Miles Guo Court Documents · Doc 271

摘要

Defense Memorandum in Support of Motions in Limine

This 69-page filing, dated April 9, 2024 from Mr. Kwok's defense team (Pryor Cashman LLP, Alston & Bird, and Sabrina P. Shroff), is the memorandum of law in support of the defense's motions in limine in United States v. Ho Wan Kwok, 1:23-CR-118-1 (AT). Filed partially under seal.

Defense's Requests

The defense moves to preclude the government's introduction of certain evidence and use of certain terminology, citing Federal Rules of Evidence 401, 402, 403, and 404(b). Categories the defense seeks to limit include:

• Characterization of the defendant's activities using particular labels (e.g., framing organizations as "the G enterprise");
• Evidence of uncharged conduct outside the time period of the indictment;
• 404(b) evidence of prior conduct not directly relevant to the charged offenses;
• Specific witness testimony that the defense argues is irrelevant or unduly prejudicial.