Case 3:18-cr-04683-GPC Document 155-1 Filed 02/28/20 PageID.1372 Page 1 of 6
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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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`
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`UNITED STATES DISTRICT COURT
`SOUTHERN DISTRICT OF CALIFORNIA
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` CASE NO. 18-CR-4683-GPC-4
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`DECLARATION OF NAEUN RIM
`IN SUPPORT OF UNOPPOSED
`MOTION FOR ORDER
`APPROVING TRAVEL REQUEST
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`Filed Concurrently with Unopposed
`Motion for Order Approving Travel
`Request; and [Proposed] Order
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`UNITED STATES OF AMERICA,
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`Plaintiff,
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`vs.
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`PETR PACAS,
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`Defendant.
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`I, Naeun Rim, declare as follows:
`I am an active member of the Bar of the State of California and a
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`Principal with Bird, Marella, Boxer, Wolpert, Nessim, Drooks, Lincenberg & Rhow,
`A Professional Corporation, attorneys of record for Defendant Petr Pacas in this
`action. I make this declaration in support of the Unopposed Motion for Order
`Approving Travel Request. Except for those matters stated on information and
`belief, I make this declaration based upon personal knowledge and, if called upon to
`do so, I could and would so testify.
`On February 11, 2020, I emailed Pretrial Services Officer Irene Pflaum
`2.
`to ask if she would approve a bond modification allowing Mr. Pacas to travel within
`the United States for the duration of this case. Officer Pflaum advised me by email
`that she did not object. I also asked Officer Pflaum whether she would approve
`Case No. 18-CR-4683-GPC-4
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`DECLARATION OF NAEUN RIM
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`Case 3:18-cr-04683-GPC Document 155-1 Filed 02/28/20 PageID.1373 Page 2 of 6
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`Mr. Pacas’s request to travel to the Czech Republic in June of 2020. She informed
`me that she did not object, so long as he provided to Pretrial Services his itinerary in
`advance and called his Pretrial Services Officer prior to departure and immediately
`upon return.
`On February 11, 2020, Assistant United States Attorney Sabrina Feve
`3.
`advised my office by email that the government has no objection to Mr. Pacas’s
`travel request.
`A true and correct copy of the February 11, 2020 email, reflecting the
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`correspondences described in paragraphs 2 and 3 above, is attached as Exhibit A to
`this declaration.
`I declare under penalty of perjury that the foregoing is true and correct.
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`Date: February 28, 2020
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`
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`s/ Naeun Rim
`Naeun Rim
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`DECLARATION OF NAEUN RIM
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`Case No. 18-CR-4683-GPC-4
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`Case 3:18-cr-04683-GPC Document 155-1 Filed 02/28/20 PageID.1374 Page 3 of 6
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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
`
`Melanie K. Pierson
`Assistance U.S. Attorney
`melanie.pierson@usdoj.gov
`
`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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`By:
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`s/ Naeun Rim
`Naeun Rim
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`Attorneys for Defendant Petr Pacas
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`DECLARATION OF NAEUN RIM
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`Case No. 18-CR-4683-GPC-4
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`DATED: February 28, 2020
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`Case 3:18-cr-04683-GPC Document 155-1 Filed 02/28/20 PageID.1375 Page 4 of 6
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`EXHIBIT A
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`Case 3:18-cr-04683-GPC Document 155-1 Filed 02/28/20 PageID.1376 Page 5 of 6
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`From:
`Sent:
`To:
`Subject:
`
`Feve, Sabrina (USACAS) <Sabrina.Feve@usdoj.gov>
`Tuesday, February 11, 2020 3:15 PM
`Naeun Rim; Pierson, Melanie (USACAS)
`RE: Petr Pacas
`
`No objection. We don’t usually stipulate, but you can note that it’s unopposed.
`
`From: Naeun Rim <nrim@birdmarella.com>
`Sent: Tuesday, February 11, 2020 2:33 PM
`To: Feve, Sabrina (USACAS) <sfeve@usa.doj.gov>; Pierson, Melanie (USACAS) <MPierson@usa.doj.gov>; Ciaffa, Robert
`(USACAS) <Robert.Ciaffa@usdoj.gov>
`Subject: FW: Petr Pacas
`
`Hello all—given the duration of this proceeding, we plan to ask the Court to modify Mr. Pacas’s bond conditions as
`follows:
`
`
`‐
`‐
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`To permit travel within the United States
`To allow him to travel in June to the Czech Republic, provided that he give his travel information to pretrial
`services and calls before leaving and after returning.
`
`His pretrial services officer has no objection. Are you willing to stipulate? Thanks very much.
`
`Naeun Rim
`Principal
`O: 310.201.2100
`F: 310.201.2110
`E: nrim@birdmarella.com
`Bird, Marella, Boxer, Wolpert, Nessim,
`Drooks, Lincenberg & Rhow, P.C.
`1875 Century Park East, 23rd Floor
`Los Angeles, California 90067‐2561
`www.BirdMarella.com
`
`From: Irene Pflaum <Irene_Pflaum@caspt.uscourts.gov>
`Sent: Tuesday, February 11, 2020 1:39 PM
`To: Naeun Rim <nrim@birdmarella.com>
`Subject: RE: Petr Pacas
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`He did not mention that to me, but as long as he provides all the information ahead of time and call prior to and upon
`returning.
`
`Thank you.
`
`From: Naeun Rim <nrim@birdmarella.com>
`Sent: Tuesday, February 11, 2020 1:35 PM
`To: Irene Pflaum <Irene_Pflaum@caspt.uscourts.gov>
`Subject: RE: Petr Pacas
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`Case 3:18-cr-04683-GPC Document 155-1 Filed 02/28/20 PageID.1377 Page 6 of 6
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`Thank you. Also, I forgot to mention that he has asked to travel to the Czech Republic to visit his family in June. He
`would, of course, provide his flight and accommodation information to pretrial services in advance. Do you have any
`objection to that?
`
`Naeun Rim
`Principal
`O: 310.201.2100
`F: 310.201.2110
`E: nrim@birdmarella.com
`Bird, Marella, Boxer, Wolpert, Nessim,
`Drooks, Lincenberg & Rhow, P.C.
`1875 Century Park East, 23rd Floor
`Los Angeles, California 90067‐2561
`www.BirdMarella.com
`
`From: Irene Pflaum <Irene_Pflaum@caspt.uscourts.gov>
`Sent: Tuesday, February 11, 2020 1:29 PM
`To: Naeun Rim <nrim@birdmarella.com>
`Subject: RE: Petr Pacas
`
`Hello, he did talk to me about it and I do not object to the request. Thank you.
`
`From: Naeun Rim <nrim@birdmarella.com>
`Sent: Tuesday, February 11, 2020 12:53 PM
`To: Irene Pflaum <Irene_Pflaum@caspt.uscourts.gov>
`Subject: Petr Pacas
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`Officer Pflaum,
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` I
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` am writing to let you know we will be seeking a Court order to allow Mr. Pacas to travel within the United States while
`he is on bond. Do you have any objections to this request? Thanks very much.
`
`Naeun Rim
`Principal
`O: 310.201.2100
`F: 310.201.2110
`E: nrim@birdmarella.com
`Bird, Marella, Boxer, Wolpert, Nessim,
`Drooks, Lincenberg & Rhow, P.C.
`1875 Century Park East, 23rd Floor
`Los Angeles, California 90067‐2561
`www.BirdMarella.com
`
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