[WebEx ex-President and outgoing CTO Min Zhu] first sexually abused [his daughter Erin] in August 1988. […] Just as [Erin] was about to fall asleep, Min Zhu slipped into bed with [Erin]. Although a brilliant student, [Erin] was naive and innocent about sexual matters. [Erin] had studied biology and was aware of the biological aspects of reproduction, but she was unaware of the "practical" aspects of sexual matters. Min Zhu was wearing shorts and a tank top/t-shirt. [Erin] was wearing shorts and a t-shirt. Min Zhu removed [Erin]’s clothes and began to touch her sexually. [Erin] verbally objected to his advances but Min Zhu merely stated that there was nothing wrong with what he was doing. Min Zhu proceeded to remove his clothes and forced [Erin]’s hand to touch him sexually. Min Zhu assured [Erin] that there was nothing wrong with [Erin] touching him in that way and that Min Zhu’s state of erection was normal. Min Zhu proceeded to turn on the lights, stating that he wanted to see [Erin] naked because he had never seen a virgin naked, since her mother was not a virgin when they were married. [Min Zhu] proceeded to place his hand between [Erin]’s legs and pronounced that the moisture in her vagina meant that her body was "being bad" and that she deserved to be punished. [Erin] attempted physically to refuse Min Zhu’s sexual advances. However, she was powerless to fight her father off. Min Zhu was approximately 39 years old, was a grown man in his prime, and was much larger and very much stronger than [Erin]. Min Zhu was approximately 5’11" tall and weighed approximately 160-170 pounds at that time. [Erin] was a fourteen-year-old girl, was only 5’4" tall and weighed less 90 lbs. Min Zhu became more aggressive and mounted [Erin]. When [Erin] struggled, Min Zhu began choking and restraining [Erin] with a blanket. He threatened to kill her. [Erin] stopped fighting her father as she was physically overpowered and feared that she would be severely harmed physically. [Erin]’s fear was all the more pronounced in light of Min Zhu’s long history of domestic violence and lack of remorse or conscience. Min Zhu then proceeded to rape [Erin].
— Excerpted from the January 18, 2000 draft complaint by Erin Zhu, the daughter, rape victim, and hush money recipient of WebEx President and CTO Min Zhu, filed as an exhibit in Opposition to the Defendants’ Motion to Strike in Zeleny v. Zhu & WebEx, Santa Clara Superior Court Case Number CV-809286.
On January 19, 2000, I traveled to Palo Alto, California, to meet with Min Zhu and Susan Xu to discuss settlement of Erin Zhu’s claims. I met them at the Gordon Biersch restaurant in Palo Alto, California. Min Zhu opened our meeting by describing to me his experiences in China during the Cultural Revolution. He stated that he and his wife had been sent to a remote camp and had had to struggle very hard just to survive. He said that he had been in many fights. He then told me he had come to this country and succeeded in building a billion dollar corporation, but if he lost it, he would not be troubled, because he had already undergone such hardships that any such loss would be nothing in comparison to what he had already suffered. He said he looked forward to a new experience, fighting in the American court system, and it could not do anything to him that could compare to what he had already endured.
During our meeting, Min Zhu expressed familiarity with the general subject matter of Erin Zhu’s claims, although I had not specified them at any point. He did not ask me about any details of Erin Zhu’s claims. He did not deny any of the allegations.
During our meeting, Min Zhu described his difficulties in parenting Erin Zhu. He said she was irresponsible. He also told me that he believed Michael Zeleny was a bad influence on her. He also speculated that Michael Zeleny was responsible for Erin’s decision to press claims against her parents.
— Declaration of David W. Affeld in Opposition to Motions For Summary Judgment and Summary Adjudication By Defendants in Zeleny v. Zhu & WebEx, Santa Clara Superior Court Case Number CV-809286.
The date: Tuesday, December 25, 2001.
The time: between 19:15 and 19:35 PST.
The action: An anonymous caller calls Michael’s AT&T mobile number 323-363-1860 seven times in a row. His caller ID is blocked. The calls are witnessed and overheard by Michael’s father Isaak Zelyony. The first six calls are wordless cackling. The last one proceeds as follows:
Anonymous Caller with a heavy Chinese accent: You are a bad man.
MZ: Say what?
AC: You are a bad man.
MZ: Really?
AC: You have been warned.
MZ: Uh huh.
AC: You have been warned.
AC hangs up.
The time: 22:20 PST.
The action: a call to 323-876-8234. The same voice as the first time.The caller ID is blocked.
AC: You’re a dead man.
MZ: Come and get me.
AC: Soon. Very soon.
AC hangs up.
The time: 22:21 PST.
The action: a call to 323-876-8234.The same voice as before. The caller ID is blocked.
AC: Don’t fuck with WebEx.
MZ scoffs.
AC: Mr. Zhu will get you. This is your last warning.
MZ snickers.
AC hangs up.
The date: Wednesday, January 2, 2002.
The time: 18:45 PST.
The action: An anonymous caller calls Michael’s AT&T mobile number, 323-363-1860. The same voice as before. The caller ID is blocked.
AC: I see you aren’t taking this seriously. You had two dogs, right? Go home and see how many dogs you have now. Do you understand me?
MZ: No, I don’t. Could you speak English?
The exchange continues along these lines for three minutes, until the connection breaks.
The time: 18:51 PST.
The action: The same anonymous caller places another call to Michael’s mobile number. The caller ID is blocked again. The same voice as before. The caller is agitated. This call is witnessed and overheard by David W. Affeld.
AC: You listen to me now. You have two dogs. Which dog you like best?
MZ: I like you. I want you to be my dog.
AC: You go home now, see you only have one dog. You understand now?
MZ: No, I don’t. Could you speak English?
AC: You only have one dog now. You take good care of one dog.
MZ: I have no idea what you are talking about. Who is this?
The exchange continues along these lines for three minutes, until AC hangs up.
