Court filing
First Notice of Motion and Motion — USA v. Ayvazyan et al. (Dkt. 107, C.D. Cal.)
Filed December 28, 2020 in USA v. Ayvazyan et al.; one of 233 filings from this case.
Record facts
| Court | U.S. District Court for the Central District of California |
|---|---|
| Filed | 2020-12-28 |
U.S. District Court for the Central District of California · No. 2:20-cr-00579-SVW · Doc. 107 · 2020-12-28 · Docket on CourtListener
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THOMAS A. MESEREAU, JR.
Mesereau Law Group
10100 Santa Monica Blvd, Suite 300
Los Angeles, CA 90067
310-651-9960
mesereau@mesereaulaw.com
JENNIFER J. WIRSCHING
1935 Alpha Rd, Suite 216
Glendale, CA 91208
424-901-9280
wirschinglaw@outlook.com
Attorneys for
ARTUR AYVAZYAN
UNITED STATES DISTRICT COURT
FOR THE CENTRAL DISTRICT OF CALIFORNIA
UNITED STATES OF AMERICA,
Plaintiff,
vs
ATRUR AYVAZYAN,
Defendant.
___________________________________
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Case No. 2:20-CR-00579-SVW-3
MOTION TO MODIFY
CONDITIONS OF PRETRIAL
RELEASE TO ALLOW TRAVEL
BETWEEN DECEMBER 30, 2020
AND JANUARY 4, 2021
COMES NOW, Defendant, Artur Ayvazyan by and through counsel Thomas A. Mesereau,
Jr. and Jennifer J. Wirsching, and pursuant to the Federal Rules of Criminal Procedure, respectfully
request this Honorable Court to modify the terms of Mr. Ayvazyan’s pretrial release to allow Mr.
Ayvazyan to travel to Snowmass Village, Colorado for a pre-planned family holiday trip. The trip
would be with Mr. Ayvazyan’s wife, their children, and some of his wife’s family. The trip is
scheduled from Wednesday, December 30, 2020 to Monday, January 4, 2021.
Mr. Ayvazyan’s current conditions of pretrial release include location monitoring.
Pretrial services currently does not have the authority to grant this travel due to the location
Case 2:20-cr-00579-SVW Document 107 Filed 12/28/20 Page 1 of 5 Page ID #:707
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monitoring restrictions which require him to be in his home with exceptions for employment,
medical care, attorney visits and court appearances. Pretrial services officer Ochoa has advised
me that she does not object to Mr. Ayvazyan going on the trip should this Honorable Court allow
it. AUSA Christopher Fenton has advised counsel that the Government takes no position on this
request and defers to this Honorable Court.
Said Motion is based on this introduction, the attached Declaration of Jennifer Wirsching,
Esq., and the complete files and records of this action.
DECLARATION OF JENNIFER J. WIRSCHING
1.
I, Jennifer J. Wirsching, an attorney licensed to practice law before all of the courts of
the State of California, all federal District Courts in California, the District of
Colorado, the Ninth Circuit Court of Appeals, and the Tenth Circuit Court of
Appeals, am an attorney of record for Artur Ayvazyan.
2.
On November 6, 2020, Mr. Ayvazyan was put under conditions of pretrial release
(Doc. 5).
3.
I have been informed and believe that Mr. Ayvazyan’s bond paperwork is completed
and has been filed.
4.
The terms of release include location monitoring which requires Mr. Ayvazyan to be
in his home except for medical needs, attorney visits, court appearances and
employment. These exceptions must be approved by Pretrial Services.
5.
I have been informed and believe that Mr. Ayvazyan would like to take a family trip
to Colorado for the New Year’s holiday.
Case 2:20-cr-00579-SVW Document 107 Filed 12/28/20 Page 2 of 5 Page ID #:708
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6.
The flights are between LAX and ASE (Aspen, Colorado). The outbound flight is on
American Airlines 3095, which leaves Wednesday, December 30, 2020. The return
flight is on American Airlines flight 3033 on Monday, January 4, 2021. Both flights
are direct.
7.
I have been informed and believe that during the trip Mr. Ayvazyan and his family
would stay at the Westin Snowmass Hotel. The hotel is located at 100 Elbert Lane,
Snowmass Village, Colorado, 81615.
8.
I spoke to Pretrial Services Officer Ochoa today, and she advised that she has no
objection to this request for travel.
9.
I spoke to AUSA Christopher Fenton today, and he advised that the Government
takes no position as to this request for travel and would defer to the judgement of this
Honorable Court.
10.
I have personal knowledge of the statements above, unless otherwise indicated as
based on information and belief.
I declare under penalty of perjury that the foregoing is true and correct.
December 28, 2020
/S/Jennifer J. Wirsching
Jennifer J. Wirsching
1935 Alpha Rd, Suite 216
Glendale, CA 91208
424-901-9280
wirschinglaw@outlook.com
Attorney for Artur Ayvazyan
Case 2:20-cr-00579-SVW Document 107 Filed 12/28/20 Page 3 of 5 Page ID #:709
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For the reasons set forth above respectively requests that this Honorable Court:
1. Modify the terms of Mr. Ayvazyan’s pretrial release to allow travel to Snowmass Village,
Colorado for a pre-planned Holiday trip from December 30, 2020 to January 4, 2020.
2. GRANT all such other relief as it deems just and proper.
Respectfully Submitted,
/s/ Jennifer J. Wirsching
Jennifer J. Wirsching
1935 Alpha Rd, Suite 216
Glendale, CA 91208
424-901-9280
wirschinglaw@outlook.com
Attorney for Artur Ayvazyan
/s/ Thomas A. Mesereau, Jr.
Mesereau Law Group
10100 Santa Monica Blvd, Suite 300
Los Angeles, CA 90067
310-651-9960
mesereau@mesereaulaw.com
Attorney for Artur Ayvazyan
Case 2:20-cr-00579-SVW Document 107 Filed 12/28/20 Page 4 of 5 Page ID #:710
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CERTIFICATE OF SERVICE
I certify that on December 28, 2020, I electronically filed the foregoing document with the
clerk of the U.S District Court, Central District of California, using the electronic case filing system
of the court to the following parties.
/s/ Jennifer J. Wirsching
Jennifer J. Wirsching
1935 Alpha Rd, Suite 216
Glendale, CA 91208
424-901-9280
wirschinglaw@outlook.com
Attorney for Artur Ayvazyan
Julian L. André
United States Attorney's Office
1100 United States Courthouse
312 North Spring Street
Los Angeles, California 90012
213- 894-6683
Julian.L.Andre@usdoj.gov
Case 2:20-cr-00579-SVW Document 107 Filed 12/28/20 Page 5 of 5 Page ID #:711File and source
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