Declaration of Catherine Ahn — USA v. Ayvazyan et al (Dkt. 441.1)

Summary

A Declaration of Catherine Ahn, Document 441-1 filed 06/07/21 in United States v. Ayvazyan, et. al, CR No. 20-579(A)-SVW, in the Central District of California. Catherine Ahn, an Assistant United States Attorney, makes the declaration in support of the Government's Reply in Support of the Government's Motion in Limine #2 to Admit Evidence Inextricably Intertwined with the Charged Offenses. She states that the T.D. iPhone Text Excerpts are copies of excerpts of text messages extracted from an Apple iPhone X seized on or about November 5, 2020. She describes Exhibits 1 through 6, including PDF files exchanged in the text message conversation and payroll reports submitted with PPP applications, some filed under seal and some filed publicly with redactions. The declaration is executed on June 7, 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 Reply 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 (filed under seal) is a true and correct copy of 
a PDF file exchanged between “tammy” and “Rich New” in the text 
message conversation described in paragraph 2, with file name “GREEN 
LABEL TAX ID.pdf.”  Exhibit 4 (filed under seal) is also a true and 
correct copy of PDF files exchanged in the same text message 
Case 2:20-cr-00579-SVW     Document 441-1     Filed 06/07/21     Page 1 of 2   Page ID
#:5031

 
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conversation, with file names “EGIA SEPTEMBER 1 PAYSTUB.pdf” and 
“TONY GLEB PAYSTSUB.pdf”.  
4. 
Exhibit 2 (filed under seal) contains are true and correct 
copies of identification documents found at the residence of T. 
Dadyan and A. Ayvazyan that were previously filed under seal as 
Exhibit 8, attached to the Declaration of Chrisopher Fenton (ECF 
207).  Exhibit 2 further contains true and correct copies of images 
found in digital devices 1B21 and 1B17, as described in the exhibit, 
whose user information indicated they belonged to and/or were used by 
A. Ayvazyan and T. Dadyan.  
5. 
Exhibit 3 (filed publicly with redactions) are true and 
correct copies of payroll reports submitted with PPP applications for 
LK Design and Journeymen Construction, and submitted with an EIDL 
application for Mykhail D. DBA MD Acquisition Services.  They have 
been redacted to remove the purported full federal tax identification 
numbers and the purported full addresses of the businesses.  Exhibit 
6 (filed publicly with redactions) is similarly redacted true and 
correct copy of payroll reports submitted with PPP applications for 
Redline Auto Collision Inc., Fiber One Media, Inc., Mod Interiors, 
Inc., and Hart Construction.    
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 June 7, 
2021. 
 
 
 
CATHERINE AHN 
 
Case 2:20-cr-00579-SVW     Document 441-1     Filed 06/07/21     Page 2 of 2   Page ID
#:5032

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