Miles Guo Court Documents · Doc 283

摘要

Government Reply · Kwok's Discovery Theory (Bai / Fox Hunt)

This five-page letter, dated April 15, 2024 from the Assistant U.S. Attorneys, replies to Mr. Kwok's April 14, 2024 letter (Dkt. 282) regarding the scope of the government's discovery obligations related to the Bai case and Operation Fox Hunt in United States v. Kwok, 23 Cr. 118 (AT).

Government's Position

The government argues:

• The defense's invocation of an expansive "prosecution team" concept would be insufficient as a matter of law;
• Kwok's already unprecedented theory would need to be expanded even further to reach the FBI's Washington Field Office, where the Bai case was investigated;
• The undersigned AUSAs' discovery obligations would, on Kwok's theory, cover the entirety of the FBI and its roughly 35,000 employees;
• The impracticality of that proposition alone is basis to reject Kwok's position.