Joint STIPULATION for Order RECOGNIZING THE LIEN OF PRIVATE MONEY SOLUTIONS, INC.… — USA v. Ayvazyan et al (Dkt. 1223)

Summary

A stipulation recognizing the lien of Private Money Solutions, Inc. and Gregory Shirin in real property in Tarzana, California, filed in the U.S. District Court for the Central District of California, Western Division, on December 29, 2021 as Document 1223 in United States of America v. Richard Ayvazyan, et al., Case 2:20-cr-00579-SVW. It is between the government, through Assistant United States Attorney Dan G. Boyle of the Asset Forfeiture Section, and the lenders, through Richard J. Reynolds. It recites that Richard Ayvazyan and Marietta Terabelian executed a Deed of Trust, recorded on June 25, 2020, in favor of California TD Specialists for the benefit of Shirin ($2,000,000.00) and PMS ($112,500.00), in the original principal amount of $2,112,500.00, and states that the lenders hold valid pre-existing liens on the property.

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TRACY L. WILKISON 
United States Attorney 
SCOTT M. GARRINGER  
Assistant United States Attorney 
Chief, Criminal Division 
JONATHAN GALATZAN 
Assistant United States Attorney 
Chief, Asset Forfeiture Section 
DAN G. BOYLE (Cal Bar No. 332518) 
Assistant United States Attorney 
Asset Forfeiture Section 
Federal Courthouse, 14th Floor 
312 North Spring Street 
Los Angeles, California 90012 
Telephone: (213) 894-2426 
Facsimile: (213) 894-0142 
E-mail: 
Daniel.Boyle2@usdoj.gov 
 
Attorneys for Plaintiff 
UNITED STATES OF AMERICA 
 
UNITED STATES DISTRICT COURT 
 
FOR THE CENTRAL DISTRICT OF CALIFORNIA 
 
WESTERN DIVISION 
 
UNITED STATES OF AMERICA, 
Plaintiff, 
v. 
RICHARD AYVAZYAN, 
     Aka “Richard Avazian” and 
“Iuliia Zhadko,” et al.,  
 
          Defendants. 
 
 
 
 
No. CR 20-00579-SVW 
STIPULATION RECOGNIZING LIEN OF  
PRIVATE MONEY SOLUTIONS, INC. AND 
GREGORY SHIRIN IN REAL PROPERTY 
LOCATED AT 4910 TOPEKA DRIVE, 
TARZANA CALIFORNIA, WITH 
ASSESSOR’S PARCEL NUMBER: 2176-
029-031 
 
 
 
Plaintiff United States of America (“Plaintiff”) and Private 
Money Solutions, Inc. (“PMS”) and Gregory Shirin (“Shirin”) 
(collectively the “Lenders”) hereby stipulate and agree to the 
following: 
1. 
On March 9, 2021, the United States of America filed a 
First Superseding Indictment including an allegation of forfeiture 
Case 2:20-cr-00579-SVW     Document 1223     Filed 12/29/21     Page 1 of 5   Page ID
#:19488

 
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with regard to the real property located at 4910 Topeka Drive, 
Tarzana California, with Assessor’s Parcel Number: 2176-029-031 (the 
“Subject Property”). 
2. 
On June 17, 2020, Sean Michaels, a single man executed a 
Grant Deed to Richard Ayvazyan and Marietta Terabelian, husband and 
wife as community property recorded on June 25, 2020 in the Riverside 
County Recorder’s Office, Instrument No. 2020-0695394. 
3. 
On June 25, 2020, Richard Ayvazyan and Marietta Terabelian, 
husband and wife as community property, executed a Deed of Trust in 
favor of California TD Specialists for the benefit of Shirin 
($2,000,000.00) and PMS ($112,500.00) recorded on June 25, 2020 in 
the Riverside County Recorder’s Office, Instrument No. 2020-0695395, 
in the original principal amount of $2,112,500.00, encumbering the 
Subject Property, and securing a Promissory Note (“Note”) in the same 
amount.   
4. 
Lenders hold valid pre-existing liens on the Subject 
Property, which liens are not contested by Plaintiff.  
5. 
Plaintiff and Lenders agree that upon entry of a Final 
Order of Forfeiture forfeiting the Subject Property to Plaintiff, 
Plaintiff will sell the Subject Property if it has not already been 
sold according to the Interlocutory Sale Order.   
6. 
The parties agree to execute further documents, to the 
extent necessary, to convey clear title to the Subject Property to 
Plaintiff and to further implement the terms of this Stipulation.  
7. 
The terms of this Stipulation are contingent upon 
forfeiture of the Subject Property to Plaintiff and the Court’s entry 
of the Final Order of Forfeiture.  
8. 
Plaintiff and Lenders agree that upon entry of the Final 
Case 2:20-cr-00579-SVW     Document 1223     Filed 12/29/21     Page 2 of 5   Page ID
#:19489

 
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Order of Forfeiture and sale of the Subject Property, the funds 
generated by the sale shall be distributed in the following order of 
priority, if available:  
a. 
First, to the United States Marshals Service for its 
costs and expenses of the sale; 
b. 
Second, to the extent sufficient sale funds are 
available, to pay any real property taxes assessed against the 
Subject Property to the date of entry of the Judgment of Forfeiture; 
c. 
Third, to the extent sufficient sale funds are 
available, to Lenders (or any successor lienholder) as follows: 
 
 
 
i. 
$2,253,792.97 due under its Note which is secured 
by the Assignment of Deed of Trust recorded as Instrument No. 2020-
0695395 against the Subject Property identifying Shirin and PMS as 
beneficiaries. 
d. 
Fourth, the balance to Plaintiff pursuant to the terms 
of the Final Order of Forfeiture, i.e., the balance will be forfeited 
to the United States of America and no other right, title or interest 
shall exist herein.  The Government will dispose of the funds in 
accordance with law. 
9. 
The payment to Lenders described above in paragraph 8(c) 
from the sales proceeds of the Subject Property shall be in full 
settlement and satisfaction of any and all claims by Lenders to the 
Subject Property and against Plaintiff resulting from the incidents 
or circumstances giving rise to this lawsuit. 
10. 
Upon payment, Lenders agree to provide its deed of 
reconveyance or such other document reasonably necessary to release 
its security interest to the United States via recordable documents 
and to release and hold harmless the Plaintiff, and any agents, 
Case 2:20-cr-00579-SVW     Document 1223     Filed 12/29/21     Page 3 of 5   Page ID
#:19490

 
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servants, and employees of the government (or any state or local law 
enforcement agency) acting in their individual or official 
capacities, from any and all claims which currently exist or which 
may arise as a result of the government’s action against the Subject 
Property. 
11. 
Lenders hereby agree not to pursue against the Plaintiff 
any other rights that it may have under the Deed of Trust, including, 
but not limited to, the right to initiate a judicial or non-judicial 
foreclosure action, without the consent of the United States 
Attorney’s Office or this Court.  Lenders further agree to join any 
government motions for interlocutory or stipulated sale of the 
Subject Property and any motions to remove occupants from the 
property for nonpayment of rent, destruction of property, or other 
just cause. 
12. 
Lenders understand and agree that by entering into this 
stipulation, it waives any right to further litigate against 
Plaintiff its interest in the Subject Property.  Unless specifically 
directed by order of this Court, Lenders are hereby excused and 
relieved from further participation in this action. 
13. 
The Court will retain jurisdiction to resolve any issues 
with respect to the parties’ performance under this Stipulation. 
// 
// 
// 
 
 
 
 
Case 2:20-cr-00579-SVW     Document 1223     Filed 12/29/21     Page 4 of 5   Page ID
#:19491

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This Stipulation is binding upon Lenders and their successors 
and assigns. 
SO STIPULATED.
DATED: December , 2021 
TRACY L. WILKISON
United States Attorney 
SCOTT M. GARRINGER
Assistant United States Attorney 
Chief, Criminal Division 
JONATHAN GALATZAN 
Assistant United States Attorney 
Chief, Asset Forfeiture Section
_____  
DAN G. BOYLE 
Assistant United States Attorney 
Attorneys for Plaintiff 
United States of America 
DATED: December , 2021 
   _____
RICHARD J. REYNOLDS 
Attorney and Authorized Representative 
for Private Money Solutions, Inc. and 
Gregory Shirin 
DAN G. BOYLE
A
i t
t U
Case 2:20-cr-00579-SVW     Document 1223     Filed 12/29/21     Page 5 of 5   Page ID
#:19492

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