Documenti di Didattica
Documenti di Professioni
Documenti di Cultura
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 Sang Lan , by and through their attorneys, the Law Office of Ming Hai,
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
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
http:l/www.timewarner.com.
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.
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-
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)-
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
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
http://www.timewarner.com.
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.
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 ) .
and/or domiciliary of the State of New York with a principal business address at : 225
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
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.
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
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
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
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
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
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)
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
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
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
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 .
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
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
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
Case 1:11-cv-02870-TPG Document 2-1 Filed 05/13/11 Page 11 of 38
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
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
40. Plaintiffs action as against AOL TIME WARNER, INC. and USA
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
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
Case 1:11-cv-02870-TPG Document 2-1 Filed 05/13/11 Page 13 of 38
Gymnastic Team. Thus, they are the boss of Ms. Sang Lan. She stayed there for ten
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
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
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.
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"
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
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
Case 1:11-cv-02870-TPG Document 2-1 Filed 05/13/11 Page 15 of 38
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
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 ,
! ~
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
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
hurtful to Sang Lan, caused Sang Lan irreparable extreme emotional distress, that
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
53 Defendants AOL and TED TURNER failed to perform and/or breached the
agreement.
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
restated herein.
coverage to Ms. LAN in the event of an accident during the Goodwill Games, which has
INSURANCE failed to perform and/or breached the agreement despite due notice and
opportunity.
60 As a direct result of the above, Ms. LAN has been damaged and
FEDERATION d/b/a USA GYMNASTICS and TIG INSURANCE jointly and severally
services that allow persons like Ms. LAN participate meaningfully in society.
discriminate against, Ms. LAN by denying full and equal access to, and full and equal
and demands judgment against TIG INSURANCE for an amount of damages of $ 100
Rights Law by denying full and equal access to, and full and equal enjoyment of, the
and demands judgment against TIG INSURANCE for an amount of damages of $ 100
Rights Law by denying full and equal access to, and full and equal enjoyment of, the
and demands judgment against TIG INSURANCE for an amount of damages of $100
services that allow persons like Ms. LAN participate meaningfully in society. THE
subject to the 5thAmendment and/or the 1 4 ' ~Amendment of the United States
Constitution.
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
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
and demands judgment against TIG INSURAIVCE for an amount of damages of $ 100
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.
and demands judgment against TIG INSURANCE for an amount of damages of $100
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
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
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
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
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
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;
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
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.
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,
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
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.
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
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
102 As a direct result of the above, Ms. LAN has been damaged,
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
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
106 Plaintiff also lost income, good public image as plaintiff has
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,
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
110 Plaintiff also lost income, good public image as plaintiff has
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,
112 Ms. LAN realleges each paragraph 1 through 111 of this complaint
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
114 Plaintiff also lost income, good public image as plaintiff has
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
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
120 Plaintiff also lost income, good public image as plaintiff has
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
122 Ms. LAN realleges each paragraph 1 through 121 of this complaint
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
125 K.S. LIU and K.S. GINA HIU-HUNG failed to pay in full despite
126 Plaintiff also lost income, good public image as plaintiff has
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
trial.
128 Ms. LAN realleges each paragraph 1 through 127 of this complaint
about a harmful and offensive contact with Ms. LAN without consent, provocation or
justification.
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
131 Plaintiff also lost income, good public image as plaintiff has
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
133 Ms. LAN realleges each paragraph 1 through 132 of this complaint
134 At all relevant times herein, Defendants owed a common law and
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-
137 Plaintiff also lost income, good public image as plaintiff has
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
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'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
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,
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
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
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.
under the circumstances that they know plaintiffs physical and emotional weakness.
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,
LIU and K.S. GINA HIU-HUNG and Hugh Mo and John Does and Jane Does
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
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,
WHEREFORE, Ms. LAN demands judgment against the Defendants, jointly and
severally, as follows:
damages for an amount of $ 100 millions for each and every cause of action, including
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
John Does and Jane Does # 1 through # 15 from further use of Ms. LAN's name, portrait,
g) Any further relief this Court deems just, proper and equitable.
BY..c
Hai, Ming ,Esquire
36-09 Main Street, 7B
Flushing, NY 11354
(718) 445-91 11
Pro Bono Attorneys for Plaintiff
SANG LAN
TED TURNER
One Time Warner Center
New York, New York 10019-8016
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
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Sang Lan ,being dtlfy sworn, depose itlld say to be ttnd correct, under the
Verified Complaint and know the contents thereof, The same are true and conect ta csmy
and belief, and as to tl~osematters, 1believe them to be &tie. Where I live in Chim no