Library
Selected documents for the three proposed appeal grounds are presented below. The Archive holds the fuller court records and correspondence from which those selections are drawn.
This initial catalogue shows the intended organisation. File links will appear as documents are uploaded.
Ground 1 — Abuse of Power / Abuse of Process
Selected records concerning the purpose of the prosecution, search warrants and Court Attendance Notices, and extradition.
FOI Disclosure — 2022
G1-01 · FOI Disclosure — Internal ATO Records
PDF · Source file: FOI p1-71.pdf
Selected FOI records relied upon by Mr Zhang concerning the RHV assessment and the development of the criminal investigation.
File awaiting upload
Search Warrants and Court Attendance Notices
G1-02 · Newcastle Local Court — Search-Warrant Records
27 April 2022 · PDF
Arrest and Extradition
G1-03 · Arrest Warrants, CANs and Extradition Records
2014–2019
Records to be selected concerning the Australian warrants and Mr Zhang’s extradition from New Zealand.
Selection to follow
Full records in the Archive
Ground 2 — Impermissible and Excessive Judicial Intervention
Selected passages from Mr Zhang’s evidence, closing address and the summing up. The sample entries below identify the records to be attached; they are not a completed ranking of the ten strongest interventions.
G2-01 · Mr Zhang’s Evidence — 28 August 2023
Trial Day 122 · PDF · File awaiting upload
Evidence and exchanges concerning the disputed electronic documents. The relevant passages will be identified alongside the complete day’s transcript.
G2-02 · Mr Zhang’s Evidence — 30 August 2023
Trial Day 124 · PDF
The exchanges underlying Mr Zhang’s complaint about the judge’s suggestion that he may have created the disputed material and the “alibi” discussion.
G2-03 · Mr Zhang’s Evidence — 31 August 2023
Trial Day 125 · PDF · File awaiting upload
Further exchanges about the electronic evidence and Mr Zhang’s defence.
G2-04 · Summing Up — Day 1
21 September 2023 · PDF · File awaiting upload
The first day of the trial judge’s summing up, to be read alongside Mr Zhang’s closing address and the evidence.
G2-05 · Summing Up — Day 2
22 September 2023 · PDF · File awaiting upload
The second day of the summing up, including the presentation of the competing cases.
G2-06 · Summing Up — Day 3
25 September 2023 · PDF · File awaiting upload
The final day of the summing up before jury deliberations.
Full transcripts in the Archive
Ground 3 — Errors of Law
Selected records supporting “delusive onus of proof” and the challenge to the admission and use of allegedly false documents.
Delusive Onus of Proof
G3-01 · CCA Submission — Delusive Onus of Proof
1 April 2025 · PDF extract · File awaiting upload
Ground 3, Heading 1, paragraphs 104–123, printed pages 18–20: Mr Zhang’s argument that the matters the prosecution sought to prove did not establish the charged offences.
Disputed Emails and Documents
G3-02 · Email 207 — Email and Attached Spreadsheet
Native MSG/XLS · Email_A_207.MSG · Email_A_207_a.XLS · File awaiting upload
The email and spreadsheet challenged by Mr Zhang concerning purported AusChintle invoices in July and August 2004. Native files preserve the electronic material for inspection.
G3-03 · E_DOC_A_024 — Dates and Later Transactions
Comparison proposed between the spreadsheet’s metadata and records concerning the RHV and HT6 transactions. Selection to follow
G3-04 · E_DOC_A_063 — Lobbyfit and Y&L Entries
Comparison proposed between the disputed spreadsheet and contemporaneous invoice and BAS records. Selection to follow
Source records in the Archive
Crowe total 1 to 11
6. Mr Crowe’s Affidavit on Search Warrant 118/09 and the WHK Emails
Crowe's 13 July 2020 affidavit with the attachements of search warrant 118/09 and his emails.
G3-01 · CCA Submission — Delusive Onus of Proof
1 April 2025 · PDF extract · File awaiting upload
Ground 3, Heading 1, paragraphs 104–123, printed pages 18–20: Mr Zhang’s argument that the matters the prosecution sought to prove did not establish the charged offences.
Disputed Emails and Documents
G3-02 · Email 207 — Email and Attached Spreadsheet
Native MSG/XLS · Email_A_207.MSG · Email_A_207_a.XLS · File awaiting upload
The email and spreadsheet challenged by Mr Zhang concerning purported AusChintle invoices in July and August 2004. Native files preserve the electronic material for inspection.
G3-03 · E_DOC_A_024 — Dates and Later Transactions
Comparison proposed between the spreadsheet’s metadata and records concerning the RHV and HT6 transactions. Selection to follow
G3-04 · E_DOC_A_063 — Lobbyfit and Y&L Entries
Comparison proposed between the disputed spreadsheet and contemporaneous invoice and BAS records. Selection to follow
Source records in the Archive
Trial analysis
Selected records supporting “delusive onus of proof” and the challenge to the admission and use of allegedly false documents.
Delusive Onus of Proof
G3-01 · CCA Submission — Delusive Onus of Proof
1 April 2025 · PDF extract · File awaiting upload
Ground 3, Heading 1, paragraphs 104–123, printed pages 18–20: Mr Zhang’s argument that the matters the prosecution sought to prove did not establish the charged offences.
Disputed Emails and Documents
G3-02 · Email 207 — Email and Attached Spreadsheet
Native MSG/XLS · Email_A_207.MSG · Email_A_207_a.XLS · File awaiting upload
The email and spreadsheet challenged by Mr Zhang concerning purported AusChintle invoices in July and August 2004. Native files preserve the electronic material for inspection.
G3-03 · E_DOC_A_024 — Dates and Later Transactions
Comparison proposed between the spreadsheet’s metadata and records concerning the RHV and HT6 transactions. Selection to follow
G3-04 · E_DOC_A_063 — Lobbyfit and Y&L Entries
Comparison proposed between the disputed spreadsheet and contemporaneous invoice and BAS records. Selection to follow
Source records in the Archive
Archive — Full Records and Correspondence or no need!!!???
A · Pre-Trial Proceedings
The Archive is the main collection. Grounds 1–3 select and explain relevant items from it; the same source file will be linked wherever it is needed.
Transcripts, submissions, rulings and documents. Collection to be added.
B · District Court Trial
Trial transcript collection — Days 1–139 (files awaiting upload)
Transcripts arranged by day/date, exhibits by existing exhibit names/numbers, summing up and jury communications. Only attached days will have working links; the full set is not yet available on this website.
Day 1 — 28 November 2022 · File awaiting upload Day 116 — 15 August 2023 · File awaiting upload Day 122 — 28 August 2023 · File awaiting upload Day 124 — 30 August 2023 · Open PDF — Day 124 Day 125 — 31 August 2023 · File awaiting upload
Summing up
Summing Up Day 1 — 21 September 2023 · File awaiting upload Summing Up Day 2 — 22 September 2023 · File awaiting upload Summing Up Day 3 — 25 September 2023 · File awaiting upload
C · NSW Court of Criminal Appeal
Mr Zhang’s Written Submission — 1 April 2025 · 1.Submission20250402pp260.pdf · File awaiting upload CCA Hearing Transcript — 1 September 2025 · 5.1Transcripts20250901pp90.pdf · File awaiting upload Applicant’s Combined Documents — AA001–151 · File awaiting upload Judgment/orders category to follow
D · Arrest and Extradition
Warrants, affidavits, New Zealand proceedings and extradition records. Collection to be added.
E · Correspondence with the CDPP
Mr Zhang’s communications with the prosecution, arranged chronologically and by subject. Collection to be added.
F · FOI, ATO and Other Relevant Records
FOI disclosure 2022 and related audit, assessment and correspondence. Sample: FOI p1–71. File awaiting upload