EX PARTE APPLICATION for Order for Disclosure Filed by Plaintiff USA as to Defendant… — USA v. Ayvazyan et al (Dkt. 904)

Summary

An ex parte application for an order for disclosure, filed in the U.S. District Court for the Central District of California on August 31, 2021 as Document 904 in United States of America v. Richard Ayvazyan, et al., Case 2:20-cr-00579-SVW, by Assistant United States Attorneys Scott Paetty, Catherine S. Ahn and Brian Faerstein and DOJ Trial Attorney Christopher Fenton. The government asks for an order disclosing information from the U.S. Probation Office on the pretrial supervision of the defendants, including Richard Ayvazyan and Marietta Terabelian. It states that, according to the Probation Office, those two defendants absconded from pre-trial supervision on or about August 29, 2021. The government says it seeks leads on their location, how they absconded and who may have assisted them.

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TRACY L. WILKISON 
Acting United States Attorney 
SCOTT M. GARRINGER 
Assistant United States Attorney 
Chief, Criminal Division 
SCOTT PAETTY (Cal. Bar No. 274719) 
CATHERINE AHN (Cal. Bar No. 248286) 
BRIAN FAERSTEIN (Cal. Bar No. 274850) 
Assistant United States Attorneys 
Major Frauds/Environmental and Community Safety Crimes Sections 
1100/1300 United States Courthouse 
312 North Spring Street 
Los Angeles, California 90012 
Telephone: (213) 894-6527/2424/3819 
Facsimile: (213) 894-6269/0141 
E-mail: 
Scott.Paetty@usdoj.gov 
 
Catherine.S.Ahn@usdoj.gov 
 
Brian.Faerstein@usdoj.gov 
 
JOSEPH BEEMSTERBOER 
Acting Chief, Fraud Section 
Criminal Division, U.S. Department of Justice 
CHRISTOPHER FENTON 
Trial Attorney, Fraud Section 
Criminal Division, U.S. Department of Justice 
1400 New York Avenue NW, 3rd Floor 
Washington, DC 20530 
Telephone: (202) 320-0539 
Facsimile: (202) 514-0152 
 
E-mail: 
Christopher.Fenton@usdoj.gov 
 
Attorneys for Plaintiff 
UNITED STATES OF AMERICA 
 
UNITED STATES DISTRICT COURT 
 
FOR THE CENTRAL DISTRICT OF CALIFORNIA 
 
UNITED STATES OF AMERICA, 
Plaintiff, 
v. 
RICHARD AYVAZYAN, 
aka “Richard Avazian” and 
    “Iuliia Zhadko,” 
MARIETTA TERABELIAN, 
  aka “Marietta Abelian” and     
      “Viktoria Kauichko,” 
ARTUR AYVAZYAN, 
aka “Arthur Ayvazyan,” and 
TAMARA DADYAN, 
MANUK GRIGORYAN, 
  aka “Mike Grigoryan,” and 
No. CR 20-579(A)-SVW 
EX PARTE APPLICATION FOR 
DISCLOSURE ORDER  
Case 2:20-cr-00579-SVW     Document 904     Filed 08/31/21     Page 1 of 4   Page ID
#:15729

 
 
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      “Anton Kudiumov,” 
ARMAN HAYRAPETYAN, 
EDVARD PARONYAN, 
aka “Edvard Paronian” and 
    “Edward Paronyan,” and 
VAHE DADYAN, 
 
Defendants. 
 
Plaintiff United States of America, by and through its counsel 
of record, the Acting United States Attorney for the Central District 
of California, Assistant United States Attorneys Scott Paetty, 
Catherine S. Ahn, and Brian Faerstein, and Department of Justice 
Trial Attorney Christopher Fenton, hereby files an ex parte 
application for an order disclosing information held by the U.S. 
Probation Office related to the pretrial supervision of defendants in 
the above-captioned case, including defendants Richard Ayvazyan and 
Marietta Terabelian. 
According to information provided by the U.S. Probation Office, 
which includes this Court’s Pretrial Services Officers, defendants 
Richard Ayvazyan and Marietta Terabelian absconded from pre-trial 
supervision on or about August 29, 2021.  (Declaration of Catherine 
Ahn ¶ 2.)  The government is seeking information that may assist it 
in obtaining further leads or information regarding the current 
location of defendants Richard Ayvazyan and Marietta Terabelian, how 
they were able to abscond from supervision, and who may have provided 
them assistance in doing so.  The government’s request for 
information includes contact information, such as phone numbers, 
provided to the U.S. Probation Office for the other defendants in 
this case since such information may yield further investigative 
leads related to defendants Richard Ayvazyan and Marietta 
Terabelian’s flight from supervision.  The U.S. Probation Office 
Case 2:20-cr-00579-SVW     Document 904     Filed 08/31/21     Page 2 of 4   Page ID
#:15730

 
 
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informed the government that a court order is necessary for it to 
provide such information to the government.  (Id.)  The government 
therefore requests that this Court issue an order directing that the 
U.S. Probation Office disclose the following information to the 
government: 
1. Any contact information, including phone numbers, email 
addresses, and physical residence or mailing addresses, used 
by defendants in this case (Richard Ayvazyan, Marietta 
Terabelian, Artur Ayvazyan, Tamara Dadyan, Manuk Grigoryan, 
Arman Hayrapetyan, Edvard Paronyan, and Vahe Dadyan) provided 
to and/or used to contact the U.S. Probation Office during 
the course of its pretrial supervision in this case; 
2. The location histories and any tamper or modification 
histories associated with defendants Richard Ayvazyan’s and 
Marietta Terabelian’s location monitoring bracelets and/or 
information available through the location monitoring program 
since May 1, 2021; 
3. The names and contact information, including phone numbers, 
email addresses, and physical residence or mailing addresses, 
of any points of contact provided by defendants Richard 
Ayvazyan and Marietta Terabelian in case of emergency or 
other exigent circumstances; 
4. Any information provided to the U.S. Probation Office related 
to arrangements made by defendants Richard Ayvazyan and 
Marietta Terabelian in the event they were no longer 
available; and  
5. To the extent such information is possessed by the U.S. 
Probation Office, copies of any notes or other correspondence 
Case 2:20-cr-00579-SVW     Document 904     Filed 08/31/21     Page 3 of 4   Page ID
#:15731

 
 
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that were provided by defendants Richard Ayvazyan and/or 
Marietta Terabelian to family members or other points of 
contact related to their departure or lack of availability, 
and the circumstances in which such information was provided. 
This ex parte application and proposed order are based upon the 
attached declaration of Catherine Ahn, the files and records in this 
case, and such further evidence and argument as the Court may permit. 
Dated: August 31, 2021 
Respectfully submitted, 
 
TRACY L. WILKISON 
Acting United States Attorney 
 
SCOTT M. GARRINGER 
Assistant United States Attorney 
Chief, Criminal Division 
 
 
      /s/ 
 
CATHERINE AHN 
SCOTT PAETTY 
BRIAN FAERSTEIN 
Assistant United States Attorney 
CHRISTOPHER FENTON 
Department of Justice Trial Attorney 
 
Attorneys for Plaintiff 
UNITED STATES OF AMERICA 
 
 
Case 2:20-cr-00579-SVW     Document 904     Filed 08/31/21     Page 4 of 4   Page ID
#:15732

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