Case 3:18-cr-O4683-GPC Document237-2 Filed 06/09/21 PagelD.2424 Page10f4
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`EXHIBIT A
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`Case 3:18-cr-04683-GPC Document 237-2 Filed 06/09/21 PageID.2425 Page 2 of 4
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`Darren L. Patrick
`From:
`Sent:
`To:
`Cc:
`Subject:
`
`Feve, Sabrina (USACAS) <Sabrina.Feve@usdoj.gov>
`Tuesday, June 8, 2021 1:52 PM
`Nicole R. Van Dyk; Pierson, Melanie (USACAS); Heath, Candina (CRM)
`Darren L. Patrick
`RE: Petr Pacas Travel Request
`
`Dear Nicole,
`
`Thank you your thoughtful email introduction. I am including my colleague Melanie Pierson whom you already “know,”
`as well as Candy Heath from DOJ’S Computer Crime and Intellectual Property Section. While, as your client is likely
`already aware, the CDC has issued a high risk warning for travel to the Czech Republic due to public health concerns, we
`do not oppose Mr. Pacas’s request to travel there to visit family.
`
`Take care,
`Sabrina
`
`
`From: Nicole R. Van Dyk <nvandyk@birdmarella.com>
`Sent: Monday, June 7, 2021 3:52 PM
`To: Pierson, Melanie (USACAS) <MPierson@usa.doj.gov>; Feve, Sabrina (USACAS) <sfeve@usa.doj.gov>
`Cc: Darren L. Patrick <DPatrick@birdmarella.com>
`Subject: FW: Petr Pacas Travel Request
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`Dear Melanie and Sabrina,
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`First, I am writing to introduce myself – I will be joining the defense team on behalf of Mr. Pacas (along with my
`colleagues Gary Lincenberg and Darren Patrick) to take the place of Naeun Rim, who recently left the firm. It is a
`pleasure to meet you by email. My office contact information is below and my cell, should you need to reach me
`urgently for any reason, is 818‐448‐5807.
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`Second, I wanted to let you know that we plan to ask the Court to modify Mr. Pacas’s bond conditions to allow him to
`travel to the Czech Republic to visit his family this month. As set forth below, his pretrial services officer did not object
`to our request, provided that Mr. Pacas provides his travel information in advance and contacts pretrial services before
`and after his travel. I understand your office does not generally stipulate to these requests, but may I note your non‐
`objection?
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` I
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` look forward to working together.
`
`
`Best,
`Nicole
`
`
`Nicole Rodriguez Van Dyk
`Principal
`O: 310.201.2100
`F: 310.201.2110
`E: nvandyk@birdmarella.com
`Bird, Marella, Boxer, Wolpert, Nessim,
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`1
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`Case 3:18-cr-04683-GPC Document 237-2 Filed 06/09/21 PageID.2426 Page 3 of 4
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`Drooks, Lincenberg & Rhow, P.C.
`1875 Century Park East, 23rd Floor
`Los Angeles, California 90067‐2561
`www.BirdMarella.com
`
`
`From: Russell Parris <Russell_Parris@caspt.uscourts.gov>
`Sent: Monday, June 7, 2021 12:15 PM
`To: Nicole R. Van Dyk <nvandyk@birdmarella.com>
`Subject: RE: Petr Pacas Travel Request
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`**EXTERNAL EMAIL MESSAGE**
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`Good morning,
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`It is a pleasure to meet you as well. I would defer to the Court for this travel request and would ask that he follow the
`instructions that you outlined.
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`Thank you,
`
`Russell Parris
`U.S. Pretrial Services Officer
`Southern District of California
`(619) 557‐6266
`
`From: Nicole R. Van Dyk <nvandyk@birdmarella.com>
`Sent: Monday, June 7, 2021 10:54 AM
`To: Russell Parris <Russell_Parris@caspt.uscourts.gov>
`Subject: Petr Pacas Travel Request
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`CAUTION - EXTERNAL:
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`Dear Officer Parris,
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`First, it is a pleasure to meet you—I have replaced my former colleague Naeun Rim as counsel for Petr Pacas. My office
`contact information is below, and my cell is 818‐448‐5807.
`
`Second, I wanted to let you know we will be seeking a Court order to allow Mr. Pacas to travel to the Czech Republic to
`visit his family this month. No arrangements have yet been made, so we would request that he be permitted to travel in
`June with a return date on or before July 15, 2021. Do you have any objection to Mr. Pacas’s travel provided that (1) he
`gives his flight and accommodation information to pretrial services in advance, and (2) calls pretrial services prior to and
`upon returning?
`
`Thank you,
`Nicole
`
`Nicole Rodriguez Van Dyk
`Principal
`O: 310.201.2100
`F: 310.201.2110
`E: nvandyk@birdmarella.com
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`2
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`Case 3:18-cr-04683-GPC Document 237-2 Filed 06/09/21 PageID.2427 Page 4 of 4
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`Bird, Marella, Boxer, Wolpert, Nessim,
`Drooks, Lincenberg & Rhow, P.C.
`1875 Century Park East, 23rd Floor
`Los Angeles, California 90067‐2561
`www.BirdMarella.com
`
`
`CAUTION - EXTERNAL EMAIL: This email originated outside the Judiciary. Exercise caution when opening
`attachments or clicking on links.
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`3
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