Court filing
Exhibit KX28 — USA v. Ayvazyan et al (Dkt. 854.27)
Summary
Exhibit KX28, Document 854-27, filed 08/04/21 in United States v. Ayvazyan et al., No. 2:20-cr-00579-SVW (C.D. Cal.), is an IRS Criminal Investigation Memorandum of Interview dated February 18, 2021, prepared February 19, 2021 by Special Agent Geffrey Clark. It records an interview of the former legal assistant to attorney Olaf Landsgaard, who was employed at his law office from May of 2017 to July of 2019. She said she did not recognize Richard Ayvazyan, Marietta Terabelian, Tamara Dadyan, Arthur Ayvazyan or the other names put to her as clients, and that an email attributed to the office could not have come from it because the office had been closed since July of 2019. The remaining pages hold attachments, including an email she provided. The cover says filed under seal.
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Record facts
| Court | U.S. District Court for the Central District of California |
|---|---|
| Filed | 2021-08-04 |
Cite this document
“Exhibit KX28 — USA v. Ayvazyan et al (Dkt. 854.27).”
U.S. District Court for the Central District of California, No. 2:20-cr-00579-SVW, Doc. 854-27, filed 2021-08-04. Archived at Pandemic Darlings, https://pandemicdarlings.com/court-filings/full-docket-arman-hayrapetyan-cacd-813904/2021-08-04-gov-uscourts-cacd-813904-854-27-doc-854-27/
, SHA-256 fccc70c352aa7bfdebc600e27d1d5bcf2fa6416113b3f034063b2e27601f42e9.Full text
EXHIBIT KX28 (FILED UNDER SEAL) Case 2:20-cr-00579-SVW Document 854-27 Filed 08/04/21 Page 1 of 12 Page ID #:15212 Memorandum Page 1 of 4 U.S. Treasury Criminal Investigation DEPARTMENT OF THE TREASURY Internal Revenue Service Criminal Investigation Memorandum of Interview Investigation #: 1000306931 Location: Gamero Residence Investigation Name: Richard Ayvazyan 6331 Prarie Ct. Lancaster CA. 93536 Date: February 18, 2021 661-305-3467 Time: ~2:49pm - ~3:21pm Participant(s): Rosaura Gamero, Legal Assistant to Olaf Landsgaard, Esq. Geffrey Clark, Special Agent Rodolfo Mendoza, Special Agent On the above date and time, Special Agent (SA) Geffrey Clark and SA Rodolfo Mendoza arrived at the above address. SA Clark and SA Mendoza introduced themselves to Rosaura Gamero (GAMERO) as Special Agents with the Internal Revenue Service-Criminal Investigation and displayed our credentials for her inspection. SA Clark explained that they wished to speak with her regarding her employment at Olaf Landsgaard law practice. GAMERO acknowledged that she has received a call from Cecilia Fisher, Olaf Landsgaard’s (Landsgaard) sister, requesting her to contact SA Clark about her employment with Landsgaard. GAMERO requested SA Clark’s business card and stated that because of all of the scams going on she has placed a call to a friend of hers that works for the DEA to confirm SA Clark’s identity. After easing GAMERO’s concerns regarding the agent’s identity, GAMERO invited the agents into her residence and provided the following information: 1. GAMERO was employed by Landsgaard’s law offices as his legal assistant / paralegal from May of 2017 to July of 2019. Landsgaard suffered a heart attack and died on April 23, 2019. GAMERO attended the funeral. Landsgaard is buried in the cemetery located on 70th West and West L Avenue (Good Shepherd Catholic Cemetery). After Landsgaard passing GAMERO was retained by the administrator, Mark Kramer, to assist with transfer of active cases and clients to other law practices and to close up the law practice. Most cases were transferred to David Gonor of Shaffer & Gonor (Encino, California). Civil cases were transferred to Mike Zuckerman and estate attorney. 2. Landsgaard was well known in the Rosemond community. He attended Rosemond High School and was a board member for the local water district. Gamero stated that he was active in the community and provided his services for many in the community. 3. Landsgaard practiced law in the areas of criminal, contract, civil, personal injury, and estate planning. He did not deal with employment law. He did review escrow documents related to business purchases, sales, and transfers DOJ_PROD1_0000000122 KX28_001 Case 2:20-cr-00579-SVW Document 854-27 Filed 08/04/21 Page 2 of 12 Page ID #:15213 Memorandum Page 2 of 4 U.S. Treasury Criminal Investigation for clients. She recalled that he did review a few escrow documents for home purchases for friends of his. 4. As Landsgaard’s legal assistant she would assist in the preparation with letters, documents, motions, discovery, and legal documents to filed for court. Landsgaard had all types of clients. 5. There were two employees, including her, at the law practice. GAMERO was Landsgaards direct legal assistant and Christinayah Bowman was the receptionist. Since Landsgaard also owned the airport (Rosamond Skypark) and surrounding lots, which the law office was located on, Bowman also handled the business that was associated with the operation activities of the airport. The law office and airport business operated separately. She believed the law office was a LLC. 6. Landsgaard’s brother Henry Landsgaard, an emergency room physician in Colorado, took over the operation of the airport since Landsgaard’s passing. 7. GAMERO stated the only law office of Landsgaard was located at 4171 Knox Avenue in Rosemond. GAMERO stated all documents and letters that indicated the address of the law office always included P.O. Box 2567 before the street address. Mail was never delivered to the law office. GAMERO recalled mail related to the airport operations was delivered to the office. Landsgaard and his sister Cecilia (Cici) Fisher were the only ones that had access to the P.O. Box. The P.O. Box was located at the post office. 8. Most of Landsgaard’s clients were located in Rosemond, Lancaster, and Mojave. He did have some clients in the San Fernando Valley and Sylmar. GAMERO recalled that Sylmar client was Araseli Sanchez. 9. GAMERO did not recognize the following names as clients of Landsgaard: • Richard Ayvazyan • Marietta Terabelian • Tamara Dadyan • Arthur Ayvazyan • Anton Kudimov • Iulia Zhadko • Victoria Kauichko. 10. She stated that those would have been names that she would have recalled as clients of Landsgaard. GAMERO stated that she retained a list of Landsgaard’s clients that she could compare the names to. 11. GAMERO provided the following emails, which were located on her cell phone, that Landsgaard used. DOJ_PROD1_0000000123 KX28_002 Case 2:20-cr-00579-SVW Document 854-27 Filed 08/04/21 Page 3 of 12 Page ID #:15214 Memorandum Page 3 of 4 U.S. Treasury Criminal Investigation • AEROLEX@GNET.COM • Olaf@Olaflegal.com • Olaf@Olaflandsgard.com 12. GAMERO stated that an Elisa Ramirez did not work for Landsgaard as a paralegal while she was employed there. She informed the agents that she was Landsgaards legal assistant / paralegal. GAMERO did recall that Landsgaards niece, Regan Fisher, worked at the law office at times. She clarified her earlier statement and indicated that at times there were three employees at the law office. GAMERO was shown an email which represented communication from Landsgaard’s law office from an Elisa Ramirez (attached BHE). 13. GAMERO stated that the email address was not Landsgaard’s, Elisa Ramirez did not work at the office, and that the font style was not used at the law office. The font style was more professional like the Arial style. GAMERO additionally stated that the email, indicating that is was sent July 24, 2020, could not have come from Landsgaards office because the law office had been closed since July of 2019. 14. There was not an inhouse notary at the law office. The office used FNU Gonzalez when they needed a notary. Rubin is her husband, 661-713-9718. The law office never used a woman by the name of Leslie Casillas. 15. The accountant for the law firm was Laura Velasquez. Annette LNU was the accountant before Velasquez. 16. GAMERO provided the following as samples / examples of documents bearing Landsgaards writing style, address, and letterhead (attached) • Email, Updated Retainer • Superior Court of California filing • Letter March 17, 2019 • Letter March 29, 2018 • Email, April 19, 2019 I prepared this memorandum on February 19, 2021, after refreshing my memory from notes made during and immediately after the interview with Rosaura Gamero. Geffrey Clark Special Agent DOJ_PROD1_0000000124 KX28_003 Case 2:20-cr-00579-SVW Document 854-27 Filed 08/04/21 Page 4 of 12 Page ID #:15215 Memorandum Page 4 of 4 U.S. Treasury Criminal Investigation DOJ_PROD1_0000000125 KX28_004 Case 2:20-cr-00579-SVW Document 854-27 Filed 08/04/21 Page 5 of 12 Page ID #:15216 DOJ_PROD1_0000000126 KX28_005 Case 2:20-cr-00579-SVW Document 854-27 Filed 08/04/21 Page 6 of 12 Page ID #:15217 DOJ_PROD1_0000000127 KX28_006 Case 2:20-cr-00579-SVW Document 854-27 Filed 08/04/21 Page 7 of 12 Page ID #:15218 DOJ_PROD1_0000000128 KX28_007 Case 2:20-cr-00579-SVW Document 854-27 Filed 08/04/21 Page 8 of 12 Page ID #:15219 DOJ_PROD1_0000000129 KX28_008 Case 2:20-cr-00579-SVW Document 854-27 Filed 08/04/21 Page 9 of 12 Page ID #:15220 DOJ_PROD1_0000000130 KX28_009 Case 2:20-cr-00579-SVW Document 854-27 Filed 08/04/21 Page 10 of 12 Page ID #:15221 DOJ_PROD1_0000000131 KX28_010 Case 2:20-cr-00579-SVW Document 854-27 Filed 08/04/21 Page 11 of 12 Page ID #:15222 Rosaura Gamero <rgamero.legal@gmail.com> Process Service 1 message Rosaura Gamero <rgamero.legal@gmail.com> Fri, Apr 19, 2019 at 1:33 PM To: "Wayne A. Luke" <wayne@lukepi.com> Please serve the attached subpoena to the payroll company in Lancaster. thank you. -- Rosaura Gamero Legal Assistant to Olaf Landsgaard, Esq. Law Offices of Olaf Landsgaard 4171 Knox Avenue P.O. Box 2567 Rosamond, CA 93560 (661) 256-9271 tel. (661) 256-9212 fax Source One Payroll Subpoena.pdf 147K DOJ_PROD1_0000000132 KX28_011 Case 2:20-cr-00579-SVW Document 854-27 Filed 08/04/21 Page 12 of 12 Page ID #:15223
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