Court filing
First Notice of Motion and Motion to Continue Date to Surrender to Bop — USA v. Ayvazyan et al. (Dkt. 1206, C.D. Cal.)
Filed December 13, 2021 in USA v. Ayvazyan et al.; one of 233 filings from this case.
Record facts
| Court | U.S. District Court for the Central District of California |
|---|---|
| Filed | 2021-12-13 |
U.S. District Court for the Central District of California · No. 2:20-cr-00579-SVW · Doc. 1206 · 2021-12-13 · Docket on CourtListener
Full text
1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 Thomas A. Mesereau Jr., Mesereau Law Group P.C. 10100 Santa Monica Blvd. Suite 300 Los Angeles, CA 90067 310-651-9960 mesereau@mesereaulaw.com Jennifer J. Wirsching Attorney at Law 1935 Alpha Rd, Suite 216 Glendale, CA 91208 424-902-9280 wirschinglaw@outlook.com Counsel for Artur Ayvazyan UNITED STATES DISTRICT COURT CENTRAL DISTRICT OF CALIFORNIA UNITED STATES OF AMERICA, Plaintiff, v. ARTUR AYVAZYAN Defendant. Case No. 20-CR-00579-SVW ARTUR AYVAZYAN’S MOTION TO CONTINUE THE DATE FOR SURRENDER TO THE BUREAU OF PRISONS (No Hearing Requested) Artur Ayvazyan, by and through counsel, hereby move this Honorable Court to extend the surrender date of January 3, 2022 to March 5, 2022. On November 15, 2021 Artur Ayvazyan was sentenced to 60 months in prison. The Court ordered a surrender date of January 3, 2022. On December 6, 2021, the Court sentenced Artur Ayvazyan’s wife Tamara Dadyan to 130 months in prison. Tamara Dadyan was ordered to surrender on or before January 5, 2021. Artur Ayvazyan requires more time to get his family’s affairs in order before his children lose both of their parents for several years. Additionally, Artur Ayvazyan’s oldest daughter, A. Ayvazyan, has had some bloodwork come back Case 2:20-cr-00579-SVW Document 1206 Filed 12/13/21 Page 1 of 4 Page ID #:19281 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 with anomalies. Children’s Hospital Los Angeles’s Children’s Center for Cancer and Blood Diseases will be performing bloodwork to determine the cause of the problems. The results are expected on March 3, 2022. AUSA Ahn has advised that the Government opposes this motion. Dated: December 13, 2021 Respectfully submitted, /s/ Jennifer J. Wirsching _____ Jennifer J. Wirsching Counsel for Artur Ayvazyan // // // // // // // // // // // // // // // // // Case 2:20-cr-00579-SVW Document 1206 Filed 12/13/21 Page 2 of 4 Page ID #:19282 2 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 DECLARATION OF JENNIFER J. WIRSCHING 1. I, Jennifer J. Wirsching, an attorney licensed to practice law before all the courts of the State of California, the Central District of California, the Eastern District of California, the Northern District of California, the Southern District of California, the District of Colorado, the Ninth Circuit Court of Appeals, the Tenth Circuit Court of Appeals, am one of the attorneys of record for Artur Ayvazyan. 2. Artur Ayvazyan was sentenced to 60 months in the Bureau of Prisons. 3. The Court ordered Ayvazyan to surrender no later than January 3, 2022. 4. Artur Ayvazyan’s wife, Tamara Dadyan was sentenced on December 6, 2021 to 130 months’ imprisonment. 5. Tamara Dayan has been ordered by the Court to surrender on or before January 5, 2022. 6. Artur Ayvazyan and Tamara Dadyan share two daughters, A. Ayvazyan and N. Ayvazyan. 7. I am informed and believe that Artur Ayvazyan requires more time to settle the family’s affairs prior to both parents being imprisoned. 8. I am informed and believe that Artur Ayvazyan’s daughter A. Ayvazyan has had irregular blood test results, and that tests will be performed at Children’s Hospital Los Angeles to discover the source of the problem. 9. I am informed and believe that the results of this testing will not be available until March 3, 2022. 10. I am informed and believe that Artur Ayvazyan needs to ensure his daughter’s health is taken care of prior to surrender. 11. I emailed AUSA Catherine Ahn on December 11, 2021 and advised her of this motion and asked to know if the Government would oppose the motion or not. 12. AUSA Ahn advised me that the Government opposes this request. Case 2:20-cr-00579-SVW Document 1206 Filed 12/13/21 Page 3 of 4 Page ID #:19283 3 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 13. I have personal knowledge of the facts stated above unless stated as made upon information and belief. I declare under penalty of perjury that the foregoing is true and correct. December 13, 2021 /S/Jennifer J. Wirsching Jennifer J. Wirsching Attorney for Artur Ayvazyan Case 2:20-cr-00579-SVW Document 1206 Filed 12/13/21 Page 4 of 4 Page ID #:19284
File and source
- File
- gov.uscourts.cacd.802533.1206.0.pdf
- Size
- 158,008 bytes
- SHA-256
- 6186ad4de43d0906770ddde99824868f50d41709b761e1bbb4e2b9ba4868b1a2
- Original
- storage.courtlistener.com