Proposed Order Proposed Discovery Claw-Back Order — USA v. Ayvazyan et al (Dkt. 219.16)

Summary

A [Proposed] Order Regarding Claw-Back of Confidential Discovery from Defendants, filed in the U.S. District Court for the Central District of California on March 29, 2021 as Document 219-16 in United States of America v. Richard Ayvazyan, et al., Case 2:20-cr-00579-SVW. It addresses the government’s ex parte application for an order clawing back confidential discovery materials from the possession, custody and control of the defendants. The proposed order would direct counsel for each defendant to take possession of all discovery materials designated as confidential under the protective order previously entered in the case (ECF 92). It is presented by Assistant United States Attorneys Brian Faerstein and Scott Paetty and DOJ Trial Attorney Christopher Fenton.

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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 
 
DANIEL S. KAHN 
Acting Chief, Fraud Section 
Criminal Division, U.S. Department of Justice 
CHRISTOPHER FENTON 
Trial Attorney, Fraud Section 
Criminal Division, U.S. Department of Justice 
1400 New York Avenue NW, 3rd Floor 
Washington, DC 20530 
Telephone: (202) 320-0539 
Facsimile: (202) 514-0152 
 
E-mail: 
Christopher.Fenton@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,” and 
TAMARA DADYAN, 
MANUK GRIGORYAN, 
  aka “Mike Grigoryan,” and 
      “Anton Kudiumov,” 
ARMAN HAYRAPETYAN, 
EDVARD PARONYAN, 
No. CR 20-579(A)-SVW 
[PROPOSED] ORDER REGARDING CLAW-
BACK OF CONFIDENTIAL DISCOVERY 
FROM DEFENDANTS 
 
Case 2:20-cr-00579-SVW     Document 219-16     Filed 03/29/21     Page 1 of 2   Page ID
#:1939

 
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aka “Edvard Paronian” and 
    “Edward Paronyan,” and 
VAHE DADYAN, 
 
Defendants. 
The Court has read and considered the government’s ex parte 
application for an order clawing back confidential discovery 
materials from the possession, custody, and control of defendants, 
filed by the government in this matter, which this Court 
incorporates by reference into this order, and FOR GOOD CAUSE SHOWN 
the Court hereby FINDS AND ORDERS as follows:   
1. 
Counsel for each of the defendants shall take possession 
of all discovery materials designated as confidential under the 
protective order previously entered by the Court in this case (ECF 
92), whether in hard copy or digital format, that counsel previously 
provided to their respective clients in this case.   
2. 
Once counsel for each of the defendants takes possession 
of the aforementioned discovery materials, counsel shall notify 
counsel for the government in writing. 
IT IS SO ORDERED. 
 
 
 
 
 
DATE 
 
HONORABLE STEPHEN V. WILSON 
UNITED STATES DISTRICT JUDGE 
 
Presented by: 
 
 
     /s/ 
BRIAN FAERSTEIN 
SCOTT PAETTY 
Assistant United States Attorneys 
CHRISTOPHER FENTON 
DOJ Trial Attorney 
 
 
Case 2:20-cr-00579-SVW     Document 219-16     Filed 03/29/21     Page 2 of 2   Page ID
#:1940

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