Miles Guo Court Documents · Doc 812

摘要

Government Letter · Opposition to Last-Minute Extension Request

This two-page letter, dated March 9, 2026 and signed by the Assistant U.S. Attorneys assigned to United States v. Miles Guo, S3 23 Cr. 118 (AT), opposes the defendant's same-day request for a one-week extension of the deadline to file his sentencing submission (filed at Dkt. 811, case-doc-811).

Procedural Context

The government characterizes the circumstances as exceeding a request for the courtesy of a short deadline extension to accommodate counsel:

• Guo's sentencing has been pending for over 18 months since his trial conviction;
• The deadlines set by the Court months ago in December 2025 remain in force;
• Counsel for the defendant waited until the arrival of the deadline, then contacted the assigned AUSAs via email at 4:19 p.m. on the deadline day requesting a call;
• The government called defense counsel shortly thereafter. During the call, defense counsel stated that they sought an additional week to file their submission;
• Defense counsel made clear that:
• The defendant was not withdrawing his one-month adjournment request (Dkt. 807, with government opposition at Dkt. 809);
• The defendant was not committing to file his submission in one week irrespective of that latest pending one-month adjournment request.

Government's Position

The letter argues there is no good cause — much less the "exceptional[]" good cause the Court said would be required for further adjournments (Dkt. 782) — for granting an extension at the eleventh hour of a deadline set by the Court months ago in December 2025 (Dkt. 782). The government recites that the Court specifically cautioned counsel months ago that "[n]o further adjournment of sentenc[ing]" would be granted absent exceptionally good cause.

Relief Sought

The government asks the Court to:

• Deny the eleventh-hour extension request;
• Enforce the existing deadlines for the defense's sentencing submission.