Miles Guo Court Documents · Doc 776

摘要

Defense Reply · Three-Month Adjournment Request

This four-page letter, dated December 17, 2025 from Melinda Sarafa (with co-counsel Joshua Dratel and John Kaley), replies in further support of Mr. Guo's December 3, 2025 request to adjourn sentencing — then scheduled for January 20, 2026 — for approximately three months in United States v. Ho Wan Kwok, et al., 23-CR-118 (AT).

Procedural Posture

• December 3, 2025 (ECF No. 768): Defense filed the fifth adjournment request, asking for approximately three months;
• December 11, 2025 (ECF No. 773): Government opposed, characterizing the request as further delay;
• December 17, 2025 (this letter): Defense replies in further support.

Defense's Reasons for Adjournment

The letter identifies multiple factors supporting the request:

1. Extraordinary volume of material: The case file contains material relevant to sentencing — both substantive and procedural — that current counsel had not yet been able to obtain or review;
2. Complexity of sentencing issues: The intersecting questions of loss amount, forfeiture, restitution, victim identification, and supporter statements present unusually complex sentencing posture;
3. Client's native-language review: Counsel emphasizes the need to ensure Mr. Guo can review sentencing materials in his native language (Mandarin Chinese) and provide meaningful feedback before submission;
4. Discovery and Rule 17(c) materials: Substantive items including the Rule 17(c) subpoena application and CIPA Section 4 questions remain pending and may produce additional materials requiring review;
5. CJA payment suspension: A temporary suspension of Criminal Justice Act payments contributed to scheduling pressure.

Tone

The defense characterizes the government's opposition (Dkt. 773) as "neither recogniz[ing], appreciat[ing], nor understand[ing]" the obligations of counsel for Mr. Guo — a sharper response than typical defense letters and reflecting the escalating tone of the late-2025 adjournment disputes.