Exhibit F — USA v. Ayvazyan et al. (Dkt. 451-8, C.D. Cal.)

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U.S. District Court for the Central District of California · No. 2:20-cr-00579-SVW · Doc. 451-8 · 2021-06-08 · Docket on CourtListener

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EXHIBIT F
Case 2:20-cr-00579-SVW     Document 451-8     Filed 06/08/21     Page 1 of 2   Page ID
#:5189

1
From:
Fenton, Christopher (CRM) <Christopher.Fenton@usdoj.gov>
Sent:
Tuesday, June 1, 2021 10:52 PM
To:
Ram, Ashwin; Silverman, Nicholas; Keough, Michael; Law offices of Fred G. Minassian, Inc.; David 
Diamond; John Littrell; mesereau@mesereaulaw.com; Wirschinglaw@outlook.com; 
john@hanuszlaw.com; peter@peterjohnsonlaw.com; jilbert@jilbertlaw.com; rfraser@bklwlaw.com; 
michael@thefreedmanfirm.com; George Mgdesyan; rfraser@bklwlaw.com
Cc:
Paetty, Scott (USACAC); Ahn, Catherine S. (USACAC); Paul, Annamelda (CRM)
Subject:
US v. Ayvazyan et al., No. CR 20-579-SVW - Summary Chart Exhibits FRE 1006
Attachments:
Summary Chart Exhibits re Tracing (Draft for Circulation) (06.02.2021).pdf; Summary Chart Exhibit re 
COVID-19 Disaster Relief Loan Application (Draft for Circulation) (06.02.2021).pdf
Counsel –  
For your review, here are two draft sets of summary chart exhibits that the government plans to use at trial 
pursuant to FRE 1006.  In order to provide notice and for ease of reference, the government is identifying these 
summary chart exhibits as trial exhibits and providing a draft copy to you separate and apart from the trial 
exhibit list. The government nevertheless considers these summary charts to be on the government’s trial 
exhibit list for the upcoming trial. 
The first set of charts summarizes information from the many COVID-19 disaster relief loan applications 
submitted by the defendants in this case.  The second set of charts summarizes the flow of those funds from 
those loans through bank and brokerage accounts owned and controlled by the defendants.  Please let us 
know by 6pm Pacific on Thursday, June 3 whether you have any objections to the attached summary chart 
exhibits.   
The government provides its trial exhibit list with the following caveats. 
The government reserves: (1) the right to develop demonstrative exhibits based on the attached list of exhibits 
and content (the government will provide prior notice of a demonstrative exhibit to defense prior to presenting 
it to the jury); (2) the right to refresh a witness’s recollection with exhibits not listed in here; (3) the right to 
change layout/presentment as needed for technology or other presentation purposes but underlying content 
remains the same; (4) the right to remove information from summary exhibits or correct information, as 
needed; (5) the right to not seek admission of all the information in the list; (6) to use additional information 
not listed in rebuttal or to respond to challenges as to the content; (7) to the extent physical exhibits are 
included, the right to replace or supplement the physical exhibits with digital representations of them, as 
needed (the government will provide prior notice of any digital representations of the physical exhibit will be 
provided to defense prior to presentment to the jury and, as always, will make the physical exhibit available 
for inspection upon request).  
Thank you. 
Christopher Fenton 
Trial Attorney 
U.S. Department of Justice 
Criminal Division, Fraud Section 
1400 New York Avenue, NW 
Bond Building 
Washington, DC 20530 
202.320.0539 
84
EXHIBIT F
Case 2:20-cr-00579-SVW     Document 451-8     Filed 06/08/21     Page 2 of 2   Page ID
#:5190

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