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AFM:CBB 271 Cadman Plaza East\n F. #2024R00105 Brooklyn, New York 11201\n\n\n\n September 11, 2026\n By ECF\n\n The Honorable Clay H. Kaminsky\n United States Magistrate Judge\n Eastern District of New York\n 225 Cadman Plaza East\n Brooklyn, New York 11201\n\n Re: United States v. Approximately 127,271 Bitcoin\n Civil Docket No. 25-5745 (RPK) (CHK)\n\n Dear Judge Kaminsky:\n\n The government respectfully submits this motion to compel claimant LuBian to\n comply with the government\u2019s special interrogatories served on it on February 20, 2026 (the\n \u201cSpecial Interrogatories\u201d). LuBian responded on April 28, 2026 with vague and incomplete\n answers (LuBian\u2019s \u201cObjections and Responses\u201d or \u201cObj. & Resp.,\u201d attached as Ex. A). On May\n 18, 2026, the parties met and conferred. LuBian\u2019s counsel provided some additional detail by way\n of attorney proffer, but to date LuBian has failed to supplement, let alone fully answer, its\n interrogatory responses. The government has been left with incomplete responses that lack the\n most basic information needed to assess LuBian\u2019s standing and to reconcile its claim with\n overlapping claims filed by other, apparently affiliated entities. The Court should compel LuBian\n to respond so that its standing can be tested.\n\n I. Background\n\n As the Court is aware, on October 14, 2025, the government filed the verified\n complaint in this case (the \u201cComplaint\u201d), which seeks the forfeiture of 127,271 bitcoin (the\n \u201cDefendant Cryptocurrency\u201d) previously in the control of Chen Zhi (\u201cChen\u201d) as proceeds of fraud\n and property involved in money laundering. See ECF No. 1. The Complaint alleges that Chen,\n who was the chairman of the Prince Holding Group (\u201cPrince Group\u201d), operated forced-labor scam\n compounds across Cambodia that perpetrated cryptocurrency investment fraud schemes, and that\n he laundered the proceeds of those schemes through various corporate entities, professional money\n laundering networks and cryptocurrency mining operations. See id. \u00b6\u00b6 38-43. The Complaint also\n alleges that Chen and his co-conspirators laundered their illicit proceeds by, among other things,\n funding large-scale cryptocurrency mining operations, including LuBian, to produce large sums\n of clean Bitcoin dissociated from criminal proceeds. Id. \u00b6 42.\n\n On January 20, 2026, LuBian filed a barebones claim, asserting a generalized\n interest in the Defendant Cryptocurrency \u201carising from [LuBian\u2019s] participation in operations\n\fCase 1:25-cv-05745-RPK-CHK Document 504 Filed 09/11/26 Page 2 of 8 PageID #:\n 13173\n\n\n\n connected to the mining of a substantial quantity of BTC constituting the Defendant Assets and its\n hosting of those assets at wallet addresses for which it held the private keys.\u201d ECF No. 79, \u00b6 4.\n LuBian\u2019s claim did not explain basic facts about the basis of its interest, such as how much of the\n Defendant Cryptocurrency it was claiming, or provide any details about the origin and nature of\n its asserted property interest. The claim described LuBian\u2019s own identity only in the vaguest of\n terms, as an \u201cunincorporated collective of software engineers involved in BTC mining group\n operations and cryptocurrency wallet hosting services, among other ventures . . . .\u201d Id. \u00b6 2. The\n claim was verified by an individual claiming to be a \u201cmember of the collective of LuBian.\u201d Id.\n \u00b6 3.\n\n II. Applicable Law\n\n To determine a claimant\u2019s standing and the validity of his claim, including the\n precise nature of the interest it is asserting, the government may serve the claimant with special\n interrogatories at any time after a claim is filed. R. G(6); cf. United States v. $133,420.00 in U.S.\n Currency, 672 F.3d 629, 642 (9th Cir. 2012) (explaining that \u201cRule G(6)(a) . . . gives the\n government the right to question the claimant regarding the claimant\u2019s identity and relationship to\n the defendant property, and to gather information that bears on the claimant\u2019s standing.\u201d (citations\n and internal quotation marks omitted)). See generally, Gov\u2019t Mot. to Compel Warp Data, ECF\n No. 439 at 3-5 (reviewing relevant law). \u201cSo important are these interrogatories to the issue of\n standing that Rule G(8)(c)(1) permits the government to move to strike a claim or answer \u2018(A) for\n failing to comply with Rule G(5) or (6); or (B) because the claimant lacks standing.\u2019\u201d United\n States v. $10,055.00 in U.S. Currency, No. 17-CV-78, 2018 WL 2933850, at *2 (N.D. Ohio June\n 12, 2018). \u201c[T]he drafters of Rule G(6) intended the special interrogatories to provide an efficient\n means of testing the truthfulness of the [c]laimant\u2019s claim to have a real interest in the defendant\n property.\u201d United States v. $104,250.00 in U.S. Currency, 947 F. Supp. 2d 560, 563 (D. Md.\n 2013). For that reason, special interrogatory responses that fail to provide sufficient information\n \u201cimpair[] the truth-seeking function of the judicial process.\u201d United States v. $295,726.42 in\n Account Funds Seized, 279 F. Supp. 3d 1050, 1055 (C.D. Cal. 2018) (citing $133,420.00 in U.S.\n Currency, 672 F.3d at 642).\n\n The interrogatories may broadly inquire into any matter necessary \u201cto test the\n veracity of the claimant\u2019s claim of ownership and interest.\u201d United States v. Two Hundred\n Seventy-Two Thousand Dollars & No Cents ($272,000), No. 16-CV-06564 (AMD), 2017 WL\n 8780158, at *3 (E.D.N.Y. Oct. 26, 2017) (alteration and internal quotation marks omitted); accord\n $133,420.00 in U.S. Currency, 672 F.3d at 642 (\u201cRule G(6)(a) . . . broadly allows the government\n to collect information regarding the claimant\u2019s relationship to the defendant property.\u201d (internal\n quotation marks omitted)); United States v. $307,970.00, in U.S. Currency, No. 12-CV-136, 2013\n WL 4095373, at *3 (E.D.N.C. Aug. 13, 2013) (\u201c[P]ermissible interrogatories as to a claimant\u2019s\n relationship to the defendant property may encompass more than just the type of interest asserted\n in the property.\u201d); United States v. $2,051,660.00 in U.S. Currency, No. 07-CV-1338, 2008 WL\n 8723566, at *1 (D. Kan. Sept. 29, 2008) (explaining that because \u201cRule G(5) already requires a\n claimant to give his name, address and to state ownership interest in the seized property, the\n addition of Supplemental Rule G(6)[\u2019s] phrase regarding [the] \u2018claimant\u2019s identity and relationship\n to the defendant property\u2019 must allow more than a mere recitation of the information already\n required by . . . Rule G(5)\u201d). This includes not just the claimant\u2019s identity and the nature of his\n interest in the property, but also the circumstances of his acquiring that interest, such as the time,\n\n\n 2\n\fCase 1:25-cv-05745-RPK-CHK Document 504 Filed 09/11/26 Page 3 of 8 PageID #:\n 13174\n\n\n\n place, manner, and reason for acquiring the property, and the identity of the person from whom\n the claimant acquired it. See, e.g., $133,420.00 in U.S. Currency, 672 F.3d at 642 (explaining that\n \u201cinformation as to the circumstances under which the currency was obtained is information that\n bears on [a claimant\u2019s] standing\u201d (internal quotation marks omitted)); United States v. $63,575 in\n U.S. Currency, No. 18-CV-02131, 2019 WL 2996001, at *2-3 (E.D. Mo. July 9, 2019) (granting\n government\u2019s motion to compel responses to special interrogatories seeking \u201cthe date, time, and\n places in which any portion of the property was acquired,\u201d as well as \u201cwhether the defendant\n property was claimed on [the claimant\u2019s] local, state or federal income taxes\u201d).\n\n Indeed, courts have given particularly broad scope to the special interrogatories in\n cases involving the forfeiture of seized currency\u2014cases where the claimant\u2019s claim of ownership\n is inextricably intertwined with the evidence regarding the provenance of the money and the\n claimant\u2019s personal circumstances. See, e.g., $272,000.00 in U.S. Currency, 2017 WL 8780158,\n at *3 (granting government\u2019s motion to compel response to special interrogatory seeking \u201ceach\n and every source from which [the claimant] claims the [defendant currency] was derived\u201d\n (alterations omitted)); United States v. Funds in the Amount of $174,000.00, No. 11-CV-6698,\n 2012 WL 473146, at *1-2 (N.D. Ill. Feb. 6, 2012) (holding that the government could use special\n interrogatories to inquire into, inter alia, the claimant\u2019s interest in the currency and any documents\n substantiating that interest, the source of the currency and the date it was acquired, and the identity\n of witnesses corroborating claimant\u2019s claim of interest); United States v. Approximately $750,000\n in U.S. Currency, No. 10-CV-6069, 2011 WL 6155687, at *1, *2 (S.D.N.Y. Dec. 8, 2011) (holding\n that the government could use special interrogatories to ask the basis for the claim of ownership,\n the source of the defendant currency, the identity of any person or document supporting the claim,\n and the claimant\u2019s income and tax return information, criminal history, and past participation in\n civil lawsuits); United States v. $333,806.93 in Proceeds, No. 05-CV-2556, 2010 WL 3733932, at\n *2 (C.D. Cal. Aug. 30, 2010) (concluding that special interrogatories seeking \u201cany records or\n documents relevant to [the claimant\u2019s] interest in the defendant assets\u201d and the identities of \u201call\n persons having knowledge\u201d of that interest were \u201chighly relevant\u201d and \u201cdirectly relevant\u201d to\n standing).\n\n A claimant must answer or object to such interrogatories within 21 days of service.\n R. G(6)(b). If the claimant fails to respond, or if the claimant\u2019s responses to the interrogatories\n are inadequate, the government may file a motion to compel responses pursuant to Federal Rule\n of Civil Procedure 37 or move to strike the claim and answer pursuant to Rule G. See United\n States v. Vazquez-Alvarez, 760 F.3d 193, 196 (2d Cir. 2014); $133,420.00 in U.S. Currency, 672\n F.3d at 635; see also, e.g., United States v. $410,000.00 in U.S. Currency, No. 07-CV-0589, 2007\n WL 4557647, at *7 & n.5 (D.N.J. 2007) (granting government\u2019s motion to compel responses to\n special interrogatories as necessary to ensure claimant has standing and to protect against nominee\n claimants); United States v. $2,409.00 in U.S. Currency, No. 10-CV-0220, 2010 WL 2670982, at\n *1 (D. Md. June 24, 2010) (striking claim for failing to respond to special interrogatories within\n 21 days).\n\n\n\n\n 3\n\fCase 1:25-cv-05745-RPK-CHK Document 504 Filed 09/11/26 Page 4 of 8 PageID #:\n 13175\n\n\n\n III. LuBian Failed to Comply with Rule G(6)\n\n A. LuBian Has Failed To Explain the Nature and Source of Its Interest in the\n Defendant Cryptocurrency (Special Interrogatories 4, 5, 7)\n\n As this Court has recognized, the government is entitled to inquire into the source\n and circumstances of a claimant\u2019s asserted interest in the Defendant Cryptocurrency. This includes\n \u201cwhen, from whom, where, and how [the claimant] acquired [its] interest in the Defendant Funds.\u201d\n ECF No. 472, at 8 (quoting $272,000.00 in U.S. Currency, 2017 WL 8780158, at *3). LuBian\u2019s\n interrogatory answers, however, provide none of these details. Indeed, LuBian\u2019s answers are so\n vague that they appear to provide multiple theories of ownership\u2014and these theories are presented\n as nothing more than bare-bones assertions, lacking in factual and legal detail, and seemingly\n overlapping with one another. LuBian must supplement its answers to allow the government to\n engage in a meaningful evaluation of LuBian\u2019s identity and standing.\n\n At the outset, it is worth highlighting the information that LuBian did not provide\n about its claim of interest in the Defendant Cryptocurrency: the \u201ctime and circumstances\u201d of\n LuBian\u2019s acquisition of its interest; the \u201cvirtual currency addresses[] or accounts\u201d from which the\n funds originated (i.e., the \u201csource accounts\u201d) or passed through before reaching the 25 addresses\n comprising the Defendant Cryptocurrency (i.e., the \u201cintermediate accounts\u201d); who owned or\n controlled those source accounts or intermediate accounts; the \u201corigin of all funds\u201d traceable to\n the Defendant Cryptocurrency; whether the funds were sourced through cryptocurrency mining,\n and if so, \u201chow, when, and by whom\u201d were the cryptocurrency mining operations funded; 1 what\n other persons or entities exercise any control over the Defendant Cryptocurrency including the\n \u201cdates and manner\u201d and \u201ccircumstances\u201d of such control, and each such person or entity\u2019s\n \u201crelationship\u201d to LuBian. See Special Interrogatories 4, 5.\n\n Rather than respond to the government\u2019s interrogatories in any detail, LuBian offers\n a four-bullet list in which it sketches out (but does not explain) various theories of interest in the\n Defendant Cryptocurrency. LuBian begins by asserting a generic \u201cpossessory interest\u201d over the\n \u201centirety\u201d the Defendant Cryptocurrency based on LuBian\u2019s \u201cpossession of the private keys\u201d for\n and \u201chosting\u201d of the wallets comprising the Defendant Cryptocurrency before December 2020.\n Obj. & Resp. at 9. But LuBian never explains when or how it came to host the Defendant\n Cryptocurrency in these custodial wallets. From whom did LuBian receive the Defendant\n Cryptocurrency? Under what business arrangement were the funds retained by or turned over to\n LuBian for safekeeping? What kind of activity generated such a large sum of money?\n\n LuBian only deepens the mystery by asserting a \u201cfurther claims an interest\u201d as \u201ca\n bailee for other parties including claimants Chen Zhi and Warp Data.\u201d Obj. & Resp. at 9\n (emphases added). It is unclear whether this is a new theory or merely a continuation of the\n\n 1\n As noted in the government\u2019s forfeiture complaint, some of the Defendant\n Cryptocurrency was newly mined by LuBian. See ECF No. 1 (Verified Compl. In Rem), \u00b6 47 &\n n.9. LuBian does not explain how this newly-mined Bitcoin was nevertheless being held by\n LuBian as a bailee for another party, or how these funds differ from other funds over which LuBian\n is asserting a claim.\n\n\n 4\n\fCase 1:25-cv-05745-RPK-CHK Document 504 Filed 09/11/26 Page 5 of 8 PageID #:\n 13176\n\n\n\n \u201cpossessory interest\u201d theory. Use of the word \u201cfurther\u201d implies that it is distinct, but if so, LuBian\n never explains what distinguishes the bailee theory from the possessory interest theory. In any\n event, LuBian\u2019s bailee theory remains equally unexplained. When, how, and from whom did\n LuBian receive the Defendant Cryptocurrency as bailee? Which portions did it receive from whom?\n LuBian states that it acted as bailee for parties \u201cincluding\u201d Chen Zhi and Warp Data\u2014implying\n the existence of other bailors but declining to name them. And if there were multiple bailors (Chen\n Zhi, Warp Data, and perhaps other unnamed bailors), how was the Defendant Cryptocurrency\n divided up among them? LuBian elsewhere states that, in addition to LuBian itself, only Chen Zhi\n had complete \u201caccess to the private keys\u201d for LuBian\u2019s digital wallets. Obj. & Resp. at 14. What\n accounts for the difference in the terms of bailment between Chen Zhi and Warp Data? LuBian\n does not explain. 2\n\n It is well-established that \u201c[a]n \u2018interest\u2019 in the property is determined under the\n law of the state or foreign nation in which the interest arose . . . and the constitutional effect of that\n interest is determined under federal law.\u201d United States v. All Assets Held in Acct. No. XXXXXXXX\n in name of Doraville Props. Corp., 299 F. Supp. 3d 121, 128 (D.D.C. 2018). Here, LuBian asserts\n that its \u201cinterests\u201d (plural) arise \u201cunder the laws of Cambodia.\u201d Obj. & Resp. at 10. But LuBian\n declines to name any Cambodian statute or legal doctrine as the basis for any of its theories of\n interest. Given the extent to which legal concepts such as bailment or constructive trust differ\n across states, let alone foreign jurisdictions, LuBian must identify the specific legal basis for each\n of its theories.\n\n B. LuBian Has Not Explained Its Identity or the Nature of Its Relationship to the\n Individual Who Is Claiming To Be LuBian\u2019s Representative in the Forfeiture\n Proceeding (Special Interrogatories 1, 2, 3)\n\n LuBian has also failed to explain its own identity with sufficient detail to allow the\n government to evaluate its standing and ability to bring a claim in its own right. LuBian claims to\n be an \u201cunincorporated collective of software engineers,\u201d but its interrogatory responses provide\n no detail about what that means, who really exercises control over LuBian\u2019s affairs, or how LuBian\n is related to other claimants in this action.\n\n First, LuBian provides insufficient information about its organizational identity.\n LuBian states that, as an unincorporated collective, it \u201cdoes not have a separate legal personality\u201d\n and \u201cdoes not have an ownership structure in the corporate sense.\u201d Obj. & Resp. at 4. But LuBian\n declines to provide any further detail\u2014providing no information, for instance, about the names or\n identities of any of the \u201csoftware engineers\u201d who comprise the collective (other than the individual\n who claims to be LuBian\u2019s representative for purposes of this forfeiture litigation, referred to here\n\n\n 2\n LuBian also asserts that it is the beneficiary of a \u201cconstructive trust,\u201d Obj. & Resp.\n at 9, but a constructive trust requires the claimant to have some preexisting right to the disputed\n property. See, e.g., Mattel, Inc. v. MGA Ent., Inc., 616 F.3d 904, 909 (9th Cir. 2010), as amended\n on denial of reh\u2019g (Oct. 21, 2010) (noting that, under California law, one of the elements of a\n constructive trust is the claimant\u2019s \u201cright to that res\u201d). That just begs the question of what LuBian\u2019s\n preexisting interest in the Defendant Cryptocurrency may be.\n\n\n 5\n\fCase 1:25-cv-05745-RPK-CHK Document 504 Filed 09/11/26 Page 6 of 8 PageID #:\n 13177\n\n\n\n by the initials L.S.Z.). 3 Nor does LuBian specify the number of software engineers\u2014stating only\n that there have been \u201capproximately 40-50 software engineers\u201d who have been involved in LuBian\n \u201c[s]ince its inception.\u201d Id. LuBian\u2019s inability to name any of its current or former members is\n significant. This is not, for example, a multinational corporation with thousands of employees,\n governed by an identifiable set of corporate officers and board members, but a collective of at most\n 50 persons during its organizational lifespan, all of whom might (or might not) have some degree\n of \u201ccollective\u201d decisionmaking authority, and who may (or may not) be able to articulate some\n individualized interest in LuBian\u2019s property or operations. None of this is explained. The absence\n of any corporate structure does not excuse LuBian from providing information about its identity.\n Just the opposite, it magnifies the importance of understanding who stands behind LuBian, directs\n its affairs, or is poised to benefit from any recovery in this forfeiture proceeding.\n\n Indeed, LuBian appears to be, at best, a dormant entity that has not engaged in any\n operations since December 2020. LuBian states that it \u201ccommenced its business in 2018\u201d but its\n \u201ccryptocurrency operations ceased in December 2020.\u201d Obj. & Resp. at 4. Of course, that answer\n seems to leave open the possibility that LuBian continued another line of \u201cbusiness\u201d distinct from\n \u201ccryptocurrency operations\u201d past December 2020. If so, LuBian must supplement its response.\n But if it is true that LuBian, an \u201cunincorporated collective,\u201d ceased all operations in December\n 2020, what accounts for its continuing existence and capacity to assert a claim in this proceeding?\n\n LuBian\u2019s answers are so elastic that they could conceivably encompass a scenario\n in which LuBian has just one self-styled member (L.S.Z.) whose personal connection to the\n Defendant Cryptocurrency remains unexplained. The only tidbit of information LuBian offers as\n to L.S.Z.\u2019s role is that he has been a \u201cmember\u201d of LuBian\u2019s \u201ccollective of software engineers since\n 2018.\u201d Missing from this answer is any detail regarding the nature of L.S.Z.\u2019s work for LuBian\n and his relationship to the other members of the \u201ccollective\u201d\u2014despite the government\u2019s specific\n requests for answers regarding, for example, L.S.Z.\u2019s \u201crole with respect to LuBian\u201d and his\n \u201cemployment history and history of association with LuBian.\u201d Special Interrogatories, at 6. Also\n missing is any explanation of \u201cthe source of [L.S.Z.\u2019s] authority . . . with respect to LuBian\u2019s\n affairs.\u201d Id. at 5-6. LuBian provides a hand-waving statement that L.S.Z.\u2019s authority \u201cderives\n from his membership of the collective,\u201d but that does not explain the legal basis for his authority\n to act and speak on LuBian\u2019s behalf, or the manner and circumstances by which LuBian\u2019s\n \u201ccollective\u201d might have conferred such authority on L.S.Z. 4\n\n\n 3\n Prior to filing its claim, LuBian filed an ex parte sealing motion, which has never\n been shared with the government. ECF No. 78. LuBian then filed a verified claim in which the\n name and signature of the individual purporting to represent LuBian and to verify LuBian\u2019s claim\n under penalty of perjury have been redacted. See ECF No. 79. LuBian subsequently disclosed the\n identity of this individual to the government, and its Objections and Responses to the government\u2019s\n Special Interrogatories were verified by the same individual. The government is referring to this\n individual by the initials L.S.Z.\n 4\n It is also unclear how LuBian can reconcile its claim to be an unincorporated\n collective represented by one of its members, L.S.Z., with its statement elsewhere that all of\n LuBian\u2019s profits are due to be paid to a different individual, Li Thet. See Obj. & Resp. at 5.\n\n\n 6\n\fCase 1:25-cv-05745-RPK-CHK Document 504 Filed 09/11/26 Page 7 of 8 PageID #:\n 13178\n\n\n\n C. LuBian Has Not Addressed Its Relationship to Other Claimants (Special\n Interrogatories 8, 9, 10, 11, 12)\n\n Finally, LuBian fails to address or explain its relationship with other claimants in\n this litigation, including Chen Zhi, Prince Holding Group, Warp Data, and Jian Yang. At the heart\n of the standing inquiry is the determination of whether a claimant is asserting an ownership interest\n in its own right, or whether it is merely acting as a pass-through or straw claimant on behalf of\n another. As this Court has explained, straw owners \u201clack standing because they \u2018do not themselves\n suffer an injury when the property is taken.\u2019\u201d ECF No. 472, at 11 (quoting United States v.\n Khudainatov, 177 F.4th 224, 229 (2d Cir. 2026)). Special interrogatories are necessary to \u201c\u2018test\n the Claimant\u2019s assertion that she is the true owner of the defendant property and not merely a\n courier for a third party.\u2019\u201d Id. (quoting United States v. $104,250.00 in U.S. Currency, 947 F.\n Supp. 2d 560, 565 (D. Md. 2013)).\n\n Some of the government\u2019s interrogatories about LuBian\u2019s relationship with other\n claimants are met with outright refusal. E.g., Obj. & Resp. at 15-16 (declining to respond to\n Special Interrogatory No. 12, regarding the distinction between LuBian\u2019s claim and those filed by\n other claimants including Chen Zhi, Prince Holding Group, Warp Data, and Jian Yang). Others\n are strategically vague. E.g., Obj. & Resp. at 12-13 (declining to explain relationship between\n LuBian and Prince Group other than to state that Prince Holding Group does not own LuBian); id.\n at 13-14 (declining to explain relationship between LuBian and Warp Data other than to state that\n Warp Data generated an unspecified amount of cryptocurrency that \u201cwould be held in [LuBian\u2019s]\n digital wallets\u201d). LuBian\u2019s answers with respect to Chen Zhi are particularly evasive. LuBian\n elsewhere acknowledges what appears to be an extensively intertwined relationship between itself\n and Chen Zhi\u2014stating that Chen Zhi (alone) shared access to the private keys for LuBian\u2019s digital\n wallets; that LuBian acted as a bailee for Chen Zhi; and that one of Chen Zhi\u2019s close associates,\n an individual named Li Thet, is \u201centitled to any profits derived from [LuBian\u2019s] business\n operations.\u201d Obj. & Resp. at 5, 9, 14. Yet when asked in Special Interrogatory 10 to explain the\n relationship between LuBian and Chen Zhi, LuBian declines to provide anything close to a\n complete answer. Rather than affirmatively stating what the relationship between LuBian and\n Chen Zhi is, LuBian attempts to get away with stating what the relationship is not, offering only\n that \u201cChen Zhi had no formal membership, employment, advisory or consulting relationship with\n Claimant.\u201d Id. at 14. Such narrowly-crafted denials are transparently designed to avoid answering\n the question, as there are numerous other ways Chen Zhi might have exerted influence and control\n over LuBian\u2019s affairs or assets. And LuBian\u2019s response, framed as it is in terms of \u201cformal\u201d roles,\n is next to worthless when it comes to an \u201cunincorporated collective\u201d that appears to observe no\n corporate formalities. LuBian must supplement its responses to provide a clear and comprehensive\n explanation of its relationship to Chen Zhi, Warp Data, and each of the other named entities.\n\n IV. Conclusion\n\n For these reasons, the government respectfully requests that the Court compel\n LuBian to properly respond to the government\u2019s special interrogatories pursuant to Rule G(6). If\n LuBian fails to comply, the government intends to move to strike its claim on this basis in addition\n to those already contemplated in the government\u2019s forthcoming motions to strike for failure to\n establish statutory and constitutional standing. See Vazquez-Alvarez, 760 F.3d at 196; United\n States v. $19,764.00 in U.S. Currency, No. 10-CV-573A, 2011 WL 4899958, at *2-3 (W.D.N.Y.\n\n\n 7\n\fCase 1:25-cv-05745-RPK-CHK Document 504 Filed 09/11/26 Page 8 of 8 PageID #:\n 13179\n\n\n\n Aug. 12, 2011), report and recommendation adopted, No. 10-CV-573, 2011 WL 4896507\n (W.D.N.Y. Oct. 14, 2011) (citing cases granting motions to strike for failure to respond to\n interrogatories).\n\n Respectfully submitted,\n\n JOSEPH NOCELLA, JR.\n United States Attorney\n\n By: /s/\n Alexander F. Mindlin\n Tanisha R. Payne\n Benjamin Weintraub\n Andrew D. Reich\n Alessandra V. Rafalson\n Assistant U.S. Attorneys\n (718) 254-7000\n\n Christopher B. Brown\n Supervisory Trial Attorney\n Noah Simmons\n Trial Attorney\n National Security Cyber Section\n National Security Division\n U.S. Department of Justice\n\n\n cc: Clerk of Court (CHK)\n Counsel of Record\n\n\n\n\n 8\n\f","ocr_status":2,"date_upload":"2026-09-11T14:43:12.203927-07:00","document_number":"504","attachment_number":null,"pacer_doc_id":"123024175550","is_available":true,"is_free_on_pacer":null,"is_sealed":false,"document_type":1,"description":"Compel","acms_document_guid":""},{"resource_uri":"https://www.courtlistener.com/api/rest/v4/recap-documents/493336837/","id":493336837,"tags":[],"absolute_url":"/docket/71639393/504/1/united-states-v-approximately-127271-bitcoin-btc-previously-stored-at/","date_created":"2026-09-11T14:43:15.767742-07:00","date_modified":"2026-09-11T14:43:18.155181-07:00","sha1":"bbe144fdd720f9f4d6c43b7316f1ce6bb91a696d","page_count":18,"file_size":186874,"filepath_local":"recap/gov.uscourts.nyed.537552/gov.uscourts.nyed.537552.504.1.pdf","filepath_ia":"","ia_upload_failure_count":null,"thumbnail":null,"thumbnail_status":0,"plain_text":"Case 1:25-cv-05745-RPK-CHK Document 504-1 Filed 09/11/26 Page 1 of 18 PageID\n #: 13180\n\n\n\n\n EXHIBIT A\n\fCase 1:25-cv-05745-RPK-CHK Document 504-1 Filed 09/11/26 Page 2 of 18 PageID\n #: 13181\n\n\n\n\n UNITED STATES DISTRICT COURT\n EASTERN DISTRICT OF NEW YORK\n No. 1:25-cv-05745-RPK\n UNITED STATES OF AMERICA,\n\n Plaintiff, CLAIMANT LUBIAN\u2019S OBJECTIONS\n v. AND RESPONSES TO PLAINTIFF\n UNITED STATES OF AMERICA\u2019S\n FIRST SET OF SPECIAL\n APPROXIMATELY 127,271 BITCOIN (\u201cBTC\u201d) INTERROGATORIES\n PREVIOUSLY STORED AT THE VIRTUAL\n CURRENCY ADDRESSES LISTED IN\n ATTACHMENT A TO THE VERIFIED\n COMPLAINT, AND ALL PROCEEDS\n TRACEABLE THERETO,\n Defendant In Rem,\n\n\n LUBIAN,\n\n Claimant.\n\n\n\n\n Pursuant to Rule G(6)(a) of the Supplemental Rules of Admiralty or Maritime Claims and\n\n Asset Forfeiture Actions, Claimant LuBian (\u201cClaimant\u201d or \u201cLuBian\u201d), by and through its\n undersigned counsel, hereby objects and responds to Plaintiff United States of America\u2019s\n\n (\u201cPlaintiff\u201d) First Set of Special Interrogatories to Claimant (the \u201cInterrogatories\u201d and each an\n\n \u201cInterrogatory\u201d). These Objections and Responses are made solely for the purpose of and in relation\n to this action.\n\n The Objections and Responses set forth in this document are based on Claimant\u2019s\n\n knowledge, investigation, and analysis to date. Claimant reserves the right to supplement and\n\n amend these Objections and Responses should Claimant become aware of additional information.\n\n\n\n\n -1-\n\fCase 1:25-cv-05745-RPK-CHK Document 504-1 Filed 09/11/26 Page 3 of 18 PageID\n #: 13182\n\n\n\n I. GLOBAL OBJECTIONS\n\n 1. Claimant objects to the Interrogatories on the grounds that Claimant\u2019s standing to\n contest forfeiture is not reasonably in dispute because Plaintiff\u2019s Verified Complaint alleges facts\n\n sufficient to show standing at this stage.\n\n 2. Claimant objects to the Interrogatories to the extent they seek information already in\n\n Plaintiff\u2019s possession, custody, or control.\n 3. Claimant objects to any Interrogatory that exceeds the limited scope of Rule G(6),\n\n which permits special interrogatories \u201climited to claimant\u2019s identity and relationship to the\n\n defendant property,\u201d and of the Court\u2019s text order of February 17, 2026, which permitted Plaintiff to\n\n serve special interrogatories \u201climited to each claimant\u2019s identity and relationship to the defendant\n property.\u201d\n\n 4. Claimant objects to the Interrogatories to the extent they seek information protected\n\n by the attorney-client privilege, the work-product doctrine, or any other applicable privilege or\n protection. Claimant hereby asserts those privileges and protections in response to any Interrogatory\n\n that may be construed as calling for privileged or protected information, and objects to such\n\n Interrogatories on those bases. Nothing in Claimant\u2019s Responses is intended to be or shall be\n\n deemed a waiver of any rights under such privileges or protections.\n 5. Claimant objects to the Interrogatories to the extent they are overly broad, are unduly\n\n burdensome, are not limited to a reasonable timeframe, or seek information that is not reasonably\n\n accessible.\n\n 6. Claimant objects to the Interrogatories to the extent they assume facts that have not\n been established or admitted by Claimant.\n\n 7. Claimant objects to the Interrogatories to the extent they call for legal conclusions.\n\n 8. Nothing in these Responses should be construed as waiving any rights or objections\n that might be available to Claimant; nor should Claimant\u2019s Response to any Interrogatory be\n\n deemed an admission of relevancy, materiality, or admissibility concerning any information or\n\n document.\n\n -2-\n\fCase 1:25-cv-05745-RPK-CHK Document 504-1 Filed 09/11/26 Page 4 of 18 PageID\n #: 13183\n\n\n\n 9. Claimant objects to the definitions and instructions to the extent they are overly\n\n broad, burdensome, or inconsistent with the applicable federal and local rules.\n II. SPECIFIC OBJECTIONS AND RESPONSES\n\n SPECIAL INTERROGATORY NO. 1:\n\n State the full legal name of the entity filing the Claim (referred to herein as \u201cLuBian\u201d).\n\n Describe LuBian\u2019s operations in detail and identify: (a) its ownership and operating structure,\n including that of any parent or subsidiary entities; (b) all entities or individuals who have an\n\n ownership or investment interest in it and the percentage of such ownership or interest; (c) the dates\n\n it began and ceased operations and the circumstances of its creation and closure; (d) the countries in\n\n which it operated and what those operations consisted of; (e) each physical address at which it has\n conducted operations; (f) all persons involved in its creation and operation or who have knowledge\n\n of its business, including any members, employees, officers, managers, directors or principals; (g)\n\n all operating agreements or other governing documents; (h) any relationship it has or has ever had\n to the governments of the People\u2019s Republic of China and Iran; (i) all names used by it and when\n\n and where it used those names; (j) all financial accounts and virtual currency addresses used by it\n\n and (k) the nation under whose laws it is incorporated, organized or otherwise formed, and the\n\n nature of that formation.\n RESPONSE TO SPECIAL INTERROGATORY NO. 1:\n\n Claimant objects to this Interrogatory to the extent it exceeds the permissible scope of Rule\n\n G(6), which authorizes special interrogatories \u201climited to the claimant\u2019s identity and relationship to\n\n the defendant property,\u201d and of the Court\u2019s text order of February 17, 2026, which permitted\n Plaintiff to serve special interrogatories \u201climited to each claimant\u2019s identity and relationship to the\n\n defendant property.\u201d Claimant further objects to this Interrogatory as overbroad, unduly\n\n burdensome, and seeking information that is irrelevant or disproportionate to the needs of the case.\n Claimant further objects to this Interrogatory to the extent it seeks information already in Plaintiff\u2019s\n\n possession, custody, and control. For example, Plaintiff\u2019s Verified Complaint states that Claimant\n\n \u201cLubian was a Chinese bitcoin mining operation that maintained bitcoin mining facilities across\n\n -3-\n\fCase 1:25-cv-05745-RPK-CHK Document 504-1 Filed 09/11/26 Page 5 of 18 PageID\n #: 13184\n\n\n\n Asia\u201d and \u201cthe Lubian mining operation was the sixth largest bitcoin mining operation in the\n\n world.\u201d Claimant further objects to this Interrogatory because it is compound and improperly\n combines multiple discrete interrogatories. Accordingly, Claimant declines to respond to this\n\n Interrogatory, except to note the following:\n\n \uf0b7 Claimant is an unincorporated collective of software engineers and does not have a\n\n separate legal personality. Claimant operates under the name of LuBian. Since its\n formation, there have been approximately 40-50 software engineers who act as the\n\n members of Claimant, including\n\n \uf0b7 As an unincorporated collective, Claimant is formed of its members and does not\n\n have an ownership structure in the corporate sense. Subject to this, Claimant refers\n Plaintiff to Claimant\u2019s Response to Special Interrogatory No. 2.\n\n \uf0b7 Claimant\u2019s business has included the development and operation of cryptocurrency\n\n wallet software, known as Touhou; the development and operation of a\n cryptocurrency mining pool, under its own name; and the development and operation\n\n of a website advertising its cryptocurrency services, known as LuBian.com.\n\n \uf0b7 Claimant commenced its business in 2018. Its initial operations involved the Touhou\n\n wallet software, which by December 2020 included all the digital currency wallets\n listed in Attachment A to Plaintiff\u2019s Verified Complaint. In March 2020, Claimant\n\n began offering its cryptocurrency mining pool services. In April 2020, Claimant\n\n launched the LuBian.com website.\n\n \uf0b7 Claimant\u2019s cryptocurrency operations ceased in December 2020, after the vast\n majority of cryptocurrency held in Claimant\u2019s Touhou wallets was stolen in a\n\n hacking attack.\n\n \uf0b7 Claimant has conducted its business in China and Cambodia.\n \uf0b7 Claimant has not had any relationship with the government of the People\u2019s Republic\n\n of China or any party related to the same.\n\n\n\n -4-\n\fCase 1:25-cv-05745-RPK-CHK Document 504-1 Filed 09/11/26 Page 6 of 18 PageID\n #: 13185\n\n\n\n \uf0b7 Claimant has not had any relationship with the government of Iran or any party\n\n related to the same.\n \uf0b7 Claimant has not operated under any other name than LuBian.\n\n \uf0b7 Claimant hosted all the virtual currency wallets identified in Attachment A to the\n\n Verified Complaint.\n\n \uf0b7 Claimant is an unincorporated collective and therefore not formed under the laws of\n any country. As noted above, it has conducted its business operations from China and\n\n Cambodia.\n\n SPECIAL INTERROGATORY NO. 2:\n\n State the names, addresses, phone numbers, email addresses, and other contact information\n for all persons or entities holding more than a 10 (ten) percent interest in LuBian, and the fraction of\n\n the interest held by that person or entity.\n\n RESPONSE TO SPECIAL INTERROGATORY NO. 2:\n Claimant objects to this Interrogatory to the extent it exceeds the permissible scope of Rule\n\n G(6), which authorizes special interrogatories \u201climited to the claimant\u2019s identity and relationship to\n\n the defendant property,\u201d and of the Court\u2019s text order of February 17, 2026, which permitted\n\n Plaintiff to serve special interrogatories \u201climited to each claimant\u2019s identity and relationship to the\n defendant property.\u201d Claimant further objects to this Interrogatory on the grounds that it is\n\n compound and improperly combines multiple discrete interrogatories. Accordingly, Claimant\n\n declines to respond to this Interrogatory, except to note the following:\n\n \uf0b7 As Claimant noted in its Response to Special Interrogatory No. 1, Claimant is\n an unincorporated collective and does not have an ownership structure in the\n\n corporate sense. Li Thet is entitled to any profits derived from Claimant\u2019s business\n\n operations.\n \uf0b7 Address: , London, SW1E\n\n 6AN, United Kingdom.\n\n\n\n -5-\n\fCase 1:25-cv-05745-RPK-CHK Document 504-1 Filed 09/11/26 Page 7 of 18 PageID\n #: 13186\n\n\n\n\n SPECIAL INTERROGATORY NO. 3:\n Your Claim was signed and verified by an individual asserting to be a\n\n \u201cmember of the collective of LuBian.\u201d Explain in detail this individual\u2019s role with respect to\n\n LuBian and the source of this individual\u2019s authority, past and present, with respect to LuBian\u2019s\n\n affairs. Also provide:\n a. full name and any prior names or aliases, place and date of birth,\n\n identification numbers on any official documents (such as a passport or driver\u2019s license), country or\n\n countries of citizenship, current and prior residential and business addresses, personal and business\n\n phone numbers, and personal and business email addresses.\n b. employment history and history of association with LuBian, including\n\n what entity/entities employed and compensated this individual, title or positions held and when they\n\n were held, location of work and when worked at those locations, job\n responsibilities, and wages or other compensation received.\n\n RESPONSE TO SPECIAL INTERROGATORY NO. 3:\n\n Claimant objects to this Interrogatory to the extent it exceeds the permissible scope of Rule\n\n G(6), which authorizes special interrogatories \u201climited to the claimant\u2019s identity and relationship to\n the defendant property,\u201d and of the Court\u2019s text order of February 17, 2026, which permitted\n\n Plaintiff to serve special interrogatories \u201climited to each claimant\u2019s identity and relationship to the\n\n defendant property.\u201d Claimant further objects to this Interrogatory as overbroad, unduly\n\n burdensome, and seeking information that is irrelevant or disproportionate to the needs of the case.\n Claimant further objects to this Interrogatory on the grounds that it is compound and improperly\n\n combines multiple discrete interrogatories. Accordingly, Claimant declines to respond to this\n\n Interrogatory, except to note the following:\n \uf0b7 is and has been a member of the Claimant\u2019s collective of software\n\n engineers since 2018 and his authority on behalf of Claimant derives from his\n\n membership of the collective.\n\n -6-\n\fCase 1:25-cv-05745-RPK-CHK Document 504-1 Filed 09/11/26 Page 8 of 18 PageID\n #: 13187\n\n\n\n \uf0b7 Passport No.:\n\n \uf0b7 Nationality: China\n SPECIAL INTERROGATORY NO. 4:\n\n The Defendant Cryptocurrency comprises assets previously held at the virtual currency\n\n addresses listed in Attachment A of the Verified Complaint. For each of the 25 addresses that held\n\n assets to which you are asserting a claim, provide the following information in detail:\n a. The nature of your interest in the virtual assets previously stored at that address. For\n\n example, state whether you claim an interest as an owner of the property, a custodian, a bailee, an\n\n entity with a secured, unsecured or equitable interest in the property, or otherwise, and how and in\n\n what jurisdiction that interest was established and memorialized. Identify any documents\n memorializing that interest.\n\n b. State whether the interest described above is an interest in the property held by you\n\n directly, or is an interest held by an entity that you own or control, in whole or in part, and what\n entity.\n\n c. State the names, addresses, phone numbers, and contact details of any individual or entity\n\n who, in addition to yourself, has any interest in the virtual assets, and the nature and extent of that\n\n interest. For an entity, also state its place of incorporation or registration, contact details of\n registered agents and all beneficial owners of such entity, and your relationship to the entity. If any\n\n entity named in response to this Interrogatory is owned or controlled in whole or in part by another\n\n entity, provide the same information with respect to the beneficial ownership of that entity.\n\n d. The time and circumstances of your acquisition of any interest in the virtual assets\n previously stored at that address.\n\n e. All virtual currency addresses, or accounts (including accounts at virtual currency\n\n exchanges and traditional fiat currency accounts), from which any of the virtual assets at that\n address originated (the \u201csource accounts\u201d) and through which such assets passed (the \u201cintermediate\n\n accounts\u201d).\n\n\n\n -7-\n\fCase 1:25-cv-05745-RPK-CHK Document 504-1 Filed 09/11/26 Page 9 of 18 PageID\n #: 13188\n\n\n\n f. Any individual or entity that had ownership or control of the source accounts or the\n\n intermediate accounts, including the individuals or entities that possessed or had access to the\n private keys. Explain your relationship to each individual or entity identified.\n\n g. The origin of all funds, including traditional fiat currency and virtual assets, in the source\n\n accounts, and the circumstances that led to the deposit of the funds in those source accounts. If the\n\n source of any of the funds or assets was cryptocurrency mining, state where the mining operations\n were located and describe them in detail, including how, when, and by whom they were funded.\n\n h. State whether, at each stage in the transfer of the funds from the source accounts through\n\n the intermediate accounts, the funds were under your control and, if so, the manner in which you\n\n exercised such control.\n i. For any virtual assets you allege were mined by LuBian, state whether and for how long\n\n LuBian had an ownership interest in those assets after they were mined and the nature of that\n\n interest. For example, if assets were mined and then stored at certain virtual currency addresses\n and/or transferred to additional addresses, state the nature of LuBian\u2019s ownership of those assets in\n\n each location where they were stored. Identify any other individual or entity who also had an\n\n ownership interest in those assets at any time after they were mined, and the nature and time period\n\n of that ownership interest. If LuBian relinquished control of any such assets, state when and to\n whom and under what circumstances.\n\n RESPONSE TO SPECIAL INTERROGATORY NO. 4:\n\n Claimant objects to this Interrogatory to the extent it exceeds the permissible scope of Rule\n\n G(6), which authorizes special interrogatories \u201climited to the claimant\u2019s identity and relationship to\n the defendant property,\u201d and of the Court\u2019s text order of February 17, 2026, which permitted\n\n Plaintiff to serve special interrogatories \u201climited to each claimant\u2019s identity and relationship to the\n\n defendant property.\u201d Claimant further objects to this Interrogatory as overbroad, unduly\n burdensome, and seeking information that is irrelevant or disproportionate to the needs of the case.\n\n Claimant further objects to this Interrogatory to the extent it seeks duplicative information,\n\n including information already in Plaintiff\u2019s possession, custody, and control. For example,\n\n -8-\n\fCase 1:25-cv-05745-RPK-CHK Document 504-1 Filed 09/11/26 Page 10 of 18 PageID\n #: 13189\n\n\n\n Plaintiff\u2019s Verified Complaint states that \u201clarge-scale cryptocurrency mining operations, including\n\n the Laos-based Warp Data and its Texas-based subsidiary, and the China-based Lubian, \u2026\n produced large sums of clean bitcoin.\u201d Compl. \u00b6 42. Claimant further objects to this Interrogatory to\n\n the extent that it seeks information that is either equally available to the government, including\n\n information on the public blockchain ledger, or in the exclusive possession, custody, or control of\n\n the government, including information about the Defendant Cryptocurrency during the time period\n from December 28, 2020, until the filing of the Complaint on October 14, 2025.\n\n Claimant further objects to this Interrogatory on the grounds that the operative complaint in\n\n this action does not include sufficient detail regarding the seizure and custody of the Defendant\n\n Cryptocurrency. Claimant further objects to this Interrogatory to the extent that it seeks information\n not in Claimant\u2019s possession, custody, or control, including information about the Defendant\n\n Cryptocurrency during the time period from December 28, 2020, until the filing of the Complaint\n\n on October 14, 2025. Claimant further objects to this Interrogatory on the grounds that it is\n compound and improperly combines multiple discrete interrogatories. Accordingly, Claimant\n\n declines to respond to this Interrogatory, except to note the following:\n\n \uf0b7 Claimant claims a possessory interest in the entirety of the Defendant\n\n Cryptocurrency. Claimant\u2019s interest derives from its possession of the private keys\n for and hosting of the digital currency wallets holding the Defendant Cryptocurrency\n\n before it was stolen in December of 2020.\n\n \uf0b7 Claimant further claims an interest in the Defendant Cryptocurrency as a bailee for\n\n other parties including claimants Chen Zhi and Warp Data.\n \uf0b7 Claimant further claims an interest in the Defendant Cryptocurrency as the\n\n beneficiary of a constructive trust. Specifically, in December 2020 the Defendant\n\n Cryptocurrency was stolen, and thus any successive possessors of the Defendant\n Cryptocurrency could not have acquired good title and thus held the Defendant\n\n Cryptocurrency in trust for the rightful owners, including Claimant.\n\n\n\n -9-\n\fCase 1:25-cv-05745-RPK-CHK Document 504-1 Filed 09/11/26 Page 11 of 18 PageID\n #: 13190\n\n\n\n \uf0b7 Claimant\u2019s interests arise under the laws of Cambodia, where Claimant previously\n\n did business. Claimant presently lacks sufficient information about the 2020 theft of\n the Defendant Cryptocurrency to determine if Claimant\u2019s interest as beneficiary of a\n\n constructive trust arises under the laws of any other jurisdiction.\n\n SPECIAL INTERROGATORY NO. 5:\n\n Unless such information has been provided in your response above, identify any and all\n individuals or entities that, in addition to yourself, have exercised control over any virtual assets that\n\n are part of the Defendant Cryptocurrency and which assets specifically, the dates and manner in\n\n which such individual or entity exercised such control, the circumstances whereby such individual\n\n or entity ceased to exercise such control, and your relationship to such individual or entity.\n RESPONSE TO SPECIAL INTERROGATORY NO. 5:\n\n Claimant objects to this Interrogatory to the extent it exceeds the permissible scope of Rule\n\n G(6), which authorizes special interrogatories \u201climited to the claimant\u2019s identity and relationship to\n the defendant property,\u201d and of the Court\u2019s text order of February 17, 2026, which permitted\n\n Plaintiff to serve special interrogatories \u201climited to each claimant\u2019s identity and relationship to the\n\n defendant property.\u201d Claimant further objects to this Interrogatory as overbroad, unduly\n\n burdensome, and seeking information that is irrelevant or disproportionate to the needs of the case.\n Claimant further objects to this Interrogatory to the extent it seeks information not in Claimant\u2019s\n\n possession, custody, or control. Claimant further objects to this Interrogatory on the grounds that it\n\n is compound and improperly combines multiple discrete interrogatories.\n\n Accordingly, Claimant declines to respond to this Interrogatory, except to refer Plaintiff to\n Claimant\u2019s Response to Special Interrogatory No. 4.\n\n SPECIAL INTERROGATORY NO. 6:\n\n Identify and provide the contact information for any person who has knowledge of any of\n the facts relevant to each of the foregoing interrogatories. Identify any and all documents containing\n\n information relevant to your responses to each of the foregoing interrogatories. Identify all forms of\n\n electronic communication, including but not limited to text messages and emails, and their related\n\n - 10 -\n\fCase 1:25-cv-05745-RPK-CHK Document 504-1 Filed 09/11/26 Page 12 of 18 PageID\n #: 13191\n\n\n\n phone numbers and email addresses, used to exchange information regarding the interests of\n\n yourself and/or others in the Defendant Cryptocurrency, or the control and disposition of such\n property. To the extent it is necessary to gain access to such communications, provide the\n\n passwords and encryption keys.\n\n RESPONSE TO SPECIAL INTERROGATORY NO. 6:\n\n Claimant objects to this Interrogatory to the extent it exceeds the permissible scope of Rule\n G(6), which authorizes special interrogatories \u201climited to the claimant\u2019s identity and relationship to\n\n the defendant property,\u201d and of the Court\u2019s text order of February 17, 2026, which permitted\n\n Plaintiff to serve special interrogatories \u201climited to each claimant\u2019s identity and relationship to the\n\n defendant property.\u201d Claimant further objects to this Interrogatory as overbroad, unduly\n burdensome, and seeking information that is irrelevant or disproportionate to the needs of the case.\n\n Claimant further objects on the ground that this Interrogatory requests information relating to \u201ceach\n\n of the forgoing interrogatories,\u201d including Interrogatories that also, independently, exceed the\n permissible scope of Rule G(6). Claimant further objects to this Interrogatory to the extent it seeks\n\n information not in Claimant\u2019s possession, custody, or control, including by requesting information\n\n relating to \u201call forms of electronic communications \u2026 used to exchange information regarding the\n\n interests of \u2026 others in the Defendant Cryptocurrency.\u201d Claimant further objects to this\n Interrogatory to the extent it seeks information about or relating to other claims or claimants.\n\n Claimant further objects to this Interrogatory on the grounds that it is compound and improperly\n\n combines multiple discrete interrogatories.\n\n Accordingly, Claimant declines to respond to this Interrogatory, except to note that the\n Responses contained herein have been verified by .\n\n SPECIAL INTERROGATORY NO. 7:\n\n Identify each individual or individuals who has had access to the email\n account 1228btc@gmail.com and the time at which such individual or individuals had\n\n access.\n\n\n\n - 11 -\n\fCase 1:25-cv-05745-RPK-CHK Document 504-1 Filed 09/11/26 Page 13 of 18 PageID\n #: 13192\n\n\n\n\n RESPONSE TO SPECIAL INTERROGATORY NO. 7:\n Claimant objects to this interrogatory on the ground that it is not limited to Claimant\u2019s\n\n \u201cidentity and relationship to the defendant property\u201d\u2014or, indeed, to any individual\u2019s or entity\u2019s\n\n relationship to the defendant property\u2014and thus exceeds the permissible scope of Rule G(6).\n\n Accordingly, Claimant declines to respond to this Interrogatory, except to note that Li Thet\n and Chen Zhi have had access to the email account since its registration.\n\n SPECIAL INTERROGATORY NO. 8:\n\n Describe any relationship LuBian (or any individual or entity related to LuBian) has, or has\n\n ever had, to Prince Holding Group or any of its parent or subsidiary entities and when it had such a\n relationship, including, but not limited to: (a) any ownership interest or investment by the individual\n\n or entity; (b) any membership, employment, advisory or consulting relationship, or any other\n\n relationship by the individual or entity; (c) any Prince Holding Group-associated financial accounts\n or accounts at virtual currency exchanges for which the individual or entity was an accountholder,\n\n owner, signatory or beneficiary, or for which the individual or entity had any access or control; and\n\n (d) any associated virtual currency addresses the individual or entity had access to or control over,\n\n including by holding or having access to the private keys or otherwise.\n RESPONSE TO SPECIAL INTERROGATORY NO. 8:\n\n Claimant objects to this Interrogatory to the extent it exceeds the permissible scope of Rule\n\n G(6), which authorizes special interrogatories \u201climited to the claimant\u2019s identity and relationship to\n\n the defendant property,\u201d and of the Court\u2019s text order of February 17, 2026, which permitted\n Plaintiff to serve special interrogatories \u201climited to each claimant\u2019s identity and relationship to the\n\n defendant property.\u201d Claimant further objects to this Interrogatory as overbroad, unduly\n\n burdensome, and seeking information that is irrelevant or disproportionate to the needs of the case.\n Claimant further objects to this Interrogatory on the ground that it seeks information not in\n\n Claimant\u2019s possession, custody, or control. Claimant further objects to the extent that this\n\n Interrogatory seeks information about another claimant, Prince Holding Group, and is thus properly\n\n - 12 -\n\fCase 1:25-cv-05745-RPK-CHK Document 504-1 Filed 09/11/26 Page 14 of 18 PageID\n #: 13193\n\n\n\n directed to Prince Holding Group, not to Claimant. Claimant further objects to this Interrogatory\n\n because it is compound and improperly combines multiple discrete interrogatories.\n Accordingly, Claimant declines to respond to this Interrogatory, except to note that Prince\n\n Holding Group does not have any ownership interest in Claimant.\n\n SPECIAL INTERROGATORY NO. 9:\n\n Describe any relationship LuBian (or any individual or entity related to LuBian) has, or has\n ever had, to Warp Data or any of its parent or subsidiary entities, and when it had such a\n\n relationship, including, but not limited to: (a) any ownership interest or investment by the individual\n\n or entity; (b) any membership, employment, advisory or consulting relationship, or any other\n\n relationship by the individual or entity; (c) any Warp Data-associated financial accounts or accounts\n at virtual currency exchanges for which the individual or entity was an accountholder, owner,\n\n signatory or beneficiary, or for which the individual or entity had any access or control; and (d) any\n\n associated virtual currency addresses the individual or entity had access to or control over, including\n by holding or having access to the private keys or otherwise.\n\n RESPONSE TO SPECIAL INTERROGATORY NO. 9:\n\n Claimant objects to this Interrogatory to the extent it exceeds the permissible scope of Rule\n\n G(6), which authorizes special interrogatories \u201climited to the claimant\u2019s identity and relationship to\n the defendant property,\u201d and of the Court\u2019s text order of February 17, 2026, which permitted\n\n Plaintiff to serve special interrogatories \u201climited to each claimant\u2019s identity and relationship to the\n\n defendant property.\u201d Claimant further objects to this Interrogatory as overbroad, unduly\n\n burdensome, and seeking information that is irrelevant or disproportionate to the needs of the case.\n Claimant further objects to this Interrogatory on the ground that it seeks information not in\n\n Claimant\u2019s possession, custody, or control. Claimant further objects to the extent that this\n\n Interrogatory seeks information about another claimant, Warp Data, and is thus properly directed to\n Warp Data, not to Claimant. Claimant further objects to this Interrogatory because it is compound\n\n and improperly combines multiple discrete interrogatories.\n\n\n\n - 13 -\n\fCase 1:25-cv-05745-RPK-CHK Document 504-1 Filed 09/11/26 Page 15 of 18 PageID\n #: 13194\n\n\n\n Accordingly, Claimant declines to respond to this Interrogatory, except to note that at\n\n times, cryptocurrency which was generated by Warp Data would be held in Claimant\u2019s digital\n wallets.\n\n SPECIAL INTERROGATORY NO. 10:\n\n Describe in detail the current and past relationship(s) between LuBian and Chen Zhi. Among\n\n other things, provide the following information:\n a. The extent to which Chen Zhi has any ownership or investment interest in LuBian, or in\n\n any other entity that, in turn, has an ownership or investment interest in it.\n\n b. Whether Chen Zhi personally, or acting through one or more third parties, exercises or has\n\n ever exercised any control over LuBian or its assets.\n c. Whether Chen Zhi ever directed the affairs of LuBian and, if so, when.\n\n RESPONSE TO SPECIAL INTERROGATORY NO. 10:\n\n Claimant objects to this Interrogatory to the extent it exceeds the permissible scope of Rule\n G(6), which authorizes special interrogatories \u201climited to the claimant\u2019s identity and relationship to\n\n the defendant property,\u201d and of the Court\u2019s text order of February 17, 2026, which permitted\n\n Plaintiff to serve special interrogatories \u201climited to each claimant\u2019s identity and relationship to the\n\n defendant property.\u201d Claimant further objects to this Interrogatory as overbroad, unduly\n burdensome, and seeking information that is irrelevant or disproportionate to the needs of the case.\n\n Claimant further objects to this Interrogatory on the ground that it seeks information not in\n\n Claimant\u2019s possession, custody, or control. Claimant further objects to this Interrogatory because it\n\n is compound and improperly combines multiple discrete interrogatories.\n Accordingly, Claimant declines to respond to this Interrogatory, except to note the\n\n following:\n\n \uf0b7 Chen Zhi had no formal membership, employment, advisory or consulting\n relationship with Claimant.\n\n \uf0b7 Claimant understands that Chen Zhi, in addition to Claimant, had access to the\n\n private keys for Claimant\u2019s digital wallets.\n\n - 14 -\n\fCase 1:25-cv-05745-RPK-CHK Document 504-1 Filed 09/11/26 Page 16 of 18 PageID\n #: 13195\n\n\n\n SPECIAL INTERROGATORY NO. 11:\n\n Identify any documents, emails, text messages, or other communications relating in any way\n to the relationship between Chen Zhi and LuBian.\n\n RESPONSE TO SPECIAL INTERROGATORY NO. 11:\n\n Claimant objects to this Interrogatory to the extent it exceeds the permissible scope of Rule\n\n G(6), which authorizes special interrogatories \u201climited to the claimant\u2019s identity and relationship to\n the defendant property,\u201d and of the Court\u2019s text order of February 17, 2026, which permitted\n\n Plaintiff to serve special interrogatories \u201climited to each claimant\u2019s identity and relationship to the\n\n defendant property.\u201d Claimant further objects to this Interrogatory as overbroad, unduly\n\n burdensome, and seeking information that is irrelevant or disproportionate to the needs of the case.\n Claimant further objects to this Interrogatory on the ground that it seeks information not in\n\n Claimant\u2019s possession, custody, or control.\n\n Accordingly, Claimant declines to respond to this Interrogatory.\n SPECIAL INTERROGATORY NO. 12:\n\n State the relationship between your interest in the Defendant Cryptocurrency and that\n\n asserted by claimants Chen Zhi, Prince Holding Group, Warp Data and Jian Yang, and explain the\n\n difference between their interests and yours.\n RESPONSE TO SPECIAL INTERROGATORY NO. 12:\n\n Claimant objects to this Interrogatory to the extent it exceeds the permissible scope of Rule\n\n G(6), which authorizes special interrogatories \u201climited to the claimant\u2019s identity and relationship to\n\n the defendant property,\u201d and of the Court\u2019s text order of February 17, 2026, which permitted\n Plaintiff to serve special interrogatories \u201climited to each claimant\u2019s identity and relationship to the\n\n defendant property.\u201d Claimant further objects to this Interrogatory as overbroad, unduly\n\n burdensome, and seeking information that is irrelevant or disproportionate to the needs of the case.\n Claimant further objects to this Interrogatory on the ground that it seeks information not in\n\n Claimant\u2019s possession, custody, or control. Claimant further objects to the extent that this\n\n\n\n - 15 -\n\fCase 1:25-cv-05745-RPK-CHK Document 504-1 Filed 09/11/26 Page 17 of 18 PageID\n #: 13196\n\n\n\n Interrogatory seeks information about claims asserted by other claimants, and is thus properly\n\n directed to those claimants, not to Claimant.\n Accordingly, Claimant declines to respond to this Interrogatory, except to refer Plaintiff to\n\n Claimant\u2019s Responses to Special Interrogatories Nos. 4, 8, 9 and 10.\n\n SPECIAL INTERROGATORY NO. 13:\n\n For the purpose of identifying potential witnesses whose depositions may be taken, provide\n the names, addresses and contract information of all individuals associated with LuBian who\n\n possess information relating to the relationship between that entity and Chen Zhi. If such persons\n\n are represented by counsel, also provide the contact information for such counsel.\n\n RESPONSE TO SPECIAL INTERROGATORY NO. 13:\n Claimant objects to this Interrogatory to the extent it exceeds the permissible scope of Rule\n\n G(6), which authorizes special interrogatories \u201climited to the claimant\u2019s identity and relationship to\n\n the defendant property,\u201d and of the Court\u2019s text order of February 17, 2026, which permitted\n Plaintiff to serve special interrogatories \u201climited to each claimant\u2019s identity and relationship to the\n\n defendant property.\u201d Claimant further objects to this Interrogatory as overbroad, unduly\n\n burdensome, and seeking information that is irrelevant or disproportionate to the needs of the case.\n\n Claimant further objects to this Interrogatory on the ground that it seeks information not in\n Claimant\u2019s possession, custody, or control.\n\n Accordingly, Claimant declines to respond to this Interrogatory.\n\n Dated: April 28, 2026 Respectfully submitted,\n\n By: Jeffrey A Brown\n\n Jeffrey A. Brown\n DECHERT LLP\n Three Bryant Park\n 1095 Avenue of the Americas\n New York, NY 10036\n Tel.: +1 212 698 3500\n jeffrey.brown@dechert.com\n\n Counsel for Claimant LuBian\n\n - 16 -\n\fCase 1:25-cv-05745-RPK-CHK Document 504-1 Filed 09/11/26 Page 18 of 18 PageID\n #: 13197\n\n\n\n VERIFICATION\n\n\n I, of LuBian, declare under penalty of perjury that the foregoing responses\n\n to the United States\u2019 Special Interrogatories to Claimant LuBian are true, accurate, and complete to\n\n the best of my knowledge and belief, with the understanding that Claimant is continuing to\n\n investigate and research its responses to these Special Interrogatories and reserves the right to\n supplement these responses as necessary.\n\n\n\n Executed: April 28, 2026\n\n\n\n\n - 18 -\n NA_DECHERT.95148189.2\n\f","ocr_status":1,"date_upload":"2026-09-11T14:43:17.981721-07:00","document_number":"504","attachment_number":1,"pacer_doc_id":"123024175551","is_available":true,"is_free_on_pacer":null,"is_sealed":false,"document_type":2,"description":"Exhibit A","acms_document_guid":""}],"date_created":"2026-09-11T14:43:11.624434-07:00","date_modified":"2026-09-11T14:53:43.211506-07:00","date_filed":"2026-09-11","time_filed":"17:41:45","entry_number":504,"recap_sequence_number":"2026-09-11.001","pacer_sequence_number":4095,"description":"MOTION to Compel as to LuBian by United States of America. (Attachments: (1) Exhibit A) (Brown, Christopher)","tags":[]},{"resource_uri":"https://www.courtlistener.com/api/rest/v4/docket-entries/476985487/","id":476985487,"docket":"https://www.courtlistener.com/api/rest/v4/dockets/71639393/","recap_documents":[{"resource_uri":"https://www.courtlistener.com/api/rest/v4/recap-documents/492563987/","id":492563987,"tags":[],"absolute_url":"","date_created":"2026-09-04T09:54:28.102651-07:00","date_modified":"2026-09-04T09:54:28.102663-07:00","sha1":"","page_count":null,"file_size":null,"filepath_local":null,"filepath_ia":"","ia_upload_failure_count":null,"thumbnail":null,"thumbnail_status":0,"plain_text":"","ocr_status":null,"date_upload":null,"document_number":"","attachment_number":null,"pacer_doc_id":"","is_available":false,"is_free_on_pacer":null,"is_sealed":null,"document_type":1,"description":"Order(Other)","acms_document_guid":""}],"date_created":"2026-09-04T09:54:28.090848-07:00","date_modified":"2026-09-04T09:54:28.090859-07:00","date_filed":"2026-09-04","time_filed":"12:44:54","entry_number":null,"recap_sequence_number":"2026-09-04.001","pacer_sequence_number":null,"description":"","tags":[]},{"resource_uri":"https://www.courtlistener.com/api/rest/v4/docket-entries/476985080/","id":476985080,"docket":"https://www.courtlistener.com/api/rest/v4/dockets/71639393/","recap_documents":[{"resource_uri":"https://www.courtlistener.com/api/rest/v4/recap-documents/492563529/","id":492563529,"tags":[],"absolute_url":"","date_created":"2026-09-04T09:46:14.341830-07:00","date_modified":"2026-09-04T09:46:14.341855-07:00","sha1":"","page_count":null,"file_size":null,"filepath_local":null,"filepath_ia":"","ia_upload_failure_count":null,"thumbnail":null,"thumbnail_status":0,"plain_text":"","ocr_status":null,"date_upload":null,"document_number":"","attachment_number":null,"pacer_doc_id":"","is_available":false,"is_free_on_pacer":null,"is_sealed":null,"document_type":1,"description":"Order","acms_document_guid":""}],"date_created":"2026-09-04T09:46:14.330480-07:00","date_modified":"2026-09-04T09:46:14.330502-07:00","date_filed":"2026-09-04","time_filed":null,"entry_number":null,"recap_sequence_number":"2026-09-04.001","pacer_sequence_number":null,"description":"ORDER: The 501 crossclaims filed by the 9/11 Claimants are held in abeyance pending the resolution of their 66 160 258 493 motions for leave to file verified claims in this case. Ordered by Judge Rachel P. Kovner on 9/4/2026. (AFK)","tags":[]},{"resource_uri":"https://www.courtlistener.com/api/rest/v4/docket-entries/476913371/","id":476913371,"docket":"https://www.courtlistener.com/api/rest/v4/dockets/71639393/","recap_documents":[{"resource_uri":"https://www.courtlistener.com/api/rest/v4/recap-documents/492489493/","id":492489493,"tags":[],"absolute_url":"/docket/71639393/503/united-states-v-approximately-127271-bitcoin-btc-previously-stored-at/","date_created":"2026-09-03T18:05:46.816887-07:00","date_modified":"2026-09-09T09:35:53.021150-07:00","sha1":"14d5b58441e2adbc5c288af942f949a9679bdddd","page_count":2,"file_size":142971,"filepath_local":"recap/gov.uscourts.nyed.537552/gov.uscourts.nyed.537552.503.0.pdf","filepath_ia":"https://archive.org/download/gov.uscourts.nyed.537552/gov.uscourts.nyed.537552.503.0.pdf","ia_upload_failure_count":1,"thumbnail":null,"thumbnail_status":0,"plain_text":"Case 1:25-cv-05745-RPK-CHK Document 503 Filed 09/03/26 Page 1 of 2 PageID #:\n 13170\n\n\n\n 787 Seventh Avenue\n New York, NY 10019-6099\n Tel: 212 728 8000\n Fax: 212 728 8111\n\n\nVIA ECF\n\nSeptember 3, 2026\n\nHon. Rachel P. Kovner\nUnited States District Judge\nEastern District of New York\n225 Cadman Plaza East\nBrooklyn, NY 11201\n\nRe: United States v. Approximately 127,271 Bitcoin, No. 1:25-cv-5745 (RPK)\n\nDear Judge Kovner:\n\n The Gold Star Claimants respectfully submit this letter with respect to the 9/11 Claimants\u2019\nAmended Answer and Cross-Claims (ECF No. 501). The 9/11 Claimants\u2019 cross-claims seek, among\nother things, \u201ca declaration that, as a matter of New York and federal law, their claims are entitled to\npriority\u2014in order to facilitate an equitable distribution among all Iran terror victims\u2014over all competing\nclaims for the purpose of execution and attachment, including but not limited to competing forfeiture\nclaims, terrorism judgment creditors, execution creditors, and non-TRIA claimants.\u201d ECF No. 501, at\n15. The 9/11 Claimants\u2019 original cross-claims, filed February 27, sought substantially identical relief.\nSee ECF No. 261, at 15.\n\n On March 13, before the deadline to answer the 9/11 Claimants\u2019 initial cross-claim, the Court\nheld those cross-claims in abeyance \u201cpending the resolution of their motions for an extension to file a\nverified claim in this case.\u201d Text-Only Order of Mar. 13, 2026. The Court has yet to do so with respect\nto the 9/11 Claimants\u2019 substantially identical amended cross-claims, which were amended \u201csolely to add\nthe claims of\u201d certain additional claimants. ECF No. 501, at 1 n.1.\n\n The Gold Star Claimants respectfully request that the Court clarify (or order) that the 9/11\nClaimants\u2019 Amended Cross-Claims are held in abeyance.\n\n In the alternative, the Gold Star Claimants respectfully request an extension to and including\nSeptember 18, 2026 to answer or otherwise respond to the 9/11 Claimants\u2019 Amended Cross-Claims.\n\n Respectfully submitted,\n\n /s/ Aaron E. Nathan\n\n Michael J. Gottlieb\n WILLKIE FARR & GALLAGHER LLP\n 2029 Century Park East\n\n\n B RUSSELS C HICAGO F RANKFURT H OUSTON L ONDON L OS A NGELES M ILAN\n N EW Y ORK P ALO A LTO P ARIS R OME S AN F RANCISCO W ASHINGTON\n\fCase 1:25-cv-05745-RPK-CHK Document 503 Filed 09/03/26 Page 2 of 2 PageID #:\n 13171\nSeptember 3, 2026\nPage 2\n\n Los Angeles, CA 90067-2905\n Tel: (310) 855-3000\n Fax: (310) 855-3099\n mgottlieb@willkie.com\n\n Nicholas Reddick (admitted pro hac vice)\n WILLKIE FARR & GALLAGHER LLP\n 333 Bush Street\n San Francisco, CA 94104\n Tel: (415) 858-7400\n Fax: (415) 858-7599\n nreddick@willkie.com\n\n Lee Wolosky\n Aaron E. Nathan\n WILLKIE FARR & GALLAGHER LLP\n 787 Seventh Avenue\n New York, NY 10019-6099\n Tel: (212) 728-8000\n Fax: (212) 728-8111\n lwolosky@willkie.com\n anathan@willkie.com\n\n Counsel for Gold Star Claimants\n\f","ocr_status":1,"date_upload":"2026-09-03T18:05:47.163731-07:00","document_number":"503","attachment_number":null,"pacer_doc_id":"123024150262","is_available":true,"is_free_on_pacer":null,"is_sealed":false,"document_type":1,"description":"Letter","acms_document_guid":""}],"date_created":"2026-09-03T18:05:46.788815-07:00","date_modified":"2026-09-09T06:24:27.835865-07:00","date_filed":"2026-09-03","time_filed":"21:03:31","entry_number":503,"recap_sequence_number":"2026-09-03.001","pacer_sequence_number":4091,"description":"Letter re. 9/11 Claimants' Amended Cross-Claims by Gold Star Claimants (Nathan, Aaron) (Entered: 09/03/2026)","tags":[]},{"resource_uri":"https://www.courtlistener.com/api/rest/v4/docket-entries/476509184/","id":476509184,"docket":"https://www.courtlistener.com/api/rest/v4/dockets/71639393/","recap_documents":[{"resource_uri":"https://www.courtlistener.com/api/rest/v4/recap-documents/492073761/","id":492073761,"tags":[],"absolute_url":"/docket/71639393/502/united-states-v-approximately-127271-bitcoin-btc-previously-stored-at/","date_created":"2026-09-01T07:24:11.744110-07:00","date_modified":"2026-09-08T22:24:54.498292-07:00","sha1":"ed1984bcda4a920b820af5abcb06933bd692c2d8","page_count":3,"file_size":116481,"filepath_local":"recap/gov.uscourts.nyed.537552/gov.uscourts.nyed.537552.502.0_1.pdf","filepath_ia":"https://archive.org/download/gov.uscourts.nyed.537552/gov.uscourts.nyed.537552.502.0.pdf","ia_upload_failure_count":null,"thumbnail":null,"thumbnail_status":0,"plain_text":"Case 1:25-cv-05745-RPK-CHK Document 502 Filed 08/31/26 Page 1 of 3 PageID #:\n 13167\n\n\n\n UNITED STATES DISTRICT COURT\n EASTERN DISTRICT OF NEW YORK\n\n -------------------------------------------------------------X\n UNITED STATES OF AMERICA,\n Plaintiff,\n 1:25-cv-05745-RPK\n v.\n\n APPROXIMATELY 127,271 BITCOIN (BTC) PREVIOUSLY\n STORED AT THE VIRTUAL CURRENCY ADDRESSES\n LISTED IN ATTACHMENT A, AND ALL PROCEEDS\n TRACEABLE THERETO,\n Defendants In Rem.\n -------------------------------------------------------------X\n\n CLAIMANT RAVI ANAND'S ANSWER TO THE 9/11 CLAIMANTS'\n CROSS-CLAIM AND COUNTERCLAIM\n\n Claimant Ravi Anand (\u201cClaimant\u201d), appearing pro se, hereby answers the Cross-Claim and\n Counterclaim (the \u201cTRIA Claims\u201d) asserted by the O\u2019Neill, Burnett, Ashton, and Ashton-\n Burlingame Claimants (collectively, the \u201c9/11 Claimants\u201d) in their Second Amended Answer to\n Verified Complaint In Rem (ECF No. 501), to the extent the TRIA Claims are directed at\n Claimant as one of \u201call other claimants asserting an interest in the Defendant Cryptocurrency\n who appear in this action.\u201d Claimant states as follows:\n\n GENERAL RESPONSE\n\n 1. Claimant lacks knowledge or information sufficient to form a belief as to the truth of the\n allegations concerning the Iran-China Group, LuBian, the Rafsanjan mining facility, Chen\u2019s\n alleged fraud and money laundering schemes, or any other factual matter set forth in the 9/11\n Claimants\u2019 Second Amended Answer to Verified Complaint In Rem, and on that basis denies\n each such allegation.\n\n 2. Claimant admits that he has filed a Verified Claim in this action asserting an interest in a\n portion of the Defendant Cryptocurrency as a victim of fraud whose stolen funds Claimant\n contends are traceable to the Defendant Cryptocurrency.\n\n 3. Claimant denies that the 9/11 Claimants\u2019 asserted priority under the Terrorism Risk Insurance\n Act (\u201cTRIA\u201d), N.Y. C.P.L.R. \u00a7 5234, N.Y. C.P.L.R. Article 62, or any other authority cited in\n the Cross-Claim and Counterclaim is superior to Claimant\u2019s interest in the Defendant\n Cryptocurrency.\n\n RESPONSE TO NUMBERED PARAGRAPHS\n\n 4. In response to Paragraphs 1 through 9 of the Cross-Claim and Counterclaim (jurisdiction,\n venue, and background allegations), Claimant admits that this Court has jurisdiction over the\n\n\n 1\n\fCase 1:25-cv-05745-RPK-CHK Document 502 Filed 08/31/26 Page 2 of 3 PageID #:\n 13168\n\n\n\n underlying in rem forfeiture action and that venue is proper for purposes of Claimant\u2019s own\n Verified Claim. Claimant lacks knowledge or information sufficient to admit or deny the\n remaining allegations of Paragraphs 1 through 9, including the 9/11 Claimants\u2019 asserted\n judgments against Iran and the nature and scope of the TRIA Claims, and on that basis denies\n same. Claimant further denies, to the extent Paragraph 4 characterizes Claimant as a party\n against whom the 9/11 Claimants are entitled to relief, that any such entitlement exists. Claimant\n notes that Paragraph 5 states that the TRIA Claims \u201cdo not seek adjudication of priority until the\n universe of legally permissible claimants in this action is established,\u201d and Claimant reserves all\n rights to be heard, and to present evidence and argument, at such time as priority among\n claimants is actually adjudicated.\n\n 5. In response to the First Count (Priority under CPLR 5234), Paragraphs 10 through 15,\n Claimant denies that the 9/11 Claimants have priority over Claimant\u2019s interest in the Defendant\n Cryptocurrency under CPLR 5234 or CPLR 5240, and denies each allegation in Paragraphs 10\n through 15 to the extent it purports to establish such priority over Claimant.\n\n 6. In response to the Second Count (Priority under CPLR Article 62), Paragraphs 16 through 19,\n Claimant denies that the 9/11 Claimants have priority over Claimant\u2019s interest in the Defendant\n Cryptocurrency under CPLR Article 62 or CPLR 5240, and denies each allegation in Paragraphs\n 16 through 19 to the extent it purports to establish such priority over Claimant.\n\n 7. In response to the Third Count (Priority under TRIA \u00a7 201), Paragraphs 20 through 24,\n Claimant denies that TRIA \u00a7 201, or the \u201cnotwithstanding\u201d clause therein, subordinates\n Claimant\u2019s interest in the Defendant Cryptocurrency \u2014 which Claimant contends derives from\n funds stolen from him through fraud and traceable to the Defendant Cryptocurrency \u2014 to the\n 9/11 Claimants\u2019 asserted priority, and denies each allegation in Paragraphs 20 through 24 to the\n extent it purports to establish such priority over Claimant.\n\n 8. In response to the Fourth Count (Declaratory Relief), Paragraphs 25 through 27, Claimant\n denies that the 9/11 Claimants are entitled to a declaration of priority over Claimant\u2019s interest in\n the Defendant Cryptocurrency, and denies each allegation in Paragraphs 25 through 27 to the\n extent directed at Claimant.\n\n AFFIRMATIVE AND OTHER DEFENSES\n\n 1. Claimant\u2019s interest in the portion of the Defendant Cryptocurrency traceable to funds stolen\n from him arises from his status as a direct victim of fraud and is not subordinate to the 9/11\n Claimants\u2019 judgment-creditor claims against Iran.\n\n 2. The TRIA Claims, as pleaded, expressly do not seek adjudication of priority at this time\n (Cross-Claim \u00b6 5), and any adjudication of priority as to Claimant at this stage is therefore\n premature.\n\n 3. Claimant reserves the right to assert additional or amended defenses as the priority dispute\n among claimants is further briefed and as discovery, if any, proceeds.\n\n\n\n\n 2\n\fCase 1:25-cv-05745-RPK-CHK Document 502 Filed 08/31/26 Page 3 of 3 PageID #:\n 13169\n\n\n\n 4. Claimant reserves all rights, remedies, and defenses available to him as a claimant of record in\n this action, including without limitation any defense or objection relating to notice, service, or\n the timeliness of this Answer.\n\n WHEREFORE, Claimant Ravi Anand respectfully requests that the Court deny the 9/11\n Claimants\u2019 request for a declaration of priority over Claimant\u2019s interest in the Defendant\n Cryptocurrency, preserve Claimant\u2019s interest and right to be heard on any future adjudication of\n priority among claimants, and grant such other and further relief as the Court deems just and\n proper.\n\n\n Dated: August 31st, 2026\n\n Respectfully submitted,\n\n /s/ Ravi Anand\n Ravi Anand\n Claimant, Pro Se\n 1165 N. Clark St. #700\n Chicago, IL 60610\n\n\n CERTIFICATE OF SERVICE\n\n I hereby certify that on August 31st, 2026, I filed the foregoing Answer with the Clerk of Court\n through the Court\u2019s CM/ECF system, which will effect service upon all registered counsel and\n self-represented parties entitled to electronic service in this action.\n\n /s/ Ravi Anand\n Ravi Anand\n Claimant, Pro Se\n\n\n\n\n 3\n\f","ocr_status":2,"date_upload":"2026-09-02T17:06:42.922773-07:00","document_number":"502","attachment_number":null,"pacer_doc_id":"123024137391","is_available":true,"is_free_on_pacer":null,"is_sealed":false,"document_type":1,"description":"Answer to Counterclaim","acms_document_guid":""}],"date_created":"2026-09-01T07:24:11.705218-07:00","date_modified":"2026-09-02T17:07:25.833527-07:00","date_filed":"2026-08-31","time_filed":null,"entry_number":502,"recap_sequence_number":"2026-08-31.001","pacer_sequence_number":4089,"description":"ANSWER to 501 Amended Crossclaim, Counterclaim, filed by Ravi Anand. (VRM) (Entered: 09/01/2026)","tags":[]},{"resource_uri":"https://www.courtlistener.com/api/rest/v4/docket-entries/475398013/","id":475398013,"docket":"https://www.courtlistener.com/api/rest/v4/dockets/71639393/","recap_documents":[{"resource_uri":"https://www.courtlistener.com/api/rest/v4/recap-documents/490928108/","id":490928108,"tags":[],"absolute_url":"/docket/71639393/501/united-states-v-approximately-127271-bitcoin-btc-previously-stored-at/","date_created":"2026-08-21T13:12:25.629118-07:00","date_modified":"2026-09-09T04:16:27.288739-07:00","sha1":"482405800fc4176e58a2eb0bbca8749eb90eea4e","page_count":23,"file_size":699536,"filepath_local":"recap/gov.uscourts.nyed.537552/gov.uscourts.nyed.537552.501.0_1.pdf","filepath_ia":"https://archive.org/download/gov.uscourts.nyed.537552/gov.uscourts.nyed.537552.501.0.pdf","ia_upload_failure_count":null,"thumbnail":"recap-thumbnails/gov.uscourts.nyed.537552/490928108.thumb.1068.png","thumbnail_status":1,"plain_text":"Case 1:25-cv-05745-RPK-CHK Document 501 Filed 08/21/26 Page 1 of 23 PageID #:\n 13144\n\n\n\n UNITED STATES DISTRICT COURT\n EASTERN DISTRICT OF NEW YORK\n\n UNITED STATES OF AMERICA,\n\n Plaintiff,\n v. JURY TRIAL DEMANDED\n\n APPROXIMATELY 127,271 BITCOIN\n (\u201cBTC\u201d) PREVIOUSLY STORED AT THE Civil Action No. 25-5745 (RPK)\n VIRTUAL CURRENCY ADDRESSES\n LISTED IN ATTACHMENT A, AND ALL\n PROCEEDS TRACEABLE THERETO,\n\n Defendant In Rem.\n\n\n 9/11 CLAIMANTS\u2019 SECOND AMENDED ANSWER TO VERIFIED COMPLAINT IN\n REM\n Pursuant to Rule G(5)(b) of the Federal Rules of Civil Procedure, the O\u2019Neill, Burnett,\n\n Ashton, and Ashton-Burlingame Claimants (together, the \u201c9/11 Claimants\u201d), on behalf of over\n\n 12,000 family members and individuals who either sustained physical injuries as victims of the\n\n September 11, 2001 terrorist attacks (the \u201c9/11 Attacks\u201d) or are the estate representatives of\n\n individuals killed in the 9/11 Attacks and have been awarded compensatory damages judgments\n\n totaling over approximately $93,698,050,499, exclusive of interest, under 28 U.S.C. \u00a7\u00a7 1605A and\n\n 1605B against the Islamic Republic of Iran (\u201cIran\u201d) for its role in sponsoring the 9/11 Attacks,\n\n hereby submit a second amended answer 1 to the United States government\u2019s Verified Complaint\n\n In Rem, dated October 14, 2025 (ECF No. 1), as follows: 2\n\n\n\n\n 1\n This Second Amended Answer is being submitted solely to add the claims of the Additional O\u2019Neill Claimants. See\n ECF Nos. 493-495 (July 31, 2026).\n 2\n A full list of the 9/11 Claimants is included as exhibits to the Verifications of the 9/11 Claimants\u2019 Claims. See ECF\n Nos. 160-3, 160-7, 160-11, 160-15, 163-1, 163-5, 163-9, 163-15, 258-3, 260-1, and 495-1.\n\n 1\n DOCS-100917792.1\n\fCase 1:25-cv-05745-RPK-CHK Document 501 Filed 08/21/26 Page 2 of 23 PageID #:\n 13145\n\n\n\n NATURE OF THE ACTION\n\n 1. The 9/11 Claimants admit the allegations in Paragraph 1, but deny that the United\n\n States has any right, title or interest in the Defendant Cryptocurrency that is superior to the right,\n\n title or interest of the 9/11 Claimants in the Defendant Cryptocurrency.\n\n 2. Paragraph 2 contains legal conclusions to which no response is required. To the\n\n extent a response is required, the 9/11 Claimants deny that any of the authorities referenced in\n\n Paragraph 2 confer on the United States any right, title or interest in the Defendant Cryptocurrency\n\n that is superior to the right, title or interest of the 9/11 Claimants in the Defendant Cryptocurrency.\n\n JURISDICTION AND VENUE\n\n 3. Paragraph 3 contains jurisdictional and legal conclusions to which no response is\n\n required. To the extent a response is required, the 9/11 Claimants admit that this Court has\n\n jurisdiction over this action pursuant to 28 U.S.C. \u00a7\u00a7 1345 and 1355.\n\n 4. Paragraph 4 contains jurisdictional and legal conclusions to which no response is\n\n required. To the extent a response is required, the 9/11 Claimants lack knowledge sufficient to\n\n confirm or deny the allegation that acts and omissions giving rise to the forfeiture occurred in the\n\n Eastern District of New York.\n\n THE DEFENDANTS IN REM\n\n 5. The 9/11 Claimants admit that the Defendant Cryptocurrency is the 127,271 Bitcoin\n\n that was once stored at the addresses listed in Attachment A to the Verified Complaint. The\n\n Defendant Cryptocurrency is owned by the Iran and China Investment Development Group (\u201cIran-\n\n China Group\u201d), an Iranian joint-stock company doing business as LuBian that partnered with the\n\n Iranian government to build a large Bitcoin mine in Rafsanjan, Iran to assist that country\u2019s\n\n longstanding efforts to evade U.S. sanctions.\n\n\n\n 2\n DOCS-100917792.1\n\fCase 1:25-cv-05745-RPK-CHK Document 501 Filed 08/21/26 Page 3 of 23 PageID #:\n 13146\n\n\n\n 6. On information and belief, the 9/11 Claimants admit the allegations in Paragraph\n\n 6.\n\n RELEVANT STATUTES AND REGULATIONS\n\n A. Wire Fraud\n\n 7. Paragraph 7 characterizes a statute that speaks for itself, and no response is\n\n required.\n\n 8. Paragraph 8 characterizes a statute that speaks for itself, and no response is\n\n required.\n\n B. Money Laundering\n\n 9. Paragraph 9 characterizes a statute that speaks for itself, and no response is\n\n required.\n\n 10. Paragraph 10 characterizes a statute that speaks for itself, and no response is\n\n required.\n\n 11. Paragraph 11 characterizes a statute that speaks for itself, and no response is\n\n required.\n\n 12. Paragraph 12 characterizes and purports to quote a statute that speaks for itself, and\n\n no response is required.\n\n C. Forfeiture Statutes\n\n 13. Paragraph 13 characterizes a statute that speaks for itself, and no response is\n\n required. To the extent a response is required, the 9/11 Claimants deny that any of the authorities\n\n referenced in Paragraph 13 confer on the United States any right, title or interest in the Defendant\n\n Cryptocurrency that is superior to the right, title or interest of the 9/11 Claimants in the Defendant\n\n Cryptocurrency.\n\n\n\n 3\n DOCS-100917792.1\n\fCase 1:25-cv-05745-RPK-CHK Document 501 Filed 08/21/26 Page 4 of 23 PageID #:\n 13147\n\n\n\n 14. Paragraph 14 characterizes a statute that speaks for itself, and no response is\n\n required. To the extent a response is required, the 9/11 Claimants deny that any of the authorities\n\n referenced in Paragraph 14 confer on the United States any right, title or interest in the Defendant\n\n Cryptocurrency that is superior to the right, title or interest of the 9/11 Claimants in the Defendant\n\n Cryptocurrency.\n\n FACTS\n\n A. Introduction\n\n 15. The 9/11 Claimants lack knowledge sufficient to confirm or deny the allegations in\n\n Paragraph 15.\n\n B. Relevant Individuals and Entities\n\n 16. On information and belief, the 9/11 Claimants admit that LuBian was the\n\n cryptocurrency mining pool and front for the Iran-China Group, an Iranian joint-stock company\n\n backed by Chinese investors that partnered with the Iranian government to build a large Bitcoin\n\n mine in Rafsanjan, Iran to assist that country\u2019s longstanding efforts to evade U.S. sanctions. The\n\n 9/11 Claimants further admit that the Iran-China Group maintained a Bitcoin mining facility in\n\n Iran. The 9/11 Claimants lack knowledge sufficient to confirm or deny the remaining allegations\n\n in Paragraph 16, including subsections (a) through (t) and (v) through (y).\n\n C. Relevant Terms and Definitions\n\n 17. The 9/11 Claimants admit the allegations in subsections (d) through (l) of Paragraph\n\n 17. The 9/11 Claimants lack knowledge sufficient to confirm or deny the remaining allegations in\n\n Paragraph 17, including subsections (a) through (c).\n\n\n\n\n 4\n DOCS-100917792.1\n\fCase 1:25-cv-05745-RPK-CHK Document 501 Filed 08/21/26 Page 5 of 23 PageID #:\n 13148\n\n\n\n D. The Criminal Schemes\n\n i. Background\n\n 18. The 9/11 Claimants lack knowledge sufficient to confirm or deny the allegations in\n\n Paragraph 18.\n\n 19. Paragraph 19 purports to quote a document that speaks for itself, and no response\n\n is required. The 9/11 Claimants lack knowledge sufficient to confirm or deny the remaining\n\n allegations in Paragraph 19.\n\n 20. The 9/11 Claimants lack knowledge sufficient to confirm or deny the allegations in\n\n Paragraph 20.\n\n ii. The Fraud Schemes\n\n 21. The 9/11 Claimants lack knowledge sufficient to confirm or deny the allegations in\n\n Paragraph 21.\n\n a. The Scam Compounds\n\n 22. The 9/11 Claimants lack knowledge sufficient to confirm or deny the allegations in\n\n Paragraph 22.\n\n 23. The 9/11 Claimants lack knowledge sufficient to confirm or deny the allegations in\n\n Paragraph 23.\n\n 24. The 9/11 Claimants lack knowledge sufficient to confirm or deny the allegations in\n\n Paragraph 24.\n\n 25. The 9/11 Claimants lack knowledge sufficient to confirm or deny the allegations in\n\n Paragraph 25.\n\n 26. The 9/11 Claimants lack knowledge sufficient to confirm or deny the allegations in\n\n Paragraph 26.\n\n\n\n 5\n DOCS-100917792.1\n\fCase 1:25-cv-05745-RPK-CHK Document 501 Filed 08/21/26 Page 6 of 23 PageID #:\n 13149\n\n\n\n b. The Use of Bribes and Violence in Furtherance of the Schemes\n\n 27. The 9/11 Claimants lack knowledge sufficient to confirm or deny the allegations in\n\n Paragraph 27.\n\n 28. The 9/11 Claimants lack knowledge sufficient to confirm or deny the allegations in\n\n Paragraph 28.\n\n 29. The 9/11 Claimants lack knowledge sufficient to confirm or deny the allegations in\n\n Paragraph 29.\n\n 30. The 9/11 Claimants lack knowledge sufficient to confirm or deny the allegations in\n\n Paragraph 30.\n\n 31. The 9/11 Claimants lack knowledge sufficient to confirm or deny the allegations in\n\n Paragraph 31.\n\n c. The Brooklyn Network\n\n 32. The 9/11 Claimants lack knowledge sufficient to confirm or deny the allegations in\n\n Paragraph 32.\n\n 33. The 9/11 Claimants lack knowledge sufficient to confirm or deny the allegations in\n\n Paragraph 33.\n\n 34. The 9/11 Claimants lack knowledge sufficient to confirm or deny the allegations in\n\n Paragraph 34.\n\n 35. The 9/11 Claimants lack knowledge sufficient to confirm or deny the allegations in\n\n Paragraph 35.\n\n 36. The 9/11 Claimants lack knowledge sufficient to confirm or deny the allegations in\n\n Paragraph 36.\n\n\n\n\n 6\n DOCS-100917792.1\n\fCase 1:25-cv-05745-RPK-CHK Document 501 Filed 08/21/26 Page 7 of 23 PageID #:\n 13150\n\n\n\n 37. The 9/11 Claimants lack knowledge sufficient to confirm or deny the allegations in\n\n Paragraph 37 and Footnote 2.\n\n iii. The Money Laundering Schemes\n\n 38. The 9/11 Claimants lack knowledge sufficient to confirm or deny the allegations in\n\n Paragraph 38.\n\n 39. The 9/11 Claimants lack knowledge sufficient to confirm or deny the allegations in\n\n Paragraph 39.\n\n 40. The 9/11 Claimants lack knowledge sufficient to confirm or deny the allegations in\n\n Paragraph 40 and Footnote 3.\n\n 41. Footnote 4 purports to quote a document that speaks for itself, and no response is\n\n required. The 9/11 Claimants lack knowledge sufficient to confirm or deny the allegations in\n\n Paragraph 41.\n\n 42. On information and belief, the 9/11 Claimants admit that the Iran-China Group\n\n doing business as LuBian operated a Bitcoin mining facility that \u201cproduced large sums of clean\n\n bitcoin dissociated from criminal proceeds.\u201d The 9/11 Claimants also admit that this was the sixth\n\n largest Bitcoin mining operation in the world for some of the time it was active. On information\n\n and belief, the 9/11 Claimants deny that the Iran- China Group was based in China. To the contrary,\n\n on information and belief, the Iran-China Group was an Iranian joint-stock company funded by\n\n Chinese investors that partnered with the Iranian government to build a large Bitcoin mine in\n\n Rafsanjan, Iran to assist that country\u2019s longstanding efforts to evade U.S. sanctions, and LuBian\n\n was the name of its cryptocurrency mining pool. The 9/11 Claimants deny any implication that\n\n Chen provided all of the financial support for the Iran-China Group\u2019s mining operations. The 9/11\n\n\n\n\n 7\n DOCS-100917792.1\n\fCase 1:25-cv-05745-RPK-CHK Document 501 Filed 08/21/26 Page 8 of 23 PageID #:\n 13151\n\n\n\n Claimants lack knowledge sufficient to confirm or deny the remaining allegations in Paragraph\n\n 42.\n\n 43. On information and belief, the 9/11 Claimants deny the implication that the wallets\n\n containing the Defendant Cryptocurrency were exclusively controlled by Chen. Rather, on\n\n information and belief, the Iran-China Group doing business as LuBian controlled the wallets\n\n containing the Defendant Cryptocurrency. The 9/11 Claimants lack knowledge sufficient to\n\n confirm or deny the remaining allegations in Paragraph 43 and Footnote 5.\n\n E. The Defendants In Rem\n\n 44. On information and belief, the 9/11 Claimants admit the allegations contained in\n\n Footnote 7 and that the government is seeking to forfeit Bitcoin that was stored at the 25\n\n cryptocurrency addresses identified in the table following Paragraph 44. 3 On information and\n\n belief, the 9/11 Claimants deny that the table following Paragraph 44 accurately identifies the\n\n amount of Bitcoin stored at each address in December 2020, provides a complete list of all\n\n addresses containing the Iran-China Group\u2019s Bitcoin in December 2020, or identifies all of the\n\n Bitcoin owned by the Iran-China Group that is currently in the government\u2019s possession. The 9/11\n\n Claimants also deny that the Defendant Cryptocurrency comprises solely the proceeds of Chen\u2019s\n\n fraud packaged as heavily laundered cryptocurrency. On information and belief, at least 11,166.51\n\n BTC of the Defendant Cryptocurrency are directly traceable to Bitcoin mined by the Iran-China\n\n Group\u2019s Rafsanjan mine, and all of the Defendant Cryptocurrency constituted the Iran-China\n\n Group\u2019s pool-level reserve of Bitcoin. The 9/11 Claimants lack knowledge sufficient to confirm\n\n or deny the remaining allegations in Paragraph 44 and Footnote 6.\n\n\n 3\n Throughout its Verified Complaint, including in Paragraphs 44, 46, 48, 49, 52, 55, and 56, the government describes\n the addresses that stored the Defendant Cryptocurrency in December 2020 as \u201cChen Wallets.\u201d The 9/11 Claimants\n deny that those addresses are properly described as \u201cChen Wallets\u201d to the extent the term implies that all the Defendant\n Cryptocurrency necessarily belonged to Chen.\n\n 8\n DOCS-100917792.1\n\fCase 1:25-cv-05745-RPK-CHK Document 501 Filed 08/21/26 Page 9 of 23 PageID #:\n 13152\n\n\n\n 45. On information and belief, the 9/11 Claimants admit that at least some of the\n\n cryptocurrency addresses were funded using Bitcoin newly mined by the Iran-China Group doing\n\n business as LuBian. The 9/11 Claimants lack knowledge sufficient to confirm or deny the\n\n remaining allegations in Paragraph 45 and Footnote 8.\n\n 46. The 9/11 Claimants lack knowledge sufficient to confirm or deny the allegations in\n\n Paragraph 46 and the following table.\n\n 47. On information and belief, the 9/11 Claimants admit that the four (4)\n\n cryptocurrency wallet addresses listed in Cluster Index-4 as described in subsection (d) and\n\n Footnote 9 of Paragraph 47 were associated with the Iran-China Group doing business as LuBian\n\n and were funded at least in part using the newly mined proceeds of the Iran-China Group\u2019s Bitcoin\n\n mining operations. On information and belief, the 9/11 Claimants deny any implication that the\n\n other cryptocurrency wallet addresses described in subsections (a) through (c) and (e) through (m)\n\n of Paragraph 47 were not associated with the Iran-China Group doing business as LuBian. On\n\n information and belief, to the contrary, all of the wallets described in Paragraph 47 were held by\n\n the Iran-China Group doing business as LuBian. On information and belief, the 9/11 Claimants\n\n also deny that Paragraph 47 accurately identifies the total amount of Bitcoin stored at the\n\n address(es) constituting each Cluster in December 2020. The 9/11 Claimants lack knowledge\n\n sufficient to confirm or deny the remaining allegations in Paragraph 47 and Footnote 9, including\n\n subparagraphs (a) through (m).\n\n 48. On information and belief, the 9/11 Claimants deny that all of the Defendant\n\n Cryptocurrency went \u201cthrough a process of high-volume disaggregation and funneling\u201d \u201cacross a\n\n complex network of hosted and unhosted cryptocurrency wallets,\u201d as at least some of the\n\n Defendant Cryptocurrency was Bitcoin that was newly mined by the Iran-China Group doing\n\n\n\n 9\n DOCS-100917792.1\n\fCase 1:25-cv-05745-RPK-CHK Document 501 Filed 08/21/26 Page 10 of 23 PageID\n #: 13153\n\n\n\n business as LuBian. The 9/11 Claimants lack knowledge sufficient to confirm or deny the\n\n remaining allegations in Paragraph 48.\n\n 49. The 9/11 Claimants lack knowledge sufficient to confirm or deny the allegations in\n\n Paragraph 49.\n\n 50. On information and belief, the 9/11 Claimants admit that the Defendant\n\n Cryptocurrency encompasses Bitcoin directly traceable to cryptocurrency that was newly mined\n\n by the Iran-China Group doing business as LuBian, though the 9/11 Claimants calculate that\n\n number as encompassing at least 11,166.51 BTC. The 9/11 Claimants lack knowledge sufficient\n\n to confirm or deny the remaining allegations in Paragraph 50.\n\n 51. The 9/11 Claimants lack knowledge sufficient to confirm or deny the allegations in\n\n Paragraph 51.\n\n 52. The 9/11 Claimants lack knowledge sufficient to confirm or deny the allegations in\n\n Paragraph 52.\n\n 53. The 9/11 Claimants lack knowledge sufficient to confirm or deny the allegations in\n\n Paragraph 53.\n\n 54. The 9/11 Claimants lack knowledge sufficient to confirm or deny the allegations in\n\n Paragraph 54.\n\n 55. The 9/11 Claimants lack knowledge sufficient to confirm or deny the allegations in\n\n Paragraph 55, including subsections (a) through (g).\n\n 56. The 9/11 Claimants lack knowledge sufficient to confirm or deny the allegations in\n\n Paragraph 56.\n\n 57. The 9/11 Claimants lack knowledge sufficient to confirm or deny the allegations in\n\n Paragraph 57.\n\n\n\n 10\n DOCS-100917792.1\n\fCase 1:25-cv-05745-RPK-CHK Document 501 Filed 08/21/26 Page 11 of 23 PageID\n #: 13154\n\n\n\n 58. On information and belief, the 9/11 Claimants admit the allegations in Paragraph\n\n 58.\n\n F. Criminal and Regulatory Actions\n\n 59. On information and belief, the 9/11 Claimants admit the allegations in Paragraph\n\n 59, but they deny any implication that they need a license from the United States Department of\n\n the Treasury\u2019s Office of Foreign Assets Control to attach and execute against the Defendant\n\n Cryptocurrency under the Terrorism Risk Insurance Act (\u201cTRIA\u201d).\n\n FIRST CLAIM FOR RELIEF\n (Proceeds Traceable to Wire Fraud)\n\n 60. The 9/11 Claimants incorporate and reallege each and every response to Paragraphs\n\n 1 through 59 set forth above as though set forth in full here.\n\n 61. Paragraph 61 contains legal conclusions to which no response is required. To the\n\n extent a response is required, the 9/11 Claimants deny that any of the allegations in Paragraph 61\n\n confer on the United States any right, title or interest in the Defendant Cryptocurrency that is\n\n superior to the right, title or interest of the 9/11 Claimants in the Defendant Cryptocurrency.\n\n 62. Paragraph 62 contains legal conclusions to which no response is required. To the\n\n extent a response is required, the 9/11 Claimants deny that any of the allegations in Paragraph 62\n\n confer on the United States any right, title or interest in the Defendant Cryptocurrency that is\n\n superior to the right, title or interest of the 9/11 Claimants in the Defendant Cryptocurrency.\n\n SECOND CLAIM FOR RELIEF\n (Property Involved in Money Laundering)\n\n 63. The 9/11 Claimants incorporate and reallege each and every response to Paragraphs\n\n 1 through 62 set forth above as though set forth in full here.\n\n 64. Paragraph 64 contains legal conclusions to which no response is required. To the\n\n extent a response is required, the 9/11 Claimants also deny that any of the allegations in Paragraph\n\n 11\n DOCS-100917792.1\n\fCase 1:25-cv-05745-RPK-CHK Document 501 Filed 08/21/26 Page 12 of 23 PageID\n #: 13155\n\n\n\n 64 confer on the United States any right, title or interest in the Defendant Cryptocurrency that is\n\n superior to the right, title or interest of the 9/11 Claimants in the Defendant Cryptocurrency.\n\n 65. Paragraph 65 contains legal conclusions to which no response is required. To the\n\n extent a response is required, the 9/11 Claimants deny that any of the allegations in Paragraph 65\n\n confer on the United States any right, title or interest in the Defendant Cryptocurrency that is\n\n superior to the right, title or interest of the 9/11 Claimants in the Defendant Cryptocurrency.\n\n AFFIRMATIVE AND OTHER DEFENSES\n\n The defenses asserted herein are based on the 9/11 Claimants\u2019 knowledge, information,\n\n and belief at this time. The 9/11 Claimants specifically reserve the right to assert additional\n\n affirmative defenses and other defenses and/or modify, amend, or supplement any defense\n\n contained herein at any time. Without admitting any of the facts alleged in the Complaint except\n\n as specifically set forth above, and without assuming any burden of proof, persuasion, or\n\n production not otherwise legally assigned to it as to any element of the government\u2019s claims, the\n\n 9/11 Claimants assert the following affirmative and other defenses:\n\n 1. The 9/11 Claimants possess an interest in the Defendant Cryptocurrency.\n\n 2. The 9/11 Claimants, as Judgment Creditors of the Islamic Republic of Iran, by\n\n operation of TRIA, 28 U.S.C. \u00a7 1610 note, hold an interest in the Defendant Cryptocurrency\n\n superior to the claims of the United States, as well as all other non-TRIA claimants,\n\n notwithstanding the instant civil forfeiture action.\n\n 3. The Defendant Cryptocurrency constitutes a \u201cblocked asset\u201d under TRIA, by virtue\n\n of Executive Order 13,559, 77 Fed. Reg. 6659 (Feb. 5, 2012).\n\n 4. The Defendant Cryptocurrency is the \u201cblocked asset\u201d of the Iran-China Group, an\n\n agency and instrumentality of the Islamic Republic of Iran, a \u201cterrorist party.\u201d\n\n\n\n 12\n DOCS-100917792.1\n\fCase 1:25-cv-05745-RPK-CHK Document 501 Filed 08/21/26 Page 13 of 23 PageID\n #: 13156\n\n\n\n 5. The 9/11 Claimants are entitled to execute and attach upon the Defendant\n\n Cryptocurrency because they have satisfied TRIA. Specifically, the 9/11 Claimants obtained their\n\n judgments against the Islamic Republic of Iran\u2014a terrorist party\u2014based on an act of terrorism;\n\n the Defendant Cryptocurrency is blocked under the International Emergency Economic Powers\n\n Act including through Executive Orders issued thereunder; and the Defendant Cryptocurrency is\n\n owned by the Iran and China Investment Development Group, an agency or instrumentality of\n\n Iran.\n\n 6. Claims of law and equity in this forfeiture action brought by the United States\n\n cannot override statutory priority rights conferred by TRIA or constitutional due process\n\n protections owed to the 9/11 Claimants. To the extent a forfeiture may be imposed in a manner\n\n that operates punitively against the 9/11 Claimants\u2019 asserted statutory interests, such forfeiture\n\n would be constitutionally excessive and invalid.\n\n 7. The 9/11 Claimants specifically deny each and every assertion of fact or law by the\n\n United States that the Defendant Cryptocurrency is in any way the property of the United States,\n\n or that the United States has any legal, equitable or any other right to it. Upon information and\n\n belief, the Defendant Cryptocurrency was the property of the Iran and China Investment\n\n Development Group, a joint venture between the underlying criminal defendants and the Islamic\n\n Revolutionary Guard Corps, doing business as LuBian and mining the blockchain as Lubian.com,\n\n that partnered with the Iranian government to build a large Bitcoin mine in Rafsanjan, Iran to assist\n\n that country\u2019s longstanding efforts to evade sanctions imposed by the United States and other\n\n\n\n\n 13\n DOCS-100917792.1\n\fCase 1:25-cv-05745-RPK-CHK Document 501 Filed 08/21/26 Page 14 of 23 PageID\n #: 13157\n\n\n\n countries. Therefore, the 9/11 Claimants are entitled to execute and attach upon the Defendant\n\n Cryptocurrency because they have satisfied TRIA.\n\n 8. The Fifth Amendment provides that \u201c[n]o person shall be deprived of life, liberty,\n\n or property without due process of law.\u201d U.S. Const. amend. V. Because of their claim under\n\n TRIA, the 9/11 Claimants have a property interest in the Defendant Cryptocurrency governed by\n\n the Fifth Amendment. As a result, forfeiting the Defendant Cryptocurrency to the government\n\n without \u201cdue process of law\u201d would violate the 9/11 Claimants\u2019 rights under the Fifth Amendment.\n\n 9. The Fifth Amendment also provides that \u201cprivate property\u201d shall not \u201cbe taken for\n\n public use, without just compensation.\u201d U.S. Const. amend. V. Because of the 9/11 Claimants\u2019\n\n property interest in the Defendant Cryptocurrency, forfeiting that property to the government\n\n would result in a taking of their property without just compensation.\n\n 10. To the extent the Defendant Cryptocurrency is not required to be transferred to the\n\n 9/11 Claimants, it is required to be deposited into the United States Victims of State Sponsored\n\n Terrorism Fund. See 34 U.S.C. \u00a7 20144(e)(2)(A).\n\n 11. The United States\u2019 claim for forfeiture is barred in whole or in part by the doctrine\n\n of unclean hands because, upon information and belief, the United States omitted material\n\n information regarding the connections between the Defendant Cryptocurrency and the Islamic\n\n Republic of Iran, thereby failing to provide adequate notice to the 9/11 Claimants that demonstrates\n\n the 9/11 Claimants\u2019 interest in the Defendant Cryptocurrency and/or the requirement that the\n\n Defendant Cryptocurrency be deposited into the United States Victims of State Sponsored\n\n Terrorism Fund.\n\n 12. The Defendant Cryptocurrency should be placed into a constructive trust for the\n\n benefit of all proper claimants who hold judgments against Iran as a result of terrorist acts.\n\n\n\n 14\n DOCS-100917792.1\n\fCase 1:25-cv-05745-RPK-CHK Document 501 Filed 08/21/26 Page 15 of 23 PageID\n #: 13158\n\n\n\n 13. The United States\u2019 claim for forfeiture is barred in whole or in part by the statute\n\n of limitations because the United States did not commence this action within the time period\n\n prescribed by 19 U.S.C. \u00a7 1621.\n\n 14. The forfeiture of the 9/11 Claimants\u2019 property would violate the Excessive Fines\n\n clause of the Eighth Amendment.\n\n 15. The 9/11 Claimants deny all allegations not expressly admitted herein and\n\n specifically reserve the right to amend this Answer, to raise additional defenses, cross-claims, and\n\n third-party claims not asserted herein as may be warranted by the revelation of information during\n\n further proceedings, and to pursue alternative remedies under civil forfeiture law.\n\n 16. The 9/11 Claimants incorporate by reference any defense that any other claimant\n\n pleads in this action, to the extent the defense applies to any claims against the Defendant\n\n Cryptocurrency, in whole or in part.\n\n CROSS-CLAIM AND COUNTERCLAIMS\n\n The 9/11 Claimants assert the following cross-claims and counterclaims (the \u201cTRIA\n\n Claims\u201d) against the United States and all other claimants asserting an interest in the Defendant\n\n Cryptocurrency who appear in this action. Therein, the 9/11 Claimants seek a declaration that, as\n\n a matter of New York and federal law, their claims are entitled to priority\u2014in order to facilitate\n\n an equitable distribution among all Iran terror victims\u2014over all competing claims for the purpose\n\n of execution and attachment, including but not limited to competing forfeiture claims, terrorism\n\n judgment creditors, execution creditors, and non-TRIA claimants, and allege as follows:\n\n 1. This Court has jurisdiction over the TRIA Claims pursuant to 28 U.S.C. \u00a7\u00a7 1331,\n\n 1345, 1355, and 1367, and Supplemental Rule G.\n\n 2. Venue is proper in this District because the TRIA Claims are ancillary to, and arise\n\n\n\n 15\n DOCS-100917792.1\n\fCase 1:25-cv-05745-RPK-CHK Document 501 Filed 08/21/26 Page 16 of 23 PageID\n #: 13159\n\n\n\n from, the same proceeding pending before this Court.\n\n 3. The 9/11 Claimants are judgment creditors of the Islamic Republic of Iran, holding\n\nfinal, unsatisfied judgments for damages arising from acts of state-sponsored terrorism.\n\n 4. The defendants to the TRIA Claims include the United States and all other parties\n\nwho assert any legal, equitable, possessory, property, or contingent interest in the Defendant\n\nCryptocurrency.\n\n 5. The TRIA Claims are asserted for the limited purpose of preserving the 9/11\n\nClaimants\u2019 priority rights in order to facilitate an equitable distribution among all Iran terror victims\n\nand do not seek adjudication of priority until the universe of legally permissible claimants in this\n\naction is established.\n\n 6. Through the TRIA Claims, the 9/11 Claimants, do not assert any cause of action\n\nagainst the United States, or any foreign sovereign, other than execution against blocked assets as\n\nspecifically permitted and authorized by TRIA, as set forth herein.\n\n 7. The 9/11 Claimants have filed a Verified Claim in this action and will pursue\n\njudicial authorization under 28 U.S.C. \u00a7 1610(c) to execute on their judgments.\n\n 8. The Defendant Cryptocurrency constitutes blocked assets of Iran and/or its agency\n\nor instrumentality, and is therefore subject to execution and attachment by the 9/11 Claimants\n\npursuant to TRIA \u00a7 201.\n\n 9. Multiple parties now assert competing interests in the Defendant Cryptocurrency,\n\nincluding the United States, other terrorism judgment creditors, and non-TRIA claimants.\n\n\n\n\n 16\n DOCS-100917792.1\n\fCase 1:25-cv-05745-RPK-CHK Document 501 Filed 08/21/26 Page 17 of 23 PageID\n #: 13160\n\n\n\n FIRST COUNT\n\n (Priority under CPLR 5234 \u2013 Executions, as modified by CPLR 5240)\n\n 10. The 9/11 Claimants restate and reallege the foregoing Paragraphs as if fully set\n\nforth herein.\n\n 11. Federal courts routinely apply state execution priority rules, including, but not\n\nlimited to, CPLR 5234, in aid of federal execution proceedings.\n\n 12. CPLR 5234(b) establishes a priority regime among judgment creditors executing\n\non the same property, keyed to the time of delivery of execution, levy, and related enforcement\n\nsteps as modified by CPLR 5240 that authorizes a \u201ccourt . . . at any time\u201d to \u201cmake an order denying,\n\nlimiting, conditioning, regulating, extending or modifying the use of any enforcement procedure.\u201d\n\n 13. Under CPLR 5234(c), where executions are returned unsatisfied or partially\n\nsatisfied, priority is preserved for creditors who first perfect execution rights as modified by CPLR\n\n5240 that authorizes a \u201ccourt . . . at any time\u201d to \u201cmake an order denying, limiting, conditioning,\n\nregulating, extending or modifying the use of any enforcement procedure.\u201d\n\n 14. The 9/11 Claimants have priority over competing judgment creditors under CPLR\n\n5234, as modified by CPLR 5240, in order to facilitate an equitable distribution among all Iran\n\nterror victims.\n\n 15. The 9/11 Claimants have acted diligently and in good faith to: (i) pursue\n\nauthorization orders under 28 U.S.C. \u00a7 1610(c); (ii) assert their claims in this action; and (iii) pursue\n\nexecution against the Defendant Cryptocurrency.\n\n\n\n\n 17\n DOCS-100917792.1\n\fCase 1:25-cv-05745-RPK-CHK Document 501 Filed 08/21/26 Page 18 of 23 PageID\n #: 13161\n\n\n\n SECOND COUNT\n\n (Priority under CPLR Article 62 \u2013 Attachment, as modified by CPLR 5240)\n\n 16. The 9/11 Claimants restate and reallege the foregoing Paragraphs as if fully set\n\nforth herein.\n\n 17. CPLR Article 62 governs prejudgment and post-judgment attachment and\n\nestablishes priority based on the timing of attachment orders, levy, and perfection as modified by\n\nCPLR 5240 that authorizes a \u201ccourt . . . at any time\u201d to \u201cmake an order denying, limiting,\n\nconditioning, regulating, extending or modifying the use of any enforcement procedure.\u201d\n\n 18. The 9/11 Claimants\u2019 attachment rights arise from final judgments, New York law,\n\nstatutory authorization under TRIA, and judicial permission under FSIA \u00a7 1610(c).\n\n 19. The 9/11 Claimants have priority over competing judgment creditors under CPLR\n\n5234, as modified by CPLR 5240, in order to facilitate an equitable distribution among all Iran\n\nterror victims.\n\n THIRD COUNT\n\n (Priority under TRIA \u00a7 201)\n\n 20. The 9/11 Claimants restate and reallege the foregoing Paragraphs as if fully set\n\nforth herein.\n\n 21. TRIA \u00a7 201(a) provides that, \u201c[n]otwithstanding any other provision of law,\u201d\n\nblocked assets of a terrorist party or its agency or instrumentality shall be subject to execution by\n\nholders of terrorism judgments.\n\n 22. TRIA\u2019s \u201cnotwithstanding\u201d clause preempts inconsistent state and federal law,\n\noverrides competing claims not grounded in TRIA, and elevates qualifying terrorism judgment\n\ncreditors over all non-TRIA claimants.\n\n\n\n 18\n DOCS-100917792.1\n\fCase 1:25-cv-05745-RPK-CHK Document 501 Filed 08/21/26 Page 19 of 23 PageID\n #: 13162\n\n\n\n 23. Federal courts have consistently recognized that TRIA creates a priority execution\n\nregime favoring holders of terrorism judgments over competing non-TRIA claimants.\n\n 24. Accordingly, even if competing claimants satisfy federal forfeiture and/or state-law\n\nexecution or attachment requirements, their claims are subordinate to the 9/11 Claimants\u2019 TRIA\n\nClaims.\n\n FOURTH COUNT\n\n (Declaratory Relief)\n\n 25. The 9/11 Claimants restate and reallege the foregoing Paragraphs as if fully set\n\nforth herein.\n\n 26. An actual and justiciable controversy exists concerning the relative priority of the\n\nparties\u2019 interests in the Defendant Cryptocurrency.\n\n 27. The 9/11 Claimants seek a declaration that: (i) they hold priority rights for\n\nexecution and attachment purposes in order to facilitate an equitable distribution among all Iran\n\nterror victims; (ii) any competing executions and/or attachments are subordinate to their TRIA\n\nClaims; and (iii) any distribution of the Defendant Cryptocurrency must respect that priority.\n\n JURY DEMAND\n\n Pursuant to Federal Rule of Civil Procedure 38(b) and Rule G(9) of the Supplemental Rules\n\nfor Admiralty or Maritime Claims and Asset Forfeiture Actions, the 9/11 Claimants demand a trial\n\nby jury on all issues so triable.\n\n PRAYER FOR RELEF\n\n WHEREFORE, the 9/11 Claimants respectfully request that the Court:\n\n 28. Order that judgment be entered in their favor and against Plaintiff and all other\n\nclaimants in this action.\n\n\n\n 19\n DOCS-100917792.1\n\fCase 1:25-cv-05745-RPK-CHK Document 501 Filed 08/21/26 Page 20 of 23 PageID\n #: 13163\n\n\n\n 29. Order that the Defendant Cryptocurrency be released from Plaintiff\u2019s custody and\n\nreturned to the 9/11 Claimants.\n\n 30. Declare the 9/11 Claimants\u2019 interests have priority over other parties for execution\n\nand attachment purposes under CPLR 5234, CPLR Article 62, CPLR 5240, TRIA \u00a7 201, FSIA \u00a7\n\n1610, and all other applicable laws, in order to facilitate an equitable distribution among all Iran\n\nterror victims.\n\n 31. Declare that any competing executions, attachments, liens, or asserted interests are\n\nsubordinate to the 9/11 Claimants\u2019 rights for execution and attachment purposes.\n\n 32. Order that the Defendant Cryptocurrency be preserved and maintained subject to\n\nthe Court\u2019s jurisdiction, and that no distribution or disposition affecting the priority of claimants\n\noccur unless and until the 9/11 Claimants\u2019 asserted statutory rights are adjudicated.\n\n 33. In the alternative, and only if the Court determines that the Defendant\n\nCryptocurrency, or any portion thereof, is not lawfully subject to execution and attachment by the\n\n9/11 Claimants, the Court should declare that any forfeiture, remission, or other disposition of such\n\nassets must be deposited into the United States Victims of State Sponsored Terrorism Fund pursuant\n\nto the statutory scheme set forth in 34 U.S.C. \u00a7 20144(e), and that no disposition inconsistent with\n\nthat statutory framework may occur.\n\n 34. Order that the 9/11 Claimants be awarded attorneys\u2019 fees and the costs of suit.\n\n 35. Grant the 9/11 Claimants such other and further relief as the Court deems just and\n\nproper.\n\n\n\n\n 20\n DOCS-100917792.1\n\fCase 1:25-cv-05745-RPK-CHK Document 501 Filed 08/21/26 Page 21 of 23 PageID\n #: 13164\n\n\n\nDated: August 21, 2026\n Respectfully submitted,\n\n ANDERSON KILL P.C.\n By: /s/ Jerry S. Goldman\n Jerry S. Goldman, Esq.\n Bruce E. Strong, Esq.\n Alexander A. Greene, Esq.\n 7 Times Square, 15th Floor\n New York, NY 10036\n Tel.: (212) 278-1000\n jgoldman@andersonkill.com\n bstrong@andersonkill.com\n agreene@andersonkill.com\n Attorneys for the O\u2019Neill Claimants\n\n\n KREINDLER & KREINDLER LLP\n By: /s/ Megan Wolfe Benett\n Justin T. Green, Esq.\n Megan Wolfe Benett, Esq.\n 485 Lexington Ave\n New York, NY 10017\n Tel.: (212) 973-3438\n jgreen@kreindler.com\n mbenett@kreindler.com\n Attorneys for the Ashton Claimants\n\n\n\n\n 21\n DOCS-100917792.1\n\fCase 1:25-cv-05745-RPK-CHK Document 501 Filed 08/21/26 Page 22 of 23 PageID\n #: 13165\n\n\n\n\n MOTLEY RICE LLC\n By: /s/ John M. Eubanks\n John M. Eubanks, Esq.\n John C. Duane, Esq.\n 28 Bridgeside Boulevard\n Mount Pleasant, SC 29465\n jeubanks@motleyrice.com\n jduane@motleyrice.com\n Tel.: (843) 216-9218\n Attorneys for the Burnett Claimants\n\n SPEISER KRAUSE, P.C.\n By: /s/ Jeanne M. O\u2019Grady\n Jeanne M. O\u2019Grady, Esq.\n 800 Westchester Avenue, Suite S-608\n Rye Brook, New York 10573\n jog@speiserkrause.com\n Tel.: (914) 220-5333\n Attorneys for the Ashton-Burlingame\n Claimants\n\n\n\n\n 22\n DOCS-100917792.1\n\fCase 1:25-cv-05745-RPK-CHK Document 501 Filed 08/21/26 Page 23 of 23 PageID\n #: 13166\n\n\n\n CERTIFICATE OF SERVICE\n\n I hereby certify that on August 21, 2026, I electronically filed the foregoing 9/11\n\n Claimants\u2019 Second Amended Answer to Verified Complaint In Rem via CM/ECF for the United\n\n States District Court for the Eastern District of New York and therefore caused it to be served on\n\n all parties registered for CM/ECF, including attorneys for the government, in the above-captioned\n\n matter.\n\n\n\n Dated: August 21, 2026 /s/ Jerry S. Goldman\n Jerry S. Goldman\n\n\n\n\n 23\n DOCS-100917792.1\n\f","ocr_status":2,"date_upload":"2026-09-02T17:07:06.015954-07:00","document_number":"501","attachment_number":null,"pacer_doc_id":"123024103415","is_available":true,"is_free_on_pacer":null,"is_sealed":false,"document_type":1,"description":"Amended Answer to Complaint AND Counterclaim AND Crossclaim","acms_document_guid":""}],"date_created":"2026-08-21T13:12:25.593148-07:00","date_modified":"2026-09-02T17:07:25.740792-07:00","date_filed":"2026-08-21","time_filed":"16:10:14","entry_number":501,"recap_sequence_number":"2026-08-21.001","pacer_sequence_number":3438,"description":"AMENDED ANSWER to 1 Complaint,, Second Amended Answer, CROSSCLAIM against All Parties, COUNTERCLAIM against All Parties by 9/11 Claimants. (Goldman, Jerry) (Entered: 08/21/2026)","tags":[]},{"resource_uri":"https://www.courtlistener.com/api/rest/v4/docket-entries/474499426/","id":474499426,"docket":"https://www.courtlistener.com/api/rest/v4/dockets/71639393/","recap_documents":[{"resource_uri":"https://www.courtlistener.com/api/rest/v4/recap-documents/490001585/","id":490001585,"tags":[],"absolute_url":"/docket/71639393/500/united-states-v-approximately-127271-bitcoin-btc-previously-stored-at/","date_created":"2026-08-14T10:59:11.117192-07:00","date_modified":"2026-08-22T20:50:50.599900-07:00","sha1":"7daa8374ef1d7a596a327d22c650fb6b73e71ffd","page_count":6,"file_size":503604,"filepath_local":"recap/gov.uscourts.nyed.537552/gov.uscourts.nyed.537552.500.0.pdf","filepath_ia":"https://archive.org/download/gov.uscourts.nyed.537552/gov.uscourts.nyed.537552.500.0.pdf","ia_upload_failure_count":null,"thumbnail":null,"thumbnail_status":0,"plain_text":"Case 1:25-cv-05745-RPK-CHK Document 500 Filed 08/14/26 Page 1 of 6 PageID #:\n 13090\n\n\n\n\n August 14, 2026\nBY ECF\nThe Honorable Clay H. Kaminsky\nUnited States Magistrate Judge\nUnited States District Court\nEastern District of New York\n225 Cadman Plaza East\nBrooklyn, New York 11201\n\n Re: United States v. Approximately 127,271 Bitcoin,\n 25 Civ. 5745 (RPK) (CHK)\n\nDear Judge Kaminsky:\n\n Claimants Chen Zhi and Prince Holding Group (\u201cClaimants\u201d) and the United States of\nAmerica (the \u201cgovernment\u201d) respectfully submit this joint letter motion pursuant to Rule II.C. of Your\nHonor\u2019s Individual Practices and Rules concerning Claimants\u2019 motion to compel the government to\nrespond to Claimants\u2019 First Sets of Interrogatories and First Requests for Production of Documents,\nserved on June 19, 2026. See Exs. A (Chen Zhi) and B (Prince Group) (the \u201cInterrogatories\u201d); Exs.\nC (Chen Zhi) and D (Prince Group) (the \u201cRFPs\u201d) (collectively, the \u201cDiscovery Requests\u201d).\n\n Background. Claimants served the Discovery Requests by email on June 19, 2026. The\ngovernment responded as follows by email on July 16, 2026:\n\n These requests are improper at this stage. Your clients have not established statutory or\n constitutional standing\u2014nor have you adequately responded to the government\u2019s first set of\n special interrogatories aimed at testing their standing. The United States is not required to\n submit to discovery by an unverified claimant who has failed to comply with the mandatory\n provisions of Supplemental Rule G.\n\nEx. E.\n\n Meet-and-Confer. The parties met and conferred regarding this discovery dispute by\nteleconference on August 4, 2026. The teleconference lasted approximately 15 minutes. Present on\nbehalf of the Claimants were Peter Skinner and Dan Boyle of Boies Schiller Flexner LLP, and on\nbehalf of the government were AUSAs Alexander Mindlin, Tanisha Payne, Alessandra Rafalson,\nBenjamin Weintraub, Andrew Reich, and Trial Attorney Christopher Brown. The government agreed\nduring the conference to review legal authority cited by Claimants, but the parties have since been\nunable to resolve their dispute without the Court\u2019s intervention. Accordingly, the parties respectfully\nsubmit that they have complied in good faith with the meet-and-confer requirements of Fed. R. Civ.\nP. 37(a)(1) and the Court\u2019s Individual Practices.\n\n * * *\n\fCase 1:25-cv-05745-RPK-CHK Document 500 Filed 08/14/26 Page 2 of 6 PageID #:\n 13091\n\n\n\n CLAIMANTS\u2019 POSITION\n\n The dispute before the Court is narrow: whether the government must respond to Claimants\u2019\ndiscovery demands while the government challenges their standing. The answer is yes, because\nClaimants have standing and have fully complied with their obligations to respond to the\ngovernment\u2019s special interrogatories. But even if there were a legitimate dispute as to Claimants\u2019\nstanding (which, respectfully, there is not), the government still cannot ignore the Discovery Requests,\nbecause they seek evidence relevant to standing\u2014the very issue the government disputes. Having put\nClaimants\u2019 interests in the Defendant Property at issue, the government cannot now withhold\nevidence relevant to that dispute. Nothing in the procedures specific to civil forfeiture changes that\nbedrock principle.1\n\n In response to the government\u2019s recent motion to compel, Claimants explained at length why\nthey have standing and why no further responses to the government\u2019s special interrogatories are\nrequired. See ECF No. 478, at 9-11. There is nothing further to say on that score. If the Court agrees,\nthen the government clearly cannot object on the basis that Claimants have not established standing.\nBut even if it disagrees, and Claimants are required to produce additional information in response to\nthe government\u2019s special interrogatories, the government must also be required to produce the\nevidence that it possesses relevant to Claimants\u2019 standing.\n\n The government plainly has evidence responsive to the Discovery Requests about the\nownership and control of the Bitcoin at issue. See United States v. Cambio Exacto, S.A., 166 F.3d 522,\n527 (2d Cir. 1999) (standing to challenge forfeiture turns on \u201cownership and possession because they\nare often reliable indicators of injury\u201d). For example, the Complaint alleges that Mr. Chen controlled\nthe relevant digital wallets, that the Bitcoin at issue was traceable to the Prince Group\u2019s \u201conline\ngambling and cryptocurrency mining\u201d operations, and that it was \u201csubsequently transferred\u201d to\ngovernment control. See ECF No. 1, at \u00b6\u00b6 38, 40, 44-45, 58; see also Fed. R. Civ. P. 11(b)(3) (by\nsigning the Complaint, the government\u2019s attorneys certified to the Court that their \u201cfactual contentions\nhave evidentiary support\u201d); Supp. R. G(2)(a) (requiring in rem forfeiture complaint to be verified).\nThe evidentiary support for these allegations is much of what is sought in the Discovery Requests.\nSee, e.g., Ex. B, at Rog Nos. 2-5, 7-8, 10-12; Ex. D, at RFP Nos. 2-7, 10, 13.\n\n Claimants are entitled to this discovery under Rule 26(b)(1), which permits discovery\n\u201cregarding any matter, not privileged, that is relevant to the claim or defense of any party.\u201d Standing\nis no exception. For example, in United States v. Sum of $70,990,605, the government moved to strike\na claimant on standing grounds, and the claimant cross-moved to compel production of discovery\nheld by the government which it argued was necessary to respond to the motion to strike. The court\nagreed, holding that the claimant was \u201centitled to any jurisdictional discovery that could help either\nestablish itself as an \u2018owner\u2019 or satisfy one of the two aforementioned exceptions to the ownership\nprovision.\u201d 305 F.R.D. 20, at 26-27 (D.D.C. 2015) (\u201cSince the United States\u2019 Motion to Strike \u2026 is\npredicated upon the notion that [claimant] AIB lacks the necessary statutory standing to become a\nclaimant, [] any interrogatories related to the issue of standing are relevant.\u201d). The court further\nrejected the same argument the government makes here\u2014that a claimant has no right to discovery\n\n1\n As a procedural matter, this case is exempted from Rule 26(a)\u2019s initial disclosure and discovery\nconference requirements. See Fed. R. Civ. P. 26(a)(1)(B)(ii) (including any \u201cforfeiture action in rem arising\nfrom a federal statute\u201d among excluded proceedings). And while Mr. Chen moved to dismiss this action, the\ngovernment has not responded to that motion, much less sought a stay of discovery while that motion is pending.\nAnd in any event, the Prince Holding Group answered the Complaint and has not moved to dismiss.\n\n 2\n\fCase 1:25-cv-05745-RPK-CHK Document 500 Filed 08/14/26 Page 3 of 6 PageID #:\n 13092\n\n\n\nuntil it establishes that it has standing to challenge the forfeiture action\u2014in finding that denying a\nclaimant such discovery \u201cwould be an overly broad measure that would deny [claimant] AIB the\nopportunity to establish statutory standing.\u201d Id., at 28.\n\n Closer to home, in United States v. The M/Y Amadea, Judge Ho in the Southern District of\nNew York ordered discovery far broader than what Claimants seek here before determining whether\na claimant had standing to contest forfeiture. See, e.g., No. 23 Civ. 9304 (DEH) (S.D.N.Y.) ECF No.\n17 (setting discovery deadlines for document requests, interrogatories, depositions, requests for\nadmission and expert discovery). Despite ultimately determining the claimant lacked standing, the\ncourt permitted the claimant to compel the production of documents, take depositions, and conduct\nexpert discovery. See United States v. M/Y Amadea, 770 F. Supp. 3d 558, 569-71 (S.D.N.Y. 2025)\n(describing how discovery period was extended four times to complete discovery).\n\n Put simply, the government cannot have it both ways. If it challenges Claimants\u2019 interests in\nthe Defendant Cryptocurrency (as it has), then Claimants are \u201centitled to review the information that\nformed the basis of [the] complaint,\u201d such as the allegations about who possessed the Defendant\nCryptocurrency before and after it was stolen, where it came from, and who transferred it to the\ngovernment and when. In re 650 Fifth Ave. & Related Props., 934 F.3d 147, 159 (2d Cir. 2019)\n(holding district court abused its discretion by denying claimants\u2019 motion to compel discovery,\nleaving the record \u201chardly developed\u201d and that claimants had not been afforded \u201ca full and fair\nopportunity to present evidence\u201d). And having made that challenge, the government cannot use its\nown motion to compel to avoid its discovery obligations.\n\n Nothing in the Federal Rules makes discovery seriatim; one party\u2019s discovery obligations are\nnot suspended while it seeks to compel discovery from another party. And the special rules for\nforfeiture do not change this default rule. While Rule G(6) interrogatories can delay the government\u2019s\nresponse to a motion to dismiss, the rule is limited to dispositive motions and does not address the\ngovernment\u2019s discovery obligations. Supp. R. G(6)(a); see also United States v. Starling, 76 F.4th 92,\n101 n.4 (2d Cir. 2023) (\u201cWhat we have described as \u2018statutory standing\u2019 operates as an obstacle only\nto dispositive motions which follow from establishing the initial claim.\u201d). Rather, as the civil forfeiture\nstatute makes clear (in addressing stays and protective orders), courts should not \u201callow one party to\npursue discovery while the other party is substantially unable to do so.\u201d See 18 U.S.C. \u00a7 981(g)(3)\n(governing discovery stays of forfeiture actions). There is simply no bar to a civil forfeiture claimant,\nlike Claimants here, seeking discovery on disputed standing issues.\n\n Lastly, the Court should require the government not only to respond to Claimants\u2019 Discovery\nRequests, but to produce the requested discovery in full, as the government waived any other\nobjections it may have by failing to object on any basis other than standing. See Fed. R. Civ. P.\n33(b)(4) (\u201cThe grounds for objecting to an interrogatory must be stated with specificity. Any ground\nnot stated in a timely objection is waived unless the court, for good cause, excuses the failure.\u201d);\nLabarbera v. Absolute Trucking, Inc., 2009 WL 2496463, at *1 (E.D.N.Y. Aug. 12, 2009) (\u201cIt is well\nestablished that by failing to respond or object to a discovery request in a timely manner, a party\nwaives any objection which may have been available.\u201d). The government could have, but chose not\nto, either serve objections to the Discovery Requests or seek a protective order. See, e.g., $70,990,605,\n305 F.R.D. at 27-28 (government moved for protective order so as not to respond to discovery\nrequests while standing was still at issue). Instead, it simply ignored the Discovery Requests, and\nshould be held to the consequences of that strategic decision.\n\n\n 3\n\fCase 1:25-cv-05745-RPK-CHK Document 500 Filed 08/14/26 Page 4 of 6 PageID #:\n 13093\n\n\n\n GOVERNMENT\u2019S POSITION\n\n It is axiomatic that a claimant cannot request discovery from the government before\nthe government has had an opportunity to test the claimant\u2019s standing. Claimants\u2019 discovery\nrequests (the \u201cRequests\u201d) seek to end-run that simple and widely observed rule.\n Claimants have not established standing. The government has served special\ninterrogatories on Claimants, and a motion is before the Court to compel them to respond. See ECF\nNos. 468, 486. As of now, the Court has not had an opportunity to rule on Claimants\u2019 standing\nthrough the motion-to-strike process, nor have Claimants even provided the responses necessary to\nevaluate that standing. And their standing is subject to serious doubt, for reasons discussed in the\ngovernment\u2019s motion to compel. See ECF Nos. 469, 486. Among many other defects, neither\nClaimant has set forth how much of the res is theirs, when or how they obtained it, or how their\nsupposed acquisition of the res was funded; Chen claims without elaboration to be a bailee of\nPrince Group and also asserts an ill-defined relationship with Lubian; and Chen is concededly\nunavailable, having taken no part in preparing his or Prince Group\u2019s interrogatory responses, such\nthat his responses are neither signed, sworn, nor even truly his.\n Of course, \u201c[a] putative claimant who lacks standing is \u2018simply a stranger to the\nlitigation\u2019 and \u2018lacks the right to bring any motion, regardless of the basis.\u2019\u201d United States v.\nVazquez-Alvarez, 760 F. 3d 193, 196-97 (2d Cir. 2014)). Accordingly, Rule G is structured to\nforeclose motion practice by would-be claimants until they can demonstrate standing. The Rule\ncontemplates the government\u2019s service of numerous special interrogatories (to explore \u201cfactually\ncomplex standing issues,\u201d see 2006 Cmte. Note); affords broad authority to serve those\ninterrogatories without leave of court; and provides that the \u201cGovernment\u2019s Response [is] Deferred\u201d\nto dispositive motions, while the government probes claimants\u2019 standing. Claimants\u2019 application\nturns this logic on its head, seeking to receive discovery from the government while Claimants\nneither have, nor apparently can, provide meaningful discovery of their own. See United States v.\nReal Property Located at 8 Drift Street, New Brunswick, New Jersey, No. 14-CV-3587 (MAS),\n2015 WL 13861803, at *1 (D.N.J. Apr. 21, 2015) (\u201cClaimant\u2019s motion to compel discovery is\npremature as there is a pending motion relating to Claimant\u2019s standing\u201d); United States v.\nApproximately One Million Seven Hundred Eighty Four Thousand (1,784,000) Contraband\nCigarettes of Assorted Brands from the Indian Country Smoke Shop Main Store, No. 12-CV-5992\n(BHS), 2016 WL 6084938, at *5 (W.D. Wash. Oct. 18, 2016) (\u201c[A]llowing [claimant] to seek\ndiscovery at this time could [] prove a wasteful endeavor, as the Government\u2019s motion to strike his\nclaim is currently pending before the Court.\u201d); United States v. $1,106,775.00 in United States\nCurrency, No. 20-CV-158 (MMD) (WGC), 2020 WL 6930103, at *3 (D. Nev. Nov. 23, 2020)\n(staying claimant\u2019s discovery requests \u201cpending [Claimant]\u2019s response to the special interrogatories\nand the resolution of Claimants\u2019 standing\u201d).\n Claimants are not \u201cdifferent.\u201d There are 78 sets of claimants in this action,\ncomprising more than 14,000 individuals. Each of them could make the argument advanced by\nClaimants, contending that he or she deserves discovery to determine his or her own standing. But\nthat is not the way a forfeiture action works. Claimants must give their own clear and complete\nanswers to the government\u2019s interrogatories, providing the facts in their possession that entitle them\nto relief. There is no practical or legal basis for them to withhold what they must know; strategic\nvagueness is not a permissible basis for refusing response. (Nor is implausible ignorance \u2013 notably,\nPrince Group\u2019s first Request for Production demands evidence that Prince Group is a Cambodian-\nregistered holding company.) Moreover, if Claimants\u2019 arguments are accepted, then all 78 putative\n\n 4\n\fCase 1:25-cv-05745-RPK-CHK Document 500 Filed 08/14/26 Page 5 of 6 PageID #:\n 13094\n\n\n\nclaimants have the opportunity likewise to demand discovery of the government, regardless of the\nmerits of their claims. That cannot be the law. The standing inquiry is a threshold requirement,\nmeant \u201cto ensure that the government is put to its proof only where someone with a legitimate\ninterest contests the forfeiture.\u201d United States v. $557,993.89, More or Less, in U.S. Funds, 287\nF.3d 66, 79 (2d Cir. 2002).\n A theme running through Claimants\u2019 briefing is that Claimants are different\u2014that\ntheir standing is effectively conceded in the government\u2019s complaint. Not so. For the reasons\naddressed at length in the government\u2019s reply brief supporting its motion to compel interrogatory\nresponses from Claimants, see ECF No. 486 at 1-3, Claimants are not exempt from the obligation to\nset forth their \u201cidentity and relationship to the defendant property.\u201d\n Amadea is not to the contrary. The government understands from counsel that\nClaimants\u2019 argument is premised on the proceedings in United States v. The M/Y Amadea, No. 23-\nCV-9304 (DEH) (S.D.N.Y. 2023) (\u201cAmadea\u201d), where the Court ultimately held an evidentiary\nhearing with respect to the standing of the single claimant in the case. Amadea provides no basis\nfor Claimants to resist providing discovery, much less to seek reciprocal discovery before the\ngovernment has even filed a motion to strike. Because Claimant has not even answered the special\ninterrogatories, any discussion of summary judgment is premature, let alone an evidentiary hearing;\nclaimants cannot gesture to the prospect of a hearing as a basis to resist the government\u2019s special\ninterrogatories and demand discovery of their own. Much less can they do so where they are only\none of 78 claimants, each of whom could raise the same arguments with equal logic.\n The Requests do not go to standing. While Claimants lack any authority to\ndemand discovery at this stage, the Requests are particularly inapposite because most of them do\nnot conceivably go to standing. By way of example, Prince Group demands information regarding\n\u201cthe circumstances whereby Plaintiff took possession of the Defendant Cryptocurrency.\u201d Prince\nGroup Interrogatory No. 12. But Prince Group\u2019s standing turns on its own relationship to the\nDefendant Cryptocurrency. Similarly, both Claimants propound interrogatories regarding \u201cwho had\npossession of the Defendant Cryptocurrency between on or about December 29, 2020, and July 31,\n2024, and where it was held during such period.\u201d Chen Zhi Interrogatory No. 7; Prince Group\nInterrogatory No. 11. But the Defendant Cryptocurrency is defined by reference to the addresses\nwhere it was held as of December 2020, see Compl. \u00b6 44 n.7, and both Claimants have stated that\nthey lost control of it after December 28, 2020. ECF No. 478 at 4. The requested details are\ntherefore irrelevant to standing (and, indeed, to any other issue in this case).\n * * *\n\n\n\n\n 5\n\fCase 1:25-cv-05745-RPK-CHK Document 500 Filed 08/14/26 Page 6 of 6 PageID #:\n 13095\n\n\n\n The parties respectfully request that the Court resolve this dispute by order or, in the\nalternative, schedule a discovery conference at the Court\u2019s earliest convenience.\n\n\n Respectfully submitted,\n\n BOIES SCHILLER FLEXNER LLP\n\n /s/ Matthew L. Schwartz\n Matthew L. Schwartz\n Peter M. Skinner\n 55 Hudson Yards\n New York, New York 10001\n\n Dan G. Boyle\n 2029 Century Park East, Suite 1520\n Los Angeles, California 90067\n\n Counsel for Claimants Chen Zhi\n and Prince Holding Group\n\n\n\n\n 6\n\f","ocr_status":2,"date_upload":"2026-08-14T10:59:11.392178-07:00","document_number":"500","attachment_number":null,"pacer_doc_id":"123024078280","is_available":true,"is_free_on_pacer":null,"is_sealed":false,"document_type":1,"description":"Compel","acms_document_guid":""},{"resource_uri":"https://www.courtlistener.com/api/rest/v4/recap-documents/490001586/","id":490001586,"tags":[],"absolute_url":"/docket/71639393/500/1/united-states-v-approximately-127271-bitcoin-btc-previously-stored-at/","date_created":"2026-08-14T10:59:13.311210-07:00","date_modified":"2026-08-22T20:49:36.164031-07:00","sha1":"3260a061ff2bad1130fc3ed87fc8b405d592e01d","page_count":11,"file_size":151886,"filepath_local":"recap/gov.uscourts.nyed.537552/gov.uscourts.nyed.537552.500.1.pdf","filepath_ia":"https://archive.org/download/gov.uscourts.nyed.537552/gov.uscourts.nyed.537552.500.1.pdf","ia_upload_failure_count":null,"thumbnail":null,"thumbnail_status":0,"plain_text":"Case 1:25-cv-05745-RPK-CHK Document 500-1 Filed 08/14/26 Page 1 of 11 PageID\n #: 13096\n\n\n\n\n EXHIBIT A\n\fCase 1:25-cv-05745-RPK-CHK Document 500-1 Filed 08/14/26 Page 2 of 11 PageID\n #: 13097\n\n\n UNITED STATES DISTRICT COURT\n EASTERN DISTRICT OF NEW YORK\n\n\n UNITED STATES OF AMERICA,\n\n Plaintiff,\n\n -against- No. 25 Civ. 05745 (RPK)\n\n CLAIMANT CHEN ZHI\u2019S FIRST SET\n APPROXIMATELY 127,271 BITCOIN\n OF INTERROGATORIES TO\n (\u201cBTC\u201d) PREVIOUSLY STORED AT THE PLAINTIFF UNITED STATES OF\n VIRTUAL CURRENCY ADDRESSES AMERICA\n LISTED IN ATTACHMENT A, AND ALL\n PROCEEDS TRACEABLE THERETO,\n Defendants in rem,\n\n\n CHEN ZHI,\n\n Claimant.\n\n\n Pursuant to Federal Rules of Civil Procedure 26 and 33, and the applicable Local Rules of\n\n the United States District Court for the Eastern District of New York, Claimant Chen Zhi\n\n (\u201cClaimant\u201d) hereby submits the following Interrogatories to Plaintiff United States of America\n\n (\u201cPlaintiff\u201d). Each Interrogatory is to be read in accordance with the Definitions and Instructions\n\n that follow. Responses are due within thirty (30) days of service.\n\fCase 1:25-cv-05745-RPK-CHK Document 500-1 Filed 08/14/26 Page 3 of 11 PageID\n #: 13098\n\n\n\n I. DEFINITIONS\n\n 1. Pursuant to E.D.N.Y. Local Rule 26.3(c)(1), \u201cCommunication\u201d means the\n\n transmittal of information (in the form of facts, ideas, inquiries, or otherwise).\n\n 2. \u201cComplaint\u201d means the initial pleading filed as ECF No. 1 on October 14, 2025, in\n\n the matter of United States of America v. Approximately 127,271 Bitcoin (\u201cBTC\u201d) Previously\n\n Stored at the Virtual Currency Addresses Listed in Attachment A, and All Proceeds Traceable\n\n Thereto, 1:25-cv-05745-RPK, United States District Court, Eastern District of New York, and any\n\n subsequent amendment(s) thereto.\n\n 3. Pursuant to E.D.N.Y. Local Rule 26.3(c)(7), \u201cconcerning\u201d means relating to,\n\n referring to, describing, evidencing, or constituting.\n\n 4. \u201cDefendant Cryptocurrency\u201d means the assets seized and named as the Defendant\n\n in this action\u2014specifically, 127,271 Bitcoin previously stored at the virtual currency addresses\n\n listed in Attachment A, and all proceeds traceable thereto\u2014as described in the Plaintiff\u2019s\n\n Complaint for Forfeiture.\n\n 5. Pursuant to E.D.N.Y. Local Rule 26.3(c)(2), \u201cDocument\u201d is defined to be\n\n synonymous in meaning and equal in scope to the usage of the term \u201cdocuments or electronically\n\n stored information\u201d in Fed. R. Civ. P. 34(a)(1)(A). A draft or non-identical copy is a separate\n\n document within the meaning of this term.\n\n 6. Pursuant to E.D.N.Y. Local Rule 26.3(c)(3), \u201cidentify,\u201d when referring to a person,\n\n means to give, to the extent known, the person\u2019s full name, present or last known address, and\n\n when referring to a natural person, additionally, the present or last known place of employment.\n\n Once a person has been identified in accordance with this subparagraph, only the name of that\n\n\n\n\n 2\n\fCase 1:25-cv-05745-RPK-CHK Document 500-1 Filed 08/14/26 Page 4 of 11 PageID\n #: 13099\n\n\n\n person need be listed in response to subsequent discovery requesting the identification of that\n\n person;\n\n 7. Pursuant to E.D.N.Y. Local Rule 26.3(c)(4), \u201cidentify, \u201d when referring documents,\n\n means to give, to the extent known, the (i) type of document, (ii) the subject matter, (iii) date of\n\n the document, and (iv) the author(s), the addressee(s) and recipient(s). In the alternative, the\n\n responding party may produce the documents, together with identifying information sufficient to\n\n satisfy Fed. R. Civ. P. 33(d).\n\n 8. The terms \u201cinclude\u201d or \u201cincluding\u201d mean \u201cinclude, but not limited to\u201d or\n\n \u201cincluding, but not limited to.\u201d\n\n 9. Pursuant to E.D.N.Y. Local Rule 26.3(c)(6), \u201cPerson(s)\u201d is defined as any natural\n\n person or any legal entity, including, without limit, any business or governmental entity or\n\n association.\n\n 10. \u201cPlaintiff\u201d means the government of the United States of America and includes any\n\n agency or instrumentality of Plaintiff, as well as all staff, agents, attorneys, representatives,\n\n employees, independent contractors, confidential sources, cooperating foreign authorities, and\n\n anyone else acting on Plaintiff\u2019s behalf or in concert with Plaintiff.\n\n 11. The terms \u201cyou,\u201d \u201cyour,\u201d or \u201cyours,\u201d means Plaintiff, and unless privileged,\n\n Plaintiff\u2019s attorneys, their staff, agents, representatives, and/or employees, and anyone else acting\n\n on your behalf.\n\n 12. The terms \u201ctraceable to\u201d and \u201cinvolved in\u201d shall have the meanings used in the\n\n Complaint and under applicable forfeiture statutes.\n\n\n\n\n 3\n\fCase 1:25-cv-05745-RPK-CHK Document 500-1 Filed 08/14/26 Page 5 of 11 PageID\n #: 13100\n\n\n\n II. GENERAL INSTRUCTIONS\n\n 1. Time Period. The time period for these requests is January 1, 2015, through the\n\n present (and ongoing) unless stated otherwise.\n\n 2. Responses: When an Interrogatory asks for specific information, and the specific\n\n information requested is not known to you, such Interrogatory shall be deemed to ask you to\n\n approximate the information requested as best you can, provided that you indicate in your response\n\n that the information being provided is an approximation or is incomplete in certain specific\n\n requests. When, after a reasonable and thorough investigation using due diligence, you are unable\n\n to answer any part of an Interrogatory because of lack of information available to you, specify in\n\n full and complete detail the type of information which you claim is not available to you and what\n\n has been done by you to locate such information. In addition, specify what knowledge or\n\n information you have concerning the unanswered portion of the Interrogatory, set forth the facts\n\n upon which such knowledge or belief is based, and identify the PERSON or entity who is likely\n\n to have the information which you claim is not available.\n\n 3. Construction: For purposes of reading, interpreting, or construing the scope of the\n\n Definitions, Instructions, and Interrogatories, all of the terms shall be given their most expansive\n\n and inclusive interpretation. This includes the following:\n\n a. The singular form of a word shall be interpreted as plural and vice versa.\n\n b. Pursuant to E.D.N.Y. Local Rule 26.3(d)(2), the connectives \u201cand\u201d and \u201cor\u201d\n\n must be construed either disjunctively or conjunctively as necessary to bring\n\n within the scope of the discovery request all responses that might otherwise\n\n be construed to be outside of its scope.\n\n\n\n\n 4\n\fCase 1:25-cv-05745-RPK-CHK Document 500-1 Filed 08/14/26 Page 6 of 11 PageID\n #: 13101\n\n\n\n c. Pursuant to E.D.N.Y. Local Rule 26.3(d)(1), the terms \u201call,\u201d \u201ceach\u201d and\n\n \u201cany\u201d must be construed as encompassing any and all.\n\n d. The masculine form of a word shall be interpreted as and shall include the\n\n feminine and vice versa.\n\n e. The use of a verb in any particular tense shall be construed as the use of the\n\n verb in all other tenses as necessary to bring within the scope of the\n\n Interrogatory that might otherwise be construed to be outside the scope of\n\n the Interrogatory.\n\n 4. Objections: Each Interrogatory shall be responded to fully, unless it is objected to\n\n in good faith. In that case, the reason(s) for the objection shall be stated in writing and with\n\n particularity. If an objection is to only a portion of the Interrogatory, state the objection as to that\n\n portion only and respond to any portion of the Interrogatory to which you do not object.\n\n a. If you claim any ambiguity in interpreting the Interrogatory or any of the\n\n applicable Instructions or Definitions, such claim shall not be used as a basis\n\n for refusing to respond to the Interrogatory. In any such circumstance, you\n\n must set forth as part of your response the language claimed to be\n\n ambiguous and the interpretation chosen or used by you in responding to\n\n the Interrogatory and you shall respond as fully as possible notwithstanding\n\n any claimed ambiguity or objection.\n\n b. If you object to the Interrogatory on the ground that it is overly broad, you\n\n are instructed to provide a response as narrowed to conform to your\n\n objection and to state in you response: (1) how you narrowed the\n\n\n\n\n 5\n\fCase 1:25-cv-05745-RPK-CHK Document 500-1 Filed 08/14/26 Page 7 of 11 PageID\n #: 13102\n\n\n\n Interrogatory; and (2) all reason(s) why you claim the Interrogatory is\n\n overly broad.\n\n 5. Privilege Log: If any information called for by these Interrogatories is withheld\n\n under a claim of privilege or is not responded to for whatever reason, you are requested at the time\n\n of responding to these Interrogatories to separately state in writing and with specificity for any\n\n such information withheld (a) the claim of privilege or other reason asserted for withholding such\n\n information; and (b) all information supporting the claim of privilege or other reason for\n\n withholding asserted as to such information, including, without limitation, the type or nature of\n\n the response for which a privilege is claimed, all in a manner sufficient to allow each response to\n\n be described to the Court in order for the Court to rule on the validity of the claim of privilege or\n\n other reason asserted for withholding your response. You are further requested to provide all\n\n requested information that is not subject to a claim of privilege or other reasons for nonresponse\n\n by excising or otherwise protecting the portion of such response for which a privilege is asserted\n\n and responding to the remainder of the Interrogatory.\n\n 6. Continuing Obligation: These Interrogatories are to be considered continuing in\n\n nature, and you must promptly furnish supplemental responses if any additional information is\n\n discovered or created after your responses are tendered, or if any of your responses are\n\n subsequently determined to be incorrect, incomplete, or misleading in any respect.\n\n\n\n\n 6\n\fCase 1:25-cv-05745-RPK-CHK Document 500-1 Filed 08/14/26 Page 8 of 11 PageID\n #: 13103\n\n\n\n III. INTERROGATORIES\n\n INTERROGATORY NO. 1:\n\n Identify the full name and any registration number of the \u201cPrince Group mining\n\n operation\u201d referred to in Paragraph 40 of the Complaint, and state those facts supporting your\n\n allegation in that paragraph that \u201cFTI was used to launder illicit funds\u201d from this\n\n \u201cPrince Group mining operation.\u201d\n\n INTERROGATORY NO. 2:\n\n State those facts supporting your allegation in Paragraph 44 of the Complaint that \u201c[b]y\n\n approximately 2020, Chen had amassed \u2026 the Defendant Cryptocurrency, which was stored\n\n across 25 cryptocurrency addresses in unhosted wallets controlled and personally tracked by\n\n Chen (the \u2018Chen Wallets\u2019).\u201d\n\n INTERROGATORY NO. 3:\n\n State those facts supporting your allegation in Paragraph 44 of the Complaint that Chen\n\n Zhi controlled the Chen Wallets.\n\n INTERROGATORY NO. 4:\n\n State those facts supporting your allegation in Paragraph 44, footnote 6, of the Complaint\n\n that Chen Zhi \u201cpersonally maintained records of the wallet addresses and seed phrases associated\n\n with the private keys for each [of the Chen Wallets].\u201d\n\n INTERROGATORY NO. 5:\n\n Identify the person(s) you contend possessed the Defendant Cryptocurrency prior to\n\n December 29, 2020.\n\n\n\n\n 7\n\fCase 1:25-cv-05745-RPK-CHK Document 500-1 Filed 08/14/26 Page 9 of 11 PageID\n #: 13104\n\n\n\n INTERROGATORY NO. 6:\n\n Identify the date upon which Plaintiff took possession of the Defendant Cryptocurrency\n\n and who first took possession of the Defendant Cryptocurrency. If more than one agency or\n\n instrumentality of Plaintiff had possession of the Defendant Cryptocurrency at different times,\n\n identify each such agency or instrumentality of Plaintiff, and when each such agency or\n\n instrumentality of Plaintiff first took possession of the Defendant Cryptocurrency.\n\n INTERROGATORY NO. 7:\n\n Identify who had possession of the Defendant Cryptocurrency between on or about\n\n December 29, 2020, and July 31, 2024, and where it was held during such period.\n\n INTERROGATORY NO. 8:\n\n Describe the circumstances whereby Plaintiff took possession of the Defendant\n\n Cryptocurrency, including the identity of any persons involved in transferring the Defendant\n\n Cryptocurrency to Plaintiff\u2019s custody or control.\n\n INTERROGATORY NO. 9:\n\n State those facts supporting your allegation in Paragraph 16(u) of the Complaint that\n\n Lubian \u201cmaintained bitcoin mining facilities [in] Iran.\u201d\n\n INTERROGATORY NO. 10\n\n State those facts supporting your allegation in Paragraph 32 of the Complaint that the\n\n \u201cBrooklyn Network\u201d was \u201cworking on Prince Group\u2019s behalf.\u201d\n\n INTERROGATORY NO. 11:\n\n State those facts supporting your allegation in Paragraph 4 of the Complaint that \u201cacts\n\n and omissions giving rise to the forfeiture accrued in the Eastern District of New York.\u201d\n\n\n\n\n 8\n\fCase 1:25-cv-05745-RPK-CHK Document 500-1 Filed 08/14/26 Page 10 of 11 PageID\n #: 13105\n\n\n\n Dated: June 19, 2026\n BOIES SCHILLER FLEXNER LLP\n\n /s/\n By:\n Matthew L. Schwartz\n Peter Skinner\n BOIES SCHILLER FLEXNER LLP\n 55 Hudson Yards, 20th Floor\n New York, NY 10001\n Telephone: (212) 446-2300\n Facsimile: (212) 446-2350\n mschwartz@bsfllp.com\n pskinner@bsfllp.com\n\n Dan G. Boyle\n BOIES SCHILLER FLEXNER LLP\n 2029 Century Park East, Suite 1520\n Los Angeles, California 90067\n Telephone: (213) 629-9040\n dboyle@bsfllp.com\n\n\n Attorneys for Claimant Chen Zhi\n\n\n\n\n 9\n\fCase 1:25-cv-05745-RPK-CHK Document 500-1 Filed 08/14/26 Page 11 of 11 PageID\n #: 13106\n\n\n\n CERTIFICATE OF SERVICE\n\n I certify that on June 19, 2026, I caused or caused to be served the foregoing on\n\n Plaintiff\u2019s counsel of record via electronic means.\n\n\n /s/\n Dan G. Boyle\n\f","ocr_status":1,"date_upload":"2026-08-14T10:59:15.694428-07:00","document_number":"500","attachment_number":1,"pacer_doc_id":"123024078281","is_available":true,"is_free_on_pacer":null,"is_sealed":false,"document_type":2,"description":"Exhibit A (Claimant Chen Zhi's First Set of Interrogatories to Plaintiff)","acms_document_guid":""},{"resource_uri":"https://www.courtlistener.com/api/rest/v4/recap-documents/490001587/","id":490001587,"tags":[],"absolute_url":"/docket/71639393/500/2/united-states-v-approximately-127271-bitcoin-btc-previously-stored-at/","date_created":"2026-08-14T10:59:13.331444-07:00","date_modified":"2026-08-22T20:49:40.874890-07:00","sha1":"f335230431bee978d6343c5e50f20ba9785366a5","page_count":12,"file_size":154404,"filepath_local":"recap/gov.uscourts.nyed.537552/gov.uscourts.nyed.537552.500.2.pdf","filepath_ia":"https://archive.org/download/gov.uscourts.nyed.537552/gov.uscourts.nyed.537552.500.2.pdf","ia_upload_failure_count":null,"thumbnail":null,"thumbnail_status":0,"plain_text":"Case 1:25-cv-05745-RPK-CHK Document 500-2 Filed 08/14/26 Page 1 of 12 PageID\n #: 13107\n\n\n\n\n EXHIBIT B\n\fCase 1:25-cv-05745-RPK-CHK Document 500-2 Filed 08/14/26 Page 2 of 12 PageID\n #: 13108\n\n\n UNITED STATES DISTRICT COURT\n EASTERN DISTRICT OF NEW YORK\n\n\n UNITED STATES OF AMERICA,\n\n Plaintiff,\n\n -against- No. 25 Civ. 05745 (RPK)\n\n CLAIMANT PRINCE HOLDING\n APPROXIMATELY 127,271 BITCOIN\n GROUP\u2019S FIRST SET OF\n (\u201cBTC\u201d) PREVIOUSLY STORED AT THE INTERROGATORIES TO PLAINTIFF\n VIRTUAL CURRENCY ADDRESSES UNITED STATES OF AMERICA\n LISTED IN ATTACHMENT A, AND ALL\n PROCEEDS TRACEABLE THERETO,\n Defendants in rem,\n\n\n PRINCE HOLDING GROUP,\n\n Claimant.\n\n\n Pursuant to Federal Rules of Civil Procedure 26 and 33, and the applicable Local Rules of\n\n the United States District Court for the Eastern District of New York, Claimant Prince Holding\n\n Group (\u201cClaimant\u201d) hereby submits the following Interrogatories to Plaintiff United States of\n\n America (\u201cPlaintiff\u201d). Each Interrogatory is to be read in accordance with the Definitions and\n\n Instructions that follow. Responses are due within thirty (30) days of service.\n\fCase 1:25-cv-05745-RPK-CHK Document 500-2 Filed 08/14/26 Page 3 of 12 PageID\n #: 13109\n\n\n\n I. DEFINITIONS\n\n 1. Pursuant to E.D.N.Y. Local Rule 26.3(c)(1), \u201cCommunication\u201d means the\n\n transmittal of information (in the form of facts, ideas, inquiries, or otherwise).\n\n 2. \u201cComplaint\u201d means the initial pleading filed as ECF No. 1 on October 14, 2025, in\n\n the matter of United States of America v. Approximately 127,271 Bitcoin (\u201cBTC\u201d) Previously\n\n Stored at the Virtual Currency Addresses Listed in Attachment A, and All Proceeds Traceable\n\n Thereto, 1:25-cv-05745-RPK, United States District Court, Eastern District of New York, and any\n\n subsequent amendment(s) thereto.\n\n 3. Pursuant to E.D.N.Y. Local Rule 26.3(c)(7), \u201cconcerning\u201d means relating to,\n\n referring to, describing, evidencing, or constituting.\n\n 4. \u201cDefendant Cryptocurrency\u201d means the assets seized and named as the Defendant\n\n in this action\u2014specifically, 127,271 Bitcoin previously stored at the virtual currency addresses\n\n listed in Attachment A, and all proceeds traceable thereto\u2014as described in the Plaintiff\u2019s\n\n Complaint for Forfeiture.\n\n 5. Pursuant to E.D.N.Y. Local Rule 26.3(c)(2), \u201cDocument\u201d is defined to be\n\n synonymous in meaning and equal in scope to the usage of the term \u201cdocuments or electronically\n\n stored information\u201d in Fed. R. Civ. P. 34(a)(1)(A). A draft or non-identical copy is a separate\n\n document within the meaning of this term.\n\n 6. Pursuant to E.D.N.Y. Local Rule 26.3(c)(3), \u201cidentify,\u201d when referring to a person,\n\n means to give, to the extent known, the person\u2019s full name, present or last known address, and\n\n when referring to a natural person, additionally, the present or last known place of employment.\n\n Once a person has been identified in accordance with this subparagraph, only the name of that\n\n\n\n\n 2\n\fCase 1:25-cv-05745-RPK-CHK Document 500-2 Filed 08/14/26 Page 4 of 12 PageID\n #: 13110\n\n\n\n person need be listed in response to subsequent discovery requesting the identification of that\n\n person;\n\n 7. Pursuant to E.D.N.Y. Local Rule 26.3(c)(4), \u201cidentify, \u201d when referring documents,\n\n means to give, to the extent known, the (i) type of document, (ii) the subject matter, (iii) date of\n\n the document, and (iv) the author(s), the addressee(s) and recipient(s). In the alternative, the\n\n responding party may produce the documents, together with identifying information sufficient to\n\n satisfy Fed. R. Civ. P. 33(d).\n\n 8. The terms \u201cinclude\u201d or \u201cincluding\u201d mean \u201cinclude, but not limited to\u201d or\n\n \u201cincluding, but not limited to.\u201d\n\n 9. Pursuant to E.D.N.Y. Local Rule 26.3(c)(6), \u201cPerson(s)\u201d is defined as any natural\n\n person or any legal entity, including, without limit, any business or governmental entity or\n\n association.\n\n 10. \u201cPlaintiff\u201d means the government of the United States of America and includes any\n\n agency or instrumentality of Plaintiff, as well as all staff, agents, attorneys, representatives,\n\n employees, independent contractors, confidential sources, cooperating foreign authorities, and\n\n anyone else acting on Plaintiff\u2019s behalf or in concert with Plaintiff.\n\n 11. The terms \u201cyou,\u201d \u201cyour,\u201d or \u201cyours,\u201d means Plaintiff, and unless privileged,\n\n Plaintiff\u2019s attorneys, their staff, agents, representatives, and/or employees, and anyone else acting\n\n on your behalf.\n\n 12. The terms \u201ctraceable to\u201d and \u201cinvolved in\u201d shall have the meanings used in the\n\n Complaint and under applicable forfeiture statutes.\n\n\n\n\n 3\n\fCase 1:25-cv-05745-RPK-CHK Document 500-2 Filed 08/14/26 Page 5 of 12 PageID\n #: 13111\n\n\n\n II. GENERAL INSTRUCTIONS\n\n 1. Time Period. The time period for these requests is January 1, 2015, through the\n\n present (and ongoing) unless stated otherwise.\n\n 2. Responses: When an Interrogatory asks for specific information, and the specific\n\n information requested is not known to you, such Interrogatory shall be deemed to ask you to\n\n approximate the information requested as best you can, provided that you indicate in your response\n\n that the information being provided is an approximation or is incomplete in certain specific\n\n requests. When, after a reasonable and thorough investigation using due diligence, you are unable\n\n to answer any part of an Interrogatory because of lack of information available to you, specify in\n\n full and complete detail the type of information which you claim is not available to you and what\n\n has been done by you to locate such information. In addition, specify what knowledge or\n\n information you have concerning the unanswered portion of the Interrogatory, set forth the facts\n\n upon which such knowledge or belief is based, and identify the PERSON or entity who is likely\n\n to have the information which you claim is not available.\n\n 3. Construction: For purposes of reading, interpreting, or construing the scope of the\n\n Definitions, Instructions, and Interrogatories, all of the terms shall be given their most expansive\n\n and inclusive interpretation. This includes the following:\n\n a. The singular form of a word shall be interpreted as plural and vice versa.\n\n b. Pursuant to E.D.N.Y. Local Rule 26.3(d)(2), the connectives \u201cand\u201d and \u201cor\u201d\n\n must be construed either disjunctively or conjunctively as necessary to bring\n\n within the scope of the discovery request all responses that might otherwise\n\n be construed to be outside of its scope.\n\n\n\n\n 4\n\fCase 1:25-cv-05745-RPK-CHK Document 500-2 Filed 08/14/26 Page 6 of 12 PageID\n #: 13112\n\n\n\n c. Pursuant to E.D.N.Y. Local Rule 26.3(d)(1), the terms \u201call,\u201d \u201ceach\u201d and\n\n \u201cany\u201d must be construed as encompassing any and all.\n\n d. The masculine form of a word shall be interpreted as and shall include the\n\n feminine and vice versa.\n\n e. The use of a verb in any particular tense shall be construed as the use of the\n\n verb in all other tenses as necessary to bring within the scope of the\n\n Interrogatory that might otherwise be construed to be outside the scope of\n\n the Interrogatory.\n\n 4. Objections: Each Interrogatory shall be responded to fully, unless it is objected to\n\n in good faith. In that case, the reason(s) for the objection shall be stated in writing and with\n\n particularity. If an objection is to only a portion of the Interrogatory, state the objection as to that\n\n portion only and respond to any portion of the Interrogatory to which you do not object.\n\n a. If you claim any ambiguity in interpreting the Interrogatory or any of the\n\n applicable Instructions or Definitions, such claim shall not be used as a basis\n\n for refusing to respond to the Interrogatory. In any such circumstance, you\n\n must set forth as part of your response the language claimed to be\n\n ambiguous and the interpretation chosen or used by you in responding to\n\n the Interrogatory and you shall respond as fully as possible notwithstanding\n\n any claimed ambiguity or objection.\n\n b. If you object to the Interrogatory on the ground that it is overly broad, you\n\n are instructed to provide a response as narrowed to conform to your\n\n objection and to state in you response: (1) how you narrowed the\n\n\n\n\n 5\n\fCase 1:25-cv-05745-RPK-CHK Document 500-2 Filed 08/14/26 Page 7 of 12 PageID\n #: 13113\n\n\n\n Interrogatory; and (2) all reason(s) why you claim the Interrogatory is\n\n overly broad.\n\n 5. Privilege Log: If any information called for by these Interrogatories is withheld\n\n under a claim of privilege or is not responded to for whatever reason, you are requested at the time\n\n of responding to these Interrogatories to separately state in writing and with specificity for any\n\n such information withheld (a) the claim of privilege or other reason asserted for withholding such\n\n information; and (b) all information supporting the claim of privilege or other reason for\n\n withholding asserted as to such information, including, without limitation, the type or nature of\n\n the response for which a privilege is claimed, all in a manner sufficient to allow each response to\n\n be described to the Court in order for the Court to rule on the validity of the claim of privilege or\n\n other reason asserted for withholding your response. You are further requested to provide all\n\n requested information that is not subject to a claim of privilege or other reasons for nonresponse\n\n by excising or otherwise protecting the portion of such response for which a privilege is asserted\n\n and responding to the remainder of the Interrogatory.\n\n 6. Continuing Obligation: These Interrogatories are to be considered continuing in\n\n nature, and you must promptly furnish supplemental responses if any additional information is\n\n discovered or created after your responses are tendered, or if any of your responses are\n\n subsequently determined to be incorrect, incomplete, or misleading in any respect.\n\n\n\n\n 6\n\fCase 1:25-cv-05745-RPK-CHK Document 500-2 Filed 08/14/26 Page 8 of 12 PageID\n #: 13114\n\n\n\n III. INTERROGATORIES\n\n INTERROGATORY NO. 1:\n\n Identify the full name and registration number of the entity referred to in Paragraph 16(o)\n\n of the Complaint as \u201cPrince Group\u201d and defined as \u201ca Cambodian-registered corporate holding\n\n company.\u201d\n\n INTERROGATORY NO. 2:\n\n Identify the full names and any registration numbers of the \u201conline gambling\n\n and cryptocurrency mining operations\u201d alleged to be part of \u201cPrince Group\u2019s own network of\n\n ostensibly legal business enterprises,\u201d as referred to in Paragraph 20 of the Complaint.\n\n INTERROGATORY NO. 3:\n\n Identify the full names and any registration numbers of the \u201conline gambling and\n\n cryptocurrency mining\u201d business referred to in Paragraph 38 of the Complaint as owned by\n\n \u201cPrince Group.\u201d\n\n INTERROGATORY NO. 4:\n\n State those facts supporting your allegation in Paragraph 38 of the Complaint that \u201cPrince\n\n Group\u2019s own businesses, including online gambling and cryptocurrency mining\u201d were used to\n\n \u201claunder[] Prince Group\u2019s illicit profits, including the Defendant Cryptocurrency\u201d\n\n INTERROGATORY NO. 5:\n\n Identify the full name and any registration number of the \u201cPrince Group mining\n\n operation\u201d referred to in Paragraph 40 of the Complaint, and state those facts supporting your\n\n allegation in that paragraph that \u201cFTI was used to launder illicit funds\u201d from this\n\n \u201cPrince Group mining operation.\u201d\n\n\n\n\n 7\n\fCase 1:25-cv-05745-RPK-CHK Document 500-2 Filed 08/14/26 Page 9 of 12 PageID\n #: 13115\n\n\n\n INTERROGATORY NO. 6:\n\n State those facts supporting your allegation in Paragraph 44 of the Complaint that \u201c[b]y\n\n approximately 2020, Chen had amassed \u2026 the Defendant Cryptocurrency, which was stored\n\n across 25 cryptocurrency addresses in unhosted wallets controlled and personally tracked by\n\n Chen (the \u2018Chen Wallets\u2019).\u201d\n\n INTERROGATORY NO. 7:\n\n State those facts supporting your allegation in Paragraph 44 of the Complaint that Chen\n\n Zhi controlled the Chen Wallets.\n\n INTERROGATORY NO. 8:\n\n State those facts supporting your allegation in Paragraph 44, footnote 6, of the Complaint\n\n that Chen Zhi \u201cpersonally maintained records of the wallet addresses and seed phrases associated\n\n with the private keys for each [of the Chen Wallets].\u201d\n\n INTERROGATORY NO. 9:\n\n Identify the person(s) you contend possessed the Defendant Cryptocurrency prior to\n\n December 29, 2020.\n\n INTERROGATORY NO. 10:\n\n Identify the date upon which Plaintiff took possession of the Defendant Cryptocurrency\n\n and who first took possession of the Defendant Cryptocurrency. If more than one agency or\n\n instrumentality of Plaintiff had possession of the Defendant Cryptocurrency at different times,\n\n identify each such agency or instrumentality of Plaintiff, and when each such agency or\n\n instrumentality of Plaintiff first took possession of the Defendant Cryptocurrency.\n\n\n\n\n 8\n\fCase 1:25-cv-05745-RPK-CHK Document 500-2 Filed 08/14/26 Page 10 of 12 PageID\n #: 13116\n\n\n\n INTERROGATORY NO. 11:\n\n Identify who had possession of the Defendant Cryptocurrency between on or about\n\n December 29, 2020, and July 31, 2024, and where it was held during such period.\n\n INTERROGATORY NO. 12:\n\n Describe the circumstances whereby Plaintiff took possession of the Defendant\n\n Cryptocurrency, including the identity of any persons involved in transferring the Defendant\n\n Cryptocurrency to Plaintiff\u2019s custody or control.\n\n INTERROGATORY NO. 13:\n\n State those facts supporting your allegation in Paragraph 16(u) of the Complaint that\n\n Lubian \u201cmaintained bitcoin mining facilities [in] Iran.\u201d\n\n INTERROGATORY NO. 14:\n\n State those facts supporting your allegation in Paragraph 32 of the Complaint that the\n\n \u201cBrooklyn Network\u201d was \u201cworking on Prince Group\u2019s behalf.\u201d\n\n INTERROGATORY NO. 15:\n\n State those facts supporting your allegation in Paragraph 4 of the Complaint that \u201cacts\n\n and omissions giving rise to the forfeiture accrued in the Eastern District of New York.\u201d\n\n //\n\n\n\n\n 9\n\fCase 1:25-cv-05745-RPK-CHK Document 500-2 Filed 08/14/26 Page 11 of 12 PageID\n #: 13117\n\n\n\n\n Dated: June 19, 2026\n BOIES SCHILLER FLEXNER LLP\n\n /s/\n By:\n Matthew L. Schwartz\n Peter Skinner\n BOIES SCHILLER FLEXNER LLP\n 55 Hudson Yards, 20th Floor\n New York, NY 10001\n Telephone: (212) 446-2300\n Facsimile: (212) 446-2350\n mschwartz@bsfllp.com\n pskinner@bsfllp.com\n\n Dan G. Boyle\n BOIES SCHILLER FLEXNER LLP\n 2029 Century Park East, Suite 1520\n Los Angeles, California 90067\n Telephone: (213) 629-9040\n dboyle@bsfllp.com\n\n\n Attorneys for Claimant Prince Holding Group\n\n\n\n\n 10\n\fCase 1:25-cv-05745-RPK-CHK Document 500-2 Filed 08/14/26 Page 12 of 12 PageID\n #: 13118\n\n\n\n CERTIFICATE OF SERVICE\n\n I certify that on June 19, 2026, I caused or caused to be served the foregoing on\n\n Plaintiff\u2019s counsel of record via electronic means.\n\n\n /s/\n Dan G. Boyle\n\f","ocr_status":1,"date_upload":"2026-08-14T10:59:18.122283-07:00","document_number":"500","attachment_number":2,"pacer_doc_id":"123024078282","is_available":true,"is_free_on_pacer":null,"is_sealed":false,"document_type":2,"description":"Exhibit B (Claimant Prince Group's First Set of Interrogatories to Plaintif","acms_document_guid":""},{"resource_uri":"https://www.courtlistener.com/api/rest/v4/recap-documents/490001588/","id":490001588,"tags":[],"absolute_url":"/docket/71639393/500/3/united-states-v-approximately-127271-bitcoin-btc-previously-stored-at/","date_created":"2026-08-14T10:59:13.351184-07:00","date_modified":"2026-08-22T20:49:37.965336-07:00","sha1":"887428eb27203e7252f3a267786b98a9fe45aaf9","page_count":11,"file_size":130331,"filepath_local":"recap/gov.uscourts.nyed.537552/gov.uscourts.nyed.537552.500.3.pdf","filepath_ia":"https://archive.org/download/gov.uscourts.nyed.537552/gov.uscourts.nyed.537552.500.3.pdf","ia_upload_failure_count":null,"thumbnail":null,"thumbnail_status":0,"plain_text":"Case 1:25-cv-05745-RPK-CHK Document 500-3 Filed 08/14/26 Page 1 of 11 PageID\n #: 13119\n\n\n\n\n EXHIBIT C\n\fCase 1:25-cv-05745-RPK-CHK Document 500-3 Filed 08/14/26 Page 2 of 11 PageID\n #: 13120\n\n\n UNITED STATES DISTRICT COURT\n EASTERN DISTRICT OF NEW YORK\n\n\n UNITED STATES OF AMERICA,\n\n Plaintiff,\n\n -against- No. 25 Civ. 05745 (RPK)\n\n CLAIMANT CHEN ZHI\u2019S FIRST\n APPROXIMATELY 127,271 BITCOIN\n REQUESTS FOR PRODUCTION OF\n (\u201cBTC\u201d) PREVIOUSLY STORED AT THE DOCUMENTS TO PLAINTIFF UNITED\n VIRTUAL CURRENCY ADDRESSES STATES OF AMERICA\n LISTED IN ATTACHMENT A, AND ALL\n PROCEEDS TRACEABLE THERETO,\n\n Defendants in rem,\n\n\n CHEN ZHI,\n\n Claimant.\n\n\n\n Pursuant to Rules 26 and 34 of the Federal Rules of Civil Procedure, and the applicable\n\n Local Rules of the United States District Court for the Eastern District of New York, Claimant\n\n Chen Zhi (\u201cClaimant\u201d) propounds the following First Set of Requests for Production of Documents\n\n to Plaintiff United States of America (\u201cPlaintiff\u201d).\n\n Claimant hereby requests that Plaintiff respond to each request and produce the following\n\n documents and things, in Plaintiff\u2019s possession, custody, or control, within thirty (30) days of\n\n service hereof, as required by Rule 34.\n\fCase 1:25-cv-05745-RPK-CHK Document 500-3 Filed 08/14/26 Page 3 of 11 PageID\n #: 13121\n\n\n\n I. DEFINITIONS AND INSTRUCTIONS\n\n 1. Pursuant to E.D.N.Y. Local Rule 26.3(c)(1), \u201cCommunication\u201d means the\n\n transmittal of information (in the form of facts, ideas, inquiries, or otherwise).\n\n 2. \u201cComplaint\u201d means the initial pleading filed as ECF No. 1 on October 14, 2025, in\n\n the matter of United States of America v. Approximately 127,271 Bitcoin (\u201cBTC\u201d) Previously\n\n Stored at the Virtual Currency Addresses Listed in Attachment A, and All Proceeds Traceable\n\n Thereto, 1:25-cv-05745-RPK, United States District Court, Eastern District of New York, and any\n\n subsequent amendment(s) thereto.\n\n 3. Pursuant to E.D.N.Y. Local Rule 26.3(c)(7), \u201cconcerning\u201d means relating to,\n\n referring to, describing, evidencing, or constituting.\n\n 4. The term \u201cDefendant Cryptocurrency\u201d means the assets seized and named as the\n\n Defendant in this action\u2014specifically, 127,271 Bitcoin previously stored at the virtual currency\n\n addresses listed in Attachment A, and all proceeds traceable thereto\u2014as described in the Plaintiff\u2019s\n\n Complaint for Forfeiture.\n\n 5. Pursuant to E.D.N.Y. Local Rule 26.3(c)(2), \u201cDocument\u201d is defined to be\n\n synonymous in meaning and equal in scope to the usage of the term \u201cdocuments or electronically\n\n stored information\u201d in Fed. R. Civ. P. 34(a)(1)(A). A draft or non-identical copy is a separate\n\n document within the meaning of this term.\n\n 6. \u201cIncluding\u201d means including, but not limited to.\n\n 7. \u201cInformation\u201d means information of any kind in any form whatsoever.\n\n 8. \u201cLubian\u201d mean claimant Lubian in this action.\n\n 9. \u201cPlaintiff\u201d means the government of the United States of America and includes any\n\n agency or instrumentality of Plaintiff, as well as all staff, agents, attorneys, representatives,\n\n\n\n 2\n\fCase 1:25-cv-05745-RPK-CHK Document 500-3 Filed 08/14/26 Page 4 of 11 PageID\n #: 13122\n\n\n\n employees, independent contractors, confidential sources, cooperating foreign authorities, and\n\n anyone else acting on Plaintiff\u2019s behalf or in concert with Plaintiff.\n\n 10. The terms \u201cyou,\u201d \u201cyour,\u201d or \u201cyours,\u201d means Plaintiff, and Plaintiff\u2019s staff, agents,\n\n attorneys, representatives, employees, and independent contractors, and anyone else acting on\n\n Plaintiff\u2019s behalf.\n\n 11. Plaintiff shall respond to these Requests and produce the following documents for\n\n inspection and copying within thirty (30) days of the service of the requests.\n\n 12. Plaintiff is further requested to produce and permit the inspection and copying of\n\n documents and/or other items described at: Boies Schiller Flexner LLP, 55 Hudson Yards, Floor\n\n 20, New York, New York 10001. This demand may be complied with by delivery of legible copies\n\n of the subject documents and other items described, verified as true and correct, to the undersigned\n\n at: Boies Schiller Flexner LLP, 55 Hudson Yards, Floor 20, New York, New York 10001.\n\n 13. Plaintiff shall produce all originals, drafts, reproductions, and photographs of\n\n documents requested.\n\n 14. The documents to be produced in response to these requests include all documents\n\n within your possession, custody, or control. This includes documents in the possession, custody,\n\n or control of Plaintiff\u2019s attorneys, agents, employees, investigators, consultants, and experts, as\n\n well as a firm, company, corporation, or business in which Plaintiff owns a controlling interest or\n\n over which you exercise control in fact.\n\n 15. Plaintiff is required to use reasonable diligence to locate the documents, including\n\n those that are not in its immediate possession.\n\n 16. For the convenience of the parties and to reduce production costs, please produce\n\n documents which may exist in hard copy form in an electronic format (e.g., PDF or the equivalent).\n\n\n\n 3\n\fCase 1:25-cv-05745-RPK-CHK Document 500-3 Filed 08/14/26 Page 5 of 11 PageID\n #: 13123\n\n\n\n 17. Pursuant to FRCP 34(b), please produce all electronically stored information in its\n\n native electronic format, with all metadata preserved and all accompanying load files.\n\n 18. If you claim that a privilege applies, or a reason for withholding a document is\n\n applicable, please set forth in writing and with your response to this Request: (1) the date of the\n\n document; (2) the type of document; (3) the subject matter of the document; (4) the name,\n\n employment, and title of each person who prepared or received the document or any copy thereof;\n\n and (5) the basis for the claim of privilege or other ground for withholding the document. If it is\n\n claimed that only part of the document is privileged or otherwise need not be produced, please\n\n produce the remaining part of the document.\n\n 19. For any record or document responsive or relating to these requests which is known\n\n to have been destroyed or lost, or is otherwise unavailable, identify each such document as\n\n completely as possible, including the author, address, date, type of document, number of pages,\n\n and subject matter, and explain in detail the events leading to the destruction or the loss, or the\n\n reason for the unavailability of such document, including the date it was lost, and identity of all\n\n persons having knowledge of the contents of the document.\n\n 20. Do not make any redactions on produced documents unless they involve a valid\n\n privilege and you produce an appropriate privilege log.\n\n 21. Please organize and label the documents to correspond to the categories in the\n\n demand. This can usually be accomplished by producing a list at the time of production which\n\n identifies by Bates-stamp number which documents are responsive to which requests.\n\n 22. These requests are continuing in nature. If, after producing the requested\n\n documents, Plaintiff obtains or becomes aware of further documents responsive to these requests,\n\n Plaintiff is required to produce to Claimant such additional documents.\n\n\n\n 4\n\fCase 1:25-cv-05745-RPK-CHK Document 500-3 Filed 08/14/26 Page 6 of 11 PageID\n #: 13124\n\n\n\n 23. Unless otherwise specified, these requests are limited to the time period from\n\n January 1, 2015, to and including the date of service of these requests.\n\n\n\n\n 5\n\fCase 1:25-cv-05745-RPK-CHK Document 500-3 Filed 08/14/26 Page 7 of 11 PageID\n #: 13125\n\n\n\n II. FIRST SET OF REQUESTS FOR PRODUCTION\n\n CLAIMANT\u2019S REQUEST NO. 1:\n\n All Documents and Communications concerning your allegation in Paragraph 16(o) of the\n\n Complaint that \u201cPrince Group\u201d was \u201ca Cambodian-registered corporate holding company.\u201d\n\n CLAIMANT\u2019S REQUEST NO. 2:\n All Documents and Communications concerning your allegation in Paragraph 38 of the\n\n Complaint that \u201cPrince Group\u2019s own businesses, including online gambling and cryptocurrency\n\n mining,\u201d were used to \u201claunder[] Prince Group\u2019s illicit profits, including the Defendant\n\n Cryptocurrency.\u201d\n\n CLAIMANT\u2019S REQUEST NO. 3:\n All Documents and Communications concerning your allegation in Paragraph 44 of the\n\n Complaint that Chen Zhi controlled the Chen Wallets.\n\n CLAIMANT\u2019S REQUEST NO. 4:\n All Documents and Communications concerning your allegation in Paragraph 44, footnote\n\n 6, of the Complaint that Chen Zhi \u201cpersonally maintained records of the wallet addresses and seed\n\n phrases associated with the private keys for each [of the Chen Wallets].\u201d\n\n CLAIMANT\u2019S REQUEST NO. 5:\n All Documents and Communications concerning your allegation in Paragraph 58 of the\n\n Complaint that the Defendant Cryptocurrency was \u201ctransferred in its entirety to multiple additional\n\n addresses\u201d and is \u201ccurrently in the custody of the United States.\u201d\n\n CLAIMANT\u2019S REQUEST NO. 6:\n\n All Documents and Communications concerning all transfers of the Defendant\n\n Cryptocurrency from December 1, 2020 through January 31, 2021.\n\n\n\n\n 6\n\fCase 1:25-cv-05745-RPK-CHK Document 500-3 Filed 08/14/26 Page 8 of 11 PageID\n #: 13126\n\n\n\n CLAIMANT\u2019S REQUEST NO. 7:\n\n All Documents and Communications concerning all transfers of the Defendant\n\n Cryptocurrency into Plaintiff\u2019s possession in or around June and July of 2024.\n\n CLAIMANT\u2019S REQUEST NO. 8:\n\n All search and/or seizure warrants concerning the Defendant Cryptocurrency, including all\n\n supporting affidavits made in connection therewith and all inventories of property searched and\n\n seized.\n\n CLAIMANT\u2019S REQUEST NO. 9:\n All Documents and Communications concerning the July 2019 border stop of members of\n\n the Lubian project development team, and in particular Zhou Lanshun, including but not limited\n\n to any subsequent or related investigation of the same.\n\n CLAIMANT\u2019S REQUEST NO. 10:\n All Documents and Communications concerning your allegation in Paragraph 16(u) of the\n\n Complaint that Lubian \u201cmaintained bitcoin mining facilities [in] Iran.\u201d\n\n CLAIMANT\u2019S REQUEST NO. 11:\n All Documents and Communications concerning your allegation in Paragraph 32 of the\n\n Complaint that the \u201cBrooklyn Network\u201d was \u201cworking on Prince Group\u2019s behalf.\u201d\n\n CLAIMANT\u2019S REQUEST NO. 12:\n All Documents and Communications concerning your allegation in Paragraph 35 of the\n\n Complaint that \u201cthe Brooklyn Network sent the funds through a series of accounts back to Prince\n\n Group scammers at the Jinbei Compound and elsewhere, where they were further laundered before\n\n returning to Prince Group and its top executives.\u201d\n\n\n\n\n 7\n\fCase 1:25-cv-05745-RPK-CHK Document 500-3 Filed 08/14/26 Page 9 of 11 PageID\n #: 13127\n\n\n\n CLAIMANT\u2019S REQUEST NO. 13:\n All Documents and Communications concerning your allegation in Paragraph 44 of the\n\n Complaint that Chen Zhi had \u201camassed\u201d the Defendant Cryptocurrency by \u201capproximately\n\n December 2020.\u201d\n\n CLAIMANT\u2019S REQUEST NO. 14:\n All Documents and Communications concerning the forfeiture.gov publication\n\n reproduced at page 4 of Claimant\u2019s motion for a more definite statement [ECF No. 317].\n\n CLAIMANT\u2019S REQUEST NO. 15:\n All Documents and Communications concerning your allegation in Paragraph 4 of the\n\n Complaint that \u201cacts and omissions giving rise to the forfeiture accrued in the Eastern District of\n\n New York.\u201d\n\n CLAIMANT\u2019S REQUEST NO. 15:\n All Documents and Communications concerning the transactions described in Paragraph\n\n 37 and footnote 2 of the Complaint.\n\n //\n\n\n\n\n 8\n\fCase 1:25-cv-05745-RPK-CHK Document 500-3 Filed 08/14/26 Page 10 of 11 PageID\n #: 13128\n\n\n\n Dated: June 19, 2026\n\n BOIES SCHILLER FLEXNER LLP\n\n By: /s/\n Matthew L. Schwartz\n Peter M. Skinner\n BOIES SCHILLER FLEXNER LLP\n 55 Hudson Yards, 20th Floor\n New York, NY 10001\n Telephone: (212) 446-2300\n Facsimile: (212) 446-2350\n mschwartz@bsfllp.com\n pskinner@bsfllp.com\n\n Dan G. Boyle\n BOIES SCHILLER FLEXNER LLP\n 2029 Century Park East, Suite 1520\n Los Angeles, California 90067\n Telephone: (213) 629-9040\n dboyle@bsfllp.com\n\n Attorneys for Claimant Chen Zhi\n\n\n\n\n 9\n\fCase 1:25-cv-05745-RPK-CHK Document 500-3 Filed 08/14/26 Page 11 of 11 PageID\n #: 13129\n\n\n\n CERTIFICATE OF SERVICE\n\n I certify that on June 19, 2026, I caused or caused to be served the foregoing on\n\n Plaintiff\u2019s counsel of record via electronic means and U.S. mail.\n\n\n /s/\n Dan G. Boyle\n\f","ocr_status":1,"date_upload":"2026-08-14T10:59:20.327998-07:00","document_number":"500","attachment_number":3,"pacer_doc_id":"123024078283","is_available":true,"is_free_on_pacer":null,"is_sealed":false,"document_type":2,"description":"Exhibit C (Claimant Chen Zhi's First Requests for Production to Plaintiff)","acms_document_guid":""},{"resource_uri":"https://www.courtlistener.com/api/rest/v4/recap-documents/490001589/","id":490001589,"tags":[],"absolute_url":"/docket/71639393/500/4/united-states-v-approximately-127271-bitcoin-btc-previously-stored-at/","date_created":"2026-08-14T10:59:13.372788-07:00","date_modified":"2026-08-22T20:49:44.166761-07:00","sha1":"97c43d064ac47f314611db9f83a19b9011757d9f","page_count":11,"file_size":131287,"filepath_local":"recap/gov.uscourts.nyed.537552/gov.uscourts.nyed.537552.500.4.pdf","filepath_ia":"https://archive.org/download/gov.uscourts.nyed.537552/gov.uscourts.nyed.537552.500.4.pdf","ia_upload_failure_count":null,"thumbnail":null,"thumbnail_status":0,"plain_text":"Case 1:25-cv-05745-RPK-CHK Document 500-4 Filed 08/14/26 Page 1 of 11 PageID\n #: 13130\n\n\n\n\n EXHIBIT D\n\fCase 1:25-cv-05745-RPK-CHK Document 500-4 Filed 08/14/26 Page 2 of 11 PageID\n #: 13131\n\n\n UNITED STATES DISTRICT COURT\n EASTERN DISTRICT OF NEW YORK\n\n\n UNITED STATES OF AMERICA,\n\n Plaintiff,\n No. 25 Civ. 05745 (RPK)\n -against-\n CLAIMANT PRINCE HOLDING\n APPROXIMATELY 127,271 BITCOIN GROUP\u2019S FIRST REQUESTS FOR\n (\u201cBTC\u201d) PREVIOUSLY STORED AT THE PRODUCTION OF DOCUMENTS TO\n VIRTUAL CURRENCY ADDRESSES PLAINTIFF UNITED STATES OF\n LISTED IN ATTACHMENT A, AND ALL AMERICA\n PROCEEDS TRACEABLE THERETO,\n\n Defendants in rem,\n\n\n PRINCE HOLDING GROUP,\n\n Claimant.\n\n\n\n Pursuant to Rules 26 and 34 of the Federal Rules of Civil Procedure, and the applicable\n\n Local Rules of the United States District Court for the Eastern District of New York, Claimant\n\n Prince Holding Group (\u201cClaimant\u201d) propounds the following First Set of Requests for Production\n\n of Documents to Plaintiff United States of America (\u201cPlaintiff\u201d).\n\n Claimant hereby requests that Plaintiff respond to each request and produce the following\n\n documents and things, in Plaintiff\u2019s possession, custody, or control, within thirty (30) days of\n\n service hereof, as required by Rule 34.\n\fCase 1:25-cv-05745-RPK-CHK Document 500-4 Filed 08/14/26 Page 3 of 11 PageID\n #: 13132\n\n\n\n I. DEFINITIONS AND INSTRUCTIONS\n\n 1. Pursuant to E.D.N.Y. Local Rule 26.3(c)(1), \u201cCommunication\u201d means the\n\n transmittal of information (in the form of facts, ideas, inquiries, or otherwise).\n\n 2. \u201cComplaint\u201d means the initial pleading filed as ECF No. 1 on October 14, 2025, in\n\n the matter of United States of America v. Approximately 127,271 Bitcoin (\u201cBTC\u201d) Previously\n\n Stored at the Virtual Currency Addresses Listed in Attachment A, and All Proceeds Traceable\n\n Thereto, 1:25-cv-05745-RPK, United States District Court, Eastern District of New York, and any\n\n subsequent amendment(s) thereto.\n\n 3. Pursuant to E.D.N.Y. Local Rule 26.3(c)(7), \u201cconcerning\u201d means relating to,\n\n referring to, describing, evidencing, or constituting.\n\n 4. The term \u201cDefendant Cryptocurrency\u201d means the assets seized and named as the\n\n Defendant in this action\u2014specifically, 127,271 Bitcoin previously stored at the virtual currency\n\n addresses listed in Attachment A, and all proceeds traceable thereto\u2014as described in the Plaintiff\u2019s\n\n Complaint for Forfeiture.\n\n 5. Pursuant to E.D.N.Y. Local Rule 26.3(c)(2), \u201cDocument\u201d is defined to be\n\n synonymous in meaning and equal in scope to the usage of the term \u201cdocuments or electronically\n\n stored information\u201d in Fed. R. Civ. P. 34(a)(1)(A). A draft or non-identical copy is a separate\n\n document within the meaning of this term.\n\n 6. \u201cIncluding\u201d means including, but not limited to.\n\n 7. \u201cInformation\u201d means information of any kind in any form whatsoever.\n\n 8. \u201cLubian\u201d mean claimant Lubian in this action.\n\n 9. \u201cPlaintiff\u201d means the government of the United States of America and includes any\n\n agency or instrumentality of Plaintiff, as well as all staff, agents, attorneys, representatives,\n\n\n\n 2\n\fCase 1:25-cv-05745-RPK-CHK Document 500-4 Filed 08/14/26 Page 4 of 11 PageID\n #: 13133\n\n\n\n employees, independent contractors, confidential sources, cooperating foreign authorities, and\n\n anyone else acting on Plaintiff\u2019s behalf or in concert with Plaintiff\n\n 10. The terms \u201cyou,\u201d \u201cyour,\u201d or \u201cyours,\u201d means Plaintiff, and Plaintiff\u2019s staff, agents,\n\n attorneys, representatives, employees, and independent contractors, and anyone else acting on\n\n Plaintiff\u2019s behalf.\n\n 11. Plaintiff shall respond to these Requests and produce the following documents for\n\n inspection and copying within thirty (30) days of the service of the requests.\n\n 12. Plaintiff is further requested to produce and permit the inspection and copying of\n\n documents and/or other items described at: Boies Schiller Flexner LLP, 55 Hudson Yards, Floor\n\n 20, New York, New York 10001. This demand may be complied with by delivery of legible copies\n\n of the subject documents and other items described, verified as true and correct, to the undersigned\n\n at: Boies Schiller Flexner LLP, 55 Hudson Yards, Floor 20, New York, New York 10001.\n\n 13. Plaintiff shall produce all originals, drafts, reproductions, and photographs of\n\n documents requested.\n\n 14. The documents to be produced in response to these requests include all documents\n\n within your possession, custody, or control. This includes documents in the possession, custody,\n\n or control of Plaintiff\u2019s attorneys, agents, employees, investigators, consultants, and experts, as\n\n well as a firm, company, corporation, or business in which Plaintiff owns a controlling interest or\n\n over which you exercise control in fact.\n\n 15. Plaintiff is required to use reasonable diligence to locate the documents, including\n\n those that are not in its immediate possession.\n\n 16. For the convenience of the parties and to reduce production costs, please produce\n\n documents which may exist in hard copy form in an electronic format (e.g., PDF or the equivalent).\n\n\n\n 3\n\fCase 1:25-cv-05745-RPK-CHK Document 500-4 Filed 08/14/26 Page 5 of 11 PageID\n #: 13134\n\n\n\n 17. Pursuant to FRCP 34(b), please produce all electronically stored information in its\n\n native electronic format, with all metadata preserved and all accompanying load files.\n\n 18. If you claim that a privilege applies, or a reason for withholding a document is\n\n applicable, please set forth in writing and with your response to this Request: (1) the date of the\n\n document; (2) the type of document; (3) the subject matter of the document; (4) the name,\n\n employment, and title of each person who prepared or received the document or any copy thereof;\n\n and (5) the basis for the claim of privilege or other ground for withholding the document. If it is\n\n claimed that only part of the document is privileged or otherwise need not be produced, please\n\n produce the remaining part of the document.\n\n 19. For any record or document responsive or relating to these requests which is known\n\n to have been destroyed or lost, or is otherwise unavailable, identify each such document as\n\n completely as possible, including the author, address, date, type of document, number of pages,\n\n and subject matter, and explain in detail the events leading to the destruction or the loss, or the\n\n reason for the unavailability of such document, including the date it was lost, and identity of all\n\n persons having knowledge of the contents of the document.\n\n 20. Do not make any redactions on produced documents unless they involve a valid\n\n privilege and you produce an appropriate privilege log.\n\n 21. Please organize and label the documents to correspond to the categories in the\n\n demand. This can usually be accomplished by producing a list at the time of production which\n\n identifies by Bates-stamp number which documents are responsive to which requests.\n\n 22. These requests are continuing in nature. If, after producing the requested\n\n documents, Plaintiff obtains or becomes aware of further documents responsive to these requests,\n\n Plaintiff is required to produce to Claimant such additional documents.\n\n\n\n 4\n\fCase 1:25-cv-05745-RPK-CHK Document 500-4 Filed 08/14/26 Page 6 of 11 PageID\n #: 13135\n\n\n\n 23. Unless otherwise specified, these requests are limited to the time period from\n\n January 1, 2015, to and including the date of service of these requests.\n\n\n\n\n 5\n\fCase 1:25-cv-05745-RPK-CHK Document 500-4 Filed 08/14/26 Page 7 of 11 PageID\n #: 13136\n\n\n\n II. FIRST SET OF REQUESTS FOR PRODUCTION\n\n CLAIMANT\u2019S REQUEST NO. 1:\n\n All Documents and Communications concerning your allegation in Paragraph 16(o) of the\n\n Complaint that \u201cPrince Group\u201d was \u201ca Cambodian-registered corporate holding company.\u201d\n\n CLAIMANT\u2019S REQUEST NO. 2:\n All Documents and Communications concerning your allegation in Paragraph 38 of the\n\n Complaint that \u201cPrince Group\u2019s own businesses, including online gambling and cryptocurrency\n\n mining,\u201d were used to \u201claunder[] Prince Group\u2019s illicit profits, including the Defendant\n\n Cryptocurrency.\u201d\n\n CLAIMANT\u2019S REQUEST NO. 3:\n All Documents and Communications concerning your allegation in Paragraph 44 of the\n\n Complaint that Chen Zhi controlled the Chen Wallets.\n\n CLAIMANT\u2019S REQUEST NO. 4:\n All Documents and Communications concerning your allegation in Paragraph 44, footnote\n\n 6, of the Complaint that Chen Zhi \u201cpersonally maintained records of the wallet addresses and seed\n\n phrases associated with the private keys for each [of the Chen Wallets].\u201d\n\n CLAIMANT\u2019S REQUEST NO. 5:\n All Documents and Communications concerning your allegation in Paragraph 58 of the\n\n Complaint that the Defendant Cryptocurrency was \u201ctransferred in its entirety to multiple additional\n\n addresses\u201d and is \u201ccurrently in the custody of the United States.\u201d\n\n CLAIMANT\u2019S REQUEST NO. 6:\n\n All Documents and Communications concerning all transfers of the Defendant\n\n Cryptocurrency from December 1, 2020 through January 31, 2021.\n\n\n\n\n 6\n\fCase 1:25-cv-05745-RPK-CHK Document 500-4 Filed 08/14/26 Page 8 of 11 PageID\n #: 13137\n\n\n\n CLAIMANT\u2019S REQUEST NO. 7:\n\n All Documents and Communications concerning all transfers of the Defendant\n\n Cryptocurrency into Plaintiff\u2019s possession in or around June and July of 2024.\n\n CLAIMANT\u2019S REQUEST NO. 8:\n\n All search and/or seizure warrants concerning the Defendant Cryptocurrency, including all\n\n supporting affidavits made in connection therewith and all inventories of property searched and\n\n seized.\n\n CLAIMANT\u2019S REQUEST NO. 9:\n All Documents and Communications concerning the July 2019 border stop of members of\n\n the Lubian project development team, and in particular Zhou Lanshun, including but not limited\n\n to any subsequent or related investigation of the same.\n\n CLAIMANT\u2019S REQUEST NO. 10:\n All Documents and Communications concerning your allegation in Paragraph 16(u) of the\n\n Complaint that Lubian \u201cmaintained bitcoin mining facilities [in] Iran.\u201d\n\n CLAIMANT\u2019S REQUEST NO. 11:\n All Documents and Communications concerning your allegation in Paragraph 32 of the\n\n Complaint that the \u201cBrooklyn Network\u201d was \u201cworking on Prince Group\u2019s behalf.\u201d\n\n CLAIMANT\u2019S REQUEST NO. 12:\n All Documents and Communications concerning your allegation in Paragraph 35 of the\n\n Complaint that \u201cthe Brooklyn Network sent the funds through a series of accounts back to Prince\n\n Group scammers at the Jinbei Compound and elsewhere, where they were further laundered before\n\n returning to Prince Group and its top executives.\u201d\n\n\n\n\n 7\n\fCase 1:25-cv-05745-RPK-CHK Document 500-4 Filed 08/14/26 Page 9 of 11 PageID\n #: 13138\n\n\n\n CLAIMANT\u2019S REQUEST NO. 13:\n All Documents and Communications concerning your allegation in Paragraph 44 of the\n\n Complaint that Chen Zhi had \u201camassed\u201d the Defendant Cryptocurrency by \u201capproximately\n\n December 2020.\u201d\n\n CLAIMANT\u2019S REQUEST NO. 14:\n All Documents and Communications concerning the forfeiture.gov publication\n\n reproduced at page 4 of claimant Chen Zhi\u2019s motion for a more definite statement [ECF No.\n\n 317].\n\n CLAIMANT\u2019S REQUEST NO. 15:\n All Documents and Communications concerning your allegation in Paragraph 4 of the\n\n Complaint that \u201cacts and omissions giving rise to the forfeiture accrued in the Eastern District of\n\n New York.\u201d\n\n CLAIMANT\u2019S REQUEST NO. 15:\n All Documents and Communications concerning the transactions described in Paragraph\n\n 37 and footnote 2 of the Complaint.\n\n //\n\n\n\n\n 8\n\fCase 1:25-cv-05745-RPK-CHK Document 500-4 Filed 08/14/26 Page 10 of 11 PageID\n #: 13139\n\n\n\n Dated: June 19, 2026\n\n BOIES SCHILLER FLEXNER LLP\n\n By: /s/\n Matthew L. Schwartz\n Peter M. Skinner\n BOIES SCHILLER FLEXNER LLP\n 55 Hudson Yards, 20th Floor\n New York, NY 10001\n Telephone: (212) 446-2300\n Facsimile: (212) 446-2350\n mschwartz@bsfllp.com\n pskinner@bsfllp.com\n\n Dan G. Boyle\n BOIES SCHILLER FLEXNER LLP\n 2029 Century Park East, Suite 1520\n Los Angeles, California 90067\n Telephone: (213) 629-9040\n dboyle@bsfllp.com\n\n Attorneys for Prince Holding Group\n\n\n\n\n 9\n\fCase 1:25-cv-05745-RPK-CHK Document 500-4 Filed 08/14/26 Page 11 of 11 PageID\n #: 13140\n\n\n\n CERTIFICATE OF SERVICE\n\n I certify that on June 19, 2026, I caused or caused to be served the foregoing on\n\n Plaintiff\u2019s counsel of record via electronic means and U.S. mail.\n\n\n /s/\n Dan G. Boyle\n\f","ocr_status":1,"date_upload":"2026-08-14T10:59:22.484284-07:00","document_number":"500","attachment_number":4,"pacer_doc_id":"123024078284","is_available":true,"is_free_on_pacer":null,"is_sealed":false,"document_type":2,"description":"Exhibit D (Claimant Prince Group's First Requests for Production to Plainti","acms_document_guid":""},{"resource_uri":"https://www.courtlistener.com/api/rest/v4/recap-documents/490001590/","id":490001590,"tags":[],"absolute_url":"/docket/71639393/500/5/united-states-v-approximately-127271-bitcoin-btc-previously-stored-at/","date_created":"2026-08-14T10:59:13.420710-07:00","date_modified":"2026-08-22T20:49:39.607676-07:00","sha1":"1419e2bc18bfc27f695e79531bbe08314c752927","page_count":3,"file_size":150660,"filepath_local":"recap/gov.uscourts.nyed.537552/gov.uscourts.nyed.537552.500.5.pdf","filepath_ia":"https://archive.org/download/gov.uscourts.nyed.537552/gov.uscourts.nyed.537552.500.5.pdf","ia_upload_failure_count":null,"thumbnail":null,"thumbnail_status":0,"plain_text":"Case 1:25-cv-05745-RPK-CHK Document 500-5 Filed 08/14/26 Page 1 of 3 PageID\n #: 13141\n\n\n\n\n EXHIBIT E\n\fCase 1:25-cv-05745-RPK-CHK Document 500-5 Filed 08/14/26 Page 2 of 3 PageID\n #: 13142\n\n From: Mindlin, Alexander (USANYE)\n To: Dan Boyle\n Cc: Peter Skinner; Matthew L. Schwartz; Rafalson, Alessandra (USANYE); Brown, Christopher (NSD); Weintraub,\n Benjamin (USANYE); Payne, Tanisha (USANYE); Reich, Andrew (USANYE)\n Subject: RE: 25 Civ. 05745 (RPK) - Discovery Requests\n Date: Thursday, July 16, 2026 4:37:10 PM\n\n\n\n Dan:\n These requests are improper at this stage. Your clients have not established statutory or\n constitutional standing\u2014nor have you adequately responded to the government\u2019s first\n set of special interrogatories aimed at testing their standing. The United States is not\n required to submit to discovery by an unverified claimant who has failed to comply with\n the mandatory provisions of Supplemental Rule G.\n\n Regards,\n\n Alexander Mindlin\n Assistant United States Attorney\n Co-Chief, National Security and Cybercrime Section - United States Attorney's Office,\n E.D.N.Y.\n Desk: (718) 254-6433\n Mobile: (347) 677-2387\n\n\n\n From: Dan Boyle \n Sent: Friday, June 19, 2026 4:51 PM\n To: Mindlin, Alexander (USANYE) ; Reich, Andrew (USANYE)\n ; Payne, Tanisha (USANYE) ; Weintraub,\n Benjamin (USANYE) ; Brown, Christopher (NSD)\n ; Rafalson, Alessandra (USANYE)\n \n Cc: Peter Skinner ; Matthew L. Schwartz \n Subject: [EXTERNAL] 25 Civ. 05745 (RPK) - Discovery Requests\n\n\n Counsel:\n\n On behalf of claimants Chen Zhi and Prince Holding Group, please see the attached\n discovery requests.\n\n Regards,\n Dan Boyle\n Partner\n\fCase 1:25-cv-05745-RPK-CHK Document 500-5 Filed 08/14/26 Page 3 of 3 PageID\n #: 13143\n\n BOIES SCHILLER FLEXNER LLP\n 2029 Century Park East, Suite 1520\n Los Angeles, CA 90067\n (t) +1 (213) 995-5732\n (c) +1 (860) 508-3599\n dboyle@bsfllp.com\n www.bsfllp.com\n\n\n\n The information contained in this electronic message is confidential information intended only for the use of the named recipient(s) and may contain\n information that, among other protections, is the subject of attorney-client privilege, attorney work product or exempt from disclosure under applicable\n law. If the reader of this electronic message is not the named recipient, or the employee or agent responsible to deliver it to the named recipient, you are\n hereby notified that any dissemination, distribution, copying or other use of this communication is strictly prohibited and no privilege is waived. If you\n have received this communication in error, please immediately notify the sender by replying to this electronic message and then deleting this electronic\n message from your computer. [v.1 08201831BSF]\n\f","ocr_status":1,"date_upload":"2026-08-14T10:59:24.750157-07:00","document_number":"500","attachment_number":5,"pacer_doc_id":"123024078285","is_available":true,"is_free_on_pacer":null,"is_sealed":false,"document_type":2,"description":"Exhibit E (email correspondence between Claimants' counsel and the governme","acms_document_guid":""}],"date_created":"2026-08-14T10:59:11.085202-07:00","date_modified":"2026-08-17T18:27:38.959440-07:00","date_filed":"2026-08-14","time_filed":"13:57:39","entry_number":500,"recap_sequence_number":"2026-08-14.001","pacer_sequence_number":3436,"description":"MOTION to Compel the government to respond to Claimants' First Sets of Interrogatories and First Requests for Production by Zhi Chen, Prince Holding Group. (Attachments: # 1 Exhibit A (Claimant Chen Zhi's First Set of Interrogatories to Plaintiff), # 2 Exhibit B (Claimant Prince Group's First Set of Interrogatories to Plaintiff), # 3 Exhibit C (Claimant Chen Zhi's First Requests for Production to Plaintiff), # 4 Exhibit D (Claimant Prince Group's First Requests for Production to Plaintiff), # 5 Exhibit E (email correspondence between Claimants' counsel and the government)) (Schwartz, Matthew) (Entered: 08/14/2026)","tags":[]},{"resource_uri":"https://www.courtlistener.com/api/rest/v4/docket-entries/473942275/","id":473942275,"docket":"https://www.courtlistener.com/api/rest/v4/dockets/71639393/","recap_documents":[{"resource_uri":"https://www.courtlistener.com/api/rest/v4/recap-documents/489427137/","id":489427137,"tags":[],"absolute_url":"/docket/71639393/499/united-states-v-approximately-127271-bitcoin-btc-previously-stored-at/","date_created":"2026-08-10T16:40:08.941392-07:00","date_modified":"2026-08-22T10:34:55.055605-07:00","sha1":"5559950778588e71f44f69490b58a7796e71857f","page_count":4,"file_size":97130,"filepath_local":"recap/gov.uscourts.nyed.537552/gov.uscourts.nyed.537552.499.0.pdf","filepath_ia":"https://archive.org/download/gov.uscourts.nyed.537552/gov.uscourts.nyed.537552.499.0.pdf","ia_upload_failure_count":null,"thumbnail":null,"thumbnail_status":0,"plain_text":"Case 1:25-cv-05745-RPK-CHK Document 499 Filed 08/10/26 Page 1 of 4 PageID #:\n 13021\n\n CAHILL GORDON & REINDEL LLP\n 32 OLD SLIP\n NEW YORK, NY 10005\n TELEPHONE: (212) 701-3000\n WWW.CAHILL.COM\n\n 900 16th STREET, N.W. Suite 500 221 W. 10th STREET 20 FENCHURCH STREET\n WASHINGTON, DC 20006 WILMINGTON, DE 19801 LONDON EC3M 3BY\n (202) 862-8900 (302) 884-0000 +44 (0) 20 7920 9800\n\n\n\n\n August 10, 2026\n BY ECF AND ELECTRONIC MAIL\n The Honorable Rachel P. Kovner\n United States District Court for the Eastern District of New York\n 225 Cadman Plaza East\n Brooklyn, New York 11201\n\n Re: United States v. Approximately 127,271 Bitcoin, No. 25 Civ. 5745\n Letter to Judge Kovner re: Pre-Motion Request\n\n Dear Judge Kovner,\n\n We write on behalf of claimants Tiger Mines New York Inc. (\u201cTiger Mines\u201d) and Hassan\n Miah, pursuant to Rule IV.A of the Court\u2019s Individual Rules, to request a pre-motion conference\n in connection with Tiger Mines\u2019 anticipated motion\u2014under Supplemental Rule (\u201cSupp. R.\u201d)\n G(5)(a)(ii) and Federal Rules of Civil Procedure (\u201cRules\u201d) 6(b)(1)(B), 15(a)(2) and 15(c)\u2014\n seeking (1) nunc pro tunc acceptance of Mr. Miah\u2019s original pro se Verified Claim and Answer\n and (2) leave to file an Amended Verified Claim and Amended Answer that relate back to those\n original pro se filings. Consistent with the relief granted to other claimants and Rule IV.A.5, we\n respectfully submit that the Court may construe this letter and its enclosures as the motion itself\n and grant the requested relief without further briefing.1\n\n Procedural Background\n\n The Government commenced this in rem action on October 14, 2025, seeking forfeiture of\n approximately 127,271 Bitcoin at the twenty-five virtual currency addresses in Attachment A to\n the Verified Complaint (the \u201cDefendants In Rem\u201d), ECF No. 1. The Court extended the claim-\n filing deadline to December 29, 2025 generally, and to January 19, 2026 for claimants Chen Zhi\n and Warp Data Technology Lao Sole Co., Ltd. (\u201cWarp Data\u201d). December 11, 2025 Order; see\n also December 18 and 29, 2025 Orders. Mr. Miah received no direct notice, first learned of this\n action in late fall of 2025, and pro se filed a Verified Claim and Letter Motion for Extension of\n Time Nunc Pro Tunc on January 19, 2026 and an Answer on January 21, 2026. ECF Nos. 84, 103.\n\n\n\n 1\n Along with the enclosed proposed Amended Verified Claim, the proposed Amended Answer, the supporting\n Declaration of Hassan Miah (\u201cMiah Decl.\u201d), and a proposed order, we refer to text-only docket entries reflecting the\n Court\u2019s December 11, 2025, December 18, 2025, December 29, 2025, and January 5, 2026 orders granting other\n claimants\u2019 requests for extensions of time to file claims.\n\n\n -1-\n\fCase 1:25-cv-05745-RPK-CHK Document 499 Filed 08/10/26 Page 2 of 4 PageID #:\n 13022\n\n CAHILL GORDON & REINDEL LLP\n\n\n -2-\n\n After unrelated pro se grand jury subpoena-related motion practice resolved by the Magistrate\n Judge\u2019s April 8, 2026 Order, Mr. Miah retained undersigned counsel.\n\n Pioneer Warrants Acceptance of Mr. Miah\u2019s Pro Se Filings Nunc Pro Tunc\n\n Supp. R. G(5)(a)(ii) (\u201cgood cause\u201d) and Rule 6(b)(1)(B) (\u201cexcusable neglect\u201d) are\n governed by the four-factor analysis of Pioneer Investment Services Co. v. Brunswick Associates,\n 507 U.S. 380, 395 (1993). See also Silivanch v. Celebrity Cruises, Inc., 333 F.3d 355, 366 (2d Cir.\n 2003) (holding that Pioneer\u2019s \u201cmore liberal\u201d definition of excusable neglect applies beyond the\n bankruptcy context in which it originated). Pioneer permits this Court to accept Mr. Miah\u2019s pro se\n filings nunc pro tunc upon showing that (i) the Government would not suffer prejudice from his\n filings nunc pro tunc, (ii) the delay was short and had no adverse impact on the proceedings, (iii)\n the delay was beyond Mr. Miah\u2019s control, and (iv) Mr. Miah acted in good faith. See Pioneer, 507\n U.S. at 395.\n\n Each of the Pioneer factors favors Mr. Miah. First, the Government suffers no prejudice:\n the Defendants In Rem remain in United States custody (\u201cno risk of asset flight,\u201d December 11,\n 2025 Order). Second, the delay was short\u2014twenty-one days. Further, this delay did not adversely\n impact the proceedings, as it did not disturb the scheduling order. Third, the reason for the delay\n was beyond Mr. Miah\u2019s control: Mr. Miah received no direct notice, first learned of this action in\n late fall of 2025, and consulted multiple attorneys whose advice was inconsistent, confusing, and,\n in at least one instance, came from counsel with a pre-existing relationship with others claiming\n the same property. He also faced difficulties identifying his specific interest among the Defendants\n In Rem\u2014the same difficulty the Court credited for other claimants\u2014because Chen Zhi never\n provided the wallet-identifying information. He nonetheless filed pro se and promptly retained\n counsel thereafter. See Miah Decl. \u00b6\u00b6 49\u201350, 55. Mr. Miah acted in good faith at all times, thereby\n satisfying Pioneer\u2019s fourth and final factor.\n\n Finally, this Court has already found good cause to excuse comparable delay by other\n claimants. By its December 11, 2025 Order, the Court extended the deadline for Chen Zhi and\n Warp Data, finding \u201cgood cause\u201d based on their good-faith effort, absence of asset-flight risk or\n prejudice, and the difficulty claimants face in identifying their specific interests in the seized\n cryptocurrency. These same considerations apply with even more force to Mr. Miah, who received\n no direct notice from the government and filed on the extended deadline allowed for other\n claimants. The Court also afforded nunc pro tunc relief to pro se claimant Ath Leepinyo by its\n January 5, 2026 Order to extend his time to file an answer.2 Mr. Miah seeks comparable relief:\n nunc pro tunc acceptance of his pro se claim and answer, and leave to file the enclosed counseled,\n Rule G-compliant pleadings.\n\n\n\n 2\n The Government has since moved to strike Leepinyo\u2019s filings on grounds unrelated to timeliness. See ECF No. 197.\n That motion, which remains pending, does not bear on the relief sought here: unlike Leepinyo, Mr. Miah seeks leave\n to file Rule G-compliant amended pleadings that cure any deficiency in his original pro se submissions.\n\fCase 1:25-cv-05745-RPK-CHK Document 499 Filed 08/10/26 Page 3 of 4 PageID #:\n 13023\n\n CAHILL GORDON & REINDEL LLP\n\n\n -3-\n\n The Amended Pleadings Relate Back to Mr. Miah\u2019s Original Pro Se Filings\n\n Once the Court accepts Mr. Miah\u2019s pro se filings nunc pro tunc, the Court should allow\n Mr. Miah to submit amended pleadings on behalf of Tiger Mines that relate back to his initial\n claim under Rule 15(c). The amendments arise from the same transaction. Rule 15(c)(1)(B)\n permits relation back where the amended pleading \u201carose out of the conduct, transaction, or\n occurrence set out\u2014or attempted to be set out\u2014in the original pleading.\u201d The Amended Verified\n Claim asserts an interest in the identical property and rests on the identical transaction: Chen Zhi\u2019s\n September 18, 2024 assignment to Tiger Mines. The amended pleadings supply the precision\n Supp. R. G(5) requires, but there is no new property, transaction, or theory.\n\n Moreover, an amendment adding a party relates back where the added and original parties\n share an identity of interest such that the opposing party had notice and will not be\n prejudiced. Advanced Magnetics, Inc. v. Bayfront Partners, Inc., 106 F.3d 11, 19 (2d Cir. 1997).\n Mr. Miah is Tiger Mines\u2019 sole owner and principal and filed his pro se claim asserting ownership\n of the very property Tiger Mines now claims. The amendment only corrects the claim to name the\n entity through which Mr. Miah holds that interest. The Government has been on notice since at\n least January 19, 2026 and cannot claim surprise or prejudice\u2014particularly with the res in its\n custody.\n\n The Amended Verified Claim Is Legally Sufficient, and Amendment Would Not Be Futile\n\n Leave to amend is freely given absent undue delay, bad faith, prejudice, or futility. Foman\n v. Davis, 371 U.S. 178, 182 (1962). None are present here. The Amended Verified Claim satisfies\n Supp. R. G(5)(a)(i). It identifies the specific property\u2014the Defendants In Rem\u2014by alphanumeric\n address; states the nature and basis of the interest (ownership through Chen Zhi\u2019s September 18,\n 2024 assignment for value); and is verified under 28 U.S.C. \u00a7 1746. A claimant need only allege\n a \u201cfacially colorable interest\u201d to contest a forfeiture. United States v. $557,933.89, 287 F.3d 66,\n 79 (2d Cir. 2002). An assignment for value confers a cognizable ownership interest; the absence\n of cryptographic key custody does not defeat legal title. Whether the property is ultimately\n forfeitable, and whether Tiger Mines is a bona fide purchaser under 18 U.S.C. \u00a7 983(d)(3) is a\n merits question, not grounds to deny leave to amend. Supp. R. G reinforces this: claims are stricken\n \u201conly if [the court] is satisfied that an opportunity should not be afforded to cure the defects.\u201d Fed.\n R. Civ. P. Supp. R. G advisory committee\u2019s note to 2006 amendment. The Amended Verified\n Claim is precisely the amendment the rule contemplates, and the Amended Answer perfects Mr.\n Miah\u2019s pro se answer by responding to the Verified Complaint through counsel.\n\n * * *\n For the foregoing reasons, claimants respectfully request an order (1) accepting nunc pro\n tunc Mr. Miah\u2019s original pro se Verified Claim and Answer, and (2) granting leave to file the\n enclosed Amended Verified Claim and Amended Answer, which relate back to the original filings.\n The Court may grant this relief on the papers or, in the alternative, schedule a pre-motion\n conference.\n\fCase 1:25-cv-05745-RPK-CHK Document 499 Filed 08/10/26 Page 4 of 4 PageID #:\n 13024\n\n CAHILL GORDON & REINDEL LLP\n\n\n -4-\n\n Respectfully submitted,\n\n By: /s/ Samson A. Enzer\n Samson A. Enzer\n Kiersten A. Fletcher\n CAHILL GORDON & REINDEL LLP\n 32 Old Slip\n New York, NY 10005\n Telephone: 212-701-3125\n SEnzer@cahill.com\n KFletcher@cahill.com\n\n Attorneys for Claimants Hassan\n Miah and Tiger Mines New York Inc.\n\n\n Encls.\n cc: All counsel of record (via ECF)\n\f","ocr_status":2,"date_upload":"2026-08-10T16:40:09.446078-07:00","document_number":"499","attachment_number":null,"pacer_doc_id":"123024061611","is_available":true,"is_free_on_pacer":null,"is_sealed":false,"document_type":1,"description":"Pre Motion Conference","acms_document_guid":""},{"resource_uri":"https://www.courtlistener.com/api/rest/v4/recap-documents/489427138/","id":489427138,"tags":[],"absolute_url":"/docket/71639393/499/1/united-states-v-approximately-127271-bitcoin-btc-previously-stored-at/","date_created":"2026-08-10T16:40:11.428871-07:00","date_modified":"2026-08-22T10:35:06.749043-07:00","sha1":"602aad1481f3316ffc16f8df088c58747fd72593","page_count":20,"file_size":17970590,"filepath_local":"recap/gov.uscourts.nyed.537552/gov.uscourts.nyed.537552.499.1.pdf","filepath_ia":"https://archive.org/download/gov.uscourts.nyed.537552/gov.uscourts.nyed.537552.499.1.pdf","ia_upload_failure_count":null,"thumbnail":null,"thumbnail_status":0,"plain_text":"Case 1:25-cv-05745-RPK-CHK Document 499-1 Filed 08/10/26 Page 1 of 20 PagelD\n#: 13025\n\nUNITED STATES DISTRICT COURT\nFOR THE EASTERN DISTRICT OF NEW YORK\n\nUNITED STATES OF AMERICA,\nPlaintiff,\nVv.\n\nAPPROXIMATELY 127,271 BITCOIN (BTC) 1:25-cv-05745 (RPK) (CHK)\nPREVIOUSLY STORED AT THE VIRTUAL\nCURRENCY ADDRESSES LISTED IN\nATTACHMENT A, AND ALL PROCEEDS\nTRACEABLE THERETO,\n\nDefendants In Rem.\n\nDECLARATION OF HASSAN MIAH IN SUPPORT OF\nAMENDED VERIFIED CLAIM AND STATEMENT OF INTEREST OR RIGHT\nIN PROPERTY SUBJECT TO FORFEITURE IN REM\n\nI, Hassan Miah, declare under penalty of perjury pursuant to 28 U.S.C. \u00a7 1746 as follows:\nI. INTRODUCTION AND PROFESSIONAL BACKGROUND\n\n1. I submit this declaration in support of the present pre-motion letter and its\nenclosures, by and through my counsel Cahill Gordon & Reindel LLP (\u201cCahill\u201d). I am the sole\nowner and operator of Tiger Mines New York Inc. (\u201cTiger Mines\u201d), and I am authorized to make\nthis Declaration on behalf of Tiger Mines and to assert its claim in this action. I have personal\nknowledge of the matters set forth in this Declaration, except as to those matters expressly stated\nto be on information and belief. As to those matters, I believe they are true.\n\nDs I submit this declaration to establish three points relevant to the relief sought. First,\nTiger Mines is the owner of the cryptocurrency the Government seeks to forfeit in this action (the\n\n\u201cDefendants In Rem\u2019), having acquired it through an assignment from Chen Zhi on September 18,\n\n1\n\fCase 1:25-cv-05745-RPK-CHK Document 499-1 Filed 08/10/26 Page 2 of 20 PagelD\n#: 13026\n\n2024. Second, Tiger Mines acquired that interest in good faith and for value\u2014and at a time when\nI had no knowledge or reason to believe that the property was, or might become, subject to\nforfeiture; indeed, neither Chen Zhi nor Prince Group was indicted or designated by the U.S.\nTreasury\u2019s Office of Foreign Assets Control (\u201cOFAC\u201d) until more than a year later. Third, 1 did\nnot receive direct notice of this action and did not learn of it until late fall of 2025; after which I\nreceived inconsistent and confusing legal advice that ultimately led me to file my claim pro se.\nThe balance of this declaration sets out the facts supporting each of these points.\n\n3. Iam 70 years old and reside in Glen Head, New York. I hold a Bachelor of Business\nAdministration in Accounting from the University of Michigan (1976) and an MBA from the\nStanford Graduate School of Business (1981). Iam a former partner at KPMG, where I specialized\nin corporate finance and mergers and acquisitions. Over the course of my career, I have advised\non a wide range of financial, accounting, and digital-asset matters.\n\n4. I have spent nearly four decades working at the intersection of finance and\nemerging technology. I began my career at KPMG, where I returned in 1985 and became a partner\nin 1991; most of my assignments were in community banking, regional investment banking firms,\nand Hollywood studios. I later served as a Corporate Agent and then as Head of Technology and\nDigital Media at Creative Artists Agency (\u201cCAA\u201d). At CAA, I was a partner of the consulting\nteam that advised Seagrams on its acquisition of Universal Studios, and I later led the team that\ncreated the CAA/Intel Media Lab, the first major collaboration between Hollywood and the\ntechnology industry. I have since founded, led, and advised numerous technology companies,\nincluding as Chief Executive Officer of Xing Technology Corporation, the creator of the world\u2019s\nfirst consumer MP3 recorder, which was acquired for approximately $75 million, and as Managing\n\nDirector of Media Investments at Intel Capital Corporation. In 2020, I co-founded and became\n\fCase 1:25-cv-05745-RPK-CHK Document 499-1 Filed 08/10/26 Page 3 of 20 PagelD\n#: 13027\n\nChief Executive Officer of Paybby, a financial-technology company offering checking and savings\naccounts. Notably, Paybby implemented a comprehensive, technology-based know-your-\ncustomer (\u201cK YC\u201d) and anti-money laundering (\u201cAML\u201d) system, compliant with the U.S. Bank\nSecrecy Act, that was reviewed and accepted by the sponsor bank and regulators.\n\n>. My wife and business partner, Miranda Tan, co-founded Paybby with me. Ms. Tan\nis fluent in Chinese and has at times translated on my behalf, as I do not speak the language.\n\nIl THE TETHER ENGAGEMENT AND THE TIGER MINES LITIGATION\n\n6. In or about November 2022, I attended Bitmain\u2019s World Digital Mining Summit in\nCancun, Mexico. At the time, I was working on Cheetah Miner USA Inc. (\u201cCheetah Miner\u201d),\nwhich was a Bitcoin mining company I started. While there, a Bitmain sales representative\nintroduced me to potential investors seeking access to inexpensive power and mining sites in the\nUnited States. Among those investors were Xuesong (\u201cCharles\u201d) Ren and Haibin (\u201cHarris\u201d) Zeng,\nwhom I understood at the time to be associated with Warp Data Technology Lao Sole Co., Ltd.\n(\u201cWarp Data\u2019).\n\nTe At the time, I was unfamiliar with Prince Group. Based on my internet research at\nthe time, I understood Prince Group was a large conglomerate involved in a variety of businesses,\nincluding real estate and airlines. After the introduction, Charles introduced me to his \u201cboss,\u201d who\nI now know is Qianjiang Wei (\u201cWilliam Wei\u201d), to discuss a potential investment by Warp Data in\nCheetah Miner\u2019s mining site in Michigan. Charles mentioned that Prince Group might also be\ninterested in my digital-banking company, Paybby.\n\n8. In or about November 2023, Charles informed me that Warp Data had a wallet\nholding approximately $60 million in USDT (also known as \u201cTether\u2019) that had been frozen by\n\nTether Holdings Limited (\u201cTether Holdings\u201d) at the request of the Chinese police. After our initial\n\fCase 1:25-cv-05745-RPK-CHK Document 499-1 Filed 08/10/26 Page 4 of 20 PagelD\n#: 13028\n\ndiscussions, I learned that there were in fact two frozen Tether wallets, holding a combined value\nof approximately $160 million. Charles stated that Warp Data was looking for assistance in getting\nthe wallets unfrozen, as they had been improperly frozen by the Chinese police in an effort to\nextort Warp Data. Based on my background, Charles was interested in whether I had any ideas\nfor unfreezing the wallets. I agreed to consider how I might assist.\n\n2. In December 2023, I traveled to Cambodia, accompanied by Ms. Tan, to meet in\nperson with William Wei, Charles, and Harris to discuss a proposed strategy for unfreezing the\nwallets as well as a potential investment in Cheetah Miner and/or Paybby. The proposed strategy\ncontemplated that I would work in close collaboration with U.S.-based counsel to unfreeze the\nwallets. During this trip, William Wei informed me for the first time that Chen Zhi was the\nultimate beneficial owner of Warp Data, Prince Group, and the frozen Tether wallets.\n\n10. Following the meeting, I exchanged several proposed agreements with Chen Zhi\u2019s\nrepresentatives concerning how to structure an engagement around the unfreezing. At some point,\nit became clear in the course of these exchanges that I (through one of my entities) would need to\nacquire an ownership stake in the frozen Tether wallets in order to engage Tether Holdings directly\nand try to negotiate a resolution and/or pursue litigation. As part of these discussions, the parties\nagreed that, if my efforts succeeded in unfreezing the wallets, I would be paid a success fee for\nthat work.\n\n11. Before agreeing to assist with the Tether wallets, I made clear that I would conduct\ndiligence on the wallets and underlying USDT transactions to (1) confirm that they were not\nconnected to criminal or illicit activity\u2014and thus had been frozen in error\u2014and (2) satisfy myself\n\nthat I was not unwittingly doing business with bad actors.\n\fCase 1:25-cv-05745-RPK-CHK Document 499-1 Filed 08/10/26 Page 5 of 20 PagelD\n#: 13029\n\n12. As part of my diligence efforts, in January 2024, I purchased a subscription to\nChainalysis and commissioned an analysis by someone certified in Chainalysis, who prepared a\nreport for me on the Tether wallets (the \u201cChainalysis Report\u201d).\n\n13. The Chainalysis Report concluded that, \u201c[c]ontrary to Tether\u2019s action, the analysis\ndid not uncover any involvement with illegal or high-risk operators.\u201d The Chainalysis Report also\ndetermined that since 100% of the funds in the frozen wallets had been traced to cryptocurrency\nexchanges adhering to KYC/AML regulations before being deposited into the wallets, the funds\nin the wallets were not illicit.\n\n14. The Chainalysis Report discussed a Chinese criminal judgment from December\n2023, which purported to connect the two frozen Tether wallets to illegal gambling operations.\nBecause I understood that this Chinese criminal judgment might be the basis for Tether\u2019s decision\nto freeze the wallets, I focused on assessing the content of the judgment. Based on a translation\nof the judgment, I understood the judgment related to third parties (two individuals named Li Hai\nand Qiu Junxin) who were alleged to have helped launder proceeds from the illegal gambling\noperations of Zhao Xunli/Xunliang and Zhao Xunzhong by purchasing USDT through Binance\u2019s\ntrading platform, moving it to a wallet registered by Zhao Xunzhong, and then transferring it to\nthree wallets said to be controlled by the gambling operation\u2014two of which were the frozen Tether\nwallets. I understood the judgment did not relate to anyone in Chen Zhi\u2019s network with whom I\nhad substantively engaged to date, nor did it explicitly connect any alleged criminal activity to\nChen Zhi, Warp Data, or Prince Group.\n\n15. Around this same time, I retained King & Wood, one of the largest and leading law\nfirms in China, to engage with Chinese authorities about the Tether wallets. That engagement\n\ngave me no reason to believe the freezing of the wallets was legitimate. I also gathered and\n\fCase 1:25-cv-05745-RPK-CHK Document 499-1 Filed 08/10/26 Page 6 of 20 PagelD\n#: 13030\n\nreviewed additional diligence materials, including regarding the wallets\u2019 source of funds and KYC\nand source of wealth information on Chen Zhi and Prince Group. Based on the diligence I\nconducted and commissioned, I became comfortable that the wallets were not connected to\ncriminal activity and therefore had been frozen in error.\n\n16. In January 2024, I returned to Cambodia, accompanied by Ms. Tan, to meet for the\nfirst time with Chen Zhi, together with William Wei, Charles, Harris, and Ryan Tang (Charles\u2019\nassistant). During the meeting, and to confirm my initial diligence findings, I asked Chen Zhi,\nWilliam Wei, and Harris how the frozen Tether wallets had been funded. Harris represented that\nthe wallets had been funded with the proceeds of Warp Data\u2019s cryptocurrency-mining operations.\nChen Zhi also represented that he amassed his wealth in part through an enormously profitable\nreal estate company and offered to substantiate that representation by showing me audited financial\nstatements. I did not raise the Chinese criminal judgment with Chen Zhi during this meeting\nbecause, based on the diligence I had conducted and commissioned, I believed the judgment was\nunrelated to him.\n\n17. Based on my understanding that I (through one of my entities) needed to acquire\nan ownership stake in the frozen Tether wallets in order to engage Tether Holdings directly and\ntry to negotiate a resolution and/or pursue litigation, Chen Zhi executed an April 2024 assignment\nagreement with Tiger Mines, in which Chen Zhi assigned full rights in the wallets to Tiger Mines\nfor $500,000. Around this same time, I also discussed with Charles and Harris the possibility of\npursuing damages against Tether Holdings and the parties agreed that I would keep any recovered\ndamages for myself.\n\n18. Tiger Mines retained counsel (first Keven Kerveng Tung, P.C., and subsequently\n\nQuinn Emanuel Urquhart & Sullivan, LLP) to help unfreeze the Tether wallets.\n\fCase 1:25-cv-05745-RPK-CHK Document 499-1 Filed 08/10/26 Page 7 of 20 PagelD\n#: 13031\n\n19. Before initiating litigation against Tether Holdings in August 2024, Tiger Mines\nsought to negotiate the unfreezing of the wallets with counsel for Tether Holdings. These efforts\nincluded sending Tether Holdings\u2019 counsel a draft complaint on or about April 18, 2024; meeting\nin person with Tether Holdings\u2019 counsel to discuss a possible settlement on or about May 23, 2024;\nand providing Tether Holdings\u2019 counsel a copy of the Chinese criminal judgment on or about June\n17, 2024.\n\n20. Although Tether Holdings\u2019 counsel advised on or about July 15, 2024 that Tether\nHoldings did not intend to keep the wallets frozen indefinitely based solely on the original Chinese\nlaw-enforcement request, on or about July 31, 2024, it informed Tiger Mines that it would give\nChinese law enforcement until September 30, 2024 to commence a proceeding in the British Virgin\nIslands.\n\n21. Around this time, I took steps to assess the risk that Chinese authorities would\nprevail in a proceeding against the wallets in the British Virgin Islands, and I understood that risk\nto be low.\n\n22. On August 2, 2024, faced with continued delay and no firm commitment to release\nthe wallets, Tiger Mines filed a complaint in Tiger Mines New York Inc. v. Tether Holdings\nLimited et al., No. 24 Civ. 5905 (VEC) (S.D.N.Y.), seeking to compel Tether Holdings to return\nthe wallets and seeking damages for their unlawful seizure.\n\n23. Shortly after Tiger Mines filed suit, on or about September 6, 2024, Tether\nHoldings\u2019 counsel sent Tiger Mines\u2019 counsel a draft settlement agreement. To my surprise, the\ndraft included a provision requiring me to personally indemnify Tether Holdings in the event of\n\nfuture claims relating to the Tether wallets. On or about September 9, 2024, Tiger Mines\u2019 counsel\n\fCase 1:25-cv-05745-RPK-CHK Document 499-1 Filed 08/10/26 Page 8 of 20 PagelD\n#: 13032\n\nresponded with proposed revisions that sought to (1) remove the personal indemnification\nprovision and (2) add language providing for damages.\n\n24. With respect to the personal indemnification provision, Tether Holdings refused to\nremove the indemnification requirement. When I agreed to assist Chen Zhi, I had not contemplated\nassuming personal liability that could reach into the millions of dollars, and Tether Holdings\u2019\ninsistence on that provision caused me considerable concern.\n\nZo. With respect to the damages, Tiger Mines\u2019 claim had two components: a claim for\nthe lost interest or \u201cstaking fees\u201d Tiger Mines would have earned on approximately $160 million\nof USDT during the period the wallets were frozen, and a related lost-profits claim. Indeed, in the\nproposed settlement agreement revisions circulated on or about September 9, 2024, Tiger Mines\ninserted language secking \u201ccompensatory damages calculated by the loss staking fees in the $160\nMillion for the time the wallet was frozen.\u201d\n\n26. Onor about September 14, 2024, I requested a meeting with Chen Zhi to discuss\nthe settlement agreement.\n\n21. On or about September 16, 2024, Tiger Mines\u2019 counsel conveyed to Tether\nHoldings\u2019 counsel that Tiger Mines was pursuing \u201cpayment of damages from Tether after the\nwallets [had been] held for almost three years and Tether is able to earn \u2018[staking] interest\u2019 from\nthe wallets. Tether can propose a number of the damage.\u201d I estimated the aggregate damages claim\nTiger Mines had against Tether Holdings, including the lost staking fees and related lost profits,\nto be at least $50 million.\n\nIl. THE SEPTEMBER 18, 2024 ASSIGNMENT OF THE LUBIAN WALLETS\n28. | Onor about September 18, 2024, at Chen Zhi\u2019s invitation and accompanied by Ms.\n\nTan to translate, I met with Chen Zhi at his townhouse in London (the \u201cSeptember 2024 Meeting\u201d).\n\fCase 1:25-cv-05745-RPK-CHK Document 499-1 Filed 08/10/26 Page 9 of 20 PagelD\n. #: 13033\n\nAlso present at Chen Zhi\u2019s London townhouse were Harris and Yun (\u201cSandy\u201d) Zhou, whom I\nunderstood to be a member of Chen Zhi\u2019s senior business team. We also later met only with Chen\nZhi without others.\n\n29. During the meetings, I informed Chen Zhi of the proposed settlement agreement. [\nexplained that Tiger Mines could obtain at least an additional approximately $50 million in USDT\nfrom Tether Holdings in the form of compensatory damages for lost staking interest/lost profits\nand that I did not want to settle without receiving these damages. In response, Chen Zhi pushed\nhard for me to forgo the damages in the Tether litigation. Chen Zhi stated that if I agreed to sign\nthe Tether Holdings settlement on terms acceptable to Tether Holdings\u2014forgoing the damages\nclaim and accepting the personal indemnity provision\u2014he would, in exchange, pay the agreed-\nupon success fee, indemnify me against my personal exposure under the settlement, and assign to\nTiger Mines the assets he previously held in a separate set of cryptocurrency wallets that he\ndescribed, collectively, as his \u201cLubian wallets.\u201d Based on this and subsequent conversations with\nChen Zhi and his representatives, as well as my review of the government\u2019s allegations in this\naction, I understand the \u201cLubian wallets\u201d label to refer not only to wallets previously associated\nwith the Lubian mining pool, but also to wallets previously holding Chen Zhi\u2019s other Bitcoin.\n\n30. | When I asked for specifics on the Lubian wallets at the September 2024 Meeting,\nChen Zhi represented that the wallets were his, there were \u201ca lot\u201d of them, and they had contained\n\u201cbillions\u201d of dollars\u2019 worth of Bitcoin that belonged to him, but that they had been hacked and\nwere for the time being inaccessible to him. I viewed the Lubian wallets as essentially distressed\nassets that might prove worthless, but might also be worth billions of dollars if I succeeded in\n\nrecovering the assets Chen Zhi previously stored in them. In exchange for the potential upside of\n\fCase 1:25-cv-05745-RPK-CHK Document 499-1 Filed 08/10/26 Page 10 of 20 PagelD\n#: 13034\n\nrecovering the Bitcoin previously stored in these wallets, I accepted Chen Zhi\u2019s offer and agreed\nto forgo the damages claim and otherwise accept Tether Holdings\u2019 proposed settlement.\n\n31. At Chen Zhi\u2019s urging, Tiger Mines relinquished its damages claim against Tether\nHoldings\u2014teal and substantial value that I bargained for and gave up\u2014in exchange for the Bitcoin\nthat Chen Zhi previously held in the Lubian wallets. I was under no obligation to sign the Tether\nHoldings settlement, and I did so only because I understood that, in exchange, I would receive the\nfull consideration I had agreed to with Chen Zhi, which included the assets previously held in the\nLubian wallets. As part of that same bargain, Chen Zhi agreed to pay the agreed-upon success fee\nand to indemnify me against the personal indemnity exposure to Tether Holdings that I was to\nassume under the settlement.\n\n32. At the time Chen Zhi assigned the assets previously held in the Lubian wallets to\nTiger Mines, I understood Chen Zhi to be using \u201cLubian wallets\u201d as a shorthand label, not as a\nreference to a single mining pool or a distinct legal entity. Indeed, my subsequent conversations\nwith Chen Zhi\u2019s representatives confirmed my understanding that Chen Zhi used the term \u201cLubian\nwallets\u201d in our agreement to describe a broader set of Bitcoin holdings identical to those at issue\nin this matter. Chen Zhi did not at the meeting identify the wallets by individual cryptographic\naddress. When I asked him for that information, he explained that a member of his team would\nneed to assemble it, and I understood that the precise addresses, as well as access and control\ninformation, would be provided to me later. As such, I understand that the assets previously stored\nin the Lubian wallets Chen Zhi conveyed to Tiger Mines are the same assets that the Government\nseeks to forfeit as the Defendants In Rem, and the description Chen Zhi and his representatives\n\ngave me is consistent with how the Defendants In Rem are described in this matter. Tiger Mines\n\n10\n\fCase 1:25-cv-05745-RPK-CHK Document 499-1 Filed 08/10/26 Page 11 of 20 PagelD\n#: 13035\n\nhas held its ownership interest in the Defendants In Rem continuously since Chen Zhi\u2019s September\n18, 2024 assignment, and it presently claims that interest in this action.\n\n33. At the time of the assignment, I understood from Chen Zhi\u2019s representations that,\nnotwithstanding the \u201chacked\u201d status, Chen Zhi owned the assets that were hacked from the wallets.\nI also understood that the technical impediment to access was a temporary condition that could be\naddressed in due course, and that Chen Zhi or his associates would provide that information. I\naccepted the assignment notwithstanding that I did not at that time have cryptographic control. I\nunderstood the assignment to convey Chen Zhi\u2019s full legal and beneficial ownership interest in the\nwallets and the Bitcoin previously held in them, separate and apart from the mechanical question\nof when the private keys or seed phrases would be transferred to permit operational control.\nAlthough Chen Zhi\u2019s assignment of the assets held in the Lubian wallets to Tiger Mines was oral,\nI understood it to be a binding conveyance of his full ownership interest, and Chen Zhi never\ndisclaimed the assignment thereafter.\n\n34. At the time of the assignment of the assets previously held in the Lubian wallets, I\nhad no knowledge or reason to believe that Chen Zhi, Prince Group, Warp Data, Lubian and his\nother mining operations, or any associated person or entity was the subject of any United States\ncriminal investigation, indictment, or civil forfeiture action, or that the Lubian wallets or the\nBitcoin held in them was or might become subject to forfeiture under United States law. Based\non the diligence I had already conducted and commissioned, I had no reason to believe that the\nwallets or assets previously held therein were connected to criminal activity or potentially subject\n\nto forfeiture.\n\ni\n\fCase 1:25-cv-05745-RPK-CHK Document 499-1 Filed 08/10/26 Page 12 of 20 PagelD\n#: 13036\n\n35. Following the September 2024 Meeting and in reliance on Chen Zhi\u2019s assignment,\nI directed Tiger Mines\u2019 counsel to send Tether Holdings a revised settlement agreement removing\n\nthe request for damages, which counsel did on or about September 18, 2024.\n\nIV. THE TETHER SETTLEMENT AND CHEN ZHI\u2019S DRAINING OF THE TETHER\nWALLETS\n\n36. Tiger Mines and Tether Holdings ultimately executed a settlement agreement dated\non or about November 6, 2024 (the \u201cSettlement Agreement\u201d). In connection with that settlement,\nand consistent with the written assignment of the Tether wallets from Chen Zhi, Tiger Mines\nrepresented that it had \u201cthe sole legal and beneficial ownership interest\u201d in the wallets and the\nUSDT held therein, and that \u201c[nJeither [Chen Zhi] nor any other third party has any legal rights\nrelating to the USDT held in the Wallets.\u201d\n\n37. On or about November 20, 2024, the Tether wallets were unfrozen. At that time,\nand as Tiger Mines had truthfully represented to Tether Holdings in the Settlement Agreement,\nTiger Mines was the sole legal and beneficial owner of the wallets and the USDT held in them.\nAlthough I had been provided with certain private keys to the wallets, before I was able to use\nthose keys to access the wallets, the USDT in the Tether wallets was transferred to new wallets.\nWhen I asked Chen Zhi whether he had moved the funds, he confirmed that he had. I did not\nauthorize Chen Zhi to do so. His unilateral action deprived Tiger Mines and me of the very\nproperty we had worked for nearly a year to recover. Although I had previously discussed with\nChen Zhi the sale of Tiger Mines to him (and thus the proceeds of the Tether wallets) once the\nwallets were unfrozen, I understood that this contemplated transaction would occur through a\nnegotiated and orderly process during which I would also receive precise address, access, and\ncontrol information for the Lubian wallets\u2014not through Chen Zhi\u2019s unilateral seizure of assets\n\nthat, as of that moment, belonged to Tiger Mines.\n\n2\n\fCase 1:25-cv-05745-RPK-CHK Document 499-1 Filed 08/10/26 Page 13 of 20 PagelD\n#: 13037\n\nV. EFFORTS TO OBTAIN THE LUBIAN WALLET INFORMATION AND THE\nCONTINUING RELATIONSHIP WITH CHEN ZHI\n\n37. In or about January 2025, I traveled to London and met with Chen Zhi at his\ntownhouse, accompanied by Ms. Tan to translate (the \u201cJanuary 2025 Meeting\u201d). Chen Zhi\u2019s\nassistant, Sin Huat Yeo (\u201cAlan\u201d), was also present.\n\n38. During the January 2025 Meeting, I raised with Chen Zhi the status of the Lubian\nwallets that had been the subject of his September 18, 2024 assignment to Tiger Mines. I asked\nChen Zhi for the information necessary to specifically identify and ultimately access the Lubian\nwallets and to work to recover the assets hacked from them\u2014for example, the wallet addresses,\nany private keys or seed phrases in his custody, and any related custodial information\u2014because,\nalthough Tiger Mines held the assigned legal interest in the assets, I had no independent means of\nidentifying or controlling them. Chen Zhi explained that his assistant, Alan, would need to go\nthrough Chen Zhi\u2019s phone(s) in order to assemble the relevant information, and agreed to provide\nme with that information once Alan had done so.\n\n39. During the January 2025 Meeting, I also continued the diligence I had been\nconducting on Chen Zhi since the outset of our dealings. I asked Chen Zhi about recent negative\npress reports by Radio Free Asia (\u201cRFA\u201d). Chen Zhi adamantly disputed the reports, describing\nthem as false and damaging. Chen Zhi\u2019s denials were consistent with the diligence I had conducted\nand commissioned to that point, and I had no information contradicting them. Chen Zhi also asked\nwhether I could help address the reports, and I agreed. In the months that followed, up until Chen\nZhi\u2019s October 2025 Indictment, through Brookville LLC, a consulting firm of which I am a co-\nowner, I engaged in outreach to RFA, as well as various third parties in an effort to persuade RFA\nto retract its articles about Chen Zhi. While seeking to obtain a retraction of the RFA articles, I\n\ninformed Chen Zhi that I would follow where the evidence led, and Chen Zhi agreed to proceed\n\n13\n\fCase 1:25-cv-05745-RPK-CHK Document 499-1 Filed 08/10/26 Page 14 of 20 PagelD\n#: 13038\n\non that basis. I understood this public-affairs work to be a legitimate engagement, and I undertook\nnothing improper in connection with it.\n\n40. By this time, Chen Zhi had already drained the Tether wallets (totaling\n\napproximately $160 million), as described above. Because those wallets had been the principal\nasset securing my dealings with Chen Zhi, his draining of them left me with no practical leverage\nto compel him to deliver the Lubian wallet information he had promised. Throughout this period,\nhowever, Chen Zhi never disclaimed or retracted his assignment of the assets previously held in\nthe Lubian wallets to Tiger Mines, and members of his staff acknowledged the assignment, as\ndiscussed below.\nVI. FIRST AWARENESS OF THE CIVIL FORFEITURE ACTION\n\n41. After the January 2025 Meeting, I had no further substantive communications with\nChen Zhi about the Lubian wallets, the assets previously held therein, or their assignment to Tiger\nMines. I did not receive from Chen Zhi, Alan, or anyone else the wallet addresses, private keys,\nseed phrases, or other relevant information Chen Zhi had said Alan would assemble. My\nprofessional engagements with Chen Zhi and his associates during the spring and summer of\n2025\u2014principally the RFA engagement described above\u2014were unrelated to the Lubian wallets.\nAt no point during this period was I told that any specific cryptocurrency held by Chen Zhi\u2014let\nalone the assets held in the Lubian wallets\u2014was the subject of a forfeiture investigation or might\nbecome subject to United States forfeiture.\n\n42. On October 8, 2025, a grand jury in this District returned an Indictment charging\nChen Zhi with wire-fraud conspiracy and money-laundering conspiracy. On October 14, 2025,\nthe Indictment was unsealed, the United States filed the Verified Complaint in this action seeking\n\nthe in rem forfeiture of approximately 127,271 Bitcoin previously stored at the twenty-five virtual\n\n14\n\fCase 1:25-cv-05745-RPK-CHK Document 499-1 Filed 08/10/26 Page 15 of 20 PagelD\n#: 13039\n\ncurrency addresses listed in Attachment A, and OFAC designated Prince Group, Chen Zhi, and\nrelated individuals and entities, including Alan, Sandy, and William Wei, on the Specially\nDesignated Nationals and Blocked Persons List. These events occurred more than a year after\nChen Zhi assigned the assets previously held in the Lubian wallets to Tiger Mines.\n\n43. [did not receive direct notice of this action under Supplemental Rule G(4)(b) when\nit was filed. I have since learned from the Government\u2019s January 27, 2026 status letter (ECF No.\n126) that the operative claim-filing framework was: a default deadline of December 15, 2025 (sixty\ndays from the October 16, 2025 first day of publication on www.forfeiture.gov); a court-extended\ngeneral deadline of December 29, 2025 (Dec. 11, 2025 Order); and an extended deadline of\nJanuary 19, 2026 for certain identified claimants, including Chen Zhi and Warp Data (same order).\n\n44. In early November 2025, Ms. Tan traveled to Hong Kong with Jeremy Zucker of\nDechert LLP to meet with Harris and Charles regarding their HashUnion and Warp Data U.S.\nmatter. While in Hong Kong, Harris suggested that Ms. Tan and Mr. Zucker travel to Cambodia\nto meet with Sandy about a potential engagement concerning sanctions. Ms. Tan then traveled to\nCambodia. I understand from Ms. Tan that, during that trip, she met separately with William Wei,\nthe Chairman of Warp Data, and with Sandy, and that both acknowledged to her Tiger Mines\u2019\nownership of the Bitcoin previously held in the Lubian wallets. Sandy further asked Ms. Tan\nwhether I intended to file a claim in this civil forfeiture action concerning that Bitcoin, and told\n\nMs. Tan that, if she remained in Cambodia, she and Chen Zhi would compile and provide her\n\ninformation about the wallets that was represented to be held \u201con Chen\u2019s phone\u201d\u2014a representation\nconsistent with what Chen Zhi himself had said at the January 2025 Meeting about Alan retrieving\n\nwallet information from Chen Zhi\u2019s phone(s).\n\ni\n\fCase 1:25-cv-05745-RPK-CHK Document 499-1 Filed 08/10/26 Page 16 of 20 PagelD\n#: 13040\n\n45. My subsequent conversation with Ms. Tan was the first time I learned that the\nGovernment had filed a civil forfeiture action against the cryptocurrency Chen Zhi assigned to\nTiger Mines on September 18, 2024. The confirmation from both William Wei and Sandy that the\nBitcoin was Tiger Mines\u2019\u2014together with Sandy\u2019s offer to provide information from Chen Zhi\u2019s\nphone\u2014was consistent with my understanding of the September 2024 assignment and confirmed\nthat Chen Zhi\u2019s own associates recognized Tiger Mines\u2019 ownership interest in the property. This\nconversation further confirmed for me that the assets in the Lubian wallets Chen Zhi assigned to\nme were the same assets as the Defendants In Rem.\n\n46. Around the same time, I consulted a number of attorneys about whether and how\nto file a claim to assert Tiger Mines\u2019 interest in the Defendants In Rem, what information a claim\nwould require, and whether I could interact directly with Chen Zhi and his associates given their\nlegal exposure and the fact that they had been sanctioned. Without waiving attorney-client\nprivilege, the advice I received was inconsistent, confusing, and, in at least one instance, came\nfrom attorneys who had a pre-existing relationship with other individuals claiming ownership of\nthe Bitcoin at issue in the forfeiture action.\u2019 As a result, I did not immediately file a claim.\n\nVil. THE JANUARY 13, 2026 FBI CONTACT AND THE JANUARY 2026 PRO SE\nFILINGS\n\n47. On January 13, 2026, FBI agents contacted me without prior notice. To the best of\nmy recollection, the agents identified themselves as FBI personnel and stated that they wished to\nspeak with me in connection with an ongoing investigation. They asked, among other things,\n\nwhether I had a professional engagement with Chen Zhi. This was the first occasion on which any\n\n' To the extent any description of legal advice in this Declaration could be construed as a waiver of attorney-client\nprivilege, no such waiver is intended, and any such potential disclosure is limited to what is necessary to establish\nthe Pioneer \u201creason for the delay\u201d factor and the related Rule G(5)(a)(ii) \u201cgood cause\u201d showing. I do not, by virtue\nof this declaration, waive any privilege as to communications with counsel on any other subject.\n\n16\n\fCase 1:25-cv-05745-RPK-CHK Document 499-1 Filed 08/10/26 Page 17 of 20 PagelD\n#: 13041\n\nUnited States law-enforcement agency contacted me directly in connection with any matter\ninvolving Chen Zhi, Prince Group, Warp Data, the Lubian wallets, or any of the individuals or\nentities referenced in the Verified Complaint.\n\n48. Immediately following the FBI contact, I engaged counsel to handle the\ncommunication with the FBI on my behalf. I have since learned from the Government\u2019s\nsubmission at ECF No. 349 that, on January 15, 2026, my counsel informed the Government that\nI likely would agree to be interviewed but needed additional time to meet with her first; that on\nJanuary 22, 2026, my counsel proposed January 29, 2026 as an interview date; and that on January\n26, 2026, my counsel communicated to the Government that I was no longer willing to be\ninterviewed.\n\n49. Around the same time as the FBI\u2019s January 13, 2026 contact, I learned that the\nCourt had extended the claims-filing deadline from December 29, 2025 to January 19, 2026 for\ncertain identified claimants, including Chen Zhi and Warp Data. Concerned that I had not been\nreceiving sound or disinterested advice, and unwilling to risk further prejudice, I determined to file\nmy claim by January 19, 2026\u2014the extended deadline the Court had granted certain identified\nclaimants\u2014albeit on a rushed, pro se basis.\n\n50. I prepared the January 19, 2026 filing personally and without the assistance of\ncounsel, and submitted it through the EDNY Pro Se Electronic Delivery Portal. The filing\nconsisted of a Letter Motion for Extension of Time Nunc Pro Tunc under Supplemental Rule\nG(5)(a)(ii) and Federal Rule of Civil Procedure 6(b)(1)(B), a Verified Claim of Hassan Miah, Pro\nSe, and a Proposed Order, and was docketed at ECF No. 84. Two days later, on January 21, 2026,\nI filed an Answer of Claimant Hassan Miah (ECF No. 103), likewise prepared personally and\n\nwithout the assistance of counsel.\n\n17\n\fCase 1:25-cv-05745-RPK-CHK Document 499-1 Filed 08/10/26 Page 18 of 20 PagelD\n#: 13042\n\nVI. THE GRAND JURY SUBPOENA\n\n51. OnMarch 9, 2026, FBI agents served a grand jury subpoena on me personally. The\nsubpoena directed me to appear before the grand jury on March 26, 2026 and indicated that I could\ncomply by producing certain specified documents in lieu of testimony. The subpoena was\naccompanied by a cover letter from Assistant U.S. Attorney Benjamin L. Weintraub requesting\nthat I refrain from disclosing the existence or contents of the subpoena while the investigation was\nongoing.\n\n52. On March 10, 2026, I filed three pro se motions in this action: a Motion for\nProtective Order (ECF No. 318), a Motion to Quash Grand Jury Subpoena (ECF No. 319), and a\nMotion to File the Grand Jury Subpoena Under Seal (ECF No. 321). On March 17, 2026, the\nGovernment filed a response (ECF No. 349). On March 19, 2026, I filed a sealed pro se Reply\nand supporting Declaration (ECF Nos. 354, 355). On March 30, 2026, the Government filed a\nsur-reply (ECF No. 379).\n\nos On April 8, 2026, Magistrate Judge Clay H. Kaminsky issued an Order denying my\nMotion for Protective Order and my Motion to Quash, denying my Motion to Seal the subpoena\nas moot, and granting my Motion to Seal the Reply. The Order indicated that I could \u201cmake an\napplication for court-appointed counsel pursuant to the Criminal Justice Act (CJA), 18 U.S.C. \u00a7\n3006A, as well as Section ITI(A)(9) of this District?s CJA Plan.\u201d\n\n54. Shortly thereafter, I retained counsel to represent me and Tiger Mines in pursuing\nmy claim.\n\n55. From the time I first learned of this action in late fall of 2025, I have sought to\nprotect my interest in the Defendants In Rem as promptly as my circumstances allowed. I did not\n\nreceive direct notice of this action and learned of it only secondhand; and the advice available to\n\n18\n\fCase 1:25-cv-05745-RPK-CHK Document 499-1 Filed 08/10/26 Page 19 of 20 PagelD\n#: 13043\n\nme before I retained Cahill was inconsistent, confusing, and, in at least one instance, came from\nattorneys who had a pre-existing relationship with other individuals claiming ownership of the\nBitcoin at issue in this action. Notwithstanding those circumstances, I filed my pro se Verified\nClaim and Letter Motion for Extension of Time Nunc Pro Tunc on January 19, 2026\u2014the date to\nwhich the Court had extended the deadline for certain identified claimants\u2014and my pro se Answer\non January 21, 2026. Once I retained Cahill in April 2026, I moved promptly to perfect the claim\nthrough this pre-motion letter and its enclosures. The facts set forth in this Declaration are also\nthe facts on which the proposed Amended Verified Claim and Amended Answer enclosed with\nthe pre-motion letter are based, and I have reviewed those proposed pleadings and confirm that the\nfactual statements they contain concerning the ownership interest in the Defendants In Rem are\n\ntrue and correct to the best of my knowledge. I respectfully submit this Declaration in support of\n\nthat effort.\n\n19\n\fCase 1:25-cv-05745-RPK-CHK Document 499-1 Filed 08/10/26 Page 20 of 20 PagelD\n#: 13044\n\nI declare under penalty of perjury that the foregoing is true and correct.\n\nExecuted on August 7, 2026, in Glen Head, New York.\n\nHassan Miah\n\n20\n","ocr_status":1,"date_upload":"2026-08-10T16:40:31.469436-07:00","document_number":"499","attachment_number":1,"pacer_doc_id":"123024061612","is_available":true,"is_free_on_pacer":null,"is_sealed":false,"document_type":2,"description":"Declaration of Hassan Miah","acms_document_guid":""},{"resource_uri":"https://www.courtlistener.com/api/rest/v4/recap-documents/489427139/","id":489427139,"tags":[],"absolute_url":"/docket/71639393/499/2/united-states-v-approximately-127271-bitcoin-btc-previously-stored-at/","date_created":"2026-08-10T16:40:11.445678-07:00","date_modified":"2026-08-22T10:34:55.322288-07:00","sha1":"75a697fb81987edc7830c0f63f5cbac22001c020","page_count":5,"file_size":24590,"filepath_local":"recap/gov.uscourts.nyed.537552/gov.uscourts.nyed.537552.499.2.pdf","filepath_ia":"https://archive.org/download/gov.uscourts.nyed.537552/gov.uscourts.nyed.537552.499.2.pdf","ia_upload_failure_count":null,"thumbnail":null,"thumbnail_status":0,"plain_text":"Case 1:25-cv-05745-RPK-CHK Document 499-2 Filed 08/10/26 Page 1 of 5 PageID\n #: 13045\n\n\n\n UNITED STATES DISTRICT COURT\n FOR THE EASTERN DISTRICT OF NEW YORK\n\n\n UNITED STATES OF AMERICA,\n\n Plaintiff,\n\n v.\n\n APPROXIMATELY 127,271 BITCOIN (BTC) 1:25-cv-05745 (RPK) (CHK)\n PREVIOUSLY STORED AT THE VIRTUAL\n CURRENCY ADDRESSES LISTED IN\n ATTACHMENT A, AND ALL PROCEEDS\n TRACEABLE THERETO,\n\n Defendants In Rem.\n\n\n\n\n AMENDED VERIFIED CLAIM AND STATEMENT OF INTEREST OR RIGHT IN\n PROPERTY SUBJECT TO FORFEITURE IN REM\n\n Pursuant to Rule G(5)(a)(i) of the Supplemental Rules for Admiralty or Maritime Claims\n\n and Asset Forfeiture Actions (the \u201cSupplemental Rules\u201d), Claimants Tiger Mines New York Inc.\n\n (\u201cTiger Mines\u201d) and Hassan Miah (together with Tiger Mines, the \u201cClaimants\u201d) hereby file this\n\n Amended Verified Claim and Statement of Interest or Right in Property Subject to Forfeiture In\n\n Rem, pursuant to the contemporaneously-filed pre-motion letter. Claimants appear through their\n\n counsel, Cahill Gordon & Reindel LLP, and state as follows:\n\n 1. Mr. Miah is a resident of Glen Head, New York. He holds a Bachelor of Business\n\n Administration in Accounting from the University of Michigan and a Master\u2019s in Business\n\n Administration from Stanford University\u2019s Graduate School of Business, and is a former partner\n\n at KPMG who has spent much of his career advising on financial, accounting, and digital-asset\n\n\n\n\n 1\n\fCase 1:25-cv-05745-RPK-CHK Document 499-2 Filed 08/10/26 Page 2 of 5 PageID\n #: 13046\n\n\n\n matters. Mr. Miah is the sole owner and principal of Tiger Mines, a New York corporation through\n\n which he holds his interest in the Defendant Property (as defined below).\n\n 2. Pursuant to Supplemental Rule G(5)(a)(i), Tiger Mines asserts a direct and legally\n\n cognizable ownership interest in the cryptocurrency identified at the twenty-five (25) virtual\n\n currency addresses listed in Attachment A to the Government\u2019s Verified Complaint (ECF No. 1),\n\n together with all proceeds traceable thereto (the \u201cDefendant Property\u201d); Mr. Miah, as the sole\n\n owner and principal of Tiger Mines, holds his interest in the Defendant Property through Tiger\n\n Mines. Those addresses are:\n\n (1) 3Pja5FPK1wFB9LkWWJai8XYL1qjbqqT9Ye;\n\n (2) 3FrM1He2ZDbsSKmYpEZQNGjFTLMgCZZkaf;\n\n (3) 3B1u4PsuFzww1P8if5jYmitXxpMs2EMSqt;\n\n (4) 3JJ8b7voMPSPChHazdHkrZMqxC7Cb4vNk2;\n\n (5) 3PWNGS2357TnjRX7FpewqR3e3qsWwpFrJH;\n\n (6) 34Jpa4Eu3ApoPVUKNTN2WeuXVVq1jzxgPi;\n\n (7) 338uPVW8drux5gSemDS4gFLSGrSfAiEvpX;\n\n (8) 3J4sTPyD1g6KvNUSJxjwLs4iaPeDPqxUZr;\n\n (9) 33uEsaGLcF9H46Dvzx1kMnuMCQ13ndkAjV;\n\n (10) 3KabDvdetZXDHNm9HXowLc9SppiSXKn7UU;\n\n (11) 38Md7BghVmV7XUUT1Vt9CvVcc5ssMD6ojt;\n\n (12) 3GaB3nRWA1PLc3XQkkbpVtFwYYZEuMxD4i;\n\n (13) 32i6n2vXhjvJg1vniURFy7A5VK6eG6oDgg;\n\n (14) 3HuUiXmKN3beQSoM97kWjK1fesWWJvKvaZ;\n\n (15) 34MFtk9iMxYcUPZWXHfiGfqz4o7X3kpJbV;\n\n\n\n 2\n\fCase 1:25-cv-05745-RPK-CHK Document 499-2 Filed 08/10/26 Page 3 of 5 PageID\n #: 13047\n\n\n\n (16) 3LjTXe31gepN8nW3AZyKpyD2QwbtmfjNwm;\n\n (17) 3MHa8JJ3bu8j3x3iQHhqsrZvk1EjBQmC78;\n\n (18) 3AWpzKtkHfWsiv9RGXKA3Z8951LefsUGXQ;\n\n (19) 34KYo7VdVr5CJ7m4hYhH9RpwqXhbsTrw4T;\n\n (20) 3DdFSGcXaP2rZ9CaL3tjnqRARvQ5K3VW4a;\n\n (21) 39B6oSa58qNpFMGpuowtRHAYp3fM4ghXRq;\n\n (22) 3NmHmQte2rP8pS54U3B8LPYQKkpG1pFF69;\n\n (23) 3BA3PEF4BMoy9y3kdMRUdMhL8Gp24vikhF;\n\n (24) 389JrNcn8trYgYi2EtHi4X7bTCqtVbep86; and\n\n (25) 339khCuymVi4FKbW9hCHkH3CQwdopXiTvA.\n\n This is the property in which Claimants assert their interest.\n\n 3. As set forth in the attached Declaration of Hassan Miah dated August 7, 2026 (the\n\n \u201cMiah Declaration\u201d), Tiger Mines is the legal and beneficial owner of the Defendant Property by\n\n virtue of an assignment from Chen Zhi to Tiger Mines on or about September 18, 2024. Mr. Miah,\n\n as the sole owner of Tiger Mines, holds his interest in the Defendant Property through Tiger Mines.\n\n 4. Prior to the assignment of the Defendant Property, Chen Zhi had assigned to Tiger\n\n Mines two wallets previously frozen by Tether Holdings Limited (\u201cTether Holdings\u201d). Tiger\n\n Mines initially worked to unfreeze the wallets through negotiation, but ultimately commenced\n\n litigation against Tether Holdings in the Southern District of New York on August 2, 2024. Tiger\n\n Mines and Tether Holdings then engaged in settlement negotiations. In consideration for the\n\n assignment of the Defendant Property, Mr. Miah and Tiger Mines agreed to (i) execute the\n\n settlement agreement with Tether Holdings on terms acceptable to Tether Holdings, including\n\n relinquishing an approximately $50 million damages claim that Tiger Mines had against Tether\n\n\n\n 3\n\fCase 1:25-cv-05745-RPK-CHK Document 499-2 Filed 08/10/26 Page 4 of 5 PageID\n #: 13048\n\n\n\n Holdings arising from the frozen Tether wallets, so that the settlement could close; and (ii) accept\n\n the personal indemnity exposure to Tether Holdings that Mr. Miah assumed under that settlement.\n\n The relinquishment of Tiger Mines\u2019 approximately $50 million damages claim constituted the\n\n value given in exchange for the Defendant Property, which Tiger Mines acquired after the conduct\n\n alleged to give rise to forfeiture and without knowledge or reasonable cause to believe that the\n\n property was subject to forfeiture, rendering Tiger Mines a bona fide purchaser for value under 18\n\n U.S.C. \u00a7 983(d)(3).\n\n 5. The assignment conveyed to Tiger Mines Mr. Chen\u2019s full legal and beneficial\n\n ownership interest in the cryptocurrency wallets Mr. Chen described as the \u201cLubian wallets\u201d\u2014a\n\n shorthand label Mr. Chen used to refer to a broader set of his mining-derived Bitcoin holdings,\n\n and not solely wallets associated with the Lubian mining pool. The wallets so assigned are the\n\n same wallets the Government now seeks to forfeit in this action. As set forth in detail in the Miah\n\n Declaration, Claimants\u2019 interest in the Defendant Property is further supported by the execution of\n\n the Tether settlement agreement on Mr. Chen\u2019s terms, the forbearance from pressing Tiger Mines\u2019\n\n damages claim against Tether Holdings, Mr. Miah\u2019s January 2025 conversations with Mr. Chen\n\n regarding the wallet information, and the independent confirmations Ms. Tan, Mr. Miah\u2019s spouse,\n\n received from Mr. Chen\u2019s associates Qianjiang Wei (also known as \u201cWilliam Wei\u201d) and Yun Zhou\n\n (also known as \u201cSandy\u201d) in early November 2025 acknowledging Tiger Mines\u2019 ownership of the\n\n wallets.\n\n 6. This Amended Verified Claim is filed pursuant to the contemporaneously-filed pre-\n\n motion letter which, under Supplemental Rule G(5)(a)(ii) and Federal Rules of Civil Procedure\n\n 6(b)(1)(B), 15(a)(2), and 15(c), seeks (1) nunc pro tunc acceptance of Mr. Miah\u2019s original pro se\n\n Verified Claim and Answer and (2) leave to file the Amended Verified Claim and Amended\n\n\n\n 4\n\fCase 1:25-cv-05745-RPK-CHK Document 499-2 Filed 08/10/26 Page 5 of 5 PageID\n #: 13049\n\n\n\n Answer. On January 19, 2026, Mr. Miah filed a pro se Verified Claim (ECF No. 84) asserting his\n\n interest in the Defendant Property, and the claim asserted herein by Tiger Mines shares an identity\n\n of interest with, and relates back to, that filing. The Amended Verified Claim submitted herewith\n\n cures the procedural and substantive deficiencies in the original pro se filing.\n\n 7. Claimants reserve all rights and remedies available in law and equity to defend their\n\n interest in the Defendant Property.\n\n VERIFICATION\n\n I, Hassan Miah, declare under penalty of perjury pursuant to 28 U.S.C. \u00a7 1746 as follows:\n\n 1. I am a Claimant in this action and the sole owner and principal of Claimant Tiger\n\n Mines New York Inc., and I am authorized to make this verification on behalf of Tiger Mines.\n\n 2. I have read the foregoing Amended Verified Claim and verify that all of the factual\n\n allegations contained herein are true and correct to the best of my knowledge.\n\n Dated: August 10, 2026\n\n /s/ Hassan Miah\n Hassan Miah, individually and as sole\n owner of Tiger Mines New York Inc.\n\n\n\n Respectfully submitted,\n\n\n /s/ Samson A. Enzer\n Samson A. Enzer\n Kiersten A. Fletcher\n CAHILL GORDON & REINDEL LLP\n 32 Old Slip\n New York, NY 10005\n Telephone: 212-701-3125\n SEnzer@cahill.com\n KFletcher@cahill.com\n\n Attorneys for Claimants Hassan\n Miah and Tiger Mines New York Inc.\n\n 5\n\f","ocr_status":2,"date_upload":"2026-08-10T16:40:33.643635-07:00","document_number":"499","attachment_number":2,"pacer_doc_id":"123024061613","is_available":true,"is_free_on_pacer":null,"is_sealed":false,"document_type":2,"description":"Amended Verified Claim","acms_document_guid":""},{"resource_uri":"https://www.courtlistener.com/api/rest/v4/recap-documents/489427140/","id":489427140,"tags":[],"absolute_url":"/docket/71639393/499/3/united-states-v-approximately-127271-bitcoin-btc-previously-stored-at/","date_created":"2026-08-10T16:40:11.462468-07:00","date_modified":"2026-08-22T10:35:05.698937-07:00","sha1":"a69b36f3bdf1e59d67f533017bbfce4a43e1334c","page_count":8,"file_size":728198,"filepath_local":"recap/gov.uscourts.nyed.537552/gov.uscourts.nyed.537552.499.3.pdf","filepath_ia":"https://archive.org/download/gov.uscourts.nyed.537552/gov.uscourts.nyed.537552.499.3.pdf","ia_upload_failure_count":null,"thumbnail":null,"thumbnail_status":0,"plain_text":"Case 1:25-cv-05745-RPK-CHK Document 499-3 Filed 08/10/26 Page 1 of 8 PageID\n #: 13050\n\n\n Case 1:25-cv-05745-RPK Document 84 Filed 01/19/26 Page 4 of 6 PageID #: 2448\n UNITED STATES DISTRICT COURT\n UNITED STATES DISTRICT COURT\n FOR THE EASTERN DISTRICT OF NEW YORK\n UNITED STATES OF AMERICA,\n\n\n\n UNITED STATES OF\n AMERICA,\n\n Plaintiff,\n\n v.\n 1:25-cv-05745 (RPK) (CHK)\n APPROXIMATELY 127,271 BITCOIN\n (BTC) PREVIOUSLY STORED AT THE\n VIRTUAL CURRENCY ADDRESSES\n LISTED IN ATTACHMENT A, AND ALL\n PROCEEDS TRACEABLE THERETO,\n\n Defendants In Rem.\n Plaintiff,\n\n\n v.\n APPROXIMATELY 127,271 BITCOIN,\n\n Defendant in Rem.\n\n\n\n\n Case No. 1:25-cv-05745 (RPK)\n\n\n AMENDED VERIFIED CLAIM AND STATEMENT OF HASSAN MIAH, PRO\n SEINTEREST OR RIGHT IN\n PROPERTY SUBJECT TO FORFEITURE IN REM\n Pursuant to Rule G(5)(a)(i) of the Supplemental Rules for Admiralty or Maritime Claims\n\n and Asset Forfeiture Actions (the \u201cSupplemental Rules\u201d), Claimants Tiger Mines New York Inc.\n\n (\u201cTiger Mines\u201d) and Hassan Miah (together with Tiger Mines, the \u201cClaimants\u201d) hereby file this\n\n Amended Verified Claim and Statement of Interest or Right in Property Subject to Forfeiture In\n\n Rem, pursuant to the contemporaneously-filed pre-motion letter. Claimants appear through their\n\n counsel, Cahill Gordon & Reindel LLP, and state as follows:\n\fCase 1:25-cv-05745-RPK-CHK Document 499-3 Filed 08/10/26 Page 2 of 8 PageID\n #: 13051\n\n\n\n 1. Mr. Miah is a resident of Glen Head, New York. He holds a Bachelor of Business\n\n Administration in Accounting from the University of Michigan and a Master\u2019s in Business\n\n Administration from Stanford University\u2019s Graduate School of Business, and is a former partner\n\n at KPMG who has spent much of his career advising on financial, accounting, and digital-asset\n\fCase 1:25-cv-05745-RPK-CHK Document 499-3 Filed 08/10/26 Page 3 of 8 PageID\n #: 13052\n\n matters. Mr. Miah is the sole owner and principal of Tiger Mines, a New York corporation\n\n through which he holds his interest in the Defendant Property (as defined below).\n\n\n I, Hassan Miah, submit this Verified Claim pursuant2. Pursuant to Supplemental Rule\n G(5)(a):(i), Tiger Mines asserts a direct and legally\n cognizable ownership interest in the cryptocurrency identified at the twenty-five (25) virtual\n\n currency addresses listed in Attachment A to the Government\u2019s Verified Complaint (ECF No. 1),\n\n together with all proceeds traceable thereto (the \u201cDefendant Property\u201d); Mr. Miah, as the sole\n\n owner and principal of Tiger Mines, holds his interest in the Defendant Property through Tiger\n\n Mines. Those addresses are:\n\n (1) 3Pja5FPK1wFB9LkWWJai8XYL1qjbqqT9Ye;\n\n (2) 3FrM1He2ZDbsSKmYpEZQNGjFTLMgCZZkaf;\n\n (3) 3B1u4PsuFzww1P8if5jYmitXxpMs2EMSqt;\n\n (4) 3JJ8b7voMPSPChHazdHkrZMqxC7Cb4vNk2;\n\n (5) 3PWNGS2357TnjRX7FpewqR3e3qsWwpFrJH;\n\n (6) 34Jpa4Eu3ApoPVUKNTN2WeuXVVq1jzxgPi;\n\n (7) 338uPVW8drux5gSemDS4gFLSGrSfAiEvpX;\n\n (8) 3J4sTPyD1g6KvNUSJxjwLs4iaPeDPqxUZr;\n\n (9) 33uEsaGLcF9H46Dvzx1kMnuMCQ13ndkAjV;\n\n (10) 3KabDvdetZXDHNm9HXowLc9SppiSXKn7UU;\n\n (11) 38Md7BghVmV7XUUT1Vt9CvVcc5ssMD6ojt;\n\n (12) 3GaB3nRWA1PLc3XQkkbpVtFwYYZEuMxD4i;\n\n (13) 32i6n2vXhjvJg1vniURFy7A5VK6eG6oDgg;\n\n (14) 3HuUiXmKN3beQSoM97kWjK1fesWWJvKvaZ;\n\n (15) 34MFtk9iMxYcUPZWXHfiGfqz4o7X3kpJbV;\n\fCase 1:25-cv-05745-RPK-CHK Document 499-3 Filed 08/10/26 Page 4 of 8 PageID\n #: 13053\n\n (16) 3LjTXe31gepN8nW3AZyKpyD2QwbtmfjNwm;\n\n (17) 3MHa8JJ3bu8j3x3iQHhqsrZvk1EjBQmC78;\n\n (18) 3AWpzKtkHfWsiv9RGXKA3Z8951LefsUGXQ;\n\n (19) 34KYo7VdVr5CJ7m4hYhH9RpwqXhbsTrw4T;\n\n (20) 3DdFSGcXaP2rZ9CaL3tjnqRARvQ5K3VW4a;\n\n (21) 39B6oSa58qNpFMGpuowtRHAYp3fM4ghXRq;\n\n (22) 3NmHmQte2rP8pS54U3B8LPYQKkpG1pFF69;\n\n (23) 3BA3PEF4BMoy9y3kdMRUdMhL8Gp24vikhF;\n\n (24) 389JrNcn8trYgYi2EtHi4X7bTCqtVbep86; and\n\n (25) 339khCuymVi4FKbW9hCHkH3CQwdopXiTvA.\n\n\n This is the property in which Claimants assert their interest.\n 3. As set forth in the attached Declaration of Hassan Miah dated August 7, 2026 (the\n\n \u201cMiah Declaration\u201d), Tiger Mines is the legal and beneficial owner of the Defendant Property by\n\n virtue of an assignment from Chen Zhi to Tiger Mines on or about September 18, 2024. Mr. Miah,\n\n as the sole owner of Tiger Mines, holds his interest in the Defendant Property through Tiger Mines.\n\n 4. Prior to the assignment of the Defendant Property, Chen Zhi had assigned to Tiger\n\n Mines two wallets previously frozen by Tether Holdings Limited (\u201cTether Holdings\u201d). Tiger\n\n Mines initially worked to unfreeze the wallets through negotiation, but ultimately commenced\n\n litigation against Tether Holdings in the Southern District of New York on August 2, 2024. Tiger\n\n Mines and Tether Holdings then engaged in settlement negotiations. In consideration for the\n\n assignment of the Defendant Property, Mr. Miah and Tiger Mines agreed to (i) execute the\n\n settlement agreement with Tether Holdings on terms acceptable to Tether Holdings, including\n\n relinquishing an approximately $50 million damages claim that Tiger Mines had against Tether\n\fCase 1:25-cv-05745-RPK-CHK Document 499-3 Filed 08/10/26 Page 5 of 8 PageID\n #: 13054\n\n Holdings arising from the frozen Tether wallets, so that the settlement could close; and (ii) accept\n\n the personal indemnity exposure to Tether Holdings that Mr. Miah assumed under that\n\n settlement. The relinquishment of Tiger Mines\u2019 approximately $50 million damages claim\n\n constituted the value given in exchange for the Defendant Property, which Tiger Mines acquired\n\n after the conduct alleged to give rise to forfeiture and without knowledge or reasonable cause to\n\n believe that the property was subject to forfeiture, rendering Tiger Mines a bona fide purchaser\n\n for value under 18 U.S.C. \u00a7 983(d)(3).\n\n 5. The assignment conveyed to Tiger Mines Mr. Chen\u2019s full legal and beneficial\n\n ownership interest in the cryptocurrency wallets Mr. Chen described as the \u201cLubian wallets\u201d\u2014a\n\n shorthand label Mr. Chen used to refer to a broader set of his mining-derived Bitcoin holdings,\n\n and not solely wallets associated with the Lubian mining pool. The wallets so assigned are the\n\n same wallets the Government now seeks to forfeit in this action. As set forth in detail in the Miah\n\n Declaration, Claimants\u2019 interest in the Defendant Property is further supported by the execution\n\n of the Tether settlement agreement on Mr. Chen\u2019s terms, the forbearance from pressing Tiger\n\n Mines\u2019 damages claim against Tether Holdings, Mr. Miah\u2019s January 2025 conversations with Mr.\n\n Chen regarding the wallet information, and the independent confirmations Ms. Tan, Mr. Miah\u2019s\n\n spouse, received from Mr. Chen\u2019s associates Qianjiang Wei (also known as \u201cWilliam Wei\u201d) and\n\n Yun Zhou (also known as \u201cSandy\u201d) in early November 2025 acknowledging Tiger Mines\u2019\n\n ownership of the wallets.\n\n 6. This Amended Verified Claim is filed pursuant to the contemporaneously-filed pre-\n\n motion letter which, under Supplemental Rule G(5)(a)(ii) and Federal Rules of Civil Procedure\n\n 6(b)(1)(B), 15(a)(2), and 15(c), seeks (1) nunc pro tunc acceptance of Mr. Miah\u2019s original pro se\n\n Verified Claim and Answer and (2) leave to file the Amended Verified Claim and Amended\n\f Case 1:25-cv-05745-RPK-CHK Document 499-3 Filed 08/10/26 Page 6 of 8 PageID\n #: 13055\n\nAnswer. On January 19, 2026, Mr. Miah filed a pro se Verified Claim (ECF No. 84) asserting his\n\ninterest in the Defendant Property, and the claim asserted herein by Tiger Mines shares an identity\n\nof interest with, and relates back to, that filing. The Amended Verified Claim submitted herewith\n\n1. I am a natural person filing this claimcures the procedural and substantive deficiencies in the original\npro se filing.\n 2. I assert a direct, personal, and legally cognizable interest in the Defendant Assets,\n including but not limited to the Bitcoin associated with the wallet addresses identified in\n the Verified Complaint and any traceable proceeds.\n\n 7. Claimants reserve all rights and remedies available in law and equity to defend their\n\n3. I intend to contest the forfeiture ofinterest in the Defendant AssetsProperty.\n 4. I respectfully request that the Court accept this Verified Claim nunc pro tunc and deem it\n timely as granted to other claimants.\n\n VERIFICATION\n\n 5. I, Hassan Miah, declare under penalty of perjury that the foregoing is true and correct.pursuant to 28\n U.S.C. \u00a7 1746 as follows:\n\n\n\n Dated: Nassau County, New York\n\n 1. I am a Claimant in this action and the sole owner and principal of Claimant Tiger\n\nMines New York Inc., and I am authorized to make this verification on behalf of Tiger Mines.\n\n 2. I have read the foregoing Amended Verified Claim and verify that all of the factual\n\nallegations contained herein are true and correct to the best of my knowledge.\n\nJanuary 17Dated: August 10, 2026\n\n\n\n\n /s/ Hassan Miah\n Hassan Miah, Pro Seindividually and as sole\n\fCase 1:25-cv-05745-RPK-CHK Document 499-3 Filed 08/10/26 Page 7 of 8 PageID\n #: 13056\n\n\n Case 1:25-cv-05745-RPK Document 84 Filed 01/19/26 Page 5 of 6 PageID #: 2449\n owner of Tiger Mines New York Inc.\n\n\n\n Respectfully submitted,\n\n\n /s/ Samson A. Enzer\n Samson A. Enzer\n Kiersten A. Fletcher\n CAHILL GORDON & REINDEL LLP\n 32 Old Slip\n 1080 Old Country Road, Suite 1042\n WestburyNew York, NY\n 1159010005\n Telephone: 212-701-3125\n hmiah@brookvillellc SEnzer@cahill.\n com\n\n 917-545-0137\n KFletcher@cahill.com\n\n Attorneys for Claimants Hassan\n Miah and Tiger Mines New York Inc.\n\fCase 1:25-cv-05745-RPK-CHK Document 499-3 Filed 08/10/26 Page 8 of 8 PageID\n #: 13057\n\n\n\n\n Summary report:\n Litera Compare for Word 11.9.0.82 Document comparison done on\n 8/10/2026 2:42:09 PM\n Style name: Cahill Default\n Intelligent Table Comparison: Active\n Original filename:\n US_DIS_NYED_1_25cv5745_d16584330e65137_MOTION_for_Extension_of_\n Time_to_File_Verfied_Claim.pdf\n Modified filename: 2 - Amended Verified Claim.pdf\n Changes:\n Add 84\n Delete 30\n Move From 3\n Move To 3\n Table Insert 1\n Table Delete 0\n Table moves to 0\n Table moves from 0\n Embedded Graphics (Visio, ChemDraw, Images etc.) 1\n Embedded Excel 0\n Format changes 0\n Total Changes: 122\n\f","ocr_status":1,"date_upload":"2026-08-10T16:40:36.347888-07:00","document_number":"499","attachment_number":3,"pacer_doc_id":"123024061614","is_available":true,"is_free_on_pacer":null,"is_sealed":false,"document_type":2,"description":"Verified Claim - Redline","acms_document_guid":""},{"resource_uri":"https://www.courtlistener.com/api/rest/v4/recap-documents/489427141/","id":489427141,"tags":[],"absolute_url":"/docket/71639393/499/4/united-states-v-approximately-127271-bitcoin-btc-previously-stored-at/","date_created":"2026-08-10T16:40:11.479114-07:00","date_modified":"2026-08-22T10:35:04.988127-07:00","sha1":"7b60549538874bf5dcb218bec2a0bb9d7528d0c3","page_count":14,"file_size":42946,"filepath_local":"recap/gov.uscourts.nyed.537552/gov.uscourts.nyed.537552.499.4.pdf","filepath_ia":"https://archive.org/download/gov.uscourts.nyed.537552/gov.uscourts.nyed.537552.499.4.pdf","ia_upload_failure_count":null,"thumbnail":null,"thumbnail_status":0,"plain_text":"Case 1:25-cv-05745-RPK-CHK Document 499-4 Filed 08/10/26 Page 1 of 14 PageID\n #: 13058\n\n\n\n UNITED STATES DISTRICT COURT\n FOR THE EASTERN DISTRICT OF NEW YORK\n\n\n UNITED STATES OF AMERICA,\n\n Plaintiff,\n\n v.\n\n APPROXIMATELY 127,271 BITCOIN (BTC) 1:25-cv-05745 (RPK) (CHK)\n PREVIOUSLY STORED AT THE VIRTUAL\n CURRENCY ADDRESSES LISTED IN\n ATTACHMENT A, AND ALL PROCEEDS\n TRACEABLE THERETO,\n\n Defendants In Rem.\n\n\n\n CLAIMANTS TIGER MINES NEW YORK INC. AND HASSAN MIAH\u2019S AMENDED\n ANSWER TO VERIFIED COMPLAINT IN REM\n\n Pursuant to Rule G(5)(b) of the Supplemental Rules for Admiralty or Maritime Claims and\n\n Asset Forfeiture Actions (the \u201cSupplemental Rules\u201d), Claimants Tiger Mines New York Inc.\n\n (\u201cTiger Mines\u201d) and Hassan Miah (together with Tiger Mines, the \u201cClaimants\u201d) hereby answer the\n\n Government\u2019s Verified Complaint In Rem, dated October 14, 2025 (ECF No. 1). Tiger Mines is\n\n the assignee and owner of the cryptocurrency identified at the twenty-five (25) virtual currency\n\n addresses listed in Attachment A to the Government\u2019s Verified Complaint In Rem, together with\n\n all proceeds traceable thereto (the \u201cDefendant Property\u201d), and Mr. Miah, as the sole owner and\n\n principal of Tiger Mines, holds his interest therein through Tiger Mines. This Amended Answer\n\n is filed pursuant to the contemporaneously-filed pre-motion letter which, under Supplemental Rule\n\n G(5)(a)(ii) and Federal Rules of Civil Procedure 6(b)(1)(B), 15(a)(2), and 15(c), seeks (1) nunc\n\n pro tunc acceptance of Mr. Miah\u2019s original pro se Verified Claim and Answer and (2) leave to file\n\n the Amended Verified Claim and Amended Answer. On January 21, 2026, Mr. Miah filed a pro\n\n 1\n\fCase 1:25-cv-05745-RPK-CHK Document 499-4 Filed 08/10/26 Page 2 of 14 PageID\n #: 13059\n\n\n\n se Answer (ECF No. 103), and this Amended Answer relates back to that filing under Federal Rule\n\n of Civil Procedure 15(c). Claimants respond to the allegations in the Verified Complaint as\n\n follows:\n\n NATURE OF THE ACTION\n\n 1. Claimants admit that this is a civil action in rem concerning the above-captioned\n\n defendant property. Claimants deny that the United States has any right, title, or interest in the\n\n Defendant Property that is superior to the right, title, or interest of Claimants in the Defendant\n\n Property.\n\n 2. Paragraph 2 contains legal conclusions to which no response is required. To the\n\n extent a response is required, Claimants deny that any of the authorities referenced in Paragraph 2\n\n confer on the United States any right, title, or interest in the Defendant Property that is superior to\n\n the right, title, or interest of Claimants in the Defendant Property.\n\n JURISDICTION AND VENUE\n\n 3. Paragraph 3 contains jurisdictional and legal conclusions to which no response is\n\n required. To the extent a response is required, Claimants admit that this Court has jurisdiction\n\n over this action pursuant to 28 U.S.C. \u00a7\u00a7 1345 and 1355.\n\n 4. Paragraph 4 contains jurisdictional and legal conclusions to which no response is\n\n required. To the extent a response is required, Claimants lack knowledge sufficient to admit or\n\n deny the allegation that acts and omissions giving rise to the forfeiture occurred in the Eastern\n\n District of New York.\n\n THE DEFENDANTS IN REM\n\n 5. Claimants admit that the Defendant Property is the approximately 127,271 Bitcoin\n\n that was once stored at the addresses listed in Attachment A to the Verified Complaint. Claimants\n\n\n\n 2\n\fCase 1:25-cv-05745-RPK-CHK Document 499-4 Filed 08/10/26 Page 3 of 14 PageID\n #: 13060\n\n\n\n deny any characterization of the Defendant Property that is inconsistent with Tiger Mines\u2019\n\n ownership interest therein. Claimants lack knowledge sufficient to admit or deny the remaining\n\n allegations in Paragraph 5.\n\n 6. Claimants lack knowledge sufficient to admit or deny the allegations in Paragraph\n\n 6.\n\n RELEVANT STATUTES AND REGULATIONS\n\n A. Wire Fraud\n\n 7. Paragraph 7 characterizes a statute that speaks for itself, and no response is\n\n required.\n\n 8. Paragraph 8 characterizes a statute that speaks for itself, and no response is\n\n required.\n\n B. Money Laundering\n\n 9. Paragraph 9 characterizes a statute that speaks for itself, and no response is\n\n required.\n\n 10. Paragraph 10 characterizes a statute that speaks for itself, and no response is\n\n required.\n\n 11. Paragraph 11 characterizes a statute that speaks for itself, and no response is\n\n required.\n\n 12. Paragraph 12 characterizes and purports to quote a statute that speaks for itself, and\n\n no response is required.\n\n C. Forfeiture Statutes\n\n 13. Paragraph 13 characterizes a statute that speaks for itself, and no response is\n\n required. To the extent a response is required, Claimants deny that any of the authorities referenced\n\n\n\n 3\n\fCase 1:25-cv-05745-RPK-CHK Document 499-4 Filed 08/10/26 Page 4 of 14 PageID\n #: 13061\n\n\n\n in Paragraph 13 confer on the United States any right, title, or interest in the Defendant Property\n\n that is superior to the right, title, or interest of Claimants in the Defendant Property.\n\n 14. Paragraph 14 characterizes a statute that speaks for itself, and no response is\n\n required. To the extent a response is required, Claimants deny that any of the authorities referenced\n\n in Paragraph 14 confer on the United States any right, title, or interest in the Defendant Property\n\n that is superior to the right, title, or interest of Claimants in the Defendant Property.\n\n FACTS\n\n A. Introduction\n\n 15. Claimants lack knowledge sufficient to admit or deny the allegations in Paragraph\n\n 15.\n\n B. Relevant Individuals and Entities\n\n 16. Claimants lack knowledge sufficient to admit or deny the allegations in Paragraph\n\n 16, including subsections (a) through (y).\n\n C. Relevant Terms and Definitions\n\n 17. Claimants admit the allegations in: (1) the first sentence in subsection 17(d); (2) the\n\n first sentence in subsection 17(e); (3) the first sentence in subsection 17(f); (4) subsection 17(h);\n\n (5) the first two sentences in subsection 17(i); and (6) the first sentence in subsection 17(j).\n\n Claimants lack knowledge sufficient to admit or deny the remaining allegations in Paragraph 17,\n\n including subsections (a) through (c), (g), (k) and (l), as well as the remaining sentences in\n\n subsections (d) through (f), (i), and (j).\n\n D. The Criminal Schemes\n\n i. Background\n\n\n\n\n 4\n\fCase 1:25-cv-05745-RPK-CHK Document 499-4 Filed 08/10/26 Page 5 of 14 PageID\n #: 13062\n\n\n\n 18. Claimants lack knowledge sufficient to admit or deny the allegations in Paragraph\n\n 18.\n\n 19. Paragraph 19 purports to quote a document that speaks for itself, and no response\n\n is required. Claimants lack knowledge sufficient to admit or deny the remaining allegations in\n\n Paragraph 19.\n\n 20. Claimants lack knowledge sufficient to admit or deny the allegations in Paragraph\n\n 20.\n\n ii. The Fraud Schemes\n\n 21. Claimants lack knowledge sufficient to admit or deny the allegations in Paragraph\n\n 21.\n\n a. The Scam Compounds\n\n 22. Claimants lack knowledge sufficient to admit or deny the allegations in Paragraph\n\n 22.\n\n 23. Claimants lack knowledge sufficient to admit or deny the allegations in Paragraph\n\n 23.\n\n 24. Claimants lack knowledge sufficient to admit or deny the allegations in Paragraph\n\n 24.\n\n 25. Claimants lack knowledge sufficient to admit or deny the allegations in Paragraph\n\n 25.\n\n 26. Claimants lack knowledge sufficient to admit or deny the allegations in Paragraph\n\n 26.\n\n b. Use of Bribes and Violence in Furtherance of the Schemes\n\n\n\n\n 5\n\fCase 1:25-cv-05745-RPK-CHK Document 499-4 Filed 08/10/26 Page 6 of 14 PageID\n #: 13063\n\n\n\n 27. Claimants lack knowledge sufficient to admit or deny the allegations in Paragraph\n\n 27.\n\n 28. Claimants lack knowledge sufficient to admit or deny the allegations in Paragraph\n\n 28.\n\n 29. Claimants lack knowledge sufficient to admit or deny the allegations in Paragraph\n\n 29.\n\n 30. Claimants lack knowledge sufficient to admit or deny the allegations in Paragraph\n\n 30.\n\n 31. Claimants lack knowledge sufficient to admit or deny the allegations in Paragraph\n\n 31.\n\n c. The Brooklyn Network\n\n 32. Claimants lack knowledge sufficient to admit or deny the allegations in Paragraph\n\n 32.\n\n 33. Claimants lack knowledge sufficient to admit or deny the allegations in Paragraph\n\n 33.\n\n 34. Claimants lack knowledge sufficient to admit or deny the allegations in Paragraph\n\n 34.\n\n 35. Claimants lack knowledge sufficient to admit or deny the allegations in Paragraph\n\n 35.\n\n 36. Claimants lack knowledge sufficient to admit or deny the allegations in Paragraph\n\n 36.\n\n 37. Claimants lack knowledge sufficient to admit or deny the allegations in Paragraph\n\n 37 and Footnote 2.\n\n\n\n 6\n\fCase 1:25-cv-05745-RPK-CHK Document 499-4 Filed 08/10/26 Page 7 of 14 PageID\n #: 13064\n\n\n\n iii. The Money Laundering Schemes\n\n 38. Claimants lack knowledge sufficient to admit or deny the allegations in Paragraph\n\n 38.\n\n 39. Claimants lack knowledge sufficient to admit or deny the allegations in Paragraph\n\n 39.\n\n 40. Claimants lack knowledge sufficient to admit or deny the allegations in Paragraph\n\n 40 and Footnote 3.\n\n 41. Footnote 4 purports to quote a document that speaks for itself, and no response is\n\n required. Claimants lack knowledge sufficient to admit or deny the remaining allegations in\n\n Paragraph 41.\n\n 42. Claimants admit that the Lubian mining operation produced bitcoin through\n\n cryptocurrency mining operations. Claimants lack knowledge sufficient to admit or deny the\n\n remaining allegations in Paragraph 42.\n\n 43. Claimants lack knowledge sufficient to admit or deny the allegations in Paragraph\n\n 43 and Footnote 5.\n\n E. The Defendants In Rem\n\n 44. Claimants admit that the government is seeking to forfeit Bitcoin that was stored at\n\n the twenty-five cryptocurrency addresses identified in the table following Paragraph 44. Claimants\n\n deny that the table following Paragraph 44 describing the twenty-five cryptocurrency addresses as\n\n \u201cChen Wallets\u201d is accurate, to the extent the term \u201cChen Wallets\u201d implies that all of the Defendant\n\n Property belonged to Mr. Chen at the time of the government\u2019s seizure. Mr. Chen assigned his\n\n ownership interests in the twenty-five cryptocurrency addresses identified in the table following\n\n\n\n\n 7\n\fCase 1:25-cv-05745-RPK-CHK Document 499-4 Filed 08/10/26 Page 8 of 14 PageID\n #: 13065\n\n\n\n Paragraph 44 to Tiger Mines on or about September 18, 2024. Claimants lack knowledge\n\n sufficient to admit or deny the remaining allegations in Paragraph 44 and Footnotes 6 and 7.\n\n 45. Claimants lack knowledge sufficient to admit or deny the allegations in Paragraph\n\n 45 and Footnote 8.\n\n 46. Claimants lack knowledge sufficient to admit or deny the allegations in Paragraph\n\n 46 and the following table.\n\n 47. Claimants lack knowledge sufficient to admit or deny the allegations in Paragraph\n\n 47 and Footnote 9, including subsections (a) through (m).\n\n 48. Claimants lack knowledge sufficient to admit or deny the allegations in Paragraph\n\n 48.\n\n 49. Claimants lack knowledge sufficient to admit or deny the allegations in Paragraph\n\n 49.\n\n 50. Claimants lack knowledge sufficient to admit or deny the allegations in Paragraph\n\n 50.\n\n 51. Claimants lack knowledge sufficient to admit or deny the allegations in Paragraph\n\n 51.\n\n 52. Claimants lack knowledge sufficient to admit or deny the allegations in Paragraph\n\n 52.\n\n 53. Claimants lack knowledge sufficient to admit or deny the allegations in Paragraph\n\n 53.\n\n 54. Claimants lack knowledge sufficient to admit or deny the allegations in Paragraph\n\n 54.\n\n\n\n\n 8\n\fCase 1:25-cv-05745-RPK-CHK Document 499-4 Filed 08/10/26 Page 9 of 14 PageID\n #: 13066\n\n\n\n 55. Claimants lack knowledge sufficient to admit or deny the allegations in Paragraph\n\n 55, including subsections (a) through (g).\n\n 56. Claimants lack knowledge sufficient to admit or deny the allegations in Paragraph\n\n 56.\n\n 57. Claimants lack knowledge sufficient to admit or deny the allegations in Paragraph\n\n 57.\n\n 58. Claimants lack knowledge sufficient to admit or deny the allegations in Paragraph\n\n 58.\n\n F. Criminal and Regulatory Actions\n\n 59. Claimants admit that the indictment charging Mr. Chen was unsealed on October\n\n 14, 2025. Claimants further admit that, on October 14, 2025 as well, the Prince Group\n\n Transnational Criminal Organization was designated by the United States Department of\n\n Treasury\u2019s Office of Foreign Assets Control (\u201cOFAC\u201d) and Prince Holding Group and many of\n\n its affiliates were placed on the Specially Designated Nationals and Blocked Persons List.\n\n Claimants lack knowledge sufficient to admit or deny the remaining allegations in Paragraph 59.\n\n FIRST CLAIM FOR RELIEF\n (Proceeds Traceable to Wire Fraud)\n\n 60. Claimants incorporate and reallege each and every response to Paragraphs 1\n\n through 59 set forth above as though set forth in full here.\n\n 61. Paragraph 61 contains legal conclusions to which no response is required. To the\n\n extent a response is required, Claimants deny that any of the allegations in Paragraph 61 confer on\n\n the United States any right, title, or interest in the Defendant Property that is superior to the right,\n\n title, or interest of Claimants in the Defendant Property.\n\n\n\n\n 9\n\fCase 1:25-cv-05745-RPK-CHK Document 499-4 Filed 08/10/26 Page 10 of 14 PageID\n #: 13067\n\n\n\n 62. Paragraph 62 contains legal conclusions to which no response is required. To the\n\n extent a response is required, Claimants deny that any of the allegations in Paragraph 62 confer on\n\n the United States any right, title, or interest in the Defendant Property that is superior to the right,\n\n title, or interest of Claimants in the Defendant Property.\n\n SECOND CLAIM FOR RELIEF\n (Property Involved in Money Laundering)\n\n 63. Claimants incorporate and reallege each and every response to Paragraphs 1\n\n through 62 set forth above as though set forth in full here.\n\n 64. Paragraph 64 contains legal conclusions to which no response is required. To the\n\n extent a response is required, Claimants deny that any of the allegations in Paragraph 64 confer on\n\n the United States any right, title, or interest in the Defendant Property that is superior to the right,\n\n title, or interest of Claimants in the Defendant Property.\n\n 65. Paragraph 65 contains legal conclusions to which no response is required. To the\n\n extent a response is required, Claimants deny that any of the allegations in Paragraph 65 confer on\n\n the United States any right, title, or interest in the Defendant Property that is superior to the right,\n\n title, or interest of Claimants in the Defendant Property.\n\n AFFIRMATIVE DEFENSES\n\n The defenses asserted herein are based on Claimants\u2019 knowledge, information, and belief\n\n at this time. Claimants specifically reserve the right to assert additional affirmative defenses and\n\n other defenses and/or modify, amend, or supplement any defense contained herein at any time.\n\n Without admitting any of the facts alleged in the Complaint except as specifically set forth above,\n\n and without assuming any burden of proof, persuasion, or production not otherwise legally\n\n\n\n\n 10\n\fCase 1:25-cv-05745-RPK-CHK Document 499-4 Filed 08/10/26 Page 11 of 14 PageID\n #: 13068\n\n\n\n assigned to them as to any element of the government\u2019s claims, Claimants assert the following\n\n affirmative and other defenses:\n\n 1. Tiger Mines possesses a legal and beneficial ownership interest in the Defendant\n\n Property by virtue of the assignment from Mr. Chen made on or about September 18, 2024, for\n\n value\u2014namely, in exchange for the relinquishment of a damages claim that Tiger Mines held\n\n against Tether Holdings in the amount of at least $50 million. Mr. Miah, as the sole owner of\n\n Tiger Mines, holds his interest in the Defendant Property through Tiger Mines.\n\n 2. Tiger Mines is an \u201cinnocent owner\u201d of the Defendant Property within the meaning\n\n of 18 U.S.C. \u00a7 983(d), and specifically, a bona fide purchaser for value under 18 U.S.C. \u00a7\n\n 983(d)(3). Tiger Mines acquired its interest in the Defendant Property through the September\n\n 2024 assignment\u2014after the conduct alleged to give rise to forfeiture\u2014and did not know, and was\n\n reasonably without cause to believe, that the property was subject to forfeiture. Specifically, at\n\n the time of the assignment: (a) neither Tiger Mines nor Mr. Miah had any knowledge or reason to\n\n believe that Mr. Chen or any associated person or entity was the subject of any United States\n\n criminal investigation, indictment, or civil forfeiture action; (b) Mr. Miah, who has years of\n\n industry-specific knowledge from working with digital asset companies, had conducted his own\n\n due diligence into the property at issue, which included an analysis that \u201cdid not uncover any\n\n involvement with illegal or high-risk operators,\u201d such that he had no reason to believe that the\n\n property provided to him was connected to criminal activity; and (c) the Indictment, the civil\n\n forfeiture Verified Complaint, and the OFAC designation were not issued until October 2025,\n\n more than a year after the assignment.\n\n 3. Tiger Mines is a bona fide purchaser for value of the Defendant Property under 18\n\n U.S.C. \u00a7 983(d)(3). It acquired its interest in a good-faith transaction, in exchange for substantial\n\n\n\n 11\n\fCase 1:25-cv-05745-RPK-CHK Document 499-4 Filed 08/10/26 Page 12 of 14 PageID\n #: 13069\n\n\n\n and legitimate consideration as described above, and without knowledge or reason to believe that\n\n the property was subject to forfeiture. Accordingly, Tiger Mines\u2019 interest as a bona fide purchaser\n\n for value is superior to any interest the United States may have in the Defendant Property.\n\n 4. Upon information and belief, the Defendant Property lacks a sufficient nexus to the\n\n alleged criminal activity to support forfeiture. The Verified Complaint alleges that the addresses\n\n comprising the Defendant Property were primarily funded by two categories of sources:\n\n cryptocurrency mining\u2014including mining attributable to the Lubian and Warp Data mining\n\n operations\u2014and indirect transfers from cryptocurrency exchanges (see \u00b6 45). To the extent the\n\n Defendant Property, or any portion thereof, constitutes newly mined Bitcoin generated through the\n\n Lubian mining operation or any other cryptocurrency mining operation, such Bitcoin is not\n\n \u201cproceeds traceable to\u201d wire fraud under 18 U.S.C. \u00a7 981(a)(1)(C), nor is it \u201cproperty involved in\u201d\n\n a money laundering transaction under 18 U.S.C. \u00a7 981(a)(1)(A), nor is there a \u201csubstantial\n\n connection\u201d between the Defendant Property and any money laundering transaction as is required\n\n by 18 U.S.C. \u00a7 983(c)(3), because the mining of new Bitcoin through computational processes is\n\n an independent economic activity that does not constitute, derive from, or connect to the specified\n\n unlawful activity alleged in the Verified Complaint.\n\n 5. The forfeiture of the Defendant Property in which Claimants hold an interest would\n\n violate the Excessive Fines Clause of the Eighth Amendment to the United States Constitution.\n\n Neither Tiger Mines nor Mr. Miah is alleged to have participated in or to have had knowledge of\n\n the criminal activity described in the Verified Complaint. Forfeiting the property of a bona fide\n\n purchaser for value that acquired its interest without knowledge of the underlying criminal activity,\n\n and that is not alleged to have engaged in any wrongdoing, would be grossly disproportional to\n\n any offense and would constitute an excessive fine within the meaning of the Eighth Amendment.\n\n\n\n 12\n\fCase 1:25-cv-05745-RPK-CHK Document 499-4 Filed 08/10/26 Page 13 of 14 PageID\n #: 13070\n\n\n\n 6. The causes of action alleged in the Verified Complaint are barred by the relevant\n\n statutes of limitations.\n\n 7. Claimants deny all allegations not expressly admitted herein and specifically\n\n reserve the right to amend this Answer, to raise additional defenses, cross-claims, and third-party\n\n claims not asserted herein as may be warranted by the revelation of information during further\n\n proceedings, and to pursue alternative remedies under civil forfeiture law.\n\n 8. Claimants incorporate by reference any defense that any other claimant pleads in\n\n this action, to the extent the defense applies to any claims against the Defendant Property, in whole\n\n or in part, and is otherwise consistent with this Answer.\n\n PRAYER FOR RELIEF\n\n WHEREFORE, Claimants respectfully request that the Court:\n\n 1. Enter judgment in favor of Claimants and against Plaintiff.\n\n 2. Declare that Tiger Mines is the lawful owner of the Defendant Property by virtue\n\n of the September 2024 assignment from Mr. Chen, and that Mr. Miah holds his interest therein\n\n through Tiger Mines.\n\n 3. Declare that Tiger Mines is an innocent owner of the Defendant Property within the\n\n meaning of 18 U.S.C. \u00a7 983(d).\n\n 4. Order that the Defendant Property be released from Plaintiff\u2019s custody and returned\n\n to Tiger Mines.\n\n 5. Order that the Defendant Property be preserved and maintained subject to the\n\n Court\u2019s jurisdiction, and that no distribution or disposition occur unless and until Claimants\u2019\n\n asserted ownership rights are adjudicated.\n\n 6. Award Claimants their attorneys\u2019 fees and the costs of suit.\n\n\n\n 13\n\fCase 1:25-cv-05745-RPK-CHK Document 499-4 Filed 08/10/26 Page 14 of 14 PageID\n #: 13071\n\n\n\n 7. Grant Claimants such other and further relief as the Court deems just and proper.\n\n\n\n\n Dated: August 10, 2026 Respectfully submitted,\n\n\n /s/ Samson A. Enzer\n Samson A. Enzer\n Kiersten A. Fletcher\n CAHILL GORDON & REINDEL LLP\n 32 Old Slip\n New York, NY 10005\n Telephone: 212-701-3125\n SEnzer@cahill.com\n KFletcher@cahill.com\n\n Attorneys for Claimants Hassan\n Miah and Tiger Mines New York Inc.\n\n\n\n\n 14\n\f","ocr_status":2,"date_upload":"2026-08-10T16:40:38.731147-07:00","document_number":"499","attachment_number":4,"pacer_doc_id":"123024061615","is_available":true,"is_free_on_pacer":null,"is_sealed":false,"document_type":2,"description":"Amended Answer","acms_document_guid":""},{"resource_uri":"https://www.courtlistener.com/api/rest/v4/recap-documents/489427142/","id":489427142,"tags":[],"absolute_url":"/docket/71639393/499/5/united-states-v-approximately-127271-bitcoin-btc-previously-stored-at/","date_created":"2026-08-10T16:40:11.531471-07:00","date_modified":"2026-08-22T10:35:06.317318-07:00","sha1":"2a093ff42f81284efba427b5dc926e97ec1a967d","page_count":16,"file_size":712009,"filepath_local":"recap/gov.uscourts.nyed.537552/gov.uscourts.nyed.537552.499.5.pdf","filepath_ia":"https://archive.org/download/gov.uscourts.nyed.537552/gov.uscourts.nyed.537552.499.5.pdf","ia_upload_failure_count":null,"thumbnail":null,"thumbnail_status":0,"plain_text":"Case 1:25-cv-05745-RPK-CHK Document 499-5 Filed 08/10/26 Page 1 of 16 PageID\n #: 13072\n\n\n\n UNITED STATES DISTRICT COURT\n FOR THE EASTERN DISTRICT OF NEW YORK\n\n\n\n UNITED STATES OF\n AMERICA,\n\n Plaintiff,\n\n v.\n 1:25-cv-05745 (RPK) (CHK)\n APPROXIMATELY 127,271 BITCOIN (BTC)\n PREVIOUSLY STORED AT THE VIRTUAL\n CURRENCY ADDRESSES LISTED IN\n ATTACHMENT A, AND ALL PROCEEDS\n TRACEABLE THERETO,\n\n Defendants In Rem.\n\n\n CLAIMANTS TIGER MINES NEW YORK INC. AND HASSAN MIAH\u2019S AMENDED\n ANSWER TO VERIFIED COMPLAINT IN REM\n Pursuant to Rule G(5)(b) of the Supplemental Rules for Admiralty or Maritime Claims and\n\n Asset Forfeiture Actions (the \u201cSupplemental Rules\u201d), Claimants Tiger Mines New York Inc.\n\n (\u201cTiger Mines\u201d) and Hassan Miah (together with Tiger Mines, the \u201cClaimants\u201d) hereby answer the\n\n Government\u2019s Verified Complaint In Rem, dated October 14, 2025 (ECF No. 1). Tiger Mines is the\n\n assignee and owner of the cryptocurrency identified at the twenty-five (25) virtual currency\n\n addresses listed in Attachment A to the Government\u2019s Verified Complaint In Rem, together with all\n\n proceeds traceable thereto (the \u201cDefendant Property\u201d), and Mr. Miah, as the sole owner and\n\n principal of Tiger Mines, holds his interest therein through Tiger Mines. This Amended Answer is\n\n filed pursuant to the contemporaneously-filed pre-motion letter which, under Supplemental Rule\n\n G(5)(a)(ii) and Federal Rules of Civil Procedure 6(b)(1)(B), 15(a)(2), and 15(c), seeks (1) nunc pro\n\n tunc acceptance of Mr. Miah\u2019s original pro se Verified Claim and Answer and (2) leave to file the\n\n Amended Verified Claim and Amended Answer. On January 21, 2026, Mr. Miah filed a pro\n\fCase 1:25-cv-05745-RPK-CHK Document 499-5 Filed 08/10/26 Page 2 of 16 PageID\n #: 13073\n\n se Answer (ECF No. 103), and this Amended Answer relates back to that filing under Federal\n\n Rule of Civil Procedure 15(c). Claimants respond to the allegations in the Verified Complaint as\n\n follows:\n\n\n NATURE OF THE ACTION\n 1. Claimants admit that this is a civil action in rem concerning the above-captioned\n\n defendant property. Claimants deny that the United States has any right, title, or interest in the\n\n Defendant Property that is superior to the right, title, or interest of Claimants in the Defendant\n\n Property.\n\n 2. Paragraph 2 contains legal conclusions to which no response is required. To the\n\n extent a response is required, Claimants deny that any of the authorities referenced in Paragraph 2\n\n confer on the United States any right, title, or interest in the Defendant Property that is superior to\n\n the right, title, or interest of Claimants in the Defendant Property.\n\n\n JURISDICTION AND VENUE\n 3. Paragraph 3 contains jurisdictional and legal conclusions to which no response is\n\n required. To the extent a response is required, Claimants admit that this Court has jurisdiction\n\n over this action pursuant to 28 U.S.C. \u00a7\u00a7 1345 and 1355.\n\n 4. Paragraph 4 contains jurisdictional and legal conclusions to which no response is\n\n required. To the extent a response is required, Claimants lack knowledge sufficient to admit or\n\n deny the allegation that acts and omissions giving rise to the forfeiture occurred in the Eastern\n\n District of New York.\n\n\n THE DEFENDANTS IN REM\n 5. Claimants admit that the Defendant Property is the approximately 127,271 Bitcoin\n\n that was once stored at the addresses listed in Attachment A to the Verified Complaint.\n\n Claimants\n\fCase 1:25-cv-05745-RPK-CHK Document 499-5 Filed 08/10/26 Page 3 of 16 PageID\n #: 13074\n\n deny any characterization of the Defendant Property that is inconsistent with Tiger Mines\u2019\n\n ownership interest therein. Claimants lack knowledge sufficient to admit or deny the remaining\n\n allegations in Paragraph 5.\n\n\n 6. Claimants lack knowledge sufficient to admit or deny the allegations in Paragraph\n\n 6.\n\n RELEVANT STATUTES AND REGULATIONS\n\n A. Wire Fraud\n 7. Paragraph 7 characterizes a statute that speaks for itself, and no response is\n\n required.\n\n\n 8. Paragraph 8 characterizes a statute that speaks for itself, and no response is\n\n required.\n\n B. Money Laundering\n 9. Paragraph 9 characterizes a statute that speaks for itself, and no response is\n\n required.\n\n 10. Paragraph 10 characterizes a statute that speaks for itself, and no response is\n\n required.\n\n 11. Paragraph 11 characterizes a statute that speaks for itself, and no response is\n\n required.\n\n\n 12. Paragraph 12 characterizes and purports to quote a statute that speaks for itself, and\n\n no response is required.\n\n C. Forfeiture Statutes\n 13. Paragraph 13 characterizes a statute that speaks for itself, and no response is\n\n required. To the extent a response is required, Claimants deny that any of the authorities referenced\n\fCase 1:25-cv-05745-RPK-CHK Document 499-5 Filed 08/10/26 Page 4 of 16 PageID\n #: 13075\n\n in Paragraph 13 confer on the United States any right, title, or interest in the Defendant Property\n\n that is superior to the right, title, or interest of Claimants in the Defendant Property.\n\n 14. Paragraph 14 characterizes a statute that speaks for itself, and no response is\n\n required. To the extent a response is required, Claimants deny that any of the authorities referenced\n\n in Paragraph 14 confer on the United States any right, title, or interest in the Defendant Property\n\n that is superior to the right, title, or interest of Claimants in the Defendant Property.\n\n\n FACTS\n\n A. Introduction\n\n 15. Claimants lack knowledge sufficient to admit or deny the allegations in Paragraph\n\n 15.\n\n B. Relevant Individuals and Entities\n\n 16. Claimants lack knowledge sufficient to admit or deny the allegations in Paragraph\n\n 16, including subsections (a) through (y).\n\n C. Relevant Terms and Definitions\n 17. Claimants admit the allegations in: (1) the first sentence in subsection 17(d); (2) the\n\n first sentence in subsection 17(e); (3) the first sentence in subsection 17(f); (4) subsection 17(h); (5)\n\n the first two sentences in subsection 17(i); and (6) the first sentence in subsection 17(j). Claimants\n\n lack knowledge sufficient to admit or deny the remaining allegations in Paragraph 17, including\n\n subsections (a) through (c), (g), (k) and (l), as well as the remaining sentences in subsections (d)\n\n through (f), (i), and (j).\n\n\n D. The Criminal Schemes\n\n i. Background\n\fCase 1:25-cv-05745-RPK-CHK Document 499-5 Filed 08/10/26 Page 5 of 16 PageID\n #: 13076\n\n\n\n 18. Claimants lack knowledge sufficient to admit or deny the allegations in Paragraph\n\n 18.\n 19. Paragraph 19 purports to quote a document that speaks for itself, and no response\n\n is required. Claimants lack knowledge sufficient to admit or deny the remaining allegations in\n\n Paragraph 19.\n\n\n 20. Claimants lack knowledge sufficient to admit or deny the allegations in\n\n 20.\n\n ii. The Fraud Schemes\n\n 21. Claimants lack knowledge sufficient to admit or deny the allegations in\n\n 21.\n\n a. The Scam Compounds\n\n 22. Claimants lack knowledge sufficient to admit or deny the allegations in\n\n 22.\n\n 23. Claimants lack knowledge sufficient to admit or deny the allegations in\n\n 23.\n\n 24. Claimants lack knowledge sufficient to admit or deny the allegations in\n\n 24.\n\n 25. Claimants lack knowledge sufficient to admit or deny the allegations in\n\n 25.\n\n 26. Claimants lack knowledge sufficient to admit or deny the allegations in\n\n 26.\n\n b. Use of Bribes and Violence in Furtherance of the Schemes\n\fCase 1:25-cv-05745-RPK-CHK Document 499-5 Filed 08/10/26 Page 6 of 16 PageID\n #: 13077\n\n\n\n 27. Claimants lack knowledge sufficient to admit or deny the allegations in Paragraph\n 27.\n\n 28.\n Claimants lack knowledge sufficient to admit or deny the allegations in Paragraph\n 28.\n\n 29.\n Claimants lack knowledge sufficient to admit or deny the allegations in Paragraph\n 29.\n\n 30.\n Claimants lack knowledge sufficient to admit or deny the allegations in Paragraph\n 30.\n\n 31.\n Claimants lack knowledge sufficient to admit or deny the allegations in Paragraph\n 31.\n\n c. The Brooklyn Network\n 32.\n Claimants lack knowledge sufficient to admit or deny the allegations in Paragraph\n 32.\n\n 33.\n Claimants lack knowledge sufficient to admit or deny the allegations in Paragraph\n 33.\n\n 34.\n Claimants lack knowledge sufficient to admit or deny the allegations in Paragraph\n 34.\n\n 35.\n Claimants lack knowledge sufficient to admit or deny the allegations in Paragraph\n 35.\n\n 36.\n Claimants lack knowledge sufficient to admit or deny the allegations in Paragraph\n 36.\n\n 37. Claimants lack knowledge sufficient to admit or deny the allegations in Paragraph\n\n 37 and Footnote 2.\n\fCase 1:25-cv-05745-RPK-CHK Document 499-5 Filed 08/10/26 Page 7 of 16 PageID\n #: 13078\n\n\n\n iii. The Money Laundering Schemes\n\n 38. Claimants lack knowledge sufficient to admit or deny the allegations in Paragraph\n\n 38.\n\n 39. Claimants lack knowledge sufficient to admit or deny the allegations in Paragraph\n\n 39.\n 40. Claimants lack knowledge sufficient to admit or deny the allegations in Paragraph\n\n 40 and Footnote 3.\n\n 41. Footnote 4 purports to quote a document that speaks for itself, and no response is\n\n required. Claimants lack knowledge sufficient to admit or deny the remaining allegations in\n\n Paragraph 41.\n\n 42. Claimants admit that the Lubian mining operation produced bitcoin through\n\n cryptocurrency mining operations. Claimants lack knowledge sufficient to admit or deny the\n\n remaining allegations in Paragraph 42.\n\n\n 43. Claimants lack knowledge sufficient to admit or deny the allegations in Paragraph\n\n 43 and Footnote 5.\n\n E. The Defendants In Rem\n 44. Claimants admit that the government is seeking to forfeit Bitcoin that was stored at\n\n the twenty-five cryptocurrency addresses identified in the table following Paragraph 44. Claimants\n\n deny that the table following Paragraph 44 describing the twenty-five cryptocurrency addresses as\n\n \u201cChen Wallets\u201d is accurate, to the extent the term \u201cChen Wallets\u201d implies that all of the Defendant\n\n Property belonged to Mr. Chen at the time of the government\u2019s seizure. Mr. Chen assigned his\n\n ownership interests in the twenty-five cryptocurrency addresses identified in the table following\n\fCase 1:25-cv-05745-RPK-CHK Document 499-5 Filed 08/10/26 Page 8 of 16 PageID\n #: 13079\n\n Paragraph 44 to Tiger Mines on or about September 18, 2024. Claimants lack knowledge\n\n sufficient to admit or deny the remaining allegations in Paragraph 44 and Footnotes 6 and 7.\n\n 45. Claimants lack knowledge sufficient to admit or deny the allegations in Paragraph\n\n 45 and Footnote 8.\n\n 46. Claimants lack knowledge sufficient to admit or deny the allegations in Paragraph\n\n 46 and the following table.\n\n 47. Claimants lack knowledge sufficient to admit or deny the allegations in Paragraph\n\n 47 and Footnote 9, including subsections (a) through (m).\n\n\n 48. Claimants lack knowledge sufficient to admit or deny the allegations in Paragraph\n 48.\n\n 49.\n Claimants lack knowledge sufficient to admit or deny the allegations in Paragraph\n 49.\n\n 50.\n Claimants lack knowledge sufficient to admit or deny the allegations in Paragraph\n 50.\n\n 51.\n Claimants lack knowledge sufficient to admit or deny the allegations in Paragraph\n 51.\n\n 52.\n Claimants lack knowledge sufficient to admit or deny the allegations in Paragraph\n 52.\n\n 53.\n Claimants lack knowledge sufficient to admit or deny the allegations in Paragraph\n 53.\n\n 54.\n Claimants lack knowledge sufficient to admit or deny the allegations in Paragraph\n 54.\n\fCase 1:25-cv-05745-RPK-CHK Document 499-5 Filed 08/10/26 Page 9 of 16 PageID\n #: 13080\n\n Case 1:25-cv-05745-RPK Document 103 Filed 01/21/26 Page 2 of 4 PageID #: 2606\n\n\n\n\n UNITED STATES DISTRICT COURT\n EASTERN DISTRICT OF NEW YORK\n\n 55. Claimants lack knowledge sufficient to admit or deny the allegations in Paragraph\n\n 55, including subsections (a) through (g).\n 56. Claimants lack knowledge sufficient to admit or deny the allegations in Paragraph\n\n 56.\n\n\n 57. Claimants lack knowledge sufficient to admit or deny the allegations in Paragraph\n\n 57.\n\n 58. Claimants lack knowledge sufficient to admit or deny the allegations in Paragraph\n\n 58.\n\n F. Criminal and Regulatory Actions\n\n 59. Claimants admit that the indictment charging Mr. Chen was unsealed on October\n\n 14, 2025. Claimants further admit that, on October 14, 2025 as well, the Prince Group\n\n Transnational Criminal Organization was designated by the United States of America,\n Plaintiff,Department of\n\n\n v.\n ANSWER OF CLAIMANT HASSAN MIAH\n Case No. 1:25-cv-05745 (RPK)\n\n\n Approximately 127,271 Bitcoin,\n Defendant in Rem.\n\n\n ANSWER OF CLAIMANT HASSAN MIAH\n Claimant Hassan Miah, appearing pro se, respectfully submits this Answer to the\n Verified Complaint for Forfeiture In Rem.\n\n Treasury\u2019s Office of Foreign Assets Control (\u201cOFAC\u201d) and Prince Holding Group and many of\n\n its affiliates were placed on the Specially Designated Nationals and Blocked Persons List.\n\fCase 1:25-cv-05745-RPK-CHK Document 499-5 Filed 08/10/26 Page 10 of 16 PageID\n #: 13081\n\n\n\n Claimants lack knowledge sufficient to admit or deny the remaining allegations in Paragraph 59.\n\n FIRST CLAIM FOR RELIEF\n (Proceeds Traceable to Wire Fraud)\n\n 60. Claimants incorporate and reallege each and every response to Paragraphs 1\n\n through 59 set forth above as though set forth in full here.\n\n 61. Paragraph 61 contains legal conclusions to which no response is required. To the\n\n extent a response is required, Claimants deny that any of the allegations in Paragraph 61 confer on\n\n 1. Claimant admits only that the United States has filed a civil forfeiture action in this\n matter.any right, title, or interest in the Defendant Property that is superior to the right,\n 2. Claimant denies the remaining allegations in the Complaint or states that he lacks\n sufficient knowledge or information to form a belief as to their truth and therefore\n denies them.\n\n Claimant has previously filed a Verified Claim asserting histitle, or interest of Claimants in the\n Defendant Property.\n Claimant reserves all rights to amend or supplement this Answer as permitted by\n the Federal Rules of Civil Procedure and Supplemental Rule G.\n\n\n Dated: January 21, 2026\n Respectfully submitted,\n\n\n\n\n Hassan Miah\n\fCase 1:25-cv-05745-RPK-CHK Document 499-5 Filed 08/10/26 Page 11 of 16 PageID\n #: 13082\n\n\n\n 62. Paragraph 62 contains legal conclusions to which no response is required. To the\n\n extent a response is required, Claimants deny that any of the allegations in Paragraph 62 confer on\n\n the United States any right, title, or interest in the Defendant Property that is superior to the right,\n\n title, or interest of Claimants in the Defendant Property.\n\n SECOND CLAIM FOR RELIEF\n (Property Involved in Money Laundering)\n\n 63. Claimants incorporate and reallege each and every response to Paragraphs 1\n\n through 62 set forth above as though set forth in full here.\n\n 64. Paragraph 64 contains legal conclusions to which no response is required. To the\n\n extent a response is required, Claimants deny that any of the allegations in Paragraph 64 confer on\n\n the United States any right, title, or interest in the Defendant Property that is superior to the right,\n\n title, or interest of Claimants in the Defendant Property.\n\n 65. Paragraph 65 contains legal conclusions to which no response is required. To the\n\n extent a response is required, Claimants deny that any of the allegations in Paragraph 65 confer on\n\n the United States any right, title, or interest in the Defendant Property that is superior to the right,\n\n title, or interest of Claimants in the Defendant Property.\n\n AFFIRMATIVE DEFENSES\n\n The defenses asserted herein are based on Claimants\u2019 knowledge, information, and belief\n\n at this time. Claimants specifically reserve the right to assert additional affirmative defenses and\n\n other defenses and/or modify, amend, or supplement any defense contained herein at any time.\n\n Without admitting any of the facts alleged in the Complaint except as specifically set forth above,\n\n and without assuming any burden of proof, persuasion, or production not otherwise legally\n\fCase 1:25-cv-05745-RPK-CHK Document 499-5 Filed 08/10/26 Page 12 of 16 PageID\n #: 13083\n\n assigned to them as to any element of the government\u2019s claims, Claimants assert the following\n\n affirmative and other defenses:\n\n 1. Tiger Mines possesses a legal and beneficial ownership interest in the Defendant\n\n Property by virtue of the assignment from Mr. Chen made on or about September 18, 2024, for\n\n value\u2014namely, in exchange for the relinquishment of a damages claim that Tiger Mines held\n\n against Tether Holdings in the amount of at least $50 million. Mr. Miah, as the sole owner of\n\n Tiger Mines, holds his interest in the Defendant Property through Tiger Mines.\n\n 2. Tiger Mines is an \u201cinnocent owner\u201d of the Defendant Property within the meaning\n\n of 18 U.S.C. \u00a7 983(d), and specifically, a bona fide purchaser for value under 18 U.S.C. \u00a7\n\n 983(d)(3). Tiger Mines acquired its interest in the Defendant Property through the September\n\n 2024 assignment\u2014after the conduct alleged to give rise to forfeiture\u2014and did not know, and was\n\n reasonably without cause to believe, that the property was subject to forfeiture. Specifically, at\n\n the time of the assignment: (a) neither Tiger Mines nor Mr. Miah had any knowledge or reason to\n\n believe that Mr. Chen or any associated person or entity was the subject of any United States\n\n criminal investigation, indictment, or civil forfeiture action; (b) Mr. Miah, who has years of\n\n industry-specific knowledge from working with digital asset companies, had conducted his own\n\n due diligence into the property at issue, which included an analysis that \u201cdid not uncover any\n\n involvement with illegal or high-risk operators,\u201d such that he had no reason to believe that the\n\n property provided to him was connected to criminal activity; and (c) the Indictment, the civil\n\n forfeiture Verified Complaint, and the OFAC designation were not issued until October 2025,\n\n more than a year after the assignment.\n\n 3. Tiger Mines is a bona fide purchaser for value of the Defendant Property under 18\n\n U.S.C. \u00a7 983(d)(3). It acquired its interest in a good-faith transaction, in exchange for substantial\n\fCase 1:25-cv-05745-RPK-CHK Document 499-5 Filed 08/10/26 Page 13 of 16 PageID\n #: 13084\n\n and legitimate consideration as described above, and without knowledge or reason to believe that\n\n the property was subject to forfeiture. Accordingly, Tiger Mines\u2019 interest as a bona fide purchaser\n\n for value is superior to any interest the United States may have in the Defendant Property.\n\n 4. Upon information and belief, the Defendant Property lacks a sufficient nexus to the\n\n alleged criminal activity to support forfeiture. The Verified Complaint alleges that the addresses\n\n comprising the Defendant Property were primarily funded by two categories of sources:\n\n cryptocurrency mining\u2014including mining attributable to the Lubian and Warp Data mining\n\n operations\u2014and indirect transfers from cryptocurrency exchanges (see \u00b6 45). To the extent the\n\n Defendant Property, or any portion thereof, constitutes newly mined Bitcoin generated through the\n\n Lubian mining operation or any other cryptocurrency mining operation, such Bitcoin is not\n\n \u201cproceeds traceable to\u201d wire fraud under 18 U.S.C. \u00a7 981(a)(1)(C), nor is it \u201cproperty involved in\u201d\n\n a money laundering transaction under 18 U.S.C. \u00a7 981(a)(1)(A), nor is there a \u201csubstantial\n\n connection\u201d between the Defendant Property and any money laundering transaction as is required\n\n by 18 U.S.C. \u00a7 983(c)(3), because the mining of new Bitcoin through computational processes is an\n\n independent economic activity that does not constitute, derive from, or connect to the specified\n\n unlawful activity alleged in the Verified Complaint.\n\n 5. The forfeiture of the Defendant Property in which Claimants hold an interest would\n\n violate the Excessive Fines Clause of the Eighth Amendment to the United States Constitution.\n\n Neither Tiger Mines nor Mr. Miah is alleged to have participated in or to have had knowledge of\n\n the criminal activity described in the Verified Complaint. Forfeiting the property of a bona fide\n\n purchaser for value that acquired its interest without knowledge of the underlying criminal activity,\n\n and that is not alleged to have engaged in any wrongdoing, would be grossly disproportional to any\n\n offense and would constitute an excessive fine within the meaning of the Eighth Amendment.\n\fCase 1:25-cv-05745-RPK-CHK Document 499-5 Filed 08/10/26 Page 14 of 16 PageID\n #: 13085\n\n\n\n 6. The causes of action alleged in the Verified Complaint are barred by the relevant\n\n statutes of limitations.\n 7. Claimants deny all allegations not expressly admitted herein and specifically\n\n reserve the right to amend this Answer, to raise additional defenses, cross-claims, and third-party\n\n claims not asserted herein as may be warranted by the revelation of information during further\n\n proceedings, and to pursue alternative remedies under civil forfeiture law.\n\n\n 8. Claimants incorporate by reference any defense that any other claimant pleads in\n\n this action, to the extent the defense applies to any claims against the Defendant Property, in whole\n\n or in part, and is otherwise consistent with this Answer.\n\n PRAYER FOR RELIEF\n\n WHEREFORE, Claimants respectfully request that the Court:\n\n 1. Enter judgment in favor of Claimants and against Plaintiff.\n\n 2. Declare that Tiger Mines is the lawful owner of the Defendant Property by virtue\n of the September 2024 assignment from Mr. Chen, and that Mr. Miah holds his interest therein\n\n through Tiger Mines.\n\n 3. Declare that Tiger Mines is an innocent owner of the Defendant Property within the\n\n meaning of 18 U.S.C. \u00a7 983(d).\n\n 4. Order that the Defendant Property be released from Plaintiff\u2019s custody and returned\n\n to Tiger Mines.\n\n 5. Order that the Defendant Property be preserved and maintained subject to the\n\n Court\u2019s jurisdiction, and that no distribution or disposition occur unless and until Claimants\u2019\n\n asserted ownership rights are adjudicated.\n\n\n 6. Award Claimants their attorneys\u2019 fees and the costs of suit.\n\fCase 1:25-cv-05745-RPK-CHK Document 499-5 Filed 08/10/26 Page 15 of 16 PageID\n #: 13086\n\n\n Case 1:25-cv-05745-RPK Document 103 Filed 01/21/26 Page 3 of 4 PageID #: 2607\n\n\n\n\n 1080 Old Country Road, Suite 1042\n 7. Grant Claimants such other and further relief as the Court deems just and proper.\n\n\n\n\n Dated: August 10, 2026 Respectfully submitted,\n\n\n /s/ Samson A. Enzer\n Samson A. Enzer\n Kiersten A. Fletcher\n CAHILL GORDON & REINDEL LLP\n 32 Old Slip\n WestburyNew York, NY\n 1159010005\n 917-545-0137Telephone:\n 212-701-3125\n hmiah@brookvillellc SEnzer@cahill.\n com\n\n Pro Se\n KFletcher@cahill.com\n\n Attorneys for Claimants Hassan\n Miah and Tiger Mines New York Inc.\n\fCase 1:25-cv-05745-RPK-CHK Document 499-5 Filed 08/10/26 Page 16 of 16 PageID\n #: 13087\n\n\n\n\n Summary report:\n Litera Compare for Word 11.9.0.82 Document comparison done on\n 8/10/2026 3:20:46 PM\n Style name: Cahill Default\n Intelligent Table Comparison: Active\n Original filename:\n US_DIS_NYED_1_25cv5745_d16584330e65685_Answer_of_Claimant_Hassan\n _Miah_filed_by_Hassan_Mia.pdf\n Modified filename: 4 - Amended Answer.pdf\n Changes:\n Add 186\n Delete 30\n Move From 2\n Move To 2\n Table Insert 4\n Table Delete 0\n Table moves to 0\n Table moves from 0\n Embedded Graphics (Visio, ChemDraw, Images etc.) 1\n Embedded Excel 0\n Format changes 0\n Total Changes: 225\n\f","ocr_status":1,"date_upload":"2026-08-10T16:40:42.291460-07:00","document_number":"499","attachment_number":5,"pacer_doc_id":"123024061616","is_available":true,"is_free_on_pacer":null,"is_sealed":false,"document_type":2,"description":"Answer - Redline","acms_document_guid":""},{"resource_uri":"https://www.courtlistener.com/api/rest/v4/recap-documents/489427143/","id":489427143,"tags":[],"absolute_url":"/docket/71639393/499/6/united-states-v-approximately-127271-bitcoin-btc-previously-stored-at/","date_created":"2026-08-10T16:40:11.555255-07:00","date_modified":"2026-08-22T19:25:55.465152-07:00","sha1":"f2e24c7620f630350bdbe730b9fee5a623bf769a","page_count":2,"file_size":11103,"filepath_local":"recap/gov.uscourts.nyed.537552/gov.uscourts.nyed.537552.499.6.pdf","filepath_ia":"https://archive.org/download/gov.uscourts.nyed.537552/gov.uscourts.nyed.537552.499.6.pdf","ia_upload_failure_count":null,"thumbnail":null,"thumbnail_status":0,"plain_text":"Case 1:25-cv-05745-RPK-CHK Document 499-6 Filed 08/10/26 Page 1 of 2 PageID\n #: 13088\n\n\n\n UNITED STATES DISTRICT COURT\n FOR THE EASTERN DISTRICT OF NEW YORK\n\n\n UNITED STATES OF AMERICA,\n\n Plaintiff,\n\n v.\n\n APPROXIMATELY 127,271 BITCOIN (BTC) 1:25-cv-05745 (RPK) (CHK)\n PREVIOUSLY STORED AT THE VIRTUAL\n CURRENCY ADDRESSES LISTED IN\n ATTACHMENT A, AND ALL PROCEEDS\n TRACEABLE THERETO,\n\n Defendants In Rem.\n\n\n\n [PROPOSED] ORDER\n\n Upon consideration of the pre-motion letter of Claimants Tiger Mines New York Inc. and\n\n Hassan Miah seeking (1) nunc pro tunc acceptance of Mr. Miah\u2019s original pro se Verified Claim\n\n and Answer and (2) leave to file an Amended Verified Claim and Amended Answer, the supporting\n\n Declaration of Hassan Miah, the proposed Amended Verified Claim and Amended Answer, the\n\n other enclosures thereto, and the entire record in this action; the Court having elected, pursuant to\n\n Rule IV.A.5 of its Individual Practice Rules, to construe the pre-motion letter and its enclosures\n\n as the motion itself; and good cause and excusable neglect appearing under Supplemental Rule\n\n G(5)(a)(ii) and Federal Rule of Civil Procedure 6(b)(1)(B):\n\n IT IS HEREBY ORDERED that the Motion is GRANTED;\n\n IT IS FURTHER ORDERED that, for good cause and excusable neglect shown under\n\n Supplemental Rule G(5)(a)(ii) and Federal Rule of Civil Procedure 6(b)(1)(B), Mr. Miah\u2019s original\n\fCase 1:25-cv-05745-RPK-CHK Document 499-6 Filed 08/10/26 Page 2 of 2 PageID\n #: 13089\n\n\n\n pro se Verified Claim (ECF No. 84) is accepted nunc pro tunc as of January 19, 2026, and his\n\n original pro se Answer (ECF No. 103) is accepted nunc pro tunc as of January 21, 2026;\n\n IT IS FURTHER ORDERED that Claimants are granted leave under Federal Rule of Civil\n\n Procedure 15(a)(2) to file the Amended Verified Claim enclosed with their pre-motion letter,\n\n which relates back under Federal Rule of Civil Procedure 15(c) to the date of Mr. Miah\u2019s original\n\n pro se Verified Claim (ECF No. 84) filed January 19, 2026;\n\n IT IS FURTHER ORDERED that Claimants are granted leave under Federal Rule of Civil\n\n Procedure 15(a)(2) to file the Amended Answer enclosed with their pre-motion letter, which\n\n relates back under Federal Rule of Civil Procedure 15(c) to the date of Mr. Miah\u2019s original pro se\n\n Answer (ECF No. 103) filed January 21, 2026;\n\n IT IS FURTHER ORDERED that the Amended Verified Claim and Amended Answer\n\n shall be the operative pleadings in this action, and the original pro se Verified Claim (ECF No. 84)\n\n and original pro se Answer (ECF No. 103) shall remain of record as the filings to which the\n\n amended pleadings relate back;\n\n IT IS FURTHER ORDERED that Mr. Miah\u2019s pending pro se Letter Motion for Extension\n\n of Time Nunc Pro Tunc (ECF No. 84) is GRANTED to the extent set forth herein and is otherwise\n\n DENIED as moot.\n\n\n\n SIGNED this _____ day of __________ 2026.\n\n\n ___________________________\n RACHEL P. KOVNER\n UNITED STATES DISTRICT JUDGE\n\f","ocr_status":2,"date_upload":"2026-08-10T16:40:44.211023-07:00","document_number":"499","attachment_number":6,"pacer_doc_id":"123024061617","is_available":true,"is_free_on_pacer":null,"is_sealed":false,"document_type":2,"description":"Proposed Order","acms_document_guid":""}],"date_created":"2026-08-10T16:40:08.905552-07:00","date_modified":"2026-08-17T18:27:38.918722-07:00","date_filed":"2026-08-10","time_filed":"19:39:14","entry_number":499,"recap_sequence_number":"2026-08-10.003","pacer_sequence_number":3430,"description":"Letter MOTION for pre motion conference re 84 MOTION for Extension of Time to File Verfied Claim pursuant to Supplemental Rule G(5)(a)(ii) and Federal Rule of Civil Procedure 6(b)(1)(B), filed, 103 Notice (Other) by Hassan Miah, Tiger Mines New York Inc.. (Attachments: # 1 Declaration of Hassan Miah, # 2 Amended Verified Claim, # 3 Verified Claim - Redline, # 4 Amended Answer, # 5 Answer - Redline, # 6 Proposed Order) (Enzer, Samson) (Entered: 08/10/2026)","tags":[]},{"resource_uri":"https://www.courtlistener.com/api/rest/v4/docket-entries/473939116/","id":473939116,"docket":"https://www.courtlistener.com/api/rest/v4/dockets/71639393/","recap_documents":[{"resource_uri":"https://www.courtlistener.com/api/rest/v4/recap-documents/489423963/","id":489423963,"tags":[],"absolute_url":"/docket/71639393/498/united-states-v-approximately-127271-bitcoin-btc-previously-stored-at/","date_created":"2026-08-10T16:17:43.278621-07:00","date_modified":"2026-08-22T09:47:01.790248-07:00","sha1":"5e405128b9120579b55a61e29ff679d555bc18be","page_count":1,"file_size":383859,"filepath_local":"recap/gov.uscourts.nyed.537552/gov.uscourts.nyed.537552.498.0.pdf","filepath_ia":"https://archive.org/download/gov.uscourts.nyed.537552/gov.uscourts.nyed.537552.498.0.pdf","ia_upload_failure_count":null,"thumbnail":null,"thumbnail_status":0,"plain_text":" Case 1:25-cv-05745-RPK-CHK Document 498 Filed 08/10/26 Page 1 of 1 PageID #:\n 13020\nAO 458 (Rev. 06/09) Appearance of Counsel\n\n\n UNITED STATES DISTRICT COURT\n for the\n Eastern District\n __________ of of\n District New York\n __________\n\n\n United States of America )\n Plaintiff )\n v. ) Case No. 25-cv-05745-RPK-CHK\n Approximately 127,271 bitcoin (BTC) )\n Defendant )\n\n APPEARANCE OF COUNSEL\n\nTo: The clerk of court and all parties of record\n\n I am admitted or otherwise authorized to practice in this court, and I appear in this case as counsel for:\n\n Tiger Mines New York Inc. .\n\n\nDate: 08/10/2026 /s/ Kiersten A. Fletcher\n Attorney\u2019s signature\n\n\n Kiersten A. Fletcher 4881256\n Printed name and bar number\n\n Cahill Gordon & Reindel LLP\n 32 Old Slip\n New York, NY 10005\n Address\n\n KFletcher@cahill.com\n E-mail address\n\n (212) 701-3365\n Telephone number\n\n (212) 269-5420\n FAX number\n\f","ocr_status":2,"date_upload":"2026-08-10T16:17:43.487671-07:00","document_number":"498","attachment_number":null,"pacer_doc_id":"123024061545","is_available":true,"is_free_on_pacer":null,"is_sealed":false,"document_type":1,"description":"Notice of Appearance","acms_document_guid":""}],"date_created":"2026-08-10T16:17:43.237114-07:00","date_modified":"2026-08-17T18:27:38.906859-07:00","date_filed":"2026-08-10","time_filed":"19:16:37","entry_number":498,"recap_sequence_number":"2026-08-10.002","pacer_sequence_number":3427,"description":"NOTICE of Appearance by Kiersten Ann Fletcher on behalf of Tiger Mines New York Inc. (aty to be noticed) (Fletcher, Kiersten) (Entered: 08/10/2026)","tags":[]},{"resource_uri":"https://www.courtlistener.com/api/rest/v4/docket-entries/473939110/","id":473939110,"docket":"https://www.courtlistener.com/api/rest/v4/dockets/71639393/","recap_documents":[{"resource_uri":"https://www.courtlistener.com/api/rest/v4/recap-documents/489423948/","id":489423948,"tags":[],"absolute_url":"/docket/71639393/497/united-states-v-approximately-127271-bitcoin-btc-previously-stored-at/","date_created":"2026-08-10T16:16:10.244174-07:00","date_modified":"2026-08-22T09:51:03.766556-07:00","sha1":"ccac18afabbe5269956d3a854aed73d49113223e","page_count":1,"file_size":384720,"filepath_local":"recap/gov.uscourts.nyed.537552/gov.uscourts.nyed.537552.497.0.pdf","filepath_ia":"https://archive.org/download/gov.uscourts.nyed.537552/gov.uscourts.nyed.537552.497.0.pdf","ia_upload_failure_count":null,"thumbnail":null,"thumbnail_status":0,"plain_text":" Case 1:25-cv-05745-RPK-CHK Document 497 Filed 08/10/26 Page 1 of 1 PageID #:\n 13019\nAO 458 (Rev. 06/09) Appearance of Counsel\n\n\n UNITED STATES DISTRICT COURT\n for the\n Eastern District\n __________ of of\n District New York\n __________\n\n\n United States of America )\n Plaintiff )\n v. ) Case No. 25-cv-05745-RPK-CHK\n Approximately 127,271 bitcoin (BTC) )\n Defendant )\n\n APPEARANCE OF COUNSEL\n\nTo: The clerk of court and all parties of record\n\n I am admitted or otherwise authorized to practice in this court, and I appear in this case as counsel for:\n\n Tiger Mines New York Inc. .\n\n\nDate: 08/10/2026 /s/ Samson A. Enzer\n Attorney\u2019s signature\n\n\n Samson A. Enzer 4625828\n Printed name and bar number\n\n Cahill Gordon & Reindel LLP\n 32 Old Slip\n New York, NY 10005\n Address\n\n SEnzer@cahill.com\n E-mail address\n\n (212) 701-3125\n Telephone number\n\n (212) 269-5420\n FAX number\n\f","ocr_status":2,"date_upload":"2026-08-10T16:16:10.725686-07:00","document_number":"497","attachment_number":null,"pacer_doc_id":"123024061532","is_available":true,"is_free_on_pacer":null,"is_sealed":false,"document_type":1,"description":"Notice of Appearance","acms_document_guid":""}],"date_created":"2026-08-10T16:16:10.203263-07:00","date_modified":"2026-08-17T18:27:38.890540-07:00","date_filed":"2026-08-10","time_filed":"19:14:54","entry_number":497,"recap_sequence_number":"2026-08-10.001","pacer_sequence_number":3423,"description":"NOTICE of Appearance by Samson Enzer on behalf of Tiger Mines New York Inc. (aty to be noticed) (Enzer, Samson) (Entered: 08/10/2026)","tags":[]},{"resource_uri":"https://www.courtlistener.com/api/rest/v4/docket-entries/472870759/","id":472870759,"docket":"https://www.courtlistener.com/api/rest/v4/dockets/71639393/","recap_documents":[{"resource_uri":"https://www.courtlistener.com/api/rest/v4/recap-documents/488317174/","id":488317174,"tags":[],"absolute_url":"/docket/71639393/496/united-states-v-approximately-127271-bitcoin-btc-previously-stored-at/","date_created":"2026-07-31T13:25:43.498333-07:00","date_modified":"2026-08-14T21:38:12.270773-07:00","sha1":"ff327e8b0367c62a395d6c893c242dab9bac3283","page_count":2,"file_size":144196,"filepath_local":"recap/gov.uscourts.nyed.537552/gov.uscourts.nyed.537552.496.0.pdf","filepath_ia":"https://archive.org/download/gov.uscourts.nyed.537552/gov.uscourts.nyed.537552.496.0.pdf","ia_upload_failure_count":null,"thumbnail":null,"thumbnail_status":0,"plain_text":"Case 1:25-cv-05745-RPK-CHK Document 496 Filed 07/31/26 Page 1 of 2 PageID #:\n 13017\n\n\n\n IN THE UNITED STATES DISTRICT COURT\n EASTERN DISTRICT OF NEW YORK\n\n\n\n UNITED STATES OF AMERICA, et al.,\n\n Plaintiff,\n\n v.\n\n APPROXIMATELY 127,271 BITCOIN Civil Action No. 1:25-cv-05745 (RPK)\n (\u201cBTC\u201d) PREVIOUSLY STORED AT THE\n VIRTUAL CURRENCY ADDRESSES\n LISTED IN ATTACHMENT A, AND ALL\n PROCEEDS TRACEABLE THERETO,\n\n Defendant In Rem\n\n\n\n NOTICE OF APPEARANCE OF COUNSEL\n\n PLEASE TAKE NOTICE that I, John R. Fabry, hereby respectfully enter my appearance\n\n in the above-captioned matter on behalf of certain of the Owens Victims referenced in ECF 491,\n\n the Notice of Verified Claim and Statement of Interest or Right in Property Subject to Forfeiture\n\n In Rem filed July 27, 2026 (Notice). Specifically, I am entering my appearance for the Plaintiffs in\n\n Taitt v. Islamic Republic of Iran, 1:20-cv-01557 and in Gunn v. Islamic Republic of Iran, 1:21-cv-\n\n 01187, listed in Attachment A to the Notice. See ECF 491-2, PageID Nos. 12975 \u2013 12980. I certify\n\n that I am admitted to practice before this Court. All future pleadings, motions, and other papers\n\n filed or served in this action should be served at the address identified below.\n\n Dated: July 30, 2026 Respectfully submitted,\n\n /s/ John R. Fabry\n John R. Fabry (No. 6410180)\n The Carlson Law Firm P.C.\n 559 S. IH-35, Ste. 250\n Round Rock, TX 78664\n JFabry@carlsonattorneys.com\n Phone: (512) 671-7277\n\fCase 1:25-cv-05745-RPK-CHK Document 496 Filed 07/31/26 Page 2 of 2 PageID #:\n 13018\n\n\n\n Fax: (512) 238-0275\n\n Attorney for Taitt and Gunn Claimants\n\n\n\n\n 2\n\f","ocr_status":1,"date_upload":"2026-07-31T13:25:43.706508-07:00","document_number":"496","attachment_number":null,"pacer_doc_id":"123024032319","is_available":true,"is_free_on_pacer":null,"is_sealed":false,"document_type":1,"description":"Notice of Appearance","acms_document_guid":""}],"date_created":"2026-07-31T13:25:43.466374-07:00","date_modified":"2026-08-07T07:34:46.909760-07:00","date_filed":"2026-07-31","time_filed":"16:20:50","entry_number":496,"recap_sequence_number":"2026-07-31.004","pacer_sequence_number":3415,"description":"NOTICE of Appearance by John R. Fabry on behalf of Sean Taitt, Mona Gunn (aty to be noticed) (Fabry, John) (Entered: 07/31/2026)","tags":[]},{"resource_uri":"https://www.courtlistener.com/api/rest/v4/docket-entries/472861934/","id":472861934,"docket":"https://www.courtlistener.com/api/rest/v4/dockets/71639393/","recap_documents":[{"resource_uri":"https://www.courtlistener.com/api/rest/v4/recap-documents/488308110/","id":488308110,"tags":[],"absolute_url":"/docket/71639393/494/united-states-v-approximately-127271-bitcoin-btc-previously-stored-at/","date_created":"2026-07-31T12:51:07.987126-07:00","date_modified":"2026-07-31T13:07:14.121697-07:00","sha1":"","page_count":null,"file_size":null,"filepath_local":null,"filepath_ia":"","ia_upload_failure_count":null,"thumbnail":null,"thumbnail_status":0,"plain_text":"","ocr_status":null,"date_upload":null,"document_number":"494","attachment_number":null,"pacer_doc_id":"123024031951","is_available":false,"is_free_on_pacer":null,"is_sealed":null,"document_type":1,"description":"Notice(Other)","acms_document_guid":""}],"date_created":"2026-07-31T12:51:07.968584-07:00","date_modified":"2026-08-07T07:34:46.879157-07:00","date_filed":"2026-07-31","time_filed":"15:44:20","entry_number":494,"recap_sequence_number":"2026-07-31.002","pacer_sequence_number":3410,"description":"NOTICE by ONeill Claimants re 69 Notice(Other) of Supplemental Verified Claim and Statement of Interest or Right in Property Subject to Forfeiture in Rem (Goldman, Jerry) (Entered: 07/31/2026)","tags":[]},{"resource_uri":"https://www.courtlistener.com/api/rest/v4/docket-entries/472861912/","id":472861912,"docket":"https://www.courtlistener.com/api/rest/v4/dockets/71639393/","recap_documents":[{"resource_uri":"https://www.courtlistener.com/api/rest/v4/recap-documents/488308088/","id":488308088,"tags":[],"absolute_url":"/docket/71639393/495/united-states-v-approximately-127271-bitcoin-btc-previously-stored-at/","date_created":"2026-07-31T12:51:05.543384-07:00","date_modified":"2026-09-09T16:04:03.493300-07:00","sha1":"230c968963144ccad3e07379a8baf2ee61a7d822","page_count":3,"file_size":513632,"filepath_local":"recap/gov.uscourts.nyed.537552/gov.uscourts.nyed.537552.495.0.pdf","filepath_ia":"","ia_upload_failure_count":2,"thumbnail":null,"thumbnail_status":0,"plain_text":"Case 1:25-cv-05745-RPK-CHK Document 495 Filed 07/31/26 Page 1 of 3 PageID #:\n 13013\n\n\n\n UNITED STATES DISTRICT COURT\n EASTERN DISTRICT OF NEW YORK\n\n\n UNITED STATES OF AMERICA,\n\n Plaintiff,\n\n v. Civil Action No. 1:25-cv-05745\n APPROXIMATELY 127,271 BITCOIN (\u201cBTC\u201d) (RPK)\n PREVIOUSLY STORED AT THE VIRTUAL\n CURRENCY ADDRESSES LISTED IN ATTACHMENT\n A, AND ALL PROCEEDS TRACEABLE THERETO,\n\n Defendant, In Rem.\n\n VERIFICATION OF THE ADDITIONAL O\u2019NEILL CLAIMANTS\u2019 CLAIMS\n\n JERRY S. GOLDMAN, Esq., an attorney duly licensed to practice law before the Courts\n\n of the State of New York and this Court, declares under penalties of perjury pursuant to 28 U.S.C.\n\n \u00a7 1746 as follows:\n\n 1. I am a shareholder of the law firm Anderson Kill P.C., 7 Times Square, 15th Floor,\n\n New York, NY 10036.\n\n 2. All statements in this verification are within my personal knowledge and reflected\n\n in the official dockets of this court and the United States District Court for the Southern District\n\n of New York.\n\n 3. I make this declaration on behalf of the Additional O\u2019Neill Claimants, as identified\n\n on annexed Exhibit 1.\n\n 4. This Verified Claim supplements and relates back to the Verified Claim and\n\n associated documents submitted by the O\u2019Neill Claimants. See ECF Nos. 66, 69-70 (original claim\n\n asserted by the O\u2019Neill Claimants); see also ECF Nos. 160, 162-63 (9/11 Claimants\u2019 Amended\n\n Claim); see also ECF Nos. 258, 259-260 (O\u2019Neill Claimants\u2019 Supplemental Claim).\n\n\n\n DOCS-100917791.2\n\fCase 1:25-cv-05745-RPK-CHK Document 495 Filed 07/31/26 Page 2 of 3 PageID #:\n 13014\n\n\n\n 5. I represent the O\u2019Neill Claimants and the Additional O\u2019Neill Claimants in this\n\n action, and in actions consolidated into the multidistrict litigation, In re Terrorist Attacks on\n\n September 11, 2001, No. 03-MDL-1570 (GBD)(SN)(S.D.N.Y.) (the \u201c9/11 MDL\u201d).\n\n 6. On June 1, 2026, the Additional O\u2019Neill Claimants were awarded compensatory\n\n damages judgments totaling $120,750,000.00, exclusive of interest, under 28 U.S.C. \u00a7 1605A\n\n against the Islamic Republic of Iran (\u201cIran\u201d) for its role in sponsoring the 9/11 Attacks.\n\n 7. Attached hereto as Exhibit 1 is a verified list of the Additional O\u2019Neill Claimants,\n\n the amount of compensatory damages awarded to such claimant, and the date and ECF No. of such\n\n judgment.\n\n 8. The compensatory damages judgments identified in annexed Exhibit 1 are in the\n\n process of being served on Iran.\n\n 9. As detailed in a related action pending in this Court, entitled Fritz v. Iran & China\n\n Investment Development Group, No. 1:2025-cv-07093 (E.D.N.Y.) (the \u201cFritz Action\u201d), the\n\n 127,271 Bitcoin that constitute the Defendant Cryptocurrency in the instant action belong to the\n\n Iran and China Investment Development Group (\u201cIran-China Group\u201d), doing business as\n\n Lubian.com or LuBian. See Fritz Action, ECF No. 70. The Iran-China Group is an agency or\n\n instrumentality of Iran. Accordingly, its assets are blocked by operation of U.S. law. See Executive\n\n Order No. 13599, 77 Fed. Reg. 6659, 6659 (Feb. 5, 2012).\n\n 10. To preserve the Additional O\u2019Neill Claimants\u2019 ability to pursue execution and\n\n turnover of the 127,271 Bitcoin\u2014which constitute the Defendant Cryptocurrency in this action\u2014\n\n on behalf of the Additional O\u2019Neill Claimants pursuant to N.Y. CPLR 3020(d), I hereby notice\n\n and verify the claim of the Additional O\u2019Neill Claimants against the Defendant Cryptocurrency.\n\n Because the Terrorism Risk Insurance Act (\u201cTRIA\u201d) allows victim of terrorism with judgments\n\n\n\n 2\n DOCS-100917791.2\n\fCase 1:25-cv-05745-RPK-CHK Document 495 Filed 07/31/26 Page 3 of 3 PageID #:\n 13015\n\n\n\n against state sponsors of terrorism to pursue execution and turnover against blocked assets of those\n\n terrorist states or their agents or instrumentalities\u2014including such assets that have been \u201cseized\u201d\n\n by the U.S. government\u2014\u201cnotwithstanding the any other provision of law,\u201d TRIA \u00a7 201(a), I\n\n hereby notice and verify the Additional O\u2019Neill Claimants\u2019 claim (as supplementing the O\u2019Neill\n\n Claimants\u2019 claim, and thus as part of the 9/11 Claimants\u2019 claim) superior interest in so much of\n\n the Defendant Cryptocurrency as may ultimately be necessary to satisfy the outstanding\n\n compensatory damages owed to the 9/11 Claimants on their judgments against Iran, plus pre- and\n\n post-judgment interest.\n\n I declare under penalties of perjury pursuant to 28 U.S.C. \u00a7 1746 that the foregoing is true\n\n and correct.\n\n Dated: New York, New York\n July 31, 2026\n /s/ Jerry S. Goldman\n Jerry S. Goldman, Esq.\n\n\n\n\n 3\n DOCS-100917791.2\n\f","ocr_status":2,"date_upload":"2026-08-21T07:50:13.187274-07:00","document_number":"495","attachment_number":null,"pacer_doc_id":"123024031981","is_available":true,"is_free_on_pacer":null,"is_sealed":null,"document_type":1,"description":"Claim","acms_document_guid":""},{"resource_uri":"https://www.courtlistener.com/api/rest/v4/recap-documents/488313829/","id":488313829,"tags":[],"absolute_url":"/docket/71639393/495/1/united-states-v-approximately-127271-bitcoin-btc-previously-stored-at/","date_created":"2026-07-31T13:09:07.218917-07:00","date_modified":"2026-08-21T07:49:55.453278-07:00","sha1":"b410094bf2c3ddb6b3d87ad92042689ca9d3ca37","page_count":1,"file_size":209206,"filepath_local":"recap/gov.uscourts.nyed.537552/gov.uscourts.nyed.537552.495.1.pdf","filepath_ia":"https://archive.org/download/gov.uscourts.nyed.537552/gov.uscourts.nyed.537552.495.1.pdf","ia_upload_failure_count":null,"thumbnail":null,"thumbnail_status":0,"plain_text":" Case 1:25-cv-05745-RPK-CHK Document 495-1 Filed 07/31/26 Page 1 of 1 PageID\n #: 13016\n\n Date of Iran Compensatory\n Claimant\u2019s Relationship Statutory Basis 9/11 MDL ECF\nClaimant Name 9/11 Decedent Iran Damages\n to 9/11 Decedent for Judgment No. of Judgment\n Judgment Amount Awarded\n\nZeshan Hamdani\n as Personal 12097; 12094\nRepresentative of Mohammad S. (Memorandum\n Parent (Deceased) 6/1/2026 1605A $8,500,000.00\n the Estate of Hamdani Decision and\n Mohammad Order)\nSaleem Hamdani\nJudith Knight as\n Personal 12097; 12094\nRepresentative of (Memorandum\n Frank Wisniewski Parent (Deceased) 6/1/2026 1605A $8,500,000.00\n the Estate of Decision and\n Vincent Order)\n Wisniewski\n 12097; 12094\n (Memorandum\n Lea McKenzie Molly McKenzie Child 6/1/2026 1605A $8,500,000.00\n Decision and\n Order)\n 12097; 12094\n (Memorandum\n Stacy Paolozzi Franklin Pershep PR 6/1/2026 1605A $2,000,000.00\n Decision and\n Order)\n Brian Fine, as\n 12097; 12094\n Personal\n (Memorandum\nRepresentative of Franklin Pershep Child (Deceased) 6/1/2026 1605A $8,500,000.00\n Decision and\n the Estate of\n Order)\n Sharyn Fine\n 12097; 12094\n (Memorandum\nQuawana Bowden Lacey B. Ivory Child 6/1/2026 1605A $8,500,000.00\n Decision and\n Order)\n Andrew C. Kelly\n 12097; 12094\n as the Personal\n (Memorandum\nRepresentative of Maurice Kelly Child (Deceased) 6/1/2026 1605A $8,500,000.00\n Decision and\nthe Estate of Sean\n Order)\n Kelly\n 12097; 12094\nKen Reibman, aka (Memorandum\n Chet Louie PR 6/1/2026 1605A $2,000,000.00\n Calvin Louie Decision and\n Order)\n 12097; 12094\n Pamela Bittner- (Memorandum\n Jeffrey Bittner PR 6/1/2026 1605A $2,000,000.00\n Conley Decision and\n Order)\nKenneth Lum and\n Russell Lum, as 12097; 12094\n co-Personal (Memorandum\n William Lum Parent (Deceased) 6/1/2026 1605A $8,500,000.00\nRepresentatives of Decision and\n the Estate of Order)\n Grace Lum\n 12097; 12094\n (Memorandum\n Michelle Fallon David Ruddle Sibling 6/1/2026 1605A $4,250,000.00\n Decision and\n Order)\n 12097; 12094\n (Memorandum\n David Kuo Frederick Kuo, Jr. Child 6/1/2026 1605A $8,500,000.00\n Decision and\n Order)\n 12097; 12094\n Melissa Kuo (Memorandum\n Frederick Kuo, Jr. Child 6/1/2026 1605A $8,500,000.00\n Wallace Decision and\n Order)\n 12097; 12094\n (Memorandum\nFrederick J. Kuo Frederick Kuo, Jr. Child 6/1/2026 1605A $8,500,000.00\n Decision and\n Order)\n 12097; 12094\n (Memorandum\n John McShane Terence McShane Sibling 6/1/2026 1605A $4,250,000.00\n Decision and\n Order)\n 12097; 12094\n (Memorandum\nKieran McShane Terence McShane Sibling 6/1/2026 1605A $4,250,000.00\n Decision and\n Order)\nGeorge O. Taylor\n 12097; 12094\n as Personal\n (Memorandum\nRepresentative of Hilda E. Taylor Child (Deceased) 6/1/2026 1605A $8,500,000.00\n Decision and\n the Estate of\n Order)\nDonald Stafford\n 12097; 12094\n Geraldine (Memorandum\n David Ruddle Sibling 6/1/2026 1605A $4,250,000.00\n Mechutan Decision and\n Order)\n 12097; 12094\n Patricia Ruddle (Memorandum\n David Ruddle Sibling 6/1/2026 1605A $4,250,000.00\n Gallagher Decision and\n Order)\n\f","ocr_status":2,"date_upload":"2026-07-31T13:09:09.515242-07:00","document_number":"495","attachment_number":1,"pacer_doc_id":"123024031982","is_available":true,"is_free_on_pacer":null,"is_sealed":false,"document_type":2,"description":"Exhibit 1- Supplemental Claims","acms_document_guid":""}],"date_created":"2026-07-31T12:51:05.515982-07:00","date_modified":"2026-08-07T07:34:46.895346-07:00","date_filed":"2026-07-31","time_filed":"15:47:25","entry_number":495,"recap_sequence_number":"2026-07-31.003","pacer_sequence_number":3413,"description":"CLAIM Verification of Additional O'Neill Claimants' Claims by ONeill Claimants. (Attachments: # 1 Exhibit 1- Supplemental Claims) (Goldman, Jerry) (Entered: 07/31/2026)","tags":[]},{"resource_uri":"https://www.courtlistener.com/api/rest/v4/docket-entries/472861170/","id":472861170,"docket":"https://www.courtlistener.com/api/rest/v4/dockets/71639393/","recap_documents":[{"resource_uri":"https://www.courtlistener.com/api/rest/v4/recap-documents/488307259/","id":488307259,"tags":[],"absolute_url":"/docket/71639393/493/united-states-v-approximately-127271-bitcoin-btc-previously-stored-at/","date_created":"2026-07-31T12:40:56.438577-07:00","date_modified":"2026-07-31T12:52:27.921655-07:00","sha1":"","page_count":null,"file_size":null,"filepath_local":null,"filepath_ia":"","ia_upload_failure_count":null,"thumbnail":null,"thumbnail_status":0,"plain_text":"","ocr_status":null,"date_upload":null,"document_number":"493","attachment_number":null,"pacer_doc_id":"123024031846","is_available":false,"is_free_on_pacer":null,"is_sealed":null,"document_type":1,"description":"Motion for Leave to File Document","acms_document_guid":""},{"resource_uri":"https://www.courtlistener.com/api/rest/v4/recap-documents/488308280/","id":488308280,"tags":[],"absolute_url":"/docket/71639393/493/1/united-states-v-approximately-127271-bitcoin-btc-previously-stored-at/","date_created":"2026-07-31T12:52:29.641970-07:00","date_modified":"2026-08-14T21:53:20.130768-07:00","sha1":"f642ad564a71334e48f0197fa89f6395a90310f8","page_count":8,"file_size":570619,"filepath_local":"recap/gov.uscourts.nyed.537552/gov.uscourts.nyed.537552.493.1.pdf","filepath_ia":"https://archive.org/download/gov.uscourts.nyed.537552/gov.uscourts.nyed.537552.493.1.pdf","ia_upload_failure_count":null,"thumbnail":null,"thumbnail_status":0,"plain_text":"Case 1:25-cv-05745-RPK-CHK Document 493-1 Filed 07/31/26 Page 1 of 8 PageID\n #: 12993\n\n\n\n UNITED STATES DISTRICT COURT\n EASTERN DISTRICT OF NEW YORK\n\n\n UNITED STATES OF AMERICA,\n\n Plaintiff,\n\n v. Civil Action No. 1:25-cv-05745\n APPROXIMATELY 127,271 BITCOIN (\u201cBTC\u201d) (RPK)\n PREVIOUSLY STORED AT THE VIRTUAL\n CURRENCY ADDRESSES LISTED IN ATTACHMENT\n A, AND ALL PROCEEDS TRACEABLE THERETO,\n\n Defendant, In Rem.\n\n NOTICE OF SUPPLEMENTAL VERIFIED CLAIM AND STATEMENT OF INTEREST\n OR RIGHT IN PROPERTY SUBJECT TO FORFEITURE IN REM\n\n The 9/11 Claimants1 include over 10,454 family members and estate representatives of\n\n approximately 2,303 individuals who were victims of the September 11, 2001 terrorist attacks (the\n\n \u201c9/11 Attacks\u201d), and individuals catastrophically injured in the 9/11 Attacks. The 9/11 Claimants\n\n have been awarded compensatory damages judgments under 28 U.S.C. \u00a7\u00a7 1605A and 1605B\n\n against the Islamic Republic of Iran (\u201cIran\u201d) for its role in sponsoring the 9/11 Attacks.\n\n Certain 9/11 plaintiffs represented by Anderson Kill P.C. (the \u201cAdditional O\u2019Neill\n\n Claimants\u201d) file this notice of verified claim, that supplements and relates back to the to the\n\n original Verified Claim and associated documents submitted by the O\u2019Neill Claimants.2 to include\n\n a new, recently obtained judgment. This new judgment, dated June 1, 2026, was issued in In re\n\n Terrorist Attacks on September 11, 2001, No. 03-MDL-1570 (GBD)(SN) (S.D.N.Y.), ECF Nos.\n\n\n\n\n 1\n This term includes the O\u2019Neill, Burnett, Ashton, and Ashton-Burlingame Claimants as defined in their respective\n verifications See ECF Nos. 160-2, 160-6, 160-10, 160-14, 163, 163-4, 163-8, and 163-12. Unless otherwise\n indicated, \u201cECF No.\u201d citations are to this case docket.\n\n 2\n See ECF Nos. 66, 69-70 (original claim asserted by the O\u2019Neill Claimants); ECF Nos. 160, 162-63 (9/11\n Claimants\u2019 Amended Claim); ECF Nos. 258, 259-260 (O\u2019Neill Claimants\u2019 Supplemental Claims).\n\n 1\n DOCS-100917790.3\n\fCase 1:25-cv-05745-RPK-CHK Document 493-1 Filed 07/31/26 Page 2 of 8 PageID\n #: 12994\n\n\n\n 12097, 12094, after the filing of the 9/11 Claimants\u2019 amended claim, ECF Nos. 160, 162-163, and\n\n the O\u2019Neill Claimants\u2019 supplemental claim, ECF Nos. 258, 259-260.\n\n As previously set forth in ECF Nos. 162 and 259, we learned about this forfeiture action\n\n and the allegations in Fritz v. Iran and China Investment Development Group d/b/a Lubian.com,\n\n No. 1:25-cv-07093 (E.D.N.Y.) regarding the Defendant Cryptocurrency that is property of the Iran\n\n and China Investment Development Group (\u201cIran-China Group\u201d). The Additional O\u2019Neill\n\n Claimants promptly sought leave to file Notice upon learning of this information and this\n\n proceeding and obtaining judgments.3 Based on the allegations in Fritz under the Terrorism Risk\n\n Insurance Act (\u201cTRIA\u201d), Pub. L. 107-297, 116 Stat. 2322 (Nov. 26, 2002), codified at 28 U.S.C.\n\n \u00a7 1610 Note, the Additional O\u2019Neill Claimants, as supplementing the O\u2019Neill Claimants\u2019 claim,\n\n can attach and execute on the property of Iran and its agencies and instrumentalities, including the\n\n Iran-China Group, \u201c[n]otwithstanding any other provision of law.\u201d The Additional O\u2019Neill\n\n Claimants hereby assert their superior interest to any interest of the U.S. government in so much\n\n of the Defendant Cryptocurrency as may ultimately be necessary to satisfy the Additional O\u2019Neill\n\n Claimants\u2019 outstanding compensatory damages judgments against Iran, plus pre- and post-\n\n judgment interest thereon.\n\n In support of this Notice, the Additional O\u2019Neill Claimants state as follows:\n\n\n\n\n 3\n As previously explained, the O\u2019Neill Claimants moved this Court, on January 19, 2026, for leave to file their\n verified claim. See ECF Nos. 66, 69-70. The 9/11 Claimants subsequently filed their Notice of Amended Verified\n Claim on February 2, 2026 to include all 9/11 Claimants\u2019 Verified Claims. See ECF Nos. 160, 162-63. Certain\n additional O\u2019Neill Claimants filed a Notice of Verified Claim on February 27, 2026. See ECF Nos. 258, 259-260.\n\n 2\n DOCS-100917790.3\n\fCase 1:25-cv-05745-RPK-CHK Document 493-1 Filed 07/31/26 Page 3 of 8 PageID\n #: 12995\n\n\n\n I. The Additional O\u2019Neill Claimants Have Been Awarded $120,750,000.00\n (Exclusive of Interest) in Compensatory Damages Against Iran.\n\n 1. On May 28, 2026, the U.S. District Court for the Southern District of New York\n\n entered compensatory damages judgments against Iran under 28 U.S.C. \u00a7 1605A for the Additional\n\n O\u2019Neill Claimants in the amount of $120,750,000.00, exclusive of interest.\n\n 2. The name of each Additional O\u2019Neill Claimant, the amount of compensatory\n\n damages awarded to such claimant, and the date and ECF No. of such judgment is listed in Exhibit\n\n 1 to the accompanying Verification of the Additional O\u2019Neill Claimants\u2019 Claims.\n\n 3. The compensatory damages judgments identified in Exhibit 1 are in the process of\n\n being served on Iran. The U.S. Department of State has informed us that there is a service delay\n\n due to the closure of the Swiss Embassy in Tehran, which coordinates with the U.S. Department\n\n of State to serve Iran documents via diplomatic channels pursuant to 28 U.S.C. \u00a7 1608(a)(4).\n\n 4. To date, Iran has not paid any portion of any of the Additional O\u2019Neill Claimants\u2019\n\n judgments, and none of Additional O\u2019Neill Claimants\u2019 judgments have been satisfied. The\n\n Additional O\u2019Neill Claimants\u2019 judgments continue to accrue post-judgment interest pursuant to 28\n\n U.S.C. \u00a7 1961.\n\n II. The U.S. Government Commenced this Forfeiture Action Against the Defendant\n Cryptocurrency Without Disclosing Its Extensive Connections to Iran\n\n 5. On October 14, 2025, the U.S. government initiated the instant civil forfeiture\n\n action against approximately 127,271 Bitcoin once stored in the virtual-currency addresses\n\n identified in Attachment A of its complaint. See ECF No. 1 (\u201cForfeiture Compl.\u201d) at 1 &\n\n Attachment. On the same day, this Court issued an arrest warrant in rem for Defendant\n\n Cryptocurrency pursuant to 18 U.S.C. \u00a7 981(a)(1)(C) and (a)(1)(A). See ECF 3.\n\n 6. The U.S. government alleges the Defendant Cryptocurrency is subject to\n\n condemnation and forfeiture by the United States: (1) under 18 U.S.C. \u00a7 981(a)(1)(C), as property\n\n 3\n DOCS-100917790.3\n\fCase 1:25-cv-05745-RPK-CHK Document 493-1 Filed 07/31/26 Page 4 of 8 PageID\n #: 12996\n\n\n\n that constitutes proceeds or is derived from proceeds of a violation of the wire fraud statute or a\n\n conspiracy to violate that statute, 18 U.S.C. \u00a7\u00a7 1343, 1349; and (2) under 18 U.S.C. \u00a7 981(a)(1)(A),\n\n as property that was involved in or is derived from property involved in a money laundering\n\n transaction, an attempted money laundering transaction, or a conspiracy to make a money\n\n laundering transaction, 18 U.S.C. \u00a7 1956. See Forfeiture Compl. \u00b6 2. Specifically, the U.S.\n\n government alleges that the Defendant Cryptocurrency was involved in or derived from money-\n\n laundering operations conducted by Chen Zhi and Prince Holding Group, an alleged front for\n\n Chen\u2019s transnational criminal organization. Id. at \u00b6\u00b6 20, 38-43.\n\n 7. According to the U.S. government, one such scheme involved using stolen\n\n cryptocurrency to fund a \u201clarge-scale cryptocurrency mining operation[ ]\u201d called \u201cLubian,\u201d which\n\n was the \u201csixth largest bitcoin mining operation in the world\u201d \u201c[f]or some of the time it was active\u201d\n\n and produced \u201clarge sums of clean bitcoin dissociated from criminal proceeds.\u201d Id. \u00b6 42.\n\n 8. The U.S. government describes \u201cLubian\u201d as \u201ca Chinese Bitcoin mining operation\n\n that maintained bitcoin mining facilities across Asia, including in China and Iran.\u201d Id. \u00b6 16(u)\n\n (emphasis added). However, the U.S. government did not include information that put the\n\n Additional O\u2019Neill Claimants on notice that the bitcoin mining operation involved conduct\n\n attributable to the Iranian Government, or otherwise that the Additional O\u2019Neill Claimants had a\n\n basis to claim any of the Defendant Cryptocurrency.\n\n IV. The Additional O\u2019Neill Claimants Learned of the Relationship Between the\n Defendant Cryptocurrency and the Government of Iran\n\n 9. Based on information and belief, it appears that the Defendant Cryptocurrency is\n\n directly tied to Iran, which was not clear from the forfeiture pleadings commenced by the U.S.\n\n government.\n\n\n\n\n 4\n DOCS-100917790.3\n\fCase 1:25-cv-05745-RPK-CHK Document 493-1 Filed 07/31/26 Page 5 of 8 PageID\n #: 12997\n\n\n\n 10. On December 26, 2025, other victims of Iran\u2019s state-sponsored terrorism\n\n commenced a separate action alleging that LuBian was the cryptocurrency mining pool for the\n\n Iran-China Group, an Iranian joint-stock company that partnered with the Iranian government to\n\n build a large Bitcoin mine in Rafsanjan, Iran to assist Iran\u2019s longstanding efforts to evade U.S.\n\n sanctions. See Fritz v. Iran and China Investment Development Group d/b/a Lubian.com, No. 1:25-\n\n cv-07093 (E.D.N.Y.), Complaint for Execution and Turnover, ECF No. 1.\n\n 11. The Fritz plaintiffs in the Fritz action, along with another group of victims of Iran\u2019s\n\n state-sponsored terrorism (the \u201cBaxter Victims\u201d), filed Notices of Verified Claims in this action\n\n on December 29, 2025. See ECF Nos. 29 and 30.\n\n 12. Based on the information revealed in the allegations in the Fritz action and\n\n summarized by the Notices of Verified Claims filed by the other terrorism victim claimants in this\n\n action, see e.g., ECF Nos. 29 and 30, the Additional O\u2019Neill Claimants now submit this\n\n supplemental Notice of Verified Claim to be considered as part of the O\u2019Neill Claimants\u2019 Claim.\n\n V. Under TRIA, the Additional O\u2019Neill Claimants Have a Senior Interest in the\n Defendant Cryptocurrency\n\n 13. In the context of a forfeiture action, at this stage of the proceedings, the Additional\n\n O\u2019Neill Claimants need only assert that they have a \u201cfacially colorable interest\u201d in the property at\n\n issue. United States v. Ross, 161 F.4th 100, 109 (2d Cir. 2025) (citation omitted). \u201c[W]hether [they]\n\n ultimately prove[ ] the existence of that interest is a question for a later stage in the proceedings.\u201d\n\n Id. (citation omitted). Here, based on the information alleged in the Fritz action and summarized\n\n by the Notices of Verified Claims filed by the other terrorism victim claimants in this action, the\n\n 9/11 Claimants have far more than a \u201cfacially colorable interest\u201d in the Defendant Cryptocurrency.\n\n 14. The Additional O\u2019Neill Claimants are judgment creditors of Iran as a result of Iran\u2019s\n\n acts of state-sponsored terrorism. As has now been alleged, because the Iran-China Group was or\n\n\n 5\n DOCS-100917790.3\n\fCase 1:25-cv-05745-RPK-CHK Document 493-1 Filed 07/31/26 Page 6 of 8 PageID\n #: 12998\n\n\n\n is an agent or instrumentality of Iran, TRIA entitles the Additional O\u2019Neill Claimants to execute\n\n on the Defendant Cryptocurrency to satisfy those judgments \u201c[n]otwithstanding any other\n\n provision of law.\u201d TRIA \u00a7 201(a). Accordingly, the Additional O\u2019Neill Claimants have a\n\n possessory interest in the Defendant Cryptocurrency, which permits them to bring the claims\n\n asserted here.\n\n 15. Specifically, TRIA provides that \u201c[n]otwithstanding any other provision of law,\u201d\n\n those who hold judgments against a \u201cterrorist party\u201d may execute on the \u201cblocked assets\u201d of that\n\n terrorist party or its \u201cagency or instrumentality\u201d \u201cto satisfy such judgment to the extent of any\n\n compensatory damages.\u201d Pub. L. No. 107-297, \u00a7 201(a), 116 Stat. 2322, 2337 (2002), codified at\n\n 28 U.S.C. \u00a7 1610 Note. TRIA\u2019s cornerstone is the statute\u2019s broad \u201cnotwithstanding\u201d clause, which\n\n aims to \u201cenable\u201d victims \u201cto execute on\u201d terrorists\u2019 assets by preventing other provisions of law\n\n from \u201cbar[ring] victims\u2019 efforts to enforce [their] judgments.\u201d Ministry of Def. & Support for the\n\n Armed Forces of the Islamic Republic of Iran v. Elahi, 556 U.S. 366, 391-92 (2009) (Kennedy, J.,\n\n concurring). The notwithstanding clause \u201cmak[es] plain that the force of the [statute] extends\n\n everywhere\u201d and \u201c\u2018supersede[s] all other laws.\u2019\u201d Weinstein v. Islamic Republic of Iran, 609 F.3d\n\n 43, 49 (2d Cir. 2010) (citation omitted). Accordingly, because it expressly overrides \u201cconflict[ing]\n\n laws,\u201d TRIA\u2019s notwithstanding clause necessarily overrides \u201cthe civil-forfeiture statute.\u201d Estate of\n\n Levin v. Wells Fargo Bank, N.A., 156 F.4th 632, 643 n.1 (D.C. Cir. 2025).\n\n 16. Because the Additional O\u2019Neill Claimants satisfy the requirements of TRIA, their\n\n interest in the Defendant Cryptocurrency necessarily is superior to the claims of the U.S.\n\n government, as well as all other non-TRIA claimants, in this forfeiture action. First, as explained\n\n above, the Additional O\u2019Neill Claimants hold judgments for compensatory damages against Iran\n\n based on an act of terrorism under 28 U.S.C. \u00a7 1605A. Second, Iran is a \u201cterrorist party\u201d because\n\n it has been designated as a state sponsor of terrorism under the Export Administration Act of 1979.\n\n 6\n DOCS-100917790.3\n\fCase 1:25-cv-05745-RPK-CHK Document 493-1 Filed 07/31/26 Page 7 of 8 PageID\n #: 12999\n\n\n\n See TRIA \u00a7 201(d)(4); Executive Order No. 13599, 77 Fed. Reg. 6659 (Feb. 5, 2012). Third, as\n\n alleged in the Fritz action, the Iran-China Group operated as Iran\u2019s agency or instrumentality by\n\n materially helping Iran avoid U.S. sanctions, while providing the material function to Iran of\n\n laundering its energy resources through cryptocurrency mining, at Iran\u2019s direction and behest.\n\n Fritz Suit, ECF No. 70, Plaintiffs\u2019 Memorandum of Law in Support of Motion for Attachment, at\n\n 13-17 (Dec. 28, 2025); see Kirschenbaum v. 650 Fifth Ave., 830 F.3d 107, 135 (2d Cir. 2016).\n\n Fourth, under TRIA, \u201c[b]locked assets\u201d include \u201cany asset seized or frozen by the United States\u201d\n\n pursuant to the International Emergency Economic Powers Act. TRIA \u00a7 201(d)(2)(A).\n\n 20. The U.S. government has used its authority under that statute to \u201cblock\u201d all Iranian\n\n property in the United States, including the property of agencies or instrumentalities of Iran. 31\n\n C.F.R. \u00a7\u00a7 510.211, 594.201(a)(5); Kirschenbaum, 830 F.3d at 120. As a result, if the Iran-China\n\n Group is an agency or instrumentality of Iran, all property of the Iran-China Group qualifies as a\n\n blocked asset under TRIA. See Levinson v. Kuwait Finance House (Malaysia) Berhad, 44 F.4th\n\n 91, 98 n.6 (2d Cir. 2022). Because the Defendant Cryptocurrency is property of the Iran-China\n\n Group, it is therefore blocked and subject to execution by the Additional O\u2019Neill Claimants under\n\n TRIA.\n\n Pursuant to 28 U.S.C. \u00a7 983(a) and Rule G, the Additional O\u2019Neill Claimants hereby assert\n\n a claim against such amount of the Defendant Cryptocurrency\u2014as the property of an agency or\n\n instrumentality of Iran\u2014as may ultimately be necessary to satisfy the outstanding compensatory\n\n damages owed to them under their judgments against Iran, plus pre- and post-judgment interest,\n\n based on the date the Defendant Cryptocurrency is valued for purposes of judgment. The\n\n Additional O\u2019Neill Claimants\u2019 claim (as supplementing the O\u2019Neill Claimants\u2019 claim, and thus as\n\n part of the 9/11 Claimants\u2019 claim) is senior to the U.S. government\u2019s claim. Notwithstanding the\n\n\n\n 7\n DOCS-100917790.3\n\fCase 1:25-cv-05745-RPK-CHK Document 493-1 Filed 07/31/26 Page 8 of 8 PageID\n #: 13000\n\n\n\n U.S. government\u2019s forfeiture efforts, the Additional O\u2019Neill Claimants reserve all rights and\n\n remedies available in law and equity to enforce their interest in the Defendant Cryptocurrency.\n\n Dated: July 31, 2026\n\n ANDERSON KILL P.C.\n By: /s/ Jerry S. Goldman\n Jerry S. Goldman, Esq.\n Bruce Strong, Esq.\n Ethan Greenberg, Esq.\n Samuel Braverman, Esq.\n Alexander Greene, Esq.\n Amy Weiss, Esq.\n 7 Times Square, 15th Floor\n New York, New York 10036\n jgoldman@andersonkill.com\n Tel: (212) 278-1000\n Fax: (212) 278-1733\n Attorneys for the O\u2019Neill Claimants\n\n\n\n\n 8\n DOCS-100917790.3\n\f","ocr_status":2,"date_upload":"2026-07-31T12:52:32.562897-07:00","document_number":"493","attachment_number":1,"pacer_doc_id":"123024031847","is_available":true,"is_free_on_pacer":null,"is_sealed":false,"document_type":2,"description":"Notice of Supplemental Verified Claim and Statement of Interest or Right in Pro","acms_document_guid":""},{"resource_uri":"https://www.courtlistener.com/api/rest/v4/recap-documents/488308281/","id":488308281,"tags":[],"absolute_url":"/docket/71639393/493/2/united-states-v-approximately-127271-bitcoin-btc-previously-stored-at/","date_created":"2026-07-31T12:52:29.655834-07:00","date_modified":"2026-08-14T22:27:22.763923-07:00","sha1":"cea9a3f3d7511a6b27669cb1563cc5bd4dd67432","page_count":3,"file_size":513636,"filepath_local":"recap/gov.uscourts.nyed.537552/gov.uscourts.nyed.537552.493.2.pdf","filepath_ia":"https://archive.org/download/gov.uscourts.nyed.537552/gov.uscourts.nyed.537552.493.2.pdf","ia_upload_failure_count":null,"thumbnail":null,"thumbnail_status":0,"plain_text":"Case 1:25-cv-05745-RPK-CHK Document 493-2 Filed 07/31/26 Page 1 of 3 PageID\n #: 13001\n\n\n\n UNITED STATES DISTRICT COURT\n EASTERN DISTRICT OF NEW YORK\n\n\n UNITED STATES OF AMERICA,\n\n Plaintiff,\n\n v. Civil Action No. 1:25-cv-05745\n APPROXIMATELY 127,271 BITCOIN (\u201cBTC\u201d) (RPK)\n PREVIOUSLY STORED AT THE VIRTUAL\n CURRENCY ADDRESSES LISTED IN ATTACHMENT\n A, AND ALL PROCEEDS TRACEABLE THERETO,\n\n Defendant, In Rem.\n\n VERIFICATION OF THE ADDITIONAL O\u2019NEILL CLAIMANTS\u2019 CLAIMS\n\n JERRY S. GOLDMAN, Esq., an attorney duly licensed to practice law before the Courts\n\n of the State of New York and this Court, declares under penalties of perjury pursuant to 28 U.S.C.\n\n \u00a7 1746 as follows:\n\n 1. I am a shareholder of the law firm Anderson Kill P.C., 7 Times Square, 15th Floor,\n\n New York, NY 10036.\n\n 2. All statements in this verification are within my personal knowledge and reflected\n\n in the official dockets of this court and the United States District Court for the Southern District\n\n of New York.\n\n 3. I make this declaration on behalf of the Additional O\u2019Neill Claimants, as identified\n\n on annexed Exhibit 1.\n\n 4. This Verified Claim supplements and relates back to the Verified Claim and\n\n associated documents submitted by the O\u2019Neill Claimants. See ECF Nos. 66, 69-70 (original claim\n\n asserted by the O\u2019Neill Claimants); see also ECF Nos. 160, 162-63 (9/11 Claimants\u2019 Amended\n\n Claim); see also ECF Nos. 258, 259-260 (O\u2019Neill Claimants\u2019 Supplemental Claim).\n\n\n\n DOCS-100917791.2\n\fCase 1:25-cv-05745-RPK-CHK Document 493-2 Filed 07/31/26 Page 2 of 3 PageID\n #: 13002\n\n\n\n 5. I represent the O\u2019Neill Claimants and the Additional O\u2019Neill Claimants in this\n\n action, and in actions consolidated into the multidistrict litigation, In re Terrorist Attacks on\n\n September 11, 2001, No. 03-MDL-1570 (GBD)(SN)(S.D.N.Y.) (the \u201c9/11 MDL\u201d).\n\n 6. On June 1, 2026, the Additional O\u2019Neill Claimants were awarded compensatory\n\n damages judgments totaling $120,750,000.00, exclusive of interest, under 28 U.S.C. \u00a7 1605A\n\n against the Islamic Republic of Iran (\u201cIran\u201d) for its role in sponsoring the 9/11 Attacks.\n\n 7. Attached hereto as Exhibit 1 is a verified list of the Additional O\u2019Neill Claimants,\n\n the amount of compensatory damages awarded to such claimant, and the date and ECF No. of such\n\n judgment.\n\n 8. The compensatory damages judgments identified in annexed Exhibit 1 are in the\n\n process of being served on Iran.\n\n 9. As detailed in a related action pending in this Court, entitled Fritz v. Iran & China\n\n Investment Development Group, No. 1:2025-cv-07093 (E.D.N.Y.) (the \u201cFritz Action\u201d), the\n\n 127,271 Bitcoin that constitute the Defendant Cryptocurrency in the instant action belong to the\n\n Iran and China Investment Development Group (\u201cIran-China Group\u201d), doing business as\n\n Lubian.com or LuBian. See Fritz Action, ECF No. 70. The Iran-China Group is an agency or\n\n instrumentality of Iran. Accordingly, its assets are blocked by operation of U.S. law. See Executive\n\n Order No. 13599, 77 Fed. Reg. 6659, 6659 (Feb. 5, 2012).\n\n 10. To preserve the Additional O\u2019Neill Claimants\u2019 ability to pursue execution and\n\n turnover of the 127,271 Bitcoin\u2014which constitute the Defendant Cryptocurrency in this action\u2014\n\n on behalf of the Additional O\u2019Neill Claimants pursuant to N.Y. CPLR 3020(d), I hereby notice\n\n and verify the claim of the Additional O\u2019Neill Claimants against the Defendant Cryptocurrency.\n\n Because the Terrorism Risk Insurance Act (\u201cTRIA\u201d) allows victim of terrorism with judgments\n\n\n\n 2\n DOCS-100917791.2\n\fCase 1:25-cv-05745-RPK-CHK Document 493-2 Filed 07/31/26 Page 3 of 3 PageID\n #: 13003\n\n\n\n against state sponsors of terrorism to pursue execution and turnover against blocked assets of those\n\n terrorist states or their agents or instrumentalities\u2014including such assets that have been \u201cseized\u201d\n\n by the U.S. government\u2014\u201cnotwithstanding the any other provision of law,\u201d TRIA \u00a7 201(a), I\n\n hereby notice and verify the Additional O\u2019Neill Claimants\u2019 claim (as supplementing the O\u2019Neill\n\n Claimants\u2019 claim, and thus as part of the 9/11 Claimants\u2019 claim) superior interest in so much of\n\n the Defendant Cryptocurrency as may ultimately be necessary to satisfy the outstanding\n\n compensatory damages owed to the 9/11 Claimants on their judgments against Iran, plus pre- and\n\n post-judgment interest.\n\n I declare under penalties of perjury pursuant to 28 U.S.C. \u00a7 1746 that the foregoing is true\n\n and correct.\n\n Dated: New York, New York\n July 31, 2026\n /s/ Jerry S. Goldman\n Jerry S. Goldman, Esq.\n\n\n\n\n 3\n DOCS-100917791.2\n\f","ocr_status":2,"date_upload":"2026-07-31T12:52:35.127747-07:00","document_number":"493","attachment_number":2,"pacer_doc_id":"123024031848","is_available":true,"is_free_on_pacer":null,"is_sealed":false,"document_type":2,"description":"Verification of the Additional O'Neill Claimants' Claims","acms_document_guid":""},{"resource_uri":"https://www.courtlistener.com/api/rest/v4/recap-documents/488308282/","id":488308282,"tags":[],"absolute_url":"/docket/71639393/493/3/united-states-v-approximately-127271-bitcoin-btc-previously-stored-at/","date_created":"2026-07-31T12:52:29.666942-07:00","date_modified":"2026-08-14T22:27:23.807272-07:00","sha1":"41a171c0fbfff0571904b636218c31868dead368","page_count":1,"file_size":221657,"filepath_local":"recap/gov.uscourts.nyed.537552/gov.uscourts.nyed.537552.493.3.pdf","filepath_ia":"https://archive.org/download/gov.uscourts.nyed.537552/gov.uscourts.nyed.537552.493.3.pdf","ia_upload_failure_count":null,"thumbnail":null,"thumbnail_status":0,"plain_text":" Case 1:25-cv-05745-RPK-CHK Document 493-3 Filed 07/31/26 Page 1 of 1 PageID\n #: 13004\n\n Date of Iran Compensatory\n Claimant\u2019s Relationship Statutory Basis 9/11 MDL ECF\nClaimant Name 9/11 Decedent Iran Damages\n to 9/11 Decedent for Judgment No. of Judgment\n Judgment Amount Awarded\n\nZeshan Hamdani\n as Personal 12097; 12094\nRepresentative of Mohammad S. (Memorandum\n Parent (Deceased) 6/1/2026 1605A $8,500,000.00\n the Estate of Hamdani Decision and\n Mohammad Order)\nSaleem Hamdani\nJudith Knight as\n Personal 12097; 12094\nRepresentative of (Memorandum\n Frank Wisniewski Parent (Deceased) 6/1/2026 1605A $8,500,000.00\n the Estate of Decision and\n Vincent Order)\n Wisniewski\n 12097; 12094\n (Memorandum\n Lea McKenzie Molly McKenzie Child 6/1/2026 1605A $8,500,000.00\n Decision and\n Order)\n 12097; 12094\n (Memorandum\n Stacy Paolozzi Franklin Pershep PR 6/1/2026 1605A $2,000,000.00\n Decision and\n Order)\n Brian Fine, as\n 12097; 12094\n Personal\n (Memorandum\nRepresentative of Franklin Pershep Child (Deceased) 6/1/2026 1605A $8,500,000.00\n Decision and\n the Estate of\n Order)\n Sharyn Fine\n 12097; 12094\n (Memorandum\nQuawana Bowden Lacey B. Ivory Child 6/1/2026 1605A $8,500,000.00\n Decision and\n Order)\n Andrew C. Kelly\n 12097; 12094\n as the Personal\n (Memorandum\nRepresentative of Maurice Kelly Child (Deceased) 6/1/2026 1605A $8,500,000.00\n Decision and\nthe Estate of Sean\n Order)\n Kelly\n 12097; 12094\nKen Reibman, aka (Memorandum\n Chet Louie PR 6/1/2026 1605A $2,000,000.00\n Calvin Louie Decision and\n Order)\n 12097; 12094\n Pamela Bittner- (Memorandum\n Jeffrey Bittner PR 6/1/2026 1605A $2,000,000.00\n Conley Decision and\n Order)\nKenneth Lum and\n Russell Lum, as 12097; 12094\n co-Personal (Memorandum\n William Lum Parent (Deceased) 6/1/2026 1605A $8,500,000.00\nRepresentatives of Decision and\n the Estate of Order)\n Grace Lum\n 12097; 12094\n (Memorandum\n Michelle Fallon David Ruddle Sibling 6/1/2026 1605A $4,250,000.00\n Decision and\n Order)\n 12097; 12094\n (Memorandum\n David Kuo Frederick Kuo, Jr. Child 6/1/2026 1605A $8,500,000.00\n Decision and\n Order)\n 12097; 12094\n Melissa Kuo (Memorandum\n Frederick Kuo, Jr. Child 6/1/2026 1605A $8,500,000.00\n Wallace Decision and\n Order)\n 12097; 12094\n (Memorandum\nFrederick J. Kuo Frederick Kuo, Jr. Child 6/1/2026 1605A $8,500,000.00\n Decision and\n Order)\n 12097; 12094\n (Memorandum\n John McShane Terence McShane Sibling 6/1/2026 1605A $4,250,000.00\n Decision and\n Order)\n 12097; 12094\n (Memorandum\nKieran McShane Terence McShane Sibling 6/1/2026 1605A $4,250,000.00\n Decision and\n Order)\nGeorge O. Taylor\n 12097; 12094\n as Personal\n (Memorandum\nRepresentative of Hilda E. Taylor Child (Deceased) 6/1/2026 1605A $8,500,000.00\n Decision and\n the Estate of\n Order)\nDonald Stafford\n 12097; 12094\n Geraldine (Memorandum\n David Ruddle Sibling 6/1/2026 1605A $4,250,000.00\n Mechutan Decision and\n Order)\n 12097; 12094\n Patricia Ruddle (Memorandum\n David Ruddle Sibling 6/1/2026 1605A $4,250,000.00\n Gallagher Decision and\n Order)\n\f","ocr_status":2,"date_upload":"2026-07-31T12:52:37.480358-07:00","document_number":"493","attachment_number":3,"pacer_doc_id":"123024031849","is_available":true,"is_free_on_pacer":null,"is_sealed":false,"document_type":2,"description":"Exhibit 1 Supplemental Claims","acms_document_guid":""}],"date_created":"2026-07-31T12:40:56.416437-07:00","date_modified":"2026-08-07T07:34:46.852626-07:00","date_filed":"2026-07-31","time_filed":"15:32:13","entry_number":493,"recap_sequence_number":"2026-07-31.001","pacer_sequence_number":3408,"description":"Letter MOTION for Leave to File Document re Verified Claim of the Additional O'Neill Claimants to Supplement the O'Neill Claim by ONeill Claimants. (Attachments: # 1 Notice of Supplemental Verified Claim and Statement of Interest or Right in Property Subject to Forfeiture in rem, # 2 Verification of the Additional O'Neill Claimants' Claims, # 3 Exhibit 1 Supplemental Claims) (Goldman, Jerry) (Entered: 07/31/2026)","tags":[]},{"resource_uri":"https://www.courtlistener.com/api/rest/v4/docket-entries/472564967/","id":472564967,"docket":"https://www.courtlistener.com/api/rest/v4/dockets/71639393/","recap_documents":[{"resource_uri":"https://www.courtlistener.com/api/rest/v4/recap-documents/488003019/","id":488003019,"tags":[],"absolute_url":"/docket/71639393/492/united-states-v-approximately-127271-bitcoin-btc-previously-stored-at/","date_created":"2026-07-29T13:58:09.394244-07:00","date_modified":"2026-08-14T23:06:49.024747-07:00","sha1":"5e0a7af3379d4b6a6ab6b96ca0d18d35866268ea","page_count":3,"file_size":190073,"filepath_local":"recap/gov.uscourts.nyed.537552/gov.uscourts.nyed.537552.492.0.pdf","filepath_ia":"https://archive.org/download/gov.uscourts.nyed.537552/gov.uscourts.nyed.537552.492.0.pdf","ia_upload_failure_count":null,"thumbnail":null,"thumbnail_status":0,"plain_text":"Case 1:25-cv-05745-RPK-CHK Document 492 Filed 07/29/26 Page 1 of 3 PageID #:\n 12986\n\n\n\n UNITED STATES DISTRICT COURT\n EASTERN DISTRICT OF NEW YORK\n\n\n UNITED STATES OF AMERICA,\n\n Plaintiff,\n Case No. 1:25-cv-05745-RPK\n v.\n NOTICE OF APPEARANCE\n APPROXIMATELY 127,271 BITCOIN (\u201cBTC\u201d)\n PREVIOUSLY STORED AT THE VIRTUAL\n CURRENCY ADDRESSES LISTED IN\n ATTACHMENT A, AND ALL PROCEEDS\n TRACEABLE THERETO,\n\n Defendant In Rem.\n\n\n\n PLEASE TAKE NOTICE that the undersigned attorney, CHRISTOPHER J. DUNNE,\n\n of the law firm Sullivan & Cromwell LLP, hereby respectfully enters her appearance on behalf of the\n\n Authorized Foreign Representatives of Prince Global Holdings Limited and 29 affiliated companies (the\n\n \u201cDebtors\u201d)1 in the above-captioned matter. Pursuant to the Order Granting Recognition of Foreign Main\n\n Proceedings and Related Relief, In re Prince Global Holdings Ltd., No. 26-10769 (MG) (Bankr. S.D.N.Y.\n\n June 18, 2026), ECF No. 90, the Authorized Foreign Representatives limit their appearance to informing\n\n this Court of their interests in this proceeding. I certify that I am admitted to practice before this Court.\n\n All future pleadings, motions, and other papers filed or served in this action should be served at the address\n\n identified below.\n\n\n\n\n 1\n A complete list of the Debtors and their company numbers is attached as Exhibit A to the\n Prince Global Holdings Limited and Its Affiliated Debtors Statement of Interest, ECF No.\n 485.\n\fCase 1:25-cv-05745-RPK-CHK Document 492 Filed 07/29/26 Page 2 of 3 PageID #:\n 12987\n\n\n\n Dated: July 29, 2026 Respectfully submitted,\n New York, New York\n\n /s/ Christopher J. Dunne\n Christopher J. Dunne\n SULLIVAN & CROMWELL LLP\n 125 Broad Street\n New York, NY 10004\n Telephone: (212) 558-4000\n Facsimile: (212) 558-4115\n Email: dunnec@sullcrom.com\n\n\n Counsel to the Authorized Foreign\n Representatives\n\fCase 1:25-cv-05745-RPK-CHK Document 492 Filed 07/29/26 Page 3 of 3 PageID #:\n 12988\n\n\n\n Certificate of Service\n\n I, CHRISTOPHER J. DUNNE, declare under penalty of perjury that a true and correct copy of the\n foregoing Notice of Appearance was filed on July 29, 2026 by means of the U.S. District Court\n for the Eastern District of New York\u2019s Case Management/Electronic Case Filing (CM/ECF),\n which will send notification of such filing by electronic mail to all ECF participants.\n\n /s/ Christopher J. Dunne\n Christopher J. Dunne\n\f","ocr_status":2,"date_upload":"2026-07-29T13:58:09.654911-07:00","document_number":"492","attachment_number":null,"pacer_doc_id":"123024022794","is_available":true,"is_free_on_pacer":null,"is_sealed":false,"document_type":1,"description":"Notice of Appearance","acms_document_guid":""}],"date_created":"2026-07-29T13:58:09.362154-07:00","date_modified":"2026-07-30T22:13:03.905947-07:00","date_filed":"2026-07-29","time_filed":"16:57:25","entry_number":492,"recap_sequence_number":"2026-07-29.001","pacer_sequence_number":3403,"description":"NOTICE of Appearance by Christopher James Dunne on behalf of James Drury, Paul Pretlove, David Standish (aty to be noticed) (Dunne, Christopher) (Entered: 07/29/2026)","tags":[]},{"resource_uri":"https://www.courtlistener.com/api/rest/v4/docket-entries/472319842/","id":472319842,"docket":"https://www.courtlistener.com/api/rest/v4/dockets/71639393/","recap_documents":[{"resource_uri":"https://www.courtlistener.com/api/rest/v4/recap-documents/487749623/","id":487749623,"tags":[],"absolute_url":"/docket/71639393/491/united-states-v-approximately-127271-bitcoin-btc-previously-stored-at/","date_created":"2026-07-27T18:22:48.795889-07:00","date_modified":"2026-08-14T21:41:08.522378-07:00","sha1":"3e67fd0c8998d363d3359cbad866e1de871db550","page_count":10,"file_size":200467,"filepath_local":"recap/gov.uscourts.nyed.537552/gov.uscourts.nyed.537552.491.0.pdf","filepath_ia":"https://archive.org/download/gov.uscourts.nyed.537552/gov.uscourts.nyed.537552.491.0.pdf","ia_upload_failure_count":null,"thumbnail":null,"thumbnail_status":0,"plain_text":"Case 1:25-cv-05745-RPK-CHK Document 491 Filed 07/27/26 Page 1 of 10 PageID #:\n 12962\n\n\n\n IN THE UNITED STATES DISTRICT COURT\n EASTERN DISTRICT OF NEW YORK\n\n\n\n UNITED STATES OF AMERICA, et al.,\n\n Plaintiffs,\n\n v.\n\n APPROXIMATELY 127,271 BITCOIN Civil Action No. 1:25-cv-05745 (RPK)\n (\u201cBTC\u201d) PREVIOUSLY STORED AT THE\n VIRTUAL CURRENCY ADDRESSES\n LISTED IN ATTACHMENT A, AND ALL\n PROCEEDS TRACEABLE THERETO,\n\n Defendant In Rem.\n\n\n\n NOTICE OF VERIFIED CLAIM AND STATEMENT OF INTEREST\n OR RIGHT IN PROPERTY SUBJECT TO FORFEITURE IN REM\n\n Claimants are victims of state-sponsored terrorism (the \u201cOwens Victims\u201d), who have\n\n obtained final judgments against the Islamic Republic of Iran, including under 28 U.S.C. \u00a7 1605A\n\n and its predecessor statute, 28 U.S.C. \u00a7 1605(a)(7).1 Like the other Iran judgment creditors who\n\n have asserted claims against the Defendant Cryptocurrency, the Owens Victims have been waiting\n\n years\u2014and in some cases decades\u2014for Iran to satisfy their judgments.\n\n The Owens Victims now seek to attach the Defendant Cryptocurrency on the same legal\n\n basis as the other Iran judgment creditors: the Terrorism Risk Insurance Act (\u201cTRIA\u201d), which\n\n provides that \u201c[n]otwithstanding any other provision of law,\u201d those who hold judgments against a\n\n \u201cterrorist party\u201d may \u201cexecut[e]\u201d on or attach \u201cin aid of execution\u201d the \u201cblocked assets\u201d of that\n\n terrorist party or its \u201cagency or instrumentality.\u201d Pub. L. No. 107-297 \u00a7 201(a), 116 Stat. 2322,\n\n\n\n 1\n A full list of Claimants and the compensatory damages that they have been awarded is\n included as Attachment A to the Verification of the Owens Victims\u2019 Claims.\n\fCase 1:25-cv-05745-RPK-CHK Document 491 Filed 07/27/26 Page 2 of 10 PageID #:\n 12963\n\n\n\n 2337 (2002) (codified as 28 U.S.C. \u00a7 1610 (note)). \u201cCongress specifically intended TRIA to\n\n address the Executive Branch\u2019s reluctance to allow blocked funds to be used to compensate\n\n terrorism victims.\u201d Hausler v. JP Morgan Chase Bank, N.A., 740 F. Supp. 2d 525, 538 (S.D.N.Y.\n\n 2010). And Congress designed both TRIA and the FSIA to permit attachment and execution in\n\n precisely these circumstances, where victims of terrorism identify assets in the United States\n\n belonging to a state sponsor of terrorism that were blocked after being used for a paradigmatic\n\n commercial activity. See TRIA \u00a7 201; 28 U.S.C. \u00a7 1610(a)(7), (g).\n\n The evidence establishing that the Defendant Cryptocurrency constitutes blocked assets of\n\n Iran through the Iran-China Group\u2014an agency or instrumentality of Iran\u2014has already been\n\n extensively briefed by the Fritz Victims and Baxter Victims. See ECF 29 (summarizing evidence\n\n presented in turnover proceeding, Fritz v. Iran & China Invs. Dev. Grp., No. 1:25-cv-07093\n\n (E.D.N.Y.)); ECF 30 \u00b6\u00b6 16-18 (same); see also Complaint for Execution and Turnover, Fritz,\n\n No. 1:25-cv-07093 (E.D.N.Y. Dec. 26, 2025), ECF 1 (\u201cFritz Compl.\u201d). Accordingly, the Owens\n\n Victims hereby assert their superior interest in all of the Defendant Cryptocurrency, or at least so\n\n much as may ultimately be necessary to satisfy the outstanding compensatory damages, with post-\n\n judgment interest, on their judgments, which TRIA makes senior to any interest the government\n\n could assert.2\n\n I. Background\n\n A. The Owens Victims Hold Billions of Dollars in Judgments Against Iran.\n\n The Owens Victims are direct victims of Iranian state-sponsored terrorism who have\n\n obtained final judgments against Iran in the U.S. District Court for the District of Columbia. Owens\n\n\n 2\n Because the value of Bitcoin fluctuates from day to day, the amount of Bitcoin necessary to\n satisfy the Owens Victims\u2019 judgments cannot be fully determined until the Bitcoin is transferred\n or otherwise liquidated in satisfaction of the judgments.\n\n\n 2\n\fCase 1:25-cv-05745-RPK-CHK Document 491 Filed 07/27/26 Page 3 of 10 PageID #:\n 12964\n\n\n\n v. Republic of Sudan, No. 1:01-cv-02244 (D.D.C. Nov. 28, 2011), ECF 214; Mwila v. Islamic\n\n Republic of Iran, No. 1:08-cv-01377 (D.D.C. Nov. 30, 2011), ECF 30; Khaliq v. Republic of Sudan,\n\n No. 1:10-cv-00356 (D.D.C. Nov. 30, 2011) ECF 25; Taitt v. Islamic Republic of Iran, No. 1:20-cv-\n\n 01557 (D.D.C. Mar. 16, 2023) , ECF 21; Gunn v. Islamic Republic of Iran, No. 1:21-cv-01187\n\n (D.D.C. Aug. 2, 2024), ECF 46. These judgments were entered pursuant to 28 U.S.C. \u00a7 1605A or\n\n its predecessor statute, 28 U.S.C. \u00a7 1605(a)(7), which provide an exception to foreign sovereign\n\n immunity for claims arising from acts of terrorism by state sponsors of terrorism\u2014a category that\n\n includes Iran. See Havlish v. Taliban, 152 F.4th 339, 360 (2d Cir. 2025) (recognizing that Iran is a\n\n \u201cterrorist party\u201d under TRIA).\n\n The Owens Victims have suffered devastating losses as a result of Iran\u2019s material support\n\n for terrorist organizations. They consist of the victims and family members of victims of al Qaeda\u2019s\n\n 1998 suicide bombings of the U.S. embassies in Kenya and Tanzania and al Qaeda\u2019s 2000 bombing\n\n of the U.S.S. Cole in Yemen. See Owens, No. 1:01-cv-02244 (D.D.C. Nov. 28, 2011), ECF 215;\n\n Mwila, No. 1:08-cv-01377 (D.D.C. Nov. 30, 2011), ECF 31; Khaliq, No. 1:10-cv-00356 (D.D.C.\n\n Nov. 30, 2011), ECF 26; Taitt, No. 1:20-cv-01557 (D.D.C. Mar. 16, 2023), ECF 22; Gunn,\n\n No. 1:21-cv-01187 (D.D.C. July 29, 2024), ECF 39. The judgments entered on behalf of the Owens\n\n Victims reflect the gravity of their injuries and represent the legal determination by U.S. courts\n\n that Iran is liable for its role in enabling these terrorist attacks. See Owens, No. 1:01-cv-02244\n\n (D.D.C. Nov. 28, 2011), ECF 215; Mwila, No. 1:08-cv-01377 (D.D.C. Nov. 30, 2011), ECF 31;\n\n Khaliq, No. 1:10-cv-00356 (D.D.C. Nov. 30, 2011), ECF 26; Taitt, No. 1:20-cv-01557 (D.D.C.\n\n Mar. 16, 2023), ECF 22; Gunn, No. 1:21-cv-01187 (D.D.C. July 29, 2024), ECF 39. Iran has\n\n refused to honor its obligations under these judgments.\n\n\n\n\n 3\n\fCase 1:25-cv-05745-RPK-CHK Document 491 Filed 07/27/26 Page 4 of 10 PageID #:\n 12965\n\n\n\n B. The Defendant Cryptocurrency Is Property of Iran Through the Iran-China\n Group.\n\n As extensively documented in the Fritz Victims\u2019 Complaint and attachment motion papers,\n\n the Defendant Cryptocurrency\u2014approximately 127,271 Bitcoin\u2014constitutes blocked assets of\n\n Iran through the Iran-China Group, an agency or instrumentality of Iran. See generally ECF 29.\n\n The Iran-China Group, doing business on the blockchain as Lubian.com or \u201cLuBian,\u201d is\n\n an Iranian joint-stock company that created and operated a cryptocurrency mining pool in Iran\u2019s\n\n Rafsanjan Special Economic Zone. Fritz Compl. \u00b6\u00b6 20, 72-106. Through this mining operation,\n\n the Iran-China Group converted Iranian energy resources into cryptocurrency, enabling Iran to\n\n evade comprehensive U.S. sanctions. Id. \u00b6\u00b6 72-87. Iranian officials have openly acknowledged\n\n that cryptocurrency mining is \u201ca tool for bypassing sanctions\u201d and that \u201cdigital currency is most\n\n efficient during times of sanctions.\u201d Id. \u00b6 77.\n\n The Iran-China Group worked closely with the Iranian government to establish this\n\n operation. LuBian boasted of its \u201cgood local resources in Iran\u201d and \u201cgood relations\u201d with Iran\u2019s\n\n Ministry of Energy, Ministry of Foreign Affairs, \u201cand even the army.\u201d Id. \u00b6 4. The Iran-China\n\n Group built and then donated \u201cmassive\u201d electric infrastructure for the project back to Iran\u2019s state-\n\n owned power company, Tavanir. Id.\n\n Before LuBian\u2019s wallets were hacked in December 2020, LuBian accumulated at least\n\n 127,271 Bitcoin\u2014worth approximately $11.4 billion as of December 2025. Id. \u00b6 108. Under\n\n Iranian law, licensed miners were required to supply their mined cryptocurrency to \u201cchannels\u201d\n\n selected by the Central Bank of Iran or pay industrial taxes of 25% to Iran. Id.\n\n In December 2020, a \u201cwhitehat\u201d hacker breached LuBian\u2019s crypto wallets and stole over\n\n 127,000 Bitcoin. Id. \u00b6\u00b6 109-10. The Iran-China Group\u2014as LuBian\u2014sent numerous messages to\n\n the hacker on the blockchain, claiming ownership of the Bitcoin (calling it \u201cour asset\u201d) and\n\n\n\n 4\n\fCase 1:25-cv-05745-RPK-CHK Document 491 Filed 07/27/26 Page 5 of 10 PageID #:\n 12966\n\n\n\n demanding the hacker \u201ccontact us through 1228btc@gmail.com to discuss the return.\u201d Id.\n\n Eventually, the hacker apparently handed over the keys to the Iran-China Group\u2019s cryptocurrency\n\n wallets to the U.S. government. Id.\n\n C. The Government Initiates Forfeiture Proceedings but Downplays the Iran\n Connection.\n\n On October 14, 2025, the government initiated the instant civil forfeiture action against the\n\n Defendant Cryptocurrency. ECF 1. The government alleges that the Defendant Cryptocurrency\n\n was involved in money-laundering and wire-fraud schemes conducted by Chen Zhi and Prince\n\n Holding Group. Id. \u00b6 15. However, as the Fritz Victims have demonstrated, the government\u2019s\n\n complaint minimizes LuBian\u2019s connection to Iran. Fritz Compl. \u00b6 112 (discussing ECF 1). While\n\n the government acknowledges that LuBian had mining facilities in Iran, it describes LuBian simply\n\n as \u201ca Chinese bitcoin mining operation\u201d\u2014understating the extensive evidence that the Iran-China\n\n Group was an agency or instrumentality of Iran. ECF 1\u00b6 16(u). Indeed, all of the wallets belonged\n\n to and were controlled by LuBian, because all of the addresses in the government\u2019s complaint\n\n initiated messages to the whitehat hacker starting with \u201cMSG from LB [LuBian]\u201d and begging for\n\n the funds to be returned. Fritz Compl. \u00b6 112. The only way to send these messages was by signing\n\n a transaction with a wallet\u2019s private keys\u2014conclusively establishing LuBian\u2019s ownership of the\n\n Defendant Cryptocurrency. Id.\n\n D. Multiple Groups of Iran Judgment Creditors Have Filed Claims and\n Attachment Motions.\n\n Numerous groups of Iran judgment creditors have already filed claims and attachment\n\n motions in this proceeding. On December 29, 2025, the Fritz Victims\u2014nearly 2,300 victims of\n\n state-sponsored terrorism holding more than $23 billion in judgments against Iran, including more\n\n than $9.1 billion in compensatory damages\u2014filed a Notice of Verified Claim and Statement of\n\n Interest. ECF 29. On the same date, the Baxter Victims\u2014holding judgments worth more than $2\n\n\n 5\n\fCase 1:25-cv-05745-RPK-CHK Document 491 Filed 07/27/26 Page 6 of 10 PageID #:\n 12967\n\n\n\n billion, including over $470 million in compensatory damages\u2014filed a similar notice. ECF 30.\n\n The Fritz Victims also filed an emergency motion for ex parte order of attachment on December\n\n 28, 2025, in their related turnover action. Fritz, No. 1:25-cv-07093, ECFs 69, 70. Additional\n\n groups of Iran judgment creditors, including the O\u2019Neill Claimants, Fishbeck Claimants, and\n\n Iranian Terrorism Victims, have also filed claims in this action.\n\n II. The Owens Victims Are Entitled to Attachment Under TRIA and New York Law.\n\n The Owens Victims satisfy every element required for attachment under TRIA. TRIA\n\n \u00a7 201(a) provides:\n\n Notwithstanding any other provision of law \u2026 in every case in which a person has obtained\n a judgment against a terrorist party on a claim based upon an act of terrorism \u2026 the blocked\n assets of that terrorist party (including the blocked assets of any agency or instrumentality\n of that terrorist party) shall be subject to execution or attachment in aid of execution in\n order to satisfy such judgment to the extent of any compensatory damages for which such\n terrorist party has been adjudged liable.\n\n TRIA\u2019s requirements are satisfied here. The Owens Victims hold final judgments against\n\n Iran, a state sponsor of terrorism, Havlish, 152 F.4th at 360, for compensatory damages for acts of\n\n terrorism under 28 U.S.C. \u00a7 1605A. Further, the Iran-China Group d/b/a Lubian.com is an\n\n \u201cinstrumentality\u201d of Iran within the meaning of TRIA. See Kirschenbaum v. 650 Fifth Ave. &\n\n Related Props., 830 F.3d 107, 135 (2d Cir. 2016) (observing that an entity qualifies as an \u201cagency\n\n or instrumentality of a terrorist party\u201d if it \u201c(1) was a means through which a material function of\n\n the terrorist party is accomplished, (2) provided material services to, on behalf of, or in support of\n\n the terrorist party, or (3) was owned, controlled, or directed by the terrorist party.\u201d (cleaned up)).\n\n Indeed, as the Fritz Victims have extensively documented, \u201cIran orchestrated the construction and\n\n operation of the Rafsanjan mine through and in partnership with the Iran-China Group, from which\n\n it derived substantial infrastructural and economic benefits used to avoid sanctions.\u201d Memo. of\n\n Law in Support of Ex Parte Order at 16, Fritz, No. 1:25-cv-07093, ECF 70. Iran \u201c\u2018could not have\n\n\n\n 6\n\fCase 1:25-cv-05745-RPK-CHK Document 491 Filed 07/27/26 Page 7 of 10 PageID #:\n 12968\n\n\n\n carried out\u2019 this project \u2018had it not been\u2019 for the Iran-China Group\u2019s equipment and services in\n\n constructing and operating the mine.\u201d See id. at 16 (quoting Levin v. Bank of N.Y. Mellon, 2019\n\n WL 564341, at *4 (S.D.N.Y. Feb. 12, 2019) (analyzing \u201cmaterial support\u201d).) As such, blocked\n\n assets of the Iran-China Group are subject to attachment in aid of execution to satisfy the Owens\n\n Victims\u2019 judgment.\n\n The Defendant Cryptocurrency here qualifies as a blocked asset. Under TRIA, \u201cblocked\n\n asset[s]\u201d include \u201cany asset seized or frozen by the United States\u201d pursuant to certain sections of\n\n the International Emergency Economic Powers Act (\u201cIEEPA\u201d). TRIA \u00a7 201(d)(2)(A). In 2012,\n\n President Obama issued\u2014pursuant to IEEPA\u2014Executive Order 13,599, blocking \u201c[a]ll property\n\n and interests in property of the Government of Iran\u201d that \u201care in the United States,\u201d \u201ccome within\n\n the United States,\u201d or \u201ccome within the possession or control of any United States person,\n\n including any foreign branch.\u201d 77 Fed. Reg. 6659, 6659 (Feb. 8, 2012) (later codified at 31 C.F.R.\n\n \u00a7\u00a7 510.211, 594.201(a)(5)). Consequently, the Second Circuit has recognized that \u201call assets\n\n belonging to an entity that satisfies Executive Order 13,599\u2019s definition of \u2018Government of Iran\u2019\n\n are automatically blocked.\u201d Kirschenbaum, 830 F.3d at 137. That definition includes both the\n\n Government of Iran and \u201cany ... agency, or instrumentality thereof.\u201d Id. at 120 (quoting 77 Fed.\n\n Reg. at 6660). Because the Iran-China Group is such an agency or instrumentality, the Defendant\n\n Cryptocurrency qualifies as a blocked asset.\n\n In addition to satisfying TRIA\u2019s substantive requirements, the Owens Victims satisfy the\n\n requirements for attachment under New York law. Article 62 of the CPLR, specifically CPLR\n\n \u00a7 6205, authorizes attachment \u201cin aid of execution\u201d for \u201ca party that has been awarded a money\n\n judgment against a foreign state, as defined in 28 United States Code Section 1603, in accordance\n\n with and subject to the limitations of 28 United States Code Section 1610 and other applicable\n\n\n\n\n 7\n\fCase 1:25-cv-05745-RPK-CHK Document 491 Filed 07/27/26 Page 8 of 10 PageID #:\n 12969\n\n\n\n law.\u201d N.Y. CPLR \u00a7 6205. The Owens Victims have obtained money judgments against Iran, which\n\n is \u201ccertainly\u201d a foreign state under 28 U.S.C. \u00a7 1603. Kirschenbaum, 830 F.3d at 125. Furthermore,\n\n to the extent CPLR \u00a7 6212(a)\u2019s requirements apply to post-judgment attachment under Section\n\n 6205, the Owens Victims satisfy those requirements: (1) they have causes of action under TRIA,\n\n (2) \u201cit is probable\u201d that they will succeed on the merits, (3) grounds for attachment exist under\n\n CPLR \u00a7 6201, and (4) there are no known counterclaims, so that \u201cthe amount demanded from the\n\n defendant exceeds all counterclaims known to the plaintiff.\u201d N.Y. CPLR \u00a7 6212(a).\n\n III. TRIA Supersedes the Government\u2019s Forfeiture Claims.\n\n TRIA\u2019s cornerstone is the statute\u2019s broad \u201cnotwithstanding\u201d clause, which aims to \u201cenable\u201d\n\n victims \u201cto execute on\u201d terrorists\u2019 assets by preventing other provisions of law from \u201cbar[ring]\n\n victims\u2019 efforts to enforce [their] judgments.\u201d Ministry of Def. & Support for the Armed Forces of\n\n the Islamic Rep. of Iran v. Elahi, 556 U.S. 366, 391-92 (2009) (Kennedy, J., concurring). That\n\n notwithstanding clause \u201cmak[es] plain that the force of the [statute] extends everywhere\u201d and\n\n \u201c\u2018supersede[s] all other laws.\u2019\u201d Weinstein v. Islamic Rep. of Iran, 609 F.3d 43, 49, 53 (2d Cir. 2010)\n\n (quoting Cisneros v. Alpine Ridge Grp., 508 U.S. 10, 18 (1993)). Accordingly, because it overrides\n\n \u201c\u2018statutory provisions that conflict with the scope of the TRIA,\u2019\u201d TRIA\u2019s notwithstanding clause\n\n necessarily overrides \u201cthe civil-forfeiture statute.\u201d Est. of Levin v. Wells Fargo Bank, N.A., 156\n\n F.4th 632, 643 n.1 (D.C. Cir. 2025) (quoting Greenbaum v. Islamic Rep. of Iran, 67 F.4th 428, 432\n\n (D.C. Cir. 2023)). Thus, under TRIA, the Owens Victims\u2019 interest in the Defendant Cryptocurrency\n\n is superior to the government\u2019s forfeiture claims.\n\n IV. The Owens Victims Are Entitled to Equal Treatment With Other Iran Judgment\n Creditors.\n\n TRIA makes no distinction among categories of terrorism victims\u2014all victims who have\n\n obtained judgments against terrorist parties based on acts of terrorism are entitled to execute on\n\n\n\n 8\n\fCase 1:25-cv-05745-RPK-CHK Document 491 Filed 07/27/26 Page 9 of 10 PageID #:\n 12970\n\n\n\n blocked assets. TRIA \u00a7 201. The Owens Victims satisfy the same legal requirements under TRIA\n\n as the Fritz Victims, Baxter Victims, and other Iran judgment creditors. All of these groups hold\n\n final judgments against Iran based on acts of terrorism, all seek to attach the same Defendant\n\n Cryptocurrency, and all rely on the same statutory framework and factual predicates. Thus, there\n\n is no legal basis for treating the Owens Victims differently from the other Iran judgment creditors\n\n who have already filed claims and attachment motions. Moreover, this Court has indicated that it\n\n will \u201cexercise its docket-management authority to equitably consolidate any requests for writs of\n\n attachment, so that all such claims can be adjudicated in an orderly fashion.\u201d Fritz, No. 1:25-cv-\n\n 07093 (E.D.N.Y. Feb. 2, 2026) (text order). Granting the Owens Victims\u2019 motion alongside the\n\n pending attachment motions would advance this goal by ensuring that all similarly situated Iran\n\n judgment creditors are treated consistently.\n\n Pursuant to 28 U.S.C. \u00a7 983(a) and Rule G, the Owens Victims hereby assert a claim to the\n\n Defendant Cryptocurrency\u2014as the property of an agency or instrumentality of Iran\u2014that is senior\n\n to the government\u2019s claim. Notwithstanding the government\u2019s forfeiture efforts, the Owens\n\n Victims reserve all rights and remedies available in law and equity to enforce their interest in the\n\n Defendant Cryptocurrency.\n\n Dated: July 27, 2026 Respectfully submitted,\n\n /s/ Matthew V.H. Noller\n Matthew V.H. Noller (No. 5288998)\n KING & SPALDING LLP\n 50 California Street, Suite 3300\n San Francisco, CA 94111\n (415) 318-1200\n mnoller@kslaw.com\n\n Matthew D. McGill\n KING & SPALDING LLP\n 1700 Pennsylvania Avenue NW\n Suite 900\n Washington DC 20006\n\n\n 9\n\fCase 1:25-cv-05745-RPK-CHK Document 491 Filed 07/27/26 Page 10 of 10 PageID\n #: 12971\n\n\n\n (202) 737-0500\n matthew.mcgill@kslaw.com\n\n Attorneys for Owens, Gunn, Khaliq,\n Mwila, and Taitt Claimants\n\n Craig Carlson\n THE CARLSON LAW FIRM\n 100 E Central Texas Expressway\n Killeen, TX 76541\n (254) 526-5688\n\n Attorney for Gunn and Taitt Claimants\n\n\n\n\n 10\n\f","ocr_status":2,"date_upload":"2026-07-27T18:22:49.050470-07:00","document_number":"491","attachment_number":null,"pacer_doc_id":"123024014137","is_available":true,"is_free_on_pacer":null,"is_sealed":false,"document_type":1,"description":"Claim","acms_document_guid":""},{"resource_uri":"https://www.courtlistener.com/api/rest/v4/recap-documents/487749624/","id":487749624,"tags":[],"absolute_url":"/docket/71639393/491/1/united-states-v-approximately-127271-bitcoin-btc-previously-stored-at/","date_created":"2026-07-27T18:22:50.015540-07:00","date_modified":"2026-08-14T21:41:08.679028-07:00","sha1":"a9bfed66f18f3bef3ad5d0461dd732a316a19cd4","page_count":2,"file_size":136774,"filepath_local":"recap/gov.uscourts.nyed.537552/gov.uscourts.nyed.537552.491.1.pdf","filepath_ia":"https://archive.org/download/gov.uscourts.nyed.537552/gov.uscourts.nyed.537552.491.1.pdf","ia_upload_failure_count":null,"thumbnail":null,"thumbnail_status":0,"plain_text":"Case 1:25-cv-05745-RPK-CHK Document 491-1 Filed 07/27/26 Page 1 of 2 PageID\n #: 12972\n\n\n\n IN THE UNITED STATES DISTRICT COURT\n EASTERN DISTRICT OF NEW YORK\n\n\n\n UNITED STATES OF AMERICA, et al.,\n\n Plaintiffs,\n\n v.\n\n APPROXIMATELY 127,271 BITCOIN (\u201cBTC\u201d) Civil Action No. 1:25-cv-05745 (RPK)\n PREVIOUSLY STORED AT THE VIRTUAL\n CURRENCY ADDRESSES LISTED IN\n ATTACHMENT A, AND ALL PROCEEDS\n TRACEABLE THERETO,\n\n Defendant In Rem.\n\n\n\n VERIFICATION OF OWENS VICTIMS\u2019 CLAIMS\n\n I, Matthew V.H. Noller, hereby declare under penalty of perjury pursuant to 28 U.S.C.\n\n \u00a7 1746 and C.P.L.R. \u00a7 3020, that the following is true and correct:\n\n 1. I am a counsel at the law firm of King & Spalding LLP, in San Francisco, CA. I am admitted\n\n to the New York State Bar and the bar of this Court.\n\n 2. I represent the Owens, Mwila, Khaliq, Gunn, and Taitt Claimants (\u201cOwens Victims\u201d) in\n\n the instant action.\n\n 3. All statements in this claim are within the personal knowledge of myself and other counsel\n\n for the Owens Victims, and are reflected in the official dockets of this court and the U.S. District\n\n Court for the District of Columbia.\n\n 4. The Owens Victims all hold judgments against the Islamic Republic of Iran (\u201cIran\u201d) for its\n\n sponsorship of terrorist attacks in which they or their family members are victims. Together, the\n\n Owens Victims hold $3,651,185,548.66 in judgments against Iran, including $1,127,438,601.27 in\n\n compensatory damages.\n\fCase 1:25-cv-05745-RPK-CHK Document 491-1 Filed 07/27/26 Page 2 of 2 PageID\n #: 12973\n\n\n\n 5. Attached hereto as Attachment A is a verified list of all of the Owens Victims, the\n\n judgments they have been awarded against Iran for its sponsorship of terrorism, and the\n\n compensatory damages awarded in those judgments.\n\n 6. As detailed by the Fritz Claimants (ECF 29), the 127,271 Bitcoin that constitute the\n\n Defendant Cryptocurrency in this action belong to the Iran and China Investment Development\n\n Group (\u201cIran-China Group\u201d), doing business as Lubian.com or LuBian. The Iran-China Group is\n\n an agency or instrumentality of Iran. Accordingly, its assets are blocked by the operation of U.S.\n\n law. See Exec. Order No. 13,599, 77 Fed. Reg. 6659, 6659 (Feb. 8, 2012).\n\n 7. To preserve the Owens Victims\u2019 ability to pursue execution and turnover of the Defendant\n\n Cryptocurrency, on behalf of the Owens Victims pursuant to CPLR 3020(d), I hereby notice and\n\n verify the claims of the Owens Victims against the Defendant Cryptocurrency. Because the\n\n Terrorism Risk Insurance Act allows victims of terrorism with judgments against state sponsors of\n\n terrorism to attach and execute against blocked assets of those terrorist states or their agents or\n\n instrumentalities \u201cnotwithstanding any other provision of law,\u201d TRIA \u00a7 201(a), I hereby notice and\n\n verify the Owens Victims\u2019 superior interests in all of the Defendant Cryptocurrency, or at least so\n\n much as may ultimately be necessary to satisfy the outstanding compensatory damages owed to\n\n the Owens Victims on their judgments, plus post-judgment interest, against Iran.\n\n\n\n Executed on: July 27, 2026\n Washington, D.C.\n /s/ Matthew V.H. Noller\n Matthew V.H. Noller\n\f","ocr_status":2,"date_upload":"2026-07-27T18:22:52.083202-07:00","document_number":"491","attachment_number":1,"pacer_doc_id":"123024014138","is_available":true,"is_free_on_pacer":null,"is_sealed":false,"document_type":2,"description":"Verification of Claim","acms_document_guid":""},{"resource_uri":"https://www.courtlistener.com/api/rest/v4/recap-documents/487749625/","id":487749625,"tags":[],"absolute_url":"/docket/71639393/491/2/united-states-v-approximately-127271-bitcoin-btc-previously-stored-at/","date_created":"2026-07-27T18:22:50.025345-07:00","date_modified":"2026-08-14T21:41:12.099807-07:00","sha1":"54a092249161978942b6cae99ff79c03598f9105","page_count":12,"file_size":313068,"filepath_local":"recap/gov.uscourts.nyed.537552/gov.uscourts.nyed.537552.491.2.pdf","filepath_ia":"https://archive.org/download/gov.uscourts.nyed.537552/gov.uscourts.nyed.537552.491.2.pdf","ia_upload_failure_count":null,"thumbnail":null,"thumbnail_status":0,"plain_text":"Case 1:25-cv-05745-RPK-CHK Document 491-2 Filed 07/27/26 Page 1 of 12 PageID\n #: 12974\n\n\n\n\n Attachment A\n\f Case 1:25-cv-05745-RPK-CHK Document 491-2 Filed 07/27/26 Page 2 of 12 PageID\n #: 12975\n\nCase Judgment Plaintiffs Compensatory Total Outstanding\n Damages Awarded Judgment\n\nTaitt v. Islamic Order, Dkt. 21 Jermaine Adyelott $201,750,000.00 $807,000,000.00\nRepublic of Iran (D.D.C. Mar. 16, 2023) Erik Alton\n1:20-cv-01557-RC Denize Alton-Johnson\n(D.D.C.) Jasmine Baker\n Kristion Belcher\n Miss Belcher\n Angela Brown\n Tayinikia Carlton\n Eugene Carter\n Marlon Carter\n Tiffany Carter\n Toni Carter\n Tyrena Carter\n Lynell Cooper\n Sheila Cooper\n Jakari DeGracia\n Yvette Franklin\n Craig Freeman\n Maia Freeman\n Leonia Graham\n Paul Graham\n Donna Green\n Detarence Harris\n Diquan Jackson\n Jacquez Jackson\n Rodney Jackson\n Ashilia Mack\n Deon Mack\n Tiffany Major\n Keelta Mills\n\f Case 1:25-cv-05745-RPK-CHK Document 491-2 Filed 07/27/26 Page 3 of 12 PageID\n #: 12976\n\nctd. Taitt v. Islamic Bryan Mitchell Sr.\nRepublic of Iran Aaron Morgan\n1:20-cv-01557-RC Osa Neal\n(D.D.C.) Rose Neal\n Deloris O'Neil\n Franklin O'Neil\n Jaja O'Neil\n Marlon O'Neil\n Mary Ousley\n Adrian Payne\n Kenneth Payne\n Nyshantae Payne\n Abigail Prather\n Michael Proctor\n Stephanie Putman\n Tiffany Putman\n Veronica Reese\n Shavar Reynolds\n Angel Simmons\n Alexander Sims\n Isadore Sims\n Taebryanna Sims\n Sean Taitt\n Charrod Taylor\n Tashomba Taylor\n Stafford Tyson\n Mary Ward\n Sherita Ward\nGunn v. Islamic Order, Dkt. 38 Paul Abney $489,000,000.00 $1,956,000,000.00\nRepublic of Iran (D.D.C. Jul. 29, 2024) Connie Albright\n1:21-cv-01187-RC Order, Dkt. 46 Chad Atwood\n(D.D.C.) (D.D.C. Aug. 2, 2024) Lori Austin\n\f Case 1:25-cv-05745-RPK-CHK Document 491-2 Filed 07/27/26 Page 4 of 12 PageID\n #: 12977\n\nctd. Gunn v. Islamic Gina Baenziger\nRepublic of Iran Isabella Beasley\n1:21-cv-01187-RC Kathy Brown\n(D.D.C.) Latoya Brown\n John Buckley III\n Noah Clodfelter\n Brady Costelow\n Dorothy Costelow\n Ethan Costelow\n Joseph Costelow\n Sharla Costelow\n Lauren Crago\n Justin Crowe\n Jamisha Davis\n Carol Dimauro\n Marion Dimauro\n Terry Duff\n Theresa Embry\n Sarah Esquival\n David Francis\n James Francis\n Ronald Francis\n Sandra Francis\n Anton Gunn\n Jamal Gunn\n Jason Gunn\n Mona Gunn\n Dianne Harris\n Rick Harrison\n Kay Johnson\n Eric Kafka\n Jessica Kritzas\n Avinesh Kumar\n\f Case 1:25-cv-05745-RPK-CHK Document 491-2 Filed 07/27/26 Page 5 of 12 PageID\n #: 12978\n\nctd. Gunn v. Islamic Preshilla Kumar\nRepublic of Iran Hannah Latham\n1:21-cv-01187-RC Toni Lewis\n(D.D.C.) Tremane Lide\n Andy Lopez\n Margaret Lopez\n Keith Lorensen\n Lisa Lorensen\n Edward Love\n Dominique McDaniels\n Jeffrey McKee\n Robert McTureous\n Kera Miller\n Ashley Misch\n David Morales\n Elroy Newton\n Christopher Nolf\n Gail Nolf\n Gregory Nolf\n Jaime Owens\n Hugh Palmer\n Etta Parlett\n Leroy Parlett\n Matthew Parlett\n James Parlier\n Chauntavia Peterkin\n Jason Phillips\n Mary Phillips\n Frederica Phoenix\n Keyna Powell\n Sean Powell\n Steven Powell\n Sharon Priepke\n\f Case 1:25-cv-05745-RPK-CHK Document 491-2 Filed 07/27/26 Page 6 of 12 PageID\n #: 12979\n\nctd. Gunn v. Islamic Michael Dillon Pritchard\nRepublic of Iran Corey Reier\n1:21-cv-01187-RC Kevin Roy\n(D.D.C.) Christian Russell\n Michael Russell\n Michelle Russell\n Olivia Rux\n Patricia Ryan\n Matthew Saigger\n Simeona Santiago\n Isley Saunders\n Jacqueline Saunders\n Jocelyn Saunders\n Ryan Schmalz\n Ollesha Smith\n Tracy Smith\n Martin Songer Jr\n Shelly Songer\n Heather Startz\n Jeremy Stewart\n Deborah Swenchonis\n Gary Swenchonis\n Jack Swenson\n Karissa Tandy\n Amelia Thompson\n Dwight Thompson\n Aaron Toney\n Andrea Triplett\n Freddie Triplett\n Kevin Triplett\n Lorrie Triplett\n Savannah Triplett\n Madeline Turlich King\n\f Case 1:25-cv-05745-RPK-CHK Document 491-2 Filed 07/27/26 Page 7 of 12 PageID\n #: 12980\n\nctd. Gunn v. Islamic Jeff Vinneau\nRepublic of Iran Linda Vinneau\n1:21-cv-01187-RC Sean Walsh\n(D.D.C.) Patricia Wibberley\n Thomas Wibberley\n Eric Williams\n Gayla Wilson\n Carl Wingate\n Shalala Wood\nKhaliq v. Republic of Order, Dkt. 25 Rizwan Khaliq $22,000,720.00 $49,761,544.86\nSudan (D.D.C. Nov. 28, 2011) Jenny Christiana Lovblom\n1:10-cv-00356-JDB Imran Khaliq\n(D.D.C.) Order, Dkt. 40 Tehsin Khaliq\n (D.D.C. Mar. 28, 2014)\n Kamran Khaliq\n Imtiaz Bedum\n Irfan Khaliq\n Yasir Aziz\n Naurin Khaliq\nOwens v. Republic of Order, Dkt. 214 James Owens $228,692,953.28 $418,671,363.31\nSudan (D.D.C. Nov. 28, 2011) Estate of Betty Owens Evely\n1:01-cv-02244-JDB Gary Robert Owens\n(D.D.C.) Order, Dkt. 301 Barbara Goff\n (D.D.C. Mar. 28, 2014) Estate of Jesse Nathanael Aliganga\n Leah Ann Colston-Baker\n Order Dkt. 502\n Clara Leah Aliganga\n (D.D.C. Mar. 12, 2026)\n Estate of Julian Leotis Bartley, Jr.\n Estate of Julian Leotis Bartley, Sr.\n Edith Lynn Bartley\n Estate of Gladys Baldwin\n Mary Linda Sue Bartley\n Daniel Briehl\n Gary Cross\n Estate of Jean Rose Dalizu\n\f Case 1:25-cv-05745-RPK-CHK Document 491-2 Filed 07/27/26 Page 8 of 12 PageID\n #: 12981\n\nctd. Owens v. Egambi Fred Kibuhiru Dalizu\nRepublic of Sudan Estate of Gwendolyn Tauwana Garrett\n1:01-cv-02244-JDB Estate of James Herbert Freeman\n(D.D.C.) Estate of Jeanette Ella Marie Goines\n Jewell Patricia Neal\n Estate of Joyce McCray\n June Beverly Freeman\n Lawrence Anthony Hicks\n Lori Elaine Dalizu\n Mangairu Vidija Dalizu\n Estate of Rose Banks Freeman\n Estate of Sheila Elaine Freeman\n Temina Engesia Dalizu\n Estate of Molly Huckaby Hardy\n Brandi Hardy Plants\n Estate of Jane Huckaby\n Lydia Hickey\n Tabitha Carter\n Robert Harris, Executor of the Estate of Laura\n Harris, deceased\n Estate of Leroy Moorefield\n Estate of Rodney Moorefield\n Estate of Roger Moorefield\n Lora Murphy\n Loretta Paxton\n Bettina Gould, Executrix of the Estate of Linda\n Shough, deceased\n Estate of Howard Sparks, Sr.\n Stephen Harding Martin\n Margaret Baker\n Estate of Kenneth Ray Hobson II\n Robert Michael Kirk\n Tara Lia Kavaler\n\f Case 1:25-cv-05745-RPK-CHK Document 491-2 Filed 07/27/26 Page 9 of 12 PageID\n #: 12982\n\nctd. Owens v. Estate of Inez Hirn\nRepublic of Sudan Richard Martin Kavaler\n1:01-cv-02244-JDB Estate of Pearl Daniels Kavaler\n(D.D.C.) Howard Sparks, Jr.\n Estate of Mary Louise Martin\n Estate of Mary Katherine Bradley\n Maya Pia Kavaler\n Michael Ray Sparks\n Estate of Kenneth Alva Bradley\n James Robert Klaucke\n Robert Kirk, Jr.\n Douglas Norman Klaucke\n Martha Martin Ourso\n Karen Marie Klaucke\n Estate of Kenneth Ray Hobson\n Deborah Hobson-Bird\n Estate of Arlene Bradley Kirk\n Bonnie Sue Hobson\n Estate of Leon Kavaler\n Meghan Elizabeth Hobson\n Gary Lonnquist\n Estate of Kathleen Martin Boellert\n Eloise Hubble\n Estate of Patricia Anne Bradley Williams\n Michael Hawkins Martin\n Estate of Prabhi Guptara Kavaler\n Maisha Kirk Humphrey\n Neil Alan Bradley\n Dennis Arthur Bradley\n William Russell Klaucke\n Katherine Bradley Wright\n Susan Elizabeth Marti Bryson\n Estate of Howard Charles Kavaler\n\f Case 1:25-cv-05745-RPK-CHK Document 491-2 Filed 07/27/26 Page 10 of 12 PageID\n #: 12983\n\nctd. Owens v. Estate of Clyde M. Hirn\nRepublic of Sudan Paul Hirn\n1:01-cv-02244-JDB Estate of Joseph Denegre Martin III\n(D.D.C.) Estate of Joseph Denegre Martin, Jr.\n Patricia K. Fast\n Estate of Sherry Lynn Olds\n Kimberly Ann Zimmerman\n Serpil Buyuk\n James Paul O\u2019Connor\n Jennifer Erin Perez\n Tara Colleen O\u2019Connor\n Jon B. Pressley\n Christa Gay DeGracia\n Berk F. Pressley\n Frank B. Pressley, Jr.\n Gwendolyn Frederic Deney\n Marsey Gayle Cornett\n Micaela Ann O\u2019Connor\n Estate of Montine Bowen\n Delbert Raymond Olds\n Michael F. Pressley\n Tulay Buyuk\n Estate of Frank Pressley, Sr.\n Estate of Ann Michelle O\u2019Connor\n Sundus Buyuk\n Ahmet Buyuk\n Estate of Mary Evelyn Freeman Olds\n Thomas C. Pressley\n Dorothy Willard\n David A. Pressley\n Marc Y. Pressley\n Bahar Buyuk\n Yasemin B. Pressley\n\f Case 1:25-cv-05745-RPK-CHK Document 491-2 Filed 07/27/26 Page 11 of 12 PageID\n #: 12984\n\nctd. Owens v. Gary Spiers\nRepublic of Sudan Richard David Patrick\n1:01-cv-02244-JDB Estate of Donald G. Bomer\n(D.D.C.) Linda Whiteside O\u2019Donnell\n Worley Lee Reed\n Estate of Patricia Feore\n Estate of Flossie Varney\n Victoria Q. Spiers\n Bret W. Reed\n Joyce Reed\n Victoria J. Spiers\n Michael James Cormier\n Estate of Ruth Ann Whiteside\n Cheryl L. Blood\n Ellen Richard\nJudith Abasi Mwila, Order, Dkt. 30 Abdul Shabani Mtuyla $185,994,927.99 $419,752,640.49\net al, v. the Islamic (D.D.C. Nov. 30, 2011) Saidi Shabani Mtuyla\nRepublic of Iran Estate of Mtendeje Rajabu Mtulya\n1:08-cv-01377-JDB Order, Dkt. 88 Shabani Saidi Mtulya\n(D.D.C.) (D.D.C. Mar. 28, 2014) Upendo Ramadhani\n Halima Ndange\n Happiness Abasi Mwila\n Estate of Yusuf Shamte Ndange\n Estate of William Abbas Mwila\n Mwajabu Yusuph Shamte Ndange\n Hanuni Ramadhani Ndange\n Maua Ndange\n Ramadhani Ndange\n Estate of Dotio Ramadhani\n Elisha Donti Mwaipape\n Kulwa Ramadhani\n Renema Ramadhani\n Donti Akili Mwaipape\n\f Case 1:25-cv-05745-RPK-CHK Document 491-2 Filed 07/27/26 Page 12 of 12 PageID\n #: 12985\n\nctd. Judith Abasi Mengo Ramadhani\nMwila, et al, v. the William Abasi Mwila\nIslamic Republic of Edwina Abasi Mwila\nIran Juma Yusuph Shamte Ndange\n1:08-cv-01377-JDB Abdul Yusuph Shamte Ndange\n(D.D.C.)\n Estate of Victoria Donti Mwaipape\n Nicholas Mwaipape\n Judith Abasi Mwila\n Joseph Donti Mwaipape\n John Rogath Saidi\n Estate Adabeth Saidi Nang\u2019oko\n Estate of Rogath Saidi Saidi\n Eric Mathew Rutaheshelwa\n Edward Mathew Rutaheshelwa\n Idifonce Rogath Saidi\n Happiness Mathew Rutaheshelwa\n Estate of Veronica Alois Saidi\n Selinia Rogath Saidi\n Daniel Rogath Saidi\n Estate of Aisha Mawazo\n Angelina Mathew Rutaheshelwa\n Elizabeth Mathew Rutaheshelwa\n Coronella Samuel Marcus\n Estate of Samuel Thomas Marcus\n Venant Valentine Mathew Katunda\n Diana Valentine Katunda\n Valentine Mathew Katunda\n Edwin Valentine Mathew Katunda\n Desidery Valentine Mathe Katunda\n Abella Valentine Katunda\nTotal $1,127,438,601.27 $3,651,185,548.66\n\f","ocr_status":1,"date_upload":"2026-07-27T18:22:54.472178-07:00","document_number":"491","attachment_number":2,"pacer_doc_id":"123024014139","is_available":true,"is_free_on_pacer":null,"is_sealed":false,"document_type":2,"description":"Attachment A - List of Owens Claimants","acms_document_guid":""}],"date_created":"2026-07-27T18:22:48.780701-07:00","date_modified":"2026-07-30T22:13:03.884078-07:00","date_filed":"2026-07-27","time_filed":"21:21:41","entry_number":491,"recap_sequence_number":"2026-07-27.003","pacer_sequence_number":3399,"description":"CLAIM / VERIFIED CLAIM AND STATEMENT OF INTEREST OR RIGHT IN PROPERTY SUBJECT TO FORFEITURE IN REM by Owens Claimants. (Attachments: # 1 Verification of Claim, # 2 Attachment A - List of Owens Claimants) (Noller, Matthew) (Entered: 07/27/2026)","tags":[]},{"resource_uri":"https://www.courtlistener.com/api/rest/v4/docket-entries/472319375/","id":472319375,"docket":"https://www.courtlistener.com/api/rest/v4/dockets/71639393/","recap_documents":[{"resource_uri":"https://www.courtlistener.com/api/rest/v4/recap-documents/487749153/","id":487749153,"tags":[],"absolute_url":"/docket/71639393/490/united-states-v-approximately-127271-bitcoin-btc-previously-stored-at/","date_created":"2026-07-27T18:14:32.957403-07:00","date_modified":"2026-08-14T22:00:47.537241-07:00","sha1":"45c0d50a290cacdf8ac413beaf264973ba65c192","page_count":2,"file_size":204913,"filepath_local":"recap/gov.uscourts.nyed.537552/gov.uscourts.nyed.537552.490.0.pdf","filepath_ia":"https://archive.org/download/gov.uscourts.nyed.537552/gov.uscourts.nyed.537552.490.0.pdf","ia_upload_failure_count":null,"thumbnail":null,"thumbnail_status":0,"plain_text":"Case 1:25-cv-05745-RPK-CHK Document 490 Filed 07/27/26 Page 1 of 2 PageID #:\n 12960\n\n King & Spalding LLP\n 50 California Street\n Suite 3300\n San Francisco, CA 94111\n T: +1 415 318 1200\n F: +1 415 318 1300\n kslaw.com\n\n\n Matthew Noller\n Counsel\n T: +1 415 318 1242\n\n mnoller@kslaw.com\n\n\n July 27, 2026\n\n Via CM/ECF\n\n The Honorable Rachel P. Kovner\n United States District Judge\n United States District Court for the\n Eastern District of New York\n 225 Cadman Plaza East - Room 517 North\n Brooklyn, NY 11201\n\n Re: United States of America v. Approximately 127,271 bitcoin (BTC) previously\n stored at the virtual currency addresses listed in Attachment A, and all proceeds\n traceable thereto, No. 1:25-cv-05745-RPK-CHK\n\n Dear Judge Kovner:\n\n I represent the Owens Victims, who are victims of state-sponsored terrorism that have obtained\n final judgments against the Islamic Republic of Iran, including under 28 U.S.C. \u00a7 1605A and its\n predecessor statute, 28 U.S.C. \u00a7 1605(a)(7). The Owens Victims collectively hold judgments\n totaling $3,651,185,548.66, which include $1,127,438,601.27 in compensatory damages.1\n\n I write to respectfully request an extension of time for the Owens Victims to file their attached\n verified claims to the Defendant Cryptocurrency at issue in this action.\n\n Generally, a \u201cmotion to file a late claim against seized property is \u2018governed by the excusable\n neglect standard of\u2019\u201d Federal Rule of Civil Procedure 6. United States v. Real Prop. & Premises\n Located at 26421 Riverrock Way, Santa Clarita, Cal. 91350-3995, 2025 WL 1291658, at *4\n (E.D.N.Y. May 5, 2025) (quoting United States v. Starling, 76 F.4th 92, 100 (2d Cir. 2023)). But\n as this Court noted in this action, in an in rem forfeiture action, the Court may \u201cfor good cause\n set[] a different time by which a claimant may contest the forfeiture by filing a claim.\u201d United\n 1\n See Owens v. Republic of Sudan, No. 1:01-cv-02244 (D.D.C. Nov. 28, 2011), ECF 214; Mwila\n v. Islamic Republic of Iran, No. 1:08-cv-01377 (D.D.C. Nov. 30, 2011), ECF 30; Khaliq v. Republic\n of Sudan, No. 1:10-cv-00356 (D.D.C. Nov. 30, 2011) ECF 25; Taitt v. Islamic Republic of Iran,\n No. 1:20-cv-01557 (D.D.C. Mar. 16, 2023), ECF 21; Gunn v. Islamic Republic of Iran, No. 1:21-\n cv-01187 (D.D.C. Aug. 2, 2024), ECF 46.\n\fCase 1:25-cv-05745-RPK-CHK Document 490 Filed 07/27/26 Page 2 of 2 PageID #:\n 12961\n\n\n July 27, 2026\n Page 2 of 2\n\n States v. Approximately 127,271 bitcoin previously stored at virtual currency addresses listed in\n Attachment A, 2025 WL 3652955, at *1 (E.D.N.Y. Dec. 11, 2025) (quotation marks omitted).\n Further, \u201c[n]umerous courts have held\u2014in the analogous context where the Court extended the\n deadline for a late-filed claim\u2014that where putative claimants have placed the court and the\n government on notice of their interest in the property and their intent to contest the forfeiture,\n courts will grant extensions of time, recognizing both the good-faith effort put forth and the lack\n of prejudice to the government under such circumstances.\u201d Id. (quotation marks omitted).\n\n The Owens Victims only recently became aware of this forfeiture action and the allegations in\n Fritz v. Iran & China Investment Development Group, No. 1:25-cv-07093 (E.D.N.Y.). Moreover,\n despite Rule G(5)\u2019s requirements that it do so, the Government did not provide the Owens Victims\n any direct notice of the action despite being aware of the interests of victims of Iranian terrorism,\n including specifically the interests of the Owens Victims who are approved claimants of the DOJ-\n administered United States Victims of State Sponsored Terrorism Fund. See also Fed. R. Civ. P.\n G(4)(b)(i) (requiring that \u201c[t]he government must send notice of the action and a copy of the\n complaint to any person who reasonably appears to be a potential claimant on the facts known to\n the government before the end of the time for filing a claim under Rule G(5)(a)(ii)(B)\u201d). As a\n result, none of the Owens Victims received direct notice of this forfeiture action.\n\n The Owens Victims acted promptly upon becoming aware of their potential interest in the action,\n and no other parties will be prejudiced by allowing the Owens Victims to file their claims. That is\n because the Court has not yet adjudicated the substantive issues in this action and the Government\n has received timely notice.\n\n Finally, including under the Terrorism Risk Insurance Act, the Owens Victims have the right to\n attach and execute on the property of Iran and its agencies and instrumentalities\u2014including Iran-\n China Group\u2014\u201c[n]otwithstanding any other provision of law.\u201d Pub. L. No. 107-297 \u00a7 201(a), 116\n Stat. 2322 (2002) (codified as 28 U.S.C. \u00a7 1610 (note)). Thus, the Owens Victims have an interest\n in as much of the Defendant Cryptocurrency as may be necessary to satisfy their outstanding\n compensatory damages judgments against Iran, plus post-judgment interest, which interest is\n superior to that of the U.S. Government.\n\n We thank the Court for its attention to this matter.\n\n Respectfully submitted,\n\n /s/ Matthew V.H. Noller\n Matthew V.H. Noller\n\n Counsel for Owens Claimants\n\n cc: All Counsel of Record via CM/ECF\n\f","ocr_status":1,"date_upload":"2026-07-27T18:14:33.227121-07:00","document_number":"490","attachment_number":null,"pacer_doc_id":"123024014112","is_available":true,"is_free_on_pacer":null,"is_sealed":false,"document_type":1,"description":"Extension of Time to File Document","acms_document_guid":""}],"date_created":"2026-07-27T18:14:32.928978-07:00","date_modified":"2026-07-30T22:13:03.867733-07:00","date_filed":"2026-07-27","time_filed":"21:13:34","entry_number":490,"recap_sequence_number":"2026-07-27.002","pacer_sequence_number":3397,"description":"Letter MOTION for Extension of Time to File Verified Claim by Owens Claimants. (Noller, Matthew) (Entered: 07/27/2026)","tags":[]},{"resource_uri":"https://www.courtlistener.com/api/rest/v4/docket-entries/472319283/","id":472319283,"docket":"https://www.courtlistener.com/api/rest/v4/dockets/71639393/","recap_documents":[{"resource_uri":"https://www.courtlistener.com/api/rest/v4/recap-documents/487749052/","id":487749052,"tags":[],"absolute_url":"/docket/71639393/489/united-states-v-approximately-127271-bitcoin-btc-previously-stored-at/","date_created":"2026-07-27T18:07:51.602217-07:00","date_modified":"2026-08-13T23:01:14.232808-07:00","sha1":"94061f964219d9d39855d8795e16b5e4af69caa4","page_count":1,"file_size":111904,"filepath_local":"recap/gov.uscourts.nyed.537552/gov.uscourts.nyed.537552.489.0.pdf","filepath_ia":"https://archive.org/download/gov.uscourts.nyed.537552/gov.uscourts.nyed.537552.489.0.pdf","ia_upload_failure_count":null,"thumbnail":null,"thumbnail_status":0,"plain_text":"Case 1:25-cv-05745-RPK-CHK Document 489 Filed 07/27/26 Page 1 of 1 PageID #:\n 12959\n\n\n\n IN THE UNITED STATES DISTRICT COURT\n EASTERN DISTRICT OF NEW YORK\n\n\n\n UNITED STATES OF AMERICA, et al.,\n\n Plaintiffs,\n\n v.\n\n APPROXIMATELY 127,271 BITCOIN Civil Action No. 1:25-cv-05745 (RPK)\n (\u201cBTC\u201d) PREVIOUSLY STORED AT THE\n VIRTUAL CURRENCY ADDRESSES\n LISTED IN ATTACHMENT A, AND ALL\n PROCEEDS TRACEABLE THERETO,\n\n Defendant In Rem.\n\n\n NOTICE OF APPEARANCE OF COUNSEL\n\n PLEASE TAKE NOTICE that I, Matthew V.H. Noller, hereby respectfully enter my\n\n appearance for the Owens Victims in the above-captioned matter. Pursuant to Rule E(8) of the\n\n Supplemental Rules for Admiralty or Maritime Claims and Asset Forfeiture Actions to the Federal\n\n Rules of Civil Procedure, made applicable to forfeiture actions by Supplemental Rule G(1), the\n\n Gold Star Claimants expressly limit their appearance to asserting and defending their claims. I\n\n certify that I am admitted to practice before this Court. All future pleadings, motions, and other\n\n papers filed or served in this action should be served at the address identified below.\n\n Dated: July 27, 2026 Respectfully submitted,\n\n /s/ Matthew V.H. Noller\n Matthew V.H. Noller (No. 5288998)\n KING & SPALDING LLP\n 50 California Street, Suite 3300\n San Francisco, CA 94111\n (415) 318-1200\n mnoller@kslaw.com\n\n Attorney for Owens Claimants\n\f","ocr_status":2,"date_upload":"2026-07-27T18:07:51.947670-07:00","document_number":"489","attachment_number":null,"pacer_doc_id":"123024014105","is_available":true,"is_free_on_pacer":null,"is_sealed":false,"document_type":1,"description":"Notice of Appearance","acms_document_guid":""}],"date_created":"2026-07-27T18:07:51.574096-07:00","date_modified":"2026-07-30T22:13:03.852968-07:00","date_filed":"2026-07-27","time_filed":"21:06:29","entry_number":489,"recap_sequence_number":"2026-07-27.001","pacer_sequence_number":3393,"description":"NOTICE of Appearance by Matthew Vincent Hamilto Noller on behalf of Owens Claimants (aty to be noticed) (Noller, Matthew) (Entered: 07/27/2026)","tags":[]},{"resource_uri":"https://www.courtlistener.com/api/rest/v4/docket-entries/472094053/","id":472094053,"docket":"https://www.courtlistener.com/api/rest/v4/dockets/71639393/","recap_documents":[{"resource_uri":"https://www.courtlistener.com/api/rest/v4/recap-documents/487515849/","id":487515849,"tags":[],"absolute_url":"/docket/71639393/488/united-states-v-approximately-127271-bitcoin-btc-previously-stored-at/","date_created":"2026-07-24T14:33:08.162994-07:00","date_modified":"2026-08-14T19:23:18.151934-07:00","sha1":"bad64577951668367bc6e5f895abb80d79b531a5","page_count":2,"file_size":156081,"filepath_local":"recap/gov.uscourts.nyed.537552/gov.uscourts.nyed.537552.488.0.pdf","filepath_ia":"https://archive.org/download/gov.uscourts.nyed.537552/gov.uscourts.nyed.537552.488.0.pdf","ia_upload_failure_count":null,"thumbnail":null,"thumbnail_status":0,"plain_text":"Case 1:25-cv-05745-RPK-CHK Document 488 Filed 07/24/26 Page 1 of 2 PageID #:\n 12957\n U.S. Department of Justice\n\n\n United States Attorney\n Eastern District of New York\n\n AFM:ADR 271 Cadman Plaza East\n F. #2024R00105 Brooklyn, New York 11201\n\n\n\n July 24, 2026\n By ECF\n\n The Honorable Clay H. Kaminsky\n United States Magistrate Judge\n Eastern District of New York\n 225 Cadman Plaza East\n Brooklyn, New York 11201\n\n Re: United States v. Approximately 127,271 Bitcoin\n Civil Docket No. 25-5745 (RPK) (CHK)\n\n Dear Judge Kaminsky:\n\n The government respectfully submits this letter in further support of its objections\n to the designation of certain information as Confidential Discovery Material by claimants Chen\n Zhi (\u201cChen\u201d) and Prince Holding Group (\u201cPrince Group\u201d). See ECF No. 470 (\u201cGov. Objections\u201d).\n For the reasons set forth in that submission, certain of the designations are improper and the Court\n should direct that the redacted information be unsealed. Contrary to counsel\u2019s assertions, see ECF\n No. 479 (\u201cBSF Letter\u201d), the government has not taken inconsistent positions with respect to\n confidentiality designations.\n\n First, counsel argues that the government\u2019s objection to sealing the names of\n Chen\u2019s alleged attorneys-in-fact is inconsistent with its position on claimant Lubian\u2019s sealing of\n the identity of the signatory to its claim. Of course, Lubian\u2019s sealing motion, see ECF No. 78, was\n submitted ex parte and under seal and granted by the Court the following day. The government\n had no opportunity to review or take any position at all on that motion and does not know the bases\n for whatever requests were made in it (as Boies Schiller apparently does).\n\n Second, counsel argues that the government has taken a different position on\n designations by Chen and Prince Group than it did on designations by Warp Data. Again, this is\n incorrect. As the government wrote in its initial letter objecting to Chen\u2019s and Prince Group\u2019s\n designations, \u201cthe government limit[ed] its objections to designated information that is referenced,\n and thus currently redacted, in the government\u2019s motion to compel. The government reserves the\n right to make additional objections to other designations in Chen\u2019s and Prince Group\u2019s\n interrogatory responses should they be referenced in future filings.\u201d Gov. Objections at 1 n.2. The\n government took the same approach with Warp Data, however neither Warp Data\u2019s nor the\n government\u2019s briefs litigating Warp Data\u2019s Rule G(6) compliance contained any redacted\n information. Should that change in future filings, the government will provide its position on any\n redactions to the Court, pursuant to the Protective Order.\n\fCase 1:25-cv-05745-RPK-CHK Document 488 Filed 07/24/26 Page 2 of 2 PageID #:\n 12958\n\n\n\n In the meantime, there remains no basis for Chen\u2019s and Prince Group\u2019s counsel to\n redact information about Lubian\u2019s role in their \u201ccryptocurrency storage practices.\u201d BSF Letter at\n 2. Nor does any of the redacted information speak to any \u201cbusiness relationships\u201d or \u201cfinancial\n arrangements\u201d with Lubian as counsel claims, BSF Letter at 2, despite the government\u2019s requests\n for that very information. And to the extent the redacted information reveals \u201cthe factual basis for\n [Chen\u2019s and Prince Group\u2019s] asserted interests in the Defendant Cryptocurrency,\u201d id., that is not\n by itself a basis to designate it as \u201csensitive commercial information\u201d under the Protective Order.\n To the contrary, that provides all the more reason to make it viewable by the public and by other\n claimants in this action. Tellingly, counsel provides no authority for that unusual position.\n\n Respectfully submitted,\n\n JOSEPH NOCELLA, JR.\n United States Attorney\n\n By: /s/\n Alexander F. Mindlin\n Andrew D. Reich\n Benjamin Weintraub\n Alessandra V. Rafalson\n Tanisha R. Payne\n Assistant U.S. Attorneys\n (718) 254-7000\n\n Christopher B. Brown\n Supervisory Trial Attorney\n National Security Cyber Section\n National Security Division\n U.S. Department of Justice\n\n\n cc: Clerk of Court (CHK)\n Counsel of Record\n\n\n\n\n 2\n\f","ocr_status":2,"date_upload":"2026-07-24T14:33:08.681693-07:00","document_number":"488","attachment_number":null,"pacer_doc_id":"123024008129","is_available":true,"is_free_on_pacer":null,"is_sealed":false,"document_type":1,"description":"Reply in Support","acms_document_guid":""}],"date_created":"2026-07-24T14:33:08.091888-07:00","date_modified":"2026-07-30T22:13:03.835834-07:00","date_filed":"2026-07-24","time_filed":"17:32:26","entry_number":488,"recap_sequence_number":"2026-07-24.003","pacer_sequence_number":3390,"description":"REPLY in Support re 470 Letter Objecting to Chen Zhi's and Prince Group's Confidential Discovery Designations filed by United States of America. (Reich, Andrew) (Entered: 07/24/2026)","tags":[]},{"resource_uri":"https://www.courtlistener.com/api/rest/v4/docket-entries/472068116/","id":472068116,"docket":"https://www.courtlistener.com/api/rest/v4/dockets/71639393/","recap_documents":[{"resource_uri":"https://www.courtlistener.com/api/rest/v4/recap-documents/487489319/","id":487489319,"tags":[],"absolute_url":"/docket/71639393/487/united-states-v-approximately-127271-bitcoin-btc-previously-stored-at/","date_created":"2026-07-24T12:21:53.026265-07:00","date_modified":"2026-08-14T18:54:16.451994-07:00","sha1":"63b2441892ec6e796090623d1d7c217e44988713","page_count":11,"file_size":934574,"filepath_local":"recap/gov.uscourts.nyed.537552/gov.uscourts.nyed.537552.487.0.pdf","filepath_ia":"https://archive.org/download/gov.uscourts.nyed.537552/gov.uscourts.nyed.537552.487.0.pdf","ia_upload_failure_count":null,"thumbnail":null,"thumbnail_status":0,"plain_text":"Case 1:25-cv-05745-RPK-CHK Document 487 Filed 07/24/26 Page 1 of 11 PageID #:\n 12946\n U.S. Department of Justice\n\n\n United States Attorney\n Eastern District of New York\n\n AFM:ADR 271 Cadman Plaza East\n F. #2024R00105 Brooklyn, New York 11201\n\n\n\n July 24, 2026\n By ECF\n\n The Honorable Clay H. Kaminsky\n United States Magistrate Judge\n Eastern District of New York\n 225 Cadman Plaza East\n Brooklyn, New York 11201\n\n Re: United States v. Approximately 127,271 Bitcoin\n Civil Docket No. 25-5745 (RPK) (CHK)\n\n Dear Judge Kaminsky:\n\n The government respectfully submits this reply in support of its motion to compel\n claimants Chen Zhi (\u201cChen\u201d) and Prince Holding Group (\u201cPrince Group\u201d) to comply with the\n government\u2019s special interrogatories. See ECF No. 468 (\u201cGov. Mot.\u201d). Boies Schiller\u2019s\n opposition on behalf of a shifting roster of purported clients and client surrogates asks this Court\n to ignore threshold deficiencies in its responses and to disregard the law and the Court\u2019s own order\n setting forth the obligations of putative claimants in this case. See ECF No. 478 (\u201cBSF Opp.\u201d).\n Moreover, counsel\u2019s repeated claim that Chen need not comply with Rule G(6) is fundamentally\n incorrect. Chen and Prince Group are not exempt from the rules. The Court should compel them\n to adequately respond to the government\u2019s basic inquiries, just as it did Warp Data, see ECF No.\n 472 (\u201cJuly 7 Order\u201d), and just as all claimants must do.\n\n I. Chen Is Not Exempt From Rule G(6)\u2019s Obligations\n\n To begin with, as argued in the government\u2019s motion, Chen is not somehow exempt\n from the obligations of Rule G(6) simply because he is alleged to have previously possessed the\n Defendant Cryptocurrency. See Gov. Mot. at 7 (citing cases). \u201cA claimant asserting a possessory\n interest . . . must at the motion to dismiss stage \u2018offer some \u201cfactual allegations regarding how the\n claimant came to possess the property, the nature of the claimant\u2019s relationship to the property,\n and/or the story behind the claimant\u2019s control of the property.\u201d\u2019\u201d United States v. $1,106,775.00\n in United States Currency, 177 F.4th 986, 992 (9th Cir. 2026) (quoting United States v.\n $133,420.00 in U.S. Currency, 672 F.3d 629, 638 (9th Cir. 2012)). 1 Moreover, even where a\n claimant meets his burden of establishing standing at the motion to dismiss stage (and Chen has\n 1\n Boies Schiller\u2019s opposition focuses heavily on this recent Ninth Circuit decision\n but misrepresents its holdings. As discussed in further detail below, $1,106,775.00 only further\n supports the government\u2019s motion to compel proper responses.\n\fCase 1:25-cv-05745-RPK-CHK Document 487 Filed 07/24/26 Page 2 of 11 PageID #:\n 12947\n\n\n\n not), \u201cthe government could still tee up a challenge to his stated basis for standing. The\n government need not accept [the claimant\u2019s] claim of ownership at face value. Instead, it is entitled\n to investigate [the claimant\u2019s] factual account to see if it holds up . . . including through reasonable\n use of Rule G(6) interrogatories.\u201d Id. at 997.\n\n Indeed, Rule G(6) \u201cbroadly allows the government to collect information regarding\n the claimant\u2019s \u2018relationship to the defendant property.\u2019\u201d Id. (quoting $133,420.00, 672 F.3d at 642\n and Supp. R. G(6)(a)). And, even where \u201ca claimant asserts an ownership interest,\u201d as Chen does\n as to some undisclosed portion of the Defendant Cryptocurrency, \u201cthe government can still probe\n the veracity of his claim . . . through Rule G(6) interrogatories.\u201d Id. (cleaned up). As the Ninth\n Circuit explained:\n\n [The claimant\u2019s] unequivocal assertion of ownership and the fact\n that he possessed the money when seized would establish standing\n so long as the government did not further contest the point. But the\n government can subject [the claimant\u2019s] representations to the\n crucible of the discovery process in an effort to show why his\n narrative is unsupported and why he thus lacks standing . . . . [I]n a\n case like this one, where the government intends to dispute the core\n facts underlying the claimant\u2019s assertion of standing, Rule G(6)\n interrogatories are still fair game.\n\n $1,106,775.00, 177 F.4th at 997-98 (cleaned up) (citing United States v. 17 Coon Creek Rd., 787\n F.3d 968, 978 n.4 (9th Cir. 2015) (noting that the government is entitled to adversarial testing of a\n claimant\u2019s continued standing) and United States v. Funds in the Amount of $574,840, 719 F.3d\n 648, 652 (7th Cir. 2013) (\u201cIt is always open to a party to contest standing by proving facts that\n contradict his opponent\u2019s allegations of standing.\u201d)).\n\n Thus, Chen\u2019s prior access to the Defendant Cryptocurrency does not erase his\n obligation to describe the nature of his claim and to be held to those answers. As discussed in the\n government\u2019s motion, Chen\u2019s claim and purported interrogatory responses assert multiple vague\n and incompatible theories of ownership that will shape the litigation going forward, including an\n alleged bailment on behalf of Prince Group and some arrangement by which\n Each theory sets a different path for this litigation.\n The point of the verification requirement is that Chen himself must pick a story and swear that it\n is true. His counsel cannot proceed on multiple theories and pick the most advantageous one down\n the line. 2 See United States v. Two Hundred Seventy-Two Thousand Dollars & No Cents\n ($272,000), No. 16-CV-06564 (AMD), 2017 WL 8780158, at *3 (E.D.N.Y. Oct. 26, 2017)\n (interrogatories may broadly inquire into any matter necessary \u201cto test the veracity of the\n\n 2\n Boies Schiller\u2019s own filing asserts that questions around standing in this case are\n open and shut because Chen possessed the private keys to access the cryptocurrency wallets\n containing the Defendant Bitcoin, see BSF Opp. at 9, and that whoever has the private keys to\n access a digital asset \u201ccontrols that asset,\u201d id. at 10. But the filing simultaneously concedes that\n also had access to the wallets, raising more questions than it answers. See id. at\n 16; see also Chen Response No. 4.\n\n\n 2\n\fCase 1:25-cv-05745-RPK-CHK Document 487 Filed 07/24/26 Page 3 of 11 PageID #:\n 12948\n\n\n\n claimant\u2019s claim of ownership and interest\u201d (cleaned up)). Indeed, Boies Schiller\u2019s \u201cnarrow\n construction of Rule G(6) [is] untenable because it would make the requirements of Rule G(6)\n coextensive with what is already required for the claim itself under Rule G(5).\u201d $1,106,775.00,\n 177 F.4th at 997.\n\n Nor does United States v. Technodyne LLC, 753 F.3d 368 (2d Cir. 2014), relied on\n by Boies Schiller, suggest otherwise, as the Court has already determined. See July 7 Order at 6-\n 7 (finding Warp Data\u2019s reliance on Technodyne \u201cunpersuasive\u201d). Technodyne addressed a\n claimant\u2019s burden under the fugitive disentitlement doctrine, a separate issue. The Second Circuit\n panel separately observed in dicta that \u201c[t]he record in the present case\u201d suggested that standing\n was not an issue because the government had not alleged that the claimants had failed to comply\n with Rule G, and because the government\u2019s complaint alleged that the claimants owned the\n defendant properties and held them in their names. 753 F.3d at 380. Here, unlike in Technodyne,\n the government does allege that Chen failed to comply with Rule G, and his own claim and\n purported interrogatory responses demonstrate that the competing ownership allegations in this\n case are much more complicated and unclear than those in Technodyne. See July 7 Order at 6\n (observing that \u201cthere is at least a genuine question as to who (or what) was truly injured by the\n seizure of the Defendant Bitcoin\u201d).\n\n Thus, whether or not \u201callegations set forth in a civil forfeiture complaint may\n establish standing on its face,\u201d July 7 Order at 5 (emphasis added), that is clearly not the case here.\n Nor, even if it were, does that absolve Chen from providing sworn admissions about the nature of\n his claim in response to special interrogatories by the government, as described above. Boies\n Schiller knows this, or it would not have provided reams of unresponsive and inadequate answers\n to the government\u2019s interrogatory requests in the first instance and convinced two individuals to\n sign them. Its assertion that the government\u2019s interrogatories are \u201c[u]nenforceable,\u201d BSF Opp. at\n 9, is belied by its own actions and the law. 3\n\n II. Boies Schiller\u2019s Submission in Chen\u2019s Name is Improper\n\n Boies Schiller concedes that, following his extradition to China, Chen has been (and\n continues to be) \u201cunavailable to review and execute discovery responses.\u201d BSF Opp. at 19. As a\n result, Boies Schiller created its own responses without Chen\u2019s input or sworn verification. As the\n government argued in its motion, these purported responses on behalf of Chen are not Chen\u2019s\n responses and are improper. See Gov. Mot. at 5-7. These are not ministerial requirements.\n Instead, they are fundamental to the litigation and serve critical functions that cannot be satisfied\n\n 3\n Boies Schiller also appears to argue that because Chen is the defendant in parallel\n criminal proceedings, the government is foreclosed from inquiring into the nature of his standing\n here. Of course, that is incorrect. Civil forfeiture actions are frequently brought in tandem with\n criminal cases, particularly where the same alleged crimes and criminal proceeds are at issue, and\n criminal defendants are therefore frequently claimants in those actions. As with any other\n claimant, they still must comply with Rule G, and Boies Schiller does not provide any authority\n suggesting otherwise. Nor is the government having it \u201cboth ways,\u201d BSF Opp. at 11, by asserting\n forfeiture allegations against funds previously controlled by Chen and then seeking Rule G(6)\n discovery from him and other claimants. This is, in fact, what Rule G prescribes.\n\n\n 3\n\fCase 1:25-cv-05745-RPK-CHK Document 487 Filed 07/24/26 Page 4 of 11 PageID #:\n 12949\n\n\n\n by the purported verification of counsel or attorneys-in-fact (much less by alleged attorneys-in-\n fact for whom no evidence has been provided of their appointment). 4 See id.\n\n The importance of Rule 33\u2019s requirements is reflected in courts\u2019 pattern of strict\n adherence to them. It simply is not the case that \u201ccourts regularly allow a party\u2019s agent to verify\n interrogatory responses where, as here, that party is unavailable.\u201d BSF Opp. at 2. Instead, courts\n routinely emphasize that inability to reach a client does not justify exceptions to Rule 33\u2019s answer,\n signature and verification requirements. See Gov. Mot. at 6 (citing cases); see also McDougall v.\n Dunn, 468 F.2d 468, 472 (4th Cir. 1972) (\u201cNor is the requirement of the Rule to be relaxed merely\n because of difficulties relating to the availability of the party.\u201d); In re CCA Recordings 2255 Litig.\n v. United States, No. 19-CV-2491, 2021 WL 63281, at *1 (D. Kan. Jan. 6, 2021) (\u201cRule 33 makes\n no exception where a party is unavailable to sign his or her answers.\u201d); Lackey v. SDT Waste &\n Debris Servs., No. 11-CV-1087, 2013 WL 5772325 at *10 (E.D. La. Oct. 23, 2013) (\u201cDeviation\n from this rule is almost never granted.\u201d).\n\n The cases cited by Boies Schiller do not suggest any other outcome. For example,\n citing Fyodorova v. National Enquirer, Inc., 89 F.R.D. 68 (S.D.N.Y. 1981), Boies Schiller asserts\n that \u201cexigent circumstances\u201d warrant bypassing Rule 33\u2019s requirements. See BSF Opp. at 18-19.\n In Fyodorova, the court approved counsel\u2019s preparation of interrogatory responses while the\n plaintiff was residing in the Soviet Union as an interim measure to expedite the defendant\u2019s\n preparation for an impending trial. See 89 F.R.D. at 69. The court did not waive the plaintiff\u2019s\n obligation to verify her own responses, and instead set a one-month deadline for the plaintiff to do\n so. See id. Fyodorova in no way supports Boies Schiller\u2019s request that the Court accept someone\n else\u2019s responses as Chen\u2019s, and such a request is inconsistent with the law. See also Trueman v.\n N.Y. State Canal Corp., No. 09-CV-049, 2010 WL 681341, at *5 (N.D.N.Y. Feb. 24, 2010) (\u201c[T]he\n answer must remain the party\u2019s and not the attorney\u2019s.\u201d); Lastick v. Bahama Cruise Line, Inc., No.\n 88-CV-3624, 1990 WL 139023, at *5 (S.D.N.Y. 1990) (\u201c[T]he importance of sworn answers given\n upon personal knowledge is obvious.\u201d).\n\n Boies Schiller also relies on a handful of district court cases permitting verification\n by an appointed agent for incompetent parties with acute mental health conditions or dementia.\n See BSF Opp. at 19. To begin with, courts have rightfully identified those cases as extreme outliers\n and have declined to be bound by them outside those rare circumstances. See, e.g., In re CCA\n Recordings, 2021 WL 63281, at *1. More fundamentally, however, if Boies Schiller wishes to\n justify its noncompliance with Rule 33 on the grounds that Chen is analogous to a permanently\n incompetent party because he will never be able to appear in these proceedings, then that raises a\n much broader set of concerns about the future of this litigation and Boies Schiller\u2019s authority to\n pursue a claim. Cf. Wright v. Elton Corp., No. 17-CV-286, 2021 WL 9385092, at *2 (D. Del. Mar.\n\n 4\n The government is currently aware of no basis for the claim that either of the\n individuals identified by Boies Schiller legally hold any sort of power of attorney for Chen beyond\n the bare assertion made in the verification. Boies Schiller incorrectly asserts that the government\n never made any inquiry into these individuals or the source of their alleged authority, but in fact\n the government did that during its April 27, 2026 meet and confer with Boies Schiller. To date,\n the government has not received any supplemental responses by Boies Schiller on this topic (or\n any other).\n\n\n 4\n\fCase 1:25-cv-05745-RPK-CHK Document 487 Filed 07/24/26 Page 5 of 11 PageID #:\n 12950\n\n\n\n 2, 2021) (\u201c[T]he Court suspects that separate and apart from its decision on the interrogatories, a\n broader ruling might be eventually needed in this case as to whether Ms. Wright is competent and\n capable of suing and being sued here[.]\u201d).\n\n Given Chen\u2019s complete lack of involvement in making, signing and verifying the\n interrogatory responses, and the insufficiency of his attorneys\u2019 proposed solution\u2014preparation of\n the answers by parties lacking first-hand knowledge and verification by individuals with unproven\n authority\u2014Rule 33\u2019s mandates remain unsatisfied. The government recognizes that Chen\u2019s\n detention means that his attorneys currently cannot reach him through ordinary channels, but the\n proper solution is not to simply waive Rule 33\u2019s requirements, which are critical to ensuring a\n claimant\u2019s complete, truthful and consistent responses. See Fyodorova, 89 F.R.D. at 69.\n\n Boies Schiller alludes to accommodations such as an extension of time or the\n initiation of unspecified international processes. See BSF Opp. at 19-20. But it has been nearly\n six months since the government served its special interrogatories on Chen and Prince Group.\n Counsel has not identified or initiated any particular procedure, nor asked for an adjournment of\n deadlines, nor provided any proposal to the Court as to how they intend to proceed in this action\n without Chen\u2019s participation (or even his awareness that they are doing so and making\n representations and decisions on his behalf). The Court should order Chen to comply, and if he is\n not able to, then the parties will need to litigate his ability to continue to press a claim in this action.\n\n III. Boies Schiller\u2019s Submissions for Chen and Prince Group Are Otherwise Deficient\n\n Counsel\u2019s vague and inadequate answers illustrate why uninformed third parties\n cannot stand in for sworn fact witnesses. As set forth in the government\u2019s motion, Chen\u2019s and\n Prince Group\u2019s purported responses fail to answer key questions necessary to parsing their claims\n in this action. See Gov. Mot. at 7-12. While the government raised in its motion numerous\n inadequacies in the responses across multiple interrogatories, Boies Schiller focuses on two\n general categories\u2014inquiries about Chen\u2019s and Prince Group\u2019s claims to portions of the Defendant\n Cryptocurrency, and information about Lubian. As described below, these categories are actually\n one and the same. But the government addresses each in turn.\n\n A. Boies Schiller Fails to Provide Adequate Answers to Proper Inquiries About Chen\u2019s\n and Prince Group\u2019s Claimed Interests in the Defendant Cryptocurrency\n\n To begin with, Boies Schiller contends that the government\u2019s inquiries are improper\n because they probe the legitimacy of the manner in which Chen and Prince Group allegedly came\n to own and possess the claimed property. See BSF Opp. at 10. That is incorrect. The government\n has made inquiries to understand and \u201ctest the veracity of the claimant\u2019s claim of ownership and\n interest.\u201d July 7 Order at 4 (citing $272,000, 2017 WL 8780158, at *3 (internal quotation marks\n omitted)). The government does not at this stage question whether the funds were obtained through\n legal and proper means, but rather what those means were in the first instance. That has not been\n sufficiently explained. Nowhere in the responses, including in the \u201cthousands of pages of\n corporate records\u201d provided, BSF Opp. at 7, do Chen and Prince Group explain where the funds\n in any of the 25 virtual currency addresses listed in the Complaint came from. Despite the smoke\n and mirrors from the \u201cextensive\u201d materials provided, the only explanation that Boies Schiller\n offers is the bare, conclusory assertion that \u201c[b]y late 2020, Mr. Chen had acquired a substantial\n\n\n 5\n\fCase 1:25-cv-05745-RPK-CHK Document 487 Filed 07/24/26 Page 6 of 11 PageID #:\n 12951\n\n\n\n amount of bitcoin with the proceeds from the above-described legitimate businesses[.]\u201d BSF Opp.\n at 4. But those business activities go back more than a decade, and Boies Schiller makes no effort\n to actually link, in sworn responses submitted under penalty of perjury, particular funds to the\n funds in the 25 virtual currency addresses that constitute the Defendant Cryptocurrency. Without\n more, Boies Schiller asks the government and the Court \u201cto make a logical leap absent from the\n face of the Complaint,\u201d July 7 Order at 6, and from any other information provided in its\n submissions. 5\n\n Thus, the government\u2019s inquiries into \u201chow the claimant came to possess the\n property\u201d or \u201cthe story behind the claimant\u2019s control of the property\u201d are not merits questions\n probing the legitimacy or the \u201cwhy\u201d behind Chen\u2019s and Prince Group\u2019s alleged accrual of the\n Defendant Cryptocurrency, as Boies Schiller argues. See BSF Opp. at 7-8, 10. Instead, these are\n questions meant to sharpen their sweeping claims of possession and ownership among a sea of\n similar claims. To be sure, there may be overlaps in coverage between questions pertaining to\n standing and those pertaining to the merits of the case. But such overlaps do not make the special\n interrogatories \u201ca substitute for merits discovery.\u201d BSF Opp. at 7. As the Court observed in its\n July 7 Order, \u201c[t]hat some evidence relevant to standing may also ultimately bear on the merits\n question of who owns the [defendant property] does not transform the threshold standing inquiry\n into an improper merits determination.\u201d July 7 Order at 9 (alterations in original) (quoting United\n States v. Khudainatov, 177 F.4th 224, 230 (2d Cir. 2026)). In that Order, the Court squarely\n foreclosed such objections from Warp Data, particularly as to interrogatories inquiring into the\n source of its alleged interest, and the circumstances by which that interest was acquired. See July\n 7 Order at 7-9.\n\n Boies Schiller also argues that Special Interrogatory No. 4 to Chen and Special\n Interrogatory No. 3 to Prince Group are \u201cfacially overbroad\u201d and go \u201cfar beyond Claimants\u2019\n \u2018relationship to the defendant property\u2019 under Rule G(6).\u201d BSF Opp. at 12. Boies Schiller takes\n particular issue with the government\u2019s inquiries into wallets or accounts that the Defendant\n Cryptocurrency originated in or passed through, the identity of individuals or entities that had\n ownership or control of those wallets or accounts (or access to private keys), and the sources that\n funded those wallets or accounts. Id. These objections do not withstand scrutiny. As the Court\n concluded in its July 7 Order, the government\u2019s authority to seek information is broad: \u201cCourts\n\n 5\n Indeed, it is curious that although Chen and Prince Group are assertedly \u201cstill\n attempting to trace the Defendant Cryptocurrency,\u201d Chen Response No. 4, see also Prince Group\n Response No. 3, they can somehow provide sworn representations that the Defendant\n Cryptocurrency is directly derived from these dozens of sources. Boies Schiller asserts that, \u201cfor\n the avoidance of doubt, the sources of funds extensively detailed in Mr. Chen\u2019s responses to\n Interrogatory Nos. 3 and 13 were, in fact, the sources of funds used to purchase the seized bitcoin\n he owned. See Chen Resp. at 17.\u201d BSF Opp. at 12 n.12. Boies Schiller provides no explanation\n for how it could know this, which portions of those profits it means to refer to, or which portions\n of the Defendant Cryptocurrency it means to refer to (as the government noted in its motion, it\n certainly cannot be all of it, since some of it was newly mined). Nor does it explain what\n \u201cpurchase[s]\u201d it is referring to. Rather, it appears that Boies Schiller simply compiled a list of\n every single business venture of Chen\u2019s that it was able to identify, and then summarily represented\n that those are the sources of the Defendant Cryptocurrency. That is not an adequate explanation.\n\n\n 6\n\fCase 1:25-cv-05745-RPK-CHK Document 487 Filed 07/24/26 Page 7 of 11 PageID #:\n 12952\n\n\n\n have routinely approved interrogatories that ask about the circumstances surrounding the\n acquisition of the claimant\u2019s interest, including \u2018when, from whom, where, and how [the claimant]\n acquired [its] interest in the Defendant Funds.\u2019\u201d July 7 Order 7-8 (quoting $272,000, 2017 WL\n 8780158, at *3); see United States v. Real Props., No. 18-CV-9293, 2019 WL 4877490, at *3\n (D.N.J. Oct. 2, 2019) (\u201cCourts have approved special interrogatories that inquire into a claimant\u2019s\n identity, its interest in the defendant property, and the circumstances surrounding its acquisition of\n the defendant property.\u201d). In $272,000, for example, the court upheld an interrogatory asking \u201cthe\n claimant to identify \u2018each and every source from which [she] claim[s] the Defendant Funds was\n derived, including the exact amount of money derived from each source[.]\u201d $272,000, 2017 WL\n 8780158, at *3; see also United States v. $209,815 in U.S. Currency, No. 14-CV-0780, 2015 WL\n 1927431, at *4 (N.D. Cal. Apr. 28, 2015). These inquiries are no less probing than those the\n government makes here. As the Court made clear, the question is whether the information sought\n \u201cis relevant to understanding [the claimant\u2019s] relationship to the defendant property.\u201d July 7 order\n at 8. Indeed, an accounting of the sources that funded the Defendant Cryptocurrency is \u201cespecially\n relevant . . . where claimants assert conflicting claims to the defendant property.\u201d Id. at 9 (citing\n United States v. $70,670.00 in U.S. Currency, No. 15-CV-23616, 2016 WL 233405 (S.D. Fla. Jan.\n 20, 2016)).\n\n Boies Schiller invokes the Ninth Circuit\u2019s recent decision in $1,106,775.00\n primarily for the proposition that courts cannot compel \u201cexhaustive transaction-by-transaction\n details concerning a claimant\u2019s acquisition of seized property.\u201d BSF Opp. at 13; 177 F.4th at 999.\n But this is misleading. For one, as described above, the Ninth Circuit supported the government\u2019s\n authority to propound broad interrogatories into the nature of a claimant\u2019s purported claim.\n Moreover, the claimant in that case did provide additional responses to supplement his inadequate\n initial submission, which contained the very type of information the government seeks from Chen\n and Prince Group. In particular, that claimant \u201cexplained how he earned the [funds in\n question] . . . , what documentation would support his ownership . . . , and where he kept the\n money,\u201d and \u201cprovided the government with the names of the movie companies he received money\n from, a link to his [online] page listing past projects, a Chase Bank account number, and various\n personal identifying information.\u201d $1,106,775.00, 177 F.4th at 998. Thus, under the\n circumstances of that case, the claimant\u2019s \u201cresponses . . . provided the government with a\n sufficient basis for conducting further investigation into his claimed ownership of the money.\u201d Id.\n at 999 (limiting the interrogatories \u201cif the responses already given provide adequate fodder for\n investigation of the claimant\u2019s asserted basis for standing\u201d). In other words, the government in\n that case could reconstruct and verify the claimant\u2019s asserted ownership interest. It simply cannot\n do that here. 6\n\n Central to that inquiry is the government\u2019s request for information regarding the\n specific portions of the Defendant Cryptocurrency Chen and Prince Group claim to own or possess.\n\n 6\n Crucially, $1,106,775.00 involved far simpler circumstances than those present\n here. That was a case with a single claimant that did not involve the sifting and verifying of dozens\n of nuanced claims of possession and/or ownership of non-traditional digital assets stored across a\n series of 25 separate virtual currency addresses accessible from anywhere in the world. The same\n is true of United States v. Funds in the Amount of $574,840, 719 F.3d 648 (7th Cir. 2013), also\n relied on by Boies Schiller.\n\n\n 7\n\fCase 1:25-cv-05745-RPK-CHK Document 487 Filed 07/24/26 Page 8 of 11 PageID #:\n 12953\n\n\n\n Boies Schiller objects to this request. See BSF Opp. at 14. But this Court already firmly rejected\n such challenges in its July 7 Order: \u201cSimilarly proper are the interrogatories that seek information\n about the source and identity of the specific portions of the res [the claimant] is claiming.\u201d July 7\n Order at 8. The Court explained that claimants \u201cmust . . . establish standing over some part of the\n res, and the government is entitled to inquire what part that is.\u201d Id. at 8-9 (citing $272,000, 2017\n WL 8780158, at *3). Such inquiries are appropriate because \u201c[t]his information is directly relevant\n to understanding [the claimant\u2019s] relationship to the defendant property and is especially relevant\n here, where claimants assert conflicting claims to the defendant property.\u201d Id. at 9 (citing United\n States v. $70,670.00 in U.S. Currency, No. 15-CV-23616, 2016 WL 233405 (S.D. Fla. Jan. 20,\n 2016)). 7 Boies Schiller cites United States v. $191,910.00 in U.S. Currency, 16 F.3d 1051, 1058\n (9th Cir. 1994) (which is not a decision about the proper scope of special interrogatories) for the\n uncontroversial proposition that a claimant may assert an ownership interest in a portion of the\n res. BSF Opp. at 14. Of course, as that same court much more recently confirmed, even where \u201ca\n claimant asserts an ownership interest, the government can still probe the veracity of his\n claim . . . through Rule G(6) interrogatories.\u201d $1,106,775.00, 177 F.4th at 997 (cleaned up).\n\n Boies Schiller\u2019s remaining arguments are equally unavailing. Boies Schiller\n contends that it cannot respond to the interrogatories because it lacks information about the\n Defendant Cryptocurrency after December 2020, see BSF Opp. at 12, 14, but this is a red herring.\n The 25 virtual currency addresses identified in the Complaint are the addresses \u201cat which the\n Defendant Cryptocurrency was stored as of December 2020,\u201d Compl. \u00b6 44 n.7, and nowhere in the\n interrogatories does the government seek information from Chen or Prince Group about the\n Defendant Cryptocurrency after that date. Boies Schiller also contends that the government cannot\n compel responses to certain interrogatories because it has already conducted certain tracing in this\n case. See BSF Opp. at 13-14. It cites no authority for this claim, because there is none. Instead it\n relies broadly on a stray provision of Rule 26(b)(1) to the effect that the scope of discovery depends\n in part on \u201cthe parties\u2019 relative access to relevant information.\u201d Id. at 13 (quoting Fed. R. Civ. P.\n 26(b)(1)). Of course, Rule G(6) takes precedence over Rule 26 in determining the scope of special\n interrogatories. See Supp. R. G(1) (noting that the Federal Rules of Civil Procedure only apply\n \u201c[t]o the extent that [Rule G] does not address an issue\u201d). Moreover, Rule 26(b)(1) only weighs\n the parties\u2019 relative access to information as one of multiple factors in determining the scope of\n discovery, including \u201cthe importance of the discovery in resolving the issues.\u201d Fed. R. Civ. P.\n 26(b)(1). Nor is it clear that consideration of \u201cthe parties\u2019 relative access to relevant information\u201d\n favors Chen and Prince Group. The government\u2019s tracing cannot reveal which individuals or\n\n 7\n Boies Schiller also claims that the government\u2019s interrogatories never requested\n this information from them and that therefore \u201cthe government cannot compel such an answer\n now.\u201d BSF Opp. at 14. This is absurd on its face. Information regarding which funds Chen and\n Prince Group claim to have possessed and owned is repeatedly requested throughout the\n government\u2019s special interrogatories, beginning in the government\u2019s request that \u201cfor each of the\n 25 addresses [listed in the Complaint],\u201d the claimants identify the \u201cnature of your interest in the\n virtual assets previously stored at that address.\u201d Chen Interrogatory No. 4 and Prince Group\n Interrogatory No. 3. Of course, this objection is in any event academic, as the government can\n serve additional special interrogatories without limit and \u201cwithout the court\u2019s leave at any time\n after the claim is filed and before discovery is closed.\u201d Supp. R. G(6)(a); see $1,106,775.00, 177\n F.4th at 993 (\u201cSupplemental Rule G(6) interrogatories are not limited in number . . .\u201d).\n\n\n 8\n\fCase 1:25-cv-05745-RPK-CHK Document 487 Filed 07/24/26 Page 9 of 11 PageID #:\n 12954\n\n\n\n entities had access to the funds at various times, cannot account for the full picture of off-chain\n transactions that funded the wallets at issue, and\u2014most importantly\u2014does not currently support\n or explain any of the contentions being made by Chen and Prince Group. That information is\n squarely within their possession. Indeed, as the Complaint notes, \u201c[t]he Defendant Cryptocurrency\n was moved across a complex network of . . . wallets affiliated with various shell companies and\n individuals,\u201d through processes \u201cdesigned to dissociate funds from their illicit sources.\u201d Compl.\n \u00b6 48. Given such efforts at obfuscation, Chen is better positioned than the government to elucidate\n the precise trail of possession and ownership. 8\n\n B. The Interrogatories Regarding Lubian Are Proper\n\n Boies Schiller separately argues that the Court\u2019s July 7 Order excuses their\n inadequate responses to interrogatories pertaining to Lubian. See BSF Opp. at 2, 16. This misreads\n the Order and its application here. To begin with, Lubian\u2019s involvement in Chen\u2019s and Prince\n Group\u2019s claims over the Defendant Cryptocurrency is not separate and distinct from the tracing\n questions discussed above, as Boies Schiller suggests. See BSF Opp at 1, 2. The government\u2019s\n questions about the nature of these claims cannot be answered without explaining Lubian\u2019s\n purported role in holding and mining portions of the Defendant Cryptocurrency. Boies Schiller\u2019s\n purported responses explicitly but vaguely implicate Lubian in Chen\u2019s and Prince Group\u2019s\n possessory and ownership claims; they must do more to explain how. See Gov. Mot. at 10-12.\n\n Moreover, as noted above, the central question governing the proper scope of the\n government\u2019s interrogatories is whether the information sought \u201cis relevant to understanding [the\n claimant\u2019s] relationship to the defendant property.\u201d July 7 Order at 8. Among other things,\n \u201crequests are appropriate to the extent they seek information related to whether [the claimant\u2019s]\n relationship with third parties affects its ownership interest in the Defendant Bitcoin.\u201d Id. at 11.\n Such an inquiry is especially relevant when potential nominee or straw owner issues are\n implicated, for claims by such entities are prohibited in civil forfeiture actions. See, e.g., United\n States v. One 1990 Beechcraft, 619 F.3d 1275, 1278-79 (11th Cir. 2010) (a corporation holding\n legal title is not an owner if all control is exercised by its majority shareholder in his individual\n capacity without regard to the corporate form); United States v. $410,000.00 in U.S. Currency, No.\n 07-CV-0598, 2007 WL 4557647, at *7 & n.5 (granting government\u2019s motion to compel responses\n to special interrogatories as necessary to ensure claimant has standing and to protect against\n nominee claimants). Indeed, while \u201can owner of the defendant property \u2018will normally have\n standing to challenge forfeiture,\u2019 \u2018straw owners\u2019\u2014those who legally \u2018own\u2019 the property but hold\n title for another party\u2014lack standing[.]\u201d July 7 Order at 11 (quoting Khudainatov, 177 F.4th at\n\n 8\n On this topic, Boies Schiller also misleadingly asserts that the government has\n previously argued that tracing \u201cis an issue for trial\u201d and \u201cgo[es] to the merits of this case.\u201d BSF\n Opp. at 15 (citing ECF No. 10 at 4). This is out of context. Those statements were about the\n government\u2019s obligation to prove the allegations in the Complaint by tracing funds subject to\n forfeiture, which need not be met until trial. See ECF No. 10 at 4 (\u201cTracing in a civil forfeiture\n case is an issue for trial; it is not required to satisfy the government\u2019s pleading requirements set\n forth in Rule G(2)(f).\u201d). Of course, special interrogatories have nothing to do with the\n government\u2019s pleading requirements, nor are they even governed by the claimant\u2019s pleading\n requirements, or else Rule G(6) would be superfluous. See $1,106,775.00, 177 F.4th at 997.\n\n\n 9\n\fCase 1:25-cv-05745-RPK-CHK Document 487 Filed 07/24/26 Page 10 of 11 PageID\n #: 12955\n\fCase 1:25-cv-05745-RPK-CHK Document 487 Filed 07/24/26 Page 11 of 11 PageID\n #: 12956\n\n\n\n IV. Conclusion\n\n For these reasons, and for all the reasons stated in the government\u2019s motion, the\n government respectfully requests that the Court compel Chen and Prince Group to properly\n respond to the government\u2019s special interrogatories pursuant to Rule G(6).\n\n\n\n Respectfully submitted,\n\n JOSEPH NOCELLA, JR.\n United States Attorney\n\n By: /s/\n Alexander F. Mindlin\n Andrew D. Reich\n Benjamin Weintraub\n Alessandra V. Rafalson\n Tanisha R. Payne\n Assistant U.S. Attorneys\n (718) 254-7000\n\n Christopher B. Brown\n Supervisory Trial Attorney\n National Security Cyber Section\n National Security Division\n U.S. Department of Justice\n\n\n cc: Clerk of Court (CHK)\n Counsel of Record\n\n\n\n\n 11\n\f","ocr_status":1,"date_upload":"2026-07-24T12:21:53.804940-07:00","document_number":"487","attachment_number":null,"pacer_doc_id":"123024006954","is_available":true,"is_free_on_pacer":null,"is_sealed":false,"document_type":1,"description":"Reply in Support","acms_document_guid":""}],"date_created":"2026-07-24T12:21:52.943939-07:00","date_modified":"2026-07-30T22:13:03.823537-07:00","date_filed":"2026-07-24","time_filed":"15:21:08","entry_number":487,"recap_sequence_number":"2026-07-24.002","pacer_sequence_number":3386,"description":"REPLY in Support re 468 MOTION to Compel as to Chen Zhi & Prince Group filed by United States of America. (Reich, Andrew) (Entered: 07/24/2026)","tags":[]}],"entries_total":"https://www.courtlistener.com/api/rest/v4/docket-entries/?count=on&docket=71639393&page_size=40"}