Second Request for Extension of Time — USA v. Ayvazyan et al. (Dkt. 804, C.D. Cal.)

Summary

Through attorney Jilbert Tahmazian, Arman Hayrapetyan filed this request on 07/27/21 (Document 804, Case No. CR 20-579(A)-SVW) for a minimum 30-day extension of a release condition: the deadline for surety Evelina Manukyan to replace an affidavit of surety without justification for $50,000 with a full deeding of property. Counsel's declaration says Judge Stephen Wilson granted reconsideration of detention (Dkt. No. 444), Magistrate Judge Paul Abrams then signed a release order, and Judge Wilson later extended the original deadline for the surety (Dkt. No. 660). It says the continued impact of the coronavirus on the County recorder's office made the deadline impossible to meet and that an appraisal of the home has been ordered, with all other conditions to remain unchanged.

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Case 2:20-cr-00579-SVW Document 804 Filed 07/27/21 Page 1 of 3 Page ID
#:13586
1 || JILBERT TAHMAZIAN; 143574
TAHMAZIAN LAW FIRM P.C.
2 || 1518 West Glenoaks Blvd.,
Glendale, CA 91201
Telephone: (818) 242-8201
4 || Facsimile: (818) 242-8246
Attorney for Defendant,
5 |} ARMAN HAYRAPETYAN
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UNITED STATES DISCTRICT COURT
7 CENTERAL DISTRICT OF CALIFORNIA
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9 UNITED STATES OF AMERICA, CASE NO.: CR 20-579(A)-SVW
10 REQUEST FOR EXTENSION OF BOND
CONDITON
ARMAN HAYRAPETYAN, [PROPOSED ORDER FILED
12 CONCURRENTLY]
3 DEFENDANT.
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15 . .
Arman Hayrapetyan, by and through counsel, hereby files this request for extension for a
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condition of his release. Specifically, Mr. Hayrapetyan seeks a minimum 30-day extension for the
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18 July 30", 2021 deadline of having surety Evelina Manukuyan replace the affidavit of surety without
19 ||Justification for the amount of $50,000 with a full deeding of property’.
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This application is based on the attached declaration of counsel.
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' The property in question is located at 67110 Garbino Road, Cathedral City, CA 92234.
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Case 2:20-cr-00579-SVW Document 804 Filed 07/27/21 Page 2 of 3 Page ID
#:13587
1 DECLARATION OF COUNSEL
2 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
7 reconsideration of detention. See Dkt. No. 444. After submitting the bond documents to
8 criminal intake, Magistrate Judge Paul Abrams signed a release order for Mr. Hayrapetyan
9 on June 8", 2021.
10 3. As part of his release, Mr. Hayrapetyan had a surety—Evelina Manukyan—-sign an affidavit
i of surety without justification for the amount of $50,000 to be replaced with a surety with
justification and a full deeding of property.2
14 4. The abovementioned condition was ordered to be met and posted by June 25", 2021.
15 5. Judge Wilson granted an extension for the deadline of having the surety without justification
16 for the amount of $50,000 to be replaced with a surety with justification and a full deeding
17 of property from June 25", 2021 to July 30", 2021 [See Dkt. No. 660]
18 6. However, given the continued impact of the coronavirus on the County recorder’s office, it
9 has not been possible to fulfill this obligation in the amount of time afforded to Mr.
Hayrapetyan by this court.
79 7. An appraisal has already been ordered on the home and the accompanying appraisal report
33 will likely be ready in the coming days.
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% * The property in question is located at 67110 Garbino Road, Cathedral City, CA 92234.
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Case 2:20-cr-00579-SVW Document 804 Filed 07/27/21 Page 3 of 3 Page ID
#:13588
1 8. The Court, in its first release order, [See Dkt. No. 444; pg. 4] noted—under the “other
2 conditions” subsection—that the deadline may be extended with Court order.
9. Accordingly we respectfully ask that the Court order an extension given the circumstances.
10. All other conditions would remain unchanged.
Dated: July 27", 2021 Respectfully Submitted,
8 BY:
9 JILBERT TAHMAZIAN,
10 Attorney for Defendant
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