Court filing
Exhibit A — USA v. Ayvazyan et al. (Dkt. 419-2, C.D. Cal.)
Filed June 4, 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 | 2021-06-04 |
U.S. District Court for the Central District of California · No. 2:20-cr-00579-SVW · Doc. 419-2 · 2021-06-04 · Docket on CourtListener
Full text
EXHIBIT A
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SUPERIOR COURT OF THE STATE OF CALIFORNIA
COUNTY OF LOS ANGELES
SPECIAL STATEWIDE GRAND JURY
THE PEOPLE OF THE STATE OF CALIFORNIA,
V.
1. TAMARA DADY AN, (DOB 10/3111981 ),
a/k/a "Tammy,"
2. RICHARD A YV AZY AN, (DOB 08/02/1978),
a/k/a "Richard Ayvazian,"
a/k/a "Rich,"
a/k/a "Richo,"
(A..s ~ NVr,11 ~
Plaintiff,
~
'1 'j '{ 2 q 3
o FORMED .,OPV
C
ORIGINAL Fil ED .
S
Of\ I' court at C, l1forn1a
ubounly ol Los An t:Jles
P,PR 2 6 2021
3. ARTUR A YV AZYAN, (DOB 02/09/1980),
a/k/a "Arthur,"
Sherri R. Carter, Executive O ticer/Clerk of Court
By: B. Perez, eputy
a/k/a "Art,"
4. GRIGOR TATOIAN, (DOB 07/16/1970),
a/k/a "Greg,"
5. ANDRANIKPETROSYAN, (DOB 01/15/1975)
a/k/a "Andy,"
a/k/a "Ando,"
6. ARSHAKBARTOUMIAN (07/26/1972),
7. ARTASHES MARTIROSYAN, (DOB 08/30/1977),
a/k/a "Art,"
8. LILIT MALY AN, (DOB 04/08/1982),
a/k/a "Lilo,"
9. LUBIA CARRILLO (DOB 08/26/1980),
10. ROSAZARATE,(DOB 11/07/1971),
a/k/a "Roza A vakian,"
11. ESTEPHANIE REYNOSO (DOB 12/04/1989),
12. VANESSA BELL (05/20/1960),
Page 1 of99
INDICTMENT
Defendants.
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A Special Statewide Grand Jury of the County of Los Angeles, State of California, accuses
the following defendants of committing, in the Counties of Los Angeles, Riverside, and Ventura,
before the finding of this indictment, of the following crimes: ~
COUNTl ~
CONSPIRACY TO COlVIMIT GRAND THEFT Re:
nthon A.
On or about and between May 1, 2015, and October 7, 2019, in the COUNTY of LOS
ANGELES, the crime of CONSPIRACY, in violation of Penal Code section 182(a)(l) a felony,
was committed by TAMARA DADYAN, RICHARD AYVAZYAN, ARTUR AYVAZYAN,
ARTASHES MARTIROSYAN, GRIGOR TATOIAN, ESTEPHANIE REYNOSO, and ROSA
ZARA TE, who did willfully and unlawfully conspire together with another person or persons
whose identity is known or unknown to commit the crime of GRAND THEFT BY FALSE
PRETENSES, 487(a), of the California Penal Code, a felony, pursuant to and for the purpose of
carrying out the objects and purposes of the aforesaid conspiracy, Defendants committed the
following overt act(s):
OVERT ACT 1
On or about April 12, 2016, Tamara DADY AN emailed Grigor TA TO IAN with the subject
"Anthony DL copy and no he dosent have account at wells his the Corp president have your friend
open one for him," attaching a driver's license in Anthony A's name.
OVERTACT2
On or about April 15, 2016, Tamara DADYAN emailed Grigor TATOIAN with the subject
"Here u go Anthony Andrew," and attached California Driver's Licenses in the names of Anthony
A. and Andrew A.
OVERTACT3
On or about May 26, 2016, Artur A YV AZY AN posed as Anthony A. and signed a Deed of
Trust for a $1.84 million loan from the Bleecker Family Trust, secured by the property located at
5141 Genesta A venue in Encino, California.
II
II
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OVERT ACT4
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obtain $218,597 from Ygrene Energy
for purported improvements to his home at 5141
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Genesta.
OVERTACT5
~
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On or about July 5, 201~ !fohard A YV AZYAN mailed Tamara DADY AN with the subject
-
line, "List of other repairs that YGR:E)'qE will finance."
on RTJ\C'f--e, _ _ _ __ _
9
On or about November 3, 2016, Richard A YV AZYAN emailed Tamara DADY AN with the
10
subject, "INVENTORY OF ALL PROJECTS," and attached a spreadsheet that detailed the status
11
of Ygrene and Renew funding as to different addresses and names, including Anthony A.
12
OVERT ACT 7
13
On or about November 22, 2016 Richard A YV AZY AN mailed Tamara DADY AN, using
14
Anthony A.'s name, with the subject, "TIN REQUEST," writing, "TAM, I FILLED OUT THE
15
FORM. WE rusT NEED TO FAX IT. I DON'T HA VE AF AX AT THE OFFICE. ALSO, I USED
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THE LITHUANIA ADDRESS, MAKE SURE WE CAN STILL GET MAIL THERE."
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A YV AZY AN attached an Employer Identification Number application in the name o Andrew A.
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and SA VS Enterprise.
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OVERT ACT 8
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On or about December 5, 2016, Rosa ZARATE used a U.S. Bank ATM to access the account
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ending in -9086, held in Anthony A. 's name.
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OVERT ACT 9
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On or about December 21, 2016, Richard A YV AZY AN sent Tamara DADY AN statements
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from a U.S. Bank account ending in -9086 held in the name of Anthony A.
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OVERT ACT 10
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On or about April 4, 2017, Richard A YV AZY AN posed as Anthony A. to obtain $21,900
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from Renew Funding for purported improvements to 22330 Victory Blvd., Unit No. 303 m
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Woodland Hills.
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OVERT ACT 11
2
On or about April 4, 2017, Richard A YV AZYAN posed as Anthony A. to obtain $24,800
3
from Y grene Energy Fund for purported improvements to 22330 Victory Blvd., Unit No. 303.
4
OVERT ACT 12
5
On or about May 7, 2017, Richard A YV AZY AN posed as Anthony A. via email in order to
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obtain $199,940 from Renew Funding for purported improvements to his home at 5141 Genesta.
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OVERT ACT 13
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On or about June 15, 2017, Richard A YV AZY AN posed as Anthony A. via email in order to
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obtain a $1,500,000 loan from East West Bank for his Genesta home.
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OVERT ACT 14
11
On or about August 16, 2017, Artur A YV AZY AN posed as Anthony A. and signed a grant
12
deed to Susanna M. for the 5141 Genesta property.
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OVERT ACT 15
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On or about April 5, 2018, Richard A YV AZYAN emailed Tamara DADY AN a recorded
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"Notice of Default" on a loan taken out in Anthony A.'s name for the property located at 22330
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Victory Blvd., #303, in Woodland Hills, and asked her, "How do we stop the sale?"
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OVERT ACT 16
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On or about June 5, 2018, Tamara DADYAN emailed Artashes MARTIROSYAN a
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document titled, "14808 Aztec Family Trust," that listed Anthony A. as a Successor Trustee and
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was purportedly notarized by Pauline S. on February 8, 2018.
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OVERT ACT 17
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On or about June 20, 2018, Richard AYVAZYAN emailed Tamara DADYAN, usmg
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Anthony A.'s name, regarding a Ygrene Energy Fund representative's requests.
24
OVERT ACT 18
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On or about July 18, 2018, Richard AYVAZYAN emailed Vanessa BELL, using Anthony
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A.' s name, and told BELL to email another PACE company "saying that you would like to cancel
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the project with the current Contractor."
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//
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COUNT
UNLAWFUL TRANSFER OF IDENTIFY IN
Re: Anthon A.
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On or about May 7, 2017, in the COUNTY of LOS ANGELES, the crime ofIDENTITY
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THEFT in violation of Penal Code section 530.5(d)(l), a felony, was committed by TAMARA
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DADYAN, RJCHARD AYVAZYAN, ARTUR AYVAZYAN, ARTASHES MARTIROSYAN,
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GRJGOR TATOIAN, £STEPHANIE REYNOSO, and ROSA ZARA TE, who did willfully and
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unlawfully with the intent to defraud sell, transfer, or convey the personal identifying information
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of another person, to wit: ANTHONY A.'S NAME ON A RENEW FUNDING AGREEMENT
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TO PAY ASSESSMENT AND FINANCE IMPROVEMENTS AS TO 51
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IN ENCINO, CALIFORNIA.
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COUNT3
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GRAND THEFT Re: Anthon
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On or about and between February 1, 2017, and June 28, 2017, in the COUNTY of LOS
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ANGELES, the crime of GRAND THEFT in violation of Penal Code section 487(a), a felony, was
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c_ommitted by TAMARA DADYAN, RJCHARD AYVAZYAN, ARTUR AYVAZYAN,
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ARTASHES MARTIROSYAN, GRJGOR TATOIAN, £STEPHANIE REYNOSO, and ROSA
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ZARA TE, who did knowingly and designedly, by a false or fraudulent representation or pretense,
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obtain money, or real property by fraud from RENEW FUNDING, SPECIFICALLY, $199,940
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FOR 5141 GENESTA AVENUE IN ENCINO, CALIFORNIA, which had a value exceeding nine
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hundred fifty dollars ($950).
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COUNT4
MORTGAGE FRAUD
e: Anthon
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On or about and between March 29, 2017, and July 31, 2017, in the COUNTY of LOS
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ANGELES, the crime of MORTGAGE FRAUD in violation of Penal Code section 532f(a)(2), a
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felony, was committed by TAMARA DADYAN, RJCHARD AYVAZYAN, ARTUR
26
AYVAZYAN,
ARTASHES
MARTIROSYAN,
GRJGOR
TATOIAN,
£STEPHANIE
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REYNOSO, and ROSA ZAF~t\ TE, ,,,ho did unlawfully and deliberately use or facilitate the use of
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a misstatement, misrepresentation, or omission, with the knowledge it contained a misstatement,
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misrepresentation, or omission, during the mortgage lending process, with the intention that it be
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relied upon by a mortgage lender, borrower, or other party to the mortgage lending process, to wit:
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EAST WEST BANK. It is further alleged, pursuant to Penal Code section 532fU), that the value
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of the fraud exceeds $950.
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6
COUNTS
GRAND THEFT
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On or about and between March 8, 2017, and August 23, 2017, in the COUNTY of LOS
8
ANGELES, the crime of GRAND THEFT in violation of Penal Code section 487(a), a felony, was
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committed by TAMARA DADYAN, RlCHARD AYVAZYAN, ARTUR AYVAZYAN,
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ARTASHES MARTIROSYAN, GRIGOR TATOIAN, ESTEPHANIE REYNOSO, and ROSA
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ZARA TE, who did knowingly and designedly, by a false or fraudulent representation or pretense,
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obtain money, labor or real and personal property by fraud from EAST WEST BANK,
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SPECIFICALLY, A $1,500,000 LOAN FOR 5141 GENESTA .ii"-'~~
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CALIFORNIA, which had a value exceeding nine hundred fifty dollars
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COUNT 6
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UNLAWFUL TRANSFER OF IDENTIFYING INFO
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On or about July 13, 2017, in the COUNTY of LOS ANGELES, the crime ofIDENTITY
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THEFT in violation of Penal Code section 530.5(d)(l), a felony, was committed by TAMARA
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DADYAN, RICHARD AYVAZYAN, ARTUR AYVAZYAN, ARTASHES MARTIROSYAN,
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GRIGOR TATOIAN, ESTEPHANIE REYNOSO, and ROSA ZARATE, who did willfully and
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unlawfully with the intent to defraud sell, transfer, or convey the personal identifying information
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of another person, to wit:
ANTHONY A.'S NAME ON RECORDED DOCUMENT NO.
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20170862745, A $1,500,000 EAST WEST BANK DEED OF TRUST FOR 5141 GENESTA
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A VENUE IN ENCINO, CALIFORNIA.
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COUNT7
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PROCURING OR OFFERING FALSE OR FORGED
e: Anthon A.
27
On or about July 13, 2017, in the COUNTY of LOS ANGELES, the crime of PROCURING
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OR OFFERING A FALSE OR FORGED INSTRUMENT in violation of Penal Code section
Page 6 of99
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115(a), a felony, was committed by TAMARA DADYAN, RJCHARD AYVAZYAN, ARTUR
2
AYVAZYAN,
ARTASHES
MARTIROSYAN,
GRIGOR
TATOIAN,
ESTEPHANIE
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REYNOSO, and ROSA ZARA TE, who did unlawfully and knowingly procure or offer a false or
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forged instrument to be filed, registered, or recorded in a public office in California, which
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instrument, if genuine, might be filed, registered, or recorded under a law of California or the United
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States, to wit: RECORDED DOCUMENT NO. 2017086LJ-'t~~/-\.ST WEST BANK DEED OF
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TRUST FOR 5141 GENEST A A VENUE.
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COUNTS
9
MORTGAGE FRAUD EXCEEDING $950: FIL
10
(Re: Anthony A.)
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On or about July 13, 2017, in the COUNTY of LOS ANGELES, the crime of FILING A
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FRAUDULENT DOCUMENT in violation of Penal Code section 532f(a)(4), a felony, was
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committed by TAMARA DADYAN, RJCHARD AYVAZYAN, ARTUR AYVAZYAN,
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ARTASHES MARTIROSYAN, GRJGOR TATOIAN, ESTEPHANIE REYNOSO, and ROSA
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ZARA TE, who did with the intent to defraud, file or cause to be filed with the recorder of any
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county in connection with a mortgage loan transaction, a document with the knowledge the
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document contains a deliberate misstatement, misrepresentation, or omission, to wit: RECORDED
18
DOCUMENT NO. 20170862745, EAST WEST BANK DEED OF TRUST FOR 5141 GENESTA
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A VENUE. It is further alleged that the value of the fraud exceeds nine hundred fifty dollars ($950),
20
within the meaning of Penal Code section 532fU).
21
COUNT 9
22
UNLAWFUL TRANSFER OF IDENTIFYING INF
23
On or about July 27, 2017, in the COUNTY of LOS ANGELES, the crime of IDENTITY
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THEFT in violation of Penal Code section 530.5(d)(l), a felony, was committed by TAMARA
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DADYAN, RJCHARD AYVAZYAN, ARTUR AYVAZYAN, ARTASHES MARTIROSYAN,
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GRIGOR TATOIAN, ESTEPHANIE REYNOSO, and ROSA ZARATE, who did willfully and
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unlawfully with the intent to defraud sell, transfer, or convey the personal identif;ing information
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of another person, to wit: ANTHONY A.'S NAME THROUGH THE USE OF THE "LOGIC360"
EMAIL ACCOUNT.
@)
COUNT 10
NLA WFUL TRAN FER OF IDENTIFYING INFORMATIO {Re: Anthony A.}
On or about August 16, 2017, in the COUNTY of LOS ANGELES, the crime oflDENTITY
THEFT in violation of Penal Code section 530.5(d)(l), a felony, was committed by TAMARA
DADYAN, RICHARD AYVAZYAN, ARTUR AYVAZYAN, ARTASHES MARTIROSYAN,
GRIGOR TATOIAN, ESTEPHANIE REYNOSO, and ROSA ZARA TE, who did willfully and
unlawfully with the intent to defraud sell, transfer, or convey the personal identifying information
of another person, to wit:
ANTHONY A.'S NAME ON RECORDED DOCUMENT NO.
20170956081, GRANT DEED FOR 5141 GENESTA.
COUNT 11
PROCURI G OR OFFERJNG FALSE OR FORGED IN TRUMENT (Re: Anthony A.)
On or about August 16, 2017, in the COUNTY of LOS ANGELES, the crime of
PROCURING OR OFFERING A FALSE OR FORGED INSTRUMENT in violation of Penal
Code section l l 5(a), a felony, was committed by TAMARA DADY AN, RICHARD A YV AZYAN,
ARTUR AYVAZYAN, ARTASHES MARTIROSYAN, GRIGOR TATOIAN, ESTEPHANIE
REYNOSO, and ROSA ZARA TE, who did unlawfully and knowingly procure or offer a false or
forged instrument to be filed, registered, or recorded in a public office in California, which
instrument, if genuine, might be filed, registered, or recorded under a w of California or the United
21
States, to wit:
RECORDED DOCUMENT NO. 2017.0 56081, ORA T DEED FOR 5141
22
GENESTA.
23
COUNT 12
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MORTGAGE FRAUD EXCEEDING $950: FILING
25
(Re: Anthony A.)
26
On or about August 16, 2017, in the COUNTY of LOS ANGELES, the crime of FILING A
27
FRAUDULENT DOCUMENT in violation of Penal Code section 532f(a)(4), a felony, was
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committed by TAMARA DADYAN, RICHARD AYVAZYAN, ARTUR AYVAZYAN,
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ARTASHES MARTIROSYAN, GRIGOR TATOIAN, ESTEPHANIE REYNOSO, and ROSA
2
ZARA TE, who did with the intent to defraud, file or cause to be filed with the recorder of any
3
county in connection with a mortgage loan transaction, a document with the knowledge the
4
document contains a deliberate misstatement, misrepresentation, or omission, to wit: RECORDED
5
DOCUMENT NO. 20170956081, GRANT DEED FOR 5141 GENESTA. It is further alleged that
6
the value of the fraud exceeds nine hundred fifty dollars ($950), within the meaning of Penal Code
7
section 532fG).
8
COUNT 13
9
PROCURING OR OFFERING F AL E OR FOR
TRUMENT {Re: John W.)
10
On or about October 7, 2019, in the COUNTY of LOS ANGELES, the crime of
11
PROCURING OR OFFERING A FALSE OR FORGED INSTRUMENT in violation of Penal
12
Code section 1 l 5(a), a felony, was committed by RICHARD A YVAZYAN, TAMARA DADY AN,
13
ARTUR AYVAZYAN, ARTASHES MARTIROSYAN, GRIGOR TATOIAN, ESTEPHANIE
14
REYNOSO, and ROSA ZARATE, who did unlawfully and knowingly procure or offer a false or
15
forged instrument to be filed, registered, or recorded in a public office in California, which
16
instrument, if genuine, might be filed, registered, or recorded under a law of California or the United
17
States, to wit: GRANT DEED, RECORDED DOCUMENT NO. 202001203 3.
18
COUNT 14
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CONSPIRACY TO COMMIT GRAND T
20
: Andrew A. Sarki B. & Savs Enter r
21
On or about and between January 31, 2014, and October 14, 2019, in the COUNTY of LOS
22
ANGELES, the crime of CONSPIRACY, in violation of Penal Code section 182(a)(l) a felony,
23
was committed by TAMARA DADYAN, RICHARD AYVAZYAN, ARTUR AYVAZYAN,
24
LILIT MALYAN, GRIGOR TATOIAN, ARTASHES MARTIROSYAN, ROSA ZARATE,
25
ESTEPHANIE REYNOSO, LUBIA CARRILLO, and VANESSA RAY BELL, who did willfully
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and unlawfully conspire together with another person or persons whose identity is known or
27
unknown to commit the crime of GRAND THEFT BY FALSE PRETENSES, 487(a), of the
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California Penal Code, a felony, pursuant to and for the purpose of carrying out the objects and
2
purposes of the aforesaid conspiracy, Defendants committed the following overt act(s):
3
OVERT ACT 1
4
On or about March 23, 2016, Tamara DADY AN and Estephanie REYNOSO created a Yahoo
5
email account using the name of Sarkis B. and the related business, SA VS Enterprise.
6
OVERT ACT2
7
On or about April 12, 2016, Vanessa BELL provided Evidence oflnsurance in Andrew A.'s
8
name for the property located at 3946 Knobhill Drive in Sherman Oaks.
9
OVERTACT3
10
On or about April 29, 2016, Tamara DADYAN emailed Grigor TATOIAN with the subject,
11
"Contractor that's licensed," and attached images of a Contractors State License Board (CSLB)
12
card in the name of "SAVS ENTERPRISES" as well as a business tax certificate for Sarkis B.,
13
SA VS Enterprises, and a driver's license in the name of Sarkis B.
14
OVERT ACT 4
15
On or about May 6, 2016, Tamara DADY AN used Andrew A.'s name to obtain $993,670.41
16
in proceeds from a Banc of California loan for the property located at 3946 Knobhill in Sherman
17
Oaks, California.
18
OVERT ACT 5
19
On or about July 25, 2016, Tamara DADYAN emailed Grigor TATOIAN a Fictitious
20
Business Name Statement (FBN) for "SA VS ENTERPRISE" that listed Andrew A. as the
21
registered owner.
22
OVERT ACT 6
23
On or about July 26, 2016, Grigor TATOIAN replied to DADYAN's email regarding the
24
"SA VS ENTERPRISE" FBN and asked, "Whats this? New account needed?" to which DADY AN
25
replied, "Yes."
26
II
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//
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//
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OVERT ACT 7
2
On or about July 29, 2016, Richard A YV AZYAN used a Bank of America account ending
3
in-6529, held in Andrew A.'s name "DBA SAYS ENTERPRISE", to obtain $218,597 from Ygrene
4
Energy Fund for purported improvements to his home at 5141 Genesta Avenue, Encino, California.
5
OVERT ACT 8
6
On or about August 1, 2016, Richard A YV AZY AN used the Bank of America account ending
7
in -6529 held in Andrew A. 's name to transfer $210,000 of the Y grene proceeds to a Bank of
8
America account ending in -6898 that he controlled in Vahan T.' s name.
9
OVERT ACT9
10
On or about September 16, 2016, Richard A YV AZYAN used the Bank of America account
11
ending in -6529 held in Andrew A.'s name to obtain $86,627 from Ygrene Energy Fund for
12
purported improvements to a property in Melanya A.'s name located at 6556 Andasol Avenue in
13
Van Nuys.
14
OVERT ACT 10
15
On or about September 19, 2016, Richard A YV AZYAN, Estephanie REYNOSO, and Rosa
16
ZARA TE used the Bank of America account ending in -6529 held in Andrew A.' s name to transfer
17
$40,000 to an account ending in -0865 held in the name of "Tammy DADY AN Investments."
18
OVERT ACT 11
19
On or about September 19, 2016, Richard A YVAZYAN, Estephanie REYNOSO, and Rosa
20
ZARA TE used the Bank of America account ending in -6529 held in Andrew A.' s name to transfer
21
$5,000 to a U.S. Bank account ending in -6086 held in Osbaldo V.'s name.
22
OVERT ACT 12
23
On or about September 19, 2016, Richard A YV AZYAN, Estephanie REYNOSO, and Rosa
24
ZARA TE used the Bank of America account ending in -6529 held in Andrew A.' s name to transfer
25
$5,050 to a Wells Fargo account ending in -3333 held in Andrew A.'s name.
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II
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II
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OVERT ACT 13
2
On or about September 19, 2016, Richard A YVAZYAN, Estephanie REYNOSO, and Rosa
3
ZARA TE used the Bank of America account ending in -6529 held in Andrew A.' s name to transfer
4
$36,100 to a Bank of America account ending in -3470 held in Andrew A.'s name.
5
OVERT ACT 14
6
On or about September 20, 2016, Richard A YV AZYAN, Estephanie REYNOSO, and Rosa
7
ZARA TE used the Bank of America account ending in -34 70 held in Andrew A.' s name to transfer
8
$20,434.23 to a Wells Fargo account ending in -1754 held in the name of"Secureline Realty and
9
Funding," Tamara DADYAN's business.
10
OVERTACT15
11
On or about September 28, 2016, Richard A YV AZYAN used the Bank of America account
12
ending in -6529 held in Andrew A.' s name to obtain $31,565 from Y grene Energy Fund for
13
purported improvements to a property in Suzanne B.'s name located at 4915 Bellaire Avenue in
14
Valley Village.
15
OVERTACT16
16
On or about September 30, 2016, Richard A YV AZY AN used Andrew A. 's name to privately
17
register the website domain "savsenterprise.com."
18
OVERT ACT 17
19
On or about October 3, 2016, Rosa ZARATE withdrew $500 from the Bank of America
20
account ending in -6529 held in Andrew A.'s name.
21
OVERT ACT 18
22
On or about October 4, 2016, Richard A YV AZY AN used the Bank of America account
23
ending in -6529 held in Andrew A.'s name to pay $1,091 for the rent of an office located at 5525
24
Oakdale Avenue in Woodland Hills.
25
OVERT ACT 19
26
On or about October 5, 2016, Richard A YV AZYAN used the Bank of America account
27
ending in -6529 held in Andrew A.'s name to obtain $91,035 from Ygrene Energy Fund for
28
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1
purported improvements to a property in Suzanne B.'s name located at 4915 Bellaire Avenue in
2
Valley Village.
3
OVERT ACT 20
4
On or about October 14, 2016, Richard A YV AZYAN used the Bank of America account
5
ending in -6529 held in Andrew A.'s name to obtain $63,200 from Ygrene Energy Fund for
6
purported improvements to a property in Grigor G.'s name located at 12607 Willard Street in North
7
Hollywood.
8
OVERT ACT 21
9
On or about October 18, 2016, Richard A YV AZY AN, Estephanie REYNOSO, and Rosa
10
ZARA TE used the Bank of America account ending in -6529 held in Andrew A.' s name to transfer
11
$6,300 to a Bank of America account ending in -8003 that he controlled in Andrew A.'s name.
12
OVERT ACT 22
13
On or about October 20, 2016, Richard AYVAZYAN, Estephanie REYNOSO, and Rosa
14
ZARATE used the Bank of America account ending in -6529 held in Andrew A.'s name to wire
15
$60,000 to a Bank of America account ending in -4312 that was held in Suzanne B.'s name.
16
OVERT ACT 23
17
On or about November 1, 2016, Richard A YV AZY AN used the Bank of America account
18
ending in -6529 held in Andrew A. 's name to obtain $69,880 from Y grene Energy Fund for
19
purported improvements to a property in Mykhailo D.'s name located at 1124 S. Normandie in Los
20
Angeles.
21
OVERT ACT 24
22
On or about November 14, 2016, Richard AYVAZYAN used the Bank of America account
23
ending in -6529 held in Andrew A. 's name to obtain $64,495 from Y grene Energy Fund for
24
purported improvements to a property in Grigor G.'s name located at 12607 Willard in North
25
Hollywood.
26
II
27
II
28
II
Page 13 of99
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1
OVERT ACT 25
2
On or about November 18, 2016, Richard A YV AZY AN used the Bank of America account
3
ending in -6529 held in Andrew A.'s name to obtain $82,395 from Ygrene Energy Fund for
4
purported improvements to a property in Peter R.'s name located at 17359 Victory in Van Nuys.
5
OVERT ACT 26
6
On or about November 22, 2016, Richard A YV AZY AN emailed Tamara DADY AN, using
7
Anthony A.'s name, with the subject, "TIN REQUEST," writing, "TAM, I FILLED OUT THE
8
FORM. WE JUST NEED TO FAX IT. I DON'T HA VE AF AX AT THE OFFICE. ALSO, I USED
9
THE LITHUANIA ADDRESS, MAKE SURE WE CAN STILL GET MAIL THERE."
10
A YV AZY AN attached an Employer Identification Number application in the name of Andrew A.
11
and SA VS Enterprise.
12
OVERT ACT 27
13
On or about November 23, 2016, Richard A YV AZYAN used the Bank of America account
14
ending in -6529 held in Andrew A.'s name to obtain $79,155 from Renew Funding for purported
15
improvements to a property in Peter R's name located at 17359 Victory in Van Nuys.
16
OVERT ACT 28
17
On or about November 28, 2016, Richard A YV AZY AN used the Bank of America account
18
ending in -6529 held in Andrew A.'s name to obtain $62,175 from Renew Funding for purported
19
improvements to a property in Anastasia A. 's name located at 15203 Leadwell in Van Nuys.
20
OVERT ACT 29
21
On or about November 30, 2016, Richard A YV AZYAN used the Bank of America account
22
ending in -6529 held in Andrew A.'s name to obtain $59,125 from Ygrene Energy Fund for
23
purported improvements to a property in Anastasia A.'s name located at 15203 Leadwell in Van
24
Nuys.
25
OVERT ACT 30
26
On or about December 12, 2016, Richard A YV AZY AN emailed Tamara DADY AN with the
27
subject, "Need Financials for Savs," writing "Send this to Razmik," listing "Savs Enterprise -
28
General Contractor," an address on Lithuania Drive in Granada Hills, and a phone number ending
Page 14 of99
Case 2:20-cr-00579-SVW Document 419-2 Filed 06/04/21 Page 15 of 100 Page ID
#:4407
1
in -0801. Richard A YV AZY AN also wrote, "Need to show Gross sales of $2,080,030 up to date.
2
Show about 15% net profit from the Gross."
3
OVERT ACT 31
4
On or about January 17, 2017, Richard A YV AZY AN emailed Tamara DADY AN with the
5
subject "SA VS Info for new account" and attached a Federal Employee Identification Number
6
(EIN) ending in -1495 for the business SAVS ENTERPRISE, as well as a Fictitious Business Name
7
Statement for SA VS ENTERPRISE filed and signed in Andrew A.' s name with the Los Angeles
8
County Clerk.
9
OVERT ACT 32
10
On or about January 17, 2017, Tamara DADY AN forwarded Richard A YV AZYAN's email
11
regarding "SAYS Info for new account" to Grigor TATOIAN.
12
OVERT ACT 33
13
On or about January 24, 2017, Richard A YV AZY AN used the U.S. Bank account ending in
14
-2662 held in Andrew A.'s name to obtain $119,145 from Renew Funding for purported
15
improvements to a property in Larisa K.' s name located at 13 546 Sarah Street in Sherman Oaks.
16
OVERT ACT 34
17
On or about January 25, 2017, Rosa ZARA TE deposited a $10,000 check from the U.S. Bank
18
account ending in -2662 held in Andrew A.' s name to a U.S. Bank account ending in -0458 held in
19
the name of Egia K.
20
OVERT ACT 35
21
On or about January 31, 2017, Richard A YV AZYAN used the U.S. Bank account ending in
22
-2662 held in Andrew A's name to obtain $134,275 from Renew Funding for purported
23
improvements to a property in Tetiana V.'s located at 4050 Camino de la Cumbre in Los Angeles.
24
OVERT ACT 36
25
On or about February 27, 2017, Richard A YV AZYAN used the U.S. Bank account ending
26
m -2662 held in Andrew A.'s name to obtain $88,550 from Renew Funding for purported
27
improvements to a property in Liudmy!a K.'s name located at 8400 Natalie Lane in West Hills.
28
//
Page 15 of99
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1
OVERT ACT 37
2
On or about March 7, 2017, Richard A YVAZYAN used the U.S. Bank account ending in -
3
2662 held in Andrew A.'s name to obtain $56,550 from Ygrene Energy Fund for purported
4
improvements to a property in Anna P.'s name located at 14808 Aztec Street in Sylmar.
5
OVERT ACT 38
6
On or about March 10, 2017, Richard A YV AZYAN used the U.S. Bank account ending in -
7
2662 held in Andrew A.'s name to obtain $60,000 from Ygrene Energy Fund for purported
8
improvements to a property in Susanna M.'s name located at 8937 Haskell Avenue in North Hills.
9
OVERT ACT 39
10
On or about March 10, 2017, Richard A YV AZYAN used the U.S. Bank account ending in -
11
2662 held in Andrew A. 's name to obtain $131,700 from Renew Funding for purported
12
improvements to a property in Fatima l's name located at 12334 Longacre Avenue in Granada
13
Hills.
14
OVERT ACT 40
15
On or about March 10, 2017, Richard AYVAZYAN, Estephanie REYNOSO, and Rosa
16
ZARA TE deposited a $37,500 check made to "Cash" from the U.S. Bank account ending in -2662
17
held in Andrew A.'s name to the Bank of America account ending in -6898 held in Vahan T.'s
18
name that Richard A YV AZY AN controlled.
19
OVERT ACT 41
20
On or about March 16, 2017, Richard AYVAZYAN, Estephanie REYNOSO, and Rosa
21
ZARATE deposited a $9,600 check made to "Cash" from the U.S. Bank account ending in -2662
22
held in Andrew A.'s name to the Bank of America account ending in -4999 held in Vahan T.'s
23
name that Richard A YV AZY AN controlled.
24
OVERT ACT 42
25
On or about March 17, 2017, Richard A YV AZYAN used the U.S. Bank account ending in -
26
2662 held in Andrew A.' s name to obtain $74,300 from Y grene Energy Fund for purported
27
improvements to a property in Liudmyla K.'s name located at 8400 Natalie Lane in West Hills.
28
//
Page 16 of99
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#:4409
I
OVERT ACT 43
2
On or about March 20, 2017, Richard A YV AZYAN used the U.S. Bank account ending in -
3
2662 held in Andrew A.'s name to obtain $70,150 from Renew Funding for purported
4
improvements to a property in Susanna M.'s name located at 8937 Haskell Avenue in North Hills.
5
OVERT ACT 44
6
On or about March 20, 2017, Rosa ZARA TE deposited a $66,870 check to "Cash" from the
7
U.S. Bank account ending in-2662 held in Andrew A.'s name to a Bank of America account ending
8
in -4408.
9
OVERT ACT 45
10
On or about March 22, 2017, Richard A YV AZY AN used the U.S. Bank account ending in -
11
2662 held in Andrew A.'s name to obtain $24,800 from Ygrene Energy Fund for purported
12
improvements to a property in Anthony A.'s name located at 22330 Victory Boulevard, No. 303,
13
in Woodland Hills.
14
OVERT ACT 46
15
On or about April 7, 2017, Richard A YV AZYAN used the U.S. Bank account ending in -
16
2662 held in Andrew A.'s name to obtain $21,900 from Renew Funding for purported
17
improvements to a property in Anthony A.'s name located at 22330 Victory Boulevard, No. 303,
18
in Woodland Hills.
19
OVERT ACT 47
20
On or about April 28, 2017, Richard A YV AZYAN used the U.S. Bank account ending in -
21
2662 held in Andrew A.'s name to obtain $103,600 from Renew Funding for purported
22
improvements to a property in Lilit MAL YAN's name located at 11633 Spy Glass in Northridge.
23
OVERT ACT48
24
On or about May 1, 2017, Richard A YV AZYAN used the U.S. Bank account ending in -
25
2662 held in Andrew A.'s name to obtain $43,260 from Renew Funding for purported
26
improvements to a property in Melanya A. 's name l?cated at 3520 Ridgeford in Westlake Village.
27
II
28
II
Page 17 of99
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#:4410
1
OVERT ACT 49
2
On or about May 3, 2017, Richard A YV AZYAN used the U.S. Bank account ending in -
3
2662 .held in Andrew A's name to obtain $72,600 from Renew Funding for purported
4
improvements to a property in Armen I.' s name located at 2080 Riverbirch Drive in Simi Valley.
5
OVERT ACT 50
6
On or about May 5, 2017, Richard A YV AZYAN used the U.S. Bank account ending in -
7
2662 held in Andrew A. 's name to obtain $68,000 from Y grene Energy Fund for purported
8
improvements to a property in Aram S.'s name located at 8112 Crosnoe Avenue in Panorama City.
9
OVERT ACT 51
10
On or about May 9, 2017, Richard AYVAZYAN used the U.S. Bank account ending in -
11
2662 held in Andrew A.'s name to obtain $81,360 from Renew Funding for purported
12
improvements to a property in Liudmyla K.'s name located at 2162 Rohner Avenue in Simi Valley.
13
OVERT ACT 52
14
On or about May 10, 2017, Richard A YV AZYAN used the U.S. Bank account ending in -
15
2662 held in Andrew A's name to obtain $113,625 from Ygrene Energy Fund for purported
16
improvements to a property located at 12334 Longacre Avenue in Granada Hills.
17
OVERT ACT 53
18
On or about May 19, 2017, Lubia CARRILLO accepted a $50,000 check issued from the
19
U.S. Bank account ending in -2662 held in Andrew A.'s name.
20
OVERT ACT 54
21
On or about May 25, 2017, Richard AYVAZYAN used the U.S. Bank account ending in -
22
2662 held in Andrew A's name to obtain $70,200 from Renew Funding for purported
23
improvements to a property located at 8112 Crosnoe Avenue in Panorama City.
24
OVERT ACT 55
25
On or about May 30, 2017, Richard AYVAZYAN used the U.S. Bank account ending in -
26
2662 held in Andrew A's name to obtain $100,940 from Renew Funding for purported
27
improvements to a property located at 3520 Fjdgeford in Westlake Village.
28
//
Page 18 of99
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#:4411
1
OVERT ACT 56
2
On or about June 13, 2017, Richard A YV AZY AN used the U.S. Bank account ending in -
3
2662 held in Andrew A.'s name to obtain $47,000 from Ygrene Energy Fund for purported
4
improvements to a property located at 15821 Kingsbury in Granada Hills.
5
OVERT ACT 57
6
On or about June 23, 2017, Richard A YV AZY AN used the U.S. Bank account ending in -
7
2662 held in Andrew A.'s name to obtain $115,000 from Ygrene Energy Fund for purported
8
improvements to a property located at 14212 Chandler Boulevard in Los Angeles.
9
OVERT ACT 58
10
On or about June 27, 2017, Richard AYVAZYAN used the U.S. Bank account ending in -
11
2662 held in Andrew A.'s name to obtain $53,500 from Renew Funding for purported
12
improvements to a property located at 15 821 Kingsbury Street in Granada Hills.
13
OVERT ACT 59
14
On or about June 28, 2017, Richard AYVAZYAN used the U.S. Bank account ending in -
15
2662 held in Andrew A.'s name to obtain $139,958 from Renew Funding for purported
16
improvements to his home located at 5141 Genesta A venue in Encino.
17
OVERT ACT 60
18
On or about July 3, 2017, Richard A YV AZYAN used the U.S. Bank account ending in -2662
19
held in Andrew A.' s name to obtain $78,960 from Renew Financial for purported improvements to
20
a property located at 14212 Chandler Boulevard in Los Angeles.
21
OVERT ACT pl
22
On or about August 2, 2017, Richard A YV AZY AN used a key to open the office located at
23
5525 Oakdale, and he, along with Rosa ZARA TE and Estephanie REYNOSO, entered the office.
24
OVERT ACT 62
25
On or about August 2, 2017, Rosa ZARA TE left the 5525 Oakdale office and drove to
26
17450 Weddington Street, Tamara DADYAN's residence.
27
II
28
//
Page 19 of99
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#:4412
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
OVERT ACT 63
On or about August 15, 2017, Richard A YV AZYAN used the U.S. Bank account ending in
-2662 held in Andrew A.'s name to obtain $73,200 from Ygrene Energy Fund for purported
improvements to a property located at 7106 Jellico A venue in Van Nuys.
OVERTACT64
On or about September 6, 2017, Richard A YV AZY AN used a U.S. Bank account ending in
-2287 held in Andrew A.'s name to obtain $86,400 from Ygrene Energy Fund for purported
improvements to a property located at 8150 Day Street in Sunland.
OVERT ACT65
On or about July 19, 2018, Tamara DADYAN stated under sworn testimony that Andrew
A. was a client.
OVERTACT66
On or about October 14, 2019, Grigor TATOIAN emailed a lease dated July 1, 2018, that
was purportedly signed by Andrew A. as the landlord of 1603 New York Drive in Altadena.
COUNT 15
GRAND THEFT (Re: Andrew A,)
On or about and between March 22, 2017, and May 3, 2017, in
ANGELES and VENTURA, the crime of GRAND THEFT in violation of Penal Code section
487(a), a felony, was committed by TAMARA DADY AN, RICHARD A YV AZYAN, ARTUR
AYVAZYAN, LILIT MALYAN, GRIGOR TATOIAN, ROSA ZARATE, ESTEPHANIE
REYNOSO, LUBIA CARRILLO, and VANESSA RAY BELL, who did knowingly and
designedly, by a false or fraudulent representation or pretense, obtain money, labor or real and
personal property by fraud from RENEW FUNDING, SPECIFICALLY, $72,600 FOR 2080
RIVERBIRCH, which had a value exceeding nine hundred fifty dolla~
COUNT16
c#
GRAND THEFT (Re: Andrew A.)
On or about and between March 14, 2017, and May 5, 2017, in the COUNTY of LOS
ANGELES, the crime of GRAND THEFT in violation of Penal Code section 487(a), a felony, was
Page 20 of99
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#:4413
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
committed by TAMARA DADYAN, RICHARD AYVAZYAN, ARTUR AYVAZYAN, LILIT
MALY AN, GRIGOR TATOIAN, ROSA ZARA TE, ESTEPHANIE REYNOSO, LUBIA
CARRILLO, and VANESSA RAY BELL, who did knowingly and designedly, by a false or
fraudulent representation or pretense, obtain money by fraud from YGRENE ENERGY FUND,
SPECIFICALLY, $68,000 FOR 8112 CROSNOE, which had a value exceeding nine hundred fifty
dollars ($950).
~
COUNT 17
'1)
UNLAWFUL TRANSFER OF IDENTIFYING I
TION (Re: Sa rid B.)
On or about May 4, 2017, in the COUNTIES of LOS ANGELES and VENTURA, the crime
of IDENTITY THEFT in violation of Penal Code section 530.5(d)(l), a felony, was committed by
TAMARA DADYAN, RICHARD AYVAZYAN, ARTUR AYVAZYAN, LILIT MALYAN,
GRIGOR TATOIAN, ROSA ZARATE, ESTEPHANIE REYNOSO, LUBIA CARRILLO, and
VANES SA RAY BELL, who did willfully and unlawfully with the intent to defraud sell, transfer,
or convey the personal identifying information of another person, to wit: SARKIS B.'S NAME
ON A RENEW FUNDING COMPLETION CERTIFICATE FOR 2162 R
COUNT18
GRAND THEFT Re: Andrew A.
On or about and between March 21, 2017, and May 9, 2017, in the COUNTIES of LOS
ANGELES and VENTURA, the crime of GRAND THEFT in violation of Penal Code section
487(a), a felony, was committed by TAMARA DADYAN, RICHARD AYVAZYAN, ARTUR
AYVAZYAN, LILIT MALYAN, GRIGOR TATOIAN, ROSA ZARATE, ESTEPHANIE
REYNOSO, LUBIA CARRILLO, and VANESSA RAY BELL, who did knowingly and
designedly, by a false or fraudulent representation or pretense, obtain money by fraud from
RENEW FUNDING, SPECIFICALLY, $81,360, FOR 2162 ROHNER, which had a value
exceeding nine hundred fifty dollars ($950).
II
II
II
Page 21 of99
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#:4414
1
COUNT 19
2
UNLAWFUL TRAN FER OF IDENTIFYING INFORMATION {Re: Sarkis B.)
3
On or about May 8, 2017, in the COUNTY of LOS ANGELES, the crime of.IDENTITY
4
THEFT in violation of Penal Code section 530.S(d)(l), a felony, was committed by TAMARA
5
DADYAN, RICHARD AYVAZYAN, ARTUR AYVAZYAN, LILIT MALYAN, GRIGOR
6
TATOIAN, ROSA ZARATE, £STEPHANIE REYNOSO, LUBIA CARRILLO, and VANESSA
7
RAY BELL, who did willfully and unlawfully with the intent to defraud sell, transfer, or convey
8
the personal identifying information of another person, to wit: SARKIS B.'S NAME FOR A
9
YGRENE ENERGY FUND COMPLETION CERTIFICATE FOR 123 ,
GACRE.
10
11
GRAND THEFT
12
On or about and between March 24, 2017, and May 10, 2017, in the COUNTY of LOS
13
ANGELES, the crime of GRAND THEFT in violation of Penal Code section 487(a), a felony, was
14
committed by TAMARA DADYAN, RICHARD AYVAZYAN, ARTUR AYVAZYAN, LILIT
15
MALYAN, GRIGOR TATOIAN, ROSA ZARATE, £STEPHANIE REYNOSO, LUBIA
16
CARRILLO, and VANES SA RAY BELL, who did knowingly and designedly, by a false or
17
fraudulent representation or pretense, obtain money, labor or real and personal property by fraud
18
from YGRENE ENERGY FUND, SPECIFICALLY, $113,625, FOR
334 LONGACRE, which
19
had a value exceeding nine hundred fifty dollars ($950).
20
COUNT21
21
UNLAWFUL TRANSFER OF IDENTIFYING INFOR
B.)
22
On or about May 23, 2017, in the COUNTY of LOS ANGELES, the crime of IDENTITY
23
THEFT in violation of Penal Code section 530.5(d)(l), a felony, was committed by TAMARA
24
DADYAN, RICHARD AYVAZYAN, ARTUR AYVAZYAN, LILIT MALYAN, GRIGOR
25
TATOIAN, ROSA ZARATE, ESTEPHANIE REYNOSO, LUBIA CARRILLO, and VANESSA
26
RAY BELL, who did willfully and unlawfully with the intent to defraud sell, transfer, or convey
27
the personal identifying information of another person, to wit: SARKIS B.' S NAME FOR A
28
RENEW FUNDING COMPLETION CERTIFICATE FOR 8112 CROSNOE.
Page 22 of99
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#:4415
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
COUNT22
$
GRAND THEFT ffie: Andrew A.V
On or about and between April 13, 2017, and May 25, 2017, in the COUNTY of LOS
ANGELES, the crime of GRAND THEFT in violation of Penal Code section 487(a), a felony, was
committed by TAMARA DADYAN, RICHARD AYVAZYAN, ARTUR AYVAZYAN, LILIT
MAL YAN, GRlGOR TATOIAN, ROSA ZARATE, ESTEPHANIE REYNOSO, LUBIA
CARRILLO, and VANESSA RAY BELL, who did knowingly and designedly, by a false or
fraudulent representation or pretense, obtain money, labor or real and personal property by fraud
from RENEW FUNDING, SPECIFICALLY, $70,200, FOR 8112 CROSNOE, which had a value
exceeding nine hundred fifty dollars ($950).
COUNT23
MO
On or about and between May 2, 2017, and May 25, 2017, in the COUNTY of LOS
ANGELES, the crime of MONEY LAUNDERING in violation of Penal Code section 186.lO(a), a
felony, was committed by TAMARA DADYAN, RICHARD AYVAZYAN, ARTUR
AYVAZYAN, LILIT MALYAN, GRlGOR TATOIAN, ROSA ZARATE, ESTEPHANIE
REYNOSO, LUBIA CARRILLO, and VANESSA RAY BELL, who did unlawfully conduct
transactions involving monetary instruments of a value exceeding $25,000, through a financial
institution knowing that the monetary instruments represented the proceeds of, and was derived
directly or indirectly from the proceeds of, criminal activity, to wit:
$276,862.22 TOTAL
THROUGH AT LEAST 13 TRANSACTIONS, AS DETAILED IN THE TABLE BELOW. It is
further alleged, pursuant to Penal Code section 186.1 0(c )(l)(B), that the value of the transaction or
transactions exceeds one hundred fifty thousand dollars ($150,000) but is less than one million
dollars ($1,000,000).
DATE
AMOUNT TRANSACTION
5/2/17
$20,000
U.S. Bank-2662 check to U.S. Bank -9086
5/2/17
$32,000
U.S. Bank -2662 check to Bank of America -6898
Page 23 of99
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#:4416
1
2
3
4
5
6
7
8
9
10
11
12
13
5/4/17
$10,000
5/5/17
$16,282.22
5/7/17
$6,500
5/11/17
$18,000
5/11/17
$1 ,400
5/17/17
$11,000
5/17/17
$40,680
5/17/17
$50,000
5/19/17
$60,000
5/19/17
$2,000
5/22/17
$9,000
U.S. Bank -2662 check to Bank of America -0440
U.S. Bank -2662 payment to White Glass Lending
U.S . Bank -2662 check to Bank of America -4999
U.S. Bank -2662 check to Bank of America -9473
U.S. Bank-2662 check to U.S. Bank -9649
U.S. Bank -2662 check to Bank of America -0440
U.S. Bank -2662 check to U.S. Bank -2961
U.S. Bank -2662 check to Matadors Community Credit Union -7500
U.S. Bank -2662 check to Bank of America -6898
U.S. Bank-2662 check to Wells Fargo -7847
U.S. Bank -2662 check to Bank of America -0559
COUNT24 @
14
UNLAWFUL TRANSFER OF IDENTIFYING INFORMATION (Re: arl<ls B.)
15
On or about May 23, 2017, in the COUNTY of LOS ANGELES, the crime ofIDENTITY
16
THEFT in violation of Penal Code section 530.5(d)(l), a felony, was committed by TAMARA
17
DADYAN, RICHARD AYVAZYAN, ARTUR AYVAZYAN, LILIT MALYAN, GRIGOR
18
TATOIAN, ROSA ZARATE, ESTEPHANIE REYNOSO, LUBIA CARRILLO, and VANESSA
19
RAY BELL, who did willfully and unlawfully with the intent to defraud sell, transfer, or convey
20
the personal identifying information of another person, to wit:
21
RENEW FUNDING COMPLETION CERTIFICATE FOR 3"1,iii::--~
ORD.
22
COUNT 25
23
~G~RA=N..:.a:Da:......:.T.:aaHE==<=F--=T~.:=....=.:::.:..:=-
24
On or about and between March 2, 2017 and May 30, 2017, in the COUNTY of LOS
25
ANGELES, the crime of GRAND THEFT in violation of Penal Code section 487(a), a felony, was
26
committed by TAMARA DADYAN, RICHARD AYVAZYAN, ARTUR AYVAZYAN, LILIT
27
l\.A~LYAN, GRIGOR TATOIAN, ROSA ZARATE, ESTEPHANIE REYNOSO, LUBIA
28
CARRILLO, and VANESSA RAY BELL, who did knowingly and designedly, by a false or
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1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
fraudulent representation or pretense, obtain money, labor or real and personal property by fraud
from RENEW FUNDING, SPECIFICALLY, $144,200, FOR 3520 RIDGEFORD, which had a
value exceeding nine hundred fifty dollars ($950).
@
COUNT26
MONEY LAUNDERING (Re: Andrew A.)
On or about and between May 30, 2017, and June 27, 2017, in the COUNTY of LOS
ANGELES, the crime of MONEY LAUNDERING in violation of Penal Code section 186.l0(a), a
felony, was committed by TAMARA DADYAN, RICHARD AYVAZYAN, ARTUR
AYVAZYAN, LILIT MALYAN, GRIGOR TATOIAN, ROSA ZARATE, ESTEPHANIE
REYNOSO, LUBIA CARRILLO, and VANESSA RAY BELL, who did unlawfully conduct
transactions involving monetary instruments of a value exceeding $25,000, through a financial
institution knowing that the monetary instruments represented the proceeds of, and was derived
directly or indirectly from the proceeds of, criminal activity, to wit: $185,560 TOTAL THROUGH
AT LEAST FIVE TRANSACTIONS AS DETAILED IN THE TABLE BELOW. It is further
alleged, pursuant to Penal Code section 186.10( c )(1 )(B), that the value of the transaction or
transactions exceeds one hundred fifty thousand dollars ($150,000) but is less than one million
dollars ($1,000,000).
DATE
AMOUNT TRANSACTION
6/1/17
$76,000
U.S. Bank -2662 check to Bank of America -5068
6/1/17
$9,500
U.S. Bank -2662 check to Bank of America -4999
6/1/17
$50,000
U.S. Bank -2662 check to Bank of America -6898
6/13/17
$4,500
U.S. Bank -2662 payment to Bank of America -9473
6/23/17
$45,560
U.S. Bank-2662 check to Bank of America -4999
COUNT27
,C1
UNLAWFUL TRANSFER OF IDENTIFYING INFORMATION < ~~: iarkis B.)
._/
On or about June 20, 2017, in the COUNTY of LOS ANGELES, the crime oflDENTITY
THEFT in violation of Penal Code section 530.S(d)(l), a felony, was committed by TAMARA
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1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
DADYAN, RICHARD AYVAZYAN, ARTUR AYVAZYAN, LILIT MALYAN, GRIGOR
TATOIAN, ROSA ZARATE, ESTEPHANIE REYNOSO, LUBIA CARRILLO, and VANESSA
RAY BELL, who did willfully and unlawfully with the intent to defraud sell, transfer, or convey
the personal identifying information of another person, to wit: SARKIS B.' S NAME FOR A
YGRENE ENERGY FUND COMPLETION CERTIFICATE FOR 14212 CHANDLER.
@)
COUNT 28
GRAND THEFT (Re: Andrew A.)
On or about and between May 15, 2017, and June 23, 2017, in the COUNTY of LOS
ANGELES, the crime of GRAND THEFT in violation of Penal Code section 487(a), a felony, was
committed by TAMARA DADYAN, RICHARD AYVAZYAN, ARTUR AYVAZYAN, LILIT
MALYAN, GRlGOR TATOIAN, ROSA ZARATE, ESTEPHANIE REYNOSO, LUBIA
CARRILLO, and VANES SA RAY BELL, who did knowingly and designedly, by a false or
fraudulent representation or pretense, obtain money by fraud from YGRENE ENERGY FUND,
SPECIFICALLY, $115,000, FOR 14212 CHANDLER, which had a value exceeding nine hundred
fifty dollars ($950).
~
COUNT29
V
U LAWFUL TRANSFER OF IDENTIFYING INFORMATION (Re: Sarkis B.)
On or about June 8, 2017, in the COUNTY of LOS ANGELES, the crime of IDENTITY
THEFT in violation of Penal Code section 530.5(d)(l), a felony, was committed by TAMARA
DADY AN, RICHARD A YV AZ YAN, ARTUR A YV AZY AN, LILIT MAL YAN, GRIGOR
TATOIAN, ROSA ZARATE, ESTEPHANIE REYNOSO, LUBIA CARRILLO, and VANESSA
RAY BELL, who did willfully and unlawfully with the intent to defraud sell, transfer, or convey
the personal identifying information of another person, to wit: SARKIS B. 'S NAME FOR A
YGRENE ENERGY FUND COMPLETION CERTIFICATE FOR 15821 KINGSBURY.
COUNT 30
GRAND THEFT (Re: Andrew A.)
On or about and between May 8, 2017, and June 13, 2017, in tli
ANGELES, the crime of GRAND THEFT in violation of Penal Code section 487(a), a felony, was
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1
2
3
4
, 5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
committed by TAMARA DADYAN, RICHARD AYVAZYAN, ARTUR AYVAZYAN, LILIT
MALYAN, GRIGOR TATOIAN, ROSA ZARATE, ESTEPHANIE REYNOSO, LUBIA
CARRILLO, and VANESSA RAY BELL, who did knowingly and designedly, by a false or
fraudulent representation or pretense, obtain money, labor or real and personal property by fraud
from YGRENE ENERGY FUND, SPECIFICALLY, $47,000, FOR 15821 KINGSBURY, which
had a value exceeding nine hundred fifty dollars ($950).
~
COUNT31
~
UNLAWFUL TRANSFER OF IDENTIFYING INFORMATION (Re: Sarkis B.)
On or about June 23, 2017, in the COUNTY of LOS ANGELES, the crime of IDENTITY
THEFT in violation of Penal Code section 530.5(d)(l), a felony, was committed by TAMARA
DADYAN, RICHARD AYVAZYAN, ARTUR AYVAZYAN, LILIT MALYAN, GRIGOR
TATOIAN, ROSA ZARATE, ESTEPHANIE REYNOSO, LUBIA CARRILLO, and VANESSA
RAY BELL, who did willfully and unlawfully with the intent to defraud sell, transfer, or convey
the personal identifying information of another person, to wit: SARKIS B.'S NAME FOR A
RENEW FUNDING COMPLETION CERTIFICATE FOR 5141 GENESTA.
COUNT 32
GRAND THEFT (Re: Andrew A.)
On or about and between January 26, 2017, and June 28, 2017, in the COUNTY of LOS
ANGELES, the crime of GRAND THEFT in violation of Penal Code section 487(a), a felony, was
committed by TAMARA DADYAN, RICHARD AYVAZYAN, ARTUR AYVAZYAN, LILIT
MAL YAN, GRIGOR TATOIAN, ROSA ZARATE, ESTEPHANIE REYNOSO, LUBIA
CARRILLO, and VANESSA RAY BELL, who did knowingly and designedly, by a false or
fraudulent representation or pretense, obtain money, labor or real and personal property by fraud
from RENEW FUNDING, SPECIFICALLY, $139,958, FOR 5141 GENESTA, which had a value
exceeding nine hundred fifty dollars ($950).
II
II
II
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1
COUNT 33
2
MONEY LAUNDERING
3
On or about and between June 28, 2017, and July 24, 2017, in the COUNTY of LOS
4
ANGELES, the crime of MONEY LAUNDERJNG in violation of Penal Code section 186.l0(a), a
5
felony, was committed by TAMARA DADYAN, RICHARD AYVAZYAN, ARTUR
6
AYVAZYAN, LILIT MALYAN, GRlGOR TATOIAN, ROSA ZARATE, ESTEPHANIE
7
REYNOSO, LUBIA CARRILLO, and VANESSA RAY BELL, who did unlawfully conduct
8
transactions involving monetary instruments of a value exceeding $25,000, through a financial
9
institution knowing that the monetary instruments represented the proceeds of, and was derived
10
directly or indirectly from the proceeds of, criminal activity, to wit: $165,900 TOTAL THROUGH
11
AT LEAST EIGHT TRANSACTIONS AS DETAILED IN THE TABLE BELOW. It is further
12
alleged, pursuant to Penal Code section 186.10( c )(1 )(B), that the value of the transaction or
13
transactions exceeds one hundred fifty thousand dollars ($150,000) but is less than one million
14
dollars ($1,000,000).
15
16
17
18
19
20
21
22
23
24
25
DATE
6/30/17
7/1/17
7/3/17
7/5/17
7/10/17
7/21/17
7/24/17
7/24/17
AMOUNT
$44,000
$20,000
$26,000
$1,200
$48,700
$1,000
$5,000
$20,000
TRANSACTION
U.S. Bank -2662 check to Bank of America -6898
U.S. Bank -2662 check to Bank of America -9473
U.S. Bank -2662 check to Bank of America -6898
U.S. Bank -2662 check to Bank of America -6898
U.S. Bank -2662 check to Bank of America -9418
U.S. Bank -2662 check to Bank of America -6898
U.S. Bank -2662 check to Bank of America -4999
U.S. Bank -2662 check to Bank of Ameri~,
COUNT 34
@)
26
UNLAWFUL TRANSFER OF IDENTIFYING INFORMATION (Re: arkjs B.)
27
On or about August 15, 2017, in the COUNTY of LOS ANGELES, the crime ofIDENTITY
28
THEFT in violation of Penal Code section 530.5(d)(l), a felony, was committed by TAMARA
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#:4421
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
DADYAN, RICHARD AYVAZYAN, ARTUR AYVAZYAN, LILIT MALYAN, GRIGOR
TATOIAN, ROSA ZARATE, ESTEPHANIE REYNOSO, LUBIA CARRILLO, and VANESSA
RAY BELL, who did willfully and unlawfully with the intent to defraud sell, transfer, or convey
the personal identifying information of another person, to wit: SARKJS B.'S NAME FOR A
YGRENE ENERGY FUND COMPLETION CERTIFICATE FOR 7106 JELLICO.
COUNT35
@
(I/
GRAND THEFT (Re: Andrew A.)
On or about and between July 25, 2017, and August 15, 2017, in the COUNTY of LOS
ANGELES, the crime of GRAND THEFT in violation of Penal Code section 487(a), a felony, was
committed by TAMARA DADYAN, RICHARD AYVAZYAN, ARTUR AYVAZYAN, LILIT
MALYAN, GRIGOR TATOIAN, ROSA ZARATE, ESTEPHANIE REYNOSO, LUBIA
CARRILLO, and VANESSA RAY BELL, who did knowingly and designedly, by a false or
fraudulent representation or pretense, obtain money, labor or real and personal property by fraud
from YGRENE ENERGY FUND, SPECIFICALLY, $73,200, FOR 7106 JELLICO, which had a
value exceeding nine hundred fifty dollars ($950).
COUNT 36
MONEY LAUNDERING Re: Andrew A.
On or about and between August 1, 2017, and August 16, 2017, in the COUNTY of LOS
ANGELES, the crime of MONEY LAUNDERING in violation of Penal Code section 186.lO(a), a
felony, was committed by TAMARA DADYAN, RICHARD AYVAZYAN, ARTUR
AYVAZYAN, LILIT MALYAN, GRIGOR TATOIAN, ROSA ZARATE, ESTEPHANIE
REYNOSO, LUBIA CARRILLO, and VANES SA RAY BELL, who did unlawfully conduct
transactions involving monetary instruments of a value exceeding $25,000, through a financial
institution knowing that the monetary instruments represented the proceeds of, and was derived
directly or indirectly from the proceeds of, criminal activity, to wit: $80,000 TOTAL THROUGH
AT LEAST FOUR TRANSACTIONS AS DETAILED IN THE TABLE BELOW. It is further
alleged, pursuant to Penal Code section 186.I0(c)(l)(A), that the value of the transaction or
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1
transactions exceeds fifty thousand dollars ($50,000) but is less than one hundred fifty thousand
2
dollars ($150,000).
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
DATE
AMOUNT TRANSACTION
8/1/17
$20,000
U.S. Bank -2662 check to Bank of America -6898
8/15/17
$10,000
U.S. Bank -2662 check to Bank of America -4999
8/15/17
$30,000
U.S. Bank -2662 check to Bank of America -6898
8/16/17
$20,000
U.S. Bank-2662 check to Bank of America -9473
COUNT 37
~
UNLAWFUL TRANSFER OF IDENTIFYING INFORMATION (Re: Sarkis B.)
On or about August 29, 2017, in the COUNTY of LOS ANGELES, the crime ofIDENTITY
THEFT in violation of Penal Code section 530.5(d)(l), a felony, was committed by TAMARA
DADYAN, RICHARD AYVAZYAN, ARTUR AYVAZYAN, LILIT MALYAN, GRlGOR
TATOIAN, ROSA ZARATE, ESTEPHANIE REYNOSO, LUBIA CARRILLO, and VANESSA
RAY BELL, who did willfully and unlawfully with the intent to defraud sell, transfer, or convey
the personal identifying information of another person, to wit: SARKIS B.'S NAME FOR A
YGRENE ENERGY FUND COMPLETION CERTIFICATE FOR 8150. LJW<r"I~
COUNT 38
GRAND THEFT (Re: Andrew A.)
On or about and between August 7, 2017, and September 6, 2017, in the COUNTY of LOS
ANGELES, the crime of GRAND THEFT in violation of Penal Code section 487(a), a felony, was
committed by TAMARA DADYAN, RICHARD AYVAZYAN, ARTUR AYVAZYAN, LILIT
MALYAN, GRIGOR TATOIAN, ROSA ZARATE, ESTEPHANIE REYNOSO, LUBIA
CARRILLO, and VANESSA RAY BELL, who did knowingly and designedly, by a false or
fraudulent representation or pretense, obtain money, labor or real and personal property by fraud
from YGRENE ENERGY FUND, SPECIFICALLY, $86,400, FOR 8150 DAY, which had a value
exceeding nine hundred fifty dollars ($950).
II
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1
COUNT39
2
CONSPIRACY TO COMMIT GRAND THE
3
On or about and between June 16, 2015, and February 4, 2020, in the COUNTY of LOS
4
ANGELES, the crime of CONSPIRACY, in violation of Penal Code section l 82(a)(l) a felony,
5
was committed by TAMARA DADYAN, RICHARD AYVAZYAN, ARTUR AYVAZYAN,
6
LILIT
MALYAN,
ARTASHES
MARTIROSYAN,
GRIGOR
TATOIAN,
ARSHAK
7
BARTOUMIAN, ROSA ZARA TE, ESTEPHANIE REYNOSO, and VANESSA RAY BELL, who
8
did willfully and unlawfully conspire together with another person or persons whose identity is
9
known or unknown to commit the crime of GRAND THEFT BY FALSE PRETENSES, 487(a), of
10
the California Penal Code, a felony, pursuant to and for the purpose of carrying out the objects and
11
purposes of the aforesaid conspiracy, Defendants committed the following overt act(s):
12
OVERT ACT 1
13
On or about June 16, 2015, Richard AYVAZYAN, Rosa ZARATE, and ESTEPHANIE
14
REYNOSO, created a Yahoo email address with the user name "lkdesign15" using the name of
15
"Liudmyla K."
16
OVERT ACT 2
17
On or about August 31, 2015, Tamara DADY AN created a Residential Purchase Agreement
18
using Liudmyla K.' s name for the property located at 2162 Rohner A venue in Simi Valley.
19
OVERT ACT 3
20
On or about October 9, 2015, Vanessa BELL created an Evidence of Insurance document
21
using the name of Liudmyla K. for the property located 2162 Rohner A venue in Simi Valley.
22
OVERT ACT 4
23
On or about October 16, 2015, Tamara DADYAN used Liudmyla K's name to obtain a
24
$535,128 loan from the Banc of California for the property located 2162 Rohner Avenue in Simi
25
Valley.
26
II
27
II
28
II
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1
OVERT ACT 5
2
On or about October 20, 2016, Tamara DADYAN used Liudmyla K.'s name on a Deed of
3
Trust for a $635,500 loan from the Banc of California for the property located at 11633 Spy Glass
4
Drive in Northridge.
5
OVERT ACT6
6
On or about October 21, 2016, Tamara DADY AN emailed Richard A YV AZY AN images of
7
a driver's license and social security card in Liudmyla K.'s name.
8
OVERTACT7
9
On or about November 1, 2016, Rosa ZARA TE deposited $6,451.92 and withdrew $900 via
10
ATM from a U.S. Bank account ending in -6908 in the name ofLiudmyla K.
11
OVERT ACT 8
12
On or about November 28, 2016, Tamara DADY AN emailed Lilit MALY AN documents for
13
the $653,500 loan from the Banc of California for the property located at 11633 Spy Glass Drive
14
in Northridge, in the name of Liudmyla K., and stated, "Keep this docs payment due your house
15
dee 1 remind me."
16
OVERT ACT 9
17
On or about December 14, 2016, Tamara DADY AN used Liudmyla K.'s name on a Deed of
18
Trust for a $604,000 loan from the Banc of California for the property located at 8400 Natalie Lane
19
inWestHills.
20
OVERT ACT 10
21
On or about December 29, 2016, Tamara DADY AN used Liudmyla K.'s name to open a U.S.
22
Bank account ending in -2506, doing business as "Canon Builders."
23
OVERT ACT 11
24
On or about January 12, 2017, Tamara DADYAN emailed Richard AYVAZYAN a credit
25
report in Liudmyla K.'s name linked to 11633 Spy Glass Drive in Northridge, California.
26
OVERT ACT 12
27
On or about January 20, 2017, Tamara DADY AN used Liudmyla K.'s name on a Grant Deed
28
transferring the property at 11633 Spy Glass Drive in Northridge to Lilit MALY AN.
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1
OVERT ACT 13
2
On or about February 9, 2017, Richard A YV AZYAN, Estephanie REYNOSO, and ROSA
3
ZARATE submitted a Ygrene Energy Fund completion certificate in the name ofLiudmyla K. and
4
Aida M., in the amount of $74,300, for 8400 Natalie Lane in West Hills.
5
OVERT ACT 14
6
On or about February 17, 2017, Richard A YV AZYAN, Estephanie REYNOSO, and ROSA
7
ZARATE submitted a Renew Funding completion certificate in the name ofLiudmyla K. and Aida
8
M., in the amount of $88,550, for 8400 Natalie Lane in West Hills.
9
OVERT ACT 15
10
On or about March 14, 2017, Artur A YV AZYAN filed a bankruptcy petition in Liudmyla
11
K.'s name in the Central District of California in Case No. 17-10641-MT.
12
OVERT ACT 16
13
On or about May 4, 2017, Richard A YV AZY AN, Estephanie REYNOSO, and ROSA
14
ZARATE submitted a Renew Funding completion certificate in the name of Liudmyla K., in the
15
amount of $81,360, for 2162 Rohner Avenue in Simi Valley.
16
OVERT ACT 17
17
On or about September 3, 2017, Tamara DADY AN emailed Richard A YV AZY AN with the
18
subject, "Roghner sold grant deed if u need to send to cal first," and attached a Grant Deed
19
transferring the property at 2162 Rohner A venue in Simi Valley from Liudmy la K. to Naira A.
20
OVERT ACT 18
21
On or about October 10, 2017, Arshak BARTOUMIAN emailed Tamara DADY AN with the
22
subject, "BK WAS DISMISSED ON THE CASE MA TEO I GUESS SO THAT MAY BE THE
23
PROBLEM WE NEED A NEW ONE CARLOS IS A BK WE HA VE BUT THIS PROPERTY
24
NOT IN IT," and attached a faxed document regarding bankruptcies filed in the names ofLiudmyla
25
K. and Mateo J.
26
II
27
II
28
II
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1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
OVERT ACT 19
On or about July 24, 2018, Tamara DADY AN emailed Romana Cias with the subject "Sign
copy for [Liudmyla K.] sign the package u got in the mail they keep calling from the mortgage they
need that back" and attached an image of a handwritten signature.
OVERTACT20
On or about January 25, 2019, Tamara DADYAN emailed Lilit MALY AN and wrote, "I
send another email for a bofa girl can you email her this tell her to open business ace for canon
builders," attaching the Fictitious Business Name Statement for Canon Builders that was filed in
Liudmyla K.'s name.
@
COUNT40
Iv
UNLAWFUL TRANSFER OF IDENTIFYING INFO
TION (Re: Liudmyla K.)
On or about May 4, 2017, in the COUNTY of LOS ANGELES, the crime of IDENTITY
THEFT in violation of Penal Code section 530.5(d)(l), a felony, was committed by TAMARA
DADYAN, RICHARD AYVAZYAN, ARTUR AYVAZYAN, LILIT MALYAN, ARTASHES
MARTIROSYAN, GRIGOR TATOIAN, ROSA ZARATE, ESTEPHANIE REYNOSO, LUBIA
CARRILLO, and VANES SA RAY BELL, who did willfully and unlawfully with the intent to
defraud sell, transfer, or convey the personal identifying information of another person, to wit:
LIUDMYLA K.' S NAME ON A RENEW FUNDING COMPLb1.F1~
ROHNER IN SIMI VALLEY.
COUNT41
UNLAWFUL TRANSFER OF IDENTIFYING INFORMATION
(Re: Liudmvla K. & Erwin N.)
On or about September 3, 2017, in the COUNTY of LOS ANGELES, the cnme of
IDENTITY THEFT in violation of Penal Code section 530.5(d)(l), a felony, was committed by
TAMARA DADYAN, RICHARD AYVAZYAN, ARTUR AYVAZYAN, LILIT MALYAN,
ARTASHES MARTIROSYAN, GRIGOR TATOIAN, ROSA ZARATE, ESTEPHANIE
REYNOSO, and V Al\TESSA RAY BELL, who did willfully and unlawfully with the intent to
defraud sell, transfer, or convey the personal identifying information of another person, to wit:
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1
LIUDMYLA K.'S NAME, AND ERWIN N.'S NAME AND NOTARY STAMP ON A GRANT
2
DEED FOR 2162 ROHNER A VENUE IN SIMI VALLEY FRO
3
A.
4
COUNT42
5
6
(Re: Liudmyla K. & Roy D.)
7
On or about February 4, 2020, in the COUNTY of LOS ANGELES, the crime ofIDENTITY
8
THEFT in violation of Penal Code section 530.5(d)(l), a felony, was committed by TAMARA
9
DADYAN, RICHARD AYVAZYAN, ARTUR AYVAZYAN, LILIT MAL YAN, ARTASHES
10
MARTIROSYAN, GRIGOR TATOIAN, ARSHAK BARTOUMIAN, ROSA ZARATE,
11
ESTEPHANIE REYNOSO, and VANESSA RAY BELL, who did willfully and unlawfully with
12
the intent to defraud sell, transfer, or convey the personal identifying information of another person,
13
to wit: LIUDMYLA K.'S NAME AND ROY D.'S NAME ON LOS ANGELES COUNTY
14
RECORDED DOCUMENT NO. 20200139370.
15
COUNT 43
16
FORGERY RELATING TO IDENTITY THEFT (Re: Roy D.)
17
On or about February 4, 2020, in the COUNTY of LOS ANGELES, the crime of FORGERY
18
in violation of Penal Code section 470(b), a felony, was committed by TAMARA DADYAN,
19
RICHARD
AYVAZYAN,
ARTUR
AYVAZYAN,
LILIT
MALYAN,
ARTASHES
20
MARTIROSYAN, GRIGOR TATOIAN, ARSHAK BARTOUMIAN, ROSA ZARATE,
21
ESTEPHANIE REYNOSO, and VANESSA RAY BELL, who with the intent to defraud,
22
counterfeited and/or forged the seal or handwriting of another in or on LOS ANGELES COUNTY
23 . RECORDED DOCUMENT NO. 20200139370 IN THE NAME OF ROY D. Furthermore, the
Defendants are charged in COUNT 42 with identity theft, as dA~, Penal Code section 530.5.
24
25
COUNT44
tt)
26
PROCURING OR OFFERING FALSE OR FORGED INSTRUMENT (Re: Liudmyla K.)
27
On or about February 4, 2020, in the COUNTY of LOS ANGELES, the crime of
28
PROCURING OR OFFERING A FALSE OR FORGED INSTRUMENT in violation of Penal
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Code section l 15(a), a felony, was committed byTAMARADADYAN,RICHARD A YVAZYAN,
ARTUR A YV AZY AN, LILIT MAL YAN, ART ASHES MARTIROSY AN, GRIGOR TATOIAN,
ARSHAK BARTOUMIAN, ROSA ZARA TE, ESTEPHANIE REYNOSO, and VANES SA RAY
BELL, who did unlawfully and knowingly procure or offer a false or forged instrument to be filed,
registered, or recorded in a public office in California, which instrument, if genuine, might be filed,
registered, or recorded under a law of California or the United States, to wit: LOS ANGELES
COUNTY RECORDED DOCUMENT NO. 20200139370. n')
COUNT45 (9
CONSPIRACY TO COMMIT GRAND THEFT (Re: Susanna M.)
On or about and between June 1, 2016, and October 1, 2019, in the COUNTY of LOS
ANGELES, the crime of CONSPIRACY, in violation of Penal Code section l 82(a)(l) a felony,
was committed by TAMARA DADYAN, RICHARD AYVAZYAN, ARTUR AYVAZYAN,
ROSA ZARA TE, ESTEPHANIE REYNOSO, and VANESSA RAY BELL, who did willfully and
unlawfully conspire together with another person or persons whose identity is known or unknown
to commit the crime of GRAND THEFT BY FALSE PRETENSES, 487(a), of the California Penal
Code, a felony, pursuant to and for the purpose of carrying out the objects and purposes of the
aforesaid conspiracy, Defendants committed the following overt act(s):
OVERT ACT 1
On or about June 9, 2016, Richard AYVAZYAN and Estephanie REYNOSO created the
Yahoo account, "Susanna644," using Susanna M. 's name.
OVERT ACT2
On or about August 5, 2016, Richard A YV AZY AN used the "Susanna644" Yahoo account
to register an internet domain in the name of "FiberOneMedia."
OVERT ACT3
On or about September 6, 2016, Richard A YV AZY AN used the "Susanna644" Yahoo
account to create an email account in the name of "Osbaldo V." linked to the internet domain of
"FiberOneMedia."
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OVERT ACT4
2
On or about September 6, 2016, Richard A YV AZY AN used a Bank of America account
3
ending in -0559, held in Susanna M.'s name, to order checks shipped to 22615 Mariano St. in
4
Woodland Hills.
5
OVERT ACT 5
6
On or about November 16, 2016, Tamara DADY AN emailed Richard AYVAZYAN and
7
attached paystubs for Susanna's purported employment through "Fiber One Media."
8
OVERTACT6
9
On or about January 10, 2017, Richard A YV AZY AN used the "Susanna644" Yahoo account
10
to send financial documents in Susanna M.'s name to a Bourns Employee Federal Credit Union
11
(EFCU) representative, including statements for the Bank of America account ending in -0559 that
12
showed the balance inflated by $56,756.96.
13
OVERT ACT 7
14
On or about January 20, 2017, Richard A YV AZYAN used Susanna M.'s name to obtain a
15
$513,000 loan from Bourns FCU for the property located at 8937 Haskell.
16
OVERT ACT 8
17
On or about February 8, 2017, Richard A YV AZY AN used Anthony A.' s name to email
18
Tamara DADYAN with the subject, ''Need A Favor," writing, "Can you ask Romana to fix this
19
Hud. I want the loan amount to be 413,000 instead of 513,000," and attached a Buyer's Final
20
Settlement Statement in Susanna M.'s name for the 8937 Haskell property that showed a $513,000
21
trust deed from Bourns EFCU.
22
OVERT ACT 9
23
On or about February 9, 2017, Tamara DADYAN emailed Richard AYVAZYAN with the
24
subject, "See if good," and attached a Buyer's Final Settlement Statement in Susanna M.'s name
25
that showed a $413,000 trust deed from Bourns EFCU.
26
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OVERT ACT 10
2
On or about March 29, 2017, Richard AYVAZYAN, Tamara DADYAN, and Artur
3
A YV AZY AN used Susanna M.' s name on a grant deed for the property located at 5141 Genesta in
4
Encino, California, where Richard A YV AZY AN lived.
5
OVERT ACT 11
6
On or about April 24, 2017, Richard A YV AZY AN used the "Susanna644" Yahoo account
7
to send a U.S. Bank representative images of a driver's license in Susanna M.'s name as well as a
8
utility bill jn her name.
9
OVERT ACT 12
10
On or about July 13, 2017, Richard A YV AZY AN used Susanna M.' s name to obtain a
11
$1,500,000 loan from East West Bank for the 5141 Genesta property.
12
OVERT ACT 13
13
On or about August 2, 2017, Richard AYVAZYAN, Estephanie REYNOSO, and Rosa
14
ZARA TE deposited a $3,500 check from the U.S. Bank account ending in -3701, held in Susanna
15
M.'s name, to the Bank of America account ending in -9473, held in Susanna M.'s name as DBA
16
Fiber One Media.
17
OVERT ACT 14
18
On or about August 16, 2017, Richard AYVAZYAN, Estephanie REYNOSO, and Rosa
19
ZARA TE deposited a $20,000 check from the U.S. Bank account ending in -2662, held in Andrew
20
A.'s name DBA SAVS Enterprise, to the Bank of America account ending in -9473, held in Susanna
21
M.'s name as DBA Fiber One Media.
22
OVERT ACT 15
23
On or about August 17, 2017, Richard A YV AZYAN, Estephanie REYNOSO, and Rosa
24
ZARA TE used a Bank of America account ending in -94 73, held in Susanna M.' s name doing
25
business as "Fiber One Media," to transfer $20,000 to the Bank of America account ending in -
26
0559, held in Susanna M.'s name.
27
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OVERT ACT 16
2
On or about August 17, 2017, Richard A YV AZYAN, Estephanie REYNOSO, and Rosa
3
ZARA TE used the Bank of America account ending in -0559, held in Susanna M.'s name, to
4
transfer $2,000 to a bank account held in the name of Richard A YV AZY AN' s wife, Marietta Ter-
5
Abelian.
6
OVERT ACT 17
7
On or about August 24, 2017, Richard A YV AZYAN, Rosa ZARA TE, and Estephanie
8
REYNOSO used the Bank of America account ending in -0559, held in Susanna M.'s name, to
9
transfer $3,500 to a bank account held in the name of Richard A YV AZY AN's wife, Marietta Ter-
10
Abelian.
11
OVERT ACT 18
12
On or about September 17, 2018, Richard A YV AZY AN used the Bank of America account
13
ending in -0559 held in Susanna M.'s name to obtain $273,343.39 in pJoceed from the purported
14
sale of A YV AZY AN' s home located at 5141 Genesta A venue i1
15
COUNT46
16
MORTGAGE FRAUD {Re: Susann
17
On or about and between March 29, 2017, and July 31, 2017, in the COUNTY of LOS
18
ANGELES, the crime of MORTGAGE FRAUD in violation of Penal Code section 532f(a)(2), a
19
felony, was committed by TAMARA DADYAN, RJCHARD AYVAZYAN, ARTUR
20
A YV AZY AN, ROSA ZARA TE, ESTEPHANIE REYNOSO, and VANES SA RAY BELL, who
21
did unlawfully and deliberately use or facilitate the use of a misstatement, misrepresentation, or
22
omission, with the knowledge it contained a misstatement, misrepresentation, or omission, during
23
the mortgage lending process, with the intention that it be relied upon by a mortgage lender,
24
borrower, or other party to the mortgage lending process, to wit: EAST WEST BANK. It is further
25
alleged, pursuant to Penal Code section 532f(j), that the value of the fraud exceeds $950.
26
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27
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28
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24
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COUNT47 (§)
UNLAWFUL TRANSFER OF IDENTIFYING INFORMATION (Re: Susanna M.)
On or about July 13, 2017, in the COUNTY of LOS ANGELES, the crime of IDENTITY
THEFT in violation of Penal Code section 530.5(d)(l), a felony, was committed by TAMARA
DADYAN, RICHARD A YVAZYAN, ARTUR A YVAZYAN, ROSA ZARATE, ESTEPHANIE
REYNOSO, and VANESSA RAY BELL, who did willfully and unlawfully with the intent to
defraud sell, transfer, or convey the personal identifying information of another person, to wit:
SUSANNA M.'S NAME ON AN EAST WEST BANK DEED OF TRUST FOR 5141 GENESTA,
RECORDED DOCUMENT NO. 20170862745.
~
COUNT48 ~
MONEY LAUNDERING (Re: Susanna M.)
On or about and between August 16, 2017, and August 17, 2017, in the COUNTY of LOS
ANGELES, the crime of MONEY LAUNDERING in violation of Penal Code section 186.I0(a), a
felony, was committed by TAMARA DADYAN, RICHARD AYVAZYAN, ARTUR
A YV AZY AN, ROSA ZARA TE, ESTEPHANIE REYNOSO, and VANESSA RAY BELL, who
did unlawfully conduct transactions involving monetary instruments of a value exceeding $5,000,
within a seven-day period, through a financial institution knowing that the monetary instruments
represented the proceeds of, and was derived directly or indirectly from the proceeds of, criminal
activity, to wit: $20,000 FROM U.S. BANK ACCOUNT ENDING IN -2662 TO BANK OF
AMERICA ACCOUNT ENDING IN -9473 TO BANK OF AMERICA ACCOUNT ENDING IN
-0559, AS DETAILED IN THE TABLE BELOW:
DATE
AMOUNT TRANSACTION
8/16/17
$20,000
U.S. Bank-2662 check to Bank of America -9473
8/17/17
$20,000
Bank of America -9473 transfer to Bank of America -0559
26
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27
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COUNT49 @>
CONSPIRACY TO COMMIT GRAND THEFT (Re: Fatima J.)
On or about and between May 19, 2016, and December 13, 2018, in the COUNTY of LOS
ANGELES, the crime of CONSPIRACY, in violation of Penal Code section 182(a)(l) a felony,
was committed by TAMARA DADYAN, RICHARD AYVAZYAN, GRIGOR TATOIAN,
ANDRANIK PETROSYAN, LILIT MALYAN, ARTASHES MARTIROSYAN, LUBIA
CARRILLO, ARSHAK BARTOUMIAN, ROSA ZARATE, ESTEPHANIE REYNOSO, and
VANESSA RAY BELL, who did willfully and unlawfully conspire together with another person
or persons whose identity is known or unknown to commit the crime of GRAND THEFT BY
FALSE PRETENSES, 487(a), of the California Penal Code, a felony, pursuant to and for the
purpose of carrying out the objects and purposes of the aforesaid conspiracy, Defendants committed
the following overt act(s):
OVERT ACT 1
On or about May 19, 2016, Tamara DADY AN emailed Andranik PETROSYAN with the
subject, "Your offer," and attached a purchase agreement in the name of Fatima J., offering $1 .4
million for the property located at 12334 Longacre Avenue in Granada Hills.
OVERT ACT2
On or about May 20, 2016, Andranik PETROSYAN emailed the purchase agreement from
Tamara DADYAN to the agent representing the sellers of the 12334 Longacre property.
OVERTACT3
On or about June 15, 2016, Tamara DADY AN emailed Andranik PETRO SY AN and a Banc
of California representative, attaching paystubs in the name of "Fatima J." that were purportedly
from "Urban Solutions Services LLC."
OVERTACT4
On or about July 26, 2016, Tamara DADY AN emailed Lilit MALY AN with the subject
"Need to do this [sic] transcripts" and attached a tax return in the name of Fatima J. that included
her social security number.
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OVERT ACT 5
2
On or about August 23, 2016, Vanessa BELL emailed a Tower Escrow officer and attached
3
an Evidence oflnsurance document in the name of Fatima J.
4
OVERT ACT6
5
On or about September 7, 2016, Tamara DADYAN used Fatima J.'s name and the notary
6
stamp of Jon B. on a Deed of Trust for a $1,099,000.00 loan from the Banc of California for the
7
property located at 12334 Longacre Ave. in Granada Hills.
8
OVERT ACT7
9
On or about September 28, 2016, Tamara DADYAN used Fatima J.'s name and the notary
10
stamp of Erwin N. on a Deed of Trust for a $170,000.00 loan from Bodega S&L for the property
11
located at 12334 Longacre Avenue in Granada Hills.
12
OVERT ACT 8
13
On or about October 20, 2016, Tamara DADY AN emailed Andranik PETRO SY AN and
14
attached an image of a driver's license in the name of Fatima J. that included her date of birth.
15
OVERT ACT 9
16
On or about December 11, 2016, Tamara DADY AN emailed Richard A YV AZY AN with the
17
subject "Don't forget apply for his too" and attached the Real Estate Purchase Agreement in Fatima
18
J.'s name from the Banc of California loan for 12334 Longacre.
19
OVERT ACT 10
20
On or about January 11, 2017, Tamara DADY AN forwarded Lilit MALY AN an email with
21
Fatima J.'s Banc of California loan documents attached and wrote, "This is the property she now
22
owns see if we can get that loan that we 're trying to get that Arus gets but first look at the credit
23
let's see."
24
OVERT ACT 11
25
On or about January 26, 2017, Estephanie REYNOSO used Fatima J.'s name to create a
26
Yahoo email account.
27
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28
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OVERT ACT 12
2
On or about February 3, 2017, Richard AYV AZYAN used the Fatima J. Yahoo account to
3
apply for funding from Renew Funding.
4
OVERT ACT 13
5
On or about February 3, 2017, Richard A YV AZY AN emailed Tamara DADY AN with the
6
subject "Fatima Approval" and included a screenshot of the Renew Funding application.
7
OVERT ACT 14
8
On or about March 8, 2017, Richard A YV AZYAN submitted a Renew Funding completion
9
certificate in the name of Fatima J., in the amount of $131 ,700, for the property at 12334
10
Longacre A venue in Granada Hills.
11
OVERT ACT 15
12
On or about April 18, 2017, Tamara DADY AN emailed Richard A YV AZYAN with the
13
subject, "Pending that I remember," and a list of names and streets, including Longacre.
14
OVERT ACT 16
15
On or about May 8, 2017, Richard A YVAZYAN, Estephanie REYNOSO, and Rosa
16
ZARA TE submitted a Y grene Energy Fund completion certificate in the name of Fatima J., in the
17
amount of $113,625, for the property at 12334 Longacre Avenue in Granada Hills.
18
OVERT ACT 17
19
On or about July 14,2017, Tamara DADY AN used Fatima J.'s name on a Deed of Trust for
20
a $149,000 loan from the Valdez Family Trust for the property located at 12334 Longacre in
21
Granada Hills, California.
22
OVERT ACT 18
23
On or about March 25, 2018, Tamara DADY AN emailed Andranik PETRO SY AN with the
24
subject "Need to get dl ss with karine pie for ur house" and attached an image of a driver's license
25
in the name of Fatima J. and a social security card in her name.
26
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28
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OVERT ACT 19
2
On or about June 8, 2018, Lubia CARRILLO emailed Tamara DADY AN with the subject,
3
"LONGACRE FORECLOSURE," attaching a Notice of Trustee's Sale requested by Dennis
4
Valdez.
5
OVERT ACT 20
6
. On or about June 13, 2018, Tamara DADYAN emailed Arshak BARTOUMIAN with the
7
subject "Long acre deed of trust I put trustee as your legal firm," attaching a purported Deed of
8
Trust with Fatima J. as the trustor, "Legal Works, Etc" as the trustee, and Larissa K. as the
9
beneficiary, to which BARTOUMIAN replied, "Ok."
10
OVERT ACT 21
11
On or about June 14, 2018, Tamara DADY AN emailed Arshak BAR TOUMIAN a copy of a
12
Trustee's Deed Upon Sale for Dennis Valdez as to the 12334 Longacre property, writing "Save this
13
till I call u."
14
OVERT ACT 22
15
On or about June 14, 2018, Tamara DADYAN emailed Lubia CARRILLO and Golie
16
Ghoreishi, attached the Deed of Trust purportedly signed by Fatima J. and told Ghoreishi to email
17
the attachments to CARRILLO and ask for her help with getting payoff information.
18
OVERT ACT 23
19
On or about June 29, 2018, Tamara DADY AN emailed Artashes MARTIROSYAN with the
20
subject, "Stamp goes on page 2 dates need to match date there," and DADY AN attached the Deed
21
of Trust with Fatima J. 's purported signature.
22
OVERT ACT 24
23
On or about July 17, 2018, Andranik PETROSYAN emailed Tamara DADYAN with the
24
subject "Longacre" and attached an image of an unlawful detainer ( eviction) action brought by the
25
Valdez Family Trust.
26
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OVERT ACT 25
2
On or about July 27, 2018, Grigor TA TO IAN emailed Tamara DADY AN a motion to strike
3
complaint for unlawful detainer with Andranik PETROSYAN's name for the 12334 Longacre
4
property.
5
OVERT ACT 26
6
On or about July 31, 2018, Grigor TA TO IAN emailed ~amara DADY AN with the subject
7
"Longacre" and said, "You call and tell him if he shows up to change the locks tomorrow tenant
8
will call the cops. Theres no judgment against tenant for a lockout. He should fuck off with his
9
locksmith."
10
OVERT ACT 27
11
On or about August 5, 2018, Grigor TATOIAN emailed Tamara DADY AN with the subject,
12
"Rescission for Ando," and attached a purported "Notice of Rescission" as to the Dennis Valdez
13
Trustee's Deed Upon Sale for the 12334 Longacre property that was filed on June 6, 2018.
14
OVERT ACT 28
15
On or about November 27, 2018, Grigor TA TO IAN emailed Andranik PETRO SY AN a court
16
complaint prepared using Fatima l's name as plaintiff regarding the Valdez Family Trust loan for
17
the 12334 Longacre property.
18
OVERT ACT 29
19
On or about December 13, 2018, Grigor TA TO IAN emailed Tamara DADY AN, "I served
20
Dennis today the law suit. Loi," and attached a picture of a man I
21
COUNT 50
22
UNLA WF L TRANSFER OF IDENTIFYING INFO
e: Fatima J.
23
On or about May 8, 2017, in the COUNTY of LOS ANGELES, the crime of IDENTITY
24
THEFT in violation of Penal Code section 530.5(d)(l), a felony, was committed by TAMARA
25
DADYAN, RICHARD AYVAZYAN, ARTUR AYVAZYAN, LILIT MALYAN, GRIGOR
26
TATOIAN, ROSA ZARATE, ESTEPHANIE REYNOSO, LUBIA CARRILLO, and VANESSA
27
RAY BELL, who did willfully and unlawfully with the intent to defraud sell, transfer, or convey
28
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the personal identifying information of another person, to wit: FATIMA J.' S NAME ON A
YGRENE ENERGY FUND COMPLETION CERTIFICATE FOR 1~33
ONGACRE.
COUNT51
'I.;
MORTGAGE FRAUD (Re: Fatima J.J
On or about and between June 12, 2017, and July 14, 2017, in the COUNTY of LOS
ANGELES, the crime of MORTGAGE FRAUD in violation of Penal Code section 532f(a)(2), a
felony, was committed by TAMARA DADY AN, RICHARD A YV AZY AN, ANDRANIK
PETROSYAN, LILIT MAL YAN, ARTASHES MARTIROSYAN, ARSHAK BARTOUMIAN,
ROSA ZARA TE, LUBIA CARRILLO, ESTEPHANIE REYNOSO, and VANESSA RAY BELL,
who did unlawfully and deliberately use or facilitate the use of a misstatement, misrepresentation,
or omission, with the knowledge it contained a misstatement, misrepresentation, or omission,
during the mortgage lending process, with the intention that it be relied upon by a mortgage lender,
borrower, or other party to the mortgage lending process, to wit: THE VALDEZ FAMILY TRUST.
It is further alleged, pursuant to Penal Code section 532fU), that the value of the fraud exceeds
@
$950.
COUNT52
GRAND THEFT {Re: Fatima J.)
On or about and between June 12, 2017, and July 14, 2017, in the COUNTY of LOS
ANGELES, the crime of GRAND THEFT in violation of Penal Code section 487(a), a felony, was
committed by TAMARA DADYAN, RICHARD. AYVAZYAN, ANDRANIK PETROSYAN,
LILITMALYAN,ARTASHESMARTIROSYAN,ARSHAKBARTOUMIAN,ROSAZARATE,
LUBIA CARRILLO, ESTEPHANIE REYNOSO, and VANESSA RAY BELL, who did
knowingly and designedly, by a false or fraudulent representation or pretense, obtain money, or
real property by fraud from THE VALDEZ FAMILY TRUST, SPECIFICALLY, A $149,000
LOAN FOR 12334 LONGACRE AVENUE, which had a value exceeding nine hundred fifty
dollars ($950).
!!
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4
5
6
7
8
9
10
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12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
COUNT 53
UNLAWFUL TRANSFER OF IDENTIFYING INFORMATION
(Re: Fatima J. & Erwin N.)
On or about July 24, 2017, in the COUNTY of LOS ANGELES, the crime of IDENTITY
THEFT in violation of Penal Code section 530.5(d)(l), a felony, was committed by TAMARA
DADYAN,
RICHARD
AYVAZYAN, ANDRANIK PETROSYAN,
LILIT MALYAN,
ARTASHES MARTIROSYAN, ARSHAK BARTOUMIAN, ROSA ZARATE, LUBIA
CARRILLO, ESTEPHANIE REYNOSO, and VANESSA RAY BELL, who did willfully and
unlawfully with the intent to defraud sell, transfer, or convey the personal identifying information
of another person, to wit: FATIMA J.' S NAME AND ERWIN N.' S NAME ON A LOS ANGELES
COUNTY RECORDED DOCUMENT NO. 20170826251, DEE~
. RUST.
COUNT54
~
FORGERY RELATING TO IDENTITY THEFT (Re: Fatima J.)
On or about July 14, 2017, in the COUNTY of LOS ANGELES, the crime of FORGERY in
violation of Penal Code section 470(a), a felony, was committed by TAMARA DADYAN,
RICHARD AYVAZYAN, ANDRANIK PETROSYAN, LILIT MALYAN, ARTASHES
MARTIROSYAN, ARSHAK BARTOUMIAN, ROSA ZARATE, LUBIA CARRILLO,
ESTEPHANIE REYNOSO, and VANESSA RAY BELL, who with the intent to defraud, signed
the name of another person or of a fictitious person to convey any real property, specifically
RECORDED DOCUMENT NO. 20170826251, DEED OF TRUST IN THE NAME OF FATIMA
J., knowing that they had no authority to do so. Furthermore, the Defendants are charged in
COUNT 53 with Identity Theft, as defined in Penal Code section
COUNT 55
FORGERY RELATING TO IDENTITY THE
On or about July 24, 2017, in the COUNTY of LOS ANGELES, the crime of FORGERY in
violation of Penal Code section 470(b), a felony, was committed by TAMARA DADYAN,
FJCHARD AYVAZYAN, ANDRA.NIK PETROSYAN, LILIT MALYAN, ARTASHES
MARTIROSYAN, ARSHAK BARTOUMIAN, ROSA ZARATE, LUBIA CARRILLO,
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ESTEPHANIE REYNOSO, and VANESSA RAY BELL, who with the intent to defraud,
2
counterfeited and/or forged the seal or handwriting of another in or on a RECORDED
3
DOCUMENT NO. 20170826251, DEED OF TRUST. Furthermore, the Defendants are charged in
4
COUNT 53 with identity theft, as defined in Penal Code section 530.5.
5
COUNT 56
6
PROCURING OR OFFERING FALSE OR FORGED IN TRUMENT (Re: Fatima J.)
7
On or about July 24, 2017, in the COUNTY of LOS ANGELES, the crime of PROCURING
8
OR OFFERING A FALSE OR FORGED INSTRUMENT in violation of Penal Code section
9
115(a), a felony, was committed by TAMARA DADYAN, RICHARD AYVAZYAN,
10
ANDRANIK PETROSYAN, LILIT MALYAN, ARTASHES MARTIROSYAN, ARSHAK
11
BARTOUMIAN, ROSA ZARATE, LUBIA CARRILLO, ESTEPHANIE REYNOSO, and
12
VANES SA RAY BELL, who did unlawfully and knowingly procure or offer a false or forged
13
instrument to be filed, registered, or recorded in a public office in California, which instrument, if
14
genuine, might be filed, registered, or recorded under a law of California or the United States, to
15
wit: RECORDED DOCUMENT NO. 20170826251, DEED OF TRUST.
16
COUNT 57
17
MORTGAGE FRAUD EXCEEDING $950: FILING A FRAUDULE T DOCUMENT
18
(Re: Fatima J.)
19
On or about July 24, 2017, in the COUNTY of LOS ANGELES, the crime of FILING A
20
FRAUDULENT DOCUMENT in violation of Penal Code section 532f(a)(4), a felony, was
21
committed by TAMARA DADY AN, RICHARD A YV AZY AN, ANDRANIK PETRO SY AN,
22
LILITMALYAN,ARTASHESMARTIROSYAN,ARSHAKBARTOUMIAN,ROSAZARATE,
23
LUBIA CARRILLO, ESTEPHANIE REYNOSO, and VANESSA RAY BELL, who did with the
24
intent to defraud, file or cause to be filed with the recorder of any ~aunty in connection with a
25
mortgage loan transaction, a document with the knowledge the document contains a deliberate
26
misstatement, misrepresentation, or omission, to wit:
RECORDED DOCUMENT NO.
27
20170826251, DEED OF TRUST. It is further alleged that the value of the fraud exceeds nine
28
hundred fifty dollars ($950), within the meaning of Penal Code section 532fG).
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2
COUNT 58
UNLAWFUL TRAN FER OF IDENTIFYING IN,......-.. ...,v,
3
(Re: Fatima J. & ilver D.V.) . (];
TION
4
On or about July 27, 2018, in the COUNTY of LOS ANGELE , the crime of IDENTITY
5
THEFT in violation of Penal Code section 530.5(d)(l), a felony, was committed by TAMARA
6
DADY AN, RICHARD A YV AZYAN, GRIGOR TATOIAN, ANDRANIK PETROSYAN, LILIT
7
MALYAN, ARTASHES MARTIROSYAN, ARSHAK BARTOUMIAN, ROSA ZARATE,
8
LUBIA CARRILLO, ESTEPHANIE REYNOSO, and VANESSA RAY BELL, who did willfully
9
and unlawfully with the intent to defraud sell, transfer, or convey the personal identifying
10
information of another person, to wit: THE NAMES OF FATIMA J. AND SILVER D.V. ON
11
RECORDED DOCUMENT NO. 20180756418, NOTICE OF RESCI
12
COUNT 59
13
FORGERY RELATING TO IDENTITY THEF
14
On or about July 27, 2018, in the COUNTY of LOS ANGELES, the crime of FORGERY in
15
violation of Penal Code section 470(b), a felony, was committed by TAMARA DADYAN,
16
RICHARD AYVAZYAN, GRIGOR TATOIAN, ANDRANIKPETROSYAN, LILITMALYAN,
17
ARTASHES MARTIROSYAN, ARSHAK BARTOUMIAN, ROSA ZARATE, LUBIA
18
CARRILLO, ESTEPHANIE REYNOSO, and VANESSA RAY BELL, who with the intent to
19
defraud, counterfeited and/or forged the seal or handwriting of another in or on RECORDED
20
DOCUMENT NO. 20180756418, NOTICE OF RESCISSION in the name of Silver D.V.
21
Furthermore, the Defendants are charged in COUNT 58 wit~ ntity theft, as defined in Penal
22
Code section 530.5.
23
COUNT 60
24
PROCURING OR OFFERING FALSE OR FORGED INSTRUMENT (Re: Fatima J.)
25
On or about July 27, 2018, in the COUNTY of LOS ANGELES, the crime of PROCURING
26
OR OFFERING A FALSE OR FORGED INSTRUMENT in violation of Penal Code section
27
115(a), a felony, was committed by TAMARA DADYAN, FJCH..A.RD AYVAZYAN, GRIGOR
28
TATOIAN, ANDRANIK PETROSYAN, LILIT MALYAN, ARTASHES MARTIROSYAN,
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1
ARSHAK BARTOUMIAN, ROSA ZARATE, LUBIA CARRILLO, ESTEPHANIE REYNOSO,
2
and VANES SA RAY BELL, who did unlawfully and knowingly procure or offer a false or forged
3
instrument to be filed, registered, or recorded in a public office in California, which instrument, if
4
genuine, might be filed, registered, or recorded under a law of CalifoJ
5
wit: RECORDED DOCUMENT NO. 20180756418, NOTICE OF
6
COUNT61
7
CONSPIRACY TO COMMIT GRAND THEFT (
8
On or about and between December 2, 2016, and September 26, 2019, in the COUNTY of
9
LOS ANGELES, the crime of CONSPIRACY, in violation of Penal Code section 182(a)(l) a
10
felony, was committed by TAMARA DADYAN, RICHARD AYVAZYAN, LILIT MAL YAN,
11
LUBIA CARRILLO, ESTEPHANIE REYNOSO, and ROSA ZARA TE who did willfully and
12
unlawfully conspire together with another person or persons whose identity is known or unknown
13
to commit the crime of GRAND THEFT BY FALSE PRETENSES, 487(a), of the California Penal
14
Code, a felony, pursuant to and for the purpose of carrying out the objects and purposes of the
15
aforesaid conspiracy, Defendants committed the following overt act(s):
16
OVERT ACT 1
17
On or about December 2, 2016, Lubia CARRILLO submitted a Residential Purchase
18
Agreement in the name of Walter C. to Caliber Home Loans for a loan on the property located at
19
15821 Kingsbury Street in Granada Hills.
20
OVERT ACT 2
21
On or about December 29, 2016, Tamara DADY AN emailed Richard A YV AZYAN with the
22
subject "Walter di" and attached an image of a driver's license in the name of Walter C.
23
OVERT ACT 3
24
On or about March 3, 2017, Tamara DADY AN used Walter C.'s name and the notary stamp
25
of Carolyn S. on a Deed of Trust for a $525,309 loan from Caliber Home Loans for the property at
26
15821 Kingsbury Street in Granada Hills.
27
II
28
II
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1
OVERT ACT4
2
On or about March 21 , 2017, Tamara DADYAN emailed Richard AYVAZYAN a closing
3
disclosure and stated, "Look befor u send out I can have romana fix the downpayment to show
4
more equity."
5
OVERT ACT 5
6
On or about April 18, 2017, Tamara DADYAN emailed Richard AYVAZYAN a list of
7
pending deals, including, "Walter kingsbury."
8
OVERT ACT6
9
On or about May 8, 201 7, Richard A YV AZY AN, Estephanie REYNOSO, and Rosa
10
ZARATE created a Gmail account using Walter C.'s name.
11
OVERT ACT 7
12
On or about May 8, 2017, Tamara DADY AN emailed Richard A YV AZY AN, copying a
13
different Gmail account in Walter C.' s name, and stated, "This is Walters email comes to my
14
phone."
15
OVERT ACT 8
16
On or about May 8, 2017, Tamara DADY AN emailed Richard A YV AZY AN a loan
17
application in the name of Walter C. for 15821 Kingsbury Street in Granada Hills and stated, "Here
18
is the 1003 but don't put his phone number on this 1003 put any other one."
19
OVERT ACT 9
20
On or about May 26, 2017, Tamara DADY AN emailed Richard A YV AZY AN a paystub and
21
W-2 purportedly from SAVS Enterprise in the name of Walter C.
22
OVERT ACT 10
23
On or about June 8, 2017, Richard A YVAZYAN, Estephanie REYNOSO, and Rosa
24
ZARATE submitted a Ygrene Energy Fund completion certificate in the name of Walter C., in the
25
amount of $47,000, for 15821 Kingsbury Street in Granada Hills.
26
II
27
II
28
II
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1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
OVERT ACT 11
On or about June 22, 2017, Richard A YV AZYAN, Estephanie REYNOSO, and Rosa
ZARA TE submitted a Renew Funding completion certificate in the name of Walter C., in the
amount of $53,500, for 15821 Kingsbury Street in Granada Hills.
OVERT ACT 12
On or about May 2, 2018, Tamara DADY AN emailed Lubia CARRILLO statements from a
Chase account ending in -9688 that was held in Walter C.'s name.
OVERT ACT 13
On or about May 4, 2018,Tamara DADY AN emailed Lubia CARRILLO Caliber Home Loan
documents, an earning statement, and a Form W-2 in the name of Walter C.
OVERT ACT 14
On or about May 14, 2018, Lubia CARRILLO emailed Tamara DADY AN, with the subject,
"waiter updated stmt april," and stated, "Thank you. I submitted the package on line. Let's see
what happens."
OVERT ACT 15
On or about June 8, 2018, Lubia CARRILLO emailed Tamara DADYAN with the subject,
"Walter," and said, "Can I please get May bank statement."
OVERT ACT 16
On or about June 9, 2018, Tamara DADY AN forwarded Lubia CARRILLO's bank statement
request to Lilit MALY AN.
OVERT ACT 17
On or about September 26, 2019, Lubia CARRILLO filed a bankrugtcy petition in Walter
C. 's name in the Central District of California in Case No. 19-12427-MQ
COUNT62
V
UNLAWFUL TRAN FER OF IDE TIFYING INFORMATION (Re: Walter C.)
On or about June 27, 2017, in the COUNTY of LOS ANGELES, the crime of IDENTITY
THEFT in violation of Penal Code section 530.5(d)(l), a felony, was committed by TAMARA
DADYAN, RICHARD AYVAZYAN, LILIT MALYAN, LUBIA CARRILLO, ESTEPHANIE
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1
REYNOSO, and ROSA ZARA TE, who did willfully and unlawfully with the intent to defraud sell,
2
transfer, or convey the personal identifying information of another person, to wit: WALTER C.' S
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
NAME FOR A YGRENE ENERGY FUND COMPLETION CERTIFICATE FOR 15821
KINGSBURY IN GRANADA HILLS.
~
COUNT63 (:k/
U LAWFUL TRA
FER OF IDENTIFYING INFORMATION (Re: Walter C.)
On or about September 26, 2019, in the COUNTY of LOS ANGELES, the crime of
IDENTITY THEFT in violation of Penal Code section 530.5(d)(l), a felony, was committed by
TAMARA DADYAN, RICHARD AYVAZYAN, LILIT MALYAN, LUBIA CARRILLO,
ESTEPHANIE REYNOSO, and ROSA ZARA TE, who did willfully and unlawfully with the intent
to defraud sell, transfer, or convey the personal identifying information of another person, to wit:
WALTER C.'S NAME ON A DEBTOR'S PETITION
CALIFORNIA CASE NO. 19-12427-MT.
COUNT 64
PROCURJNG OR OFFERING FALSE OR FORGED INSTRUME T {Re: Walter C.)
On or about September 26, 2019, in the COUNTY of LOS ANGELES, the crime of
PROCURING OR OFFERING A FALSE OR FORGED INSTRUMENT in violation of Penal
Code section l 15(a), a felony, was committed by TAMARA DADY AN, RICHARD A YV AZYAN,
LILIT MALY AN, LUBIA CARRILLO, ESTEPHANIE REYNOSO, and ROSA ZARA TE, who
did unlawfully and knowingly procure or offer a false or forged instrument to be filed, registered,
or recorded in a public office in California, which instrument, if genuine, might be filed, registered,
or recorded under a law of California or the United States, to wit: DEBTOR'S PETITION IN
CENTRAL DISTRICT OF CALIFORNIA CASE NO. 19-12~
COUNT65
~
CO SPIRACY TO COMMIT GRAND THEFT {Re: 0 baldo V.)
On or about and between December 14, 2016, and April 11, 2019, in the COUNTY of LOS
ANGELES, the crime of CONSPIRACY, in violation of Penal Code section 182(a)(l), a felony,
was committed by TAMARA DADYAN, RICHARD AYVAZYAN, ARTUR AYVAZYAN,
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1
GRIGOR
TATOIAN,
ARTASHES
MARTIROSYAN,
ARSHAK
BARTOUMIAN,
2
ESTEPHANIE REYNOSO, ROSA ZARA TE, and ANDRANIK PETROSYAN, who did willfully
3
and unlawfully conspire together with another person or persons whose identity is known or
4
unknown to commit the crime of GRAND THEFT BY FALSE PRETENSES, 487(a), of the
5
California Penal Code, a felony, pursuant to and for the purpose of carrying out the objects and
6
purposes of the aforesaid conspiracy, Defendants committed the following overt act(s):
7
OVERT ACT 1
8
On or about December 14, 2016, Richard A YV AZY AN emailed Tamara DADY AN with the
9
subject, "Co sign for Osbaldo," and included the information of Rogelio V. and Savs Enterprise.
10
OVERT ACT 2
11
On or about December 21, 2016, Tamara DADYAN, using Osbaldo V.'s name, emailed
12
Richard A YV AZYAN with the subject, "Copy oflD," and attached an image of a driver's license
13
in the name of Osbaldo V.
14
OVERT ACT 3
15
On or about December 28, 2016, Richard AYVAZYAN emailed Artur AYVAZYAN an
16
image of a driver's license in the name of Osbaldo V.
17
OVERTACT4
18
On or about January 25, 2017, Tamara DADY AN emailed Andranik PETROSYAN images
19
of a driver's license and social security card in the name of Osbaldo V., and asked, "Canu see if u
20
can open a bofa or wells or chase[?]"
21
OVERT ACT 5
22
On or about January 30, 2017, Tamara DADY AN emailed Grigor TA TO IAN an image of a
23
social security card in the name of Osbaldo V., with the subject, "Osballdo ssi use same address
24
Wells Fargo personal ace please," and exchanged a conversation about the account.
25
OVERT ACT 6
26
On or about April 19, 2017, Richard A YV AZY AN emailed Tamara DADY AN a Fiber One
27
Media letter confirming Osbaldo V. as a Chief Operations Officer, with a salary of $420,000, and
28
stated, "Steph wanted this letter on the company letterhead. Here you go ... "
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1
OVERT ACT 7
2
On or about November 8, 2017, Tamara DADY AN faxed herself Form W-2's and a Form
3
1040 from Fiber One Media in the name of Osbaldo V.
4
OVERT ACT 8
5
On or about November 23, 2017, Razmik Galoosian faxed Tamara DADY AN payroll
6
statements from Fiber One Media in the name of Osbaldo V.
7
OVERT ACT 9
8
On or about December 5, 2017, Artashes MARTIROSYAN emailed Tamara DADYAN
9
images of a driver's license and debit card in the name of Osbaldo V. with the subject, "Osbaldo
10
V," and spoke about rent payments, deposits, and tax returns related to Osbaldo V.
11
OVERT ACT 10
12
On or about March 20, 2018, Tamara DADYAN emailed Andranik PETROSYAN, with the
13
subject, "Rojellio 1003," and attached a loan application for the property located at 5141 Genesta
14
Avenue, Encino, California in the name of Osbaldo V.
15
OVERT ACT 11
16
On or about April 9, 2018, Artashes MARTIROSYAN emailed Tamara DADYAN an
17
Attorney Certification containing the name of Osbaldo V., with the subject line, "Osbaldo," and
18
stated, "Corrected name."
19
OVERT ACT 12
20
On or about April 22, 2018, Grigor TATOIAN emailed Tamara DADY AN, with the subject,
21
"University RP A," and attached a Residential Purchase Agreement for the property at 931
22
University A venue, Burbank, California in the name of Osbaldo V.
23
OVERT ACT 13
24
On or about April 30, 2018, Tamara DADY AN responded to an email that asked about re-
25
applying to the HERO Program.
26
OVERT ACT 14
27
On or about May 3, 2018, Artashes MARTIROSYAN emailed Tamara D.ADYAN with the
28
subject, "Extensions," and attached a Form 4868 request for extension to file a tax return in the
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1
name and social security number of Osbaldo V.
2
OVERT ACT 15
3
On or about May 11, 2018, Artur A YV AZY AN paid for a SiriusXM subscription using a
4
debit card in the name of Osbaldo V.
5
OVERT ACT 16
6
On or about June 13, 2018, Artashes MARTIROSYAN emailed Tamara DADY AN with the
7
subject, "Osbaldo 2017 W2," and attached a Form W-2 in the name and social security number of
8
Osbaldo V.
9
OVERT ACT 17
10
On or about June 14, 2018, Tamara DADYAN emailed Artashes MARTIROSYAN Wells
11
Fargo bank statements in the name of Osbaldo V., and stated, "I need this to give to Todd for
12
longacre but we also need to give it to philip for university."
13
OVERT ACT 18
14
On or about June 19, 2018, Artashes MARTIROSYAN emailed Tamara DADYAN Wells
15
Fargo bank statements in the name ofOsbaldo V., with the subject, "Osbaldo University."
16
OVERT ACT 19
17
On or about June 26, 2018, Tamara DADY AN emailed herself Letters of Explanations in the
18
name, date of birth, and social security number of Osbaldo V ., and reminded herself, "You need to
19
re send her the transcripts for 2016 and the payroll checks."
20
OVERT ACT 20
21
On or about June 29, 2018, Tamara DADYAN emailed lending and escrow agents an
22
addendum for the property at 931 University Avenue, Burbank, California, indicating that the
23
buyer, Osbaldo V., and the seller agreed to "drop the purchase price to $1,100,000."
24
OVERT ACT 21
25
On or about July 6, 2018, Grigor TATOIAN emailed Tamara DADYAN with the subject,
26
"Rent from Moso," and attached an image of a Cashier's Check in the name of Osbaldo V.
27
OVERT ACT 22
28
On or about July 10, 2018, Tamara DADY AN emailed a lender with the subject, "Here u go
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1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
babe," and attached a request for verification ofrent in the name of Osbaldo V.
OVERT ACT23
On or about July 18, 2018, Artashes MAR TIRO SY AN emailed Tamara DADY AN, with the
subject, "Osbaldo," and attached a Consumer Explanation Letter in the name of Osbaldo V. for
Supreme Lending.
OVERT ACT24
On or about August 1, 2018, in response to a lender asking about Osbaldo V.' s disconnected
business and cellphone numbers, Artashes MARTIROSYAN, posing as Osbaldo V., stated, "I have
no idea what your talking about Todd .... What's seems to be the problem?? You clearly can see
both myself and escrow and Tammy are here in our end to complete this loan process."
OVERTACT25
On or about August 17, 2018, Tamara DADY AN emailed Artashes MARTIROSYAN, with
the subject, "My phone died I didn't pay my bill," and stated, "Art can u login to mykailo wells
[a]nd osbaldo wells[.] We need to make westhore [p]ayment."
OVERT ACT26
On or about December 10, 2018, Tamara DADY AN emailed Grigor TA TO IAN an image of
a blank Wells Fargo check in the name of Osbaldo V.
COUNT66 ~
UNLAWFUL TRANSFER OF IDENTIFYI G INF~ION (Re: Osbaldo V.)
On or about December 5, 2017, in the COUNTY of LOS ANGELES, the crime oflDENTITY
THEFT in violation of Penal Code section 530.5(d)(l), a felony, was committed by TAMARA
22
DADYAN,
RICHARD
AYVAZYAN,
ARTUR
AYVAZYAN,
GRIGOR
TATOIAN,
23
ART ASHES MAR TIRO SY AN, £STEPHANIE REYNOSO, ROSA ZARA TE, and ANDRANIK
24
PETRO SY AN, who did willfully and unlawfully with the intent to defraud sell, transfer, or convey
25
the personal identifying information of another person, to wit: DRIVER'S LICENSE AND DEBIT
26
CARD IN OSBALDO V.'S NAME.
27
//
28
//
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COUNT67
2
MORTGAGE FRAUD (Re: Osbaldo V.)
3
On or about and between March 20, 2018, and July 23, 2018, in the COUNTY of LOS
4
ANGELES, the crime of MORTGAGE FRAUD in violation of Penal Code section 532f(a)(2), a
5
felony, was committed by TAMARA DADYAN, RJCHARD AYVAZYAN, ARTUR
6
AYVAZYAN,
GRJGOR
TATOIAN,
ARTASHES
MARTIROSYAN,
ESTEPHANIE
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
REYNOSO, ROSA ZARATE, and ANDRANIK PETROSYAN, who did unlawfully and
deliberately use or facilitate the use of a misstatement, misrepresentation, or omission, with the
knowledge it contained a misstatement, misrepresentation, or omission, during the mortgage
lending process, with the intention that it be relied upon by a mortgage lender, borrower, or other
party to the mortgage lending process, to wit: SUPREME LENDING. It is further alleged, pursuant
to Penal Code section 532f(j), that the value of the fraud exceeds $95½'""'\
COUNT68
~
UNLAWFUL TRANSFER OF IDENTIFYING INFORMATION (Re: Osbaldo V.)
On or about March 20, 2018, in the COUNTY of LOS ANGELES, the crime of IDENTITY
THEFT in violation of Penal Code section 530.5(d)(l), a felony, was committed by TAMARA
DADYAN,
RJCHARD
AYVAZYAN,
ARTUR
AYVAZYAN,
GRJGOR
TATOIAN,
ARTASHES MARTIROSYAN, £STEPHANIE REYNOSO, ROSA ZARATE, and ANDRANIK
PETROSYAN, who did willfully and unlawfully with the intent to defraud sell, transfer, or convey
the personal ident.ifying information of another person, to wit: A LOAN APPLICATION IN THE
NAME AND SOCIAL SECURJTY NUMBER OF O BALD~
COUNT 69 (:fr
UNLAWFUL TRANSFER OF IDENTIFY! G INFORMATION (Re: Osbaldo V.)
On or about April 22, 2018, in the COUNTY of LOS ANGELES, the crime of IDENTITY
THEFT in violation of Penal Code section 530.5(d)(l), a felony, was committed by TAMARA
DADYAN,
RICHARD
AYVAZYAN,
ARTUR
AYVAZYAN,
GRIGOR
TATOIAN,
ARTASHES MARTIROSYAN, ESTEPRt\NIE REYNOSO, ROSA ZARATE, and ANDRANIK
PETROSYAN, who did willfully and unlawfully with the intent to defraud sell, transfer, or convey
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1
the personal identifying information of another person, to wit: A RESIDENTIAL PURCHASE
2
AGREEMENT IN THE NAME OF OSBALDO V.
3
COUNT 70
4
FORGERY RELATING TO IDENTITY THEFT (Re: Osbaldo V.)
5
On or about April 22, 2018, in the COUNTY of LOS ANGELES, the crime of FORGERY
6
in violation of Penal Code section 470(a), a felony, was committed by TAMARA DADYAN,
7
RICHARD
AYVAZYAN, ARTUR AYVAZYAN,
GRIGOR TATOIAN,
ARTASHES
8
MARTIROSYAN,
ESTEPHANIE
REYNOSO,
ROSA
ZARATE,
and
ANDRANIK
9
PETRO SY ANN, who with the intent to defraud, signed the name of another person or of a fictitious
10
person to A CONTRACT IN THE NAME OF OSBALDO V., SPECIFICALLY A RESIDENTIAL
11
PURCHASE AGREEMENT, knowing that they had no authority to do so. Furthermore, the
12
Defendants are charged in COUNT 69 with identity theft, as define · _ e aal Code section 530.5.
13
COUNT 71
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
UNLAWFUL TRANSFER OF IDE TIFYING INFO
(Re: Osbaldo V.)
On or about June 13, 2018, in the COUNTY of LOS ANGELES, the crime ofIDENTITY
THEFT in violation of Penal Code section 530.5(d)(l), a felony, was committed by TAMARA
DADYAN,
RICHARD
AYVAZYAN,
ARTUR
AYVAZYAN,
GRIGOR
TATOIAN,
ARTASHES MARTIROSYAN, ARSHAK BARTOUMIAN, ESTEPHANIE REYNOSO, ROSA
ZARATE, and ANDRANIK PETROSYAN, who did willfully and unlawfully with the intent to
defraud sell, transfer, or convey the personal identifying information of another person, to wit:
FORM W-2 IN THE NAME AND SOCIAL SECURITY NUM~SBALDO V.
COUNT72
·/lt)
UNLAWFUL TRANSFER OF IDENTITYING INFO
ON (Re: Osbaldo V.)
On or about June 19, 2018, in the COUNTY of LOS ANGELES, the crime of IDENTITY
THEFT in violation of Penal Code section 530.5(d)(l), a felony, was committed by TAMARA
DADYAN,
RICHARD
AYVAZYAN,
ARTUR
AYVAZYAN,
GRlGOR
TATOIAN,
ARTASHES MARTIROSYAN, ARSHAK BARTOUMIAN, ESTEPHANIE REYNOSO, ROSA
ZARA TE, and ANDRANIK PETROSYAN, who did willfully and unlawfully with the intent to
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defraud sell, transfer, or convey the personal identifying information of another person, to wit:
WELLS FARGO BANK STATEMENTS ENDING IN -09~0
BALDO V.'S NAME.
COUNT73
CJ.)
UNLAWFUL TRANSFER OF IDENTIFYI GI
RMATIO
(Re: Osbaldo .)
On or about June 29, 2018, in the COUNTY of LOS ANGELES, the crime of IDENTITY
THEFT in violation of Penal Code section 530.5(d)(l), a felony, was committed by TAMARA
DADYAN,
RICHARD
AYVAZYAN,
ARTUR
AYVAZYAN,
GRIGOR
TATOIAN,
ARTASHES MARTIROSYAN, ARSHAK BARTOUMIAN, ESTEPHANIE REYNOSO, ROSA
ZARA TE, and ANDRANIK PETROSYAN, who did willfully and unlawfully with the intent to
defraud sell, transfer, or convey the personal identifying information of another person, to wit:
ADDENDUM TO A RESIDENTIAL PURCHASE AGREEMENT IN OSBALDO V.'S NAME.
COUNT74 <f!:!!J)
UNLAWFUL TRANSFER OF IDENTIFYING INFORMATION (Re: 0 baldo V.)
On or about July 10, 2018, in the COUNTY of LOS ANGELES, the crime of IDENTITY
THEFT in violation of Penal Code section 530.S(d)(l), a felony, was committed by TAMARA
DADYAN,
RICHARD
AYVAZYAN,
ARTUR
AYVAZYAN,
GRIGOR
TATOIAN,
ARTASHES MARTIROSYAN, ARSHAK BARTOUMIAN, ESTEPHANIE REYNOSO, ROSA
ZARA TE, and ANDRANIK PETROSYAN, who did willfully and unlawfully with the intent to
defraud sell, transfer, or convey the personal identifying information of another person, to wit:
REQUEST FOR VERIFICATION OF RENT IN OSBALD~.
COUNT 75 CY
UNLAWFUL TRANSFER OF IDENTIFYING INFORMATION (Re: 0 baldo V.)
On or about July 18, 2018, in the COUNTY of LOS ANGELES, the crime ofIDENTITY
THEFT in violation of Penal Code section 530.S(d)(l), a felony, was committed by TAMARA
DADYAN,
RICHARD
AYVAZYAN,
ARTUR
AYVAZYAN,
GRIGOR
TATOIAN,
ARTASHES MARTIROSYAN, ARSHAK BARTOUMIAN, ESTEPHANIE REYNOSO, ROSA
ZARATE, and ANDRA.NIK PETROSYAN, v,1110 did ,,1illfully and unlawfully with the intent to
defraud sell, transfer, or convey the personal identifying information of another person, to wit:
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CONSUMER EXPLANATION LETTER IN OSBALDO V.'S ~
COUNT76
~
UNLAWFUL TRANSFER OF IDENTIFY! G INFORMATION {Re: Elizabeth W.)
On or about July 23, 2018, in the COUNTY of LOS ANGELES, the crime of IDENTITY
THEFT in violation of Penal Code section 530.5(d)(l), a felony, was committed by TAMARA
DADYAN,
RJCHARD
AYVAZYAN,
ARTUR
AYVAZYAN,
GRIGOR
TATOIAN,
ARTASHES MARTIROSYAN, ARSHAK BARTOUMIAN, ESTEPHANIE REYNOSO, ROSA
ZARA TE, and ANDRANIK PETROSYAN, who did willfully and unlawfully with the intent to
defraud sell, transfer, or convey the personal identifying information of another person, to wit:
RECORDED DOCUMENT NO.2018073049, ORDER EXPUNGING NOTICE OF PEND ENCY
11
IN THE NAME OF ELIZABETH W.
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
COUNT 77
FORGERY RELATING TO IDENTITY THEFT (Re: Elizabeth W.)
On or about July 23, 2018, in the COUNTY of LOS ANGELES, the crime of FORGERY in
violation of Penal Code section 470(b), a felony, was committed by TAMARA DADYAN,
RICHARD AYVAZYAN,
ARTUR AYVAZYAN,
GRIGOR TATOIAN, ARTASHES
MARTIROSYAN, ARSHAK BARTOUMIAN, ESTEPHANIE REYNOSO, ROSA ZARA TE,
and ANDRANIK PETRO SY AN, who with the intent to defraud, counterfeited and/or forged the
seal or handwriting of another in or on a RECORDED DOCUMENT NO. 2018073049, ORDER
EXPUNGING NOTICE OF PENDENCY IN THE NAME OF EL ~ABETH W. Furthermore, the
Defendants are charged in COUNT 76 with identity theft, as ~
Penal Code section 530.5.
COUNT78 CV~
PROCURI G OR OFFERING FALSE OR FORG
TRUMENT (Re: Elizabeth W.)
On or about July 23, 2018, in the COUNTY of LOS ANGELES, the crime of PROCURING
OR OFFERING A FALSE OR FORGED INSTRUMENT in violation of Penal Code section
115(a), a felony, was committed by TAMARA DADYAN, RICHARD AYVAZYAN, ARTUR
27
AYVAZYAN,
GRIGOR
TATOIAN,
A.RTASHES
MARTIROSYAN,
ARSHAK
28
BARTOUMIAN, ESTEPHANIEREYNOSO, ROSA ZARATE, andANDRANIKPETROSYAN,
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who did unlawfully and knowingly procure or offer a false or forged instrument to be filed,
registered, or recorded in a public office in California, which instrument, if genuine, might be filed,
registered, or recorded under a law of California or the United States, to wit: RECORDED
DOCUMENT NO. 2018073049, ORDER EXPUNGING NOTICE ~CY.
COUNT79
~
NLA WFUL TRANSFER OF IDENTIFYING INFORMATION (Re: Jean W. & Lori H.)
On or about July 23, 2018, in the COUNTY of LOS ANGELES, the crime oflDENTITY
THEFT in violation of Penal Code section 530.5(d)(l), a felony, was committed by TAMARA
DADYAN,
RICHARD
AYVAZYAN,
ARTUR
AYVAZYAN,
GRIGOR
TATOIAN,
ARTASHES MARTIROSYAN, ARSHAK BARTOUMIAN, £STEPHANIE REYNOSO, ROSA
ZARA TE, and ANDRANIK PETROSYAN, who did willfully and unlawfully with the intent to
defraud sell, transfer, or convey the personal identifying information of another person, to wit:
:~::~E::::: ::~2:18073050, EXPUNGING PEND~CTION IN THE
COUNT 80
(!9'
FORGERY RELATING TO IDENTITY THEFT (Re: Jean W. & Lori 1-1.)
On or about July 23, 2018, in the COUNTY of LOS ANGELES, the crime of FORGERY in
violation of Penal Code section 470(a), a felony, was committed by TAMARA DADYAN,
RICHARD
AYVAZYAN,
ARTUR AYVAZYAN,
GRIGOR TATOIAN, ARTASHES
MARTIROSYAN, ARSHAK BARTOUMIAN, ESTEPHANIE REYNOSO, ROSA ZARATE,
and ANDRANIK PETRO SY AN, who with the intent to defraud, signed the name of another person
or of a fictitious person to a release or discharge of any suit or action in the name of Jean W. and
Lori H., specifically RECORDED DOCUMENT NO. 2018073050, EXPUNGING PENDENCY
OF ACTION IN THE NAME OF JEAN W. AND LORI H., knowing that they had no authority to
do so. Furthermore, the Defendants are charged in COUNT 79 with identity theft, as defined in
Penal Code section 530.5.
II
II
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COUNT 81
2
PROCURING OR OFFERING FALSE OR FORGED INSTRUMENT
3
(Re: Jean W. & Lori H.)
4
On or about July 23, 2018, in the COUNTY of LOS ANGELES, the crime of PROCURING
5
OR OFFERING A FALSE OR FORGED INSTRUMENT in violation of Penal Code section
6
115(a), a felony, was committed by TAMARA DADYAN, RICHARD AYVAZYAN, ARTUR
7
AYVAZYAN,
GRIGOR
TATOIAN,
ARTASHES
MARTIROSYAN,
ARSHAK
8
BARTOUMIAN, £STEPHANIE REYNOSO, ROSA ZARATE, and ANDRANIK PETROSYAN,
9
who did unlawfully and knowingly procure or offer a false or forged instrument to be filed,
10
registered, or recorded in a public office in California, which instrument, if genuine, might be filed,
11
registered, or recorded under a law of California or the United States, to wit: RECORDED
12
DOCUMENT NO. 2018073050, EXPUNGING PENDENCY OF ACTION IN THE NAME OF
13
JEAN W. AND LORI H.
14
15
16
17
18
19
20
21
22
23
24
25
26
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COUNT 82
GRAND THEFT (Re: OsbaJdo V.)
On or about and between July 18, 2018, and July 23, 2018, in the COUNTY of LOS
ANGELES, the crime of GRAND THEFT in violation of Penal Code section 487(a), a felony, was
committed by TAMARA DADY AN, RICHARD A YV AZYAN, ARTUR A YV AZYAN, GRIGOR
TATOIAN, ARTASHES MARTIROSYAN, ARSHAK BARTOUMIAN, £STEPHANIE
REYNOSO, ROSA ZARA TE, and ANDRANIK PETRO SY AN, who did knowingly and
designedly, by a false or fraudulent representation or pretense, obtain money by fraud from
SUPREME LENDING, SPECIFICALLY $990,000 FOR 931 UNIVERSITY A VENUE IN
BURBANK, CALIFORNIA, which had a value exceeding nine hund.~llars ($950).
COUNT83
&
PROCURING OR OFFER! G FALSE OR FORGED INSTRUMENT (Re: Osbaldo V.)
On or about July 23, 2018, in the COUNTY of LOS ANGELES, the crime of PROCURING
OR OFFERING A FALSE OR FORGED INSTRUMENT in violation of Penal Code section
115(a), a felony, was committed by TAMARA DADYAN, RICHARD AYVAZYAN, ARTUR
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AYVAZYAN,
GRIGOR
TATOIAN,
ARTASHES
MARTIROSYAN,
ARSHAK
2
3
4
5
6
7
8
9
10
11
12
13
14
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17
18
19
20
21
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23
24
25
26
27
28
BARTOUMIAN, ESTEPHANIE REYNOSO, ROSA ZARA TE, and ANDRANIK PETROSYAN,
who did unlawfully and knowingly procure or offer a false or forged instrument to be filed,
registered, or recorded in a public office in California, which instrument, if genuine, might be filed,
registered, or recorded under a law of California or the United States, to wit: RECORDED
DOCUMENT NO. 20180732053, DEED OF TRUST.
~
COUNT84
Q,0
MORTGAGE FRAUD EXCEEDING $950: FILING A FRA
I NT DOCUMENT
(Re: 0 baldo V.)
On or about July 23, 2018, in the COUNTY of LOS ANGELES, the crime of FILING A
FRAUDULENT DOCUMENT in violation of Penal Code section 532f(a)(4), a felony, was
committed by TAMARA DADY AN, RICHARD A YV AZY AN, ARTUR A YV AZYAN, GRIGOR
TATOIAN, ARTASHES MARTIROSYAN, ARSHAK BARTOUMIAN, ESTEPHANIE
REYNOSO, ROSA ZARATE, and ANDRANIK PETROSYAN who did with the intent to defraud,
file or cause to be filed with the recorder of any county in connection with a mortgage loan
transaction, a document with the knowledge the document contains a deliberate misstatement,
misrepresentation, or omission, to wit: RECORDED DOCUMENT NO. 20180732053, DEED OF
TRUST. It is further alleged that the value of the fraud exceeds nine hundred fifty dollars ($950),
within the meaning of Penal Code section 532fG).
@)
COUNT85
CONSPIRACY TO COMMIT GRAND THEFT (Re: Rogelio V.)
On or about and between April 4, 2016, and January 23, 2020, in the COUNTY of LOS
ANGELES, the crime of CONSPIRACY, in violation of Penal Code section 182(a)(l) a felony,
was committed by TAMARA DADYAN, RICHARD AYVAZYAN, ARTUR AYVAZYAN,
LILIT MALY AN, ART ASHES MAR TIRO SY AN,
GRIGOR TATOIAN, ANDRANIK
PETROSYAN, ROSA ZARA TE, and ESTEPHANIE REYNOSO, who did willfully and
unlawfully conspire together with another person or persons whose identity is kriown or unknown
to commit the crime of GRAND THEFT BY FALSE PRETENSES, 487(a), of the California Penal
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Code, a felony, pursuant to and for the purpose of carrying out the objects and purposes of the
2
aforesaid conspiracy, Defendants committed the following overt act(s):
3
OVERT ACT 1
4
On or about April 4, 2016, Tamara DADYAN emailed Victoria Akopyan with the subject,
5
"Rojolio credit," and attached a credit report in the name of Rogelio V.
6
OVERT ACT2
7
On or about July 21, 2016, Tamara DADYAN emailed Richard AYVAZYAN with the
8
subject, "Did I give u this," and attached a credit report in the name of Rogelio V.
9
OVERT ACT3
IO
On or about September 16, 2016, Richard A YV AZY AN, Estephanie REYNOSO, and ROSA
11
ZARATE created a Yahoo email account using the name of Rogelio V.
12
OVERT ACT 4
13
On or about October 7, 2016, Richard AYVAZYAN, Estephanie REYNOSO, and Rosa
14
ZARATE opened a First Tech Federal Credit Union (FCU) account in the name of Rogelio V.
15
OVERT ACT 5
16
On or about December 5, 2016, Richard AYVAZYAN opened a U.S. Bank account in the
17
name of Rogelio V.
18
OVERT ACT 6
19
On or about December 14, 2016, Richard A YV AZY AN emailed Tamara DADY AN Rogelio
20
V.'s social security number and birthdate, asking Tamara DADYAN to have Razmik Galoosian
21
"start the income docs" and to communicate with a Caliber Home Loans representative.
22
OVERT ACT 7
23
On or about December 14, 2016, Richard A YV AZYAN and Estephanie REYNOSO created
24
the email address, "rog@savsenterprise.com" using Rogelio V.'s name.
25
OVERT ACT 8
26
On or about December 20, 2016, Tamara DADY AN emailed Richard A YV AZYAN tax
27
forms in Rogelio V.'s name and told A YV AZY AN, "remind me to do the stolen identity paper for
28
IRS for Walter oswaldo and rojolio it's a must rich."
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OVERT ACT9
2
On or about January 25, 2017, Tamara DADY AN emailed Lilit MAL YAN with the subject,
3
"See if this is good," and attached W-2 statements and earning statements purportedly from SAVS
4
Enterprise in the name of Rogelio V.
5
OVERT ACT 10
6
On or about February 1, 2017, Richard AYVAZYAN, Estephanie REYNOSO, and Rosa
7
ZARATE deposited a $2,500 check from the U.S. Bank account ending in -2662, held in the name
8
of SAVS Enterprise and Andrew A., to the First Tech FCU account held in Rogelio V.'s name.
9
OVERT ACT 11
10
On or about March 30, 2017, Richard A YV AZY AN emailed himself images of a driver's
11
license and social security card in the name of Rogelio V.
12
OVERT ACT 12
13
On or about July 20, 2017, Artur A YV AZY AN acted as Rogelio V. and signed a Deed of
14
Trust for a $636,087 loan from Caliber Home Loans for the property located at 8150 Day Street in
15
Sunland, California.
16
OVERT ACT 13
17
On or about July 31, 2017, Tamara DADY AN emailed Richard A YV AZYAN and Artashes
18
MARTIROSYAN a copy of the Buyer/Borrower Statement for the 8150 Day loan in Rogelio V.'s
19
name.
20
OVERT ACT 14
21
On or about February 7, 2018, Estephanie REYNOSO used the Rogelio V. Yahoo account to
22
email an AJ Madison representative and attached a driver's license in the name of Rogelio V.
23
OVERT ACT 15
24
On or about March 20, 2018, Tamara DADYAN emailed Andranik PETROSYAN a credit
25
report in the name of Rogelio V.
26
OVERT ACT 16
27
On or about March 25, 2018, Tamara DADY AN emailed Andranik PETROSYAN a driver's
28
license and social security card in the name of Rogelio V.
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3
4
5
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9
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11
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13
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OVERT ACT 17
On or about June 5, 2018, Tamara DADY AN emailed Greg TATOIAN a driver's license and
social security card in the name of Rogelio V.
OVERT ACT 18
On or about January 21, 2020, Tamara DADY AN and Artur A YVAZYAN exchanged drafts
of an amended complaint against Caliber Home Loans in the name of Rogelio V., which was
subsequently filed in Central District of California Case No. 2: 19-cv-989~
COUNT86
6
UNLAWFUL TRANSFER OFIDE TIFYING INFORMATION (Re: Rogelio V.)
On or about June 5, 2017, in the COUNTY of LOS ANGELES, the crime oflDENTITY
THEFT in violation of Penal Code section 530.5(d)(l), a felony, was committed by TAMARA
DADYAN, RICHARD AYVAZYAN, ARTUR AYVAZYAN, LILIT MALYAN, ARTASHES
MARTIROSYAN, ROSA ZARATE, and ESTEPHANIE REYNOSO, who did willfully and
unlawfully with the intent to defraud sell, transfer, or convey the personal identifying information
of another person, to wit: ROGELIO V.'S NAME THROUGH THE USE OF A U.S. BANK
ACCOUNT HELD IN HIS NAME.
COUNT87
MORTGAGE FRAUD (Re: Rogelio V.)
19
On or about and between December 14, 2016, and July 31, 2017, in the COUNTY of LOS
20
ANGELES, the crime of MORTGAGE FRAUD in violation of Penal Code section 532f(a)(2), a
21
felony, was committed by TAMARA DADYAN, RICHARD AYVAZYAN, ARTUR
22
AYVAZYAN, LILIT MAL YAN, ARTASHES MARTIROSYAN, GRIGOR TATOIAN, ROSA
23
ZARA TE, and ESTEPHANIE REYNOSO, who did unlawfully and deliberately use or facilitate
24
the use of a misstatement, misrepresentation, or omission, with the knowledge it contained a
25
misstatement, misrepresentation, or omission, during the mortgage lending process, with the
26
intention that it be relied upon by a mortgage lender, borrower, or other party to the mortgage
27
lending process, to wit: CALIBER HOME LOANS. It is further alleged, pursuant to Penal Code
28
section 532fU), that the value of the fraud exceeds $950.
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COUNT 88
GRAND THEFT {Re: Rogelio V.)
On or about and between June 12, 2017, and July 31, 2017, in the COUNTY of LOS
ANGELES, the crime of GRAND THEFT in violation of Penal Code section 487(a), a felony, was
committed by TAMARA DADY AN, RICHARD AYVAZYAN, ARTUR AYVAZYAN, LILIT
MALYAN, ARTASHES MARTIROSYAN, GRIGOR TATOIAN, ROSA ZARATE, and
ESTEPHANIE REYNOSO, who did knowingly and designedly, by a false or fraudulent
representation or pretense, obtain money or real property by fraud from CALIBER HOME
LOANS, SPECIFICALLY, A $636,087 LOAN FOR 8150 DAY STREET IN SUNLAND,
CALIFORNIA, which had a value exceeding nine hundred fifty dollars ($95~
.Q -
COUNT 89
~
NLA WF L TRANSFER OF IDENTIFYING INFORMATION (Re: Rogelio V.)
On or about June 20, 2017, in the COUNTY of LOS ANGELES, the crime of IDENTITY
THEFT in violation of Penal Code section 530.5(d)(l), a felony, was committed by TAMARA
DADYAN, RICHARD AYVAZYAN, ARTUR AYVAZYAN, LILIT MAL YAN, ARTASHES
MARTIROSYAN, ROSA ZARATE, and ESTEPHANIE REYNOSO, who did willfully and
unlawfully with the intent to defraud sell, transfer, or convey the personal identifying information
of another person, to wit:
ROGELIO V.'S NAME, DEED OF TRUST, RECORDED
DOCUMENT NO. 20170852148.
COUNT90
@J
21
FORGERY RELATING TO IDENTITY THEFT (Re: Rogelio V.)
22
On or about June 20, 2017, in the COUNTY of LOS ANGELES, the crime of FORGERY in
23
violation of Penal Code section 470(b), a felony, was committed by TAMARA DADYAN,
24
RICHARD
AYVAZYAN,
ARTUR
AYVAZYAN,
LILIT
MALYAN,
ARTASHES
25
MARTIROSY AN, ROSA ZARA TE, and ESTEPHANIE REYNOSO, who with the intent to
26
defraud, counterfeited or forged the seal or handwriting of another in or on DEED OF TRUST,
27
RECORDED DOCUMENT NO. 20170852148.
Furthennore, the Defendants are charged in
28
COUNT 89 with identity theft, as defined in Penal Code section 530.5.
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2
3
4
5
6
7
8
9
10
II
12
13
14
15
16
17
18
COUNT91
PROCURING OR OFFERING FALSE OR FORGED INSTRUMENT (Re: Rogelio V.)
On or about June 20, 2017, in the COUNTY of LOS ANGELES, the crime of PROCURING
OR OFFERING A FALSE OR FORGED INSTRUMENT in violation of Penal Code section
115(a), a felony, was committed by TAMARA DADYAN, RICHARD AYVAZYAN, ARTUR
AYVAZYAN, LILIT MALYAN, ARTASHES MARTIROSYAN, ROSA ZARATE, and
ESTEPHANIE REYNOSO, who did unlawfully and knowingly procure or offer a false or forged
instrument to be filed, registered, or recorded in a public office in California, which instrument, if
genuine, might be filed, registered, or recorded under a law of California or the United States, to
wit: DEED OF TRUST, RECORDED DOCUMENT NO. 20170852148. ~
COUNT92
~
UNLAWFUL TRAN FER OF IDENTIFYING INFORMATION (Re: Rogelio V.)
On or about August 29, 2017, in the COUNTY of LOS ANGELES, the crime ofIDENTITY
THEFT in violation of Penal Code section 530.5(d)(l), a felony, was committed by TAMARA
DADYAN, RICHARD AYVAZYAN, ARTUR AYVAZYAN, LILIT MAL YAN, ARTASHES
MARTIROSYAN, GRIGOR TATOIAN, ROSA ZARATE, and ESTEPHANIE REYNOSO, who
did willfully and unlawfully with the intent to defraud sell, transfer, or convey the personal
identifying information of another person, to wit: ROGELIO V.'S NAME FOR A YGRENE
19
ENERGY FUND COMPLETION CERTIFICATE FOR 8150 DAY.
20
COUNT93
21
UNLAWFUL TRANSFER OF IDENTIFYING INFORMATION {Re: Rogelio V.)
22
On or about February 7, 2018, in the COUNTY of LOS ANGELES, the crime ofIDENTITY
23
THEFT in violation of Penal Code section 530.S(d)(l), a felony, was committed by TAMARA
24
DADYAN, RICHARD AYVAZYAN, ARTUR AYVAZYAN, LILIT MAL YAN, ARTASHES
25
MARTIROSYAN, GRIGOR TATOIAN, ROSA ZARATE, and ESTEPHANIE REYNOSO, who
26
did willfully and unlawfully with the intent to defraud sell, transfer, or convey the personal
27
identifying information of another person, to wit: ROGELIO V.'S NA.ME THROUGH THE USE
28
OF A YAHOO ACCOUNT IN HIS NAME.
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3
4
5
6
7
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25
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COUNT 94
UNLAWFUL TRANSFER OF IDE TIFYING INFORMATION {Re: Rogelio V.)
On or about March 20, 2018, in the COUNTY of LOS ANGELES, the crime ofIDENTITY
THEFT in violation of Penal Code section 530.5(d)(l), a felony, was committed by TAMARA
DADYAN, RICHARD AYVAZYAN, ARTUR AYVAZYAN, ANDRANIK PETROSYAN,
LILIT MALY AN, ARTASHES MARTIROSYAN, GRIGOR TATOIAN, ROSA ZARATE, and
ESTEPHANIE REYNOSO, who did willfully and unlawfully with the intent to defraud sell,
transfer, or convey the personal identifying information of another person, to wit: ROGELIO V.'S
NAME THROUGH THE TRANSFER OF CREDIT REPORT IN HIS NAME~
COUNT 95
~
UNLAWFUL TRANSFER OF IDENTIFYING INFORMATION (Re: Rogelio V.)
On or about March 25, 2018, in the COUNTY of LOS ANGELES, the crime ofIDENTITY
THEFT in violation of Penal Code section 530.S(d)(l), a felony, was committed by TAMARA
DADY AN, RICHARD A YV AZYAN, ARTUR AYVAZYAN, ANDRANIK PETROSYAN,
LILIT MALYAN, ARTASHES MARTIROSYAN, GRIGOR TATOIAN, ROSA ZARATE, and
ESTEPHANIE REYNOSO, who did willfully and unlawfully with the intent to defraud sell,
transfer, or convey the personal identifying information of another person, to wit: ROGELIO V.'S
NAME THROUGH THE TRANSFER OF DRIVER'S LICENSE IN HIS N~
COUNT96
~
UNLAWFUL TRANSFER OF IDENTIFYING INFORMATION (Re: Rogelio V.)
On or about June 5, 2018, in the COUNTY of LOS ANGELES, the crime ofIDENTITY
THEFT in violation of Penal Code section 530.S(d)(l), a felony, was committed by TAMARA
DADYAN, RICHARD AYVAZYAN, ARTUR AYVAZYAN, ANDRANIK PETROSYAN,
LILIT MALY AN, ARTASHES MARTIROSYAN, GRIGOR TATOIAN, ROSA ZARATE, and
ESTEPHANIE REYNOSO, who did willfully and unlawfully with the intent to defraud sell,
transfer, or convey the personal identifying information of another person, to wit: ROGELIO V.' S
Ni\ME THROUGH THE TRANSFER OF A DRIVER'S LICENSE IN HIS NAME.
II
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COUNT97
2
UNLAWFUL TRANSFER OF IDENTIFYCNG INFORMATION (Re: Rogelio V.)
3
On or about January 23, 2020, in the COUNTY of LOS ANGELES, the crime of IDENTITY
4
THEFT in violation of Penal Code section 530.5(d)(l), a felony, was committed by TAMARA
5
DADY AN, RICHARD A YVAZY AN, ARTUR A YV AZY AN, ANDRANIK PETROSYAN,
6
LILIT MAL YAN, ARTASHES MARTIROSYAN, GRIGOR TATOIAN, ROSA ZARATE, and
7
ESTEPHANIE REYNOSO, who did willfully and unlawfully with the intent to defraud sell,
8
transfer, or convey the personal identifying information of another person, to wit: AMENDED
9
COMPLAINT IN CENTRAL DISTRICT OF CALIFORNIA CASE NO. 2:19-CV-~,·IC'"'.
10
COUNT 98
11
FORGERY RELATING TO IDENTITY THEFT
12
On or about January 23, 2020, in the COUNTY of LOS ANGELES, the crime of FORGERY
13
in violation of Penal Code section 470(b), a felony, was committed by TAMARA DADYAN,
14
RICHARD AYVAZYAN, ARTUR AYVAZYAN, ANDRANIK PETROSYAN,
LILIT
15
MAL YAN, ARTASHES MARTIROSYAN, ROSA ZARATE, and ESTEPHANIE REYNOSO,
16
who with the intent to defraud, counterfeited or forged the seal or handwriting of another in or on
17
AMENDED COMPLAINT IN CENTRAL DISTRICT OF CALIFORNIA CASE NO. 2:19-CV-
18
9897. Furthermore, the Defendants are charged in COUNT 97 with identity theft, as defined in
19
Penal Code section 530.5.
20
COUNT99
21
PROCURING OR OFFERING FALSE OR FORGED INSTRUMENT (Re: Rogelio V.)
22
On or about January 23, 2020, in the COUNTY of LOS ANGELES, the crime of
23
PROCURING OR OFFERING A FALSE OR FORGED INSTRUMENT in violation of Penal
24
Code section l 15(a), a felony, was committed by TAMARA DADY AN, RICHARD A YV AZYAN,
25
ARTUR
AYVAZYAN,
ANDRANIK
PETROSYAN,
LILIT
MALYAN,
ARTASHES
26
MARTIROSYAN, GRIGOR TATOIAN, ROSA ZARATE, and ESTEPHANIE REYNOSO, who
27
did unlawfully and kno\.vingly procure or offer a false or forged instrument to be filed, registered,
28
or recorded in a public office in California, which instrument, if genuine, might be filed, registered,
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1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
or recorded under a law of California or the United States, to wit: AMENDED COMPLAINT IN
@)
CENTRAL DISTRICT OF CALIFORNIA CASE NO. 2:19-CV-9897.
COUNT 100
CONSPIRACY TO COMMIT GRAND THEFT (Re: Melanva A.)
On or about and between May 11, 2016 and December 20, 2019, in the COUNTY of LOS
ANGELES, the crime of CONSPIRACY, in violation of Penal Code section 182(a)(l), a felony,
was committed by TAMARA DADYAN, RICHARD AYVAZYAN, GRJGOR TATOIAN,
ARTASHES MARTIROSYAN, ARSHAK BARTOUMIAN, ESTEPHANIE REYNOSO, and
ROSA ZARA TE, who did willfully and unlawfully conspire together with another person or
persons whose identity is known or unknown to commit the crime of GRAND THEFT BY FALSE
PRETENSES, 487(a), of the California Penal Code, a felony, pursuant to and for the purpose of
carrying out the objects and purposes of the aforesaid conspiracy, Defendants committed the
following overt act(s):
OVERT ACT 1
On or about May 11, 2016, Tamara DADY AN, posing as Melanya A., emailed Equity Fund
Financial, Inc. and stated "Here are the documents you requested," and attached a Wells Fargo bank
statement in the name of Melanya A, an image of a driver's license in the name of Melany a A.,
and an image of a social security number in the name of Melanya A.
OVERT ACT 2
On or about July 28, 2016, Tamara DADY AN emailed Grigor TA TOIAN a 2016 Corporation
Estimated Tax and stated, "Can u do a Corp resolution ASAP for westlake please adding Melanya
a[.] and adeliya T[.] as both interest holders please say treasure and ceo something like that."
OVERT ACT 3
On or about July 28, 2016, Grigor TATOIAN replied to Tamara DADYAN's email regarding
the corporation resolution and asked, "Got it. Still using the same investors?"
OVERTACT4
On or about July 30, 2016, Grigor TATOIAN emailed Tamara DA.DYAN and attached a
"Corporate Resolution" listing Melanya A. as the director and secretary of Adeliya Timirova
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Investments, Inc. in relation to the purchasing of 3520 Ridgeford Drive, Westlake Village,
2
California.
3
OVERT ACT 5
4
On or about September 6, 2016, Tamara DADY AN used Melanya A.' s name on a Grant Deed
5
transferring the property located at 3520 Ridgeford Drive, Westlake Village, California from AAA
6
Electronical Engineering, Inc. to Melanya A.
7
OVERTACT6
8
On or about September 9, 2016, Richard A YV AZY AN, Estephanie REYNOSO, and Rosa
9
ZARA TE submitted a Y grene Energy Fund completion certificate in the name of Melanya A. for
10
purported improvements to the property at 6556 Andasol Avenue, Van Nuys, California in the
11
amount of $86,627.
12
OVERT ACT 7
13
On or about October 28, 2016, Richard A YV AZY AN, Estephanie REYNOSO, and Rosa
14
ZARATE submitted a Renew Funding completion certificate in the name of Melanya A. for
15
purported improvements to the property at 6556 Andasol Avenue in Van Nuys, California, in the
16
amount of $47,356.
17
OVERT ACT 8
18
On or about December 11, 2016, Tamara DADYAN forwarded Richard AYVAZYAN an
19
email from Lubia CARRILLO with the subject, "a[.] loan docs," attached unsigned mortgage loan
20
documents in the name of Melanya A. and in the amount of $800,000, for the property at 3520
21
Ridgeford Drive, Westlake Village, California, and stated, "Apply for this on a rush."
22
OVERT ACT 9
23
On or about February 2, 2017, Tamara DADYAN forwarded an email to Richard
24
A YV AZYAN with the subject, "Westlake melan Fwd: Ridgeford 1003," attached with a refinance
25
loan application containing Melanya A. 's name, date of birth, and social security number for the
26
property at 3520 Ridgeford Drive, Westlake Village, California 91361, and stated, "Her password
27
is Hoparl910 I get al! her emails sou can give me heads up."
28
//
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1
OVERT ACT 10
2
On or about March 20, 2017, Tamara DADY AN used Corrie S.'s name and notary stamp on
3
a Grant Deed transferring the property located at 6556 Andasol Avenue in Van Nuys, California
4
from Melanya A to Andrew A, Trustee of the Andasol Family Trust.
5
OVERT ACT 11
6
On or about April 3, 2017, Tamara DADY AN emailed Richard A YV AZYAN with the
7
subject, "Keep in mind 6556 andasol is in her name only," and attached a credit report containing
8
Melanya A.' s name, date of birth, and social security number.
9
OVERT ACT 12
10
On or about April 7, 2017, Tamara DADYAN emailed Richard AYVAZYAN with the
11
subject, "A[.] Melanya DL And SSN," and attached images of a driver's license and a social
12
security number card in the name of Melanya A
13
OVERT ACT 13
14
On or about April 18, 2017, Tamara DADYAN emailed Richard AYVAZYAN with the
15
subject, "Pending that I remember," and provided a list of pending deals, including "Melanya -
16
westlake."
17
OVERT ACT 14
18
On or about May 23, 2017, Richard AYVAZYAN, Estephanie REYNOSO, and Rosa
19
ZARA TE submitted a Renew Funding completion certificate in the name of Melany a A for
20
purported improvements to the property at 3520 Ridgeford Drive, Westlake Village, California in
21
the amount of $144,200.
22
OVERT ACT 15
23
On or about November 1, 2017, Tamara DADY AN forwarded herself an email that was sent
24
from an escrow officer to a Mail.com email address in the name of Melanya A, requesting the
25
signature and completion of escrow documents in the name of Melanya A. for the property at 3520
26
Ridgeford Drive, Westlake Village, California, and a blank grant deed transferring the same
27
property from Melanya A. to Anna D.
28
//
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1
OVERT ACT 16
2
On or about November 3, 2017, Grigor TATOIAN emailed Tamara DADYAN with the
3
subject, "Westlake NOD," and attached Notices of Default addressed to Melanya A. and for the
4
property at 3520 Ridgeford Drive, Westlake Village, California.
5
OVERT ACT 17
6
On or about November 27,2017, Tamara DADY AN, posing as Melanya A., emailed Renew
7
Funding requesting transfer and release documents and attached a Notice of Assessment in the
8
name of Melanya A. for the property at 3520 Ridgeford Drive, Westlake Village, California.
9
OVERT ACT 18
10
On or about January 16, 2018, Artashes MARTIROSYAN emailed Tamara DADYAN
11
escrow and realty documents in the name of Melanya A. related to the sale of 3520 Ridgeford
12
Drive, Westlake Village, California, and stated, "For Ridgeford."
13
OVERT ACT 19
14
On or about January 17, 2018, Grigor TATOIAN emailed Tamara DADYAN with the
15
subject, "Received today Westlake," and attached a Motion for Relief from the Automatic Stay and
16
related documents for a bankruptcy case in the name of Melany a A.
17
OVERT ACT 20
18
On or about January 19, 2018, Tamara DADYAN forwarded the email from Grigor
19
TATOIAN regarding the Motion for Relief from the Automatic Stay to Arshak BARTOUMIAN
20
and asked, "What u think of this?"
21
OVERT ACT 21
22
On or about January 19, 2018, ArshakBARTOUMIAN replied to Tamara DADYAN's email
23
and stated, "Is it does the same thing that they filed already and sent over."
24
OVERT ACT 22
25
On or about January 24, 2018, Arshak BARTOUMIAN emailed Tamara DADY AN a
26
Bankruptcy Petition and a Notice of Dismissal in the name of Melanya A.
27
OVERT ACT 23
28
On or about January 26, 2018, Artashes MARTIROSYAN replied to Tamara DADY AN with
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1
the subject, "Adamian - red'x.PDF," attached unsigned and not filed bankruptcy documents in the
2
name of Melany a A., and stated "ok here."
3
OVERT ACT 24
4
On or about January 29, 2018, Tamara DADY AN filed a Bankruptcy Petition in the name of
5
Melanya A.
6
OVERT ACT 25
7
On or about February 20, 2018, Artashes MARTIROSYAN emailed Tamara DADY AN with
8
the subject, "Ridgeford," and attached financial, realty, and escrow documents containing the
9
names and signatures of Melanya A. and Anna D.
10
OVERT ACT 26
11
On or about February 27, 2018, in response to Tamara DADYAN's email with the subject,
12
"Ridgeford," and stating, "Art u don't have January Wells Fargo," Artashes MARTIROSYAN
13
responded, "Sitting here for a week. Need to go over."
14
OVERT ACT 27
15
On or about March 20, 2018, Tamara DADYAN emailed Artashes MARTIROSYAN and
16
attached images of a driver's license and a social security number card in the name ofMelanya A.
17
OVERT ACT 28
18
On or about March 23, 2018, Tamara DADY AN emailed escrow and lender officers with the
19
subject, "Here si q copy of the documents," and attached multiple documents containing Melanya
20
A.' s name, signatures, and initials.
21
OVERT ACT 29
22
On or about March 26, 2018, Tamara DADYAN emailed a lending group and a Mail.com
23
email address in the name ofMelanya A., Renew Funding documents in the name and signature of
24
Melanya A., for 3520 Ridgeford Drive, Westlake Village, California, and stated, "This is what I
25
have the signed documents on ridgeford from seller."
26
OVERT ACT 30
27
On or about April 11, 2018, Tamara DA.DYAN emailed an escrow officer escrow documents
28
in the names and signatures of Melanya A. and Anna D., and for the property at 3520 Ridgeford
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1
Drive, Westlake Village, California.
2
OVERT ACT 31
3
On or about April 11, 2018, Tamara DADYAN emailed Grigor TATOIAN a Short Form
4
Deed of Trust and Assignment of Rents in the name of Melanya A. and for the property at 3520
5
Ridgeford Drive, Westlake Village, California.
6
OVERT ACT 32
7
On or about June 7, 2018, Tamara DADYAN emailed Grigor TATOIAN a Trustee's Deed
8
Upon Sale for the sale of the property at 3520 Ridgeford Drive, Westlake Village, California, which
9
listed Melanya A. as the previous owner.
10
OVERT ACT 33
11
On or about March 21, 2019, Tamara DADY AN forwarded herself an email that she sent to
12
Renew Funding on November 28, 2017, posing as Melanya A., requesting transfer and release
13
documents attached with a Notice of Assessment in the name of Melanya A. for the property at
14
3520 Ridgeford Drive, Westlake Village, California.
15
OVERT ACT 34
16
On or about December 20, 2019, Tamara DADYAN used Adam S.'s name on a Grant Deed
17
transferring the property located at 3520 Ridgeford Drive, Westlake Village, California, from
18
Melanya A. to Anna D.
19
COUNT 101
20
UNLAWFUL TRANSFER OF IDENTIFYING INFORMATION (Re: Melanya A.)
21
On or about May 23, 2017, in the COUNTY of LOS ANGELES, the crime of IDENTITY
22
THEFT in violation of Penal Code section 530.5(d)(l), a felony, was committed by TAMARA
23
DADYAN, RICHARD AYVAZYAN, GRIGOR TATOIAN, ESTEPHANIE REYNOSO, and
24
ROSA ZARA TE, who did willfully and unlawfully with the intent to defraud sell, transfer, or
25
convey the personal identifying information of another person, to wit: MELANYA A.'S NAME
26
ON A RENEW FUNDING COMPLETION CERTIFICATE FOR 3520 RIDGEFORD.
27
II
28
II
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COUNT 102
2
FORGERY RELATING TO IDENTITY THEFT {Re: Melanya A.)
3
On or about May 23, 2017, in the COUNTY of LOS ANGELES, the crime of FORGERY in
4
violation of Penal Code section 470(a), a felony, was committed by TAMARA DADYAN,
5
RICHARD AYVAZYAN, GRIGOR TATOIAN, £STEPHANIE REYNOSO, and ROSA
6
ZARA TE, who with the intent to defraud, signed the name of another person or of a fictitious
7
person to A CONTRACT IN THE NAME OF MELANY A A., SPECIFICALLY A RENEW
8
FUNDING COMPLETION CERTIFICATE, knowing that they had no authority to do so.
9
Furthermore, the Defendants are charged in COUNT 101 with identity theft, as defined in Penal
10
Code section 530.5.
11
COUNT 103
12
UNLAWFUL TRANSFER OF IDENTIFYING INFORMATION (Re: Melanya A.)
13
On or about December 1, 2017, in the COUNTY ofLOS ANGELES, the crime oflDENTITY
14
THEFT in violation of Penal Code section 530.5(d)(l), a felony, was committed by TAMARA
15
DADYAN, RICHARD AYVAZYAN, GRIGOR TATOIAN, £STEPHANIE REYNOSO, and
16
ROSA ZARA TE, who did willfully and unlawfully with the intent to defraud sell, transfer, or
17
convey the personal identifying information of another person, to wit: BANKRUPTCY PETITION
18
IN THE NAME OF MELANY A A.
19
COUNT 104
20
FORGERY RELATING TO IDE TITY THEFT (Re: Melanva A.)
21
On or about December 1, 2017, in the COUNTY ofLOS ANGELES, the crime of FORGERY
22
in violation of Penal Code section 470(b), a felony, was committed by TAMARA DADY AN,
23
RICHARD AYVAZYAN, GRIGOR T{\TOIAN, ESTEPHANIE REYNOSO, and ROSA
24
ZARA TE, who with the intent to defraud, counterfeited and/or forged the seal or handwriting of
25
another in or on A BANKRUPTCY PETITION IN THE NAME OF MELANY A A. Furthermore,
26
the Defendants are charged in COUNT 103 with identity theft, as defined in Penal Code section
27
530.5.
28
//
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COUNT 105
2
PROCURING OR OFFERING FALSE OR FORGED INSTRUMENT (Re: Melanya A.)
3
On or about December 1, 2017, in the COUNTY of LOS ANGELES, the crime of
4
PROCURING OR OFFERING A FALSE OR FORGED INSTRUMENT in violation of Penal
5
Code section 115(a), a felony, was committed by TAMARA DADY AN, RICHARD A YV AZYAN,
6
GRIGOR TATOIAN, ESTEPHANIE REYNOSO, and ROSA ZARATE, who did unlawfully and
7
knowingly procure or offer a false or forged instrument to be filed, registered, or recorded in a
8
public office in California, which instrument, if genuine, might be filed, registered, or recorded
9
under a law of California or the United States, to wit: BANKRUPTCY PETITION IN THE NAME
10
OF MELANYA A.
11
COUNT 106
12
UNLAWFUL TRANSFER OF IDENTIFYING INFORMATION (Re: Melanya A.)
13
On or about January 29, 2018, in the COUNTY of LOS ANGELES, the crime ofIDENTITY
14
THEFT in violation of Penal Code section 530.5(d)(l), a felony, was committed by TAMARA
15
DADYAN, RICHARD AYVAZYAN, GRIGOR TATOIAN, ARTASHES MARTIROSYAN,
16
ARSHAK BARTOUMIAN, ESTEPHANIE REYNOSO, and ROSA ZARA TE, who did willfully
17
and unlawfully with the intent to defraud sell, transfer, or convey the personal identifying
18
information of another person, to wit:
BANKRUPTCY PETITION IN THE NAME OF
19
MELANY A A.
20
COUNT 107
21
FORGERY RELATING TO IDENTITY THEFT (Re: Melanya A.)
22
On or about January 29, 2018, in the COUNTY of LOS ANGELES, the crime of FORGERY
23
in violation of Penal Code section 470(b), a felony, was committed by TAMARA DADYAN,
24
RICHARD AYVAZYAN, GRIGOR TATOIAN, ARTASHES MARTIROSYAN, ARSHAK
25
BARTOUMIAN, ESTEPHANIE REYNOSO, and ROSA ZARA TE, who with the intent to
26
defraud, counterfeited and/or forged the seal or handwriting of another in or on a BANKRUPTCY
27
PETITION IN THE NAME OF MELANYA A. Furthermore, the Defendants are charged in
28
COUNT 106 with identity theft, as defined in Penal Code section 530.5.
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COUNT 108
@
2
PROCURI G OR OFFERING FALSE OR FORGED INSTRUME T {Re: Melanya A.)
3
On or about January 29, 2018, in the COUNTY of LOS ANGELES, the crime of
4
PROCURING OR OFFERING A FALSE OR FORGED INSTRUMENT in violation of Penal
5
Code section 115(a), a felony, was committed by TAMARA DADY AN, RICHARD A YV AZYAN,
6
GRIGOR
TATOIAN,
ARTASHES
MARTIROSYAN,
ARSHAK
BARTOUMIAN,
7
8
9
10
11
12
13
14
15
16
17
18
ESTEPHANIE REYNOSO, and ROSA ZARA TE, who did unlawfully and knowingly procure or
offer a false or forged instrument to be filed, registered, or recorded in a public office in California,
which instrument, if genuine, might be filed, registered, or recorded under a law of California or
the United States, to wit: BANKRUPTCY PETITION IN THE NAM~~ANY A A.
COUNT109
~
UNLAWFUL TRANSFER OF IDENTIFYING INFORMATION (Re: Melanya A.)
On or about February 20, 2018, in the COUNTY of LOS ANGELES, the crime ofIDENTITY
THEFT in violation of Penal Code section 530.5(d)(l), a felony, was committed by TAMARA
DADYAN, RICHARD AYVAZYAN, GRIGOR TATOIAN, ARTASHES MARTIROSYAN,
ARSHAK BARTOUMIAN, £STEPHANIE REYNOSO, and ROSA ZARA TE, who did willfully
and unlawfully with the intent to defraud sell, transfer, or convey the personal identifying
information of another person, to wit: A RESIDENTIAL PURCHASE AGREEMENT IN THE
19
NAME OF MELANYA A.
20
COUNT 110
21
FORGERY RELATING TO IDENTITY THEFT (Re: Melanya A.)
22
Onor about February 20, 2018, in the COUNTY ofLOS ANGELES, the crime ofFORGERY
23
in violation of Penal Code section 470(a), a felony, was committed by TAMARA DADYAN,
24
RICHARD AYVAZYAN, GRIGOR TATOIAN, ARTASHES MARTIROSYAN, ARSHAK
25
BARTOUMIAN, ESTEPHANIE REYNOSO, and ROSA ZARA TE, who with the intent to
26
defraud, signed the name of another person or of a fictitious person to a contract to convey any real
27
property, specifically A RESIDENTIAL PURCHASE AGREEMENT IN THE NAME OF
28
MELANY A A., knowing that they had no authority to do so. Furthermore, the Defendants are
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l
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
charged in COUNT 109 with identity theft, as defined in Penal Code s c~.
COUNTlll
~
UNLAWFUL TRANSFER OF IDENTIFYING INFORMATION (Re: Melanva A.)
On or about March 20, 2018, in the COUNTY of LOS ANGELES, the crime of IDENTITY
THEFT in violation of Penal Code section 530.S(d)(l), a felony, was committed by TAMARA
DADYAN, RICHARD AYVAZYAN, GRIGOR TATOIAN, ARTASHES MARTIROSYAN,
ARSHAK BARTOUMIAN, ESTEPHANIE REYNOSO, and ROSA ZARATE, who did willfully
and unlawfully with the intent to defraud sell, transfer, or convey the personal identifying
information of another person, to wit: A DRIVER'S LICENSE AND SOCIAL SECURITY CARD
IN THE NAME, DATE OF BIRTH, AND SOCIAL SECURITY NUMBER~F
I
NY A A.
COUNT 112
J& 'J
UNLAWFUL TRANSFER OF IDENTIFYING INFORMATION (
.
elanya A.)
On or about March 23, 2018, in the COUNTY of LOS ANGELES, the crime ofIDENTITY
THEFT in violation of Penal Code section 530.S(d)(l), a felony, was committed by TAMARA
DADYAN, RICHARD AYVAZYAN, GRIGOR TATOIAN, ARTASHES MARTIROSYAN,
ARSHAK BARTOUMIAN, ESTEPHANIE REYNOSO, and ROSA ZARA TE, who did willfully
and unlawfully with the intent to defraud sell, transfer, or convey the personal identifying
information of another person, to wit: MELANY A A.' S NAME ON A GRANT DEED FOR 3 520
RIDGEFORD DRIVE, WESTLAKE VILLAGE, CALIFORNIA, FROM AAA ELECTRONICAL
20
ENGINEERING, INC. TO MELANY A A.
21
COUNT 113
22
UNLAWFUL TRANSFER OF IDENTIFYING INFORMATION (Re: Melanya A.)
23
On or about March 26, 2018, in the COUNTY of LOS ANGELES, the crime ofIDENTITY
24
THEFT in violation of Penal Code section 530.S(d)(l), a felony, was committed by TAMARA
25
DADYAN, RICHARD AYVAZYAN, GRIGOR TATOIAN, ARTASHES MARTIROSYAN,
26
ARSHAK BARTOUMIAN, ESTEPHANIE REYNOSO, and ROSA ZARATE, who did willfully
27
and unlawfully with the intent to defraud sell, transfer, or convey the personal identif1ing
28
information of another person, to wit: A RENEW FUNDING CONTRACT IN THE NAME OF
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2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
MELANY AA.
COUNT 114
@)
UNLAWFUL TRANSFER OF IDENTIFYING INFORMATION (Re: Melanva A.)
On or about April 11, 2018, in the COUNTY of LOS ANGELES, the crime of IDENTITY
THEFT in violation of Penal Code section 530.5(d)(l), a felony, was committed by TAMARA
DADYAN, RICHARD AYVAZYAN, GRIGOR TATOIAN, ARTASHES MARTIROSYAN,
ARSHAK BARTOUMIAN, ESTEPHANIE REYNOSO, and ROSA ZARA TE, who did willfully
and unlawfully with the intent to defraud sell, transfer, or convey the personal identifying
information of another person, to wit: FEDERAL ESCROW, INC. DOCUMENTS IN THE NAME
~
OF MELANY A A.
COUNT 115
FORGERY RELATING TO IDENTITY THEFf (Re: Melanya A.)
On or about April 11, 2018, in the COUNTY of LOS ANGELES, the crime of FORGERY
in violation of Penal Code section 470(a), a felony, was committed by TAMARA DADYAN,
RICHARD AYVAZYAN, GRlGOR TATOIAN, ARTASHES MARTIROSYAN, ARSHAK
BARTOUMIAN, ESTEPHANIE REYNOSO, and ROSA ZARATE, who with the intent to
defraud, signed the name of another person or of a fictitious person to ESCROW DOCUMENTS
TO CONVEY ANY REAL PROPERTY, SPECIFICALLY FEDERAL ESCROW, INC.
DOCUMENTS IN THE NAME OF MELANY A A., knowing that they had no authority to do so.
Furthermore, the Defendants are charged in COUNT 114 with identity theft, as defined in Penal
21
Code section 530.5.
22
COUNT 116
23
UNLAWFUL TRANSFER OF IDENTIFYING INFORMATION (Re: Melanya A.)
24
On or about December 20, 2019, in the COUNTY of LOS ANGELES, the crime of
25
IDENTITY THEFT in violation of Penal Code section 530.S(d)(l), a felony, was committed by
26
TAMARA
DADYAN,
RICHARD
AYVAZYAN,
GRIGOR
TATOIAN,
ARTASHES
27
MARTIROSYAN, ARSHAK BARTOUMIAN, ESTEPHANIE REYNOSO, and ROSA
28
ZARA TE, who did willfully and unlawfully with the intent to defraud sell, transfer, or convey the
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1
personal identifying information of another person, to wit: RECORDED DOCUMENT NO.
2
20191423545 IN THE NAME OF MELANY A A.
3
COUNT 117
4
5
6
7
8
9
10
11
12
13
14
15
16
17
FORGERY RELATING TO IDENTITY THEFT (Re: Melanya A.)
On or about December 20, 2019, in the COUNTY of LOS ANGELES, the crime of
FORGERY in violation of Penal Code section 470(a), a felony, was committed by TAMARA
DADYAN, RICHARD AYVAZYAN, GRIGOR TATOIAN, ARTASHES MARTIROSYAN,
ARSHAK BARTOUMIAN, ESTEPHANIE REYNOSO, and ROSA ZARATE, who with the
intent to defraud, signed the name of another person or of a fictitious person to CONVEY ANY
REAL PROPERTY, SPECIFICALLY RECORDED DOCUMENT NO. 20191423545 IN THE
NAME OF MELANY A A., knowing that they had no authority to do so. Furthermore, the
Defendants are charged in COUNT 116 with identity theft, as defined in Penal ~~~t1 530.5.
COUNT118
~
PROCURING OR OFFERING FALSE OR FORGED INSTR MENT (Re: Melaoya A.)
On or about December 20, 2019, in the COUNTY of LOS ANGELES, the crime of
PROCURING OR OFFERING A FALSE OR FORGED INSTRUMENT in violation of Penal
Code section 115(a), a felony, was committed by TAMARA DADY AN, RICHARD A YV AZYAN,
18
GRIGOR
TATOIAN,
ARTASHES
MARTIROSYAN,
ARSHAK
BARTOUMIAN,
19
ESTEPHANIE REYNOSO, and ROSA ZARA TE, who did unlawfully and knowingly procure or
20
offer a false or forged instrument to be filed, registered, or recorded in a public office in California,
21
which instrument, if genuine, might be filed, registered, or recorded under a law of California or
22
the United States, to wit: RECORDED DOCUMENT NO. 20191423545 IN THE NAME OF
23
MELANY A A.
24
COUNT 119
25
CONSPIRACY TO COMMIT GRAND THEFT (Re: Vahan T.)
26
On or about and between February 6, 2015 and August 27, 2018, in the COUNTY of LOS
27
ANGELES, the crime of CONSPIRACY, in violation of Penal Code section 182(a)(l ), a felony,
28
was committed by TAMARA DADYAN, RICHARD AYVAZYAN, ARTUR AYVAZYAN,
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1
ESTEPHANIE REYNOSO, and ROSA ZARA TE, who did willfully and unlawfully conspire
2
together with another person or persons whose identity is known or unknown to commit the crime
3
of GRAND THEFT BY FALSE PRETENSES, 487(a), of the California Penal Code, a felony,
4
pursuant to and for the purpose of carrying out the objects and purposes of the aforesaid conspiracy,
5
Defendants committed the following overt act(s):
6
OVERT ACT 1
7
On or about February 6, 2015, Artur A YV AZYAN appeared as Vahan T. for a notarization
8
of a Deed of Trust for $341,600 requested by Val-Chris Investments, Inc.
9
OVERT ACT2
10
On or about January 5, 2016, Richard A YV AZYAN, posing as Vahan T., emailed a
11
homeowners association and stated, "Please change the mailing address of my account ... New
12
Address: 22330 Victory Blvd #303, Woodland Hills, CA 91367."
13
OVERT ACT 3
14
On or about February 3, 2016, in response to a funding specialist, Richard AYVAZYAN,
15
posing as Vahan T., emailed Bank of America account statements ending in -6898 and a funding
16
application in the names of Vahan T.
17
OVERT ACT 4
18
On or about February 8, 2016, Richard A YV AZYAN, posing as Vahan T., emailed a lender
19
a credit report in the name of Vahan T. and stated, "Please see my credit report attached."
20
OVERT ACT 5
21
On or about February 24, 2016, in response to the lender, Richard A YV AZYAN, posing as
22
Vahan T., emailed a credit report in the name of Mariam T. and stated, "I had no clue of the
23
derogatory items that you found on my credit. I am in the process of trying to remove those items
24
from my credit profile. In the meanwhile .. .I am attaching my sisters credit report for your review."
25
OVERT ACT 6
26
On or about March 16, 2016, Richard A YV AZY AN, posing as Vahan T., emailed a lender a
27
loan modification agreement in the name of Vahan T. and stated, "Please see attached signed Loan
28
Modification Agreement. I will put the original in the mail today."
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1
OVERTACT7
2
On or about April 11, 2016, Richard A YV AZYAN, posing as Vahan T., emailed Tamara
3
DADY AN and an escrow officer an invoice in the name of Vahan T. with the subject, "22330
4
Victory Blvd #303," and stated, "Here is a copy of my last mortgage payment from Loan Oak
5
Fund."
6
OVERT ACT 8
7
On or about May 10, 2016, Richard A YV AZYAN, posing as Vahan T., emailed the escrow
8
officer, "Thank you for sending me the estimate. Sure, I will then contact Tammy to get the rest of
9
the documents signed."
10
OVERT ACT 9
11
On or about May 11, 2016, Richard A YVAZYAN, posing as Vahan T., forwarded Tamara
12
DADY AN an email from an escrow officer, attached a blank Quitclaim Deed in the name of Vahan
13
T. for the property at 22330 Victory Boulevard, #303, Woodland Hills, California 91302, and
14
stated, "Tam I just got this from escrow. Can u have the girls notarize this please. I'm not in the
15
office."
16
OVERT ACT 10
17
On or about May 13, 2016, Tamara DADY AN, Estephanie REYNOSO, and Rosa ZARATE
18
used Vahan T.'s name and Anthony A.'s name on a Grant Deed transferring the property at 22330
19
Victory Boulevard, #303, Woodland Hills, California 91302 from Vahan T. to Anthony A.
20
OVERT ACT 11
21
On or about July 28, 2016, Richard A YV AZY AN, posing as Vahan T., requested that Rogelio
22
V. be added as an authorized user for a Chase bank account ending in -3852 in the name of Vahan
23
T.
24
OVERT ACT 12
25
On or about August 1, 2016, Richard AYVAZYAN, Estephanie REYNOSO, and Rosa
26
ZARA TE wired $210,000 from a Bank of America account ending in -6529 in the name of Andrew
27
A. to a Bank of An1erica account ending in -6898 in the name ofVahan T.
28
//
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1
OVERT ACT 13
2
On or about August 1, 2016, Richard AYVAZYAN, Estephanie REYNOSO, and Rosa
3
ZARATE wired $100,900 from a Bank of America account ending in -6898 in the name ofVahan
4
T. into a Bank of America account ending in -4999 in the name of Vahan T.
5
OVERT ACT 14
6
On or about August 15, 2016, Richard AYV AZYAN, posing as Vahan T., emailed himself
7
posing as Sarkis B., recommending Sarkis B. and Savs Enterprise as a contractor for home
8
improvement.
9
OVERT ACT 15
10
On or about October 4, 2016, Richard A YV AZY AN, using the email address
11
vahant818@yahoo.com, sent an email to the savsenterprise@yahoo.com email address and stated,
12
"Need to talk. Call me."
13
OVERT ACT 16
14
On or about January 10, 2017, Richard AYVAZYAN emailed Tamara DADYAN a Grant
15
Deed transferring the property at 22330 Victory Boulevard, #303, Woodland Hills, California
16
91302 from Vahan T. to Anthony A., with the subject, "Grant Deed for moms condo."
17
OVERT ACT 17
18
On or about January 20, 2017, Richard A YV AZY AN emailed VIP Tickets Sherman Oaks
19
payment confirmation of Los Angeles Laker's tickets, a credit card, and a driver's license with
20
Artur A YVAZYAN's picture, in the name ofVahan T.
21
OVERT ACT 18
22
On or about March 8, 2017, Richard A YV AZYAN, posing as Anthony A., emailed Level 3
23
Homes a lease agreement for the property at 5141 Genesta Avenue in Encino, California, and listed
24
Vahan T. as a tenant with Vahan T.' s signature.
25
OVERT ACT 19
26
On or about March 15, 2017, Richard AYVAZYAN emailed Tamara DADYAN with the
27
subject, "Checks," and attached two images of checks labeled "Cancelled Check[s]," in the name
28
ofVahan T.
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1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
OVERT ACT20
On or about June 26, 2017, Richard A YV AZYAN, from the vahant8l8@yahoo.com email,
sent a payment confirmation of $17,500 from a Bank of America account ending in -4999 in the
name of Vahan T. regarding a down payment for the property at 7106 Jellico Avenue, Van Nuys,
Los Angeles, California, in the name of Armen I.
OVERT ACT21
On or about September 26, 2017, Richard A YV AZY AN purchased two roundtrip airline
tickets from Los Angeles, California to Rome, Italy using a Chase credit card ending in -3852 in
the name of Vahan T.
OVERT ACT22
On or about August 27, 2018, in response to American Express's Global Security
Investigations, Richard A YV AZYAN, posing as Vahan T., stated, "I appreciate your being bluntly
and addressing your concerns. Unfortunately, I can not speak with Rich [Ayvazyan] because he
passed away from a car accident about 5 months ago (writing this with teary eyes). If you do have
some suspicion on any of those charges and do think that he might have deceived/tricked me' about
it. I would not be able to get to the bottom of it. I am heart broken as it is with his passing and
would appreciate that you can understand the situation."
COUNT120
@
MONEY LAUNDERING {Re: Vahan T.)
On or about June 29, 2017, in the COUNTY of LOS ANGELES, the crime of MONEY
LAUNDERING in violation of Penal Code section 186.I0(a), a felony, was committed by
TAMARA DADYAN, RICHARD AYVAZYAN, ARTUR AYVAZYAN, ESTEPHANIE
REYNOSO, and ROSA ZARA TE, who did unlawfully conduct transactions involving monetary
instruments of a value exceeding $25,000, through a financial institution knowing that the monetary
instruments represented the proceeds of, and was derived directly or indirectly from the proceeds
of, criminal activity, to wit: $44,000 THROUGH ONE TRANSACTION.
II
II
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#:4480
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
COUNT 121
UNLAWFUL TRANSFER OF IDENTIFYING INFORMATION (Re: Vahan T.)
On or about September 26, 2017, in the COUNTY of LOS ANGELES, the crime of
IDENTITY THEFT in violation of Penal Code section 530.5(d)(l), a felony, was committed by
TAMARA DADYAN, RICHARD AYVAZYAN, ARTUR AYVAZYAN, ESTEPHANIE
REYNOSO, and ROSA ZARA TE, who did willfully and unlawfully with the intent to defraud sell,
transfer, or convey the personal identifying information of another person, to wit: A CHASE
CREDIT CARD ENDING IN -3852 IN THE NAME OF V AHAN T. (2
COUNT 122
UNLAWFUL TRA SFER OF IDENTIFYING INFORMATI
(
Vahan T.)
On or about August 27, 2018, in the COUNTY of LOS ANGELES, the crime ofIDENTITY
THEFT in violation of Penal Code section 530.5(d)(l), a felony, was committed by TAMARA
DADY AN, RICHARD A YV AZYAN, ARTUR A YV AZYAN, ESTEPHANIE REYNOSO, and
ROSA ZARA TE, who did willfully and unlawfully with the intent to defraud sell, transfer, or
convey the personal identifying information of another person, to wit: A YAHOO EMAIL IN THE
NAME OF V AHAN T.
@
COUNT 123
CONSPIRACY TO COMMIT GRAND THEFT (Re: Lari a K.)
On or about and between February 24, 2016, and August 2, 2018, in the COUNTY of LOS
ANGELES, the crime of CONSPIRACY, in violation of Penal Code section 182(a)(l) a felony,
was committed by TAMARA DADYAN, RICHARD AYVAZYAN, ARTUR AYVAZYAN,
22
ANDRANIK
PETROSYAN,
LILIT
MALYAN,
GRIGOR
TATOIAN,
ARTASHES
23
MARTIROSYAN, ARSHAK BARTOUMIAN, ROSA ZARATE, ESTEPHANIE REYNOSO,
24
and VANES SA RAY BELL, who did willfully and unlawfully conspire together with another
25
person or persons whose identity is known or unknown to commit the crime of GRAND THEFT
26
BY FALSE PRETENSES, 487(a), of the California Penal Code, a felony, pursuant to and for the
27
purpose of carrying out the objects and purposes of the aforesaid conspiracy, Defendants committed
28
the following overt act(s):
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1
OVERT ACT 1
2
On or about January 12, ,2016, Tamara DADY AN emailed Victoria Akopyan with the
3
subje~t, "Keep this for your records this is the closing stmt for the house," and attached an escrow
4
statement in Larisa K. 's name of the Buyer's Estimated Closing Costs for a Banc of California loan
5
as to the property located at 17966 Valley Vista Blvd. in Encino, California.
6
OVERTACT2
7
On or about January 15, 2016, Tamara DADYAN obtained a $1,072,000 loan from Banc of
8
California in Larisa K. 's name for the property located at 17966 Valley Vista Blvd. in Encino,
9
California, based in part on Larisa K.'s purported monthly salary of $16,500 from American Eagle
10
Nursing Registry.
11
OVERT ACT 3
12
On or about February 24, 2016, Tamara DADY AN emailed Victoria Akopyan a credit report
13
in the name of Larisa K.
14
OVERT ACT 4
15
On or about February 25, 2016, Tamara DADYAN emailed Victoria Akopyan a loan
16
application in the name of Larisa K. for the purchase of a property located at 13546 Sarah Street in
17
Sherman Oaks.
18
OVERT ACT 5
19
On or about April 12, 2016, Tamara DADY AN emailed Grigor TATOIAN an image of a
20
driver's license in the name of Larisa K., with the subject, "Ask ur friend if she has a existing
21
account first."
22
OVERT ACT 6
23
On or about July 8, 2016, Tamara DADY AN emailed Richard A YV AZYAN a credit report
24
in the name of Larisa K.
25
OVERT ACT 7
26
On or about August 20, 2016, Tamara DADY AN emailed VictoriaAkopyan documents from
27
the California Secretary of State for "AAA Electronical Engineer, Inc.," that listed Larisa K. as the
28
Director and Secretary of the corporation.
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1
OVERT ACT 8
2
On or about August 31, 2016, Tamara DADYAN used Larisa K.'s name and Karen S.'s
3
notary stamp on a Grant Deed from AAA Electronical Engineering, Inc., to Melanya A., for the
4
property located at 3520 Ridgeford Drive in Westlake Village, California.
5
OVERT ACT9
6
On or about September 7, 2016, Tamara DADYAN emailed Grigor TATOIAN with the
7
subject, "AAA Electronical Engineer," writing, "Have Gagik K[.] sign SI-200 & Purchase
8
Agreement and take it to bank for new account." DADYAN attached documents from the
9
California Secretary of State for "AAA Electronical Engineer, Inc.," that listed Larisa K. as the
10
Incorporator of the corporation.
11
OVERT ACT 10
12
On or about October 11, 2016, Tamara DADY AN used LarisaK.'s name for a $760,000 loan
13
from Private Capital Management on the property located at 13 546 Sarah St. in Sherman
14
Oaks, California.
15
OVERT ACT 11
16
On or about October 21, 2016, Tamara DADY AN emailed Richard A YVAZYAN a driver's
17
license and social security card in the name of Larisa K., with the subject, "Larissa apply on 13546
18
sara st sherman oaks ca 91423 or 403 ."
19
OVERT ACT 12
20
On or about December 7, 2016, Estephanie REYNOSO created a Yahoo email account using
21
Larisa K.'s name.
22
OVERT ACT 13
23
On or about January 24, 2017, Richard A YV AZYAN used the U.S. Bank account ending in
24
-2662 held in Andrew A's name to obtain $119,145 from Renew Funding for purported
25
improvements to a property in Larisa K.'s name located at 13546 Sarah Street in Sherman Oaks.
26
OVERT ACT 14
27
On or about April 13, 2018, Grigor TATOIAN filed a bankruptcy petition in the name of
28
Larisa K. in Central District of California Case No. 18-bk-10905.
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2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
OVERT ACT 15
On or about May 29, 2018, Artur AYVAZYAN filed a bankruptcy petition in the name of
Larisa K. in Central District of California Case No. 18-bk-11359.
OVERT ACT 16
On or about June 29, 2018, Tamara DADY AN emailed Artashes MARTIROSYAN with the
subject, "Stamp goes on page 2 dates need to match date there," attaching a bankruptcy notice in
Larisa K.'s name as well as a Deed of Trust for the 12334 Longacre property in Larisa K.'s name.
OVERT ACT 17
On or about August 2, 2018, Tamara DADYAN emailed Artashes MARTIROSYAN with
the subject, "EXHIBITS AND TIME LINE FOR LARISSA K[.]," detailing efforts to avoid
foreclosure on the 17966 Valley Vista property where Larisa K.'s purported daughter, Victoria
Akopyan, lived.
@
COUNT 124
PROCURING OR OFFERING FALSE OR FORGED INSTRUMENT (Re: Larisa K.)
On or about April 13, 2018, in the COUNTY of LOS ANGELES, the crime of PROCURING
OR OFFERING A FALSE OR FORGED INSTRUMENT in violation of Penal Code section
115(a), a felony, was committed by TAMARA DADYAN, RICHARD AYVAZYAN, ARTUR
AYVAZYAN,
ANDRANIK
PETROSYAN,
LILIT
MALYAN,
GRIGOR
TATOIAN,
ARTASHES MARTIROSYAN, ARSHAK BARTOUMIAN, ROSA ZARATE, ESTEPHANIE
REYNOSO, and VANES SA RAY BELL, who did unlawfully and knowingly procure or offer a
false or forged instrument to be filed, registered, or recorded in a public office in California, which
instrument, if genuine, might be filed, registered, or recorded under a law of California or the United
States, to wit: BANKR~TCY PETITION IN LARISA K.'S NAME IN CENTRAL DISTRICT
24
OF CALIFORNIA CASE NO. 18-BK-10905.
25
COUNT 125
26
PROCURING OR OFFERING FALSE OR FORGED INSTRUMENT (Re: Larisa K.}
27
On or about May 29, 2018, in the COUNTY of LOS ANGELES, the crime of PROCURING
28
OR OFFERING A FALSE OR FORGED INSTRUMENT in violation of Penal Code section
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115(a), a felony, was committed by TAMARA DADYAN, RICHARD AYVAZYAN, ARTUR
2
AYVAZYAN,
ANDRANIK
PETROSYAN,
LILIT
MALYAN,
GRIGOR TATOIAN,
3
ARTASHES MARTIROSYAN, ARSHAK BARTOUMIAN, ROSA ZARATE, ESTEPHANIE
4
REYNOSO, and VANESSA RAY BELL, who did unlawfully and knowingly procure or offer a
5
false or forged instrument to be filed, registered, or recorded in a public office in California, which
6
instrument, if genuine, might be filed, registered, or recorded under a law of California or the United
7
States, to wit: BANKRUPTCY PETITION IN LARISA K.'S NAME IN CENTRAL DISTRICT
8
OF CALIFORNIA CASE NO. 18-BK-11359.
9
COUNT 126
10
PROCURING OR OFFERING FALSE OR FORGED INSTRUMENT {Re: Lari a K.)
11
On or about November 6, 2018, in the COUNTY of LOS ANGELES, the crime of
12
PROCURING OR OFFERING A FALSE OR FORGED INSTRUMENT in violation of Penal
13
Code section 115(a), a felony, was committed by TAMARA DADY AN, RICHARD AYVAZYAN,
14
ARTUR AYVAZYAN, ANDRANIK PETROSYAN, LILIT MALYAN, GRIGOR TATOIAN,
15
ARTASHES MARTIROSYAN, ARSHAK BARTOUMIAN, ROSA ZARATE, ESTEPHANIE
16
REYNOSO, and VANES SA RAY BELL, who did unlawfully and knowingly procure or offer a
17
false or forged instrument to be filed, registered, or recorded in a public office in California, which
18
instrument, if genuine, might be filed, registered, or recorded under a law of California or the United
19
States, to wit: A COMPLAINT IN LARISA K.' S NAME IN LOS ANGELES SUPERIOR COURT
20
CASE NO. 18VECV00146.
21
COUNT 127
22
CONSPIRACY TO COMMIT GRAND THEFT (Re: Mvkhailo D.)
23
On or about and between June 1, 2016, and July 26, 2018, in the COUNTY of LOS
24
ANGELES, the crime of CONSPIRACY, in violation of Penal Code section 182(a)(l) a felony,
25
was committed by TAMARA DADYAN, RICHARD AYVAZYAN, ARTUR AYVAZYAN,
26
LILIT MALYAN, ARTASHES MARTIROSYAN, GRIGOR TATOIAN, ROSA ZARATE,
27
ESTEPHANIE REYNOSO, and VANES SA RAY BELL, who did willfully and unlawfully
28
conspire together with another person or persons whose identity is known or unknown to commit
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#:4485
1
the crime of GRAND THEFT BY FALSE PRETENSES, 487(a), of the California Penal Code, a
2
felony, pursuant to and for the purpose of carrying out the objects and purposes of the aforesaid
3
conspiracy, Defendants committed the following overt act(s):
4
OVERT ACT 1
5
On or about April 7, 2016, Tamara DADY AN used Mykhailo D.'s name and Jon B.'s name
6
and notary stamp to obtain a $513,000 loan from Stearns Lending for the property located at 1124
7
S. Normandie Avenue in Los Angeles.
8
OVERT ACT2
9
On or about August 22, 2016, Richard A YV AZY AN and Estephanie REYNOSO used
10
Mykhailo D. 's name to create a Yahoo account.
11
OVERT ACT 3
12
On or about November 1, 2016, Richard A YV AZYAN used Mykhailo D.'s name to receive
13
$69,880 from Y grene Energy Fund for purported improvements to the 1124 S. Normandie property.
14
OVERT ACT 4
15
On or about November 7, 2016, Richard AYVAZYAN used Mykhailo D.'s name to apply
16
for $62,300 from Renew Funding for purported improvements to the 1124 S. Normandie property.
17
OVERT ACT 5
18
On or about October 23, 2017, Tamara DADYAN used Mykhailo D.'s name to receive
19
$14,878.72 from the proceeds of the trustee's sale of the 1124 S. Normandie property.
20
OVERT ACT 6
21
On or about October 26, 2017, Tamara DADYAN deposited a $15,000.07 check to a Bank
22
of America account ending in -5068 in the name of AAA Electronical_ Engineering that was
23
controlled by DADY AN.
24
OVERT ACT 7
25
On or about February 6, 2018, Tamara DADYAN emailed herself Wells Fargo Business
26
Account application documents in the name of Mykhail D., for the purported business, "MD
27
Acquisition Servives," writing in the subject, "Print and fax it to Well's Fargo Bank Art will give
28
you the NR#."
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OVERTACT8
2
On or about February 26, 2018, Tamara DADY AN emailed Artur A YVAZYAN with the
3
subject, "Mykhail for Wells Fargo Bank," and attached the Business Account application
4
documents, as well as images of a driver's license and social security card in Mykhailo D.'s name.
5
OVERT ACT9
6
On or about February 27, 2018, Tamara DADY AN emailed Vanessa BELL with the subject,
7
"I need an EOI," and listed a property located at 2283 Westshore Lane in Thousand Oaks, as well
8
as Mykhailo D.'s name.
9
OVERT ACT 10
10
On or about February 27, 2018, Vanessa BELL emailed Tamara DADY AN and attached an
11
Evidence of Insurance (EOI) document in the name of "Mykhail" D. for the 2283 Westshore
12
property.
13
OVERT ACT 11
14
On or about March 12, 2018, Richard A YV AZY AN emailed a Wells Fargo email account
15
and attached the Business Account application documents, as well as a Fictitious Business Name
16
statement in Mykhail D.'s name.
17
OVERT ACT 12
18
On or about April 9, 2018, Tamara DADY AN emailed an AOL account in the name of
19
Mykhailo D., which was controlled by DADY AN, and attached loan application documents in
20
Mykhailo D. 's name for the 2283 Westshore property with California Hard Money Direct listed as
21
the lender.
22
OVERT ACT 13
23
On or about April 11, 2018, Tamara DADYAN emailed Grigor TATOIAN and wrote,
24
"Look," attaching a screenshot of messages from the website "Hard Money Updates" that listed
25
"Myk" D. as the client and stated, "Our investor Camano Group is going to fund this."
26
II
27
//
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II
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OVERT ACT 14
2
On or about April 19, 2018, Artashes MARTIROSYAN emailed Tamara DADY AN with the
3
subject, "Mykhail," and attached a W-2 statement in Mykhailo D.'s name purportedly from "AAA
4
Electronical Engineer, Inc."
5
OVERT ACT 15
6
On or about April 24, 2018, Tamara DADYAN used the Wells Fargo account ending in -
7
2440 held in Mykhailo D.'s name to obtain a $586,291.77 wire from Stewart Title for "closing
8
proceeds" related to the 2283 Westshore property.
9
OVERT ACT 16
10
On or about July 26, 2018, Lilit MAL YAN deposited a $7,000 check to "Cash" from the
11
Wells Fargo account ending in -2440 held in Mykhailo D.'s name to the Chase account ending in -
12
5723 that MAL YAN controlled.
13
COUNT 128
14
MORTGAGE FRA D (Re: Mvkhailo D.)
15
On or about and between February 27, 2018, and April 24, 2018, in the COUNTIES of LOS
16
ANGELES and VENTURA, the crime ofMORTGAGE FRAUD in violation of Penal Code section
17
532f(a)(2), a felony, was committed by TAMARA DADY AN, RICHARD A YV AZYAN, ARTUR
18
AYVAZYAN, GRIGOR TATOIAN, ARTASHES MARTIROSYAN, ROSA ZARATE,
19
ESTEPHANIE REYNOSO, and VANES SA RAY BELL, who did unlawfully and deliberately use
20
or facilitate the use of a misstatement, misrepresentation, or omission, with the knowledge it
21
contained a misstatement, misrepresentation, or omission, during the mortgage lending process,
22
with the intention that it be relied upon by a mortgage lender, borrower, or other party to the
23
mortgage lending process, to wit: CALIFORNIA HARD MONEY DIRECT/CAMANO GROUP.
24
It is further alleged, pursuant to Penal Code section 532f(j), that the value of the fraud exceeds
25
$950.
26
II
27
II
28
//
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COUNT 129
GRAND THEFT (Re: Mvkhailo D.)
On or about and between February 27, 2018, and April 24, 2018, in the COUNTIES of LOS
ANGELES and VENTURA, the crime of GRAND THEFT in violation of Penal Code section
487(a), a felony, was committed by TAMARA DADY AN, RICHARD AYVAZYAN, ARTUR
AYVAZYAN, GRIGOR TATOIAN, ARTASHES MARTIROSYAN, ROSA ZARATE,
ESTEPHANIE REYNOSO, and VANESSA RAY BELL, who did knowingly and designedly, by
a false or fraudulent representation or pretense, obtain money or real property by fraud from
CAMANO GROUP, SPECIFICALLY, A $610,000 LOAN FOR 2283 WESTSHORE LANE IN
THOUSAND OAKS, CALIFORNIA, which had a value exceeding nine hundred fifty dollars
($950).
@
COUNT 130
UNLAWFUL TRANSFER OF IDENTIFYING INFORMATION (Re: Mvkhailo D.)
On or about April 20, 2018, in the COUNTY of LOS ANGELES, the crime of IDENTITY
THEFT in violation of Penal Code section 530.5(d)(l), a felony, was committed by TAMARA
DADYAN,
RICHARD
AYVAZYAN,
ARTUR
AYVAZYAN,
GRIGOR
TATOIAN,
ARTASHES MARTIROSYAN, ROSA ZARATE, ESTEPHANIE REYNOSO, and VANESSA
RAY BELL, who did willfully and unlawfully with the intent to defraud sell, transfer, or convey
the personal identifying information ofanotherperson, to wit: MYKHAILO D.'S NAME ON THE
20
CAMANO GROUP DEED OF TRUST.
21
COUNT 131
22
PROCURING OR OFFERING FALSE OR FORGED INSTRUMENT (Re: Mykhailo D.)
23
On or about April 20, 2018, in the COUNTY of VENTURA, the crime of PROCURING OR
24
OFFERING A FALSE OR FORGED INSTRUMENT in violation of Penal Code section l 15(a), a
25
felony,
was committed by TAMARA DADYAN, RICHARD AYVAZYAN, ARTUR
26
AYVAZYAN, GRIGOR TATOIAN, ARTASHES MARTIROSYAN, ROSA ZARATE,
27
ESTEPHANIE REYNOSO, and VANESSA RAY BELL, who did unlawfully and knowingly
28
procure or offer a false or forged instrument to be filed, registered, or recorded in a public office in
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California, which instrument, if genuine, might be filed, registered, or recorded under a law of
California or the United States, to wit: VENTURA COUNTY RECORDED DOCUMENT
NUMBER 20180424-00046902-0 1/16 IN THE NAME OF MYKHA~
COUNT132
~\
MORTGAGE FRAUD EXCEEDING $950: FILING A FRAUDULE. T DOCUMENT
(Re: Mykhailo D.)
On or about April 20, 2018, in the COUNTY of VENTURA, the crime of FILING A
FRAUDULENT DOCUMENT in violation of Penal Code section 532f(a)(4), a felony, was
committed by TAMARA DADY AN, RICHARD A YV AZY AN, ARTUR A YV AZY AN, GRIGOR
TATOIAN, ARTASHES MARTIROSYAN, ROSA ZARATE, £STEPHANIE REYNOSO, and
VANES SA RAY BELL, who did with the intent to defraud, file or cause to be filed with the
recorder of any county in connection with a mortgage loan transaction, a document with the
knowledge the document contains a deliberate misstatement, misrepresentation, or omission, to wit:
VENTURA COUNTY RECORDED DOCUMENT NUMBER 20180424-00046902-0 1/16 IN
THE NAME OF MYKHAILO D. It is further alleged that the value of the fraud exceeds nine
hundred fifty dollars ($950), within the meaning of Penal Code section 532fU).
COUNT 133
19
On or about and between April 26, 20 I 8, and May 24, 2018, in the COUNTY of LOS
20
ANGELES, the crime of MONEY LAUNDERING in violation of Penal Code section 186.l0(a), a
21
felony, was committed by TAMARA DADYAN, RICHARD AYVAZYAN, ARTUR
22
AYVAZYAN,
LILIT
MALYAN,
ARTASHES
MARTIROSYAN,
ROSA
ZARATE,
23
£STEPHANIE REYNOSO, and VANESSA RAY BELL, who did unlawfully conduct transactions
24
involving monetary instruments of a value exceeding $25,000, through a financial institution
25
knowing that the monetary instruments represented the proceeds of, or was derived directly or
26
indirectly from the proceeds of, criminal activity, to wit: $162,619.96 TOTAL THROUGH AT
27
LEAST FOUR TRANSACTIONS, AS DETAILED IN THE TABLE BELO\X/.
It is further
28
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#:4490
t
I,
•
'II
1
alleged, pursuant to Penal Code section 186.10( c )(1 )(B), that the value of the transactions exceeds
2
one hundred fifty thousand dollars ($150,000) but is less than one million dollars ($1 ,000,000).
3
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DATE
AMOUNT TRANSACTION
4/26/18
$56,097
Wells Fargo -2440 check to Wells Fargo -0950
4/30/18
$55,400.79
Wells Fargo -0950 check to Bank of America -5068
5/1/18
$1,122
Wells Fargo -0950 check for 5525 Oakdale office rent
5/10/18
$50,000.17
Wells Fargo -2440 check to Wells Fargo -0950
~
FIRST SPECIAL ALLEGATION
~
[AGGRAVATED WHITE-COLLAR CRIME IN EXCESS OF $500,000]
It is further alleged pursuant to Penal Code section 186.l l(a)(2), that TAMARA DADY AN,
RICHARD AYVAZYAN, ARTUR AYVAZYAN, GRIGOR TATOIAN,
ANDRANIK
PETROSYAN, ARTASHES MARTIROSYAN, ARSHAK BARTOUMIAN, LILIT MAL YAN,
LUBIA CARRILLO, ROSA ZARA TE, ESTEPHANIE REYNOSO, and VANES SA RAY BELL,
committed two or more related felonies to wit: the counts alleged against each of them in this
Indictment, a material element of which is fraud, involving a pattern of related felony conduct and
the taking of, or resulted in the loss by another person or entity of, more tha@1
fiv
red thousand
dollars ($500,000).
~
~
SECOND SPECIAL ALLEGATION
[THEFT OF AMOUNT OVER $100,000 (PENAL CODE SECTION 1203.045)]
It is further alleged that TAMARA DADYAN, RICHARD AYVAZYAN, ARTUR
22
AYVAZYAN,
GRIGOR
TATOIAN,
ANDRANIK
PETROSYAN,
ARTASHES
23
MARTIROSYAN, ARSHAK BARTOUMIAN, LILIT MAL YAN, LUBIA CARRILLO, ROSA
24
ZARA TE, ESTEPHANIE REYNOSO, and VANESSA RAY BELL, in the commission of the
25
Grand Theft counts alleged against them in this Indictment, with the intent to do so, took funds of
26
a value exceeding one hundred thousand dollars ($100,000) within the meaning of Penal Code
27
section 1203.045.
28
//
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* * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * *
2
A TRUE BILL, and with a finding that the requirements of Penal Code section 923(c) have
3
been satisfied.
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1.
Juror#
Dated: :-/:{2<p/ Z./
THE FOLLOWING \MTNE~S APPEARED BEFORE THE GRAND JURY IN THE
---x:ffi)~TIONED MATTER:
I
,
1. Lyle Barnes
25. David W.
2. James Harbin
26. Paul Fedynich
3. James Thiede
27. Kevin Hoffman
4. Sarkis B.
28. Robin Letourneau
5. Fatima J.
29. Lisa Barr \,-- -
6. Golie Ghoreishi
30. Flor Martinez
7. PattiAnn Brundige
31. Nina Kaminsky
8. Edward Treder
32. Timony Dharmpetarksakul
9. Jennifer Link
33. Anita M.
10. Lara Donigian
34. Pauline S.
11. Dennis V.
35. John w.
12. Linda Huynh
36. Jeremiah S.
13. Marissa Gil
37. JonB.
14. Dennis Jin
38. Erwin N.
15. Jason Schermer
39. Roy D.
16. Supriva Sachar
40. Corrie S.
17. Vincent Hill
41. Silver D.V.
18. Renee Byrom
42. Carolyn S.
19. Lori H.
43. Karen S.
20. Elizabeth W.
44. Adam S.
21. Jean W.
45. Trevor Larsen
22. Damon B.
46. Angelica Aguilar
23. Evet Minasian
47. Razmik Galoosian
24. Gustavo Garcia
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