Miles Guo Court Documents · Doc 178
Motion for Release from Custody Memorandum in Support of Renewed Motion for Pretrial Release of Ho Wan Kwok / (中文）
摘要
Defense Memorandum · Renewed Motion for Pretrial Release
This 31-page filing, dated November 2023 from Mr. Kwok's defense team (Sabrina P. Shroff and Pryor Cashman LLP), is the memorandum of law in support of Defendant Ho Wan Kwok's renewed motion for pretrial release in United States v. Ho Wan Kwok, 1:23-CR-118-1 (AT). Filed partially under seal.
Defense's Arguments
The 31-page memorandum advances detailed arguments for pretrial release:
- The § 3142(g) factors, properly weighed, support release on conditions;
- New or developing circumstances since the initial Bail Order (April 20, 2023) support reconsideration;
- Proposed conditions adequately address the government's flight-risk and danger-to-community concerns;
- Mr. Kwok's status in MDC pretrial detention is itself prejudicial to his ability to prepare for trial.