Declaration of Ashwin J. Ram in Support — USA v. Ayvazyan et al (Dkt. 426.2)

Record facts

U.S. District Court for the Central District of California · No. 2:20-cr-00579-SVW · Doc. 426-2 · 2021-06-07 · Docket on CourtListener

Summary

A declaration of Ashwin J. Ram, a partner at Steptoe & Johnson LLP and counsel for defendant Richard Ayvazyan, filed June 7, 2021 as Doc. 426-2 in United States of America v. Richard Ayvazyan, et al., No. 2:20-cr-00579-SVW, in the U.S. District Court for the Central District of California. It is filed in support of the opposition to the government's motion to redact the superseding indictment for use at trial (Dkt. 422) and the cross-motion to strike paragraphs 10-18 of the superseding indictment, noticed for June 15, 2021 before Hon. Stephen V. Wilson. The declaration attaches as Exhibit A a May 26, 2021 email sending the government proposed jury instructions, including an instruction on multiple conspiracies. It attaches as Exhibit B a May 27, 2021 government email proposing to redact Paragraph 32 from the superseding indictment for trial.

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DECLARATION OF A. RAM IN SUPPORT OF OPPOSITION TO TRIAL 
INDICTMENT AND CROSS-MOTION TO STRIKE 
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Ashwin J. Ram (SBN 227513) 
aram@steptoe.com 
Michael A. Keough (SBN 327037) 
mkeough@steptoe.com 
Nicholas P. Silverman (pro hac vice) 
nsilverman@steptoe.com 
Meghan Newcomer (pro hac vice) 
mnewcomer@steptoe.com 
STEPTOE & JOHNSON LLP 
633 West Fifth Street, Suite 1900 
Los Angeles, CA 90071 
Telephone: (213) 439-9400 
Facsimile: (213) 439-9599 
 
 
Counsel for Defendant Richard Ayvazyan 
 
UNITED STATES DISTRICT COURT 
CENTRAL DISTRICT OF CALIFORNIA  
 
 
UNITED STATES OF AMERICA, 
 
                              Plaintiff, 
 
v. 
 
RICHARD AYVAZYAN,  
et al., 
 
Defendants. 
 
 Case No.  20-cr-579 (SVW) 
 
DECLARATION OF ASHWIN J. 
RAM IN SUPPORT OF 
OPPOSITION TO 
GOVERNMENT’S MOTION TO 
REDACT SUPERSEDING 
INDICTMENT FOR USE AT TRIAL 
(DKT. 422) AND CROSS-MOTION 
TO STRIKE PARAGRAPHS 10-18 
OF THE SUPERSEDING 
INDICTMENT 
 
Judge:   Hon. Stephen V. Wilson 
Date:     June 15, 2021 
Time:    8:30 a.m. 
 
 
 
 
Case 2:20-cr-00579-SVW     Document 426-2     Filed 06/07/21     Page 1 of 2   Page ID
#:4767

 
 
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DECLARATION OF A. RAM IN SUPPORT OF OPPOSITION TO TRIAL 
INDICTMENT AND CROSS-MOTION TO STRIKE 
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I, Ashwin J. Ram, declare as follows: 
1. 
I am an attorney licensed to practice law in the state of California.  I am a 
partner at the law firm of Steptoe & Johnson LLP and counsel of record for defendant 
Richard Ayvazyan in the above-captioned matter. 
2. 
On the evening of Wednesday, May 26, 2021, counsel for defendant 
Richard Ayvazyan sent a draft set of proposed jury instructions to the government for 
their consideration.  Those instructions contained a proposed instruction related to 
multiple conspiracies.  Based on the Ninth Circuit Model Jury Instructions, the 
proposed multiple conspiracies instruction would inform the jury in relevant part that 
“If you find that the single conspiracy to commit wire fraud and bank fraud charged in 
Count 1 did not exist, then you must return a not guilty verdict, even though you may 
find that some other conspiracy existed.”  A true and correct copy of the May 26, 2021 
email transmitting those instructions is attached as Exhibit A. 
3. 
A true and correct copy of a May 27, 2021 email from the government, 
proposing for the first time to redact Paragraph 32 from the Superseding Indictment for 
use at trial, is attached as Exhibit B.   
I declare under penalty of perjury that the foregoing is true and correct. 
Executed at Los Angeles, California on June 7, 2021. 
 
 
 
 
 
 
 
 
Respectfully submitted,  
 
 
 
 
 
 
 
 
/s/ Ashwin J. Ram  
 
 
 
 
 
 
 
 
 
Ashwin J. Ram  
 
 
 
 
Counsel for Defendant Richard Ayvazyan 
Case 2:20-cr-00579-SVW     Document 426-2     Filed 06/07/21     Page 2 of 2   Page ID
#:4768

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