Case 3:18-cr-04683-GPC Document 155 Filed 02/28/20 PageID.1369 Page 1 of 3
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`Gary S. Lincenberg - State Bar No. 123058
` glincenberg@birdmarella.com
`Naeun Rim - State Bar No. 263558
` nrim@birdmarella.com
`BIRD, MARELLA, BOXER, WOLPERT, NESSIM,
`DROOKS, LINCENBERG & RHOW, P.C.
`1875 Century Park East, 23rd Floor
`Los Angeles, California 90067-2561
`Telephone: (310) 201-2100
`Facsimile: (310) 201-2110
`
`Attorneys for Defendant Petr Pacas
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`UNITED STATES DISTRICT COURT
`SOUTHERN DISTRICT OF CALIFORNIA
`UNITED STATES OF AMERICA,
` CASE NO. 3:18-cr-04683-GPC-4
`
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`UNOPPOSED MOTION FOR
`Plaintiff,
`ORDER APPROVING TRAVEL
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`REQUEST
`vs.
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`PETR PACAS,
`Filed Concurrently with Declaration of
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`Naeun Rim; and [Proposed] Order
`Defendant.
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`Assigned to Hon. Gonzalo P. Curiel
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`Defendant Petr Pacas, by and through counsel of record, hereby submits this
`Unopposed Motion for an order from the Court to modify Mr. Pacas’s bond
`conditions (1) to permit him to travel within the Unites States of America during the
`pendency of this action, and (2) to permit him to travel to the Czech Republic in
`June of 2020, so long as Mr. Pacas provides his Pretrial Services Officer with a copy
`of his travel itinerary to the Czech Republic and calls Pretrial Services both prior to
`departure and immediately upon his return. The basis for this unopposed motion is
`as follows:
`On October 31, 2018, Mr. Pacas and co-defendants Jacob Bychak,
`1.
`Mark Manoogian, and Mohammed Abdul Qayyum were charged in a 10-count
`indictment for conspiracy to commit violations of the wire fraud statute (18 U.S.C.
`§ 1343) and the CAN-SPAM Act (18 U.S.C. § 1037(a)(5)). (Dkt. 1.)
`2.
`On November 5, 2018, Mr. Pacas was arraigned and released on a
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`Case No. 3:18-cr-04683-GPC-4
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`UNOPPOSED MOTION FOR ORDER APPROVING TRAVEL REQUEST
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`Case 3:18-cr-04683-GPC Document 155 Filed 02/28/20 PageID.1370 Page 2 of 3
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`$50,000 appearance bond secured by his signature. As a condition of release, his
`travel was restricted to San Diego County, the Central District of California, and the
`state of Utah at the discretion of his Pretrial Services Officer. (Dkt. 24.)
`3.
`This Court previously approved Mr. Pacas’s request to travel to the
`Czech Republic and Austria on December 20, 2018, to January 3, 2019. Mr. Pacas
`departed and returned on the approved dates as instructed without incident.
`4.
`This Court previously approved Mr. Pacas’s request to travel to Hawaii
`on September 24, 2019, to October 2, 2019. Mr. Pacas departed and returned on the
`approved dates as instructed without incident.
`5.
`The Court has designated this case complex. Due to pending pretrial
`motions, a trial date has not yet been set in this matter.
`6.
`On February 11, 2020, Pretrial Services Officer Irene Pflaum confirmed
`to defense counsel by email that she does not oppose the request to allow Mr. Pacas
`to travel within the United States during the pendency of this action. She also has no
`objection to Mr. Pacas traveling to the Czech Republic in June of 2020, so long as
`Mr. Pacas provides his Pretrial Services Officer with a copy of his travel itinerary
`and calls Pretrial Services both prior to departure and immediately upon his return.
`Her email approving the request is attached to the accompanying declaration of
`counsel. (See Decl. Rim. ¶ 4, Exh. A.)
`7.
`On February 11, 2020, the Government confirmed to defense counsel
`by email that it does not oppose this motion. (See id.)
`DATED: February 28, 2020
`Gary S. Lincenberg
`Naeun Rim
`Bird, Marella, Boxer, Wolpert, Nessim,
`Drooks, Lincenberg & Rhow, P.C.
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`By:
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`s/ Naeun Rim
`Naeun Rim
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`Attorneys for Defendant Petr Pacas
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`Case No. 3:18-cr-04683-GPC-4
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`UNOPPOSED MOTION FOR ORDER APPROVING TRAVEL REQUEST
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`Case 3:18-cr-04683-GPC Document 155 Filed 02/28/20 PageID.1371 Page 3 of 3
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`CERTIFICATE OF SERVICE
`Counsel for Defendant certifies that the foregoing pleading has been
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`electronically served on the following parties by virtue of their registration with the
`CM/ECF system:
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`Sabrina L. Feve
`Assistant U.S. Attorney
`sabrina.feve@usdoj.gov
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`Melanie K. Pierson
`Assistance U.S. Attorney
`melanie.pierson@usdoj.gov
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`Robert Ciaffa
`Assistant U.S. Attorney
`robert.ciaffa@usdoj.gov
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`Respectfully submitted,
`Gary S. Lincenberg
`Naeun Rim
`Bird, Marella, Boxer, Wolpert, Nessim,
`Drooks, Lincenberg & Rhow, P.C.
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`DATED: February 28, 2020
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`By:
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`s/ Naeun Rim
`Naeun Rim
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`Attorneys for Defendant Petr Pacas
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`Case No. 3:18-cr-04683-GPC-4
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`UNOPPOSED MOTION FOR ORDER APPROVING TRAVEL REQUEST
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