Miles Guo Court Documents · Doc 191
Ho Wan Kwok’s Reply Memorandum of Law in Further Support of His Renewed Motion For Pretrial Release / (中文)
摘要
Kwok Reply · Renewed Motion for Pretrial Release
This 18-page filing, dated December 2023 from Mr. Kwok's defense team (Sabrina P. Shroff and Pryor Cashman LLP), is the reply in further 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.
Reply Themes
The reply addresses the government's opposition (case-doc-192), arguing:
- New circumstances or conditions support reconsideration of the initial Bail Order;
- The Section 3142(g) factors, properly weighed, support release on conditions;
- Proposed conditions adequately address the government's flight-risk and danger-to-community concerns.