Case 1:10-cr-20732-UU Document 54 Entered on FLSD Docket 11/01/2010 Page 1 of 5

UNITED STATES DISTRICT COURT

SOUTHERN DISTRICT OF FLORIDA
Case No.:10-CR-20732-UU

UNITED STATES OF AMERICA,

vs.
TZEMACH DAVID NETZER KOREM,
a/k/a DAVID KOREM, MARK PEDLEY,
MARK WELLINGTON,
MARK LOGAN WELLINGTON,
JACK WILLIAMS
Defendant.
_________________________________/
OPPOSITION TO MOTION FOR STAY OF RELEASE ORDER
AND MOTION FOR RELEASE ON OWN RECOGNIZANCE

1.

On September 10, 2010, David Korem initially appeared in the Northern District of

Florida of California based on a warrant issued in the Southern District of Florida. He was held
in detention pending a pretrial detention hearing scheduled September 14, 2010.
2.

On September 14, 2010, David Korem was Ordered released on a $200,000 personal

surety bond with various special conditions.

3.

On September 14, 2010, U.S. District Court Judge Cecilia Altonaga granted the

governments motion to stay the release Order pending review by the District Court. (DE 14).
4.

David Korem has been living with Sadia Barrameda for eight years. They have a six and

a half year old son, Tzedeq. They are currently residing at 4874 South Point Discovery Bay,
California, where they have lived for the last three and a half years. Before that, they lived at
24425 Woolsey Canyon Rd. #48 Los Angeles, California 91304. Prior to that, they lived on

Case 1:10-cr-20732-UU Document 54 Entered on FLSD Docket 11/01/2010 Page 2 of 5

Woodman Ave in Burbank, California. Sadia owns and operates a high end fashion boutique,
Glamora by Sadia in Brentwood, California. Prior to their move to Discovery Bay, Korem lived
in Palo Alto, California.
5.

Korem also has four other children: David James Pedley, 33, lives in Santa Clara,

California; Rachel Wellington, 29, lives in Paris, France; Yvonne Wellington, 27, lives with her
mother, Cynthia Wellington, in Huntington Beach, California; Hazmach, 15, lives with his
mother.
6.

Korem also has other family in California. His sister, Suzanne Thomas, lives in

Altadena, California, close by to their mother, Martha Loeder. Korems sister, Merri Knowles,
lives in Alhambra, California. Finally, Korem has another sister, Jennifer West, who lives in
Orange County, California.
7.

Korem has used the same phone number for at least 8 years and his Palm Pre smart phone

has location-enabling turned on, so that his location can be established within feet. None of his
email addresses have their IP location masked. When the government sought to find Korem,
they found him at home.
8.

Although Korem has two prior convictions, those convictions are old. Korem finished

his supervised release in July 1994 and has had no arrests or convictions in the last 16 years.
While the prosecution makes much of his connection to the Dominion of Melchizedek, that
connection has been open and notorious and there has never been any intent to hide either the
Dominion or Korems connection to the Dominion. The Dominion has been viewable at the
same location on the web for more than a decade. In fact, Korem consented to be interviewed by
Bob Simon of Sixty Minutes about his connection with the Dominion. That interview occurred
at his home. His connections with Rutuma, a part of Fiji, were also open and notorious.

Case 1:10-cr-20732-UU Document 54 Entered on FLSD Docket 11/01/2010 Page 3 of 5

9.

Korem has been interviewed by the Wall Street Journal, the Washington Post, Forbes

Magazine, and numerous other major media outlets. He maintains an active Twitter site with
more than 2400 followers, @KingofSalem, and another site as inventor which features a patent
he obtained to compensate contributors to online media. Any claim that Korem is somehow in
hiding is preposterous. He made all of his appearances in connection with his two prior federal
convictions.
10.

Counsel has personal knowledge of Korems prior attention to his responsibilities to

appear in court because as a Federal Public Defender in the early 1980s, counsel was appointed
to represent Korem and participated in a six-week trial before the Honorable Thelton Henderson
and the Honorable Ray McNichol. Following his conviction in that case, Korem was granted
bail on appeal. While on bail, he was indicted in a related matter in Boston, and a warrant was
issued for his arrest. Korem surrendered to the Marshalls, had a bail hearing in San Francisco,
was ordered released, and traveled to Boston to face the charges there. He made all of his
appearance in Boston, and was convicted and served his sentences.
11.

The only minor blemish on Korems unbroken record of attendance was a halfway house

walk away; which actually demonstrates his strong ties to the community and his family. While
in custody at a Federal prison camp, Korem learned that his child was ill. He made an
unauthorized visit to make sure that the child was receiving proper medical care, and returned to
custody. Korem lost some good time for the event, but was never prosecuted as an escapee.
Since his release, Korem has had no criminal convictions.
12.

Although Korem goes by more names than most citizens, all of those names are open and

notorious and have been connected in various publications since prior to counsel first represented
him in 1983. In fact, the majority of those names and the story of several of his name changes

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and convictions are contained in the Melchizidek Bible, available on Amazon (used).
13.

In United States. v. Madoff, 586 F.Supp.2d 240, 253 -254 (S.D.N.Y., 2009), the Court

recognized that although some Courts have considered economic harm in the context of
detention to protect the safety of the community, the amount of weight to be provided to potential
economic harm is uncertain, and that even in the case of Bernard Madoff, where millions of
dollars were taken over a long period of time and there were substantial questions of where the
money had gone, the Government had failed to provide sufficient evidence that any potential
future dissemination of Madoff's assets would rise to the level of an economic harm cognizable
under ' 3142 of the Bail Reform Act. The Court also found: Ait is far too great an extension to
reach from the cases presented by the Government that narrowly recognize the possibility of
economic harm (and rarely conclude the economic harm presented rises to the level of a danger
to the community for which someone should be detained) to such a conclusion based on the
minimal evidence presented here by the Government.@ Id.
14.

Undersigned counsel has conferred with opposing counsel. Opposing counsel objects to

this motion.
15.

Here, a magistrate has already found that David Korem is neither a flight risk nor a

danger to the community. Accordingly, we request that he be released on his own recognizance.

Respectfully Submitted,

/s/ Christopher J. Cannon

Christopher J. Cannon
Attorney for Defendant David Korem
Pro Hac Vice

Case 1:10-cr-20732-UU Document 54 Entered on FLSD Docket 11/01/2010 Page 5 of 5

/s/ William R. Barzee

William R. Barzee
Florida Bar No. 0158720
William R. Barzee, P.A.
Courthouse Center
Penthouse One
40 N.W. Third Street
Miami, Florida 33128
Tel: (305) 374-3998
Fax: (305) 374-3985
WilliamBarzee@BarzeeFlores.com

CERTIFICATE OF SERVICE
I HEREBY certify that a true and correct copy of the foregoing instrument was
electronically filed with the Clerk of the Court using CM/ECF on this 1st day of November, 2010.

/s/ William R. Barzee

William R. Barzee