Pandemic Darlings The pandemic economy, in original documents
Home Court filings USA v. Ayvazyan et al United States v. Artur Ayvazyan et al. — C.D. Cal., No. 2:20-cr-00579-SVW Exhibit A — USA v. Ayvazyan et al. (Dkt. 439-2, C.D. Cal.)

Court filing

Exhibit A — USA v. Ayvazyan et al. (Dkt. 439-2, C.D. Cal.)

Filed June 7, 2021 in USA v. Ayvazyan et al.; one of 233 filings from this case.

Record facts

CourtU.S. District Court for the Central District of California
Filed2021-06-07

U.S. District Court for the Central District of California · No. 2:20-cr-00579-SVW · Doc. 439-2 · 2021-06-07 · Docket on CourtListener

Full text

EXHIBIT A
Case 2:20-cr-00579-SVW     Document 439-2     Filed 06/07/21     Page 1 of 49   Page ID
#:4896

ROUGH TRANSCRIPT
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
UNITED STATES DISTRICT COURT
UNITED STATES DISTRICT COURT
CENTRAL DISTRICT OF CALIFORNIA
WESTERN DIVISION
- - -
HONORABLE STEPHEN V. WILSON, DISTRICT JUDGE PRESIDING
UNITED STATES OF AMERICA,
Plaintiffs,
vs.
RICHARD AYVAZYAN, et al.,
Defendants.
________________________________
)
)
)
)
)
)
)
)
)
)
)
)
)
)
No. CR 20-00579-SVW
REPORTER'S TRANSCRIPT OF PROCEEDINGS
[ZOOM] STATUS CONFERENCE HEARING
LOS ANGELES, CALIFORNIA
FRIDAY, MAY 21, 2021
_____________________________________________________________
MARIA R. BUSTILLOS
OFFICIAL COURT REPORTER
C.S.R. 12254
UNITED STATES COURTHOUSE
350 WEST 1ST STREET
SUITE 4455
LOS ANGELES, CALIFORNIA 90012
(213) 894-2739
2
EXHIBIT A
Case 2:20-cr-00579-SVW     Document 439-2     Filed 06/07/21     Page 2 of 49   Page ID
#:4897

ROUGH TRANSCRIPT
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
UNITED STATES DISTRICT COURT
2
A P P E A R A N C E S
ON BEHALF OF THE PLAINTIFFS,
UNITED STATES OF AMERICA:
OFFICE OF THE UNITED STATES
ATTORNEY
GENERAL CRIMES SECTION
BY:
SCOTT PAETTY, ESQ.
312 NORTH SPRING STREET
12TH FLOOR
LOS ANGELES, CA 90012
(213)894-6527
U.S. DEPARTMENT OF JUSTICE
BY:
CHRISTOPHER FENTON,
ESQ.
1400 NEW YORK AVENUE NW
WASHINGTON, D.C. 20530
(202)320-0539
OFFICE OF THE UNITED STATES
ATTORNEY
ORGANIZED CRIME DRUG
ENFORCEMENT TASK FORCE
SECTION
BY:
CATHERINE SUN AHN
312 NORTH SPRING STREET
SUITE 1400
LOS ANGELES, CA 90012
(213)894-0141
ON BEHALF OF THE DEFENDANTS,
RICHARD AYVAZYAN, et al.:
STEPTOE and JOHNSON, LLP
BY:
ASHWIN J. RAM, ESQ.
633 WEST 5TH STREET
SUITE 1900
LOS ANGELES, CA 90071
(213)439-9443
STEPTOE and JOHNSON, LLP
BY:
NICHOLAS P. SILVERMAN,
ESQ.
1330 CONNECTICUT AVENUE NW
WASHINGTON, D.C. 20036
(202)429-8096
3
EXHIBIT A
Case 2:20-cr-00579-SVW     Document 439-2     Filed 06/07/21     Page 3 of 49   Page ID
#:4898

ROUGH TRANSCRIPT
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
UNITED STATES DISTRICT COURT
3
A P P E A R A N C E S (CONT'D)
ON BEHALF OF THE DEFENDANTS,
et al.:
BIENERT KATZMAN LITTRELL
WILLIAMS, LLP
BY:
JOHN LEWIS LITTRELL,
ESQ.
903 CALLE ALMANECER
SUITE 350
SAN CLEMENTE, CA 92673
(949)369-3700
JENNIFER J. WIRSCHING LAW
BY:
JENNIFER J. WIRSCHING,
ESQ.
1935 ALPHA ROAD
SUITE 216
GLENDALE, CA 91208
(424)901-9280
HANUSZ LAW, P.C.
BY:
JOHN HANUSZ
800 WILSHIRE BOULEVARD
SUITE 1050
LOS ANGELES, CA 90017
(213)204-4200
ON BEHALF OF THE DEFENDANTS,
RICHARD AYVAZYAN, et al.:
THE FREEDMAN FIRM
BY:
MICHAEL G. FREEDMAN,
ESQ.
800 WILSHIRE BOULEVARD
SUITE 1050
LOS ANGELES, CA 90017
(213)816-1700
LAW OFFICE OF PETER JOHNSON
BY:
PETER JOHNSON, ESQ.
409 NORTH PACIFIC COAST
HIGHWAY
SUITE 651
REDONDO BEACH, CA 90277
(310)295-1785
4
EXHIBIT A
Case 2:20-cr-00579-SVW     Document 439-2     Filed 06/07/21     Page 4 of 49   Page ID
#:4899

ROUGH TRANSCRIPT
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
UNITED STATES DISTRICT COURT
4
A P P E A R A N C E S (CONT'D)
ON BEHALF OF THE PLAINTIFFS,
UNITED STATES OF AMERICA:
BIENERT KATZMAN LITTRELL
WILLIAMS, LLP
BY:
RYAN V. FRAZER, ESQ.
601 WEST 5TH STREET
SUITE 720
LOS ANGELES, CA 90071
(213)528-3200
LAW OFFICES OF FRED G.
MINASSIAN
BY:
FRED G. MINASSIAN, ESQ.
101 NORTH BRAND BOULEVARD
GLENDALE, CA 91203
(818)240-2444
STEPTOE and JOHNSON, LLP
BY:
MEGHAN NEWCOMER
1114 AVENUE OF THE AMERICAS
NEW YORK, NY 10036
(212)506-3900
ON BEHALF OF THE DEFENDANTS,
RICHARD AYVAZYAN, et al.:
STEPTOE and JOHNSON, LLP
BY:
MICHAEL A. KEOUGH, ESQ.
1 MARKET STREET SPEAR TOWER
SUITE 3900
SAN FRANCISCO, CA 94105
(415)365-6717
TAHMAZIAN LAW FIRM, P.C.
BY:
JILBERT TAHMAZIAN, ESQ.
1518 WEST GLENOAKS BOULEVARD
GLENDALE, CA 91201
(818)242-8201
5
EXHIBIT A
Case 2:20-cr-00579-SVW     Document 439-2     Filed 06/07/21     Page 5 of 49   Page ID
#:4900

ROUGH TRANSCRIPT
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
UNITED STATES DISTRICT COURT
5
I N D E X
PAGE
[ZOOM] STATUS CONFERENCE HEARING:
6
6
EXHIBIT A
Case 2:20-cr-00579-SVW     Document 439-2     Filed 06/07/21     Page 6 of 49   Page ID
#:4901

ROUGH TRANSCRIPT
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
UNITED STATES DISTRICT COURT
6
LOS ANGELES, CALIFORNIA; FRIDAY, MAY 21, 2021
-o0o-
(COURT IN SESSION AT 1:41 P.M.)
THE COURTROOM DEPUTY:
We're here on
CR 20-00579-SVW:
United States of America v. Richard
Ayvazyan, et al.
Please state your appearances.
MR. FENTON:
Good afternoon.
Christopher Fenton appearing for the Government and Scott
Paetty and Catherine Ahn.
MR. RAM:
Good afternoon, Your Honor.
Ashwin Ram on behalf of defendant Richard Ayvazyan, and I'm
joined by co-counsel Nick Silverman, Michael Keough and
Meghan Newcomer.
MR. LITTRELL:
John Littrell and Ryan Frazer for
Marietta Terabelian.
MS. WIRSCHING:
Jennifer Wirsching for
Artur Ayvazyan.
MR. LITTRELL:
Jilbert Tahmazian for
Arman Hayrapetyan.
MR. HANUSZ:
John Hanusz for Manuk Grigorian.
MR. FREEDMAN:
Michael Freedman for
Edvard Paronyan.
MR. JOHNSON:
And Peter Johnson for
Vahe Dadyan.
7
EXHIBIT A
Case 2:20-cr-00579-SVW     Document 439-2     Filed 06/07/21     Page 7 of 49   Page ID
#:4902

ROUGH TRANSCRIPT
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
UNITED STATES DISTRICT COURT
7
THE COURT:
This is a pretrial conference.
We
may have another -- I don't know at this point, I wanted
to ask the Government some questions, because they have
the laboring task, at least at the outset of the trial
in terms of witnesses that you -- that you intend to
call.
Can you describe just the categories of witnesses
as a start?
MR. FENTON:
Yes, Your Honor.
So the
Government anticipates calling agents who were on site
at the various premises that were searched from which
evidence was taken, cart examiners who will testify to
the digital devices that were seized.
THE COURT:
Say that last category again.
What
did you say?
MR. FENTON:
An FBI cart examiner.
MR. RAM:
Cart.
MR. FENTON:
Cart.
Yes, who will testify.
THE COURT:
What does that mean?
MR. FENTON:
It will be a forensic specialist
from the FBI who will testify about the digital devices
that were seized.
THE COURT:
What about them?
MR. FENTON:
To testify that the evidence that
we're presenting are forensically sound copies from
evidence taken of those digital devices.
8
EXHIBIT A
Case 2:20-cr-00579-SVW     Document 439-2     Filed 06/07/21     Page 8 of 49   Page ID
#:4903

ROUGH TRANSCRIPT
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
UNITED STATES DISTRICT COURT
8
THE COURT:
Okay.
I'll get back to that.
Okay.
Go ahead.
MR. FENTON:
We'll have a summary witness who
will testify about tracing the PPP and EIDL loans and
how that money was even used.
We'll have a witness from
the Small Business Administration who will testify about
the PPP and EIDL loan programs.
We'll have some victims
who fit into three different categories.
One would be a
lender victim.
One would be --
THE COURT:
A lender victim, meaning a bank?
MR. FENTON:
That's correct.
So it would be a
bank who lent funds.
THE COURT:
And so how would the bank be a
victim, monetarily or in some other way?
MR. FENTON:
So yes, the bank would be a victim
monetarily, and this witness would testify to the
materiality of the false and misleading statements
allegedly made by the defendants.
THE COURT:
Well, how -- give me an example of
how a bank would lose money in the scheme alleged.
MR. FENTON:
Well, in this particular instance,
the banks were originating the SBA loans, and they were
using their own funds that were guaranteed by the SBA.
THE COURT:
Well, wouldn't the banks --
wouldn't the banks be reimbursed by the SBA?
Weren't
9
EXHIBIT A
Case 2:20-cr-00579-SVW     Document 439-2     Filed 06/07/21     Page 9 of 49   Page ID
#:4904

ROUGH TRANSCRIPT
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
UNITED STATES DISTRICT COURT
9
they secured?
MR. FENTON:
Potentially -- that is
potentially --
THE COURT:
So how would you present the banks
as victims if under the program -- and most SBA programs
are Government secured.
It is hard to understand why
they would be a -- a victim -- I'll get back to that.
Okay.
Go ahead.
MR. FENTON:
We would also -- we would also
offer the identity theft victims, including the victims
whose identities -- victim -- theft victims mentioned in
the superseding indictment.
THE COURT:
How many -- in -- how many in that
category?
MR. FENTON:
We anticipate that there will be
about five.
THE COURT:
All right.
Let me get back to the
summary witness.
I'm sure you're aware of the
requirements of 2006 of the Evidence Code that the
summary charts would have to be prepared in advance of
trial and presented to the -- to the Defense counsel so
that they can effectively cross-examine the summary
witness or object in some way that the summary --
doesn't reflect the underlying evidence.
And my
experience with the summary charts is that they
10
EXHIBIT A
Case 2:20-cr-00579-SVW     Document 439-2     Filed 06/07/21     Page 10 of 49   Page ID
#:4905

ROUGH TRANSCRIPT
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
UNITED STATES DISTRICT COURT
10
generally include in a column, a trial -- the trial
exhibits which support whatever the summary chart
reflects.
Is that the format you're intending to use?
MR. FENTON:
Yes, Your Honor.
We provided
notice to the defendants about that summary witness'
testimony, and we have circulated a draft summary
exhibit agreement so that we can share that information
with the Defense counsel.
THE COURT:
So -- so in short, you're saying
that the Defense lawyers have a copy of the chart that
you intend to use?
MR. FENTON:
No, Your Honor.
I'm saying that
we've circulated the agreement that they sign.
Once
that agreement is signed, we will be prepared to
circulate --
THE COURT:
What is the requirement of the
agreement?
MR. FENTON:
The requirement just states that
at this point the agreements -- that the summary
exhibits are in draft form, and we're going to share a
draft copy with them in advance of the June 1st due
date --
THE COURT:
Well --
MR. FENTON:
-- and then they cannot use that
to cross-examine the summary witness at trial.
11
EXHIBIT A
Case 2:20-cr-00579-SVW     Document 439-2     Filed 06/07/21     Page 11 of 49   Page ID
#:4906

ROUGH TRANSCRIPT
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
UNITED STATES DISTRICT COURT
11
THE COURT:
I see.
MR. FENTON:
That will be the final version
that is used.
THE COURT:
I see.
So June 1st is when you
intend to supply the final version?
MR. FENTON:
That's correct, Your Honor.
That's the date set by the Court.
We fully intend to
comply.
THE COURT:
All right.
Okay.
Regarding the
categories of -- of witnesses -- in this -- you know, to
some extent while a large ex- -- depends on the position
of Defense lawyers -- and I won't get into that with
them individually now, but my thinking is -- and this is
just -- just my thinking, that if there are certain
underlying exhibits which are not in dispute -- I never
understood how a defendant benefits by having a jury see
a parade full of witnesses who reaffirm the obvious.
That always was -- my thought that it subliminally
affirms the strength of the Government's case.
So here,
in particular, there are records in different
categories.
And I'm only talking about authenticity.
In other words, this is only with regard to
authenticity.
This is nothing -- nothing to do with any
other objection that any Defense lawyer has in mind.
In
other words, this piece of paper is what it purports to
12
EXHIBIT A
Case 2:20-cr-00579-SVW     Document 439-2     Filed 06/07/21     Page 12 of 49   Page ID
#:4907

ROUGH TRANSCRIPT
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
UNITED STATES DISTRICT COURT
12
be.
That's the foundation for authenticity.
So take
bank records, for example -- records of -- bank records,
I would hope that we wouldn't have to parade a bunch of
bank custodians to weigh business record foundations or
bank records.
Similarly, with the applications for the
EI -- I forget these acronyms.
It is EIDL, is that
the -- the acronyms PPP or --
MR. FENTON:
That's correct, PPP and EIDL.
THE COURT:
Yeah.
And those applications -- I
mean, whatever -- whatever the debate is, the
authenticity would be that this was something that was
in the files of the appropriate agency, SPA treasury,
whatever agency had it, and that's all.
That's what I
would consider authenticity.
With regard to the -- with
regard to the -- and the bank records will also include
the wire transfers.
In other words, that would just
be -- again, there was a wire transfer actually made
from this bank to wherever it went.
That's all I'm
discussing.
Nothing about the probative value or any
other objection that could be raised or so forth.
Have you discussed that with the Defense
lawyers, Mr. Fenton?
MR. FENTON:
Yes, Your Honor.
So in -- in both
respects.
So we have circulated a notice of our
intention to submit documents, pursuant to 902 that
13
EXHIBIT A
Case 2:20-cr-00579-SVW     Document 439-2     Filed 06/07/21     Page 13 of 49   Page ID
#:4908

ROUGH TRANSCRIPT
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
UNITED STATES DISTRICT COURT
13
include loan files and bank records and then certain
other categories of information that are
noncontroversial, like IP address information, telephone
records and FCIC certifications.
THE COURT:
I see.
All right.
MR. FENTON:
The second thing, Your Honor, is
to your second point, we have circulated a stipulation
that we are hopeful that the parties will sign,
stipulating to the fact that the wires underlying the
wire fraud counts -- the substantive wire fraud counts
are, indeed, interested wires.
THE COURT:
I see.
All right.
Any other
stipulations that are doable would be appreciated.
MR. FENTON:
Your Honor, to your point, I
just want to -- there are some additional witnesses that
the Court would be interested -- there are some
additional witnesses, I just want to put the Court
notice of.
THE COURT:
Go ahead.
MR. FENTON:
To establish the falsity of the
statements that were made in the loan applications, we
intend to put forth witnesses talking about the absence
of certain records.
So, for example, we anticipate
having a witness from the Internal Revenue Service who
will testify to the fact that there were not tax filings
14
EXHIBIT A
Case 2:20-cr-00579-SVW     Document 439-2     Filed 06/07/21     Page 14 of 49   Page ID
#:4909

ROUGH TRANSCRIPT
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
UNITED STATES DISTRICT COURT
14
that were submitted -- the tax filings that were
attached to these applications were not submitted.
We
anticipate having a California EDD employment department
employee who will testify to the absence of records with
respect to the payment of unemployment tax.
And we
anticipate having a California DMV, Department of Motor
Vehicle's witness testify about the fact that certain
driver's licenses are fake because there is an absence
of records with respect to -- to those records, as well.
We also anticipate having a Department of
Homeland Security representative testify about the
absence of records and also travel records with respect
to the individuals who are the subject of these stolen
identities.
And the Government has provided notice
to --
THE COURT:
Say -- say the last category
again -- travel records what?
Would you repeat that.
MR. FENTON:
Yes, Your Honor.
The last -- the last department that I
mentioned is the Department of Homeland Security.
And
we will have a witness who will admit records that show
the travel history for the individuals whose identities
are being used with respect to -- to apply for these
loans.
Essentially, it's to establish that these
individuals are Russian foreign exchange students or
15
EXHIBIT A
Case 2:20-cr-00579-SVW     Document 439-2     Filed 06/07/21     Page 15 of 49   Page ID
#:4910

ROUGH TRANSCRIPT
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
UNITED STATES DISTRICT COURT
15
European foreign exchange students who were at some
point in time in the country for only moments,
Your Honor.
THE COURT:
I see.
In terms of the counts in
the indictment, which of the -- are there any counts
where the -- any one of the defendants applied for some
loan in their own name or each -- or was it one of what
you call the -- how did you -- the term fictitious -- it
wasn't "fictitious" -- what was the term you used in the
indictment for the -- for the -- the people who you say
don't exist?
What was the term?
MR. FENTON:
Sync or synthetic.
THE COURT:
Synthetic, right.
So aside from
the alleged synthetic borrowers and the corporate
entities that -- that -- in these loan applications, did
an individual have to make the application on behalf of
an entity, correct?
MR. FENTON:
That's correct, Your Honor.
THE COURT:
So it would seem like the
individuals would be officers who are owners of the
business that apply to the loan -- at least, on the
paper, correct?
MR. FENTON:
That's correct, Your Honor.
THE COURT:
And in any of the counts, do the --
do any of the defendants apply for a loan in their name
16
EXHIBIT A
Case 2:20-cr-00579-SVW     Document 439-2     Filed 06/07/21     Page 16 of 49   Page ID
#:4911

ROUGH TRANSCRIPT
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
UNITED STATES DISTRICT COURT
16
or the name of -- of a business they own?
MR. FENTON:
Yes, Your Honor.
THE COURT:
How many counts?
MR. FENTON:
Six.
THE COURT:
I see.
And was it a particular
defendant or more than one?
MR. FENTON:
There are four defendants who
apply for loans using their own name.
THE COURT:
I see.
And -- I see.
All right.
With -- with some of the witnesses that you outlined who
are not in the custodian of record type category, there
still might be some room for stipulation, but that's up
to the parties and the Government.
You know, before I forget, one of the
defendants -- I'm having trouble with his name.
It's a
Hayrapetyan -- Hayrapetyan is the best I can do.
I
probably butchered his name -- Hayrapetyan.
He's the
defendant in custody.
And he's made a motion for
modification of bond.
I would like the Government to
respond to that promptly.
MR. FENTON:
Yes, Your Honor.
The Government opposes Mr. --
THE COURT:
Yeah, I want to see it on paper.
MR. FENTON:
Oh, yes, Your Honor.
THE COURT:
Yeah.
17
EXHIBIT A
Case 2:20-cr-00579-SVW     Document 439-2     Filed 06/07/21     Page 17 of 49   Page ID
#:4912

ROUGH TRANSCRIPT
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
UNITED STATES DISTRICT COURT
17
MR. FENTON:
We'll submit a -- we'll submit a
response promptly.
THE COURT:
Yeah, promptly.
And the other
point I wanted to make is that I want the parties to
submit jury instructions by May 27th.
And my approach
to jury instructions I think is traditional.
I take the
general instructions to the extent they're applicable
from the Ninth Circuit model pattern instruction
criminal.
And to the extent that any cause of action is
the subject of an instruction in that manual, I
generally look first to that manual.
I mean, it's not
full proof, but it is generally subject to Ninth Circuit
scrutiny and -- and there are occasions when the
Ninth Circuit criticizes an instruction like that, and
it's modified; but those are my general preferences.
And in terms of instructions, I generally like to use
the least amount of instructions to convey the necessary
outline -- legal outline to the jury.
And I certainly
will not be receptive to any instruction from the
Government or the Defense which is argumentative, either
in language or as just an instruction which is designed
to support an argument.
Arguments are different than
instructions.
So essentially it is causes of action,
elements, any terms within the instructions that are
18
EXHIBIT A
Case 2:20-cr-00579-SVW     Document 439-2     Filed 06/07/21     Page 18 of 49   Page ID
#:4913

ROUGH TRANSCRIPT
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
UNITED STATES DISTRICT COURT
18
so-called words of art that meet further definition and
then any defenses -- any instructions that relate to
defenses.
So to the extent you can agree and then have
some which are always in dispute.
Present it.
That
would be all the best.
If not, we'll do it -- if not,
we'll do it anyway it comes up.
I'll deal with it.
Oh, one other thought as you're preparing for
trial -- and this is something that I feel very strongly
about -- it's the abuse of opening statement.
I will
not allow opening statements that delve into argument.
And I'm well-aware for many years of all the deft of
hand that lawyers have to make something that isn't
argument seem like it isn't an argument.
I mean,
example, the evidence will show that every plaintiff --
every prosecution witness is lying.
We will show you in
this case that the Government has no case or that --
whatever.
The opening statement should be a preview of
the evidence, not a preview of your argument.
And so
whatever your prior experience is, it'll be embarrassing
for you if I interrupt your opening statement.
And if
it goes over the line, I will.
It's not a good start
for the Government, and it's not a good start for the
Defense.
Sometimes the Government starts out these
cases with an argument, which I've never liked, sort of
19
EXHIBIT A
Case 2:20-cr-00579-SVW     Document 439-2     Filed 06/07/21     Page 19 of 49   Page ID
#:4914

ROUGH TRANSCRIPT
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
UNITED STATES DISTRICT COURT
19
a -- a first sentence of what -- something like, this
case is about cheating or about ripping off the
Government.
Don't do that.
Just -- then that gets me
to a second point.
And I'll enforce with it the
defendants as vigorously as I will with the Government.
Count on it.
And the other point is this:
The -- I read the
indictment a couple days ago again -- the
amended indictment.
And generally, I allow the
Government during the jury selection which will --
before the jury selection begins to read the indictment.
I'm not going to allow the Government to read the -- the
indictment in its entirety, because there are counts
which are structurally repetitive, but I will allow you
to read the -- I think it's the first 13 pages of the
amended indictment which is the descriptive portion of
the conspiracy.
And I think if my memory is correct, at
page 27 of the indictment, you have a description of the
wire fraud count.
And then you can tell the jury there
are counts derivative of that -- maybe read one or
two -- read just one to give the jury a flavor.
Let me ask you about this, the wire fraud and
the conspiracy charge.
There are obvious differences
between conspiracy and wire fraud, but there are also
many similarities.
In fact, the Rules of Evidence with
20
EXHIBIT A
Case 2:20-cr-00579-SVW     Document 439-2     Filed 06/07/21     Page 20 of 49   Page ID
#:4915

ROUGH TRANSCRIPT
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
UNITED STATES DISTRICT COURT
20
regard to the hearsay exception is similarly applied to
mail and wire fraud cases and to conspiracy cases.
So
in a nutshell, what is the difference between the wire
fraud and the conspiracy?
Understanding that the wire
fraud is the object of a conspiracy, was that it?
Is
that it, Mr. Fenton?
MR. FENTON:
Yes, Your Honor.
THE COURT:
That the wire fraud is the
substantive object of the conspiracy?
MR. FENTON:
As is the bank fraud.
THE COURT:
Bank fraud.
I see.
But -- but in
terms of the actual fraud -- the scheme that you allege,
it is the scheme alleged in the conspiracy count,
correct?
MR. FENTON:
That's correct.
With respect to
the 1349 conspiracy.
The money laundering conspiracy
under 1956(h) would be potentially different.
THE COURT:
I'm sorry.
I didn't hear you.
You --
MR. FENTON:
So there's two conspiracies
alleged in the indictment.
The first is the conspiracy
to commit wire fraud and bank fraud, which is the
conspiracy that you just referenced, but there's also a
conspiracy to commit money laundering, as well.
THE COURT:
And that -- that is a separate
21
EXHIBIT A
Case 2:20-cr-00579-SVW     Document 439-2     Filed 06/07/21     Page 21 of 49   Page ID
#:4916

ROUGH TRANSCRIPT
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
UNITED STATES DISTRICT COURT
21
conspiracy?
MR. FENTON:
That is pled, yes, as a separate
conspiracy.
THE COURT:
All right.
I'll have to reexamine
that.
So maybe you can re -- I missed that.
How long
is that description, the money laundering conspiracy,
how many pages?
MR. FENTON:
That is on page -- it begins at
page 40 to 42.
THE COURT:
All right.
So you -- I'll allow
you to read the -- of course, I'll tell the jury --
prospective jury members that the indictment is -- is
merely the way a case begins in federal court.
It has
no value other than that, but you can read the -- the
conspiracy 1 to 13 regarding the bank fraud and wire
fraud as objects.
You can read the -- the conspiracy
for the money laundering, and you can read the short --
the shorter version of the mail fraud -- the wire
fraud section; that's at page 27, I think.
There's some
description of wire fraud.
I'll allow you to read that.
Okay.
Now, because of the number of
defendants, the Court was concerned about logistics --
and before we began, I heard Mr. Cruz giving you some
information about the fact that I have secured the
multi-defendant courtroom, which is on the 10th floor.
22
EXHIBIT A
Case 2:20-cr-00579-SVW     Document 439-2     Filed 06/07/21     Page 22 of 49   Page ID
#:4917

ROUGH TRANSCRIPT
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
UNITED STATES DISTRICT COURT
22
It's a larger courtroom.
It has two jury boxes which
will enable the Court to spread the jurors in a way
consistent with the court's guidelines.
And -- but, of
course, there are -- there's at least one or two lawyers
for every defendant.
The counsel tables as I see them,
won't allow more than one lawyer to be with a defendant
at the counsel table.
So if there's more than one
lawyer, the principal lawyer will be at the counsel
table and the other lawyer or lawyers will have to be
close by in the gallery -- and we'll keep some rows
available for that purpose.
I trust you received the order that I issued
this morning.
Did everyone get that?
MR. RAM:
Yes, Your Honor.
THE COURT:
All right.
Then that was all I had
on my agenda.
Anything further from anybody?
MR. FENTON:
Your Honor, the Government had one
question about the order that you had issued this
morning.
Since the Court has reset the date for the
Kastigar hearing, the Government assumes that the Court
is also resetting the date for the Government's
submission of its Kastigar brief --
THE COURT:
Yes.
MR. FENTON:
-- which is due on May 24; is that
correct, Your Honor?
23
EXHIBIT A
Case 2:20-cr-00579-SVW     Document 439-2     Filed 06/07/21     Page 23 of 49   Page ID
#:4918

ROUGH TRANSCRIPT
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
UNITED STATES DISTRICT COURT
23
THE COURT:
Yes, that's correct.
That's
correct.
MR. FENTON:
Thank you, Your Honor.
MR. RAM:
Your Honor, this is Ashwin Ram.
I'm
not pictured on the screen for some reason.
My camera
is on.
THE COURT:
Oh, okay.
MR. RAM:
But I'm the black box.
THE COURT:
Ram?
MR. RAM:
Yes, Your Honor, representing
Richard Ayvazyan.
I just have a couple housekeeping
issues to address.
And before we do, Your Honor
mentioned the order from this morning.
A couple points
to raise with Your Honor for consideration:
The first
is, that one part of the Kastigar inquiry and challenge
is to the original and superseding indictments
themselves.
And specifically that there is a direct
connection between evidence in those indictments and
information that would be subject to the Kastigar
hearing.
So for that reason, Your Honor, we'd like to
ask the Court if it -- with respect to the defendant
Ayvazyan and Mari Terabelian, if there could be a
Kastigar hearing before the trial, because otherwise,
the defect is in the actual charging document itself.
THE COURT:
I'm following what you're saying.
24
EXHIBIT A
Case 2:20-cr-00579-SVW     Document 439-2     Filed 06/07/21     Page 24 of 49   Page ID
#:4919

ROUGH TRANSCRIPT
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
UNITED STATES DISTRICT COURT
24
MR. RAM:
Yeah.
THE COURT:
What's your other point?
MR. RAM:
The other point, Your Honor, is just
in terms of the mechanics of this and prejudice to --
potential prejudice to the Defense -- so in other words,
if there's information the Government knows is derived
from that information, that would -- obviously, that
wouldn't be admissible at the proceedings, regardless,
right?
And that really is the point for clarification.
So in other words, if the Government is aware of a
witness statement or piece of evidence that could be
directly tied or indirectly tied to any of the tainted
evidence, which is some, you know, 500,000 pages of
information, is it the Court's position that the
Government is precluded from using that information at
trial, Your Honor?
THE COURT:
Well, the -- the -- the -- the
order was clear.
It is -- there is a taint from using
coerced testimony.
I've made the Court's position clear
in the order, and it's up to the Government to abide by
the -- the -- the well-established case law.
And at
this point, it's my view, given as you said, the number
of exhibits and documents, it would be best -- or the
only feasible way I know of is to have the trial and
have the Kastigar hearing after the trial.
And so the
25
EXHIBIT A
Case 2:20-cr-00579-SVW     Document 439-2     Filed 06/07/21     Page 25 of 49   Page ID
#:4920

ROUGH TRANSCRIPT
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
UNITED STATES DISTRICT COURT
25
Government, I'm sure, whether they agree with my ruling
or not, is to present its case in accordance.
Is there
any problem with that, Mr. Fenton?
MR. FENTON:
No, Your Honor.
The Government
fully understands the Court's order and fully intends to
comply.
THE COURT:
Okay.
Well, thank you all for your
participation.
MR. RAM:
Your Honor, just real quick on the
housekeeping issues, if we could.
THE COURT:
Is that Ram?
MR. RAM:
Yes, yes, Your Honor.
So we'll proceed with the housekeeping issues.
One thing I'd request if Your Honor would indulge, if we
could file on the record just a motion speaking to the
actual taint and -- both, the allegation of the taint
and the indictment itself, so it's on the record,
Your Honor.
It will be a very brief motion just to
highlight --
THE COURT:
You don't need my permission to
file anything.
If you think you have something that's
in your client's best interest or you think it's
necessary to protect the record, by all means go
forward.
MR. RAM:
I appreciate that, Your Honor.
And I
26
EXHIBIT A
Case 2:20-cr-00579-SVW     Document 439-2     Filed 06/07/21     Page 26 of 49   Page ID
#:4921

ROUGH TRANSCRIPT
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
UNITED STATES DISTRICT COURT
26
won't waste the Court's time highlighting those issues.
We'll reserve that for our filing.
I believe Mr.
Silverman is going to highlight a few of the
housekeeping issues in the advance of trial.
MR. SILVERMAN:
Good afternoon, Your Honor.
THE COURT:
Oh, there he is.
Nicholas
Silverman.
MR. LITTRELL:
Yes, Your Honor.
I also
represent Mr. Ayvazyan.
And I just had a few small
discovery-related housekeeping matters that we wanted to
raise on the record today.
The first is that the
Court's order requires the Government, obviously, to
produce its exhibits and the witness list by June 1st.
We wanted to request on the record that they also
produce grand jury transcripts of -- of witness
testimony.
Those haven't been produced to us yet, and
my understanding is they would be covered by the gist of
the Court's order, if not the latter.
THE COURT:
What's your position in that
regard, Mr. Fenton?
MR. FENTON:
The Government -- and the
Government's taken this position in the various briefing
on the motions for prosecutorial misconduct -- the
defendants have not demonstrated a need for those
transcripts.
27
EXHIBIT A
Case 2:20-cr-00579-SVW     Document 439-2     Filed 06/07/21     Page 27 of 49   Page ID
#:4922

ROUGH TRANSCRIPT
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
UNITED STATES DISTRICT COURT
27
THE COURT:
So in other words, the transcripts
are -- are -- are not within the Jencks Act, correct?
MR. FENTON:
That's is correct, Your Honor.
If, however, the agent who testified before the grand
jury were to take the stand, the Government would
disclose those transcripts in compliance with the
Jencks's Act.
THE COURT:
And so with regard to the
categories of witnesses that you just mentioned, aside
from custodian witnesses, did these witnesses testify
before the grand jury?
MR. FENTON:
No, Your Honor.
THE COURT:
All right.
That clears up the --
was there something else, Mr. Silverman?
MR. SILVERMAN:
Yes, Your Honor.
Our discovery
letter which the Government filed yesterday afternoon
contained three categories of information unrelated to
the Kastigar hearing which we feel that the Government
should produce by June 1st at the latest, but first was
a list of loans that the Government alleges are part of
the 151 loans in the paragraph 32 of the superseding
indictment, so we know what the allegations are that our
clients are allegedly responsible for.
THE COURT:
So you -- you want to have a
description of the loan -- of the loan in terms of
28
EXHIBIT A
Case 2:20-cr-00579-SVW     Document 439-2     Filed 06/07/21     Page 28 of 49   Page ID
#:4923

ROUGH TRANSCRIPT
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
UNITED STATES DISTRICT COURT
28
what -- what would you want?
What type of description?
MR. SILVERMAN:
The date, the lender, the
company and the amount would allow us to identify which
loans are in question.
THE COURT:
And which loans, PPP and the
other....
MR. SILVERMAN:
The EIDL, Your Honor.
THE COURT:
The EIDL.
Any objection to that,
Mr. Fenton?
MR. FENTON:
No, Your Honor.
THE COURT:
All right then, that will be done.
MR. SILVERMAN:
The second category of
information that we have requested, Your Honor, was
Brady information and evidence in the possession of any
arm of the Prosecution, including, for example, the LAPD
which has participated with the federal Government in
this case on search warrant execution in this case and
investigation.
THE COURT:
Well, I mean, Brady is the
Government's obligation.
They're always on notice that
they have a -- a -- a duty to honor both, the letter and
spirit of Brady.
I'm sure the Government is aware of
that.
And I'm sure the Government is aware that the
consequences of not abiding by that can be severe.
I
can't do anymore at this point.
I don't know what's in
29
EXHIBIT A
Case 2:20-cr-00579-SVW     Document 439-2     Filed 06/07/21     Page 29 of 49   Page ID
#:4924

ROUGH TRANSCRIPT
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
UNITED STATES DISTRICT COURT
29
the recesses of their files.
MR. SILVERMAN:
Yes, Your Honor.
The third
category in our letter was that the Government should be
compelled to produce -- or at least identify the results
of the responsiveness review from the phones that it
seized under the search warrant.
These are the --
THE COURT:
I'm not following what you're
saying, "responsiveness"?
MR. SILVERMAN:
Yes, Your Honor.
THE COURT:
What does that mean?
MR. SILVERMAN:
Rule 41 permits the Government
to temporarily over-seize electronic data and then
engage in a responsiveness review to see which files are
responsive.
THE COURT:
I see.
Yes.
MR. SILVERMAN:
We are -- we have requested
that the Government identify which files were identified
as responsive, and therefore, have been seized from the
four co-defendants whose phones were seized and maybe
used at trial.
THE COURT:
What's your position in that
regard, Mr. Fenton?
MR. FENTON:
Your Honor, the deadline under the
magistrate judge's order is July 3rd.
So the Government
is still continuing its responsiveness review.
With
30
EXHIBIT A
Case 2:20-cr-00579-SVW     Document 439-2     Filed 06/07/21     Page 30 of 49   Page ID
#:4925

ROUGH TRANSCRIPT
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
UNITED STATES DISTRICT COURT
30
that said, we fully expect to identify for that -- for
the Court and for all parties the exhibits that we
intend to use at trial by June 1st, and I think that by
the time that we are ready to go to trial on June 15,
the Government will have fully completed its
responsiveness review and can share that
information with --
THE COURT:
I want to make sure I'm following
this issue correctly.
What I'm perceiving is that
Mr. Silverman is saying that when these electronic
devices were seized, the Government is allowed to peruse
them at least in the first instance to see what is -- is
pertinent to the warrant or the investigation.
And
what, again, is your point?
I am correct; that's part
of it, right, Mr. Silverman?
MR. SILVERMAN:
Yes, Your Honor.
THE COURT:
And what do you want the Government
to tell you?
I mean, that is probably what you did.
I
mean, so what more do you want to know?
MR. SILVERMAN:
Your Honor, based on the fact
that the responsiveness review is apparently still
ongoing, we anticipate making a motion to suppress which
we will draft and put on file in the near future.
MR. FENTON:
The deadline for the Government to
complete its responsiveness review is July 3rd, pursuant
31
EXHIBIT A
Case 2:20-cr-00579-SVW     Document 439-2     Filed 06/07/21     Page 31 of 49   Page ID
#:4926

ROUGH TRANSCRIPT
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
UNITED STATES DISTRICT COURT
31
to the magistrate judge's order.
The defendant sounds
like they're going to be -- I guess they're filing
motions to suppress evidence that is being reviewed in
compliance with a Court order.
THE COURT:
Why aren't they -- why aren't
things being reviewed at this juncture?
The indictment
originally which at least contained the outline of many
of the charges, not all -- was November of 2020.
This
indictment -- the amended indictment by my calculation,
was March -- some date in March -- it's a long time
ago -- and weren't these phones seized -- are these the
phones that were seized in the searches?
MR. FENTON:
Yes, the searches from the
premises.
THE COURT:
What date was that?
MR. FENTON:
In November -- complete -- so,
Your Honor --
THE COURT:
Why does it take all this time for
the Government to do things?
MR. FENTON:
Well, the Government -- the
Government produced a complete forensic copy of these
devices to Defense counsel months ago, beginning in
December.
THE COURT:
When you say "forensic copy," what
do you mean?
32
EXHIBIT A
Case 2:20-cr-00579-SVW     Document 439-2     Filed 06/07/21     Page 32 of 49   Page ID
#:4927

ROUGH TRANSCRIPT
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
UNITED STATES DISTRICT COURT
32
MR. FENTON:
A copy of the data that is
contained in the phones.
THE COURT:
When you say "data," what does that
mean?
MR. FENTON:
So for a smart phone like an
iPhone that would include text messages, e-mails, web
browser history, things of that nature.
THE COURT:
So wait, did you just tell them
what you're telling me now, just the generic description
of what was found or did it go further than that?
MR. FENTON:
No, so, Your Honor, we made a copy
of the devices and provided them to the Defense, and
then we did a filter review for privilege.
So what has
taken time is that we have a filter team that is
reviewing the data on the phone to ensure that no
privileged communications are released to the
prosecution team.
And that is what -- that's what's
taking the time is the filter review.
THE COURT:
And that has been ongoing since
November?
MR. FENTON:
Yes, Your Honor.
THE COURT:
I see.
All right.
I understand.
Okay.
MR. RAM:
Your Honor --
THE COURT:
Yes.
33
EXHIBIT A
Case 2:20-cr-00579-SVW     Document 439-2     Filed 06/07/21     Page 33 of 49   Page ID
#:4928

ROUGH TRANSCRIPT
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
UNITED STATES DISTRICT COURT
33
MR. RAM:
-- if I may, this is Mr. Ram again.
So in the black bottom screen, no camera -- so this is
part of the problem:
You know, the Government said on
June 1st it's going to finally tell us which of the 151
loans that they've alleged are involved in the
conspiracies they charged are -- are going to be
relevant to trial.
It's the same issue with this
responsiveness review.
They gave us an image of an --
of entire devices; but the image is not the evidence
that the Government's allowed to even have or seize or
used for trial, right?
So they gave us -- it's like a
needle in a haystack issue.
They say, here's the
haystack.
We'll let you know which needles we're going
to pull out and use at trial later -- or that we can
even use under the terms of the search warrant.
So
we're in the -- in the difficult position of trying to
prepare for a trial, right?
And we're ready -- you
know, we're ready -- we've been asking for this trial
for months now, but the Government hasn't identified the
actual evidence that's going to be in play here or near
the universe in any way.
It's unclear --
THE COURT:
I understand what you're saying.
You don't have to say it twice.
The -- the -- essentially, what the
defendant -- or this defendant wants, I guess -- who do
34
EXHIBIT A
Case 2:20-cr-00579-SVW     Document 439-2     Filed 06/07/21     Page 34 of 49   Page ID
#:4929

ROUGH TRANSCRIPT
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
UNITED STATES DISTRICT COURT
34
you represent, which defendant?
MR. RAM:
Mr. Richard Ayvazyan.
THE COURT:
So that's the defendant that has
been sort of making the motions and doing the brief
writing that the other defendants -- or most of them
have joined in on?
So --
MR. RAM:
And, Your Honor, I didn't --
THE COURT:
Why is it, Mr. Fenton, that you
can't, at least, give the defendants the -- the identity
or description of the loans that -- that you're going to
attempt to have evidence about?
MR. FENTON:
Your Honor, we -- we will give
them a list, but we have produced discovery with respect
to all of those loans.
THE COURT:
But in other words --
MR. FENTON:
In a detailed e-mail.
THE COURT:
In discovery, there are -- let me
clarify this:
When you gave the loan files to the
Defense, were those all the loan files that you intend
to use?
MR. FENTON:
Yes, Your Honor.
THE COURT:
So --
MR. FENTON:
It's their e-mails.
THE COURT:
So in other words, the -- it wasn't
35
EXHIBIT A
Case 2:20-cr-00579-SVW     Document 439-2     Filed 06/07/21     Page 35 of 49   Page ID
#:4930

ROUGH TRANSCRIPT
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
UNITED STATES DISTRICT COURT
35
like you gave the defendants a thousand loan files, and
you plan to use a hundred.
Every loan file that you
gave to them is going to be the subject of some count,
conspiracy or substantive?
MR. FENTON:
No, there are some additional
loans that are included there, but it is not a thousand.
THE COURT:
Well --
MR. FENTON:
Well, there are some additional
loans, but --
THE COURT:
Well, you say a hundred 50 loans or
thereabouts, how many additional loan files did you
provide to the Defense in the discovery?
MR. FENTON:
I think that we have produced
around 250 loan files.
THE COURT:
So the universe is 250?
MR. FENTON:
Right.
THE COURT:
And you're intending to use a
hundred 50 to 250?
MR. FENTON:
Right.
THE COURT:
Why can't you at this point tell
them what the hundred 50 are?
MR. FENTON:
Your Honor, we can, and we are
agreeable to do so.
THE COURT:
Well, do it.
Do it now.
Let's not
wait.
Do it now.
36
EXHIBIT A
Case 2:20-cr-00579-SVW     Document 439-2     Filed 06/07/21     Page 36 of 49   Page ID
#:4931

ROUGH TRANSCRIPT
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
UNITED STATES DISTRICT COURT
36
MR. FENTON:
We will do it.
Yes, Your Honor.
THE COURT:
Now.
Just get back there and do
it.
And with regard to the other -- the phone --
digital device issues, am I correctly understanding that
when these phones were seized, pictures were taken of
what was on the phone?
MR. FENTON:
Some pictures were taken at the
time that they were seized -- this is for the phones
that were seized at the border stop.
THE COURT:
It wasn't like a Miami situation?
MR. FENTON:
Correct, Your Honor.
Correct.
THE COURT:
So the phones that were -- or
phone, whatever it was seized there, there were pictures
taken of it, correct?
MR. FENTON:
That's correct, Your Honor.
THE COURT:
And were those pictures provided to
the defendant?
MR. FENTON:
Yes, Your Honor.
They were
produced in discovery.
THE COURT:
Okay.
So now, we're talking about
digital devices really cell phones, correct.
MR. FENTON:
Yes, Your Honor.
THE COURT:
They -- they -- these are the ones
that were seized in these -- in the searches of the --
37
EXHIBIT A
Case 2:20-cr-00579-SVW     Document 439-2     Filed 06/07/21     Page 37 of 49   Page ID
#:4932

ROUGH TRANSCRIPT
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
UNITED STATES DISTRICT COURT
37
of some of the defendant's homes, correct?
MR. FENTON:
That is correct, Your Honor.
THE COURT:
And you -- in those digital
devices, are you saying that you still haven't decided
which -- what information in those -- on those phones
you intend to use?
MR. FENTON:
No, Your Honor.
We have produced
a report of that information to the Defense counsel, and
now are in the process of identifying which pieces of
information we'll seize and use as exhibits at trial.
And we will do that by June 1st by the deadline.
THE COURT:
And so what is going to be the
universe of -- of text messages or other things that you
think are relevant on these phones at trial?
MR. FENTON:
So the universe will include text
messages between some of the defendants and also some
pictures -- digital photographs that were on -- that are
on these phones; and it will be a discreet set.
THE COURT:
What will the photographs be of?
MR. FENTON:
The photographs are primarily of
credit cards, identification documents, PPP loans, loan
applications, and those are the primary accounts.
THE COURT:
And so are you saying at this time
you don't know which of those items will be used?
MR. FENTON:
Your Honor, we're saying that
38
EXHIBIT A
Case 2:20-cr-00579-SVW     Document 439-2     Filed 06/07/21     Page 38 of 49   Page ID
#:4933

ROUGH TRANSCRIPT
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
UNITED STATES DISTRICT COURT
38
we're in the process of making final decisions about
which ones we will use at trial.
And that -- and our
goal --
THE COURT:
But -- but some of these things,
like the loan applications -- are these loan
applications that were different than the ones in this
case?
MR. FENTON:
No, no, Your Honor.
THE COURT:
So -- so some of this information
the defendants have already?
MR. FENTON:
Well, the defendants have all of
this information, because we made available the report
of the phones, and we've provided an image, and we've
also provided a searchable report.
So, for example,
Your Honor, in order to run a search --
THE COURT:
What do you mean by "an image"?
An
image of what?
MR. FENTON:
It's a report.
So the report is a
viewable image of the contents of the phone.
So the
defendants can go in to that -- to the report.
And if
they wanted to search it, for -- so, for example,
Iuliia Zhadko which is one of the names that you've seen
discussed a lot in this case -- the defendants can type
that name into the search function and search the entire
content of the phone.
The defendants have that ability
39
EXHIBIT A
Case 2:20-cr-00579-SVW     Document 439-2     Filed 06/07/21     Page 39 of 49   Page ID
#:4934

ROUGH TRANSCRIPT
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
UNITED STATES DISTRICT COURT
39
to get it, because we've already produced all that data
to them.
THE COURT:
I see.
Okay.
MR. FENTON:
So the defendants are essentially
saying, we haven't identified which documents we're
going to use at trial.
THE COURT:
I understand your position, but on
June 3rd, you intend to go the extra step?
MR. FENTON:
That's correct, Your Honor.
THE COURT:
All right.
Well, that's all I
wanted to accomplish now.
We may need to have another
hearing.
I mean, it is really up to the parties, but it
will be helpful I think to everyone if things that are
not in dispute, at least as to authenticity, are agreed
on; and we can trim down the number of -- of witnesses.
Okay.
Thank you.
MR. JOHNSON:
Your Honor, this is Peter Johnson
on behalf of Vahe Dadyan.
I know that the Court
described the reading of the portions of the indictment
that will be read to the jury.
I would just simply ask
on the record, because I didn't hear everything -- that
the Government identify those specific portions of the
indictment that will be read and produce that to the
Defense lawyers.
THE COURT:
I'll make that order.
40
EXHIBIT A
Case 2:20-cr-00579-SVW     Document 439-2     Filed 06/07/21     Page 40 of 49   Page ID
#:4935

ROUGH TRANSCRIPT
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
UNITED STATES DISTRICT COURT
40
MR. JOHNSON:
Thank you.
THE COURT:
Thank you.
That's it.
Thank you,
Your Honor.
MS. WIRSCHING:
Thank you, Your Honor.
(Whereupon proceeding adjourned.)
- - -
41
EXHIBIT A
Case 2:20-cr-00579-SVW     Document 439-2     Filed 06/07/21     Page 41 of 49   Page ID
#:4936

ROUGH TRANSCRIPT
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
UNITED STATES DISTRICT COURT
41
C E R T I F I C A T E
UNITED STATES OF AMERICA
vs.
RICHARD AYVAZYAN, et al.
:
:
:
No. CR 20-00579-SVW
I, MARIA BUSTILLOS, OFFICIAL COURT REPORTER, IN AND FOR THE
UNITED STATES DISTRICT COURT FOR THE CENTRAL DISTRICT OF
CALIFORNIA, DO HEREBY CERTIFY THAT PURSUANT TO SECTION 753,
TITLE 28, UNITED STATES CODE, THE FOREGOING IS A TRUE AND
CORRECT TRANSCRIPT OF THE STENOGRAPHICALLY REPORTED
PROCEEDINGS HELD IN THE ABOVE-ENTITLED MATTER AND THAT THE
TRANSCRIPT PAGE FORMAT IS IN CONFORMANCE WITH THE REGULATIONS
OF THE JUDICIAL CONFERENCE OF THE UNITED STATES.
FEES CHARGED FOR THIS TRANSCRIPT, LESS ANY CIRCUIT FEE
REDUCTION AND/OR DEPOSIT, ARE IN CONFORMANCE WITH THE
REGULATIONS OF THE JUDICIAL CONFERENCE OF THE UNITED STATES.
/S/                         
05/28/2021  
MARIA R. BUSTILLOS
DATE
OFFICIAL REPORTER
42
EXHIBIT A
Case 2:20-cr-00579-SVW     Document 439-2     Filed 06/07/21     Page 42 of 49   Page ID
#:4937

ROUGH TRANSCRIPT
/
/S [1] - 41:22
0
05/27/2021 [1] - 41:22
1
1 [2] - 4:17, 21:15
10036 [1] - 4:13
101 [1] - 4:9
1050 [2] - 3:14, 3:19
10th [1] - 21:25
1114 [1] - 4:12
12254 [1] - 1:22
12TH [1] - 2:6
13 [2] - 19:15, 21:15
1330 [1] - 2:24
1349 [1] - 20:16
1400 [2] - 2:10, 2:15
15 [1] - 30:4
151 [2] - 27:21, 33:4
1518 [1] - 4:21
1900 [1] - 2:20
1935 [1] - 3:10
1956(h [1] - 20:17
1:41 [1] - 6:3
1ST [1] - 1:23
1st [7] - 10:21, 11:4,
26:13, 27:19, 30:3,
33:4, 37:11
2
20-00579-SVW [3] -
1:10, 6:5, 41:6
20036 [1] - 2:25
2006 [1] - 9:19
202)320-0539 [1] -
2:11
202)429-8096 [1] -
2:25
2020 [1] - 31:8
2021 [2] - 1:18, 6:1
20530 [1] - 2:10
21 [2] - 1:18, 6:1
212)506-3900 [1] -
4:13
213 [1] - 1:24
213)204-4200 [1] -
3:15
213)439-9443 [1] -
2:21
213)528-3200 [1] - 4:6
213)816-1700 [1] -
3:20
213)894-0141 [1] -
2:16
213)894-6527 [1] - 2:7
216 [1] - 3:10
24 [1] - 22:24
ROUGH TRANSCRIPT
250 [3] - 35:14, 35:15,
35:18
27 [2] - 19:18, 21:19
27th [1] - 17:5
28 [1] - 41:13
3
310)295-1785 [1] -
3:25
312 [2] - 2:5, 2:15
32 [1] - 27:21
350 [2] - 1:23, 3:6
3900 [1] - 4:17
3rd [3] - 29:24, 30:25,
39:8
4
40 [1] - 21:9
409 [1] - 3:23
41 [1] - 29:11
415)365-6717 [1] -
4:18
42 [1] - 21:9
424)901-9280 [1] -
3:11
4455 [1] - 1:23
5
50 [3] - 35:10, 35:18,
35:21
500,000 [1] - 24:13
5TH [2] - 2:20, 4:5
6
6 [1] - 5:2
601 [1] - 4:5
633 [1] - 2:20
651 [1] - 3:24
7
720 [1] - 4:5
753 [1] - 41:12
8
800 [2] - 3:13, 3:19
818)240-2444 [1] -
4:10
818)242-8201 [1] -
4:22
894-2739 [1] - 1:24
9
90012 [3] - 1:24, 2:6,
2:16
ROUGH TRANSCRIPT
90017 [2] - 3:14, 3:20
90071 [2] - 2:21, 4:6
902 [1] - 12:25
90277 [1] - 3:24
903 [1] - 3:5
91201 [1] - 4:21
91203 [1] - 4:10
91208 [1] - 3:11
92673 [1] - 3:6
94105 [1] - 4:18
949)369-3700 [1] - 3:7
A
abide [1] - 24:20
abiding [1] - 28:24
ability [1] - 38:25
ABOVE [1] - 41:15
ABOVE-ENTITLED [1]
- 41:15
absence [4] - 13:22,
14:4, 14:8, 14:12
abuse [1] - 18:10
accomplish [1] -
39:11
accordance [1] - 25:2
accounts [1] - 37:22
acronyms [2] - 12:6,
12:7
Act [2] - 27:2, 27:7
action [2] - 17:10,
17:24
actual [4] - 20:12,
23:24, 25:16, 33:20
additional [5] - 13:15,
13:17, 35:5, 35:8,
35:11
address [2] - 13:3,
23:12
adjourned [1] - 40:5
Administration [1] -
8:6
admissible [1] - 24:8
admit [1] - 14:21
advance [3] - 9:20,
10:21, 26:4
affirms [1] - 11:19
afternoon [4] - 6:8,
6:11, 26:5, 27:16
agency [2] - 12:12,
12:13
agenda [1] - 22:16
agent [1] - 27:4
agents [1] - 7:9
ago [3] - 19:8, 31:11,
31:22
agree [2] - 18:4, 25:1
agreeable [1] - 35:23
agreed [1] - 39:14
agreement [4] - 10:7,
10:13, 10:14, 10:17
agreements [1] -
10:19
ahead [3] - 8:2, 9:8,
13:19
ROUGH TRANSCRIPT
Ahn [1] - 6:10
AHN [1] - 2:14
al [7] - 1:12, 2:19, 3:3,
3:17, 4:16, 6:6, 41:7
allegation [1] - 25:16
allegations [1] - 27:22
allege [1] - 20:12
alleged [5] - 8:20,
15:14, 20:13, 20:21,
33:5
allegedly [2] - 8:18,
27:23
alleges [1] - 27:20
allow [8] - 18:11, 19:9,
19:12, 19:14, 21:10,
21:20, 22:6, 28:3
allowed [2] - 30:11,
33:10
ALMANECER [1] - 3:5
ALPHA [1] - 3:10
amended [3] - 19:9,
19:16, 31:9
AMERICA [4] - 1:7,
2:3, 4:3, 41:5
America [1] - 6:5
AMERICAS [1] - 4:12
amount [2] - 17:18,
28:3
AND [3] - 41:10,
41:13, 41:15
AND/OR [1] - 41:19
ANGELES [9] - 1:17,
1:24, 2:6, 2:16, 2:21,
3:14, 3:20, 4:6, 6:1
anticipate [6] - 9:15,
13:23, 14:3, 14:6,
14:10, 30:22
anticipates [1] - 7:9
ANY [1] - 41:18
anyway [1] - 18:7
appearances [1] - 6:7
appearing [1] - 6:9
applicable [1] - 17:7
application [1] - 15:16
applications [8] -
12:5, 12:9, 13:21,
14:2, 15:15, 37:22,
38:5, 38:6
applied [2] - 15:6,
20:1
apply [4] - 14:23,
15:21, 15:25, 16:8
appreciate [1] - 25:25
appreciated [1] -
13:13
approach [1] - 17:5
appropriate [1] -
12:12
ARE [1] - 41:19
argument [6] - 17:23,
18:11, 18:14, 18:19,
18:25
argumentative [1] -
17:21
arguments [1] - 17:23
ROUGH TRANSCRIPT
UNITED STATES DISTRICT COURT
42
arm [1] - 28:15
Arman [1] - 6:20
art [1] - 18:1
Artur [1] - 6:18
ASHWIN [1] - 2:19
Ashwin [2] - 6:12,
23:4
aside [2] - 15:13, 27:9
assumes [1] - 22:20
AT [1] - 6:3
attached [1] - 14:2
attempt [1] - 34:12
ATTORNEY [2] - 2:4,
2:12
authenticity [6] -
11:21, 11:23, 12:1,
12:11, 12:14, 39:14
available [2] - 22:11,
38:12
AVENUE [3] - 2:10,
2:24, 4:12
aware [5] - 9:18,
18:12, 24:10, 28:22,
28:23
AYVAZYAN [5] - 1:12,
2:19, 3:17, 4:16,
41:7
Ayvazyan [7] - 6:6,
6:12, 6:18, 23:11,
23:22, 26:9, 34:2
B
bank [16] - 8:10, 8:12,
8:13, 8:15, 8:20,
12:2, 12:4, 12:5,
12:15, 12:18, 13:1,
20:10, 20:11, 20:22,
21:15
banks [4] - 8:22, 8:24,
8:25, 9:4
based [1] - 30:20
BEACH [1] - 3:24
began [1] - 21:23
beginning [1] - 31:22
begins [3] - 19:11,
21:8, 21:13
behalf [3] - 6:12,
15:16, 39:18
BEHALF [6] - 2:3,
2:18, 3:3, 3:17, 4:3,
4:15
benefits [1] - 11:16
best [4] - 16:16, 18:6,
24:23, 25:22
between [4] - 19:24,
20:3, 23:18, 37:16
BIENERT [2] - 3:3, 4:3
black [2] - 23:8, 33:2
bond [1] - 16:19
border [1] - 36:10
borrowers [1] - 15:14
bottom [1] - 33:2
BOULEVARD [4] -
3:13, 3:19, 4:9, 4:21
43
EXHIBIT A
Case 2:20-cr-00579-SVW     Document 439-2     Filed 06/07/21     Page 43 of 49   Page ID
#:4938

ROUGH TRANSCRIPT
box [1] - 23:8
boxes [1] - 22:1
Brady [3] - 28:14,
28:19, 28:22
BRAND [1] - 4:9
brief [3] - 22:22,
25:18, 34:4
briefing [1] - 26:22
browser [1] - 32:7
bunch [1] - 12:3
Business [1] - 8:6
business [3] - 12:4,
15:21, 16:1
BUSTILLOS [3] - 1:21,
41:10, 41:23
butchered [1] - 16:17
BY [15] - 2:5, 2:9, 2:14,
2:19, 2:23, 3:4, 3:9,
3:13, 3:18, 3:22, 4:4,
4:9, 4:12, 4:16, 4:20
C
C.S.R [1] - 1:22
CA [12] - 2:6, 2:16,
2:21, 3:6, 3:11, 3:14,
3:20, 3:24, 4:6, 4:10,
4:18, 4:21
calculation [1] - 31:9
CALIFORNIA [5] - 1:2,
1:17, 1:24, 6:1,
41:12
California [2] - 14:3,
14:6
CALLE [1] - 3:5
camera [2] - 23:5,
33:2
cannot [1] - 10:24
cards [1] - 37:21
cart [4] - 7:11, 7:15,
7:16, 7:17
case [11] - 11:19,
18:17, 19:2, 21:13,
24:21, 25:2, 28:17,
38:7, 38:23
cases [3] - 18:25, 20:2
categories [7] - 7:6,
8:8, 11:10, 11:21,
13:2, 27:9, 27:17
category [6] - 7:13,
9:14, 14:16, 16:11,
28:12, 29:3
Catherine [1] - 6:10
CATHERINE [1] - 2:14
causes [1] - 17:24
cell [1] - 36:22
CENTRAL [2] - 1:2,
41:11
certain [4] - 11:14,
13:1, 13:23, 14:7
certainly [1] - 17:19
certifications [1] -
13:4
CERTIFY [1] - 41:12
challenge [1] - 23:15
ROUGH TRANSCRIPT
charge [1] - 19:23
charged [1] - 33:6
CHARGED [1] - 41:18
charges [1] - 31:8
charging [1] - 23:24
chart [2] - 10:2, 10:10
charts [2] - 9:20, 9:25
cheating [1] - 19:2
CHRISTOPHER [1] -
2:9
Christopher [1] - 6:9
Circuit [3] - 17:8,
17:13, 17:15
CIRCUIT [1] - 41:18
circulate [1] - 10:15
circulated [4] - 10:6,
10:13, 12:24, 13:7
clarification [1] - 24:9
clarify [1] - 34:19
clear [2] - 24:18, 24:19
clears [1] - 27:13
CLEMENTE [1] - 3:6
client's [1] - 25:22
clients [1] - 27:23
close [1] - 22:10
co [2] - 6:13, 29:19
co-counsel [1] - 6:13
co-defendants [1] -
29:19
COAST [1] - 3:23
Code [1] - 9:19
CODE [1] - 41:13
coerced [1] - 24:19
column [1] - 10:1
commit [2] - 20:22,
20:24
communications [1] -
32:16
company [1] - 28:3
compelled [1] - 29:4
complete [3] - 30:25,
31:16, 31:21
completed [1] - 30:5
compliance [2] - 27:6,
31:4
comply [2] - 11:8,
25:6
concerned [1] - 21:22
CONFERENCE [4] -
1:16, 5:2, 41:17,
41:20
conference [1] - 7:1
CONFORMANCE [2] -
41:16, 41:19
CONNECTICUT [1] -
2:24
connection [1] - 23:18
consequences [1] -
28:24
consider [1] - 12:14
consideration [1] -
23:14
consistent [1] - 22:3
conspiracies [2] -
20:20, 33:6
ROUGH TRANSCRIPT
conspiracy [19] -
19:17, 19:23, 19:24,
20:2, 20:4, 20:5,
20:9, 20:13, 20:16,
20:21, 20:23, 20:24,
21:1, 21:3, 21:6,
21:15, 21:16, 35:4
CONT'D [2] - 3:1, 4:1
contained [3] - 27:17,
31:7, 32:2
content [1] - 38:25
contents [1] - 38:19
continuing [1] - 29:25
convey [1] - 17:18
copies [1] - 7:24
copy [6] - 10:10,
10:21, 31:21, 31:24,
32:1, 32:11
corporate [1] - 15:14
correct [24] - 8:11,
11:6, 12:8, 15:17,
15:18, 15:22, 15:23,
19:17, 20:14, 20:15,
22:25, 23:1, 23:2,
27:2, 27:3, 30:14,
36:12, 36:15, 36:16,
36:22, 37:1, 37:2,
39:9
CORRECT [1] - 41:14
correctly [2] - 30:9,
36:5
counsel [8] - 6:13,
9:21, 10:8, 22:5,
22:7, 22:8, 31:22,
37:8
count [4] - 19:6,
19:19, 20:13, 35:3
country [1] - 15:2
counts [8] - 13:10,
15:4, 15:5, 15:24,
16:3, 19:13, 19:20
couple [3] - 19:8,
23:11, 23:13
course [2] - 21:11,
22:4
Court [11] - 11:7,
13:16, 13:17, 21:22,
22:2, 22:19, 22:20,
23:21, 30:2, 31:4,
39:18
court [1] - 21:13
COURT [111] - 1:1,
1:21, 6:3, 7:1, 7:13,
7:18, 7:22, 8:1, 8:10,
8:13, 8:19, 8:24, 9:4,
9:13, 9:17, 10:9,
10:16, 10:23, 11:1,
11:4, 11:9, 12:9,
13:5, 13:12, 13:19,
14:16, 15:4, 15:13,
15:19, 15:24, 16:3,
16:5, 16:9, 16:23,
16:25, 17:3, 20:8,
20:11, 20:18, 20:25,
21:4, 21:10, 22:15,
22:23, 23:1, 23:7,
ROUGH TRANSCRIPT
23:9, 23:25, 24:2,
24:17, 25:7, 25:11,
25:20, 26:6, 26:19,
27:1, 27:8, 27:13,
27:24, 28:5, 28:8,
28:11, 28:19, 29:7,
29:10, 29:15, 29:21,
30:8, 30:17, 31:5,
31:15, 31:18, 31:24,
32:3, 32:8, 32:19,
32:22, 32:25, 33:22,
34:3, 34:9, 34:16,
34:18, 34:23, 34:25,
35:7, 35:10, 35:15,
35:17, 35:20, 35:24,
36:2, 36:11, 36:13,
36:17, 36:21, 36:24,
37:3, 37:12, 37:19,
37:23, 38:4, 38:9,
38:16, 39:3, 39:7,
39:10, 39:25, 40:2,
41:10, 41:11
Court's [6] - 24:14,
24:19, 25:5, 26:1,
26:12, 26:18
court's [1] - 22:3
COURTHOUSE [1] -
1:22
courtroom [2] - 21:25,
22:1
COURTROOM [1] -
6:4
covered [1] - 26:17
CR [3] - 1:10, 6:5, 41:6
credit [1] - 37:21
CRIME [1] - 2:13
CRIMES [1] - 2:4
criminal [1] - 17:9
criticizes [1] - 17:15
cross [2] - 9:22, 10:25
cross-examine [2] -
9:22, 10:25
Cruz [1] - 21:23
custodian [2] - 16:11,
27:10
custodians [1] - 12:4
custody [1] - 16:18
D
D.C [2] - 2:10, 2:25
Dadyan [2] - 6:25,
39:18
data [5] - 29:12, 32:1,
32:3, 32:15, 39:1
date [7] - 10:22, 11:7,
22:19, 22:21, 28:2,
31:10, 31:15
DATE [1] - 41:23
days [1] - 19:8
deadline [3] - 29:23,
30:24, 37:11
deal [1] - 18:7
debate [1] - 12:10
December [1] - 31:23
ROUGH TRANSCRIPT
UNITED STATES DISTRICT COURT
43
decided [1] - 37:4
decisions [1] - 38:1
defect [1] - 23:24
defendant [14] - 6:12,
11:16, 16:6, 16:18,
21:25, 22:5, 22:6,
23:21, 31:1, 33:25,
34:1, 34:3, 36:18
defendant's [1] - 37:1
Defendants [1] - 1:13
defendants [20] -
8:18, 10:5, 15:6,
15:25, 16:7, 16:15,
19:5, 21:22, 26:24,
29:19, 34:5, 34:10,
35:1, 37:16, 38:10,
38:11, 38:20, 38:23,
38:25, 39:4
DEFENDANTS [4] -
2:18, 3:3, 3:17, 4:15
Defense [15] - 9:21,
10:8, 10:10, 11:12,
11:24, 12:21, 17:21,
18:24, 24:5, 31:22,
32:12, 34:20, 35:12,
37:8, 39:24
defenses [2] - 18:2,
18:3
definition [1] - 18:1
deft [1] - 18:12
delve [1] - 18:11
demonstrated [1] -
26:24
department [2] - 14:3,
14:19
DEPARTMENT [1] -
2:8
Department [3] - 14:6,
14:10, 14:20
DEPOSIT [1] - 41:19
DEPUTY [1] - 6:4
derivative [1] - 19:20
derived [1] - 24:6
describe [1] - 7:6
described [1] - 39:19
description [7] -
19:18, 21:6, 21:20,
27:25, 28:1, 32:9,
34:11
descriptive [1] - 19:16
designed [1] - 17:22
detailed [1] - 34:17
device [1] - 36:5
devices [9] - 7:12,
7:20, 7:25, 30:11,
31:22, 32:12, 33:9,
36:22, 37:4
difference [1] - 20:3
differences [1] - 19:23
different [5] - 8:8,
11:20, 17:23, 20:17,
38:6
difficult [1] - 33:16
digital [7] - 7:12, 7:20,
7:25, 36:5, 36:22,
37:3, 37:17
44
EXHIBIT A
Case 2:20-cr-00579-SVW     Document 439-2     Filed 06/07/21     Page 44 of 49   Page ID
#:4939

ROUGH TRANSCRIPT
direct [1] - 23:17
directly [1] - 24:12
disclose [1] - 27:6
discovery [6] - 26:10,
27:15, 34:14, 34:18,
35:12, 36:20
discovery-related [1]
- 26:10
discreet [1] - 37:18
discussed [2] - 12:21,
38:23
discussing [1] - 12:19
dispute [3] - 11:15,
18:5, 39:14
DISTRICT [5] - 1:1,
1:2, 1:5, 41:11
DIVISION [1] - 1:3
DMV [1] - 14:6
DO [1] - 41:12
doable [1] - 13:13
document [1] - 23:24
documents [4] -
12:25, 24:23, 37:21,
39:5
done [1] - 28:11
down [1] - 39:15
draft [4] - 10:6, 10:20,
10:21, 30:23
driver's [1] - 14:8
DRUG [1] - 2:13
due [2] - 10:21, 22:24
during [1] - 19:10
duty [1] - 28:21
E
e-mail [1] - 34:17
e-mails [2] - 32:6,
34:24
EDD [1] - 14:3
Edvard [1] - 6:23
effectively [1] - 9:22
EI [1] - 12:6
EIDL [6] - 8:4, 8:7,
12:6, 12:8, 28:7,
28:8
either [1] - 17:21
electronic [2] - 29:12,
30:10
elements [1] - 17:25
embarrassing [1] -
18:20
employee [1] - 14:4
employment [1] - 14:3
enable [1] - 22:2
enforce [1] - 19:4
ENFORCEMENT [1] -
2:13
engage [1] - 29:13
ensure [1] - 32:15
entire [2] - 33:9, 38:24
entirety [1] - 19:13
entities [1] - 15:15
ENTITLED [1] - 41:15
entity [1] - 15:17
ROUGH TRANSCRIPT
ESQ [12] - 2:5, 2:9,
2:19, 2:24, 3:5, 3:9,
3:18, 3:22, 4:4, 4:9,
4:16, 4:20
essentially [4] - 14:24,
17:24, 33:24, 39:4
establish [2] - 13:20,
14:24
established [1] -
24:21
et [7] - 1:12, 2:19, 3:3,
3:17, 4:16, 6:6, 41:7
European [1] - 15:1
Evidence [2] - 9:19,
19:25
evidence [14] - 7:11,
7:23, 7:25, 9:24,
18:15, 18:19, 23:18,
24:11, 24:13, 28:14,
31:3, 33:9, 33:20,
34:12
ex [1] - 11:11
examine [2] - 9:22,
10:25
examiner [1] - 7:15
examiners [1] - 7:11
example [7] - 8:19,
12:2, 13:23, 18:15,
28:15, 38:14, 38:21
exception [1] - 20:1
exchange [2] - 14:25,
15:1
execution [1] - 28:17
exhibit [1] - 10:7
exhibits [7] - 10:2,
10:20, 11:15, 24:23,
26:13, 30:2, 37:10
exist [1] - 15:11
expect [1] - 30:1
experience [2] - 9:25,
18:20
extent [4] - 11:11,
17:7, 17:10, 18:4
extra [1] - 39:8
F
fact [6] - 13:9, 13:25,
14:7, 19:25, 21:24,
30:20
fake [1] - 14:8
false [1] - 8:17
falsity [1] - 13:20
FBI [2] - 7:15, 7:20
FCIC [1] - 13:4
feasible [1] - 24:24
federal [2] - 21:13,
28:16
FEE [1] - 41:18
FEES [1] - 41:18
FENTON [84] - 2:9,
6:8, 7:8, 7:15, 7:17,
7:19, 7:23, 8:3, 8:11,
8:15, 8:21, 9:2, 9:9,
9:15, 10:4, 10:12,
ROUGH TRANSCRIPT
10:18, 10:24, 11:2,
11:6, 12:8, 12:23,
13:6, 13:14, 13:20,
14:18, 15:12, 15:18,
15:23, 16:2, 16:4,
16:7, 16:21, 16:24,
17:1, 20:7, 20:10,
20:15, 20:20, 21:2,
21:8, 22:17, 22:24,
23:3, 25:4, 26:21,
27:3, 27:12, 28:10,
29:23, 30:24, 31:13,
31:16, 31:20, 32:1,
32:5, 32:11, 32:21,
34:13, 34:17, 34:22,
34:24, 35:5, 35:8,
35:13, 35:16, 35:19,
35:22, 36:1, 36:8,
36:12, 36:16, 36:19,
36:23, 37:2, 37:7,
37:15, 37:20, 37:25,
38:8, 38:11, 38:18,
39:4, 39:9
Fenton [8] - 6:9,
12:22, 20:6, 25:3,
26:20, 28:9, 29:22,
34:9
few [2] - 26:3, 26:9
fictitious [2] - 15:8,
15:9
file [4] - 25:15, 25:21,
30:23, 35:2
filed [1] - 27:16
files [10] - 12:12, 13:1,
29:1, 29:13, 29:17,
34:19, 34:20, 35:1,
35:11, 35:14
filing [2] - 26:2, 31:2
filings [2] - 13:25,
14:1
filter [3] - 32:13,
32:14, 32:18
final [3] - 11:2, 11:5,
38:1
finally [1] - 33:4
FIRM [2] - 3:17, 4:20
first [8] - 17:12, 19:1,
19:15, 20:21, 23:14,
26:11, 27:19, 30:12
fit [1] - 8:8
five [1] - 9:16
flavor [1] - 19:21
floor [1] - 21:25
FLOOR [1] - 2:6
following [3] - 23:25,
29:7, 30:8
FOR [3] - 41:10,
41:11, 41:18
FORCE [1] - 2:13
FOREGOING [1] -
41:13
foreign [2] - 14:25,
15:1
forensic [3] - 7:19,
31:21, 31:24
forensically [1] - 7:24
ROUGH TRANSCRIPT
forget [2] - 12:6, 16:14
form [1] - 10:20
FORMAT [1] - 41:16
format [1] - 10:3
forth [2] - 12:20, 13:22
forward [1] - 25:24
foundation [1] - 12:1
foundations [1] - 12:4
four [2] - 16:7, 29:19
FRANCISCO [1] - 4:18
fraud [19] - 13:10,
19:19, 19:22, 19:24,
20:2, 20:4, 20:5,
20:8, 20:10, 20:11,
20:12, 20:22, 21:15,
21:16, 21:18, 21:19,
21:20
Frazer [1] - 6:15
FRAZER [1] - 4:4
FRED [2] - 4:8, 4:9
Freedman [1] - 6:22
FREEDMAN [3] - 3:17,
3:18, 6:22
FRIDAY [2] - 1:18, 6:1
full [2] - 11:17, 17:13
fully [5] - 11:7, 25:5,
30:1, 30:5
function [1] - 38:24
funds [2] - 8:12, 8:23
future [1] - 30:23
G
gallery [1] - 22:10
general [2] - 17:7,
17:16
GENERAL [1] - 2:4
generally [5] - 10:1,
17:12, 17:13, 17:17,
19:9
generic [1] - 32:9
gist [1] - 26:17
given [1] - 24:22
GLENDALE [3] - 3:11,
4:10, 4:21
GLENOAKS [1] - 4:21
goal [1] - 38:3
Government [47] -
6:9, 7:3, 7:9, 9:6,
14:14, 16:13, 16:19,
16:22, 17:21, 18:17,
18:23, 18:24, 19:3,
19:5, 19:10, 19:12,
22:17, 22:20, 24:6,
24:10, 24:15, 24:20,
25:1, 25:4, 26:12,
26:21, 27:5, 27:16,
27:18, 27:20, 28:16,
28:22, 28:23, 29:3,
29:11, 29:17, 29:24,
30:5, 30:11, 30:17,
30:24, 31:19, 31:20,
31:21, 33:3, 33:19,
39:22
Government's [5] -
ROUGH TRANSCRIPT
UNITED STATES DISTRICT COURT
44
11:19, 22:21, 26:22,
28:20, 33:10
grand [3] - 26:15,
27:4, 27:11
Grigorian [1] - 6:21
guaranteed [1] - 8:23
guess [2] - 31:2, 33:25
guidelines [1] - 22:3
H
hand [1] - 18:13
HANUSZ [3] - 3:12,
3:13, 6:21
Hanusz [1] - 6:21
hard [1] - 9:6
Hayrapetyan [4] -
6:20, 16:16, 16:17
haystack [2] - 33:12,
33:13
hear [2] - 20:18, 39:21
heard [1] - 21:23
HEARING [2] - 1:16,
5:2
hearing [6] - 22:20,
23:20, 23:23, 24:25,
27:18, 39:12
hearsay [1] - 20:1
HELD [1] - 41:15
helpful [1] - 39:13
HEREBY [1] - 41:12
highlight [2] - 25:19,
26:3
highlighting [1] - 26:1
HIGHWAY [1] - 3:23
history [2] - 14:22,
32:7
Homeland [2] - 14:11,
14:20
homes [1] - 37:1
honor [1] - 28:21
Honor [68] - 6:11, 7:8,
10:4, 10:12, 11:6,
12:23, 13:6, 13:14,
14:18, 15:3, 15:18,
15:23, 16:2, 16:21,
16:24, 20:7, 22:14,
22:17, 22:25, 23:3,
23:4, 23:10, 23:12,
23:14, 23:20, 24:3,
24:16, 25:4, 25:9,
25:12, 25:14, 25:18,
25:25, 26:5, 26:8,
27:3, 27:12, 27:15,
28:7, 28:10, 28:13,
29:2, 29:9, 29:23,
30:16, 30:20, 31:17,
32:11, 32:21, 32:24,
34:8, 34:13, 34:22,
35:22, 36:1, 36:12,
36:16, 36:19, 36:23,
37:2, 37:7, 37:25,
38:8, 38:15, 39:9,
39:17, 40:3, 40:4
HONORABLE [1] - 1:5
45
EXHIBIT A
Case 2:20-cr-00579-SVW     Document 439-2     Filed 06/07/21     Page 45 of 49   Page ID
#:4940

ROUGH TRANSCRIPT
hope [1] - 12:3
hopeful [1] - 13:8
housekeeping [5] -
23:11, 25:10, 25:13,
26:4, 26:10
hundred [4] - 35:2,
35:10, 35:18, 35:21
I
identification [1] -
37:21
identified [3] - 29:17,
33:19, 39:5
identify [5] - 28:3,
29:4, 29:17, 30:1,
39:22
identifying [1] - 37:9
identities [3] - 9:11,
14:14, 14:22
identity [2] - 9:10,
34:10
image [6] - 33:8, 33:9,
38:13, 38:16, 38:17,
38:19
IN [5] - 6:3, 41:10,
41:15, 41:16, 41:19
include [5] - 10:1,
12:15, 13:1, 32:6,
37:15
included [1] - 35:6
including [2] - 9:10,
28:15
indeed [1] - 13:11
indictment [18] - 9:12,
15:5, 15:10, 19:8,
19:9, 19:11, 19:13,
19:16, 19:18, 20:21,
21:12, 25:17, 27:22,
31:6, 31:9, 39:19,
39:23
indictments [2] -
23:16, 23:18
indirectly [1] - 24:12
individual [1] - 15:16
individually [1] -
11:13
individuals [4] -
14:13, 14:22, 14:25,
15:20
indulge [1] - 25:14
information [18] -
10:7, 13:2, 13:3,
21:24, 23:19, 24:6,
24:7, 24:14, 24:15,
27:17, 28:13, 28:14,
30:7, 37:5, 37:8,
37:10, 38:9, 38:12
inquiry [1] - 23:15
instance [2] - 8:21,
30:12
instruction [5] - 17:8,
17:11, 17:15, 17:20,
17:22
instructions [8] -
ROUGH TRANSCRIPT
17:5, 17:6, 17:7,
17:17, 17:18, 17:24,
17:25, 18:2
intend [9] - 7:5, 10:11,
11:5, 11:7, 13:22,
30:3, 34:20, 37:6,
39:8
intending [2] - 10:3,
35:17
intends [1] - 25:5
intention [1] - 12:25
interest [1] - 25:22
interested [2] - 13:11,
13:16
Internal [1] - 13:24
interrupt [1] - 18:21
investigation [2] -
28:18, 30:13
involved [1] - 33:5
IP [1] - 13:3
iPhone [1] - 32:6
IS [2] - 41:13, 41:16
issue [3] - 30:9, 33:7,
33:12
issued [2] - 22:12,
22:18
issues [6] - 23:12,
25:10, 25:13, 26:1,
26:4, 36:5
it'll [1] - 18:20
items [1] - 37:24
itself [2] - 23:24, 25:17
Iuliia [1] - 38:22
J
Jencks [1] - 27:2
Jencks's [1] - 27:7
Jennifer [1] - 6:17
JENNIFER [2] - 3:8,
3:9
Jilbert [1] - 6:19
JILBERT [1] - 4:20
JOHN [2] - 3:4, 3:13
John [2] - 6:15, 6:21
Johnson [2] - 6:24,
39:17
JOHNSON [9] - 2:19,
2:23, 3:22, 3:22,
4:11, 4:16, 6:24,
39:17, 40:1
joined [2] - 6:13, 34:6
JUDGE [1] - 1:5
judge's [2] - 29:24,
31:1
JUDICIAL [2] - 41:17,
41:20
July [2] - 29:24, 30:25
juncture [1] - 31:6
June [9] - 10:21, 11:4,
26:13, 27:19, 30:3,
30:4, 33:4, 37:11,
39:8
jurors [1] - 22:2
jury [15] - 11:16, 17:5,
ROUGH TRANSCRIPT
17:6, 17:19, 19:10,
19:11, 19:19, 19:21,
21:11, 21:12, 22:1,
26:15, 27:5, 27:11,
39:20
JUSTICE [1] - 2:8
K
Kastigar [7] - 22:20,
22:22, 23:15, 23:19,
23:23, 24:25, 27:18
KATZMAN [2] - 3:3,
4:3
keep [1] - 22:10
Keough [1] - 6:13
KEOUGH [1] - 4:16
knows [1] - 24:6
L
laboring [1] - 7:4
language [1] - 17:22
LAPD [1] - 28:15
large [1] - 11:11
larger [1] - 22:1
last [4] - 7:13, 14:16,
14:19
latest [1] - 27:19
latter [1] - 26:18
laundering [4] - 20:16,
20:24, 21:6, 21:17
LAW [5] - 3:8, 3:12,
3:22, 4:8, 4:20
law [1] - 24:21
lawyer [5] - 11:24,
22:6, 22:8, 22:9
lawyers [7] - 10:10,
11:12, 12:22, 18:13,
22:4, 22:9, 39:24
least [9] - 7:4, 15:21,
17:18, 22:4, 29:4,
30:12, 31:7, 34:10,
39:14
legal [1] - 17:19
lender [3] - 8:9, 8:10,
28:2
lent [1] - 8:12
LESS [1] - 41:18
letter [3] - 27:16,
28:21, 29:3
LEWIS [1] - 3:4
licenses [1] - 14:8
line [1] - 18:22
list [3] - 26:13, 27:20,
34:14
Littrell [1] - 6:15
LITTRELL [6] - 3:3,
3:4, 4:3, 6:15, 6:19,
26:8
LLP [6] - 2:19, 2:23,
3:4, 4:4, 4:11, 4:16
loan [18] - 8:7, 13:1,
13:21, 15:7, 15:15,
ROUGH TRANSCRIPT
15:21, 15:25, 27:25,
34:19, 34:20, 35:1,
35:2, 35:11, 35:14,
37:21, 38:5
loans [15] - 8:4, 8:22,
14:24, 16:8, 27:20,
27:21, 28:4, 28:5,
33:5, 34:11, 34:15,
35:6, 35:9, 35:10,
37:21
logistics [1] - 21:22
look [1] - 17:12
LOS [9] - 1:17, 1:24,
2:6, 2:16, 2:21, 3:14,
3:20, 4:6, 6:1
lose [1] - 8:20
lying [1] - 18:16
M
magistrate [2] - 29:24,
31:1
mail [3] - 20:2, 21:18,
34:17
mails [2] - 32:6, 34:24
manual [2] - 17:11,
17:12
Manuk [1] - 6:21
March [2] - 31:10
Mari [1] - 23:22
MARIA [3] - 1:21,
41:10, 41:23
Marietta [1] - 6:16
MARKET [1] - 4:17
materiality [1] - 8:17
MATTER [1] - 41:15
matters [1] - 26:10
MAY [2] - 1:18, 6:1
mean [12] - 7:18,
12:10, 17:12, 18:14,
28:19, 29:10, 30:18,
30:19, 31:25, 32:4,
38:16, 39:12
meaning [1] - 8:10
means [1] - 25:23
mechanics [1] - 24:4
meet [1] - 18:1
MEGHAN [1] - 4:12
Meghan [1] - 6:14
members [1] - 21:12
memory [1] - 19:17
mentioned [4] - 9:11,
14:20, 23:13, 27:9
merely [1] - 21:13
messages [3] - 32:6,
37:13, 37:16
Miami [1] - 36:11
MICHAEL [2] - 3:18,
4:16
Michael [2] - 6:13,
6:22
might [1] - 16:12
MINASSIAN [2] - 4:8,
4:9
mind [1] - 11:24
ROUGH TRANSCRIPT
UNITED STATES DISTRICT COURT
45
misconduct [1] -
26:23
misleading [1] - 8:17
missed [1] - 21:5
model [1] - 17:8
modification [1] -
16:19
modified [1] - 17:16
moments [1] - 15:2
monetarily [2] - 8:14,
8:16
money [6] - 8:5, 8:20,
20:16, 20:24, 21:6,
21:17
months [2] - 31:22,
33:19
morning [3] - 22:13,
22:19, 23:13
most [2] - 9:5, 34:5
motion [4] - 16:18,
25:15, 25:18, 30:22
motions [3] - 26:23,
31:3, 34:4
Motor [1] - 14:6
MR [117] - 6:8, 6:11,
6:15, 6:19, 6:21,
6:22, 6:24, 7:8, 7:15,
7:16, 7:17, 7:19,
7:23, 8:3, 8:11, 8:15,
8:21, 9:2, 9:9, 9:15,
10:4, 10:12, 10:18,
10:24, 11:2, 11:6,
12:8, 12:23, 13:6,
13:14, 13:20, 14:18,
15:12, 15:18, 15:23,
16:2, 16:4, 16:7,
16:21, 16:24, 17:1,
20:7, 20:10, 20:15,
20:20, 21:2, 21:8,
22:14, 22:17, 22:24,
23:3, 23:4, 23:8,
23:10, 24:1, 24:3,
25:4, 25:9, 25:12,
25:25, 26:5, 26:8,
26:21, 27:3, 27:12,
27:15, 28:2, 28:7,
28:10, 28:12, 29:2,
29:9, 29:11, 29:16,
29:23, 30:16, 30:20,
30:24, 31:13, 31:16,
31:20, 32:1, 32:5,
32:11, 32:21, 32:24,
33:1, 34:2, 34:8,
34:13, 34:17, 34:22,
34:24, 35:5, 35:8,
35:13, 35:16, 35:19,
35:22, 36:1, 36:8,
36:12, 36:16, 36:19,
36:23, 37:2, 37:7,
37:15, 37:20, 37:25,
38:8, 38:11, 38:18,
39:4, 39:9, 39:17,
40:1
MS [2] - 6:17, 40:4
multi [1] - 21:25
multi-defendant [1] -
46
EXHIBIT A
Case 2:20-cr-00579-SVW     Document 439-2     Filed 06/07/21     Page 46 of 49   Page ID
#:4941

ROUGH TRANSCRIPT
21:25
N
name [7] - 15:7, 15:25,
16:1, 16:8, 16:15,
16:17, 38:24
names [1] - 38:22
nature [1] - 32:7
near [2] - 30:23, 33:20
necessary [2] - 17:18,
25:23
need [3] - 25:20,
26:24, 39:11
needle [1] - 33:12
needles [1] - 33:13
never [2] - 11:15,
18:25
NEW [2] - 2:10, 4:13
NEWCOMER [1] -
4:12
Newcomer [1] - 6:14
NICHOLAS [1] - 2:23
Nicholas [1] - 26:6
Nick [1] - 6:13
Ninth [3] - 17:8, 17:13,
17:15
noncontroversial [1] -
13:3
NORTH [4] - 2:5, 2:15,
3:23, 4:9
nothing [3] - 11:23,
12:19
notice [5] - 10:5,
12:24, 13:18, 14:14,
28:20
November [3] - 31:8,
31:16, 32:20
number [3] - 21:21,
24:22, 39:15
nutshell [1] - 20:3
NW [2] - 2:10, 2:24
NY [1] - 4:13
O
object [3] - 9:23, 20:5,
20:9
objection [3] - 11:24,
12:20, 28:8
objects [1] - 21:16
obligation [1] - 28:20
obvious [2] - 11:17,
19:23
obviously [2] - 24:7,
26:12
occasions [1] - 17:14
OF [24] - 1:2, 1:7, 1:15,
2:3, 2:3, 2:8, 2:12,
2:18, 3:3, 3:17, 3:22,
4:3, 4:3, 4:8, 4:12,
4:15, 41:5, 41:11,
41:14, 41:17, 41:20
offer [1] - 9:10
ROUGH TRANSCRIPT
OFFICE [3] - 2:3, 2:12,
3:22
officers [1] - 15:20
OFFICES [1] - 4:8
OFFICIAL [3] - 1:21,
41:10, 41:23
ON [6] - 2:3, 2:18, 3:3,
3:17, 4:3, 4:15
once [1] - 10:13
one [16] - 8:8, 8:9,
15:6, 15:7, 16:6,
16:14, 18:8, 19:20,
19:21, 22:4, 22:6,
22:7, 22:17, 23:15,
25:14, 38:22
ones [3] - 36:24, 38:2,
38:6
ongoing [2] - 30:22,
32:19
opening [4] - 18:10,
18:11, 18:18, 18:21
opposes [1] - 16:22
order [13] - 22:12,
22:18, 23:13, 24:18,
24:20, 25:5, 26:12,
26:18, 29:24, 31:1,
31:4, 38:15, 39:25
ORGANIZED [1] - 2:13
original [1] - 23:16
originally [1] - 31:7
originating [1] - 8:22
other... [1] - 28:6
otherwise [1] - 23:23
outline [3] - 17:19,
31:7
outlined [1] - 16:10
outset [1] - 7:4
over-seize [1] - 29:12
own [4] - 8:23, 15:7,
16:1, 16:8
owners [1] - 15:20
P
P.C [2] - 3:12, 4:20
P.M [1] - 6:3
PACIFIC [1] - 3:23
PAETTY [1] - 2:5
Paetty [1] - 6:10
page [4] - 19:18, 21:8,
21:9, 21:19
PAGE [2] - 5:2, 41:16
pages [3] - 19:15,
21:7, 24:13
paper [3] - 11:25,
15:22, 16:23
parade [2] - 11:17,
12:3
paragraph [1] - 27:21
Paronyan [1] - 6:23
part [4] - 23:15, 27:20,
30:14, 33:3
participated [1] -
28:16
participation [1] -
ROUGH TRANSCRIPT
25:8
particular [3] - 8:21,
11:20, 16:5
parties [5] - 13:8,
16:13, 17:4, 30:2,
39:12
pattern [1] - 17:8
payment [1] - 14:5
people [1] - 15:10
perceiving [1] - 30:9
permission [1] - 25:20
permits [1] - 29:11
pertinent [1] - 30:13
peruse [1] - 30:11
PETER [2] - 3:22, 3:22
Peter [2] - 6:24, 39:17
phone [7] - 32:5,
32:15, 36:4, 36:7,
36:14, 38:19, 38:25
phones [13] - 29:5,
29:19, 31:11, 31:12,
32:2, 36:6, 36:9,
36:13, 36:22, 37:5,
37:14, 37:18, 38:13
photographs [3] -
37:17, 37:19, 37:20
pictured [1] - 23:5
pictures [5] - 36:6,
36:8, 36:14, 36:17,
37:17
piece [2] - 11:25,
24:11
pieces [1] - 37:9
plaintiff [1] - 18:15
Plaintiffs [1] - 1:8
PLAINTIFFS [2] - 2:3,
4:3
plan [1] - 35:2
play [1] - 33:20
pled [1] - 21:2
point [15] - 7:2, 10:19,
13:7, 13:14, 15:2,
17:4, 19:4, 19:7,
24:2, 24:3, 24:9,
24:22, 28:25, 30:14,
35:20
points [1] - 23:13
portion [1] - 19:16
portions [2] - 39:19,
39:22
position [8] - 11:11,
24:14, 24:19, 26:19,
26:22, 29:21, 33:16,
39:7
possession [1] -
28:14
potential [1] - 24:5
potentially [3] - 9:2,
9:3, 20:17
PPP [6] - 8:4, 8:7,
12:7, 12:8, 28:5,
37:21
precluded [1] - 24:15
preferences [1] -
17:16
ROUGH TRANSCRIPT
prejudice [2] - 24:4,
24:5
premises [2] - 7:10,
31:14
prepare [1] - 33:17
prepared [2] - 9:20,
10:14
preparing [1] - 18:8
present [3] - 9:4, 18:5,
25:2
presented [1] - 9:21
presenting [1] - 7:24
PRESIDING [1] - 1:5
pretrial [1] - 7:1
preview [2] - 18:18,
18:19
primarily [1] - 37:20
primary [1] - 37:22
principal [1] - 22:8
privilege [1] - 32:13
privileged [1] - 32:16
probative [1] - 12:19
problem [2] - 25:3,
33:3
proceed [1] - 25:13
proceeding [1] - 40:5
PROCEEDINGS [2] -
1:15, 41:15
proceedings [1] - 24:8
process [2] - 37:9,
38:1
produce [5] - 26:13,
26:15, 27:19, 29:4,
39:23
produced [7] - 26:16,
31:21, 34:14, 35:13,
36:20, 37:7, 39:1
program [1] - 9:5
programs [2] - 8:7,
9:5
promptly [3] - 16:20,
17:2, 17:3
proof [1] - 17:13
prosecution [2] -
18:16, 32:17
Prosecution [1] -
28:15
prosecutorial [1] -
26:23
prospective [1] -
21:12
protect [1] - 25:23
provide [1] - 35:12
provided [6] - 10:4,
14:14, 32:12, 36:17,
38:13, 38:14
pull [1] - 33:14
purports [1] - 11:25
purpose [1] - 22:11
PURSUANT [1] -
41:12
pursuant [2] - 12:25,
30:25
put [3] - 13:17, 13:22,
30:23
ROUGH TRANSCRIPT
UNITED STATES DISTRICT COURT
46
Q
questions [1] - 7:3
quick [1] - 25:9
R
raise [2] - 23:14, 26:11
raised [1] - 12:20
RAM [16] - 2:19, 6:11,
7:16, 22:14, 23:4,
23:8, 23:10, 24:1,
24:3, 25:9, 25:12,
25:25, 32:24, 33:1,
34:2, 34:8
ram [2] - 23:9, 33:1
Ram [3] - 6:12, 23:4,
25:11
re [1] - 21:5
read [13] - 19:7, 19:11,
19:12, 19:15, 19:20,
19:21, 21:11, 21:14,
21:16, 21:17, 21:20,
39:20, 39:23
reading [1] - 39:19
ready [3] - 30:4,
33:17, 33:18
reaffirm [1] - 11:17
real [1] - 25:9
really [3] - 24:9, 36:22,
39:12
reason [2] - 23:5,
23:20
received [1] - 22:12
receptive [1] - 17:20
recesses [1] - 29:1
record [8] - 12:4,
16:11, 25:15, 25:17,
25:23, 26:11, 26:14,
39:21
records [16] - 11:20,
12:2, 12:5, 12:15,
13:1, 13:4, 13:23,
14:4, 14:9, 14:12,
14:17, 14:21
REDONDO [1] - 3:24
REDUCTION [1] -
41:19
reexamine [1] - 21:4
referenced [1] - 20:23
reflect [1] - 9:24
reflects [1] - 10:3
regard [8] - 11:22,
12:14, 12:15, 20:1,
26:20, 27:8, 29:22,
36:4
regarding [2] - 11:9,
21:15
regardless [1] - 24:8
REGULATIONS [2] -
41:16, 41:20
reimbursed [1] - 8:25
relate [1] - 18:2
related [1] - 26:10
47
EXHIBIT A
Case 2:20-cr-00579-SVW     Document 439-2     Filed 06/07/21     Page 47 of 49   Page ID
#:4942

ROUGH TRANSCRIPT
released [1] - 32:16
relevant [2] - 33:7,
37:14
repeat [1] - 14:17
repetitive [1] - 19:14
report [6] - 37:8,
38:12, 38:14, 38:18,
38:20
REPORTED [1] -
41:14
REPORTER [3] - 1:21,
41:10, 41:23
REPORTER'S [1] -
1:15
represent [2] - 26:9,
34:1
representative [1] -
14:11
representing [1] -
23:10
request [2] - 25:14,
26:14
requested [2] - 28:13,
29:16
requirement [2] -
10:16, 10:18
requirements [1] -
9:19
requires [1] - 26:12
reserve [1] - 26:2
reset [1] - 22:19
resetting [1] - 22:21
respect [7] - 14:5,
14:9, 14:12, 14:23,
20:15, 23:21, 34:14
respects [1] - 12:24
respond [1] - 16:20
response [1] - 17:2
responsible [1] -
27:23
responsive [2] -
29:14, 29:18
responsiveness [8] -
29:5, 29:8, 29:13,
29:25, 30:6, 30:21,
30:25, 33:8
results [1] - 29:4
Revenue [1] - 13:24
review [9] - 29:5,
29:13, 29:25, 30:6,
30:21, 30:25, 32:13,
32:18, 33:8
reviewed [2] - 31:3,
31:6
reviewing [1] - 32:15
Richard [4] - 6:5, 6:12,
23:11, 34:2
RICHARD [5] - 1:12,
2:19, 3:17, 4:16,
41:7
ripping [1] - 19:2
ROAD [1] - 3:10
room [1] - 16:12
rows [1] - 22:10
Rule [1] - 29:11
ROUGH TRANSCRIPT
Rules [1] - 19:25
ruling [1] - 25:1
run [1] - 38:15
Russian [1] - 14:25
Ryan [1] - 6:15
RYAN [1] - 4:4
S
SAN [2] - 3:6, 4:18
SBA [4] - 8:22, 8:23,
8:25, 9:5
scheme [3] - 8:20,
20:12, 20:13
SCOTT [1] - 2:5
Scott [1] - 6:9
screen [2] - 23:5, 33:2
scrutiny [1] - 17:14
search [7] - 28:17,
29:6, 33:15, 38:15,
38:21, 38:24
searchable [1] - 38:14
searched [1] - 7:10
searches [3] - 31:12,
31:13, 36:25
second [4] - 13:6,
13:7, 19:4, 28:12
SECTION [3] - 2:4,
2:14, 41:12
section [1] - 21:19
secured [3] - 9:1, 9:6,
21:24
Security [2] - 14:11,
14:20
see [17] - 11:1, 11:4,
11:16, 13:5, 13:12,
15:4, 16:5, 16:9,
16:23, 20:11, 22:5,
29:13, 29:15, 30:12,
32:22, 39:3
seem [2] - 15:19,
18:14
seize [3] - 29:12,
33:10, 37:10
seized [13] - 7:12,
7:21, 29:6, 29:18,
29:19, 30:11, 31:11,
31:12, 36:6, 36:9,
36:10, 36:14, 36:25
selection [2] - 19:10,
19:11
sentence [1] - 19:1
separate [2] - 20:25,
21:2
Service [1] - 13:24
SESSION [1] - 6:3
set [2] - 11:7, 37:18
severe [1] - 28:24
share [3] - 10:7,
10:20, 30:6
short [2] - 10:9, 21:17
shorter [1] - 21:18
show [3] - 14:21,
18:15, 18:16
sign [2] - 10:13, 13:8
ROUGH TRANSCRIPT
signed [1] - 10:14
SILVERMAN [12] -
2:23, 26:5, 27:15,
28:2, 28:7, 28:12,
29:2, 29:9, 29:11,
29:16, 30:16, 30:20
Silverman [5] - 6:13,
26:3, 26:7, 30:10,
30:15
silverman [1] - 27:14
similarities [1] - 19:25
similarly [2] - 12:5,
20:1
simply [1] - 39:20
site [1] - 7:9
situation [1] - 36:11
six [1] - 16:4
Small [1] - 8:6
small [1] - 26:9
smart [1] - 32:5
so-called [1] - 18:1
sometimes [1] - 18:24
sorry [1] - 20:18
sort [2] - 18:25, 34:4
sound [1] - 7:24
sounds [1] - 31:1
SPA [1] - 12:12
speaking [1] - 25:15
SPEAR [1] - 4:17
specialist [1] - 7:19
specific [1] - 39:22
specifically [1] - 23:17
spirit [1] - 28:22
spread [1] - 22:2
SPRING [2] - 2:5, 2:15
stand [1] - 27:5
start [3] - 7:7, 18:22,
18:23
starts [1] - 18:24
state [1] - 6:7
statement [4] - 18:10,
18:18, 18:21, 24:11
statements [3] - 8:17,
13:21, 18:11
states [1] - 10:18
STATES [12] - 1:1, 1:7,
1:22, 2:3, 2:12, 4:3,
41:5, 41:11, 41:13,
41:17, 41:20
States [1] - 6:5
STATUS [2] - 1:16, 5:2
STENOGRAPHICAL
LY [1] - 41:14
step [1] - 39:8
STEPHEN [1] - 1:5
STEPTOE [4] - 2:19,
2:23, 4:11, 4:16
still [4] - 16:12, 29:25,
30:21, 37:4
stipulating [1] - 13:9
stipulation [2] - 13:7,
16:12
stipulations [1] -
13:13
stolen [1] - 14:13
ROUGH TRANSCRIPT
stop [1] - 36:10
STREET [6] - 1:23,
2:5, 2:15, 2:20, 4:5,
4:17
strength [1] - 11:19
strongly [1] - 18:9
structurally [1] -
19:14
students [2] - 14:25,
15:1
subject [5] - 14:13,
17:11, 17:13, 23:19,
35:3
subliminally [1] -
11:18
submission [1] -
22:22
submit [4] - 12:25,
17:1, 17:5
submitted [2] - 14:1,
14:2
substantive [3] -
13:10, 20:9, 35:4
SUITE [10] - 1:23,
2:15, 2:20, 3:6, 3:10,
3:14, 3:19, 3:24, 4:5,
4:17
summary [11] - 8:3,
9:18, 9:20, 9:22,
9:23, 9:25, 10:2,
10:5, 10:6, 10:19,
10:25
SUN [1] - 2:14
superseding [3] -
9:12, 23:16, 27:21
supply [1] - 11:5
support [2] - 10:2,
17:23
suppress [2] - 30:22,
31:3
sync [1] - 15:12
synthetic [3] - 15:12,
15:13, 15:14
T
table [2] - 22:7, 22:9
tables [1] - 22:5
TAHMAZIAN [2] -
4:20, 4:20
Tahmazian [1] - 6:19
taint [3] - 24:18, 25:16
tainted [1] - 24:12
task [1] - 7:4
TASK [1] - 2:13
tax [3] - 13:25, 14:1,
14:5
team [2] - 32:14, 32:17
telephone [1] - 13:3
temporarily [1] -
29:12
Terabelian [2] - 6:16,
23:22
term [3] - 15:8, 15:9,
15:11
ROUGH TRANSCRIPT
UNITED STATES DISTRICT COURT
47
terms [8] - 7:5, 15:4,
17:17, 17:25, 20:12,
24:4, 27:25, 33:15
testified [1] - 27:4
testify [12] - 7:11,
7:17, 7:20, 7:23, 8:4,
8:6, 8:16, 13:25,
14:4, 14:7, 14:11,
27:10
testimony [3] - 10:6,
24:19, 26:16
text [3] - 32:6, 37:13,
37:15
THAT [2] - 41:12,
41:15
THE [129] - 2:3, 2:3,
2:12, 2:18, 3:3, 3:17,
3:17, 4:3, 4:12, 4:15,
6:4, 7:1, 7:13, 7:18,
7:22, 8:1, 8:10, 8:13,
8:19, 8:24, 9:4, 9:13,
9:17, 10:9, 10:16,
10:23, 11:1, 11:4,
11:9, 12:9, 13:5,
13:12, 13:19, 14:16,
15:4, 15:13, 15:19,
15:24, 16:3, 16:5,
16:9, 16:23, 16:25,
17:3, 20:8, 20:11,
20:18, 20:25, 21:4,
21:10, 22:15, 22:23,
23:1, 23:7, 23:9,
23:25, 24:2, 24:17,
25:7, 25:11, 25:20,
26:6, 26:19, 27:1,
27:8, 27:13, 27:24,
28:5, 28:8, 28:11,
28:19, 29:7, 29:10,
29:15, 29:21, 30:8,
30:17, 31:5, 31:15,
31:18, 31:24, 32:3,
32:8, 32:19, 32:22,
32:25, 33:22, 34:3,
34:9, 34:16, 34:18,
34:23, 34:25, 35:7,
35:10, 35:15, 35:17,
35:20, 35:24, 36:2,
36:11, 36:13, 36:17,
36:21, 36:24, 37:3,
37:12, 37:19, 37:23,
38:4, 38:9, 38:16,
39:3, 39:7, 39:10,
39:25, 40:2, 41:10,
41:11, 41:13, 41:14,
41:15, 41:16, 41:17,
41:19, 41:20
theft [2] - 9:10, 9:11
themselves [1] -
23:17
thereabouts [1] -
35:11
therefore [1] - 29:18
they've [1] - 33:5
thinking [2] - 11:13,
11:14
third [1] - 29:2
48
EXHIBIT A
Case 2:20-cr-00579-SVW     Document 439-2     Filed 06/07/21     Page 48 of 49   Page ID
#:4943

ROUGH TRANSCRIPT
THIS [1] - 41:18
thousand [2] - 35:1,
35:6
three [2] - 8:8, 27:17
tied [2] - 24:12
TITLE [1] - 41:13
TO [1] - 41:12
today [1] - 26:11
TOWER [1] - 4:17
tracing [1] - 8:4
traditional [1] - 17:6
TRANSCRIPT [4] -
1:15, 41:14, 41:16,
41:18
transcripts [4] -
26:15, 26:25, 27:1,
27:6
transfer [1] - 12:17
transfers [1] - 12:16
travel [3] - 14:12,
14:17, 14:22
treasury [1] - 12:12
trial [23] - 7:4, 9:21,
10:1, 10:25, 18:9,
23:23, 24:16, 24:24,
24:25, 26:4, 29:20,
30:3, 30:4, 33:7,
33:11, 33:14, 33:17,
33:18, 37:10, 37:14,
38:2, 39:6
trim [1] - 39:15
trouble [1] - 16:15
TRUE [1] - 41:13
trust [1] - 22:12
trying [1] - 33:16
twice [1] - 33:23
two [4] - 19:21, 20:20,
22:1, 22:4
type [3] - 16:11, 28:1,
38:23
U
U.S [1] - 2:8
unclear [1] - 33:21
under [5] - 9:5, 20:17,
29:6, 29:23, 33:15
underlying [3] - 9:24,
11:15, 13:9
understood [1] -
11:16
unemployment [1] -
14:5
United [1] - 6:5
UNITED [12] - 1:1, 1:7,
1:22, 2:3, 2:12, 4:3,
41:5, 41:11, 41:13,
41:17, 41:20
universe [4] - 33:21,
35:15, 37:13, 37:15
unrelated [1] - 27:17
up [5] - 16:12, 18:7,
24:20, 27:13, 39:12
ROUGH TRANSCRIPT
V
Vahe [2] - 6:25, 39:18
value [2] - 12:19,
21:14
various [2] - 7:10,
26:22
Vehicle's [1] - 14:7
version [3] - 11:2,
11:5, 21:18
victim [6] - 8:9, 8:10,
8:14, 8:15, 9:7, 9:11
victims [5] - 8:7, 9:5,
9:10, 9:11
view [1] - 24:22
viewable [1] - 38:19
vigorously [1] - 19:5
vs [2] - 1:10, 41:6
W
wait [2] - 32:8, 35:25
wants [1] - 33:25
warrant [4] - 28:17,
29:6, 30:13, 33:15
WASHINGTON [2] -
2:10, 2:25
waste [1] - 26:1
web [1] - 32:6
weigh [1] - 12:4
well-aware [1] - 18:12
well-established [1] -
24:21
WEST [4] - 1:23, 2:20,
4:5, 4:21
WESTERN [1] - 1:3
WILLIAMS [2] - 3:4,
4:4
WILSHIRE [2] - 3:13,
3:19
WILSON [1] - 1:5
wire [15] - 12:16,
12:17, 13:10, 19:19,
19:22, 19:24, 20:2,
20:3, 20:4, 20:8,
20:22, 21:15, 21:18,
21:20
wires [2] - 13:9, 13:11
WIRSCHING [4] - 3:8,
3:9, 6:17, 40:4
Wirsching [1] - 6:17
WITH [2] - 41:16,
41:19
witness [13] - 8:3, 8:5,
8:16, 9:18, 9:23,
10:25, 13:24, 14:7,
14:21, 18:16, 24:11,
26:13, 26:15
witness' [1] - 10:5
witnesses [12] - 7:5,
7:6, 11:10, 11:17,
13:15, 13:17, 13:22,
16:10, 27:9, 27:10,
39:15
ROUGH TRANSCRIPT
UNITED STATES DISTRICT COURT
48
words [9] - 11:22,
11:25, 12:16, 18:1,
24:5, 24:10, 27:1,
34:16, 34:25
writing [1] - 34:5
Y
years [1] - 18:12
yesterday [1] - 27:16
YORK [2] - 2:10, 4:13
Z
Zhadko [1] - 38:22
ZOOM [2] - 1:16, 5:2
49
EXHIBIT A
Case 2:20-cr-00579-SVW     Document 439-2     Filed 06/07/21     Page 49 of 49   Page ID
#:4944

File and source

File
gov.uscourts.cacd.802533.439.2.pdf
Size
1,135,153 bytes
SHA-256
2b496b5f1d935fd1ea7751dd2ebbabc21e498dbd1bdad24edf33092150a55dc6
Our copy
gov.uscourts.cacd.802533.439.2.pdf
Original
PACER (login required)
  1. Exhibit B — USA v. Ayvazyan et al. (Dkt. 439-3, C.D. Cal.)same docket · 2021-06-07
  2. Declaration of Ashwin J. Ram in Support — USA v. Ayvazyan et al (Dkt. 439.1)same docket · 2021-06-07
  3. Exhibit C — USA v. Ayvazyan et al. (Dkt. 439-4, C.D. Cal.)same docket · 2021-06-07
  4. Reply in Support of Joint Notice of Motion and Motion to Exclude — USA v. Ayvazyan et al. (Dkt. 439, C.D. Cal.)same docket · 2021-06-07
  5. Exhibit D — USA v. Ayvazyan et al. (Dkt. 439-5, C.D. Cal.)same docket · 2021-06-07
  6. Exhibit E — USA v. Ayvazyan et al. (Dkt. 439-6, C.D. Cal.)same docket · 2021-06-07
  7. Exhibit B — USA v. Ayvazyan et al. (Dkt. 426-4, C.D. Cal.)same docket · 2021-06-07
  8. Exhibit F — USA v. Ayvazyan et al. (Dkt. 439-7, C.D. Cal.)same docket · 2021-06-07
  9. Exhibit A — USA v. Ayvazyan et al. (Dkt. 426-3, C.D. Cal.)same case · 2021-06-07
  10. Exhibit G — USA v. Ayvazyan et al. (Dkt. 439-8, C.D. Cal.)same case · 2021-06-07
  11. Declaration of Ashwin J. Ram in Support — USA v. Ayvazyan et al (Dkt. 426.2)same case · 2021-06-07
  12. Exhibit H — USA v. Ayvazyan et al. (Dkt. 439-9, C.D. Cal.)same case · 2021-06-07
  13. Proposed Order — USA v. Ayvazyan et al (Dkt. 426.1)same case · 2021-06-07
  14. Notice of Motion and Motion to Strike — USA v. Ayvazyan et al. (Dkt. 426, C.D. Cal.)same case · 2021-06-07
  15. Exhibit B — USA v. Ayvazyan et al. (Dkt. 419-3, C.D. Cal.)same case · 2021-06-04
  16. Notice of Motion and Motion in Limine to Preclude — USA v. Ayvazyan et al. (Dkt. 451, C.D. Cal.)same case · 2021-06-08
  17. Exhibit A — USA v. Ayvazyan et al. (Dkt. 419-2, C.D. Cal.)same docket · 2021-06-04
  18. Proposed Order — USA v. Ayvazyan et al (Dkt. 451.1)same docket · 2021-06-08
  19. Declaration of Ashwin J. Ram in Support — USA v. Ayvazyan et al (Dkt. 419.1)same docket · 2021-06-04
  20. Declaration of Ashwin J. Ram in Support — USA v. Ayvazyan et al (Dkt. 451.2)same docket · 2021-06-08

Part of: USA v. Ayvazyan et al (CACD 802533) · U.S. District Court for the Central District of California · Paycheck Protection Program (PPP) · COVID Economic Injury Disaster Loans (EIDL) · Criminal prosecutions · Exhibits and declarations · 2021 · Court filings

Back to top