Miles Guo Court Documents · Doc 790

摘要

Government Letter Motion · Supplemental Preliminary Order of Forfeiture

This four-page letter motion, dated January 19, 2026 from the Assistant U.S. Attorneys assigned to United States v. Miles Guo, S3 23 Cr. 118 (AT), asks Judge Analisa Torres to enter the proposed supplemental preliminary order of forfeiture attached as Exhibit A. The supplemental POF relates to additional specific property the government identifies as traceable to the defendant's crimes and to property involved in the laundering of those proceeds.

Defense's Position

The letter notes that Guo "takes 'no position with respect to any personal interest he may have in the assets the Government seeks to forfeit'" (citing Dkt. 789, case-doc-789), leaving the supplemental POF effectively unopposed as to specific property.

I. Applicable Law

A. Racketeering Forfeiture

Section 1963 directs that a district court, in imposing sentence, "shall order" a defendant to forfeit:

1. Any interest the person has acquired or maintained in violation of Section 1962;
2. Any:
- (A) interest in;
- (B) security of;
- (C) claim against; or
- (D) property or contractual right of any kind affording a source of influence over
the RICO enterprise; and
3. Any property constituting, or derived from, any proceeds which the person obtained, directly or indirectly, from racketeering activity or unlawful debt collection in violation of section 1962.

The motion cites 18 U.S.C. § 1963(a).

B. Fraud Forfeiture

Section 981(a)(1)(C) subjects to civil forfeiture: "Any property, real or personal, which constitutes or is derived from proceeds traceable to . . . any offense constituting 'specific unlawful activity' (as defined in section 1956(c)(7) of this title), or a conspiracy to commit such offense."

Property at Issue

The Supplemental POF's Exhibit A identifies the additional specific bank-account funds, luxury items, and related property the government seeks to add to the previously entered Preliminary Order of Forfeiture (case-doc-720). The motion frames these as funds traceable to the offense conduct proven at trial, including racketeering and fraud proceeds and property involved in money laundering.