Exhibit — USA v. Ayvazyan et al (Dkt. 391.3)

Record facts

U.S. District Court for the Central District of California · No. 2:20-cr-00579-SVW · Doc. 391-3 · 2021-05-31 · Docket on CourtListener

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EXHIBIT 8 
 
Case 2:20-cr-00579-SVW     Document 391-3     Filed 05/31/21     Page 1 of 3   Page ID
#:4065

From:
Andre, Julian L. (USACAC)
To:
Silverman, Nicholas
Cc:
Ram, Ashwin; Keough, Michael; John Littrell; David Diamond; Law offices of Fred G. Minassian, Inc.;
mesereau@mesereaulaw.com; Wirschinglaw@outlook.com; Fenton, Christopher (CRM)
Subject:
RE: US v. Ayvazyan - Digital Device Data (Dec. 24 production)
Date:
Monday, January 4, 2021 6:35:50 PM
Nick:
 
We produced to the defendants complete forensic copies of the seven digital devices.  This is the
FBI’s standard method of producing copies of digital devices as it allows the defense to access all of
the data on the devices and to conduct its own review of the devices.  We understand that there are
a number of commercially available software programs that the defense can use to access, search,
and review the data on the forensic copies.  We further understand that there are a number of free
software programs available online that would allow the defense to review the forensic copies,
including a free version of FTK Imager available for download from AccessData at
 https://accessdata.com.
 
The government does not have the type of “logistical report” referenced in your email and has not
otherwise distilled the information into some “other PDF format.”  We have not yet produced any of
these types of reports because the government has prioritized providing the defense with complete
forensic copies of the devices and therefore has not yet completed its own review of the devices. 
We will produce any discoverable reports generated as part of the government’s review of the
devices once the government’s review is complete and such reports are generated.
 
Additionally, we are planning to produce copies of additional digital devices to you on or before
Monday, January 11, 2021.   We, however, have been advised that some of the forensic images are
very large and will likely require additional storage space.  Would it be possible for you to send
another 2TB or larger external hard-drive to Agent Palmerton tomorrow that the FBI can use to load
the additional digital data?  The hard-drive should be sent to the following address:
 
Justin Palmerton, Special Agent
Federal Bureau of Investigation
11000 Wilshire Blvd, Suite 1700
Los Angeles, California 90024
 
Thank you.
 
Julian L. André
Assistant United States Attorney
Major Frauds Section
United States Courthouse, Suite 1100
312 N. Spring St. | Los Angeles, California 90012
T: 213.894.6683 | julian.l.andre@usdoj.gov
 
 
From: Silverman, Nicholas <nsilverman@steptoe.com> 
Sent: Thursday, December 31, 2020 10:04 AM
Case 2:20-cr-00579-SVW     Document 391-3     Filed 05/31/21     Page 2 of 3   Page ID
#:4066

To: Andre, Julian L. (USACAC) <JAndre1@usa.doj.gov>; Fenton, Christopher (CRM)
<Christopher.Fenton@CRM.USDOJ.GOV>
Cc: Ram, Ashwin <aram@Steptoe.com>; Keough, Michael <mkeough@Steptoe.com>
Subject: US v. Ayvazyan - Digital Device Data (Dec. 24 production)
 
Julian and Chris,
 
I have been advised that we would need to forensically extract the digital device data at
significant cost in order to process the data produced on Dec. 24.  In our experience (both
Ashwin’s experience at C.D. Cal. and our experience with other cases around the country),
much if not all of the same information is usually available in a logistical report or other PDF
format.  Did the production include the logistical reports?  If so, we have not been able to
locate them.  Perhaps it would make sense to have a follow-up call with our technical
personnel in order to facilitate efficient production and review?
 
Regards,
 
Nicholas P. Silverman
Associate
nsilverman@steptoe.com
Steptoe
 
+1 202 429 8096 direct
+1 617 595 6559 mobile
+1 202 429 3902 fax
Steptoe & Johnson LLP
1330 Connecticut Avenue, NW
Washington, DC 20036
www.steptoe.com
 
 
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Case 2:20-cr-00579-SVW     Document 391-3     Filed 05/31/21     Page 3 of 3   Page ID
#:4067

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