Case 3:18-cr-04683-GPC Document 392 Filed 04/21/22 PageID.6012 Page 1 of 2
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`RANDY S. GROSSMAN
`United States Attorney
`MELANIE K. PIERSON
`SABRINA L. FEVE
`Assistant U.S. Attorneys
`California Bar No. 112520/226590
`Office of the U.S. Attorney
`880 Front Street, Room 6293
`San Diego, CA 92101
`Tel: (619) 546-7976
`Fax: (619) 546-0631
`Email:Melanie.Pierson@usdoj.gov/Sabrina.Feve@usdoj.gov
`
`CANDINA S. HEATH
`Senior Counsel
`Texas Bar No. 09347450
`Computer Crime and Intellectual Property Section
`U.S. Department of Justice
`Washington, D.C. 20005
`Tel: (202) 307-1049
`Email: Candina.Heath2@usdoj.gov
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`Attorneys for Plaintiff
`United States of America
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`UNITED STATES DISTRICT COURT
`SOUTHERN DISTRICT OF CALIFORNIA
`Case No.: 18cr4683-GPC
`UNITED STATES OF AMERICA,
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`UNITED STATES’ MOTION TO
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`Plaintiff,
`EXTEND THE FILING
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`DEADLINE FOR ITS TRIAL
`v.
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`EXHIBIT LIST
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`JACOB BYCHAK (1),
`MARK MANOOGIAN (2),
`ABDUL MOHAMMED QAYYUM (3), and
`PETR PACAS (4),
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`Defendants.
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`COMES NOW the plaintiff, United States of America, by and through its counsel,
`Randy S. Grossman, United States Attorney, and Assistant United States Attorneys
`Melanie K. Pierson, Sabrina L. Fève, and Computer Crime and Intellectual Property
`Section Senior Counsel Candy Heath, and hereby files its above-referenced Motion, based
`on the files and records in this case.
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`Case 3:18-cr-04683-GPC Document 392 Filed 04/21/22 PageID.6013 Page 2 of 2
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`On April 11, 2022, the Court ordered the government to provide its exhibit list by
`Friday, April 22, 2022. [ECF No. 382.] The government is requesting this deadline be
`extended to Monday, April 25, 2022, to provide a more coherent exhibit list. The
`government has prepared a list of the bates numbers of its potential exhibits but has not
`had time to organize and de-duplicate the exhibits and does not believe it can complete this
`process by 5 pm on Friday. The de-duplication process is particularly challenging in this
`case because the government received numerous copies of the same emails in response to
`its subpoenas. Many of the emails involve branching threads, which require separately
`marked attachments. The process of matching the right attachment to the sequentially-
`bates stamped email is also time-consuming and requires review involving one-for-one
`comparison and a close reading of multiple copies of the same emails and attachments. To
`minimize the risk of duplication, and to properly format the list with a brief description of
`the documents that will assist in identifying the listed exhibit, the government respectfully
`requests a one-day extension from Friday, April 22, 2022, to Monday, April 25, 2022.
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`DATED: April 21, 2022
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`Respectfully submitted,
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`RANDY S. GROSSMAN
`United States Attorney
`
`/s/Melanie K. Pierson
`Assistant United States Attorney
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`/s/Sabrina L. Fève
`Assistant United States Attorney
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`/s/Candy Heath
`Senior Counsel
`Computer Crime and Intellectual Property Section
`Department of Justice, Criminal Division
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`Government’s Motion to Extend the Deadline for
`filing its Trial Exhibit List
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`18cr4683-GPC
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