Miles Guo Court Documents · Doc 870

摘要

Stipulation and Order · Legal Fees Recognized as Bona Fide Purchase

A seven-page Stipulation and Order in United States v. Miles Guo, S3 23 Cr. 118 (AT) (S.D.N.Y.), executed on July 29, 2026 and entered on the docket on August 18, 2026. The parties are the United States — by Sean S. Buckley, Attorney for the United States acting under authority conferred by 28 U.S.C. § 515, with Assistant United States Attorney Juliana Murray of counsel — and Pillsbury Winthrop Shaw Pittman LLP, represented by Sharon Cohen Levin of Sullivan & Cromwell LLP. It is SO ORDERED by U.S. District Judge Analisa Torres.

The forfeiture background recited

The stipulation opens with a recital of the case history. The third superseding indictment (Dkt. No. 307), filed April 24, 2024, charged thirteen counts including racketeering conspiracy, wire and bank fraud conspiracy, money laundering conspiracy, securities fraud conspiracy, and substantive fraud counts tied to the GTV private placement, the farm loan program, G|CLUBS, and the Himalaya Exchange, plus unlawful monetary transactions and obstruction of justice. The indictment alleged that the racketeering enterprise included G Club International Limited and G Club Operations LLC, and that the conduct ran from at least 2018 through at least March 2023. Following a jury trial, the defendant was found guilty on July 16, 2024 of Counts One, Two, Three, Four, Seven, Eight, Nine, Ten and Eleven (Dkt. No. 395).

The property at issue is identified precisely:

• the G Club International Funds — approximately $11,538,579.87 formerly on deposit at Mercantile Bank International in the name of "G Club International Ltd.," seized on or about October 16, 2022;
• the G Club Operations Funds — approximately $2,112,510.70 formerly at Banco Popular in the name of G Club Operations LLC, covered by the Government's January 19, 2026 application for a First Supplemental Preliminary Order of Forfeiture (Dkt. No. 790).

Co-defendant Yvette "Yanping" Wang pleaded guilty on or about May 3, 2024; a final order of forfeiture entered January 7, 2025 (Dkt. No. 488) vested the G Club International Funds in the United States. The Preliminary Order of Forfeiture of August 11, 2025 (Dkt. No. 720) imposed a $1.3 billion money judgment against the defendant and forfeited specifically identified property including the G Club International Funds.

Pillsbury's asserted interest

Pillsbury asserted an interest in two categories of G Club money: approximately $3,304,285.11 already paid to it for legal services rendered before September 1, 2023 (the "Paid Legal Fees"), and up to approximately $1,142,638.81 owed for services rendered between September 1, 2023 and May 17, 2024 (the "Unpaid Legal Fees"). With the Government's consent, Pillsbury's deadline to file a third-party petition was extended to the date of the stipulation. Pillsbury supplied a sworn declaration setting out the factual and legal basis for its claim, including its status as a bona fide purchaser for value who at the time was reasonably without cause to believe the Paid Legal Fees were subject to forfeiture.

The agreed terms

1. The G Club International Funds, the G Club Operations Funds and the Paid Legal Fees are subject to forfeiture as a result of the offenses of conviction and of Wang's offenses of plea, under 18 U.S.C. §§ 1963(a) and (c), 981(a)(1)(C) and 982(a)(1); 28 U.S.C. § 2461(c); and 21 U.S.C. § 853(c).
2. On the strength of the declaration, the Government recognizes Pillsbury as a bona fide purchaser for value of the Paid Legal Fees under 18 U.S.C. § 1963(l)(6)(B) and 21 U.S.C. § 853(n)(6)(B).
3. Pillsbury will not assert, or help others assert, any claim to the G Club International Funds or the G Club Operations Funds — including the Unpaid Legal Fees — or any claim against the United States, the U.S. Marshals Service, the FBI, the U.S. Attorney's Office for the Southern District of New York or their personnel arising out of the seizure or restraint of those funds, including any claim that probable cause was lacking, that Pillsbury is a prevailing party, or that it is entitled to attorney's fees or interest.
4. Pillsbury reserves the right to file a Petition for Remission, or a claim before a Special Master, in an amount not exceeding the Unpaid Legal Fees.
5. Pillsbury will hold the United States and those agencies harmless from third-party ownership claims to the Paid Legal Fees.

The remaining paragraphs provide for execution in counterparts, make the stipulation the complete agreement as to the funds, waive all rights to appeal or otherwise contest its validity, have each party bear its own costs and fees, and reserve the Court's jurisdiction to enter further orders implementing it.