Second Notice of Motion and Motion to Continue — USA v. Ayvazyan et al. (Dkt. 1216, C.D. Cal.)

Record facts

U.S. District Court for the Central District of California · No. 2:20-cr-00579-SVW · Doc. 1216 · 2021-12-22 · Docket on CourtListener

Full text

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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 
SECOND 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. Specifically, Artur 
Ayvazyan’s disabled mother Zhaneta Momdzayan has lost her caretaker, and 
Case 2:20-cr-00579-SVW     Document 1216     Filed 12/22/21     Page 1 of 4   Page ID
#:19433

 
 
 
 
 
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Artur Ayvazyan has had to step in to provide her care until another caretaker can 
be found. Efforts to find a caretaker since the prior caretaker quit in November 
have not been successful – due in part to the holiday season. Ms. Momdzayan 
has diabetes, is blind in one eye, has little sight left in the remining eye, has high-
blood pressure, nerve damage, stomach issues, and requires extensive daily care. 
She must be provided with multiple medications and supplements over the 
course of each day to keep her health in check.  She also requires someone to 
bathe her, feed her, do her shopping. As Richard Ayvazyan cannot be located, 
Artur Ayvazyan is the only child Ms. Momdzayan has left to see to her care. 
AUSA Ahn has advised that the Government opposes this motion.  
 
Dated: December 22, 2021 
 
 
 
Respectfully submitted,  
 
 
 
 
 
 
 
 
 
 
 
 
 
/s/ Jennifer J. Wirsching _____     
 
 
 
 
 
 
Jennifer J. Wirsching 
 
 
  
 
Counsel for Artur Ayvazyan 
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Case 2:20-cr-00579-SVW     Document 1216     Filed 12/22/21     Page 2 of 4   Page ID
#:19434

 
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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. 
Zhaneta Momdzayan is Artur Ayvazyan and Richard Ayvazyan’s 
 
mother. 
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 mother Ms. 
 
Momdzayan suffers from diabetes as well as other medical issues. 
9. 
I am informed and believe that Artur Ayvazyan’s mother Ms. 
 
Momdzayan has lost her vision in one eye and has limited vision in 
 
the other eye. 
10. 
I am informed and believe that Artur Ayvazyan’s mother Ms. 
 
Momdzayan’s caretaker quit in mid-November. 
11. 
I am informed and believe that Artur Ayvazyan’s mother Ms. 
 
Momdzayan requires someone to provide her medications and 
 
supplements to her multiple times per day. 
12. 
I am informed and believe that Artur Ayvazyan has been taken over 
 
the care of his mother since her caretaker left her job. 
Case 2:20-cr-00579-SVW     Document 1216     Filed 12/22/21     Page 3 of 4   Page ID
#:19435

 
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13. 
I am informed and believe that Artur Ayvazyan’s care includes the 
 
bathing, feeding, shopping, providing medications and supplements 
 
for his mother. 
14. 
I emailed AUSA Catherine Ahn and advised her of this motion and 
 
asked to know if the Government would oppose the motion or not. 
15. 
AUSA Ahn advised me that the Government opposes this request.  
 
16.  
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 22, 2021 
 
 
 
/S/Jennifer J. Wirsching  
 
 
Jennifer J. Wirsching 
 
 
Attorney for Artur Ayvazyan 
 
 
Case 2:20-cr-00579-SVW     Document 1216     Filed 12/22/21     Page 4 of 4   Page ID
#:19436

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