Miles Guo Court Documents · Doc 853

摘要

Defense Motion to Adjourn the June 29, 2026 Sentencing

Counsel for Miles Guo (Melinda Sarafa, Joshua Dratel, and John Kaley) filed a letter-motion to the Honorable Analisa Torres on June 25, 2026, asking the Court to adjourn Mr. Guo's sentencing, then scheduled for June 29, 2026. Counsel state that, in their professional judgment, the case is not ready for sentencing because the volume and complexity of six outstanding issues make a fully informed and fair proceeding impossible on that date. The Government, through Assistant U.S. Attorney Ryan Finkel, opposes the request.

The six unresolved issues

1. Fatico hearing. Counsel state Mr. Guo requested a Fatico hearing (ECF Nos. 826-1, 834) to resolve the loss amount — described as the most significant issue affecting the Guidelines calculation — and alleged obstruction; the request remains pending.
2. Rule 17(c) subpoena. Counsel state a prior attorney has not fully complied with the Rule 17(c) subpoena served March 23, 2026; their April 2, 2026 motion to compel (ECF No. 829) is unresolved. They note the subpoenaed party ("Witness 1") characterized the requests as "wildly speculative" and "blunderbuss" in an April 30, 2026 sealed letter.
3. Brady motion. A sealed February 24, 2026 motion under Brady v. Maryland, 383 U.S. 73 (1963) seeking documents for sentencing remains outstanding; counsel ask, at minimum, for unredacted copies of USAO_00282658–USAO_00282813.
4. Motion to preserve assets. A September 4, 2025 letter-motion (ECF No. 724) seeking to direct the Government to obtain potentially forfeitable assets from the Chapter 11 bankruptcy Trustee remains unresolved and bears on any personal money judgment.
5. Special master. Following the January 20, 2026 conference and a March 17, 2026 order (ECF No. 820), the parties' proposals for a special master to address 21 U.S.C. § 853(n) claims remain open.
6. § 853(n) petitions. Counsel state thousands of investors filed § 853(n) petitions for return of seized funds; an unknown number were submitted directly to the U.S. Attorney's Office or via the Clerk and never docketed. A February 24, 2026 letter-motion (ECF No. 806) sought their production.

Supporter data update

Updating the figures from counsel's April 29, 2026 letter (ECF No. 843), counsel state that of 1,286 represented individuals — 1,182 of whom say they invested in one or more G Series entities — 1,223 expressly disclaim having been victimized by Mr. Guo, with disclosed G Series investments totaling $72,372,224.94. Counsel further report that 108 declarants say they were interrogated by the CCP, 35 say they were coerced into statements such as confessions or acknowledgements of fraud, 7 say they were forced to file false complaints against Mr. Guo, and 28 say they were arrested or prosecuted by the CCP. One supporter (SS30) asked to withdraw his statement.

Relief sought

Counsel respectfully request that sentencing be adjourned to a date allowing adequate time to resolve these issues and afford a fully informed and fair sentencing proceeding.