Miles Guo Court Documents · Doc 328
Response in Opposition by Miles Guo re: 272 Motion to Exclude Testimony of Defendant’s Expert Witness / (中文)
摘要
Defense Opposition · Government's Renewed Motion to Exclude Expert Testimony
This 51-page filing, dated May 3, 2024 from Mr. Guo's defense team (Sidhardha Kamaraju, Matthew S. Barkan, Daniel J. Pohlman, John M. Kilgard, Clare P. Tilton of Pryor Cashman LLP, with Sabrina P. Shroff), is the defense memorandum in opposition to the government's renewed motion in limine to exclude the testimony of Mr. Guo's expert witnesses in United States v. Miles Guo, 1:23-CR-118-1 (AT). The filing is partially under seal.
Defense Experts at Issue
The opposition addresses the government's renewed motion (Dkt. 272, refiled as Dkt. 322, case-doc-322) to exclude:
- Raymond Dragon — valuation expert;
- Paul Doran — Chinese Communist Party (CCP) expert;
- Thomas Bishop — accounting expert.
Defense's Principal Arguments
- Each expert's proposed testimony is relevant to defenses on specific charges;
- Each expert is qualified under Federal Rule of Evidence 702 and Daubert;
- The government's renewed motion does not present new grounds warranting exclusion;
- The Court's prior order (Dkt. 305, "First Daubert Order," case-doc-305) established the framework, and the defense's supplemental disclosures address the Court's specific concerns.