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Paul Kelley Responses

Paul Kelley Responses

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Published by: sharesleuthdocs on Jan 14, 2011
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09/28/2013

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Macleod Dixon

LLP

Toronto Almaty , Calgary Caracas Moscow Rio de Janeiro

Toronto-Dominion Centre Canadian Pacific Tower 100 Wellington Street West Suite 500, P.O. Box 128 Toronto, Ontario, Canada M5K 1H1 Main: (416) 360-8511 Fax: (416)360-8277

www.macleoddixon.com
Our file:

256615

Erik Penz Direct telephone: 416 203 4469 email: erik.penz@macleoddixon.com

20 March 2009 VIA DELIVERY

Aaron Blumenfeld Borden Ladner Gervais LLP Barristers & Solicitors Suite 4100 40 King Street West Scotia Plaza Toronto M5H3Y4 Dear Mr Blumenfeld: Re: Bankruptcy of Jay Tien Chiang Ontario Superior Court of Justice file nos. OO-CL-3835 and 31-352841

Further to the undertakings given at your examination of my client, Paul Kelley, on 11 March 2009, please find enclosed the answers to undertakings we have compiled to date, viz: 1. UT to advise as to date of Paul Kelley's first trip to China, whereat he first met Mei Huang. Response: September 2003. 2. UT to advise as to dates of Paul Kelley's trips to China with Jay Chiang. Response: September 2003, August 2004, April/May 2005 and November 2006. 3. UT to advise as to how many shares Winner International Group Limited received in Telestone Technologies Corp, Orsus Xelent Technologies Lie, New Oriental Energy & Chemical Corp and Kandi Technologies Corp, and to produce any associated agreements regarding such shares. Response: 1,452,500 shares in Orsus Xelent Technologies Inc 599,700 shares in New Oriental Energy & Chemical Corp 950,000 shares in Kandi Technologies Corp

Aaron Blumenfeld Borden Ladner Gervais LLP 20 March 2009 page 2

A T-|

Paul Kelley is awaiting a response to his enquiry concerning Telestone Technologies Corp. Paul Kelley is awaiting executed copies of the applicable share-purchase agreements and stock power(s) .for the shares obtained by Winner International Group Inc hi the foregoing companies. 4. UT to provide a summary of the payments received by Paul Kelley's companies from Winner International Group Limited and the associated expenses paid by Paul Kelley's companies. Response: please see attached. 5. UT to provide a copy of Paul Kelley's notice of resignation to Winner International Group Limited. Response: please see attached. 6. UT to make reasonable enquiries concerning whose telephone numbers are found on pages 843 and 845 of Paul Kelley's 10 March 2009 productions. Response: Paul Kelley has confirmed with Philip Cheng that +852 2521 9012 is Mr Cheng's old telephone number from before his office moved. Paul Kelley cannot determine whose telephone number +852 252 1251 is, and notes that it does not appear to have enough digits for a Hong Kong telephone number. 7. UT to ask Liya Wu to provide Huang Mei's mobile telephone numbers. Response: China mobile: +86 28 8966 8488 Hong Kong mobile: +852 6808 05091 Shenzhen mobile: +86 134 2395 09512
i

1 2

Apparently Huang Mei's Hong Kong mobile is only turned on when she is in Hong Kong. Apparently Huang Mei's Shenzhen mobile is oniy turned on when she is in Shenzhen.

Aaron Blumenfeld Borden Ladner Gervais LLP 20 March 2009 pageS

8.

UT to ask Liya Wu if she contacted Jay Chiang on 17 December 2007 to determine the correct account number for Winner International Group Limited's account with HSBC because of the wire returned to Lighthouse Financial Group LLC on or about 5 December 2007. Response: Liya Wu does not recall but does not believe that she obtained the correct account number for Winner International Group Limited's account with HSBC from Jay Chiang.

9.

UT to provide copies of the attachments forwarded to Jay Chiang with the 15 April 2008 email found at pages 902-905 of Paul Kelley's March 10 productions. Response: please see attached.

10.

UT to provide a copy of the power-point presentation for Asia First referenced in the 29 April 2008 email from Jay Chiang, at page 906 of Paul Kelley's March 10th productions, which Paul Kelley subsequently sent to Jay Chiang. Response: please see attached.

11.

UT to provide a copy of the LFG presentation emailed by Jacqueline Silva of Lightstone Financial Group LLC to Paul Kelley on 29 October 2008, and forwarded by Paul Kelly to Jay Chiang with the 31 October 2008 email at page 909 of Paul Kelley's March 10th productions. Response: please see attached.

12.

UT to review contacts and telephone records and to advise if the telephone number 647 868 8388 was Jay Chiang's telephone number and, if not, to advise as to whose number this is. Response: Liya Wu advises that 647 868 8388 was a number for a mobile telephone purchased by Ms Wu on 30 August 2007 at the expense of Paul Kelley's companies. This telephone was purchased at Jay Chiang's request, to loan to him for Mr Chiang to contact Jack Tang and Winner International Group Limited with regard to payment of the US going-public expenses for Telestone Technologies Corp, Orsus Xelent Technologies Inc, New Oriental Energy & Chemical Corp and Kandi Technologies Corp. Ms Wu was not aware that Paul Kelley had cancelled Asia First Financial Corp's contract with Jay Chiang on 26 June 2007.

Aaron Blumenfeld Borden Ladner Gervais LLP 20 March 2009 page 4

13.

UT to enquire from the bank as to the source of two wire payments received by Paul Kelley's companies from Winner International Group Limited. Response: enquiry made by Paul Kelley on 12 March 2009; Paul Kelley is awaiting the bank's response.

Kindest regards,

c.

Paul Kelley

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