Miles Guo Court Documents · Doc 143
Memorandum of Law in Support of Defendant Ho Wan Kwok’s Motion to Compel Discovery (English) / (中文)
摘要
Defense Memorandum · Motion to Compel Discovery (Round 1)
This 26-page filing, dated September 2023 from Mr. Kwok's defense team at Pryor Cashman LLP, is the memorandum of law in support of Defendant Ho Wan Kwok's first motion to compel discovery in United States v. Ho Wan Kwok, 1:23-CR-118-1 (AT). Filed partially under seal.
Discovery Theory
The motion seeks compelled production of all communications and documents exchanged between the government and:
- The Chapter 11 Trustee appointed to oversee Mr. Kwok's bankruptcy proceedings;
- The Securities and Exchange Commission (SEC);
- Additional government agencies the defense argues should be considered part of the prosecution team.