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`
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`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
`
`
`
`IN THE UNITED STATES DISTRICT COURT
`FOR THE SOUTHERN DISTRICT OF CALIFORNIA
`
`Case No. 18-CR-4683-GPC
`Honorable Gonzalo P. Curiel
`
`DECLARATION OF JACOB BYCHAK
`IN SUPPORT OF DEFENDANTS’
`MOTION TO SUPPRESS AND DISMISS
`UNDER THE FOURTH AMENDMENT
`
`Hearing Date: April 1, 2022
`Hearing Time: 2:30 p.m.
`Department: Courtroom 2D
`
`
`Plaintiff,
`
`UNITED STATES OF AMERICA,
`
`
`
`v.
`
`JACOB BYCHAK, et al.,
`
` Defendants.
`
`
`
`
`
`
`DECLARATION OF JACOB BYCHAK
`
`I, Jacob Bychak, declare as follows:
`
`1. On April 5, 2010, I was hired by the predecessor of Company A as a
`
`marketing analyst.
`
`2.
`Later that year I moved to the Operations team. In June through September of
`2011, I was Company A’s Business Operations Manager.
`
`3.
`Between 2011 to 2014, I was issued a laptop and a company email address. I
`had a password to login to my laptop and a separate password to login to my email
`address. To my knowledge the company did not have my passwords.
`1
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`DECLARATION OF JACOB BYCHAK
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`Case 3:18-cr-04683-GPC Document 330-2 Filed 02/18/22 PageID.4218 Page 2 of 2
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`I took my laptop home almost every evening and if I left the laptop in my
`4.
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`office, it was locked in my desk drawer.
`
`5.
`I used my laptop for work and personal use and occasionally used my
`company email address for non-company related emails.
`
`6. During this time, to my knowledge Company A had no policy in place
`indicating that they monitored company email.
`
`7. Based on the above, I had an expectation of privacy in my Company A email.
`I declare under the penalty of perjury that the foregoing is true and correct.
`Executed on February 18, 2022 in Carlsbad, California.
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`Jacob Bychak
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`2
`DECLARATION OF JACOB BYCHAK
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