Declaration — USA v. Ayvazyan et al. (Dkt. 152-1, C.D. Cal.)

Record facts

U.S. District Court for the Central District of California · No. 2:20-cr-00579-SVW · Doc. 152-1 · 2021-03-15 · Docket on CourtListener

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DECLARATION OF SCOTT PAETTY 
I, Scott Paetty, hereby declare and state as follows: 
I am an Assistant United States Attorney with the United States 
Attorney’s Office for the Central District of California.  I am an 
attorney assigned to the case of United States v. Richard Ayvazyan et 
al., No. 20-CR-579(A)-SVW. 
1. 
Exhibit 1 is a true and correct copy of an email from FBI 
SA Justin Palmerton to Customs and Border Protection (“CBP”) Officer 
Carlos DeSouza. 
2. 
Exhibit 2 is true and correct copy of a photograph obtained 
from CBP that depicted a credit card in the name of “Viktoria 
Kauichko” that CBP officers found in defendant Marietta Terabelian’s 
(“Terabelian”) luggage after officers conducted a secondary 
inspection at Miami International Airport (“MIA”) upon Terabelian’s 
arrival at around 3:30 p.m. on October 19, 2020. 
3. 
Exhibit 3 is a true and correct copy of a photograph a 
photograph obtained from CBP that depicted one credit card in the 
name of “Runyan Tax Services/Viktoria Kauichko,” and four credit 
cards in the name of “Iuliia Zhadko,” including cards associated with 
“Top Quality Contracting” and “Turing Info Solutions that were found 
in defendant Richard Ayvazyan’s (“Ayvazyan”) belongings after 
officers conducted a secondary inspection at MIA upon Ayvazyan’s 
arrival at around 3:30 p.m. on October 19, 2020. 
4. 
Exhibit 4 is a true and correct copy of a directive issued 
by CBP.   
5. 
Exhibit 5 is a true and correct copy of a report from CBP 
related to defendant Ayvazyan.  
Case 2:20-cr-00579-SVW     Document 152-1     Filed 03/15/21     Page 1 of 3   Page ID
#:1150

 
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6. 
Exhibit 6 is a true and correct copy of a report from CBP 
related to defendant Terabelian.  
7. 
Exhibit 7 is a true and correct copy of a tear sheet from 
CBP that is given to passengers regarding “Inspection of Digital 
Devices”.    
8. 
Exhibit 8 is a true and correct copy of photographs 
obtained from CBP that depicted items that were discovered when CBP 
officers conducted a manual search of defendant Terabelian and 
defendant Ayvazyan’s digital devices.  
9. 
Exhibit 9 is a true and correct copy of a biographical 
questionnaire that was provided to defendants Terabalian and Ayvazyan 
by CBP officers at MIA.  
10. 
Exhibit 10 is a true and correct copy of a FBI report 
regarding the arrest of defendants Terabelian and Ayvazyan.  
11. 
Exhibit 11 is a true and correct copy of a search warrant 
application in case no. 20-MJ-5282.    
12. 
Exhibit 12 is a true and correct copy of a search warrant 
application in case no. 20-MJ-5484. 
13. 
Exhibit 13 is a true and correct copy of a report regarding 
the execution of a search warrant in case no. 20-MJ-5286. 
14. 
Exhibit 14 is a true and correct copy of a letter from CBP 
to DOJ Trial Attorney Christopher Fenton and the undersigned 
declarant. 
// 
 
 
Case 2:20-cr-00579-SVW     Document 152-1     Filed 03/15/21     Page 2 of 3   Page ID
#:1151

 
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I declare under penalty of perjury under the laws of the United 
States of America that the foregoing is true and correct and that 
this declaration is executed at Princeville, Hawaii, on March 15, 
2021. 
 
 
 
SCOTT PAETTY 
 
Case 2:20-cr-00579-SVW     Document 152-1     Filed 03/15/21     Page 3 of 3   Page ID
#:1152

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