Consent to Video Hearing filed by Defendant Edvard Paronyan — USA v. Ayvazyan et al. (Dkt. 370, C.D. Cal.)

Summary

Consent to Video Conference/Telephonic Conference form filed 05/27/21 as Document 370 in Case 2:20-cr-00579-SVW in the Central District of California, by defendant Edvard Paronyan (case number 20-579(A)-SVW-7). Over the signature /s/ Edvard Paronyan dated 5/27/21, the form states that after consultation with counsel the defendant knowingly and voluntarily consents to listed proceedings taking place by video conference or, if not reasonably available, by telephonic conference. The proposed findings state that Paronyan desires his change of plea hearing to proceed at the earliest opportunity and, citing the CARES Act and Order No. 20-043 as extended by Order 21-031, agrees that delay would cause serious harm to the interests of justice. The findings request that the hearing proceed via video conference, and counsel also signs.

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Case 2:20-cr-00579-SVW Document 370 Filed 05/27/21 Pagelof2 PageID
#:3760
NAME & ADDRESS
Michael G. Freedman (SBN 281279)
The Freedman Firm PC
800 Wilshire Blvd., Suite 1050, Los Angeles, CA 90017

UNITED STATES DISTRICT COURT
CENTRAL DISTRICT OF CALIFORNIA

CASE NUMBER
UNITED STATES OF AMERICA
PLAINTIFF, 20-579(A)-SVW-7
Vv.
Edvard Paronyan
CONSENT TO VIDEO/TELEPHONIC CONFERENCE
USMS Reg. #: AND/OR WAIVER OF DEFENDANT'S PRESENCE
DEFENDANT(S). AND PROPOSED FINDINGS/ORDER
Check each that applies:
CONSENT TO VIDEO CONFERENCE/TELEPHONIC CONFERENCE [_] WAIVER OF DEFENDANT'S PRESENCE

1. Consent to Video Conference/Telephonic Conference

I, Edvard Paronyan , understand that the U.S. Constitution, the Federal Rules of Criminal

Procedure, and/or one or more federal statutes may give me the right to have all the below-listed proceedings take place in person in
open court. After consultation with counsel, I knowingly and voluntarily consent to the proceedings below instead taking place by
video conference or, if video conference is not reasonably available, by telephonic conference:

Check each that applies:

|] Detention/Bail Review/Reconsideration Hearing(s) (18 U.S.C. Sec. 3142) [_] Initial Appearance (Fed. R. Crim. P. 5)

[| Preliminary Hearing (Fed. R. Crim. P. 5.1) [_] Arraignment (Fed. R. Crim. P. 10)

[_] Pretrial Release Revocation Proceedings (18 U.S.C. Sec. 3148) [_] Waiver of Indictment (Fed. R. Crim. P. 7(b))
[| Misdemeanor Pleas and Sentencings (Fed. R. Crim. P. 43(b)(2)) [_] Appearances under Fed. R. Crim. P. 40

[_] Probation and Supervised Release Revocation Proceedings (Fed. R. Crim. P. 32.1)

Note: to consent to an appearance by video or telephonic conference at one of the two proceedings listed below, you must also complete
the "Proposed Findings" section on page 2 of this form.

Felony Pleas (Fed. R. Crim. P. 11) [_] Felony Sentencings (Fed. R. Crim. P. 32)

2. Waiver of Defendant's Presence

I, » understand that the U.S. Constitution, the Federal Rules of Criminal

Procedure, and/or one or more federal statutes may give me the right to be present at all of the below-listed proceedings - in person,
by video conference, or by telephonic conference. After consultation with counsel, I knowingly and voluntarily waive my right to be
present in person in open court or by video conference or by telephonic conference at the proceedings below:

Check each that applies (and use Form CR-35 to waive the defendant's presence at other types of proceedings):

[_] Detention/Bail Review/Reconsideration Hearing(s) (18 U.S.C. Sec. 3142) [_] Probation and Supervised Release Revocation
|] Preliminary Hearing (Fed. R. Crim. P. 5.1) Proceedings (Fed. R. Crim. P. 32.1)

[_] Pretrial Release Revocation Proceedings (18 U.S.C. Sec. 3148) [_] Waiver of Indictment (Fed. R. Crim. P. 7(b))
[| Misdemeanor Pleas and Sentencings (Fed. R. Crim. P. 43(b)(2)) [_] Appearances under Fed. R. Crim. P. 40
5/27/21

/s/ Edvard Paronyan
Date Defendant Signed for Defendant by Counsel for Defendant with

Defendant's Authorization [Check if applicable]

?
In Custody’ For in-custody defendants,
[_] Yes No list institution where housed:

CR-029 (08/20) CONSENT TO VIDEO/TELEPHONIC CONFERENCE AND/OR WAIVER OF DEFENDANT'S PRESENCE P.1OF2
Case 2:20-cr-00579-SVW Document 370 Filed 05/27/21 Page2of2 PageID
#:3761

I have translated this consent/waiver to the Defendant in the language.

Date Interpreter (if required)
Signed for Interpreter by Counsel for Defendant with

L Interpreter's Authorization [Check if applicable]

I am counsel for the Defendant herein. Prior to the Defendant signing this document or authorizing me to sign this document on the
Defendant's behalf, I fully advised the Defendant of the Defendant's above-referenced rights and consulted with the Defendant
regarding such rights and the Defendant's consent/waiver(s). I believe that the Defendant understands such rights and that the
Defendant's consent/waiver(s) are knowing and voluntary, and I concur with such consent/waiver(s).

5/27/21 /s/ Michael G. Freedman

Date Counsel for Defendant

3. Proposed Findings Regarding Harm of Further Delay of Felony Plea or Sentencing

Pursuant to § 15002(b)(2) of the Coronavirus Aid, Relief, and Economic Security ("CARES") Act and § 2 of Order of the Chief Judge
No. 20-043 (In Re: Coronavirus Public Emergency Use of Video and Telephonic Conference in Certain Criminal Proceedings), felony
pleas and sentencings cannot be conducted other than in person in open court unless the judge makes specific findings that the plea
or sentencing “cannot be further delayed without serious harm to the interests of justice." Accordingly, if the defendant intends to
consent to a felony plea or sentencing taking place by video conference or, if video conference is not reasonably available, by
telephonic conference, instead of in person in open court, the defendant must set forth below proposed findings sufficient to make
this showing.

Defendant Edvard Paronyan, upon advice and agreement from his counsel, desires his change of plea hearing to proceed at the
earliest opportunity. Given the CARES Act and Order No. 20-043, as extended by Order 21-031, of the Chief Judge, Defendant
Paronyan agrees that delay of his change of plea hearing will cause serious harm to the interests of justice and therefore
respectfully requests and agrees that the change of plea hearing may proceed via video conference.

4. Order Adopting Findings Regarding Harm of Further Delay of Felony Plea or Sentencing

Pursuant to § 15002(b)(2) of the Coronavirus Aid, Relief, and Economic Security ("CARES") Act and § 2 of Order of the Chief Judge
No. 20-043 (In Re: Coronavirus Public Emergency Use of Video and Telephonic Conference in Certain Criminal Proceedings), I
hereby find that the:

Felony Plea (Fed. R. Crim. P. 11) [_] Felony Sentencing (Fed. R. Crim. P. 32)

in this case cannot be further delayed without serious harm to the interests of justice, for the reasons set forth above.

Date United States District Judge

CR-029 (08/20) CONSENT TO VIDEO/TELEPHONIC CONFERENCE AND/OR WAIVER OF DEFENDANT'S PRESENCE P.2 OF2


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