Case 3:18-cr-04683-GPC Document 240 Filed 06/11/21 PageID.2450 Page 1 of 12
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`BIENERT KATZMAN
`LITTRELL WILLIAMS LLP
`Thomas H. Bienert, Jr., SBN 135311
`James D. Riddet, SBN 39826
`Whitney Z. Bernstein, SBN 304917
`903 Calle Amanecer, Suite 350
`San Clemente, California 92673
`Telephone: (949) 369-3700
`Email: tbienert@bklwlaw.com
` jriddet@bklwlaw.com
` wbernstein@bklwlaw.com
`
`BIRD MARELLA BOXER WOLPERT
`NESSIM DROOKS LINCENBERG
`RHOW P.C.
`Gary S. Lincenberg, SBN 123058
`Nicole Rodriguez Van Dyk, SBN 261646
`Darren L. Patrick, SBN 310727
`1875 Century Park East, Floor 23
`Los Angeles, CA 90067
`Telephone: (310) 201-2100
`Email: glincenberg@birdmarella.com
`nvandyk@birdmarella.com
` dpatrick@birdmarella.com
`Attorneys for Mohammed Abdul Qayyum
`Attorneys for Petr Pacas
`WIECHERT, MUNK &
`GOLDSTEIN, PC
`David W. Wiechert, SBN 94607
`Jessica C. Munk, SBN 238832
`27136 Paseo Espada, Suite B1123
`San Juan Capistrano, CA 92675
`Telephone: (949) 361-2822
`Email: dwiechert@wmgattorneys.com
` jessica@wmgattorneys.com
`Attorneys for Jacob Bychak
`
`MINTZ, LEVIN, COHN, FERRIS,
`GLOVSKYAND POPEO, P.C.
`Randy K. Jones, SBN 141711
`3580 Carmel Mountain Road, Suite 300
`San Diego, CA 92130
`Telephone: (858) 314-1510
`Email: rkjones@mintz.com
`Attorney for Mark Manoogian
`
`IN THE UNITED STATES DISTRICT COURT
`FOR THE SOUTHERN DISTRICT OF CALIFORNIA
`
`UNITED STATES OF AMERICA,
`
`Plaintiff,
`
`v.
`
`JACOB BYCHAK, MARK
`MANOOGIAN, MOHAMMED ABDUL
`QAYYUM, AND PETR PACAS,
`
`Defendants.
`
`Case No. 18-cr-04683-GPC
`Hon. Gonzalo P. Curiel
`
`DEFENDANTS’ JOINT MOTION
`TO CONTINUE TRIAL
`[Filed concurrently with the Declaration of
`Whitney Z. Bernstein; [Proposed] Order]
`
`18-cr-04683-GPC
`DEFENDANTS’ JOINT MOTION TO CONTINUE TRIAL
`
`

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`Case 3:18-cr-04683-GPC Document 240 Filed 06/11/21 PageID.2451 Page 2 of 12
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`TO PLAINTIFFS AND THEIR ATTORNEYS OF RECORD:
`PLEASE TAKE NOTICE THAT Jacob Bychak, Mark Manoogian, Mohammed
`Abdul Qayyum, and Petr Pacas (collectively, the “Defendants”), will and hereby do move
`this Court for an order continuing the jury trial currently set for November 30, 2021 to
`September 2022 (with a concomitant extension of related deadlines) (the “Motion”).
`The Defendants respectfully request that the Court continue the current November
`30, 2021 trial date in light of a conflicting trial proceeding in an Arizona federal court case,
`which impacts three of the lead trial attorneys in this case. The Arizona federal case
`predates this case by several months, involves six defendants, a dozen of defense counsel,
`six prosecutors, three government case agents, and 90 proposed witnesses for the
`government’s case in chief. The Arizona federal case is estimated to last from August 23,
`2021 into December 2021, and counsel expects it may last even longer. Further warranting
`the extended continuance request is the fact that trial counsel for Mr. Bychak, Mr. Qayyum,
`and Mr. Pacas are scheduled for other trials through June of 2022. Counsel for Mr. Bychak
`has an in-custody federal first-degree murder case that was recently continued to the third
`week of January 2022 with a two-week trial estimate, and both trial attorneys for Mr.
`Bychak have a complex healthcare fraud case in mid-February of 2022 with a four-to-five-
`week trial estimate. Also, trial counsel for Mr. Bychak has an SEC case scheduled to go to
`trial on April 4, 2022, with a two-week trial estimate, and both trial attorneys for
`Mr. Bychak have an IEEPA case that was indicted in early 2018 that has been continued
`seven times and is set for trial on May 24, 2022, with a three-week estimate. All of these
`cases counsel for Mr. Bychak expect to go to trial. Further, both trial attorneys for
`Mr. Qayyum are separately scheduled for a month-long trial in both January and late
`February of 2022, and trial attorneys for Mr. Pacas are also scheduled for a month-long trial
`in late February of 2022 and late April 2022. Therefore, the requested trial continuance to
`September of 2022 is necessary to permit the aforementioned trial attorneys to adequately
`prepare for trial in this complex case through the summer of 2022. This Motion is the first
`trial continuance request in this case.
`
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`DEFENDANTS’ JOINT MOTION TO CONTINUE TRIAL
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`18-cr-04683-GPC
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`Case 3:18-cr-04683-GPC Document 240 Filed 06/11/21 PageID.2452 Page 3 of 12
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`The Motion is based on the attached memorandum of points and authorities, the
`Declaration of Whitney Z. Bernstein, all pleadings documents on file in this case, and upon
`such other written and oral argument as may be presented to the Court at any hearing on
`this matter.
`
`Dated: June 11, 2021
`
`Dated: June 11, 2021
`
`Dated: June 11, 2021
`
`Dated: June 11, 2021
`
` Respectfully Submitted,
`
`BIENERT KATZMAN
`LITTRELL WILLIAMS LLP
`By: Whitney Z. Bernstein
` Thomas H. Bienert, Jr.
` James D. Riddet
` Whitney Z. Bernstein
` Attorneys for Abdul Mohammed
`
`BIRD, MARELLA, BOXER, WOLPERT,
`NESSIM, DROOKS, LINCENBERG &
`RHOW, P.C.
`By: Gary S. Lincenberg
` Gary S. Lincenberg
`Nicole Rodriguez Van Dyk
` Darren L. Patrick
` Attorneys for Petr Pacas
`
`MINTZ, LEVIN, COHN, FERRIS,
`GLOVSKY AND POPEO, P.C.
`By: Randy K. Jones
` Randy K. Jones
` Attorneys for Mark Manoogian
`
`WIECHERT, MUNK & GOLDSTEIN, PC
`By: Jessica C. Munk
` David W. Wiechert
` Jessica C. Munk
` Attorneys for Jacob Bychak
`
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`18-cr-04683-GPC
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`I.
`
`MEMORANDUM OF POINTS & AUTHORITES
`INTRODUCTION
`The Defendants bring this Motion for an order continuing the trial from November
`30, 2021 to a date in September of 2022. The lead trial counsel for Mr. Qayyum and
`Mr. Pacas will be in the middle of a lengthy 16-week trial in Arizona (the “Arizona Case”)
`(United States v. Lacey, et al. (D. Ariz.), Case No. 18-CR-00422-PHX-SMB).
` At a status conference on January 21, 2021, Defendants diligently advised the Court
`that three out of seven trial counsel (representing half of the Defendants) would be
`unavailable during the Fall of 2021 due to trial in the Arizona Case, which at the time was
`expected to be continued to September of 2021. Aware of a potential conflict created by
`the Arizona Case, the Court proceeded to set the instant case for November 30, 2021, with
`the caveat of: “[w]e are all going to have to be somewhat flexible, even this Court, because
`of the number of attorneys that are involved in this litigation.” Declaration of Whitney Z.
`Bernstein (“Bernstein Decl.”), ¶ 9, Ex. A at 15:17-19 (Transcript of January 21, 2021 Status
`Conference).
`In light of that, and forecasting an influx of factors arising from the COVID-19 health
`crisis, this Court set the trial date for November 30, leaving open the possibility of a further
`continuance if the Arizona Case created an untenable conflict: “it looks like everyone is
`free in October, November, December, unless [the Arizona Case] is continued until
`September; and if its continued to September; if it actually goes forward.” Bernstein Decl.
`¶ 9, Ex. A at 16:17-19. As it turns out, the Arizona Case was continued to August 23, 2021,
`and is all but certain to proceed.
`Moreover, the government is not expected to suffer any prejudice from this
`continuance since it has known of Defendants’ counsel’s potential trial conflicts since the
`January 2021 status conference. At the extreme opposite, two of the Defendants will suffer
`severe and irremediable prejudice if they are compelled to face the trial of their lives without
`their chosen counsel, who have represented them since 2018 and are intimately familiar
`with the complex set of facts involved here. Because of the numerous issues of first
`
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`impression that were previously rigorously briefed and remain issues at trial, it is imperative
`that Mr. Qayyum and Mr. Pacas have their desired trial counsel. A continuance in this
`matter is necessary.
`RELEVANT FACTS
`II.
`On March 28, 2018, an indictment was filed against the defendants in the Arizona
`Case. Several months later, on October 31, 2018, the government filed an indictment
`against Defendants in this case. See Dkt. No. 1. The Arizona Case was initially set for trial
`on January 15, 2020, then continued sua sponte to May 5, 2020, for a third time to August
`17, 2020, for a fourth time to January 12, 2021, and then again to April 12, 2021. Bernstein
`Decl., ¶ 5. On January 19, 2021, the defendants in the Arizona Case filed a request for a
`sixth trial continuance due to the ongoing health crisis occasioned by the COVID-19
`pandemic. Id. at ¶ 5. On January 21, 2021, this Court contemplated a trial date for this
`case. Defendants diligently advised this Court of the continuance motion pending in the
`Arizona Case and the likelihood that it would be granted. See Ex. A at 7:2-3 (“And there’s
`now a continuance motion [in the Arizona Case], which – the Court hasn’t granted it yet
`but I think the Court is going to have to because of COVID reasons.”). Defendants’ counsel
`also informed the Court that the Arizona Case would likely conflict with any date set in the
`Fall of 2021: “[a]nd we are looking to start it in September, and it is a three-month trial.”
`See id. at 7:4-5. The attorneys who will be participating in the Arizona Case are Thomas
`H. Bienert, Jr. and Whitney Z. Bernstein (Mr. Qayyum’s trial counsel) and Gary S.
`Lincenberg (Mr. Pacas’ trial counsel). Bernstein Decl., ¶ 2.
`As such, at the time of the January 21, 2021 status conference, Defendants’ counsel
`concurred that May of 2022 would be the earliest—and in fact only—feasible trial date, as
`counsel had several pre-scheduled trial conflicts at that time. See id at 7:17-18 (“this is
`what led us to propose May 2022 because any earlier date, I am just not sure it is going to
`be a real date because of all of the traffic jam of trials.”).
`Since the January 2021 hearing in this case, defense counsel have been set for various
`other trials, which prohibit both the current trial date and the formerly requested May trial
`
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`date. Counsel for Mr. Qayyum and Mr. Pacas are in trial on the Arizona case from August
`2021 to December 2021. Additionally, trial counsel for Mr. Bychak has an in-custody
`federal first-degree murder case that was recently continued to the third week of January
`2022 with a two-week trial estimate, both trial attorneys for Mr. Bychak have a complex
`healthcare fraud case in mid-February of 2022 with a four-to-five-week trial estimate, trial
`counsel for Mr. Bychak has an SEC case scheduled to go to trial on April 4, 2022, with a
`two-week trial estimate, and both trial attorneys for Mr. Bychak have an IEEPA case that
`was continued after the January 21, 2021 status conference to May 24, 2022, which a three-
`week estimate. This IEEPA case was indicted in early 2018 and has been continued seven
`times. Counsel for Mr. Bychak expects all of these cases to go to trial. Further, both trial
`attorneys for Mr. Qayyum are separately scheduled for a month-long case in both January
`and late February of 2022, and trial counsel for Mr. Pacas is also scheduled for a month-
`long case in late February and late April of 2022. Unfortunately, based on counsel’s current
`trial calendar, a trial date in May of 2022 is no longer feasible.
`Moreover, at the January 2021 status conference, the Court noted counsel’s conflicts
`and appeared ready to set the trial date for this case after Fall of 2021. See Ex. A at 7:21-
`23 (“Well, it sounds like the fall wouldn’t be practicable. It wouldn’t be likely that we would
`be able to get this case tried in the fall.”). Indeed, the Court recognized that having this trial
`in 2022 was an appealing option, given the logistical complications attendant with the
`COVID-19 crisis: “Well, kicking out to 2022 would make it easier for the Court to work its
`way out of the backlog of trials that it will be facing.” Ex. A at 4:21-23. Nevertheless, the
`Court proceeded to set the current trial date.
` The court in the Arizona Case subsequently granted the defendants’ pending motion
`and continued the trial date from April 12, 2021 to August 23, 2021. Bernstein Decl. ¶ 4.
`As a result, the Arizona Case is expected to last into December 2021.
`III. ARGUMENT
`The Court has the discretion to grant an order continuing the trial date. See United
`States v. Flynt, 756 F. 2d1352, 1358 (9th Cir. 1985) (recognized the broad discretion of trial
`
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`courts to rule on requests for continuances). A district court abuses its discretion in denying
`a trial continuance motion for “arbitrary or unreasonable” reasons. Id. In this case, the
`Defendants’ first request for a trial continuance is reasonable and justified.
`Flynt prescribes a four-factor test that district courts should apply when considering
`trial continuances. See 756 F. 2d at 1359. Accordingly, courts should consider: (1) whether
`the defendant has been diligently preparing for their trial defense or whether the continuance
`request is a delay tactic; (2) the utility of the continuance; (3) the inconvenience that a
`continuance would cause to the court and other parties; and (4) whether the defendant is
`prejudiced by the denial. Id. Here, all four factors militate in favor of the Defendants’
`continuance request.
`Defendants have diligently prepared for trial.
`1.
`There is no dispute that Defendants have been diligently preparing for their trial
`defense. See generally United States v. Kloehn, 620 F.2d 1122 (2010) (district court abused
`its discretion and prejudiced defendant’s ability to present a defense in refusing to continue
`trial). Prior to when the Court set the current trial date, and ever since, Defendants and their
`counsel have worked assiduously to review voluminous discovery productions generated
`by the government’s years-long investigation, conducted their own investigation, and
`strategized pre-trial and in limine motion practice. This factor thus supports a trial
`continuance.
`2.
`
`The requested trial continuance is necessary to respect Mr.
`Qayyum’s and Mr. Pacas’ counsel of choice.
`The constitution guarantees a criminal defendant the right to counsel of his or her
`choosing. See Luis v. United States, 136 S. Ct. 1083, 1085 (2016); see also Powell v.
`Alabama, 287 U.S. 45, 53 (1932). The lead trial counsel for both Mr. Qayyum and Mr.
`Pacas – who have handled their defense since at least 2018 – have conflicting duties in the
`Arizona Case and will not be available for trial on November 30, 2021. See Bernstein Decl.,
`¶ 7. At this point in time, it is virtually certain that trial in the Arizona Case will proceed
`as currently scheduled.
`
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`18-cr-04683-GPC
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`Case 3:18-cr-04683-GPC Document 240 Filed 06/11/21 PageID.2457 Page 8 of 12
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`For added reference, that case commenced on March 28, 2018, and predates this case
`by approximately seven months. See Bernstein Decl., ¶ 3. To date, it has been continued
`six times. See id. The Arizona Case was originally set to start trial on January 15, 2020,
`then continued sua sponte to May 5, 2020, for a third time to August 17, 2020, for a fourth
`time to January 12, 2021, for a fifth time to April 12, 2021, and most recently to August 23,
`2021, due to the COVID-19 health crisis. Bernstein Decl., ¶ 5. Moreover, the Arizona case
`involves six defendants, a dozen of defense counsel, six prosecutors, three government case
`agents, and 90 proposed witnesses for the government’s case in chief. See id. at ¶ 5.
`Unfortunately, since the January 21, 2021 status conference, the trial calendar for
`Mr. Bychak’s attorneys has changed, and they are no longer available in May of 2022.
`Accordingly, counsel for Mr. Bychak have a trial set to commence on May 24, 2022, with
`a three-week estimate. This case has already been continued 7 times and trial is very likely
`to proceed in May of 2022. Therefore, in order to afford counsel the opportunity to properly
`prepare for this complex case, a trial continuance to September of 2022 is warranted. This
`factor also weighs in favor of a continuance.
`Neither the government nor the Defendants will be harmed by this
`3.
`trial continuance.
`No party in this case will experience harm from the requested trial continuance.
`Mr. Qayyum and Mr. Pacas, joined in this Motion by Mr. Bychak and Mr. Manoogian,
`collectively requested a trial date for May of 2022 at the time the Court set the initial trial
`date in January 2021. See Ex. A at 7:17-18. Although the government objected to the
`Defendants’ requested trial date (and opposes this Motion), the government was aware of
`the trial conflicts impacting Defendants’ counsel’s schedules as of the January 2021
`hearing. See Ex. A at 9:6-7; 9:17-18 (“The government really wants to get to trial sooner
`rather than later.”). However, this objection was perplexing in light of the serious health
`concerns and logistical nightmares occasioned by the COVID-19 crisis—a fact recognized
`by this Court and by Chief Judge Burns. See Ex. A at 11:21-23 (“there are certainly lots of
`moving parts, and it is a dynamic situation, given COVID.”); see also Chief Judge Order
`
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`No. 52C, Extending Renewed Suspension of Jury Trials and Other In-Person Proceedings
`During Covid-19 Public Emergency (Jan. 13, 2020). While the government will not suffer
`any prejudice from this necessary continuance, Mr. Qayyum and Mr. Pacas would suffer
`devastating consequences if forced to go to trial without the counsel that they have chosen
`– counsel who are intimately familiar and very knowledgeable of the many complex and
`novel issues presented in this case. As a result, this factor also favors continuance of the
`trial.
`
`4. Mr. Qayyum and Mr. Pacas will be severely prejudiced if a
`continuance is denied.
`As already discussed in detail, Mr. Qayyum and Mr. Pacas will be prejudiced by the
`denial of this motion. First, and most importantly, they will be forced to proceed without
`their leading trial counsel of choice if a continuance is denied. Second, given the
`unavailability of Defendants’ counsel, it will be near impossible to coordinate and complete
`the necessary trial preparation if another trial attorney must assume trial responsibilities for
`this complex case with just a few months before trial. And as the Court is well aware, this
`criminal case involves a complicated cast of witnesses, novel and unresolved legal issues,
`and a voluminous amount of discovery. Accordingly, good cause exists for a continuance
`under this factor too.
`Given consideration of the above factors, Defendants request that the Court grant this
`motion for an order continuing trial.
`IV. CONCLUSION
`Based upon the foregoing, Defendants respectfully request that the Court continue
`the November 30, 2021 trial date to a date in September of 2022, along with a concomitant
`extension of related deadlines, due to the unavailability of leading trial counsel for
`Mr. Qayyum and Mr. Pacas.
`/ / /
`/ / /
`/ / /
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`Case 3:18-cr-04683-GPC Document 240 Filed 06/11/21 PageID.2459 Page 10 of 12
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`Respectfully submitted,
`
`BIENERT KATZMAN
`LITTRELL WILLIAMS LLP
`By: Whitney Z. Bernstein
` Thomas H. Bienert, Jr.
` James D. Riddet
` Whitney Z. Bernstein
` Attorneys for Abdul Mohammed
`
`BIRD, MARELLA, BOXER, WOLPERT,
`NESSIM, DROOKS, LINCENBERG &
`RHOW, P.C.
`By: Gary S. Lincenberg
` Gary S. Lincenberg
`Nicole Rodriguez Van Dyk
` Darren L. Patrick
` Attorneys for Petr Pacas
`
`MINTZ, LEVIN, COHN, FERRIS,
`GLOVSKY AND POPEO, P.C.
`By: Randy K. Jones
` Randy K. Jones
` Attorneys for Mark Manoogian
`
`WIECHERT, MUNK & GOLDSTEIN, PC
`By: Jessica C. Munk
` David W. Wiechert
` Jessica C. Munk
` Attorneys for Jacob Bychak
`
`Dated: June 11, 2021
`
`Dated: June 11, 2021
`
`Dated: June 11, 2021
`
`Dated: June 11, 2021
`
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`Case 3:18-cr-04683-GPC Document 240 Filed 06/11/21 PageID.2460 Page 11 of 12
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`CERTIFICATE OF AUTHORIZATION TO SIGN ELECTRONIC SIGNATURE
`Pursuant to Section 2(f)(4) of the Electronic Case Filing Administrative Policies and
`Procedures of the United States District Court for the Southern District of California, I
`certify that the content of this document is acceptable to counsel for the Defendants and that
`I have obtained authorization from Randy K. Jones, Jessica C. Munk, and Gary S.
`Lincenberg to affix their electronic signatures to this document.
`
`Dated: June 11, 2021
`
`By: Whitney Z. Bernstein___________________
` Whitney Z. Bernstein
`
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`Case 3:18-cr-04683-GPC Document 240 Filed 06/11/21 PageID.2461 Page 12 of 12
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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
`
`Dated: June 11, 2021
`
`BIENERT KATZMAN
`LITTRELL WILLIAMS LLP
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`By: Whitney Z. Bernstein
` Whitney Z. Bernstein
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`11
`18-cr-04683-GPC
`DEFENDANTS’ JOINT MOTION TO CONTINUE TRIAL
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