Complaint of Lawsuit against Jiang Delivered Following Court Order

On October 18, 2002, individual plaintiffs filed a class action lawsuit in the United States District Court of the Northern District of Illinois, Eastern Division against Jiang Zemin and Falun Gong Control Office (Office 6/10). The Civil Action No. is 02 C 7530. Based on Court Order on October 21, 2002, Defendant Jiang representing himself and the other defendant, Office 6/10, was served with the complaint and court summons by alternate service upon security agents designated by the courts as appropriate substitutes for personal service on October 22, 2002.

Based on Federal Tort Act (5, b, 2, item A), a lawsuit can proceed to the next step only if the complaint is served to the defendant.

On December 13, 2002, a notice of hearing in both Chinese and English was signed by a court clerk, a letter explaining the notice, complaint, summons, and copy of court order allowing the plaintiffs to serve the defendant by alternative service were delivered by FedEx to defendant Jiang's office in Zhongnanhai, the Central Government Office Compound in Beijing, China. The above-mentioned documents were received with signature by Mr. T. Huang at the mailing address of Zhongnanhai at 3:30 p.m. on December 18, 2002.

On January 13, 2003, the judge's oral order recorded in court notes asked plaintiffs to send absence ruling requisition (via FedEx not US postal office) to the defendants based on Federal Tort Act (5, b, 2, item A). On February 14, 2003, FedEx delivered two copies of the absence ruling requisition in English and Chinese translation to defendant Jiang's office in Zhongnanhai, Beijing. A FedEx agent delivered the documents in person and Mr. T. Huang from Zhongnanhai representing defendant Jiang received the documents and signed the receipt at 3:54 p.m. on February 14, 2003. Please see the delivery document, including written verification from FedEx Incorporation and receipt from FedEx.

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