Miles Guo Court Documents · Doc 385

摘要

Government Motion · Preclude Improper and Inadmissible Defense Evidence

This 11-page letter motion, dated June 30, 2024 from the Assistant U.S. Attorneys, asks the Court to preclude introduction of certain defense evidence in United States v. Guo, S3 23 Cr. 118 (AT). Exhibit B (case-doc-385-1) is GXSTIP19.

Five Categories Targeted

1. "Non-Victim" Investor Witnesses: Testimony from individual investors who claim not to be victims of the charged schemes — the government argues this is irrelevant to materiality and intent. The Rule 26.2 materials Guo has produced to date suggest that Guo intends to call at least three investors in the G Enterprise investment projects who will testify they do not consider themselves victims;
2. Defense Witness-1: Testimony from a specific defense witness identified anonymously that the government characterizes as irrelevant and unduly prejudicial;
3. George Higginbotham: The government seeks to limit Higginbotham's testimony to personal knowledge and preclude transmission of hearsay;
4. Defense Experts Opining on Other Witnesses: The government seeks to preclude defense experts from rendering opinions about the testimony of government witnesses;
5. Himalaya Exchange Redemptions: The government seeks to exclude evidence of redemptions paid by the Himalaya Exchange as irrelevant to the fraud charges.