Court filing
Exhibit — USA v. Ayvazyan et al (Dkt. 391.5)
Filed May 31, 2021 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 | 2021-05-31 |
U.S. District Court for the Central District of California · No. 2:20-cr-00579-SVW · Doc. 391-5 · 2021-05-31 · Docket on CourtListener
Full text
EXHIBIT 10 Case 2:20-cr-00579-SVW Document 391-5 Filed 05/31/21 Page 1 of 7 Page ID #:4072 United States Department of Justice United States Attorney’s Office Central District of California Scott Paetty Phone: (213) 894-6527 E-mail: Scott.Paetty@usdoj.gov 1100 United States Courthouse 312 North Spring Street Los Angeles, California 90012 BY EMAIL April 26, 2021 Ashwin J. Ram Michael A. Keough Nicholas P. Silverman Steptoe & Johnson LLP 1330 Connecticut Avenue, NW Washington, DC 20036 Counsel for Richard Ayvazyan David D. Diamond Diamond and Associates 1200 Wilshire Boulevard Suite 406 Los Angeles, CA 90017 John Lewis Littrell Bienert Katzman PC 903 Calle Amanecer Suite 350 San Clemente, CA 92673 Counsel for Marietta Terabelian Thomas A. Mesereau, Jr. Mesereau Law Group 10100 Santa Monica Boulevard Suite 300 Los Angeles, CA 90067 Jennifer J. Wirsching Attorney at Law 1935 Alpha Road Suite 216 Glendale, CA 91208 Counsel for Artur Ayvazyan Fred G. Minassian Law Offices of Fred G. Minassian, Inc. 101 N. Brand Blvd., Suite 1970 Glendale, CA 91203 Counsel for Tamara Dadyan Re: United States v. Ayvazyan et. al, No. CR 2:20-cr-00579-SVW Dear Counsel: We write to you concerning materials seized from the residences of your respective clients, Richard Ayvazyan, Marietta Terabelian, Artur Ayvazyan and Tamara Dadyan, pursuant to federal search warrants 2:20-mj-5282 and 2:20-mj-5286, executed on November 5, 2020. As the government previously explained, certain of the digital devices that the government obtained from the execution of these search warrants (e.g., smartphones, computers, and removable storage media), were provided to the government’s filter team for a privilege review.1 1 As the government previously explained, certain of the digital devices that the government obtained from the execution of these search warrants – namely routers, modems, a Case 2:20-cr-00579-SVW Document 391-5 Filed 05/31/21 Page 2 of 7 Page ID #:4073 RE: United States v. Ayvazyan et. al April 26, 2021 Page 2 We understand that the filter team has reviewed the data obtained from certain of these digital devices, and the filter team provided to the prosecution team the data that the filter team determined not to be potentially privileged in the form of Cellebrite reports or reviewable load files. The prosecution team, in turn, has produced all of those filtered Cellebrite reports and reviewable load files that are discoverable and in its possession to defense counsel in the criminal case, all of whom are copied on this correspondence. We further understand that the filter team is completing its filter of four additional digital devices, described in Exhibit A attached hereto, and will provide to the prosecution team the data that the filter team determines not to be potentially privileged in the form of Cellebrite reports. The prosecution team, in turn, will produce these four filtered Cellebrite reports to defense counsel in the criminal case, all of whom are copied on this correspondence. These four Cellebrite reports will be produced in addition to the complete forensic copy of these four digital devices, which, as you know, the government previously produced to you (counsel for the original four defendants) on February 1, 2021. We also understand that there are additional materials that the filter team has not reviewed and therefore has made no determination as to whether they are privileged, namely data obtained from various digital devices that have been imaged but not reviewed. These additional materials have not been released to the prosecution team and thus will not be used by the prosecution team in its case-in-chief in this matter. It is also our understanding that the filter team does not intend to continue reviewing these additional materials for privilege. These digital devices are listed in the attached Exhibit B, and we understand the FBI will be returning each listed device to counsel for its respective owner. As we previously explained to you, we also understand that there are several digital devices that CART could not access for imaging or review. These additional materials will not be used by the prosecution team in its case-in-chief in this matter. It is also our understanding that no further efforts will be undertaken by CART to access these devices. The digital devices that CART could not access for imaging or review are listed in the attached Exhibit C. We understand the FBI will be returning each listed device to counsel for its respective owner. As you know, the government already provided to you, as counsel for the original four defendants in this case, a complete forensic image of all of the digital devices that could be accessed and imaged based on your December 11, 2020, joint-letter stating that “each defendant provides a limited consent that their electronic data may be shared with the other three defendants currently in the case for the purposes of their defense in this case.” Thus, with respect to all of the digital devices provided to the filter team, including the digital devices listed in Exhibits A and B, you have already received a complete forensic image of those devices, and you will now receive back the underlying devices reflected in Exhibit B as well. As for the encrypted and damaged devices listed in Exhibit C that could not be accessed or imaged, as cable box, and GPS devices – were separately provided to and analyzed by the FBI’s Computer Analysis and Response Team (CART). (See Mar. 26, 2021 Letter; Apr. 9, 2021 Letter.) Case 2:20-cr-00579-SVW Document 391-5 Filed 05/31/21 Page 3 of 7 Page ID #:4074 Case 2:20-cr-00579-SVW Document 391-5 Filed 05/31/21 Page 4 of 7 Page ID #:4075 Case 2:20-cr-00579-SVW Document 391-5 Filed 05/31/21 Page 5 of 7 Page ID #:4076 Case 2:20-cr-00579-SVW Document 391-5 Filed 05/31/21 Page 6 of 7 Page ID #:4077 Case 2:20-cr-00579-SVW Document 391-5 Filed 05/31/21 Page 7 of 7 Page ID #:4078
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- gov.uscourts.cacd.802533.391.5.pdf
- Size
- 443,551 bytes
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- 67e4d4e02cf7ca0ba37c3c6758594c80934d07af0acfd106336ee612d6ab7f81
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