Miles Guo Court Documents · Doc 259

摘要

Kwok Letter · Response to Government Letter

This 15-page filing, dated April 4, 2024 from Sidhardha Kamaraju of Pryor Cashman LLP, responds to the government's March 31, 2024 letter regarding pretrial scheduling and discovery in United States v. Kwok et al., 1:23-cr-00118 (AT). Exhibits A–D and K (case-doc-259-1) are filed under seal.

Defense's Substantive Arguments

The filing develops Mr. Kwok's positions on:

• The government's proposed pre-trial disclosure schedule;
• The government's specific factual representations the defense argues require correction;
• Discovery items the defense seeks but believes have not been adequately produced — including Operation Fox Hunt-related materials that ground the broader political-context theme;
• Specific objections to the government's argued framework for trial-exhibit production.

Exhibits A–D and K are filed under seal — containing material the defense considers sensitive for ongoing trial-preparation purposes or that implicates classified-information frameworks.