JOINDER in EX PARTE APPLICATION for Protective Order Government's Ex Parte… — USA v. Ayvazyan et al (Dkt. 236)

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Defendants’ Notice of Joinder in Richard Ayvazyan’s Response to Government’s Ex Parte Application for Modified Protective Order, Document 236 filed March 31, 2021 in United States of America v. Richard Ayvazyan, et al., Case No. 20-CR-579 (SVW), in the U.S. District Court for the Central District of California. Defendants Artur Ayvazyan and Tamara Dadyan join the response filed by Richard Ayvazyan (Dkt. 234). The notice argues that the court should not enter essentially the same protective order the government sought through an earlier ex parte application and that no new circumstances warrant changing the existing protective order. It is signed by Fred G. Minassian, counsel for Tamara Dadyan.

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UNITED STATES DISTRICT COURT 
CENTRAL DISTRICT OF CALIFORNIA  
 
 
UNITED STATES OF AMERICA, 
 
v. 
 
RICHARD AYVAZYAN,  
MARIETTA TERABELIAN, 
ARTUR AYVAZYAN, 
TAMARA DADYAN, 
 
Defendants. 
 
 
 
 
 
Case No.  20-CR-579 (SVW) 
 
 
 
 
 
DEFENDANTS’ NOTICE OF JOINDER IN RICHARD AYVAZYAN’S RESPONSE TO 
GOVERNMENT’S EX PARTE APPLICATION FOR MODIFIED PROTECTIVE 
ORDER 
 
I. JOINDER IN RESPONSE  
 
 
Please take notice that Defendant Artur Ayvazyan and Defendant Tamara Dadyan hereby 
join in the Response to the Government’s Ex-Parte Application for Modified Protective Order 
filed by Defendant Richard Ayvazyan (Dkt. 234). 
 
 
The government’s contention in connection with Ms. Dadyan's actions ultimately falls 
that in reviewing discovery Ms. Dadyan would then engage in the type of activity that is alleged. 
Whether the government can make those allegations at trial subject to its obligations under 
Napue v. Illinois, 360 U.S. 264 (1959) remains to be seen, but the Court is not obligated to credit 
the government’s demonstrably flawed theory of the case at this juncture and hamstring 
Dadyan’s ability to prepare for trial. 
 
 
The Court should not enter essentially the same protective order that the government tried 
and failed to receive through an earlier ex parte application. Putting aside the government’s 
unsupported and wishful thinking, as well as its continued misconduct (including its open 
defiance and blatant disregard with respect to the Court’s discovery order), there are no new 
circumstances that warrant a change to the existing protective order (as the “discovery” 
misconduct alleged by the government is a complete fiction). Moreover, the government’s 
overly-restrictive protective order denies the defendants from possessing any discovery and 
creates an unconstitutional burden that prevents them—particularly under the circumstances of 
this case—from assisting in their own defense. 
 
 
 
 
Case 2:20-cr-00579-SVW     Document 236     Filed 03/31/21     Page 1 of 2   Page ID
#:2125

2 
 
 
 
 
 
 
 
 
Respectfully submitted, 
 
 
 
Thomas A. Mesereau, Jr. 
Mesereau Law Group, P.C. 
10100 Santa Monica Blvd, Ste 300 
 Los Angeles, CA 90067 
310- 651-9960 
mesereau@mesereaulaw.com 
 
/s/ Thomas A.  Mesereau, Jr._________________________ 
 
 
Jennifer J. Wirsching 
1935 Alpha Rd. Suite 216 
Glendale, CA 91208 
424-901-9280 
wirschinglaw@outlook.com 
 
/s/ Jennifer J. Wirsching_____________ 
 
Counsel for Artur Ayvazyan 
 
 
 
Fred G. Minassian 
Law Offices of Fred G. Minassian, Inc. 
101 N. Brand Blvd., Suite 1970 
Glendale, CA 91203 
fgminassianlaw@yahoo.com 
 
/s/ Fred G. Minassian_____ 
 
 
Counsel for Tamara Dadyan 
Case 2:20-cr-00579-SVW     Document 236     Filed 03/31/21     Page 2 of 2   Page ID
#:2126

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