Ex Parte Application for Ruling Setting Surrender Date Filed by Defendant Artur — USA v. Ayvazyan et al. (Dkt. 1266, C.D. Cal.)

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U.S. District Court for the Central District of California · No. 2:20-cr-00579-SVW · Doc. 1266 · 2022-01-28 · Docket on CourtListener

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TARIK S. ADLAI, SBN 165454
LAW OFFICES OF TARIK S. ADLAI
65 No. Raymond Avenue, Suite 320
Pasadena, California 91103
Tel: (626) 578-7294
Fax: (626) 685-2562
E-mail: tadlai@adlailaw.com
Attorney for Defendant
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
EMERGENCY APPLICATION
TO SET SURRENDER DATE
TO THE HONORABLE STEPHEN V. WILSON, UNITED STATES
DISTRICT JUDGE, ALL PARTIES AND THEIR ATTORNEYS OF
RECORD:
Defendant Artur Ayvazyan, by and through his attorney Tarik S. Adlai,
respectfully hereby applies ex parte for an emergency application to set a
surrender date.  This application is necessary because he has been denied bail
pending appeal but his surrender date has expired and, at the Government’s
behest, probation has instructed him to surrender “immediately,” with no
opportunity to arrange his affairs and at the risk of unfairly treating him as a
untimely surrender by BOP, adversely affecting his designation.
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Case 2:20-cr-00579-SVW   Document 1266   Filed 01/28/22   Page 1 of 3   Page ID #:19767

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DATED: January 28, 2022.
Respectfully submitted,
Law Offices of Tarik S. Adlai
      /s/ Tarik S. Adlai
TARIK S. ADLAI, Esq.
Attorney for Defendant 
Artur Ayvazyan
At the time of sentencing, this Court denied the Government’s motion
to remand and allowed Mr. Ayvazyan to surrender the first week of January
2022.  In December 2021, this Court denied Mr. Ayvazyann’s motion for bail
on appeal. Mr. Ayvazyan’s appellate counsel filed a motion for bail in the
Ninth Circuit that automatically stayed his surrender.  Ninth Cir. R. 9-1.2(e).
The Ninth Circuit denied Mr. Ayvazyan’s motion for bail on appeal on
January 27, 2022.  On the morning of January 28, 2022, Mr. Ayvazyan’s
probation officer directed Mr. Ayvazyan to surrender by noon, with no time
to get his affairs in order, including the care and placement of his two teen
daughters and his brother’s three children who he voluntarily took
responsibility for in his brother’s absence.
This Court has found Mr. Ayvazyan neither a flight risk nor a danger
and has agreed he is a good candidate to allow to self-surrender.  A four-hour
notice to surrender is extremely disruptive and entirely unnecessary.
DATED: January 28, 2022.
Respectfully submitted,
Law Offices of Tarik S. Adlai
      /s/ Tarik S. Adlai
TARIK S. ADLAI, Esq.
Attorney for Defendant 
Artur Ayvazyan
DECLARATION OF TARIK S. ADLAI
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Case 2:20-cr-00579-SVW   Document 1266   Filed 01/28/22   Page 2 of 3   Page ID #:19768

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I, Tarik S. Adlai, declare:
1.
I am an attorney, duly licensed and authorized to practice law
before all courts of the State of California and am a member of the bar of this
Court.  I am counsel for Artur Ayvazyan, the defendant herein.  The facts
contained in this declaration are true based on the papers, pleadings, and
records on file in this case, are personally known to be to be true, or I am
informed and believe them to be true.  If called as a witness, I could and
would competently testify thereto. 
2.
The facts contained in the accompanying motion are true.
I declare under penalty of perjury that the foregoing is true and that this
declaration was executed this 28th day of January 2022, at Aspen, Colorado.
/s/ Tarik S. Adlai
TARIK S. ADLAI
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Case 2:20-cr-00579-SVW   Document 1266   Filed 01/28/22   Page 3 of 3   Page ID #:19769

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