{"id":"court_sdny_91_0","court":"SDNY","case_no":"23-cr-00118","doc_number":91,"sub_number":0,"doc_type":"LETTER","filed_date":null,"title":"![](_page_0_Picture_0.jpeg) June 23, 2023","summary_zh":"诉讼文件—律师信函（美国诉 Ho Wan Kwok/郭文贵等案，SDNY 1:23-cr-00118 ECF 91，2023年6月23日立案）—— Yanping Wang 的代理律师向法官 Analisa Torres 申请延期提交答辩意见。律师声称政府新增事实指控（包括妨碍司法罪名），需时间调查。","summary_en":"Litigation Document — Counsel Letter (United States v. Ho Wan Kwok / Miles Guo et al., SDNY 1:23-cr-00118, ECF 91, filed June 23, 2023) — Counsel for defendant Yanping Wang requests extension to file reply to government opposition. States government allegations include newly alleged factual matters and obstruction of justice charges requiring investigation.","body_en":"![](_page_0_Picture_0.jpeg)\n\nJune 23, 2023\n\n*Via* **ECF**\n\nHon. Analisa Torres United States District Judge Southern District of New York 500 Pearl Street New York, NY 10007\n\n## *Re: United States v. Yanping Wang***, S1 1:23-cr-00118-AT**\n\nDear Hon. Judge Torres:\n\nAlong with Lipman Law PLLC, we represent Ms. Yanping Wang in the above-referenced matter. On June 5, 2023, Ms. Wang filed her bail application (ECF No. 81) and on June 6, 2023, the Court set a briefing schedule for the government's opposition to Ms. Wang's bail application (which was due and filed on June 20, 2023, ECF No. 89) and Ms. Wang's reply to the government's application, which is currently due on June 28, 2023. We respectfully request a three-day extension to file Ms. Wang's reply, which would change the filing date to June 30, 2023.\n\nThe reasons for our request are: 1) the government's opposition contains entirely new factual allegations (including obstruction of justice) against Ms. Wang, 2) because Ms. Wang is in custody and counsels' schedule, today was the first day we were able to meet with her to discuss these new allegations, and 3) we need additional time to investigate these new allegations so we can effectively respond to them. This is our first request for an extension to file Ms. Wang's reply. The government does not object to this request. The requested adjournment will not affect any other scheduled date in this matter.\n\nWe thank Your Honor in advance for Your courtesy.\n\nRespectfully submitted,\n\nPriya Choudhary\n\nPriya Chaudhry","body_zh":null,"key_entities":["Yanping Wang","Torres","Je","Analisa Torres"],"ecf_references":[{"doc_number":81,"court":"SDNY"},{"doc_number":89,"court":"SDNY"}],"word_count":250,"status":"published","published_at":null,"created_at":null,"updated_at":"2026-07-21 05:53:34"}