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UNITED STATES DISTRICT COURT

SOUTHERN DISTRICT OF OHIO

WESTERN DIVISION

- - -

UNITED STATES OF AMERICA,

Plaintiff,

vs.

YANJUN XU, also known as XU

YANJUN, also known as QU HUI,

also known as ZHANG HUI,

Defendant.

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CASE NO. 1:18-cr-0043

IN-PERSON TRIAL

PROCEEDINGS

21st of OCTOBER, 2021

9:43 A.M.

DAY 4

- - -

TRANSCRIPT OF PROCEEDINGS

BEFORE THE HONORABLE TIMOTHY S. BLACK, JUDGE

- - -

APPEARANCES:

For the Plaintiff:

Timothy S. Mangan, Esq.

Emily N. Glatfelter, Esq.

Assistant United States Attorneys

221 East Fourth Street, Suite 400

Cincinnati, Ohio 45202

and

Matthew John McKenzie, Esq.

United States Department of Justice

National Security Division

950 Pennsylvania Avenue NW

Washington, D.C. 20530

and

Jacqueline K. Prim

Special Assistant, Paralegal

United States Department of Justice

National Security Division

950 Pennsylvania Avenue NW

Washington, D.C. 20530

For the Defendant:

Ralph William Kohnen, Esq.

Jeanne Marie Cors, Esq.

Sanna-Rae Taylor, Esq.

Courtney Lynch, Esq.

Taft Stettinius and Hollister

425 East Walnut Street, Suite 1800

Cincinnati, Ohio 45202

and

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Robert K. McBride, Esq.

Amanda Johnson, Esq.

Taft Stettinius and Hollister

50 East RiverCenter Boulevard

Suite 850

Covington, Kentucky 41011

and

Florian Miedel, Esq.

Miedel & Mysliwiec, LLP

80 Broad Street, Suite 1900

New York, New York 10004

Also present: Mae Harmon, Interpreter

Robin Murphy, Interpreter via telephone

Yanjun Xu, Defendant.

Law Clerk: Cristina V. Frankian, Esq.

Courtroom Deputy: Rebecca Santoro

Stenographer: Julie Hohenstein, RPR, RMR, CRR

United States District Court

200 West Second Street

Dayton, Ohio 45402

Proceedings reported by mechanical stenography,

transcript produced by computer.

*** *** *** ***

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INDEX

WITNESSES DIRECT CROSS REDIRECT RECROSS

BRADLEY HULL 9

INDEX OF EXHIBITS

EXHIBITS MARKED ADMITTED

Government's Exhibit 63b 13 14

Government's Exhibit 2c 18 19

Government's Exhibits 11a

through 11h

23 23

Government's Exhibit 17 28 29

Government's Exhibit 18 30 31

Government's Exhibits 21a

and 21b

37 38

Government's Exhibit 22 45

Government's Exhibits 23

through 28

46 47

Government's Exhibit 29a 63 64

Government's Exhibit 29b 64 65

Government's Exhibit 29c 65 65

Government's Exhibits 31a

and 31b

69 70

Government's Exhibit 32a 79 80

Government's Exhibits 32b

through 32i

80 85

Government's Exhibit 33a 92 94

Government's Exhibits 33b

through 33h

95 96

Government's Exhibits 37a

and 37b

108 109

Government's Exhibit 36 111 112

Government's Exhibits 38a

and 38b

126 128

Government's Exhibit 38c 128 129

Government's Exhibits 39a

and 39b

135 136

Government's Exhibits 40a

and 40b

138 139

Government's Exhibits 41a

and 41b

141 142

Government's Exhibits 42a

and 42b

152 152

Government's Exhibits 43a

and 43b

168 169

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Government's Exhibits 43c

and 43d

170 171

Government's Exhibit 43e 174 175

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P-R-O-C-E-E-D-I-N-G-S 9:43 A.M.

COURTROOM DEPUTY: All rise. This United States

District Court for the Southern District of Ohio is now in

session. The Honorable Timothy S. Black, District Judge,

presiding.

THE COURT: Please be seated. Good morning. We

are here in the open courtroom on the record. Quarter to

ten in the continuation of United States of America versus

Xu.

The Government team is present in full. Defense

team is present in full. Defendant is present with his

interpreter.

We have arranged for a second interpreter to be

court provided, and it's my understanding that she will be

interpreting everything by phone into the Defendant's ears.

I want to pause and ask the Defendant through

counsel whether this is working?

MR. MIEDEL: Your Honor, Florian Miedel. Could I

have just a moment with Ms. Frankian?

THE COURT: Yes.

(Mr. Miedel confers with Ms. Frankian.)

(The Court confers with Ms. Frankian.)

THE COURT: So I've been advised to ask the

question again of the Defendant through counsel. Is the

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current interpretation process working?

THE INTERPRETER: (Interpreting from English to

Mandarin Chinese.)

MR. FLORIAN: Your Honor, I think the problem is

that the microphone that picks up Mr. Xu's voice also picks

up what's in the, in the courtroom; and so it creates

feedback, and so we're trying -- I think we're just trying

to work out that technical issue. Otherwise it should be

fine.

THE COURT: So should I chill for a moment? This

is your opportunity to tell a Federal Judge to chill.

(Laughter.)

MR. MIEDEL: You can chill for a moment, Judge.

THE COURT: Very well. We'll go off the record.

(Discussion held off the record.)

MR. MIEDEL: All right, Judge. I think we're ready

to go.

THE COURT: The interpretation is working to the

satisfaction of the Defense; is that right?

MR. MIEDEL: That's correct.

THE COURT: Ms. Frankian, do I need to inquire of

the interpreter how she's doing?

MS. FRANKIAN: Judge, I don't know that she can

respond unless she responds through Mr. Xu.

THE COURT: I need to administer the oath.

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MS. FRANKIAN: Oh. I don't know how we're going to

do that.

THE COURT: She can hear me; correct?

MS. FRANKIAN: Yes.

THE COURT: And her first name is Robin?

MS. FRANKIAN: Robin Murphy.

THE COURT: Ms. Murphy, this is Judge Black. Would

you raise your right hand. Do you solemnly swear or affirm

that you will accurately translate these proceedings today?

INTERPRETER ROBIN MURPHY: Yes, I do.

THE COURT: Thank you. We're going to have to go

slower and take more frequent breaks because it's exhausting

for the translator, and I want to be sure it's working

properly.

We're all advised to speak slowly. When you ask a

question, pause. The interpreter will interpret it, and

then you'll get your answers. So we're going to take a

break in about 30 minutes.

I'm going to call for the Jury. What does the

Defense propose I tell the Jury about the addition of a

second interpreter, if anything, and the need for us to take

more regular breaks?

MR. McBRIDE: Your Honor, I suggest that the Court

explain to the Jurors that this is for the benefit of the

process. That Mr. Xu is fully aware of the proceedings

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today, and that the Court has provided this for him because

he was becoming -- he was starting to have difficulty

keeping up with the evidence as it came in.

THE COURT: Is the Government comfortable with that

approach? Take a moment if you wish to whisper.

MR. MANGAN: Your Honor, I don't know that we need

to get into the reasons. If the Court wants to explain to

them that there is going to be an additional translator and

that may slow things down, I think that would be enough to

inform them.

They will -- I believe we will have somebody

in-person next week, and then obviously they would see it in

realtime that they are going to have an additional

translator here.

THE COURT: I'm inclined to be as succinct as I

can. Are you comfortable with the Government -- with what

the Government has suggested, Mr. McBride?

MR. McBRIDE: Yes, sir.

THE COURT: Very well. I'll do the best I can.

MR. McBRIDE: Thank you.

THE COURT: Let's call for the Jury, please. Is

Mr. Kohnen here today?

MR. McBRIDE: He is, sir.

MR. KOHNEN: Good morning, Your Honor.

THE COURT: Good morning, Mr. Kohnen.

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SPECIAL AGENT BRADLEY HULL -- DIRECT 9

COURTROOM DEPUTY: All rise for the Jury.

(Jury entered the Courtroom.)

THE COURT: All 15 Jurors have arrived. You may

all be seated. To the 15 Jurors, good morning. Thank you

for your continued participation, attention, and patience.

We've arranged for a second interpreter to assist

the process. We're going to have to take more frequent

breaks, so this morning we're going to take a break pretty

quickly after 30 minutes, and at this point the Government

has the opportunity to call its next witness.

MR. MANGAN: Your Honor, the Government calls

Special Agent Bradley Hull.

THE COURT: If that gentleman would approach the

witness stand? And if you'd pause and raise your right hand

for the oath.

BRADLEY HULL, GOVERNMENT'S WITNESS, SWORN

THE WITNESS: I do.

THE COURT: Very well. You may be seated at the

stand. Get yourself acclimated close to the microphone.

Mr. Mangan, you may proceed slowly.

MR. MANGAN: Thank you, Your Honor.

DIRECT EXAMINATION

BY MR. MANGAN:

Q Good morning, sir. Can you state your full name and

spell your last name?

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SPECIAL AGENT BRADLEY HULL -- DIRECT 10

A My name is Bradley Douglas Hull, H-U-L-L.

Q And where do you work?

A I work in the Cincinnati Division of the Federal

Bureau of Investigation.

Q What is your job title?

A I'm a Supervisory Special Agent.

Q And do you work in a particular area?

A I do. I specialize in counterintelligence

investigations.

Q Special Agent Hull, what is counterintelligence?

A Counterintelligence is a very broad investigative

scope within the F.B.I. We cover everything from espionage

investigations, which is when someone is spying inside the

United States Government, through to things like trade

control investigations when controlled commodities would be

leaving the United States and sort of everything in between.

THE COURT: I'm going to ask you to be slow in your

answers.

BY MR. MANGAN:

Q Special Agent Hull, can you explain your educational

background?

A Yes. I hold an undergraduate degree from the

University of Edinburgh in Scotland. I hold a Master's

degree in Art with Honors from the University of Edinburgh

in Scotland. I hold a Master's degree in Science from the

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SPECIAL AGENT BRADLEY HULL -- DIRECT 11

University of Wisconsin at Madison, and I hold a Doctorate

from the University of Oxford in England.

Q And explain what was the field for your Doctorate in

Oxford?

A It was archeology and the stable isotope geochemistry.

Q All right. And for a time, did you teach while in

Oxford?

A Yes.

Q What state are you originally from?

A I'm proudly from Ohio.

Q All right. Special Agent Hull, after leaving Oxford,

did you begin working at the F.B.I.?

A Yes.

Q In what division?

A The Laboratory Division at Quantico, Virginia.

Q And was that as a scientist?

A Yes.

Q Okay. At some point did you become a Special Agent?

A Yes.

Q What year was that?

A 2010.

Q In your career as a Special Agent, what types of cases

have you investigated?

A Exclusively counterintelligence investigations.

Q Have you received ongoing training from the F.B.I. in

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SPECIAL AGENT BRADLEY HULL -- DIRECT 12

counterintelligence?

A Yes.

Q In what field offices have you worked in?

A I've served in the Boston Division and the Cincinnati

Division.

Q All right. And what is your current squad?

A I supervise the Counterintelligence Squad in Southern

and Southwestern Ohios.

Q Okay. Special Agent Hull, were you involved in the

investigation of the Defendant, Xu Yanjun?

A Yes, I was the Case Agent.

Q Were you also involved in the investigation of a

person named David Zheng?

A Yes.

Q Can you explain who he is?

A Dr. Zheng was an employee of GE Aviation based in

Evendale, Ohio.

Q And what was the nature of your investigation into Dr.

Zheng?

A We had determined that Dr. Zheng may have been in

contact with an agent of the Chinese Government, and we

investigated thusly.

Q Was there a particular trip to China that you were

investigating?

A Yes. A trip in May and June of 2017.

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SPECIAL AGENT BRADLEY HULL -- DIRECT 13

Q Now, did you reach out to GE -- excuse me.

Did you reach out to GE Aviation for assistance with

that investigation?

A Yes.

Q And from that information -- or excuse me.

And from them did you learn that information had been

downloaded by the employee?

A Yes.

Q All right. And as part of the investigation, did you

prepare search warrants related to the employee's E-Mail

accounts?

A Yes.

Q Did you also prepare a search warrant for the home of

the GE employee?

A Yes.

Q And was that the same date that you interviewed the

employee?

A Yes. On November 1st of 2018.

Q Was that 2017?

A 2017. I apologize, yes.

Q Okay.

(Government's Exhibit 63b marked.)

MR. MANGAN: I'm going to ask if we could show the

witness Exhibit 63b?

THE COURT: Yes, 63b.

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SPECIAL AGENT BRADLEY HULL -- DIRECT 14

(Government's Exhibit 63b was shown on the screen for the

Court and Witness.)

BY MR. MANGAN:

Q Agent Hull, do you recognize that?

A I do.

Q Can you describe what it is?

A It is a business card with the name Qu Hui, Associate

with the Jiangsu Association of Science and Technology.

Q And where did you find this?

A In the GE Aviation engineer's home.

Q In his home?

A In his home, yes, sir.

MR. MANGAN: Your Honor, we'd move to admit

Exhibit 63b?

THE COURT: Any objection?

MR. McBRIDE: No objection.

THE COURT: It's admitted.

(Government's Exhibit 63b admitted.)

MR. MANGAN: May we publish?

THE COURT: Yes.

(Government's Exhibit 63b was shown on the screen for Jury.)

BY MR. MANGAN:

Q Agent Hull, in looking at Exhibit 63b, this is the

English side of the card; correct?

A It is. On the opposite side was the exact same

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SPECIAL AGENT BRADLEY HULL -- DIRECT 15

information in Mandarin Chinese characters.

MR. MANGAN: If we could turn to page two?

(Government's Exhibit 63b page two was shown on the screen

for Jury.)

BY MR. MANGAN:

Q Is that the other side of the card?

A It is.

Q Thank you.

MR. MANGAN: Can we turn back to page one?

(Government's Exhibit 63b page one was shown on the screen

for Jury.)

BY MR. MANGAN:

Q You mentioned the name that is on the business card.

Is there also a mobile phone number?

A There is.

Q And does that end in the numbers 2316?

A Yes.

Q And there's also a website and other E-Mail address

noted as well; do you see that?

A I do.

Q And what is the website?

A HTTP colon back slash back slash www dot stachina dot

org.

Q And in the nature of your investigation, did you come

across the organization that is listed at the top?

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SPECIAL AGENT BRADLEY HULL -- DIRECT 16

A Yes.

Q And is that sometimes referred to by initials?

A Yes.

Q Explain?

A For simplicity sake we called it JAST, the Jiangsu

Association for Science and Technology, but it was also

referred to as J-P-A-I-S-T-D, which is on the business card.

It says the Jiangsu Provincial Association For International

Science and Technology Development.

Q All right.

THE COURT: You need to pause. And you need to

continue to work to go slowly. You may proceed.

BY MR. MANGAN:

Q At the same time you were investigating the GE

employee, did you investigate who had invited him to China?

A Yes.

Q Why did you do that?

A There were hallmarks of the invitation that seemed

suspicious to us at the time.

Q Okay. And did the -- after you interviewed the GE

employee, did he retain an attorney?

A Yes, he did.

Q And did he begin to cooperate in your investigation?

A Yes, he did.

Q And during this period of cooperation, did the GE

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SPECIAL AGENT BRADLEY HULL -- DIRECT 17

employee begin to communicate with the individuals who

invited him?

A Yes.

Q Did that include a person by the name of Qu Hui?

A It did.

Q And is that same name we just saw on the business

card?

A It is.

Q Through those communications, between the GE employee

and this Qu Hui, was a meeting arranged?

A Yes.

Q Where was the meeting to occur?

A It was to occur in Brussels, Belgium.

Q And when was the meeting set up for?

A April 1st of 2018.

Q Were you there for that meeting?

A Yes.

Q And who arrived at the meeting location to meet the GE

employee?

A The Defendant, and a second individual identified as

Xu Heng.

Q What was the date of that arrest?

A April 1st of 2018. It was Easter Sunday.

Q Now, was he arrested in Belgium at the request of the

United States?

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SPECIAL AGENT BRADLEY HULL -- DIRECT 18

A Yes.

Q And did the arrest occur at the meeting place arranged

through the GE employee?

A Yes.

Q All right. After the arrest, did you accompany the

Defendant when he was brought to the United States?

A Yes. In October of 2018.

Q Okay. And did he have -- or excuse me.

Did you have custody of his Chinese passport at that

time?

A I did.

Q All right. And that was seized at the time of the

arrest?

A Yes.

Q I believe you were here yesterday when a witness was

looking at the original passport; do you recall that?

A I do.

Q All right.

(Government's Exhibit 2c marked.)

MR. MANGAN: I'd like to show the witness

Exhibit 2c?

THE COURT: Yes.

(Government's Exhibit 2c was shown on the screen for the

Court and Witness.)

BY MR. MANGAN:

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SPECIAL AGENT BRADLEY HULL -- DIRECT 19

Q Do you recognize what that is?

A It is not on my screen yet. There we go. Yes.

Q And what is this?

A It is the passport belonging to the Defendant, Xu

Yanjun.

Q Are these photos of the passport?

A Yes.

MR. MANGAN: Your Honor, we'd ask to admit

Exhibit 2c?

THE COURT: Any objection?

MR. McBRIDE: No objection.

THE COURT: It's admitted.

(Government's Exhibit 2c admitted.)

MR. MANGAN: If we could publish it and zoom in to

the bottom?

(Government's Exhibit 2c was shown on the screen for Jury.)

BY MR. MANGAN:

Q Agent Hull, does this state the name of the Defendant?

A Yes.

Q Does it indicate a province for his home?

A Yes. Jiangsu.

Q And it has a date of birth as well; correct?

A Yes.

Q And the year of his birth was 1980?

A Correct.

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SPECIAL AGENT BRADLEY HULL -- DIRECT 20

MR. MANGAN: Now, if we could turn to page two?

(Government's Exhibit 2c page two was shown on the screen

for Jury.)

BY MR. MANGAN:

Q Inside the passport was there also this Schengen Visa?

A Yes.

Q Can you explain what a Schengen Visa is?

A So within the European Union, there's a Schengen Visa

zone. So if you were able to achieve a Visa from one nation

within that treaty, the Schengen treaty, you can travel to

any nation within the Schengen zone without having to have

another passport control.

So if you enter through France, you can go to Germany

without showing your passport to anybody else. You have

free access to travel throughout the Schengen zone.

Q Do you see the date range for this Schengen Visa?

A I do.

Q And what is it?

A It is June 15 of 2017 to September 15 of 2017.

Q And are you aware of a trip the Defendant took to

France in June of 2017?

A Yes.

Q All right. We'll come back to that.

MR. MANGAN: If we can turn down to page three?

(Government's Exhibit 2c page three was shown on the screen

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SPECIAL AGENT BRADLEY HULL -- DIRECT 21

for Jury.)

BY MR. MANGAN:

Q Is this another Schengen Visa?

A It is.

Q And what is the date for this Schengen Visa?

A March the 13 of 2018.

Q And is this shortly before the meeting time where he

was arrested?

A Yes.

Q All right.

MR. MANGAN: And then lastly if we can turn to page

five?

(Government's Exhibit 2c page five was shown on the screen

for Jury.)

BY MR. MANGAN:

Q I believe the witness yesterday was talking about an

additional form that was added to the passport. Is this the

form?

A Yes.

Q Can you explain what this is?

A So when the Defendant was extradited to the United

States, he did not have a Visa to enter the country, so the

Department of Homeland Security issued him a special Parole

to enter the country, and this is that documentation inside

the passport.

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SPECIAL AGENT BRADLEY HULL -- DIRECT 22

Q Thank you. Did you also take possession of the credit

card and National ID that was seized?

A Yes.

MR. MANGAN: Could we publish Exhibit 4c? I

believe it's already admitted.

THE COURT: Yes.

(Government's Exhibit 4c was shown on the screen for Jury.)

BY MR. MANGAN:

Q Is this the photo of the translated credit card and

National ID?

A Yes.

Q Does it indicate the same date of birth for the

Defendant?

A It does.

Q And it also includes a citizenship number; do you see

that?

A I do.

Q All right. And then there's an address for his home;

do you see that?

A I do.

Q And is this information that you found in other pieces

of evidence as well?

A Yes.

MR. McBRIDE: Your Honor, objection. Leading.

THE COURT: Overruled. Don't lead the witness.

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SPECIAL AGENT BRADLEY HULL -- DIRECT 23

MR. MANGAN: All right. We can take that down.

BY MR. MANGAN:

Q You mentioned that someone else was arrested in

Belgium?

A I did.

Q Who was that?

A His name was Xu Heng.

Q Did he also have a Schengen Visa?

A Yes.

Q And what country issued these Schengen Visa to Xu

Yanjun?

A The Republic of France.

Q As part of your investigation, did you obtain records

from the country of France related to those Visas?

A Yes.

(Government's Exhibits 11a through 11h marked.)

MR. MANGAN: Your Honor, we'd move to admit

Exhibits 11a through h pursuant to a stipulation?

THE COURT: Any objection?

MR. McBRIDE: No, Your Honor.

THE COURT: They're admitted.

(Government's Exhibits 11a through 11h admitted.)

BY MR. MANGAN:

Q If you could turn to that binder, Agent Hull?

A (Witness complies.)

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SPECIAL AGENT BRADLEY HULL -- DIRECT 24

Q We will only look at a couple of these, but if you

could generally just explain the information that was

produced by France that is in Exhibits 11a through h?

THE COURT: Are we publishing this?

MR. MANGAN: I'm going to pull up a certain one

later, sir.

THE COURT: Very well.

THE WITNESS: So Exhibit 11a is the original

response from the French Government in French related to the

request for the information about the Visas for both Xu

Yanjun and Xu Heng.

11b is an English translation of the same document.

And then 11c, d, e, and f are portions of the

rather large (Indicating) amount of material provided by the

French Government.

BY MR. MANGAN:

Q All right. Thank you.

MR. MANGAN: I'd like to publish Exhibit 11d?

THE COURT: Yes.

MR. MANGAN: If we could go to page four at the

bottom, please?

(Government's Exhibit 11d page four was shown on the screen

for Jury.)

BY MR. MANGAN:

Q Agent Hull, was this part of the documents provided by

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SPECIAL AGENT BRADLEY HULL -- DIRECT 25

the French Government?

A Yes.

Q And for this particular item, can you explain the

title of the document?

A Is a Registration Card of Permanent Residents.

Q And what is the name for the person?

A Xu Yanjun.

Q Does it have the same birthday we've already seen?

A Yes.

Q It has a citizen ID card number. Does that match the

card?

A It does.

Q Okay. And if you look down further, do you see an

item where it says Employer?

A I do.

Q What is listed as the employer for Xu Yanjun?

A Nanjing Luote Technology and Information Center.

Q And was this part of the information submitted to the

French Government for the Visa?

A Yes.

MR. MANGAN: Now, if we could turn to the next page

and look at the bottom?

(Government's Exhibit 11d page five was shown on the screen

for Jury.)

BY MR. MANGAN:

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SPECIAL AGENT BRADLEY HULL -- DIRECT 26

Q Okay. Is there a similar form with information for

his wife?

A Yes.

Q If we look at the top right where it says Relation to

Householder, do you see that?

A It says wife.

Q Okay. And what is the name?

A Zhong Lin.

Q All right. Thank you.

MR. MANGAN: I'd ask if we could publish

Exhibit 11f?

THE COURT: Yes.

(Government's Exhibit 11f was shown on the screen for Jury.)

MR. MANGAN: We can start with page one.

THE COURT: Mr. Mangan, for planning purposes,

we're going to break in about 10 minutes.

MR. MANGAN: Yes, sir.

BY MR. MANGAN:

Q Can you explain what this is, Agent Hull?

A This is an excerpt of information provided by the

French Government pursuant to the request for a Schengen

Visa for an individual identified as Xu Heng.

MR. MANGAN: And if we could turn to page two,

please?

(Government's Exhibit 11f page two was shown on the screen

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SPECIAL AGENT BRADLEY HULL -- DIRECT 27

for Jury.)

BY MR. MANGAN:

Q Can you explain what this item is?

A This is a copy of the passport of Xu Heng.

Q All right.

MR. MANGAN: And then lastly if we could turn to

page three?

(Government's Exhibit 11f page three was shown on the screen

for Jury.)

MR. MANGAN: If we can go down to the bottom part

and zoom in?

BY MR. MANGAN:

Q What's the name of this document?

A The Registration Card of Permanent Residents.

Q And what's the name of the person on the application?

A Xu Heng.

Q And what did Xu Heng list as his employer?

A Said he was unemployed.

Q All right.

MR. MANGAN: We can take that down.

BY MR. MANGAN:

Q Agent Hull, can you explain the types of evidence you

gathered in the course of your investigation?

A We collected E-Mails, iCloud phone backups, as well as

physical devices, to include computers, cellular telephones,

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SPECIAL AGENT BRADLEY HULL -- DIRECT 28

and a variety of other media.

Q Did you look for E-Mails that communicated with the GE

employee?

A Yes.

Q Did you identify any Google E-Mails?

A Several.

Q Okay. Are you familiar with an account called

J-A-S-T-X-Y-J?

A Yes.

Q All right. And how is that Gmail account tied to your

investigation of the GE employee?

A It E-Mailed the GE employee.

Q All right. Did you also identify an E-Mail account

called jastquhui?

A Yes.

Q All right. I believe as we saw from the Agent Vokas,

did the F.B.I. obtain a subscriber information from those

accounts?

A We did.

Q All right. Did you also identify a Yahoo E-Mail

account?

A Yes.

(Government's Exhibit 17 marked.)

MR. MANGAN: Could we show the witness Exhibit 17?

THE COURT: Yes.

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SPECIAL AGENT BRADLEY HULL -- DIRECT 29

(Government's Exhibit 17 was shown on the screen for the

Court and Witness.)

BY MR. MANGAN:

Q Do you recognize what this is?

A I do.

Q What is it?

A It's a response from Oath, which is a company that

manages the Yahoo E-Mail accounts, with information related

to the account in question, which is quhui11@yahoo.com.

MR. MANGAN: Your Honor, we'd move to admit

Exhibit 17?

THE COURT: Any objection?

MR. McBRIDE: No.

THE COURT: It's admitted.

(Government's Exhibit 17 admitted.)

MR. MANGAN: May we publish?

THE COURT: Yes.

(Government's Exhibit 17 was shown on the screen for Jury.)

BY MR. MANGAN:

Q Agent Hull, can you once, again, read what the E-Mail

account name is?

A It's quhui11@yahoo.com.

MR. MANGAN: And if we could turn to page three of

these records?

(Government's Exhibit 17 page three was shown on the screen

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SPECIAL AGENT BRADLEY HULL -- DIRECT 30

for Jury.)

BY MR. MANGAN:

Q If we look down toward the bottom, do you see an item

called Alternate E-Mail address?

A I do.

Q Can you read the alternate E-Mail address?

A xuyanjun1980@sohu.com.

Q All right. Thank you. Was this another connection

for you between the name Xu Yanjun and Qu Hui?

A Yes.

Q We'd like to show -- excuse me.

MR. MANGAN: Show the witness Exhibit 18, please?

THE COURT: Very well.

(Government's Exhibit 18 marked.)

(Government's Exhibit 18 was shown on the screen for the

Court and Witness.)

BY MR. MANGAN:

Q Can you explain what this is, Agent Hull?

A These are the compilations of the subscriber

information provided by the E-Mail service providers to the

F.B.I. for three accounts: The jastxyj@gmail.com account,

the jastquhui@gmail.com account, and the quhui11@yahoo.com

account.

MR. MANGAN: Your Honor, we'd move to admit Exhibit

18?

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SPECIAL AGENT BRADLEY HULL -- DIRECT 31

THE COURT: Any objection?

MR. McBRIDE: I object, Your Honor. Lack of

foundation with the admission of this document.

BY MR. MANGAN:

Q Can you explain, Agent Hull, where the information for

this came from?

A They were provided from the E-Mail companies to the

F.B.I. pursuant to a legal request.

Q And was that subscriber information then compiled into

this summary?

A Yes.

Q All right. And did you review this document?

A I have.

Q And compare it with the original subscriber

information?

A Yes.

MR. MANGAN: Your Honor, we'd move to admit

Exhibit 18?

THE COURT: Any objection?

MR. McBRIDE: No objection.

THE COURT: Admitted.

(Government's Exhibit 18 admitted.)

MR. MANGAN: May we publish?

THE COURT: Yes.

(Government's Exhibit 18 was shown on the screen for Jury.)

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SPECIAL AGENT BRADLEY HULL -- DIRECT 32

BY MR. MANGAN:

Q Agent Hull, as we look at the subscriber information,

can you explain the similarities that you saw before --

between the first -- well, between these three accounts?

A First, the jastxyj@gmail.com account and the

jastquhui@gmail.com account have the same recovery address,

which is 3025544@qq.com. Also they have the same SMS number

associated with the accounts, which is 861-391-388-2316.

And the final account used the Defendant's name and

date of birth, which is xuyanjun1980@sohu.com as its

recovery E-Mail address.

Q For the first two accounts, how close in time were

they created?

A About five minutes.

Q All right. And did they have the same IP address for

setting them up?

A Yes.

Q We saw a business card earlier. Were there

similarities between the business card you found and the

subscriber information?

A Yes. It's the exact same phone number.

Q All right. And what was the name on the card?

A I apologize. Repeat the question?

Q Sure. What was the name on the business card?

A Qu Hui.

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SPECIAL AGENT BRADLEY HULL -- DIRECT 33

Q All right. Thank you.

MR. MANGAN: We can take that down.

BY MR. MANGAN:

Q Now, pursuant to an F.B.I. warrant, did you obtain

records relating to an iCloud account with the name

jastquhui?

A Yes.

Q All right. Can you describe what was produced from

that iCloud account?

A It was a large amount of data. It included a, a

backup of a telephone as described yesterday. It included

images in a separate folder.

Within the phone itself, it had an iCalendar. It had

a contact list, which had roughly 2,000 contacts in it. It

had E-Mails, text messages, WeChat messages. Basically

everything else that would be on anybody's phone.

Q You mentioned a phone backup, what type of phone was

backed up?

A It was an iPhone 5s.

Q And were you able to confirm a match between that

phone and one of the phones recovered in Belgium?

A Yes.

Q How so?

A The IMEI and the phone number associated with the

accounts were the same.

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SPECIAL AGENT BRADLEY HULL -- DIRECT 34

Q All right. And in reviewing the content of the Cloud

account, did you find evidence showing that the account was

used by Xu Yanjun?

A Yes.

MR. McBRIDE: Objection, Your Honor.

THE COURT: I'm going to break at this moment. It

is now 10:20. I'll address the objection in due course. I

told you we were going to break quickly, and we are. How

long?

MS. FRANKIAN: 20 minutes.

THE COURT: We're going to take a 20-minute break.

We'll suggest looking for you at 20 minutes of 11. During

the break, take the break. Don't discuss the case with

anyone, even among yourselves. No independent research.

Continue to keep an open mind.

Out of respect for you, we'll rise as you leave.

COURTROOM DEPUTY: All rise for the Jury.

(Jury exited the Courtroom.)

THE COURT: Jury's left the room. The door is

closed. We're going to break for 20 minutes.

Did I observe that the Defendant is not using the

interpreter?

(Mr. McBride confers with Defendant Yanjun Xu.)

MR. McBRIDE: Your Honor, he just removed them from

his head. He is using the interpreter.

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SPECIAL AGENT BRADLEY HULL -- DIRECT 35

THE COURT: We'll go into recess.

COURTROOM DEPUTY: This Court is now in recess.

(Court was in recess at 10:20 a.m. and resumed at 10:50

a.m.)

COURTROOM DEPUTY: All rise. This Court's back in

session pursuant to the recess.

THE COURT: Thanks. Please be seated.

Government's team is here in full. The Defendant as well.

The Defendant and both interpreters are.

Are we ready to get the Jury from the Government's

perspective?

MR. MANGAN: We are, Your Honor.

THE COURT: And for the Defense?

MR. KOHNEN: Yes, Your Honor.

THE COURT: All right. I'm going break after

30 minutes. May we call for the Jury, please?

Perhaps we should pause. Is the Defense ready?

MR. MIEDEL: Yes.

THE COURT: We'll call for the Jury, please.

COURTROOM DEPUTY: All rise for the Jury.

(Jury entered the Courtroom.)

THE COURT: You may all be seated. The Jury has

returned. All 15 members. Thank you for your patience and

attention, Jurors.

We had a question and an objection. Have you all

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SPECIAL AGENT BRADLEY HULL -- DIRECT 36

resolve that?

MR. MANGAN: Your Honor, I can back up and take

another run at it.

THE COURT: All right. I sustain the objection.

Take another run at it.

MR. MANGAN: All right.

THE COURT: Special Agent, would you be comfortable

health-wise to take the mask off?

THE WITNESS: I would prefer not to, sir.

THE COURT: What?

THE WITNESS: I would prefer not to, sir.

THE COURT: Very well.

BY MR. MANGAN:

Q All right. Agent Hull, let me ask you a few more

questions here. We were talking about the jastquhui Cloud

account, if you recall?

A I do.

Q And did Apple provide those records to the F.B.I.?

A Yes.

Q And were those records made available to you as the

case agent to review?

A Yes.

Q You mentioned that there was a phone backup in the

Cloud records?

A Correct.

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SPECIAL AGENT BRADLEY HULL -- DIRECT 37

Q And was that processed by the F.B.I. personnel, like

Agent Vokas?

MR. McBRIDE: Objection, Your Honor.

MR. MANGAN: Basis?

THE COURT: Basis?

MR. McBRIDE: Leading.

THE COURT: Basis?

MR. McBRIDE: Leading, Your Honor.

THE COURT: Overruled. Please proceed.

THE WITNESS: Yes.

BY MR. MANGAN:

Q Were you able to review the contents of the phone

backup?

A I was.

Q And were you involved in the process of reviewing the

contents of the Cloud?

A Yes.

Q And where needed, did you have that -- the contents

translated?

A Yes.

Q All right. If you can take a look --

MR. MANGAN: If we can show the witness

Exhibits 21a and b?

THE COURT: Yes.

(Government's Exhibits 21a and 21b marked.)

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SPECIAL AGENT BRADLEY HULL -- DIRECT 38

MR. MANGAN: If we could start with 21a?

(Government's Exhibit 21a shown on the screen for the Court

and Witness.)

BY MR. MANGAN:

Q All right. Agent Hull, do you recognize what this

is?

A Yes. It is a document in Mandarin Chinese with a

photograph of the Defendant in some type of a uniform, and

21b is the same document translated into English.

Q With respect to the original pictures in 21a, where

were those found?

A Within the iPhotos folder from the return from Apple.

MR. MANGAN: Your Honor, we'd move to admit

Exhibits 21a and b?

THE COURT: Any objection?

MR. McBRIDE: No objection, Your Honor.

THE COURT: They're admitted.

(Government's Exhibits 21a and 21b admitted.)

MR. MANGAN: Could we publish Exhibit 21a, page

one?

THE COURT: Yes.

(Government's Exhibit 21a page one was shown on the screen

for Jury.)

BY MR. MANGAN:

Q Agent Hull, can you describe what page one is?

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SPECIAL AGENT BRADLEY HULL -- DIRECT 39

A It is a document in Mandarin Chinese with a photograph

of the Defendant in the upper right-hand corner.

MR. MANGAN: And if we could turn a couple pages.

Let's turn to page two?

(Government's Exhibit 21a page two was shown on the screen

for Jury.)

THE WITNESS: (Witness complies.)

BY MR. MANGAN:

Q Can you explain what this is?

A It's the Properties of the image from the previous

page.

Q All right.

MR. MANGAN: And then if we could turn to page

three?

THE WITNESS: (Witness complies.)

(Government's Exhibit 21a page three was shown on the screen

for Jury.)

BY MR. MANGAN:

Q What is that?

A It's a continuation of the image Properties.

Q All right.

MR. MANGAN: Please turn to page four.

(Government's Exhibit 21a page four was shown on the screen

for Jury.)

THE WITNESS: (Witness complies.)

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SPECIAL AGENT BRADLEY HULL -- DIRECT 40

BY MR. MANGAN:

Q What is this?

A It was an additional page of the same document in

Mandarin Chinese.

Q All right. And was this a separate image?

A Yes.

Q Okay. And does the Exhibit 21a sort of continue on

like this?

A Yes.

Q All right. Let's take a look at the translation.

MR. MANGAN: Can we turn -- can we publish

Exhibit 21b?

THE COURT: Yes.

(Government's Exhibit 21b was shown on the screen for Jury.)

BY MR. MANGAN:

Q Do you have page one up?

A I do.

Q All right. Agent Hull, can you read the title of the

document?

A Cadre Approval/Removal Appointment Application Form.

Q And what is a Cadre?

A Indicates you're a member of the Chinese Communist

Party.

Q All right. For this form, what is the name

indicated?

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SPECIAL AGENT BRADLEY HULL -- DIRECT 41

A Xu Yanjun, the Defendant.

Q All right. And moving across the top, is there a date

of birth?

A There's a month and a year, September of 1980.

Q Is that consistent with the documentation we discussed

earlier?

A Yes, it is.

Q And does it indicate a Province of Ancestry?

A Yes, Jiangsu.

Q Now, under Date of Joining the Party, what does it

say?

A March of 2001.

Q Under Date of Started Working, what does it say?

A August of 2001.

Q Let's go down to the Education. Do you see where it

says College?

A Yes.

Q And what does it say below that?

A Bachelor Degree in Engineering.

Q If we could go to the right. Do you see where it says

Graduation School and Major?

A Yes.

Q Will you please read what it states?

A Institute of Electrical Engineering of Hohai

University, Electrical Engineering and its Automation.

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SPECIAL AGENT BRADLEY HULL -- DIRECT 42

Q And if we could move down to where it says Current

Post. Do you see that?

A I do.

Q Can please read the Current Post?

A It says, Deputy Division Director at Sixth Bureau of

Jiangsu Province Ministry of State Security.

Q Thank you.

MR. MANGAN: If we could now move down to the next

page?

(Government's Exhibit 21b page two was shown on the screen

for Jury.)

THE WITNESS: (Witness complies.)

BY MR. MANGAN:

Q Thank you. Do you see how this has a list of dates to

the left, Agent Hull?

A I do.

Q And then a description on the right hand side?

A Yes.

Q All right. If we could start at the item where it's

in 2003, June of 2003; do you see that?

A I do.

Q All right. Starting there, can you read the date and

description?

A June 2003 to September 2003, Cadre at Fourth Bureau of

Jiangsu Ministry of State Security.

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SPECIAL AGENT BRADLEY HULL -- DIRECT 43

September 2003 to August 2006, Staff Member at Fourth

Bureau of Jiangsu Ministry of State Security.

August 2006 to August 2009, Senior Staff Member at

Fourth Bureau of Jiangsu Ministry of State Security.

August 2009 to August 2010, Deputy Section Chief at

Second Section at Fourth Bureau of Jiangsu Ministry of State

Security.

August 2010 to November 2014, Section Chief at Second

Section of Fourth Bureau of Jiangsu Ministry of State

Security -- in parentheses -- the agency renamed to Sixth

Bureau in December, 2013.

November 2014 to May 2015, Section Chief at Second

Section of Sixth Bureau of Jiangsu Ministry of State

Security.

And, finally, May 2015 to present, Deputy Division

Director at Sixth Bureau of Jiangsu Province Ministry of

State Security.

Q All right. Thank you.

MR. MANGAN: I'd like to turn to page three of the

document?

THE WITNESS: (Witness complies.)

(Government's Exhibit 21b page three was shown on the screen

for Jury.)

BY MR. MANGAN:

Q Again, we are in Exhibit 21b; correct?

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SPECIAL AGENT BRADLEY HULL -- DIRECT 44

A Yes.

MR. MANGAN: If we could forward to the top --

excuse me. Zoom in a little bit to the top.

BY MR. MANGAN:

Q Do you see where it says, Rewards and Punishment?

A I do.

Q It says, Commendation in 2009 and 2014. Third-Class

Merits in 2010. Second-Class Merits in 2013. Do you see

that?

A I do.

Q Did I read that correctly?

A Yes, you did.

Q If you could read the next line where it states,

Annual Evaluation Results?

A Evaluation for 2013 is Competent. Evaluation for 2014

is Outstanding.

Q And if we could move down a little bit on that page

where it indicates Family Members, does it indicate the name

of his wife?

A Yes, Zhong Lin.

Q All right. And does that match the name that you saw

on the French Visa documents?

A Yes.

Q Thank you. Agent Hull, you've worked in

counterintelligence since 2010, have you ever seen a Cadre

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SPECIAL AGENT BRADLEY HULL -- DIRECT 45

form like this before?

A No. No one has.

Q Now, are you aware of any other forms like this that

are publicly known?

A No.

Q As you conducted your investigation, what was the

significance of this particular document?

A It identified the Defendant, Xu Yanjun, as

intelligence officer, the People's Republic of China,

Ministry of State Security.

Q All right. And was it significant to your

investigation that this person was communicating with the GE

employee?

A Yes.

(Government's Exhibit 22 marked.)

BY MR. MANGAN:

Q All right. I'd ask you to turn and take a look at

Exhibit 22, if you could?

A (Witness reviews exhibit.)

(Government's Exhibit 22 shown on the screen for the Court

and Witness.)

MR. MANGAN: We can take that down.

BY MR. MANGAN:

Q As background, Agent Hull, we heard Agent Vokas talk

about UFED Reports; do you recall that?

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SPECIAL AGENT BRADLEY HULL -- DIRECT 46

A I do.

Q With respect to the 5s backup in the Cloud account,

was that processed like a phone?

A It was.

Q And were you able to view a UFED Report for that

backup phone?

A Yes.

Q And could you pull reports from that backup?

A Yes.

Q All right. Can you describe what Exhibit 22 is?

A Exhibit 22 is a UFED Extraction Report for the Apple

iPhone, and it contains a number of images that were

collected from that iPhone backup.

Q Okay. And does it show where the photos were found in

that particular backup?

A Yes. It includes both the path and the MD5 for each

individual file name.

Q All right.

(Government's Exhibits 23 through 28 marked.)

MR. MANGAN: And then if you could take a look at

Exhibits 23 through 28?

THE WITNESS: (Witness reviews exhibits.)

(Government's Exhibits 23 through 28 shown on the screen for

the Court and Witness.)

BY MR. MANGAN:

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SPECIAL AGENT BRADLEY HULL -- DIRECT 47

Q And describe what those are?

A Exhibit 23 is a photograph of the Xu Yanjun National

ID Card, and Exhibit 24, 25, 26, 27, and 28, are photographs

of documents in Mandarin Chinese.

Q And do those documents -- or excuse me -- those

photos in Exhibits 23 through 28, are they found in the UFED

Report in Exhibit 22?

A Yes.

MR. MANGAN: All right. Your Honor, at this time

we'd move to admit Exhibit 22 through 28?

THE COURT: Any objection?

MR. McBRIDE: We object, Your Honor.

THE COURT: Basis?

MR. McBRIDE: This gentleman did not do the

extraction, and so there's no connection between the

extraction and the UFED Report.

THE COURT: Overruled. You may proceed.

(Government's Exhibits 23 through 28 admitted.)

MR. MANGAN: Are Exhibits 22 through 28 admitted?

THE COURT: Yes.

MR. MANGAN: Your Honor, if we could, could we

publish Exhibit 23?

THE COURT: Yes.

(Government's Exhibit 23 was shown on the screen for Jury.)

BY MR. MANGAN:

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SPECIAL AGENT BRADLEY HULL -- DIRECT 48

Q Agent Hull, was this one of the photos found on the 5s

backup?

A Yes, it is.

Q Explain what this is?

A It's an image of the reverse side of the Defendant Xu

Yanjun's National ID Card.

Q And I believe you said you brought the actual card

back with you from Belgium?

A I did.

Q Does this match the physical card?

A It does.

Q All right. And is there a page two?

A Yes.

MR. MANGAN: If we could turn to that?

(Government's Exhibit 23 page two was shown on the screen

for Jury.)

BY MR. MANGAN:

Q Is that the reverse of the card?

A It is with the Defendant's photograph.

Q All right. And, again, just to clarify, where was

this found?

A It was an image inside the Apple iCloud backup.

Q For which phone?

A The 5s.

Q All right. Thank you.

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SPECIAL AGENT BRADLEY HULL -- DIRECT 49

MR. MANGAN: If we could publish Exhibit 24,

please?

THE COURT: Yes.

(Government's Exhibit 24 was shown on the screen for Jury.)

BY MR. MANGAN:

Q Can you describe what Exhibit 24 is?

A The first page Exhibit 24 is an image of a document in

Mandarin Chinese. And the second page is an English

translation of the same document.

Q All right.

MR. MANGAN: Could we turn to page two?

(Government's Exhibit 24 page two was shown on the screen

for Jury.)

BY MR. MANGAN:

Q Is this a translation of that image?

A Yes, it is.

Q And, again, where was the image found?

A Within the iCloud backup for the 5s.

Q And do you recognize this document?

A I do.

Q What is it?

A It is a City Resident card.

Q All right. Were there any similarities between this

and any of the documents you found from the French Visa?

A Yes.

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SPECIAL AGENT BRADLEY HULL -- DIRECT 50

Q Can you explain?

A We found the same basic document provided by the

French Government for his Visa.

Q And, again, on here what does it indicate as the Job

Location?

A Nanjing Luote Technology Information Center.

Q And what is the name at the top?

A Xu Yanjun.

Q All right. Does this have the same date of birth for

Mr. Xu Yanjun?

A Yes, it does. September 20 of 1980.

Q And does it have the same National ID Number?

A It does ending in 0015.

Q All right. Thank you.

MR. MANGAN: We can take that down. May we publish

Exhibit 25?

THE COURT: Yes.

(Government's Exhibit 25 was shown on the screen for Jury.)

BY MR. MANGAN:

Q Can you explain what Exhibit 25 is?

A 25 is another image of a document collected from the

iPhone backup as --

MR. MANGAN: If we turn to page two?

THE WITNESS: (Witness complies.)

(Government's Exhibit 25 page two was shown on the screen

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SPECIAL AGENT BRADLEY HULL -- DIRECT 51

for Jury.)

BY MR. MANGAN:

Q Is that another image?

A It is.

MR. MANGAN: Let's turn to page three.

THE WITNESS: (Witness complies.)

(Government's Exhibit 25 page three was shown on the screen

for Jury.)

BY MR. MANGAN:

Q Is this yet another image?

A It is.

MR. MANGAN: And turn one more page?

THE WITNESS: (Witness complies.)

(Government's Exhibit 25 page four was shown on the screen

for Jury.)

THE WITNESS: It's another image of the same, same

type.

MR. MANGAN: Can we turn to page five, please?

(Government's Exhibit 25 page five was shown on the screen

for Jury.)

THE WITNESS: It is another image of documents in

Mandarin Chinese.

BY MR. MANGAN:

Q And were -- where were all these pictures found?

A In the iPhone iCloud backup.

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SPECIAL AGENT BRADLEY HULL -- DIRECT 52

MR. MANGAN: If we could turn to the translation, I

believe on the next page?

(Government's Exhibit 25 page six was shown on the screen

for Jury.)

BY MR. MANGAN:

Q Agent Hull, can you describe what you found in the

translation?

A They're his pay stubs.

Q All right. And in looking at these pay stubs, for

example, we'll look at the one from the top. What is the

name listed at the top left?

A Xu Yanjun.

Q Under Department?

A Sixth Division.

Q What is the Pay Period?

A July 2015.

Q Let's go through a couple more columns. Is there a

Base Position Pay?

A Yes, there is.

Q And is there a Rank Pay?

A Yes.

Q And what is the next column over?

A Law Enforcement Title Pay.

Q And what was the significance of the Law Enforcement

Title Pay to you?

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SPECIAL AGENT BRADLEY HULL -- DIRECT 53

A It indicated -- further indicated type of

employment.

Q All right. And you can flip through all the pages.

Generally what is the date range for these pay stubs that

you recovered?

A The first is July of 2015. The second is February of

2016. The next is October of 2016.

Q Next page?

A Is July of 2016. The next is September of 2016. On

the final page, February of 2017.

Q All right. Thank you. And did each of these pay

stubs indicate a section for Law Enforcement Title Pay?

A It did.

Q All right. Thank you.

MR. MANGAN: Your Honor, if we can publish

Exhibit 26?

THE COURT: Very well.

(Government's Exhibit 26 was shown on the screen for Jury.)

BY MR. MANGAN:

Q All right. Agent Hull, can you describe what this

document is?

A It is an image of a document with a seal in Mandarin

Chinese. And the second page is the English translation of

the same document.

Q And where was this found?

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SPECIAL AGENT BRADLEY HULL -- DIRECT 54

A It was found in the photograph section of the iCloud

return from Apple for the 5s.

Q All right.

MR. MANGAN: Let's turn to the translation, please?

(Government's Exhibit 26 page two was shown on the screen

for Jury.)

BY MR. MANGAN:

Q Agent Hull, can you read the title at the top of the

document?

A Provincial Institute Provident Fund Withdrawal

Application.

Q And what is the date below that?

A March 10, 2017.

Q Does the bank withdrawal form indicate an Employer

Name?

A Yes.

Q What is that?

A Jiangsu State Security Department.

Q And then to the right, what is the Employee Name?

A Xu Yanjun, the Defendant.

Q We can go down two rows. Do you see where it says

Identity Card Number?

A I do.

Q Does that number match the National Identity Card that

we've talked about?

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SPECIAL AGENT BRADLEY HULL -- DIRECT 55

A Yes.

Q And then it indicates the amount withdrawn; correct?

A It does.

Q All right. Thank you.

MR. MANGAN: If we could take that down. May we

publish Exhibit 27?

THE COURT: Before we do -- I'm inclined to take a

break at this time. So, ladies and gentlemen of the Jury,

we're going to break for 15 minutes at my request.

During the break do not discuss the case with

anyone or among yourselves. No independent research.

Continue to keep an open mind.

Out of respect for you, we'll rise as you leave for

15 minutes.

COURTROOM DEPUTY: All rise for the Jury.

(Jury exited the Courtroom.)

THE COURT: All right. Jury's left. We're in

recess for 15 minutes. Don't discuss your testimony, Mr.

Witness, please, during the break.

COURTROOM DEPUTY: This Court's in recess for

15 minutes.

(Court was in recess at 11:14 a.m. and resumed at 11:32

a.m.)

COURTROOM DEPUTY: All rise. This Court is back in

session pursuant to the recess.

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SPECIAL AGENT BRADLEY HULL -- DIRECT 56

THE COURT: Thank you. Please be seated.

Government's team here. Defense's teams here. Defendant's

here. The Jury is not yet in the room.

Is there something that needs my attention outside

the presence of the Jury?

MR. McBRIDE: Your Honor, I'd like to raise an

issue, if I may --

THE COURT: Yes.

MR. McBRIDE: -- and further explain? I objected

to Government's Exhibit Number 22 and the following

photographs that went through it.

Agent Hull testified, as I recall, that he went

into an Extraction Report to view those documents. The

Extraction Report was not authenticated yesterday by Mr.

Vokas, but Government's Exhibit 22 shows that the examiner

was a man named Soundappan, and I believe he was located in

African.

The Government can't authenticate these documents,

and I move to strike 22 and the following -- and the

relevant documents 23, 24, 25, 26, 27, and 28 -- although I

don't know that they've been admitted yet -- because the

Government did not lay the foundation for those documents

because they did not identify for validate -- pardon me --

lay a foundation for the Extraction Report this agent

reviewed.

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SPECIAL AGENT BRADLEY HULL -- DIRECT 57

THE COURT: Does the Government wish to be heard on

the objection?

MR. MANGAN: Yes, Your Honor. Agent Vokas

explained yesterday that the Cloud information that was

produced provided a backup for the iCloud -- excuse me --

provided a backup for the 5s phone, and that he processed

that phone in the same way that he would any other phone,

and it turns it then into a UFED Report, which is available

for the agents to then review and read.

This is a report that when the agents go to that

UFED Report for the 5s backup, this is where they can pull

off these UFED, you know, various pieces of data from that

5s backup. So this agent has explained that it came from

the same 5s backup. Agent Vokas explained how he --

THE COURT: I'm going to ask you to stop for just a

moment. Are we having troubles?

MR. MIEDEL: They've been resolved, Your Honor.

THE COURT: I'm sorry to have interrupted. Go

ahead, Mr. Mangan, and don't forget to go slowly.

MR. MANGAN: I'm sorry.

THE COURT: Defense counsel's standing. Are we

okay? Are we hearing the Government?

MR. McBRIDE: I'm sorry, Your Honor. I'm fine.

I'm just listening.

THE COURT: Okay. Go ahead, Mr. Mangan.

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SPECIAL AGENT BRADLEY HULL -- DIRECT 58

MR. MANGAN: Your Honor, what I was stating was

Agent Vokas explained the way Apple produces the iCloud

return, it produces a backup file. He took that file, which

had phone data in it. He then processed it through

Cellebrite, and that creates a UFED Report.

The UFED Report was then provided to the agents.

This agent testified that he was able to view that data, and

that this is what they pulled. We believe that's more than

enough foundation for it.

THE COURT: I agree. Objection's overruled.

MR. McBRIDE: Thank you, Your Honor.

THE COURT: May we get --

MR. MANGAN: May we -- sorry?

THE COURT: What?

MR. MANGAN: I don't want to mess up a positive

ruling. I just -- I just noted another point that I failed

to make, but --

THE COURT: Go ahead. Make it.

MR. MANGAN: When the Defense mentioned a notation

to Africa, that was a notation to the time zone connected to

the Universal Time Zone, so --

THE COURT: Very well.

MR. MANGAN: Thank you, Your Honor.

THE COURT: Can we get the Jury?

MR. MANGAN: From our perspective, yes.

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SPECIAL AGENT BRADLEY HULL -- DIRECT 59

THE COURT: Defense?

MR. McBRIDE: Yes, Your Honor.

THE COURT: All right. Let's get the Jury. We're

going to break about noon.

COURTROOM DEPUTY: All rise for the Jury.

(Jury entered the Courtroom.)

THE COURT: You may all be seated. 15 members of

the Jury have rejoined us. Good morning, again. We'll

continue to hear testimony. Mr. Mangan, you may proceed.

MR. MANGAN: Thank you, Your Honor.

BY MR. MANGAN:

Q Agent Hull, we were walking through a number of

pictures, if you recall. Can you just remind the Jury where

those pictures were recovered?

A In the iCloud backup provided by Apple. The iPhone

5s.

Q And was that 5s connected to the physical 5s that was

recovered in Belgium?

A Yes.

Q Through the IMEI or any other identifier?

A And the phone number.

Q All right.

MR. MANGAN: All right. I'll ask if we could

publish Exhibit 27, which I believe the Court has admitted?

THE COURT: Yes.

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SPECIAL AGENT BRADLEY HULL -- DIRECT 60

(Government's Exhibit 27 was shown on the screen for Jury.)

BY MR. MANGAN:

Q Can you describe what this is, Agent Hull?

A It is a screen capture of a document in Mandarin

Chinese, and --

Q Can we turn -- I'm sorry.

A The next page is the English translation of the same.

MR. MANGAN: Can we turn to page two?

(Government's Exhibit 27 page two was shown on the screen

for Jury.)

BY MR. MANGAN:

Q And for this document, do you see where it lists the

name Husband about halfway down?

A I do.

Q And what is the name next to that?

A Xu Yanjun.

Q Does it list a Political Status?

A Yes.

Q What is that?

A CCP member.

Q And then to the right where it says Employer and

Position Title, what is listed for Xu Yanjun?

A Jiangsu State Security Department.

Q And then at the bottom, where it says, Person filling

out the form, who is that?

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SPECIAL AGENT BRADLEY HULL -- DIRECT 61

A Zhong Lin.

Q Thank you.

MR. MANGAN: You can take that exhibit down. If we

could, please, publish Exhibit 28, please?

THE COURT: Yes.

(Government's Exhibit 28 was shown on the screen for Jury.)

BY MR. MANGAN:

Q What is this, Agent Hull?

A It is an image of a certificate and document with an

official seal in Mandarin Chinese, and page two is the

English translation of the same.

MR. MANGAN: If we could turn to page two?

(Government's Exhibit 28 page two was shown on the screen

for Jury.)

BY MR. MANGAN:

Q What is the name of the university?

A The Nanjing University of Aeronautics and

Astronautics.

Q And if we look to the left hand column, do you see

where it says Student Name?

A I do.

Q And what is the name?

A Xu Yanjun.

Q And can you read what it says below that?

A You have been admitted to our College of Aerospace

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SPECIAL AGENT BRADLEY HULL -- DIRECT 62

Engineering Aeronautical Engineering -- parentheses,

Professional Degree, end parentheses -- Degree program as a

Full Time Contractual Training graduate student.

Q And then what is the date?

A June of 2016.

Q And if you see to the right where it says, Identity

Card Number, do you recognize that?

A I do.

Q And what is that?

A It's the same number previously identified on the

Defendant's PRC National ID Card.

Q Thank you.

MR. MANGAN: Now, if we could take that down?

BY MR. MANGAN:

Q Let's go back to talking some more about what you

found in the -- this same Cloud account. Was there a

calendar function connected to the account?

A Yes, there was.

Q Explain what was found there?

A It's a calendar on anybody's smartphone. It has

appointments, holidays scheduled, and also in this instance,

it included a lot of entries that were treated a little bit

like a, like a diary almost.

Q And was that Cloud function available for you to

review?

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SPECIAL AGENT BRADLEY HULL -- DIRECT 63

A It was.

Q And where did that come from?

A The Apple data from the backup of the 5s.

Q All right. As you reviewed the calendar function, did

you have that translated?

A Yes.

Q Okay. And were you able to pull a UFED Report of that

calendar function?

A Yes.

(Government's Exhibit 29a marked.)

MR. MANGAN: If he could have the witness take a

look at Exhibit 29a, please?

THE COURT: Yes.

(Government's Exhibit 29a shown on the screen for the Court

and Witness.)

BY MR. MANGAN:

Q Can you identify what this is, Agent Hull?

A Yes, it's a UFED Extraction Report of the calendar

from the 5s and the Apple data with 1146 calendar entries.

Q And are these entries in the Chinese language?

A Yes.

Q All right.

MR. MANGAN: Your Honor, we'd move to admit

Exhibit 29a?

MR. McBRIDE: No objection, Your Honor.

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SPECIAL AGENT BRADLEY HULL -- DIRECT 64

THE COURT: It's admitted.

(Government's Exhibit 29a admitted.)

MR. MANGAN: And we're not going to publish this.

BY MR. MANGAN:

Q How many entries were in the calendar?

A 1,146.

Q And so how many pages are in this report?

A 105.

Q All right. Did you have the -- this UFED Report

translated?

A Yes, we did.

(Government's Exhibit 29b marked.)

(Government's Exhibit 29b shown on the screen for the Court

and Witness.)

BY MR. MANGAN:

Q Can you take a look at Exhibit 29b?

A (Witness reviews exhibit.)

Q Do you recognize what that is?

A I do.

Q What is that?

A It's the English translation of the iCalendar report.

Q And do these translations also correspond to the same

1,146 entries in the calendar?

A Yes, they do.

Q All right. And so this is -- is this a complete

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SPECIAL AGENT BRADLEY HULL -- DIRECT 65

translation of that calendar?

A It is.

Q All right.

MR. MANGAN: Your Honor, we'd move to admit

Exhibit 29b?

MR. McBRIDE: No objection, Your Honor.

THE COURT: It's admitted.

(Government's Exhibit 29b admitted.)

(Government's Exhibit 29c marked.)

(Government's Exhibit 29c shown on the screen for the Court

and Witness.)

BY MR. MANGAN:

Q Now, if you could turn, Agent Hull, to Exhibit 29c.

Can you explain what this is?

A (Witness complies.) 29c is a compilation that we

distilled from the 1,146 calendar entries to selected ones

that we thought were relevant.

MR. MANGAN: All right. Your Honor, we'd ask to

move to admit 29c?

MR. McBRIDE: No objection, Your Honor.

THE COURT: It's admitted.

(Government's Exhibit 29c admitted.)

MR. MANGAN: If we could just, for example, publish

29c page one?

(Government's Exhibit 29c page one was shown on the screen

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SPECIAL AGENT BRADLEY HULL -- DIRECT 66

for Jury.)

BY MR. MANGAN:

Q As we take a look at this, Agent Hull, were each of

the entries numbered?

A Yes, and they're also given a category.

Q Okay. So for here, you mentioned that 29c is, is a

shortened or subset of the full calendar?

A It is.

Q Is that why the -- do you notice on the left the

numbers are not in perfect sequence?

A Correct.

Q All right. And why is that?

A We took out things like birthdays and non-relevant

calendar entries.

Q All right. In the second column where it says

Category, what were the -- some of the categories that you

saw?

A Personal and work, and we -- and family. We primarily

chose work, not exclusively.

Q All right. And then for these calendar entries, would

there typically be some period of content in the area called

Subject?

A Yes.

Q And then to the right what is the final column?

A It's the Date.

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SPECIAL AGENT BRADLEY HULL -- DIRECT 67

Q All right. In general, can you describe what type of

significance this calendar had to your investigation?

A It allowed us to identify other officers from the MSS

as well as meetings with aviation engineers from Chinese

companies and American companies and others.

Q So, for example, you mentioned that there was a trip

by the GE employee to China; correct?

A Yes.

Q What was the date of that employee's presentation?

A June the 2nd of 2017.

MR. MANGAN: If we could take a look at page five

of Exhibit 29c?

(Government's Exhibit 29c page five was shown on the screen

for Jury.)

MR. MANGAN: If we could move down to where it says

entry 196?

BY MR. MANGAN:

Q Do you see that highlighted there, sir?

A I do.

Q Can you read that entry?

A Received Zheng. Ji Xiuzhen, participated.

Q And what's the date?

A June 2 of 2017.

Q And where it says, Received Zheng, is that the same

name that the GE employee has?

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SPECIAL AGENT BRADLEY HULL -- DIRECT 68

A Yes.

MR. MANGAN: If we could take a look at the day

before?

BY MR. MANGAN:

Q Do you see an entry dated June 1st, 2017, numbered

198?

A I do.

Q Can you read what that entry is for the day before the

presentation?

A "Afternoon, met with Ji Xiuzhen and Chai Meng to talk

about the plan."

Q All right. Thank you.

MR. MANGAN: We can take that down.

BY MR. MANGAN:

Q Will we come back to talk about Chai Meng?

A We will.

Q We saw that there was a, an entry related to a

graduate program in aviation. Do you recall that?

A I do.

MR. MANGAN: I'm sorry. If we could -- my

apologies. Could we put 29c back up, please?

Your Honor, publish page ten?

THE COURT: Yes.

(Government's Exhibit 29c page ten was shown on the screen

for Jury.)

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SPECIAL AGENT BRADLEY HULL -- DIRECT 69

BY MR. MANGAN:

Q If we look at the calendar reference under line 350.

A Yes.

Q What was --

A It says, "Evening --

Q I'm sorry. What was the date of that entry?

A December 12, 2016.

Q All right. And can you read what the entry is for

that?

A "Evening, Zhang Jian of NUAA Mechanics of Material

Department tutored."

Q Agent Hull, did you and the other agents find

recordings in that Cloud account?

A Yes, we did.

Q Did you find any recordings that corresponded to that

date?

A Yes.

Q And did you have that recording translated?

A Yes.

Q And did the content correspond with the entry here?

A It did.

MR. MANGAN: If we could have you take a look at

Exhibits 31a and 31b?

(Government's Exhibits 31a and 31b marked.)

MR. MANGAN: I believe 31a would just be the

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SPECIAL AGENT BRADLEY HULL -- DIRECT 70

placeholder for the recording.

Your Honor, we won't be playing the actual

recording.

BY MR. MANGAN:

Q Agent Hull, did you review the recording that was

pulled from the iCloud?

A I did. I -- and I sent it in for translation, which

is what 32 -- or excuse me -- 31b is.

Q All right. Thank you. And is 31a the recording?

A It is.

Q All right.

MR. MANGAN: Your Honor --

BY MR. MANGAN:

Q And then let me ask you again about 31b. Is this the

translation of that recording?

A It is.

Q And, again, was this recording found on the jastquhui

iCloud account?

A Yes.

MR. MANGAN: Your Honor, we'd move to admit 31a and

b?

THE COURT: Any objection?

MR. McBRIDE: No objection, Your Honor.

THE COURT: Admitted.

(Government's Exhibits 31a and 31b admitted.)

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SPECIAL AGENT BRADLEY HULL -- DIRECT 71

BY MR. MANGAN:

Q All right. Agent Hull, if we could --

MR. MANGAN: If we could publish Exhibit 31b and

turn to page four?

(Government's Exhibit 31b page four was shown on the screen

for Jury.)

BY MR. MANGAN:

Q This is about a 20-page transcript; is that correct?

A It is.

Q We won't read all 20 pages, so I promise you that. I

would like to read an excerpt or two.

If we could start at page four at the top where it

says:

"Otherwise the three of us will all."

Do you see that?

A I do.

Q And I understand we need to go slowly. How about if

you read the part that is listed for Xu, and I will read the

part for Mr. Zhang?

A Understood.

Q All right. "Otherwise the three of us will

all....honestly --"

A "Right, right."

Q " -- lose our jobs. Even if you fail the exam, you

still safely keep your job?"

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SPECIAL AGENT BRADLEY HULL -- DIRECT 72

A "Still have to do the job!"

Q "It's not a must do, this is just icing on the cake."

A "Right, right."

Q "But if you do this, then...right?"

A "Right, right, I understand. That's why my travel, so

--"

MR. MANGAN: If we can move down?

BY MR. MANGAN:

Q "Then it will do all three of us in. To be honest in

private, this is simply copyrights violation; right?"

A "Right, of course. I understand. That's why --"

Q "Because this is trying to steal others' secrets.

Oh?"

A "I understand."

Q "That's the fact."

A "That eh..."

MR. MANGAN: If we could zoom in on the bottom?

BY MR. MANGAN:

Q "Maybe it is not your intention..."

A "Teacher Zhang, here is what --"

Q "Eh?"

A "Teacher Zhang, here, Teacher Zhang, let me tell you,

as you know, for a job like mine, we have a lot of

friends out there who, who risk their life to work for

us. I wouldn't let...you rest assured, I definitely

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SPECIAL AGENT BRADLEY HULL -- DIRECT 73

keep my responsibility to you. I keep Dean Shen --"

Q "You definitely have to be responsible for yourself."

A "Right, right."

MR. MANGAN: If we could go to next page?

(Government's Exhibit 31b page five was shown on the screen

for Jury.)

BY MR. MANGAN:

Q "But the remark you made that day really scared me..."

A "I know, I know."

Q "Because you may always do such things, but we don't

usually..?"

A "I understand, I know."

Q All right. Why don't we stop there. And then I'd

like to --

MR. MANGAN: If we could skip to page 12 of that

exhibit?

THE WITNESS: (Witness complies.)

MR. MANGAN: And we'll start at the top of that

page and read a couple pages there.

(Government's Exhibit 31b page 12 was shown on the screen

for Jury.)

THE WITNESS: "Xu: Oh, you are going to Cheng Fei,

to 611."

BY MR. MANGAN:

Q "Mm. Chen Fei. You guys are in frequent contact with

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SPECIAL AGENT BRADLEY HULL -- DIRECT 74

them because the confidentiality and security; right?"

A "That's true, that er...we were invited to the J-20

first flight."

Q Let me stop right there. Agent Hull, do you know what

the J-20 is?

A Yes.

Q What is it?

A It's a fighter aircraft that the People's Liberation

Army Air Force flies.

Q All right. Let's resume with reading the transcript.

"Oh?"

A "We, the reason I have lots of contacts with Nang

Hang -- parentheses -- NAUU -- to be honest with you,

people in the intelligence like us, we focus on

aviation."

Q "Mm."

A "The institute used to have a location in downtown.

They moved."

Q "Mm."

A "They moved outside downtown."

Q "How many days you work every week?"

A "Ah?"

Q "How many days you work every week?"

A "We just work five days a week. But sometimes,

sometimes..."

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SPECIAL AGENT BRADLEY HULL -- DIRECT 75

Q "You would have emergencies, travel, and handle

situations?"

A "Yeah, we do. When things happen, work over time --"

Q "Are there many secret leak incidents?"

A "A lot."

Q A swear word. "So, can you actually do remote

monitoring if someone steals secret? So many

computers, so much networking stuff, you can detect

everything?"

A "Clear throat."

Q "That wouldn't be easy?"

MR. MANGAN: If we could turn to the next page?

(Government's Exhibit 31b page 13 was shown on the screen

for Jury.)

THE WITNESS: Xu: "Nowadays, on the Internet, for

example, they are in indeed -- they are in need of

faculty member. Some Nan Hang -- parentheses,

NUAA, end parentheses -- faculty member posts

something like a picture after work, we basically

need to see it."

BY MR. MANGAN:

Q "You can see all that?"

A "Mm. There are indeed too many leaks."

Q "Mm, look some faculty members at home, their contact

with the U.S. or U.K., send E-Mails, you can see that

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SPECIAL AGENT BRADLEY HULL -- DIRECT 76

too?"

A "Yes."

Q "You can see! The specific content?"

A "Can see all that. Clears throat."

MR. MANGAN: If we could scan down?

(Government's Exhibit 31b page 13 was shown on the screen

for Jury.)

BY MR. MANGAN:

Q "What about the things that are people's privacies,

you don't care about that?"

A "No, we don't care, this aspect --"

Q "As long as it's national secrets."

A "Because there would be too much private stuff to

handle."

Q Then there's a statement from an unidentified female.

"Can see personal stuff?"

A "Can see personal stuff."

Q "So that's brutal."

A "That's why the Central Discipline Inspection

Commission usually comes to us when they have

investigations."

MR. MANGAN: If we could turn to the next page?

(Government's Exhibit 31b page 14 was shown on the screen

for Jury.)

BY MR. MANGAN:

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SPECIAL AGENT BRADLEY HULL -- DIRECT 77

Q "Mm. For sure, since you know the personal stuff."

A "Mm. Long pause. See the Big Data these days --"

Q "Mm."

A "-- just enter the -- parentheses, data of a, end

parentheses -- person into computer, so we can tell

basically all the trails of your activities. If you

use other people's information to get an ID card, that

won't work at all."

Q "Because you know everything?"

A "We know it all because your behavior patterns can't

be changed."

Q "That's right."

A "I just need to keep a tap on three sites of yours:

Job, er...home and the places you frequent for fun,

the three locations, that will allow us to pinpoint a

person."

Q "So what about criminal cases? Do you guys do that

yourselves? Those criminals are handed to you;

right?"

A "We don't work those."

Q "Those should be lower level; right?"

A "Mm."

Q "Hehehe."

A "That is not our responsibility."

Q "I heard from Department Head Shen, that signature of

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SPECIAL AGENT BRADLEY HULL -- DIRECT 78

Chief of -- unintelligible -- is required when you

guys go somewhere and each time you dine out?"

A "That should be the case."

Q "Should be."

A "Dine out is fine. But job like ours, expenses are

guaranteed. Clear throat."

Q "Your average work are long days. Very long, oh?"

MR. MANGAN: If we could turn to the next page?

(Government's Exhibit 31b page 15 was shown on the screen

for Jury.)

THE WITNESS: "Xu: We are under great pressure,

because the job of ours is not like you can do it

by sitting at home. Mm. The leadership asks you

to get the materials of U.S., the U.S. F-22 fighter

aircraft, you can't get it by sitting at home."

BY MR. MANGAN:

Q "Mm. Clear throat. You also have to flip someone,

travel outside China and take the risk?"

A "That's correct."

Q Let's stop there. Agent Hull, are you familiar with

what the U.S. F-22 is?

A Yes.

Q And explain to the Jury what that is?

A It's a U.S. fighter aircraft.

Q Is it military?

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SPECIAL AGENT BRADLEY HULL -- DIRECT 79

A Exclusively.

(Government's Exhibit 32a marked.)

BY MR. MANGAN:

Q All right. Thank you. Agent Hull, I'd ask you to

turn and take a look at Exhibit 32, please, starting with

32a?

THE COURT: Yes.

MR. MANGAN: Just waiting for him to get to it,

Your Honor.

THE COURT: Likewise.

THE WITNESS: 32a is a UFED Extraction Report

containing 21 SMS text messages from the iCloud account.

MR. MANGAN: All right. And if you could display

it for the witness too? Sorry.

THE COURT: Yes.

(Government's Exhibit 32a shown on the screen for the Court

and Witness.)

BY MR. MANGAN:

Q I'm sorry, Agent Hull. Where did you say the text

messages were found?

A From the iCloud account associated with the Apple

material for the iPhone 5s.

Q And when you're looking at this UFED Report, are you

able to select certain messages that you want a report

generated for?

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SPECIAL AGENT BRADLEY HULL -- DIRECT 80

A Yes.

Q And is this report, does it have the original Chinese

version?

A It does.

Q All right. And --

A And a English translation toward the rear of 32a.

Q So at the end it has the translations?

A It does.

MR. MANGAN: Your Honor, we'd move to admit

Exhibit 32a?

MR. McBRIDE: No objection, Your Honor.

THE COURT: Admitted.

(Government's Exhibit 32a admitted.)

(Government's Exhibits 32b through 32i marked.)

BY MR. MANGAN:

Q And then if you could take a look at Exhibits 32b

through 32i and explain what those are?

A (Witness reviews exhibits.) They are the individual

text messages in English only separated out by sender and

receiver.

Q All right.

THE COURT: I need to pause at a good moment.

MR. MANGAN: This is as good as any, Your Honor.

THE COURT: Very well. Members of the Jury, it

appears to be high noon. We're going to take a lunch break.

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SPECIAL AGENT BRADLEY HULL -- DIRECT 81

We're going to break until 1:30.

During the lunch break, take a break. Don't

discuss the case among yourselves or with anyone else. No

independent research. Continue to keep an open mind.

Out of respect for you, we'll rise as you leave

until 1:30.

COURTROOM DEPUTY: All rise for the Jury.

(Jury exited the Courtroom.)

THE COURT: All right. The Jury's left the room.

The door is closed. I'm prepared to recess until 1:30. Is

there anything that requires my attention from you all

before then?

MR. MANGAN: No, Your Honor.

THE COURT: Defense?

MR. McBRIDE: No, Your Honor.

THE COURT: Very well. Enjoy lunch. We're in

break until 1:30.

COURTROOM DEPUTY: This Court's in recess until

1:30.

(Court was in recess at 12:00 p.m. and resumed at 1:34 p.m.)

COURTROOM DEPUTY: All rise. This Court is in

session pursuant to the recess.

THE COURT: Thank you. Please be seated. We're

back in the open courtroom on the record. The Jury's not

yet joined us.

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SPECIAL AGENT BRADLEY HULL -- DIRECT 82

I'm hoping that we can proceed to a 45 minutes --

to 45 minutes of testimony, and then take a 20-minute break.

Come back. Do some more testimony. Then take a 20-minute

break.

It's my understanding that the authenticity of

E-Mails are still at issue, but we may not reach it for a

while. Is that accurate from the Government's perspective?

MR. MANGAN: I believe that's correct, Your Honor.

I'm not sure exactly when we'll get to it. If it be later

today in the afternoon, and perhaps we could address it at

one of those breaks if you'd like.

THE COURT: Is the Defense comfortable with that?

I mean, I'm ready to go. I just want to try and respect the

time of the Jurors and the translator.

MR. McBRIDE: Agreed, Your Honor. We're fine with

that.

THE COURT: Very well. Are we ready for the Jury

from the Government's perspective?

MR. MANGAN: We are.

THE COURT: The Defense as well?

MR. McBRIDE: Yes, sir.

THE COURT: Very well. Let's call for the Jury.

COURTROOM DEPUTY: All rise for the Jury.

(Jury entered the Courtroom.)

THE COURT: You may all be seated. The 15 members

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SPECIAL AGENT BRADLEY HULL -- DIRECT 83

of the Jury have rejoined us. Good afternoon. I hope you

had a decent lunch break.

We're ready to continue the presentation of

testimony. The witness is still under oath, and he

acknowledges that; is that right, sir?

THE WITNESS: Yes, sir.

THE COURT: Very well. You may proceed, Mr.

Mangan.

MR. MANGAN: Thank you, Your Honor.

BY MR. MANGAN:

Q Agent Hull, when we left off, we were taking a look at

Exhibit 32. Just to refresh, we were talking about an

iPhone 5s backup; do you recall that?

A I do.

Q And where was that backup found?

A In the iCloud account belonging to the jastquhui

E-Mail account.

Q All right. And I believe we also talked about a

business card that was found earlier?

A We did.

Q All right. And where was that business card for Qu

Hui found?

A In the home of the GE Aviation engineer.

Q Okay. All right. The phone backup that we've been

talking about, what type of phone was it?

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SPECIAL AGENT BRADLEY HULL -- DIRECT 84

A It was an iPhone 5s.

Q And were you able to match that to one of the phones

recovered in Belgium?

A Yes.

Q All right. Now, if you could turn back to Exhibit 32?

MR. MANGAN: I believe we'd already admitted 32a,

Your Honor, if I'm correct?

BY MR. MANGAN:

Q And I was asking if you could take a look at

Exhibits 32b and 32i. Did you identified text messages in

that iPhone backup?

A Yes.

Q All right. And can you describe what Exhibits 32b

through 32i are?

A They're individual text message chains broken down

from the previous exhibit.

Q And do those all come from the original translations

in 32a?

A Yes.

Q All right.

MR. MANGAN: Your Honor, we'd move to admit

Exhibits 32b through 32i?

THE COURT: Any objection?

MR. McBRIDE: No, Your Honor.

THE COURT: They're admitted.

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SPECIAL AGENT BRADLEY HULL -- DIRECT 85

(Government's Exhibits 32b through 32i admitted.)

MR. MANGAN: May we publish 32b?

THE COURT: Yes.

(Government's Exhibit 32b was shown on the screen for Jury.)

BY MR. MANGAN:

Q Agent Hull, is this one of the text messages recovered

from the 5s backup?

A Yes.

Q And what is the phone number that was associated as

the sender?

A The number ending in 2316.

Q All right. And, again, as we go through these, will

the statements from that phone number be indicated in blue?

A Yes.

Q And any responses would be in a different color?

A In green.

Q All right. What is the date of this particular text

message?

A March 3 of 2014.

Q Can you read it for the Jury, please?

A "Academician Ouyang. This is Little Xu of the State

Security Department. I will be on time to meet you

across the street from Nanjing University of Chemical

Technology at five today."

Q All right. Thank you.

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SPECIAL AGENT BRADLEY HULL -- DIRECT 86

MR. MANGAN: If we could publish Exhibit 32b, Your

Honor?

THE COURT: Yes.

(Government's Exhibit 32b was shown on the screen for Jury.)

BY MR. MANGAN:

Q As we look at this, again, Agent Hull, who is this --

oh, I'm sorry. Is that the same?

A It is.

Q That's what I was just on. Let me try that again.

MR. MANGAN: Could we publish 32c?

THE COURT: 32c?

(Government's Exhibit 32c was shown on the screen for Jury.)

MR. MANGAN: Yeah.

THE COURT: Yes. Has 32c been admitted?

MR. MANGAN: I thought we just admitted 32b

through 32i?

THE COURT: Right. Now what is this?

MR. MANGAN: 32c.

THE COURT: And we're showing it to the witness?

MR. MANGAN: No, Your Honor --

THE COURT: Is it b through i or b and i?

MR. MANGAN: I was, I was offering 32b through

32i.

THE COURT: It's my mistake. Please proceed. You

can show it to the Jury. Perhaps you could blow it up, so

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SPECIAL AGENT BRADLEY HULL -- DIRECT 87

to speak.

MR. MANGAN: Yes. If he could blow up Exhibit 32c,

please?

(Government's Exhibit 32c was shown on the screen for Jury.)

BY MR. MANGAN:

Q Agent Hull, what is the date of this text message?

A September 19 of 2014.

Q And who is it from?

A It's from the Defendant, Xu Yanjun.

Q Can you read the text message, please?

A "Dean Zhu, I called you earlier, but I couldn't get

through. Could you please notify the qualified

students to send their resumes to this E-Mail address,

Jastxyj@gmail.com by 3 p.m. next Monday --

parentheses, the 22nd, end parentheses -- and have

them include the contact phone numbers in their

resumes. I will notify the students who meet the

requirement for interviews in the afternoon of the

23rd. Thanks, Xu Yanjun."

Q All right. Thank you, Agent.

MR. MANGAN: Your Honor, may we publish 32d?

THE COURT: Yes.

MR. MANGAN: And we're just going to look at the

top text message, please.

(Government's Exhibit 32d was shown on the screen for Jury.)

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SPECIAL AGENT BRADLEY HULL -- DIRECT 88

BY MR. MANGAN:

Q What is the date of this message?

A September the 19, 2014.

Q And, Agent Hull, can you read this text message?

A "Secretary Shen, this is Xu Yanjun of the Provincial

State Security Office and the unit of recruiting is

Ministry of State Security. Work location: Beijing.

Position type: Government employees. Must have taken

the national service examination.

They must meet these criteria: Either from the

College of Aeronautics, College of Automation, College

of Aerospace, or related disciplines, under the age of

25, Party member, male, undergraduates or graduate

degrees.

For those with Master's degrees, they must have

graduated from a 211 or 985 college or universities

qualified students can send their resumes before

Monday the 22nd to jastxyj@gmail.com.

Within the resume please include contact phone

information. I'll contact the qualified students for

interviews in the afternoon of the 23rd."

Q All right. With respect to that E-Mail account, do

you believe that's a typo there?

A I do.

Q All right. Thank you.

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SPECIAL AGENT BRADLEY HULL -- DIRECT 89

MR. MANGAN: We can take that down. If we could

take a look at -- Your Honor, could we publish 32e?

THE COURT: Yes.

(Government's Exhibit 32e was shown on the screen for Jury.)

MR. MANGAN: If we could zoom in?

BY MR. MANGAN:

Q What is the date of this message?

A December 10, 2014.

Q And could you read this age, Agent Hull?

A "Division Director Cai, the address is Division Six,

Jiangsu Provincial State Security Department, Xu

Yanjun. Thanks."

Q All right. Thank you.

MR. MANGAN: We'll take that down. Your Honor, may

we publish 32f?

THE COURT: Yes.

(Government's Exhibit 32f was shown on the screen for Jury.)

BY MR. MANGAN:

Q And who is this message from?

A The Defendant, Xu Yanjun.

Q And what is the date?

A August 25, 2015.

Q And can you read the message, please?

A "Director Wang, I am Xu Yanjun of the Jiangsu Bureau.

Thanks."

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SPECIAL AGENT BRADLEY HULL -- DIRECT 90

Q Thank you.

MR. MANGAN: Let's take that down. Your Honor, may

we publish 32g?

THE COURT: Yes.

(Government's Exhibit 32g was shown on the screen for Jury.)

BY MR. MANGAN:

Q And who is this message from?

A The Defendant, Xu Yanjun.

Q And this is dated November 29, 2014; correct?

A Correct.

Q All right. Can you read that, Agent Hull?

A "Secretary Xia, this is Xu Yanjun of the State

Security Bureau."

Q All right.

MR. MANGAN: Your Honor, may we publish

Exhibit 32h?

THE COURT: Yes.

(Government's Exhibit 32h was shown on the screen for Jury.)

BY MR. MANGAN:

Q And, Agent Hull, is this also from Xu Yanjun?

A It is.

Q And is it dated December 26, 2013?

A Yes.

Q Could you read the message for the Jury, please?

A "Chief Cheng, this is Little Xu of the Jiangsu State

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SPECIAL AGENT BRADLEY HULL -- DIRECT 91

Security Bureau. I am in Yanliang. Will you be in

The institute tomorrow? I would like to see you."

MR. MANGAN: And then if we can move to 32i? We --

may we publish?

THE COURT: Yes.

(Government's Exhibit 32i was shown on the screen for Jury.)

BY MR. MANGAN:

Q What is the date of this text message?

A April 1st, 2014.

Q And who is it from?

A The Defendant, Xu Yanjun.

Q Could you read this message, please?

A "Chief Gao, I am Little Xu of the Jiangsu State

Security Bureau. I will arrive in Yanliang tomorrow

afternoon. Tao Xiaojiang of the Aircraft Design

Institute has arranged a vehicle for me, and there are

no needs to bother you.

Due to the fact that there are a lot of materials on

flight control, I would like to get -- dedicate one

half of a day in the morning the day after tomorrow

for you to arrange for experts to come to my room to

view the materials.

This way, there will be ample time. The materials

mainly include flaps, high-lifts, slats, and other

materials. Thanks."

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SPECIAL AGENT BRADLEY HULL -- DIRECT 92

Q Thank you.

MR. MANGAN: We can take that down.

BY MR. MANGAN:

Q Agent Hull, have you heard of a communications App

called WeChat?

A Yes.

Q And are you familiar with it?

A I am.

Q And can you describe what it is?

A The best similarity, imagine a little bit of text

capability mixed with Facebook mixed with a little bit of

Amazon. You can make phone calls inside the App. You can

send text messages back and forth. You can exchange files.

You can do some money transfers. It's a pretty inclusive

application.

Q And what is a handle, a WeChat handle?

A It's a user generated name often comes with an image

associated with it.

Q And in your review of the 5s backup in the Cloud, did

you find WeChats?

A Yes.

Q And did you find multiple WeChats relating to the

Defendant?

A Yes.

(Government's Exhibit 33a marked.)

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SPECIAL AGENT BRADLEY HULL -- DIRECT 93

(Government's Exhibit 33a shown on the screen for the Court

and Witness.)

BY MR. MANGAN:

Q I'll have you take a look at Exhibit 33a?

A (Witness reviews exhibit.)

Q Can you describe what these are?

A It is a UFED Extraction Report of WeChat messages

collected from the Apple iCloud material for the Apple

iPhone 5s --

Q And --

A -- in Mandarin, and then the latter half of the

document are the English translations of the same.

Q Okay. So the original translations are behind the

UFED Report?

A Yes.

Q All right. And is the UFED Report in Chinese -- or

at least has Chinese messages?

A Yes.

Q All right. And was this with a handle called Surface?

A Yes.

Q All right.

MR. MANGAN: Your Honor, we'd move to admit

Exhibit 33a?

MR. McBRIDE: No objection, Your Honor.

THE COURT: It's admitted.

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SPECIAL AGENT BRADLEY HULL -- DIRECT 94

(Government's Exhibit 33a admitted.)

MR. MANGAN: Your Honor, if we could publish --

THE COURT: Yes.

MR. MANGAN: -- 33a page one?

THE COURT: Yes.

(Government's Exhibit 33a page one was shown on the screen

for Jury.)

BY MR. MANGAN:

Q And if we just look at the top one there, Agent Hull,

do you see that?

A I do.

Q And looking at the, the first WeChat number that's

right underneath participants, do you see it, a number that

starts with WXID?

A I do.

Q Can you explain what that is?

A That is the WeChat code that's generated when the user

creates an account. So that's not something that's created

by the user. That's created by the App itself.

Q All right. And so this particular account number ends

with -- do you see the numbers 55311?

A I do.

Q And is that one of the WeChat handles that you

encountered in the evidence in this case?

A Yes, it is.

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SPECIAL AGENT BRADLEY HULL -- DIRECT 95

Q And if we could set that aside and go back to one of

the exhibits from the Belgian phones, if we could.

MR. MANGAN: Your Honor, could we put up

Exhibit 7c, which I believe has already been admitted?

THE COURT: Yes.

MR. MANGAN: We'd like to go to the top of page

three, please?

(Government's Exhibit 7c page three was shown on the screen

for Jury.)

BY MR. MANGAN:

Q And you can see it on the screen as well, Agent Hull,

if that's easier. Was this one of the WeChats that was

found on the phone in Belgium?

A Yes, it was.

Q All right. And, again, this is Exhibit 7c. If we

look at the participants for the very top chat. Do you see

the WeChat number that's listed as the owner?

A It is. And it ends in 55311.

Q Is that the same WeChat account we were just

discussing in the Cloud?

A Yes, it is.

Q All right. Thank you.

MR. MANGAN: We can set that aside. I'd like you

to go back and take a look at Exhibits 33b through 33h.

(Government's Exhibits 33b through 33h marked.)

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SPECIAL AGENT BRADLEY HULL -- DIRECT 96

THE WITNESS: (Witness reviews exhibits.) Yes.

BY MR. MANGAN:

Q And can you describe what these are?

A These are the English translations of the same WeChat

messages that were outlined in 33a in English.

MR. MANGAN: Your Honor, we would move to admit

Exhibits 33b through 33h?

MR. McBRIDE: No objection.

THE COURT: They're admitted.

(Government's Exhibits 33b through 33h admitted.)

MR. MANGAN: Your Honor, may we publish 33b?

THE COURT: Yes.

(Government's Exhibit 33b was shown on the screen for Jury.)

BY MR. MANGAN:

Q Agent Hull, can you describe -- first of all, who is

this exchange between?

A It's between an account. Appears to identify the

WeChat account with the username Surface and another account

with the username Juice.

Q Okay.

THE COURT: Yes.

A JUROR: Sorry. Our monitor is showing static.

THE COURT: The monitor is what?

MR. MANGAN: It's showing static, I believe.

A JUROR: Everyone else's is good. Ours is messed

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SPECIAL AGENT BRADLEY HULL -- DIRECT 97

up.

THE COURT: Somebody able to assist who's not my

age? We'll pause off the record.

(Discussion held off the record.)

THE COURT: We're going to call for IT. They'll be

here momentarily.

A JUROR: We can make it work, Your Honor.

THE COURT: We can make it work, is that what I

heard?

A JUROR: Yes.

THE COURT: Thank you. Did you kick it?

(Laughter.)

THE COURT: Very well. Jurors are sharing screens

and are prepared to proceed. Mr. Mangan, you may proceed.

MR. MANGAN: Thank you, Your Honor.

BY MR. MANGAN:

Q Looking at Exhibit 33b, Agent Hull, if we could go

down to the message at the very bottom of the page. Do you

see message on March 30 from Juice, and it states:

"June 26, to July 12, medical exam and recuperation at

Taihu. Medical insurance card number and date are

needed."

Do you see that?

A I do.

Q All right.

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SPECIAL AGENT BRADLEY HULL -- DIRECT 98

MR. MANGAN: I'd like to turn to the next page.

(Government's Exhibit 33b page two was shown on the screen

for Jury.)

MR. MANGAN: Go to the top.

BY MR. MANGAN:

Q And what was sent by the owner Surface?

A The Jiangsu Province Provincial Government Medical

Card in the name of Xu Yanjun with the photo of the

Defendant.

Q All right. Did this help confirm that the Surface

WeChat belonged to Mr. Xu?

A Yes, it did.

MR. MANGAN: If we can turn and publish

Exhibit 33c, please?

THE COURT: Yes.

(Government's Exhibit 33c was shown on the screen for Jury.)

BY MR. MANGAN:

Q Who is this chat between?

A It's between the Surface account associated with Xu

Yanjun and an account associated with Lin 772438.

Q If you can go through and read the messages -- first

of all, do the messages start on January 14, 2016?

A They do.

Q If you could read the messages from the sender, Mr.

Xu. I'll read any responses.

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SPECIAL AGENT BRADLEY HULL -- DIRECT 99

A "Send Attachment 1.pic -- parentheses -- Division Six

Cadre Vacation Application Form."

"Asked for leave early enough."

"Login to my account to buy."

Q "Tell me the username and password."

A "The username is probably my cell phone number."

"Password is xuyanjun1980."

MR. MANGAN: If we could turn to the next page?

(Government's Exhibit 33c page two was shown on the screen

for Jury.)

BY MR. MANGAN:

Q Was there a document attached?

A There was.

Q And was that document translated?

A It was.

MR. MANGAN: If we could turn to the next page?

(Government's Exhibit 33c page three was shown on the screen

for Jury.)

BY MR. MANGAN:

Q What is this, sir?

A It's a document entitled Division Six Cadre Vacation

Application Form.

Q And in whose name?

A Xu Yanjun.

Q And what is his division?

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SPECIAL AGENT BRADLEY HULL -- DIRECT 100

A Division Six.

Q And what is his title?

A Deputy Division Director.

Q And after the vacation information, do you see where

it says Director's Comment?

A I do.

Q And director -- excuse me -- Department Leader's

Comment? Who is listed next to Director's Comment?

A Chen Li.

Q All right. And what is the date?

A January 14.

Q All right. Thank you.

MR. MANGAN: If we could skip to Exhibit 33e. May

we publish?

THE COURT: Yes.

(Government's Exhibit 33e was shown on the screen for Jury.)

BY MR. MANGAN:

Q Who is, who is -- Agent Hull, who are the individuals

in this conversation?

A The blue is the Defendant, Xu Yanjun; and the green is

a user with the handle Shanzm0527, and the name Yuanwai.

Q All right. If we could read through this, I will read

the messages in green.

"Hey, man, I heard you are with the

intelligence?"

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SPECIAL AGENT BRADLEY HULL -- DIRECT 101

A "Yes, what's yours."

Q "I'm with the information."

"Hardship."

A "Are you in the system of the 16th Bureau?"

Q "M-hum."

"You?"

A "I'm in the system of the Sixth Bureau."

"The Sixth Bureau and the 16th Bureau are in the

same compound."

MR. MANGAN: If we could turn to the next page?

(Government's Exhibit 33e page two was shown on the screen

for Jury.)

THE WITNESS: "Information is nice job."

"We are the actual hardship."

BY MR. MANGAN:

Q "You, hardship -- awkward?"

A "We are under lots of stress."

"Heavy tasks."

Q "More money, though!"

A "There are a lot of more money, but dare not to

spend under current situation."

"A lot of business charges were returned from our

Division last year."

"A Section Chief was transferred from Information

Division to our Division two years ago, now

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SPECIAL AGENT BRADLEY HULL -- DIRECT 102

he/she can't stand anymore and wants to be

transferred away."

MR. MANGAN: If we could turn to the next page?

I'm sorry. That was the end of that exhibit. Sorry. Thank

you, Your Honor. Oh, this is a continuation.

I believe we're on Exhibit 33e; correct? If we

could go to next page?

MS. PRIM: It's only two pages.

MR. MANGAN: It's only two pages. All right.

Thank you. If we could take -- that's the end of 33e.

Could we publish 33f, please?

THE COURT: Yes.

(Government's Exhibit 33f was shown on the screen for Jury.)

BY MR. MANGAN:

Q All right. For these messages, Agent Hull, is this

between Xu Yanjun and someone at Longrising Assets?

A Yes.

Q And what is the date of these messages?

A February 20, 2016.

Q And the message in green, does that say:

"Are you still with State Security?"

A It does. And the response from the Defendant:

"Yes, nowhere to go."

Q Thank you.

MR. MANGAN: May we publish Exhibit 33g?

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SPECIAL AGENT BRADLEY HULL -- DIRECT 103

THE COURT: Yes.

(Government's Exhibit 33g was shown on the screen for Jury.)

BY MR. MANGAN:

Q Is this a chat between Xu Yanjun and someone named

Vivian?

A Yes.

Q All right. Once, again, I will read the item in

green.

"Do you have information assessment?" "Picking

nose?"

A "No."

"Ours is intelligence assessment."

"For the Ministry."

Q "M-hum."

"Your requirements are high and you have specific

methods and ways?"

A "We have large investment."

"Different directions."

"Different focuses, too."

MR. MANGAN: If we could turn?

(Government's Exhibit 33g page two was shown on the screen

for Jury.)

BY MR. MANGAN:

Q "M-hum."

"Yours is more professional."

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SPECIAL AGENT BRADLEY HULL -- DIRECT 104

"We feel so stressed for information right now."

A "The same."

Q "Yours should be much better."

A "A lot of stress."

Q "You are also under a lot of stress?" "Awkward."

"I've always thought that you were very happy."

A "So much suffering."

Q "Awkward."

"Really." "Awkward."

"In that case, just eat more and drink more..."

"Do you deal with Hong Kong?"

A "Our Division doesn't."

"Some others do."

Q "Okay." "Crying loud." "Crying loud."

"Does your Division mostly deal with overseas?"

A "Right. Science and Technology."

Q "M-hm, I see."

"When will you have time? So that I could learn

from you. My treat for a meal?"

And is that the end of the exhibit? It -- I'm sorry.

Next page.

(Government's Exhibit 33g page three was shown on the screen

for Jury.)

THE WITNESS: "After the holiday."

BY MR. MANGAN:

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SPECIAL AGENT BRADLEY HULL -- DIRECT 105

Q All right. We can end there. Agent Hull, the

reference there to the Bureau doing Science and Technology,

is that consistent with what Dr. Mulvenon said regarding the

Sixth Bureau?

A It is.

MR. MANGAN: Lastly, could we publish 33h, please?

THE COURT: Yes.

(Government's Exhibit 33h was shown on the screen for Jury.)

BY MR. MANGAN:

Q And is this a message between Xu Yanjun and someone

named Gu Ning?

A Yes.

Q All right.

MR. MANGAN: If we could move down to the middle?

BY MR. MANGAN:

Q Let me start with the message dated April 7, 2017, in

green.

"Why do you want to find me? Don't you work for

the Ministry of State Security? Isn't it easy to

find me?"

A "Why can't we have a normal relationship then?"

"Do I have to use special method?"

Q All right. We'll stop there.

MR. MANGAN: We can take that down.

BY MR. MANGAN:

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SPECIAL AGENT BRADLEY HULL -- DIRECT 106

Q Agent Hull, did these messages help you confirm who

was using that WeChat handle?

A Yes, the Defendant, Xu Yanjun.

Q And did this provide more confirmation of where he

worked?

A It did.

Q We talked earlier about a, a Cadre Form. Do you

recall seeing that?

A I do.

Q And could you remind the Jury of what the job title

was that Mr. Xu had?

A Deputy Division Director.

Q And in that, there was a reference to a Jiangsu

Province; do you recall that?

A I do.

Q All right. Do you know what Jiangsu is?

A I do.

Q What is it?

A It's a province in East Central China, just a little

bit to the west of Shanghai.

Q All right. And where is -- do you know what Nanjing

is?

A It's the provincial capitol of the Province of

Jiangsu.

Q All right. And have you seen the term JSSD in some of

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SPECIAL AGENT BRADLEY HULL -- DIRECT 107

the communications from the Cloud?

A Yes.

Q All right. And what does that refer to?

A The Jiangsu State Security Department.

Q Through the various communications and the calendar

entries that we've talked about from this 5s Cloud, did you

find information regarding other colleagues that Mr. Xu

worked with?

A Yes.

Q And did that sometimes reflect titles for these

individuals?

A They did.

Q Were there ever communications where he referred to

individuals as his boss?

A Yes.

Q All right. Let's -- I'd like to help the Jury get

acquainted with certain individuals. What was the name of

the colleague who was with the Defendant in Belgium?

A Xu Heng.

Q And that was spelled H-E-N-G?

A Yes.

Q Earlier we saw a calendar entry with a person named

Chai Meng; do you recall that?

A I do.

Q Was that another individual that you saw in these

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SPECIAL AGENT BRADLEY HULL -- DIRECT 108

communications?

A Yes.

Q Okay. We just saw a vacation form that we just showed

the Jury; do you remember that?

A I do.

Q And who was listed as the approving individual?

A Chen Li.

Q All right.

MR. MANGAN: I'd like to show the Defendant -- or

excuse me, show the witness Exhibit 37a and 37b, please?

THE COURT: Very well.

(Government's Exhibits 37a and 37b marked.)

(Government's Exhibit 37a shown on the screen for the Court

and Witness.)

BY MR. MANGAN:

Q If you could look at 37a, do you recognize what this

is?

A I do.

Q And what is it?

A It's a message between Xu Yanjun and a telephone

number, ends in 0333.

MR. MANGAN: And if we can show the witness

Exhibit 37b?

THE COURT: Yes.

(Government's Exhibit 37b shown on the screen for the Court

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SPECIAL AGENT BRADLEY HULL -- DIRECT 109

and Witness.)

BY MR. MANGAN:

Q Do you recognize what this is?

A It is, it's a UFED Extraction Report containing two

SMS messages from the iCloud account associated with the

Apple iPhone 5s in the original Mandarin.

Q And does it relate to the same message we just saw?

A Yes.

Q All right.

MR. MANGAN: Your Honor, we'd move to admit

Exhibits 37a and b?

MR. McBRIDE: No objection.

THE COURT: Admitted.

(Government's Exhibits 37a and 37b admitted.)

MR. MANGAN: If we could publish 37b --

THE COURT: Yes.

MR. MANGAN: -- just for a moment?

(Government's Exhibit 37b was shown on the screen for Jury.)

BY MR. MANGAN:

Q So the Jury can see this, Agent Hull, is this an

example of what this UFED Report would look like?

A It is.

Q And this is for these two particular text messages?

A Yes.

Q Okay.

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SPECIAL AGENT BRADLEY HULL -- DIRECT 110

MR. MANGAN: Let's go over to 37a then to see the

translation, please?

(Government's Exhibit 37a was shown on the screen for Jury.)

BY MR. MANGAN:

Q Is there a message from Xu Yanjun?

A There is.

Q And is that dated October 21, 2014?

A Yes.

Q All right. Without reading every single number that's

in there, could you read the content of the message?

A "Division Director Luo, this is Xu Yanjun from

Jiangsu Department, Division Director Zha asked

me to send a citizenship identification numbers

to you. Thanks, Song Wenhui, with a PRC number

to follow; Chen Li, with a PRC identification

number to follow; Zha Rong, with a PRC

identification number to follow; and Xu

Yanjun, with a previously identified PRC National

ID Number."

Q All right. And in the course of reviewing these --

the evidence from this Cloud account, do you help identify

who these other three individuals are with Mr. Xu?

A Yes.

Q Who are they?

A They're his chain of command.

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SPECIAL AGENT BRADLEY HULL -- DIRECT 111

Q All right. And Chen Li, was that the individual on

the vacation form?

A Yes, it was.

Q All right. Did you also review the calendar entries

that Mr. Xu had in the Cloud account?

A Yes.

(Government's Exhibit 36 marked.)

BY MR. MANGAN:

Q All right. We'd like to have you take a look at

Exhibit 36.

MR. MANGAN: Your Honor, may he grab the binder for

that?

THE COURT: Yes.

MR. MANGAN: Thank you.

THE WITNESS: I don't have that binder up here.

THE COURT: Is it one of the two there? No.

THE WITNESS: No, sir. Oh. I'm sorry. Could you

remind me of the number, please?

BY MR. MANGAN:

Q Exhibit 36, please.

A (Witness reviews exhibit.)

Q Now, within the -- we talked about the calendar that

was found in the Cloud; correct?

A Yes.

Q And it had a lot of entries?

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SPECIAL AGENT BRADLEY HULL -- DIRECT 112

A 1,146.

Q All right. From that were you able to cull down that

amount with respect to certain individuals?

A Yes.

Q Can you explain what Exhibit 36 is?

A It's the iCloud calendar with references to Zha Rong,

Chen Li, Song, and other individuals that we identified as

likely working for the Sixth Bureau of the MSS in Jiangsu

Province.

Q All right. So is this a subset of the calendar?

A Yes.

Q And these are just selections?

A Yes. It's not the whole 150-some pages.

MR. MANGAN: All right. Your Honor, we'd move to

admit Exhibit 36?

MR. McBRIDE: No objection.

THE COURT: Admitted.

(Government's Exhibit 36 admitted.)

BY MR. MANGAN:

Q All right.

MR. MANGAN: If we could publish, Your Honor,

please?

THE COURT: Yes.

(Government's Exhibit 36 was shown on the screen for Jury.)

BY MR. MANGAN:

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SPECIAL AGENT BRADLEY HULL -- DIRECT 113

Q We'd like to start. We're not going to read all of

this. There's a lot of entries, aren't there?

A A lot.

Q All right. But to give the Jury a sampling, if we

could start on page 11.

(Government's Exhibit 36 page 11 was shown on the screen for

Jury.)

BY MR. MANGAN:

Q If I could pick out certain entries by number on left

and then ask you to read them, Agent Hull?

A Yes.

Q And for each one of these, is there a date indicated?

A Yes.

Q And where is the date?

A On the far right-hand column.

Q Okay. So I'd like to start on page 11 with 973. Do

you see that, sir?

A I do.

Q Can you read the entry for 973, please?

A "Evening, Chen Li and Zha Rong held banquet for 606

and 410. Second and Fourth Section attended. And the

day was 7-15 of 2014."

Q All right.

MR. MANGAN: If we could go to the prior page, page

ten?

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SPECIAL AGENT BRADLEY HULL -- DIRECT 114

(Government's Exhibit 36 page ten shown on the screen for

the Court and Witness.)

BY MR. MANGAN:

Q We're going to look at number 786.

A (Witness reviews exhibit.)

Q And what is the date for this particular entry?

A March 26, 2015.

Q Can you read the entry, please?

A "Talked to Chen Li. Chen stated to add a Deputy

Division Director position and had discussed with Song

and Wang. The predetermined person would be me, but

there are some resistance."

Q Thank you.

MR. MANGAN: Let's turn to page nine.

(Government's Exhibit 36 page nine was shown on the screen

for Jury.)

BY MR. MANGAN:

Q We'll start at the bottom. Looking at number 762,

please. Is that entry dated April 7, 2015?

A It is.

Q And by the way, for the Category on the left, what's

the Category indicated for these?

A Work.

Q All right. Please read the entry?

A "Noon, Chen Li held banquet for Zhang Hongrui and Zha.

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SPECIAL AGENT BRADLEY HULL -- DIRECT 115

Second and Fourth Section attended. During the

banquet, Chen mentioned about the newly established

Deputy Division Director position in the Division and

said I could be the one."

Q And if we look up from there and look at 757, that's

dated the next day, April 8, could you read that entry,

please?

A "Afternoon, the Department held democratic poll for

Deputy Division Director nomination. 12 out of the

whole Department. One from my Division."

Q Thank you.

MR. MANGAN: I'd like to skip to page seven. Go

back a couple.

(Government's Exhibit 36 page seven was shown on the screen

for Jury.)

BY MR. MANGAN:

Q We're going to look at number 617, and what's the date

for that?

A September 22, 2015.

Q Could you read that entry, please?

A "Morning, the Department called democratic

recommendation for Deputy Department Director position

and Deputy Department Director level position. Chen

Li failed to be selected."

Q Thank you. The next one we'll do is 582. What's the

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SPECIAL AGENT BRADLEY HULL -- DIRECT 116

date?

A November the 22nd, 2015.

Q If you could read it, please?

A "Department Deputy Division Director training

session."

Q Thank you.

MR. MANGAN: Let's turn one page back to page six.

(Government's Exhibit 36 page six was shown on the screen

for Jury.)

BY MR. MANGAN:

Q Looking down at the bottom, do you see 478?

A I do.

Q Let's read that entry for the Jury.

A "May 16, 2016. Morning, Song announced that Zha will

temporarily in charge of Sixth Division."

Q And if we go up from there a little bit, do you see

just the two right above it, 474 and 473?

A I do.

Q If you could read those as well?

A "May 19, 2016. Afternoon, election for Division

Director."

"May 23, 2016. Evening, the core members of the

Division, Chen Li, and branch dined together."

Q All right. If we go two steps up from there to 464.

Is there an entry dated June 6, 2016?

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SPECIAL AGENT BRADLEY HULL -- DIRECT 117

A Yes.

Q Could you please read that, Agent Hull?

A "Morning, the Personnel office reviewed Zha and

assessed my probation period."

Q All right. Now, we're just going to go up a little

bit to 435 and 434, and those are both dated August 24,

2016; correct?

A Yes.

Q All right. If you could read the one on -- well,

either one of them? You can read both?

A "Zha's appointment was announced."

"My official appointment came. Parentheses -- waited

for too long. It finally came. Took a load off my

mind."

Q Okay. And if we look up -- we don't have to

highlight it, but 425, does that say?

"Zha's official appointment came?"

A It does.

Q Let's take a look at number 412 at the very top of the

page. What's the date there?

A September 29, 2016.

Q Could you read the entry for the Jury, please?

A "Zha assigned me to be in charge of Fourth Division."

Q Thank you. Now, just a couple more I'd like to take a

look at.

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SPECIAL AGENT BRADLEY HULL -- DIRECT 118

MR. MANGAN: If we could go to page three?

(Government's Exhibit 36 page three was shown on the screen

for Jury.)

BY MR. MANGAN:

Q Like I said, we won't read a lot of these. There's a

lot in there. If you could take a look at number 244,

please. What's the Category for this?

A Thoughts.

Q At times did this calendar seem to read like a diary?

A It did.

Q All right. What was the date of this entry?

A March the 27, 2017.

Q And could you read the, read the entry, please?

A "Zha rejected a receipt. Parentheses -- Zha rejected

a meal receipt today. Rebuked Chai Meng. The

ingratitude person like him is shameless. Will

revenge."

Q If you recall we earlier read an entry from a couple

days before Dr. Zheng's visit to China; do you remember

that?

A I do.

Q All right. And where he mentioned meeting with two

individuals?

A He did.

Q All right. Do you recall the name of one of those?

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SPECIAL AGENT BRADLEY HULL -- DIRECT 119

A Chai Meng.

Q Okay. Is that the same name that we see in 244?

A It is.

Q All right.

MR. MANGAN: If we could go up to 223, please?

BY MR. MANGAN:

Q It's dated April 28, 2017; correct?

A It is.

Q Could you read that one?

A Category "Thoughts. Relationship with Zha has dropped

to freezing point. Zha undermine me. I need to

adjust my mindset."

Q All right. Thank you.

MR. MANGAN: And then if we could go to 219?

BY MR. MANGAN:

Q Are these more thoughts?

A Yes.

Q And this one's dated May 4, 2017; correct?

A It is.

Q Could you read this entry, please?

A "The big cat fight between Zha and Chen is now on --

exclamation point. Watching the show -- exclamation

point."

Q Are these two of his superiors?

A They are.

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SPECIAL AGENT BRADLEY HULL -- DIRECT 120

Q All right. And then if we look up at 213 at the very

top. It's a longer entry. I know we don't need to read the

entire thing, but is this more relating to the individual

named Zha?

A Yes, it is.

Q And could you read where it starts with:

"I have been with Zha for more than a decade."

Do you see that?

A "I've been with Zha for more than a decade, but Zha

has turned hostile on me, and Zha is now tight with

Teng. What a joke. I think my relationship with him

will never be the same again. We will be using each

other to our own ends. I will not help him anymore.

It's whatever now. Have leader like this, what's the

point."

Q All right. Thank you.

MR. MANGAN: Then, lastly, let's turn to page one

for a couple entries.

(Government's Exhibit 36 page one was shown on the screen

for Jury.)

BY MR. MANGAN:

Q At the very bottom, the last entry, number 156, what's

the date for that one?

A July the 5th, 2017.

Q And could you read that entry?

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SPECIAL AGENT BRADLEY HULL -- DIRECT 121

A "Boss Song brought Chen and Zha to Sixth. Not sure

what they talked about."

Q And, again, who are those three individuals?

A Those are his chain of command.

Q All right. And what is the order from the titles that

you saw?

A Song and then Chen and then Zha is his immediate

supervisor.

Q I'm sorry. Could you speak up, speak up?

A I said Zha would be his immediate supervisor.

Q Okay. Thank you. And then let's take a look at

number 135?

THE COURT: We're at a break point. Does it work

for you?

MR. MANGAN: I've got two left. Can we do two

more --

THE COURT: Go ahead.

MR. MANGAN: -- and then we'll be done? Thank you,

Your Honor.

BY MR. MANGAN:

Q For number 135, Agent Hull, do you see on there where

it says:

"The core members of the Division accompanied. During

the feast, Zha went nuts and said I am poor at

management on Guozhi's issue."

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SPECIAL AGENT BRADLEY HULL -- DIRECT 122

Do you see that?

A I do.

Q All right. Did you see references to an individual

name Guozhi?

A Yes.

Q What is his name?

A His full name was Li Guozhi.

Q All right. And then lastly if we could look at the

very top entry number 51. Is that dated October 20, 2017?

A It is.

Q Could you read that for the Jury, please?

A "Morning, personnel review, Division Director Zha

passed probation."

MR. MANGAN: Your Honor, if we could stop there?

THE COURT: Very well. We're going to take a

mid-afternoon break. We'll break until quarter of the next

hour.

During the break, take a break. Don't discuss this

case with anyone, including among yourselves. No

independent research. Continue to keep an open mind.

Out of respect for you, we'll rise as you leave

until 2:45.

COURTROOM DEPUTY: All rise for the Jury.

(Jury exited the Courtroom.)

THE COURT: Jury's left the room, and the door is

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SPECIAL AGENT BRADLEY HULL -- DIRECT 123

closed. Anything before we break from the Government?

MR. MANGAN: No, Your Honor.

THE COURT: The Defense?

MR. McBRIDE: No, Your Honor.

THE COURT: We're in recess until 2:45. Witness,

please do not discuss your testimony.

COURTROOM DEPUTY: This Court's in recess until

2:45.

(Court was in recess at 2:23 p.m. and resumed at 2:49 p.m.)

COURTROOM DEPUTY: All rise. This Court is in

session pursuant to the recess.

THE COURT: Thank you. Please be seated. We're

back in the courtroom on the record outside the presence of

the Jury.

Are we ready to continue the testimony from the

Government's perspective?

MR. MANGAN: Yes, Your Honor.

THE COURT: And from the Defense?

MR. McBRIDE: Yes, sir.

THE COURT: And you're going to alert me when we

need to recess, Mr. Mangan?

MR. MANGAN: Yes, I will.

THE COURT: Very well. Let's call for the Jury,

please?

COURTROOM DEPUTY: All rise for the Jury?

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SPECIAL AGENT BRADLEY HULL -- DIRECT 124

(Jury entered the Courtroom.)

THE COURT: You may all be seated. 15 Jurors have

rejoined us. Is that computer screen now working, sir?

A JUROR: It came back on, yes. It's good.

THE COURT: Is the answer yes?

A JUROR: Yes.

THE COURT: Great. Don't kick it again.

(Laughter.)

THE COURT: I know you didn't.

(Laughter.)

THE COURT: All right. Witness's still on the

stand. You recall that you're under oath, sir? I have to

ask.

THE WITNESS: I do.

THE COURT: Very well. You may proceed, Mr.

Mangan.

MR. MANGAN: Thank you, Your Honor.

BY MR. MANGAN:

Q Agent Hull, in your review of the various

communications and records that we've been discussing, did

you see discussions relating to meetings with employees from

aviation companies?

A Yes.

Q And did those include aviation companies based in the

U.S. and Europe?

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SPECIAL AGENT BRADLEY HULL -- DIRECT 125

A Yes.

Q Can you give examples of some of the companies that

you saw represented?

A GE Aviation, Boeing, Honeywell, Pratt and Whitney,

UTC, Fokker, amongst others.

Q And were these types of meetings discussed in the

calendar that we just mentioned?

A Yes, they were.

Q And in some of the WeChats and text messages?

A Yes.

Q Was there a name that Mr. Xu and his associates used

for that type of meeting?

A Exchanges.

Q All right. And what did they -- was there a name

that they used to refer to the employee from the aviation

company that would come over?

A Sometimes guests. Other times projects.

Q All right. Now, we just saw some references to an

individual named Zha Rong. Do you remember that?

A I do.

THE COURT: Can you spell that name, please?

THE WITNESS: Z-H-A, R-O-N-G.

THE COURT: Very well.

BY MR. MANGAN:

Q Did you find text messages between the Defendant and

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SPECIAL AGENT BRADLEY HULL -- DIRECT 126

Zha Rong in the jastquhui Cloud?

A Yes.

Q And in looking at the text messages, did you also come

across something that looked like a number system?

A Yes.

Q Can you explain to the Jury what you saw?

A So for particular individuals, the messages only

showed the last five digits of their phone number once they

got into a chat stream.

Q And looking at those numbers, were you able to

identify certain individuals?

A Yes.

Q How?

A They used their real names.

Q Okay.

MR. MANGAN: Can you -- could we show the witness

Exhibits 38 and -- excuse me 38a and b?

THE COURT: Yes.

(Government's Exhibits 38a and 38b marked.)

BY MR. MANGAN:

Q Do you have the binder there, Agent Hull?

A I do.

(Government's Exhibit 38a shown on the screen for the Court

and Witness.)

BY MR. MANGAN:

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SPECIAL AGENT BRADLEY HULL -- DIRECT 127

Q Do you recognize what 38a is?

A I do. It is a UFED Extraction Report of 361 SMS text

messages from the aforementioned Apple iCloud backup for the

iPhone 5s.

THE COURT: And excuse me. The UFED Extraction

Report. UFED is all caps, U-F-E-D; is that right?

THE WITNESS: Yes, sir, it is.

THE COURT: Very well.

BY MR. MANGAN:

Q And do these pertain to -- as far as messages between

certain individuals?

A Yes.

Q Can you explain?

A They're the text messages back and forth just like in

everybody else's phone, and then the back half of 38a is the

English translation of the Mandarin original.

Q You mentioned a certain phone index that was used. Is

there a phone number that these messages were sent to and

from?

A 63866.

Q And from the messages, did you identify who that

was -- would be?

A Yes.

Q And who was that?

A Zha Rong.

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SPECIAL AGENT BRADLEY HULL -- DIRECT 128

MR. MANGAN: Your Honor, we'd move to admit

Exhibits 38a and b?

MR. McBRIDE: No objection.

THE COURT: Admitted.

(Government's Exhibits 38a and 38b admitted.)

(Government's Exhibit 38c marked.)

BY MR. MANGAN:

Q All right. Then, Agent Hull, if you could take a look

at 38c, please?

THE WITNESS: (Witness reviews exhibit.)

BY MR. MANGAN:

Q Explain what that is?

A It's a subset of the 361 text messages sort of

summarized or boiled down into a smaller set.

Q Okay. So there was the original set of 361 text

messages and that is in Exhibit 31b --

A Yes.

Q -- or excuse me -- 38b?

A 38b.

Q And then 38c, can you explain that again?

A It's just a subset of the messages between the

Defendant and Zha Rong.

Q All right. Thank you.

MR. MANGAN: Your Honor, we'd move to admit 38c?

MR. McBRIDE: No objection.

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SPECIAL AGENT BRADLEY HULL -- DIRECT 129

THE COURT: Admitted.

(Government's Exhibit 38c admitted.)

MR. MANGAN: May we publish?

THE COURT: Yes.

(Government's Exhibit 38c was shown on the screen for Jury.)

BY MR. MANGAN:

Q Agent Hull, I'd just like to highlight a few here.

Starting with page one, number 3719; do you see that message

to the left?

A I do.

Q Who is that message to?

A It's to the number we associated with Zha Rong.

Q All right. And what is the date of that message?

A October 22, 2014.

Q Can you go ahead and read the message to the Jury?

A "Director Zha, I had finalized the meeting site and

the meeting agenda a moment ago. The evaluation fee

has also been discussed and finalized with Chief Hu.

He has made the arrangements. Tomorrow Chief Hu will

go to the train station to pick you all up. Do I need

to come? Or wait at the meeting site."

Q And is Chief Hu spelled H-U?

A It is.

Q All right. Thank you. Within these messages, did you

see references to the exchanges that we talked about?

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SPECIAL AGENT BRADLEY HULL -- DIRECT 130

A Yes.

MR. MANGAN: I'd like to turn to page two.

(Government's Exhibit 38c page two was shown on the screen

for Jury.)

BY MR. MANGAN:

Q Starting down at the messages in April 2, 2015. Do

you see message 2587, Agent Hull?

A Yes.

Q All right. And is that message to Zha Rong?

A Yes.

Q Let's wait for a moment. We're going to start at

message 2587; do you see that?

A I do.

Q If you read the messages to Zha Rong from the

Defendant, I will read the messages from Zha Rong.

Hang on. We're going to start at 2587. All right.

Go ahead.

A "Did not bring all the materials."

Q "What have been brought?"

A "Brought half of as10 and all of 11."

"He said that -- he said that he went to a different

place to get it."

Q "Why is it incomplete?"

"He has several places to get materials."

A "He said that he asked other people in another

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SPECIAL AGENT BRADLEY HULL -- DIRECT 131

branch."

Q "A pack of lies."

A "Also, he has cut off the headings of the documents.

All of the document generation dates are within the

last couple of days."

MR. MANGAN: If we could continue onto the top of

the next page?

(Government's Exhibit 38c page three was shown on the screen

for Jury.)

BY MR. MANGAN:

Q Is this a continuation of the text messages with Zha

Rong?

A It is.

Q If you can continue at the top?

A "He wants to quit his job and get another one."

Q "Where does he want to go?"

A "He says that he is unhappy with his work."

"Eaton."

Q "To do what."

"To do what."

A "Still his old profession."

"This one is to work on components."

Q "Will there be a salary increase? Are the conditions

better?"

A "It's hard to tell right now. The key is that he is

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SPECIAL AGENT BRADLEY HULL -- DIRECT 132

unhappy with the current situation."

"He has said that the upper management is giving too

much hard time to the old-timer's of the company."

Q All right. Now, I'd like to go to the very bottom,

the last message there number 2475; do you see that?

A I do.

Q If we could start with that message and then continue

onto the next page, please?

A "The guest has been picked up."

(Government's Exhibit 38c page four was shown on the screen

for Jury.)

BY MR. MANGAN:

Q Continuing on next page. "Okay. Changed to Private

Room 305?"

A "Okay."

"The guest has said that he/she cannot remember the

data. He/she wants to go back to write the report."

Q "Okay. He/she may come anytime or send it over when

it's ready?"

All right. Agent Hull, we'll stop there. If we could

turn to page three -- I'm sorry. We just did that. I'm

sorry. Page four. In the middle there where it's May 8,

2015. I'm referencing entry 2103; do you see that?

A I do.

Q Can you read that message?

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SPECIAL AGENT BRADLEY HULL -- DIRECT 133

A "Yesterday, Boss Shi and Hongrui went to 603."

Q Based on your investigation, did you learn what 603

refers to?

A Yes.

Q Can you explain what that is?

A So previously testimony talking about the AVIC

Corporation. They have numbered institutes within AVIC that

each have a specialty in a different technology. 603 is one

of those numbered institutes.

Q All right. And then if we could go down to the

messages starting at 1300, dated August 13, 2015. Do you

see that, sir?

A I do.

Q Can you start reading those messages?

A "Chen has asked me to discuss with you. For the

reporting, try to think of something on the thinking

process and individual cases."

"Below is what I have found out so far: Director

General Shi plans to arrive in Nanjing in the evening

this Sunday and return to Beijing on Thursday.

Aerospace will report on Monday morning while military

electronics will report in the afternoon."

Q "Okay. We will talk tonight."

All right. If we could turn finally to the last page?

A (Witness complies.)

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SPECIAL AGENT BRADLEY HULL -- DIRECT 134

(Government's Exhibit 38c page five was shown on the screen

for Jury.)

BY MR. MANGAN:

Q Agent Hull, do you see a message there for 1040 from

Zha Rong that states:

"Chen is not among the candidates for the Deputy

Director-General position?"

A I do.

Q And then what is the response from Xu?

A "Yes. I heard it from older sister this morning."

"Going nowhere."

Q All right. It continues on. Was there a reference to

this on the calendar as well?

A Yes, there was.

Q About Chen Li not getting a promotion?

A Yes.

Q All right. Thank you. We can set that exhibit aside.

I believe you also mentioned another colleague named Chai

Meng?

A Yes.

Q Can you spell that?

A C-H-A-I. Second part, M-E-N-G.

Q Can you --

MR. MANGAN: Could we show the witness Exhibits 39a

and 39b, please?

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SPECIAL AGENT BRADLEY HULL -- DIRECT 135

THE COURT: Yes.

(Government's Exhibits 39a and 39b marked.)

(Government's Exhibit 39a shown on the screen for the Court

and Witness.)

BY MR. MANGAN:

Q Agent Hull, in the iCloud 5s backup that we've been

discussing, did you find messages between the Defendant and

a person named Chai Meng?

A Yes.

Q Can you identify what 39a and b are?

A It's the UFED Extraction Report of 172 SMS text

messages between the Defendant, Xu Yanjun, and Chai Meng in

Mandarin with the English translation toward the back of the

packet.

Q All right. And Exhibit 39b?

A Yes.

Q Can you identify what that is?

A Sorry. It's the English translation of those same

messages.

Q All right. At least some of the messages; correct?

A Some of them, yes.

Q All right.

MR. MANGAN: Your Honor, we'd move to admit

Exhibits 39a and 39b?

MR. McBRIDE: No objection.

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SPECIAL AGENT BRADLEY HULL -- DIRECT 136

THE COURT: Admitted.

(Government's Exhibits 39a and 39b admitted.)

MR. MANGAN: If we could publish 39b?

THE COURT: Yes.

(Government's Exhibit 39b was shown on the screen for Jury.)

BY MR. MANGAN:

Q Now, there's about 11 pages of messages. I'd just

like to read a couple.

MR. MANGAN: If we could turn to page ten?

THE WITNESS: (Witness reviews exhibit.)

(Government's Exhibit 39b page ten was shown on the screen

for Jury.)

BY MR. MANGAN:

Q And look at the -- do you see a text message dated

October 26, 2015?

A Yes.

Q And is there a message from Mr. Xu starting with "It's

Possible?"

A Yes.

MR. MANGAN: I'm sorry. Thank you. There we are.

BY MR. MANGAN:

Q If you could start reading with that message, please?

A "It's possible that Chen Li may take action against

you by dismissing you as Section Chief and promote

Geng. Talked about it with Zha today."

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SPECIAL AGENT BRADLEY HULL -- DIRECT 137

Q "Got it. I'll find Song as soon as possible."

A "Chen will let Geng and Song carry the same rank, a

mutual check and balancing."

Q All right.

MR. MANGAN: And then if we could turn to the last

page? Up.

(Government's Exhibit 39b page 11 was shown on the screen

for Jury.)

BY MR. MANGAN:

Q Do you see a message dated March 29, 2016, from --

A I do.

Q -- Mr. Xu, and who is that to?

A It's to Chai Meng.

Q Can you read that message, please?

A "A Communist Party meeting is over and Chen is

stepping down."

Q "Zha is promoted? It looks like he wants to send me

to Seven when he's arranging the work situation in the

afternoon?"

A "Should be dregs."

Q All right. That's all for that exhibit. In looking

at the calendar, there's one other name we mentioned. Do

you recall a name Li Guozhi?

A Yes.

Q And is that spelled L-I, G-H-O-U-Z-H-I?

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SPECIAL AGENT BRADLEY HULL -- DIRECT 138

A Sounds about right.

Q All right. Now, was his name mentioned in the

calendar?

A Yes, it was.

Q And did you find messages between the Defendant and Li

Guozhi?

A Yes.

Q Can you --

MR. MANGAN: Could we show the witness Exhibits 40a

and 40b, please?

(Government's Exhibits 40a and 40b marked.)

THE COURT: Yes.

(Government's Exhibit 40a shown on the screen for the Court

and Witness.)

BY MR. MANGAN:

Q Agent Hull, can you explain what Exhibits 40a and b

are?

A 40a is a UFED Extraction Report from the iCloud of 63

SMS text messages with the original being in Mandarin

Chinese, and at the back of that packet, there's English

translations of the same.

And 40b is just a compilation of those same messages

in English.

Q All right.

MR. MANGAN: Your Honor, we'd move to admit

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SPECIAL AGENT BRADLEY HULL -- DIRECT 139

Exhibit 40a and 40b?

MR. McBRIDE: No objection.

THE COURT: Admitted.

(Government's Exhibits 40a and 40b admitted.)

MR. MANGAN: May we publish 40b, please?

THE COURT: Yes.

(Government's Exhibit 40b was shown on the screen for Jury.)

BY MR. MANGAN:

Q Now, that the Jury can see that, Agent Hull, are these

some of the messages between Xu Yanjun and Li Guozhi?

A Yes.

Q Okay.

MR. MANGAN: I'd like to just turn and read a

couple on page three, if we might.

(Government's Exhibit 40b page three was shown on the screen

for Jury.)

BY MR. MANGAN:

Q Starting on January 26, 2014, do you see a message

from Xu Yanjun?

A I do.

Q If we could start there.

A "Let me know what's going on in the work space. Send

message to me."

Q "Geng, Gao, and Meng are coming back today. The 3rd

Division of Sixth Bureau are coming to talk about Red

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SPECIAL AGENT BRADLEY HULL -- DIRECT 140

Net. Song, the Director-General of the Department,

has approved the document and will be sending it out

tomorrow?"

A "Let me know if there is any personnel change within

the department."

Q "Sure."

And then I'd like to continue on, but note that it's a

new date. Do you see that it's January 28, 2014?

A I do.

Q All right. I'll continue on with the message from Li

Guozhi. "Which name do you use to communicate with Liming?"

A "Forgot."

"Need to check text message."

"Just don't sign the name."

Q "Is it under the name of the Association?"

A "For what?"

Q "To send E-Mail."

A "It was sent before. Check which E-Mail address was

used. He knows our identity."

Q "Didn't find our E-Mail address in the address list,

only his two E-Mail addresses. I will keep looking?"

A "Didn't he reply the E-Mail several days ago saying

the attachment is in gibberish."

Q "Found it. It's the one with gibberish."

All right. And we'll stop right there.

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SPECIAL AGENT BRADLEY HULL -- DIRECT 141

A Okay.

Q Okay. Thank you. Agent Hull, just a moment ago I

think you mentioned a group called AVIC; correct?

A I did.

Q And can you just remind us what that was?

A It's one of the State-Owned Enterprises that's

responsible for aircraft design in China.

Q And in connection with the exchanges, did you see

communications with technical experts at AVIC?

A Yes.

Q Now, based on your understanding, does the MSS

manufacture any kind of airplanes?

A No.

Q What does AVIC do?

A They do the research and design in order to

manufacture aircraft.

Q Did you see communications between Mr. Xu and

individuals at AVIC?

A Yes.

Q And did those pertain to these exchanges with foreign

aviation experts?

A They did.

Q I'll have you look at Exhibits 41a and b.

(Government's Exhibits 41a and 41b marked.)

THE WITNESS: (Witness reviews exhibit.)

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SPECIAL AGENT BRADLEY HULL -- DIRECT 142

BY MR. MANGAN:

Q Do you see those?

A I do.

Q All right. Can you describe them, Agent Hull?

A 41a contains 84 SMS text messages in a UFED Extraction

Report from the aforementioned iPhone between various

individuals identified as working for AVIC.

41b is a summary of all those, all those messages

between the Defendant and the AVIC employees.

MR. MANGAN: Your Honor, we'd move to admit

Exhibits 41a and b?

MR. McBRIDE: No objection.

THE COURT: Admitted.

(Government's Exhibits 41a and 41b admitted.)

MR. MANGAN: May we publish 41b, sir?

THE COURT: Yes.

MR. MANGAN: Thank you.

(Government's Exhibit 41b was shown on the screen for Jury.)

BY MR. MANGAN:

Q Agent Hull, these messages on the summary in 41b, are

these in chronological order?

A They are.

Q All right. But as we go through it, at times is Mr.

Xu speaking with different individuals at AVIC?

A He is.

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SPECIAL AGENT BRADLEY HULL -- DIRECT 143

Q All right.

A I tried to adjust the color so we could tell the

difference.

Q All right. And the messages that are in blue, who are

those messages from?

A The Defendant, Xu Yanjun.

Q Okay. I'd like to read the messages on the first page

in this top block between the Defendant, Xu Yanjun, and an

individual. Can you state the name of the individual he's

talking to?

A Chengyu Liu.

Q Could you spell that, please?

A C-H-E-N-G-Y-U, and then L-I-U.

Q All right. And these messages begin on December 27,

2013; is that correct?

A That is correct.

Q All right. I'll begin for the part in green to Mr.

Xu.

"The analytical tools for Boeing strength engineers,

such as Famoss. Boeing Design Manual, such as book2,

3, and BDMs?"

A "Okay."

Q "Software such as famoss and csw, the analytical

tools. Also the Boeing Design Manual?"

A "Manager Yang asks if we need the manual of the

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SPECIAL AGENT BRADLEY HULL -- DIRECT 144

software."

Q "Did the driver take you to your destinations in the

afternoon?"

A "Yes, the driver did. I will talk to the guest about

it in couple days."

"Institution Chair Liu, what is BDMs -- question mark?

I have only heard of BDM. Is it Boeing Design

Manual -- question mark."

Q "That's it."

"We don't know the exact serial number."

A "Is there any particular serial number?" I check the

menu, if it begins with a 4, it is structural

allowables-flight equipment, if it begins with a 5, it

is structural-allowable support equipment, if it

begins with a 6, it is structural analysis methods,

and if it begins with a 7, it is electrical design."

"If it begins with a 1, it is general design."

"Which one fits your demand more? 1, 4, 5, 6, or 7?"

Q "I think 6."

A "Okay."

Q All right. We'll stop there.

MR. MANGAN: I'd like to turn to page two, and

highlight the message that's in the middle dated April 4,

2014.

(Government's Exhibit 41b page two was shown on the screen

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SPECIAL AGENT BRADLEY HULL -- DIRECT 145

for Jury.)

BY MR. MANGAN:

Q Do you see that one, Agent Hull?

A I do.

Q And is there a -- it begins with Director Lin, do you

see that?

A I do.

Q Okay. And the message from Xu Yanjun, who is that

being sent to?

A Yiguang Lin.

Q Could you spell that, please?

A Y-I-G-U-A-N-G, then L-I-N.

Q All right. Thank you. Could you read the message

from Mr. Xu on that date?

A "Director Lin, just called your office but no one

picked up. The contents of our information are mainly

the design drawings, 3D digital model, and material

processing techniques for the rigid fuel equipment of

ruddervator of the U.S. Aerial Refueling Aircraft --

parentheses, kc-135, end parentheses. Another project

is the design specification, system requirements, and

simulation evaluation of the deicing technology.

Please contact me and kindly review the assessment

when you receive it. Thank you very much and come to

visit Nanjing whenever you have some time. Xu

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SPECIAL AGENT BRADLEY HULL -- DIRECT 146

Yanjun."

Q "Got it. Q." All right. Thank you.

MR. MANGAN: I'd like to turn to page three.

(Government's Exhibit 41b page three was shown on the screen

for Jury.)

BY MR. MANGAN:

Q Just read a few more of these messages. The message

we just talked about, it referenced a kc-135. Do you know

what that is?

A It's a U.S. Military aircraft.

Q All right. Thank you. Let's turn to page three

toward the bottom. Do you see some messages that start on

December 15, 2014?

A I do.

Q And who are those messages between?

A Chengyu Liu we discussed previously.

Q All right. If you could start with the message that's

starts on the 15th?

A "Institution Chair Liu, have you received the material

yet."

Q "Not yet."

A "Institution Chair Liu, let me know after you get it.

I will communicate with the confidential --

department. Don't know why it's so slow."

Q "Okay. Maybe it is just slower to go through

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SPECIAL AGENT BRADLEY HULL -- DIRECT 147

confidential route?"

A "Institution Chair Liu, give me one of your E-Mail

addresses. I will send the form to you. Please

fill-in the keywords for me."

"I have removed the keywords in the form."

Q All right.

MR. MANGAN: If we could turn to the next page?

(Government's Exhibit 41b page four was shown on the screen

for Jury.)

BY MR. MANGAN:

Q And do you see the message that begins the next day

dated December 17, 2014?

A I do.

Q And is that sent to a different individual?

A It is.

Q Could you read those next five messages -- who are

those messages sent to?

A Renjun Sun.

Q Could you spell it, please?

A R-E-N-J-U-N. Second name, S-U-N.

Q Could you read those top five messages, please?

A "Engineer Sun, I send the data requirement from the

expert to your E-Mail. There are also two documents

regarding the talent recruitment project. Please

replace the sensitive words as follows: Project one:

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SPECIAL AGENT BRADLEY HULL -- DIRECT 148

Jzyjj -- carrier based aircraft early warning

aircraft, bbdw -- eight eight unit, zzbb -- General

Armaments Department; Project 2: dxy -- excuse me --

Dxjyysj -- large scale military transport aircraft.

The rest of the -- keywords -- will be replaced in the

same manner. The reviewing expert for both projects

will be Cheng Puqiang."

Q Could you spell that?

A C-H-E-N-G, second name is P-U-Q-I-A-N-G.

Q Thank you. If you could continue with the next

message?

A "Please print the documents for talent recruitment

project single sided."

"Three copies for each project and please stamp the

third page."

"If Chairman Liu is not available in the afternoon,

please hand it directly to Lin Yiguang from the

Ministry of Science and Technology. Thanks."

"I just called Chair Liu."

Q And there's a response message saying, "got it." And

then if you could read one more message, please?

A "Institution Chair Liu, my address is: Sixth Division

of Jiangsu Ministry of State Security, Xu Yanjun.

Thanks."

Q All right. Thank you, Agent Hull.

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SPECIAL AGENT BRADLEY HULL -- DIRECT 149

MR. MANGAN: And then if we could turn to page five

of that exhibits?

(Government's Exhibit 41b page five was shown on the screen

for Jury.)

BY MR. MANGAN:

Q Do you see two more messages from Renjun Sun?

A I do.

Q And those are dated March 24, 2015; correct?

A Yes.

Q And the message at the top does it read:

"Section Chief Xu, the relevant materials have been

sent to your E-Mail address. Within it, J means

flight deck, L means payload, Q means international

collaboration, B means land-base, F means flight

vehicle, K means aviation, C means design model, and D

means landing gear.

A and Q are the names for our flights. Contact me if

you need explanation on anything?"

"Do not hesitate."

Do you see that?

A I do. With the exception of you said Q and I think

you meant G in the second line.

Q Okay. I apologize. Hopefully the Jury caught it.

Thank you. Before we move on from this exhibit, I'd like to

go back just briefly to the page before at the very top.

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SPECIAL AGENT BRADLEY HULL -- DIRECT 150

(Government's Exhibit 41b page four was shown on the screen

for Jury.)

BY MR. MANGAN:

Q To that message from December 17, 2014, do you see

that, Agent Hull?

A I do.

Q And did you see other messages that contained codes

like this?

A Yes.

Q I think previously we were talking about one of Mr.

Xu's associates named Li Guozhi?

A We were.

Q And we introduced some of the messages between the two

of them?

A We did.

Q Did you find a similar message around the same time

from Mr. Guozhi?

A Yes.

MR. MANGAN: If we could go back to Exhibit 40b,

page seven. I believe it's already admitted, Your Honor?

THE COURT: Yes.

MR. MANGAN: May we publish?

THE COURT: Yes.

(Government's Exhibit 40b page seven was shown on the screen

for Jury.)

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SPECIAL AGENT BRADLEY HULL -- DIRECT 151

MR. MANGAN: If we can go to the very bottom?

BY MR. MANGAN:

Q Do you see the message from Mr. Li Guozhi to Xu?

A Yes.

MR. MANGAN: And if we can zoom in on the very

bottom?

BY MR. MANGAN:

Q Can you read the date of that message?

A December 17, 2014.

Q And can you read the content of the message, please?

A "Project 1:jzyjj-carrier-based airborne early warning

aircraft, bbdw- eight eight unit, zzbb- General

Armaments Department; Project 2:dxjyysj- large scale

military transport aircraft. The rest are the same as

above. The top right corner of the cover page shall

be Secret. Change the reviewing expert and the person

in charge for the project --"

MR. MANGAN: Could we turn to the next page?

THE WITNESS: Sorry.

(Government's Exhibit 40b page eight was shown on the screen

for Jury.)

BY MR. MANGAN:

Q Thank you. Please continue.

A "-- reviewing expert and the person in charge for the

project on the third page to Cheng Puqiang."

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SPECIAL AGENT BRADLEY HULL -- DIRECT 152

Q And then was that the message that Mr. Xu relayed to

Sun Renjun?

A Yes.

Q All right. Thank you. I'd like to have you take --

MR. MANGAN: If we could show the witness

Exhibit 42a and b?

THE COURT: Yes.

(Government's Exhibits 42a and 42b marked.)

(Government's Exhibit 42a shown on the screen for the Court

and Witness.)

BY MR. MANGAN:

Q Do you recognize these, Agent Hull?

A I do.

Q And can you identify what they are?

A They are UFED Extraction Report of 31 SMS text

messages between the Defendant Xu Yanjun and an individual

with the name of Guangqing He, and I'll spell it,

G-U-A-N-G-Q-I-N-G. The second name, H-E.

Q All right.

MR. MANGAN: Your Honor, we'd move to admit

Exhibits 42a and b?

MR. McBRIDE: No objection.

THE COURT: Admitted.

(Government's Exhibits 42a and 42b admitted.)

MR. MANGAN: May we publish 42b?

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SPECIAL AGENT BRADLEY HULL -- DIRECT 153

THE COURT: Yes.

(Government's Exhibit 42b was shown on the screen for Jury.)

BY MR. MANGAN:

Q And in looking at these messages, once, again, Agent

Hull, can you remind us where these messages came from?

A From the iCloud data from Google for the iPhone 5s.

Q The very top message, do you see where it says:

"Hello Manager Xu. This is He Guangqing from Hunan

Tyen?"

Do you see that?

A I do.

Q Do you know what that company is?

A It is a aircraft component manufacturer.

Q And where are they based?

A In China.

Q All right. I'd like to start further down actually to

just read through the messages here.

MR. MANGAN: If we could go to the bottom of page

one?

(Government's Exhibit 42b page one was shown on the screen

for Jury.)

BY MR. MANGAN:

Q Do you see a message starting with Director He, I've

modified the report?

A Yes.

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SPECIAL AGENT BRADLEY HULL -- DIRECT 154

Q All right. If we can start there, and I will read the

responses from the Director.

A "Director He, I've modified the report, I will send to

you tomorrow morning."

Q "Okay, thanks."

A "Thank you instead."

Q "We are brothers, don't be so formal. Haha."

A "Bro, the document is sent. Please check. The "xxx"

in the document means "State Security Department.""

"The "lower case y upper case Y Y" means "diesel

engine VNT turbocharging technology.""

MR. MANGAN: If we can turn to the next page?

(Government's Exhibit 42b page two was shown on the screen

for Jury.)

BY MR. MANGAN:

Q And if you could continue reading the messages,

please?

A "The tsqd means "special channel."

"Also, this document is urgent, please send it to the

group as soon as possible. Thanks. Xu Yanjun."

Q "Okay. Thanks."

A "Document is sent. Please check. The "zzz" means

"variable nozzle turbocharging." The "if" means

"Honeywell." Thanks. Xu."

"The "xxx" means "State Security Department.""

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SPECIAL AGENT BRADLEY HULL -- DIRECT 155

Q "Okay. Thanks."

A "Tell Staff Han from the Group that this document will

need the Group to affix the Group seal. Also, tell

her that the document from yesterday was from the 5th

Bureau of the Ministry and documents from today is

from the 6th Bureau of the Ministry. Thanks."

Q All right. Thank you, Agent Hull. In these last

few exhibits we've gone through, are these examples of the

types of codes that you saw being exchanged in these

messages?

A Yes.

Q All right. And did they sometimes correlate with the

various exchanges you saw on the calendar?

A They did.

MR. MANGAN: Your Honor, this would be probably the

right time that we discussed.

THE COURT: Very well. We're going to take an

afternoon break. We'll call it 3:30. I'm going to ask the

Jury to take a break for 30 minutes. We'll come get you at

4 o'clock.

During the break, take a break. Don't discuss the

case with anyone, even among yourselves. No independent

research. Continue to keep an open mind, and we'll rise in

respect as you leave.

COURTROOM DEPUTY: All rise for the Jury.

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SPECIAL AGENT BRADLEY HULL -- DIRECT 156

(Jury exited the Courtroom.)

THE COURT: The Jury has a left the courtroom, and

the door is closing. The Jury's going to be on break for

30 minutes. I'd like the lawyers and parties to be back in

15 minutes, so that I can address the lawyer's arguments as

to authenticity. I'd like the Defendant back in 15 minutes

as well at quarter of four.

Is there anything that requires my attention before

we adjourn for 15 minutes and a half hour outside the

presence of the Jury for the Government?

MR. MANGAN: No, Your Honor.

THE COURT: Defense?

MR. McBRIDE: No, Your Honor.

THE COURT: See you in 15 minutes. Thank you.

COURTROOM DEPUTY: This Court is in recess for

15 minutes.

(Court was in recess at 3:28 p.m. and resumed at 3:45 p.m.)

COURTROOM DEPUTY: All rise. This Court is in

session pursuant to the recess.

THE COURT: Thank you. Please be seated. Would

you please close the door, please?

We're back in the open courtroom on the record

outside the presence of the Jury. Government team is here.

Defense team is here. The Defendant and both interpreters.

I wish to address the objection as to authenticity

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SPECIAL AGENT BRADLEY HULL -- DIRECT 157

of E-Mails. The Defendant challenges the authenticity of

the content from two E-Mail accounts that the Government

intends to present as evidence.

Specifically Defendant argues that the evidence

suggests that multiple people may have had access to the

E-Mail account; and, therefore, there is sufficient evidence

to authenticate the authorship of the E-Mail content.

I believe initially the objection was as to

messages from the iCloud account as well, but the Defense

has elected to withdraw the objection as to the iCloud

messages.

Mr. McBride, is all of that accurate from the

Defense's perspective?

MR. McBRIDE: Yes, Your Honor.

THE COURT: All right. I'd like to establish the

case law and then pause. I believe the accounts at issue

are two of the three JAST accounts, J-A-S-T, and that the

jastburton account, J-A-S-T-B-U-R-T-O-N, account is not at

issue because there will be witness authentication; is that

right, Counsel?

MR. McBRIDE: Yes, Your Honor.

THE COURT: Very well. Let's get to the law.

Federal Rule of Evidence 901(a) provides that, quote, to

satisfy the requirement of authenticating or identifying an

item of evidence, the proponent must produce evidence

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SPECIAL AGENT BRADLEY HULL -- DIRECT 158

sufficient to support a finding that the item is what the

proponent claims it is, end quote.

New quote, authentication is a relatively low

hurdle and may be proved through a variety of methods,

including circumstantial evidence, end quote. From U.S.

versus Quintana, Q-U-I-N-T-A-N-A, 763 Federal Appendix 422,

426 6th Circuit 2019.

Further quote, the authentication -- bracket,

authentication, bracket, rule requires only that the Court

admit evidence if sufficient proof has been introduced so

that a reasonable Juror could find in favor of authenticity

or identification. The rest is up to the Jury, end quote.

U.S. versus Jones, 107 F.3d 1147, comma, 1150, Note one, 6th

Circuit 1997.

Rule 901(b) provides a non-exhaustive list of the

types of evidence that may be presented to satisfy

authentication.

As an initial matter, authenticity may be

established by the trial testimony of a witness with

knowledge, e.g., the sender or recipient of the E-Mail, or

someone who saw the author compose the E-Mail. Fed Rule

Evidence 901(b)(1).

Additionally, under Rule 901(b)(4), the proponent

may authenticate evidence by offering evidence of, quote,

the appearance, contents, substance, internal patterns, or

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SPECIAL AGENT BRADLEY HULL -- DIRECT 159

other distinct characteristics of the item taken together

with all the circumstances, period, end quote.

With regard to E-Mails and electronic

communications in particular, courts have looked to a number

of factors to support a finding of authenticity based on

circumstantial evidence.

For example, the Court may consider, among other

things, whether:

One, the purported author's name is in the E-Mail

address;

Two, the content of the E-Mail or message shows

knowledge that the purported sender would possess;

Three, the purported sender's name was used to sign

off on the E-Mails or messages;

Four, the IP address matches the purported sender's

known location;

Five, the E-Mail address or telephone number from

which the messages were sent are linked to other accounts

belonging to the purported sender;

Six, the E-Mail account is linked to a phone number

or physical address belonging to the purported sender;

And, seven, the account is found on or otherwise

linked to a device in the purported sender's possession.

See, e.g., United States versus Fluker, F-L-U-K-E-R, 698

F.3d 988, coma, 999-1000 7th Circuit 2012, where E-Mail

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SPECIAL AGENT BRADLEY HULL -- DIRECT 160

authorship authenticated by showing that the purported

sender's name was part of the E-Mail address and the content

of the E-Mails demonstrated knowledge that few others than

the purported sender would possess.

See further, United States versus Siddiqui,

S-I-D-D-I-Q-U-I, 235 F.3d 1318, comma, 1322-23, 11th Circuit

2000, where authentication was permitted by showing the

E-Mail address included the purported sender's name; content

of the E-Mail showed specific knowledge that would have only

been known by few people other than the purported senders;

and the E-Mails were signed off with the name Mo, which was

the purported sender's known nickname.

Similar cases where I won't read the parentheticals

are U.S. versus Lewisbey, L-E-W-I-S-B-E-Y, out of the 7th

Circuit; U.S. versus Simpson, out of the 10th Circuit; U.S.

versus Lundy, L-U-N-D-Y, out of the 5th Circuit.

Here this Court has already seen a number of

exhibits that speak to the authentication factors. For

instance, Exhibit 18 shows how the two JAST E-Mails connect

back to Defendant's others accounts, and also connects the

alias Qu Hui, spelled Q-U, capital H-U-I, which connects the

alias to the Defendant.

Exhibits 32c and 32d link the jastxyj E-Mail

directly to Defendant, where he identifies himself by name

and gives jastxyj as his E-Mail.

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SPECIAL AGENT BRADLEY HULL -- DIRECT 161

Exhibit 7a shows that the jastquhui,

J-A-S-T-Q-U-H-U-I, E-Mail is the Apple ID E-Mail connected

to the iPhone that was in Defendant's physical possession

when he was arrested.

Additionally, the JAST E-Mail addresses at issue

contain Defendant's initials or alias; and as I just

identified, that alias is connected to Defendant through use

on Defendant's other accounts.

Additionally, the account information such as name,

recovery E-Mail, and associated telephone number are either

the same across the disputed accounts or are the same as

Defendant's information from other known accounts and also

match information linked to the phone confiscated from the

Defendant at the time of his arrest.

Court notes that the Government has acknowledged

that the IP addresses associated with activities on these

accounts do, at times, indicate locations inconsistent with

Defendant's known whereabouts or otherwise indicating

multiple locations but whether this means that anyone else

was using the accounts is a question for the Jury to decide.

In short, it appears the Government has met its

burden as to authentication, which is a relatively low bar.

Does the Government wish to be heard further in

argument?

MR. MANGAN: No, Your Honor. We have additional

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SPECIAL AGENT BRADLEY HULL -- DIRECT 162

items we can present, but we agree with the Court's

analysis.

THE COURT: Does the Defendant wish to be heard

further?

MR. McBRIDE: I do, Your Honor. I'll try to be

brief. Thank you for recognizing the Government's admission

with regard to the facts that there may be other users to

these accounts.

Your Honor, in that letter from Mr. Mangan, they

provided us with an enormous set of data ranging from 2013

to the date of -- past actually the date of Mr. Xu's arrest.

Bear with me. Let me pull my notes out here, Judge.

THE COURT: Yes.

MR. McBRIDE: So the jastquhui -- pardon me. Let

me start with the jastxyj, Judge. There are approximately

55 times that the account was accessed after Mr. Xu was

arrested.

There are a number of domain names, ChinaNet

Jiangsu April 2nd, Berlin Services -- or Service Providers

on April 3, then we are back the Jiangsu Province on April 4

and April 14. We're now at the China Unicom Jiangsu

Province Network, and those dates are the 24th of April, and

then we have also -- we're back to China Mobile

Communications on April 3rd -- pardon me, April 3rd --

pardon me, May -- April 3rd twice and then the 5th. And

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SPECIAL AGENT BRADLEY HULL -- DIRECT 163

then on the -- let me back up on that.

So what we have, Judge, is access to that JAST

E-Mail. I'd like to point out to you -- and I've got copies

of this, Judge, if it would be helpful?

THE COURT: I'm okay.

MR. McBRIDE: The I -- or the IP address, Judge,

is when a device goes and reaches out to the Internet. What

it does, essentially a router assigns the IP address. You

cannot identify what address or what device or who is using

the device by an IP address.

All you can get is a general location where the

device tried to access the Internet because you get the

domain basically. It's where the router is.

So what we have in this circumstance is the

E-Mails -- some of which may be Mr. Xu's -- but the

Government can't establish which ones are Mr. Xu's because

we have admissions of access. The phone's being accessed

after the fact.

When we get to each E-Mail the Government wants to

put in, they have no basis into which to say this E-Mail is

Mr. Xu's; and while I recognize what the Court has said so

far, I'd like to refer you to, Your Honor, U.S. v Shah, 125

Fed Supp 350 at page 576. In addressing the same issue,

where we have essentially blind E-Mails -- for instance, let

me explain this.

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SPECIAL AGENT BRADLEY HULL -- DIRECT 164

I have an E-Mail account in my office. My legal

assistant can access that and send an E-Mail to somebody as

though it were my name, so it's a blind address.

In other words, they don't know really that it's

myself sending the E-Mail, though they might think they

have.

And the Shah court said this: The Government may

not rely exclusively on the Defendant's prior use of an

E-Mail address -- I'll skip the name, Judge -- to

authenticate the documents. Both E-Mail and electronic

chats are faceless means of communications where users are

identified by E-Mail address or username. The recipient

cannot simply by looking at the E-Mail address of the

username, pardon me, in the contents --

THE COURT: Slow down, please.

MR. McBRIDE: I'm sorry, Judge. I forgot.

THE COURT: It's not for me.

MR. McBRIDE: -- readily identified the true

identity of the message's sender.

It goes on, the recipient can't -- in neither case

can the recipient rely on the use of an E-Mail address or

username to conclude the third party has not made

serendipitous use of the otherwise familiar account.

Instead, the recipient must use additional

information gleaned from the context, for example, the

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SPECIAL AGENT BRADLEY HULL -- DIRECT 165

knowledge the communication was prompted by the recipient or

the contact -- factors that you were talking about, Your

Honor.

So with regard to these E-Mails coming from Mr. Xu,

the Government's going to have to show that the content of

the E-Mail in and of itself represents -- provides the Court

with an understanding that this is coming from Mr. Xu.

Moving to jastquhui, we have the same situation,

Judge. We got about 55 times the accounts were accessing to

the Internet after Mr. Xu was arrested from a variety of IP

addresses with several locations, Judge.

There's also examples within the E-Mails that the

Government was actually referring to where you have people

who -- you have E-Mail access points where somebody is in

America in one moment, and the next minute it's being

accessed from China.

So that in and of itself, Your Honor -- and I could

dig that cite out for you -- shows that there are obviously

more than one person accessing these accounts.

So in order to show that Mr. Xu -- I understand

it's a low bar -- that Mr. Xu was sending these accounts, I

think the Government has to show more than -- pardon me --

just attaching it to the subscriber information.

Anybody can go in and setup an account under

anybody's name with anybody's phone number to establish the

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SPECIAL AGENT BRADLEY HULL -- DIRECT 166

subscriber account; and here we have allegations from the

Government that we have a conspiracy of spies; and part of

what they're saying to you, Your Honor, is, well, they're

all using each other's E-Mail address. They're all using

aliases. Then they turnaround and say, well, we want to

authenticate this document because it's got some indicia of

Xu Yanjun's identity on it, so I submit, Your Honor, that

they can't make their burden in this particular situation by

just showing you there are some connections. I think -- I'd

ask the Court to look to the content.

THE COURT: Very well. Thank you. Have you been

fully heard?

MR. McBRIDE: I have, Your Honor. Thank you.

THE COURT: All right. The Defense will have the

opportunity to raise the inconsistent IP address issues for

the Jury, but an additional user is not the only

explanation; and therefore, it cannot and does not undermine

the Government's evidence as to authenticity.

The bar is low for authenticity, and the Court

finds that the Government has met its burden. Frankly, far

be it beyond the low bar.

Accordingly, Defendant's objection is overruled.

Based on the appearance, content, and distinct

characteristics of the E-Mails, Court makes a preliminary

finding under Federal Rule of Evidence 104, that the

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SPECIAL AGENT BRADLEY HULL -- DIRECT 167

exhibits are authentic, i.e., they are what the Government

claims them to be.

So I've heard argument and ruled on authenticity as

to E-Mails. It's on the record.

Are we ready to get the Jury for another half hour

from the Government's perspective?

MR. MANGAN: Yes, Your Honor.

THE COURT: Is there anything else before we get

them?

MR. MANGAN: Not from me, Your Honor. No.

THE COURT: Are we ready for the Jury, Mr. McBride?

MR. McBRIDE: We are, Your Honor.

THE COURT: Very well. Let's call for the Jury.

And while we're getting them, a translator was onboard for

that. I don't want to wear her out. Ms. Frankian, what

time do you propose that we adjourn from this witness given

the translator's fatigue?

MS. FRANKIAN: 4:20.

THE COURT: 4:20, so we've got 15 minutes, Mr.

Mangan, and you're not allowed to speak fast.

MR. MANGAN: I understand.

THE COURT: Very well.

COURTROOM DEPUTY: All rise for the Jury.

(Jury entered the Courtroom.)

THE COURT: Jury's arrived. You may all be seated.

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SPECIAL AGENT BRADLEY HULL -- DIRECT 168

All 15 members of the Jury, welcome back. Witness is on

the stand, remains under oath, and he understands, correct,

sir?

THE WITNESS: Yes, sir.

THE COURT: Mr. Mangan, you may proceed.

MR. MANGAN: Thank you, Your Honor.

BY MR. MANGAN:

Q All right. Agent Hull, previously we discussed the

idea of exchanges. I'd like to talk about one example. Are

you familiar with the name Bin Liang, spelled B-I-N,

L-I-A-N-G?

A I am.

MR. MANGAN: And could we have the witness look at

Exhibits 43a and b?

THE COURT: Yes.

(Government's Exhibits 43a and 43b marked.)

(Government's Exhibits 43a and 43b shown on the screen for

the Court and Witness.)

BY MR. MANGAN:

Q When you get those, Agent Hull, can you tell us if you

recognize what they are?

A Yes.

Q Can you explain what they are?

A It is an E-Mail from the E-Mail address

jastxyj@gmail.com with an attachment benjamin.liang.doc in

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SPECIAL AGENT BRADLEY HULL -- DIRECT 169

Mandarin Chinese on 43a, and 43B is the English translation

of the, of the same.

MR. MANGAN: Your Honor, we'd move to admit

Exhibits 43a and b?

MR. McBRIDE: No objection, Your Honor.

THE COURT: Admitted.

(Government's Exhibits 43a and 43b admitted.)

MR. MANGAN: If we may publish 43B?

THE COURT: Yes.

(Government's Exhibit 43b was shown on the screen for Jury.)

BY MR. MANGAN:

Q Looking at the very bottom, Agent Hull, do you see

where an E-Mail starts at the bottom of that page?

A I do.

Q All right. One moment. Okay. And who is the E-Mail

from? What address?

A jastxyj@gmail.com.

Q And what is the date?

A December the 15th, 2013.

Q Okay. And can you read the content of the E-Mail?

A "Institution Director Liu, how are you? Please find

the expert's bio attached for the exchange next week."

Q And then what is the name of the attachment?

A Benjamin underscore Liang, L-I-A-N-G, dot doc.

Q And the name Institution Director Liu, is that the

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SPECIAL AGENT BRADLEY HULL -- DIRECT 170

same name we saw previously with the AVIC messages?

A Yes, it is.

Q And if you can look to the next page, can you identify

based on the resume -- we don't have to turn to it -- but

where was Mr. Liang working at that time?

A Fokker, which is an aviation company.

Q Could you spell that?

A F-O-K-K-E-R.

Q All right. And did you say they're an aviation

company?

A They are. They're located in the state of Washington.

Q All right. If you could then turn --

MR. MANGAN: We'll take those down.

(Government's Exhibits 43c and 43d marked.)

(Government's Exhibits 43c and 43d shown on the screen for

the Court and Witness.)

BY MR. MANGAN:

Q If you could look at Exhibits 43c and d. When you

have those, could you explain what those are?

A 43c are E-Mails between E-Mail account

bingofishing@163.com and the E-Mail account

jastquhui@gmail.com.

43c is the original Mandarin, and 43d is the English

translation of the same.

MR. MANGAN: Your Honor, we'd move to admit

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SPECIAL AGENT BRADLEY HULL -- DIRECT 171

Exhibits 43c and d?

MR. McBRIDE: No objection, Your Honor.

THE COURT: Admitted.

(Government's Exhibits 43c and 43d admitted.)

MR. MANGAN: May we publish 43d?

THE COURT: Yes.

(Government's Exhibit 43d was shown on the screen for Jury.)

BY MR. MANGAN:

Q All right. In looking at these E-Mails, I just want

to start at the bottom of page one. We'll just read a

couple selections from these E-Mails.

At the bottom what is the date of that E-Mail, Agent

Hull?

A September the 18 of 2013.

Q And is it addressed to Mr. Liang?

A It is.

Q And if you could read the second paragraph, starting

with "regarding"?

A "Regarding the invitation via phone last time for you

to give lectures in China, I sincerely hoping you can

make the trip this year.

We have already confirmed this with scientific

research units in China and is only pending your

return to China. So before you return for China,

please let me know so that I can make all the

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SPECIAL AGENT BRADLEY HULL -- DIRECT 172

arrangements for you. Thanks. Again, wishing you

well, Qu Hui."

MR. MANGAN: And could we turn to page two?

(Government's Exhibit 43d page two was shown on the screen

for Jury.)

BY MR. MANGAN:

Q Do you see an E-Mail at the top dated October 21,

2013?

A I do.

Q All right. And if you could just read the paragraph

starting with:

"After speaking with you on the phone last time?"

A "After speaking with you on the phone last time, I

contacted the research institute in Xi'an -- which is

spelled X-I apostrophe A-N. They looked at your

resume, and they thought your engineering experience

would be very helpful to their current project. You

may resolve some of the challenging issues if we can

have some exchanges and discussions. That says, I

applied a specific project expense from the PRC State

Administration of Foreign Expert Affairs for you to

return to China for the exchange.

In addition, I have been in contact with you for so

long, I would like this to work out, both to satisfy

you and to help China. Thanks. Qu Hui."

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SPECIAL AGENT BRADLEY HULL -- DIRECT 173

Q Thank you.

MR. MANGAN: If we could finally turn to page

three?

(Government's Exhibit 43d page three was shown on the screen

for Jury.)

BY MR. MANGAN:

Q Do you see an E-Mail dated November 4, 2013?

A I do.

Q And let's look at the bottom paragraph starting with,

regarding your return to China?

A "Regarding your return to China, since I have already

applied specific expenses for you to exchange early of

this year, which includes your international airfare

and accommodation while in China, if you can make

arrangements, please come back for an exchange.

Xi'an -- X-I, apostrophe A-N -- has looked at your

resume and they are very interested, but since this is

going to be the first time, for long-term

collaboration point of view, they want to further

understand each another.

That says, they ask that if you are able to go to

Xi'an -- X-I apostrophe A-N -- and describe the type

of work you did in the past in detail, especially the

most recent projects, and then the technology you

specialize in. That way, they will be able to

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SPECIAL AGENT BRADLEY HULL -- DIRECT 174

establish a specific direction of action.

I think Xi'an -- X-I apostrophe A-N -- has a good

point of view because the technological collaboration

we hoped for is not superficial, rather, for in-depth

and long-term, which will help the technology

improvement of China. Hope you can do some

preparation for this. Thanks, Qu Hui."

Q And, again, Agent Hull, who was Mr. Liang working for

at this time?

A Fokker.

Q All right. And this is talking about an upcoming

visit in late 2013. Did you also find messages with

Institution Chair Liu regarding this visit?

A Yes.

Q All right. And if you can take a look at Exhibit 43e?

THE COURT: Yes. 43 what?

MR. MANGAN: 43e.

THE COURT: Very well.

(Government's Exhibit 43e marked.)

(Government's Exhibit 43e shown on the screen for the Court

and Witness.)

BY MR. MANGAN:

Q Do you have that?

A I do.

Q Can you identify what this is?

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SPECIAL AGENT BRADLEY HULL -- DIRECT 175

A They are messages -- a mix of E-Mail, WeChat --

regarding the visit from Bin Liang.

MR. MANGAN: All right. Your Honor, we'd move to

admit 43e?

MR. McBRIDE: No objection.

THE COURT: Admitted.

(Government's Exhibit 43e admitted.)

MR. MANGAN: May we publish?

THE COURT: Yes.

(Government's Exhibit 43e was shown on the screen for Jury.)

BY MR. MANGAN:

Q All right. Agent Hull, this is just a one-pager --

which is good given the time of day -- so if we could start

where the black bar is?

MR. MANGAN: If we can zoom in. Thank you, Ms.

Prim.

BY MR. MANGAN:

Q Okay. We'll start after the E-Mails. Do you see a

set of WeChat messages between Xu Yanjun and Liu Chengyu?

A I do.

Q All right. If you could read the pieces that are in

blue that are sent by Mr. Xu, I will read the responses.

A "Institution Chair Liu, we are taking the flight

HU7640 in the afternoon of the 26th. Will be at

Xi'an at 18:20. On the 27th, we will do the

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SPECIAL AGENT BRADLEY HULL -- DIRECT 176

exchange for half day, then take the guest to

visit the Terracotta Army. If you have

additional demands, it is possible to increase

the time for exchange. We will spend the night

in Xi'an on the 27th. Division Director Zha and

I will accompany the guest. Two rooms will be

sufficient."

Q "Okay."

"Booked three single rooms for you guys. The

Room price for are Runtian Hotel is high now.

It's about 780 per night but the standard room

is 680. Let me know if you want single rooms or

standard rooms?"

"Okay."

A "I will share the standard room with Division

Director Zha. The guest can stay in a standard

room as well.

Thanks."

Q "After you landed, the driver will contact you

and take you to Runtian Hotel. Two standard

rooms are booked. You can tell the receptionist

the rooms are booked by Liu Chengyu. You guys

can have dinner by yourselves as I have other

things to work on. We will have the exchange at

the Second Conference room at the hotel at

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SPECIAL AGENT BRADLEY HULL -- DIRECT 177

9:00 a.m?

Manager Yang will treat you guys for lunch. The

driver will then take you guys to visit the

Terracotta Army and then take you guys to Xi'an.

Also the rent for the conference room is 4,000

Yuan, Manager Yang wants to know if you can take

care of it?"

A "Thanks, if you can't take care of the conference

fee, we can take care of it."

Q "Okay. I will confirm that with Manager Yang."

"Is the lecture a foreigner or Chinese?"

"Chinese American; right?"

A "Chinese, no problem speaking Chinese."

"Yes."

Q "Got it. Let me ask Manager Yang to participate

in this. After the exchange in the morning, I

can arrange the ride to visit the Terracotta

Army?"

A "Institution Chair Liu, Division Director Zha has

another unexpected matter and he can't make it.

Little Li from our Division will accompany the

guest instead."

Q "Got it. I will make sure everybody here knows

you are from Nanjing Science and Technology

Association?"

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SPECIAL AGENT BRADLEY HULL -- DIRECT 178

A "Thanks."

"The guest doesn't know our identity. I've

approached him in the name of Hui Qu, the Deputy

Secretary General of the Science and Technology

Association.

Q All right. Agent Hull, do these messages in late

December 2013, correspond with the E-Mails arranging Mr.

Liang's visit?

A Yes, they do.

Q That we discussed in the other E-Mails?

A Yes.

Q I know we didn't read all the E-Mails, but do the

dates correspond?

A Yes, they do.

Q All right. And in the very last line there, where it

mentions the name and that title, is that the same name and

title that you found on the business card?

A Yes, in the home of the GE Aviation engineer.

MR. MANGAN: Thank you. Your Honor, I think this

would be a good time to stop.

THE COURT: Very well. Ladies and gentlemen of the

Jury, we're going to break for the day. I've been watching

you, and I'm enormously grateful on behalf of the court and

the community for the work you are doing.

When you go home tonight, I want you to have a

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179

break. I order you not to discuss the case with anyone,

even among yourselves. No independent research. Something

comes on the news, and it won't, step away and enjoy your

break. We need you back here tomorrow by 9:15 so we can get

you at 9:30.

Out of respect for you, we'll rise as you leave for

the day.

COURTROOM DEPUTY: All rise for the Jury.

(Jury exited the Courtroom.)

THE COURT: Jury's left the courtroom. Door is

closed. Are we ready to adjourn for the day from the

Government's perspective?

MR. MANGAN: No, Your Honor.

THE COURT: No?

MR. MANGAN: I'm sorry. I thought you asked if we

had anything further.

THE COURT: I asked if you're ready to adjourn and

you said no.

MR. MANGAN: Oh. That tells you I'm ready to

adjourn.

THE COURT: Okay. Very well. Is the Defense ready

to adjourn for the day?

MR. McBRIDE: Absolutely, Your Honor.

THE COURT: All right. I don't want the Jury to

see the Defendant in the custody of the Marshals. How can

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180

we accomplish that? They're leaving the courtroom.

MARSHAL: Are they leaving now or --

THE COURT: I don't know. I don't talk to them. I

can't hear you. Should we let them go now, the Marshal and

the Defendant?

MS. FRANKIAN: That's fine.

(Discussion held off the record.)

THE COURT: You'll take the Marshals' elevator.

MARSHAL: We'll clear the hallway, Judge.

THE COURT: Okay. Thanks. The witness will not

discuss his testimony during the break, and he too will

enjoy a break. Thank you. Is that right?

THE WITNESS: (Witness nods head affirmatively.)

THE COURT: Very well. We're in recess.

COURTROOM DEPUTY: This Court is now in recess.

(The trial was recessed at 4:21 p.m.)

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181

CERTIFICATE OF REPORTER

I, Julie Hohenstein, Federal Official Realtime

Court Reporter, in and for the United States District Court

for the Southern District of Ohio, do hereby certify that

pursuant to Section 753, Title 28, United States Code that

the foregoing is a true and correct transcript of the

stenographically reported proceedings held in the

above-entitled matter and that the transcript page format is

in conformance with the regulations of the Judicial

Conference of the United States.

s/Julie Hohenstein December 3, 2021

JULIE HOHENSTEIN, RPR, CRR, RMR

FEDERAL OFFICIAL REALTIME COURT REPORTER

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