---
type: court_doc
id: "court_sdny_829_0"
court: "SDNY"
case_no: ""
doc_number: 829
doc_type: "DOC"
filed_date: "2026-04-02"
lang: "en"
machine_translated: false
url: "https://mubeitech.com/en/court/court_sdny_829_0"
json_url: "https://mubeitech.com/api/court/court_sdny_829_0"
---
# Guo Wengui / Miles Guo — criminal case · ECF #829

**Defense Counsel Motion Letter —— United States v. Ho Wan Kwok (Miles Guo / Guo Wengui), SDNY 1:23-cr-00118 ECF #829 (filed April 2, 2026). Defense counsel for Miles Guo requested that the Court order the defendant's former attorney to comply fully with a Rule 17(c) subpoena authorized by the Court, arguing that the former attorney's production was incomplete; counsel requested specific compliance deadlines and leave to supplement the sentencing memorandum based on materials received.**


43 West 43rd Street, Suite 370　New York, NY 10036
212.785.7577　646.868.8266 (fax)
www.sarafazellan.com

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