Miles Guo Court Documents · Doc 823
法庭文件 · 2026-03-23 · 3 页 · United States District Court · S.D.N.Y.
Rule 17(c) subpoena grantedmotion to quash deniedNixon standardstandingformer attorneyex parte to publicexpedited complianceApril 3 supplementation deadline
The court denies the government’s motion to quash and grants Mr. Guo’s Rule 17(c) subpoena request (with limits), allowing him to obtain specific documents from a former attorney for sentencing, while setting expedited deadlines to avoid delay.
摘要
Order · Rule 17(c) Subpoena Granted; Government's Motion to Quash Denied
This three-page order, signed by United States District Judge Analisa Torres and dated March 23, 2026, resolves the parties' competing positions on the defense's application for a Rule 17(c) subpoena directed at Mr. Guo's purported former attorney in United States v. Miles Guo, 23 Cr. 118 (AT).
Procedural Background Recited
The order traces the application's path:
- November 12, 2025 (Def. Ltr. I, ECF No. 815): Guo moved by ex parte letter for issuance of a Rule 17(c) subpoena seeking documents from his purported former attorney, claiming the documents would be relevant to his sentencing submission;
- January 13, 2026 (ex parte order): The Court directed Guo to supplement his application with greater specificity about the relevance and necessity of the materials sought;
- January 27, 2026 (Def. Ltr. II, ECF No. 816): Guo filed the supplement detailing the specifics, with the proposed scope of materials and information believed contained within;
- March 11, 2026 (ECF No. 814): The Court determined there was no good cause for continued ex parte handling, ordered Guo to serve the government with the prior ex parte letters and orders, and ordered Guo to file his letters on the docket. The Court also ordered the government to respond to the application;
- March 17, 2026 (Gov't Ltr. Mot. at 1, ECF No. 819): The government moved to quash on the grounds that the application fails to meet the United States v. Nixon, 418 U.S. 683 (1974) standard and would further delay resolution of the case.
Court's Disposition: Government's Motion to Quash Denied
The Court denies the government's motion to quash on standing grounds. The order recites that the government has not established any legitimate interest of its own in the subpoena issued to a third-party former attorney, and a motion to quash by a non-party must demonstrate the moving party's own legitimate interest in the materials.
Court's Disposition: Rule 17(c) Subpoena Issued
The Court grants Mr. Guo's application for a Rule 17(c) subpoena, with scope limits described in the order. The order sets expedited deadlines designed to avoid disruption of the then-scheduled April 27, 2026 sentencing:
- Compliance with the subpoena on an expedited timetable;
- Supplementation of Guo's sentencing submission with any responsive materials by April 3, 2026.
Downstream Effects
- Partial production triggers the motion to compel at case-doc-829;
- Supplementation flows into the Reply Sentencing Memorandum at case-doc-834;
- Briefing schedule adjustments documented in case-docs-824 and 825.
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