JOINDER in EX PARTE APPLICATION for Protective Order Government's Ex Parte… — USA v. Ayvazyan et al (Dkt. 235)

Summary

Defendant Vahe Dadyan, through counsel Peter Johnson, joins Defendant R. Ayvazyan's response to the government's Ex Parte Application for Modified Protective Order [Doc. # 219 and 234] and adds a supplemental memorandum, in Case No. 20-CR-579-SVW (C.D. Cal.), Document 235, filed 03/31/21. He argues the proposed order change is overbroad and unnecessary, because the application focuses on alleged violations by two (2) of the eight (8) defendants and those can be addressed by enforcing the existing order (Doc. #92). The memorandum says he was not named in the original complaint or indictment, is not charged in the aggravated identity theft counts and has complied with the order. It adds that the change would hamper his preparation for trial on May 4, 2021, and urges denial of the request.

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Peter Johnson (State Bar  No. 252542) 
Email: peter@peterjohnsonlaw.com 
Law Office of Peter Johnson 
409 N. Pacific Coast Hwy, 651  
Redondo Beach, California 90027 
Telephone: (310) 295-1785 
 
Attorney for Defendant 
VAHE DADYAN 
UNITED STATES DISTRICT COURT 
CENTRAL DISTRICT OF CALIFORNIA 
WESTERN DIVISION 
 
UNITED STATES OF AMERICA, 
 
Plaintiff, 
 
 
v. 
 
VAHE DADYAN (Defendant #8) 
Defendant 
 
 
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Case No. 20-CR-579-SVW 
 
DEFENDANT VAHE DADYAN’ S 
JOINDER IN DEFENDANT R. 
AYVAZYAN’S RESPONSE TO 
GOVERNMENT’S EX PARTE 
APPLICATION FOR MODIFIED 
PROTECTIVE ORDER [DOC. # 
219 AND 234] AND 
SUPPLMENTAL 
MEMORANDUM  
 
 
 
 
 
Defendant Vahe Dadyan, through his counsel, Peter Johnson, hereby joins in 
Defendant R. Ayvazyan’s response to the Government’s Ex Parte Application for 
Modified Protective Order [Doc. # 219 and 234] and offers the attach supplemental 
memorandum in support of the joinder.    
 
DATED: March 31, 2021  
         Respectfully submitted, 
                
       
       
       
       
By: ___________/s/________________ 
       
       
       
       
       
       
PETER JOHNSON 
       
       
       
       
       
       
Attorney for Defendant Vahe Dadyan 
 
 
Case 2:20-cr-00579-SVW     Document 235     Filed 03/31/21     Page 1 of 3   Page ID
#:2122

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SUPPLEMENTAL MEORANDUM  
I. 
Introduction 
Because the government’s proposed modified protective order is overbroad and 
unnecessary, Mr. Vahe Dadyan (Defendant #8) joins Defendant R. Ayvazyan’s 
response to the government’s ex parte application and offers the following in support of 
the joinder.  
II. 
Relevant Facts 
The First Superseding Indictment (FSI) in this case charges Mr. Dadyan with 
bank fraud, wire fraud, money laundering and conspiracy to commit bank fraud, wire 
fraud and money laundering. (Doc. #154). Mr. Dadyan is not charged in any of the 
aggravated identity theft counts. Id.  Additionally, Mr. Dadyan was not named in the 
original complaint or indictment and, therefore, he was not a party to any of the 
previous litigation involving the existing protective order. (Doc #92).   
By letter dated March 19, 2021, the government produced “Discovery 
Productions Volumes 1-15” to counsel for Mr. Dadyan.  By letter dated March 26, 2021, 
the government produced “Discovery Production Volume 16” to counsel for Mr. 
Dadyan.  Mr. Dadyan and his counsel have been in full compliance with the Court’s 
Protective Order regarding discovery in this case. (Doc. #92). 
Mr. Dadyan has no history of prior arrests, no criminal convictions, and he has 
been in full compliance with his release conditions.  
 
Case 2:20-cr-00579-SVW     Document 235     Filed 03/31/21     Page 2 of 3   Page ID
#:2123

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III. 
Argument 
The government’s proposed modification to the protective order is overbroad and 
unnecessary. Its 29-page ex parte application is focused primarily on alleged violations 
of the protective order related to only two (2) of the eight (8) defendants. The 
complaints raised in the ex parte application regarding the alleged violations can be 
addressed under the Court’s power to enforce the existing protective order. Nothing in 
the government’s ex parte application provides a justification for expanding or modifying 
the protective order to include the other six defendants.  Additionally, the proposed 
modification to the protective order will unnecessarily prejudice Mr. Dadyan by 
intruding upon his ability to efficiently prepare for the May 4, 2021 trial.  
IV. 
Conclusion 
 
For the above reasons, and the reasons discussed in Defendant R. Ayvazyan’s 
response, the Court should deny the government’s ex parte request to modify the 
protective order.   
 
DATED: March 31, 2021  
         Respectfully submitted, 
   
       
       
       
       
       
       
By: ___________/s/________________ 
       
       
       
       
       
       
PETER JOHNSON 
       
       
       
       
       
       
Attorneys for Defendant Vahe Dadyan 
  
 
Case 2:20-cr-00579-SVW     Document 235     Filed 03/31/21     Page 3 of 3   Page ID
#:2124

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