Miles Guo Court Documents · Doc 389

摘要

Government Motion · Strike Raymond Dragon Testimony (GTV Private Placement)

This three-page letter motion, dated July 2, 2024 from the Assistant U.S. Attorneys assigned to United States v. Guo, S3 23 Cr. 118 (AT), asks the Court to strike certain testimony of Mr. Guo's valuation expert Raymond Dragon.

Testimony Targeted

The government seeks to strike Dragon's testimony at transcript page 4893, which the government argues could only be relaying hearsay relating to:

• The purported sale of approximately $150 million of GTV shares by Saraca to "a very large investor" (transcript page 4893);
• A statement by the defendant contained in Government Exhibit Z9 (a summary that includes the text of the defendant's statements from various videos).

The testimony was elicited during defense redirect in response to the defendant's own out-of-court statements in Exhibit Z9 regarding the GTV private placement.

Government's Argument

The motion argues:

• A valuation expert may explain his methodology and conclusions but may not serve as a conduit for hearsay regarding specific historical transactions;
• Dragon's testimony about the $150 million Saraca sale to "a very large investor" introduces transaction-specific hearsay without the necessary foundation in admissible evidence;
• The testimony should be struck and the jury instructed accordingly.

The defense opposes at case-doc-390.