1

UNITED STATES DISTRICT COURT

NORTHERN DISTRICT OF ILLINOIS

ZHU ZHAI HOLDINGS LIMITED )

And PETER PUI TAK LEE,

)

Plaintiffs

) Case No. 2020-CV- 4985

v.

STEVEN IVANKOVICH,

Defendant

)

)

)

Honorable Sharon Johnson Coleman

Special Master Hon. Sidney Schenkier

_____________________./

VERIFICATION

I have am the individual defendant and also the manager of and the person who on behalf of

Pilgrim Windtree LLC, Pilgrim Coulter LLC, Pilgrim Warwick LLC, Alliance HTFL LLC and

Alliance HTTX LLC the ["Pilgrim LLCs"] together with Shanna Willis the Vice President of

Atlas Homes Asset Management compiled the attached list of bank accounts pursuant to the

Special Master Order Number 1 entered on March 19, 20024 [Doc. No. 305]

XX The matters stated in the foregoing document are true to my own knowledge except as to

those matters which are stated on information and belief and identify bank accounts based upon a

diligent search ofthe financial records kept by the "Atlas" entities. I believe them to be true .

Pursuant to the Special Master Order on or about March 19, 2024, I requested Ms. Willis to

search all ofthe financial records ofthe numerous "Atlas" companies and to make a list ofthe

identity of all bank accounts of any entity on which I was an authorized signatory to a bank or

investment account, within the time period set forth in the Order.

Many ofthe identified accounts are not active accounts,. They are identified in the interest offull

transparency.

The list was compiled from the "Atlas" financial records as kept in the ordinary course ofthe

business.

The "Pilgrim" JP Morgan Chase bank accounts were previously produced.

The "Pilgrim" PNC bank statements were previously produced.

Case: 1:20-cv-04985 Document #: 309 Filed: 04/02/24 Page 1 of 3 PageID #:3876
2

It is believed that the identity ofthe Celedon accounts in the names ofthe limited liability

entities were identified and Statements were previously produced.

The Plaintiffs' had in this case issued a citation to Stifel Nicolaus & Company, Incorporated.

Stifel," filed an Answer to Citation Proceeding on March 24, 2022 [oc. No. 153]. The citation

answer identified 14 accounts oflimited liability companies that I, as the Manager ofthose

entities, had signatory authority.

I am the Manager ofintervening LLC and on behalf ofmyselfI am authorized to make this

verification for and on our behalf, and I make this verification for that reason.

Dated March 27, 2024.

Signatures following page:

Case: 1:20-cv-04985 Document #: 309 Filed: 04/02/24 Page 2 of 3 PageID #:3877
3

Pilgrim Windtree LLC.

BY: ,Steven Yankovich

Steven varikvihNRarfager

"iepm cotter t1.c.

By!even lvankovih

Stever tankovirr.Ma z,zz 1..- E 'j

Steven Ivankov1ch Manager

Pieri Warwviet 1..

By teveh lawko

Steen Iantocn (Ma I, 2UH4 L2:I9 EDI)

Steven lvankovich Manager

Alliance HTFL LLC

BY: Seven Wanko vi

St

Steven-rvankovr:_hlMar-271)02f,.l,ll9 EDTl

even IvanKovcn, Iv1anager

Alliance HTTXLLC

Bf@even Wankovik

Stever#"TV4Hk6vie#;'lanager

Seven lakovi

Sc en Hanko ch {#4ar 27, 2024 12;'9 EDI)

Steven lvankovich Individually

Case: 1:20-cv-04985 Document #: 309 Filed: 04/02/24 Page 3 of 3 PageID #:3878