ATTORNEY Aaron Halegua has submitted to the federal court “additional evidence demonstrating the untruthfulness and/or implausibility of Imperial Pacific International LLC chairwoman Cui Li Jie’s testimony.”
Halegua and Bruce Berline are the lawyers of seven construction workers who have sued IPI and its former contractor and subcontractor, MCC International and Gold Mantis, over labor and human trafficking allegations.
Halegua has accused Cui of providing “demonstrably false testimony that she had never been to the casino site before this year, that she was not served with the subpoena, and that she did not have her cell phone (containing useful information about her WeChat contacts) in her purse during the deposition.”
In a supplemental declaration, Halegua attached Exhibit A which is a copy of the minutes of a meeting of the Commonwealth Casino Commission held on June 25, 2020.
He said, the “minutes reflect that on June 2, 2020, the CCC Chairman had a meeting with Ms. Cui, [IPI attorney] Mike Dotts, Su Hong Tao, Xing Tao, and others, in which IPI payroll, staff housing, and financing issues were discussed.”
At that meeting, the lawyer said, an understanding was reached that IPI would be sending a formal letter to the Commonwealth Lottery Commission and that Cui would sign it on behalf of IPI.
The minutes, Halegua added, also refer to Su Hong Tao as the “Rep. of the Chairlady.”
According to Halegua, “these facts underscore” that the following parts of Cui’s deposition testimony were “not true or, at best, grossly misleading”:
• That she does not know Mr. Su Hong Tao and does not know his relationship to IPI.
• That she has never met Mike Dotts before but had only heard of him.
• That she has no role at IPI.
• That she had not met with anyone from IPI while in the CNMI.
Halegua also attached Exhibit B, which is an announcement to the Hong Kong Stock Exchange dated Aug. 5, 2020 issued by Cui on behalf of IPI Holdings.
The announcement references a news article about a U.S. Department of Justice indictment that had been unsealed and charged Liwen Wu and Jianmin Xu (senior executives of IPI) and Yan Shi (an MCC supervisor) with crimes.
The announcement goes on to state: “The Board hereby clarifies and confirms that one of the persons indicted by the United States Department of Justice was a former employee of the Group who was non-managerial staff and left in 2017. It is understood that the concerned incidents involve an allegation against MCC International Saipan Ltd. Co., one of the contractors of the Group in 2016, of matters including harboring illegal aliens.”
Halegua said the following facts underscore that these parts of Cui’s deposition testimony were "not true or, at best, grossly misleading”:
• That she does not know of a Mr. Xu Jianmin, who worked for IPI.
• That she did not know that Mr. Liwen Wu had been criminally indicted.
• That she did not know that MCC was a contractor for IPI on the casino project.
Exhibit C, Halegua said, is an announcement to the Hong Kong Stock Exchange dated June 15, 2020, issued by Cui on behalf of IPI Holdings.
The announcement states that Cui Li Mei, who is the sister of Cui Li Jie, “has been appointed as an executive director, a member of the Executive Committee and the authorized representative” of IPI Holdings.
“This document underscores that the following parts of Ms. [Cui Li Jie’s] deposition testimony were not true or, at best, grossly misleading: that Cui Li Mei played no role at IPIH; that Cui Li Mei did not play any role at IPIH in the past; and that Cui Li Mei was never the executive director of IPIH,” Halegua added.
He is asking the court to award the plaintiffs attorney’s fees and costs as civil contempt sanction for the IPI chairwoman’s “evasive testimony.”
The plaintiffs in the lawsuit are Tianming Wang, Dong Han, Yongjun Meng, Liangcai Sun, Youli Wang, Qingchun Xu, and Duxin Yan. They have asked the federal court to issue an order awarding them $3.86 million in compensatory damages and $7.72 million in punitive damages.
The plaintiffs have already reached a settlement agreement with MCC International and Gold Mantis.
On Feb. 11, 2021, District Court for the NMI Chief Judge Ramona V. Manglona ordered the IPI chairwoman to explain in writing why she should not be put in jail for not complying with a legal summons.
The judge issued the order to show cause following a petition from the plaintiffs’ attorneys asking the federal court to find the IPI chairwoman in contempt of court for disobeying a valid and properly served subpoena.
A hearing will be held today, Feb. 23, at 9 a.m.