Miles Guo Court Documents · Doc 172

摘要

Defense Memorandum · Motion to Compel Discovery (Round 2)

This 33-page filing, dated November 17, 2023 from Mr. Kwok's defense team at Pryor Cashman LLP, is the memorandum of law in support of Defendant Ho Wan Kwok's second motion to compel discovery in United States v. Ho Wan Kwok, 1:23-CR-118-1 (AT). Filed partially under seal.

Defense's Discovery Theory

The memorandum develops the defense's expanded discovery theory:

• The Chinese Communist Party's targeting of Mr. Kwok and his associates;
• Evidence of the credibility of his political movement, the New Federal State of China;
• Government-Trustee communications;
• Government-SEC communications;
• Other categories of material the defense argues the government's prosecution team controls.