Case 3:18-cr-04683-GPC Document 358-1 Filed 03/24/22 PageID.5044 Page 1 of 11
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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
`Carlos A. Nevarez, SBN 324407
`903 Calle Amanecer, Suite 350
`San Clemente, California 92673
`Telephone: (949) 369-3700
`Email: tbienert@bklwlaw.com
`jriddet@bklwlaw.com
`wbernstein@bklwlaw.com
`cnevarez@bklwlaw.com
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`Attorneys For Mohammed Abdul Qayyum
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`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
`Alexis A. Wiseley, SBN 330100
`1875 Century Park East, Floor 23
`Los Angeles, CA 90067
`Telephone: (310) 201-2100
`Email: Glincenberg@Birdmarella.com
`Nvandyk@Birdmarella.com
`Dpatrick@Birdmarella.com
`Awiseley@birdmarella.com
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`Attorneys For Petr Pacas
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`WIECHERT, MUNK & GOLDSTEIN, PC
`David W. Wiechert, SBN 94607
`Jessica C. Munk, SBN 238832
`William J. Migler, SBN 318518
`27136 Paseo Espada, Suite B1123
`San Juan Capistrano, CA 92675
`Telephone: (949) 361-2822
`Email: Dwiechert@aol.com
`Jessica@Wmgattorneys.com
`William@Wmgattorneys.com
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`Attorneys For Jacob Bychak
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`MINTZ, LEVIN, COHN, FERRIS,
`GLOVSKY AND 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
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`Daniel J. Goodrich, BBO 692624 (Pro Hac)
`Ryan Dougherty, BBO 703380 (Pro Hac)
`1 Financial Center
`Boston, MA 02111
`Email: Djgoodrich@Mintz.com
`Rtdougherty@Mintz.com
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`Attorneys For Mark Manoogian
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`18-cr-04683-GPC
`DEFENDANTS’ NOTICE OF MOTION AND MOTION IN LIMINE NO. 7
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`IN THE UNITED STATES DISTRICT COURT
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`FOR THE SOUTHERN DISTRICT OF CALIFORNIA
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`Plaintiff,
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`UNITED STATES OF AMERICA,
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`v.
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`JACOB BYCHAK et al.
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`Defendants.
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`Case No. 3:18-cr-04683-GPC
`Hon. Gonzalo P. Curiel
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`DEFENDANTS’ MOTION IN LIMINE
`NO. 7 TO PRECLUDE REFERENCES TO
`CERTAIN INDIVIDUALS AS “VICTIMS”
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`Date: April 7, 2022
`Time: 1:00 p.m.
`Dept.: 2D
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`18-cr-04683-GPC
`DEFENDANTS’ NOTICE OF MOTION AND MOTION IN LIMINE NO. 7
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`Case 3:18-cr-04683-GPC Document 358-1 Filed 03/24/22 PageID.5046 Page 3 of 11
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`MEMORANDUM OF POINTS AND AUTHORITIES
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`Defendants move in limine for an order precluding the government from referring to
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`any individuals as “victims” in front of the jury because such references eviscerate the
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`Defendants’ presumption of innocence and are so unduly prejudicial that Defendants will
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`be deprived of a fair trial.
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`I.
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`Background and Relevant Facts.
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`Based on previous representations in its pleadings and before the Court, it is evident
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`that the government intends to use the term “victim” in an indiscriminate manner in this
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`case. See Nevarez Decl., Ex. A (Hrg. Mot. for Protective Order) at 15:18-19 (Ms. Feve
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`stating that “under these allegations, the people who received the unsolicited e-mails were
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`victims.”).
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`Indeed, the government has expressly stated that legacy holders are victims of the
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`alleged scheme. See, e.g., Dkt. No. 241 (Opp. to Defendants’ Mot. to Continue Trial) at
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`7:21-22 (“The victim witnesses were allocated the netblocks at issue approximately 30
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`years ago”) (emphasis added). However, during their testimony at a Rule 15 deposition,
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`two holders of legacy netblocks identified in the government’s pleadings as “SAD” and
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`“LWT”, gave contrasting testimony concerning their perceived effects of the alleged
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`scheme. Notably, SAD confirmed that he did not own the netblock in question and that he
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`told government investigators that he “was not the victim.” Nevarez Decl., Ex. B (SAD
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`Dep.) at 101:16-1, 103:1-4 (“I wish to be removed as a victim from the witness list in this
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`case. I am not the victim since I did not own the asset.”) (SAD recited the language in
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`Defense Exhibit B, which is an email from SAD to a government investigator).
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`Similarly, LWT stated that her company had received the netblock in question as a
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`donation without paying anything, that her company did not use the netblock, and that she
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`in fact did not even regard it as valuable. Nevarez Decl., Ex. C (LWT Dep.) at 34:23-35:3,
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`35:13-17, 36:3-5, 38:22-39:11. LWT also affirmed that Company A’s use of the netblock
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`in question did not affect LWT’s ability to sell the netblock, nor its monetary value. Id. at
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`47:15-48:8.
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`DEFENDANTS’ MOTION IN LIMINE NO. 7
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`In its recent disclosure of expert witnesses, the government alluded to yet another
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`category of victims – internet upstream providers such as internet hosting companies. See
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`Dkt. No. 342. Accordingly, the government has indicated that it intends to put forth the
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`following “expert” testimony:
` Michael Ward to testify that he denied announcing a netblock “to protect the
`integrity of the ViaWest network” (Dkt. No. 342 at 5:16-18);
` Ried Zulager to testify that he removed an announcement to “maintain the
`integrity and security of the Cogent network” (Id. at 6:5-7);
` Peter Holden to testify that Hostwinds removed blocklisted IP addresses “to
`protect the network’s integrity and security” (Id. at 6:17-20); and
` Sean Zadig to testify “how spam affects Yahoo’s business, how hijacked IPs
`affect Yahoo’s business, and Yahoo’s experience in 2013 and 2014 with spam
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`sent by defendants’ then-employer.” (Id. at 4:12-16).
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`The government moreover produced in discovery an email from Zadig where he reported
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`costs associated with cleaning up Yahoo’s network from Company A’s purported
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`commercial email. See Zadig email dated September 11, 2018.1
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`II. The Court should preclude the government’s indiscriminate references to
`“victims” in front of the jury.
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`The government has in the past identified a widespread cast of parties as “victims”.
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`For instance, it has repeatedly and expressly referred to those individuals and entities that
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`were assigned legacy IP addresses as “victims.” See, e.g., Dkt. No. 241 at 7:21-22 (“The
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`victim witnesses were allocated the netblocks at issue approximately 30 years ago”); see
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`also Nevarez Decl., Ex. D (Hrg. Mots. to Dismiss Indictment and for Bill of Particulars) at
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`29:2-4 (Ms. Feve stating: “I think the most obvious victims are the individuals who were
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`the registrants of these IP netblocks”). Elsewhere, and including in its expert disclosure,
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`1 Sean Zadig’s email has been included as an exhibit to Defendants’ Motion In Limine No.
`9. To eliminate any duplicative exhibits, that exhibit has not been reattached to this
`motion.
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`2
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`DEFENDANTS’ MOTION IN LIMINE NO. 7
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`3:18-cr-04683-GPC
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`the government has suggested that internet hosting companies, like Hostwinds and Cogent,
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`expert witnesses, and even Google and Yahoo, are also victims. See Dkt. No. 342; see also
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`Nevarez Decl., Ex. D at 29:10-11 (Ms. Feve stating: “that is to say Gmail is a potential
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`victim if you look at the statute”). And moreover, the government has also claimed that
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`anyone who conceivably received a commercial email from Company A is also a victim.
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`See Nevarez Decl., Ex. A at 15:18-19 (“under these allegations, the people who received
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`the unsolicited e-mails were victims.”).
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`These examples suggest it is probable that the government’s attorneys and fact and
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`expert witnesses will characterize these individuals, or others like them, as “victims” before
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`the jury. The Court should not allow use of that terminology. Giving the government carte
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`blanche to call this exceedingly broad and diverse group of people “victims” is not only
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`incorrect in this case, but it would also be unduly prejudicial to Defendants. Defendants
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`should be judged based on the evidence of what they did and what they knew or intended,
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`not based on how the government or witnesses characterize what occurred – which now
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`apparently includes the remote and tenuous effects of Company A’s commercial emails on
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`Yahoo.
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`As an initial matter, the government’s use of the term “victim” at trial would turn the
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`presumption of innocence on its head. At this stage, Defendants are merely accused of
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`criminal conduct, not convicted of any crimes. For that reason, they are as a matter of law
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`cloaked with the presumption of innocence. Using and re-iterating the term “victim”
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`obliterates that presumption, and it carries with it the connotation that a crime has indeed
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`occurred and the witness has been injured. See Adam J. MacLeod, All for One: A Review
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`of Victim-Centric Justifications for Criminal Punishment, 13 Berkeley J. Crim. L. 31 (2008)
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`(“Consequentialist reasoning provides a link between the harm suffered by a particular
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`victim and the culpability of the perpetrator.”).
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`It moreover suggests that there exists extra-judicial evidence that has persuaded the
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`speaker – the government’s counsel or prosecution witnesses – to proclaim Defendants’
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`guilt. The term “victim” further confers an aura of vulnerability and misfortune on the
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`DEFENDANTS’ MOTION IN LIMINE NO. 7
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`individuals so characterized, thereby inserting an impermissible element of sympathy at
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`trial.
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`Use of this term is so prejudicial that the government has agreed to refrain from its
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`use in other cases. See, e.g., United States v. Idaho Cnty. Light & Power Coop. Assoc., Inc.,
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`2020 WL 1105091, at *7 (D. Ida. Mar. 6, 2020). Indeed, courts have even stricken the term
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`from an indictment as irrelevant and prejudicial. See, e.g., United States v. Lalley, 2010 WL
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`3946659, at *3-4 (D. N.J. Oct. 5, 2010) (granting defendant’s motion to strike the term
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`“victim” from the indictment). Because use of the term “victim” will be unduly prejudicial
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`to Defendants, will likely create bias against them, and will deprive them of a fair trial in
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`violation of the Due Process Clause, this Court should preclude it. Instead, the Court should
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`require the government and its witnesses to refer to those individuals by their names, by
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`their initials, or with some other reference that accurately describes them without injecting
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`the trial with unfair prejudice.
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`Next, there is no evidence that the individuals and entities identified as “victims” by
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`the government were actually victimized by Defendants. In sum, Defendants are accused
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`of scheming to take and use decades-old IP addresses by submitting false documentation to
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`send commercial emails on behalf of their uncharged employer. Defendants, however, are
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`not accused of defrauding the holders of those legacy IP addresses. There is moreover no
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`evidence that any of the putative “victims” even knew about the identity or existence of
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`their “victimizers.” See, e.g., Nevarez Decl., Ex. C (LWT Dep.) at 29:16-30:12; Ex. B
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`(SAD Dep.) at 51:21-52:8, 163:11-14; Ex. E (Thomas Conner Interview, October 27, 2014)
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`at 1-2 (“CONNER believes that any and all claims to the IP blocks were relinquished in the
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`sale of the company [in November 1999]”); Ex. F (Mike Durbin Interview, October 29,
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`2015) at 1-3 (Durbin stated that when his company was acquired “all assets were transferred
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`to OSAGE SYSTEMS GROUP, which would include the IP block” and that OSAGE went
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`out of business in 2001); Ex. G (Rhonda Johnson Interview, February 24, 2012) at 2
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`(reciting email by holder’s representative that “EDUCAUSE ha[d] not suffered significant
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`monetary damage . . . other than staff response.”); Ex. H (Anne Gideon 302 Interview,
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`Case 3:18-cr-04683-GPC Document 358-1 Filed 03/24/22 PageID.5050 Page 7 of 11
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`February 18, 2021) at 1-2 (holder of legacy address “was sold to Haymarket Media and
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`dissolved in 2003,” and Gideon was unsure “if the IP addresses were transferred to
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`Haymarket when sold.”). And at least one of these holders of legacy addresses – SAD –
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`continually reiterated that “he was not a victim.” See Ex. B (SAD Dep.) at 101:16-17,
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`103:1-4.
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`While the government alleges that Defendants created and sent purported false
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`documents to internet hosting companies “fraudulently making it appear” that they were
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`registrants of the IP addresses (see Dkt. No. 1, ¶ 6), there is no evidence that those
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`companies sustained monetary losses because of handling such IP addresses. At most, the
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`government’s discovery and pleadings disclose that these upstream providers sustained
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`reputational harm or tenuous and incidental by-product of the alleged scheme. That is not
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`enough for wire fraud charges enumerated in the indictment. See United States v. Yates, 16
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`F.4th 256, 264 (9th Cir. 2021) (The “property deprivation must play more than some bit
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`part in a scheme—the loss to the victim must be an ‘object of the fraud . . . .”); see also
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`Kelly v. United States, 140 S. Ct. 1565, 1573-74 (2020) (holding that under the wire fraud
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`statute, “[t]he loss to the victim must be an object of the fraud, not a mere implementation
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`cost or incidental byproduct of the scheme.”).
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`Based on the absence of any significant pecuniary loss, it is thus inappropriate to call
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`any of these parties “victims” in this case. United States v. Yagar, 404 F.3d 967, 971 (6th
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`Cir. 2005) (account holders were not victims and concluding that “where the monetary loss
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`is short-lived and immediately covered by a third-party, we do not think that there has been
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`‘actual loss’ or ‘pecuniary harm.’”).
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`Finally, courts must preclude presentation of any evidence that is unduly prejudicial
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`or likely to confuse the jurors under Rule 403 of the Federal Rules of Evidence. The same
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`concerns about fairness that guide a court’s analysis on the admissibility of evidence under
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`Rule 403 are applicable to references by prosecutors and witnesses to people as “victims,”
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`and provide another basis for precluding them. Indeed, such references are unduly
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`prejudicial and likely to confuse the jurors. The use of the term “victim” is a conclusion of
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`DEFENDANTS’ MOTION IN LIMINE NO. 7
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`fact that should be left to the jury. Use of the term by prosecutors and government witnesses
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`would involve an unfair prejudging of the issues and would cause undue prejudice to
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`Defendants’ right to a fair trial. See United States v. Marr, No. 14-CR-00580-PJH, 2017
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`WL 1540815, at *11 (N.D. Cal. Apr. 28, 2017), aff’d sub nom. United States v. Sanchez,
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`760 F. App’x 533 (9th Cir. 2019); see also Michael Conklin, Victim or Complaining
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`Witness: The Difference Between Guilty and Not Guilty, 57 San Diego L. Rev. 423, 429
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`(2020) (reporting on a series of surveys that showed a “significant effect” on the likelihood
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`that respondents would find hypothetical defendant guilty when referring to a “female
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`victim” versus a “female complaining witness”). Conversely, there is no reason the
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`prosecutors and the witnesses cannot refer to the people by their names, initials, etc., such
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`that the government can present its case while protecting the due process rights of the
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`Defendants.
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`III. Conclusion.
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`For all the foregoing reasons, the Court should enter an order precluding the
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`government and its witnesses from referring to any individuals as “victims.”
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`Dated: March 24, 2022
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`Respectfully submitted,
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`BIENERT KATZMAN LITTRELL
`WILLIAMS LLP
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`By: /s/ Carlos A. Nevarez
`Thomas H. Bienert, Jr.
`James D. Riddet
`Whitney Z. Bernstein
`Carlos A. Nevarez
`Attorneys for Mohammed Abdul Qayuum
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`DATED: March 24, 2022
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`DATED: March 24, 2022
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`DATED: March 24, 2022
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`MINTZ LEVIN COHN FERRIS
`GLOVSKY AND POPEO, P.C.
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`By: /s/ Randy K. Jones
`Randy K. Jones
`Daniel J. Goodrich (Pro Hac)
`Ryan Dougherty (Pro Hac)
`Attorneys for Mark Manoogian
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`WIECHERT, MUNK & GOLDSTEIN, PC
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`By: /s/ Jessica C. Munk
`David W. Wiechert
`Jessica C. Munk
`William J. Migler
`Attorneys for Jacob Bychak
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`BIRD, MARELLA, BOXER, WOLPERT,
`NESSIM, DROOKS, LINCENBERG &
`RHOW, P.C.
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`By: /s/ Gary S. Lincenberg
`Gary S. Lincenberg
`Nicole Rodriguez Van Dyk
`Darren L. Patrick
`Alexis A. Wiseley
`Attorneys for Petr Pacas
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`CERTIFICATION OF AUTHORIZATION TO SIGN SIGNATURE
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`The undersigned counsel of record for Defendant Mohammed Abdul Qayyum
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`certifies that the content of this document is acceptable to each of the Defendants’ counsel
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`whose electronic signature appears thereon, and that I have obtained their authorization to
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`sign this document on their behalf.
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`/s/ Carlos A. Nevarez
` Carlos A. Nevarez
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`3:18-cr-04683-GPC
`CERTIFICATION OF AUTHORIZATION TO SIGN SIGNATURE
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`CERTIFICATE OF SERVICE
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`Counsel for Defendant Mohammed Abdul Qayuum certifies that the foregoing
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`pleading has been electronically served on the following parties by virtue of their
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`registration with the CM/ECF system:
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`Counsel for Defendant certifies that the foregoing pleading has been electronically served
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`on the following parties by virtue of their registration with the CM/ECF system:
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`AUSA Melanie K. Pierson
`AUSA Sabrina L. Feve
`AUSA Ashley E. Goff
`U.S. Attorney’s Office
`880 Front Street, Rm 6293
`San Diego, CA 92101
`melanie.pierson@usdoj.gov
`sabrina.feve@usdoj.gov
`ashley.goff@usdoj.gov
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`Candina S. Heath
`Department of Justice
`1301 New York Avenue NW, Suite 600
`Washington, DC 20530
`candina.heath2@usdoj.gov
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` certify under penalty of perjury under the laws of the United States of America that
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`the foregoing is true and correct, and that I executed this declaration on March 24, 2022, at
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`Los Angeles, California.
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`/s/ Carlos A. Nevarez
` Carlos A. Nevarez
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`1
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`CERTIFICATE OF SERVICE
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`3:18-cr-04683-GPC
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