Proposed Order — USA v. Ayvazyan et al (Dkt. 466.1)

Summary

A proposed order granting the parties' Stipulation for Order Pursuant to Fed. R. 502(d), Document 466-1, filed 06/09/21 in United States v. Ayvazyan et al., No. CR 20-579(A)-SVW (C.D. Cal.), for Judge Stephen V. Wilson's signature. It addresses material the Filter Team has identified as potentially privileged and as belonging to Defendants R. Ayvazyan, Terabelian, A. Ayvazyan and T. Dadyan. The order says producing such material dated before October 19, 2020 to Defendants Grigoryan, Hayrapetyan, Paronyan and Vahe Dadyan waives no party's privileges, and that the Filter Team will not produce later material to them or any potentially privileged material to the Prosecution Team. Use is limited to this case, and any party may ask for in camera review. The signature date is blank.

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TRACY L. WILKISON 
Acting United States Attorney 
BRANDON D. FOX 
Assistant United States Attorney 
Chief, Criminal Division 
 
DANIEL S. KAHN 
Acting Chief, Fraud Section 
Criminal Division, U.S. Department of Justice 
 
BENNETT STARNES 
Attorney, Special Matters Unit, Fraud Section 
Criminal Division, U.S. Department of Justice 
1400 New York Avenue NW 
Washington, DC 20530 
Telephone: (202) 616-2684 
Facsimile: (202) 514-0152 
E-mail: 
Bennett.Starnes@usdoj.gov 
 
 
 
 
Attorneys for Plaintiff 
UNITED STATES OF AMERICA 
 
UNITED STATES DISTRICT COURT 
 
FOR THE CENTRAL DISTRICT OF CALIFORNIA 
 
UNITED STATES OF AMERICA, 
Plaintiff, 
v. 
RICHARD AYVAZYAN, 
aka “Richard Avazian” and 
    “Iuliia Zhadko,” 
MARIETTA TERABELIAN, 
  aka “Marietta Abelian” and     
      “Viktoria Kauichko,” 
ARTUR AYVAZYAN, 
aka “Arthur Ayvazyan,” and 
TAMARA DADYAN, 
MANUK GRIGORYAN, 
  aka “Mike Grigoryan,” and 
      “Anton Kudiumov,” 
ARMAN HAYRAPETYAN, 
EDVARD PARONYAN, 
aka “Edvard Paronian” and 
    “Edward Paronyan,” and 
VAHE DADYAN, 
 
Defendants. 
 No. CR 20-579(A)-SVW 
 
[PROPOSED] ORDER GRANTING 
STIPULATION FOR ORDER PURSUANT TO 
FED. R. 502(D) 
  
 
  
 
Case 2:20-cr-00579-SVW     Document 466-1     Filed 06/09/21     Page 1 of 3   Page ID
#:5477

 
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The Court has read and considered the Stipulation for Order 
Pursuant to Fed. R. 502(D) filed by the parties in this matter on 
June 9, 2021.  The Court understands that the parties have identified 
a method of searching and reviewing material that the Filter Team has 
identified as potentially privileged (“Filter Material”).  This 
material has been identified as belonging to Defendants R. AYVAZYAN, 
TERABELIAN, A. AYVAZYAN, and/or T. DADYAN. The court understands that 
the Filter Team has withheld the material from the Prosecution Team 
and from Defendants GRIGORYAN, HAYRAPETYAN, PARONYAN, and VAHE 
DADYAN.  The Court also understands that the defense is concerned 
that using this approach may result in the inadvertent production of 
privileged material, and that no party is waiving any privilege it 
holds.  Therefore, good cause appearing: 
1. 
The production of potentially privileged material dated 
prior to October 19, 2020, by the Filter Team to Defendants 
GRIGORYAN, HAYRAPETYAN, PARONYAN, and VAHE DADYAN does not result in 
a waiver of any party’s privileges.  Such material shall not be 
transmitted by the Filter Team to the Prosecution Team, nor by the 
Filter Team or Co-Defendants to any third parties.  
2.   The Filter Team will not produce potentially privileged 
material dated on or after October 19, 2020 to Defendants GRIGORYAN, 
HAYRAPETYAN, PARONYAN, and VAHE DADYAN. 
3. 
The Filter Team will not produce any potentially privileged 
material to the Prosecution Team.   
4. 
The use of the potentially privileged material by any 
parties other than the potential privilege holder is limited to the 
instant case, barring any subsequent determination that the material 
is not privileged.  
Case 2:20-cr-00579-SVW     Document 466-1     Filed 06/09/21     Page 2 of 3   Page ID
#:5478

 
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5. Nothing in this Order limits the right of any party, 
including the Filter Team, to petition the Court for an in camera 
review of the Potentially Protected Information. 
 
IT IS SO ORDERED. 
 
Dated: June__, 2021 
 
___________________________ 
Hon. Stephen V. Wilson 
United States District Judge 
 
 
 
Case 2:20-cr-00579-SVW     Document 466-1     Filed 06/09/21     Page 3 of 3   Page ID
#:5479

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