(i) Plaintiff (ii) LSMA (iii) 1st (iv) 18th June2019

HCA 1060 I 2019

IN THE HIGH COURT OF THE SPECIAL ADMINISTRATIVE REGION COURT OF FIRST INSTANCE ACTION NO. 1060 OF 2019

BETWEEN

AXA CHINA REGION INSURANCE COMPANY LIMITED Plaintiff

and

PERSONS UNLAWFULLY OCCUPYING OR REMAINING AT 20/F, 1st Defendant TOWER TWO, , 1 MATHESON STREET, , HONG KONG WITHOUT THE PLAINTIFF'S CONSENT AND/OR PERSONS OBSTRUCTING OR HINDERING ACCESS TO AND EXIT FROM THOSE PREMISES AND THE UNITS THEREIN AND/OR PERSONS INTERFERING WITH THE USE OF THOSE PREMISES AND THE WHOLE OF TOWER TWO, TIMES SQUARE BY THE PLAINTIFF, ITS STAFF, SERVANTS, AGENTS, LICENSEES AND LAWFUL VISITORS

PERSONS UNLAWFULLY OCCUPYING OR REMAINING AT 11/F, 2nd Defendant MIRA PLACE TOWER A (FORMERLY AND ALSO KNOWN AS MIRAMAR TOWER), 132 NA THAN ROAD, TSIM SHA TSUI, HONG KONG WITHOUT THE PLAINTIFF'S CONSENT AND/OR PERSONS OBSTRUCTING OR HINDERING ACCESS TO AND EXIT FROM THOSE PREMISES AND UNITS 1101, 1117-1118 THEREIN AND/OR PERSONS INTERFERING WITH THE USE OF THOSE PREMISES AND THE WHOLE OF MIRA PLACE TOWER A BY THE PLAINTIFF, ITS STAFF, SERVANTS, AGENTS, LICENSEES AND LAWFUL VISITORS

PERSONS UNLAWFULLY OCCUPYING OR REMAINING AT 40/F 3rd Defendant AND 42/F, AXA TOWER, 100 HOW MING STREET, KWUN TONG, WITHOUT THE PLAINTIFF'S CONSENT AND/OR PERSONS OBSTRUCTING OR HINDERING ACCESS TO AND EXIT FROM THOSE PREMISES AND THE UNITS THEREIN AND/OR PERSONS INTERFERING WITH THE USE OF THOSE PREMISES AND THE WHOLE OF AXA TOWER BY THE PLAINTIFF, ITS STAFF, SERVANTS, AGENTS, LICENSEES AND LAWFUL VISITORS

535865-4-6329-vl.0 - 1- HK-1000-LDR-18 AFFIRMATION OF LI SIN MAN ALICE

I, Li Sin Man Alice, of 20th Floor, Vertical Sq, 28 Heung Yip Road, Wong Chuk Hang, Hong Kong, solemnly and sincerely affirm as follows:-

1. I am the Head of Corporate and Customer Communications of the Plaintiff and am duly authorised by the Plaintiff to make this Affirmation on their behalf.

2. Unless otherwise indicated, the facts and matters deposed to herein are within my own knowledge, or are derived from documents and information which I have received from the sources identified, and are true to the best of my knowledge, information and belief.

3. I make this affirmation in support of the Plaintiffs application for urgent injunctive relief in respect of the activities of the Defendants on the terms outlined in the draft Order.

Description of the Plaintiff

4. The Plaintiff is and was at all material times a private limited company with its registered office at 20th Floor, Vertical Sq, 28 Heung Yip Road, Wong Chuk Hang, Hong Kong. The Plaintiff is an authorized insurer under the Insurance Ordinance (Cap. 41) and is regulated by the Insurance Authority in Hong Kong. It provides a wide range ofinsurance services, and is part of AXA S.A. which is headquartered in Paris and which is one of the largest insurance companies globally.

The Plaintiff's customer service centres

5. The Plaintiff has three customer service centres in Hong Kong. They are located at (i) Suite 2001, 20/F, Tower Two, Times Square, 1 Matheson Street, Causeway Bay, Hong Kong (the "Times Square Centre"), (ii) Unit 1101, 11/F, Mira Place Tower A, 132 Nathan Road, Tsim Sha Tsui, Kowloon, Hong Kong (the "Mira Place Centre") and (iii) Room 4202, 42/F, AXA Tower, 100 How Ming Street, Kwun Tong, Kowloon (the "AXA Tower Centre") (collectively the "Customer Service Centres"). A copy of the tenancy agreement entered into by the Plaintiff

535865-4-6329-v2.0 - 2- HK-1000-LDR-18 in relation to the office premises of each of the Customer Service Centres is now produced and shown to me marked Exhibit "LSMA-1 ". As shown in the tenancy agreements:

(a) The Times Square Centre is located on a floor which is fully leased by the Plaintiff. The other areas of 20/F of Tower Two, Times Square are used by the Plaintiff as internal offices for agents.

(b) The Mira Place Centre is located on a floor which is not fully leased by the Plaintiff. Other tenants not related to the Plaintiff or its affiliates occupy certain parts of 11/F, Mira Place Tower A.

(c) The AXA Tower Centre is located on a floor which is fully leased by the Plaintiff. The other areas of 42/F of AXA Tower are used by the Plaintiff as internal offices for agents and emloyees.

6. The Customer Service Centres are established for, among other things, providing support services to the Plaintiffs customers, including for example the submission of documents and the collection of policy premiums. They are open usually from 9 am to 5:30 pm on Monday to Friday, and 9 am- 1 pm on Saturday.

The Plaintiffs other office premises

7. In addition to the Customer Service Centres, the Plaintiff also has other office premises in Hong Kong used by its employees and agents. These office premises are generally non-customer facing. Such offices include 40/F of AXA Tower, which is an office used by insurance agents of the Plaintiff.

The present application

8. The present application is made on an ex parte basis as there is genuine urgency in obtaining an injunction against the Defendants before open of business on Monday, 17 June 2019.

9. As will be further explained below, the conduct of the Defendants between 12 to 15 June 2019 at the Customer Service Centres and the agency offices at 40/F and 42/F of AXA Tower has caused significant disturbance and interruption to the Plaintiffs business. Based on the information I have received from the Plaintiffs employees and agents and judging from the Defendants' conduct in the past few days, I verily believe that, in the absence of an urgent injunction, the Defendants

535865-4-6329-v2.0 - 3- HK-1000-LDR-18 will persist with such conduct on Monday, 17 June 2019 when the Plaintiffs business opens, causing further disturbance and interruption to the Plaintiffs business.

10. Of note is that, as a result of the Defendants' conduct over the course of the past few days, the Plaintiff was left with no alternative but to temporarily close down the Customer Support Centres on 15 June 2019.

11. Given that time required for the Plaintiff to gather the requisite evidence and take legal advice on the matter, and for the Plaintiffs legal team to prepare the necessary papers, the application herein is taken out on an urgent basis during a weekend.

The Defendants

12. The pt Defendant, the 2nd Defendant and the 3rd Defendant are groups of people who visited and occupied the Customer Service Centres and the Plaintiffs agency offices without the licence or consent of the Plaintiff, causing nuisance in or around the vicinity of these premises.

13. The Plaintiff understands that the aim of the Defendants' actions is to, inter alia, seek payments from the Plaintiff with respect to the drop in value of certain investment-linked assurance schemes known as "Evolution" which they (or individuals or entities related to them) allegedly purchased from the Plaintiff. The Plaintiff has been discussing the matter with certain policyholders for at least a few months.

14. The individual identities of the Defendants in the present application are not known to the Plaintiff. The Plaintiff is not able to identity whether the individuals comprising the Defendants are also the complainants in the Evolution matter, as it is possible that such individuals have changed throughout the course of the protests.

Events that took place between 11 and 15 June 2019

15. The below is an account of the events between 11 and 15 June 2019 in relation to the conduct of the Defendants, based on the information, including the photographs now produced and shown to me marked Exhibit "LSMA-2 (for Times Square Centre), Exhibit "LSMA-3" (for Mira Place Centre) and Exhibit "LSMA- 4 (for AXA Tower Centre) and the videos, now produced and shown to me marked

535865-4-6329-v2.0 - 4- HK-1000-LDR-18 Exhibit "LSMA-5", provided to me by the Plaintiffs staff or agents who were personally involved in handling the Defendants at the respective locations at the relevant time.

16. Starting from 11 June 2019, a group of around 30 protestors gathered at the vicinity of the Mira Place Centre (on Park Lane) in Tsim Sha Tsui to protest from 10 am to 4:20 pm. The Plaintiff respected their rights to protest in the public and kept monitoring the development.

17. On 12 June 2019, a group of individuals protested in public on Russell Street, opposite to Times Square in Causeway Bay in the vicinity of the Times Square Centre. Some of the protestors then went up to the Times Square Centre as well as an agency office at Suite 3404, 34/F of One, 33 Hysan Avenue, Causeway Bay, Hong Kong ("Lee Garden Office") to continue their protest at around 3:33 pm. The conduct of these individuals caused disruption to the operation of the Times Square Centre, the Plaintiff had to temporarily close down the Times Square Centre. However, despite the closure, the protestors continued to sit by the door of the Times Square Centre. The Plaintiff also had to cancel a seminar for our agency office at 20/F, Times Square Tower 2 due to the disruption caused by their presence. They finally left our Times Square Centre and Lee Garden Office at around 5:30 pm.

18. Given the disruptions caused by the protestors on 12 June, the Plaintiff closely monitored the situation at its different offices. On 13 and 14 June, the protesters escalated their actions, disrupting the operation of all three Customer Service Centres, as well as another office of the Plaintiffs personnel located at 40/F of AXA Tower.

Times Square Centre

19. At around 10:20 a.m. on 13 June, a group of 10 protestors holding banners arrived at the Times Square Centre. A lot of them was fearing face masks. Wary of the disruption they may cause and the safety of the Plaintiffs staff, staff at the Times Square Centre decided to lock the glass door to stop them at the lift lobby, and sought assistance from the Time Square Building Management Office ("TS

535865-4-6329-v2.0 - 5- HK-1000-LDR-18 BMO"). Photos taken of the protesters at the lift lobby at the time are exhibited at Exhibit "LSMA-2".

20. A protester then yelled their complaints at the Plaintiffs staff through a loudhailer, making statements such as he pitied AXA's employees as they were working for a company that set up traps, and other protesters applauded his speech. A video of this is exhibited at LSMA-5.

21. The protestors then refused to leave. They either sat by the door of the Times Square Centre or stood around the lift lobby, as shown in photos exhibited at LSMA-2. The TS BMO contacted the Police for assistance. The Police came but did not manage to ask the protesters to leave.

22. With the protesters staying at the lift lobby, the Times Square Centre could not operate properly. In the afternoon, several customers complained to our staff that they could not enter the Times Square Centre; and some became very angry. Our staff could only handle customers' enquiries and payment transaction through the door seam. The protesters finally left the Times Square Centre at around 6 p.m. on 13 June.

23. The Plaintiff was informed overnight that the protesters indicated that they would return to the Times Square Centre the next day. Given the events on 13 June, we decided to lock the glass door of the Times Square Centre at around 9:30 a.m. on 14 June. Our Compliance Team also reported the matter to the Police in the morning of 14 June to seek their assistance.

24. The protesters started arriving at Times Square Centre at around 10 a.m. As shown in a photo exhibited at LSMA-2, around five of the protesters again sat at the lift lobby outside the Times Square Centre, displaying their banners. A few police officers arrived, but did not manage to get the protesters to leave.

25. During the morning of 14 June, the protesters complained of AXA to other customers seeking service at the Times Square Centre. At around 10:50 a.m., an employee at the Times Square Centre offered some water to the protesters, who seized the chance to stop our security guards from closing the front door of the

535865-4-6329-v2.0 - 6- HK-1000-LDR-18 Times Square Centre, and demanded to meet with the Chief Executive Officer of AXA. This is shown in a video at Exhibit LSMA-5.

26. The protestors again blocked the front door of the Times Square Centre and got into heated argument with the Plaintiffs staff standing behind the glass door of the Times Square Centre starting from around 1 pm. Despite repeated requests to unblock our front door, the protestors refused to let anyone (including our agents and employees) in unless they were also allowed as well.

27. At around 1:40 pm, police officers came again to follow up with the report made by our Compliance Team in the morning. The protestors became more emotional as they thought we called the Police again. As shown in the video recorded at 1:52pm at Exhibit LSMA-5, the protestors kept chanting slogans at the lift lobby, and a protestor shouted "this will become the biggest scandal in AXA's history"(" ~~~ffF{rJ:f&::kBkJ:B:[:ijj") in the video recorded at 2:02 pm, also at Exhibit LSMA-5. Due to the blockage of the front door, customers of the Plaintiff could not get through to the Times Square Centre for normal services, as shown in some of the photos at Exhibit LSMA-2.

28. Because of the ongoing disruption, the Plaintiff decided that the Customer Service Centres would be closed on 15 June (Saturday) (which would otherwise be usually open for business), although some of the Plaintiffs employees at the Times Square Centre and agent attended work.

29. In the morning of 15 June, around 7 protestors came and continued their protests. They became so emotional that we had to seek the Police's assistance to protect our employees and agents when leaving the Times Square Centre. As shown in the video taken at 1: 17pm in Exhibit LSMA-5, it took at least four police officers and two security guards of TS BMO to help our staff from leaving, and the protestors chanted threatening slogan loudly, angrily and continuously at our employees and agents: "AXA Insurance, die without descendants" ("~~fi~, WT--rtts 1)J, ").

Mira Place Centre

30. On 13 June at around 11 am, more than 10 protestors arrived at the Mira Place Centre with banners. As with the Times Square Centre, staff at the Mira Place

535865-4-6329-vl.0 - 7- HK-1000-LDR-18 Centre closed its glass door to block the protestors from entering, as shown in photos marked 1105 in Exhibit LSMA-3. The protestors then sat by the glass door to display their banner.

31. Our staff then reported the situation to the Mira Place Building Management Office ("MP BMO") and the Police for assistance. A few police officers arrived at the scene to maintain order, as shown in the photo mark 1105 in Exhibit LSMA- 3.

32. The police officers left at around 12:17 pm, without managing to ask the protestors to leave. The security guards from MP BMO stayed on to monitor the situation, and informed us at around 12:40 pm that they overheard 4 protestors were heading to the AXA Tower in K wun Tong. I then informed relevant colleagues at the AXA Tower of the same (see below). At 12:50 pm, I was updated that 3 protestors remained and sat by the glass door of the Mira Place Centre. They eventually left around 6 pm.

33. On 14 June at around 10:40 am, two protesters arrived outside the Mira Place Centre. Our staff there contacted the MP BMO and locked the main door, and we also sought assistance from the Police.

34. Three police officers arrived at around 11: 15 am to persuade the protestors to leave (to no avail), as shown in photos marked 1114 - 1137 at Exhibit LSMA-3. Also, according to the photo marked 1110 in Exhibit LSMA-3, some protestors talked to the Plaintiffs customer who went to the Mira Place Centre. The protestors also handed out papers to our customers.

35. At around noon, six more protesters arrived at the Mira Place Centre. They sat by the main glass door, as shown in the photos marked 1231 at Exhibit LSMA-3.

36. At around 2 pm, the protestors also stood at the side door of the Mira Place Centre and protested loudly. Despite our staffs request for them to leave, they kept blocking the side door, such that our customers had to wait inside the Mira Place Centre, as shown in photo marked 1405 and 1416 at Exhibit LSMA-3. Some

535865-4-6329-v2.0 - 8- HK-1000-LDR-18 protestors also tried to enter the Mira Place Centre, thus blocking other customers from accessing the Mira Place Centre for normal services.

37. As a result of the chaotic situation, MP BMO called the Police for assistance again, and 2 police officers arrived at the scene at around 2:30pm. Although finally by that time we could finally allow customers to access the Mira Place Centre through the side door, those customers complained of such arrangements. We subsequently also received complaints from other tenants nearby the Mira Place via MP BMO against the nuisance caused by the protestors.

AXA Tower Centre

38. At around 12:40pm on 13 June, our staff had to shut the door of the AXA Tower Centre to prevent the protestors from occupying the office, upon being informed of the protestors' intention to go into the AXA Tower Centre despite our decline to their entry request.

39. Our PR agency staff therefore went to AXA Tower. When they arrived, six protestors were already at the AXA Tower Centre, as shown in the photo marked [1417] at Exhibit LSMA-4. Similar to what the protestors did in the other locations, they unfurled banner at the door of the AXA Tower Centre and chanted slogans. As recorded in the video at 15: 12 at Exhibit LSMA-5, they also entered into heated arguments with staff of the Plaintiff who wanted them to leave and stop blocking the door with the banner.

40. At around 4:06 pm, the Police finally managed to get the protesters to leave the AXA Tower building.

41. At around 11 am on 14 June, the protesters returned to the AXA Tower Centre. They entered into argument with our security guards and sought to push into the office despite repeated refusal for their entry.

42. Police officers arrived at around 11: 10am to persuade the protesters to leave, but they refused and continued to display their banner. One protestor also claimed to feel unwell and lied in front of the door of the AXA Tower Centre, blocking the

535865-4-6329-v2.0 - 9- HK-1000-LDR-18 entrance. However, he refused to go to the hospital even after our staff called an ambulance for him.

43. The whole protest persisted in the afternoon of 14 June until after 7 pm. In the course of their protest, the protestors chanted slogans loudly (such as "AXA is a liar") and disturbed AXA's customers whom were queueing up to be served at the AXA Tower Centre.

44. In addition, they also unfurled huge banner, at the ground floor lobby of the AXA Tower as shown in a photo in Exhibit LSMA-4.

Agency office at 40/F of AXA Tower

45. At around 2:20 pm on 13 June 2019, three protestors, without permission, entered into the office of an AXA's agency (of insurance agents), which is their private office not open to the public, located on 40/F of AXA Tower, when one of its staff member exited the premises.

46. The protestors wore face masks and caps, unfurled two banners stating accusations against AXA, and played recorded slogans loudly within the office premises, effectively preventing any work to be done by the staff there. As evidenced by the video recorded at 2:26pm at Exhibit LSMA-5, the three protestors shouted loudly at the agents and refused to leave the private premises.

47. Police officers arrived at around 2:48pm to persuade the protestors to leave. The protestors refused and one protestor lied on the floor of the office. Police officer finally removed the protestors from the office premises with force, but they remained at the hallway outside the premises on the 40/F, shouting through the doors and even banging on the door as shown in the videos recorded.

48. As a result of the intrusion and the ongoing disturbance, the agency was forced to close the office at 3 :20pm for the remainder of the day due to concerns about security and safety of staff.

49. Those protestors then sought to join the other protestors at 42/F, but was stopped by the Police. They were forced to return to the ground floor lobby.

Letter to and response from Ms Gao Tong ("Ms Gao")

535865-4-6329-v2.0 - 10- HK-1000-LDR-18 50. In view of the disturbance caused to the Plaintiffs operations and business by the Defendants, the Plaintiff sent an email to a Ms Gao (whom the Plaintiff understands to be the "lead" complainant allegedly representing a number of the policyholders involved in the Evolution matter), stating that:

(a) the actions taken at the Plaintiffs premises at Times Square, Mira Place, Lee Garden and offices at Kwun Tong on 12 and 13 June 2019 may constitute illegal activities;

(b) the Plaintiff has no hesitation in reporting to the police and supporting any subsequent prosecution actions; and

(c) the Plaintiff will cease to engage in any further discussions with Ms Gao, unless and until she ( and those she represents) ceases and desists engaging in the aforesaid behaviour and provide a written assurance to that effect.

51. In response, Ms Gao indicated that those in her group are getting emotional (" .. . ~1nrn~.AlI!.1fil~'~ti ... ") and she has no control over her group's emotions(" .. . ~5~~fgg:1J*~FtUr!l~.ABkJ'~ti ... ").

52. A copy of the said email chain between the Plaintiff and Ms Gao is now produced and shown to me marked Exhibit "LSMA-6".

Trespass and Nuisance

53. I am advised and verily believe that, based on the above facts, there is a strong case on the merits in trespass and private nuisance. The protestors have no right or entitlement to remain or occupy areas in or in the vicinity of the Customer Service Centres, which are located in leased commercial premises. The protestors have also, through their conduct, seriously affected the use and enjoyment of the premises through blocking access, using loudhailers, refusing to leave when requested and being a harassment to AXA's staff and customers.

Necessity of an injunction

54. Based on the facts I have referred to, there is a need for an injunction to restrain the conduct of the protestors which amount to clear acts of trespass and private nuisance. Their protests have continued despite our requests to ask them to leave, and unless restrained by the court, there is a real risk that they will continue. The Plaintiff has already been forced to temporarily close down operations of the

535865-4-6329-v2.0 - 11- HK-1000-LDR-18 Customer Services Centres on Saturday due to concerns about the safety and welfare of AXA' s staff and those of its customers. The disruption to business has been serious, and threatens to continue without an injunction.

Balance of convenience

55. As can be seen from the above, the Defendants have been persistent in their acts of nuisance and trespass, causing significant disturbance to the Plaintiffs operations and business (as evidenced by the closure of the Customer Service Centres and agency office as described above). I have been advised and verily believe that the grant of an injunction in the terms set out in the draft Order will not be unjust nor inconvenient for the Defendants as, should the Defendants be minded to continue their demonstrations, they can apply for the relevant approvals and do so in public areas, as opposed to continuing their acts of nuisance and trespass at the Plaintiffs premises.

56. In view of the significant disturbance caused by the Defendants' activities to the Plaintiff, I have been advised and verily believe that the balance of convenience is overwhelmingly in favour of granting the injunction.

Service on the Defendants

57. Due to the transient nature of the presence of the Defendants at the premises, it is impracticable to effect service on the Defendants in the usual manner. The Plaintiff therefore respectfully invites the Court to grant an order for substituted service i n the methods set out in the draft Order.

Undertakings

58. The Plaintiff is willing to give the usual undertaking as to damages as set out in the draft Order. The Plaintiff is a financially substantial company

Conclusion

59. In the premises, the Plaintiff respectfully seeks an order in terms of the draft Order filed together with this Affirmation.

And I solemnly and sincerely affirm that the contents of this affirmation are true.

535865-4-6329-v2.0 - 12- HK-1000-LDR-18 fhL- LI SIN MAN ALICE

~ I - ~L s I Jo..TJ.;,..e. ~~ . th AFFIRMED at v'~, ;-r:r, this 18 day of June 2019 ~ e,1"">-....J"'+ f 1~~ , ee~I, ~':j ltc:, Before me,

This Affirmation is filed on behalf of the Plaintiff.

535865-4-6329-v2.0 - 13- HK-I 000-LDR-l 8 HCA 1060 I 2019

IN THE HIGH COURT OF THE HONG KONG SPECIAL ADMINISTRATIVE REGION COURT OF FIRST INSTANCE ACTION NO. 1060 OF 2019 BETWEEN

AXA CHINA REGION INSURANCE COMPANY LIMITED Plaintiff and

PERSONS UNLAWFULLY OCCUPYING OR REMAINING AT 20/F, TOWER TWO, 1st Defendant TIMES SQUARE, 1 MATHESON STREET, CAUSEWAY BAY, HONG KONG WITHOUT THE PLAINTIFF'S CONSENT AND/OR PERSONS OBSTRUCTING OR HINDERING ACCESS TO AND EXIT FROM THOSE PREMISES AND THE UNITS THEREIN AND/OR PERSONS INTERFERING WITH THE USE OF THOSE PREMISES AND THE WHOLE OF TOWER TWO, TIMES SQUARE BY THE PLAINTIFF, ITS STAFF, SERVANTS, AGENTS, LICENSEES AND LAWFUL VISITORS

2nd Defendant PERSONS UNLAWFULLY OCCUPYING OR REMAINING AT 11/F, MIRA PLACE TOWER A (FORMERLY AND ALSO KNOWN AS MIRAMAR TOWER), 132 NATHAN ROAD, TSIM SHA TSUI, HONG KONG WITHOUT THE PLAINTIFF'S CONSENT AND/OR PERSONS OBSTRUCTING OR HINDERING ACCESS TO AND EXIT FROM THOSE PREMISES AND UNITS 1101, 1117-1118 THEREIN AND/OR PERSONS INTERFERING WITH THE USE OF THOSE PREMISES AND THE WHOLE OF MIRA PLACE TOWER A BY THE PLAINTIFF, ITS STAFF, SERVANTS, AGENTS, LICENSEES AND LAWFUL VISITORS

rd PERSONS UNLAWFULLY OCCUPYING OR REMAINING AT 40/F AND 42/F, AXA 3 Defendant TOWER, 100 HOW MING STREET, KWUN TONG, KOWLOON WITHOUT THE PLAINTIFF'S CONSENT AND/OR PERSONS OBSTRUCTING OR HINDERING ACCESS TO AND EXIT FROM THOSE PREMISES AND THE UNITS THEREIN AND/OR PERSONS INTERFERING WITH THE USE OF THOSE PREMISES AND THE WHOLE OF AXA TOWER BY THE PLAINTIFF, ITS STAFF, SERVANTS, AGENTS, LICENSEES AND LAWFUL VISITORS

AFFIRMATION OF LI SIN MAN ALICE

Dated this 18th day of June 2019 Filed this ft,µ.. day of June 2019

Clifford Chance Solicitors for the Plaintiff 27th Floor, One Connaught Place Hong Kong Tel: 2825 8888 Fax: 2825 8800 Ref: ERJ.70-40710571.WWKW.AOTC.HRF

535865-4-6329-v2.0 - 14- HK-1000-LDR-18