Declaration — USA v. Ayvazyan et al. (Dkt. 207-2, C.D. Cal.)

Summary

Christopher Fenton, a Trial Attorney in the Justice Department's Criminal Division, Fraud Section, declares what Exhibits 1 through 14 are, in United States v. Richard Ayvazyan et al., No. 20-CR-579(A)-SVW (C.D. Cal.), Document 207-2, filed 03/22/21. The exhibits include FBI firearms checks on Richard and Artur Ayvazyan, a photograph of items from trash left outside a Glendale property bought in the name of Iuliia Zhadko, described as Richard Ayvazyan's alias, and an FBI property receipt and reports on the search of SUBJECT PREMISES-4 on or about November 5, 2020. Other exhibits are photographs of ammunition, a gun safe and its contents, fake and stolen identification and credit cards, a list titled EMAILS FOR BORROWERS, loan applications and blank checks. Each was produced in discovery. The declaration is dated March 22, 2021.

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DECLARATION OF CHRISTOPHER FENTON 
I, Christopher Fenton, hereby declare and state as follows: 
I am a Trial Attorney with the Criminal Division, Fraud Section, 
of the United States Department of Justice.  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 the results of a 
firearms check run by the Federal Bureau of Investigation (“FBI”) on 
defendant Richard Ayvazyan (“R. Ayvazyan”).  This document was Bates-
stamped DOJ_PROD_0000002185-DOJ_PROD_0000002187, and produced in 
discovery. 
2. 
Exhibit 2 is a true and correct copy of the results of a 
firearms check run by the FBI on defendant Artur Ayvazyan.  This 
document was Bates-stamped DOJ_PROD_0000154368, and produced in 
discovery. 
3. 
Exhibit 3 is a true and correct copy of a photograph taken 
on or about October 7, 2020, depicting items found as part of a 
search by law enforcement of trash left curbside outside of the 
Glendale property that defendants purchased in the name of defendant 
R. Ayvazyan’s alias, “Iuliia Zhadko.”  This document was Bates-
stamped DOJ_PROD_0000003743, and produced in discovery. 
4. 
Exhibit 4 is a true and correct copy of a receipt for 
property prepared by the FBI following law enforcement’s search of 
SUBJECT PREMISES-4 on or about November 5, 2020.  This document was 
Bates-stamped DOJ_PROD_0000153638-DOJ_PROD_0000153640, and produced 
in discovery. 
5. 
Exhibit 5 is a true and correct copy of photographs 
depicting ammunition and empty magazines found during law 
Case 2:20-cr-00579-SVW     Document 207-2     Filed 03/22/21     Page 1 of 4   Page ID
#:1713

 
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enforcement’s search of SUBJECT PREMISES-4 on or about November 5, 
2020.  These documents were Bates-stamped DOJ_PROD_0000028774, 
DOJ_PROD_0000028777, and DOJ_PROD_0000028780, and produced in 
discovery. 
6. 
Exhibit 6 is a true and correct copy of a photograph 
depicting a gun safe found during law enforcement’s search of SUBJECT 
PREMISES-4 on or about November 5, 2020.  This document was Bates-
stamped DOJ_PROD_0000022853, and produced in discovery. 
7. 
Exhibit 7 is a true and correct copy of a report from the 
FBI related to law enforcement’s search of SUBJECT PREMISES-4 on or 
about November 5, 2020.  This document was Bates-stamped 
DOJ_PROD_0000153633-DOJ_PROD_0000153634, and produced in discovery. 
8. 
Exhibit 8 is a true and correct copy of photographs 
depicting examples of the fake and stolen California driver’s 
licenses, social security cards, and credit cards found during law 
enforcement’s search of SUBJECT PREMISES-4 on or about November 5, 
2020.  These documents were Bates-stamped DOJ_PROD_0000028011, 
DOJ_PROD_0000028013, DOJ_PROD_0000028015, DOJ_PROD_0000028019, and 
DOJ_PROD_0000028021, and produced in discovery. 
9. 
Exhibit 9 is a true and correct copy of examples of 
handwritten and typed lists of personally identifiable information 
(“PII”) seized during law enforcement’s search of SUBJECT PREMISES-4 
on or about November 5, 2020.  These documents were Bates-stamped 
DOJ_PROD_0000023893-DOJ_PROD_0000023894 and DOJ_PROD_0000023897- 
DOJ_PROD_0000023904, and produced in discovery. 
10. 
Exhibit 10 is a true and correct copy of a list titled 
“EMAILS FOR BORROWERS” seized during law enforcement’s search of 
SUBJECT PREMISES-4 on or about November 5, 2020.  This document was 
Case 2:20-cr-00579-SVW     Document 207-2     Filed 03/22/21     Page 2 of 4   Page ID
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Bates-stamped DOJ_PROD_0000027515-DOJ_PROD_0000027519, and produced 
in discovery. 
11. 
Exhibit 11 is a true and correct copy of an example of 
COVID-19 disaster relief loan applications seized during law 
enforcement’s search of SUBJECT PREMISES-4 on or about November 5, 
2020.  These documents were Bates-stamped DOJ_PROD_0000026641- 
DOJ_PROD_0000026653, and produced in discovery. 
12. 
Exhibit 12 is a true and correct copy of examples of blank 
checks seized during law enforcement’s search of SUBJECT PREMISES-4 
on or about November 5, 2020, including blank checks signed by “T.T,” 
who is recently deceased.  These documents were Bates-stamped 
DOJ_PROD_0000024574-DOJ_PROD_0000024581 and DOJ_PROD_0000151004, and 
produced in discovery. 
13. 
Exhibit 13 is a true and correct copy of a report regarding 
the execution of the search warrant for SUBJECT PREMISES-4.  This 
document was Bates-stamped DOJ_PROD_0000149591–DOJ_PROD_0000149602, 
and produced in discovery. 
14. 
Exhibit 14 is a true and correct copy of photographs 
depicting an envelope and U.S. currency found in a safe during law  
// 
// 
 
 
 
 
 
 
 
Case 2:20-cr-00579-SVW     Document 207-2     Filed 03/22/21     Page 3 of 4   Page ID
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enforcement’s search of SUBJECT PREMISES-4 on or about November 5, 
2020.  These documents were Bates-stamped DOJ_PROD_0000022830- 
DOJ_PROD_0000022831, and produced in discovery. 
 
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 West Tisbury, Massachusetts, on March 
22, 2021. 
  
 
 
CHRISTOPHER FENTON 
 
Case 2:20-cr-00579-SVW     Document 207-2     Filed 03/22/21     Page 4 of 4   Page ID
#:1716

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