Court filing

EX PARTE APPLICATION for order sealing first superseding indictment and related… — USA v. Ayvazyan et al (Dkt. 174)

Record facts

Court	U.S. District Court for the Central District of California
Filed	2021-03-09

U.S. District Court for the Central District of California · No. 2:20-cr-00579-SVW · Doc. 174 · 2021-03-09 · Docket on CourtListener

Summary

The government's ex parte application for an order sealing the first superseding indictment and related documents in USA v. Ayvazyan et al, CR 20-579(A)-SVW, in the U.S. District Court for the Central District of California, filed March 9, 2021 as Doc. 174. The application asks that the indictment and related documents, except arrest warrants, stay sealed until one of four newly charged defendants, Manuk Grigoryan, Arman Hayrapetyan, Edvard Paronyan or Vahe Dadyan, is arrested and the government files a Report Commencing Criminal Action. It is made under Federal Rule of Criminal Procedure 6(e)(4). An attached declaration of Assistant United States Attorney Brian Faerstein states that the four defendants have not been taken into custody or told they are charged, and that public release could jeopardize their apprehension.

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Full text

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TRACY L. WILKISON 
Acting United States Attorney 
BRANDON D. FOX 
Assistant United States Attorney 
Chief, Criminal Division 
SCOTT PAETTY (Cal. Bar No. 274719) 
BRIAN FAERSTEIN (Cal. Bar No. 274850) 
Assistant United States Attorneys 
Major Frauds/Environmental and Community Safety Crimes Sections 
1100/1300 United States Courthouse 
312 North Spring Street 
Los Angeles, California 90012 
Telephone: (213) 894-6527/3819 
Facsimile: (213) 894-6269/0141 
E-mail: 
Scott.Paetty@usdoj.gov/Brian.Faerstein@usdoj.gov 
 
Attorneys for Plaintiff 
UNITED STATES OF AMERICA 
 
UNITED STATES DISTRICT COURT 
 
FOR THE CENTRAL DISTRICT OF CALIFORNIA 
 
UNITED STATES OF AMERICA, 
Plaintiff, 
v. 
RICHARD AYVAZYAN, 
aka “Richard Avazian” and 
    “Iuliia Zhadko,” 
MARIETTA TERABELIAN, 
  aka “Marietta Abelian” and     
      “Viktoria Kauichko,” 
ARTUR AYVAZYAN, 
aka “Arthur Ayvazyan,” 
TAMARA DADYAN, 
MANUK GRIGORYAN, 
  aka “Mike Grigoryan,” and 
      “Anton Kudiumov,” 
ARMAN HAYRAPETYAN, 
EDVARD PARONYAN, 
aka “Edvard Paronian” and 
    “Edward Paronyan,” and 
VAHE DADYAN, 
 
Defendants. 
CR 20-579(A)-SVW 
GOVERNMENT’S EX PARTE APPLICATION 
FOR ORDER SEALING FIRST 
SUPERSEDING INDICTMENT AND RELATED 
DOCUMENTS; DECLARATION OF BRIAN 
FAERSTEIN 
(UNDER SEAL) 
 
The government hereby applies ex parte for an order that the 
first superseding indictment and any related documents in the above-
titled case (except the arrest warrants for the newly-charged 
Case 2:20-cr-00579-SVW     Document 174     Filed 03/09/21     Page 1 of 4   Page ID
#:1283
VM
March 9, 2021

 
 
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defendants) be kept under seal until one of the four new defendants 
charged in the first superseding indictment (defendants Manuk 
Grigoryan, Arman Hayrapetyan, Edvard Paronyan, or Vahe Dadyan) is 
arrested and the government files a “Report Commencing Criminal 
Action” in this matter relating to that defendant. 
This ex parte application is made pursuant to Federal Rule of 
Criminal Procedure 6(e)(4) and is based on the attached declaration 
of Brian Faerstein.  
Dated: March 9, 2021 
Respectfully submitted, 
 
TRACY L. WILKISON 
Acting United States Attorney 
 
BRANDON D. FOX 
Assistant United States Attorney 
Chief, Criminal Division 
 
 
   
 
BRIAN FAERSTEIN 
SCOTT PAETTY 
Assistant United States Attorneys 
 
Attorneys for Plaintiff 
UNITED STATES OF AMERICA 
Case 2:20-cr-00579-SVW     Document 174     Filed 03/09/21     Page 2 of 4   Page ID
#:1284

 
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DECLARATION OF BRIAN FAERSTEIN 
I, Brian Faerstein, declare as follows: 
1. 
I am an Assistant United States Attorney in the United 
States Attorney’s Office for the Central District of California.  I 
am one of the prosecutors representing the government in the 
prosecution of United States v. Richard Ayvazyan, et al., the first 
superseding indictment in which is being presented to a federal grand 
jury in the Central District of California on March 9, 2021. 
2. 
Four of the defendants who are charged in the first 
superseding indictment in the above-captioned proceeding but were not 
charged in the initial indictment –- defendants Manuk Grigoryan, 
Arman Hayrapetyan, Edvard Paronyan, and Vahe Dadyan -- have not been 
taken into custody on the charges contained in the first superseding 
indictment.  Moreover, those four defendants have not been informed 
that they are being named as defendants in the first superseding 
indictment.  The likelihood of apprehending one or more of the new 
defendants to be charged might be jeopardized if the first 
superseding indictment in this case were made publicly available 
before any of the four newly-charged defendants are taken into 
custody on the first superseding indictment. 
3. 
Accordingly, the government requests that the first 
superseding indictment and sealed documents in this case (except the 
arrest warrants) be sealed and remain so until one of the four new 
defendants charged in the first superseding indictment (defendants 
Manuk Grigoryan, Arman Hayrapetyan, Edvard Paronyan, or Vahe Dadyan) 
is arrested and the government files a “Report Commencing Criminal 
Action” in this matter relating to that defendant. 
// 
Case 2:20-cr-00579-SVW     Document 174     Filed 03/09/21     Page 3 of 4   Page ID
#:1285

 
 
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4. 
I declare under penalty of perjury under the laws of the 
United States of America that the foregoing is true and correct and 
that this declaration is executed at Los Angeles, California, on 
March 9, 2021. 
 
 
 
 
 
 
 
 
 
BRIAN FAERSTEIN 
Case 2:20-cr-00579-SVW     Document 174     Filed 03/09/21     Page 4 of 4   Page ID
#:1286

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