Miles Guo Court Documents · Doc 219
Memorandum of Law in Support of Defendant’s Renewed Motion For a Stay and Motion for Reconsideration / (中文)
摘要
Defense Memorandum · Renewed Bankruptcy Stay Motion
This 21-page filing, dated January 2024 from Mr. Kwok's defense team at Pryor Cashman LLP, is the memorandum of law in support of Defendant Ho Wan Kwok's renewed motion to stay the Chapter 11 bankruptcy cases and motion for reconsideration of the Court's December 21, 2023 order denying the original motion to stay (Stay Order, ECF No. 204) in United States v. Ho Wan Kwok, 1:23-CR-118-1 (AT). Filed partially under seal.
Defense's Arguments
- New circumstances: Specific factual or procedural developments since the December 21, 2023 Stay Order that the defense argues warrant reconsideration;
- Continuing prejudice: The bankruptcy proceedings allegedly continue to prejudice Mr. Kwok's criminal defense by requiring document productions and depositions that overlap with criminal-case discovery;
- Statutory and equitable framework: Authorities supporting a federal-court stay of parallel proceedings in similar circumstances.