Miles Guo Court Documents · Doc 163

摘要

Defense Reply · Motion to Compel

This 23-page filing, dated November 2023 from Mr. Kwok's defense team at Pryor Cashman LLP, is the reply in further support of the motion to compel discovery in United States v. Ho Wan Kwok, 1:23-CR-118-1 (AT). Filed partially under seal.

Reply Themes

The defense addresses the government's opposition (case-doc-201), arguing:

• The government's narrow view of the prosecution team's discovery obligations conflicts with controlling precedent;
• CCP-targeting evidence is squarely Brady/Giglio material;
• The Trustee and SEC communications are within the scope of required disclosure under the defense's prosecution-team theory;
• The government has not adequately justified its refusal to produce.