Court filing
Exhibit C — USA v. Ayvazyan et al. (Dkt. 451-5, C.D. Cal.)
Filed June 8, 2021 in USA v. Ayvazyan et al.; one of 233 filings from this case.
Record facts
| Court | U.S. District Court for the Central District of California |
|---|---|
| Filed | 2021-06-08 |
U.S. District Court for the Central District of California · No. 2:20-cr-00579-SVW · Doc. 451-5 · 2021-06-08 · Docket on CourtListener
Full text
EXHIBIT C Case 2:20-cr-00579-SVW Document 451-5 Filed 06/08/21 Page 1 of 49 Page ID #:5119 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 14 EXHIBIT C Case 2:20-cr-00579-SVW Document 451-5 Filed 06/08/21 Page 2 of 49 Page ID #:5120 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 15 EXHIBIT C Case 2:20-cr-00579-SVW Document 451-5 Filed 06/08/21 Page 3 of 49 Page ID #:5121 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 16 EXHIBIT C Case 2:20-cr-00579-SVW Document 451-5 Filed 06/08/21 Page 4 of 49 Page ID #:5122 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 17 EXHIBIT C Case 2:20-cr-00579-SVW Document 451-5 Filed 06/08/21 Page 5 of 49 Page ID #:5123 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 18 EXHIBIT C Case 2:20-cr-00579-SVW Document 451-5 Filed 06/08/21 Page 6 of 49 Page ID #:5124 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. 19 EXHIBIT C Case 2:20-cr-00579-SVW Document 451-5 Filed 06/08/21 Page 7 of 49 Page ID #:5125 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. 20 EXHIBIT C Case 2:20-cr-00579-SVW Document 451-5 Filed 06/08/21 Page 8 of 49 Page ID #:5126 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 21 EXHIBIT C Case 2:20-cr-00579-SVW Document 451-5 Filed 06/08/21 Page 9 of 49 Page ID #:5127 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 22 EXHIBIT C Case 2:20-cr-00579-SVW Document 451-5 Filed 06/08/21 Page 10 of 49 Page ID #:5128 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. 23 EXHIBIT C Case 2:20-cr-00579-SVW Document 451-5 Filed 06/08/21 Page 11 of 49 Page ID #:5129 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 24 EXHIBIT C Case 2:20-cr-00579-SVW Document 451-5 Filed 06/08/21 Page 12 of 49 Page ID #:5130 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 25 EXHIBIT C Case 2:20-cr-00579-SVW Document 451-5 Filed 06/08/21 Page 13 of 49 Page ID #:5131 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 26 EXHIBIT C Case 2:20-cr-00579-SVW Document 451-5 Filed 06/08/21 Page 14 of 49 Page ID #:5132 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 27 EXHIBIT C Case 2:20-cr-00579-SVW Document 451-5 Filed 06/08/21 Page 15 of 49 Page ID #:5133 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 28 EXHIBIT C Case 2:20-cr-00579-SVW Document 451-5 Filed 06/08/21 Page 16 of 49 Page ID #:5134 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. 29 EXHIBIT C Case 2:20-cr-00579-SVW Document 451-5 Filed 06/08/21 Page 17 of 49 Page ID #:5135 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 30 EXHIBIT C Case 2:20-cr-00579-SVW Document 451-5 Filed 06/08/21 Page 18 of 49 Page ID #:5136 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 31 EXHIBIT C Case 2:20-cr-00579-SVW Document 451-5 Filed 06/08/21 Page 19 of 49 Page ID #:5137 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 32 EXHIBIT C Case 2:20-cr-00579-SVW Document 451-5 Filed 06/08/21 Page 20 of 49 Page ID #:5138 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 33 EXHIBIT C Case 2:20-cr-00579-SVW Document 451-5 Filed 06/08/21 Page 21 of 49 Page ID #:5139 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. 34 EXHIBIT C Case 2:20-cr-00579-SVW Document 451-5 Filed 06/08/21 Page 22 of 49 Page ID #:5140 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? 35 EXHIBIT C Case 2:20-cr-00579-SVW Document 451-5 Filed 06/08/21 Page 23 of 49 Page ID #:5141 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. 36 EXHIBIT C Case 2:20-cr-00579-SVW Document 451-5 Filed 06/08/21 Page 24 of 49 Page ID #:5142 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 37 EXHIBIT C Case 2:20-cr-00579-SVW Document 451-5 Filed 06/08/21 Page 25 of 49 Page ID #:5143 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 38 EXHIBIT C Case 2:20-cr-00579-SVW Document 451-5 Filed 06/08/21 Page 26 of 49 Page ID #:5144 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. 39 EXHIBIT C Case 2:20-cr-00579-SVW Document 451-5 Filed 06/08/21 Page 27 of 49 Page ID #:5145 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 40 EXHIBIT C Case 2:20-cr-00579-SVW Document 451-5 Filed 06/08/21 Page 28 of 49 Page ID #:5146 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 41 EXHIBIT C Case 2:20-cr-00579-SVW Document 451-5 Filed 06/08/21 Page 29 of 49 Page ID #:5147 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 42 EXHIBIT C Case 2:20-cr-00579-SVW Document 451-5 Filed 06/08/21 Page 30 of 49 Page ID #:5148 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 43 EXHIBIT C Case 2:20-cr-00579-SVW Document 451-5 Filed 06/08/21 Page 31 of 49 Page ID #:5149 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? 44 EXHIBIT C Case 2:20-cr-00579-SVW Document 451-5 Filed 06/08/21 Page 32 of 49 Page ID #:5150 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. 45 EXHIBIT C Case 2:20-cr-00579-SVW Document 451-5 Filed 06/08/21 Page 33 of 49 Page ID #:5151 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 46 EXHIBIT C Case 2:20-cr-00579-SVW Document 451-5 Filed 06/08/21 Page 34 of 49 Page ID #:5152 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 47 EXHIBIT C Case 2:20-cr-00579-SVW Document 451-5 Filed 06/08/21 Page 35 of 49 Page ID #:5153 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. 48 EXHIBIT C Case 2:20-cr-00579-SVW Document 451-5 Filed 06/08/21 Page 36 of 49 Page ID #:5154 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 -- 49 EXHIBIT C Case 2:20-cr-00579-SVW Document 451-5 Filed 06/08/21 Page 37 of 49 Page ID #:5155 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 50 EXHIBIT C Case 2:20-cr-00579-SVW Document 451-5 Filed 06/08/21 Page 38 of 49 Page ID #:5156 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 51 EXHIBIT C Case 2:20-cr-00579-SVW Document 451-5 Filed 06/08/21 Page 39 of 49 Page ID #:5157 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. 52 EXHIBIT C Case 2:20-cr-00579-SVW Document 451-5 Filed 06/08/21 Page 40 of 49 Page ID #:5158 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.) - - - 53 EXHIBIT C Case 2:20-cr-00579-SVW Document 451-5 Filed 06/08/21 Page 41 of 49 Page ID #:5159 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. 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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 I 55 EXHIBIT C Case 2:20-cr-00579-SVW Document 451-5 Filed 06/08/21 Page 43 of 49 Page ID #:5161 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 I 56 EXHIBIT C Case 2:20-cr-00579-SVW Document 451-5 Filed 06/08/21 Page 44 of 49 Page ID #:5162 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 I 57 EXHIBIT C Case 2:20-cr-00579-SVW Document 451-5 Filed 06/08/21 Page 45 of 49 Page ID #:5163 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] - I 58 EXHIBIT C Case 2:20-cr-00579-SVW Document 451-5 Filed 06/08/21 Page 46 of 49 Page ID #:5164 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 I 59 EXHIBIT C Case 2:20-cr-00579-SVW Document 451-5 Filed 06/08/21 Page 47 of 49 Page ID #:5165 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 I 60 EXHIBIT C Case 2:20-cr-00579-SVW Document 451-5 Filed 06/08/21 Page 48 of 49 Page ID #:5166 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 61 EXHIBIT C Case 2:20-cr-00579-SVW Document 451-5 Filed 06/08/21 Page 49 of 49 Page ID #:5167
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