Court filing

Proposed Order — USA v. Ayvazyan et al (Dkt. 329.1)

Summary

A proposed Order Granting Motion to Dismiss for Prosecutorial Misconduct, Document 329-1, filed 05/10/21 in United States of America v. Richard Ayvazyan, et al., Case No. 20-cr-579 (SVW), in the United States District Court, Central District of California, before Hon. Stephen V. Wilson, with a Hearing Date of May 24, 2021 at 11:00 a.m. Counsel for Defendant Richard Ayvazyan are listed from Steptoe & Johnson LLP. The order would grant the Motion to Dismiss filed by Richard Ayvazyan and dismiss the indictment and superseding indictment with prejudice. It would also order the government to produce discovery about its internal charging decisions, grand jury exhibits, transcripts and subpoenas, and to identify trial exhibits and witness testimony derived from tainted evidence.

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Record facts

Court	U.S. District Court for the Central District of California
Filed	2021-05-10

Cite this document

“Proposed Order — USA v. Ayvazyan et al (Dkt. 329.1).” U.S. District Court for the Central District of California, No. 2:20-cr-00579-SVW, Doc. 329-1, filed 2021-05-10. Archived at Pandemic Darlings, https://pandemicdarlings.com/court-filings/full-docket-arman-hayrapetyan-cacd-813904/2021-05-10-gov-uscourts-cacd-813904-329-1-doc-329-1/, SHA-256 8debbe6b6a6c9425de7e40c077e798135688fcea2be6e14de9ed600767b6c910.

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Full text

[PROPOSED] ORDER GRANTING MOTION TO DISMISS 
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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 
UNITED STATES DISTRICT COURT 
CENTRAL DISTRICT OF CALIFORNIA  
UNITED STATES OF AMERICA, 
            Plaintiff, 
v. 
RICHARD AYVAZYAN,  
et al., 
Defendants. 
Case No.  20-cr-579 (SVW)  
[PROPOSED] ORDER GRANTING 
MOTION TO DISMISS FOR 
PROSECUTORIAL MISCONDUCT  
Judge:             Hon. Stephen V. Wilson 
Hearing Date: May 24, 2021 
Time:              11:00 a.m. 
Case 2:20-cr-00579-SVW     Document 329-1     Filed 05/10/21     Page 1 of 2   Page ID
#:3351

 
 
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[PROPOSED] ORDER GRANTING MOTION TO DISMISS  
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[PROPOSED] ORDER 
 
This Court, having considered the Motion to Dismiss for Prosecutorial 
Misconduct and Memorandum in Support, filed by Defendant Richard Ayvazyan, 
hereby GRANTS the application and ORDERS the following relief: 
 
 
The indictment and superseding indictment are dismissed with prejudice. 
 
 
The government is ordered to produce discovery regarding its internal 
decision-making about whether and how to charge different individuals 
within fourteen days. 
 
 
The government is ordered to produce all grand jury exhibits and 
transcripts within seven days. 
 
 
The government is ordered to produce all grand jury subpoenas within 
seven days. 
 
 
The government is ordered to identify all trial exhibits and witness 
testimony that could have been affected or shaped by tainted evidence or 
otherwise derived from tainted evidence within seven days. 
 
 
IT IS SO ORDERED. 
 
  Dated:  ________, 2021  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
The Honorable Stephen V. Wilson 
 
 
 
 
 
 
United States District Judge 
Case 2:20-cr-00579-SVW     Document 329-1     Filed 05/10/21     Page 2 of 2   Page ID
#:3352

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File: gov.uscourts.cacd.813904.329.1.pdf
Size: 176,272 bytes
SHA-256: 8debbe6b6a6c9425de7e40c077e798135688fcea2be6e14de9ed600767b6c910
Our copy: gov.uscourts.cacd.813904.329.1.pdf
Original: PACER (login required)