Guo Wengui / Miles Guo — criminal case · ECF #829

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April 2, 2026

By ECF Filing Honorable Analisa Torres United States District Judge Daniel Patrick Moynihan United States Courthouse 500 Pearl Street New York, NY 10007

Re: United States v. Ho Wan Kwok, et al.

23-CR-118 (AT)

Dear Judge Torres:

On behalf our client Miles Guo (a/k/a “Ho Wan Kwok”), the defense respectfully submits this letter motion to request that the Court enter an order compelling Mr. Guo’s former attorney to comply with the Rule 17(c) subpoena authorized by this Court on March 23, 2026 (ECF No. 823), and served on the recipient the same day. While we have received a small number of responsive documents from the former attorney, we do not consider the limited production to constitute full compliance with the subpoena. Due to the impracticability of setting forth the facts in support of this motion without disclosing the identity of the subpoenaed party, even with redactions, we have submitted a detailed letter motion with exhibits to the Court and to the Government under seal. Should the Court determine that the complete motion and exhibits should be filed on the docket, we will comply with any such order.

We note that we have endeavored to avoid any disruption to the April 27, 2026, sentencing date, and respectfully request that the Court order full compliance with the subpoena no later than April 10, 2026, and allow Mr. Guo until April 17, 2026, to supplement his sentencing memorandum based on the material received.

Respectfully submitted,

Melinda Sarafa Joshua Dratel John Kaley

cc: All counsel via ECF SARAFA ZELLAN