Stipulation re Interstate Wires filed by Plaintiff USA — USA v. Ayvazyan et al. (Dkt. 530, C.D. Cal.)

Summary

A stipulation regarding interstate wire transfers, filed June 15, 2021 as Document 530 in United States of America v. Richard Ayvazyan et al., Case 2:20-cr-00579-SVW, in the U.S. District Court for the Central District of California, in which the government and defendants Richard Ayvazyan, Marietta Terabelian, Artur Ayvazyan, Tamara Dadyan and Arman Hayrapetyan agree only that certain wires traveled in interstate commerce, not that the defendants knew of them or that they furthered the scheme alleged by the government. The listed transfers include $182,637.00 sent on May 1, 2020 from WebBank to an account of Sabala Construction and $384,100.00 sent on July 31, 2020 from Capital One, N.A. to an account of Mod Interiors, Inc., and the parties agree that the stipulation be entered into evidence at trial.

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Case 2:20-cr-00579-SVW     Document 530     Filed 06/15/21     Page 1 of 7   Page ID
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TRACY L. WILKISON
Acting United States Attorney
SCOTT M. GARRINGER
Assistant United States Attorney
Chief, Criminal Division
SCOTT PAETTY (Cal. Bar No. 274719)
CATHERINE AHN (Cal. Bar No. 248286)
BRIAN FAERSTEIN (Cal. Bar No. 274850)
Assistant United States Attorneys
Major Frauds/Environmental and Community Safety Crimes Sections
1100/1300 United States Courthouse
312 North Spring Street
Los Angeles, California 90012
Telephone: (213) 894-6527/2424/3819
Facsimile: (213) 894-6269/0141
E-mail: Scott.Paetty@usdoj.gov/Catherine.Ahn@usdoj.gov/
Brian. Faerstein@usdoj.gov

DANTEL S. KAHN
Acting Chief, Fraud Section
Criminal Division, U.S. Department of Justice
CHRISTOPHER FENTON
Trial Attorney, Fraud Section
Criminal Division, U.S. Department of Justice
1400 New York Avenue NW, 3rd Floor
Washington, DC 20530
Telephone: (202) 320-0539
Facsimile: (202) 514-0152
E-mail: Christopher. Fenton@usdoj.gov

Attorneys for Plaintiff
UNITED STATES OF AMERICA

UNITED STATES DISTRICT COURT
FOR THE CENTRAL DISTRICT OF CALIFORNIA
UNITED STATES OF AMERICA, No. CR 20-00579 (A) -SVW

PIAS TELE £ , STIPULATION REGARDING
INTERSTATE WIRE TRANSFERS

Vv.

RICHARD AYVAZYAN,
aka “Richard Avazian” and
“Tuliia Zhadko,”
MARIETTA TERABELIAN,
aka “Marietta Abelian” and
“Viktoria Kauichko,”
ARTUR AYVAZYAN,
aka “Arthur Ayvazyan,” and
TAMARA DADYAN,
MANUK GRIGORYAN,
aka “Mike Grigoryan,” and
“Anton Kudiumov, ”
Case 2:20-cr-00579-SVW     Document 530     Filed 06/15/21     Page 2 of 7   Page ID
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ARMAN HAYRAPETYAN,

EDVARD PARONYAN,

aka “Edvard Paronian” and
“Edward Paronyan,” and

VAHE DADYAN,

Defendants.

Plaintiff United States of America, by and through its
counsel of record, the Acting United States Attorney for the
Central District of California, Assistant United States
Attorneys Scott Paetty, Catherine Ahn, Brian Faerstein, and
Department of Justice Trial Attorney Christopher Fenton, and
defendant Richard Ayvazyan, individually and by and through his
counsel of record Ashwin J. Ram; defendant Marietta Terabelian,
individually and by and through her counsel of record John Lewis
Littrell; defendant Artur Ayvazyan, individually and by and
through his counsel of record Thomas A. Mesereau, Jr. and
Jennifer J. Wirsching; defendant Tamara Dadyan, individually and
by and through her counsel of record Fred G. Minassian;
defendant Arman Hayrapetyan, individually and by and through his
counsel of record Jilbert Tahmazian; hereby agree and stipulate
as follows:
Case 2:20-cr-00579-SVW     Document 530     Filed 06/15/21     Page 3 of 7   Page ID
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STIPULATION AS TO INTERSTATE WIRES

This stipulation solely relates to the fact that certain
wires actually traveled in interstate commerce. It does
not include an agreement regarding whether the defendants
knew these wires occurred or knew that these wires
traveled in interstate commerce, OF that either fact was
foreseeable. It also does not include an agreement
regarding whether these wires were in furtherance of the
scheme alleged by the government.

A wire transfer of $182,637.00, sent on May 1, 2020, from
WebBank to a JPMorgan Chase, N.A. account in the name of
Sabala Construction, was a wire transmission that
traveled in interstate commerce from Utah to California.
A wire transfer of $124,000.00, sent on May 5, 2020, from
Cross River Bank to a U.S. Bank account in the name of
Allstate Towing and Transport LLC, was a wire
transmission that traveled in interstate commerce from
New Jersey, Pennsylvania, or Texas to Kansas.

A wire transfer of $130,000.00, sent on May 7, 2020, from
Celtic Bank to a Wells Fargo Bank, N.A. account in the
name of Iuliia Zhadko dba Top Quality Contracting, was a
wire transmission that traveled in interstate commerce
from Utah to Minnesota.

A wire transfer of $137,500.00, sent on May 11, 2020,
from Comerica Bank to a Comerica Bank account in the name
of Secureline Realty and Funding, Inc., was a wire
transmission that traveled in interstate commerce from

Ohio to California.
Case 2:20-cr-00579-SVW     Document 530     Filed 06/15/21     Page 4 of 7   Page ID
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A wire transfer of $130,187.00, sent on May 8, 2020, from
Celtic Bank to a JPMorgan Chase, N.A. account in the name
of Redline Auto Collision Inc., was a wire transmission
that traveled in interstate commerce from Utah to
California.

A wire transfer of $157,500.00, sent on May 19, 2020,
from Celtic Bank to a Wells Fargo Bank, N.A. account in
the name of Voyage Limo LLC, was a wire transmission that
traveled in interstate commerce from Utah to Minnesota.

A wire transfer of $149,900.00, sent on June 16, 2020,
from the United States Small Business Administration
(“SBA”) to a U.S. Bank account in the name of G&A
Diamonds, was a wire transmission that traveled in
interstate commerce from Colorado to Missouri to New
Jersey to Colorado.

A wire transfer of $150,000.00, sent on June 17, 2020,
from a JPMorgan Chase, N.A. account in the name of
Redline Auto Collision Inc. to a Bank of America, N.A.
account in the name of Marietta Terabelian, was a wire
transmission that traveled in interstate commerce from
California to Pennsylvania or Texas to California.

A wire transfer of $149,900.00, sent on June 22, 2020,
from the SBA to a Radius Bank (a/k/a LendingClub Bank)
account in the name of Timeline Transport, Inc., was a
wire transmission that traveled in interstate commerce
from Colorado to Missouri to New Jersey to Massachusetts.
A wire transfer of $384,100.00, sent on July 31, 2020,
from Capital One, N.A. to a Radius Bank account in the
Case 2:20-cr-00579-SVW     Document 530     Filed 06/15/21     Page 5 of 7   Page ID
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name of Mod Interiors, Inc., was a wire transmission that
traveled in interstate commerce from Illinois or Virginia
to Arkansas to Georgia to Massachusetts.

The submission of a PPP loan application on August 13,
2020, to Newtek Small Business Finance in the name of
Anna Dzukaeva, was a wire transmission that traveled in
interstate commerce from California to Arizona.

This stipulation is being entered into freely and

voluntarily by all parties.
Case 2:20-cr-00579-SVW     Document 530     Filed 06/15/21     Page 6 of 7   Page ID
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The parties agree and stipulate that this stipulation be entered

into evidence at the trial in this matter.

DATED: June AY,

DATED:

DATED:

DATED:

DATED:

June A,

June M

June re

Respectfully submitted,

TRACY L. WILKISON
Acting United States Attorney

SCOLIL-PAETTY

CATHERINE AHN

BRIAN FAERSTEIN

Assistant United States Attorneys
CHRISTOPHER FENTON

Department of Justice Trial
Attorney

Attorneys for Plaintiff
UNITED STATES OF AMERICA

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ASHWIN J. &
Attorney for Defendant
RICHARD AYVAZYAN

RICHARD AYVAZYAN

JOHN L hy LITTRELL
aibeohe ys for Defendant
MARIETTA TERABELIAN

MARIETTA TERABELIAN
Case 2:20-cr-00579-SVW     Document 530     Filed 06/15/21     Page 7 of 7   Page ID
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Case 2:20-cr-00579-SVW

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Document 530 =Filed 06/15/21 Page 7of7 PageID

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THOMAS A. MESEREAU, JR.
JENNIFER J. WIRSCHING

Attorn for Defenfant
ARTUR AYMAZYAN

ARTUR AYYAZY, N7 \y-

BRED G. MINASSIAN
Attorney for Defendant
TAMARA DADYAN

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TAMARA DADYAN

JILBERT TAHMAZTAN
Attorney for Defendant
ARMAN HAYRAPETYAN

ARMAN HAYRAPETYAN


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