Declaration of Ashwin J. Ram in Support — USA v. Ayvazyan et al (Dkt. 329.2)

Summary

A Declaration of Ashwin J. Ram in Support of Defendant Richard Ayvazyan's Reply in Support of Motion to Dismiss for Prosecutorial Misconduct, Document 329-2 filed 05/10/21 in United States of America v. Richard Ayvazyan, et al., Case No. 20-cr-579 (SVW), in the Central District of California. Mr. Ram states that he is a partner at the law firm of Steptoe & Johnson LLP and counsel of record for defendant Richard Ayvazyan. He attaches as Exhibit A a May 7, 2021 letter from defense counsel to the government regarding the government's discovery obligations, and as Exhibit B a May 7, 2021 letter seeking discovery on evidence tainted by coerced statements. The declaration is executed on May 10, 2021, and the caption lists Judge Stephen V. Wilson and a May 24, 2021 date.

Summary drafted by a model from the document's text below and checked by script against that text before publication. It is a navigation aid, not a reading of what the document proves. Where AI is used

Record facts

Full text

DECLARATION OF A. RAM IN SUPPORT OF REPLY – MOTION TO DISMISS 
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
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) 
 
DECLARATION OF ASHWIN J. 
RAM IN SUPPORT OF 
DEFENDANT RICHARD 
AYVAZYAN’S REPLY IN 
SUPPORT OF MOTION TO 
DISMISS FOR PROSECUTORIAL 
MISCONDUCT 
 
Judge:   Hon. Stephen V. Wilson 
Date:     May 24, 2021 
Time:    11:00 a.m. 
 
 
 
Case 2:20-cr-00579-SVW     Document 329-2     Filed 05/10/21     Page 1 of 2   Page ID
#:3353

 
 
1 
DECLARATION OF A. RAM IN SUPPORT OF REPLY – MOTION TO DISMISS 
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
 
I, Ashwin J. Ram, declare as follows: 
1. 
I am an attorney licensed to practice law in the state of California.  I am a 
partner at the law firm of Steptoe & Johnson LLP and counsel of record for defendant 
Richard Ayvazyan in the above-captioned matter. 
2. 
A true and correct copy of the May 7, 2021 letter from counsel for 
Defendant Richard Ayvazyan to the government regarding the government’s discovery 
obligations is attached as Exhibit A.  
3. 
A true and correct copy of the May 7, 2021 letter from counsel for 
Defendant Richard Ayvazyan to the government seeking discovery on evidence tainted 
by coerced statements is attached as Exhibit B. 
I declare under penalty of perjury that the foregoing is true and correct. 
Executed at Los Angeles, California on May 10, 2021. 
 
 
 
 
 
 
 
 
Respectfully submitted, 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
/s/ Ashwin J. Ram  
 
 
 
 
 
 
 
 
 
Ashwin J. Ram  
 
 
 
 
Counsel for Defendant Richard Ayvazyan 
 
 
Case 2:20-cr-00579-SVW     Document 329-2     Filed 05/10/21     Page 2 of 2   Page ID
#:3354

File and source

File

gov.uscourts.cacd.813904.329.2.pdf

Size

136,907 bytes

SHA-256

88533edfe7659e82ee6f5a431eed1d5f0c81512d8f94647e64c3a6fceb16e45e

Our copy

gov.uscourts.cacd.813904.329.2.pdf

Original

PACER (login required)