Miles Guo Court Documents · Doc 331
Response in Support of Motion by USA as to Miles Guo re: 273 Motion in Limine / (中文)
摘要
Government Reply · Witness-1 Testimony Admission
This nine-page letter brief, dated May 7, 2024 from the Assistant U.S. Attorneys, is in further support of the government's motion in limine to admit certain testimony from "Witness-1" in United States v. Guo, S3 23 Cr. 118 (AT).
Procedural Context
- Gov't MIL: Dkt. 273 at 31–34 — the government's original motion;
- Guo Opp'n: Dkt. 287 at 25–33 — the defense opposition;
- Witness-1 Order: Dkt. 310 — the Court's preliminary order raising the possibility that Witness-1's testimony may involve privileged communications.
Government's Arguments
The government argues the Court should admit Witness-1's testimony as described in the letter:
- Witness-1 was not personal counsel to Mr. Guo for the relevant communications;
- Any attorney-client relationship was with a corporate entity, not Mr. Guo personally, on the matters at issue;
- Even if some communications involved Mr. Guo, the crime-fraud exception or waiver doctrines apply to the proposed testimony;
- The testimony is directly relevant to the GTV private placement charges and the defendant's awareness of the legal risks of pooling non-accredited investors' funds.