Motion for Child Support in Zhengjun Dong, Wen Lin, Kaixin Hong, Chenglong Wang, Fanhui Kong, Chu Lee, Chingwa Wong v. Gtv Media Group, Inc., Saraca Media Group, Inc.| Trellis.Law

On April 01, 2021 a Motion-Secondary was filed involving a dispute between Chenglong Wang, Chingwa Wong, Chu Lee, Fanhui Kong, Kaixin Hong, Wen Lin, Zhengjun Dong, and Gtv Media Group, Inc., Saraca Media Group, Inc., Wengui Guo, for Commercial Division in the District Court of New York County.

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FILED: NEW YORK COUNTY CLERK 12/30/2022 10:12 AM INDEX NO. 652190/2021
NYSCEF DOC. NO. 175 RECEIVED NYSCEF: 12/30/2022

SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF NEW YORK
----------------------------------------------------------------------X
ZHENGJUN DONG, WEN LIN, KAIXIN HONG
and CHENGLONG WANG, individually, and
on behalf of all others similarly situated,

Plaintiffs, Hon. Andrew Borrok

-against- Index No. 652190/2021

GTV MEDIA GROUP, INC., SARACA MEDIA
GROUP INC., and WENGUI GUO,

Defendants.
----------------------------------------------------------------------X

MEMORANDUM OF LAW IN SUPPORT OF NONPARTY’S
MOTION TO QUASH NONPARTY SUBPOENAS AND FOR
PROTECTIVE ORDER AND SANCTIONS

Brian Witthuhn
Justin S. Weddle
Weddle Law PLLC
250 West 55th Street
30th Floor
New York, NY 10019

Attorneys for Nonparty G-Club Operations LLC

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TABLE OF CONTENTS
Introduction ................................................................................................ 1
Background ................................................................................................. 1
A. The Complaint................................................................................ 2
B. Plaintiffs’ Prior Attempts to Obtain Discovery about Nonparty
G-Club ........................................................................................ 2
1. First Citibank Crane Subpoena ................................................ 3
2. Quashed Crane Subpoena ......................................................... 4
3. G-Club Subpoena and Pending Motion to Quash .................... 6
4. September 2022 Crane Citibank Subpoena ............................. 8
C. Current Signature and Morgan Stanley Subpoenas .................... 9
Argument .................................................................................................. 12
I. Plaintiffs Seek Utterly Irrelevant Information ................................. 12
A. No Plaintiff Has Standing with Respect to G-Club ................... 13
B. The Undisputed Facts Foreclose Any Purported Relevance to
Discovery about Nonparty G-Club .......................................... 15
II. Plaintiffs Seek Improper Pre-Class Certification Discovery ............ 20
A. Applicable Law ............................................................................. 21
B. The Scope of the Nonparty Subpoena to G-Club Severely
Violates the Limits of Pre-Class Certification Discovery ...... 24
III. The Court Should Issue a Protective Order and Sanction Plaintiffs25
A. Applicable Law ............................................................................. 26
B. Plaintiffs’ Repeated Misconduct .................................................. 28
1. Misuse of Subpoenas ............................................................... 28
2. Frivolous Legal and Factual Claims....................................... 32
C. Substantial Sanctions Are Warranted ........................................ 36
Conclusion................................................................................................. 37

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TABLE OF AUTHORITIES

Cases

Arch Ins. Co. v. Delric Constr. Co.,
174 A.D.3d 560 (2d Dept. 2019) ........................................................... 28
Barnes v. Osofsky,
373 F.2d 269 (2d Cir. 1967) .................................................................. 14
Burdick v. Tonoga, Inc.,
60 Misc. 3d 1212(A), 2018 WL 3355239 (Sup. Ct., Rensselaer County,
July 3, 2018) .......................................................................................... 24
Chang v. Westside 309 LLC,
206 A.D.3d 491 (1st Dept. 2022) .......................................................... 25
Chang v. Westside 309 LLC,
Decision & Order on Motion, Ind. No. 153031/2018 (Sup. Ct., N.Y.
County, March 2, 2022) ........................................................................ 24
Chimenti v. Am. Express Co.,
97 A.D.2d 351 (1st Dept. 1983) ............................................................ 21
Gewanter v. Quaker State Oil Refining Corp.,
87 A.D.2d 970 (4th Dept. 1982) ............................................................ 23
In re Beiny,
129 A.D.2d 126 (1st Dept. 1987) .............................................. 29, 33, 35
In re Hoppenstein,
209 A.D.3d 492 (1st Dept. 2022) .......................................................... 32
Reiken v. Nationwide Leisure Corp.,
75 A.D.2d 551 (1st Dept. 1980) ............................................................ 23
Rodriguez de Quijas v. Shearson/Am. Express, Inc.,
490 U.S. 477 (1989) ............................................................................... 18
Rodriguez v. Metro. Cable Commc’ns,
79 A.D.3d 841 (2d Dept. 2010) ............................................................. 22
Smith v. Atlas Int’l Tours,
80 A.D.2d 762 (1st Dept. 1981) ............................................................ 22
Velez v. Hunts Point Multi-Service Center,
29 A.D.3d 104 (1st Dept. 2006) ............................................................ 31

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Statutes

C.P.L.R. § 3103(a) ................................................................... 26, 29, 33, 36
C.P.L.R. § 3120(3) ............................................................................... 26, 32

Other Authorities

Patrick M. Connors, Practice Commentaries, C.P.L.R. § 3120 (2018) ... 27

Rules

22 N.Y.C.R.R. § 130-1.1...................................................................... 28, 33

Treatises

7 Carmody-Wait 2d § 42:229 (Sept. 2022 Update) ................................. 21

iii

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INTRODUCTION

Almost one year ago, nonparty G-Club Operations LLC (“G-Club”)

requested a protective order to avoid burdening G-Club with plaintiffs’

abusive discovery practices in this litigation, in which G-Club is not a

party and has no involvement. Plaintiffs have since repeatedly taken G-

Club’s prediction as an invitation to issue improper discover demands

rather than as a warning. In their most recent round of demands,

plaintiffs seek irrelevant financial information concerning G-Club and its

members from nonparty banks, and plaintiffs have done so covertly in

dereliction of their statutory obligations. The subpoenas should be

quashed, and plaintiffs should be sanctioned.

BACKGROUND

Nonparty G-Club is a limited liability company organized under the

laws of Puerto Rico. G-Club operates “G|CLUBS,” a luxury concierge

service that is provided to customers on a paid membership basis.

G|CLUBS members have access to, among additional services, a 24/7

concierge service center, an exclusive membership ID, discounted prices

on fashion collections, music, and various events.

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A. The Complaint

Plaintiffs brought this action on April 1, 2021. They brought it

against defendants GTV Media Group, Inc. (“GTV”), Saraca Media

Group, Inc. (“Saraca”), and Wengui Guo, on April 1, 2021, “under Sections

5, 12 and 15 of the [Securities Act of 1933], 15 U.S.C. §§ 77e, 77l, and 77o

. . . on behalf of all investors (‘Class’) who purchased or otherwise invested

in securities of Defendant GTV in the offering (‘GTV Offering’) conducted

by Defendants between approximately April 1, 2020 and the present.”

NYSCEF 1 (Complaint) ¶ 1. G-Club is not a party.

B. Plaintiffs’ Prior Attempts to Obtain Discovery about
Nonparty G-Club

Plaintiffs allege that defendant Guo, in a social media livestream

in 2021, said that individuals who purchased G-Club memberships

“would be entitled to receive” shares in GTV. NYSCEF 66 (Plaintiffs’

Motion) at 4. Plaintiffs, however, do not allege that G-Club sold GTV

shares to anyone. Nor do plaintiffs dispute that every G-Club member

agreed: that their membership was not an investment (in GTV or any

entity); that any statements by defendant Guo about G-Club were void

and not part of the terms of membership; and that G-Club members

agreed to mandatory arbitration and to waive the right to participate in

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a class action. NYSCEF 150 (Membership Agreement); NYSCEF 143

(Disclaimer); see NYSCEF 152-55 (Plaintiffs’ Opp.) (nowhere contesting

those irrefutable facts).

Nonetheless, plaintiffs have repeatedly used this litigation against

defendants, over the course of more than one year, to attempt to obtain

irrelevant, confidential, and extensive information about nonparty G-

Club and its members through improper nonparty subpoenas.

1. First Citibank Crane Subpoena

Another nonparty, Crane Advisory Group LLC (“Crane”), used a

bank account at Citibank (“Crane Citibank Account”) to perform escrow

agent services on behalf of G-Club. That is, Crane received membership

payments from G-Club customers into the Crane Citibank Account

pursuant to a written Payment Facilitation Agreement. G-Club and

Crane had a comprehensive Non-Disclosure Non-Circumvention

Agreement (NYSCEF 74) in place to protect the confidentiality of G-

Club’s financial information, and of the personal identity and financial

information of G-Club members.

On September 27, 2021, plaintiffs subpoenaed Citibank to obtain

information about G-Club members and the Crane Citibank Account.

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NYSCEF 42 (“September 2021 Citi Crane Subpoena”). Plaintiffs defined

the “Relevant Period” for the subpoena as “January 1, 2019 to the

present,” i.e., as starting more than one year before the “GTV Offering”

allegedly began. Id. at 5. Plaintiffs demanded, among multiple other

blanket requests, “[a]ll documents sufficient to identify all wire transfers

received into [the Crane Citibank Account] during the Relevant Period,

including but not limited to the identity of the sender of the wire, the

sending bank, sending account number, and the amount of the wire.” Id.

at Doc. Request No. 3.

On October 29, 2021, Crane moved to quash plaintiffs’ September

2021 Citi Crane Subpoena because it demanded irrelevant and

confidential information. NYSCEF 41. Plaintiffs thereafter withdrew

their subpoena, and Crane therefore withdrew its motion on November

23, 2021. NYSCEF 47.

2. Quashed Crane Subpoena

On or about January 5, 2022, plaintiffs issued another subpoena

demanding blanket access to irrelevant, confidential personal identity

and financial information of G-Club and its members. NYSCEF 75

(“January 2022 Crane Subpoena”). This time, plaintiffs subpoenaed

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Crane, demanding financial records regarding the Crane Citibank

Account, as well as communications involving Crane. Id. G-Club learned

of the subpoena only indirectly; plaintiffs did not provide it to G-Club.

On February 2, 2022, G-Club, as a nonparty, moved to quash the

subpoena and for a protective order to block plaintiffs from further

improper subpoenas seeking to obtain information about G-Club and its

members. Motion Seq. 005.1 G-Club demonstrated that the subpoena

failed to provide notice why the material sought was relevant, and sought

improper pre-class certification discovery; and that plaintiffs improperly

sought confidential financial and personal identity information of G-Club

and its members. NYSCEF 76.

Plaintiffs opposed, arguing that the subpoena was not defective,

that a discovery stipulation into which the parties entered (not

nonparties, such as G-Club) alleviated confidentiality concerns, and that

because the subpoena demanded information purportedly relevant to

merits and damages issues, it was properly issued prior to class

certification. NYSCEF 89. Plaintiffs also argued that G-Club had no

1 Crane separately moved to quash. Motion Seq. 007.

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standing to move to quash the subpoena or for a protective order because

plaintiffs issued it to Crane, not to G-Club. Id. at 8, 14 n.6.

On September 16, 2022, the Court granted G-Club’s motion and

quashed the January 2022 Crane Subpoena. The Court agreed that the

subpoena was defective on its face, and that G-Club had standing to

object to the subpoena. NYSCEF 123 at 3. The Court quashed the

subpoena because plaintiffs failed to comply with a basic requirement of

nonparty subpoenas—a statement providing notice of why the material

was purportedly relevant. Even though the plaintiffs provided no such

articulation—which would provide the starting point for litigating the

propriety of the subpoena or the relevance of the material sought—the

Court sua sponte posited that the documents were necessary for class

certification and on the merits. Id.

3. G-Club Subpoena and Pending Motion to Quash

On September 16, 2022, the same day the Court’s decision quashing

the January 2022 Crane Subpoena was entered, plaintiffs issued a

subpoena directly to nonparty G-Club. Plaintiffs demanded near total

access to G-Club’s records and to the personal and financial information

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of G-Club members, as well as for a G-Club representative to testify at a

deposition (“September 2022 G-Club Subpoena”). NYSCEF 142.

G-Club moved to quash and for a protective order, explaining that:

the subpoenaed information was irrelevant because no plaintiff or

prospective plaintiff had standing based on any actual or purported

purchase of a G-Club membership; plaintiffs are seeking improper pre-

class certification discovery; and the subpoena, in any event, is

overbroad. NYSCEF 141.

Plaintiffs opposed, claiming that the information was relevant

because on March 11, 2021, defendant Guo said in a social media

livestream that individuals “who ‘purchased’ G-Club memberships would

be entitled to receive 10 GTV shares per dollar spent ‘purchasing’ G-Club

memberships.” NYSCEF 155 at 4. Plaintiffs also claimed that they are

“entitled to seek both merits and class certification discovery,” and that

the subpoena is not overbroad. Id. at 10-13.

The motion to quash the September 2022 G-Club Subpoena and for

a protective order is pending. Motion Seq. 010.

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4. September 2022 Crane Citibank Subpoena

Unbeknownst to G-Club, on or about September 19, 2022, plaintiffs

once again subpoenaed Citibank to obtain blanket access to the

confidential financial and personal identity information of G-Club and its

members through the Crane Citibank Account (“September 2022

Citibank Subpoena”).

Plaintiffs provided no notice to G-Club of the subpoena seeking

information about G-Club and its members. It also does not appear that

plaintiffs provided any notice to Crane—plaintiffs failed to include G-

Club or Crane on an email to defendants linking the subpoena, and

unlike prior subpoenas, Crane has filed no motion to quash. Exhibit 1

(Sept. 19 email from plaintiffs’ counsel to defendants’ counsel attaching

September 2022 Citibank Subpoena; not sent to G-Club or Crane). G-

Club first learned of the September 2022 Citibank Subpoena more than

three months later, on December 21, 2022, when counsel for defendant

Guo forwarded an email (Exhibit 1) with an expired link to the subpoena

to counsel for G-Club. Witthuhn Aff. ¶ 4a. Neither counsel for defendants

GTV and Saraca nor counsel for defendant Guo was able to provide G-

Club with a copy of the actual September 2022 Citibank Subpoena. Id.

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In addition, it appears that plaintiffs did not provide defendants

with the subpoena return from Citibank until November 29 and

December 21, 2022, at least forty-one days or more than two months after

plaintiffs received the documents from Citibank. Exhibits 2 & 3 (Nov.

29 and Dec. 21 emails from plaintiffs to defendants purporting to attach

documents produced by Citibank).2 Plaintiffs also did not notify G-Club

(nor, apparently, Crane) of the documents produced by Citibank.

C. Current Signature and Morgan Stanley Subpoenas

Now with blanket information in hand from Citibank regarding the

Crane Citibank Account, as a result of their surreptitious September

2022 Citibank Subpoena, plaintiffs issued yet two more nonparty

subpoenas to Signature Bank and Morgan Stanley Smith Barney LLC

(“Morgan Stanley”) seeking to trace funds from the Crane Citibank

Account to accounts at those banks (“Signature Subpoena” and “Morgan

2 In their emails to defendants, plaintiffs’ counsel stated merely that they had
“recently received” the documents from Citibank, without specifying the date when
Citibank produced them. Exhibits 2 & 3. G-Club, of course, has been kept in the
dark about the September 2022 Citibank Subpoena, but if we assume plaintiffs issued
it on September 19, the same day plaintiffs provided it to defendants rather than
earlier (which is not a safe assumption, given plaintiffs’ repeated failures to comply
with C.P.L.R. § 3120(3)), then the return date for the subpoena would have been
October 19.

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Stanley Subpoena”). Plaintiffs aver that these are G-Club funds. See, e.g.,

Exhibit 5 (Signature and Morgan Stanley Subpoenas) at pdf 4, 62.

Plaintiffs served Signature and Morgan Stanley with the respective

subpoenas on December 1, 2022. Exhibit 5 at pdf 60, 118. Nonetheless,

plaintiffs did not provide notice of the subpoenas to defendants until

eleven days later, on December 12, 2022. Exhibit 4 (Dec. 12 email from

plaintiffs to defendants linking Signature and Morgan Stanley

Subpoenas). Plaintiffs never provided notice of the subpoenas to G-Club,

about whom they are seeking information.3 G-Club learned of the

subpoenas only because counsel for defendants Saraca and GTV

forwarded them to G-Club on December 12. Witthuhn Aff. ¶ 4d.

In the Morgan Stanley Subpoena, plaintiffs demand comprehensive

information about a purported $60 million transfer of funds Crane

received on behalf of G-Club from the Crane Citibank Account to an

account at Morgan Stanley, information about that account, and

information about any other Morgan Stanley accounts of Crane. Exhibit

5 at pdf 4. Plaintiffs also claim, “[b]ased on Citibank’s records for the

3 It also appears that plaintiffs never served Crane with the Signature and Morgan
Stanley Subpoenas, as Crane, like G-Club, was not copied on plaintiffs’ belated email
to defendants. Exhibit 4.

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Citibank Crane Account,” that “over $9 million was transferred to an

account . . . held at Signature Bank by [Crane],” Exhibit 5 at pdf 62, and

demand similar information from Signature. Plaintiffs defined the

“Relevant Period” for both subpoenas as beginning January 1, 2019, i.e.,

more than one year before the alleged “GTV Offering” took place.

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ARGUMENT

I. PLAINTIFFS SEEK UTTERLY IRRELEVANT INFORMATION

Plaintiffs’ latest subpoenas fail on every level to seek relevant

information. Plaintiffs are pursuing an action based on the alleged

improper sale of unregistered securities (shares in defendant GTV), but

no one purchased securities from nonparty G-Club. Plaintiffs do not even

allege otherwise. The most plaintiffs claim regarding G-Club is that

defendant Guo mentioned G-Club in a social media post, but the express

terms of G-Club’s membership agreement provide that a G-Club

membership is just that: a membership, not an investment of any sort,

let alone in shares of GTV. Furthermore, individuals purchasing G-Club

memberships also expressly acknowledged and agreed to a disclaimer

stating that no one could rely on statements of defendant Guo referencing

G-Club. And, even if a dispute arises between a G-Club member and G-

Club, whether related to purported securities-related conduct or

otherwise, each G-Club member specifically agreed to arbitrate any

claims, and not to participate in a class action.

Plaintiffs’ counsel, on some level, seems to understand all that.

After all, they did not name G-Club as a defendant in their lawsuit. (Nor

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was G-Club subject to, nor even mentioned in, the SEC enforcement

action against defendants GTV and Saraca from which plaintiffs’ counsel

cribbed their lawsuit). Nonetheless, plaintiffs’ counsel has treated

G-Club like a defendant, issuing subpoenas, one after another, seeking

extensive, confidential, and burdensome discovery about G-Club and its

members.

Plaintiffs’ counsel’s repeated, backdoor attempts to use their

lawsuit against defendants GTV, Saraca, and Guo, to obtain information

about nonparty G-Club and its members are a paradigmatic abuse of the

discovery process. The most recent subpoenas, to Morgan Stanley and

Signature Bank, should be quashed, and an order protecting G-Club from

all such future attempts should enter.

A. No Plaintiff Has Standing with Respect to G-Club

The first insurmountable hurdle facing plaintiffs is standing. A

person may not offer or sell nonexempt, unregistered securities, 15 U.S.C.

§ 77e, and anyone who does is liable “to the person purchasing such

security from him” in the amount of “the consideration paid for such

security . . . or for damages if he no longer owns the security,” id. § 77l

(emphasis added); see also id. § 77o (holding a person who “controls any

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person liable under” Section 77l jointly-and-severally liable). Thus, it is

axiomatic—and clear from the plain statutory language—that only those

individuals who purchased a security offered in violation of Section 77e

have standing to obtain damages under Sections 77l and 77o, as plaintiffs

seek here. Accord Barnes v. Osofsky, 373 F.2d 269, 271-72 (2d Cir. 1967)

(holding that only plaintiffs who could prove they purchased shares

issued under defective registration statement had standing under

Section 77k, not individuals who purchased in secondary offering).

It is undisputed that no one purchased unregistered GTV shares

from G-Club. Neither plaintiffs nor the proposed plaintiffs allege that

they did so. At most, they claim that they purchased G-Club

memberships, and that (according to a Guo social media post) G-Club

members “would be entitled to receive 10 GTV shares per dollar spent

purchasing G-Club memberships.” See Exhibit 5 (Signature and Morgan

Stanley Subpoenas) at pdf 4, 62. But plaintiffs do not claim that they

actually purchased GTV shares from G-Club, as required for standing

under Section 77l. Therefore, plaintiffs’ vague claim—that “the

documents sought . . . are material and necessary to establish Plaintiffs’

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allegations that Defendants violated Sections 5 and 12(a)(1) of the

Securities Act,” Exhibit 4 at pdf 4, 62—is not and cannot be true.

Plaintiffs’ counsel’s repeated efforts to pry into G-Club’s finances

and confidential membership information can therefore have no

relevance to this action for damages, under the federal securities laws, on

behalf of individuals who allegedly bought unregistered GTV shares (not

G-Club memberships) from defendants GTV, Saraca, and Guo (not from

nonparty G-Club). See 15 U.S.C. § 77l.

B. The Undisputed Facts Foreclose Any Purported Relevance
to Discovery about Nonparty G-Club

In their fishing expedition, the only line plaintiffs’ counsel has cast

toward G-Club is the allegation that in 2021, defendant Guo said in a

social media livestream that G-Club members “would be entitled to

receive 10 GTV shares per dollar spent ‘purchasing’ G-Club

memberships.” See NYSCEF 66 (Plaintiffs’ Memo of Law in Support of

Motion for Class Certification) at 4. Even accepting that allegation, the

uncontested facts regarding G-Club memberships also foreclose any

relevance to demanding nonparty discovery from or about G-Club.

Each individual who purchased a G-Club membership agreed to a

Membership Agreement, and to having “reviewed, underst[ood], and

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agree[d] to” a disclaimer. See NYSCEF 140 (Witthuhn Aff.) ¶¶ 5-6.

Plaintiffs do not dispute that. See NYSCEF 152-55 (Plaintiffs’ Opposition

to Motion to Quash). The Membership Agreement specifically states that

the agreement provides just that (membership in G-Club), and that “the

membership is not an investment” in any entity. NYSCEF 150

(Membership Agreement) ¶ 12(e) (emphasis added). Plaintiffs do not

contest that either.

Plaintiffs’ counsel also do not dispute that any proposed named

plaintiffs who purchased G-Club memberships necessarily signed a

disclaimer stating that they understood and agreed that they could not

rely on any statement by defendant Guo (or anyone else) about G-Club:

NO ONE CAN RELY ON ANY EARLIER DESCRIPTION
BY MR. GUO OR ANY OTHER PERSON OF (I) THE
BENEFITS THAT COULD OR WOULD BE AVAILABLE
TO [G-CLUB] MEMBERS OR (II) ANY OTHER ASPECT
OF THE STRUCTURE OR TERMS OF [G-CLUB].

NYSCEF 143 (Disclaimer). Thus, nonparty discovery about G-Club and

its customers is irrelevant because it is uncontested that G-Club

members (including the proposed plaintiffs who joined G-Club)4 agreed

4 See NYSCEF 141 (Memo of Law in Support

Case Info

Judge

Andrew Borrok Track Judge’s New Case

Case No.

(Subscribe to View)

Document Filed Date

December 30, 2022

Case Filing Date

April 01, 2021

County

Parties

BALDIGA, WILLIAM R. Attorney
Brown Rudnick LLP Non Party
Chenglong Wang Plaintiff
Chingwa Wong Plaintiff
Chu Lee Plaintiff
Crane Advisory Group LLC Non Party
Fanhui Kong Plaintiff
GAVENMAN, JEFFREY SAMUEL Attorney for the Defendant
G-Club Operations LLC Non Party
GTV Media Group, Inc. Defendant
Kaixin Hong Plaintiff
KIM, JOO YUN Attorney for the Plaintiff
MITCHELL, AARON AUBREY Attorney for the Defendant
NI, ANGUS Attorney for the Plaintiff
Saraca Media Group, Inc. Defendant
TA, HUNG GIA Attorney for the Plaintiff
WARREN, CHRISTOPHER DONALD Attorney
Wengui Guo Defendant
Wen Lin Plaintiff
WILLIAMS, NATALIA DORA Attorney for the Plaintiff
WITTHUHN, BRIAN MONTER Attorney
YANG, YUE Attorney for the Plaintiff
Zhengjun Dong Plaintiff
JASMIN KIM Attorneys for Plaintiffs
ALEXANDER HU Attorneys for Plaintiffs
MICHAEL RYAN Attorney
STUART SARNOFF Attorney
NING YE Attorney
KEVIN TUNG Attorney
JONATHAN TREXLER Attorney
ANDREW MILTENBERG Attorney
WEI ZHU Attorney
Brian Lanciault Attorney
URIEL PINELO Attorney
EDWARD GREIM Attorney

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Motion-Secondary: Zhengjun Dong, Wen Lin, Kaixin Hong, Chenglong Wang, Fanhui Kong, Chu Lee, Chingwa Wong v. Gtv Media Group, Inc., Saraca Media Group, Inc.

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