JOINDER in NOTICE OF MOTION AND MOTION for Order for to Hold a Kastigar Hearing, to… — USA v. Ayvazyan et al (Dkt. 347)

Summary

Filed May 19, 2021 as Document 347 in Case 2:20-cr-00579-SVW (C.D. Cal.), this is Defendant Vahe Dadyan's joinder, through counsel Peter Johnson, in the motion of Defendants R. Ayvazyan and M. Terabelian for a Kastigar hearing to disqualify the prosecution team and dismiss the case [Doc. # 338]. His supplemental memorandum says he was not named in the original complaint or indictment and argues the timing of the First Superseding Indictment gives rise to an inference that the prosecution used tainted information. He also joins co-defendant Grigoryan's joinder [Doc. #346]. He asks the Court to require persons who handled the information to testify, and to order the government to produce grand jury transcripts and disclose its trial exhibits before the hearing.

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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 AND M. 
TERABELIAN’S MOTION FOR 
A KASTIGAR HEARING TO 
DISQUALIFY THE 
PROSECUTION TEAM, AND 
TO DISMISS [Doc. # 338]; 
SUPPLMENTAL 
MEMORANDUM  
 
 
 
 
 
Defendant Vahe Dadyan, through his counsel, Peter Johnson, hereby joins in 
Defendant R. Ayvazyan’s and M. Terabelian’s Motion for Kastigar Hearing to Disqualify 
the Prosecution Team and Dismiss the Case [Doc. # 338].    
 
DATED: May 19, 2021   
         Respectfully submitted, 
                
       
       
       
       
By: ___________/s/________________ 
       
       
       
       
       
       
PETER JOHNSON 
       
       
       
       
       
       
Attorney for Defendant Vahe Dadyan 
 
Case 2:20-cr-00579-SVW     Document 347     Filed 05/19/21     Page 1 of 3   Page ID
#:3517

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SUPPLEMENTAL MEORANDUM  
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 was not named in the original 
complaint or indictment. [Doc.# 1 and Doc.#32].  Because the timing of the FSI alone 
gives rise to an inference that the prosecution team used tainted information to further 
its case against Mr. Dadyan, Mr. Dadyan joins in Defendant R. Ayvazyan’s and M. 
Terabelian’s Motion for Kastigar Hearing to Disqualify the Prosecution Team and 
Dismiss the Case. [Doc. # 338].     
Mr. Dadyan also joins in co-defendant Grigoryan’s joinder [Doc. #346] and 
respectfully requests that the Court order the following: 
1) any person who possessed, reviewed, or discussed the tainted information at 
any time be required to testify and demonstrate that the taint did not affect 
their actions or decision-making process in any manner;  
2) to ensure that the grand jury was completely unaffected by the evidence at 
issue, the government must produce all the grand jury transcripts to the 
defense in advance of the hearing; and 
3) to ensure that its trial presentation will be completely unaffected by the  
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Case 2:20-cr-00579-SVW     Document 347     Filed 05/19/21     Page 2 of 3   Page ID
#:3518

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evidence at issue, the government must disclose its trial exhibits in advance 
of the hearing. 
 
DATED: May 19, 2021   
         Respectfully submitted, 
   
       
       
       
       
       
       
By: ___________/s/________________ 
       
       
       
       
       
       
PETER JOHNSON 
       
       
       
       
       
       
Attorneys for Defendant Vahe Dadyan 
  
 
Case 2:20-cr-00579-SVW     Document 347     Filed 05/19/21     Page 3 of 3   Page ID
#:3519

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