Declaration of Catherine Ahn — USA v. Ayvazyan et al (Dkt. 476.1)

Summary

A Declaration of Catherine Ahn, Document 476-1 filed 06/09/21 in United States v. Ayvazyan, et. al, CR No. 20-579(A)-SVW, in the Central District of California. Ms. Ahn, an Assistant United States Attorney, makes the declaration in support of the government's ex parte application for permission to file a trial memorandum over 25 pages. She states that there have been 474 docket entries in the case, and that the charges the government must prove include thirty-three counts covering two alleged conspiracies, wire and bank fraud offenses, aggravated identity theft charges, and offenses committed while on pre-trial release. She states that the government's trial memorandum is 37 pages. The declaration is executed on June 9, 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.   
2. 
I make this declaration in support of the government’s ex 
parte application for permission to file a trial memorandum over 25 
pages, as authorized in Central District of California Local Rule 11-
6.  In its trial memorandum, the government describes the factual and 
procedural history of the case, including previously filed and 
pending evidentiary motions and pre-trial motions.  As of the time of 
this filing, there have been 474 docket entries in this case, 
including numerous motions to dismiss, to exclude, and suppress 
evidence.  Furthermore, the charges in this case that the government 
must prove beyond a reasonable doubt at trial include thirty-three 
counts covering two alleged conspiracies, substantive wire and bank 
fraud offenses, aggravated identity theft charges, and offenses 
committed while on pre-trial release.  As a result, the government’s 
factual and procedural history, summary of the evidence, and summary 
of the evidentiary issues raised required additional length to 
describe.  The government’s trial memorandum is 37 pages.  
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 9, 
2021. 
 
 
 
CATHERINE AHN 
 
Case 2:20-cr-00579-SVW     Document 476-1     Filed 06/09/21     Page 1 of 1   Page ID
#:5878

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