GOVERNMENTS PROPOSED EXCERPTS OF THE FIRST SUPERSEDING INDICTMENT TO BE READ TO THE… — USA v. Ayvazyan et al (Dkt. 374)

Record facts

U.S. District Court for the Central District of California · No. 2:20-cr-00579-SVW · Doc. 374 · 2021-05-27 · Docket on CourtListener

Summary

The government's proposed excerpts of the First Superseding Indictment to be read to the jury in USA v. Ayvazyan et al, No. 2:20-cr-00579-SVW, in the U.S. District Court for the Central District of California, filed May 27, 2021 as Document 374. It is submitted under a Court order dated May 21, 2021 and draws on the First Superseding Indictment filed March 9, 2021 (ECF 154) against Richard Ayvazyan, Marietta Terabelian, Artur Ayvazyan, Tamara Dadyan, Manuk Grigoryan, Arman Hayrapetyan, Edvard Paronyan and Vahe Dadyan. The Count One excerpts under 18 U.S.C. § 1349 describe synthetic identities, the PPP and EIDL programs, the lenders and the bank accounts each defendant controlled, and allege a conspiracy from about March 2020 to August 2020 to commit wire fraud and bank fraud. Text of later counts and the forfeiture allegations is marked omitted.

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TRACY L. WILKISON 
Acting United States Attorney 
BRANDON D. FOX 
Assistant United States Attorney 
Chief, Criminal Division 
SCOTT PAETTY (Cal. Bar No. 274719) 
CATHERINE AHN (Cal. Bar No. 248286) 
BRIAN FAERSTEIN (Cal. Bar No. 274850) 
Assistant United States Attorneys 
Major Frauds/Environmental and Community Safety Crimes Sections 
1100/1300 United States Courthouse 
312 North Spring Street 
Los Angeles, California 90012 
Telephone: (213) 894-6527/2424/3819 
Facsimile: (213) 894-6269/0141 
E-mail: 
Scott.Paetty@usdoj.gov 
 
Catherine.S.Ahn@usdoj.gov 
 
Brian.Faerstein@usdoj.gov 
 
DANIEL S. KAHN 
Acting Chief, Fraud Section 
Criminal Division, U.S. Department of Justice 
CHRISTOPHER FENTON 
Trial Attorney, Fraud Section 
Criminal Division, U.S. Department of Justice 
1400 New York Avenue NW, 3rd Floor 
Washington, DC 20530 
Telephone: (202) 320-0539 
Facsimile: (202) 514-0152 
 
E-mail: 
Christopher.Fenton@usdoj.gov 
 
Attorneys for Plaintiff 
UNITED STATES OF AMERICA 
 
UNITED STATES DISTRICT COURT 
 
FOR THE CENTRAL DISTRICT OF CALIFORNIA 
 
UNITED STATES OF AMERICA, 
Plaintiff, 
v. 
RICHARD AYVAZYAN, 
aka “Richard Avazian” and 
    “Iuliia Zhadko,” 
MARIETTA TERABELIAN, 
  aka “Marietta Abelian” and     
      “Viktoria Kauichko,” 
ARTUR AYVAZYAN, 
aka “Arthur Ayvazyan,” and 
TAMARA DADYAN, 
MANUK GRIGORYAN, 
  aka “Mike Grigoryan,” and 
No. CR 20-579(A)-SVW 
GOVERNMENT’S PROPOSED EXCERPTS OF 
THE FIRST SUPERSEDING INDICTMENT 
TO BE READ TO THE JURY 
Case 2:20-cr-00579-SVW     Document 374     Filed 05/27/21     Page 1 of 19   Page ID
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      “Anton Kudiumov,” 
ARMAN HAYRAPETYAN, 
EDVARD PARONYAN, 
aka “Edvard Paronian” and 
    “Edward Paronyan,” and 
VAHE DADYAN, 
 
Defendants. 
 
Plaintiff the United States of America, by and through its 
counsel of record, the Acting United States Attorney for the Central 
District of California and Assistant United States Attorneys Scott 
Paetty, Catherine Ahn, and Brian Faerstein, and Department of Justice 
Trial Attorney Christopher Fenton, hereby submits its proposed 
excerpts of the indictment to be read to the jury in accordance with 
Court’s May 21, 2021 order (ECF 360).  These excerpts are from the 
First Superseding Indictment filed on March 9, 2021 (ECF 154).1   
Dated: May 27, 2021 
Respectfully submitted, 
 
TRACY L. WILKISON 
Acting United States Attorney 
 
BRANDON D. FOX 
Assistant United States Attorney 
Chief, Criminal Division 
 
 
      /s/ 
 
CATHERINE AHN 
SCOTT PAETTY 
BRIAN FAERSTEIN 
Assistant United States Attorney 
 
Attorneys for Plaintiff 
UNITED STATES OF AMERICA 
 
 
1 The government will be filing a proposed redacted indictment 
for use at trial; none of the proposed redactions affect any of the 
proposed excerpts.   
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PROPOSED EXCERPTS 
COUNT ONE 
[18 U.S.C. § 1349] 
[ALL DEFENDANTS] 
A. 
INTRODUCTORY ALLEGATIONS 
At times relevant to this First Superseding Indictment: 
1. 
Synthetic identities were false identities created using 
certain personally identifiable information, such as names, dates of 
birth, and social security numbers, that typically consisted of a 
combination of stolen and fictitious information.  Synthetic 
identities could be used to create false business names and entities.     
THE DEFENDANTS 
2. 
Defendant RICHARD AYVAZYAN, also known as (“aka”) “Richard 
Avazian” and “Iuliia Zhadko” (“R. AYVAZYAN”), was a resident of 
Encino, California.   
3. 
Defendant MARIETTA TERABELIAN, aka “Marietta Abelian” and 
“Viktoria Kauichko,” was a resident of Encino, California.  Defendant 
TERABELIAN and defendant R. AYVAZYAN were married.   
4. 
Defendant ARTUR AYVAZYAN, aka “Arthur Ayvazyan” 
(“A. AYVAZYAN”), was a resident of Encino, California.  Defendant A. 
AYVAZYAN and defendant R. AYVAZYAN were brothers.   
5. 
Defendant TAMARA DADYAN (“T. DADYAN”) was a resident of 
Encino, California.  Defendant T. DADYAN and defendant A. AYVAZYAN 
were married.   
6. 
Defendant MANUK GRIGORYAN, aka “Mike Grigoryan” and “Anton 
Kudiumov,” was a resident of Sun Valley, California. 
7. 
Defendant ARMAN HAYRAPETYAN was a resident of Glendale, 
California. 
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8. 
Defendant EDVARD PARONYAN, aka “Edvard Paronian” and 
“Edward Paronyan,” was a resident of Granada Hills, California. 
9. 
Defendant VAHE DADYAN (“V. DADYAN”) was a resident of 
Glendale, California.  
THE PAYCHECK PROTECTION PROGRAM 
10. 
The Coronavirus Aid, Relief, and Economic Security 
(“CARES”) Act was a federal law enacted in or about March 2020 that 
was designed to provide emergency financial assistance to Americans 
suffering economic harm as a result of the COVID-19 pandemic.  One 
form of assistance provided by the CARES Act was the authorization of 
United States taxpayer funds in forgivable loans to small businesses 
for job retention and certain other expenses, through a program 
referred to as the Paycheck Protection Program (“PPP”).  
11. 
In order to obtain a PPP loan, a qualifying business was 
required to submit a PPP loan application signed by an authorized 
representative of the business.  The PPP loan application required 
the small business (through its authorized representative) to 
acknowledge the program rules and make certain affirmative 
certifications in order to be eligible to obtain the PPP loan.  One 
such certification required the applicant to affirm that “[t]he [PPP 
loan] funds w[ould] be used to retain workers and maintain payroll or 
make mortgage interest payments, lease payments, and utility 
payments.”  The applicant (through its authorized representative) was 
also required to acknowledge that “I understand that if the funds are 
used for unauthorized purposes, the federal government may pursue 
criminal fraud charges.”  In the PPP loan application, the applicant 
was required to state, among other things, its: (a) average monthly 
payroll expenses; and (b) number of employees.  These figures were 
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used to calculate the amount of money the small business was eligible 
to receive under the PPP.  In addition, the applicant was required to 
provide documentation showing its payroll expenses.   
12. 
A business’s PPP loan application was received and 
processed, in the first instance, by a participating financial 
institution.  If a PPP loan application was approved, the 
participating financial institution would fund the PPP loan using its 
own monies.    
13. 
PPP loan proceeds were required to be used by the business 
on certain permissible expenses, namely, payroll costs, interest on 
mortgages, rent, and utilities.  The PPP allowed the interest and 
principal on the PPP loan to be entirely forgiven if the business 
spent the loan proceeds on these expenses within a designated period 
of time and used at least a minimum amount of the PPP loan proceeds 
towards payroll expenses. 
THE ECONOMIC INJURY DISASTER LOAN PROGRAM  
14. 
The Economic Injury Disaster Loan Program (“EIDL”) was a 
United States Small Business Administration (“SBA”) program that 
provided low-interest financing to small businesses, renters, and 
homeowners in regions affected by declared disasters. 
15. 
The CARES Act authorized the SBA to provide EIDL loans of 
up to $2 million to eligible small businesses experiencing 
substantial financial disruption due to the COVID-19 pandemic.   
16. 
To obtain an EIDL loan, a qualifying business was required 
to submit an application to the SBA and provide information about the 
business’s operations, such as the number of employees, gross 
revenues for the 12-month period preceding the disaster, and cost of 
goods sold in the 12-month period preceding the disaster.  In the 
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case of EIDL loans for COVID-19 relief, the 12-month period was the 
12-month period from January 31, 2019, to January 31, 2020.  The 
applicant was also required to certify that all of the information in 
the application was true and correct to the best of the applicant’s 
knowledge. 
17. 
EIDL loan applications were submitted directly to the SBA 
and processed by the agency with support from a government 
contractor.  The amount of the loan, if the application was approved, 
was determined based, in part, on the information provided by the 
applicant about employment, revenue, and cost of goods sold, as 
described in paragraph 15 above.  Any funds issued under an EIDL loan 
were issued directly by the SBA.   
18. 
EIDL loan funds could be used for payroll expenses, sick 
leave, production costs, and business obligations, such as debts, 
rent, and mortgage payments.  If the applicant also obtained a loan 
under the PPP, the EIDL loan funds could not be used for the same 
purpose as the PPP loan funds. 
RELEVANT LENDING INSTITUTIONS  
19. 
Lenders A, B, C, D, E, G, and H were financial institutions 
insured by the Federal Deposit Insurance Company (“FDIC”) that were 
approved SBA lenders of PPP loans.   
20. 
Lender F was a financial institution that was an approved 
SBA lender of PPP loans. 
BANK ACCOUNTS CONTROLLED BY THE DEFENDANTS 
21. 
Banks 1, 2, 3, 4, 5, 6, 7, and 8 were financial 
institutions insured by the FDIC.   
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22. 
Defendant R. AYVAZYAN controlled and/or was a signatory (in 
his legal name or using one of his aliases) on the following bank 
accounts: 
a. 
A business checking account at Bank 1 in the name of 
“Timeline Transport, Inc.” (the “Timeline Transport Bank 1 Account”); 
b. 
A business checking account at Bank 2 in the name of 
“Inception Ventures Inc.” (the “Inception Ventures Bank 2 Account”);  
c. 
A business checking account at Bank 3 in the name of 
“Iuliia Zhadko dba Top Quality Contracting” (the “TQC Bank 3 
Account”);  
d. 
A business checking account at Bank 7 in the name of 
“Mod Interiors, Inc.” (the “Mod Interiors Bank 7 Account”); 
e. 
A business checking account at Bank 5 in the name of 
“Turing Info Solutions Inc.” (the “Turing Info Bank 5 Account”); and 
f. 
A personal checking account at Bank 5 in the name of 
“Iuliia Zhadko” (the “Zhadko Bank 5 Account”). 
23. 
Defendant TERABELIAN controlled and/or was a signatory (in 
her legal name or using one of her aliases) on the following bank 
accounts: 
a. 
A personal checking account at Bank 2 in the name of 
defendant TERABELIAN (the “Terabelian Bank 2 Account”); 
b. 
A business checking account at Bank 2 in the name of 
“Runyan Tax Service Inc.” (the “Runyan Tax Bank 2 Account”); and 
c. 
The Mod Interiors Bank 7 Account. 
24. 
Defendant A. AYVAZYAN controlled and/or was a signatory (in 
his legal name or using his alias) on the following bank accounts: 
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a. 
A business checking account at Bank 2 in the name of 
“Allstate Towing and Transport LLC” (the “Allstate Towing Bank 2 
Account”);  
b. 
A business checking account at Bank 4 in the name of 
“Allstate Towing and Transport LLC” (the “Allstate Towing Bank 4 
Account”); and 
c. 
A personal checking account at Bank 8 in the name of 
A.D. (the “A.D. Bank 8 Account”). 
25. 
Defendant T. DADYAN controlled and/or was a signatory on 
the following bank accounts: 
a. 
A business checking account at Bank 3 in the name of  
“Secureline Realty and Funding, Inc.” (the “Secureline Realty Bank 3 
Account”); 
b. 
A business checking account at Bank 5 in the name of 
“ABC Realty Advisors, Inc.” (the “ABC Realty Bank 5 Account”);  
c. 
A business checking account at Bank 6 in the name of 
“Secureline Realty and Funding, Inc.” (the “Secureline Realty Bank 6 
Account”); and 
d. 
The A.D. Bank 8 Account. 
26. 
Defendant GRIGORYAN controlled and/or was a signatory (in 
his legal name or using one of his aliases) on the following bank 
accounts: 
a. 
A business checking account at Bank 4 in the name of 
“G&A Diamonds” (the “G&A Diamonds Bank 4 Account”); 
b. 
A business checking account at Bank 2 in the name of 
“Redline Auto Mechanics” (the “Redline Auto Mechanics Bank 2 
Account”); and 
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c. 
A personal checking account at Bank 2 in the name of 
“Anton Kudiumov” (the “Kudiumov Bank 2 Account”). 
27. 
Defendant HAYRAPETYAN controlled and/or was a signatory on 
the following bank accounts: 
a. 
A business checking account at Bank 5 in the name of 
“Arman Hayrapetyan DBA S. Construction” (the “S. Construction Bank 5 
Account”); 
b. 
A business checking account at Bank 5 in the name of 
“Arman Hayrapetyan DBA H. Construction Co.” with account number 
ending in 1511 (the “H. Construction 1511 Bank 5 Account”); 
c. 
A business checking account at Bank 5 in the name of 
“Arman Hayrapetyan DBA H. Construction Co.” with account number 
ending in 9066 (the “H. Construction 9066 Bank 5 Account”); and 
d. 
A personal checking account at Bank 5 in the name of 
defendant HAYRAPETYAN. 
28. 
Defendant PARONYAN controlled and was a signatory (in his 
legal name or using his alias) on the following bank accounts: 
a. 
A business checking account at Bank 5 in the name of 
“Redline Auto Collision, Inc.” (the “Redline Auto Collision Bank 5 
Account”); and 
b. 
A personal checking account at Bank 5 in the name of 
defendant PARONYAN (the “Paronyan Bank 5 Account”). 
29. 
Defendant V. DADYAN controlled and was a signatory on the 
following bank account: 
a. 
A business checking account at Bank 3 in the name of 
“Voyage Limo LLC” (the “Voyage Limo Bank 3 Account”). 
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B. 
THE OBJECTS OF THE CONSPIRACY 
30. 
Beginning no later than in or around March 2020 and 
continuing until at least in or around August 2020, in Los Angeles 
County, within the Central District of California, and elsewhere, 
defendants R. AYVAZYAN, TERABELIAN, A. AYVAZYAN, T. DADYAN, 
GRIGORYAN, HAYRAPETYAN, PARONYAN, and V. DADYAN conspired with one 
another and with others known and unknown to the Grand Jury to 
commit: (a) wire fraud, in violation of Title 18, United States Code, 
Section 1343; and (b) bank fraud, in violation of Title 18, United 
States Code, Section 1344(2). 
C. 
THE MANNER AND MEANS OF THE CONSPIRACY 
31. 
The objects of the conspiracy were to be carried out, and 
were carried out, in substance, as follows:   
a. 
Defendants R. AYVAZYAN, TERABELIAN, A. AYVAZYAN, T. 
DADYAN, GRIGORYAN, HAYRAPETYAN, PARONYAN, and V. DADYAN, together 
with other coconspirators, used and caused to be used, stolen, 
fictitious, and synthetic identities of individuals to submit 
fraudulent applications for PPP and EIDL loans.   
b. 
Defendants R. AYVAZYAN, TERABELIAN, A. AYVAZYAN, T. 
DADYAN, GRIGORYAN, HAYRAPETYAN, PARONYAN, and V. DADYAN, together 
with other coconspirators, used and caused to be used, stolen, 
fictitious, and synthetic business names to submit fraudulent 
applications for PPP and EIDL loans.   
c. 
Defendants R. AYVAZYAN, TERABELIAN, A. AYVAZYAN, T. 
DADYAN, GRIGORYAN, HAYRAPETYAN, PARONYAN, and V. DADYAN, together 
with other coconspirators, made and caused to be made, false 
statements to the SBA and financial institutions in connection with 
the fraudulent applications for PPP and EIDL loans, including false 
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representations regarding the number of employees to whom the 
companies had paid wages and false certifications that the loans 
would be used for permissible business purposes.   
d. 
Defendants R. AYVAZYAN, TERABELIAN, A. AYVAZYAN, T. 
DADYAN, GRIGORYAN, HAYRAPETYAN, PARONYAN, and V. DADYAN, together 
with other coconspirators, electronically submitted, and caused to be 
submitted, false documents to the SBA and financial institutions in 
support of the fraudulent PPP and EIDL loan applications, including 
false or fictitious tax documents, payroll records, bank records, and 
identification documents.  
e. 
Defendants R. AYVAZYAN, TERABELIAN, A. AYVAZYAN, T. 
DADYAN, GRIGORYAN, HAYRAPETYAN, PARONYAN, and V. DADYAN, together 
with other coconspirators, directed the other defendants and their 
coconspirators to deposit PPP and EIDL loan proceeds into bank 
accounts that defendants R. AYVAZYAN, TERABELIAN, A. AYVAZYAN, T. 
DADYAN, GRIGORYAN, HAYRAPETYAN, PARONYAN, and V. DADYAN, and their 
coconspirators controlled.   
f. 
Defendants R. AYVAZYAN, TERABELIAN, A. AYVAZYAN, T. 
DADYAN, GRIGORYAN, HAYRAPETYAN, PARONYAN, and V. DADYAN, together 
with other coconspirators, laundered and used the fraudulently 
obtained PPP and EIDL loan proceeds for their own personal benefit 
and for the benefit of their coconspirators, including for expenses 
prohibited under the requirements of the PPP and EIDL programs, such 
as the purchase of residential properties at Address 1 in Tarzana, 
California (“Residential Property 1”), Address 2 in Glendale, 
California (“Residential Property 2”), and Address 3 in Palm Desert, 
California (“Residential Property 3”), gold coins, diamonds, jewelry, 
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luxury watches, fine imported furnishings, designer handbags and 
clothing, cryptocurrency, and securities.  
32. 
[OMITTED] 
D. 
OVERT ACTS   
33. 
 On or about the [] dates [specified in the indictment], in 
furtherance of the conspiracy and to accomplish its objects, 
defendants R. AYVAZYAN, TERABELIAN, A. AYVAZYAN, T. DADYAN, 
GRIGORYAN, HAYRAPETYAN, PARONYAN, and V. DADYAN, together with other 
coconspirators, committed and willfully caused others to commit the 
overt act [specified in the indictment], among others, within the 
Central District of California. 
[OVERT ACTS OMITTED] 
 
 
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COUNTS TWO THROUGH TWELVE 
[18 U.S.C. §§ 1343, 2(a)] 
[ALL DEFENDANTS] 
34. 
[OMITTED] 
A. 
THE SCHEME TO DEFRAUD 
35. 
Beginning no later than in or around March 2020 and 
continuing until at least in or around August 2020, in Los Angeles 
County, within the Central District of California, and elsewhere, 
defendants R. AYVAZYAN, TERABELIAN, A. AYVAZYAN, T. DADYAN, 
GRIGORYAN, HAYRAPETYAN, PARONYAN, and V. DADYAN, together with others 
known and unknown to the Grand Jury, knowingly and with intent to 
defraud, devised, intended to devise, and participated in a scheme to 
defraud the SBA and financial institutions, and to obtain money and 
property by means of material false pretenses, representations, and 
promises, and the concealment of material facts. 
36. 
[OMITTED] 
B. 
USE OF THE WIRES 
37. 
On or about the dates set forth [in the indictment], in Los 
Angeles County, within the Central District of California, and 
elsewhere, for the purpose of executing the above-described scheme to 
defraud, defendants R. AYVAZYAN, TERABELIAN, A. AYVAZYAN, T. DADYAN, 
GRIGORYAN, HAYRAPETYAN, PARONYAN, and V. DADYAN, together with others 
known and unknown to the Grand Jury, aiding and abetting each other, 
transmitted and caused the transmission of the items [specified in 
counts two through twelve of the indictment] by means of wire and 
radio communication in interstate and foreign commerce: 
 
[COUNTS TWO - TWELVE OMITTED] 
 
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COUNTS THIRTEEN THROUGH TWENTY 
[18 U.S.C. §§ 1344(2), 2(a), 2(b)] 
[ALL DEFENDANTS] 
38. 
[OMITTED] 
A. 
[OMITTED]  
39. 
Beginning no later than in or around March 2020 and 
continuing until at least in or around August 2020, in Los Angeles 
County, within the Central District of California, and elsewhere, 
defendants R. AYVAZYAN, TERABELIAN, A. AYVAZYAN, T. DADYAN, 
GRIGORYAN, HAYRAPETYAN, PARONYAN, and V. DADYAN, together with others 
known and unknown to the Grand Jury, knowingly and with intent to 
defraud, devised, participated in, and executed a scheme to obtain 
moneys, funds, credits, assets, and other property owned by and in 
the custody and control of federally-insured financial institutions 
by means of material false and fraudulent pretenses, representations, 
and promises, and the concealment of material facts. 
B. 
[OMITTED] 
40. 
On or about the following dates, in Los Angeles County, 
within the Central District of California, and elsewhere, defendants 
R. AYVAZYAN, TERABELIAN, A. AYVAZYAN, T. DADYAN, GRIGORYAN, 
HAYRAPETYAN, PARONYAN, and V. DADYAN, together with others known and 
unknown to the Grand Jury, aiding and abetting each other, committed 
and willfully caused others to commit the  acts {specified in counts 
thirteen through twenty of the indictment], each of which constituted 
an execution of the fraudulent scheme: 
 
[COUNTS THIRTEEN - TWENTY OMITTED] 
 
 
 
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COUNT TWENTY-ONE 
[18 U.S.C. §§ 1028A(a)(1), 2(b)] 
[Defendant R. AYVAZYAN]  
41. 
[OMITTED] 
42. 
[OMITTED] 
COUNT TWENTY-TWO 
[18 U.S.C. §§ 1028A(a)(1), 2(a), 2(b)] 
[Defendants R. AYVAZYAN and TERABELIAN]  
43. 
[OMITTED] 
44. 
[OMITTED] 
COUNT TWENTY-THREE 
[18 U.S.C. §§ 1028A(a)(1), 2(b)] 
[Defendant GRIGORYAN]  
45. 
[OMITTED] 
46. 
[OMITTED] 
COUNT TWENTY-FOUR 
[18 U.S.C. §§ 1028A(a)(1), 2(a), 2(b)] 
[Defendants A. AYVAZYAN and T. DADYAN]  
47. 
[OMITTED] 
48. 
[OMITTED] 
COUNT TWENTY-FIVE 
[18 U.S.C. §§ 1028A(a)(1), 2(b)] 
[Defendant HAYRAPETYAN]  
49. 
[OMITTED] 
50. 
[OMITTED] 
 
 
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COUNT TWENTY-SIX 
[18 U.S.C. § 1956(h)] 
[ALL DEFENDANTS] 
51. 
[OMITTED] 
A. 
THE OBJECTS OF THE CONSPIRACY 
52. 
Beginning no later than in or around March 2020 and 
continuing until at least in or around October 2020, in Los Angeles 
County, within the Central District of California, and elsewhere, 
defendants R. AYVAZYAN, TERABELIAN, A. AYVAZYAN, T. DADYAN, 
GRIGORYAN, HAYRAPETYAN, PARONYAN, and V. DADYAN conspired with one 
another and with others known and unknown, to commit offenses against 
the United States in violation of Title 18, United States Code, 
Section 1956, to wit:  
a. 
to knowingly conduct and attempt to conduct a 
financial transaction involving the proceeds of specified unlawful 
activity, that is, wire fraud and bank fraud, knowing that the 
transaction was designed in whole and in part to conceal and disguise 
the nature, location, source, ownership, and control of the proceeds 
of specified unlawful activity, in violation of Title 18, United 
States Code, Section 1956(a)(1)(B)(i); and  
b. 
to knowingly engage and attempt to engage in monetary 
transactions in criminally derived property of a value greater than 
$10,000, such property having been derived from a specified unlawful 
activity, that is, bank and wire fraud, in violation of Title 18, 
United States Code, Section 1957. 
B. 
THE MANNER AND MEANS OF THE CONSPIRACY 
53. 
The objects of the conspiracy were carried out, and to be 
carried out, as follows: 
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a. 
Defendants R. AYVAZYAN, TERABELIAN, A. AYVAZYAN, T. 
DADYAN, GRIGORYAN, HAYRAPETYAN, PARONYAN, and V. DADYAN, together 
with other coconspirators, submitted and caused the submission of 
fraudulent PPP and EIDL loan applications, which caused the SBA and 
SBA-approved lenders, including lenders who were federally-insured 
financial institutions, to wire loan proceeds to bank accounts in the 
names of the entities used to obtain such loans. 
b. 
Defendants R. AYVAZYAN, TERABELIAN, A. AYVAZYAN, T. 
DADYAN, GRIGORYAN, HAYRAPETYAN, PARONYAN, and V. DADYAN, together 
with other conspirators, transferred and caused the transfer of the 
loan proceeds, including in financial transactions of $10,000 or 
greater, to secondary accounts under their control, including in the 
names of fictitious identities, and in order to conceal the true 
nature, location, source, ownership, and control of the funds. 
c. 
Defendants R. AYVAZYAN, TERABELIAN, A. AYVAZYAN, T. 
DADYAN, GRIGORYAN, HAYRAPETYAN, PARONYAN, and V. DADYAN, together 
with other conspirators, spent the PPP and EIDL fraud proceeds for 
their own personal benefit and for the benefit of their 
coconspirators, including for expenses prohibited under the 
requirements of the PPP and EIDL programs, such as the purchase of 
Residential Property 1, Residential Property 2, and Residential 
Property 3, gold coins, diamonds, jewelry, luxury watches, fine 
imported furnishings, designer handbags and clothing, cryptocurrency, 
and securities. 
C. 
[OMITTED] 
54. 
[OMITTED] 
 
 
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COUNT TWENTY-SEVEN 
[18 U.S.C. §§ 1956(a)(1)(B)(i), 2(b)] 
[Defendant V. DADYAN] 
55. 
[OMITTED] 
[OMITTED] 
56. 
[OMITTED] 
 
 
COUNTS TWENTY-EIGHT THROUGH THIRTY-TWO 
[18 U.S.C. §§ 1956(a)(1)(B)(i), 2(b), 3147] 
 [Defendant R. AYVAZYAN] 
57. 
[OMITTED] 
A. 
[OMITTED] 
58. 
[OMITTED] 
 
COUNT 
DATE 
TRANSACTION 
 
[COUNTS TWENTY-EIGHT – THIRTY-TWO OMITTED] 
 
 
B. 
[OMITTED] 
59. 
[OMITTED] 
 
 
 
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COUNT THIRTY-THREE 
[18 U.S.C. §§ 1344(2), 2(a), 2(b), 3147] 
 [Defendant T. DADYAN] 
60. 
[OMITTED] 
A. 
[OMITTED] 
61. 
[OMITTED] 
62. 
[OMITTED] 
a. 
[OMITTED] 
b. 
[OMITTED] 
c. 
[OMITTED] 
B. 
[OMITTED] 
63. 
[OMITTED] 
C. 
[OMITTED] 
64. 
[OMITTED] 
 
 
 
[FORFEITURE ALLEGATIONS ONE THROUGH FIVE OMITTED] 
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