EX PARTE APPLICATION to Modify Conditions of Release Filed by Defendant Edvard… — USA v. Ayvazyan et al (Dkt. 387)

Record facts

U.S. District Court for the Central District of California · No. 2:20-cr-00579-SVW · Doc. 387 · 2021-05-31 · Docket on CourtListener

Summary

An unopposed ex parte application filed May 31, 2021 by defendant Edvard Paronyan in United States v. Edvard Paronyan, No. 2:20-cr-00579-SVW, in the U.S. District Court for the Central District of California, docketed as Document 387. It asks the court to modify his pretrial release conditions so that he may attend a school graduation ceremony in Canoga Park on June 6, 2021 from 9:00 a.m. to 2:00 p.m., and states that the government does not oppose. An attached declaration of counsel Michael G. Freedman recounts that a First Superseding indictment of March 9, 2021 charges conspiracy and wire and bank fraud counts over an alleged scheme to submit fraudulent applications for COVID-19 relief funds guaranteed by the Small Business Administration. It also records release on a $75,000 unsecured bond ordered March 11, 2021 and a jury trial set for June 15, 2021.

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UNOPPOSED EX PARTE APPLICATION 
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Michael G. Freedman (State Bar No. 281279) 
THE FREEDMAN FIRM PC 
800 Wilshire Blvd., Suite 1050 
Los Angeles, California  90017 
Telephone: (213) 816-1700 
Facsimile: (213) 816-1706 
Email: Michael@thefreedmanfirm.com 
 
Attorney for Defendant Edvard Paronyan 
 
 
 
 
 
UNITED STATES DISTRICT COURT 
 
CENTRAL DISTRICT OF CALIFORNIA 
 
 
 
UNITED STATES OF AMERICA, 
Plaintiff, 
vs. 
EDVARD PARONYAN, 
Defendant. 
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Case No.: 20-CR-579(A)-SVW 
UNOPPOSED EX PARTE 
APPLICATION TO MODIFY 
CONDITIONS OF RELEASE RE: 
SON’S FIFTH GRADE 
GRADUATION ON JUNE 6, 2021 
[Proposed Order Filed Concurrently] 
 
 
Edvard Paronyan, by and through his counsel of record, Michael G. 
Freedman, hereby files this unopposed ex parte application for an Order modifying 
the conditions of his pretrial release to allow Mr. Paronyan to attend his son’s fifth 
grade graduation ceremony on June 6, 2021 from 9:00 a.m. to 2:00 p.m. in Canoga 
Park.  The government has no objection to this request.  This application is based 
on the attached Declaration of Michael G. Freedman. 
 
Dated: May 31, 2021 
 
 
 
Respectfully submitted, 
 
 
 
 
 
 
 
 
 
 
By: 
/s/ Michael G. Freedman 
 
 
 
 
 
 
 
 
Michael G. Freedman 
 
 
 
 
 
 
 
 
Attorney for Defendant 
 
 
 
 
 
 
 
 
Edvard Paronyan 
Case 2:20-cr-00579-SVW     Document 387     Filed 05/31/21     Page 1 of 3   Page ID
#:4020

 
DECLARATION OF COUNSEL 
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DECLARATION OF MICHAEL G. FREEDMAN 
 
 
I, Michael G. Freedman, do declare and state: 
1. I am counsel for Edvard Paronyan in this matter.  I am licensed to practice in  
the State of California, and admitted to practice before this Court. 
2. On March 9, 2021, Mr. Paronyan was charged by the First Superseding  
indictment in this matter with several counts of conspiracy and wire and bank fraud 
relating to an alleged scheme to submit fraudulent loan applications seeking 
COVID-19 relief funds guaranteed by the Small Business Administration (SBA) 
under the Coronavirus Aid, Relief, and Economic Security (CARES) Act.  (Dkt. 
154). 
3. On March 11, 2021, the Honorable Maria A. Audero, United States  
Magistrate Judge, ordered Mr. Paronyan released on a $75,000 unsecured bond to 
be signed by his brother, Zaven Paronian.  (Dkt. 177).  Judge Audero ordered that 
the unsecured bond be replaced by a $75,000 bond secured by Zaven Paronian’s 
real property on or before April 1, 2021.  (Id.)  On March 30, 2021, Mr. Paronyan 
filed an ex parte application for a thirty-day extension to post the secured bond due 
to a Coronavirus-related backlog at the Los Angeles County Registrar-Recorder.  
(Dkt. 228).  That extension was granted on March 31, 2021 (Dkt. 252), and Mr. 
Paronyan posted the secured bond on April 28, 2021 (Dkt. 320). 
4. Mr. Paronyan signed a plea agreement with the government on May 26,  
2021 (Dkt. 368), but the Court declined to accept the plea at a change of plea 
hearing on May 27, 2021 (Dkt. 375).  Jury trial is scheduled for June 15, 2021. 
5. The conditions of Mr. Paronyan’s release restrict him to his residence except  
for medical needs or treatment, attorney visits, court appearances, and 
employment, all of which must be preapproved by U.S. Pretrial Services. 
6. Mr. Paronyan’s son Christopher is finishing fifth grade at the AGBU School  
Case 2:20-cr-00579-SVW     Document 387     Filed 05/31/21     Page 2 of 3   Page ID
#:4021

 
DECLARATION OF COUNSEL 
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in Canoga Park, California.  A graduation ceremony for students and their families 
is scheduled for Sunday, June 6, 2021 from approximately 9:00 a.m. to 2:00 p.m.  
Mr. Paronyan hopes to attend his son’s graduation along with his wife and 
daughter.  Mr. Paronyan requested permission from his pretrial supervision officer 
on approximately May 27, 2021 and was informed he would have to seek a Court 
order. 
7. I have communicated with Assistant United States Attorney Scott  
Paetty, who represents the government in this matter. Mr. Paetty advised 
me that the government does not oppose the relief sought in this application. 
 
I declare under penalty of perjury under the laws of the United States of 
America that the foregoing is true and correct and that this declaration is executed 
at Los Angeles, California on May 31, 2021. 
 
 
 
 
 
 
 
 
/s/Michael G. Freedman 
 
 
 
 
 
 
 
Michael G. Freedman 
Case 2:20-cr-00579-SVW     Document 387     Filed 05/31/21     Page 3 of 3   Page ID
#:4022

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