JOINDER in NOTICE OF MOTION AND MOTION for Order for to Hold a Kastigar Hearing, to… — USA v. Ayvazyan et al (Dkt. 348)

Summary

Defendant Edvard Paronyan, through counsel Michael G. Freedman, joins the motion of R. Ayvazyan and M. Terabelian (Dkt. 338) for a Kastigar hearing to disqualify the prosecution team and dismiss the case, in No. 20-CR-579(A)-SVW (C.D. Cal.), Document 348, filed 05/19/21. His supplemental memorandum notes that he was charged only in the First Superseding Indictment in March 2021, which he says supports an inference that the prosecution team used tainted information to build its case against him. He also joins Defendant Grigoryan's joinder (Dkt. 346). He asks the Court to order those who possessed, reviewed or discussed the allegedly illegally obtained evidence to testify, and to order disclosure of the grand jury transcripts and the trial exhibits before the hearing.

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EDVARD PARONYAN’S JOINDER IN MOTION FOR KASTIGAR HEARING 
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Michael G. Freedman (State Bar No. 281279) 
THE FREEDMAN FIRM PC 
800 Wilshire Blvd., Suite 1050 
Los Angeles, California  90017 
Telephone: (213) 816-1700 
Facsimile: (213) 816-1706 
Email: Michael@thefreedmanfirm.com 
 
Attorney for Defendant Edvard Paronyan 
 
 
 
 
 
UNITED STATES DISTRICT COURT 
 
CENTRAL DISTRICT OF CALIFORNIA 
 
 
 
UNITED STATES OF AMERICA, 
Plaintiff, 
vs. 
EDVARD PARONYAN, 
Defendant. 
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Case No.: 20-CR-579(A)-SVW 
DEFENDANT EDVARD 
PARONYAN’S JOINDER IN 
DEFENDANT R. AYVAZYAN’S 
AND M. TERABELIAN’S MOTION 
FOR A KASTIGAR HEARING TO 
DISQUALIFY THE 
PROSECUTION TEAM (DKT. 338) 
AND SUPPLEMENTAL 
MEMORANDUM 
 
 
Defendant Edvard Paronyan, by and through his counsel of record, Michael 
G. Freedman, hereby joins in Defendant R. Ayvazyan’s and M. Terabelian’s 
Motion for Kastigar Hearing to Disqualify the Prosecution Team and Dismiss the 
Case (Dkt.  338) and provides the attached supplemental memorandum in support 
of his joinder.   
 
Dated: May 19, 2021 
 
 
 
Respectfully submitted, 
 
 
 
 
 
 
 
 
 
 
By: 
/s/ Michael G. Freedman 
 
 
 
 
 
 
 
 
Michael G. Freedman 
 
 
 
 
 
 
 
 
Attorney for Defendant 
 
 
 
 
 
 
 
 
Edvard Paronyan 
Case 2:20-cr-00579-SVW     Document 348     Filed 05/19/21     Page 1 of 2   Page ID
#:3520

 
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EDVARD PARONYAN’S JOINDER IN MOTION FOR KASTIGAR HEARING 
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SUPPLEMENTAL MEMORANDUM 
 
Mr.  Paronyan was not charged in the original complaint or initial indictment 
in this case. (Dkt. 1 & 32).  Rather, Mr. Paronyan was charged in the First 
Superseding Indictment in March 2021.  This timing gives rise to an inference that 
the prosecution team used tainted information to build its case against Mr. 
Paronyan and in its decision to prosecute him.  Accordingly, Mr. Paronyan joins in 
Defendant R. Ayvazyan’s and M. Terabelian’s Motion for Kastigar Hearing to 
Disqualify the Prosecution Team and Dismiss the Case (Dkt. 338) as well as 
Defendant Grigoryan’s Joinder in that motion (Dkt. 346).   
 
Mr. Paronyan respectfully requests that the Court: (1) order all individuals 
who possessed, reviewed, or discussed the illegally-obtained evidence to provide 
testimony in this matter; (2) order the government to disclose the grand jury 
transcripts to the defense in advance of the hearing as well; and (3) order that the 
government disclose its trial exhibits in advance of the hearing.  
  
Dated: May 19, 2021 
 
 
 
Respectfully submitted, 
 
 
 
 
 
 
 
 
 
 
By: 
/s/ Michael G. Freedman 
 
 
 
 
 
 
 
 
Michael G. Freedman 
 
 
 
 
 
 
 
 
Attorney for Defendant 
 
 
 
 
 
 
 
 
Edvard Paronyan 
Case 2:20-cr-00579-SVW     Document 348     Filed 05/19/21     Page 2 of 2   Page ID
#:3521

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