Guo Wengui / Miles Guo — criminal case · ORDER · ECF #231

Document 231

led 01/18/24 P


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AUSTIN BRUSSELS DALLAS DUBAI HOUSTON LONDON

NEW YORK PALO ALTO RIYADH SAN FRANCISCO SINGAPORE WASHINGTON

January 18, 2024

Brendan F. Quigley TEL: 2124082520 FAX: 2122592520 brendan.quigley@bakerbotts.com

The Honorable Analisa Torres United States District Judge Southern District of New York 500 Pearl Street New York, NY 10007

Re: *United States v. Yanping Wang, et al*., 23 Cr. 118-3 (AT)

Dear Judge Torres:

We represent Yanping Wang in this matter. We write in response to the Court's January 16, 2024 order directing us to inform the Court by today whether, in light of the new schedule in the case, Ms. Wang "intends to file a new omnibus motion, or whether [Ms. Wang] intends to rest on the arguments contained in her motion dated December 15, 2023." ECF No. 230.

Ms. Wang does not intend to file additional motions to suppress, for a bill of particulars, or for severance in light of the S2 Indictment. As such, and as we have discussed with the government, these motions will continue to be briefed on the schedule entered by the Court on November 15, ECF No. 175, with the government's opposition due today and Ms. Wang's reply due February 1.

Ms. Wang did join in portions Mr. Kwok's motion to dismiss the S1 Indictment, which the Court has now dismissed as moot. *See* ECF No. 230 ¶ 1. For avoidance of doubt, and while reserving all rights, Ms. Wang will file any motion to dismiss all or part of the S2 Indictment on the schedule in paragraph 1 of the Court's January 16 Order. *See id.*

Respectfully submitted,

/s/ Brendan F. Quigley Brendan F. Quigley