RESPONSE by USA as to Martin Kao re 21 MOTION to Modify Conditions of… — PPP Attempt Conspiracy Legal Filings (Dkt. 22)

Summary

The Government's Response to Motion to Modify Condition of Release, Document 22, filed October 27, 2020 in United States of America v. Martin Kao, Case 1:21-cr-00061-LEK (captioned Mag. No. 20-01208 WRP), in the U.S. District Court for the District of Hawaii. Responding to the defendant's Motion to Modify Condition of Release (ECF No. 21), the government states that, based on the facts set forth in the motion, it does not oppose the motion. The three-page filing is signed by Assistant U.S. Attorney Craig S. Nolan for United States Attorney Kenji M. Price, and its certificate of service lists defense counsel David M. Chaiken, Miranda Hooker and Michael Jay Green.

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 Case 1:21-cr-00061-LEK    Document 22    Filed 10/27/20   Page 1 of 3 PageID.88



KENJI M. PRICE #10523
United States Attorney
District of Hawaii

CRAIG S. NOLAN
Assistant U.S. Attorney
Room 6-100, PJKK Federal Building
300 Ala Moana Boulevard
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,      )             MAG. NO. 20-01208 WRP
                               )
               Plaintiff,      )             GOVERNMENT’S RESPONSE TO
                               )             MOTION TO MODIFY
          vs.                  )             CONDITION OF RELEASE;
                               )             CERTIFICATE OF SERVICE
MARTIN KAO,                    )
                               )
               Defendant.      )
______________________________ )

                   GOVERNMENT’S RESPONSE TO
              MOTION TO MODIFY CONDITION OF RELEASE

      The United States hereby responds to defendant’s Motion to Modify

Condition of Release (ECF No. 21). Based on the facts set forth in the Motion,

the government does not oppose the Motion.
Case 1:21-cr-00061-LEK   Document 22       Filed 10/27/20   Page 2 of 3 PageID.89



    DATED: October 27, 2020, at Honolulu, Hawaii.

                                            Respectfully submitted,

                                            KENJI M. PRICE
                                            United States Attorney
                                            District of Hawaii


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




                                       2
 Case 1:21-cr-00061-LEK    Document 22     Filed 10/27/20   Page 3 of 3 PageID.90



                          CERTIFICATE OF SERVICE

      I hereby certify that a true and correct copy of the attached was duly served

upon the following person as set forth below:



Served Electronically by CM/ECF:

DAVID M. CHAIKEN                             david.chaiken@troutman.com
Attorney Pro Hac Vice for Defendant
MARTIN KAO

MIRANDA HOOKER                               miranda.hooker@troutman.com
Attorney Pro Hac Vice for Defendant
MARTIN KAO

MICHAEL JAY GREEN                            michael@michaeljaygreen.com
Attorney for Defendant
MARTIN KAO


      DATED:       October 27, 2020, at Honolulu, Hawaii.


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

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