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

Summary

Document 865-1, a one-page Declaration of Christopher Fenton, a Trial Attorney at the Fraud Section of the Department of Justice, filed 08/11/2021 in the Central District of California, Case 2:20-cr-00579-SVW, United States v. Edvard Paronyan et al. It supports the government's opposition to Paronyan's ex parte motion to modify conditions of pretrial release. Fenton says Probation and Pretrial Services Officer Stacey Cooke told him on August 10 and 11, 2021 that location monitoring should remain, and that his claim of nightly check-in notifications around 3:00a.m. or 4:00a.m. is not true because they are random. Cooke is willing to give him a location monitoring ankle bracelet in light of his sleep concerns and wish to travel locally by car.

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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

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