Miles Guo Court Documents · Doc 780
Mr. Guo’s lawyers argue again that they need more time to prepare for sentencing and reject the government’s claims that the delay is intentional.
摘要
Defense Reply · Adjournment Briefing (December 18, 2025)
This two-page letter, dated December 18, 2025 from John F. Kaley of Doar Rieck Kaley & Mack (with co-counsel Joshua Dratel and Melinda Sarafa), replies in brief to the government's December 17, 2025 letter (Dkt. 779, case-doc-779) reiterating its opposition to the defense's request for an adjournment of sentencing in United States v. Ho Wan Kwok (Miles Guo), S3 23 Cr. 118 (AT).
Tone
The defense characterizes the government's letter as last-minute arguments with "even less merit than the meritless arguments raised in the Government's initial opposition letter." The defense addresses the government's arguments seriatim.
Defense's Principal Points
1. Need for Time at Sentencing Differs from Trial Preparation
The government argues current counsel has not explained why they need additional time to prepare for sentencing and that the defense seeks more time than prior counsel needed to prepare for trial. The defense responds that it has addressed this point and will not burden the Court with further reiteration, noting the difference in issues presented at this stage of the case.
2. Rule 17(c) Discovery Requirement
The government hypothesizes that counsel would have had to sufficiently review prior discovery materials before seeking the Rule 17(c) subpoena. The defense disputes this characterization, arguing that the Rule 17(c) materials seek information from a third party that is not in the defense's possession by definition.