Case 3:18-cr-04683-GPC Document 370 Filed 03/31/22 PageID.5342 Page 1 of 10
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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
`fpatrick@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’ OPPOSITION TO MOTION IN LIMINE TO ADMIT: (1) COCONSPIRATOR
`STATEMENTS; AND (2) EVIDENCE OF NETBLOCKS NOT IDENTIFIED IN THE
`SUBSTANTIVE COUNTS
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`Case 3:18-cr-04683-GPC Document 370 Filed 03/31/22 PageID.5343 Page 2 of 10
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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’ OPPOSITION TO
`GOVERNMENT’S MOTION IN LIMINE
`TO ADMIT: (1) COCONSPIRATOR
`STATEMENTS; AND (2) EVIDENCE OF
`NETBLOCKS NOT IDENTIFIED IN THE
`SUBSTANTIVE COUNTS [DKT. 350]
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`Date: April 7, 2022
`Time: 1:00 p.m.
`Dept.: 2D
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`18-cr-04683-GPC
`DEFENDANTS’ OPPOSITION TO MOTION IN LIMINE TO ADMIT: (1) COCONSPIRATOR
`STATEMENTS; AND (2) EVIDENCE OF NETBLOCKS NOT IDENTIFIED IN THE
`SUBSTANTIVE COUNTS
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`Case 3:18-cr-04683-GPC Document 370 Filed 03/31/22 PageID.5344 Page 3 of 10
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`MEMORANDUM OF POINTS AND AUTHORITIES
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`The Court should deny the government’s motion (“Motion”) to admit: (1) statements
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`allegedly made by purported coconspirators during and in furtherance of the alleged
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`conspiracy to use the GetAds netblocks; and (2) evidence of GetAds and AFRINIC
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`netblocks identified in the notice filed by the government on March 18, 2022 [Dkt. 347]
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`(“404(b) Notice”).
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`I.
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`THE COURT SHOULD EXCLUDE ANY ALLEGED STATEMENTS MADE
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`BY PURPORTED COCONSPIRATORS.
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`As the government’s own cited authority recognizes, “an accused’s knowledge of
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`and participation in an alleged conspiracy with the putative coconspirator are preliminary
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`facts that must be established, by a preponderance of the evidence, before the
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`coconspirator’s out-of-court statements can be introduced into evidence.” United States v.
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`Castaneda, 16 F.3d 1504, 1507 (9th Cir. 1994) (emphasis added), citing United States v.
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`Silverman, 861 F.2d 571, 576 (9th Cir. 1988). In order to establish these facts, “the
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`government cannot rely solely on the coconspirator statements themselves.” Castaneda, 16
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`F.3d at 1507, citing Silverman, 861 F.2d at 578; see also Fed. R. Evid. 801(d)(2) (“The
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`statement … does not by itself establish … the existence of the conspiracy or participation
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`in it”); United States v. Tellier, 83 F.3d 578, 580 (2d Cir. 1996) (finding hearsay statements
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`are “presumptively unreliable” and that “for such statements to be admissible, there must
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`be some independent corroborating evidence of the defendant's participation in the
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`conspiracy”).
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`To prove a connection between the accused and the alleged conspiracy, the
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`government must produce “some independent evidence which, viewed in light of the
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`coconspirator statements, establishes the requisite connection between the accused and the
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`conspiracy.” Castaneda, 16 F.3d at 1507. The government must prove not only that each
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`Defendant is a member of the conspiracy, but also that each declarant is. United States v.
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`Liera, 585 F.3d 1237, 1245-46 (9th Cir. 2009) (vacating conviction due to trial judge’s error
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`1
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`18-cr-04683-GPC
`DEFENDANTS’ OPPOSITION TO MOTION IN LIMINE TO ADMIT: (1) COCONSPIRATOR
`STATEMENTS; AND (2) EVIDENCE OF NETBLOCKS NOT IDENTIFIED IN THE
`SUBSTANTIVE COUNTS
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`Case 3:18-cr-04683-GPC Document 370 Filed 03/31/22 PageID.5345 Page 4 of 10
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`in admitting hearsay statements without the government first proving that declarant was a
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`member of the conspiracy). And the government must also prove that any hearsay
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`statements it seeks to introduce were made “in furtherance” of that conspiracy. Fed. R.
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`Evid. 801(d)(2)(E); United States v. Eubanks, 591 F.2d 513, 520 (9th Cir. 1979) (“Not all
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`statements made by co-conspirators can be considered to have been made in furtherance of
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`the conspiracy”).
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`Here, the government fails to meet its burden as the Motion does not identify or attach
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`any facts or independent evidence establishing the Defendants’ knowledge of and
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`participation in an alleged conspiracy with the putative coconspirators, or that the
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`statements it seeks to admit were made in furtherance of the conspiracy. Rather, the Motion
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`merely contains conclusory assertions regarding grand jury exhibits “produced in
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`discovery” – yet not provided to the Court in support of the Motion – that purportedly show
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`an alleged conspiracy. See Motion at 3-4.
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`As the government cannot prove (a) that a conspiracy existed, (b) that Dye and
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`Tarney were a part of it, (c) that any or all of Defendants were also a part of it, or (d) that
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`any statements of Dye and Tarney were made in furtherance of that conspiracy, the Court
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`should deny the government’s motion to admit out-of-court statements. See, e.g., United
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`States v. Archuleta, No. CR 17-2956 JAP, 2018 WL 3242286, at *3-7 (D.N.M. July 3, 2018)
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`(declining to reconsider an order denying the government’s motion to admit five text
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`messages as coconspirator statements where the government “produced no evidence of an
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`agreement between the Defendants to commit the charged crime of Conspiracy”); United
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`States v. Jett, No. 116CR00001TWPTAB, 2017 WL 402154, at *3 (S.D. Ind. Jan. 30, 2017)
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`(denying government’s motion in limine to admit a coconspirator’s statement because, inter
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`alia, the government “provided almost no evidence to support its contention that the
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`statement was made in the furtherance of an ongoing conspiracy”); United States v. Moran
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`OZ (2), No. CR1300273SRNFLN, 2017 WL 210232, at *1 (D. Minn. Jan. 18, 2017)
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`(denying government’s motion in limine to admit coconspirator statements where “[t]he
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`2
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`18-cr-04683-GPC
`DEFENDANTS’ OPPOSITION TO MOTION IN LIMINE TO ADMIT: (1) COCONSPIRATOR
`STATEMENTS; AND (2) EVIDENCE OF NETBLOCKS NOT IDENTIFIED IN THE
`SUBSTANTIVE COUNTS
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`Case 3:18-cr-04683-GPC Document 370 Filed 03/31/22 PageID.5346 Page 5 of 10
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`only evidence the Government points to are the pleas of other co-conspirators—none of
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`which are yet part of the evidentiary record in this case” and “[i]t is not presently clear even
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`what statements the Government hopes to admit”); United States v. Farmer, No. 08 CR
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`526, 2009 WL 3380943, at *3 (N.D. Ill. Oct. 16, 2009) (denying government’s motion to
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`admit unspecified statements “that may be recounted by [the] special agent … and the
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`government’s confidential source at trial” where “the government has not identified
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`precisely what statements it seeks to admit” and, therefore, “the court cannot assess whether
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`the statements were made by coconspirators, or whether the statements were made in
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`furtherance of the conspiracy”); United States v. Pharis, No. CRIM.99-743, 2000 WL
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`1469330, at *2 (E.D. Pa. Sept. 26, 2000) (denying government’s motion in limine to admit
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`coconspirator statements “with leave to renew” because “the Government has not motioned
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`to introduce any specific statements of Defendants and when exactly they occurred”).
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`Moreover, the government’s request to admit alleged coconspirator statements
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`should be denied because it is premature. See, e.g., United States v. Davis, No. 1:CR-10-
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`211-BLW, 2011 WL 1704234, at *3 (D. Idaho May 3, 2011) (denying the government’s
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`motion to admit co-conspirator statements without prejudice since the motion was
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`“dependent on the testimony and evidence at trial and not amenable to resolution in a pre-
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`trial proceeding”).
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`As the government has failed to establish the required foundation to introduce
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`hearsay statements through the co-conspirator exception, the Court should not admit these
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`unidentified statements. Not only would admission of such statements be extremely
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`prejudicial to Defendants, but if the Court admits such statements and the government later
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`fails to lay the required foundation, the only remedies would be a motion to strike or a
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`mistrial. See, e.g., U.S.A. v. Rodriguez-Landa, No. 213CR00484CAS135610, 2019 WL
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`653853, at *28 (C.D. Cal. Feb. 13, 2019) (noting that the Court will strike alleged
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`coconspirator statements or “declare a mistrial” if “at the end of trial, the government fails
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`to establish the requisite foundation”); see also United States v. Harshaw, 705 F.2d 317,
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`3
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`18-cr-04683-GPC
`DEFENDANTS’ OPPOSITION TO MOTION IN LIMINE TO ADMIT: (1) COCONSPIRATOR
`STATEMENTS; AND (2) EVIDENCE OF NETBLOCKS NOT IDENTIFIED IN THE
`SUBSTANTIVE COUNTS
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`Case 3:18-cr-04683-GPC Document 370 Filed 03/31/22 PageID.5347 Page 6 of 10
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`320-22 (8th Cir. 1983) (affirming district court’s order declaring a mistrial where the
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`government failed to establish the existence of a conspiracy by a preponderance of evidence
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`independent of the hearsay statements themselves). The Court may admit co-conspirator
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`statements without the required foundation only if it determines “that a motion to strike
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`could cure the defects resulting from insufficient proof of the necessary preliminary facts.”
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`United States v. Perez, 658 F.2d 654, 659-670 (9th Cir. 1981). Here, the fiction that such a
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`motion would unring the bell of Dye’s and Tarney’s statements in the minds of the jurors
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`would threaten the integrity of the entire trial.
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`When the evidence outside of the improperly admitted hearsay statements is weak or
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`non-existent, the admission of such statements is prejudicial to the defendant and warrants
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`reversal. See Silverman, 861 F.2d at 580 (the “district court’s error in admitting the
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`[hearsay] statements, . . . was necessarily prejudicial and compels reversal” when the
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`erroneously entered statements were a basis for the jury’s conspiracy conclusion); United
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`States v. Tavares, 512 F.2d 872, 875 (9th Cir. 1975) (where improperly admitted statements
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`“were the strongest and the only direct evidence against [the defendant],” the admission
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`was not harmless error); United States v. Orellana-Blanco, 294 F.3d 1143, 1152 (9th Cir.
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`2002) (same); United States v. Felix-Jerez, 667 F.2d 1297, 1304 (9th Cir. 1982) (same);
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`United States v. Alonzo, 991 F.2d 1422, 1427 (8th Cir. 1993) (erroneous admission of
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`hearsay evidence did not pass the “rigorous standard for harmless error” where a “crucial
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`aspect of the prosecution’s case was greatly enhanced by its use of the inadmissible
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`[evidence]”); United States v. Reyes, 18 F.3d 65, 71-72 (2d Cir. 1994) (when the
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`inadmissible co-conspirator statements “addressed the most important disputed issue in the
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`trial” and there was no opportunity to cross-examine the alleged declarants, error was not
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`harmless); United States v. Am. Grain & Related Indus., 763 F.2d 312, 319 (8th Cir. 1985)
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`(where government failed to produce any evidence to show that corporate counsel was a
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`coconspirator and corporate counsel’s statements conditionally admitted at trial were too
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`prejudicial to be cured by a cautionary instruction, the Eighth Circuit reversed the
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`4
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`18-cr-04683-GPC
`DEFENDANTS’ OPPOSITION TO MOTION IN LIMINE TO ADMIT: (1) COCONSPIRATOR
`STATEMENTS; AND (2) EVIDENCE OF NETBLOCKS NOT IDENTIFIED IN THE
`SUBSTANTIVE COUNTS
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`Case 3:18-cr-04683-GPC Document 370 Filed 03/31/22 PageID.5348 Page 7 of 10
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`convictions of three defendants and granted them a new trial); United States v. Helmel, 769
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`F.2d 1306, 1315 (8th Cir. 1985) (reversing a defendant’s conviction where the government
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`failed “to connect conditionally admitted statements to the conspiracy,” the district court's
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`determination that the defendant was a coconspirator was clearly erroneous, and the
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`admission of inadmissible hearsay not falling within the coconspirator exception was
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`prejudicial error).
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`The government must meet its burden of establishing the foundation for the unknown
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`statements’ admissibility before the jury hears them.
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`II.
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`EVIDENCE RELATING TO THE GETADS AND AFRINIC NETBLOCKS
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`IDENTIFIED IN THE 404(B) NOTICE IS INADMISSIBLE.
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`With respect to the government’s request to admit evidence of GetAds and AFRINIC
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`netblocks identified in the 404(b) Notice (see Motion at 5-9), the Defendants have filed
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`Motion in Limine No. 8 to Exclude Government’s 404(b) Evidence, which addresses the
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`points raised by the government in this Motion. See Dkt. 360. Defendants hereby
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`incorporate by reference all arguments set forth in their Motion in Limine No. 8.
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`Even in its Motion, the government entirely fails to establish an evidentiary
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`connection between its AFRINIC evidence and Defendants’ purported intent or knowledge.
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`Instead, without any evidentiary link, the government suggests that it knows that the
`AFRINIC netblock transactions were questionable and disreputable, and that a jury can
`therefore infer that Defendants had the requisite knowledge and intent with respect to the
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`charged netblocks. The Court should not invite a trial within a trial by admitting this
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`unfounded propensity evidence. Moreover, the government’s citation to a December 2019
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`news article it produced in discovery is irrelevant; there is no allegation at all that
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`Defendants are familiar with this article. See Motion at 8.
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`For the foregoing reasons, the Court should deny the government’s Motion in Limine
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`requesting an order admitting coconspirator statements and evidence of netblocks not
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`identified in the substantive counts in the Indictment.
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`5
`18-cr-04683-GPC
`DEFENDANTS’ OPPOSITION TO MOTION IN LIMINE TO ADMIT: (1) COCONSPIRATOR
`STATEMENTS; AND (2) EVIDENCE OF NETBLOCKS NOT IDENTIFIED IN THE
`SUBSTANTIVE COUNTS
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`Case 3:18-cr-04683-GPC Document 370 Filed 03/31/22 PageID.5349 Page 8 of 10
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`Dated: March 31, 2022
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`Respectfully submitted,
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`BIENERT KATZMAN LITTRELL
`WILLIAMS LLP
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`DATED: March 31, 2022
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`By: /s/ Whitney Z. Bernstein
`Thomas H. Bienert, Jr.
`James D. Riddet
`Whitney Z. Bernstein
`Carlos A. Nevarez
`Attorneys for Mohammed Abdul Qayyum
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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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`DATED: March 31, 2022
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`DATED: March 31, 2022
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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, LINCENBERT &
`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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`6
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`18-cr-04683-GPC
`DEFENDANTS’ OPPOSITION TO MOTION IN LIMINE TO ADMIT: (1) COCONSPIRATOR
`STATEMENTS; AND (2) EVIDENCE OF NETBLOCKS NOT IDENTIFIED IN THE
`SUBSTANTIVE COUNTS
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`

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`Case 3:18-cr-04683-GPC Document 370 Filed 03/31/22 PageID.5350 Page 9 of 10
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`CERTIFICATION OF AUTHORIZATION TO SIGN SIGNATURE
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`The undersigned counsel of record for Defendant Abdul Mohammed 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/ Whitney Z. Bernstein
` Whitney Z. Bernstein
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`1
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`3:18-cr-04683-GPC
`CERTIFICATION OF AUTHORIZATION TO SIGN SIGNATURE
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`Case 3:18-cr-04683-GPC Document 370 Filed 03/31/22 PageID.5351 Page 10 of 10
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`CERTIFICATE OF SERVICE
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`Counsel for Defendant Mohammed Abdul Qayyum 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. Fève
`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 31, 2022, at
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`San Clemente, California.
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`/s/ Whitney Z. Bernstein
` Whitney Z. Bernstein
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`1
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`3:18-cr-04683-GPC
`CERTIFICATION OF AUTHORIZATION TO SIGN SIGNATURE
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