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Case 1:11-cv-02870-TPG Document 2-1 Filed 05/13/11 Page 1 of 38

UNITED STATES DISTRICT COURT


SOUTHERN DISTRICT OF NEW YORK
....................................................................... X
SANG LAN
Index No. 1I L 2@ 7a
Plaintiff, JURY TRIAL DEMANDED

- against - AMENDED VERIFIED


COMPLAINT

AOL TIME WARNER, INC., THE UNITED STATES


GYMNASTICS FEDERATION d/b/a USA GYMNASTICS,
TIG INSURANCE COMPANY, TIG SPECIALTY
IIVSURANCE SOLUTIONS, RIVERSTOIVE CLAIMS
MANAGEMENT, LLC, TED TURNER, K.S. LIU
(CHINESE IVAME $4 &), K.S GINA HIU-HUNG
(CHINESE NAME i&@a), WILSON XUE (i%f%%),
HUGH MO ( , JOHN DOES AND JANE DOES # 1
THROUGH 15, INCLUSIVE

Defendants.
....................................................................... X

This law firm represents the plaintiff Sang Lan, a paralyzed girl on a wheelchair

since she was 17 years old. This is a pro bono case for this law firm, we represent

plaintiff free of charge.

Plaintiff Sang Lan , by and through their attorneys, the Law Office of Ming Hai,

P.C., hereby alleges as follows:

THE PARTIES

1. SANG LAN (hereinafter "Ms. LAN") is an individual, over the age of 18,

and citizen and/or domiciliary of the Peoples Republic of China who was injured in New

York during the 1998 Good Will Games.


Case 1:11-cv-02870-TPG Document 2-1 Filed 05/13/11 Page 2 of 38

2. AOL TIME WARNER, INC. (hereinafter "AOL") is a domestic

corporation, duly organized and operation under the State of New York with a principal

place of business known and located at One Time Warner Center, New York, New York

10019-8016, with a phone number (212)-484-8000 and a website

http:l/www.timewarner.com.

3. THE UNITED STATES GYMNASTICS FEDERATION d/b/a USA

GYMNASTICS (hereinafter "USA GYMNASTICS") is a foreign corporation, duly

organized and operating under the laws of the State of Indiana, with a principle place of

business known and located at 132 E. Washington Street, Suite 700, Indianapolis, IN

46204, with a phone number (3 17)-237-5050, with a fax number (3 17)-237-5069 and a

website www.usa-aymnastics.org.

4. TIG INSURANCE CONIPANY is a foreign corporation, organized and

operating under the laws of the State of New Hampshire, with a principal place of

business known and located at 250 Commercial Street, Suite 5000, Manchester, New

Hampshire 03 101, with a phone number (603)-656-2292, with a fax number (603)-656-

7656 and a website http://www.ti~specialty.com.

5. TIG SPECIALTY INSURANCE SOLUTIONS is a foreign corporation,

organized and operating under the laws of the State of New Hampshire, with a principal

place of business known and located at 250 Commercial Street, Suite 5000, Manchester,

New Hampshire 03 101, with a phone number (603)-656-2292, with a fax number (603)-

656-7656 and a website htt~://www.tigspecialt~.com.

6. RIVERSTONE CLAIMS MANAGEMENT, LLC is a foreign corporation,

organized and operating under the State of Delaware, with a registered business address
Case 1:11-cv-02870-TPG Document 2-1 Filed 05/13/11 Page 3 of 38

in Manhattan, New York at 111 Eighth Ave, New York, NY 10011. Its principal place of

business known and located at 250 Commercial Street, Suite 5000, Manchester, New

Hampshire 03 101, with a phone number (603)-656-2200 and a website

http://www.riverstone-group.com. RIVERSTONE CLAIMS MANAGEMENT, LLC is

the insurance agent.

7. TED TURNER (hereinafter "TED TURNER") is an individual, over the

age of 18 and a citizen and/or domiciliary of the State of New York with a principal place

of business known and located at One Time Warner Center, New York, IVew York

10019-8016, with a phone number (212)-484-8000 and a website

http://www.timewarner.com.

8. K.S. LIU (CHINESE NAME 3q a !ik) is an individual, over the age of 18


and a citizen andlor domiciliary of the State of New York with a principal residence

known and located at 17 Whippoorwill Road, Arrnonk, New York 10504.

9. K.S GINA HIU-HUNG (CHINESE NAME t%j$@&I)


is an individual, over

the age of 18 and a citizen and/or domiciliary of the State of New York with a principal

residence known and located at 17 Whippoorwill Road, Armonk, New York 10504.

10. TIG INSURANCE COMPANY, TIG SPECIALTY INSURANCE

SOLUTIONS and RIVERSTONE CLAIMS MANAGEMENT, LLC will be hereinafter

collectively referred to as "TIG INSURANCE".

11. WILSON XUE (%fl'5&), ) is an individual, over the age of 18 and a

citizen and/or domiciliary of the State of New York with a principal residence known and

located at 17 Whippoorwill Road, Armonk, New York 10504. WILSON XUE (@{%&)
Case 1:11-cv-02870-TPG Document 2-1 Filed 05/13/11 Page 4 of 38

is the son of K.S. LIU (CHINESE NAME ?fl B ?k)and K.S GINA HIU-HUNG
(CHINESE NAME $f B ! & I ) .

12. HUGH MO ( 8%) is an individual, over the age of 18 and a citizen

and/or domiciliary of the State of New York with a principal business address at : 225

Broadway, Suite 2702, New York NY 10007. HUGH MO ( is an attorney

licensed to practice law in the State of New York, is also a long term fiiends of co-

defendants K.S. LIU (CHINESE NAME 3!I g)and K.S GINA HIU-HUNG
(CHINESE NAME $$R$I)for at least 13 years. Based on information, belief and

admissions by defendants, HUGH MO ( %E)is also the former counsel for plaintiff

Sang Lan on a consultation basis regarding her 1998 injury and rights to seek recourse

from said injuries.

13. "JOHN DOES " AND "JANE DOES " # 1 THROUGH 15,

INCLUSIVE are fictious names, who are compliances and participants of defendants KS

Liu , Gina Liu and Hugh Mo' s campaigns to smear Sang Lan' s good name and

inflicted extreme emotional distress on her. As discovery may start, plaintiff will reserve

the right to substitute the fictious name with real names of the parties.

JURISDICTION AND VENUE

14. This Court has subject matter jurisdiction pursuant to 28 U.S.C. 5 1332
because of diversity of citizenship and the amounts in controversy are in excess of

$75,000.00, exclusive of interest and costs.


Case 1:11-cv-02870-TPG Document 2-1 Filed 05/13/11 Page 5 of 38

15. This Court has jurisdiction pursuant to the Civil Rights Act of 1964 42

U.S.C. 5 2000a et. seq. (hereinafter "Civil Rights Act"), the Americans with Disabilities

Act, 42 U.S.C. ?J 12181 et. seq. (hereinafter "ADA"), the Administrative Code of the City

of New York 5 8-107 et. seq. (hereinafter "New York City Human Rights Law"), the
New York State Executive Law 5 296 et. seq. (hereinafter "New York State Human

Rights Laws") and The New York State Insurance Law 5 2606.

16. This Court is vested with original jurisdiction under 28 U.S.C. 5 133 1 and
28 U.S.C. 5 1343. The New York City and New York State claims are properly before

this Court under the Court's supplemental jurisdiction pursuant to 28 U.S.C. 5 1367.
17. Venue is proper in this district pursuant to 28 U.S.C. 5 1391 because the
unlawful actions complained of occurred in, and the Defendants maintains its principal

place of business in, does business in, and has designated address located in this District

for service of process and, accordingly, resides in this District.

FACTUAL BACKGROUND

18. Ms. LAN ( %%), born June 11, 1981, is a former Chinese gymnast,

member of Chinese Gymnastic Team participated in the 1998 Goodwill Games held in

New York.

19. Ms. LAN started specialized training in gymnastics at the age of five (5),

which helped her to achieve excellence in gymnastics at a young age, including winning

every single event at the 1991 Zhejiang Province Championships. By 1995, she was
Case 1:11-cv-02870-TPG Document 2-1 Filed 05/13/11 Page 6 of 38

competing nationally and was one of China's strongest vaulters. She competed in the

Chinese Nationals, placing second in 1995 and first in 1997.

20. In 1998, Ms. LAN was selected to be a member of the Chinese team

competing in the fourth Goodwill Games. The Goodwill Games was founded and

organized by TED TURNER in the face that the world boycotted the Moscow Olympics

Game, after the former USSR invasion of Afghanistan, thus it is known as the "mini-

Olympics".

2 1. On July 2 1St, 1998, when Ms. LAN was only 17 years old, a minor, she

arrived in New York as a member of the Chinese Team to compete in the Goodwill

Games.

22. During warm-ups for the final vault event, Ms. LAN fell while she was

performing a timer (a simple vault, used by the athlete to familiarize themselves with the

apparatus and warm-up). She could not raise herself from the mat and was taken to the

hospital. The incident was caused by an employee/agent/guest/personal of the

defendants' organizer AOL and USA GYMNASTICS. Said person intentionally, and/or

alternatively, recklessly and/or grossly negligently walked into the vault area after Ms.

LAN pushed off the vault, but before she landed, and remove a mat from where she was

about to land. Ms. LAN was disturbed, fell and hit her head on the floor, leading to

permanent disability from her chest down and the immobility of her two arms and hands.

Tests indicated that she had fractured and dislocated her C6 and C7 vertebrae and injured

her spinal cord. The result of the injury was paralysis from the mid-chest down.

23. After the tragic event, many celebrities, including Leonardo DiCaprio,

Celine Dion and Christopher Reeve visited and offered their support. Ms. LAN was also
Case 1:11-cv-02870-TPG Document 2-1 Filed 05/13/11 Page 7 of 38

invited to participate in the New Year's Eve festivities in Times Square as an honored

guest with then Mayor Giuliani. The then United States President Bill Clinton and First

Lady sent their personal condolences; Vice President A1 Gore and his family visited Ms.

LAN in the hospital. Her tragic stories have been widely reported by international mass

medias worldwide.

24. Ms. Sang Lan is the only child of her parents as her parents have to

comply with the China "one child per couple" birth control policy. As Sang Lan is totally

paralyzed, she lost her ability to support her elderly parents who also grows ill as their

only child. Sang Lan's potential to have her own child in the future is also a big question

due to the 1998 injury. At present, Sang Lan lives on a 1600 RMB per month salary,

equals about $250 US Dollars per month, which is also the main reason why this law

firm decides to represent Sang Lan Pro Bono. .

25. Back to on or about July 22, 1998, the following day after the tragic

incident, Ms. LAN's biological parents were called, and immediately came to New York

from China. However, Ms. LAN's parents were immediately deprived of all parental

rights on their 17 years old daughter. Instead, K. S. LIU (CHINESE NAME $1. BLk)

and K.S GINA HIU-HUNG (CHINESE NAME i%lf 8$!!21)husband


, and wife, were

appointed by Chinese Gymnastic Association ,where Ms. LAN was employed ,to be her

guardian without due process or any legal procedures, to take an air tight control of

everything Ms. LAN may do or speak .

26. Based on information and belief, KS Liu and K.S GINA HIU-HUNG are

Chinese Americans, residents of the State of New York, County of Westchester, and

business partners with Chinese Gymnastic Association, involved in business


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dealingsltransactions such as Sports Lottery in China with corrupted officials in many

hundred millions dollars. K.S GINA HIU-HUNG was and still is the Vice-President of

the Official Chinese Gymnastic Association, despite the fact that she is not a Chinese

citizen, but citizens of the State of New York and of the United States. Her husband KS

Liu was the Vice President of Chinese National Swimming Team. It is extremely rare

and unusual for non-Chinese citizens to hold governmental office such as Vice-President

of Chinese Gymnastic Association. They catered Chinese officials of all levels in their

private homes in the State of New York.

27. KS Liu and K.S GINA HIU-HUNG have maintained offices in Beijing,

China, inside the very compound where the Chinese State Sport Committee situated.

Treatment such as this is a rare privilege for non-Chinese citizens, as a matter of fact,

they have been treated as and indeed they are Chinese State Sport Committee officials.

28. After being appointed as guardians against Ms. LAN's and her parents

will, KS Liu and K.S GINA HIU-HUNG have taken complete control of Ms. LAN's

activities, prohibits any media interviews except those authorized by their Chinese boss.

Sang mentioned that her fall was cause by the intrusion of another person when she was

sent to hospital, but the KS Liu and K.S GINA HIU-HUNG and their Chinese boss

immediately silenced her and dismissed her accusation, saying she had brain damage.

29. K.S. LIU and K.S GINA HIU-HUNG have acted in concert with Zhang

Jian, the President of Chinese Gymnastic Association, preventing Ms. LAN and her

parents from voicing any complaints or lodging claims against whoever could be liable

for her injuries, in an effort to protect the Defendants and business partners, who are
Case 1:11-cv-02870-TPG Document 2-1 Filed 05/13/11 Page 9 of 38

acting in a conflict of interest. As a matter of fact, Ms. LAN has been under house arrest

by K.S. LIU and K.S. GINA HIU-HUNG, who listens to their Chinese boss only.

30. In order to seal Ms. LAN's mouth from speaking out the truth, KS Liu and

K.S GINA HIU-HUNG falsely promised that they would provide for her needs and living

expenses for life, since they had profited from being appointed and acted as guardians

for her. KS Liu and K.S GINA HIU-HUNG 's business and company have harvested

several hundreds millions dollars income from Chinese Sports related business

transactions, since after they were appointed as guardian for Ms. LAN, and they only act

according to the instructions from their Chinese boss, who made them billionaires in

China .

3 1. K.S. LIU and K.S. GINA HIU-HUNG'S representations/promises have

never been made true.

32. After being officially appointed guardians by the Chinese Gymnastic

Association illegally, KS Liu and K.S GINA HIU-HUNG left Ms. LAN in New York

with their family members, and flighted to Bejjing one month after Ms. LAN's injury, to

hold a press conference with Zhang Jian, the President of Chinese Gymnastic

Association, declaring that Ms. LAN's injury was 100% her own fault, and she could not

and should not blame anyone else, let alone to sue anybody.

33. K.S. LIU and'^.^. GINA HIU-HUNG also illegally used Ms. LAN's
name, likeness and images without authorization from her or her parents in their business

activities, advertisements, website publications, etc.

34. KS Liu and K.S GINA HIU-HUNG also illegally published Ms. LAN's

and her boyfriend's private letters, mails, emails, messages, photos of her private home,
Case 1:11-cv-02870-TPG Document 2-1 Filed 05/13/11 Page 10 of 38

private life, private matters and other privacies she hope to keep private relating to her

disability and special needs on websites and other publications ,with malice to injure the

plaintiff.

35. On or about from January 201 1 till present day, immediately prior the

commencement of this action, KS Liu and K.S GINA HIU-HUNG started a propaganda

campaign to smear plaintiffs good name on the internet by publishing defamatory

statements, blogs, such as: "she is a wicked person, forgot all the good things (KS Liu

and K.S GINA HIU-HUNG have done for her), will be punished by God."; "Sang Lan is

a lazy person, only wants luxury. Her lawsuit is for money to satisfy her appetite for

luxuries."; "Sang Lan is so lazy, that she was trained to pee on her own, but she didn't .

I am a big man, I had to use a tube to assist her to pee." "Sang Lan is too lazy, can't get a

job. I helped her to get the job at the Star TV, through my connections with high rank

Chinese government officials, but she lost that job later because she didn't want to work

seriously"; "They (meaning Sang Lan and her boyfriend ) want to get pregnant, and

came to the U.S. to give birth of a baby in the US, so that her whole family can

immigrate to the US one day "; "they (meaning Sang Lan and her boyfriend ) are so

shameless, they should die", with apparent malice to ruin plaintiffs good name and

heroic image in public both in China and the United States. Above were published to

public, including but not limited to a New York based Chinese language website, which

can be seen by all Chinese citizens and the American citizens in both countries.

36. K.S. LIU and K.S GINA HIU-HUNG started a fund called "Good Will for

Sang Lan Fund" (hereinafter "Good Will Fund") that they ran out of their private

residence located at 17 Whippoorwill Road, Arrnonk, New York 10504. The Good Will
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Fund was established for the benefit of Ms. LAN by voluntary contributions/donations of

hundreds of thousands loving New Yorkers after Ms. LAN's tragic fall in 1998 in New

York. The money in the Good Will Fund was exclusively managed by the K.S. LIU and

K.S GINA HIU-HUNG and kept at Abacus Federal Savings Bank. As of June 18,2008,

the Good Will Fund allegedly had a cash balance of $140,000.00. K.S. LIU and

K.S GINA HIU-HUNG recently in 2008 provided portions of the fbnds to Ms. LAN

without accounting for the remaining fbnds. Said funds have been mishandled,

embezzled and comingled with defendants' personal funds without Sang Lan's consent.

37. Despite all of this, TED TURNER promised to Ms. LAN, her agents and

Chinese government officials including but not limited to then Chinese President Jiang

Zemin that that he and his companies would provide for Ms. LAN for her living

expenses and medical care for life. Ms. LAN has relied on TED TURNER's promise to

her own detriment. However, TED TURNER's promise is nothing but misrepresentation,

with no intent to deliver, merely for the purpose to advance defendants' own public

image and reputation as a charitable person.

38. Moreover, USA GYMNASTICS made an application and purchased

"catastrophic medical" insurance policy number SPX-37393552 from TIG INSURANCE

with a maximum liability policy limit of $10,000,000.00. The insurance policy provides

life-time medical coverage for Ms. LAN, but TIG INSURANCE has refbsed to provide

promised coverage under the excuse that Ms. LAN does not live in the United States.

39. Due the lack of proper insurance coverage, and TED TURNER's failure to

provide for Ms. LAN as promised, she could not receive the necessary treatments for the

past 13 years, and her physical condition has deteriorated as a result.


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40. Plaintiffs action as against AOL TIME WARNER, INC. and USA

GYMNASTICS, FORMERLY US GYMNASTICS FEDERATION has been seriously

delayed as Sang Lan has had no freedom to take actions, and mainly was because she has

been under the control of K.S. LIU and K.S. GINA HIU-HUNG, her alleged guardians

and trusteelmanagers of a "Good Will Fund", which are made by many donations to Ms.

LAN personally by New Yorkers after her tragic fall in the Good Will Game. K. S. LIU

and K.S GINA HIU-HLJNG refused to turn over the fund money to Ms. LAN for more

than 10 years. Only recently they turned a portion of the money to Ms. LAN's personal

control. Further, K. S. LIU and K.S GINA HIU-HUNG have been in total control of

Sang Lan's medical treatments, choices of treatment, any and all connections with

American doctors, and have threatened to cut off the links should Ms. LAN take legal

action. Living in China for the past 13 years, Ms. LAlV was literally unable to sue in an

American court or Chinese court. Ms. LAN has been struggling for the past 13 years in

China, without proper medical insurance coverage, without a penny compensatory

damage for her fatal permanent injury, without freedom or recourse to seek justice.

41. Ms. Sang Lan participated in the Good Will Game of 1998 in New York

when she was only 17 years old , and was injured and paralyzed from chest down

completely, lost all functions of her four limbs. Since then she has to be on a wheelchair

for life. After the injury, she and her mother were placed in KS Liu and Gina Liu 's

private home at 17 Whippoorwill Road, Arrnonk NY 10504. Mr. KS Liu and his wife

were appointed by Chinese Gymnastic Team as her official guardians in the US despite

the objection by her own mother. Gina Liu was and still is the Vice President of Chinese
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Gymnastic Team. Thus, they are the boss of Ms. Sang Lan. She stayed there for ten

months with her mother before she finally returned to China.

42. Recently, newspaper and other medias have revealed that Ms. Sang Lan

was sexually molested by KS Liu ,a then 60 years old male and his step-son Wilson Xue,

a male in his twenties. (See attached media reports). KS Liu and Wilson Xue have

bathed disabled Sang Lan nude, even though it is unnecessary, because Sang Lan's own

mother has undertaken that job. KS Liu even have touched Ms. Sang Lan's vagina area,

and stick a tube into her vagina under pretense to help her to urinate , which is not

necessary as Sang Lan's mother was available to help. KS Liu and Wilson Xue is not

licensed medical assistant. Sang Lan is completely helpless, and was totally embarrassed

and shocked, but dared not to report to police, because of her condition. Neither Ms Sang

Lan nor her mother speaks any English.

43. This may involve sex crimes against a minor. Even though the statute of

limitation is 5 years, KS Liu and Wilson Xue have been out of the country for most of

the past ten years, as they have been doing business in China and Hong Kong. It is

believed that in order to evade liabilities and other reasons, Wilson Xue has denounced

his US Citizenship and accepted Hong Kong citizenship. Therefore, the statute limitation

may have been tolled.

44. Ms. Sang Lan confirmed the above sexual assault and molestation against

her by defendants, and filed a police report recently with the Westchester County District

Attorney's Office.

45. Co-defendant Hugh Mo is a New York State attorney, a close family

friend of co-defendant KS Liu and Gina Liu for at least 13 years. During the period of 10
Case 1:11-cv-02870-TPG Document 2-1 Filed 05/13/11 Page 14 of 38

months after plaintiffs injury , plaintiff Sang Lan was placed in co-defendants house

arrests, Hugh Mo visited planiitff Sang Lan many times there, provided false legal advice

and consultations to Sang Lan regarding her injury , acted in concert with co-defendants

KS Liu and Gina Liu, in joint efforts to prevent Sang Lan from seeking legal action for

damages. As a long term personal legal adviser to KS Liu and Gina Liu who were

appointed as guardians for Sang Lan by the Chinese Gymnastic Team Association, Gina

Liu on many occasions admitted that she has consulted Hugh Mo regarding Sang lan's

injury and Sang Lan's legal rights related to her injuries, Hugh Mo advised Gina Liu that

Sang Lan may have a case but politically it would be wrong to pursue it. Hugh Mo is a

former NYPD police officer, and he has given his replica badge from NYPD to plaintiff

Sang Lan as a gift after several meetings in Gina Liu's home and legal consultations.

46. After Sang Lan made public that she intended to take actions against all

those who may be responsible for her permanent injury and sexual assault and

harassments ,KS Liu, K.S. GINA HIU-HUNG Liu, Hugh Mo and "JOHN DOES"

AND "JANE DOES" # 1 THROUGH 15, IIVCLUSIVE acted in concert, joined

together , organized and orchestrated a media and World Wide Web war to smear Sang

Lan's good name, image, including but not limited to the use of outrageous personal

insults, attacks, false accusations and humiliating and derogatory statements and words

against Sang Lan', Sang Lan's boyfriend, agent and representatives.

47. Hugh Mo spoke to media named QQ Sports on May 5thand May 6th,201 1,

that, " Sang Lan lied about being sexually harassed by Wilson Xue or KS Liu. Sexual

harassment never even occurred. It is all her own crafted creation or maybe it is her

lawyers' creation." "Sang Lan's lawsuit is frivolous, made of lies, will all be dismissed
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by the court." " Sang Lan and her lawyer will be severely sanctioned by the court."

" Sang Lan has personally insulted KS Liu and his family for no good cause." It is

particularly outrageous that Hugh Mo mocked Sang Lan's permanent injury and

disability by saying to the media that, " Sang Lan crashed herself on the ground 13 years

ago; today, she crashed herself once again on the law." An apology was demanded to no

avail.

48. Hugh Mo's malicious mocking was published world wide, as a major

leading force to a bigger and even more massive campaign to smear Sang Lan and hurt

her on the media and websites. After Hugh Mo's statements, co-defendants KS Liu ,

Wilson Xue ,K.S. GINA HIU-HUNG Liu, Hugh Mo and "JOHN DOES " AND

"JANE DOES " # 1 THROUGH 15, INCLUSIVE echoed by posting thousands more

of articles and derogatory statements on the internets where Sang Lan ,her boyfriend

Huang Jian and her lawyer maintain their personal homepages and blogs, by saying

things including but not limited to the following : "Sang Lan should die in her crash 13

years ago, or today. " " Sang Lan is a poisonous snake" , " Sang Lan is a wicked

witch ." " Don't come to New York, o r she w i 11 be killed. " , " Sang Lan will

have to commit suicide." " All she wants is money, she will die for it ." " Sang Lan is

condemned by God, that is why she crashed her neck." " Nobody should help Sang Lan,

a person condemned by God." " It is Sang Lan's fate to have her neck crashed." " Sang

Lan is paralyzed from chest down because she has an evil heart." "Sang Lan is the single

worst ungrateful person in entire human history, the evilest one in this whole world. So

evil , both human and God hates her with a passion." " Sang Lan, you have no face.

Huang Jian (Sang Lan's fiancke ) , You are so cheap." " Every citizen of this world
Case 1:11-cv-02870-TPG Document 2-1 Filed 05/13/11 Page 16 of 38

should kill Sang Lan and Huang Jian (Sang Lan's fiancde ) as a capital punishment for

them" . "In the dictionary, the word Sang Lan is interpreted as liar, cheater, ungrateful

devil." "Hugh Mo, we love you to speak for us, we want Sang Lan be put into death ."

" Hugh Mo, you are right. KS Liu and Gina Liku are not Sang Lan's guardians, but

volunteers, so that not responsible for anything." "Sang Lan is Bin La Din, and will have

same kind of death." "Sang Lan and her lawyer want death, Hugh Mo kill them all. You

can!." " Sang Lan ,who wants to sexually harasses you ? You are so dirty, even if you

wanted to be raped by someone, nobody wants to !" " Sang Lan, you should die long

time ago. Your heart has been eaten by the dogs whose owners took care of you (meaning

KS Liu's dogs). If you die, we will bum hell money for you. " (In Chinese custom,

people bum paper money for the dead for the dead to have money to spend in the other

world) . "Sang Lan, why are you still not dying? " " Sang Lan has a devil's face with a

snake heart." "Sang Lan ,you are half dead already, your body is nothing but an empty

shell." "Sang Lan, your second crash in New York (echoing defendant Hugh Mo's 2nd

crash theory) will be much worse than the first one 13 years ago." And so on. All of the

above have been happened after Hugh Mo's derogatory public speech against Sang Lan.

KS Liu , Gina Liu and Hugh Mo have encouraged, participated and indeed organized all

of the above illegal activities.

49. With full knowledge of all above is happening around, hatred, malice and

illegal activities were ongoing on the websites, Hugh Mo continued to speak ill of Sang

Lan to incite more hatred and brutal verbal violence against her. On May 11,201 1, Hugh

Mo met media again, told them that "Sang Lan is laughable to file a lawsuit for $1.8

billion dollars. Her 22 pages complaint is nothing but garbage." He refers the verbal
Case 1:11-cv-02870-TPG Document 2-1 Filed 05/13/11 Page 17 of 38

violence against Sang Lan on the internet as described in paragraph 47 and 48 of this

complaint, defendant Hugh Mo said, "that's dogs fights, dog bites dog." Sang Lan is a

"biting dog" bite the hands that feed her. " It is the farmer and snake story." Hugh Mo's

statements immediately spread all around amongst the Chinese community , media and

websites, helping to push a new wave of hatred , personal attacks on the " biting dog"

Sang Lan, a paralyzed girl on a wheelchair since she was 17 years old. Shortly after

Hugh Mo's above statements, on or about May 12,2011, co-defendants KS Liu , Wilson

Xue , K.S. GINA HIU-HUNG Liu, Hugh Mo and "JOHN DOES" AND "JANE

DOES" # 1 THROUGH 15, INCLUSIVE posted the following on the World Wide

Web, that " Garbage, human waste such as the rotten Sang Lan should not be accepted by

Beijing University, it is a dirty stain on that famous university. She is so ugly and

difficult to look at, especially her mole on top of her lips is like a piece of shit. She sits on

her wheelchair whole day long with nothing good to do but to calculate how to extort

money from people. She should and must go to hell! ." (original in Chinese as follows: %

$ + ~ $ B B R % ~ : ~ ~ ~ U L ~ L AE
~EIZ
, E~%G B ~ ~ t 3 3 ~ ~ 3 S+ Bn 2 ~ z ,
! ~

3P$$B@-$$R, @X@$E%@L#j ,E!6L%!E+, %ti+,&$+AjGij?Ti&ijit


! )

Above posting was posted in a language that can be understood by Sang Lan and at

numerous websites, homepages, including Sang Lan's own blogs, Sang Lan's attorney's

personal blogs, Sang Lan's boyfriend's personal blogs, etc, with the obvious intention to

hurt Sang Lan personally as much as possible.

50 . Given the fact that Hugh Mo is an influential figure in the Chinese

community, a formerly legal adviser to Sang Lan, a respectful elder to Sang Lan as she

often addressed him as "uncle" each time they met, a trusted friend, Hugh Mo's act of
Case 1:11-cv-02870-TPG Document 2-1 Filed 05/13/11 Page 18 of 38

betrayal as a friend and "uncle" ,breach of fiduciary duty as an attorney is particularly

hurtful to Sang Lan, caused Sang Lan irreparable extreme emotional distress, that

requires treatments, medications, and medical care.

AS AND FOR A FIRST CAUSE OF ACTION


Breach of Agreement

5 1 Ms. LAN realleges each paragraph 1 through 50 of this complaint as if fully

restated herein.

52 Ms. LAN and Defendants AOL and TED TURNER entered into an agreement

whereby Defendants AOL and TED TURNER would provide for Ms. LAN's

living expenses and medical care for life.

53 Defendants AOL and TED TURNER failed to perform and/or breached the

agreement.

54 Plaintiff also lost income, good public image as plaintiff has

always enjoyed, advertisement opportunities, job opportunities, etc.

55 As a direct result of the above, Ms. LAN has been damaged and demands

judgment against Defendants AOL and TED TURNER, jointly and severally for

an amount of damages of $ 100 millions to be proven at trial.

AS AND FOR A SECOND CAUSE OF ACTION


Breach of Agreement

56 Ms. LAN realleges each paragraph 1 through 55 of this complaint as if fully

restated herein.

57 Ms. LAN and Defendants THE UNITED STATES

GYMNASTICS FEDERATION d/b/a USA GYMNASTICS and TIG INSURANCE

entered into an agreement whereby Defendants agreed to provide life-time medical


Case 1:11-cv-02870-TPG Document 2-1 Filed 05/13/11 Page 19 of 38

coverage to Ms. LAN in the event of an accident during the Goodwill Games, which has

been acknowledged by the Defendants.

58 Ms. LAN performed all conditions precedent; Defendants THE

UNITED STATES GYh4NASTICS FEDERATION d/b/a USA GYMNASTICS and TIG

INSURANCE failed to perform and/or breached the agreement despite due notice and

opportunity.

59 Plaintiff also lost income, good public image as plaintiff has

always enjoyed, advertisement opportunities, job opportunities, etc.

60 As a direct result of the above, Ms. LAN has been damaged and

demands judgment against Defendants THE UNITED STATES GYMNASTICS

FEDERATION d/b/a USA GYMNASTICS and TIG INSURANCE jointly and severally

for an amount of damages of $ 100 millions to be proven at trial.

AS AND FOR A THIRD CAUSE OF ACTION


Violation of Americans with Disabilities Act

61 Ms. LAN realleges each paragraph 1 through 60 of this complaint

as if fully restated herein.

62 TIG INSURANCE is a place of public accommodation providing

services that allow persons like Ms. LAN participate meaningfully in society.

63 TIG INSURANCE has discriminated, and continues to

discriminate against, Ms. LAN by denying full and equal access to, and full and equal

enjoyment of, the services, privileges, advantages and/or accommodations as required

based upon her national origin despite requests.

64 Plaintiff also lost income, good public image as plaintiff has

always enjoyed, advertisement opportunities, job opportunities, etc.


Case 1:11-cv-02870-TPG Document 2-1 Filed 05/13/11 Page 20 of 38

65 As such, Ms. LAN has been damaged and continues to be damaged

and demands judgment against TIG INSURANCE for an amount of damages of $ 100

millions to be proven at trial.

AS AND FOR A FOURTH CAUSE OF ACTION


Violations of the New York City Human Rights Laws

66 Ms. LAN realleges each paragraph 1 through 65 of this complaint

as if fully restated herein.

67 TIG INSURANCE is in violation of the New York City Human

Rights Law by denying full and equal access to, and full and equal enjoyment of, the

services, privileges, advantages andlor accommodations as required based upon her

national origin despite requests.

68 Plaintiff also lost income, good public image as plaintiff has

always enjoyed, advertisement opportunities, job opportunities, etc.

69 As such, Ms. LAN has been damaged and continues to be damaged

and demands judgment against TIG INSURANCE for an amount of damages of $ 100

millions to be proven at trial.

AS AND FOR A FIFTH CAUSE OF ACTION


Violations of the New York State Human Rights Laws

70 Ms. LAN realleges each paragraph 1 through 69 of this complaint

as if fully restated herein.


Case 1:11-cv-02870-TPG Document 2-1 Filed 05/13/11 Page 21 of 38

71 TIG INSURANCE is in violation of the New York City Human

Rights Law by denying full and equal access to, and full and equal enjoyment of, the

services, privileges, advantages and/or accommodations as required based upon her

national origin despite requests.

72 Plaintiff also lost income, good public image as plaintiff has

always enjoyed, advertisement opportunities, job opportunities, etc.

73 As such, Ms. LAN has been damaged and continues to be damaged

and demands judgment against TIG INSURANCE for an amount of damages of $100

millions to be proven at trial.

AS AND FOR A SIXTH CAUSE OF ACTION


Violations of Civil Rights Act of 1964 and/or the 5thAmendment and/or the 14th
Amendment of the United States Constitution

74 Ms. LAN realleges each paragraph 1 through 73 of this complaint

as if fully restated herein.

75 TIG INSURANCE is a place of public accommodation providing

services that allow persons like Ms. LAN participate meaningfully in society. THE

UNITED STATES GYMNASTICS FEDERATION d/b/a USA GYMNASTICS

(hereinafter "USA GYMNASTICS") is State funded andlor Federal funded entity,

subject to the 5thAmendment and/or the 1 4 ' ~Amendment of the United States

Constitution.

76 TIG INSURANCE and "USA GYMNASTICS" have

discriminated, and continues to discriminate against, Ms. LAN by denying full and equal

access to, and full and equal enjoyment of, the services, privileges, advantages and/or

accommodations as required based upon her national origin despite requests. TIG
Case 1:11-cv-02870-TPG Document 2-1 Filed 05/13/11 Page 22 of 38

INSURANCE and "USA GYMNASTICS" have also discriminated plaintiff based on

race, national origins by denying her medical coverage on the ground that she resides in

China instead of in the U.S., in contrary to the Insurance Policy, Agreement, promises

made to plaintiff, law of this county and public policy.

77 Plaintiff lost income, good public image, advertisement

opportunities, job opportunities, etc.

78 As such, Ms. LAN has been damaged and continues to be damaged

and demands judgment against TIG INSURAIVCE for an amount of damages of $ 100

millions, including punitive damages, to be proven at trial.

AS AND FOR A SEVENTH CAUSE OF ACTION


Violations of the New York State Insurance Law

79 Ms. LAN realleges each paragraph 1 through 78 of this complaint

as if fully restated herein.

80 TIG INSURANCE is in violation of the New York State Insurance

Law by denying full and equal access to, and full and equal enjoyment of, the services,

privileges and advantages as required based upon her national origin despite requests.

81 Plaintiff also lost income, good public image as plaintiff has

always enjoyed, advertisement opportunities, job opportunities, etc.

82 As such, Ms. LAN has been damaged and continues to be damaged

and demands judgment against TIG INSURANCE for an amount of damages of $100

millions, including punitive damages, to be proven at trial.


Case 1:11-cv-02870-TPG Document 2-1 Filed 05/13/11 Page 23 of 38

AS AND FOR A EIGHTH CAUSE OF ACTION


Unjust Enrichment

83 Ms. LAN realleges each paragraph 1 through 82 of this complaint

as if fully restated herein.

84 K.S. LIU and K.S. GINA HIU-HUNG have knowingly,

intentionally, recklessly, fraudulently and in bad faith failed to provide Ms. LAN the

funds in the Good Will Fund despite due notice, ample opportunity and requests and

unjustly enriched as a result of their misconduct.

85 Plaintiff also lost income, good public image as plaintiff has

always enjoyed, advertisement opportunities, job opportunities, etc.

86 As a direct result of the above, K.S. LIU and K.S. GINA HIU-

HUNG have been unjustly enriched and Ms. LAN demands judgment against them,

jointly and severally, for an amount of damages of $ 100 millions, including punitive

damages, to be proven at trial plus disgorgement.

AS AND FOR A NINTH CAUSE OF ACTION


Conversion

87 Ms. LAN realleges each paragraph 1 through 86 of this complaint

as if fully restated herein.

88 K.S. LIU and K.S. GINA HIU-HUNG actually interfered with Ms.

LAN's right to possession of the f h d s in the Good Will Fund by the unlawful and

wrongful exercise of dominion and control over said funds, without justification, and

with intent to deprive Ms. LAN of her rights by their unauthorized acts in assuming

dominion and control, in defiance of Ms. LAN's right to possession of the funds.
Case 1:11-cv-02870-TPG Document 2-1 Filed 05/13/11 Page 24 of 38

89 Plaintiff also lost income, good public image as plaintiff has

always enjoyed, advertisement opportunities, job opportunities, etc.

90 As a direct result of the above, Ms. LAN has been damaged, and

continues to be damaged, and demands judgment against K.S. LIU and K.S. GINA HIU-

HUNG, jointly and severally for an amount of damages of $ 100 millions, including

punitive damages, to be proven at trial.

AS AND FOR A TENTH CAUSE OF ACTION


Breach of Fiduciary Duty as against K.S. LIU and K.S. GINA HIU-HUNG and Hugh Mo

91 Ms. LAN realleges each paragraph 1 through 90 of this complaint

as if fully restated herein.

92 K.S. LIU and K.S. GINA HIU-HUNG and Hugh Mo had a duty to

deal with Ms. LAN fairly, honestly and with undivided loyalty, and undertook that duty

accumulating substantial monetary gain there from. Hugh Mo as a former legal advisor

also owes a special duty to former client Sang Lan.

93 K.S. LIU and K.S. GINA HIU-HUNG and Hugh Mo

intentionally, recklessly and/or negligently breached their duty to Ms. LAN by their

action, including without limitation, the following: (I) failing to advise Ms. LAN of her

right to litigate her disputes, (2) failing to sue on her behalf; (3) publicly defaming her in

an effort to intimidate and threaten Ms. LAN from bring a lawsuit; (4) failing to disclose

their conflict of interest between Ms. LAN and the Chinese Gymnastic Association; (5)

failing to obtain her consent to use her image, name and likeness in their business

activities, advertisements; (6) failing and/or preventing Ms. LAN from speaking publicly

about her accident and/or lodging complaints against those that are liable for her injuries;
Case 1:11-cv-02870-TPG Document 2-1 Filed 05/13/11 Page 25 of 38

(7) publicly declaring that Ms. LAN's injuries were "100%" her fault without foundation;

(8) publicly publishing defamatory statements online and elsewhere in an effort to

intimidate and threaten Ms. LAN from bring a lawsuit; and (9) publishing Ms. LAN's

private letters, mails, messages, photos of her private home and other privacies related to

her disabilities and special needs online and elsewhere in an effort to intimidate and

threaten Ms. LAN from bring a lawsuit, among other things.

94 That K.S. LIU and K.S. GINA HIU-HLTNGs' and Hugh Mo's

actions and omissions are the proximate cause of Ms. LAN's damages, and that but for

the aforementioned actions and omissions, Ms. LAN would not have suffered damages.

95 Plaintiff also lost income, good public image as plaintiff has

always enjoyed, advertisement opportunities, job opportunities, etc.

96 As a direct result of the above, Ms. LAN has been damaged, and

continues to be damaged, and demands judgment against K.S. LIU and K.S. GINA HIU-

HUNG and Hugh Mo jointly and severally for an amount of damages of $ 100 millions,

including punitive damages, to be proven at trial.

AS AND FOR A ELEVENTH CAUSE OF ACTION


Defamation against
- K.S. LIU and K.S. GINA HIU-HUNG and Hugh Mo and John Does
and Jane Does

97 Ms. LAN realleges each paragraph 1 through 97 of this complaint

as if fully restated herein.

98 K.S. LIU , K.S. GINA HIU-HUNG, Hugh Mo, John Does and

Jane Does, with scienter, intentionally, maliciously, recklessly and in bad faith made

such defamatory statements ( more detailed specified in the background facts section of
Case 1:11-cv-02870-TPG Document 2-1 Filed 05/13/11 Page 26 of 38

this complaint) to third-parties in media interviews and online in their blogs in an

attempt intimidate and threaten Ms. LAN from bring a lawsuit, to stigmatize and smear

her good names and reputation in the eyes of the public and Chinese community.

99 The defamatory statements were of and concerning the Ms. LAN

as cited and recited by the named defendants.

100 K.S. LIU and K.S. GINA HIU-HUNG and Hugh Mo and John

Does and Jane Does made and published such statements knowing that they were false

and/or with reckless disregard of whether the statements were false or not, in a grossly

irresponsible manner without consideration for the standards of information gathering

and dissemination by responsible parties.

101 K.S. LIU and K.S. GINA HIU-HUNG and Hugh Mo and John

Does and Jane Does' statements were a substantial factor in causing Ms. LAN to suffer

actual harm and financial loss.

102 As a direct result of the above, Ms. LAN has been damaged,

including but not limited to loss of income, advertisement opportunities, job

opportunities, public images and reputation, etc., and demands judgment against K.S.

LIU and K.S. GINA HIU-HUNG and Hugh Mo and John Does and Jane Does ,jointly

and severally for an amount of damages of $ 100 millions to be proven at trial, including

special damages and punitive damages.

AS AND FOR A TWELFTH CAUSE OF ACTION


Civil Conspiracy as against K.S. LIU and K.S. GINA HIU-HUNG and Hugh Mo and
John Does and Jane Does
Case 1:11-cv-02870-TPG Document 2-1 Filed 05/13/11 Page 27 of 38

103 Ms. LAN realleges each paragraph 1 through 102 of this

complaint as if fully restated herein.

104 The foregoing and other actions and inactions by against K.S. LIU

and K.S. GINA HIU-HUNG and Hugh Mo and John Does and Jane Does were

intentionally and unjustifiably done in concert, agreement and conspiracy with each

other, for the purpose of inducing Ms. LAN to act and/or forebear from acting.

105 The aforesaid actions and inactions by against K.S. LIU and K.S.

GINA HIU-HUNG and Hugh Mo and John Does and Jane Does were grossly and

willfully fraudulent and were done with wanton, morally culpable and reckless disregard

for the rights of Ms. LAN.

106 Plaintiff also lost income, good public image as plaintiff has

always enjoyed, advertisement opportunities, job opportunities, etc.

107 As a direct result of the above, Ms. LAN has been damaged and

demands judgment against K.S. LIU and K.S. GINA HIU-HUNG and Hugh Mo and John

Does and Jane Does ,jointly and severally for an amount of damages of $ 100 millions,

to be proven at trial, including punitive damages.

AS AND FOR A THIRTEENTH CAUSE OF ACTION


Prima Facie Tort against K.S. LIU and K.S. GINA HIU-HUNG and Hugh Mo and John
Does and Jane Does

108 Ms. LAN realleges each paragraph 1 through 107 of this

complaint as if hlly restated herein.

109 K.S. LIU and K.S. GINA HIU-HUNG and Hugh Mo and John

Does and Jane Does , with scienter, intentionally, maliciously, recklessly and in bad faith
Case 1:11-cv-02870-TPG Document 2-1 Filed 05/13/11 Page 28 of 38

engaged in a campaign to smear the reputation and good name of Ms. LAN, without

justification, economic or otherwise.

110 Plaintiff also lost income, good public image as plaintiff has

always enjoyed, advertisement opportunities, job opportunities, etc.

111 As a direct result of the above, Ms. LAN has been damaged and

demands judgment against K.S. LIU and K.S. GINA HIU-HUNG and Hugh Mo and John

Does and Jane Does ,jointly and severally for an amount of damages of $ 100 millions,

including punitive damages, to be proven at trial, including special damages.

AS AND FOR A FOURTEENTH CAUSE OF ACTION


Invasion of Privacy

112 Ms. LAN realleges each paragraph 1 through 111 of this complaint

as if fully restated herein.

113 K.S. LIU and K.S. GINA HIU-HUNG intentionally and knowingly

use Ms. LAN's name, portrait, image and picture for the purposes of advertising or trade

without consent and for a profit.

114 Plaintiff also lost income, good public image as plaintiff has

always enjoyed, advertisement opportunities, job opportunities, etc.

115 As a direct result of the above, Ms. LAN has been damaged and

demands judgment against K.S. LIU and K.S. GINA HIU-HUNG, jointly and severally

for an amount of damages of $ 100 millions, including punitive damages, to be proven at

trial, including injunctive relief.

AS AND FOR A FIFTEENTH CAUSE OF ACTION


Promissory EstoppelIDetrimental Reliance
Case 1:11-cv-02870-TPG Document 2-1 Filed 05/13/11 Page 29 of 38

116 Ms. LAN realleges each paragraph 1 through 115 of this

complaint as if fully restated herein.

117 AOL and TED TURNER made clear and unambiguous promises

to provide for Ms. LAN's living expenses and medical care for life.

118 Ms. LAN reasonably and foreseeably relied upon AOL and TED

TUFChTER's representations to her detriment.

119 AOL and TED TURNER'S failed to pay despite their

representations and due notice.

120 Plaintiff also lost income, good public image as plaintiff has

always enjoyed, advertisement opportunities, job opportunities, etc.

121 As a direct result of the above, Ms. LAN has been damaged and

demands judgment against AOL and TED TURNER, jointly and severally for an amount

of damages to be proven at trial.

AS AND FOR A SIXTEENTH CAUSE OF ACTION


Promissory EstoppelIDetrimental Reliance

122 Ms. LAN realleges each paragraph 1 through 121 of this complaint

as if fully restated herein.

123 K.S. LIU and K.S. GINA HIU-HUNG made clear and

unambiguous promises to provide monies from the Good Will Fund for her benefit and

medical care.

124 Ms. LAN reasonably and foreseeably relied upon K.S. LIU and

K.S. GINA HIU-HUNG'S representations to her detriment.

125 K.S. LIU and K.S. GINA HIU-HUNG failed to pay in full despite

their representations and due notice.


Case 1:11-cv-02870-TPG Document 2-1 Filed 05/13/11 Page 30 of 38

126 Plaintiff also lost income, good public image as plaintiff has

always enjoyed, advertisement opportunities, job opportunities, etc.

127 As a direct result of the above, Ms. LAN has been damaged and

demands judgment against K.S. LIU and K.S. GINA HIU-HUNG, jointly and severally

for an amount of damages of $ 100 millions, including punitive damages, to be proven at

trial.

AS AND FOR A SEVENTEENTH CAUSE OF ACTION


Intentional Tort/Battery

128 Ms. LAN realleges each paragraph 1 through 127 of this complaint

as if fully restated herein.

129 Defendants intentionally, grossly, wantonly and willfully brought

about a harmful and offensive contact with Ms. LAN without consent, provocation or

justification.

130 That Defendants' intentional, gross, wanton, willful, harmful and

offensive contact was the proximate cause of Ms. LAN's damages, including without

limitation physical injury, humiliation, fkight, and/or mental anguish, and but for

Defendants' contact, Ms. LAN would not have suffered damages.

131 Plaintiff also lost income, good public image as plaintiff has

always enjoyed, advertisement opportunities, job opportunities, etc.

132 As a direct result thereof, Ms. LAN has been damaged and

demands judgment against Defendants, jointly and severally for an amount of damages of

$ 100 millions, including punitive damages, to be proven at trial.

AS AND FOR A EIGHTEENTH CAUSE OF ACTION


Negligence
Case 1:11-cv-02870-TPG Document 2-1 Filed 05/13/11 Page 31 of 38

133 Ms. LAN realleges each paragraph 1 through 132 of this complaint

as if fully restated herein.

134 At all relevant times herein, Defendants owed a common law and

contractual duty to Ms. LAN.

135 Defendants breached their duty to Ms. LAN by failing to exercise

the degree of care, skill and diligence commonly possessed and exercised under the

circumstances.

136 That Defendants' failure to exercise the degree of care, skill and

diligence commonly possessed and exercised under the circumstances is the proximate

cause for Ms. LAN's damages, and that Ms. LAN would not have suffered damages but-

for Defendants' negligence.

137 Plaintiff also lost income, good public image as plaintiff has

always enjoyed, advertisement opportunities, job opportunities, etc.

138 As a direct result thereof, Ms. LAN has been damaged and

demands judgment against Defendants, jointly and severally for an amount of damages of

$ 100 millions, to be proven at trial, including special and punitive damages.

AS AND FOR A NINETEENTH CAUSE OF ACTION


BATTERY ISEXTUAL HARRASSMENT AS AGAINST KS LIU AND WILSON XUE

139 Plaintiff realleges each paragraph 1 through 138 of this complaint

as if fully restated herein.


Case 1:11-cv-02870-TPG Document 2-1 Filed 05/13/11 Page 32 of 38

140 Plaintiff Ms. Sang Lan was sexually molested by KS Liu , a 60

years old male and his step-son Wilson Xue, a male in his twenties. KS Liu and Wilson

Xue have bathed disabled Sang Lan nude, even though it is unnecessary, because Sang

Lan's own mother has undertaken that job. KS Liu even have touched Ms. Sang Lan's

vagina area, and stick a tube into her vagina under pretense to help her to pee, which is

not necessary as Sang Lan's mother was available to help. KS Liu and Wilson Xue is not

licensed medical assistant. Sang Lan is completely helpless, and was totally embarrassed

and shocked, but dared not to report to police, because of her condition. Neither Ms Sang

Lan nor her mother speaks any English.

141 Above described unauthorized touches and invasion of Ms. Sang

Lan's body is without plaintiffs consent or justification. Defendants are not medical

personals. Indeed, those unwanted sexual advance have caused medical complications to

plaintiff.

142 Plaintiff also lost income, good public image as plaintiff has

always enjoyed, advertisement opportunities, job opportunities, etc.

143 As a direct result thereof, Ms. LAN has been agonized, humiliated,

injured , fell into illness, severely damaged, and demands judgment against Defendants,

jointly and severally for an amount of damages of $ 100 millions, to be proven at trial,

including special and punitive damages.

AS AND FOR A TWENTYTH CAUSE OF ACTION


Case 1:11-cv-02870-TPG Document 2-1 Filed 05/13/11 Page 33 of 38

Intentional Infliction of Extreme Emotional Distress as against K.S. LIU and K.S.

GINA HIU-HUNG and Hugh Mo and John Does and Jane Does #1 through # 15

144 Plaintiff realleges each paragraph 1 through 143 of this complaint

as if fully restated herein.

145 In order to prevent, discourage, intimidate plaintiff from taking

action to exercise her rights and for other purposes, defendants K.S. LIU and K.S. GINA

HIU-HUNG and Hugh Mo and John Does and Jane Does #1 through # 15 have acted in

concert, conducted themselves , mobilized a war on media , internet ,among other things,

as more fully described in background story section of this complaint, in such a way so

shocking and outrageous to plaintiff Sang Lan, who is a former National Gymnastic

Champion but paralyzed and live on a wheelchair for life , that has exceeds all

reasonable bounds of decency as measured by what the average member of the

community would tolerate.

146 Defendants conducts have caused sever emotional distress to

plaintiff, plaintiffs family members. Plaintiff has wept, cried, lost sleep, appetite, need

medications and medical care to cope with the sever distresses. Plaintiff also lost income,

good public image as plaintiff has always enjoyed, advertisement opportunities, job

opportunities, etc.

147 Defendants intended to cause such emotional distress on plaintiff,

under the circumstances that they know plaintiffs physical and emotional weakness.

Defendants act are malicious, deserve punitive damages.

148 As a direct result thereof, Ms. LAN has been agonized, humiliated,

injured , fell into illness, severely damaged, and demands judgment against Defendants,
Case 1:11-cv-02870-TPG Document 2-1 Filed 05/13/11 Page 34 of 38

jointly and severally for an amount of damages of $ 100 millions, to be proven at trial,

including special and punitive damages.

AS AND FOR A TWENTY-FIRST CAUSE OF ACTION


Negligently/Recklessly Infliction of Extreme Emotional Distress as against K.S.

LIU and K.S. GINA HIU-HUNG and Hugh Mo and John Does and Jane Does

149 Plaintiff realleges each paragraph 1 through 148 of this complaint

as if fully restated herein.

150 In order to prevent, discourage, intimidate plaintiff from taking

action to exercise her rights and for other purposes, defendants K.S. LIU and K.S. GINA

HIU-HUNG and Hugh Mo and John Does and Jane Does #1 through # 15 have acted in

concert, conducted themselves , mobilized a war on media, internet ,among other things,

as more fully described in background story section of this complaint, in such a way so

shocking and outrageous to plaintiff Sang Lan, who is a former National Gymnastic

Champion but paralyzed and live on a wheelchair for life , that has exceeds all

reasonable bounds of decency as measured by what the average member of the

community would tolerate.

151 Defendants conducts have caused sever emotional distress to

plaintiff, plaintiffs family members. Plaintiff has wept, cried, lost sleep, appetite, need

medications and medical care to cope with the sever distresses. Plaintiff also lost income,
Case 1:11-cv-02870-TPG Document 2-1 Filed 05/13/11 Page 35 of 38

good public image as plaintiff has always enjoyed, advertisement opportunities, job

opportunities, etc.

152 Defendants have acted in such a reckless manner, and all acts are

done in such a manner and under the circumstances that they know plaintiffs physical

and emotional weakness as a disabled person, as to show defendants utter disregard of the

consequences that may follow. Defendants acts are grossly recltless, deserve punitive

damages.

153 As a direct result thereof, Ms. LAN has been agonized, humiliated,

injured , fell into illness, severely damaged, and demands judgment against Defendants,

jointly and severally for an amount of damages of $ 100 millions, to be proven at trial,

including special and punitive damages.

WHEREFORE, Ms. LAN demands judgment against the Defendants, jointly and

severally, as follows:

a) An award of actual, compensatory, consequential damages and special

damages for an amount of $ 100 millions for each and every cause of action, including

punitive damages, to be determined at trial;

b) An award of reasonable attorney's fees;

c) An award of statutory interest, costs and disbursements;

d) An order declaring TIG INSURANCE in violation of Civil Rights Act,

ADA, New York City Human Rights Law, New York State Executive Law and New

York State Insurance Law and requiring TIG INSURANCE a reasonable time to

undertake and complete corrective procedures;


Case 1:11-cv-02870-TPG Document 2-1 Filed 05/13/11 Page 36 of 38

e) An order enjoining KS Liu , K.S. GIIVA HIU-HUNG and Hugh Mo and

John Does and Jane Does # 1 through # 15 from further use of Ms. LAN's name, portrait,

image and picture;

f) An award of punitive damages;

g) Any further relief this Court deems just, proper and equitable.

Dated: Flushing, New York


May /> 2011
LAW OFFICE OF MING HAI, P.C.

BY..c
Hai, Ming ,Esquire
36-09 Main Street, 7B
Flushing, NY 11354
(718) 445-91 11
Pro Bono Attorneys for Plaintiff
SANG LAN

To: AOL TINIE WARNER, INC.


One Time Warner Center
New York, New York 10019-8016

THE UNITED STATES GYMNASTICS FEDERATION d/b/a USA GYMNASTICS


132 E. Washington Street, Suite 700
Indianapolis, IN 46204

TIG INSURANCE COMPANY


250 Commercial Street, Suite 5000
Manchester, New Hampshire 03 101

TIG SPECIALTY INSURANCE SOLUTIONS


250 Commercial Street, Suite 5000
Manchester, New Hampshire 03 101

RIVERSTONE CLAIMS MANAGEMENT, LLC


I l l fIthAve.
New York NY 10011
Case 1:11-cv-02870-TPG Document 2-1 Filed 05/13/11 Page 37 of 38

TED TURNER
One Time Warner Center
New York, New York 10019-8016

K.S. LIU (CHINESE NAME $!I !&)


17 Whippoorwill Road
Armonk, New York 10504

K.S GINA HIU-HLNG (CHINESE NAME i%l'l@,!kC)


17 Whippoorwill Road
Armonk, New York 10504
WILSON XUE (@{%&),
17 Whippoorwill Road
Armonk, New York 10504

HUGH MO ( %l% )
225 Broadway, Suite 2702
New York NY 10007
Case 1:11-cv-02870-TPG Document 2-1 Filed 05/13/11 Page 38 of 38

UNITED STATES DISTRICT COURT


SOII'I"mRN DISTRICT OF NEW YOEX
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AOL 'TIMEWARNER, INC., THE UNITED STATES


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SlTRANCE COWANY, TIC SPECIAI.,TfY
LUTIONS, RIVERSTONE C1,AIMS
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(CHINESE NAME l$f!$i3 &X), WILSON XUE ($$%$!),
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Sang Lan ,being dtlfy sworn, depose itlld say to be ttnd correct, under the

penalties of perjury, the following:

in the within actioa. I have read the foregoing Ainended


1am the PIait~tiE

Verified Complaint and know the contents thereof, The same are true and conect ta csmy

o'i.vx1h~awiedge,except as to the matters tlrerei~statccl to be dleged uqan inkrmation

and belief, and as to tl~osematters, 1believe them to be &tie. Where I live in Chim no

US Notary Pufilt's is available to rtotarize may ~ i g n a ~~SIBS,


e , I am signing this

verificatislz in the presence of tt+*owitl~esses.


0 5 / 1 3/ Z O (/
QI

I$e t130fl$t fie\


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Wib~esses# 2
He Dong Mei