Acknowledgement of Wrongdoing

公开道歉

I, Hai Ming, an attorney duly admitted to practice in the courts of the State of New York, hereby respectfully and sincerely apologize to Attorney Hugh H. Mo, Maria Mo, K.S. Liu, Gina Liu, Winston Sie. and their families and associates for my misconduct against them with respect to the matter of Sang Lan v. AOL Time Warner, Inc., et al. that I filed in U.S. District Court Southern District of New York.

本人海明，是纽约州执业律师，在此向莫虎律师、张燕女士(莫虎夫人)、刘国生先生、谢晓虹女士和薛伟森先生以及他们的亲友致以真诚的道歉，事关本人向纽约南区美国联邦法院所递交的桑兰诉AOL时代华纳等一案的诉状中，因行为不当而触犯上述各位。

I profoundly regret that I have caused severe and irreparable harm to the Lius and Mr. Mo by filing salacious complaints against them that included clearly frivolous claims based upon causes of action that do not exist under New York law or completely fail to allege even the basic elements of the relevant cause of action, including bizarre damage allegations and claims for civil conspiracy, defamation by Mr. Mo, prima facie tort, intentional/negligent infliction of emotional distress, as well as several of the alleged grounds for breach of fiduciary duty.

本人在针对刘国生先生、谢晓虹女士和莫虎律师的诉状中，提出了一些欠缺依据、明显恶意和不符合纽约州法律的控罪，因而造成对他们的严重伤害，对此本人非常后悔。

I am also very sorry for making baseless accusations against the Lius and Mr. Mo on the internet and through the media, including the allegations of sexual abuse, in order to coerce them to settle the lawsuit, which I acknowledge have caused them to suffer personally and publicly.

本人对刘国生先生、谢晓虹女士和莫虎律师在互联网和媒体上作出了失实的指控，包括“性侵”指控，目的在于压迫他们在诉讼上作出退让和解，由此而构成对他们的伤害，本人同样深表歉意。

In view of my serious wrongdoing and misconduct herein, I am grateful to the Lius and Mr. Mo for their generosity to permit me to offer this heartfelt apology (and pay certain monies) in full settlement of thetravesties that I have caused to them.

有鉴于本人的上述严重错误行为和不当做法，刘国生先生、谢晓虹女士和莫虎律师允许本人向他们道歉，并且向他们支付一定金额的补偿，作为双方的完全和解，本人对他们的宽宏大量表示感谢。

For these reasons, I beg them to forgive me.

为此，我恳求他们的饶恕。

civil conspiracy

12: Civil Conspiracy as against K.S. LIU and K.S. GINA HIU-HUNG and Hugh Mo and John Does and Jane Does

defamation by Mr. Mo

11: Defamation against K.S. LIU and K.S. GINA HIU-HUNG and Hugh Mo and John Does and Jane Does

prima facie tort

13: Prima Facie Tort against K.S. LIU and K.S. GINA HIU-HUNG and Hugh Mo and John Does and Jane Does

intentional/negligent infliction of emotional distress

20: Intentional Infliction of Extreme Emotional Distress as against K.S. LIU and K.S.GINA HIU-HUNG and Hugh Mo and John Does and Jane Does #1 through # 15

several of the alleged grounds for breach of fiduciary duty

10: Breach of Fiduciary Duty as against K.S. LIU and K.S. GINA HIU-HUNG and Hugh Mo