EX PARTE APPLICATION to Modify Conditions of Release Filed by Defendant Arman… — USA v. Ayvazyan et al (Dkt. 553)

Summary

Arman Hayrapetyan, through counsel Jilbert Tahmazian, files an unopposed ex parte application to modify his conditions of release in No. CR 20-579(A)-SVW-6 (C.D. Cal.), Document 553, filed 06/21/21. He asks the court to replace his home confinement condition with standalone monitoring. Counsel's declaration says that in June 2021 Judge Stephen Wilson granted reconsideration of detention (Dkt. No. 444), that a magistrate judge then signed a release order, and that location monitoring restricted him to his home. Counsel says this prevents him from working, and that all other conditions would remain unchanged. He states that the prosecutor and Pretrial Services officers do not oppose the request.

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Ase 2:20-cr-00579-SVW Document 553 _~ ~Filed 06/21/21
#:6594

JILBERT TAHMAZIAN; 143574
TAHMAZIAN LAW FIRM P.C.
1518 West Glenoaks Blvd.,
Glendale, CA 91201

Telephone: (818) 242-8201
Facsimile: (818) 242-8246

Page l1of3 Page ID

Attorney for Defendant,
ARMAN HAYRAPETYAN
UNITED STATES DISCTRICT COURT
CENTERAL DISTRICT OF CALIFORNIA
UNITED STATES OF AMERICA, CASE NO.: CR 20-579(A)-SV W-6
UNOPPOSED EX PARTE APPLICATION
vs TO MODIFY CONDITIONS OF RELEASE:
; DECLARATION OF COUNSEL
ARMAN HAYRAPETYAN,
[PROPOSED ORDER FILED
DEFENDANT. CONCURRENTLY]

Arman Hayrapetyan, by and through counsel, hereby files this unopposed ex parte
application to modify the conditions of release. Specifically, Mr. Hayrapetyan seeks an order

replacing his home confinement condition with standalone monitoring.

This application is based on the attached declaration of counsel.

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Clase 2:20-cr-00579-SVW Document 553 Filed 06/21/21 Page2of3 PageID

#:6595

DECLARATION OF COUNSEL

I, Jilbert Tahmazian, do declare and state:

1. I represent Arman Hayrapetyan in this matter. I am licensed to practice in the State of
California, admitted to practice before this Court.

2. On June 7", 2021 Judge Stephen Wilson granted Mr. Hayrapetyan’s application for
reconsideration of detention. See Dkt. No. 444. After submitting the bond documents to
criminal intake, Magistrate Judge Paul Abrams signed a release order for Mr. Hayrapetyan
on June 8", 2021. As part of his release, Mr. Hayrapetyan was required to be placed on
location monitoring, which restricted him to his home.

3. Mr. Hayrapetyan lives alone and survives off of the income he makes working in ambulatory
transportation. Without this income Mr. Hayrapetyan will be unable to pay his bills.

4. As aresult, I respectfully request that the Court modify the terms on Mr. Hayrapetyan’s bond
to replace the home confinement condition with a stand-alone monitoring condition. This
would allow the defendant to resume employment and, in turn, possess some modicum of
financial stability.

5. All other conditions would remain unchanged.

6. Ihave conferred with Assistant United States Attorney Catherine Ahn and Pretrial Services
Officers Theophile and Kwon regarding the relief sought here. Ms. Ahn, Officer Theophile,

and Officer Kwon indicated that they do not oppose the relief sought in this application.

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fase 2:20-cr-00579-SVW Document553_ Filed 06/21/21 Page 3o0f3 Page ID
#:6596

7. Mr. Samsonian and Ms. Manukyan consent to the modification as wé

Dated: June 16", 2021

A pert TAHMAZIAN,
Attorney for Defendant

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