Court filing
TRANSCRIPT filed as to Defendant Richard Ayvazyan, Marietta Terabelian, Artur… — USA v. Ayvazyan et al (Dkt. 676)
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. 676 · 2021-07-09 · Docket on CourtListener
Summary
A reporter's transcript of Jury Trial - Day Six, Volume 1, A.M. Session, in United States of America v. Richard Ayvazyan, et al., No. CR 20-579 SVW, held in Los Angeles on Wednesday, June 23, 2021 at 9:14 a.m. before United States District Judge Stephen V. Wilson in the U.S. District Court for the Central District of California, Western Division, and filed July 9, 2021 as Doc. 676. Counsel are listed for the Government and for each of the four named defendants. The index shows testimony resumed from a defense witness and direct and cross-examination of defendant Artur Ayvazyan, with an accompanying exhibit table. The opening records the court taking up defense exhibits offered with a 902.11 certificate outside the presence of the jury. The transcript is 170 pages and closes with a word index.
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 SIX
VOLUME 1 - A.M. SESSION
WEDNESDAY, JUNE 23, 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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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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I N D E X
WITNESS NAME PAGE
JUSTIN PALMERTON
Direct Examination by Mr. Ram (Res'd) 6
Direct Examination by Mr. Mesereau 31
Direct Examination by Mr. Johnson 39
Cross-Examination by Mr. Fenton 46
Redirect Examination by Mr. Ram 62
Recross-Examination by Mr. Fenton 67
ARTUR AYVAZYAN
Direct Examination by Mr. Mesereau 78
Direct Examination by Mr. Johnson 116
Cross-Examination by Ms. Ahn 118
EXHIBIT I.D. IN EVID.
23, 25, 41, 43, 44, 50, 75, 102, 103
5 5
15 6
18 10 11
74 11 12
112 25
59 29 29
300 58
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LOS ANGELES, CALIFORNIA; WEDNESDAY, JUNE 23, 2021
9:14 A.M.
- - - - -
(The following proceedings were held outside the
presence of the jury:)
THE COURT: We are present with the parties and
counsel. Thank you once again, members of the jury, for
being so punctual and attentive. It is appreciated by
all. We are ready to resume.
MR. RAM: Your Honor, I believe Mr. Palmerton is
still on the stand. As we call him into the room, the
defense would like to move to exhibit the following
exhibits that are accompanied by a 902.11 certificate.
THE COURT: All right.
MR. RAM: Defense Exhibits 23, 25, 41, 43, 44, 50,
75, 102, and 103.
THE COURT: Any objection?
MR. FENTON: As long as they are accompanied by a
902.11 certificate, no objection.
THE COURT: They are received.
(Exhibits 23, 25, 41, 43, 44, 50, 75, 102 and 103
marked for identification.)
MR. LITTRELL: Also, your Honor, the parties have
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agreed to an instruction before the witness testifies. I
think the Court has it before it.
THE COURT: You mean this piece of paper?
MR. LITTRELL: Yes, your Honor.
THE COURT: You have heard testimony yesterday
that Special Agent Palmerton testified about alleged
communication or contact between Manuk Grigoryan and
Marietta Terabelian. I have stricken that testimony.
You must disregard it.
Let's get the next witness.
THE CLERK: The witness is reminded he is still
under oath.
DIRECT EXAMINATION [RESUMED]
BY MR. RAM:
Q
Good morning, Agent Palmerton.
A
Good morning.
Q
I want to take a look -- we can put up just for the
witness's screen Defense Exhibit 15.
Agent Palmerton, just take a look at the
document and see if you recognize it.
Agent Palmerton, as part of your
investigation, did you look for publicly available
records for some of the business entities that were
involved in your investigation?
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A
Yes. Yes, we did.
Q
And was one of those business entities Mod
Interiors?
A
It was.
Q
Do you recognize Defense Exhibit 15 generally?
A
I mean, not off the top of my head. But I
recognize it. It is for Mod Interiors.
Q
Okay. And it is from the Contractors State License
Board of the State of California; is that right?
A
It appears to be, yes.
Q
And is it for the business Mod Interiors, Inc.
located at -- it is really small -- can we blow that up
for a second?
15928 Ventura Boulevard, Suite 224, Encino
California?
A
Yes, it is.
MR. RAM: Your Honor, I move to admit Defense
Exhibit 15.
MR. FENTON: Objection, your Honor. Lacks
authentication.
THE COURT: Sustained.
Q BY MR. RAM: Agent Palmerton, do you recognize this
to be a publicly available record from the website that
is depicted in the document?
MR. FENTON: Objection, your Honor. He already
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said he does not recognize it.
THE COURT: You can ask him again. I don't know.
Q BY MR. RAM: Agent Palmerton, the question is do you
recognize this to be of the type of documents that you
reviewed -- this is a government website, yes?
MR. FENTON: Objection, your Honor. Misstates the
document.
THE COURT: Well, he asked him -- I don't know.
If the witness knows, he can say. If he doesn't know, he
can say he doesn't know.
THE WITNESS: Yeah. I couldn't say for certain,
though.
Q BY MR. RAM: What website do you recognize it to be
from?
MR. FENTON: Objection, your Honor. He just said
he doesn't recognize it.
THE COURT: Do you recognize it or not or are you
unsure?
THE WITNESS: I am unsure. I don't see like a URL
that specifies where this is from.
Q BY MR. RAM: Have you heard of the Contractors State
License Board?
A
Yes, I have.
Q
What is that?
A
My understanding, it is a board that licenses
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contractors for the State of California.
Q
Okay. And as part of your investigation, did you
look up certain companies on that website?
A
Yes. I believe we looked up Hart Construction's
business license.
Q
And does this look consistent with what the other
companies' web pages would look like from the Contractors
State Licensing Board?
MR. FENTON: Objection. Calls for speculation.
THE COURT: Let him offer it and then make an
objection. He is trying to lay a foundation. He may be
successful or not. Are you offering it?
MR. RAM: Yes, your Honor.
THE COURT: Is there an objection?
MR. FENTON: Objection, your Honor. Lacks --
THE COURT: Sustained.
Q BY MR. RAM: Agent Palmerton, is this of the type of
record that you would expect to pull from the Contractors
State License Board?
A
It could be. I just I can't recall with
specificity if it is the same thing I looked at before.
Q
And did you look up whether Mod Interiors was a
real existing company on this website?
A
Not that I recall. But we did -- not myself, but
agents on the investigative team did go to this address
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to determine if this company existed.
Q
Okay. And are you aware from the document in front
of you that it expired January 1st, 2020?
THE COURT: You can't talk about the document
until it is in evidence.
MR. RAM: Okay. Your Honor, has there been a
sufficient showing --
THE COURT: There hasn't been.
MR. RAM: All right. Well, let's move on from
Exhibit 15 for now. Let's take a look just for the
witness at Exhibit 18.
Q
BY MR. RAM: First I will direct you, Agent
Palmerton, to the Bates stamp at the bottom right-hand
side of the page. Do you recognize that?
A
I do.
Q
And what is it?
A
Well, it looks like our production Bates stamps.
Q
Our being?
A
The government.
Q
Okay. So this is a document produced in discovery?
A
To the best of my knowledge, yes.
Q
Okay. And specifically, do you recognize the
company name? That is Choice Credit Repair.
A
I recognize it, but that is the extent of my
knowledge.
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Q
Okay.
MR. RAM: Your Honor, I move to admit Defense
Exhibit 18 into evidence.
MR. FENTON: No objection.
THE COURT: Received.
(Exhibit 18 was marked for identification.)
MR. RAM: We can come back to this document later.
I just wanted to put it up for you.
Let's take a look at just for the witness
Defense Exhibit 74.
Q
BY MR. RAM: Agent Palmerton, as part of your
investigation -- the universal you, the government -- did
you subpoena records from Venmo in general?
A
Yes, we did.
Q
And was a subset of those records for someone named
Anna Manukyan?
A
Yes.
Q
Do you recognize the spreadsheet on your screen,
who that is for?
A
Yes. It looks like a spreadsheet for Anna
Manukyan.
Q
From what platform?
A
Venmo.
THE COURT: What did you say, "ven" what?
MR. RAM: Venmo, your Honor.
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THE COURT: Venmo?
MR. RAM: Yes, your Honor.
THE COURT: What is Venmo?
THE WITNESS: My understanding is that it is a
financial platform that allows people to send funds back
and forth to each other. Kind of like a bank.
THE COURT: I heard the term Venmo. Is that a
common term? Maybe I am not modern. I have never heard
that before.
Q BY MR. RAM: Is it a company name, Agent Palmerton?
A
To the best of my knowledge, it is a company name.
THE COURT: Have you dealt with that entity
before?
THE WITNESS: Personally or?
THE COURT: Yes.
THE WITNESS: I have personally. Yes.
THE COURT: I see. Let's move on.
MR. RAM: Okay. I move to admit Defense Exhibit
74, your Honor.
THE COURT: Any objection?
MR. FENTON: No objection.
THE COURT: Received.
(Exhibit 74 was marked for identification.)
Q BY MR. RAM: All right. Now let's come back to your
testimony. Let's take a look at government Exhibit 10,
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page 30. Specifically, once it comes up -- I am going to
direct your attention to line 4288 when it comes up on
the screen.
Actually first let's show you the first page
of Exhibit 10 when we pull it up.
This has already been admitted into evidence.
It's government's Exhibit 10.
THE CLERK: Do you only want it displayed?
MR. RAM: For everyone. Thank you.
Q
BY MR. RAM: All right. Agent Palmerton, do you
recognize government Exhibit 10?
A
Yes. This looks like the text string between Rich
New and Tammy.
Q
And are you familiar with how government Exhibit 10
was compiled?
A
I mean, yeah. From the phone. 1B21, I believe.
Q
And how was it compiled from the phone?
A
My understanding, it was an export from the
Cellebrite report into this Excel format.
Q
And were you involved in that process in selecting
the messages that appear here?
A
I was not.
Q
Who was?
A
Other members of the investigative team.
Q
Do you know of anyone in particular?
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A
Not specifically.
Q
Okay.
A
Yes. I mean, possibly Agent Tim Massino.
Q
Are you speculating or do you know if Agent
Massino --
A
I don't. I guess I am speculating.
Q
Now, let's take a look at page 30 of this exhibit.
Specifically if I could direct your attention to -- I am
going to blow it up for you -- 4288.
Specifically 4288, it's from a Tammy, and it
says, "Should I have Art call Wells tomorrow to order
checks from this account too?" Do you see that?
A
Yes, I do.
Q
Did you investigate Artashes Martirosyan in this
case?
A
No. No, we did not.
Q
Are you aware that Artash Martirosyan engaged in
loan fraud?
MR. FENTON: Objection, your Honor. Lacks
foundation.
MR. RAM: Your Honor, the first question was about
this case. He said no.
THE COURT: He didn't investigate it, and then you
might ask him did he ever investigate this Artash
whatever his name is.
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MR. RAM: Yes.
Q
BY MR. RAM: So the first question is -- I think
you answered, no, you did not investigate Artashes
Martirosyan in this case; correct?
A
No, not to the best of my knowledge.
Q
Okay. And are you aware of any connection between
Artash Martirosyan and Tamara Dadyan prior to March 2020?
A
No.
Q
Okay. You did review bank records in this case,
though, didn't you?
A
I did.
Q
All right. Well, are you aware of any bank records
evidencing payments from one of the synthetic identities
discussed in this case to Artashes Martirosyan?
MR. FENTON: Objection, your Honor. Vague.
THE COURT: Overruled.
Q BY MR. RAM: Do you understand the question, Agent
Palmerton?
A
Could you repeat it, please?
Q
Of course. So I asked you are you aware of any
bank records evidencing a payment from one of the
synthetic identities alleged in this case to Artashes
Martirosyan?
A
No. Not that I recall.
Q
All right. Why don't we take a look at what has
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been admitted as government Exhibit 105 at page 138. And
we can pull that up on the screen.
It is already in evidence.
Why don't we go to the first page first so you
can see what it is. Good call.
Okay. Agent Palmerton, do you generally
recognize what this document is?
A
Yeah. It looks like a signature card for Diana
Sakyan for Bank of America.
Q
Diana Sakyan, and you understand that name to be
one of the synthetic identities alleged in this case?
A
Yes.
Q
Now, let's about to page 138 of that exhibit. We
can scroll back a couple of pages if you want to see what
this particular bank statement is.
Okay. For the record we are on page 135. It
is the start of a bank statement.
Do you see that, Agent Palmerton?
A
Yes.
Q
Which bank statement month is this and who is it
for?
A
This is from December 7, 2019 to January 8, 2020,
and it appears to be for Diana Sakyan.
Q
And once again, the allegation in this case is that
person is not real; is that right?
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A
Yes.
Q
Now, let's go to page 138, which is later on in
this same statement. And we will go specifically to a
transaction for December 23rd, 2019.
MR. FENTON: Objection, your Honor. This is --
relevance. This is outside the relevant time period.
THE COURT: Sustained.
MR. RAM: The relevant time period, your Honor?
THE COURT: Sustained.
Q BY MR. RAM: So let me just ask generally. Prior to
March of 2020, the question I asked you earlier, you said
you are not aware of any payment between Diane and
Artashes Martirosyan; is that right?
A
Prior to 2020?
Q
Prior to March of 2020.
A
No.
Q
Does this refresh your recollection?
A
Yes, it does.
Q
Okay, and was there in fact a payment?
MR. FENTON: Objection, your Honor. Relevance.
THE COURT: Sustained.
Q BY MR. RAM: Did you investigate whether individuals
connected with Tamara Dadyan were receiving payments
prior to March 2020 to some of the same entities and
individuals alleged in this case as being synthetic?
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MR. FENTON: Objection, your Honor. Relevance.
THE COURT: You can answer "yes" or "no."
THE WITNESS: No. No, we did not.
Q BY MR. RAM: Okay. Thank you. Now, let's look at
government Exhibit 10, still page 9.
Page 9, Exhibit 10. Specifically I will
direct your attention to line 2930.
Blow up the text around there.
Let's look there first.
On 5/28/2020 at line 2930, Tammy says, "Bro,
Arshak called BOFA." Is that Bank of America? Do you
understand that?
A
Yes.
Q
"Arshak called BOFA. They released our hold";
right?
A
Yes.
Q
Now, if we can go to page 15, same exhibit. I will
direct your attention to line 3280.
Okay. Tammy says, "Arshak to send to Lendio.
The guy texted him yesterday hat whatever I sent you was
from Lendio not the Evergreen. No e-mails for Armin."
Do you see that?
A
Yes.
Q
Okay. Now, let's take a look at line 3844, which
is much later on. Okay. In fact, instead of wasting
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time, those two references we just read, those were to
Arshak; correct?
A
Yes.
Q
Did you investigate Arshak Hartunian and his
relationship to Tamara Dadyan in this case?
A
No. Not that I recall.
Q
And are you aware of any transactions between
Arshak Hartunian and Tamara Dadyan or any of the
synthetic identities in this case prior to March of 2020?
MR. FENTON: Objection, your Honor. Relevance.
THE COURT: You can answer "yes" or "no."
THE WITNESS: No.
Q BY MR. RAM: Now, let's take a look at page 24 of
same government Exhibit 10. And I will direct your
attention to lines 3893 to 3895.
Actually if we can get just a few more of the
text messages when you blow it up, starting with the
screenshot.
There we go.
Okay. So on 3893, this is on July 21, 2020,
"Tammy, what is a payroll register?" "Tammy, is it the
form Greg gave us or the payroll report from Gusto?"
Do you see that?
A
Yes.
Q
In relation to the text message that we just read
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from this phone, did you investigate Grigor Tatioan in
this case? And that is spelled T-A-T-I-O-A-N.
MR. FENTON: Objection. Lacks foundation.
THE COURT: Overruled.
Q BY MR. RAM: You can answer the question
A
No.
Q
And did you review evidence that Grigor Tatioan
engaged in any transactions with Tamara Dadyan prior to
March of 2020?
MR. FENTON: Objection. Relevance.
THE COURT: Overruled.
THE WITNESS: No.
Q BY MR. RAM: All right. Now let's take a look at
Exhibit 18, which is already in evidence.
No, no. Sorry, government Exhibit 18.
Do you recognize what is depicted in
government Exhibit 18 that is in evidence?
A
Yes. This looks like 1B85, which is a phone we
seized from 4910 Topeka.
Q
And was it the phone ending in 6000, if you
remember?
A
I believe so, yes.
Q
We heard previously that Exhibit 19 contains images
from the 6000 phone, just to speed this up. I can pull
up Exhibit 19 for you, which is already in evidence.
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That is the Cellebrite report; right?
A
Yes, containing user information.
Q
Okay. And now, did the -- and now what we are
showing is Exhibit 19B. Is that an image on the 6000
phone?
A
Yes, I believe so.
Q
Okay. Did the FBI conduct a forensic analysis to
determine if the image we just saw at 19B and the others
on the 6000 phone were uploaded to the phone from an
iCloud account or through a text message, for example?
A
No. No, I don't believe so.
Q
Okay. Now, let's look at 19B1, which should be the
next page.
Okay. Do you recognize who is depicted in the
photo there?
Just pause it there. Page 1 still.
Do you recognize who is in that photo, Agent
Palmerton?
A
Yes. Anna Manukyan.
Q
And are you aware that this image was texted
several years prior to 2020?
MR. FENTON: Objection. Foundation.
THE COURT: Sustained.
Q BY MR. RAM: Did you try to determine when the image
was texted to the phone?
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A
I didn't know it was texted to the phone.
Q
Okay. And that is because you didn't do the
forensic analysis; is that right?
A
I didn't do it. The FBI did not.
Q
The FBI did not?
A
No. Not to my knowledge, no.
Q
Okay. Did you or the FBI attempt to obtain
metadata regarding the image on the phone?
MR. FENTON: Objection, your Honor. Vague with
respect to metadata.
THE COURT: Sustained.
Q BY MR. RAM: What do you understand the term
metadata to mean, Agent Palmerton?
A
It is basically the underlying data for an image to
include, like the date, time the photo was taken or
possibly the geolocation of where it was taken.
Q
And did the FBI attempt to obtain metadata for the
image we see on the screen at 19B1?
A
My understanding is this photo should have had the
metadata on it. It should have been included with it.
Q
Was it?
A
It should have been, yes.
Q
And where would we see the metadata if it existed?
A
In the property section of the photo.
Q
Okay. And that would be in the Cellebrite report?
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A
It should have been. Yes.
Q
Okay. We can go back to the Cellebrite report if
that would help. That was Exhibit 19A, I believe.
Was that the report you were referring to?
A
Well, this is the user information for the phone,
not necessarily the metadata for that photo.
Q
Do you know if the government has introduced in
evidence in this case the Cellebrite report that would
contain that data?
A
Yes.
Q
Where is that?
A
I'm sorry. I am not -- what do you mean?
Q
The question was is that in evidence in this case?
Do you have an understanding if the government submitted
that in evidence to the jury?
A
Yes. Yes, we did.
Q
Okay. And where is that?
MR. FENTON: Objection. Vague.
THE COURT: Where is that meaning what exhibit
number?
MR. RAM: Yes. What exhibit number would that be?
THE COURT: If he knows, he can say. If he
doesn't, he doesn't know.
THE WITNESS: Yeah, I don't know what the exhibit
number is or was.
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Q BY MR. RAM: Okay. And you are the lead case agent
on the case; is that right?
A
Yeah, the lead FBI case agent.
Q
Did you help with the trial preparation?
A
I did.
Q
Did you help identify exhibits that will be
provided to the jury at trial?
A
Yes.
Q
And are you sure that that Cellebrite report that
would contain the data you referenced is in evidence?
MR. FENTON: Objection. Asked and answered.
THE COURT: He can answer it one more time, "yes"
or "no."
THE WITNESS: Yes.
Q BY MR. RAM: Yes, you are sure?
A
Fairly certain. Yes.
Q
Now, let's take a look at the second page of
Exhibit 19. Exhibit 19B, I believe.
Do you recognize these documents on the
screen?
A
I do.
Q
Do you know why this driver's license and Social
Security number were sent to the phone?
A
I don't. I didn't know it was sent. I just saw it
on the phone.
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Q
And did you investigate who Grigor Paronyan is?
A
I believe we did some initial steps because we
honestly didn't get the Cellebrite report until not that
long ago. So the initial steps would have included some
open source research into Grigor Paronyan, but I don't
recall any specifics.
Q
Okay. Let me show you just for you, to help you
with some of the specifics, defense Exhibit 112. If we
could just show it to the witness for identification.
Take a look at that and look up when you have
finished reviewing it.
A
Okay.
Q
All right. Now, putting away that document, taking
it off the screen.
Did you determine if there was ever a PPP loan
application submitted in the name of Grigor Paronyan?
A
No.
Q
No, no. Meaning did you inquire?
A
Yes. Yes, I did, per that e-mail.
Q
And the answer is?
A
No.
Q
There was never an application submitted; right?
A
It doesn't appear so.
Q
All right. Now, let's take a look at -- actually
before we go to the exhibit, as part of your
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investigation, you were aware that Richard Ayvazian was
out of the county on October 14th, 2020?
A
Yes. In Turks and Caicos.
Q
And take a look at what has been admitted as
government Exhibit 1R at page 15. And this is for
everybody. It has already been admitted.
Oh, yeah. Let's look at first page first.
Sorry. Okay.
What do you see at government Exhibit 1R on
the first page? We can blow it up for you.
A
Again, this is a signature card from Chase Bank for
a bank account in the name of Iulia Zhadko.
Q
Is that the bank account ending in 5268?
A
Yes, it is.
Q
Okay. Let's scroll through to page 15.
THE COURT: Ask him what he did or didn't do.
Let's not review the evidence through him unless you are
making a point that I am not aware of.
MR. RAM: I am about to, your Honor. I am going
to direct him to a specific transaction. That is what I
am doing now.
THE COURT: Ask him whether he investigated or not
and make your argument at the right time.
MR. RAM: Correct. Yes, your Honor.
Q
BY MR. RAM: So take a look at page 15 we have up
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on the screen for government Exhibit 1R.
A
Okay.
Q
All right. Do you see -- let me blow this up where
it says ATM and debit card withdrawals.
A
I do.
Q
Can we blow that up? All right.
And what is the October 14th transaction in
this account for Iulia Zhadko ending in 5268?
A
It is a card purchase for Lamps Plus for $875.99.
Q
And what is that information next to where it says
Lamps Plus. There is, it looks like, a phone number and
a state?
A
Phone number and the state and then a code 55-46.
Q
And did you investigate whether this transaction
occurred where Lamps Plus is located in California?
A
Yes.
Q
And what did you determine from your investigation?
A
This purchase was actually initiated on August 21,
2020.
Q
And was that initiated in the store?
A
Based on the investigation, it sounded like it was
entered manually. And the individual I spoke with
thought that it was entered in over the phone. Like
there was not a swipe. It was manually entered into a
terminal.
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Q
So your testimony is that the transaction did not
occur in the store?
A
I don't know if it did or not.
Q
Okay. Now, let's take a look at Defense Exhibit
59 -- actually it is not in evidence yet, so just for the
witness.
I'm sorry, actually let's go back to the last
exhibit, specifically Exhibit 1R at 15.
And you said you spoke to the store clerk; is
that right?
A
It wasn't the store clerk. It was -- she was an
executive at the Lamps Plus headquarters.
Q
And when you asked about the code 55-46, did she
specifically tell you that she could not determine if it
was conducted in the store?
A
Yes. She couldn't determine. All she could say is
that it was punched in manually. And she thought that it
likely would have occurred over the phone as if somebody
would have called in and punched in the credit card as it
was being read over the phone.
Q
But she didn't know one way or the other?
A
She did not.
Q
And that code is consistent with both an online and
a store transaction; is that correct?
A
It is. Yes.
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Q
Now, let's take a look at the next exhibit. Just
for the witness, Defense Exhibit 59. You testified
yesterday that you were the lead FBI agent investigated
in this case?
A
Yes.
THE COURT: You have said that a number of times.
Ask a question.
Q BY MR. RAM: And in your role as the lead
investigator, did you review evidence seized from the
Canoga apartment?
A
Yes.
Q
Take a look at Exhibit 59 on your screen. Do you
recognize the document?
A
Yes. This looks like one of our receipts for
properties for the 6150 Canoga search warrant.
MR. RAM: Your Honor, I move to admit Exhibit 59.
THE COURT: Is there an objection?
MR. FENTON: Let me just take a look at it.
No objection.
THE COURT: Received.
(Exhibit 59 was marked for identification.)
MR. RAM: May I publish to the jury, your Honor?
THE COURT: Yes. I don't think it is coming up on
the screen.
MR. RAM: There we go.
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Q BY MR. RAM: Agent Palmerton, I want to you describe
to the jury what this is.
A
So it is a receipt for property that we -- I mean,
in the search warrant we fill out this receipt for
property basically detailing the items we seized during
the search warrant. And we leave a copy with somebody.
If there is somebody present, we even have them sign it.
Otherwise in this instance there was no one
there so we just left it as not present. But it is
essentially detailing what we seized pursuant to the
search warrant.
Q
Okay. Take a look at page 3. If you can scroll
through.
Okay. Let's pause there.
Do you recognize what this document is?
A
Yes. It looks like a EDD document for Aro
Agakanyan.
Q
Let's scroll through the remaining pages.
So on page 4, does that relate to the same EDD
pandemic benefits claim?
A
It appears to be.
Q
Page 6. The next page, and next page.
Okay. Did you investigate why there were EDD
pandemic benefit documents at the Canoga address?
A
No. Not specifically. We were focused on PPP and
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SBA loan fraud.
Q
Did you uncover any evidence of EDD fraud at the
Canoga address other than this document?
A
No. No, not that I recall.
Q
Did you look for any?
A
For EDD fraud?
Q
Yes.
A
No.
Q
Okay.
MR. RAM: No further questions, your Honor. I
believe there are other defendants who would like to
question the witness.
THE COURT: All right.
DIRECT EXAMINATION
BY MR. MESEREAU:
Q
Good morning, Mr. Palmerton.
A
Good morning.
Q
My name is Tom Mesereau and I speak for Artur
Ayvazian. Did you conduct a search at 17450 Weddington
Street in Encino, California?
A
I did not personally conduct that search.
Q
Were you in charge of that search?
A
I was not.
Q
Were you involved with it at all?
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A
I was involved in part.
Q
Which part were you involved in?
A
That would have been giving Special Agent Madison
MacDonald responsibilities for that location.
Q
So you basically determined who was going to search
the house; correct?
A
No. That was Special Agent Madison MacDonald.
Q
Did you tell Agent MacDonald what to look for?
A
I provided her and her team copies of the search
warrant and the attachment that listed the items that
were to be seized.
Q
And did you yourself do any investigation into who
owned that residence?
A
Yes.
Q
And isn't it true that when that residence was
searched, Tamara Dadyan was the sole owner of that
residence?
A
If I recall -- I don't think Tamara Dadyan was the
owner of the residence. I thought it was in a trust name
that we were actually unable to determine if that person
existed.
Q
But you certainly didn't find any information
suggesting that Artur Ayvazian owned that home; correct?
A
Aside from like IP address that placed Artur
Ayvazian as a subscriber that came back to that address,
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nothing I can recall specifically.
Q
You never saw any deed or certificate of ownership
that suggested Artur Ayvazian owned that residence;
correct?
A
No. Nothing I recall.
Q
Okay. Now, there was an office in that residence;
correct?
A
I believe so. Yes.
Q
And you wanted that office searched; correct?
A
I wanted the residence searched.
Q
But you certainly wanted that office searched;
correct?
A
Prior to the search, I did not know if there was an
office in that residence or not.
Q
But you learned at some point there was one office
in that residence; true?
A
Subsequent to the search.
Q
And on the door of that office, the only office in
the residence, was a business certificate for Secureline
Realty & Funding, Inc.; right?
MR. FENTON: Objection, your Honor. The witness
has testified that he didn't go to that search site.
THE COURT: Objection. Sustained.
Q BY MR. MESEREAU: Did you have any role in any
document examination of documents found that location?
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A
Yes. Subsequent to the search, yes.
Q
And when those documents were reviewed, was it your
understanding that documents came from various rooms of
the house?
A
Yes.
Q
And did you examine documents that were purportedly
found in the sole office in the house?
A
Yes.
Q
And those were primarily real estate-related
documents; correct?
A
I couldn't say if there was a majority of real
estate documents or a majority of PPP and what appeared
to be synthetic identity documents.
Q
You didn't see a lot of documents for a towing and
transport company, did you?
A
We saw some documents, though.
Q
You saw some, but you didn't see very many at all;
correct?
MR. FENTON: Objection, your Honor. Vague.
THE COURT: Sustained.
Q BY MR. MESEREAU: The majority of the documents in
that office were real estate-related; true?
MR. FENTON: Objection, your Honor. Asked and
answered.
THE COURT: Sustained.
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Q
BY MR. MESEREAU: Did you investigate to determine
if Tamara Dadyan was a licensed real estate agent?
A
Yes. And I think we determined her license was
suspended.
Q
And did you ever determine how long she had had a
real estate license?
A
I think at some point I did know, but I don't
recall it now.
Q
Did you investigate whether Artur Ayvazian ever had
a real estate license?
A
No.
Q
You didn't check that out?
A
No.
Q
Okay. Now, when agents went into the home, do you
know what time of day it was?
A
It would have been approximately 6:00 a.m.
Q
And people in the home were sleeping when the
agents went in; correct?
A
I don't know if they were sleeping or not.
Q
Do you know whether or not Artur Ayvazian and
Tamara Dadyan were in separate rooms?
MR. FENTON: Objection, your Honor. The witness
has testified that he was not at the search site.
THE COURT: Well, it may have been reported back
to him. I don't know.
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THE WITNESS: The only report I received was that
Tamara and Artur were at the residence. I don't know if
they were in separate rooms or not.
Q BY MR. MESEREAU: Did you ever determine whether or
not Tamara Dadyan and Artur Ayvazian filed separate tax
returns?
A
No.
MR. FENTON: Objection. Relevance.
THE COURT: Overruled.
Q BY MR. MESEREAU: Well, you certainly were
investigating any business relationship that might exist
between Artur Ayvazian and Tamara Dadyan; correct?
A
Yes. We were following the flow of funds, the flow
of money.
Q
But you didn't check to see whether they filed a
joint return or separate returns; correct?
MR. FENTON: Objection, your Honor. Asked and
answered.
THE COURT: Sustained.
Q BY MR. MESEREAU: And you said you found some
documents related to Allstate Towing and Transport;
correct?
A
Yes. I believe so.
Q
Did you ever check to see who paid taxes or filed
tax-related documents on behalf of Allstate Towing and
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Transport?
A
You mean like federal, state or local taxes?
Q
Any of them, sure.
A
I mean, we reached out to the IRS for fact of
filing and determined that there were no federal taxes
paid, I believe, for Allstate Towing and Transport.
Q
Did you investigate Allstate Towing and Transport
Company to see if it was a real company?
A
Yes.
Q
And did you investigate whether or not Artur
Ayvazian owned a truck?
A
Yes.
Q
And he did own a truck; correct?
A
He did.
Q
And on that truck, it said Allstate Towing and
Transport; correct?
A
I don't know I --
MR. FENTON: Objection. Foundation.
THE COURT: He is asking the question. The
witness can answer yes, no, I don't know. I can't tell
the witness how to answer.
Q BY MR. MESEREAU: Did you ever look to see if that
truck that Artur Ayvazian owned said Allstate Towing and
Transport on the truck?
A
No. I only reviewed DMV records that showed that
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Mr. Ayvazian owned the truck.
Q
Did you determine whether or not Artur Ayvazian and
Allstate Towing and Transport had a certificate of
liability insurance?
A
No, I don't believe so.
Q
Okay. Did you determine whether or not Artur
Ayvazian had a commercial driver's license?
A
Yes, we did.
Q
And did he have one?
A
He did.
Q
Did you determine whether or not Artur Ayvazian had
a motor carrier permit from the Department of Motor
Vehicles?
A
I can't recall.
Q
But you did investigate DMV records; correct?
A
Yes, we did.
Q
And what you found was consistent with Artur
Ayvazian owning a trucking company; correct?
A
Yes.
Q
And what you saw was consistent with Artur Ayvazian
being a truck driver himself; correct?
A
Yes.
Q
Did you investigate to determine whether Artur
Ayvazian as a truck driver had submitted to required drug
testing?
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MR. FENTON: Objection, your Honor. Relevance.
THE COURT: Sustained.
Q BY MR. MESEREAU: And did you check California
Secretary of State records to see if Allstate Towing and
Transport, LLC had filed the required documentation?
MR. FENTON: Objection, your Honor. Vague with
respect to required documentation.
THE COURT: Let's make the question "any
documentation."
MR. MESEREAU: Yes, your Honor.
THE WITNESS: Yes.
Q BY MR. MESEREAU: And did you find that articles of
organization had been filed with the California Secretary
of State by Allstate Towing and Transport, LLC?
A
Yes, but I can't recall the dates.
Q
Okay.
MR. MESEREAU: No further questions, your Honor.
DIRECT EXAMINATION
BY MR. JOHNSON:
Q
Good morning, agent. I represent Vahe Dadyan. I
just wanted to be clear. There were several searches
that you were talking about during this investigation;
right? Searches of homes.
A
Yes.
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Q
And none of those homes that you were referring to
was a search of Mr. Vahe Dadyan's home at 1004 East
Garfield Avenue, Apartment 4?
A
No.
Q
And I would like to ask you some questions about --
did you confirm that the PPP application in the name of
Voyage Limo actually was the same address as Vahe Dadyan?
A
I believe it was.
Q
And you confirmed that Mr. Vahe Dadyan lived at
1004 East Garfield Avenue in Apartment 4; correct?
A
Yes. Myself and Agent Clark went to Mr. Dadyan's
apartment to deliver a subpoena. He wasn't there, but I
believe it was his girlfriend or wife at the time
confirmed that he did live there.
Q
And did you do some research about who else lived
there?
A
Aside from seeing what I believe was his wife or
girlfriend, that was the extent of it.
Q
Okay. I would like to ask you some questions about
a company called Runyan Tax. Are you familiar with that
in this investigation?
A
I am.
Q
There is a website that was referred to in some of
those text messages as www.Runyantax.com.
During your investigation, did you visit that
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site?
A
I can't recall or I don't remember.
Q
Also, there is a Bank of America account related to
Runyantax.com in this investigation. Are you familiar
with those records?
A
There is a Runyon Tax Services Bank of America
account. Yes.
Q
And that the bank account is -- I guess the
signature on that bank account was the name Victoria
Kauichko. I hope I am saying the name correct.
A
I believe so, yes.
Q
Okay. Why don't I show you Exhibit 1P.
Does that look familiar to you?
This is already in evidence.
A
Yes, it does.
Q
I would like to move to page 3 of that document.
Down at the bottom this is a record that would
indicate that someone opened that bank account; correct?
A
Someone opened the bank account and then -- using
the name Victoria Kauichko.
Q
Yes. And that is a physical signature; correct?
A
It appears to be so.
Q
During your investigation did you or the FBI go to
Bank of America to determine who signed that in Bank of
America?
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A
We didn't go to Bank of America in person, no.
Q
Did you check any video camera that may have
existed in Bank of America to determine who physically
signed that document?
A
Not that I recall specifically. I know we
requested video footage. I can't recall if we did
anything specifically for this signing.
Q
So at this point, you had no video or photograph
evidence from Bank of America to determine who opened
that account?
A
No, we don't.
Q
Would it be fair to say that a person, somebody,
walked in Bank of America and signed that document?
A
I mean, it is possible it is in person. I mean, it
could be digital as well.
Q
When I look down at the bottom, there is a B of A
document number down at the bottom corner and a DOJ
document number. Do you recognize those numbers?
A
Yes. I believe those are our Bates numbers for
this document.
Q
When you say our Bates numbers, those are Bates
numbers or document numbers that were produced by the
government; correct?
A
The government, and yes, Bank of America.
Q
The government and Bank of America. And when you
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say "our," that is the FBI and the Department of Justice
here sitting at this table?
A
The investigative team. Yes.
Q
Thank you. I would now like to talk to you about
the investigation of Tamara Dadyan at her Weddington
home. Are you familiar with that?
A
Yes.
Q
And are you familiar with the evidence that was
seized from that home?
A
Yes.
Q
And part of the seized evidence were a series of
driver's license; correct?
A
Yes.
Q
Driver's license that were not in Tamara Dadyan's
name; correct?
A
Yes. They were all either fake or synthetic
individuals.
Q
When you say fake, that would mean taking the
identifications of some people and manufacturing
identifications; correct?
A
Correct.
Q
And these would be victims of identity theft;
correct?
A
I mean, without getting too legal -- I guess I
don't know.
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Q
Okay. So you do investigate identity theft for the
FBI; correct?
A
Yes.
Q
And part of the investigation into going into
Tamara Dadyan's house was allegations of identity theft;
correct?
A
Yes.
Q
And synthetic identities are -- why don't you
explain to us what these synthetic identities are.
A
So my understanding of what a synthetic identity
is, it is an identity that has been created or
manufactured generally using various people's information
to include -- in this instance what we saw were name,
date of birth and Social Security, and then there were
driver's license created with that information but
utilizing somebody's face, an address, height, weight,
eye color, hair color.
Q
And tell us what these fake identifications are. I
guess there is a distinction between synthetic and fake.
A
Right. So I suppose what I meant by fake was the
driver's licenses were fake, and we requested from the
DMV records just to determine if these actually existed
or were real, but the DMV came back and told us that, no,
they were in fact not real.
Q
Were the pictures that were depicted in some of
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these identifications real -- of real people?
A
Yes. To the best of my knowledge.
Q
Were you able to determine who the pictures -- who
the people depicted in those pictures were?
A
No.
Q
Did you try -- did the FBI try to determine who the
pictures -- who these people are in these pictures?
A
You mean like did we submit their photos for like
facial recognition?
Q
Absolutely?
A
No. No, we did not.
Q
And why not?
A
At the time we didn't need to.
Q
Why don't I show you Exhibit 57B at page 8.
Just one moment, please.
Okay. Do you recognize these photos as photos
that were seized from Tamara Dadyan's home during the
search in November 5th, 2020?
A
Yes.
Q
Do you recognize anyone in those photos?
A
The one in the upper left to me appeared to be
Tamara Dadyan.
Q
Those individuals that are depicted in there, do
they appear to you to be real people?
A
They do. Yeah.
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Q
And were those people in your view part of the
documents that were depicted in fake identifications?
A
I mean, off the top of my head, maybe one or two of
them I saw as represented in some of the driver's
licenses we seized.
Q
And it didn't occur to the FBI to determine whether
any one of these people might be victims?
A
No. Not at the time.
Q
And the FBI didn't look into any database to
determine whether the facial recognition of these
individuals, they might be victims?
A
Well, facial recognition is -- I mean, to say the
least, it's not -- sometimes it just doesn't work.
Q
But it would never work if you never try; isn't
that correct?
A
I suppose so. Yes.
MR. JOHNSON: I don't have any further questions.
THE COURT: Okay.
CROSS-EXAMINATION
BY MR. FENTON:
Q
Good morning, Special Agent Palmerton.
A
Good morning.
Q
Approximately when did you begin investigating PPP
and EIDL loan fraud?
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A
June of 2020.
Q
And as part of your investigation over the course
of the last year, did you investigate all of the eight
defendants named in the first superseding indictment?
A
Yes, I did.
Q
And can you describe for the jury some of the
investigative steps that you took as part of your
investigation?
A
Yes. So open source research, requesting records
from banks, financial institutions, government entities
working with other agents, interviews, search warrants,
trash pulls, a variety of other things I can't recall.
Q
Let's talk first about documents. You said that
you requested documents from financial institutions and
other places as well; correct?
A
Yes. Financial institutions, mobile service
providers, IP providers.
Q
Approximately how many subpoenas were served in
this case?
A
I believe well over 500.
Q
And how many loan files did you review in
connection with your investigation?
A
Hundreds.
Q
And how many bank records did you review in
connection with this investigation?
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A
Hundreds as well.
Q
Did you look into -- did you subpoena telephone
records?
A
Yes.
Q
What telephone records did you subpoena?
A
Telephone records associated with a number of the
loans.
Q
With the telephone numbers that are listed in the
loans?
A
Yes.
Q
And were you able to link those telephone numbers
to some of the defendants?
A
Yes.
Q
Did you look at IP address information?
A
Yes.
Q
What did you find?
A
We found that in certain instances the IP addresses
came back to, in one instance subscriber records, as I
mentioned before, in the name of Artur Ayvazian,
subscriber records for Victoria Kauichko, and then also
some of it came back to VPNs.
Q
Do you recall approximately how many subpoenas you
served requesting IP address information?
A
I can't recall but it would have been dozens.
Q
And why is IP address information relevant to your
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investigation?
A
Well, IP address or Internet protocol is generally
something that is assigned to a device. And so to figure
out who the IP address was subscribed to or belonged to
would help us determine who in this instance may have
submitted a loan.
Q
But getting IP address information is not the only
way to make that determination; correct?
A
No, no. You can follow the money.
Q
So tell us about that. What did you do to follow
the money?
A
Yes. So in this instance, I mean, as I said
before, we reviewed hundreds of bank records, and we were
trying to figure out who was behind submitting these loan
applications. They appeared to be behind synthetic
identities.
And the one that comes to mind for me was
Iulia Zhadko. That was one of the initial individuals or
synthetic identities we were looking into.
So in one instance we requested records. We
saw that a fraudulent loan was deposited into an account
at Timeline Transport at Radius Bank. From there I saw a
$110,000 wire transfer to an escrow company.
I reviewed records for that escrow company and
determined that $110,000 wire transfer was going to be
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used to purchase 4910 Topeka, in the name of Richard
Ayvazyan and Marietta Terabelian.
There was an e-mail that appeared to be from
Richard Ayvazyan directing --
MR. RAM: Objection, your Honor. Move to strike.
Hearsay. He is referring to an e-mail that was not in
evidence.
MR. FENTON: Your Honor, that e-mail is in
evidence.
THE COURT: Then if it is, the objection is
improper. It is overruled.
MR. FENTON: I would ask the witness to continue
his answer.
THE WITNESS: That home was purchased in the name
of Richard Ayvazyan and Marietta Terabelian. So that was
my first connection that Iulia Zhadko was Richard
Ayvazian using the alias Iulia Zhadko.
MR. RAM: Objection, your Honor.
THE COURT: On what ground?
MR. RAM: He is giving his opinion.
THE COURT: That is what you asked him to do.
MR. RAM: And I wasn't allowed to, your Honor.
THE COURT: Well, you did ask him questions about
his opinions. And what this questioning is about, I take
it, is to allow the government to tell the jury what did
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he do.
In other words, the cross-examination was
allowed because it may or may not be relevant for the
jury's determination as to whether or not the scope of
the investigation was adequate or not. And now the
government is reviewing what he did do.
So review what he did do and keep it on track.
MR. FENTON: Yes, your Honor.
May the witness finish his answer?
THE COURT: Yes.
THE WITNESS: Yes. So again, in reviewing those
escrow records we saw the $110,000 was going to be used
for a deposit for the purchase of the residence 4910
Topeka in the name of Richard Ayvazyan and Marietta
Terabelian.
I again went back to the bank records for the
Radius Bank account and saw that those PPP funds were
also being sent to a company called Gentleman Timepieces.
We reached out to Gentleman Timepieces, and they were
actually initially unable to determine who the wires were
coming into. We were requesting information for Iulia
Zhadko.
And when I was on the phone with them --
MR. RAM: Objection. Calls for hearsay.
THE COURT: Overruled. He is telling the jury
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what he did. In other words, you are attempting to
elicit how he conducted his flow of money analysis; is
that it?
MR. FENTON: Absolutely, your Honor. The original
question was how did you follow the money.
THE COURT: You can't do that for every
transaction because we would be here for another week,
but is this one instance of how he did it?
MR. FENTON: Yes, your Honor.
THE COURT: All right. Then, I will allow it for
that purpose only.
MR. FENTON: So, your Honor, can the witness
complete his answer?
THE COURT: Yes.
THE WITNESS: So in speaking with Gentleman
Timepieces, they were initially confused because we had
requested information --
MR. RAM: Objection. Hearsay as to the extent he
is relating the conversation to the third party.
THE COURT: Overruled.
THE WITNESS: I was speaking specifically with
Andrew Farrer at Gentleman Timepieces, and he was
confused, as we had requested information relating to
Iulia Zhadko. That money was coming from an account in
the name of Iulia Zhadko.
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And when I specified and said it was a $25,000
wire transfer, he looked at the records, and what I
recall him specifically saying, oh, you mean Richard.
MR. RAM: Objection. Hearsay. Confrontation
issue.
THE COURT: We are getting into a lot of detail
about conversations. Why can't the questioning be more
pointed to just what he did. Not in that detail.
MR. FENTON: Your Honor, I just asked the witness
how he found the money. He is just completing his
answer. Mr. Ram has interrupted him about five times
now.
THE COURT: Just ask him what he did. I mean, how
he went about following the money.
MR. FENTON: Can he just complete his -- he was
about to complete his answer?
THE COURT: No, no. Ask him the questions in the
format I have suggested.
Q BY MR. FENTON: Special Agent Palmerton, how did you
go about following the money?
A
We followed the money by reviewing bank records and
transactions that linked the synthetic identities with
real individuals.
Q
And what type of -- what type of companies did
you -- did you conduct interviews in connection with your
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efforts to follow the money?
A
Yes.
Q
Who did you interview, if anybody?
A
We interviewed representatives from Gentleman
Timepieces.
Q
And did you interview anyone from escrow companies?
A
Yes.
Q
How about furniture dealers?
A
Yes.
Q
Jewelry dealers?
A
Yes.
Q
Did you conduct other interviews of other witnesses
in connection with your investigation in this case?
A
Yes.
Q
Approximately how many other witnesses did you
interview?
A
It was dozens. Dozens of witnesses.
Q
Did you conduct surveillance?
A
Yes.
Q
What did you conduct surveillance on?
A
We conducted surveillance on the residences that
were purchased with fraudulent PPP proceeds as well as
individuals we that believed were behind the fraudulent
loans.
Q
And did you personally conduct that surveillance?
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A
I personally conducted some of the surveillance and
we also had our surveillance group conduct the
surveillance.
Q
And what did you learn as a result of the
surveillance that you conducted?
A
That -- well, for instance, one of the properties
purchased at 834 Calle La Primavera, it appeared to be
Marietta's sister Gohar Terabelian was living at that
residence.
Q
And whose name was that residence purchased in?
A
It was in the name of Iulia Zhadko.
Q
So it was purchased in the name of Iulia Zhakdo,
but your surveillance showed that Gohar Terabelian lived
the house?
A
Yes.
Q
And that is Marietta's sister?
A
Yes.
Q
As part of your investigation, did you search
defendants' homes?
A
Yes.
Q
Or at least some of the defendants; correct?
A
Yes.
Q
And which defendants' homes did you search?
A
I searched Richard Ayvazyan and Marietta
Terabelian's house.
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Q
And when you searched that house, did you seize
routers?
A
We did.
Q
And did the FBI make efforts to analyze the data to
determine if there is any data on those routers?
A
Yes. We did.
Q
And what did you find?
A
We found that the router logs had been turned off
so IP information was not or could not be retained.
MR. RAM: Objection, move to strike. Speculation.
No foundation.
THE COURT: Overruled.
Q BY MR. FENTON: Yesterday, Mr. Ram asked you whether
you looked into the criminal history for Manuk Grigoryan.
Do you remember that?
A
Yes.
Q
Did you look into the criminal histories of the
defendants?
A
Yes.
MR. RAM: Objection, your Honor. Improper
testimony. Ruling of the Court.
THE COURT: Overruled. I mean, sorry. My
apologies. Objection sustained.
Q BY MR. FENTON: As part of the investigation, you
said that you investigated Richard Ayvazyan; correct?
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A
Yes.
Q
And you also investigated Manuk Grigoryan?
A
Yes.
Q
Did you investigate whether Richard Ayvazyan was
working with Manuk Grigoryan to fraudulently submit PPP
and EIDL loan applications?
A
Yes.
Q
What did you find?
A
Well, we interviewed one witness. Again, this is
going back to the purchase of the Calle La Primavera
property. She identified that Richard was --
MR. RAM: Objection, your Honor. Hearsay.
Confrontation issues. This is completely beyond --
THE COURT: The question was did you investigate
the relationship between Richard Ayvazyan and Grigoryan.
He said yes. And then you can ask him generally what he
did in pursuit of that.
MR. FENTON: Yes, your Honor.
THE COURT: I will ask. What did you do generally
to pursue the relationship, if any, between those two
defendants.
THE WITNESS: Yes. In addition to reviewing the
evidence from the search warrants, flows of funds and
text messages as well as interviews of witnesses, we
determined that there was a working relationship between
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them.
THE COURT: Okay. And whatever the evidence is,
the evidence is there. The parties can argue at the
appropriate time. Let's not have him review it.
MR. FENTON: Thank you, your Honor. We will move
on.
Q
BY MR. FENTON: Special Agent Palmerton, I would
like to show you government Exhibit 300.
MR. RAM: Your Honor, we move to exclude any
discussion of this late-produced discovery. What they
are marking is 300.
THE COURT: I don't know what it is and I can't
rule until it is identified and there is some basis for
me to consider the objection.
MR. FENTON: Your Honor, this is the issue that we
took up yesterday.
THE COURT: I don't remember. There were so many
issues. You will have to just begin at a point and hope
I can focus on the issue.
Q
BY MR. FENTON: So earlier Mr. Ram asked you
questions about whether or not you looked into IP
addresses; correct?
A
Correct.
MR. RAM: Objection. Beyond the scope. And that
is not true. We did not discuss --
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THE COURT: Don't say it is true or not true.
Just make an objection. What is the basis of your
objection, legal grounds?
MR. RAM: Beyond the scope of the direct.
THE COURT: Overruled.
MR. RAM: And misstates.
THE COURT: Overruled.
Q BY MR. FENTON: So Special Agent Palmerton,
yesterday Mr. Ram asked you about your investigation into
IP addresses; correct?
A
Yes.
Q
And did you look into other Internet activity,
whether there is other Internet activity by the
defendants other than just IP address information.
A
Yes.
Q
Okay. Showing you -- Mr. Cruz, can we show the
exhibit just to the witness, please?
THE COURT: Why do you have to show him the
exhibit? Why can't you just ask him -- the point of this
whole thing is not to have the witness review the whole
case.
I mean, the jury will make its determination
at the appropriate time. The point is to just allow the
parties to ask this witness what did he or what he didn't
do, and the investigation. So just keep it on that
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level.
MR. FENTON: All right. We will move on.
Q
BY MR. FENTON: Earlier Mr. Ram asked about a
transaction at Lamps Plus. Do you recall that?
A
I do.
Q
And he asked you whether or not that transaction
took place on October 13; correct?
A
Correct.
Q
Okay. And you said that transaction did not --
THE INTERPRETER: I am so sorry. Please slow down
just a tad, please. Thank you.
THE COURT: You are speaking too quickly. You
know, my aged brain works slowly. So see if you can't
slow it down.
Go ahead.
MR. FENTON: Yes, your Honor.
Q
BY MR. FENTON: And you testified that you had
actually looked into that transaction; correct?
A
Yes.
Q
And that transaction took place on what date?
A
August 21st of 2020.
Q
So that was approximately two-and-a-half months
before Richard Ayvazian and Marietta Terabelian left the
country to go to Turks and Caicos; correct?
A
Yes.
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Q
So they were in the country at the time; correct?
A
Yes. To the best of my knowledge.
Q
Did you investigate --
THE COURT: Why are you getting into substance
just as the defendants? The substance may be relevant to
a point of why something was done or not, but that was
unnecessary.
MR. FENTON: I just have a few more questions,
your Honor. Then I will wrap up.
THE COURT: Get to it and let's get through with
this witness.
Q
BY MR. FENTON: As part of your investigation, did
you investigate where Artur Ayvazian lived?
A
Yes.
Q
And what, if anything, did you determine?
A
Well, when we pulled up his DMV records, the
license, his license had the 17450 Weddington address, at
that location.
Q
And that was the house that you searched; correct?
A
Correct.
Q
By you I mean the FBI; correct?
A
Yes.
Q
Earlier Mr. Mesereau asked you if you had pulled
Artur Ayvazian's tax returns; right?
A
Yes.
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Q
This is not a tax case; correct?
A
It is not a tax case.
Q
And do you know whether you are able to pull tax
returns in a case that is not a tax case, in a nontax
case?
A
I am not able to do that.
MR. FENTON: Thank you. No further questions.
THE COURT: Very briefly.
MR. RAM: Yes.
THE COURT: Very briefly.
RECROSS-EXAMINATION
BY MR. RAM:
Q
You just testified a moment ago about Lamps Plus.
Do you remember that?
A
Yes.
Q
And you told the jury you called someone, and the
transaction you found out happened on August 21, which
was more than a month-and-a-half before the defendant
Richard Ayvazyan was out of the country; correct?
A
Yes.
Q
Let's pull up Exhibit 1R, which is the bank
statement for the account at issue. Why don't we start
with page 15. Actually let's start with page 7 this
time.
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I think if we blow up this box here. Okay.
Specifically, three lines down, there is a
transaction. See it there? Can we blow up just the top
part there.
Okay. Now on August 24th, meaning when it
hits the account, there is a transaction for August 21st
at Lamps Plus with a code of 46 in Rancho Mirage,
California for the card ending in 3537; right?
A
Yes.
Q
And that is the Zhadko account we have been talking
about?
A
Yes, it is.
Q
Specifically the Chase Account?
A
Yes.
Q
Ending in 5268?
A
Yes.
Q
And so when you called the representative, you
indicated she said the purchase was actually made on
August 21st; right?
A
Yes.
Q
And that is the transaction you were talking about?
A
Well, yes. So the records indicated that there
were multiple purchases made on that date, and the reason
that it showed up on October 13th was because that is
when the package was shipped from the location.
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Q
Well, let's look at the bank statement instead of
your hearsay statement.
MR. FENTON: Objection, your Honor.
Argumentative.
THE COURT: Don't do that. I mean, why do you
interject your opinion about the quality of the
statement? You have done that frequently, and it is
improper. Just ask questions. You can make all these
arguments to the jury at the right time.
MR. RAM: Okay, your Honor.
Q
BY MR. RAM: So this is the transaction for
August 21; right?
A
I believe one of the transactions. Yes.
Q
Okay. Now let's jump ahead to page 15. Let's blow
up the area where it says October 14th ATM transaction.
Now, there is a separate transaction which
lists 10/13, Lamps Plus, which hit the account on 10/14.
Do you see that?
A
Yes. This is the August 21st transaction, though.
Q
Well, are you aware that the representative you
spoke to said someone picked up the package on
October 13th?
MR. FENTON: Objection, your Honor. That is
hearsay.
THE COURT: Overruled.
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MR. FENTON: Assumes facts not in evidence.
THE COURT: What does aware mean? Why don't we
just ask the question in the format did he further
investigate the issue beyond contacting this consecutive
at Lamps Plus.
MR. RAM: Yes, your Honor.
Q BY MR. RAM: Did you further investigate and learn
that a package was picked up at Lamps Plus?
THE COURT: Did he further investigate it. Don't
ask him that question in that format. Ask him a
foundational question. Did you further investigate the
issue of this Lamps Plus transaction beyond that which
you told us about.
THE WITNESS: Yes.
THE COURT: And tell us what you did.
THE WITNESS: So I made a follow-up call to look
into this transaction and determined at that somebody by
the name of Samantha Perk or Kirk picked up the package
on -- I can't recall the date. It must have been the
13th.
Q
BY MR. RAM: Of October?
A
Of October.
Q
Thank you.
MR. RAM: No further questions.
Actually one further question, your Honor.
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Q
BY MR. RAM: You testified quite a bit a moment ago
about flow of funds as being one of the foundations to
your investigation, yes?
MR. FENTON: Objection, your Honor. Misstates
testimony.
THE COURT: He didn't say anything about
foundation. That is your word.
MR. RAM: Sure. Let me ask --
THE COURT: Just one minute.
MR. RAM: Sorry, your Honor.
THE COURT: He testified that he did examine the
flow of funds. With that in mind, you can a question.
Q BY MR. RAM: Okay. And flow of funds was very
important to your investigation; is that right?
A
Yes.
Q
Okay. But you did not look at account balances
prior to March of 2020 with regards to the entities and
individuals you were investigating; correct?
A
No. Because --
Q
So the answer to that question is no; right?
All right. And further, you did not obtain
evidence as to whether any of the defendants had
knowledge that actual PPP funds were moving as opposed to
funds from other ventures; true?
MR. FENTON: Objection. Argument.
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THE COURT: He can answer "yes" or "no."
THE WITNESS: Can you restate the question?
Q BY MR. RAM: Sure. You didn't investigate or obtain
any evidence that the defendants actually knew that PPP
funds were moving between their accounts as opposed to
funds from other ventures related to the same entities
and individuals?
MR. FENTON: Objection.
THE COURT: Objection sustained.
MR. RAM: No further questions, your Honor.
MR. FENTON: Your Honor, just a brief redirect.
THE COURT: I mean, we have to get through with
this witness. I think the parties have had a fair
opportunity to deal with the witness. Make it very
brief.
MR. FENTON: Can we put government's Exhibit 1R,
page 15?
RECROSS-EXAMINATION
BY MR. FENTON:
Q
Special Agent Palmerton -- Mr. Cruz, can you allow
us to display the exhibit to the courtroom?
THE CLERK: Do you want it just to the witness?
MR. FENTON: No, to the entire courtroom.
It has not come up yet.
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THE CLERK: It would be on your end. The monitors
are all on.
Q BY MR. FENTON: Special Agent Palmerton, I am
showing you the document that Mr. Ram just showed you.
This is government Exhibit 1R at page 15.
Do you see this?
A
Yes.
Q
And I am going to ask Ms. Paul to magnify that
transaction again on October 13th. And can you take a
look to the far right there where it reads the card
number?
Can you tell what that card number reeds?
A
3537.
Q
I am now going to show you what was previously
admitted as government Exhibit 76, or a portion of what
was government Exhibit 76.
MR. RAM: Your Honor, this is beyond the scope
now.
THE COURT: Overruled.
Q BY MR. FENTON: Special Agent Palmerton, do you
recognize this card as one of the cards that was seized
from --
THE COURT: You are asking him -- this is all
matters that you can argue to the jury. There is no
restriction on that if it is in evidence. And you are
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reviewing as other parties have, not just what he did or
didn't do, but the parties are trying to make their
respective points heard through the witness, and the
point of it is to do it in final argument.
All right. No further questions.
Next witness. Is the next witness the one
that we discussed after the jury left yesterday?
MR. FENTON: Yes, your Honor.
THE COURT: Pass on that witness for the moment.
I will take that up without wasting the jury's time.
Let's get to another witness.
MR. JOHNSON: Your Honor, may I ask that we take
the --
THE COURT: No. You may not.
MR. MESEREAU: Your Honor, the defense will call
Mr. Artur Ayvazian.
THE COURT: Well, if you are going to call Artur
Ayvazian -- am I reading the clock correctly? Is it
10:34?
THE CLERK: Yes, your Honor.
THE COURT: All right. Let's take 10 minutes, and
then we will hear from the next witness.
(The following proceedings were held outside the
presence of the jury:)
THE CLERK: Please be seated.
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THE COURT: We are outside the presence of the
jury. Let me take up that matter now that was raised
yesterday. You have an objection to the summary,
Mr. Fenton. Can I hear your objection get to the point
if you can?
MR. FENTON: I can do that, your Honor.
The objection is that we were provided notice
about the summary chart exhibit literally moments before
we walked into the courtroom and were powering down our
e-mails.
THE COURT: One second. I understood yesterday
one of the counsel to say that -- I don't know why I
remember this, but he said at 12:37 yesterday afternoon
he gave the summary chart to you; is that correct?
MR. FENTON: That is not exactly accurate. At
12:47 they e-mailed it to us as we were coming back into
the courtroom.
THE COURT: Slow down. Would you, please?
So then are you saying that because it was
e-mailed to you and you were here, you didn't see it
until the court was concluded?
MR. FENTON: That's correct, your Honor.
THE COURT: So when did you first see it?
MR. FENTON: We saw it -- well, we first learned
about it when Mr. Keough raised it at the end of the day.
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THE COURT: But when did you first see it?
MR. FENTON: We first saw it when we got back to
our offices about 6:00 o'clock.
THE COURT: All right. So aside from the short
notice, what is it about the summary chart that would
become a 1006 issue?
MR. FENTON: This chart fails to meet any of the
basic prerequisites for admissibility. The summary chart
exhibits are incomplete. They do not contain dates so
you can't tell what dates are being referenced on this
chart.
It does not purport to summarize voluminous
information, which is the purpose behind Rule 1006.
THE COURT: So, how many transactions does the
chart purport to summarize?
MR. FENTON: It purports to summarize a couple
dozen.
THE COURT: Okay. And do you recognize the
transactions it purports to summarize?
MR. FENTON: Well, your Honor, the problem is that
there are no dates in this chart. And I cannot --
MR. KEOUGH: Your Honor, if I may speak on this
issue.
THE COURT: One second. I will get to the
proponent's position in a moment, but what about the
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underlying documents. Does the chart have a column for
the underlying documents.
MR. FENTON: It does, your Honor. And some of
those underlying documents --
MR. KEOUGH: Your Honor, would it be helpful --
THE COURT: If you interrupt one more time, I am
going to lose my patience.
MR. FENTON: Some of those underlying documents
have not --
THE COURT: Now, who are you who is standing up
all the time and interrupting? What is your name?
MR. KEOUGH: My apologies. Michael Keough.
THE COURT: Don't do that anymore. Go ahead.
MR. FENTON: Thank you, your Honor. Some of the
documents -- the underlying documents have not been
provided to the government by the time they provided the
chart.
THE COURT: Which underlying documents? Can you
identify the documents that are referenced in the chart
that were not provided to you by the defendants?
MR. FENTON: Defense Exhibit 19, 102 and 103.
THE COURT: And what does the summary chart
purport, from your understanding, to represent?
MR. FENTON: I think it is very confusing, your
Honor. It purports to represent how certain IP addresses
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were used, but I think that what is missing from most of
the summary chart is the fact that --
THE COURT: One second. How IP address were used.
Can you give me more detail about that?
MR. FENTON: For Venmo accounts.
THE COURT: Let me see the chart. Hand it up.
Not you. Okay.
If you have the chart, give it to me.
Let me see the chart.
MR. FENTON: Michael, can you provide us a copy of
the chart that you just handed to the judge?
MR. KEOUGH: It is the same one.
MR. FENTON: Can you just provide a copy, please.
THE COURT: Is the chart -- does it contain four
pages? Is that the full chart? Four pages. That is
what I have, four pages.
MR. KEOUGH: Your Honor, may I answer the
question?
THE COURT: Yes.
MR. KEOUGH: There are two exhibits. The first
one is the one you just referenced with four pages. And
then there is a second exhibit that just has a single
page.
THE COURT: So let me start in a different way.
Maybe I should have done that at the outset. Can you
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briefly tell me what this purports to represent?
MR. KEOUGH: Yes, your Honor. The chart lists IP
addresses that were produced in discovery in this case.
And then the chart lists the references to those IP
addresses in certain government and defense exhibits that
have been admitted into evidence, all of which were
produced from the government to the defense during the
course of discovery.
THE COURT: So what is the point of it. How does
it advance your position?
MR. KEOUGH: So the chart is helpful for two
reasons. First of all, the defense and government
exhibits span hundreds of pages, loan files, bank records
that are voluminous.
And the second reason is that it shows where
certain IP addresses were used to access certain accounts
or whether they were used to submit certain loan
applications so the jury can see where IP addresses were
used in certain documents they have seen in the case.
THE COURT: But, is the summary selective? I
mean, it doesn't include all the loan applications and
their relationship to IP addresses; correct?
MR. KEOUGH: Correct, your Honor. It only
contains these five IP addresses that have come up
frequently throughout the case.
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THE COURT: And it appears in the description
column to have summaries within summaries. I see the
word summary within summaries.
MR. KEOUGH: So, your Honor, the description
column was taken -- for the most part taken straight from
the document. So I mean, for example, Venmo account --
THE COURT: I mean, like, for example, I am
looking at the single-page exhibit. I have two things
marked DX1100-1. Is that a separate document?
MR. KEOUGH: Yes.
THE COURT: And then there is a DX1000. I see.
So the DX1100-001 is the separate document; correct?
MR. KEOUGH: Correct, your Honor. There are two
exhibits.
THE COURT: And within that document, there are
summaries; correct? I see something with application IP
address the, second from the bottom, intake application
summary. Where did that summary come from?
MR. KEOUGH: Sorry, your Honor. I see what you
are saying. So "Intake Application Summary" I believe is
the title of the page in GX6H.
THE COURT: So what is the purpose of the summary
chart? It is trying to link IP addresses to a loan
application?
MR. KEOUGH: And to bank accounts and other
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documents that the government has used.
THE COURT: Say that again more clearly.
MR. KEOUGH: Yes, your Honor. The purpose of the
chart is to show IP addresses that have been referenced
in this case and then list the references to those IP
addresses in government and defense exhibits so that the
jury can see from the large number of exhibits that are
going to go back with them rather than having to turn
through and find these IP addresses. The IP addresses
are listed here in the chart as a summary.
THE COURT: The IP addresses in terms of what?
MR. KEOUGH: Where they appear in the exhibits.
So if the IP address, just for an example, appears in,
say, three bank accounts and two loan applications, it
appears on the chart here to show which exhibits the jury
can reference to find those IP addresses.
THE COURT: I see. All right. Let me hear from
the government on that.
MR. FENTON: So, your Honor, there are two primary
problems with this. One is that there are no dates on
this chart. Without having any dates, there is no way
for the jury to find the actual references in this chart,
and they may not be accurate. We have no way to actually
check to see if the contents of this is in any way
accurate because there is no information about when these
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events purportedly happened.
The second principal issue is if you look at
the subscriber information at the top of right under the
IP address, for the majority of these charts there is no
subscriber information, which means that this information
is not helpful to the jury because it doesn't actually
say who that IP address would tie back to.
THE COURT: Okay. Let's take the recess. Seven
minutes.
(Recess from 10:47 a.m. to 10:59 a.m.)
(The following proceedings were held in the
presence of the jury:)
MR. RAM: Should we call our witness, your Honor?
THE COURT: We have to deal with the chart.
MR. RAM: Yes.
THE COURT: My ruling is such that you will not
need that witness, but I will explain it outside the
presence of the jury. So that means we have another
witness.
MR. MESEREAU: Yes. Thank you, your Honor. The
defense will call Mr. Artur Ayvazian.
(The witness was sworn.)
THE CLERK: State your full name and spell it for
the record.
THE WITNESS: Artur Ayvazian, A-R-T-U-R, last name
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A-Y-V-A-Z-I-A-N.
MR. MESEREAU: May I proceed, your Honor?
THE COURT: Yes.
MR. MESEREAU: Thank you.
DIRECT EXAMINATION
BY MR. MESEREAU:
Q
Good morning, Mr. Ayvazian.
A
Good morning, Mr. Mesereau.
Q
How old are you?
A
I am 41 years old.
Q
Where do you live?
A
I live in Encino, California.
Q
What is the address?
A
17450 Weddington Street, Encino, California 91316.
Q
And that is the home that was searched in this
case; correct?
A
Correct.
Q
How long have you lived in that home?
A
I have been residing there since 2006.
Q
And do you own that home?
A
No, I do not.
Q
Have you ever owned the home?
A
No, sir.
Q
Have you ever signed any document relinquishing any
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interest in the home?
A
At the time of the purchase, my wife made me sign
something that I am not a part of that house. I don't
recall what it was.
Q
And you are married?
A
Yes.
Q
And who are you married to?
A
Tamara Dadyan.
Q
And how long have you been married to Tamara
Dadyan?
A
Sixteen years.
Q
And you have two children?
A
Yes. Two wonderful children.
Q
Now, could you briefly -- very briefly summarize
your education?
A
When I came to this country in 1989, I went through
third grade all the way up to 10th grade, and then I
dropped out of high school.
Q
And could you briefly summarize your work history?
A
I have been working all my life. Came here in
1989. I was nine years old. I started working when I
was 12 years old. I started passing out pizza flyers $4
a hour for two hours a day.
I have had random jobs, car wash jobs,
restaurants, fast food places. Just a lot of jobs.
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Supermarkets, seafood jobs, trucking. I have done a lot
of jobs.
Q
Okay. Now, let me ask you about the seafood job.
A
Yes.
THE COURT: Keep your voice up just a little bit,
Mr. Mesereau.
MR. MESEREAU: Sorry, your Honor. Yes.
Q
BY MR. MESEREAU: You were in the seafood business
at one point, were you not?
A
Correct.
Q
Could you please tell the jury what you did?
A
I had a partner, Thanh Tran. He was one of my best
friends for 18 years. We went to Louisiana to establish
a seafood company by process and resell seafood.
And we went to Louisiana. We established a
good company. We brought a lot of seafood. We processed
it, packed it, shipped it to Los Angeles to the accounts
that my friend held with all the restaurants here in
Alhambra.
And we were there for I believe six months and
then the oil spill happened and just destroyed us.
Q
And when you were in that business, did you make
money?
A
We made enough money to get by, and we -- no, we
didn't. It was not enough time for us to get
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established.
Q
Did anyone help you financially with that business?
A
Yes. My brothers helped me out a lot in that
business.
Q
And how many brothers do you have?
A
You have I one, on older brother.
Q
And is that Richard?
A
Yes, sir.
Q
He helped you financially with those business
obligations; correct?
A
Yes. He has always been there for me.
Q
Now, at some point you got into the trucking
business; correct?
A
Correct.
Q
Could you please tell the jury what you did?
A
I started my own trucking company. I went to
school. I got my trucking license. I borrowed money
from my brother to establish my business, and I purchased
my truck and I have been trucking ever since.
Q
And are you a truck driver yourself?
A
Yes, sir.
Q
And you still a truck driver?
A
Yes, sir.
Q
And what kind of hours could you keep?
A
Long hours. The Federal Motor Carrier
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Administration only allows you to work 14 hours a day,
and from that 14 hours a day you can only drive 11 hours,
but by the time I am done with my shift it is always 16,
17 hours, sometimes longer.
Q
And what year did you start your trucking company?
A
Back in 2012.
Q
And how did you start it?
A
I filed for a DBA. I had my commercial license
that time. Once I got my DBA, I filed for my permits. I
got my permits and I got my insurance active and I
started working.
Q
And how many trucks have you ever owned at one
point?
A
Back in the days, I have done local towing. I
believe it was 2006, I want to say. I am not sure. I
did local towing for the City. I have had three trucks
at that time. But when it came to 18-wheeler trucking, I
have only maintained one truck, but I have owned couple
of trucks. One of them the motor went bad and I had to
purchase another one.
Q
And do your trucks identify the company?
A
Yes, sir. They have to.
Q
Why is that?
A
For the Department of Transportation to recognize
who you are and what you are hauling and if your permits
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are allowed for you to hold certain cargo.
Q
And what do your trucks say on the outside?
A
My company name, Allstate Towing and Transport.
Q
Now, has that company gone through some changes?
A
Yes.
Q
Please tell the jury.
A
We went from being a sole proprietorship into an
LLC.
Q
What is an LLC?
A
A corporation.
Q
Has anyone ever owned it but you?
A
No, sir.
Q
Has anyone else ever driven trucks for the company
but you?
A
Yes.
Q
Who?
A
I have had numerous drivers come and go, but no one
ever stuck to the company due to various reasons. They
can't drive 13-speed auto transmission. The insurance
didn't accept them. We didn't get along. They weren't
communicative. They weren't doing their job properly.
So these drivers came and left. Two days, one
day, three days max, then I had to let them go.
Q
And does the company currently have employees?
A
Yes. Myself.
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Q
And let's go back to the period of March through
August, 2020.
A
Okay.
Q
Was the company in existence?
A
Yes.
Q
Were you in charge of the company?
A
Yes, sir.
Q
Did the company have employees?
A
Yes.
Q
And please explain who they were.
A
Myself.
Q
Anyone else?
A
I have had couple of drivers. Yes.
Q
Now, I gather you have had trouble keeping drivers;
correct?
A
Yes, sir.
Q
And when you try to test a driver to see if they
are going to be a good employee, what do you do?
A
I put them behind the wheel and they have to
perform certain things, backing up, shifting gears,
knowing the law, and that is it. Paying attention.
Q
Do the employees have to have certain licenses?
A
Yes, of course. They need to have a commercial
license.
Q
Is there any other license they have to have?
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A
It is optional. They could get hazmat endorsement
or doubles or triples to put doubles trailers, things
like that.
Q
Do they have to go through any type of medical
testing?
A
Yes, of course.
Q
Please tell the jury what you mean.
A
First thing they got to be involved is in the drug
and alcohol program, which require a commercial license.
On top of that, you need to, through the DMV every two
years, you need to go for a medical exam to get checked
out and stuff.
Q
Does your company have to cover -- excuse me, does
your company have insurance?
A
Yes, of course, sir.
Q
What kind?
A
Minimum of $1 million liability insurance, and
depending on the freight broker you are working with,
they require cargo insurance and also your physical
damage insurance, which is your truck and trailer.
Q
And do you own these trucks or lease them?
A
I have owned them, but I have financed them before,
and I have paid them off.
Q
And how do you finance them?
A
Well, my credit is not the greatest in the world so
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I really don't have much options and I try to find
companies that do inhouse financing. And with certain
amount of down payment, they close their eyes and they
finance you.
Q
Now, has the company been profitable?
A
Yes. Yes. It has been growing.
Q
And is it profitable today?
A
Not at the moment.
Q
And let me ask you about the period March through
August of 2020. Was the company profitable?
A
No, sir.
Q
Please explain what you mean.
A
Well, 2019 I did great. I made a lot of money in
2019. As soon as 2020 came, I went from making 130
something thousand to $30,000.
Once the pandemic hit, I was just devastated.
There was no jobs. The receivers weren't working.
Nobody was going to work. I was having very hard time
finding loads to move.
Q
Now, when you say you went from 130 to 30?
A
Yes, sir.
Q
Is that net profit?
A
No, that is gross profit, sir.
Q
Please explain what you mean.
A
Yeah. 130 minus diesel costs, wear and tear, you
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probably net somewhere in about 85 to $90,000.
Q
Have you ever been in the real estate business?
A
No, sir.
Q
Have you ever had a real estate license?
A
No, sir.
Q
What business is your wife in?
A
Real estate.
Q
And has she been in that business since you were
married?
A
I believe so, yes. So 20 years now.
Q
Where does your wife operate that business?
A
She works from home, sir. She has a home office.
Q
And you have heard references to searches of the
home office in your house. Is that her office?
A
Yes, sir.
Q
Is that your office?
A
No, sir. I don't have an office.
Q
Do you ever use that office?
A
I go in there time to time to make copies and faxes
and that is it.
Q
What do you use as an office?
A
My truck is my office and the briefcase that I
carry with me, all my permits in there. I usually have a
couple of files that set completed jobs, receipts,
repairs and freight broker applications and that is it.
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I usually carry that with me. If not, it is in my truck
at all times.
Q
Do you have your own accountant?
A
Yes, sir.
Q
Who is that?
A
A lady by the name of Dorothy Wang out in Alhambra.
Q
What does she help you with?
A
She does my taxes.
Q
Is your wife, Tamara, involved in the trucking
business at all?
A
Not at all, sir. She is against it.
Q
Who do you mean by that?
A
She doesn't want me to drive a truck, but I love
doing what I am doing and I am very independent.
Q
Now, has your wife been in the real estate business
from the time you were married?
A
Yes, sir. Even before.
Q
And have you ever assisted her in any of her work?
A
I have helped her out, you know. She has a back
problem that comes and goes every now and then that she
gets pretty much paralyzed and, you know, I feel bad and
she asks me to do some things.
MS. AHN: Objection, relevance.
THE COURT: Overruled.
THE WITNESS: She asks me to perform certain
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things like, oh, hey, babe, can you take these papers to
escrow or can you please go make a deposit for me. Can
you do this, do that. And I do help her out sometimes
for things like that.
Q BY MR. MESEREAU: You said your brother Richard
helped you financially with the seafood business?
A
Yes, sir.
Q
Did he ever help you with your trucking business?
A
Yes, yes. He has always been there for me. He is
a great guy.
Q
What do you mean he helped you financially. Tell
the jury what he did.
A
He has loaned me money to purchase my truck. He
has loaned me money for the seafood venture. And
throughout my personal life, you know, he has always been
there for me.
Q
Okay.
A
But mostly, yes, he has helped me in my business.
MR. MESEREAU: Your Honor, I am going to use the
old-fashioned overhead if I may.
THE COURT: Yes.
MR. MESEREAU: I would like to show the witness a
document already in evidence. It is Exhibit 57B, page 3
of 8. I apologize for being a little clumsy, but haven't
used up with in a while.
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Q
BY MR. MESEREAU: Do you see that document,
Mr. Ayvazian?
A
Yes, sir.
Q
This is a document that was seized by the
government. Do you see that?
A
Yes.
Q
Now, first let me ask you this. Do you -- have you
seen your wife's handwriting?
A
We have been married for 16 years. I have seen her
handwriting.
Q
Can you recognize her handwriting?
A
Yes, sir.
Q
Showing you this exhibit that is in evidence, 57B,
page 3 of 8. Do you see handwriting on that document?
A
Yes, sir.
Q
And the document says, "Currently has personal and
business need to add this new business address" -- or
access and some other language. Whose handwriting is
that?
A
That is Tammy's handwriting.
Q
Is that your handwriting?
A
No, sir.
Q
Showing you another document that is in evidence,
Exhibit 57B, page 5 of 8. Do you see that document?
A
Yes, sir.
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Q
And do you see handwriting on that document?
A
Yes, sir.
Q
Whose handwriting is that or do you recognize it?
A
I don't recognize this one, sir.
Q
Is it your handwriting?
A
No, sir.
Q
Showing you another document from that exhibit --
may I check with co-counsel for a second here.
This is also from Exhibit 57B, which is in
evidence. Do you see that document, Mr. Ayvazian?
A
Yes, sir.
Q
Do you see it looks like a tab with handwriting on
it in the upper right-hand corner?
A
Yes, sir.
Q
Do you know whose handwriting that is?
A
I can't recall that writing.
Q
Is it yours?
A
No, sir.
Q
I am going to show you a document that is in
evidence --
THE COURT: Just a moment. I notice one lawyer
standing is there any reason for that?
MR. FRASER: Yes, your Honor. I can't see the
monitor.
THE COURT: I see. All right. Sorry.
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Q BY MR. MESEREAU: This is a document in evidence.
It is GEX57D, page 1. Do you see that document,
Mr. Ayvazian?
A
Yes, sir.
Q
Now, there is some handwriting in the upper
right-hand corner. Do you see that?
A
Yes, sir.
Q
Do you recognize that handwriting?
A
Yes, sir.
Q
Whose is that?
A
Tammy's writing.
Q
And there seems to be some handwriting towards the
bottom of the right-hand side. Do you see it looks like
a Post-it?
A
Yes, sir.
Q
Do you recognize that handwriting?
A
Yes, sir.
Q
Who is handwriting is that?
A
My wife, Tammy's.
Q
Now, there are some names referenced on that
document -- excuse me, there are some e-mails referenced
on that document. And I wanted to ask, would you take a
look at that document. Do you recognize any of these
e-mails?
A
I don't see anything, sir.
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Q
There is one that says Tamara Dadyan towards the
bottom at hotmail.com. Do you see that, Angelina?
A
I don't see anything on the screen.
Q
Oh, I'm sorry. Do you see towards the bottom it
says Tamara Dadyan?
A
Yes.
Q
Angelina. Do you know who Angelina is?
A
Angelina that is my oldest daughter.
Q
Do you see other e-mails that you recognize?
A
I see my little daughter's, Natalie, 2008, but I
don't see any other e-mails.
Q
And there is some handwriting in what appears to be
the lower left-hand corner. Do you see that writing?
A
Yes, sir.
Q
Do you recognize the handwriting?
A
Yes, sir.
Q
Whose is it?
A
Tammy's.
Q
I am now showing you a document that's in evidence,
Exhibit 57.f, page 3 of 3.
Do you see that document?
A
Yes, sir.
Q
And do you recognize the handwriting in that
document?
A
Yes.
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Q
Whose handwriting is that?
A
It is Tammy's.
Q
Is it yours?
A
No, sir.
Q
Showing you a document that is in evidence. It is
Exhibit 57.g, page 4 of 30. Do you see that document,
Mr. Ayvazian?
A
Yes, sir.
Q
Do you see some handwriting on that document?
A
Yes, sir.
Q
Do you recognize that handwriting?
A
It looks similar to Tammy's handwriting.
Q
Is it yours?
A
No, sir.
Q
Okay. Mr. Ayvazian, I am going to show you some
other documents that are in evidence in Exhibit 57. Do
you see these documents?
A
Yes, sir.
Q
They look like they are checks; correct?
A
Correct.
Q
And there seems to be a name in the upper left-hand
corner, Anastaya Rysik. Do you see that?
A
Yes.
Q
Do you know who that person is?
A
No, sir.
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Q
There is another document from that exhibit. These
appear to be checks. Do you see that?
A
Yes.
Q
Please look at each of these six checks and see if
you recognize them.
A
It is Tamara Dadyan, my wife's checks.
Q
Are any of these your checks?
A
No, sir.
Q
Moving along with the same exhibit. Do you see
these checks?
A
Yes.
Q
Do any of these checks belong to you?
A
No, sir.
Q
Moving along, same exhibit in evidence. Do you see
these, what appear to be copies of checks?
A
I do.
Q
Do you recognize anyone named in those checks?
A
No, I don't.
Q
This is in the same exhibit in evidence. Do you
see these documents?
A
Yes, sir.
Q
Did you recognize anyone mentioned on these checks?
A
No, sir.
Q
Same exhibit in evidence. Do you see this page?
A
Yes, sir.
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Q
Recognize anyone mentioned on what appear to be
checkbooks?
A
No, sir.
Q
Did you keep your checks in the office at home?
A
No, sir. All my checks are in my briefcase at all
times.
Q
Moving on to Exhibit 57.h, page 1 of 4. Do you see
that document?
A
I do.
Q
And at the top it says August 2017; right?
A
Yes, sir.
Q
And then you see handwriting on that document;
right?
A
Yes.
Q
Do you recognize the handwriting on that document?
A
I do, sir.
Q
Whose handwriting is it?
A
My wife, Tammy's.
Q
Do you see your handwriting anywhere on this
document?
A
No, sir.
Q
Moving on to Exhibit 57.h, page 3 of 4. It is in
evidence. Do you see that document?
A
Yes, sir.
Q
Do you recognize the handwriting on that document?
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A
Yes, sir.
Q
Whose is it?
A
My wife, Tammy's.
MS. AHN: Your Honor, the government is unclear
which pages be are being shown.
THE COURT: He is telling you. I thought it was
57 small H, page 1. Was that it?
MR. MESEREAU: Yes, your Honor.
MS. AHN: He has gone through several pages now,
your Honor.
THE COURT: Well, he has told each page. I heard
it. I don't know.
MR. MESEREAU: I can try and clarify.
THE COURT: I think it is clear, 57 small f. 57
small g. He has said it. Go ahead.
Q BY MR. MESEREAU: Now, same Exhibit 57.h, page 4 of
4. It is in evidence. Mr. Ayvazian, do you see this
document in front of you?
A
I do, sir.
Q
Do you recognize the handwriting in that document?
A
Yes, sir.
Q
Whose is it?
A
My wife, Tammy's.
Q
If you look four lines down from the top, it says
SBA Agricultural. Do you see that?
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A
Yes, sir.
Q
And that is not your writing; correct?
A
Yes, sir, it is not my writing.
Q
It is hers?
A
Yes, sir.
Q
Moving on to Exhibit GEV57I, which I believe is in
evidence. Do you see that document?
A
Yes, sir.
Q
You see handwriting on that document?
A
Yes.
Q
Do you recognize the handwriting on that document?
A
I do, sir.
Q
Whose is it?
A
My wife, Tammy's.
Q
Does your handwriting appear anywhere on that
document?
A
No, they do not.
Q
Moving on to Exhibit 57.k, page 1 of 10, which I
believe is in evidence. Do you see that document?
A
Yes, sir.
Q
Do you see handwriting on that document?
A
Yes, sir.
Q
You recognize the handwriting on that document?
A
I do, sir.
Q
Whose is it?
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A
My wife, Tammy's.
Q
Looking at the other side of that document, which
would be Exhibit 57.k, page 2 of 10. Do you see that?
A
Yes, sir.
Q
Do you see handwriting on that document?
A
I do, sir.
Q
Do you know whose handwriting that is?
A
Yes. My wife, Tammy's.
Q
Moving on to Exhibit 57.k, page 3 of 10, which I
believe is in evidence. Do you see that document?
A
Yes, sir.
Q
Do you recognize the handwriting on that document?
A
Yes, sir.
Q
Whose.
A
My wife, Tammy's.
Q
Looking at Exhibit 57.k, page 4 of 10. Do you see
that document in front of you?
A
Yes.
Q
Do you see handwriting on that document?
A
Yes, sir.
Q
Do you know whose handwriting that is?
A
Yes, sir.
Q
Whose handwriting is it?
A
My wife, Tammy's.
Q
Moving on to exhibit -- well, still 57.k. I think
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this is page 7 that is in evidence. Did you see that
document?
A
Yes, sir.
Q
Do you see the handwriting on the document?
A
Yes, sir.
Q
Do you recognize it?
A
I do.
Q
Whose is it?
A
My wife, Tammy's.
Q
Looking at Exhibit 57.k, page 7 of 10, which I
believe is in evidence. Do you see that document?
A
Yes, sir.
Q
You see handwriting on the document?
A
Yes, I do.
Q
Do you recognize whose handwriting that is?
A
Yes.
Q
Whose is it?
A
Tammy's handwriting.
Q
Moving on to Exhibit 57k, page 8 of 10, the next
page in evidence. Do you see handwriting on that
document?
A
Yes, sir.
Q
Whose is it?
A
Tammy's.
Q
Moving on to Exhibit 57.k, page 9 of 10, which is
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in evidence, I believe. Do you see handwriting on that
document?
A
Yes, I do.
Q
Do you know whose handwriting that is?
A
Yes, sir.
Q
Whose handwriting is it?
A
Tammy's.
Q
Looking at Exhibit 57.k, page 10 of 10, do you see
that document?
A
Yes, sir.
Q
Do you see handwriting on the document?
A
Yes, sir.
Q
Can you tell whose handwriting that is?
A
Tammy's.
Q
Looking at Exhibit 57.l, page 1 of 1, which is in
evidence. Do you see this document?
A
Yes, sir.
Q
Do you see handwriting on the document?
A
Yes, sir.
Q
Do you know whose handwriting it is?
A
I do.
Q
Whose?
A
Tammy's.
Q
Mr. Ayvazian, I would like to explore a little more
deeply the business relationship between you and your
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wife.
A
The only business relationship we have is to raise
our children.
Q
Are you involved in a real estate business at all?
A
No, sir.
Q
You said she has asked you to help her from time to
time; is that correct?
A
Yes. That's correct.
Q
And what has she asked you to do?
A
Deliver documents to escrow, pick up packages from
her customers, drop off packages to her customers, go to
the mailbox -- or I mean mail place and/or FedEx and
stuff like that.
Q
Does she have access to your phones?
A
Yes. Of course.
Q
Please explain what you mean.
A
I mean there has been hundreds, hundreds of times
when I come home, I put my phone down next to my car keys
and I will take a shower. And when I came out of the
shower, I see her on my phone.
And she says, oh, my battery is dead. I had
to use your phone. There has been hundreds of times that
we were in the car. She says, babe, my battery is dead.
Let me use your phone.
So she has access to my phone. And I don't
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keep anything in my phone. She knows the codes to the
locking screen and so do my kids. My kids access my
phone and play games.
Q
How many phones do you have -- excuse me, let me
rephrase that. Between March and August of 2020, how
many phones did you have?
A
I have only had one phone all my life.
Q
Do you know how many phones she had between March
and August of 2020?
A
I don't know. There has been a bunch of phones at
the house. I don't know what belongs to her.
Q
Now, do you pay your taxes together?
A
No, sir.
Q
You file separately?
A
Yes, sir.
Q
Whose idea was that?
A
My idea.
Q
Why?
A
I didn't want to get involved in filing with her.
Q
And you have a prenuptial agreement; correct?
A
Yeah. When we first got married, that is the first
document she put in front of me so I signed it.
Q
You signed it?
A
Yeah.
Q
Okay. Does Allstate Towing and Trucking ever use
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that office in the home?
A
Never. Never.
Q
Whose -- excuse me, let me rephrase that. If you
want to enter that office, you go through a door;
correct?
A
Yes, sir. It is through the kitchen and it is the
first door on the right before the garage.
Q
What is on that door?
A
Her business license is hanging on the door, and I
believe her business name.
Q
There are various items on the wall of that office;
correct?
A
Yes. She has bunch of plaques that she has gotten
from when she used to be with RE/MAX on the Boulevard.
Bunch of star agent plaques, agent of the year. Like
just a bunch of awards.
Q
Any of your awards on those walls?
A
No, sir. No.
Q
Any pictures of you on those walls?
A
Yes. She has family photos and stuff like that and
I am in those photos. My kids, her.
Q
Okay. Now, in this trial, it has come to the
attention of everyone that some what appear to be
synthetic ID's, fake ID's, driver's licenses, whatever,
were found on your phone?
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A
Right.
Q
Did you put those on your phone?
A
No, sir. I don't even know the whereabouts until I
got charged and I went through the phone and I saw all
that stuff and I erased it right away.
Q
Do you know who put that information on your phone?
A
Most likely my wife.
Q
You did not do it?
A
No, sir.
Q
Did you invent any of those fake ID's or
manufacture them at any point?
A
No, sir.
Q
And the first time you say you learned about it was
in this case?
A
Yes, sir. But there has been times where -- you
know, I hardly go through my photos unless I am bored and
I want to go and see some old pictures of my kids. There
has been times when there has been ID's and I confronted
her and she says, oh, that is for me. Erase it or don't
worry about it. You know, I don't need it anymore. So I
end up erasing it.
I don't think of anything different because,
you know she is a realtor. There has been bunch of
documents, bunch of stuff that she does with people's
information. She is a real estate agent. I don't know
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of any wrongdoing.
Q
In your business as a trucker and a truck driver,
do you use ID's?
A
I only use my driver's license.
Q
In your business as a trucker and a truck driver,
do you use various identification cards?
A
No, sir. Only mine, because when you enter to the
warehouse to pick up preloaded trailers or load, the
security guard always asks for your own ID.
Q
At one point you filed for divorce; correct?
A
Yes.
Q
Why?
A
Well, this was a time where I have -- we didn't see
eye to eye. I got fed up with her working hours. There
was people coming and going to the house at 9, 10 o'clock
at night talking about deals. There was no working hours
set for her. And I just had enough.
Like, you know, I had to make a stand, tell
her, hey, you need to cut this out or you are going to
lose me. And that is when I had enough and I filed for a
divorce. I served her with the divorce.
Q
What happened?
A
She -- I don't know, she took it to heart. And,
you know, my kids. I moved out of the house right away
even though my lawyer advised me not to, because I had
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every right to be there, but I just didn't want to see
her face anymore.
So my kids called me crying every single day
for the past two weeks. And one incident that really got
to me was they called me one night around 10:00 o'clock.
They said -- scared, crying, and she said mommy is here
and there are some guys over here screaming at her,
please come.
So I went over there and it was like a heated
confrontation that, I don't know, some deal gone wrong.
And I went over there to diffuse everything and send
those people off their way.
And that is when I told her, I said, look, I
love my kids. I am going to come back, but I am not
doing it for you. I am doing it for my kids because I
fear for their safety.
And ever since then, I told her, me and you,
we are not husband and wife. We are business partners
and our job is to raise our kids, and that is it.
Q
Now, the government searched your home at 6 in the
morning; correct?
A
Yes. Very -- I was scared. So were my kids.
Q
Where were you?
A
I was sleeping in the separate bedroom, I consider
to be my bedroom.
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Q
Separate from Tammy?
A
Yes.
Q
Now, let me ask you about these PPP loans.
A
Yes, sir.
Q
Allstate Towing and Trucking did apply for PPP and
EIDL loans?
A
No, sir. This time when my company was hit big
with no business, and PPP announcements news, everything
was on TV, on the radio. So I told Tammy, hey, do you
think my company will qualify because I am really in need
right now. She says, yes, I'll take care of it. And --
MS. AHN: Objection. Hearsay.
THE COURT: Overruled.
THE WITNESS: She says, yes, I'll take care of it.
And I said okay. She asked to see my 1099's from 2019.
And she asked a copy of my driver's license and a voided
check, which I provided, and that is it. Nothing else.
Q
Did you ever review any PPP loan application?
A
No, sir.
Q
Did anyone ever present you with one?
A
No, sir.
Q
Did you ever review the rules or regulations or
laws that apply to the Small Business Administration?
A
No, sir.
Q
Did you submit that loan application?
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A
No, sir. I was told I qualified due to the fact
that I made certain amount of money in 2019, and the loss
that I have done in 2020, that automatically qualifies
me, and that is what I was told.
Q
Told by who?
A
My wife, Tammy.
Q
Who filled out the loan application?
A
She did.
Q
Who submitted the loan application?
A
She did.
Q
But you knew your company was going to try and get
PPP?
A
Yes, sir. Yes. Well, she submitted the loan --
excuse me -- I received an initial $10,000 deposit into
my bank account. So I approached her. I said, hey,
whatever did you, they only approved me I guess for
10,000.
And she said that, no, that is just emergency
relief upfront money or something like that. And then
they are going to fund the loan, you know, in a week or
two. I said okay.
Q
How much money were you expecting from the --
A
I wanted no more than about 30, $40,000, just so I
could get back on my feet until the pandemic blew over.
It was not expecting $125,000. I didn't even know I
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could qualify for $125,000.
Q
Were more than one application submitted, to your
knowledge?
A
After the PPP loan I received, after the $10,000, I
believe a couple of months went by and then there was
this another deposit into my Bank of America account.
This was the new account I had opened because of my LLC
corporation. I wanted to try a new bank. Their fees
were lower. They had more branches. It was convenient
for me. So that is when I opened up Bank of America.
And when I opened that account, I have got a
deposit there for 149,000 or -- yeah, 149,900.
Q
And what happened with those?
A
I confronted her. I said, you know, what is going
on? What is this money? And she had told me that
President Trump at this time was on TV.
MS. AHN: Objection. Hearsay.
THE COURT: What was that?
MS. AHN: Objection. Hearsay.
THE COURT: Overruled.
THE WITNESS: At this time on TV they were talking
about how President Trump was forgiving loans and stuff
like that. So she made me believe that, oh, that first
loan that you have gotten has been forgiven by President
Trump and this is going to be your actual loan. And that
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is it.
And I asked her, okay, well, you know, what
are going to be my payments. She said roughly about
$1,300 you have to pay back. I said okay. And that is
all I know.
Q BY MR. MESEREAU: What happened to the money?
A
Well, since I have got the first one that came, I
spent a lot of it towards my business. I was behind my
trucking payments. I was behind on repairs. I needed
tires. I mean, just a lot of expenses towards the
company.
And when the second one came. I had I guess,
you know, substantial amount left, and that is when I
paid back my brother his money, the money that I owed
him.
Q
And was that the money you talked about earlier
when he helped you with your sea food business?
A
I mean, you know, throughout the years it
accumulated and Tammy told me that, hey, Richard is
buying a house. Do you think you could pay back the loan
that, you know, all these years that you have had towards
him.
I said sure. So I reached out and I told him,
hey, I have some money saved. I didn't tell him I got a
loan. I said I got money saved and I want to help you
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out in your time of need and pay back the loan that I owe
you.
Q
What accounts were those PPP funds put into?
A
One of them, the very first one was into my US bank
account. And then I moved money from there to my
corporation account. And the reason I did that is for
tax purposes.
I wanted to convert everything to my
corporation and close down the sole proprietorship
account and just start working from that account.
Q
Is that what your accountant advised you to do?
A
Yeah. Yes, sir.
Q
Did you ever set up any secret account --
A
No, sir.
Q
-- to bury these funds?
A
No, sir. No.
Q
Ever set up any new account with a false name to
hide these funds?
A
Never, sir. Never.
Q
Ever convert these funds into cash so you could
hide the cash?
A
No, sir.
Q
Did you think you were doing anything wrong when
you tried to pay your brother back?
A
No. No. I mean, I was explain that it was to pay
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off debt -- and back debt or just stuff for the business.
And since he invested in my business throughout the
years, that is when I paid him back. I didn't know I was
doing something wrong.
MR. MESEREAU: May I talk to co-counsel for a
second here?
THE COURT: Yes.
MR. MESEREAU: Thank you.
(Counsel confer.)
Q BY MR. MESEREAU: Let me just ask you, Mr. Ayvazian,
if you know a couple of people. Do you know Payrur
Hayrapetyan?
A
Never heard of him.
Q
Do you know Arman Hayrapetyan?
A
No, sir.
Q
Do you know Asya Vostanikyan?
A
No, sir.
Q
Do you know Edvard Paronyan?
A
No, sir.
Q
Let me ask you some questions about these charges,
okay?
A
Yes.
Q
Did you ever make an agreement with anyone between
March and August of 2020 to defraud a bank?
A
No, sir.
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Q
Did you ever enter into an agreement with anyone
between March and August of 2020 to defraud the US
government?
A
No, sir.
Q
Did you ever think you were agreeing with anyone to
commit a crime between March and August of 2020?
A
No, sir.
Q
Did you think at any time you were in some criminal
conspiracy to defraud anybody?
A
No, sir. If I knew I would have never accepted any
of these loans. I mean, I am not a saint. I have done
things in my past that are wrong but --
MS. AHN: Objection, your Honor.
THE WITNESS: But this is not the case.
THE COURT: Overruled.
Q BY MR. MESEREAU: Did you ever intentionally make a
false statement to the Small Business Administration
A
Never.
Q
Or intentionally make a false statement to a bank?
A
No, sir.
Q
Did you ever think you were engaged in bank fraud
between March and August of 2020?
A
No, sir.
Q
Did you ever think you were engaged in wire fraud
between March and August of 2020?
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A
No, sir.
Q
Now, you know that the application for the PPP loan
apparently had IRS documents, 940 and 941 right?
A
I have been hearing, yes.
Q
Did you fill those out?
A
No, sir.
Q
Who filled them out?
A
My wife, Tammy. She filled them out.
Q
Did she show them to you before she submitted them?
A
No. I didn't even know the whereabouts of all
those documents until all of this has been put in front
of me.
Q
Okay. Ever hear of a place called Six Star Farms?
A
No, sir.
Q
Did you learn about it in this case?
A
No, sir.
Q
Now, you are being charged with aggravated identity
theft. You are aware of that; right?
A
Yes, sir.
Q
Did you ever steal anyone's identity?
A
No, sir.
Q
Use it for false purposes?
A
No, sir.
(Counsel confer.)
Q BY MR. MESEREAU: My co-counsel reminded me, do you
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know the name Anna Dzukaeva?
A
No, sir. Not until I was charged with her identify
theft.
Q
You ever heard of that person?
A
No, sir.
MR. MESEREAU: No further questions at this time,
your Honor.
THE COURT: Am I seeing that the clock correctly?
It is about 9 to; right?
MS. AHN: Yes, your Honor.
THE COURT: All right. Cross-examination.
MR. JOHNSON: Your Honor, I just have one
question. This is Peter Johnson.
THE COURT: Right. But you will have to deal with
that -- are you calling this witness also? Is that what
you are saying?
MR. JOHNSON: Yes. And it is just one question.
THE COURT: All right.
DIRECT EXAMINATION
BY MR. JOHNSON:
Q
I would like to show you Exhibit 57B at page 8 that
is already in the record. It will show up in the screen.
A
Oh, okay.
Q
Do you recognize anyone depicted in these photos?
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A
Yes, I do.
Q
Who do you recognize?
A
My wife, my wife's grandmother and my
mother-in-law.
Q
I will just --
A
And the lady next to my mother-in-law looks like
one of the agents that commonly visits the house for
Tammy. She is a real estate agent. Her name Zahva.
Q
If it is possible, can you tap the right-hand
screen -- the right-hand top corner of your screen?
A
Yes.
Q
Do you see something that moves down and there is a
pen there?
A
Yes.
Q
Can you tap the pen?
A
Uh-huh.
Q
Can you circle your wife, please.
Can you circle your wife's mother, please.
Can you circle your wife's mother's mother?
A
It is actually her father's mother.
Q
Can you circle your wife's father's mother?
A
Yes.
Q
Can you circle the person that you referred to as a
real estate agent that works with your wife?
Thank you. I have no further questions.
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THE COURT: Okay. Cross-examination.
CROSS-EXAMINATION
BY MS. AHN:
Q
Hello, Mr. Ayvazian.
A
Hello, ma'am.
Q
So you testified earlier that Richard Ayvazyan is
your older brother; is that correct?
A
Yes, ma'am.
Q
And you are married to Tamara Dadyan; is that
right?
A
That's correct.
Q
Is she related to Mr. Vahe Dadyan?
A
I believe so.
Q
Do you see him in the courtroom here?
A
Yes, I do.
Q
Where is he?
A
Right there next to counsel.
Q
Thank you. So earlier you testified that you were
sleeping in separate bedrooms; is that correct?
A
Correct.
Q
And that you were estranged; is that correct?
A
What does that mean?
Q
You said earlier that your relationship with her
was as a business relationship to raise your children; is
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that correct?
A
That's correct.
Q
So your marriage wasn't in a good state; is that
correct?
A
It is still not.
Q
And so your testimony is that you had your wife
fill out a PPP application for you after your marriage
broke up?
A
I did not have her fill out anything. She offered
to do everything. All she said was I'll take care of it,
and that is it.
Q
You testified earlier that your wife is not
involved in your business at all; is that correct?
A
Correct.
Q
And that you were very independent with your
business; isn't that correct?
A
Yes. It is a trucking business.
Q
And you testified earlier that you didn't want to
file taxings with her; is that correct?
A
Correct.
Q
And you were separated from her; is that correct?
A
I never filed for separation. I filed for a
divorce, but I did move out of the house for a couple of
weeks.
Q
And you were concerned about filing taxes with her;
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is that right?
A
Correct.
Q
You didn't know what her finances were like?
A
No. She doesn't get me involved in her finances.
Q
But yet you let her pick up and use your phone at
will; is that correct?
A
Yes.
Q
As a businessman, you have expenses; is that
correct?
A
Correct.
Q
And you pay for those expenses from bank accounts;
is that correct?
A
Yes.
Q
I'm going to show you page 4 from government
Exhibit 1.h, which was previously admitted, the account
opening statement for Allstate Towing and Transport,
LLC's Bank of America account ending in 7695.
Again, that is 1.h, page 4.
Do you see that in front of you?
A
Yes.
Q
And at the bottom, is that your name?
A
Yes.
Q
One manager?
A
Yes.
Q
Is that your signature?
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A
Yes.
Q
You testified earlier that you received a loan from
the SBA; is that correct?
A
I don't know what is an SBA and what is a PPP and
stuff like that.
Q
My apologies. You testified earlier that you
received money from the government; is that correct?
A
Yes, twice.
Q
And you pay close attention to your accounts; is
that correct?
A
I do.
Q
Going to page 69 of the same government exhibit, do
you see that in front of you?
A
Yes.
Q
Do you see the area I just magnified for July 13th,
2020?
A
Yes, ma'am.
Q
Did you notice that money coming into your account?
A
Yes.
Q
Is that one of the loans you received from the
government?
A
Yes. That is the second loan that I received.
Q
And you testified earlier that you used this money
for business expenses; is that correct?
A
Correct.
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Q
And to pay back your brother?
A
Yes.
Q
Do you see that line for July 27th, 2020 in front
of you?
A
I do.
Q
A withdrawal for $24,067.15?
A
Yes. That was a cashier's check that I took out.
Q
And that was about 14 days or two weeks after you
received the deposit?
A
Yes.
Q
And that was for a Harley-Davidson; isn't that
right?
A
Correct.
Q
I am going to show you now government Exhibit 1J.
This is page 1 of 1J. Do you see that in
front of you?
A
Yes, I do.
Q
And do you see your name under account holder?
A
Yes.
Q
And do you see below that it says e-signed?
A
Yes.
Q
By Artur Ayvazian?
A
Yes.
Q
And just to clarify, a Harley-Davidson is a
motorcycle; is that correct?
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A
That's correct.
Q
Is this your account for your business?
A
Yes. The sole proprietorship business.
Q
Thank you. I am going to show you page 23 of
government Exhibit 10. Do you see that in front of you?
A
I do.
Q
And in text message 3778, does it say Art's,
73,500?
A
That is what it says.
Q
I am going to show you previously admitted
government Exhibit 10-24, which is one of the text
message attachments.
Do you see that in front of you?
A
Uh-huh. I do.
Q
And you testified earlier Thanh Tran was a former
business partner; is that correct?
A
Yes, and a good friend of mine.
Q
Is the name in front of you Thanh Tran?
A
Yes. First time I am seeing this document.
Q
I am going to move that to the left, and on the
right I am going to go back -- excuse me. And on the
right I am going to show you government Exhibit 1P.
So on the left, which was government Exhibit
10-24, under beneficiary account number, do you see a
number that ends in 9700?
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A
I do.
Q
On the right, next to account number in government
Exhibit 1P, page 1, do you see a number ending in 9700?
A
Yes, I do.
Q
Going to page 59 on the right of government Exhibit
1P, do you see that in front of you?
A
I do.
Q
And it says Allstate Towing and Transport, LLC; is
that correct?
A
That's correct.
Q
For 73,500?
A
Correct. I have been wanting to know who made this
deposit.
MS. AHN: There is no question pending, your
Honor.
THE WITNESS: Thank you for pointing out.
Q
BY MS. AHN: You stated earlier that you love your
children; isn't that right?
A
Yes, ma'am.
Q
In fact, when you left Ms. Dadyan, they called you
to come back and you did; isn't that right?
A
Correct.
Q
Despite having difficulty with your marriage?
A
Yes.
Q
So you do a lot to stay with them; isn't that
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right?
A
That is all I care about is my children.
MS. AHN: No further questions, your Honor.
THE COURT: All right.
THE WITNESS: I would like to explain the $73,000,
your Honor. They never asked me to explain it.
THE COURT: There is no question pending. So if
there is no other question, that completes the testimony.
Thank you, sir. You are excused.
THE WITNESS: Thank you.
THE COURT: It is time for the lunch recess.
(The following proceedings were held outside the
presence of the jury:)
THE COURT: You may be seated.
THE COURT: What remains in the case, anything
else?
MR. JOHNSON: Your Honor, Mr. Vahe Dadyan will not
testify.
THE COURT: He will not.
MR. JOHNSON: He will not.
THE COURT: So is there any other testimony.
MR. KEOUGH: Your Honor, only the summary chart
witness.
THE COURT: Yes. I am rejecting the summary chart
for the reasons the government gave. Also, in a hotly
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contested trial like this with hundreds or thousands of
documents, to give the government this short notice and
expect them to ascertain the accuracy of the summary, so
called summary chart, even if it is ultimately supported
or referenced to exhibits in evidence, would unfairly
handicap the government.
And also it appears to me that many of the
things you -- that are on the summary chart can be argued
in some ways. It appears to be somewhat more
demonstrative than summary. And you can argue what is in
the chart, but, for those reasons, it is not going to be
received.
What else is there in the case?
MR. RAM: Motions to renew.
THE COURT: Well, aside from that. Any other
evidence?
Let me ask the defense to -- and I have asked
this question a number of times, but I am going to ask it
again. I guess, Mr. Ram, you are the person addressing
this issue. I want to get the government's response at
this point. What is the argument regarding
multi-conspiracy? And, in particular, not the argument
which I have in mind about other conspiracies such as the
bust out scheme or other credit card schemes or mortgage
fraud scheme or whatever.
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But, in this case, in other words, my
perception at this point is that you are arguing at least
for purposes of the issue that there may be two PPP
conspiracies involved, but they are disconnected and
they, arguably from your standpoint, are not the same
conspiracy that the government alleged. So that is the
part that I want you to explain in as much detail as you
can.
MR. RAM: Yes, your Honor. Thank you.
So there are -- the government has charged two
conspiracies as one. The two conspiracies with --
THE COURT: Okay. Now, give me, let's call it
conspiracy 1, tell me what that is, and then tell me what
you think conspiracy 2 is.
MR. RAM: Yes, your Honor. Conspiracy 1 consists
of Manuk Grigoryan and his group.
THE COURT: Who was his group?
MR. RAM: His group consists of Edward Paronyan,
Arman Harapetyan, Payrur Harapetyan and other
individuals.
THE COURT: And two of those are defendants in the
case?
MR. RAM: Correct, your Honor.
The other group consists of the what we will
call the Dadyan group which consisted of Tammy Dadyan and
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individuals that we heard earlier today in the testimony
from Exhibit 10 referenced. I can pull those names for
you, but it is Arshak Martirosyan, Diana, Gregor Tatioan,
referenced as Greg in the text messages, your Honor. Art
Martirosyan referenced as Art in the text messages.
THE COURT: Art who? Wasn't that the first person
you mentioned.
MR. RAM: Arshak.
THE COURT: Are there two Martirosyans?
MR. RAM: Arshak Bartunyan, your Honor.
THE COURT: Arshak Bartunyan. And the third was
Artashes Martirosyans; is that it?
MS. NEWCOMER: Artash. M-A-R-T-I-R-O-S-Y-A-N.
THE COURT: Okay. So those are the two
conspiracies in the case?
MR. RAM: Correct, your Honor.
THE COURT: And your client is charged as a
conspirator. Who did he conspire with if he conspired at
all?
MR. RAM: Reading the government's allegations,
your Honor, he would be a conspirator in the Grigoryan
group, and he would -- the allegation is that he is also
a conspirator in the Dadyan group.
THE COURT: I see.
THE COURT: Just one moment. When I pause, it
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doesn't mean that there can't be silence for a few
minutes.
So are you saying that the evidence, if it
shows your client to be involved, he would be involved
with the Tamara Dadyan group as you described it and
the -- and also the Grigoryan group?
MR. RAM: Yes. That is the allegations, your
Honor.
THE COURT: But there is no third group with him?
MR. RAM: Third group, your Honor?
THE COURT: Yes. In other words, is there, at
least structurally, the possibility of a third group
meaning your client and some of the other conspirators
other than Tamara Dadyan and Grigoryan?
MR. RAM: There is, your Honor. There is
potentially a third group with Tamara Dadyan and Richard
Ayvazian, but the two main focus groups I would say is
the Manuk Grigoryan crew and the Tamara Dadyan group.
Both groups were attempting to obtain PPP loans.
THE COURT: Okay. We are now at the end of the
case, and you are going to argue it shortly. Who are you
going to argue is -- I just had a memory loss for a
second. The person we have been talking about for the
last week-and-a-half, who is that person?
MR. RAM: Manuk Grigoryan, your Honor?
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THE COURT: No. No. Who is the Russian name that
we were talking about?
MS. AHN: Anna Dzukaeva? Anton Kudiomov?
THE COURT: No.
MS. AHN: Victoria Kauichko.
THE COURT: I knew I would get to it eventually.
I need prompting to make myself coherent.
So who are you going to argue is Kauichko?
MR. RAM: We are going to debunk -- we are going
to argue that the government's theory has been debunked,
that it was avatar theory where Kauichko was Marietta
Terabelian and Kudiomov was Grigoryan and Zhadko was Rich
Ayvazian. And we are going to argue --
THE COURT: Say that again now.
MR. RAM: Sure. So the government is essentially
alleging that Richard Ayvazyan was Zhadko, that Anton
Kudiumov was Grigoryan and that Kauichko was Marietta
Terabelian. Our argument is going to be that the
evidence that we have seen at this trial fairly
explicitly shows that that is simply not the case, and,
if anything, multiple people at any given time controlled
these identities. Specifically, it just depends on the
timing --
THE COURT: So maybe more to the point, in that
exhibit with the text messages, who was -- who are you
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going to argue Tamara Dadyan was talking to?
MR. RAM: I am going to argue it essentially two
ways, your Honor. I shouldn't say ways. Two angles.
Which is first the government hasn't proved beyond a
reasonable doubt that it was Rich Ayvazyan, but if you
take the government for face value and essentially its
entire focus was to show Rich Ayvazian was the one
talking to Tammy. And if you accept that proposition to
be true, the government has to lose its case because that
is two different conspiracies and two different schemes.
It is Rich Ayvazian with the Manuk group, and
it is Rich Ayvazian with the Dadyan group. They are not
joint ventures. There is no interdependence, and one
didn't rely on the other. And there is a series of
differences that we will tease out from the evidence
presented --
THE COURT: All right. I get your argument. Let
me hear from the government because I haven't heard your
position on this as of yet.
MS. AHN: Yes, your Honor.
THE COURT: Take the lecturn if you can.
Your Honor, there just is no factual basis
for the argument that there is multiple conspiracies.
THE COURT: Don't start out with a conclusion.
MS. AHN: Yes, your Honor.
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THE COURT: Let me hear the argument how you
analyze this. We heard how Mr. Ram did. I am giving you
the opportunity to tell me how you view the issue of
multiple conspiracies or the conspiracy alleged. And
maybe the best way to direct you would be what is the
evidence in the record regarding the interdependency of
Grigoryan Ayvazian, Richard Ayvazian and Tamara Dadyan.
MS. AHN: Yes, your Honor. I think probably the
most illustrative way of looking at it is to just look at
the money. If you look at the money, you see that it
flowed between the defendants that were charged in the
conspiracy.
So, for example, if you go to Government
Exhibit 115 which is one of our summary exhibits. I will
pull up for you here. This is page 8. You can see here
money coming in into the Hayrapetyan Hart Construction
account flowing out to yet another Hayrapetyan Hart
Construction account. And keep in mind Hayrapetyan is
part of the other group according to defense.
THE COURT: Let's make sure that we don't use
other, his, this. Other meaning Grigoryan; right?
MS. AHN: Yes.
THE COURT: Say Grigoryan so I am clear.
MS. AHN: Yes, your Honor. So the defense is
alleging that Mr. Harapetyan is part of the Grigoryan
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group. However, what you see is money going through --
from the PPP funds going through the Hayrapetyan accounts
over to the Fiber One, Iulia Zhadko and Anna Manukyan
accounts. And you may recall that, on Richard Ayvazyan's
phone, there was a driver's license for Anna Manukyan as
well as a credit card front and back in the name of Anna
Manukyan. Mr. Ayvazian also had a credit card with his
name on it and also Fiber One again making the link
between Mr. Avazyan and Fiber One.
THE COURT: And didn't these monies -- hold it.
Didn't the funds that went into those accounts ultimately
from the government's evidence move to an account that
the government says is Ayvazian's account or to some
escrow that ultimately was for his benefit?
MS. AHN: Yes, I believe you are thinking of the
previous page which I was about to turn to if you give me
a moment, your Honor.
THE COURT: Yes.
MS. AHN: So this is page 7, actually, of Exhibit
115, and here you see Mr. Paronyan, Artash Grigoryan --
well, the Artash Grigoryan that we actually believe was
used by Manuk Grigoryan. The Artur Ayvazian, the Iulia
Zhadko, the Tamara Dadyan Secureline Funding, these
accounts all received PPP or EIDL funds. They go through
additional accounts and as your Honor recalled, all go to
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benefit Mr. Richard Ayvazyan and Ms. Marietta Terabelian.
THE COURT: I see. So that is the principle
connection and interdependence?
MS. AHN: It is not the only one but probably the
simplest and most succinct way.
THE COURT: Well, I am following your argument,
but the other item that I remember, may not be the only
one, was the real estate broker when she testified there
was Grigoryan with Richard Ayvazyan at least at one or
two showings of homes.
Then there was a third person who seemed to
have a name that I think was one of the alleged synthetic
names; correct?
MS. AHN: Yes. Mr. Anton Kudiomov.
THE COURT: Who was Anton Kudiomov? I mean,
anyone know who that -- is there a real Anton Kudiomov.
MS. AHN: Yes. He was a foreign exchange student
that was temporarily in the United States but had left by
the time of the pandemic.
THE COURT: So when the real estate agent
testified, was she testifying about things that happened
from March to August of 2020?
MS. AHN: Yes, your Honor
THE COURT: So had Kudiomov gone back to Russia by
then.
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MS. AHN: I don't recall the specific country, but
he certainly was not in the United States, your Honor.
THE COURT: So we don't know who that person
referred to as Kudiomov was?
MS. AHN: We have our suspicions, but we don't
know definitively.
THE COURT: Suspicions aren't --
MS. AHN: Yes, sir
THE COURT: So what other evidence is there? I am
not suggesting that what you have said so far is
insufficient. I have to think about it, but what other
evidence is there?
MS. AHN: Well, I would refer you back to --
excuse me, your Honor.
Going to Government Exhibit 116 which is again
one of our summary exhibits.
THE COURT: Okay.
MS. AHN: This shows the comparison between
various PPP and EIDL loan applications. There is
actually three charts like this all showing the exact
same numbers on the Form 940, showing the same Gusto
payroll report, same monthly payroll, same timeframe,
same reported taxes, everything the same. Some of these
even report the exact same employees despite having --
being for completely different industries.
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This shows that there is commonalities, common
hand or a common group of hands submitting these
applications. They include the Fiber One Media, Mod
Interiors, et cetera. I would point you to the Mod
Interiors one, your Honor, because we looked at that
loan, and it actually gets funded into an account where
the two authorized representatives were Arman Injijian
and Richard Ayvazyan. I would note that the similarities
in this group include the Redline Auto Collision loan
submitted in the name of Edward Paronyan.
In addition, several of these loans including
I believe the -- I think it was the Fiber One, may have
been the LK Design, Liudmyla Kopytova one --
THE COURT: I missed what you just said.
MS. AHN: I would note that one of these loans, I
believe it was either the Fiber One Media or the LK
Design loan on a different page, that listed the 6000
number as the contact number for the president, the
supposed president of this synthetic identity. And that
6000 number is Mr. Richard Ayvazyan's phone. It is the
phone that was found in his house during the search
warrant, again, connecting these loans to Mr. Richard
Ayvazyan as well as of course through the text messages,
Ms. Tamara Dadyan, Edward Paronyan, et cetera, et cetera.
THE COURT: Understood, but with regard to
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Grigoryan, the representation by Mr. Ram was that his
group included Paronyan and -- I can't say it --
Hayrapetyan?
MS. AHN: Yes. Mr. Arman Harapetyan, your Honor.
THE COURT: And that is someone who also was a
defendant in this case?
MS. AHN: Yes, your Honor. His account was used.
THE COURT: And where does he appear on these
summary charts?
MS. AHN: We do not believe he actually submitted
a PPP or EIDL loan in his name. Instead his accounts
were used to funnel money.
THE COURT: And is that in evidence?
MS. AHN: Yes, your Honor. That is part of the
summary chart we just looked at, the flow of funds chart,
your Honor.
THE COURT: Go back to that one again.
MS. AHN: Yes, your Honor. Page 8, your Honor.
THE COURT: Just one second.
So the first set of boxes to the left on
this chart represents where the PPP funds were first
deposited; is that right?
MS. AHN: Yes, your Honor. The first line here
references the actual PPP or EIDL loan applications going
into the second set here.
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THE COURT: So that is where the PPP funds went
from the government to an account?
MS. AHN: Yes, your Honor.
THE COURT: And there it goes to Harapetyan and
Zhadko, and then to, I see, another Hart Construction
account. And then, from there, to a bunch of accounts,
Zhadko, 501, Anna Manukyan, and your position is that
Richard Ayvazyan controlled those accounts?
MS. AHN: Our position is that he ultimately
benefited from the PPP funds.
THE COURT: But when it goes in that chart to the
final column on the right, where would the money go after
that? Would that be the next chart?
MS. AHN: Let me just take a look, your Honor.
(Pause in proceedings.)
MS. AHN: So we don't have that on this specific
exhibit, your Honor, but I will point out that the Iulia
Zhadko identity was used to purchase -- was used to
purchase the home where Ms. Terabelian's mother had paid
the utilities for.
THE COURT: And what was the address of that home?
How is it referred to?
MS. AHN: Was the Calle Primavera residence, your
Honor.
THE COURT: And Dadyan, is Vahe Dadyan is also a
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conspirator, alleged conspirator in this case; correct?
MS. AHN: Yes, your Honor.
THE COURT: So in the government's view of the
evidence, how is he a conspirator?
MS. AHN: We believe he conspired with Ms. Dadyan
and Richard Ayvazyan and the other co-conspirators.
THE COURT: But what does the evidence show
regarding what did he in this case?
MS. AHN: Yes, your Honor.
THE COURT: It is a little confusing for me some
times because I think of what was said outside the
presence of the jury, and I can't consider that. I only
can consider the record here. So what does the record --
I mean, I know he made the loan on behalf of the Voyage,
but a lot of what he said outside the presence of the
jury wasn't produced in this trial.
MS. AHN: That is true, your Honor. The evidence
is that the government's argument or the government's
evidence shows that Mr. Vahe Dadyan, with his cousin
Tamara Dadyan, submitted or caused the submission of the
Voyage Limo PPP loan which went into his account and was
later transferred to the Runyan Tax Service account which
of course went to the home of Ms. Terabelian's relative.
With respect to the --
THE COURT: And then as I remember it, there was
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some mention in the trial of some of these parties who
cooperated in the PPP applications getting 35 percent or
something like that of the proceeds?
MS. AHN: Yes, your Honor.
THE COURT: My recollection is that with Dadyan
actually it was closer to 50 percent. He got back some
months later --
MS. AHN: Yes, your Honor.
THE COURT: -- $75,000.
MS. AHN: Yes. The money appears to have sat in
the account for a while until it was transferred over to
Runyan tax service on or about July 3rd, and it was after
that point there are a number of text messages from
Tamara Dadyan to Rich New asking him to make sure to
transfer the money to Vahe.
THE COURT: Who said what to whom there?
MS. AHN: The Tammy participant is texting the
Rich New participant telling her make sure you wire the
funds for Vahe. It actually happens quite often.
THE COURT: Make sure you do what.
MS. AHN: Wire the funds to Vahe.
THE COURT: Yes.
MS. AHN: It appears that Rich New had attempted
to wire the funds several times. For whatever reason, it
didn't work according to the text messages, and --
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THE COURT: Wire them where?
MS. AHN: To -- it appears based upon the text
messages to the V & D Limo account, your Honor.
THE COURT: I see. Okay.
Anything else?
MS. AHN: Just one note, your Honor, according to
the Ninth Circuit case, US versus Escalante, a person may
be a member of a conspiracy even if they don't know all
of the participants in that conspiracy.
THE COURT: I mean, that is just -- I guess they
don't use that expression anymore -- warmed up law, but
the requirement in law of conspiracy that, yes, someone
can be a conspirator by not -- if that person did not
conspire with all the conspirators. But my view of the
law is that if someone conspired with just another member
of the conspiracy, and in cases like this where there are
others, the defendant who conspired with just one other
conspirator would have to believe or know that, I guess
know that that conspirator was just part of a larger
conspiracy.
MS. AHN: Yes, your Honor. And with respect to
that, I would note that he received the money from
Richard Ayvazian or the Rich New participant is the one
that was sending him the money, and, furthermore, when
that transfer, the $155,000 transfer went, it was listed
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with the purpose of payroll which is obviously not what
that is for. It is consistent with the other indicators
of fraud.
THE COURT: And on the application for the Voyage
PPP, there was false information about the details of the
company such as number of employees and some other
things; correct?
MS. AHN: Yes, your Honor
THE COURT: All right. Let me hear final word
from the -- from the -- Mr. Ram on the argument that was
made by the government.
THE COURT: Go ahead.
MR. RAM: Big picture it sounds like we have a
factual dispute. Let me put down a chart that Ms. Ahn
started with.
It was page 8, your Honor, of I believe
Exhibit 115. Okay. And I believe Ms. Ahn said this
explains how there is interdependence and a joint venture
amongst the two groups that we posited are the multiple
conspiracies.
THE COURT: Wait. I am understanding that
Hayrapetyan was part of the Grigoryan group as you
described it and that he is in the loop of the monies
that the government argues ultimately were transferred
for the benefit of Richard Ayvazian.
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MR. RAM: Right. I think your Honor can see it.
So every entity on this page is Manuk's crew or Manuk's
IP address which has come out at trial. So there is
really two points to make here, and I will make it short,
your Honor, because I think we have had this discussion,
but, in short, all of this is Manuk's crew. Arman
Harapetyan doesn't know anyone in the Dadyan crew.
Right.
And it is not just one person. There is other
patterns, your Honor. These are construction companies,
contracting companies. That was Manuk's MO. That comes
out from the search of his home and the list of entities.
This is all Manuk's crew. The other point the government
made, your Honor, is that, well, this money ended up with
Richard Ayvazyan.
I don't want to give away the farm for
tomorrow, your Honor, but big picture, we are almost
there, it is unremarkable if that is true, that Richard
Ayvazyan is getting money from Grigoryan's crew and
possibly even Dadyan's crew. It is unremarkable
because --
THE COURT: Why?
MR. RAM: -- because the argument is Richard
Ayvazyan is, according to their allegation, he is in both
conspiracies. The way they charge it, Richard Ayvazyan
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is part of Manuk's crew.
THE COURT: All right. I have what you are
saying. Thank you.
MR. RAM: Okay.
THE COURT: Let me ask you this the -- I have been
working on the jury instructions as we go here. What I
have done is looked at the government's proposed, the
defendant's proposed, and the -- and if there was a model
Ninth Circuit jury instruction on the same matter. I
have a few questions regarding the instruction that talks
about half truths or omissions. My understanding -- you
can sit down, Mr. Ram.
MR. RAM: Thank you, your Honor.
THE COURT: My understanding of the way the case
has gone is that I don't see where half truths come in.
It seems to me that the way the evidence has been
introduced, there were falsehoods, not half truths.
Where are the half truths in the case?
MS. AHN: Your Honor, I think it lies in the idea
of the synthetic identity, your Honor. That a person
does exist and a real person does have this name, but
this person doesn't have these other identifiers and
certainly was not in the country applying --
THE COURT: But that isn't a half truth. That is
a falsehood. If they are using an identity of someone
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who may have been an exchange student at some point and
then that person had not been in the country for years,
that is a falsehood. It is not a half truth.
MS. AHN: We agree. We think the half truth is
still a false statement in the sense that, for example,
Mr. Artur Ayvazian cover a role towing company or
Mr. Vahe Dadyan could have a real limo company, but they
may not have 11 employees so portions of the
applications --
THE COURT: But that isn't what a half truth is
about. I mean, a half truth to me is when someone makes
a statement that is knowingly misleading. In other
words, you are saying something and you are trying to
mislead by not including the rest of it which you know
would create a different impression. What you are
arguing doesn't seem to me to be in the realm of half
truths.
Okay. Let's leave that alone.
Second thing, I don't recall there being any
404(b) evidence in the case.
MS. AHN: The government was very careful to try
and include only direct evidence.
THE COURT: What was the 404(b) evidence?
MR. LITTRELL: Exhibit 16B, I think was 404(b)
evidence.
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THE COURT: What is that?
MR. LITTRELL: That is the image from 2018 on
Ms. Terabelian's cell phone. It is an image that it
predated conspiracy by two years.
MS. AHN: We filed motions on this --
THE COURT: Let me just hear one argument at a
time.
MR. LITTRELL: It is just by definition it is
other acts because it occurred --
THE COURT: Other acts are different than evidence
that is intertwined with things. So why is this
another -- another act. In other words, what is the
other act?
MR. LITTRELL: It is the capturing of that image
two years before on the cell phone. It doesn't have any
relevance unless it is another act.
THE COURT: Why -- I mean, I don't understand it
being another act. Circumstantial evidence doesn't have
to be another act.
MR. LITTRELL: No. But it has to be relevant to
the charged offense.
THE COURT: I mean, I have ruled that it is
sufficiently relevant given the overall evidence. So,
all right. Let me hear from the government on that
point.
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MS. AHN: Yes, your Honor. I don't believe we
have actually introduced any 404(b) evidence, your Honor.
THE COURT: So you would argue that isn't 404(b)?
MS. AHN: Yes, your Honor.
THE COURT: What other --
MR. RAM: Just on the 404(b) point, your Honor.
You may find that it is inextricably intertwined, but
there has been quite a bit of discussion about
identification of acts that occurred prior to 2020 that
involve whether it is credit card bust outs or aggravated
identity theft or EDD fraud.
THE COURT: We haven't heard any evidence about
that. You have argued that lots of times. I haven't
allowed any evidence about that.
MR. RAM: So, for example, Manuk Grigoryan's 2017
aggravated identity theft, that came in through two
witnesses. I am not advocating, your Honor.
THE COURT: All right. I got it. Okay. And in
the Cellebrite exhibit. I am referring to the Cellebrite
exhibit that included the mass of information from the
cell phones, and that was allowed in evidence because it
was a foundation for the preparer of the subgroup to say
that the subgroup was derived from the mass of documents;
correct?
MS. AHN: Yes, your Honor
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THE COURT: But it seems to me that exhibit should
not go to the jury except those portions of it that
relate to the subgroup.
MS. AHN: Yes, your Honor. We are fine with the
government's exhibits.
THE COURT: There ought to be a redaction. That
is what I am saying.
MS. AHN: Yes, your Honor. And the only portions
of the Cellebrite report that the government intends to
use or has used are identified separately as a government
exhibit. So we are fine with the actual physical
exhibits not going back, your Honor.
THE COURT: Okay. Now, let me ask you this. I
can't see that far.
MS. AHN: It is about 10 to 1:00, your Honor.
THE COURT: So we all have to get, I guess, a
little lunch, and I have to discuss the jury instructions
with you. Should we begin the arguments today? Or wait
until tomorrow? What is -- what do you think?
MR. RAM: I will speak for myself. I suspect the
preference would be to do them altogether on the same
day.
MR. LITTRELL: I prefer to get started just so we
don't lose time.
THE COURT: Okay. What is the government's view?
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MR. FENTON: We have no objection to waiting until
tomorrow. That is fine, or we can start today. We can
start today or we can start tomorrow.
THE COURT: How long did you say your argument was
going to be again?
MR. FENTON: Hour-and-a-half to two hours, and we
have no preference. We can do it either way.
THE COURT: I see. Well, it is 1:00 o'clock now.
(Recess.)
(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 23, 2021
/s/ Katie Thibodeaux, CSR No. 9858, RPR, CRR
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Case 2:20-cr-00579-SVW Document 676 Filed 07/09/21 Page 150 of 170 Page ID
#:10709
MR. FENTON: [75] 5/19 7/18
7/24 8/5 8/14 9/8 9/14 11/3
12/20 14/18 15/14 17/4 17/19
17/25 19/9 20/2 20/9 21/21
22/8 23/17 24/10 29/17 33/20
34/18 34/22 35/21 36/7 36/16
37/17 38/25 39/5 50/7 50/11
51/7 52/3 52/8 52/11 53/8
53/14 57/17 58/4 58/14 60/1
60/15 61/7 62/6 64/2 64/22
64/25 66/3 66/24 67/7 67/10
67/15 67/23 69/7 70/5 70/14
70/21 70/23 71/1 71/6 71/15
71/19 72/2 72/7 72/13 72/20
72/23 73/4 73/9 73/12 76/18
148/25 149/5
MR. FRASER: [1] 91/22
MR. JOHNSON: [6] 46/16
69/11 116/11 116/16 125/16
125/19
MR. KEOUGH: [17] 71/21 72/4
72/11 73/11 73/16 73/19 74/1
74/10 74/22 75/3 75/9 75/12
75/18 75/24 76/2 76/11
125/21
MR. LITTRELL: [8] 5/24 6/3
145/23 146/1 146/7 146/13
146/19 148/22
MR. MESEREAU: [14] 39/9
39/16 69/14 77/19 78/1 78/3
80/6 89/18 89/21 97/7 97/12
113/4 113/7 116/5
MR. RAM: [70] 5/11 5/16
7/16 9/12 10/5 10/8 11/1
11/6 11/24 12/1 12/17 13/8
14/20 14/25 17/7 23/20 26/18
26/23 29/15 29/21 29/24 31/9
50/4 50/17 50/19 50/21 51/23
52/17 53/3 56/9 56/19 57/11
58/8 58/23 59/3 59/5 62/8
64/9 65/5 65/23 66/7 66/9
67/9 68/16 77/12 77/14
126/13 127/8 127/14 127/17
127/22 128/7 128/9 128/15
128/19 129/6 129/9 129/14
129/24 130/8 130/14 131/1
142/12 142/25 143/22 144/3
144/12 147/5 147/14 148/19
MS. AHN: [64] 88/22 97/3
97/8 108/11 110/16 110/18
114/12 116/9 124/13 125/2
130/2 130/4 131/19 131/24
132/7 132/21 132/23 133/14
133/18 134/3 134/13 134/16
134/22 134/25 135/4 135/7
135/12 135/17 136/14 137/3
137/6 137/9 137/13 137/17
137/22 138/2 138/8 138/13
138/15 138/22 139/1 139/4
139/8 139/16 140/3 140/7
140/9 140/16 140/20 140/22
141/1 141/5 141/20 142/7
144/18 145/3 145/20 146/4
146/25 147/3 147/24 148/3
148/7 148/14
MS. NEWCOMER: [1] 128/12
THE CLERK: [7] 6/10 13/7
67/22 67/25 69/19 69/24
77/22
THE COURT: [248]
THE INTERPRETER: [1] 60/9
THE WITNESS: [28] 8/10 8/18
12/3 12/13 12/15 18/2 19/11
20/11 23/23 24/13 35/25
39/10 50/13 51/10 52/14
52/20 57/21 65/13 65/15 67/1
77/24 88/24 108/13 110/20
114/13 124/15 125/4 125/9
$
$1 [1] 85/17
$1 million [1] 85/17
$1,300 [1] 111/4
$10,000 [2] 109/14 110/4
$110,000 [3] 49/23 49/25
51/12
$125,000 [2] 109/25 110/1
$155,000 [1] 141/25
$24,067.15 [1] 122/6
$25,000 [1] 53/1
$30,000 [1] 86/15
$4 [1] 79/22
$40,000 [1] 109/23
$73,000 [1] 125/5
$75,000 [1] 140/9
$875.99 [1] 27/9
$90,000 [1] 87/1
-
-and [2] 2/5 2/8
/
/s [1] 150/12
0
001 [1] 75/12
1
1.h [2] 120/15 120/18
10 [23] 4/14 12/25 13/5 13/7
13/11 13/14 18/5 18/6 19/14
69/21 98/18 99/3 99/9 99/16
100/10 100/19 100/25 101/8
101/8 106/15 123/5 128/2
148/15
10,000 [1] 109/17
10-24 [2] 123/11 123/24
10/13 [1] 64/17
10/14 [1] 64/17
10036 [1] 2/18
1004 [2] 40/2 40/10
1006 [2] 71/6 71/13
10100 [1] 3/15
102 [4] 4/13 5/18 5/23 72/21
103 [4] 4/13 5/18 5/23 72/21
105 [1] 16/1
1099's [1] 108/15
10:00 o'clock [1] 107/5
10:34 [1] 69/19
10:47 [1] 77/10
10:59 [1] 77/10
10th [1] 79/17
11 [4] 4/14 4/15 82/2 145/8
1114 [1] 2/17
112 [2] 4/15 25/8
115 [3] 132/14 133/20 142/17
116 [2] 4/9 135/15
118 [1] 4/10
12 [2] 4/15 79/22
12:37 yesterday [1] 70/13
12:47 they [1] 70/16
13 [2] 60/7 64/17
13-speed [1] 83/19
130 [3] 86/14 86/20 86/25
1330 [1] 2/23
135 [1] 16/16
138 [3] 16/1 16/13 17/2
13th [5] 63/24 64/22 65/20
68/9 121/15
14 [4] 64/17 82/1 82/2 122/8
1400 [1] 2/10
149,000 [1] 110/12
149,900 [1] 110/12
14th [3] 26/2 27/7 64/15
15 [14] 4/14 6/19 7/5 7/18
10/10 18/17 26/5 26/15 26/25
28/8 62/24 64/14 67/17 68/5
15928 [1] 7/14
16 [2] 82/3 90/9
16B [1] 145/24
17 [1] 82/4
17450 [3] 31/20 61/17 78/15
18 [8] 4/14 10/11 11/3 11/6
20/14 20/15 20/17 80/13
18-wheeler [1] 82/17
19 [4] 20/23 20/25 24/18
72/21
1900 [1] 2/15
1935 [1] 3/12
1989 [2] 79/16 79/21
19A [1] 23/3
19B [3] 21/4 21/8 24/18
19B1 [2] 21/12 22/18
1:00 [1] 148/15
1:00 o'clock [1] 149/8
1B21 [1] 13/16
1B85 [1] 20/18
1J [2] 122/14 122/15
1P [4] 41/12 123/22 124/3
124/6
1R [7] 26/5 26/9 27/1 28/8
62/22 67/16 68/5
1st [2] 1/22 10/3
2
20 [1] 87/10
20-579 [1] 1/8
20036 [1] 2/23
2006 [2] 78/20 82/15
2008 [1] 93/10
2012 [1] 82/6
2017 [2] 96/10 147/15
2018 [1] 146/2
2019 [6] 16/22 17/4 86/13
86/14 108/15 109/2
2020 [33] 10/3 15/7 16/22
17/11 17/14 17/15 17/24
18/10 19/9 19/20 20/9 21/21
26/2 27/19 45/18 47/1 60/21
66/17 84/2 86/10 86/14 103/5
103/9 109/3 113/24 114/2
114/6 114/22 114/25 121/16
122/3 134/22 147/9
2021 [3] 1/17 5/1 150/10
20530 [1] 2/10
21 [4] 19/20 27/18 62/18
64/12
216 [1] 3/13
21st [4] 60/21 63/6 63/19
64/19
224 [1] 7/14
23 [7] 1/17 4/13 5/1 5/17
5/23 123/4 150/10
23rd [1] 17/4
24 [3] 19/13 123/11 123/24
24th [1] 63/5
25 [4] 4/13 4/15 5/17 5/23
27th [1] 122/3
28 [1] 150/4
29 [2] 4/16 4/16
2930 [2] 18/7 18/10
3
30 [5] 13/1 14/7 86/20 94/6
109/23
300 [4] 3/16 4/16 58/8 58/11
31 [1] 4/5
312 [1] 2/6
3280 [1] 18/18
35 percent [1] 140/2
350 [2] 1/22 3/5
3537 [2] 63/8 68/13
3778 [1] 123/7
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3
3844 [1] 18/24
3893 [2] 19/15 19/20
3895 [1] 19/15
39 [1] 4/5
3900 [1] 2/20
3rd [1] 140/12
4
404 [6] 145/20 145/23 145/24
147/2 147/3 147/6
409 [1] 3/20
41 [4] 4/13 5/17 5/23 78/11
4288 [3] 13/2 14/9 14/10
43 [3] 4/13 5/17 5/23
4311 [1] 1/22
44 [3] 4/13 5/17 5/23
46 [4] 4/6 27/13 28/13 63/7
4910 [3] 20/19 50/1 51/13
5
5/28/2020 [1] 18/10
50 [4] 4/13 5/17 5/23 140/6
500 [1] 47/20
501 [1] 138/7
5268 [3] 26/13 27/8 63/15
55-46 [2] 27/13 28/13
57 [4] 94/16 97/7 97/14
97/14
57.f [1] 93/20
57.g [1] 94/6
57.h [3] 96/7 96/22 97/16
57.k [8] 98/18 99/3 99/9
99/16 99/25 100/10 100/25
101/8
57.l [1] 101/15
579 [1] 1/8
57B [6] 45/14 89/23 90/13
90/24 91/9 116/22
57k [1] 100/19
58 [1] 4/16
59 [7] 4/16 28/5 29/2 29/12
29/16 29/21 124/5
5th [3] 2/14 3/8 45/18
6
6000 [6] 20/20 20/24 21/4
21/9 136/17 136/20
601 [1] 3/8
6150 [1] 29/15
62 [1] 4/6
633 [1] 2/14
651 [1] 3/21
67 [1] 4/7
69 [1] 121/12
6:00 a.m [1] 35/16
6:00 o'clock [1] 71/3
7
720 [1] 3/8
73,500 [2] 123/8 124/11
74 [4] 4/15 11/10 12/19
12/23
75 [3] 4/13 5/18 5/23
753 [1] 150/4
76 [2] 68/15 68/16
7695 [1] 120/17
78 [1] 4/9
8
834 [1] 55/7
85 [1] 87/1
9
90012 [2] 1/23 2/7
90067 [1] 3/16
90071 [2] 2/15 3/9
902.11 [2] 5/15 5/21
90277 [1] 3/21
903 [1] 3/5
91208 [1] 3/13
91316 [1] 78/15
92673 [1] 3/6
940 [2] 115/3 135/21
941 [1] 115/3
94105 [1] 2/21
9700 [2] 123/25 124/3
9858 [2] 1/21 150/12
9:14 [1] 5/2
A
A-R-T-U-R [1] 77/25
A-Y-V-A-Z-I-A-N [1] 78/1
a.m [5] 1/16 5/2 35/16 77/10
77/10
able [4] 45/3 48/11 62/3
62/6
about [69] 6/6 10/4 14/21
16/13 26/19 28/13 39/23 40/5
40/15 40/19 43/4 47/13 49/10
50/23 50/24 53/7 53/11 53/14
53/16 53/20 54/8 58/21 59/9
60/3 62/14 63/11 63/21 64/6
65/13 66/2 66/6 70/8 70/25
71/3 71/5 71/25 73/4 76/25
80/3 86/9 87/1 105/13 105/20
106/16 108/3 109/23 110/22
111/3 111/16 113/20 115/15
116/9 119/25 122/8 125/2
126/23 129/23 130/2 133/16
134/21 135/11 140/12 142/5
144/11 145/11 147/8 147/12
147/14 148/15
above [1] 150/7
above-entitled [1] 150/7
Absolutely [2] 45/10 52/4
accept [2] 83/20 131/8
accepted [1] 114/10
access [5] 74/16 90/18
102/14 102/25 103/2
accompanied [2] 5/15 5/20
according [4] 132/19 140/25
141/6 143/24
account [51] 14/12 21/10
26/12 26/13 27/8 41/3 41/7
41/8 41/9 41/18 41/19 42/10
49/21 51/17 52/24 62/23 63/6
63/10 63/13 64/17 66/16 75/6
109/15 110/6 110/7 110/11
112/5 112/6 112/10 112/10
112/13 112/17 120/15 120/17
121/18 122/18 123/2 123/24
124/2 132/17 132/18 133/12
133/13 136/6 137/7 138/2
138/6 139/21 139/22 140/11
141/3
accountant [2] 88/3 112/11
accounts [17] 67/5 73/5
74/16 75/25 76/14 80/17
112/3 120/11 121/9 133/2
133/4 133/11 133/24 133/25
137/11 138/6 138/8
accumulated [1] 111/19
accuracy [1] 126/3
accurate [3] 70/15 76/23
76/25
act [5] 146/12 146/13 146/16
146/18 146/19
active [1] 82/10
activity [2] 59/12 59/13
acts [3] 146/9 146/10 147/9
actual [5] 66/23 76/22
110/25 137/24 148/11
actually [26] 13/4 19/16
25/24 27/18 28/5 28/7 32/20
40/7 44/22 51/20 60/18 62/24
63/18 65/25 67/4 76/23 77/6
117/20 133/19 133/21 135/20
136/6 137/10 140/6 140/19
147/2
add [1] 90/17
addition [2] 57/22 136/11
additional [1] 133/25
address [24] 9/25 30/24 31/3
32/24 32/25 40/7 44/16 48/14
48/23 48/25 49/2 49/4 49/7
59/14 61/17 73/3 75/17 76/13
77/4 77/7 78/14 90/17 138/21
143/3
addresses [17] 48/17 58/22
59/10 72/25 74/3 74/5 74/16
74/18 74/22 74/24 75/23 76/4
76/6 76/9 76/9 76/11 76/16
addressing [1] 126/19
adequate [1] 51/5
Administration [3] 82/1
108/23 114/17
admissibility [1] 71/8
admit [4] 7/17 11/2 12/18
29/16
admitted [8] 13/6 16/1 26/4
26/6 68/15 74/6 120/15
123/10
advance [1] 74/10
advised [2] 106/25 112/11
advocating [1] 147/17
after [7] 69/7 110/4 110/4
119/7 122/8 138/12 140/12
afternoon [1] 70/13
again [17] 5/9 8/2 16/24
26/11 51/11 51/16 57/9 68/9
76/2 120/18 126/19 130/14
133/8 135/15 136/22 137/17
149/5
against [1] 88/11
Agakanyan [1] 30/17
aged [1] 60/13
agent [41] 6/6 6/16 6/20
6/22 7/22 8/3 9/17 10/12
11/11 12/10 13/10 14/3 14/4
15/17 16/6 16/18 21/17 22/13
24/1 24/3 29/3 30/1 32/3
32/7 32/8 35/2 39/21 40/11
46/22 53/19 58/7 59/8 67/21
68/3 68/20 104/15 104/15
105/25 117/8 117/24 134/20
agents [5] 9/25 35/14 35/18
47/11 117/7
aggravated [3] 115/17 147/10
147/16
ago [3] 25/4 62/14 66/1
agree [1] 145/4
agreed [1] 6/1
agreeing [1] 114/5
agreement [3] 103/20 113/23
114/1
Agricultural [1] 97/25
ahead [5] 60/15 64/14 72/13
97/15 142/12
AHN [5] 2/5 4/10 124/17
142/14 142/17
al [1] 1/9
alcohol [1] 85/9
Alhambra [2] 80/19 88/6
alias [1] 50/17
all [69] 5/11 5/16 10/9
12/24 13/10 15/12 15/25
20/13 25/13 25/24 27/3 27/6
28/16 31/13 31/25 34/17
43/16 47/3 52/10 60/2 64/8
66/21 68/2 68/23 69/5 69/21
71/4 72/11 74/6 74/12 74/21
76/17 79/17 79/20 80/18
87/23 88/2 88/10 88/11 91/25
96/5 96/5 102/4 103/7 105/4
111/5 111/21 115/10 115/11
Case 2:20-cr-00579-SVW Document 676 Filed 07/09/21 Page 152 of 170 Page ID
#:10711
A
all... [20] 116/11 116/18
119/10 119/13 125/2 125/4
128/19 131/17 133/24 133/25
135/20 141/8 141/14 142/9
143/6 143/13 144/2 146/24
147/18 148/16
allegation [3] 16/24 128/22
143/24
allegations [3] 44/5 128/20
129/7
alleged [8] 6/6 15/22 16/11
17/25 127/6 132/4 134/12
139/1
alleging [2] 130/16 132/25
allow [4] 50/25 52/10 59/23
67/21
allowed [5] 50/22 51/3 83/1
147/14 147/21
allows [2] 12/5 82/1
Allstate [14] 36/21 36/25
37/6 37/7 37/15 37/23 38/3
39/4 39/14 83/3 103/25 108/5
120/16 124/8
almost [1] 143/17
alone [1] 145/18
along [3] 83/20 95/9 95/14
Alpha [1] 3/12
already [9] 7/25 13/6 16/3
20/14 20/25 26/6 41/14 89/23
116/23
also [17] 5/25 41/3 48/20
51/18 55/2 57/2 85/19 91/9
116/15 125/25 126/7 128/22
129/6 133/7 133/8 137/5
138/25
altogether [1] 148/21
always [5] 81/11 82/3 89/9
89/15 106/9
am [56] 8/19 12/8 13/1 14/6
14/8 23/12 26/18 26/19 26/19
26/21 40/22 41/10 60/10 62/6
68/3 68/8 68/14 69/18 72/6
75/7 78/11 79/3 82/3 82/15
88/14 88/14 89/19 91/19
93/19 94/15 104/21 105/16
107/14 107/14 107/15 108/10
114/11 116/8 122/14 123/4
123/10 123/19 123/20 123/21
123/22 125/24 126/18 131/2
132/2 132/23 134/6 135/9
142/21 147/17 147/19 148/7
Amanecer [1] 3/5
America [17] 1/6 2/3 16/9
18/11 41/3 41/6 41/24 41/25
42/1 42/3 42/9 42/13 42/24
42/25 110/6 110/10 120/17
Americas [1] 2/17
amongst [1] 142/19
amount [3] 86/3 109/2 111/13
analysis [3] 21/7 22/3 52/2
analyze [2] 56/4 132/2
Anastaya [1] 94/22
and/or [1] 102/12
Andrew [1] 52/22
ANGELES [8] 1/14 1/23 2/7
2/15 3/9 3/16 5/1 80/17
Angelina [4] 93/2 93/7 93/7
93/8
angles [1] 131/3
Anna [9] 11/16 11/20 21/19
116/1 130/3 133/3 133/5
133/6 138/7
announcements [1] 108/8
another [16] 52/7 69/11
77/18 82/20 90/23 91/7 95/1
110/6 132/17 138/5 141/15
146/12 146/12 146/16 146/18
146/19
answer [15] 18/2 19/11 20/5
24/12 25/20 37/20 37/21
50/13 51/9 52/13 53/11 53/16
66/20 67/1 73/17
answered [4] 15/3 24/11
34/24 36/18
Anton [5] 130/3 130/16
134/14 134/15 134/16
any [60] 5/19 12/20 15/6
15/12 15/20 17/12 19/7 19/8
20/8 25/6 31/2 31/5 32/12
32/22 33/2 33/24 33/24 36/11
37/3 39/8 42/2 46/7 46/9
46/17 56/5 57/20 58/9 66/22
67/4 71/7 76/21 76/24 78/25
78/25 84/25 85/4 88/18 91/22
92/23 93/11 95/7 95/12
104/17 104/19 105/10 105/11
106/1 108/18 112/13 112/17
114/8 114/10 125/21 126/15
130/21 145/19 146/15 147/2
147/12 147/14
anybody [2] 54/3 114/9
anymore [4] 72/13 105/20
107/2 141/11
anyone [17] 13/25 45/20 54/6
81/2 83/11 83/13 84/12 95/17
95/22 96/1 108/20 113/23
114/1 114/5 116/25 134/16
143/7
anyone's [1] 115/20
anything [12] 42/7 61/15
66/6 92/25 93/3 103/1 105/22
112/23 119/9 125/15 130/21
141/5
anywhere [2] 96/19 98/15
apartment [4] 29/10 40/3
40/10 40/12
apologies [3] 56/23 72/12
121/6
apologize [1] 89/24
apparently [1] 115/3
appear [10] 13/21 25/23
45/24 76/12 95/2 95/15 96/1
98/15 104/23 137/8
APPEARANCES [2] 2/1 3/1
appeared [5] 34/12 45/21
49/15 50/3 55/7
appears [13] 7/10 16/23
30/21 41/22 75/1 76/13 76/15
93/12 126/7 126/9 140/10
140/23 141/2
application [15] 25/16 25/22
40/6 75/16 75/17 75/20 75/24
108/18 108/25 109/7 109/9
110/2 115/2 119/7 142/4
applications [11] 49/15 57/6
74/18 74/21 76/14 87/25
135/19 136/3 137/24 140/2
145/9
apply [2] 108/5 108/23
applying [1] 144/23
appreciated [1] 5/10
approached [1] 109/15
appropriate [2] 58/4 59/23
approved [1] 109/16
approximately [6] 35/16
46/24 47/18 48/22 54/15
60/22
are [130]
area [2] 64/15 121/15
aren't [1] 135/7
arguably [1] 127/5
argue [11] 58/3 68/24 126/10
129/21 129/22 130/8 130/10
130/13 131/1 131/2 147/3
argued [2] 126/8 147/13
argues [1] 142/24
arguing [2] 127/2 145/16
argument [15] 26/23 66/25
69/4 126/21 126/22 130/18
131/17 131/23 132/1 134/6
139/18 142/10 143/23 146/6
149/4
Argumentative [1] 64/4
arguments [2] 64/9 148/18
Arman [5] 113/14 127/19
136/7 137/4 143/6
Armin [1] 18/21
Aro [1] 30/16
around [2] 18/8 107/5
Arshak [10] 18/11 18/14
18/19 19/2 19/4 19/8 128/3
128/8 128/10 128/11
Art [4] 14/11 128/4 128/5
128/6
Art's [1] 123/7
Artash [6] 14/17 14/24 15/7
128/13 133/20 133/21
Artashes [6] 14/14 15/3
15/14 15/22 17/13 128/12
articles [1] 39/12
ARTUR [29] 3/11 4/8 31/19
32/23 32/24 33/3 35/9 35/20
36/2 36/5 36/12 37/10 37/23
38/2 38/6 38/11 38/17 38/20
38/23 48/19 61/13 61/24
69/16 69/17 77/21 77/25
122/22 133/22 145/6
as [77]
ascertain [1] 126/3
Ashwin [1] 2/13
aside [4] 32/24 40/17 71/4
126/15
ask [34] 8/2 14/24 17/10
26/16 26/22 29/7 40/5 40/19
50/12 50/23 53/13 53/17
57/16 57/19 59/19 59/24 64/8
65/3 65/10 65/10 66/8 68/8
69/12 80/3 86/9 90/7 92/22
108/3 113/10 113/20 126/17
126/18 144/5 148/13
asked [22] 8/8 15/20 17/11
24/11 28/13 34/23 36/17
50/21 53/9 56/13 58/20 59/9
60/3 60/6 61/23 102/6 102/9
108/15 108/16 111/2 125/6
126/17
asking [3] 37/19 68/23
140/14
asks [3] 88/22 88/25 106/9
assigned [1] 49/3
assisted [1] 88/18
associated [1] 48/6
Assumes [1] 65/1
Asya [1] 113/16
ATM [2] 27/4 64/15
attachment [1] 32/10
attachments [1] 123/12
attempt [2] 22/7 22/17
attempted [1] 140/23
attempting [2] 52/1 129/19
attention [8] 13/2 14/8 18/7
18/18 19/15 84/21 104/23
121/9
attentive [1] 5/10
ATTORNEY'S [1] 2/4
August [19] 27/18 60/21
62/18 63/5 63/6 63/19 64/12
64/19 84/2 86/10 96/10 103/5
103/9 113/24 114/2 114/6
114/22 114/25 134/22
August 2017 [1] 96/10
August 21 [3] 27/18 62/18
64/12
August 21st [4] 60/21 63/6
63/19 64/19
Case 2:20-cr-00579-SVW Document 676 Filed 07/09/21 Page 153 of 170 Page ID
#:10712
A
August 24th [1] 63/5
AUSA [2] 2/5 2/5
authentication [1] 7/20
authorized [1] 136/7
auto [2] 83/19 136/9
automatically [1] 109/3
available [2] 6/23 7/23
avatar [1] 130/11
Avazyan [1] 133/9
Avenue [5] 2/10 2/17 2/23
40/3 40/10
awards [2] 104/16 104/17
aware [13] 10/2 14/17 15/6
15/12 15/20 17/12 19/7 21/20
26/1 26/18 64/20 65/2 115/18
away [4] 25/13 105/5 106/24
143/16
Ayvazian [49] 26/1 31/20
32/23 32/25 33/3 35/9 35/20
36/5 36/12 37/11 37/23 38/1
38/2 38/7 38/11 38/18 38/20
38/24 48/19 50/17 60/23
61/13 69/16 69/18 77/21
77/25 78/8 90/2 91/10 92/3
94/7 94/15 97/17 101/24
113/10 118/5 122/22 129/17
130/13 131/7 131/11 131/12
132/7 132/7 133/7 133/22
141/23 142/25 145/6
Ayvazian's [2] 61/24 133/13
Ayvazyan [26] 1/9 2/12 3/11
4/8 50/2 50/4 50/15 51/14
55/24 56/25 57/4 57/15 62/20
118/7 130/16 131/5 134/1
134/9 136/8 136/23 138/8
139/6 143/15 143/19 143/24
143/25
Ayvazyan's [2] 133/4 136/20
B
babe [2] 89/1 102/23
back [39] 11/7 12/5 12/24
16/14 23/2 28/7 32/25 35/24
44/23 48/18 48/21 51/16
57/10 70/16 71/2 76/8 77/7
82/6 82/14 84/1 88/19 107/14
109/24 111/4 111/14 111/20
112/1 112/24 113/1 113/3
122/1 123/21 124/21 133/6
134/24 135/13 137/17 140/6
148/12
backing [1] 84/20
bad [2] 82/19 88/21
balances [1] 66/16
bank [47] 12/6 15/9 15/12
15/21 16/9 16/15 16/17 16/20
18/11 26/11 26/12 26/13 41/3
41/6 41/8 41/9 41/18 41/19
41/24 41/24 42/1 42/3 42/9
42/13 42/24 42/25 47/24
49/13 49/22 51/16 51/17
53/21 62/22 64/1 74/13 75/25
76/14 109/15 110/6 110/8
110/10 112/4 113/24 114/19
114/21 120/11 120/17
banks [1] 47/10
Bartunyan [2] 128/10 128/11
based [2] 27/21 141/2
basic [1] 71/8
basically [3] 22/14 30/5
32/5
basis [3] 58/13 59/2 131/22
Bates [5] 10/13 10/17 42/19
42/21 42/21
battery [2] 102/21 102/23
be [76]
Beach [1] 3/21
because [25] 22/2 25/2 51/3
52/7 52/16 63/24 66/19 70/19
76/25 77/6 105/22 106/7
106/25 107/15 108/10 110/7
131/9 131/18 136/5 139/11
143/5 143/21 143/23 146/9
147/21
become [1] 71/6
bedroom [2] 107/24 107/25
bedrooms [1] 118/20
been [53] 10/6 10/8 13/6
16/1 22/20 22/22 23/1 26/4
26/6 32/3 35/16 35/24 39/13
44/11 48/24 56/8 63/10 65/19
72/15 74/6 76/4 78/20 79/9
79/20 81/11 81/19 86/5 86/6
87/2 87/8 88/15 89/9 89/15
90/9 102/17 102/22 103/10
105/15 105/18 105/18 105/23
110/24 115/4 115/11 124/12
129/23 130/10 136/13 144/5
144/16 145/1 145/2 147/8
before [16] 6/1 6/2 9/21
12/9 12/13 25/25 48/19 49/13
60/23 62/19 70/8 85/22 88/17
104/7 115/9 146/15
begin [3] 46/24 58/18 148/18
behalf [3] 2/3 36/25 139/14
behind [7] 49/14 49/15 54/23
71/13 84/19 111/8 111/9
being [15] 5/10 10/18 17/25
28/20 38/21 51/18 66/2 71/10
83/7 89/24 97/5 115/17
135/25 145/19 146/18
believe [44] 5/12 9/4 13/16
20/22 21/6 21/11 23/3 24/18
25/2 31/11 33/8 36/23 37/6
38/5 40/8 40/13 40/17 41/11
42/19 47/20 64/13 75/20
80/20 82/15 87/10 98/6 98/19
99/10 100/11 101/1 104/10
110/5 110/23 118/14 133/15
133/21 136/12 136/16 137/10
139/5 141/18 142/16 142/17
147/1
believed [1] 54/23
belong [1] 95/12
belonged [1] 49/4
belongs [1] 103/11
below [1] 122/20
beneficiary [1] 123/24
benefit [4] 30/24 133/14
134/1 142/25
benefited [1] 138/10
benefits [1] 30/20
best [7] 10/21 12/11 15/5
45/2 61/2 80/12 132/5
between [22] 6/7 13/12 15/6
17/12 19/7 36/12 44/19 57/15
57/20 57/25 67/5 101/25
103/5 103/8 113/23 114/2
114/6 114/22 114/25 132/11
133/9 135/18
beyond [7] 57/13 58/24 59/4
65/4 65/12 68/17 131/4
Bienert [2] 3/4 3/7
big [3] 108/7 142/13 143/17
birth [1] 44/14
bit [3] 66/1 80/5 147/8
blew [1] 109/24
blow [10] 7/12 14/9 18/8
19/17 26/10 27/3 27/6 63/1
63/3 64/14
board [5] 7/9 8/22 8/25 9/8
9/19
BOFA [2] 18/11 18/14
bored [1] 105/16
borrowed [1] 81/17
both [3] 28/23 129/19 143/24
bottom [9] 10/13 41/17 42/16
42/17 75/17 92/13 93/2 93/4
120/21
Boulevard [3] 3/15 7/14
104/14
box [1] 63/1
boxes [1] 137/20
brain [1] 60/13
branches [1] 110/9
brief [2] 67/11 67/15
briefcase [2] 87/22 96/5
briefly [6] 62/8 62/10 74/1
79/14 79/14 79/19
Bro [1] 18/10
broke [1] 119/8
broker [3] 85/18 87/25 134/8
brother [7] 81/6 81/18 89/5
111/14 112/24 118/8 122/1
brothers [2] 81/3 81/5
brought [1] 80/16
bunch [7] 103/10 104/13
104/15 104/16 105/23 105/24
138/6
bury [1] 112/15
business [47] 6/24 7/2 7/11
9/5 33/19 36/11 80/8 80/22
81/2 81/4 81/9 81/13 81/18
87/2 87/6 87/8 87/11 88/10
88/15 89/6 89/8 89/18 90/17
90/17 101/25 102/2 102/4
104/9 104/10 106/2 106/5
107/18 108/8 108/23 111/8
111/17 113/1 113/2 114/17
118/25 119/13 119/16 119/17
121/24 123/2 123/3 123/16
businessman [1] 120/8
bust [2] 126/24 147/10
buying [1] 111/20
C
CA [9] 1/23 2/7 2/15 2/21
3/6 3/9 3/13 3/16 3/21
Caicos [2] 26/3 60/24
CALIFORNIA [13] 1/2 1/14 5/1
7/9 7/15 9/1 27/15 31/21
39/3 39/13 63/8 78/13 78/15
call [10] 5/13 14/11 16/5
65/16 69/15 69/17 77/13
77/21 127/12 127/25
Calle [4] 3/5 55/7 57/10
138/23
called [12] 18/11 18/14
28/19 40/20 51/18 62/17
63/17 107/3 107/5 115/13
124/20 126/4
calling [1] 116/15
Calls [2] 9/9 51/24
came [14] 32/25 34/3 44/23
48/18 48/21 79/16 79/20
82/17 83/22 86/14 102/19
111/7 111/12 147/16
camera [1] 42/2
can [80]
can't [23] 9/20 10/4 37/20
38/14 39/15 41/2 42/6 47/12
48/24 52/6 53/7 58/12 59/19
60/13 65/19 71/10 83/19
91/16 91/23 129/1 137/2
139/12 148/14
cannot [1] 71/21
Canoga [4] 29/10 29/15 30/24
31/3
capturing [1] 146/14
car [3] 79/24 102/18 102/23
card [13] 16/8 26/11 27/4
27/9 28/19 63/8 68/10 68/12
68/21 126/24 133/6 133/7
147/10
cards [2] 68/21 106/6
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care [4] 108/11 108/14
119/10 125/2
careful [1] 145/21
cargo [2] 83/1 85/19
carrier [2] 38/12 81/25
carry [2] 87/23 88/1
case [49] 14/15 14/22 15/4
15/9 15/14 15/22 16/11 16/24
17/25 19/5 19/9 20/2 23/8
23/13 24/1 24/2 24/3 29/4
47/19 54/13 59/21 62/1 62/2
62/4 62/4 62/5 74/3 74/19
74/25 76/5 78/17 105/14
114/14 115/15 125/15 126/13
127/1 127/22 128/15 129/21
130/20 131/9 137/6 139/1
139/8 141/7 144/14 144/18
145/20
cases [1] 141/16
cash [2] 112/20 112/21
cashier's [1] 122/7
CATHERINE [1] 2/5
caused [1] 139/20
cell [3] 146/3 146/15 147/21
Cellebrite [10] 13/19 21/1
22/25 23/2 23/8 24/9 25/3
147/19 147/19 148/9
CENTRAL [1] 1/2
certain [16] 8/11 9/3 24/16
48/17 72/25 74/5 74/16 74/16
74/17 74/19 83/1 84/20 84/22
86/2 88/25 109/2
certainly [5] 32/22 33/11
36/10 135/2 144/23
certificate [6] 5/15 5/21
33/2 33/19 38/3 150/1
certify [1] 150/4
cetera [3] 136/4 136/24
136/24
changes [1] 83/4
charge [3] 31/23 84/6 143/25
charged [7] 105/4 115/17
116/2 127/10 128/17 132/11
146/21
charges [1] 113/20
chart [40] 70/8 70/14 71/5
71/7 71/8 71/11 71/15 71/21
72/1 72/17 72/19 72/22 73/2
73/6 73/8 73/9 73/11 73/14
73/15 74/2 74/4 74/11 75/23
76/4 76/10 76/15 76/21 76/22
77/14 125/22 125/24 126/4
126/8 126/11 137/15 137/15
137/21 138/11 138/13 142/14
charts [3] 77/4 135/20 137/9
Chase [2] 26/11 63/13
check [9] 35/12 36/15 36/24
39/3 42/2 76/24 91/8 108/17
122/7
checkbooks [1] 96/2
checked [1] 85/11
checks [13] 14/12 94/19 95/2
95/4 95/6 95/7 95/10 95/12
95/15 95/17 95/22 96/4 96/5
children [6] 79/12 79/13
102/3 118/25 124/18 125/2
Choice [1] 10/23
Christopher [1] 2/9
circle [5] 117/17 117/18
117/19 117/21 117/23
Circuit [2] 141/7 144/9
Circumstantial [1] 146/18
City [1] 82/16
claim [1] 30/20
clarify [2] 97/13 122/24
Clark [1] 40/11
clear [3] 39/22 97/14 132/23
clearly [1] 76/2
Clemente [1] 3/6
clerk [2] 28/9 28/11
client [3] 128/17 129/4
129/13
clock [2] 69/18 116/8
close [3] 86/3 112/9 121/9
closer [1] 140/6
clumsy [1] 89/24
co [4] 91/8 113/5 115/25
139/6
co-conspirators [1] 139/6
co-counsel [3] 91/8 113/5
115/25
Coast [1] 3/20
code [5] 27/13 28/13 28/23
63/7 150/5
codes [1] 103/1
coherent [1] 130/7
Collision [1] 136/9
color [2] 44/17 44/17
column [4] 72/1 75/2 75/5
138/12
come [13] 11/7 12/24 67/25
74/24 75/18 83/17 102/18
104/22 107/8 107/14 124/21
143/3 144/15
comes [5] 13/1 13/2 49/17
88/20 143/11
coming [7] 29/23 51/21 52/24
70/16 106/15 121/18 132/16
commercial [4] 38/7 82/8
84/23 85/9
commit [1] 114/6
common [3] 12/8 136/1 136/2
commonalities [1] 136/1
commonly [1] 117/7
communication [1] 6/7
communicative [1] 83/21
companies [6] 9/3 53/24 54/6
86/2 143/10 143/11
companies' [1] 9/7
company [37] 9/23 10/1 10/23
12/10 12/11 34/15 37/8 37/8
38/18 40/20 49/23 49/24
51/18 80/14 80/16 81/16 82/5
82/21 83/3 83/4 83/13 83/18
83/24 84/4 84/6 84/8 85/13
85/14 86/5 86/10 108/7
108/10 109/11 111/11 142/6
145/6 145/7
comparison [1] 135/18
compiled [2] 13/15 13/17
complete [3] 52/13 53/15
53/16
completed [1] 87/24
completely [2] 57/13 135/25
completes [1] 125/8
completing [1] 53/10
concerned [1] 119/25
concluded [2] 70/21 149/10
conclusion [1] 131/24
conduct [9] 21/7 31/20 31/22
53/25 54/12 54/18 54/20
54/25 55/2
conducted [5] 28/15 52/2
54/21 55/1 55/5
confer [2] 113/9 115/24
Conference [1] 150/9
confirm [1] 40/6
confirmed [2] 40/9 40/14
conformance [1] 150/8
confrontation [3] 53/4 57/13
107/10
confronted [2] 105/18 110/14
confused [2] 52/16 52/23
confusing [2] 72/24 139/10
connected [1] 17/23
Connecticut [1] 2/23
connecting [1] 136/22
connection [7] 15/6 47/22
47/25 50/16 53/25 54/13
134/3
consecutive [1] 65/4
consider [4] 58/14 107/24
139/12 139/13
consisted [1] 127/25
consistent [5] 9/6 28/23
38/17 38/20 142/2
consists [3] 127/15 127/18
127/24
conspiracies [10] 126/23
127/4 127/11 127/11 128/15
131/10 131/23 132/4 142/20
143/25
conspiracy [14] 114/9 126/22
127/6 127/13 127/14 127/15
132/4 132/12 141/8 141/9
141/12 141/16 141/20 146/4
conspirator [9] 128/18
128/21 128/23 139/1 139/1
139/4 141/13 141/18 141/19
conspirators [3] 129/13
139/6 141/14
conspire [2] 128/18 141/14
conspired [4] 128/18 139/5
141/15 141/17
construction [4] 132/16
132/18 138/5 143/10
Construction's [1] 9/4
Cont'd [1] 3/1
contact [2] 6/7 136/18
contacting [1] 65/4
contain [4] 23/9 24/10 71/9
73/14
containing [1] 21/2
contains [2] 20/23 74/24
contents [1] 76/24
contested [1] 126/1
continue [1] 50/12
contracting [1] 143/11
contractors [5] 7/8 8/21 9/1
9/7 9/18
controlled [2] 130/21 138/8
convenient [1] 110/9
conversation [1] 52/19
conversations [1] 53/7
convert [2] 112/8 112/20
cooperated [1] 140/2
copies [3] 32/9 87/19 95/15
copy [4] 30/6 73/10 73/13
108/16
corner [6] 42/17 91/13 92/6
93/13 94/22 117/10
corporation [4] 83/10 110/8
112/6 112/9
correct [115]
correctly [2] 69/18 116/8
costs [1] 86/25
could [19] 9/20 14/8 15/19
25/9 28/14 28/16 42/15 56/9
79/14 79/19 80/11 81/15
81/24 85/1 109/24 110/1
111/20 112/20 145/7
couldn't [3] 8/11 28/16
34/11
counsel [9] 2/1 5/9 70/12
91/8 113/5 113/9 115/24
115/25 118/18
country [7] 60/24 61/1 62/20
79/16 135/1 144/23 145/2
county [1] 26/2
couple [8] 16/14 71/16 82/18
84/13 87/24 110/5 113/11
119/23
course [9] 15/20 47/2 74/8
84/23 85/6 85/15 102/15
136/23 139/23
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court [5] 1/1 1/21 6/2 56/21
70/21
courtroom [5] 67/22 67/24
70/9 70/17 118/15
cousin [1] 139/19
cover [2] 85/13 145/6
CR [1] 1/8
create [1] 145/15
created [2] 44/11 44/15
credit [7] 10/23 28/19 85/25
126/24 133/6 133/7 147/10
crew [8] 129/18 143/2 143/6
143/7 143/13 143/19 143/20
144/1
crime [1] 114/6
criminal [3] 56/14 56/17
114/8
cross [7] 4/6 4/10 46/20
51/2 116/11 118/1 118/3
cross-examination [7] 4/6
4/10 46/20 51/2 116/11 118/1
118/3
CRR [1] 150/12
Cruz [2] 59/16 67/21
crying [2] 107/3 107/6
CSR [2] 1/21 150/12
currently [2] 83/24 90/16
customers [2] 102/11 102/11
cut [1] 106/19
D
DADYAN [47] 3/18 15/7 17/23
19/5 19/8 20/8 32/16 32/18
35/2 35/21 36/5 36/12 39/21
40/7 40/9 43/5 45/22 79/8
79/10 93/1 93/5 95/6 118/10
118/13 124/20 125/17 127/25
127/25 128/23 129/5 129/14
129/16 129/18 131/1 131/12
132/7 133/23 136/24 138/25
138/25 139/5 139/19 139/20
140/5 140/14 143/7 145/7
Dadyan's [6] 40/2 40/11
43/14 44/5 45/17 143/20
damage [1] 85/20
data [5] 22/14 23/9 24/10
56/4 56/5
database [1] 46/9
date [6] 22/15 44/14 60/20
63/23 65/19 150/10
dates [6] 39/15 71/9 71/10
71/21 76/20 76/21
daughter [1] 93/8
daughter's [1] 93/10
Davidson [2] 122/11 122/24
day [9] 1/15 35/15 70/25
79/23 82/1 82/2 83/23 107/3
148/22
days [4] 82/14 83/22 83/23
122/8
DBA [2] 82/8 82/9
DC [2] 2/10 2/23
dead [2] 102/21 102/23
deal [4] 67/14 77/14 107/10
116/14
dealers [2] 54/8 54/10
deals [1] 106/16
dealt [1] 12/12
debit [1] 27/4
debt [2] 113/1 113/1
debunk [1] 130/9
debunked [1] 130/10
December [2] 16/22 17/4
December 23rd [1] 17/4
December 7 [1] 16/22
deed [1] 33/2
deeply [1] 101/25
defendant [8] 1/9 2/12 3/3
3/11 3/18 62/19 137/6 141/17
defendant's [1] 144/8
defendants [13] 31/11 47/4
48/12 55/21 56/18 57/21
59/14 61/5 66/22 67/4 72/20
127/21 132/11
defendants' [2] 55/19 55/23
defense [21] 5/14 5/17 6/19
7/5 7/17 11/2 11/10 12/18
25/8 28/4 29/2 69/15 72/21
74/5 74/7 74/12 76/6 77/21
126/17 132/19 132/24
definition [1] 146/8
definitively [1] 135/6
defraud [3] 113/24 114/2
114/9
deliver [2] 40/12 102/10
demonstrative [1] 126/10
DEPARTMENT [5] 2/4 2/9 38/12
43/1 82/24
depending [1] 85/18
depends [1] 130/22
depicted [8] 7/24 20/16
21/14 44/25 45/4 45/23 46/2
116/25
deposit [7] 51/13 89/2
109/14 110/6 110/12 122/9
124/13
deposited [2] 49/21 137/22
derived [1] 147/23
describe [2] 30/1 47/6
described [2] 129/5 142/23
description [2] 75/1 75/4
Design [2] 136/13 136/17
despite [2] 124/23 135/24
destroyed [1] 80/21
detail [4] 53/6 53/8 73/4
127/7
detailing [2] 30/5 30/10
details [1] 142/5
determination [3] 49/8 51/4
59/22
determine [27] 10/1 21/8
21/24 25/15 27/17 28/14
28/16 32/20 35/1 35/5 36/4
38/2 38/6 38/11 38/23 41/24
42/3 42/9 44/22 45/3 45/6
46/6 46/10 49/5 51/20 56/5
61/15
determined [6] 32/5 35/3
37/5 49/25 57/25 65/17
devastated [1] 86/16
device [1] 49/3
Diana [4] 16/8 16/10 16/23
128/3
Diane [1] 17/12
did [200]
didn't [40] 14/23 15/10 22/1
22/2 22/4 24/24 25/3 26/16
28/21 32/22 33/22 34/14
34/17 35/12 36/15 42/1 45/13
46/6 46/9 59/24 66/6 67/3
69/2 70/20 80/25 83/20 83/20
103/19 106/13 107/1 109/25
111/24 113/3 115/10 119/18
120/3 131/14 133/10 133/11
140/25
diesel [1] 86/25
differences [1] 131/15
different [8] 73/24 105/22
131/10 131/10 135/25 136/17
145/15 146/10
difficulty [1] 124/23
diffuse [1] 107/11
digital [1] 42/15
direct [20] 4/4 4/5 4/5 4/9
4/9 6/14 10/12 13/2 14/8
18/7 18/18 19/14 26/20 31/15
39/19 59/4 78/6 116/20 132/5
145/22
directing [1] 50/4
disconnected [1] 127/4
discovery [4] 10/20 58/10
74/3 74/8
discuss [2] 58/25 148/17
discussed [2] 15/14 69/7
discussion [3] 58/10 143/5
147/8
display [1] 67/22
displayed [1] 13/8
dispute [1] 142/14
disregard [1] 6/9
distinction [1] 44/19
DISTRICT [3] 1/1 1/2 1/4
DIVISION [1] 1/2
divorce [4] 106/10 106/21
106/21 119/23
DMV [6] 37/25 38/15 44/22
44/23 61/16 85/10
do [230]
document [83]
documentation [3] 39/5 39/7
39/9
documents [37] 8/4 24/19
30/24 33/25 34/2 34/3 34/6
34/10 34/12 34/13 34/14
34/16 34/21 36/21 36/25 46/2
47/13 47/14 72/1 72/2 72/4
72/8 72/15 72/15 72/18 72/19
74/19 76/1 94/16 94/17 95/20
102/10 105/24 115/3 115/11
126/2 147/23
does [32] 8/1 9/6 17/17
17/18 30/19 41/13 41/15 65/2
71/12 71/14 72/1 72/3 72/22
73/14 74/9 83/24 85/13 85/13
87/11 88/7 88/8 98/15 102/14
103/25 105/24 118/23 123/7
137/8 139/7 139/13 144/21
144/21
doesn't [17] 8/9 8/10 8/16
23/23 23/23 25/23 46/13
74/21 77/6 88/13 120/4 129/1
143/7 144/22 145/16 146/15
146/18
doing [8] 26/21 83/21 88/14
88/14 107/15 107/15 112/23
113/4
DOJ [1] 42/17
don't [70] 8/2 8/8 8/19 14/6
15/25 16/4 21/11 23/24 24/24
25/5 28/3 29/23 32/18 35/7
35/19 35/25 36/2 37/17 37/20
38/5 41/2 41/12 42/11 43/25
44/8 45/14 46/17 58/12 58/17
59/1 62/23 64/5 65/2 65/9
70/12 72/13 79/3 86/1 87/17
91/4 92/25 93/3 93/11 95/18
97/12 102/25 103/10 103/11
105/3 105/19 105/20 105/22
105/25 106/23 107/10 121/4
131/24 132/20 135/1 135/3
135/5 138/16 141/8 141/11
143/16 144/15 145/19 146/17
147/1 148/24
done [9] 61/6 64/7 73/25
80/1 82/3 82/14 109/3 114/11
144/7
door [5] 33/18 104/4 104/7
104/8 104/9
Dorothy [1] 88/6
doubles [2] 85/2 85/2
doubt [1] 131/5
down [15] 41/17 42/16 42/17
60/10 60/14 63/2 70/9 70/18
86/3 97/24 102/18 112/9
117/12 142/14 144/12
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dozen [1] 71/17
dozens [3] 48/24 54/17 54/17
drive [3] 82/2 83/19 88/13
driven [1] 83/13
driver [7] 38/21 38/24 81/20
81/22 84/17 106/2 106/5
driver's [11] 24/22 38/7
43/12 43/14 44/15 44/21 46/4
104/24 106/4 108/16 133/5
drivers [4] 83/17 83/22
84/13 84/14
drop [1] 102/11
dropped [1] 79/18
drug [2] 38/24 85/8
due [2] 83/18 109/1
during [7] 30/5 39/23 40/25
41/23 45/17 74/7 136/21
DX1000 [1] 75/11
DX1100 [2] 75/9 75/12
DX1100-001 [1] 75/12
DX1100-1 [1] 75/9
Dzukaeva [2] 116/1 130/3
E
e-mail [4] 25/19 50/3 50/6
50/8
e-mailed [2] 70/16 70/20
e-mails [6] 18/21 70/10
92/21 92/24 93/9 93/11
e-signed [1] 122/20
each [3] 12/6 95/4 97/11
earlier [16] 17/11 58/20
60/3 61/23 111/16 118/7
118/19 118/24 119/12 119/18
121/2 121/6 121/23 123/15
124/17 128/1
East [2] 40/2 40/10
EDD [6] 30/16 30/19 30/23
31/2 31/6 147/11
education [1] 79/15
Edvard [1] 113/18
Edward [3] 127/18 136/10
136/24
efforts [2] 54/1 56/4
EIDL [7] 46/25 57/6 108/6
133/24 135/19 137/11 137/24
eight [1] 47/3
either [3] 43/16 136/16
149/7
elicit [1] 52/2
else [7] 40/15 83/13 84/12
108/17 125/16 126/13 141/5
emergency [1] 109/18
employee [1] 84/18
employees [6] 83/24 84/8
84/22 135/24 142/6 145/8
Encino [4] 7/14 31/21 78/13
78/15
end [4] 68/1 70/25 105/21
129/20
ended [1] 143/14
ending [7] 20/20 26/13 27/8
63/8 63/15 120/17 124/3
endorsement [1] 85/1
ends [1] 123/25
engaged [4] 14/17 20/8
114/21 114/24
enough [4] 80/24 80/25
106/17 106/20
enter [3] 104/4 106/7 114/1
entered [3] 27/22 27/23
27/24
entire [2] 67/24 131/7
entities [7] 6/24 7/2 17/24
47/10 66/17 67/6 143/12
entitled [1] 150/7
entity [2] 12/12 143/2
Erase [1] 105/19
erased [1] 105/5
erasing [1] 105/21
Escalante [1] 141/7
escrow [7] 49/23 49/24 51/12
54/6 89/2 102/10 133/14
essentially [4] 30/10 130/15
131/2 131/6
establish [2] 80/13 81/18
established [2] 80/15 81/1
estate [16] 34/9 34/12 34/22
35/2 35/6 35/10 87/2 87/4
87/7 88/15 102/4 105/25
117/8 117/24 134/8 134/20
estate-related [2] 34/9
34/22
estranged [1] 118/22
et [4] 1/9 136/4 136/24
136/24
even [10] 30/7 88/17 105/3
106/25 109/25 115/10 126/4
135/24 141/8 143/20
events [1] 77/1
eventually [1] 130/6
ever [36] 14/24 25/15 35/5
35/9 36/4 36/24 37/22 78/23
78/25 81/19 82/12 83/11
83/13 83/18 87/2 87/4 87/18
88/18 89/8 103/25 107/17
108/18 108/20 108/22 112/13
112/17 112/20 113/23 114/1
114/5 114/16 114/21 114/24
115/13 115/20 116/4
Evergreen [1] 18/21
every [6] 52/6 85/10 88/20
107/1 107/3 143/2
everybody [1] 26/6
everyone [2] 13/9 104/23
everything [5] 107/11 108/8
112/8 119/10 135/23
EVID [1] 4/12
evidence [78]
evidencing [2] 15/13 15/21
exact [2] 135/20 135/24
exactly [1] 70/15
exam [1] 85/11
examination [22] 4/4 4/5 4/5
4/6 4/6 4/7 4/9 4/9 4/10
6/14 31/15 33/25 39/19 46/20
51/2 62/12 67/19 78/6 116/11
116/20 118/1 118/3
examine [2] 34/6 66/11
example [7] 21/10 75/6 75/7
76/13 132/13 145/5 147/15
Excel [1] 13/19
except [1] 148/2
exchange [2] 134/17 145/1
exclude [1] 58/9
excuse [7] 85/13 92/21 103/4
104/3 109/14 123/21 135/14
excused [1] 125/9
executive [1] 28/12
exhibit [113]
exhibits [18] 5/15 5/17 5/23
24/6 71/9 73/20 74/5 74/13
75/14 76/6 76/7 76/12 76/15
126/5 132/14 135/16 148/5
148/12
exist [2] 36/11 144/21
existed [5] 10/1 22/23 32/21
42/3 44/22
existence [1] 84/4
existing [1] 9/23
expect [2] 9/18 126/3
expecting [2] 109/22 109/25
expenses [4] 111/10 120/8
120/11 121/24
expired [1] 10/3
explain [10] 44/9 77/17
84/10 86/12 86/24 102/16
112/25 125/5 125/6 127/7
explains [1] 142/18
explicitly [1] 130/20
explore [1] 101/24
export [1] 13/18
expression [1] 141/11
extent [3] 10/24 40/18 52/18
eye [3] 44/17 106/14 106/14
eyes [1] 86/3
F
face [3] 44/16 107/2 131/6
facial [3] 45/9 46/10 46/12
fact [7] 17/19 18/25 37/4
44/24 73/2 109/1 124/20
facts [1] 65/1
factual [2] 131/22 142/14
fails [1] 71/7
fair [2] 42/12 67/13
fairly [2] 24/16 130/19
fake [9] 43/16 43/18 44/18
44/19 44/20 44/21 46/2
104/24 105/10
false [6] 112/17 114/17
114/19 115/22 142/5 145/5
falsehood [2] 144/25 145/3
falsehoods [1] 144/17
familiar [6] 13/14 40/20
41/4 41/13 43/6 43/8
family [1] 104/20
far [3] 68/10 135/10 148/14
farm [1] 143/16
Farms [1] 115/13
Farrer [1] 52/22
fashioned [1] 89/20
fast [1] 79/25
father's [2] 117/20 117/21
faxes [1] 87/19
FBI [15] 21/7 22/4 22/5 22/7
22/17 24/3 29/3 41/23 43/1
44/2 45/6 46/6 46/9 56/4
61/21
fear [1] 107/16
fed [1] 106/14
federal [3] 37/2 37/5 81/25
FedEx [1] 102/12
feel [1] 88/21
fees [1] 110/8
feet [1] 109/24
Fenton [9] 2/9 4/6 4/7 58/7
58/20 60/3 60/17 61/12 70/4
few [4] 19/16 61/8 129/1
144/10
Fiber [6] 133/3 133/8 133/9
136/3 136/12 136/16
figure [2] 49/3 49/14
file [2] 103/14 119/19
filed [12] 36/5 36/15 36/24
39/5 39/13 82/8 82/9 106/10
106/20 119/22 119/22 146/5
files [3] 47/21 74/13 87/24
filing [3] 37/5 103/19
119/25
fill [4] 30/4 115/5 119/7
119/9
filled [3] 109/7 115/7 115/8
final [3] 69/4 138/12 142/9
finance [2] 85/24 86/4
financed [1] 85/22
finances [2] 120/3 120/4
financial [4] 12/5 47/10
47/14 47/16
financially [4] 81/2 81/9
89/6 89/11
financing [1] 86/2
find [10] 32/22 39/12 48/16
56/7 57/8 76/9 76/16 76/22
86/1 147/7
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finding [1] 86/19
fine [3] 148/4 148/11 149/2
finish [1] 51/9
finished [1] 25/11
first [35] 10/12 13/4 13/4
14/21 15/2 16/4 16/4 18/9
26/7 26/7 26/10 47/4 47/13
50/16 70/23 70/24 71/1 71/2
73/20 74/12 85/8 90/7 103/21
103/21 104/7 105/13 110/23
111/7 112/4 123/19 128/6
131/4 137/20 137/21 137/23
five [2] 53/11 74/24
Floor [1] 2/6
flow [7] 36/13 36/13 52/2
66/2 66/12 66/13 137/15
flowed [1] 132/11
flowing [1] 132/17
flows [1] 57/23
flyers [1] 79/22
focus [3] 58/19 129/17 131/7
focused [1] 30/25
follow [5] 49/9 49/10 52/5
54/1 65/16
follow-up [1] 65/16
followed [1] 53/21
following [9] 5/6 5/14 36/13
53/14 53/20 69/23 77/11
125/12 134/6
food [2] 79/25 111/17
footage [1] 42/6
foregoing [1] 150/5
foreign [1] 134/17
forensic [2] 21/7 22/3
forgiven [1] 110/24
forgiving [1] 110/22
form [2] 19/22 135/21
format [5] 13/19 53/18 65/3
65/10 150/8
former [1] 123/15
forth [1] 12/6
found [10] 33/25 34/7 36/20
38/17 48/17 53/10 56/8 62/18
104/25 136/21
foundation [8] 9/11 14/20
20/3 21/22 37/18 56/11 66/7
147/22
foundational [1] 65/11
foundations [1] 66/2
four [5] 73/14 73/15 73/16
73/21 97/24
Francisco [1] 2/21
Fraser [1] 3/7
fraud [10] 14/18 31/1 31/2
31/6 46/25 114/21 114/24
126/25 142/3 147/11
fraudulent [3] 49/21 54/22
54/23
fraudulently [1] 57/5
freight [2] 85/18 87/25
frequently [2] 64/7 74/25
friend [2] 80/18 123/17
friends [1] 80/13
front [14] 10/2 97/18 99/17
103/22 115/11 120/19 121/13
122/3 122/16 123/5 123/13
123/18 124/6 133/6
full [2] 73/15 77/23
fund [1] 109/20
funded [1] 136/6
Funding [2] 33/20 133/23
funds [25] 12/5 36/13 51/17
57/23 66/2 66/12 66/13 66/23
66/24 67/5 67/6 112/3 112/15
112/18 112/20 133/2 133/11
133/24 137/15 137/21 138/1
138/10 140/19 140/21 140/24
funnel [1] 137/12
furniture [1] 54/8
further [16] 31/10 39/17
46/17 62/7 65/3 65/7 65/9
65/11 65/24 65/25 66/21
67/10 69/5 116/6 117/25
125/3
furthermore [1] 141/24
G
games [1] 103/3
garage [1] 104/7
Garfield [2] 40/3 40/10
gather [1] 84/14
gave [3] 19/22 70/14 125/25
gears [1] 84/20
general [1] 11/13
generally [7] 7/5 16/6 17/10
44/12 49/2 57/16 57/19
Gentleman [5] 51/18 51/19
52/15 52/22 54/4
geolocation [1] 22/16
get [23] 6/10 19/16 25/3
61/10 61/10 67/12 69/11 70/4
71/24 80/24 80/25 83/20 85/1
85/11 103/19 109/11 109/24
120/4 126/20 130/6 131/17
148/16 148/23
gets [2] 88/21 136/6
getting [6] 43/24 49/7 53/6
61/4 140/2 143/19
GEV57I [1] 98/6
GEX57D [1] 92/2
girlfriend [2] 40/13 40/18
give [6] 73/4 73/8 126/2
127/12 133/16 143/16
given [2] 130/21 146/23
giving [3] 32/3 50/20 132/2
Glendale [1] 3/13
go [39] 9/25 16/4 17/2 17/3
18/17 19/19 23/2 25/25 28/7
29/25 33/22 41/23 42/1 53/20
60/15 60/24 72/13 76/8 83/17
83/23 84/1 85/4 85/11 87/19
89/2 97/15 102/11 104/4
105/16 105/17 123/21 132/13
133/24 133/25 137/17 138/12
142/12 144/6 148/2
goes [3] 88/20 138/4 138/11
Gohar [2] 55/8 55/13
going [52] 13/1 14/9 26/19
32/5 44/4 49/25 51/12 57/10
68/8 68/14 69/17 72/7 76/8
84/18 86/18 89/19 91/19
94/15 106/15 106/19 107/14
109/11 109/20 110/14 110/25
111/3 120/14 121/12 122/14
123/4 123/10 123/20 123/21
123/22 124/5 126/11 126/18
129/21 129/22 130/8 130/9
130/9 130/13 130/18 131/1
131/2 133/1 133/2 135/15
137/24 148/12 149/5
gone [5] 83/4 97/9 107/10
134/24 144/15
good [14] 6/16 6/17 16/5
31/17 31/18 39/21 46/22
46/23 78/8 78/9 80/16 84/18
119/3 123/17
got [17] 71/2 81/12 81/17
82/9 82/10 82/10 85/8 103/21
105/4 106/14 107/4 110/11
111/7 111/24 111/25 140/6
147/18
gotten [2] 104/13 110/24
government [69] 8/5 10/19
11/12 12/25 13/11 13/14 16/1
18/5 19/14 20/15 20/17 23/7
23/14 26/5 26/9 27/1 42/23
42/24 42/25 47/10 50/25 51/6
58/8 68/5 68/15 68/16 72/16
74/5 74/7 74/12 76/1 76/6
76/18 90/5 97/4 107/20 114/3
120/14 121/7 121/12 121/21
122/14 123/5 123/11 123/22
123/23 124/2 124/5 125/25
126/2 126/6 127/6 127/10
130/15 131/4 131/6 131/9
131/18 132/13 133/13 135/15
138/2 142/11 142/24 143/13
145/21 146/24 148/9 148/10
government's [12] 13/7 67/16
126/20 128/20 130/10 133/12
139/3 139/18 139/18 144/7
148/5 148/25
grade [2] 79/17 79/17
grandmother [1] 117/3
great [2] 86/13 89/10
greatest [1] 85/25
Greg [2] 19/22 128/4
Gregor [1] 128/3
Grigor [5] 20/1 20/7 25/1
25/5 25/16
Grigoryan [23] 6/7 56/14
57/2 57/5 57/15 127/16
128/21 129/6 129/14 129/18
129/25 130/12 130/17 132/7
132/21 132/23 132/25 133/20
133/21 133/22 134/9 137/1
142/22
Grigoryan's [2] 143/19
147/15
gross [1] 86/23
ground [1] 50/19
grounds [1] 59/3
group [24] 3/15 55/2 127/16
127/17 127/18 127/24 127/25
128/22 128/23 129/5 129/6
129/9 129/10 129/12 129/16
129/18 131/11 131/12 132/19
133/1 136/2 136/9 137/2
142/22
groups [3] 129/17 129/19
142/19
growing [1] 86/6
guard [1] 106/9
guess [10] 14/6 41/8 43/24
44/19 109/16 111/12 126/19
141/10 141/18 148/16
Gusto [2] 19/22 135/21
guy [2] 18/20 89/10
guys [1] 107/7
GX6H [1] 75/21
H
had [52] 22/19 35/5 35/5
35/9 38/3 38/7 38/11 38/24
39/5 39/13 42/8 52/16 52/23
55/2 56/8 60/17 61/17 61/23
66/22 67/13 79/24 80/12 82/8
82/16 82/19 83/17 83/23
84/13 84/14 87/4 102/21
103/7 103/8 106/17 106/18
106/20 106/25 110/7 110/9
110/15 111/12 111/21 115/3
119/6 129/22 133/7 134/18
134/24 138/19 140/23 143/5
145/2
hair [1] 44/17
half [14] 60/22 62/19 129/24
144/11 144/15 144/17 144/18
144/24 145/3 145/4 145/10
145/11 145/16 149/6
hand [10] 10/13 73/6 91/13
92/6 92/13 93/13 94/21 117/9
117/10 136/2
handed [1] 73/11
handicap [1] 126/6
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hands [1] 136/2
handwriting [53] 90/8 90/10
90/11 90/14 90/18 90/20
90/21 91/1 91/3 91/5 91/12
91/15 92/5 92/8 92/12 92/16
92/18 93/12 93/15 93/23 94/1
94/9 94/11 94/12 96/12 96/15
96/17 96/19 96/25 97/20 98/9
98/11 98/15 98/21 98/23 99/5
99/7 99/12 99/19 99/21 99/23
100/4 100/13 100/15 100/18
100/20 101/1 101/4 101/6
101/11 101/13 101/18 101/20
hanging [1] 104/9
happened [7] 62/18 77/1
80/21 106/22 110/13 111/6
134/21
happens [1] 140/19
Harapetyan [6] 127/19 127/19
132/25 137/4 138/4 143/7
hard [1] 86/18
hardly [1] 105/16
Harley [2] 122/11 122/24
Harley-Davidson [2] 122/11
122/24
Hart [4] 9/4 132/16 132/17
138/5
Hartunian [2] 19/4 19/8
has [58] 6/2 10/6 13/6 15/25
23/7 26/4 26/6 33/22 35/23
44/11 53/11 67/25 73/22 76/1
81/11 83/4 83/11 83/13 86/5
86/6 87/8 87/12 88/15 88/19
89/9 89/13 89/14 89/15 89/18
90/16 97/9 97/11 97/15 102/6
102/9 102/17 102/22 102/25
103/10 104/13 104/13 104/20
104/22 105/15 105/18 105/18
105/23 110/24 115/11 127/10
130/10 131/9 143/3 144/15
144/16 146/20 147/8 148/10
hasn't [2] 10/8 131/4
hat [1] 18/20
hauling [1] 82/25
have [160]
haven't [4] 89/24 131/18
147/12 147/13
having [5] 76/8 76/21 86/18
124/23 135/24
Hayrapetyan [8] 113/12
113/14 132/16 132/17 132/18
133/2 137/3 142/22
hazmat [1] 85/1
he [105]
head [2] 7/6 46/3
headquarters [1] 28/12
hear [9] 69/22 70/4 76/17
115/13 131/18 132/1 142/9
146/6 146/24
heard [14] 6/5 8/21 12/7
12/8 20/23 69/3 87/13 97/11
113/13 116/4 128/1 131/18
132/2 147/12
hearing [1] 115/4
hearsay [10] 50/6 51/24
52/18 53/4 57/12 64/2 64/24
108/12 110/17 110/19
heart [1] 106/23
heated [1] 107/9
height [1] 44/16
held [6] 5/6 69/23 77/11
80/18 125/12 150/6
Hello [2] 118/5 118/6
help [11] 23/3 24/4 24/6
25/7 49/5 81/2 88/7 89/3
89/8 102/6 111/25
helped [7] 81/3 81/9 88/19
89/6 89/11 89/18 111/17
helpful [3] 72/5 74/11 77/6
her [44] 32/9 32/9 35/3 43/5
87/14 88/18 88/18 88/19 89/3
90/9 90/11 102/6 102/11
102/11 102/20 103/11 103/19
104/9 104/10 104/21 105/19
106/14 106/17 106/19 106/21
107/2 107/7 107/13 107/17
109/15 110/14 111/2 116/2
117/8 117/20 118/24 119/9
119/19 119/21 119/25 120/3
120/4 120/5 140/18
here [22] 13/21 43/2 52/7
63/1 70/20 76/10 76/15 79/20
80/18 91/8 107/6 107/7 113/6
118/15 132/15 132/15 133/20
137/23 137/25 139/13 143/4
144/6
hereby [1] 150/4
hers [1] 98/4
hey [6] 89/1 106/19 108/9
109/15 111/19 111/24
hide [2] 112/18 112/21
high [1] 79/18
Highway [1] 3/20
him [34] 5/13 8/2 8/8 9/10
14/24 18/20 26/16 26/17
26/20 26/22 35/25 50/21
50/23 53/3 53/11 53/13 53/17
57/16 58/4 59/18 59/19 65/10
65/10 68/23 111/15 111/22
111/23 111/24 113/3 113/13
118/15 129/9 140/14 141/24
himself [1] 38/21
his [30] 14/25 19/4 40/13
40/17 50/13 50/20 50/24 51/9
52/2 52/13 53/10 53/15 53/16
61/16 61/17 111/14 127/16
127/17 127/18 132/21 133/7
133/14 136/21 137/1 137/7
137/11 137/11 139/19 139/21
143/12
histories [1] 56/17
history [2] 56/14 79/19
hit [3] 64/17 86/16 108/7
hits [1] 63/6
hold [3] 18/14 83/1 133/10
holder [1] 122/18
home [24] 32/23 35/14 35/17
40/2 43/6 43/9 45/17 50/14
78/16 78/19 78/21 78/23 79/1
87/12 87/12 87/14 96/4
102/18 104/1 107/20 138/19
138/21 139/23 143/12
homes [5] 39/24 40/1 55/19
55/23 134/10
honestly [1] 25/3
Honor [165]
HONORABLE [1] 1/3
hope [2] 41/10 58/18
hotly [1] 125/25
hotmail.com [1] 93/2
hour [2] 79/23 149/6
Hour-and-a-half [1] 149/6
hours [10] 79/23 81/24 81/25
82/1 82/2 82/2 82/4 106/14
106/16 149/6
house [17] 32/6 34/4 34/7
44/5 55/14 55/25 56/1 61/19
79/3 87/14 103/11 106/15
106/24 111/20 117/7 119/23
136/21
how [39] 13/14 13/17 35/5
37/21 47/18 47/21 47/24
48/22 52/2 52/5 52/8 53/10
53/13 53/19 54/8 54/15 71/14
72/25 73/3 74/9 78/10 78/19
79/9 81/5 82/7 82/12 85/24
103/4 103/5 103/8 109/22
110/22 132/1 132/2 132/3
138/22 139/4 142/18 149/4
However [1] 133/1
huh [2] 117/16 123/14
hundreds [8] 47/23 48/1
49/13 74/13 102/17 102/17
102/22 126/1
husband [1] 107/18
I
I'll [3] 108/11 108/14
119/10
I'm [4] 23/12 28/7 93/4
120/14
I.D [1] 4/12
iCloud [1] 21/10
ID [1] 106/9
ID's [5] 104/24 104/24
105/10 105/18 106/3
idea [3] 103/16 103/17
144/19
identification [7] 5/24 11/6
12/23 25/9 29/21 106/6 147/9
identifications [5] 43/19
43/20 44/18 45/1 46/2
identified [3] 57/11 58/13
148/10
identifiers [1] 144/22
identify [4] 24/6 72/19
82/21 116/2
identities [10] 15/13 15/22
16/11 19/9 44/8 44/9 49/16
49/19 53/22 130/22
identity [14] 34/13 43/22
44/1 44/5 44/10 44/11 115/17
115/20 136/19 138/18 144/20
144/25 147/11 147/16
illustrative [1] 132/9
image [10] 21/4 21/8 21/20
21/24 22/8 22/14 22/18 146/2
146/3 146/14
images [1] 20/23
important [1] 66/14
impression [1] 145/15
improper [3] 50/11 56/20
64/8
Inc [2] 7/11 33/20
incident [1] 107/4
include [6] 22/15 44/13
74/21 136/3 136/9 145/22
included [4] 22/20 25/4
137/2 147/20
including [2] 136/11 145/14
incomplete [1] 71/9
independent [2] 88/14 119/15
indicate [1] 41/18
indicated [2] 63/18 63/22
indicators [1] 142/2
indictment [1] 47/4
individual [1] 27/22
individuals [12] 17/22 17/25
43/17 45/23 46/11 49/18
53/23 54/23 66/18 67/7
127/20 128/1
industries [1] 135/25
inextricably [1] 147/7
information [24] 21/2 23/5
27/10 32/22 44/12 44/15
48/14 48/23 48/25 49/7 51/21
52/17 52/23 56/9 59/14 71/13
76/25 77/3 77/5 77/5 105/6
105/25 142/5 147/20
inhouse [1] 86/2
initial [4] 25/2 25/4 49/18
109/14
initially [2] 51/20 52/16
initiated [2] 27/18 27/20
Injijian [1] 136/7
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inquire [1] 25/18
instance [8] 30/8 44/13
48/18 49/5 49/12 49/20 52/8
55/6
instances [1] 48/17
instead [3] 18/25 64/1
137/11
institutions [3] 47/10 47/14
47/16
instruction [3] 6/1 144/9
144/10
instructions [2] 144/6
148/17
insufficient [1] 135/11
insurance [7] 38/4 82/10
83/19 85/14 85/17 85/19
85/20
intake [2] 75/17 75/20
intends [1] 148/9
intentionally [2] 114/16
114/19
interdependence [3] 131/13
134/3 142/18
interdependency [1] 132/6
interest [1] 79/1
Interiors [6] 7/3 7/7 7/11
9/22 136/4 136/5
interject [1] 64/6
Internet [3] 49/2 59/12
59/13
interrupt [1] 72/6
interrupted [1] 53/11
interrupting [1] 72/11
intertwined [2] 146/11 147/7
interview [3] 54/3 54/6
54/16
interviewed [2] 54/4 57/9
interviews [4] 47/11 53/25
54/12 57/24
introduced [3] 23/7 144/17
147/2
invent [1] 105/10
invested [1] 113/2
investigate [27] 14/14 14/23
14/24 15/3 17/22 19/4 20/1
25/1 27/14 30/23 35/1 35/9
37/7 37/10 38/15 38/23 44/1
47/3 57/4 57/14 61/3 61/13
65/4 65/7 65/9 65/11 67/3
investigated [4] 26/22 29/3
56/25 57/2
investigating [3] 36/11
46/24 66/18
investigation [29] 6/23 6/25
9/2 11/12 26/1 27/17 27/21
32/12 39/23 40/21 40/25 41/4
41/23 43/5 44/4 47/2 47/8
47/22 47/25 49/1 51/5 54/13
55/18 56/24 59/9 59/25 61/12
66/3 66/14
investigative [4] 9/25 13/24
43/3 47/7
investigator [1] 29/9
involve [1] 147/10
involved [14] 6/25 13/20
31/25 32/1 32/2 85/8 88/9
102/4 103/19 119/13 120/4
127/4 129/4 129/4
IP [33] 32/24 47/17 48/14
48/17 48/23 48/25 49/2 49/4
49/7 56/9 58/21 59/10 59/14
72/25 73/3 74/2 74/4 74/16
74/18 74/22 74/24 75/16
75/23 76/4 76/5 76/9 76/9
76/11 76/13 76/16 77/4 77/7
143/3
IRS [2] 37/4 115/3
is [526]
isn't [10] 32/15 46/14
119/16 122/11 124/18 124/21
124/25 144/24 145/10 147/3
issue [12] 53/5 58/15 58/19
62/23 65/4 65/12 71/6 71/23
77/2 126/20 127/3 132/3
issues [2] 57/13 58/18
it [372]
it's [3] 13/7 14/10 46/13
item [1] 134/7
items [3] 30/5 32/10 104/11
its [3] 59/22 131/6 131/9
Iulia [13] 26/12 27/8 49/18
50/16 50/17 51/21 52/24
52/25 55/11 55/12 133/3
133/22 138/17
J
January [2] 10/3 16/22
January 1st [1] 10/3
January 8 [1] 16/22
Jennifer [1] 3/12
Jewelry [1] 54/10
job [3] 80/3 83/21 107/19
jobs [7] 79/24 79/24 79/25
80/1 80/2 86/17 87/24
John [1] 3/4
Johnson [9] 2/14 2/17 2/19
2/22 3/19 3/20 4/5 4/9
116/13
joint [3] 36/16 131/13
142/18
Jr [1] 3/14
judge [2] 1/4 73/11
Judicial [1] 150/9
July [4] 19/20 121/15 122/3
140/12
July 13th [1] 121/15
July 21 [1] 19/20
July 27th [1] 122/3
July 3rd [1] 140/12
jump [1] 64/14
JUNE [4] 1/17 5/1 47/1
150/10
jury [36] 1/15 5/7 5/9 23/15
24/7 29/22 30/2 47/6 50/25
51/25 59/22 62/17 64/9 68/24
69/7 69/24 70/2 74/18 76/7
76/15 76/22 77/6 77/12 77/18
80/11 81/15 83/6 85/7 89/12
125/13 139/12 139/16 144/6
144/9 148/2 148/17
jury's [2] 51/4 69/10
just [92]
JUSTICE [3] 2/4 2/9 43/1
JUSTIN [1] 4/4
K
KATIE [2] 1/21 150/12
Katzman [2] 3/4 3/7
Kauichko [7] 41/10 41/20
48/20 130/5 130/8 130/11
130/17
keep [7] 51/7 59/25 80/5
81/24 96/4 103/1 132/18
keeping [1] 84/14
Keough [3] 2/19 70/25 72/12
keys [1] 102/18
kids [10] 103/2 103/2 104/21
105/17 106/24 107/3 107/14
107/15 107/19 107/22
kind [3] 12/6 81/24 85/16
Kirk [1] 65/18
kitchen [1] 104/6
knew [4] 67/4 109/11 114/10
130/6
know [82]
knowing [1] 84/21
knowingly [1] 145/12
knowledge [9] 10/21 10/25
12/11 15/5 22/6 45/2 61/2
66/23 110/3
knows [3] 8/9 23/22 103/1
Kopytova [1] 136/13
Kudiomov [7] 130/3 130/12
134/14 134/15 134/16 134/24
135/4
Kudiumov [1] 130/17
L
La [2] 55/7 57/10
Lacks [4] 7/19 9/15 14/19
20/3
lady [2] 88/6 117/6
Lamps [11] 27/9 27/11 27/15
28/12 60/4 62/14 63/7 64/17
65/5 65/8 65/12
language [1] 90/18
large [1] 76/7
larger [1] 141/19
last [4] 28/7 47/3 77/25
129/24
late [1] 58/10
late-produced [1] 58/10
later [5] 11/7 17/2 18/25
139/22 140/7
law [8] 3/15 3/20 84/21
117/4 117/6 141/11 141/12
141/15
laws [1] 108/23
lawyer [2] 91/21 106/25
lay [1] 9/11
lead [4] 24/1 24/3 29/3 29/8
learn [3] 55/4 65/7 115/15
learned [3] 33/15 70/24
105/13
lease [1] 85/21
least [5] 46/13 55/21 127/2
129/12 134/9
leave [2] 30/6 145/18
lecturn [1] 131/21
left [13] 30/9 45/21 60/23
69/7 83/22 93/13 94/21
111/13 123/20 123/23 124/20
134/18 137/20
left-hand [2] 93/13 94/21
legal [2] 43/24 59/3
Lendio [2] 18/19 18/21
let [32] 9/10 17/10 25/7
27/3 29/18 66/8 70/2 73/6
73/9 73/24 76/17 80/3 83/23
86/9 90/7 102/24 103/4 104/3
108/3 113/10 113/20 120/5
126/17 131/17 132/1 138/14
142/9 142/14 144/5 146/6
146/24 148/13
let's [43] 6/10 10/9 10/10
11/9 12/17 12/24 12/25 13/4
14/7 16/13 17/2 18/4 18/9
18/24 19/13 20/13 21/12
24/17 25/24 26/7 26/15 26/17
28/4 28/7 29/1 30/14 30/18
39/8 47/13 58/4 61/10 62/22
62/24 64/1 64/14 64/14 69/11
69/21 77/8 84/1 127/12
132/20 145/18
level [1] 60/1
Lewis [1] 3/4
liability [2] 38/4 85/17
license [24] 7/8 8/22 9/5
9/19 24/22 35/3 35/6 35/10
38/7 43/12 43/14 44/15 61/17
61/17 81/17 82/8 84/24 84/25
85/9 87/4 104/9 106/4 108/16
133/5
licensed [1] 35/2
Case 2:20-cr-00579-SVW Document 676 Filed 07/09/21 Page 160 of 170 Page ID
#:10719
L
licenses [5] 8/25 44/21 46/5
84/22 104/24
Licensing [1] 9/8
lies [1] 144/19
life [3] 79/20 89/15 103/7
like [51] 5/14 8/19 9/7
10/17 11/20 12/6 13/12 16/8
20/18 22/15 27/11 27/21
27/23 29/14 30/16 31/11
32/24 37/2 40/5 40/19 41/16
43/4 45/8 45/8 58/8 75/7
85/3 89/1 89/4 89/22 91/12
92/13 94/19 101/24 102/13
104/15 104/20 106/18 107/9
109/19 110/23 116/22 117/6
120/3 121/5 125/5 126/1
135/20 140/3 141/16 142/13
likely [2] 28/18 105/7
limo [4] 40/7 139/21 141/3
145/7
line [7] 13/2 18/7 18/10
18/18 18/24 122/3 137/23
line 2930 [1] 18/7
line 3280 [1] 18/18
line 3844 [1] 18/24
lines [3] 19/15 63/2 97/24
link [3] 48/11 75/23 133/8
linked [1] 53/22
list [2] 76/5 143/12
listed [5] 32/10 48/8 76/10
136/17 141/25
lists [3] 64/17 74/2 74/4
literally [1] 70/8
little [6] 80/5 89/24 93/10
101/24 139/10 148/17
Littrell [3] 3/4 3/4 3/7
Liudmyla [1] 136/13
live [3] 40/14 78/12 78/13
lived [5] 40/9 40/15 55/13
61/13 78/19
living [1] 55/8
LK [2] 136/13 136/16
LLC [6] 39/5 39/14 83/8 83/9
110/7 124/8
LLC's [1] 120/17
LLP [6] 2/14 2/17 2/19 2/22
3/4 3/7
load [1] 106/8
loads [1] 86/19
loan [37] 14/18 25/15 31/1
46/25 47/21 49/6 49/14 49/21
57/6 74/13 74/17 74/21 75/23
76/14 108/18 108/25 109/7
109/9 109/13 109/20 110/4
110/24 110/25 111/20 111/25
112/1 115/2 121/2 121/22
135/19 136/6 136/9 136/17
137/11 137/24 139/14 139/21
loaned [2] 89/13 89/14
loans [12] 48/7 48/9 54/24
108/3 108/6 110/22 114/11
121/20 129/19 136/11 136/15
136/22
local [3] 37/2 82/14 82/16
located [2] 7/12 27/15
location [4] 32/4 33/25
61/18 63/25
locking [1] 103/2
logs [1] 56/8
long [7] 5/20 25/4 35/5
78/19 79/9 81/25 149/4
longer [1] 82/4
look [53] 6/18 6/20 6/23 9/3
9/6 9/7 9/22 10/10 11/9
12/25 14/7 15/25 18/4 18/9
18/24 19/13 20/13 21/12
24/17 25/10 25/10 25/24 26/4
26/7 26/25 28/4 29/1 29/12
29/18 30/12 31/5 32/8 37/22
41/13 42/16 46/9 48/2 48/14
56/17 59/12 64/1 65/16 66/16
68/10 77/2 92/23 94/19 95/4
97/24 107/13 132/9 132/10
138/14
looked [9] 9/4 9/21 53/2
56/14 58/21 60/18 136/5
137/15 144/7
looking [8] 49/19 75/8 99/2
99/16 100/10 101/8 101/15
132/9
looks [12] 10/17 11/20 13/12
16/8 20/18 27/11 29/14 30/16
91/12 92/13 94/12 117/6
loop [1] 142/23
LOS [8] 1/14 1/23 2/7 2/15
3/9 3/16 5/1 80/17
lose [4] 72/7 106/20 131/9
148/24
loss [2] 109/2 129/22
lot [11] 34/14 53/6 79/25
80/1 80/16 81/3 86/13 111/8
111/10 124/25 139/15
lots [1] 147/13
Louisiana [2] 80/13 80/15
love [3] 88/13 107/14 124/17
lower [2] 93/13 110/9
lunch [2] 125/11 148/17
M
M-A-R-T-I-R-O-S-Y-A-N [1]
128/13
ma'am [4] 118/6 118/9 121/17
124/19
MacDonald [3] 32/4 32/7 32/8
made [12] 63/18 63/23 65/16
79/2 80/24 86/13 109/2
110/23 124/12 139/14 142/11
143/14
Madison [2] 32/3 32/7
magnified [1] 121/15
magnify [1] 68/8
mail [5] 25/19 50/3 50/6
50/8 102/12
mailbox [1] 102/12
mailed [2] 70/16 70/20
mails [6] 18/21 70/10 92/21
92/24 93/9 93/11
main [1] 129/17
maintained [1] 82/18
majority [4] 34/11 34/12
34/21 77/4
make [24] 9/10 26/23 39/8
49/8 56/4 59/2 59/22 64/8
67/14 69/2 80/22 87/19 89/2
106/18 113/23 114/16 114/19
130/7 132/20 140/14 140/18
140/20 143/4 143/4
makes [1] 145/11
making [3] 26/18 86/14 133/8
manager [1] 120/23
manually [3] 27/22 27/24
28/17
manufacture [1] 105/11
manufactured [1] 44/12
manufacturing [1] 43/19
Manuk [10] 6/7 56/14 57/2
57/5 127/16 129/18 129/25
131/11 133/22 147/15
Manuk's [6] 143/2 143/2
143/6 143/11 143/13 144/1
Manukyan [7] 11/16 11/21
21/19 133/3 133/5 133/7
138/7
many [14] 34/17 47/18 47/21
47/24 48/22 54/15 58/17
71/14 81/5 82/12 103/4 103/6
103/8 126/7
March [17] 15/7 17/11 17/15
17/24 19/9 20/9 66/17 84/1
86/9 103/5 103/8 113/24
114/2 114/6 114/22 114/25
134/22
March 2020 [2] 15/7 17/24
Marietta [9] 6/8 50/2 50/15
51/14 55/24 60/23 130/11
130/17 134/1
Marietta's [2] 55/8 55/16
marked [5] 5/24 11/6 12/23
29/21 75/9
Market [1] 2/20
marking [1] 58/11
marriage [3] 119/3 119/7
124/23
married [8] 79/5 79/7 79/9
87/9 88/16 90/9 103/21
118/10
Martirosyan [9] 14/14 14/17
15/4 15/7 15/14 15/23 17/13
128/3 128/5
Martirosyans [2] 128/9
128/12
mass [2] 147/20 147/23
Massino [2] 14/3 14/5
matter [3] 70/2 144/9 150/7
matters [1] 68/24
max [2] 83/23 104/14
may [27] 9/11 29/22 35/24
42/2 49/5 51/3 51/3 51/9
61/5 69/12 69/14 71/22 73/17
76/23 78/2 89/20 91/8 113/5
125/14 127/3 133/4 134/7
136/12 141/7 145/1 145/8
147/7
maybe [5] 12/8 46/3 73/25
130/24 132/5
me [85]
mean [48] 6/3 7/6 13/16 14/3
22/13 23/12 30/3 37/2 37/4
42/14 42/14 43/18 43/24 45/8
46/3 46/12 49/12 53/3 53/13
56/22 59/22 61/21 64/5 65/2
67/12 74/21 75/6 75/7 85/7
86/12 86/24 88/12 89/11
102/12 102/16 102/17 111/10
111/18 112/25 114/11 118/23
129/1 134/15 139/14 141/10
145/11 146/17 146/22
meaning [5] 23/19 25/18 63/5
129/13 132/21
means [2] 77/5 77/18
meant [1] 44/20
Media [2] 136/3 136/16
medical [2] 85/4 85/11
meet [1] 71/7
Meghan [1] 2/16
member [2] 141/8 141/15
members [2] 5/9 13/24
memory [1] 129/22
mention [1] 140/1
mentioned [4] 48/19 95/22
96/1 128/7
Mesereau [11] 3/14 3/15 4/5
4/9 31/19 35/1 61/23 78/9
80/6 80/8 90/1
message [4] 19/25 21/10
123/7 123/12
messages [11] 13/21 19/17
40/24 57/24 128/4 128/5
130/25 136/23 140/13 140/25
141/3
metadata [7] 22/8 22/10
22/13 22/17 22/20 22/23 23/6
Michael [3] 2/19 72/12 73/10
might [4] 14/24 36/11 46/7
46/11
Case 2:20-cr-00579-SVW Document 676 Filed 07/09/21 Page 161 of 170 Page ID
#:10720
M
million [1] 85/17
mind [4] 49/17 66/12 126/23
132/18
mine [2] 106/7 123/17
Minimum [1] 85/17
minus [1] 86/25
minute [1] 66/9
minutes [3] 69/21 77/9 129/2
Mirage [1] 63/7
mislead [1] 145/14
misleading [1] 145/12
missed [1] 136/14
missing [1] 73/1
misstates [3] 8/6 59/6 66/4
MO [1] 143/11
mobile [1] 47/16
Mod [6] 7/2 7/7 7/11 9/22
136/3 136/4
model [1] 144/8
modern [1] 12/8
moment [9] 45/15 62/14 66/1
69/9 71/25 86/8 91/21 128/25
133/17
moments [1] 70/8
mommy [1] 107/6
money [43] 36/14 49/9 49/11
52/2 52/5 52/24 53/10 53/14
53/20 53/21 54/1 80/23 80/24
81/17 86/13 89/13 89/14
109/2 109/19 109/22 110/15
111/6 111/14 111/14 111/16
111/24 111/25 112/5 121/7
121/18 121/23 132/10 132/10
132/16 133/1 137/12 138/12
140/10 140/15 141/22 141/24
143/14 143/19
Monica [1] 3/15
monies [2] 133/10 142/23
monitor [1] 91/24
monitors [1] 68/1
month [2] 16/20 62/19
month-and-a-half [1] 62/19
monthly [1] 135/22
months [4] 60/22 80/20 110/5
140/7
more [14] 19/16 24/12 53/7
61/8 62/19 72/6 73/4 76/2
101/24 109/23 110/2 110/9
126/9 130/24
morning [10] 6/16 6/17 31/17
31/18 39/21 46/22 46/23 78/8
78/9 107/21
mortgage [1] 126/24
most [5] 73/1 75/5 105/7
132/9 134/5
mostly [1] 89/18
mother [7] 117/4 117/6
117/18 117/19 117/20 117/21
138/19
mother's [1] 117/19
mother-in-law [2] 117/4
117/6
motions [2] 126/14 146/5
motor [4] 38/12 38/12 81/25
82/19
motorcycle [1] 122/25
move [17] 5/14 7/17 10/9
11/2 12/17 12/18 29/16 41/16
50/5 56/10 58/5 58/9 60/2
86/19 119/23 123/20 133/12
moved [2] 106/24 112/5
moves [1] 117/12
moving [12] 66/23 67/5 95/9
95/14 96/7 96/22 98/6 98/18
99/9 99/25 100/19 100/25
Mr [27] 4/4 4/5 4/5 4/6 4/6
4/7 4/9 4/9 10/12 11/11
13/10 15/2 26/25 35/1 58/7
58/20 60/3 60/17 61/12 64/11
65/21 66/1 78/9 80/6 80/8
90/1 144/12
Mr. [47] 5/12 31/17 38/1
40/2 40/9 40/11 53/11 56/13
58/20 59/9 59/16 60/3 61/23
67/21 68/4 69/16 70/4 70/25
77/21 78/8 90/2 91/10 92/3
94/7 94/15 97/17 101/24
113/10 118/5 118/13 125/17
126/19 132/2 132/25 133/7
133/9 133/20 134/1 134/14
136/20 136/22 137/1 137/4
139/19 142/10 145/6 145/7
Mr. Anton [1] 134/14
Mr. Arman [1] 137/4
Mr. Artur [3] 69/16 77/21
145/6
Mr. Avazyan [1] 133/9
Mr. Ayvazian [12] 38/1 78/8
90/2 91/10 92/3 94/7 94/15
97/17 101/24 113/10 118/5
133/7
Mr. Cruz [2] 59/16 67/21
Mr. Dadyan's [1] 40/11
Mr. Fenton [1] 70/4
Mr. Harapetyan [1] 132/25
Mr. Keough [1] 70/25
Mr. Mesereau [1] 61/23
Mr. Palmerton [2] 5/12 31/17
Mr. Paronyan [1] 133/20
Mr. Ram [10] 53/11 56/13
58/20 59/9 60/3 68/4 126/19
132/2 137/1 142/10
Mr. Richard [3] 134/1 136/20
136/22
Mr. Vahe [6] 40/2 40/9
118/13 125/17 139/19 145/7
Ms [2] 4/10 124/17
Ms. [10] 68/8 124/20 134/1
136/24 138/19 139/5 139/23
142/14 142/17 146/3
Ms. Ahn [2] 142/14 142/17
Ms. Dadyan [2] 124/20 139/5
Ms. Marietta [1] 134/1
Ms. Paul [1] 68/8
Ms. Tamara [1] 136/24
Ms. Terabelian's [3] 138/19
139/23 146/3
much [5] 18/25 86/1 88/21
109/22 127/7
multi [1] 126/22
multi-conspiracy [1] 126/22
multiple [5] 63/23 130/21
131/23 132/4 142/19
must [2] 6/9 65/19
my [118]
myself [6] 9/24 40/11 83/25
84/11 130/7 148/20
N
name [45] 4/3 10/23 12/10
12/11 14/25 16/10 25/16
26/12 31/19 32/19 40/6 41/9
41/10 41/20 43/15 44/13
48/19 50/1 50/14 51/14 52/25
55/10 55/11 55/12 65/18
72/11 77/23 77/25 83/3 88/6
94/21 104/10 112/17 116/1
117/8 120/21 122/18 123/18
130/1 133/6 133/8 134/12
136/10 137/11 144/21
named [3] 11/15 47/4 95/17
names [3] 92/20 128/2 134/13
Natalie [1] 93/10
necessarily [1] 23/6
need [11] 45/13 77/17 84/23
85/10 85/11 90/17 105/20
106/19 108/10 112/1 130/7
needed [1] 111/9
net [2] 86/22 87/1
never [14] 12/8 25/22 33/2
46/14 46/14 104/2 104/2
112/19 112/19 113/13 114/10
114/18 119/22 125/6
new [11] 2/10 2/18 13/13
90/17 110/7 110/8 112/17
140/14 140/18 140/23 141/23
Newcomer [1] 2/16
news [1] 108/8
next [15] 6/10 21/13 27/10
29/1 30/22 30/22 69/6 69/6
69/22 100/19 102/18 117/6
118/18 124/2 138/13
Nicholas [1] 2/22
night [2] 106/16 107/5
nine [1] 79/21
Ninth [2] 141/7 144/9
no [162]
Nobody [1] 86/18
none [1] 40/1
nontax [1] 62/4
North [2] 2/6 3/20
not [142]
note [4] 136/8 136/15 141/6
141/22
nothing [3] 33/1 33/5 108/17
notice [5] 70/7 71/5 91/21
121/18 126/2
November [1] 45/18
November 5th [1] 45/18
now [61] 10/10 12/24 14/7
16/13 17/2 18/4 18/17 18/24
19/13 20/13 21/3 21/3 21/12
24/17 25/13 25/24 26/21 28/4
29/1 33/6 35/8 35/14 43/4
51/5 53/12 63/5 64/14 64/16
68/14 68/18 70/2 72/10 79/14
80/3 81/12 83/4 84/14 86/5
86/20 87/10 88/15 88/20 90/7
92/5 92/20 93/19 97/9 97/16
103/12 104/22 107/20 108/3
108/11 115/2 115/17 122/14
127/12 129/20 130/14 148/13
149/8
number [23] 23/20 23/21
23/25 24/23 27/11 27/13 29/6
42/17 42/18 48/6 68/11 68/12
76/7 123/24 123/25 124/2
124/3 126/18 136/18 136/18
136/20 140/13 142/6
numbers [8] 42/18 42/19
42/21 42/22 42/22 48/8 48/11
135/21
numerous [1] 83/17
NW [2] 2/10 2/23
NY [1] 2/18
O
o'clock [4] 71/3 106/15
107/5 149/8
oath [1] 6/12
objection [66] 5/19 5/21
7/19 7/25 8/6 8/15 9/9 9/11
9/14 9/15 11/4 12/20 12/21
14/19 15/15 17/5 17/20 18/1
19/10 20/3 20/10 21/22 22/9
23/18 24/11 29/17 29/19
33/21 33/23 34/19 34/23
35/22 36/8 36/17 37/18 39/1
39/6 50/5 50/10 50/18 51/24
52/18 53/4 56/10 56/20 56/23
57/12 58/14 58/24 59/2 59/3
64/3 64/23 66/4 66/25 67/8
67/9 70/3 70/4 70/7 88/23
108/12 110/17 110/19 114/13
149/1
Case 2:20-cr-00579-SVW Document 676 Filed 07/09/21 Page 162 of 170 Page ID
#:10721
O
obligations [1] 81/10
obtain [5] 22/7 22/17 66/21
67/3 129/19
obviously [1] 142/1
occur [2] 28/2 46/6
occurred [4] 27/15 28/18
146/9 147/9
October [9] 26/2 27/7 60/7
63/24 64/15 64/22 65/21
65/22 68/9
October 13 [1] 60/7
October 13th [3] 63/24 64/22
68/9
October 14th [3] 26/2 27/7
64/15
off [8] 7/6 25/14 46/3 56/8
85/23 102/11 107/12 113/1
offense [1] 146/21
offer [1] 9/10
offered [1] 119/9
offering [1] 9/12
office [23] 2/4 3/20 33/6
33/9 33/11 33/14 33/15 33/18
33/18 34/7 34/22 87/12 87/14
87/14 87/16 87/17 87/18
87/21 87/22 96/4 104/1 104/4
104/11
offices [1] 71/3
Official [1] 1/21
often [1] 140/19
oh [8] 26/7 53/3 89/1 93/4
102/21 105/19 110/23 116/24
oil [1] 80/21
okay [85]
old [6] 78/10 78/11 79/21
79/22 89/20 105/17
old-fashioned [1] 89/20
older [2] 81/6 118/8
oldest [1] 93/8
omissions [1] 144/11
once [5] 5/9 13/1 16/24 82/9
86/16
one [90]
online [1] 28/23
only [21] 13/8 33/18 36/1
37/25 49/7 52/11 74/23 82/1
82/2 82/18 102/2 103/7 106/4
106/7 109/16 125/22 134/4
134/7 139/12 145/22 148/8
open [2] 25/5 47/9
opened [6] 41/18 41/19 42/9
110/7 110/10 110/11
opening [1] 120/16
operate [1] 87/11
opinion [2] 50/20 64/6
opinions [1] 50/24
opportunity [2] 67/14 132/3
opposed [2] 66/23 67/5
optional [1] 85/1
options [1] 86/1
order [1] 14/11
organization [1] 39/13
original [1] 52/4
other [58] 9/6 12/6 13/24
28/21 31/3 31/11 47/11 47/12
47/15 51/2 52/1 54/12 54/12
54/15 59/12 59/13 59/14
66/24 67/6 69/1 75/25 84/25
90/18 93/9 93/11 94/16 99/2
125/8 125/21 126/15 126/23
126/24 127/1 127/19 127/24
129/11 129/13 129/14 131/14
132/19 132/21 132/21 134/7
135/9 135/11 139/6 141/17
142/2 142/6 143/9 143/13
144/22 145/12 146/9 146/10
146/12 146/13 147/5
others [2] 21/8 141/17
Otherwise [1] 30/8
ought [1] 148/6
our [19] 10/17 10/18 18/14
29/14 42/19 42/21 43/1 55/2
70/9 71/3 77/13 102/3 107/19
107/19 130/18 132/14 135/5
135/16 138/9
out [37] 26/2 30/4 35/12
37/4 49/4 49/14 51/19 62/18
62/20 79/18 79/22 81/3 85/12
88/6 88/19 89/3 102/19
106/19 106/24 109/7 111/23
112/1 115/5 115/7 115/8
119/7 119/9 119/23 122/7
124/16 126/24 131/15 131/24
132/17 138/17 143/3 143/12
outs [1] 147/10
outset [1] 73/25
outside [9] 5/6 17/6 69/23
70/1 77/17 83/2 125/12
139/11 139/15
over [11] 27/23 28/18 28/20
47/2 47/20 107/7 107/9
107/11 109/24 133/3 140/11
overall [1] 146/23
overhead [1] 89/20
overruled [17] 15/16 20/4
20/11 36/9 50/11 51/25 52/20
56/12 56/22 59/5 59/7 64/25
68/19 88/24 108/13 110/20
114/15
owe [1] 112/1
owed [1] 111/14
own [6] 37/13 78/21 81/16
85/21 88/3 106/9
owned [11] 32/13 32/23 33/3
37/11 37/23 38/1 78/23 82/12
82/18 83/11 85/22
owner [2] 32/16 32/19
ownership [1] 33/2
owning [1] 38/18
P
Pacific [1] 3/20
package [4] 63/25 64/21 65/8
65/18
packages [2] 102/10 102/11
packed [1] 80/17
PAETTY [1] 2/5
page [76]
pages [10] 9/7 16/14 30/18
73/15 73/15 73/16 73/21
74/13 97/5 97/9
paid [6] 36/24 37/6 85/23
111/14 113/3 138/19
PALMERTON [27] 4/4 5/12 6/6
6/16 6/20 6/22 7/22 8/3 9/17
10/13 11/11 12/10 13/10
15/18 16/6 16/18 21/18 22/13
30/1 31/17 46/22 53/19 58/7
59/8 67/21 68/3 68/20
pandemic [5] 30/20 30/24
86/16 109/24 134/19
paper [1] 6/3
papers [1] 89/1
paralyzed [1] 88/21
Paronyan [9] 25/1 25/5 25/16
113/18 127/18 133/20 136/10
136/24 137/2
part [24] 6/22 9/2 11/11
25/25 32/1 32/2 43/11 44/4
46/1 47/2 47/7 55/18 56/24
61/12 63/4 75/5 79/3 127/7
132/19 132/25 137/14 141/19
142/22 144/1
participant [3] 140/17
140/18 141/23
participants [1] 141/9
particular [3] 13/25 16/15
126/22
parties [8] 5/8 5/25 58/3
59/24 67/13 69/1 69/2 140/1
partner [2] 80/12 123/16
partners [1] 107/18
party [1] 52/19
Pass [1] 69/9
passing [1] 79/22
past [2] 107/4 114/12
patience [1] 72/7
patterns [1] 143/10
Paul [1] 68/8
pause [4] 21/16 30/14 128/25
138/15
pay [9] 103/12 111/4 111/20
112/1 112/24 112/25 120/11
121/9 122/1
Paying [1] 84/21
payment [4] 15/21 17/12
17/19 86/3
payments [4] 15/13 17/23
111/3 111/9
payroll [5] 19/21 19/22
135/22 135/22 142/1
Payrur [2] 113/11 127/19
pen [2] 117/13 117/15
pending [2] 124/14 125/7
people [13] 12/5 35/17 43/19
45/1 45/4 45/7 45/24 46/1
46/7 106/15 107/12 113/11
130/21
people's [2] 44/12 105/24
per [1] 25/19
percent [2] 140/2 140/6
perception [1] 127/2
perform [2] 84/20 88/25
period [4] 17/6 17/8 84/1
86/9
Perk [1] 65/18
permit [1] 38/12
permits [4] 82/9 82/10 82/25
87/23
person [21] 16/25 32/20 42/1
42/12 42/14 94/24 116/4
117/23 126/19 128/6 129/23
129/24 134/11 135/3 141/7
141/13 143/9 144/20 144/21
144/22 145/2
personal [2] 89/15 90/16
personally [5] 12/14 12/16
31/22 54/25 55/1
Peter [3] 3/19 3/20 116/13
phone [39] 13/16 13/17 20/1
20/18 20/20 20/24 21/5 21/9
21/9 21/25 22/1 22/8 23/5
24/23 24/25 27/11 27/13
27/23 28/18 28/20 51/23
102/18 102/20 102/22 102/24
102/25 103/1 103/3 103/7
104/25 105/2 105/4 105/6
120/5 133/5 136/20 136/21
146/3 146/15
phones [6] 102/14 103/4
103/6 103/8 103/10 147/21
photo [6] 21/15 21/17 22/15
22/19 22/24 23/6
photograph [1] 42/8
photos [8] 45/8 45/16 45/16
45/20 104/20 104/21 105/16
116/25
physical [3] 41/21 85/19
148/11
physically [1] 42/3
pick [3] 102/10 106/8 120/5
picked [3] 64/21 65/8 65/18
picture [2] 142/13 143/17
pictures [7] 44/25 45/3 45/4
45/7 45/7 104/19 105/17
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piece [1] 6/3
pizza [1] 79/22
place [4] 60/7 60/20 102/12
115/13
placed [1] 32/24
places [2] 47/15 79/25
PLAINTIFF [2] 1/7 2/3
plaques [2] 104/13 104/15
platform [2] 11/22 12/5
play [1] 103/3
please [21] 15/19 45/15
59/17 60/10 60/11 69/25
70/18 73/13 80/11 81/15 83/6
84/10 85/7 86/12 86/24 89/2
95/4 102/16 107/8 117/17
117/18
Plus [11] 27/9 27/11 27/15
28/12 60/4 62/14 63/7 64/17
65/5 65/8 65/12
point [26] 26/18 33/15 35/7
42/8 58/18 59/19 59/23 61/6
69/4 70/4 74/9 80/9 81/12
82/13 105/11 106/10 126/21
127/2 130/24 136/4 138/17
140/13 143/13 145/1 146/25
147/6
pointed [1] 53/8
pointing [1] 124/16
points [2] 69/3 143/4
portion [1] 68/15
portions [3] 145/8 148/2
148/8
posited [1] 142/19
position [5] 71/25 74/10
131/19 138/7 138/9
possibility [1] 129/12
possible [2] 42/14 117/9
possibly [3] 14/3 22/16
143/20
Post [1] 92/14
Post-it [1] 92/14
potentially [1] 129/16
powering [1] 70/9
PPP [33] 25/15 30/25 34/12
40/6 46/24 51/17 54/22 57/5
66/23 67/4 108/3 108/5 108/8
108/18 109/12 110/4 112/3
115/2 119/7 121/4 127/3
129/19 133/2 133/24 135/19
137/11 137/21 137/24 138/1
138/10 139/21 140/2 142/5
predated [1] 146/4
prefer [1] 148/23
preference [2] 148/21 149/7
preloaded [1] 106/8
prenuptial [1] 103/20
preparation [1] 24/4
preparer [1] 147/22
prerequisites [1] 71/8
presence [8] 5/7 69/24 70/1
77/12 77/18 125/13 139/12
139/15
present [4] 5/8 30/7 30/9
108/20
presented [1] 131/16
president [5] 110/16 110/22
110/24 136/18 136/19
PRESIDING [1] 1/4
pretty [1] 88/21
previous [1] 133/16
previously [4] 20/23 68/14
120/15 123/10
primarily [1] 34/9
primary [1] 76/19
Primavera [3] 55/7 57/10
138/23
principal [1] 77/2
principle [1] 134/2
prior [11] 15/7 17/10 17/14
17/15 17/24 19/9 20/8 21/21
33/13 66/17 147/9
probably [3] 87/1 132/8
134/4
problem [2] 71/20 88/20
problems [1] 76/20
proceed [1] 78/2
proceedings [8] 1/13 5/6
69/23 77/11 125/12 138/15
149/10 150/6
proceeds [2] 54/22 140/3
process [2] 13/20 80/14
processed [1] 80/16
produced [6] 10/20 42/22
58/10 74/3 74/7 139/16
production [1] 10/17
profit [2] 86/22 86/23
profitable [3] 86/5 86/7
86/10
program [1] 85/9
prompting [1] 130/7
properly [1] 83/21
properties [2] 29/15 55/6
property [4] 22/24 30/3 30/5
57/11
proponent's [1] 71/25
proposed [2] 144/7 144/8
proposition [1] 131/8
proprietorship [3] 83/7
112/9 123/3
protocol [1] 49/2
proved [1] 131/4
provide [2] 73/10 73/13
provided [7] 24/7 32/9 70/7
72/16 72/16 72/20 108/17
providers [2] 47/17 47/17
publicly [2] 6/23 7/23
publish [1] 29/22
pull [8] 9/18 13/5 16/2
20/24 62/3 62/22 128/2
132/15
pulled [2] 61/16 61/23
pulls [1] 47/12
punched [2] 28/17 28/19
punctual [1] 5/10
purchase [11] 27/9 27/18
50/1 51/13 57/10 63/18 79/2
82/20 89/13 138/18 138/19
purchased [6] 50/14 54/22
55/7 55/10 55/12 81/18
purchases [1] 63/23
purport [3] 71/12 71/15
72/23
purportedly [2] 34/6 77/1
purports [4] 71/16 71/19
72/25 74/1
purpose [5] 52/11 71/13
75/22 76/3 142/1
purposes [3] 112/7 115/22
127/3
pursuant [2] 30/10 150/4
pursue [1] 57/20
pursuit [1] 57/17
put [12] 6/18 11/8 67/16
84/19 85/2 102/18 103/22
105/2 105/6 112/3 115/11
142/14
putting [1] 25/13
Q
qualified [1] 109/1
qualifies [1] 109/3
qualify [2] 108/10 110/1
quality [1] 64/6
question [27] 8/3 14/21 15/2
15/17 17/11 20/5 23/13 29/7
31/12 37/19 39/8 52/5 57/14
65/3 65/10 65/11 65/25 66/12
66/20 67/2 73/18 116/13
116/17 124/14 125/7 125/8
126/18
questioning [2] 50/24 53/7
questions [19] 31/10 39/17
40/5 40/19 46/17 50/23 53/17
58/21 61/8 62/7 64/8 65/24
67/10 69/5 113/20 116/6
117/25 125/3 144/10
quickly [1] 60/12
quite [3] 66/1 140/19 147/8
R
radio [1] 108/9
Radius [2] 49/22 51/17
raise [3] 102/2 107/19
118/25
raised [2] 70/2 70/25
Ram [22] 2/13 4/4 4/6 10/12
11/11 13/10 15/2 26/25 53/11
56/13 58/20 59/9 60/3 64/11
65/21 66/1 68/4 126/19 132/2
137/1 142/10 144/12
Rancho [1] 63/7
random [1] 79/24
rather [1] 76/8
RE [1] 104/14
RE/MAX [1] 104/14
reached [3] 37/4 51/19
111/23
read [3] 19/1 19/25 28/20
reading [2] 69/18 128/20
reads [1] 68/10
ready [1] 5/11
real [28] 9/23 16/25 34/9
34/11 34/22 35/2 35/6 35/10
37/8 44/23 44/24 45/1 45/1
45/24 53/23 87/2 87/4 87/7
88/15 102/4 105/25 117/8
117/24 134/8 134/16 134/20
144/21 145/7
really [5] 7/12 86/1 107/4
108/10 143/4
realm [1] 145/16
realtor [1] 105/23
Realty [1] 33/20
reason [5] 63/23 74/15 91/22
112/6 140/24
reasonable [1] 131/5
reasons [4] 74/12 83/18
125/25 126/11
recall [26] 9/20 9/24 15/24
19/6 25/6 31/4 32/18 33/1
33/5 35/8 38/14 39/15 41/2
42/5 42/6 47/12 48/22 48/24
53/3 60/4 65/19 79/4 91/16
133/4 135/1 145/19
recalled [1] 133/25
receipt [2] 30/3 30/4
receipts [2] 29/14 87/24
received [15] 5/22 11/5
12/22 29/20 36/1 109/14
110/4 121/2 121/7 121/20
121/22 122/9 126/12 133/24
141/22
receivers [1] 86/17
receiving [1] 17/23
recess [4] 77/8 77/10 125/11
149/9
recognition [3] 45/9 46/10
46/12
recognize [51] 6/21 7/5 7/7
7/22 8/1 8/4 8/13 8/16 8/17
10/14 10/22 10/24 11/18
13/11 16/7 20/16 21/14 21/17
24/19 29/13 30/15 42/18
45/16 45/20 68/21 71/18
82/24 90/11 91/3 91/4 92/8
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recognize... [20] 92/16
92/23 93/9 93/15 93/23 94/11
95/5 95/17 95/22 96/1 96/15
96/25 97/20 98/11 98/23
99/12 100/6 100/15 116/25
117/2
recollection [2] 17/17 140/5
record [9] 7/23 9/18 16/16
41/17 77/24 116/23 132/6
139/13 139/13
records [28] 6/24 11/13
11/15 15/9 15/12 15/21 37/25
38/15 39/4 41/5 44/22 47/9
47/24 48/3 48/5 48/6 48/18
48/20 49/13 49/20 49/24
51/12 51/16 53/2 53/21 61/16
63/22 74/13
Recross [3] 4/7 62/12 67/19
Recross-Examination [3] 4/7
62/12 67/19
redaction [1] 148/6
redirect [2] 4/6 67/11
Redline [1] 136/9
Redondo [1] 3/21
reeds [1] 68/12
refer [1] 135/13
reference [1] 76/16
referenced [11] 24/10 71/10
72/19 73/21 76/4 92/20 92/21
126/5 128/2 128/4 128/5
references [6] 19/1 74/4
76/5 76/22 87/13 137/24
referred [4] 40/23 117/23
135/4 138/22
referring [4] 23/4 40/1 50/6
147/19
refresh [1] 17/17
regard [1] 136/25
regarding [5] 22/8 126/21
132/6 139/8 144/10
regards [1] 66/17
register [1] 19/21
regulations [2] 108/22 150/8
rejecting [1] 125/24
relate [2] 30/19 148/3
related [7] 34/9 34/22 36/21
36/25 41/3 67/6 118/13
relating [2] 52/19 52/23
relation [1] 19/25
relationship [10] 19/5 36/11
57/15 57/20 57/25 74/22
101/25 102/2 118/24 118/25
relative [1] 139/23
released [1] 18/14
relevance [9] 17/6 17/20
18/1 19/10 20/10 36/8 39/1
88/23 146/16
relevant [7] 17/6 17/8 48/25
51/3 61/5 146/20 146/23
relief [1] 109/19
relinquishing [1] 78/25
rely [1] 131/14
remaining [1] 30/18
remains [1] 125/15
remember [8] 20/21 41/2
56/15 58/17 62/15 70/13
134/7 139/25
reminded [2] 6/11 115/25
renew [1] 126/14
Repair [1] 10/23
repairs [2] 87/25 111/9
repeat [1] 15/19
rephrase [2] 103/5 104/3
report [13] 13/19 19/22 21/1
22/25 23/2 23/4 23/8 24/9
25/3 36/1 135/22 135/24
148/9
reported [3] 35/24 135/23
150/6
Reporter [1] 1/21
REPORTER'S [1] 1/13
represent [4] 39/21 72/23
72/25 74/1
representation [1] 137/1
representative [2] 63/17
64/20
representatives [2] 54/4
136/7
represented [1] 46/4
represents [1] 137/21
requested [6] 42/6 44/21
47/14 49/20 52/17 52/23
requesting [3] 47/9 48/23
51/21
require [2] 85/9 85/19
required [3] 38/24 39/5 39/7
requirement [1] 141/12
Res'd [1] 4/4
research [3] 25/5 40/15 47/9
resell [1] 80/14
residence [15] 32/13 32/15
32/17 32/19 33/3 33/6 33/10
33/14 33/16 33/19 36/2 51/13
55/9 55/10 138/23
residences [1] 54/21
residing [1] 78/20
respect [4] 22/10 39/7
139/24 141/21
respective [1] 69/3
response [1] 126/20
responsibilities [1] 32/4
rest [1] 145/14
restate [1] 67/2
restaurants [2] 79/25 80/18
restriction [1] 68/25
result [1] 55/4
resume [1] 5/11
RESUMED [1] 6/14
retained [1] 56/9
return [1] 36/16
returns [4] 36/6 36/16 61/24
62/4
review [11] 15/9 20/7 26/17
29/9 47/21 47/24 51/7 58/4
59/20 108/18 108/22
reviewed [5] 8/5 34/2 37/25
49/13 49/24
reviewing [6] 25/11 51/6
51/11 53/21 57/22 69/1
Rich [10] 13/12 130/12 131/5
131/7 131/11 131/12 140/14
140/18 140/23 141/23
Richard [36] 1/9 26/1 50/1
50/4 50/15 50/16 51/14 53/3
55/24 56/25 57/4 57/11 57/15
60/23 62/20 81/7 89/5 111/19
118/7 129/16 130/16 132/7
133/4 134/1 134/9 136/8
136/20 136/22 138/8 139/6
141/23 142/25 143/15 143/18
143/23 143/25
right [84]
right-hand [6] 10/13 91/13
92/6 92/13 117/9 117/10
Road [1] 3/12
role [3] 29/8 33/24 145/6
room [1] 5/13
rooms [3] 34/3 35/21 36/3
roughly [1] 111/3
router [1] 56/8
routers [2] 56/2 56/5
RPR [1] 150/12
rule [2] 58/13 71/13
ruled [1] 146/22
rules [1] 108/22
ruling [2] 56/21 77/16
Runyan [3] 40/20 139/22
140/12
Runyantax.com [1] 41/4
Runyon [1] 41/6
Russia [1] 134/24
Russian [1] 130/1
Ryan [1] 3/7
Rysik [1] 94/22
S
safety [1] 107/16
said [41] 8/1 8/15 14/22
17/11 28/9 29/6 36/20 37/15
37/23 47/13 49/12 53/1 56/25
57/16 60/9 63/18 64/21 70/13
89/5 97/15 102/6 107/6 107/6
107/13 108/15 109/15 109/18
109/21 110/14 111/3 111/4
111/23 111/25 118/24 119/10
135/10 136/14 139/11 139/15
140/16 142/17
saint [1] 114/11
Sakyan [3] 16/9 16/10 16/23
Samantha [1] 65/18
same [25] 9/21 17/3 17/24
18/17 19/14 30/19 40/7 67/6
73/12 95/9 95/14 95/19 95/24
97/16 121/12 127/5 135/21
135/21 135/22 135/22 135/23
135/23 135/24 144/9 148/21
San [2] 2/21 3/6
Santa [1] 3/15
sat [1] 140/10
saved [2] 111/24 111/25
saw [15] 21/8 24/24 33/2
34/16 34/17 38/20 44/13 46/4
49/21 49/22 51/12 51/17
70/24 71/2 105/4
say [30] 8/9 8/10 8/11 11/24
23/22 28/16 34/11 42/12
42/21 43/1 43/18 46/12 59/1
66/6 70/12 76/2 76/14 77/7
82/15 83/2 86/20 105/13
123/7 129/17 130/14 131/3
132/23 137/2 147/22 149/4
saying [9] 41/10 53/3 70/19
75/20 116/16 129/3 144/3
145/13 148/7
says [20] 14/11 18/10 18/19
27/4 27/10 64/15 90/16 93/1
93/5 96/10 97/24 102/21
102/23 105/19 108/11 108/14
122/20 123/9 124/8 133/13
SBA [4] 31/1 97/25 121/3
121/4
scared [2] 107/6 107/22
scheme [2] 126/24 126/25
schemes [2] 126/24 131/10
school [2] 79/18 81/17
scope [4] 51/4 58/24 59/4
68/17
SCOTT [1] 2/5
screaming [1] 107/7
screen [15] 6/19 11/18 13/3
16/2 22/18 24/20 25/14 27/1
29/12 29/24 93/3 103/2
116/23 117/10 117/10
screenshot [1] 19/18
scroll [4] 16/14 26/15 30/12
30/18
sea [1] 111/17
seafood [8] 80/1 80/3 80/8
80/14 80/14 80/16 89/6 89/14
search [22] 29/15 30/4 30/6
30/11 31/20 31/22 31/23 32/5
32/9 33/13 33/17 33/22 34/1
35/23 40/2 45/18 47/11 55/18
55/23 57/23 136/21 143/12
searched [9] 32/16 33/9
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searched... [7] 33/10 33/11
55/24 56/1 61/19 78/16
107/20
searches [3] 39/22 39/24
87/13
seated [2] 69/25 125/14
second [17] 7/13 24/17 70/11
71/24 73/3 73/22 74/15 75/17
77/2 91/8 111/12 113/6
121/22 129/23 137/19 137/25
145/19
secret [1] 112/13
Secretary [2] 39/4 39/13
section [2] 22/24 150/4
Secureline [2] 33/19 133/23
security [3] 24/23 44/14
106/9
see [125]
seeing [3] 40/17 116/8
123/19
seem [1] 145/16
seemed [1] 134/11
seems [4] 92/12 94/21 144/16
148/1
seen [4] 74/19 90/8 90/9
130/19
seize [1] 56/1
seized [11] 20/19 29/9 30/5
30/10 32/11 43/9 43/11 45/17
46/5 68/21 90/4
selecting [1] 13/20
selective [1] 74/20
send [3] 12/5 18/19 107/11
sending [1] 141/24
sense [1] 145/5
sent [4] 18/20 24/23 24/24
51/18
separate [10] 35/21 36/3
36/5 36/16 64/16 75/9 75/12
107/24 108/1 118/20
separated [1] 119/21
separately [2] 103/14 148/10
separation [1] 119/22
series [2] 43/11 131/14
served [3] 47/18 48/23
106/21
service [3] 47/16 139/22
140/12
Services [1] 41/6
SESSION [1] 1/16
set [6] 87/24 106/17 112/13
112/17 137/20 137/25
Seven [1] 77/8
several [5] 21/21 39/22 97/9
136/11 140/24
she [63] 28/11 28/13 28/14
28/16 28/16 28/17 28/21
28/22 35/5 57/11 63/18 87/8
87/12 87/12 88/7 88/8 88/11
88/13 88/19 88/20 88/22
88/25 102/6 102/9 102/14
102/21 102/23 102/25 103/1
103/8 103/22 104/13 104/13
104/14 104/20 105/19 105/23
105/24 105/25 106/23 106/23
107/6 108/11 108/14 108/15
108/16 109/8 109/10 109/13
109/18 110/15 110/23 111/3
115/8 115/9 115/9 117/8
118/13 119/9 119/10 120/4
134/8 134/21
shift [1] 82/3
shifting [1] 84/20
shipped [2] 63/25 80/17
short [4] 71/4 126/2 143/4
143/6
shortly [1] 129/21
should [10] 14/11 21/12
22/19 22/20 22/22 23/1 73/25
77/13 148/1 148/18
shouldn't [1] 131/3
show [24] 13/4 25/7 25/9
41/12 45/14 58/8 59/16 59/18
68/14 76/4 76/15 89/22 91/19
94/15 115/9 116/22 116/23
120/14 122/14 123/4 123/10
123/22 131/7 139/7
showed [4] 37/25 55/13 63/24
68/4
shower [2] 102/19 102/20
showing [11] 10/7 21/4 59/16
68/4 90/13 90/23 91/7 93/19
94/5 135/20 135/21
showings [1] 134/10
shown [1] 97/5
shows [6] 74/15 129/4 130/20
135/18 136/1 139/19
side [3] 10/14 92/13 99/2
sign [2] 30/7 79/2
signature [5] 16/8 26/11
41/9 41/21 120/25
signed [7] 41/24 42/4 42/13
78/25 103/22 103/23 122/20
signing [1] 42/7
silence [1] 129/1
Silverman [1] 2/22
similar [1] 94/12
similarities [1] 136/8
simplest [1] 134/5
simply [1] 130/20
since [6] 78/20 81/19 87/8
107/17 111/7 113/2
single [3] 73/22 75/8 107/3
single-page [1] 75/8
sir [126]
sister [2] 55/8 55/16
sit [1] 144/12
site [3] 33/22 35/23 41/1
sitting [1] 43/2
six [4] 1/15 80/20 95/4
115/13
Sixteen [1] 79/11
sleeping [4] 35/17 35/19
107/24 118/20
slow [3] 60/10 60/14 70/18
slowly [1] 60/13
small [6] 7/12 97/7 97/14
97/15 108/23 114/17
so [132]
Social [2] 24/22 44/14
sole [5] 32/16 34/7 83/7
112/9 123/3
some [54] 6/24 17/24 25/2
25/4 25/8 33/15 34/16 34/17
35/7 36/20 40/5 40/15 40/19
40/23 43/19 44/25 46/4 47/6
48/12 48/21 55/1 55/21 58/13
72/3 72/8 72/14 81/12 83/4
88/22 90/18 92/5 92/12 92/20
92/21 93/12 94/9 94/15
104/23 105/17 107/7 107/10
111/24 113/20 114/8 126/9
129/13 133/13 135/23 139/10
140/1 140/1 140/6 142/6
145/1
somebody [5] 28/18 30/6 30/7
42/12 65/17
somebody's [1] 44/16
someone [10] 11/15 41/18
41/19 62/17 64/21 137/5
141/12 141/15 144/25 145/11
something [10] 49/3 61/6
75/16 79/3 86/15 109/19
113/4 117/12 140/3 145/13
sometimes [3] 46/13 82/4
89/3
somewhat [1] 126/9
somewhere [1] 87/1
soon [1] 86/14
sorry [11] 20/15 23/12 26/8
28/7 56/22 60/10 66/10 75/19
80/7 91/25 93/4
sounded [1] 27/21
sounds [1] 142/13
source [2] 25/5 47/9
span [1] 74/13
speak [3] 31/19 71/22 148/20
speaking [3] 52/15 52/21
60/12
Spear [1] 2/20
Special [10] 6/6 32/3 32/7
46/22 53/19 58/7 59/8 67/21
68/3 68/20
specific [3] 26/20 135/1
138/16
specifically [18] 10/22 13/1
14/1 14/8 14/10 17/3 18/6
28/8 28/14 30/25 33/1 42/5
42/7 52/21 53/3 63/2 63/13
130/22
specificity [1] 9/21
specifics [2] 25/6 25/8
specified [1] 53/1
specifies [1] 8/20
speculating [2] 14/4 14/6
speculation [2] 9/9 56/10
speed [2] 20/24 83/19
spell [1] 77/23
spelled [1] 20/2
spent [1] 111/8
spill [1] 80/21
spoke [3] 27/22 28/9 64/21
spreadsheet [2] 11/18 11/20
Spring [1] 2/6
stamp [1] 10/13
stamps [1] 10/17
stand [2] 5/13 106/18
standing [2] 72/10 91/22
standpoint [1] 127/5
star [2] 104/15 115/13
start [11] 16/17 62/23 62/24
73/24 82/5 82/7 112/10
131/24 149/2 149/3 149/3
started [6] 79/21 79/22
81/16 82/11 142/15 148/23
starting [1] 19/17
state [13] 7/8 7/9 8/21 9/1
9/8 9/19 27/12 27/13 37/2
39/4 39/14 77/23 119/3
stated [1] 124/17
statement [13] 16/15 16/17
16/20 17/3 62/23 64/1 64/2
64/7 114/17 114/19 120/16
145/5 145/12
STATES [8] 1/1 1/4 1/6 2/3
134/18 135/2 150/5 150/9
stay [1] 124/25
steal [1] 115/20
stenographically [1] 150/6
STEPHEN [1] 1/3
steps [3] 25/2 25/4 47/7
Steptoe [4] 2/14 2/17 2/19
2/22
still [8] 5/13 6/11 18/5
21/16 81/22 99/25 119/5
145/5
store [6] 27/20 28/2 28/9
28/11 28/15 28/24
straight [1] 75/5
Street [7] 1/22 2/6 2/14
2/20 3/8 31/21 78/15
stricken [1] 6/8
strike [2] 50/5 56/10
string [1] 13/12
structurally [1] 129/12
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stuck [1] 83/18
student [2] 134/17 145/1
stuff [8] 85/12 102/13
104/20 105/5 105/24 110/22
113/1 121/5
subgroup [3] 147/22 147/23
148/3
submission [1] 139/20
submit [4] 45/8 57/5 74/17
108/25
submitted [12] 23/14 25/16
25/22 38/24 49/6 109/9
109/13 110/2 115/9 136/10
137/10 139/20
submitting [2] 49/14 136/2
subpoena [4] 11/13 40/12
48/2 48/5
subpoenas [2] 47/18 48/22
subscribed [1] 49/4
subscriber [5] 32/25 48/18
48/20 77/3 77/5
Subsequent [2] 33/17 34/1
subset [1] 11/15
substance [2] 61/4 61/5
substantial [1] 111/13
successful [1] 9/12
succinct [1] 134/5
such [3] 77/16 126/23 142/6
sufficient [1] 10/7
sufficiently [1] 146/23
suggested [2] 33/3 53/18
suggesting [2] 32/23 135/10
Suite [9] 1/22 2/15 2/20 3/5
3/8 3/13 3/16 3/21 7/14
summaries [4] 75/2 75/2 75/3
75/16
summarize [6] 71/12 71/15
71/16 71/19 79/14 79/19
summary [24] 70/3 70/8 70/14
71/5 71/8 72/22 73/2 74/20
75/3 75/18 75/18 75/20 75/22
76/10 125/22 125/24 126/3
126/4 126/8 126/10 132/14
135/16 137/9 137/15
SUN [1] 2/5
Supermarkets [1] 80/1
superseding [1] 47/4
supported [1] 126/4
suppose [2] 44/20 46/16
supposed [1] 136/19
sure [12] 24/9 24/15 37/3
66/8 67/3 82/15 111/23
130/15 132/20 140/14 140/18
140/20
surveillance [9] 54/18 54/20
54/21 54/25 55/1 55/2 55/3
55/5 55/13
suspect [1] 148/20
suspended [1] 35/4
suspicions [2] 135/5 135/7
sustained [14] 7/21 9/16
17/7 17/9 17/21 21/23 22/11
33/23 34/20 34/25 36/19 39/2
56/23 67/9
SVW [1] 1/8
swipe [1] 27/24
sworn [1] 77/22
synthetic [18] 15/13 15/22
16/11 17/25 19/9 34/13 43/16
44/8 44/9 44/10 44/19 49/15
49/19 53/22 104/24 134/12
136/19 144/20
T
T-A-T-I-O-A-N [1] 20/2
tab [1] 91/12
table [1] 43/2
tad [1] 60/11
take [36] 6/18 6/20 10/10
11/9 12/25 14/7 15/25 18/24
19/13 20/13 24/17 25/10
25/24 26/4 26/25 28/4 29/1
29/12 29/18 30/12 50/24 68/9
69/10 69/12 69/21 70/2 77/8
89/1 92/22 102/19 108/11
108/14 119/10 131/6 131/21
138/14
taken [4] 22/15 22/16 75/5
75/5
taking [2] 25/13 43/18
talk [4] 10/4 43/4 47/13
113/5
talked [1] 111/16
talking [9] 39/23 63/10
63/21 106/16 110/21 129/23
130/2 131/1 131/8
talks [1] 144/10
Tamara [34] 15/7 17/23 19/5
19/8 20/8 32/16 32/18 35/2
35/21 36/2 36/5 36/12 43/5
43/14 44/5 45/17 45/22 79/8
79/9 88/9 93/1 93/5 95/6
118/10 129/5 129/14 129/16
129/18 131/1 132/7 133/23
136/24 139/20 140/14
Tammy [15] 13/13 14/10 18/10
18/19 19/21 19/21 108/1
108/9 109/6 111/19 115/8
117/8 127/25 131/8 140/17
Tammy's [20] 90/20 92/11
92/19 93/18 94/2 94/12 96/18
97/3 97/23 98/14 99/1 99/8
99/15 99/24 100/9 100/18
100/24 101/7 101/14 101/23
tap [2] 117/9 117/15
Tatioan [3] 20/1 20/7 128/3
tax [12] 36/5 36/25 40/20
41/6 61/24 62/1 62/2 62/3
62/4 112/7 139/22 140/12
tax-related [1] 36/25
taxes [7] 36/24 37/2 37/5
88/8 103/12 119/25 135/23
taxings [1] 119/19
team [4] 9/25 13/24 32/9
43/3
tear [1] 86/25
tease [1] 131/15
telephone [5] 48/2 48/5 48/6
48/8 48/11
tell [21] 28/14 32/8 37/20
44/18 49/10 50/25 65/15
68/12 71/10 74/1 80/11 81/15
83/6 85/7 89/11 101/13
106/18 111/24 127/13 127/13
132/3
telling [3] 51/25 97/6
140/18
temporarily [1] 134/18
TERABELIAN [11] 3/3 6/8 50/2
50/15 51/15 55/8 55/13 60/23
130/12 130/18 134/1
Terabelian's [4] 55/25
138/19 139/23 146/3
term [3] 12/7 12/8 22/12
terminal [1] 27/25
terms [1] 76/11
test [1] 84/17
testified [18] 6/6 29/2
33/22 35/23 60/17 62/14 66/1
66/11 118/7 118/19 119/12
119/18 121/2 121/6 121/23
123/15 134/8 134/21
testifies [1] 6/1
testify [1] 125/18
testifying [1] 134/21
testimony [10] 6/5 6/8 12/25
28/1 56/21 66/5 119/6 125/8
125/21 128/1
testing [2] 38/25 85/5
text [16] 13/12 18/8 19/17
19/25 21/10 40/24 57/24
123/7 123/11 128/4 128/5
130/25 136/23 140/13 140/25
141/2
texted [4] 18/20 21/20 21/25
22/1
texting [1] 140/17
than [9] 31/3 59/14 62/19
76/8 109/23 110/2 126/10
129/14 146/10
Thanh [3] 80/12 123/15
123/18
Thank [21] 5/9 13/9 18/4
43/4 58/5 60/11 62/7 65/23
72/14 77/20 78/4 113/8
117/25 118/19 123/4 124/16
125/9 125/10 127/9 144/3
144/13
that [702]
that's [7] 70/22 93/19 102/8
118/12 119/2 123/1 124/10
theft [7] 43/22 44/1 44/5
115/18 116/3 147/11 147/16
their [10] 45/8 67/5 69/2
74/22 83/21 86/3 107/12
107/16 110/8 143/24
them [26] 30/7 37/3 46/4
51/23 58/1 76/8 82/19 83/20
83/23 84/19 85/21 85/22
85/22 85/23 85/24 95/5
105/11 112/4 115/7 115/8
115/9 115/9 124/25 126/3
141/1 148/21
then [32] 9/10 14/23 27/13
41/19 44/14 48/20 50/10
52/10 57/16 61/9 69/22 70/19
73/22 74/4 75/11 76/5 79/17
80/21 83/23 88/20 96/12
107/17 109/19 110/5 112/5
127/13 134/11 134/25 138/5
138/6 139/25 145/2
theory [2] 130/10 130/11
there [143]
these [50] 24/19 43/22 44/9
44/18 44/22 45/1 45/7 45/7
45/16 46/7 46/10 49/14 64/8
74/24 76/9 76/25 77/4 83/22
85/21 89/1 92/23 94/17 95/1
95/4 95/7 95/10 95/12 95/15
95/20 95/22 108/3 111/21
112/15 112/18 112/20 113/20
114/11 116/25 130/22 133/10
133/23 135/23 136/2 136/11
136/15 136/22 137/8 140/1
143/10 144/22
they [59] 5/20 5/22 18/14
35/19 36/3 36/15 43/16 44/24
45/24 45/25 46/11 49/15
51/19 52/16 58/10 61/1 70/16
71/9 72/16 74/17 74/19 76/12
76/23 82/22 83/18 83/20
83/21 84/10 84/17 84/19
84/23 84/25 85/1 85/4 85/8
85/19 86/3 86/3 94/19 94/19
98/17 107/5 107/6 109/16
109/20 110/9 110/21 124/20
125/6 127/4 127/5 131/12
133/24 136/3 141/8 141/10
143/25 144/25 145/7
THIBODEAUX [2] 1/21 150/12
thing [4] 9/21 59/20 85/8
145/19
things [12] 47/12 75/8 84/20
85/2 88/22 89/1 89/4 114/12
126/8 134/21 142/7 146/11
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think [32] 6/2 15/2 29/23
32/18 35/3 35/7 63/1 67/13
72/24 73/1 97/14 99/25
105/22 108/10 111/20 112/23
114/5 114/8 114/21 114/24
127/14 132/8 134/12 135/11
136/12 139/11 143/1 143/5
144/19 145/4 145/24 148/19
thinking [1] 133/15
third [8] 52/19 79/17 128/11
129/9 129/10 129/12 129/16
134/11
this [187]
Thomas [1] 3/14
those [46] 7/2 11/15 19/1
19/1 34/2 34/9 40/1 40/24
41/5 42/18 42/19 42/21 45/4
45/20 45/23 46/1 48/11 51/11
51/17 56/5 57/20 72/4 72/8
74/4 76/5 76/16 81/9 95/17
104/17 104/19 104/21 105/2
105/10 107/12 110/13 112/3
115/5 115/11 120/11 126/11
127/21 128/2 128/14 133/11
138/8 148/2
though [5] 8/12 15/10 34/16
64/19 106/25
thought [4] 27/23 28/17
32/19 97/6
thousand [1] 86/15
thousands [1] 126/1
three [5] 63/2 76/14 82/16
83/23 135/20
through [25] 21/10 26/15
26/17 30/13 30/18 61/10
67/12 69/3 76/9 79/16 83/4
84/1 85/4 85/10 86/9 97/9
104/4 104/6 105/4 105/16
133/1 133/2 133/24 136/23
147/16
throughout [4] 74/25 89/15
111/18 113/2
tie [1] 77/7
Tim [1] 14/3
time [44] 17/6 17/8 19/1
22/15 24/12 26/23 35/15
40/13 45/13 46/8 58/4 59/23
61/1 62/25 64/9 69/10 72/6
72/11 72/16 79/2 80/25 82/3
82/9 82/17 86/18 87/19 87/19
88/16 102/6 102/7 105/13
106/13 108/7 110/16 110/21
112/1 114/8 116/6 123/19
125/11 130/21 134/19 146/7
148/24
timeframe [1] 135/22
Timeline [1] 49/22
Timepieces [5] 51/18 51/19
52/16 52/22 54/5
times [12] 29/6 53/11 88/2
96/6 102/17 102/22 105/15
105/18 126/18 139/11 140/24
147/13
timing [1] 130/23
tires [1] 111/10
title [2] 75/21 150/4
today [5] 86/7 128/1 148/18
149/2 149/3
together [1] 103/12
told [13] 44/23 62/17 65/13
97/11 107/13 107/17 108/9
109/1 109/4 109/5 110/15
111/19 111/23
Tom [1] 31/19
tomorrow [5] 14/11 143/17
148/19 149/2 149/3
too [3] 14/12 43/24 60/12
took [6] 47/7 58/16 60/7
60/20 106/23 122/7
top [8] 7/6 46/3 63/3 77/3
85/10 96/10 97/24 117/10
Topeka [3] 20/19 50/1 51/14
towards [6] 92/12 93/1 93/4
111/8 111/10 111/21
Tower [1] 2/20
towing [18] 34/14 36/21
36/25 37/6 37/7 37/15 37/23
38/3 39/4 39/14 82/14 82/16
83/3 103/25 108/5 120/16
124/8 145/6
track [1] 51/7
trailer [1] 85/20
trailers [2] 85/2 106/8
Tran [3] 80/12 123/15 123/18
transaction [23] 17/4 26/20
27/7 27/14 28/1 28/24 52/7
60/4 60/6 60/9 60/18 60/20
62/18 63/3 63/6 63/21 64/11
64/15 64/16 64/19 65/12
65/17 68/9
transactions [6] 19/7 20/8
53/22 64/13 71/14 71/19
transcript [3] 1/13 150/6
150/7
transfer [6] 49/23 49/25
53/2 140/15 141/25 141/25
transferred [3] 139/22
140/11 142/24
transmission [1] 83/19
transport [14] 34/15 36/21
37/1 37/6 37/7 37/16 37/24
38/3 39/5 39/14 49/22 83/3
120/16 124/8
Transportation [1] 82/24
trash [1] 47/12
trial [9] 1/15 24/4 24/7
104/22 126/1 130/19 139/16
140/1 143/3
tried [1] 112/24
triples [1] 85/2
trouble [1] 84/14
truck [19] 37/11 37/13 37/15
37/23 37/24 38/1 38/21 38/24
81/19 81/20 81/22 82/18
85/20 87/22 88/1 88/13 89/13
106/2 106/5
trucker [2] 106/2 106/5
trucking [14] 38/18 80/1
81/12 81/16 81/17 81/19 82/5
82/17 88/9 89/8 103/25 108/5
111/9 119/17
trucks [7] 82/12 82/16 82/19
82/21 83/2 83/13 85/21
true [11] 32/15 33/16 34/22
58/25 59/1 59/1 66/24 131/9
139/17 143/18 150/5
Trump [3] 110/16 110/22
110/25
trust [1] 32/19
truth [5] 144/24 145/3 145/4
145/10 145/11
truths [5] 144/11 144/15
144/17 144/18 145/17
try [10] 21/24 45/6 45/6
46/14 84/17 86/1 97/13
109/11 110/8 145/21
trying [5] 9/11 49/14 69/2
75/23 145/13
Turks [2] 26/3 60/24
turn [2] 76/8 133/16
turned [1] 56/8
TV [3] 108/9 110/16 110/21
Twelfth [1] 2/6
twice [1] 121/8
two [37] 19/1 46/3 57/20
60/22 73/20 74/11 75/8 75/13
76/14 76/19 79/12 79/13
79/23 83/22 85/10 107/4
109/21 122/8 127/3 127/10
127/11 127/21 128/9 128/14
129/17 131/2 131/3 131/10
131/10 134/10 136/7 142/19
143/4 146/4 146/15 147/16
149/6
two-and-a-half [1] 60/22
type [5] 8/4 9/17 53/24
53/24 85/4
U
U.S [3] 1/21 2/4 2/4
Uh [2] 117/16 123/14
Uh-huh [2] 117/16 123/14
ultimately [5] 126/4 133/11
133/14 138/9 142/24
unable [2] 32/20 51/20
unclear [1] 97/4
uncover [1] 31/2
under [4] 6/12 77/3 122/18
123/24
underlying [7] 22/14 72/1
72/2 72/4 72/8 72/15 72/18
understand [5] 15/17 16/10
18/12 22/12 146/17
understanding [11] 8/25 12/4
13/18 22/19 23/14 34/3 44/10
72/23 142/21 144/11 144/14
understood [2] 70/11 136/25
unfairly [1] 126/5
UNITED [8] 1/1 1/4 1/6 2/3
134/18 135/2 150/5 150/9
universal [1] 11/12
unless [3] 26/17 105/16
146/16
unnecessary [1] 61/7
unremarkable [2] 143/18
143/20
unsure [2] 8/18 8/19
until [11] 10/5 25/3 58/13
70/21 105/3 109/24 115/11
116/2 140/11 148/19 149/1
up [56] 6/18 7/12 9/3 9/4
9/22 11/8 13/1 13/2 13/5
14/9 16/2 18/8 19/17 20/24
20/25 25/10 26/10 26/25 27/3
27/6 29/23 58/16 61/9 61/16
62/22 63/1 63/3 63/24 64/15
64/21 65/8 65/16 65/18 67/25
69/10 70/2 72/10 73/6 74/24
79/17 80/5 84/20 89/25
102/10 105/21 106/8 106/14
110/10 112/13 112/17 116/23
119/8 120/5 132/15 141/11
143/14
upfront [1] 109/19
uploaded [1] 21/9
upon [1] 141/2
upper [4] 45/21 91/13 92/5
94/21
URL [1] 8/19
us [17] 2/9 19/22 44/9 44/18
44/23 49/5 49/10 65/13 65/15
67/22 70/16 73/10 80/21
80/25 112/4 114/2 141/7
use [14] 87/18 87/21 89/19
102/22 102/24 103/25 106/3
106/4 106/6 115/22 120/5
132/20 141/11 148/10
used [17] 50/1 51/12 73/1
73/3 74/16 74/17 74/19 76/1
89/25 104/14 121/23 133/22
137/7 137/12 138/18 138/18
148/10
user [2] 21/2 23/5
using [4] 41/19 44/12 50/17
144/25
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usually [2] 87/23 88/1
utilities [1] 138/20
utilizing [1] 44/16
V
Vague [5] 15/15 22/9 23/18
34/19 39/6
VAHE [13] 3/18 39/21 40/2
40/7 40/9 118/13 125/17
138/25 139/19 140/15 140/19
140/21 145/7
value [1] 131/6
variety [1] 47/12
various [6] 34/3 44/12 83/18
104/11 106/6 135/19
Vaughan [1] 3/7
Vehicles [1] 38/13
ven [1] 11/24
Venmo [8] 11/13 11/23 11/25
12/1 12/3 12/7 73/5 75/6
Ventura [1] 7/14
venture [2] 89/14 142/18
ventures [3] 66/24 67/6
131/13
versus [1] 141/7
very [13] 34/17 62/8 62/10
66/13 67/14 72/24 79/14
86/18 88/14 107/22 112/4
119/15 145/21
victims [3] 43/22 46/7 46/11
Victoria [4] 41/9 41/20
48/20 130/5
video [3] 42/2 42/6 42/8
view [5] 46/1 132/3 139/3
141/14 148/25
visit [1] 40/25
visits [1] 117/7
voice [1] 80/5
voided [1] 108/16
VOLUME [1] 1/16
voluminous [2] 71/12 74/14
Vostanikyan [1] 113/16
Voyage [4] 40/7 139/14
139/21 142/4
VPNs [1] 48/21
W
wait [2] 142/21 148/18
waiting [1] 149/1
walked [2] 42/13 70/9
wall [1] 104/11
walls [2] 104/17 104/19
Wang [1] 88/6
want [16] 6/18 13/8 16/14
30/1 67/23 82/15 88/13
103/19 104/4 105/17 107/1
111/25 119/18 126/20 127/7
143/16
wanted [9] 11/8 33/9 33/10
33/11 39/22 92/22 109/23
110/8 112/8
wanting [1] 124/12
warehouse [1] 106/8
warmed [1] 141/11
warrant [6] 29/15 30/4 30/6
30/11 32/10 136/22
warrants [2] 47/11 57/23
was [239]
wash [1] 79/24
Washington [2] 2/10 2/23
wasn't [6] 28/11 40/12 50/22
119/3 128/6 139/16
wasting [2] 18/25 69/10
way [15] 28/21 49/8 73/24
76/21 76/23 76/24 79/17
107/12 132/5 132/9 134/5
143/25 144/14 144/16 149/7
ways [3] 126/9 131/3 131/3
we [177]
wear [1] 86/25
web [1] 9/7
website [6] 7/23 8/5 8/13
9/3 9/23 40/23
Weddington [4] 31/20 43/5
61/17 78/15
WEDNESDAY [2] 1/17 5/1
week [3] 52/7 109/20 129/24
week-and-a-half [1] 129/24
weeks [3] 107/4 119/24 122/8
weight [1] 44/16
well [41] 8/8 10/9 10/17
15/12 23/5 35/24 36/10 42/15
46/12 47/15 47/20 48/1 49/2
50/23 54/22 55/6 57/9 57/24
61/16 63/22 64/1 64/20 69/17
70/24 71/20 85/25 86/13
97/11 99/25 106/13 109/13
111/2 111/7 126/15 133/6
133/21 134/6 135/13 136/23
143/14 149/8
Wells [1] 14/11
went [22] 35/14 35/18 40/11
51/16 53/14 79/16 80/13
80/15 81/16 82/19 83/7 86/14
86/20 105/4 107/9 107/11
110/5 133/11 138/1 139/21
139/23 141/25
were [117]
weren't [3] 83/20 83/21
86/17
West [3] 1/22 2/14 3/8
WESTERN [1] 1/2
what [165]
whatever [7] 14/25 18/20
58/2 104/24 109/16 126/25
140/24
wheel [1] 84/19
wheeler [1] 82/17
when [56] 13/2 13/5 19/17
21/24 25/10 28/13 32/15 34/2
35/14 35/17 42/16 42/21
42/25 43/18 46/24 51/23 53/1
56/1 61/16 63/5 63/17 63/25
70/23 70/25 71/1 71/2 76/25
79/16 79/21 80/22 82/17
84/17 86/20 102/18 102/19
103/21 104/14 105/18 106/7
106/20 107/13 108/7 110/10
110/11 111/12 111/13 111/17
112/23 113/3 124/20 128/25
134/8 134/20 138/11 141/24
145/11
where [33] 8/20 22/16 22/23
23/11 23/17 23/19 27/3 27/10
27/15 61/13 64/15 68/10
74/15 74/18 75/18 76/12
78/12 87/11 105/15 106/13
107/23 118/17 130/11 136/6
137/8 137/21 138/1 138/12
138/19 141/1 141/16 144/15
144/18
whereabouts [2] 105/3 115/10
whether [25] 9/22 17/22
26/22 27/14 35/9 35/20 36/4
36/15 37/10 38/2 38/6 38/11
38/23 46/6 46/10 51/4 56/13
57/4 58/21 59/13 60/6 62/3
66/22 74/17 147/10
which [45] 16/20 17/2 18/24
20/14 20/18 20/25 21/12 32/2
55/23 62/18 62/22 64/16
64/17 65/12 71/13 72/18 74/6
76/15 77/5 85/9 85/20 91/9
97/5 98/6 98/18 99/2 99/9
100/10 100/25 101/15 108/17
120/15 123/11 123/23 126/23
127/25 131/4 132/14 133/16
135/15 139/21 139/22 142/1
143/3 145/14
while [2] 89/25 140/11
who [60] 11/19 13/23 16/20
21/14 21/17 25/1 31/11 32/5
32/12 36/24 40/15 41/24 42/3
42/9 45/3 45/3 45/6 45/7
49/4 49/5 49/14 51/20 54/3
72/10 72/10 77/7 79/7 82/25
83/16 84/10 88/5 88/12 92/18
93/7 94/24 105/6 109/5 109/7
109/9 115/7 117/2 124/12
127/17 128/6 128/18 129/21
129/24 130/1 130/8 130/25
130/25 134/11 134/15 134/16
135/3 137/5 140/1 140/16
141/17 145/1
whole [2] 59/20 59/20
whom [1] 140/16
whose [27] 55/10 90/18 91/3
91/15 92/10 93/17 94/1 96/17
97/2 97/22 98/13 98/25 99/7
99/14 99/21 99/23 100/8
100/15 100/17 100/23 101/4
101/6 101/13 101/20 101/22
103/16 104/3
why [24] 15/25 16/4 24/22
30/23 41/12 44/8 45/12 45/14
48/25 53/7 59/18 59/19 61/4
61/6 62/23 64/5 65/2 70/12
82/23 103/18 106/12 143/22
146/11 146/17
wife [27] 40/13 40/17 79/2
87/6 87/11 88/9 88/15 92/19
96/18 97/3 97/23 98/14 99/1
99/8 99/15 99/24 100/9 102/1
105/7 107/18 109/6 115/8
117/3 117/17 117/24 119/6
119/12
wife's [6] 90/8 95/6 117/3
117/18 117/19 117/21
will [35] 10/12 17/3 18/6
18/17 19/14 24/6 52/10 57/19
58/5 58/18 59/22 60/2 61/9
69/10 69/15 69/22 71/24
77/16 77/17 77/21 102/19
108/10 116/14 116/23 117/5
120/6 125/17 125/19 125/20
127/24 131/15 132/14 138/17
143/4 148/20
Williams [2] 3/4 3/7
WILSON [1] 1/3
wire [8] 49/23 49/25 53/2
114/24 140/18 140/21 140/24
141/1
wires [1] 51/20
Wirsching [1] 3/12
withdrawal [1] 122/6
withdrawals [1] 27/4
within [3] 75/2 75/3 75/15
without [3] 43/24 69/10
76/21
witness [40] 4/3 6/1 6/10
6/11 8/9 10/11 11/9 25/9
28/6 29/2 31/12 33/21 35/22
37/20 37/21 50/12 51/9 52/12
53/9 57/9 59/17 59/20 59/24
61/11 67/13 67/14 67/23 69/3
69/6 69/6 69/9 69/11 69/22
77/13 77/17 77/19 77/22
89/22 116/15 125/23
witness's [1] 6/19
witnesses [5] 54/12 54/15
54/17 57/24 147/17
wonderful [1] 79/13
word [3] 66/7 75/3 142/9
words [6] 51/2 52/1 127/1
129/11 145/13 146/12
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work [7] 46/13 46/14 79/19
82/1 86/18 88/18 140/25
working [12] 47/11 57/5
57/25 79/20 79/21 82/11
85/18 86/17 106/14 106/16
112/10 144/6
works [3] 60/13 87/12 117/24
world [1] 85/25
worry [1] 105/20
would [59] 5/14 9/7 9/18
22/23 22/25 23/3 23/8 23/21
24/10 25/4 28/18 28/19 31/11
32/3 35/16 40/5 40/19 41/16
41/17 42/12 43/4 43/18 43/22
46/14 48/24 49/5 50/12 52/7
58/7 68/1 70/18 71/5 72/5
77/7 89/22 92/22 99/3 101/24
114/10 116/22 125/5 126/5
128/21 128/22 129/4 129/17
130/6 132/5 135/13 136/4
136/8 136/15 138/12 138/13
141/18 141/22 145/15 147/3
148/21
wrap [1] 61/9
writing [5] 91/16 92/11
93/13 98/2 98/3
wrong [4] 107/10 112/23
113/4 114/12
wrongdoing [1] 106/1
www.Runyantax.com [1] 40/24
Y
yeah [12] 8/11 13/16 16/8
23/24 24/3 26/7 45/25 86/25
103/21 103/24 110/12 112/12
year [3] 47/3 82/5 104/15
years [15] 21/21 78/11 79/11
79/21 79/22 80/13 85/11
87/10 90/9 111/18 111/21
113/3 145/2 146/4 146/15
yes [346]
yesterday [10] 6/5 18/20
29/3 56/13 58/16 59/9 69/7
70/3 70/11 70/13
yet [5] 28/5 67/25 120/5
131/19 132/17
York [2] 2/10 2/18
you [763]
you review [1] 29/9
your [293]
yours [3] 91/17 94/3 94/13
yourself [2] 32/12 81/20
Z
Zahva [1] 117/8
Zhadko [17] 26/12 27/8 49/18
50/16 50/17 51/22 52/24
52/25 55/11 63/10 130/12
130/16 133/3 133/23 138/5
138/7 138/18
Zhakdo [1] 55/12
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#:10729File and source
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- gov.uscourts.cacd.802533.676.0.pdf
- Size
- 525,967 bytes
- SHA-256
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