Miles Guo Court Documents · Doc 369
Letter by USA as to Miles Guo re: Witness Testimony Document / (中文)
摘要
Government Letter · Steele Schottenheimer Testimony
This five-page letter, dated May 30, 2024 from the Assistant U.S. Attorneys, addresses anticipated testimony of Steele Schottenheimer, a managing director of Hayman Capital Management, L.P. ("Hayman"), in United States v. Guo, S3 23 Cr. 118 (AT).
Witness and Topic
Ms. Schottenheimer is expected to testify about the potential uses and capacities of a Hayman financial product with which she has personal familiarity — specifically, the Hayman Hong Kong Opportunities Fund (HHKOF) — described as an investment fund that pays off if the value of the Hong Kong Dollar significantly decreases.
Defense Objection Anticipated
The defense has objected to the government's attempt to elicit Ms. Schottenheimer's understanding about whether HHKOF itself could have a negative impact on the CCP.
Government's Position
The government argues that Schottenheimer's testimony — based on her personal perception and familiarity with HHKOF — is properly admissible as lay-witness testimony grounded in her work for Hayman. The government invokes Second Circuit precedent allowing lay opinion from a civilian analyst or investigator that is based on the investigator's own investigation and reflects investigatory findings and conclusions (citing Bank of China, N.Y. Branch v. NBM LLC).