EX PARTE APPLICATION to Modify Conditions of Release Filed by Defendant Edvard… — USA v. Ayvazyan et al (Dkt. 662)

Record facts

U.S. District Court for the Central District of California · No. 2:20-cr-00579-SVW · Doc. 662 · 2021-07-01 · Docket on CourtListener

Summary

An unopposed ex parte application to modify conditions of release filed July 1, 2021 by defendant Edvard Paronyan, through counsel Michael G. Freedman, in United States v. Ayvazyan et al, No. 2:20-cr-00579-SVW, in the U.S. District Court for the Central District of California; it is Doc. 662. The application asks for an order replacing the home confinement condition of his pretrial release with a curfew set by United States Pretrial Services. It states that the government and Pretrial Services have no objection to the request. The application rests on an attached declaration of counsel and a declaration of the surety for the bond, with a proposed order filed concurrently. The filing is one page.

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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.  Specifically, Mr. Paronyan seeks an order 
replacing the home confinement condition with a condition that he be subject to a 
curfew set by United States Pretrial Services.  The government and Pretrial 
Services have 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). 
 
Dated: July 1, 2021 
 
 
 
Respectfully submitted, 
 
 
 
 
 
 
 
 
 
By: 
/s/ Michael G. Freedman 
 
 
 
 
 
 
 
 
Michael G. Freedman 
 
 
 
 
 
 
 
 
Attorney for Defendant 
 
 
 
 
 
 
 
 
Edvard Paronyan 
Case 2:20-cr-00579-SVW     Document 662     Filed 07/01/21     Page 1 of 1   Page ID
#:9717

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