Case 3:18-cr-04683-GPC Document 306-1 Filed 11/10/21 PageID.3906 Page 1 of 2
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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
`Alexis A. Wiseley - State Bar No. 330100
` awisely@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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`
`
`UNITED STATES OF AMERICA,
`
`Plaintiff,
`
`vs.
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`PETR PACAS,
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`Defendant.
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`UNITED STATES DISTRICT COURT
`SOUTHERN DISTRICT OF CALIFORNIA
`
` CASE NO. 18-CR-4683-GPC-4
`
`DECLARATION OF NICOLE R.
`VAN DYK IN SUPPORT OF
`UNOPPOSED MOTION FOR
`ORDER APPROVING TRAVEL
`REQUEST
`
`Filed Concurrently with Unopposed
`Motion for Order Approving Travel
`Request; and [Proposed] Order
`
`Assigned to Hon. Gonzalo P. Curiel
`
`
`I, Nicole R. Van Dyk, 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 would so
`testify if called upon to do so.
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`DECLARATION OF NICOLE R. VAN DYK
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`Case No. 18-CR-4683-GPC-4
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`Case 3:18-cr-04683-GPC Document 306-1 Filed 11/10/21 PageID.3907 Page 2 of 2
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`On November 9, 2021, I conferred with Pretrial Services Officer
`2.
`Russell Parris to ask if he would approve a bond modification allowing Mr. Pacas to
`travel to the Czech Republic to visit his family beginning on December 1, 2021,
`with a return date on or before January 15, 2022. Mr. Russell confirmed that he had
`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 November 9, 2021, Assistant United States Attorney Melanie
`3.
`Pierson 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.
`Assistant United States Attorneys Sabrina Feve, Melanie Pierson, and Candina
`Heath 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: November 10, 2021
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`s/ Nicole R. Van Dyk
`Nicole R. Van Dyk
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`DECLARATION OF NICOLE R. VAN DYK
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`Case No. 18-CR-4683-GPC-4
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