Indictment Filed as to Richard Ayvazyan — USA v. Ayvazyan et al. (Dkt. 32, C.D. Cal.)

Record facts

U.S. District Court for the Central District of California · No. 2:20-cr-00579-SVW · Doc. 32 · 2020-11-17 · Docket on CourtListener

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UNITED STATES DISTRICT COURT 
FOR THE CENTRAL DISTRICT OF CALIFORNIA 
October 2020 Grand Jury 
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, 
Defendants.
CR 
I N D I C T M E N T 
[18 U.S.C. § 1349: Conspiracy to 
Commit Bank Fraud and Wire Fraud; 
18 U.S.C. § 1343: Wire Fraud; 18 
U.S.C. § 1344(2): Bank Fraud; 18 
U.S.C. § 1028A(a)(1): Aggravated 
Identity Theft; 18 U.S.C. §§ 981, 
982, 1028 and 28 U.S.C. § 2461(c): 
Criminal Forfeiture] 
The Grand Jury charges: 
COUNT ONE 
[18 U.S.C. § 1349] 
[ALL DEFENDANTS] 
A.
INTRODUCTORY ALLEGATIONS
At times relevant to this Indictment:
2:20-cr-00579-SVW
11/17/2020
DM
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FILED 
CLERK, U.S. DISTRICT COURT 
 
 
 
 
 
CENTRAL DISTRICT OF CALIFORNIA 
 
BY: ___________________ DEPUTY 

 
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THE DEFENDANTS 
1. 
Defendant RICHARD AYVAZYAN, also known as (“aka”) “Richard 
Avazian” and “Iuliia Zhadko” (“R. AYVAZYAN”), was a resident of 
Encino, California, within the Central District of California.   
2. 
Defendant MARIETTA TERABELIAN, aka “Marietta Abelian” and 
“Viktoria Kauichko,” was a resident of Encino, California, within the 
Central District of California.  Defendant TERABELIAN and defendant 
R. AYVAZYAN were married.   
3. 
Defendant ARTUR AYVAZYAN, aka “Arthur Ayvazyan” 
(“A. AYVAZYAN”), was a resident of Encino, California, within the 
Central District of California.  Defendant A. AYVAZYAN and defendant 
R. AYVAZYAN were brothers.   
4. 
Defendant TAMARA DADYAN was a resident of Encino, 
California, within the Central District of California.  Defendant 
DADYAN and defendant A. AYVAZYAN were married.   
THE PAYCHECK PROTECTION PROGRAM 
5. 
The Coronavirus Aid, Relief, and Economic Security 
(“CARES”) Act was a federal law enacted in or about March 2020 that 
was designed to provide emergency financial assistance to Americans 
suffering economic harm as a result of the COVID-19 pandemic.  One 
form of assistance provided by the CARES Act was the authorization of 
United States taxpayer funds in forgivable loans to small businesses 
for job retention and certain other expenses, through a program 
referred to as the Paycheck Protection Program (“PPP”).  
6. 
In order to obtain a PPP loan, a qualifying business was 
required to submit a PPP loan application signed by an authorized 
representative of the business.  The PPP loan application required 
the small business (through its authorized representative) to 
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acknowledge the program rules and make certain affirmative 
certifications in order to be eligible to obtain the PPP loan.  One 
such certification required the applicant to affirm that “[t]he [PPP 
loan] funds w[ould] be used to retain workers and maintain payroll or 
make mortgage interest payments, lease payments, and utility 
payments.”  The applicant (through its authorized representative) was 
also required to acknowledge that “I understand that if the funds are 
used for unauthorized purposes, the federal government may pursue 
criminal fraud charges.”  In the PPP loan application, the applicant 
was required to state, among other things, its: (a) average monthly 
payroll expenses; and (b) number of employees.  These figures were 
used to calculate the amount of money the small business was eligible 
to receive under the PPP.  In addition, the applicant was required to 
provide documentation showing its payroll expenses.   
7. 
A business’s PPP loan application was received and 
processed, in the first instance, by a participating financial 
institution.  If a PPP loan application was approved, the 
participating financial institution would fund the PPP loan using its 
own monies.    
8. 
PPP loan proceeds were required to be used by the business 
on certain permissible expenses, namely, payroll costs, interest on 
mortgages, rent, and utilities.  The PPP allowed the interest and 
principal on the PPP loan to be entirely forgiven if the business 
spent the loan proceeds on these expenses within a designated period 
of time and used at least a minimum amount of the PPP loan proceeds 
towards payroll expenses. 
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THE ECONOMIC INJURY DISASTER LOAN PROGRAM  
9. 
The Economic Injury Disaster Loan Program (“EIDL”) was a 
United States Small Business Administration (“SBA”) program that 
provided low-interest financing to small businesses, renters, and 
homeowners in regions affected by declared disasters. 
10. 
The CARES Act authorized the SBA to provide EIDL loans of 
up to $2 million to eligible small businesses experiencing 
substantial financial disruption due to the COVID-19 pandemic.   
11. 
To obtain an EIDL loan, a qualifying business was required 
to submit an application to the SBA and provide information about the 
business’s operations, such as the number of employees, gross 
revenues for the 12-month period preceding the disaster, and cost of 
goods sold in the 12-month period preceding the disaster.  In the 
case of EIDL loans for COVID-19 relief, the 12-month period was the 
12-month period from January 31, 2019, to January 31, 2020.  The 
applicant was also required to certify that all of the information in 
the application was true and correct to the best of the applicant’s 
knowledge. 
12. 
EIDL loan applications were submitted directly to the SBA 
and processed by the agency with support from a government 
contractor.  The amount of the loan, if the application was approved, 
was determined based, in part, on the information provided by the 
applicant about employment, revenue, and cost of goods sold, as 
described in paragraph 11 above.  Any funds issued under an EIDL loan 
were issued directly by the SBA.   
13. 
EIDL loan funds could be used for payroll expenses, sick 
leave, production costs, and business obligations, such as debts, 
rent, and mortgage payments.  If the applicant also obtained a loan 
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under the PPP, the EIDL loan funds could not be used for the same 
purpose as the PPP loan funds. 
RELEVANT LENDING INSTITUTIONS  
14. 
Lenders A, B, C, D, and E were financial institutions 
insured by the Federal Deposit Insurance Company (“FDIC”) that were 
approved SBA lenders of PPP loans.   
BANK ACCOUNTS CONTROLLED BY THE DEFENDANTS 
15. 
Banks 1, 2, 3, 4, 5, and 6 were financial institutions 
insured by the FDIC.   
16. 
Defendant R. AYVAZYAN controlled and was a signatory (in 
his legal name or using one of his aliases) on the following bank 
accounts: 
a. 
A business checking account at Bank 1 in the name of 
“Timeline Transport, Inc.” (the “Timeline Transport Bank 1 Account”); 
b. 
A business checking account at Bank 2 in the name of 
“Inception Ventures Inc.” (the “Inception Ventures Bank 2 Account”); 
and 
c. 
A business checking account at Bank 3 in the name of 
“Iuliia Zhadko dba Top Quality Contracting” (the “TQC Bank 3 
Account”).  
17. 
Defendant TERABELIAN controlled and was a signatory (in her 
legal name or using one of her aliases) on the following bank 
accounts: 
a. 
A personal checking account at Bank 2 in the name of 
TERABELIAN (the “Terabelian Bank 2 Account”); and 
b. 
A business checking account at Bank 2 in the name of 
“Runyan Tax Service Inc.” (the “Runyan Tax Bank 2 Account”). 
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18. 
Defendant A. AYVAZYAN controlled and was a signatory (in 
his legal name or using his alias) on the following bank accounts: 
a. 
A business checking account at Bank 2 in the name of 
“Allstate Towing and Transport LLC” (the “Allstate Towing Bank 2 
Account”); and  
b. 
A business checking account at Bank 4 in the name of 
“Allstate Towing and Transport LLC” (the “Allstate Towing Bank 4 
Account”). 
19. 
Defendant DADYAN controlled and was a signatory on the 
following bank accounts: 
a. 
A business checking account at Bank 3 in the name of  
“Secureline Realty and Funding, Inc.” (the “Secureline Realty Bank 3 
Account”); 
b. 
A business checking account at Bank 5 in the name of 
“ABC Realty Advisors, Inc.” (the “ABC Realty Bank 5 Account”); and  
c. 
A business checking account at Bank 6 in the name of 
“Secureline Realty and Funding, Inc.” (the “Secureline Realty Bank 6 
Account”). 
B. 
THE OBJECTS OF THE CONSPIRACY 
20. 
Beginning no later than in or around March 2020 and 
continuing until at least in or around July 2020, in Los Angeles 
County, within the Central District of California, and elsewhere, 
defendants R. AYVAZYAN, TERABELIAN, A. AYVAZYAN, and DADYAN, 
conspired with one another and with others known and unknown to the 
Grand Jury to commit: (a) wire fraud, in violation of Title 18, 
United States Code, Section 1343; (b) bank fraud, in violation of 
Title 18, United States Code, Section 1344(2). 
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C. 
THE MANNER AND MEANS OF THE CONSPIRACY 
21. 
The objects of the conspiracy were to be carried out, and 
were carried out, in substance, as follows:   
a. 
Defendants R. AYVAZYAN, TERABELIAN, A. AYVAZYAN, and 
DADYAN, together with other coconspirators, used and caused to be 
used, stolen, fictitious, or synthetic identities of individuals to 
submit fraudulent applications for PPP and EIDL loans;   
b. 
Defendants R. AYVAZYAN, TERABELIAN, A. AYVAZYAN, and 
DADYAN, together with other coconspirators, would use, and cause to 
be used, stolen, fictitious, and synthetic business names to submit 
fraudulent applications for PPP and EIDL loans;   
c. 
Defendants R. AYVAZYAN, TERABELIAN, A. AYVAZYAN, and 
DADYAN, together with other coconspirators, would make, and cause to 
be made, false statements to the SBA and financial institutions in 
connection with the fraudulent applications for PPP and EIDL loans, 
including false representations regarding the number of employees to 
whom the companies had paid wages and false certifications that the 
loans would be used for permissible business purposes.   
d. 
Defendants R. AYVAZYAN, TERABELIAN, A. AYVAZYAN, and 
DADYAN, together with other coconspirators, would electronically 
submit, and cause to be submitted, false and fictitious documents to 
the SBA and financial institutions in support of the fraudulent PPP 
and EIDL loan applications, including false or fictitious tax 
documents, payroll records, bank records, and identification 
documents.  
e. 
Defendants R. AYVAZYAN, TERABELIAN, A. AYVAZYAN, and 
DADYAN, together with other coconspirators, would direct that PPP and 
EIDL loan proceeds be deposited into bank accounts that defendants 
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R. AYVAZYAN, TERABELIAN, A. AYVAZYAN, and DADYAN, and their 
coconspirators controlled.   
f. 
Defendants R. AYVAZYAN, TERABELIAN, A. AYVAZYAN, and 
DADYAN, and their coconspirators, would use the fraudulently obtained 
PPP and EIDL loan proceeds for their own personal benefit and for the 
benefit of their coconspirators, including for expenses prohibited 
under the requirements of the PPP and EIDL programs, such as the 
purchase of residential properties at Address 1 in Tarzana, 
California (“Residential Property 1”), and Address 2 in Glendale, 
California (“Residential Property 2”). 
22. 
As part of the conspiracy, between in or around March 2020 
and in or around July 2020, defendants R. AYVAZYAN, TERABELIAN, 
A. AYVAZYAN, and DADYAN, together with other coconspirators, 
submitted and caused the submission of at least 35 fraudulent PPP and 
EIDL loan applications seeking a total of at least $5.6 million in 
PPP and EIDL proceeds from the SBA and financial institutions and 
received a total of at least $4.6 million in PPP and EIDL loan 
proceeds from the SBA and financial institutions.   
D. 
OVERT ACTS 
23. 
On or about the following dates, in furtherance of the 
conspiracy and to accomplish its objects, defendants R. AYVAZYAN, 
TERABELIAN, A. AYVAZYAN, and DADYAN, together with other 
conspirators, committed and willfully caused others to commit the 
following overt acts, among others, within the Central District of 
California:    
Secureline Realty PPP Loans 
Overt Act No. 1: 
On or about April 22, 2020, defendant DADYAN 
submitted and caused to be submitted to Lender D an application in 
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the name of Secureline Realty and Funding, Inc. (“Secureline Realty”) 
seeking a PPP loan in the amount of $122,838, which application: 
(a) falsely represented that Secureline Realty had eight employees, 
including employees for whom it had paid wages and payroll taxes; and 
(b) falsely certified Secureline Realty would use the loan proceeds 
for permissible business purposes.   
Overt Act No. 2: 
On or about April 22, 2020, defendant DADYAN 
submitted and caused to be submitted to Lender D false and fraudulent 
documents in support of the Secureline Realty PPP loan application, 
including the following: 
a. 
A fake Internal Revenue Service (“IRS”) Form 940 for 
2019, which falsely represented that Secureline Realty had paid 
$589,623 to its employees in 2019.   
b. 
A fake IRS Form 941 for the first quarter of 2020, 
which falsely represented that Secureline Realty had paid $151,842 to 
its employees during that period.   
Overt Act No. 3: 
On or about May 7, 2020, defendant DADYAN 
caused Lender D to wire approximately $122,838 in proceeds from the 
Secureline Realty PPP loan to Secureline Realty Bank 3 Account.   
Overt Act No. 4: 
On or about May 9, 2020, defendant DADYAN 
submitted and caused to be submitted to Lender E an application in 
the name of Secureline Realty seeking a PPP loan in the amount of 
$137,500, which application: (a) falsely represented that Secureline 
Realty had eight employees, including employees for whom it had paid 
wages and payroll taxes; and (b) falsely certified Secureline Realty 
would use the loan proceeds for permissible business purposes.     
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Overt Act No. 5: 
On or about May 11, 2020, defendant DADYAN 
caused Lender E to wire approximately $137,500 in proceeds from the 
Secureline Realty PPP loan to Secureline Realty Bank 6 Account.   
Overt Act No. 6: 
On or about May 27, 2020, defendant DADYAN 
caused a check for approximately $136,000, drawn on Secureline Realty 
Bank 6 Account and comprised in substantial part of the PPP loan 
proceeds for Secureline Realty, to be deposited into ABC Realty Bank 
5 Account. 
Overt Act No. 7: 
On or about June 12, 2020, defendant DADYAN 
caused approximately $120,010, which in substantial part came from 
the PPP loan proceeds for Secureline Realty, to be withdrawn from 
Secureline Realty Bank 3 Account and subsequently caused 
approximately $120,000 to be deposited to ABC Realty Bank 5 Account.   
Overt Act No. 8: 
On or about June 17, 2020, defendant DADYAN 
caused approximately $200,000 to be wired from ABC Realty Bank 5 
Account to Inception Ventures Bank 2 Account, for which defendant 
R. AYVAZYAN was the sole signatory.   
Overt Act No. 9: 
On or about June 22, 2020, defendant 
R. AYVAZYAN caused approximately $435,000, which in part came from 
the approximately $200,000 in PPP loan funds defendant R. AYVAZYAN 
received from defendant DADYAN, to be wired from Inception Ventures 
Bank 2 Account to Escrow Company 1 to be used to as part of the 
$3,250,000 purchase price for Residential Property 1, which was 
purchased in the names of defendants R. AYVAZYAN and TERABELIAN.   
Top Quality Contracting PPP Loan 
Overt Act No. 10: 
On or about April 30, 2020, defendant 
R. AYVAZYAN, using the name of M.Z., submitted and caused to be 
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submitted to Lender B an application in the name of Top Quality 
Contracting (“TQC”), seeking a PPP loan in the amount of $130,000.  
Overt Act No. 11: 
On or about April 30, 2020, in connection 
with the TQC PPP loan application, defendant R. AYVAZYAN submitted 
and caused to be submitted to Lender B a fake copy of M.Z.’s 
California driver’s license and a false IRS Form 940 purportedly 
prepared and filed by M.Z. 
Overt Act No. 12: 
On or about May 8, 2020, defendant 
R. AYZAYAN caused Lender B to wire approximately $130,000 in proceeds 
from the TQC PPP loan to TQC Bank 3 Account, which listed defendant 
R. AYVAZYAN’s alias “Iuliia Zhadko” and M.Z. as the only signatories.  
Allstate Towing PPP Loan 
Overt Act No. 13: 
On or about May 2, 2020, defendant 
A. AYVAZYAN submitted and caused to be submitted to Lender C an 
application in the name of Allstate Towing and Transport LLC 
(“Allstate Towing”) seeking a PPP loan in the amount of $124,000, 
which application: (a) falsely represented that Allstate Towing had 
11 employees, including employees for whom it had paid wages and 
payroll taxes; and (b) falsely certified Allstate Towing would use 
the loan proceeds for permissible business purposes.  
Overt Act No. 14: 
On or about May 2, 2020, defendant 
A. AYVAZYAN submitted and caused to be submitted to Lender C false 
and fraudulent documents in support of the Allstate Towing PPP loan 
application, including the following: 
a. 
A fake IRS Form 940 for 2019, which falsely 
represented that Allstate Towing had paid $546,000 to its employees 
in 2019.   
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b. 
A fake IRS Form 941 for the first quarter of 2020, 
which falsely represented that Allstate Towing had paid $136,500 to 
its employees during that period.  
Overt Act No. 15: 
On or about May 5, 2020, defendant 
A. AYVAZYAN caused Lender C to wire approximately $124,000 in 
proceeds from the Allstate Towing PPP loan to Allstate Towing Bank 4 
Account.  
Overt Act No. 16: 
On or about May 21, 2020, defendant 
A. AYVAZYAN caused approximately $80,000, which in substantial part 
came from the Allstate Towing PPP loan proceeds, to be wired from 
Allstate Towing Bank 4 Account to Allstate Towing Bank 2 Account.   
Overt Act No. 17: 
On or about June 3, 2020, defendant 
A. AYVAZYAN caused approximately $93,000, which in substantial part 
came from the Allstate Towing PPP loan proceeds, to be wired from 
Allstate Towing Bank 2 Account to Escrow Company 1 to be used as part 
of the $3,250,000 purchase price for Residential Property 1, which 
was purchased in the names of defendants R. AYVAZYAN and TERABELIAN.   
G&A Diamonds and Redline Auto Collision Loans 
Overt Act No. 18: 
On or about May 3, 2020, defendants 
R. AYVAZYAN and TERABELIAN, together with other coconspirators, 
submitted and caused to be submitted to Lender C an application in 
the name of G&A Diamonds seeking a PPP loan in the amount of 
approximately $113,750.   
Overt Act No. 19: 
 On or about May 5, 2020, defendants 
R. AYVAZYAN and TERABELIAN, together with other coconspirators, 
caused Lender C to wire approximately $113,750 in proceeds from the 
G&A Diamonds PPP loan to G&A Diamonds’ Bank 4 account (the “G&A 
Diamonds Bank 4 Account”). 
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Overt Act No. 20: 
On or about June 2, 2020, defendants 
R. AYVAZYAN and TERABELIAN, together with other coconspirators, 
submitted and caused to be submitted to the SBA an application in the 
name of Redline Auto Collision Inc. (“Redline Auto”) seeking an EIDL 
loan in the amount of approximately $150,000. 
Overt Act No. 21: 
On or about June 8, 2020, defendants 
R. AYVAZYAN and TERABELIAN, together with other coconspirators, 
caused the SBA to wire approximately $149,900 in proceeds from the 
Redline Auto EDIL loan to Redline Auto’s Bank 5 account (the “Redline 
Auto Bank 5 Account”). 
Overt Act No. 22: 
On or about June 14, 2020, defendants 
R. AYVAZYAN and TERABELIAN, together with other coconspirators, 
submitted and caused to be submitted to the SBA an application in the 
name of G&A Diamonds seeking an EIDL loan in the amount of 
approximately $150,000. 
Overt Act No. 23: 
On or about June 16, 2020, defendants 
R. AYVAZYAN and TERABELIAN, together with other coconspirators, 
caused the SBA to wire approximately $149,900 to G&A Diamonds Bank 4 
Account.   
Overt Act No. 24: 
On or about June 17, 2020, defendants 
R. AYVAZYAN and TERABELIAN, together with other coconspirators, 
caused approximately $150,000, comprised in substantial part of the 
proceeds from the Redline Auto EIDL loan, to be wired from Redline 
Auto Bank 5 Account to Terabelian Bank 2 Account. 
Overt Act No. 25: 
On or about June 19, 2020, defendants 
R. AYVAZYAN and TERABELIAN, together with other coconspirators, 
caused approximately $100,000, which in substantial part came from 
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the proceeds from the G&A Diamonds PPP and EIDL loans, to be wired 
from G&A Diamonds Bank 4 Account to Terabelian Bank 2 Account. 
Overt Act No. 26: 
On or about June 22, 2020, defendants 
R. AYVAZYAN and TERABELIAN caused approximately $565,000, which in 
substantial part came from PPP and EIDL loan funds obtained from the 
SBA and financial institutions in the name of G&A Diamonds and 
Redline Auto, to be wired from Terabelian Bank 2 Account to Escrow 
Company 1 to be used as part of the $3,250,000 purchase price for 
Residential Property 1, which was purchased in the names of 
defendants R. AYVAZYAN and TERABELIAN.   
Timeline Transport EIDL Loan 
Overt Act No. 27: 
On or about June 15, 2020, defendant 
R. AYVAZYAN, using the alias “Iuliia Zhadko,” submitted and caused to 
be submitted to the SBA an application in the name of Timeline 
Transport, Inc. (“Timeline Transport”) seeking an EIDL loan in the 
amount of approximately $150,000, which application: (a) falsely 
represented that “Iuliia Zhadko” had owned Timeline Transport since 
2016 and was the company’s Chief Executive Officer; (b) falsely 
represented that Timeline Transport had 22 employees, including 
employees for whom it had paid wages and payroll taxes; and 
(c) falsely certified Timeline Transport would use the loan proceeds 
for permissible business purposes.    
Overt Act No. 28: 
On or about June 22, 2020, defendant 
R. AYVAZYAN caused the SBA to wire approximately $149,900 in proceeds 
from the Timeline Transport EIDL loan to Timeline Transport Bank 1 
Account.   
Overt Act No. 29: 
On or about June 24, 2020, defendant 
R. AYVAZYAN caused approximately $110,000, which in substantial part 
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came from the Timeline Transport EIDL loan proceeds, to be wired from 
Timeline Transport Bank 1 Account to Escrow Company 1 to be used as 
part of the $3,250,000 purchase price for Residential Property 1, 
which was purchased in the names of defendants R. AYVAZYAN and 
TERABELIAN.   
Runyan Tax Service PPP Loan 
Overt Act No. 30: 
On or about July 13, 2020, defendant 
R. AYVAZYAN and defendant TERABELIAN, using her alias “Viktoria 
Kauichko,” submitted and caused to be submitted to Lender A an 
application in the name of Runyan Tax Service, Inc. (“Runyan Tax 
Service”) seeking a PPP loan in the amount of $276,653, which 
application: (a) falsely represented that Runyan Tax Service had 22 
employees, including employees for whom it had paid wages and payroll 
taxes; and (b) falsely certified Runyan Tax Service would use the 
loan proceeds for permissible business purposes.   
Overt Act No. 31: 
On or about July 13, 2020, defendants 
R. AYVAZYAN and TERABELIAN submitted and caused to be submitted to 
Lender A false and fraudulent documents in support of the Runyan Tax 
Service PPP loan application, including a fraudulent California 
driver’s license purportedly belonging to “Viktoria Kauichko,” and a 
federal tax filing representing “Viktoria Kauichko” as Runyan Tax 
Service’s President, even though defendants R. AYVAZYAN and 
TERABELIAN knew at the time that “Viktoria Kauichko” was a fake and 
synthetic identity.  
Overt Act No. 32: 
On or about July 21, 2020, defendants 
R. AYVAZYAN and TERABELIAN caused Lender A to wire approximately 
$276,653 in proceeds from the Runyan Tax Service PPP loan to Runyan 
Tax Bank 2 Account. 
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Overt Act No. 33: 
On or about July 23, 2020, defendants 
R. AYVAZYAN and TERABELIAN caused approximately $238,614, which in 
substantial part came from the Runyan Tax Service PPP loan proceeds, 
to be transferred from Runyan Tax Bank 2 Account to Escrow Company 2 
to be used as part of the approximately $1,000,000 purchase price for 
Residential Property 2, which was purchased in the name of defendant 
R. AYVAZYAN’s alias “Iuliia Zhadko.” 
 
 
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COUNTS TWO THROUGH SEVEN 
[18 U.S.C. §§ 1343, 2(a)] 
[ALL DEFENDANTS] 
24. 
The Grand Jury re-alleges paragraphs 1 through 19 and 21 
through 23 of this Indictment here. 
A. 
THE SCHEME TO DEFRAUD 
25. 
Beginning no later than in or around March 2020 and 
continuing until at least in or around July 2020, in Los Angeles 
County, within the Central District of California, and elsewhere, 
defendants R. AYVAZYAN, TERABELIAN, A. AYVAZYAN, and DADYAN, together 
with others known and unknown to the Grand Jury, knowingly and with 
intent to defraud, devised, participated in, and executed a scheme to 
defraud the SBA and financial institutions as to material matters, 
and to obtain moneys, funds, assets, and other property owned by and 
in the custody and control of the SBA and financial institutions by 
means of material false and fraudulent pretenses, representations, 
and promises, and the concealment of material facts. 
26. 
The fraudulent scheme operated and was carried out, in 
substance, as described in paragraphs 21 through 23 of this 
Indictment.   
B. 
USE OF THE WIRES 
27. 
On or about the dates set forth below, in Los Angeles 
County, within the Central District of California, and elsewhere, for 
the purpose of executing the above-described scheme to defraud, 
defendants R. AYVAZYAN, TERABELIAN, A. AYVAZYAN, and DADYAN, together 
with others known and unknown to the Grand Jury, aiding and abetting 
each other, transmitted and caused the transmission of the following 
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items by means of wire and radio communication in interstate and 
foreign commerce: 
COUNT 
DATE 
INTERSTATE WIRE TRANSMISSION 
TWO 
May 5, 2020 
Transfer of approximately $124,000 in PPP 
loan proceeds from Lender C, sent by 
means of an interstate wire, into 
Allstate Towing Bank 4 Account  
THREE 
May 8, 2020 
Transfer of approximately $130,000 in PPP 
loan proceeds from Lender B, sent by 
means of an interstate wire, into TQC 
Bank 3 Account  
FOUR 
May 11, 2020 
Transfer of approximately $137,500 in PPP 
loan proceeds from Lender E, sent by 
means of an interstate wire, into  
Secureline Realty Bank 6 Account  
FIVE 
June 16, 2020 
Transfer of approximately $149,900 in 
EIDL loan proceeds from the SBA, sent by 
means of an interstate wire, into G&A 
Diamonds Bank 4 Account 
SIX  
June 17, 2020 
Transfer of approximately $150,000 in 
EIDL loan proceeds from the Redline Auto 
Bank 5 Account, sent by means of an 
interstate wire, to Terabelian Bank 2 
Account  
SEVEN 
June 22, 2020 
Transfer of approximately $149,900 in 
EIDL loan proceeds from the SBA, sent by 
means of an interstate wire, into 
Timeline Transport Bank 1 Account  
 
 
 
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COUNTS EIGHT THROUGH ELEVEN 
[18 U.S.C. §§ 1344(2), 2] 
[ALL DEFENDANTS] 
28. 
The Grand Jury re-alleges paragraphs 1 through 19 and 21 
through 23 of this Indictment here. 
A. 
THE SCHEME TO DEFRAUD 
29. 
Beginning no later than in or around March 2020 and 
continuing until at least in or around July 2020, in Los Angeles 
County, within the Central District of California, and elsewhere, 
defendants R. AYVAZYAN, TERABELIAN, A. AYVAZYAN, and DADYAN, together 
with others known and unknown to the Grand Jury, knowingly and with 
intent to defraud, devised, participated in, executed, and attempted 
to execute a scheme to obtain moneys, funds, credits, assets, and 
other property owned by and in the custody and control of federally-
insured financial institutions by means of material false and 
fraudulent pretenses, representations, and promises, and the 
concealment of material facts. 
30. 
The fraudulent scheme operated and was carried out, in 
substance, as described in paragraphs 21 through 23 of this 
Indictment. 
B. 
EXECUTIONS OF THE SCHEME 
31. 
On or about the following dates, in Los Angeles County, 
within the Central District of California, and elsewhere, defendants 
R. AYVAZYAN, TERABELIAN, A. AYVAZYAN, and DADYAN, together with 
others known and unknown to the Grand Jury, aiding and abetting each 
other, committed and willfully caused others to commit the following 
acts, each of which constituted an execution of the fraudulent 
scheme: 
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COUNT 
DATE 
ACT 
EIGHT 
April 30, 2020 
Submission of application for PPP loan 
to Lender B in the name of TQC 
NINE 
May 2, 2020 
Submission of application for PPP loan 
to Lender C in the name of Allstate 
Towing 
TEN 
May 9, 2020 
Submission of application for PPP loan 
to Lender E in the name of Secureline 
Realty 
ELEVEN 
July 13, 2020 
Submission of application for PPP loan 
to Lender A in the name of Runyan Tax 
Service 
 
 
 
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COUNT TWELVE 
[18 U.S.C. §§ 1028A(a)(1), 2(b)] 
[Defendant R. AYVAZYAN]  
32. 
The Grand Jury re-alleges paragraphs 1 through 19 and 21 
through 23 of this Indictment here. 
33. 
Beginning no later than in or around March 2020 and 
continuing until at least in or around July 2020, in Los Angeles 
County, within the Central District of California, and elsewhere, 
defendant R. AYVAZYAN knowingly transferred, possessed, and used, and 
willfully caused to be transferred, possessed, and used, without 
lawful authority, a means of identification that defendant 
R. AYVAZYAN knew belonged to another person, namely, the name of 
M.Z., during and in relation to bank fraud, a felony violation of 
Title 18, United States Code, Section 1344(2), as charged in Count 
Eight of this Indictment.    
 
 
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FORFEITURE ALLEGATION ONE 
[18 U.S.C. § 982] 
34. 
Pursuant to Rule 32.2(a) of the Federal Rules of Criminal 
Procedure, notice is hereby given that the United States of America 
will seek forfeiture as part of any sentence, pursuant to Title 18, 
United States Code, Section 982(a)(2), and Title 28, United States 
Code, Section 2461(c), in the event of any defendant’s conviction of 
the offense set forth in Count One of this Indictment.   
35. 
The defendant so convicted shall forfeit to the United 
States of America the following: 
a. 
all right, title and interest in any and all property, 
real or personal, constituting, or derived from, any proceeds 
obtained, directly or indirectly, as a result of the offense, 
including, but not limited to, certain real property referred to 
herein as Residential Property 1 located in the County of Los 
Angeles, State of California, APN 2176-029-031, and certain real 
property referred to herein as Residential Property 2 located in the 
County of Los Angeles, State of California, APN 5663-036-033; and  
b. 
To the extent such property is not available for 
forfeiture, a sum of money equal to the total value of the property 
described in subparagraph (a). 
36. 
Pursuant to Title 21, United States Code, Section 853(p), 
as incorporated by Title 18, United States Code, Section 982(b) and 
Title 28, United States Code, Section 2461(c), any defendant so 
convicted shall forfeit substitute property, up to the total value of 
the property described in the preceding paragraph if, as the result 
of any act or omission of said defendant, the property described in 
the preceding paragraph, or any portion thereof: (a) cannot be 
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located upon the exercise of due diligence; (b) has been transferred, 
sold to or deposited with a third party; (c) has been placed beyond 
the jurisdiction of the court; (d) has been substantially diminished 
in value; or (e) has been commingled with other property that cannot 
be divided without difficulty. 
 
 
 
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FORFEITURE ALLEGATION TWO 
[18 U.S.C. § 981(a)(1)(C) and 28 U.S.C. § 2461(c)] 
37. 
Pursuant to Rule 32.2 of the Federal Rules of Criminal 
Procedure, notice is hereby given that the United States of America 
will seek forfeiture as part of any sentence, pursuant to Title 18, 
United States Code, Section 981(a)(1)(C) and Title 28, United States 
Code, Section 2461(c), in the event of any defendant’s conviction of 
the offenses set forth in any of Counts Two through Seven of this 
Indictment. 
38. 
The defendant, if so convicted, shall forfeit to the United 
States of America the following:  
a. 
all right, title, and interest in any and all 
property, real or personal, constituting, or derived from, any 
proceeds traceable to the offenses, including, but not limited to, 
certain real property referred to herein as Residential Property 1 
located in the County of Los Angeles, State of California, APN 2176-
029-031, and certain real property referred to herein as Residential 
Property 2 located in the County of Los Angeles, State of California, 
APN 5663-036-033; and  
b. 
to the extent such property is not available for 
forfeiture, a sum of money equal to the total value of the property 
described in subparagraph (a).  
39. 
Pursuant to Title 21, United States Code, Section 853(p), 
as incorporated by Title 28, United States Code, Section 2461(c), the 
defendant, if so convicted, shall forfeit substitute property, up to 
the value of the property described in the preceding paragraph if, as 
the result of any act or omission of the defendant, the property 
described in the preceding paragraph or any portion thereof (a) 
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cannot be located upon the exercise of due diligence; (b) has been 
transferred, sold to, or deposited with a third party; (c) has been 
placed beyond the jurisdiction of the court; (d) has been 
substantially diminished in value; or (e) has been commingled with 
other property that cannot be divided without difficulty. 
 
 
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FORFEITURE ALLEGATION THREE 
[18 U.S.C. § 982] 
40. 
Pursuant to Rule 32.2(a) of the Federal Rules of Criminal 
Procedure, notice is hereby given that the United States of America 
will seek forfeiture as part of any sentence, pursuant to Title 18, 
United States Code, Section 982(a)(2), and Title 28, United States 
Code, Section 2461(c), in the event of any defendant’s conviction of 
the offenses set forth in any of Counts Eight through Eleven of this 
Indictment.   
41. 
Any defendant so convicted shall forfeit to the United 
States of America the following: 
a. 
all right, title and interest in any and all property, 
real or personal, constituting, or derived from, any proceeds 
obtained, directly or indirectly, as a result of the offense, 
including, but not limited to, certain real property referred to 
herein as Residential Property 1 located in the County of Los 
Angeles, State of California, APN 2176-029-031, and certain real 
property referred to herein as Residential Property 2 located in the 
County of Los Angeles, State of California, APN 5663-036-033; and  
b. 
to the extent such property is not available for 
forfeiture, a sum of money equal to the total value of the property 
described in subparagraph (a). 
42. 
Pursuant to Title 21, United States Code, Section 853(p), 
as incorporated by Title 18, United States Code, Section 982(b) and 
Title 28, United States Code, Section 2461(c), any defendant so 
convicted shall forfeit substitute property, up to the total value of 
the property described in the preceding paragraph if, as the result 
of any act or omission of said defendant, the property described in 
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the preceding paragraph, or any portion thereof: (a) cannot be 
located upon the exercise of due diligence; (b) has been transferred, 
sold to or deposited with a third party; (c) has been placed beyond 
the jurisdiction of the court; (d) has been substantially diminished 
in value; or (e) has been commingled with other property that cannot 
be divided without difficulty. 
 
 
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FORFEITURE ALLEGATION FOUR 
[18 U.S.C. §§ 982 and 1028 and 28 U.S.C. § 2461(c)] 
43. 
Pursuant to Rule 32.2 of the Federal Rules of Criminal 
Procedure, notice is hereby given that the United States of America 
will seek forfeiture as part of any sentence, pursuant to Title 18, 
United States Code, Sections 982 and 1028 and Title 28, United States 
Code, Section 2461(c) in the event of the conviction of defendant 
RICHARD AYVAZYAN, also known as (“aka”) “Richard Avazian,” and 
“Iuliia Zhadko,” of the offense set forth in Count Twelve of this 
Indictment.  
44. 
The defendant, if so convicted, shall forfeit to the United 
States of America the following: 
a. 
all right, title and interest in any and all property, 
real or personal, constituting, or derived from, any proceeds 
obtained, directly or indirectly, as a result of the offense, 
including, but not limited to, certain real property referred to 
herein as Residential Property 1 located in the County of Los 
Angeles, State of California, APN 2176-029-031, and certain real 
property referred to herein as Residential Property 2 located in the 
County of Los Angeles, State of California, APN 5663-036-033; 
b. 
any personal property used or intended to be used to 
commit the offense; and  
c. 
to the extent such property is not available for 
forfeiture, a sum of money equal to the total value of the property 
described in subparagraphs (a) and (b).  
45. 
Pursuant to Title 21, United States Code, Section 853(p), 
as incorporated by Title 18, United States Code, Sections 982(b) and 
1028(g), the defendant, if so convicted, shall forfeit substitute 
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property, up to the total value of the property described in the 
preceding paragraph if, as the result of any act or omission of the 
defendant, the property described in the preceding paragraph, or any 
portion thereof: (a) cannot be located upon the exercise of due 
diligence; (b) has been transferred, sold to or deposited with a 
third party; (c) has been placed beyond the jurisdiction of the 
court; (d) has been substantially diminished in value; or (e) has 
been commingled with other property that cannot be divided without 
difficulty. 
 
A TRUE BILL 
 
 
     /S/ 
 
Foreperson 
 
NICOLA T. HANNA 
United States Attorney 
 
 
 
BRANDON D. FOX 
Assistant United States Attorney 
Chief, Criminal Division 
 
RANEE A. KATZENSTEIN 
Assistant United States Attorney 
Chief, Major Frauds Section 
 
DANIEL A. KAHN 
Acting Chief, Fraud Section 
Criminal Division 
United States Department of Justice 
 
KRISTEN A. WILLIAMS 
Assistant United States Attorney 
Deputy Chief, Major Frauds Section 
 
JULIAN L. ANDRÉ 
Assistant United States Attorney 
Major Frauds Section 
 
CHRISTOPHER FENTON 
Trial Attorney, Fraud Section 
Criminal Division 
United States Department of Justice 
 
 
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