Declaration of Ashwin J. Ram in Support — USA v. Ayvazyan et al (Dkt. 451.2)

Record facts

U.S. District Court for the Central District of California · No. 2:20-cr-00579-SVW · Doc. 451-2 · 2021-06-08 · Docket on CourtListener

Summary

A declaration of Ashwin J. Ram, counsel for defendant Richard Ayvazyan, in United States of America v. Richard Ayvazyan, et al., No. 2:20-cr-00579-SVW, in the U.S. District Court for the Central District of California, filed June 8, 2021 as Doc. 451-2. It supports the defendants' motion in limine to preclude a summary witness, set for hearing before Judge Stephen V. Wilson on June 14, 2021. The declaration identifies attached exhibits: Exhibit A, the government's May 18, 2021 letter; Exhibit B, a May 24, 2021 email exchange; Exhibit C, the transcript of the May 21, 2021 status conference; Exhibits D and E, government summary chart exhibits on tracing and on COVID-19 Disaster Relief Loan Applications emailed June 1, 2021; Exhibit F, a June 1, 2021 government email; and Exhibit G, a June 5, 2021 email exchange. It is two pages.

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Full text

DECLARATION OF A. RAM IN SUPPORT OF MOTION IN LIMINE TO 
PRECLUDE SUMMARY WITNESS 
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Ashwin J. Ram (SBN 227513) 
aram@steptoe.com 
Michael A. Keough (SBN 327037) 
mkeough@steptoe.com 
Meghan L. Newcomer (pro hac vice) 
mnewcomer@steptoe.com 
Nicholas P. Silverman (pro hac vice) 
nsilverman@steptoe.com 
STEPTOE & JOHNSON LLP 
633 West Fifth Street, Suite 1900 
Los Angeles, CA 90071 
Telephone: (213) 439-9400 
Facsimile: (213) 439-9599 
 
 
Counsel for Defendant Richard Ayvazyan 
 
UNITED STATES DISTRICT COURT 
CENTRAL DISTRICT OF CALIFORNIA  
 
 
UNITED STATES OF AMERICA, 
 
                              Plaintiff, 
 
v. 
 
RICHARD AYVAZYAN,  
et al., 
 
Defendants. 
 
Case No.  20-cr-579 (SVW) 
 
DECLARATION OF ASHWIN J. 
RAM IN SUPPORT OF 
DEFENDANTS’ NOTICE OF 
MOTION AND MOTION IN 
LIMINE TO PRECLUDE 
SUMMARY WITNESS 
 
Judge:               Hon. Stephen V. Wilson 
Hearing Date:   June 14, 2021 
Time:                11:00 a.m. 
 
 
 
 
Case 2:20-cr-00579-SVW     Document 451-2     Filed 06/08/21     Page 1 of 2   Page ID
#:5105

 
 
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DECLARATION OF A. RAM IN SUPPORT OF MOTION IN LIMINE TO 
PRECLUDE SUMMARY WITNESS 
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I, Ashwin J. Ram, declare as follows: 
1. 
I am an attorney licensed to practice law in the state of California.  I am a 
partner at the law firm of Steptoe & Johnson LLP and counsel of record for defendant 
Richard Ayvazyan in the above-captioned matter. 
2. 
Attached as Exhibit A is a true and correct copy of the government’s May 
18, 2021 letter to defense counsel. 
3. 
Attached as Exhibit B is a true and correct copy of a May 24, 2021 email 
exchange between the government and defense counsel. 
4. 
Attached as Exhibit C is a true and correct copy of the transcript of the 
Status Conference Hearing held on May 21, 2021 in the above-captioned matter, 
obtained from the Court Reporter. 
5. 
Attached as Exhibit D is a true and correct copy of the government’s 
Summary Chart Exhibit re Tracing, emailed to defense counsel on June 1, 2021, with 
street address numbers redacted. 
6. 
Attached as Exhibit E is a true and correct copy of the government’s 
Summary Chart Exhibit re COVID-19 Disaster Relief Loan Application, emailed to 
defense counsel on June 1, 2021, with dates of birth and street address numbers 
redacted. 
7. 
Attached as Exhibit F is a true and correct copy of the government’s June 
1, 2021 email to defense counsel regarding summary chart exhibits. 
8. 
Attached as Exhibit G is a true and correct copy of a June 5, 2021 email 
exchange between the government and defense counsel. 
I declare under penalty of perjury that the foregoing is true and correct. 
Executed at Los Angeles, California on June 8, 2021. 
 
 
 
 
 
 
 
 
Respectfully submitted,  
 
 
 
 
 
 
 
 
/s/ Ashwin J. Ram  
 
 
 
 
 
 
 
 
 
Ashwin J. Ram  
 
 
 
 
Counsel for Defendant Richard Ayvazyan 
Case 2:20-cr-00579-SVW     Document 451-2     Filed 06/08/21     Page 2 of 2   Page ID
#:5106

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