OPPOSITION to Second EX PARTE APPLICATION to Continue Trial Date from 05/04/2021 to… — USA v. Ayvazyan et al (Dkt. 267)

Summary

Filed April 8, 2021 as Document 267 in Case 2:20-cr-00579-SVW (C.D. Cal.), before Hon. Stephen V. Wilson, this is the defendants' opposition to the government's ex parte application for a continuance and exclusion of time (Dkt. 264). The defendants argue the government sought a sixteen-week continuance days after saying it was ready for trial and call this gamesmanship. They ask the Court to order the government to identify its exhibits and witnesses by April 15, 2021 and, if a continuance is needed because of jury summonses, to set a trial date no later than necessary, noting they had suggested June 15, 2021. They also ask the Court to issue a Rule 48(b) warning, saying the Court has authority to dismiss the indictment. These are the defendants' characterizations.

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DEFENDANTS’ OPPOSITION TO GOVERNMENT’S EX PARTE APPLICATION 
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Ashwin J. Ram (SBN 227513) 
aram@steptoe.com 
Michael A. Keough (SBN 327037) 
mkeough@steptoe.com 
Nicholas P. Silverman (pro hac vice) 
nsilverman@steptoe.com 
STEPTOE & JOHNSON LLP 
633 West Fifth Street, Suite 1900 
Los Angeles, CA 90071 
Telephone: (213) 439-9400 
Facsimile: (213) 439-9599 
Counsel for Defendant Richard Ayvazyan 
 
Fred G. Minassian (SBN 170974) 
fgminassian@yahoo.com  
LAW OFFICES OF FRED G.  
MINASSIAN, INC. 
101 N. Brand Blvd., Suite 1970  
Glendale, CA 91203  
Telephone: (818) 240-2444 
 
Counsel for Defendant Tamara Dadyan 
 
John L. Littrell (SBN 221601) 
jlittrell@bklwlaw.com 
 
Ryan V. Fraser (SBN 272196) 
rfraser@bklwlaw.com 
BIENERT KATZMAN LITTRELL 
WILLIAMS, LLP 
601 W. 5th Street, Suite 720 
Los Angeles, CA 90071 
Telephone: (213) 528-3400 
Facsimile: (949) 369-3701 
 
Counsel for Defendant Marietta Terabelian 
 
Thomas A. Mesereau, Jr. (SBN 91182) 
mesereau@mesereaulaw.com 
Jennifer J. Wirsching (SBN 263141) 
wirschinglaw@outlook.com 
MESEREAU LAW GROUP, P.C. 
10100 Santa Monica Blvd. Suite 300 
Los Angeles, CA 90067 
Telephone: (310) 561-9960 
 
 
 
Counsel for Defendant Artur Ayvazyan 
 
UNITED STATES DISTRICT COURT 
CENTRAL DISTRICT OF CALIFORNIA  
 
 
UNITED STATES OF AMERICA, 
 
v. 
 
RICHARD AYVAZYAN,  
et al., 
 
Defendants. 
 
 Case No.  20-cr-579 (SVW) 
 
DEFENDANTS’ OPPOSITION 
TO GOVERNMENT’S EX 
PARTE APPLICATION FOR 
CONTINUANCE AND 
EXCLUSION OF TIME (DKT. 
264) 
 
Hon. Stephen V. Wilson 
 
 
 
 
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DEFENDANTS’ OPPOSITION TO GOVERNMENT’S EX PARTE APPLICATION 
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The government’s gamesmanship knows no bounds.  Days after being taken to 
task for their attempted end-run around the Court’s protective order and discovery 
cutoff, the government claimed it was ready to proceed to trial.1  But the next day, the 
government made an about-face and filed the present application for a sixteen-week 
continuance of the trial date that it could strategically leverage.  The government 
indicted this case nearly six months ago and has already enjoyed the benefit of one 
lengthy continuance over the objection of all defendants.  There is no reason why the 
government should be allowed to reap a windfall while the Central District works to 
resume operations with the end of the pandemic in sight.  Accordingly, the defendants 
make two requests: 
First, the government should be required to identify the exhibits and witnesses it 
will use in its case-in-chief no later than April 15, 2021, approximately three weeks 
before the current trial date.  The government has pointed to no reason why the trial 
should be delayed except for the delay in sending jury summonses as the Central 
District reopens after the pandemic, and the government should not receive a windfall 
based on a pandemic-related delay.  Such an order would be consistent with the March 
15, 2021 discovery cutoff that this Court has already imposed, and would mirror the 
relief granted by Judge Walter in United States v. Cai, No. 19-cr-761 (C.D. Cal.). 
Second, to the extent a continuance is necessary due to a delay in sending jury 
summonses, the Court should enforce the defendants’ right to a speedy trial and set a 
trial date no later than is necessary to seat a jury.  Within hours of the government 
indicating it was ready for trial subject only to the issuance of jury summonses, 
defendants suggested June 15, 2021 as a trial date in the event a continuance was 
necessary.  The government then abandoned all pretense of being “ready for trial,” and 
sought a sixteen-week continuance, with absolutely no explanation for why an 
additional two-month delay was necessary and no explanation for why it ignored the 
                                                                                                                                                                      
1 See Declaration of Ashwin J. Ram, dated April 8, 2021, Ex. 1. 
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defendants’ request to identify exhibits and witnesses.  The government’s unjustified 
request for a second lengthy continuance, especially where, as here, the defendants are 
all subject to home confinement and one defendant is in custody awaiting trial is 
particularly troubling.  The parties should be prepared to go to trial as soon as a jury can 
be seated, not months later.   
Rather than grant yet another continuance, the Court should dismiss the 
indictment.  The government indicted this case and sought to restrict the liberty of 
individual citizens despite any intent to provide those individuals with a speedy trial to 
clear their names.  The government’s rush to indict when it was not capable of going to 
trial and its consequent obstinance at every turn in providing its trial materials should 
not be countenanced and merits dismissal rather than a continuance.  If the Court does 
grant a continuance, however, the court should set the case for trial no later than June 
15, 2021, and should reject the requested exclusion of time under the Speedy Trial Act.  
I. 
THE COURT SHOULD ORDER THE GOVERNMENT TO DISCLOSE 
ITS TRIAL EXHIBITS AND WITNESS LIST ON APRIL 15, 2021, 
CONSISTENT WITH THE CURRENT TRIAL DATE 
Regardless of whether the Court grants a second continuance over the objection 
of all defendants, the Court should order the government to identify its witnesses and 
trial exhibits by April 15, 2021—three weeks before the trial date chosen by the 
government in its first request for a continuance and over one week after the 
government stated it was ready to proceed to trial.  There is no excuse for the 
government to continue to withhold this information from the defense after the 
government has had months to prepare for trial. 
The government chose to file a criminal indictment in the midst of a pandemic, 
then requested that the defendants be held without bail, ultimately securing orders that 
place the applicable defendants under house arrest until trial.  Beginning within twenty-
four hours of the November 17 indictment, each defendant requested that the 
government identify its trial exhibits and witnesses so that they could prepare for trial. 
Dkt. 63-3 § III ¶ 13; id. § VII.  The government summarily refused and ignored each 
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request for exhibits for over four weeks.  See Dkt. 96 at 7 (summarizing the requests 
and the government’s refusal to engage).  Finally, at the last moment, the government 
(moving ex parte despite the seven-week lead time it argues is required to seat a jury) 
made its first request for a continuance without producing discovery.  Dkt. 94.  The 
government specifically requested that trial be set for May 4, 2021. 
The defendants opposed the government’s request because, while the 
government may have filed charges in a district where criminal trials were “suspended 
indefinitely,” Dkt. 73 at 2, the government is not entitled to use COVID-19 “to gain a 
windfall by obtaining additional post-indictment investigation time and taking a 
lackadaisical approach to its discovery obligations.”  Dkt. 96 at 10.  The defendants 
pointed to United States v. Cai, 19-cr-761 (JFW) (C.D. Cal.), where the government 
sought to use COVID-19 to continue not just the trial date but also the deadlines for 
identifying exhibits and witnesses because the government wanted to allow for its 
“understanding of the evidence … to change, which could significantly alter the 
presentation of evidence at trial and thus the exhibits that are presented.”  Dkt. 96 at 9 
(quoting Gov’t’s Ex Parte App’n to Continue at 16, Cai, Dkt. 134).  The Cai court 
disagreed, holding that the government could not “l[ie] in wait for the continuance of 
trial” it expected and use that as an excuse not to produce its trial exhibits and witness 
lists.  Dkt. 96 at 10 (quoting Hr’g Tr. at 21, Cai, Dkt. 190).  The Cai court therefore 
continued the trial date to March 2021 but ordered the government to produce all 
exhibits and witness lists by August 2020.  Id. (citing Hr’g Tr. at 32, Cai, Dkt. 190). 
On December 22, 2020, the Court ruled on this dispute by granting the 
government’s request for a May 4, 2021 trial date but ordering the government “to 
produce all outstanding discovery, including documentary and physical evidence it 
intends to rely on in its case-in-chief” by March 15, 2021.”  Dkt. 105 (“Any evidence 
produced after March 15, 2021, will not be admitted absent extraordinary 
circumstances.”).  The Court’s Order made clear that rather than using COVID-19 as an 
excuse to indict now and investigate later, the government should expeditiously 
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produce the discovery needed for the defendants to prepare for trial.2   
            The fundamental point of Cai and this Court’s December 22, 2020 Order 
remains the same.  COVID-19 may lead to continuances resulting in extended pretrial 
house arrest periods and delayed trials, but the government is not entitled to use those 
continuances to secure a tactical advantage by withholding discovery, witness lists, and 
exhibit lists.  The only thing that has changed since December is that the government 
has had more than three additional months to attempt to complete its investigation, and 
it can no longer argue that this case “stands in stark contrast” to Cai because “in Cai, 
the government had months to complete the production of discovery and prepare its 
pretrial filings….”  Dkt. 99-2 at 8.  The government has had months to prepare for trial, 
it has indicated that it is prepared now, and it has no reason to continue to withhold 
information from the defendants. 
II.
THE COURT SHOULD ISSUE A RULE 48(B) WARNING THAT THE
GOVERNMENT CANNOT CONTINUE TO SEEK CONTINUANCES OF
A CASE IT CHOSE TO INDICT
The government indicted this case before it was ready, has already violated the
Court’s discovery order, Dkt. 248, at 3–7, and is now desperately scrambling to delay 
the trial for as long as it thinks it can ask with a straight face. Under these 
circumstances, the Court has the authority to dismiss. See id. at 7–9; Fed. R. Crim. P. 
48(b)(1), (3) (providing the Court may dismiss if “unnecessary delay occurs in” 
indicting or “bringing a defendant to trial”); Fed. R. Crim. P. 48 advisory committee’s 
note (2002) (“Rule 48(b), of course, operates independently from the [Speedy Trial] 
Act.”); United States v. Hattrup, 763 F.2d 376, 377 (9th Cir. 1985) (“It is within the 
2 The identification of trial exhibits and witnesses is necessary to prepare for trial because the 
government keeps changing the scope of its alleged crime.  The government has produced a mountain 
of hundreds of thousands pages of discovery, within which it claims are hundreds of loans that are 
somehow part of a single conspiracy and yet the government claims its case will last less than two 
weeks.  The effect of the government’s tactics is that the defendants are left without a clear picture of 
what defines the alleged conspiracy’s scope and which actions were allegedly unlawful.  Trial 
exhibits and witnesses—if narrowly tailored consistent with the government’s two-week estimate—
should help provide some notice of the government’s allegations that the defendants must prepare to 
face. 
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trial court’s inherent power under Rule 48(b) to dismiss a case with prejudice for 
prosecutorial delay not amounting to a Sixth Amendment violation.”).  Even if the 
Court does not dismiss at this time, it should at least warn the government that it faces 
the possibility of dismissal with prejudice as a sanction for any further unreasonable 
delay. In the Ninth Circuit, forewarning is a requirement for dismissal with prejudice 
under Rule 48(b). United States v. Huntley, 976 F.2d 1287, 1291 (9th Cir. 1992). 
III. 
THE COURT SHOULD DELAY THE TRIAL ONLY AS LONG AS 
NECESSARY TO SEAT A JURY 
The government’s argument for a continuance is entirely based on the delay in 
issuing jury summonses as the Central District emerges from the COVID-19 
pandemic.3  The government claims that it is otherwise ready to go to trial as soon as 
possible, and the clerk of court estimates that trials may begin in this District by June 1, 
2021.  This renders the government’s request for a sixteen-week continuance baffling.   
The clerk of court has already begun issuing jury summonses for the Central 
District’s Southern Division, and estimates that it will begin issuing summonses for the 
other divisions by April 12, 2021.4  The clerk of court estimates that trials can resume 
seven weeks after the summonses are sent, or approximately June 1, 2021.5  In response 
to the government’s claim that it was ready for trial, the defendants objected to any 
continuance, while alternatively proposing a June 15, 2021 trial date, which would 
allow the matter to proceed to trial as soon as juries could be seated subject to the 
District’s General Orders (while factoring in possible delay in the clerk of court’s 
proposed schedule for sending out summonses).  The government’s application does 
not address the defendants’ proposed trial date.  Nor does the government explain why 
                                                                                                                                                                      
3 The government half-heartedly claims that this case is a “complex” one that requires additional 
delay, but has repeatedly represented to the Court in its previous filings that its alleged scheme is 
“simple and straightforward,” Dkt. 188 at 13, 16, 23; Dkt. 207 at 7, and that trial will take less than 
two weeks.  Regardless of whether these are misrepresentations, the government claims that it is ready 
to go to trial. 
4 See https://www.cacd.uscourts.gov/news/phased-reopening-court. 
5 Id. 
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an additional ten weeks are necessary between June 15 and the government’s proposed 
trial date of August 23, 2021.  Instead, the government relies on year-old information 
regarding the effect of the pandemic on the Central District’s operations to justify yet 
another continuance of the trial date. 
Ayvazyan is well aware of the COVID-19 pandemic.  He and his wife suffered 
from symptomatic bouts of COVID-19 as a result of government-requested detention.  
But the government’s application pays short shrift to the rapidly improving conditions 
in California that are allowing the clerk of court to begin issuing jury summonses again 
in the first place.  At the time of this filing, 43% of Californians over the age of 16 have 
already received at least one dose of a COVID-19 vaccine, with a similar percentage of 
Los Angeles County residents receiving a vaccine.6  This week, Governor Gavin 
Newsom announced that California’s positivity rate for new virus cases was the lowest 
of any state in the nation and that he expected the state to abandon its tiered reopening 
system in favor of a full reopening by June 15, 2021.7  After a year of a devasting 
pandemic, there is every reason to believe that the normal functions of society—
including jury trials—can resume on the clerk of court’s projected schedule.  A June 15, 
2021 trial date accommodates the need for the clerk to issue jury summonses while 
granting defendants the ability to clear their names at trial.   
More fundamentally, the government’s requested trial date violates the original 
defendants’ right to a speedy trial.  The government has already taken advantage of the 
COVID-19 pandemic to push their trial date far past the 70 days allowed under 18 
U.S.C. § 3161.  The original defendants were indicted on November 17, 2020, and all 
four had been arraigned in the Central District of California and pleaded not guilty by 
December 4, 2020. In compliance with 18 U.S.C. § 3161(a), the case was “set … for 
trial on a date certain,” specifically, January 12, 2021.   
                                                                                                                                                                      
6 See https://abc7news.com/covid-vaccine-california-tracker-ca-newsom-update/9567632/ 
7 See, e.g., https://www.sfgate.com/bayarea/article/California-has-lowest-COVID-19-positivity-rate-
in-16082922.php 
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In December, over the defendants’ objections, the government received a 
pandemic-related continuance that resulted in the current trial date of May 4, 2021.  
Now, despite acknowledging that juries will be seated by June and claiming that they 
are ready for trial, the government is requesting a late August trial.  The defendants are 
entitled by the Speedy Trial Act and Sixth Amendment to a speedy trial. 8   The 
government has not offered a single justification for pushing the trial into late August.  
Given that the government was already granted a pandemic-related extension, and jury 
trials can clearly proceed in this district in early June (they should already be taking 
place), the Court should uphold the defendants’ Sixth Amendment rights by denying 
any continuance. If a continuance is granted over our objections, trial at a minimum 
should be scheduled for no later than June 15, 2021.     
IV. 
CONCLUSION 
For the above reasons, the Court should deny the government’s ex parte 
application and order the government to identify the exhibits and witnesses for its case-
in-chief no later than April 15, 2021. If the Court grants the continuance despite our 
objections, then, at a minimum, the Court should set the matter for trial no later than 
June 15, 2021. 
// 
// 
// 
// 
// 
                                                                                                                                                                      
8 The government acknowledges that defendant Hayrapetyan is in custody, and therefore not subject to 
the extended 180-day speedy trial clock set by the Judicial Council of the Ninth Circuit. But the 
government failed to grapple with that fact when setting an August trial date, which is more than two 
months after Hayrapetyan’s 70-day trial clock will run. Both the Supreme Court and this Circuit have 
held that codefendants are subject to the same speedy trial clock, which runs from the date the last 
codefendant is indicted or arraigned. See Henderson v. United States, 476 U.S. 321, 323 n. 2 (1986); 
United States v. Morales, 875 F.2d 775, 776 (9th Cir. 1989). The government should be held to this 
rule, and all defendants should be subject to the same speedy trial clock: the 70-day trial clock of 
Hayrapetyan. 
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Dated:  April 8, 2021 
 
 
Respectfully submitted, 
 
 
 
 
 
 
 
 
STEPTOE & JOHNSON LLP 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
/s/ Ashwin J. Ram  
 
 
 
 
 
 
 
 
 
 
Ashwin J. Ram (SBN 227513) 
 
 
 
 
 
 
 
aram@steptoe.com 
 
 
 
 
 
 
 
STEPTOE & JOHNSON LLP 
 
 
 
 
 
 
 
633 West Fifth Street, Suite 1900 
 
 
 
 
 
 
 
Los Angeles, CA 90071 
 
 
 
 
 
 
 
Telephone: (213) 439-9400 
 
 
 
Facsimile: (213) 439-9599 
 
Michael A. Keough (SBN 327037) 
mkeough@steptoe.com 
 
 
 
 
 
 
 
One Market Plaza 
Spear Tower, Suite 3900 
San Francisco, CA 94105 
Telephone: (415) 365-6700 
Facsimile: (415) 365-6699 
 
 
 
 
 
 
 
 
Nicholas P. Silverman (pro hac vice) 
 
 
 
 
 
 
 
nsilverman@steptoe.com 
 
 
 
 
 
 
 
1330 Connecticut Avenue, N.W. 
 
 
 
 
 
 
 
Washington D.C., 20036 
 
 
 
 
 
 
 
Telephone: (202) 429-8096 
 
 
 
Facsimile: (202) 329-3902 
 
 
 
 
 
 
Counsel for Defendant Richard Ayvazyan 
 
BIENERT KATZMAN LITTRELL 
WILLIAMS, LLP 
 
 
 
 
 
 
 
 
/s/ John L. Littrell  
 
 
 
 
 
 
 
 
 
 
John L. Littrell (SBN 221601)  
 
 
 
 
 
 
 
jlittrell@bklwlaw.com 
Ryan V. Fraser (SBN 272196) 
rfraser@bklwlaw.com 
BIENERT KATZMAN LITTRELL 
WILLIAMS, LLP 
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601 W. 5th Street, Suite 720 
Los Angeles, CA 90071 
Telephone: (213) 528-3400 
Facsimile: (949) 369-3701 
 
Counsel for Defendant  
Marietta Terabelian 
 
LAW OFFICES OF FRED G.  
MINASSIAN, INC. 
 
 
 
 
 
 
 
 
/s/ Fred G. Minassian 
 
 
 
Fred G. Minassian (SBN 170974) 
fgminassian@yahoo.com  
LAW OFFICES OF FRED G.  
MINASSIAN, INC. 
101 N. Brand Blvd., Suite 1970  
Glendale, CA 91203  
Telephone: (818) 240-2444 
 
Counsel for Defendant Tamara Dadyan 
 
MESEREAU LAW GROUP, P.C. 
 
 
 
 
 
 
 
 
/s/ Thomas A. Mesereau  
 
 
Thomas A. Mesereau, Jr. (SBN 91182) 
mesereau@mesereaulaw.com 
MESEREAU LAW GROUP, P.C. 
10100 Santa Monica Blvd. Suite 300 
Los Angeles, CA 90067 
Telephone: (310) 561-9960 
 
/s/ Jennifer J. Wirsching  
 
 
Jennifer J. Wirsching (SBN 263141) 
wirschinglaw@outlook.com 
1935 Alpha Rd. 216 
Glendale, CA 91208 
Telephone: (424) 901-9280 
 
Counsel for Defendant Artur Ayvazyan 
 
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SIGNATURE ATTESTATION 
Pursuant to Local Rule 5-4.3.4(a)(i), the filer attests that all signatories listed, and 
on whose behalf the filing is submitted, concur in the filing’s content and have 
authorized the filing.  
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