Miles Guo Court Documents · Doc 332
Letter by Miles Guo re: Response to Government Letter Doc 331 / (中文)
摘要
Defense Letter · Response on Witness-1 Privileged Communications
This three-page filing, dated May 8, 2024 from Sidhardha Kamaraju of Pryor Cashman LLP, responds to the government's May 7, 2024 letter (Dkt. 331, case-doc-331) in further support of its motion to admit Witness-1's testimony about the GTV private placement in United States v. Guo et al., 1:23-cr-00118 (AT).
Defense's Principal Arguments
The defense argues:
- The government's motion is a misguided effort to introduce into evidence privileged conversations in which Witness-1 provided legal advice in connection with the GTV private placement;
- The government's May 7 letter provides more detail about the scope of Witness-1's testimony, but that scope still implicates communications protected by the attorney-client privilege;
- A personal attorney-client relationship existed between Mr. Guo and Witness-1, separate from any corporate engagement;
- The Court has already raised the possibility of attorney-client privilege protection in its April 29, 2024 order, and that concern should weigh against admission of the testimony.