Miles Guo Court Documents · Doc 830

摘要

Response in Opposition · Beibei Zhu Sanctions Motion · Cross-Motion for Sanctions

This six-page document, dated April 6, 2026 and signed by undersigned counsel Bradford L. Geyer, responds to and opposes the "Supplemental Notice of Victim Damages, Objection to Procedural Fraud, and Motion for Sanctions" filed by Zhubeibei / Beibei Zhu in United States v. Ho Wan Kwok et al., 23-cr-118 (AT), and cross-moves for sanctions against the movant under Federal Rule of Civil Procedure 11 and the Court's inherent authority.

Filings at Issue

The response addresses:

• The movant's "Supplemental Notice of Victim Damages, Objection to Procedural Fraud, and Motion for Sanctions" filed on or about March 21–22, 2026;
• Subsequent pro se letter motions filed through the pro se filing system on March 26, April 2, April 4, and April 6, 2026.

The response argues these filings are recycled, meritless attacks already rejected by prior proceedings in the case, and asks the Court to deny them in full, strike them from the record, and award sanctions against the movant for abuse of process and Rule 11 violations.

I. Preliminary Statement

The response characterizes the movant's filings as a "deliberate, bad-faith disruption tactic designed to harass undersigned counsel, smear legitimate victim advocacy, and delay restitution for thousands of bona fide Himalaya Exchange customers whose assets were seized by the Government."

The response recites: the movant voluntarily registered as a client on December 22, 2023, affirmatively consented to representation, and was included in the sealed master roster. When she later objected, counsel immediately terminated the relationship (see ECF 712). The response argues this should have ended the matter.

The response also notes that the movant has launched a campaign of "repetitive, inflammatory filings (ECF 709, now this Supplemental Motion) that recycle the same debunked allegations while escalating demands to half a million dollars in punitive damages." The response identifies specific language used by the movant — "procedural predatory behavior," "administrative hijacking," "secondary plunder" — as inflammatory rhetoric.

II. Factual Background

The response asserts:

• On December 22, 2023 at 9:20 a.m., Beibei Zhu registered as a client of FormerFedsGroup.Com LLC and expressly requested representation in connection with the seized Himalaya Exchange assets;
• She was added to the sealed master client roster and was among the initial 3,345+ customers on whose behalf the Rule 41(g) Motion for Return of Property was filed on December 6, 2023 (ECF No. 186);
• Her consent was written and voluntary;
• The December 2023 motion protected victims rather than "hijacking" anything, as the movant alleges.

Relief Sought

The response asks the Court to:

• Deny the movant's Supplemental Motion in full;
• Strike the related filings from the record;
• Award sanctions against the movant under Rule 11 and the Court's inherent authority for what counsel characterizes as vexatious litigation, including the escalating monetary demands.