Court filing
TRANSCRIPT filed as to Defendant Richard Ayvazyan, Marietta Terabelian, Artur… — USA v. Ayvazyan et al (Dkt. 675)
Record facts
| Court | U.S. District Court for the Central District of California |
|---|---|
| Filed | 2021-07-09 |
U.S. District Court for the Central District of California · No. 2:20-cr-00579-SVW · Doc. 675 · 2021-07-09 · Docket on CourtListener
Summary
A reporter's transcript of proceedings in United States of America v. Richard Ayvazyan, et al., No. 2:20-cr-00579-SVW, before the Honorable Stephen V. Wilson in the U.S. District Court for the Central District of California, Western Division, filed July 9, 2021 as Document 675. The 132-page volume is captioned Jury Trial - Day Five, Volume 1, A.M. session, June 22, 2021, and opens with appearances for the United States and for defendants Richard Ayvazyan, Marietta Terabelian, Artur Ayvazyan and Vahe Dadyan, a witness index and an exhibit table. Outside the presence of the jury the court rules that a proposed defense witness may not testify and says a minute order will follow, and a sidebar addresses a search carried out in a separate investigation. The remainder records direct examination of a government special agent about the loan-fraud investigation, bank records and travel records.
Summary drafted by a model from the document's text below and checked by script against that text before publication. It is a navigation aid, not a reading of what the document proves. Where AI is used
Full text
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UNITED STATES DISTRICT COURT
CENTRAL DISTRICT OF CALIFORNIA - WESTERN DIVISION
HONORABLE STEPHEN V. WILSON
UNITED STATES DISTRICT JUDGE PRESIDING
- - -
United States of America,
)
PLAINTIFF, )
)
VS. ) NO. CR 20-579 SVW
)
Richard Ayvazyan, et al.,
)
DEFENDANT, )
___________________________________)
REPORTER'S TRANSCRIPT OF PROCEEDINGS
LOS ANGELES, CALIFORNIA
JURY TRIAL - DAY FIVE
VOLUME 1 - A.M. SESSION
TUESDAY, JUNE 22, 2021
_____________________________________
KATIE E. THIBODEAUX, CSR 9858
U.S. Official Court Reporter
Suite 4311
350 West 1st Street
Los Angeles, CA 90012
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Case 2:20-cr-00579-SVW Document 675 Filed 07/09/21 Page 1 of 132 Page ID
#:10428
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APPEARANCES OF COUNSEL:
ON BEHALF OF THE PLAINTIFF, UNITED STATES OF AMERICA:
U.S. DEPARTMENT OF JUSTICE
U.S. ATTORNEY'S OFFICE
BY: CATHERINE SUN AHN, AUSA
-and- SCOTT PAETTY, AUSA
312 North Spring Street
Twelfth Floor
Los Angeles, CA 90012
-and-
Christopher Fenton
US Department of Justice
1400 New York Avenue, NW
Washington, DC 20530
FOR DEFENDANT R. AYVAZYAN:
Ashwin J. Ram
Steptoe and Johnson LLP
633 West 5th Street
Suite 1900
Los Angeles, CA 90071
Meghan Newcomer
Steptoe and Johnson LLP
1114 Avenue of the Americas
New York, NY 10036
Michael A. Keough
Steptoe and Johnson LLP
1 Market Street
Spear Tower Suite 3900
San Francisco, CA 94105
Nicholas P. Silverman
Steptoe and Johnson LLP
1330 Connecticut Avenue NW
Washington, DC 20036
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APPEARANCES (Cont'd):
FOR DEFENDANT TERABELIAN:
John Lewis Littrell
Bienert Katzman Littrell Williams LLP
903 Calle Amanecer
Suite 350
San Clemente, CA 92673
Ryan Vaughan Fraser
Bienert Katzman Littrell Williams LLP
601 West 5th Street
Suite 720
Los Angeles, CA 90071
FOR DEFENDANT ARTUR AYVAZYAN:
Jennifer J. Wirsching
1935 Alpha Road
Suite 216
Glendale, CA 91208
Thomas A. Mesereau, Jr.
Mesereau Law Group
10100 Santa Monica Boulevard
Suite 300
Los Angeles, CA 90067
FOR DEFENDANT VAHE DADYAN:
Peter Johnson
Law Office of Peter Johnson
409 North Pacific Coast Highway
Suite 651
Redondo Beach, CA 90277
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Case 2:20-cr-00579-SVW Document 675 Filed 07/09/21 Page 3 of 132 Page ID
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4
I N D E X
WITNESS NAME PAGE
GEFFREY CLARK
Direct Examination by Mr. Fenton 8
Cross-Examination by Mr. Silverman 32
EXHIBIT I.D. IN EVID.
74 22 22
84 24 24
56D 27 28
75 30 30
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24 59 59
52 62 62
48 63 64
73 69 69
3 75 75
4 76 77
63 82 82
45 96 96
35, 3-5 97 97
46 100 101
38 102 103
34 109
47 109 108
35, 6 109 110
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Case 2:20-cr-00579-SVW Document 675 Filed 07/09/21 Page 4 of 132 Page ID
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LOS ANGELES, CALIFORNIA; TUESDAY, JUNE 22, 2021
9:00 A.M.
- - - - -
(The following proceedings were held outside the
presence of the jury:)
THE COURT: We are present with the parties and
counsel outside the presence of the jury.
A number of things. First, I have considered
the argument about whether Barnes should, under the
appropriate offers of proof, be allowed to testify, and I
have concluded that he cannot testify. I am issuing a
minute order which will explain my reasoning.
I don't want to take up time on it now, but I
will issue tht and you can have it for your record.
Will the defendants approach sidebar.
(The following proceedings were held at sidebar
outside the presence of the jury:)
THE COURT: Regarding Stevens, when he -- can you
hear me okay?
When he made the search that you are going to
get into, was that in connection with this investigation
or some other investigation?
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MR. RAM: Some other.
THE COURT: Some other?
MR. RAM: Yes.
THE COURT: Because there was a state LAPD
officer; correct?
MR. RAM: Correct.
THE COURT: And so what investigation was it? Was
it an investigation that we have mentioned so far or
something else?
MR. RAM: It hasn't developed yet. It is just
that he searched his house.
THE COURT: But in that investigation was
Grigoryan obviously the subject or target of the
investigation?
MR. RAM: It is an ongoing. I believe it is an
ongoing investigation.
THE COURT: It is ongoing.
MR. RAM: Yes.
THE COURT: But in that investigation, are any of
the other defendants in this case involved like Richard
Ayvazian?
MR. RAM: No.
THE COURT: Or Tamara Dadyan.
MR. RAM: No.
THE COURT: It is just a one-off as regards him?
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MR. RAM: Correct.
THE COURT: I see. Okay. I just wanted to make
that clear.
MR. RAM: It might be completely -- I don't want
to speak out of turn, but I believe it is like a random
drug investigation by the state. I just don't know the
full details and we are not going to get into that.
THE COURT: You are not going to get into that.?
MR. RAM: Not at all, your Honor. Not relevant.
(The following proceedings were held outside the
presence of the jury:)
THE COURT: Get the jury.
Does it say 17 after 9:00?
MS. AHN: Yes, your Honor. I believe so.
(The following proceedings were held in the
presence of the jury:)
THE COURT: Good morning, members of the jury.
Thank you once again for being punctual. The Court
appreciates it and the parties do. We are ready to
resume.
MR. FENTON: Thank you, your Honor. The
government calls Special Agent Geffrey Clark.
(The witness was sworn.)
THE CLERK: Please be seated. State your full
name and spell it for the record.
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Case 2:20-cr-00579-SVW Document 675 Filed 07/09/21 Page 7 of 132 Page ID
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THE WITNESS: My name is Geffrey Clark. It is
spelled G-E-F-F-R-E-Y, C-L-A-R-K.
DIRECT EXAMINATION
BY MR. FENTON:
Q
Good morning, Special Agent Clark. Can you tell us
where you work?
A
I work for the IRS criminal investigation.
Q
And how long have you been a federal agent?
A
For just under 22 years.
Q
Now, did there come a time when you began
investigating PPP and EIDL loan product fraud?
A
Yes.
Q
And approximately when was that?
A
The end of June of 2020.
Q
And how did your investigation begin?
A
I was asked to participate in this investigation
and investigate financial crimes as well as tax crimes.
The original lead came in under Jobe
Construction. Several of the names were Ulia Zhadko,
Mark Zindroski, Timeline Transport and Top Quality
Contracting.
Q
As part of the investigation, did your
investigation eventually include the defendants?
A
Yes, it did.
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Case 2:20-cr-00579-SVW Document 675 Filed 07/09/21 Page 8 of 132 Page ID
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Q
And as part of your investigation, did you look
into where the defendants lived between March and August,
2020?
A
Yes, I did.
Q
And what did you find?
A
They lived in the Central District of California.
Q
And as part of your investigation, did you look
into whether the defendants were actually in or around
Los Angeles, in or around the Central District during the
time that they were submitting the fraudulent PPP and
EIDL loan applications?
A
Yes, I did.
Q
And what did you find?
A
That they were living in the Central District of
California.
Q
And they were actually present in California as
well?
MR. LITTRELL: Objection. Foundation.
THE COURT: Sustained.
Q BY MR. FENTON: Special Agent Clark, did you review
bank records relating to the defendants?
A
Yes, I did.
Q
And relating to the defendant's aliases as well?
A
Yes, I did.
Q
Would that include Ulia Zhadko?
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Case 2:20-cr-00579-SVW Document 675 Filed 07/09/21 Page 9 of 132 Page ID
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A
Yes.
Q
Viktoria Kauichko?
A
Yes.
Q
Anton Kudiomov?
A
Yes.
Q
What did you find as a result of that review?
A
In reviewing the bank records, I reviewed
particularly the expenses or point of sale where
purchases were made. The majority of those sales were
made in the San Fernando Valley in Los Angeles County
Central District of California.
Q
And those are all locations within the Central
District of California?
A
Yes.
Q
Did you review IP address information relating to
the applications that were submitted in this case?
A
Yes, I did.
Q
And I am going to show you a couple of those
documents. I am going to start by showing you what has
been previously admitted as government's Exhibit 73C.
Looking at this page, is that one of the IP
addresses that was used to submit PPP and EIDL loan
applications?
A
Yes. This is the subscriber record for Viktoria
Kauichko.
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Case 2:20-cr-00579-SVW Document 675 Filed 07/09/21 Page 10 of 132 Page ID
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Q
And what is the subscriber address here?
A
You want me to read the whole thing?
Q
Yes.
A
2605 --
Q
No. The subscriber address.
A
Oh. The address, 6150 Canoga Avenue, Apartment
337, Woodland Hills, California.
Q
And is that within the Central District of
California?
A
Yes.
Q
All right. Let's look at page 6. Is this one of
the IP addresses that was used in connection with the
fraudulent scheme?
A
Yes, this is for Manuk Grigoryan.
Q
And what is his subscriber address?
A
10537 Dora. That is in Sun Valley, California.
Q
Is that within the Central District of California?
A
Yes, it is.
Q
Let's look at one more. Let's look at page 12, and
what subscriber name do we have here?
A
Artur Ayvazian.
Q
And what is the subscriber address?
A
17450 Weddington Street, Encino, California.
Q
Is that address also within the Central District of
California?
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Case 2:20-cr-00579-SVW Document 675 Filed 07/09/21 Page 11 of 132 Page ID
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12
A
Yes.
Q
And was this IP address used in connection with the
fraudulent scheme?
A
Yes.
Q
Earlier you mentioned that the defendants lived in
and around Los Angeles. Did any of the defendants use
their home addresses on fraudulent PPP and EIDL loan
applications?
MR. LITTRELL: Objection. Foundation.
THE COURT: Ask the question again.
MR. FENTON: Yes, your Honor.
Q BY MR. FENTON: Did any of the defendants use their
home addresses in connection with PPP or EIDL loan
applications?
THE COURT: The objection was what?
MR. LITTRELL: Foundation.
THE COURT: Sustained.
Q BY MR. FENTON: Special Agent Clark, did you review
PPP and EIDL loan applications in connection with your
investigation?
A
Yes.
Q
Did any of the defendants use their home addresses?
MR. LITTRELL: Objection. Foundation.
THE COURT: Sustained.
MR. FENTON: All right. We will move on.
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Case 2:20-cr-00579-SVW Document 675 Filed 07/09/21 Page 12 of 132 Page ID
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Q
Did the defendants travel outside of the country
between March and August 2020?
MR. LITTRELL: Objection. Foundation.
THE COURT: Sustained.
Q BY MR. FENTON: Special Agent Clark, did you review
travel records relating to the defendant's travel in
connection with your investigation?
A
Yes.
Q
And based on your review of those travel records,
did any of the defendants travel outside of the country
between March and August 2020?
MR. LITTRELL: Objection. Foundation.
THE COURT: Sustained.
Q BY MR. FENTON: Earlier you testified that you
analyzed the bank records for the defendants and their
aliases; correct?
A
Yes.
Q
Did you look at the bank records for Ulia Zhadko?
A
Yes, I did.
Q
I am going to show you what what was previously
admitted as government's Exhibit 1N. And directing your
attention to -- well, do you recognize this document?
Let me direct your attention to page 31. Do
you recognize this document?
A
Yes.
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Case 2:20-cr-00579-SVW Document 675 Filed 07/09/21 Page 13 of 132 Page ID
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Q
Can you tell me what this is?
A
This is what we refer to as a travel alert.
Q
Okay. And what is this travel alert requesting?
A
This is a travel alert that Ulia Zhadko was
informing the bank that he will be traveling out of the
country and these travel alerts are basically to let the
credit card company know or the bank know that purchases
or expenses may be observed out of their normal spending
pattern.
Q
All right. Can we turn to page 2 -- or 32. All
right. And when does Ulia Zhadko tell his bank that he
will be traveling?
THE COURT: I still didn't hear a thing you said.
Q BY MR. FENTON: What dates did Ulia Zhadko tell
Radius Bank that he will be traveling?
A
October 10th through October 20th and that would
refer to last year, 2020.
Q
And where did Ulia Zhadko say that he was traveling
to?
A
Indicated he was going to the Caribbean, Turks and
Caicos.
Q
All right. At the start of your investigation,
what, if anything, did you do to investigate the name
Ulia Zhadko?
A
I reviewed several numerous loan applications, and
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Case 2:20-cr-00579-SVW Document 675 Filed 07/09/21 Page 14 of 132 Page ID
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I specifically ran the driver's license associated to
those loan applications.
Q
All right. I am showing you what has been
previously admitted as government Exhibit 6J.
Directing your attention to page 18, do you
recognize this document?
A
Yes.
Q
Okay. What is this?
A
It is the driver's license submitted in support of
the application.
Q
All right. And did you --
THE COURT: What application? I mean, ask
complete questions and let's get complete answers.
Q BY MR. FENTON: Is this the -- can we go back to the
front. Special Agent Clark, do you recognize this
document?
A
Yes.
Q
Can you tell us what it is?
A
It is an application for a PPP loan in the business
name of Timeline Transport, Inc.
Q
All right. Directing your attention to the next
page. Who signs this application?
MR. LITTRELL: Objection. Foundation.
THE COURT: The document is in evidence; correct?
MR. FENTON: Yes.
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THE COURT: Who signs the application. The
objection is sustained. No foundation.
Q BY MR. FENTON: Directing your attention to the
bottom of the page, can you read to us what it says under
signature of authorized representative of applicant?
A
Under that in type it says Ulia Zhadko.
Q
All right. Directing your attention to page 18, do
you recognize this document?
A
Yes.
Q
And what do you recognize this document to be?
A
That is the driver's license submitted with the PPP
application.
Q
And the address here says 5141 Genesta Avenue,
Encino, California; correct?
A
Correct.
Q
Did you investigate that address?
A
Yes.
Q
What steps, if any, did you take?
A
I basically did a public database search. I ran
the name through Accurate, which is very similar to TLO.
Q
And what did you find?
A
That is the former address of defendants Richard
Ayvazian and Marietta Terabelian.
Q
We are going to move on to another exhibit. I am
going to show you what has been previously marked as
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government's Exhibit 6L. Do you recognize this document?
THE COURT: Is this 6L? Is 6L in evidence.
THE WITNESS: I thought it says 6I.
THE COURT: One moment. Is it in evidence?
MR. FENTON: Yes, your Honor.
THE COURT: All right. And is this a document
this witness gathered in his investigation?
MR. FENTON: This is a document that the witness
reviewed in the course of his investigation.
THE COURT: Why do you ask whether he recognize it
or not? I mean, let's say he doesn't recognize it.
Would you still ask him what is in it?
MR. FENTON: I would, your Honor.
THE COURT: Well, do that.
MR. FENTON: Okay.
Q
BY MR. FENTON: Directing your attention to page
16. Do you recognize --
THE COURT: Somebody's phone is going off, or am I
hearing something?
Q BY MR. FENTON: Special Agent Clark, have you seen
this driver's license before?
A
Yes.
Q
Did you look at it in connection with your
investigation?
A
Yes.
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Q
And the address in this driver's license is 22330
Victory Boulevard, Apartment 303, Woodland Hills,
California; correct?
A
Yes.
Q
Did you investigate this address?
A
Yes.
Q
And what did you find?
A
I found that --
MR. SILVERMAN: Objection. Foundation.
THE COURT: What did you find? I mean, that is a
very open-ended question. I mean, can you make it a
little more specific?
MR. FENTON: I can, your Honor.
Q
BY MR. FENTON: Did you search public databases,
publicly available records to see who resided at this
address?
A
Yes.
Q
And what did you find?
MR. SILVERMAN: Objection. Foundation.
THE COURT: Overruled.
THE WITNESS: That Ulia Zhadko did not reside at
that address.
Q
BY MR. FENTON: Okay. Did you actually visit that
address?
A
Yes, I did.
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Q
In person?
A
Yes.
Q
And what did you find?
A
We had executed a search warrant and the door was
still boarded up. It indicated that basically nobody was
living there anymore.
Q
All right. Did you investigate Timeline Transport?
A
Yes.
Q
And what steps did you take to investigate Timeline
Transport, the company?
A
I went to the locations indicated on the
application.
Q
Okay. And what did you find when you visited that
location?
A
That the business wasn't there.
Q
Are you familiar with a company referred to as Top
Quality Contracting?
A
Yes.
Q
And is that a company that's associated with Ulia
Zhadko?
A
Yes.
Q
And did you investigate that company as well?
A
Yes.
Q
And what steps did you take?
A
The location is Mark Zindroski's.
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Q
Okay. And how about the company? Are you familiar
with the company Turing Info Solutions?
A
Yes.
Q
Is that one of the companies that was used to apply
for PPP loan applications?
A
Yes.
Q
Is that one of the companies associated with Ulia
Zhadco?
A
Yes.
Q
Did you investigate that company as well?
A
Yes.
Q
And did you do a location check for that company?
A
I spoke with the property manager for that
location.
Q
Okay. And what did you find?
A
That -- I found that Turing Info Solutions was not
at that address and had never been at that address.
Q
All right. In the course of your investigation,
did you look into how Ulia Zhadco's name was used just
generally?
A
Yes.
Q
And was his name used in connection with any real
estate transactions?
A
Yes, it was.
Q
What real estate transaction was that name used in
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connection with?
A
It was a purchase of a residence on Calle La
Primavera in the City of Glendale, California.
Q
And was that within the Central District of
California?
A
Yes.
Q
Did you take any steps to actually investigate the
actual real estate transaction itself?
A
Yes, I did.
Q
What steps did you take?
A
I reviewed the escrow documents.
Q
Going to show you what has been previously admitted
as government Exhibit 30J.
Can you tell what this document is, Special
Agent?
A
This is part of an e-mail string regarding the real
estate transaction.
Q
For which property?
A
It is the Beverly Hills escrow, so that would be
the Calle La Primavera purchase.
Q
It appears this is an e-mail sent from the law
offices of owe Olaf Landsgaard; correct?
A
Yes, it does represent that.
Q
Based upon your review of this e-mail, what was
Olaf Landsgaard's purported role in this transaction?
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A
He was an attorney representing the purchaser Ulia
Zhadco in the purchase of the Calle La Primavera
property?
Q
Now, as part of your investigation did you attempt
to reach out to and interview Olaf Landsgaard?
A
Yes, I did.
Q
And were you able to do so?
A
No, I was not.
Q
And why is that?
A
He had passed away in April of 2019.
Q
All right. Showing you what has been previously
marked government's Exhibit 74 for identification.
Mr. Cruz, I just ask that we show the witness
this exhibit.
Special Agent Clark, what is this document?
Do you recognize this document?
A
Yes, I do.
Q
And what do you recognize it to be?
A
This is a death certificate for Olaf Landsgaard.
MR. FENTON: Your Honor, the government moves to
admit government Exhibit 74.
THE COURT: Received.
MR. FENTON: Permission to publish.
(Exhibit 74 received in evidence.)
THE WITNESS: Yes.
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Q BY MR. FENTON: Based on your review of the death
certificate, when did Olaf Landsgaard pass away?
A
April 23rd, 2001.
Q
And when was Olaf Landsgaard's name used in
connection with the Ulia Zhadco deal?
A
In the summer of 2020.
Q
Did you investigate who was living in the house
purchased by Ulia Zhadco?
A
Yes. I attempted to.
Q
Okay. And what steps did you take?
A
I obtained the records from the City of Glendale
Department of Water and Power.
Q
All right. I am going to show you what has been
marked as government's Exhibit 84.
And, Mr. Cruz, again I would ask that we show
this only to the witness.
Do you recognize this document, Special Agent?
A
Yes. This is part of the documents that I received
from the City of Glendale.
Q
And you received these documents personally?
A
Yes.
MR. FENTON: Your Honor, we move to admit as a
self-authenticating business record pursuant to 902(11)
and 803(6).
THE COURT: Received.
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MR. FENTON: Permission to publish.
THE COURT: Yes.
(Exhibit 84 received in evidence.)
Q
BY MR. FENTON: So, Special Agent Clark, can you
tell the jury, what does this document show?
A
I think you need to go to a different page of the
document.
MR. FENTON: Mr. Cruz, can we publish this
document. My apologies.
Q
BY MR. FENTON: Special agent Clark, can you tell
the jury what does this document show?
A
Well, this document just shows who the account
holder on the -- you need to go to a different page.
Q
All right. Let's go to page 2.
A
I believe it is more towards the end of the
document. Back up.
Q
Is this the page that you were referring to,
Special Agent Clark?
A
Yes, it is.
Q
What does it say next to account holder?
A
It says that the name of the account holder is
Vardui Terabelian.
Q
And did you look into that name?
A
Yes.
Q
And does that name have any relationship to the
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defendants?
A
It is Marietta Terabelian's mother and Richard
Ayvazian's mother-in-law.
Q
And this is the person who the account for water
and utilities is in for the Ulia Zhadco house?
A
Yes, it is.
Q
Now, as part of your investigation what, if
anything, did do you to investigate the name Viktoria
Kauichko?
A
I analyzed bank records. I went to the location
indicated on the driver's license and the addresses
associated to the loans.
Q
Okay. When you say the addresses associated with
the loans, do you mean the loans that were taken out in
the Viktoria Kauichko name?
A
Yes.
Q
And is Runyan Tax Service one of those names?
A
Yes, it is.
Q
Did you attempt to visit the address for Runyan Tax
Service?
A
I did visit the address.
Q
And what did you find?
A
That Runyan Tax Service was not there.
Q
All right. Is Fiber One another company that was
submitted -- for which Viktoria Kauichko submitted a PPP
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loan application?
A
Yes, it is.
Q
And did you visit the Fiber One Media address on
that application?
A
Yes, I did.
Q
And what did you find?
A
That Fiber One wasn't there. It was occupied by an
accounting company for at least six years.
Q
And how about Journeyman Construction. Is that
another company associated with Viktoria Kauichko?
A
Yes, it is.
Q
Did that company file for a PPP loan application?
A
Yes, it did.
Q
Did you visit the address for that company as well?
A
Yes, I did.
Q
And what did you find?
A
That unit was occupied by like a home design
service company for the past two years.
Q
Now, as part of your investigation, were you
involved in the execution of any search warrants of any
of the defendants' homes?
A
Yes, I was.
Q
Which residence?
A
The residence of Richard Ayvazian and Mary
Terabelian, which is the Topeka residence.
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Q
And are you physically on the property during the
search?
A
Yes, I was.
Q
What was your role in connection with that search?
A
Initial role was assigned as a searcher, but I
turned more into a rover.
Q
And what is a rover? Can you please describe what
a rover does for the jury?
A
I would go around and answer questions of other
agents that were searching regarding what they found, if
it was relevant or not.
Q
And what was the date of that search?
A
November 5th, 2020.
Q
Showing you what has been previously marked,
government Exhibit 56D.
Mr. Cruz, I would like to show this just to
the witness at first. Do you recognize this photograph?
A
Yes, I do.
Q
What does this photograph depict?
A
It is a picture of a cell phone, of which there are
three credit cards on it.
Q
Okay. And did you find this phone at the search
site?
A
I wasn't the finder of the phone, but on the
initial assessment when I went through at the beginning
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to determine if we needed more manpower, I found this
phone on the kitchen table.
Q
And when you found the phone, can you just tell us
what state was the phone in?
A
In our training if we find a digital device, we are
instructed to see if the device is on. And if it is on,
we are instructed to turn it into airplane mode so there
is no communication going into the phone. So when I
flipped it over, it was in the on state.
Q
And was this what you saw when you flipped the
phone over?
A
Yes.
Q
And is this photograph a fair and accurate
depiction of what was on the phone at that time?
A
Yes.
MR. FENTON: Your Honor, the government moves to
admit.
THE COURT: Received.
MR. FENTON: Permission to publish.
THE COURT: What exhibit number is this?
MR. FENTON: This is government Exhibit 56D, as in
delta.
THE COURT: Yes.
(Exhibit 56D received in evidence.)
Q BY MR. FENTON: Special agent Clark, this is the
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phone you found on November 5th when you searched the
house that Richard Ayvazian and Mary Terabelian's home;
correct?
A
This was on the kitchen table.
Q
And can you describe for the jury what are the
names on the three credit cards depicted in this
photograph?
A
From top to bottom, the Citibank gold card is Ulia
Zhadco, the middle Citibank gold card is Viktoria
Kauichko and the bottom Citicard is Ulia Zhadco.
Q
Okay. And the search took place approximately two
weeks after the defendants had been arrested in
connection with this case; correct?
A
Approximately.
Q
Now, as part of your investigation, did you look
into a company named Mod Interiors?
A
Yes.
Q
And what steps did you take to investigate Mod
Interiors?
A
Again, I did a location check.
Q
Okay. And is Mod Interiors one of the companies
that applied for a PPP loan in connection with this case?
A
Yes.
Q
Showing you what has been marked -- what has been
previously admitted as government Exhibit 2O. And,
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Case 2:20-cr-00579-SVW Document 675 Filed 07/09/21 Page 29 of 132 Page ID
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Special Agent Clark, is this one of the PPP loan
applications submitted by Mod Interiors?
A
This is one of the applications for Mod Interiors.
Q
All right. Directing your attention to page 2, at
the bottom of the page, it says signature of authorized
representative of applicant. What name does it say
there?
A
In the print it says Nazar Terabelian.
Q
And what is the date that the signature?
A
July 23rd, 2020.
Q
Now, did you conduct an investigation into the name
Nazar Terabelian?
A
Yes, I did.
Q
And what did you find?
A
I found Nazar had passed away.
Q
All right. Showing you what has been marked for
identification as government Exhibit 75.
Mr. Cruz, I would ask that we show this only
to the witness.
Special Agent Clark, did do you recognize this
document?
A
Yes, I do.
Q
What is this?
A
It is the death certificate for Nazar Terabelian.
MR. FENTON: Your Honor, the government moves to
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admit government Exhibit 75?
THE COURT: Received.
(Exhibit 75 received in evidence.)
MR. FENTON: Permission to publish.
THE COURT: Yes.
Q BY MR. FENTON: Special Agent Clark, can you explain
to the jury what this document shows?
A
It is the death certificate for Nazar Terabelian.
It indicates the date of death as July 18th, 2020.
Q
And when was Nazar Terabelian's name used in
connection with the Mod Interiors PPP loan application?
A
July 23rd, 2020.
Q
So approximately five days following his date of
death?
A
Approximately.
Q
And did you look to see whether Nazar Terabelian
was related to any of the defendants in this case?
A
Yes.
Q
And what did you find?
A
Nazar Terabelian is Marietta Terabelian's father,
and the father-in-law of Richard Ayvazian.
MR. FENTON: No further questions.
THE COURT: Cross-examination.
MR. SILVERMAN: Your Honor, we have some defense
exhibits we would like to move into evidence that we sent
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the government last night.
THE COURT: Any objection to these exhibits?
MR. FENTON: Your Honor, I believe that there may
be an objection to some of these exhibits.
THE COURT: Well, then, we have to deal with them
one at a time. I mean, if this witness is the witness
who can lay a foundation, do that. Otherwise, we can't
show exhibits to the jury regarding exhibits that haven't
been received.
MR. SILVERMAN: Yes, your Honor. I believe we can
deal with it as it comes.
THE COURT: Okay.
CROSS-EXAMINATION
BY MR. SILVERMAN:
Q
Good morning, Agent Clark.
A
Good morning.
Q
Agent Clark, you testified about your investigation
into this case; correct?
A
Yes.
Q
And as part of that investigation, you investigated
Manuk Grigoryan; correct?
A
Yes, he was part of this investigation.
Q
And he was responsible for several key synthetic
identities, wasn't he?
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MR. FENTON: Objection, your Honor. That question
is confusing and vague.
THE COURT: The word responsible?
MR. FENTON: Yes. The word responsible and key.
Q BY MR. SILVERMAN: He used synthetic identities,
didn't he?
A
Yes.
Q
He used them from his home; correct?
A
Yes.
Q
And his home is at 10537 Dora Street; right?
A
Yes.
Q
And that is in Sun Valley, California?
A
Yes.
Q
And he used them from his apartment, didn't he?
A
The 6150 Canoga.
Q
He used them from 6150 Canoga Avenue; right?
A
Yes.
Q
And that apartment was registered in his name,
wasn't it?
A
Initially.
Q
And, initially, specifically, it was registered in
his name beginning in November, 2019?
A
That seems about right.
Q
And that is before any -- the CARES Act was passed;
correct?
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A
Yes.
Q
And then, in April, 2020 he received a renewal
packet; right?
A
I am not aware of that.
MR. SILVERMAN: If we could please pull up
government Exhibit 42 and go to page 3.
Oh. I need to switch over.
If we can blow up the bottom half of the page,
please.
Q
BY MR. SILVERMAN: And so does this show that on
approximately -- or it is actually April 23rd, a renewal
packet was sent to Manuk Grigoryan?
A
Could I see page 1 so I know what the totality of
the document is?
Q
Absolutely. If we could go over to page 1, please,
and I can represent to you that the custodian on this
document was Warner Pointe Center?
THE COURT: I didn't hear what you said.
MR. SILVERMAN: I can represent to the witness
that the custodian on the document was Warner Center, The
Pointe at Warner Center.
THE WITNESS: Okay.
Q BY MR. SILVERMAN: And up at the top it says
"Activity for Victoria Kauichko"; correct?
A
Yes, it does.
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Q
So if we can go to page 3 and blow up the bottom
half again. And listed as activity for Viktoria Kauichko
on April 23rd is sending a renewal packet to Manuk
Grigoryan at Mikegrigoryan93@gmail.com; right?
A
That is what it represents.
Q
And three weeks later, an application was submitted
in the name of Viktoria Kauichko; correct?
A
That is what it represents.
MR. SILVERMAN: And can we go to the next page,
please, and blow up the top half of the page.
THE COURT: An application for a lease?
MR. SILVERMAN: Yes, your Honor.
THE COURT: Let's finish these sentences.
MR. SILVERMAN: Yes, your Honor.
Q BY MR. SILVERMAN: And after the application was
submitted, it was approved; correct?
A
Yes. That is what it represents there on May 14th.
Q
And it looks like in June, 2020, Viktoria Kauichko
became the rental holder at 6150 Canoga Avenue; right?
A
I don't know that.
MR. SILVERMAN: Well, can we go to page 24, I
guess, please. And can we blowup the second line,
please.
Q
So this is a document related to 6150 Canoga
Avenue; correct?
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A
Yes.
Q
Page 4, which we were on a moment ago, said that
Viktoria Kauichko took over; correct?
A
I don't know if that document says she took over or
she was added to the lease.
Q
So either she was added to the lease or she
replaced Manuk Grigoryan; correct?
A
I can't say either way.
Q
Now, if we can go to page 12, please. And if we
can blowup just the top couple of lines.
This is a key fob registry; is that right?
A
Yes.
Q
And up at the top left it says Manuk Grigoryan;
right?
A
Yes.
Q
So this key fob is presumably registered to Manuk
Grigoryan?
A
Yes.
Q
And if we look at the date stamp there, it was used
up through November, 2020; right?
A
That is what it indicates.
Q
And so that is even after Viktoria Kauichko was
added to the lease or signed her own lease; correct?
THE COURT: You know, something is happening with
your questions that don't enable me to hear you clearly.
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Could you make a better effort?
MR. SILVERMAN: Yes, your Honor.
Q
BY MR. SILVERMAN: Agent Clark, November, 2020, was
after Viktoria Kauichko submitted an application;
correct?
A
Yes.
Q
And, after, that application for residency was
approved; correct?
A
Yes.
Q
And Manuk Grigoryan's key fob was still being used
to scan in and out of the building; correct?
A
The key fob assigned to him was being used.
Q
Well, do you think that the key fob was in Richard
Ayvazian's possession?
MR. FENTON: Objection, your Honor. That lacks
foundation calls for speculation.
THE COURT: Sustained.
MR. SILVERMAN: Yes, your Honor.
Q
BY MR. SILVERMAN: Let's see if we go to page 14,
please. And can we zoom in on those dates, please.
Now, this says that the key fob was used on
October 21 and October 22nd; correct?
A
Yes. Going top to bottom, it indicates activity
for the key fob.
Q
So Richard Ayvazian was in jail in Miami on
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October 21 and October 22, wasn't he?
A
That is my recollection. Yes.
Q
In connection with this case?
A
Yes.
Q
Now, the government obtained surveillance videos
from this apartment complex; correct?
A
Yes.
Q
And in fact you visited this apartment complex,
right?
A
Several times.
Q
And you viewed those surveillance videos?
A
Videos were provided to me and I viewed those
videos.
THE COURT: I didn't hear what you said.
THE WITNESS: Videos were provided to me that I
viewed. I didn't search for the videos.
Q BY MR. SILVERMAN: And on any of those videos did
you see Richard Ayvazian?
MR. FENTON: Objection, your Honor. I think there
is some confusion about what videos were viewed.
THE COURT: I don't know. I mean, do you
understand the question?
THE PROSPECTIVE JUROR: Yes, your Honor.
THE COURT: Then you can answer it.
MR. SILVERMAN: And I can clarify, your Honor.
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THE COURT: He understands the question. That is
the important thing.
MR. SILVERMAN: I would like to just make sure --
if counsel doesn't understand, I would like to make sure
that the jury understands as well.
THE COURT: Well, let him answer and see what
follows. I mean, it sounds simple. You asked whether
there were videos of the apartment.
MR. SILVERMAN: Correct.
THE COURT: He said he didn't -- wasn't the person
who made the videos, but they were made available to him.
You can ask him how he got them and what he saw on them
if anything. I don't know.
Q
BY MR. SILVERMAN: How is it you got the
surveillance videos from Canoga Avenue?
A
Well, I went to the Canoga and they gave me the
hard drive.
Q
And who reviewed those hard drives?
A
One of our computer specialists.
Q
And what were they supposed to give to you?
A
They would give me clips of certain times that they
believe maybe there would be activity that I could
recognize somebody.
Q
And were they provided with photos of the
defendants?
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A
No, they were not.
Q
Were they provided with descriptions of the
defendants?
A
General descriptions.
Q
And did anyone review these videos that had a
photograph of Richard Ayvazian?
A
Yes.
Q
And did anybody provide you with a video clip that
had Richard Ayvazian going in or out of the Canoga
apartment complex?
A
There were several videos of unidentified males
that we reviewed. So I couldn't say if it was Richard or
not.
Q
But you reviewed whatever was given to you;
correct?
A
Yes. Very limited.
Q
And you know what Richard Ayvazian looks like?
A
Yes.
Q
You have been investigating him for almost a year?
A
Since October of last year.
Q
Did you see Richard Ayvazian on any of those
videos?
A
Not to my knowledge.
MR. SILVERMAN: I would like to bring up defense
Exhibit 1, please.
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Q
BY MR. SILVERMAN: Now, you were here when Agent
Massino was questioned about this particular photograph
yesterday; correct?
A
Yes.
Q
And he was asked whether in June, 2020 he believed
this person was Ulia Zhadco?
A
From the e-mail. Yes.
Q
And in June, 2020, did you believe this person was
Ulia Zhadco?
A
We believed that this person was using Ulia
Zhadco's debit card to access funds from -- I think this
is from B of A.
Q
Now, when you reviewed those surveillance videos,
you did see this person on them, didn't you?
A
To clarify, I didn't see any videos. I just saw
photographs.
Q
When you reviewed the clips from the Canoga
apartment complex, you did see this person in those
clips; right?
A
I believe that I did see an individual with this
gentleman's stature.
Q
So this gentleman did appear to be going in and out
of Canoga; correct?
A
There was only one video clip with this gentleman
on there that I observed.
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Q
And you know this gentleman to be a man named
Parure Hayrapetyan; correct?
A
Yes.
Q
And Parure Hayrapetyan works with Manuk Grigoryan,
doesn't he?
A
I am not aware of that.
Q
Mr. Clark, you worked with a man named Arman
Hayrapetyan in this case; correct?
A
Yes, that's correct. I recall now.
Q
So Armin Hayrapetyan informed you that Parure
Hayrapetyan works for Manuk Grigoryan; correct?
A
Hayrapetyan -- well, this gentleman -- I don't want
to mispronounce the name -- would pick Armin up. Yes.
Q
And to back up for one moment, Armin and Parure,
there is no relation; correct?
A
Not to my knowledge.
Q
And Armin worked for Manuk Grigoryan?
MR. FENTON: Objection, your Honor. Lack of
foundation, based on hearsay.
THE COURT: Did you investigate that relationship?
THE WITNESS: In a general sense, yes.
THE COURT: What did you do?
THE WITNESS: I tried to connect a familiar link
through public records.
THE COURT: And were you able to make any
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connection between the names that the lawyer has asked
you about in the question?
THE WITNESS: No.
THE COURT: The objection is sustained.
MR. SILVERMAN: Your Honor, may I inquire as to
the -- for the failure to investigate leads, your Honor?
THE COURT: Well, he just said he did investigate.
If you want to ask him about what else he could have done
or what he did do, you can do that, but the objection to
your question is sustained.
Q BY MR. SILVERMAN: Agent Clark, based on your
investigation in this case, are you aware that Armin and
Parure Hayrapetyan are connected with Manuk Grigoryan?
A
Yes.
Q
Now we can take down the photo.
You mentioned on direct examination that you
reviewed IP addresses in this case?
A
Cursory review.
Q
And one of the IP addresses in this case belongs to
Manuk Grigoryan's apartment -- or excuse me, to the
Canoga apartment; correct?
A
Yes. That would be the Viktoria Kauichko
subscriber information.
THE COURT: Would you keep your voice up a little
bit?
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THE WITNESS: Yes, your Honor.
THE COURT: You speak very softly for some reason.
THE WITNESS: I apologize.
Q BY MR. SILVERMAN: If we can go to GX73.B, please.
And actually before we bring this up, I want to ask one
or three questions quickly, just changing the subject
suddenly, and I apologize for that. Your also reviewed
bank accounts in connection with this investigation; is
that right?
A
Voluminous bank accounts.
Q
And on direct examination you testified to a bank
account of Ulia Zhadco; right?
A
Yes, I believe that is Timeline Transport.
Q
And there were requests submitted in the name of
Ulia Zhadco; correct?
A
Clarify requests.
Q
There was a travel alert placed in the name of Ulia
Zhadco; right?
A
Yes.
Q
And would you agree that you also reviewed a
JPMorgan Chase account in the name of Ulia Zhadco?
A
Most likely.
Q
And sitting here today, can you recall any travel
alert being placed on any JPMorgan Chase account in the
name of Ulia Zhadco?
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A
In the documents produced, no.
Q
And you likely reviewed a JPMorgan chase account in
the name of Turing Info Solutions; is that right?
A
Yes.
Q
And do you recall any travel alert being placed on
the account in the name of Turing Info Solutions?
A
No, I do not.
Q
Now, if we can bring up GX373.B. Going back to IP
addresses and go to page 2, please, and if you can blow
up the target details at the very top.
And the IP address, suffice it to say, it ends
in .188; correct?
A
Yes.
Q
And down at the bottom it says current lease start,
December 11, 2019; right?
A
That is what that indicates. Yes.
Q
And that would be before the CARES Act was passed
or PPP loans began; correct?
A
Yes.
Q
Now keeping in mind this .188 IP address, can we
please bring up for the witness only defense Exhibit 19?
Agent Clark, can you please identify what this
document is?
A
I don't know what it is.
Q
Can you identify who it was produced by?
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A
It would be produced by JPMorgan chase.
Q
And following that, is there a DOJ prod number in
the bottom right-hand corner?
A
Yes.
Q
And are you familiar that that means it was
produced by the government in this case?
A
Yes.
MR. SILVERMAN: Move to admit it, your Honor.
THE COURT: Received.
(Exhibit 19 received in evidence.)
MR. SILVERMAN: If we can go to page 19, please.
Or actually stay on page 1 for a moment. I apologize,
Ms. Romero. And can we publish, please. Permission to
publish.
THE COURT: Yes.
Q
Which three customer names does this document
regard?
A
As indicated the document, it indicates customer
name, Edvard Paronyan on the top. In the middle, it
indicates Ulia Zhadco. And on the bottom, it indicates
Manuk Grigoryan.
Q
And if we can go to page 19, please. And if we can
zoom in slightly.
And about two-thirds of the way down the
screen, you are going to see 104.34.75.188. Can you
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highlight that, please. On April 7th.
Now, Agent Clark, does that show that on
April 7th the .188 IP address was used to log into Manuk
Grigoryan's account?
A
I have no idea what this document is.
Q
Next to the .188 number, what user number does it
say?
MR. FENTON: Objection, your Honor. The witness
just said he doesn't know what this document is.
THE COURT: Sustained.
Q BY MR. SILVERMAN: Agent Clark, you have reviewed
bank records in this case; right?
A
Yes.
Q
I believe you said voluminous bank records?
A
Yes.
Q
If there was an important bank record, you were
going to review it; correct?
MR. FENTON: Objection, your Honor.
THE COURT: Overruled at this point. Go ahead.
THE WITNESS: Define important. When I looked at
the bank records, I am looking at financial transactions.
Q BY MR. SILVERMAN: And so you were looking at
financial transactions specifically in connection with
Ulia Zhadco; right?
A
And others.
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Q
And this document contains a number of entries with
respect to -- well, actually let's go back to page 10,
please. And if we can zoom in on the information.
Suffice it to say this document contains a
large number of transactions involving Ulia Zhadco;
correct?
MR. FENTON: Objection, your Honor. He is asking
him to testify about the same document he just said he
does not understand.
THE COURT: Overruled.
THE WITNESS: I don't know if the document -- I
never looked at these types of documents.
THE COURT: One minute here. Just -- question and
answer. Question and answer. I mean, the question was
is Zhadko or whoever mentioned frequently in this
document. That was the question, wasn't it?
MR. SILVERMAN: Correct, your Honor.
THE COURT: All right. So he can answer "yes" or
"no" regardless of what else he knows about it.
Q BY MR. SILVERMAN: Agent --
THE COURT: Let him answer.
MR. SILVERMAN: Yes.
THE WITNESS: In reading the document, it says
Ulia Zhadco 11.
Q BY MR. SILVERMAN: And specifically it says that
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Case 2:20-cr-00579-SVW Document 675 Filed 07/09/21 Page 48 of 132 Page ID
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under user; correct?
A
Yes.
Q
And under IP, it says 104.34.75.188?
A
Again, in reading the document --
THE COURT: Is this document in evidence?
MR. SILVERMAN: Yes, your Honor.
THE COURT: All right. Then you can ask him these
questions.
Q BY MR. SILVERMAN: So, Agent Clark, is it your
testimony that you have not reviewed this document in the
past?
A
That's correct.
Q
And you decided that it wasn't important to look
into what IP addresses access Ulia Zhadco's account?
MR. FENTON: Objection, your Honor.
Argumentative.
THE COURT: Overruled.
THE WITNESS: The question again, please.
Q BY MR. SILVERMAN: You decided that it wasn't
important to look into which IP addresses accessed Ulia
Zhadco's account?
A
The task of looking into IP addresses was not what
my role is in this investigation. I am a financial
investigator. I trace the money to where it goes.
Q
Agent Clark, on direct examination you testified
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that you reviewed IP addresses; right?
A
I reviewed the subscriber.
Q
And you reviewed financial transactions?
A
Yes.
Q
And you decided that it was not important to review
the IP addresses connected with those financial
transactions?
MR. FENTON: Objection, your Honor. Asked and
answered. Argumentative.
THE COURT: All right. He has answered. He said
whatever value it has that he wasn't assigned to do what
you are asking him about. So he has answered the
question.
MR. SILVERMAN: Yes, your Honor.
THE COURT: Let's move to something else.
Q BY MR. SILVERMAN: Now, if we can move to page 19 of
this document, just to close the loop. And on April
April 7th, the item that we started to discuss before
that is the same 104.34.75.188 that was used to access
Ulia Zhadco's account; correct?
A
From the subscriber information. Yes.
Q
And if we can go to the next page, and go to May 6
and May 7.
And, again, that is the same 104.34.75.188
that was used to access Ulia Zhadco's account?
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A
You know, I don't know if that was used for the
account. I didn't review these documents.
Q
It was the same number that showed up on the page
that said Ulia Zhadco; correct?
A
I mean, I don't know, does this correspond to the
Ulia Zhadco account or is this a culmination of all
the -- I don't know what this document is.
Q
Agent Clark, I am going to try and clarify what I
am trying to ask you.
THE COURT: Well, get to it, because so far it is
not entirely clear. He is not familiar with this
document. To the extent you want him to read literally
from the document, you can, but, if he doesn't know what
this document is, he can't answer other questions.
MR. SILVERMAN: Yes.
Q
BY MR. SILVERMAN: The number in column B here is
the same number that was listed next to Ulia Zhadco 11 on
page 12; right?
A
Yes.
MR. SILVERMAN: Now, if we can bring up defense
Exhibit 20 only for the witness please?
THE COURT: Is it in evidence?
MR. SILVERMAN: It is not.
THE COURT: Is that an exhibit or is that the
exhibit on the screen?
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52
MR. SILVERMAN: No, your Honor. She is pulling up
that exhibit.
Q
BY MR. SILVERMAN: Agent Clark, can you see the
spreadsheets on your screen?
A
Yes.
Q
And can you read the names in the bottom left-hand
tab -- or, I'm sorry. Are you familiar with the names in
the bottom left-hand tab?
THE COURT: He can't read from something that is
not in evidence.
MR. SILVERMAN: Yes, your Honor.
Q
BY MR. SILVERMAN: Can you identify the names in
the bottom left-hand tab?
MR. SILVERMAN: We will move to offer it, your
Honor.
THE COURT: Well, I don't know what it is. What
does it purport to be? We are looking at a chart with
names and columns. What does it purport to be?
MR. SILVERMAN: We will circle back to this. It
is not clear from the face of it and I have to talk to
counsel.
THE COURT: I mean, you can't ask him about
something that was not in evidence. Maybe it will be,
but it is not now.
MR. SILVERMAN: Correct, your Honor.
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Actually, I will offer it into evidence, your
Honor?
MR. FENTON: No objection from the government.
THE COURT: Wait a second. We have to hear other
people. Are there other objections?
MR. JOHNSON: I'm sorry, your Honor. It is just
that the interpreter cannot hear you.
THE COURT: You can't hear me?
THE INTERPRETER: Yes, your Honor.
THE COURT: I apologize. Sometimes I
unfortunately do what I tell other people not to do.
THE INTERPRETER: I appreciate it, your Honor.
THE COURT: All right. So the bottom of this is
that it is in evidence. Now you can ask him about its
contents.
Q BY MR. SILVERMAN: Agent Clark, does this appear to
be a record of a user name Ulia Zhadco?
A
It appears to be it. I don't think I have ever
seen this spreadsheet before.
Q
So I will represent to you this is a production
from Bank of America. Have you reviewed the productions
from Bank of America?
A
Voluminous.
Q
And have you reviewed this spreadsheet?
A
No.
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Case 2:20-cr-00579-SVW Document 675 Filed 07/09/21 Page 53 of 132 Page ID
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Q
And then in that case I am just going to ask you to
if you take a look at row 503 and column F there. Is the
IP address listed there the same as the IP address that
was listed next to Manuk Grigoryan's name on the last
exhibit?
Oh. Permission to publish, your Honor?
THE COURT: Yes.
THE WITNESS: In reading the spreadsheet, it is
the same number.
Q
BY MR. SILVERMAN: And if we can go, please, to the
top, TQ Contracting tab on the bottom right. And TQ
Contracting, do you know if that was a term used to refer
to Top Quality Contracting?
A
Yes, it was.
Q
And if we can expand column F, please.
In column F do you see the same 188 IP address
that was used to access Manuk Grigoryan's account in
DX19? [][]
A
Yes.
Q
In addition to using this IP address to access bank
accounts, it was also used to submit PPP applications;
correct?
A
Yes.
Q
And if we can bring out government Exhibit 3.E,
please. And if we can please go to page 11.
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Case 2:20-cr-00579-SVW Document 675 Filed 07/09/21 Page 54 of 132 Page ID
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55
And if you can zoom in -- or, I'm sorry, if
you can zoom in to the signature of authorized
representative of applicant.
And what name is there?
A
The name that is printed is Viktoria Kauichko.
Q
And what is the date of this submission?
A
On the document it indicates April 14th, 2020.
Q
And underneath Viktoria Kauichko's name, it has the
.188 IP address; correct?
A
Yes. As the document reads, yes.
Q
And if we can flip backwards one page.
This is an application for Fiber One Media
correct?
A
As the document reads, yes, Fiber One.
Q
If we could go to GX3.I.
Is the company name here Hart Construction?
A
Yes.
Q
And we have heard testimony in this case about Hart
Construction and a number of other construction
companies?
A
Yes.
Q
If you can go to page 73, please. And if you can
blow up the center next to signature.
This was signed -- or purportedly signed by
Michael Hart; correct?
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A
The electronic signature indicates Michael Hart.
Q
And it was using IP address 104.34.75.188; right?
A
Yes, in the middle of the bottom there.
Q
And that is the IP address registered to the Canoga
Avenue apartment; right?
A
The subscriber information yes.
Q
If we could go to GX3.M, please.
You testified on direct examination regarding
a PPP loan or EIDL loan application in the name of Mod
Interiors; right?
A
One of the applications in the name of Mod
Interiors.
Q
Is this another application in the name of Mod
Interiors?
A
Yes. There are several.
Q
And specifically this one preceded that
application; right?
A
I would have to look at the dates.
Q
That application was in July?
A
Yes.
Q
Now, if we can go to page 30 of this application,
and if we can blow up the signer events, including the
time stamp there.
So two months before that application, another
one was submitted in the name of Mod Interiors; correct?
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A
Yes. Based off the time date stamp there.
Q
And the IP address was the Canoga Avenue apartment;
right?
A
Yes.
Q
Now, this is the last loan application. If we can
go to 2.4, please -- 2.8, excuse me.
Is this a loan application in the name of G&A
Diamonds?
A
Yes, it is.
Q
And is the applicant listed as Artashes Grigoryan?
A
Yes, it is.
Q
And do you know that to be Manuk Grigoryan's
father?
A
Yes.
Q
Now, if we can go to page 39, please.
At the bottom of the screen, you see the
Canoga Avenue IP address again; right?
A
In the bottom two right cells.
Q
And that is on May 2nd, 2020?
A
Yes.
Q
Now, up above it you see another IP address; right?
A
Can you point it out?
Q
(Indicating.)
A
Yes.
Q
Are you familiar with that IP address?
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A
If it is on the subscriber info, I reviewed it.
Q
Let's bring up government Exhibit 73.I, which has
that subscriber info. And if we can go to page 2.
That second address belongs to Manuk Grigoryan
as well; right?
A
As indicated on this subscriber record. Yes.
Q
And specifically it is his Dora Street house;
right?
A
Yes, his residence.
Q
That is his residence where he lives with his
family?
A
As purported. Yes.
Q
Including his wife, global Edit Madatyan;
correct?
A
I don't know if she lives there.
Q
The user name is EditMadatyan@yahoo.com?
A
Yes. As that document states, it's the email
address.
Q
Correct. And just to be precise, Edit Madatyan is
his wife, though, whether or not she lives there?
A
To my knowledge. Yes.
Q
Now, I am going to ask you some questions about
this IP address now rather than the Canoga Avenue one.
And I will refer to this as the Dora Street address.
Okay?
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59
Now, if we can pull up Defense Exhibit 24 just
for the witness.
Have you seen this before?
A
I don't recall.
MR. SILVERMAN: Your Honor, I will offer this into
evidence.
THE COURT: Any objection?
MR. FENTON: No objection.
THE COURT: Received.
MR. SILVERMAN: And can we publish, your Honor?
THE COURT: Yes.
(Exhibit 24 received in evidence.)
Q BY MR. SILVERMAN: What does this appear to be?
A
Production pursuant to -- from Google regarding
subscriber information.
Q
And is it subscriber information for somebody in
the name of Viktoria Kauichko?
A
That is what the document appears to read.
Q
And specifically for the e-mail address
VKauichko.89@gmail.com?
A
Yes.
Q
And have you seen that e-mail address before?
A
Yes.
Q
It is used on Viktoria Kauichko documents; correct?
A
A lot of them.
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Q
Now, if we go to page 2, please. And please blow
up April 16th through 20th.
And that is the Dora Street IP address;
correct, on -- I will call it line 3.
A
Correct.
Q
And on the second to the last row?
A
Yes.
Q
Both of those are the Dora Street IP address?
A
For the subscriber information. Yes.
Q
And that address was also used to log in to other
accounts; right?
A
I am not aware of that. I didn't conduct like some
analysis of all the IP addresses.
Q
And you didn't conduct analysis of which ones were
used to log in to which bank accounts?
A
No.
Q
Or which --
A
That wasn't my task in this investigation.
Q
Did you conduct any analysis of which ones were
used to log in to which brokerage accounts?
A
No, I did not.
Q
So if somebody was logging in to Ulio Zhadko's
account, you wouldn't know where they were logging in
from; correct?
MR. FENTON: Objection, your Honor. Asked and
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answered several times.
THE COURT: You made the point. Move on.
Q BY MR. SILVERMAN: Now, we have heard testimony
about Anna Manukyan; correct?
A
Yes.
Q
And loans applied for in her name?
A
Yes. And a house purchase.
Q
And a house purchase. She is Manuk's aunt;
correct?
A
That is my belief. Yes.
MR. SILVERMAN: If we can bring up Defense Exhibit
73 just for the witness.
Q BY MR. SILVERMAN: I want to direct your attention
to Medet Murat. Are you familiar with that name?
A
With the name.
Q
And Medet Murat was used to apply for a number of
loans in this case; correct?
A
As I recall.
Q
And if we bring up DX40, which is in evidence. Go
to page 2, please.
And in the middle there, do you see the Dora
Street IP address?
A
Correct.
Q
And if we go up to the top. If you can go to the
top of the page -- I'm sorry, the top of the document.
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Case 2:20-cr-00579-SVW Document 675 Filed 07/09/21 Page 61 of 132 Page ID
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This is the subscriber information for Medet
Murat; correct?
A
Yes, as it reads on the document.
Q
And MedetMurat1994@gmail.com?
A
Yes. That is what it says.
Q
I want to ask you a few questions about the
relevance of Medet Murat. We heard testimony from a
Gusto witness this week that she searched all the
identities and entities given to her by the government;
correct?
A
Yes.
Q
And we heard testimony that there was only one hit;
correct?
A
That is my recollection.
Q
And specifically it was VLA Construction and Medet
Murat; right?
A
Yes.
Q
If we could bring up GX52, please.
And I would move to admit GX52. I don't
believe it's in evidence.
THE COURT: Any objection?
MR. FENTON: No objection.
THE COURT: Received.
(Exhibit GX52 received in evidence.)
Q BY MR. SILVERMAN: If we can go to page 5, please.
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Case 2:20-cr-00579-SVW Document 675 Filed 07/09/21 Page 62 of 132 Page ID
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If we can scroll up slightly here.
Does this say "User Details"?
A
Yes.
Q
And under e-mail address it says
MedetMurat1994@gmail.com?
A
Yes.
Q
That is the one we just looked at right?
A
Yes.
Q
And can you tell from this document what it is?
A
Rephrase your question.
Q
Can you tell from the document who -- which company
is the custodian of it?
A
I think Gusto.
Q
Correct?
A
Yes.
Q
Now, in addition to Medet Murat, we mentioned VLA
Construction; right?
A
Yes.
Q
And if we could bring up GX54.B, already in
evidence. This is a list of companies that was found in
the Canoga Street apartment; right?
A
Yes, it is.
Q
And do you see VLA on this?
A
Yes. It is on the second line.
Q
And you did not attend the Canoga Street search
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Case 2:20-cr-00579-SVW Document 675 Filed 07/09/21 Page 63 of 132 Page ID
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warrant execution; right?
A
No, I did not.
Q
Are you familiar with items that were seized at
Canoga?
A
I reviewed photographs of the items seized.
Q
If we can bring up just for the witness DX48. And
if we can scroll through pages 1, 2 and 3.
Are these three documents that were seized in
the Canoga Street seizures?
THE COURT: The Canoga Street seizures?
Q
BY MR. SILVERMAN: Are these three documents that
were seized in the search warrant at Canoga Street?
A
I don't know if they were seized, but photographs
were taken of them.
Q
At Canoga Street?
A
Yes. That is Manuk's wife.
MR. SILVERMAN: I would offer it.
THE COURT: Any objection?
MR. FENTON: No objection.
THE COURT: Received.
(Exhibit 48 received in evidence.)
Q BY MR. SILVERMAN: Can we go to page 1, please
THE COURT: I think we are going to have to take a
brief morning recess now for 10 minutes and then we will
complete this exam.
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(The following proceedings were held outside the
presence of the jury:)
(Recess from 10:37 a.m. to 10:53 a.m.)
(The following proceedings were held in the
presence of the jury:)
THE COURT: Ready to proceed?
MR. SILVERMAN: Yes, your Honor.
May I proceed, your Honor?
THE COURT: Yes.
Q BY MR. SILVERMAN: If we can pull back up government
Exhibit 73.I and go to page 2. So just to reorient
ourselves, we were talking about this IP address that
belongs to Manuk Grigoryan; right?
A
Okay.
Q
And it specifically belongs to his Dora Street
house; correct?
A
That is what the subscriber record indicates.
Q
And it matched up with an IP address used to access
Medet Murat's; correct?
A
What document are you referring to?
Q
If we can go to DX40, please. And go to the next
page.
A
Yes.
Q
And so that is a yes to the IP address from the
Dora Street matching here to Medet Murat's account;
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Case 2:20-cr-00579-SVW Document 675 Filed 07/09/21 Page 65 of 132 Page ID
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correct?
A
Yes. On this document.
Q
And Medet Murat and VLA Construction were the
applicants for the Gusto account; correct?
A
I don't recall the testimony from the Gusto
representative, but I know the name is associated to the
VLA account.
THE COURT: I can't hear you.
THE WITNESS: I apologize.
THE COURT: Why can't you speak more audibly?
Please make a better record.
THE WITNESS: Yes.
Q BY MR. SILVERMAN: And specifically, it is
associated with Medet Murat and the VLA account; correct?
A
Yes.
Q
Now, what I was showing you before we took a short
break was defense Exhibit 48.
And I believe I had offered it into evidence;
is that correct?
THE CLERK: Yes.
MR. SILVERMAN: Thank you.
Q
BY MR. SILVERMAN: Now, this is an envelope that
was found in the Canoga Avenue apartment; correct?
A
Yes.
Q
And if we zoom in on the bottom left-hand corner,
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can you make out that writing?
A
I mean, I can make it out because I know it.
Q
And specifically the middle name is Medet; right?
A
That is what it reads. Yes.
Q
If we can zoom back out and go into the middle
here. And again, there is a reference to Medet and
Whitsett; is that right?
A
Yes.
Q
And is Whitsett a street that Medet Murat allegedly
lived on?
A
His name was associated to an address on Whitsett.
Q
All right. We can zoom back out, please. And if
we can zoom in on the list on the right-hand side,
please.
Again, this is found in the Canoga Avenue
apartment; correct?
A
Yes.
Q
And the list includes Anton Kudiomov and an arrow
and Canoga; right?
A
I'm sorry, I didn't hear you clearly.
Q
The list includes Anton Kudiomov and then an arrow,
Canoga; right?
A
Yes.
Q
And when it includes Viktoria Kauichko and then an
arrow, Canoga; right?
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Case 2:20-cr-00579-SVW Document 675 Filed 07/09/21 Page 67 of 132 Page ID
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A
Yes.
Q
If we can go to the next page, please.
And was this also found at the Canoga Avenue
apartment?
A
Yes.
Q
And it is a medical bill; right?
A
Yes. It purports to be.
Q
And can you read the name that it is addressed to?
A
Edit Madatyan.
Q
And that is the person you identified as Manuk's
current or former wife; right?
A
That is my belief. Yes.
Q
And if you go to the next page, please. And can
you identify what this is?
A
The top one is a franchise tax board notice or some
kind of document from them, and the bottom looks like
some kind of bill. I can't make out who it is from on
there right now.
Q
Is the remit to address Health Services Asset
Management?
A
Yes.
Q
And are both of these documents addressed to Edit
Madatyan?
A
Yes.
MR. SILVERMAN: Now, we have been talking about
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69
the Dora Street IP address, and there was one document
that I wasn't able to ask but that I would like to offer
into evidence now as DX64. I provided a copy to counsel
during the break. Or, I'm sorry, 73.
THE COURT: Any objection?
MR. FENTON: No objection.
THE COURT: Received.
MR. SILVERMAN: We can publish to the jury, your
Honor?
THE COURT: Yes.
(Exhibit 73 received in evidence.)
Q BY MR. SILVERMAN: Do you see the business name on
this form?
A
Yes.
Q
What is the business name?
A
Manuk or Manukyan Construction.
Q
Now, I will represent to you that this is a
production from BlueVine. Do you know what BlueVine is?
A
It is in the investigation. I don't think it is a
bank. I think they do applications for banks that they
partner with.
Q
And if you look at this form in the second column
about a halfway down, do you see PPP Celtic first?
A
Under user account type.
Q
And based on your knowledge and investigation, does
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that mean that it is an application to Celtic Bank for a
first draw PPP loan?
A
This is BlueVine, so the application would have
been through BlueVine, and I believe funded by Celtic
Bank.
Q
And it would be a PPP application; right?
A
Yes.
Q
And if you look at the authorized person just to
the low left, that is Anna Manukyan; right?
A
Yes, it is.
Q
And we established before that she is Manuk
Grigoryan's aunt; correct?
A
That is my belief.
Q
If we can blow up the bottom right-hand corner,
please. Or actually the bottom of the screen entirely.
Thank you.
Now, the IP address listed under Params for
May 14th, that's the same for Manuk Grigoryan's Dora
Street address; right?
A
Yes.
Q
Now, you testified about the Topeka search;
correct?
A
Yes.
Q
And in the Topeka search were several routers
recovered?
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A
I believe so.
Q
And did you do any analysis on the IP address of
those routers?
A
That is not my -- that is not in my job
description.
Q
Whose job description would it be?
A
That would be like some computer-type person.
Q
And who on the investigation would have handled
that?
A
I believe all electronic devices were handled by
the bureau, the FBI.
Q
And who would have made the determination about
whether it was worthwhile to investigate the IP address
on a given router?
MR. FENTON: Objection, your Honor.
Argumentative.
THE COURT: I mean, the question is not
argumentative. The objection is overruled on those
grounds.
THE WITNESS: Can I have the question again?
Q BY MR. SILVERMAN: Who would have determined whether
it was worthwhile to investigate what the IP address was
on the routers recovered from Topeka Avenue?
A
I don't know.
Q
Now, you are not aware of any of the routers or
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Case 2:20-cr-00579-SVW Document 675 Filed 07/09/21 Page 71 of 132 Page ID
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72
modems at Topeka Avenue being used to submit any loans in
this case, are you?
THE COURT: Now you are being argumentative.
MR. SILVERMAN: Yes, your Honor.
Q
BY MR. SILVERMAN: Now, you testified about Ulio
Zhadko buying a house at 834 Calle La Primavera in
Glendale.
A
Yes.
Q
And you investigated whether or not -- I'm sorry,
strike that. You investigated the identity of Ulio
Zhadko; correct?
THE COURT: Who?
MR. SILVERMAN: Of Ulio Zhadko.
I can rephrase, your Honor.
THE COURT: Somehow your voice at the end drops
off. I don't know why that is.
MR. SILVERMAN: I will do better.
THE COURT: Try and do a little better.
Q
BY MR. SILVERMAN: You investigated the identity of
Ulio Zhadko; right?
A
Yes. I tried to find him.
Q
And you tried to find who owned that house?
THE COURT: What is "that house"?
MR. SILVERMAN: The house --
THE COURT: Can I tell you something. In most
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trials pronouns are not helpful. It is always better not
to overdo it, but to be specific. I mean, you are
talking about an exhibit, the exhibit number. You are
talking about an address, the address.
This and that and it and who only create
confusion. I am not accusing you of that because a lot
of that has gone on. But it shouldn't.
MR. SILVERMAN: Thank you, Judge. I do appreciate
it.
Q
BY MR. SILVERMAN: You investigated who was living
at the Ulio Zhadko house; correct?
A
Yes. We attempted to find out who was living
there.
Q
And on direct examination you testified regarding
utilities; correct?
A
Correct.
Q
And wouldn't you agree that utilities could be
registered in anybody's name; right?
A
I don't know about anybody, but somebody could
register for the utilities in that name.
THE COURT: Only answer questions if you know. If
you don't know, you can just say I don't know. You are
not here to speculate.
THE WITNESS: I don't know.
MR. SILVERMAN: So you don't know whether --
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THE COURT: He said he doesn't know.
MR. SILVERMAN: Yes, your Honor.
Q
MR. SILVERMAN: Now, as part of your investigation,
the team conducted trash pulls from the house owned by
Ulio Zhadko; correct?
A
At Calle La Primavera, yes.
THE INTERPRETER: Counsel, can you repeat that
question please?
Q BY MR. SILVERMAN: As part of your investigation,
the team conducted trash pulls from the house at Calle La
Primavera?
A
Yes.
Q
And in those trash pulls, the team did not find any
evidence of Richard Ayvazian, did it?
MR. FENTON: Objection, your Honor.
THE COURT: I well, I mean there has to be a
foundation. I mean, did you participate in that search?
THE WITNESS: I did not conduct those trash pulls.
Q
BY MR. SILVERMAN: And was it relevant to your
examination what was discovered in the various searches?
THE WITNESS: Yes.
THE COURT: And was what was produced in the
searches of the homes produced for you in connection with
what your role was?
THE WITNESS: The searches of the homes? Yes.
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THE COURT: And including a home that was just
mentioned, the -- what was it called?
MR. SILVERMAN: Calle La Primavera.
THE COURT: La Primavera Street, was that made
known to you?
THE WITNESS: The search. Yes.
THE COURT: You can follow through.
MR. SILVERMAN: If we can show just the witness
defense Exhibit 3.
Q
BY MR. SILVERMAN: Have you seen this picture
before?
A
I have seen this picture but I did not conduct this
trash pull.
Q
All right. But it did come from the trash pull at
Calle La Primavera?
A
That is my understanding.
MR. SILVERMAN: I would offer Defense Exhibit 3
into evidence.
THE COURT: Received.
(Exhibit 3 received in evidence.)
Q BY MR. SILVERMAN: If we can look at Defense Exhibit
4, and we will circle that in a moment.
And are you familiar with this picture?
A
I don't know. I don't recognize it as I sit here.
MR. SILVERMAN: Your Honor, may I show an image
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just to the witness to try to refresh his recollection?
THE COURT: Yes.
MR. FENTON: Objection, your Honor. He didn't say
that a document could refresh his recollection.
THE COURT: Well, I mean, that is the whole point
of refreshing recollection. I mean, you know what is
going to jog your memory. So it may or may not. But you
can do it or try to do it.
MR. SILVERMAN: Just for the witness.
THE COURT: Go ahead.
MR. SILVERMAN: Just for the witness, can I please
have defense Exhibit 2A.
THE COURT: But don't say anything more about it.
Say you are looking at 2A. Does that refresh your
recollection about whatever question you asked. He can
say "yes" or "no."
Q BY MR. SILVERMAN: If you can read that and look up
when you are done, please.
A
Yes.
Q
Does that refresh your recollection regarding
whether you have seen defense Exhibit 4 before?
A
Yes.
Q
Have you seen Defense Exhibit 4 as part of the
trash pull at Calle La Primavera?
A
Yes.
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MR. SILVERMAN: All right. I would offer Defense
Exhibit 4 as well, your Honor.
THE COURT: Received.
(Exhibit 4 received in evidence.)
MR. SILVERMAN: If we could publish defense
Exhibit 3, please.
Q
BY MR. SILVERMAN: So this is a package that was
found in the trash at Calle La Primavera; right?
A
Yes.
Q
The home owned by or in the name of Ulio Zhadko?
A
Yes.
Q
And can we zoom in on the "to" address? And that
is a package addressed to Hripsik Grigoryan; right?
A
Yes. I believe he was an employee of the school
there.
Q
And that is a relative of Manuk Grigoryan's?
A
I don't know if he is a relative.
Q
And if we can go to Defense Exhibit 4, please. At
the top, we see a prescription in the name of Hripsik
Grigoryan; correct?
A
That is what it says.
Q
And you don't know if that person is a relative.
Did you look into it?
A
I recall looking into regarding the label of the
package, and I looked up the school. I think that is
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about as far as I remember I went with that.
Q
And there is also a receipt in the name of Rita
Grigoryan; right?
A
Yes.
Q
And Rita Grigoryan is a relative of Manuk
Grigoryan's; right?
A
I don't know that one.
Q
Did you look into that one?
A
No, I did not.
MR. SILVERMAN: We can take that down. I am going
to change gears slightly.
Q
BY MR. SILVERMAN: You are familiar with the
indictment in this case; correct?
A
Yes.
Q
And the superseding indictment charges a conspiracy
involving 151 loans; right?
A
Yes. 150.
Q
And as part of the government's investigation, it
looked at far more loans than that, didn't it?
A
Yes.
Q
Approximately 250?
A
I don't know the number.
Q
The government produced discovery on about 250
loans?
A
I don't know the number that was produced.
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Q
And then after the indictment with 151 loans, you
heard Ms. Robinson testify that she was given 53 loans;
right?
A
Yes.
Q
And you saw her charts that had 24 loans; right?
A
Yes.
THE COURT: I mean, you are arguing with this
witness. You can say whatever you think is relevant when
you give closing argument, but the purpose of these
witnesses is not to preview your argument. So don't do
that.
MR. SILVERMAN: Yes, your Honor. I will move on.
Q
BY MR. SILVERMAN: Now, as part of the
investigation, you investigated a woman named Tamara
Dadyan; right?
A
Yes.
Q
And you learned that Ms. Dadyan runs an alleged
mortgage fraud ring; right?
MR. FENTON: Objection, your Honor.
THE COURT: Say that question again.
Q BY MR. SILVERMAN: You learned that Ms. Dadyan runs
an alleged mortgage fraud ring?
THE COURT: Objection. Sustained.
MR. FENTON: Your Honor, we move to strike the
question.
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THE COURT: It is stricken.
MR. SILVERMAN: Can we ask for a sidebar on this
point, your Honor?
THE COURT: No.
Q
BY MR. SILVERMAN: You learned that Ms. Dadyan
works with people named Grigor Totorian; correct?
MR. FENTON: Objection, your Honor. Lack of
foundation.
THE COURT: Do you know?
THE WITNESS: I do not.
THE COURT: The objection is sustained.
Q BY MR. SILVERMAN: Have you heard of the name Arshak
Hartunian?
A
No.
Q
And have you heard of the name of Art Mardarosian?
A
No.
Q
Earlier we talked about Manuk Grigoryan and his
relationship with Armin Hayrapetyan and Parure
Hayrapetyan; correct?
A
Yes.
Q
And he also had a relationship with Edvard
Paronyan; correct?
THE COURT: Who is "he"?
Q
BY MR. SILVERMAN: Manuk Grigoryan also had a
relationship with Edvard Paronyan; correct?
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A
Yes.
Q
And did you learn in your investigation how Manuk
Grigoryan paid the people he worked with?
A
Can you refer to a specific individual?
Q
Did you learn in your investigation that Manuk
Grigoryan paid Parure Hayrapetyan a set amount of check
that was deposited?
MR. FENTON: Objection, your Honor. Lack of
foundation. Calls for speculation. Relevance.
THE COURT: You say did you learn. I mean, you
are asking him questions about the investigation
generally, and he has said that he had a particular role
in looking at financial transactions.
If you want to get into the thoroughness of
what he said in that regard or whether he is being
truthful when he says that was his role, you can do that,
but you can't ask the type of question you have been
asking.
MR. SILVERMAN: May I inquire as to the witness'
interviews?
THE COURT: If he interviewed anybody, you can ask
him.
Q BY MR. SILVERMAN: You interviewed Armin
Hayrapetyan; correct?
A
I believe that was part of the proffer section.
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Q
And you learned that Manuk Grigoryan paid Parure
Hayrapetyan a flat fee?
MR. FENTON: Objection, your Honor.
THE COURT: Sustained.
Q BY MR. SILVERMAN: If we can bring up defense
Exhibit 63 only for the witness.
Mr. Clark, can you tell what this is?
A
It looks like a cover letter from JPMorgan Chase.
Q
And if we go the second page, please.
MR. SILVERMAN: I would move it into evidence,
your Honor.
THE COURT: Any objection?
MR. FENTON: No objection.
THE COURT: Received.
(Exhibit 63 received in evidence.)
Q BY MR. SILVERMAN: Now, if we can go to page 3,
please. Or, I'm sorry, page 12, please.
MR. SILVERMAN: And permission to publish, your
Honor.
THE COURT: Yes.
Q BY MR. SILVERMAN: Is this another JPMorgan Chase
account in the name of Ulio Zhadko?
A
Yes. This appears to be the opening statement for
this account.
Q
And it opened on March -- on or around March 11th;
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correct?
A
Correct.
Q
Before the PPP loan program began?
THE COURT: What year?
Q BY MR. SILVERMAN: If you look in the top right
corner, you see March 12th, 2020; correct?
A
Yes. That's correct.
Q
And so this account was opened before the PPP loan
began; correct?
A
Right before.
Q
Specifically, it didn't begin until the end of
March; right?
The additional deposit was on March 11th. The
PPP loan program did not begin until the end of March;
correct?
A
Around there. Yes.
Q
Now, if we can go to page 19, please. Now, is this
a check made out to cash from Armin Hayrapetyan?
A
Yes.
Q
And you have learned as part of your investigation
that Armin Hayrapetyan wrote checks to Manuk Grigoryan;
correct?
MR. FENTON: Objection, your Honor. Lacks
foundation.
THE COURT: I don't know. Can you tell what your
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specific instruction was in this investigation? In other
words, what exactly were you responsible to do? Maybe
more than one thing, but tell us.
THE WITNESS: I had the task of reviewing the bank
accounts specific to the bank statements, following
money, identifying transactions which may be of interest,
looking at the escrow documents, reviewing --
THE COURT: I am not -- maybe the jury is
understanding you, but I am not. Can you make it a
little clearer? In other words, what were you told to
do? Were you given things to trace or were you asked to
investigate things on your own?
THE WITNESS: In a general sense, follow the
money.
THE COURT: But how were you instructed in that
regard? I mean, what was the beginning of the money that
you were following? Were you told to look at certain
bank accounts or were you asked to use your judgment in
following money?
THE WITNESS: The latter is correct. Use my
judgment in following the money.
THE COURT: So when you used your judgment, how
did you decide which money to follow?
THE WITNESS: Deciding on which money to follow
would be based on the amount of money.
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THE COURT: Well, I mean, amount from where?
Where was the starting point here? Where did you begin
your analysis from?
THE WITNESS: From the deposit of the PPP funds or
the EIDL funds.
THE COURT: And were you told to look at certain
accounts to which allegedly PPP funds were deposited?
THE WITNESS: Yes.
THE COURT: And the government told you to do
that?
THE WITNESS: That was the general understanding.
I would look at when the deposit came in, and then I
would follow the money from account to account to
account.
THE COURT: And was that with all the PPP loans?
In other words, we heard some reference -- and I don't
know what the facts are, but we heard some reference to
150 loans.
And then there is another reference to 53
loans. And then another reference to 24 loans. Which of
those numbers were you asked to follow?
In other words, which PPP loans were you asked
to examine from the point that the PPP loan was deposited
to an account?
THE WITNESS: As loans came in, I would evaluate
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each one as they would come in. Not each one, but as
they came in, I would evaluate those.
THE COURT: So am I correct that you were
examining the deposit of these PPP loans, some of them in
real time?
THE WITNESS: Fairly shortly after we got the
documents, yes, your Honor.
THE COURT: So in other words, you know what the
dates of the indictment are; correct?
THE WITNESS: Yes.
THE COURT: And it appears that you were examining
the deposit of PPP loans actually during the period of
the investigation?
THE WITNESS: Correct.
THE COURT: And so it was an ongoing process? In
other words, as PPP loans were deposited to accounts, you
began to your tracing or following the funds?
THE WITNESS: Yes.
THE COURT: And do you know how many loan
deposits, PPP loan deposits you performed that analysis
with?
THE WITNESS: Rough number, 80 plus.
THE COURT: And when you say following the money,
can you tell exactly what you did in understandable
terms? In other words, I am understanding that the PPP
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funds go to an account. Did you then go to the bank
records for that account?
THE WITNESS: Yes.
THE COURT: And what did do you thereafter?
THE WITNESS: I followed where the money flowed
out of the account to the destinations, and then once the
destination was determined, I could follow the money back
to other accounts because following the money isn't
linear. It can be cyclical.
THE COURT: So are you saying that when the money
was followed, you followed it wherever it went?
THE WITNESS: Yes.
THE COURT: Give us an example.
THE WITNESS: I believe like the Timeline
Transport, some of the money that was used to fund the
Encore escrow for the purchase of the Topeka property.
So you could follow to the escrow account, which would
also identify other monies used to purchase that
property. And then --
THE COURT: Wait a minute.
THE PROSPECTIVE JUROR: Okay. And then when you
find the source of those other funds, you can kind of
back into other accounts, and even other PPP loans.
THE COURT: I see. So if I understand what you
are saying, when you follow the money and it went to
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purchase some asset of some kind, if that asset was
purchased with funds in addition to the PPP loans you
would also investigate the other monies that were used to
purchase that asset?
THE WITNESS: Yes.
THE COURT: And is that the extent of what you did
in this case?
THE WITNESS: Yes.
THE COURT: You said you did participate in some
searches.
THE WITNESS: Yes. I participated in the search
warrants.
THE COURT: Which searches did you participate in?
THE WITNESS: The Topeka property.
THE COURT: And did you say your role was like
rover or something.
THE WITNESS: Yes.
THE COURT: And what else did you do in this case?
What else were you asked to do.
THE WITNESS: I was asked to go to the various
locations that were indicated on the PPP loan where the
businesses were supposed to be located at and determine
if they were located there.
THE COURT: What else were you asked to do?
THE WITNESS: Interview various tax preparers or
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accountants.
THE COURT: And who did you interview?
THE WITNESS: David Dura, Frank Amer, Bruce Durkey
(phon.).
THE COURT: All right. And anything else? What
were you interviewing the accountants generally about?
THE WITNESS: About the supporting documents in
the loan applications. And the basic question was did
they prepare them.
THE COURT: Is there any other aspect of the
investigation you were asked to participate in?
THE WITNESS: No. That is generally it. The
following money took up a lot of time.
THE COURT: You were asked about the identifying
information for cell phones and things in that regard;
right?
THE WITNESS: I was asked about that. Yes.
THE COURT: Was that part of your investigation?
THE WITNESS: It was part of the investigation.
That was not an aspect that I --
THE COURT: I was just interested in what you were
asked to do. Were you asked to get into the e-mail
identifications?
THE WITNESS: No.
THE COURT: Was it part of your investigation to
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investigate electronic devices?
THE WITNESS: No.
THE COURT: So I think you can ask him any
question about what he did. If that is what he did, then
you can inquire. That seems the proper scope.
MR. SILVERMAN: Yes, your Honor. If I could ask
one clarifying question, I think I might be able to
remove some ambiguity here.
Q
BY MR. SILVERMAN: Agent Clark, you were one of
three lead agents on this case; right?
A
One of three agents. I wouldn't describe myself as
one of three lead.
Q
And who would you describe as the lead agent?
A
We don't really have a lead agent. Each agent
brings various sets of skills from their agency to the
investigation.
Q
So all three of you would commonly be on
communications about the case; right?
A
Yes.
Q
And these communications would go far beyond just
financial records; right?
A
Yes.
Q
And you would discuss what the right course of
action is?
THE COURT: You know, keep your voice up and
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clear.
MR. SILVERMAN: Yes, your Honor.
THE COURT: I am going to become very directed
about that. I am tired of directing that aspect of
things, not just with you, but with almost everyone else.
And so, don't -- don't swallow words. Keep
your voices up.
MR. SILVERMAN: Yes, your Honor.
THE COURT: And think about that. That goes for
everybody. Including me.
Go ahead.
So you are saying -- let me ask you this.
These other agents, were they involved in investigating
matters beyond what you were tasked to do?
THE WITNESS: I'm sorry. I don't understand the
question.
THE COURT: Well, you just described what your
function was. Were they part of the same function or did
the co-IRS agents have totally different functions?
THE WITNESS: There is only one other IRS agent on
this case with me. He performed basically the same task
that I did.
THE COURT: So did you sort of divide up the
responsibilities as you described them and what you did?
THE WITNESS: With the other IRS agent on the
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case, yes.
THE COURT: And did he do essentially the types of
things you just described?
THE WITNESS: Yes.
Q
BY MR. SILVERMAN: Were you involved in
communications among the other agents outside of the IRS?
A
Yes.
Q
And were those communications common?
A
Yes.
THE COURT: What is the relevance of that? He is
not the lead agent. He had a discrete task. It is
improper at this point to walk him through your case.
MR. SILVERMAN: Understood, your Honor.
THE COURT: And that is what you are trying to do.
And you will have that opportunity, but not at this time.
MR. SILVERMAN: Yes, your Honor.
THE COURT: Let's move this along.
MR. SILVERMAN: All right.
Q
BY MR. SILVERMAN: Agent Clark, you were tasked
with following the money, as you put it; correct?
A
Yes.
Q
And you mentioned that the amount of money mattered
to you; right?
A
Yes.
Q
So maybe a $1,960 check might not be worth
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following?
MR. FENTON: Objection. Misstates his testimony.
THE COURT: I don't know what matters means. What
does matter mean?
MR. SILVERMAN: I can rephrase, your Honor.
Q
BY MR. SILVERMAN: You prioritized larger amounts;
correct?
A
Initially.
Q
And by the end of the investigation, were you
following amounts like $1,960?
A
Yes.
Q
And did you follow why this amount was deposited
from Armin Hayrapetyan to Ulia Zhadko?
A
No.
Q
If we can go to page 23. So just to resituate
everyone, if we can go backward one page so we can see on
whose behalf this is.
This is Exhibit 63 for the record.
So this is still Ulio Zhadko's Chase account;
correct?
A
Yes.
Q
And if we go to page 31. Now, is this a $50,000
check from Armin Hayrapetyan to Ulio Zhadko?
A
It is a cashier's check.
Q
And is the remitter listed as Armin Hayrapetyan?
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A
Yes, it is.
Q
Did you follow this money?
A
I believe so.
Q
What did you learn?
A
If there is something you can refresh my memory.
Q
So you don't recall what the reason for this
transaction was?
A
No. I believe that this check was also a part of
two other checks for I believe in the same amount of
50,000 to -- I believe one was Anna Manukyan. I don't
recall the other one.
Q
And Anna Manukyan, again that is Grigoryan's wife?
A
Yes.
Q
And Armin Hayrapetyan is an associate of
Grigoryan's?
A
Yes.
Q
Now, as part of your investigation, did you become
aware of an LAPD search of Manuk Grigoryan's home?
MR. FENTON: Objection, your Honor. Relevance.
THE COURT: Sustained.
MR. SILVERMAN: Your Honor, this particular
witness has foundational knowledge.
THE COURT: You can ask him another question to
see where it goes, but -- you can ask another question.
Q BY MR. SILVERMAN: From whom did you gather evidence
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as part of this investigation?
MR. FENTON: Objection, your Honor. It is a very
vague question.
THE COURT: From whom did he get what evidence?
Q BY MR. SILVERMAN: Did you receive documents from
the LAPD?
MR. FENTON: Objection, your Honor. Again, it is
a vague question. It is not even tied to this case.
THE COURT: Sustained.
Q
BY MR. SILVERMAN: Did you receive documents --
THE COURT: Sustained.
MR. SILVERMAN: Your Honor, if I could make an
offer of proof here.
THE COURT: Not now. We will take it up at a
recess or the lunch hour.
Q BY MR. SILVERMAN: Now, you mentioned interviewing
accountants; correct?
A
Yes.
Q
And tax preparers?
A
Yes.
Q
And you went through a list of names from memory;
right?
A
No.
Q
You listed off a number of people that you
interviewed?
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A
Yes, I did.
Q
And one of the people you didn't list was a woman
named Asya Vostanikyan; correct?
A
Yes.
Q
And that was somebody you interviewed; right?
A
Yes.
Q
And she is a credit repair specialist and tax
return preparer?
A
I only know her as a tax preparer.
Q
And if we could bring up DX45 just for the witness
and go to the last page. Have you seen this before?
A
No.
MR. SILVERMAN: I would like to offer it into
evidence, your Honor.
THE COURT: Objection?
MR. FENTON: No objection.
THE COURT: Received.
(Exhibit DX45 received in evidence.)
MR. SILVERMAN: And if we could publish to the
jury.
THE COURT: Yes.
Q
BY MR. SILVERMAN: Is this a business card for Asya
Vostanikyan?
A
It appears so.
Q
And does it list credit repair and income tax?
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A
Yes, in the middle.
Q
And you interviewed Ms. Vostanikyan on
January 13th, 2201; right? Sounds about right.
MR. SILVERMAN: And if we can bring up just for
the witness Defense Exhibit 35. And go to page three.
Q
BY MR. SILVERMAN: Now, have you seen this document
before?
A
This looks familiar. Yes.
Q
And can we go to page 4, please.
Have you seen this document before?
A
Looks familiar.
Q
And page 5, please. Have you seen this document
before?
A
Looks familiar, yes.
MR. SILVERMAN: I move to admit pages 3 through 5
of Defense Exhibit 35.
MR. FENTON: No objection.
THE COURT: Received.
(Exhibit 35, pages 3-5 received in evidence.)
THE WITNESS: I believe she indicated she didn't
prepare any of those.
THE COURT: No question pending.
MR. SILVERMAN: Permission to publish to the jury,
your Honor.
THE COURT: Yes.
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MR. SILVERMAN: Can we zoom in on top here?
Q
BY MR. SILVERMAN: This is Defense Exhibit 35, page
5. At the top, does it say "Profit and loss for Top
Quality Contracting"?
A
Yes.
Q
And it is January 1st, 2020 through June 30th,
2020; right?
A
Yes.
Q
And if we can zoom back out. And then there are a
series of numbers right?
A
Yes.
Q
And at the bottom it is signed in the name of Asya
Vostanikyan; correct?
A
It appears so.
Q
And it says "I have reviewed and prepared this
profit and loss statement July 16th, 2020"?
A
Yes.
Q
And you were aware that this was used in
conjunction with the home purchase; right?
THE COURT: With a what?
MR. SILVERMAN: A home purchase.
THE WITNESS: Yes.
Q BY MR. SILVERMAN: Do you know which home it was
used to purchase?
A
Not this one. I would have to read my memo.
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Q
Was it either the Ulio Zhadko home or the Viktoria
Kauichko home?
A
Yes.
MR. SILVERMAN: Now, if we can go back to page 4,
please. And if we can zoom in slightly so he can read
the language.
Q
BY MR. SILVERMAN: And this is another letter
purportedly signed by Asya Vostanikyan; correct?
A
Yes.
Q
And it says that she is certifying that Ulio Zhadko
owns 100 percent of Top Quality Contracting; right?
A
That is what it reads.
Q
And if we can go back to page 3, please.
This is a letter dated July 17th from Asya
Vostanikyan -- excuse me.
A
Yes. It is dated in handwriting.
Q
And this too was used as part of a home purchase;
correct?
A
Yes.
Q
And it says that, "With this letter I certify that
Ulio Zhakdo owns 100 percent of Top Quality"; right?
A
Yes.
MR. SILVERMAN: Now, if we can bring up just for
the witness Defense Exhibit 46, please.
Q
BY MR. SILVERMAN: Agent Clark, have you seen this
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before?
A
I don't recall. If could you refresh my memory
with a memo.
Q
Did you review a document production from Asya
Vostanikyan?
A
Yes.
Q
Was this document in that production?
A
Yes.
MR. SILVERMAN: I would offer it, your Honor.
THE COURT: Received.
MR. FENTON: Your Honor, the government has an
objection. I think the issue is -- and this is a
question --
THE COURT: Just tell me.
MR. FENTON: Lack of --
THE COURT: You haven't been objecting so maybe I
ruled prematurely. Let me take a look at this document.
So what is the objection. What is the legal
ground?
MR. FENTON: The objection is lack of
authentication and lack of foundation as well.
THE COURT: But the question seemed to be this
letter became part of what this witness has said he was
investigating. Is that the question?
MR. SILVERMAN: Your Honor, that is going to be
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the question. Yes.
THE COURT: And so it falls within that category,
at least at the outset.
MR. FENTON: And I understand that, your Honor. I
think the preliminary question now is whether Asya
Vostanikyan said whether she produced these documents,
prepared these documents.
THE COURT: Well, there is no evidence about that
yet.
MR. SILVERMAN: Your Honor, if I may be heard on
that.
THE COURT: Just go to the question that I think
you are going to ask, and let's proceed with the question
and answer.
Q
BY MR. SILVERMAN: Agent Clark, you just testified
that you read this as part of the Vostanikyan production;
correct?
A
I believe so.
MR. SILVERMAN: I would offer it, your Honor.
THE COURT: All right. Received.
(Exhibit 46 received in evidence.)
MR. SILVERMAN: And permission to publish.
THE COURT: Yes.
Q BY MR. SILVERMAN: Now, on page 1 does it say that
she certifies based on tax returns prepared and reviewed
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by me that Viktoria Kauichko owns 100 percent of Fiber
One Media?
MR. FENTON: Your Honor, I object on hearsay
grounds.
THE COURT: Overruled.
THE WITNESS: That is what it says.
Q
BY MR. SILVERMAN: And the author is listed as Asya
Vostanikyan; right?
A
Yes.
Q
And if we can go to page 2, please.
And is this an income and expenses worksheet
for Fiber One Media?
A
I don't recall seeing this document.
Q
And if we can go to page 3.
Is this an assets and liability sheet?
A
Yes. I don't recall seeing this document.
MR. SILVERMAN: Now, if we could pull up defense
Exhibit 38, please, just for the witness.
Or, I'm sorry, if we can hold here for one
second.
Q
BY MR. SILVERMAN: Just to clarify, because as part
of the record it does have a DOJ production stamp in the
bottom right-hand corner; correct?
A
Yes.
MR. SILVERMAN: And if we can go to Defense
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Exhibit 38, please, just for the witness.
Q
BY MR. SILVERMAN: Agent Clark, have you seen this
before?
A
Yes.
MR. SILVERMAN: I would offer it, your Honor.
THE COURT: Any objection?
MR. FENTON: Your Honor, same objection.
THE COURT: You saw it before. In what
connection?
THE WITNESS: I believe this was included in one
of the loan applications.
THE COURT: Was that for -- did you have a
different answer?
THE WITNESS: These types of documents were found
in escrow documents and also we served a subpoena, so it
was part of the subpoena production.
THE COURT: But I mean, were these documents
examined by you in connection with the tasks that you
described you performed?
THE PROSPECTIVE JUROR: Yes.
THE COURT: All right. Received.
MR. SILVERMAN: And may it be admitted into
evidence, your Honor, and published to the jury?
THE COURT: Yes. Yes.
(Exhibit 38 received in evidence.)
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Q
BY MR. SILVERMAN: So in this letter, Asya
Vostanikyan is certifying that Mr. Anton Kudiomov has
been self-employed; right?
A
That is what it states.
Q
And you said it was the type of document that was
included in the home purchase files that you reviewed;
right?
A
That is my recollection; right.
Q
Do you know why this kind of document would be
included?
A
Based on my experience, it would be to support the
application for whether they could afford the house.
Q
I'm sorry, I didn't mean to cut you off.
A
I guess it would be required by a lender. They
would provide some documentation regarding their
affiliation to a business ownership.
Q
So if it would be required by a lender and they
would provide documentation, by "they," you mean the
buyer; right?
A
Generally, yes.
Q
Or if somebody is giving a gift --
A
I don't understand your question.
Q
It would be coming from the buyer's side; right?
A
If it was requested.
Q
And so in this instance it would be on behalf of
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Anton Kudiomov; right?
A
Yes.
Q
Now, you interviewed Ms. Vostanikyan on
January 13th regarding these topics; right?
A
Yes. I believe I spoke with her a couple of times.
Q
And on the 13th you interviewed her for about 45
minutes?
A
Sounds about right.
Q
You were there with another agent?
A
Yes.
Q
And you asked her about these certifications;
right?
A
Yes.
Q
And I believe you began telling me this earlier,
she denied preparing these certifications?
A
That is my recollection. Yes.
Q
She said they were fraudulent.
A
She indicated she did not prepare the documents I
presented her.
MR. SILVERMAN: If we could bring up just for the
witness Defense Exhibit 34.
Q
BY MR. SILVERMAN: And I would ask for you to read
paragraphs three and four to yourself and then look up
when you are done.
A
Yes.
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Q
Agent Clark, does that refresh your recollection
regarding whether she used the word fraudulent?
THE COURT: I didn't hear what you said.
Q BY MR. SILVERMAN: Agent Clark, does that refresh
your recollection regarding whether she used the word
fraudulent?
A
Yes, it does.
Q
And she said that these applications, these letters
were fraudulent; right?
A
In the memo it says she believes the documents are
fraudulent but says she did not prepare them.
MR. FENTON: Objection, your Honor. Hearsay and
the witness is reading from the document.
THE COURT: Well, he shouldn't be. You don't know
what he should be doing.
Let's just get through it.
MR. SILVERMAN: I am going to take down the
document and put back defense Exhibit 37, please, which
is in evidence.
Q
BY MR. SILVERMAN: So after you questioned her
about these letters for, among other people, Anton
Kudiomov; correct?
A
Yes.
Q
And in response she said she didn't know who Anton
Kudiomov was?
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MR. FENTON: Objection, your Honor. Hearsay.
THE COURT: Sustained.
MR. SILVERMAN: Your Honor, it is not offered for
the truth of the matter asserted. Rather the very
opposite.
THE COURT: The objection is sustained.
Q BY MR. SILVERMAN: What did you understand her
connection to be to Anton Kudiomov?
MR. FENTON: Objection, your Honor. Vague.
THE COURT: Sustained.
Q BY MR. SILVERMAN: After this interview with
Ms. Vostanikyan, did you follow up with her?
A
This was the first time that -- I believe I did go
back another time.
Q
And between those two interviews, you did
additional investigation, didn't you?
A
Regarding what?
Q
You did additional investigation regarding Asya
Vostanikyan's relationship with the synthetic identities,
didn't you?
A
I don't recall that.
MR. SILVERMAN: If we could pull up for the
witness alone Defense Exhibit 47.
Q
BY MR. SILVERMAN: You mentioned reviewing the
Vostanikyan production; correct?
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A
Yes.
Q
And did you review this document as part of the
production?
A
Yes.
MR. SILVERMAN: We would move it in, your Honor.
THE COURT: Objection?
MR. FENTON: No objection.
THE COURT: Received.
(Exhibit 47 received in evidence.)
MR. SILVERMAN: And publish to the jury, please.
THE COURT: Yes.
MR. SILVERMAN: If we could go to the next page,
please.
Q
BY MR. SILVERMAN: Now, is this a tax return for
Fiber One Media Incorporated?
A
Yes.
Q
And is it signed by Asya Vostanikyan?
A
It is not signed but it has her name in the
preparer part.
Q
And it was produced by her company; right?
A
Yes.
Q
And she is listed as the president here?
A
Viktoria Kauichko is president.
Q
I apologize. And on page 7, please.
There is a K-1; correct?
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A
Yes.
Q
Also produced by Asya Vostanikyan?
A
Yes. Part of the production.
Q
And it is a K-1 planning income for Victoria
Kauichko; correct?
A
That would be her shareholder's income.
Q
Can you explain what a K-1 is?
A
In general terms, the K-1 is a distribution to one
of the partners or various owners of a corporation.
There is one or more divided up based on ownership
percentage.
Q
And so it might be used by a shareholder to
demonstrate income; right?
A
It could be.
MR. SILVERMAN: And if we can go back to Defense
Exhibit 35, please. And at page 6 just for the witness.
Q
BY MR. SILVERMAN: Agent Clark, do you recognize
this?
A
Yes.
Q
And did you attach this to a memorandum that you
wrote?
A
Yes.
Q
Is it a bank statement that you reviewed?
A
Yes.
MR. SILVERMAN: I would offer it into evidence,
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your Honor.
THE COURT: Received.
(Exhibit 35, page 6 received in evidence.)
MR. SILVERMAN: Permission to publish, your Honor.
THE COURT: Yes.
MR. SILVERMAN: Please publish to the jury,
Ms. Romero.
Q
BY MR. SILVERMAN: Now, is this a bank account
statement that you reviewed before your second interview
Ms. Vostanikyan?
A
Yes.
Q
Up in that top left-hand corner, can we zoom in for
a moment. And it says Anton Kudiomov; right?
A
Yes.
Q
And if we zoom in on July 30th, there is a payment
from Mr. Kudiomov to K&A Consultants; right?
A
Yes.
Q
And that is Asya Vostanikyan's firm; right?
A
Yes.
Q
So you brought it back to her and you asked about
it; right?
A
Yes, I did. I believe I brought that before we
served the subpoena on her.
THE COURT: Let's take the recess. It is now
12:00 o'clock. Come back at 1:00 o'clock.
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Thank you.
(The following proceedings were held outside the
presence of the jury:)
THE COURT: What was your offer of proof on that
question some time ago?
What was the question and what is your offer
of proof?
MR. SILVERMAN: There was a question regarding the
LAPD search of Manuk Grigoryan's home.
THE COURT: Is that in connection with the
mortgage fraud?
MR. SILVERMAN: No, your Honor.
THE COURT: Then what is it in connection with?
MR. SILVERMAN: In connection -- the search was
conducted in connection with an LAPD case unrelated to
this, but Agent Clark received the documents.
THE COURT: Let's take it a step at a time. So
the search that you wanted to ask about was conducted by
the LAPD for an investigation different than the mortgage
fraud?
MR. SILVERMAN: Correct.
THE COURT: And whose home was it again that was
searched?
MR. SILVERMAN: Manuk Grigoryan's.
THE COURT: In that investigation -- maybe we took
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that up before and I just forgot, but were any of the
defendants in this case subject to investigation?
MR. SILVERMAN: Not to our knowledge, your Honor.
And the use case in this instance is very different from
the use case --
THE COURT: What did you just say, use?
MR. SILVERMAN: The use case. The reason we --
THE COURT: What is the use case? Is that the
name of a case?
MR. SILVERMAN: No. I'm sorry. I confused things
by using court terminology.
MR. RAM: Your Honor, this is the matter we spoke
of earlier at sidebar.
THE COURT: I thought it was and I just forgot.
So let's have it again, just a little more clearly than
at sidebar.
So when was this search conducted?
MR. SILVERMAN: December 17th or 18th of 2020.
THE COURT: And the point here is that the
identifying information in this case what was found at
his home when the defendants had already been arrested or
on home confinement?
MR. SILVERMAN: Correct.
THE COURT: And that is part of your theory, that
Grigoryan was Zhadko?
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MR. SILVERMAN: That he was responsible for at
least some of the Zhadko transactions, including ones
that are specifically charged against my client.
THE COURT: I see. All right. Then you can get
into that.
MR. SILVERMAN: Thank you, your Honor.
MR. FENTON: Your Honor, the concern that we have
is this is very confusing to the jury.
THE COURT: It is your job to make it unconfusing.
I mean, there are a lot of documents and a lot of
numbers, and you are going to have to bring this home at
some point to the jury.
My experience is, to the extent I know, that
juries follow their responsibilities closely, and if they
are unsure about things, they are not going to convict.
And so they have to have a firm conviction.
In fact, that is the language of the
instruction. They have to be firmly convinced that the
evidence points at least in part to the government.
I mean, this is part of the theory of the
defendant's case. The cases are pretty clear. All you
have to do is look at this case from the Ninth Circuit,
United States versus Hernandez Mesa. And the Court even
says in that case lawyers don't even have to believe it.
They can sort of think it. And if it is something that
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can help their client, they can do it. And the cases are
uniform.
I mean, there are limits, and Rule 403 is
always in play. But the theory here is that Grigoryan,
Rosodco(Phon.) or Grigoryan made all the PPP loans and
whatever, and this may be a piece of the argument they
can make. It is not for me to weigh evidence. So you
can get into that. All right?
How much longer will you be on this witness?
MR. SILVERMAN: I think less than 20 minutes.
THE COURT: And what about the government. Do you
intend to redirect or direct him?
MR. FENTON: I do, but only briefly. Three to
five minutes.
THE COURT: All right. Who is the next witness
after that?
MR. FENTON: This is our last witness. The only
thing remaining is for the government to read two factual
stipulations into the record for the jury.
MR. SILVERMAN: And, your Honor, as the witness is
still on the stand, we would ask that he not meet with
the government over lunch.
THE COURT: Yes.
MR. MESEREAU: Your Honor, I have a very short
cross.
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THE COURT: Okay.
MR. LITTRELL: And of course, your Honor, I expect
there will be motions following the government resting.
Does the Court want to set aside time to hear those after
the government rests?
THE COURT: Yes. I have been following the
evidence as closely as I can, so I don't want the
arguments to be too extensive, but tell me what they are.
I will hear them and consider them.
MR. LITTRELL: Very well.
THE COURT: And then the defendants are going to
have, what, one more witness?
MR. RAM: I believe three witnesses, your Honor,
but they should all finish this afternoon.
THE COURT: And so the next step is go review the
jury instructions. Well, I want to do that if we have
time, which we probably will this afternoon if we get
finished. I send the jury home and then we can spend the
rest of the working day going over the jury instructions.
MR. MESEREAU: Your Honor, we intend to call one
witness.
THE COURT: You do?
MR. JOHNSON: We may as well, your Honor.
THE COURT: I see. So do you think your witnesses
will be -- I am not committing you to anything, but do
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think they will be lengthy?
MR. MESEREAU: I don't think so, your Honor.
Maybe an hour.
THE COURT: An hour. What about you?
MR. JOHNSON: I would say the same, your Honor,
but it also depends upon the cross.
THE COURT: All right. We will see what happens.
MR. RAM: Your Honor, if I could have 30 seconds
to maybe knock out one of our -- it's actually four
witnesses, but one is the probation officer just to
testify that Mr. Ayvazian did not leave the State of
California at any time during his supervision.
Is that something the Court could take
judicial notice of?
THE COURT: I don't know. I mean there was
something about purchases in Las Vegas at a point in time
when, if I remember correctly, Ayvazian was on home
arrest. I mean, the probation officer wouldn't appear to
me to really know where he was. Did he have an ankle
monitoring bracelet?
MR. RAM: Yes, your Honor. Hone confinement and
ankle monitoring.
THE COURT: So if he had an ankle monitoring
bracelet, he would be in a position to know whether the
move triggered the ankle. I would think you want to
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agree to that, but maybe there is some reason you don't.
MR. FENTON: If we can have a conversation with
the probation officer over lunch.
THE COURT: Okay. Do that. What is the next
thing?
MR. RAM: Because the probation officer is driving
two hours from right now from Ventura County.
THE COURT: Call her on her cell phone or
something. Maybe you can have her make a U-turn
somewhere.
MR. FENTON: We will reach out to her.
THE COURT: Anything else that could be expedited?
MR. LITTRELL: I don't think so, your Honor
(Proceedings concluded.)
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CERTIFICATE
I 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.
Date: June 22, 2021
/s/ Katie Thibodeaux, CSR No. 9858, RPR, CRR
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Case 2:20-cr-00579-SVW Document 675 Filed 07/09/21 Page 118 of 132 Page ID
#:10545
MR. FENTON: [68]
MR. JOHNSON: [3] 53/5
115/22 116/4
MR. LITTRELL: [10] 9/17
12/8 12/15 12/22 13/2 13/11
15/22 115/1 115/9 117/12
MR. MESEREAU: [3] 114/23
115/19 116/1
MR. RAM: [16] 5/25 6/2 6/5
6/9 6/14 6/17 6/21 6/23 6/25
7/3 7/8 112/11 115/12 116/7
116/20 117/5
MR. SILVERMAN: [112]
MS. AHN: [1] 7/13
THE CLERK: [2] 7/23 66/19
THE COURT: [252]
THE INTERPRETER: [3] 53/8
53/11 74/6
THE PROSPECTIVE JUROR: [3]
38/22 87/20 103/19
THE WITNESS: [65]
$
$1,960 [2] 92/25 93/10
$50,000 [1] 93/22
-
-and [2] 2/5 2/8
.
.188 [5] 45/12 45/20 47/3
47/6 55/9
/
/s [1] 118/12
1
10 [2] 48/2 64/24
100 [1] 4/15
100 percent [3] 99/11 99/21
102/1
10036 [1] 2/18
101 [1] 4/15
10100 [1] 3/15
102 [1] 4/15
103 [1] 4/15
104.34.75.188 [5] 46/25 49/3
50/19 50/24 56/2
10537 [2] 11/16 33/10
108 [1] 4/16
109 [3] 4/16 4/16 4/17
10:37 [1] 65/3
10:53 [1] 65/3
10th [1] 14/16
11 [5] 23/23 45/15 48/24
51/17 54/25
110 [1] 4/17
1114 [1] 2/17
11th [2] 82/25 83/13
12 [4] 11/19 36/9 51/18
82/17
12:00 [1] 110/25
12th [1] 83/6
1330 [1] 2/23
13th [3] 97/3 105/4 105/6
14 [1] 37/19
1400 [1] 2/10
14th [3] 35/17 55/7 70/18
150 [2] 78/17 85/18
151 [2] 78/16 79/1
16 [1] 17/17
16th [2] 60/2 98/16
17 [1] 7/13
17450 [1] 11/23
17th [2] 99/14 112/18
18 [2] 15/5 16/7
188 [1] 54/16
18th [2] 31/9 112/18
19 [7] 4/10 45/21 46/10
46/11 46/22 50/16 83/17
1900 [1] 2/15
1935 [1] 3/12
1:00 o'clock [1] 110/25
1N [1] 13/21
1st [2] 1/22 98/6
2
2.4 [1] 57/6
2.8 [1] 57/6
20 [2] 51/21 114/10
20-579 [1] 1/8
2001 [1] 23/3
20036 [1] 2/23
2019 [3] 22/10 33/22 45/15
2020 [23] 8/15 9/3 13/2
13/11 14/17 23/6 27/13 30/10
31/9 31/12 34/2 35/18 36/20
37/3 41/5 41/8 55/7 57/19
83/6 98/6 98/7 98/16 112/18
2021 [3] 1/17 5/1 118/10
20530 [1] 2/10
20th [2] 14/16 60/2
21 [2] 37/22 38/1
216 [1] 3/13
22 [7] 1/17 4/8 4/8 5/1 8/10
38/1 118/10
2201 [1] 97/3
22330 [1] 18/1
22nd [1] 37/22
23 [1] 93/15
23rd [5] 23/3 30/10 31/12
34/11 35/3
24 [8] 4/8 4/8 4/10 35/21
59/1 59/12 79/5 85/20
250 [2] 78/21 78/23
2605 [1] 11/4
27 [1] 4/9
28 [2] 4/9 118/4
2A [2] 76/12 76/14
2nd [1] 57/19
2O [1] 29/25
3
3-5 [2] 4/14 97/19
3.E [1] 54/24
30 [4] 4/9 4/9 56/21 116/8
300 [1] 3/16
303 [1] 18/2
30J [1] 21/13
30th [2] 98/6 110/15
31 [2] 13/23 93/22
312 [1] 2/6
32 [2] 4/5 14/10
337 [1] 11/7
34 [2] 4/16 105/21
35 [8] 4/14 4/17 97/5 97/16
97/19 98/2 109/16 110/3
350 [2] 1/22 3/5
37 [1] 106/18
38 [4] 4/15 102/18 103/1
103/25
39 [1] 57/15
3900 [1] 2/20
4
403 [1] 114/3
409 [1] 3/20
42 [1] 34/6
4311 [1] 1/22
45 [3] 4/10 4/14 105/6
46 [4] 4/10 4/15 99/24
101/21
47 [3] 4/16 107/23 108/9
48 [3] 4/11 64/21 66/17
5
50,000 [1] 94/10
503 [1] 54/2
5141 [1] 16/13
52 [1] 4/11
53 [2] 79/2 85/19
56D [4] 4/9 27/15 28/21
28/24
579 [1] 1/8
59 [2] 4/10 4/10
5th [4] 2/14 3/8 27/13 29/1
6
601 [1] 3/8
6150 [5] 11/6 33/15 33/16
35/19 35/24
62 [2] 4/11 4/11
63 [5] 4/11 4/13 82/6 82/15
93/18
633 [1] 2/14
64 [1] 4/11
651 [1] 3/21
69 [2] 4/12 4/12
6I [1] 17/3
6J [1] 15/4
6L [3] 17/1 17/2 17/2
7
720 [1] 3/8
73 [5] 4/12 55/22 61/12 69/4
69/11
73.I [2] 58/2 65/11
73C [1] 10/20
74 [4] 4/8 22/12 22/21 22/24
75 [6] 4/9 4/12 4/12 30/17
31/1 31/3
753 [1] 118/4
76 [1] 4/13
77 [1] 4/13
7th [3] 47/1 47/3 50/18
8
80 [1] 86/22
803 [1] 23/24
82 [2] 4/13 4/13
834 [1] 72/6
84 [3] 4/8 23/14 24/3
9
90012 [2] 1/23 2/7
90067 [1] 3/16
90071 [2] 2/15 3/9
902 [1] 23/23
90277 [1] 3/21
903 [1] 3/5
91208 [1] 3/13
92673 [1] 3/6
94105 [1] 2/21
96 [2] 4/14 4/14
97 [2] 4/14 4/14
9858 [2] 1/21 118/12
9:00 [2] 5/2 7/13
A
a.m [4] 1/16 5/2 65/3 65/3
able [4] 22/7 42/25 69/2
90/7
about [54] 5/12 20/1 26/9
32/18 33/23 38/20 41/2 43/2
43/8 46/24 48/8 48/19 50/12
52/22 53/14 55/18 58/22 61/4
62/6 65/12 68/25 69/23 70/21
71/12 72/5 73/3 73/4 73/19
76/13 76/15 78/1 78/23 80/17
81/11 89/6 89/7 89/14 89/17
90/4 90/18 91/4 91/9 97/3
101/8 105/6 105/8 105/11
106/21 110/20 111/18 113/15
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about... [3] 114/11 116/4
116/16
above [2] 57/21 118/7
above-entitled [1] 118/7
Absolutely [1] 34/15
access [7] 41/11 49/14 50/19
50/25 54/17 54/20 65/18
accessed [1] 49/20
account [36] 24/12 24/20
24/21 25/4 44/12 44/21 44/24
45/2 45/6 47/4 49/14 49/21
50/20 50/25 51/2 51/6 54/17
60/23 65/25 66/4 66/7 66/14
69/24 82/22 82/24 83/8 85/13
85/13 85/14 85/24 87/1 87/2
87/6 87/17 93/19 110/8
accountants [3] 89/1 89/6
95/17
accounting [1] 26/8
accounts [12] 44/8 44/10
54/21 60/11 60/15 60/20 84/5
84/18 85/7 86/16 87/8 87/23
accurate [2] 16/20 28/13
accusing [1] 73/6
Act [2] 33/24 45/17
action [1] 90/24
activity [4] 34/24 35/2
37/23 39/22
actual [1] 21/8
actually [12] 9/8 9/16 18/23
21/7 34/11 44/5 46/12 48/2
53/1 70/15 86/12 116/9
added [3] 36/5 36/6 36/23
addition [3] 54/20 63/16
88/2
additional [3] 83/13 107/16
107/18
address [61]
addressed [3] 68/8 68/22
77/13
addresses [16] 10/22 11/12
12/7 12/13 12/22 25/11 25/13
43/17 43/19 45/9 49/14 49/20
49/22 50/1 50/6 60/13
admit [7] 22/21 23/22 28/17
31/1 46/8 62/19 97/15
admitted [6] 10/20 13/21
15/4 21/12 29/25 103/22
affiliation [1] 104/16
afford [1] 104/12
after [12] 7/13 29/12 35/15
36/22 37/4 37/7 79/1 86/6
106/20 107/11 114/16 115/4
afternoon [2] 115/14 115/17
again [17] 7/18 12/10 23/15
29/20 35/2 49/4 49/18 50/24
57/17 67/6 67/15 71/20 79/20
94/12 95/7 111/22 112/15
against [1] 113/3
agency [1] 90/15
agent [48] 7/22 8/6 8/9 9/20
12/18 13/5 15/15 17/20 21/15
22/15 23/17 24/4 24/10 24/18
28/25 30/1 30/20 31/6 32/16
32/18 37/3 41/1 43/11 45/22
47/2 47/11 48/20 49/9 49/25
51/8 52/3 53/16 90/9 90/13
90/14 90/14 91/20 91/25
92/11 92/19 99/25 101/15
103/2 105/9 106/1 106/4
109/17 111/16
agents [6] 27/10 90/10 90/11
91/13 91/19 92/6
ago [2] 36/2 111/5
agree [3] 44/20 73/17 117/1
ahead [3] 47/19 76/10 91/11
AHN [1] 2/5
airplane [1] 28/7
al [1] 1/9
alert [6] 14/2 14/3 14/4
44/17 44/24 45/5
alerts [1] 14/6
aliases [2] 9/23 13/16
all [44] 7/9 10/12 11/11
12/25 14/10 14/10 14/22 15/3
15/11 15/21 16/7 17/6 19/7
20/18 22/11 23/13 24/14
25/24 30/4 30/16 48/18 49/7
50/10 51/6 53/13 60/13 62/8
67/12 71/10 75/14 77/1 85/15
89/5 90/17 92/18 101/20
103/21 113/4 113/21 114/5
114/8 114/15 115/14 116/7
alleged [2] 79/17 79/22
allegedly [2] 67/9 85/7
allowed [1] 5/13
almost [2] 40/19 91/5
alone [1] 107/23
along [1] 92/17
Alpha [1] 3/12
already [2] 63/19 112/21
also [15] 11/24 44/7 44/20
54/21 60/10 68/3 78/2 80/21
80/24 87/18 88/3 94/8 103/15
109/2 116/6
always [2] 73/1 114/4
am [27] 5/14 10/18 10/19
13/20 15/3 16/24 17/18 23/13
34/4 42/6 47/21 49/23 51/8
51/9 54/1 58/22 60/12 73/6
78/10 84/8 84/9 86/3 86/25
91/3 91/4 106/17 115/25
Amanecer [1] 3/5
ambiguity [1] 90/8
Amer [1] 89/3
America [4] 1/6 2/3 53/21
53/22
Americas [1] 2/17
among [2] 92/6 106/21
amount [6] 81/6 84/25 85/1
92/22 93/12 94/9
amounts [2] 93/6 93/10
analysis [6] 60/13 60/14
60/19 71/2 85/3 86/20
analyzed [2] 13/15 25/10
ANGELES [10] 1/14 1/23 2/7
2/15 3/9 3/16 5/1 9/9 10/10
12/6
ankle [4] 116/19 116/22
116/23 116/25
Anna [4] 61/4 70/9 94/10
94/12
another [14] 16/24 25/24
26/10 56/13 56/24 57/21
82/21 85/19 85/20 94/23
94/24 99/7 105/9 107/14
answer [11] 27/9 38/24 39/6
48/14 48/14 48/18 48/21
51/14 73/21 101/14 103/13
answered [4] 50/9 50/10
50/12 61/1
answers [1] 15/13
Anton [9] 10/4 67/18 67/21
104/2 105/1 106/21 106/24
107/8 110/13
any [37] 6/19 12/6 12/12
12/22 13/10 16/18 20/22 21/7
24/25 26/20 26/20 31/17 32/2
33/24 38/17 40/21 41/15
42/25 44/23 44/24 45/5 59/7
60/19 62/21 64/18 69/5 71/2
71/25 72/1 74/13 82/12 89/10
90/3 97/21 103/6 112/1
116/12
anybody [3] 40/8 73/19 81/21
anybody's [1] 73/18
anymore [1] 19/6
anyone [1] 40/5
anything [7] 14/23 25/8
39/13 76/13 89/5 115/25
117/12
apartment [17] 11/6 18/2
33/14 33/18 38/6 38/8 39/8
40/10 41/18 43/20 43/21 56/5
57/2 63/21 66/23 67/16 68/4
apologies [1] 24/9
apologize [6] 44/3 44/7
46/12 53/10 66/9 108/24
appear [4] 41/22 53/16 59/13
116/18
APPEARANCES [2] 2/1 3/1
appears [7] 21/21 53/18
59/18 82/23 86/11 96/24
98/14
applicant [4] 16/5 30/6 55/3
57/10
applicants [1] 66/4
application [29] 15/10 15/12
15/19 15/22 16/1 16/12 19/12
26/1 26/4 26/12 31/11 35/6
35/11 35/15 37/4 37/7 55/12
56/9 56/13 56/17 56/19 56/21
56/24 57/5 57/7 70/1 70/3
70/6 104/12
applications [17] 9/11 10/16
10/23 12/8 12/14 12/19 14/25
15/2 20/5 30/2 30/3 54/21
56/11 69/20 89/8 103/11
106/8
applied [2] 29/22 61/6
apply [2] 20/4 61/16
appreciate [2] 53/12 73/8
appreciates [1] 7/19
approach [1] 5/18
appropriate [1] 5/13
approved [2] 35/16 37/8
approximately [7] 8/14 29/11
29/14 31/13 31/15 34/11
78/21
April [11] 22/10 23/3 34/2
34/11 35/3 47/1 47/3 50/17
50/18 55/7 60/2
April 14th [1] 55/7
April 16th [1] 60/2
April 23rd [3] 23/3 34/11
35/3
April 7th [1] 47/3
are [67]
arguing [1] 79/7
argument [4] 5/12 79/9 79/10
114/6
argumentative [5] 49/16 50/9
71/16 71/18 72/3
arguments [1] 115/8
Arman [1] 42/7
Armin [13] 42/10 42/13 42/14
42/17 43/12 80/18 81/23
83/18 83/21 93/13 93/23
93/25 94/14
around [6] 9/8 9/9 12/6 27/9
82/25 83/16
arrest [1] 116/18
arrested [2] 29/12 112/21
arrow [3] 67/18 67/21 67/25
Arshak [1] 80/12
Art [1] 80/15
Artashes [1] 57/10
ARTUR [2] 3/11 11/21
as [83]
Ashwin [1] 2/13
aside [1] 115/4
ask [30] 12/10 15/12 17/10
17/12 22/13 23/15 30/18
39/12 43/8 44/5 49/7 51/9
52/22 53/14 54/1 58/22 62/6
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ask... [13] 69/2 80/2 81/17
81/21 90/3 90/6 91/12 94/23
94/24 101/13 105/22 111/18
114/21
asked [21] 8/17 39/7 41/5
43/1 50/8 60/25 76/15 84/11
84/18 85/21 85/22 88/19
88/20 88/24 89/11 89/14
89/17 89/22 89/22 105/11
110/20
asking [4] 48/7 50/12 81/11
81/18
aspect [3] 89/10 89/20 91/4
asserted [1] 107/4
assessment [1] 27/25
asset [4] 68/19 88/1 88/1
88/4
assets [1] 102/15
assigned [3] 27/5 37/12
50/11
associate [1] 94/14
associated [9] 15/1 19/19
20/7 25/12 25/13 26/10 66/6
66/14 67/11
Asya [13] 96/3 96/22 98/12
99/8 99/14 100/4 101/5 102/7
104/1 107/18 108/17 109/2
110/18
attach [1] 109/20
attempt [2] 22/4 25/19
attempted [2] 23/9 73/12
attend [1] 63/25
attention [9] 13/22 13/23
15/5 15/21 16/3 16/7 17/16
30/4 61/13
attorney [1] 22/1
ATTORNEY'S [1] 2/4
audibly [1] 66/10
August [3] 9/2 13/2 13/11
August 2020 [2] 13/2 13/11
aunt [2] 61/8 70/12
AUSA [2] 2/5 2/5
authenticating [1] 23/23
authentication [1] 100/21
author [1] 102/7
authorized [4] 16/5 30/5
55/2 70/8
available [2] 18/15 39/11
Avenue [18] 2/10 2/17 2/23
11/6 16/13 33/16 35/19 35/25
39/15 56/5 57/2 57/17 58/23
66/23 67/15 68/3 71/23 72/1
aware [7] 34/4 42/6 43/12
60/12 71/25 94/18 98/18
away [3] 22/10 23/2 30/15
Ayvazian [15] 6/21 11/21
16/23 26/24 29/2 31/21 37/25
38/18 40/6 40/9 40/17 40/21
74/14 116/11 116/17
Ayvazian's [2] 25/3 37/14
Ayvazyan [3] 1/9 2/12 3/11
B
back [19] 15/14 24/16 42/14
45/8 48/2 52/19 65/10 67/5
67/12 87/7 87/23 98/9 99/4
99/13 106/18 107/14 109/15
110/20 110/25
backward [1] 93/16
backwards [1] 55/11
bank [29] 9/21 10/7 13/15
13/18 14/5 14/7 14/11 14/15
25/10 44/8 44/10 44/11 47/12
47/14 47/16 47/21 53/21
53/22 54/20 60/15 69/20 70/1
70/5 84/4 84/5 84/18 87/1
109/23 110/8
banks [1] 69/20
Barnes [1] 5/12
based [11] 13/9 21/24 23/1
42/19 43/11 57/1 69/25 84/25
101/25 104/11 109/10
basic [1] 89/8
basically [4] 14/6 16/19
19/5 91/21
be [65]
Beach [1] 3/21
became [2] 35/19 100/23
because [7] 6/4 51/10 67/2
73/6 87/8 102/21 117/6
become [2] 91/3 94/17
been [22] 8/9 10/20 15/3
16/25 20/17 21/12 22/11
23/13 27/14 29/12 29/24
29/24 30/16 32/9 40/19 68/25
70/4 81/17 100/16 104/3
112/21 115/6
before [26] 17/21 33/24 44/5
45/17 50/18 53/19 56/24 59/3
59/22 66/16 70/11 75/11
76/21 83/3 83/8 83/10 96/11
97/7 97/10 97/13 100/1 103/3
103/8 110/9 110/22 112/1
began [6] 8/11 45/18 83/3
83/9 86/17 105/14
begin [4] 8/16 83/11 83/14
85/2
beginning [3] 27/25 33/22
84/16
behalf [3] 2/3 93/17 104/25
being [8] 7/18 37/10 37/12
44/24 45/5 72/1 72/3 81/15
belief [3] 61/10 68/12 70/13
believe [32] 6/15 7/5 7/14
24/15 32/3 32/10 39/22 41/8
41/20 44/13 47/14 62/20
66/18 70/4 71/1 71/10 77/14
81/25 87/14 94/3 94/8 94/9
94/10 97/20 101/18 103/10
105/5 105/14 107/13 110/22
113/24 115/13
believed [2] 41/5 41/10
believes [1] 106/10
belongs [4] 43/19 58/4 65/13
65/15
better [5] 37/1 66/11 72/17
72/18 73/1
between [5] 9/2 13/2 13/11
43/1 107/15
Beverly [1] 21/19
beyond [2] 90/20 91/14
Bienert [2] 3/4 3/7
bill [2] 68/6 68/17
bit [1] 43/25
blow [8] 34/8 35/1 35/10
45/9 55/23 56/22 60/1 70/14
blowup [2] 35/22 36/10
BlueVine [4] 69/18 69/18
70/3 70/4
board [1] 68/15
boarded [1] 19/5
both [2] 60/8 68/22
bottom [24] 16/4 29/8 29/10
30/5 34/8 35/1 37/23 45/14
46/3 46/20 52/6 52/8 52/13
53/13 54/11 56/3 57/16 57/18
66/25 68/16 70/14 70/15
98/12 102/23
Boulevard [2] 3/15 18/2
bracelet [2] 116/20 116/24
break [2] 66/17 69/4
brief [1] 64/24
briefly [1] 114/13
bring [18] 40/24 44/5 45/8
45/21 51/20 54/24 58/2 61/11
61/19 62/18 63/19 64/6 82/5
96/10 97/4 99/23 105/20
113/11
brings [1] 90/15
brokerage [1] 60/20
brought [2] 110/20 110/22
Bruce [1] 89/3
building [1] 37/11
bureau [1] 71/11
business [7] 15/19 19/15
23/23 69/12 69/15 96/22
104/16
businesses [1] 88/22
buyer [1] 104/19
buyer's [1] 104/23
buying [1] 72/6
C
C-L-A-R-K [1] 8/2
CA [9] 1/23 2/7 2/15 2/21
3/6 3/9 3/13 3/16 3/21
Caicos [1] 14/21
CALIFORNIA [20] 1/2 1/14 5/1
9/6 9/15 9/16 10/11 10/13
11/7 11/9 11/16 11/17 11/23
11/25 16/14 18/3 21/3 21/5
33/12 116/12
call [3] 60/4 115/20 117/8
Calle [11] 3/5 21/2 21/20
22/2 72/6 74/6 74/10 75/3
75/15 76/24 77/8
called [1] 75/2
calls [3] 7/22 37/16 81/9
came [4] 8/19 85/12 85/25
86/2
can [160]
can't [10] 32/7 36/8 51/14
52/9 52/22 53/8 66/8 66/10
68/17 81/17
cannot [2] 5/14 53/7
Canoga [28] 11/6 33/15 33/16
35/19 35/24 39/15 39/16 40/9
41/17 41/23 43/21 56/4 57/2
57/17 58/23 63/21 63/25 64/4
64/9 64/10 64/12 64/15 66/23
67/15 67/19 67/22 67/25 68/3
card [5] 14/7 29/8 29/9
41/11 96/22
cards [2] 27/21 29/6
CARES [2] 33/24 45/17
Caribbean [1] 14/20
case [37] 6/20 10/16 29/13
29/22 31/17 32/19 38/3 42/8
43/12 43/17 43/19 46/6 47/12
54/1 55/18 61/17 72/2 78/13
88/7 88/18 90/10 90/18 91/21
92/1 92/12 95/8 111/15 112/2
112/4 112/5 112/7 112/8
112/9 112/20 113/21 113/22
113/24
cases [2] 113/21 114/1
cash [1] 83/18
cashier's [1] 93/24
category [1] 101/2
CATHERINE [1] 2/5
cell [3] 27/20 89/15 117/8
cells [1] 57/18
Celtic [3] 69/23 70/1 70/4
center [4] 34/17 34/20 34/21
55/23
CENTRAL [10] 1/2 9/6 9/9
9/14 10/11 10/12 11/8 11/17
11/24 21/4
certain [3] 39/21 84/17 85/6
certificate [5] 22/19 23/2
30/24 31/8 118/1
certifications [2] 105/11
105/15
certifies [1] 101/25
certify [2] 99/20 118/4
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certifying [2] 99/10 104/2
change [1] 78/11
changing [1] 44/6
charged [1] 113/3
charges [1] 78/15
chart [1] 52/17
charts [1] 79/5
chase [7] 44/21 44/24 45/2
46/1 82/8 82/21 93/19
check [8] 20/12 29/20 81/6
83/18 92/25 93/23 93/24 94/8
checks [2] 83/21 94/9
Christopher [1] 2/9
circle [2] 52/19 75/22
Circuit [1] 113/22
Citibank [2] 29/8 29/9
Citicard [1] 29/10
City [3] 21/3 23/11 23/19
clarify [5] 38/25 41/15
44/16 51/8 102/21
clarifying [1] 90/7
CLARK [40] 4/4 7/22 8/1 8/6
9/20 12/18 13/5 15/15 17/20
22/15 24/4 24/10 24/18 28/25
30/1 30/20 31/6 32/16 32/18
37/3 42/7 43/11 45/22 47/2
47/11 49/9 49/25 51/8 52/3
53/16 82/7 90/9 92/19 99/25
101/15 103/2 106/1 106/4
109/17 111/16
clear [5] 7/3 51/11 52/20
91/1 113/21
clearer [1] 84/10
clearly [3] 36/25 67/20
112/15
Clemente [1] 3/6
client [2] 113/3 114/1
clip [2] 40/8 41/24
clips [3] 39/21 41/17 41/19
close [1] 50/17
closely [2] 113/14 115/7
closing [1] 79/9
co [1] 91/19
co-IRS [1] 91/19
Coast [1] 3/20
Code [1] 118/5
column [5] 51/16 54/2 54/15
54/16 69/22
columns [1] 52/18
come [4] 8/11 75/14 86/1
110/25
comes [1] 32/11
coming [1] 104/23
committing [1] 115/25
common [1] 92/8
commonly [1] 90/17
communication [1] 28/8
communications [4] 90/18
90/20 92/6 92/8
companies [5] 20/4 20/7
29/21 55/20 63/20
company [19] 14/7 19/10
19/16 19/19 19/22 20/1 20/2
20/10 20/12 25/24 26/8 26/10
26/12 26/14 26/18 29/16
55/16 63/11 108/20
complete [3] 15/13 15/13
64/25
completely [1] 7/4
complex [4] 38/6 38/8 40/10
41/18
computer [2] 39/19 71/7
computer-type [1] 71/7
concern [1] 113/7
concluded [2] 5/14 117/14
conduct [6] 30/11 60/12
60/14 60/19 74/18 75/12
conducted [5] 74/4 74/10
111/15 111/18 112/17
Conference [1] 118/9
confinement [2] 112/22
116/21
conformance [1] 118/8
confused [1] 112/10
confusing [2] 33/2 113/8
confusion [2] 38/20 73/6
conjunction [1] 98/19
connect [1] 42/23
connected [2] 43/13 50/6
Connecticut [1] 2/23
connection [26] 5/24 11/12
12/2 12/13 12/19 13/7 17/23
20/22 21/1 23/5 27/4 29/13
29/22 31/11 38/3 43/1 44/8
47/23 74/23 103/9 103/18
107/8 111/10 111/13 111/14
111/15
consider [1] 115/9
considered [1] 5/11
conspiracy [1] 78/15
construction [9] 8/20 26/9
55/16 55/19 55/19 62/15
63/17 66/3 69/16
Consultants [1] 110/16
Cont'd [1] 3/1
contains [2] 48/1 48/4
contents [1] 53/15
Contracting [7] 8/22 19/17
54/11 54/12 54/13 98/4 99/11
conversation [1] 117/2
convict [1] 113/15
conviction [1] 113/16
convinced [1] 113/18
copy [1] 69/3
corner [6] 46/3 66/25 70/14
83/6 102/23 110/12
corporation [1] 109/9
correct [117]
correctly [1] 116/17
correspond [1] 51/5
could [30] 34/5 34/13 34/15
37/1 39/22 43/8 55/15 56/7
62/18 63/19 73/17 73/19 76/4
77/5 87/7 87/17 90/6 95/12
96/10 96/19 100/2 102/17
104/12 105/20 107/22 108/12
109/14 116/8 116/13 117/12
couldn't [1] 40/12
counsel [6] 2/1 5/10 39/4
52/21 69/3 74/7
country [3] 13/1 13/10 14/6
County [2] 10/10 117/7
couple [3] 10/18 36/10 105/5
course [4] 17/9 20/18 90/23
115/2
court [7] 1/1 1/21 7/18
112/11 113/23 115/4 116/13
cover [1] 82/8
CR [1] 1/8
create [1] 73/5
credit [5] 14/7 27/21 29/6
96/7 96/25
crimes [2] 8/18 8/18
criminal [1] 8/8
cross [5] 4/5 31/23 32/14
114/25 116/6
Cross-Examination [3] 4/5
31/23 32/14
CRR [1] 118/12
Cruz [5] 22/13 23/15 24/8
27/16 30/18
CSR [2] 1/21 118/12
culmination [1] 51/6
current [2] 45/14 68/11
Cursory [1] 43/18
custodian [3] 34/16 34/20
63/12
customer [2] 46/16 46/18
cut [1] 104/13
cyclical [1] 87/9
D
DADYAN [6] 3/18 6/23 79/15
79/17 79/21 80/5
database [1] 16/19
databases [1] 18/14
date [8] 27/12 30/9 31/9
31/13 36/19 55/6 57/1 118/10
dated [2] 99/14 99/16
dates [4] 14/14 37/20 56/18
86/9
David [1] 89/3
day [2] 1/15 115/19
days [1] 31/13
DC [2] 2/10 2/23
deal [3] 23/5 32/5 32/11
death [6] 22/19 23/1 30/24
31/8 31/9 31/14
debit [1] 41/11
December [2] 45/15 112/18
December 11 [1] 45/15
December 17th [1] 112/18
decide [1] 84/23
decided [3] 49/13 49/19 50/5
Deciding [1] 84/24
DEFENDANT [5] 1/9 2/12 3/3
3/11 3/18
defendant's [3] 9/23 13/6
113/21
defendants [22] 5/18 6/20
8/24 9/2 9/8 9/21 12/5 12/6
12/12 12/22 13/1 13/10 13/15
16/22 25/1 29/12 31/17 39/25
40/3 112/2 112/21 115/11
defendants' [1] 26/21
defense [27] 31/24 40/24
45/21 51/20 59/1 61/11 66/17
75/9 75/17 75/21 76/12 76/21
76/23 77/1 77/5 77/18 82/5
97/5 97/16 98/2 99/24 102/17
102/25 105/21 106/18 107/23
109/15
Define [1] 47/20
delta [1] 28/22
demonstrate [1] 109/13
denied [1] 105/15
DEPARTMENT [3] 2/4 2/9 23/12
depends [1] 116/6
depict [1] 27/19
depicted [1] 29/6
depiction [1] 28/14
deposit [5] 83/13 85/4 85/12
86/4 86/12
deposited [5] 81/7 85/7
85/23 86/16 93/12
deposits [2] 86/20 86/20
describe [4] 27/7 29/5 90/11
90/13
described [4] 91/17 91/24
92/3 103/19
description [2] 71/5 71/6
descriptions [2] 40/2 40/4
design [1] 26/17
destination [1] 87/7
destinations [1] 87/6
details [3] 7/7 45/10 63/2
determination [1] 71/12
determine [2] 28/1 88/22
determined [2] 71/21 87/7
developed [1] 6/10
device [2] 28/5 28/6
devices [2] 71/10 90/1
Diamonds [1] 57/8
did [157]
didn't [23] 14/13 33/6 33/14
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didn't... [20] 34/18 38/14
38/16 39/10 41/14 41/15 51/2
60/12 60/14 67/20 76/3 78/19
83/11 96/2 97/20 104/13
106/3 106/24 107/16 107/20
different [6] 24/6 24/13
91/19 103/13 111/19 112/4
digital [1] 28/5
direct [10] 4/4 8/4 13/23
43/16 44/11 49/25 56/8 61/13
73/14 114/12
directed [1] 91/3
directing [8] 13/21 15/5
15/21 16/3 16/7 17/16 30/4
91/4
discovered [1] 74/20
discovery [1] 78/23
discrete [1] 92/11
discuss [2] 50/18 90/23
distribution [1] 109/8
DISTRICT [12] 1/1 1/2 1/4
9/6 9/9 9/14 10/11 10/13
11/8 11/17 11/24 21/4
divide [1] 91/23
divided [1] 109/10
DIVISION [1] 1/2
do [79]
document [73]
documentation [2] 104/15
104/18
documents [25] 10/19 21/11
23/18 23/20 45/1 48/12 51/2
59/24 64/8 64/11 68/22 84/7
86/7 89/7 95/5 95/10 101/6
101/7 103/14 103/15 103/17
105/18 106/10 111/16 113/10
does [34] 7/13 14/11 21/23
24/5 24/11 24/20 24/25 27/8
27/19 30/6 34/10 34/25 46/16
47/2 47/6 48/9 51/5 52/17
52/18 53/16 59/13 63/2 69/25
76/14 76/20 93/4 96/25 98/3
101/24 102/22 106/1 106/4
106/7 115/4
doesn't [6] 17/11 39/4 42/5
47/9 51/13 74/1
doing [1] 106/15
DOJ [2] 46/2 102/22
don't [59] 5/16 7/4 7/6
35/20 36/4 36/25 38/21 39/13
42/12 45/24 48/11 51/1 51/5
51/7 52/16 53/18 58/15 59/4
62/19 64/13 66/5 69/19 71/24
72/16 73/19 73/22 73/22
73/24 73/25 75/24 75/24
76/13 77/17 77/22 78/7 78/22
78/25 79/10 83/25 85/16
90/14 91/6 91/6 91/15 93/3
94/6 94/10 100/2 102/13
102/16 104/22 106/14 107/21
113/24 115/7 116/2 116/15
117/1 117/13
done [3] 43/8 76/18 105/24
door [1] 19/4
Dora [11] 11/16 33/10 58/7
58/24 60/3 60/8 61/21 65/15
65/25 69/1 70/18
down [6] 43/15 45/14 46/24
69/23 78/10 106/17
draw [1] 70/2
drive [1] 39/17
driver's [6] 15/1 15/9 16/11
17/21 18/1 25/11
drives [1] 39/18
driving [1] 117/6
drops [1] 72/15
drug [1] 7/6
Dura [1] 89/3
during [5] 9/9 27/1 69/4
86/12 116/12
Durkey [1] 89/3
DX19 [1] 54/18
DX40 [2] 61/19 65/21
DX45 [2] 96/10 96/18
DX48 [1] 64/6
DX64 [1] 69/3
E
e-mail [8] 21/16 21/21 21/24
41/7 59/19 59/22 63/4 89/22
each [3] 86/1 86/1 90/14
earlier [5] 12/5 13/14 80/17
105/14 112/13
Edit [4] 58/13 58/19 68/9
68/22
EditMadatyan [1] 58/16
Edvard [3] 46/19 80/21 80/25
effort [1] 37/1
EIDL [8] 8/12 9/11 10/22
12/7 12/13 12/19 56/9 85/5
either [3] 36/6 36/8 99/1
electronic [3] 56/1 71/10
90/1
else [10] 6/9 43/8 48/19
50/15 88/18 88/19 88/24 89/5
91/5 117/12
email [1] 58/17
employed [1] 104/3
employee [1] 77/14
enable [1] 36/25
Encino [2] 11/23 16/14
Encore [1] 87/16
end [6] 8/15 24/15 72/15
83/11 83/14 93/9
ended [1] 18/11
ends [1] 45/11
entirely [2] 51/11 70/15
entities [1] 62/9
entitled [1] 118/7
entries [1] 48/1
envelope [1] 66/22
escrow [6] 21/11 21/19 84/7
87/16 87/17 103/15
essentially [1] 92/2
established [1] 70/11
estate [4] 20/23 20/25 21/8
21/17
et [1] 1/9
evaluate [2] 85/25 86/2
even [5] 36/22 87/23 95/8
113/23 113/24
events [1] 56/22
eventually [1] 8/24
ever [1] 53/18
everybody [1] 91/10
everyone [2] 91/5 93/16
EVID [1] 4/7
evidence [47] 15/24 17/2
17/4 22/24 24/3 28/24 31/3
31/25 46/10 49/5 51/22 52/10
52/23 53/1 53/14 59/6 59/12
61/19 62/20 62/24 63/20
64/21 66/18 69/3 69/11 74/14
75/18 75/20 77/4 82/10 82/15
94/25 95/4 96/14 96/18 97/19
101/8 101/21 103/23 103/25
106/19 108/9 109/25 110/3
113/19 114/7 115/7
exactly [2] 84/2 86/24
exam [1] 64/25
examination [11] 4/4 4/5 8/4
31/23 32/14 43/16 44/11
49/25 56/8 73/14 74/20
examine [1] 85/23
examined [1] 103/18
examining [2] 86/4 86/11
example [1] 87/13
excuse [3] 43/20 57/6 99/15
executed [1] 19/4
execution [2] 26/20 64/1
exhibit [72]
exhibits [5] 31/25 32/2 32/4
32/8 32/8
expand [1] 54/15
expect [1] 115/2
expedited [1] 117/12
expenses [3] 10/8 14/8
102/11
experience [2] 104/11 113/13
explain [3] 5/15 31/6 109/7
extensive [1] 115/8
extent [3] 51/12 88/6 113/13
F
face [1] 52/20
fact [2] 38/8 113/17
facts [1] 85/17
factual [1] 114/18
failure [1] 43/6
fair [1] 28/13
Fairly [1] 86/6
falls [1] 101/2
familiar [14] 19/16 20/1
42/23 46/5 51/11 52/7 57/25
61/14 64/3 75/23 78/12 97/8
97/11 97/14
family [1] 58/11
far [5] 6/8 51/10 78/1 78/19
90/20
father [3] 31/20 31/21 57/13
father-in-law [1] 31/21
FBI [1] 71/11
federal [1] 8/9
fee [1] 82/2
Fenton [7] 2/9 4/4 17/16
18/14 18/23 24/4 24/10
Fernando [1] 10/10
few [1] 62/6
Fiber [8] 25/24 26/3 26/7
55/12 55/14 102/1 102/12
108/15
file [1] 26/12
files [1] 104/6
financial [8] 8/18 47/21
47/23 49/23 50/3 50/6 81/13
90/21
find [22] 9/5 9/13 10/6
16/21 18/7 18/10 18/18 19/3
19/13 20/15 25/22 26/6 26/16
27/22 28/5 30/14 31/19 72/21
72/22 73/12 74/13 87/22
finder [1] 27/24
finish [2] 35/13 115/14
finished [1] 115/18
firm [2] 110/18 113/16
firmly [1] 113/18
first [5] 5/11 27/17 69/23
70/2 107/13
five [3] 1/15 31/13 114/14
flat [1] 82/2
flip [1] 55/11
flipped [2] 28/9 28/10
Floor [1] 2/6
flowed [1] 87/5
fob [7] 36/11 36/16 37/10
37/12 37/13 37/21 37/24
follow [13] 75/7 84/13 84/23
84/24 85/13 85/21 87/7 87/17
87/25 93/12 94/2 107/12
113/14
followed [3] 87/5 87/11
87/11
following [22] 5/7 5/19 7/10
7/15 31/13 46/2 65/1 65/4
84/5 84/17 84/19 84/21 86/17
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following... [9] 86/23 87/8
89/13 92/20 93/1 93/10 111/2
115/3 115/6
follows [1] 39/7
foregoing [1] 118/5
forgot [2] 112/1 112/14
form [2] 69/13 69/22
format [1] 118/8
former [2] 16/22 68/11
found [14] 18/8 20/16 27/10
28/1 28/3 29/1 30/15 63/20
66/23 67/15 68/3 77/8 103/14
112/20
foundation [18] 9/18 12/9
12/16 12/23 13/3 13/12 15/23
16/2 18/9 18/19 32/7 37/16
42/19 74/17 80/8 81/9 83/24
100/21
foundational [1] 94/22
four [2] 105/23 116/9
franchise [1] 68/15
Francisco [1] 2/21
Frank [1] 89/3
Fraser [1] 3/7
fraud [5] 8/12 79/18 79/22
111/11 111/20
fraudulent [9] 9/10 11/13
12/3 12/7 105/17 106/2 106/6
106/9 106/11
frequently [1] 48/15
front [1] 15/15
full [2] 7/7 7/24
function [2] 91/18 91/18
functions [1] 91/19
fund [1] 87/15
funded [1] 70/4
funds [8] 41/11 85/4 85/5
85/7 86/17 87/1 87/22 88/2
further [1] 31/22
G
G-E-F-F-R-E-Y [1] 8/2
gather [1] 94/25
gathered [1] 17/7
gave [1] 39/16
gears [1] 78/11
GEFFREY [3] 4/4 7/22 8/1
general [5] 40/4 42/21 84/13
85/11 109/8
generally [5] 20/20 81/12
89/6 89/12 104/20
Genesta [1] 16/13
gentleman [4] 41/22 41/24
42/1 42/12
gentleman's [1] 41/21
get [13] 5/24 7/7 7/8 7/12
15/13 51/10 81/14 89/22 95/4
106/16 113/4 114/8 115/17
gift [1] 104/21
give [4] 39/20 39/21 79/9
87/13
given [5] 40/14 62/9 71/14
79/2 84/11
giving [1] 104/21
Glendale [5] 3/13 21/3 23/11
23/19 72/7
global [1] 58/13
gmail.com [4] 35/4 59/20
62/4 63/5
go [67]
goes [3] 49/24 91/9 94/24
going [33] 5/23 7/7 7/8
10/18 10/19 13/20 14/20
16/24 16/25 17/18 21/12
23/13 28/8 37/23 40/9 41/22
45/8 46/25 47/17 51/8 54/1
58/22 64/23 76/7 78/10 91/3
100/25 101/13 106/17 113/11
113/15 115/11 115/19
gold [2] 29/8 29/9
gone [1] 73/7
Good [4] 7/17 8/6 32/16
32/17
Google [1] 59/14
got [3] 39/12 39/14 86/6
government [30] 7/22 15/4
21/13 22/20 22/21 27/15
28/16 28/21 29/25 30/17
30/25 31/1 32/1 34/6 38/5
46/6 53/3 54/24 58/2 62/9
65/10 78/23 85/9 100/11
113/19 114/11 114/18 114/22
115/3 115/5
government's [6] 10/20 13/21
17/1 22/12 23/14 78/18
Grigor [1] 80/6
Grigoryan [29] 6/13 11/14
32/22 34/12 35/4 36/7 36/13
36/17 42/4 42/11 42/17 43/13
46/21 57/10 58/4 65/13 77/13
77/20 78/3 78/5 80/17 80/24
81/3 81/6 82/1 83/21 112/25
114/4 114/5
Grigoryan's [15] 37/10 43/20
47/4 54/4 54/17 57/12 70/12
70/18 77/16 78/6 94/12 94/15
94/18 111/9 111/24
ground [1] 100/19
grounds [2] 71/19 102/4
Group [1] 3/15
guess [2] 35/22 104/14
Gusto [4] 62/8 63/13 66/4
66/5
GX3.I [1] 55/15
GX3.M [1] 56/7
GX373.B [1] 45/8
GX52 [3] 62/18 62/19 62/24
GX54.B [1] 63/19
GX73.B [1] 44/4
H
had [16] 19/4 20/17 22/10
29/12 30/15 40/5 40/9 66/18
79/5 80/21 80/24 81/12 84/4
92/11 112/21 116/23
half [3] 34/8 35/2 35/10
halfway [1] 69/23
hand [9] 46/3 52/6 52/8
52/13 66/25 67/13 70/14
102/23 110/12
handled [2] 71/8 71/10
handwriting [1] 99/16
happening [1] 36/24
happens [1] 116/7
hard [2] 39/17 39/18
Hart [4] 55/16 55/18 55/25
56/1
Hartunian [1] 80/13
has [24] 10/19 15/3 16/25
21/12 22/11 23/13 27/14
29/24 29/24 30/16 43/1 50/10
50/11 50/12 55/8 58/2 73/7
74/16 81/12 94/22 100/11
100/23 104/2 108/18
hasn't [1] 6/10
have [70]
haven't [2] 32/8 100/16
Hayrapetyan [18] 42/2 42/4
42/8 42/10 42/11 42/12 43/13
80/18 80/19 81/6 81/24 82/2
83/18 83/21 93/13 93/23
93/25 94/14
he [83]
Health [1] 68/19
hear [13] 5/22 14/13 34/18
36/25 38/14 53/4 53/7 53/8
66/8 67/20 106/3 115/4 115/9
heard [10] 55/18 61/3 62/7
62/12 79/2 80/12 80/15 85/16
85/17 101/10
hearing [1] 17/19
hearsay [4] 42/19 102/3
106/12 107/1
held [8] 5/7 5/19 7/10 7/15
65/1 65/4 111/2 118/6
help [1] 114/1
helpful [1] 73/1
her [21] 36/23 61/6 62/9
79/5 96/9 105/5 105/6 105/11
105/19 106/20 107/7 107/12
108/18 108/20 109/6 110/20
110/23 117/8 117/8 117/9
117/11
here [21] 11/1 11/20 16/13
41/1 44/23 48/13 51/16 55/16
63/1 65/25 67/6 73/23 75/24
85/2 90/8 95/13 98/1 102/19
108/22 112/19 114/4
hereby [1] 118/4
Hernandez [1] 113/23
highlight [1] 47/1
Highway [1] 3/20
Hills [3] 11/7 18/2 21/19
him [22] 6/25 17/12 37/12
39/6 39/11 39/12 40/19 43/8
48/8 48/21 49/7 50/12 51/12
52/22 53/14 72/21 81/11
81/22 90/3 92/12 94/23
114/12
his [27] 6/11 11/15 14/11
17/7 17/9 20/22 31/13 33/8
33/10 33/14 33/18 33/22 58/7
58/9 58/10 58/10 58/13 58/20
65/15 67/11 76/1 76/4 80/17
81/16 93/2 112/21 116/12
hit [1] 62/12
hold [1] 102/19
holder [4] 24/13 24/20 24/21
35/19
home [24] 12/7 12/13 12/22
26/17 29/2 33/8 33/10 75/1
77/10 94/18 98/19 98/21
98/23 99/1 99/2 99/17 104/6
111/9 111/22 112/21 112/22
113/11 115/18 116/17
homes [3] 26/21 74/23 74/25
Hone [1] 116/21
Honor [116]
HONORABLE [1] 1/3
hour [3] 95/15 116/3 116/4
hours [1] 117/7
house [16] 6/11 23/7 25/5
29/2 58/7 61/7 61/8 65/16
72/6 72/22 72/23 72/24 73/11
74/4 74/10 104/12
how [12] 8/9 8/16 20/1 20/19
26/9 39/12 39/14 81/2 84/15
84/22 86/19 114/9
Hripsik [2] 77/13 77/19
I
I'm [12] 52/7 53/6 55/1
61/25 67/20 69/4 72/9 82/17
91/15 102/19 104/13 112/10
I.D [1] 4/7
idea [1] 47/5
identification [2] 22/12
30/17
identifications [1] 89/23
identified [1] 68/10
identify [5] 45/22 45/25
52/12 68/14 87/18
identifying [3] 84/6 89/14
112/20
identities [4] 32/25 33/5
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identities... [2] 62/9
107/19
identity [2] 72/10 72/19
image [1] 75/25
important [6] 39/2 47/16
47/20 49/13 49/20 50/5
improper [1] 92/12
Inc [1] 15/20
include [2] 8/24 9/25
included [3] 103/10 104/6
104/10
includes [3] 67/18 67/21
67/24
including [5] 56/22 58/13
75/1 91/10 113/2
income [5] 96/25 102/11
109/4 109/6 109/13
Incorporated [1] 108/15
indicated [9] 14/20 19/5
19/11 25/11 46/18 58/6 88/21
97/20 105/18
indicates [10] 31/9 36/21
37/23 45/16 46/18 46/20
46/20 55/7 56/1 65/17
Indicating [1] 57/23
indictment [4] 78/13 78/15
79/1 86/9
individual [2] 41/20 81/4
info [6] 20/2 20/16 45/3
45/6 58/1 58/3
information [11] 10/15 43/23
48/3 50/21 56/6 59/15 59/16
60/9 62/1 89/15 112/20
informed [1] 42/10
informing [1] 14/5
initial [2] 27/5 27/25
initially [3] 33/20 33/21
93/8
inquire [3] 43/5 81/19 90/5
instance [2] 104/25 112/4
instructed [3] 28/6 28/7
84/15
instruction [2] 84/1 113/18
instructions [2] 115/16
115/19
intend [2] 114/12 115/20
interest [1] 84/6
interested [1] 89/21
Interiors [10] 29/16 29/19
29/21 30/2 30/3 31/11 56/10
56/12 56/14 56/25
interpreter [1] 53/7
interview [5] 22/5 88/25
89/2 107/11 110/9
interviewed [7] 81/21 81/23
95/25 96/5 97/2 105/3 105/6
interviewing [2] 89/6 95/16
interviews [2] 81/20 107/15
investigate [20] 8/18 14/23
16/16 18/5 19/7 19/9 19/22
20/10 21/7 23/7 25/8 29/18
42/20 43/6 43/7 71/13 71/22
84/12 88/3 90/1
investigated [6] 32/21 72/9
72/10 72/19 73/10 79/14
investigating [4] 8/12 40/19
91/13 100/24
investigation [61]
investigator [1] 49/24
involved [4] 6/20 26/20
91/13 92/5
involving [2] 48/5 78/16
IP [40] 10/15 10/21 11/12
12/2 43/17 43/19 45/8 45/11
45/20 47/3 49/3 49/14 49/20
49/22 50/1 50/6 54/3 54/3
54/16 54/20 55/9 56/2 56/4
57/2 57/17 57/21 57/25 58/23
60/3 60/8 60/13 61/22 65/12
65/18 65/24 69/1 70/17 71/2
71/13 71/22
IRS [5] 8/8 91/19 91/20
91/25 92/6
is [353]
isn't [1] 87/8
issue [2] 5/17 100/12
issuing [1] 5/14
it [275]
it's [3] 58/17 62/20 116/9
item [1] 50/18
items [2] 64/3 64/5
its [1] 53/14
itself [1] 21/8
J
jail [1] 37/25
January [3] 97/3 98/6 105/4
January 13th [2] 97/3 105/4
January 1st [1] 98/6
Jennifer [1] 3/12
job [3] 71/4 71/6 113/9
Jobe [1] 8/19
jog [1] 76/7
John [1] 3/4
Johnson [6] 2/14 2/17 2/19
2/22 3/19 3/20
Journeyman [1] 26/9
JPMorgan [6] 44/21 44/24
45/2 46/1 82/8 82/21
Jr [1] 3/14
JUDGE [2] 1/4 73/8
judgment [3] 84/18 84/21
84/22
judicial [2] 116/14 118/9
July [7] 30/10 31/9 31/12
56/19 98/16 99/14 110/15
July 16th [1] 98/16
July 17th [1] 99/14
July 18th [1] 31/9
July 23rd [2] 30/10 31/12
July 30th [1] 110/15
JUNE [8] 1/17 5/1 8/15 35/18
41/5 41/8 98/6 118/10
juries [1] 113/14
jury [31] 1/15 5/8 5/10 5/20
7/11 7/12 7/16 7/17 24/5
24/11 27/8 29/5 31/7 32/8
39/5 65/2 65/5 69/8 84/8
96/20 97/23 103/23 108/10
110/6 111/3 113/8 113/12
114/19 115/16 115/18 115/19
just [57] 6/10 6/25 7/2 7/6
8/10 20/19 22/13 24/12 27/16
28/3 36/10 39/3 41/15 43/7
44/6 47/9 48/8 48/13 50/17
53/6 54/1 58/19 59/1 61/12
63/7 64/6 65/11 70/8 73/22
75/1 75/8 76/1 76/9 76/11
89/21 90/20 91/5 91/17 92/3
93/15 96/10 97/4 99/23
100/14 101/12 101/15 102/18
102/21 103/1 105/20 106/16
109/16 112/1 112/6 112/14
112/15 116/10
JUSTICE [2] 2/4 2/9
K
K-1 [4] 108/25 109/4 109/7
109/8
KATIE [2] 1/21 118/12
Katzman [2] 3/4 3/7
Kauichko [23] 10/2 10/25
25/9 25/15 25/25 26/10 29/10
34/24 35/2 35/7 35/18 36/3
36/22 37/4 43/22 55/5 59/17
59/24 67/24 99/2 102/1
108/23 109/5
Kauichko's [1] 55/8
keep [3] 43/24 90/25 91/6
keeping [1] 45/20
Keough [1] 2/19
key [9] 32/24 33/4 36/11
36/16 37/10 37/12 37/13
37/21 37/24
kind [5] 68/16 68/17 87/22
88/1 104/9
kitchen [2] 28/2 29/4
knock [1] 116/9
know [60]
knowledge [6] 40/23 42/16
58/21 69/25 94/22 112/3
known [1] 75/5
knows [1] 48/19
Kudiomov [10] 10/4 67/18
67/21 104/2 105/1 106/22
106/25 107/8 110/13 110/16
L
La [11] 21/2 21/20 22/2 72/6
74/6 74/10 75/3 75/4 75/15
76/24 77/8
label [1] 77/24
lack [6] 42/18 80/7 81/8
100/15 100/20 100/21
lacks [2] 37/15 83/23
Landsgaard [4] 21/22 22/5
22/19 23/2
Landsgaard's [2] 21/25 23/4
language [2] 99/6 113/17
LAPD [6] 6/4 94/18 95/6
111/9 111/15 111/19
large [1] 48/5
larger [1] 93/6
Las [1] 116/16
last [8] 14/17 32/1 40/20
54/4 57/5 60/6 96/11 114/17
later [1] 35/6
latter [1] 84/20
law [5] 3/15 3/20 21/21 25/3
31/21
lawyer [1] 43/1
lawyers [1] 113/24
lay [1] 32/7
lead [6] 8/19 90/10 90/12
90/13 90/14 92/11
leads [1] 43/6
learn [4] 81/2 81/5 81/10
94/4
learned [5] 79/17 79/21 80/5
82/1 83/20
lease [6] 35/11 36/5 36/6
36/23 36/23 45/14
least [4] 26/8 101/3 113/2
113/19
leave [1] 116/11
left [7] 36/13 52/6 52/8
52/13 66/25 70/9 110/12
left-hand [5] 52/6 52/8
52/13 66/25 110/12
legal [1] 100/18
lender [2] 104/14 104/17
lengthy [1] 116/1
less [1] 114/10
let [6] 13/23 14/6 39/6
48/21 91/12 100/17
let's [17] 11/11 11/19 11/19
15/13 17/11 24/14 35/13
37/19 48/2 50/15 58/2 92/17
101/13 106/16 110/24 111/17
112/15
letter [6] 82/8 99/7 99/14
99/20 100/23 104/1
letters [2] 106/8 106/21
Lewis [1] 3/4
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liability [1] 102/15
license [6] 15/1 15/9 16/11
17/21 18/1 25/11
like [19] 6/20 7/5 26/17
27/16 31/25 35/18 39/3 39/4
40/17 40/24 60/12 68/16 69/2
71/7 82/8 87/14 88/15 93/10
96/13
likely [2] 44/22 45/2
limited [1] 40/16
limits [1] 114/3
line [3] 35/22 60/4 63/24
line 3 [1] 60/4
linear [1] 87/9
lines [1] 36/10
link [1] 42/23
list [7] 63/20 67/13 67/18
67/21 95/21 96/2 96/25
listed [10] 35/2 51/17 54/3
54/4 57/10 70/17 93/25 95/24
102/7 108/22
literally [1] 51/12
little [5] 18/12 43/24 72/18
84/10 112/15
Littrell [3] 3/4 3/4 3/7
lived [4] 9/2 9/6 12/5 67/10
lives [3] 58/10 58/15 58/20
living [5] 9/14 19/6 23/7
73/10 73/12
LLP [6] 2/14 2/17 2/19 2/22
3/4 3/7
loan [29] 8/12 9/11 10/22
12/7 12/13 12/19 14/25 15/2
15/19 20/5 26/1 26/12 29/22
30/1 31/11 56/9 56/9 57/5
57/7 70/2 83/3 83/8 83/14
85/23 86/19 86/20 88/21 89/8
103/11
loans [25] 25/12 25/14 25/14
45/18 61/6 61/17 72/1 78/16
78/19 78/24 79/1 79/2 79/5
85/15 85/18 85/20 85/20
85/22 85/25 86/4 86/12 86/16
87/23 88/2 114/5
located [2] 88/22 88/23
location [6] 19/14 19/25
20/12 20/14 25/10 29/20
locations [3] 10/12 19/11
88/21
log [4] 47/3 60/10 60/15
60/20
logging [2] 60/22 60/23
long [1] 8/9
longer [1] 114/9
look [29] 9/1 9/7 11/11
11/19 11/19 13/18 17/23
20/19 24/23 29/15 31/16
36/19 49/13 49/20 54/2 56/18
69/22 70/8 75/21 76/17 77/23
78/8 83/5 84/17 85/6 85/12
100/17 105/23 113/22
looked [5] 47/20 48/12 63/7
77/25 78/19
looking [9] 10/21 47/21
47/22 49/22 52/17 76/14
77/24 81/13 84/7
looks [7] 35/18 40/17 68/16
82/8 97/8 97/11 97/14
loop [1] 50/17
LOS [10] 1/14 1/23 2/7 2/15
3/9 3/16 5/1 9/9 10/10 12/6
loss [2] 98/3 98/16
lot [5] 59/25 73/6 89/13
113/10 113/10
low [1] 70/9
lunch [3] 95/15 114/22 117/3
M
Madatyan [4] 58/13 58/19
68/9 68/23
made [10] 5/23 10/9 10/10
39/11 39/11 61/2 71/12 75/4
83/18 114/5
mail [8] 21/16 21/21 21/24
41/7 59/19 59/22 63/4 89/22
majority [1] 10/9
make [15] 7/2 18/11 37/1
39/3 39/4 42/25 66/11 67/1
67/2 68/17 84/9 95/12 113/9
114/7 117/9
males [1] 40/11
man [2] 42/1 42/7
Management [1] 68/20
manager [1] 20/13
manpower [1] 28/1
Manuk [34] 11/14 32/22 34/12
35/3 36/7 36/13 36/16 37/10
42/4 42/11 42/17 43/13 43/20
46/21 47/3 54/4 54/17 57/12
58/4 65/13 69/16 70/11 70/18
77/16 78/5 80/17 80/24 81/2
81/5 82/1 83/21 94/18 111/9
111/24
Manuk's [3] 61/8 64/16 68/10
Manukyan [5] 61/4 69/16 70/9
94/10 94/12
many [1] 86/19
March [9] 9/2 13/2 13/11
82/25 82/25 83/6 83/12 83/13
83/14
March 11th [2] 82/25 83/13
March 12th [1] 83/6
Mardarosian [1] 80/15
Marietta [3] 16/23 25/2
31/20
Mark [2] 8/21 19/25
marked [6] 16/25 22/12 23/14
27/14 29/24 30/16
Market [1] 2/20
Mary [2] 26/24 29/2
Massino [1] 41/2
matched [1] 65/18
matching [1] 65/25
matter [4] 93/4 107/4 112/12
118/7
mattered [1] 92/22
matters [2] 91/14 93/3
may [18] 14/8 32/3 35/17
43/5 50/22 50/23 57/19 65/8
70/18 75/25 76/7 76/7 81/19
84/6 101/10 103/22 114/6
115/23
May 14th [2] 35/17 70/18
May 2nd [1] 57/19
May 6 [1] 50/22
May 7 [1] 50/23
maybe [11] 39/22 52/23 84/2
84/8 92/25 100/16 111/25
116/3 116/9 117/1 117/9
me [23] 5/22 11/2 13/23 14/1
36/25 38/12 38/15 39/16
39/21 43/20 53/8 57/6 91/10
91/12 91/21 99/15 100/14
100/17 102/1 105/14 114/7
115/8 116/19
mean [32] 15/12 17/11 18/10
18/11 25/14 32/6 38/21 39/7
48/14 51/5 52/22 67/2 70/1
71/17 73/2 74/16 74/17 76/5
76/6 79/7 81/10 84/16 85/1
93/4 103/17 104/13 104/18
113/10 113/20 114/3 116/15
116/18
means [2] 46/5 93/3
Medet [13] 61/14 61/16 62/1
62/7 62/15 63/16 65/19 65/25
66/3 66/14 67/3 67/6 67/9
MedetMurat1994 [2] 62/4 63/5
Media [5] 26/3 55/12 102/2
102/12 108/15
medical [1] 68/6
meet [1] 114/21
Meghan [1] 2/16
members [1] 7/17
memo [3] 98/25 100/3 106/10
memorandum [1] 109/20
memory [4] 76/7 94/5 95/21
100/2
mentioned [9] 6/8 12/5 43/16
48/15 63/16 75/2 92/22 95/16
107/24
Mesa [1] 113/23
Mesereau [2] 3/14 3/15
Miami [1] 37/25
Michael [3] 2/19 55/25 56/1
middle [7] 29/9 46/19 56/3
61/21 67/3 67/5 97/1
might [4] 7/4 90/7 92/25
109/12
Mikegrigoryan93 [1] 35/4
mind [1] 45/20
minute [3] 5/15 48/13 87/20
minutes [4] 64/24 105/7
114/10 114/14
mispronounce [1] 42/13
Misstates [1] 93/2
Mod [10] 29/16 29/18 29/21
30/2 30/3 31/11 56/9 56/11
56/13 56/25
mode [1] 28/7
modems [1] 72/1
moment [6] 17/4 36/2 42/14
46/12 75/22 110/13
money [21] 49/24 84/6 84/14
84/16 84/19 84/21 84/23
84/24 84/25 85/13 86/23 87/5
87/7 87/8 87/10 87/15 87/25
89/13 92/20 92/22 94/2
Monica [1] 3/15
monies [2] 87/18 88/3
monitoring [3] 116/20 116/22
116/23
months [1] 56/24
more [12] 11/19 18/12 24/15
27/6 28/1 66/10 76/13 78/19
84/3 109/10 112/15 115/12
morning [5] 7/17 8/6 32/16
32/17 64/24
mortgage [4] 79/18 79/22
111/11 111/19
most [2] 44/22 72/25
mother [2] 25/2 25/3
mother-in-law [1] 25/3
motions [1] 115/3
move [17] 12/25 16/24 23/22
31/25 46/8 50/15 50/16 52/14
61/2 62/19 79/12 79/24 82/10
92/17 97/15 108/5 116/25
moves [3] 22/20 28/16 30/25
Mr [50] 4/4 4/5 17/16 18/14
18/23 24/4 24/10 34/10 37/3
37/19 39/14 41/1 51/16 52/3
52/12 54/10 64/11 66/22 72/5
72/19 73/10 74/3 74/19 75/10
77/7 78/12 79/13 80/5 80/24
90/9 92/5 92/19 93/6 95/10
96/22 97/6 98/2 99/7 99/25
101/15 102/7 102/21 103/2
104/1 105/22 106/20 107/24
108/14 109/17 110/8
Mr. [10] 22/13 23/15 24/8
27/16 30/18 42/7 82/7 104/2
110/16 116/11
Mr. Anton [1] 104/2
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Mr. Ayvazian [1] 116/11
Mr. Clark [2] 42/7 82/7
Mr. Cruz [5] 22/13 23/15
24/8 27/16 30/18
Mr. Kudiomov [1] 110/16
Ms [2] 105/3 110/10
Ms. [8] 46/13 79/2 79/17
79/21 80/5 97/2 107/12 110/7
Ms. Dadyan [3] 79/17 79/21
80/5
Ms. Robinson [1] 79/2
Ms. Romero [2] 46/13 110/7
Ms. Vostanikyan [2] 97/2
107/12
much [1] 114/9
Murat [9] 61/14 61/16 62/2
62/7 62/16 63/16 66/3 66/14
67/9
Murat's [2] 65/19 65/25
my [25] 5/15 8/1 24/9 38/2
40/23 42/16 49/23 58/21
60/18 61/10 62/14 68/12
70/13 71/4 71/4 75/16 84/20
94/5 98/25 100/2 104/8
104/11 105/16 113/3 113/13
myself [1] 90/11
N
name [63]
named [6] 29/16 42/1 42/7
79/14 80/6 96/3
names [10] 8/20 25/17 29/6
43/1 46/16 52/6 52/7 52/12
52/18 95/21
Nazar [8] 30/8 30/12 30/15
30/24 31/8 31/10 31/16 31/20
need [3] 24/6 24/13 34/7
needed [1] 28/1
never [2] 20/17 48/12
New [2] 2/10 2/18
Newcomer [1] 2/16
next [15] 15/21 24/20 35/9
47/6 50/22 51/17 54/4 55/23
65/21 68/2 68/13 108/12
114/15 115/15 117/4
Nicholas [1] 2/22
night [1] 32/1
Ninth [1] 113/22
no [46] 1/8 6/22 6/24 11/5
16/2 22/8 28/8 31/22 40/1
42/15 43/3 45/1 45/7 47/5
48/19 52/1 53/3 53/25 59/8
60/16 60/21 62/22 64/2 64/19
69/6 76/16 78/9 80/4 80/14
80/16 82/13 89/12 89/24 90/2
93/14 94/8 95/23 96/12 96/16
97/17 97/22 101/8 108/7
111/12 112/10 118/12
nobody [1] 19/5
normal [1] 14/8
North [2] 2/6 3/20
not [72]
notice [2] 68/15 116/14
November [5] 27/13 29/1
33/22 36/20 37/3
November 5th [2] 27/13 29/1
now [63]
number [18] 5/11 28/20 46/2
47/6 47/6 48/1 48/5 51/3
51/16 51/17 54/9 55/19 61/16
73/3 78/22 78/25 86/22 95/24
numbers [3] 85/21 98/10
113/11
numerous [1] 14/25
NW [2] 2/10 2/23
NY [1] 2/18
O
o'clock [2] 110/25 110/25
object [1] 102/3
objecting [1] 100/16
objection [64]
objections [1] 53/5
observed [2] 14/8 41/25
obtained [2] 23/11 38/5
obviously [1] 6/13
occupied [2] 26/7 26/17
October [7] 14/16 14/16
37/22 37/22 38/1 38/1 40/20
October 10th [1] 14/16
October 20th [1] 14/16
October 21 [2] 37/22 38/1
October 22 [1] 38/1
October 22nd [1] 37/22
off [6] 6/25 17/18 57/1
72/16 95/24 104/13
offer [15] 52/14 53/1 59/5
64/17 69/2 75/17 77/1 95/13
96/13 100/9 101/19 103/5
109/25 111/4 111/6
offered [2] 66/18 107/3
offers [1] 5/13
OFFICE [2] 2/4 3/20
officer [5] 6/5 116/10
116/18 117/3 117/6
offices [1] 21/22
Official [1] 1/21
Oh [3] 11/6 34/7 54/6
okay [21] 5/22 7/2 14/3 15/8
17/15 18/23 19/13 20/1 20/15
23/10 25/13 27/22 29/11
29/21 32/12 34/22 58/25
65/14 87/21 115/1 117/4
Olaf [6] 21/22 21/25 22/5
22/19 23/2 23/4
once [2] 7/18 87/6
one [58] 6/25 10/21 11/11
11/19 17/4 20/4 20/7 25/17
25/24 26/3 26/7 29/21 30/1
30/3 32/6 39/19 41/24 42/14
43/19 44/5 48/13 55/11 55/12
55/14 56/11 56/16 56/25
58/23 62/12 63/7 68/15 69/1
78/7 78/8 84/3 86/1 86/1
90/7 90/9 90/11 90/12 91/20
93/16 94/10 94/11 96/2 98/25
102/2 102/12 102/19 103/10
108/15 109/8 109/10 115/12
115/20 116/9 116/10
one-off [1] 6/25
ones [3] 60/14 60/19 113/2
ongoing [4] 6/15 6/16 6/17
86/15
only [13] 23/16 30/18 41/24
45/21 51/21 62/12 73/5 73/21
82/6 91/20 96/9 114/13
114/17
open [1] 18/11
open-ended [1] 18/11
opened [2] 82/25 83/8
opening [1] 82/23
opportunity [1] 92/15
opposite [1] 107/5
order [1] 5/15
original [1] 8/19
other [32] 5/25 6/1 6/2 6/20
27/9 51/14 53/4 53/5 53/11
55/19 60/10 84/1 84/10 85/16
85/22 86/8 86/16 86/25 87/8
87/18 87/22 87/23 87/23 88/3
89/10 91/13 91/20 91/25 92/6
94/9 94/11 106/21
others [1] 47/25
Otherwise [1] 32/7
our [5] 28/5 39/19 112/3
114/17 116/9
ourselves [1] 65/12
out [21] 7/5 14/5 14/8 22/5
25/14 37/11 40/9 41/22 54/24
57/22 67/1 67/2 67/5 67/12
68/17 73/12 83/18 87/6 98/9
116/9 117/11
outset [1] 101/3
outside [9] 5/7 5/10 5/20
7/10 13/1 13/10 65/1 92/6
111/2
over [9] 28/9 28/11 34/7
34/15 36/3 36/4 114/22
115/19 117/3
overdo [1] 73/2
overruled [6] 18/20 47/19
48/10 49/17 71/18 102/5
owe [1] 21/22
own [2] 36/23 84/12
owned [3] 72/22 74/4 77/10
owners [1] 109/9
ownership [2] 104/16 109/10
owns [3] 99/11 99/21 102/1
P
Pacific [1] 3/20
package [3] 77/7 77/13 77/25
packet [3] 34/3 34/12 35/3
PAETTY [1] 2/5
page [74]
pages [3] 64/7 97/15 97/19
paid [3] 81/3 81/6 82/1
paragraphs [1] 105/23
Params [1] 70/17
Paronyan [3] 46/19 80/22
80/25
part [36] 8/23 9/1 9/7 21/16
22/4 23/18 25/7 26/19 29/15
32/21 32/23 74/3 74/9 76/23
78/18 79/13 81/25 83/20
89/18 89/19 89/25 91/18 94/8
94/17 95/1 99/17 100/23
101/16 102/21 103/16 108/2
108/19 109/3 112/24 113/19
113/20
participate [5] 8/17 74/17
88/9 88/13 89/11
participated [1] 88/11
particular [3] 41/2 81/12
94/21
particularly [1] 10/8
parties [2] 5/9 7/19
partner [1] 69/21
partners [1] 109/9
Parure [8] 42/2 42/4 42/10
42/14 43/13 80/18 81/6 82/1
pass [1] 23/2
passed [4] 22/10 30/15 33/24
45/17
past [2] 26/18 49/11
pattern [1] 14/9
payment [1] 110/15
pending [1] 97/22
people [7] 53/5 53/11 80/6
81/3 95/24 96/2 106/21
percent [3] 99/11 99/21
102/1
percentage [1] 109/11
performed [3] 86/20 91/21
103/19
period [1] 86/12
permission [10] 22/23 24/1
28/19 31/4 46/13 54/6 82/18
97/23 101/22 110/4
person [12] 19/1 25/4 39/10
41/6 41/8 41/10 41/14 41/18
68/10 70/8 71/7 77/22
personally [1] 23/20
Peter [2] 3/19 3/20
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phon [2] 89/4 114/5
phone [12] 17/18 27/20 27/22
27/24 28/2 28/3 28/4 28/8
28/11 28/14 29/1 117/8
phones [1] 89/15
photo [1] 43/15
photograph [6] 27/17 27/19
28/13 29/7 40/6 41/2
photographs [3] 41/16 64/5
64/13
photos [1] 39/24
physically [1] 27/1
pick [1] 42/13
picture [4] 27/20 75/10
75/12 75/23
piece [1] 114/6
place [1] 29/11
placed [3] 44/17 44/24 45/5
PLAINTIFF [2] 1/7 2/3
planning [1] 109/4
play [1] 114/4
please [67]
plus [1] 86/22
point [12] 10/8 47/19 57/22
61/2 76/5 80/3 85/2 85/23
92/12 112/19 113/12 116/16
Pointe [2] 34/17 34/21
points [1] 113/19
position [1] 116/24
possession [1] 37/14
Power [1] 23/12
PPP [37] 8/12 9/10 10/22
12/7 12/13 12/19 15/19 16/11
20/5 25/25 26/12 29/22 30/1
31/11 45/18 54/21 56/9 69/23
70/2 70/6 83/3 83/8 83/14
85/4 85/7 85/15 85/22 85/23
86/4 86/12 86/16 86/20 86/25
87/23 88/2 88/21 114/5
preceded [1] 56/16
precise [1] 58/19
preliminary [1] 101/5
prematurely [1] 100/17
prepare [4] 89/9 97/21
105/18 106/11
prepared [3] 98/15 101/7
101/25
preparer [3] 96/8 96/9
108/19
preparers [2] 88/25 95/19
preparing [1] 105/15
prescription [1] 77/19
presence [8] 5/8 5/10 5/20
7/11 7/16 65/2 65/5 111/3
present [2] 5/9 9/16
presented [1] 105/19
president [2] 108/22 108/23
PRESIDING [1] 1/4
presumably [1] 36/16
pretty [1] 113/21
preview [1] 79/10
previously [8] 10/20 13/20
15/4 16/25 21/12 22/11 27/14
29/25
Primavera [11] 21/3 21/20
22/2 72/6 74/6 74/11 75/3
75/4 75/15 76/24 77/8
print [1] 30/8
printed [1] 55/5
prioritized [1] 93/6
probably [1] 115/17
probation [4] 116/10 116/18
117/3 117/6
proceed [3] 65/6 65/8 101/13
proceedings [10] 1/13 5/7
5/19 7/10 7/15 65/1 65/4
111/2 117/14 118/6
process [1] 86/15
prod [1] 46/2
produced [11] 45/1 45/25
46/1 46/6 74/22 74/23 78/23
78/25 101/6 108/20 109/2
product [1] 8/12
production [11] 53/20 59/14
69/18 100/4 100/7 101/16
102/22 103/16 107/25 108/3
109/3
productions [1] 53/21
proffer [1] 81/25
profit [2] 98/3 98/16
program [2] 83/3 83/14
pronouns [1] 73/1
proof [4] 5/13 95/13 111/4
111/7
proper [1] 90/5
property [7] 20/13 21/18
22/3 27/1 87/16 87/19 88/14
provide [3] 40/8 104/15
104/18
provided [5] 38/12 38/15
39/24 40/2 69/3
public [3] 16/19 18/14 42/24
publicly [1] 18/15
publish [18] 22/23 24/1 24/8
28/19 31/4 46/13 46/14 54/6
59/10 69/8 77/5 82/18 96/19
97/23 101/22 108/10 110/4
110/6
published [1] 103/23
pull [8] 34/5 59/1 65/10
75/13 75/14 76/24 102/17
107/22
pulling [1] 52/1
pulls [4] 74/4 74/10 74/13
74/18
punctual [1] 7/18
purchase [14] 21/2 21/20
22/2 61/7 61/8 87/16 87/18
88/1 88/4 98/19 98/21 98/24
99/17 104/6
purchased [2] 23/8 88/2
purchaser [1] 22/1
purchases [3] 10/9 14/7
116/16
purport [2] 52/17 52/18
purported [2] 21/25 58/12
purportedly [2] 55/24 99/8
purports [1] 68/7
purpose [1] 79/9
pursuant [3] 23/23 59/14
118/4
put [2] 92/20 106/18
Q
Quality [6] 8/21 19/17 54/13
98/4 99/11 99/21
question [41] 12/10 18/11
33/1 38/22 39/1 43/2 43/10
48/13 48/14 48/14 48/16
49/18 50/13 63/10 71/17
71/20 74/8 76/15 79/20 79/25
81/17 89/8 90/4 90/7 91/16
94/23 94/24 95/3 95/8 97/22
100/13 100/22 100/24 101/1
101/5 101/12 101/13 104/22
111/5 111/6 111/8
questioned [2] 41/2 106/20
questions [11] 15/13 27/9
31/22 36/25 44/6 49/8 51/14
58/22 62/6 73/21 81/11
quickly [1] 44/6
R
Radius [1] 14/15
Ram [1] 2/13
ran [2] 15/1 16/19
random [1] 7/5
rather [2] 58/23 107/4
reach [2] 22/5 117/11
read [13] 11/2 16/4 51/12
52/6 52/9 59/18 68/8 76/17
98/25 99/5 101/16 105/22
114/18
reading [4] 48/23 49/4 54/8
106/13
reads [5] 55/10 55/14 62/3
67/4 99/12
ready [2] 7/19 65/6
real [5] 20/22 20/25 21/8
21/16 86/5
really [2] 90/14 116/19
reason [4] 44/2 94/6 112/7
117/1
reasoning [1] 5/15
recall [13] 42/9 44/23 45/5
59/4 61/18 66/5 77/24 94/6
94/11 100/2 102/13 102/16
107/21
receipt [1] 78/2
receive [2] 95/5 95/10
received [42] 22/22 22/24
23/18 23/20 23/25 24/3 28/18
28/24 31/2 31/3 32/9 34/2
46/9 46/10 59/9 59/12 62/23
62/24 64/20 64/21 69/7 69/11
75/19 75/20 77/3 77/4 82/14
82/15 96/17 96/18 97/18
97/19 100/10 101/20 101/21
103/21 103/25 108/8 108/9
110/2 110/3 111/16
recess [4] 64/24 65/3 95/15
110/24
recognize [18] 13/22 13/24
15/6 15/15 16/8 16/10 17/1
17/10 17/11 17/17 22/16
22/18 23/17 27/17 30/20
39/23 75/24 109/17
recollection [11] 38/2 62/14
76/1 76/4 76/6 76/15 76/20
104/8 105/16 106/1 106/5
record [12] 5/17 7/25 10/24
23/23 47/16 53/17 58/6 65/17
66/11 93/18 102/22 114/19
records [15] 9/21 10/7 13/6
13/9 13/15 13/18 18/15 23/11
25/10 42/24 47/12 47/14
47/21 87/2 90/21
recovered [2] 70/25 71/23
redirect [1] 114/12
Redondo [1] 3/21
refer [5] 14/2 14/17 54/12
58/24 81/4
reference [5] 67/6 85/16
85/17 85/19 85/20
referred [1] 19/16
referring [2] 24/17 65/20
refresh [8] 76/1 76/4 76/14
76/20 94/5 100/2 106/1 106/4
refreshing [1] 76/6
regard [4] 46/17 81/15 84/16
89/15
regarding [16] 5/21 21/16
27/10 32/8 56/8 59/14 73/14
76/20 77/24 104/15 105/4
106/2 106/5 107/17 107/18
111/8
regardless [1] 48/19
regards [1] 6/25
register [1] 73/20
registered [5] 33/18 33/21
36/16 56/4 73/18
registry [1] 36/11
regulations [1] 118/8
related [2] 31/17 35/24
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relating [4] 9/21 9/23 10/15
13/6
relation [1] 42/15
relationship [6] 24/25 42/20
80/18 80/21 80/25 107/19
relative [4] 77/16 77/17
77/22 78/5
relevance [4] 62/7 81/9
92/10 94/19
relevant [4] 7/9 27/11 74/19
79/8
remaining [1] 114/18
remember [2] 78/1 116/17
remit [1] 68/19
remitter [1] 93/25
remove [1] 90/8
renewal [3] 34/2 34/11 35/3
rental [1] 35/19
reorient [1] 65/11
repair [2] 96/7 96/25
repeat [1] 74/7
rephrase [3] 63/10 72/14
93/5
replaced [1] 36/7
reported [1] 118/6
Reporter [1] 1/21
REPORTER'S [1] 1/13
represent [5] 21/23 34/16
34/19 53/20 69/17
representative [4] 16/5 30/6
55/3 66/6
representing [1] 22/1
represents [3] 35/5 35/8
35/17
requested [1] 104/24
requesting [1] 14/3
requests [2] 44/14 44/16
required [2] 104/14 104/17
reside [1] 18/21
resided [1] 18/15
residence [6] 21/2 26/23
26/24 26/25 58/9 58/10
residency [1] 37/7
resituate [1] 93/15
respect [1] 48/2
response [1] 106/24
responsibilities [2] 91/24
113/14
responsible [5] 32/24 33/3
33/4 84/2 113/1
rest [1] 115/19
resting [1] 115/3
rests [1] 115/5
result [1] 10/6
resume [1] 7/20
return [2] 96/8 108/14
returns [1] 101/25
review [16] 9/20 10/6 10/15
12/18 13/5 13/9 21/24 23/1
40/5 43/18 47/17 50/5 51/2
100/4 108/2 115/15
reviewed [27] 10/7 14/25
17/9 21/11 39/18 40/12 40/14
41/13 41/17 43/17 44/7 44/20
45/2 47/11 49/10 50/1 50/2
50/3 53/21 53/24 58/1 64/5
98/15 101/25 104/6 109/23
110/9
reviewing [4] 10/7 84/4 84/7
107/24
Richard [16] 1/9 6/20 16/22
25/2 26/24 29/2 31/21 37/13
37/25 38/18 40/6 40/9 40/12
40/17 40/21 74/14
right [133]
right-hand [4] 46/3 67/13
70/14 102/23
ring [2] 79/18 79/22
Rita [2] 78/2 78/5
Road [1] 3/12
Robinson [1] 79/2
role [8] 21/25 27/4 27/5
49/23 74/24 81/12 81/16
88/15
Romero [2] 46/13 110/7
Rosodco [1] 114/5
Rough [1] 86/22
router [1] 71/14
routers [4] 70/24 71/3 71/23
71/25
rover [4] 27/6 27/7 27/8
88/16
row [2] 54/2 60/6
RPR [1] 118/12
Rule [1] 114/3
ruled [1] 100/17
runs [2] 79/17 79/21
Runyan [3] 25/17 25/19 25/23
Ryan [1] 3/7
S
said [22] 14/13 34/18 36/2
38/14 39/10 43/7 47/9 47/14
48/8 50/10 51/4 74/1 81/12
81/15 88/9 100/23 101/6
104/5 105/17 106/3 106/8
106/24
sale [1] 10/8
sales [1] 10/9
same [14] 48/8 50/19 50/24
51/3 51/17 54/3 54/9 54/16
70/18 91/18 91/21 94/9 103/7
116/5
San [3] 2/21 3/6 10/10
Santa [1] 3/15
saw [5] 28/10 39/12 41/15
79/5 103/8
say [26] 7/13 14/18 17/11
24/20 25/13 30/6 36/8 40/12
45/11 47/7 48/4 63/2 73/22
76/3 76/13 76/14 76/16 79/8
79/20 81/10 86/23 88/15 98/3
101/24 112/6 116/5
saying [3] 87/10 87/25 91/12
says [27] 16/4 16/6 16/13
17/3 24/21 30/5 30/8 34/23
36/4 36/13 37/21 45/14 48/23
48/25 49/3 62/5 63/4 77/21
81/16 98/15 99/10 99/20
102/6 106/10 106/11 110/13
113/24
scan [1] 37/11
scheme [2] 11/13 12/3
school [2] 77/14 77/25
scope [1] 90/5
SCOTT [1] 2/5
screen [5] 46/25 51/25 52/4
57/16 70/15
scroll [2] 63/1 64/7
search [23] 5/23 16/19 18/14
19/4 26/20 27/2 27/4 27/12
27/22 29/11 38/16 63/25
64/12 70/21 70/24 74/17 75/6
88/11 94/18 111/9 111/14
111/18 112/17
searched [4] 6/11 29/1 62/8
111/23
searcher [1] 27/5
searches [5] 74/20 74/23
74/25 88/10 88/13
searching [1] 27/10
seated [1] 7/24
second [9] 35/22 53/4 58/4
60/6 63/24 69/22 82/9 102/20
110/9
seconds [1] 116/8
section [2] 81/25 118/4
see [30] 7/2 18/15 28/6
31/16 34/13 37/19 38/18 39/6
40/21 41/14 41/15 41/18
41/20 46/25 52/3 54/16 57/16
57/21 61/21 63/23 69/12
69/23 77/19 83/6 87/24 93/16
94/24 113/4 115/24 116/7
seeing [2] 102/13 102/16
seemed [1] 100/22
seems [2] 33/23 90/5
seen [14] 17/20 53/19 59/3
59/22 75/10 75/12 76/21
76/23 96/11 97/6 97/10 97/12
99/25 103/2
seized [5] 64/3 64/5 64/8
64/12 64/13
seizures [2] 64/9 64/10
self [2] 23/23 104/3
self-authenticating [1]
23/23
self-employed [1] 104/3
send [1] 115/18
sending [1] 35/3
sense [2] 42/21 84/13
sent [3] 21/21 31/25 34/12
sentences [1] 35/13
series [1] 98/10
served [2] 103/15 110/23
service [4] 25/17 25/20
25/23 26/18
Services [1] 68/19
SESSION [1] 1/16
set [2] 81/6 115/4
sets [1] 90/15
several [8] 8/20 14/25 32/24
38/10 40/11 56/15 61/1 70/24
shareholder [1] 109/12
shareholder's [1] 109/6
she [29] 36/4 36/5 36/6 36/6
52/1 58/15 58/20 61/8 62/8
70/11 79/2 96/7 97/20 97/20
99/10 101/6 101/25 105/15
105/17 105/18 105/18 106/2
106/5 106/8 106/10 106/11
106/24 106/24 108/22
sheet [1] 102/15
short [2] 66/16 114/24
shortly [1] 86/6
should [3] 5/12 106/15
115/14
shouldn't [2] 73/7 106/14
show [16] 10/18 13/20 16/25
21/12 22/13 23/13 23/15 24/5
24/11 27/16 30/18 32/8 34/10
47/2 75/8 75/25
showed [1] 51/3
showing [7] 10/19 15/3 22/11
27/14 29/24 30/16 66/16
shows [2] 24/12 31/7
side [2] 67/13 104/23
sidebar [5] 5/18 5/19 80/2
112/13 112/16
signature [6] 16/5 30/5 30/9
55/2 55/23 56/1
signed [7] 36/23 55/24 55/24
98/12 99/8 108/17 108/18
signer [1] 56/22
signs [2] 15/22 16/1
Silverman [45] 2/22 4/5
34/10 37/3 37/19 39/14 41/1
51/16 52/3 52/12 54/10 64/11
66/22 72/5 72/19 73/10 74/3
74/19 75/10 77/7 78/12 79/13
80/5 80/24 90/9 92/5 92/19
93/6 95/10 96/22 97/6 98/2
99/7 99/25 101/15 102/7
102/21 103/2 104/1 105/22
106/20 107/24 108/14 109/17
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Silverman... [1] 110/8
similar [1] 16/20
simple [1] 39/7
Since [1] 40/20
sit [1] 75/24
site [1] 27/23
sitting [1] 44/23
six [1] 26/8
skills [1] 90/15
slightly [4] 46/23 63/1
78/11 99/5
so [81]
softly [1] 44/2
Solutions [4] 20/2 20/16
45/3 45/6
some [25] 5/25 6/1 6/2 31/24
32/4 38/20 44/2 58/22 60/12
68/15 68/17 71/7 85/16 85/17
86/4 87/15 88/1 88/1 88/9
90/8 104/15 111/5 113/2
113/12 117/1
somebody [6] 39/23 59/16
60/22 73/19 96/5 104/21
Somebody's [1] 17/18
Somehow [1] 72/15
something [13] 6/9 17/19
36/24 50/15 52/9 52/23 72/25
88/16 94/5 113/25 116/13
116/16 117/9
Sometimes [1] 53/10
somewhere [1] 117/10
sorry [12] 52/7 53/6 55/1
61/25 67/20 69/4 72/9 82/17
91/15 102/19 104/13 112/10
sort [2] 91/23 113/25
sounds [3] 39/7 97/3 105/8
source [1] 87/22
speak [3] 7/5 44/2 66/10
Spear [1] 2/20
Special [17] 7/22 8/6 9/20
12/18 13/5 15/15 17/20 21/14
22/15 23/17 24/4 24/10 24/18
28/25 30/1 30/20 31/6
specialist [1] 96/7
specialists [1] 39/19
specific [5] 18/12 73/2 81/4
84/1 84/5
specifically [13] 15/1 33/21
47/23 48/25 56/16 58/7 59/19
62/15 65/15 66/13 67/3 83/11
113/3
speculate [1] 73/23
speculation [2] 37/16 81/9
spell [1] 7/25
spelled [1] 8/2
spend [1] 115/18
spending [1] 14/8
spoke [3] 20/13 105/5 112/12
spreadsheet [3] 53/19 53/24
54/8
spreadsheets [1] 52/4
Spring [1] 2/6
stamp [4] 36/19 56/23 57/1
102/22
stand [1] 114/21
start [3] 10/19 14/22 45/14
started [1] 50/18
starting [1] 85/2
state [6] 6/4 7/6 7/24 28/4
28/9 116/11
statement [4] 82/23 98/16
109/23 110/9
statements [1] 84/5
states [9] 1/1 1/4 1/6 2/3
58/17 104/4 113/23 118/5
118/9
stature [1] 41/21
stay [1] 46/12
stenographically [1] 118/6
step [2] 111/17 115/15
STEPHEN [1] 1/3
steps [7] 16/18 19/9 19/24
21/7 21/10 23/10 29/18
Steptoe [4] 2/14 2/17 2/19
2/22
Stevens [1] 5/21
still [6] 14/13 17/12 19/5
37/10 93/19 114/21
stipulations [1] 114/19
street [24] 1/22 2/6 2/14
2/20 3/8 11/23 33/10 58/7
58/24 60/3 60/8 61/22 63/21
63/25 64/9 64/10 64/12 64/15
65/15 65/25 67/9 69/1 70/19
75/4
stricken [1] 80/1
strike [2] 72/10 79/24
string [1] 21/16
subject [3] 6/13 44/6 112/2
submission [1] 55/6
submit [3] 10/22 54/21 72/1
submitted [11] 10/16 15/9
16/11 25/25 25/25 30/2 35/6
35/16 37/4 44/14 56/25
submitting [1] 9/10
subpoena [3] 103/15 103/16
110/23
subscriber [18] 10/24 11/1
11/5 11/15 11/20 11/22 43/23
50/2 50/21 56/6 58/1 58/3
58/6 59/15 59/16 60/9 62/1
65/17
suddenly [1] 44/7
suffice [2] 45/11 48/4
Suite [8] 1/22 2/15 2/20 3/5
3/8 3/13 3/16 3/21
summer [1] 23/6
SUN [3] 2/5 11/16 33/12
superseding [1] 78/15
supervision [1] 116/12
support [2] 15/9 104/11
supporting [1] 89/7
supposed [2] 39/20 88/22
sure [2] 39/3 39/4
surveillance [4] 38/5 38/11
39/15 41/13
sustained [19] 9/19 12/17
12/24 13/4 13/13 16/2 37/17
43/4 43/10 47/10 79/23 80/11
82/4 94/20 95/9 95/11 107/2
107/6 107/10
SVW [1] 1/8
swallow [1] 91/6
switch [1] 34/7
sworn [1] 7/23
synthetic [3] 32/24 33/5
107/19
T
tab [4] 52/7 52/8 52/13
54/11
table [2] 28/2 29/4
take [18] 5/16 16/18 19/9
19/24 21/7 21/10 23/10 29/18
43/15 54/2 64/23 78/10 95/14
100/17 106/17 110/24 111/17
116/13
taken [2] 25/14 64/14
talk [1] 52/20
talked [1] 80/17
talking [4] 65/12 68/25 73/3
73/4
Tamara [2] 6/23 79/14
target [2] 6/13 45/10
task [5] 49/22 60/18 84/4
91/21 92/11
tasked [2] 91/14 92/19
tasks [1] 103/18
tax [12] 8/18 25/17 25/19
25/23 68/15 88/25 95/19 96/7
96/9 96/25 101/25 108/14
team [3] 74/4 74/10 74/13
tell [19] 8/6 14/1 14/11
14/14 15/18 21/14 24/5 24/10
28/3 53/11 63/9 63/11 72/25
82/7 83/25 84/3 86/24 100/14
115/8
telling [1] 105/14
TERABELIAN [10] 3/3 16/23
24/22 26/25 30/8 30/12 30/24
31/8 31/16 31/20
Terabelian's [4] 25/2 29/2
31/10 31/20
term [1] 54/12
terminology [1] 112/11
terms [2] 86/25 109/8
testified [9] 13/14 32/18
44/11 49/25 56/8 70/21 72/5
73/14 101/15
testify [5] 5/13 5/14 48/8
79/2 116/11
testimony [7] 49/10 55/18
61/3 62/7 62/12 66/5 93/2
than [6] 58/23 78/19 84/3
111/19 112/15 114/10
Thank [7] 7/18 7/21 66/21
70/16 73/8 111/1 113/6
that [389]
that's [5] 19/19 42/9 49/12
70/18 83/7
their [9] 12/7 12/12 12/22
13/15 14/8 90/15 104/15
113/14 114/1
them [16] 32/5 33/8 33/14
33/16 39/12 39/12 41/14
59/25 64/14 68/16 86/4 89/9
91/24 106/11 115/9 115/9
then [23] 32/5 34/2 38/24
49/7 54/1 64/24 67/21 67/24
79/1 85/12 85/19 85/20 87/1
87/6 87/19 87/21 90/4 98/9
105/23 111/13 113/4 115/11
115/18
theory [3] 112/24 113/20
114/4
there [60]
thereafter [1] 87/4
these [26] 14/6 23/20 32/2
32/4 35/13 40/5 48/12 49/7
51/2 64/8 64/11 68/22 79/9
86/4 90/20 91/13 101/6 101/7
103/14 103/17 105/4 105/11
105/15 106/8 106/8 106/21
they [38] 9/6 9/10 9/14 9/16
27/10 39/11 39/16 39/20
39/21 39/21 39/24 40/1 40/2
60/23 64/13 69/20 69/20 86/1
86/2 88/23 89/9 91/13 91/18
104/12 104/14 104/17 104/18
105/17 113/14 113/15 113/16
113/18 113/25 114/1 114/6
115/8 115/14 116/1
THIBODEAUX [2] 1/21 118/12
thing [6] 11/2 14/13 39/2
84/3 114/18 117/5
things [8] 5/11 84/11 84/12
89/15 91/5 92/3 112/10
113/15
think [24] 24/6 37/13 38/19
41/11 53/18 63/13 64/23
69/19 69/20 77/25 79/8 90/3
90/7 91/9 100/12 101/5
101/12 113/25 114/10 115/24
116/1 116/2 116/25 117/13
thirds [1] 46/24
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this [250]
Thomas [1] 3/14
thoroughness [1] 81/14
those [27] 10/9 10/12 10/18
13/9 15/2 25/17 37/20 38/11
38/12 38/17 39/18 40/21
41/13 41/18 50/6 60/8 71/3
71/18 74/13 74/18 85/21 86/2
87/22 92/8 97/21 107/15
115/4
though [1] 58/20
thought [2] 17/3 112/14
three [15] 27/21 29/6 35/6
44/6 46/16 64/8 64/11 90/10
90/11 90/12 90/17 97/5
105/23 114/13 115/13
through [14] 14/16 16/20
27/25 36/20 42/24 60/2 64/7
70/4 75/7 92/12 95/21 97/15
98/6 106/16
tht [1] 5/17
tied [1] 95/8
time [18] 5/16 8/11 9/10
28/14 32/6 56/23 57/1 86/5
89/13 92/15 107/13 107/14
111/5 111/17 115/4 115/17
116/12 116/16
Timeline [6] 8/21 15/20 19/7
19/9 44/13 87/14
times [4] 38/10 39/21 61/1
105/5
tired [1] 91/4
Title [1] 118/4
TLO [1] 16/20
today [1] 44/23
told [4] 84/10 84/17 85/6
85/9
too [2] 99/17 115/8
took [6] 29/11 36/3 36/4
66/16 89/13 111/25
top [24] 8/21 19/16 29/8
34/23 35/10 36/10 36/13
37/23 45/10 46/19 54/11
54/13 61/24 61/25 61/25
68/15 77/19 83/5 98/1 98/3
98/3 99/11 99/21 110/12
Topeka [7] 26/25 70/21 70/24
71/23 72/1 87/16 88/14
topics [1] 105/4
totality [1] 34/13
totally [1] 91/19
Totorian [1] 80/6
towards [1] 24/15
Tower [1] 2/20
TQ [2] 54/11 54/11
trace [2] 49/24 84/11
tracing [1] 86/17
training [1] 28/5
transaction [5] 20/25 21/8
21/17 21/25 94/7
transactions [9] 20/23 47/21
47/23 48/5 50/3 50/7 81/13
84/6 113/2
transcript [3] 1/13 118/6
118/7
Transport [6] 8/21 15/20
19/7 19/10 44/13 87/15
trash [8] 74/4 74/10 74/13
74/18 75/13 75/14 76/24 77/8
travel [12] 13/1 13/6 13/6
13/9 13/10 14/2 14/3 14/4
14/6 44/17 44/23 45/5
traveling [4] 14/5 14/12
14/15 14/18
TRIAL [1] 1/15
trials [1] 73/1
tried [3] 42/23 72/21 72/22
triggered [1] 116/25
true [1] 118/5
truth [1] 107/4
truthful [1] 81/16
try [4] 51/8 72/18 76/1 76/8
trying [2] 51/9 92/14
TUESDAY [2] 1/17 5/1
Turing [4] 20/2 20/16 45/3
45/6
Turks [1] 14/20
turn [4] 7/5 14/10 28/7
117/9
turned [1] 27/6
Twelfth [1] 2/6
two [9] 26/18 29/11 46/24
56/24 57/18 94/9 107/15
114/18 117/7
two-thirds [1] 46/24
type [5] 16/6 69/24 71/7
81/17 104/5
types [3] 48/12 92/2 103/14
U
U-turn [1] 117/9
U.S [3] 1/21 2/4 2/4
Ulia [40] 8/20 9/25 13/18
14/4 14/11 14/14 14/18 14/24
16/6 18/21 19/19 20/7 20/19
22/1 23/5 23/8 25/5 29/8
29/10 41/6 41/9 41/10 44/12
44/15 44/17 44/21 44/25
46/20 47/24 48/5 48/24 49/14
49/20 50/20 50/25 51/4 51/6
51/17 53/17 93/13
Ulio [14] 60/22 72/5 72/10
72/13 72/20 73/11 74/5 77/10
82/22 93/19 93/23 99/1 99/10
99/21
unconfusing [1] 113/9
under [10] 5/12 8/10 8/19
16/4 16/6 49/1 49/3 63/4
69/24 70/17
underneath [1] 55/8
understand [8] 38/22 39/4
48/9 87/24 91/15 101/4
104/22 107/7
understandable [1] 86/24
understanding [4] 75/16 84/9
85/11 86/25
understands [2] 39/1 39/5
Understood [1] 92/13
unfortunately [1] 53/11
unidentified [1] 40/11
uniform [1] 114/2
unit [1] 26/17
UNITED [7] 1/1 1/4 1/6 2/3
113/23 118/5 118/9
unrelated [1] 111/15
unsure [1] 113/15
until [2] 83/11 83/14
up [56] 5/16 19/5 24/16 34/5
34/8 34/23 35/1 35/10 36/13
36/20 40/24 42/13 42/14
43/24 44/5 45/8 45/10 45/21
51/3 51/20 52/1 55/23 56/22
57/21 58/2 59/1 60/2 61/11
61/19 61/24 62/18 63/1 63/19
64/6 65/10 65/18 70/14 76/17
77/25 82/5 89/13 90/25 91/7
91/23 95/14 96/10 97/4 99/23
102/17 105/20 105/23 107/12
107/22 109/10 110/12 112/1
upon [2] 21/24 116/6
us [7] 2/9 8/6 15/18 16/4
28/3 84/3 87/13
use [10] 12/6 12/12 12/22
84/18 84/20 112/4 112/5
112/6 112/7 112/8
used [41] 10/22 11/12 12/2
20/4 20/19 20/22 20/25 23/4
31/10 33/5 33/8 33/14 33/16
36/19 37/10 37/12 37/21 47/3
50/19 50/25 51/1 54/12 54/17
54/21 59/24 60/10 60/15
60/20 61/16 65/18 72/1 84/22
87/15 87/18 88/3 98/18 98/24
99/17 106/2 106/5 109/12
user [6] 47/6 49/1 53/17
58/16 63/2 69/24
using [4] 41/10 54/20 56/2
112/11
utilities [4] 25/5 73/15
73/17 73/20
V
vague [4] 33/2 95/3 95/8
107/9
VAHE [1] 3/18
Valley [3] 10/10 11/16 33/12
value [1] 50/11
Vardui [1] 24/22
various [5] 74/20 88/20
88/25 90/15 109/9
Vaughan [1] 3/7
Vegas [1] 116/16
Ventura [1] 117/7
versus [1] 113/23
very [12] 16/20 18/11 40/16
44/2 45/10 91/3 95/2 107/4
112/4 113/8 114/24 115/10
Victoria [2] 34/24 109/4
Victory [1] 18/2
video [2] 40/8 41/24
videos [16] 38/5 38/11 38/12
38/13 38/15 38/16 38/17
38/20 39/8 39/11 39/15 40/5
40/11 40/22 41/13 41/15
viewed [4] 38/11 38/12 38/16
38/20
Viktoria [22] 10/2 10/24
25/8 25/15 25/25 26/10 29/9
35/2 35/7 35/18 36/3 36/22
37/4 43/22 55/5 55/8 59/17
59/24 67/24 99/1 102/1
108/23
visit [5] 18/23 25/19 25/21
26/3 26/14
visited [2] 19/13 38/8
VKauichko.89 [1] 59/20
VLA [6] 62/15 63/16 63/23
66/3 66/7 66/14
voice [3] 43/24 72/15 90/25
voices [1] 91/7
VOLUME [1] 1/16
voluminous [3] 44/10 47/14
53/23
Vostanikyan [17] 96/3 96/23
97/2 98/13 99/8 99/15 100/5
101/6 101/16 102/8 104/2
105/3 107/12 107/25 108/17
109/2 110/10
Vostanikyan's [2] 107/19
110/18
W
Wait [2] 53/4 87/20
walk [1] 92/12
want [14] 5/16 7/4 11/2
42/12 43/8 44/5 51/12 61/13
62/6 81/14 115/4 115/7
115/16 116/25
wanted [2] 7/2 111/18
Warner [3] 34/17 34/20 34/21
warrant [3] 19/4 64/1 64/12
warrants [2] 26/20 88/12
was [195]
Washington [2] 2/10 2/23
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wasn't [13] 19/15 26/7 27/24
32/25 33/19 38/1 39/10 48/16
49/13 49/19 50/11 60/18 69/2
water [2] 23/12 25/4
way [2] 36/8 46/24
we [168]
Weddington [1] 11/23
week [1] 62/8
weeks [2] 29/12 35/6
weigh [1] 114/7
well [32] 8/18 9/17 9/23
13/22 17/14 19/22 20/10
24/12 26/14 32/5 35/21 37/13
39/5 39/6 39/16 42/12 43/7
48/2 51/10 52/16 58/5 74/16
76/5 77/2 85/1 91/17 100/21
101/8 106/14 115/10 115/16
115/23
went [8] 19/11 25/10 27/25
39/16 78/1 87/11 87/25 95/21
were [89]
West [3] 1/22 2/14 3/8
WESTERN [1] 1/2
what [184]
whatever [5] 40/14 50/11
76/15 79/8 114/6
when [33] 5/21 5/23 8/11
8/14 14/11 19/13 23/2 23/4
25/13 27/25 28/3 28/8 28/10
29/1 31/10 41/1 41/13 41/17
47/20 67/24 76/18 79/8 81/16
84/22 85/12 86/23 87/10
87/21 87/25 105/24 112/17
112/21 116/17
where [14] 8/7 9/2 10/8
14/18 49/24 58/10 60/23 85/1
85/2 85/2 87/5 88/21 94/24
116/19
wherever [1] 87/11
whether [19] 5/12 9/8 17/10
31/16 39/7 41/5 58/20 71/13
71/21 72/9 73/25 76/21 81/15
101/5 101/6 104/12 106/2
106/5 116/24
which [29] 5/15 16/20 21/18
25/25 26/23 26/25 27/20 36/2
46/16 49/20 58/2 60/14 60/15
60/17 60/19 60/20 61/19
63/11 84/6 84/23 84/24 85/7
85/20 85/22 87/17 88/13
98/23 106/18 115/17
Whitsett [3] 67/7 67/9 67/11
who [25] 15/22 16/1 18/15
23/7 24/12 25/4 32/7 39/11
39/18 45/25 63/11 68/17 71/8
71/12 71/21 72/12 72/22 73/5
73/10 73/12 80/23 89/2 90/13
106/24 114/15
whoever [1] 48/15
whole [2] 11/2 76/5
whom [2] 94/25 95/4
whose [3] 71/6 93/17 111/22
why [6] 17/10 22/9 66/10
72/16 93/12 104/9
wife [5] 58/13 58/20 64/16
68/11 94/12
will [30] 5/15 5/17 5/18
12/25 14/5 14/12 14/15 52/14
52/19 52/23 53/1 53/20 58/24
59/5 60/4 64/24 69/17 72/17
75/22 79/12 92/15 95/14
114/9 115/3 115/9 115/17
115/25 116/1 116/7 117/11
Williams [2] 3/4 3/7
WILSON [1] 1/3
Wirsching [1] 3/12
within [6] 10/12 11/8 11/17
11/24 21/4 101/2
witness [41] 4/3 7/23 17/7
17/8 22/13 23/16 27/17 30/19
32/6 32/6 34/19 45/21 47/8
51/21 59/2 61/12 62/8 64/6
75/8 76/1 76/9 76/11 79/8
82/6 94/22 96/10 97/5 99/24
100/23 102/18 103/1 105/21
106/13 107/23 109/16 114/9
114/15 114/17 114/20 115/12
115/21
witness' [1] 81/19
witnesses [4] 79/10 115/13
115/24 116/10
woman [2] 79/14 96/2
Woodland [2] 11/7 18/2
word [4] 33/3 33/4 106/2
106/5
words [8] 84/2 84/10 85/16
85/22 86/8 86/16 86/25 91/6
work [2] 8/7 8/8
worked [3] 42/7 42/17 81/3
working [1] 115/19
works [3] 42/4 42/11 80/6
worksheet [1] 102/11
worth [1] 92/25
worthwhile [2] 71/13 71/22
would [68]
wouldn't [4] 60/23 73/17
90/11 116/18
writing [1] 67/1
wrote [2] 83/21 109/21
Y
yahoo.com [1] 58/16
year [4] 14/17 40/19 40/20
83/4
years [3] 8/10 26/8 26/18
yes [334]
yesterday [1] 41/3
yet [2] 6/10 101/9
York [2] 2/10 2/18
you [488]
your [189]
yourself [1] 105/23
Z
Zhadco [22] 20/8 22/2 23/5
23/8 25/5 29/9 29/10 41/6
41/9 44/12 44/15 44/18 44/21
44/25 46/20 47/24 48/5 48/24
51/4 51/6 51/17 53/17
Zhadco 11 [1] 48/24
Zhadco's [6] 20/19 41/11
49/14 49/21 50/20 50/25
Zhadko [26] 8/20 9/25 13/18
14/4 14/11 14/14 14/18 14/24
16/6 18/21 19/20 48/15 72/6
72/11 72/13 72/20 73/11 74/5
77/10 82/22 93/13 93/23 99/1
99/10 112/25 113/2
Zhadko's [2] 60/22 93/19
Zhakdo [1] 99/21
Zindroski [1] 8/21
Zindroski's [1] 19/25
zoom [15] 37/20 46/23 48/3
55/1 55/2 66/25 67/5 67/12
67/13 77/12 98/1 98/9 99/5
110/12 110/15
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