Miles Guo Court Documents · Doc 811
Mr. Guo’s newly appointed counsel asks the court for one more week to file the sentencing memorandum, explaining that the case materials are extensive and complex and that they need additional time to prepare a complete submission.
摘要
Defense Letter · One-Week Extension Request from Newly Appointed Counsel
This one-page letter, dated March 9, 2026 from John F. Kaley of Doar Rieck Kaley & Mack (with co-counsel Joshua L. Dratel and Melinda Sarafa), asks Judge Analisa Torres for one additional week to file Mr. Guo's sentencing memorandum in United States v. Ho Wan Kwok (Miles Guo), S3 23 Cr. 118 (AT).
Procedural Posture
- Counsel state they have been appointed to represent Mr. Guo;
- Sentencing was then scheduled for April 13, 2026 (ECF No. 782);
- The sentencing memorandum was due on the date of the letter (March 9, 2026).
Reasons Cited
The letter sets out:
- Counsel for Mr. Guo continue to work diligently on the matter;
- The amount of information gathered is "nothing short of staggering";
- Counsel is trying to synthesize that information and set it forth in a manner that is of assistance to the Court and fully reflects all arguments (both as to facts and law) regarding sentencing;
- The information is complex;
- The defense has two motions presently before the Court seeking access to information that is of critical importance (referring to the Rule 17(c) subpoena and the CIPA Section 4 motion);
- Despite best efforts and the extraordinary amount of time devoted to the case, counsel are simply unable to complete the sentencing submission on the deadline date and are constrained by their professional obligations to make this request.
Coordination
The letter reports that counsel has conferred with the government regarding this request and awaits the government's position. The government filed its opposition the same day (case-doc-812).
Relief Requested
Counsel requests one additional week to file the sentencing submission.