MOTION for Return of Property Pursuant to Rule 41(g) of the Federal… — PPP Attempt Conspiracy Legal Filings (Dkt. 82)

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A Motion for Return of Property Pursuant to Rule 41(g) of the Federal Rules of Criminal Procedure, Document 82, filed January 24, 2023 in United States of America v. Martin Kao, Cr. No. 21-00061 LEK, in the U.S. District Court for the District of Hawaii. The movant is PacMar Technologies LLC, formerly known as Martin Defense Group, LLC and as Navatek LLC, represented by David M. Louie and Jesse W. Schiel of Kobayashi Sugita & Goda, LLP. PacMar seeks the return of an Apple iPhone 11 Pro that the motion states was seized by the Department of Justice in 2020 at the time of Martin Kao's arrest. The caption lists an accompanying memorandum in support, declarations, Exhibits 1 – 9 and a certificate of service; the two-page motion is signed by Mr. Schiel.

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Case 1:21-cr-00061-LEK          Document 82   Filed 01/24/23   Page 1 of 2 PageID.297
#1924247



KOBAYASHI SUGITA & GODA, LLP                                                FILED IN THE
                                                                   UNITED STATES DISTRICT COURT

DAVID M. LOUIE                2162                                      DISTRICT OF HAWAII
                                                                    Jan 24, 2023 at 3:52 p.m.
JESSE W. SCHIEL               7995                                   John A. Mannle, Clerk of Court

First Hawaiian Center
999 Bishop Street, Suite 2600
Honolulu, Hawaii 96813
Telephone: (808) 535-5700
Facsimile: (808) 535-5799
E-mail:     dml@ksglaw.com;
            jws@ksglaw.com

Attorneys for Movant
PACMAR TECHNOLOGIES LLC f/k/a
MARTIN DEFENSE GROUP, LLC f/k/a
NAVATEK LLC

                     IN THE UNITED STATES DISTRICT COURT

                              FOR THE DISTRICT OF HAWAII

 UNITED STATES OF AMERICA,                    CR. NO. 21-00061 LEK

                 Plaintiff,                   MOTION FOR RETURN OF
                                              PROPERTY PURSUANT TO RULE
           vs.                                41(g) OF THE FEDERAL RULES OF
                                              CRIMINAL PROCEDURE;
 MARTIN KAO,                                  MEMORANDUM IN SUPPORT OF
                                              MOTION; DECLARATION OF
                 Defendant.                   JAMES TOSHIZO OTA;
                                              DECLARATION OF JESSE W.
                                              SCHIEL; EXHIBITS 1 – 9;
                                              CERTIFICATE OF SERVICE
Case 1:21-cr-00061-LEK      Document 82       Filed 01/24/23   Page 2 of 2 PageID.298



    MOTION FOR RETURN OF PROPERTY PURSUANT TO RULE
    41(G) OF THE FEDERAL RULES OF CRIMINAL PROCEDURE
          PACMAR TECHNOLOGIES LLC f/k/a MARTIN DEFENSE GROUP, LLC

f/k/a NAVATEK LLC (“PacMar”) files this motion pursuant to Rule 41(g) of the

Federal Rules of Criminal Procedure seeking the return of an Apple iPhone 11 Pro

(IMEI 353247100759018, associated with the phone number ending in 0371), seized

by the Department of Justice in 2020 at the time of Defendant MARTIN KAO’S

arrest.

          DATED: Honolulu, Hawaii, January 24, 2023.

                                      /s/ Jesse W. Schiel
                                      DAVID M. LOUIE
                                      JESSE W. SCHIEL

                                      Attorneys for Movant
                                      PACMAR TECHNOLOGIES LLC
                                      f/k/a MARTIN DEFENSE GROUP,
                                      LLC f/k/a NAVATEK LLC




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