Court filing
TRANSCRIPT filed as to Defendant Richard Ayvazyan, Marietta Terabelian, Artur… — USA v. Ayvazyan et al (Dkt. 677)
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. 677 · 2021-07-09 · Docket on CourtListener
Summary
A reporter's transcript of Jury Trial - Day Seven, 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 Thursday, June 24, 2021 at 9:00 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. 677. Counsel are listed for the Government and for each of the four named defendants. The index shows no witnesses and no exhibits for this session and gives the pages at which two closing arguments begin. The opening records the court taking up, outside the presence of the jury, the redaction of Exhibit 50 after the final instructions had been provided. The transcript is 133 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
1
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 SEVEN
VOLUME 1 - A.M. SESSION
THURSDAY, JUNE 24, 2021
_____________________________________
KATIE E. THIBODEAUX, CSR 9858
U.S. Official Court Reporter
Suite 4311
350 West 1st Street
Los Angeles, CA 90012
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 2:20-cr-00579-SVW Document 677 Filed 07/09/21 Page 1 of 133 Page ID
#:10730
2
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
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 2:20-cr-00579-SVW Document 677 Filed 07/09/21 Page 2 of 133 Page ID
#:10731
3
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
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 2:20-cr-00579-SVW Document 677 Filed 07/09/21 Page 3 of 133 Page ID
#:10732
4
I N D E X
WITNESS NAME PAGE
(None.)
EXHIBIT I.D. IN EVID.
(None.)
CLOSING ARGUMENTS PAGE
BY MR. FENTON 34
BY MR. LITTRELL 87
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 2:20-cr-00579-SVW Document 677 Filed 07/09/21 Page 4 of 133 Page ID
#:10733
5
LOS ANGELES, CALIFORNIA; THURSDAY, JUNE 24, 2021
9:00 A.M.
- - - - -
(The following proceedings were held outside the
presence of the jury:)
THE COURT: We are here with the parties and
counsel. I have given you the final instructions. Just
quickly, the government has not redacted the Exhibit 50,
as I instructed, in the transcription side, and then
there is the translation side.
In the transcription, there still is a
reference to a lawyer. If you notice at the bottom of
the page on the left side, that should not be.
MR. PAETTY: Your Honor, the correct transcript
is -- they are Exhibits 50B and 50E. The government last
night e-mailed a copy of 50B and 50E to Mr. Cruz, and
those are the correct redactions.
THE COURT: And it doesn't include this lawyer
reference.
MR. PAETTY: That's correct, your Honor. I can
provide the Court with a copy of that.
THE COURT: I will take your word for it, but make
sure it doesn't.
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 2:20-cr-00579-SVW Document 677 Filed 07/09/21 Page 5 of 133 Page ID
#:10734
6
MR. PAETTY: Yes, your Honor.
THE COURT: And otherwise, I think we are ready.
What time is it now?
THE CLERK: It is practically 9:00 o'clock, your
Honor.
MS. AHN: Your Honor?
THE COURT: Yes.
MS. AHN: It appears that the Court maintained in
the second element on page 35 court instruction No. 28
for money laundering, 1956, that the defendant knew the
property represented the proceeds of one of those three
crimes.
That is, again, inconsistent with the statute
and the model instruction, your Honor.
If the government -- if the Court looks at 18,
U.S.C. 1956 A1, A1 specifies whoever knowing that the
property involved, a financial transaction represents the
proceeds of some form of unlawful activity.
THE COURT: What unlawful activity did it
represent other than those three crimes?
MS. AHN: Well, the statute continues in Section
C1. And the statute says:
"The term 'knowing that the property involved in a
financial transaction' represents the proceeds of
some form of unlawful activity means that the
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 2:20-cr-00579-SVW Document 677 Filed 07/09/21 Page 6 of 133 Page ID
#:10735
7
person knew the property involved in the
transaction represented proceeds from some form,
though not necessarily which form, of activity
that constitutes a felony under state federal or
foreign law."
THE COURT: I see. All right.
MS. AHN: So we would recommend that the Court use
the model instruction.
THE COURT: I will edit that quickly.
MS. AHN: Yes, your Honor. And one note --
THE COURT: Let's get through this. We have spent
hours and hours on these things.
MS. AHN: Yes, your Honor.
THE COURT: We have gone through drafts and
drafts. What else?
MS. AHN: Yes, your Honor. The Court, regarding
government Exhibits 117, 118, 119 and 120, which were the
physical exhibits containing the subset Cellebrite
report, Counsel John Littrell yesterday made the very
reasonable and I think sensible suggestion that the
parties agree that since those exhibits were used for
foundational purposes for the government exhibits that
were submitted through Special Agent Massino that the
parties agree that those physical exhibits not go back
given all the relevant information from the trial that is
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 2:20-cr-00579-SVW Document 677 Filed 07/09/21 Page 7 of 133 Page ID
#:10736
8
already introduced.
THE COURT: Okay. I will agree to that.
MR. LITTRELL: Yes, your Honor. Just to be clear,
I preserve all objections to --
THE COURT: Well, yes. Of course.
MR. LITTRELL: Also on that jury instruction
issue, I just want to preserve another objection that if
the jury instruction is changed along the lines of what
the government suggests, I think it could permit a
constructive amendment of the indictment, because the
jury could convict him of crimes that the grand jury was
never presented with.
THE COURT: I see. All right.
MR. JOHNSON: I join that argument. Also, your
Honor, I appreciate the edits on the aiding and abetting,
but the instruction said you should not apply this
instruction to any other counts? It should say you must
not apply this instruction to any other counts, because
it if they do, that would cause a problem. You can't
apply that to the conspiracy counts. You just cannot.
THE COURT: In other words, you think "should"
should be "must."
MR. JOHNSON: Yes, your Honor.
THE COURT: Okay.
MR. RAM: Your Honor, I join the defense's
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 2:20-cr-00579-SVW Document 677 Filed 07/09/21 Page 8 of 133 Page ID
#:10737
9
objections.
MR. LITTRELL: Join.
MR. RAM: Just point out it has to be connected to
PPP and EIDL loans. It is not about the law. Otherwise
it's a constructive --
THE COURT: What are you referencing?
MR. RAM: The money laundering counts.
THE COURT: 35, page 35?
MR. RAM: It is in a couple of places.
Thirty-five, and then on 37 it says the defendant knew
that the transaction involved property representing the
proceeds of unlawful activity. It should say "related to
PPP or the EIDL loans." Otherwise it is not clear that
it is about this case.
MS. AHN: Your Honor, as we discussed yesterday,
that factual matter is contained in a different element.
It is contained in -- for page 35, it is contained in the
first element, and for page 37, it is contained in the
fourth element. Defendant's request would essentially
merge those elements together in a way that is
inconsistent with the explicit language of the statute.
(Court and clerk confer.)
THE COURT: Okay. When we get the jury, we will
move forward.
MR. RAM: One last point, your Honor.
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 2:20-cr-00579-SVW Document 677 Filed 07/09/21 Page 9 of 133 Page ID
#:10738
10
THE COURT: Yes.
MR. RAM: The one overall language instead of
"and." So the conspiracy instruction.
THE COURT: You said that yesterday and I have not
included it.
(Pause in proceedings.)
THE COURT: With your charts, Mr. Mesereau. This
chart, this one here, I am going to strike that, and not
allow that one.
MR. MESEREAU: Yes, your Honor.
THE COURT: This one, I will allow it with one
condition, that you relate it to "firmly convinced," or
language in the instruction.
In other words, if you use this to show that
you can't be firmly convinced, it has some sort of
demonstrative or helps your argument. You can do that,
but make sure do you this in relation to why you can't be
firmly convinced.
MR. MESEREAU: Yes, your Honor.
THE COURT: You could suspect perhaps, may not be,
possibly not, you know, whatever you want it to, but
anchor it to the instruction.
MR. MESEREAU: Yes, sir. Thank you.
(Recess from 9:05 a.m. to 9:18 a.m.)
(The following proceedings were held in the
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 2:20-cr-00579-SVW Document 677 Filed 07/09/21 Page 10 of 133 Page ID
#:10739
11
presence of the jury:)
THE COURT: Members of the jury, now that you have
heard all the evidence it is my duty to instruct on the
law that applies to this case. A copy of these
instructions will be available in the jury room for you
to consult.
It is your duty to weigh and evaluate all the
evidence received in the case and in that process to
decide the facts. It is also your duty to apply the law
as I give it to you to the facts as you find them,
whether you agree with the law or not.
You must decide the case solely on the
evidence and the law. You should not be influenced by
any person's race, color, religious beliefs, national
ancestry, sexual orientation, gender identity, gender or
economic circumstances.
Also, do not allow yourself to be influenced
by personal likes or dislikes, sympathy, prejudice, fear,
public opinion or biases, including unconscious biases.
Unconscious biases are stereotypes attitudes or
preferences that people may consciously reject but may be
expressed without conscious awareness, control or
intention. You will recall that you took an oath
promising to do so at the beginning of the case.
You must follow all these instructions and not
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 2:20-cr-00579-SVW Document 677 Filed 07/09/21 Page 11 of 133 Page ID
#:10740
12
single out some and ignore others; they are all equally
important -- they are all important.
Please do not read into these instructions or
into anything I may have said or done any suggestion as
to what verdict you should return. That is a matter
entirely up to you.
The indictment is not evidence. The
defendants have pleaded not guilty to the charges. The
defendants are presumed to be innocent unless and until
the government proves the defendants guilty beyond a
reasonable doubt.
In addition, defendants do not have to testify
or preempt any evidence. The defendants to not have to
prove innocence; the government has the burden of proving
every element of the charges beyond a reasonable doubt.
Proof beyond a reasonable doubt is proof that
leaves you firmly convinced the defendant is guilty.
It is not required that the government prove
guilt beyond all possible doubt. A reasonable doubt is a
doubt based upon reason and common sense and is not based
purely on speculation. It may arise from a careful and
impartial consideration of all the evidence or from lack
of evidence.
If after a careful and impartial consideration
of all the evidence you are not convinced beyond a
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 2:20-cr-00579-SVW Document 677 Filed 07/09/21 Page 12 of 133 Page ID
#:10741
13
reasonable doubt that the defendant is guilty, it is your
duty to find the defendant not guilty.
On the other hand, if after a careful and
impartial consideration of all the evidence you are
convinced beyond a reasonable doubt that the defendant is
guilty, it is your duty to find the defendant guilty.
The evidence you are to consider in deciding
what the facts are consists of, one, the sworn testimony
of any witness, two, the exhibits received in evidence,
and three, any facts to which the parties have agreed.
In reaching your verdict, you may consider
only testimony and exhibits received in evidence. The
following things are not evidence and you may not
consider them in deciding what the facts are.
Questions, statements, objections and
arguments by the lawyers are not evidence. The lawyers
are not witnesses. Although you must consider a lawyer's
questions to understand the answer of a witness, the
lawyer's questions are not evidence.
Similarly, what the lawyers have said in their
opening statements and what they will say in their
closing arguments and at other times is intended to help
you interpret the evidence but it is not evidence.
If the facts as you remember them differ from
the way the lawyers state them, your memory of them
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 2:20-cr-00579-SVW Document 677 Filed 07/09/21 Page 13 of 133 Page ID
#:10742
14
controls.
Any testimony that I have excluded, stricken
or instructed you to disregard is not evidence. In
addition, if any evidence was received for a limited
purpose, if I gave that instruction you must follow it.
Anything you may have seen or heard when the
court was not in session is not evidence. You are to
decide the case solely on the evidence received at the
trial.
Evidence may be direct or circumstantial.
Direct evidence is direct proof of a fact such as
testimony by a witness about what that witness personally
saw or heard or did. Circumstantial evidence is indirect
evidence. That is proof of one or more facts from which
you can find another fact.
You are to consider both direct and
circumstantial evidence. Either can be used to prove any
fact. The law make no distinction between the weight to
be given to either direct or circumstantial evidence. It
is for you to decide how much weight to give to any
evidence.
A defendant in a criminal case has a
constitutional right not to testify. In arriving at your
verdict, the law prohibits from you considering in any
manner that the defendant did not testify.
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 2:20-cr-00579-SVW Document 677 Filed 07/09/21 Page 14 of 133 Page ID
#:10743
15
A defendant has testified. You should treat
this testimony just as you would the testimony of any
other witness.
In deciding the facts in this case, you may
have to decide which testimony to believe and which
testimony not to believe. You may believe everything a
witness says or part of it or none of it.
In considering the testimony of any witness,
you may take into account:
One, the opportunity and ability of the
witness to see or hear or know the things testified to.
Two, the witness' memory.
Three, the witness' manner while testifying.
Four, the witness' interest in the outcome of
the case, if any.
Five, the witness' bias and prejudice, if any.
Six, whether other evidence contradicted the
witness' testimony.
Seven, the reasonableness of the witness'
testimony in light of all the evidence.
And eight, any other factors that bear on
believability.
Sometimes a witness may say something that is
not consistent with something else he or she said.
Sometimes different witnesses will give different
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 2:20-cr-00579-SVW Document 677 Filed 07/09/21 Page 15 of 133 Page ID
#:10744
16
versions of what happened. People often forget things or
make mistakes in what they remember. Also, two people
may see the same event but remember it differently.
You should consider these differences, but not
decide that testimony is untrue just because it differs
from other testimony.
However, if you decide that a witness has
deliberately testified untruthfully about something, you
may chose not to believe anything that witness has said.
On the other hand, if you think the witness testified
untruthfully about some things but told the truth about
others, you may accept the part you think is true and
ignore the rest.
The weight of the evidence as to a fact does
not necessarily depend on the number of witnesses who
testify. What is important is how believable the
witnesses were and how much weight you think their
testimony deserves.
You have heard evidence that a witness had a
prior criminal conviction. You may consider this
evidence in deciding whether or not to believe this
witness and how much weight to give to the testimony of
this witness.
You are here only to determine whether the
defendants are guilty or not guilty of the charges in the
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 2:20-cr-00579-SVW Document 677 Filed 07/09/21 Page 16 of 133 Page ID
#:10745
17
indictment. The defendants are not on trial for any
conduct or offense not charged in the indictment.
A separate crime is charged against one or
more defendants in each count. The charges have been
joined for trial. You must decide the case of each
defendant on each crime charged against that defendant
separately. Your verdict on any count as to any
defendant should not control your verdict on any other
count as to any other defendant.
All the instructions apply to each defendant
and to each count unless a specific instruction states
that it applies only to a specific defendant or count.
The parties have agreed to certain facts that
have been stated to you. Those facts are now
conclusively established.
You have heard a recording in the Armenian
language. Each of you were shown or will be shown a
transcript of the recording which has been admitted into
evidence. The transcript an English language translation
of the recording.
Although some of you may know the Armenian
language, it is important that all jurors consider the
same evidence. The transcript is the evidence, not the
foreign language spoken in the recording.
You have heard that defendant Marietta
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 2:20-cr-00579-SVW Document 677 Filed 07/09/21 Page 17 of 133 Page ID
#:10746
18
Terabelian made phone calls from jail. You should not
consider the fact that she was in jail as evidence of her
guilt of the crimes charged in this case.
You have heard evidence that defendant Richard
Ayvazyan was released under the Bail Reform Act. You may
consider this evidence only for its bearing, if any, on
the question of whether Richard Ayvazyan was released
under that Act during the commission of the offenses
charged in counts 28 through 32 of the indictment.
You may not consider defendant Richard
Ayvazyan's bail status as evidence of guilt of the crimes
for which he is now on trial.
You have heard that other codefendants were
charged in this case and you should not speculate about
the reasons why codefendants were not part of the trial.
The indictment charges that some of the
offenses alleged were committed on or about or in or
around certain dates.
Although it is necessary for the government to
prove beyond a reasonable doubt that the specific offense
was committed on the date reasonably near the date
alleged in the specified count, it is not necessary for
the government to prove the specified offense was
committed precisely on the date charged.
Certain charts and summaries have been
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 2:20-cr-00579-SVW Document 677 Filed 07/09/21 Page 18 of 133 Page ID
#:10747
19
admitted into evidence. Charts and summaries are only as
good as the underlying supporting material. You should
therefore give them only such weight as you think the
underlying material deserves.
The defendants are charged in Count 1 of the
indictment with conspiring to commit wire fraud in
violation of Section 1343 of Title 18 of the United
States Code, and bank fraud in violation of Section 1344
of Title 18 of the United States Code.
In order for the defendant to be found guilty
of that charge, the government must prove each of the
following elements beyond a reasonable doubt:
First, beginning at least on or about
March 2020 and continuing to at least August 2020, there
was an agreement between two or more persons to commit at
least one crime as charged in the indictment.
Second, defendant became a member of the
conspiracy knowing of at least one of its objects and
intending to help accomplish it.
A conspiracy is a kind of criminal
partnership, an agreement of two or more persons to
commit one or more crimes. The crime of conspiracy is
the agreement to do something unlawful. It does not
matter whether the crime agreed upon was committed.
For a conspiracy to have existed, it is not
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 2:20-cr-00579-SVW Document 677 Filed 07/09/21 Page 19 of 133 Page ID
#:10748
20
necessary that the conspirators made a formal agreement
or that they agreed on every detail of the conspiracy.
It is not enough, however, that they simply met,
discussed matters of common interest, acted in similar
ways or perhaps helped one another.
You must find that there was a plan to commit
at least one of the crimes charged in the indictment as
an object of the conspiracy with all of you agreeing as
to the particular crime which the conspirators agreed to
commit.
One becomes a member of a conspiracy by
willfully participating in the unlawful plan with the
intent to advance or further some object or purpose of
the conspiracy even though that person does not have full
knowledge of all the details of the conspiracy.
Furthermore, one who willfully joins an existing
conspiracy is as responsible for it as the originators.
On the other hand, one who has no knowledge of
a conspiracy but happens to act in a way which furthers
some object or purpose of the conspiracy, does not
thereby become a conspirator.
Similarly, a person does not become a
conspirator merely by associating with one or more
persons who are conspirators, nor merely by knowing that
a conspiracy exists.
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 2:20-cr-00579-SVW Document 677 Filed 07/09/21 Page 20 of 133 Page ID
#:10749
21
A conspiracy may continue for a long period of
time and may include the performance of many
transactions. It is not necessary that all members of
the conspiracy join at the same time, and one may become
a member of a conspiracy without full knowledge of all of
the details of the unlawful scheme or the names,
identities or locations of all of the other members.
Even though a defendant did not directly
conspire with the other conspirators in the overall
scheme, the defendant has in effect agreed to participate
in the conspiracy if the government proves each of the
following beyond a reasonable doubt.
First, that the defendant directly conspired
with one or more conspirators to carry out at least one
of the objects of the conspiracy.
Second, the defendant knew or had reason to
know that other conspirators were involved with those
with whom the defendant directly conspired.
And third, that the defendant had reason to
believe that whatever benefits the defendant might get
from the conspiracy were probably dependent upon the
success of the entire venture.
It is not a defense that a person's
participation in the conspiracy was minor or for a short
period of time.
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 2:20-cr-00579-SVW Document 677 Filed 07/09/21 Page 21 of 133 Page ID
#:10750
22
Each member of a conspiracy is responsible for
the actions of the other conspirators performed during
the course of and in furtherance of the conspiracy. If
one member of a conspiracy commits a crime in furtherance
of a conspiracy, the other members have also under the
law committed the crime.
Therefore, you may find the defendant guilty
of a crime charged in the indictment if the government
has proved each of the following elements beyond a
reasonable doubt.
First, someone committed the crime.
Second, that person was a member of a
conspiracy charged in the indictment.
Third, that person performed the crime in
furtherance of the conspiracy.
Fourth, that person and the defendant were
members of the same conspiracy at the time that the crime
was committed.
And fifth, the crime fell within the scope of
the conspiracy and could reasonably have been foreseen by
the defendant to be a necessary or natural consequence of
that conspiracy.
The defendants are charged in counts 2 through
12 of the indictment with wire fraud in violation of
Section 1343 of the United States Code as follows.
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 2:20-cr-00579-SVW Document 677 Filed 07/09/21 Page 22 of 133 Page ID
#:10751
23
You will receive a chart. I am not going to
read the chart, but there will be in that instruction
number 24, at page 26, on the left a column which
identifies the count of the indictment, the second column
from the left, the date, then, some description of that
count, and finally the defendants who were charged in
that count.
That will be through counts 10 to 12. I hope
that will assist you in going through the evidence.
In order for defendant to be found guilty of
wire fraud in violation of Section 1343 of Title 18 of
the United States code, a defendant [sic] must prove each
of the following elements beyond a reasonable doubt:
First, defendant knowingly participated in or
devised a scheme or plan to defraud or a scheme or plan
for obtaining money or property by means of false or
fraudulent pretenses, representations or promises.
Second, the statements made or facts omitted
as part of the scheme were material. That is, they had a
natural tendency to influence or were capable of
influencing a person to part with money or property.
Third, the defendant acted with the intent to
defraud. That is, the intent to deceive and cheat.
And fourth, the defendant used or caused to be
used interstate wire communications to carry out or
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 2:20-cr-00579-SVW Document 677 Filed 07/09/21 Page 23 of 133 Page ID
#:10752
24
attempt to carry out an essential part of the scheme.
In determining whether a scheme to defraud
exists, you may consider not only the defendant's words
and statements, but also the circumstances in which they
are used as a whole.
A wiring is caused when one knows that a wire
will be used in the ordinary course of business or when
one can reasonably foresee such use.
It need not have reasonably -- it need not
have been reasonably foreseeable to the defendant that
the wire communication would be interstate in nature.
Rather, it must have been reasonably foreseeable to the
defendant that some wire communication would occur in
furtherance of the scheme, and an interstate wire
communication must have actually occurred in furtherance
of the scheme.
Instruction No. 25 is with regard to bank
fraud. The defendants are charged in counts 13 through
20 of the indictment with bank fraud in violation of
Section 1344, subsection 2, of Title 18, United States
code as follows:
As I just told you with wire fraud, there is a
chart similarly laid out with regard to the bank fraud
charges, and it will assist you if you need to refer to a
count and a defendant and a brief description of the
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 2:20-cr-00579-SVW Document 677 Filed 07/09/21 Page 24 of 133 Page ID
#:10753
25
count. I won't read that to you. You will get a copy of
these instructions, and you will have that to examine if
you wish.
In order for a defendant to be found guilty of
bank fraud in violation of Section 1344, subsection 2, of
Title 18 of the United States Code, the government must
prove each of the following elements beyond a reasonable
doubt for each count:
First, defendant knowingly carried out a
scheme or plan to obtain money or property from the
financial institution specified in the count by making
false statements or promises.
Second, defendant knew that the statements or
promises were false.
Third, the statements or promises were
material. That is, they had a natural tendency to
influence or were capable of influencing a financial
institution to part with money or property.
Fourth, the defendant acted with the intent to
defraud.
And fifth, the specified financial institution
was federally insured.
The following instructions apply only to
counts 2 through 12. The instruction I am reading to you
will be captioned "Aiding and Abetting," and they only
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 2:20-cr-00579-SVW Document 677 Filed 07/09/21 Page 25 of 133 Page ID
#:10754
26
apply for wire fraud and counts 13 through 20 for bank
fraud. That is, counts 2 to 12 and 13 to 20. You must
not apply this instruction to any other counts.
A defendant may also be found guilty of a
crime even if the defendant personally did not commit the
act or acts constituting the crime but aided and abetted
in its commission. To aid and abet means intentionally
to help someone else commit a crime.
To prove a defendant guilty of committing a
particular crime by means of aiding and abetting, the
government must prove each of the following beyond a
reasonable doubt:
First, a crime was committed by someone.
Second, the defendant aided, counseled,
commanded, induced or procured that person with respect
to at least one element of the crime.
Third, the defendant acted with the intent to
facilitate the crime.
And, fourth, defendant acted before the crime
was completed.
It is not enough that the defendant merely
associated with the person committing the crime or
unknowingly or unintentionally did things that were
helpful to that person or was present at the scene of the
crime. The evidence must show beyond a reasonable doubt
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 2:20-cr-00579-SVW Document 677 Filed 07/09/21 Page 26 of 133 Page ID
#:10755
27
that the defendant acted with the knowledge and intention
of helping that person to commit the crime.
A defendant acts with the intent to facilitate
the crime when the defendant actively participates in a
criminal venture with advance knowledge of the crime.
The government is not required to prove
precisely which defendant actually committed the crime
and which defendant aided and abetted.
All of the defendants are charged in counts 26
of the indictment with conspiring to engage in money
laundering in violation of Section 1956(H) of Title 18 of
the United States Code.
In order for defendant to be found guilty of
that charge, the government must prove each of the
following elements beyond a reasonable doubt:
First, beginning no later than in or around
March 2020 and continuing until at least in or around
October 2020, there was an agreement between two or more
persons to commit at least one of the following crimes:
One, money laundering in violation of Section
1956(A)(i)(b)(i) of Title 18 of the United States Code,
as explained in instruction 28. And, two, engaging in
monetary transactions in property derived from specified
unlawful activity in violation of Section 1957 of Title
18 of the United States Code, as explained in instruction
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 2:20-cr-00579-SVW Document 677 Filed 07/09/21 Page 27 of 133 Page ID
#:10756
28
No. 29, with all of you agreeing as to the particular
crime which the conspirators agreed to commit.
And second, defendant became a member of the
conspiracy knowing of at least one of its objects and
intending to help accomplish it.
In considering the charge of conspiracy to
commit money laundering, you must consider the general
conspiracy instructions that the Court provided to you
earlier. Those instructions are numbers 21 through 22.
The crime of money laundering under Section
1956(A)(i)(b)(i) of Title 18 of the United States Code
consists of the following elements which the government
must prove beyond a reasonable doubt:
First, defendant conducted a financial
transaction involving property that represented the
proceeds of conspiracy to commit bank fraud and wire
fraud in violation of Section 1349 of Title 18 of the
United States Code, wire fraud in violation of Section
1343 of Title 18, or bank fraud in violation of Section
1344 of Title 18.
The defendant knew that the property
represented the proceeds of some form of unlawful
activity.
Third, defendant knew that the transaction was
designed in whole or in part to conceal or disguise the
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 2:20-cr-00579-SVW Document 677 Filed 07/09/21 Page 28 of 133 Page ID
#:10757
29
nature, location, source, ownership, or control of such
proceeds.
A financial transaction is a transaction
involving the use of a financial institution that is
engaged in or the activities of which affect interstate
or foreign commerce in any way.
The phrase "knew that the property represented
the proceeds of some form of unlawful activity" means
defendant knew the property involved in the transaction
represented the proceeds from some form, though not
necessarily which form of activity that constitutes a
felony. I instruct you that conspiracy to commit wire
fraud, bank fraud and wire fraud are such felonies.
Let me say at that again. I instruct you that
conspiracy to commit wire fraud and bank fraud -- comma,
wire fraud and bank fraud are each a felony.
The crime of engaging in monetary transactions
and property derived from specified unlawful activity
under Section 1957 of Title 18, consists of the following
elements which the government must prove beyond a
reasonable doubt:
First, the defendant engaged in a monetary
transaction.
Second, defendant knew that the transaction
involved criminally derived property.
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 2:20-cr-00579-SVW Document 677 Filed 07/09/21 Page 29 of 133 Page ID
#:10758
30
Third, the property had a value greater than
$10,000.
Fourth, the property was in fact derived from
conspiracy to commit bank fraud and wire fraud in
violation of 1349 of Title 18, wire fraud in violation of
Section 1343 or bank fraud in violation of Section 1344.
Fifth, the transaction occurred in the United
States.
The term "monetary transaction" means a
deposit, withdrawal, transfer or exchange in or affecting
interstate commerce of funds or a monetary instrument by,
through or to a financial institution.
Defendant Vahe Dadyan is charged in count 27
and defendant Richard Ayvazyan is charged in counts 28
through 32 with money laundering in violation of 1956.
And the instruction has all the subsections. I am not
going to read that.
Instruction No. 28 explains the elements of
money laundering in violation Section 1956 in count 30.
That is, in count 30, you should look at the instruction
in instruction 28 for the elements of money laundering.
For each of counts 27 through 32, you must
find beyond a reasonable doubt that the defendant charged
in those counts committed each of the three elements
described in instruction No. 28.
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 2:20-cr-00579-SVW Document 677 Filed 07/09/21 Page 30 of 133 Page ID
#:10759
31
In considering the charges in counts 27
through 32, you must be careful to refer to the elements
in instruction No. 28 and not instruction No. 29.
I know this is a lot for you to remember with
precision. I am giving you these instructions so that
you have a general idea of how to follow the arguments
that the lawyers will give to you in a few moments, but
ultimately you will get a copy of these instructions to
review if necessary in the jury room, so don't be fearful
that you are not remembering everything I say. I
wouldn't remember everything I say if I were sitting
where you are. But that is the general idea of reading
these instructions at this point.
Defendant Richard Ayvazyan is charged with
committing the offenses charged in counts 28 through 32
while released pursuant to the Bail Reform Act. If you
find beyond a reasonable doubt that defendant Richard
Ayvazyan committed any of these offenses, you may also
determine whether the government has proven beyond a
reasonable doubt that he committed the offense while on
release.
Defendant Richard Ayvazyan is charged in
counts 21 and 22 of the indictment with aggravated
identity theft in violation of Section 1028(A) of Title
18 of the United States Code.
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 2:20-cr-00579-SVW Document 677 Filed 07/09/21 Page 31 of 133 Page ID
#:10760
32
Defendant Marietta Terabelian is charged with
this offense in count 22.
And defendant Artur Ayvazian is charged with
this offense in count 24.
In order for defendant to be found guilty of
aggravated identity theft as alleged in these counts, the
government must prove each of the following elements
beyond a reasonable doubt:
First, the defendant knowingly transferred,
possessed or used without legal authority a means of
identification of another person; namely, the following:
For count 21, the name of Mark Zindroski.
For count 22, the name and California driver's
license number of Nazar Terabelian.
For count 4, the name and date of birth of
Anna Dzukaeva.
Second, the defendant knew the means of
identification belonged to a real person.
And third, the defendant did so during and in
relation to a specific bank fraud or wire fraud offense
charged in the indictment; namely, the following:
For count 21, bank fraud as charged in
count 14.
For count 22, wire fraud, as charged in count
11.
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 2:20-cr-00579-SVW Document 677 Filed 07/09/21 Page 32 of 133 Page ID
#:10761
33
And for count 22, wire fraud as charged in
count 12.
The government need not establish the means of
identification of another person. Let me say that again.
The government need not establish that the means of
identification of another person was stolen or used
without that person's consent or permission.
A person has possession of something if the
person knows of its presence and has physical control of
it or knows of its presence and has the power and
intention to control it.
More than one person can be in possession of
something if each knows of it presence and has the power
and intention to control it.
I have three or four parting instructions to
give to you as to how you organize yourselves,
communicate with me, if necessary, how you deal with the
verdict form and so forth, but I will await giving you
those few instructions until after the lawyers have
completed their final arguments and before you begin your
deliberations.
We will now first hear from the government,
and then the defendants will have opportunities to
deliver their final arguments and the government will
have a rebuttal.
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 2:20-cr-00579-SVW Document 677 Filed 07/09/21 Page 33 of 133 Page ID
#:10762
34
I am advised that I may have accidentally said
something that I didn't intend to say. If I did say the
defendant must prove something beyond a reasonable doubt,
of course the government has the burden of proving things
beyond a reasonable doubt.
If I did misstate something, ignore that.
All right. Let's begin. And it will be
Mr. Fenton speaking for the government.
MR. FENTON: Thank you, your Honor. Members of
the jury, this is a case about the defendants' decision
to perpetrate a massive fraud during a national
catastrophe.
In a race against time, the government tried
to get out disaster relief funds to small businesses who
needed the money to survive. Seeing opportunity in
crisis, the defendants tried to get those disaster relief
funds first before that money ran out, meaning before
that money went to the small businesses who needed that
money to survive.
The evidence that we have heard over the last
five days shows that the defendants worked together to
build an assembly line of fraud. The defendants worked
together to produce, to submit disaster relief loan
applications, and once those disaster relief loan
applications were granted and they were funded and they
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 2:20-cr-00579-SVW Document 677 Filed 07/09/21 Page 34 of 133 Page ID
#:10763
35
got money, the defendants worked together to conceal and
to spend those funds.
Over the last five days, we have seen and we
have heard evidence about fake, stolen and synthetic
identities, fraudulent disaster relief loan applications,
fake tax forms, fake payroll reports, bank accounts that
were opened using other people's names, the names of
identities that are fake and stolen of individuals and
also of businesses as well.
And you have heard about wire transfers,
checks, credit cards, debit cards, all used to move the
money and to spend the criminal proceeds.
Now, while this fraud was massive, the
defendants who were responsible for this are part of a
small group of family and friends. You have the
defendant Richard Ayvazyan, his wife, Marietta
Terabelian, his brother Artur Ayvazian, his
sister-in-law, Tamara Dadyan, Tamara's cousin, defendant
Vahe Dadyan, defendant Richard Ayvazyan's associates and
friends Manuk Grigoryan and Edward Paronyan, and an
individual who worked with them named Armin Hayrapetyan.
That is the small group of defendants who were directly
involved in this who conspired and worked together.
A central feature of this particular
conspiracy is that defendants obscured their own
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 2:20-cr-00579-SVW Document 677 Filed 07/09/21 Page 35 of 133 Page ID
#:10764
36
identities and they obscured their role. The defendants
hid behind each other and they hid behind the fake
identities that they had created.
In the trial they have done the same thing.
You heard in opening statements that Vahe Dadyan blames
his cousin Tamara Dadyan. You heard that Artur Ayvazian
blames his wife. You heard that Marietta Terabelian
blames her husband, Richard Ayvazyan. And Richard
Ayvazyan blames Manuk Grigoryan, his coconspirator.
The evidence that you have seen and heard over
the last five days, however, shows beyond a reasonable
doubt that the defendants are all members of the
conspiracies that are charged, the two conspiracies:
One, to commit bank and wire fraud, and two, to commit
money laundering.
Once you are a member of a conspiracy, you
cannot discharge your responsibilities by blaming your
co-conspirators. Once you have that agreement to join,
you are all in it together.
Now, Judge Wilson has instructed you on the
law which you must follow. In a moment we will review
the evidence proving beyond a reasonable doubt that the
defendants are guilty of the crimes charged.
Before we do that, we respectfully ask you to
consider three things as you review the evidence.
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 2:20-cr-00579-SVW Document 677 Filed 07/09/21 Page 36 of 133 Page ID
#:10765
37
First, follow the money. Try as they may to
hide behind each other and to hide behind the fake,
stolen and synthetic identities in this case, the money
points directly to the defendants.
In some instances, the defendants directly
received the fraudulently obtained disaster relief money.
Defendants Artur Ayvazian, Vahe Dadyan, they put their
names on the applications, then they took those funds and
they lied on those applications.
In other instances, the defendants indirectly
received the money after it was funneled through accounts
to their co-conspirators or fake and stolen business
names. This applies to defendant Richard Ayvazyan. It
applies to defendant Marietta Terabelian.
If you follow the money, you will find the
mansion, the 3.25 million-dollar mansion that Richard
Ayvazyan and Marietta Terabelian purchased with PPP and
EIDL money, in their own name.
If you follow the money, you will find the
luxury watches that defendant Richard Ayvazyan purchased
from the Timepiece Gentleman, Anthony Farrer, who took
that stand and testified, and he purchased it using PPP
and EIDL loan money. Those watches were found in Richard
Ayvazyan and Marietta Terabelian's home, and they were
brought here and you saw them with your own eyes.
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 2:20-cr-00579-SVW Document 677 Filed 07/09/21 Page 37 of 133 Page ID
#:10766
38
If you follow the money, you will find the 60
gold coins that Richard Ayvazyan and Marietta Terabelian
purchased using money obtained from a PPP loan that was
filled out in the name of Marietta Terabelian's then
recently deceased father, Nazar Terabelian. Those 60
gold coins, again, were found in Richard Ayvazyan and
Marietta Terabelian's home. And you saw them with your
own eyes.
If you follow the money, you will find the
Harley-Davidson motorcycle that Artur Ayvazian admitted
on the stand that he purchased and that was purchased
with PPP funds that he also told you he needed so
desperately to save his business.
And if you follow the money, you will find
Vahe Dadyan's $50,000 cut of the criminal proceeds given
to him by Richard Ayvazyan using a fake company, Timeline
Transport.
The second thing that we would ask you to
consider as you go through the evidence is that
co-conspirators have different roles. The defendants are
charged with being participants, members of two
conspiracies: A conspiracy to commit bank fraud and wire
fraud, number one, by fraudulently obtaining PPP and EIDL
loan funds, and, number two, a conspiracy to commit money
laundering.
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 2:20-cr-00579-SVW Document 677 Filed 07/09/21 Page 38 of 133 Page ID
#:10767
39
As we explained during our opening statements,
the defendants each played very different roles. We
previewed this for you, and this bears out in the
evidence.
Defendant Richard Ayvazyan was the leader. He
put together the assembly line for fraud and for
laundering the criminal proceeds. He also used a
synthetic identity Iulia Zhadko.
Defendant Marietta Terabelian assumed the
identity of Victoria Kauichko to apply for many loans and
moved and spent the criminal proceeds.
Defendant Artur Ayvazian submitted fraudulent
PPP and EIDL loan applications. He created fake
identities and he moved the criminal proceeds as well.
Defendant Vahe Dadyan, he no doubt has the
smallest role in the entire conspiracy. We previewed
that from minute one of our case. His role involves one
single loan. But the fact remains, he cooperated with
his cousin Tamara Dadyan and Artur Ayvazian and Richard
Ayvazyan to fraudulently apply for that loan through the
assembly line of fraud that they had created, and he got
his cut. He gave the money to a fake company. He
received the money back from a fake company. That makes
him a member of the conspiracy.
Regardless of their role, they are all
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 2:20-cr-00579-SVW Document 677 Filed 07/09/21 Page 39 of 133 Page ID
#:10768
40
co-conspirators.
Third, we ask you to remember that the
defendants are liable if they submitted or caused to be
submitted these applications. The indictment charges
that each defendant committed an act or that they caused
that act to be committed, meaning, for example, the
indictment charges that defendant Richard Ayvazyan
submitted a PPP loan application or caused that PPP loan
application to be submitted.
It is therefore not necessary that each
defendant actually submit the application themselves if
they otherwise took steps to cause the fraudulent PPP
application to be submitted.
Now, we will move on to the evidence. We will
move on to a review of the evidence.
From the outset, you heard that the federal
government threw a lifeline to small businesses, and that
was in two forms. The first was with the Paycheck
Protection Program, and Kathleen Littwin from the SBA
came and testified here.
She testified about the fact that they allowed
the borrowers to provide self-certifications, and she
also testified about the type of information that was
important to the SBA.
And she walked through the various
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 2:20-cr-00579-SVW Document 677 Filed 07/09/21 Page 40 of 133 Page ID
#:10769
41
certifications, including certifications regarding the
number of employees and explaining why that was
important, and the fact that the business was in fact in
operation, and the fact that those proceeds that would be
lent out by the SBA would actually be used for business
expenses and not personal expenses.
Likewise, she also testified about the
economic injury disaster loan program, which was
similarly designed to allow for self-certification and
also to allow businesses to get the lifeline that they
needed to continue operations, save jobs and save the
economy.
Now, just like with respect to the PPP loans,
the use of these loans was to be for business purposes,
not personal purposes. And, again, she testified that it
was important to the SBA that that was how the funds were
used.
You also heard from a Celtic Bank
representative, Justin Masterman, who told you that with
respect to the PPP program it mattered to the bank
whether or not borrowers were truthful on their
application. This was important so that the government
was able to get the money in the right hands.
Now, we have showed you some of the text
messages that are contained in Exhibit 10. Exhibit 10 is
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 2:20-cr-00579-SVW Document 677 Filed 07/09/21 Page 41 of 133 Page ID
#:10770
42
the excerpts from the extensive text communications
between two individuals.
The first individual is named Rich New, and
ties back to a telephone number that ends 4170. We
showed you evidence that that phone number ties back to
Iulia Zhadko. And the telephone number was also used by
Richard Ayvazyan.
The second participant is Tamara Dadyan, who
is referred to in the texts as Tammy.
These two individuals, who were the leaders of
this fraudulent conspiracy, provide in those texts
details, details about how they planned and executed the
conspiracy. I would strongly encourage you, read those
texts.
They will show you that on March 12, as soon
as they heard about the announcement from the president
that they were going to pass this bill to give billions
of dollars in funding, Richard Ayvazyan and Tamara Dadyan
were on top of it. Tamara writes, "We can totally do
this."
Weeks later, Richard Ayvazyan writes they
started getting e-mails today from the SBA, $10,000
guaranteed. And this is the advance that you heard
about. Tamara says, okay, so let's do it for all these
idiots. 10,000 is 10,000.
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 2:20-cr-00579-SVW Document 677 Filed 07/09/21 Page 42 of 133 Page ID
#:10771
43
Richard Ayvazyan writes, "You use the bank
statement I gave you for Iulio. They don't check for
shit, Tam. It's all automated."
Weeks later -- or months later, he writes,
"Newtek is the bomb. Just got docs on two I did last
week," with a huge smiley face.
And there are other text messages as well if
you take time to look at them, text messages that show
you there was a race against time. "We need to do this
to the max we can now because you understand that the
market is going to crash." And, "We can use the same
names."
And they did. We showed you in the summary
chart exhibit, 116, that they were using the same names
over and over again. Richard says in a separate text,
"Good because you know this program is over by the end of
the month. So get as much as you can."
They talk about the frustrations and
challenges that they encounter when things don't go their
way. And if you see here, they are laughing all the way
to the bank.
There is difficulty trying to get in touch
with one of the banks and Tamara Dadyan says, "I was like
on hold forever, bro. Kept calling back. Today was a
disaster, just like the loan they are giving, LOL."
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 2:20-cr-00579-SVW Document 677 Filed 07/09/21 Page 43 of 133 Page ID
#:10772
44
They also talked about which places were the
best places to get the loans because they were easiest.
And in this text, for example, you see Richard saying, "I
did two yesterday and got docs today. One of them
already funded the account. It is crazy. Do PayPal."
And PayPal is WebBank.
And then you see them reporting to each other
when they successfully get the loans. Here they say,
"Signed today" with a bag of cash, and a sign saying that
everything is good. Tamara Dadyan responds "LOL,"
laughing out loud.
And they continue to laugh, "laughing my ass
off. They just ran out of money and they can't fund.
Just got an e-mail." Tamara Dadyan writes, "They are
never going to have enough money. America needs to file
BK."
These are the individuals who led this
conspiracy. These are the individuals who created an
assembly line for fraud. They learned how to do this
from day one when the program became available. They put
together the parts and then they shared them with their
co-conspirators.
There are five exhibits. There is a lot of
evidence in this case. There is a mountain of evidence
in this case, but there are five exhibits that I would
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 2:20-cr-00579-SVW Document 677 Filed 07/09/21 Page 44 of 133 Page ID
#:10773
45
direct your attention to.
First, the text messages between Richard
Ayvazyan and Tamara Dadyan, government Exhibit No. 10.
It is about 41 pages, and it is worth the read. It goes
through in details the inner workings of the fraud. It
also details the involvement of co-conspirators,
co-conspirators like Artur Ayvazian and Vahe Dadyan. We
will give you some examples of those text messages later.
The second exhibit that we suggest that you
read is the "Flow of Funds Summary Chart" exhibit.
Marylee Robinson testified about her efforts to follow
the money. This is the document that she put together
that does just that.
Again, this is a document that shows you that
this is a cohesive conspiracy involving eight defendants,
eight individuals, and it shows you -- if you look, you
can see all the different places where these defendants
are interacting and sharing money from PPP and EIDL loan
programs.
The third piece of evidence that we would
direct you to is government Exhibit 57A, the driver's
licenses that came from Artur Ayvazian's house. Dozens,
dozens of fake driver's licenses with individuals on
there, Social Security cards, credit cards and debit
cards all found in his home.
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 2:20-cr-00579-SVW Document 677 Filed 07/09/21 Page 45 of 133 Page ID
#:10774
46
There are also credit cards that were
belonging to Iulia Zhadko and Victoria Kauichko seized
from defendants Richard Ayvazyan and Marietta Terabelian
at Miami International Airport as they came back from a
vacation from Turks and Caicos in the middle of the
pandemic in October.
And, fifth, we direct you to the jail calls
that Marietta Terabelian placed when she was arrested at
Miami International Airport and was in jail in Miami.
Those are government Exhibits 50A/B and 50D/E.
Now, we will talk about the individual counts
and the evidence supporting those counts. And here, this
is not all of the evidence. This is just the evidence
that we are choosing to highlight for you here.
These are the eight co-conspirators. First,
we will focus on Richard. Here is one of the many texts
that show Richard Ayvazyan and Tamara Dadyan planning the
conspiracy. And if you recall in the opening statement,
Richard Ayvazyan is suggesting that it is Tamara Dadyan
who would be responsible, not him.
And if you look here, he says, "Go to BlueVine
right now and apply. They are approving and closing
within 24 hours." And she says, "With same info?" He
says, "Yeah, just change your EIN by one number. I did
seven apps last night, and four of them got e-mailed that
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 2:20-cr-00579-SVW Document 677 Filed 07/09/21 Page 46 of 133 Page ID
#:10775
47
it is funded." He goes on to say at the bottom, "I
didn't sleep all night. I was working 24 hours
straight."
He then asked her a question in a separate
text message, "Who told you to use those numbers? She
says, "Me myself, LOL." He responds, "You are funny. I
told you that I have the freaking formula."
How do we know that Richard Ayvazyan is Iulia
Zhadko? Well, there is a mountain of evidence that shows
that he is. Here are the various Iulia Zhadko IDs that
are in evidence with references to where you can find
them.
There are three different versions where he is
a male, and if you look at the address, the address on
the fake driver's license matches the address on the
driver's license for defendant Richard Ayvazyan, 5141
Genesta Avenue, Encino, California. That ID is the ID
that Richard Ayvazyan sent to the Timepiece Gentleman in
a text message from the telephone number ending 4170.
That is the same telephone number that he uses to text
with Tamara Dadyan.
This is also the same address, if you look at
text messages -- I'm sorry, e-mails from Richard
Ayvazyan. When he is buying his dream home, the one that
he brought with PPP and EIDL loan funds, he uses the
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 2:20-cr-00579-SVW Document 677 Filed 07/09/21 Page 47 of 133 Page ID
#:10776
48
address 5141 Genesta. He says, "You can use that address
below for all mailing pertaining to the purchase."
As we demonstrated to you through the witness
testimony and the evidence that we have submitted, Iulia
Zhadko is actually a woman. And Iulia Zhadko is a
foreign exchange student who had come to the United
States for a brief period of time and moved on, as was
the case with other individuals.
The reason why that is relevant, and this will
come with respect to later counts, is because with
aggravated identity theft, one of the elements is that
you have to show that there was knowledge that the
defendant knew that the person's whose identity was at
issue was a real person.
What you see in this case is a pattern where
foreign students who are coming to the United States on
visas are having their identities taken by the defendants
and used for purposes like this.
We then look at the credit cards that were
discovered in Richard Ayvazyan's luggage at Miami
International Airport. There are five credit cards here
in the name of Iulia Zhadko. And not only in the name of
Iulia Zhadko, but if you look at these credit cards you
will see they are in the name of companies that apply for
PPP and EIDL loans, Top Quality contracting, Turing Info
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 2:20-cr-00579-SVW Document 677 Filed 07/09/21 Page 48 of 133 Page ID
#:10777
49
Solutions. Those are two companies that we see loans
applied for that are fraudulent loan applications and the
money goes back to defendant Richard Ayvazyan.
The sixth card that we see here is Runyan Tax
Services. This is a Victoria Kauichko card. And again,
this is another company that applied for a PPP loan. And
you heard testimony during the trial from Jack Runyan,
who founded Runyan Tax Services. He does not know
Victoria Kauichko.
He has one employee since his wife passed
away. That employee is he himself. That is it. It is
his company, not their company. But they are carrying
around his card and applying for loans in his name.
Here is also a credit card discovered on
Richard Ayvazyan's phone. That credit card is in the
name of Iulia Zhadko. We then see that Iulia Zhadko
applied for many different loans. This one in particular
is the Timeline Transport loan. And if you follow the
money, it goes right to Richard Ayvazyan. It is used as
part of the down payment on what counsel said was in her
opening statement Richard Ayvazyan and Marietta
Terabelian's dream home, purchased in June, 2020, in the
middle of a pandemic, with disaster relief funds.
There is other financial information that is
found in Richard Ayvazyan's phone as well. Runyan Tax
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 2:20-cr-00579-SVW Document 677 Filed 07/09/21 Page 49 of 133 Page ID
#:10778
50
Service checks. Checks from Fiber One Media with
somebody else's name, Suzanna Merkuchian. Anna
Manukyan's name. A credit card in the name of Victoria
Kauichko. Another credit card with the name Victoria
Kauichko. And a credit card that says Richard Ayvazyan,
Fiber One Media.
And then again, these are companies that are
applying for these loans. We showed you in summary
Exhibit 116 that there is evidence showing that Fiber One
Media applied for PPP and EIDL loan funds. And again,
this is a fraudulent company, a fake company.
Now, how do we know that this is a conspiracy?
There is a lot of different evidence to show that they
joined together. Some of the evidence is the text
messages. Some of the evidence is the flow of funds.
Another piece of evidence that is really
important are these charts. What they show is the
assembly line of fraud. The assembly line for fraud.
There are component parts that go into these
applications. Two things are particularly important.
One, payroll reports from Gusto, or payroll reports
period. In this particular instance, they came from
Gusto.
And you heard from a represent from Gusto who
testified about why some of the payroll reports that you
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 2:20-cr-00579-SVW Document 677 Filed 07/09/21 Page 50 of 133 Page ID
#:10779
51
saw in this case did not come from Gusto and that they
were fake.
The second piece of evidence is Form 940s and
form 941s. These are tax forms which were fraudulently
completed and submitted in support of these applications.
The reason why they evidence a conspiracy amongst
defendants is because if you look at the different
applications and you look at the supporting
documentation, there are different groupings where they
use the same numbers to the penny. To the penny.
And they do it over and over again. And here
are some examples of companies that are directly tied to
Richard Ayvazyan. Fiber One Media and Mod Interiors.
And then we see companies that are tied to
other co-defendants -- other co-conspirators. For
example, Edward Paronyan, who submitted the application
in the name of Redline Auto Collision. His payroll
report that supposedly came from Gusto was the same as
payroll reports for Fiber One Media and Mod Interiors to
the penny, not only for the year, but for all 12 months
as well.
This is evidence of conspiracy.
We now look at Marietta Terabelian. There is
a credit card discovered in Marietta Terabelian's luggage
at Miami International Airport. This credit card did not
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 2:20-cr-00579-SVW Document 677 Filed 07/09/21 Page 51 of 133 Page ID
#:10780
52
belong to her. It was in the name of Victoria Kauichko.
On a phone that was seized elsewhere, not at
the airport, but somewhere else, at her home on
November 5th, there is an image that is discovered on
Marietta Terabelian's phone of Fiber One Media and the
name Suzanna Merkuchian, which should be familiar because
it is the same name on the card in Richard's possession.
And there is personally identifiable information
contained on this note.
If you look at the text messages that Richard
Ayvazyan sent to the Timepiece Gentleman, Anthony Farrer,
those text messages show that when he was having watches
shipped, one of those watches he had shipped to someone
that he said was his wife, and he provided his wife's
info. The information that he provided, the name
Victoria Kauichko, the company Fiber One Media.
The evidence also shows that if you look at
the card that was in Marietta's possession, that card was
used to buy things that would be unique to Marietta
Terabelian. For example, furniture purchased from Italy
2000, which is imported fine furniture, sold to Victoria
Kauichko, delivered to 5141 Genesta Avenue. That is
where they lived before they moved to their dream home.
This card was also used to pay for the rent
for the apartment at 6150 Canoga Avenue, which you heard
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 2:20-cr-00579-SVW Document 677 Filed 07/09/21 Page 52 of 133 Page ID
#:10781
53
a lot about during this trial. The reason why you have
heard a lot about that apartment is because it was an
apartment that was used in furtherance of the scheme to
commit bank fraud and wire fraud.
There are several different applications that
were submitted using this address, the name of Victoria
Kauichko, Fiber One media, Journeyman Construction, which
is another Victoria Kauichko company, and Runyan Tax
Service as well.
IP addresses that tie back to this apartment
were also used in furtherance of the fraud. If you look
at how this money was spent -- and I will give you an
example -- if you look at how the Runyan Tax Service
money was spent, it was spent on things unique to
Marietta Terabelian.
She paid for her father's funeral using money
from Runyan Tax Service. That check was cut on
July 21st. If you look at the bank records, it will show
on the same day that a PPP loan came in from Seattle Bank
for Runyan Tax Services.
Runyan Tax Services also paid for more
furniture delivered to 5141 Genesta Avenue, which is
where defendants Richard Ayvazyan and Marietta Terabelian
resided before they moved to their dream home.
And the money from Runyan Tax Services was
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 2:20-cr-00579-SVW Document 677 Filed 07/09/21 Page 53 of 133 Page ID
#:10782
54
also used to pay for a down payment for another home.
That home was purchased in the name of Iulia Zhadko, and
the person who paid for the water and the power for that
home, the power user for the home, Verdui Terabelian,
Marietta Terabelian's mother.
Marietta Terabelian also played a role with
respect to pooling and transferring money. And you
recall this chart. This was from Exhibit 115. And if
you look here, you see her role. She is receiving EIDL
and PPP loan money into her personal bank account.
And if you look at the bank records, and they
are in evidence, what you will see is she is the
individual owner of that account, the sole signatory.
She controls that bank account, what goes in, what goes
out.
What came in was EIDL and PPP loan money
fraudulently obtained. What went out was a wire transfer
to Encore Escrow to purchase a 3.25 million-dollar home
in her name and the name of her husband on Topeka Drive.
And then there are the jail calls. And we
encourage you to take a look at these jail calls in
detail.
There is two that we focus on here. The
first, "Richard and I were caught," which means according
to the translator, apprehended. "Found a card or I don't
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 2:20-cr-00579-SVW Document 677 Filed 07/09/21 Page 54 of 133 Page ID
#:10783
55
know what. You know the charges," which means that she
knows the charges. And then she implores the person on
the other end, "Clean the house as much as you can."
Now, counsel suggests that what that means is
that she got caught, she is worried about the charges and
the first thing she thinks is to tidy up. That defies
common sense. She says "you know the charges," because
she knows the charges and she says you know the charges
because she wants them to clean the house of evidence,
evidence of the crime.
These are the parts of the assembly line of
fraud that we spoke about earlier. There are the fake
ID's, there are the applications, there are the payroll
reports. They are all the things that you see on
Richard's phone and elsewhere and at Artur's home at
Weddington and on his phone as well.
There is a second call, "Tell mom me and
Richard are both at Miami jail. Nothing wrong. Tell
them so that they know so that they can try to clean,
clean the house as much as you can, everything, and
whoever calls, whatever they say, you shouldn't say
anything to anyone."
Now, we will take a look at Artur Ayvazian's
role in the crime. Artur Ayvazian lived at 17450
Weddington Street. You know that because he told you.
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 2:20-cr-00579-SVW Document 677 Filed 07/09/21 Page 55 of 133 Page ID
#:10784
56
You know that because that is what the agent said as
well. There are volumes of evidence showing that that
was his home.
This is what was found in his home. Dozens of
fake ID's, fake driver's license, all parts of the
assembly line for fraud. And they found PPP loan
applications as well.
These are not digital copies. These are hard
copies. And if you look -- I will give you some
examples. If you look at the types of applications that
were found in Artur Ayvazian's home, one was for Anna
Dzukaeva. She is the individual who is alleged -- whose
identity was allegedly used in connection with applying
for fraudulent PPP loan applications. You also find a
hard copy of PPP loan applications submitted in Tamara
Dadyan's name as well as Artur Ayvazian's name.
These hard copy documents are contained in his
home along with the fake IDs.
There are also lists of e-mails for borrowers,
and these e-mails are not for Tamara or Arthur. These
are e-mails for people like Anna Dzukaeva, people whose
e-mails were used fraudulently to apply for PPP and EIDL
loans.
And you find checks, checks for dozens of
companies. Here is just an excerpt. Here are just
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 2:20-cr-00579-SVW Document 677 Filed 07/09/21 Page 56 of 133 Page ID
#:10785
57
examples. These companies, Victoria Kauichko, Sabala
Construction, Anna Dzukaeva, Liudmyla Kopytova, Voyage
Limo, Vahe Dadyan's company. EM Construction, Rosa
Avakian. All of these individuals, none of whom are
Tamara Dadyan or Artur Ayvazian. These are other
people's names, other people's companies.
You also find handwritten notes relating back
to Fiber One Media, which is similar -- it is the same
company for which there are handwritten notes found on
Marietta Terabelian's phone as well. Again, this is more
evidence of conspiracy. The reason why, these companies
are fake. They don't exist.
These are two important exhibits. The first
is a list that was found in Artur Ayvazian's home. It
lists local construction companies, Sabala Construction.
VLA Construction, EM Construction. These are companies
whose names were used to fraudulently apply for PPP and
EIDL loans.
If you look at the Canoga apartment, which was
initially leased by Manuk Grigoryan, one of the
co-conspirators, and later leased by Victoria Kauichko,
it ties back to that card that was found on Marietta
Terabelian's person at Miami International Airport. The
lists have similarities.
Sabala is on both lists, VLA is on both lists.
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 2:20-cr-00579-SVW Document 677 Filed 07/09/21 Page 57 of 133 Page ID
#:10786
58
EM Construction is on both lists. It is not a
coincidence. It is a conspiracy. They are working
together to file these loan applications.
This is further proof of a conspiracy between
Tamara Dadyan, Artur Ayvazian, Manuk Grigoryan, Richard
Ayvazyan, Marietta Terabelian, the individuals who
controlled these different residences.
This shows what was found in those residences,
and there is overlap. And if you look at the checks as
well that I just showed you, there are check books in the
name of Sabala Construction, EM Construction, and other
construction companies as well, which is further proof of
the conspiracy.
If we look at what Arthur did with his money,
in addition to buying a Harley-Davidson, he gave the
money to his brother to buy a 3.25 million-dollar mansion
just to help him out.
And here are text messages between Richard
Ayvazyan and Tamara Dadyan that put Arthur in the middle,
the middle of this conspiracy, "You have money in B of A.
Art does. I will call him in a minute. I need 95,000
for escrow today." He is going to call Art.
"Leave a note to file on his trucking."
That's Richard's suggestion, and that is what he does.
And he takes the money and gives it to Richard, and he
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 2:20-cr-00579-SVW Document 677 Filed 07/09/21 Page 58 of 133 Page ID
#:10787
59
buys himself a Harley.
"Tom is coming over," Tamara says. "I told
Art show him the decline letter from EIDL, and it is
simple. It is 35 percent for PPP." 35 percent what?
The evidence shows it's a 35 percent cut. They help him
file, and they get a piece of it.
And Richard says, "Okay, let me do this. Give
me 30 minutes." And Artur Ayvazian is not an errand boy.
You look at the text in the middle, Art wants to do
another one with US Bank.
And when you look at another text message
here, "Rich, for Runyan, you have enough money. If I'm
right, 73,500 hours and my Vahe deal, the 38,750 and the
58,125."
These are cuts from the conspiracy. They are
dividing the criminal proceeds. This is the evidence.
Text messages between co-conspirators talking about other
co-conspirators and their roles.
They need checks to order for different fake
identities. This one is Mikala(Phon.). " Which place
will be fast," Tamara asks. Richard has an idea, "Have
Art go buy those blank ones from Office Depo and just buy
the software for every bank. Just make the checks."
And then Tamara says, "I am expecting a wire
for Art for $73,500." This is the wire that we spoke
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 2:20-cr-00579-SVW Document 677 Filed 07/09/21 Page 59 of 133 Page ID
#:10788
60
about earlier. "And for me," she is reminding him,
"157,000."
Here is the check that Arthur gets through
Runyan Tax Service. That company doesn't exist. It is
fake. Well, it is not fake. It actually belongs to Jack
Runyan, but this version of the company is fake.
Further evidence of Arthur's involvement is
the fact that IP address information ties back to his
home. He is the subscriber. The subscriber name is
Arthur Ayvazian. This is his IP address. That is his
subscriber address, 17450 Weddington Street. He applies
for the Anna Dzukaeva loan.
And we hear this name over and over again,
Anna Dzukaeva. She is the individual whose identity they
stole to file these loan applications that is charged in
the indictment.
Here are examples of PPP and EIDL loans that
tie back to Arthur Ayvazian's IP address at his
subscriber name at his subscriber address. And they
include the application for Vahe Dadyan, which they
helped him submit because it is a conspiracy and they are
working together.
Now, Arthur said Tamara did it; right? She
put stuff on his phone. They had similar things on the
phone, for sure. They had the Anna Dzukaeva IDs. And
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 2:20-cr-00579-SVW Document 677 Filed 07/09/21 Page 60 of 133 Page ID
#:10789
61
you see that here.
This possession of this ID in furtherance of a
fraudulent act, a wire fraud or bank fraud count, that is
a crime. That is what is charged in the indictment. It
is count 24.
They also had checks. But notice, these
pictures are not identical. These are different pictures
of Anna Dzukaeva checks, and they are different checks as
well. And then you see they have information -- they
both have information on their phone showing that they
are applying and tracking PPP and EIDL loan applications.
But there are differences as well, differences
that are unique to Arthur's role. One of those is that
Arthur has information that can be used to create fake
IDs. Information like this, and this isn't theoretical.
This isn't something he may or may not have done. There
is evidence he actually did it. More evidence unique to
Arthur's phone showing people asking for IDs to be
created using particular information and then they file
the product.
There is more evidence as well. If you look
at the highlighted paragraph, "Please use an old Armenian
guy and please make his description match. Thank you."
And Arthur replies, "There is the ID." This is Arthur's
role. Not Tamara's role. This is Arthur's role. They
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 2:20-cr-00579-SVW Document 677 Filed 07/09/21 Page 61 of 133 Page ID
#:10790
62
work together, no doubt. And you see in the text
messages what they worked together to do. But you also
see Arthur's unique role in this conspiracy. He is
responsible for parts of the assembly line for fraud,
these IDs.
Further evidence of the conspiracy is the fact
that, like with the other loans that we looked at, they
are using the same supporting documentation. Again,
summary chart Exhibit 116. You look at this and see that
they are using the same Form 940s down to the penny, and
this includes Arthur Ayvazian and Vahe Dadyan as well.
Now, Arthur Ayvazian took the stand. You
heard from him yesterday. He told his story. And he
explained to you all of the reasons why he won't trust
Tamara Dadyan.
The question was asked, "Is your wife, Tamara
Dadyan, involved in this trucking business at all?"
"No, not at all, sir. She is against it."
The question was asked, "Now, do you pay your
taxes together?"
He said, "No, sir."
Question, "Whose idea was that?"
"My idea."
"Why?"
"I didn't want to get involved in filing with
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 2:20-cr-00579-SVW Document 677 Filed 07/09/21 Page 62 of 133 Page ID
#:10791
63
her."
He explains, "I moved out of the house right
away even though my lawyer told me not to, because I had
every right to be there and I just didn't want to see her
face anymore."
And then he goes on to explain that there are
times where there have been IDs on his phone, "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 Arthur says, "I end up erasing it."
Yet he trusted Tamara Dadyan to submit his PPP
and EIDL loan applications? He won't file taxes with her
but will have her do the paperwork for loans? It defies
common sense because it is not true.
"So I told Tammy, hey, do you think my company
will qualify, because I really need it right now."
"She says, yeah, I'll take care of it."
"She says, yes, I'll take care of it"
And I said "okay."
"She asked to see my 1099s." These are the
1099s -- he won't file taxes with her. She is not
involved in his business, but now he is just going to
hand everything over? It defies common sense.
He also told you he had a desperate, desperate
need for the funds for his business.
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 2:20-cr-00579-SVW Document 677 Filed 07/09/21 Page 63 of 133 Page ID
#:10792
64
"2019, I did great. I made a lot of money in
2019, but as soon as 2020 came I went from making 130
something thousand to $30,000. Once the pandemic hit, I
was just devastated. There were no jobs. The receivers
weren't working."
What do you need the money for? Well, since I
got the first one that came, he spent a lot of it towards
his business. He was behind in his trucking payments.
He's behind in repairs, he needs tires. Just a lot of
expenses toward the company.
Yet, he immediately spent his EIDL loan
proceeds on a Harley-Davidson and his brother Richard
Ayvazyan's 3.25 million-dollar mansion.
His explanation that he had desperate need for
the money for his business defies common sense. That is
not how his money was spent. It's not true.
We look at Vahe Dadyan. Vahe Dadyan had the
smallest role in the conspiracy. But it is significant,
because he lied on a PPP loan application, one
application for $157,500 signed with his name in the name
of his company.
How do we know it is a conspiracy? Well, the
application was submitted by Tamara Dadyan. We saw that
earlier through the IP address information. And it was
using the same documentation that Arthur used for the
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 2:20-cr-00579-SVW Document 677 Filed 07/09/21 Page 64 of 133 Page ID
#:10793
65
Allstate Towing.
Again, these are tax forms, Form 940s, with
the same financial information down to the penny because
they are fake.
Now, he gets all this money. It goes into his
account. If you look at the documents that are in
evidence, the bank records, what it shows is he is the
sole owner of this company and the signatory on this bank
account. It is his bank account. He controls it.
Nobody else.
What does he do with that money? He sends it
to Runyan Tax Services. Not Jack Runyan's Tax Service.
Victoria Kauichka's tax service. That company doesn't
exist. Victoria Kauichko, not a real person. Yet, Vahe
Dadyan sends the money there. What does he call it?
What does he say when he sent the money? He calls it
payroll. And, you know what, that was a lie, because it
wasn't.
What happens to that money? It doesn't go to
pay anybody. It goes to buy a house in the name of Iulia
Zhadko. This is evidence of conspiracy.
Now, Vahe Dadyan is prominently featured in
text messages between Richard Ayvazyan and Tamara Dadyan.
Why? Because he is insistent. He wants his cut, and he
wants it now.
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 2:20-cr-00579-SVW Document 677 Filed 07/09/21 Page 65 of 133 Page ID
#:10794
66
If you look at the text messages, they talk
about how Vahe was pushing. "Rich, we've got to send him
his part here."
"How much?"
"I will tell you."
Where they going to send it? V&D Limo. Those
initials, Vahe Dadyan.
"Rich, let me know if you have checks for
deposit, if I can wire this out to Vahe -- part. He's
the type, wake up and checks account."
He is waking up and checking his account. He
wants his money. And then she says that in the text
below. "Please, like, he wakes up and tests me. LOL."
This is not a passive participant. This is
somebody who wants their cut. And these text messages,
these aren't between and amongst strangers. They are
between and amongst co-conspirators, people who are
working together for a common goal.
That goal is to defraud the SBA and the
lenders to get disaster relief funds that don't belong to
them, to which they are not entitled.
You then see these additional text messages.
They go back and forth all about wires.
"Send me the routing number for the Vahe
wire." And they provide the information. Then they try
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 2:20-cr-00579-SVW Document 677 Filed 07/09/21 Page 66 of 133 Page ID
#:10795
67
to figure out how are they going to pay for it. They are
going to pay for it from Runyan.
Then they talk about the problems they are
encountering in terms of actually getting the wires to
work. Richard says, "Tammy, the limit is 25 a day." She
says, "Well, so then do Tuesday and Wednesday all from
the same place so I don't deal with him, please."
"Okay, Vahe can wait."
"Okay, I want a wire now." A wire for Vahe.
"What e-mail should I put for him?" This is
Vahe's e-mail. Vahe314@yahoo.com. It only allows -- "It
allows me only 25, so I sent 25. Do you want me to send
it to another place or can it wait?"
"Okay. Monday or you can give check. Art
will deport for him or whatever."
The money eventually gets to Vahe. He gets
his cut. And if you look at the bank records, he gets
the two $25,000 payments because they are on different
days, just like they planned, because otherwise it
wouldn't work.
And where does this money come from? It comes
from a company that does not exist, Timeline Transport,
from an individual who is fake.
This is all evidence of conspiracy. The
defendants, if you look in the middle, well, Tamara
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 2:20-cr-00579-SVW Document 677 Filed 07/09/21 Page 67 of 133 Page ID
#:10796
68
Dadyan called Vahe an idiot, so he must be. Well, Tamara
Dadyan called a lot of people idiots, and here are some
of the samples from the text messages. If you look
through those text messages, to Tamara Dadyan, anyone who
bothers her, who makes her day a little bit more
complicated is an idiot.
And you will see another word that is bandied
about as well. Moron. That is how she talks. It is
just what she says. Is that proof that Vahe Dadyan lacks
the intellectual capacity to commit fraud?
Look at the aggravated identity theft counts.
There are three.
Count 21, Richard Ayvazyan. You heard from
Mark Zindroski. He is one of the first witnesses we
called. He came up and testified from that stand. And
he told you he looked at this application and he laughed
because it is not him.
Somebody took his name and they submitted it
along with the name of his company that he owned, he
alone, owned for decades.
Iulia Zhadko, TQ Contracting.com. Look at the
phone number, 4170. It is the same phone number that
Tamara Dadyan is using to text Richard Ayvazyan. This
credit card was discovered in Richard Ayvazyan's luggage.
Top Quality Contracting, Iulia Zhadko.
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 2:20-cr-00579-SVW Document 677 Filed 07/09/21 Page 68 of 133 Page ID
#:10797
69
Now, there is a question. Does Richard
Ayvazyan know that this man is real? Of course he does.
He targets the owners of local construction companies.
Here is a list of them.
This was found at 6150 Canoga. It is the
apartment that Victoria Kauichko pays for.
Count 22. This is the aggravated identity
theft count that ties back to that Nazar Terabelian.
There are credit cards discovered on Richard Ayvazyan's
phone in the name of Mod Interiors, the company that
Nazar Terabelian supposedly worked at after he died.
And Nazar Terabelian. There are notes that
talk about the application, Mod SBA, in the corner up
there, with statistics, business figures, financial
figures for a company that doesn't exist. E-mail
addresses for a man who is deceased. And bank accounts
as well.
Nazar Terabelian died on July 18, 2020. This
is his death certificate. Here is the application he
submitted for a PPP loan five days later. It is a fraud.
Someone took his identity and used it after he died. And
then they spent the money on themselves.
What did they spend it on? Furniture,
diamonds, gold coins. How many gold coins? Sixty.
Sixty gold coins. Thirty plus 30 equals 60. Where do we
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 2:20-cr-00579-SVW Document 677 Filed 07/09/21 Page 69 of 133 Page ID
#:10798
70
find 60 gold coins? Richard Ayvazyan, Marietta
Terabelian's home.
Count 24. Artur Ayvazian, Anna Dzukaeva.
Anna Dzukaeva is a real person. We know that because the
witness from the Department of Homeland Security sat
there and testified to that fact, and we have documents.
Like Iulia Zhadko, the woman, not the fake man, she had
traveled to this country at one time. Foreign exchange
student. She was here for a while. She went back.
How does Artur Ayvazian know that she is real?
Well, there is evidence in his home that they are
collecting visas for foreign exchange students. These
are the individuals that they target in addition to the
local construction company owners.
This is the other type of people whose
identities they took. This is how you know that they
know that they are real.
These are the documents that were discovered
at Arthur's home. The applications with Anna Dzukaeva's
name on them. The images discovered in Artur Ayvazian's
phone. Her driver's license. Well, it is fake. And
there are two of them. And the two pictures are two
totally different individuals. And neither of them look
like the actual real Anna Dzukaeva, because that is
someone else who is in a foreign country right now.
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 2:20-cr-00579-SVW Document 677 Filed 07/09/21 Page 70 of 133 Page ID
#:10799
71
Her checkbook. IP address information showing
that this loan application was submitted from Artur
Ayvazian's home, where he is the subscriber.
We now look at count 26. Count 26 is the
money laundering conspiracy. It is different than the
bank and wire fraud conspiracy, but it is also related.
Summary chart, Exhibit 115. If you look at
this exhibit, it will tell you everything that you need
to know. There are two objects here. One is
concealment. The other is spending.
These charts detail how the defendants in this
case concealed and spent the criminal proceeds. This
example is Vahe Dadyan, Richard Ayvazyan, Marietta
Terabelian using this PPP money, concealing it, and then
eventually spending it on a home purchased in the name of
Iulia Zhadko.
And again, this is the home where Marietta
Terabelian's mother pays for the utilities.
Here are additional co-conspirators. Anton
Kudiomov. That is Manuk Grigoryan teaming up with
Victoria Kauichko, with whom he shared the apartment.
They take the PPP and EIDL money. They buy another house
in the name of Victoria Kauichko.
And then we have the slide here that shows all
of the players in the conspiracy -- most of the players
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 2:20-cr-00579-SVW Document 677 Filed 07/09/21 Page 71 of 133 Page ID
#:10800
72
in the conspiracy -- gathering their money, transferring
it to various accounts to conceal it, and ultimately it
is spent on a house for Richard Ayvazyan and Marietta
Terabelian.
And you have heard talk about Manuk Grigoryan.
This is the biggest prize, this house, $3.25 million.
This tells you everything you need to know. If there is
any suggestion that it was Manuk Grigoryan who is behind
it all, why doesn't he live in this house. Why is it
Richard Ayvazyan and Marietta Terabelian's house?
It is because they are in charge.
More evidence of money laundering conspiracy.
Armin Hayrapetyan, who has a smaller role like Vahe,
sending money through various accounts. Sabala
Construction. That is one of the companies we just
talked about.
Where do you see that company? That name is
at Canoga, Manuk Grigoryan's apartment, and also the
apartment that Victoria Kauichko rented.
You also see that name at Weddington, where
Artur and Tamara live as well. They have Sabala
Construction checkbooks, and they also have a list of
different companies that include Sabala Construction.
The reason as to the overlap, it is because it is a
conspiracy.
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 2:20-cr-00579-SVW Document 677 Filed 07/09/21 Page 72 of 133 Page ID
#:10801
73
Hart Construction. Same thing. They pooled
this money together, and what do they do? They pay three
individuals, Iulia Zhadko -- we all know who that is at
this point. The evidence shows -- the mountain of
evidence shows it is Richard Ayvazyan.
Fiber One. Fiber One is Victoria Kauichko.
Suzanna Merkuchian. It is also Richard Ayvazyan. We
know that because we saw the credit card that says Fiber
One Media. Richard Ayvazyan, that was in his possession.
Anna Manukyan. We also saw credit cards that
were in the possession of Richard Ayvazyan. We also see
credit cards that are in possession of Anna Manukyan
evidence with other co-conspirators as well.
The point is that Armin Hayrapetyan, the
individual who is moving this money, is giving this money
to the defendants sitting in this courtroom. It is not a
gift. It is a cut of the proceeds of the conspiracy.
Now, I don't think that any of this is really
in dispute. There is overwhelming evidence that all of
the loans that are detailed in the indictment, that they
all contain fraudulent information, information that
mattered to the SBA, information that mattered to the SBA
for lenders. And the reason we know that is because we
heard from them.
We asked them if this type of thing mattered
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 2:20-cr-00579-SVW Document 677 Filed 07/09/21 Page 73 of 133 Page ID
#:10802
74
and they said that it does. This is additional evidence
of the bank fraud and the wire fraud.
Witnesses. You heard from witnesses from the
Internal Revenue Service. You heard from California EDD.
The DMV, DHS. You heard from Gusto. You heard victim
testimony from Mark Zindroski, Jack Runyan, Alexander
Farrer, saying that when their names were on these
documents it was because their names were stolen.
And then there is documentary evidence. There
are the bank records, the loan files, and then the
records from the various state and federal agencies that
further document the fact that the statements made in
these loan applications are false.
And I will take some time to just briefly go
through this.
Sabala Construction, this is one of the loans
that was taken out, the false and misleading statements.
They used the stolen identity Donald Sabala. They
misrepresented the payroll employees.
And there is a false certification regarding
the use of funds. We know what happened with the money
that went to Sabala Construction. It went to Richard
Ayvazyan and Fiber One Media.
Anna Manukyan. Allstate Towing and Transport.
This is Artur Ayvazian's company. He misrepresented his
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 2:20-cr-00579-SVW Document 677 Filed 07/09/21 Page 74 of 133 Page ID
#:10803
75
payroll of his employees. It says in that application he
has 11 employees. He told you on the stand he doesn't
have 11 employees.
False certification regarding use of funds.
That money went to a Harley, went to his brother. And
there are fake IRS forms that were submitted in support
of that application that he wouldn't file taxes with his
wife, he said, but he let her handle these forms. Defies
common sense.
Top Quality Contracting. All you need to know
is that Mark Zindroski didn't submit this application.
That alone makes it fake. They also used a fake
California driver's license and fake IRS forms as well.
Comerica Bank. This is Tamara Dadyan's realty
company. Misrepresented the payroll, number of
employees, and a false certification regarding the use of
funds.
We know what happened to that money. That
money went to Richard Ayvazyan and Marietta Terabelian to
pay for their dream home.
The same thing with the second Secureline
Realty and Funding application. This time it also
contains fake IRS forms.
Redline Auto Collision. This was one of the
applications that was submitted in the name of Edward
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 2:20-cr-00579-SVW Document 677 Filed 07/09/21 Page 75 of 133 Page ID
#:10804
76
Paronyan, who is one of the co-conspirators, using
documentation that was similar to documentation used by
the other co-conspirators because it all came from the
assembly line for fraud.
You know where his money went. Government
Exhibit 115, the summary chart exhibit, shows you exactly
where it went. And it wasn't for business expenses.
Same thing with the other Redline Auto
Collision loan. Voyage Limo $157,500. It says here that
the number of employees is 11, like a lot of other
applications. But the evidence we presented shows that
that is not true.
There is a false certification regarding use
of funds. We know where that money went. Government
Exhibit 115. And fake IRS forms are submitted in
support.
All of these applications are fraudulent.
G&A Diamonds. This is Manuk Grigoryan's
father's company, Acacius(Phon.) Grigoroyan. Except it
is not really a company. It doesn't do anything anymore.
They misrepresented the payroll and the employees, and
there is a false certification regarding the use of
funds. This money goes to pay for Richard Ayvazyan's and
Marietta Terabelian's home. There are a couple of G&A
Diamond loans, and it is the same story. The one here
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 2:20-cr-00579-SVW Document 677 Filed 07/09/21 Page 76 of 133 Page ID
#:10805
77
also has fake IRS forms and misrepresents payroll
employees as well.
Timeline Transport, we already spoke about
that. Iulia Zhadko, not a real person. The application
is clearly fraudulent. The company, fake. They don't
have employees. The use of funds was never for business
purposes. It was for Richard and Marietta's house.
Mod Interiors. This is the company that Nazar
Terabelian took over after he died. It is not real. The
money went to go buy diamonds and gold coins.
Anna Dzukaeva. We have spoken about Anna
Dzukaeva repeatedly, and she is not in the country. They
stole her ID and they submitted this loan.
Hart Construction, it is the same story. You
see Hart Construction listed on the evidence. This is
one of the local construction companies that they stole
the identities for as well.
And then there is Redline Auto Mechanics.
They used a fake identity, Anton Kudiomov. Fake
California driver's license. Fake IRS forms. And you
heard from Alexander Farrer [sic], who took the stand and
said that he never prepared these documents, but they
used his name anyway.
Runyan Tax Service. You heard from Jack
Runyan. He did not submit this application. He doesn't
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 2:20-cr-00579-SVW Document 677 Filed 07/09/21 Page 77 of 133 Page ID
#:10806
78
know a Victoria Kauichko. She does not work for him.
That is because she is fake.
And then Turing Info Solutions. Turing Info
Solutions, we will look at this one more closely. Turing
Info Solution is Iulia Zhadko's company, except Iulia
Zhadko is not real. They used the fake driver's license,
fake IRS form, and the tax preparer is Jack Runyan.
So Jack Runyan gets hit twice. They take his
company name and then they sign his name to these forms
to say that he is responsible for them.
THE COURT: Let me ask you a question. Sorry to
interrupt. How much longer do you think you will be?
Just an estimate.
MR. FENTON: Ten minutes, 15 minutes the most.
THE COURT: I think we have to take a very short
recess. Five minutes. Sorry about that.
MR. FENTON: Okay.
(The following proceedings were held outside the
presence of the jury:)
THE COURT: Just one thing, Mr. Ram. You may be
seated, if you wish. You did submit what you announced
in open court for the Court's consideration yesterday
your outline of your argument. I won't get into that
because that was under seal and not to be discussed.
But there was one aspect in there, and I don't
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 2:20-cr-00579-SVW Document 677 Filed 07/09/21 Page 78 of 133 Page ID
#:10807
79
know if that is your intention or not. As I told the
lawyers yesterday, and in particular, Mr. Mesereau, if
you intend to argue reasonable doubt in any way like your
notes, that would be impermissible.
MR. RAM: Yes. We changed that after your update,
your Honor. That has been changed.
(Recess from 11:06 to 11:14 a.m.)
(The following proceedings were held in the
presence of the jury:)
THE COURT: You can continue your argument,
Mr. Fenton.
MR. FENTON: Thank you, your Honor.
The last loan that I will talk about is Turing
Info Solutions. This loan was for $384,150, submitted in
the name of Iulia Zhadko. And we spoke about Iulia
Zhadko quite a lot. Iulia Zhadko was a female foreign
exchange student whose identity was then taken, combined
with additional information, made into a synthetic
identity and turned into a male.
We have seen three different versions of that
identity used at this point. And this is one of the
applications that was submitted using the synthetic Iulia
Zhadko name.
There is a fake California driver's license.
We've showed you examples of these. Fake IRS forms, as I
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 2:20-cr-00579-SVW Document 677 Filed 07/09/21 Page 79 of 133 Page ID
#:10808
80
said earlier. They took Jack Runyan's name, and not only
did she submit fraudulent PPP loan applications using his
name, they also used his name to create fake IRS tax
forms as well.
Now, with respect to these bank fraud and wire
fraud counts, they are different than the conspiracy
count. The conspiracy count -- count 1 alleges a
conspiracy. The individual wire and bank fraud counts
are substantive counts which are separate and apart from
the conspiracy counts as well.
This is what I was speaking about earlier when
I talked about being responsible, regardless of whether
you submit the actual application itself or cause it to
be submitted.
Under either circumstance, the government
alleges in the indictment that it would be sufficient
that some of these applications were caused to be
submitted by the defendants. They don't actually need to
submit them themselves.
The other thing that I just want to call your
attention to with respect to the individual wire fraud
and bank fraud counts is that with respect to these there
is something called aiding and abetting liability, which
Judge Wilson has already instructed you on and which
applies with respect to these particular counts.
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 2:20-cr-00579-SVW Document 677 Filed 07/09/21 Page 80 of 133 Page ID
#:10809
81
We will now move onto counts 28 through 32.
After Richard Ayvazyan was arrested, he was
put on something called pretrial release. We had
testimony to that effect. When you are on pretrial
release, there are certain conditions. One of the
conditions is that you cannot commit additional crimes.
While on pretrial release awaiting trial, it
is alleged that Richard Ayvazyan engaged in money
laundering. The money laundering involved proceeds from
the PPP and EIDL loans that were deposited into the
Turing Info Solutions bank account.
This is a credit card discovered in Richard
Ayvazyan's luggage at the Miami International Airport
that shows that he had access to that account. It was an
account that was within his control.
We also know that Richard is in charge of this
identity because in the text messages with his
co-conspirator Tamara Dadyan, he actually shares this
information with her. He says, here, use this. The
owner is Iulia. And he gives the web address for Turing
Solutions and then also forwards along this piece of
paper.
This piece of paper contains a significant
amount of information relating to Turing Info Solutions
that could be used to do a variety of things like access
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 2:20-cr-00579-SVW Document 677 Filed 07/09/21 Page 81 of 133 Page ID
#:10810
82
bank accounts, open bank accounts or apply for PPP or
EIDL loans.
Now, we know that the Coinbase accounts,
basically the money was taken and it was used to do a
couple of different things. The EIDL and PPL loan comes
in for Turing Solutions in August 2020. That money then
sits there for several months. It sits there until about
December, 2020.
And this is after Mr. Ayvazian is arrested and
while he is on pretrial release. There is one transfer
that goes, $47,000 to Iulia Zhadko, JP Morgan account,
another transfer on December 22nd that goes to the Iulia
Zhadko account as well. And then that money is
subsequently transferred to an Ameritrade account.
Separate and apart from that, there is a
$22,000 transfer that takes place from the Turing Info
Solutions account to the Coinbase account. And if we
look at who that Coinbase account is in the name of, it
is Iulia Zhadko.
There are two Coinbase accounts in the name of
Iulia Zhadko. There is an old account that links back to
this driver's license, which we have seen before, and
there is a new account that links back to this third
Iulia Zhadko driver's license. And this is the one that
receives the laundered criminal proceeds.
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 2:20-cr-00579-SVW Document 677 Filed 07/09/21 Page 82 of 133 Page ID
#:10811
83
Now, we have spoken about the fact that
Richard Ayvazyan and Marietta Terabelian went to Turks
and Caicos in mid October. They were arrested upon their
return. And there is additional evidence further showing
the link between Richard's usage of the Iulia Zhadko name
in the form of bank records.
You heard special agent Clark testify about
these. When Richard Ayvazyan and Marietta Terabelian
were preparing to travel to Turks and Caicos on
October 9th, Iulia Zhadko controls this bank account at
Radius Bank, reaches out to Radius Bank and says, I want
to put a travel notice on my account.
And the bank representative asks what dates
will you be traveling and where will you be traveling to.
And the person who was pretending to be Iulia Zhadko says
October 10th through October 20th, Caribbean, Turks and
Caicos Islands.
And we see what they are doing when they are
in Turks and Caicos Islands. The text messages continue
between Richard Ayvazyan and Tamara Dadyan, and the text
messages are about the fraud.
He says:
"What's up, Tams? You up? I am three hours ahead
here. Text me when you get this. I made
introduction to escrow and said my attorney will
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 2:20-cr-00579-SVW Document 677 Filed 07/09/21 Page 83 of 133 Page ID
#:10812
84
be handling the loan doc signing. Can you respond
from his e-mail" -- the attorney e-mail -- "and
ask them to send you the docs?"
And Tamara Dadyan replies, "Good morning from
Olaf e-mail." And he says "LOL." And this is where
Richard Ayvazyan is at the time that he is writing these
text messages. He is in Turks and Caicos on the beach in
the middle of a pandemic.
Iulia Zhadko. I'm sorry. He responds, "Good
afternoon -- afternoon, LOL." He then sends the Anton
Kudiomov e-mail address, and you have heard a lot about
that and who controls that account. Richard Ayvazyan is
the person who is e-mailing that e-mail address to Tamara
Dadyan.
And Tamara Dadyan says, "Reply to Olaf
e-mail." And, "Olaf got your e-mail but nothing."
And as you heard from Special Agent Clark, as
you see from the death certificate, the lawyer that
Richard Ayvazyan is talking about, Olaf Landsgaard, is
deceased. And he didn't die recently. He died years
ago. A year before his name was used in connection with
a real estate transaction to buy property in the name of
Anton Kudiomov, Olaf Landsgaard died.
There are additional text messages around this
time when he is in Turks and Caicos as well that continue
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 2:20-cr-00579-SVW Document 677 Filed 07/09/21 Page 84 of 133 Page ID
#:10813
85
to talk about the fraud. They are talking about Sabala
Construction. "What is the Sabala Construction phone?
The 760, who answers it? I called that number. It said
Sabala Construction."
Richard Ayvazyan writes, "I don't recognize
that number. We had a different one. I think you call
the actual owner."
They know that they are stealing this
identity. They know that there is an actual owner.
Tamara Dadyan thinks it is a joke, "LOL, I know. I
called. Some girl answered, LOL."
Richard Ayvazyan responds, "I got rid of
everything on Sabala."
Tamara says, "Well, I said I had the wrong
number, LOL. Something with everything so we can pick up
the phone."
And Richard has a solution. He says, "Put Top
Quality Contracting." And if you recall, that company
belongs to Mark Zindroski, who took the stand, and has
belonged to him for decades. That is not Richard
Ayvazyan's company. That is Mark Zindroski's company.
Now, you have heard a little bit about Lamps
Plus, and there is the suggestion that Lamps Plus, that
there was a purchase at a Lamps Plus store on
October 14th. And, that, therefore, it is impossible
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 2:20-cr-00579-SVW Document 677 Filed 07/09/21 Page 85 of 133 Page ID
#:10814
86
that Richard Ayvazyan is Iulia Zhadko or that he is using
that name.
If you look at the actual bank records, you
see here that that purchase was paid for using card
ending 3537. This is that card. It is in my hand. We
got it from Richard Ayvazyan. And we got it from him
when he came back through Miami International Airport and
was arrested on October 20th.
This card was in his possession. 3537. It
matches the number right there on the bank statement
because he is in control of the bank account, and he is
the one who made that purchase.
The last thing I will say on this is you
should really pay attention to these bank calls. They
tell you quite a bit. They tell you about state of mind
and they tell you about knowledge.
And I will end with this jail call from
Marietta Terabelian. She knows that they found the card.
She knows the charges. And she knows that there is
evidence of this crime. And what she says is that, "You
need to clean the house as much as you can." You need to
get rid of the evidence because they had been arrested.
"And you shouldn't say anything to anybody."
And that, members of the jury, that tells you
everything that you need to know about this crime and
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 2:20-cr-00579-SVW Document 677 Filed 07/09/21 Page 86 of 133 Page ID
#:10815
87
this conspiracy.
Now, after considering all of the evidence we
will ask you to return the verdict that we think is
consistent with that evidence, which is the verdict of
guilty on all counts.
Thank you.
THE COURT: Thank you. Which of the defendants
wishes to argue first?
MR. LITTRELL: We do, your Honor.
Let's see if I can make this work.
There we go.
Morning, folks. I haven't had a great look at
you during the trial, especially those of you behind us.
I am John Littrell. I speak for Marietta Terabelian.
I don't want to take up too much of your time.
We have taken up a lot of it already. But I do want to
address the government's allegations against
Ms. Terabelian. Something struck me that I feel like we
have to address right away.
Mr. Fenton says this is an assembly line of
fraud, and it was an interesting analogy to use because
an assembly line, like he said, requires a lot of
different people doing a lot of different things. Each
person has a job and role and it is essential to the
fraud.
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 2:20-cr-00579-SVW Document 677 Filed 07/09/21 Page 87 of 133 Page ID
#:10816
88
We didn't really see evidence of that in this
case. I am not even talking about Ms. Terabelian yet.
We didn't see evidence of the concept of an assembly
line. This is a fraud factory, and it is basically
located at the Weddington Street address, maybe the
Canoga Street apartment. And there is just no evidence
of any kind that Ms. Tarabelian individually had anything
to do with it.
Now, when he described this conspiracy and
everyone's roles, he was looking to find a role for Mary
Tarabelian. And that is what he has to do, because this
is a conspiracy. And if she is not a willful participant
in this conspiracy, if she doesn't have an active role,
then she is not guilty.
And so the role he picked for her was the role
of Victoria Kauichko. And I am going to talk a little
bit about who Victoria Kauichko is, but the overwhelming
evidence in this case shows that it is not Mary
Terabelian.
Before we get started, I want to briefly go
over how we make decisions in this case. One -- and
these are all in the jury instructions -- each defendant
has to be considered individually.
This is a conspiracy case and the prosecution
is going to try to lump everybody together. And they
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 2:20-cr-00579-SVW Document 677 Filed 07/09/21 Page 88 of 133 Page ID
#:10817
89
used a lot of buzz words during their opening about that,
about everyone working together and doing their part, but
you actually have to decide what Ms. Terabelian did, what
she knew and what she intended.
Two, you must presume all of the defendants to
be innocent, which means that you have to be skeptical of
what the prosecution says.
We all want to believe that prosecutors tell
the truth. We all want to believe that their story is
based on the actual evidence. I don't think that bears
out in this case.
Three, the standard that you are applying to
decide what are the facts and what's going to be your
verdict is proof beyond a reasonable doubt.
Now, I am going to talk a little bit about
what that means. Proof beyond a reasonable doubt is
proof that leaves you firmly convinced. It is a very,
very high standard of proof.
It is hard to illustrate really what it means.
The jury instructions talk a little bit about it. And it
is also very hard for us as jurors to really think in
that way. We make decisions all the time. We rely on
incomplete facts all the time to make decisions about
what we are going to do, even really important decisions.
Your favorite restaurant, you go to it ten
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 2:20-cr-00579-SVW Document 677 Filed 07/09/21 Page 89 of 133 Page ID
#:10818
90
times in a row. Every time it is good. It is reasonable
to conclude that when you go to it that 11th time, it is
going to be good. You don't go back in the kitchen to
see if the same cook is working or if they have had their
certificate updated. It is fair to assume and it is a
very reliable assumption that it is going to be good that
11th time.
That is not the way you can think about this
case. You have to check everything. You can't make any
assumptions, and you certainly can't assume that the
prosecutors are right.
And the best way to think about it is this.
Where there are two different conclusions that can be
reached based on the evidence, one that favors the
prosecution and the other that favors the defense, that
is the very definition of reasonable doubt.
Now, I am going to go through some of the
counts and the evidence in this case and talk about how
that --
THE COURT: The definition is the one I gave.
MR. LITTRELL: That is correct.
THE COURT: I mean, you can argue however you want
about the facts and it not amounting to reasonable doubt
or whatever or convert the meaning that it does amount to
reasonable doubt, but the instruction is the one I gave.
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 2:20-cr-00579-SVW Document 677 Filed 07/09/21 Page 90 of 133 Page ID
#:10819
91
That is the instruction you are to follow.
And you can massage and use the evidence -- both sides
can -- in any way you want to show that the evidence in
your view doesn't support that burden.
MR. LITTRELL: Very well. And I guess the most
straightforward way of saying it is reasonable doubt is a
doubt that is reasonable. That there is an explanation
of the facts that is different from the prosecution's and
it is reasonable, that is reasonable doubt.
So here is the verdict form. You are going to
get a verdict form that is much more detailed, but this
is sort of a work sheet for us to use.
Interestingly, Ms. Terabelian is charged in
nearly every count. Even though there is not really
evidence that she did anything in this case, she is
charged on all the counts. And that is sort of how
conspiracies work, or at least that is how they are
charged.
I am going to go through these
chronologically, essentially from left to right. Before
we get there, bank fraud just to sort of go over the
broad strokes of it, bank fraud is submitting a fake
application to a bank. You know, an application that has
got false information or false names but it is not
submitted for the purpose it is intended for.
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 2:20-cr-00579-SVW Document 677 Filed 07/09/21 Page 91 of 133 Page ID
#:10820
92
So when we get to a bank card, you have to
submit false information to a bank. Bank fraud applies
to people who apply for loans.
Wire fraud is essentially receiving money from
banks in response to those false applications for a loan.
THE COURT: Mr. Littrell, I am just informed from
the court reporter that you have to just slow down a bit.
MR. LITTRELL: I am so sorry.
THE COURT: Please continue. You don't have to
move any more quickly than you want to.
MR. LITTRELL: Thank you, your Honor.
So that is wire fraud. Receiving money from a
bank.
Aggravated identity theft, as I am going to
talk about in a moment, that is using or possessing the
identity of a real person in connection with a wire fraud
count. And what we are going to get to is that
Ms. Terabelian didn't commit any wire fraud counts, and
so she is not going to be guilty of aggravated identity
theft.
The government's case here is really based on
the notion of conspiracy. And the instructions you got I
think honestly are very confusing. They were read out
loud. You will have a copy of it. And I will get to
this later too.
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 2:20-cr-00579-SVW Document 677 Filed 07/09/21 Page 92 of 133 Page ID
#:10821
93
They do not mean that someone who knows that a
conspiracy is happening or does something that
inadvertently aids the conspiracy is guilty. Conspiracy
can sound like you can assume people are guilty, but that
is not what it means. That is not how it works.
We will get to that in a minute.
Let's start with bank fraud. There is no
doubt about who is responsible for submitting the fake
applications to the banks. I agree with the government
on this point. Pretty much the whole story is in
government's Exhibit 10, and that is the text exchange
between Rich New and Tammy.
Basically what that text chain is is a
play-by-play analysis of who is doing what when and it is
a guide to just about everything in the case.
What you won't see anywhere is any reference
to Mary Terabelian. In fact, what you see is two spouses
committing fraud and keeping their significant others out
of it. So I just encourage you to read this carefully.
So she is not guilty of bank fraud because she
didn't submit any applications to a bank. It is just as
simple as that.
Now, what about wire fraud. Wire fraud, the
way you can figure out who is responsible for wire fraud
is to look at the actual bank accounts that received the
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 2:20-cr-00579-SVW Document 677 Filed 07/09/21 Page 93 of 133 Page ID
#:10822
94
money. In this case, I put up a couple of exhibits, one
from Runyan Tax, one from Iulia Zhadko individually, and
the other are checks from a bank account associated with
Nazar Terabelian.
And here is what I am seeing. These are the
signatures associated with those accounts. So one thing
that I think you can reasonably infer is that Victoria
Kauichko, Iulia Zhadko and Nazar Terabelian for this
purpose are probably the same person, but in any case it
is not Mary Terabelian.
So that is why you have to find her not guilty
of all of the wire fraud counts.
Now, I left one blank. And that is because
there was one wire that went to Mary Terabelian's bank
account. If you remember, Ms. Robinson testified about
the flow of funds. And one of the things that you saw
and was pointed out to you is that Mary Terabelian,
although she is right here in the middle of the chart, is
different from almost everybody else.
It is a personal bank account signed by her,
no corporate entity associated with that bank account.
It is her personal bank account.
Now, the government says that Mary Terabelian
committed wire fraud when a wire came into her account on
June 17 of 2020. They have introduced no evidence at all
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 2:20-cr-00579-SVW Document 677 Filed 07/09/21 Page 94 of 133 Page ID
#:10823
95
that she asked for that wire, that she knew that wire got
there. No evidence at all.
And the reason I wanted to point this out is
that this essentially is the government's money
laundering case against Ms. Terabelian. It is
essentially the only evidence. And it also relies on a
wire going from Ms. Terabelian's bank account to the
purchase of this home.
And we will get to that in a minute.
That is it.
So when the witness was testifying and said
let's take a look at this bank account that is so
important -- again, that is Mary Terabelian's signature.
It was opened in 2018.
Now, you will have a chance to look at this
when you deliberate. It is government's Exhibit 89. But
what you will see is this is the bank account of a
stay-at-home mom. The purchases that are being made from
this bank account are Postmates, Uber, Restoration
Hardware, things that you buy if you are a stay-at-home
mom which is Ms. Terabelian is.
Now, the government says, but wait a minute.
On June 19th, a wire went into this bank account. And
also, the total of those wires if you can see sum up to
$577,000. That is a balance that is starkly in contrast
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 2:20-cr-00579-SVW Document 677 Filed 07/09/21 Page 95 of 133 Page ID
#:10824
96
with what you see in this account otherwise.
Then, a couple of days later, a wire goes
right back out of that account. Oh, look at that. Goes
right back out of that account for $565,000. Essentially
the money goes in, the money goes out.
Now, for Ms. Terabelian to be guilty of wire
fraud based on this wire that hit her account for three
days, she has to have known and willfully directed that
wire into the account and known and willfully directed
that wire out of the account.
There is just no evidence that she did that.
Now, we have missed -- now I am going to screw
this up.
Now, we have no obligation to produce evidence
or produce a defense at all. We don't have to explain
anything. But, you know, and keep in mind this proof
beyond a reasonable doubt. And the government hasn't
even come close for this bank statement.
But think about the context. This witness
admitted the way you control this bank account is with a
user name and a password. It is available online.
And she corrected herself. When the
government asked her who controls this bank account, I
objected. There was no foundation for that. The signer
does not control the bank account. The person who
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 2:20-cr-00579-SVW Document 677 Filed 07/09/21 Page 96 of 133 Page ID
#:10825
97
controls the bank account is the person with the user
name and password. And there is no evidence that that
was Mary Terabelian in this case.
And keep in mind, this is a case where Richard
Ayvazyan has been accused of controlling other people's
bank accounts, moving money through other people's bank
accounts.
Now, if you had to pick somebody who was more
likely to be the person that initiated these wires and
you had to choose between Mary Terabelian and Richard
Ayvazyan, I think the choice would be clear.
So she is not guilty of any of the wire fraud
counts.
Now, this is interesting. Aggravated identity
theft is an account that relates to a wire that went into
the Mod Interiors bank account. Mod interiors is the
company associated with Nazar Terabelian. That is Mary's
father.
Now, I was waiting for the government to show
us some evidence that Mary Terabelian had anything to do
with that. And they just had their chance and they just
presented it to you. And if you recall what he
presented, they presented a bunch of notes on Richard
Ayvazyan's phone with log-in information and all kinds of
stuff about Nazar Terabelian.
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 2:20-cr-00579-SVW Document 677 Filed 07/09/21 Page 97 of 133 Page ID
#:10826
98
If you look in the exhibits, you will also see
Nazar Terabelian credit cards and other information in
Richard Ayvazyan's possession. There is just nothing
like that in Mary Terabelian's possession.
So there is two alternatives for you to
consider. One, that five days after her father's death
and after she is grieving, she decides that she is going
to get into the PPP loan fraud business for the very
first time. That is a good time for her to get started.
Then she actually creates a bank account which
she then controls and commits wire fraud using her
father's stolen identity. That is the government's
theory.
The other is that it is her husband. The
person who had Nazar Terabelian's log-in information and
other notes in his phone, the person that has had his
credit cards, if you had to choose between either of
those alternatives, the choice would also be clear.
But again, the government didn't even argue
that she was responsible for it. So there is just
nothing for you to consider.
Now, they may come back and say, oh, well,
what we really meant to say is Mary Terabelian aided and
abetted her husband. And aiding and abetting is an
instruction that you are going to get.
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 2:20-cr-00579-SVW Document 677 Filed 07/09/21 Page 98 of 133 Page ID
#:10827
99
But aiding and abetting doesn't just mean
married to somebody. It means you actually have to help
a person do that. And I don't think Richard Ayvazyan
needs any help committing bank fraud and wire fraud.
You know, look, there is just no evidence that
she is responsible. But one thing I wanted to put up is
a bank account in Nazar Terabelian's name, and the signer
in this case is Rich Ayvazyan.
So if the government is correct that the
signer of a bank account controls it, again, Richard
Ayvazyan is the prime suspect.
And so you don't -- we haven't really gotten
into reasonable doubt that much because the choices have
been relatively clear. You cannot convict somebody based
on a complete lack of evidence. And that is what we have
in this case.
And so the government's case, as it said in
the outset, really turns on conspiracy.
Now, this might take up a lot of your time
when you deliberate, reading those instructions, trying
to understand them, but here are the key things that you
can consider. I am hoping that we will make it somewhat
easier for you.
No matter what else those instructions say, to
be guilty of conspiracy you have to willfully participate
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 2:20-cr-00579-SVW Document 677 Filed 07/09/21 Page 99 of 133 Page ID
#:10828
100
in a plan with the intent to advance the purpose of the
conspiracy. In this case the purpose of the conspiracy
is stealing PPP loan funds, stealing EIDL loan funds.
Now, if there is no evidence that Mary
Terabelian participated in any other way, then there is
no evidence that she is willfully participating in that
scheme.
You are also going to get an instruction that
if you think she is participating in some other scheme or
that she is guilty of something else, that does not allow
you to find her guilty of this conspiracy. And this
conspiracy is about PPP and EIDL loan funds.
The other is somebody who knows that a
conspiracy is happening -- or I'm sorry, who does not
know, but happens to act in a way that furthers that
conspiracy, is not guilty.
For example, if you don't know the money is
going through your bank account -- well, actually that
kind of assumes that she at least sent a wire, but in
this case there is just no evidence she did that either.
But had she done that, she still wouldn't be guilty if
she didn't know of the conspiracy.
I think the one that really sticks out and I
think is most important here is the last. A person does
not become a conspirator merely by associating with one
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 2:20-cr-00579-SVW Document 677 Filed 07/09/21 Page 100 of 133 Page ID
#:10829
101
or more persons who are conspirators, nor merely by
knowing that a conspiracy exists.
And I think that if you take the government's
presentation and its evidence in the light most favorable
to them, you indulge presumptions for them, which again,
you can not do. At most it would show that -- the
government could at least argue that at some point she
knew.
The government could never argue and there is
no evidence to support the idea that she participated in
this conspiracy.
So here is what the case comes down to for
conspiracy. Three things.
This card found in Ms. Terabelian's carry-on
luggage in its own compartment.
Two, the jail call, which the government has
made sort of the core of its case.
And, three, a piece of paper found in her
phone.
Now, let's get to the bottom of it, because I
was prepared to -- you know, basically what the
government has done is they have said the reason
Ms. Terabelian is guilty is because she is Victoria
Kauichko. And that is just -- that is a concept that
they can't possibly prove.
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 2:20-cr-00579-SVW Document 677 Filed 07/09/21 Page 101 of 133 Page ID
#:10830
102
As I have said, the signatures of Victoria
Kauichko and Iulia Zhadko were remarkably similar. So
one thing you can infer about who is Victoria Kauichko is
that they may very well be the same person. And if they
are the same person, it is not Mary Terabelian.
Now, Victoria Kauichko's checks with her
distinctive signature are found at the -- I believe that
is from Canoga -- from the Weddington house. Then these
are notes with Fiber One Media found at the Canoga
apartment.
Mary Terabelian didn't live at the Canoga
apartment. The Weddington Street address is the address
associated with Art and Tamara.
Now, the government says, well, guess what.
She must be Victoria Kauichko because this credit card
that we are going to talk about in a minute, that this
debit was found in her luggage in October 2020.
But here is the problem. The same credit card
was found in Richard Ayvazyan's phone along with lots of
other credit cards associated with Victoria Kauichko,
along with tons of other evidence, including the evidence
in the text messages between him and Tammy Dadyan.
So the idea that Mary Terabelian is Victoria
Kauichko is not only false, it is improbable. It is
impossible basically. And you can hold it against the
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 2:20-cr-00579-SVW Document 677 Filed 07/09/21 Page 102 of 133 Page ID
#:10831
103
government that they are asking you to believe that she
is Victoria Kauichko.
If they are asking you to believe that Mary
Terabelian is Victoria Kauichko, you have every reason to
doubt everything else that they say.
Now, one thing we do know about Victoria
Kauichko, and this is sort of at the core of the
government's argument. Victoria Kauichko does make
purchases, and a lot of the time those purchases benefit
Mary Terabelian.
What do we make of that? I think that
Victoria Kauichko cares very much about Mary Terabelian.
I think that Victoria Kauichko may love her family too.
You will see that purchases are -- you know, again, these
are purchases by Victoria Kauichko that certainly benefit
Richard Ayvazyan, and not Mary Terabelian.
The one on the right is the text messages
between Richard Ayvazyan and the person at Gentleman
Timepieces. And he says, and the government emphasizes,
I want you to ship these watches to my wife, and my wife
is Victoria Kauichko.
And now for the first time in a fraud cause
where they are alleging that Mr. Ayvazian is submitting
false information, now they are saying, no, this time he
is right. This time he really means Victoria Kauichko is
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 2:20-cr-00579-SVW Document 677 Filed 07/09/21 Page 103 of 133 Page ID
#:10832
104
his wife, and this is evidence that that means it must be
Mary Terabelian.
That is just nonsense. It is nonsense. And
you have every right to judge them for even asking you to
believe that.
Again, Victoria Kauichko pays for Nazar
Terabelian's funeral. I'm sorry. This is Iulia Zhadko
buys a house and next thing you know Mary Terabelian's
mom is either living there or at least paying the
utilities.
What this says about Victoria Kauichko is this
Victoria Kauichko loves Mary Terabelian, wants to protect
her. And that is consistent with the other evidence that
we have seen.
You have heard Artur Ayvazian testify that his
big brother had always looked out for him and supported
him financially. And the same is true for Rich Ayvazyan
and Mary Terabelian.
That does not make her guilty of conspiracy
because he is doing it by committing fraud.
Now, let's get to this debit card. Now,
again, the core of the government's case, one of three
pieces of evidence that directly ties in Mary Terabelian.
And rather than actually tell you what happened, I am
going to show you the video.
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 2:20-cr-00579-SVW Document 677 Filed 07/09/21 Page 104 of 133 Page ID
#:10833
105
I am going to see if I can do it without
screwing it up completely.
So this is Mary Terabelian. You are going to
see here, this card is pulled out. She points to the
door. She nods her head. He confronts her again with
the card. Again she points to the door. Who is outside
that door? Richard Ayvazyan.
Now, she is not panicking. She is not
freaking out. She is just making a very straightforward
statement to that officer, this is not my card. Now,
that is the moment where the government had an obligation
to find out whether she was telling the truth.
And she had an opportunity to do that. And
the way they would do that is fingerprint the card,
investigate it. There is just no evidence they did any
of that.
So they have lost the right, for many reasons,
to tell you that her possession of this card in its own
compartment in her carry-on luggage, to which both Mary
Terabelian and Richard Ayvazyan had access, the
government has lost the right to be able to argue that
that means that she is Victoria Kauichko.
And make no mistake, that is what they are
saying. They are saying because she had this card on
October 19th, 2020, two months after this so-called
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 2:20-cr-00579-SVW Document 677 Filed 07/09/21 Page 105 of 133 Page ID
#:10834
106
conspiracy ended, that that means that she must be
Victoria Kauichko. She must know what Victoria Kauichko
knows. That means that she submitted the loans, that
Victoria Kauichko's name is on it. That is just
nonsense.
Now, we get to the jail calls. And you heard
that you cannot -- you know, as we learned, Mary
Terabelian went to jail because of that credit card. So
she is confronted with this credit card. She denies that
it is hers, and the next thing you know she is in jail.
And she makes a call and she says a couple of
things that are absolutely true. We were caught. You
know, the interpreters took care to note when she said
"caught," it is capable of multiple meanings. It could
mean apprehended, arrested, detained. And he was careful
to do that because he didn't want to give a misleading
impression of what she meant.
They found a card, that is true. She knows
she is in jail because they found a credit card in
somebody's name that doesn't belong to here.
You know the charges. Now, the government
says, ah, this is it. You know the charges. That means
that she is signaling you know the charges because you
know that I am a criminal and you know what I have done
and I must be guilty.
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 2:20-cr-00579-SVW Document 677 Filed 07/09/21 Page 106 of 133 Page ID
#:10835
107
Again, nonsense. She is in jail. She knows
the charges. Of course she has been given opportunities
to make other calls and tell the family. So if she is
informed of the charges and she tells her family what
they are, then of course she says "you know the charges."
She is asking for help. So it it doesn't tell us
anything.
"Please take care of the kids. Maybe you can
take them to mom's and they can stay over there until we
figure out what is going on."
"Clean the house." Clean the house is the
most difficult piece of evidence for us to confront in
this case. It makes her look guilty.
And I know why the government focused on it.
I know why they are building their case around it. It is
the biggest problem we have.
Now, you heard me cross-examine that
interpreter. And I tried to elicit some evidence that
really clean the house could have multiple different
meanings. I tried to speak Armenian. We all saw how
that went.
But at the end of the day it is reasonable for
you to conclude that this means exactly what the
government says it means.
In October 20th of 2020, two months after the
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 2:20-cr-00579-SVW Document 677 Filed 07/09/21 Page 107 of 133 Page ID
#:10836
108
conspiracy is over and after she is caught with the
credit card in somebody else's name and she finds herself
in jail and she is separated from her kids and she
worries about them, she panics.
Maybe she is worried that they will find some
other evidence of stolen credit cards in her house. That
is a reasonable conclusion.
But here is the problem. It doesn't tell you
what she knew about this actual conspiracy. It shows
that she is responding to the fact that a credit card was
found in her luggage and she is panicked.
Now, just as Richard Ayvazyan protects her, it
is also reasonable to infer that she may be trying to
protect him in that moment. That doesn't make her guilty
of the conspiracy that is charged to her. That makes her
guilty of very bad judgment. That is not a reason to
convict her in this case.
Now, this is an instruction you are going to
get. You are here only to determine whether defendants
are guilty or not guilty of the charges in the
indictment.
The defendants are not on trial for any
conduct or offense that is not charged in the indictment.
What that means is that if you think that she panicked
and she actually tried to get somebody to hide evidence
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 2:20-cr-00579-SVW Document 677 Filed 07/09/21 Page 108 of 133 Page ID
#:10837
109
in this case, that does not make her guilty of this
conspiracy. That makes her guilty of being a panicked,
concerned mom.
Now, here is the last one. What I view as a
desperate attempt to find some evidence to prove that
Mary Terabelian is Victoria Kauichko, which remember, is
the government's theory. They seize her phone.
Now, they seize Richard Ayvazyan's phone, and
they find all kinds of stuff on there. On Mary
Terabelian's phone, we see from this image there are
44,000 images. There are tons of text messages, tons of
passwords. There is a vast trove of evidence on this
phone. And they are looking for something to pin Mary
Terabelian to this conspiracy.
What they find is one image that was taken on
October 28th, 2018, two-and-a-half years before this
conspiracy began.
Now, the government says these are all fake
companies, but they have not established that this was a
fake company in 2018. But most importantly, they haven't
established how that image got on Mary Terabelian's
phone, whether she ever saw it, who put it there and what
it means.
You cannot convict her based on an image that
was taken on 2018 on a different phone and finding its
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 2:20-cr-00579-SVW Document 677 Filed 07/09/21 Page 109 of 133 Page ID
#:10838
110
way into the thousands of images on her current phone.
We heard evidence that images are stored
chronologically. Images from two and a half years ago,
you would have to scroll through images for days just to
even find it if you knew what you were looking for.
So that just isn't enough to convict her. But
think about this, and think about the caliber and quality
of the evidence they have presented against Mary
Terabelian, what it means, what they are asking you to
infer from it.
They are asking you to infer that she is a
willful, active participant in this conspiracy because of
these three pieces of evidence.
And it is just not enough.
It comes down to this card, which was never
fingerprinted, and in a single compartment in her
carry-on luggage, a jail call that happened two months
after the conspiracy was over, and an image on her phone
that was taken two-and-a-half years before.
It is just not enough.
Mary Terabelian is here because she is married
to Richard Ayvazyan. And I get it. The government gave
a long introduction to its closing about how egregious
this case is.
These are loans that were meant for small
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 2:20-cr-00579-SVW Document 677 Filed 07/09/21 Page 110 of 133 Page ID
#:10839
111
businesses in the middle of a pandemic. There was a big
conspiracy. There was a lot of people involved.
I understand the government's urge to make
this case as big as it can be and involve as many people
as they can, but that doesn't make Mary Terabelian
guilty.
So I would ask you to please carefully follow
your instructions and talk to each other, remembering the
burden of proof beyond a reasonable doubt, what that
means is that if you have a reasonable doubt, it might be
different from somebody else's. The whole purpose of
deliberating is to talk it through.
Some of you may think a piece of evidence
means something different from somebody else. Talk about
it. And the instructions say and you should take
seriously that if it causes to you change your
perspective, you should do it.
But one thing I have noticed is that if jurors
are deliberating and they see things in a different way,
in a sense that is reasonable doubt right there, the fact
that somebody sees something differently from the way you
see it. That itself can be reasonable doubt.
Now, you also will get an instruction that
Mary Terabelian didn't testify, didn't have to testify,
and that you can't hold that against her. That is a very
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 2:20-cr-00579-SVW Document 677 Filed 07/09/21 Page 111 of 133 Page ID
#:10840
112
difficult instruction to follow.
It is natural for us to assume that a
defendant who is innocent would get up and tell you,
would testify. That is natural. But in a case like
this, with evidence like this, why would a defendant take
the stand?
It is a dangerous place to be. The
prosecutors can cross-examine the defendant. Then you
look at that defendant and you decide you don't like the
way she looks. You don't like what she is wearing. It
places her at tremendous risk.
And I say this only to say you cannot hold
against her the fact that she did not testify. You
cannot draw any assumptions from it.
And I am particularly concerned about this in
this case because one defendant did testify. She is here
because she is married to Richard Ayvazyan, and really no
other reason.
So I respectfully ask you to find her not
guilty of all counts.
THE COURT: Okay. I think it is almost -- what
time is that?
Is it five to 12:00 -- did I read that right?
I think it is probably best to take the lunch
break and then we will come back at 1 o'clock and we will
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 2:20-cr-00579-SVW Document 677 Filed 07/09/21 Page 112 of 133 Page ID
#:10841
113
hear from the counsel for the other defendants. Then the
government has a chance to make a rebuttal.
So, again, don't talk about the case to each
other, and we will see you back promptly at 1:00 o'clock.
(Luncheon recess from 11:56 a.m. to 1:00 p.m.)
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 2:20-cr-00579-SVW Document 677 Filed 07/09/21 Page 113 of 133 Page ID
#:10842
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 25, 2021
/s/ Katie Thibodeaux, CSR No. 9858, RPR, CRR
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 2:20-cr-00579-SVW Document 677 Filed 07/09/21 Page 114 of 133 Page ID
#:10843
MR. FENTON: [4] 34/8 78/13
78/16 79/11
MR. JOHNSON: [2] 8/13 8/22
MR. LITTRELL: [8] 8/2 8/5
9/1 87/8 90/20 91/4 92/7
92/10
MR. MESEREAU: [3] 10/9
10/18 10/22
MR. PAETTY: [3] 5/15 5/21
5/25
MR. RAM: [7] 8/24 9/2 9/6
9/8 9/24 10/1 79/4
MS. AHN: [8] 6/5 6/7 6/20
7/6 7/9 7/12 7/15 9/14
THE CLERK: [1] 6/3
THE COURT: [34] 5/7 5/19
5/23 6/1 6/6 6/18 7/5 7/8
7/10 7/13 8/1 8/4 8/12 8/20
8/23 9/5 9/7 9/22 9/25 10/3
10/6 10/10 10/19 11/1 78/10
78/14 78/19 79/9 87/6 90/19
90/21 92/5 92/8 112/20
$
$10,000 [2] 30/2 42/22
$157,500 [2] 64/20 76/9
$22,000 [1] 82/16
$25,000 [1] 67/18
$3.25 [1] 72/6
$3.25 million [1] 72/6
$30,000 [1] 64/3
$384,150 [1] 79/14
$47,000 [1] 82/11
$50,000 [1] 38/15
$565,000 [1] 96/4
$577,000 [1] 95/25
$73,500 [1] 59/25
'
'knowing [1] 6/23
-
-and [2] 2/5 2/8
/
/s [1] 114/12
1
10 [5] 23/8 41/25 41/25 45/3
93/11
10,000 [2] 42/25 42/25
10036 [1] 2/18
10100 [1] 3/15
1028 [1] 31/24
1099s [2] 63/20 63/21
10th [1] 83/16
11 [4] 32/25 75/2 75/3 76/10
1114 [1] 2/17
115 [4] 54/8 71/7 76/6 76/15
116 [3] 43/14 50/9 62/9
117 [1] 7/17
118 [1] 7/17
119 [1] 7/17
11:06 [1] 79/7
11:14 [1] 79/7
11:56 [1] 113/5
11th [2] 90/2 90/7
12 [7] 22/24 23/8 25/24 26/2
33/2 42/15 51/20
120 [1] 7/17
12:00 [1] 112/23
13 [3] 24/18 26/1 26/2
130 [1] 64/2
1330 [1] 2/23
1343 [5] 19/7 22/25 23/11
28/19 30/6
1344 [5] 19/8 24/20 25/5
28/20 30/6
1349 [2] 28/17 30/5
14 [1] 32/23
1400 [1] 2/10
14th [1] 85/25
15 [1] 78/14
157,000 [1] 60/2
17 [1] 94/25
17450 [2] 55/24 60/11
18 [17] 6/15 19/7 19/9 23/11
24/20 25/6 27/11 27/21 27/25
28/11 28/17 28/19 28/20
29/19 30/5 31/25 69/18
1900 [1] 2/15
1935 [1] 3/12
1956 [7] 6/10 6/16 27/11
27/21 28/11 30/15 30/19
1957 [2] 27/24 29/19
19th [2] 95/23 105/25
1:00 [1] 113/5
1:00 o'clock [1] 113/4
1st [1] 1/22
2
20 [3] 24/19 26/1 26/2
20-579 [1] 1/8
2000 [1] 52/21
20036 [1] 2/23
2018 [4] 95/14 109/16 109/20
109/25
2019 [2] 64/1 64/2
2020 [13] 19/14 19/14 27/17
27/18 49/22 64/2 69/18 82/6
82/8 94/25 102/17 105/25
107/25
2021 [3] 1/17 5/1 114/10
20530 [1] 2/10
20th [3] 83/16 86/8 107/25
21 [5] 28/9 31/23 32/12
32/22 68/13
216 [1] 3/13
21st [1] 53/18
22 [7] 28/9 31/23 32/2 32/13
32/24 33/1 69/7
22nd [1] 82/12
24 [8] 1/17 5/1 23/3 32/4
46/23 47/2 61/5 70/3
25 [5] 24/17 67/5 67/12
67/12 114/10
26 [4] 23/3 27/9 71/4 71/4
27 [3] 30/13 30/22 31/1
28 [11] 6/9 18/9 27/22 30/14
30/18 30/21 30/25 31/3 31/15
81/1 114/4
28th [1] 109/16
29 [2] 28/1 31/3
3
3.25 million-dollar [4]
37/16 54/18 58/16 64/13
30 [4] 30/19 30/20 59/8
69/25
300 [1] 3/16
312 [1] 2/6
32 [6] 18/9 30/15 30/22 31/2
31/15 81/1
34 [1] 4/10
35 [4] 6/9 9/8 9/8 9/17
35 percent [3] 59/4 59/4
59/5
350 [2] 1/22 3/5
3537 [2] 86/5 86/9
37 [2] 9/10 9/18
38,750 [1] 59/13
3900 [1] 2/20
4
409 [1] 3/20
41 [1] 45/4
4170 [3] 42/4 47/19 68/22
4311 [1] 1/22
44,000 [1] 109/11
5
50 [1] 5/10
50A/B [1] 46/10
50B [2] 5/17 5/18
50D/E [1] 46/10
50E [2] 5/17 5/18
5141 [4] 47/16 48/1 52/22
53/22
579 [1] 1/8
57A [1] 45/21
58,125 [1] 59/14
5th [3] 2/14 3/8 52/4
6
60 [4] 38/1 38/5 69/25 70/1
601 [1] 3/8
6150 [2] 52/25 69/5
633 [1] 2/14
651 [1] 3/21
7
720 [1] 3/8
73,500 [1] 59/13
753 [1] 114/4
760 [1] 85/3
8
87 [1] 4/11
89 [1] 95/16
9
90012 [2] 1/23 2/7
90067 [1] 3/16
90071 [2] 2/15 3/9
90277 [1] 3/21
903 [1] 3/5
91208 [1] 3/13
92673 [1] 3/6
940s [3] 51/3 62/10 65/2
94105 [1] 2/21
941s [1] 51/4
95,000 [1] 58/21
9858 [2] 1/21 114/12
9:00 [1] 5/2
9:00 o'clock [1] 6/4
9:05 [1] 10/24
9:18 [1] 10/24
9th [1] 83/10
A
a.m [6] 1/16 5/2 10/24 10/24
79/7 113/5
A1 [2] 6/16 6/16
abet [1] 26/7
abetted [3] 26/6 27/8 98/24
abetting [6] 8/15 25/25
26/10 80/23 98/24 99/1
ability [1] 15/10
able [2] 41/23 105/21
about [89]
above [1] 114/7
above-entitled [1] 114/7
absolutely [1] 106/12
Acacius [1] 76/19
accept [1] 16/12
access [3] 81/14 81/25
105/20
accidentally [1] 34/1
accomplish [2] 19/19 28/5
according [1] 54/24
account [52] 15/9 44/5 54/10
54/13 54/14 65/6 65/9 65/9
66/10 66/11 81/11 81/14
Case 2:20-cr-00579-SVW Document 677 Filed 07/09/21 Page 115 of 133 Page ID
#:10844
A
account... [40] 81/15 82/11
82/13 82/14 82/17 82/17
82/18 82/21 82/23 83/10
83/12 84/12 86/11 94/3 94/15
94/20 94/21 94/22 94/24 95/7
95/12 95/17 95/19 95/23 96/1
96/3 96/4 96/7 96/9 96/10
96/20 96/23 96/25 97/1 97/15
97/16 98/10 99/7 99/10
100/18
accounts [13] 35/6 37/11
69/16 72/2 72/14 82/1 82/1
82/3 82/20 93/25 94/6 97/6
97/7
accused [1] 97/5
act [9] 18/5 18/8 20/19 26/6
31/16 40/5 40/6 61/3 100/15
acted [6] 20/4 23/22 25/19
26/17 26/19 27/1
actions [1] 22/2
active [2] 88/13 110/12
actively [1] 27/4
activities [1] 29/5
activity [10] 6/18 6/19 6/25
7/3 9/12 27/24 28/23 29/8
29/11 29/18
acts [2] 26/6 27/3
actual [8] 70/24 80/13 85/7
85/9 86/3 89/10 93/25 108/9
actually [16] 24/15 27/7
40/11 41/5 48/5 60/5 61/17
67/4 80/18 81/18 89/3 98/10
99/2 100/18 104/24 108/25
addition [4] 12/12 14/4
58/15 70/13
additional [7] 66/22 71/19
74/1 79/18 81/6 83/4 84/24
address [22] 47/14 47/14
47/15 47/22 48/1 48/1 53/6
60/8 60/10 60/11 60/18 60/19
64/24 71/1 81/20 84/11 84/13
87/17 87/19 88/5 102/12
102/12
addresses [2] 53/10 69/16
admitted [4] 17/18 19/1
38/10 96/20
advance [4] 20/13 27/5 42/23
100/1
advised [1] 34/1
affect [1] 29/5
affecting [1] 30/10
after [17] 12/24 13/3 33/19
37/11 69/11 69/21 77/9 79/5
81/2 82/9 87/2 98/6 98/7
105/25 107/25 108/1 110/18
afternoon [2] 84/10 84/10
again [27] 6/13 29/14 33/4
38/6 41/15 43/15 45/14 49/5
50/7 50/10 51/11 57/10 60/13
62/8 65/2 71/17 95/13 98/19
99/10 101/5 103/14 104/6
104/22 105/5 105/6 107/1
113/3
against [11] 17/3 17/6 34/13
43/9 62/18 87/17 95/5 102/25
110/8 111/25 112/13
agencies [1] 74/11
agent [4] 7/23 56/1 83/7
84/17
aggravated [8] 31/23 32/6
48/11 68/11 69/7 92/14 92/19
97/14
ago [2] 84/21 110/3
agree [5] 7/21 7/24 8/2
11/11 93/9
agreed [7] 13/10 17/13 19/24
20/2 20/9 21/10 28/2
agreeing [2] 20/8 28/1
agreement [6] 19/15 19/21
19/23 20/1 27/18 36/18
ah [1] 106/22
ahead [1] 83/23
AHN [1] 2/5
aid [1] 26/7
aided [4] 26/6 26/14 27/8
98/23
aiding [6] 8/15 25/25 26/10
80/23 98/24 99/1
aids [1] 93/3
airport [8] 46/4 46/9 48/21
51/25 52/3 57/23 81/13 86/7
al [1] 1/9
Alexander [2] 74/6 77/21
all [74]
allegations [1] 87/17
alleged [5] 18/17 18/22 32/6
56/12 81/8
allegedly [1] 56/13
alleges [2] 80/7 80/16
alleging [1] 103/23
allow [6] 10/9 10/11 11/17
41/9 41/10 100/10
allowed [1] 40/21
allows [2] 67/11 67/12
Allstate [2] 65/1 74/24
almost [2] 94/19 112/21
alone [2] 68/20 75/12
along [6] 8/8 56/18 68/19
81/21 102/19 102/21
Alpha [1] 3/12
already [5] 8/1 44/5 77/3
80/24 87/16
also [55] 8/6 8/14 11/9
11/17 16/2 22/5 24/4 26/4
31/18 35/9 38/12 39/7 40/23
41/7 41/10 41/18 42/6 44/1
45/6 46/1 47/22 49/14 52/17
52/24 53/11 53/21 54/1 54/6
56/14 56/19 57/7 61/6 62/2
63/24 71/6 72/18 72/20 72/22
73/7 73/10 73/11 75/12 75/22
77/1 80/3 81/16 81/21 89/21
95/6 95/24 98/1 98/18 100/8
108/13 111/23
alternatives [2] 98/5 98/18
although [4] 13/17 17/21
18/19 94/18
always [1] 104/16
am [24] 10/8 23/1 25/24
30/16 31/5 34/1 59/24 83/23
87/14 88/2 88/16 89/15 90/17
91/19 92/6 92/8 92/14 94/5
96/12 99/22 104/24 105/1
106/24 112/15
Amanecer [1] 3/5
amendment [1] 8/10
America [3] 1/6 2/3 44/15
Americas [1] 2/17
Ameritrade [1] 82/14
amongst [3] 51/6 66/16 66/17
amount [2] 81/24 90/24
amounting [1] 90/23
analogy [1] 87/21
analysis [1] 93/14
ancestry [1] 11/15
anchor [1] 10/22
ANGELES [7] 1/14 1/23 2/7
2/15 3/9 3/16 5/1
Anna [18] 32/16 50/2 56/11
56/21 57/2 60/12 60/14 60/25
61/8 70/3 70/4 70/19 70/24
73/10 73/12 74/24 77/11
77/11
announced [1] 78/21
announcement [1] 42/16
another [17] 8/7 14/15 20/5
32/11 33/4 33/6 49/6 50/4
50/16 53/8 54/1 59/10 59/11
67/13 68/7 71/22 82/12
answer [1] 13/18
answered [1] 85/11
answers [1] 85/3
Anthony [2] 37/21 52/11
Anton [4] 71/19 77/19 84/10
84/23
any [43] 8/17 8/18 11/14
12/4 12/13 13/9 13/10 14/2
14/4 14/17 14/20 14/24 15/2
15/8 15/15 15/16 15/21 17/1
17/7 17/7 17/8 17/9 18/6
26/3 29/6 31/18 72/8 73/18
79/3 88/7 90/9 91/3 92/10
92/18 93/16 93/21 94/9 97/12
99/4 100/5 105/15 108/22
112/14
anybody [2] 65/20 86/23
anymore [3] 63/5 63/10 76/20
anyone [2] 55/22 68/4
anything [11] 12/4 14/6 16/9
55/22 76/20 86/23 88/7 91/15
96/16 97/20 107/7
anyway [1] 77/23
anywhere [1] 93/16
apart [2] 80/9 82/15
apartment [12] 52/25 53/2
53/3 53/10 57/19 69/6 71/21
72/18 72/19 88/6 102/10
102/12
APPEARANCES [2] 2/1 3/1
appears [1] 6/8
application [23] 40/8 40/9
40/11 40/13 41/22 51/16
60/20 64/19 64/20 64/23
68/16 69/13 69/19 71/2 75/1
75/7 75/11 75/22 77/4 77/25
80/13 91/23 91/23
applications [32] 34/24
34/25 35/5 37/8 37/9 39/13
40/4 49/2 50/20 51/5 51/8
53/5 55/13 56/7 56/10 56/14
56/15 58/3 60/15 61/11 63/12
70/19 74/13 75/25 76/11
76/17 79/22 80/2 80/17 92/5
93/9 93/21
applied [4] 49/2 49/6 49/17
50/10
applies [7] 11/4 17/12 37/13
37/14 60/11 80/25 92/2
apply [16] 8/16 8/18 8/20
11/9 17/10 25/23 26/1 26/3
39/10 39/20 46/22 48/24
56/22 57/17 82/1 92/3
applying [5] 49/13 50/8
56/13 61/11 89/12
appreciate [1] 8/15
apprehended [2] 54/25 106/15
approving [1] 46/22
apps [1] 46/25
are [216]
aren't [1] 66/16
argue [7] 79/3 87/8 90/22
98/19 101/7 101/9 105/21
argument [5] 8/14 10/16
78/23 79/10 103/8
arguments [6] 4/9 13/16
13/22 31/6 33/20 33/24
arise [1] 12/21
Armenian [4] 17/16 17/21
61/22 107/20
Armin [3] 35/21 72/13 73/14
around [6] 18/18 27/16 27/17
49/13 84/24 107/15
arrested [7] 46/8 81/2 82/9
83/3 86/8 86/22 106/15
arriving [1] 14/23
Case 2:20-cr-00579-SVW Document 677 Filed 07/09/21 Page 116 of 133 Page ID
#:10845
A
Art [8] 58/21 58/22 59/3
59/9 59/22 59/25 67/14
102/13
Arthur [13] 56/20 58/14
58/19 60/3 60/10 60/18 60/23
61/14 61/24 62/11 62/12
63/10 64/25
Arthur's [7] 60/7 61/13
61/18 61/24 61/25 62/3 70/19
ARTUR [25] 3/11 32/3 35/17
36/6 37/7 38/10 39/12 39/19
45/7 45/22 55/23 55/24 56/11
56/16 57/5 57/14 58/5 59/8
70/3 70/10 70/20 71/2 72/21
74/25 104/15
Artur's [1] 55/15
as [103]
Ashwin [1] 2/13
ask [8] 36/24 38/18 40/2
78/11 84/3 87/3 111/7 112/19
asked [7] 47/4 62/16 62/19
63/20 73/25 95/1 96/23
asking [7] 61/18 103/1 103/3
104/4 107/6 110/9 110/11
asks [2] 59/21 83/13
aspect [1] 78/25
ass [1] 44/12
assembly [13] 34/22 39/6
39/21 44/19 50/18 50/18
55/11 56/6 62/4 76/4 87/20
87/22 88/3
assist [2] 23/9 24/24
associated [7] 26/22 94/3
94/6 94/21 97/17 102/13
102/20
associates [1] 35/19
associating [2] 20/23 100/25
assume [4] 90/5 90/10 93/4
112/2
assumed [1] 39/9
assumes [1] 100/19
assumption [1] 90/6
assumptions [2] 90/10 112/14
attempt [2] 24/1 109/5
attention [3] 45/1 80/21
86/14
attitudes [1] 11/20
attorney [2] 83/25 84/2
ATTORNEY'S [1] 2/4
August [2] 19/14 82/6
August 2020 [2] 19/14 82/6
AUSA [2] 2/5 2/5
authority [1] 32/10
Auto [4] 51/17 75/24 76/8
77/18
automated [1] 43/3
available [3] 11/5 44/20
96/21
Avakian [1] 57/4
Avenue [7] 2/10 2/17 2/23
47/17 52/22 52/25 53/22
await [1] 33/18
awaiting [1] 81/7
awareness [1] 11/22
away [3] 49/11 63/3 87/19
Ayvazian [20] 32/3 35/17
36/6 37/7 38/10 39/12 39/19
45/7 55/24 57/5 58/5 59/8
60/10 62/11 62/12 70/3 70/10
82/9 103/23 104/15
Ayvazian's [9] 45/22 55/23
56/11 56/16 57/14 60/18
70/20 71/3 74/25
Ayvazyan [82]
Ayvazyan's [15] 18/11 35/19
48/20 49/15 49/25 64/13
68/24 69/9 76/23 81/13 85/21
97/24 98/3 102/19 109/8
B
back [24] 7/24 39/23 42/4
42/5 43/24 46/4 49/3 53/10
57/7 57/22 60/8 60/18 66/23
69/8 70/9 82/21 82/23 86/7
90/3 96/3 96/4 98/22 112/25
113/4
bad [1] 108/16
bag [1] 44/9
bail [3] 18/5 18/11 31/16
balance [1] 95/25
bandied [1] 68/7
bank [89]
banks [3] 43/23 92/5 93/9
based [8] 12/20 12/20 89/10
90/14 92/21 96/7 99/14
109/24
basically [5] 82/4 88/4
93/13 101/21 102/25
be [85]
beach [2] 3/21 84/7
bear [1] 15/21
bearing [1] 18/6
bears [2] 39/3 89/10
became [3] 19/17 28/3 44/20
because [56] 8/10 8/18 16/5
43/10 43/16 44/2 48/10 51/7
52/6 53/2 55/7 55/9 55/25
56/1 60/21 63/3 63/14 63/16
64/19 65/3 65/17 65/24 67/18
67/19 68/17 70/4 70/24 72/11
72/24 73/8 73/23 74/8 76/3
78/2 78/24 81/17 86/11 86/22
87/21 88/11 93/20 94/13
99/13 101/20 101/23 102/15
104/20 105/24 106/8 106/16
106/19 106/23 110/12 110/21
112/16 112/17
become [4] 20/21 20/22 21/4
100/25
becomes [1] 20/11
been [13] 17/4 17/14 17/18
18/25 22/20 24/10 24/12 63/7
79/6 86/22 97/5 99/14 107/2
before [13] 26/19 33/20
34/17 34/17 36/24 52/23
53/24 82/22 84/21 88/20
91/20 109/16 110/19
began [1] 109/17
begin [2] 33/20 34/7
beginning [3] 11/24 19/13
27/16
BEHALF [1] 2/3
behind [8] 36/2 36/2 37/2
37/2 64/8 64/9 72/8 87/13
being [4] 38/21 80/12 95/18
109/2
beliefs [1] 11/14
believability [1] 15/22
believable [1] 16/16
believe [12] 15/5 15/6 15/6
16/9 16/21 21/20 89/8 89/9
102/7 103/1 103/3 104/5
belong [3] 52/1 66/20 106/20
belonged [2] 32/18 85/20
belonging [1] 46/2
belongs [2] 60/5 85/19
below [2] 48/2 66/13
benefit [2] 103/9 103/15
benefits [1] 21/20
best [3] 44/2 90/12 112/24
between [18] 14/18 19/15
27/18 42/2 45/2 58/4 58/18
59/17 65/23 66/16 66/17 83/5
83/20 93/12 97/10 98/17
102/22 103/18
beyond [29] 12/10 12/15
12/16 12/19 12/25 13/5 18/20
19/12 21/12 22/9 23/13 25/7
26/11 26/25 27/15 28/13
29/20 30/23 31/17 31/19 32/8
34/3 34/5 36/11 36/22 89/14
89/16 96/17 111/9
bias [1] 15/16
biases [3] 11/19 11/19 11/20
Bienert [2] 3/4 3/7
big [3] 104/16 111/1 111/4
biggest [2] 72/6 107/16
bill [1] 42/17
billions [1] 42/17
birth [1] 32/15
bit [7] 68/5 85/22 86/15
88/17 89/15 89/20 92/7
BK [1] 44/16
blames [4] 36/5 36/7 36/8
36/9
blaming [1] 36/17
blank [2] 59/22 94/13
BlueVine [1] 46/21
bomb [1] 43/5
books [1] 58/10
borrowers [3] 40/22 41/21
56/19
both [8] 14/16 55/18 57/25
57/25 58/1 61/10 91/2 105/19
bothers [1] 68/5
bottom [3] 5/14 47/1 101/20
Boulevard [1] 3/15
boy [1] 59/8
break [1] 112/25
brief [2] 24/25 48/7
briefly [2] 74/14 88/20
bro [1] 43/24
broad [1] 91/22
brother [5] 35/17 58/16
64/12 75/5 104/16
brought [2] 37/25 47/25
build [1] 34/22
building [1] 107/15
bunch [1] 97/23
burden [4] 12/14 34/4 91/4
111/9
business [15] 24/7 37/12
38/13 41/3 41/5 41/14 62/17
63/22 63/25 64/8 64/15 69/14
76/7 77/6 98/8
businesses [6] 34/14 34/18
35/9 40/17 41/10 111/1
buy [9] 52/19 58/16 59/22
59/22 65/20 71/22 77/10
84/22 95/20
buying [2] 47/24 58/15
buys [2] 59/1 104/8
buzz [1] 89/1
C
C1 [1] 6/22
CA [9] 1/23 2/7 2/15 2/21
3/6 3/9 3/13 3/16 3/21
Caicos [7] 46/5 83/3 83/9
83/17 83/19 84/7 84/25
caliber [1] 110/7
CALIFORNIA [9] 1/2 1/14 5/1
32/13 47/17 74/4 75/13 77/20
79/24
call [10] 55/17 58/21 58/22
65/15 80/20 85/6 86/17
101/16 106/11 110/17
Calle [1] 3/5
called [8] 68/1 68/2 68/15
80/23 81/3 85/3 85/11 105/25
calling [1] 43/24
calls [9] 18/1 46/7 54/20
54/21 55/21 65/16 86/14
106/6 107/3
came [13] 40/20 45/22 46/4
Case 2:20-cr-00579-SVW Document 677 Filed 07/09/21 Page 117 of 133 Page ID
#:10846
C
came... [10] 50/22 51/18
53/19 54/16 64/2 64/7 68/15
76/3 86/7 94/24
can [47] 5/22 10/16 14/15
14/17 24/8 33/12 42/19 43/10
43/11 43/17 45/17 47/11 48/1
55/3 55/19 55/20 61/14 66/9
67/8 67/13 67/14 79/10 84/1
85/15 86/21 87/10 90/8 90/13
90/22 91/2 91/3 93/4 93/4
93/24 94/7 95/24 99/22 101/6
102/3 102/25 105/1 107/8
107/9 111/4 111/5 111/22
112/8
can't [8] 8/19 10/15 10/17
44/13 90/9 90/10 101/25
111/25
cannot [8] 8/20 36/17 81/6
99/14 106/7 109/24 112/12
112/14
Canoga [8] 52/25 57/19 69/5
72/18 88/6 102/8 102/9
102/11
capable [3] 23/20 25/17
106/14
capacity [1] 68/10
captioned [1] 25/25
card [41] 49/4 49/5 49/13
49/14 49/15 50/3 50/4 50/5
51/24 51/25 52/7 52/18 52/18
52/24 54/25 57/22 68/24 73/8
81/12 86/4 86/5 86/9 86/18
92/1 101/14 102/15 102/18
104/21 105/4 105/6 105/10
105/14 105/18 105/24 106/8
106/9 106/18 106/19 108/2
108/10 110/15
cards [16] 35/11 35/11 45/24
45/24 45/25 46/1 48/19 48/21
48/23 69/9 73/10 73/12 98/2
98/17 102/20 108/6
care [4] 63/17 63/18 106/13
107/8
careful [5] 12/21 12/24 13/3
31/2 106/15
carefully [2] 93/19 111/7
cares [1] 103/12
Caribbean [1] 83/16
carried [1] 25/9
carry [6] 21/14 23/25 24/1
101/14 105/19 110/17
carry-on [3] 101/14 105/19
110/17
carrying [1] 49/12
case [53] 9/14 11/4 11/8
11/12 11/24 14/8 14/22 15/4
15/15 17/5 18/3 18/14 34/10
37/3 39/17 44/24 44/25 48/8
48/15 51/1 71/12 88/2 88/18
88/21 88/24 89/11 90/9 90/18
91/15 92/21 93/15 94/1 94/9
95/5 97/3 97/4 99/8 99/16
99/17 100/2 100/20 101/12
101/17 104/22 107/13 107/15
108/17 109/1 110/24 111/4
112/4 112/16 113/3
cash [1] 44/9
catastrophe [1] 34/12
CATHERINE [1] 2/5
caught [5] 54/24 55/5 106/12
106/14 108/1
cause [4] 8/19 40/12 80/13
103/22
caused [6] 23/24 24/6 40/3
40/5 40/8 80/17
causes [1] 111/16
Cellebrite [1] 7/18
Celtic [1] 41/18
central [2] 1/2 35/24
certain [4] 17/13 18/18
18/25 81/5
certainly [2] 90/10 103/15
certificate [4] 69/19 84/18
90/5 114/1
certification [6] 41/9 74/20
75/4 75/16 76/13 76/22
certifications [3] 40/22
41/1 41/1
certify [1] 114/4
chain [1] 93/13
challenges [1] 43/19
chance [3] 95/15 97/21 113/2
change [2] 46/24 111/16
changed [3] 8/8 79/5 79/6
charge [5] 19/11 27/14 28/6
72/11 81/16
charged [38] 17/2 17/3 17/6
18/3 18/9 18/14 18/24 19/5
19/16 20/7 22/8 22/13 22/23
23/6 24/18 27/9 30/13 30/14
30/23 31/14 31/15 31/22 32/1
32/3 32/21 32/22 32/24 33/1
36/13 36/23 38/21 60/15 61/4
91/13 91/16 91/18 108/15
108/23
charges [23] 12/8 12/15
16/25 17/4 18/16 24/24 31/1
40/4 40/7 55/1 55/2 55/5
55/7 55/8 55/8 86/19 106/21
106/22 106/23 107/2 107/4
107/5 108/20
chart [11] 10/8 23/1 23/2
24/23 43/14 45/10 54/8 62/9
71/7 76/6 94/18
charts [5] 10/7 18/25 19/1
50/17 71/11
cheat [1] 23/23
check [6] 43/2 53/17 58/10
60/3 67/14 90/9
checkbook [1] 71/1
checkbooks [1] 72/22
checking [1] 66/11
checks [15] 35/11 50/1 50/1
56/24 56/24 58/9 59/19 59/23
61/6 61/8 61/8 66/8 66/10
94/3 102/6
choice [2] 97/11 98/18
choices [1] 99/13
choose [2] 97/10 98/17
choosing [1] 46/14
chose [1] 16/9
Christopher [1] 2/9
chronologically [2] 91/20
110/3
circumstance [1] 80/15
circumstances [2] 11/16 24/4
circumstantial [4] 14/10
14/13 14/17 14/19
Clark [2] 83/7 84/17
clean [8] 55/3 55/9 55/19
55/20 86/21 107/11 107/11
107/19
clear [5] 8/3 9/13 97/11
98/18 99/14
clearly [1] 77/5
Clemente [1] 3/6
clerk [1] 9/22
close [1] 96/18
closely [1] 78/4
closing [4] 4/9 13/22 46/22
110/23
co [19] 36/18 37/12 38/20
40/1 44/22 45/6 45/7 46/15
51/15 51/15 57/21 59/17
59/18 66/17 71/19 73/13 76/1
76/3 81/18
co-conspirator [1] 81/18
co-conspirators [17] 36/18
37/12 38/20 40/1 44/22 45/6
45/7 46/15 51/15 57/21 59/17
59/18 66/17 71/19 73/13 76/1
76/3
co-defendants [1] 51/15
Coast [1] 3/20
coconspirator [1] 36/9
code [13] 19/8 19/9 22/25
23/12 24/21 25/6 27/12 27/21
27/25 28/11 28/18 31/25
114/5
codefendants [2] 18/13 18/15
cohesive [1] 45/15
Coinbase [4] 82/3 82/17
82/18 82/20
coincidence [1] 58/2
coins [7] 38/2 38/6 69/24
69/24 69/25 70/1 77/10
collecting [1] 70/12
Collision [3] 51/17 75/24
76/9
color [1] 11/14
column [2] 23/3 23/4
combined [1] 79/17
come [7] 48/6 48/10 51/1
67/21 96/18 98/22 112/25
Comerica [1] 75/14
comes [4] 67/21 82/5 101/12
110/15
coming [2] 48/16 59/2
comma [1] 29/15
commanded [1] 26/15
commerce [2] 29/6 30/11
commission [2] 18/8 26/7
commit [23] 19/6 19/15 19/22
20/6 20/10 26/5 26/8 27/2
27/19 28/2 28/7 28/16 29/12
29/15 30/4 36/14 36/14 38/22
38/24 53/4 68/10 81/6 92/18
commits [2] 22/4 98/11
committed [15] 18/17 18/21
18/24 19/24 22/6 22/11 22/18
26/13 27/7 30/24 31/18 31/20
40/5 40/6 94/24
committing [6] 26/9 26/22
31/15 93/18 99/4 104/20
common [8] 12/20 20/4 55/7
63/14 63/23 64/15 66/18 75/9
communicate [1] 33/17
communication [3] 24/11
24/13 24/15
communications [2] 23/25
42/1
companies [17] 48/24 49/1
50/7 51/12 51/14 56/25 57/1
57/6 57/11 57/15 57/16 58/12
69/3 72/15 72/23 77/16
109/19
company [38] 38/16 39/22
39/23 49/6 49/12 49/12 50/11
50/11 52/16 53/8 57/3 57/9
60/4 60/6 63/15 64/10 64/21
65/8 65/13 67/22 68/19 69/10
69/15 70/14 72/17 74/25
75/15 76/19 76/20 77/5 77/8
78/5 78/9 85/18 85/21 85/21
97/17 109/20
compartment [3] 101/15
105/19 110/16
complete [1] 99/15
completed [3] 26/20 33/20
51/5
completely [1] 105/2
complicated [1] 68/6
component [1] 50/19
conceal [3] 28/25 35/1 72/2
concealed [1] 71/12
Case 2:20-cr-00579-SVW Document 677 Filed 07/09/21 Page 118 of 133 Page ID
#:10847
C
concealing [1] 71/14
concealment [1] 71/10
concept [2] 88/3 101/24
concerned [2] 109/3 112/15
conclude [2] 90/2 107/23
conclusion [1] 108/7
conclusions [1] 90/13
conclusively [1] 17/15
condition [1] 10/12
conditions [2] 81/5 81/6
conduct [2] 17/2 108/23
conducted [1] 28/14
confer [1] 9/22
Conference [1] 114/9
conformance [1] 114/8
confront [1] 107/12
confronted [2] 63/8 106/9
confronts [1] 105/5
confusing [1] 92/23
connected [1] 9/3
Connecticut [1] 2/23
connection [3] 56/13 84/21
92/16
conscious [1] 11/22
consciously [1] 11/21
consent [1] 33/7
consequence [1] 22/21
consider [18] 13/7 13/11
13/14 13/17 14/16 16/4 16/20
17/22 18/2 18/6 18/10 24/3
28/7 36/25 38/19 98/6 98/21
99/22
consideration [4] 12/22
12/24 13/4 78/22
considered [1] 88/23
considering [5] 14/24 15/8
28/6 31/1 87/2
consistent [3] 15/24 87/4
104/13
consists [3] 13/8 28/12
29/19
conspiracies [4] 36/13 36/13
38/22 91/17
conspiracy [108]
conspirator [4] 20/21 20/23
81/18 100/25
conspirators [26] 20/1 20/9
20/24 21/9 21/14 21/17 22/2
28/2 36/18 37/12 38/20 40/1
44/22 45/6 45/7 46/15 51/15
57/21 59/17 59/18 66/17
71/19 73/13 76/1 76/3 101/1
conspire [1] 21/9
conspired [3] 21/13 21/18
35/23
conspiring [2] 19/6 27/10
constitutes [2] 7/4 29/11
constituting [1] 26/6
constitutional [1] 14/23
construction [25] 53/7 57/2
57/3 57/15 57/15 57/16 57/16
58/1 58/11 58/11 58/12 69/3
70/14 72/15 72/22 72/23 73/1
74/16 74/22 77/14 77/15
77/16 85/2 85/2 85/4
constructive [2] 8/10 9/5
consult [1] 11/6
Cont'd [1] 3/1
contain [1] 73/21
contained [7] 9/16 9/17 9/17
9/18 41/25 52/9 56/17
containing [1] 7/18
contains [2] 75/23 81/23
context [1] 96/19
continue [7] 21/1 41/11
44/12 79/10 83/19 84/25 92/9
continues [1] 6/21
continuing [2] 19/14 27/17
contracting [4] 48/25 68/25
75/10 85/18
Contracting.com [1] 68/21
contradicted [1] 15/17
contrast [1] 95/25
control [10] 11/22 17/8 29/1
33/9 33/11 33/14 81/15 86/11
96/20 96/25
controlled [1] 58/7
controlling [1] 97/5
controls [9] 14/1 54/14 65/9
83/10 84/12 96/23 97/1 98/11
99/10
convert [1] 90/24
convict [5] 8/11 99/14
108/17 109/24 110/6
conviction [1] 16/20
convinced [7] 10/12 10/15
10/18 12/17 12/25 13/5 89/17
cook [1] 90/4
cooperated [1] 39/18
copies [2] 56/8 56/9
copy [8] 5/18 5/23 11/4 25/1
31/8 56/15 56/17 92/24
core [3] 101/17 103/7 104/22
corner [1] 69/13
corporate [1] 94/21
correct [6] 5/16 5/19 5/22
90/21 99/9 114/5
corrected [1] 96/22
could [9] 8/9 8/11 10/20
22/20 81/25 101/7 101/9
106/14 107/19
counsel [6] 2/1 5/9 7/19
49/20 55/4 113/1
counseled [1] 26/14
count [41] 17/4 17/7 17/9
17/11 17/12 18/22 19/5 23/4
23/6 23/7 24/25 25/1 25/8
25/11 30/13 30/19 30/20 32/2
32/4 32/12 32/13 32/15 32/22
32/23 32/24 32/24 33/1 33/2
61/3 61/5 68/13 69/7 69/8
70/3 71/4 71/4 80/7 80/7
80/7 91/14 92/17
count 14 [1] 32/23
country [3] 70/8 70/25 77/12
counts [38] 8/17 8/18 8/20
9/7 18/9 22/23 23/8 24/18
25/24 26/1 26/2 26/3 27/9
30/14 30/22 30/24 31/1 31/15
31/23 32/6 46/11 46/12 48/10
68/11 80/6 80/8 80/9 80/10
80/22 80/25 81/1 87/5 90/18
91/16 92/18 94/12 97/13
112/20
couple [6] 9/9 76/24 82/5
94/1 96/2 106/11
course [7] 8/5 22/3 24/7
34/4 69/2 107/2 107/5
court [13] 1/1 1/21 5/23 6/8
6/9 6/15 7/7 7/16 9/22 14/7
28/8 78/22 92/7
Court's [1] 78/22
courtroom [1] 73/16
cousin [3] 35/18 36/6 39/19
CR [1] 1/8
crash [1] 43/11
crazy [1] 44/5
create [2] 61/14 80/3
created [5] 36/3 39/13 39/21
44/18 61/19
creates [1] 98/10
credit [30] 35/11 45/24 46/1
48/19 48/21 48/23 49/14
49/15 50/3 50/4 50/5 51/24
51/25 68/24 69/9 73/8 73/10
73/12 81/12 98/2 98/17
102/15 102/18 102/20 106/8
106/9 106/19 108/2 108/6
108/10
crime [35] 17/3 17/6 19/16
19/22 19/24 20/9 22/4 22/6
22/8 22/11 22/14 22/17 22/19
26/5 26/6 26/8 26/10 26/13
26/16 26/18 26/19 26/22
26/25 27/2 27/4 27/5 27/7
28/2 28/10 29/17 55/10 55/24
61/4 86/20 86/25
crimes [10] 6/12 6/20 8/11
18/3 18/11 19/22 20/7 27/19
36/23 81/6
criminal [13] 14/22 16/20
19/20 27/5 35/12 38/15 39/7
39/11 39/14 59/16 71/12
82/25 106/24
criminally [1] 29/25
crisis [1] 34/16
cross [2] 107/17 112/8
cross-examine [2] 107/17
112/8
CRR [1] 114/12
Cruz [1] 5/18
CSR [2] 1/21 114/12
current [1] 110/1
cut [8] 38/15 39/22 53/17
59/5 65/24 66/15 67/17 73/17
cuts [1] 59/15
D
DADYAN [47] 3/18 30/13 35/18
35/19 36/5 36/6 37/7 39/15
39/19 42/8 42/18 43/23 44/10
44/14 45/3 45/7 46/17 46/19
47/21 57/5 58/5 58/19 60/20
62/11 62/15 62/17 63/11
64/17 64/17 64/23 65/15
65/22 65/23 66/7 68/1 68/2
68/4 68/9 68/23 71/13 81/18
83/20 84/4 84/14 84/15 85/10
102/22
Dadyan's [4] 38/15 56/16
57/3 75/14
dangerous [1] 112/7
date [6] 18/21 18/21 18/24
23/5 32/15 114/10
dates [2] 18/18 83/13
Davidson [3] 38/10 58/15
64/12
day [6] 1/15 44/20 53/19
67/5 68/5 107/22
days [9] 34/21 35/3 36/11
67/19 69/20 96/2 96/8 98/6
110/4
DC [2] 2/10 2/23
deal [3] 33/17 59/13 67/7
death [3] 69/19 84/18 98/6
debit [4] 35/11 45/24 102/17
104/21
decades [2] 68/20 85/20
deceased [3] 38/5 69/16
84/20
deceive [1] 23/23
December [2] 82/8 82/12
December 22nd [1] 82/12
decide [11] 11/9 11/12 14/8
14/20 15/5 16/5 16/7 17/5
89/3 89/13 112/9
decides [1] 98/7
deciding [4] 13/7 13/14 15/4
16/21
decision [1] 34/10
decisions [4] 88/21 89/22
89/23 89/24
decline [1] 59/3
defendant [103]
defendant's [2] 9/19 24/3
Case 2:20-cr-00579-SVW Document 677 Filed 07/09/21 Page 119 of 133 Page ID
#:10848
D
defendants [47] 12/8 12/9
12/10 12/12 12/13 16/25 17/1
17/4 19/5 22/23 23/6 24/18
27/9 33/23 34/16 34/21 34/22
35/1 35/14 35/22 35/25 36/1
36/12 36/23 37/4 37/5 37/7
37/10 38/20 39/2 40/3 45/15
45/17 46/3 48/17 51/7 51/15
53/23 67/25 71/11 73/16
80/18 87/7 89/5 108/19
108/22 113/1
defendants' [1] 34/10
defense [3] 21/23 90/15
96/15
defense's [1] 8/25
defies [5] 55/6 63/13 63/23
64/15 75/8
definition [2] 90/16 90/20
defraud [5] 23/15 23/23 24/2
25/20 66/19
deliberate [2] 95/16 99/20
deliberately [1] 16/8
deliberating [2] 111/12
111/19
deliberations [1] 33/21
deliver [1] 33/24
delivered [2] 52/22 53/22
demonstrated [1] 48/3
demonstrative [1] 10/16
denies [1] 106/9
DEPARTMENT [3] 2/4 2/9 70/5
depend [1] 16/15
dependent [1] 21/21
Depo [1] 59/22
deport [1] 67/15
deposit [2] 30/10 66/9
deposited [1] 81/10
derived [4] 27/23 29/18
29/25 30/3
described [2] 30/25 88/9
description [3] 23/5 24/25
61/23
deserves [2] 16/18 19/4
designed [2] 28/25 41/9
desperate [4] 63/24 63/24
64/14 109/5
desperately [1] 38/13
detail [3] 20/2 54/22 71/11
detailed [2] 73/20 91/11
details [6] 20/15 21/6 42/12
42/12 45/5 45/6
detained [1] 106/15
determine [3] 16/24 31/19
108/19
determining [1] 24/2
devastated [1] 64/4
devised [1] 23/15
DHS [1] 74/5
Diamond [1] 76/25
diamonds [3] 69/24 76/18
77/10
did [31] 6/19 14/13 14/25
21/8 26/5 26/23 32/19 34/2
34/6 43/5 43/13 44/4 46/24
51/1 51/25 58/14 60/23 61/17
64/1 69/23 77/25 78/21 80/2
89/3 91/15 96/11 100/20
105/15 112/13 112/16 112/23
didn't [16] 34/2 47/2 62/25
63/4 75/11 84/20 88/1 88/3
92/18 93/21 98/19 100/22
102/11 106/16 111/24 111/24
die [1] 84/20
died [6] 69/11 69/18 69/21
77/9 84/20 84/23
differ [1] 13/24
differences [3] 16/4 61/12
61/12
different [34] 9/16 15/25
15/25 38/20 39/2 45/17 47/13
49/17 50/13 51/7 51/9 53/5
58/7 59/19 61/7 61/8 67/18
70/23 71/5 72/23 79/20 80/6
82/5 85/6 87/23 87/23 90/13
91/8 94/19 107/19 109/25
111/11 111/14 111/19
differently [2] 16/3 111/21
differs [1] 16/5
difficult [2] 107/12 112/1
difficulty [1] 43/22
digital [1] 56/8
direct [8] 14/10 14/11 14/11
14/16 14/19 45/1 45/21 46/7
directed [2] 96/8 96/9
directly [8] 21/8 21/13
21/18 35/22 37/4 37/5 51/12
104/23
disaster [10] 34/14 34/16
34/23 34/24 35/5 37/6 41/8
43/25 49/23 66/20
discharge [1] 36/17
discovered [9] 48/20 49/14
51/24 52/4 68/24 69/9 70/18
70/20 81/12
discussed [3] 9/15 20/4
78/24
disguise [1] 28/25
dislikes [1] 11/18
dispute [1] 73/19
disregard [1] 14/3
distinction [1] 14/18
distinctive [1] 102/7
DISTRICT [3] 1/1 1/2 1/4
dividing [1] 59/16
DIVISION [1] 1/2
DMV [1] 74/5
do [52] 8/19 10/16 10/17
11/17 11/24 12/3 12/12 19/23
36/24 42/19 42/24 43/9 44/5
44/19 47/8 50/12 51/11 59/7
59/9 62/2 62/19 63/13 63/15
64/6 64/22 65/11 67/6 67/12
69/25 72/17 73/2 73/2 76/20
78/12 81/25 82/4 87/9 87/16
88/8 88/11 89/24 93/1 97/20
99/3 101/6 103/6 103/11
105/1 105/13 105/14 106/16
111/17
doc [1] 84/1
docs [3] 43/5 44/4 84/3
document [3] 45/12 45/14
74/12
documentary [1] 74/9
documentation [5] 51/9 62/8
64/25 76/2 76/2
documents [6] 56/17 65/6
70/6 70/18 74/8 77/22
does [28] 16/14 19/23 20/14
20/20 20/22 45/13 49/8 58/21
58/24 65/11 65/15 65/16
67/21 67/22 69/1 69/2 70/10
74/1 78/1 90/24 93/2 96/25
100/10 100/14 100/24 103/8
104/19 109/1
doesn't [18] 5/20 5/25 60/4
65/13 65/19 69/15 72/9 75/2
76/20 77/25 88/13 91/4 99/1
106/20 107/6 108/8 108/14
111/5
doing [5] 83/18 87/23 89/2
93/14 104/20
dollar [4] 37/16 54/18 58/16
64/13
dollars [1] 42/18
don't [25] 31/9 43/2 43/19
54/25 57/12 63/9 63/9 66/20
67/7 73/18 77/5 78/25 80/18
85/5 87/15 89/10 90/3 92/9
96/15 99/3 99/12 100/17
112/9 112/10 113/3
Donald [1] 74/18
done [6] 12/4 36/4 61/16
100/21 101/22 106/24
door [3] 105/5 105/6 105/7
doubt [46] 12/11 12/15 12/16
12/19 12/19 12/20 13/1 13/5
18/20 19/12 21/12 22/10
23/13 25/8 26/12 26/25 27/15
28/13 29/21 30/23 31/17
31/20 32/8 34/3 34/5 36/12
36/22 39/15 62/1 79/3 89/14
89/16 90/16 90/23 90/25 91/6
91/7 91/9 93/8 96/17 99/13
103/5 111/9 111/10 111/20
111/22
down [7] 49/20 54/1 62/10
65/3 92/7 101/12 110/15
dozens [4] 45/22 45/23 56/4
56/24
drafts [2] 7/14 7/15
draw [1] 112/14
dream [5] 47/24 49/22 52/23
53/24 75/20
Drive [1] 54/19
driver's [13] 32/13 45/21
45/23 47/15 47/16 56/5 70/21
75/13 77/20 78/6 79/24 82/22
82/24
during [9] 18/8 22/2 32/19
34/11 39/1 49/7 53/1 87/13
89/1
duty [5] 11/3 11/7 11/9 13/2
13/6
Dzukaeva [13] 32/16 56/12
56/21 57/2 60/12 60/14 60/25
61/8 70/3 70/4 70/24 77/11
77/12
Dzukaeva's [1] 70/19
E
e-mail [11] 44/14 67/10
67/11 69/15 84/2 84/2 84/5
84/11 84/13 84/16 84/16
e-mailed [2] 5/18 46/25
e-mailing [1] 84/13
e-mails [6] 42/22 47/23
56/19 56/20 56/21 56/22
each [30] 17/4 17/5 17/6
17/10 17/11 17/17 19/11
21/11 22/1 22/9 23/12 25/7
25/8 26/11 27/14 29/16 30/22
30/24 32/7 33/13 36/2 37/2
39/2 40/5 40/10 44/7 87/23
88/22 111/8 113/3
earlier [6] 28/9 55/12 60/1
64/24 80/1 80/11
easier [1] 99/23
easiest [1] 44/2
economic [2] 11/16 41/8
economy [1] 41/12
EDD [1] 74/4
edit [1] 7/9
edits [1] 8/15
Edward [3] 35/20 51/16 75/25
effect [2] 21/10 81/4
efforts [1] 45/11
egregious [1] 110/23
EIDL [25] 9/4 9/13 37/18
37/23 38/23 39/13 45/18
47/25 48/25 50/10 54/9 54/16
56/22 57/18 59/3 60/17 61/11
63/12 64/11 71/22 81/10 82/2
82/5 100/3 100/12
eight [4] 15/21 45/15 45/16
46/15
Case 2:20-cr-00579-SVW Document 677 Filed 07/09/21 Page 120 of 133 Page ID
#:10849
E
EIN [1] 46/24
either [6] 14/17 14/19 80/15
98/17 100/20 104/9
element [6] 6/9 9/16 9/18
9/19 12/15 26/16
elements [14] 9/20 19/12
22/9 23/13 25/7 27/15 28/12
29/20 30/18 30/21 30/24 31/2
32/7 48/11
elicit [1] 107/18
else [11] 7/15 15/24 26/8
52/3 65/10 70/25 94/19 99/24
100/10 103/5 111/14
else's [3] 50/2 108/2 111/11
elsewhere [2] 52/2 55/15
EM [4] 57/3 57/16 58/1 58/11
emphasizes [1] 103/19
employee [2] 49/10 49/11
employees [10] 41/2 74/19
75/1 75/2 75/3 75/16 76/10
76/21 77/2 77/6
Encino [1] 47/17
Encore [1] 54/18
encounter [1] 43/19
encountering [1] 67/4
encourage [3] 42/13 54/21
93/19
end [5] 43/16 55/3 63/10
86/17 107/22
ended [1] 106/1
ending [2] 47/19 86/5
ends [1] 42/4
engage [1] 27/10
engaged [3] 29/5 29/22 81/8
engaging [2] 27/22 29/17
English [1] 17/19
enough [7] 20/3 26/21 44/15
59/12 110/6 110/14 110/20
entire [2] 21/22 39/16
entirely [1] 12/6
entitled [2] 66/21 114/7
entity [1] 94/21
equally [1] 12/1
equals [1] 69/25
Erase [1] 63/8
erasing [1] 63/10
errand [1] 59/8
escrow [3] 54/18 58/22 83/25
especially [1] 87/13
essential [2] 24/1 87/24
essentially [6] 9/19 91/20
92/4 95/4 95/6 96/4
establish [2] 33/3 33/5
established [3] 17/15 109/19
109/21
estate [1] 84/22
estimate [1] 78/13
et [1] 1/9
evaluate [1] 11/7
even [11] 20/14 21/8 26/5
63/3 88/2 89/24 91/14 96/18
98/19 104/4 110/5
event [1] 16/3
eventually [2] 67/16 71/15
ever [1] 109/22
every [8] 12/15 20/2 59/23
63/4 90/1 91/14 103/4 104/4
everybody [2] 88/25 94/19
everyone [1] 89/2
everyone's [1] 88/10
everything [14] 15/6 31/10
31/11 44/10 55/20 63/23 71/8
72/7 85/13 85/15 86/25 90/9
93/15 103/5
EVID [1] 4/6
evidence [142]
exactly [2] 76/6 107/23
examine [3] 25/2 107/17
112/8
example [7] 40/6 44/3 51/16
52/20 53/13 71/13 100/17
examples [6] 45/8 51/12
56/10 57/1 60/17 79/25
except [2] 76/19 78/5
excerpt [1] 56/25
excerpts [1] 42/1
exchange [6] 30/10 48/6 70/8
70/12 79/17 93/11
excluded [1] 14/2
executed [1] 42/12
exhibit [19] 4/6 5/10 41/25
41/25 43/14 45/3 45/9 45/10
45/21 50/9 54/8 62/9 71/7
71/8 76/6 76/6 76/15 93/11
95/16
exhibits [14] 5/17 7/17 7/18
7/21 7/22 7/24 13/9 13/12
44/23 44/25 46/10 57/13 94/1
98/1
exist [5] 57/12 60/4 65/14
67/22 69/15
existed [1] 19/25
existing [1] 20/16
exists [3] 20/25 24/3 101/2
expecting [1] 59/24
expenses [4] 41/6 41/6 64/10
76/7
explain [2] 63/6 96/15
explained [4] 27/22 27/25
39/1 62/14
explaining [1] 41/2
explains [2] 30/18 63/2
explanation [2] 64/14 91/7
explicit [1] 9/21
expressed [1] 11/22
extensive [1] 42/1
eyes [2] 37/25 38/8
F
face [2] 43/6 63/5
facilitate [2] 26/18 27/3
fact [20] 14/11 14/15 14/18
16/14 18/2 30/3 39/18 40/21
41/3 41/3 41/4 60/8 62/6
70/6 74/12 83/1 93/17 108/10
111/20 112/13
factors [1] 15/21
factory [1] 88/4
facts [15] 11/9 11/10 13/8
13/10 13/14 13/24 14/14 15/4
17/13 17/14 23/18 89/13
89/23 90/23 91/8
factual [1] 9/16
fair [1] 90/5
fake [50] 35/4 35/6 35/6
35/8 36/2 37/2 37/12 38/16
39/13 39/22 39/23 45/23
47/15 50/11 51/2 55/12 56/5
56/5 56/18 57/12 59/19 60/5
60/5 60/6 61/14 65/4 67/23
70/7 70/21 75/6 75/12 75/12
75/13 75/23 76/15 77/1 77/5
77/19 77/19 77/20 78/2 78/6
78/7 79/24 79/25 80/3 91/22
93/8 109/18 109/20
false [16] 23/16 25/12 25/14
74/13 74/17 74/20 75/4 75/16
76/13 76/22 91/24 91/24 92/2
92/5 102/24 103/24
familiar [1] 52/6
family [4] 35/15 103/13
107/3 107/4
Farrer [4] 37/21 52/11 74/7
77/21
fast [1] 59/21
father [2] 38/5 97/18
father's [4] 53/16 76/19
98/6 98/12
favorable [1] 101/4
favorite [1] 89/25
favors [2] 90/14 90/15
fear [1] 11/18
fearful [1] 31/9
feature [1] 35/24
featured [1] 65/22
federal [3] 7/4 40/16 74/11
federally [1] 25/22
feel [1] 87/18
fell [1] 22/19
felonies [1] 29/13
felony [3] 7/4 29/12 29/16
female [1] 79/16
Fenton [5] 2/9 4/10 34/8
79/11 87/20
few [2] 31/7 33/19
Fiber [14] 50/1 50/6 50/9
51/13 51/19 52/5 52/16 53/7
57/8 73/6 73/6 73/8 74/23
102/9
fifth [4] 22/19 25/21 30/7
46/7
figure [3] 67/1 93/24 107/10
figures [2] 69/14 69/15
file [9] 44/15 58/3 58/23
59/6 60/15 61/19 63/12 63/21
75/7
files [1] 74/10
filing [1] 62/25
filled [1] 38/4
final [3] 5/9 33/20 33/24
finally [1] 23/6
financial [12] 6/17 6/24
25/11 25/17 25/21 28/14 29/3
29/4 30/12 49/24 65/3 69/14
financially [1] 104/17
find [28] 11/10 13/2 13/6
14/15 20/6 22/7 30/23 31/17
37/15 37/19 38/1 38/9 38/14
47/11 56/14 56/24 57/7 70/1
88/10 94/11 100/11 105/12
108/5 109/5 109/9 109/15
110/5 112/19
finding [1] 109/25
finds [1] 108/2
fine [1] 52/21
fingerprint [1] 105/14
fingerprinted [1] 110/16
firmly [5] 10/12 10/15 10/18
12/17 89/17
first [26] 9/18 19/13 21/13
22/11 23/14 25/9 26/13 27/16
28/14 29/22 32/9 33/22 34/17
37/1 40/18 42/3 45/2 46/15
54/24 55/6 57/13 64/7 68/14
87/8 98/9 103/22
five [12] 9/10 15/16 34/21
35/3 36/11 44/23 44/25 48/21
69/20 78/16 98/6 112/23
Floor [1] 2/6
flow [3] 45/10 50/15 94/16
focus [2] 46/16 54/23
focused [1] 107/14
folks [1] 87/12
follow [15] 11/25 14/5 31/6
36/21 37/1 37/15 37/19 38/1
38/9 38/14 45/11 49/18 91/1
111/7 112/1
following [19] 5/6 10/25
13/13 19/12 21/12 22/9 23/13
25/7 25/23 26/11 27/15 27/19
28/12 29/19 32/7 32/11 32/21
78/18 79/8
follows [2] 22/25 24/21
foregoing [1] 114/5
foreign [9] 7/5 17/24 29/6
Case 2:20-cr-00579-SVW Document 677 Filed 07/09/21 Page 121 of 133 Page ID
#:10850
F
foreign... [6] 48/6 48/16
70/8 70/12 70/25 79/16
foresee [1] 24/8
foreseeable [2] 24/10 24/12
foreseen [1] 22/20
forever [1] 43/24
forget [1] 16/1
form [17] 6/18 6/25 7/2 7/3
28/22 29/8 29/10 29/11 33/18
51/3 51/4 62/10 65/2 78/7
83/6 91/10 91/11
formal [1] 20/1
format [1] 114/8
forms [14] 35/6 40/18 51/4
65/2 75/6 75/8 75/13 75/23
76/15 77/1 77/20 78/9 79/25
80/4
formula [1] 47/7
forth [2] 33/18 66/23
forward [1] 9/24
forwards [1] 81/21
found [29] 19/10 23/10 25/4
26/4 27/13 32/5 37/23 38/6
45/25 49/25 54/25 56/4 56/6
56/11 57/9 57/14 57/22 58/8
69/5 86/18 101/14 101/18
102/7 102/9 102/17 102/19
106/18 106/19 108/11
foundation [1] 96/24
foundational [1] 7/22
founded [1] 49/8
four [3] 15/14 33/15 46/25
fourth [6] 9/19 22/16 23/24
25/19 26/19 30/3
Francisco [1] 2/21
Fraser [1] 3/7
fraud [90]
fraudulent [13] 23/17 35/5
39/12 40/12 42/11 49/2 50/11
56/14 61/3 73/21 76/17 77/5
80/2
fraudulently [7] 37/6 38/23
39/20 51/4 54/17 56/22 57/17
freaking [2] 47/7 105/9
friends [2] 35/15 35/20
frustrations [1] 43/18
full [2] 20/14 21/5
fund [1] 44/13
funded [3] 34/25 44/5 47/1
funding [2] 42/18 75/22
funds [25] 30/11 34/14 34/17
35/2 37/8 38/12 38/24 41/16
45/10 47/25 49/23 50/10
50/15 63/25 66/20 74/21 75/4
75/17 76/14 76/23 77/6 94/16
100/3 100/3 100/12
funeral [2] 53/16 104/7
funneled [1] 37/11
funny [1] 47/6
furniture [4] 52/20 52/21
53/22 69/23
further [7] 20/13 58/4 58/12
60/7 62/6 74/12 83/4
furtherance [8] 22/3 22/4
22/15 24/14 24/15 53/3 53/11
61/2
Furthermore [1] 20/16
furthers [2] 20/19 100/15
G
gathering [1] 72/1
gave [7] 14/5 39/22 43/2
58/15 90/20 90/25 110/22
gender [2] 11/15 11/15
general [3] 28/7 31/6 31/12
Genesta [4] 47/17 48/1 52/22
53/22
Gentleman [4] 37/21 47/18
52/11 103/18
get [39] 7/11 9/23 21/20
25/1 31/8 34/14 34/16 41/10
41/23 43/17 43/22 44/2 44/8
59/6 62/25 66/20 78/23 83/24
86/22 88/20 91/11 91/21 92/1
92/17 92/24 93/6 95/9 98/8
98/9 98/25 100/8 101/20
104/21 106/6 108/19 108/25
110/22 111/23 112/3
gets [6] 60/3 65/5 67/16
67/16 67/17 78/8
getting [2] 42/22 67/4
gift [1] 73/17
girl [1] 85/11
give [14] 11/10 14/20 15/25
16/22 19/3 31/7 33/16 42/17
45/8 53/12 56/9 59/7 67/14
106/16
given [5] 5/9 7/25 14/19
38/15 107/2
gives [2] 58/25 81/20
giving [4] 31/5 33/18 43/25
73/15
Glendale [1] 3/13
go [18] 7/24 38/19 43/19
46/21 50/19 59/22 65/19
66/23 74/14 77/10 87/11
88/20 89/25 90/2 90/3 90/17
91/19 91/21
goal [2] 66/18 66/19
goes [16] 45/4 47/1 49/3
49/19 54/14 54/14 63/6 65/5
65/20 76/23 82/11 82/12 96/2
96/3 96/5 96/5
going [37] 10/8 23/1 23/9
30/17 42/17 43/11 44/15
58/22 63/22 66/6 67/1 67/2
88/16 88/25 89/13 89/15
89/24 90/3 90/6 90/17 91/10
91/19 92/14 92/17 92/19 95/7
96/12 98/7 98/25 100/8
100/18 102/16 104/25 105/1
105/3 107/10 108/18
gold [7] 38/2 38/6 69/24
69/24 69/25 70/1 77/10
gone [1] 7/14
good [9] 19/2 43/16 44/10
84/4 84/9 90/1 90/3 90/6
98/9
got [17] 35/1 39/21 43/5
44/4 44/14 46/25 55/5 64/7
66/2 84/16 85/12 86/6 86/6
91/24 92/22 95/1 109/21
gotten [1] 99/12
government [60]
government's [12] 87/17
92/21 93/11 95/4 95/16 98/12
99/17 101/3 103/8 104/22
109/7 111/3
grand [1] 8/11
granted [1] 34/25
great [2] 64/1 87/12
greater [1] 30/1
grieving [1] 98/7
Grigoroyan [1] 76/19
Grigoryan [7] 35/20 36/9
57/20 58/5 71/20 72/5 72/8
Grigoryan's [2] 72/18 76/18
group [3] 3/15 35/15 35/22
groupings [1] 51/9
guaranteed [1] 42/23
guess [2] 91/5 102/14
guide [1] 93/15
guilt [3] 12/19 18/3 18/11
guilty [44] 12/8 12/10 12/17
13/1 13/2 13/6 13/6 16/25
16/25 19/10 22/7 23/10 25/4
26/4 26/9 27/13 32/5 36/23
87/5 88/14 92/19 93/3 93/4
93/20 94/11 96/6 97/12 99/25
100/10 100/11 100/16 100/21
101/23 104/19 106/25 107/13
108/14 108/16 108/20 108/20
109/1 109/2 111/6 112/20
Gusto [6] 50/21 50/23 50/24
51/1 51/18 74/5
guy [1] 61/23
H
had [39] 16/19 21/16 21/19
23/19 25/16 30/1 36/3 39/21
48/6 52/13 60/24 60/25 61/6
63/3 63/24 64/14 64/17 70/7
81/3 81/14 85/6 85/14 86/22
87/12 88/7 90/4 97/8 97/10
97/20 97/21 98/15 98/16
98/17 100/21 104/16 105/11
105/13 105/20 105/24
half [3] 109/16 110/3 110/19
hand [5] 13/3 16/10 20/18
63/23 86/5
handle [1] 75/8
handling [1] 84/1
hands [1] 41/23
handwritten [2] 57/7 57/9
happened [5] 16/1 74/21
75/18 104/24 110/17
happening [2] 93/2 100/14
happens [3] 20/19 65/19
100/15
hard [5] 56/8 56/15 56/17
89/19 89/21
Hardware [1] 95/20
Harley [5] 38/10 58/15 59/1
64/12 75/5
Harley-Davidson [3] 38/10
58/15 64/12
Hart [3] 73/1 77/14 77/15
has [43] 5/10 9/3 10/15
12/14 14/22 15/1 16/7 16/9
17/18 20/18 21/10 22/9 30/16
31/19 33/8 33/9 33/10 33/13
34/4 36/20 39/15 49/10 59/21
61/14 72/13 75/2 77/1 79/6
80/24 85/17 85/19 87/24
88/11 88/23 91/23 96/8 97/5
98/16 101/16 101/22 105/21
107/2 113/2
hasn't [1] 96/17
have [115]
haven't [3] 87/12 99/12
109/20
having [2] 48/17 52/12
Hayrapetyan [3] 35/21 72/13
73/14
he [144]
He's [2] 64/9 66/9
head [1] 105/5
hear [4] 15/11 33/22 60/13
113/1
heard [41] 11/3 14/6 14/13
16/19 17/16 17/25 18/4 18/13
34/20 35/4 35/10 36/5 36/6
36/7 36/10 40/16 41/18 42/16
42/23 49/7 50/24 52/25 53/2
62/13 68/13 72/5 73/24 74/3
74/4 74/5 74/5 77/21 77/24
83/7 84/11 84/17 85/22
104/15 106/6 107/17 110/2
held [5] 5/6 10/25 78/18
79/8 114/6
help [9] 13/22 19/19 26/8
28/5 58/17 59/5 99/2 99/4
107/6
helped [2] 20/5 60/21
helpful [1] 26/24
Case 2:20-cr-00579-SVW Document 677 Filed 07/09/21 Page 122 of 133 Page ID
#:10851
H
helping [1] 27/2
helps [1] 10/16
her [70]
here [53] 5/8 10/8 16/24
37/25 40/20 43/20 44/8 46/12
46/14 46/16 46/21 47/10
48/21 49/4 49/14 51/11 54/9
54/23 56/25 56/25 58/18
59/12 60/3 60/17 61/1 66/3
68/2 69/4 69/19 70/9 71/9
71/19 71/24 76/9 76/25 81/19
83/24 86/4 91/10 92/21 94/5
94/18 99/21 100/24 101/12
102/18 105/4 106/20 108/8
108/19 109/4 110/21 112/16
hereby [1] 114/4
hers [1] 106/10
herself [2] 96/22 108/2
hey [1] 63/15
hid [2] 36/2 36/2
hide [3] 37/2 37/2 108/25
high [1] 89/18
highlight [1] 46/14
highlighted [1] 61/22
Highway [1] 3/20
him [23] 8/11 38/16 39/24
46/20 58/17 58/21 59/3 59/5
60/1 60/21 62/13 66/2 67/7
67/10 67/15 68/17 78/1 85/20
86/6 102/22 104/16 104/17
108/14
himself [2] 49/11 59/1
his [79]
hit [3] 64/3 78/8 96/7
hold [4] 43/24 102/25 111/25
112/12
home [31] 37/24 38/7 45/25
47/24 49/22 52/3 52/23 53/24
54/1 54/2 54/4 54/4 54/18
55/15 56/3 56/4 56/11 56/18
57/14 60/9 70/2 70/11 70/19
71/3 71/15 71/17 75/20 76/24
95/8 95/18 95/20
Homeland [1] 70/5
honestly [1] 92/23
Honor [22] 5/16 5/22 6/1 6/5
6/6 6/14 7/10 7/13 7/16 8/3
8/15 8/23 8/25 9/15 9/25
10/10 10/19 34/9 79/6 79/12
87/9 92/11
HONORABLE [1] 1/3
hope [1] 23/8
hoping [1] 99/22
hours [6] 7/12 7/12 46/23
47/2 59/13 83/23
house [19] 45/22 55/3 55/9
55/20 63/2 65/20 71/22 72/3
72/6 72/9 72/10 77/7 86/21
102/8 104/8 107/11 107/11
107/19 108/6
how [33] 14/20 16/16 16/17
16/22 31/6 33/16 33/17 41/16
42/12 44/19 47/8 50/12 53/12
53/13 64/16 64/22 66/2 66/4
67/1 68/8 69/24 70/10 70/16
71/11 78/12 88/21 90/18
91/16 91/17 93/5 107/20
109/21 110/23
however [4] 16/7 20/3 36/11
90/22
huge [1] 43/6
husband [4] 36/8 54/19 98/14
98/24
I
I'll [2] 63/17 63/18
I'm [5] 47/23 59/12 84/9
100/14 104/7
I.D [1] 4/6
ID [5] 47/17 47/17 61/2
61/24 77/13
ID's [2] 55/13 56/5
idea [7] 31/6 31/12 59/21
62/22 62/23 101/10 102/23
identical [1] 61/7
identifiable [1] 52/8
identification [4] 32/11
32/18 33/4 33/6
identifies [1] 23/4
identities [11] 21/7 35/5
35/8 36/1 36/3 37/3 39/14
48/17 59/20 70/16 77/17
identity [24] 11/15 31/24
32/6 39/8 39/10 48/11 48/13
56/13 60/14 68/11 69/7 69/21
74/18 77/19 79/17 79/19
79/21 81/17 85/9 92/14 92/16
92/19 97/14 98/12
idiot [2] 68/1 68/6
idiots [2] 42/25 68/2
IDs [7] 47/10 56/18 60/25
61/15 61/18 62/5 63/7
ignore [3] 12/1 16/13 34/6
illustrate [1] 89/19
image [6] 52/4 109/10 109/15
109/21 109/24 110/18
images [6] 70/20 109/11
110/1 110/2 110/3 110/4
immediately [1] 64/11
impartial [3] 12/22 12/24
13/4
impermissible [1] 79/4
implores [1] 55/2
important [14] 12/2 12/2
16/16 17/22 40/24 41/3 41/16
41/22 50/17 50/20 57/13
89/24 95/13 100/24
importantly [1] 109/20
imported [1] 52/21
impossible [2] 85/25 102/25
impression [1] 106/17
improbable [1] 102/24
inadvertently [1] 93/3
include [4] 5/20 21/2 60/20
72/23
included [1] 10/5
includes [1] 62/11
including [3] 11/19 41/1
102/21
incomplete [1] 89/23
inconsistent [2] 6/13 9/21
indictment [25] 8/10 12/7
17/1 17/2 18/9 18/16 19/6
19/16 20/7 22/8 22/13 22/24
23/4 24/19 27/10 31/23 32/21
40/4 40/7 60/16 61/4 73/20
80/16 108/21 108/23
indirect [1] 14/13
indirectly [1] 37/10
individual [10] 35/21 42/3
46/11 54/13 56/12 60/14
67/23 73/15 80/8 80/21
individually [3] 88/7 88/23
94/2
individuals [13] 35/8 42/2
42/10 44/17 44/18 45/16
45/23 48/8 57/4 58/6 70/13
70/23 73/3
induced [1] 26/15
indulge [1] 101/5
infer [5] 94/7 102/3 108/13
110/10 110/11
influence [2] 23/20 25/17
influenced [2] 11/13 11/17
influencing [2] 23/21 25/17
info [10] 46/23 48/25 52/15
78/3 78/3 78/5 79/14 81/11
81/24 82/16
information [27] 7/25 40/23
49/24 52/8 52/15 60/8 61/9
61/10 61/14 61/15 61/19
64/24 65/3 66/25 71/1 73/21
73/21 73/22 79/18 81/19
81/24 91/24 92/2 97/24 98/2
98/15 103/24
informed [2] 92/6 107/4
initially [1] 57/20
initials [1] 66/7
initiated [1] 97/9
injury [1] 41/8
inner [1] 45/5
innocence [1] 12/14
innocent [3] 12/9 89/6 112/3
insistent [1] 65/24
instance [1] 50/22
instances [2] 37/5 37/10
instead [1] 10/2
institution [5] 25/11 25/18
25/21 29/4 30/12
instruct [3] 11/3 29/12
29/14
instructed [4] 5/11 14/3
36/20 80/24
instruction [33] 6/9 6/14
7/8 8/6 8/8 8/16 8/17 8/18
10/3 10/13 10/22 14/5 17/11
23/2 24/17 25/24 26/3 27/22
27/25 30/16 30/18 30/20
30/21 30/25 31/3 31/3 90/25
91/1 98/25 100/8 108/18
111/23 112/1
instructions [21] 5/9 11/5
11/25 12/3 17/10 25/2 25/23
28/8 28/9 31/5 31/8 31/13
33/15 33/19 88/22 89/20
92/22 99/20 99/24 111/8
111/15
instrument [1] 30/11
insured [1] 25/22
intellectual [1] 68/10
intend [2] 34/2 79/3
intended [3] 13/22 89/4
91/25
intending [2] 19/19 28/5
intent [7] 20/13 23/22 23/23
25/19 26/17 27/3 100/1
intention [5] 11/23 27/1
33/11 33/14 79/1
intentionally [1] 26/7
interacting [1] 45/18
interest [2] 15/14 20/4
interesting [2] 87/21 97/14
Interestingly [1] 91/13
interiors [6] 51/13 51/19
69/10 77/8 97/16 97/16
Internal [1] 74/4
International [7] 46/4 46/9
48/21 51/25 57/23 81/13 86/7
interpret [1] 13/23
interpreter [1] 107/18
interpreters [1] 106/13
interrupt [1] 78/12
interstate [5] 23/25 24/11
24/14 29/5 30/11
introduced [2] 8/1 94/25
introduction [2] 83/25
110/23
investigate [1] 105/15
involve [1] 111/4
involved [13] 6/17 6/23 7/1
9/11 21/17 29/9 29/25 35/23
62/17 62/25 63/22 81/9 111/2
involvement [2] 45/6 60/7
involves [1] 39/17
involving [3] 28/15 29/4
Case 2:20-cr-00579-SVW Document 677 Filed 07/09/21 Page 123 of 133 Page ID
#:10852
I
involving... [1] 45/15
IP [6] 53/10 60/8 60/10
60/18 64/24 71/1
IRS [9] 75/6 75/13 75/23
76/15 77/1 77/20 78/7 79/25
80/3
is [624]
Islands [2] 83/17 83/19
isn't [3] 61/15 61/16 110/6
issue [2] 8/7 48/14
it [300]
it's [4] 9/5 43/3 59/5 64/16
Italy [1] 52/20
its [12] 18/6 19/18 26/7
28/4 33/9 33/10 101/4 101/15
101/17 105/18 109/25 110/23
itself [2] 80/13 111/22
Iulia [40] 39/8 42/6 46/2
47/8 47/10 48/4 48/5 48/22
48/23 49/16 49/16 54/2 65/20
68/21 68/25 70/7 71/16 73/3
77/4 78/5 78/5 79/15 79/15
79/16 79/22 81/20 82/11
82/12 82/19 82/21 82/24 83/5
83/10 83/15 84/9 86/1 94/2
94/8 102/2 104/7
Iulio [1] 43/2
J
Jack [8] 49/7 60/5 65/12
74/6 77/24 78/7 78/8 80/1
jail [16] 18/1 18/2 46/7
46/9 54/20 54/21 55/18 86/17
101/16 106/6 106/8 106/10
106/19 107/1 108/3 110/17
Jennifer [1] 3/12
job [1] 87/24
jobs [2] 41/11 64/4
John [3] 3/4 7/19 87/14
Johnson [6] 2/14 2/17 2/19
2/22 3/19 3/20
join [5] 8/14 8/25 9/2 21/4
36/18
joined [2] 17/5 50/14
joins [1] 20/16
joke [1] 85/10
Journeyman [1] 53/7
JP [1] 82/11
Jr [1] 3/14
judge [4] 1/4 36/20 80/24
104/4
judgment [1] 108/16
Judicial [1] 114/9
July [2] 53/18 69/18
July 18 [1] 69/18
July 21st [1] 53/18
JUNE [6] 1/17 5/1 49/22
94/25 95/23 114/10
June 17 [1] 94/25
June 19th [1] 95/23
jurors [3] 17/22 89/21
111/18
jury [17] 1/15 5/7 8/6 8/8
8/11 8/11 9/23 11/1 11/2
11/5 31/9 34/10 78/19 79/9
86/24 88/22 89/20
just [58]
JUSTICE [2] 2/4 2/9
Justin [1] 41/19
K
Kathleen [1] 40/19
KATIE [2] 1/21 114/12
Katzman [2] 3/4 3/7
Kauichka's [1] 65/13
Kauichko [45] 39/10 46/2
49/5 49/9 50/4 50/5 52/1
52/16 52/22 53/7 53/8 57/1
57/21 65/14 69/6 71/21 71/23
72/19 73/6 78/1 88/16 88/17
94/8 101/24 102/2 102/3
102/15 102/20 102/24 103/2
103/4 103/7 103/8 103/12
103/13 103/15 103/21 103/25
104/6 104/11 104/12 105/22
106/2 106/2 109/6
Kauichko's [2] 102/6 106/4
keep [2] 96/16 97/4
keeping [1] 93/18
Keough [1] 2/19
Kept [1] 43/24
key [1] 99/21
kids [2] 107/8 108/3
kind [3] 19/20 88/7 100/19
kinds [2] 97/24 109/9
kitchen [1] 90/3
knew [17] 6/10 7/1 9/10
21/16 25/13 28/21 28/24 29/7
29/9 29/24 32/17 48/13 89/4
95/1 101/8 108/9 110/5
know [65]
knowing [5] 6/16 19/18 20/24
28/4 101/2
knowingly [3] 23/14 25/9
32/9
knowledge [7] 20/15 20/18
21/5 27/1 27/5 48/12 86/16
known [2] 96/8 96/9
knows [14] 24/6 33/9 33/10
33/13 55/2 55/8 86/18 86/19
86/19 93/1 100/13 106/3
106/18 107/1
Kopytova [1] 57/2
Kudiomov [4] 71/20 77/19
84/11 84/23
L
lack [2] 12/22 99/15
lacks [1] 68/9
laid [1] 24/23
Lamps [3] 85/22 85/23 85/24
Landsgaard [2] 84/19 84/23
language [7] 9/21 10/2 10/13
17/17 17/19 17/22 17/24
last [11] 5/17 9/25 34/20
35/3 36/11 43/5 46/25 79/13
86/13 100/24 109/4
later [10] 27/16 42/21 43/4
43/4 45/8 48/10 57/21 69/20
92/25 96/2
laugh [1] 44/12
laughed [1] 68/16
laughing [3] 43/20 44/11
44/12
laundered [1] 82/25
laundering [17] 6/10 9/7
27/11 27/20 28/7 28/10 30/15
30/19 30/21 36/15 38/25 39/7
71/5 72/12 81/9 81/9 95/5
law [13] 3/15 3/20 7/5 9/4
11/4 11/9 11/11 11/13 14/18
14/24 22/6 35/18 36/21
lawyer [4] 5/14 5/20 63/3
84/18
lawyer's [2] 13/17 13/19
lawyers [7] 13/16 13/16
13/20 13/25 31/7 33/19 79/2
leader [1] 39/5
leaders [1] 42/10
learned [2] 44/19 106/7
leased [2] 57/20 57/21
least [14] 19/13 19/14 19/16
19/18 20/7 21/14 26/16 27/17
27/19 28/4 91/17 100/19
101/7 104/9
Leave [1] 58/23
leaves [2] 12/17 89/17
led [1] 44/17
left [5] 5/15 23/3 23/5
91/20 94/13
legal [1] 32/10
lenders [2] 66/20 73/23
lent [1] 41/5
let [6] 29/14 33/4 59/7 66/8
75/8 78/11
let's [8] 7/11 34/7 42/24
87/10 93/7 95/12 101/20
104/21
letter [1] 59/3
Lewis [1] 3/4
liability [1] 80/23
liable [1] 40/3
license [11] 32/14 47/15
47/16 56/5 70/21 75/13 77/20
78/6 79/24 82/22 82/24
licenses [2] 45/22 45/23
lie [1] 65/17
lied [2] 37/9 64/19
lifeline [2] 40/17 41/10
light [2] 15/20 101/4
like [24] 41/13 43/23 43/25
45/7 48/18 56/21 61/15 62/7
66/13 67/19 70/7 70/24 72/13
76/10 79/3 81/25 87/18 87/22
93/4 98/4 112/4 112/5 112/9
112/10
likely [1] 97/9
likes [1] 11/18
Likewise [1] 41/7
limit [1] 67/5
limited [1] 14/4
Limo [3] 57/3 66/6 76/9
line [13] 34/22 39/6 39/21
44/19 50/18 50/18 55/11 56/6
62/4 76/4 87/20 87/22 88/4
lines [1] 8/8
link [1] 83/5
links [2] 82/21 82/23
list [3] 57/14 69/4 72/22
listed [1] 77/15
lists [6] 56/19 57/15 57/24
57/25 57/25 58/1
little [5] 68/5 85/22 88/16
89/15 89/20
Littrell [7] 3/4 3/4 3/7
4/11 7/19 87/14 92/6
Littwin [1] 40/19
Liudmyla [1] 57/2
live [3] 72/9 72/21 102/11
lived [2] 52/23 55/24
living [1] 104/9
LLP [6] 2/14 2/17 2/19 2/22
3/4 3/7
loan [48] 34/23 34/24 35/5
37/23 38/3 38/24 39/13 39/18
39/20 40/8 40/8 41/8 43/25
45/18 47/25 49/2 49/6 49/18
50/10 53/19 54/10 54/16 56/6
56/14 56/15 58/3 60/12 60/15
61/11 63/12 64/11 64/19
69/20 71/2 74/10 74/13 76/9
77/13 79/13 79/14 80/2 82/5
84/1 92/5 98/8 100/3 100/3
100/12
loans [25] 9/4 9/13 39/10
41/13 41/14 44/2 44/8 48/25
49/1 49/13 49/17 50/8 56/23
57/18 60/17 62/7 63/13 73/20
74/16 76/25 81/10 82/2 92/3
106/3 110/25
local [4] 57/15 69/3 70/14
77/16
located [1] 88/5
location [1] 29/1
locations [1] 21/7
Case 2:20-cr-00579-SVW Document 677 Filed 07/09/21 Page 124 of 133 Page ID
#:10853
L
log [2] 97/24 98/15
log-in [2] 97/24 98/15
LOL [9] 43/25 44/10 47/6
66/13 84/5 84/10 85/10 85/11
85/15
long [2] 21/1 110/23
longer [1] 78/12
look [52] 30/20 43/8 45/16
46/21 47/14 47/22 48/19
48/23 51/7 51/8 51/23 52/10
52/17 53/11 53/13 53/18 54/9
54/11 54/21 55/23 56/9 56/10
57/19 58/9 58/14 59/9 59/11
61/21 62/9 64/17 65/6 66/1
67/17 67/25 68/3 68/11 68/21
70/23 71/4 71/7 78/4 82/18
86/3 87/12 93/25 95/12 95/15
96/3 98/1 99/5 107/13 112/9
looked [3] 62/7 68/16 104/16
looking [3] 88/10 109/13
110/5
looks [2] 6/15 112/10
LOS [7] 1/14 1/23 2/7 2/15
3/9 3/16 5/1
lost [2] 105/17 105/21
lot [19] 31/4 44/23 50/13
53/1 53/2 64/1 64/7 64/9
68/2 76/10 79/16 84/11 87/16
87/22 87/23 89/1 99/19 103/9
111/2
lots [1] 102/19
loud [2] 44/11 92/24
love [1] 103/13
loves [1] 104/12
luggage [9] 48/20 51/24
68/24 81/13 101/15 102/17
105/19 108/11 110/17
lump [1] 88/25
lunch [1] 112/24
Luncheon [1] 113/5
luxury [1] 37/20
M
made [11] 7/19 18/1 20/1
23/18 64/1 74/12 79/18 83/24
86/12 95/18 101/17
mail [11] 44/14 67/10 67/11
69/15 84/2 84/2 84/5 84/11
84/13 84/16 84/16
mailed [2] 5/18 46/25
mailing [2] 48/2 84/13
mails [6] 42/22 47/23 56/19
56/20 56/21 56/22
maintained [1] 6/8
make [22] 5/24 10/17 14/18
16/2 59/23 61/23 87/10 88/21
89/22 89/23 90/9 99/22 103/8
103/11 104/19 105/23 107/3
108/14 109/1 111/3 111/5
113/2
makes [7] 39/23 68/5 75/12
106/11 107/13 108/15 109/2
making [3] 25/11 64/2 105/9
male [2] 47/14 79/19
man [3] 69/2 69/16 70/7
manner [2] 14/25 15/13
mansion [4] 37/16 37/16
58/16 64/13
Manuk [9] 35/20 36/9 57/20
58/5 71/20 72/5 72/8 72/18
76/18
Manukyan [3] 73/10 73/12
74/24
Manukyan's [1] 50/3
many [7] 21/2 39/10 46/16
49/17 69/24 105/17 111/4
March [3] 19/14 27/17 42/15
March 12 [1] 42/15
March 2020 [2] 19/14 27/17
Marietta [36] 17/25 32/1
35/16 36/7 37/14 37/17 37/24
38/2 38/4 38/7 39/9 46/3
46/8 49/21 51/23 51/24 52/5
52/19 53/15 53/23 54/5 54/6
57/10 57/22 58/6 70/1 71/13
71/17 72/3 72/10 75/19 76/24
83/2 83/8 86/18 87/14
Marietta's [2] 52/18 77/7
Mark [6] 32/12 68/14 74/6
75/11 85/19 85/21
market [2] 2/20 43/11
married [3] 99/2 110/21
112/17
Mary [37] 88/10 88/18 93/17
94/10 94/14 94/17 94/23
95/13 97/3 97/10 97/20 98/4
98/23 100/4 102/5 102/11
102/23 103/3 103/10 103/12
103/16 104/2 104/8 104/12
104/18 104/23 105/3 105/19
106/7 109/6 109/9 109/13
109/21 110/8 110/21 111/5
111/24
Mary's [1] 97/17
Marylee [1] 45/11
massage [1] 91/2
Massino [1] 7/23
massive [2] 34/11 35/13
Masterman [1] 41/19
match [1] 61/23
matches [2] 47/15 86/10
material [4] 19/2 19/4 23/19
25/16
matter [5] 9/16 12/5 19/24
99/24 114/7
mattered [4] 41/20 73/22
73/22 73/25
matters [1] 20/4
max [1] 43/10
may [37] 10/20 11/21 11/21
12/4 12/21 13/11 13/13 14/6
14/10 15/4 15/6 15/9 15/23
16/3 16/9 16/12 16/20 17/21
18/5 18/10 21/1 21/2 21/4
22/7 24/3 26/4 31/18 34/1
37/1 61/16 61/16 78/20 98/22
102/4 103/13 108/13 111/13
maybe [3] 88/5 107/8 108/5
me [19] 29/14 33/4 33/17
47/6 55/17 59/7 59/8 60/1
63/3 63/8 66/8 66/13 66/24
67/12 67/12 78/11 83/24
87/18 107/17
mean [4] 90/22 93/1 99/1
106/15
meaning [3] 34/17 40/6 90/24
meanings [2] 106/14 107/20
means [31] 6/25 23/16 26/7
26/10 29/8 30/9 32/10 32/17
33/3 33/5 54/24 55/1 55/4
89/6 89/16 89/19 93/5 99/2
103/25 104/1 105/22 106/1
106/3 106/22 107/23 107/24
108/24 109/23 110/9 111/10
111/14
meant [3] 98/23 106/17
110/25
Mechanics [1] 77/18
media [12] 50/1 50/6 50/10
51/13 51/19 52/5 52/16 53/7
57/8 73/9 74/23 102/9
Meghan [1] 2/16
member [9] 19/17 20/11 21/5
22/1 22/4 22/12 28/3 36/16
39/24
members [9] 11/2 21/3 21/7
22/5 22/17 34/9 36/12 38/21
86/24
memory [2] 13/25 15/12
merely [5] 20/23 20/24 26/21
100/25 101/1
merge [1] 9/20
Merkuchian [3] 50/2 52/6
73/7
Mesereau [4] 3/14 3/15 10/7
79/2
message [3] 47/5 47/19 59/11
messages [26] 41/25 43/7
43/8 45/2 45/8 47/23 50/15
52/10 52/12 58/18 59/17 62/2
65/23 66/1 66/15 66/22 68/3
68/4 81/17 83/19 83/21 84/7
84/24 102/22 103/17 109/11
met [1] 20/3
Miami [9] 46/4 46/9 46/9
48/20 51/25 55/18 57/23
81/13 86/7
Michael [1] 2/19
mid [1] 83/3
middle [9] 46/5 49/23 58/19
58/20 59/9 67/25 84/8 94/18
111/1
might [3] 21/20 99/19 111/10
Mikala [1] 59/20
million [5] 37/16 54/18
58/16 64/13 72/6
mind [3] 86/15 96/16 97/4
minor [1] 21/24
minute [6] 39/17 58/21 93/6
95/9 95/22 102/16
minutes [4] 59/8 78/14 78/14
78/16
misleading [2] 74/17 106/16
misrepresented [4] 74/19
74/25 75/15 76/21
misrepresents [1] 77/1
missed [1] 96/12
misstate [1] 34/6
mistake [1] 105/23
mistakes [1] 16/2
Mod [7] 51/13 51/19 69/10
69/13 77/8 97/16 97/16
model [2] 6/14 7/8
mom [5] 55/17 95/18 95/21
104/9 109/3
mom's [1] 107/9
moment [4] 36/21 92/15
105/11 108/14
moments [1] 31/7
Monday [1] 67/14
monetary [5] 27/23 29/17
29/22 30/9 30/11
money [97]
Monica [1] 3/15
month [1] 43/17
months [6] 43/4 51/20 82/7
105/25 107/25 110/17
more [20] 14/14 17/4 19/15
19/21 19/22 20/23 21/14
27/18 33/12 53/21 57/10
61/17 61/21 68/5 72/12 78/4
91/11 92/10 97/8 101/1
Morgan [1] 82/11
morning [2] 84/4 87/12
Moron [1] 68/8
most [8] 71/25 78/14 91/5
100/24 101/4 101/6 107/12
109/20
mother [2] 54/5 71/18
motorcycle [1] 38/10
mountain [3] 44/24 47/9 73/4
move [6] 9/24 35/11 40/14
40/15 81/1 92/10
moved [6] 39/11 39/14 48/7
52/23 53/24 63/2
Case 2:20-cr-00579-SVW Document 677 Filed 07/09/21 Page 125 of 133 Page ID
#:10854
M
moving [2] 73/15 97/6
MR [2] 4/10 4/11
Mr. [10] 5/18 10/7 34/8
78/20 79/2 79/11 82/9 87/20
92/6 103/23
Mr. Ayvazian [2] 82/9 103/23
Mr. Cruz [1] 5/18
Mr. Fenton [3] 34/8 79/11
87/20
Mr. Littrell [1] 92/6
Mr. Mesereau [2] 10/7 79/2
Mr. Ram [1] 78/20
Ms. [13] 87/18 88/2 88/7
89/3 91/13 92/18 94/15 95/5
95/7 95/21 96/6 101/14
101/23
Ms. Robinson [1] 94/15
Ms. Tarabelian [1] 88/7
Ms. Terabelian [9] 87/18
88/2 89/3 91/13 92/18 95/5
95/21 96/6 101/23
Ms. Terabelian's [2] 95/7
101/14
much [14] 14/20 16/17 16/22
43/17 55/3 55/20 66/4 78/12
86/21 87/15 91/11 93/10
99/13 103/12
multiple [2] 106/14 107/19
must [32] 8/17 8/22 11/12
11/25 13/17 14/5 17/5 19/11
20/6 23/12 24/12 24/15 25/6
26/2 26/11 26/25 27/14 28/7
28/13 29/20 30/22 31/2 32/7
34/3 36/21 68/1 89/5 102/15
104/1 106/1 106/2 106/25
my [13] 11/3 44/12 59/13
62/23 63/3 63/15 63/20 83/12
83/25 86/5 103/20 103/20
105/10
myself [1] 47/6
N
name [62]
named [2] 35/21 42/3
namely [2] 32/11 32/21
names [12] 21/6 35/7 35/7
37/8 37/13 43/12 43/14 57/6
57/17 74/7 74/8 91/24
national [2] 11/14 34/11
natural [5] 22/21 23/20
25/16 112/2 112/4
nature [2] 24/11 29/1
Nazar [15] 32/14 38/5 69/8
69/11 69/12 69/18 77/8 94/4
94/8 97/17 97/25 98/2 98/15
99/7 104/6
near [1] 18/21
nearly [1] 91/14
necessarily [3] 7/3 16/15
29/11
necessary [8] 18/19 18/22
20/1 21/3 22/21 31/9 33/17
40/10
need [20] 24/9 24/9 24/24
33/3 33/5 43/9 58/21 59/19
63/9 63/16 63/25 64/6 64/14
71/8 72/7 75/10 80/18 86/21
86/21 86/25
needed [4] 34/15 34/18 38/12
41/11
needs [3] 44/15 64/9 99/4
neither [1] 70/23
never [6] 8/12 44/15 77/6
77/22 101/9 110/15
new [5] 2/10 2/18 42/3 82/23
93/12
Newcomer [1] 2/16
Newtek [1] 43/5
next [2] 104/8 106/10
Nicholas [1] 2/22
night [3] 5/18 46/25 47/2
no [29] 1/8 14/18 20/18
27/16 39/15 62/1 62/18 62/21
64/4 88/6 93/7 94/21 94/25
95/2 96/11 96/14 96/24 97/2
99/5 99/24 100/4 100/6
100/20 101/10 103/24 105/15
105/23 112/17 114/12
No. [8] 6/9 24/17 28/1 30/18
30/25 31/3 31/3 45/3
No. 10 [1] 45/3
No. 25 [1] 24/17
No. 28 [4] 6/9 30/18 30/25
31/3
No. 29 [2] 28/1 31/3
Nobody [1] 65/10
nods [1] 105/5
none [4] 4/4 4/7 15/7 57/4
nonsense [4] 104/3 104/3
106/5 107/1
North [2] 2/6 3/20
not [161]
note [4] 7/10 52/9 58/23
106/13
notes [7] 57/7 57/9 69/12
79/4 97/23 98/16 102/9
nothing [4] 55/18 84/16 98/3
98/21
notice [3] 5/14 61/6 83/12
noticed [1] 111/18
notion [1] 92/22
November [1] 52/4
November 5th [1] 52/4
now [73]
number [21] 16/15 23/3 32/14
38/23 38/24 41/2 42/4 42/5
42/6 46/24 47/19 47/20 66/24
68/22 68/22 75/15 76/10 85/3
85/6 85/15 86/10
numbers [3] 28/9 47/5 51/10
NW [2] 2/10 2/23
NY [1] 2/18
O
o'clock [3] 6/4 112/25 113/4
oath [1] 11/23
object [3] 20/8 20/13 20/20
objected [1] 96/24
objection [1] 8/7
objections [3] 8/4 9/1 13/15
objects [4] 19/18 21/15 28/4
71/9
obligation [2] 96/14 105/11
obscured [2] 35/25 36/1
obtain [1] 25/10
obtained [3] 37/6 38/3 54/17
obtaining [2] 23/16 38/23
occur [1] 24/13
occurred [2] 24/15 30/7
October [12] 27/18 46/6 83/3
83/10 83/16 83/16 85/25 86/8
102/17 105/25 107/25 109/16
October 10th [1] 83/16
October 14th [1] 85/25
October 19th [1] 105/25
October 2020 [2] 27/18
102/17
October 20th [3] 83/16 86/8
107/25
October 28th [1] 109/16
October 9th [1] 83/10
off [1] 44/13
offense [8] 17/2 18/20 18/23
31/20 32/2 32/4 32/20 108/23
offenses [4] 18/8 18/17
31/15 31/18
OFFICE [3] 2/4 3/20 59/22
officer [1] 105/10
Official [1] 1/21
often [1] 16/1
oh [3] 63/8 96/3 98/22
okay [11] 8/2 8/24 9/23
42/24 59/7 63/19 67/8 67/9
67/14 78/17 112/21
Olaf [5] 84/5 84/15 84/16
84/19 84/23
old [2] 61/22 82/21
omitted [1] 23/18
once [4] 34/24 36/16 36/18
64/3
one [108]
ones [1] 59/22
online [1] 96/21
only [18] 13/12 16/24 17/12
18/6 19/1 19/3 24/3 25/23
25/25 48/22 51/20 67/11
67/12 80/1 95/6 102/24
108/19 112/12
open [2] 78/22 82/1
opened [2] 35/7 95/14
opening [6] 13/21 36/5 39/1
46/18 49/21 89/1
operation [1] 41/4
operations [1] 41/11
opinion [1] 11/19
opportunities [2] 33/23
107/2
opportunity [3] 15/10 34/15
105/13
order [6] 19/10 23/10 25/4
27/13 32/5 59/19
ordinary [1] 24/7
organize [1] 33/16
orientation [1] 11/15
originators [1] 20/17
other [64]
others [3] 12/1 16/12 93/18
otherwise [6] 6/2 9/4 9/13
40/12 67/19 96/1
our [2] 39/1 39/17
out [38] 9/3 12/1 21/14
23/25 24/1 24/23 25/9 34/14
34/17 38/4 39/3 41/5 44/11
44/13 54/15 54/17 58/17 63/2
66/9 67/1 74/17 83/11 89/11
92/23 93/18 93/24 94/17 95/3
96/3 96/4 96/5 96/10 100/23
104/16 105/4 105/9 105/12
107/10
outcome [1] 15/14
outline [1] 78/23
outset [2] 40/16 99/18
outside [3] 5/6 78/18 105/6
over [18] 34/20 35/3 36/10
43/15 43/15 43/16 51/11
51/11 59/2 60/13 60/13 63/23
77/9 88/21 91/21 107/9 108/1
110/18
overall [2] 10/2 21/9
overlap [2] 58/9 72/24
overwhelming [2] 73/19 88/17
own [6] 35/25 37/18 37/25
38/8 101/15 105/18
owned [2] 68/19 68/20
owner [5] 54/13 65/8 81/20
85/7 85/9
owners [2] 69/3 70/14
ownership [1] 29/1
P
p.m [1] 113/5
Pacific [1] 3/20
PAETTY [1] 2/5
page [9] 4/3 4/9 5/15 6/9
9/8 9/17 9/18 23/3 114/7
Case 2:20-cr-00579-SVW Document 677 Filed 07/09/21 Page 126 of 133 Page ID
#:10855
P
pages [1] 45/4
paid [4] 53/16 53/21 54/3
86/4
pandemic [5] 46/6 49/23 64/3
84/8 111/1
panicked [3] 108/11 108/24
109/2
panicking [1] 105/8
panics [1] 108/4
paper [3] 81/22 81/23 101/18
paperwork [1] 63/13
paragraph [1] 61/22
Paronyan [3] 35/20 51/16
76/1
part [13] 15/7 16/12 18/15
23/19 23/21 24/1 25/18 28/25
35/14 49/20 66/3 66/9 89/2
participant [4] 42/8 66/14
88/12 110/12
participants [1] 38/21
participate [2] 21/10 99/25
participated [3] 23/14 100/5
101/10
participates [1] 27/4
participating [3] 20/12
100/6 100/9
participation [1] 21/24
particular [9] 20/9 26/10
28/1 35/24 49/17 50/22 61/19
79/2 80/25
particularly [2] 50/20
112/15
parties [5] 5/8 7/21 7/24
13/10 17/13
parting [1] 33/15
partnership [1] 19/21
parts [5] 44/21 50/19 55/11
56/5 62/4
pass [1] 42/17
passed [1] 49/10
passive [1] 66/14
password [2] 96/21 97/2
passwords [1] 109/12
pattern [1] 48/15
Pause [1] 10/6
pay [10] 52/24 54/1 62/19
65/20 67/1 67/2 73/2 75/20
76/23 86/14
Paycheck [1] 40/18
paying [1] 104/9
payment [2] 49/20 54/1
payments [2] 64/8 67/18
PayPal [2] 44/5 44/6
payroll [13] 35/6 50/21
50/21 50/25 51/17 51/19
55/13 65/17 74/19 75/1 75/15
76/21 77/1
pays [3] 69/6 71/18 104/6
penny [5] 51/10 51/10 51/20
62/10 65/3
people [14] 11/21 16/1 16/2
56/21 56/21 61/18 66/17 68/2
70/15 87/23 92/3 93/4 111/2
111/4
people's [5] 35/7 57/6 57/6
97/5 97/6
percent [3] 59/4 59/4 59/5
performance [1] 21/2
performed [2] 22/2 22/14
perhaps [2] 10/20 20/5
period [4] 21/1 21/25 48/7
50/22
permission [1] 33/7
permit [1] 8/9
perpetrate [1] 34/11
person [40] 7/1 20/14 20/22
22/12 22/14 22/16 23/21
26/15 26/22 26/24 27/2 32/11
32/18 33/4 33/6 33/8 33/9
33/12 48/14 54/3 55/2 57/23
65/14 70/4 77/4 83/15 84/13
87/24 92/16 94/9 96/25 97/1
97/9 98/15 98/16 99/3 100/24
102/4 102/5 103/18
person's [4] 11/14 21/23
33/7 48/13
personal [6] 11/18 41/6
41/15 54/10 94/20 94/22
personally [3] 14/12 26/5
52/8
persons [5] 19/15 19/21
20/24 27/19 101/1
perspective [1] 111/17
pertaining [1] 48/2
Peter [2] 3/19 3/20
Phon [2] 59/20 76/19
phone [32] 18/1 42/5 49/15
49/25 52/2 52/5 55/15 55/16
57/10 60/24 60/25 61/10
61/18 63/7 68/22 68/22 69/10
70/21 85/2 85/16 97/24 98/16
101/19 102/19 109/7 109/8
109/10 109/13 109/22 109/25
110/1 110/18
phrase [1] 29/7
physical [3] 7/18 7/24 33/9
pick [2] 85/15 97/8
picked [1] 88/15
pictures [3] 61/7 61/7 70/22
piece [9] 45/20 50/16 51/3
59/6 81/21 81/23 101/18
107/12 111/13
pieces [2] 104/23 110/13
pin [1] 109/13
place [5] 59/20 67/7 67/13
82/16 112/7
placed [1] 46/8
places [5] 9/9 44/1 44/2
45/17 112/11
PLAINTIFF [2] 1/7 2/3
plan [6] 20/6 20/12 23/15
23/15 25/10 100/1
planned [2] 42/12 67/19
planning [1] 46/17
play [2] 93/14 93/14
play-by-play [1] 93/14
played [2] 39/2 54/6
players [2] 71/25 71/25
pleaded [1] 12/8
please [8] 12/3 61/22 61/23
66/13 67/7 92/9 107/8 111/7
plus [4] 69/25 85/23 85/23
85/24
point [9] 9/3 9/25 31/13
73/4 73/14 79/21 93/10 95/3
101/7
pointed [1] 94/17
points [3] 37/4 105/4 105/6
pooled [1] 73/1
pooling [1] 54/7
possessed [1] 32/10
possessing [1] 92/15
possession [12] 33/8 33/12
52/7 52/18 61/2 73/9 73/11
73/12 86/9 98/3 98/4 105/18
possible [1] 12/19
possibly [2] 10/21 101/25
Postmates [1] 95/19
power [4] 33/10 33/13 54/3
54/4
PPL [1] 82/5
PPP [40] 9/4 9/13 37/17
37/22 38/3 38/12 38/23 39/13
40/8 40/8 40/12 41/13 41/20
45/18 47/25 48/25 49/6 50/10
53/19 54/10 54/16 56/6 56/14
56/15 56/22 57/17 59/4 60/17
61/11 63/11 64/19 69/20
71/14 71/22 80/2 81/10 82/1
98/8 100/3 100/12
practically [1] 6/4
precisely [2] 18/24 27/7
precision [1] 31/5
preempt [1] 12/13
preferences [1] 11/21
prejudice [2] 11/18 15/16
prepared [2] 77/22 101/21
preparer [1] 78/7
preparing [1] 83/9
presence [7] 5/7 11/1 33/9
33/10 33/13 78/19 79/9
present [1] 26/24
presentation [1] 101/4
presented [6] 8/12 76/11
97/22 97/23 97/23 110/8
preserve [2] 8/4 8/7
president [1] 42/16
PRESIDING [1] 1/4
presume [1] 89/5
presumed [1] 12/9
presumptions [1] 101/5
pretending [1] 83/15
pretenses [1] 23/17
pretrial [4] 81/3 81/4 81/7
82/10
Pretty [1] 93/10
previewed [2] 39/3 39/16
prime [1] 99/11
prior [1] 16/20
prize [1] 72/6
probably [3] 21/21 94/9
112/24
problem [4] 8/19 102/18
107/16 108/8
problems [1] 67/3
proceedings [7] 1/13 5/6
10/6 10/25 78/18 79/8 114/6
proceeds [22] 6/11 6/18 6/24
7/2 9/12 28/16 28/22 29/2
29/8 29/10 35/12 38/15 39/7
39/11 39/14 41/4 59/16 64/12
71/12 73/17 81/9 82/25
process [1] 11/8
procured [1] 26/15
produce [3] 34/23 96/14
96/15
product [1] 61/20
program [5] 40/19 41/8 41/20
43/16 44/20
programs [1] 45/19
prohibits [1] 14/24
prominently [1] 65/22
promises [4] 23/17 25/12
25/14 25/15
promising [1] 11/24
promptly [1] 113/4
proof [13] 12/16 12/16 14/11
14/14 58/4 58/12 68/9 89/14
89/16 89/17 89/18 96/16
111/9
property [19] 6/11 6/17 6/23
7/1 9/11 23/16 23/21 25/10
25/18 27/23 28/15 28/21 29/7
29/9 29/18 29/25 30/1 30/3
84/22
prosecution [3] 88/24 89/7
90/15
prosecution's [1] 91/8
prosecutors [3] 89/8 90/11
112/8
protect [2] 104/12 108/14
Protection [1] 40/19
protects [1] 108/12
prove [18] 12/14 12/18 14/17
18/20 18/23 19/11 23/12 25/7
Case 2:20-cr-00579-SVW Document 677 Filed 07/09/21 Page 127 of 133 Page ID
#:10856
P
prove... [10] 26/9 26/11
27/6 27/14 28/13 29/20 32/7
34/3 101/25 109/5
proved [1] 22/9
proven [1] 31/19
proves [2] 12/10 21/11
provide [4] 5/23 40/22 42/11
66/25
provided [3] 28/8 52/14
52/15
proving [3] 12/14 34/4 36/22
public [1] 11/19
pulled [1] 105/4
purchase [6] 48/2 54/18
85/24 86/4 86/12 95/8
purchased [10] 37/17 37/20
37/22 38/3 38/11 38/11 49/22
52/20 54/2 71/15
purchases [5] 95/18 103/9
103/9 103/14 103/15
purely [1] 12/21
purpose [8] 14/5 20/13 20/20
91/25 94/9 100/1 100/2
111/11
purposes [5] 7/22 41/14
41/15 48/18 77/7
pursuant [2] 31/16 114/4
pushing [1] 66/2
put [13] 37/7 39/6 44/20
45/12 58/19 60/24 67/10 81/3
83/12 85/17 94/1 99/6 109/22
Q
qualify [1] 63/16
quality [5] 48/25 68/25
75/10 85/18 110/7
question [7] 18/7 47/4 62/16
62/19 62/22 69/1 78/11
questions [3] 13/15 13/18
13/19
quickly [3] 5/10 7/9 92/10
quite [2] 79/16 86/15
R
race [3] 11/14 34/13 43/9
Radius [2] 83/11 83/11
Ram [2] 2/13 78/20
ran [2] 34/17 44/13
rather [2] 24/12 104/24
reached [1] 90/14
reaches [1] 83/11
reaching [1] 13/11
read [10] 12/3 23/2 25/1
30/17 42/13 45/4 45/10 92/23
93/19 112/23
reading [3] 25/24 31/12
99/20
ready [1] 6/2
real [13] 32/18 48/14 65/14
69/2 70/4 70/10 70/17 70/24
77/4 77/9 78/6 84/22 92/16
really [18] 50/16 63/16
73/18 76/20 86/14 88/1 89/19
89/21 89/24 91/14 92/21
98/23 99/12 99/18 100/23
103/25 107/19 112/17
realty [2] 75/14 75/22
reason [14] 12/20 21/16
21/19 48/9 51/6 53/1 57/11
72/24 73/23 95/3 101/22
103/4 108/16 112/18
reasonable [46] 7/20 12/11
12/15 12/16 12/19 13/1 13/5
18/20 19/12 21/12 22/10
23/13 25/7 26/12 26/25 27/15
28/13 29/21 30/23 31/17
31/20 32/8 34/3 34/5 36/11
36/22 79/3 89/14 89/16 90/1
90/16 90/23 90/25 91/6 91/7
91/9 91/9 96/17 99/13 107/22
108/7 108/13 111/9 111/10
111/20 111/22
reasonableness [1] 15/19
reasonably [7] 18/21 22/20
24/8 24/9 24/10 24/12 94/7
reasons [3] 18/15 62/14
105/17
rebuttal [2] 33/25 113/2
recall [5] 11/23 46/18 54/8
85/18 97/22
receive [1] 23/1
received [9] 11/8 13/9 13/12
14/4 14/8 37/6 37/11 39/23
93/25
receivers [1] 64/4
receives [1] 82/25
receiving [3] 54/9 92/4
92/12
recently [2] 38/5 84/20
recess [4] 10/24 78/16 79/7
113/5
recognize [1] 85/5
recommend [1] 7/7
recording [4] 17/16 17/18
17/20 17/24
records [8] 53/18 54/11 65/7
67/17 74/10 74/11 83/6 86/3
redacted [1] 5/10
redactions [1] 5/19
Redline [4] 51/17 75/24 76/8
77/18
Redondo [1] 3/21
refer [2] 24/24 31/2
reference [3] 5/14 5/21
93/16
references [1] 47/11
referencing [1] 9/6
referred [1] 42/9
Reform [2] 18/5 31/16
regard [2] 24/17 24/23
regarding [7] 7/16 41/1
74/20 75/4 75/16 76/13 76/22
regardless [2] 39/25 80/12
regulations [1] 114/8
reject [1] 11/21
relate [1] 10/12
related [2] 9/12 71/6
relates [1] 97/15
relating [2] 57/7 81/24
relation [2] 10/17 32/20
relatively [1] 99/14
release [5] 31/21 81/3 81/5
81/7 82/10
released [3] 18/5 18/7 31/16
relevant [2] 7/25 48/9
reliable [1] 90/6
relief [8] 34/14 34/16 34/23
34/24 35/5 37/6 49/23 66/20
relies [1] 95/6
religious [1] 11/14
rely [1] 89/22
remains [1] 39/18
remarkably [1] 102/2
remember [8] 13/24 16/2 16/3
31/4 31/11 40/2 94/15 109/6
remembering [2] 31/10 111/8
reminding [1] 60/1
rent [1] 52/24
rented [1] 72/19
repairs [1] 64/9
repeatedly [1] 77/12
replies [2] 61/24 84/4
Reply [1] 84/15
report [2] 7/19 51/18
reported [1] 114/6
reporter [2] 1/21 92/7
REPORTER'S [1] 1/13
reporting [1] 44/7
reports [6] 35/6 50/21 50/21
50/25 51/19 55/14
represent [2] 6/20 50/24
representations [1] 23/17
representative [2] 41/19
83/13
represented [6] 6/11 7/2
28/15 28/22 29/7 29/10
representing [1] 9/11
represents [2] 6/17 6/24
request [1] 9/19
required [2] 12/18 27/6
requires [1] 87/22
resided [1] 53/24
residences [2] 58/7 58/8
respect [9] 26/15 41/13
41/20 48/10 54/7 80/5 80/21
80/22 80/25
respectfully [2] 36/24
112/19
respond [1] 84/1
responding [1] 108/10
responds [4] 44/10 47/6 84/9
85/12
response [1] 92/5
responsibilities [1] 36/17
responsible [11] 20/17 22/1
35/14 46/20 62/4 78/10 80/12
93/8 93/24 98/20 99/6
rest [1] 16/13
restaurant [1] 89/25
Restoration [1] 95/19
return [3] 12/5 83/4 87/3
Revenue [1] 74/4
review [4] 31/9 36/21 36/25
40/15
Rich [7] 42/3 59/12 66/2
66/8 93/12 99/8 104/17
Richard [105]
Richard's [4] 52/7 55/15
58/24 83/5
rid [2] 85/12 86/22
right [27] 7/6 8/13 14/23
34/7 41/23 46/22 49/19 59/13
60/23 63/2 63/4 63/16 70/25
86/10 87/19 90/11 91/20
94/18 96/3 96/4 103/17
103/25 104/4 105/17 105/21
111/20 112/23
risk [1] 112/11
Road [1] 3/12
Robinson [2] 45/11 94/15
role [19] 36/1 39/16 39/17
39/25 54/6 54/9 55/24 61/13
61/25 61/25 61/25 62/3 64/18
72/13 87/24 88/10 88/13
88/15 88/15
roles [4] 38/20 39/2 59/18
88/10
room [2] 11/5 31/9
Rosa [1] 57/3
routing [1] 66/24
row [1] 90/1
RPR [1] 114/12
Runyan [21] 49/4 49/7 49/8
49/25 53/8 53/13 53/17 53/20
53/21 53/25 59/12 60/4 60/6
65/12 67/2 74/6 77/24 77/25
78/7 78/8 94/2
Runyan's [2] 65/12 80/1
Ryan [1] 3/7
S
Sabala [14] 57/1 57/15 57/25
58/11 72/14 72/21 72/23
74/16 74/18 74/22 85/1 85/2
85/4 85/13
Case 2:20-cr-00579-SVW Document 677 Filed 07/09/21 Page 128 of 133 Page ID
#:10857
S
said [26] 8/16 10/4 12/4
13/20 15/24 16/9 34/1 49/20
52/14 56/1 60/23 62/21 63/19
74/1 75/8 77/22 80/1 83/25
85/3 85/14 87/22 95/11 99/17
101/22 102/1 106/13
same [32] 16/3 17/23 21/4
22/17 36/4 43/11 43/14 46/23
47/20 47/22 51/10 51/18 52/7
53/19 57/8 62/8 62/10 64/25
65/3 67/7 68/22 73/1 75/21
76/8 76/25 77/14 90/4 94/9
102/4 102/5 102/18 104/17
samples [1] 68/3
San [2] 2/21 3/6
Santa [1] 3/15
sat [1] 70/5
save [3] 38/13 41/11 41/11
saw [10] 14/13 37/25 38/7
51/1 64/23 73/8 73/10 94/16
107/20 109/22
say [25] 8/17 9/12 13/21
15/23 29/14 31/10 31/11 33/4
34/2 34/2 44/8 47/1 55/21
55/21 65/16 78/10 86/13
86/23 98/22 98/23 99/24
103/5 111/15 112/12 112/12
saying [7] 44/3 44/9 74/7
91/6 103/24 105/24 105/24
says [49] 6/22 9/10 15/7
42/24 43/15 43/23 46/21
46/23 46/24 47/6 48/1 50/5
55/7 55/8 59/2 59/7 59/24
63/8 63/10 63/17 63/18 66/12
67/5 67/6 68/9 73/8 75/1
76/9 81/19 83/11 83/15 83/22
84/5 84/15 85/14 85/17 86/20
87/20 89/7 94/23 95/22
102/14 103/19 104/11 106/11
106/22 107/5 107/24 109/18
SBA [9] 40/19 40/24 41/5
41/16 42/22 66/19 69/13
73/22 73/22
scene [1] 26/24
scheme [13] 21/6 21/10 23/15
23/15 23/19 24/1 24/2 24/14
24/16 25/10 53/3 100/7 100/9
scope [1] 22/19
SCOTT [1] 2/5
screw [1] 96/12
screwing [1] 105/2
scroll [1] 110/4
seal [1] 78/24
seated [1] 78/21
Seattle [1] 53/19
second [17] 6/9 19/17 21/16
22/12 23/4 23/18 25/13 26/14
28/3 29/24 32/17 38/18 42/8
45/9 51/3 55/17 75/21
Section [20] 6/21 19/7 19/8
22/25 23/11 24/20 25/5 27/11
27/20 27/24 28/10 28/17
28/18 28/19 29/19 30/6 30/6
30/19 31/24 114/4
Secureline [1] 75/21
Security [2] 45/24 70/5
see [50] 7/6 8/13 15/11 16/3
43/20 44/3 44/7 45/17 48/15
48/24 49/1 49/4 49/16 51/14
54/9 54/12 55/14 61/1 61/9
62/1 62/3 62/9 63/4 63/20
66/22 68/7 72/17 72/20 73/11
77/15 83/18 84/18 86/4 87/10
88/1 88/3 90/4 93/16 93/17
95/17 95/24 96/1 98/1 103/14
105/1 105/4 109/10 111/19
111/22 113/4
seeing [2] 34/15 94/5
seen [6] 14/6 35/3 36/10
79/20 82/22 104/14
sees [1] 111/21
seize [2] 109/7 109/8
seized [2] 46/2 52/2
self [2] 40/22 41/9
self-certification [1] 41/9
self-certifications [1]
40/22
send [5] 66/2 66/6 66/24
67/12 84/3
sending [1] 72/14
sends [3] 65/11 65/15 84/10
sense [7] 12/20 55/7 63/14
63/23 64/15 75/9 111/20
sensible [1] 7/20
sent [5] 47/18 52/11 65/16
67/12 100/19
separate [5] 17/3 43/15 47/4
80/9 82/15
separated [1] 108/3
separately [1] 17/7
seriously [1] 111/16
service [9] 50/1 53/9 53/13
53/17 60/4 65/12 65/13 74/4
77/24
Services [6] 49/5 49/8 53/20
53/21 53/25 65/12
session [2] 1/16 14/7
seven [3] 1/15 15/19 46/25
several [2] 53/5 82/7
sexual [1] 11/15
shared [2] 44/21 71/21
shares [1] 81/18
sharing [1] 45/18
she [137]
sheet [1] 91/12
ship [1] 103/20
shipped [2] 52/13 52/13
shit [1] 43/3
short [2] 21/24 78/15
should [20] 5/15 8/16 8/17
8/21 8/22 9/12 11/13 12/5
15/1 16/4 17/8 18/1 18/14
19/2 30/20 52/6 67/10 86/14
111/15 111/17
shouldn't [2] 55/21 86/23
show [15] 10/14 26/25 42/15
43/8 46/17 48/12 50/13 50/17
52/12 53/18 59/3 91/3 97/19
101/6 104/25
showed [6] 41/24 42/5 43/13
50/8 58/10 79/25
showing [6] 50/9 56/2 61/10
61/18 71/1 83/4
shown [2] 17/17 17/17
shows [17] 34/21 36/11 45/14
45/16 47/9 52/17 58/8 59/5
65/7 71/24 73/4 73/5 76/6
76/11 81/14 88/18 108/9
sic [2] 23/12 77/21
side [3] 5/11 5/12 5/15
sides [1] 91/2
sign [2] 44/9 78/9
signaling [1] 106/23
signatory [2] 54/13 65/8
signature [2] 95/13 102/7
signatures [2] 94/6 102/1
signed [3] 44/9 64/20 94/20
signer [3] 96/24 99/7 99/10
significant [3] 64/18 81/23
93/18
signing [1] 84/1
Silverman [1] 2/22
similar [5] 20/4 57/8 60/24
76/2 102/2
similarities [1] 57/24
similarly [4] 13/20 20/22
24/23 41/9
simple [2] 59/4 93/22
simply [1] 20/3
since [3] 7/21 49/10 64/6
single [3] 12/1 39/18 110/16
sir [3] 10/23 62/18 62/21
sister [1] 35/18
sister-in-law [1] 35/18
sits [2] 82/7 82/7
sitting [2] 31/11 73/16
Six [1] 15/17
sixth [1] 49/4
Sixty [2] 69/24 69/25
skeptical [1] 89/6
sleep [1] 47/2
slide [1] 71/24
slow [1] 92/7
small [6] 34/14 34/18 35/15
35/22 40/17 110/25
smaller [1] 72/13
smallest [2] 39/16 64/18
smiley [1] 43/6
so [52] 7/7 10/3 11/24 31/5
31/9 32/19 33/18 38/12 41/22
42/24 43/17 55/19 55/19
63/10 63/15 67/6 67/7 67/12
68/1 78/8 85/15 88/15 91/10
92/1 92/8 92/12 92/19 93/19
93/20 94/6 94/11 95/11 95/12
97/12 98/5 98/20 99/9 99/12
99/17 101/12 102/2 102/23
105/3 105/17 105/25 106/8
107/3 107/6 110/6 111/7
112/19 113/3
so-called [1] 105/25
Social [1] 45/24
software [1] 59/23
sold [1] 52/21
sole [2] 54/13 65/8
solely [2] 11/12 14/8
solution [2] 78/5 85/17
Solutions [9] 49/1 78/3 78/4
79/14 81/11 81/21 81/24 82/6
82/17
some [35] 6/18 6/25 7/2
10/15 12/1 16/11 17/21 18/16
20/13 20/20 23/5 24/13 28/22
29/8 29/10 37/5 41/24 45/8
50/14 50/15 50/25 51/12 56/9
68/2 74/14 80/17 85/11 90/17
97/20 100/9 101/7 107/18
108/5 109/5 111/13
somebody [12] 50/2 66/15
68/18 97/8 99/2 99/14 100/13
108/2 108/25 111/11 111/14
111/21
somebody's [1] 106/20
someone [7] 22/11 26/8 26/13
52/13 69/21 70/25 93/1
something [20] 15/23 15/24
16/8 19/23 33/8 33/13 34/2
34/3 34/6 61/16 64/3 80/23
81/3 85/15 87/18 93/2 100/10
109/13 111/14 111/21
Sometimes [2] 15/23 15/25
somewhat [1] 99/22
somewhere [1] 52/3
soon [2] 42/15 64/2
sorry [7] 47/23 78/11 78/16
84/9 92/8 100/14 104/7
sort [6] 10/15 91/12 91/16
91/21 101/17 103/7
sound [1] 93/4
source [1] 29/1
speak [2] 87/14 107/20
speaking [2] 34/8 80/11
Spear [1] 2/20
special [3] 7/23 83/7 84/17
specific [4] 17/11 17/12
Case 2:20-cr-00579-SVW Document 677 Filed 07/09/21 Page 129 of 133 Page ID
#:10858
S
specific... [2] 18/20 32/20
specified [6] 18/22 18/23
25/11 25/21 27/23 29/18
specifies [1] 6/16
speculate [1] 18/14
speculation [1] 12/21
spend [3] 35/2 35/12 69/23
spending [2] 71/10 71/15
spent [11] 7/11 39/11 53/12
53/14 53/14 64/7 64/11 64/16
69/22 71/12 72/3
spoke [4] 55/12 59/25 77/3
79/15
spoken [3] 17/24 77/11 83/1
spouses [1] 93/17
Spring [1] 2/6
stand [8] 37/22 38/11 62/12
68/15 75/2 77/21 85/19 112/6
standard [2] 89/12 89/18
starkly [1] 95/25
start [1] 93/7
started [3] 42/22 88/20 98/9
state [4] 7/4 13/25 74/11
86/15
stated [1] 17/14
statement [6] 43/2 46/18
49/21 86/10 96/18 105/10
statements [11] 13/15 13/21
23/18 24/4 25/12 25/13 25/15
36/5 39/1 74/12 74/17
states [22] 1/1 1/4 1/6 2/3
17/11 19/8 19/9 22/25 23/12
24/20 25/6 27/12 27/21 27/25
28/11 28/18 30/8 31/25 48/7
48/16 114/5 114/9
statistics [1] 69/14
status [1] 18/11
statute [4] 6/13 6/21 6/22
9/21
stay [3] 95/18 95/20 107/9
stay-at-home [2] 95/18 95/20
stealing [3] 85/8 100/3
100/3
stenographically [1] 114/6
STEPHEN [1] 1/3
steps [1] 40/12
Steptoe [4] 2/14 2/17 2/19
2/22
stereotypes [1] 11/20
sticks [1] 100/23
still [2] 5/13 100/21
stole [3] 60/15 77/13 77/16
stolen [9] 33/6 35/4 35/8
37/3 37/12 74/8 74/18 98/12
108/6
store [1] 85/24
stored [1] 110/2
story [5] 62/13 76/25 77/14
89/9 93/10
straight [1] 47/3
straightforward [2] 91/6
105/9
strangers [1] 66/16
Street [10] 1/22 2/6 2/14
2/20 3/8 55/25 60/11 88/5
88/6 102/12
stricken [1] 14/2
strike [1] 10/8
strokes [1] 91/22
strongly [1] 42/13
struck [1] 87/18
student [3] 48/6 70/9 79/17
students [2] 48/16 70/12
stuff [3] 60/24 97/25 109/9
submit [12] 34/23 40/11
60/21 63/11 75/11 77/25
78/21 80/2 80/13 80/19 92/2
93/21
submitted [26] 7/23 39/12
40/3 40/4 40/8 40/9 40/13
48/4 51/5 51/16 53/6 56/15
64/23 68/18 69/20 71/2 75/6
75/25 76/15 77/13 79/14
79/22 80/14 80/18 91/25
106/3
submitting [3] 91/22 93/8
103/23
subscriber [6] 60/9 60/9
60/11 60/19 60/19 71/3
subsection [2] 24/20 25/5
subsections [1] 30/16
subsequently [1] 82/14
subset [1] 7/18
substantive [1] 80/9
success [1] 21/22
successfully [1] 44/8
such [5] 14/11 19/3 24/8
29/1 29/13
sufficient [1] 80/16
suggest [1] 45/9
suggesting [1] 46/19
suggestion [5] 7/20 12/4
58/24 72/8 85/23
suggests [2] 8/9 55/4
Suite [8] 1/22 2/15 2/20 3/5
3/8 3/13 3/16 3/21
sum [1] 95/24
summaries [2] 18/25 19/1
summary [6] 43/13 45/10 50/8
62/9 71/7 76/6
SUN [1] 2/5
support [5] 51/5 75/6 76/16
91/4 101/10
supported [1] 104/16
supporting [4] 19/2 46/12
51/8 62/8
supposedly [2] 51/18 69/11
sure [3] 5/25 10/17 60/25
survive [2] 34/15 34/19
suspect [2] 10/20 99/11
Suzanna [3] 50/2 52/6 73/7
SVW [1] 1/8
sworn [1] 13/8
sympathy [1] 11/18
synthetic [5] 35/4 37/3 39/8
79/18 79/22
T
take [20] 5/24 15/9 43/8
54/21 55/23 63/17 63/18
71/22 74/14 78/8 78/15 87/15
95/12 99/19 101/3 107/8
107/9 111/15 112/5 112/24
taken [8] 48/17 74/17 79/17
82/4 87/16 109/15 109/25
110/19
takes [2] 58/25 82/16
talk [18] 43/18 46/11 66/1
67/3 69/13 72/5 79/13 85/1
88/16 89/15 89/20 90/18
92/15 102/16 111/8 111/12
111/14 113/3
talked [3] 44/1 72/16 80/12
talking [4] 59/17 84/19 85/1
88/2
talks [1] 68/8
Tam [1] 43/3
Tamara [42] 35/18 36/6 39/19
42/8 42/18 42/19 42/24 43/23
44/10 44/14 45/3 46/17 46/19
47/21 56/15 56/20 57/5 58/5
58/19 59/2 59/21 59/24 60/23
62/15 62/16 63/11 64/23
65/23 67/25 68/1 68/4 68/23
72/21 75/14 81/18 83/20 84/4
84/13 84/15 85/10 85/14
102/13
Tamara's [2] 35/18 61/25
Tammy [5] 42/9 63/15 67/5
93/12 102/22
Tams [1] 83/23
Tarabelian [2] 88/7 88/11
target [1] 70/13
targets [1] 69/3
tax [20] 35/6 49/4 49/8
49/25 51/4 53/8 53/13 53/17
53/20 53/21 53/25 60/4 65/2
65/12 65/12 65/13 77/24 78/7
80/3 94/2
taxes [4] 62/20 63/12 63/21
75/7
teaming [1] 71/20
telephone [4] 42/4 42/6
47/19 47/20
tell [14] 55/17 55/18 66/5
71/8 86/15 86/15 86/16 89/8
104/24 105/18 107/3 107/6
108/8 112/3
telling [1] 105/12
tells [3] 72/7 86/24 107/4
ten [2] 78/14 89/25
tendency [2] 23/20 25/16
TERABELIAN [76]
Terabelian's [24] 37/24 38/4
38/7 49/22 51/24 52/5 54/5
57/10 57/23 70/2 71/18 72/10
76/24 94/14 95/7 95/13 98/4
98/15 99/7 101/14 104/7
104/8 109/10 109/21
term [2] 6/23 30/9
terms [1] 67/4
testified [15] 15/1 15/11
16/8 16/10 37/22 40/20 40/21
40/23 41/7 41/15 45/11 50/25
68/15 70/6 94/15
testify [11] 12/12 14/23
14/25 16/16 83/7 104/15
111/24 111/24 112/4 112/13
112/16
testifying [2] 15/13 95/11
testimony [19] 13/8 13/12
14/2 14/12 15/2 15/2 15/5
15/6 15/8 15/18 15/20 16/5
16/6 16/18 16/22 48/4 49/7
74/6 81/4
tests [1] 66/13
text [39] 41/24 42/1 43/7
43/8 43/15 44/3 45/2 45/8
47/5 47/19 47/20 47/23 50/14
52/10 52/12 58/18 59/9 59/11
59/17 62/1 65/23 66/1 66/12
66/15 66/22 68/3 68/4 68/23
81/17 83/19 83/20 83/24 84/7
84/24 93/11 93/13 102/22
103/17 109/11
texts [4] 42/9 42/11 42/14
46/16
than [8] 6/20 27/16 30/1
33/12 71/5 80/6 92/10 104/24
Thank [7] 10/23 34/9 61/23
79/12 87/6 87/7 92/11
that [708]
That's [2] 5/22 58/24
theft [8] 31/24 32/6 48/11
68/11 69/8 92/14 92/20 97/15
their [33] 13/20 13/21 16/17
33/20 33/24 35/25 36/1 37/7
37/12 37/18 39/25 41/21
43/19 44/21 48/17 49/12
52/23 53/24 59/18 61/10
66/15 72/1 74/7 74/8 75/20
83/3 89/1 89/2 89/9 90/4
93/18 97/21 107/15
them [33] 11/10 13/14 13/24
13/25 13/25 19/3 35/21 37/25
Case 2:20-cr-00579-SVW Document 677 Filed 07/09/21 Page 130 of 133 Page ID
#:10859
T
them... [25] 38/7 43/8 44/4
44/7 44/21 46/25 47/12 55/9
55/19 66/21 69/4 70/20 70/22
70/23 73/24 73/25 78/10
80/19 84/3 99/21 101/5 101/5
104/4 107/9 108/4
themselves [3] 40/11 69/22
80/19
then [47] 5/11 9/10 23/5
33/23 37/8 38/4 44/7 44/21
47/4 48/19 49/16 50/7 51/14
54/20 55/2 59/24 61/9 61/19
63/6 66/12 66/22 66/25 67/3
67/6 69/22 71/14 71/24 74/9
74/10 77/18 78/3 78/9 79/17
81/21 82/6 82/13 84/10 88/14
96/2 98/10 98/11 100/5 102/8
107/5 112/8 112/25 113/1
theoretical [1] 61/15
theory [2] 98/13 109/7
there [118]
thereby [1] 20/21
therefore [4] 19/3 22/7
40/10 85/25
these [78]
they [198]
THIBODEAUX [2] 1/21 114/12
thing [17] 36/4 38/18 55/6
73/1 73/25 75/21 76/8 78/20
80/20 86/13 94/6 99/6 102/3
103/6 104/8 106/10 111/18
things [23] 7/12 13/13 15/11
16/1 16/11 26/23 34/4 36/25
43/19 50/20 52/19 53/14
55/14 60/24 81/25 82/5 87/23
94/16 95/20 99/21 101/13
106/12 111/19
think [35] 6/2 7/20 8/9 8/21
16/10 16/12 16/17 19/3 63/15
73/18 78/12 78/15 85/6 87/3
89/10 89/21 90/8 90/12 92/23
94/7 96/19 97/11 99/3 100/9
100/23 100/24 101/3 103/11
103/13 108/24 110/7 110/7
111/13 112/21 112/24
thinks [2] 55/6 85/10
third [11] 21/19 22/14 23/22
25/15 26/17 28/24 30/1 32/19
40/2 45/20 82/23
Thirty [2] 9/10 69/25
Thirty-five [1] 9/10
this [260]
Thomas [1] 3/14
those [41] 5/19 6/11 6/20
7/21 7/24 9/20 17/14 21/17
28/9 30/24 33/19 34/16 34/24
35/2 37/8 37/9 37/23 38/5
41/4 42/11 42/13 45/8 46/10
46/12 47/5 49/1 52/12 52/13
58/8 59/22 61/13 66/6 68/4
87/13 92/5 94/6 95/24 98/18
99/20 99/24 103/9
though [6] 7/3 20/14 21/8
29/10 63/3 91/14
thousand [1] 64/3
thousands [1] 110/1
three [18] 6/11 6/20 13/10
15/13 30/24 33/15 36/25
47/13 68/12 73/2 79/20 83/23
89/12 96/7 101/13 101/18
104/22 110/13
threw [1] 40/17
through [36] 7/11 7/14 7/23
18/9 22/23 23/8 23/9 24/18
25/24 26/1 28/9 30/12 30/15
30/22 31/2 31/15 37/11 38/19
39/20 40/25 45/5 48/3 60/3
64/24 68/4 72/14 74/15 81/1
83/16 86/7 90/17 91/19 97/6
100/18 110/4 111/12
THURSDAY [2] 1/17 5/1
tidy [1] 55/6
tie [2] 53/10 60/18
tied [2] 51/12 51/14
ties [6] 42/4 42/5 57/22
60/8 69/8 104/23
time [28] 6/3 21/2 21/4
21/25 22/17 34/13 43/8 43/9
48/7 70/8 74/14 75/22 84/6
84/25 87/15 89/22 89/23 90/1
90/2 90/7 98/9 98/9 99/19
103/9 103/22 103/24 103/25
112/22
Timeline [4] 38/16 49/18
67/22 77/3
Timepiece [3] 37/21 47/18
52/11
Timepieces [1] 103/19
times [3] 13/22 63/7 90/1
tires [1] 64/9
Title [16] 19/7 19/9 23/11
24/20 25/6 27/11 27/21 27/24
28/11 28/17 28/19 28/20
29/19 30/5 31/24 114/4
to apply [1] 39/10
today [5] 42/22 43/24 44/4
44/9 58/22
together [19] 9/20 34/21
34/23 35/1 35/23 36/19 39/6
44/21 45/12 50/14 58/3 60/22
62/1 62/2 62/20 66/18 73/2
88/25 89/2
told [15] 16/11 24/22 38/12
41/19 47/5 47/7 55/25 59/2
62/13 63/3 63/15 63/24 68/16
75/2 79/1
Tom [1] 59/2
tons [3] 102/21 109/11
109/11
too [3] 87/15 92/25 103/13
took [13] 11/23 37/8 37/21
40/12 62/12 68/18 69/21
70/16 77/9 77/21 80/1 85/19
106/13
top [5] 42/19 48/25 68/25
75/10 85/17
Topeka [1] 54/19
total [1] 95/24
totally [2] 42/19 70/23
touch [1] 43/22
toward [1] 64/10
towards [1] 64/7
Tower [1] 2/20
Towing [2] 65/1 74/24
TQ [1] 68/21
tracking [1] 61/11
transaction [13] 6/17 7/2
9/11 28/15 28/24 29/3 29/3
29/9 29/23 29/24 30/7 30/9
84/22
transaction' [1] 6/24
transactions [3] 21/3 27/23
29/17
transcript [7] 1/13 5/16
17/18 17/19 17/23 114/6
114/7
transcription [2] 5/11 5/13
transfer [5] 30/10 54/17
82/10 82/12 82/16
transferred [2] 32/9 82/14
transferring [2] 54/7 72/1
transfers [1] 35/10
translation [2] 5/12 17/19
translator [1] 54/25
Transport [5] 38/17 49/18
67/22 74/24 77/3
travel [2] 83/9 83/12
traveled [1] 70/8
traveling [2] 83/14 83/14
treat [1] 15/1
tremendous [1] 112/11
trial [13] 1/15 7/25 14/9
17/1 17/5 18/12 18/15 36/4
49/7 53/1 81/7 87/13 108/22
tried [5] 34/13 34/16 107/18
107/20 108/25
trove [1] 109/12
trucking [3] 58/23 62/17
64/8
true [8] 16/12 63/14 64/16
76/12 104/17 106/12 106/18
114/5
trust [1] 62/14
trusted [1] 63/11
truth [3] 16/11 89/9 105/12
truthful [1] 41/21
try [4] 37/1 55/19 66/25
88/25
trying [3] 43/22 99/20
108/13
Tuesday [1] 67/6
Turing [10] 48/25 78/3 78/3
78/4 79/13 81/11 81/20 81/24
82/6 82/16
Turks [7] 46/5 83/2 83/9
83/16 83/19 84/7 84/25
turned [1] 79/19
turns [1] 99/18
Twelfth [1] 2/6
twice [1] 78/8
two [37] 13/9 15/12 16/2
19/15 19/21 27/18 27/22
36/13 36/14 38/21 38/24
40/18 42/2 42/10 43/5 44/4
49/1 50/20 54/23 57/13 67/18
70/22 70/22 70/22 71/9 82/20
89/5 90/13 93/17 98/5 101/16
105/25 107/25 109/16 110/3
110/17 110/19
two-and-a-half [2] 109/16
110/19
type [4] 40/23 66/10 70/15
73/25
types [1] 56/10
U
U.S [3] 1/21 2/4 2/4
U.S.C [1] 6/16
Uber [1] 95/19
ultimately [2] 31/8 72/2
unconscious [2] 11/19 11/20
under [8] 7/4 18/5 18/8 22/5
28/10 29/19 78/24 80/15
underlying [2] 19/2 19/4
understand [4] 13/18 43/10
99/21 111/3
unintentionally [1] 26/23
unique [5] 52/19 53/14 61/13
61/17 62/3
UNITED [21] 1/1 1/4 1/6 2/3
19/7 19/9 22/25 23/12 24/20
25/6 27/12 27/21 27/25 28/11
28/18 30/7 31/25 48/6 48/16
114/5 114/9
unknowingly [1] 26/23
unlawful [11] 6/18 6/19 6/25
9/12 19/23 20/12 21/6 27/24
28/22 29/8 29/18
unless [2] 12/9 17/11
until [5] 12/9 27/17 33/19
82/7 107/9
untrue [1] 16/5
untruthfully [2] 16/8 16/11
up [21] 12/6 55/6 63/10
66/10 66/11 66/13 68/15
Case 2:20-cr-00579-SVW Document 677 Filed 07/09/21 Page 131 of 133 Page ID
#:10860
U
up... [14] 69/13 71/20 83/23
83/23 85/15 87/15 87/16 94/1
95/24 96/13 99/6 99/19 105/2
112/3
update [1] 79/5
updated [1] 90/5
upon [4] 12/20 19/24 21/21
83/3
urge [1] 111/3
us [9] 2/9 59/10 87/13 89/21
91/12 97/20 107/6 107/12
112/2
usage [1] 83/5
use [21] 7/7 10/14 24/8 29/4
41/14 43/1 43/11 47/5 48/1
51/10 61/22 74/21 75/4 75/16
76/13 76/22 77/6 81/19 87/21
91/2 91/12
used [38] 7/21 14/17 23/24
23/25 24/5 24/7 32/10 33/6
35/11 39/7 41/5 41/17 42/6
48/18 49/19 52/19 52/24 53/3
53/11 54/1 56/13 56/22 57/17
61/14 64/25 69/21 74/18
75/12 76/2 77/19 77/23 78/6
79/21 80/3 81/25 82/4 84/21
89/1
user [3] 54/4 96/21 97/1
uses [2] 47/20 47/25
using [20] 35/7 37/22 38/3
38/16 43/14 53/6 53/16 61/19
62/8 62/10 64/25 68/23 71/14
76/1 79/22 80/2 86/1 86/4
92/15 98/11
utilities [2] 71/18 104/10
V
vacation [1] 46/5
VAHE [27] 3/18 30/13 35/19
36/5 37/7 38/15 39/15 45/7
57/3 59/13 60/20 62/11 64/17
64/17 65/14 65/22 66/2 66/7
66/9 66/24 67/8 67/9 67/16
68/1 68/9 71/13 72/13
Vahe's [1] 67/11
Vahe314 [1] 67/11
value [1] 30/1
variety [1] 81/25
various [5] 40/25 47/10 72/2
72/14 74/11
vast [1] 109/12
Vaughan [1] 3/7
venture [2] 21/22 27/5
verdict [11] 12/5 13/11
14/24 17/7 17/8 33/18 87/3
87/4 89/14 91/10 91/11
Verdui [1] 54/4
version [1] 60/6
versions [3] 16/1 47/13
79/20
very [16] 7/19 39/2 78/15
89/17 89/18 89/21 90/6 90/16
91/5 92/23 98/8 102/4 103/12
105/9 108/16 111/25
victim [1] 74/5
Victoria [48] 39/10 46/2
49/5 49/9 50/3 50/4 52/1
52/16 52/21 53/6 53/8 57/1
57/21 65/13 65/14 69/6 71/21
71/23 72/19 73/6 78/1 88/16
88/17 94/7 101/23 102/1
102/3 102/6 102/15 102/20
102/23 103/2 103/4 103/6
103/8 103/12 103/13 103/15
103/21 103/25 104/6 104/11
104/12 105/22 106/2 106/2
106/4 109/6
video [1] 104/25
view [2] 91/4 109/4
violation [18] 19/7 19/8
22/24 23/11 24/19 25/5 27/11
27/20 27/24 28/17 28/18
28/19 30/5 30/5 30/6 30/15
30/19 31/24
visas [2] 48/17 70/12
VLA [2] 57/16 57/25
VOLUME [1] 1/16
volumes [1] 56/2
Voyage [2] 57/2 76/9
W
wait [3] 67/8 67/13 95/22
waiting [1] 97/19
wake [1] 66/10
wakes [1] 66/13
waking [1] 66/11
walked [1] 40/25
want [18] 8/7 10/21 62/25
63/4 67/9 67/12 80/20 83/11
87/15 87/16 88/20 89/8 89/9
90/22 91/3 92/10 103/20
106/16
wanted [2] 95/3 99/6
wants [7] 55/9 59/9 65/24
65/25 66/12 66/15 104/12
was [145]
Washington [2] 2/10 2/23
wasn't [2] 65/18 76/7
watches [5] 37/20 37/23
52/12 52/13 103/20
water [1] 54/3
way [21] 9/20 13/25 20/19
29/6 43/20 43/20 79/3 89/22
90/8 90/12 91/3 91/6 93/24
96/20 100/5 100/15 105/14
110/1 111/19 111/21 112/10
ways [1] 20/5
we [138]
we've [2] 66/2 79/25
wearing [1] 112/10
web [1] 81/20
WebBank [1] 44/6
Weddington [7] 55/16 55/25
60/11 72/20 88/5 102/8
102/12
Wednesday [1] 67/6
week [1] 43/6
Weeks [2] 42/21 43/4
weigh [1] 11/7
weight [6] 14/18 14/20 16/14
16/17 16/22 19/3
well [45] 6/21 8/5 35/9
39/14 43/7 47/9 49/25 51/21
53/9 55/16 56/2 56/7 56/16
57/10 58/10 58/12 60/5 61/9
61/12 61/21 62/11 64/6 64/22
67/6 67/25 68/1 68/8 69/17
70/11 70/21 72/21 73/13
75/13 77/2 77/17 80/4 80/10
82/13 84/25 85/14 91/5 98/22
100/18 102/4 102/14
went [19] 34/18 54/17 64/2
70/9 74/22 74/22 75/5 75/5
75/19 76/5 76/7 76/14 77/10
83/2 94/14 95/23 97/15 106/8
107/21
were [64]
weren't [1] 64/5
West [3] 1/22 2/14 3/8
WESTERN [1] 1/2
what [98]
what's [2] 83/23 89/13
whatever [5] 10/21 21/20
55/21 67/15 90/24
when [31] 9/23 14/6 24/6
24/7 27/4 43/19 44/8 44/20
46/8 47/24 52/12 59/11 65/16
74/7 80/11 81/4 83/8 83/18
83/24 84/25 86/7 88/9 90/2
92/1 93/14 94/24 95/11 95/16
96/22 99/20 106/13
where [25] 31/12 45/17 47/11
47/13 48/15 51/9 52/23 53/23
63/7 66/6 67/21 69/25 71/3
71/17 72/17 72/20 76/5 76/7
76/14 83/14 84/5 90/13 97/4
103/23 105/11
whether [13] 11/11 15/17
16/21 16/24 18/7 19/24 24/2
31/19 41/21 80/12 105/12
108/19 109/22
which [51] 7/3 7/17 13/10
14/14 15/5 15/5 17/18 18/12
20/9 20/19 23/3 24/4 27/7
27/8 28/2 28/12 29/5 29/11
29/20 36/21 41/8 44/1 51/4
52/6 52/21 52/25 53/7 53/22
54/24 55/1 57/8 57/9 57/19
58/12 59/20 60/20 66/21 80/9
80/23 80/24 82/22 87/4 87/7
89/6 95/21 98/10 101/5
101/16 105/19 109/6 110/15
while [7] 15/13 31/16 31/20
35/13 70/9 81/7 82/10
who [64]
whoever [2] 6/16 55/21
whole [4] 24/5 28/25 93/10
111/11
whom [3] 21/18 57/4 71/21
whose [8] 48/13 56/12 56/21
57/17 60/14 62/22 70/15
79/17
why [17] 10/17 18/15 41/2
48/9 50/25 51/6 53/1 57/11
62/14 62/24 65/24 72/9 72/9
94/11 107/14 107/15 112/5
wife [9] 35/16 36/7 49/10
52/14 62/16 75/8 103/20
103/20 104/1
wife's [1] 52/14
will [78]
willful [2] 88/12 110/12
willfully [6] 20/12 20/16
96/8 96/9 99/25 100/6
Williams [2] 3/4 3/7
WILSON [3] 1/3 36/20 80/24
wire [63]
wires [4] 66/23 67/4 95/24
97/9
wiring [1] 24/6
Wirsching [1] 3/12
wish [2] 25/3 78/21
wishes [1] 87/8
withdrawal [1] 30/10
within [3] 22/19 46/23 81/15
without [5] 11/22 21/5 32/10
33/7 105/1
witness [20] 4/3 13/9 13/18
14/12 14/12 15/3 15/7 15/8
15/11 15/23 16/7 16/9 16/10
16/19 16/22 16/23 48/3 70/5
95/11 96/19
witness' [6] 15/12 15/13
15/14 15/16 15/18 15/19
witnesses [7] 13/17 15/25
16/15 16/17 68/14 74/3 74/3
woman [2] 48/5 70/7
won't [6] 25/1 62/14 63/12
63/21 78/23 93/16
word [2] 5/24 68/7
words [4] 8/21 10/14 24/3
89/1
work [7] 62/1 67/5 67/20
78/1 87/10 91/12 91/17
worked [7] 34/21 34/22 35/1
Case 2:20-cr-00579-SVW Document 677 Filed 07/09/21 Page 132 of 133 Page ID
#:10861
W
worked... [4] 35/21 35/23
62/2 69/11
working [7] 47/2 58/2 60/22
64/5 66/18 89/2 90/4
workings [1] 45/5
works [1] 93/5
worried [2] 55/5 108/5
worries [1] 108/4
worry [1] 63/9
worth [1] 45/4
would [25] 7/7 8/19 9/19
15/2 24/11 24/13 38/18 41/4
41/5 42/13 44/25 45/20 46/20
52/19 79/4 80/16 97/11 98/18
101/6 105/14 110/4 111/7
112/3 112/4 112/5
wouldn't [4] 31/11 67/20
75/7 100/21
writes [6] 42/19 42/21 43/1
43/4 44/14 85/5
writing [1] 84/6
wrong [2] 55/18 85/14
Y
yahoo.com [1] 67/11
yeah [2] 46/24 63/17
year [2] 51/20 84/21
years [4] 84/20 109/16 110/3
110/19
yes [14] 6/1 6/7 7/10 7/13
7/16 8/3 8/5 8/23 10/1 10/10
10/19 10/23 63/18 79/5
yesterday [7] 7/19 9/15 10/4
44/4 62/13 78/22 79/2
yet [4] 63/11 64/11 65/14
88/2
York [2] 2/10 2/18
you [454]
your [59]
yourself [1] 11/17
yourselves [1] 33/16
Z
Zhadko [38] 39/8 42/6 46/2
47/9 47/10 48/5 48/5 48/22
48/23 49/16 49/16 54/2 65/21
68/21 68/25 70/7 71/16 73/3
77/4 78/6 79/15 79/16 79/16
79/23 82/11 82/13 82/19
82/21 82/24 83/5 83/10 83/15
84/9 86/1 94/2 94/8 102/2
104/7
Zhadko's [1] 78/5
Zindroski [5] 32/12 68/14
74/6 75/11 85/19
Zindroski's [1] 85/21
Case 2:20-cr-00579-SVW Document 677 Filed 07/09/21 Page 133 of 133 Page ID
#:10862File and source
- File
- gov.uscourts.cacd.802533.677.0.pdf
- Size
- 465,272 bytes
- SHA-256
- 7a6519d0ab56cb04d4a69c53618478ce86e30a5931d7a1bf003a8e9412f5452c
- Original
- PACER (login required)