Miles Guo Court Documents · Doc 201
The Government’s Memorandum of Law in Opposition to The Defendant’s Motion to Compel / (中文)
摘要
Government Memorandum · Opposition to Motion to Compel
This 26-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 motion to compel in United States v. Ho Wan Kwok, S1 23 Cr. 118 (AT).
Underlying Motion
Kwok's motion to compel (ECF Nos. 170, 172) sought:
- Evidence about the CCP's targeting of Kwok and his associates;
- Evidence about the credibility of his movement, the New Federal State of China;
- Other categories of Brady/Giglio responsive material.
Government's Position
The 26-page memorandum opposes each category, arguing:
- The requested material does not satisfy the Brady/Giglio framework;
- Specific categories of CCP-related material are beyond the prosecution team's discovery obligations;
- The defense's broader political-context theme does not justify expanded discovery.