Declaration Catherine Ahn — USA v. Ayvazyan et al (Dkt. 358.1)

Summary

A Declaration of Catherine Ahn, an Assistant United States Attorney, Document 358-1, filed 05/24/21 in Case 2:20-cr-00579-SVW in the United States District Court, Central District of California. The declaration states that it supports the government's motion in limine #1 to exclude evidence and argument of alleged victim negligence and guarantees. It states that the government emailed counsel for all defendants on May 22, 2021 about their position, that counsel for defendant Richard Ayvazyan declined to take a position on May 23, 2021, and that counsel for the remaining defendants had not responded. It is executed May 24, 2021 over the typed name CATHERINE AHN.

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DECLARATION OF CATHERINE AHN 
I, Catherine Ahn, declare as follows: 
1. 
I am an Assistant United States Attorney in the United 
States Attorney’s Office for the Central District of California.  I 
am one of the attorneys representing the government in this case.  I 
make this declaration in support of the government’s motion in limine 
#1 to exclude evidence and argument of alleged victim negligence and 
guarantees (“the motion”).  
2. 
On May 22, 2021, the government emailed counsel for all 
defendants requesting their position on whether they would seek to 
introduce evidence of victim negligence or third-party guarantees.  
On May 23, 2021, counsel for defendant Richard Ayvazyan declined to 
take a position as to whether it would seek to introduce evidence of 
victim negligence or guarantees, but also did not offer any grounds 
for seeking to introduce it.  As of the date of this filing, counsel 
for the remaining defendants have not responded.  
I declare under penalty of perjury under the laws of the United 
States of America that the foregoing is true and correct and that 
this declaration is executed at Los Angeles, California, on May 24, 
2021. 
 
 
 
 
 
 
 
 
 
 
CATHERINE AHN 
Case 2:20-cr-00579-SVW     Document 358-1     Filed 05/24/21     Page 1 of 1   Page ID
#:3662

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gov.uscourts.cacd.813904.358.1.pdf

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