EX PARTE APPLICATION for Bill of Particulars FIRST AMENDED Filed by Plaintiff USA as… — USA v. Ayvazyan et al (Dkt. 407)

Summary

The government's First Amended Bill of Particulars re Forfeiture Allegations, filed June 3, 2021, as Doc. 407, in the U.S. District Court for the Central District of California, No. CR 20-00579(A)-SVW. It gives notice that, under the forfeiture allegations in the First Superseding Indictment, the government intends to seek criminal forfeiture of listed property. The list includes $12,520.00 and $451,185.00 in U.S. Currency, bank funds of $74,557.79 and $65,990.43, wrist watches, gold bullion coins, jewelry, and a cryptocurrency hardware wallet. It also lists real property in Tarzana, Glendale, and Palm Desert, California, each with a legal description. The signature block names Dan G. Boyle.

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TRACY L. WILKISON 
Acting United States Attorney 
SCOTT M. GARRINGER 
Assistant United States Attorney 
Chief, Criminal Division 
SCOTT PAETTY (Cal. Bar No. 274719) 
CATHERINE AHN (Cal. Bar No. 248286) 
BRIAN FAERSTEIN (Cal. Bar No. 274850) 
Assistant United States Attorneys 
Major Frauds/Environmental and Community Safety Crimes Sections 
1100/1300 United States Courthouse 
312 North Spring Street 
Los Angeles, California 90012 
Telephone: (213) 894-6527/2424/3819 
Facsimile: (213) 894-6269/0141 
E-mail: 
Scott.Paetty@usdoj.gov 
 
Catherine.S.Ahn@usdoj.gov 
 
Brian.Faerstein@usdoj.gov 
 
DANIEL S. KAHN 
Acting Chief, Fraud Section 
Criminal Division, U.S. Department of Justice 
CHRISTOPHER FENTON 
Trial Attorney, Fraud Section 
Criminal Division, U.S. Department of Justice 
1400 New York Avenue NW, 3rd Floor 
Washington, DC 20530 
Telephone: (202) 320-0539 
Facsimile: (202) 514-0152 
E-mail: 
Christopher.Fenton@usdoj.gov 
 
Attorneys for Plaintiff 
UNITED STATES OF AMERICA 
 
UNITED STATES DISTRICT COURT 
 
FOR THE CENTRAL DISTRICT OF CALIFORNIA 
 
UNITED STATES OF AMERICA, 
Plaintiff, 
v. 
RICHARD AYVAZYAN,  
     Aka “Richard Ayazian” and 
“Iuliia Zhadko,” et al. 
 
Defendants. 
No. CR 20-00579(A)-SVW             
GOVERNMENT’S FIRST AMENDED BILL OF 
PARTICULARS RE FORFEITURE 
ALLEGATIONS  
Case 2:20-cr-00579-SVW     Document 407     Filed 06/03/21     Page 1 of 9   Page ID
#:4145

 
 
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Notice is hereby given that the government, pursuant to the 
forfeiture allegations set out in the First Superseding Indictment, 
intends to seek the criminal forfeiture of the following specific 
property: 
a. 
$12,520.00 in U.S. Currency seized during the execution of 
a federal search warrant on November 5, 2020, in Encino, California, 
at the residence of defendants Tamara Dadyan (“Dadyan”) and Artur 
Ayvazyan (“A. Ayvazyan”);  
b. 
$74,557.79 in Bank funds seized pursuant to a federal 
seizure warrant executed on November 20, 2020, from Bank of America 
account number ending in 7695 held in the name of Allstate Towing & 
Transport LLC; 
c. 
$451,185.00 in U.S. Currency seized on November 5, 2020, 
during the execution of a federal search warrant in various areas and 
back yard of a Tarzana, California residence (APN: 2176-029-031); 
d. 
Miscellaneous jewelry and precious items seized on November 
5, 2020, during the execution of a federal search warrant at a 
Tarzana, California residence (APN: 2176-029-031), consisting of: 
I. 
One Audermars Piguet, Royal Oak 18 carat rose gold 
wrist watch, model 26331, serial number J52335; 
II. 
One Rolex Datajust stainless steel wrist watch, model 
126334, serial number 4U95Z313; 
III. 
One Cartier Chronoscaph 21 stainless steel wrist 
watch, model 2424, serial number 880317LX; 
IV. 
One Audemars Piguet, Royal Oak Offshore black ceramic 
wrist watch, serial number K23313; 
Case 2:20-cr-00579-SVW     Document 407     Filed 06/03/21     Page 2 of 9   Page ID
#:4146

 
 
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V. 
One Audemars Piguet Royal Oak Offshore black ceramic 
wrist watch, serial number LU44845K; 
VI. 
Audemars Piguet Royal Oak stainless steel wrist watch, 
serial number LW3397N; 
VII. 
One 1979 Gold Bullion Coin; 
VIII. 
Two 1980 Gold Bullion Coins; 
IX. 
Ten 1982 Gold Bullion Coins; 
X. 
Seventeen 1983 Gold Bullion Coins; 
XI. 
Five 1984 Gold Bullion Coins; 
XII. 
Five 1985 Gold Bullion Coins; 
XIII. 
Ten 1986 Gold Bullion Coins; 
XIV. 
Ten 1987 Gold Bullion Coins; 
XV. 
One 14 carat rose tint gold pendant, cross-shaped; and 
e. 
Miscellaneous jewelry and precious items seized on October 
20, 2020, from R. Ayvazyan and Terabelian at Miami International 
Airport, consisting of: 
I. 
One Rolex Yacht-Master II watch, model 116681, serial 
number C32K8231; 
II. 
One Rolex Day-Date 40 watch, model W6685656; 
III. 
One Rolex Day-Date watch, serial number W44P7238; 
IV. 
One Pair of 14 carat white gold earrings with diamond 
studs; 
V. 
One pair of 18 carat white gold earrings with 
diamonds; 
VI. 
One 14 carat white gold bracelet with 2 rows of 
diamonds; 
VII. 
One 14 carat yellow gold 24” neck chain; 
Case 2:20-cr-00579-SVW     Document 407     Filed 06/03/21     Page 3 of 9   Page ID
#:4147

 
 
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VIII. 
One 14 carat yellow gold cross pendant; 
IX. 
One 14 carat yellow gold 16” neck chain;  
X. 
One 18 carat white gold bracelet double chain link 
“Evil Eye” with diamonds; and  
XI. 
One fabric cord bracelet with 18 carat white gold 
clasp and diamond “Evil Eye”; 
f. 
$3,422.00.00 in U.S. Currency seized on November 20, 2020, 
from R. Ayvazyan and Terabelian at the Miami International Airport; 
g. 
Ledger re Nanos Cryptocurrency Hardware Wallet seized on 
November 5, 2020, during the execution of a federal search warrant at 
a Tarzana, California residence (APN:2176-029-031); and 
h. 
$65,990.43 in Bank funds seized pursuant to a federal 
seizure warrant executed on December 2, 2020, from Bank of America 
account ending in ‘9700 in the name of Runyan Tax Service Inc.  
i. 
Real Property located in Tarzana, California more 
particularly described as follows: 
DESCRIPTION: THE LAND REFERRED TO HEREIN IS SITUATED IN THE 
COUNTY OF LOS ANGELES, STATE OF CALIFORNIA, AND IS DESCRIBED AS 
FOLLOWS: 
PARCEL 1: 
THOSE PORTIONS OF LOT 71 and 72 OF TRACT 2605, IN THE CITY 
OF LOS ANGELES, COUNTY OF LOS ANGELES, STATE OF CALIFORNIA, AS 
PER MAP RECORDED IN BOOK 27 PAGE 55 ET SEQ. OF MAPS, AND THAT 
PORTION OF PARCEL "A” OF PARCEL MAP L.A. NO. 2015 AS PER MAP 
FILED IN BOOK 32 PAGE 19 OF PARCEL MAPS, IN THE OFFICE OF THE 
COUNTY RECORDER OF SAID COUNTY, DESCRIBED AS FOLLOWS: 
Case 2:20-cr-00579-SVW     Document 407     Filed 06/03/21     Page 4 of 9   Page ID
#:4148

 
 
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BEGINNING AT A POINT IN THE CENTERLINE OF TOPEKA DRIVE, 40 
FEET WIDE, AS SHOWN ON SAID MAP, DISTANT THEREON SOUTH 15° 10' 
00" WEST 178.55 FEET FROM THE NORTHEASTERLY TERMINUS OF THAT 
CERTAIN COURSE IN THE CENTERLINE OF TOPEKA DRIVE SHOWN ON SAID 
MAP AS HAVING A BEARING OF NORTH 15° 10' 00" EAST AND LENGTH OP 
1055.19 FEET; 
THENCE SOUTH 74° 50' 00" EAST 56.09 FEET TO THE BEGINNING 
OF A TANGENT CURVE, CONCAVE TO THE NORTHWEST, HAVING A RADIUS OF 
129.86 FEET; 
THENCE EASTERLY ALONG SAID CURVE 128.40 FEET; TO THE TRUE 
POINT OF BEGINNING; 
THENCE TANGENT TO SAID CURVE NORTH 48° 30' 50" EAST 147.14 
FEET TO THE BEGINNING OF A TANGENT CURVE, CONCAVE TO THE 
SOUTHEAST, HAVING A RADIUS OF 100.05 FEET; 
THENCE EASTERLY ALONG SAID CURVE, 125.14 FEET, A RADIAL 
LINE TO SAID POINT BEARS NORTH 30° 10' 46" EAST; 
THENCE NORTH 10° 52' 46" EAST 45.32 FEET; 
THENCE SOUTH 84° 29' 18" EAST 182.82 FEET; 
THENCE SOUTH 04° 13' 10" WEST 195.63 FEET TO A POINT IN A 
CURVE CONCAVE WESTERLY HAVING A RADIUS OF 175.31 FEET; A RADIAL 
LINE TO SAID POINT BEARS NORTH 62° 22' 50” EAST; 
THENCE CONTINUING EASTERLY AND SOUTHERLY ALONG SAID CURVE 
THROUGH A CENTRAL ANGLE OF 50° 06' 30" AN ARC DISTANCE OF 153.32 
FEET; 
THENCE TANGENT TO SAID CURVE SOUTH 22° 29' 20" WEST 63.38 
FEET TO THE BEGINNING OF A TANGENT CURVE CONCAVE TO THE 
NORTHWEST HAVING A RADIUS OF 375.00 FEET; 
Case 2:20-cr-00579-SVW     Document 407     Filed 06/03/21     Page 5 of 9   Page ID
#:4149

 
 
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THENCE SOUTHWESTERLY ALONG SAID CURVE, THROUGH A CENTRAL 
ANGLE OF 13° 52' 00" 90.76 FEET TO THE BEGINNING OF A REVERSE 
CURVE CONCAVE TO THE SOUTHEAST HAVING A RADIUS OF 161.89 FEET; 
THENCE SOUTHEASTERLY ALONG SAID CURVE, THROUGH A CENTRAL 
ANGLE OF 17° 46' 00" 50.20 FEET TO THE BEGINNING OF A REVERSE 
CURVE CONCAVE TO THE NORTHWEST HAVING A RADIUS OF 75.69 FEET; 
THENCE SOUTHWESTERLY AND WESTERLY ALONG SAID CURVE, THROUGH 
A CENTRAL ANGLE OF 33° 58' 30" 44.88 FEET TO A POINT OF CUSP IN 
THE NORTHERLY LINE OF SAID PARCEL "A" SAID NORTHERLY LINE BEING 
A CURVE CONCAVE SOUTHWESTERLY HAVING A RADIUS OF 30.00'; A 
RADIAL LINE TO SAID POINT BEARS SOUTH 38° 26' 10" EAST; 
THENCE EASTERLY ALONG SAID CURVE THROUGH A CENTRAL ANGLE 
116° 31' 20" AN ARC DISTANCE OF 61.01 FEET; 
THENCE SOUTH 10° 54' 50" EAST 92.71 FEET; 
THENCE SOUTH 80° 16' 17" WEST 20.00 FEET; 
THENCE NORTH 31° 28' 33" WEST 120.33 FEET; 
THENCE NORTH 22° 17' 48" WEST 20.00 FEET TO THE BEGINNING 
OF A CURVE CONCAVE NORTHWESTERLY HAVING A RADIUS OF 55.69 FEET; 
THENCE NORTHEASTERLY ALONG SAID CURVE THROUGH A CENTRAL 
ANGLE OF 49° 06' 52" AN ARC DISTANCE OF 47.74 FEET TO THE 
BEGINNING OF A REVERSE CURVE CONCAVE SOUTHEASTERLY HAVING A 
RADIUS OF 181.89 FEET; 
THENCE NORTHEASTERLY ALONG SAID CURVE THROUGH A CENTRAL 
ANGLE OF 17° 46' 00" AN ARC DISTANCE OF 56.40 FEET TO THE 
BEGINNING OF A REVERSE CURVE CONCAVE NORTHWESTERLY HAVING A 
RADIUS OF 355.00 FEET; 
Case 2:20-cr-00579-SVW     Document 407     Filed 06/03/21     Page 6 of 9   Page ID
#:4150

 
 
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THENCE NORTHEASTERLY ALONG SAID CURVE THROUGH A CENTRAL 
ANGLE OF 12° 45' 16" AN ARC DISTANCE OF 79.03 FEET; 
THENCE NORTH 67° 12' 02" WEST 268.30 FEET; 
THENCE NORTH 15° 10' 00" EAST 43.00 FEET; 
THENCE NORTH 47° 02' 30" WEST 175.00 FEET TO THE TRUE POINT 
OF BEGINNING. 
PARCEL 2: 
THE RIGHT OF INGRESS AND EGRESS FOR SAID PROPERTY OVER A 
ROADWAY EASEMENT FROM TOPEKA DRIVE OVER THAT PORTION OF LOT 71, 
OF TRACT NO. 2605, IN THE CITY OF LOS ANGELES, COUNTY OF LOS 
ANGELES, STATE OF CALIFORNIA, AS PER MAP RECORDED IN BOOK 27, 
PAGE 55, ET SEQ., OF MAPS, IN THE OFFICE OF THE COUNTY RECORDER 
OF SAID COUNTY, INCLUDED WITHIN A STRIP OF LAND 30.00 FEET IN 
WITH, LYING 15.00 FEET ON EACH SIDE OF THE FOLLOWING DESCRIBED 
CENTER LINE: 
BEGINNING AT THE SOUTHWESTERLY CORNER OF THE LAND CONVEYED 
TO CIRELLA G. SMITH AND HUSBAND, BY DEED RECORDED JULY 8, 1943 
AS INSTRUMENT NO. 118, IN BOOK 20132 PAGE 100, OFFICIAL RECORDS, 
SAID CORNER BEING DISTANT 261.45 FEET NORTHERLY FROM THE 
SOUTHWESTERLY CORNER OF LOT 71, SAID TRACT 2605; THENCE NORMAL 
TO THE EASTERLY LINE OF TOPEKA DRIVE, SOUTH 74° 50' 00” EAST 
36.09 FEET TO THE BEGINNING OF A TANGENT CURVE CONCAVE TO THE 
NORTHWEST HAVING A RADIUS OF 129.86 FEET; THENCE NORTHEASTERLY 
ALONG SAID CURVE, 128.40 FEET; THENCE TANGENT TO SAID CURVE, 
NORTH 48° 30' 50" EAST 147.14 FEET TO THE BEGINNING OF A TANGENT 
CURVE CONCAVE SOUTHERLY, HAVING A RADIUS OF 100.05 FEET; THENCE 
EASTERLY ALONG SAID CURVE, 144.70 FEET; THENCE TANGENT TO SAID 
Case 2:20-cr-00579-SVW     Document 407     Filed 06/03/21     Page 7 of 9   Page ID
#:4151

 
 
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CURVE, SOUTH 48° 37' 10" EAST, 161.06 FEET TO THE BEGINNING OF A 
TANGENT CURVE CONCAVE WESTERLY, HAVING A RADIUS OF 175.31 FEET, 
THENCE SOUTHERLY ALONG SAID CURVE, 217.57 FEET; THENCE TANGENT 
TO SAID CURVE, SOUTH 22° 29' 20" WEST 42.15 FEET TO A POINT. 
APN: 2176-029-031 
j. 
Real Property located in Glendale, California more 
particularly described as follows: 
Parcel 1: 
Lot 56 of Tract No. 45375, in the City of Glendale, County 
of Los Angeles, State of California, as per map recorded in Book 
1128, Page(s) 55 to 63 inclusive of Maps, in the office of the 
County Recorder of said County. 
Except therefrom all oil and minerals in, on and under said 
land as reserved by Benjamin Dreyfus in deeds recorded in Book 
101, Pages 551 and in Book 107, Page 447 both of Deeds, in said 
Office of the County Recorder. 
Parcel 2: 
Non-exclusive easements for access, ingress, egress, 
encroachments, maintenance, repair, drainage, support and other 
purposes, all as described in the Master Declaration recorded 
March 7, 1989 as Instrument No. 1989-354873 and any amendments 
thereto. 
APN: 5663-036-033 
k. 
Real Property located in Palm Desert, California more 
particularly described as follows: 
Described real property in the County of Riverside, State 
of California: 
Case 2:20-cr-00579-SVW     Document 407     Filed 06/03/21     Page 8 of 9   Page ID
#:4152

 
 
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PARCEL 1: 
LOT 8 OF TRACT NO. 36554-1 IN THE CITY OF PALM DESERT, 
COUNTY OF RIVERSIDE, STATE OF CALIFORNIA AS PER MAP RECORDED IN 
THE BOOK 438 PAGES 98 AND 99, INCLUSIVE, OF MAPS, IN THE OFFICE 
OF THE COUNTY RECORDER OF CALIFORNIA. 
PARCEL 2: 
NON-EXCLUSIVE EASEMENTS APPURTENANT TO PARCEL 1 ABOVE, ON 
AND OVER THE “COMMON AREA” AS DEFINED IN THE DECLARATION OF 
COVENANTS, CONDITIONS, RESTRICTIONS AND RESERVATION OF EASEMENTS 
FOR ENCORE PALM DESERT (“DECLARATION”) RECORDED IN THE OFFICE OF 
SAID COUNTY RECORDER OF CALIFORNIA ON DECEMER 23, 2013 AS 
INSTRUMENT NO. 2013-0591271, FOR ACCESS, USE, OCCUPANCY, 
ENJOYMENT, INGRESS AND EGRESS OF THE AMENITIES LOCATED THEREON.  
THE COMMON AREA IS FOR THE USE OF OWNERS OF LOTS WHICH ARE 
SUBJECT TO THE DECLARATION AND IS NOT FOR THE USE OF THE GENERAL 
PUBLIC. 
APN: 694-331-008. 
Dated: June 3, 2021 
Respectfully submitted, 
 
TRACY L. WILKISON 
Acting United States Attorney 
 
SCOTT M. GARRINGER 
Assistant United States Attorney 
Chief, Criminal Division 
 
 
      /s/ 
 
DAN G. BOYLE 
Assistant United States Attorney 
Asset Forfeiture Section 
 
Attorney for Plaintiff 
UNITED STATES OF AMERICA 
 
 
 
Case 2:20-cr-00579-SVW     Document 407     Filed 06/03/21     Page 9 of 9   Page ID
#:4153

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