Miles Guo Court Documents · Doc 261

摘要

Government Letter · Pre-Hearing Brief for April 9 Suppression Hearing

This six-page letter, dated April 8, 2024 from the Assistant U.S. Attorneys, addresses the applicable law and previews facts the government expects to establish at the April 9, 2024 suppression hearing in United States v. Yanping Wang, S2 23 Cr. 118 (AT).

Government's Pre-Hearing Position

The letter walks through:

• The legal standard for analyzing Miranda violations and Edwards v. Arizona invocations of right to counsel;
• The factual evidence the government expects to introduce at the hearing — including testimony from FBI Special Agent Baccari and other arrest-team members;
• The government's framework for arguing that no Miranda violation occurred during Wang's arrest and that no Edwards invocation triggered suppression.