Declaration — USA v. Ayvazyan et al. (Dkt. 865-1, C.D. Cal.)

Record facts

U.S. District Court for the Central District of California · No. 2:20-cr-00579-SVW · Doc. 865-1 · 2021-08-11 · Docket on CourtListener

Full text

1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
DECLARATION OF CHRISTOPHER FENTON 
I, CHRISTOPHER FENTON, hereby declare as follows: 
1. 
I am a Trial Attorney at the Fraud Section within the 
Criminal Division of the Department of Justice.  I represent the 
government in this matter and submit this declaration in support of 
the Government’s Opposition to Defendant Edvard Paronyan’s Ex Parte  
Motion to Modify Conditions of Pretrial Release. 
2. 
In connection with the defendant’s motion, I spoke with 
United States Probation and Pretrial Services Officer Stacey Cooke on 
Tuesday, August 10, 2021, to obtain more information about the 
defendant’s ongoing supervision and conditions of release.  I spoke 
with Officer Cooke again on Wednesday, August 11, 2021.  Officer 
Cooke, who is responsible for monitoring the defendant’s location, 
told me that she believes location monitoring should remain in place.   
3. 
Officer Cooke also explained that the defendant’s claim 
that he typically receives location monitoring notifications every 
night around 3:00a.m. or 4:00a.m. is not true.  According to Officer 
Cooke, the location monitoring notifications are random so as to 
prevent the defendant from knowing precisely when he will be required 
to check-in.  If, as the defendant claims, the location monitoring 
notifications requiring him to check-in took place every night around 
the same time, the defendant would be able to ignore curfew and 
arrive home by 3:00a.m. 
4. 
In light of the defendant’s concerns about uninterrupted 
sleep and wish to travel locally by car, Officer Cooke is agreeable 
to outfit the defendant with a location monitoring ankle bracelet.   
Case 2:20-cr-00579-SVW     Document 865-1     Filed 08/11/21     Page 1 of 1   Page ID
#:15312

File and source

File

gov.uscourts.cacd.813905.865.1.pdf

Size

78,212 bytes

SHA-256

5b52d32d7b537b5c5fadb4535b71362f7611970555f5e7a1e51b6b2a1d08683c

Our copy

gov.uscourts.cacd.813905.865.1.pdf

Original

PACER (login required)