As I stated in my complaint, the United States is vulnerable while facing the Unrestricted War initiated by the Chinese Government. We need stand up to fight against the Chinese Communist Party to protect the security of the United States and the American people.
God Bless America!
Gang Liu
January 13, 2011
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UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
----------------------------------------GANG LIU )
)
)
Plaintiff, )
)v. ) 1:11-CV-5229(PGG)(HBP)
) NOTICE OF OPPOSITION
PFIZER INC., GOOGLE INC., AND )
ROBERT L. BERNSTEIN )
)
Defendants. )
)
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MEMORANDUM OF LAW
IN SUPPORT OF PLAINTIFF PRO SE GANG LIU'S OPPOSITION TO DISMISS
Plaintiff Gang Liu respectfully submits this memorandum of law in support of his amended complaint (the "Amended Complaint") 11-5229 filed by pro se Plaintiff on July 29, 2011, and to oppose to dismiss the Amended Complaint in the motions filed by the Defendants Pfizer Inc. ("Pfizer"), Google Inc. ("Google"), and Robert L. Bernstein ("Mr. Bernstein").
FACTUAL BACKGROUND
The Plaintiff filed the Amended Complaint 11-5229 against the defendants Pfizer, Google, and Mr. Bernstein. Then the defendants filed motions to request the Honorable Judge Gardephe to dismiss the Amended Complaint. The defendants claimed in their motions that the Plaintiff fails to allege facts and failed to state valid claims as a matter of law. As the defendants still believe the evidences provided in the Plaintiff's Amended Complaint are not good enough, the Plaintiff is happy to provide more evidences to support his Amended Complaint.
1. Ms. Yinghua Guo ("Ms. Guo"), also named Elisa Guo, while worked as an employee at Wyeth was the key player to make Pfizer's acquisition of Wyeth.
2. Ms. Guo is a military officer and an agent for the Chinese People's Liberation Army ("PLA"). Ms. Guo continuously get instructions/orders/supports from the PLA. The PLA and the Chinese government are behind the Pfizer's acquisition of Wyeth.
3. To make the Pfizer's acquisition of Wyeth happen, Ms. Guo also got helps from Mr. Hank Wei ("Mr. Wei") and Mr. George Wu ("Mr. Wu"), as well as their companies.
4. Mr. Wei is a long time (over 10 years) consultant and a technical leading manager to provide IT service and support the Database for Pfizer. So, Mr. Wei was familiar with the technical tools of Pfizer, and can access the Pfizer's database.
5. Mr. Wu is the President and CTO of the ChinaSoft International ("CSI"), and the CEO of the DoubleBridge Technology Inc. ("DoubleBridge"). Mr. Wu frequently meet with Pfizer's executive management team to discuss business requests/requirements, as well as business opportunities, especially to cooperate with CSI, DoubleBridge, and the Chinese government.
6. The CSI is mainly controlled by the China Electric Corporation ("CEC"), which is a part of the Chinese government.
7. The Golden series, including the Golden Shield, are the key products/services of CSI's provided to the Ministry of Public Security (MPS) of China. The Golden Shield is also called the Great Firewall, which can help the Chinese Communist Party ("CCP") to do internet censorship. With the helps of CSI, the Chinese government arrested and persecuted many of Chinese dissidents, including Mr. Lin Hai, Mr. Huang Qi, etc.. It clearly shows that the CSI is not only simply a software company to provide IT service, but also played as accomplice for the Chinese government. It always ready to serve for the Chinese government, including espionage the U.S. military sensitive information as well as corporation information. Pfizer is listed as one of the major client on the CSI's website. That means, the Chinese government has the capability to access Pfizer's database, to espionage Pfizer's confidential file systems, etc..
8. DoubleBridge is a U.S. based IT firm and a subsidiary of the CSI. DoubleBridge sent many IT software engineers and Database Administrators to Pfizer as on site consultants.
9. Mr. Wei is the lead of the on site team at Pfizer for over 10 years. Mr. Wei and his team manage some of the database of Pfizer, and develop software tools for Pfizer. Most of such kind projects are outsourced to China, especially developed by CSI.
10. Through DoubleBridge, CSI, Mr. Wu, and Mr. Wei, Pfizer has extensive exposures to the Chinese government.
11. Upon Ms. Guo's requests, Mr. Wei and Mr. Wu met Ms. Guo frequently to provide technical supports to Ms. Guo and to manipulate tools that were used by Wyeth and Ms. Guo. Using such manipulated tools, Ms. Guo eventually gave very low prices for Wyeth products in the North American region, especially in Canada market. It was well-known that the relevant pharmaceutical products in Canada are much cheaper than the same products in the United States. Due to the low prices in North America region (except the United States), Wyeth could no longer survive. Pfizer took advantage and the opportunity to acquire Wyeth. This opportunity was created by Ms. Guo with helps from Mr. Wei and Mr. Wu, and all of them are serving for the Chinese military or the Chinese government. The Chinese government is the black-hand behind the Pfizer's acquisition of Wyeth.
12. In 2008, the Plaintiff happened found Mr. Wei came to the Plaintiff’s home to meet with Ms. Guo. Around the end of 2008 or early 2009, the Plaintiff saw Mr. Wei ran out from Plaintiff’s home at 11 Ridings Parkway, Princeton, NJ, when Plaintiff came home from work. Mr. Wei was so hurry to run out that he didn't say hello to Plaintiff even he knew Plaintiff. Ms. Guo lived in that house at that time. Ms. Guo immediately threatened Plaintiff not telling anyone about her meeting with Mr. Wei at home. Ms. Guo told Plaintiff that it was a criminal activity for her to ask Mr. Wei to come home to manipulate the Wyeth pricing tool. Ms. Guo also said that she would be arrested and jailed if FBI or Wyeth knew about what she did with Mr. Wei at home. The Plaintiff had not understood why Ms. Guo and Mr. Wei were so panic for their meeting at home, until Wyeth was acquired by Pfizer and until Plaintiff found Ms. Guo was a Chinese Military agent.
13. It was true that Ms. Guo was married with the Plaintiff at the end of 2007. However, Ms. Guo cheated the Plaintiff to get the marriage. She hid her true identity as a Chinese military background. In fact, Ms. Guo was sent by the Chinese military to marry the Plaintiff and to watch and harass the Plaintiff. The Chinese security agents applied the so called "Schemes of a Beauty" (Mei Ren Ji) to destroy the Plaintiff’s life. Ms. Guo was the "Beauty Tiger" in this conspiracy trap designed by the CCP.
14. The Plaintiff was used to be one of the well known dissident and a famous student leader during Tiananmen pro-democracy movement in 1989. Due to his important role in the pro-democracy movement in China, the Chinese government hates the Plaintiff and wanted to destroy the Plaintiff. The Chinese government not only jailed the Plaintiff for six years from 1989 to 1995, but also wanted to destroy the Plaintiff’s personnel life and his American dream even after the Plaintiff escaped to the United States in 1996. The Chinese government has the intentions and the capabilities to do all such conspiracies.
15. The Plaintiff is not the only Chinese dissident to experience such "Schemes of a Beauty" trap. Mr. Wang Bingzhang, Mr. Peng Ming, and Mr. Zhang Hongbao were all used to be the well known Chinese dissidents and were friends of the Plaintiff. All of them had experienced the same traps designed by the Chinese government.
16. Dr. Wang Bingzhang is known as the founding father of the Chinese democracy movement in the United State. He has been the Number 1 target by the Chinese security agents for the past 30 years. The Chinese security agents applied the so called "Schemes of a Beauty" to Dr. Wang Bingzhang. In early 2002, the Chinese government sent two sisters, Ms. Yan Qingxin, and Ms. Zhang Qi, both are Chinese military agents, to approach and to date with Dr. Wang Bingzhang. In June 2002, Dr. Wang Bingzhang was first lured to Vietnam by Ms. Zhang Qi, who was known as Wang Bingzhang's girl friend at that time, then they were kidnapped by a group of Chinese military agents. And then they were found in China. Six months later, Dr. Wang Bingzhang was give life sentence by the Chinese government, while Ms. Zhang Qi was sent back the United States! Wang Bingzhang has served 10 years in Chinese prison and has no hope to be released by the Chinese government.
Please check the following link for more details about Dr. Wang Bingzhang's case:
http://en.wikipedia.org/wiki/Wang_BingzhangMs. Yan Qingxin and Ms. Zhang Qi, along with Mr. Ye Ning, Mr. Feng Donghai are not only involved in the kidnapping of Mr. Wang Bingzhang, but they were also involved in the kidnapping of Mr. Peng Ming on May 4th 2004.
Please check the following links for more details about Mr. Peng Ming's case:
http://www.world-rights.org/china/Peng_Ming_Case/AP_Report_on_Peng_Ming_2nd.htmEver more, Ms. Yan Qingxin and Ms. Zhang Qi, along with Mr. Ye Ning, Mr. Feng Donghai are also involved in the 49 false accusation against Mr. Zhang Hongbao, and eventually made Mr. Zhang Hongbao killed in 2006.
Please check the following links for more details about Mr. Zhang Hongbao's case:
http://en.wikipedia.org/wiki/Zhang_Hongbao
17. Ms. Yan Qingxin and Ms. Zhang Qi, along with Mr. Ye Ning are all living in the United States without any investigation, While Mr. Feng Donghai moved back to China and now is the Head of Chinese Security Agency who was in charge of the South-East Asia region.
18. Now, some of these Chinese security agents, including the above mentioned Ms. Yan Qingxin, Ms. Zhang Qi, Mr. Tang Yuhua, Mr. Ye Ning, Mr. Zhao Yan, and Ms. Guo Yinghua are working together and targeting at the Plaintiff. Ms. Guo has been the key player in this trap to destroy the Plaintiff. It is fortunate that Mr. Tang Yuhua was arrested by FBI on November 21st, 2011.
19. Ms. Guo was the key contributor to the Pfizer's acquisition of Wyeth. To compensate or to award Ms. Guo's contribution in the Pfizer's acquisition of Wyeth, Pfizer continued to hire Ms. Guo as a director responsible for Strategic Planning of Pfizer, and is in charge of the market planning for Asian-Pacific region. Before merged with Pfizer, Ms. Guo worked as Associate Director for the Strategic Planning group in Wyeth. She had many colleagues in that department. However, Ms. Guo got offers from Pfizer long time before Wyeth closed, while all of her colleagues including her boss were laid of before the merge. Why Pfizer kept only Ms. Guo and none of her colleagues? That is an exceptional reward to Ms. Guo. That reward must not be based on regular performance. Instead, it was a reward to what Ms. Guo did for the Pfizer's acquisition of Wyeth. Only Pfizer could tell the real reason. Hope the defendant Pfizer can provide more explanations and reasons for hiring Ms. Guo.
20. Ms. Guo received $60,000 annually from the Chinese military. Mr. Yan Wenming, another Chinese military agent came to the United States and gave $60,000 cash to Ms. Guo as reward. Ms. Guo had at least 14 bank accounts, most of them are used to do money laundry or receive money from the Chinese military agencies.
21. Mr. Wu was also promoted and awarded by the Chinese government. Mr. Wu was promoted to the president and CTO of the CSI. Mr. Wu and Mr. Wei travel to China very often and meet with CCP leaders and officers from the military or secret security agencies. Both Mr. Wu and Mr. Wei received huge hiding benefits.
22. The Chinese government also got huge benefits from the Pfizer's acquisition with Wyeth. First of all, the Chinese government bribed many related executive managers in Pfizer and political figures in Canada. Ms. Guo told the Plaintiff that she frequently negotiate with executive officers from Insurance companies and from Canadian government to decide prices for Wyeth's products in Canada market. The Chinese government bribed some of the related Canadian decision makers who negotiate with Ms. Guo, and help them to get the lowest price deal. Second, Pfizer's executive managers already knew that the Chinese government was behind the Pfizer's acquisition of Wyeth, they knew it was a great deal to Pfizer, but it might be a fraud deal. Thirdly, The Chinese government kept threaten the relevant executive officers from Canada and from Pfizer to force them to cooperate with the Chinese government, otherwise, would send them to prison by exposing the fraud deals. That was the normal strategy used by the Chinese security agents to threaten political figures of very important persons to cooperate with the Chinese government. The Canadian Council Member Mr. Bob Dechert is one of such example who has experienced such traps.
23. In April 2010, Ms. Liu Zhongyu, who is Ms. Guo's mother, happened mentioned to Plaintiff’s friends that Ms. Guo was an active military officer of the PLA. That made Ms. Guo very panic. She started to move out the Plaintiff’s house and tried all her best to destroy or silence the Plaintiff. Ms. Guo eventually moved out the Plaintiff’s house at the end of June 2010. A few days later, once the Plaintiff moved back to his house in New Jersey, the Plaintiff found some of evidences that can show Ms. Guo was an active military officer of the PLA. Then the Plaintiff believed that Ms. Guo was a secret military agent working for the Chinese government.
24. In July 2010, the Plaintiff reported Ms. Guo's case to FBI as well as Pfizer. Pfizer immediately responded to the Plaintiff’s report. In July 2010, Pfizer sent two gentle men to meet the Plaintiff at a restaurant at the corner of the 47th Street and Broadway Avenue in Manhattan. The two men from Pfizer claimed themselves were lawyers from Pfizer and asked the Plaintiff to provide evidences to show Ms. Guo was a military officer for PLA. The Plaintiff provided the copy of an ID card that proves Ms. Guo graduated from the Shanghai Second Military Medical University, while Ms. Guo cheated Pfizer in her resume that she BS degree from the Shanghai Second Medical University. All graduates from military school have to join the PLA while enrolled and would be assigned at least rank of lieutenant once graduated. According to the Chinese law, all lieutenants must work for the PLA at least 14 years. Ms. Guo graduated from military school in 1996, thus she has to serve for the PLA as an active military officer until 2010. The Plaintiff also provided the evidence that Ms. Guo received money from Chinese government along with 14 bank accounts information owned by Ms. Guo. The Plaintiff asked the two lawyers from Pfizer to investigate and check Ms. Guo's background, and to check whether Ms. Guo received money from the Chinese government, and to investigate the role played by the Chinese government and Ms. Guo during the Pfizer's acquisition of Wyeth, so that to protect Pfizer from further espionage from the Chinese government. The Plaintiff’s report and evidences are definitely valuable tips for Pfizer to prevent further loss. Pfizer should investigate Ms. Guo's case immediately. However, the two lawyers from Pfizer were not interested in the evidences provided by the Plaintiff. Instead, they threatened the Plaintiff not telling Ms. Guo's espionage activities to anyone else. The two lawyers also claimed that it was the Plaintiff who was harassing Ms. Guo by reporting to Pfizer. After carefully look at the evidences provided by the plaintif, the two lawyers from Pfizer simply concluded that it was just a divorce case. The two lawyers advised the Plaintiff to prepare for divorce with Ms. Guo and stop such kind report to any U.S. agents. The Plaintiff requests Pfizer to provide the names and contact information of the two lawyers who met the Plaintiff in July 2010. The Plaintiff believes the above mentioned two lawyers from Pfizer are important witnesses for this case.
25. The Plaintiff also reported Ms. Guo's along with Mr. Tang Yuhua's case to FBI, INS, Some Congress members and Senators. Due to Plaintiff’s repeated reports, Mr. Tang Yuhua was arrested by FBI on November 2011.
26. Since the Plaintiff reported Ms. Guo's case to Pfizer, Ms. Guo has speeded up her plan to destroy the Plaintiff. Ms. Guo asked defendant Mr. Bernstein to help her to destroy the Plaintiff. Mr. Bernstein has tried all her best to help Ms. Guo. Since July 2010, Mr. Bernstein has called the Plaintiff many times to threaten the Plaintiff. Mr. Bernstein then asked Mr. Greathead (one of the current representative of Mr. Bernstein), Ms. Sharon Hom (the Executive Director for Human Rights in China, which was founded by Mr. Bernstein), and some other people to help Ms. Guo to persecute and harass the Plaintiff. Mr. Bernstein told his assistants in Human Rights in China that "Gang Liu (the Plaintiff) is really tarff, we need to fix him."
27. Mr. Bernstein has been a long time friend of the Plaintiff. Mr. Bernstein has known the Plaintiff since the Plaintiff was sentenced by the CCP in 1989. Mr. Bernstein, along with Human Rights in China, and the Human Rights Watch, both were founded by Mr. Bernstein, has openly appealed for the Plaintiff while the Plaintiff was jailed in Chinese Communist prison from 1989 to 1995. The Plaintiff appreciated all the works that Mr. Bernstein has done to help the Plaintiff and other political prisoners jailed by the CCP.
28. Mr. Bernstein first met Ms. Guo on September 18th, 2009, at an Art Exhibition organized by the Plaintiff in New York City. Mr. Bernstein was deeply attracted by the beauty of Ms. Guo, who was the wife of the Plaintiff. Mr. Bernstein asked the Plaintiff to bring Ms. Guo to his office to meet Mr. Bernstein. In the following week, the Plaintiff introduced Ms. Guo to Mr. Bernstein at his office located at the Park Avenue and 47th Street in Manhattan. Since then, Mr. Bernstein met with Ms. Guo frequently. After the third time for their meeting, Mr. Bernstein offered Ms. Guo to be Executive Director for the Human Rights in China. Ms. Guo told the Plaintiff that she could not take the offer to join Human Rights in China although the offer is so good compared with the position she was with Pfizer, as she had more important work need to be done at Pfizer. It implies that the Chinese government was more interesting to espionage Pfizer than a none-profit organization.
29. Before Mr. Bernstein met with Ms. Guo, Mr. Bernstein promised the Plaintiff to get funds for the "Tear Down This Wall Art Exhibition", which was organized by the Plaintiff and targeting at promoting the pro-democracy movement in China and other Communist Countries. In about October 2009, Mr. Bernstein raised $50,000 funds from an old lady and promised to give "Tear Down This Wall Foundation" for the art exhibition. Mr. Bernstein also promised to raise funds from other organization, including $300,000 from Atlantic Foundation. Bernstein told the Plaintiff that he already got the check of $50,000 fund from the lady who used to donate for Human Rights in China and who had donated $30 million at one time to Mr. Bernstein's organization. Bernstein deposited the raised funds to his private account and he said it was illegal for doing that. Bernstein promised to the Plaintiff to used that fund to create more Statues for the Art Exhibition. Based on this commitment with Mr. Bernstein, the Plaintiff worked with some other Chinese dissidents and artists to create relevant arts, including a statue of the likeness of Defendant Mr. Bernstein. The Plaintiff spent more than $50,000 to create all these statues requested by Mr. Bernstein. However, Mr. Bernstein has never provided the raised funds to the Plaintiff and the Plaintiff’s team for the art exhibition. Instead, Mr. Bernstein worked with Ms. Guo and tried to transfer the raised funds to Ms. Guo's personnel account. Ms. Guo told the Plaintiff that the funds are raised for Ms. Guo's personnel usage, especially for purchasing houses/apartment in New York City.
30. The "Tear Down this Wall" art exhibition had its opening ceremony in New York City on September 8th, 2009, and had its second tour in the Capital Hill on October 1st, 2009. Many American political figures, including Congresswoman Carolyn Maloney, the ex State Assistant Secretary Winston Lord, as well as Mr. Bernstein attended and gave speeches at the events. These events also made the Chinese government very angry at the Plaintiff for organizing these art exhibition. The Chinese government sent its secret security agent Mr. Yan Wenming, who was also a comrade of Ms. Guo, to come to New York City and to monitor the Art Exhibition events. Mr. Yan Wenming lived with Ms. Guo in Plaintiff’s house in New Jersey from September 8th to September 19th, 2009. Mr. Yan Wenming stayed at The National Arts Club in New York City almost every day in that time period while the first art tour was hosted there. Right after the closing ceremony of the first tour of the art exhibition held on September 18th, 2009, Mr. Yan Wenming gave orders to Ms. Guo to stop the art Exhibition. Some relevant facts showed that that order must came from the Chinese government. Since then, Ms. Guo used many ways to force the Plaintiff to stop the art exhibition. Ms. Guo asked the Plaintiff to destroy all the art pieces and statues that were used for the exhibition. The Plaintiff refused Ms. Guo's requests, then Ms. Guo assault the Plaintiff almost every night whenever the Plaintiff came home from work.
31. Another strategy Ms. Guo used to force the Plaintiff to stop the art exhibition was to exhaust the money of the Plaintiff. Ms. Guo kept transferred most of the money from Plaintiff’s accounts (or joint accounts with Ms. Guo) to Ms. Guo's account. Also, Ms. Guo met with Mr. Bernstein asked Mr. Bernstein stop transferring the agreed funds to Plaintiff or to the Artists who had spent money for the art exhibition.
32. Mr. Bernstein has become the "God Father" and a slave of Ms. Guo after they met three times! The Plaintiff believes Ms. Guo must have applied her skills of "Schemes of a Beauty" trap to Mr. Bernstein. Ms. Guo has been trained by the PLA for doing those kind traps. Mr. Bernstein is well known for taking Chinese beautiful lady to be "God Daughters" and posing his nose to his God Daughters' family and marriage life. Ms. Xiaotian Hou was used to be the wife of Mr. Juntao Wang, who is another well known Chinese dissident. Once Mr. Bernstein met with Ms. Xiaotian Hou and became her "God Father", Ms. Xiaotian Hou divorced with his long time husband. Mr. Bernstein has records to interfere other family's life and to make his "God Daughters" to persecute their husbands. Mr. Juntao Wang has told many of his friends that his ex-wife Ms. Xiaotian Hou was working for the Chinese government as a Secret Agent since 1980's. Mr. Juntao Wang also had another girl friend Ms. Wei Li working as a Chinese Secret Agent. Ms. Wei Li is a graduate of the Institute of International Rlations of China, which is a notorious spy school and a subsidiary of the Ministry of Security of China. Ms. Wei Li had applied the "Schemes of a Beauty" to Mr. Juntao Wang in 1997 and put Mr. Juntao Wang into prison several times. All these ladies have been adopted by Mr. Bernstein as "God Daughters".
33. Since Mr. Bernstein became the God Father of Ms. Guo, Mr. Bernstein frequently blame and accuse the Plaintiff without any reasons. Mr. Bernstein played as the Judge for all family issues between the Plaintiff and Ms. Guo. Mr. Bernstein helped Ms. Guo to find attorneys to file lawsuit against the Plaintiff again and again. Mr. Bernstein also asked Mr. Greathead and Ms. Hom to contact with the Plaintiff’s attorney to give them pressure for representing the Plaintiff in family related cases. Mr. Bernstein or his staffs in his organizations has contacted at least 5 attorneys hired by the Plaintiff to make the Plaintiff have to change attorney and to make Plaintiff waste a lot of money.
34. Under the instruction of Mr. Bernstein, Mr. Greathead has also contacted with General Attorney's office in New Jersey to give them pressure to take any reports or claims from the Plaintiff. Whenever the Plaintiff showed up at the court in New Jersey, the Judge and the Prosecutor always asked the police to provide special protect to Ms. Guo. The prosecutor at the Municipal court noticed the Plaintiff that the General Attorney's noticed the Municipal court that the Plaintiff had plan to kill Ms. Guo and asked the Municipal court and the Superior court to provide special protect for Ms. Guo.
35. Ms. Guo could also ask the NYPD officers to do errands for her. It was Lieutenant Stewart Loo and his Detective Squad in the 17th Precinct in Manhattan serve the civil summons to the Plaintiff for Ms. Guo. However, they rufused to serve the similar summons for the same case to Ms. Guo for the Plaintiff. Officers in the 17th Precinct told the Plaintiff that they never serve civil summons. Why could they serve civil summons for Ms. Guo? The Plaintiff has no idea and no clue for why they did serve civil summons for Ms. Guo, unless the 17th Precinct has become a branch of the Chinese Communist Party, or some officers in that Precinct have been bribed by Ms. Guo or by Mr. Bernstein.
36. In October 2010, Officer Loo and his Detective Squad called the Plaintiff at his work phone again and asked the Plaintiff to go to the 17th Precinct to talk to them. They promised the Plaintiff through phone that they just wanted to talk to the Plaintiff and would not arrest the Plaintiff as long as the Plaintiff to go to the 17th Precinct. The Plaintiff went to the 17th Precinct with his attorney during the following weekend. The police officer in the 17th immediately arrested the Plaintiff and sent the Plaintiff to the jail. That case lasted for 8 months and eventually was dropped by the New York Criminal court. The district prosecutor accused the Plaintiff violate the protection order issued by the Somerset Superior Court. The prosecutor provided two evidences to support their accusation. One of the evidence is a criminal record submitted by Ms. Guo to the court. It was claimed as the Plaintiff’s criminal record. However, that criminal record was someone called Daniel who was Spanish. It was definitely not the Plaintiff. The other evidence is a copy of email sent from the Plaintiff to Ms. Guo. That email was true sent from one of the plaintiff’s Google email account. However, according to the sender's IP address that email was sent from China in January 2011, while the Plaintiff had never been in China since 1996! It was definitely sent by the Plaintiff! Both evidences are not false or lies! The New York criminal court had to drop that case in May 2011. However, the Judge issued a protection order against the Plaintiff based on the false accusation by Ms. Guo.
37. The New York Criminal court dropped that case against the Plaintiff. However, Ms. Guo has never stopped harassing the Plaintiff through Officer Loo and his Detective Squad in the 17th Precinct. Officer Loo kept calling the Plaintiff and threatened the Plaintiff again and again. In June 2011, Lieutenant Stewart Loo called the Plaintiff many times to threaten the Plaintiff. Usually, Officer Loo called the Plaintiff and simply telling the Plaintiff he was a police officer and then dropped the phone. Once the Plaintiff called back, Officer Loo just told the Plaintiff that he would arrest the Plaintiff if the Plaintiff called him again. That was definitely a harassment to the Plaintiff. Officer Loo and his Detective Squad continuously doing that for Ms. Guo's benefits.
38. Around the end of June 2011, Officer Loo and his Detective Squad called the Plaintiff. Again, they asked the Plaintiff to go to the 17th Precinct and talk to them. On July 6th, the Plaintiff went to the 17th Precinct. Again, the police officers in the 17th Precinct arrested the Plaintiff and sent the Plaintiff to the Jail again. This case is still alive and will have another hearing on January 23rd, 2012.
39. The Plaintiff was bailed out on July 7th, 2011. Once the Plaintiff went to work at Morgan Stanley, Morgan Stanley immediately fired the Plaintiff for no reasons.
40. Why Lieutenant Stewart Loo and his Detective Squad always help Ms. Guo to persecute the Plaintiff, who is a well known Chinese dissident and a successful professional with proved records? Because Ms. Guo is a Chinese Military officer? Or, because Ms. Guo has bribed Lieutenant Loo? Or, because Mr. Bernstein or Mr. Greathead have influenced the 17th Precinct through their powerful network? Or, the Chinese government has influenced Officer Loo through the powerful Chinese secret agents? The Plaintiff has no idea about that. The Plaintiff has no resources or authorities to investigate it and to give an answer for that. It was the responsibility of FBI or NYPD to investigate such kind cases. However, the Plaintiff believes that Lieutenant Stewart Loo should provide valid reasons for doing that. And Stewart Loo should have responsibility to protect the security of the Plaintiff, a U.S. citizen, instead of protecting a CCP member and a Chinese military officer hiding in the United States.
41. Mr. Bernstein had tried to transfer money to Ms. Guo through illegal method. The money was raised for the Plaintiff to create arts for the Art Exhibition. However, Mr. Bernstein later wanted to give the money to Ms. Guo for personnel usage. Bernstein first asked Ms. Sharon Hom and the Human Rights in China to use their 501C account to transfer $50,000 to Ms. Guo's personnel account. Ms. Sharon Hom refused to do that and warned Mr. Bernstein that it was illegal to transfer money through their 501C account to Ms. Guo. Then Mr. Bernstein tried several other ways to transfer the raised funds to Ms. Guo. In October, 2009, Mr. Bernstein met with Mr. Steve Isenberg, who was the Executive officer of the Pen Association of America, to discuss transferring money through the 501C accounts of the PEN Association. Both Mr. Bernstein and Ms. Guo clearly said what they were trying to do were illegal.
42. The Plaintiff's email accounts hosted by Google were frequently accessed by the Chinese Security Agents. The most serious case was happened in January, 2011. The Chinese Security agents sent emails and pretended to be the Plaintiff as the sender to many people and invited them to the Plaintiff's house in New Jersey to have a party on January 30th, 2011. Many people later responded to the Plaintiff that they couldn't show up at the party. The Plaintiff found that the email accounts might be accessed by intruders. The Plaintiff reported to Google's technical supporting team and ask them to find out who was the real sender. But Google has never responded to the Plaintiff. These emails have been used by Ms. Guo as evidences to accuse the Plaintiff and the Plaintiff was arrested based on that false evidence. The Plaintiff has to hire attorney to represent the Plaintiff. The lawsuit made the Plaintiff extensive costs and even made the Plaintiff lost jobs on July 8th, 2011.
43. On January 30th, 2011, there were two guests wanted to come to the Plaintiff's house, they are Mr. Tang Yuhua and Mr. Zhao Yan. Mr. Zhao Yan was an ex-police officer when he was in China, and Mr. Tang Yuhua was said to be the head of the Chinese Security Agency in the North America region. The Plaintiff refused Mr. Zhao and Mr. Tang's request to come to the Plaintiff's house. Since then, the Plaintiff publicly revealed the true identity of Mr. Zhao and Mr. Tang. Mr. Tang was arrested by FBI on November 21, 2011. As Google used to declare that the Chinese government frequently access Google's email accounts, especially targeting at the accounts of some Chinese dissidents'. The Plaintiff beloved that his Google email accounts were intruded by the Chinese Security agents and thus allow Ms. Guo to false accuse the Plaintiff.
44. Why Pfizer always helped Ms. Guo to persecute the Plaintiff? The Plaintiff believes that Pfizer clearly knew that Ms. Guo and the Chinese government played important role in the Pfizer's acquisition of Wyeth. Pfizer also know that once the true identity of Ms. Guo was exposed, the FBI would investigate the process of the Pfizer-Wyeth merge. By covering Ms. Guo and by silencing the Plaintiff, Pfizer could cover the investigation of the Pfizer-Wyeth merge case and keep it as a secret. That could be the only reason for Pfizer to send its lawyers to threaten the Plaintiff.
45. The Plaintiff sent emails to Mr. Bernstein and told Bernstein that Ms. Guo was a Military officer of PLA. The Plaintiff asked Bernstein to stop raise funds for Ms. Guo. However, Mr. Bernstein continuously helped Ms. Guo to raise funds. Mr. Bernstein also helped Ms. Guo to have the Plaintiff arrested by the NYPD. Eventually, with the helps of Mr. Bernstein, Ms. Guo made the suffer huge loss financially and psychotically. The Plaintiff lost jobs, lost houses.
46. As the Plaintiff's Gmail accounts was intruded frequently by the Chinese Security agents, the Plaintiff suffered huge loss. The Plaintiff was arrested by NYPD for due to such the emails sent by intruders.
47. In order to have me lost job, the Chinese government even launched Cyber-Attacks against my employer Morgan Stanley in February, 2011. The government has constantly given pressure to Morgan Stanley to fire the Plaintiff. As there are news around May 2011 that wrongly reported the Plaintiff was working for Citigroup, the Citigroup was Cyber-Attacked by Chinese military based hackers in June 2011. There are many media reports about the above mentioned Cyber-Attacks. Both attacks are launched from China and operated by the powerful "Aurora", which only the Chinese military force has the capability and resources to operate on. Both Cyber-Attacks made the Plaintiff's ex-employers suffer multi-billion dollars loss. Both Cyber-Attacks are targeting at the Plaintiff and try to help Ms. Guo. It clearly shows that the Chinese government can do whatever that can destroy the Plaintiff.
48. The CCP leaders always treat the United States as their number 1 enemy and they always try to start war against the United States. In recent years, Chinese military has developed a new strategy named "Unrestricted War". Some Chinese generals even summarized this strategy in the notorious book "Unrestricted Warfare". The major target of the "Unrestricted War" is to destroy the United States. The major strategies can be summarized as "Legal War", "Financial War", "Internet Attack", etc. The Chinese government has applied all these strategies to destroy the Plaintiff, directly or through Ms. Guo.
49. The Plaintiff understands that the defendant Pfizer could be also another victim in the Unrestricted War initiated by the Chinese government. That is why the Defendant gave warnings and reports to Pfizer and asked Pfizer to investigate the Background of Ms. Guo. If Pfizer continue to protect and support Ms. Guo, Pfizer could become another victim of the Chinese government.
50. The Plaintiff understands that Mr. Bernstein could be another victim of the Chinese government, and he could be cheated and utilized by Ms. Guo and the Chinese government. That is why the Plaintiff kept sending emails to Mr. Bernstein, to notice him that the real identity of Ms. Guo was the Chinese Military officer, thus was an enemy of the United States. However, Mr. Bernstein has never stopped to support Ms. Guo, including raising and transferring funds to Ms. Guo illegally.
51. The Plaintiff understands that Google has already been the victim of the Chinese government. Google has publicly disclosed that the Google email system had been attacked or accessed by the Chinese government. Google has bravely stood up to fight back against the Chinese government. The Plaintiff understands that there are no technical solutions to protect a database system from Cyber-Attacks launched by the Chinese government. The only solution is let people know who is behind the attacks and force the Chinese government to stop any further attacks. That is why the Plaintiff asked Google to provide the information of the intruders who sent emails pretended to be the Plaintiff. That is why the Plaintiff asked Google to cooperate in this case, and to disclose more details about how the Chinese government attacked the Google database system.
52. The Plaintiff understands that there may not have earlier case like this case, because he "Unrestricted War" is really a new war initiated by the Chinese government. There could be no valid laws to apply this case. New laws might be needed to prevent the further penetration from the Chinese Military agents and to stop the Unrestricted War initiated by the Chinese government. The Plaintiff honestly asks the Honorable Judge Gardephe to allow the Plaintiff publish this file and other related files to the public and to the America Lawmakers, so that let all the American people know that our country is vulnerable and is in danger in the Unrestricted War initiated by the Chinese Government.
53. The Plaintiff understands that this is an "Unrestricted War" between the individual Plaintiff and the Chinese government. The Plaintiff understands that he himself has no chances to win this war. The Plaintiff asks the defendants Pfizer and Mr. Bernstein to stop supporting the Chinese Military officer. The Plaintiff asks the Defendant Google to continue disclose the real sender of the email that was used by Ms. Guo to put the Plaintiff into jail.
RELATIONSHIP AND LOGICS OF THE RELATED PARTIES
The Plaintiff understands that there are two many names and parties mentioned in this file. To clarify the relationships of the relevant parties, the Plaintiff draw the following charts to explain the relationships among some of the parties, and to explain how the Chinese government manipulate the Pfizer’s acquisition of Wyeth, and how the Chinese government persecuted the Plaintiff, as well as how Pfizer and Mr. Bernstein helped Ms. Guo to persecute the Plaintif.
MORE EVIDENCES
The Plaintiff provides the following evidences to show the roles of the relevant parties.
1. The role of the ChinaSoft, and its relationship with Pfizer.
The following snapshot shows that ChinaSoft is mainly controlled by the Chinese government. It is a subsidiary of the CEC, which is a part of the Chinese government. The major product of the ChinaSoft is called Golden Shield, which was used by the Ministry of the Public Security to do internet censorship, and many Chinese dissidents were arrested due to the censorship. It is clearly indicated that ChinaSoft is part or a accomplice of the Chinese Security Agents, which is responsible for censorship, and its employees might be responsible to do espionage in the United States.
The following snapshot shows a list of the products of the ChinaSoft. Most of the products are for the Ministry of the Public Security, which is a KGB like government agency. It indicated that ChinaSoft is a accomplice of the Chinese security agency.
The following snapshot explains the Golden Shield project and its roles in the internet censorship in China.
2. The role of DoubleBridge and its relationship with Pfizer
The following snapshot shows that DoubleBridge is a subsidiary of the ChinaSoft. It sends at least dozens Chinese software engineers to work on site at Pfizer as long time consultants. DoubleBridge treats Pfizer as its Number 1 client.
3. The role of Mr. George Wu’s and his relationship with ChinaSoft, DoubleBridge, Pfizer, and with Ms. Guo.
The following snapshot shows that Mr. George Wu frequently showed up at meetings with Chinese government officials, to discuss how to utilize Chinese software engineers working in the United States to serve for their motherland China. It also mentioned that Pfizer is his major client and target.
4. The role of Mr. Hank Wei and his relationship with Pfizer. The following snapshot shows that Mr. Wei is a long time consultant for Pfizer.
Mr. Bernstein promised to raise funds for the Tear Down This Wall art exhibition. He requested the Plaintiff to have a statue of his likeness in the Exhibition. Here are some pictures provided by Mr. Bernstein for creating the Statue.
The following snapshot shows several emails sent from Bernstein or his assistants. These emails discusses how to arrange meeting with Mr. Steve Isenberg to transfer funds to Ms. Yinghua Guo.
The following email was sent by Ms. Guo to Mr. Bernstein. This email shows that Ms. Guo was targeting at other very important persons (VIP) in the United States. Ms. Guo also tried to ask Mr. Bernstein to introduce Ms. Guo to Mr. Warren Buffet. All those VIPs are top targets of the Chinese government.
6. Evidences related to Google
The Plaintiff’s Gmail accounts have been frequently intruded by other people, most likely by the Chinese security agents, as some of the Emails were used by Ms. Guo to sue the Plaintiff.
The following snapshot are responses from people who received emails from the Plaintiff, but all these emails were not sent by the Plaintiff. Some of the IP address show that the Email were sent from China.
The snapshot on the next page shows some of the detailed contents of the responses from the receiver of the fraud emails. Some of the receiver even told the sender (who pretended to be the Plaintiff) some very confidential information, such as how to access their house in Florida, etc.
The following snapshot shows more of such accounts that forward the Plaintiff’s emails to theirs.
7. Evidences related to Ms. Guo.
The following picture was one of the evidences submitted by Ms. Guo to sue the Plaintiff and let the NYPD police officers arrest the Plaintiff.
The following snapshot lists some of the phone records that Lieutenant Loo made to harass and to threatne the Plaintiff.
Here is the snapshot of Ms. Guo’s resume. She lied that she was graduated from Shanghai Second Medical University in 1996.
Unit 61398 is an military spy agency of the PLA and is mainly responsible for cyber attacks. It normally recruits officers from civil school or sent its officers to schools for further training, especially as a hacker. The above picture shows one of the advertisement for Unit 61398 recruiting computer hackers. Ms. Yinghua Guo joined recruited by Unit 61398 while she was in Shanghai Second Military Medical University. In 1996, Yinghua Guo was sent to Shanghai University of Science and Technology by the Unit of 61398.
Unit 61398 of PLA is a spy agency and are responsible for Cyber attacks against the United States. The above paper is one of such kind evidences.
On Sept. 9th, 2010, Ms. G herself confessed at the Somerset Superior court that she was a graduate of "Shanghai Second MILITARY Medical University" and received her bachelor degree in 1996. Based on the Chinese law and the rules for the Chinese military graduates, Ms. Guo must be a military officer of the PLA.
The following picture is a snapshot at the website:
http://www.gov.cn/banshi/gm/content_63642.htm.
It indicates that all graduates of Military University would be granted at least the rank of lieutenant, and would be promoted to a higher rank every 5 years.
In China, All Chinese military officers must be the member of the CCP, Ms. Guo must be a member of the CCP.
The following picture is a snapshot of the website:
http://www.mod.gov.cn/policy/2009-07/14/content_3100989.htm。
《中华人民共和国现役军官法》.
This is the Chinese Law about the PLA active military officers. It indicates that a military officer with the rank of lieutenant must serve in the army at least 16 years. That means, Ms. Guo couldn’t retire from the PLA until 2011! Unless Ms. Guo can show the document for her retirement from the PLA, Ms. G must be an active military officer of the PLA.
The following picture shows that any military officer is strictly forbidden to travel abroad unless he or she is sent by the Chinese General Political Department of the PLA for special missions. Then, Ms. Guo must be sent by the Chinese PLA for special missions. That special mission is part of the Unrestricted War against the United States!
The following picture shows that there are hundreds military training camps in civil universities in China. All of these students have to be enrolled in the army and become military officers. Most of these military officers would be sent to the United States or other western countries as secret military spy agents. China trained as many as 10,000 such kind military spy agents every year. At least thousands of such kind secret military agents would be sent to the United States to join the Unrestricted War. How many Chinese military officers are in the United States as sleeping cells? Much more than the Paramilitaries terrorism sleeping cells. These Chinese military officers are well trained and armed with the Unrestricted warfare skills, and are ready to start Legal-Economic-Network attacks against the United States!
8. Ms. Wei Li, another Chinese Lady who played the "Schemes of a Beauty" to Chinese dissidents.
The following two snapshots are profile and resume of Ms. Wei Li. Ms. Li dated with Mr. Juntao Wang while both of them in Harvard University. Ms. Li false accused Mr. Juntao Wang and put Juntao Wang into prison several times. Mr. Juntao Wang later told his friends that Ms. Li was a secret security agent sent by the Chinese government. Mr. Juntao Wang claimed that Ms. Wei Li alread confessed to Mr. Juntao Wang about her real identity.
CONCLUSIONThe Plaintiff believes the Amended Complaint 11-5229, supported by the evidences provided in this file, is a valid complaint. The Plaintiff opposes to dismiss this case. The Plaintiff honestly request the Honorable Judge Gardephe to give further hearing about this case, and eventually let the Jury to give a final decision for this case.
Dated January 11, 2012-1-11
By ______________________________
/s/ Gang Liu
Plaintiff, Pro Se
Flushing, NY 11354
Email: gang.liu.1989@gmail.com
Cell: 646-591-9803
