Court filing

RESPONSE in Support by USA as to Martin Kao re 190 MOTION for Hearing… — PPP Attempt Conspiracy Legal Filings (Dkt. 193)

No. 1:21-cr-00061-LEK · Doc. 193 · Docket on CourtListener

Summary

The government's response to movant PacMar Technologies LLC's renewed motion for restitution under 18 U.S.C. § 3663A and § 3664 (ECF 190), in United States of America v. Martin Kao, Crim. No. 21-00061 LEK, in the U.S. District Court for the District of Hawaii, filed March 26, 2026 as Document 193. The United States concurs in the arguments and request for restitution set out in PacMar's renewed motion. Relying on those reasons and the government's earlier submissions, it asks the court to order the defendant to pay restitution to PacMar as requested. The three-page response is signed by Assistant U.S. Attorney Craig S. Nolan and includes a certificate of service on counsel for the defendant and for PacMar.

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Full text

Case 1:21-cr-00061-LEK    Document 193   Filed 03/26/26   Page 1 of 3 PageID.2442



KENNETH M. SORENSON
United States Attorney
District of Hawaii

CRAIG S. NOLAN
Assistant U.S. Attorney
Room 6100, PJKK Federal Building
300 Ala Moana Blvd.
Honolulu, Hawaii 96850
Telephone: (808) 541-2850
Facsimile: (808) 541-2958
Email: Craig.Nolan@usdoj.gov

Attorneys for Plaintiff
UNITED STATES OF AMERICA

                IN THE UNITED STATES DISTRICT COURT

                         FOR THE DISTRICT OF HAWAII

 UNITED STATES OF AMERICA, )             Crim. No. 21-00061 LEK
                           )
              Plaintiff,   )             GOVERNMENT’S RESPONSE
                           )             TO MOVANT PACMAR
     v.                    )             TECHNOLOGIES LLC’S RENEWED
                           )             MOTION FOR RESTITUTION
 MARTIN KAO,               )             PURSUANT TO 18 U.S.C. § 3663A
                           )             AND § 3664 (ECF 190)
              Defendant.   )
                           )


           GOVERNMENT’S RESPONSE TO MOVANT
    PACMAR TECHNOLOGIES LLC’S RENEWED MOTION FOR
 RESTITUTION PURSUANT TO 18 U.S.C. § 3663A AND § 3664 (ECF 190)

      The United States of America concurs in the arguments and request for

restitution set forth in PacMar Technologies LLC’s Renewed Motion for
Case 1:21-cr-00061-LEK   Document 193        Filed 03/26/26   Page 2 of 3 PageID.2443



Restitution Pursuant to 18 U.S.C. § 3663A and § 3664 (ECF 190). For the reasons

articulated therein and those found in the government’s earlier submissions and

arguments to the Court, the government respectfully requests that the Court order

Defendant Martin Kao to pay restitution to PacMar as requested in PacMar’s

Renewed Motion.

      DATED: March 26, 2026, at Honolulu, Hawaii.

                                               KENNETH M. SORENSON
                                               United States Attorney
                                               District of Hawaii

                                               By /s/ Craig S. Nolan
                                                 CRAIG S. NOLAN
                                                 Assistant U.S. Attorney

                                               Attorneys for Plaintiff
                                               UNITED STATES OF AMERICA




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Case 1:21-cr-00061-LEK     Document 193       Filed 03/26/26   Page 3 of 3 PageID.2444



                           CERTIFICATE OF SERVICE

      I hereby certify that, on the date noted below, a true and correct copy of the

foregoing was served on the following by the specified method of service.

By CM/ECF electronic filing system

Randall K. Hironaka, Esq.
Attorney for Defendant Marin Kao

Philip Miyoshi, Esq.
Attorney for Tiffany Lam

David M. Louie, Esq.
Jesse W. Schiel, Esq.
Attorneys for PacMar Technologies LLC

By email

Sara Nieling
United States Probation Officer

      DATED: March 26, 2026, at Honolulu, Hawaii.

                                                /s/ Craig S. Nolan
                                                Craig S. Nolan
                                                U.S. Attorney’s Office
                                                District of Hawaii




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File and source

File: gov.uscourts.hid.154417.193.0.pdf
Size: 129,899 bytes
SHA-256: 82aa7f06a151b0f8e9d4cdc5967418c0247b33f01c0a5cde41b0dfd08995cd0c
Our copy: gov.uscourts.hid.154417.193.0.pdf
Original: PACER (login required)