Case 3:18-cr-04683-GPC Document 497 Filed 08/31/22 PageID.7418 Page 1 of 4
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`MINTZ, LEVIN, COHN, FERRIS,
`MINTZ, LEVIN, CORN, FERRIS,
`GLOVSKYAND POPEO, P.C.
`GLOVSKYAND POPEO, P.C.
`Randy K. Jones, SBN 141711
`Randy K. Jones, SBN 141711
`3580 Carmel Mountain Road, Suite 300
`3580 Carmel Mountain Road, Suite 300
`San Diego, Ca 92130
`San Diego, Ca 92130
`Telephone: (858) 314-1510
`Telephone: (858) 314-1510
`Email: rkjones@mintz.com
`Email: rkjones@mintz.com
`
`Daniel Goodrich, BBO 692624 (Pro Hac)
`Daniel Goodrich, BBO 692624 (Pro Hac)
`Ryan Dougherty, BBO 703380 (Pro Hac)
`Ryan Dougherty, BBO 703380 (Pro Hac)
`One Financial Center
`One Financial Center
`Boston, MA 02111
`Boston, MA 02111
`Email: djgoodrich@mintz.com
`Email: djgoodrich@mintz.com
`rtdougherty@mintz.com
`rtdougherty@mintz.com
`
`Attorneys For Mark Manoogian
`Attorneys For Mark Manoogian
`
`UNITED STATES DISTRICT COURT
`UNITED STATES DISTRICT COURT
`SOUTHERN DISTRICT OF CALIFORNIA
`SOUTHERN DISTRICT OF CALIFORNIA
`
`UNITED STATES OF AMERICA,
`UNITED STATES OF AMERICA,
`Plaintiff,
`Plaintiff,
`
`v.
`v.
`JACOB BYCHAK, et al.,
`JACOB BYCHAK, et al.,
`Defendant.
`Defendant.
`
`CASE NO.: 18-CR-4683-GPC
`CASE NO.: 18-CR-4683-GPC
`The Honorable Gonzalo P. Curiel
`The Honorable Gonzalo P. Curiel
`DEFENDANT MARK
`DEFENDANT MARK
`MANOOGIAN’S UNOPPOSED
`MANOOGIAN'S UNOPPOSED
`MOTION FOR ORDER APPROVING
`MOTION FOR ORDER APPROVING
`TRAVEL REQUEST; ORDER
`TRAVEL REQUEST; ORDER
`
`Defendant Mark Manoogian, by and through counsel, Randy K. Jones, hereby
`Defendant Mark Manoogian, by and through counsel, Randy K. Jones, hereby
`submits this Unopposed Motion for an Order modifying Mr. Manoogian’s bond
`submits this Unopposed Motion for an Order modifying Mr. Manoogian's bond
`conditions, permitting him to travel to within the continental United States, so long
`conditions, permitting him to travel to within the continental United States, so long
`as Mr. Manoogian provides his Pretrial Services Officer with a copy of any planned
`as Mr. Manoogian provides his Pretrial Services Officer with a copy of any planned
`travel itinerary and calls Pretrial Services both prior to departure and upon his return.
`travel itinerary and calls Pretrial Services both prior to departure and upon his return.
`The basis for this Unopposed Motion is as follows:
`The basis for this Unopposed Motion is as follows:
`1
`1
`DEFENDANT MARK MANOOGIAN’S UNOPPOSED MOTION FOR ORDER TO TRAVEL
`DEFENDANT MARK MANOOGIAN'S UNOPPOSED MOTION FOR ORDER TO TRAVEL
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`MINTZ, LEVIN, COHN, FERRIS,
`MINTZ, LEVIN, CORN, FERRIS,
`GLOVSKYAND POPEO, P.C.
`GLOVSKYAND POPEO, P.C.
`Randy K. Jones, SBN 141711
`Randy K. Jones, SBN 141711
`3580 Carmel Mountain Road, Suite 300
`3580 Carmel Mountain Road, Suite 300
`San Diego, Ca 92130
`San Diego, Ca 92130
`Telephone: (858) 314-1510
`Telephone: (858) 314-1510
`Email: rkjones@mintz.com
`Email: rkjones@mintz.com
`
`Daniel Goodrich, BBO 692624 (Pro Hac)
`Daniel Goodrich, BBO 692624 (Pro Hac)
`Ryan Dougherty, BBO 703380 (Pro Hac)
`Ryan Dougherty, BBO 703380 (Pro Hac)
`One Financial Center
`One Financial Center
`Boston, MA 02111
`Boston, MA 02111
`Email: djgoodrich@mintz.com
`Email: djgoodrich@mintz.com
`rtdougherty@mintz.com
`rtdougherty@mintz.com
`
`Attorneys For Mark Manoogian
`Attorneys For Mark Manoogian
`
`UNITED STATES DISTRICT COURT
`UNITED STATES DISTRICT COURT
`SOUTHERN DISTRICT OF CALIFORNIA
`SOUTHERN DISTRICT OF CALIFORNIA
`
`UNITED STATES OF AMERICA,
`UNITED STATES OF AMERICA,
`Plaintiff,
`Plaintiff,
`
`v.
`v.
`JACOB BYCHAK, et al.,
`JACOB BYCHAK, et al.,
`Defendant.
`Defendant.
`
`CASE NO.: 18-CR-4683-GPC
`CASE NO.: 18-CR-4683-GPC
`The Honorable Gonzalo P. Curiel
`The Honorable Gonzalo P. Curiel
`DEFENDANT MARK
`DEFENDANT MARK
`MANOOGIAN’S UNOPPOSED
`MANOOGIAN'S UNOPPOSED
`MOTION FOR ORDER APPROVING
`MOTION FOR ORDER APPROVING
`TRAVEL REQUEST; ORDER
`TRAVEL REQUEST; ORDER
`
`Defendant Mark Manoogian, by and through counsel, Randy K. Jones, hereby
`Defendant Mark Manoogian, by and through counsel, Randy K. Jones, hereby
`submits this Unopposed Motion for an Order modifying Mr. Manoogian’s bond
`submits this Unopposed Motion for an Order modifying Mr. Manoogian's bond
`conditions, permitting him to travel to within the continental United States, so long
`conditions, permitting him to travel to within the continental United States, so long
`as Mr. Manoogian provides his Pretrial Services Officer with a copy of any planned
`as Mr. Manoogian provides his Pretrial Services Officer with a copy of any planned
`travel itinerary and calls Pretrial Services both prior to departure and upon his return.
`travel itinerary and calls Pretrial Services both prior to departure and upon his return.
`The basis for this Unopposed Motion is as follows:
`The basis for this Unopposed Motion is as follows:
`1
`1
`DEFENDANT MARK MANOOGIAN’S UNOPPOSED MOTION FOR ORDER TO TRAVEL
`DEFENDANT MARK MANOOGIAN'S UNOPPOSED MOTION FOR ORDER TO TRAVEL
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`Case 3:18-cr-04683-GPC Document 497 Filed 08/31/22 PageID.7419 Page 2 of 4
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`On October 31, 2018, Mr. Manoogian and his co-defendants Jacob
`1.
`1.
`On October 31, 2018, Mr. Manoogian and his co-defendants Jacob
`Bychak, Mohammed Abdul Qayyum, and Petr Pacas were charged in a 10-count
`Bychak, Mohammed Abdul Qayyum, and Petr Pacas were charged in a 10-count
`Indictment for conspiracy to commit violations of the wire fraud statute (18 U.S.C.
`Indictment for conspiracy to commit violations of the wire fraud statute (18 U.S.C.
`§ 1343), and the CAN-SPAM Act (18 U.S.C. § 1037(a)(5)). ECF Dkt. No. 1.
`§ 1343), and the CAN-SPAM Act (18 U.S.C. § 1037(a)(5)). ECF Dkt. No. 1.
`2.
`On November 1, 2018, Mr. Manoogian was arraigned and released on
`On November 1, 2018, Mr. Manoogian was arraigned and released on
`2.
`a $50,000 appearance bond secured by his signature. ECF Dkt. Nos. 10, 16. Mr.
`a $50,000 appearance bond secured by his signature. ECF Dkt. Nos. 10, 16. Mr.
`Manoogian’s travel was restricted to San Diego County and the states of Arizona,
`Manoogian's travel was restricted to San Diego County and the states of Arizona,
`Massachusetts, and Rhode Island at the discretion of Pretrial Services and he was
`Massachusetts, and Rhode Island at the discretion of Pretrial Services and he was
`instructed not to travel to Mexico. ECF Dkt. No. 16.
`instructed not to travel to Mexico. ECF Dkt. No. 16.
`3.
`On May 23, 2022, the trial in this case began and, on June 10, 2022, the
`On May 23, 2022, the trial in this case began and, on June 10, 2022, the
`3.
`Court declared a mistrial. ECF Dkt. Nos. 443, 485.
`Court declared a mistrial. ECF Dkt. Nos. 443, 485.
`4.
`On June 10, 2022, Mr. Manoogian entered a guilty plea to Count 1 of
`On June 10, 2022, Mr. Manoogian entered a guilty plea to Count 1 of
`4.
`the Superseding Information, charging conspiracy to violate the CAN-SPAM Act,
`the Superseding Information, charging conspiracy to violate the CAN-SPAM Act,
`18 U.S.C. § 1037(a)(5), (b)(3) and a violation of the CAN-SPAM Act, 18 U.S.C. §
`18 U.S.C. § 1037(a)(5), (b)(3) and a violation of the CAN-SPAM Act, 18 U.S.C. §
`1037(a)(5), (b)(3), both misdemeanors. ECF Dkt. Nos. 481, 482.
`1037(a)(5), (b)(3), both misdemeanors. ECF Dkt. Nos. 481, 482.
`5.
`Mr. Manoogian’s sentencing hearing is set for October 3, 2022, at 10:30
`5. Mr. Manoogian's sentencing hearing is set for October 3, 2022, at 10:30
`a.m in Courtroom 2D before Judge Gonzalo P. Curiel. ECF Dkt. No. 481.
`a.m in Courtroom 2D before Judge Gonzalo P. Curiel. ECF Dkt. No. 481.
`6.
`Mr. Manoogian recently launched a new business and plans to attend a
`6. Mr. Manoogian recently launched a new business and plans to attend a
`trade show in Lafayette, Louisiana from October 16, 2022 through October 18, 2022,
`trade show in Lafayette, Louisiana from October 16, 2022 through October 18, 2022,
`to promote his business and to develop other business opportunities.
`to promote his business and to develop other business opportunities.
`7.
`Mr. Manoogian’s new business venture may require additional travel
`7. Mr. Manoogian's new business venture may require additional travel
`within the continental United States in the coming months to promote the business
`within the continental United States in the coming months to promote the business
`and to develop other opportunities.
`and to develop other opportunities.
`8.
`Mr. Manoogian plans to travel to his home state of Massachusetts along
`8. Mr. Manoogian plans to travel to his home state of Massachusetts along
`with his wife and children to visit family from November 11, 2022 through
`with his wife and children to visit family from November 11, 2022 through
`November 13, 2022. Under the conditions of his Pretrial Release Order, Mr.
`November 13, 2022. Under the conditions of his Pretrial Release Order, Mr.
`Manoogian is permitted to travel to Massachusetts without pre-approval from this
`Manoogian is permitted to travel to Massachusetts without pre-approval from this
`Court or his Pretrial Services Officer. ECF Dkt. No. 16. Time permitting during the
`Court or his Pretrial Services Officer. ECF Dkt. No. 16. Time permitting during the
`2
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`DEFENDANT MARK MANOOGIAN’S UNOPPOSED MOTION FOR ORDER TO TRAVEL
`DEFENDANT MARK MANOOGIAN'S UNOPPOSED MOTION FOR ORDER TO TRAVEL
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`Case 3:18-cr-04683-GPC Document 497 Filed 08/31/22 PageID.7420 Page 3 of 4
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`trip, however, Mr. Manoogian and his family may also visit his sister, who lives in
`trip, however, Mr. Manoogian and his family may also visit his sister, who lives in
`New Jersey. As such, Mr. Manoogian requests permission to travel to New Jersey,
`New Jersey. As such, Mr. Manoogian requests permission to travel to New Jersey,
`and through Connecticut and New York on the way to New Jersey.
`and through Connecticut and New York on the way to New Jersey.
`9.
`Mr. Manoogian’s Pretrial Services Officer has no objection to these
`9. Mr. Manoogian's Pretrial Services Officer has no objection to these
`travel requests and defers to the Court. Further, Mr. Manoogian’s Pretrial Services
`travel requests and defers to the Court. Further, Mr. Manoogian's Pretrial Services
`Officer suggested that Mr. Manoogian request that the Court modify the conditions
`Officer suggested that Mr. Manoogian request that the Court modify the conditions
`of his release to allow travel within the continental United States, subject to the
`of his release to allow travel within the continental United States, subject to the
`discretion of Pretrial Services. Pretrial Services is not opposed to such modification.
`discretion of Pretrial Services. Pretrial Services is not opposed to such modification.
`10.
`The government has no objection to these specific travel requests or a
`10. The government has no objection to these specific travel requests or a
`modification to allow travel within the continental United States.
`modification to allow travel within the continental United States.
`
`Dated: August 31, 2022
`Dated: August 31, 2022
`
`Respectfully submitted,
`Respectfully submitted,
`MINTZ, LEVIN, COHN, FERRIS,
`MINTZ, LEVIN, CORN, FERRIS,
`GLOVSKY AND POPEO, P.C.
`GLOVSKY AND POPEO, P.C.
`
`/s/ Randy K. Jones
`/s/ Randy K Jones
`Randy K. Jones
`Randy K. Jones
`Daniel J. Goodrich (Pro Hac)
`Daniel J. Goodrich (Pro Hac)
`Ryan Dougherty (Pro Hac)
`Ryan Dougherty (Pro Hac)
`Attorneys for Mark Manoogian
`Attorneys for Mark Manoogian
`
`3
`3
`DEFENDANT MARK MANOOGIAN’S UNOPPOSED MOTION FOR ORDER TO TRAVEL
`DEFENDANT MARK MANOOGIAN'S UNOPPOSED MOTION FOR ORDER TO TRAVEL
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`Case 3:18-cr-04683-GPC Document 497 Filed 08/31/22 PageID.7421 Page 4 of 4
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`CERTIFICATE OF SERVICE
`CERTIFICATE OF SERVICE
`Counsel for the Defendant certifies that the foregoing pleading has been
`Counsel for the Defendant certifies that the foregoing pleading has been
`electronically served on the following parties by virtue of their registration with the
`electronically served on the following parties by virtue of their registration with the
`CM/ECF system:
`CM/ECF system:
`
`Melanie K. Pierson
`Melanie K. Pierson
`Assistant U.S. Attorney
`Assistant U.S. Attorney
`880 Front Street, Rm 6293
`880 Front Street, Rm 6293
`San Diego, CA 92101
`San Diego, CA 92101
`melanie.pierson@usdoj.gov
`melanie.pierson@usdoj.gov
`
`Sabrina Feve
`Sabrina Feve
`Assistant U.S. Attorney
`Assistant U.S. Attorney
`880 Front Street, Rm 6293
`880 Front Street, Rm 6293
`San Diego, CA 92101
`San Diego, CA 92101
`sfeve@usa.doj.gov
`sfeve@usa.doj.gov
`
`Candina S. Heath
`Candina S. Heath
`Department of Justice
`Department of Justice
`1301 New York Avenue NW, Suite 600
`1301 New York Avenue NW, Suite 600
`Washington, DC 20530
`Washington, DC 20530
`candina.heath2@usdoj.gov
`candina.heath2@usdoj.gov
`
`I certify under penalty of perjury under the laws of the United States of
`I certify under penalty of perjury under the laws of the United States of
`America that the foregoing is true and correct.
`America that the foregoing is true and correct.
`
`Executed on August 31, 2022 in San Diego, California.
`Executed on August 31, 2022 in San Diego, California.
`
`/s/ Randy K. Jones
`/s/ Randy K Jones
`Randy K. Jones
`Randy K. Jones
`Attorney for Mark Manoogian
`Attorney for Mark Manoogian
`
`128722869v.4
`128722869v.4
`
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`CERTIFICATE OF SERVICE
`CERTIFICATE OF SERVICE
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