Court filing
TRANSCRIPT filed as to Defendant Arman Hayrapetyan for proceedings held on June 4,… — USA v. Ayvazyan et al (Dkt. 866)
Record facts
| Court | U.S. District Court for the Central District of California |
|---|---|
| Filed | 2021-08-12 |
U.S. District Court for the Central District of California · No. 2:20-cr-00579-SVW · Doc. 866 · 2021-08-12 · Docket on CourtListener
Summary
A reporter's transcript of a change of plea hearing in United States v. Arman Hayrapetyan, No. CR 20-579-SVW, held June 4, 2021 in Los Angeles before the Honorable Stephen V. Wilson of the U.S. District Court for the Central District of California, filed August 12, 2021 as Document 866. The defendant withdraws his not guilty plea and pleads guilty to Count 26 of the First Superseding Indictment, which the transcript describes as charging conspiracy to commit money laundering. An Armenian interpreter assists throughout the hearing. The court conducts the plea colloquy, covering voluntariness, the defendant's satisfaction with counsel, the signing and translation of the plea agreement, and the trial rights given up. Scott Paetty appears for the government and Jilbert Tahmazian for the defendant; the transcript is 47 pages and ends with a word index.
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
Full text
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P a t C u n e o C S R 1 6 0 0 , O f f i c i a l R e p o r t e r
UNITED STATES DISTRICT COURT
CENTRAL DISTRICT OF CALIFORNIA
WESTERN DIVISION
THE HONORABLE STEPHEN V. WILSON, JUDGE PRESIDING
UNITED STATES OF AMERICA, )
)
Plaintiff,
)
)
vs.
) NO. CR 20-579-SVW
)
ARMAN HAYRAPETYAN,
)
)
Defendant.
)
___________________________________)
REPORTER'S TRANSCRIPT OF PROCEEDINGS
Los Angeles, California
Friday, June 4, 2021, 11:33 A.M.
Change of Plea Hearing
PAT CUNEO CSR 1600, CRR-CM
Official Reporter
First Street Courthouse
350 West 1st Street
Room 4311
Los Angeles, CA 90012
213-894-1782
patcuneo1600@gmail.com
www.patcuneo.com
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Case 2:20-cr-00579-SVW Document 866 Filed 08/12/21 Page 1 of 47 Page ID
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P a t C u n e o C S R 1 6 0 0 , O f f i c i a l R e p o r t e r
APPEARANCES:
FOR THE PLAINTIFF: TRACY L. WILKISON
ACTING UNITED STATES ATTORNEY
BY: SCOTT PAETTY
ASSISTANT UNITED STATES ATTORNEY
United States Courthouse
312 North Spring Street
Los Angeles, California 90012
FOR THE DEFENDANT: TAHMAZIAN LAW FIRM PC
BY: JILBERT TAHMAZIAN
ATTORNEY AT LAW
1518 West Glenoaks Boulevard
Glendale, California 91201
818-242-8201
jilbert@jilbertlaw.com
ALSO PRESENT: MAGDALINA AVETISYAN
ARMENIAN INTERPRETER
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Case 2:20-cr-00579-SVW Document 866 Filed 08/12/21 Page 2 of 47 Page ID
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P a t C u n e o C S R 1 6 0 0 , O f f i c i a l R e p o r t e r
LOS ANGELES, CALIFORNIA; FRIDAY, JUNE 4, 2021; 11:33 A.M.
-oOo-
THE CLERK: Good afternoon, Your Honor.
THE COURT: Good afternoon, Paul.
THE CLERK: May I call the case?
THE COURT: Yes.
THE CLERK: Counsel, we're here before the
Honorable Stephen V. Wilson in Criminal Matter 20-579-SVW,
United States of America vs. Arman Hayrapetyan.
Counsel, please state your appearances.
MR. PAETTY: Good morning, Your Honor.
Scott Paetty for the United States.
MR. TAHMAZIAN: Good morning, Your Honor.
Jilbert Tahmazian for Mr. Hayrapetyan, Your Honor.
THE CLERK: The defendant will please state his
name.
THE DEFENDANT: Arman Hayrapetyan.
THE CLERK: Is that your true and correct name?
THE DEFENDANT: Yes.
THE CLERK: Is it now your intention to withdraw
your not guilty plea so that you can enter a plea of guilty
to Count 26 of the First Superseding Indictment?
THE DEFENDANT: Yes.
THE CLERK: How do you now plead to Count 26 of
the First Superseding Indictment; guilty or not guilty?
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Case 2:20-cr-00579-SVW Document 866 Filed 08/12/21 Page 3 of 47 Page ID
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P a t C u n e o C S R 1 6 0 0 , O f f i c i a l R e p o r t e r
THE DEFENDANT: Guilty.
THE CLERK: The Court is going to ask you some
questions while under oath.
THE COURT: I didn't hear the answer.
THE INTERPRETER: This is the interpreter. The
answer was "guilty."
THE COURT: Go ahead.
THE CLERK: The Court is going to ask you some
questions while under oath.
Can you raise your right hand?
THE DEFENDANT: (Complies.)
THE CLERK: Do you solemnly swear that the answers
you make to the questions asked of you by the Court shall be
the truth, the whole truth, and nothing but the truth, so
help you God?
THE DEFENDANT: Yes.
THE CLERK: Thank you.
THE COURT: Madam Interpreter, when you address
the Court, would it be possible for you to take that device
away from your mouth so I can see you better?
THE INTERPRETER: Sure. It's just I'm talking
with this device with him only and I am muting myself when I
speak Armenian.
THE COURT: Do it as best for yourself. I
understand.
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P a t C u n e o C S R 1 6 0 0 , O f f i c i a l R e p o r t e r
All right. Go ahead.
THE CLERK: The defendant pled guilty and has been
sworn, Your Honor, and we can proceed with the proceeding.
THE COURT: All right. So, Mr. Hayrapetyan, is
that the correct pronunciation? Hayrapetyan?
Is that correct, Mr. Tahmazian? Hayrapetyan?
MR. TAHMAZIAN: It's actually Hayrapetyan.
THE COURT: All right. Hayrapetyan. Okay.
Mr. Hayrapetyan, I'm going to ask you some
questions which are designed to assure me that your guilty
plea is freely and voluntarily made and that there is a
factual basis for your guilty plea.
THE DEFENDANT: Yes.
THE COURT: Have you had enough opportunity to
discuss this case with your lawyer Mr. Tahmazian and have
you considered all possible defenses?
THE DEFENDANT: Yes.
THE COURT: Are you satisfied with Mr. Tahmazian's
representation?
THE DEFENDANT: Yes. Very much so.
THE COURT: Has anyone made any threats or
promises to induce you to plead guilty other than the plea
agreement you've reached with the government?
THE DEFENDANT: No.
THE COURT: My copy of the plea agreement shows
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P a t C u n e o C S R 1 6 0 0 , O f f i c i a l R e p o r t e r
that you signed it on May 25th of this year. Is that
correct?
THE DEFENDANT: That's correct.
THE COURT: And before you signed the plea
agreement, was it translated to you in the Armenian
language?
MR. TAHMAZIAN: Your Honor, I apologize to
interrupt but he signed it after I spoke to him and told him
what it is. It was translated through telephone by a
certified interpreter two days later on May 27th. That's
how it went.
THE COURT: And --
THE DEFENDANT: That's correct.
THE COURT: And so when you signed the plea
agreement, it was on the basis of what your lawyer
Mr. Tahmazian explained to you was in the plea agreement;
correct?
THE DEFENDANT: That's correct.
THE COURT: And, Mr. Tahmazian, when you explained
on the telephone as you've described it to your client what
was in the plea agreement, can you tell me what you told
him?
MR. TAHMAZIAN: Yes, Your Honor. Actually, I met
him in jail on two separate occasions.
THE COURT: Let me just ask you first. Are you
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P a t C u n e o C S R 1 6 0 0 , O f f i c i a l R e p o r t e r
fluent in the Armenian language?
MR. TAHMAZIAN: Yes, Your Honor, I am.
THE COURT: And is that because of your study of
the language or from family or how is it that you're
familiar with it?
MR. TAHMAZIAN: From family, from having spoken
the language for many years, and having 90 percent Armenian
clientele for 32 years, Your Honor, I've become very fluent
in the language.
And for the Court's information, I met him twice
in court -- in jail. I went over the plea agreement, every
page, before he signed on the 25th of May.
Then on May 27th, I arranged for a certified
court interpreter in my presence in my office on telephone
translate every single word of the plea agreement to him on
the date that he signed off, May 27th, Your Honor.
THE COURT: And as you listened to the translator
read the plea agreement to him, was the plea agreement any
different than the way you read it to him?
MR. TAHMAZIAN: No, Your Honor.
THE COURT: And so you are totally satisfied based
upon what you said that he understood the plea agreement?
MR. TAHMAZIAN: Yes, Your Honor.
THE COURT: And I take it that in your
conversations with him, as any nonlawyer would think, there
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P a t C u n e o C S R 1 6 0 0 , O f f i c i a l R e p o r t e r
would be questions about the plea agreement.
Did you go back and forth with him when he had
questions about the plea agreement?
MR. TAHMAZIAN: Yes, Your Honor. On more than one
occasion.
THE COURT: I see. And did he appear to you to
understand the plea agreement?
MR. TAHMAZIAN: Yes, Your Honor.
THE COURT: And Mr. --
MR. TAHMAZIAN: Hayrapetyan, Your Honor.
THE COURT: I wrote it phonetically so I don't
mispronounce it.
Mr. Hayrapetyan, do you agree that the meetings
that you had with your lawyer, as he described it, occurred?
THE DEFENDANT: I agree. Yes, exactly right.
THE COURT: And was there any difference in your
mind between what Mr. Tahmazian described the plea agreement
to be in the telephone conversations he had with you before
you signed the agreement and the translation by the
interpreter two days later?
THE DEFENDANT: No, the translation was fine.
Everything was normal.
THE COURT: All right. Have you taken any drugs
or medications in the last 24 hours?
THE DEFENDANT: No, never.
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Case 2:20-cr-00579-SVW Document 866 Filed 08/12/21 Page 8 of 47 Page ID
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P a t C u n e o C S R 1 6 0 0 , O f f i c i a l R e p o r t e r
THE COURT: Are you thinking clearly today?
THE DEFENDANT: That's correct.
THE COURT: And you realize that today is a very
important day because you're pleading guilty to very serious
charges. Have you given this adequate thought?
THE DEFENDANT: Yes.
THE COURT: We're now going to ask Mr. Paetty to
review parts of the plea agreement in this specific order:
First, the maximum penalty.
Second, the elements of the offense or offenses to
which he is pleading guilty.
Third, the constitutional rights he's waiving by
pleading guilty.
Fourth, a summary of the important points of the
plea agreement, that is, the bargain between the government
and the defendant; what the government is agreeing to do, if
anything, for the defendant regarding the plea and what
requirements the defendant has on his aspect of the
agreement.
And then finally, the factual basis.
Would you please do that, Mr. Paetty, in that
order.
MR. PAETTY: Yes, Your Honor.
The statutory maximum sentence that the Court can
impose for conspiracy to commit money laundering is 20
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Case 2:20-cr-00579-SVW Document 866 Filed 08/12/21 Page 9 of 47 Page ID
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P a t C u n e o C S R 1 6 0 0 , O f f i c i a l R e p o r t e r
years' imprisonment, a three-year period of supervised
release, a fine of $500,000, or twice the gross gain or
gross loss resulting from the offense, whichever is
greatest, and a mandatory special assessment of $100.
For defendant to be guilty of the crime charged in
count 26 of the Superseding Indictment which charges him
with conspiracy to commit money laundering, the following
must be true:
1. Defendant agreed with one or more
coconspirators to knowingly conduct a financial transaction
involving property that represented the proceeds of wire
fraud and/or bank fraud.
2. Defendant knew that the property represented
the proceeds of some form of unlawful activity.
And 3. Defendant knew that the transaction was
designed in whole or in part to conceal or disguise the
nature, location, source, ownership, or control of the
proceeds of such unlawful activity.
By pleading guilty, the defendant gives up the
following rights:
The right to persist in a plea of not guilty.
The right to a speedy and public trial by jury.
The right to be represented by counsel.
And, if necessary, have the Court appoint counsel
at trial.
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Case 2:20-cr-00579-SVW Document 866 Filed 08/12/21 Page 10 of 47 Page ID
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P a t C u n e o C S R 1 6 0 0 , O f f i c i a l R e p o r t e r
Defendant understands, however, that he retains
the right to be represented by counsel and, if necessary,
have the Court appoint counsel at every other stage of the
proceedings.
He gives up the right to be presumed innocent and
to have the burden of proof placed on the government to
prove him guilty beyond a reasonable doubt.
The right to confront and cross-examine witnesses
against him.
The right to testify and to present evidence in
opposition to the charges including the right to compel the
attendance of witnesses to testify.
The right not to be compelled to testify and, if
defendant chose not to testify or present evidence, to have
that choice not be used against him.
And he gives up any and all rights to pursue any
affirmative defenses, Fourth Amendment or Fifth Amendment
claims, or other pretrials motions that have been or could
be filed.
The plea agreement here, Your Honor, is binding on
the parties but not on the Court; and in the agreement the
defendant agrees to the following among other things:
To plead guilty to Count 26 of the Superseding
Indictment charging him with conspiracy to commit money
laundering.
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P a t C u n e o C S R 1 6 0 0 , O f f i c i a l R e p o r t e r
To consent to all court appearances except
sentencing by video teleconference.
To cooperate with the government as outlined in
paragraph 4 and in paragraph 8 of the agreement to
applicable sentencing factors that include a base offense
level of 22 and a plus 2 enhancement for a money laundering
conviction and a limited waiver of appeal of his conviction
and sentence as stated in the plea agreement.
And the government agrees to dismiss all remaining
counts against the defendant at the time of sentencing.
To recommend a three-level reduction in the
guidelines at sentencing provided defendant demonstrates
acceptance of responsibility.
To make a low-end sentencing recommendation and to
consider the possibility, depending on the circumstances
that exist at the time of sentence, to make a motion under
5K1.1 of the sentencing guidelines.
Additionally, there is no agreement with regard to
criminal history or criminal history category.
If this case were to proceed to trial, the
government would be prepared to prove beyond a reasonable
doubt, among other things, beginning in or around March 2020
and continuing at least until in or around October 2020 --
THE COURT: One second. You're not following the
direction.
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P a t C u n e o C S R 1 6 0 0 , O f f i c i a l R e p o r t e r
MR. PAETTY: What was that?
THE COURT: I had a specific direction. Well,
maybe you did. I have to apologize. I think you did review
the maximum penalty, the elements, the constitutional
rights, and you did describe -- (screen frozen, no sound).
MR. TAHMAZIAN: I think the judge froze.
MR. PAETTY: Your Honor, I believe the image is
frozen.
THE COURT: Can you hear me now?
MR. PAETTY: Yes, Your Honor.
THE COURT: What I said was (screen frozen, no
sound).
MR. PAETTY: Your Honor, I believe you're frozen
again.
(Pause in the proceedings.)
MR. PAETTY: Paul, can you hear me?
THE CLERK: Your Honor, you froze up twice. Do
you want to sign on -- sign off and sign back on? You seem
to be -- you seem to be okay now.
THE COURT: Okay. Can you hear me now?
MR. PAETTY: Yes, Your Honor.
THE COURT: Okay. What I said before was I think
I made an error. You had in fact reviewed the first four
instructions that I gave, that is, the maximum penalty, the
elements, the constitutional rights, and the essence of the
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P a t C u n e o C S R 1 6 0 0 , O f f i c i a l R e p o r t e r
plea agreement.
And you now were going to go to the factual basis
when I interrupted you improperly. So proceed to the
factual basis.
MR. PAETTY: Yes, Your Honor.
If this case were to proceed to trial, the
government would be prepared to prove beyond a reasonable
doubt, among other things, that beginning in or around
March 2020 and continuing at least in or around
October 2020, defendant together with coconspirators known
and unknown including Manuk Grigoryan and others,
collectively coconspirators, knowingly engaged in a money
laundering conspiracy, the object of which was to transfer
the illicit proceeds of a scheme in order to conceal the
nature, source, location, ownership, and control of those
proceeds.
These proceeds constituted fraudulently obtained
disaster relief funds under the Paycheck Protection Program,
PPP, and Economic Injury Disaster Loan Program, EIDL, two
federal relief programs that were created through the
Coronavirus Aid, Relief, and Economic Security Act, a
federal law that was enacted in or around March 2020 and it
was designed to provide emergency financial assistance to
Americans suffering economic harm as a result of the
Covid-19 pandemic.
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Case 2:20-cr-00579-SVW Document 866 Filed 08/12/21 Page 14 of 47 Page ID
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P a t C u n e o C S R 1 6 0 0 , O f f i c i a l R e p o r t e r
As a result of the money laundering conspiracy,
such proceeds were distributed among the coconspirators for
their personal benefit including the purchase of luxury
goods, services, and real estate, rather than being used for
the permissible business expenditures under the provisions
of the PPP and EIDL programs.
Defendant was recruited by coconspirator Grigoryan
to join the money laundering conspiracy. In furtherance of
the conspiracy and for the purpose of carrying out its
object at the direction of Grigoryan and others, defendant
opened various business checking accounts at a federally
insured institution with account names that included Arman
Hayrapetyan DBA S. Construction; Arman Hayrapetyan DBA H.
Construction; and Arman Hayrapetyan DBA S. Dental, as set
forth in the below chart (the DBA bank accounts) for the
purpose of receiving deposits of criminal proceeds which
included the fraudulently obtained PPP and EIDL loans listed
below.
Defendant opened these accounts based on
Grigoryan's representation that defendant would be a partner
in the businesses listed in the account names.
In fact, defendant was never legally associated
with any of those businesses and proceeds from the loans in
the chart equal approximately $1,323,887.
At the direction of codefendant Grigoryan who
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P a t C u n e o C S R 1 6 0 0 , O f f i c i a l R e p o r t e r
supervised and managed defendant, defendant then used the
DBA bank accounts to launder the proceeds from fraudulently
obtained PPP and EIDL loans which defendant knew were the
proceeds of illegal activity undertaken by his
coconspirators including Grigoryan, Richard Ayvazyan,
Marietta Terabelian, Artur Ayvazyan, Tamara Dadyan, Edvard
Paronyan, and Vahe Dadyan.
For example, on or about May 4th, 2020,
defendant together with other coconspirators including
Grigoryan caused a check for approximately $50,000 drawn on
the AH DBA S. Construction bank account and comprised in
substantial part of the fraudulent PPP loan proceeds for S.
Construction and H. Construction to be written to the order
of Fiber One Media (the Fiber One Media check).
The Fiber One Media check was endorsed on the back
with the name of codefendant Terabelian's alias, Viktoria
Kauichko.
Further, defendant together with other
coconspirators including Grigoryan caused some smaller
payments to be made out of each of the above-referenced DBA
bank accounts to some of the other codefendants.
To facilitate these transfers, defendant provided
his log-in and password information, the DBA bank accounts,
to codefendant Grigoryan to give Grigoryan access to these
accounts.
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P a t C u n e o C S R 1 6 0 0 , O f f i c i a l R e p o r t e r
For instance, after the deposit of fraudulent PPP
loan proceeds into the AH DBA S. Construction Co. account,
defendant and codefendant Grigoryan caused the transfer of
$500 to Iuliia Zhadko, the alias of codefendant
Richard Ayvazyan.
Similarly, after the deposit of the proceeds from
two of the PPP loans into the AH DBA H. Construction
account, defendant and codefendant Grigoryan caused the
transfer of two separate payments ($600 and $400) to
codefendant Viktoria Kauichko.
Defendant agrees that he received approximately
5 percent of the fraudulent proceeds as payment for his
agreement to launder the funds.
Defendant agrees the deposits of fraudulently
obtained PPP and EIDL loan proceeds into bank accounts that
defendant controlled totaled approximately $1,323,887.
THE COURT: Now, Mr. Hayrapetyan, I have to be
satisfied that you are in fact guilty of the charge that
you're pleading guilty to, and I am reading the factual
basis at page 15 of the plea agreement and I'm going to ask
you some questions that are designed to assure me that in
fact you did acts which would constitute a finding of guilty
to these charges.
And so when you say at page 13 of the plea
agreement at line 16 that: Beginning in or around
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P a t C u n e o C S R 1 6 0 0 , O f f i c i a l R e p o r t e r
March 2020 until October 2020, together with coconspirators
known and unknown, including Grigoryan and others, who are
the others?
In other words, in this conspiracy or in the
Indictment there are eight people named as defendants.
You say that you conducted money laundering with
Grigoryan and others. Which of the other eight defendants
did you have contact with? In other words, who did you take
direction from other than Grigoryan?
THE DEFENDANT: With nobody.
THE COURT: And did you know Grigoryan before
October 2020?
THE DEFENDANT: No. I met him here.
THE COURT: When did you meet him?
THE DEFENDANT: In the beginning of March.
THE COURT: And how did you get to meet him? What
was the occasion or introduction?
THE DEFENDANT: He was just offering me because at
the time I was looking for a second job. I wanted to work.
THE COURT: And what kind of business did
Grigoryan have in March of 2020? What did he represent to
you?
THE DEFENDANT: He was presenting it as a
construction business.
THE COURT: And what job did he offer you?
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P a t C u n e o C S R 1 6 0 0 , O f f i c i a l R e p o r t e r
THE DEFENDANT: That I was told work at this
construction -- that he was working at this large
construction business and then we could open a branch in my
name for this company, for the construction company.
THE COURT: Uh-huh. I'm not following that. I
need some further explanation. You're not, at least at this
point, adequately informing me of your initial contact with
Grigoryan. How did you meet him? Who introduced you to
him?
THE DEFENDANT: A friend of mine introduced me to
him.
THE COURT: Who was the friend?
THE INTERPRETER: A-l-i-k, interpreter spelling,
Alik.
THE DEFENDANT: Yes.
THE COURT: I didn't hear that.
THE INTERPRETER: Oh, Your Honor, I was spelling
the name. A-l-i-k. Alik.
THE COURT: Is that the first or last name?
THE DEFENDANT: I'm saying his first name.
THE COURT: Let me say this to you,
Mr. Hayrapetyan. These questions are not designed to
influence you to answer in any way. All I'm seeking is what
your true involvement was, if any, in the charges that
you're pleading or attempting to plead to.
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P a t C u n e o C S R 1 6 0 0 , O f f i c i a l R e p o r t e r
And so far I have to tell you that what you're
saying doesn't come together for me. In other words, you're
not giving me your version, if in fact there is more to it,
regarding how you met Grigoryan; and you're saying in the
plea agreement that this codefendant Grigoryan asked you to
set up some accounts in certain business names that weren't
yours.
Let me back up and just ask you that.
Did Grigoryan ask you to set up certain bank
accounts for businesses that were not businesses for which
you were involved?
THE DEFENDANT: Yes.
THE COURT: And when you set up these bank
accounts, did you do it online or did you go to a bank?
THE DEFENDANT: I went to the bank personally and
I opened them.
THE COURT: And did Grigoryan accompany you to the
bank?
THE DEFENDANT: No.
THE COURT: And when you went to the bank, did you
go to a bank where the bank employee spoke the Armenian
language?
THE DEFENDANT: Yes.
THE COURT: Where was that bank? Was it the same
bank or different banks?
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P a t C u n e o C S R 1 6 0 0 , O f f i c i a l R e p o r t e r
THE DEFENDANT: I went to two banks.
THE COURT: What were the banks? Where were they
located?
THE DEFENDANT: Chase. Chase Bank and they were
in Glendale.
THE COURT: I see. And when you went to the bank,
were there bank employees who spoke the Armenian language?
THE DEFENDANT: Yes.
THE COURT: And did you speak to these bank
employees in the Armenian language or the English language?
THE DEFENDANT: No, I was speaking in Armenian
because I don't know how to speak English.
THE COURT: And so when you opened the bank
accounts that are listed in the Indictment, they were in the
names of the companies that are contained at lines 21 on
page 14 to line 10 at page 15.
Those bank accounts appear to be opened at -- some
on the same date and some on different dates. I'm looking
at the plea agreement, and it seems like all the bank
accounts were opened at Chase Bank. Is that correct?
THE DEFENDANT: Yes.
THE COURT: And was it the same branch in Glendale
or a different branch?
THE DEFENDANT: No. In Glendale but different
branches.
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P a t C u n e o C S R 1 6 0 0 , O f f i c i a l R e p o r t e r
THE COURT: And did Mr. Grigoryan instruct you to
open accounts at different branches of Chase Banks in
Glendale?
THE DEFENDANT: Yes.
THE COURT: And did he tell you why that should be
done?
THE DEFENDANT: Yes.
THE COURT: And what did he tell you?
THE DEFENDANT: He was saying that the account
needs to be open in your name because we have to transfer
money into it in order to pay the workers money; and for me
to do that, I will be receiving 5 percent of the amount.
THE COURT: But what he said, you have to open
these bank accounts in the names of the businesses in the
plea agreement for workers, what did you understand to be
the workers?
THE DEFENDANT: In my understanding, the way I
understood it, it was that they were going to pay some
workers, people who are working at construction, and for me
I had to also go and kind of supervise the work there but I
did not go.
THE COURT: Did Mr. Grigoryan tell you why you
should open bank accounts in order to pay his workers?
THE DEFENDANT: In my understanding he was saying
that -- I understood that he was very busy and that's why he
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P a t C u n e o C S R 1 6 0 0 , O f f i c i a l R e p o r t e r
was trying for one portion of the business to be in my name
so that I could take care of it. That's -- something like
that.
THE COURT: And were you in the construction
business?
THE DEFENDANT: Yes. When I was in Armenia, I to
some degree was involved in construction.
THE COURT: Like what? To what degree? What did
you do? Were you an electrician, a carpenter, a laborer, an
architect? What did you do?
THE DEFENDANT: No. In Armenia, I have to serve
in military so when I'm talking about working in
construction, I was just doing it for my own house whenever
things needed to be done or constructed. So that's how I
was using the construction skill working on my paternal
house.
THE COURT: Now, I remember from the bail hearing
that you were traveling back and forth to Armenia in the
period prior to March of 2020.
When did you come to the United States from
Armenia in your most -- before meeting Grigoryan? Do you
understand the question? In other words, how long before
you met Grigoryan -- did you meet Grigoryan for the first
time in March of 2020 or did you meet him before that?
THE DEFENDANT: No, it was after that.
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P a t C u n e o C S R 1 6 0 0 , O f f i c i a l R e p o r t e r
THE COURT: But how long had you been back from
Armenia, that is, how long were you in the United States
before you met Grigoryan?
THE DEFENDANT: So it was only once that I
actually went to Armenia and back. It's not that I kept
going back and forth but I came back that one time.
I came back in May and then I met with Grigoryan
in March. And then the only other time it was September but
I wasn't going back and forth.
THE COURT: You're not giving me the chronology
correctly because these bank accounts in the plea agreement,
the column for deposit date, I don't know. When you opened
the accounts, did you make deposits at the time you opened
the accounts?
THE DEFENDANT: So it was -- I put there only $100
and then it was only until May. In May, I had to go back to
Armenia because of family issues.
THE COURT: Okay. When were these accounts
opened? The Indictment doesn't say -- unless I'm missing
something -- when these accounts were opened. It just has a
column for the first deposit.
When was the account -- when were these accounts
in the plea agreement opened? When did you open them? What
date? In March or May or some other date?
THE DEFENDANT: No. I opened the account in
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P a t C u n e o C S R 1 6 0 0 , O f f i c i a l R e p o r t e r
March, two account, and that was online; and then through
online account, I was just transferring the checks.
THE COURT: I'm not following. The question again
is: There are one, two, three -- how many accounts were
opened? There's the account for S. Construction, AH DBA H.
Construction, H. Construction, S.S Dental.
I guess that's one, two, three. Looks like four
accounts. Is that correct? Am I correct on that,
Prosecutor Paetty? Is that --
MR. PAETTY: No, Your Honor. There are three
accounts that are listed. The 9906, 1511, 5355.
THE COURT: One moment.
(Pause in the proceedings.)
THE COURT: So I'm looking at page 14. The AH DBA
H and H. Construction are the same account; correct?
MR. PAETTY: Your Honor, if you look on the far
right column, there's an account number.
THE COURT: I see. But there's a column, Business
Applicant, H. Construction; and then the bank account seems
to be AH DBA H.
MR. PAETTY: That's correct, Your Honor. The
business applicant is who is applying for the loans and the
funds for the loans were going into a different account.
So when you see the column that says "Business
Applicant," that's the name that was on the loan.
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P a t C u n e o C S R 1 6 0 0 , O f f i c i a l R e p o r t e r
THE COURT: And there I see business applicant, I
see S. Construction, that's one. AH DBA Construction is
two. I see S.S. Dental is three. So those are the three
applicants; correct?
MR. PAETTY: Yes, Your Honor.
THE COURT: And did you open those accounts at the
same time or at different times, Mr. Hayrapetyan?
THE DEFENDANT: I only opened two accounts in the
month of March and just a little bit one after another.
THE COURT: Only two. So which two did you open?
THE INTERPRETER: Your Honor, this is the
interpreter. So I'm not understanding his pronunciation
about the name. Could you -- he's saying it in English, I
guess, but I wasn't able to understand it.
THE COURT: Mr. Hayrapetyan, the translator is not
understanding your answer and you apparently tried to answer
in English. Can you answer once again which of the three
accounts did you personally open? You said you opened two
of the three. Which two?
THE DEFENDANT: When Grigoryan told me -- brought
me the papers to open the account, it was only for two.
THE INTERPRETER: And, Your Honor, the interpreter
is hearing Bolo Construction and Got Construction. That's
what I hear that he's saying in English.
THE COURT: Can you ask him in Armenian -- can you
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P a t C u n e o C S R 1 6 0 0 , O f f i c i a l R e p o r t e r
tell him how you say the letter S in Armenian, S.
Construction?
THE DEFENDANT: S -- I mean, I don't know the
English alphabet.
THE COURT: Well, can he tell -- can you tell the
translator, Mr. Hayrapetyan, the names of the accounts that
you personally opened at the Chase Banks as set forth in the
plea agreement in the Armenian language?
THE DEFENDANT: Okay. I don't know how to explain
it but it's the letter that looks like 8, like S.
THE COURT: When the -- and when Mr. Grigoryan
instructed you to open the accounts, did he have all the
information filled out?
THE DEFENDANT: Yes. He brought the paper and it
already had a seal on it; and according to that paperwork,
that's how I went to the bank.
THE COURT: And turning back to an earlier
question, who introduced you to Mr. Grigoryan?
THE DEFENDANT: My friend. It was a friend of
mine that when I came from Armenia, he came to greet me.
That friend.
THE COURT: What was the friend's name?
THE DEFENDANT: Alik.
THE COURT: And I don't have that before me,
Mr. Paetty. Would you read the names of the eight
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P a t C u n e o C S R 1 6 0 0 , O f f i c i a l R e p o r t e r
defendants other than Grigoryan? Just read those names.
MR. PAETTY: Yes, Your Honor.
Richard Ayvazyan, Marietta Terabelian,
Artur Ayvazyan, Tamara Dadyan, Edvard Paronyan, Vahe Dadyan.
THE COURT: Did you ever meet those people?
THE DEFENDANT: Never. I only knew Grigoryan.
THE COURT: Did he ever mention the names of those
other defendants that the prosecutor just read?
THE DEFENDANT: No. And I didn't have that much
closeness with him. Like we didn't have too many meetings
or things like that.
THE COURT: How many times did you meet Grigoryan
before you opened these accounts?
THE DEFENDANT: So I only met him after I opened
the account because the first conversation was over the
phone that my friend introduced me to him so we had the
conversation and then afterwards I only met him in Vegas.
THE COURT: Now, I'm going to tell you how I'm
understanding your answer and I want you to tell me if I'm
understanding your answer correctly or incorrectly or how
you want to modify it.
What I hear you saying is that Grigoryan told you
that he had a construction business and that he wanted you
to open certain bank accounts so he could use those bank
accounts to pay his employees. Is that what he told you?
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P a t C u n e o C S R 1 6 0 0 , O f f i c i a l R e p o r t e r
THE DEFENDANT: Yes.
THE COURT: And did he tell you anything else?
THE INTERPRETER: Your Honor, this is the
interpreter. May I inquire? His voice was cutting off so I
need a couple of words there. Could I inquire?
THE COURT: Yes. Go ahead.
THE INTERPRETER: Thank you.
(Interpreter speaking to defendant.)
THE INTERPRETER: So the way he was saying, I
asked what kind of company is that; and he said: This is a
very large company but the company is not doing well. The
company might go bankrupt. They might close it up.
So that's why he was saying maybe small branch we
could open in your name like have a bank account. That's
how he was describing it.
THE COURT: Did you understand that to mean that
if Grigoryan's companies went bankrupt, these bank accounts
could be used outside the bankruptcy to pay his employees
and keep the business going?
THE DEFENDANT: Yes, yes. That's very correct.
THE COURT: And it says at line 19 on page 15 that
on May 4th you cashed a check for approximately $50,000
drawn on the AH DBA S.Construction account comprised a
substantial amount of fraudulently PPP loan proceeds for S.
Construction and H. Construction to be written to the order
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P a t C u n e o C S R 1 6 0 0 , O f f i c i a l R e p o r t e r
of Fiber One Media (The Fiber One check) and that check was
endorsed by codefendant Terabelian.
Did you write that check? Sign that check?
THE DEFENDANT: No, no.
THE COURT: It says in the factual basis that you
knew that the deposits to these bank accounts that you
opened were substantially -- that the deposits in those
accounts were substantially from fraudulent PPP loans.
Do you know what PPP loans are?
THE DEFENDANT: So I understood that word only
after I spoke with my lawyer. I only found out that's what
it meant.
THE COURT: Right.
I'm now going to ask Mr. Paetty some questions.
What evidence would the government have if this
case went to trial that would establish the money laundering
that you have alleged?
Because the way I'm understanding his answers is
he has not admitted to the crimes that are charged. He
possibly is admitting to participation in some sort of
bankruptcy charge. That isn't what's alleged.
What evidence would you have if the case went to
trial to show that he was guilty of money laundering as
charged?
MR. PAETTY: Yes, Your Honor.
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P a t C u n e o C S R 1 6 0 0 , O f f i c i a l R e p o r t e r
So as I read earlier on the elements of money
laundering, he does not need to know that the proceeds that
he was laundering and the money that was being transferred
through his accounts which are alleged in the charts on page
14 and 15, he does not need to know that the source of those
fraudulent proceeds were in fact PPP or EIDL funds.
He just needs to know those funds were sourced
from some unlawful -- they were unlawful proceeds and
that --
THE COURT: Perhaps -- so far I haven't -- I
understand that but that isn't -- the Indictment
specifically charges the EIDL and the PPP loans.
What he's talking about, if in fact they are
fraudulent funds -- and I don't know that at this point --
that's not alleged in the Indictment.
MR. PAETTY: If I understand Your Honor's question
correctly, what's alleged in the Indictment is a PPP loan
fraud scheme and an EIDL loan fraud scheme.
What Mr. Hayrapetyan is pleading guilty to is the
money laundering conspiracy. There are two conspiracies in
the Indictment. One is the fraud conspiracy and one is
money laundering.
THE COURT: I want to have the Indictment before
me. But read to me the beginning of the conspiracy, the
money laundering conspiracy count. Just that count.
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P a t C u n e o C S R 1 6 0 0 , O f f i c i a l R e p o r t e r
MR. PAETTY: May I have one moment, Your Honor?
(Pause in the proceedings.)
MR. PAETTY: This is on page 40 of the Superseding
Indictment.
That beginning no later than in or around
March 2020 and continuing --
THE COURT: Read it slowly if you will.
MR. PAETTY: Yes, Your Honor.
Beginning no later than in or around March 2020
and continuing until at least in or around October 2020, in
Los Angeles County within the Central District of California
and elsewhere, defendants Richard Ayvazyan, Marietta
Terabelian, Artur Ayvazyan, Tamara Dadyan, Manuk Grigoryan,
Arman Hayrapetyan, Edvard Paronyan, and Vahe Dadyan
conspired with one another and with others known and unknown
to commit offenses against the United States in violation --
well, to commit -- conspiracy to commit money laundering, to
wit, to knowingly conduct and attempt to conduct financial
transactions involving the proceeds of specified unlawful
activity, that is, wire fraud and bank fraud, knowing that
the transaction was designed in whole and in part to conceal
and disguise the nature, location, source, ownership, and
control of the proceeds of specified unlawful activity; to
knowingly engage and attempt to engage in monetary
transactions in criminally derived property of a value
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P a t C u n e o C S R 1 6 0 0 , O f f i c i a l R e p o r t e r
greater than $10,000, such property having been derived from
the specified unlawful activity, that is, bank and wire
fraud.
And then the manner and the means of the
conspiracy. The defendants Richard Ayvazyan, Terabelian,
Artur Ayvazyan, Tamara Dadyan, Grigoryan, Hayrapetyan,
Paronyan, and Vahe Dadyan, together with other
coconspirators, submitted and caused the submission of
fraudulent PPP and EIDL loan applications which caused the
Small Business Association, the SBA, and SBA-approved
lenders including lenders who were federally insured
financial institutions to wire loan proceeds to bank
accounts in the names of the entities used to obtain such
loans.
THE COURT: Let me ask you this. When you mention
wire fraud and mail fraud, the only wire fraud and mail
fraud in the Indictment is the wire fraud and mail fraud
alleged in Count 1 of the Indictment; correct?
MR. PAETTY: That's the conspiracy count, Your
Honor, and there are separate substantive wire and bank
fraud counts also alleged.
THE COURT: Is there any wire and bank fraud count
that relates to bankruptcy fraud?
MR. PAETTY: No, Your Honor.
THE COURT: And by the way, is there any -- does
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P a t C u n e o C S R 1 6 0 0 , O f f i c i a l R e p o r t e r
anyone know whether any of -- what's his name, Grigoryan,
ever put any of his companies into bankruptcy?
MR. PAETTY: I'm unaware of that, Your Honor.
THE COURT: You know something? This is deficient
and I am not going to go any further. Either I'm not fully
understanding, perhaps it's not my place, why these pleas
are even being attempted.
This is just inadequate. I don't know what is
truthful or untruthful; but it seems to me that's a jury
question and if the jury believes what Mr. Hayrapetyan says,
there's a good argument for Mr. Tahmazian that he isn't
guilty of money laundering and, under these circumstances, I
can't accept the plea.
There is some indication of cooperation. Is the
cooperation anticipated that he would say what he has said
about Grigoryan?
MR. PAETTY: Yes, Your Honor.
He would say about Grigoryan that Grigoryan
instructed to open these accounts; and if the Court would
allow Mr. Hayrapetyan to continue to describe the conduct
that he undertook at the direction of Mr. Grigoryan, the
Court may understand that there was no legitimate business
that was being done by any of these construction businesses;
that Mr. Hayrapetyan was essentially being paid 5 percent of
the proceeds of the PPP and EIDL fraud.
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P a t C u n e o C S R 1 6 0 0 , O f f i c i a l R e p o r t e r
He did not know the source. He did not know that
those funds from fraudulent PPP and EIDL loans; but the
monies that were coming into that account were fraudulent.
There was no basis for them. There was no construction
business that he was working on.
THE COURT: It's over. I'm rejecting the plea.
It is over. We're going to trial on the 15th.
MR. TAHMAZIAN: Your Honor, may I very briefly be
heard please. Thank you, Your Honor.
It's unfortunate that in this colloquy the main
point is not coming across, Your Honor; and I apologize for
that.
But just to put the whole thing into perspective
is that when Mr. Hayrapetyan was approached to open up these
accounts and do this transaction, he was told that he'll be
doing some supervision work. He'll be doing some work for a
certain amount of money every month and it had to do with
construction work.
But within a few days he realize that there is no
construction work, there is no construction site, there are
no employees, he was getting checks to deposit in the
account, money was going in the account.
THE COURT: How did he know this? He's not even
telling me how he knew Grigoryan. He's not familiar with
the construction business. You know something? I'm not
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P a t C u n e o C S R 1 6 0 0 , O f f i c i a l R e p o r t e r
going any further.
This is -- this is just plain inadequate. I am
not pulling teeth here. This should be clear as a bell.
This should not need all these explanations.
MR. TAHMAZIAN: Your Honor --
THE COURT: No, it's over. I am rejecting the
plea. Mr. Tahmazian, I have spoken and you are not to speak
any more. It is over.
This is very inadequate; and if you intended for
your client to plead guilty under these circumstances, I
think you ought to be better prepared and certainly he ought
to be better prepared; and that doesn't in any way signal
that he should say what he didn't do to plead guilty.
We are going to trial.
THE CLERK: Your Honor. There is a matter of a
third application for --
THE COURT: What about the bail? I rejected bail
previously. But what is the government's position on the
bail?
MR. PAETTY: Your Honor, the government's position
is the same. This is the third motion to reconsider. The
Court has denied the previous two.
Defendant has essentially proffered the same
sureties that were proffered before, and there's no material
change to his argument for bond.
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P a t C u n e o C S R 1 6 0 0 , O f f i c i a l R e p o r t e r
THE COURT: What is the difference now between the
other two bail bond applications?
MR. TAHMAZIAN: Two differences, Your Honor, if I
may. I just need five minutes of your time to explain where
I'm coming from, Your Honor.
THE COURT: The facts are different then before?
MR. TAHMAZIAN: Yes.
The difference is he met with the government, he
gave his story. He agreed to cooperate and he's willing to
accept responsibility for his side of what he did. In
addition to that, Your Honor, if you just give me just a few
minutes.
THE COURT: Go ahead.
MR. TAHMAZIAN: I'm sorry?
THE COURT: Go ahead.
MR. TAHMAZIAN: Thank you.
When this Indictment first came down against my
client was March of this year, Your Honor. When arrest
warrant was issued, there was a knock on the door at a
location where he was supposed to meet. Supposed to be
living in.
It was the agent. When he heard about that, there
was a card left. He retained my offices and within a week
we came to court.
In that week, Your Honor, I went through the
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P a t C u n e o C S R 1 6 0 0 , O f f i c i a l R e p o r t e r
entire Indictment and I told him exactly what he's facing;
and knowing that he could be going to trial and getting
large number of years in custody, he walked in the
courtroom.
Prior to that, there was some discussion with the
government about a possible bail; and at that time the
government decides other terms of house arrest, electronic
monitoring, was asking for $125,000 of secured bond.
At that time I was not able to put that together
and in my mind, Your Honor, I thought that if somebody with
this kind of Indictment facing this kind of Indictment is
walking in the courtroom, the Court and everybody else can
see that this man is not a flight risk. He's walking
himself with his own two feet.
THE COURT: You've made that argument before.
MR. TAHMAZIAN: Oh. So since then, I was able to
secure additional sureties which total about $125,000,
75,000 is unsecured; 50,000 is secured and I made that
argument to Your Honor previously.
But since then, he's met with the government.
He's given a statement. He's trying to accept
responsibility for whatever he's done and take his
punishment. Help the government to try to show that this is
not something ordinary for this man because his background
is military.
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P a t C u n e o C S R 1 6 0 0 , O f f i c i a l R e p o r t e r
And I was hoping the Court can see that based on
his role in this offense, based on his knowledge of the
people, only knows one person, the Court may consider
allowing him to be out on bail with this surety.
THE COURT: All right. I will take the matter
under advisement, give further thought to your argument, and
I'll issue an order. Thank you.
MR. TAHMAZIAN: May I ask one more question, Your
Honor? I am so sorry. Would the Court give us a chance to
amend his factual basis exactly in the specific order you
want to refile the plea agreement, Your Honor?
THE COURT: You've misinterpreted. I don't want
anything. I don't want a thing. I don't want him to plead
guilty. I don't want him to go to trial. I have no stake
in this whatsoever.
My job here is to assure me that he's pleading
guilty because he is guilty and for no other reason and I am
unsatisfied at this point. That's the end of it.
MR. TAHMAZIAN: Thank you, Your Honor.
THE CLERK: This Honorable Court stands in recess.
(At 12:48 p.m., proceedings were concluded.)
-oOo-
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P a t C u n e o C S R 1 6 0 0 , O f f i c i a l R e p o r t e r
CERTIFICATE
I, PAT CUNEO, CSR 1600, hereby certify that
pursuant to Section 753, Title 28, United States Code, the
foregoing is a true and correct transcript of the
stenographically reported proceedings held in the
above-entitled matter and that the transcript page format is
in conformance with the regulations of the Judicial
Conference of the United States.
Date: June 8, 2021
/s/__________________________
PAT CUNEO, OFFICIAL REPORTER
CSR NO. 1600
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MR. PAETTY: [24] 3/11
9/23 13/1 13/7 13/10
13/13 13/16 13/21 14/5
25/10 25/16 25/21 26/5
28/2 30/25 31/16 32/1
32/3 32/8 33/19 33/24
34/3 34/17 36/20
MR. TAHMAZIAN: [21]
3/13 5/7 6/7 6/23 7/2
7/6 7/20 7/23 8/4 8/8
8/10 13/6 35/8 36/5
37/3 37/7 37/14 37/16
38/16 39/8 39/19
THE CLERK: [15] 3/3
3/5 3/7 3/15 3/18 3/20
3/24 4/2 4/8 4/12 4/17
5/2 13/17 36/15 39/20
THE COURT: [108]
THE DEFENDANT:
[62]
THE INTERPRETER:
[9] 4/5 4/21 19/13
19/17 26/11 26/22 29/3
29/7 29/9
$
$1,323,887 [2] 15/24
17/16
$10,000 [1] 33/1
$100 [2] 10/4 24/15
$125,000 [2] 38/8 38/17
$400 [1] 17/9
$50,000 [2] 16/10 29/22
$500 [1] 17/4
$500,000 [1] 10/2
$600 [1] 17/9
-
-oOo [2] 3/2 39/23
/
/s [1] 40/15
1
10 [1] 21/16
11:33 [2] 1/17 3/1
12:48 [1] 39/21
13 [1] 17/24
14 [3] 21/16 25/14 31/5
15 [4] 17/20 21/16
29/21 31/5
1511 [1] 25/11
1518 [1] 2/7
15th [1] 35/7
16 [1] 17/25
1600 [3] 1/21 40/3
40/16
1782 [1] 1/24
19 [2] 14/25 29/21
1st [1] 1/22
2
20 [1] 9/25
20-579-SVW [2] 1/8 3/8
2020 [15] 12/22 12/23
14/9 14/10 14/22 16/8
18/1 18/1 18/12 18/21
23/19 23/24 32/6 32/9
32/10
2021 [3] 1/17 3/1 40/10
21 [1] 21/15
213-894-1782 [1] 1/24
22 [1] 12/6
24 [1] 8/24
25th [2] 6/1 7/12
26 [4] 3/22 3/24 10/6
11/23
27th [3] 6/10 7/13 7/16
28 [1] 40/4
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4
40 [1] 32/3
4311 [1] 1/23
4th [2] 16/8 29/22
5
5 percent [3] 17/12
22/12 34/24
50,000 [1] 38/18
5355 [1] 25/11
5K1.1 [1] 12/17
7
75,000 [1] 38/18
753 [1] 40/4
8
818-242-8201 [1] 2/8
8201 [1] 2/8
9
90 percent [1] 7/7
90012 [2] 1/23 2/5
91201 [1] 2/8
9906 [1] 25/11
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A.M [2] 1/17 3/1
able [3] 26/14 38/9
38/16
about [12] 8/1 8/3 16/8
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above [2] 16/20 40/7
above-entitled [1] 40/7
above-referenced [1]
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accept [3] 34/13 37/10
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acceptance [1] 12/13
access [1] 16/24
accompany [1] 20/17
according [1] 27/15
account [22] 15/12
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accounts [41]
across [1] 35/11
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activity [6] 10/14 10/18
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acts [1] 17/22
actually [3] 5/7 6/23
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addition [1] 37/11
additional [1] 38/17
Additionally [1] 12/18
address [1] 4/18
adequate [1] 9/5
adequately [1] 19/7
admitted [1] 30/19
admitting [1] 30/20
advisement [1] 39/6
affirmative [1] 11/17
after [7] 6/8 17/1 17/6
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afternoon [2] 3/3 3/4
afterwards [1] 28/17
again [3] 13/14 25/3
26/17
against [5] 11/9 11/15
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agent [1] 37/22
agree [2] 8/13 8/15
agreed [2] 10/9 37/9
agreeing [1] 9/16
agreement [35] 5/23
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agrees [4] 11/22 12/9
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AH [8] 16/11 17/2 17/7
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ahead [5] 4/7 5/1 29/6
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alias [2] 16/16 17/4
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all [13] 5/1 5/4 5/8 5/16
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alleged [7] 30/17 30/21
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allowing [1] 39/4
alphabet [1] 27/4
already [1] 27/15
also [3] 2/13 22/20
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am [9] 4/22 7/2 17/19
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amend [1] 39/10
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Americans [1] 14/24
among [4] 11/22 12/22
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amount [3] 22/12
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another [2] 26/9 32/15
answer [8] 4/4 4/6
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argument [5] 34/11
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Arman Hayrapetyan [5]
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ARMENIAN [12] 2/13
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around [9] 12/22 12/23
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arrest [2] 37/18 38/7
Artur [4] 16/6 28/4
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Artur Ayvazyan [4]
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as [17] 4/24 6/20 7/17
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ask [12] 4/2 4/8 5/9
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39/8
asked [3] 4/13 20/5
29/10
asking [1] 38/8
aspect [1] 9/18
assessment [1] 10/4
assistance [1] 14/23
ASSISTANT [1] 2/3
associated [1] 15/22
Association [1] 33/10
assure [3] 5/10 17/21
39/16
at [40] 2/7 10/25 11/3
12/10 12/12 12/16
12/23 14/9 15/10 15/11
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attempt [2] 32/18
32/24
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attempting [1] 19/25
attendance [1] 11/12
{PLAINTIFF} v.
{WITNESSNAME}
{DEFENDANT}
{DATE}
Pat Cuneo CSR 1600, Official Reporter
(1) MR. PAETTY: - attendance
Case 2:20-cr-00579-SVW Document 866 Filed 08/12/21 Page 41 of 47 Page ID
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ATTORNEY [3] 2/2 2/3
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away [1] 4/20
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back [13] 8/2 13/18
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background [1] 38/24
bail [7] 23/17 36/17
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bank [40] 10/12 15/15
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bankrupt [2] 29/12
29/17
bankruptcy [4] 29/18
30/21 33/23 34/2
banks [5] 20/25 21/1
21/2 22/2 27/7
bargain [1] 9/15
base [1] 12/5
based [4] 7/21 15/19
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basis [9] 5/12 6/15
9/20 14/2 14/4 17/20
30/5 35/4 39/10
be [39] 4/13 4/19 8/1
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because [11] 7/3 9/4
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become [1] 7/8
been [4] 5/2 11/18 24/1
33/1
before [16] 3/7 6/4
7/12 8/18 13/22 18/11
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27/24 28/13 31/23
36/24 37/6 38/15
beginning [7] 12/22
14/8 17/25 18/15 31/24
32/5 32/9
being [5] 15/4 31/3
34/7 34/23 34/24
believe [2] 13/7 13/13
believes [1] 34/10
bell [1] 36/3
below [2] 15/15 15/18
benefit [1] 15/3
best [1] 4/24
better [3] 4/20 36/11
36/12
between [3] 8/17 9/15
37/1
beyond [3] 11/7 12/21
14/7
binding [1] 11/20
bit [1] 26/9
Bolo [1] 26/23
bond [3] 36/25 37/2
38/8
Boulevard [1] 2/7
branch [4] 19/3 21/22
21/23 29/13
branches [2] 21/25
22/2
briefly [1] 35/8
brought [2] 26/20
27/14
burden [1] 11/6
business [18] 15/5
15/11 18/20 18/24 19/3
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25/22 25/24 26/1 28/23
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busy [1] 22/25
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call [1] 3/5
came [6] 24/6 24/7
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38/12 39/1
can't [1] 34/13
card [1] 37/23
care [1] 23/2
carpenter [1] 23/9
carrying [1] 15/9
case [6] 3/5 5/15 12/20
14/6 30/16 30/22
cashed [1] 29/22
category [1] 12/19
caused [6] 16/10 16/19
17/3 17/8 33/8 33/9
CENTRAL [2] 1/2
32/11
certain [4] 20/6 20/9
28/24 35/17
certainly [1] 36/11
CERTIFICATE [1] 40/1
certified [2] 6/10 7/13
certify [1] 40/3
chance [1] 39/9
change [2] 1/19 36/25
charge [2] 17/18 30/21
charged [3] 10/5 30/19
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chart [2] 15/15 15/24
charts [1] 31/4
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check [8] 16/10 16/14
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checking [1] 15/11
checks [2] 25/2 35/21
choice [1] 11/15
chose [1] 11/14
chronology [1] 24/10
circumstances [3]
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claims [1] 11/18
clear [1] 36/3
clearly [1] 9/1
client [3] 6/20 36/10
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close [1] 29/12
closeness [1] 28/10
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coconspirator [1] 15/7
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colloquy [1] 35/10
column [5] 24/12 24/21
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come [2] 20/2 23/20
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company [6] 19/4 19/4
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concluded [1] 39/21
conduct [4] 10/10
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34/15
copy [1] 5/25
Coronavirus [1] 14/21
correct [18] 3/18 5/5
5/6 6/2 6/3 6/13 6/17
6/18 9/2 21/20 25/8
25/8 25/15 25/21 26/4
29/20 33/18 40/5
correctly [3] 24/11
28/20 31/17
could [9] 11/18 19/3
23/2 26/13 28/24 29/5
29/14 29/18 38/2
counsel [6] 3/7 3/10
10/23 10/24 11/2 11/3
count [9] 3/22 3/24
10/6 11/23 31/25 31/25
33/18 33/19 33/22
Count 1 [1] 33/18
counts [2] 12/10 33/21
County [1] 32/11
couple [1] 29/5
court [21] 1/1 4/2 4/8
4/13 4/19 7/11 7/14
9/24 10/24 11/3 11/21
12/1 34/19 34/22 36/22
37/24 38/12 39/1 39/3
39/9 39/20
Court's [1] 7/10
Courthouse [2] 1/22
2/4
courtroom [2] 38/4
38/12
Covid [1] 14/25
Covid-19 [1] 14/25
CR [1] 1/8
created [1] 14/20
crime [1] 10/5
crimes [1] 30/19
criminal [4] 3/8 12/19
12/19 15/16
criminally [1] 32/25
cross [1] 11/8
cross-examine [1]
11/8
CRR [1] 1/21
CRR-CM [1] 1/21
CSR [3] 1/21 40/3
40/16
CUNEO [3] 1/21 40/3
40/16
custody [1] 38/3
cutting [1] 29/4
D
Dadyan [8] 16/6 16/7
28/4 28/4 32/13 32/14
{PLAINTIFF} v.
{WITNESSNAME}
{DEFENDANT}
{DATE}
Pat Cuneo CSR 1600, Official Reporter
(2) ATTORNEY - Dadyan
Case 2:20-cr-00579-SVW Document 866 Filed 08/12/21 Page 42 of 47 Page ID
#:15354
D
Dadyan... [2] 33/6 33/7
date [6] 7/16 21/18
24/12 24/24 24/24
40/10
dates [1] 21/18
day [1] 9/4
days [3] 6/10 8/20
35/19
DBA [15] 15/13 15/13
15/14 15/15 16/2 16/11
16/20 16/23 17/2 17/7
25/5 25/14 25/20 26/2
29/23
decides [1] 38/7
defendant [36] 1/10
2/6 3/15 5/2 9/16 9/17
9/18 10/5 10/9 10/13
10/15 10/19 11/1 11/14
11/22 12/10 12/12
14/10 15/7 15/10 15/19
15/20 15/22 16/1 16/1
16/3 16/9 16/18 16/22
17/3 17/8 17/11 17/14
17/16 29/8 36/23
defendants [6] 18/5
18/7 28/1 28/8 32/12
33/5
defenses [2] 5/16
11/17
deficient [1] 34/4
degree [2] 23/7 23/8
demonstrates [1]
12/12
denied [1] 36/22
Dental [3] 15/14 25/6
26/3
depending [1] 12/15
deposit [5] 17/1 17/6
24/12 24/21 35/21
deposits [5] 15/16
17/14 24/13 30/6 30/7
derived [2] 32/25 33/1
describe [2] 13/5 34/20
described [3] 6/20
8/14 8/17
describing [1] 29/15
designed [6] 5/10
10/16 14/23 17/21
19/22 32/21
device [2] 4/19 4/22
did [48]
didn't [5] 4/4 19/16
28/9 28/10 36/13
difference [3] 8/16
37/1 37/8
differences [1] 37/3
different [9] 7/19 20/25
21/18 21/23 21/24 22/2
25/23 26/7 37/6
direction [6] 12/25
13/2 15/10 15/25 18/9
34/21
disaster [2] 14/18
14/19
discuss [1] 5/15
discussion [1] 38/5
disguise [2] 10/16
32/22
dismiss [1] 12/9
distributed [1] 15/2
DISTRICT [3] 1/1 1/2
32/11
DIVISION [1] 1/3
do [16] 3/24 4/12 4/24
8/13 9/16 9/21 13/17
20/14 22/12 23/9 23/10
23/21 30/9 35/15 35/17
36/13
does [3] 31/2 31/5
33/25
doesn't [3] 20/2 24/19
36/12
doing [4] 23/13 29/11
35/16 35/16
don't [12] 8/11 21/12
24/12 27/3 27/9 27/24
31/14 34/8 39/12 39/13
39/13 39/14
done [4] 22/6 23/14
34/23 38/22
door [1] 37/19
doubt [3] 11/7 12/22
14/8
down [1] 37/17
drawn [2] 16/10 29/23
drugs [1] 8/23
E
each [1] 16/20
earlier [2] 27/17 31/1
economic [3] 14/19
14/21 14/24
Edvard [3] 16/6 28/4
32/14
EIDL [11] 14/19 15/6
15/17 16/3 17/15 31/6
31/12 31/18 33/9 34/25
35/2
eight [3] 18/5 18/7
27/25
Either [1] 34/5
electrician [1] 23/9
electronic [1] 38/7
elements [4] 9/10 13/4
13/25 31/1
else [2] 29/2 38/12
elsewhere [1] 32/12
emergency [1] 14/23
employee [1] 20/21
employees [5] 21/7
21/10 28/25 29/18
35/21
enacted [1] 14/22
end [2] 12/14 39/18
endorsed [2] 16/15
30/2
engage [2] 32/24 32/24
engaged [1] 14/12
English [6] 21/10
21/12 26/13 26/17
26/24 27/4
enhancement [1] 12/6
enough [1] 5/14
enter [1] 3/21
entire [1] 38/1
entities [1] 33/13
entitled [1] 40/7
equal [1] 15/24
error [1] 13/23
essence [1] 13/25
essentially [2] 34/24
36/23
establish [1] 30/16
estate [1] 15/4
even [2] 34/7 35/23
ever [3] 28/5 28/7 34/2
every [4] 7/11 7/15
11/3 35/17
everybody [1] 38/12
Everything [1] 8/22
evidence [4] 11/10
11/14 30/15 30/22
exactly [3] 8/15 38/1
39/10
examine [1] 11/8
example [1] 16/8
except [1] 12/1
exist [1] 12/16
expenditures [1] 15/5
explain [2] 27/9 37/4
explained [2] 6/16 6/19
explanation [1] 19/6
explanations [1] 36/4
F
facilitate [1] 16/22
facing [2] 38/1 38/11
fact [7] 13/23 15/22
17/18 17/22 20/3 31/6
31/13
factors [1] 12/5
facts [1] 37/6
factual [7] 5/12 9/20
14/2 14/4 17/19 30/5
39/10
familiar [2] 7/5 35/24
family [3] 7/4 7/6 24/17
far [3] 20/1 25/16 31/10
federal [2] 14/20 14/22
federally [2] 15/11
33/11
feet [1] 38/14
few [2] 35/19 37/11
Fiber [5] 16/14 16/14
16/15 30/1 30/1
Fifth [1] 11/17
filed [1] 11/19
filled [1] 27/13
finally [1] 9/20
financial [4] 10/10
14/23 32/18 33/12
finding [1] 17/22
fine [2] 8/21 10/2
FIRM [1] 2/6
first [12] 1/22 3/22 3/25
6/25 9/9 13/23 19/19
19/20 23/23 24/21
28/15 37/17
five [1] 37/4
flight [1] 38/13
fluent [2] 7/1 7/8
following [6] 10/7
10/20 11/22 12/24 19/5
25/3
foregoing [1] 40/5
form [1] 10/14
format [1] 40/7
forth [6] 8/2 15/15
23/18 24/6 24/9 27/7
found [1] 30/11
four [2] 13/23 25/7
Fourth [2] 9/14 11/17
fraud [18] 10/12 10/12
31/18 31/18 31/21
32/20 32/20 33/3 33/16
33/16 33/16 33/17
33/17 33/17 33/21
33/22 33/23 34/25
fraudulent [9] 16/12
17/1 17/12 30/8 31/6
31/14 33/9 35/2 35/3
fraudulently [5] 14/17
15/17 16/2 17/14 29/24
freely [1] 5/11
Friday [2] 1/17 3/1
friend [6] 19/10 19/12
27/19 27/19 27/21
28/16
friend's [1] 27/22
froze [2] 13/6 13/17
frozen [4] 13/5 13/8
13/11 13/13
fully [1] 34/5
funds [7] 14/18 17/13
25/23 31/6 31/7 31/14
35/2
further [5] 16/18 19/6
34/5 36/1 39/6
furtherance [1] 15/8
G
gain [1] 10/2
gave [2] 13/24 37/9
get [1] 18/16
getting [2] 35/21 38/2
give [4] 16/24 37/11
39/6 39/9
given [2] 9/5 38/21
gives [3] 10/19 11/5
11/16
giving [2] 20/3 24/10
Glendale [5] 2/8 21/5
21/22 21/24 22/3
Glenoaks [1] 2/7
gmail.com [1] 1/24
go [15] 4/7 5/1 8/2 14/2
20/14 20/21 22/20
22/21 24/16 29/6 29/12
34/5 37/13 37/15 39/14
God [1] 4/15
going [19] 4/2 4/8 5/9
9/7 14/2 17/20 22/18
24/6 24/9 25/23 28/18
29/19 30/14 34/5 35/7
35/22 36/1 36/14 38/2
good [5] 3/3 3/4 3/11
3/13 34/11
goods [1] 15/4
Got [1] 26/23
government [14] 5/23
9/15 9/16 11/6 12/3
12/9 12/21 14/7 30/15
37/8 38/6 38/7 38/20
38/23
government's [2]
36/18 36/20
greater [1] 33/1
greatest [1] 10/4
greet [1] 27/20
Grigoryan [43]
Grigoryan's [2] 15/20
29/17
gross [2] 10/2 10/3
guess [2] 25/7 26/14
guidelines [2] 12/12
12/17
guilty [29] 3/21 3/21
3/25 3/25 4/1 4/6 5/2
5/10 5/12 5/22 9/4 9/11
9/13 10/5 10/19 10/21
11/7 11/23 17/18 17/19
17/22 30/23 31/19
34/12 36/10 36/13
39/14 39/17 39/17
H
had [13] 5/14 8/2 8/14
8/18 13/2 13/23 22/20
24/1 24/16 27/15 28/16
28/23 35/17
hand [1] 4/10
harm [1] 14/24
has [8] 5/2 5/21 9/18
24/20 30/19 34/15
36/22 36/23
have [29] 5/14 5/15
8/23 9/5 10/24 11/3
11/6 11/14 11/18 13/3
17/17 18/8 18/21 20/1
22/10 22/13 23/11
27/12 27/24 28/9 28/10
29/14 30/15 30/17
30/22 31/23 32/1 36/7
39/14
haven't [1] 31/10
having [3] 7/6 7/7 33/1
HAYRAPETYAN [27]
1/9 3/9 3/14 3/17 5/4
{PLAINTIFF} v.
{WITNESSNAME}
{DEFENDANT}
{DATE}
Pat Cuneo CSR 1600, Official Reporter
(3) Dadyan... - HAYRAPETYAN
Case 2:20-cr-00579-SVW Document 866 Filed 08/12/21 Page 43 of 47 Page ID
#:15355
H
HAYRAPETYAN... [22]
5/5 5/6 5/7 5/8 5/9 8/10
8/13 15/13 15/13 15/14
17/17 19/22 26/7 26/15
27/6 31/19 32/14 33/6
34/10 34/20 34/24
35/14
he [72]
he'll [2] 35/15 35/16
he's [14] 9/12 26/13
26/24 31/13 35/23
35/24 37/9 38/1 38/13
38/20 38/21 38/21
38/22 39/16
hear [7] 4/4 13/9 13/16
13/20 19/16 26/24
28/22
heard [2] 35/9 37/22
hearing [3] 1/19 23/17
26/23
held [1] 40/6
help [2] 4/15 38/23
here [5] 3/7 11/20
18/13 36/3 39/16
hereby [1] 40/3
him [33] 4/22 6/8 6/8
6/22 6/24 7/10 7/15
7/18 7/19 7/25 8/2 10/6
11/7 11/9 11/15 11/24
18/13 18/14 18/16 19/8
19/9 19/11 23/24 26/25
27/1 28/10 28/14 28/16
28/17 38/1 39/4 39/13
39/14
himself [1] 38/14
his [25] 3/15 9/18 12/7
16/4 16/23 17/12 19/20
22/23 26/12 28/25 29/4
29/18 30/18 31/4 34/1
34/2 36/25 37/9 37/10
38/14 38/22 38/24 39/2
39/2 39/10
history [2] 12/19 12/19
Honor [55]
Honor's [1] 31/16
HONORABLE [3] 1/4
3/8 39/20
hoping [1] 39/1
hours [1] 8/24
house [3] 23/13 23/16
38/7
how [21] 3/24 6/11 7/4
18/16 19/8 20/4 21/12
23/14 23/22 24/1 24/2
25/4 27/1 27/9 27/16
28/12 28/18 28/20
29/15 35/23 35/24
however [1] 11/1
huh [1] 19/5
I
I'll [1] 39/7
I'm [23] 4/21 5/9 17/20
19/5 19/20 19/23 21/18
23/12 24/19 25/3 25/14
26/12 28/18 28/18
28/19 30/14 30/18 34/3
34/5 35/6 35/25 37/5
37/14
I've [1] 7/8
if [22] 9/16 10/24 11/2
11/13 12/20 14/6 19/24
20/3 25/16 28/19 29/17
30/15 30/22 31/13
31/16 32/7 34/10 34/19
36/9 37/3 37/11 38/10
illegal [1] 16/4
illicit [1] 14/14
image [1] 13/7
important [2] 9/4 9/14
impose [1] 9/25
imprisonment [1] 10/1
improperly [1] 14/3
inadequate [3] 34/8
36/2 36/9
include [1] 12/5
included [2] 15/12
15/17
including [8] 11/11
14/11 15/3 16/5 16/9
16/19 18/2 33/11
incorrectly [1] 28/20
indication [1] 34/14
Indictment [19] 3/22
3/25 10/6 11/24 18/5
21/14 24/19 31/11
31/15 31/17 31/21
31/23 32/4 33/17 33/18
37/17 38/1 38/11 38/11
induce [1] 5/22
influence [1] 19/23
information [3] 7/10
16/23 27/13
informing [1] 19/7
initial [1] 19/7
Injury [1] 14/19
innocent [1] 11/5
inquire [2] 29/4 29/5
instance [1] 17/1
institution [1] 15/12
institutions [1] 33/12
instruct [1] 22/1
instructed [2] 27/12
34/19
instructions [1] 13/24
insured [2] 15/12
33/11
intended [1] 36/9
intention [1] 3/20
interpreter [11] 2/13
4/5 4/18 6/10 7/14 8/20
19/13 26/12 26/22 29/4
29/8
interrupt [1] 6/8
interrupted [1] 14/3
introduced [4] 19/8
19/10 27/18 28/16
introduction [1] 18/17
involved [2] 20/11 23/7
involvement [1] 19/24
involving [2] 10/11
32/19
is [87]
isn't [3] 30/21 31/11
34/11
issue [1] 39/7
issued [1] 37/19
issues [1] 24/17
it [56]
it's [8] 4/21 5/7 24/5
27/10 34/6 35/6 35/10
36/6
its [1] 15/9
Iuliia [1] 17/4
J
jail [2] 6/24 7/11
jilbert [3] 2/6 2/9 3/14
jilbertlaw.com [1] 2/9
job [3] 18/19 18/25
39/16
join [1] 15/8
judge [2] 1/4 13/6
Judicial [1] 40/8
June [3] 1/17 3/1 40/10
jury [3] 10/22 34/9
34/10
just [18] 4/21 6/25
18/18 20/8 23/13 24/20
25/2 26/9 28/1 28/8
31/7 31/25 34/8 35/13
36/2 37/4 37/11 37/11
K
Kauichko [2] 16/17
17/10
keep [1] 29/19
kept [1] 24/5
kind [5] 18/20 22/20
29/10 38/11 38/11
knew [6] 10/13 10/15
16/3 28/6 30/6 35/24
knock [1] 37/19
know [17] 18/11 21/12
24/12 27/3 27/9 30/9
31/2 31/5 31/7 31/14
34/1 34/4 34/8 35/1
35/1 35/23 35/25
knowing [2] 32/20 38/2
knowingly [4] 10/10
14/12 32/18 32/24
knowledge [1] 39/2
known [3] 14/10 18/2
32/15
knows [1] 39/3
L
laborer [1] 23/9
language [10] 6/6 7/1
7/4 7/7 7/9 20/22 21/7
21/10 21/10 27/8
large [3] 19/2 29/11
38/3
last [2] 8/24 19/19
later [4] 6/10 8/20 32/5
32/9
launder [2] 16/2 17/13
laundering [17] 9/25
10/7 11/25 12/6 14/13
15/1 15/8 18/6 30/16
30/23 31/2 31/3 31/20
31/22 31/25 32/17
34/12
law [3] 2/6 2/7 14/22
lawyer [4] 5/15 6/15
8/14 30/11
least [4] 12/23 14/9
19/6 32/10
left [1] 37/23
legally [1] 15/22
legitimate [1] 34/22
lenders [2] 33/11 33/11
Let [4] 6/25 19/21 20/8
33/15
letter [2] 27/1 27/10
level [2] 12/6 12/11
like [9] 21/19 23/2 23/8
25/7 27/10 27/10 28/10
28/11 29/14
limited [1] 12/7
line [3] 17/25 21/16
29/21
lines [1] 21/15
listed [4] 15/17 15/21
21/14 25/11
listened [1] 7/17
little [1] 26/9
living [1] 37/21
loan [10] 14/19 16/12
17/2 17/15 25/25 29/24
31/17 31/18 33/9 33/12
loans [11] 15/17 15/23
16/3 17/7 25/22 25/23
30/8 30/9 31/12 33/14
35/2
located [1] 21/3
location [4] 10/17
14/15 32/22 37/20
log [1] 16/23
log-in [1] 16/23
long [3] 23/22 24/1
24/2
look [1] 25/16
looking [3] 18/19 21/18
25/14
looks [2] 25/7 27/10
Los [5] 1/15 1/23 2/5
2/16 32/11
Los Angeles [1] 32/11
loss [1] 10/3
low [1] 12/14
low-end [1] 12/14
luxury [1] 15/3
M
Madam [1] 4/18
made [6] 5/11 5/21
13/23 16/20 38/15
38/18
MAGDALINA [1] 2/13
mail [3] 33/16 33/16
33/17
main [1] 35/10
make [4] 4/13 12/14
12/16 24/13
man [2] 38/13 38/24
managed [1] 16/1
mandatory [1] 10/4
manner [1] 33/4
Manuk [2] 14/11 32/13
many [4] 7/7 25/4
28/10 28/12
March [15] 12/22 14/9
14/22 18/1 18/15 18/21
23/19 23/24 24/8 24/24
25/1 26/9 32/6 32/9
37/18
March 2020 [6] 12/22
14/9 14/22 18/1 32/6
32/9
Marietta [3] 16/6 28/3
32/12
material [1] 36/24
matter [4] 3/8 36/15
39/5 40/7
maximum [4] 9/9 9/24
13/4 13/24
may [19] 3/5 6/1 6/10
7/12 7/13 7/16 16/8
24/7 24/16 24/16 24/24
29/4 29/22 32/1 34/22
35/8 37/4 39/3 39/8
May 25th [1] 6/1
May 27th [3] 6/10 7/13
7/16
May 4th [2] 16/8 29/22
maybe [2] 13/3 29/13
me [30] 5/10 6/21 6/25
13/9 13/16 13/20 17/21
18/18 19/7 19/10 19/21
20/2 20/3 20/8 22/11
22/19 24/10 26/20
26/21 27/20 27/24
28/16 28/19 31/24
31/24 33/15 34/9 35/24
37/11 39/16
mean [2] 27/3 29/16
means [1] 33/4
meant [1] 30/12
Media [4] 16/14 16/14
16/15 30/1
medications [1] 8/24
meet [8] 18/14 18/16
19/8 23/23 23/24 28/5
28/12 37/20
meeting [1] 23/21
meetings [2] 8/13
{PLAINTIFF} v.
{WITNESSNAME}
{DEFENDANT}
{DATE}
Pat Cuneo CSR 1600, Official Reporter (4) HAYRAPETYAN... - meetings
Case 2:20-cr-00579-SVW Document 866 Filed 08/12/21 Page 44 of 47 Page ID
#:15356
M
meetings... [1] 28/10
mention [2] 28/7 33/15
met [11] 6/23 7/10
18/13 20/4 23/23 24/3
24/7 28/14 28/17 37/8
38/20
might [2] 29/12 29/12
military [2] 23/12 38/25
mind [2] 8/17 38/10
mine [2] 19/10 27/20
minutes [2] 37/4 37/12
misinterpreted [1]
39/12
mispronounce [1] 8/12
missing [1] 24/19
modify [1] 28/21
moment [2] 25/12 32/1
monetary [1] 32/24
money [21] 9/25 10/7
11/24 12/6 14/12 15/1
15/8 18/6 22/11 22/11
30/16 30/23 31/1 31/3
31/20 31/22 31/25
32/17 34/12 35/17
35/22
monies [1] 35/3
monitoring [1] 38/8
month [2] 26/9 35/17
more [5] 8/4 10/9 20/3
36/8 39/8
morning [2] 3/11 3/13
most [1] 23/21
motion [2] 12/16 36/21
motions [1] 11/18
mouth [1] 4/20
Mr [2] 5/6 8/9
Mr. [30] 3/14 5/4 5/9
5/15 5/18 6/16 6/19
8/13 8/17 9/7 9/21
17/17 19/22 22/1 22/22
26/7 26/15 27/6 27/11
27/18 27/25 30/14
31/19 34/10 34/11
34/20 34/21 34/24
35/14 36/7
Mr. Grigoryan [5] 22/1
22/22 27/11 27/18
34/21
Mr. Hayrapetyan [14]
3/14 5/4 5/9 8/13 17/17
19/22 26/7 26/15 27/6
31/19 34/10 34/20
34/24 35/14
Mr. Paetty [4] 9/7 9/21
27/25 30/14
Mr. Tahmazian [6]
5/15 6/16 6/19 8/17
34/11 36/7
Mr. Tahmazian's [1]
5/18
much [2] 5/20 28/9
must [1] 10/8
muting [1] 4/22
my [17] 5/25 7/14 7/14
19/3 22/17 22/24 23/1
23/13 23/15 27/19
28/16 30/11 34/6 37/17
37/23 38/10 39/16
myself [1] 4/22
N
name [14] 3/16 3/18
16/16 19/4 19/18 19/19
19/20 22/10 23/1 25/25
26/13 27/22 29/14 34/1
named [1] 18/5
names [10] 15/12
15/21 20/6 21/15 22/14
27/6 27/25 28/1 28/7
33/13
nature [3] 10/17 14/15
32/22
necessary [2] 10/24
11/2
need [6] 19/6 29/5 31/2
31/5 36/4 37/4
needed [1] 23/14
needs [2] 22/10 31/7
never [3] 8/25 15/22
28/6
no [33] 1/8 5/24 7/20
8/21 8/25 12/18 13/5
13/11 18/13 20/19
21/11 21/24 23/11
23/25 24/25 25/10 28/9
30/4 30/4 32/5 32/9
33/24 34/22 35/4 35/4
35/19 35/20 35/21 36/6
36/24 39/14 39/17
40/16
nobody [1] 18/10
nonlawyer [1] 7/25
normal [1] 8/22
North [1] 2/4
not [39] 3/21 3/25
10/21 11/13 11/14
11/15 11/21 12/24 19/5
19/6 19/22 20/3 20/10
22/21 24/5 24/10 25/3
26/12 26/15 29/11
30/19 31/2 31/5 31/15
34/5 34/5 34/6 35/1
35/1 35/11 35/23 35/24
35/25 36/3 36/4 36/7
38/9 38/13 38/24
nothing [1] 4/14
now [12] 3/20 3/24 9/7
13/9 13/19 13/20 14/2
17/17 23/17 28/18
30/14 37/1
number [2] 25/17 38/3
O
oath [2] 4/3 4/9
object [2] 14/13 15/10
obtain [1] 33/13
obtained [4] 14/17
15/17 16/3 17/15
occasion [2] 8/5 18/17
occasions [1] 6/24
occurred [1] 8/14
October [5] 12/23
14/10 18/1 18/12 32/10
October 2020 [4] 14/10
18/1 18/12 32/10
off [3] 7/16 13/18 29/4
offense [4] 9/10 10/3
12/5 39/2
offenses [2] 9/10 32/16
offer [1] 18/25
offering [1] 18/18
office [1] 7/14
offices [1] 37/23
Official [2] 1/21 40/16
Oh [2] 19/17 38/16
okay [6] 5/8 13/19
13/20 13/22 24/18 27/9
on [42]
once [2] 24/4 26/17
one [21] 8/4 10/9 12/24
16/14 16/14 16/15 23/1
24/6 25/4 25/7 25/12
26/2 26/9 30/1 30/1
31/21 31/21 32/1 32/15
39/3 39/8
online [3] 20/14 25/1
25/2
only [15] 4/22 24/4
24/8 24/15 24/16 26/8
26/10 26/21 28/6 28/14
28/17 30/10 30/11
33/16 39/3
oOo [2] 3/2 39/23
open [15] 19/3 22/2
22/10 22/13 22/23
24/23 26/6 26/10 26/18
26/21 27/12 28/24
29/14 34/19 35/14
opened [19] 15/11
15/19 20/16 21/13
21/17 21/20 24/12
24/13 24/19 24/20
24/23 24/25 25/5 26/8
26/18 27/7 28/13 28/14
30/7
opportunity [1] 5/14
opposition [1] 11/11
or [46]
order [9] 9/8 9/22
14/14 16/13 22/11
22/23 29/25 39/7 39/10
ordinary [1] 38/24
other [23] 5/22 11/3
11/18 11/22 12/22 14/8
16/9 16/18 16/21 18/4
18/7 18/8 18/9 20/2
23/22 24/8 24/24 28/1
28/8 33/7 37/2 38/7
39/17
others [6] 14/11 15/10
18/2 18/3 18/7 32/15
ought [2] 36/11 36/11
out [5] 15/9 16/20
27/13 30/11 39/4
outlined [1] 12/3
outside [1] 29/18
over [6] 7/11 28/15
35/6 35/7 36/6 36/8
own [2] 23/13 38/14
ownership [3] 10/17
14/15 32/22
P
p.m [1] 39/21
PAETTY [7] 2/3 3/12
9/7 9/21 25/9 27/25
30/14
page [10] 7/12 17/20
17/24 21/16 21/16
25/14 29/21 31/4 32/3
40/7
paid [1] 34/24
pandemic [1] 14/25
paper [1] 27/14
papers [1] 26/21
paperwork [1] 27/15
paragraph [2] 12/4
12/4
Paronyan [4] 16/7 28/4
32/14 33/7
part [3] 10/16 16/12
32/21
participation [1] 30/20
parties [1] 11/21
partner [1] 15/20
parts [1] 9/8
password [1] 16/23
PAT [3] 1/21 40/3
40/16
patcuneo1600 [1] 1/24
paternal [1] 23/15
Paul [2] 3/4 13/16
Pause [3] 13/15 25/13
32/2
pay [5] 22/11 22/18
22/23 28/25 29/18
Paycheck [1] 14/18
payment [1] 17/12
payments [2] 16/20
17/9
PC [1] 2/6
penalty [3] 9/9 13/4
13/24
people [4] 18/5 22/19
28/5 39/3
percent [4] 7/7 17/12
22/12 34/24
perhaps [2] 31/10 34/6
period [2] 10/1 23/19
permissible [1] 15/5
persist [1] 10/21
person [1] 39/3
personal [1] 15/3
personally [3] 20/15
26/18 27/7
perspective [1] 35/13
phone [1] 28/16
phonetically [1] 8/11
place [1] 34/6
placed [1] 11/6
plain [1] 36/2
Plaintiff [2] 1/7 2/2
plea [39] 1/19 3/21
3/21 5/11 5/12 5/22
5/25 6/4 6/14 6/16 6/21
7/11 7/15 7/18 7/18
7/22 8/1 8/3 8/7 8/17
9/8 9/15 9/17 10/21
11/20 12/8 14/1 17/20
17/24 20/5 21/19 22/15
24/11 24/23 27/8 34/13
35/6 36/7 39/11
plead [7] 3/24 5/22
11/23 19/25 36/10
36/13 39/13
pleading [8] 9/4 9/11
9/13 10/19 17/19 19/25
31/19 39/16
pleas [1] 34/6
please [4] 3/10 3/15
9/21 35/9
pled [1] 5/2
plus [1] 12/6
point [4] 19/7 31/14
35/11 39/18
points [1] 9/14
portion [1] 23/1
position [2] 36/18
36/20
possibility [1] 12/15
possible [3] 4/19 5/16
38/6
possibly [1] 30/20
PPP [17] 14/19 15/6
15/17 16/3 16/12 17/1
17/7 17/15 29/24 30/8
30/9 31/6 31/12 31/17
33/9 34/25 35/2
prepared [4] 12/21
14/7 36/11 36/12
presence [1] 7/14
present [3] 2/13 11/10
11/14
presenting [1] 18/23
PRESIDING [1] 1/4
presumed [1] 11/5
pretrials [1] 11/18
previous [1] 36/22
previously [2] 36/18
38/19
prior [2] 23/19 38/5
proceed [4] 5/3 12/20
14/3 14/6
proceeding [1] 5/3
proceedings [7] 1/14
11/4 13/15 25/13 32/2
39/21 40/6
proceeds [24] 10/11
{PLAINTIFF} v.
{WITNESSNAME}
{DEFENDANT}
{DATE}
Pat Cuneo CSR 1600, Official Reporter
(5) meetings... - proceeds
Case 2:20-cr-00579-SVW Document 866 Filed 08/12/21 Page 45 of 47 Page ID
#:15357
P
proceeds... [23] 10/14
10/18 14/14 14/16
14/17 15/2 15/16 15/23
16/2 16/4 16/12 17/2
17/6 17/12 17/15 29/24
31/2 31/6 31/8 32/19
32/23 33/12 34/25
proffered [2] 36/23
36/24
Program [2] 14/18
14/19
programs [2] 14/20
15/6
promises [1] 5/22
pronunciation [2] 5/5
26/12
proof [1] 11/6
property [4] 10/11
10/13 32/25 33/1
prosecutor [2] 25/9
28/8
Protection [1] 14/18
prove [3] 11/7 12/21
14/7
provide [1] 14/23
provided [2] 12/12
16/22
provisions [1] 15/5
public [1] 10/22
pulling [1] 36/3
punishment [1] 38/23
purchase [1] 15/3
purpose [2] 15/9 15/16
pursuant [1] 40/4
pursue [1] 11/16
put [4] 24/15 34/2
35/13 38/9
Q
question [6] 23/22
25/3 27/18 31/16 34/10
39/8
questions [9] 4/3 4/9
4/13 5/10 8/1 8/3 17/21
19/22 30/14
R
raise [1] 4/10
rather [1] 15/4
reached [1] 5/23
read [8] 7/18 7/19
27/25 28/1 28/8 31/1
31/24 32/7
reading [1] 17/19
real [1] 15/4
realize [2] 9/3 35/19
reason [1] 39/17
reasonable [3] 11/7
12/21 14/7
received [1] 17/11
receiving [2] 15/16
22/12
recess [1] 39/20
recommend [1] 12/11
recommendation [1]
12/14
reconsider [1] 36/21
recruited [1] 15/7
reduction [1] 12/11
referenced [1] 16/20
refile [1] 39/11
regard [1] 12/18
regarding [2] 9/17 20/4
regulations [1] 40/8
rejected [1] 36/17
rejecting [2] 35/6 36/6
relates [1] 33/23
release [1] 10/2
relief [3] 14/18 14/20
14/21
remaining [1] 12/9
remember [1] 23/17
reported [1] 40/6
Reporter [2] 1/21
40/16
REPORTER'S [1] 1/14
represent [1] 18/21
representation [2]
5/19 15/20
represented [4] 10/11
10/13 10/23 11/2
requirements [1] 9/18
responsibility [3]
12/13 37/10 38/22
result [2] 14/24 15/1
resulting [1] 10/3
retained [1] 37/23
retains [1] 11/1
review [2] 9/8 13/3
reviewed [1] 13/23
Richard [5] 16/5 17/5
28/3 32/12 33/5
Richard Ayvazyan [4]
17/5 28/3 32/12 33/5
right [18] 4/10 5/1 5/4
5/8 8/15 8/23 10/21
10/22 10/23 11/2 11/5
11/8 11/10 11/11 11/13
25/17 30/13 39/5
rights [5] 9/12 10/20
11/16 13/5 13/25
risk [1] 38/13
role [1] 39/2
Room [1] 1/23
S
S.Construction [1]
29/23
S.S [2] 25/6 26/3
said [7] 7/22 13/11
13/22 22/13 26/18
29/10 34/15
same [7] 20/24 21/18
21/22 25/15 26/7 36/21
36/23
satisfied [3] 5/18 7/21
17/18
say [8] 17/24 18/6
19/21 24/19 27/1 34/15
34/18 36/13
saying [10] 19/20 20/2
20/4 22/9 22/24 26/13
26/24 28/22 29/9 29/13
says [4] 25/24 29/21
30/5 34/10
SBA [2] 33/10 33/10
SBA-approved [1]
33/10
scheme [3] 14/14
31/18 31/18
SCOTT [2] 2/3 3/12
Scott Paetty [1] 3/12
screen [2] 13/5 13/11
seal [1] 27/15
second [3] 9/10 12/24
18/19
Section [1] 40/4
secure [1] 38/17
secured [2] 38/8 38/18
Security [1] 14/21
see [10] 4/20 8/6 21/6
25/18 25/24 26/1 26/2
26/3 38/13 39/1
seeking [1] 19/23
seem [2] 13/18 13/19
seems [3] 21/19 25/19
34/9
sentence [3] 9/24 12/8
12/16
sentencing [6] 12/2
12/5 12/10 12/12 12/14
12/17
separate [3] 6/24 17/9
33/20
September [1] 24/8
serious [1] 9/4
serve [1] 23/11
services [1] 15/4
set [5] 15/14 20/6 20/9
20/13 27/7
shall [1] 4/13
should [5] 22/5 22/23
36/3 36/4 36/13
show [2] 30/23 38/23
shows [1] 5/25
side [1] 37/10
sign [4] 13/18 13/18
13/18 30/3
signal [1] 36/12
signed [7] 6/1 6/4 6/8
6/14 7/12 7/16 8/19
Similarly [1] 17/6
since [2] 38/16 38/20
single [1] 7/15
site [1] 35/20
skill [1] 23/15
slowly [1] 32/7
small [2] 29/13 33/10
smaller [1] 16/19
so [33] 3/21 4/14 4/20
5/4 5/20 6/14 7/21 8/11
14/3 17/24 20/1 21/13
23/2 23/12 23/14 24/4
24/15 25/14 25/24 26/3
26/10 26/12 28/14
28/16 28/24 29/4 29/9
29/13 30/10 31/1 31/10
38/16 39/9
solemnly [1] 4/12
some [21] 4/2 4/8 5/9
10/14 16/19 16/21
17/21 19/6 20/6 21/17
21/18 22/18 23/7 24/24
30/14 30/20 31/8 34/14
35/16 35/16 38/5
somebody [1] 38/10
something [5] 23/2
24/20 34/4 35/25 38/24
sorry [2] 37/14 39/9
sort [1] 30/20
sound [2] 13/5 13/12
source [5] 10/17 14/15
31/5 32/22 35/1
sourced [1] 31/7
speak [4] 4/23 21/9
21/12 36/7
speaking [2] 21/11
29/8
special [1] 10/4
specific [3] 9/8 13/2
39/10
specifically [1] 31/12
specified [3] 32/19
32/23 33/2
speedy [1] 10/22
spelling [2] 19/13
19/17
spoke [4] 6/8 20/21
21/7 30/11
spoken [2] 7/6 36/7
Spring [1] 2/4
stage [1] 11/3
stake [1] 39/14
stands [1] 39/20
state [2] 3/10 3/15
stated [1] 12/8
statement [1] 38/21
STATES [12] 1/1 1/6
2/2 2/3 2/4 3/9 3/12
23/20 24/2 32/16 40/4
40/9
statutory [1] 9/24
stenographically [1]
40/6
STEPHEN [2] 1/4 3/8
story [1] 37/9
Street [3] 1/22 1/22 2/4
study [1] 7/3
submission [1] 33/8
submitted [1] 33/8
substantial [2] 16/12
29/24
substantially [2] 30/7
30/8
substantive [1] 33/20
such [4] 10/18 15/2
33/1 33/13
suffering [1] 14/24
summary [1] 9/14
Superseding [5] 3/22
3/25 10/6 11/23 32/3
supervise [1] 22/20
supervised [2] 10/1
16/1
supervision [1] 35/16
supposed [2] 37/20
37/20
Sure [1] 4/21
sureties [2] 36/24
38/17
surety [1] 39/4
SVW [2] 1/8 3/8
swear [1] 4/12
sworn [1] 5/3
T
TAHMAZIAN [10] 2/6
2/6 3/14 5/6 5/15 6/16
6/19 8/17 34/11 36/7
Tahmazian's [1] 5/18
take [6] 4/19 7/24 18/8
23/2 38/22 39/5
taken [1] 8/23
talking [3] 4/21 23/12
31/13
Tamara [4] 16/6 28/4
32/13 33/6
teeth [1] 36/3
teleconference [1]
12/2
telephone [4] 6/9 6/20
7/14 8/18
tell [11] 6/21 20/1 22/5
22/8 22/22 27/1 27/5
27/5 28/18 28/19 29/2
telling [1] 35/24
Terabelian [5] 16/6
28/3 30/2 32/13 33/5
Terabelian's [1] 16/16
terms [1] 38/7
testify [4] 11/10 11/12
11/13 11/14
than [9] 5/22 7/19 8/4
15/4 18/9 28/1 32/5
32/9 33/1
Thank [6] 4/17 29/7
35/9 37/16 39/7 39/19
that [166]
that's [22] 6/3 6/10
6/13 6/18 9/2 22/25
23/2 23/14 25/7 25/21
25/25 26/2 26/23 27/16
29/13 29/14 29/20
30/11 31/15 33/19 34/9
39/18
their [1] 15/3
them [3] 20/16 24/23
35/4
then [14] 7/13 9/20
{PLAINTIFF} v.
{WITNESSNAME}
{DEFENDANT}
{DATE}
Pat Cuneo CSR 1600, Official Reporter
(6) proceeds... - then
Case 2:20-cr-00579-SVW Document 866 Filed 08/12/21 Page 46 of 47 Page ID
#:15358
T
then... [12] 16/1 19/3
24/7 24/8 24/16 25/1
25/19 28/17 33/4 37/6
38/16 38/20
there [28] 5/11 7/25
8/16 12/18 18/5 20/3
21/7 22/20 24/15 25/4
25/10 26/1 29/5 31/20
33/20 33/22 33/25
34/14 34/22 35/4 35/4
35/19 35/20 35/20
36/15 37/19 37/22 38/5
there's [5] 25/5 25/17
25/18 34/11 36/24
these [23] 14/17 15/19
16/22 16/24 17/23
19/22 20/13 21/9 22/14
24/11 24/18 24/20
24/22 28/13 29/17 30/6
34/6 34/12 34/19 34/23
35/14 36/4 36/10
they [7] 21/2 21/4
21/14 22/18 29/12 31/8
31/13
thing [2] 35/13 39/13
things [5] 11/22 12/22
14/8 23/14 28/11
think [5] 7/25 13/3 13/6
13/22 36/11
thinking [1] 9/1
third [3] 9/12 36/16
36/21
this [45]
those [13] 14/15 15/23
21/17 26/3 26/6 28/1
28/5 28/7 28/24 30/7
31/5 31/7 35/2
thought [3] 9/5 38/10
39/6
threats [1] 5/21
three [9] 10/1 12/11
25/4 25/7 25/10 26/3
26/3 26/17 26/19
three-level [1] 12/11
three-year [1] 10/1
through [5] 6/9 14/20
25/1 31/4 37/25
time [11] 12/10 12/16
18/19 23/24 24/6 24/8
24/13 26/7 37/4 38/6
38/9
times [2] 26/7 28/12
Title [1] 40/4
today [2] 9/1 9/3
together [7] 14/10 16/9
16/18 18/1 20/2 33/7
38/9
told [8] 6/8 6/21 19/1
26/20 28/22 28/25
35/15 38/1
too [1] 28/10
total [1] 38/17
totaled [1] 17/16
totally [1] 7/21
TRACY [1] 2/2
transaction [4] 10/10
10/15 32/21 35/15
transactions [2] 32/19
32/25
transcript [3] 1/14 40/5
40/7
transfer [4] 14/13 17/3
17/9 22/10
transferred [1] 31/3
transferring [1] 25/2
transfers [1] 16/22
translate [1] 7/15
translated [2] 6/5 6/9
translation [2] 8/19
8/21
translator [3] 7/17
26/15 27/6
traveling [1] 23/18
trial [10] 10/22 10/25
12/20 14/6 30/16 30/23
35/7 36/14 38/2 39/14
tried [1] 26/16
true [4] 3/18 10/8 19/24
40/5
truth [3] 4/14 4/14 4/14
truthful [1] 34/9
try [1] 38/23
trying [2] 23/1 38/21
turning [1] 27/17
twice [3] 7/10 10/2
13/17
two [22] 6/10 6/24 8/20
14/19 17/7 17/9 21/1
25/1 25/4 25/7 26/3
26/8 26/10 26/10 26/18
26/19 26/21 31/20
36/22 37/2 37/3 38/14
U
Uh [1] 19/5
Uh-huh [1] 19/5
unaware [1] 34/3
under [8] 4/3 4/9 12/16
14/18 15/5 34/12 36/10
39/6
understand [9] 4/25
8/7 22/15 23/22 26/14
29/16 31/11 31/16
34/22
understanding [8]
22/17 22/24 26/12
26/16 28/19 28/20
30/18 34/6
understands [1] 11/1
understood [4] 7/22
22/18 22/25 30/10
undertaken [1] 16/4
undertook [1] 34/21
unfortunate [1] 35/10
UNITED [12] 1/1 1/6
2/2 2/3 2/4 3/9 3/12
23/20 24/2 32/16 40/4
40/9
unknown [3] 14/11
18/2 32/15
unlawful [7] 10/14
10/18 31/8 31/8 32/19
32/23 33/2
unless [1] 24/19
unsatisfied [1] 39/18
unsecured [1] 38/18
until [4] 12/23 18/1
24/16 32/10
untruthful [1] 34/9
up [10] 10/19 11/5
11/16 13/17 20/6 20/8
20/9 20/13 29/12 35/14
upon [1] 7/22
us [1] 39/9
use [1] 28/24
used [5] 11/15 15/4
16/1 29/18 33/13
using [1] 23/15
V
Vahe [4] 16/7 28/4
32/14 33/7
Vahe Dadyan [4] 16/7
28/4 32/14 33/7
value [1] 32/25
various [1] 15/11
Vegas [1] 28/17
version [1] 20/3
very [9] 5/20 7/8 9/3
9/4 22/25 29/11 29/20
35/8 36/9
video [1] 12/2
Viktoria [2] 16/16
17/10
Viktoria Kauichko [1]
17/10
violation [1] 32/16
voice [1] 29/4
voluntarily [1] 5/11
W
waiver [1] 12/7
waiving [1] 9/12
walked [1] 38/3
walking [2] 38/12
38/13
want [9] 13/18 28/19
28/21 31/23 39/11
39/12 39/13 39/13
39/14
wanted [2] 18/19 28/23
warrant [1] 37/19
was [85]
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Zhadko [1] 17/4
{PLAINTIFF} v.
{WITNESSNAME}
{DEFENDANT}
{DATE}
Pat Cuneo CSR 1600, Official Reporter
(7) then... - Zhadko
Case 2:20-cr-00579-SVW Document 866 Filed 08/12/21 Page 47 of 47 Page ID
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