Guo Wengui / Miles Guo — criminal case · ORDER · ECF #8

## UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK

UNITED STATES OF AMERICA,

v.

YANPING WANG,

Defendant.

Case No. 23-MAG-2007

## **NOTICE OF MOTION FOR AN ORDER DIRECTING DEFENDANT HAS COMPLIED WITH THE TERMS OF HER BAIL CONDITIONS**

**PLEASE TAKE NOTICE** that, pursuant to 18 U.S.C. § 3142, upon the accompanying Memorandum of Law, Defendant Yanping Wang, by and through her counsel, ChaudhryLaw PLLC and Lipman Law PLLC, respectfully moves this Court before the Honorable Robert W. Lehrburger, United States Magistrate Judge, Daniel Patrick Moynihan United States Courthouse, 500 Pearl Street, New York, NY 10007, for an Order approving Defendant's proffered bond cosigners heretofore arbitrarily rejected by the government; or, alternatively, to amend Defendant's bail conditions to eliminate the requirement that she obtain two financially responsible persons to co-sign her bond.

Dated: New York, New York March 24, 2023

ChaudhryLaw PLLC

By: */s/ Priya Chaudhry* Priya Chaudhry 147 W. 25th Street, 12th Floor New York, New York 10001 Tel: (212) 785-5550 Email: priya@chaudhrylaw.com

> Alex Lipman Lipman Law PLLC 147 W. 25th Street, 12th Floor New York, New York 10001 Tel: (212) 401-0070 Email: alexlipman@limpanpllc.com

*Attorneys for Defendant Yanping Wang*