Miles Guo Court Documents · Doc 768
Mr. Guo’s defense team asks the judge to delay his January 2026 sentencing by about three months because the case materials are extremely large and complex, require translation, and past funding delays hindered their preparation.
摘要
Defense Letter · Fifth Adjournment Request · Three Months
This two-page letter, dated December 3, 2025 from John F. Kaley of Doar Rieck Kaley & Mack (with co-counsel Joshua L. Dratel and Melinda Sarafa), asks Judge Analisa Torres to adjourn Mr. Guo's sentencing — then scheduled for January 20, 2026 — for approximately three months in United States v. Ho Wan Kwok (Miles Guo), S3 23 Cr. 118 (AT).
Procedural Note
Counsel reports that AUSA Ryan Finkel opposes the request on behalf of the government and intends to submit written opposition.
Defense's Stated Reasons
The letter identifies multiple grounds for additional time:
1. Underestimation of review burden: The defense underestimated the time needed to review:
- A 6,000-page trial transcript;
- Thousands of pages of exhibits;
- Hours of video recordings admitted into evidence;
- Substantial 3500 (Jencks Act / Giglio) material provided to counsel;
- The staggering volume of discovery produced;
2. Complexity of sentencing issues: Including loss-amount disputes, forfeiture, restitution, victim identification, and supporter statements;
3. Translation needs: Materials require translation into Mandarin to ensure Mr. Guo can meaningfully review them in his native language and provide feedback;
4. CJA payment suspension: A temporary suspension of Criminal Justice Act payments contributed to schedule pressure during a critical preparation window;
5. Pending motions: The Rule 17(c) subpoena application and CIPA Section 4 issues remain pending; their resolution may produce additional materials counsel must consider.