P. 1 (An excerpt of Li Da Liang’s testimony)

o “Q: And had you been jumped-in to the gang at all? Had you been jumped-in to the gang at all before January 24^th?

o A: No.

o Q: And what does jumping-in mean? …

o THE WITNESS: I don’t know how to say it.

o BY MS LLOYD: Q: Okay. Well, to get jumped-in do you have to do anything criminal?

o A: I think so. We have to do something for them,” (People v. Mo Court transcripts p. 75)

P. 2-14 (Mo’s gang affiliation, and relation with the gang members in this case, can be dated back to her 1998 conviction when she began to associate with different gangs).

o In 1998, West Covina Police Department (WCPD) did not report on Mo’s gang affiliation. Their report showed “None stated”. However, Mo told IPD Investigators Larry Montgomery and Tracy Jacobson (in the 2000 case) that she was not Wah Ching, despite being involved in the circle.

§ “TJ (Tracy Jacobson): Are you Wah Ching?

HM (Helen Mo): No, I’m not.

TJ: How did you run with them for so long, so deep and not be?

HM: Um, well, my first boyfriend was in the gang—well, he wasn’t in Wah Ching though but he was in a gang. And that’s when I guess I got involved in the circle and stuff and that’s when I like I got arrested also. …

TJ: Okay, and so—when—you were kind of running around with the U.B. when you got arrested before?

HM: Yeah, I was running around with the U.B. and like some of the Taiwanese like from um, W.C.

TJ: What’s W.C. stand for?

HM: Wah Ching. …

TJ: How—how do you run so tight in their—in their inner circle?

HM: Um—

TJ: Without being part of it? I didn’t think that was possible.

HM: Well, to be part of it you have to like—if it’s a girl, I think you have to get jumped in or something like that. …

TJ: You’re sure this wasn’t part of you getting jumped in—

HM: No.

TJ: --To do this with Eric?

HM: No, huh-uh. I—I want to be from Wah Ching—I mean, I guess you can say like I know people from like the different gangs and stuff but it wasn’t—I didn’t get really –I was involved when I was like 16. Not like in it but I was like associated with them and stuff. And then I didn’t get involved again until I met Sonny, which is like November this year. That’s because before then, I didn’t really go to the cafes ‘cause I guess in Monterey it’s…,” (Interview of Helen Mo by Inv. Montgomery and Inv. Jacobson p. 44).

o Within Mo’s social circle, Mo is familiar with three co-defendants in this case: Yo (Souriyo Banthakounh), Adat (Li Da Liang), and Doug Lim (Lim Cheng), who she knew two years ago in West Covina (Interview with Helen Mo 1/26/00 p. 22 of 43 and Helen Mo’s Interview p. 2). Mo recalled seeing four or five individuals that supposedly “rushed into her house” on the day of the murder. But instead of identifying all four or five individuals, she revealed only two of them: Yo and Adat (Interview with Helen Mo 1/26/00 p. 22-23 of 43). However, in an investigator’s notes, it indicated that two of the four subjects who rushed in the house was “Yo” and “Affa” (Untitled Investigator’s notes from 1-25-00 with bates stamp 001268).

P. 16-20 (The police suspected Mo as being the mastermind of this case. They believed her to be a big sister of the group because of her authority to tell the group to get out. It is believed that with her level of sophistication exhibited during her juvenile years, Mo has the capabilities to lead a group for this type of crime).

o “ML (Mike Li): A lot of people respect him, Sonny is basically a Dai Loh basically right.

HM (Helen Mo): That would give like or would do anything for him. …

ML: Do you have your own group of friends?

HM: Yeah.

ML: Your group of kids that hang out with you?

HM: Uh-huh.

ML: And who are they?

HM: Um, I hang out with Dora, with Daniel, Lee, um, Kong…

ML: Are you kind of like the big sister of the group?

HM: No.

ML: No?

HM: No,” (Helen Mo’s 3rd Interview 2-3-00 1145 hours, p. 94).

o “HM (Helen Mo): I don’t know. I have no idea why they were in our house. I mean, they didn’t do anything, they just—

ML (Mike Li): Helen, you said it yourself.

HM: Uh-huh.

ML: Okay, you told them to get out.

HM: Uh-huh.

ML: Okay, how do you have authority to tell them to get out and they leave?

HM: I don’t know.

ML: Okay, don’t tell me you don’t know, you know, Helen.

HM: No, I only know two of them.

ML: These four kids aren’t gonna go up to your house charging up the garage, going into upstairs, and then say ‘hey’, and then look at you and not say anything and run straight out. …

ML: Okay. On top of it, you’re telling them to get out, and then they get out. What were they there for?

HM: I don’t know,” (Helen Mo’s 3^rd Interview 2-3-00 1145 hours, p. 103).

o “GC (Gary Cain): Well you see, the problem is what you—what comes out of your mouth is ‘I’m telling you the truth.’ The problem is the truth you’re telling us now isn’t the same truth you were pitching 15 minutes ago. So—

ML (Mike Li): You already said 15 minutes ago that (UNINTELLIGBLE)

GC: And whatever you tell us doesn’t mean…so we’re going to go ahead and take you. You want to make a phone call now or not?

HM (Helen Mo): Yeah,” (Helen Mo’s Interview p. 144).

P. 21-30 (The police redacted some important information in relation to Mo when she attempted to contact her old attorney from 1998, Mr. Joseph Borges, to help her contact Dora Sam, a friend of hers).

o “She asked if there was anyway she could not be taken into custody, and I told her that after we had talked to her for about four hours, I saw that nothing new was coming up. She stated, ‘If I tell you everything, will that prevent me from being arrested (This portion of the report was originally redacted)…Officer Li at one point made a statement that now was the time to help herself. I reiterated to Helen Mo that it was important for her to be honest and tell the truth. Li made a statement three other times about helping herself, and I stressed to her each time after that that we only wanted her to tell the truth and be honest. Li also said once that she needed to tell the truth,” (Supplemental Report/187 PC—Homicide p. 13 of 18 with handwritten bates stamp 51) (italics added).

o “She then asked to call a deputy sheriff by the name of Brent Witt whose phone number was in there. …I was later told by Li and Jacobson that Mo had attempted to make contact with Witt but was unable to make contact with him. …at a time when Mo made contact with an attorney by the name of Joseph Borges. …Borges apparently did not wish to assist Mo in any way since he was not currently representing her (This portion of the report was originally redacted)” (Supplemental Report/187 PC—Homicide p. 14 of 18).

§ Dora’s, Mr. Borges’, and Brent Witt’s phone numbers can be found on a case work sheet with bates stamp 001355 with other untitled documents. More information about her calls can also be found on p. 29-30.

P. 31-37 (The police conducted a search at Mo’s house on 2/3/00, over a week after the murder. On that same day, the police interviewed Mo’s parents. Mo’s mother, Amy Sunmo, was able to identify the individuals that came to their house on the day of the murder, but she did not recognize Sonny nor ever heard of his name).

o Police did a search at Mo’s house on 2/3/00. Mo’s parents are Amy Tienchun Sunmo (mother) and Bob Lien Mo (father). On that same day, Officer Li interviewed Amy Sunmo and Bob Mo at Garfield Medical Center. Sunmo told to Officer Li about her whereabouts and activities with her husband on Monday, January 24^th, 2000. According to Sunmo, Helen was still at home when she and her husband left the house at approximately 1130 hours. Helen was not sick that morning and did not go to her required community service at Rio Hondo Courthouse.

o Sunmo later state that when she came home and talked to Helen, “four young kids ran up the stairway from the garage (unintelligible) the living room area. … (unintelligible) Sunmo thought that they attended Mark Kepple High School, and were alarmed that they were there. …,” (Supplemental Report 187 CPC—Homicide p. 1-2 with handwritten bates stamp 94-95).

§ Case documentation have shown that one of the co-defendants, Li Da Liang (aka Adat), used to attend Mark Keppel High School. Additionally, Helen Mo previously stated that she knew Adat, Yo, and Doug two years ago (1998) when she was convicted with her ex-boyfriend, Samuel Chang for a series of crimes.

o “She was then shown a group of photographs of possible associates or persons who Sonny Wong had called in the area of January 24, 2000, and stated she did not recognize any of the persons. She was also shown a picture of Sonny Wong, and she said she did not recognize him. She stated that she did not recognize the name of Sonny. …Amy stated that she had seen Eric at the house approximately 2 to 3 times in the past, but no more than five times,” (Investigative Supplemental 187 CPC—Homicide p. 5 with bates stamp 000341). This portion of the report was redacted. Sunmo was never called to testify in Sonny’s trial, stating that Sonny was not one of the individuals who came to her house on the day of the murder.

P. 39-40 (Mo provided some information regarding the gang members’ common hangout spots, such as crash pads).

o “TJ (Tracy Jacobson): Who do they live—do they live at home with their families?

HM (Helen Mo): I don’t think so.

TJ: Who do you think they live with?

HM: Just whoever, like crash pads, whoever they can—because these kids are—I don’t know. I guess their parents don’t care. …

HM: I mean, I know like Adat’s family, it’s like it’s really bad for him. I—their parents don’t like provide anything and they don’t have clothes or anything so—

LM (Larry Montgomery): Where does his family live, Adat’s?

HM: I’m not sure. I never-- …

“TJ: Are Yo and Adat, are those like gang names or street names or—

HM: Um.

TJ: --what kind of names are those? …

TJ: Okay. They’re not the kind of names that somebody would be born with or—

HM: No, no, huh-uh,” (Helen Mo’s 6^th Interview 2-4-00, p. 7-8).

P. 41 (This is in relation to Mo’s gang affiliation. Because of Mo’s level of sophistication that she displayed in 1998, she was able to obtain the title as a “big sister” or “shot caller,” which allows her to have such authority over the gang members that came to her house on the day of the murder).

o “Q: Do gangs like Wah Ching—do they have what’s called a shot caller?

A: A person who’s organizing, directing –

Q: Right.

A: --the activities?

Q: Yes.

A: Yes.

Q: Okay. And would it be unusual for a woman to be in that role?

A: It does not happen often, but it can happen and does happen,” (Preliminary hearing court transcript p. 234).

P. 43-56 (Mo told the investigators the reasons for people to join gangs. This is contrary to Sonny, who was going to work as a real estate agent and had everything he needed. Committing such crime would not be beneficial for Sonny at all. Additionally, Mo stated that the youngsters are usually more dedicated to the gang. If Sonny was a part of the gang, wouldn’t the youngsters feel more obligated to protect their member? Instead, the youngsters and the rest of the gang members all incriminate Sonny in this case).

o “HM (Helen Mo): They’re just—there’s people—I guess kids join gangs for two reasons. And one is like oh, I want to be cool, and um, you know, I have backup.

TJ (Tracy Jacobson): Uh-huh.

HM: And the second reason is just because their family—they have, they get no love from their family.

TJ: Uh-huh.

HM: --and they turn to the gangs. And these kids are the ones that they have no love from their family.

TJ: Uh-huh.

HM: And their only way, I guess of survival, that they know of, is to join the gangs. …So they’re very different from the other kids, which are more prevalent. I mean, these kids, they don’t do anything.

TJ: They’re more dedicated to the gang?

HM: Yeah. …They would really do anything for their gang,” (Interview of Helen Mo by Inv. Montgomery and Inv. Jacobson p. 13).

o 8134 E. Tang, Fay J.: 3-99 Repo.

4Y68838 90 Dodge Truck Wht.

§ This information was found on 2/1/00 (Untitled document, with bates stamp 001282).

§ It is believed that this subject is the same “Fay” in Mo’s 1998 conviction (Please see p. 46-47 for more information about Fay).

§ Around October of 1998, Mo was arrested for stealing a Honda Accord, even though she said it was Fay who stole the car. Detectives from West Covina Police Department (WCPD) spoke to Jen-Tu Liu regarding a transaction between him and a female Asian who purchased some rims and tires on or about 8-14-1998 (Please see p. 52-56).

o Investigators had also obtained information about Pocket (“Michael,” “Quang Minh Lam”) earlier on in their investigation (Untitled document with bates stamp 001276), but they didn’t interview him until June 2000. Mo had mentioned a subject named “Pocket” in her interviews when the investigators asked about the stolen jewelries. Mo told the investigators that the youngsters had probably given the jewelries to their Dai Lo (Chinese word for “big brother”) who is Pocket.

P. 58-60 (Leang Tea’s (Cheng Lim’s brother) statement)

o “On the evening of 2/10/00 at approximately 7:30 p.m., contact was made at the South Second address with Irvine Police Department personnel, Probation Officer Kuk and some personnel from Alhambra Police Department. The residents, who included Liu’s parents and brother, Leang Ivy Tea, were contacted and interviewed separately.

During a search of the house, numerous items were taken from the residence for possible evidence in this case. Included in the items taken were a roll of duct tape that had been located outside a hallway adjacent to the bedroom occupied by Cheng Lim and his brother, Leang Tea, for possible comparison to the strand makeup of the duct tape located on the victim. In the bedroom shared by Cheng Lim and Leang Tea, was a small knife that was taken as evidence to see if it had any blood residue on it. …Leang Tea stated that his brother, Cheng Lim, likes to collect Zippo lighters and that at one time a short time ago, had as many as six Zippo lighters in his possession,” (Investigative Supplemental 187 CPC—Homicide p. 1 with bates stamp 000315).

o “Leang Tea was asked about Sonny Wong and was shown a picture of Sonny Wong. Leang Tea recognized Sonny and stated that he had seen him quite often around his brother, although he hasn’t seen him in approximately six months. The last time he had seen Sonny Wong was when the family had lived on Casanova Street in L.A. Sonny and his brother Cheng Lim had been good friends in the past. Leang Tea stated that his brother now has a shaved head. Leang Tea stated that his brother does run with the Wah Ching gang and that his brother’s and all of his friends have dragon tattoos on them, which is consistent with members of the Wah Ching gang. …Leang Tea was then asked about a subject known as ‘Adat.’ Leang Tea stated that he was familiar with this subject and that his build is very similar to that of his brother’s. …” (Investigative Supplemental 187 CPC—Homicide p. 2 with bates stamp 000316).

§ These portions of the report were redacted.

P. 61-70 (Information about Cheng Lim’s past convictions)

P. 71-74 (Information about Ken Vay Luong, leader of Kenside, and the factions of Wah Ching).

o John S. Gordon article about the federal indictment of 11 members of the Wah Ching gang for racketeering charges.

§ On 1/23/02, a federal grand jury in Los Angeles indicted 11 people who are leaders and members of the Wah Ching gang. The indictment included the following Dai-Los:

· Kien Vay Luong, who controlled “Kenside”

· Paul Cho Liu, who controlled “Paulside”

· John Sun, who controlled “T-side”

· Wai Yin Chu, who controlled “Sonnyside”

§ Kien Vay Luong is also the same subject that District Attorney Investigator Carol Mona interviewed on 5/27/01. Luong was the manager of “Happy Fashion Clothing Manufacturing Company” and recalled Cheng Lim as a worker at the company Lim had also been previously affiliated with Luong in his past conviction.

P. 75-88, 98 (Continuation of Cheng Lim’s past convictions)

P. 89-97 (Zippo lighter results found at Cheng Lim’s residence)

o Forensics conducted an examination of the Zippo lighters that were obtained at Lim’s residence. Results showed that “the lighter from the burned vehicle was charred, and the following manufacturer’s information was located on the bottom: K Zippo® XII, Bradford, PA., MADE IN U.S.A.” The other two lighters had the following manufacture information on the bottom of the two lighters: K Zippo® XV, Bradford, PA., MADE IN U.S.A. It was determined that “the lighter from the burned vehicle was the same approximate size and shape as the two lighters submitted by Irvine PD,” (Orange County Sheriff—Coroner Department Forensic Science Services—Criminalistics: Report of Evidence Examination with bates stamp 000832).

o Please view “Declaration IV of Sergio A. Robleto” for further information about the Cheng Lim and the Zippo lighters.

P. 99 (An excerpt of Mo’s taped conversation with her mother, Amy Sunmo).

o Throughout Mo’s interview, Mo was deceptive on her narrative. She did not really reveal the individuals that were involved in the case. Mo’s mother, Amy Sunmo, was aware of what happened on the day of the murder and told Helen to tell the truth.

P. 100-101 (Visitor History of Cheng Lim)

§ This history included Quang Lam (“Michael” and “Pocket”) and Chi Quan (“Johnny Quan) as visitors for Cheng Lim. It is believed that these individuals are Wah Ching gang associates of Cheng Lim. As indicated by Leang Tea, Johnny’s house is a common place for Wah Ching gang associates to hang out. It is believed that Johnny’s house is a crash pad for the gang.

P. 102 (Field Interrogation card of Cheng Lim)

P. 103-110 (Interview of Chi Keung Liang and Johnny Quan by Inv. Sergio Robleto. The interviews were in relation to Li Da Liang (Adat)).

o Inv. Sergio Robleto interviewed Li Da Liang’s (Adat) father, Chi Keung Liang, during his post-conviction investigation. Mr. Liang stated that it was a subject name “Ben” that picked up his son on the day of the murder to go eat. Mr. Liang made it clear that it was not Sonny who picked his son up. He added that his son’s best friend was a person named Johnny, who he believes to be a member of a “good” group. When the police were after his son (Adat) and he could no longer run away, his son’s friends urged him to turn himself in. Adat asked Johnny to help him. Johnny was point person who contacted the police to arrange the dinner meeting. The police narrative about the dinner meeting can be seen on p. 109. The dinner meeting was at a restaurant and after dinner, the police arrested Adat. Mr. Liang did not know who Sonny was until he went to trial. Mr. Liang was never subpoenaed to Sonny’s trial either.

o Inv. Tracy Jacobson identified “Ben” as Bieu Quoc Ngo (“Westside” and “Billy”), a Wah Ching gang member. Mo made many references of Ngo throughout her interviews, stating that he was one of the youngsters that stole the victim’s jewelries. Bieu was also present at the doughnut shop when the group said, “We fucked up.”

o Inv. Robleto also interviewed Johnny Quan about his knowledge with the case. He initially denied providing any help to the police, but when he was asked about the police being present at Liang’s arrest, he stated, “I think I helped to arrange that.” He recalled the meeting took place at a restaurant called “Noodle World.”

o When the police arrested Liang on 2/28/00, he drew a meat cleaver and put his signature next to it (Untitled document with bates stamp 00429). This signature does not match Liang’s signature on his immunity agreement.