Declaration Declaration of Michael G. Freedman — USA v. Ayvazyan et al (Dkt. 662.1)

Record facts

U.S. District Court for the Central District of California · No. 2:20-cr-00579-SVW · Doc. 662-1 · 2021-07-01 · Docket on CourtListener

Summary

The declaration of Michael G. Freedman, counsel for defendant Edvard Paronyan, filed July 1, 2021 as Doc. 662-1 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 recounts the procedural history of Mr. Paronyan's release, including a $75,000 unsecured bond ordered on March 11, 2021 and later replaced by a secured bond, and a revised plea agreement the court accepted on June 11, 2021. The declaration states that a U.S. Pretrial Services officer recommended modifying his release conditions from home confinement to a curfew between 10:00 p.m. and 5:00 a.m. It states that an Assistant United States Attorney responded on June 30, 2021 that the government had no objection, provided other conditions such as location monitoring remain. The related email correspondence is attached.

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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  
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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).  The Court granted that 
request on June 1, 2021.  (Dkt. 396). 
7. On June 22, 2021, Mr. Paronyan filed an ex parte application to modify  
the conditions of his pretrial release to allow him to attend his daughter’s 
kindergarten graduation ceremony and his godchildren’s baptism, both on June 25, 
2021.  (Dkt. 561).  The Court granted that request on June 22, 2021.  (Dkt. 570). 
8. Following the June 22, 2021 request, I communicated with United States  
Pretrial Services Officer Allyson Theophile, who expressed to me that she 
recommends Mr. Paronyan’s pretrial release conditions be modified from home 
confinement to a curfew requiring him to be home between the hours of 10:00 p.m. 
and 5:00 a.m.  Officer Theophyle emailed the same request to the Assistant United 
States Attorneys assigned to this case on June 22, 2021.  Specifically, Officer 
Theophyle noted that this request “would allow Mr. Paronyan to seek employment 
and help provide for his family and take care of his family.”  Furthermore, she 
noted that “Mr. Paronyan has been compliant in regards to his supervision and is 
abiding by all of his reporting instructions.  Although born in Armenia, he has 
strong ties to the CAC and willing sureties.” 
9. On June 30, 2021, Assistant United States Attorney Catherine Ahn  
responded to Officer Theophile that “[t]he government has no objection to your 
recommendation, on the understanding that other conditions (location monitoring, 
etc.) would remain the same.”  Officer Theophile responded the same day that she 
would advise the location monitoring officer that “he can place Mr. Paronyan on 
stand alone [location monitoring]. He will continue on [location monitoring] just a 
different level.”  A true and correct copy of the above-described email 
correspondence is attached to this declaration. 
10. As Officer Theophile notes, the requested modification would allow Mr.  
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Paronyan to help support his family.  He has young children and it has been 
difficult for him and his wife to manage their schedules, especially during the 
summer, when he has been unable to leave the home.  The requested modification 
would ease the burden on Mr. Paronyan’s family by allowing him to help with 
family responsibilities. 
11. In addition to the positions of AUSA Ahn and Officer Theophile, Mr.  
Paronyan’s surety, his brother Zaven Paronian, consents to the modification as 
well, as noted in the concurrently filed declaration. 
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 July 1, 2021. 
/s/Michael G. Freedman  
 
 
 
 
 
 
 
Michael G. Freedman 
Counsel for Defendant  
Edvard Paronyan  
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Michael@thefreedmanfirm.com
From:
Allyson Theophile <Allyson_Theophile@cacp.uscourts.gov>
Sent:
Wednesday, June 30, 2021 10:00 PM
To:
Ahn, Catherine S. (USACAC)
Cc:
Faerstein, Brian (USACAC); michael@thefreedmanfirm.com; Paetty, Scott (USACAC); 
Fenton, Christopher (CRM)
Subject:
Re: Revised by Court - RE: US v. Paronyan, 20-579-SWV, Unopposed Ex Parte to Modify 
Conditions of Release
Thank you Catherine. I will advise the LM Officer that he can place Mr. Paronyan on stand alone LM. He will continue on 
LM just a different level. 
 
Thank you, 
 
Allyson 
 
Get Outlook for iOS 
From: Ahn, Catherine S. (USACAC) <Catherine.S.Ahn@usdoj.gov> 
Sent: Wednesday, June 30, 2021 2:27:40 PM 
To: Allyson Theophile <Allyson_Theophile@cacp.uscourts.gov> 
Cc: Faerstein, Brian (USACAC) <Brian.Faerstein@usdoj.gov>; michael@thefreedmanfirm.com 
<michael@thefreedmanfirm.com>; Paetty, Scott (USACAC) <Scott.Paetty@usdoj.gov>; Fenton, Christopher (CRM) 
<Christopher.Fenton@usdoj.gov> 
Subject: RE: Revised by Court - RE: US v. Paronyan, 20-579-SWV, Unopposed Ex Parte to Modify Conditions of Release  
  
CAUTION - EXTERNAL: 
 
Officer Theophile, 
  
The government has no objection to your recommendation, on the understanding that other conditions (location 
monitoring, etc.) would remain the same. 
  
Sincerely, 
Catherine 
  
Catherine S. Ahn | Assistant United States Attorney  
Criminal Division | Major Frauds 
✉ catherine.s.ahn@usdoj.gov | ፥
፦
፧
፨
፩ 213.894.2424   
 ௲
௳
௴ https://www.justice.gov/usao-cdca 
  
  
  
From: Ahn, Catherine S. (USACAC)  
Sent: Monday, June 28, 2021 8:33 AM 
To: Allyson Theophile <Allyson_Theophile@cacp.uscourts.gov> 
Cc: Faerstein, Brian (USACAC) <bfaerstein@usa.doj.gov>; michael@thefreedmanfirm.com; Scott Paetty (USACAC) 
(spaetty@usa.doj.gov) <spaetty@usa.doj.gov>; Christopher Fenton (CRM) (Christopher.Fenton@usdoj.gov) 
<Christopher.Fenton@usdoj.gov> 
Subject: RE: Revised by Court - RE: US v. Paronyan, 20-579-SWV, Unopposed Ex Parte to Modify Conditions of Release 
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Thank you, Officer Theophile.  We are reviewing and will let you know our position shortly.  Thank you for your patience.
  
From: Allyson Theophile <Allyson_Theophile@cacp.uscourts.gov>  
Sent: Tuesday, June 22, 2021 5:08 PM 
To: Faerstein, Brian (USACAC) <bfaerstein@usa.doj.gov>; michael@thefreedmanfirm.com; Ahn, Catherine S. (USACAC) 
<cahn@usa.doj.gov> 
Subject: FW: Revised by Court - RE: US v. Paronyan, 20-579-SWV, Unopposed Ex Parte to Modify Conditions of Release 
  
Hello, 
  
I am emailing you regarding Edvard Paroyan who I am supervising.  I am requesting that Mr. 
Paronyan’s LM condition be modified to curfew instead or stand-alone monitoring instead of 
home detention. This will allow him to seek employment to help provide for his family and 
take care of his family.  My suggestion is either a curfew between the hours of 10:00 pm to 
5:00 am.  Mr. Paronyan has been compliant in regards to his supervision and is abiding by all of 
his reporting instructions.  Although born in Armenia, he has strong family ties to the CAC and 
willing sureties. 
  
Please let me know if you require any additional information. 
  
  
 
  
From: MAAChambers <MAA_Chambers@cacd.uscourts.gov>  
Sent: Tuesday, June 22, 2021 4:38 PM 
To: michael@thefreedmanfirm.com 
Cc: 'Faerstein, Brian (USACAC)' <Brian.Faerstein@usdoj.gov>; 'Ahn, Catherine S. (USACAC)' 
<Catherine.S.Ahn@usdoj.gov>; christopher.fenton@usdoj.gov; Scott.Paetty@usdoj.gov; Allyson Theophile 
<Allyson_Theophile@cacp.uscourts.gov> 
Subject: Revised by Court - RE: US v. Paronyan, 20-579-SWV, Unopposed Ex Parte to Modify Conditions of Release 
  
Hi Counsel 
  
Revised order issued by the Court. 
  
Thank you  
  
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From: michael@thefreedmanfirm.com <michael@thefreedmanfirm.com>  
Sent: Tuesday, June 22, 2021 2:05 PM 
To: MAAChambers <MAA_Chambers@cacd.uscourts.gov> 
Cc: 'Faerstein, Brian (USACAC)' <Brian.Faerstein@usdoj.gov>; 'Ahn, Catherine S. (USACAC)' 
<Catherine.S.Ahn@usdoj.gov>; christopher.fenton@usdoj.gov; Scott.Paetty@usdoj.gov; Allyson Theophile 
<Allyson_Theophile@cacp.uscourts.gov> 
Subject: RE: US v. Paronyan, 20-579-SWV, Unopposed Ex Parte to Modify Conditions of Release 
  
CAUTION - EXTERNAL: 
  
Good afternoon, 
  
Attached is the ex parte application to modify pretrial release conditions (relating to a June 25 matter) for Defendant 
Edvard Paronyan, as well as the Proposed Order in Word format.   
  
Thank you, 
Michael Freedman 
  
  
Michael G. Freedman
THE FREEDMAN FIRM PC
 
800 Wilshire Blvd., Suite 1050
Los Angeles, CA 90017 
Office: (213) 816-1700 
Mobile: (310) 339-4503 
Email: michael@thefreedmanfirm.com 
Web: http://www.thefreedmanfirm.com
  
  
  
CAUTION - EXTERNAL EMAIL: This email originated outside the Judiciary. Exercise caution when opening 
attachments or clicking on links. 
  
CAUTION - EXTERNAL EMAIL: This email originated outside the Judiciary. Exercise caution when opening 
attachments or clicking on links. 
 
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