Court filing
Exhibit A — USA v. Ayvazyan et al. (Dkt. 426-3, C.D. Cal.)
Summary
Exhibit A, Document 426-3 filed June 7, 2021 in Case 2:20-cr-00579-SVW (C.D. Cal.), is an email sent Wednesday, May 26, 2021 by Michael Keough of Steptoe & Johnson LLP to government counsel Christopher Fenton, Scott Paetty and Catherine Ahn, copying defense counsel. The subject is US v. Ayvazyan et al - Jury Instructions, with a draft set of proposed defense jury instructions attached for all defendants except Arman Hayrapetyan. The email says language that differs from the government's is highlighted in yellow and offers to meet and confer. It proposes that the government and the defense each file one set of instructions.
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Filed June 7, 2021 in USA v. Ayvazyan et al.; one of 698 filings from this case.
Record facts
| Court | U.S. District Court for the Central District of California |
|---|---|
| Filed | 2021-06-07 |
Cite this document
“Exhibit A — USA v. Ayvazyan et al. (Dkt. 426-3, C.D. Cal.).”
U.S. District Court for the Central District of California, No. 2:20-cr-00579-SVW, Doc. 426-3, filed 2021-06-07. Archived at Pandemic Darlings, https://pandemicdarlings.com/court-filings/full-docket-artur-ayvazyan-cacd-802533/2021-06-07-gov-uscourts-cacd-802533-426-3-doc-426-3/
, SHA-256 b70a46a3f1a738a577059d02011c077d81c107a0ed8ee3d4cea1fba7366c1cec.Full text
EXHIBIT A Case 2:20-cr-00579-SVW Document 426-3 Filed 06/07/21 Page 1 of 2 Page ID #:4769 1 From: Keough, Michael Sent: Wednesday, May 26, 2021 10:34 PM To: Fenton, Christopher (CRM); Paetty, Scott (USACAC); Ahn, Catherine S. (USACAC) Cc: David Diamond; George Mgdesyan; John Littrell; Law offices of Fred G. Minassian, Inc.; Newcomer, Meghan; Ryan V. Fraser; Wirschinglaw@outlook.com; john@hanuszlaw.com; mesereau@mesereaulaw.com; Peter Johnson; Ram, Ashwin; Silverman, Nicholas Subject: US v. Ayvazyan et al - Jury Instructions Attachments: Proposed Joint Defense Jury Instructions-c2.DOCX Dear Counsel: Please find attached a set of proposed defense jury instructions on behalf of all defendants except Arman Hayrapetyan (whose position on the proposed instructions we do not know). These are not yet finalized, but we are providing a draft to you at this stage. Where the proposed defense instructions are different from the government’s, we have highlighted that language in yellow. We are available to meet and confer tomorrow if you would like to discuss the defense’s proposed instructions. Given that the Court has asked for the instructions by tomorrow, we would propose that the government file its instructions as being proposed by the government, and the defense file its instructions as being proposed by the defense. This will allow the Court to consider instructions from the two sets (as opposed to a set from each defendant as well as the government). Best, Mike Michael A. Keough Associate Admitted in California and New York mkeough@Steptoe.com +1 415 365 6717 direct | +1 415 365 6699 fax Steptoe Steptoe & Johnson LLP One Market Plaza | Spear Tower, Suite 3900 | San Francisco, CA 94105 www.steptoe.com This message and any attached documents contain information from the law firm Steptoe & Johnson LLP that may be confidential and/or privileged. If you are not the intended recipient, please do not read, copy, distribute, or use this information. If you have received this transmission in error, please notify the sender immediately by reply e-mail and then delete this message. Case 2:20-cr-00579-SVW Document 426-3 Filed 06/07/21 Page 2 of 2 Page ID #:4770
File and source
- File
- gov.uscourts.cacd.802533.426.3.pdf
- Size
- 171,458 bytes
- SHA-256
- b70a46a3f1a738a577059d02011c077d81c107a0ed8ee3d4cea1fba7366c1cec
- Original
- PACER (login required)