Case 3:18-cr-04683-GPC Document 488 Filed 07/22/22 PageID.7266 Page 1 of 4
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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 Defendant
`Jacob Bychak
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`UNITED STATES DISTRICT COURT
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`SOUTHERN DISTRICT OF CALIFORNIA
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`UNITED STATES OF AMERICA,
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`Plaintiff,
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`vs.
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`JACOB BYCHAK, et al.,
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`Defendants.
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` Case No. 18-CR-04683-GPC
`Assigned to Hon. Gonzalo P. Curiel
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`DEFENDANT JACOB BYCHAK’S
`UNOPPOSED MOTION FOR
`ORDER APPROVING TRAVEL
`REQUEST; [PROPOSED] ORDER
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`Defendant Jacob Bychak, by and through counsel, Jessica C. Munk, hereby
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`submits this Unopposed Motion for an order modifying Mr. Bychak’s bond
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`conditions, permitting him to travel to Delrey Beach, Florida for work from July 31,
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`2022 through August 5, 2022, and to travel to Washington D.C., and the surrounding
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`areas (Virginia and Maryland), for a family reunion on September 3, 2022 through
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`September 11, 2022, including through all cities which travel is required for flight
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`DEFENDANT BYCHAK’S UNOPPOSED MOTION FOR ORDER TO TRAVEL
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`Case 3:18-cr-04683-GPC Document 488 Filed 07/22/22 PageID.7267 Page 2 of 4
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`layovers and any additional days necessitated by flight delays or cancellations, so
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`long as Mr. Bychak provides his Pretrial Services Officer with a copy of his travel
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`itinerary and calls Pretrial Services both prior to departure and upon his return. The
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`basis for this unopposed motion is as follows:
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` 1. On October 31, 2018, Jacob Bychak and his co-defendants Mark
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`Manoogian, Mohammed Abdul Qayyum, and Petr Pacas were charged in a 10-count
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`Indictment for conspiracy to commit violations of the wire fraud statute (18 U.S.C. §
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`1343), and the CAN-SPAM Act (18 U.S.C. § 1037(a)(5)). Dkt. No. 1.
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`2. On November 1, 2018, Mr. Bychak was arraigned and released on a
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`$50,000 appearance bond secured by his signature. Dkt. Nos. 12, 15. Mr. Bychak’s
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`travel was restricted to the State of California and the State of Hawaii at the
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`discretion of Pretrial Services. Dkt. No. 15.
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`3. On May 23, 2022, the trial in this case began and, on June 10, 2022, the
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`Court declared a mistrial. Dkt. Nos. 443, 485.
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`4. On June 10, 2022, Mr. Bychak entered a guilty plea to the Superseding
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`Information, charging conspiracy to violate the CAN-SPAM Act, 18 U.S.C. §
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`1037(a)(5), (b)(3) and a violation of the CAN-SPAM Act, 18 U.S.C. § 1037(a)(5),
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`(b)(3), both misdemeanors. Dkt. Nos. 479.
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`5. Mr. Bychak’s sentencing hearing is set for October 3, 2022, at 10:30 a.m.
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`Dkt. No. 479.
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`DEFENDANT BYCHAK’S UNOPPOSED MOTION FOR ORDER TO TRAVEL
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`Case 3:18-cr-04683-GPC Document 488 Filed 07/22/22 PageID.7268 Page 3 of 4
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`6. Mr. Bychak recently obtained new employment for a remote position at a
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`company based out of Florida, and he is required to travel to Florida for training
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`from July 31, 2022 through August 5, 2022.
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`7. Mr. Bychak has a family reunion in the Washington D.C. area from
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`September 3, 2022 through September 11, 2022.
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`8. Mr. Bychak’s Pretrial Services Officer has no objection to these travel
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`requests and defers to the Court.
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`9. The government has no objection to these travel requests.
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`Respectfully submitted,
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`Dated: July 22, 2022
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`WIECHERT, MUNK & GOLDSTEIN, PC
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`By: s/Jessica C. Munk
`Jessica C. Munk
`Attorney for Defendant
`Jacob Bychak
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`DEFENDANT BYCHAK’S UNOPPOSED MOTION FOR ORDER TO TRAVEL
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`Case 3:18-cr-04683-GPC Document 488 Filed 07/22/22 PageID.7269 Page 4 of 4
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`CERTIFICATE OF SERVICE
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`Counsel for Defendant certifies that the foregoing pleading has been electronically
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`served on the following parties by virtue of their registration with the CM/ECF
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`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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` I
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` certify under penalty of perjury under the laws of the United States of
`America that the foregoing is true and correct.
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`Executed on July 22, 2022, at San Juan Capistrano, California.
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`s/Jessica C. Munk
`Jessica C. Munk
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`CERTIFICATE OF SERVICE
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