Friday, May 23, 2014

Opposition to dismiss the Lawsuit against Pfizer, Google, and Berstein

UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK

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GANG LIU                                )
                                                   )
Plaintiff,                                    )
                                                   )
                                                   )
       v.                                         )   1:11-CV-5229(PGG)(HBP)
                                                   )
                                                   )   NOTICE OF OPPOSITION
                                                   )
PFIZER INC., GOOGLE INC., )
AND                                          )
ROBERT L. BERNSTEIN       )
                                                   )
                                                   )
Cefendants.                              )
                                                   )
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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 denfendants filed motions to request the Hornorable Judge Gardephe to dismiss the Amended Complaint. The denfendants 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) counsultant 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 frenquently meet with Pfizer's executive managment team to discuss bussiness requests/requirments, as well as business opportunities, especially to coorperate with CSI, DoubleBridge, and the Chinese government.

6. The CSI is mainly controled 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.. That shows the CSI is not only simply a software company to provide IT service, but also played as accsessary for the Chinese government. It always ready to serve for the Chinese government, including espionage U.S. military 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 counsultants.

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 developped by CSI.

9. Through DoubleBridge, CSI, Mr. Wu, and Mr. Wei, Pfizer has extensive exposures to the Chinese government.

10. 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 wellknown that the relevent pharmasuetical products in Cannada 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 acquire Wyeth. This opportuinty 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 Chniese government. The Chinese government is the black hand to make the Pfizer's acquisition of Wyeth.

11. In 2008, the Plaintif happened found Mr. Wei came to the Plaintif's home to meet with Ms. Guo. Around the end of 2008 or early 2009, the Plaintif saw Mr. Wei ran out from Plaintif's home at 11 Ridings Parkway, Princeton, NJ, when Plaintif came home from work. Mr. Wei was so hurry to run out that he didn't say hello to Plaintif even he knew Plaintif. Ms. Guo lived in that house at that time. Ms. Guo immediately threaten Plaintif not telling anyone about her meeting with Mr. Wei at home. Ms. Guo told Plaintif 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 know about what she did with Mr. Wei at home. The Plaintif had not understood why Ms. Guo and Mr. Wei were so panic for meeting at home, until Wyeth was acquisited by Pfizer and until plaintif found Ms. Guo was a Chinese Military agent.

12. It was true that Ms. Guo was married with the Plaintif at the end of 2007. However, Ms. Guo cheated the Plaintif 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 plaintif. The Chinese security agents applied the so called "Schemes of a Beauty" (Mei Ren Ji) to destroy the plaintif's life. Ms. Guo was the "Beauty Tiger" in this conspircy trap.

13. The Plaintif was used to be one of the wellknown 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 hate the plaintif and wanted to destroy the plaintif. The Chinese government not only jailed the Plaintif for six years from 1989 to 1995, but also want to destroy the plaintif's personel life and his American dream enve the Plaintif escaped to the United States in 1996. The Chinese government has the intentions and the capabilities to do all such conspiracies.

14. The Plaintif 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 plaintif. All of them had experienced the same traps designed by the Chinese government.

Dr. Wang Bingzhang, who was 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_Bingzhang
Ms. 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.htm
Evern 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 enventually 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
Now, Ms. Yan Qingxin and Ms. Zhang Qi, along with Mr. Ye Ning are all living in the Uniteds 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.

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 Plaintif. Ms. Guo has been the key player in this trap to destroy the plaintif. It is fortunate that Mr. Tang Yuhua was arrested by FBI on November 21st, 2011.

15. Ms. Guo was the key countributor to the Pfizer's acquisition of Wyeth. To compense 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 Stratigic 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 Stategic 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 collegues? 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 acqusition of Wyeth. Only Pfizer could tell the real reason. Hope the defendant Pfizer can provide more explanations and reasons for hiring Ms. Guo.

16. Ms. Guo received $60,000 anually 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.

16. 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 benifits.

17. The Chinese government also got huge benifits 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 plaintif 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.

18. In April 2010, Ms. Liu Zhongyu, who is Ms. Guo's mother, happened mentioned to plaintif'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 plaintif's house and tried all her best to destoy or silence the plaintif. Ms. Guo eventually moved out the Plaintif's house at the end of June 2010. A few days later, once the Plaintif moved back to his house in New Jersey, the plaintif found some of evidences that can show Ms. Guo was an active military officer of the PLA. Then the plaintif believed that Ms. Guo was a secret military agent working for the Chinese government.

19. In July 2010, the Plaintif reported Ms. Guo's case to FBI as well as Pfizer. Pfizer immediately responded to the plaintif's report. In July 2010, Pfizer sent two gentle men to meet the Plaintif at a restaurant at the corner of 47th Street and Broadway Avenue in Manhatan. The two men from Pfizer claimed themselves were lawyers from Pfizer and asked the plaintif to provide evidences to show Ms. Guo was a military officr for PLA. The Plaintif 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. Acording 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 Plaintif also provided the evidence that Ms. Guo received money from Chinese government along with 14 bank accounts information owned by Ms. Guo. The plaintif 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 Plaintif'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 plaintif. Instead, they threatened the plaintif not telling Ms. Guo's espionage activities to anyone else. The two lawyers also claimed that it was the plaintif 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 plaintif to prepare for divorce with Ms. Guo and stop such kind report to any U.S. agents. The plaintif requests Pfizer to provide the names and contact information of the two lawyers who met the plaintif in July 2010. The plaintif believes the above mentioned two lawyers from Pfizer are important witnesses for this case.

20. The plaintif also reported Ms. Guo's along with Mr. Tang Yuhua's case to FBI, INS, Some Congress members and Senators. Due to plaitif's repeated reports, Mr. Tang Yuhua was arrested by FBI on November 2011.

21. Since the plaintif reported Ms. Guo's case to Pfizer, Ms. Guo has speeded up her plan to destroy the plaintif. Ms. Guo asked defendant Mr. Bernstein to help her to destroy the plaintif. Mr. Bernstein has tried all her best to help Ms. Guo. Since July 2010, Mr. Bernstein has called the plaintif many times to threaten the plaintif. 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 Plaintif. Mr. Bernstein told his assistants in Human Rights in China that "Gang Liu (the plaintif) is really tarff, we need to fix him."

22. Mr. Bernstein has been a long time friend of the plaintif. Mr. Bernstein has known the plaintif since the Plaintif 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 plaintif while the plaintif was jailed in Chinese Communist prison from 1989 to 1995. The plaintif appreciated all the works that Mr. Bernstein has done to help the plaintif and other political prisoners jailed by the CCP.

23. Mr. Bernstein first met Ms. Guo on September 18th, 2009, at an Art Exhibition organized by the Plaintif in New York City. Mr. Berstein was deeply attracted by the beauty of Ms. Guo, who was the wife of the Plaintif. Mr. Bernstein asked the Plaintif to bring Ms. Guo to his office to meet Mr. Bernstein. In the following week, the plaintif introduced Ms. Guo to Mr. Bernstein at his office located at the Park Avenue and 47th Street in Manhatan. 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 plaintif 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 espionge Pfizer than a none-profit organization.

24. Before Mr. Bernstein met with Ms. Guo, Mr. Bernstein promised the Plaintif to get funds for the "Tear Down This Wall Art Exhibition", which was organized by the Plaintif 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 plaintif 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 plaintif to used that fund to create more Statues for the Art Exhibition. Based on this commitment with Mr. Bernstein, the Plaintif worked with some other Chinese dissidents and artists to create relevant arts, including a statue of the likeness of Defendant Mr. Bernstein. The plaintif 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 plaintif and the plaintif's team for the art exhibition. Instead, Mr. Bernstein worked with Ms. Guo and tried to transfer the raised funds to Ms. Guo's personel account. Ms. Guo told the plaintif that the funds are raised for Ms. Guo's personel use, especially for purchasing houses/apartment in New York city.

25. 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 Moloney, the ex State Assistant Secratary Winston Lord, as well as Mr. Bernstein attended and gave speaches at the events. These events also made the Chinese government very angery at the plaintif for organizing these art exhibition. The Chinese government sent its secret security agent Mr. Yan Wenming, who was also a comerade of Ms. Guo, to come to New York City and to mornitor the Art Exhitition events. Mr. Yan Wenming lived with Ms. Guo in plaintif'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 Plaintif to stop the art exhibition. Ms. Guo asked the plaintif to destroy all the art pieces and statues that were used for the exhibtion. The plaintif rufuesed Ms. Guo's requests, then Ms. Guo assault the plaintif almost every night whenever the plaintif came home from work.

26. Another strategy Ms. Guo used to force the plaintif to stop the art exhibition was to exhaust the money of the palintif. Ms. Guo kept transferred most of the money from Plaintif'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 Plaintif or to the Artists who had spent money for the art exhibition.

27. Mr. Bernstein has become the "God Father" and a slave of Ms. Guo after they met three times! The plaintif 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 that 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 marriadge 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.

28. Since Mr. Bernstein became the God Father of Ms. Guo, Mr. Bernstein frequently blame and accuse the Plaintif without any reasons. Mr. Bernstein played as the Judge for all family issues between the Plaintif and Ms. Guo. Mr. Bernstein helped Ms. Guo to find attorneys to file lawsuit against the Plaintif again and again. Mr. Bernstein also asked Mr. Greathead and Ms. Hom to contact with the plaintif's attorney to give them pressure for representing the plaintif in family related cases. Mr. Bernstein or his staffs in his organizations has contacted at least 5 attorneys hired by the plaintif to make the plaintif have to change attorney and to make plaintif waste a lot of money.


29. 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 Plaintif. Whenever the plaintif 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 Plaintif that the General Attorney's noticed the Municipal court that the plaintif had plan to kill Ms. Guo and asked the the Municipla court and the Superior court to provide special protect for Ms. Guo.


30. Ms. Guo could also asked the NYPD officers to do errands for her. It was Lieutenant Stewart Loo and his Detective Squad in the 17th Precinct in Manhatan serve the civil summons to the Plaintif for Ms. Guo. However, they rufused to serve the similar summons for the same case to Ms. Guo for the plaintif. Officers in the 17th Precinct told the plaintif that they never serve civil summons. Why could they serve civil summons for Ms. Guo? The plaintif 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.

31. In October 2010, Officer Loo and his Detective Squad called the plaintif at his work phone again and asked the plaintif to go to the 17th Precinct to talk to them. They promised the plaintif through phone that they just wanted to talk to the plaintif and would not arrest the plaintif as long as the plaintif to go to the 17th Precinct. The Plaintif went to the 17th Precinct with his attorney during the following weekend. The police officer in the 17th immediately arrested the plaintif and sent the plaintif to the jail. That case lasted for 8 months and eventually was dropped by the New York Criminal court. The district prosecutor accused the Plaintif violate the protection order issued by the Somerset Supriou Court. The prosecutor provided two evidences to support their accusation.One evidence is a criminal record of the plaintif. However, that criminal record was someone called Daniel who was a Spanish. It was definitely not the Plaintif. The other evidence is a copy of email sent from the Plaintif to Ms. Guo. That email was true sent from one of the plaintif's Google email account. However, according to the the sender's IP address, that email was sent from China in Jannary 2011, while the plaintif had never been in China since 1996! It was definitely sent by the Plaintif! 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 Plaintif based on the false accusation by Ms. Guo.

32. The New York Criminal court dropped that case against the Plaintif. However, Ms. Guo has never stopped harassing the Plaintif through Officer Loo and his Detective Squad in the 17th Precinct. Officer Loo kept calling the Plaintif and threaten the Plaintiff again and again. In June 2011. Lieutenant Stewart Loo called the plaintif many times to threaten the Plaintif. Usually, Officer Loo called the Plaintif and simply telling the Plaintif he was a police officer and then dropped the phone. Once the Planitif called back, Officer Loo just told the plaintif that he would arrest the Plaintif if the Plaintif called him again. That was definitely a harassment to the Plaintif. Officer Loo and his Detective Squad continuously doing that for Ms. Guo's benifit.

34. Around the end of June 2011, Officer Loo and his Detective Squad called the plaintif. Again, they asked the Plaintif to go to the 17th Precinct and talk to them. On July 6th, the Plaintif went to the 17th Precinct. Again, the police officers in the 17th Precinct arrested the plaintif and sent the Plaintif to the Jail again. This case is still aliving and will have another hearing on Jannuary 23rd, 2012.

35. The Plaintif was bailed out on July 7th, 2011. Once the plaintif went to work at Morgan Stanley, Morgan Stanley immediately fired the Plaintif for no reasons.

36. Why Lieutenant Stewart Loo and his Detective Squad always help Ms. Guo to persecute the Plaintif, 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 infuluenced the 17th Precinct through their powerful network? Or, the Chinese government has influenced Officer Loo through the powerful Chinese secret agents? The plaintif has no idea about that. The Plaintif also has no resources nor rights 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 plaintif belives that Lieutenant Stewart Loo should provide valid reasons for doing that. And Stewart Loo should have responisibility to protect the security of the Plaintif, a U.S. citizen, instead of protecting a CCP member and a Chinese military officer hiding in the United States.

37. Mr. Bernstein had tried to transfer money to Ms. Guo through ilegal method. The money was raised for the Plaintif to create arts for the Art Exhibition. However, Mr. Bernstein later wanted to give the money to Ms. Guo for personel 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 personel account. Ms. Sharon Hom refused to do that and warned Mr. Bernstein that it was ilegal 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, who was the Executive officer of the Pen Association of America, to discuss transfering money through the 501C accounts of the PEN Association. Both Mr. Bernstein and Ms. Guo clearly said what they were trying to do were ilegal.

38. 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 plaintif as the sender to many people and invited them to the Plaintif's house in New Jersey to have a party on January 30th, 2011. Many people later responded to the plaintif that they couldn't show up at the party. The the Plaintif found that the email accounts might be accessed by intruders. The Plaintif 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 Plaintif. These emails has been used by Ms. Guo as evidences to accuse the Plaintif and the Plaintif was arrested based on that false evidence. The Plaintif has to hire attorney to represent the plaintif. The lawsuit made the Plaintif extensive costs and even made the plaintif lost jobs on July 8th, 2011.

39. On January 30th, 2011, there were two guests wanted to come to the Plaintif'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 Plaintif refused Mr. Zhao and Mr. Tang's request to come to the Plaintif's house. Since then, the Plaintif 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 targeing at the acounts of some Chinese dissidents' accounts. The Plaintif belived that his Google email accounts were intruded by the Chinese Security agents and thus allow Ms. Guo to false accuse the Plaintif.

40. Why Pfizer always helped Ms. Guo to persecute the Plaintif? The plaintif believes that Pfizer clearly knew that Ms. Guo and the Chinese government played important role in the Pfizer's acqusition of Wyeth. Pfizer also know that once the true identity of Ms. Guo were exposed, the FBI would investigate the process of the Pfizer-Wyeth merge. By covering Ms. Guo and by silenciing the plaintif, 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 Plaintif.

41. The Plaintif sent emails to Mr. Bernstein and told Bernstein that Ms. Guo was a Military officer of PLA. The Plaintif 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 Plaintif arrested by the NYPD. Eventually, with the helps of Mr. Bernstein, Ms. Guo made the suffer huge loss financially and psyclogically. The Plaintif lost jobs, lost his house.

42. As the Plaintif's gmail accounts was intruded frequently by the Chinese Security agents, the Plaintif suffered huge loss. The plaintif was arrested by NYPD for due to such the emails sent by intruders.

43. 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 plaintif. As there are news around May 2011 that wrongly reportd the plaintif 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 plaintif's ex-employers suffer muti-billion dolars loss. Both Cyber-Attacks are targeting at the Plaintif and try to help Ms. Guo. It clearly shows that the Chinese government can do whatever that can destroy the Plaintif.

44. 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 sumarized as "Legal War", "Financial War", "Internet Attack", etc. The Chinese government has applied all these strategies to destroy the Plaintif, directly or through Ms. Guo.

45. The plaintif understand 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.

46. The Plaintif understand 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 Plaintif kept sending emails to Mr. Bernstein to notice him that the real identity of Ms. Guo was the Chinese Military officer, thus was an enenmy of the United States. However, Mr. Bernstein has never stopped to support Ms. Guo, including raising and trasfering funds to Ms. Guo ilegally.

47. The Plaintif understand 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 stand up to fight back against the Chinese government. The Plaintif understand that there are no technical solutions to protect a database system from Cyber-Attacks lauched 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 Plaintif asked Google to provide the information of the intruders who sent emails pretended to be the Plaintif. That is why the plaintif asked Google to cooperate in this case, and to disclose more details about how the Chinese government attacked the Google database system.

48. The Plaintif understand 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 furthe penetration from the Chinese Military agents and to stop the Unrestricted War initiated by the Chinese government. The Plaintif honestly asks the Hornourable Judge Gardephe to allow the plaintif 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 vulnable and is in danger in the Unrestricted War initiated by the Chinese Government.

49. The Plaintif understand that this is an "Unrestricted War" between the individual Plaintif and the Chinese government. The Plaintif understand that he himself has no chances to win this war. The Plaintif asks the defendants Pfizer and Mr. Bernstein to stop supporting the Chinese Military officer. The Plaintif asks the Defendant Google to continue disclose the Twas the sender of the email that was used by Ms. Guo to put me into jail.

50. The Plaintif believes the Amended Complaint 11-5229, supported by the evidences provided in this file, is a valid complaint. The Plaintif opposes the dismiss this case. The Plaintif honestly request the Honorable Judge Gardephe to give further hearing about this case, and eventually let the Juary to give a final decision for this case.



RELATIONSHIP AND LOGICS OF THE RELATED PARTIES




MORE EVIDENCES

Relationship between Plaintif Pfizer and the DoubleBridge.



The key players of the DoubleBridge











--------------
In her resume, Ms. G claimed she was a graduate of "Shanghai Second Medical University". Actually, she was a graduate of "Shanghai Second MILITARY Medical University". She omitted the key word "MILITARY" and changed her school from military school to a civil school!

On Sept. 9th, 2010, Ms. G herself confessed at the court that she was a graduate of "Shanghai Second MILITARY Medical University" and received her bachalor degree in 1996. Based on the Chinese law and the rules for the Chinese military schools, we can easily derive the following conclusion:



3.1. Ms. G enrolled in the Chinese People's Liberation Army (PLA) in 1991.



3.2. Ms. G must be awarded a military officer at least the rank of lieutenant. The picture at the right is a snapshot at the website http://www.gov.cn/banshi/gm/content_63642.htm. It indicates that all graduates of Military University should be granted at least the the rank of lietenant, and would be promoted to a higher rank within 5 years. Ms. G has mentioned that she was granted the Senior Lieutenent when she graduated from the military university in 1996, due to her exellent work and she received several times of "The Third Class Hero Medal of the PLA". Then, Ms. G might be at least the rank of colonel after she worked 15 years in the PLA.



3.3. As all Chinese military officer must be the member of the CCP, Ms. G must be member of CCP.

3.4. The picture on the right 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 acitve military officers. It indicates that a military officer with the rank of lieutenent must serve in the army at least 16 years. That means, she can't retire from the PLA until 2011! Unless she can show the document for her retirement from the army, Ms. G must be an active military officer of the PLA.

3.5. The picrue on the right shows that any military officer can't travel abroad nor go to school abroad unless is sent by the Chinese General Political Department of the PLA for special missions. Then, Ms. G must be sent by the Chinese PLA for special missions. That special mission is part of the Unrestricted War against the United States!



3.6. Ms. G used faked ID to enter the United States, to enroll in University of Chicago, and to find jobs in high profile US corporations.



Had she exposed her military background to INS, she would have been rejected from entering the USA!



Had she submitted her transcript from military school to the University of Chicago, she would have been rejected from enrolling the school!



Had she put exposed her military backgrond in her resume, she would not have been hired by Wyeth nor Pfizer!



Had she exposed her military background to me, I would not have married her now apply green card for her!



Ms. G Lied to INS, her school, her employers, and her husband!



3.7. Ms. G received $60,000 anual allowances from the Chinese Military.



The picture on the left showed that there are hundreds military training camps in civil universities in China. All of these students have to be enrolled 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 for the Unrestricted warfare and are ready to start Legal-Economic-Network attacks against the United States!

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 is responsible for Cyber attacks against the United States. The above paper is one of such kind evidences.

Ms. G, a Chinese secret military agent hiden in the USA, is very dangerous to the people of USA and to the security of the United States. I myself has been frequently attacked by Ms. G. The Wyeth is another victim of the CCP and Ms. G.

-------------
Mr. Bernstein,

I hope you still remember the following attached email you sent to me on 10/15/2009. The email showed that you invited Elisa Guo (Yinghua Guo), and me to have meeting with Steven. The major topics would discuss how to transfer $50,000 you raised for our Art Exhibition in New York, Washington, and Hong Kong. After that email, you haven't sent any further follow up emails to me. I believe that you and Elisa have tried many ILLEGAL ways to transfer the money to Elisa.

Elisa told me that you met her very frequently to discuss how to transfer the money you raised for us. Later on, Elisa claimed that the money you raised was for Guo Yinghua's personel usage, no longer for our Art Exhibition. Elisa also told me that you have deposited all the money you raised into your personel account. Elisa clearly said that both of you believed that activity was illegal. Later on, Elisa told me that you asked Sharon Hom to transfer the money to Elisa, through the 401(C) tax exempt accout. Sharon refused to do that and she reminded you what you were trying to do was illegal. Then, you proposed to Elisa to ask PEN to transfer the money to Elisa. That is why you sent email to Steven (The Chairman of the PEN) and asked Elisa to join your meeting with Steven.

I clearly told Elisa that we couldn't ask Steven or any other third party to transfer the money to Elisa. It is illegal! And that money should be paid to the artists for their expenses and their cost of the arts they created for the exhibition, especially, Mr. Weiming Chen has created an sculpture for Bob and he spent more than $10,000 for Bernstein's sculpture. However, Elisa claimed she would work with you to get that money for herself. Elisa yelled at me: "Bob himself also knew all such kind activites are illegal. Howver, Bob wanted to do whatever to help me, keep away from Bob." Since then, you have met Elisa frequently and have never forwarded me any email about the money you raised for our art exhibition. Elisa told me that you cursed me many times such as "Gang is a junk, a jerk, a son of bitch", and all the money you raised should be transgerred to Yinghua Guo's personel account.

I really don't know how much money you have raised for Elisa. However, I do know that you have introduced Elisa to the president of the Atlantic Foundation, the Ford Foundation, and a partner of Warren Buffet. I do know that Elisa has transferred large amount amount of money between at least 7 bank accounts, from one of our joint account, Elisa transferred about $300,000 to her personel or her mother's account during last several months.

Elisa also mentioned that you have raised a lot money for her and you invited her to work for Human Rights in China to take over Sharon's position. On 6/26/2010, you called me and we spoke through phone. During our conversation, I told you again that Elisa is a graduate from the Chinese Military school, an active miltary officer of the Chinese PLA, a member of the Chinese Communist Party. She hid all these information and used falsified ID to enter the USA. I warned you that Elisa could be a military inteligency agency sent by the Chinese Army. I really can't give you a title or name what should I call her. It is easy for you to pick a name or whatever word to describe Elisa's identity. I asked you to stop raising money for Elisa. However, you didn't believe me and claimed I was a liar. You confirmed that it was true that you have invited Elisa to join the Human Rights In China, and you would be happy to match Yinghua Guo's current sallary. You also asked me about Elisa's current salary. I told you that her salary was less than $120,000 anually. You were so suprised about that. You said that the salary number Elisa told you was much more than $120,000. I told you that you could easily figure out who was a liar, if you want, I can provide you our tax return form. You also confirmed that you have introduced her to meet the big names mentioned above.

Elisa created the "Tear Down this Wall Foundation" and listed my name and Juntao Wang's name as board members, but she has never asked for our approval nor our signature. She created several bank accounts under the name of "Tear Down this Wall Foundation." Now Elisa took all the registration information, including the title and bank accounts with her. Neither Juntao Wang nor I could access the bank accounts, and we can't close the foundation. I have to report INS and FBI about the identy theft and other related illegal activities. They advised me inform all people who might be involved in these illegal acivities to stop transfer money to any accounts under the name of "Tear Down This Wall Foundation". Juntao Wang and I are not responsible to any money transaction from the accounts under the name of "Tear Down This Wall Foundation".

Please check the attached file for my lawsuit against Yinghua Guo, and Hu Jintao, and other PLA military officers. Based on the final statements Elisa Guo gave to the Somerset Superior court on 9/9/2010, Elisa clearly said she graduated from the Shanghai Second MILITARY Medical University and a military officer in the Chinese Army. However, she lied to the INS and her employers that she graduated from Shanghai Second Medical University, which is a normal medical school. If this is true, it is enough for the INS to arrest her and get her out of the USA.

Based on the evidence I have, I am hundred percent sure that Elisa Guo was a Chinese Military Agency and get paid by the Chinese Army roughly about $60K. As you, Steven, and Sharon are all human rights activists and long time supporters to the Chinese democracy movement, I want to warn you again: Please stop raise money for Elisa Guo, Please stop to support her to percecuted Gang Liu, who is percecuted, tortured, and senteced to 6 years by the chinese communist government due to my role in the 1989's Tiananmen pro-democratic movement. You should know that I am still on the most wanted list of the Chinese communist government, and the Chinse Communist Government keeps sending their inteligence agency to watch me, to abuse me, to destroy me, and to kidnap me. Please check the following 3 links for the similar cases:
张宏堡案件 http://en.wikipedia.org/wiki/Zhang_Hongbao
王炳章案件 http://en.wikipedia.org/wiki/Wang_Bingzhang
彭 明案件 http://www.assistnews.net/Stories/2007/s07120101.htm


Zhang Hongbao, Wang Bingzhang, and Peng Ming are all famous Chinese disidents. All of them were first allured by same two Chinese sisters, and then sued with domestic violence, traped in car accidents, or kidnaped by these Chinese women. Now one of them were killed in a car accident, two others were kidnaped by Chinese military agencies and are serving their life sentence in Chinese prisons. My follow exactly the same pattern with the other 3 cases. However, I'm lucky that I haven't gone that far yet even I lived with such a dangeraous woman for almost 3 years. I believe that Yinghua Guo is just another woman (or whatever you name it) sent by the Chinese communist military to do the similar task.


-----Original Message-----
From: Robert L. Bernstein [mailto:-----------------@att.net]
Sent: Thursday, October 15, 2009 11:00 AM
To: Liu, Gang (FID)
Cc: -----------@att.net
Subject: FW: TEAR DOWN THIS WALL EXPEDITION

FYI. Bob

-----Original Message-----
From: Robert L. Bernstein [mailto:-----------@att.net]
Sent: Wednesday, October 14, 2009 5:38 PM
To: Steve [------------@pen.org]
Cc: ---------------@att.net
Subject: TEAR DOWN THIS WALL EXPEDITION


Dear Steven,

I really enjoyed our meeting and if time ever allows, it would be great to have a non-agenda lunch. Here is a very brief presentation of Tear Down This Wall Expedition. The two people really moving it forward are Liu Gang and his wife Elisa Guo. I would be glad to meet them and you when you return from Austria, or even your associate while you are gone. If we can get this together fast enough they would like to get to Germany in the next few months.

Best,
Bob


Robert L. Bernstein
277 Park Avenue, xxth floor
New York, NY 10172
Tel # 212-207-xxxx












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