Miles Guo Court Documents · Doc 344
Letter Motion from AUSA Ryan B. Finkel re: Miscellaneous Relief / (中文)
摘要
Government Letter Motion · Miscellaneous Trial Relief
This seven-page letter motion, dated May 21, 2024 from AUSA Ryan B. Finkel, seeks multiple forms of trial-related relief in United States v. Guo, S3 23 Cr. 118 (AT).
Three Categories of Relief Sought
1. Co-Conspirator and Agent Statements
The government provides additional information regarding co-conspirator statements it may elicit at trial, including as early as this week. The Court granted, in part, the Government's motion in limine to admit certain statements.
2. Preclude Irrelevant Defense Evidence and Argument
The government asks the Court to preclude certain categories of evidence and argument the defense may seek to introduce — particularly relating to investor sophistication, redemptions, and other themes the government views as designed to deflect from the elements of the charged offenses.
3. Preclude Improper Argument About Immigration Consequences
The government asks the Court to preclude the defense from making any argument during opening statement (and throughout trial) about the immigration consequences of a conviction. The government argues such argument is irrelevant to guilt or innocence and serves only to invite jury nullification.