Declaration of Catherine Ahn — USA v. Ayvazyan et al (Dkt. 384.1)

Summary

Assistant United States Attorney Catherine Ahn declares, in support of the government's Motion in Limine #2 to Admit Evidence Inextricably Intertwined with the Charged Offenses, how the motion's exhibits were obtained in United States v. Ayvazyan, et. al, CR No. 20-579(A)-SVW (C.D. Cal.), Document 384-1, filed 05/31/21. She states that the text messages quoted in the motion came from an Apple iPhone tied to T. Dadyan, seized on or about November 5, 2020 from SUBJECT PREMISES-4, and that a forensic copy was produced to the defendants. Exhibit 1 is photographs of checks from SUBJECT PREMISES-5, Exhibit 2 is handwritten notes from SUBJECT PREMISES-2, and Exhibits 3 and 4 are files attached to text messages from July 2020. The declaration was executed at Los Angeles on May 31, 2021.

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DECLARATION OF CATHERINE AHN 
 
I, Catherine Ahn, declare and state as follows: 
1. 
I am an Assistant United States Attorney for the Central 
District of California and am assigned to the prosecution of United 
States v. Ayvazyan, et. al, CR No. 20-579(A)-SVW.  I make this 
declaration in support of the Government’s Motion in Limine #2 to 
Admit Evidence Inextricably Intertwined with the Charged Offenses. 
2. 
The “T.D. iPhone Text Excerpts” included in the above-
referenced motion are true and correct copies of excerpts of text 
messages extracted from an Apple iPhone X bearing serial number 
DNQW1LPFJCLJ and an Apple ID including T. Dadyan’s name, logged as 
evidence item 1B21 (the “T.D. iPhone”).  This digital device was 
seized on or about November 5, 2020 from SUBJECT PREMISES-4.  The text 
messages are, as indicated, excerpts of the participants’ 
conversation.  The text messages were exchanged between participants 
identified within the digital device as: “Rich New” with a phone 
number ending in -4170, “tammy (owner)” with a phone number ending in 
-5533, and an email address bearing T. Dadyan’s name also identified 
as “(owner)”.  A forensic copy of this digital device and a 
searchable report of its readable contents, post-filter review, were 
produced to defendants with Bates no. DOJ_PROD_0000160626.   
3. 
Exhibit 1 is a true and correct copy of photographs of 
checks taken on or about November 5, 2020, at SUBJECT PREMISES-5.  
Copies of these images were previously produced to defense with Bates 
no. DOJ_PROD_0000022702 and DOJ_PROD_0000022704.   
4. 
Exhibit 2 is a true and correct copy of the front and back 
of a paper containing handwritten notes found on or about November 5, 
2020, at SUBJECT PREMISES-2.  Copies of these notes were previously 
Case 2:20-cr-00579-SVW     Document 384-1     Filed 05/31/21     Page 1 of 2   Page ID
#:4015

 
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produced to defense with Bates no. DOJ_PROD_0000023682 and 
DOJ_PROD_0000023683. 
5. 
Exhibit 3 is a true and correct copy of a file attached to 
text message 3976 extracted from the T.D. iPhone, sent from 
“+18184145533 tammy” on or about July 28, 2020 Coordinated Universal 
Time (“UTC”), titled “LK Design Employee Report -Clean.pdf.”  
6. 
Exhibit 4 contains four pages, each of which are a true and 
correct copy of a file attached to text messages extracted from the 
T.D. iPhone, sent from “+18184145533 tammy.”  Exhibit 4 page 1 is a 
true and correct copy of a file attached to text message 3504, sent 
on or about July 3, 2020 UTC, titled “IMG_5861.jpg.”  Exhibit 4 page 
2 is a true and correct copy of a file attached to text message 3510, 
sent on or about July 3, 2020 UTC, titled “IMG_2124.jpeg.”  Exhibit 4 
page 3 is a true and correct copy of a file attached to text message 
3645, sent on or about July 10, 2020 UTC, titled “IMG_6512.jpg.”   
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 31, 
2021. 
 
 
 
CATHERINE AHN 
 
Case 2:20-cr-00579-SVW     Document 384-1     Filed 05/31/21     Page 2 of 2   Page ID
#:4016

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