Court filing
TRANSCRIPT filed as to Defendant Richard Ayvazyan, Marietta Terabelian, Artur… — USA v. Ayvazyan et al (Dkt. 679)
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. 679 · 2021-07-09 · Docket on CourtListener
Summary
A reporter's transcript of Jury Trial - Day Nine, Volume 1, A.M./P.M. Session, in United States of America v. Richard Ayvazyan, et al., No. CR 20-579 SVW, before United States District Judge Stephen V. Wilson in the U.S. District Court for the Central District of California, Western Division, filed July 9, 2021 as Doc. 679. The cover page gives the date as Monday, June 28, 2021 and the proceedings page as Friday, June 25, 2021 at 9:32 a.m. in Los Angeles. Counsel are listed for the Government and for each of the four named defendants, and the index shows one witness examined and exhibits 401, 402 and 200-205 marked and received. The opening records the court turning to the forfeiture aspect of the case with the jury present. The transcript is 151 pages and closes with a word index.
Summary drafted by a model from the document's text below and checked by script against that text before publication. It is a navigation aid, not a reading of what the document proves. Where AI is used
Full text
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UNITED STATES DISTRICT COURT
CENTRAL DISTRICT OF CALIFORNIA - WESTERN DIVISION
HONORABLE STEPHEN V. WILSON
UNITED STATES DISTRICT JUDGE PRESIDING
- - -
United States of America,
)
PLAINTIFF, )
)
VS. ) NO. CR 20-579 SVW
)
Richard Ayvazyan, et al.,
)
DEFENDANT, )
___________________________________)
REPORTER'S TRANSCRIPT OF PROCEEDINGS
LOS ANGELES, CALIFORNIA
JURY TRIAL - DAY NINE
VOLUME 1 - A.M./P.M. SESSION
MONDAY, JUNE 28, 2021
_____________________________________
KATIE E. THIBODEAUX, CSR 9858
U.S. Official Court Reporter
Suite 4311
350 West 1st Street
Los Angeles, CA 90012
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Case 2:20-cr-00579-SVW Document 679 Filed 07/09/21 Page 1 of 151 Page ID
#:10899
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APPEARANCES OF COUNSEL:
ON BEHALF OF THE PLAINTIFF, UNITED STATES OF AMERICA:
U.S. DEPARTMENT OF JUSTICE
U.S. ATTORNEY'S OFFICE
BY: CATHERINE SUN AHN, AUSA
-and- SCOTT PAETTY, AUSA
312 North Spring Street
Twelfth Floor
Los Angeles, CA 90012
-and-
Christopher Fenton
US Department of Justice
1400 New York Avenue, NW
Washington, DC 20530
FOR DEFENDANT R. AYVAZYAN:
Ashwin J. Ram
Steptoe and Johnson LLP
633 West 5th Street
Suite 1900
Los Angeles, CA 90071
Meghan Newcomer
Steptoe and Johnson LLP
1114 Avenue of the Americas
New York, NY 10036
Michael A. Keough
Steptoe and Johnson LLP
1 Market Street
Spear Tower Suite 3900
San Francisco, CA 94105
Nicholas P. Silverman
Steptoe and Johnson LLP
1330 Connecticut Avenue NW
Washington, DC 20036
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#:10900
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APPEARANCES (Cont'd):
FOR DEFENDANT TERABELIAN:
John Lewis Littrell
Bienert Katzman Littrell Williams LLP
903 Calle Amanecer
Suite 350
San Clemente, CA 92673
Ryan Vaughan Fraser
Bienert Katzman Littrell Williams LLP
601 West 5th Street
Suite 720
Los Angeles, CA 90071
FOR DEFENDANT ARTUR AYVAZYAN:
Jennifer J. Wirsching
1935 Alpha Road
Suite 216
Glendale, CA 91208
Thomas A. Mesereau, Jr.
Mesereau Law Group
10100 Santa Monica Boulevard
Suite 300
Los Angeles, CA 90067
FOR DEFENDANT VAHE DADYAN:
Peter Johnson
Law Office of Peter Johnson
409 North Pacific Coast Highway
Suite 651
Redondo Beach, CA 90277
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Case 2:20-cr-00579-SVW Document 679 Filed 07/09/21 Page 3 of 151 Page ID
#:10901
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I N D E X
WITNESS NAME PAGE
MARYLEE ROBINSON
Direct Examination by Mr. Boyle 5
Cross-Examination by Mr. Silverman 23
EXHIBIT I.D. IN EVID.
401 11 11
402 21 21
70*, 200-205 22 22
*Exhibit No. 70 corrected to No. 77 at page 44.
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Case 2:20-cr-00579-SVW Document 679 Filed 07/09/21 Page 4 of 151 Page ID
#:10902
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LOS ANGELES, CALIFORNIA; FRIDAY, JUNE 25, 2021
9:32 A.M.
- - - - -
(The following proceedings were held in the
presence of the jury:)
THE COURT: Good morning. We are present with the
parties and counsel. The jury is present. Thank you all
again for your attention and promptness. We are going to
proceed to the forfeiture aspect of the case.
The government can present its evidence.
MR. BOYLE: The government recalls Marylee
Robinson, your Honor.
THE CLERK: The witness is reminded she is still
under oath.
MR. BOYLE: May I proceed, Mr. Cruz?
DIRECT EXAMINATION
BY MR. BOYLE:
Q
Good morning, Ms. Robinson.
A
Good morning.
Q
Did you testify previously during this trial?
A
Yes.
Q
And do you recall that testimony?
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A
I do.
Q
Now, have you reviewed a transcript of that prior
testimony?
A
I have not.
Q
So if I ask you questions today about that prior
testimony in that earlier phase of trial will you be
relying on your best recollection of that testimony?
A
Yes.
Q
I would like to show you a document previously
admitted as government Exhibit 115.
THE CLERK: Can you speak up, counsel.
MR. BOYLE: Government Exhibit 115, Mr. Cruz.
THE CLERK: Thank you.
Q BY MR. BOYLE: Ms. Robinson, do you recognize this
document?
A
I do.
Q
Do you recall testifying about this document in the
previous phase of trial?
A
Yes.
Q
Is this document a set of summary charts that you
prepared based on documents provided to you by the
government?
A
It is.
Q
Very briefly, I would like to return to some of
these summary charts that you testified about during the
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Case 2:20-cr-00579-SVW Document 679 Filed 07/09/21 Page 6 of 151 Page ID
#:10904
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previous phase of trial.
Now, do you recall your prior testimony
regarding a parcel of real estate referred to as the
Calle La Primavera property?
A
Yes.
Q
And without going into full detail, in your prior
testimony did you attempt to trace PPP or EIDL funds into
the purchase of the Primavera property?
A
Yes, I did.
Q
I would like to show you page 5 from government
Exhibit 115.
Based on the records you reviewed, were PPP
funds used for the purchase of the Primavera property?
A
Yes.
Q
And how much in PPP funds were used for the
purchase of the Primavera property?
A
$238,614.
Q
And can you briefly describe for the jury the
source of those PPP funds you just referred to?
A
The source of those funds were two PPP loans, one
funded to Voyage Limo and the other funded to Runyan Tax
Service.
Q
And did you review escrow documents from Beverly
Hills Escrow?
A
I did.
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Q
And based on the escrow documents you reviewed,
were the PPP funds you just referred to used to purchase
reel property?
A
Yes.
Q
And what real property was that?
A
The Calle La Primavera property.
Q
So moving on now, do you recall your previous
testimony regarding a parcel of real estate referred to
as the Anastasia Lane property?
A
Yes.
Q
And without going into full detail, in your prior
testimony did you attempt to trace PPP or EIDL funds into
the purchase of that property?
A
Yes.
Q
So I would like to show you page 6 of government
Exhibit 115. Based on the records you reviewed, were PPP
or EIDL funds used for the purchase of the Anastasia Lane
property?
A
Yes.
Q
And how much in PPP or EIDL funds were used for the
purchase of the Anastasia Lane property?
A
$110,300.
Q
And can you briefly describe for the jury the
source of those PPP and EIDL funds used for the Anastasia
Lane purchase?
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#:10906
9
A
There were three loans, two EIDL loans and one PPP
loan. The first is an EIDL loan funded through Redline
Auto Mechanics as well as a PPP loan to that same Bank of
America account, and, then, the third loan, EIDL loan,
was funded to Victoria Kauichko's Bank of America
account.
Q
And did you review escrow documents for Perfect
Escrow?
A
Yes, I did.
Q
And based on the escrow documents you reviewed,
were PPP and EIDL funds, the ones you just referred to,
used to purchase real property?
A
Yes.
Q
And what real property was that?
A
The Anastasia Lane property.
Q
I would like to move on to your testimony --
withdrawn.
Do you recall your previous testimony
regarding a parcel of real estate referred to as the
Topeka Drive property?
A
Yes.
Q
And in your prior testimony, did you attempt to
trace PPP or EIDL loan funds into the purchase of that
property?
A
Yes.
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Q
I would like to show you page 7 of government
Exhibit 115. So based on the records you reviewed, were
PPP or EIDL funds used for the purchase of the Topeka
Drive property?
A
Yes.
Q
And how much in PPP or EIDL funds were used for the
purchase of the Topeka Drive property?
A
$639,807.
Q
And can you briefly describe for the jury the
source of those PPP or EIDL funds that went to the
purchase of the Topeka Drive property?
A
This was a series of EIDL and PPP loans that were
funded through Timeline Transport, Allstate Towing, G&A
Diamonds, Redline Auto Collision and two Secureline
Realty accounts.
Q
And did you review escrow documents from Encore
Escrow?
A
Yes, I did.
Q
And based on those escrow documents you reviewed,
were the PPP and EIDL funds you just referred to used for
the purchase of real property?
A
Yes.
Q
And what real property was that?
A
The Topeka Drive property.
Q
I would like to move on now from this exhibit,
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since your prior testimony, have you prepared any
additional summary charts for the government?
A
Yes, I have.
MR. BOYLE: Your Honor and Mr. Cruz, I would like
to show just the witness what the government has marked
as government Exhibit 401.
Q
Ms. Robinson, do you recognize this document?
A
I do.
Q
And is this a document that you prepared?
A
Yes.
MR. BOYLE: Your Honor, the government moves to
admit government Exhibit 401 as a summary exhibit under
Rule of Evidence 1006.
THE COURT: Received.
MR. BOYLE: Permission to publish, your Honor?
THE COURT: Yes.
Q BY MR. BOYLE: So is government Exhibit 401, is that
a summary chart similar to those you testified about in
the previous phase of trial?
A
Yes.
Q
Now, during the course of your review of documents
provided to you, did you attempt to determine the balance
of PPP or EIDL funds in certain bank accounts that you
were provided?
A
Yes.
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Q
And was one of the entities for which you conducted
that analysis Runyan Tax Services?
A
Yes.
Q
So I am showing you page 1 of government Exhibit
401. Did you attempt to trace proceeds of any PPP or
EIDL loans into any bank accounts in the name of Runyan
Tax Service?
A
Yes.
Q
Did you identify any proceeds of PPP or EIDL funds
in the name of Runyan?
A
Yes, I did.
Q
Which account was that?
A
It is the Runyan Tax Service Bank of America
account ending in 9700.
Q
And can you briefly describe that tracing exercise
for the jury.
A
This involved a series of PPP -- three PPP loans
and one EIDL loan. The PPP loan -- there was a PPP loan
funded through Voyage Limo as well as a PPP loan that
funded directly into Runyan Tax Service, and, then,
finally, a PPP and an EIDL loan funded through Mod
Interiors and ultimately payments to Runyan Tax.
Q
And what was the last date for which you reviewed
bank records for the Runyan Tax Service Bank of America
9700 account?
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A
August 31, 2020.
Q
And what was the balance of PPP or EIDL funds in
the account as of that date?
A
$107,536.23.
Q
Taking one step back, are you familiar with the
term fungible property?
A
Yes.
Q
And can you briefly describe your understanding of
the concept of fungible property to the jury?
A
When property is interchangeable, so one dollar is
interchangeable for another dollar, it is considered
fungible.
Q
And are funds in a bank account fungible property?
A
Yes.
Q
So if you put a hundred dollars into a bank
account, am I correct you don't necessarily get the exact
same hundred dollars back out?
A
Correct.
Q
So I would like to show you page 2 of government
Exhibit 401. Now, did you attempt to trace proceeds of
any PPP or EIDL loans into any bank accounts in the name
of Allstate Towing and Transport LLC?
A
Yes.
Q
Did you identify proceeds of any PPP or EIDL funds,
loan funds, in any bank accounts in the name of Allstate?
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A
Yes.
Q
And which bank account was that?
A
The Allstate Towing and Transport LLC Bank of
America account 7695.
Q
And can you briefly describe that tracing exercise
for the jury?
A
This involved a PPP loan funded into the Allstate
Towing US Bank account on May 5th of 2020 and then a
subsequent payment to the Bank of America account ending
7695 as well as an additional EIDL or SBA loan that
funded directly into the 7695 account on July 13th.
Q
And what was the last date for which you reviewed
bank records for the Allstate Bank of America 7695
account?
A
September 28th of 2020.
Q
And what was the balance of PPP or EIDL funds in
that Allstate account as of that date?
A
$144,970.07.
Q
Is it correct that for the purposes of your prior
testimony you only traced 27 PPP or EIDL loans?
A
That's correct.
Q
Now, during the course of reviewing the bank
statements provided to you by the government, did you at
times encounter other transactions which appeared to be
PPP or EIDL loans which you haven't been tasked with
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tracing?
A
That's correct.
Q
And is one such apparent loan reflected on this
chart, page 2 of Exhibit 401?
A
It is.
Q
And how did you recognize this transaction as a
possible PPP or EIDL loan payment?
A
In my review of this, the Bank of America 7695
account, on the statement, the face of the statement,
there is a transaction on July 13th that is similar in
description to other SBA or EIDL loans, and it states on
the line that it is for the benefit of or payable to
Allstate Towing and T, Towing and Transport Company.
Q
Now, during your review of the documents provided
to you, did you attempt to calculate the rough amount of
cash withdrawn from the 24 bank accounts you traced for
your prior testimony?
A
Yes.
Q
I would like to show you page 3 of government
Exhibit 401. Can you briefly explain what this chart is
summarizing for the jury?
A
This is a summary of cashier's checks identified in
the 24 bank accounts that I reviewed. These are all
cashier's checks that were issued after the receipt of
any EIDL or PPP funds.
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Q
So, as an example, can you briefly explain for the
grand jury, sorry, for the jury the fourth transaction
down in this chart which says Iulia Zhadko?
A
Yes. That is a cashier's check from an account at
Wells Fargo, Iulia Zhadko, the account ending 8054. It
is in the amount of $159,733, and it is made payable
to -- the payee indicates who it is payable to. Payable
to Iulia Zhadko.
Q
So based on the records you reviewed, Iulia Zhadko
obtained a cashier's check for $159,733 payable to Iulia
Zhadko?
A
Correct.
Q
I would like to show you page 4 of government
Exhibit 401, and can you briefly explain to the jury what
this chart is summarizing?
A
This is a summary of the checks that I located that
were made payable to cash. So those would have been
written on the payee line, the word cash on them.
Q
So what amount did your review of these bank
records indicate was withdrawn from these accounts in
checks payable to cash?
A
$17,190.
Q
And now I would like to show you page 5 of
government Exhibit 401, and can you briefly explain what
this chart is summarizing for the jury?
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A
This is a summary of cash withdrawals between
April 22nd of 2020 and November 5th of 2020.
Q
So would it be correct to say that your review
identified at least $219,000 in funds withdrawn from bank
accounts you reviewed between April 22nd, 2020, and
November 5th, 2020?
A
Correct.
Q
And did you attempt to determine whether any of
these withdrawn funds were traceable to PPP or EIDL
loans?
A
Yes.
Q
And based on your review was there an amount that
was traceable to PPP or EIDL funds?
A
Yes. The red line or the red text indicates
$181,302 was traceable to EIDL and PPP funds.
Q
And just to clarify, how many bank accounts were
you reviewing for the purpose of this exercise?
A
24.
Q
I would like to show you page 6 of government
Exhibit 401 -- actually page 7, please. Now, if you look
down at the bottom of this page, can you briefly
summarize for the jury the transaction chain starting
with CRB PPP LN number 7303?
A
Yes. That is a PPP loan that was funded on May 1,
2020, in the amount of $113,750 to Sabala Construction,
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JP Morgan account ending 9906. A couple of days later on
May 4th, $250,000 is sent out of that account to Hart
Construction, JP Morgan account ending 9066. And, then,
between May 4th and May 14th, $105,000 is withdrawn, cash
withdrawals are made from that account.
Q
Thank you. Now, during the course of your review
of the documents provided to you, did you attempt to
trace any transfers of funds from PPP or EIDL loans to
any jewelers?
A
Yes.
Q
I would like to show you page 9 of government
Exhibit 401. So can you please explain to the jury what
this chart is summarizing?
A
This chart summarizes a series of EIDL and PPP
loans that were made to Timeline Transport which
ultimately are traced to Gentleman Timepieces, purchases
between July 3rd and July 17th of 2020 in the amount of
$82,000.
Q
So, based on your review, were PPP or EIDL loan
funds transferred to Picadilly Jewelers?
A
Yes. That is part of the bottom part of the chart,
and those are PPP and EIDL through Mod Interiors towards
purchases at Picadilly.
Q
In what amount?
A
$238,960.
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Q
So, now, I would like to move on to page 9 of
government Exhibit 401. And can you briefly describe for
the jury what this chart summarizes?
A
This is a summary of the Gentleman Timepieces
records of purchases made between April, 2020, and
August, 2020.
Q
And to prepare this summary, did you review
documents provided by Gentleman Timepieces?
A
I did.
Q
Did you review Excel spreadsheets?
A
Yes.
Q
And did you review text messages?
A
Yes.
Q
And did you review bank records?
A
I did.
Q
And did you review other documents provided by
Gentleman Timepieces?
A
Yes.
Q
And does this chart attempt to summarize all of
that data drawn from that number of sources?
A
Yes.
Q
Now, I would like to show you page 10 of government
Exhibit 401. And can you briefly describe this summary
for the jury?
A
This is a summary of payments received by Gentleman
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Timepieces. The top box which sums to $283,000
represents payments that were deposited to Gentleman
Timepiece's bank account at JP Morgan ending 3656. And
then the bottom box is a series of payments that were
also sent to Gentleman Timepieces and by really three
different sources, Wise Company, Cloud Currency and NECH.
Those total $147,620. So the sum of the two boxes in
total that was received by Gentleman Timepieces is
$430,620.
Q
And when you say $430,620 was received by Gentleman
Timepieces, am I correct that that is just summarizing
what Gentleman Timepieces produced to the government?
A
Correct.
Q
Now, I notice in this top box there is a number of
entries under account that is a UNK. Is that supposed to
mean unknown?
A
Yes.
Q
And is there a reason a number of them are marked
unknown?
A
In some instances, I was able to match a payment
that was in the Gentleman Timepieces records to a bank
record that I had, the 24 bank accounts that I have been
talking about. And, if so, I was able to indicate that
bank, but, in other cases, I didn't -- I wasn't able to
connect those two.
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Q
So is it correct to say when you created this chart
and summarized the Gentleman Timepieces records, you were
also considering the 24 bank accounts you reviewed?
A
Absolutely.
MR. BOYLE: Your Honor and Mr. Cruz, I would like
to show just the witness what has been marked as
government Exhibit 402.
Q
Ms. Robinson, do you recognize this document?
A
Yes.
Q
And is this a document you prepared?
A
Yes.
MR. BOYLE: Your Honor, move to admit government
Exhibit 402 as a summary exhibit under Rule of Evidence
1006.
THE COURT: Received.
MR. BOYLE: And permission to publish.
THE COURT: Yes.
Q BY MR. BOYLE: So since your prior testimony, did
the government ask you to attempt to trace any other PPP
or EIDL funds relating to any additional transactions?
A
Yes.
Q
So turning your attention to government Exhibit
402, is this a summary of one such tracing exercise?
A
Yes.
Q
And what documents does this exhibit summarize?
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A
It summarizes a bank account -- the Turing
Information Solutions JP Morgan bank account ending 2395
and the Iulia Zhadko Doing Business As Top Quality
Contracting Bank of America account 0762 as well as the
PPP loan associated with this $384,100 PPP loan that was
funded to Turing Info Solutions.
Q
So, based on your review of these documents, were
PPP and EIDL funds used in part to make a transfer to the
entity that is circled down here at the bottom of the
chart which I will try to pronounce Chiraag Limited Doing
Business As JAIS on or about October 19th, 2020?
A
Yes.
Q
And, based on your review of those records, did
these funds go to First Carribean International Bank?
A
Yes.
MR. BOYLE: No further questions for the witness,
your Honor.
MR. SILVERMAN: Your Honor, before beginning, we
would move to admit defense Exhibits 70, 200, 201, 202,
203, 204 and 205. We have provided copies of these to
the government.
THE COURT: Any objections?
MR. BOYLE: No objection, your Honor.
THE COURT: Received.
MR. SILVERMAN: Permission to publish as I go
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along, your Honor?
THE COURT: Yes.
CROSS-EXAMINATION
BY MR. SILVERMAN:
Q
Good morning, Ms. Robinson.
A
Good morning.
Q
I would like to ask you about GX401, slide 3.
MR. SILVERMAN: Could we pull that up, Ms. Romero.
Q
Now, I believe you testified that this was part of
your summary of cash withdrawn; is that right?
A
Yes.
Q
And this isn't actually cash withdrawals, though.
It is cashier's checks; right?
A
These are cashier's checks.
Q
And do you know if they were then cashed after
this?
A
I don't.
MR. SILVERMAN: Ms. Romero, I would like you to
zoom in on the top one here.
Q
Is the payee on this top cashier's check Anna
Manukyan?
A
Yes.
Q
And it is for $50,000 on May 4th; correct?
A
Correct.
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Q
If we could bring up defense Exhibit 200 and go to
page 42. Can you see who this is a bank account
statement to?
A
It is a Chase bank record.
Q
And is it in the name of Anna Manukyan?
A
It is, yes.
Q
And can we please go to page 43 and zoom in about
halfway down the page there is a number 50,000.
Now, does this show that on May 5th there was
an ATM check deposit of $50,000 into Anna Manukyan's bank
account?
A
It does.
Q
Fair to say that Anna Manukyan -- or that somebody
deposited the $50,000 cashier's check?
MR. BOYLE: Objection. Calls for speculation,
your Honor.
THE COURT: Overruled.
THE WITNESS: I would want to vary identify that
the bank provided a copy of the cashier's check or a
check deposited.
Q BY MR. SILVERMAN: Sure. That is reasonable. Can
we go to page 55, please, and could we unzoom so we can
see the entire cashier's check on the page.
Now, is this a copy of a cashier's check dated
May 4 from Arman Hayrapetyan to Anna Manukyan?
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A
Yes.
Q
So is it fair to say that the cashier's check was
deposited into Ms. Manukyan's account?
A
That appears to be the case.
Q
If we could go back to government Exhibit 401,
slide 3. And the second row is a $50,000 cashier's check
payable to Iulia Zhadko; correct?
A
Correct.
Q
And if we can pull up defense Exhibit 63 already in
evidence from trial, and go to page 26, please.
Now, is this a JP Morgan Chase account in the
name of Iulia Zhadko?
A
Yes.
Q
And if you look at May 14th, does it show an ATM
check deposit of $50,000?
A
Yes.
MR. SILVERMAN: And if we can proceed to the next
page and one more and one more. I apologize, Ms. Romero.
Page 30.
Q
And does this say posting date May 14th?
A
Yes.
Q
And it is an ATM deposit ticket?
A
Yes.
Q
And for $50,000?
A
Yes.
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Q
And if we can go to the next page, page 31. It is
a copy of the cashier's check from Arman Hayrapetyan to
Iulia Zhadko?
A
Yes.
Q
So fair to say that the cashier's check from Arman
Hayrapetyan to Iulia Zhadko was deposited into a JP
Morgan Chase account and not cash; correct?
A
Correct.
Q
If we can go back to GX401, slide 3, please. And
the third cashier's check on this slide is payable to
Fiber One Media for $50,000 on May 4th; correct?
A
Correct.
MR. SILVERMAN: And can we please pull up GX1.C
and go to page 18. 18, please Ms. Romero.
Q
Now, is this a copy of the $50,000 cashier's check
from Arman Harapetyan to Fiber One Media?
A
Yes.
Q
And in the bottom right-hand corner, can you see is
there an endorsement on the check?
A
Yes.
Q
And it says for mobile deposit at Novo; correct?
A
That looks to be the case.
Q
And do you know Novo to be an online bank?
A
I am not familiar with that bank.
Q
But fair to say that it was presented for mobile
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deposit; correct?
A
Yes.
Q
Now, if we can go back to GX401, slide 3. The
fourth check is for $159,733; correct?
A
Yes.
Q
And made payable to Iulia Zhadko?
A
Yes.
Q
Now, can we please pull up DX202 already in
evidence. Now, is this a deposit slip at Bank of America
for exactly $159,732.52?
A
Yes.
MR. SILVERMAN: And can we go to the next page,
Ms. Romero, and is there another page after that. Thank
you.
Q
And is this a copy of a cashier's check from your
chart GX401, slide 3?
A
Yes.
MR. SILVERMAN: And can we zoom in slightly,
Ms. Romero, and then we will go back. And then if we can
go back to GX401 slide 3.
Q
Now, the last cashier's check on this list is in
Secureline Realty, and it is made be payable to Tamara
Dadyan or ABC Realty Advisors; correct?
A
Yes.
Q
And you actually testified about this particular
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cashier's check in your trial testimony; right?
A
Yes.
Q
It was made payable to Tamara Dadyan or ABC Realty,
but it was then deposited into ABC Realty's account
wasn't it?
A
Yes.
Q
So not one of these five cashier's checks was
actually signed into cash; right?
A
It appears all five of them were deposited into
accounts.
Q
And if we can please go to slide 4. These are
checks actually made payable to cash; correct?
A
Correct.
Q
Did you trace these to PPP or EIDL loan funds?
A
I don't know the specific for each one.
Q
So is it possible that of the $17,190, zero dollars
is traceable to PPP or EIDL loan funds?
A
I can't say one way or the other.
Q
If we can go to slide 5, please.
Now, at the bottom right-hand corner, it is
$181,302 that are traceable to EIDL or PPP loan funds;
correct?
A
Correct.
Q
Now, fair to say that a substantial portion of this
comes from Arman Harapetyan?
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A
Yes.
Q
There is a 165,000 withdrawal; right?
A
Correct.
Q
Now, did you look at the rest of Mr. Hayrapetyan's
bank statements from -- strike that.
Did you look at the deposits made around the
time of withdrawal?
A
I have that information. I am sure I looked at it
in preparing the analysis, but I don't have specific
recollection.
Q
Well, fair to say that this chart does not include
a column that takes into account those deposits; right?
A
Correct.
Q
Let's look at one such deposit. If we can go to
government Exhibit 1.B as in boy and go to page 60,
please. So this is one of the withdrawals included in
the chart; correct?
A
Yes. I believe so.
Q
And can we go to the next page, please.
Fair to say that during the time period in
which you were examining withdrawals, there was also a
deposit of $80,000; correct?
A
That looks to be the case, yes.
Q
And do you know from this whether that deposit was
cash?
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A
It does not indicate on the slip.
Q
I apologize. I gave you the wrong page for that.
If we can go to the next page. It has the -- does this
say a deposit of 80,000 cash in ticket?
A
Yes, it does.
Q
So fair to say that $80,000 in cash was deposited
into Mr. Hayrapetyan's account?
A
Yes. On May 14th.
Q
So if we can go back to GX401, slide 5. So this
$165,000 in withdrawals minus 80,000 would be 85,000 in
net withdrawals; correct?
A
That is math, yes. Works.
Q
And are you familiar with Mr. Hayrapetyan?
A
From -- I mean, I know the name.
Q
And you know that he plead guilty in this case;
correct?
A
I don't --
MR. BOYLE: Objection. Scope, your Honor.
THE COURT: Overruled.
Q BY MR. SILVERMAN: Well, I would like to pull it up
DX77, please.
Q
And is this a transcript of proceedings in a change
of plea hearing?
MR. BOYLE: Objection. Foundation, your Honor.
MR. SILVERMAN: It is in evidence, your Honor.
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THE COURT: Well, you can proceed.
THE WITNESS: It says it is a transcript of
proceedings for a change of plea hearing on June 4th of
2021.
Q BY MR. SILVERMAN: And the defendant is Arman
Hayrapetyan; correct?
MR. BOYLE: Your Honor, it is unclear if this was
actually in evidence or simply marked as an exhibit.
THE COURT: Well, I mean is this an official
transcript?
MR. SILVERMAN: It is a transcript received from
the reporter directly, your Honor.
THE COURT: I see. All right.
MR. SILVERMAN: And it is in evidence with respect
to counsel's question.
THE COURT: Go ahead.
Q BY MR. SILVERMAN: So the defendant is Arman
Harapetyan; correct?
A
Yes.
Q
I will be brief with this document. If we can go
to page 4 and just look at lines 8 to 16. He is under
oath?
A
Yes. That is what the transcript says.
Q
And if we can go to page 28, and then we will leave
this document behind. And if we can blow up lines 3 to 9
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or even 3 to 12. Sorry.
Fair to say that Mr. Hayrapetyan testified
under oath that he does not know Richard Ayvazyan or
Marietta Terabelian?
MR. BOYLE: Objection. Hearsay, your Honor.
THE COURT: Wait for a ruling. You can proceed.
MR. SILVERMAN: Yes.
Q
Is it fair to say that Mr. Harapetyan testified
under oath that he does not know Mr. Ayvazian or
Ms. Terabelian or others?
THE COURT: How does this relate to her tracing?
MR. SILVERMAN: It relates to whether or not she
can trace the money from Arman Hayrapetyan to Richard
Ayvazyan.
THE COURT: But her task here is not to give her
evaluation of testimony. It is just to look at discrete
bank records and give her opinion about the tracing of
the monies.
MR. SILVERMAN: Correct, your Honor, and this goes
to that opinion about the tracing of the monies,
specifically the limitations on that opinion.
THE COURT: But you can bring that out generally
but not specifically. The jury knows what she was asked
to do. The objection is sustained.
MR. SILVERMAN: Okay.
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Q
If we could please return to GX401, slide 5. Now,
fair to say that you did not review any records of
Mr. Hayrapetyan delivering cash to Mr. Ayvazian or
Ms. Terabelian?
MR. BOYLE: Objection. Foundation, your Honor.
THE COURT: Any records. He said not any
evidence, any records. In other words, how would you
relate that to records? Could you answer that in terms
of records the way the question was asked? Did the
records provide some answer one way or the other with
regard to the question?
THE WITNESS: I am trying to think of a record
that would provide such information. I can't think of
one.
THE COURT: All right. That is the answer.
Q BY MR. SILVERMAN: Do you know what happened to this
cash after Mr. Hayrapetyan withdrew it?
MR. BOYLE: Objection. Foundation, scope, your
Honor.
THE COURT: Sustained. I mean does she know by
way of tracing the funds after Hayrapetyan withdrew it?
MR. SILVERMAN: Correct.
THE COURT: All right. Can you answer that, "yes"
or "no?"
THE WITNESS: I don't know what happened to the
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cash after it went out of the account.
Q BY MR. SILVERMAN: There is a casino gaming column
here. Can you explain what that is? Those are
transactions identified on the bank statements that
involve casinos or third-party administrators at casinos.
Q
And when you say transactions that involve casinos
are they also withdrawals or something else?
A
Typically, what I saw were transactions. An
example would be an entity called Everi, E-V-E-R-I, and
they secure transactions at casinos. And that is what I
was capturing here.
Q
And casinos sometimes produce records of winnings
by the players; correct?
MR. BOYLE: Objection. Foundation, your Honor.
THE COURT: Answer of your knowledge if you know
or not or if you know or don't know.
THE WITNESS: I believe a casino could produce
records of a player's activity at a casino.
Q BY MR. SILVERMAN: And you did not review any such
records in conjunction with preparing this chart, did
you?
A
I did not.
Q
So this does not represent winnings at a casino;
right?
A
It does not.
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Q
Now, if we can go to slide 10 of this presentation,
please.
Now, these are the payments sent to Gentleman
Timepieces that you reviewed; correct?
A
Yes.
Q
And you say that the payments total $430,000; is
that right?
A
Correct.
Q
And if we go back to slide 8, please, and can we
zoom in on the transfer from Timeline to Gentleman
Timepieces.
Is it fair to say that of that $430,000 you
have traced 82,000 to PPP or EIDL loan funds?
A
The 82,000 is one tracing exercise.
Q
Well, have you traced additional money from PPP or
EIDL loan funds through to Gentleman Timepieces that is
not present on this slide?
A
Yes. I believe that is true. I just wasn't asked
to present that information.
Q
And what quantity have you traced funds through
from PPP or EIDL loan funds to Gentleman Timepieces?
A
I don't know the total.
Q
Is it fair to say that it is not $430,000?
A
If you would like to go back to the 430, I can --
Q
Sure. If we could bring up slide 10.
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A
So I could only perform tracing through the 24 bank
accounts that we have been talking about so this 430 was
paid from other -- some other sources or other sources.
Q
And, specifically, 82,000 of it was paid through
the sources you have traced; correct?
A
I traced $82,000, but I am just saying that the
number could be higher. That was just one transaction
shown on a slide.
Q
Right. We don't know if the number is higher or
not; right?
A
Correct.
Q
And if we can please go to slide -- I'm sorry. If
we could go to GX402. And, in this instance, there is a
purchase from Chiraag Limited Doing Business As Jais in
the amount of $34,750?
A
Correct.
Q
And you trace 9,200 of those dollars to PPP funds
specifically; correct?
A
Yes.
Q
So that would leave approximately $25,550 that was
not traced to PPP funds?
A
That amount sounds about right.
Q
And one last sort of math-based question. We have
got 9,200 and 82,000. That is a total of $91,200 in
traceable funds; correct?
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A
Yes.
Q
If we could please pull up government Exhibit 115
and go to slide 7. Now, this says the purchase price was
$3.52 million; correct?
A
Yes.
Q
But I believe you testified during trial that the
down payment was more like 1.2 million?
A
Yes.
Q
So if $640,000 came from EIDL and PPP funds, that
would leave about 535,000 that came from untraced funds;
correct?
A
Came from funds that I didn't trace out of the 27
loans. Other sources.
Q
Came from funds that you did not trace back to EIDL
or PPP funds; correct?
A
To the 27 loan.
Q
And the 27 loans were the EIDL or PPP funds that
you traced; right?
MR. BOYLE: Objection. Foundation. Calls for --
not in evidence.
THE COURT: Overruled.
THE WITNESS: I was looking at 27 specific loans
and tracing them through. All I am trying to distinguish
here is, as we discussed earlier, there is other loans
out there. So there is other sources and I didn't see --
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I was just looking at the 27.
Q BY MR. SILVERMAN: And when you were tracing money,
you haven't looked at the mortgage payments; right?
A
No. I have not reviewed the mortgage payments.
Q
And this purchase was made in June of 2020. So
fair to say that the mortgage payments had been going on
for almost a year?
A
I have no knowledge one way or the other if those
payments have been made.
Q
And if we could just bring up defense Exhibit 205
which was one of the ones offered into evidence already.
Now, if we could read the statement date in
the top right-hand corner, Ms. Robinson, please?
A
June 14th, 2021.
Q
And does this appear to be a mortgage statement
addressed to Richard Ayvazyan and Marietta Terabelian at
4910 Topeka Drive?
A
Yes.
MR. SILVERMAN: And if you could, Ms. Romero, zoom
in on the explanation of payment due in the top
right-hand corner.
Q
Fair to say that the current payment is over
$15,000.
A
This states the current payment is $15,826.15.
Q
And this states that the amount of overdue payments
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is less than $5,000; right?
A
Yes.
MR. SILVERMAN: So I would like to take this down
now, please, Ms. Romero.
Q
Now, you testified about a number of cash
withdrawals. Fair to say that you didn't analyze all the
places where Richard Ayvazyan may have obtained cash?
MR. BOYLE: Objection. Foundation, your Honor.
THE COURT: She can answer "yes" or "no" or what
she did.
THE WITNESS: I reviewed the 24 bank accounts.
Q BY MR. SILVERMAN: And so it is possible that he has
other sources of income; correct?
MR. BOYLE: Calls for speculation, your Honor.
THE COURT: Sustained.
Q BY MR. SILVERMAN: I will bring up defense Exhibit
203 which was offered into evidence at the outset of this
examination.
If we can zoom in on the first paragraph, is
this a tax information statement from MGM Resorts?
MR. BOYLE: Objection. Foundation, scope,
hearsay, your Honor.
MR. SILVERMAN: It is in evidence, your Honor.
THE COURT: Don't respond to each other. I
thought it was offered and you had no objection to it
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being in evidence.
MR. BOYLE: No objection to it being in evidence,
your Honor, but the witness is being asked about
documents far outside the scope of her testimony.
THE COURT: But you agreed to it being in
evidence. It is in evidence so the examiner can ask
questions about it. Go ahead.
THE WITNESS: Can you repeat the question?
Q BY MR. SILVERMAN: Does this second line say MGM
Resorts International Consolidated M Life Rewards Tax
Statement?
A
Yes.
MR. SILVERMAN: And, Ms. Romero, if we can reduce
that.
Q
If you look at total estimated win/loss in the very
bottom righthand corner, what is that amount?
A
$211,695.
Q
And what year is this statement for according to
the statement itself?
A
It says it is for 2019.
Q
And if we can bring up defense Exhibit 204 and go
to page 18. And is this a statement from back in 2009?
A
This statement references 2009.
Q
And the total win/loss for the year of 2009 is
$148,450; correct?
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A
That is what it says. Yes.
MR. SILVERMAN: No further questions, your Honor.
MR. BOYLE: Nothing from the government, your
Honor.
THE COURT: Thank you, Ms. Robinson.
MR. BOYLE: Your Honor, the government has no
further witnesses, but there is one stipulation the
parties have all agreed to to be read into the record.
THE COURT: Go ahead.
MR. BOYLE: The government has submitted an ex
parte application for a trial bill of particulars
identifying certain specific property allegedly subject
to forfeiture.
The bill of particulars. The parties agree
that the property identified in the bill of particulars
was, in fact, seized as described in the bill of
particulars. This stipulation is being entered into
freely and voluntarily by all parties. The stipulation
does not constitute an admission by any defendant that
any property identified in the bill of particulars is
actually subject to forfeiture, and the parties agree and
stipulate that this stipulation be entered into evidence
at trial. This stipulation constitutes conclusive proof
of the above matters for all purposes.
And I will read the relevant portion of the
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bill of particulars.
Notice is hereby given that the government
pursuant to the forfeiture allegations set out in the
first superseding indictment intends to seek criminal
forfeiture of the following specific property:
$74,557.79 in bank funds seized pursuant to a
federal seizure warrant executed on November 20, 2020
from Bank of America account number ending 7695 held in
the name of Allstate Towing and Transport, LLC;
$65,990.42 in bank funds seized pursuant to a federal
seizure warrant executed on or about December 2nd, 2020,
from Bank of America account ending in 9700 in the name
of Runyan Tax Service Incorporated; $3422.00 in United
States currency seized on October 20, 2020, from Richard
Ayvazyan and Marietta Terabelian at the Miami
International Airport; $451,185 in US currency seized on
November 5th, 2020 during the execution of a federal
seizure warrant in various areas in the backyard of a
Tarzana, California residence;
Miscellaneous jewelry and precious items
seized on November 5th, 2020, during the execution of a
federal seizure warrant at a Tarzana, California
residence consisting of, one, Audemars Piquet Royal Oak
18 karat rose gold wristwatch, model 26331 serial number
J52335; one Rolex date adjust stainless steel wristwatch,
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model 126334, serial number 4U95Z313; one Audemars Piquet
Royal Oak Offshore Black Ceramic wristwatch, serial
number K23313, one Audemars Piquet Royal Oak Offshore
Black Ceramic wristwatch, serial number LU44845K, one
Audemars Piquet Royal Oaks stainless steel wristwatch,
serial number LW3397N;
One 1979 gold bullion coin, two 1980 gold
bullion coins, 10 1982 gold bullion coins, 17 1983 gold
bullion coins, 5 1984 gold bullion coins; 5 1985 gold
bullion coins, 10 1986 gold bullion coins and 10 1987
gold bullion coins;
Miscellaneous jewelry and precious items
seized on October 20, 2020, from Richard Ayvazyan and
Marietta Terabelian at Miami International Airport
consisting of one Rolex day date watch serial number
W44P7238, one 14 karat yellow gold 24-inch neck chain and
one pair of 14 carat white gold earrings with diamond
studs.
That concludes the stipulation, your Honor.
THE COURT: Okay. Anything further from either
side?
MR. BOYLE: Nothing further from the government,
your Honor.
MR. SILVERMAN: Nothing further from the defense,
your Honor.
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THE COURT: All right. The evidence regarding
this phase of the case is now complete. I may need a
little time to consult with the parties about some
additional jury instructions so I will ask you to take
about 20 minutes or so, and then I will give you the
remaining jury instructions. And then you can decide
this phase of the case. Thank you.
(The following proceedings were held at sidebar
outside the presence of the jury and the Court:)
THE CLERK: We are here on the record with AUSA
Dan Boyle and defense counsel, Nicholas Silverman, to
clarify the record of an admitted exhibit.
MR. SILVERMAN: When I was speaking, I
accidentally said defense Exhibit 70. The correct number
is defense Exhibit 77.
MR. BOYLE: Agreed.
THE CLERK: All right. We are good.
(Recess from 10:39 to 10:46 a.m.)
(The following proceedings were held outside the
presence of the jury:)
THE COURT: Everybody here?
MR. RAM: I think we are missing a couple, a
defendant and then an attorney.
MR. JOHNSON: We are missing the interpreter as
well.
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THE COURT: I meant 20 minutes for the jury. I
didn't make myself clear. I intended to discuss the jury
instructions briefly with the parties. I have examined
the government's proposed instructions and the
government's objection to the defendant's instructions.
The -- one of the principle arguments concerns
the applicability of the Honeycut case. My view is that
the Honeycut case does not apply here, and there was some
discussion about the model Seventh Circuit jury
instruction, and I agree with the government's position
in that regard. If there is some further argument that
defendants want to make, I will consider it.
MR. FRASER: Just, your Honor, on behalf of
Ms. Terabelian, she joins Richard Ayvazyan's request as
to the jury instruction and verdict form.
THE COURT: All right.
MR. SILVERMAN: And, your Honor, there is one
specific government proposed instruction that we would
request be omitted, specifically, the forfeiture of
fungible property, instruction No. 12 which, first of
all, it applies to in rem proceedings as opposed to in
personum and also would cause juror confusion in this
case which deals not with any allegations that cash or
currency was replaced with identical cash or currency but
rather that it never was transferred to begin with.
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THE COURT: Let me read that again. Just one
moment.
MR. SILVERMAN: Yes, your Honor.
THE COURT: What is the government's response on
that?
MR. BOYLE: Your Honor, this case involves a
number of fungible properties including two bank
accounts, cash and precious metals. This is exactly the
kind of case where a fungible property forfeiture
instruction would apply, and the fungible property
statute which is 18, U.S.C., 984, it does apply through
28 USC -- the citation is on my jury instructions, your
Honor, but the section which states that 2461(c) which
states that simple forfeiture is applicable in criminal
proceedings where alleged properly, your Honor.
THE COURT: What did you say? The last part.
MR. BOYLE: 2461(c) states that the rules and the
statutes for civil forfeiture apply in criminal
forfeiture where properly alleged which the government
has done here, your Honor.
THE COURT: All right. I will take a look at
that, and then we will get back. Have the jury come
back. Just wait a few minutes.
(Recess from 10:50 to 11:12 a.m.)
(The following proceedings were held in the
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presence of the jury:)
THE COURT: Okay. Members of the jury, I will now
give you the instructions which apply to this phase of
the case.
While deliberating concerning the issue of
forfeiture, you must not re-examine your previous
determination regarding the defendant's guilt. However,
all the instructions previously given to you concerning
duties of the jury, your consideration of the evidence,
what is and is not evidence, the credibility of
witnesses, expert testimony, your duty to deliberate
together, your duty to base your verdict solely on the
evidence without prejudice, bias or sympathy, and the
necessity of a unanimous verdict will continue to apply
during these supplemental instructions.
Your duty at this phase of the proceeding is
solely to determine whether the government has proven the
required connection between the property sought for
forfeiture and the offenses for which you have found the
defendants guilty.
You should not consider what might happen to
the property in determining whether the property is
subject to forfeiture. The disposition of any property
that is declared forfeited is exclusively a matter for
the court to decide. Similarly, if any property has been
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transferred to a third party, the court will later
determine the rights of that third party to the property.
Some of the property which the government
claims is subject to forfeiture may be in the name of one
or more defendants and persons or business entities other
than the defendants. However, any interest that a person
other than a defendant may claim to such property will be
taken into account by this Court in a separate
proceeding. Interests of persons or entities other than
any of the defendants are not for your consideration.
Your sole task is to determine whether the
defendants' interest in the property, whatever that
interest may be, is subject to forfeiture under the
applicable law.
With two important exceptions, all previous
instructions will continue to apply to your
deliberations.
The first exception is that, during this
phase, the government's burden is no longer proof beyond
a reasonable doubt but instead it is proof by a
preponderance of the evidence which I will define for
you.
The second exception is that, during this
phase, you will consider a component of a potential
punishment to be imposed on the defendants, but your sole
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task is to determine whether the government has
established by a preponderance of the evidence the
required connection between the crimes of which
defendants have been found guilty and the property sought
for forfeiture.
When a party has the burden of proof on any
claim by a preponderance of the evidence, it means you
must be persuaded by the evidence that the claim is more
probably true than not true. You should base your
decision on all the evidence regardless of which party
presented it.
In making the forfeiture determination, you
should consider all of the evidence presented during the
trial as well as the evidence presented during these post
verdict forfeiture proceedings regardless of who offered
it. You should evaluate the evidence and its credibility
according to the instructions given to you earlier.
The forfeiture allegations are set forth in
the first superseding indictment, are not evidence and do
not create any inference that the property is subject to
forfeiture. The defendants have denied the property is
subject to forfeiture.
I will soon describe the specific property the
government seeks to forfeit and what the government must
prove to forfeit such property. You will be asked to
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consider whether such property is subject to forfeiture
including on multiple grounds. You need not be concerned
with the double counting of monetary amounts or
overlapping of properties. Even if you find that a
particular property is subject to forfeiture for more
than one reason, that does not mean the government will
receive the property twice.
However, it is important that you indicate on
the special verdict form all bases on which you find any
property is subject to forfeiture. Any issues of double
counting or overlapping will be considered by the court
when imposing sentence.
Under federal law, any defendant convicted of
one more or more violations of Title 18, United States
Code, Section 1343 shall forfeit to the government all
defendant's right, title and interest in any and all
property, real or personal constituting or derived from
any proceeds obtained directly or indirectly as a result
of the offense.
Under federal law, any defendant convicted of
one or more violations of Title 18, United States Code,
Section 1344 shall forfeit to the government all of
defendant's right, title and interest in any and all
property, real or personal, constituting or derived from
any proceeds obtained directly or indirectly as a result
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of the offense.
Under federal law, any defendant convicted of
one or more violations of Title 18, United States Code,
Section 1028(a) concerning a violation of Title 18,
United States Code, Sections 1343 or 1344 shall forfeit
to the government all of defendant's right, title and
interest in any and all property, real or personal,
constituting or derived from any proceeds obtained
directly or indirectly as a result of the offense.
Property subject to forfeiture as proceeds of
a scheme to defraud includes any money obtained as a
result of the scheme and any property obtained with that
money. Proceeds remain proceeds regardless of how many
times the property may change form.
For example, the proceeds of a crime may start
out as money in one bank account, be moved to a second
bank account, be converted to a check and then used to
buy a car. In that case, each of the items would be
considered the proceeds of the offense or property
derived from such proceeds.
In a case like this one involving a scheme to
defraud, property is subject to forfeiture if it is
derived from or traceable to the scheme as a whole. It
is not necessary for the government to trace the property
to a particular execution of the scheme such as a
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particular wire transfer.
The government is not required to identify
specific cash, precious metals or bank funds involved in
an offense that is the basis for the forfeiture because
it is not a defense that the cash, precious metals or
bank funds involved in such an offense were removed and
replaced by identical property. Any identical cash,
precious metals or bank funds found in the same place or
account as the property involved in the offense that is
the basis for the forfeiture shall be subject to
forfeiture.
The government seeks to forfeit the following
property pursuant to the findings of guilt on each of
Counts 1 through 22 and 24:
One, all of the convicted defendants' right,
title and interest in certain real property located in
Tarzana, California, identified by assessor's parcel
No. 2176-029-031;
Two, all of the convicted defendants' right,
title and interest in certain property located in
Glendale, California, identified by assessor's parcel
No. 5663-036-033;
Three, all of the defendants' right, title and
interest in certain real property located in Palm
Springs -- strike that -- Palm Desert, California,
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identified by assessor's parcel number 694-331-008;
$74,557.79 in bank funds seized from Bank of
America account number ending in 7695 held in the name of
Allstate Towing and Transport LLC;
Five, $65,990.43 in bank funds seized from
Bank of America account ending in the 9700 in the name of
Runyan Tax Service, Inc.;
Six, $451,185 in US currency seized on
November 8th, 2020, in various areas and backyard of a
Tarzana, California, residence;
Seven, $3,422 in US currency seized on
November 20, 2020, from Richard Ayvazyan and Marietta
Terabelian at the Miami International Airport;
Eight, one Audemars Piquet -- is that how you
say it -- Piquet Royal Oak 18 karat rose gold wristwatch,
model 26331, serial number J52335;
Nine, one Rolex date adjust stainless steel
wristwatch, model 126334, serial number 4U95Z313;
Ten, one Audemars Piquet Royal Oak Offshore
Black Ceramic wristwatch, serial number K23313;
Eleven, one Audemars Piquet Royal Oak Offshore
Black Ceramic wristwatch, serial number LU44845K;
Twelve, Audemars Piquet Royal Oak Stainless
Steel wristwatch, serial number LW3397N;
Thirteen one Rolex Day Date watch, serial
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number W44P7238;
Fourteen, 16 gold bullion coins;
Fifteen, one 14 karat yellow gold 24-inch neck
chain;
And, sixteen, one pair of 14 karat white gold
earrings with diamond studs.
The government contends that the property
described above constitutes or is derived from the
proceeds obtained directly or indirectly as a result of
the violations at which one or more defendants was found
guilty and is therefore subject to forfeiture to the
United States pursuant to Title 18, United States Code,
Section 981(a)(1)(C).
If you conclude that the government has proved
by a preponderance of the evidence that the property
listed above constitutes or is derived from proceeds of
one or more of the defendants obtained directly or
indirectly as a result of the violations of which one or
more defendants has been found guilty, you must find that
such property is forfeitable to the United States.
Under federal law, any defendant convicted of
one or more violations of Title 18, United States Code,
Section 1956 or a conspiracy to commit the same shall
forfeit to the government all of defendants' right, title
and interest in any and all property, real or personal
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involved in such offense or any property traceable to
such property.
Property subject to forfeiture as property
involved in a violation of Section 1956 of Title 18 of
the United States Code, Count 26, includes, one, money or
other property that was the subject of the financial
transactions that constituted the money laundering
violation, two, any property used to facilitate such a
money laundering violation, and, three, any fees or
commissions paid to the money launderer.
Property may be the subject of the financial
transaction in a number of ways. For example, the
property may be the proceeds of the underlying specified
unlawful activity which were used to conduct the
transaction. It may be property that was committed with
those proceeds at the time the financial transaction took
place or it may be property that was obtained as part of
an exchange or purchase that constituted the violation
for which a defendant has been found guilty.
Property that was used to facilitate the money
laundering transaction may include property that was not
part of the transaction itself but was used to make the
money laundering offense easier to commit or harder to
detect.
Property that is traceable to the property
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described in 1 through 3 above in this instruction is
also subject to forfeiture. The property -- any property
traceable to such property includes any property which
was exchanged for, derived from or obtained with any of
the property involved in the underlying money laundering
crime.
For example, property involved in a money
laundering violation may be used to acquire, improve or
maintain real or personal property in a transaction that
is not a money laundering violation but that real or
personal property is for -- but that real or personal
property is forfeitable because it can be traced to
property that was involved in the money laundering
violation.
Property is forfeitable as traceable to
property that was involved in a money laundering -- in a
money laundering if -- let me start that again. Property
is forfeitable as traceable to property that was involved
in money laundering even if some untainted funds were
also used to purchase, improve or maintain the property.
And the government seeks to forfeit the
following property pursuant to the findings of guilt on
Count 26 -- it appears to me that the property described
in that instruction is the same property that I
previously described; is that correct?
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MR. BOYLE: That is correct with one exception,
your Honor. There is one asset omitted, and that is the
$74,557.79 cents. That is the only distinction between
those two.
THE COURT: I see. All right.
The government contends that the property
described above -- I am not reading it to you because it
is the same with that exception as I previously read to
you, and you will have a copy of these instructions.
The government contends that the property
described above was involved in or traceable to the money
laundering violations for which one or more defendants
were found guilty and is therefore subject to forfeiture
to the United States pursuant to Title 18, United States
Code, Section 982(a)(1).
If you conclude that the government has proved
by a preponderance of the evidence that the property
listed above was involved in such offense or traceable to
the violations of which one or more defendant has been
found guilty, you must find that such property is
forfeitable to the United States.
A special verdict form has been prepared for
your use with respect to the property listed or
described. You are asked to decide whether it is subject
to forfeiture to the government based on the reasons I
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have explained to you. Your decision must be unanimous.
Indicate on the verdict form whether you find that the
property listed is subject to forfeiture and, then, the
foreperson should sign and date the form.
And, then, there will be a special verdict
form presented to you that you should complete if you can
reach a unanimous verdict.
Is the bailiff here?
THE CLERK: Yes, your Honor.
THE COURT: The bailiff is still sworn; correct?
THE CLERK: Yes, your Honor.
THE COURT: So will the bailiff usher the jury to
the jury room so they can deliberate.
MR. SILVERMAN: And, your Honor, before they
deliberate, we would ask first that our objections be
deemed renewed and for argument, your Honor.
THE COURT: Okay.
(The following proceedings were held outside the
presence of the jury:)
THE COURT: While the jury is deliberating, there
was a new matter raised by the government concerning the
issue of waiver, and can the government describe that
issue with some more detail?
MR. FENTON: Yes, your Honor.
THE COURT: Oh. Wait a minute. Wait a second.
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Get the jury back here. I'm sorry. Get them back right
away, Paul.
Did I do something that I shouldn't have by --
the government or the defense want to make arguments?
MR. RAM: Yes, your Honor.
THE COURT: I am getting the jury back
immediately. They have not even got to the jury room. I
apologize for that oversight.
MR. BOYLE: Your Honor, to the extent the court
permits argument, the government would move to strike the
defense Exhibit 77. The government recognizes that the
rules of evidence do not apply at the forfeiture phase.
However, the defendant showed two pages of a multiple,
almost 50-page transcript and now intends to send that
entire transcript back to the jury, and that risks
serious jury confusion including --
THE COURT: How does that -- why is that part of
the transcript so relevant?
MR. BOYLE: We don't believe any part of it is
relevant, your Honor.
THE COURT: What is the relevance of that part of
the transcript?
MR. SILVERMAN: Your Honor, the government's
argument with respect to cash is that Arman Hayrapetyan
withdrew cash and that at some point it was transferred
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to Mr. Ayvazyan.
THE COURT: I am not going to allow the transcript
but you can make the argument.
MR. SILVERMAN: Your Honor, if I may be heard just
briefly. Hearsay testimony is permitted under Ninth
Circuit law at forfeiture proceedings.
THE COURT: I am not allowing the transcript. You
can make the argument.
MR. SILVERMAN: Yes, your Honor.
MR. BOYLE: We understand that Exhibit 77 is
stricken, then, your Honor?
THE COURT: Yes.
MR. BOYLE: And would your Honor permit the
parties a brief recess to prepare for closing arguments.
I believe we have slides and things like that. Would the
court permit a brief recess?
THE COURT: Can't we go forward now?
MR. BOYLE: I believe I need to set up some
slides.
THE COURT: Set them up. Let's go.
MR. RAM: We are ready, your Honor.
THE COURT: I told the jury to come back. If you
have to go to the restroom, I can't say no, but you heard
me tell the bailiff to bring the jury back.
MR. RAM: Yes, sir.
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MR. BOYLE: My apologies, your Honor. I do need
to retrieve something from the second floor.
THE COURT: Well, then. We will take 5 or 10
minutes.
MR. BOYLE: Thank you, your Honor.
(Recess from 11:38 to 11:41 a.m.)
(The following proceedings were held in the
presence of the jury:)
THE COURT: Members of the jury, through my
oversight, and I apologize, I sent you out a few minutes
ago to deliberate, but I didn't give the lawyers a chance
to give their arguments which, of course, are very
important for your consideration.
So I just called you back very briefly to tell
you -- I don't think you had a chance to start your
deliberations because it was just a few minutes, but, if
you did, you should begin your deliberations anew without
any thought as to what you may have said in the last few
minutes, only after you have heard the final arguments
from the lawyers.
Do I understand -- the foreperson, did you
begin any deliberations?
THE JUROR: No, your Honor.
THE COURT: Okay. Thank you. Are we ready to go
now, or do you need more time to set up your slides?
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MR. PAETTY: Your Honor, we are still waiting on
Mr. Boyle who has gone downstairs to retrieve some
materials but should be back very soon.
THE COURT: Okay. Members of the jury, sorry to
back and forth, but give us a few minutes to get the
slide presentation ready and we will go.
(Recess from 11:42 to 12:02 p.m.)
(The following proceedings were held outside the
presence of the jury:)
THE COURT: First, we will hear from the
government.
MR. BOYLE: Good afternoon, ladies and gentlemen.
As you heard from the judge and from us
earlier, you have been asked to continue your jury
service just a little bit longer. Specifically, you are
now asked to help determine if the defendants should
forfeit their interest in certain specific property as
part of the penalty for the crimes for which you found
them guilty beyond a reasonable doubt.
Now, this last remaining task is actually a
bit narrower than it sounds because, as the court
instructed you, your sole duty now is to determine
whether the government has proven the required connection
between the property sought for forfeiture and the
offenses for which you found the defendants guilty. And
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it is that required connection that is all that is left
for you to deliberate on today. And when you consider
the evidence that you heard in the prior phase of trial
as well as the evidence you heard today, that connection
will be clear.
Now, first, I would ask you to keep in mind
the court's jury instructions from the prior phase of
trial as well as the court's jury instructions you heard
today. Now, because you have recently been given new
jury instructions for the second phase of trial, I am
going to refer to this as the forfeiture phase. And I
will refer to those as the forfeiture jury instructions,
and I will do my best to avoid any confusion when I am
referring to them.
Now, you heard the court mention that there
were two big differences between the court's instructions
in the prior guilt phase and this phase of trial
concerning forfeiture, and I want to address one of those
differences right away. Now, you heard the words "beyond
a reasonable doubt" many times in the prior phase of
trial both from the prosecutors and from the defendant's
lawyers.
Well, now that you have convicted the
defendants of certain offenses beyond a reasonable doubt,
that standard is gone. The standard now is a
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preponderance of the evidence.
As the court instructed you, the government's
burden is no longer proof beyond a reasonable doubt but
instead, simply, proof by a preponderance of the
evidence. And what is a preponderance of the evidence?
Well, it is more likely than not.
As the court instructed you, a preponderance
means you must be persuaded by the evidence that a claim
is more probably true than not. So, now, what is this
connection that you are being asked to consider in your
deliberations today? Well, for most of the charges upon
which you convicted the defendants including wire fraud,
bank fraud and aggravated identity theft based on wire
and bank fraud as well as the conspiracy charged in Count
1 relating to those offenses -- and I am going to refer
to all of those as the fraud convictions by the way --
that required connection is the same for all of them.
And it has been defined for you by the court
in the forfeiture jury instructions. Proceeds obtained
directly or indirectly as a result of the offense. And
keep in mind all of the parts of the court's forfeiture
jury instructions on this required connection for these
fraud convictions. Remember that you have been
instructed that proceeds can be direct or indirect.
Remember that proceeds stay proceeds.
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Proceeds remain proceeds regardless of how many times a
property may change form. So how are you going to know
what those proceeds are? Well, because they have already
been identified for you. You have seen a lot of summary
charts both today and in the prior phase of trial, most
of them through the testimony of Ms. Robinson, the
government's summary witness.
And, on many of them, you saw black numbers
and red numbers, and, as you heard Ms. Robinson testify,
the black numbers are the total amounts transferred, and
the red numbers represented traceable PPP and EIDL loan
funds. Well, now that you have convicted defendants on
the fraud charges and on a conspiracy to fraudulently
obtain those PPP and EIDL loan funds, you are entitled to
follow those red numbers wherever they may lead because,
remember, proceeds remain proceeds.
Now, that proceeds definition I just gave you
and I just spoke about, it applies to the fraud
convictions, but, as the court instructed you, the money
laundering conviction in Count 26 is a bit different.
For money laundering convictions, the court has defined
that required connection for you as property, real or
personal involved in such an offense.
And this matters, ladies and gentlemen,
because, as the court instructed you, property involved
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in a money laundering crime is actually more than just
the proceeds of the crime. It is both the property that
was the subject of the money laundering offense as well
as property used to facilitate that money laundering
offense. And that means property used to make the money
laundering offense easier to commit or harder to detect.
So mixing up clean and dirty money doesn't necessarily
excuse anything.
So now that we discussed how the court has
defined this required connection for you and we discussed
the court's new forfeiture jury instructions what is the
government actually seeking to forfeit here today based
on the fraud convictions and the money laundering
conviction.
Well, as you were instructed, you will be
asked to consider today whether the government has proven
by a preponderance of the evidence this required
connection between the counts for which you convicted the
defendants and four groups of property. And that is
funds seized from two bank accounts, three real
properties, personal property in the form of gold coins,
watches and jewelry as well as seized cash. And let's go
into each of those groups now.
The first assets I am going to talk to you
about are the funds seized from two bank accounts in the
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name of Runyan Tax Services and Allstate Trucking and
Towing, and both those names are probably familiar to you
from the previous phase of trial.
First, the government is seeking to forfeit
just over $65,000 seized from a Bank of America account
ending in 9700 held in the name of Runyan on
December 2nd, 2020. And that is as both fraud proceeds
and as property involved in a money laundering
conviction. Now, you found the defendants guilty beyond
a reasonable doubt of conspiracy and schemes to
fraudulently obtain PPP and EIDL loan proceeds, and, as
you heard and can see now, funds from four EIDL and PPP
loans were transferred into Runyan's 9700 account both
directly and indirectly.
And you also heard that as of August 31, 2020,
there was at least a $107,536.23 in red numbers, proceeds
in that Runyan account. And that is more than the
roughly $65,000 the government seized and is seeking to
forfeit, and the evidence shows those funds seized from
the Runyan account are connected to counts of conviction
because you herd Ms. Robinson summarize the bank chart
including the one you see right here. You saw the moving
the money from EIDL and PPP loans transferred into the
Runyan account, and you convicted the defendants for some
of that very same conduct in Count 1 which is the
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conspiracy count as well as in counts 7, 11 and 18. The
evidence before you shows that the funds seized from the
Runyan account are proceeds of the fraud convictions.
The government is also seeking to forfeit
$74,557.79 seized from a Bank of America account ending
in 7695 in the name of Allstate on November 20 both as
proceeds of fraud convictions and property involved in
the money laundering convictions. As you heard from the
government's summary witness, Ms. Robinson, and you can
see here, the Allstate account received $124,000 PPP loan
through a US Bank account in the same name, $80,000 of
which ended up in the Allstate Bank of America 7695
account.
And you will see that loan came from Cross
River Bank, and that Cross River Bank loan was charged in
the Count 1 conspiracy and counts 3 and 15 all of which
you found the defendants guilty on. In addition, you
heard Ms. Robinson note that there was another $149,900
transaction which appeared to be from another PPP or EIDL
loan.
Now, you convicted the defendants on a
conspiracy, ladies and gentlemen, and you are entitled to
determine whether this money was more probably than not
part of that conspiracy as well. And when you look at
the evidence you are presented with and the charges you
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convicted on, there will be no question that these bank
funds were proceeds of the counts of conviction.
So the next group of assets I will address are
three real properties the government is seeking to
forfeit. Now, these three properties are certainly
familiar to you now from the guilt phase of trial. First
is the Calle La Primavera property. The evidence shows
the Primavera property was purchased with proceeds of the
fraud conviction offenses and that this property was
involved in the money laundering conduct.
First, you heard Ms. Robinson, again, $238,614
in PPP loans transferred directly or indirectly to
Beverly Hills Escrow where they were used as a down
payment on the Calle La Primavera property.
And these same loans were charged in the
conspiracy count in Count 1 and executions of the schemes
alleged in Count 7, 18 and 20 all of which you convicted
the defendants on. The Primavera property was also
involved in the Count 26 money laundering conspiracy. As
you can see, this property is directly traceable to a
transfer of approximately $230,000. That transfer is
specifically identified in the overt acts alleged in
Count 26 for which you found the defendants guilty.
Next, is the Anastasia Lane property. Again,
the evidence also shows that this property was purchased
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with PPP and EIDL loan proceeds transferred directly or
indirectly to Perfect Escrow where they were used as a
down payment on the Anastasia property. The same loans
were identified in the overt acts in the conspiracy count
for which you convicted the defendants and its executions
of the scheme for which you convicted the defendants for
Count 19. Again, the evidence shows this property was
involved in the conduct underlying the money laundering
conviction in Count 26. These transfers were identified
among the overt acts.
Finally, the Topeka Drive property. You heard
from Ms. Robinson, $639,807 in PPP and EIDL loan proceeds
were transferred directly or indirectly to Encore Escrow
where they were used as a down payment on the Topeka
property. These same loans were identified in Count 1 as
executions of that conspiracy and in Counts 3, 5, 6, 10,
15, 16 and 17, and you convicted defendants beyond a
reasonable doubt on every one of those charges.
And, again, the evidence shows that the Topeka
Drive property was involved in the conduct underlying the
Count 26 money laundering convictions because these
transfers were, again, identified in the overt acts for
the money laundering conspiracy.
Now, as you probably noticed, unlike some of
the accounts we just looked at, the Topeka Drive property
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in particular was purchased with some funds traceable to
EIDL and PPP loans but also with funds that were not
traceable to PPP and EIDL loans here.
Don't forget the Court's jury instructions.
Property is forfeitable as traceable -- as involved in a
money laundering offense even if some untainted funds
were mixed in with the tainted money so long as the
purpose was to conceal or make the offense easier to
commit or harder to detect.
The next property I will address is the
personal property, specifically, 60 gold coins, watches
and two pieces of miscellaneous jewelery. First, the
government is seeking to forfeit 60 gold coins which are
identified in the instructions and the bill of
particulars that you heard me read earlier. You have
seen ample evidence that these gold coins were purchased
with proceeds from fraud convictions. First, you saw and
heard evidence of the defendant's transactions with
Piccadilly Jewelers where the defendants spent more than
$238,000 in proceeds in just three months buying gold and
jewelry. You also heard Ms. Robinson testify that these
funds are traceable to two PPP and EIDL loans for which
you convicted the defendants as part of the Count 1
conspiracy.
And you have also seen Piccadilly's invoices,
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and you will have them back there with you in the jury
room. And you have actually seen the specific checks
identified. 30 coins and 30 coins paid from Mod
Interiors. A loan which is part of the conspiracy.
Moving on to the six watches the government is
seeking to forfeit, you have seen and heard evidence
connecting these items to the counts of conviction as
well. First, you heard from Ms. Robinson that at least
$82,000 of PPP and EIDL loan proceeds were transferred to
Gentleman Timepieces, and you saw some of those very same
watches here in court.
You heard Mr. Farr testify about his
transactions with Richard Ayvazyan. You also saw
evidence that hundreds and thousands of dollars more were
transferred from the entities involved in the conspiracy,
entities which you should recognize from the earlier
phase of trial, charged in Count 1.
Now, you can see in Ms. Robinson's summary
chart, numerous entities familiar to you and the total
received by Gentleman Timepieces, $430,620.
Now, the government is seeking to forfeit six
watches, and they are listed here. You also heard them
when the court provided you the jury instructions. And
you will see, four Audemars Piquet and two Rolexes.
And if we look at the records produced from
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Gentleman Timepieces, we see multiple Audemars Piquet and
Rolexes. But that is not all. You also heard that with
respect to some of the jewelry and watches, there was an
additional $9,200 in PPP funds which were part of a wire
transfer just the day before the defendants were arrested
in Miami using a card linked to Iulia Zhadko which was
found on Richard Ayvazyan at Miami Airport when he was
arrested.
Think about it, ladies and gentlemen. Just
one day before they were stopped at Miami International
Airport, returning from the Turks and Caicos islands, a
card found on Richard Ayvazyan was used to wire more than
$34,000 to a Carribean Bank for the purchase of goods.
You are entitled to draw reasonable inferences, ladies
and gentlemen.
You have seen and heard the conspirator's
purchasing history. You have seen the card not in their
name which was used to wire the money, and you know what
the government is seeking to forfeit here. The evidence
shows that all of the personal property, the gold coins,
the watches and the pieces of jewelry found on the
defendants in Miami are traceable or involved in the
counts of conviction.
And the final assets I will address are the
seized cash. Specifically, the government is seeking to
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forfeit just over $450,000 in cash seized on
November 5th, 2020, from the home and backyard of the
Topeka property as well as $3,422 in cash seized on
November 20th from Richard Ayvazyan and Marietta
Terabelian when they were stopped at Miami International
Airport.
You have seen and heard more than enough
evidence to determine by a preponderance of the evidence
that the cash seized from these defendants is connected
to the crimes for which you have convicted them beyond a
reasonable doubt both as the proceeds of the fraud
convictions and as property involved in the money
laundering conspiracy conviction.
First, you heard Ms. Robinson testify about
tracing just 27 of these loans and 24 bank accounts, and
in just those 27 loans and 24 bank accounts, she found
over $300,000 in cashier's checks. She found $17,000 in
checks, and more than $180,000 in withdrawals traceable
to PPP and EIDL funds.
So you heard there was ample money moving
around in this conspiracy. And, now, even if you
suspected that maybe these defendants were mixing tainted
proceeds with legitimate proceeds, remember the Court's
jury instructions for money laundering. You do not need
to find that each and every dollar of cash was connected
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to a particular transaction that Ms. Robinson traced for
you so long as you conclude by a preponderance of the
evidence, more probable than not that the defendants were
mixing tainted and untainted money in order to make their
criminal proceeds harder to find.
As the Court instructed you, property used to
facilitate the money laundering transaction may include
property that was not part of the transaction itself but
was used to make the money laundering offense easier to
commit or harder to detect.
Second, you heard again and again that these
defendants were rapidly converting their criminal
proceeds into fungible property.
MR. RAM: Objection. Not in evidence. That never
came up.
MR. BOYLE: Withdrawn.
THE COURT: Objection sustained.
MR. BOYLE: Second, you heard again and again the
defendants were rapidly converting their criminal
proceeds into property. You heard, you saw a hundred
thousand dollar transfer to Diamond Merchants. That is
Belgium, New York. You heard about the purchase of
hundreds of thousands of dollars in luxury watches. You
saw receipts for purchases. These are receipts from
Piccadilly Jewelers, purchases of kilogram after kilogram
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after kilogram of gold.
You are entitled to draw a reasonable
inference from this evidence you have seen, ladies and
gentlemen. These conspirators were conspiring to launder
and convert the tainted funds that they had obtained in
multiple ways. Don't forget. You convicted them of a
money laundering conspiracy.
Third, you can consider where this cash was
found. You have heard that the bulk of this cash was
found at the Topeka property. As you have seen, that
entire property was part of the money laundering
conspiracy. You have heard it was bought with tainted
funds and that it was used to house numerous other items
which were also bought with tainted funds including
numerous watches which you have already heard about and
the 60 gold coins which you have already heard about.
So you know that this property, the Topeka
property, it was a place that defendants used to hide the
items that they had purchased with the proceeds of their
fraud. In addition, you heard that some of the cash was
actually found in the back yard of the property, and your
common sense can tell you why people would or would not
keep large amounts of cash in the backyard of their
house.
Fourth, don't abandon your common sense at the
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courthouse steps, ladies and gentlemen. Quite the
opposite. You are entitled to rely on that common sense.
You are entitled to ask why someone would have nearly
half a million dollars of cash in their home and draw
reasonable inferences from that.
Now, you have seen and you know it is not
because these defendants didn't trust or didn't know how
to use the bank. We saw Ms. Terabelian's bank accounts.
You can certainly see she had no problem conducting
business with them. You also saw records from
Mr. Ayvazyan's company, Inception Ventures, and for Mod
Interiors, a company he was a signator on the bank card
for. You also heard that these defendants were stopped
at Miami International Airport with multiple banking
credit cards which weren't in their names.
So you have seen more than enough evidence to
conclude that these defendants knew how to use banks when
it suited them. Then consider why the defendants who are
plainly familiar with electronic banking might have over
$450,000 around their house. Don't forget your common
sense, ladies and gentlemen.
Finally, remember the burden of proof at this
stage. More probable than not. You are entitled to ask
yourself is it probable a family sitting on more than
$450,000 in untainted cash savings might suddenly decide
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to start committing all of the crimes you have convicted
them for. Then ask yourself is it more probable than not
that this cash and the remainder of the assets I
discussed today come from the very similar criminal
schemes for which you have convicted the defendants.
Ladies and gentlemen, remember the court's
jury instructions, remember the court's forfeiture and
jury instructions, and don't forget your common sense.
You have seen and heard the evidence in both phases of
trial and that evidence shows that each and every one of
the assets identified in those instructions are connected
to the crimes for which you have convicted the defendants
beyond a reasonable doubt.
Thank you, ladies and gentlemen.
THE COURT: Defense.
MR. RAM: Yes, your Honor.
Good afternoon. Let's be clear what this is
not about. It is not about restitution or any money owed
to banks or anyone else affected by the crimes that the
defendants were convicted of. This is not a restitution
hearing. That will be decided by the court at a later
date.
As the prosecutor pointed out, forfeiture is
part of the penalty or punishment flowing from a
conviction, and your analysis is based on each specific
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piece of property. And for each specific piece of
property, it boils down to essentially two questions
which you heard the prosecutor describe. For what he
called the fraud offenses, the question is, is that piece
of property directly or indirectly traceable to proceeds
of the fraud. And for any piece of property you deem or
find to be obtained by means of money laundering, was it
involved in that money laundering that you found. Okay.
This is not like the conspiracy charges. The
burden is on the government to tie a specific piece of
property to the specific PPP loans that were traced in
this case. And you heard that the standard to do that is
a preponderance of the evidence. So the government has
to prove to you that it is more likely than not. Over
the 50-yard line so to speak.
And you can break down the items in different
categories just like the government did. I didn't see
his slides before I did this. So we agreed that these
are the categories for the most part, and that is
currency, slash, cash, watches, other jewelry, gold
coins, bank accounts which you heard about, but they are
not in dispute with respect to Richard Ayvazyan. There
is no argument about bank accounts here. And, finally,
real estate. And only one property is at issue with
respect to real estate with respect to Richard Ayvazyan.
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Let's start with currency and cash. As you
heard today and from trial, there is no evidence that the
$451,000 of cash found at Richard Ayvazyan's personal
residence is proceeds that are traceable to PPP fraud.
You did not hear a single piece of evidence doing that.
The government tried to do that with deposit
receipts which you saw this morning with Ms. Robinson,
but we shall able to show for essentially every single
transaction which we will go through in a second, that
wasn't -- that did not yield cash. That was deposited in
another bank account. That is not cash. And we are only
talking about right now that $451,000 of cash.
You also heard that throughout trial that the
government surveilled the defendants in this case. They
kept a close eye on them. They watched them. They had
ATM footage which some of that you saw at the trial. And
none of those instances do you see any cash going to
anyone sitting on this side of the room. That wasn't
part of the case at all. And you also didn't hear
evidence of any abnormal cash withdrawals or text
messages talking about withdrawing cash.
And that is unremarkable because the way the
scheme worked according to the government is the
defendants were obtaining PPP funds, putting them in bank
accounts and moving them to buy property. Cash wasn't
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even in the government's own theory of the case, period.
And as you saw this morning, the government
ignored where Richard Ayvazyan's cash actually came from,
and in the exhibits provided to you, there is accountings
into different bank accounts connected to Richard
Ayvazyan. And you will see that he got some money from
health care companies unrelated to any allegation of PPP
fraud.
You also heard at trial what Richard Ayvazyan
actually does or at least used to do before this trial,
and he works with tech start ups. And one of them, you
heard the incubator's name was COLabs. You will see he
was getting paid from COLabs every two weeks anywhere
from 15 to $30,000 and that is designated as Company
Laboratory LLC. That is in government Exhibit 87. That
is in evidence. That is what Richard Ayvazyan did, and
that is how he got paid. 15 to $30,000 every two weeks
for working with incubators in connecting start ups.
You also heard that he had money before PPP.
You heard that he gave, for example, a $600,000
investment into one of the start up founders that came in
and testified at trial, Matt Pelletier, and that start
up's name is Community.com a well known start up. And
that is all before PPP. And the -- what you see in
Exhibit 87 on the screen here is even during the months
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of August, September and October leading up to his
arrest, he is getting 15 to $30,000 every two weeks from
an established tech incubator called COLabs. That is not
in dispute here. And that is a source of money, a lot of
money.
The other source of money the government
conveniently neglected is casino earnings. We picked one
example from 2019 because that is before PPP. We also
showed you an example from 2009 to show you how long
Richard Ayvazyan has been gambling in Vegas at casinos.
Okay. Just looking at the funds from 2019 meaning
immediately before the alleged -- well, what you have now
concluded was a PPP fraud scheme, Richard Ayvazyan earned
$211,695 just from one casino. That is one casino. And
that is the Bellagio. That cannot be proceeds of PPP
fraud because this happened before PPP existed. Okay.
And there is obviously -- and we don't need to get into
other casinos or other money, but there are legitimate
sources of funds for Richard Ayvazyan, clean funds from
casinos pre-PPP and from his work with tech start ups,
and that far exceeds $450,000 in cash.
So let's talk about what the government did to
suggest that cash was part of this PPP loan fraud scheme.
They put up this summary chart, Exhibit 401, and almost
the vast majority of the transaction is focused on a man
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named Arman Hayrapetyan who you heard plead guilty for
being connected to the PPP loan fraud.
And I won't do it with you now, but each one
of these lines was addressed on cross-examination with
actual records both from the defense, and from the
government to show these transactions did not result in
cash. They just didn't. Let's take the first one as an
example. Account name Arman Harapetyan, and the payee
was Anna Manukyan. You saw there was a check deposit
into that account of Anna Manukyan. Okay. That wasn't
deposited to cash. Same thing next entry, Iulia Zhadko.
It is deposited into an account on May 14th. That is ten
days after the check is written.
Next entry, same thing, Fiber One Media. It
is deposited into an account, in this case a bank called
Novo, a mobile bank. The Zhadko transaction, Wells
Fargo. Same thing. Defense exhibits 201, 202. It is
deposited on June 17th into the Bank of America account.
No cash there.
And, finally, the Secureline, slash, Tamara
Dadyan transaction of $120,000, it is deposited on
June 12th into the ABC Realty Advisors account. And we
know that is the case because it is even one of the
government's overt acts in the indictment. It says that
she and others deposited that very check for $120,010
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into Secureline Realty's bank account. That is not cash
proceeds.
Okay. Next, along the same lines of evidence,
they cited to this page 5 of Exhibit 401 and said look at
this activity here, this could have all led to cash. And
they flagged $219,000 with 181,000 of it traceable to
PPP, EIDL loans. The vast majority of that comes from a
single withdrawal by, again, Arman Hayrapetyan for
$165,000.
You saw that after -- and that is in May. You
saw that on May 14th, Arman Hayrapetyan deposits $80,000
in cash into the bank account here. 80,000 in cash.
That is essentially half the amount the government has in
play. Leaving only 85,000 in net withdrawals.
But you also know that Arman Hayrapetyan is
not connected to any of the defendants sitting at this
table to my left here. He is not. To the extent he had
any cash, that is not going to any of these defendants,
and, frankly, you have just heard no evidence to that
effect either way. So that is certainly not a
preponderance of the evidence, more likely than not.
Now, you see the reference to GX10. That is
the text messages. That is Tami and Rich New text
messages. They were fairly explicit in everything they
did in those text messages, and there is not a single
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conversation about converting funds to cash. As I
mentioned earlier, that simply wasn't part of this scheme
that the government charged. This wasn't about
generating cash.
We talked about the surveillance, the security
tapes, all of that. The trash pulls from different
houses connected to this case. The 500-plus subpoenas
served in this case, review of bank files and records.
None of it points to any cash withdrawals related to
anyone sitting at this table. Period. I think that is
affirmatively disproved that there was any cash from PPP
or EIDL loans that end up with Richard or Mary Ayvazian
at their house at Topeka Drive. And, again, the burden
is on the government not the defense to prove that, but
we have. There was no cash.
Now, let's talk about watches, other jewelry
and gold coins. As you heard, if watches or jewelry or
gold coins were proceeds of the crime, then they can be
subject to forfeiture. But it is the government's burden
to prove which watches, jewelry or coins were traceable
to any PPP loan fraud. So just the fact, obviously, that
someone owns jewelry, watches or gold coins before the
alleged PPP or even during the alleged PPP scheme does
not mean they are subject to forfeiture. The whole point
of this exercise is to show a connection between the
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crimes of conviction, the counts of conviction and any
specific piece of property. So let's talk about what
connections were shown.
First, there is the watches. As you saw from
Ms. Robinson's chart and her testimony, approximately
$82,500 is traceable to PPP funds that went to
Gentleman's Timepieces. 82,000. There was an additional
watch purchased in Turks and Caicos. Of that amount
approximately 9,000 was actually traceable to PPP. Doing
the math, roughly $91,200 in watch purchases is traceable
to PPP EIDL loans. 91,200. That is all the government
can show in terms of tracing.
So we would propose two watches that you will
see on your verdict form that would be subject to
forfeiture based on that tracing. And that is the AP
watch with the serial number ending in 2335 which was
$60,000, and the Rolex purchased in Turks and Caicos for
34,750. That adds up to $91,200.
Let's walk through that so you see where it
comes from in the evidence. So here, there is only
82,000 traced to Gentleman's Timepieces. And you herd
Ms. Robinson explaining, well, I only reviewed 27
accounts and 24 loans, but, bear in mind, it is the
government's burden to show anything being forfeited
which is a penalty independent of restitution is actually
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from the crimes of conviction. Right. It has to
actually be from PPP and EIDL loan fraud. If it is not
connected to the fraud, any specific piece of property,
then it is not subject to forfeiture. Okay.
And the government talked to you about money
laundering, and we are going to get into that in a
second. But high level, the only money with the
exception of Vahe Dadyan for Count 27 of the indictment,
the only count in the indictment relating and not
including the counts that you acquitted Mr. Ayvazian of
which was post release money laundering, there is only
one money laundering count in the indictment, and that is
count 26. And that was a conspiracy or an agreement to
commit money laundering. There were no specific findings
based on the indictment or your deliberations so far that
any specific piece of property was tied to the money
laundering.
The overall gist of the government's money
laundering case is that these funds and bank accounts
were being concealed because they are in other people's
names, and the loans were being applied for in other
people's names, specifically, Zhadko, Kauichko and
others. Right. And we are not contesting a single bank
account here. All of that is subject to forfeiture.
There is no argument on the bank accounts.
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The question is is any specific property
purchased that you heard about that the government is
trying to forfeit, that the government has already
seized, is it subject to forfeiture. So with respect to
Gentleman's Timepieces, there is watches adding up to
over $400,000. How many of those watches is connected to
the PPP and EIDL loans that are the foundation of this
case. The answer that the government came up with is
only 82,000 are traceable.
It is not enough to say hey there is a money
laundering account out there, and it was a conspiracy.
The question is have they proved by a preponderance
meaning past the 50-yard line on the football field that
any given watch is tied to any count of conviction. And
they haven't done that. And Ms. Robinson, to her credit,
told you she wasn't even asked to do it. She just looked
at the 27 accounts and the 24 loans.
And the burden at all times here is on the
government. Not on the defense. But what we can tell
you is 82,000 at most is tied to any criminal conduct in
this case. There is no specific money laundering
allegation on any specific watch in this case. Period.
The agreement was in the abstract, and that is largely
focused on the bank accounts and the flow of funds.
This is the watch purchased in Turks and
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Caicos, 9,000 of it, 9200 of it was traceable to PPP
proceeds. And this is a great example. So what about
this transaction makes it subject to forfeiture? So the
government could argue this particular watch was
purchased as part of the money laundering conspiracy.
But what evidence have you heard that this particular
watch was purchased as part of the money laundering
conspiracy. That is an argument. That is not evidence.
And evidence is what decides just like in the
criminal proceedings before, evidence is what decides
what is subject to forfeiture. And, again, the two
watches we propose that are subject to forfeiture that
add up to $91,200 would be the AP model 26331 and the
Rolex serial W44P7238.
Let's talk about the other jewelry. The
government's evidence must link up each particular
specific item to the case. So, obviously, if a piece of
jewelry was bought before the case started, it can't be
part of the PPP loan fraud. It just can't. And if it
was bought from proceeds completely independent of this
case meaning clean money, it can't be part of forfeiture.
It is a specific item purchased that has nothing to do
with any count of conviction.
So what did the government present to you in
terms of actual evidence that any particular piece of
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jewelry is connected. Frankly, the only evidence you
really saw in this case is the invoices and receipts from
the stores, and they had very general descriptions. So
here is an example of a, quote, unquote, receipt that may
or may not relate to a watch that was seized in this
case. It is frankly impossible to tell.
To the extent you can read this, at the top I
have the description from the bill of particulars, and
that is a 14 karat white gold earring with diamond studs.
And the question is has the government proved by a
preponderance of the evidence that this item on the
receipt here. This is just an example, but is that a 14
karat white gold earring with diamond studs that was
seized. That is for you to decide and for you to decide
whether they proved that by a preponderance of the
evidence. I submit to you that it is entirely unclear.
It is at best equally likely. So it is not more likely
than not.
Same thing, here is another description from a
receipt, and, remember, the government didn't call to
testify either in the criminal case or in this proceeding
today anyone from the store to say here is what this item
description means, this is what it is, here is a picture
of the item. You didn't hear any of that testimony.
And the person ho has the burden is the
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government to put on that testimony. They didn't do it.
They have not proved their case for forfeiture. But,
again, up to you to decide. Is this more likely than not
evidence.
Not going to spend a lot of time on the coins.
You heard that there were receipts for 30 coins and 30
coins and that a number of -- something like 60 coins
were seized from the Topeka address. You did not hear
testimony whether there were 75 coins at the Topeka
address. You didn't hear testimony that the coins seized
at Topeka were the coins actually purchased from these
PPP related transactions. You did not hear that
evidence. Let me go back to that. That is Mod Interiors
receipts, government Exhibit 39.
And, finally, the second to last, the
category of bank accounts. That is not being contested
so if there is any bank accounts that the government
proposed forfeiting that is not subject to dispute from
Mr. Ayvazyan at least.
Now, before we go to the last category of
property, I want to show you an instruction that was
included that the court read to you. And, obviously, the
handwriting is mine. This is instruction No. 1, and it
says forfeiture of fungible property: The government is
not required to identify specific cash, precious metals
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or bank funds involved in an offense that is the basis
for forfeiture because it is not a defense that the cash,
precious metals or bank funds involved in such an offense
were removed and replaced by identical property. Any
identical cash, precious metals or bank funds found in
the same place or account as the property involved in the
offense that is the basis for the forfeiture shall be
subject to forfeiture.
Now, couple of things to observe here. First,
and foremost, the government still has to prove that that
property whether -- well, two things really. Was it
removed and replaced. You have heard no evidence that
any particular piece of jewelry in this case was removed
and replaced. You have heard no evidence on cash that it
even existed in this case.
So what this is talking about is when, let's
say you have a gold coin. Let's just use the example.
And I buy the gold coin from the store using PPP funds
that were legally obtained. That is forfeitable. If I
move it to my house, it is forfeitable. If I sell that
gold coin for a thousand dollars and buy something else
that costs a thousand dollars, a golf club, that golf
club is forfeitable because as the prosecutor told you
any proceeds that are traceable remain forfeitable.
Okay. That is absolutely true.
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But what this doesn't do is if that initial
gold coin for a thousand dollars was not proven to be
part of any crime of conviction, then it is not
forfeitable. It doesn't matter whether -- and there is
no evidence that it was replaced or otherwise changed,
the burden is still on the government to show you by a
preponderance of the evidence that that gold coin is
proceeds of a crime of conviction. Okay.
I submit to you even for the gold coins the
government hasn't done that here. No one came up on the
stand to tell you what gold coins were related to any PPP
funds. That just didn't happen. And you have a very
vague description from the receipt. But that may be a
close call for you. What is not a close call with this
instruction or otherwise is the cash in this case. There
is no evidence of any connection of cash to the schemes
or conspiracy in this case. There just isn't.
So whether a particular dollar is fungible or
not, obviously that is not in debate. Of course, one
dollar here is the same as another dollar in another
pocket. It doesn't matter. But the government doesn't
get the benefit of this unless they can show that the
original property was, in fact, derived from an offense
of conviction and, second, that it was somehow removed or
replaced. And so it is still -- we don't need to show
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the original coin if you have a replacement coin. That
doesn't apply to anything in this case, let alone the
cash.
Okay. Now coming back to wrap up here on
the last category of property. It is the house. Okay.
There are I believe three houses that are subject to
forfeiture in this case according to the government.
Richard Ayvazyan has no claim to the house at La Calle
Primavera or the other house you just heard about today.
The only house in dispute is Richard Ayvazyan's personal
residence, and that is the Topeka Drive house.
And you heard from Ms. Robinson today that
just to synthesize the testimony about half the proceeds
that went into escrow were she argued traceable to PPP,
EIDL loans and half were not. They were clean funds
unrelated to PPP. Okay. That is a fact, and the
government told you it doesn't matter if only a portion
are traceable because if the property resulted from the
money laundering offense of conviction, then the entire
property can be taken. Okay.
So think of it this way in an extreme example.
If one dollar of PPP went into the house, and the other
1.19 million was from clean funds, the government could
argue that the entire house is subject to forfeiture
because a single dollar of PPP went in. Right. It
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could.
And that as a legal proposition is true, but
what the government has to do and you heard the
prosecutor admit it several times over and over. They
can't just say there was a conspiracy money laundering
conviction. The government has to show that this
specific property subject to forfeiture, in this case,
their personal residence, right, was in fact a
monetary -- a financial transaction that came from
concealment money laundering charge in the indictment.
That is what the government has to show, and they are not
going to be able do it in this case. And here is why
that is.
So, you first you see the transfers that
come in. This just establishes that there is something
like $632,000 that are undisputedly not PPP funds, are
not traced to PPP. So, again, we will use the number
about half of the funds to purchase this house are not
PPP. What is the other thing you see? The other thing
you see is this is a house. And you have heard testimony
that there was an escrow company that held the funds for
the transaction. And, in escrow, there are detailed
documents identifying the sources of funds.
Right. So, in other words, the fact that
money came from Timeland Transport in $110,000 which was
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PPP funds, that is in the escrow documents. The fact
that money came from Allstate Towing, Marietta
Terabelian, and from Inception Ventures which is Richard
Ayvazyan's tech company, all of that is in the escrow
documents. None of that is concealed. So with respect
to the actual purchase of the house through the escrow,
there is no concealment. There is no concealment there.
This is the actual escrow records which are in
evidence. You can see that for yourself. It is
government's Exhibit 32A and 32B. All of it is plainly
laid out which entities and from whom the funds are
coming from. That is not concealment money laundering.
At best, at best and, remember, the government only
charged with respect to this property putting aside Vahe
Dadyan, there is only one count of conviction on money
laundering, and that is a conspiracy to commit.
It wasn't linked to specific property at all.
But at best, I submit to you the only money laundering
arguably is with respect from the transfers of the loan
funding to accounts that are in ambiguated account
holders. So, in other words, Iulia Zhadko, you have
concluded is a fake person, and there is money moved to
Iulia Zhadko.
Artur Ayvazian is a real person. Right. So
that is not concealment money laundering for Artur
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Ayvazian to apply for a loan in his own name and get
funds into his own bank account. Same thing, Redline
Auto Collision. You heard about Edward Paronyan. That
is not concealment money laundering. That is committing
PPP loan fraud but not concealment money laundering.
Same thing, Secureline Realty and Tamara Dadyan. None of
that -- that is in her own name and her own company --
none of that is concealment money laundering.
At best, if you have to argue for some
concealment somewhere, it would be the transfers in this
secondary field here. The hundred thousand to the
Terabelian account. The 120,000 and the 136,000 to the
Dadyan account. Okay. At best, those. So if the
government was seeking to seize and forfeit those
accounts which they are, those are subject to forfeiture,
no question. The entire contents of the account.
The government can make the argument that
clean money in that account served to make it -- that is
the magic phrase -- to facilitate or make it harder to
detect that money laundering was happening.
So that could be concealment money laundering,
but what is not concealment money laundering, it is the
opposite of concealment money laundering is any escrow
transaction here which highlights on essentially a public
record who and which accounts the money is coming from.
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And that is accurately reported there. That is not
concealment money laundering.
So the question is why does it matter. Okay.
Why does it matter that this isn't concealment money
laundering because you are going to get a verdict form
for each piece of property, and, as the prosecutor
explained to you, there is essentially two different --
if you boil down all the accounts to two different
pathways. There is the first pathway for the fraud
counts which say it is directly traceable, and, then,
there is the second pathway for money laundering specific
property meaning property obtained by virtue of money
laundering. And then the question is what was involved
in that transaction. Okay.
Now, within the money laundering, the
government charged two different objects. One is what is
called transaction almoney laundering or spending money
laundering where there is a transaction of greater than
$10,000 that used PPP funds.
Money involved in that transaction would be
the PPP funds. So the example for the Turks and Caicos
watch, it would be the $9,000 out of the 34,000, but if
there was concealment money laundering with respect to a
specific asset as the government has argued, then the
money involved in that transaction would be the other --
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for using the Turks and Caicos watches as an example, the
other 25 something thousand dollars. Right.
And the reason it matters and makes a
difference here is when we are looking at the escrow
transaction, if it is not concealment money laundering
which it is not I submit to you. Then the funds that are
subject to forfeiture is at most, at most just the
$639,807. Okay. That is it. And, again, the burden is
on the government. So when you are checking, you know,
your verdict form box, you are going to have essentially
three options.
You are going to say for any given property
not just this house, yes, it is subject to forfeiture,
or, no, it is not. Well, you have a third option of it
is subject to forfeiture but in a lesser amount than the
full value of the property. And you can write that in.
Okay. And here for the house, it is the third option at
best. It is -- if it is subject to forfeiture, it is
only in the amount of 639,000. This is not a concealment
money laundering transaction. This is open to the world.
And I will leave you with the burden is on the
government, and it matters. Okay. The government has to
affirmatively prove that this specific purchase, not any
upstream bank accounts or whatever else they are trying
to forfeit -- right -- but this purchase of a house, this
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personal residence, they got to prove that by a
preponderance. And it matters because this is the family
home, and, while forfeiture includes a penalty or
punishment, it is not intended to punish the three
children that live there.
So we got to be sure that the government has
proved concealment money laundering before you take those
kids' house away. That is the law. They have to prove
that this house purchase is concealment money laundering
for you, not you, for the government to take the entire
house. Okay. It is that important, and it makes a
difference in everyone's lives.
All right. At the end of the day, the big
picture points, this is about tracing specific assets to
counts of conviction. Right. And you get that. And
that is the exercise that needs to be done both for the
fraud counts which is the traceable proceeds and for
anything you deem to be part of money laundering which is
potentially broader. Okay.
So it is up to you to ask the critical
questions, what evidence has the government presented for
this specific asset subject to forfeiture. And if you
don't have evidence that convinces you that it is more
likely than not, if you think it is a close call and may
be evenly likely or less likely than it is likely, then,
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that means you select no when it comes to forfeiting that
specific piece of property.
And at the end of the day, it is the
government's burden at all times. Thank you.
THE COURT: Do the other defendants wish to make
final arguments?
MR. MESEREAU: Submitted, your Honor.
MR. FRASER: On behalf of Ms. Terabelian, briefly,
your Honor.
THE COURT: You wish to make an argument. I just
asked.
MR. FRASER: Yes, your Honor.
THE COURT: Members of the jury, my suggestion is
it is now 1:00 o'clock. I think lunch is ready for you.
Can we take a quicker lunch than usual, maybe a half-hour
and then come back, listen to the final defense's
argument, the government has a rebuttal, and then you
will have the case for decision. Take about 30, 40
minutes and then we will get going. Thank you.
(The following proceedings were held outside the
presence of the jury:)
THE COURT: Let's take a quick lunch break. I
have some other matters to take up over lunch. So you
can leave your belongings if you want or take them at the
table, but other lawyers are coming in just for a brief
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time to make some arguments. I would say 40 minutes.
(Recess from 1:01 to 1:45 p.m.)
(The following proceedings were held in the
presence of the jury:)
THE COURT: Yes, sir.
MR. FRASER: Thank you, your Honor.
This is Ryan Fraser on behalf of Marietta
Terabelian.
As I anticipate you will see soon when you
receive your verdict form, you are about to make a series
of findings that is more specific than the findings that
you made in the earlier phase of the trial. You will see
that your findings go defendant by defendant but also
item of property by item of property.
Now, I am going to be brief. I don't want to
take up any more of your time than is needed, and I stood
up here in part to tell you that everything that Mr. Ram
said in his arguments on behalf of Richard Ayvazyan also
applies as to Ms. Terabelian and the reasons you should
not find property forfeitable as to her.
The government didn't prove the forfeitability
of property as to Ms. Terabelian any better than it did
as to Richard Ayvazyan. The government in its argument
made reference to reasonable inferences, and I need to
point out here the question for you is not whether it
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could be reasonable for a person to draw the inferences
that the government is asking you to make, there is no
deference to the government here.
Your role is to be independent finders of the
facts and to decide whether the government convinced you
that it is more likely than not as to each item of
property that the government has proven what it must in
order to forfeit that item of property.
Forfeiting property as to Ms. Terabelian would
mean that you would be concluding that it was proved to
you, and you are convinced that it is more likely than
not as to her for each item what she did as to that item
of property, what she knew and when.
And there is no evidence in this trial at that
level of detail. I ask you not to find property
forfeitable as to Ms. Terabelian.
MR. JOHNSON: Your Honor, Peter Johnson on behalf
of Vahe Dadyan. Nothing related to Vahe Dadyan so we
submit.
THE COURT: Government?
MR. BOYLE: The government rests, your Honor.
THE COURT: Okay. Then the jury has what it needs
to decide this phrase of the case. You will get the
exhibits. You already have the exhibits relating to the
first phase. You will get the exhibits that have been
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introduced in the second phase and a copy of the jury
instructions and a verdict form. So you should proceed
to decide the case, this phase of the case.
(The following proceedings were held outside the
presence of the jury:)
THE COURT: You may be seated. Let me --
MR. RAM: Your Honor, if I may just on a pressing
issue related to the jury.
THE COURT: Yes.
MR. RAM: It is unclear which verdict form is
going back.
THE COURT: I am giving the government's verdict
form, detailed verdict form.
The -- I wanted to briefly -- obviously, we
can't do it in depth, but I wanted to understand the
newest filing which actually we counted the filings.
There have been just about 600 filings in this case.
600. That must set some sort of record.
But leaving that aside for the moment, can
someone from the government tell me what this newest
issue is about?
MR. FENTON: Yes, your Honor.
So the government believes that during trial,
defendants Richard Ayvazyan and Marietta Terabelian
affirmatively waived their that Castegar claims by
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affirmatively making arguments and eliciting testimony
and evidence related to the compelled statements.
And, if your Honor would like, I can provide a
little bit more detail if that would be helpful.
THE COURT: Let me hear some context.
MR. FENTON: Sure. So I think that it really
falls into two different categories.
The first is that the parties introduced
evidence relating to the compelled statements that the
defendants made during the custodial interrogation while
in CBP custody in response to questions that the
defendants were asked by CBP about certain evidence like,
for example, the credit cards.
The second bucket is that the parties
introduced evidence relating to what was on the
telephones that were suppressed or about the telephones
that were suppressed, for example, by arguing that there
was an absence of evidence based on the fact that some of
this evidence had been suppressed and the government
could not use it.
So the government's argument in a nutshell is
that the defendants used Castegar both as a sword and as
a shield as well which is improper and waives their
claims.
THE COURT: And I haven't considered the matter in
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depth as yet, but is there a case that speaks to this
waiver issue?
MR. FENTON: Yes, your Honor. We would cite two
cases. The first would be United States versus Benson.
THE COURT: B-E-N-S-O-N?
MR. FENTON: B-E-N-S-O-N. And the citation is
2016 West Law, 215, 233. And the second case that would
be helpful is Bittaker, B-I-T-T-A-K-E-R, versus Woodford,
W-O-O-D-F-O-R-D, and the citation is 331 F.3d, 715.
THE COURT: Is that a Ninth Circuit case?
MR. FENTON: That is a Ninth Circuit case, yes,
your Honor.
THE COURT: And in terms of -- and I am just
exploring this on the most surface level at this point,
but does the -- is it a complete waiver or just a waiver
as to the particular subject of the Castegar ruling?
MR. FENTON: The government would argue that it is
a complete waiver. The subject matter is relatively
narrow so we think it is both with respect to -- well,
just with respect to everything that happened on that
day.
THE COURT: How would it relate, for example, to
the Castegar issue and the second superseding indictment?
In other words, are you saying that even if
what you say is established, that that would take off the
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table the argument regarding Castegar with the second
superseding indictment?
MR. FENTON: Yes, your Honor. Based on what
happened during trial, yes.
THE COURT: I mean do these cases speak to that
type of situation?
MR. FENTON: The Benson case talks about the use
of a sword and shield generally, and the Bittaker case
talks about waiving privilege when privilege is -- when
essentially a defendant relies on that privilege.
THE COURT: Doesn't sound like the cases answer
the question precisely.
MR. FENTON: I think that that is -- the two cases
that I cited are more general cases. The government
seeks the opportunity to brief this issue in further
detail.
THE COURT: Well, here is what I am going to do.
I am going to issue an order today which I have already
prepared directing the government to file a submission
regarding its burden in the case, and the way I am
understanding the defense contention is that the second
superseding indictment was linked to the violation in
Miami, and that -- and that evidence at trial and/or
nonevidence, there are bases for Castegar. Aside from
the use of evidence, it was also traced to the violation,
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and this has to be done on a short turnaround.
The reason is that this case involves many,
many facts, many issues, and, with the backlog of cases
we have with the pandemic, I am going right into other
things, and I can't -- I don't have the resources and the
time to relearn everything that I think I have retained.
So I am going to give you 10 days to do that,
and the order I am outlining is very specific as to what
you should do. And then there is going to be a short
turn around for the defense. I think maybe a little
longer than 10 days but not much, and then I am setting a
date for the hearing.
I think I set the date for July 12th.
Actually, the hearing is going to be -- no. The hearing
is going to be on July 26th, and that will give the court
a little time to consider all that is briefed. If you
have some compelling argument about -- have you briefed
the waiver argument?
MR. FENTON: Not yet, your Honor, no.
THE COURT: Well, then, if you want to do it, I
mean, you have an army of lawyers. I don't know how many
more you have than you have already displayed, but there
are at least I don't know four or five lawyers and you
have the resources of the Justice Department and the U.S.
Attorney's office. File something in three days.
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But I am not going to hold up the order
because I think you will need the time to start thinking
about it, and, from what you say, so far, the teaching of
these cases, if any, is not specific as to the scope of a
waiver if there is any waiver.
Has the defense given this any thought? I
don't want to commit you or have you argue something that
you haven't given enough thought to, but do you have any
preliminary thoughts on it?
MR. RAM: Yes, your Honor. I found out about it
in court.
THE COURT: Go to the lecturn, and tell me what
your thoughts are. I mean this is all preliminary
because obviously it has to be.
MR. RAM: Yes, your Honor. As I was saying I
found out about it when I was in court today. We were
preparing for forfeiture over the weekend. I did not see
any filing yet so I don't know what the substance of it
is.
THE COURT: This is all I know is what I just
heard.
MR. RAM: Big picture, I am somewhat at a loss
with the even suggestion of a waiver argument. As the
court is aware, the defendants repeatedly requested, in
fact, the court initially ruled that there would be a
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Castegar hearing before trial. The government explicitly
asked for reconsideration of that ruling and got it.
THE COURT: I am aware of the history. That won't
get us very far. I mean, if you were just made aware of
this motion, it is unfair to get you to speculate and it
is unhelpful to the court. So let's just table it.
MR. RAM: Okay. Just two things I would point
out, just big picture, your Honor, in terms of the
schedule you proposed. I understand the court wants to
deal with this while the facts of the case are still
fresh, and that makes sense. I think the biggest part of
the Castegar hearing from the survey of cases that we
have gone through is going to be the production of
discovery that speaks to the issues of non-evidentiary
use which is at the heart of the defense's contention.
THE COURT: That discovery issue will be more
apparent if necessary as the matter is briefed, and so we
are going to go forward with the schedule. And I am just
telling you to, you know, get yourselves prepared, and it
is all detailed in an order which I will issue within the
hour. All right.
MR. FENTON: Thank you, your Honor. The
government has one more issue it would like to raise with
the court.
THE COURT: Okay.
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MR. FENTON: And that is the issue of detention
pending sentencing.
THE COURT: Yes.
MR. FENTON: The government would like to move to
remand to custody defendants Richard Ayvazyan and Artur
Ayvazian pending sentencing pursuant to Section 3143.
THE COURT: And what is the basis for that?
MR. FENTON: So with respect to Richard Ayvazyan,
just as a general matter, at this point at this stage in
the proceedings, the burden is on the defendants to
demonstrate by a clear and convincing standard that
Richard Ayvazyan does not pose a flight risk or a danger
to the community. The government believes that he poses
both. With respect to flight risk, he faces as
substantial sentence including a mandatory minimum as
demonstrated by the evidence during trial.
THE COURT: What is the mandatory minimum?
MR. FENTON: The mandatory minimum is the two year
mandatory minimum for the aggravated identity theft
counts under Section 1028(a). He has a history of using
fake identities including all the identities that we
offered evidence on at trial. There is a history of
opening bank accounts in other people's names, a history
of borrowing money in other people's names, all of which
make him a flight risk because he is able to disappear
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and essentially move about without detection.
He also has access to millions of dollars in
criminal proceeds that are still unaccounted for. We
have identified $18 million in loans that were taken.
About 80 percent of that amount of money is still
unaccounted for which means it is out there and available
for him to use. He has also been indicted by the
California State Attorney General in a case that will be
proceeding shortly.
And he has experience as an international
traveler including as demonstrated very recently
willingness to travel during the pandemic to the
Caribbean even just for vacation.
In terms of danger to the community, there are
jest a few points here that are very important. The
first is that this is his third conviction for fraud
which is significant and shows that he poses a --
THE COURT: I only knew of one other. There was
some conviction some years ago for mortgage fraud.
Wasn't that right?
MR. FENTON: That's right. In 2012, he plead
guilty. There was a federal conviction. In 1999, there
was a grand theft charge which was a California state
conviction as well.
THE COURT: Was that a fraud conviction?
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MR. FENTON: It is a grand theft.
THE COURT: What was involved in that case?
MR. FENTON: Very similar facts to those alleged
here which is the use of other people's names to
essentially obtain money from a bank. So we see facts
that are similar over the decades.
The nature of the crimes with which he was
convicted is extremely serious, you know, including
defrauding the federal government and banks during a
national catastrophe, and, in addition to that, when his
home was searched even though he is a felon, he had a gun
safe which was found during the search of his home which
strongly suggests that at some point he actually had gun
and likely hid them after he was arrested in Miami and
then released from custody and then returned back home.
So, for all of those reasons, the government
would move to remand Richard Ayvazyan in custody while he
awaits sentencing.
And then, if it pleases the Court, I can speak
on Artur Ayvazian as well or give counsel a chance to
respond.
THE COURT: Go ahead.
MR. FENTON: With regard to Artur Ayvazian, he
similarly poses a flight risk. He faces a substantial
sentence including a mandatory minimum, Section 1028(a),
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aggravated identity theft. He has a history of using
fake identities as demonstrated by the evidence at tria
and also a history of creating fake identities which is
also demonstrated by the evidence found on his telephone
that was offered during trial.
There is a history of opening bank accounts in
other people's names, dozens of different checks and
checkbooks were found in his home, and there are also
other people's checks found in his phone. He has a
history of borrowing money in other people's names as
well and access to the criminal proceeds that are still
unaccounted for.
And then he, too, has been indicted by the
California State Attorney General for fraud as well. So
he is facing additional charges in addition to everything
that he is facing --
THE COURT: He has no prior convictions though.
MR. FENTON: That's correct, your Honor. That's
correct.
With respect to danger to the community,
again, the nature of the crimes for which he was
convicted are extremely serious for the same reasons I
explained with respect to Richard Ayvazyan. The other
point that I would note was when Artur Ayvazian's house
was searched, 12 guns were found during that search. We
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also found 12 guns and ammunition and accessories as well
which shows that he is armed. And those guns were taken
but, nevertheless, he has that --
THE COURT: But there was nothing illegal about
having those guns?
MR. FENTON: He does not have a criminal history,
and that is correct, your Honor. But, nevertheless, he
has a large number of guns in his home or had at that
point.
THE COURT: You never moved to remand Tamara
Dadyan Dadyan, did you?
MR. FENTON: We did not, your Honor. And the
government acknowledges the fact that, in this particular
case, there are two families involved, both of whom have
children, and we are not moving to remand to custody
Marietta Terabelian nor Tamara Dadyan.
THE COURT: But does that mean that your position
is that you are not going to ask for a custodial sentence
for the other spouse?
MR. FENTON: At sentencing?
THE COURT: Yes.
MR. FENTON: No. We will be asking for a
custodial sentence. Absolutely.
THE COURT: Well, then how is that consistent?
MR. FENTON: Well, we believe, and we are trying
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to -- we think that the brothers pose a flight risk. We
think that if the two brothers are both detained, it
makes it less likely that other members of the family
would flee --
THE COURT: I see.
MR. FENTON: -- together.
THE COURT: And there was some mention of
children. How many children are there in each family,
and what are their ages?
MR. FENTON: I will -- the other thing -- there is
three children in the Richard Ayvazyan's household, and
two in Artur Ayvazian's household.
THE COURT: What are their age groups?
MR. FENTON: I will have to let defense counsel
speak to their ages.
THE COURT: I see.
MR. FENTON: I believe that they are younger to
mid teens.
The one additional point I want to make about
the distinction between Artur Ayvazian and Tamara Dadyan
is that Tamara Dadyan has plead guilty and accepted
responsibility and Artur Ayvazian has not which I do
think also accounts for the difference.
THE COURT: He has a constitutional right to go to
trial. The fact that he went to trial, even if you
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believe that he was guilty, shouldn't be held against
him.
MR. FENTON: Absolutely, your Honor. But I do
think the acceptance of responsibility factors into
whether or not an individual is a flight risk.
THE COURT: That is only a factor that the
guidelines consider. I mean, it is a consideration, but
I don't see how compelling it is in distinguishing Tamara
Dadyan from Richard Ayvazyan. What about Grigoryan? You
never moved to remand him either.
MR. FENTON: That's correct, your Honor. We have
not moved to remand him. We think that the roles are
also different as well. Again, Mr. Grigoryan accepted
responsibility, and, based on what we know, we do not
have reason to believe that he has firearms as well.
THE COURT: All right. Let me hear from the other
party briefly.
MR. RAM: Your Honor, we are passing out briefing
on this issue that we had had as a pocket memo. The
government --
THE COURT: What was that now?
MR. RAM: We passed up some briefing on this issue
as well, your Honor, so you could have the full history
and facts, the relationships, the children, the family,
the locations, the monitoring by probation. I can give
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your Honor a moment to review that and then speak or I
can speak now.
THE COURT: Let me read it quickly.
MR. RAM: Okay.
(Pause in proceedings.)
THE COURT: Okay. I have read it.
MR. RAM: Big picture, the government's arguments
are entirely inconsistent and punitive. The punitive is
because Mr. Ayvazian went to trial and through his
counsel filed motions to litigate the case. The
government is requesting his detention.
Its argument is inconsistent because of the
treatment of other defendants that your Honor has just
pointed to, and there is more. So, for example, Arman
Hayrapetyan who has no connections to the United States
at all --
THE COURT: He is a different category. I do
remember his situation. A year or so before the
indictment, he was splitting his time between Armenia and
here.
MR. RAM: Right. So, your Honor, big picture of
the other defendants who have plead guilty, they are not
seeking detention. Because Mr. Ayvazyan and his brother
went to trial, they are seeking detention. Richard
Ayvazyan is not a flight risk. That is the big picture
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point to underscore here. He has significant, as your
Honor can see from the filing, significant surety bonds.
THE COURT: What kind of pretrial supervision is
he under? How does he report to the probation
department?
MR. RAM: Yes, your Honor. He is currently under
home detention, and he has location monitoring. And he
reports to probation officer Manuel Ybanez who was a
witness who testified at this trial. He has been in
complete compliance with all requests from Mr. Ybanez. I
have spoken to Mr. Ybanez multiple times including when
there were state charges, your Honor. And Mr. Ybanez has
shared with me that he has had no issues with
Mr. Ayvazian whatsoever under supervision.
THE COURT: Is the other Ayvazian -- is he under
the same supervision?
MR. MESEREAU: Your Honor, he wears an ankle
bracelet. He is allowed to go to work.
THE COURT: I see.
MR. RAM: Your Honor, adding to it, Mr. Ayvazian
is not a flight risk at all. He has three kids, age 13,
14 and 15. They are his world. The passports are with I
believe the government or the probation officer or one
and the same. They don't have their passports. Their
kids are here in school. Their whole life and community
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is here.
I believe that Mr. Fenton pointed to
international travel and cited a vacation to Turks and
Caicos. That is not indicative of flight. That is not
even a serious argument. The other thing I heard which
stood out, your Honor, talking about danger to the
community, Mr. Fenton mentioned something about guns.
Mr. Ayvazyan has not had a gun in his place since his
conviction in 2012, and that is documented, the turnover
of firearms from that case and that conviction period.
He is not a danger to anyone in any shape or
form. I have gotten to know him over the last eight
months, and, frankly, he is a friend of mine. He is not
a danger to anyone. That is not a serious contention
that this Court should even look at for a split second.
The other thing Mr. Fenton referenced, there is a 2012
conviction, and that is involving a false submission to a
bank in connection with a mortgage purchase. That is a
fact.
Now, this reference to a 1999 grand theft in
state court, and Mr. Fenton alluded to the facts being
similar to this case. That is not true. What I
understand, I don't have the documentation for the '99
conviction in front of me. Big picture, Mr. Ayvazian was
a bank employee. He was working at the bank, and I don't
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have the full details but I think the allegation and
conviction was for having his hand in the cookie jar when
he was 19 years old. That is what the 1999 conviction is
for.
THE COURT: All right. Let's leave it for the
moment. Thank you.
MR. MESEREAU: May I speak on behalf of Artur
Ayvazian?
THE COURT: Yes.
MR. MESEREAU: Thank you.
Good afternoon. Tom Mesereau for Artur
Ayvazian. Your Honor, you heard him testify, and you
have seen the evidence. He is not a major player in this
alleged scheme, and the evidence clearly showed that his
wife and others were masterminding whatever went on. He
is a very peaceful person. He has been in total
compliance with pretrial services. They have allowed him
to go to work. There has been no violation of any kind,
no criticism that I am aware of.
There were some guns that were taken. They
were all in his name. I am informed the majority were
hunting weapons. He does not pose a threat to anyone.
There wasn't one witness that said they ever saw him use
a false ID. The court may recall there was one
transaction involving his towing company that he regrets
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being involved in, but he is not a threat to anyone.
He is certainly not going to flee, and I am
informed that the last time he took any trip outside the
country was 2017. That is my information. He is not a
major player in the case. He testified, I submit
truthfully. I think that your Honor had a chance to
observe who he is and what kind of a person he is. And I
think he is not a flight risk, and we definitely hope he
is not remanded.
Thank you.
THE COURT: Thank you.
(Recess from 2:26 to 4:30 p.m.)
THE COURT: The parties have received the note;
correct? What is the defense's position in terms of how
to answer?
MR. RAM: We have conferred with the government
and agree on a potential response.
THE COURT: That is great.
MR. RAM: So we have it typed.
THE COURT: Let me see it.
MR. RAM: You won't be able to read my writing.
THE COURT: Well, then read it.
MR. RAM: "It is in your sole discretion whether
the government has established the requisite connection
between a count of conviction and a specific piece of
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property and, if so, the extent of that connection.
While you may write in an amount, it is up to you to
determine the amount connected to a count of conviction
for any given property subject to forfeiture."
THE COURT: I mean, that is pretty close to what I
had in mind before I came out here, so I agree to it.
MR. RAM: Okay.
THE COURT: You say you have it typed out?
MR. RAM: I think we just sent it to Mr. Cruz.
MR. SILVERMAN: I sent it maybe 30 seconds ago,
and I CC'd Mr. Boyle.
MR. RAM: We also looked for a person with good
handwriting, but could not find one.
THE COURT: I am just going to write on top in my
handwriting and then "to the jury" and sign my name Judge
Wilson, answer to note No. 1.
THE COURT: Okay. Would you send this to the
jury.
(Recess from 4:33 to 5:03 p.m.)
(The following proceedings were held outside the
presence of the jury:)
THE COURT: We have received a note from the
foreperson of the jury that the jury has reached a
unanimous verdict.
Can you hand me the verdict, or have the
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foreperson hand it to you, Mr. Cruz.
I am just reading them in the order that they
were handed to me. There are so many entries in the
verdict form. If all the answers are the same, I am just
going to say yes or indicate where there is no.
So, as to Vahe Dadyan, on the verdict form,
every question is answered yes, and it is signed by the
foreperson dated 28 June, 2021; correct, madam
foreperson?
THE JUROR: Yes, your Honor.
THE COURT: And, then, next, in the order given to
me is as to Artur Ayvazian. Question 6 was answered no.
Question 12 was answered no. Question 18 was answered
no. There is a circle around that and some initials with
a slash in the yes bracket with what appears to be the
foreperson's initials; is that correct?
THE JUROR: Yes, your Honor.
THE COURT: So is the answer to question 18 no?
THE JUROR: Yes.
THE COURT: And question 24, no. Signed by the
foreperson dated June 28th, 2021. 24, I said was no.
All the other answers are yes.
As to Richard Ayvazyan, question 6 has a yes
but a circle. Was that the answer to question 6, yes?
With regard to Richard Ayvazyan?
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THE JUROR: If it is circled, your Honor.
THE COURT: That means that is the answer?
THE JUROR: Yes, your Honor.
THE COURT: Question 7 is no. Question 23 is no.
Question 39 is no. Question 55 is no. All the other
answers are yes. Signed by the foreperson, 28 June,
2021.
Next is to defendant Marietta Terabelian. 7
is no. Question 23 is no. Question 39 is no. Question
55 is no. All the other questions are answered yes
signed, 28 June, 2021 by the foreperson.
Is that the verdict so say each of you?
I see nodding of heads, does anyone want the
jury polled?
MR. MESEREAU: Yes, your Honor.
MR. RAM: And just clarification because they
don't have it with them. On the 451,000, there was a yes
circled.
THE COURT: I don't know. They answered the
questions. The verdict form was responsive.
Just poll the jury.
THE CLERK: Yes, your Honor. Ladies and gentlemen
of the jury, as I call your name, please answer yes if
the verdict as presented and read is your verdict.
Ms. Vargas?
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THE JUROR: Yes.
THE CLERK: Mr. Diaz Brown?
THE JUROR: Yes.
THE COURT: Ms. Perez?
THE JUROR: Yes.
THE CLERK: Mr. Lam?
THE JUROR: Yes.
THE CLERK: Ms. McGilly?
THE JUROR: Yes.
THE CLERK: Mr. Regidor?
THE JUROR: Yes.
THE CLERK: Ms. Kaminir?
THE JUROR: Yes.
THE CLERK: Ms. Hernandez?
THE JUROR: Yes.
THE CLERK: Mr. Almader?
THE JUROR: Yes.
THE COURT: Ms. Lars?
THE JUROR: Yes.
THE CLERK: Ms. Calloway?
THE JUROR: Yes.
THE COURT: And Ms. Kish?
THE JUROR: Yes.
THE CLERK: Did I miss someone.
THE COURT: Everybody was polled?
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THE CLERK: Yes, your Honor.
THE COURT: Okay. At this point, members of the
jury your service is complete, and, at this point, I can
thank you for your extraordinary service in this case.
You were extraordinarily punctual, you were very
attentive, and many of the exhibits involved numbers and
other things and sometimes a jury fades out, but I didn't
notice that at all.
And so I want to commend you and thank you,
and you are now all excused. I have one parting thing to
tell you.
You may have some questions about the
confidentiality of the proceedings. Now that the case is
over, you are free to discuss it with any person you
choose. But by the same token, I should advise you that
you are under no obligation whatsoever to discuss the
case with any person.
Always bear in mind that if you do decide to
discuss this case, the other jurors fully and freely
stated their opinions with the understanding that they
were being expressed in confidence. Please respect the
privacy of the views of the other jurors.
Finally, if you would prefer not to discuss
the case with anyone but are feeling under pressure to do
so, please feel free to contact the courtroom deputy who
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will notify me, and I will assist. Thank you again.
(The following proceedings were held outside the
presence of the jury:)
THE COURT: All right. That concludes the case at
least for the moment. The government did, I trust, get
the order? Did you see it?
MR. FENTON: Yes, your Honor. On Castegar?
THE COURT: Yes.
MR. FENTON: Yes.
THE COURT: All right. And so our next meeting
will be the hearing on the Castegar motion.
Thank you all for your vigorous representation
and your participation. Thank you.
MR. SILVERMAN: Your Honor, one piece of
scheduling. We would propose that Rule 29 and 33 motions
be briefed three weeks after the Castegar hearing. That
would be August 16th. We have floated that idea to the
government. I don't know if they have a position at this
time.
THE COURT: Why are the motions dependent on
Castegar?
MR. SILVERMAN: Your Honor, we will be preparing
for and writing to the court about Castegar in the
interim.
THE COURT: I mean, wouldn't your arguments
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regarding Rule 29, if they are based upon Castegar, be
evident in the Castegar motion?
MR. SILVERMAN: They would, your Honor. However,
we will be litigating the Castegar motions actively
between now and the conclusion of the Castegar hearing.
THE COURT: I see. Well, I have to think about
the -- about the schedule. I don't want to put things
off long because, as I said, the case is fresh in my
mind, and the longer it drifts, the more difficult it
will be for me to get back into it.
And I have made an effort to do the best I can
to study the evidence as it has been presented and
argued.
I will issue an order in that regard. Okay.
MR. SILVERMAN: Thank you, your Honor.
THE COURT: Yes. Let's set a date for sentencing.
What about -- what is the government's
position on the suggestion about the Rule 29 motions?
MR. FENTON: The government defers to the court,
your Honor.
THE COURT: I see.
Is there some reason why you couldn't make a
motion now on all issues that you think are deserving of
a Rule 29 motion, and we can hear them all on the same
date? Or a date soon after the Castegar hearing?
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MR. RAM: One reason, your Honor, would be there
is some case law that would suggest if there is a finding
of evidentiary or non-evidentiary use, that would
implicate, for example, the Rule 29 motion we made at the
close of the government's case. It would be viewed as a
sufficiency of the evidence and could warrant dismissal
of the case altogether in the Rule 29 posture because it
was preserved at the close of the government's case.
So there is some interplay there. We
certainly understand your Honor's point on while things
are fresh, moving. We think there might be more
efficiency waiting till three weeks after.
THE COURT: I will think about that.
On the motion that you made for remand, I am
going to deny those motions.
Okay. Sentencing date, the usual date is 10
weeks; correct, Paul?
THE CLERK: September 13th at 11:00 a.m.
THE COURT: That will be the date.
THE CLERK: Yes, your Honor.
(Proceedings concluded.)
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CERTIFICATE
I hereby certify that pursuant to Section 753, Title 28,
United States Code, the foregoing is a true and correct
transcript of the stenographically reported proceedings held
in the above-entitled matter and that the transcript page
format is in conformance with the regulations of the
Judicial Conference of the United States.
Date: July 8, 2021
/s/ Katie Thibodeaux, CSR No. 9858, RPR, CRR
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Case 2:20-cr-00579-SVW Document 679 Filed 07/09/21 Page 131 of 151 Page ID
#:11029
MR. BOYLE: [43] 5/12 5/16
6/11 11/3 11/10 11/14 21/4
21/11 21/15 22/15 22/22
24/14 30/17 30/23 31/6 32/4
33/4 33/17 34/13 37/18 39/7
39/13 39/20 40/1 41/2 41/5
41/9 43/21 44/15 46/5 46/16
56/25 59/8 59/18 60/9 60/12
60/17 60/25 61/4 62/11 75/15
75/17 103/20
MR. FENTON: [35] 58/23
104/21 105/5 106/2 106/5
106/10 106/16 107/2 107/6
107/12 108/18 110/21 110/25
111/3 111/7 111/17 112/20
112/25 113/2 113/22 114/17
115/5 115/11 115/19 115/21
115/24 116/5 116/9 116/13
116/16 117/2 117/10 128/6
128/8 129/18
MR. FRASER: [4] 45/12 101/7
101/11 102/5
MR. JOHNSON: [2] 44/23
103/16
MR. MESEREAU: [5] 101/6
119/16 121/6 121/9 125/14
MR. PAETTY: [1] 61/25
MR. RAM: [28] 44/21 59/4
60/20 60/24 75/13 78/15
104/6 104/9 109/9 109/14
109/21 110/6 117/17 117/21
118/3 118/6 118/20 119/5
119/19 122/15 122/18 122/20
122/22 123/6 123/8 123/11
125/15 129/25
MR. SILVERMAN: [34] 22/17
22/24 23/8 23/18 25/16 26/12
27/11 27/17 30/24 31/10
31/13 32/6 32/11 32/18 32/24
33/21 38/18 39/2 39/22 40/12
41/1 43/23 44/12 45/16 46/2
58/13 59/22 60/3 60/8 123/9
128/13 128/21 129/2 129/14
THE CLERK: [20] 5/14 6/10
6/12 44/9 44/16 58/8 58/10
125/21 126/1 126/5 126/7
126/9 126/11 126/13 126/15
126/19 126/23 126/25 130/17
130/19
THE COURT: [147]
THE JUROR: [18] 61/22 124/9
124/16 124/18 124/25 125/2
125/25 126/2 126/4 126/6
126/8 126/10 126/12 126/14
126/16 126/18 126/20 126/22
THE WITNESS: [8] 24/17 31/1
33/11 33/24 34/16 37/21
39/10 40/7
$
$10,000 [1] 98/19
$105,000 [1] 18/4
$107,536.23 [2] 13/4 67/16
$110,000 [1] 95/25
$110,300 [1] 8/22
$113,750 [1] 17/25
$120,000 [1] 83/21
$120,010 [1] 83/25
$124,000 [1] 68/10
$144,970.07 [1] 14/18
$147,620 [1] 20/7
$148,450 [1] 40/25
$149,900 [1] 68/18
$15,000 [1] 38/23
$15,826.15 [1] 38/24
$159,732.52 [1] 27/10
$159,733 [3] 16/6 16/10 27/4
$165,000 [2] 30/10 84/9
$17,000 [1] 74/17
$17,190 [2] 16/22 28/16
$18 [1] 112/4
$18 million [1] 112/4
$180,000 [1] 74/18
$181,302 [2] 17/15 28/21
$211,695 [2] 40/17 82/14
$219,000 [2] 17/4 84/6
$230,000 [1] 69/21
$238,000 [1] 71/20
$238,614 [2] 7/17 69/11
$238,960 [1] 18/25
$25,550 [1] 36/20
$250,000 [1] 18/2
$283,000 [1] 20/1
$3,422 [2] 53/11 74/3
$3.52 [1] 37/4
$3.52 million [1] 37/4
$30,000 [3] 81/14 81/17 82/2
$300,000 [1] 74/17
$34,000 [1] 73/13
$34,750 [1] 36/15
$3422.00 [1] 42/13
$384,100 [1] 22/5
$400,000 [1] 88/6
$430,000 [3] 35/6 35/12
35/23
$430,620 [3] 20/9 20/10
72/20
$450,000 [4] 74/1 77/20
77/25 82/21
$451,000 [2] 80/3 80/12
$451,185 [2] 42/16 53/8
$5,000 [1] 39/1
$50,000 [8] 23/24 24/10
24/14 25/6 25/15 25/24 26/11
26/15
$60,000 [1] 86/17
$600,000 [1] 81/20
$632,000 [1] 95/16
$639,807 [3] 10/8 70/12 99/8
$640,000 [1] 37/9
$65,000 [2] 67/5 67/18
$65,990.42 [1] 42/10
$65,990.43 [1] 53/5
$74,557.79 [4] 42/6 53/2
57/3 68/5
$80,000 [4] 29/22 30/6 68/11
84/11
$82,000 [3] 18/18 36/6 72/9
$82,500 [1] 86/6
$9,000 [1] 98/22
$9,200 [1] 73/4
$91,200 [4] 36/24 86/10
86/18 89/13
'
'99 [1] 120/23
-
-and [2] 2/5 2/8
/
/s [1] 131/12
0
008 [1] 53/1
031 [1] 52/18
033 [1] 52/22
0762 [1] 22/4
1
1.19 million [1] 94/23
1.2 million [1] 37/7
1.B [1] 29/15
10 [11] 19/22 35/1 35/25
43/8 43/10 43/10 61/3 70/16
108/7 108/11 130/16
10036 [1] 2/18
1006 [2] 11/13 21/14
10100 [1] 3/15
1028 [3] 51/4 111/20 113/25
10:39 [1] 44/18
10:46 [1] 44/18
10:50 [1] 46/24
11 [3] 4/9 4/9 68/1
1114 [1] 2/17
115 [6] 6/10 6/12 7/11 8/16
10/2 37/2
11:00 a.m [1] 130/18
11:12 [1] 46/24
11:38 [1] 61/6
11:41 [1] 61/6
11:42 [1] 62/7
12 [5] 32/1 45/20 114/25
115/1 124/13
120,000 [1] 97/12
126334 [2] 43/1 53/18
12:02 [1] 62/7
12th [2] 83/22 108/13
13 [1] 119/21
1330 [1] 2/23
1343 [2] 50/15 51/5
1344 [2] 50/22 51/5
136,000 [1] 97/12
13th [3] 14/11 15/10 130/18
14 [7] 43/16 43/17 54/3 54/5
90/9 90/12 119/22
1400 [1] 2/10
14th [7] 18/4 25/14 25/20
30/8 38/14 83/12 84/11
15 [6] 68/16 70/17 81/14
81/17 82/2 119/22
16 [3] 31/21 54/2 70/17
165,000 [1] 29/2
16th [1] 128/17
17 [2] 43/8 70/17
17th [2] 18/17 83/18
18 [18] 26/14 26/14 40/22
42/24 46/11 50/14 50/21 51/3
51/4 53/15 54/12 54/22 55/4
57/14 68/1 69/17 124/13
124/18
181,000 [1] 84/6
19 [2] 70/7 121/3
1900 [1] 2/15
1935 [1] 3/12
1956 [2] 54/23 55/4
1979 [1] 43/7
1980 [1] 43/7
1982 [1] 43/8
1983 [1] 43/8
1984 [1] 43/9
1985 [1] 43/9
1986 [1] 43/10
1987 [1] 43/10
1999 [3] 112/22 120/20 121/3
19th [1] 22/11
1:00 o'clock [1] 101/14
1:01 [1] 102/2
1:45 [1] 102/2
1st [1] 1/22
2
20 [8] 42/7 42/14 43/13 44/5
45/1 53/12 68/6 69/17
20-579 [1] 1/8
200 [2] 22/19 24/1
200-205 [1] 4/11
20036 [1] 2/23
2009 [4] 40/22 40/23 40/24
82/9
201 [2] 22/19 83/17
2012 [3] 112/21 120/9 120/16
2016 [1] 106/7
2017 [1] 122/4
Case 2:20-cr-00579-SVW Document 679 Filed 07/09/21 Page 132 of 151 Page ID
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2
2019 [3] 40/20 82/8 82/11
202 [2] 22/19 83/17
2020 [24] 13/1 14/8 14/15
17/2 17/2 17/5 17/6 17/25
18/17 19/5 19/6 22/11 38/5
42/7 42/11 42/14 42/17 42/21
43/13 53/9 53/12 67/7 67/15
74/2
2021 [9] 1/17 5/1 31/4 38/14
124/8 124/21 125/7 125/11
131/10
203 [2] 22/20 39/17
204 [2] 22/20 40/21
205 [3] 4/11 22/20 38/10
20530 [1] 2/10
20th [1] 74/4
21 [2] 4/10 4/10
215 [1] 106/7
216 [1] 3/13
22 [3] 4/11 4/11 52/14
22nd [2] 17/2 17/5
23 [3] 4/6 125/4 125/9
233 [1] 106/7
2335 [1] 86/16
2395 [1] 22/2
24 [14] 15/16 15/23 17/18
20/22 21/3 36/1 39/11 52/14
74/15 74/16 86/23 88/17
124/20 124/21
24-inch [2] 43/16 54/3
2461 [2] 46/13 46/17
25 [2] 5/1 99/2
26 [9] 25/10 55/5 56/23
65/20 69/19 69/23 70/9 70/21
87/13
26331 [3] 42/24 53/16 89/13
26th [1] 108/15
27 [11] 14/20 37/12 37/16
37/17 37/22 38/1 74/15 74/16
86/22 87/8 88/17
28 [7] 1/17 31/24 46/12
124/8 125/6 125/11 131/4
28th [2] 14/15 124/21
29 [6] 128/15 129/1 129/18
129/24 130/4 130/7
2:26 [1] 122/12
2nd [2] 42/11 67/7
3
30 [7] 25/19 72/3 72/3 91/6
91/6 101/18 123/10
300 [1] 3/16
31 [3] 13/1 26/1 67/15
312 [1] 2/6
3143 [1] 111/6
32A [1] 96/10
32B [1] 96/10
33 [1] 128/15
331 [1] 106/9
34,000 [1] 98/22
34,750 [1] 86/18
350 [2] 1/22 3/5
3656 [1] 20/3
39 [3] 91/14 125/5 125/9
3900 [1] 2/20
3rd [1] 18/17
4
40 [2] 101/18 102/1
401 [17] 4/9 11/6 11/12
11/17 12/5 13/20 15/4 15/20
16/14 16/24 17/20 18/12 19/2
19/23 25/5 82/24 84/4
402 [4] 4/10 21/7 21/13
21/23
409 [1] 3/20
42 [1] 24/2
43 [1] 24/7
430 [2] 35/24 36/2
4311 [1] 1/22
44 [1] 4/13
451,000 [1] 125/17
4910 [1] 38/17
4:30 [1] 122/12
4:33 [1] 123/19
4th [5] 18/2 18/4 23/24
26/11 31/3
4U95Z313 [2] 43/1 53/18
5
50,000 [1] 24/8
50-page [1] 59/14
50-yard [2] 79/15 88/13
500-plus [1] 85/7
535,000 [1] 37/10
55 [3] 24/22 125/5 125/10
579 [1] 1/8
5:03 [1] 123/19
5th [9] 2/14 3/8 14/8 17/2
17/6 24/9 42/17 42/21 74/2
6
60 [5] 29/15 71/11 71/13
76/16 91/7
600 [2] 104/17 104/18
601 [1] 3/8
63 [1] 25/9
633 [1] 2/14
639,000 [1] 99/19
651 [1] 3/21
694-331-008 [1] 53/1
7
70 [4] 4/11 4/13 22/19 44/14
715 [1] 106/9
720 [1] 3/8
7303 [1] 17/23
75 [1] 91/9
753 [1] 131/4
7695 [9] 14/4 14/10 14/11
14/13 15/8 42/8 53/3 68/6
68/12
77 [4] 4/13 44/15 59/11
60/10
8
80 percent [1] 112/5
80,000 [3] 30/4 30/10 84/12
8054 [1] 16/5
82,000 [8] 35/13 35/14 36/4
36/24 86/7 86/21 88/9 88/20
85,000 [2] 30/10 84/14
87 [2] 81/15 81/25
8th [1] 53/9
9
9,000 [2] 86/9 89/1
9,200 [2] 36/17 36/24
90012 [2] 1/23 2/7
90067 [1] 3/16
90071 [2] 2/15 3/9
90277 [1] 3/21
903 [1] 3/5
9066 [1] 18/3
91,200 [1] 86/11
91208 [1] 3/13
9200 [1] 89/1
92673 [1] 3/6
94105 [1] 2/21
9700 [6] 12/14 12/25 42/12
53/6 67/6 67/13
981 [1] 54/13
982 [1] 57/15
984 [1] 46/11
9858 [2] 1/21 131/12
9906 [1] 18/1
9:32 [1] 5/2
A
a.m [5] 5/2 44/18 46/24 61/6
130/18
A.M. [1] 1/16
A.M./P.M [1] 1/16
abandon [1] 76/25
ABC [4] 27/23 28/3 28/4
83/22
able [7] 20/20 20/23 20/24
80/8 95/12 111/25 122/21
abnormal [1] 80/20
about [77]
above [8] 41/24 54/8 54/16
56/1 57/7 57/11 57/18 131/7
above-entitled [1] 131/7
absence [1] 105/18
absolutely [4] 21/4 92/25
115/23 117/3
abstract [1] 88/23
acceptance [1] 117/4
accepted [2] 116/21 117/13
access [2] 112/2 114/11
accessories [1] 115/1
accidentally [1] 44/14
according [4] 40/18 49/17
80/23 94/7
account [72]
accountings [1] 81/4
accounts [41] 10/15 11/23
12/6 13/21 13/25 15/16 15/23
16/20 17/5 17/16 20/22 21/3
28/10 36/2 39/11 46/8 66/20
66/25 70/25 74/15 74/16 77/8
79/21 79/23 80/25 81/5 86/23
87/19 87/25 88/17 88/24
91/16 91/17 96/20 97/15
97/25 98/8 99/24 111/23
114/6 116/23
accurately [1] 98/1
acknowledges [1] 115/13
acquire [1] 56/8
acquitted [1] 87/10
actively [1] 129/4
activity [3] 34/18 55/14
84/5
acts [5] 69/22 70/4 70/10
70/22 83/24
actual [4] 83/5 89/25 96/6
96/8
actually [21] 17/20 23/13
27/25 28/8 28/12 31/8 41/21
62/20 66/1 66/12 72/2 76/21
81/3 81/10 86/9 86/25 87/2
91/11 104/16 108/14 113/13
add [1] 89/13
adding [2] 88/5 119/20
addition [4] 68/17 76/20
113/10 114/15
additional [9] 11/2 14/10
21/20 35/15 44/4 73/4 86/7
114/15 116/19
address [6] 63/18 69/3 71/10
73/24 91/8 91/10
addressed [2] 38/16 83/4
adds [1] 86/18
adjust [2] 42/25 53/17
administrators [1] 34/5
admission [1] 41/19
admit [4] 11/12 21/12 22/19
95/4
admitted [2] 6/10 44/12
advise [1] 127/15
Advisors [2] 27/23 83/22
affected [1] 78/19
affirmatively [4] 85/11
99/23 104/25 105/1
Case 2:20-cr-00579-SVW Document 679 Filed 07/09/21 Page 133 of 151 Page ID
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A
after [15] 15/24 23/16 27/13
33/17 33/21 34/1 61/19 75/25
76/1 83/13 84/10 113/14
128/16 129/25 130/12
afternoon [3] 62/12 78/17
121/11
again [21] 5/10 46/1 56/17
69/11 69/24 70/7 70/19 70/22
75/11 75/11 75/18 75/18 84/8
85/13 89/11 91/3 95/17 99/8
114/21 117/13 128/1
against [1] 117/1
age [2] 116/13 119/21
ages [2] 116/9 116/15
aggravated [3] 64/13 111/19
114/1
ago [3] 61/11 112/19 123/10
agree [5] 41/14 41/21 45/10
122/17 123/6
agreed [4] 40/5 41/8 44/16
79/18
agreement [2] 87/13 88/23
ahead [4] 31/16 40/7 41/9
113/22
AHN [1] 2/5
Airport [7] 42/16 43/14
53/13 73/7 73/11 74/6 77/14
al [1] 1/9
all [81]
allegation [3] 81/7 88/22
121/1
allegations [3] 42/3 45/23
49/18
alleged [9] 46/15 46/19
69/17 69/22 82/12 85/23
85/23 113/3 121/14
allegedly [1] 41/12
allow [1] 60/2
allowed [2] 119/18 121/17
allowing [1] 60/7
Allstate [15] 10/13 13/22
13/25 14/3 14/7 14/13 14/17
15/13 42/9 53/4 67/1 68/6
68/10 68/12 96/2
alluded [1] 120/21
Almader [1] 126/16
almoney [1] 98/17
almost [3] 38/7 59/14 82/24
alone [1] 94/2
along [2] 23/1 84/3
Alpha [1] 3/12
already [10] 25/9 27/8 38/11
65/3 76/15 76/16 88/3 103/24
107/18 108/22
also [38] 20/5 21/3 29/21
34/7 45/22 56/2 56/20 67/15
68/4 69/18 69/25 71/2 71/21
71/25 72/13 72/22 73/2 76/14
77/10 77/13 80/13 80/19 81/9
81/19 82/8 84/15 102/13
102/18 107/25 112/2 112/7
114/3 114/4 114/8 115/1
116/23 117/13 123/12
altogether [1] 130/7
Always [1] 127/18
am [37] 12/4 13/16 20/11
26/24 29/8 33/12 36/6 37/23
57/7 59/6 60/2 60/7 63/10
63/13 64/15 66/24 102/15
104/12 106/13 107/17 107/18
107/20 108/4 108/7 108/8
108/11 109/1 109/22 110/3
110/18 121/19 121/21 122/2
123/14 124/2 124/4 130/14
Amanecer [1] 3/5
ambiguated [1] 96/20
America [20] 1/6 2/3 9/4 9/5
12/13 12/24 14/4 14/9 14/13
15/8 22/4 27/9 42/8 42/12
53/3 53/6 67/5 68/5 68/12
83/18
Americas [1] 2/17
ammunition [1] 115/1
among [1] 70/10
amount [18] 15/15 16/6 16/19
17/12 17/25 18/17 18/24
36/15 36/22 38/25 40/16
84/13 86/8 99/15 99/19 112/5
123/2 123/3
amounts [3] 50/3 65/10 76/23
ample [2] 71/16 74/20
analysis [3] 12/2 29/9 78/25
analyze [1] 39/6
Anastasia [7] 8/9 8/17 8/21
8/24 9/15 69/24 70/3
and/or [1] 107/23
anew [1] 61/17
ANGELES [7] 1/14 1/23 2/7
2/15 3/9 3/16 5/1
ankle [1] 119/17
Anna [7] 23/21 24/5 24/10
24/13 24/25 83/9 83/10
another [8] 13/11 27/13
68/18 68/19 80/11 90/19
93/20 93/20
answer [14] 33/8 33/10 33/15
33/23 34/15 39/9 88/8 107/11
122/15 123/16 124/18 124/24
125/2 125/23
answered [6] 124/7 124/12
124/13 124/13 125/10 125/19
answers [3] 124/4 124/22
125/6
anticipate [1] 102/9
any [100]
anyone [10] 78/19 80/18
85/10 90/22 120/11 120/14
121/22 122/1 125/13 127/24
anything [5] 43/20 66/8
86/24 94/2 100/18
anywhere [1] 81/13
AP [2] 86/15 89/13
apologies [1] 61/1
apologize [4] 25/18 30/2
59/8 61/10
apparent [2] 15/3 110/17
appear [1] 38/15
APPEARANCES [2] 2/1 3/1
appeared [2] 14/24 68/19
appears [4] 25/4 28/9 56/23
124/15
applicability [1] 45/7
applicable [2] 46/14 48/14
application [1] 41/11
applied [1] 87/21
applies [3] 45/21 65/18
102/19
apply [10] 45/8 46/10 46/11
46/18 47/3 47/14 48/16 59/12
94/2 97/1
approximately [4] 36/20
69/21 86/5 86/9
April [3] 17/2 17/5 19/5
April 22nd [2] 17/2 17/5
are [135]
areas [2] 42/18 53/9
arguably [1] 96/19
argue [5] 89/4 94/24 97/9
106/17 109/7
argued [3] 94/14 98/24
129/13
arguing [1] 105/17
argument [20] 45/11 58/16
59/10 59/24 60/3 60/8 79/23
87/25 89/8 97/17 101/10
101/17 102/23 105/21 107/1
108/17 108/18 109/23 118/12
120/5
arguments [11] 45/6 59/4
60/14 61/12 61/19 101/6
102/1 102/18 105/1 118/7
128/25
Arman [15] 24/25 26/2 26/5
26/16 28/25 31/5 31/17 32/13
59/24 83/1 83/8 84/8 84/11
84/15 118/14
armed [1] 115/2
Armenia [1] 118/19
army [1] 108/21
around [5] 29/6 74/21 77/20
108/10 124/14
arrest [1] 82/2
arrested [3] 73/5 73/8
113/14
ARTUR [13] 3/11 96/24 96/25
111/5 113/20 113/23 114/24
116/12 116/20 116/22 121/7
121/11 124/12
as [162]
Ashwin [1] 2/13
aside [3] 96/14 104/19
107/24
ask [13] 6/5 21/19 23/8 40/6
44/4 58/15 63/6 77/3 77/23
78/2 100/20 103/15 115/18
asked [14] 32/23 33/9 35/18
40/3 49/25 57/24 62/14 62/16
64/10 66/16 88/16 101/11
105/12 110/2
asking [2] 103/2 115/22
aspect [1] 5/11
assessor's [3] 52/17 52/21
53/1
asset [3] 57/2 98/24 100/22
assets [6] 66/24 69/3 73/24
78/3 78/11 100/14
assist [1] 128/1
associated [1] 22/5
ATM [4] 24/10 25/14 25/22
80/16
attempt [11] 7/7 8/12 9/22
11/22 12/5 13/20 15/15 17/8
18/7 19/19 21/19
attention [2] 5/10 21/22
attentive [1] 127/6
attorney [3] 44/23 112/8
114/14
ATTORNEY'S [2] 2/4 108/25
Audemars [10] 42/23 43/1
43/3 43/5 53/14 53/19 53/21
53/23 72/24 73/1
August [5] 13/1 19/6 67/15
82/1 128/17
August 16th [1] 128/17
August 31 [2] 13/1 67/15
AUSA [3] 2/5 2/5 44/10
Auto [3] 9/3 10/14 97/3
available [1] 112/6
Avenue [3] 2/10 2/17 2/23
avoid [1] 63/13
awaits [1] 113/18
aware [4] 109/24 110/3 110/4
121/19
away [3] 59/2 63/19 100/8
Ayvazian [19] 32/9 33/3
85/12 87/10 96/24 97/1 111/6
113/20 113/23 116/20 116/22
118/9 119/14 119/15 119/20
120/24 121/8 121/12 124/12
Ayvazian's [2] 114/24 116/12
Ayvazyan [39] 1/9 2/12 3/11
32/3 32/14 38/16 39/7 42/15
43/13 53/12 60/1 72/13 73/7
73/12 74/4 79/22 79/25 81/6
81/9 81/16 82/10 82/13 82/19
Case 2:20-cr-00579-SVW Document 679 Filed 07/09/21 Page 134 of 151 Page ID
#:11032
A
Ayvazyan... [16] 91/19 94/8
102/18 102/23 104/24 111/5
111/8 111/12 113/17 114/23
117/9 118/23 118/25 120/8
124/23 124/25
Ayvazyan's [7] 45/14 77/11
80/3 81/3 94/10 96/4 116/11
B
B-E-N-S-O-N [2] 106/5 106/6
B-I-T-T-A-K-E-R [1] 106/8
back [31] 13/5 13/17 25/5
26/9 27/3 27/19 27/20 30/9
35/9 35/24 37/14 40/22 46/22
46/23 59/1 59/1 59/6 59/15
60/22 60/24 61/14 62/3 62/5
72/1 76/21 91/13 94/4 101/16
104/11 113/15 129/10
backlog [1] 108/3
backyard [4] 42/18 53/9 74/2
76/23
bailiff [4] 58/8 58/10 58/12
60/24
balance [3] 11/22 13/2 14/16
bank [106]
banking [2] 77/14 77/19
banks [3] 77/17 78/19 113/9
base [2] 47/12 49/9
based [23] 6/21 7/12 8/1
8/16 9/10 10/2 10/19 16/9
17/12 18/19 22/7 22/13 36/23
57/25 64/13 66/12 78/25
86/15 87/15 105/18 107/3
117/14 129/1
bases [2] 50/9 107/24
basis [5] 52/4 52/10 92/1
92/7 111/7
be [101]
Beach [1] 3/21
bear [2] 86/23 127/18
because [32] 52/4 56/12 57/7
61/16 62/21 63/9 65/3 65/15
65/25 67/21 70/21 77/7 80/22
82/8 82/16 83/23 87/20 92/2
92/23 94/18 94/25 98/5 100/2
109/2 109/14 111/25 118/9
118/12 118/23 125/16 129/8
130/7
been [28] 14/25 16/17 20/22
21/6 36/2 38/6 38/9 47/25
49/4 54/19 55/19 57/19 57/22
62/14 63/9 64/18 64/23 65/4
82/10 103/25 104/17 105/19
112/7 114/13 119/9 121/16
121/18 129/12
before [20] 22/18 58/14 68/2
73/5 73/10 79/18 81/10 81/19
81/24 82/8 82/12 82/16 85/22
89/10 89/18 91/20 100/7
110/1 118/18 123/6
begin [3] 45/25 61/17 61/22
beginning [1] 22/18
behalf [7] 2/3 45/13 101/8
102/7 102/18 103/17 121/7
behind [1] 31/25
being [14] 40/1 40/2 40/3
40/5 41/17 64/10 83/2 86/24
87/20 87/21 91/16 120/21
122/1 127/21
Belgium [1] 75/22
believe [15] 23/10 29/18
34/17 35/18 37/6 59/19 60/15
60/18 94/6 115/25 116/17
117/1 117/15 119/23 120/2
believes [2] 104/23 111/13
Bellagio [1] 82/15
belongings [1] 101/24
benefit [2] 15/12 93/22
Benson [2] 106/4 107/7
best [10] 6/7 63/13 90/17
96/13 96/13 96/18 97/9 97/13
99/18 129/11
better [1] 102/22
between [16] 17/1 17/5 18/4
18/17 19/5 47/18 49/3 57/3
62/24 63/16 66/18 85/25
116/20 118/19 122/25 129/5
Beverly [2] 7/23 69/13
beyond [9] 48/19 62/19 63/19
63/24 64/3 67/9 70/17 74/10
78/13
bias [1] 47/13
Bienert [2] 3/4 3/7
big [8] 63/16 100/13 109/22
110/8 118/7 118/21 118/25
120/24
biggest [1] 110/11
bill [8] 41/11 41/14 41/15
41/16 41/20 42/1 71/14 90/8
bit [4] 62/15 62/21 65/20
105/4
Bittaker [2] 106/8 107/8
black [6] 43/2 43/4 53/20
53/22 65/8 65/10
blow [1] 31/25
boil [1] 98/8
boils [1] 79/2
bonds [1] 119/2
borrowing [2] 111/24 114/10
both [16] 63/21 65/5 66/2
67/2 67/7 67/13 68/6 74/11
78/9 83/5 100/16 105/22
106/19 111/14 115/14 116/2
bottom [7] 17/21 18/21 20/4
22/9 26/18 28/20 40/16
bought [4] 76/12 76/14 89/18
89/20
Boulevard [1] 3/15
box [4] 20/1 20/4 20/14
99/10
boxes [1] 20/7
boy [1] 29/15
Boyle [5] 4/5 5/20 44/11
62/2 123/11
bracelet [1] 119/18
bracket [1] 124/15
break [2] 79/16 101/22
brief [6] 31/20 60/14 60/16
101/25 102/15 107/15
briefed [4] 108/16 108/17
110/17 128/16
briefing [2] 117/18 117/22
briefly [20] 6/24 7/18 8/23
10/9 12/15 13/8 14/5 15/20
16/1 16/14 16/24 17/21 19/2
19/23 45/3 60/5 61/14 101/8
104/14 117/17
bring [7] 24/1 32/22 35/25
38/10 39/16 40/21 60/24
broader [1] 100/19
brother [1] 118/23
brothers [2] 116/1 116/2
Brown [1] 126/2
bucket [1] 105/14
bulk [1] 76/9
bullion [9] 43/7 43/8 43/8
43/9 43/9 43/10 43/10 43/11
54/2
burden [16] 48/19 49/6 64/3
77/22 79/10 85/13 85/19
86/24 88/18 90/25 93/6 99/8
99/21 101/4 107/20 111/10
business [5] 22/3 22/11
36/14 48/5 77/10
buy [4] 51/18 80/25 92/18
92/21
buying [1] 71/20
C
CA [9] 1/23 2/7 2/15 2/21
3/6 3/9 3/13 3/16 3/21
Caicos [7] 73/11 86/8 86/17
89/1 98/21 99/1 120/4
calculate [1] 15/15
CALIFORNIA [12] 1/2 1/14 5/1
42/19 42/22 52/17 52/21
52/25 53/10 112/8 112/23
114/14
call [5] 90/20 93/14 93/14
100/24 125/23
Calle [6] 3/5 7/4 8/6 69/7
69/14 94/8
called [6] 34/9 61/14 79/4
82/3 83/15 98/17
Calloway [1] 126/20
Calls [3] 24/15 37/19 39/14
came [14] 37/9 37/10 37/12
37/14 68/14 75/15 81/3 81/21
88/8 93/10 95/9 95/25 96/2
123/6
can [93]
can't [10] 28/18 33/13 60/17
60/23 89/18 89/19 89/21 95/5
104/15 108/5
cannot [1] 82/15
capturing [1] 34/11
car [1] 51/18
carat [1] 43/17
card [4] 73/6 73/12 73/17
77/12
cards [2] 77/15 105/13
care [1] 81/7
Caribbean [1] 112/13
Carribean [2] 22/14 73/13
case [74]
cases [9] 20/24 106/4 107/5
107/11 107/13 107/14 108/3
109/4 110/12
cash [73]
cashed [1] 23/16
cashier's [22] 15/22 15/24
16/4 16/10 23/14 23/15 23/21
24/14 24/19 24/23 24/24 25/2
25/6 26/2 26/5 26/10 26/15
27/15 27/21 28/1 28/7 74/17
casino [7] 34/2 34/17 34/18
34/23 82/7 82/14 82/14
casinos [8] 34/5 34/5 34/6
34/10 34/12 82/10 82/18
82/20
Castegar [18] 104/25 105/22
106/16 106/23 107/1 107/24
110/1 110/12 128/7 128/11
128/16 128/21 128/23 129/1
129/2 129/4 129/5 129/25
catastrophe [1] 113/10
categories [3] 79/17 79/19
105/7
category [4] 91/16 91/20
94/5 118/17
CATHERINE [1] 2/5
cause [1] 45/22
CBP [2] 105/11 105/12
CC'd [1] 123/11
CENTRAL [1] 1/2
cents [1] 57/3
Ceramic [4] 43/2 43/4 53/20
53/22
certain [8] 11/23 41/12
52/16 52/20 52/24 62/17
63/24 105/12
certainly [5] 69/5 77/9
84/20 122/2 130/10
CERTIFICATE [1] 131/1
certify [1] 131/4
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chain [3] 17/22 43/16 54/4
chance [4] 61/11 61/15
113/20 122/6
change [4] 30/22 31/3 51/14
65/2
changed [1] 93/5
charge [2] 95/10 112/23
charged [7] 64/14 68/15
69/15 72/17 85/3 96/14 98/16
charges [7] 64/11 65/13
68/25 70/18 79/9 114/15
119/12
chart [21] 11/18 15/4 15/20
16/3 16/15 16/25 18/13 18/14
18/21 19/3 19/19 21/1 22/10
27/16 29/11 29/17 34/20
67/21 72/19 82/24 86/5
charts [4] 6/20 6/25 11/2
65/5
Chase [3] 24/4 25/11 26/7
check [25] 16/4 16/10 23/21
24/10 24/14 24/19 24/20
24/23 24/24 25/2 25/6 25/15
26/2 26/5 26/10 26/15 26/19
27/4 27/15 27/21 28/1 51/17
83/9 83/13 83/25
checkbooks [1] 114/8
checking [1] 99/9
checks [13] 15/22 15/24
16/16 16/21 23/14 23/15 28/7
28/12 72/2 74/17 74/18 114/7
114/9
children [6] 100/5 115/15
116/8 116/8 116/11 117/24
Chiraag [2] 22/10 36/14
choose [1] 127/15
Christopher [1] 2/9
circle [2] 124/14 124/24
circled [3] 22/9 125/1
125/18
Circuit [4] 45/9 60/6 106/10
106/11
citation [3] 46/12 106/6
106/9
cite [1] 106/3
cited [3] 84/4 107/14 120/3
civil [1] 46/18
claim [5] 48/7 49/7 49/8
64/8 94/8
claims [3] 48/4 104/25
105/24
clarification [1] 125/16
clarify [2] 17/16 44/12
clean [6] 66/7 82/19 89/21
94/15 94/23 97/18
clear [4] 45/2 63/5 78/17
111/11
clearly [1] 121/14
Clemente [1] 3/6
close [7] 80/15 93/14 93/14
100/24 123/5 130/5 130/8
closing [1] 60/14
Cloud [1] 20/6
club [2] 92/22 92/23
Coast [1] 3/20
Code [9] 50/15 50/21 51/3
51/5 54/12 54/22 55/5 57/15
131/5
coin [8] 43/7 92/17 92/18
92/21 93/2 93/7 94/1 94/1
coins [30] 43/8 43/8 43/9
43/9 43/10 43/10 43/11 54/2
66/21 71/11 71/13 71/16 72/3
72/3 73/20 76/16 79/21 85/17
85/18 85/20 85/22 91/5 91/6
91/7 91/7 91/9 91/10 91/11
93/9 93/11
COLabs [3] 81/12 81/13 82/3
Collision [2] 10/14 97/3
column [2] 29/12 34/2
come [5] 46/22 60/22 78/4
95/15 101/16
comes [4] 28/25 84/7 86/20
101/1
coming [4] 94/4 96/12 97/25
101/25
commend [1] 127/9
commissions [1] 55/10
commit [8] 54/23 55/23 66/6
71/9 75/10 87/14 96/16 109/7
committed [1] 55/15
committing [2] 78/1 97/4
common [5] 76/22 76/25 77/2
77/20 78/8
community [5] 111/13 112/14
114/20 119/25 120/7
Community.com [1] 81/23
companies [1] 81/7
company [9] 15/13 20/6 77/11
77/12 81/14 95/21 96/4 97/7
121/25
compelled [2] 105/2 105/9
compelling [2] 108/17 117/8
complete [6] 44/2 58/6
106/15 106/18 119/10 127/3
completely [1] 89/20
compliance [2] 119/10 121/17
component [1] 48/24
conceal [1] 71/8
concealed [2] 87/20 96/5
concealment [19] 95/10 96/7
96/7 96/12 96/25 97/4 97/5
97/8 97/10 97/21 97/22 97/23
98/2 98/4 98/23 99/5 99/19
100/7 100/9
concept [1] 13/9
concerned [1] 50/2
concerning [5] 47/5 47/8
51/4 58/21 63/18
concerns [1] 45/6
conclude [4] 54/14 57/16
75/2 77/17
concluded [3] 82/13 96/22
130/21
concludes [2] 43/19 128/4
concluding [1] 103/10
conclusion [1] 129/5
conclusive [1] 41/23
conduct [6] 55/14 67/25
69/10 70/8 70/20 88/20
conducted [1] 12/1
conducting [1] 77/9
Conference [1] 131/9
conferred [1] 122/16
confidence [1] 127/21
confidentiality [1] 127/13
conformance [1] 131/8
confusion [3] 45/22 59/16
63/13
conjunction [1] 34/20
connect [1] 20/25
connected [12] 67/20 74/9
74/25 78/11 81/5 83/2 84/16
85/7 87/3 88/6 90/1 123/3
Connecticut [1] 2/23
connecting [2] 72/7 81/18
connection [16] 47/18 49/3
62/23 63/1 63/4 64/10 64/17
64/22 65/22 66/10 66/18
85/25 93/16 120/18 122/24
123/1
connections [2] 86/3 118/15
consider [12] 45/12 47/21
48/24 49/13 50/1 63/2 64/10
66/16 76/8 77/18 108/16
117/7
consideration [4] 47/9 48/10
61/13 117/7
considered [4] 13/11 50/11
51/19 105/25
considering [1] 21/3
consistent [1] 115/24
consisting [2] 42/23 43/15
Consolidated [1] 40/10
conspiracy [28] 54/23 64/14
65/13 67/10 68/1 68/16 68/22
68/24 69/16 69/19 70/4 70/16
70/23 71/24 72/4 72/15 74/13
74/21 76/7 76/12 79/9 87/13
88/11 89/5 89/8 93/17 95/5
96/16
conspirator's [1] 73/16
conspirators [1] 76/4
conspiring [1] 76/4
constitute [1] 41/19
constituted [2] 55/7 55/18
constitutes [3] 41/23 54/8
54/16
constituting [3] 50/17 50/24
51/8
constitutional [1] 116/24
Construction [2] 17/25 18/3
consult [1] 44/3
Cont'd [1] 3/1
contact [1] 127/25
contends [3] 54/7 57/6 57/10
contention [3] 107/21 110/15
120/14
contents [1] 97/16
contested [1] 91/16
contesting [1] 87/23
context [1] 105/5
continue [3] 47/14 48/16
62/14
Contracting [1] 22/4
conveniently [1] 82/7
conversation [1] 85/1
convert [1] 76/5
converted [1] 51/17
converting [3] 75/12 75/19
85/1
convicted [26] 50/13 50/20
51/2 52/15 52/19 54/21 63/23
64/12 65/12 66/18 67/24
68/21 69/1 69/17 70/5 70/6
70/17 71/23 74/10 76/6 78/1
78/5 78/12 78/20 113/8
114/22
conviction [36] 65/20 66/14
67/9 67/20 69/2 69/9 70/9
72/7 73/23 74/13 78/25 86/1
86/1 87/1 88/14 89/23 93/3
93/8 93/24 94/19 95/6 96/15
100/15 112/16 112/19 112/22
112/24 112/25 120/9 120/10
120/17 120/24 121/2 121/3
122/25 123/3
convictions [12] 64/16 64/23
65/19 65/21 66/13 68/3 68/7
68/8 70/21 71/17 74/12
114/17
convinced [2] 103/5 103/11
convinces [1] 100/23
convincing [1] 111/11
cookie [1] 121/2
copies [1] 22/20
copy [7] 24/19 24/24 26/2
26/15 27/15 57/9 104/1
corner [5] 26/18 28/20 38/13
38/21 40/16
correct [63] 13/16 13/18
14/19 14/21 15/2 16/12 17/3
17/7 20/11 20/13 21/1 23/24
23/25 25/7 25/8 26/7 26/8
26/11 26/12 26/21 27/1 27/4
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correct... [41] 27/23 28/12
28/13 28/22 28/23 29/3 29/13
29/17 29/22 30/11 30/16 31/6
31/18 32/19 33/22 34/13 35/4
35/8 36/5 36/11 36/16 36/18
36/25 37/4 37/11 37/15 39/13
40/25 44/14 56/25 57/1 58/10
114/18 114/19 115/7 117/11
122/14 124/8 124/16 130/17
131/5
corrected [1] 4/13
costs [1] 92/22
could [25] 23/9 24/1 24/22
25/5 33/1 33/8 34/17 35/25
36/1 36/7 36/13 37/2 38/10
38/12 38/19 84/5 89/4 94/23
95/1 97/21 103/1 105/20
117/23 123/13 130/6
couldn't [1] 129/22
counsel [7] 2/1 5/9 6/11
44/11 113/20 116/14 118/10
counsel's [1] 31/15
count [28] 55/5 56/23 64/14
65/20 67/25 68/1 68/16 69/16
69/16 69/17 69/19 69/23 70/4
70/7 70/9 70/15 70/21 71/23
72/17 87/8 87/9 87/12 87/13
88/14 89/23 96/15 122/25
123/3
counted [1] 104/16
counting [2] 50/3 50/11
country [1] 122/4
counts [15] 52/14 66/18
67/20 68/1 68/16 69/2 70/16
72/7 73/23 86/1 87/10 98/10
100/15 100/17 111/20
couple [3] 18/1 44/22 92/9
course [5] 11/21 14/22 18/6
61/12 93/19
court [37] 1/1 1/21 44/9
47/25 48/1 48/8 50/11 59/9
60/16 62/21 63/15 64/2 64/7
64/18 65/19 65/21 65/25 66/9
72/11 72/23 75/6 78/21 91/22
108/15 109/11 109/16 109/24
109/25 110/6 110/9 110/24
113/19 120/15 120/21 121/24
128/23 129/19
court's [9] 63/7 63/8 63/16
64/21 66/11 71/4 74/23 78/6
78/7
courthouse [1] 77/1
courtroom [1] 127/25
CR [1] 1/8
CRB [1] 17/23
create [1] 49/20
created [1] 21/1
creating [1] 114/3
credibility [2] 47/10 49/16
credit [3] 77/15 88/15
105/13
crime [7] 51/15 56/6 66/1
66/2 85/18 93/3 93/8
crimes [10] 49/3 62/18 74/10
78/1 78/12 78/19 86/1 87/1
113/7 114/21
criminal [13] 42/4 46/14
46/18 75/5 75/12 75/19 78/4
88/20 89/10 90/21 112/3
114/11 115/6
critical [1] 100/20
criticism [1] 121/19
cross [5] 4/6 23/4 68/14
68/15 83/4
cross-examination [3] 4/6
23/4 83/4
CRR [1] 131/12
Cruz [6] 5/17 6/12 11/4 21/5
123/9 124/1
CSR [2] 1/21 131/12
currency [9] 20/6 42/14
42/16 45/24 45/24 53/8 53/11
79/20 80/1
current [2] 38/22 38/24
currently [1] 119/6
custodial [3] 105/10 115/18
115/23
custody [5] 105/11 111/5
113/15 113/17 115/15
D
DADYAN [17] 3/18 27/23 28/3
83/21 87/8 96/15 97/6 97/13
103/18 103/18 115/11 115/11
115/16 116/20 116/21 117/9
124/6
Dan [1] 44/11
danger [6] 111/12 112/14
114/20 120/6 120/11 120/14
data [1] 19/20
date [21] 12/23 13/3 14/12
14/17 25/20 38/12 42/25
43/15 53/17 53/25 58/4 78/22
108/12 108/13 129/16 129/25
129/25 130/16 130/16 130/19
131/10
dated [3] 24/24 124/8 124/21
day [8] 1/15 43/15 53/25
73/5 73/10 100/13 101/3
106/21
days [5] 18/1 83/13 108/7
108/11 108/25
DC [2] 2/10 2/23
deal [1] 110/10
deals [1] 45/23
debate [1] 93/19
decades [1] 113/6
December [2] 42/11 67/7
December 2nd [1] 67/7
decide [11] 44/6 47/25 57/24
77/25 90/14 90/14 91/3 103/5
103/23 104/3 127/18
decided [1] 78/21
decides [2] 89/9 89/10
decision [3] 49/10 58/1
101/18
declared [1] 47/24
deem [2] 79/6 100/18
deemed [1] 58/16
defendant [21] 1/9 2/12 3/3
3/11 3/18 31/5 31/17 41/19
44/23 48/7 50/13 50/20 51/2
54/21 55/19 57/19 59/13
102/13 102/13 107/10 125/8
defendant's [7] 45/5 47/7
50/16 50/23 51/6 63/21 71/18
defendants [58] 45/12 47/20
48/5 48/6 48/10 48/25 49/4
49/21 54/10 54/17 54/19
57/12 62/16 62/25 63/24
64/12 65/12 66/19 67/9 67/24
68/17 68/21 69/18 69/23 70/5
70/6 70/17 71/19 71/23 73/5
73/22 74/9 74/22 75/3 75/12
75/19 76/18 77/7 77/13 77/17
77/18 78/5 78/12 78/20 80/14
80/24 84/16 84/18 101/5
104/24 105/10 105/12 105/22
109/24 111/5 111/10 118/13
118/22
defendants' [5] 48/12 52/15
52/19 52/23 54/24
defense [23] 22/19 24/1 25/9
38/10 39/16 40/21 43/24
44/11 44/14 44/15 52/5 59/4
59/11 78/15 83/5 83/17 85/14
88/19 92/2 107/21 108/10
109/6 116/14
defense's [3] 101/16 110/15
122/14
deference [1] 103/3
defers [1] 129/19
define [1] 48/21
defined [3] 64/18 65/21
66/10
definitely [1] 122/8
definition [1] 65/17
defraud [2] 51/11 51/22
defrauding [1] 113/9
deliberate [5] 47/11 58/13
58/15 61/11 63/2
deliberating [2] 47/5 58/20
deliberations [6] 48/17
61/16 61/17 61/22 64/11
87/15
delivering [1] 33/3
demonstrate [1] 111/11
demonstrated [4] 111/16
112/11 114/2 114/4
denied [1] 49/21
deny [1] 130/15
department [4] 2/4 2/9
108/24 119/5
dependent [1] 128/20
deposit [12] 24/10 25/15
25/22 26/21 27/1 27/9 29/14
29/22 29/24 30/4 80/6 83/9
deposited [15] 20/2 24/14
24/20 25/3 26/6 28/4 28/9
30/6 80/10 83/11 83/12 83/15
83/18 83/21 83/25
deposits [3] 29/6 29/12
84/11
depth [2] 104/15 106/1
deputy [1] 127/25
derived [9] 50/17 50/24 51/8
51/20 51/23 54/8 54/16 56/4
93/23
describe [11] 7/18 8/23 10/9
12/15 13/8 14/5 19/2 19/23
49/23 58/22 79/3
described [8] 41/16 54/8
56/1 56/23 56/25 57/7 57/11
57/24
description [5] 15/11 90/8
90/19 90/23 93/13
descriptions [1] 90/3
Desert [1] 52/25
deserving [1] 129/23
designated [1] 81/14
detail [6] 7/6 8/11 58/23
103/15 105/4 107/16
detailed [3] 95/22 104/13
110/20
details [1] 121/1
detained [1] 116/2
detect [5] 55/24 66/6 71/9
75/10 97/20
detection [1] 112/1
detention [5] 111/1 118/11
118/23 118/24 119/7
determination [2] 47/7 49/12
determine [11] 11/22 17/8
47/17 48/2 48/11 49/1 62/16
62/22 68/23 74/8 123/3
determining [1] 47/22
diamond [5] 43/17 54/6 75/21
90/9 90/13
Diamonds [1] 10/14
Diaz [1] 126/2
did [65] 5/23 7/7 7/9 7/23
7/25 8/12 9/7 9/9 9/22 10/16
10/18 11/22 12/5 12/9 12/11
13/20 13/24 14/23 15/6 15/15
16/19 17/8 18/7 19/7 19/9
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did... [40] 19/10 19/12
19/14 19/15 19/16 21/18
22/13 28/14 29/4 29/6 33/2
33/9 34/19 34/20 34/22 37/14
39/10 46/16 59/3 61/17 61/21
79/17 79/18 80/5 80/10 81/16
82/22 83/6 84/25 89/24 91/8
91/12 102/22 103/12 109/17
115/11 115/12 126/24 128/5
128/6
didn't [18] 20/24 37/12
37/25 39/6 45/2 61/11 77/7
77/7 79/17 80/19 83/7 90/20
90/24 91/1 91/10 93/12
102/21 127/7
difference [3] 99/4 100/12
116/23
differences [2] 63/16 63/19
different [12] 20/6 65/20
79/16 81/5 85/6 98/7 98/8
98/16 105/7 114/7 117/13
118/17
difficult [1] 129/9
direct [3] 4/5 5/19 64/24
directing [1] 107/19
directly [16] 12/20 14/11
31/12 50/18 50/25 51/9 54/9
54/17 64/20 67/14 69/12
69/20 70/1 70/13 79/5 98/10
dirty [1] 66/7
disappear [1] 111/25
discovery [2] 110/14 110/16
discrete [1] 32/16
discretion [1] 122/23
discuss [5] 45/2 127/14
127/16 127/19 127/23
discussed [4] 37/24 66/9
66/10 78/4
discussion [1] 45/9
dismissal [1] 130/6
displayed [1] 108/22
disposition [1] 47/23
disproved [1] 85/11
dispute [4] 79/22 82/4 91/18
94/10
distinction [2] 57/3 116/20
distinguish [1] 37/23
distinguishing [1] 117/8
DISTRICT [3] 1/1 1/2 1/4
DIVISION [1] 1/2
do [50] 5/25 6/1 6/14 6/16
6/17 7/2 8/7 9/18 11/7 11/8
21/8 23/16 26/23 29/24 32/24
33/16 49/19 59/3 59/12 61/1
61/21 61/25 63/13 74/24
79/12 80/6 80/17 81/10 83/3
88/16 89/22 91/1 93/1 95/3
95/12 101/5 104/15 107/5
107/17 108/7 108/9 108/20
109/8 116/22 117/3 117/14
118/17 127/18 127/24 129/11
document [10] 6/9 6/15 6/17
6/20 11/7 11/9 21/8 21/10
31/20 31/25
documentation [1] 120/23
documented [1] 120/9
documents [18] 6/21 7/23 8/1
9/7 9/10 10/16 10/19 11/21
15/14 18/7 19/8 19/16 21/25
22/7 40/4 95/23 96/1 96/5
does [34] 19/19 21/25 24/9
24/12 25/14 25/20 29/11 30/1
30/3 30/5 32/3 32/9 32/11
33/20 34/23 34/25 38/15 40/9
41/19 45/8 46/11 50/6 59/17
81/10 85/23 98/3 98/4 106/15
111/12 115/6 115/17 119/4
121/22 125/13
doesn't [8] 66/7 93/1 93/4
93/21 93/21 94/2 94/17
107/11
doing [5] 22/3 22/10 36/14
80/5 86/9
dollar [9] 13/10 13/11 74/25
75/21 93/18 93/20 93/20
94/22 94/25
dollars [12] 13/15 13/17
28/16 36/17 72/14 75/23 77/4
92/21 92/22 93/2 99/2 112/2
don't [34] 13/16 23/18 28/15
29/9 30/17 33/25 34/16 35/22
36/9 39/24 59/19 61/15 71/4
76/6 76/25 77/20 78/8 82/17
93/25 100/23 102/15 108/5
108/21 108/23 109/7 109/18
117/8 119/24 120/23 120/25
125/17 125/19 128/18 129/7
done [5] 46/20 88/15 93/10
100/16 108/1
double [2] 50/3 50/10
doubt [9] 48/20 62/19 63/20
63/24 64/3 67/10 70/18 74/11
78/13
down [12] 16/3 17/21 22/9
24/8 37/7 39/3 69/13 70/3
70/14 79/2 79/16 98/8
downstairs [1] 62/2
dozens [1] 114/7
draw [4] 73/14 76/2 77/4
103/1
drawn [1] 19/20
drifts [1] 129/9
Drive [11] 9/20 10/4 10/7
10/11 10/24 38/17 70/11
70/20 70/25 85/13 94/11
due [1] 38/20
during [26] 5/23 6/25 11/21
14/22 15/14 18/6 29/20 37/6
42/17 42/21 47/15 48/18
48/23 49/13 49/14 81/25
85/23 104/23 105/10 107/4
111/16 112/12 113/9 113/12
114/5 114/25
duties [1] 47/9
duty [4] 47/11 47/12 47/16
62/22
DX202 [1] 27/8
DX77 [1] 30/21
E
E-V-E-R-I [1] 34/9
each [16] 28/15 39/24 51/18
52/13 66/23 74/25 78/10
78/25 79/1 83/3 89/16 98/6
103/6 103/12 116/8 125/12
earlier [8] 6/6 37/24 49/17
62/14 71/15 72/16 85/2
102/12
earned [1] 82/13
earnings [1] 82/7
earring [2] 90/9 90/13
earrings [2] 43/17 54/6
easier [4] 55/23 66/6 71/8
75/9
Edward [1] 97/3
effect [1] 84/20
efficiency [1] 130/12
effort [1] 129/11
EIDL [67]
eight [2] 53/14 120/12
either [4] 43/20 84/20 90/21
117/10
electronic [1] 77/19
Eleven [1] 53/21
eliciting [1] 105/1
else [4] 34/7 78/19 92/21
99/24
employee [1] 120/25
Encore [2] 10/16 70/13
encounter [1] 14/24
end [3] 85/12 100/13 101/3
ended [1] 68/12
ending [14] 12/14 14/9 16/5
18/1 18/3 20/3 22/2 42/8
42/12 53/3 53/6 67/6 68/5
86/16
endorsement [1] 26/19
enough [4] 74/7 77/16 88/10
109/8
entered [2] 41/17 41/22
entire [7] 24/23 59/15 76/11
94/19 94/24 97/16 100/10
entirely [2] 90/16 118/8
entities [7] 12/1 48/5 48/9
72/15 72/16 72/19 96/11
entitled [8] 65/14 68/22
73/14 76/2 77/2 77/3 77/23
131/7
entity [2] 22/9 34/9
entries [2] 20/15 124/3
entry [2] 83/11 83/14
equally [1] 90/17
escrow [21] 7/23 7/24 8/1
9/7 9/8 9/10 10/16 10/17
10/19 69/13 70/2 70/13 94/14
95/21 95/22 96/1 96/4 96/6
96/8 97/23 99/4
essentially [9] 79/2 80/8
84/13 97/24 98/7 99/10
107/10 112/1 113/5
established [4] 49/2 82/3
106/25 122/24
establishes [1] 95/15
estate [5] 7/3 8/8 9/19
79/24 79/25
estimated [1] 40/15
et [1] 1/9
evaluate [1] 49/16
evaluation [1] 32/16
even [20] 32/1 50/4 56/19
59/7 71/6 74/21 81/1 81/25
83/23 85/23 88/16 92/15 93/9
106/24 109/23 112/13 113/11
116/25 120/5 120/15
evenly [1] 100/25
ever [1] 121/23
Everi [1] 34/9
every [8] 70/18 74/25 78/10
80/8 81/13 81/17 82/2 124/7
Everybody [2] 44/21 126/25
everyone's [1] 100/12
everything [5] 84/24 102/17
106/20 108/6 114/15
EVID [1] 4/8
evidence [106]
evident [1] 129/2
evidentiary [3] 110/14 130/3
130/3
ex [1] 41/10
exact [1] 13/16
exactly [2] 27/10 46/8
examination [6] 4/5 4/6 5/19
23/4 39/18 83/4
examine [1] 47/6
examined [1] 45/3
examiner [1] 40/6
examining [1] 29/21
example [21] 16/1 34/9 51/15
55/12 56/7 81/20 82/8 82/9
83/8 89/2 90/4 90/12 92/17
94/21 98/21 99/1 105/13
105/17 106/22 118/14 130/4
exceeds [1] 82/21
Excel [1] 19/10
exception [5] 48/18 48/23
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exception... [3] 57/1 57/8
87/8
exceptions [1] 48/15
exchange [1] 55/18
exchanged [1] 56/4
exclusively [1] 47/24
excuse [1] 66/8
excused [1] 127/10
executed [2] 42/7 42/11
execution [3] 42/17 42/21
51/25
executions [3] 69/16 70/5
70/16
exercise [7] 12/15 14/5
17/17 21/23 35/14 85/25
100/16
exhibit [47] 4/8 4/13 6/10
6/12 7/11 8/16 10/2 10/25
11/6 11/12 11/12 11/17 12/4
13/20 15/4 15/20 16/14 16/24
17/20 18/12 19/2 19/23 21/7
21/13 21/13 21/22 21/25 24/1
25/5 25/9 29/15 31/8 37/2
38/10 39/16 40/21 44/12
44/14 44/15 59/11 60/10
81/15 81/25 82/24 84/4 91/14
96/10
exhibits [7] 22/19 81/4
83/17 103/24 103/24 103/25
127/6
existed [2] 82/16 92/15
experience [1] 112/10
expert [1] 47/11
explain [6] 15/20 16/1 16/14
16/24 18/12 34/3
explained [3] 58/1 98/7
114/23
explaining [1] 86/22
explanation [1] 38/20
explicit [1] 84/24
explicitly [1] 110/1
exploring [1] 106/14
expressed [1] 127/21
extent [4] 59/9 84/17 90/7
123/1
extraordinarily [1] 127/5
extraordinary [1] 127/4
extreme [1] 94/21
extremely [2] 113/8 114/22
eye [1] 80/15
F
F.3d [1] 106/9
face [1] 15/9
faces [2] 111/14 113/24
facilitate [5] 55/8 55/20
66/4 75/7 97/19
facing [2] 114/15 114/16
fact [12] 41/16 85/21 93/23
94/16 95/8 95/24 96/1 105/18
109/25 115/13 116/25 120/19
factor [1] 117/6
factors [1] 117/4
facts [7] 103/5 108/3 110/10
113/3 113/5 117/24 120/21
fades [1] 127/7
fair [16] 24/13 25/2 26/5
26/25 28/24 29/11 29/20 30/6
32/2 32/8 33/2 35/12 35/23
38/6 38/22 39/6
fairly [1] 84/24
fake [4] 96/22 111/21 114/2
114/3
falls [1] 105/7
false [2] 120/17 121/24
familiar [7] 13/5 26/24
30/13 67/2 69/6 72/19 77/19
families [1] 115/14
family [5] 77/24 100/2 116/3
116/8 117/24
far [5] 40/4 82/21 87/15
109/3 110/4
Fargo [2] 16/5 83/17
Farr [1] 72/12
federal [10] 42/7 42/10
42/17 42/22 50/13 50/20 51/2
54/21 112/22 113/9
feel [1] 127/25
feeling [1] 127/24
fees [1] 55/9
felon [1] 113/11
Fenton [5] 2/9 120/2 120/7
120/16 120/21
few [6] 46/23 61/10 61/16
61/18 62/5 112/15
Fiber [3] 26/11 26/16 83/14
field [2] 88/13 97/11
Fifteen [1] 54/3
file [2] 107/19 108/25
filed [1] 118/10
files [1] 85/8
filing [3] 104/16 109/18
119/2
filings [2] 104/16 104/17
final [4] 61/19 73/24 101/6
101/16
finally [7] 12/21 70/11
77/22 79/23 83/20 91/15
127/23
financial [4] 55/6 55/11
55/16 95/9
find [11] 50/4 50/9 54/19
57/20 58/2 74/25 75/5 79/7
102/20 103/15 123/13
finders [1] 103/4
finding [1] 130/2
findings [6] 52/13 56/22
87/14 102/11 102/11 102/13
firearms [2] 117/15 120/10
first [27] 9/2 22/14 39/19
42/4 45/20 48/18 49/19 58/15
62/10 63/6 66/24 67/4 69/6
69/11 71/12 71/17 72/8 74/14
83/7 86/4 92/9 95/14 98/9
103/25 105/8 106/4 112/16
five [4] 28/7 28/9 53/5
108/23
flagged [1] 84/6
flee [2] 116/4 122/2
flight [10] 111/12 111/14
111/25 113/24 116/1 117/5
118/25 119/21 120/4 122/8
floated [1] 128/17
floor [2] 2/6 61/2
flow [1] 88/24
flowing [1] 78/24
focused [2] 82/25 88/24
follow [1] 65/15
following [15] 5/6 42/5 44/8
44/19 46/25 52/12 56/22
58/18 61/7 62/8 101/20 102/3
104/4 123/20 128/2
footage [1] 80/16
football [1] 88/13
foregoing [1] 131/5
foremost [1] 92/10
foreperson [9] 58/4 61/21
123/23 124/1 124/8 124/9
124/21 125/6 125/11
foreperson's [1] 124/16
forfeit [23] 49/24 49/25
50/15 50/22 51/5 52/12 54/24
56/21 62/17 66/12 67/4 67/19
68/4 69/5 71/13 72/6 72/21
73/19 74/1 88/3 97/14 99/25
103/8
forfeitability [1] 102/21
forfeitable [13] 54/20 56/12
56/15 56/18 57/21 71/5 92/19
92/20 92/23 92/24 93/4
102/20 103/16
forfeited [2] 47/24 86/24
forfeiting [3] 91/18 101/1
103/9
forfeiture [73]
forget [4] 71/4 76/6 77/20
78/8
form [21] 45/15 50/9 51/14
57/22 58/2 58/4 58/6 65/2
66/21 86/14 98/5 99/10
102/10 104/2 104/10 104/13
104/13 120/12 124/4 124/6
125/20
format [1] 131/8
forth [2] 49/18 62/5
forward [2] 60/17 110/18
found [32] 47/19 49/4 52/8
54/10 54/19 55/19 57/13
57/20 62/18 62/25 67/9 68/17
69/23 73/7 73/12 73/21 74/16
74/17 76/9 76/10 76/21 79/8
80/3 92/5 109/10 109/16
113/12 114/4 114/8 114/9
114/25 115/1
foundation [8] 30/24 33/5
33/18 34/14 37/19 39/8 39/21
88/7
founders [1] 81/21
four [4] 66/19 67/12 72/24
108/23
Fourteen [1] 54/2
fourth [3] 16/2 27/4 76/25
Francisco [1] 2/21
frankly [4] 84/19 90/1 90/6
120/13
Fraser [2] 3/7 102/7
fraud [34] 64/12 64/13 64/14
64/16 64/23 65/13 65/18
66/13 67/7 68/3 68/7 69/9
71/17 74/11 76/20 79/4 79/6
80/4 81/8 82/13 82/16 82/23
83/2 85/21 87/2 87/3 89/19
97/5 98/9 100/17 112/16
112/19 112/25 114/14
fraudulently [2] 65/13 67/11
free [2] 127/14 127/25
freely [2] 41/18 127/19
fresh [3] 110/11 129/8
130/11
FRIDAY [1] 5/1
friend [1] 120/13
front [1] 120/24
full [5] 7/6 8/11 99/16
117/23 121/1
fully [1] 127/19
funded [12] 7/21 7/21 9/2
9/5 10/13 12/19 12/20 12/21
14/7 14/11 17/24 22/6
funding [1] 96/20
funds [100]
fungible [11] 13/6 13/9
13/12 13/13 45/20 46/7 46/9
46/10 75/13 91/24 93/18
further [8] 22/16 41/2 41/7
43/20 43/22 43/24 45/11
107/15
G
gambling [1] 82/10
gaming [1] 34/2
gave [3] 30/2 65/17 81/20
general [5] 90/3 107/14
111/9 112/8 114/14
generally [2] 32/22 107/8
generating [1] 85/4
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Gentleman [19] 18/16 19/4
19/8 19/17 19/25 20/2 20/5
20/8 20/10 20/12 20/21 21/2
35/3 35/10 35/16 35/21 72/10
72/20 73/1
Gentleman's [3] 86/7 86/21
88/5
gentlemen [11] 62/12 65/24
68/22 73/9 73/15 76/4 77/1
77/21 78/6 78/14 125/22
get [19] 13/16 46/22 59/1
59/1 62/5 82/17 87/6 93/22
97/1 98/5 100/15 101/19
103/23 103/25 110/4 110/5
110/19 128/5 129/10
getting [3] 59/6 81/13 82/2
gist [1] 87/18
give [11] 32/15 32/17 44/5
47/3 61/11 61/12 62/5 108/7
108/15 113/20 117/25
given [10] 42/2 47/8 49/17
63/9 88/14 99/12 109/6 109/8
123/4 124/11
giving [1] 104/12
Glendale [2] 3/13 52/21
go [49] 22/14 22/25 24/1
24/7 24/22 25/5 25/10 26/1
26/9 26/14 27/3 27/12 27/19
27/20 28/11 28/19 29/14
29/15 29/19 30/3 30/9 31/16
31/20 31/24 35/1 35/9 35/24
36/12 36/13 37/3 40/7 40/21
41/9 60/17 60/20 60/23 61/24
62/6 66/22 80/9 91/13 91/20
102/13 109/12 110/18 113/22
116/24 119/18 121/18
goes [1] 32/19
going [35] 5/10 7/6 8/11
38/6 60/2 63/11 64/15 65/2
66/24 80/17 84/18 87/6 91/5
95/12 98/5 99/10 99/12
101/19 102/15 104/11 107/17
107/18 108/4 108/7 108/9
108/14 108/15 109/1 110/13
110/18 115/18 122/2 123/14
124/5 130/15
gold [36] 42/24 43/7 43/7
43/8 43/8 43/9 43/9 43/10
43/11 43/16 43/17 53/15 54/2
54/3 54/5 66/21 71/11 71/13
71/16 71/20 73/20 76/1 76/16
79/20 85/17 85/18 85/22 90/9
90/13 92/17 92/18 92/21 93/2
93/7 93/9 93/11
golf [2] 92/22 92/22
gone [3] 62/2 63/25 110/13
good [10] 5/8 5/21 5/22 23/6
23/7 44/17 62/12 78/17
121/11 123/12
goods [1] 73/13
got [7] 36/24 59/7 81/6
81/17 100/1 100/6 110/2
gotten [1] 120/12
government [157]
government's [23] 45/4 45/5
45/10 46/4 48/19 59/23 64/2
65/7 68/9 81/1 83/24 85/19
86/24 87/18 89/16 96/10
101/4 104/12 105/21 118/7
129/17 130/5 130/8
grand [4] 16/2 112/23 113/1
120/20
great [2] 89/2 122/18
greater [1] 98/18
Grigoryan [2] 117/9 117/13
grounds [1] 50/2
group [2] 3/15 69/3
groups [3] 66/19 66/23
116/13
guidelines [1] 117/7
guilt [5] 47/7 52/13 56/22
63/17 69/6
guilty [18] 30/15 47/20 49/4
54/11 54/19 55/19 57/13
57/20 62/19 62/25 67/9 68/17
69/23 83/1 112/22 116/21
117/1 118/22
gun [3] 113/11 113/13 120/8
guns [7] 114/25 115/1 115/2
115/5 115/8 120/7 121/20
GX1.C [1] 26/13
GX10 [1] 84/22
GX401 [7] 23/8 26/9 27/3
27/16 27/20 30/9 33/1
GX402 [1] 36/13
H
had [21] 20/22 38/6 39/25
61/15 76/5 76/19 77/9 80/15
81/19 84/17 90/3 105/19
113/11 113/13 115/8 117/19
117/19 119/13 120/8 122/6
123/6
half [6] 77/4 84/13 94/13
94/15 95/18 101/15
half-hour [1] 101/15
halfway [1] 24/8
hand [7] 26/18 28/20 38/13
38/21 121/2 123/25 124/1
handed [1] 124/3
handwriting [3] 91/23 123/13
123/15
happen [2] 47/21 93/12
happened [5] 33/16 33/25
82/16 106/20 107/4
happening [1] 97/20
Harapetyan [5] 26/16 28/25
31/18 32/8 83/8
harder [6] 55/23 66/6 71/9
75/5 75/10 97/19
Hart [1] 18/2
has [76]
hasn't [1] 93/10
have [130]
haven't [5] 14/25 38/3 88/15
105/25 109/8
having [2] 115/5 121/2
Hayrapetyan [16] 24/25 26/2
26/6 30/13 31/6 32/2 32/13
33/3 33/17 33/21 59/24 83/1
84/8 84/11 84/15 118/15
Hayrapetyan's [2] 29/4 30/7
he [83]
heads [1] 125/13
health [1] 81/7
hear [10] 62/10 80/5 80/19
90/24 91/8 91/10 91/12 105/5
117/16 129/24
heard [64] 60/4 60/23 61/19
62/13 63/3 63/4 63/8 63/15
63/19 65/9 67/12 67/15 68/8
68/18 69/11 70/11 71/15
71/18 71/21 72/6 72/8 72/12
72/22 73/2 73/16 74/7 74/14
74/20 75/11 75/18 75/20
75/22 76/9 76/12 76/15 76/16
76/20 77/13 78/9 79/3 79/12
79/21 80/2 80/13 81/9 81/12
81/19 81/20 83/1 84/19 85/17
88/2 89/6 91/6 92/12 92/14
94/9 94/12 95/3 95/20 97/3
109/21 120/5 121/12
hearing [12] 30/23 31/3
78/21 108/12 108/14 108/14
110/1 110/12 128/11 128/16
129/5 129/25
hearsay [3] 32/5 39/22 60/5
heart [1] 110/15
held [18] 5/6 42/8 44/8
44/19 46/25 53/3 58/18 61/7
62/8 67/6 95/21 101/20 102/3
104/4 117/1 123/20 128/2
131/6
help [1] 62/16
helpful [2] 105/4 106/8
her [11] 32/11 32/15 32/15
32/17 40/4 86/5 88/15 97/7
97/7 102/20 103/12
herd [2] 67/21 86/21
here [53] 22/9 23/20 32/15
34/3 34/11 37/24 44/10 44/21
45/8 46/20 58/8 59/1 66/12
67/22 68/10 71/3 72/11 72/22
73/19 79/23 81/25 82/4 84/5
84/12 84/17 86/20 87/24
88/18 90/4 90/12 90/19 90/22
90/23 92/9 93/10 93/20 94/4
95/12 97/11 97/24 99/4 99/17
102/17 102/25 103/3 107/17
112/15 113/4 118/20 119/1
119/25 120/1 123/6
hereby [2] 42/2 131/4
Hernandez [1] 126/14
hey [1] 88/10
hid [1] 113/14
hide [1] 76/18
high [1] 87/7
higher [2] 36/7 36/9
highlights [1] 97/24
Highway [1] 3/20
Hills [2] 7/24 69/13
him [9] 111/25 112/7 117/2
117/10 117/12 120/12 121/12
121/17 121/23
his [26] 72/12 79/18 82/1
82/20 97/1 97/2 102/18
112/16 113/10 113/12 114/4
114/8 114/9 115/8 118/9
118/11 118/18 118/19 118/23
119/22 120/8 120/8 121/2
121/14 121/21 121/25
history [11] 73/17 110/3
111/20 111/22 111/23 114/1
114/3 114/6 114/10 115/6
117/23
ho [1] 90/25
hold [1] 109/1
holders [1] 96/21
home [9] 74/2 77/4 100/3
113/11 113/12 113/15 114/8
115/8 119/7
Honeycut [2] 45/7 45/8
Honor [109]
Honor's [1] 130/10
HONORABLE [1] 1/3
hope [1] 122/8
hour [2] 101/15 110/21
house [22] 76/13 76/24 77/20
85/13 92/20 94/5 94/8 94/9
94/10 94/11 94/22 94/24
95/18 95/20 96/6 99/13 99/17
99/25 100/8 100/9 100/11
114/24
household [2] 116/11 116/12
houses [2] 85/7 94/6
how [25] 7/15 8/20 10/6 15/6
17/16 32/11 33/7 51/13 53/14
59/17 65/1 65/2 66/9 77/7
77/17 81/17 82/9 88/6 106/22
108/21 115/24 116/8 117/8
119/4 122/14
However [5] 47/7 48/6 50/8
59/13 129/3
hundred [4] 13/15 13/17
75/20 97/11
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hundreds [2] 72/14 75/23
hunting [1] 121/22
I
I'm [2] 36/12 59/1
I.D [1] 4/8
ID [1] 121/24
idea [1] 128/17
identical [5] 45/24 52/7
52/7 92/4 92/5
identified [18] 15/22 17/4
34/4 41/15 41/20 52/17 52/21
53/1 65/4 69/22 70/4 70/9
70/15 70/22 71/14 72/3 78/11
112/4
identify [5] 12/9 13/24
24/18 52/2 91/25
identifying [2] 41/12 95/23
identities [4] 111/21 111/21
114/2 114/3
identity [3] 64/13 111/19
114/1
ignored [1] 81/3
illegal [1] 115/4
immediately [2] 59/7 82/12
implicate [1] 130/4
important [5] 48/15 50/8
61/13 100/11 112/15
imposed [1] 48/25
imposing [1] 50/12
impossible [1] 90/6
improper [1] 105/23
improve [2] 56/8 56/20
Inc [1] 53/7
Inception [2] 77/11 96/3
inch [2] 43/16 54/3
include [3] 29/11 55/21 75/7
included [2] 29/16 91/22
includes [4] 51/11 55/5 56/3
100/3
including [13] 46/7 50/2
59/16 64/12 67/22 76/14
87/10 111/15 111/21 112/11
113/8 113/25 119/11
income [1] 39/13
inconsistent [2] 118/8
118/12
Incorporated [1] 42/13
incubator [1] 82/3
incubator's [1] 81/12
incubators [1] 81/18
independent [3] 86/25 89/20
103/4
indicate [6] 16/20 20/23
30/1 50/8 58/2 124/5
indicates [2] 16/7 17/14
indicative [1] 120/4
indicted [2] 112/7 114/13
indictment [12] 42/4 49/19
83/24 87/8 87/9 87/12 87/15
95/10 106/23 107/2 107/22
118/19
indirect [1] 64/24
indirectly [11] 50/18 50/25
51/9 54/9 54/18 64/20 67/14
69/12 70/2 70/13 79/5
individual [1] 117/5
inference [2] 49/20 76/3
inferences [4] 73/14 77/5
102/24 103/1
Info [1] 22/6
information [6] 22/2 29/8
33/13 35/19 39/20 122/4
informed [2] 121/21 122/3
initial [1] 93/1
initially [1] 109/25
initials [2] 124/14 124/16
instance [1] 36/13
instances [2] 20/20 80/17
instead [2] 48/20 64/4
instructed [8] 62/22 64/2
64/7 64/24 65/19 65/25 66/15
75/6
instruction [10] 45/10 45/15
45/18 45/20 46/10 56/1 56/24
91/21 91/23 93/15
instructions [28] 44/4 44/6
45/3 45/4 45/5 46/12 47/3
47/8 47/15 48/16 49/17 57/9
63/7 63/8 63/10 63/12 63/16
64/19 64/22 66/11 71/4 71/14
72/23 74/24 78/7 78/8 78/11
104/2
intended [2] 45/2 100/4
intends [2] 42/4 59/14
interchangeable [2] 13/10
13/11
interest [11] 48/6 48/12
48/13 50/16 50/23 51/7 52/16
52/20 52/24 54/25 62/17
Interests [1] 48/9
interim [1] 128/24
Interiors [5] 12/22 18/22
72/4 77/12 91/13
international [10] 22/14
40/10 42/16 43/14 53/13
73/10 74/5 77/14 112/10
120/3
interplay [1] 130/9
interpreter [1] 44/24
interrogation [1] 105/10
introduced [3] 104/1 105/8
105/15
investment [1] 81/21
invoices [2] 71/25 90/2
involve [2] 34/5 34/6
involved [37] 12/17 14/7
52/3 52/6 52/9 55/1 55/4
56/5 56/7 56/13 56/16 56/18
57/11 57/18 65/23 65/25 67/8
68/7 69/10 69/19 70/8 70/20
71/5 72/15 73/22 74/12 79/8
92/1 92/3 92/6 98/13 98/20
98/25 113/2 115/14 122/1
127/6
involves [2] 46/6 108/2
involving [3] 51/21 120/17
121/25
is [624]
islands [1] 73/11
isn't [3] 23/13 93/17 98/4
issue [17] 47/5 58/22 58/23
79/24 104/8 104/21 106/2
106/23 107/15 107/18 110/16
110/20 110/23 111/1 117/19
117/22 129/14
issued [1] 15/24
issues [5] 50/10 108/3
110/14 119/13 129/23
it [252]
item [11] 89/17 89/22 90/11
90/22 90/24 102/14 102/14
103/6 103/8 103/12 103/12
items [7] 42/20 43/12 51/18
72/7 76/13 76/19 79/16
its [6] 5/12 49/16 70/5
102/23 107/20 118/12
itself [3] 40/19 55/22 75/8
Iulia [15] 16/3 16/5 16/8
16/9 16/10 22/3 25/7 25/12
26/3 26/6 27/6 73/6 83/11
96/21 96/23
J
J52335 [2] 42/25 53/16
JAIS [2] 22/11 36/14
jar [1] 121/2
Jennifer [1] 3/12
jest [1] 112/15
jewelers [4] 18/9 18/20
71/19 75/25
jewelery [1] 71/12
jewelry [15] 42/20 43/12
66/22 71/21 73/3 73/21 79/20
85/16 85/17 85/20 85/22
89/15 89/18 90/1 92/13
John [1] 3/4
Johnson [7] 2/14 2/17 2/19
2/22 3/19 3/20 103/17
joins [1] 45/14
JP [6] 18/1 18/3 20/3 22/2
25/11 26/6
Jr [1] 3/14
judge [3] 1/4 62/13 123/15
Judicial [1] 131/9
July [7] 14/11 15/10 18/17
18/17 108/13 108/15 131/10
July 12th [1] 108/13
July 13th [2] 14/11 15/10
July 17th [1] 18/17
July 26th [1] 108/15
July 3rd [1] 18/17
JUNE [11] 1/17 5/1 31/3 38/5
38/14 83/18 83/22 124/8
124/21 125/6 125/11
June 12th [1] 83/22
June 14th [1] 38/14
June 17th [1] 83/18
June 28th [1] 124/21
juror [1] 45/22
jurors [2] 127/19 127/22
jury [79]
just [74]
JUSTICE [3] 2/4 2/9 108/24
K
K23313 [2] 43/3 53/20
Kaminir [1] 126/12
karat [7] 42/24 43/16 53/15
54/3 54/5 90/9 90/13
KATIE [2] 1/21 131/12
Katzman [2] 3/4 3/7
Kauichko [1] 87/22
Kauichko's [1] 9/5
keep [3] 63/6 64/21 76/23
Keough [1] 2/19
kept [1] 80/15
kids [2] 119/21 119/25
kids' [1] 100/8
kilogram [3] 75/25 75/25
76/1
kind [4] 46/9 119/3 121/18
122/7
Kish [1] 126/22
knew [3] 77/17 103/13 112/18
know [34] 23/16 26/23 28/15
29/24 30/14 30/15 32/3 32/9
33/16 33/20 33/25 34/15
34/16 34/16 35/22 36/9 65/2
73/18 76/17 77/6 77/7 83/23
84/15 99/9 108/21 108/23
109/18 109/20 110/19 113/8
117/14 120/12 125/19 128/18
knowledge [2] 34/15 38/8
known [1] 81/23
knows [1] 32/23
L
La [5] 7/4 8/6 69/7 69/14
94/8
Laboratory [1] 81/15
ladies [11] 62/12 65/24
68/22 73/9 73/14 76/3 77/1
77/21 78/6 78/14 125/22
Case 2:20-cr-00579-SVW Document 679 Filed 07/09/21 Page 141 of 151 Page ID
#:11039
L
laid [1] 96/11
Lam [1] 126/6
Lane [6] 8/9 8/17 8/21 8/25
9/15 69/24
large [2] 76/23 115/8
largely [1] 88/23
Lars [1] 126/18
last [12] 12/23 14/12 27/21
36/23 46/16 61/18 62/20
91/15 91/20 94/5 120/12
122/3
later [3] 18/1 48/1 78/21
launder [1] 76/4
launderer [1] 55/10
laundering [72]
law [11] 3/15 3/20 48/14
50/13 50/20 51/2 54/21 60/6
100/8 106/7 130/2
lawyers [6] 61/11 61/20
63/22 101/25 108/21 108/23
lead [1] 65/15
leading [1] 82/1
least [7] 17/4 67/16 72/8
81/10 91/19 108/23 128/5
leave [6] 31/24 36/20 37/10
99/21 101/24 121/5
leaving [2] 84/14 104/19
lecturn [1] 109/12
led [1] 84/5
left [2] 63/1 84/17
legal [1] 95/2
legally [1] 92/19
legitimate [2] 74/23 82/18
less [3] 39/1 100/25 116/3
lesser [1] 99/15
let [10] 46/1 56/17 91/13
94/2 104/6 105/5 116/14
117/16 118/3 122/20
let's [17] 29/14 60/20 66/22
78/17 80/1 82/22 83/7 85/16
86/2 86/19 89/15 92/16 92/17
101/22 110/6 121/5 129/16
level [3] 87/7 103/15 106/14
Lewis [1] 3/4
life [2] 40/10 119/25
like [35] 6/9 6/24 7/10 8/15
9/16 10/1 10/25 11/4 13/19
15/19 16/13 16/23 17/19
18/11 19/1 19/22 21/5 23/8
23/19 30/20 35/24 37/7 39/3
51/21 60/15 79/9 79/17 89/9
91/7 95/16 105/3 105/12
107/11 110/23 111/4
likely [14] 64/6 79/14 84/21
90/17 90/17 91/3 100/24
100/25 100/25 100/25 103/6
103/11 113/14 116/3
limitations [1] 32/21
Limited [2] 22/10 36/14
Limo [2] 7/21 12/19
line [6] 15/12 16/18 17/14
40/9 79/15 88/13
lines [4] 31/21 31/25 83/4
84/3
link [1] 89/16
linked [3] 73/6 96/17 107/22
list [1] 27/21
listed [5] 54/16 57/18 57/23
58/3 72/22
listen [1] 101/16
litigate [1] 118/10
litigating [1] 129/4
little [5] 44/3 62/15 105/4
108/10 108/16
Littrell [3] 3/4 3/4 3/7
live [1] 100/5
lives [1] 100/12
LLC [5] 13/22 14/3 42/9 53/4
81/15
LLP [6] 2/14 2/17 2/19 2/22
3/4 3/7
LN [1] 17/23
loan [46] 9/2 9/2 9/3 9/4
9/4 9/23 12/18 12/18 12/18
12/19 12/21 13/25 14/7 14/10
15/3 15/7 17/24 18/19 22/5
22/5 28/14 28/17 28/21 35/13
35/16 35/21 37/16 65/11
65/14 67/11 68/10 68/14
68/15 68/20 70/1 70/12 72/4
72/9 82/23 83/2 85/21 87/2
89/19 96/19 97/1 97/5
loans [38] 7/20 9/1 9/1
10/12 12/6 12/17 13/21 14/20
14/25 15/11 17/10 18/8 18/15
37/13 37/17 37/22 37/24
67/13 67/23 69/12 69/15 70/3
70/15 71/2 71/3 71/22 74/15
74/16 79/11 84/7 85/12 86/11
86/23 87/21 88/7 88/17 94/15
112/4
located [4] 16/16 52/16
52/20 52/24
location [1] 119/7
locations [1] 117/25
long [4] 71/7 75/2 82/9
129/8
longer [5] 48/19 62/15 64/3
108/11 129/9
look [13] 17/20 25/14 29/4
29/6 29/14 31/21 32/16 40/15
46/21 68/24 72/25 84/4
120/15
looked [5] 29/8 38/3 70/25
88/16 123/12
looking [4] 37/22 38/1 82/11
99/4
looks [2] 26/22 29/23
LOS [7] 1/14 1/23 2/7 2/15
3/9 3/16 5/1
loss [3] 40/15 40/24 109/22
lot [3] 65/4 82/4 91/5
LU44845K [2] 43/4 53/22
lunch [4] 101/14 101/15
101/22 101/23
luxury [1] 75/23
LW3397N [2] 43/6 53/24
M
madam [1] 124/8
made [19] 16/6 16/17 18/5
18/15 19/5 27/6 27/22 28/3
28/12 29/6 38/5 38/9 102/12
102/24 105/10 110/4 129/11
130/4 130/14
magic [1] 97/19
maintain [2] 56/9 56/20
major [2] 121/13 122/5
majority [3] 82/25 84/7
121/21
make [22] 22/8 45/2 45/12
55/22 59/4 60/3 60/8 66/5
71/8 75/4 75/9 97/17 97/18
97/19 101/5 101/10 102/1
102/10 103/2 111/25 116/19
129/22
makes [5] 89/3 99/3 100/11
110/11 116/3
making [2] 49/12 105/1
man [1] 82/25
mandatory [5] 111/15 111/17
111/18 111/19 113/25
Manuel [1] 119/8
Manukyan [6] 23/22 24/5
24/13 24/25 83/9 83/10
Manukyan's [2] 24/10 25/3
many [13] 17/16 51/13 63/20
65/1 65/8 88/6 108/2 108/3
108/3 108/21 116/8 124/3
127/6
Marietta [11] 32/4 38/16
42/15 43/14 53/12 74/4 96/2
102/7 104/24 115/16 125/8
marked [4] 11/5 20/18 21/6
31/8
Market [1] 2/20
Mary [1] 85/12
MARYLEE [2] 4/4 5/13
masterminding [1] 121/15
match [1] 20/20
materials [1] 62/3
math [3] 30/12 36/23 86/10
math-based [1] 36/23
Matt [1] 81/22
matter [12] 47/24 58/21 93/4
93/21 94/17 98/3 98/4 105/25
106/18 110/17 111/9 131/7
matters [6] 41/24 65/24 99/3
99/22 100/2 101/23
may [44] 5/17 14/8 17/24
18/2 18/4 18/4 23/24 24/9
24/25 25/14 25/20 26/11 30/8
39/7 44/2 48/4 48/7 48/13
51/14 51/15 55/11 55/13
55/15 55/17 55/21 56/8 60/4
61/18 65/2 65/15 75/7 83/12
84/10 84/11 90/4 90/5 93/13
100/24 104/6 104/7 121/7
121/24 123/2 127/12
May 1 [1] 17/24
May 14th [6] 18/4 25/14
25/20 30/8 83/12 84/11
May 4 [1] 24/25
May 4th [4] 18/2 18/4 23/24
26/11
May 5th [2] 14/8 24/9
maybe [4] 74/22 101/15
108/10 123/10
McGilly [1] 126/8
me [20] 46/1 56/17 56/23
60/24 71/15 91/13 104/6
104/20 105/5 109/12 117/16
118/3 119/13 120/24 122/20
123/25 124/3 124/12 128/1
129/10
mean [15] 20/16 30/14 31/9
33/20 50/6 85/24 103/10
107/5 108/21 109/13 110/4
115/17 117/7 123/5 128/25
meaning [4] 82/11 88/13
89/21 98/12
means [8] 49/7 64/8 66/5
79/7 90/23 101/1 112/6 125/2
meant [1] 45/1
Mechanics [1] 9/3
Media [3] 26/11 26/16 83/14
meeting [1] 128/10
Meghan [1] 2/16
members [6] 47/2 61/9 62/4
101/13 116/3 127/2
memo [1] 117/19
mention [2] 63/15 116/7
mentioned [2] 85/2 120/7
Merchants [1] 75/21
Mesereau [3] 3/14 3/15
121/11
messages [5] 19/12 80/21
84/23 84/24 84/25
metals [7] 46/8 52/3 52/5
52/8 91/25 92/3 92/5
MGM [2] 39/20 40/9
Miami [11] 42/15 43/14 53/13
73/6 73/7 73/10 73/22 74/5
77/14 107/23 113/14
Michael [1] 2/19
Case 2:20-cr-00579-SVW Document 679 Filed 07/09/21 Page 142 of 151 Page ID
#:11040
M
mid [1] 116/18
might [4] 47/21 77/19 77/25
130/11
million [5] 37/4 37/7 77/4
94/23 112/4
millions [1] 112/2
mind [6] 63/6 64/21 86/23
123/6 127/18 129/9
mine [2] 91/23 120/13
minimum [5] 111/15 111/17
111/18 111/19 113/25
minus [1] 30/10
minute [1] 58/25
minutes [10] 44/5 45/1 46/23
61/4 61/10 61/16 61/19 62/5
101/19 102/1
miscellaneous [3] 42/20
43/12 71/12
miss [1] 126/24
missing [2] 44/22 44/24
mixed [1] 71/7
mixing [3] 66/7 74/22 75/4
mobile [3] 26/21 26/25 83/16
Mod [5] 12/21 18/22 72/3
77/11 91/13
model [6] 42/24 43/1 45/9
53/16 53/18 89/13
moment [5] 46/2 104/19 118/1
121/6 128/5
MONDAY [1] 1/17
monetary [2] 50/3 95/9
money [106]
Monica [1] 3/15
monies [2] 32/18 32/20
monitoring [2] 117/25 119/7
months [3] 71/20 81/25
120/13
more [50] 25/18 25/18 37/7
48/5 49/8 50/5 50/14 50/14
50/21 51/3 54/10 54/17 54/19
54/22 57/12 57/19 58/23
61/25 64/6 64/9 66/1 67/17
68/23 71/19 72/14 73/12 74/7
74/18 75/3 77/16 77/23 77/24
78/2 79/14 84/21 90/17 91/3
100/23 102/11 102/16 103/6
103/11 105/4 107/14 108/22
110/16 110/23 118/14 129/9
130/11
Morgan [6] 18/1 18/3 20/3
22/2 25/11 26/7
morning [7] 5/8 5/21 5/22
23/6 23/7 80/7 81/2
mortgage [6] 38/3 38/4 38/6
38/15 112/19 120/18
most [7] 64/11 65/5 79/19
88/20 99/7 99/7 106/14
motion [7] 110/5 128/11
129/2 129/23 129/24 130/4
130/14
motions [6] 118/10 128/15
128/20 129/4 129/18 130/15
move [10] 9/16 10/25 19/1
21/12 22/19 59/10 92/20
111/4 112/1 113/17
moved [5] 51/16 96/22 115/10
117/10 117/12
moves [1] 11/11
moving [7] 8/7 67/22 72/5
74/20 80/25 115/15 130/11
Mr [7] 4/5 4/6 5/20 23/5
87/10 123/11 126/6
Mr. [38] 5/17 6/12 11/4 21/5
29/4 30/7 30/13 32/2 32/8
32/9 33/3 33/3 33/17 60/1
62/2 72/12 77/11 91/19
102/17 117/13 118/9 118/23
119/10 119/11 119/12 119/14
119/20 120/2 120/7 120/8
120/16 120/21 120/24 123/9
124/1 126/2 126/10 126/16
Mr. Almader [1] 126/16
Mr. Ayvazian [6] 32/9 33/3
118/9 119/14 119/20 120/24
Mr. Ayvazyan [4] 60/1 91/19
118/23 120/8
Mr. Ayvazyan's [1] 77/11
Mr. Boyle [1] 62/2
Mr. Cruz [6] 5/17 6/12 11/4
21/5 123/9 124/1
Mr. Diaz [1] 126/2
Mr. Farr [1] 72/12
Mr. Fenton [4] 120/2 120/7
120/16 120/21
Mr. Grigoryan [1] 117/13
Mr. Harapetyan [1] 32/8
Mr. Hayrapetyan [4] 30/13
32/2 33/3 33/17
Mr. Hayrapetyan's [2] 29/4
30/7
Mr. Ram [1] 102/17
Mr. Regidor [1] 126/10
Mr. Ybanez [3] 119/10 119/11
119/12
Ms. [51] 5/21 6/14 11/7 21/8
23/6 23/9 23/19 25/3 25/18
26/14 27/13 27/19 32/10 33/4
38/13 38/19 39/4 40/13 41/5
45/14 65/6 65/9 67/21 68/9
68/18 69/11 70/12 71/21 72/8
72/18 74/14 75/1 77/8 80/7
86/5 86/22 88/15 94/12 101/8
102/19 102/22 103/9 103/16
125/25 126/4 126/8 126/12
126/14 126/18 126/20 126/22
Ms. Calloway [1] 126/20
Ms. Hernandez [1] 126/14
Ms. Kaminir [1] 126/12
Ms. Kish [1] 126/22
Ms. Lars [1] 126/18
Ms. Manukyan's [1] 25/3
Ms. McGilly [1] 126/8
Ms. Perez [1] 126/4
Ms. Robinson [22] 5/21 6/14
11/7 21/8 23/6 38/13 41/5
65/6 65/9 67/21 68/9 68/18
69/11 70/12 71/21 72/8 74/14
75/1 80/7 86/22 88/15 94/12
Ms. Robinson's [2] 72/18
86/5
Ms. Romero [9] 23/9 23/19
25/18 26/14 27/13 27/19
38/19 39/4 40/13
Ms. Terabelian [8] 32/10
33/4 45/14 101/8 102/19
102/22 103/9 103/16
Ms. Terabelian's [1] 77/8
Ms. Vargas [1] 125/25
much [4] 7/15 8/20 10/6
108/11
multiple [6] 50/2 59/13 73/1
76/6 77/14 119/11
must [10] 47/6 49/8 49/24
54/19 57/20 58/1 64/8 89/16
103/7 104/18
my [14] 15/8 45/7 46/12 61/1
61/9 63/13 84/17 92/20
101/13 122/4 122/21 123/14
123/15 129/8
myself [1] 45/2
N
name [26] 4/3 12/6 12/10
13/21 13/25 24/5 25/12 30/14
42/9 42/12 48/4 53/3 53/6
67/1 67/6 68/6 68/11 73/18
81/12 81/23 83/8 97/1 97/7
121/21 123/15 125/23
named [1] 83/1
names [9] 67/2 77/15 87/21
87/22 111/23 111/24 113/4
114/7 114/10
narrow [1] 106/19
narrower [1] 62/21
national [1] 113/10
nature [2] 113/7 114/21
nearly [1] 77/3
necessarily [2] 13/16 66/7
necessary [2] 51/24 110/17
necessity [1] 47/14
NECH [1] 20/6
neck [2] 43/16 54/3
need [10] 44/2 50/2 60/18
61/1 61/25 74/24 82/17 93/25
102/24 109/2
needed [1] 102/16
needs [2] 100/16 103/22
neglected [1] 82/7
net [2] 30/11 84/14
never [4] 45/25 75/14 115/10
117/10
nevertheless [2] 115/3 115/7
new [7] 2/10 2/18 58/21 63/9
66/11 75/22 84/23
Newcomer [1] 2/16
newest [2] 104/16 104/20
next [14] 25/17 26/1 27/12
29/19 30/3 69/3 69/24 71/10
83/11 83/14 84/3 124/11
125/8 128/10
Nicholas [2] 2/22 44/11
NINE [2] 1/15 53/17
Ninth [3] 60/5 106/10 106/11
no [65] 1/8 4/13 4/13 22/16
22/23 33/24 38/4 38/8 39/9
39/25 40/2 41/2 41/6 48/19
60/23 61/23 64/3 69/1 77/9
79/23 80/2 83/19 84/19 85/15
87/14 87/25 88/21 92/12
92/14 93/5 93/10 93/16 94/8
96/7 96/7 97/16 99/14 101/1
103/2 103/14 108/14 108/19
114/17 115/22 118/15 119/13
121/18 121/19 124/5 124/12
124/13 124/14 124/18 124/20
124/21 125/4 125/4 125/5
125/5 125/9 125/9 125/9
125/10 127/16 131/12
No. [5] 45/20 52/18 52/22
91/23 123/16
No. 1 [2] 91/23 123/16
No. 12 [1] 45/20
No. 2176-029-031 [1] 52/18
No. 5663-036-033 [1] 52/22
nodding [1] 125/13
non [2] 110/14 130/3
non-evidentiary [2] 110/14
130/3
none [5] 80/17 85/9 96/5
97/6 97/8
nonevidence [1] 107/24
North [2] 2/6 3/20
not [164]
note [5] 68/18 114/24 122/13
123/16 123/22
nothing [6] 41/3 43/22 43/24
89/22 103/18 115/4
notice [3] 20/14 42/2 127/8
noticed [1] 70/24
notify [1] 128/1
November [10] 17/2 17/6 42/7
42/17 42/21 53/9 53/12 68/6
74/2 74/4
November 20 [3] 42/7 53/12
68/6
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November 20th [1] 74/4
November 5th [5] 17/2 17/6
42/17 42/21 74/2
November 8th [1] 53/9
Novo [3] 26/21 26/23 83/16
now [80]
number [30] 17/23 19/20
20/14 20/18 24/8 36/7 36/9
39/5 42/8 42/24 43/1 43/3
43/4 43/6 43/15 44/14 46/7
53/1 53/3 53/16 53/18 53/20
53/22 53/24 54/1 55/12 86/16
91/7 95/17 115/8
numbers [7] 65/8 65/9 65/10
65/11 65/15 67/16 127/6
numerous [3] 72/19 76/13
76/15
nutshell [1] 105/21
NW [2] 2/10 2/23
NY [1] 2/18
O
o'clock [1] 101/14
Oak [7] 42/23 43/2 43/3
53/15 53/19 53/21 53/23
Oaks [1] 43/5
oath [4] 5/16 31/22 32/3
32/9
objection [17] 22/23 24/15
30/18 30/24 32/5 32/24 33/5
33/18 34/14 37/19 39/8 39/21
39/25 40/2 45/5 75/14 75/17
objections [2] 22/22 58/15
objects [1] 98/16
obligation [1] 127/16
observe [2] 92/9 122/7
obtain [3] 65/14 67/11 113/5
obtained [16] 16/10 39/7
50/18 50/25 51/8 51/11 51/12
54/9 54/17 55/17 56/4 64/19
76/5 79/7 92/19 98/12
obtaining [1] 80/24
obviously [7] 82/17 85/21
89/17 91/22 93/19 104/14
109/14
October [4] 22/11 42/14
43/13 82/1
October 19th [1] 22/11
October 20 [2] 42/14 43/13
off [2] 106/25 129/8
offense [23] 50/19 51/1 51/9
51/19 52/4 52/6 52/9 55/1
55/23 57/18 64/20 65/23 66/3
66/5 66/6 71/6 71/8 75/9
92/1 92/3 92/7 93/23 94/19
offenses [6] 47/19 62/25
63/24 64/15 69/9 79/4
offered [6] 38/11 39/17
39/25 49/15 111/22 114/5
office [3] 2/4 3/20 108/25
officer [2] 119/8 119/23
official [2] 1/21 31/9
Offshore [4] 43/2 43/3 53/19
53/21
Oh [1] 58/25
Okay [36] 32/25 43/20 47/2
58/17 61/24 62/4 79/8 82/11
82/16 83/10 84/3 87/4 92/25
93/8 94/4 94/5 94/16 94/20
97/13 98/3 98/14 99/8 99/17
99/22 100/11 100/19 103/22
110/7 110/25 118/4 118/6
123/7 123/17 127/2 129/14
130/16
old [1] 121/3
omitted [2] 45/19 57/2
one [93]
ones [2] 9/11 38/11
online [1] 26/23
only [22] 14/20 36/1 57/3
61/19 79/24 80/11 84/14
86/20 86/22 87/7 87/9 87/11
88/9 90/1 94/10 94/17 96/13
96/15 96/18 99/19 112/18
117/6
open [1] 99/20
opening [2] 111/23 114/6
opinion [3] 32/17 32/20
32/21
opinions [1] 127/20
opportunity [1] 107/15
opposed [1] 45/21
opposite [2] 77/2 97/23
option [2] 99/14 99/17
options [1] 99/11
order [10] 75/4 103/8 107/18
108/8 109/1 110/20 124/2
124/11 128/6 129/14
original [2] 93/23 94/1
other [67]
others [4] 32/10 83/25 87/23
121/15
otherwise [2] 93/5 93/15
our [2] 58/15 128/10
out [23] 13/17 18/2 32/22
34/1 37/12 37/25 42/3 51/16
61/10 78/23 88/11 96/11
98/22 102/25 109/10 109/16
110/8 112/6 117/18 120/6
123/6 123/8 127/7
outlining [1] 108/8
outset [1] 39/17
outside [10] 40/4 44/9 44/19
58/18 62/8 101/20 104/4
122/3 123/20 128/2
over [14] 38/22 67/5 74/1
74/17 77/19 79/14 88/6 95/4
95/4 101/23 109/17 113/6
120/12 127/14
overall [1] 87/18
overdue [1] 38/25
overlapping [2] 50/4 50/11
Overruled [3] 24/17 30/19
37/21
oversight [2] 59/8 61/10
overt [5] 69/22 70/4 70/10
70/22 83/24
owed [1] 78/18
own [5] 81/1 97/1 97/2 97/7
97/7
owns [1] 85/22
P
p.m [5] 1/16 62/7 102/2
122/12 123/19
Pacific [1] 3/20
PAETTY [1] 2/5
page [40] 4/3 4/13 7/10 8/15
10/1 12/4 13/19 15/4 15/19
16/13 16/23 17/19 17/20
17/21 18/11 19/1 19/22 24/2
24/7 24/8 24/22 24/23 25/10
25/18 25/19 26/1 26/1 26/14
27/12 27/13 29/15 29/19 30/2
30/3 31/21 31/24 40/22 59/14
84/4 131/7
pages [1] 59/13
paid [6] 36/3 36/4 55/10
72/3 81/13 81/17
pair [2] 43/17 54/5
Palm [2] 52/24 52/25
pandemic [2] 108/4 112/12
paragraph [1] 39/19
parcel [6] 7/3 8/8 9/19
52/17 52/21 53/1
Paronyan [1] 97/3
part [30] 18/21 18/21 22/8
23/10 46/16 55/17 55/22
59/17 59/19 59/21 62/18
68/24 71/23 72/4 73/4 75/8
76/11 78/24 79/19 80/19
82/23 85/2 89/5 89/7 89/19
89/21 93/3 100/18 102/17
110/11
parte [1] 41/11
participation [1] 128/13
particular [14] 27/25 50/5
51/25 52/1 71/1 75/1 89/4
89/6 89/16 89/25 92/13 93/18
106/16 115/13
particulars [8] 41/11 41/14
41/15 41/17 41/20 42/1 71/15
90/8
parties [11] 5/9 41/8 41/14
41/18 41/21 44/3 45/3 60/14
105/8 105/14 122/13
parting [1] 127/10
parts [1] 64/21
party [6] 34/5 48/1 48/2
49/6 49/10 117/17
passed [1] 117/22
passing [1] 117/18
passports [2] 119/22 119/24
past [1] 88/13
pathway [2] 98/9 98/11
pathways [1] 98/9
Paul [2] 59/2 130/17
Pause [1] 118/5
payable [13] 15/12 16/6 16/7
16/7 16/10 16/17 16/21 25/7
26/10 27/6 27/22 28/3 28/12
payee [4] 16/7 16/18 23/21
83/8
payment [10] 14/9 15/7 20/20
37/7 38/20 38/22 38/24 69/14
70/3 70/14
payments [11] 12/22 19/25
20/2 20/4 35/3 35/6 38/3
38/4 38/6 38/9 38/25
peaceful [1] 121/16
Pelletier [1] 81/22
penalty [4] 62/18 78/24
86/25 100/3
pending [2] 111/2 111/6
people [1] 76/22
people's [8] 87/20 87/22
111/23 111/24 113/4 114/7
114/9 114/10
percent [1] 112/5
Perez [1] 126/4
Perfect [2] 9/7 70/2
perform [1] 36/1
period [5] 29/20 81/1 85/10
88/22 120/10
permission [3] 11/15 21/16
22/25
permit [2] 60/13 60/16
permits [1] 59/10
permitted [1] 60/5
person [10] 48/6 90/25 96/22
96/24 103/1 121/16 122/7
123/12 127/14 127/17
personal [15] 50/17 50/24
51/7 54/25 56/9 56/11 56/11
65/23 66/21 71/11 73/20 80/3
94/10 95/8 100/1
persons [2] 48/5 48/9
personum [1] 45/22
persuaded [2] 49/8 64/8
Peter [3] 3/19 3/20 103/17
phase [26] 6/6 6/18 7/1
11/19 44/2 44/7 47/3 47/16
48/19 48/24 59/12 63/3 63/7
63/10 63/11 63/17 63/17
63/20 65/5 67/3 69/6 72/17
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phase... [4] 102/12 103/25
104/1 104/3
phases [1] 78/9
phone [1] 114/9
phrase [2] 97/19 103/23
Picadilly [2] 18/20 18/23
Piccadilly [2] 71/19 75/25
Piccadilly's [1] 71/25
picked [1] 82/7
picture [8] 90/23 100/14
109/22 110/8 118/7 118/21
118/25 120/24
piece [16] 79/1 79/1 79/4
79/6 79/10 80/5 86/2 87/3
87/16 89/17 89/25 92/13 98/6
101/2 122/25 128/14
pieces [2] 71/12 73/21
Piquet [11] 42/23 43/1 43/3
43/5 53/14 53/15 53/19 53/21
53/23 72/24 73/1
place [5] 52/8 55/17 76/18
92/6 120/8
places [1] 39/7
plainly [2] 77/19 96/10
PLAINTIFF [2] 1/7 2/3
play [1] 84/14
player [2] 121/13 122/5
player's [1] 34/18
players [1] 34/13
plea [2] 30/23 31/3
plead [5] 30/15 83/1 112/21
116/21 118/22
please [24] 17/20 18/12 24/7
24/22 25/10 26/9 26/13 26/14
27/8 28/11 28/19 29/16 29/19
30/21 33/1 35/2 35/9 36/12
37/2 38/13 39/4 125/23
127/21 127/25
pleases [1] 113/19
plus [1] 85/7
pocket [2] 93/21 117/19
point [14] 59/25 85/24
102/25 106/14 110/7 111/9
113/13 114/24 115/9 116/19
119/1 127/2 127/3 130/10
pointed [3] 78/23 118/14
120/2
points [3] 85/9 100/14
112/15
poll [1] 125/21
polled [2] 125/14 126/25
portion [3] 28/24 41/25
94/17
pose [3] 111/12 116/1 121/22
poses [3] 111/13 112/17
113/24
position [5] 45/10 115/17
122/14 128/18 129/18
possible [3] 15/7 28/16
39/12
post [2] 49/14 87/11
posting [1] 25/20
posture [1] 130/7
potential [2] 48/24 122/17
potentially [1] 100/19
PPP [116]
pre [1] 82/20
pre-PPP [1] 82/20
precious [9] 42/20 43/12
46/8 52/3 52/5 52/8 91/25
92/3 92/5
precisely [1] 107/12
prefer [1] 127/23
prejudice [1] 47/13
preliminary [2] 109/9 109/13
prepare [2] 19/7 60/14
prepared [7] 6/21 11/1 11/9
21/10 57/22 107/19 110/19
preparing [4] 29/9 34/20
109/17 128/22
preponderance [19] 48/21
49/2 49/7 54/15 57/17 64/1
64/4 64/5 64/7 66/17 74/8
75/2 79/13 84/21 88/12 90/11
90/15 93/7 100/2
presence [12] 5/7 44/9 44/20
47/1 58/19 61/8 62/9 101/21
102/4 104/5 123/21 128/3
present [6] 5/8 5/9 5/12
35/17 35/19 89/24
presentation [2] 35/1 62/6
presented [9] 26/25 49/11
49/13 49/14 58/6 68/25
100/21 125/24 129/12
preserved [1] 130/8
PRESIDING [1] 1/4
pressing [1] 104/7
pressure [1] 127/24
pretrial [2] 119/3 121/17
pretty [1] 123/5
previous [8] 6/18 7/1 8/7
9/18 11/19 47/6 48/15 67/3
previously [5] 5/23 6/9 47/8
56/25 57/8
price [1] 37/3
Primavera [10] 7/4 7/8 7/13
7/16 8/6 69/7 69/8 69/14
69/18 94/9
principle [1] 45/6
prior [16] 6/2 6/5 7/2 7/6
8/11 9/22 11/1 14/19 15/17
21/18 63/3 63/7 63/17 63/20
65/5 114/17
privacy [1] 127/22
privilege [3] 107/9 107/9
107/10
probable [4] 75/3 77/23
77/24 78/2
probably [5] 49/9 64/9 67/2
68/23 70/24
probation [4] 117/25 119/4
119/8 119/23
problem [1] 77/9
proceed [6] 5/11 5/17 25/17
31/1 32/6 104/2
proceeding [4] 47/16 48/9
90/21 112/9
proceedings [25] 1/13 5/6
30/22 31/3 44/8 44/19 45/21
46/15 46/25 49/15 58/18 60/6
61/7 62/8 89/10 101/20 102/3
104/4 111/10 118/5 123/20
127/13 128/2 130/21 131/6
proceeds [60] 12/5 12/9
13/20 13/24 50/18 50/25 51/8
51/10 51/13 51/13 51/15
51/19 51/20 54/9 54/16 55/13
55/16 64/19 64/24 64/25
64/25 65/1 65/1 65/3 65/16
65/16 65/17 66/2 67/7 67/11
67/16 68/3 68/7 69/2 69/8
70/1 70/12 71/17 71/20 72/9
74/11 74/23 74/23 75/5 75/13
75/20 76/19 79/5 80/4 82/15
84/2 85/18 89/2 89/20 92/24
93/8 94/13 100/17 112/3
114/11
produce [2] 34/12 34/17
produced [2] 20/12 72/25
production [1] 110/13
promptness [1] 5/10
pronounce [1] 22/10
proof [7] 41/23 48/19 48/20
49/6 64/3 64/4 77/22
properly [2] 46/15 46/19
properties [5] 46/7 50/4
66/21 69/4 69/5
property [189]
propose [3] 86/13 89/12
128/15
proposed [4] 45/4 45/18
91/18 110/9
proposition [1] 95/2
prosecutor [5] 78/23 79/3
92/23 95/4 98/6
prosecutors [1] 63/21
prove [9] 49/25 79/14 85/14
85/20 92/10 99/23 100/1
100/8 102/21
proved [8] 54/14 57/16 88/12
90/10 90/15 91/2 100/7
103/10
proven [5] 47/17 62/23 66/16
93/2 103/7
provide [3] 33/10 33/13
105/3
provided [12] 6/21 11/22
11/24 14/23 15/14 18/7 19/8
19/16 22/20 24/19 72/23 81/4
public [1] 97/24
publish [3] 11/15 21/16
22/25
pull [6] 23/9 25/9 26/13
27/8 30/20 37/2
pulls [1] 85/6
punctual [1] 127/5
punish [1] 100/4
punishment [3] 48/25 78/24
100/4
punitive [2] 118/8 118/8
purchase [27] 7/8 7/13 7/16
8/2 8/13 8/17 8/21 8/25 9/12
9/23 10/3 10/7 10/11 10/21
36/14 37/3 38/5 55/18 56/20
73/13 75/22 95/18 96/6 99/23
99/25 100/9 120/18
purchased [13] 69/8 69/25
71/1 71/16 76/19 86/8 86/17
88/2 88/25 89/5 89/7 89/22
91/11
purchases [6] 18/16 18/23
19/5 75/24 75/25 86/10
purchasing [1] 73/17
purpose [2] 17/17 71/8
purposes [2] 14/19 41/24
pursuant [9] 42/3 42/6 42/10
52/13 54/12 56/22 57/14
111/6 131/4
put [4] 13/15 82/24 91/1
129/7
putting [2] 80/24 96/14
Q
Quality [1] 22/3
quantity [1] 35/20
question [30] 31/15 33/9
33/11 36/23 40/8 69/1 79/4
88/1 88/12 90/10 97/16 98/3
98/13 102/25 107/12 124/7
124/12 124/13 124/13 124/18
124/20 124/23 124/24 125/4
125/4 125/5 125/5 125/9
125/9 125/9
questions [10] 6/5 22/16
40/7 41/2 79/2 100/21 105/11
125/10 125/20 127/12
quick [1] 101/22
quicker [1] 101/15
quickly [1] 118/3
Quite [1] 77/1
quote [1] 90/4
R
raise [1] 110/23
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raised [1] 58/21
Ram [2] 2/13 102/17
rapidly [2] 75/12 75/19
rather [1] 45/25
re [1] 47/6
re-examine [1] 47/6
reach [1] 58/7
reached [1] 123/23
read [13] 38/12 41/8 41/25
46/1 57/8 71/15 90/7 91/22
118/3 118/6 122/21 122/22
125/24
reading [2] 57/7 124/2
ready [4] 60/21 61/24 62/6
101/14
real [23] 7/3 8/5 8/8 9/12
9/14 9/19 10/21 10/23 50/17
50/24 51/7 52/16 52/24 54/25
56/9 56/10 56/11 65/22 66/20
69/4 79/24 79/25 96/24
really [4] 20/5 90/2 92/11
105/6
Realty [6] 10/15 27/22 27/23
28/3 83/22 97/6
Realty's [2] 28/4 84/1
reason [7] 20/18 50/6 99/3
108/2 117/15 129/22 130/1
reasonable [15] 24/21 48/20
62/19 63/20 63/24 64/3 67/10
70/18 73/14 74/11 76/2 77/5
78/13 102/24 103/1
reasons [4] 57/25 102/19
113/16 114/22
rebuttal [1] 101/17
recall [6] 5/25 6/17 7/2 8/7
9/18 121/24
recalls [1] 5/13
receipt [5] 15/24 90/4 90/12
90/20 93/13
receipts [6] 75/24 75/24
80/7 90/2 91/6 91/14
receive [2] 50/7 102/10
received [11] 11/14 19/25
20/8 20/10 21/15 22/24 31/11
68/10 72/20 122/13 123/22
recently [2] 63/9 112/11
recess [9] 44/18 46/24 60/14
60/16 61/6 62/7 102/2 122/12
123/19
recognize [5] 6/14 11/7 15/6
21/8 72/16
recognizes [1] 59/11
recollection [2] 6/7 29/10
reconsideration [1] 110/2
record [8] 20/22 24/4 33/12
41/8 44/10 44/12 97/25
104/18
records [27] 7/12 8/16 10/2
12/24 14/13 16/9 16/20 19/5
19/14 20/21 21/2 22/13 32/17
33/2 33/6 33/7 33/8 33/9
33/10 34/12 34/18 34/20
72/25 77/10 83/5 85/8 96/8
red [6] 17/14 17/14 65/9
65/11 65/15 67/16
Redline [3] 9/2 10/14 97/2
Redondo [1] 3/21
reduce [1] 40/13
reel [1] 8/3
refer [3] 63/11 63/12 64/15
reference [3] 84/22 102/24
120/20
referenced [1] 120/16
references [1] 40/23
referred [7] 7/3 7/19 8/2
8/8 9/11 9/19 10/20
referring [1] 63/14
reflected [1] 15/3
regard [5] 33/11 45/11
113/23 124/25 129/14
regarding [8] 7/3 8/8 9/19
44/1 47/7 107/1 107/20 129/1
regardless [4] 49/10 49/15
51/13 65/1
Regidor [1] 126/10
regrets [1] 121/25
regulations [1] 131/8
relate [4] 32/11 33/8 90/5
106/22
related [6] 85/9 91/12 93/11
103/18 104/8 105/2
relates [1] 32/12
relating [6] 21/20 64/15
87/9 103/24 105/9 105/15
relationships [1] 117/24
relatively [1] 106/18
relearn [1] 108/6
release [1] 87/11
released [1] 113/15
relevance [1] 59/21
relevant [3] 41/25 59/18
59/20
relies [1] 107/10
rely [1] 77/2
relying [1] 6/7
rem [1] 45/21
remain [4] 51/13 65/1 65/16
92/24
remainder [1] 78/3
remaining [2] 44/6 62/20
remand [7] 111/5 113/17
115/10 115/15 117/10 117/12
130/14
remanded [1] 122/9
remember [10] 64/23 64/25
65/16 74/23 77/22 78/6 78/7
90/20 96/13 118/18
reminded [1] 5/15
removed [5] 52/6 92/4 92/12
92/13 93/24
renewed [1] 58/16
repeat [1] 40/8
repeatedly [1] 109/24
replaced [7] 45/24 52/7 92/4
92/12 92/14 93/5 93/25
replacement [1] 94/1
report [1] 119/4
reported [2] 98/1 131/6
reporter [2] 1/21 31/12
REPORTER'S [1] 1/13
reports [1] 119/8
represent [1] 34/23
representation [1] 128/12
represented [1] 65/11
represents [1] 20/2
request [2] 45/14 45/19
requested [1] 109/24
requesting [1] 118/11
requests [1] 119/10
required [11] 47/18 49/3
52/2 62/23 63/1 64/17 64/22
65/22 66/10 66/17 91/25
requisite [1] 122/24
residence [7] 42/19 42/23
53/10 80/4 94/11 95/8 100/1
Resorts [2] 39/20 40/10
resources [2] 108/5 108/24
respect [19] 31/14 57/23
59/24 73/3 79/22 79/25 79/25
88/4 96/5 96/14 96/19 98/23
106/19 106/20 111/8 111/14
114/20 114/23 127/21
respond [2] 39/24 113/21
response [3] 46/4 105/11
122/17
responsibility [3] 116/22
117/4 117/14
responsive [1] 125/20
rest [1] 29/4
restitution [3] 78/18 78/20
86/25
restroom [1] 60/23
rests [1] 103/21
result [8] 50/18 50/25 51/9
51/12 54/9 54/18 64/20 83/6
resulted [1] 94/18
retained [1] 108/6
retrieve [2] 61/2 62/2
return [2] 6/24 33/1
returned [1] 113/15
returning [1] 73/11
review [22] 7/23 9/7 10/16
11/21 15/8 15/14 16/19 17/3
17/12 18/6 18/19 19/7 19/10
19/12 19/14 19/16 22/7 22/13
33/2 34/19 85/8 118/1
reviewed [17] 6/2 7/12 8/1
8/16 9/10 10/2 10/19 12/23
14/12 15/23 16/9 17/5 21/3
35/4 38/4 39/11 86/22
reviewing [2] 14/22 17/17
Rewards [1] 40/10
Rich [1] 84/23
Richard [40] 1/9 32/3 32/13
38/16 39/7 42/14 43/13 45/14
53/12 72/13 73/7 73/12 74/4
79/22 79/25 80/3 81/3 81/5
81/9 81/16 82/10 82/13 82/19
85/12 94/8 94/10 96/3 102/18
102/23 104/24 111/5 111/8
111/12 113/17 114/23 116/11
117/9 118/24 124/23 124/25
right [57] 23/11 23/14 26/18
28/1 28/8 28/20 29/2 29/12
31/13 33/15 33/23 34/24 35/7
36/9 36/10 36/22 37/18 38/3
38/13 38/21 39/1 44/1 44/17
45/16 46/21 50/16 50/23 51/6
52/15 52/19 52/23 54/24 57/5
59/1 63/19 67/22 80/12 87/1
87/23 94/25 95/8 95/24 96/24
99/2 99/25 100/13 100/15
108/4 110/21 112/20 112/21
116/24 117/16 118/21 121/5
128/4 128/10
right-hand [4] 26/18 28/20
38/13 38/21
righthand [1] 40/16
rights [1] 48/2
risk [9] 111/12 111/14
111/25 113/24 116/1 117/5
118/25 119/21 122/8
risks [1] 59/15
River [2] 68/15 68/15
Road [1] 3/12
ROBINSON [24] 4/4 5/14 5/21
6/14 11/7 21/8 23/6 38/13
41/5 65/6 65/9 67/21 68/9
68/18 69/11 70/12 71/21 72/8
74/14 75/1 80/7 86/22 88/15
94/12
Robinson's [2] 72/18 86/5
role [1] 103/4
roles [1] 117/12
Rolex [6] 42/25 43/15 53/17
53/25 86/17 89/14
Rolexes [2] 72/24 73/2
Romero [9] 23/9 23/19 25/18
26/14 27/13 27/19 38/19 39/4
40/13
room [4] 58/13 59/7 72/2
80/18
rose [2] 42/24 53/15
rough [1] 15/15
roughly [2] 67/18 86/10
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row [1] 25/6
Royal [8] 42/23 43/2 43/3
43/5 53/15 53/19 53/21 53/23
RPR [1] 131/12
Rule [8] 11/13 21/13 128/15
129/1 129/18 129/24 130/4
130/7
ruled [1] 109/25
rules [2] 46/17 59/12
ruling [3] 32/6 106/16 110/2
Runyan [16] 7/21 12/2 12/6
12/10 12/13 12/20 12/22
12/24 42/13 53/7 67/1 67/6
67/17 67/20 67/24 68/3
Runyan's [1] 67/13
Ryan [2] 3/7 102/7
S
Sabala [1] 17/25
safe [1] 113/12
said [8] 33/6 44/14 61/18
84/4 102/18 121/23 124/21
129/8
same [28] 9/3 13/17 52/8
54/23 56/24 57/8 64/17 67/25
68/11 69/15 70/3 70/15 72/10
83/11 83/14 83/17 84/3 90/19
92/6 93/20 97/2 97/6 114/22
119/16 119/24 124/4 127/15
129/24
San [2] 2/21 3/6
Santa [1] 3/15
savings [1] 77/25
saw [19] 34/8 65/8 67/22
71/17 72/10 72/13 75/20
75/24 77/8 77/10 80/7 80/16
81/2 83/9 84/10 84/11 86/4
90/2 121/23
say [40] 17/3 20/10 21/1
24/13 25/2 25/20 26/5 26/25
28/18 28/24 29/11 29/20 30/4
30/6 32/2 32/8 33/2 34/6
35/6 35/12 35/23 38/6 38/22
39/6 40/9 46/16 53/15 60/23
88/10 90/22 92/17 95/5 98/10
99/12 102/1 106/25 109/3
123/8 124/5 125/12
saying [3] 36/6 106/24
109/15
says [9] 16/3 26/21 31/2
31/23 37/3 40/20 41/1 83/24
91/24
SBA [2] 14/10 15/11
schedule [3] 110/9 110/18
129/7
scheduling [1] 128/15
scheme [12] 51/11 51/12
51/21 51/23 51/25 70/6 80/23
82/13 82/23 85/2 85/23
121/14
schemes [4] 67/10 69/16 78/5
93/16
school [1] 119/25
scope [5] 30/18 33/18 39/21
40/4 109/4
SCOTT [1] 2/5
screen [1] 81/25
search [2] 113/12 114/25
searched [2] 113/11 114/25
seated [1] 104/6
second [21] 25/6 40/9 48/23
51/16 58/25 61/2 63/10 75/11
75/18 80/9 87/7 91/15 93/24
98/11 104/1 105/14 106/7
106/23 107/1 107/21 120/15
secondary [1] 97/11
seconds [1] 123/10
section [12] 46/13 50/15
50/22 51/4 54/13 54/23 55/4
57/15 111/6 111/20 113/25
131/4
Sections [1] 51/5
secure [1] 34/10
Secureline [5] 10/14 27/22
83/20 84/1 97/6
security [1] 85/5
see [41] 24/2 24/23 26/18
31/13 37/25 57/5 67/12 67/22
68/10 68/14 69/20 72/18
72/24 73/1 77/9 79/17 80/17
81/6 81/12 81/24 84/22 86/14
86/19 95/14 95/19 95/20 96/9
102/9 102/12 109/17 113/5
116/5 116/16 117/8 119/2
119/19 122/20 125/13 128/6
129/6 129/21
seek [1] 42/4
seeking [13] 66/12 67/4
67/18 68/4 69/4 71/13 72/6
72/21 73/19 73/25 97/14
118/23 118/24
seeks [4] 49/24 52/12 56/21
107/15
seen [14] 65/4 71/16 71/25
72/2 72/6 73/16 73/17 74/7
76/3 76/10 77/6 77/16 78/9
121/13
seize [1] 97/14
seized [28] 41/16 42/6 42/10
42/14 42/16 42/21 43/13 53/2
53/5 53/8 53/11 66/20 66/22
66/25 67/5 67/18 67/19 68/2
68/5 73/25 74/1 74/3 74/9
88/4 90/5 90/14 91/8 91/10
seizure [4] 42/7 42/11 42/18
42/22
select [1] 101/1
sell [1] 92/20
send [2] 59/14 123/17
sense [6] 76/22 76/25 77/2
77/21 78/8 110/11
sent [6] 18/2 20/5 35/3
61/10 123/9 123/10
sentence [5] 50/12 111/15
113/25 115/18 115/23
sentencing [6] 111/2 111/6
113/18 115/20 129/16 130/16
separate [1] 48/8
September [3] 14/15 82/1
130/18
September 28th [1] 14/15
serial [14] 42/24 43/1 43/2
43/4 43/6 43/15 53/16 53/18
53/20 53/22 53/24 53/25
86/16 89/14
series [5] 10/12 12/17 18/14
20/4 102/10
serious [5] 59/16 113/8
114/22 120/5 120/14
served [2] 85/8 97/18
service [10] 7/22 12/7 12/13
12/20 12/24 42/13 53/7 62/15
127/3 127/4
services [3] 12/2 67/1
121/17
SESSION [1] 1/16
set [9] 6/20 42/3 49/18
60/18 60/20 61/25 104/18
108/13 129/16
setting [1] 108/11
Seven [1] 53/11
Seventh [1] 45/9
several [1] 95/4
shall [7] 50/15 50/22 51/5
52/10 54/23 80/8 92/7
shape [1] 120/11
shared [1] 119/13
she [16] 5/15 32/12 32/23
33/20 39/9 39/10 45/14 74/16
74/17 77/9 83/25 88/16 88/16
94/14 103/12 103/13
shield [2] 105/23 107/8
short [2] 108/1 108/9
shortly [1] 112/9
should [15] 47/21 49/9 49/13
49/16 58/4 58/6 61/17 62/3
62/16 72/16 102/19 104/2
108/9 120/15 127/15
shouldn't [2] 59/3 117/1
show [27] 6/9 7/10 8/15 10/1
11/5 13/19 15/19 16/13 16/23
17/19 18/11 19/22 21/6 24/9
25/14 80/8 82/9 83/6 85/25
86/12 86/24 91/21 93/6 93/22
93/25 95/6 95/11
showed [3] 59/13 82/9 121/14
showing [1] 12/4
shown [2] 36/8 86/3
shows [10] 67/19 68/2 69/7
69/25 70/7 70/19 73/20 78/10
112/17 115/2
side [2] 43/21 80/18
sidebar [1] 44/8
sign [2] 58/4 123/15
signator [1] 77/12
signed [5] 28/8 124/7 124/20
125/6 125/11
significant [3] 112/17 119/1
119/2
Silverman [4] 2/22 4/6 23/5
44/11
similar [6] 11/18 15/10 78/4
113/3 113/6 120/22
similarly [2] 47/25 113/24
simple [1] 46/14
simply [3] 31/8 64/4 85/2
since [3] 11/1 21/18 120/8
single [6] 80/5 80/8 84/8
84/25 87/23 94/25
sir [2] 60/25 102/5
sitting [4] 77/24 80/18
84/16 85/10
situation [2] 107/6 118/18
six [3] 53/8 72/5 72/21
sixteen [1] 54/5
slash [3] 79/20 83/20 124/15
slide [19] 23/8 25/6 26/9
26/10 27/3 27/16 27/20 28/11
28/19 30/9 33/1 35/1 35/9
35/17 35/25 36/8 36/12 37/3
62/6
slides [4] 60/15 60/19 61/25
79/18
slightly [1] 27/18
slip [2] 27/9 30/1
so [127]
sole [4] 48/11 48/25 62/22
122/23
solely [2] 47/12 47/17
Solutions [2] 22/2 22/6
some [40] 6/24 20/20 33/10
36/3 44/3 45/8 45/11 48/3
56/19 58/23 59/25 60/18 62/2
67/24 70/24 71/1 71/6 72/10
73/3 76/20 80/16 81/6 97/9
101/23 102/1 104/18 105/5
105/18 108/17 112/19 112/19
113/13 116/7 117/22 121/20
124/14 127/12 129/22 130/2
130/9
somebody [1] 24/13
somehow [1] 93/24
someone [4] 77/3 85/22
104/20 126/24
something [10] 34/7 59/3
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something... [8] 61/2 91/7
92/21 95/15 99/2 108/25
109/7 120/7
sometimes [2] 34/12 127/7
somewhat [1] 109/22
somewhere [1] 97/10
soon [4] 49/23 62/3 102/9
129/25
sorry [5] 16/2 32/1 36/12
59/1 62/4
sort [2] 36/23 104/18
sought [3] 47/18 49/4 62/24
sound [1] 107/11
sounds [2] 36/22 62/21
source [6] 7/19 7/20 8/24
10/10 82/4 82/6
sources [10] 19/20 20/6 36/3
36/3 36/5 37/13 37/25 39/13
82/19 95/23
speak [8] 6/11 79/15 107/5
113/19 116/15 118/1 118/2
121/7
speaking [1] 44/13
speaks [2] 106/1 110/14
Spear [1] 2/20
special [3] 50/9 57/22 58/5
specific [36] 28/15 29/9
37/22 41/12 42/5 45/18 49/23
52/3 62/17 72/2 78/25 79/1
79/10 79/11 86/2 87/3 87/14
87/16 88/1 88/21 88/22 89/17
89/22 91/25 95/7 96/17 98/11
98/24 99/23 100/14 100/22
101/2 102/11 108/8 109/4
122/25
specifically [10] 32/21
32/23 36/4 36/18 45/19 62/15
69/22 71/11 73/25 87/22
specified [1] 55/13
speculate [1] 110/5
speculation [2] 24/15 39/14
spend [1] 91/5
spending [1] 98/17
spent [1] 71/19
split [1] 120/15
splitting [1] 118/19
spoke [1] 65/18
spoken [1] 119/11
spouse [1] 115/19
spreadsheets [1] 19/10
Spring [1] 2/6
Springs [1] 52/25
stage [2] 77/23 111/9
stainless [4] 42/25 43/5
53/17 53/23
stand [1] 93/11
standard [4] 63/25 63/25
79/12 111/11
start [12] 51/15 56/17 61/15
78/1 80/1 81/11 81/18 81/21
81/22 81/23 82/20 109/2
started [1] 89/18
starting [1] 17/22
state [5] 112/8 112/23
114/14 119/12 120/21
stated [1] 127/20
statement [11] 15/9 15/9
24/3 38/12 38/15 39/20 40/11
40/18 40/19 40/22 40/23
statements [5] 14/23 29/5
34/4 105/2 105/9
states [27] 1/1 1/4 1/6 2/3
15/11 38/24 38/25 42/14
46/13 46/14 46/17 50/14
50/21 51/3 51/5 54/12 54/12
54/20 54/22 55/5 57/14 57/14
57/21 106/4 118/15 131/5
131/9
statute [1] 46/11
statutes [1] 46/18
stay [1] 64/25
steel [4] 42/25 43/5 53/17
53/24
stenographically [1] 131/6
step [1] 13/5
STEPHEN [1] 1/3
steps [1] 77/1
Steptoe [4] 2/14 2/17 2/19
2/22
still [10] 5/15 58/10 62/1
92/10 93/6 93/25 110/10
112/3 112/5 114/11
stipulate [1] 41/22
stipulation [6] 41/7 41/17
41/18 41/22 41/23 43/19
stood [2] 102/16 120/6
stopped [3] 73/10 74/5 77/13
store [2] 90/22 92/18
stores [1] 90/3
Street [5] 1/22 2/6 2/14
2/20 3/8
stricken [1] 60/11
strike [3] 29/5 52/25 59/10
strongly [1] 113/13
studs [4] 43/18 54/6 90/9
90/13
study [1] 129/12
subject [45] 41/12 41/21
47/23 48/4 48/13 49/20 49/22
50/1 50/5 50/10 51/10 51/22
52/10 54/11 55/3 55/6 55/11
56/2 57/13 57/24 58/3 66/3
85/19 85/24 86/14 87/4 87/24
88/4 89/3 89/11 89/12 91/18
92/8 94/6 94/24 95/7 97/15
99/7 99/13 99/15 99/18
100/22 106/16 106/18 123/4
submission [2] 107/19 120/17
submit [6] 90/16 93/9 96/18
99/6 103/19 122/5
submitted [2] 41/10 101/7
subpoenas [1] 85/7
subsequent [1] 14/9
substance [1] 109/18
substantial [3] 28/24 111/15
113/24
such [20] 15/3 21/23 29/14
33/13 34/19 48/7 49/25 50/1
51/20 51/25 52/6 54/20 55/1
55/2 55/8 56/3 57/18 57/20
65/23 92/3
suddenly [1] 77/25
sufficiency [1] 130/6
suggest [2] 82/23 130/2
suggestion [3] 101/13 109/23
129/18
suggests [1] 113/13
Suite [8] 1/22 2/15 2/20 3/5
3/8 3/13 3/16 3/21
suited [1] 77/18
sum [1] 20/7
summarize [4] 17/22 19/19
21/25 67/21
summarized [1] 21/2
summarizes [3] 18/14 19/3
22/1
summarizing [5] 15/21 16/15
16/25 18/13 20/11
summary [20] 6/20 6/25 11/2
11/12 11/18 15/22 16/16 17/1
19/4 19/7 19/23 19/25 21/13
21/23 23/11 65/4 65/7 68/9
72/18 82/24
sums [1] 20/1
SUN [1] 2/5
superseding [5] 42/4 49/19
106/23 107/2 107/22
supervision [3] 119/3 119/14
119/16
supplemental [1] 47/15
supposed [1] 20/15
suppressed [3] 105/16 105/17
105/19
sure [5] 24/21 29/8 35/25
100/6 105/6
surety [1] 119/2
surface [1] 106/14
surveillance [1] 85/5
surveilled [1] 80/14
survey [1] 110/12
suspected [1] 74/22
sustained [4] 32/24 33/20
39/15 75/17
SVW [1] 1/8
sword [2] 105/22 107/8
sworn [1] 58/10
sympathy [1] 47/13
synthesize [1] 94/13
T
table [5] 84/17 85/10 101/25
107/1 110/6
tainted [6] 71/7 74/22 75/4
76/5 76/12 76/14
take [14] 39/3 44/4 46/21
61/3 83/7 100/7 100/10
101/15 101/18 101/22 101/23
101/24 102/16 106/25
taken [5] 48/8 94/20 112/4
115/2 121/20
takes [1] 29/12
Taking [1] 13/5
talk [5] 66/24 82/22 85/16
86/2 89/15
talked [2] 85/5 87/5
talking [6] 20/23 36/2 80/12
80/21 92/16 120/6
talks [2] 107/7 107/9
Tamara [9] 27/22 28/3 83/20
97/6 115/10 115/16 116/20
116/21 117/8
Tami [1] 84/23
tapes [1] 85/6
Tarzana [4] 42/19 42/22
52/17 53/10
task [4] 32/15 48/11 49/1
62/20
tasked [1] 14/25
tax [12] 7/21 12/2 12/7
12/13 12/20 12/22 12/24
39/20 40/10 42/13 53/7 67/1
teaching [1] 109/3
tech [4] 81/11 82/3 82/20
96/4
teens [1] 116/18
telephone [1] 114/4
telephones [2] 105/16 105/16
tell [10] 60/24 61/14 76/22
88/19 90/6 93/11 102/17
104/20 109/12 127/11
telling [1] 110/19
ten [2] 53/19 83/12
TERABELIAN [21] 3/3 32/4
32/10 33/4 38/16 42/15 43/14
45/14 53/13 74/5 96/3 97/12
101/8 102/8 102/19 102/22
103/9 103/16 104/24 115/16
125/8
Terabelian's [1] 77/8
term [1] 13/6
terms [7] 33/8 86/12 89/25
106/13 110/8 112/14 122/14
testified [11] 6/25 11/18
23/10 27/25 32/2 32/8 37/6
39/5 81/22 119/9 122/5
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testify [7] 5/23 65/9 71/21
72/12 74/14 90/21 121/12
testifying [1] 6/17
testimony [29] 5/25 6/3 6/6
6/7 7/2 7/7 8/8 8/12 9/16
9/18 9/22 11/1 14/20 15/17
21/18 28/1 32/16 40/4 47/11
60/5 65/6 86/5 90/24 91/1
91/9 91/10 94/13 95/20 105/1
text [6] 17/14 19/12 80/20
84/23 84/23 84/25
than [37] 39/1 48/6 48/7
48/9 49/9 50/6 62/21 64/6
64/9 66/1 67/17 68/23 71/19
73/12 74/7 74/18 75/3 77/16
77/23 77/24 78/2 79/14 84/21
90/18 91/3 98/18 99/15
100/24 100/25 101/15 102/11
102/16 102/22 103/6 103/11
108/11 108/22
thank [23] 5/9 6/13 18/6
27/13 41/5 44/7 61/5 61/24
78/14 101/4 101/19 102/6
110/22 121/6 121/10 122/10
122/11 127/4 127/9 128/1
128/12 128/13 129/15
that [657]
That's [6] 14/21 15/2 112/21
114/18 114/18 117/11
theft [6] 64/13 111/19
112/23 113/1 114/1 120/20
their [23] 61/12 62/17 73/17
75/4 75/12 75/19 76/19 76/23
77/4 77/15 77/20 85/13 91/2
95/8 104/25 105/23 116/9
116/13 116/15 119/24 119/24
119/25 127/20
them [28] 16/18 20/18 28/9
37/23 59/1 60/20 62/19 63/14
64/17 65/6 65/8 72/1 72/22
74/10 76/6 77/10 77/18 78/2
80/15 80/15 80/24 80/25
81/11 101/24 113/14 124/2
125/17 129/24
then [46] 9/4 12/20 14/8
18/3 20/4 23/16 27/19 27/19
28/4 31/24 44/5 44/6 44/23
46/22 51/17 58/3 58/5 60/11
61/3 77/18 78/2 85/18 87/4
93/3 94/19 98/10 98/13 98/24
99/6 100/25 101/16 101/17
101/19 103/22 108/9 108/11
108/20 113/15 113/15 113/19
114/13 115/24 118/1 122/22
123/15 124/11
theory [1] 81/1
there [114]
therefore [2] 54/11 57/13
these [43] 6/25 15/23 16/19
16/20 17/9 22/7 22/14 22/20
23/15 28/7 28/11 28/14 35/3
47/15 49/14 57/9 64/22 69/1
69/5 69/15 70/9 70/15 70/21
71/16 71/21 72/7 74/9 74/15
74/22 75/11 75/24 76/4 77/7
77/13 77/17 79/18 83/4 83/6
84/18 87/19 91/11 107/5
109/4
they [58] 23/16 34/7 34/10
58/13 58/14 59/7 65/3 65/15
69/13 70/2 70/14 72/22 73/10
74/5 76/5 76/19 79/21 80/14
80/15 80/15 82/24 83/7 84/4
84/6 84/24 84/24 85/18 85/24
87/20 88/12 88/15 90/3 90/15
91/1 91/2 93/22 94/15 95/4
95/11 97/15 99/24 100/1
100/8 116/17 118/22 118/24
119/22 119/24 121/17 121/20
121/23 124/2 125/16 125/19
127/20 128/18 129/1 129/3
THIBODEAUX [2] 1/21 131/12
thing [12] 83/11 83/14 83/17
90/19 95/19 95/19 97/2 97/6
116/10 120/5 120/16 127/10
things [8] 60/15 92/9 92/11
108/5 110/7 127/7 129/7
130/10
think [30] 33/12 33/13 44/22
61/15 73/9 85/10 94/21
100/24 101/14 105/6 106/19
107/13 108/6 108/10 108/13
109/2 110/11 116/1 116/2
116/23 117/4 117/12 121/1
122/6 122/8 123/9 129/6
129/23 130/11 130/13
thinking [1] 109/2
third [9] 9/4 26/10 34/5
48/1 48/2 76/8 99/14 99/17
112/16
third-party [1] 34/5
Thirteen [1] 53/25
this [229]
Thomas [1] 3/14
those [43] 7/19 7/20 8/24
10/10 10/19 11/18 16/17
18/22 20/7 20/25 22/13 29/12
34/3 36/17 38/8 55/16 57/4
63/12 63/18 64/15 64/16 65/3
65/14 65/15 66/23 67/2 67/19
70/18 72/10 74/16 78/11
80/17 84/25 88/6 97/13 97/14
97/15 100/7 113/3 113/16
115/2 115/5 130/15
though [3] 23/13 113/11
114/17
thought [4] 39/25 61/18
109/6 109/8
thoughts [2] 109/9 109/13
thousand [6] 75/21 92/21
92/22 93/2 97/11 99/2
thousands [2] 72/14 75/23
threat [2] 121/22 122/1
three [17] 9/1 12/17 20/5
52/23 55/9 66/20 69/4 69/5
71/20 94/6 99/11 100/4
108/25 116/11 119/21 128/16
130/12
through [21] 9/2 10/13 12/19
12/21 18/22 35/16 35/20 36/1
36/4 37/23 46/11 52/14 56/1
61/9 65/6 68/11 80/9 86/19
96/6 110/13 118/9
throughout [1] 80/13
ticket [2] 25/22 30/4
tie [1] 79/10
tied [3] 87/16 88/14 88/20
till [1] 130/12
time [14] 29/7 29/20 44/3
55/16 61/25 91/5 102/1
102/16 108/6 108/16 109/2
118/19 122/3 128/19
Timeland [1] 95/25
Timeline [3] 10/13 18/15
35/10
Timepiece's [1] 20/3
Timepieces [21] 18/16 19/4
19/8 19/17 20/1 20/5 20/8
20/11 20/12 20/21 21/2 35/4
35/11 35/16 35/21 72/10
72/20 73/1 86/7 86/21 88/5
times [8] 14/24 51/14 63/20
65/1 88/18 95/4 101/4 119/11
title [16] 50/14 50/16 50/21
50/23 51/3 51/4 51/6 52/16
52/20 52/23 54/12 54/22
54/24 55/4 57/14 131/4
today [15] 6/5 63/2 63/4
63/9 64/11 65/5 66/12 66/16
78/4 80/2 90/22 94/9 94/12
107/18 109/16
together [2] 47/12 116/6
token [1] 127/15
told [4] 60/22 88/16 92/23
94/17
Tom [1] 121/11
too [1] 114/13
took [2] 55/16 122/3
top [9] 20/1 20/14 22/3
23/20 23/21 38/13 38/20 90/7
123/14
Topeka [18] 9/20 10/3 10/7
10/11 10/24 38/17 70/11
70/14 70/19 70/25 74/3 76/10
76/17 85/13 91/8 91/9 91/11
94/11
total [10] 20/7 20/8 35/6
35/22 36/24 40/15 40/24
65/10 72/19 121/16
towards [1] 18/22
Tower [1] 2/20
towing [11] 10/13 13/22 14/3
14/8 15/13 15/13 42/9 53/4
67/2 96/2 121/25
trace [13] 7/7 8/12 9/23
12/5 13/20 18/8 21/19 28/14
32/13 36/17 37/12 37/14
51/24
traceable [36] 17/9 17/13
17/15 28/17 28/21 36/25
51/23 55/1 55/25 56/3 56/15
56/18 57/11 57/18 65/11
69/20 71/1 71/3 71/5 71/22
73/22 74/18 79/5 80/4 84/6
85/20 86/6 86/9 86/10 88/9
89/1 92/24 94/14 94/18 98/10
100/17
traced [16] 14/20 15/16
18/16 35/13 35/15 35/20 36/5
36/6 36/21 37/18 56/12 75/1
79/11 86/21 95/17 107/25
tracing [16] 12/15 14/5 15/1
21/23 32/11 32/17 32/20
33/21 35/14 36/1 37/23 38/2
74/15 86/12 86/15 100/14
transaction [31] 15/6 15/10
16/2 17/22 36/7 55/12 55/15
55/16 55/21 55/22 56/9 68/19
75/1 75/7 75/8 80/9 82/25
83/16 83/21 89/3 95/9 95/22
97/24 98/14 98/17 98/18
98/20 98/25 99/5 99/20
121/25
transactions [11] 14/24
21/20 34/4 34/6 34/8 34/10
55/7 71/18 72/13 83/6 91/12
transcript [15] 1/13 6/2
30/22 31/2 31/10 31/11 31/23
59/14 59/15 59/18 59/22 60/2
60/7 131/6 131/7
transfer [7] 22/8 35/10 52/1
69/21 69/21 73/5 75/21
transferred [12] 18/20 45/25
48/1 59/25 65/10 67/13 67/23
69/12 70/1 70/13 72/9 72/15
transfers [6] 18/8 70/9
70/22 95/14 96/19 97/10
Transport [8] 10/13 13/22
14/3 15/13 18/15 42/9 53/4
95/25
trash [1] 85/6
travel [2] 112/12 120/3
traveler [1] 112/11
treatment [1] 118/13
tria [1] 114/2
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T
trial [42] 1/15 5/23 6/6
6/18 7/1 11/19 25/10 28/1
37/6 41/11 41/23 49/14 63/3
63/8 63/10 63/17 63/21 65/5
67/3 69/6 72/17 78/10 80/2
80/13 80/16 81/9 81/10 81/22
102/12 103/14 104/23 107/4
107/23 110/1 111/16 111/22
114/5 116/25 116/25 118/9
118/24 119/9
tried [1] 80/6
trip [1] 122/3
Trucking [1] 67/1
true [8] 35/18 49/9 49/9
64/9 92/25 95/2 120/22 131/5
trust [2] 77/7 128/5
truthfully [1] 122/6
try [1] 22/10
trying [5] 33/12 37/23 88/3
99/24 115/25
Turing [2] 22/1 22/6
Turks [7] 73/11 86/8 86/17
88/25 98/21 99/1 120/3
turn [1] 108/10
turnaround [1] 108/1
turning [1] 21/22
turnover [1] 120/9
Twelfth [1] 2/6
Twelve [1] 53/23
twice [1] 50/7
two [36] 7/20 9/1 10/14 20/7
20/25 43/7 46/7 48/15 52/19
55/8 57/4 59/13 63/16 66/20
66/25 71/12 71/22 72/24 79/2
81/13 81/17 82/2 86/13 89/11
92/11 98/7 98/8 98/16 105/7
106/3 107/13 110/7 111/18
115/14 116/2 116/12
type [1] 107/6
typed [2] 122/19 123/8
Typically [1] 34/8
U
U.S [4] 1/21 2/4 2/4 108/24
U.S.C [1] 46/11
ultimately [2] 12/22 18/16
unaccounted [3] 112/3 112/6
114/12
unanimous [4] 47/14 58/1
58/7 123/24
unclear [3] 31/7 90/16
104/10
under [20] 5/16 11/12 20/15
21/13 31/21 32/3 32/9 48/13
50/13 50/20 51/2 54/21 60/5
111/20 119/4 119/6 119/14
119/15 127/16 127/24
underlying [4] 55/13 56/5
70/8 70/20
underscore [1] 119/1
understand [6] 60/10 61/21
104/15 110/9 120/23 130/10
understanding [3] 13/8
107/21 127/20
undisputedly [1] 95/16
unfair [1] 110/5
unhelpful [1] 110/6
UNITED [21] 1/1 1/4 1/6 2/3
42/13 50/14 50/21 51/3 51/5
54/12 54/12 54/20 54/22 55/5
57/14 57/14 57/21 106/4
118/15 131/5 131/9
UNK [1] 20/15
unknown [2] 20/16 20/19
unlawful [1] 55/14
unless [1] 93/22
unlike [1] 70/24
unquote [1] 90/4
unrelated [2] 81/7 94/16
unremarkable [1] 80/22
untainted [4] 56/19 71/6
75/4 77/25
untraced [1] 37/10
unzoom [1] 24/22
up [39] 6/11 23/9 24/1 25/9
26/13 27/8 30/20 31/25 35/25
37/2 38/10 39/16 40/21 60/18
60/20 61/25 66/7 68/12 75/15
81/21 81/23 82/1 82/24 85/12
86/18 88/5 88/8 89/13 89/16
91/3 93/10 94/4 100/20
101/23 102/16 102/17 109/1
117/22 123/2
up's [1] 81/23
upon [2] 64/11 129/1
ups [3] 81/11 81/18 82/20
upstream [1] 99/24
us [9] 2/9 14/8 42/16 53/8
53/11 62/5 62/13 68/11 110/4
USC [1] 46/12
use [13] 57/23 77/8 77/17
92/17 95/17 105/20 107/7
107/25 110/15 112/7 113/4
121/23 130/3
used [32] 7/13 7/15 8/2 8/17
8/20 8/24 9/12 10/3 10/6
10/20 22/8 51/17 55/8 55/14
55/20 55/22 56/8 56/20 66/4
66/5 69/13 70/2 70/14 73/12
73/18 75/6 75/9 76/13 76/18
81/10 98/19 105/22
usher [1] 58/12
using [5] 73/6 92/18 99/1
111/20 114/1
usual [2] 101/15 130/16
V
vacation [2] 112/13 120/3
vague [1] 93/13
VAHE [6] 3/18 87/8 96/14
103/18 103/18 124/6
value [1] 99/16
Vargas [1] 125/25
various [2] 42/18 53/9
vary [1] 24/18
vast [2] 82/25 84/7
Vaughan [1] 3/7
Vegas [1] 82/10
Ventures [2] 77/11 96/3
verdict [25] 45/15 47/12
47/14 49/15 50/9 57/22 58/2
58/5 58/7 86/14 98/5 99/10
102/10 104/2 104/10 104/12
104/13 123/24 123/25 124/4
124/6 125/12 125/20 125/24
125/24
versus [2] 106/4 106/8
very [18] 6/24 40/15 61/12
61/14 62/3 67/25 72/10 78/4
83/25 90/3 93/12 108/8 110/4
112/11 112/15 113/3 121/16
127/5
Victoria [1] 9/5
view [1] 45/7
viewed [1] 130/5
views [1] 127/22
vigorous [1] 128/12
violation [11] 51/4 55/4
55/8 55/9 55/18 56/8 56/10
56/14 107/22 107/25 121/18
violations [8] 50/14 50/21
51/3 54/10 54/18 54/22 57/12
57/19
virtue [1] 98/12
VOLUME [1] 1/16
voluntarily [1] 41/18
Voyage [2] 7/21 12/19
W
W-O-O-D-F-O-R-D [1] 106/9
W44P7238 [3] 43/16 54/1
89/14
wait [4] 32/6 46/23 58/25
58/25
waiting [2] 62/1 130/12
waived [1] 104/25
waiver [9] 58/22 106/2
106/15 106/15 106/18 108/18
109/5 109/5 109/23
waives [1] 105/23
waiving [1] 107/9
walk [1] 86/19
want [13] 24/18 45/12 59/4
63/18 91/21 101/24 102/15
108/20 109/7 116/19 125/13
127/9 129/7
wanted [2] 104/14 104/15
wants [1] 110/9
warrant [5] 42/7 42/11 42/18
42/22 130/6
was [186]
Washington [2] 2/10 2/23
wasn't [13] 20/24 28/5 35/18
80/10 80/18 80/25 83/10 85/2
85/3 88/16 96/17 112/20
121/23
watch [12] 43/15 53/25 86/8
86/10 86/16 88/14 88/22
88/25 89/4 89/7 90/5 98/22
watched [1] 80/15
watches [20] 66/22 71/11
72/5 72/11 72/22 73/3 73/21
75/23 76/15 79/20 85/16
85/17 85/20 85/22 86/4 86/13
88/5 88/6 89/12 99/1
way [10] 28/18 33/9 33/10
33/21 38/8 64/16 80/22 84/20
94/21 107/20
ways [2] 55/12 76/6
we [135]
weapons [1] 121/22
wears [1] 119/17
weekend [1] 109/17
weeks [6] 81/13 81/17 82/2
128/16 130/12 130/17
well [48] 9/3 12/19 14/10
22/4 29/11 30/20 31/1 31/9
35/15 44/25 49/14 61/3 63/4
63/8 63/23 64/6 64/11 64/14
65/3 65/12 66/3 66/15 66/22
68/1 68/24 72/8 74/3 81/23
82/12 86/22 92/11 99/14
105/23 106/19 107/17 108/20
112/24 113/20 114/11 114/14
115/1 115/24 115/25 117/13
117/15 117/23 122/22 129/6
Wells [2] 16/5 83/16
went [10] 10/10 34/1 86/6
94/14 94/22 94/25 116/25
118/9 118/24 121/15
were [113]
weren't [1] 77/15
West [4] 1/22 2/14 3/8 106/7
WESTERN [1] 1/2
what [101]
whatever [3] 48/12 99/24
121/15
whatsoever [2] 119/14 127/16
when [28] 13/10 20/10 21/1
34/6 38/2 44/13 49/6 50/12
63/2 63/13 68/24 72/23 73/7
74/5 77/17 92/16 99/4 99/9
101/1 102/9 103/13 107/9
107/9 109/16 113/10 114/24
119/11 121/2
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where [13] 39/7 46/9 46/15
46/19 69/13 70/2 70/14 71/19
76/8 81/3 86/19 98/18 124/5
wherever [1] 65/15
whether [22] 17/8 29/24
32/12 47/17 47/22 48/11 49/1
50/1 57/24 58/2 62/23 66/16
68/23 90/15 91/9 92/11 93/4
93/18 102/25 103/5 117/5
122/23
which [100]
while [8] 47/5 58/20 100/3
105/10 110/10 113/17 123/2
130/10
white [4] 43/17 54/5 90/9
90/13
who [13] 16/7 24/2 49/15
62/2 77/18 83/1 97/25 118/15
118/22 119/8 119/9 122/7
127/25
whole [3] 51/23 85/24 119/25
whom [2] 96/11 115/14
why [9] 59/17 76/22 77/3
77/18 95/12 98/3 98/4 128/20
129/22
wife [1] 121/15
will [70]
Williams [2] 3/4 3/7
willingness [1] 112/12
WILSON [2] 1/3 123/16
win [2] 40/15 40/24
win/loss [2] 40/15 40/24
winnings [2] 34/12 34/23
wire [6] 52/1 64/12 64/13
73/4 73/12 73/18
Wirsching [1] 3/12
Wise [1] 20/6
wish [2] 101/5 101/10
withdrawal [3] 29/2 29/7
84/8
withdrawals [13] 17/1 18/5
23/13 29/16 29/21 30/10
30/11 34/7 39/6 74/18 80/20
84/14 85/9
withdrawing [1] 80/21
withdrawn [8] 9/17 15/16
16/20 17/4 17/9 18/4 23/11
75/16
withdrew [3] 33/17 33/21
59/25
within [2] 98/15 110/20
without [5] 7/6 8/11 47/13
61/17 112/1
witness [10] 4/3 5/15 11/5
21/6 22/16 40/3 65/7 68/9
119/9 121/23
witnesses [2] 41/7 47/11
won't [3] 83/3 110/3 122/21
Woodford [1] 106/8
word [1] 16/18
words [5] 33/7 63/19 95/24
96/21 106/24
work [3] 82/20 119/18 121/18
worked [1] 80/23
working [2] 81/18 120/25
works [2] 30/12 81/11
world [2] 99/20 119/22
would [78]
wouldn't [1] 128/25
wrap [1] 94/4
wristwatch [10] 42/24 42/25
43/2 43/4 43/5 53/15 53/18
53/20 53/22 53/24
write [3] 99/16 123/2 123/14
writing [2] 122/21 128/23
written [2] 16/18 83/13
wrong [1] 30/2
Y
yard [3] 76/21 79/15 88/13
Ybanez [4] 119/8 119/10
119/11 119/12
year [5] 38/7 40/18 40/24
111/18 118/18
years [2] 112/19 121/3
yellow [2] 43/16 54/3
yes [148]
yet [3] 106/1 108/19 109/18
yield [1] 80/10
York [3] 2/10 2/18 75/22
you [540]
younger [1] 116/17
your [181]
yourself [3] 77/24 78/2 96/9
yourselves [1] 110/19
Z
zero [1] 28/16
Zhadko [17] 16/3 16/5 16/8
16/9 16/11 22/3 25/7 25/12
26/3 26/6 27/6 73/6 83/11
83/16 87/22 96/21 96/23
zoom [6] 23/20 24/7 27/18
35/10 38/19 39/19
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