SUPPLEMENT to MOTION in Limine to Admit Evidence Inextricably Intertwined with the… — USA v. Ayvazyan et al (Dkt. 506)

Record facts

U.S. District Court for the Central District of California · No. 2:20-cr-00579-SVW · Doc. 506 · 2021-06-11 · Docket on CourtListener

Summary

The government's supplement to its Motion in Limine #2 regarding inextricably intertwined evidence 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 11, 2021 as Doc. 506. Responding to the court's Order re: Pretrial Motions (ECF 478), it identifies exhibits it says fall within the order's categories, such as evidence discussed in relation to PPP and EIDL loans or related to the overall scheme. It describes items from residential searches, including images of cashier's checks, printed check sheets, handwritten notes, a California driver's license and foreign visitor identification documents, in Exhibits 1, 2, 3 and 4 filed under seal. It also presents a table it says shows cash withdrawals of more than $300,000 between April and October of 2020. The 15-page filing carries the /s/ signature of Catherine S. Ahn.

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

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TRACY L. WILKISON 
Acting United States Attorney 
SCOTT M. GARRINGER 
Assistant United States Attorney 
Chief, Criminal Division 
SCOTT PAETTY (Cal. Bar No. 274719) 
CATHERINE AHN (Cal. Bar No. 248286) 
BRIAN FAERSTEIN (Cal. Bar No. 274850) 
Assistant United States Attorneys 
Major Frauds/Environmental and Community Safety Crimes Sections 
1100/1300 United States Courthouse 
312 North Spring Street 
Los Angeles, California 90012 
Telephone: (213) 894-6527/2424/3819 
Facsimile: (213) 894-6269/0141 
E-mail: 
 Scott.Paetty@usdoj.gov 
 
 Catherine.S.Ahn@usdoj.gov 
 
 Brian.Faerstein@usdoj.gov 
 
DANIEL S. KAHN 
Acting Chief, Fraud Section 
Criminal Division, U.S. Department of Justice 
CHRISTOPHER FENTON 
Trial Attorney, Fraud Section 
Criminal Division, U.S. Department of Justice 
1400 New York Avenue NW, 3rd Floor 
Washington, DC 20530 
Telephone: (202) 320-0539 
Facsimile: (202) 514-0152 
 
E-mail: 
  Christopher.Fenton@usdoj.gov 
 
Attorneys for Plaintiff 
UNITED STATES OF AMERICA 
 
UNITED STATES DISTRICT COURT 
 
FOR THE CENTRAL DISTRICT OF CALIFORNIA 
 
 
 
 
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, 
No. CR 20-579(A)-SVW 
GOVERNMENT’S SUPPLEMENT TO ITS 
MOTION IN LIMINE #2 REGARDING 
INEXTRICABLY INTERTWINED EVIDENCE 
Hearing Date: June 11, 2021 
Hearing Time: 1:00 p.m. 
Trial Date:   June 15, 2021 
Location:     Courtroom of the  
             Hon. Stephen V.  
             Wilson  
Case 2:20-cr-00579-SVW     Document 506     Filed 06/11/21     Page 1 of 15   Page ID
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aka “Edvard Paronian” and 
    “Edward Paronyan,” and 
VAHE DADYAN, 
 
Defendants. 
 
 
Plaintiff United States of America, by and through its counsel 
of record, the Acting United States Attorney for the Central District 
of California, Assistant United States Attorneys Scott Paetty, 
Catherine Ahn, and Brian Faerstein, and Department of Justice Trial 
Attorney Christopher Fenton, hereby files this supplement identifying 
the exhibits that contain inextricably intertwined evidence, in 
response to the Court’s June 10, 2021 Order re: Pretrial Motions (ECF 
478 at 15) (“Order”).  
This supplemental filing is based upon the attached memorandum 
of points and authorities, the files and records in this case, and 
such further evidence and argument as the Court may permit. 
Dated: June 11, 2021 
Respectfully submitted, 
 
TRACY L. WILKISON 
Acting United States Attorney 
 
SCOTT M. GARRINGER 
Assistant United States Attorney 
Chief, Criminal Division 
 
      /s/ 
 
CATHERINE S. AHN 
SCOTT PAETTY 
BRIAN FAERSTEIN 
Assistant United States Attorneys 
CHRISTOPHER FENTON 
Department of Justice Trial Attorney 
 
Attorneys for Plaintiff 
UNITED STATES OF AMERICA 
 
 
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TABLE OF CONTENTS 
DESCRIPTION 
PAGE 
 
MEMORANDUM OF POINTS AND AUTHORITIES................................1 
I. 
Category 3 and 4: Evidence Discussed in Relation to Fraud / 
Fraud Scheme (Exhibit 1).......................................2 
II. 
Category 4:  Evidence Related to the Overall Scheme 
(Exhibit 3)....................................................3 
III. Category 4 and Direct Use:  Evidence of the Scheme 
Collocated with Directly Used Identities Evidence (Exhibits 
2 and 4).......................................................7 
IV. 
Defendant’s Use and Withdrawal of Hundreds of Thousands of 
Dollars in Cash from Accounts Related to the Fraud and 
Money Laundering Conspiracies.................................11 
V. 
Conclusion....................................................12 
 
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MEMORANDUM OF POINTS AND AUTHORITIES 
In its June 10, 2021 Order re: Pretrial Motions (ECF 478) 
(“Order”), the Court ruled that “[t]he Government may satisfy its 
burden by showing, for example, that (1) the evidence was used in 
uncharged PPP and EIDL loans; (2) Defendants attempted to use the 
evidence in relation to PPP and EIDL loans; (3) Defendants discussed 
using the particular evidence in relation to PPP and EIDL loans; 
(4) the evidence was otherwise related to the ‘overall scheme’ to 
obtain fraudulent PPP and EIDL loans.”1  Order at 15.   
The government has identified in its attached exhibits evidence 
that would fall into the “reserve identities evidence” category – 
that is, evidence that relates to the possession or use of identities 
of individuals or businesses that were not directly tied to a PPP or 
EIDL loan or related transactions (e.g., bank accounts through which 
laundered funds flowed).  In general, this evidence would fall into 
either a combination of category #3 (Defendants discussed using the 
particular evidence in relation to PPP and EIDL loans) and category 
#4 (evidence otherwise related to the “overall scheme” to obtain 
 
1 The government generally considers evidence that falls into 
category #1 and #2 as “directly used identities” evidence that is not 
part of the evidence the government seeks to admit under an 
inextricably intertwined theory of admissibility.  (Mot. (ECF 384) at 
2.)  As such, the government’s identification efforts focused on 
categories #3 and #4 and exhibits where there was a combination of 
directly used identities evidence and reserve identity evidence 
(“combination exhibits”).  Furthermore, individuals and entities 
whose accounts or identities were used to transfer fraudulent PPP or 
EIDL funds were also considered by the government to fall into the 
category of “directly used” rather than “reserve identities” evidence 
subject to the inextricably intertwined analysis.  This includes, for 
example, images of the “V&D Limo” check sent by text message between 
“tammy” (defendant Tamara Dadyan) and “Rich New” (defendant Richard 
Ayvazyan) to identify where “Rich New” should send “Vahe” – likely 
co-defendant Vahe Dadyan - his wire.  (Mot. at 18-19 (T.D. iPhone 
Excerpt 7) and Exhibit 4 at 3 (filed under seal).)   
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fraudulent PPP and EIDL loans); category #4 on its own; or a 
combination of category #4 and directly used identities evidence 
(combination evidence).  
 
I. 
Category 3 and 4: Evidence Discussed in Relation to Fraud / 
Fraud Scheme (Exhibit 1) 
There are two items of evidence that fall into this category.  
First, images of cashier’s checks being paid to the order of “AM & AM 
Financial Services, Inc.” that were found on defendant Tamara 
Dadyan’s phone (1B21) in the Media/Images section of her device and 
are part of the Government’s Trial Exhibit (“GEX”) 13c.  (See Exhibit 
1 at 1 (all attached exhibits filed under seal).)  This falls into 
the category #3 because – in the text messages also obtained from 
that phone – “tammy” texts “Rich New” a series of images that include 
references to PPP processor Bluevine and attachments containing the 
California Secretary of State Articles of Incorporation for AM & AM 
Financial, as well as a newly obtained IRS Employer Identification 
Number for AM & AM at an address associated with defendants.  (See 
Exhibit 2 at 34, Images 50 and 512 (GEX 10, T.D. iPhone Text Messages 
with “Rich New”).)  Since the co-conspirators would obtain public 
records for business entities and then use or alter EIN documents for 
those entities, evidence related to AM & AM Financial falls into 
category #4, while the discussion of that evidence falls into 
category #3, rendering the cashier’s check a combination of the two.  
Second, handwritten notes were found at the Weddington address 
associated with defendant Tamara Dadyan and Artur Ayvazyan.  (See 
 
2 The government has not included all the GEX 10 attachments due 
to their size, but has included the text message chain and described 
those attachments when appropriate. 
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Exhibit 1 at 2 (included as part of GEX 57).)  In this note, it 
references “[individual name] Disaster loan with her bank account” 
along with a phone number, a possible bank account, and some notes 
regarding that individual’s relative.  Because of the discussion in 
relation to the EIDL program, it falls into category #3, but given 
the similarity it has to the overall scheme and conspiracy to defraud 
– the use by defendants of a name and identity not their own, with 
personal information as well as an account through which EIDL funds 
could flow, this also falls into category #4. 
II. 
Category 4:  Evidence Related to the Overall Scheme (Exhibit 3) 
There are four types of scheme-related evidence from the 
residential searches3 that fall into category #4.  (See Exhibit 3 at 
1-4 (filed under seal).)  These include physical evidence of the ways 
in which defendants created voided checks to use in PPP or EIDL 
applications; the use of numerous different business identities all 
tying back to the same address associated with defendants; 
defendant’s extensive fake identification manufacturing process and 
their use of foreign visitor identities; and their use of online 
accounts to corroborate and open new accounts.   
From GEX 54 (Canoga Residence Search), there are rows of checks 
printed on check paper, including a misprinted set of checks, which 
corroborate the discussion between “tammy” and “Rich New” in which 
the co-conspirators discuss: (1) the need to provide a copy of a 
 
3 The government’s evidence will show that the Canoga residence 
was rented in the name of defendant Manuk Grigoryan, and had the 
synthetic identity “Viktoria Kauichko” on the lease.  Applications 
were also submitted in the name of the synthetic identity “Anton 
Kudiumov” that identified the Canoga address as his residence.  The 
Topeka residence was identified as Richard Ayvazyan and Marietta 
Terabelian’s address, and the Weddington residence was identified as 
Tamara Dadyan and Artur Ayvazyan’s address. 
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voided check with an application; and (2) when “tammy” asks how she 
can make a voided check, “Rich New” tells her how to print one.  (See 
Exhibit 2 at 4 (text message 2468) and 26 (text messages 3988-3990).)   
From GEX 56 (Topeka Residence Search), agents found stacks of 
financial offers directed to the Topeka address and a Genesta address 
where defendants Richard Ayvazyan and Marietta Terabelian lived, but 
the offers are directed to numerous different companies all at the 
same address.  (See Exhibit 3 at 2-3.)  As the PPP and EIDL loan 
applications will show, defendants repeatedly used the same address 
across numerous, purportedly different business applicants.   
From GEX 57 (Weddington Residence Search), there are handwritten 
notes referencing Nerses N. and law enforcement recovered a physical 
California Driver’s License (“CADL”) purportedly belonging to Nerses 
N.  (See Exhibit 3 at 4.)  However, the individual on this version of 
the Nerses N. CADL looks strikingly different from other versions of 
the Nerses N. CADL also found on Artur Ayvazyan’s iPhone and seized 
from the Weddington residence.  Notably, law enforcement further 
found notes on Artur Ayvazyan’s phone with instructions to “please 
use a (sic) old Armenian guy” along with a version of the CADL that 
shows an older Armenian gentleman.  (See Exhibit 3 at 9.)  Although 
Nerses N. is not an identity that the government has identified on 
PPP or EIDL loans or associated financial transactions; this provides 
critical and uniquely detailed and concrete insight into the way the 
co-conspirators were able to obtain the purportedly official but 
actually fake identification cards found in PPP applications 
submitted in furtherance of the charged conspiracy (e.g., the 
synthetic “Anton Kudiumov” CADL).  There is additional evidence of 
false identification card manufacturing that was found at the 
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Weddington residence (see Exhibit 4 at 1-5), which will be further 
discussed below.  Law enforcement also seized a large number of 
foreign visitor identification documents (visas and work-related 
social security cards) at the Weddington residence.  The government’s 
evidence will show that defendants used synthetic identities composed 
of real information about foreign students who visited the United 
States but left and fake information.  These identities included 
“Iulia Zhadko,” “Viktoria Kauichko,” and “Anton Kudiumov.”  
Defendant’s possession of an unusually large amount of foreign 
visitor identification cards in many different names is proof of the 
scheme.  
Law enforcement also found at the Weddington residence images of 
additional identification cards with hand-written notes that appear 
to document the defendant-associated address that was used on the 
CADL, along with notes regarding how defendants intended to use the 
identity and account information.  (See Exhibit 3 at 7 (“currently 
has personal and business / need to add this new business account / 
use all current email and all same contact info & give us online 
access”).)  These notes mirror the ways in which defendants used the 
false or synthetic identities they discussed in the T.D. iPhone text 
messages (GEX 10); one even used the same exact password “Pookie1031” 
used to access the deceased attorney Olaf Landsgaard’s purported 
email (used in the charged real estate transaction, among others) and 
other email accounts apparently used in PPP applications.  (See 
Exhibit 2 at 14 (text messages 3209-3217) and 20 (text messages 3616-
3626).)  
The digital evidence obtained from devices seized during the 
residential searches generally fall into the following categories:   
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• Possession of more checks in individual names and 
businesses not of defendants (Exhibit 3 at 8);  
• Indicia of software to manufacture new identification and 
instructions on how to alter identification cards found in 
Artur Ayvazyan’s iPhone (id. at 9-14);  
• The creation and use of false records, to include false 940 
and 941s in the name of Corrine B. but fraudulently showing 
it had been prepared by A.F., one of the aggravated 
identity theft victims in this case and screenshots on how 
to apply for an EIN online, which we know defendants 
frequently did for entities they used in PPP and EIDL 
applications (id. at 15-16); 
• Photographs of wire receipts and deposit receipts for 
transactions, which we know from the T.D. iPhone messages 
were sent to other co-conspirators as proof a transaction 
had been made (id. at 17); 
• The possession of images of numerous CADL and social 
security cards in other people’s names, including Corrine 
B., whose 940 and 941s that were also found in Artur 
Ayvazyan’s phone fraudulently included the name of A.F., a 
tax preparer identity theft victim of the fraud conspiracy 
(id. at 18-19;   
• An image of a CADL, social security card, and financial 
debit or credit card all in the name of Grigor P. found on 
Richard Ayvazyan’s iPhone (1B85), representing the trifecta 
of information the conspirators needed to execute their 
scheme (identities and accounts in those names to receive 
or transfer fraudulent proceeds) (id. at 20);  
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• The use and possession of identities other than those of 
defendants, as shown by a photographed stack of California 
Employment Development Department envelopes with names 
other than her own on Tamara Dadyan’s iPhone (id. at 21); 
• The sharing of access to and use of databases like TLOxp 
with images from “tammy” to “Rich New” explicitly showing 
that it contains personal identifying information, which 
was used in furtherance of the PPP and EIDL scheme (id. at 
22; see also Mot. at 9); and 
• Evidence of defendant’s use of a Virtual Private Network 
(“VPN”), which would enable defendants to hide or change 
their purported location when accessing the internet (see 
Exhibit 3 at 23). 
III. Category 4 and Direct Use:  Evidence of the Scheme Collocated 
with Directly Used Identities Evidence (Exhibits 2 and 4) 
The text message conversation between “tammy” and “Rich New” is 
a classic example of inextricably intertwined evidence.  (See Exhibit 
24.)  In this discussion, co-defendants Tamara Dadyan and Richard 
Ayvazyan can be seen learning about the PPP and EIDL programs, 
learning how to apply, learning how to fraudulently alter numbers in 
order to obtain approved loans, and then discussing how much and to 
whom the proceeds of the fraud should be distributed.  (See Exhibit 
2.)  Sprinkled throughout this discussion, however, are references to 
additional identities for use or possible use, references to methods 
by which the fraud could be conducted, and attempts to further the 
 
4 Although the government did not attach all of the files or 
images exchanged between the coconspirators, those files would 
include reserve identities evidence falling into this combined 
category and the government seeks its inclusion.  
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scheme by lying to bank or loan officers in order to induce them to 
release proceeds.  It shows evidence of the scheme in the same 
context as directly used identities evidence, and one cannot be 
clearly understood without the other for context.  
The government also seized evidence that was located in the same 
location – the office - at defendant Tamara Dadyan and Artur 
Ayvazyan’s residence.  The government’s emphasis on their collocation 
is not to note that mere possession inside a home is evidence that 
the directly used and the reserve identities evidence is intertwined; 
rather, it is to show that defendants themselves considered these to 
be similar in use or possession enough to keep them in the same 
place.  The fact that it was found in the office – where presumably 
business is conducted – is telling.  
This evidence, which is part of GEX 57, includes numerous 
identification cards, including CADLs that are obviously fraudulent 
due to the multiple versions with different photographs being 
possessed.  (See Exhibit 4 at 1-5.)  Significantly, the seized 
evidence included passport-style photographs of individuals who are 
repeatedly depicted in the seized CADLs, further proving these 
materials as defendants’ literal instruments of fraud in furtherance 
of PPP and EIDL scheme and conspiracies, which rely on the 
availability of false identification documents.  (Id. at 6.)  As 
discussed above, their possession in the same place is indicative of 
their use as a common scheme or fraud.  Furthermore, as indicated in 
the government’s exhibit (marked with a red check), many of these 
identities are for individuals who were directly used by the 
coconspirators in PPP and EIDL loan applications.  As extensively 
discussed above and in its motion and reply (ECF 384 and 441), 
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defendant’s ready access to a supply of individual and business 
identities, with the relevant documentation to support their 
existence, was critical to maintaining the fraud and money laundering 
conspiracies.   
This is also the basis for the government’s argument that the 
email accounts, checks and checkbooks, calendar notes, and additional 
notes are inextricably intertwined.  (See Exhibit 4 at 7-18.)  A 
close review shows that defendants – not the government – included 
the email and online user accounts of directly used identities and 
instruments of fraud, such as Alak M., First Class Property, and the 
TLO account, on a sheet titled “EMAILS” that contained a large number 
of accounts associated with names other than defendants.  (Id. at 
11.)  The same is true of the accounts noted in the “EMAILS FOR 
BORROWERS” sheet found at Tamara Dadyan’s and Artur Ayvazyan’s 
residence.  (Id. at 8-10.)  Notably, the passwords for these accounts 
were often repeats of the password shared by “tammy” to “Rich New” 
for accounts to access emails used for PPP or EIDL applications and 
“Olaf,” the deceased lawyer. (See Exhibit 2 at 14 and 20 
(“pookie1031”).)  Similarly, the checkbooks include accounts in the 
names of entities that were directly used in the fraud and 
conspiracies, including “Medet Murat,” EM Construction Co., and First 
Class Property Management.  (See Exhibit 4 at 12-13.)  They also 
include a checkbook for Nerses N., completing the trifecta of 
defendant’s scheme by which defendants used business and individual 
identities to apply for and obtain fraudulent PPP and EIDL proceeds 
(identification card, social security, and financial account).  (Id. 
at 19.)  The Nerses N. reserve identity evidence is a critical piece 
to enabling the government to prove the manufacturing of fraudulent 
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identities as part of the scheme.  Unlike the other identities, the 
data on Artur Ayvazyan’s phone shows explicit instructions on what 
kind of photograph to use, proving the deliberate creation of false 
CADLs by the coconspirators.   
The calendar pages and notes, however, are even more probative 
of the defendants’ method of manufacturing these individual 
identities and financial profiles to execute the PPP and EIDL fraud 
and money laundering conspiracies.  Peppered throughout these pages 
are notes referencing directly used identities and the 
coconspirators’ methods of fraud.  For example, one calendar page 
alone appears to have a “to do” list of items, including: “Anna 
Dzukaeva – Bluevine / Liberty / Fundbox”; “Send Richard Bluevine 
paper that guy send”; and “do the Alak paper dl / Spyglass Wells [ ] 
mail it in to the Edd”.  (See Exhibit 4 at 14.)  Every page in the 
government’s exhibit contains numerous references to directly used 
identities that are literally on the same page as reserve identities 
evidence in which PPP or EIDL applications are referenced.  (See, 
e.g., “Kopytova DL upload to Bank of West” and the reference to Jack 
Runyan, one of the identity theft victims in this case (Exhibit 4 at 
23-24).)  The “Driscoll” notes are even more explicit, reminding the 
author to “all our EDD – Eoncie / Alak,” “Fix W2 Heros / ABC legal,” 
and “Fix DL I emailed him date on Victoria Babetska and maybe a bank 
statement I tell Ronna her to print 2 one with Victoria name one with 
VOVK US Bank.”  (See Exhibit 4 at 18.)  ABC Legal, Koptoyva, and Alak 
are all names associated with or used for PPP or EIDL applications.   
The government further seized a yellow notepad from the Canoga 
residence, which forms a part of GEX 54, that appears to have a list 
of company names and phone numbers.  (See Exhibit 4 at 19.)  As shown 
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in the text messages in GEX 10 (Exhibit 2), defendants Richard 
Ayvazyan and Tamara Dadyan assigned a phone number to a synthetic 
individual or business identity and relied on coordination to ensure 
that the correct number was answered in the event someone called to 
check the account.  (See Exhibit 2 at 13 (text message 3170), 18 
(text message 3526).)  The coconspirators had numerous phone numbers 
and had to keep track of which number was identified to which 
synthetic, false, or stolen identity.  (Id. at 34 (text messages 
4647-4665).)  Although some of the companies listed were not 
identified by the government as associated with an EIDL or PPP loan 
(“Hupp”), many of the names listed were (“Sabala”) and the sheet 
provides further evidence of the manner in which defendants were able 
to conspire to perpetrate their fraud.  As such, it is inextricably 
intertwined with the fraud and money laundering conspiracies. 
IV. 
Defendant’s Use and Withdrawal of Hundreds of Thousands of 
Dollars in Cash from Accounts Related to the Fraud and Money 
Laundering Conspiracies 
The government has identified numerous bank accounts in the 
names of defendants and the synthetic identities used by them in the 
PPP and EIDL fraud and money laundering conspiracies.  As shown in 
the table below, defendants likely made significant cash withdrawals 
from these accounts, totaling more than $300,000, during the relevant 
timeframe.  The column noted as “cash” shows direct cash withdrawals 
from these accounts; the casino/gaming column shows withdrawals from 
ATMs at gaming facilities or the conversion cash to gaming chips; and 
the “withdrawals” column indicate withdrawals that were accompanied 
by a withdrawal slip, indicating a likely cash withdrawal.  Based on 
these figures, it appears that the defendants likely withdrew in cash 
Case 2:20-cr-00579-SVW     Document 506     Filed 06/11/21     Page 14 of 15   Page ID
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or cash equivalents totaling more than $300,000 between April and 
October of 2020.  
As such, the government believes there is a sufficient 
contextual or substantive connection between the bag of cash and the 
charged offenses, and respectfully requests admittance of the 
photographs of cash found at defendant Richard Ayvazyan and Marietta 
Terabelian’s residence.  
V. 
Conclusion 
For the reasons described above, the reserve identities evidence 
the government seeks to admit at trial is inextricably intertwined 
with the fraud and money laundering conspiracies and should be 
admitted.  The government respectfully requests the Court grant its 
motion in limine and admit the evidence described and attached to 
this supplement to the government’s motion in limine. 
 
 
 
 
Case 2:20-cr-00579-SVW     Document 506     Filed 06/11/21     Page 15 of 15   Page ID
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