Court filing
Exhibit — USA v. Ayvazyan et al (Dkt. 422.3)
Record facts
| Court | U.S. District Court for the Central District of California |
|---|---|
| Filed | 2021-06-04 |
U.S. District Court for the Central District of California · No. 2:20-cr-00579-SVW · Doc. 422-3 · 2021-06-04 · Docket on CourtListener
Summary
Doc. 422-3 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 June 4, 2021, is Exhibit B: the First Superseding Indictment returned by the October 2020 Grand Jury. It names as defendants Richard Ayvazyan, Marietta Terabelian, Artur Ayvazyan, Tamara Dadyan, Manuk Grigoryan, Arman Hayrapetyan, Edvard Paronyan and Vahe Dadyan, and lists charges including 18 U.S.C. § 1349 conspiracy, wire fraud, bank fraud, aggravated identity theft and money laundering. Count One alleges that from March 2020 to August 2020 the defendants used stolen, fictitious and synthetic identities and business names to submit applications for PPP and EIDL loans. The introductory allegations describe both programs and list bank accounts each defendant allegedly controlled. The 59-page indictment ends with forfeiture allegations.
Summary drafted by a model from the document's text below and checked by script against that text before publication. It is a navigation aid, not a reading of what the document proves. Where AI is used
Full text
EXHIBIT B
Case 2:20-cr-00579-SVW Document 422-3 Filed 06/04/21 Page 1 of 59 Page ID
#:4628
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
UNITED STATES DISTRICT COURT
FOR THE CENTRAL DISTRICT OF CALIFORNIA
October 2020 Grand Jury
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,”
TAMARA DADYAN,
MANUK GRIGORYAN,
aka “Mike Grigoryan,” and
“Anton Kudiumov,”
ARMAN HAYRAPETYAN,
EDVARD PARONYAN,
aka “Edvard Paronian” and
“Edward Paronyan,” and
VAHE DADYAN,
Defendants.
CR No. 20-00579(A)-SVW
F I R S T
S U P E R S E D I N G
I N D I C T M E N T
[18 U.S.C. § 1349: Conspiracy to
Commit Bank Fraud and Wire Fraud;
18 U.S.C. § 1343: Wire Fraud; 18
U.S.C. § 1344(2): Bank Fraud and
Attempted Bank Fraud; 18 U.S.C.
§ 1028A(a)(1): Aggravated Identity
Theft; 18 U.S.C. § 1956(h): Money
Laundering Conspiracy; 18 U.S.C.
§ 1956(a)(1)(B)(i): Money
Laundering; 18 U.S.C. § 3147:
Offense Committed While on
Release; 18 U.S.C. §§ 981, 982,
1028 and 28 U.S.C. § 2461(c):
Criminal Forfeiture]
Case 2:20-cr-00579-SVW Document 422-3 Filed 06/04/21 Page 2 of 59 Page ID
#:4629
2
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
The Grand Jury charges:
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.
Case 2:20-cr-00579-SVW Document 422-3 Filed 06/04/21 Page 3 of 59 Page ID
#:4630
3
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
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
Case 2:20-cr-00579-SVW Document 422-3 Filed 06/04/21 Page 4 of 59 Page ID
#:4631
4
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
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
Case 2:20-cr-00579-SVW Document 422-3 Filed 06/04/21 Page 5 of 59 Page ID
#:4632
5
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
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.
Case 2:20-cr-00579-SVW Document 422-3 Filed 06/04/21 Page 6 of 59 Page ID
#:4633
6
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
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:
Case 2:20-cr-00579-SVW Document 422-3 Filed 06/04/21 Page 7 of 59 Page ID
#:4634
7
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
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
Case 2:20-cr-00579-SVW Document 422-3 Filed 06/04/21 Page 8 of 59 Page ID
#:4635
8
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
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”).
Case 2:20-cr-00579-SVW Document 422-3 Filed 06/04/21 Page 9 of 59 Page ID
#:4636
9
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
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
Case 2:20-cr-00579-SVW Document 422-3 Filed 06/04/21 Page 10 of 59 Page ID
#:4637
10
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
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,
Case 2:20-cr-00579-SVW Document 422-3 Filed 06/04/21 Page 11 of 59 Page ID
#:4638
11
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
luxury watches, fine imported furnishings, designer handbags and
clothing, cryptocurrency, and securities.
32.
As part of the conspiracy, between in or around March 2020
and in or around August 2020, defendants R. AYVAZYAN, TERABELIAN,
A. AYVAZYAN, T. DADYAN, GRIGORYAN, HAYRAPETYAN, PARONYAN, and V.
DADYAN, together with other coconspirators, submitted and caused the
submission of at least 151 fraudulent PPP and EIDL loan applications
seeking a total of at least $21.9 million in PPP and EIDL proceeds
from the SBA and at least 11 financial institutions, and received a
total of at least $18 million in PPP and EIDL loan proceeds from the
SBA and financial institutions.
D.
OVERT ACTS
33.
On or about the following dates, 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 following overt acts, among
others, within the Central District of California:
S. Construction and H. Construction PPP Loans
Overt Act No. 1:
On or about April 16, 2020, defendant
HAYRAPETYAN, together with other coconspirators, used the name and
social security number of D.S., a real person, to submit and cause to
be submitted to Lender H an application in the name of S.
Construction, seeking a PPP loan in the amount of $182,637, which
application: (a) falsely represented that S. Construction had 16
employees and an average monthly payroll of $73,055; and (b) falsely
certified that the purported applicant, D.S., would use the loan
proceeds only for permissible business purposes.
Case 2:20-cr-00579-SVW Document 422-3 Filed 06/04/21 Page 12 of 59 Page ID
#:4639
12
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
Overt Act No. 2:
On or about April 18, 2020, defendant
HAYRAPETYAN together with other coconspirators, used the name and
social security number of M.H., a real person, to submit and cause to
be submitted to Lender H an application in the name of H.
Construction, seeking a PPP loan in the amount of $130,000, which
application: (a) falsely represented that H. Construction had 12
employees and an average monthly payroll of $52,000; and (b) falsely
certified that the purported applicant, M.H., would use the loan
proceeds only for permissible business purposes.
Overt Act No. 3:
On or about May 1, 2020, defendant
HAYRAPETYAN, together with other coconspirators, caused Lender H to
wire approximately $182,637 in proceeds from the S. Construction PPP
loan to the S. Construction Bank 5 Account.
Overt Act No. 4:
On or about May 1, 2020, defendant
HAYRAPETYAN caused Lender H to wire approximately $130,000 in
proceeds from the H. Construction PPP loan to the H. Construction
1511 Bank 5 Account.
Overt Act No. 5:
On or about May 4, 2020, defendant
HAYRAPETYAN, together with other coconspirators, caused approximately
$250,000, comprised in part of the S. Construction PPP loan proceeds,
to be wired from the S. Construction Bank 5 Account to the H.
Construction 9066 Bank 5 Account.
Overt Act No. 6:
On or about May 4, 2020, defendant
HAYRAPETYAN, together with other coconspirators, caused approximately
$200,000, comprised in part of the H. Construction PPP loan proceeds,
to be wired from the H. Construction 1511 Bank 5 Account to the H.
Construction 9066 Bank 5 Account.
Case 2:20-cr-00579-SVW Document 422-3 Filed 06/04/21 Page 13 of 59 Page ID
#:4640
13
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
Overt Act No. 7:
On or about May 4, 2020, defendant
HAYRAPETYAN, together with other coconspirators, caused a check for
approximately $50,000, drawn on the H. Construction 9066 Bank 5
Account and comprised in substantial part of the PPP loan proceeds
for S. Construction and H. Construction, to be written to the order
of Fiber One Media, which check was endorsed on the back with the
name of defendant TERABELIAN’s alias “Viktoria Kauichko.”
Secureline Realty PPP Loans
Overt Act No. 8:
On or about April 22, 2020, defendant T.
DADYAN, together with other coconspirators, submitted and caused to
be submitted to Lender D an application in the name of Secureline
Realty and Funding, Inc. (“Secureline Realty”) seeking a PPP loan in
the amount of $122,838, which application: (a) falsely represented
that Secureline Realty had eight employees, including employees for
whom it had paid wages and payroll taxes; and (b) falsely certified
Secureline Realty would use the loan proceeds only for permissible
business purposes.
Overt Act No. 9:
On or about April 22, 2020, defendant T.
DADYAN, together with other coconspirators, submitted and caused to
be submitted to Lender D false documents, including fake Internal
Revenue Service (“IRS”) Forms 940 and 941, in support of the
Secureline Realty PPP loan application.
Overt Act No. 10:
On or about May 7, 2020, defendant T.
DADYAN, together with other coconspirators, caused Lender D to wire
approximately $122,838 in proceeds from the Secureline Realty PPP
loan to the Secureline Realty Bank 3 Account.
Overt Act No. 11:
On or about May 9, 2020, defendant T.
DADYAN, together with other coconspirators, submitted and caused to
Case 2:20-cr-00579-SVW Document 422-3 Filed 06/04/21 Page 14 of 59 Page ID
#:4641
14
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
be submitted to Lender E an application in the name of Secureline
Realty seeking a PPP loan in the amount of $137,500, which
application: (a) falsely represented that Secureline Realty had eight
employees, including employees for whom it had paid wages and payroll
taxes; and (b) falsely certified Secureline Realty would use the loan
proceeds only for permissible business purposes.
Overt Act No. 12:
On or about May 11, 2020, defendant T.
DADYAN, together with other coconspirators, caused Lender E to wire
approximately $137,500 in proceeds from the Secureline Realty PPP
loan to the Secureline Realty Bank 6 Account.
Overt Act No. 13:
On or about May 27, 2020, defendant T.
DADYAN, together with other coconspirators, caused a check for
approximately $136,000, drawn on Secureline Realty Bank 6 Account and
comprised in substantial part of the PPP loan proceeds for Secureline
Realty, to be deposited into the ABC Realty Bank 5 Account.
Overt Act No. 14:
On or about June 12, 2020, defendant T.
DADYAN, together with other coconspirators, caused approximately
$120,010, which in substantial part came from the PPP loan proceeds
for Secureline Realty, to be withdrawn from the Secureline Realty
Bank 3 Account and subsequently caused approximately $120,000 to be
deposited to the ABC Realty Bank 5 Account.
Overt Act No. 15:
On or about June 17, 2020, defendant T.
DADYAN, together with other coconspirators, caused approximately
$200,000 to be wired from the ABC Realty Bank 5 Account to the
Inception Ventures Bank 2 Account, for which defendant R. AYVAZYAN
was the sole signatory.
Overt Act No. 16:
On or about June 22, 2020, defendant
R. AYVAZYAN, together with other coconspirators, caused approximately
Case 2:20-cr-00579-SVW Document 422-3 Filed 06/04/21 Page 15 of 59 Page ID
#:4642
15
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
$435,000, which in part came from the approximately $200,000 in PPP
loan funds defendant R. AYVAZYAN received from defendant T. DADYAN,
to be wired from the Inception Ventures Bank 2 Account to Escrow
Company 1 to be used to as part of the $3,250,000 purchase price for
Residential Property 1, which was purchased in the names of
defendants R. AYVAZYAN and TERABELIAN.
Top Quality Contracting PPP Loan
Overt Act No. 17:
On or about April 30, 2020, defendant
R. AYVAZYAN, together with other coconspirators, used the name of
M.Z., a real person, to submit and cause to be submitted to Lender B
an application in the name of Top Quality Contracting (“TQC”),
seeking a PPP loan in the amount of $130,000.
Overt Act No. 18:
On or about April 30, 2020, in connection
with the TQC PPP loan application, defendant R. AYVAZYAN, together
with other coconspirators, submitted and caused to be submitted to
Lender B a fake copy of M.Z.’s California driver’s license and a fake
IRS Form 940 purportedly prepared and filed by M.Z.
Overt Act No. 19:
On or about May 8, 2020, defendant
R. AYZAYAN, together with other coconspirators, caused Lender B to
wire approximately $130,000 in proceeds from the TQC PPP loan to the
TQC Bank 3 Account, which listed defendant R. AYVAZYAN’s alias
“Iuliia Zhadko” and M.Z. as the only signatories.
Allstate Towing PPP Loan
Overt Act No. 20:
On or about May 2, 2020, defendant
A. AYVAZYAN, together with other coconspirators, submitted and caused
to be submitted to Lender C an application in the name of Allstate
Towing and Transport LLC (“Allstate Towing”) seeking a PPP loan in
the amount of $124,000, which application: (a) falsely represented
Case 2:20-cr-00579-SVW Document 422-3 Filed 06/04/21 Page 16 of 59 Page ID
#:4643
16
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
that Allstate Towing had 11 employees, including employees for whom
it had paid wages and payroll taxes; and (b) falsely certified
Allstate Towing would use the loan proceeds only for permissible
business purposes.
Overt Act No. 21:
On or about May 2, 2020, defendant
A. AYVAZYAN, together with other coconspirators, submitted and caused
to be submitted to Lender C false documents, including fake IRS Forms
940 and 941, in support of the Allstate Towing PPP loan application.
Overt Act No. 22:
On or about May 5, 2020, defendant
A. AYVAZYAN, together with other coconspirators, caused Lender C to
wire approximately $124,000 in proceeds from the Allstate Towing PPP
loan to the Allstate Towing Bank 4 Account.
Overt Act No. 23:
On or about May 21, 2020, defendant
A. AYVAZYAN, together with other coconspirators, caused approximately
$80,000, which in substantial part came from the Allstate Towing PPP
loan proceeds, to be wired from the Allstate Towing Bank 4 Account to
the Allstate Towing Bank 2 Account with the memo “BUSINESS TRANSFER
FOR PAYROLL PAYROLL [sic].”
Overt Act No. 24:
On or about June 3, 2020, defendant
A. AYVAZYAN, together with other coconspirators, caused approximately
$93,000, which in substantial part came from the Allstate Towing PPP
loan proceeds, to be wired from the Allstate Towing Bank 2 Account to
Escrow Company 1 to be used as part of the $3,250,000 purchase price
for Residential Property 1, which was purchased in the names of
defendants R. AYVAZYAN and TERABELIAN.
G&A Diamonds and Redline Auto Collision Loans
Overt Act No. 25:
On or about May 3, 2020, defendant
GRIGORYAN, together with other coconspirators, including defendants
Case 2:20-cr-00579-SVW Document 422-3 Filed 06/04/21 Page 17 of 59 Page ID
#:4644
17
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
R. AYVAZYAN and TERABELIAN, submitted and caused to be submitted to
Lender C an application in the name of G&A Diamonds seeking a PPP
loan in the amount of approximately $113,750, which application: (a)
falsely represented that G&A Diamonds had 12 employees, including
employees for whom it had paid wages and payroll taxes; and (b)
falsely certified G&A Diamonds would use the loan proceeds only for
permissible business purposes.
Overt Act No. 26:
On or about May 3, 2020, in support of the
G&A Diamonds PPP loan application, defendant GRIGORYAN, together with
other coconspirators, including defendants R. AYVAZYAN and
TERABELIAN, submitted and caused to be submitted to Lender C a fake
IRS Form 940 for 2019, which falsely represented that it had been
prepared by F.A., a professional tax preparer.
Overt Act No. 27:
On or about May 5, 2020, defendant
GRIGORYAN, together with other coconspirators, including defendants
R. AYVAZYAN and TERABELIAN, caused Lender C to wire approximately
$113,750 in proceeds from the G&A Diamonds PPP loan to the G&A
Diamonds Bank 4 Account.
Overt Act No. 28:
On or about May 7, 2020, defendant PARONYAN,
together with other coconspirators, including defendants R. AYVAZYAN
and TERABELIAN, submitted and caused to be submitted to Lender B an
application in the name of Redline Auto Collision Inc. (“Redline Auto
Collision”) seeking a PPP loan in the amount of $130,187, which
application: (a) falsely represented that Redline Auto Collision had
12 employees, including employees for whom it had paid wages and
payroll taxes, and average monthly payroll expenses of $52,075; and
(b) falsely certified Redline Auto Collision would use the loan
proceeds only for permissible business purposes.
Case 2:20-cr-00579-SVW Document 422-3 Filed 06/04/21 Page 18 of 59 Page ID
#:4645
18
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
Overt Act No. 29:
On or about May 11, 2020, defendant
PARONYAN, together with other coconspirators, including defendants R.
AYVAZYAN and TERABELIAN, caused Lender B to wire approximately
$130,187 in proceeds from the Redline Auto Collision PPP loan to the
Redline Auto Collision Bank 5 Account.
Overt Act No. 30:
On or about April 2, 2020, defendant
PARONYAN, together with other coconspirators, including defendants R.
AYVAZYAN and TERABELIAN, submitted and caused to be submitted to the
SBA an application in the name of Redline Auto Collision seeking an
EIDL loan in the amount of approximately $150,000, which application:
(a) falsely represented that Redline Auto Collision had 4 employees,
including employees for whom it had paid wages and payroll taxes; and
(b) falsely certified Redline Auto Collision would use the loan
proceeds for permissible business purposes.
Overt Act No. 31:
On or about June 8, 2020, defendant
PARONYAN, together with other coconspirators, including defendants R.
AYVAZYAN and TERABELIAN, caused the SBA to wire approximately
$149,900 in proceeds from the Redline Auto Collision EIDL loan to the
Redline Auto Collision Bank 5 account.
Overt Act No. 32:
On or about April 8, 2020, defendant
GRIGORYAN, together with other coconspirators, including defendants
R. AYVAZYAN and TERABELIAN, submitted and caused to be submitted to
the SBA an application in the name of G&A Diamonds seeking an EIDL
loan in the amount of approximately $150,000, which application:
(a) falsely represented that G&A Diamonds had 5 employees, including
employees for whom it had paid wages and payroll taxes; and (b)
falsely certified G&A Diamonds would use the loan proceeds for
permissible business purposes.
Case 2:20-cr-00579-SVW Document 422-3 Filed 06/04/21 Page 19 of 59 Page ID
#:4646
19
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
Overt Act No. 33:
On or about June 16, 2020, defendant
GRIGORYAN, together with other coconspirators, including defendants
R. AYVAZYAN and TERABELIAN, caused the SBA to wire approximately
$149,900 to the G&A Diamonds Bank 4 Account.
Overt Act No. 34:
On or about June 17, 2020, defendant
PARONYAN, together with other coconspirators, including defendants R.
AYVAZYAN and TERABELIAN, caused approximately $150,000, comprised in
substantial part of the proceeds from the Redline Auto Collision PPP
and EIDL loans, to be wired from Redline Auto Collision Bank 5
Account to the Terabelian Bank 2 Account.
Overt Act No. 35:
On or about June 19, 2020, defendant
GRIGORYAN, together with other coconspirators, including defendants
R. AYVAZYAN and TERABELIAN, caused approximately $100,000, which in
substantial part came from the proceeds from the G&A Diamonds PPP and
EIDL loans, to be wired from G&A Diamonds Bank 4 Account to
Terabelian Bank 2 Account.
Overt Act No. 36:
On or about June 22, 2020, defendants
R. AYVAZYAN and TERABELIAN, together with other coconspirators,
caused approximately $565,000, which in substantial part came from
PPP and EIDL loan funds obtained from the SBA and financial
institutions in the name of G&A Diamonds and Redline Auto Collision,
to be wired from the Terabelian Bank 2 Account to Escrow Company 1 to
be used as part of the $3,250,000 purchase price for Residential
Property 1, which was purchased in the names of defendants R.
AYVAZYAN and TERABELIAN.
Voyage Limo PPP Loan
Overt Act No. 37:
On or about May 18, 2020, defendant V.
DADYAN, together with other coconspirators, submitted and caused to
Case 2:20-cr-00579-SVW Document 422-3 Filed 06/04/21 Page 20 of 59 Page ID
#:4647
20
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
be submitted to Lender B an application in the name of Voyage Limo
seeking a PPP loan in the amount of $157,500, which application:
(a) falsely represented that Voyage Limo had 11 employees, including
employees for whom it had paid wages and payroll taxes, and average
monthly payroll expenses of $63,000; and (b) falsely certified Voyage
Limo would use the loan proceeds only for permissible business
purposes.
Overt Act No. 38:
On or about May 18, 2020, defendant V.
DADYAN, together with other coconspirators, submitted and caused to
be submitted to Lender B false documents, including fake IRS Forms
940 and 941, in support of the Voyage Limo PPP loan application.
Overt Act No. 39:
On or about May 20, 2020, defendant V.
DADYAN, together with other coconspirators, caused Lender B to wire
approximately $157,500 in proceeds from the Voyage Limo PPP loan to
the Voyage Limo Bank 3 Account.
Overt Act No. 40:
On or about July 3, 2020, defendant V.
DADYAN, together with other coconspirators, caused approximately
$155,000, which in substantial part came from the Voyage Limo PPP
loan proceeds, to be wired from the Voyage Limo Bank 3 Account to
Runyan Tax Bank 2 Account with the memo “Payroll."
Overt Act No. 41:
On or about July 23, 2020, defendants
R. AYVAZYAN and TERABELIAN caused approximately $238,614, which in
part came from the Voyage Limo PPP loan proceeds, to be transferred
from the Runyan Tax Bank 2 Account to Escrow Company 2 to be used as
part of the approximately $1,000,000 purchase price for Residential
Property 2, which was purchased in the name of defendant R.
AYVAZYAN’s alias “Iuliia Zhadko.”
Case 2:20-cr-00579-SVW Document 422-3 Filed 06/04/21 Page 21 of 59 Page ID
#:4648
21
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
Timeline Transport EIDL Loan
Overt Act No. 42:
On or about June 15, 2020, defendant
R. AYVAZYAN, using the alias “Iuliia Zhadko,” together with other
coconspirators, submitted and caused to be submitted to the SBA an
application in the name of Timeline Transport, Inc. (“Timeline
Transport”) seeking an EIDL loan in the amount of approximately
$150,000, which application: (a) falsely represented that “Iuliia
Zhadko” had owned Timeline Transport since 2016 and was the company’s
Chief Executive Officer; (b) falsely represented that Timeline
Transport had 22 employees, including employees for whom it had paid
wages and payroll taxes; and (c) falsely certified Timeline Transport
would use the loan proceeds for permissible business purposes.
Overt Act No. 43:
On or about June 22, 2020, defendant
R. AYVAZYAN, together with other coconspirators, caused the SBA to
wire approximately $149,900 in proceeds from the Timeline Transport
EIDL loan to the Timeline Transport Bank 1 Account.
Overt Act No. 44:
On or about June 24, 2020, defendant
R. AYVAZYAN, together with other coconspirators, caused approximately
$110,000, which in substantial part came from the Timeline Transport
EIDL loan proceeds, to be wired from the Timeline Transport Bank 1
Account to Escrow Company 1 to be used as part of the $3,250,000
purchase price for Residential Property 1, which was purchased in the
names of defendants R. AYVAZYAN and TERABELIAN.
Redline Auto Mechanics PPP Loan
Overt Act No. 45:
On or about June 25, 2020, defendant
GRIGORYAN, using defendant GRIGORYAN’s alias “Anton Kudiumov,”
together with other coconspirators, submitted and caused to be
submitted to Lender B an application in the name of Redline Auto
Case 2:20-cr-00579-SVW Document 422-3 Filed 06/04/21 Page 22 of 59 Page ID
#:4649
22
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
Mechanics seeking a PPP loan in the amount of $276,650, which
application: (a) falsely represented that Redline Auto Mechanics had
22 employees, including employees for whom it had paid wages and
payroll taxes; and (b) falsely certified Redline Auto Mechanics would
use the loan proceeds only for permissible business purposes.
Overt Act No. 46:
On or about June 25, 2020, defendant
GRIGORYAN, together with other coconspirators, submitted and caused
to be submitted to Lender B false documents in support of the Redline
Auto Mechanics PPP loan application, including a fake California
driver’s license in the name of “Anton Kudiumov,” and a fake IRS Form
940 for 2019, which falsely represented that it had been prepared by
A.F., a professional tax preparer.
Overt Act No. 47:
On or about June 29, 2020, defendant
GRIGORYAN, together with other coconspirators, caused Lender B to
wire approximately $276,600 in proceeds from the Redline Auto
Mechanics PPP loan to the Redline Auto Mechanics Bank 2 Account.
Overt Act No. 48:
On or about June 29, 2020, defendant
GRIGORYAN, together with other coconspirators, caused a total of
approximately $115,000, which was comprised in substantial part of
the Redline Auto Mechanics PPP loan proceeds, to be transferred from
Redline Auto Mechanics Bank 2 Account to the Kudiumov Bank 2 Account.
Overt Act No. 49:
On or about July 9, 2020, defendant
GRIGORYAN, together with other coconspirators, caused approximately
$93,200, which was comprised in substantial part from the Redline
Auto Mechanics PPP loan proceeds, to be transferred from the Kudiumov
Bank 2 Account to Escrow Company 3 to be used as part of the
approximately $600,000 purchase price for Residential Property 3,
Case 2:20-cr-00579-SVW Document 422-3 Filed 06/04/21 Page 23 of 59 Page ID
#:4650
23
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
which was purchased in the name of defendant TERABELIAN’s alias
“Viktoria Kauichko.”
Runyan Tax Service PPP Loan
Overt Act No. 50:
On or about July 13, 2020, defendants
R. AYVAZYAN and TERABELIAN, using defendant TERABELIAN’s alias
“Viktoria Kauichko,” together with other coconspirators, submitted
and caused to be submitted to Lender A an application in the name of
Runyan Tax Service, Inc. (“Runyan Tax Service”) seeking a PPP loan in
the amount of $276,653, which application: (a) falsely represented
that Runyan Tax Service had 22 employees, including employees for
whom it had paid wages and payroll taxes; and (b) falsely certified
Runyan Tax Service would use the loan proceeds only for permissible
business purposes.
Overt Act No. 51:
On or about July 13, 2020, defendants
R. AYVAZYAN and TERABELIAN, together with other coconspirators,
submitted and caused to be submitted to Lender A false documents in
support of the Runyan Tax Service PPP loan application, including a
fraudulent California driver’s license purportedly belonging to
“Viktoria Kauichko,” and a federal tax filing representing “Viktoria
Kauichko” as Runyan Tax Service’s President, even though defendants
R. AYVAZYAN and TERABELIAN knew at the time that “Viktoria Kauichko”
was a fake identity.
Overt Act No. 52:
On or about July 21, 2020, defendants
R. AYVAZYAN and TERABELIAN, together with other coconspirators,
caused Lender A to wire approximately $276,653 in proceeds from the
Runyan Tax Service PPP loan to the Runyan Tax Bank 2 Account.
Overt Act No. 53:
On or about July 23, 2020, defendants
R. AYVAZYAN and TERABELIAN, together with other coconspirators,
Case 2:20-cr-00579-SVW Document 422-3 Filed 06/04/21 Page 24 of 59 Page ID
#:4651
24
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
caused approximately $238,614, which in substantial part came from
the Runyan Tax Service PPP loan proceeds, to be transferred from the
Runyan Tax Bank 2 Account to Escrow Company 2 to be used as part of
the approximately $1,000,000 purchase price for Residential Property
2, which was purchased in the name of defendant R. AYVAZYAN’s alias
“Iuliia Zhadko.”
Mod Interiors PPP Loan
Overt Act No. 54:
On or about July 21, 2020, defendants
R. AYVAZYAN and TERABELIAN opened an account at Bank 7 in the name of
Mod Interiors, Inc. (“Mod Interiors”), and listed N.T., who was a
close relative, as the sole signatory. N.T., however, was deceased,
as he had died three days earlier.
Overt Act No. 55:
On or about July 23, 2020, defendants
R. AYVAZYAN and TERABELIAN, using the name of N.T., together with
other coconspirators, submitted and caused to be submitted to Lender
F an application in the name of Mod Interiors seeking a PPP loan in
the amount of $384,150, which application: (a) falsely represented
that N.T. was Mod Interiors’ President; (b) falsely represented that
Mod Interiors had 36 employees, including employees for whom it had
paid wages and payroll taxes; and (c) included, as a supporting
record, a copy of N.T.’s California driver’s license.
Overt Act No. 56:
On or about July 23, 2020, defendants
R. AYVAZYAN and TERABELIAN submitted and caused to be submitted to
Lender F false documents in support of the Mod Interiors PPP loan
application, including fake IRS Forms 1120-S and 940, which falsely
represented that they had been prepared by L.O., a professional tax
preparer.
Case 2:20-cr-00579-SVW Document 422-3 Filed 06/04/21 Page 25 of 59 Page ID
#:4652
25
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
Overt Act No. 57:
On or about July 31, 2020, defendants
R. AYVAZYAN and TERABELIAN, together with other coconspirators,
caused Lender F to wire approximately $384,150 in proceeds from the
Mod Interiors PPP loan to Mod Interiors Bank 7 Account.
Overt Act No. 58:
In or around August 2020, defendants
R. AYVAZYAN and TERABELIAN, together with other coconspirators,
caused a total of approximately $74,616, which in substantial part
came from the Mod Interiors PPP loan proceeds, to be transferred from
the Mod Interiors Bank 7 Account to the Runyan Tax Bank 2 Account.
Turing Info Solutions PPP Loan
Overt Act No. 59:
On or about August 3, 2020, defendant
R. AYVAZYAN, using his alias “Iuliia Zhadko,” together with other
coconspirators, submitted and caused to be submitted to Lender F an
application in the name of Turing Info Solutions Inc. (“Turing
Info”), seeking a PPP loan in the amount of $384,150.
Overt Act No. 60:
On or about August 3, 2020, in connection
with the Turing Info PPP loan application, defendant R. AYVAZYAN,
together with other coconspirators, submitted and caused to be
submitted to Lender F a fake California driver’s license in the name
of “Iuliia Zhadko” and fake IRS Forms 940 and 1120-S, which falsely
represented that each had been prepared by J.R., a professional tax
preparer.
Overt Act No. 61:
On or about August 25, 2020, defendant
R. AYZAYAN, together with other coconspirators, caused Lender F to
wire approximately $384,100 in proceeds from the Turing Info PPP loan
to the Turing Info Bank 5 Account, which listed defendant
R. AYVAZYAN’s alias “Iuliia Zhadko” as the only signatory.
Case 2:20-cr-00579-SVW Document 422-3 Filed 06/04/21 Page 26 of 59 Page ID
#:4653
26
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
A.D. PPP Loan
Overt Act No. 62:
On or about August 13, 2020, defendants A.
AYVAZYAN and T. DADYAN, using the name of A.D., a real person,
together with other coconspirators, submitted and caused to be
submitted to Lender F an application in the name of “A.D. DBA Six
Star Farms” for a PPP loan in the amount of $244,500, which
application: (a) falsely represented that A.D. had 22 employees,
including employees for whom A.D had paid wages and payroll taxes;
and (b) falsely certified that the purported applicant, A.D., would
use the loan proceeds only for permissible business purposes.
Overt Act No. 63:
On or about August 13, 2020, defendants A.
AYVAZYAN and T. DADYAN, together with other coconspirators, submitted
and caused to be submitted to Lender F false documents in support of
the A.D. DBA Six Star Farms PPP loan application, including a fake
California driver’s license purportedly belonging to A.D., and a fake
Form 941, which falsely represented that it had been prepared by
A.F., a professional tax preparer, and signed by A.D.
Overt Act No. 64:
On or about August 17, 2020, defendants
A. AYVAZYAN and T. DADYAN, together with other coconspirators, caused
Lender F to wire approximately $244,500 in proceeds from the A.D. DBA
Six Star Farms PPP loan to the A.D. Bank 8 Account.
Case 2:20-cr-00579-SVW Document 422-3 Filed 06/04/21 Page 27 of 59 Page ID
#:4654
27
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
COUNTS TWO THROUGH TWELVE
[18 U.S.C. §§ 1343, 2(a)]
[ALL DEFENDANTS]
34.
The Grand Jury re-alleges paragraphs 1 through 29 of this
First Superseding Indictment here.
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.
The fraudulent scheme operated and was carried out, in
substance, as follows:
a.
Defendants R. AYVAZYAN, TERABELIAN, A. AYVAZYAN, T.
DADYAN, GRIGORYAN, HAYRAPETYAN, PARONYAN, and V. DADYAN, together
with other co-schemers, 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 co-schemers, used and caused to be used, stolen,
fictitious, and synthetic business names to submit fraudulent
applications for PPP and EIDL loans.
Case 2:20-cr-00579-SVW Document 422-3 Filed 06/04/21 Page 28 of 59 Page ID
#:4655
28
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
c.
Defendants R. AYVAZYAN, TERABELIAN, A. AYVAZYAN, T.
DADYAN, GRIGORYAN, HAYRAPETYAN, PARONYAN, and V. DADYAN, together
with other co-schemers, 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
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 co-schemers, electronically submitted, and caused to be
submitted, fictitious documents to the SBA and financial institutions
in support of the fraudulent PPP and EIDL loan applications,
including false 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 co-schemers, directed the other defendants and their co-
schemers 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 co-
schemers controlled.
f.
Defendants R. AYVAZYAN, TERABELIAN, A. AYVAZYAN, T.
DADYAN, GRIGORYAN, HAYRAPETYAN, PARONYAN, and V. DADYAN, together
with other co-schemers, laundered and used the fraudulently obtained
PPP and EIDL loan proceeds for their own personal benefit and for the
benefit of their co-schemers, including for expenses prohibited under
the requirements of the PPP and EIDL programs, such as the purchase
Case 2:20-cr-00579-SVW Document 422-3 Filed 06/04/21 Page 29 of 59 Page ID
#:4656
29
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
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.
B.
USE OF THE WIRES
37.
On or about the dates set forth below, 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 following items by
means of wire and radio communication in interstate and foreign
commerce:
COUNT
DATE
INTERSTATE WIRE TRANSMISSION
DEFENDANTS
CHARGED
TWO
May 1,
2020
Transfer of approximately $182,637
in PPP loan proceeds from Lender H,
sent by means of an interstate wire,
into S. Construction Bank 5 Account
R. AYVAZYAN;
TERABELIAN;
A. AYVAZYAN;
T. DADYAN;
GRIGORYAN;
HAYRAPETYAN;
PARONYAN
THREE
May 5,
2020
Transfer of approximately $124,000
in PPP loan proceeds from Lender C,
sent by means of an interstate wire,
into Allstate Towing Bank 4 Account
R. AYVAZYAN;
TERABELIAN;
A. AYVAZYAN;
T. DADYAN;
GRIGORYAN;
HAYRAPETYAN;
PARONYAN
FOUR
May 8,
2020
Transfer of approximately $130,000
in PPP loan proceeds from Lender B,
sent by means of an interstate wire,
into TQC Bank 3 Account
R. AYVAZYAN;
TERABELIAN;
A. AYVAZYAN;
T. DADYAN;
GRIGORYAN;
HAYRAPETYAN;
PARONYAN
Case 2:20-cr-00579-SVW Document 422-3 Filed 06/04/21 Page 30 of 59 Page ID
#:4657
30
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
COUNT
DATE
INTERSTATE WIRE TRANSMISSION
DEFENDANTS
CHARGED
FIVE
May 11,
2020
Transfer of approximately $137,500
in PPP loan proceeds from Lender E,
sent by means of an interstate wire,
into Secureline Realty Bank 6
Account
R. AYVAZYAN;
TERABELIAN;
A. AYVAZYAN;
T. DADYAN;
GRIGORYAN;
HAYRAPETYAN;
PARONYAN
SIX
May 11,
2020
Transfer of approximately $130,187
in PPP loan proceeds from Lender B,
sent by means of an interstate wire,
into Redline Auto Collision Bank 5
Account
R. AYVAZYAN;
TERABELIAN;
A. AYVAZYAN;
T. DADYAN;
GRIGORYAN;
HAYRAPETYAN;
PARONYAN
SEVEN
May 20,
2020
Transfer of approximately $157,500
in PPP loan proceeds from Lender B,
sent by means of an interstate wire,
into Voyage Limo Bank 3 Account
ALL
DEFENDANTS
EIGHT
June 16,
2020
Transfer of approximately $149,900
in EIDL loan proceeds from the SBA,
sent by means of an interstate wire,
into G&A Diamonds Bank 4 Account
ALL
DEFENDANTS
NINE
June 17,
2020
Transfer of approximately $150,000
in EIDL loan proceeds from the
Redline Auto Collision Bank 5
Account, sent by means of an
interstate wire, to Terabelian Bank
2 Account
ALL
DEFENDANTS
TEN
June 22,
2020
Transfer of approximately $149,900
in EIDL loan proceeds from the SBA,
sent by means of an interstate wire,
into Timeline Transport Bank 1
Account
ALL
DEFENDANTS
ELEVEN July 31,
2020
Transfer of approximately $384,150
in PPP loan proceeds from Lender F,
sent by means of an interstate wire,
into Mod Interiors Bank 7 Account
ALL
DEFENDANTS
TWELVE August
13, 2020
Submission of application for PPP
loan to Lender F in the name of
A.D., sent by means of an interstate
wire
ALL
DEFENDANTS
Case 2:20-cr-00579-SVW Document 422-3 Filed 06/04/21 Page 31 of 59 Page ID
#:4658
31
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
COUNTS THIRTEEN THROUGH TWENTY
[18 U.S.C. §§ 1344(2), 2(a), 2(b)]
[ALL DEFENDANTS]
38.
The Grand Jury re-alleges paragraphs 1 through 29 of this
First Superseding Indictment here.
A.
THE SCHEME TO DEFRAUD
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.
40.
The fraudulent scheme operated and was carried out, in
substance, as follows:
a.
Defendants R. AYVAZYAN, TERABELIAN, A. AYVAZYAN, T.
DADYAN, GRIGORYAN, HAYRAPETYAN, PARONYAN, and V. DADYAN, together
with other co-schemers, used and caused to be used, stolen,
fictitious, and synthetic identities of individuals to submit
fraudulent applications for PPP loans.
b.
Defendants R. AYVAZYAN, TERABELIAN, A. AYVAZYAN, T.
DADYAN, GRIGORYAN, HAYRAPETYAN, PARONYAN, and V. DADYAN, together
with other co-schemers, used and caused to be used, stolen,
Case 2:20-cr-00579-SVW Document 422-3 Filed 06/04/21 Page 32 of 59 Page ID
#:4659
32
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
fictitious, and synthetic business names to submit fraudulent
applications for PPP loans.
c.
Defendants R. AYVAZYAN, TERABELIAN, A. AYVAZYAN, T.
DADYAN, GRIGORYAN, HAYRAPETYAN, PARONYAN, and V. DADYAN, together
with other co-schemers, made and caused to be made, false statements
to the SBA and financial institutions in connection with the
fraudulent applications for PPP loans, including false
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 co-schemers, electronically submitted, and caused to be
submitted, fictitious documents to the SBA and financial institutions
in support of the fraudulent PPP loan applications, including false
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 co-schemers, directed the other defendants and their co-
schemers to deposit PPP loan proceeds into bank accounts that
defendants R. AYVAZYAN, TERABELIAN, A. AYVAZYAN, T. DADYAN,
GRIGORYAN, HAYRAPETYAN, PARONYAN, and V. DADYAN, and their co-
schemers controlled.
f.
Defendants R. AYVAZYAN, TERABELIAN, A. AYVAZYAN, T.
DADYAN, GRIGORYAN, HAYRAPETYAN, PARONYAN, and V. DADYAN, together
with other co-schemers, laundered and used the fraudulently obtained
PPP loan proceeds for their own personal benefit and for the benefit
Case 2:20-cr-00579-SVW Document 422-3 Filed 06/04/21 Page 33 of 59 Page ID
#:4660
33
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
of their co-schemers, including for expenses prohibited under the
requirements of the PPP 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.
B.
EXECUTIONS OF THE SCHEME
41.
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 following acts, each of
which constituted an execution of the fraudulent scheme:
COUNT
DATE
ACT
DEFENDANTS
CHARGED
THIRTEEN
April 18,
2020
Submission of application for
PPP loan to Lender H in the name
of H. Construction
R. AYVAZYAN;
TERABELIAN;
A. AYVAZYAN;
T. DADYAN;
GRIGORYAN;
HAYRAPETYAN;
PARONYAN
FOURTEEN
April 30,
2020
Submission of application for
PPP loan to Lender B in the name
of TQC
R. AYVAZYAN;
TERABELIAN;
A. AYVAZYAN;
T. DADYAN;
GRIGORYAN;
HAYRAPETYAN;
PARONYAN
FIFTEEN
May 2,
2020
Submission of application for
PPP loan to Lender C in the name
of Allstate Towing
R. AYVAZYAN;
TERABELIAN;
A. AYVAZYAN;
T. DADYAN;
GRIGORYAN;
HAYRAPETYAN;
PARONYAN
Case 2:20-cr-00579-SVW Document 422-3 Filed 06/04/21 Page 34 of 59 Page ID
#:4661
34
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
COUNT
DATE
ACT
DEFENDANTS
CHARGED
SIXTEEN
May 7,
2020
Submission of application for
PPP loan to Lender B in the name
of Redline Auto Collision
R. AYVAZYAN;
TERABELIAN;
A. AYVAZYAN;
T. DADYAN;
GRIGORYAN;
HAYRAPETYAN;
PARONYAN
SEVENTEEN May 9,
2020
Submission of application for
PPP loan to Lender E in the name
of Secureline Realty
R. AYVAZYAN;
TERABELIAN;
A. AYVAZYAN;
T. DADYAN;
GRIGORYAN;
HAYRAPETYAN;
PARONYAN
EIGHTEEN
May 18,
2020
Submission of application for
PPP loan to Lender B in the name
of Voyage Limo
ALL
DEFENDANTS
NINETEEN
June 25,
2020
Submission of application for
PPP loan to Lender B in the name
of Redline Auto Mechanics
ALL
DEFENDANTS
TWENTY
July 13,
2020
Submission of application for
PPP loan to Lender A in the name
of Runyan Tax Service
ALL
DEFENDANTS
Case 2:20-cr-00579-SVW Document 422-3 Filed 06/04/21 Page 35 of 59 Page ID
#:4662
35
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
COUNT TWENTY-ONE
[18 U.S.C. §§ 1028A(a)(1), 2(b)]
[Defendant R. AYVAZYAN]
42.
The Grand Jury re-alleges paragraphs 1 through 29 of this
First Superseding Indictment here.
43.
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,
defendant R. AYVAZYAN knowingly transferred, possessed, and used, and
willfully caused to be transferred, possessed, and used, without
lawful authority, a means of identification that defendant
R. AYVAZYAN knew belonged to another person, namely, the name of
M.Z., during and in relation to bank fraud, a felony violation of
Title 18, United States Code, Section 1344(2), as charged in Count
Fourteen of this First Superseding Indictment.
Case 2:20-cr-00579-SVW Document 422-3 Filed 06/04/21 Page 36 of 59 Page ID
#:4663
36
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
COUNT TWENTY-TWO
[18 U.S.C. §§ 1028A(a)(1), 2(a), 2(b)]
[Defendants R. AYVAZYAN and TERABELIAN]
44.
The Grand Jury re-alleges paragraphs 1 through 29 of this
First Superseding Indictment here.
45.
Beginning no later than in or around July 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 and TERABELIAN, each aiding and abetting the
other, knowingly transferred, possessed, and used, and willfully
caused to be transferred, possessed, and used, without lawful
authority, means of identification that defendants R. AYVAZYAN and
TERABELIAN knew belonged to another person, namely, the name and
California driver’s license number of N.T., during and in relation to
wire fraud, a felony violation of Title 18, United States Code,
Section 1343, as charged in Count Eleven of this First Superseding
Indictment.
Case 2:20-cr-00579-SVW Document 422-3 Filed 06/04/21 Page 37 of 59 Page ID
#:4664
37
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
COUNT TWENTY-THREE
[18 U.S.C. §§ 1028A(a)(1), 2(b)]
[Defendant GRIGORYAN]
46.
The Grand Jury re-alleges paragraphs 1 through 29 of this
First Superseding Indictment here.
47.
Beginning no later than in or around June 2020 and
continuing until at least in or around August 2020, in Los Angeles
County, within the Central District of California, and elsewhere,
defendant GRIGORYAN knowingly transferred, possessed, and used, and
willfully caused to be transferred, possessed, and used, without
lawful authority, a means of identification that defendant GRIGORYAN
knew belonged to another person, namely, the name of A.F., during and
in relation to bank fraud, a felony violation of Title 18, United
States Code, Section 1344(2), as charged in Count Nineteen of this
First Superseding Indictment.
Case 2:20-cr-00579-SVW Document 422-3 Filed 06/04/21 Page 38 of 59 Page ID
#:4665
38
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
COUNT TWENTY-FOUR
[18 U.S.C. §§ 1028A(a)(1), 2(a), 2(b)]
[Defendants A. AYVAZYAN and T. DADYAN]
48.
The Grand Jury re-alleges paragraphs 1 through 29 of this
First Superseding Indictment here.
49.
Beginning no later than in or around June 2020 and
continuing until at least in or around August 2020, in Los Angeles
County, within the Central District of California, and elsewhere,
defendants A. AYVAZYAN and T. DADYAN, each aiding and abetting the
other, knowingly transferred, possessed, and used, and willfully
caused to be transferred, possessed, and used, without lawful
authority, means of identification that defendants A. AYVAZYAN and T.
DADYAN knew belonged to another person, namely, the name and date of
birth of A.D., during and in relation to wire fraud, a felony
violation of Title 18, United States Code, Section 1343, as charged
in Count Twelve of this First Superseding Indictment.
Case 2:20-cr-00579-SVW Document 422-3 Filed 06/04/21 Page 39 of 59 Page ID
#:4666
39
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
COUNT TWENTY-FIVE
[18 U.S.C. §§ 1028A(a)(1), 2(b)]
[Defendant HAYRAPETYAN]
50.
The Grand Jury re-alleges paragraphs 1 through 29 of this
First Superseding Indictment here.
51.
Beginning no later than in or around April 2020 and
continuing until at least in or around August 2020, in Los Angeles
County, within the Central District of California, and elsewhere,
defendant HAYRAPETYAN knowingly transferred, possessed, and used, and
willfully caused to be transferred, possessed, and used, without
lawful authority, a means of identification that defendant
HAYRAPETYAN knew belonged to another person, namely, the name and
social security number of M.H., during and in relation to bank fraud,
a felony violation of Title 18, United States Code, Section 1344(2),
as charged in Count Thirteen of this First Superseding Indictment.
Case 2:20-cr-00579-SVW Document 422-3 Filed 06/04/21 Page 40 of 59 Page ID
#:4667
40
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
COUNT TWENTY-SIX
[18 U.S.C. § 1956(h)]
[ALL DEFENDANTS]
52.
The Grand Jury re-alleges paragraphs 1 through 29 of this
First Superseding Indictment here.
A.
THE OBJECTS OF THE CONSPIRACY
53.
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.
Case 2:20-cr-00579-SVW Document 422-3 Filed 06/04/21 Page 41 of 59 Page ID
#:4668
41
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
B.
THE MANNER AND MEANS OF THE CONSPIRACY
53.
The objects of the conspiracy were carried out, and to be
carried out, as follows:
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.
Case 2:20-cr-00579-SVW Document 422-3 Filed 06/04/21 Page 42 of 59 Page ID
#:4669
42
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
C.
OVERT ACTS
54.
The Grand Jury re-alleges paragraph 32 of this First
Superseding Indictment as a description of the overt acts, among
others, committed and willfully caused to be committed in furtherance
of the conspiracy and used to accomplish its objects, within the
Central District of California.
Case 2:20-cr-00579-SVW Document 422-3 Filed 06/04/21 Page 43 of 59 Page ID
#:4670
43
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
COUNT TWENTY-SEVEN
[18 U.S.C. §§ 1956(a)(1)(B)(i), 2(b)]
[Defendant V. DADYAN]
55.
The Grand Jury re-alleges paragraphs 1 through 29 of this
First Superseding Indictment here.
CONCEALMENT MONEY LAUNDERING
56.
On or about July 3, 2020, in Los Angeles County, within the
Central District of California, and elsewhere, defendant V. DADYAN,
and others known and unknown to the Grand Jury, knowingly conducted,
and willfully caused others to conduct, a financial transaction
involving the proceeds of specified unlawful activity, that is,
conspiracy to commit bank and wire fraud, in violation of Title 18,
United States Code, Section 1349, wire fraud in violation of Title
18, United States Code, Section 1343, and bank fraud, in violation of
Title 18, United States Code, Section 1344(2), knowing that the
transaction was designed in whole and in part to conceal and disguise
the nature, location, source, ownership, and control of such
proceeds, to wit: a wire transfer of $155,000, which in substantial
part came from the Voyage Limo PPP loan proceeds, from the Voyage
Limo Bank 3 Account to Runyan Tax Bank 2 Account with the memo
“Payroll.”
Case 2:20-cr-00579-SVW Document 422-3 Filed 06/04/21 Page 44 of 59 Page ID
#:4671
44
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
COUNTS TWENTY-EIGHT THROUGH THIRTY-TWO
[18 U.S.C. §§ 1956(a)(1)(B)(i), 2(b), 3147]
[Defendant R. AYVAZYAN]
57.
The Grand Jury re-alleges paragraphs 1 through 29 of this
First Superseding Indictment here.
A.
CONCEALMENT MONEY LAUNDERING
58.
Beginning no later than in or around December 2020 and
continuing until at least in or around January 2021, in Los Angeles
County, within the Central District of California, and elsewhere,
defendant R. AYVAZYAN, and others known and unknown to the Grand
Jury, knowingly conducted, and willfully caused others to conduct,
the following financial transactions involving the proceeds of
specified unlawful activity, that is, conspiracy to commit bank and
wire fraud, in violation of Title 18, United States Code, Section
1349, wire fraud in violation of Title 18, United States Code,
Section 1343, and bank fraud, in violation of Title 18, United States
Code, Section 1344(2), knowing that the transactions were designed in
whole and in part to conceal and disguise the nature, location,
source, ownership, and control of such proceeds:
COUNT
DATE
TRANSACTION
TWENTY-EIGHT December 21,
2020
Transfer of $47,000 from Turing Info
Bank 5 Account to Zhadko Bank 5 Account
TWENTY-NINE
December 22,
2020
Transfer of $86,000 from Turing Info
Bank 5 Account to Zhadko Bank 5 Account
THIRTY
December 23,
2020
Transfer of $50,000 from Zhadko Bank 5
Account to Online Broker account ending
-3630, which was opened on 12/21/2020 in
the name of Iuliia Zhadko
THIRTY-ONE
December 24,
2020
Transfer of $75,000 from Zhadko Bank 5
Account to Online Broker account ending
-3630, which was opened on 12/21/2020 in
the name of Iuliia Zhadko
Case 2:20-cr-00579-SVW Document 422-3 Filed 06/04/21 Page 45 of 59 Page ID
#:4672
45
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
COUNT
DATE
TRANSACTION
THIRTY-TWO
January 13,
2021
Transfer of $22,000 from Turing Info
Bank 5 Account to Digital Currency
Exchange account ending -8efe, which was
opened on 01/07/2021 in the name of
Iuliia Zhadko
B.
OFFENSE COMMITTED WHILE ON RELEASE
59.
During the commission of the felony offenses described
above, defendant R. AYVAZYAN was released pursuant to Title 18,
United States Code, Chapter 27, in the criminal case of United States
v. Richard Ayvazyan et al., CR 20-579-SVW, in the United States
District Court for the Central District of California.
Case 2:20-cr-00579-SVW Document 422-3 Filed 06/04/21 Page 46 of 59 Page ID
#:4673
46
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
COUNT THIRTY-THREE
[18 U.S.C. §§ 1344(2), 2(a), 2(b), 3147]
[Defendant T. DADYAN]
60.
The Grand Jury re-alleges paragraphs 1 through 29 of this
First Superseding Indictment here.
A.
THE SCHEME TO DEFRAUD
61.
Beginning no later than in or around January 2021 and
continuing until at least in or around February 2021, in Los Angeles
County, within the Central District of California, and elsewhere,
defendant T. DADYAN, together with others known and unknown to the
Grand Jury, knowingly and with intent to defraud, devised,
participated in, and attempted to execute a scheme to obtain moneys,
funds, credits, assets, and other property owned by and in the
custody and control of Bank 8, a federally-insured financial
institution, by means of material false and fraudulent pretenses,
representations, and promises, and the concealment of material facts.
62.
The fraudulent scheme operated and was carried out, in
substance, in the following manner:
a.
Defendant T. DADYAN fraudulently opened an account at
Bank 8 using victim A.D.’s name (“A.D. Bank 8 Account”).
b.
Defendant T. DADYAN fraudulently obtained PPP and EIDL
loan funds, including by using victim A.D.’s name, and deposited and
transferred the funds in and to the A.D. Bank 8 Account. As of
January 22, 2021, the amount in A.D. Bank 8 Account totaled
approximately $302,274.
c.
Upon receiving notice that the funds in the A.D. Bank
8 Account had been frozen, defendant T. DADYAN repeatedly made
telephone calls to Bank 8 falsely representing that T. DADYAN was
Case 2:20-cr-00579-SVW Document 422-3 Filed 06/04/21 Page 47 of 59 Page ID
#:4674
47
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
A.D. and falsely representing that the frozen funds belonged to A.D.,
for the purpose of obtaining those funds.
B.
ATTEMPTED EXECUTION OF THE SCHEME
63.
On or about January 22, 2021, in Los Angeles County, within
the Central District of California, and elsewhere, defendant T.
DADYAN, together with others known and unknown to the Grand Jury,
aiding and abetting each other, committed and willfully caused others
to commit an act which constituted an attempted execution of the
fraudulent scheme, specifically, defendant T. DADYAN made a telephone
call to Bank 8 and falsely represented that she was A.D., in an
effort to obtain from Bank 8 funds in the A.D. Bank 8 Account, when
defendant T. DADYAN knew that she was not an authorized signatory on
the account, and that the funds in the account were comprised of
fraudulently obtained PPP and EIDL loan proceeds, including PPP loan
proceeds defendant T. DADYAN had fraudulently obtained using A.D.’s
name.
C.
OFFENSE COMMITTED WHILE ON RELEASE
64.
During the commission of the felony offense described
above, defendant T. DADYAN was released pursuant to Title 18, United
States Code, Chapter 27, in the criminal case of United States v.
Richard Ayvazyan et al., CR 20-579-SVW, in the United States District
Court for the Central District of California.
Case 2:20-cr-00579-SVW Document 422-3 Filed 06/04/21 Page 48 of 59 Page ID
#:4675
48
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
FORFEITURE ALLEGATION ONE
[18 U.S.C. § 982]
65.
Pursuant to Rule 32.2(a) of the Federal Rules of Criminal
Procedure, notice is hereby given that the United States of America
will seek forfeiture as part of any sentence, pursuant to Title 18,
United States Code, Section 982(a)(2), and Title 28, United States
Code, Section 2461(c), in the event of any defendant’s conviction of
the offense set forth in Count One of this First Superseding
Indictment.
66.
The defendant so convicted shall forfeit to the United
States of America the following:
a.
all right, title and interest in any and all property,
real or personal, constituting, or derived from, any proceeds
obtained, directly or indirectly, as a result of the offense,
including, but not limited to, certain real property referred to
herein as Residential Property 1 located in the County of Los
Angeles, State of California, APN 2176-029-031, certain real property
referred to herein as Residential Property 2 located in the County of
Los Angeles, State of California, APN 5663-036-033, and certain real
property referred to herein as Residential Property 3 located in the
County of Riverside, State of California, APN 694-331-008; and
b.
To the extent such property is not available for
forfeiture, a sum of money equal to the total value of the property
described in subparagraph (a).
67.
Pursuant to Title 21, United States Code, Section 853(p),
as incorporated by Title 18, United States Code, Section 982(b) and
Title 28, United States Code, Section 2461(c), any defendant so
convicted shall forfeit substitute property, up to the total value of
Case 2:20-cr-00579-SVW Document 422-3 Filed 06/04/21 Page 49 of 59 Page ID
#:4676
49
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
the property described in the preceding paragraph if, as the result
of any act or omission of said defendant, the property described in
the preceding paragraph, or any portion thereof: (a) cannot be
located upon the exercise of due diligence; (b) has been transferred,
sold to or deposited with a third party; (c) has been placed beyond
the jurisdiction of the court; (d) has been substantially diminished
in value; or (e) has been commingled with other property that cannot
be divided without difficulty.
Case 2:20-cr-00579-SVW Document 422-3 Filed 06/04/21 Page 50 of 59 Page ID
#:4677
50
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
FORFEITURE ALLEGATION TWO
[18 U.S.C. § 981(a)(1)(C) and 28 U.S.C. § 2461(c)]
68.
Pursuant to Rule 32.2 of the Federal Rules of Criminal
Procedure, notice is hereby given that the United States of America
will seek forfeiture as part of any sentence, pursuant to Title 18,
United States Code, Section 981(a)(1)(C) and Title 28, United States
Code, Section 2461(c), in the event of any defendant’s conviction of
the offenses set forth in any of Counts Two through Twelve of this
First Superseding Indictment.
69.
The defendant, if so convicted, shall forfeit to the United
States of America the following:
a.
all right, title, and interest in any and all
property, real or personal, constituting, or derived from, any
proceeds traceable to the offenses, including, but not limited to,
certain real property referred to herein as Residential Property 1
located in the County of Los Angeles, State of California, APN 2176-
029-031, certain real property referred to herein as Residential
Property 2 located in the County of Los Angeles, State of California,
APN 5663-036-033, and certain real property referred to herein as
Residential Property 3 located in the County of Riverside, State of
California, APN 694-331-008; and
b.
to the extent such property is not available for
forfeiture, a sum of money equal to the total value of the property
described in subparagraph (a).
70.
Pursuant to Title 21, United States Code, Section 853(p),
as incorporated by Title 28, United States Code, Section 2461(c), the
defendant, if so convicted, shall forfeit substitute property, up to
the value of the property described in the preceding paragraph if, as
Case 2:20-cr-00579-SVW Document 422-3 Filed 06/04/21 Page 51 of 59 Page ID
#:4678
51
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
the result of any act or omission of the defendant, the property
described in the preceding paragraph or any portion thereof
(a) cannot be located upon the exercise of due diligence; (b) has
been transferred, sold to, or deposited with a third party; (c) has
been placed beyond the jurisdiction of the court; (d) has been
substantially diminished in value; or (e) has been commingled with
other property that cannot be divided without difficulty.
Case 2:20-cr-00579-SVW Document 422-3 Filed 06/04/21 Page 52 of 59 Page ID
#:4679
52
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
FORFEITURE ALLEGATION THREE
[18 U.S.C. § 982]
71.
Pursuant to Rule 32.2(a) of the Federal Rules of Criminal
Procedure, notice is hereby given that the United States of America
will seek forfeiture as part of any sentence, pursuant to Title 18,
United States Code, Section 982(a)(2), and Title 28, United States
Code, Section 2461(c), in the event of any defendant’s conviction of
the offenses set forth in any of Counts Thirteen through Twenty and
Thirty-Three of this First Superseding Indictment.
72.
Any defendant so convicted shall forfeit to the United
States of America the following:
a.
all right, title and interest in any and all property,
real or personal, constituting, or derived from, any proceeds
obtained, directly or indirectly, as a result of the offense,
including, but not limited to, certain real property referred to
herein as Residential Property 1 located in the County of Los
Angeles, State of California, APN 2176-029-031, certain real property
referred to herein as Residential Property 2 located in the County of
Los Angeles, State of California, APN 5663-036-033, and certain real
property referred to herein as Residential Property 3 located in the
County of Riverside, State of California, APN 694-331-008; and
b.
to the extent such property is not available for
forfeiture, a sum of money equal to the total value of the property
described in subparagraph (a).
73.
Pursuant to Title 21, United States Code, Section 853(p),
as incorporated by Title 18, United States Code, Section 982(b) and
Title 28, United States Code, Section 2461(c), any defendant so
convicted shall forfeit substitute property, up to the total value of
Case 2:20-cr-00579-SVW Document 422-3 Filed 06/04/21 Page 53 of 59 Page ID
#:4680
53
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
the property described in the preceding paragraph if, as the result
of any act or omission of said defendant, the property described in
the preceding paragraph, or any portion thereof: (a) cannot be
located upon the exercise of due diligence; (b) has been transferred,
sold to or deposited with a third party; (c) has been placed beyond
the jurisdiction of the court; (d) has been substantially diminished
in value; or (e) has been commingled with other property that cannot
be divided without difficulty.
Case 2:20-cr-00579-SVW Document 422-3 Filed 06/04/21 Page 54 of 59 Page ID
#:4681
54
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
FORFEITURE ALLEGATION FOUR
[18 U.S.C. §§ 982 and 1028 and 28 U.S.C. § 2461(c)]
74.
Pursuant to Rule 32.2 of the Federal Rules of Criminal
Procedure, notice is hereby given that the United States of America
will seek forfeiture as part of any sentence, pursuant to Title 18,
United States Code, Sections 982 and 1028 and Title 28, United States
Code, Section 2461(c) in the event of the conviction of defendants
RICHARD AYVAZYAN, also known as (“aka”) “Richard Avazian” and “Iuliia
Zhadko,” MARIETTA TERABELIAN, aka “Marietta Abelian” and “Viktoria
Kauichko,” ARTUR AYVAZYAN, aka “Arthur Ayvazyan,” TAMARA DADYAN,
MANUK GRIGORYAN, aka “Mike Grigoryan” and “Anton Kudiumov,” and ARMAN
HAYRAPETYAN, of the offenses set forth in Counts Twenty-One through
Twenty-Five of this First Superseding Indictment.
75.
The defendants, if so convicted, shall forfeit to the
United States of America the following:
a.
all right, title and interest in any and all property,
real or personal, constituting, or derived from, any proceeds
obtained, directly or indirectly, as a result of the offense,
including, but not limited to, certain real property referred to
herein as Residential Property 1 located in the County of Los
Angeles, State of California, APN 2176-029-031, certain real property
referred to herein as Residential Property 2 located in the County of
Los Angeles, State of California, APN 5663-036-033, and certain real
property referred to herein as Residential Property 3 located in the
County of Riverside, State of California, APN 694-331-008;
b.
any personal property used or intended to be used to
commit the offense; and
Case 2:20-cr-00579-SVW Document 422-3 Filed 06/04/21 Page 55 of 59 Page ID
#:4682
55
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
c.
to the extent such property is not available for
forfeiture, a sum of money equal to the total value of the property
described in subparagraphs (a) and (b).
76.
Pursuant to Title 21, United States Code, Section 853(p),
as incorporated by Title 18, United States Code, Sections 982(b) and
1028(g), the defendants, if so convicted, shall forfeit substitute
property, up to the total value of the property described in the
preceding paragraph if, as the result of any act or omission of the
defendant, the property described in the preceding paragraph, or any
portion thereof: (a) cannot be located upon the exercise of due
diligence; (b) has been transferred, sold to or deposited with a
third party; (c) has been placed beyond the jurisdiction of the
court; (d) has been substantially diminished in value; or (e) has
been commingled with other property that cannot be divided without
difficulty.
Case 2:20-cr-00579-SVW Document 422-3 Filed 06/04/21 Page 56 of 59 Page ID
#:4683
56
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
FORFEITURE ALLEGATION FIVE
[18 U.S.C. § 982 and 28 U.S.C. § 2461(c)]
77.
Pursuant to Rule 32.2(a) of the Federal Rules of Criminal
Procedure, notice is hereby given that the United States of America
will seek forfeiture as part of any sentence, pursuant to Title 18,
United States Code, Section 982(a)(1), and Title 28, United States
Code, Section 2461(c), in the event of any defendant’s conviction of
the offenses set forth in any of Counts Twenty-Six through Thirty-Two
of this First Superseding Indictment.
78.
The defendant so convicted shall forfeit to the United
States of America the following:
a.
all right, title and interest in any and all property,
real or personal, involved in such offense, and any property
traceable to such property, including, but not limited to, certain
real property referred to herein as Residential Property 1 located in
the County of Los Angeles, State of California, APN 2176-029-031,
certain real property referred to herein as Residential Property 2
located in the County of Los Angeles, State of California, APN 5663-
036-033, and certain real property referred to herein as Residential
Property 3 located in the County of Riverside, State of California,
APN 694-331-008; and
b.
To the extent such property is not available for
forfeiture, a sum of money equal to the total value of the property
described in subparagraph (a).
Pursuant to Title 21, United States Code, Section 853(p), as
incorporated by Title 18, United States Code, Section 982(b)(1), and
Title 18, United States Code, Section 982(b)(2), any defendant so
convicted shall forfeit substitute property, up to the total value of
Case 2:20-cr-00579-SVW Document 422-3 Filed 06/04/21 Page 57 of 59 Page ID
#:4684
57
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
the property described in the preceding paragraph if, as the result
of any act or omission of said defendant, the property described in
the preceding paragraph, or any portion thereof: (a) cannot be
located upon the exercise of due diligence; (b) has been transferred,
sold to or deposited with a third party; (c) has been placed beyond
the jurisdiction of the court; (d) has been substantially diminished
in value; or (e) has been commingled with other property that cannot
be divided without difficulty. Substitution of assets shall not be
ordered, however, where the convicted defendant acted merely as an
intermediary who handled but did not retain the property in the
course of the money laundering offense unless the defendant, in
committing the offense or offenses giving rise to the forfeiture,
//
//
Case 2:20-cr-00579-SVW Document 422-3 Filed 06/04/21 Page 58 of 59 Page ID
#:4685
58
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
conducted three or more separate transactions involving a total of
$100,000.00 or more in any twelve-month period.
A TRUE BILL
Foreperson
TRACY L. WILKISON
Acting United States Attorney
BRANDON D. FOX
Assistant United States Attorney
Chief, Criminal Division
RANEE A. KATZENSTEIN
Assistant United States Attorney
Chief, Major Frauds Section
DANIEL A. KAHN
Acting Chief, Fraud Section
Criminal Division
United States Department of Justice
KRISTEN A. WILLIAMS
Assistant United States Attorney
Deputy Chief, Major Frauds Section
SCOTT PAETTY
Assistant United States Attorney
Major Frauds Section
BRIAN FAERSTEIN
Assistant United States Attorney
Environmental and Community Safety
Crimes Section
CHRISTOPHER FENTON
Trial Attorney, Fraud Section
Criminal Division
United States Department of Justice
Case 2:20-cr-00579-SVW Document 422-3 Filed 06/04/21 Page 59 of 59 Page ID
#:4686File and source
- File
- gov.uscourts.cacd.813904.422.3.pdf
- Size
- 412,980 bytes
- SHA-256
- e8e41c3c7514b316492f62ceabae7ca5e5dc1f5151e7d011054b0fc142c92e44
- Original
- PACER (login required)