`
`
`ROBERT S. BREWER, JR.
`United States Attorney
`MELANIE K. PIERSON
`SABRINA L. FEVE
`RANDY S. GROSSMAN
`Assistant United States Attorney
`California Bar Nos. 112520/226590/177890
`880 Front Street, Room 6293
`San Diego, CA 92101-8893
`Tel: (619) 546-6786
`Sabrina.Feve@usdoj.gov
`Attorneys for the United States
`
`
`
`
`
`
`UNITED STATES DISTRICT COURT
`SOUTHERN DISTRICT OF CALIFORNIA
`
`Case No. 18cr04683-GPC
`UNITED STATES OF AMERICA,
`
`
`
`Plaintiff,
`GOVERNMENT MOTION TO
`
`PERMIT FILING OF AN OVERSIZED
`v.
`
`BRIEF
`
`
`JACOB BYCHAK (1),
`
`MARK MANOOGIAN (2),
`
`Honorable Gonzalo P. Curiel
`MOHAMMED ABDUL QAYYUM (3),
`
`PETR PACAS (4),
`Date: June 26, 2020
`
`
`Defendants.
`Time: 2:30 p.m.
`
`
`
`
`
`
`
`
`
`
`
`
`Plaintiff United States of America, by and through its counsel, United States
`Attorney Robert S. Brewer, Jr. and Assistant U.S. Attorneys Melanie K. Pierson,
`Sabrina L. Fève, and Randy S. Grossman, hereby files its Motion to Permit Filing of
`An Oversized Brief. In particular, the government seeks leave to file its 45-page
`Response in Opposition to Defendants’ Motion to Dismiss Wire Fraud Counts for
`Violating the Fifth Amendment Due Process and Sixth Amendment Fair Notice
`Protections (ECF No. 169).
`
`1
`2
`3
`4
`5
`6
`7
`8
`9
`10
`11
`12
`13
`14
`15
`16
`17
`18
`19
`20
`21
`22
`23
`24
`25
`26
`27
`28
`
`
`
`
`
`Case 3:18-cr-04683-GPC Document 177 Filed 06/08/20 PageID.1897 Page 2 of 2
`
`
`
`
`In support of its Motion for leave to file briefing in excess of the 25 pages
`permitted by Local Criminal Rule 47.1(e), the United States notes that Defendants’ brief
`is 32-pages long and their attached Request for Judicial Notice, which includes a
`separate Memorandum of Points and Authorities (“MPA”) from the MPA presented in
`support of their Motion to Dismiss, is 39 pages. ECF Nos. 169-1, 169-3. Defendants
`also submitted a 12-page Statement of Undisputed Facts. ECF No. 169-2. The
`government’s response addresses both sets of legal arguments submitted by Defendants,
`the parties’ factual disputes, and the questions the Court directed both parties to address
`during the April 8, 2020 telephonic status conference. The government requires
`additional pages in excess of the 25-page limit to provide the Court with a
`comprehensive legal and factual response to the novel arguments raised by Defendants
`in this complex case.
`
`
`DATED: June 8, 2020
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`Respectfully Submitted,
`
`ROBERT S. BREWER, JR.
`United States Attorney
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`________________________
`SABRINA L. FEVE
`Assistant United States Attorney
`
`Gov. Mot. To Permit Filing of An Oversized Br.
`
`
`
`
`-2-
`
`
`
`
`1
`2
`3
`4
`5
`6
`7
`8
`9
`10
`11
`12
`13
`14
`15
`16
`17
`18
`19
`20
`21
`22
`23
`24
`25
`26
`27
`28
`
`
`
`

Accessing this document will incur an additional charge of $.
After purchase, you can access this document again without charge.
Accept $ ChargeStill Working On It
This document is taking longer than usual to download. This can happen if we need to contact the court directly to obtain the document and their servers are running slowly.
Give it another minute or two to complete, and then try the refresh button.
A few More Minutes ... Still Working
It can take up to 5 minutes for us to download a document if the court servers are running slowly.
Thank you for your continued patience.

This document could not be displayed.
We could not find this document within its docket. Please go back to the docket page and check the link. If that does not work, go back to the docket and refresh it to pull the newest information.

Your account does not support viewing this document.
You need a Paid Account to view this document. Click here to change your account type.

Your account does not support viewing this document.
Set your membership
status to view this document.
With a Docket Alarm membership, you'll
get a whole lot more, including:
- Up-to-date information for this case.
- Email alerts whenever there is an update.
- Full text search for other cases.
- Get email alerts whenever a new case matches your search.

One Moment Please
The filing “” is large (MB) and is being downloaded.
Please refresh this page in a few minutes to see if the filing has been downloaded. The filing will also be emailed to you when the download completes.

Your document is on its way!
If you do not receive the document in five minutes, contact support at support@docketalarm.com.

Sealed Document
We are unable to display this document, it may be under a court ordered seal.
If you have proper credentials to access the file, you may proceed directly to the court's system using your government issued username and password.
Access Government Site