No. 738 (supplemented by ECF No. 743);
- ECF No. 740;
- ECF No. 744.
The response notes the individual motions are "informed by" the defendant's disclaimer of any property interest, ownership, or rights in the Himalaya Exchange at ECF No. 710, and contain sections that appear coordinated.
Counsel's Position on the Individual Motions
The response's principal positions:
1. Investor-Claimant Status, Not Victim Status
Counsel argues the 6,512 HEX investors are properly characterized as lawful crypto holders harmed by the government's seizures, not fraud victims of Mr. Guo. The frame matters because § 853(n) recognizes property-interest claimants with rights superior to the government, distinct from the broader victim-restitution framework.
2. Coordinated False Statements About Counsel
The response argues that the individual motions contain coordinated falsehoods about undersigned counsel and the representation of the 6,512 claimants. Counsel argues the court record demonstrates these statements are untrue.
3. Permissible Collaboration vs. Abuse
While there is no issue with individual claimants collaborating with each other on their submissions, the response argues that the targeting of undersigned counsel through false statements crosses into abuse of process.