Exhibit — USA v. Ayvazyan et al (Dkt. 1337.1)

Summary

Exhibit A to Document 1337-1, filed December 8, 2022 in Case 2:20-cr-00579-SVW, is the Declaration of Carlo Brooks in Support of Petitioner Richard Ayvazyan’s Motion to Vacate, Set Aside, or Correct Sentence Under 28 U.S.C. § 2255, captioned Richard Ayvazyan v. United States of America with the civil number 2:22-cv-08915. Brooks, counsel for the petitioner, states that the petitioner did not receive information about the availability of an appeal of his convictions or sentence, and that counsel received the pleadings and trial transcripts from trial counsel on November 28, 2022. The declaration says a fuller statement of supporting facts and law is attached, that a supplemental memorandum on the § 2255 grounds is expected, and that the issues are novel and complex. It was executed December 8, 2022 at Los Angeles, California.

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EXHIBIT A
Case 2:20-cr-00579-SVW     Document 1337-1     Filed 12/08/22     Page 1 of 3   Page ID
#:20334

Carlo Brooks, CA Bar # 316485
3826 Grand View Boulevard, Suite 661472
Los Angeles, CA 90066
(310) 691-9373
carlo@carlobrooks.com
Attorney for Petitioner
RICHARD AYVAZYAN
UNITED STATES DISTRICT COURT
CENTRAL DISTRICT OF CALIFORNIA
WESTERN DIVISION
RICHARD AYVAZYAN,
Petitioner
vs.
UNITED STATES OF AMERICA,
Respondent.
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Case No.:
[CR No. 2:20-cr-579-SVW]
DECLARATION OF CARLO
BROOKS IN SUPPORT OF
PETITIONER RICHARD
AYVAZYAN’S MOTION TO
VACATE, SET ASIDE, OR
CORRECT SENTENCE UNDER
28 U.S.C. § 2255
1
2:22-cv-08915
Case 2:20-cr-00579-SVW     Document 1337-1     Filed 12/08/22     Page 2 of 3   Page ID
#:20335

I, Carlo Brooks, declare as follows:
1.
I am an attorney duly licensed to practice law in the State of California
and Counsel for Petitioner Richard Ayvazyan in the above-captioned matter.
2.
Petitioner was returned to the United States approximately three weeks
ago and was only able to retain post-conviction counsel on or around November 27,
2022.
3.
Petitioner did not receive information concerning the availability of, or
ability to, appeal his convictions and/or sentence
4.
Undersigned counsel received the pleadings and transcripts from trial
counsel on November 28, 2022. In light of these circumstances, undersigned
counsel has attached hereto a more fulsome statement of supporting facts and law
in support of the grounds for relief identified here, and expects to prepare a
supplemental memorandum in support of the those identified § 2255 grounds.
5.
The issues in this case are novel and complex and need to be
thoroughly presented. Because of the nature of the issues herein, it is in Petitioner’s
best interest to have the undersigned write a thorough and complete brief, which
may necessitate additional time and supplementation.
I declare under penalty of perjury that the foregoing is true and correct.
Executed on December 8, 2022 at Los Angeles, California.
/s/ Carlo Brooks
  
Carlo Brooks
2
Case 2:20-cr-00579-SVW     Document 1337-1     Filed 12/08/22     Page 3 of 3   Page ID
#:20336

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