Court filing
Exhibit — USA v. Ayvazyan et al (Dkt. 391.7)
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. 391-7 · 2021-05-31 · Docket on CourtListener
Full text
EXHIBIT 12 Case 2:20-cr-00579-SVW Document 391-7 Filed 05/31/21 Page 1 of 5 Page ID #:4084 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 FEDEX & EMAIL May 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 3500 West Olive Avenue Suite 300 Burbank, California 91505 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 John David Hanusz Hanusz Law, PC 800 Wilshire Blvd, Ste 1050 Los Angeles, CA 90017-2672 Counsel for Manuk Grigoryan Jilbert Tahmazian Tahmazian Law Firm, P.C. 1518 West Glenoaks Boulevard Glendale, CA 91201 Counsel for Arman Hayrapetyan Michael Freedman The Freedman Firm 800 Wilshire Blvd., Suite 1050 Los Angeles, CA 90017 Counsel for Edvard Paronyan Peter Johnson Peter Johnson Law 409 North Pacific Coast Hwy, 651 Redondo Beach, California 90277 Counsel for Vahe Dadyan Case 2:20-cr-00579-SVW Document 391-7 Filed 05/31/21 Page 2 of 5 Page ID #:4085 RE: United States v. Ayvazyan et. al May 26, 2021 Page 2 Re: United States v. Ayvazyan et. al, No. CR 2:20-cr-00579-SVW Discovery Production – Seized Materials Dear Counsel: We write with respect to the following digital devices: • 1B17 – Artur Ayvazyan’s iPhone • 1B21 – Tamara Dadyan’s iPhone • 1B81 – Marietta Terabelian’s iPhone • 1B85 – Richard Ayvazyan’s iPhone On February 1, 2021, the government produced a complete forensic copy of each of the above- listed iPhones to counsel for defendants Richard Ayvazyan, Marietta Terabelian, Tamara Dadyan, and Artur Ayvazyan. As you know, an independent filter team then generated a Cellebrite report for each of these iPhones and conducted an independent review for potentially privileged materials. Upon the independent filter team’s completion of its review of each of the Cellebrite reports for the above-listed iPhones, the independent filter team released a redacted copy of the Cellebrite reports to the prosecution team and the prosecution team, in turn, produced them to you. The redacted copy of the Cellebrite reports for the above-listed iPhones were produced to counsel for all defendants on April 30, 2021. Members of the prosecution team then conducted a review of the redacted Cellebrite reports for the above-listed iPhones to identify the materials that are within the scope of the applicable search warrants that would be seized. Although the deadline to complete the responsiveness review for these iPhones is July 3, 2021, the review has been completed five and a half weeks early. Pursuant to your clients’ requests for discovery and the Court’s protective order (see CR 92), enclosed please find a disc with discovery bearing Bates Numbers DOJ_PROD_0000163654 to DOJ_PROD_0000163657 and an attached index.1 These discovery materials include the materials from the above-listed iPhones that the prosecution team has seized pursuant to the applicable search warrants. This is a subset of the discovery that was previously produced to you. These discovery materials are also being uploaded to Steptoe & Johnson’s file sharing system and USAfx, as some of you have requested. The prosecution team is reviewing these materials to determine what materials from these iPhones will be used a trial exhibits at trial. The prosecution team will disclose those trial exhibits on June 1, 2021, pursuant to the Court’s April 16, 2021 order (CR 284). 1 The password to access the discovery materials will be emailed to you separately. Case 2:20-cr-00579-SVW Document 391-7 Filed 05/31/21 Page 3 of 5 Page ID #:4086 RE: United States v. Ayvazyan et. al May 26, 2021 Page 3 As with prior productions, the enclosed materials, and any future discovery provided to you, may exceed the scope of discovery mandated by the Federal Rules of Criminal Procedure, federal statute, or relevant case law, and are thus provided voluntarily and solely as a matter of discretion. By producing such materials to you, the government does not waive its right to object to any future discovery requests beyond the ambit of its legal obligations. Please let me know if you have any questions. Very truly yours, SCOTT PAETTY CATHERINE AHN Assistant United States Attorneys Major Frauds Section Christopher Fenton Trial Attorney Department of Justice Criminal Division Enclosure Case 2:20-cr-00579-SVW Document 391-7 Filed 05/31/21 Page 4 of 5 Page ID #:4087 United States v. Ayvazyan et al. Discovery Production – Seized Materials Index Description Production BEGDOC Production ENDDOC 1B17 – Reproduced Cellebrite Report DOJ_PROD_0000163654 DOJ_PROD_0000163654 1B21 – Reproduced Cellebrite Report DOJ_PROD_0000163655 DOJ_PROD_0000163655 1B81 – Reproduced Cellebrite Report DOJ_PROD_0000163656 DOJ_PROD_0000163656 1B85 – Reproduced Cellebrite Report DOJ_PROD_0000163657 DOJ_PROD_0000163657 Case 2:20-cr-00579-SVW Document 391-7 Filed 05/31/21 Page 5 of 5 Page ID #:4088
File and source
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- gov.uscourts.cacd.802533.391.7.pdf
- Size
- 281,070 bytes
- SHA-256
- 0ef02fedef5361ef0dd21000a7e3561f4b2d7895c80cf413bc2fd2e26ad4df10
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