EX PARTE APPLICATION to Modify Conditions of Release Filed by Defendant Edvard… — USA v. Ayvazyan et al (Dkt. 561)

Record facts

U.S. District Court for the Central District of California · No. 2:20-cr-00579-SVW · Doc. 561 · 2021-06-22 · Docket on CourtListener

Summary

An unopposed ex parte application to modify conditions of release filed by defendant Edvard Paronyan in USA v. Ayvazyan et al, No. 2:20-cr-00579-SVW, in the U.S. District Court for the Central District of California, filed June 22, 2021 as Document 561. Through counsel Michael G. Freedman, it asks for an order allowing Mr. Paronyan to attend two family events on June 25, 2021, and states the government has no objection. The attached declaration of counsel states that he was charged by the First Superseding indictment on March 9, 2021, was released on a $75,000 bond, and that the Court accepted a revised plea agreement on June 11, 2021. It adds that an Assistant United States Attorney advised that the government does not oppose the relief. The filing is four pages.

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Full text

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  
[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 daughter’s 
kindergarten graduation ceremony on June 25, 2021 from approximately 10:00 
a.m. to approximately 1:00 p.m. in Canoga Park and his godchildren’s baptism in
Van Nuys from approximately 5:00 p.m. on June 25, 2021 to approximately 1:00
a.m. on June 26, 2021.  The government has no objection to this request.  This
application is based on the attached Declaration of Michael G. Freedman and the
attached Declaration of Zaven Paronian (the surety for Mr. Paronyan’s bond).
Case 2:20-cr-00579-SVW     Document 561     Filed 06/22/21     Page 1 of 4   Page ID
#:6759

 
UNOPPOSED EX PARTE APPLICATION 
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Dated: June 22, 2021 
 
 
 
Respectfully submitted, 
 
 
 
 
 
 
 
 
 
 
By: 
/s/ Michael G. Freedman 
 
 
 
 
 
 
 
 
Michael G. Freedman 
 
 
 
 
 
 
 
 
Attorney for Defendant 
 
 
 
 
 
 
 
 
Edvard Paronyan 
Case 2:20-cr-00579-SVW     Document 561     Filed 06/22/21     Page 2 of 4   Page ID
#:6760

 
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). Mr. Paronyan signed a revised plea 
agreement with the government on June 8, 2021, which the Court accepted on June 
11, 2021.  (Dkt. 524). 
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. On May 31, 2021, Mr. Paronyan filed an ex parte request to modify  
Case 2:20-cr-00579-SVW     Document 561     Filed 06/22/21     Page 3 of 4   Page ID
#:6761

 
DECLARATION OF COUNSEL 
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the conditions of his pretrial release to allow him to attend his son’s fifth grade 
graduation at the AGBU School in Canoga Park, California on Sunday, June 6, 
2021 from approximately 9:00 a.m. to 2:00 p.m. (Dkt 387).  This Court granted 
that request on June 1, 2021.  (Dkt. 396.) 
7. Mr. Paronyan’s daughter is finishing kindergarten at the AGBU 
School in Canoga Park, California. A graduation ceremony for students and their 
families is scheduled for Friday, June 25, 2021 from approximately 10:00 a.m. to 
approximately 1:00 p.m. Mr. Paronyan hopes to attend his daughter’s graduation 
along with his wife and son.  
8. Also on June 25, 2021, Mr. Paronyan’s godchildren are being baptized at  
The St. Peter Armenian Apostolic Church in Van Nuys, California.  In his role as 
godfather, Mr. Paronyan is officiating at the baptism and is listed as a host on the 
invitation.  The baptism is scheduled to run from approximately 5:00 p.m. to 
approximately 6:30 p.m. at the church, and will then be followed by a family 
dinner at a banquet hall in Van Nuys, which will last until approximately 1:00 a.m. 
9. I have communicated with Assistant United States Attorney Catherine Ahn,  
who represents the government in this matter. Ms. Ahn 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 June 22, 2021. 
/s/Michael G. Freedman  
 
 
 
 
 
 
 
Michael G. Freedman 
Counsel for Defendant  
Edvard Paronyan  
Case 2:20-cr-00579-SVW     Document 561     Filed 06/22/21     Page 4 of 4   Page ID
#:6762

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