Case 3:18-cr-04683-GPC Document 431 Filed 05/19/22 PageID.6570 Page 1 of 13
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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
`
`Attorneys For Mohammed Abdul Qayyum
`
`
`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
`27136 Paseo Espada, Suite B1123
`San Juan Capistrano, CA 92675
`Telephone: (949) 361-2822
`Email: dwiechert@aol.com
` jessica@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
`
`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 THE GOVERNMENT’S AMENDED NOTICE OF
`AUTHENTICATION PURSUANT TO FED. R. EVID. 902(11) & (13)
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`Case 3:18-cr-04683-GPC Document 431 Filed 05/19/22 PageID.6571 Page 2 of 13
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`IN THE UNITED STATES DISTRICT COURT
`FOR THE SOUTHERN DISTRICT OF CALIFORNIA
`
`
`UNITED STATES OF AMERICA,
`
`
`Plaintiff,
`
`v.
`
`JACOB BYCHAK, et al.
`
`
`Defendants.
`
`Case No. 3:18-cr-04683-GPC
`Hon. Gonzalo P. Curiel
`
`DEFENDANTS’ OPPOSITION TO THE
`GOVERNMENT’S AMENDED NOTICE
`OF AUTHENTICATION PURSUANT TO
`FED. R. EVID. 902(11) & (13)
`
`
`I.
`
`INTRODUCTION.
`The government’s efforts to authenticate documents through custodians submitting
`“Certificates of Authenticity” (COA’s) are inadequate under Federal Rules of Evidence
`(FRE) 902(11) and 803(6). Nonetheless, defendants will stipulate to authentication1 of
`the documents from several of the purported custodians, namely: Goodman Law Firm,
`Moniker, ARIN, Telic, State of Delaware, and State of Louisiana. As to the identified
`documents from those entities, Defendants suggest that the parties simply stipulate that
`the documents are authentic and need not deal at trial with Certificates of Authenticity at
`
`
`1 As to those documents, Defendants stipulate to authenticity only. They do not stipulate
`to admission of the documents, relevancy, hearsay or any other evidentiary issues relating
`to whether the documents may be displayed or introduced at trial.
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`1
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`18-cr-04683-GPC
`DEFENDANTS’ OPPOSITION TO THE GOVERNMENT’S AMENDED NOTICE OF
`AUTHENTICATION PURSUANT TO FED. R. EVID. 902(11) & (13)
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`Case 3:18-cr-04683-GPC Document 431 Filed 05/19/22 PageID.6572 Page 3 of 13
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`all.
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`Defendants do object to authentication of documents via the purported COA’s for
`the following entities for the reasons stated herein:
`Broadcloud (Gov. Ex. 207)
`Mata Group (Gov. Ex. 226)
`Cogent (Gov. Ex. 227)
`Hostwinds (Gov. Ex. 229)
`GetAds (Gov. Ex. 23, 231)
`GoDaddy (Gov. Ex. 232)
`PayPal (Gov. Ex. 233)
`Name.com (Gov. Ex. 234)
`CPH Resources (Gov. Ex. 235, 236)
`Enom/Tucows (Gov. Ex. 237)
`Enom (Gov. Ex. 238)
`Amobee (Gov. Ex. 240)
`II. ARGUMENT
`FRE 902(11) reads as follows:
`The following items of evidence are self-authenticating; they require no extrinsic
`evidence of authenticity in order to be admitted:
`(11) Certified Domestic Records of a Regularly Conducted Activity. The
`original or a copy of a domestic record that meets the requirements of Rule
`803(6)(A)–(C), as shown by a certification of the custodian or another qualified
`person that complies with a federal statute or a rule prescribed by the Supreme
`Court. Before the trial or hearing, the proponent must give an adverse party
`reasonable written notice of the intent to offer the record—and must make the
`record and certification available for inspection—so that the party has a fair
`opportunity to challenge them.
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`2
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`18-cr-04683-GPC
`DEFENDANTS’ OPPOSITION TO THE GOVERNMENT’S AMENDED NOTICE OF
`AUTHENTICATION PURSUANT TO FED. R. EVID. 902(11) & (13)
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`Case 3:18-cr-04683-GPC Document 431 Filed 05/19/22 PageID.6573 Page 4 of 13
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`The government acknowledges that in order to authenticate documents pursuant to
`FRE 902(11), it “must produce evidence sufficient to support a finding that the item is
`what the proponent claims it is,’ and that to support such a finding, the proponent must
`“make a prima facie showing of authenticity” and “establish a connection between the
`proffered evidence and the defendant.” Government Supplemental Filing at 4.
`Admission of documents pursuant to FRE 902(11) must go “hand in hand” with
`admission under FRE 803(6). United States v. Safavian, 435 F. Supp. 2d 36, 38-39
`(D.D.C. 2006). “Fed. R. Evid. 902(11) was intended as a means of authenticating only
`that evidence which is being offered under the business records exception to the hearsay
`rule.” rejecting proffered 902(11) certificate when not related to documents offered
`pursuant to the business records exception of FRE 803(6)). Accordingly, a proponent of
`documents pursuant to Federal Rules of Evidence 902(11) must present competent
`evidence to authenticate corporate records under both Rules 902(11) and 803(6). Id.; VFS
`Fin., Inc. v. CHF Express, LLC, 620 F. Supp. 2d 1092, 2009 U.S. Dist. LEXIS 49509
`(C.D. Cal. 2009).
`FRE 803(6) reads as follows:
`The following are not excluded by the rule against hearsay, regardless of whether
`the declarant is available as a witness:
`(6) Records of a regularly conducted activity. A record of an act, event,
`condition, opinion, or diagnosis if:
`(A) the record was made at or near the time by—or from information
`transmitted by—someone with knowledge;
`(B) the record was kept in the course of a regularly conducted activity
`of a business, organization, occupation, or calling, whether or not for
`profit;
`(C) making the record was a regular practice of that activity;
`(D) all these conditions are shown by the testimony of the custodian or
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`3
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`18-cr-04683-GPC
`DEFENDANTS’ OPPOSITION TO THE GOVERNMENT’S AMENDED NOTICE OF
`AUTHENTICATION PURSUANT TO FED. R. EVID. 902(11) & (13)
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`Case 3:18-cr-04683-GPC Document 431 Filed 05/19/22 PageID.6574 Page 5 of 13
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`another qualified witness, or by a certification that complies with Rule
`902(11) or (12) or with a statute permitting certification; and
`(E) the opponent does not show that the source of information or the
`method or circumstances of preparation indicate a lack of
`trustworthiness.
`Mere conclusory statements without sufficient foundation facts are insufficient. Id.
`at 1098 (rejecting corporation’s contention that exhibit to paralegal’s declaration and
`exhibit to verified complaint were business records because paralegal did not set forth
`sufficient foundational facts). See also, Collins v. Kibort, 143 F.3d 331, 338 (7th Cir.
`1998) (noting that "the business records exception does require that the witness have
`knowledge of the procedure under which the records were created,” and disqualifying a
`custodian who had testified merely that "the exhibits she gathered and submitted . . . are
`taken from the records of [the company]”; the court stated "I cannot infer from [her]
`affidavit that she has knowledge of the procedures governing the creation of a record.”).
`The government makes no such showings in any of the COA’s, rendering them
`insufficient on their face. For example, none of the certifications describe “what it is” that
`they are purporting to be. Documents that simply were found in the companies files?
`Documents prepared by the persons whose names appear on them? Documents with a
`connection to any of the defendants? The government simply says, in essence, these are
`documents and are authentic, with no tie-in to anything. Nor do any of the certifications
`set forth the custodian’s knowledge, if any, of how the records are created. Nor do any of
`the certificates purport to say on what basis the documents will be offered at trial. Absent
`a showing that the documents will be offered pursuant to the business records hearsay
`exception, FRE 902(11) is not available as a means of authentication. The COA’s fail to
`meet the requirements of Rule 901 and 803(6).
`More problematic is the fact that some of the representations in the purported
`Certificates of Authenticity are unbelievable on their face. For example, Amobee
`
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`4
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`18-cr-04683-GPC
`DEFENDANTS’ OPPOSITION TO THE GOVERNMENT’S AMENDED NOTICE OF
`AUTHENTICATION PURSUANT TO FED. R. EVID. 902(11) & (13)
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`Case 3:18-cr-04683-GPC Document 431 Filed 05/19/22 PageID.6575 Page 6 of 13
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`custodian Samonte purports to establish that over 1,300,000 pages of documents were
`made “at or near the time of the occurrence of the matter set forth,” by a person “with
`knowledge of those matters,” that each and all of the documents “were kept in the
`ordinary course of the regularly conducted business activity” of Amobee, and that the
`documents “were made by [Amobee] as a regular practice.” It is simply implausible that
`Mr. Samonte, a “develops engineer” would have such knowledge for that many
`documents. And as AUSA Feve represented to the Court on May 18, 2022, these
`documents are “crucial” to the government’s case. The government cannot sweep all
`“crucial” documents into the trial as authentic on such a conclusory and questionable
`showing. Similarly, the Hostwinds custodian makes the same representations as to
`“21,176.569 kilobytes,” which can be roughly over 10,000 pages2.
`Another issue is that the government has offered custodians to authenticate records
`for other companies. For example, the government’s COA Exhibit No. 235 and 236 –
`which is says correlate to records from CPH Resources – is instead signed an employee of
`Amobee. This Amobee employee purports to have personal knowledge of roughly 1,000
`pages of documents related to a different company, CPH. If those companies are related,
`no foundation has yet to be laid. This is true of COA Exhibit Nos. 230 and 231 – the
`government says these exhibits relate to GetAds, but the person signing the COA works
`for an entirely different company, Native Rank. Yet there is no explanation of how a
`Native Rank custodian can authenticate GetAds documents. Rule 902(11) contemplates
`that the certificate will be a stand-alone document, requiring no reference to a separate
`document (1) created by a party to the litigation, (2) not attached to the certificate, and (3)
`not certified as accurate by the custodian. See generally State v. Huggins, 659 P.2d 613,
`617 (Alaska App. Ct. 1982) (holding under similar rule that certification must “make[]
`clear, on its face, the documents to which it applies”); DirectTV v. Reyes, 2006 WL
`
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`2 https://www.digitalwarroom.com/blog/how-many-pages-in-a-
`gigabyte#:~:text=Bit%3A%200.0004%20pages.,Kilobyte%3A%200.5%20pages.
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`18-cr-04683-GPC
`DEFENDANTS’ OPPOSITION TO THE GOVERNMENT’S AMENDED NOTICE OF
`AUTHENTICATION PURSUANT TO FED. R. EVID. 902(11) & (13)
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`Case 3:18-cr-04683-GPC Document 431 Filed 05/19/22 PageID.6576 Page 7 of 13
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`533364 at *5 (N.D. Ill. March 1, 2006) (finding Rule 902(11) inapplicable to document
`that could not be tied to custodian’s certificate).
`Other certifications simply fail to attach or otherwise identify the documents
`purportedly being certified. No records are attached or identified with the COA’s of
`Broadcloud (Gov. Ex. 207), Mata Group (Gov. Ex. 226), Cogent (Gov. Ex. 227),
`Hostwinds (Gov. Ex. 229), GoDaddy (Gov. Ex. 232), PayPayl (Gov. Ex. 233), Name.com
`(Gov. Ex. 234), Enom/Tucows (Gov. Ex. 238), and Enom (Gov’. Ex. 239). Additionally,
`the records purporting to be authenticated by Gov. Ex. 238 and 239 are pdfs of
`spreadsheets, with no explanation of from where or how the underlying information was
`gathered. The government’s proffered COA’s are thus inadequate.
`The government admits that the defendants may still challenge the authenticity of
`the evidence and the sufficiency of the certifications through the mechanism of a hearing
`pursuant to Fed. R. Evid. 104. United States v. Kahre, 610 F. Supp. 2d 1261, 1265 (D.
`Nev. 2009). Defendants do challenge the sufficiency of the certifications for the noted
`entities, and request the opportunity to challenge the certifications. While the court could
`schedule a hearing for such challenges, most of the “custodians” in question are also
`substantive government witnesses at trial, as detailed in the below chart. The government
`should be required to lay the foundation for those custodian’s documents when they call
`those witnesses. And the fact that they are substantively testifying in the government’s
`case obviates the primary reason the government cites for its desire to admit the
`documents pursuant to FRE 902(11), namely the government’s desire not to “avoid delay
`at trial” due to “custodians appearing for the sole purpose of authenticating their records”
`(Dkt. 397 at 2).
`III. CONCLUSION
`In summary, for the reasons stated herein, Defendants object to the government’s
`authentication motion as follows:
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`18-cr-04683-GPC
`DEFENDANTS’ OPPOSITION TO THE GOVERNMENT’S AMENDED NOTICE OF
`AUTHENTICATION PURSUANT TO FED. R. EVID. 902(11) & (13)
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`Case 3:18-cr-04683-GPC Document 431 Filed 05/19/22 PageID.6577 Page 8 of 13
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`Records
`From
`
`
`Broadcloud
`
`Custodian on
`902
`Certificate
`
`
`Brian Turbow
`
`
`
`COA
`Exhibit No.
`
`
`207
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`218
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`224
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`225
`
`226
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`
`227
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`228
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`229
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`230
`
`Goodman Law
`Firm
`Moniker
`
`ARIN
`
`
`Mata Group
`
`Cogent
`
`Telic
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`Hostwinds
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`GetAds (25)
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`231
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`GetAds (12)
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`Stipulate to Authenticity?
`
`Object. The COA is
`deficient on its face, and the
`custodian is testifying as a
`government witness.
`Yes.
`
`Yes.
`
`Linda
`Goodman
`Volker
`Greimann
`John Sweeting Yes.
`
`
`Object. The COA is
`deficient on its face, and the
`Vincent
`custodian is testifying as a
`Tarney
`government witness.
`Reid Zulager Object. The COA is
`deficient on its face, and the
`custodian is testifying as a
`government witness.
`Yes.
`Object. The COA is
`deficient on its face, and the
`custodian is testifying as a
`government witness.
`Object. The custodian does
`not work for the company
`whose records are being
`authenticated, and no
`foundation has been laid.
`Object. The custodian does
`not work for the company
`whose records are being
`authenticated, and no
`foundation has been laid.
`Object. The COA is
`
`Jeff Morgan
`
`
`Peter Holden
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`
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`Chris Guy
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`
`
`Chris Guy
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`7
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`18-cr-04683-GPC
`DEFENDANTS’ OPPOSITION TO THE GOVERNMENT’S AMENDED NOTICE OF
`AUTHENTICATION PURSUANT TO FED. R. EVID. 902(11) & (13)
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`Case 3:18-cr-04683-GPC Document 431 Filed 05/19/22 PageID.6578 Page 9 of 13
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`232
`
`GoDaddy
`
`Keena Willis
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`deficient on its face, and the
`custodian is testifying as a
`government witness.
`Object. The COA is
`deficient on its face, and the
`custodian is testifying as a
`government witness.
`Object. The COA is
`deficient on its face, and the
`custodian is testifying as a
`government witness.
`Object. The custodian does
`not work for the company
`whose records are being
`authenticated, and no
`foundation has been laid.
`Object. The custodian does
`not work for the company
`whose records are being
`authenticated, and no
`foundation has been laid.
`Yes.
`
`Object. The COA is
`deficient on its face, and the
`custodian is testifying as a
`government witness.
`Object. The COA is
`deficient on its face, and the
`custodian is testifying as a
`government witness.
`Object. The custodian will
`be testifying as a
`government witness, and
`the COA is not credible.
`Yes.
`
`
`233
`
`
`234
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`235
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`236
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`237
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`238
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`PayPal
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`Dax Hardy
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`Name.com
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`CPH
`Resources (43)
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`Jonathan
`Harrill
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`CPH
`Resources (43,
`2nd
`production)
`
`State of
`Delaware
`Enom/Tucows
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`Jonathan
`Harrill
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`
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`239
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`Enom
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`240
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`241
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`Amobee
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`
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`Mario
`Samonte
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`State of
`Louisiana
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`18-cr-04683-GPC
`DEFENDANTS’ OPPOSITION TO THE GOVERNMENT’S AMENDED NOTICE OF
`AUTHENTICATION PURSUANT TO FED. R. EVID. 902(11) & (13)
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`Case 3:18-cr-04683-GPC Document 431 Filed 05/19/22 PageID.6579 Page 10 of 13
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`Respectfully submitted,
`BIENERT KATZMAN LITTRELL
`WILLIAMS LLP
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`
`
`
`
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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
`
`MINTZ LEVIN COHN FERRIS
`GLOVSKY AND POPEO, P.C.
`
`By: /s/ Randy K. Jones
`Randy K. Jones
`Daniel J. Goodrich (Pro Hac)
`Ryan Dougherty (Pro Hac)
`Attorneys for Mark Manoogian
`
`WIECHERT, MUNK & GOLDSTEIN, PC
`
`By: /s/ Jessica C. Munk
`
`David W. Wiechert
`Jessica C. Munk
`Attorneys for Jacob Bychak
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`Dated: May 19, 2022
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`Dated: May 19, 2022
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`Dated: May 19, 2022
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`18-cr-04683-GPC
`DEFENDANTS’ OPPOSITION TO THE GOVERNMENT’S AMENDED NOTICE OF
`AUTHENTICATION PURSUANT TO FED. R. EVID. 902(11) & (13)
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`Case 3:18-cr-04683-GPC Document 431 Filed 05/19/22 PageID.6580 Page 11 of 13
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`Dated: May 19, 2022
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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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`10
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`18-cr-04683-GPC
`DEFENDANTS’ OPPOSITION TO THE GOVERNMENT’S AMENDED NOTICE OF
`AUTHENTICATION PURSUANT TO FED. R. EVID. 902(11) & (13)
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`Case 3:18-cr-04683-GPC Document 431 Filed 05/19/22 PageID.6581 Page 12 of 13
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`CERTIFICATION OF AUTHORIZATION TO SIGN SIGNATURE
`The undersigned counsel of record for Defendant Mohammed Abdul Qayyum
`certifies that the content of this document is acceptable to each of the Defendants’ counsel
`whose electronic signature appears thereon, and that I have obtained their authorization to
`sign this document on their behalf.
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`/s/ Whitney Z. Bernstein
` Whitney z. Bernstein
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`CERTIFICATE OF AUTHORIZATION
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`3:18-cr-04683-GPC
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`Case 3:18-cr-04683-GPC Document 431 Filed 05/19/22 PageID.6582 Page 13 of 13
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`CERTIFICATE OF SERVICE
`Counsel for Defendant Mohammed Abdul Qayyum certifies that the foregoing
`pleading has been electronically served on the following parties by virtue of their
`registration with the CM/ECF system:
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`Counsel for Defendant certifies that the foregoing pleading has been electronically served
`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
`Candina S. Heath
`Department of Justice
`1301 New York Avenue NW, Suite 600
`Washington, DC 20530
`candina.heath2@usdoj.gov
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`/s/ Whitney Z. Bernstein.
` Whitney Z. Bernstein
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`CERTIFICATE OF AUTHORIZATION
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`3:18-cr-04683-GPC
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