Case 3:18-cr-04683-GPC Document 237-1 Filed 06/09/21 PageID.2420 Page 1 of 4
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`Gary S. Lincenberg - State Bar No. 123058
` glincenberg@birdmarella.com
`Nicole R. Van Dyk - State Bar No. 261646
` nvandyk@birdmarella.com
`Darren L. Patrick - State Bar No. 310727
` dpatrick@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
`
`
`
`UNITED STATES OF AMERICA,
`
`Plaintiff,
`
`vs.
`
`PETR PACAS,
`
`Defendant.
`
`
`UNITED STATES DISTRICT COURT
`SOUTHERN DISTRICT OF CALIFORNIA
`
` CASE NO. 18-CR-4683-GPC-4
`
`DECLARATION OF DARREN L.
`PATRICK IN SUPPORT OF
`UNOPPOSED MOTION FOR
`ORDER APPROVING TRAVEL
`REQUEST
`
`Filed Concurrently with Unopposed
`Motion for Order Approving Travel
`Request; and [Proposed] Order
`
`I, Darren L. Patrick, declare as follows:
`I am an active member of the Bar of the State of California and an
`1.
`associate at 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 Mr. Pacas’s 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 June 7, 2021, my colleague Nicole Van Dyk, a principal of my firm
`2.
`whose application to appear in this Court is now pending, emailed Pretrial Services
`
`
`
`3723008.1
`
`
`
`1
`DECLARATION OF DARREN L. PATRICK
`
`Case No. 18-CR-4683-GPC-4
`
`

`

`Case 3:18-cr-04683-GPC Document 237-1 Filed 06/09/21 PageID.2421 Page 2 of 4
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`Officer Russell Parris to ask if he would approve a bond modification allowing Mr.
`Pacas to travel to the Czech Republic to visit his family in June of 2021, with a
`return date on or before July 15, 2021. Mr. Russell expressed no objection, so long
`as Mr. Pacas provides to Pretrial Services his itinerary in advance and calls his
`Pretrial Services Officer prior to departure and immediately upon return.
`On June 8, 2021, Assistant United States Attorney Sabrina Feve
`3.
`advised defense counsel by email that the government has no objection to Mr.
`Pacas’s travel request.
`A true and correct copy of defense counsel’s correspondence with
`4.
`Russell Parris and Sabrina Feve is attached as Exhibit A to this declaration.
`I declare under penalty of perjury that the foregoing is true and correct.
`
`Date: June 9, 2021
`
`
`
`s/ Darren L. Patrick
`Darren L. Patrick
`
`3723008.1
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`DECLARATION OF DARREN L. PATRICK
`
`Case No. 18-CR-4683-GPC-4
`
`

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`Case 3:18-cr-04683-GPC Document 237-1 Filed 06/09/21 PageID.2422 Page 3 of 4
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`CERTIFICATE OF SERVICE
`Counsel for Defendant certifies that the foregoing pleading has been
`
`electronically served on the following parties by virtue of their registration with the
`CM/ECF system:
`
`Ashley E. Goff
`Assistant U.S. Attorney
`Email: ashley.goff@usdoj.gov
`
`Sabrina L. Feve
`Assistant U.S. Attorney
`sabrina.feve@usdoj.gov
`
`Melanie K. Pierson
`Assistant U.S. Attorney
`melanie.pierson@usdoj.gov
`
`Candina S. Heath
`U.S. Department of Justice
`Email: candina.heath2@usdoj.gov
`
`
`3723008.1
`
`
`
`3
`DECLARATION OF DARREN L. PATRICK
`
`Case No. 18-CR-4683-GPC-4
`
`

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`Case 3:18-cr-04683-GPC Document 237-1 Filed 06/09/21 PageID.2423 Page 4 of 4
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`DATED: June 9, 2021
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`Respectfully submitted,
`
`Gary S. Lincenberg
`Nicole R. Van Dyk
`Darren L. Patrick
`Bird, Marella, Boxer, Wolpert, Nessim,
`Drooks, Lincenberg & Rhow, P.C.
`
`By:
`
`s/ Darren L. Patrick
`Darren L. Patrick
`
`Attorneys for Defendant Petr Pacas
`
`3723008.1
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`4
`DECLARATION OF DARREN L. PATRICK
`
`Case No. 18-CR-4683-GPC-4
`
`

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