I think you need to crack the whip right now. As with all US docs. there is the old under penalty of perjury clause
www.uspto.gov/trademarks/teas/new_teas.pdfI am quite sure you can find more than enough evidence of Homero J Garza discussing or being told and acknowledging the existence of PYC before he and his attorney filed for the application. In other words they have "willfully provided false statements..."
However since his whole operation is a scam I suspect he plans to pull a runner long before his false application winds its way through the system and simply does not care. Therefore you need to act now and force him to stop using this mark immediately which is what this dubious operation is based on.
if it was there belief that the original paycoin had no legit claim on the tm then wouldnt that mean that they didnt provide false statements? Wouldnt they only then need to show their cause for believing no tm applied to this? Just curious as to how this whole tm thing works