Declaration of Ashwin J. Ram in Support — USA v. Ayvazyan et al (Dkt. 419.1)

Record facts

U.S. District Court for the Central District of California · No. 2:20-cr-00579-SVW · Doc. 419-1 · 2021-06-04 · Docket on CourtListener

Summary

A two-page declaration of Ashwin J. Ram, counsel of record for defendant Richard Ayvazyan, filed June 4, 2021 as Doc. 419-1 in United States v. Ayvazyan, et al., No. 2:20-cr-00579-SVW, in the U.S. District Court for the Central District of California. It supports the defendants' opposition to the government's Motion in Limine #2 to admit evidence inextricably intertwined with the charged offenses, set for hearing on June 14, 2021 before Judge Stephen V. Wilson. The declaration attaches as Exhibit A an indictment filed April 26, 2021 in the Superior Court of the State of California, Los Angeles County, Case No. BA484293. It attaches as Exhibit B an email from the government to defense counsel dated May 27, 2021.

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Full text

DECLARATION OF A. RAM IN SUPPORT OPPOSITION TO MOTION IN LIMINE 
TO ADMIT “RESERVE IDENTITIES” EVIDENCE 
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Ashwin J. Ram (SBN 227513) 
aram@steptoe.com 
Michael A. Keough (SBN 327037) 
mkeough@steptoe.com 
Meghan L. Newcomer (pro hac vice) 
mnewcomer@steptoe.com 
Nicholas P. Silverman (pro hac vice) 
nsilverman@steptoe.com 
STEPTOE & JOHNSON LLP 
633 West Fifth Street, Suite 1900 
Los Angeles, CA 90071 
Telephone: (213) 439-9400 
Facsimile: (213) 439-9599 
 
 
Counsel for Defendant Richard Ayvazyan 
 
UNITED STATES DISTRICT COURT 
CENTRAL DISTRICT OF CALIFORNIA  
 
 
UNITED STATES OF AMERICA, 
 
                              Plaintiff, 
 
v. 
 
RICHARD AYVAZYAN, 
et al., 
 
Defendants. 
 Case No.  20-cr-579 (SVW) 
 
DECLARATION OF ASHWIN J. 
RAM IN SUPPORT OF 
DEFENDANTS’ OPPOSITION TO 
GOVERNMENT’S MOTION IN 
LIMINE #2 TO ADMIT EVIDENCE 
INEXTRICABLY INTERTWINED 
WITH THE CHARGED OFFENSES 
 
Judge:               Hon. Stephen V. Wilson 
Hearing Date:   June 14, 2021 
Time:                11:00 a.m. 
 
 
 
 
Case 2:20-cr-00579-SVW     Document 419-1     Filed 06/04/21     Page 1 of 2   Page ID
#:4391

 
 
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DECLARATION OF A. RAM IN SUPPORT OF OPPOSITION TO MOTION IN 
LIMINE TO ADMIT “RESERVE IDENTITIES” EVIDENCE 
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I, Ashwin J. Ram, declare as follows: 
1. 
I am an attorney licensed to practice law in the state of California.  I am a 
partner at the law firm of Steptoe & Johnson LLP and counsel of record for defendant 
Richard Ayvazyan in the above-captioned matter. 
2. 
Attached as Exhibit A is a true and correct copy of the Indictment filed on 
April 26, 2021 in the matter of People of the State of California v. Dadyan, et al., Case 
No. BA484293 before the Superior Court of the State of California, Los Angeles 
County. 
3. 
Attached as Exhibit B is a true and correct copy of an email from the 
government to defense counsel dated May 27, 2021. 
I declare under penalty of perjury that the foregoing is true and correct. 
Executed at Los Angeles, California on June 4, 2021. 
 
 
 
 
 
 
 
 
Respectfully submitted,  
 
 
 
 
 
 
 
 
/s/ Ashwin J. Ram  
 
 
 
 
 
 
 
 
 
Ashwin J. Ram  
 
 
 
 
Counsel for Defendant Richard Ayvazyan 
Case 2:20-cr-00579-SVW     Document 419-1     Filed 06/04/21     Page 2 of 2   Page ID
#:4392

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