Court filing
Fourth Request for Extension of Time — USA v. Ayvazyan et al. (Dkt. 1035, C.D. Cal.)
Summary
Arman Hayrapetyan, through attorney Jilbert Tahmazian, filed this request on 10/04/21 (Document 1035, Case No. CR 20-579(A)-SVW) for a minimum 30-day extension of the October 3rd, 2021 deadline for surety Evelina Manukyan to replace an affidavit of surety without justification for $50,000 with a full deeding of property. Counsel's declaration recounts the earlier release order (Dkt. No. 444) and says the deadline now in place came from Judge Wilson's most recent extension (Dkt. No. 915). It asks for more time chiefly to complete an appraisal of the property that has been delayed, says the defendant has complied with all other conditions set by Pre-Trial Services and the Court, and keeps all other conditions unchanged.
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Filed October 4, 2021 in USA v. Ayvazyan et al.; one of 698 filings from this case.
Record facts
| Court | U.S. District Court for the Central District of California |
|---|---|
| Filed | 2021-10-04 |
Cite this document
“Fourth Request for Extension of Time — USA v. Ayvazyan et al. (Dkt. 1035, C.D. Cal.).”
U.S. District Court for the Central District of California, No. 2:20-cr-00579-SVW, Doc. 1035, filed 2021-10-04. Archived at Pandemic Darlings, https://pandemicdarlings.com/court-filings/full-docket-arman-hayrapetyan-cacd-813904/2021-10-04-gov-uscourts-cacd-813904-1035-0-doc-1035/
, SHA-256 3f1f6dd9b1b2e4fce7676a2dece2588770b50edfdf1c7594d2bd67c9253fa4b5.Full text
Case 2:20-cr-00579-SVW Document 1035 Filed 10/04/21 Page 1 of 3 Page ID 10 11 12 13 14 15 16 17 18 19 20 22 23 24 25 26 27 28 #:17137 JILBERT TAHMAZIAN; 143574 TAHMAZIAN LAW FIRM P.C. 1518 West Glenoaks Blvd., Glendale, CA 91201 Telephone: (818) 242-8201 Facsimile: (818) 242-8246 Attorney for Defendant, ARMAN HAYRAPETYAN UNITED STATES DISCTRICT COURT CENTERAL DISTRICT OF CALIFORNIA UNITED STATES OF AMERICA, CASE NO.: CR 20-579(A)-SVW REQUEST FOR EXTENSION OF BOND CONDITON VS. ARMAN HAYRAPETYAN, [PROPOSED ORDER FILED CONCURRENTLY] DEFENDANT. Arman Hayrapetyan, by and through counsel, hereby files this request for extension for a condition of his release. Specifically, Mr. Hayrapetyan seeks a minimum 30-day extension for the October 3rd, 2021 deadline of having surety Evelina Manukuyan replace the affidavit of surety without justification for the amount of $50,000 with a full deeding of property!. This application is based on the attached declaration of counsel. ' The property in question is located at 67110 Garbino Road, Cathedral City, CA 92234. Case 2:20-cr-00579-SVW Document 1035 Filed 10/04/21 Page 2 of 3 Page ID #:17138 l DECLARATION OF COUNSEL 2 I, Jilbert Tahmazian, do declare and state: 3 1. I represent Arman Hayrapetyan in this matter. I am licensed to practice in the State of ‘ California, admitted to practice before this Court. 2. On June 7", 2021 Judge Stephen Wilson granted Mr. Hayrapetyan’s application for 7 reconsideration of detention. See Dkt. No. 444. After submitting the bond documents to 8 criminal intake, Magistrate Judge Paul Abrams signed a release order for Mr. Hayrapetyan 9 on June 8", 2021. 10 3. As part of his release, Mr. Hayrapetyan had a surety—Evelina Manukyan—-sign an affidavit of surety without justification for the amount of $50,000 to be replaced with a surety with justification and a full deeding of property.2 14 4. The abovementioned condition was ordered to be met and posted by June 25", 2021. 15 5. Judge Wilson granted his most recent extension for the deadline of having the surety without 16 justification for the amount of $50,000 to be replaced with a surety with justification and a 17 full deeding of property from September 3", 2021 to October 3", 2021 [See Dkt. No. 915] 18 6. Defendant requests additional time to fulfill the obligation required by this Court. Chiefly in 9 order to complete an appraisal on the property which has been subject to delay. 7. The Court, in its first release order, [See Dkt. No. 444; pg. 4] noted—under the “other conditions” subsection—that the deadline may be extended with Court order. 73 8. Accordingly we respectfully ask that the Court order an extension given the circumstances. 24 25 76 ||? The property in question is located at 67110 Garbino Road, Cathedral City, CA 92234. 27 28 Case 2:20-cr-00579-SVW Document 1035 Filed 10/04/21 Page 3 of 3 Page ID #:17139 1 9. Defendant has complied with all other conditions and restrictions set out by Pre-Trial 2 Services and this Court. Moreover, Defendant has displayed a steadfast resolve to atone for 3 his conduct. 4 10. All other conditions would remain unchanged. 5 6 7 Dated: October [illegible] 2021 Respectfully 8 BY: 9 KOA T TAHMAZIAN, 10 orney for Defendant 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 3. 27 28
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- gov.uscourts.cacd.813904.1035.0.pdf
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- 134,000 bytes
- SHA-256
- 3f1f6dd9b1b2e4fce7676a2dece2588770b50edfdf1c7594d2bd67c9253fa4b5
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