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MEMORANDUM in Support by PacMar Technologies LLC as to Martin Kao re… — PPP Attempt Conspiracy Legal Filings (Dkt. 198)

No. 1:21-cr-00061-LEK · Doc. 198 · Docket on CourtListener

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Case 1:21-cr-00061-LEK     Document 198   Filed 05/14/26   Page 1 of 21 PageID.2468



 KOBAYASHI SUGITA & GODA, LLP

 DAVID M. LOUIE                2162
 JESSE W. SCHIEL               7995
 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,                   MOVANT PACMAR
                                          TECHNOLOGIES LLC'S
       vs.                                SUPPLEMENTAL MEMORANDUM
                                          IN SUPPORT OF RENEWED MOTION
 MARTIN KAO,                              FOR RESTITUTION PURSUANT TO
                                          18 U.S.C. § 3663A AND § 3664, FILED
             Defendant.                   ON MARCH 10, 2026; CERTIFICATE
                                          OF SERVICE
Case 1:21-cr-00061-LEK            Document 198                  Filed 05/14/26          Page 2 of 21 PageID.2469



                        TABLE OF CONTENTS
 I.    INTRODUCTION ...........................................................................................1
 II.   ARGUMENT ...................................................................................................2
       A.       PacMar’s Attorneys’ Fees Are Categorically Recoverable Under the
                MVRA ...................................................................................................2
                1.       The Ninth Circuit Adopts a Broad View of Recoverable
                         Investigation Costs ......................................................................2
                2.       Lagos Preserves PacMar’s Fees — It Does Not Limit Them.....4
                3.       Both Investigations Were Criminal Grand Jury Proceedings .....5
                4.       The Court Has Already Determined PacMar Is Entitled to
                         Restitution ...................................................................................5
       B.       The Applicable Legal Standard Requires Reasonable Approximation,
                Not Line-by-Line Precision...................................................................6
                1.       Preponderance of the Evidence Means Reasonable
                         Approximation ............................................................................6
                2.       PacMar’s Submission Is Not a “Back-of-the-Envelope”
                         Approximation ............................................................................7
                3.       The MVRA’s Mandatory Framework Makes Denial a Last
                         Resort ..........................................................................................8
       C.       PacMar’s Submission Satisfies the Applicable Standard .....................9
                1.       The Ninth Circuit Has Endorsed Exactly This Type of Affidavit
                         .....................................................................................................9
                2.       Sworn Declarations from the Billing Attorney, Combined with
                         Invoices, Are Sufficient ............................................................10
                3.       Percentage-Based Allocation Is an Accepted Methodology ....11
                4.       Block Billing Reduces an Award; It Does Not Eliminate One 13
                5.       PacMar Has Already Implemented the “Reasonable Solution”
                         Courts Require ..........................................................................14
       D.       Denial With Prejudice Is Inappropriate and Inconsistent With the
                MVRA’s Mandatory Framework ........................................................15

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 III.   CONCLUSION..............................................................................................16




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                                     TABLE OF AUTHORITIES

                                                                                                         Page(s)

 Cases

 Dolan v. United States,
   560 U.S. 605 (2010)........................................................................................8, 16

 In re Sealed Case,
     702 F.3d 59 (D.C. Cir. 2012) ................................................................................ 7

 Lagos v. United States,
   584 U.S. 577 (2018)......................................................................................2, 4, 5

 United States v. Afriyie,
   27 F.4th 161 (2d Cir. 2022) ............................................................................5, 14

 United States v. Amato,
   540 F.3d 153 (2d Cir. 2008) .........................................................................10, 15

 United States v. Anderson,
   741 F.3d 938 (9th Cir. 2013) ................................................................................ 8

 United States v. Avenatti,
   No. (S1) 19 Cr. 373 (PGG), 2022 WL 452385 (S.D.N.Y. Feb. 14,
   2022), aff’d, 81 F.4th 171 (2d Cir. 2023) .....................................................13, 14

 United States v. Battista,
   575 F.3d 226 (2d Cir. 2009) ............................................................................... 13

 United States v. Cardozo,
   68 F.4th 725 (1st Cir. 2023)............................................................................ 7, 11

 United States v. Dadyan,
   76 F.4th 955 (9th Cir. 2023) ................................................................................. 6

 United States v. Donaghy,
   570 F. Supp. 2d 411 (E.D.N.Y. 2008) ................................................................11

 United States v. Eyraud,
   809 F.3d 462 (9th Cir. 2015) ............................................................................3, 4



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 United States v. Ferdman,
   779 F.3d 1129 (10th Cir. 2015) ..................................................................7, 9, 15

 United States v. Fogel,
   494 F. Supp. 2d 136 (D. Conn. 2007).................................................................12

 United States v. Gordon,
   393 F.3d 1044 (9th Cir. 2004) .......................................................................... 3, 4

 United States v. Gupta,
   925 F. Supp. 2d 581 (S.D.N.Y. 2013) ................................................................ 12

 United States v. Gushlak,
   728 F.3d 184 (2d Cir. 2013) ................................................................................. 6

 United States v. Holmes,
   673 F. Supp. 3d 1049 (N.D. Cal. 2023) ................................................................ 8

 United States v. Kennedy,
   643 F.3d 1251 (9th Cir. 2011) .............................................................................. 6

 United States v. Manlapaz,
   825 F. App’x 109 (4th Cir. 2020) ......................................................................... 7

 United States v. Savoie,
   985 F.2d 612 (1st Cir. 1993)................................................................................. 7

 United States v. Waknine,
   543 F.3d 546 (9th Cir. 2008) ..................................................................3, 6, 9, 10

 Statutes

 18 U.S.C. § 3663A ..................................................................................................... 1

 18 U.S.C. § 3663A(a)(1) ......................................................................................8, 15

 18 U.S.C. § 3663A(b)(4)....................................................................................2, 3, 4

 18 U.S.C. § 3663A(c)(3)(B) ................................................................................9, 15

 18 U.S.C. § 3664 ........................................................................................................ 1

 18 U.S.C. § 3664(e) ................................................................................................... 6



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    MOVANT PACMAR TECHNOLOGIES LLC’S SUPPLEMENTAL
     MEMORANDUM IN SUPPORT OF RENEWED MOTION FOR
 RESTITUTION PURSUANT TO 18 U.S.C. § 3663A AND § 3664, FILED ON
                     MARCH 10, 2026

 I.    INTRODUCTION

       Pursuant to the Court’s Electronic Order of April 30, 2026 [Dkt. 197] (the

 “EO”), PACMAR TECHNOLOGIES LLC f/k/a MARTIN DEFENSE GROUP,

 LLC f/k/a NAVATEK LLC (“PacMar”) respectfully submits this Supplemental

 Memorandum in support of its Renewed Motion for Restitution [Dkt. 190]

 (“Renewed Motion”).

       The EO directs PacMar to address the concerns raised at the April 30, 2025

 hearing when the Court denied PacMar’s prior request without prejudice. Those

 concerns centered on whether PacMar’s documentation was sufficiently specific to

 allow the Court to determine an appropriate restitution amount. Defendant Martin

 Kao’s (“Defendant Kao” or “Kao”) position — then and now — is that PacMar

 cannot provide that specificity and that its Renewed Motion should therefore be

 denied with prejudice.

       Kao is wrong on both the law and the record. The Renewed Motion already

 provides what the law requires: a sworn declaration from Preston Burton, the lead

 Buckley LLP partner who directed all of the work, offering a professional estimate

 grounded in firsthand knowledge of both investigations (the “Burton

 Declaration”), supported by highlighted invoices and two independent


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 methodologies producing corroborating figures. Under the Ninth Circuit’s and every

 other circuit’s interpretation of the Mandatory Victims Restitution Act (“MVRA”),

 this submission is sufficient for several reasons.

       First, PacMar’s attorneys’ fees are categorically recoverable under the MVRA

 — the Ninth Circuit has adopted a broad view of recoverable investigation costs,

 and the Supreme Court’s decision in Lagos v. United States expressly preserves,

 rather than limits, recovery for fees incurred in response to government grand jury

 subpoenas.

       Second, the applicable legal standard does not require line-by-line precision;

 it requires reasonable approximation supported by sound methodology.

       Third, PacMar’s submission — the Burton Declaration combined with

 highlighted invoices and two corroborating calculations — is precisely the evidence

 that the Ninth Circuit and other courts have found sufficient to support a restitution

 award.


II.    ARGUMENT

       A.     PacMar’s Attorneys’ Fees Are Categorically Recoverable Under
              the MVRA
              1.   The Ninth Circuit Adopts a Broad View of Recoverable
                   Investigation Costs

       Section 3663A(b)(4) of the MVRA requires restitution for “other expenses

 incurred during participation in the investigation or prosecution or attendance at


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 proceedings related to the offense.” 18 U.S.C. § 3663A(b)(4). The Ninth Circuit has

 “adopted a ‘broad view of the restitution authorization [for investigation costs],’

 holding that ‘investigation costs — including attorneys’ fees — incurred by private

 parties as a direct and foreseeable result of the defendant’s wrongful conduct may

 be recoverable.’” United States v. Eyraud, 809 F.3d 462, 468 (9th Cir. 2015)

 (citation omitted) (emphasis in original). To qualify, fees must be “reasonably

 necessary” to aid in the investigation or prosecution. United States v. Waknine, 543

 F.3d 546, 559 (9th Cir. 2008). Congress’s intent was that courts “engage in an

 expedient and reasonable restitution process, with uncertainties resolved with a view

 toward achieving fairness to the victim.” United States v. Gordon, 393 F.3d 1044,

 1048 (9th Cir. 2004).

       In Gordon, the Ninth Circuit specifically affirmed restitution for over $1

 million in investigation costs where those “costs were incurred in response to five

 grand jury subpoenas and a number of government requests requiring [the victim] to

 analyze vast amounts of documentation and electronic information.” Id. at 1057.

 This is precisely PacMar’s situation: Buckley was engaged specifically to respond

 to grand jury subpoenas from the USAO for the District of Hawaii and the USAO

 for the District of Columbia, and the highlighted invoice entries in Exhibit C to the

 Renewed Motion reflect work related to document collection, review, production,




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 and privilege screening in connection with those subpoenas. Declaration of Preston

 Burton in support of the Renewed Motion (“Burton Decl.”) ¶¶ 2, 8.

       Eyraud extended Gordon, holding that fees incurred during the victim’s

 “initial criminal investigation alongside the FBI” and “during the grand jury

 proceedings” are covered under § 3663A(b)(4). 809 F.3d at 468. Together, Gordon

 and Eyraud confirm that attorneys’ fees incurred by a victim to assist a government

 criminal investigation are recoverable where reasonably necessary and directly tied

 to the investigation or prosecution.

              2.    Lagos Preserves PacMar’s Fees — It Does Not Limit Them

       Lagos v. United States holds that Section 3663A(b)(4)’s reference to

 “investigation” is limited to government investigations and criminal proceedings —

 meaning fees incurred in a victim’s purely private, self-initiated internal

 investigation do not qualify. 584 U.S. 577, 581–82 (2018). The Supreme Court

 expressly preserved recovery for fees incurred “testify[ing] before a grand jury” and

 attending criminal proceedings. Id. at 582.

       PacMar did not retain Buckley to conduct a private investigation. See Burton

 Decl. ¶ 2. PacMar retained Buckley because it was served with compulsory grand

 jury subpoenas — by the USAO for the District of Hawaii, and by the USAO for the

 District of Columbia. See id. ¶ 5. The government came to PacMar; PacMar did not

 seek out the government. See id. Buckley’s work responding to those subpoenas is


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 the paradigm case Lagos preserved. Lagos thus supports PacMar’s claim; it does not

 limit it.

              3.     Both Investigations Were Criminal Grand Jury Proceedings

        In United States v. Afriyie, the Second Circuit drew a line between recoverable

 work (USAO criminal investigation) and non-recoverable work (parallel SEC civil

 investigation). 27 F.4th 161, 169 (2d Cir. 2022).

        That line does not cut against PacMar. Both the Hawaii and D.C.

 investigations were criminal grand jury proceedings — both resulted in federal

 criminal charges and guilty pleas by Defendant Kao. The allocation question here is

 one of apportionment between two covered investigations, not between a covered

 and an uncovered one. Because every dollar at issue was incurred in connection with

 one or both government criminal investigations, the threshold coverage requirement

 under Afriyie is satisfied for all claimed amounts.

              4.     The Court Has Already Determined PacMar Is Entitled to
                     Restitution

        At the April 30, 2025 hearing, the Court confirmed unequivocally that “I do

 think [PacMar is] legally entitled to certain restitution.” See Exhibit B to the

 Renewed Motion at 23:21–24. Kao has not challenged PacMar’s victim status or its

 entitlement to some amount of restitution. See Kao’s MIO to the Renewed Motion




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 [Dkt. 195] (“Kao’s MIO”) at 3–4. The threshold question is resolved. What remains

 is the quantum.

       B.     The Applicable Legal Standard Requires                      Reasonable
              Approximation, Not Line-by-Line Precision

              1.    Preponderance       of       the   Evidence   Means   Reasonable
                    Approximation

       Any dispute as to the proper amount of restitution “shall be resolved by the

 court by the preponderance of the evidence.” 18 U.S.C. § 3664(e). Federal courts are

 unanimous that preponderance under the MVRA does not mean exact proof. It

 means reasonable approximation supported by sound methodology.

       The Ninth Circuit has squarely held that the MVRA requires only “some

 reasonable certainty” about the amount of a victim’s damages; “mathematical

 precision” is not a “requirement.” United States v. Kennedy, 643 F.3d 1251, 1261

 (9th Cir. 2011) (emphasis added). The government must provide evidence sufficient

 for the court to estimate “the full amount of the victim’s losses with some reasonable

 certainty.” Id. The district court “is entitled to draw reasonable inferences when

 arriving at its restitution calculation.” United States v. Dadyan, 76 F.4th 955, 961

 (9th Cir. 2023). Evidence used must possess “sufficient indicia of reliability to

 support its probable accuracy.” Waknine, 543 F.3d at 557.

       This standard is consistent across the circuits. See United States v. Gushlak,

 728 F.3d 184, 195–96 (2d Cir. 2013) (“[T]he MVRA requires only a reasonable


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 approximation of losses supported by a sound methodology” and calculations need

 not be “mathematically precise,” especially “in cases in which an exact dollar

 amount is inherently incalculable.”); United States v. Cardozo, 68 F.4th 725, 734

 (1st Cir. 2023) (emphasizing that the government’s burden is “not a heavy one: as

 long as the court’s order reasonably responds to some reliable evidence, no more is

 exigible.”); United States v. Savoie, 985 F.2d 612, 617 (1st Cir. 1993) (“[S]o long as

 the basis for reasonable approximation is at hand, difficulties in achieving exact

 measurements will not preclude a trial court from ordering restitution.”); United

 States v. Ferdman, 779 F.3d 1129, 1133 (10th Cir. 2015) (noting courts “may resolve

 restitution uncertainties with a view towards achieving fairness to the victim so long

 as [the court] still makes a reasonable determination of appropriate restitution rooted

 in a calculation of actual loss.”) (emphasis in original); In re Sealed Case, 702 F.3d

 59, 66 (D.C. Cir. 2012) (A restitution amount need not “be proven with exactitude”

 and “determining the dollar amount of a victim’s losses . . . will inevitably involve

 some degree of approximation, which is not fatal.”); United States v. Manlapaz, 825

 F. App’x 109, 118 (4th Cir. 2020) (The MVRA “does not require absolute precision

 so long as there is a basis for reasonable approximation.”).

              2.     PacMar’s Submission Is Not a “Back-of-the-Envelope”
                     Approximation

       Kao may suggest that PacMar’s percentage-based methodology is the kind of

 arbitrary “back-of-the-envelope” approach the Ninth Circuit cautioned against in

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 United States v. Anderson, 741 F.3d 938, 953 (9th Cir. 2013). Anderson is

 inapposite. There, the court vacated a restitution order where losses were simply “not

 quantifiable to any degree of certainty.” Id. at 954. Absent from that record were

 what PacMar has provided here: actual billing records, a sworn declaration from the

 lead billing attorney explaining the methodology, and two independent calculations

 producing corroborating figures. Similarly, the district court in United States v.

 Holmes denied a $500,000 request for legal fees where no “billing records or other

 supporting documents” were submitted at all. 673 F. Supp. 3d 1049, 1064 (N.D. Cal.

 2023).

       PacMar’s submission is the direct opposite of Holmes. The distinction

 between what courts reject and what they approve is not precision versus

 approximation; it is arbitrary guesswork versus reasonable estimation grounded in

 evidence. PacMar’s submission is the latter.

              3.    The MVRA’s Mandatory Framework Makes Denial a Last
                    Resort

       The MVRA commands that “the court shall order . . . that the defendant make

 restitution to the victim.” 18 U.S.C. § 3663A(a)(1). The Supreme Court in Dolan v.

 United States confirmed that the MVRA “places primary weight upon, and

 emphasizes the importance of, imposing restitution upon those convicted of certain

 federal crimes,” and that procedural difficulties cannot defeat that mandate. 560 U.S.

 605, 612 (2010).

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       When documentation presents challenges, the Tenth Circuit in Ferdman

 identified three tools available to the Court: (1) request additional evidence, (2) hold

 an evidentiary hearing, or (3) only as a narrow last resort under § 3663A(c)(3)(B),

 decline to order restitution where determining the amount would complicate or

 prolong sentencing to a degree that outweighs the restitution interest. 779 F.3d at

 1133. That complexity exception was designed for the exceptional case — not for

 the routine challenge of apportioning fees between two concurrent criminal

 investigations conducted by the same team on the same documents. Under Ferdman,

 where PacMar has provided the Court with a sworn declaration, invoices, and two

 corroborating calculations, denial with prejudice is simply not an available option.

       C.     PacMar’s Submission Satisfies the Applicable Standard

              1.     The Ninth Circuit Has Endorsed Exactly This Type of
                     Affidavit

       The Ninth Circuit in Waknine vacated a restitution order because the victim

 submitted only bare one-page summaries listing an attorney’s name and a total dollar

 amount, with no description of time spent, activities performed, or credentials. 543

 F.3d at 557. The court drew a narrow limit on that holding: “victim affidavits will

 generally provide sufficient, reliable evidence to support a restitution order. In this

 case, however, the affidavits were too summary and too conclusory to be sufficiently

 reliable.” Id. The court added, explicitly: “A sufficiently detailed affidavit

 doubtless would suffice in most cases.” Id. at 558 (emphasis added).

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       The Burton Declaration is the “sufficiently detailed affidavit” Waknine

 endorses. Burton was the lead partner who directed all of Buckley’s representation

 of PacMar in both investigations. See Burton Decl. ¶ 2. He reviewed the invoices,

 consulted with the two remaining team members who worked on both PacMar

 matters, and reviewed correspondence with the government regarding document

 productions. Id. ¶¶ 3, 7. He identified that at least 90% of the total invoiced work

 was related to one or both grand jury investigations, and that at least 25% of that

 work was attributable to the USAO Hawaii investigation, yielding a figure of at least

 $192,963.38. Id. ¶ 7. He provided a corroborating alternative calculation. Id. ¶¶ 8–

 9. He attested under penalty of perjury that both figures likely understate the true

 Hawaii amount. Id. ¶ 9. This is not the conclusory one-page summary Waknine

 rejected. It is a detailed, sworn professional assessment from the person best

 positioned to make it.

              2.     Sworn Declarations from the Billing Attorney, Combined
                     with Invoices, Are Sufficient

       The Second Circuit in United States v. Amato upheld a restitution award of

 attorneys’ fees and accounting costs where those amounts were well substantiated

 in a memorandum supported by a sworn declaration by a member of the law firm as

 well as invoices. 540 F.3d 153, 159 (2d Cir. 2008). The court also noted that the

 MVRA makes “restitution a mandatory part of the sentences imposed for certain

 categories of offenses” and thus “[i]t requires district courts to reimburse the victim”

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 where the statute’s conditions are met. Id. This is exactly PacMar’s Renewed Motion

 submission — the Burton Declaration (a sworn statement by the Buckley

 engagement partner) supported by Exhibit C (the highlighted Buckley invoices).

       The First Circuit in Cardozo went further, holding that billing statements

 “prepared in the ordinary course of professional practice” need not even be sworn to

 be reliable for restitution purposes: “We are aware of no authority that requires a

 billing statement, prepared in the ordinary course of professional practice, to be

 sworn before it can be deemed reliable.” 68 F.4th at 735. PacMar has done more

 than Cardozo required — the Burton Declaration is sworn under penalty of perjury

 and is supported by the underlying invoices.

              3.    Percentage-Based Allocation Is an Accepted Methodology

       The leading case directly endorsing percentage-based allocation for MVRA

 restitution is United States v. Donaghy, 570 F. Supp. 2d 411 (E.D.N.Y. 2008). In

 Donaghy, the NBA sought restitution for attorneys’ fees incurred assisting the

 government in the referee-corruption investigation. The billing records covered

 work that partly related to assisting the government and partly to other matters, and

 each attorney “explained that only a portion of a billing entry was dedicated to

 assisting the government, and . . . gave his or her best estimate as to how many hours

 are recoverable.” Id. at 431. The court upheld a 25% allocation methodology, finding

 the affidavits “while not extremely detailed” sufficient to establish a reasonable


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 estimate by a preponderance, and noted that “uncertainties with respect to the

 amount in question should be resolved in favor of the victim.” Id. at 423, 432. The

 court also applied a 33% proportional multiplier to one attorney’s billing where

 precise attribution was impossible. Id. at 435.

       This is Burton’s Declaration in a nutshell: the engagement partner who

 directed the work explained, on the basis of firsthand knowledge, what percentage

 of the overlapping efforts was attributable to the Hawaii investigation.

       United States v. Gupta, 925 F. Supp. 2d 581 (S.D.N.Y. 2013) reinforces this

 approach. In Gupta, Judge Rakoff reviewed 542 pages of billing records for fees

 incurred across multiple parallel matters, applied a percentage-based exclusion of

 approximately 9–10% of entries he found non-necessary, and awarded

 approximately 90% of the total requested. Id. at 584, 587–88. The key was that the

 records identified the nature of the work with “sufficient particularity to assess what

 was done, how it was done, and why it was done.” Id. at 587. The Burton Declaration

 supplies precisely that particularity for PacMar’s highlighted entries.

       Similarly, in United States v. Fogel, 494 F. Supp. 2d 136 (D. Conn. 2007), the

 court awarded restitution for attorneys’ fees incurred by a victim insurer in a multi-

 defendant fraud, even though the insurer could not allocate the fees by individual

 defendant, because the victim documented total fees, demonstrated their connection




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 to the criminal investigation as a whole, and allocated a proportionate share. PacMar

 has done exactly the same.

          Finally, United States v. Battista, 575 F.3d 226, 233–34 (2d Cir. 2009),

 affirmed a methodology in which a district court “parsed out” compensable expenses

 from total billing using a reasonable approach — it did not require every billing entry

 to be independently verified or contemporaneously segregated into separate matter

 files.

                4.    Block Billing Reduces an Award; It Does Not Eliminate One

          Block billing warrants reduction in the MVRA context; it does not justify a

 zero award. In United States v. Avenatti, the district court found that the victim’s

 counsel’s block billing “significantly handicapped” its ability to separate

 recoverable from non-recoverable work. United States v. Avenatti, No. (S1) 19 Cr.

 373 (PGG), 2022 WL 452385, at *10 (S.D.N.Y. Feb. 14, 2022), aff’d, 81 F.4th 171

 (2d Cir. 2023). But the court did not deny the victim’s request outright. Instead, it

 awarded approximately $259,800 for entries unambiguously traceable to

 recoverable work, and the Second Circuit affirmed. See id.

          PacMar’s situation is materially stronger than Avenatti’s for two reasons.

 First, the allocation issue here is not recoverable versus non-recoverable work —

 both the Hawaii and D.C. investigations were criminal grand jury proceedings, so

 every dollar at issue was incurred in a government-compelled criminal proceeding.


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 The only question is apportionment between two fully covered investigations.

 Second, PacMar’s showing is stronger than the showing in Avenatti: in addition to

 billing records, PacMar submitted a sworn declaration from the engagement partner

 explaining, on the basis of firsthand professional knowledge, the basis for the

 allocation estimate. That declaration bridges the gap that block billing creates.

                 5. PacMar Has Already Implemented the “Reasonable
                    Solution” Courts Require

       When the Second Circuit in Afriyie confronted billing records containing

 commingled entries for recoverable (USAO criminal) and non-recoverable (SEC

 civil) work, it did not vacate the entire fee award. 27 F.4th 161. It remanded with

 instructions to the district court to “devise a reasonable solution concerning these

 commingled billing items.” Id. at 172. A sworn declaration from the engagement

 partner allocating the commingled work on the basis of firsthand knowledge —

 combined with a separate percentage methodology keyed to identified invoice

 entries — is exactly such a reasonable solution.

       PacMar has not asked this Court to accept bare billing records and extrapolate.

 PacMar has provided the Burton Declaration explaining, entry-by-entry category by

 entry-by-entry category, what the work consisted of and why a conservative

 allocation of at least 25% to the Hawaii investigation is well-supported. This is the

 methodology courts require.



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       D.     Denial With Prejudice Is Inappropriate and Inconsistent With the
              MVRA’s Mandatory Framework

       Kao requests that PacMar’s Renewed Motion be denied in its entirety with

 prejudice. See Kao MIO at 8. That request is contrary to the MVRA’s mandatory

 framework, the weight of authority, and the Court’s own prior findings.

       The statute commands that “the court shall order . . . that the defendant make

 restitution to the victim.” 18 U.S.C. § 3663A(a)(1) (emphasis added). The Second

 Circuit in Amato was clear that the MVRA makes “restitution a mandatory part of

 the sentences imposed for certain categories of offenses” and thus “[i]t requires

 district courts to reimburse the victim” where the statute’s conditions are satisfied.

 540 F.3d at 159. The Court has already determined, and Kao has not disputed, that

 PacMar is a victim of Kao’s criminal offenses. The USPO confirmed PacMar’s

 victim status. See Dkt. 177, Ex. 1 (USPO’s Victim Finding). The Court itself

 stated unequivocally at the 2025 hearing: “I do think [PacMar is] legally

 entitled to certain restitution.” See Exhibit B to the Renewed Motion at 23:21–24.

       Under Ferdman’s three-tool framework, denial with prejudice is not the

 Court’s first, second, or even third option when documentation presents challenges.

 It is a narrow last resort reserved for cases of genuine complexity where the burden

 of determination would be disproportionate. 779 F.3d at 1133; 18 U.S.C. §

 3663A(c)(3)(B). Determining the proportion of grand jury subpoena-response fees

 between two overlapping criminal investigations does not approach that threshold,

                                          15
Case 1:21-cr-00061-LEK    Document 198     Filed 05/14/26   Page 21 of 21 PageID.2488



 particularly where PacMar has supplied a sworn declaration, highlighted invoices,

 and two independent corroborating calculations.

        Denying PacMar’s claim with prejudice because the billing records are not

 amenable to line-by-line disaggregation would effectively nullify the MVRA’s

 mandatory restitution requirement for any victim whose counsel represented it in

 multiple concurrent government investigations — a result that is inconsistent with

 the statute, Dolan, and the Court’s own conclusion that PacMar is legally entitled to

 restitution.

 III.   CONCLUSION

        For the foregoing reasons, PacMar respectfully requests that this Court grant

 its Renewed Motion for Restitution and order Defendant Kao to pay restitution to

 PacMar in the amount of $192,963.38, or, alternatively, no less than $165,000.00.

        DATED: Honolulu, Hawaii, May 14, 2026.

                                        /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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