Miles Guo Court Documents · Doc 465
First Motion to Continue Sentencing Dates and Related Deadlines for First and Second Disclosure of the Presentence Report. Filed by Miles Guo / (中文)
摘要
Defense Motion · First Continuance of Sentencing and Deadlines
This two-page filing, dated September 5, 2024 from Sabrina P. Shroff for the defense, is the formal motion for a 60-day extension of the November 19, 2024 sentencing date and the associated Probation deadlines in United States v. Ho Wan Kwok, 23 Cr. 118 (AT).
Procedural Posture
The filing is the formal motion that the memo endorsement at case-doc-466 partially grants. The defense's grounds are:
- The subject matter of the trial is dense;
- The trial record is lengthy;
- The issues to be tackled are not simple for either Probation or the defense;
- A one-time 60-day extension would allow Probation and the defense to develop a complete Presentence Report;
- The First Disclosure is currently due September 12, 2024;
- The Final Disclosure is currently due October 10, 2024;
- A 4-week extension of the First Disclosure and a corresponding extension of the Final Disclosure would align with a 60-day push of the sentencing date.
Conferences with Probation
The defense reports that Probation Officer McMahon was consulted and that both parties have made diligent efforts, with the additional time being a mutual administrative need rather than a unilateral defense request.