Miles Guo Court Documents · Doc 192
Memorandum of Law of The United States of America in Opposition to Defendant Ho Wan Kwok’s Second Motion For Pretrial Release / (中文)
摘要
Government Memorandum · Opposition to Second Motion for Pretrial Release
This 35-page filing, dated December 2023 from the Assistant U.S. Attorneys (under Damian Williams), is the government's memorandum of law in opposition to Defendant Ho Wan Kwok's second motion for pretrial release in United States v. Ho Wan Kwok, S1 23 Cr. 118 (AT).
Government's Arguments
The 35-page memorandum opposes pretrial release, citing the detention factors under 18 U.S.C. § 3142(g):
- Risk of flight (Mr. Kwok's foreign ties, financial resources, and political connections);
- Danger to the community (concerns about witness tampering, obstruction);
- Severity of the charges and potential sentence;
- Absence of conditions or combination of conditions that would reasonably assure the defendant's appearance and the safety of the community.