`
`
`
`RANDY S. GROSSMAN
`United States Attorney
`Melanie K. Pierson
`Assistant United States Attorney
`California Bar No. 112520
`Federal Office Building
`880 Front Street, Room 6293
`San Diego, California 92101-8893
`Telephone: (619) 546-7976
`
`Attorneys for United States of America
`
`UNITED STATES DISTRICT COURT
`
`
`
`SOUTHERN DISTRICT OF CALIFORNIA
`
`Case No. 18cr4683
`UNITED STATES OF AMERICA,
`
`
`
` Plaintiff,
`
`MOTION AND ORDER TO FILE
` v.
`OVERSIZED BRIEF IN RESPONSE TO
`
`MOTION TO DISMISS FOR OUTRAGEOUS
`JACOB BYCHAK, et. al.
`GOVERNMENT CONDUCT
` Defendants.
`
`
`
`
`
`The United States of America, by its counsel, moves to file an
`oversize brief in response to the Defendants’ Motion to Dismiss for
`Outrageous Government Conduct. The defense brief consisted of a 30-
`page brief, and an 82-page declaration including 14 exhibits filed
`under seal. The government’s response consists of a 27-page brief (2
`pages over the limit), and a 43-page declaration including four
`exhibits, filed under seal. The defense brief raised numerous issues
`which required two additional pages to provide a thorough legal
`analysis for the court on this important issue.
`
`DATED: March 4, 2022 Respectfully submitted,
`
`RANDY S. GROSSMAN
`
`United States Attorney
`
`
`___________________________
`
`Melanie K. Pierson
`
`Assistant U. S. Attorney
`
`
`
`
`
`
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`

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