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1 Brett Ramsaur, Esq. (SBN 281566)
brett(Rramsaurlaw.corn
Ramsaur Law
3070 Bristol Street, Ste. 640
3
Costa Mesa, CA 92626
4 T: (949) 200-9114
Rongping Wu, Esq. (Pro Hac Vice)
5 lwu&dawlln.corn
DGW KRAMER LLP
45 Rockefeller Plaza, 20th Floor
New York, NY 101 1 1
7
T: (917) 633-6860
8
Attorneys for Plaintiff:
9 GONGQINGCHENG PANHUI INVESTMENT MANAGEMENT
PARTNERSHIP (LIMITED PARTNERSHIP)
10
SUPERIOR COURT OF THE STATE OF CALIFORNIA
12 FOR THE COUNTY OF SAN MATEO
13
PANHUI Case No.: 23-CIV-02886
i4 GONGQINGCHENG
INVESTMENT MANAGEMENT
PARTNERSHIP (LIMITED
PARTNERSHIP), DECLARATION OF RONGPING WU IN
16 a Chinese company, SUPPORT OF PLAINTIFF'S
OPPOSITION TO DEFENDANT YIHUA
17 Plaintiff, ZHU)S MOTION TO QUASH
18
vs.
19
LIHUI BAI, YIHUA ZHU, XYZ Corp.,
1-3, and John Does 1 — 3, inclusive,
21
Defendants.
22
23 I, RONGPING WU, an attorney admitted to practice before the courts of the State of New
24 York, affirm the following under the penalty of perjury:
25 l. All statements set forth in this Declaration are based upon my personal knowledge or my
26 review of original versions or certified copies of the relevant documents. I make this Declaration in
27 support of the Plaintiff, Gongqingcheng Panhui Investment Management Partnership (Limited
28
-1-
Declaration of Rongping Wu in Support of Plaintiff's Opposition to Defendant's Motion to Quash
1 Partnership) ("Plaintifp')'s Opposition to Defendant Yihua Zhu (the "Defendant")'s Motion to Quash
2 Subpoena.
3 2. 1 am a partner with the law firm of DGW Kramer LLP. DGW Kramer LLP acts as counsel to
4 Plaintiff for purposes of enforcing the final foreign country money judgment (the "Final Judgment" )
5 that is the underlying subject of this instant action for claims of avoidance of fraudulent transfersinter
6 alia, here in the United States of America against, inter alios, the Defendant.
7 3. Plaintiff is a corporate entity organized under the laws of the PRC with its principal place of
8 business located at 410-135 Gongqing City private Equity park, Jiujiang City, Jiangxi province, pRC.
9 4. This is an action pursuant to the Uniform Voidable Transfers Act, inter alia, Division 4, Part
10 2, Title 2, Chapter 1 of the CCP II) 3439 et seq. (the "CA UVTA"), to unwind and avoid transfers of
11 real properties which were conducted by and amongst defendant Lihui Bai ("Bai") and Defendant,
"
12 who is her son, in furtherance of Bai and her husband, Jiman Zhu ("Zhu and together with Bai, the
13 "Judgment Debtors")'s fraudulent scheme to defraud their creditors, in order to enforce the Final
14 Judgment (the "Comolaint"). The Final Judgment was issued on May 19, 2020, in Plaintiff s favor
15 against the Judgment Debtors, jointly and severally, by the Supreme people's Court, of the people'
16 Republic of China ("PRC") and assigned civil verdict no.: assigned civil verdict no.: (2019) Zui Gao
17 Fa Min Zhong No. 1931. A parallel action is currently pending before this Court for the recognition
18 and enforcement of the Final Judgment pursuant to the Uniform Foreign Money Judgments
19 Recognition Act ("UFMRJA")'.
20 5. To frustrate their creditors, including Plaintiff; Bai transferred her interest in real property
21 located at 71 Encino Rd, Atherton, CA 94027 (the "Pronertv") to her son, Defendant, for little to no
22 consideration.
23 6. On June 26, 2023, counsel for Plaintiff prepared and dispatched the commencement
24 documents and a bespoke form POS-015 Notice and Acknowledgement of Receipt for this matter to
25 Bai via USPS First Class mail to the Property. To-date, counsel for Plaintiff has not received this
26 mailing back as undeliverable, return to sender, or the signed Form POS-015.
27 'hat
I
matter is styled Gongqingcheng Panhui Investment Management Partnership (Limited
Partnership) v. Jiman ZHU, et al, was filed on June 26, 2023, and assigned case no.: 23-CIV-02884
(the "Recoenition Matter" ).
-2-
Declaration of Rongping Wu in Support of Plaintiff s Opposition to Defendant's Motion to Quash
1 7. On June 30, 2023, Plaintiff arranged for a process server (" Nationwide") to attempt to serve
2 Defendant, along with Bai, at Defendant's address in California, 358 Olympian Way, Pacifica, CA
3 94044 (the "Pacifica Address" ). On July 14, 2023 Nationwide was able to successfully serve
4 Defendant in hand at the Pacifica Address but was unable to locate Bai there. Attached hereto as
5 Exhibit 1 is a true and accurate copy of the proof of service evidencing service on Defendant at the
6 Pacifica Address.
7 8. On August 29, 2023 counsel for Plaintiff initiated service on Bai at her last known address in
8 the PRC located at Rootn //3, 8/F, Entrance (Gate) 1, Building 7, 29 Taoyuan South Road, Lianhu
9 District, Xi'an City, Shaanxi Province, PRC, Postal Code: 710082 (the "PRC Address") via the 15
10 November 1965 Convention on the Service Abroad of Judicial and Extrajudicial Documents in Civil
11 or Commercial Matters 20 U S T. 361, 658 U N T S. 163 (the "~Ha ue"). On November 15, 2023, the
12 PRC Central Authority determined that Bai could not be located at the PRC Address and represented
13 that Bai's "relatives refused to provide information about [Bai]." The matter was subsequently closed
14 by the PRC Central Authority.
15 9. On October 30, 2023, counsel for Plainnff dispatched Nationwide to attempt to serve Bai at
16 the Property with the commencement documents for this matter, inter alia, because the June 26, 2023
17 mailing had not been returned as undeliverable, return to sender. On October 31, 2023, Nationwide
18 reported back that they had spoken with a resident at the Property who indicated Bai did not currently
19 reside there. Attached hereto as Exhibit 2 is a true and accurate copy of the Nationwide diligence
20 report dated October 31, 2023 for the service attempt at the Property.
21 10. On January 3, 2024, counsel for Plaintiff re-initiated service on Bai at a newly discovered
22 address in the PRC located at No.28 Building, Huiyuan, Yuhua Road, Area B, Airport Development
23 Zone, Shunyi District, Beijing, PRC, Postal Code: 101318 (the "New PRC Address" ). To-date the
24 PRC Central Authority has accepted the commencement documents and passed them on to the
25 relevant Chinese court to perform service at the New PRC Address.
26 11. The Subpoena is intended to obtain information that will aid Plaintiff in serving Bai.
27 Moreover, the Subpoena is intended to obtain information that will aid Plaintiff in establishing the
28 extent of the Judgment Debtors'resence here in California for jurisdictional purposes. Finally, the
-3-
Declaration of Rongping Wu in Support of Plaintiff s Opposition to Defendant's Motion to Quash
1 Subpoena is intended to aid Plaintiff in discovering additional transferees and the full extent of
2 Judgment Debtors'ransfers of their assets. Plaintiff has reason to believe that the Judgment Debtors'
transfers of assets go well beyond the identified transfer of the Property and that belief was
4 memorialized by the inclusion of place-holder defendants XYZ Corps„ I — 3 and John Does I — 3 in
5 the Complaint. The Subpoena was issued to JP Morgan Chase Bank N.A. (the "Custodian" ) because
6 Plaintiff discovered that the Judgment Debtors and/or their known associates held accounts with the
7 Custodian.
8 12. On December 28, 2023, per CCP jj 1985.3, counsel for Plaintiff dispatched the required form
9 SUBP-025 along with a copy of the Subpoena and the accompanying attachment and affidavit to each
10 of the consumers affected by the Subpoena at their last known addresses (the "5gfjces"). The
11 consumers affected by the Subpoena were both of the Judgment Debtors. Out of an abundance of
12 caution and to account for the distinct possibility that the Custodian would erroneously search for
13 records using variations of Zhu's first name, a notice was issued to known third-party Jian Zhu
14 ("Jian"). Defendant has represented in the Motion that Jian is in fact Zhu's brother. (See Motion, pg.
15 1). The Subpoena does not seek records pertaining to Jian and Jian's name does not appear anywhere
16 in the Subpoena.
17 13. Counsel for Plaintiff directed an employee to mail the Notices to the last known addresses
18 for the Judgment Debtors and Jian. As of December 28, 2023, the last known addresses for the
19 Judgment Debtors were an address in the PRC for Zhu and the address of the Property for Bai. The
20 address for Jian was obtained from public records in the PRC. The employee dispatched the Notices
21 to the last known addresses for Zhu and Jian in the PRC via USPS First Class International mail and
22 to Bai in California via USPS First Class mail. A copy of the Notice bespoke for Bai was included
23 in the mailing to Zhu at the PRC Address because they are husband and wife. To-date, the Notices
24 have not been returned as undeliverable, return to sender. The records available to Plaintiff indicate
25 that the addresses for Zhu and Jian were correct. Attached hereto as Exhibit 3 are true and accurate
26 copies of the Final Judgment which contains the last known address for Jiman and a publicly available
27 document from the Hong Kong, SAR Companies Registry which contains the last known address for
28 Jian.
-4-
Declaration of Rongping Wu in Support of Plaintiff s Opposition to Defendant's Motion to Quash
1 14. Having received no objections pursuant to the Notices, on January 25, 2024, Plaintiff served
2 the Custodian in hand with the Subpoena and the Notices. Attached hereto as Exhibit 4 is a true and
3 accurate copy of the proof of service for the Subpoena. Atter the Subpoena had been served on the
4 Custodian, counsel for Plaintiff directed an employee to dispatch a courtesy email to counsel for
5 Defendant containing copies of the Subpoena and the Notices. (See Exhibit D to Colwell
6 Declaration). The Notices as provided to Defendant's counsel clearly contained the employee's
7 signature, attesting under penalty of perjury that, pursuant to CCP II 1985.3, the Notices and a copy
8 of the Subpoena, as provided for within Section 1 of page 1 of the Notices ("[a] copy of the subpoena
9 is attached" ), had been mailed out in accordance with the methodology detailed within Section 2(b)
10 of page 2 of the Notices on December 28, 2023.
11 15. The list of objections submitted by Counsel for Defendant, with the exception of one
12 objection, is entirely duplicative of the objections to the procedurally defective subpoena issued to
13 the Custodian on November 1, 2023. Attached hereto as Exhibit 5 is a true and accurate copy of the
14 email from Defendant's Counsel dated November 13, 2023.
15 16. Regarding the one new objection contained in the January 30 email, Counsel for Plaintiff
16 contacted the Custodian and unilaterally extended the due date by one week &om February 6 until
17 February 13 thereby providing the Custodian with 19 days to comply. Attached hereto as Exhibit 6
18 is a true and accurate copy of the email chain with the Custodian dated February 1, 2024 confirming
19 the extension. The Custodian never made mention of insuAicient time to comply and was surprised
20 by Plaintiff s unilateral extension.
21
22 1 declare under penalty of perjury under the laws of the state of California that the foregoing
23 is true and correct. Executed at New York, New York.
24 Dated: March 8, 2024
New York, New York
25
26
27
-5-
Declaration of Rongping Wu in Support of Plaintiffs Opposition to Defendant's Motion to Quash
EXHIBIT 1
POS-010
ATTGRNEYGR pARTYwlTHOUTATTCRNEY(Name, slalessrnumler andaddressl FOR COURT USE ONL 7
Brett Ramsaur, Esq. SBN. 281566 )
Ramsaur Law
27075 Cabot Road; Ste. 110 Laguna Hills, CA 92653
TELEpHGNE No (949) 200911s FAx No IE MAIL AGOREss orealsramsaurlmv oem
I
ATTORNEY FOR (Flamel Plaintiff GONGOINGCHENG PANHUI INV STMENT MANAGEMENT PARTNERSHIP (L(M(TEO
PARTI ERSHIP)
SAN MATEO COUNTY SUPERIOR COURT
sTR~ETAOOREss 400 COUNTY CENTER
cITY AeozIP cooE: REDWOOD CITY, CA 94063
SRANCH
NAME'LAINTIFF/PETITIONER.
GONGQINGCHENG PANHUI INVESTMENT MANAGEMENT
CASENUMSER
PARTNERSHIP (LIMITED PARTNERSHIP), a Chinese company
DEFENDANT/RESPONDENT: LIHUI BAI, et al. 23-CIV-02886
Ref No or File No
PROOF OF SERVICE OF SUMMONS Gongqingcheng v. Bai
(Sepera/s proof of service is required for each party served.)
1, At the time of service was at least 18 years of age and not a party to this action.
I
2 served copies of:
I
a. IÃ Summons
b. 2 Complaint
c. Alternative Dispute Resolution (ADR) package
d. R
Ciwl Case Cover Sheet
e. Cross-Complaint
other (spew/y documents):
3 a. Party served (spec/fy name af party as shown on documents served):
YIHUA ZHU
Aga: Late 30's Weight: 16O Hair: Black sex: Male Height: 6'6" Eyes: Brown Race: Asian
I I I I I I
Person (other than the party in item 3a) served on behalf of an entity or as an authonzed agent (and not a person under
item 5b on whom substituted servtce was made) (specify name and re/a/ianship lo the party named /n item 3a)
4, Address where the party was served: 358 Olympian Way
Pacifica, CA 94044-3934
5. I se~fv d the party (check proper box)
a M by personal service. personally delivered the documents listed in item 2 to the party or person authorized to
I
receive service of process for the party (1) on (dale): 7/14/2023 (2) at (time): 7:50 AM
by substituted service. On (date): at (time): left the documents hated in item 2 with or
I
in the presence of (name and title or relationship lo person rndica/ed in i/em 3)l
(1) (business) a person at least 18 years of age apparently in charge at the office or usual place of business of the
person to be served. informed him of her of the general nature of the papers.
I
(2) (home) a competent member of the household (at least 18 years of age) at the dwelling house or usual place of
abode of the party. informed him or her of the general nature of the papers.
I
(3) (physical address unknown) a persan at least 18 years of age apparently in charge at the usual mailing
address of the person to be served, other than a United States Postal Service post office box informed him of
I
her of the general nature of the papers.
(4) Ithereafter mailed (by first-class, postage prepaid) copies of the documents to the person to be served at the
place where the copies were left (Code Civ. Proc., 9415.20). mailed the documents on
I
(dale): from (city): or 9
a declaration of mailing is attached.
(5) I attach a declaration of diligence stating actions taken first ta attempt personal service.
Paaelof2
code of c Y Procedure 9 sly 10
Form Anptoved for Mandatory Us.
I
J d o al Counul of California PROOF OF SERVICE OF SUMMONS POS010-1/LA413303
pos-010 [pev January I 2007I
CASE
PETITIONER GDNGQINGCHENG PANHUI INVESTMENT MANAGEMENT PARTNERSHIP (LIMITED
PARTNERSHIP), 4 Chinese company NUMBER'3-CIV-02SSS
RESPONDENT. LII-Iu/ SAi, cia/.
c p by mail and acknowledgment of receipt of service.
shown in Item 4, by first-class mail, postage prepaid,
I mailed the documents hated in item 2 to the parly, to the address
(1) on (da/e). (2) from (o/y)
(3) with two copies of the Nofice and Acknoiv/edgment of Receipl and a postage-paid return envelope addressed to me.
/Attach completed Notice and Acknowledgement of Receipt.) (Code Civ Proc., 6 415.30.)
(4)+ to an address outside California w/th return receipt requested. (Code Civ. Proc., 9 415 40.)
d, by other means (speci/y means ofserv/ca and authorizing code sec/ion):
Addit/onal page descnbing sewice is attached
6. The "Not/ce to the Person Served" (on the summons) was completed as follows.
a. R as an indiv/dual defendant.
as the person sued under the fictitious name of (specify).
c. as occupant.
d. On behalf of
under the following Code of Civil Procedure section:
416.10 (corporation) 415.95 (business organization, form unknown)
416.20 (defunct corporation) Cl 416 60 (minor)
!
416.30 (joint stock company/association) 0 416 70 (ward or conservatee)
416.90 (authorized person)
416.40 (assomation or partnership)
416 50 (public entity) 415.46 (occupant)
other.
7. Person who served papers
a. Name. Gabriela de Araujo Silva - Nationwide Legal, LLC REG: 12-234648
b. Address: 1609 James M Wood Blvd. Los Angeles, CA 90015
c. Telephone number: (213) 249-9999
d. The fee for service was: $ 186.30
e, lam:
not a registered California process server.
(1)
(2)
(3) L+I
+exempt from registration under Business and Professions Code section 22350(b).
registered California prgcess server.
(I)
(ii)
[ JRegistration
owner
Noz
U employee
2023-0001533
independent contractor
(ni) County: San Francisco
8. K! I declare under penalty of perjury under the laws of the State of California that the foregoing is true and correct.
OI'
0 I am a California sheriff or marshal and certify that the foregoing is true and correct.
I
Date: 7/14/2023
Nationwide Legal, LLC
1609 James M Wood Blvd.
Los Anoeles, CA 90015
(213) 249-9999
www.nationwideasap.corn
Gabriela de Arauio Silva
(NAME OF PERSON WHO SERVED PAPERS/SHERIFF OR MARSHAL)
Page 2 o/2
Pos.ol 0 IRev Janvaly I 2002]
PROOF OF SERVICE OF SUMMONS POS-010/LA413303
EXHIBIT 2
From: tin aiinnividefeoal corn
nrnrocess
Toi. Bfeir Ramsaul
Subject: Diligence Report re:ZHU v. BAt Service on: tihui Bai
Date: Tuesday, october 31, 2023 3:46:10 pto
[ Workord~er:: [OC153222A
Reference
Number: ZHU v. BAI
Case
Number: 23-CIV-02884
Gongqingcheng Panhui Investment
Management Partnership, etc vs Jiman
Case Title: Zhu, and Lihui Bai
,035 - RELATED SERVICE OF
Job Typ~e: PROCESS Standard —
Ordered By: Brett Ramsaur (949) 200-9114
—
[Ordered On/[10/30/2023
Servee: Lihui Bai
Summons; Complaint; Alternative Dispute
Documents: (ADR) package; Civil Case Cover Sheet; J
Date: 10/31/2023
Time: 12:20 PM
Address Attempted: 71 Encino Road,,
Atherton, CA 94027
Bad address.i talked to a resident,(
female, blonde, blue eyes, 40's) who
informed there is no one with these
names, Jiman Zhu or Lihui Bai, living at
that address.
Thanl'ou for trusting Nationwide Legal!
Please do not reply to this email. It was generated automatically.
If you have any questions please do not hesitate to contact us at Iegat@nationwidetegat.corn (213)
249. 9999
CLIENT PORTAL
EXHIEIT 3
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The High People's Court of Beijing Municipality
Civil Judgment
(2018) ling Min Chn No. 122
Plaintiff; Gongqingcheng Panhui Investment Management
Partnership L'nterprise
Private Equity Park, Jiujiaug City,
(I,imited Partnership), address: 410-135 Gongqing City
Jiangxi Province, China.
Executive Partner; Beijing Qiebao Asset Management Co., Ltd.
(Representative;
WANG Xindi).
Agent ad litem: YE Xin, lawyer of Beijing Commerce & Finance
Law Oflices.
Offices.
Agent ad litem; WANG Jialu, lawyer of Beijing Commerce & Finance Law
Defendant: liarbin Gloria Group Co., Ltd, address; Room 532, No. 180 Hongqi
Street, Nangang Building 26, Hi-tech Entrepreneurship Center, Harbin
Hi-tech Industrial
Development 7xine, Heilongjiang Province.
Legal Representative: BAI Lihui, Chairman.
Agent ad litem: WANG Bo, lawyer of Beijing Iqaizhcngcheng Law Firm.
Agent ad iiiean Gao Ying, lawyer of Beijing Haizhengrheng Law Firm.
Defendant: ZHU Jiman, male, born on Han nationality, residing at
No.3, 8/F, Entrance 1, Building 7, 29 Taoyuan South Road, Lianhu District, Xi'an City,
Shaanxi Province.
Agent ad litem: WANG Bo, lawyer of Beijing Haizhengcheng Law Firm.
Agent ad lirem: GAO I.u, lawyer of Beijing Haizhengcheng Law Firm.
Defendant: BAI Lihui, female, born on Han nationality, address: No.
3, 8/F, Entrance 1, Building 7, 29 Taoyuan South Road, Lianhu District, Xi'an City,
NOTARIAL CERTIFICATE
(Translation)
(2023) J.F.Y W.J.Z.Zi, No. 977
Applicant: Gongqingcheng Panhui Investment Management
Partnership Enterprise (Limited Partnership), Address: 410-135 Gongqing
City Private Fquity Part, Jiujiang City, Jiangxi Province.
Attorney: Zhao Yi, female, born on I.D. Card No.
Item of Notarization: Conformity of Photocopy and the Original
This is to certify that the photocopy attached hereto is in conformity
with the original of Civil Judgment shown to me by Zhao Yi, the attorney
of the applicant.
Notary; Zheng Luyan
Beijing Fangyuan Notary Public Once
The People's Republic of China
March 14, 2023
(2023i 5&51ht Yr.iiE8-% 978 w
W~AA: Ã%4%@R%%@k&k+~ (4 5+8.),
hiNiTIN4AKVPt4.%%4! %k+W K 410-135.
4%1&CA: kk, 4,
k~iECV.; 444/848K
5ik~g si& XR@X%44 (2023) 5ZIPl Y~&4% 977
!"! C)2!i'.?456
NOTARIAL CERTIFICATE
(Translat&on)
(2023) J.F, Y W.J.Z.Zi, No. 978
Applicant: Gongqingcheng Panhui Investment Management
Partnership Enterprise (Limited Partnership), Address: 410-135 Gongqing
City Private Equity Park, Jiujiang City, Jiangxi Province.
Attorney: Zhao Yi, female, born on ID Card No
Item of Notarization: Conformity of Translation and Original
This is to certify that the English translation enclosed is identical
with the Chinese original of the Notarial Certiftcatc (2023) J.F.YW:J.Z.Zi,
No. 977.
Notary: Zheng Luyan
Beijing Fangyuan Notary Public Office
The People's Republic of China
March 14; 2023
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Embassy of the United )
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Katelyn C. Warden
Vice Consul
I, , Consul/Vice Consul of the United
Ar,
States ofAmerica in Beijing, tjte People's Republic of China, duly commissioned
and qualified,
Nn ~ (4 sra whose true signature and official
do hereby certify that
seal are, respectively, subscrjbed and affixed to the foregoing document, was on the
W7 day of /N 202/ an oificer of the
Ministry of Foreign Affairs of the People's Republic of China, duly commissioned
and qualified, to whose official acts faith and credit are due.
IN WITNESS WHEREOF I have hereunto set my hand and affixed the seal
of the
this
Embassy of the United States 9f America in Beijing, the People's Republic of
China
( 0 day of NOIV, 202~.
Katelyn C. Warden
'ce Consul
CEkTIFICATF. t)F TII ANSI.ATION
0 3 in Wang. being neer the agc of eighteen, duly sworn and deposed, lmteby swear and
crest to thc following*.
Myqu;ttilications:t, a utntslator are as Iollows; I grew up in thc I'coplc's Kcpubhc ol China
("PRC ') and Chinese is my naticc ianguagc. I lcamcd English fmm elementary schon
'ue
coiiegc in the I&RC Ior a total of i6 yean ol'study. I earned a Bachelor's Degme in Tmn'tauon
and lntcrpr.ting in 2031. sttbscquemly I camcd a hlastcr's Degree in Bu'incss Analytics 1«m
Soudtcnt htedtodi,t Uniccrsity in 2033, and I curtently reside in the Umted States
I liathcr certify dtat, to dtc best of my hnowlcdgc, thc attached docurncn's ia E g
and accurate translations of the attached documents in Chtnc~
I certifY
is true and correca
Signature of Tmnslatnr
HI 71 6334860
Telephone Nomina lbr Translator
+Date
Yin Wane
Ntaue of Translator
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underpcnalty ofpcr)uty under the,lawS of the State ot California that dtc foregoing
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by 4n Wdln61
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The forewing insuument was acknowledged rutd swont bciorc mc this date
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Name in Chinese
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Previous Names
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Residential No. D-501, Building 7, No. 29 Taoyuan South Road
.Address
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Preview
1 Brett Ramsaur, Esq. (SBN 281566) brett(Rramsaurlaw.corn Ramsaur Law 3070 Bristol Street, Ste. 640 3 Costa Mesa, CA 92626 4 T: (949) 200-9114 Rongping Wu, Esq. (Pro Hac Vice) 5 lwu&dawlln.corn DGW KRAMER LLP 45 Rockefeller Plaza, 20th Floor New York, NY 101 1 1 7 T: (917) 633-6860 8 Attorneys for Plaintiff: 9 GONGQINGCHENG PANHUI INVESTMENT MANAGEMENT PARTNERSHIP (LIMITED PARTNERSHIP) 10 SUPERIOR COURT OF THE STATE OF CALIFORNIA 12 FOR THE COUNTY OF SAN MATEO 13 PANHUI Case No.: 23-CIV-02886 i4 GONGQINGCHENG INVESTMENT MANAGEMENT PARTNERSHIP (LIMITED PARTNERSHIP), DECLARATION OF RONGPING WU IN 16 a Chinese company, SUPPORT OF PLAINTIFF'S OPPOSITION TO DEFENDANT YIHUA 17 Plaintiff, ZHU)S MOTION TO QUASH 18 vs. 19 LIHUI BAI, YIHUA ZHU, XYZ Corp., 1-3, and John Does 1 — 3, inclusive, 21 Defendants. 22 23 I, RONGPING WU, an attorney admitted to practice before the courts of the State of New 24 York, affirm the following under the penalty of perjury: 25 l. All statements set forth in this Declaration are based upon my personal knowledge or my 26 review of original versions or certified copies of the relevant documents. I make this Declaration in 27 support of the Plaintiff, Gongqingcheng Panhui Investment Management Partnership (Limited 28 -1- Declaration of Rongping Wu in Support of Plaintiff's Opposition to Defendant's Motion to Quash 1 Partnership) ("Plaintifp')'s Opposition to Defendant Yihua Zhu (the "Defendant")'s Motion to Quash 2 Subpoena. 3 2. 1 am a partner with the law firm of DGW Kramer LLP. DGW Kramer LLP acts as counsel to 4 Plaintiff for purposes of enforcing the final foreign country money judgment (the "Final Judgment" ) 5 that is the underlying subject of this instant action for claims of avoidance of fraudulent transfersinter 6 alia, here in the United States of America against, inter alios, the Defendant. 7 3. Plaintiff is a corporate entity organized under the laws of the PRC with its principal place of 8 business located at 410-135 Gongqing City private Equity park, Jiujiang City, Jiangxi province, pRC. 9 4. This is an action pursuant to the Uniform Voidable Transfers Act, inter alia, Division 4, Part 10 2, Title 2, Chapter 1 of the CCP II) 3439 et seq. (the "CA UVTA"), to unwind and avoid transfers of 11 real properties which were conducted by and amongst defendant Lihui Bai ("Bai") and Defendant, " 12 who is her son, in furtherance of Bai and her husband, Jiman Zhu ("Zhu and together with Bai, the 13 "Judgment Debtors")'s fraudulent scheme to defraud their creditors, in order to enforce the Final 14 Judgment (the "Comolaint"). The Final Judgment was issued on May 19, 2020, in Plaintiff s favor 15 against the Judgment Debtors, jointly and severally, by the Supreme people's Court, of the people' 16 Republic of China ("PRC") and assigned civil verdict no.: assigned civil verdict no.: (2019) Zui Gao 17 Fa Min Zhong No. 1931. A parallel action is currently pending before this Court for the recognition 18 and enforcement of the Final Judgment pursuant to the Uniform Foreign Money Judgments 19 Recognition Act ("UFMRJA")'. 20 5. To frustrate their creditors, including Plaintiff; Bai transferred her interest in real property 21 located at 71 Encino Rd, Atherton, CA 94027 (the "Pronertv") to her son, Defendant, for little to no 22 consideration. 23 6. On June 26, 2023, counsel for Plaintiff prepared and dispatched the commencement 24 documents and a bespoke form POS-015 Notice and Acknowledgement of Receipt for this matter to 25 Bai via USPS First Class mail to the Property. To-date, counsel for Plaintiff has not received this 26 mailing back as undeliverable, return to sender, or the signed Form POS-015. 27 'hat I matter is styled Gongqingcheng Panhui Investment Management Partnership (Limited Partnership) v. Jiman ZHU, et al, was filed on June 26, 2023, and assigned case no.: 23-CIV-02884 (the "Recoenition Matter" ). -2- Declaration of Rongping Wu in Support of Plaintiff s Opposition to Defendant's Motion to Quash 1 7. On June 30, 2023, Plaintiff arranged for a process server (" Nationwide") to attempt to serve 2 Defendant, along with Bai, at Defendant's address in California, 358 Olympian Way, Pacifica, CA 3 94044 (the "Pacifica Address" ). On July 14, 2023 Nationwide was able to successfully serve 4 Defendant in hand at the Pacifica Address but was unable to locate Bai there. Attached hereto as 5 Exhibit 1 is a true and accurate copy of the proof of service evidencing service on Defendant at the 6 Pacifica Address. 7 8. On August 29, 2023 counsel for Plaintiff initiated service on Bai at her last known address in 8 the PRC located at Rootn //3, 8/F, Entrance (Gate) 1, Building 7, 29 Taoyuan South Road, Lianhu 9 District, Xi'an City, Shaanxi Province, PRC, Postal Code: 710082 (the "PRC Address") via the 15 10 November 1965 Convention on the Service Abroad of Judicial and Extrajudicial Documents in Civil 11 or Commercial Matters 20 U S T. 361, 658 U N T S. 163 (the "~Ha ue"). On November 15, 2023, the 12 PRC Central Authority determined that Bai could not be located at the PRC Address and represented 13 that Bai's "relatives refused to provide information about [Bai]." The matter was subsequently closed 14 by the PRC Central Authority. 15 9. On October 30, 2023, counsel for Plainnff dispatched Nationwide to attempt to serve Bai at 16 the Property with the commencement documents for this matter, inter alia, because the June 26, 2023 17 mailing had not been returned as undeliverable, return to sender. On October 31, 2023, Nationwide 18 reported back that they had spoken with a resident at the Property who indicated Bai did not currently 19 reside there. Attached hereto as Exhibit 2 is a true and accurate copy of the Nationwide diligence 20 report dated October 31, 2023 for the service attempt at the Property. 21 10. On January 3, 2024, counsel for Plaintiff re-initiated service on Bai at a newly discovered 22 address in the PRC located at No.28 Building, Huiyuan, Yuhua Road, Area B, Airport Development 23 Zone, Shunyi District, Beijing, PRC, Postal Code: 101318 (the "New PRC Address" ). To-date the 24 PRC Central Authority has accepted the commencement documents and passed them on to the 25 relevant Chinese court to perform service at the New PRC Address. 26 11. The Subpoena is intended to obtain information that will aid Plaintiff in serving Bai. 27 Moreover, the Subpoena is intended to obtain information that will aid Plaintiff in establishing the 28 extent of the Judgment Debtors'resence here in California for jurisdictional purposes. Finally, the -3- Declaration of Rongping Wu in Support of Plaintiff s Opposition to Defendant's Motion to Quash 1 Subpoena is intended to aid Plaintiff in discovering additional transferees and the full extent of 2 Judgment Debtors'ransfers of their assets. Plaintiff has reason to believe that the Judgment Debtors' transfers of assets go well beyond the identified transfer of the Property and that belief was 4 memorialized by the inclusion of place-holder defendants XYZ Corps„ I — 3 and John Does I — 3 in 5 the Complaint. The Subpoena was issued to JP Morgan Chase Bank N.A. (the "Custodian" ) because 6 Plaintiff discovered that the Judgment Debtors and/or their known associates held accounts with the 7 Custodian. 8 12. On December 28, 2023, per CCP jj 1985.3, counsel for Plaintiff dispatched the required form 9 SUBP-025 along with a copy of the Subpoena and the accompanying attachment and affidavit to each 10 of the consumers affected by the Subpoena at their last known addresses (the "5gfjces"). The 11 consumers affected by the Subpoena were both of the Judgment Debtors. Out of an abundance of 12 caution and to account for the distinct possibility that the Custodian would erroneously search for 13 records using variations of Zhu's first name, a notice was issued to known third-party Jian Zhu 14 ("Jian"). Defendant has represented in the Motion that Jian is in fact Zhu's brother. (See Motion, pg. 15 1). The Subpoena does not seek records pertaining to Jian and Jian's name does not appear anywhere 16 in the Subpoena. 17 13. Counsel for Plaintiff directed an employee to mail the Notices to the last known addresses 18 for the Judgment Debtors and Jian. As of December 28, 2023, the last known addresses for the 19 Judgment Debtors were an address in the PRC for Zhu and the address of the Property for Bai. The 20 address for Jian was obtained from public records in the PRC. The employee dispatched the Notices 21 to the last known addresses for Zhu and Jian in the PRC via USPS First Class International mail and 22 to Bai in California via USPS First Class mail. A copy of the Notice bespoke for Bai was included 23 in the mailing to Zhu at the PRC Address because they are husband and wife. To-date, the Notices 24 have not been returned as undeliverable, return to sender. The records available to Plaintiff indicate 25 that the addresses for Zhu and Jian were correct. Attached hereto as Exhibit 3 are true and accurate 26 copies of the Final Judgment which contains the last known address for Jiman and a publicly available 27 document from the Hong Kong, SAR Companies Registry which contains the last known address for 28 Jian. -4- Declaration of Rongping Wu in Support of Plaintiff s Opposition to Defendant's Motion to Quash 1 14. Having received no objections pursuant to the Notices, on January 25, 2024, Plaintiff served 2 the Custodian in hand with the Subpoena and the Notices. Attached hereto as Exhibit 4 is a true and 3 accurate copy of the proof of service for the Subpoena. Atter the Subpoena had been served on the 4 Custodian, counsel for Plaintiff directed an employee to dispatch a courtesy email to counsel for 5 Defendant containing copies of the Subpoena and the Notices. (See Exhibit D to Colwell 6 Declaration). The Notices as provided to Defendant's counsel clearly contained the employee's 7 signature, attesting under penalty of perjury that, pursuant to CCP II 1985.3, the Notices and a copy 8 of the Subpoena, as provided for within Section 1 of page 1 of the Notices ("[a] copy of the subpoena 9 is attached" ), had been mailed out in accordance with the methodology detailed within Section 2(b) 10 of page 2 of the Notices on December 28, 2023. 11 15. The list of objections submitted by Counsel for Defendant, with the exception of one 12 objection, is entirely duplicative of the objections to the procedurally defective subpoena issued to 13 the Custodian on November 1, 2023. Attached hereto as Exhibit 5 is a true and accurate copy of the 14 email from Defendant's Counsel dated November 13, 2023. 15 16. Regarding the one new objection contained in the January 30 email, Counsel for Plaintiff 16 contacted the Custodian and unilaterally extended the due date by one week &om February 6 until 17 February 13 thereby providing the Custodian with 19 days to comply. Attached hereto as Exhibit 6 18 is a true and accurate copy of the email chain with the Custodian dated February 1, 2024 confirming 19 the extension. The Custodian never made mention of insuAicient time to comply and was surprised 20 by Plaintiff s unilateral extension. 21 22 1 declare under penalty of perjury under the laws of the state of California that the foregoing 23 is true and correct. Executed at New York, New York. 24 Dated: March 8, 2024 New York, New York 25 26 27 -5- Declaration of Rongping Wu in Support of Plaintiffs Opposition to Defendant's Motion to Quash EXHIBIT 1 POS-010 ATTGRNEYGR pARTYwlTHOUTATTCRNEY(Name, slalessrnumler andaddressl FOR COURT USE ONL 7 Brett Ramsaur, Esq. SBN. 281566 ) Ramsaur Law 27075 Cabot Road; Ste. 110 Laguna Hills, CA 92653 TELEpHGNE No (949) 200911s FAx No IE MAIL AGOREss orealsramsaurlmv oem I ATTORNEY FOR (Flamel Plaintiff GONGOINGCHENG PANHUI INV STMENT MANAGEMENT PARTNERSHIP (L(M(TEO PARTI ERSHIP) SAN MATEO COUNTY SUPERIOR COURT sTR~ETAOOREss 400 COUNTY CENTER cITY AeozIP cooE: REDWOOD CITY, CA 94063 SRANCH NAME'LAINTIFF/PETITIONER. GONGQINGCHENG PANHUI INVESTMENT MANAGEMENT CASENUMSER PARTNERSHIP (LIMITED PARTNERSHIP), a Chinese company DEFENDANT/RESPONDENT: LIHUI BAI, et al. 23-CIV-02886 Ref No or File No PROOF OF SERVICE OF SUMMONS Gongqingcheng v. Bai (Sepera/s proof of service is required for each party served.) 1, At the time of service was at least 18 years of age and not a party to this action. I 2 served copies of: I a. IÃ Summons b. 2 Complaint c. Alternative Dispute Resolution (ADR) package d. R Ciwl Case Cover Sheet e. Cross-Complaint other (spew/y documents): 3 a. Party served (spec/fy name af party as shown on documents served): YIHUA ZHU Aga: Late 30's Weight: 16O Hair: Black sex: Male Height: 6'6" Eyes: Brown Race: Asian I I I I I I Person (other than the party in item 3a) served on behalf of an entity or as an authonzed agent (and not a person under item 5b on whom substituted servtce was made) (specify name and re/a/ianship lo the party named /n item 3a) 4, Address where the party was served: 358 Olympian Way Pacifica, CA 94044-3934 5. I se~fv d the party (check proper box) a M by personal service. personally delivered the documents listed in item 2 to the party or person authorized to I receive service of process for the party (1) on (dale): 7/14/2023 (2) at (time): 7:50 AM by substituted service. On (date): at (time): left the documents hated in item 2 with or I in the presence of (name and title or relationship lo person rndica/ed in i/em 3)l (1) (business) a person at least 18 years of age apparently in charge at the office or usual place of business of the person to be served. informed him of her of the general nature of the papers. I (2) (home) a competent member of the household (at least 18 years of age) at the dwelling house or usual place of abode of the party. informed him or her of the general nature of the papers. I (3) (physical address unknown) a persan at least 18 years of age apparently in charge at the usual mailing address of the person to be served, other than a United States Postal Service post office box informed him of I her of the general nature of the papers. (4) Ithereafter mailed (by first-class, postage prepaid) copies of the documents to the person to be served at the place where the copies were left (Code Civ. Proc., 9415.20). mailed the documents on I (dale): from (city): or 9 a declaration of mailing is attached. (5) I attach a declaration of diligence stating actions taken first ta attempt personal service. Paaelof2 code of c Y Procedure 9 sly 10 Form Anptoved for Mandatory Us. I J d o al Counul of California PROOF OF SERVICE OF SUMMONS POS010-1/LA413303 pos-010 [pev January I 2007I CASE PETITIONER GDNGQINGCHENG PANHUI INVESTMENT MANAGEMENT PARTNERSHIP (LIMITED PARTNERSHIP), 4 Chinese company NUMBER'3-CIV-02SSS RESPONDENT. LII-Iu/ SAi, cia/. c p by mail and acknowledgment of receipt of service. shown in Item 4, by first-class mail, postage prepaid, I mailed the documents hated in item 2 to the parly, to the address (1) on (da/e). (2) from (o/y) (3) with two copies of the Nofice and Acknoiv/edgment of Receipl and a postage-paid return envelope addressed to me. /Attach completed Notice and Acknowledgement of Receipt.) (Code Civ Proc., 6 415.30.) (4)+ to an address outside California w/th return receipt requested. (Code Civ. Proc., 9 415 40.) d, by other means (speci/y means ofserv/ca and authorizing code sec/ion): Addit/onal page descnbing sewice is attached 6. The "Not/ce to the Person Served" (on the summons) was completed as follows. a. R as an indiv/dual defendant. as the person sued under the fictitious name of (specify). c. as occupant. d. On behalf of under the following Code of Civil Procedure section: 416.10 (corporation) 415.95 (business organization, form unknown) 416.20 (defunct corporation) Cl 416 60 (minor) ! 416.30 (joint stock company/association) 0 416 70 (ward or conservatee) 416.90 (authorized person) 416.40 (assomation or partnership) 416 50 (public entity) 415.46 (occupant) other. 7. Person who served papers a. Name. Gabriela de Araujo Silva - Nationwide Legal, LLC REG: 12-234648 b. Address: 1609 James M Wood Blvd. Los Angeles, CA 90015 c. Telephone number: (213) 249-9999 d. The fee for service was: $ 186.30 e, lam: not a registered California process server. (1) (2) (3) L+I +exempt from registration under Business and Professions Code section 22350(b). registered California prgcess server. (I) (ii) [ JRegistration owner Noz U employee 2023-0001533 independent contractor (ni) County: San Francisco 8. K! I declare under penalty of perjury under the laws of the State of California that the foregoing is true and correct. OI' 0 I am a California sheriff or marshal and certify that the foregoing is true and correct. I Date: 7/14/2023 Nationwide Legal, LLC 1609 James M Wood Blvd. Los Anoeles, CA 90015 (213) 249-9999 www.nationwideasap.corn Gabriela de Arauio Silva (NAME OF PERSON WHO SERVED PAPERS/SHERIFF OR MARSHAL) Page 2 o/2 Pos.ol 0 IRev Janvaly I 2002] PROOF OF SERVICE OF SUMMONS POS-010/LA413303 EXHIBIT 2 From: tin aiinnividefeoal corn nrnrocess Toi. Bfeir Ramsaul Subject: Diligence Report re:ZHU v. BAt Service on: tihui Bai Date: Tuesday, october 31, 2023 3:46:10 pto [ Workord~er:: [OC153222A Reference Number: ZHU v. BAI Case Number: 23-CIV-02884 Gongqingcheng Panhui Investment Management Partnership, etc vs Jiman Case Title: Zhu, and Lihui Bai ,035 - RELATED SERVICE OF Job Typ~e: PROCESS Standard — Ordered By: Brett Ramsaur (949) 200-9114 — [Ordered On/[10/30/2023 Servee: Lihui Bai Summons; Complaint; Alternative Dispute Documents: (ADR) package; Civil Case Cover Sheet; J Date: 10/31/2023 Time: 12:20 PM Address Attempted: 71 Encino Road,, Atherton, CA 94027 Bad address.i talked to a resident,( female, blonde, blue eyes, 40's) who informed there is no one with these names, Jiman Zhu or Lihui Bai, living at that address. Thanl'ou for trusting Nationwide Legal! Please do not reply to this email. It was generated automatically. If you have any questions please do not hesitate to contact us at Iegat@nationwidetegat.corn (213) 249. 9999 CLIENT PORTAL EXHIEIT 3 1III[IIIIIIIIt IIII(IIIII IIII 230095619-001 1/3 Ql %5IEDC 101 2023/04/12 Pl:Ot5%rSA.Rile KVAJRS (20183 5 ROTOR 122 + ff.: A44@@5%%4~e9.+3k (MK+S.i, lif)r@ iI t544iZ@Pt%CVIL%44-.ÃIK 410-135. 8 64%-~a& A: ktC~&4i",X%8 ~sSWK'i~=i (%t')t',&&4: EN@i. %KÃu 1%4A: NPz, lt.v-@@@At)IP+%-)fr+tJIP. %%%~&CCA: Zw@, lt.v-44%44t84~NNt)%. @5: ~ah:4~~5i%8I+8.4~ a], ~ii)frkÃkiI.%~a 74% 5 8.4P JkR R E%8khil+ 0 « iK N 26 +CW~@4% 180 + 532 k. kk&&kA: Iw@, %4%. %K4~ 1&CA: =t$ , Pt.v. k.iN,P)94%-ffr+)%. %K%& &&4A: %%, ltC4&iE@+t)%4%-)'frf4t%. N.4: +~ad, .~, , N.ik, i~lit% 4 t%w@cXM x@5Am- 29 w 7 +@ 1 ll 8 X 3 +. 45@i!i~i'445: ~5, 34 ill.+&gl)iP+4-)'fr t)4. %KN~&&eA: %4, Pt.v. e@kt)e+%8@t8. fk a . M]4~ , C.N., 8RK trtj~454Ex4[l544 29+ 7~@1 t) 8 fk 3 ~. %%%i"&&CA: Zi4, lt.v-i56i414)rr44-ffr @t)). The High People's Court of Beijing Municipality Civil Judgment (2018) ling Min Chn No. 122 Plaintiff; Gongqingcheng Panhui Investment Management Partnership L'nterprise Private Equity Park, Jiujiaug City, (I,imited Partnership), address: 410-135 Gongqing City Jiangxi Province, China. Executive Partner; Beijing Qiebao Asset Management Co., Ltd. (Representative; WANG Xindi). Agent ad litem: YE Xin, lawyer of Beijing Commerce & Finance Law Oflices. Offices. Agent ad litem; WANG Jialu, lawyer of Beijing Commerce & Finance Law Defendant: liarbin Gloria Group Co., Ltd, address; Room 532, No. 180 Hongqi Street, Nangang Building 26, Hi-tech Entrepreneurship Center, Harbin Hi-tech Industrial Development 7xine, Heilongjiang Province. Legal Representative: BAI Lihui, Chairman. Agent ad litem: WANG Bo, lawyer of Beijing Iqaizhcngcheng Law Firm. Agent ad iiiean Gao Ying, lawyer of Beijing Haizhengrheng Law Firm. Defendant: ZHU Jiman, male, born on Han nationality, residing at No.3, 8/F, Entrance 1, Building 7, 29 Taoyuan South Road, Lianhu District, Xi'an City, Shaanxi Province. Agent ad litem: WANG Bo, lawyer of Beijing Haizhengcheng Law Firm. Agent ad lirem: GAO I.u, lawyer of Beijing Haizhengcheng Law Firm. Defendant: BAI Lihui, female, born on Han nationality, address: No. 3, 8/F, Entrance 1, Building 7, 29 Taoyuan South Road, Lianhu District, Xi'an City, NOTARIAL CERTIFICATE (Translation) (2023) J.F.Y W.J.Z.Zi, No. 977 Applicant: Gongqingcheng Panhui Investment Management Partnership Enterprise (Limited Partnership), Address: 410-135 Gongqing City Private Fquity Part, Jiujiang City, Jiangxi Province. Attorney: Zhao Yi, female, born on I.D. Card No. Item of Notarization: Conformity of Photocopy and the Original This is to certify that the photocopy attached hereto is in conformity with the original of Civil Judgment shown to me by Zhao Yi, the attorney of the applicant. Notary; Zheng Luyan Beijing Fangyuan Notary Public Once The People's Republic of China March 14, 2023 (2023i 5&51ht Yr.iiE8-% 978 w W~AA: Ã%4%@R%%@k&k+~ (4 5+8.), hiNiTIN4AKVPt4.%%4! %k+W K 410-135. 4%1&CA: kk, 4, k~iECV.; 444/848K 5ik~g si& XR@X%44 (2023) 5ZIPl Y~&4% 977 !"! C)2!i'.?456 NOTARIAL CERTIFICATE (Translat&on) (2023) J.F, Y W.J.Z.Zi, No. 978 Applicant: Gongqingcheng Panhui Investment Management Partnership Enterprise (Limited Partnership), Address: 410-135 Gongqing City Private Equity Park, Jiujiang City, Jiangxi Province. Attorney: Zhao Yi, female, born on ID Card No Item of Notarization: Conformity of Translation and Original This is to certify that the English translation enclosed is identical with the Chinese original of the Notarial Certiftcatc (2023) J.F.YW:J.Z.Zi, No. 977. Notary: Zheng Luyan Beijing Fangyuan Notary Public Office The People's Republic of China March 14; 2023 IAi'--""--=-=-. - -. i kC@23009 5619 — 001 99 (@4 ) Ig iZ 09%8 s)l ff lE j0 -)6 X ~n'ufim )pt 4. +rPAK90gaIPIRWt Stgtm 090gk :+NB i'E PI g : Illlllllllllllllllilll essssasa (tz People's Republic of China) Municipality of Beijing ) ss: Embassy of the United ) States of America ) c, Katelyn C. Warden Vice Consul I, , Consul/Vice Consul of the United Ar, States ofAmerica in Beijing, tjte People's Republic of China, duly commissioned and qualified, Nn ~ (4 sra whose true signature and official do hereby certify that seal are, respectively, subscrjbed and affixed to the foregoing document, was on the W7 day of /N 202/ an oificer of the Ministry of Foreign Affairs of the People's Republic of China, duly commissioned and qualified, to whose official acts faith and credit are due. IN WITNESS WHEREOF I have hereunto set my hand and affixed the seal of the this Embassy of the United States 9f America in Beijing, the People's Republic of China ( 0 day of NOIV, 202~. Katelyn C. Warden 'ce Consul CEkTIFICATF. t)F TII ANSI.ATION 0 3 in Wang. being neer the agc of eighteen, duly sworn and deposed, lmteby swear and crest to thc following*. Myqu;ttilications:t, a utntslator are as Iollows; I grew up in thc I'coplc's Kcpubhc ol China ("PRC ') and Chinese is my naticc ianguagc. I lcamcd English fmm elementary schon 'ue coiiegc in the I&RC Ior a total of i6 yean ol'study. I earned a Bachelor's Degme in Tmn'tauon and lntcrpr.ting in 2031. sttbscquemly I camcd a hlastcr's Degree in Bu'incss Analytics 1«m Soudtcnt htedtodi,t Uniccrsity in 2033, and I curtently reside in the Umted States I liathcr certify dtat, to dtc best of my hnowlcdgc, thc attached docurncn's ia E g and accurate translations of the attached documents in Chtnc~ I certifY is true and correca Signature of Tmnslatnr HI 71 6334860 Telephone Nomina lbr Translator +Date Yin Wane Ntaue of Translator " underpcnalty ofpcr)uty under the,lawS of the State ot California that dtc foregoing State, of Texas ) ) ss: County'City of pajistS ) by 4n Wdln61 ol'onth The forewing insuument was acknowledged rutd swont bciorc mc this date of ):ghssats W year nf I 2.f) 2 9 Notary Public: Vts~p pf) g (~0bI q I Registmtion Numbcn ) 33M& 7'\ 0 My commission cxPircs on'gg7)0/fxy2I rtk S) tft )(1 COm pany Number NAR1 )7S7S78 12 Q4 Directors A %4 (If(((E,) Director(NaturalPerson) fat ggt)y — dryfgrttgigrALM ptitigt Jf a /4'gtr Usa Continuation sheet 8 if mars than 1 directoris a nslursl parson) ~ 47)tyyyAFPM'tg)4MZE P gg P(sass lick lhs relevant boktas) )g& ttfil)t IR)ltg 4 (tv E) Alternate to Capacity Director Alternate Director Name in Chinese ttk SE (th E Et'umamel Name in Enggsh 4 4'- )t)r It) ))8 C Previous Names English'inn 4'c Chinese I (Nil) (Nil) PJ 4g 4*@ I (Niil) Alias Chinese I English (Niil) l Q (E ttL Residential No. D-501, Building 7, No. 29 Taoyuan South Road .Address Xi'an City, 710000, Shaanxi Province lg tg E tts tgr concur~Region The People's Republic of China ~ tgltitl tth (Nil) Email Address 8) B 5) r)g Identirication (s) %)Ls*&iRgt) gg Hong Kong Identity Card Number (b) R ytl % gt Ig gg v'ts tg The People's Republic of China gt ttg E28991047 Numbers gt gg)t Pago 4 to%last 1I2014 (2014 te 3 n 1 case iacsaon Nc. 1/2014 (March 2014) rrc S] t(d (E Company Number NAR1 L 12 I4 Directors (gt&% ccnrdi 8, I+ ()th A i(()i)(() ) Director (Body Corporate) (t(gE(sylg82EI((E(rEAAygl igy(((((M c gtdy Uss Congnuslion sheet Of(mors Ihsn 2 directors are body corpora(s) bytybyt((iekcigfycCM Y (E please lick the relevant bor(ssj l Al& %)i(iit(t (PE) Alternate to Capacity Alternate Director lP%8% Name in Chinese %%4% Name in English L Address lgl ty y'tb g5 Counlryy'Region ~ m E(t((b ttt Email Address Qa E) ((re Company Number r~~ (Pdtylfyttygra EiygytaA tygrt (Only sppecsbls tc body ccrpcrsls rsglslsncd In Hens Kccgt by NÃA(lydia'((tfy(ffflz p yg p/sess (ick Ihs rslsvsnt bor(esp e 2 yt5y Capacity ytt E( Director (tg (E )E E( Alternate Di ale to 0564(t() Name ln Chinese 2(r % 4 tt() Name in English Address (E(EA'(E(E Counby/Region ~ ttt E) (lbh( Email Address ~s 7a @ (E Company Number (Pig(I(PI yyif 2(tr tydy P A gag(i (only sppscsbls lc bcdy ccrpcrsfc nnysfelsd in Hong Kcngt Ul (1 sgigit Psgs5 (setula( I/2014 (2014 ts 3 (() 3pccucsdcn Hb. 1/2014 (Msnh 201 4) /aigs Sett Company Number NAR1 )757878 12 8 4L'irectors (gt rN coors) C. ()iiQK4 Reserve Director ( R NI itt N y(% 4 — I tt IIS S )lt tt W lip yy tu S(t — )It EI gt) 8, A //2 =3 ) (Only applicable to a private company with only one member who is also the sole director of the company) 03ckk4 Name in Chinese Name in English Surname l Other Names ~ gt )tl %4 Previous Names Chinese l 2/) 4 Atlas Chinese English ~ Residential Address BI%/Ieg( Counuy/Region ~ stlt gt % Email Adrirass ig 53%% Identification (a) $ %%&Btty(@ Hong Kong Identity Card Number k I (b) SI( %% tg IE 8 Ie gi Passport ISSuing Ccunuy/Regicn ~ gt tg Number ~ Iae)is st 1/2014 (2014 ra 3 /I ) 3pooilioaiion No. 1/2111 4 (Mach 2314) fifi Company Number 1757878 I S 13 %)J(tg yxxgo(/Jg JS@(N particulars of Member(s) of a Company Having a Share Capital fyy)fgxt)y/fh 744///f/lf//ltx//'ompany Ireving e share cspiielmusl complete Ibis section) fgffiyfi)f/tyykk///All& y (S Please Sick fhe rplevenr bcx 5 d) Z ig 'rx =oJ (S Iit ft fff %l N'(t %.- Particulars of members of a non-listed company ere listed in Schedule 1 Xfg& 5 gg fitt R N(fi)yr)k I)t8: Particulars of members of a listed company are listed in Schedule 2 14 y/bÃJ@t)(( Company Records (d)A/)r+Jfi af/ildf)y D «fgr Use ccntinuaiicn sheer Difihs space provided is insvifcienl) & HSI)y 7 yi)Rfitt(SIIIJIIEWttfifi%(PN'I 6 )Igi)S63RfifiS)5ffitf yf) Address where the following company records are kept (If not kept at the registered office stated in Section 6) & J (H fifr Company Records IS bb Address N/A N/A 15 )(S LS I Statement ( g))gigA x) a/ 'xyffyfh'//ryy ygZ w gf Jf f„.yl yf fd/frfifi Fcr e pn'vale company, please tick ihe twx lo maire rhe Sieiemeni) jug f)t)sfifi&mfiten-(t))fttgg gfiaffffstg H)fi)fis(JD)ftsg))stfig tfia )tt)fifi&D)fifiyffiba)s (P)Bfifiitfi) gfi)SSfitH(iNS) Li)Sa)&@Ay@)fit& 3(/g(XGS(fi)dk(S(fi(St: fo)Kqfigff(lfiA f(2X 4rPgi(dtgg@22H)WSHit()SJid 4 BS(t(tK+dgZStffffifiB ')fit((fi(S &DJtt((ff) )g & 11(2) Si 24 St 32 & J fifi jfi A )ffi gf + (6 fifi ffi PI IS A ~ The company has not, since ths date of the last annual return (or since the date of incorporation in ths case of the first annual return), issued any invitation to the public to subscribe for any shares or debenlures of the company and that if the number of members of Ihe company exceods 50 as at the date of Ibis return, the excess consists wholly cf persons who, under section 11(2) of the Companies Ordinance, are excluded In the calculabon of the number of membem of the company. ig i Advisorv Note IIIN&%tfi@yffgfifigt&g)8fififfifififitffif (JfidltgffiSSI) gtfifiEMIfifilffifififififcf)fitg — fififgB ~ As directors of ths company are advised lo read 'A Guide on Direr tore'uties'ublished by the companies Registry snd acquaint themselves with ihe general duties of directors outlined in the Guide. gc sp fi( Sf ffi (S F fir) gt ) 2 This Return includes the folfowlng Continuation sheet(s) St )3 Contlnuatlon Sheet(s) A 6 C ~ )fi ffit Number of pages 0 0 0 g fififif- Signed 18 July 2022 fit S Name: ZI Jian H )S Oate s(% Oirectorxy& m*," m Cepnpany-Sesrotary BDD ) /IMM I IPYYYY Jf//I y, Pra/I/d; Deleie kvhichever does nci apply St.fif Pegef; a Ifi rNMM 3 rxcts Irc M h 3 s I 3 pssasssos No. 3/2cl 4 Iusrsk 2ct 4) F." NAR1 [gf 4— Schedule 1~ (0PZ Pt'-f'i~'4 MPH FOR NON-LISTED COMPANY) d IP f((0104) t@)tf 8 Sl Date to which this Return is Made Up rrc a) 0)(f) Company Number 00 I 2022 )7S78VI) B oo ff Iam Ig YYYY N j:ilf 'i~ Dj (f) h)I 5@()'I (% t 3 % ) Particulars of Member(s) of a Non-listed Comoanv (Section 13) (fff fgffrteyyd if ~~'efnrfffyfffffff Jf yff&'g17$ 'f8 — fgfggftr'7$yfftffrr yg— (Non-Iisted company havings share cepiiat must compteie tnis page. 7 If the spece provided is insufficien, or if there is more than one cress of shares, please use addrtionat Schedule 1.) gtek'Ipgg&gg@N f) gggbhp (0)giig particulars of Member(si as at the Date to which this Relum is Made ~U Itdyfw Bf Class of Shares Ordinary I)bi(KI0))0)l'ABQ(yNttf(t Total Numberof issuedShares inthis Class 10,000 It(f) Shares (ft 4 8 4 t)f I)t 20 )0% R ftf $4 IR Name Address Current Transferred Remarks Holding ftt f) B N0 Number Date k No. D-SOI, Building 7, No. 29 Taoyuan South Road, Xi'an 10,000 ZHU Jien Ctty, 710000, Shaenxt Province, The People' Republic