Declaration Declaration of Michael G. Freedman — USA v. Ayvazyan et al (Dkt. 900.1)

Record facts

U.S. District Court for the Central District of California · No. 2:20-cr-00579-SVW · Doc. 900-1 · 2021-08-31 · Docket on CourtListener

Summary

A declaration of Michael G. Freedman, counsel for defendant Edvard Paronyan, filed August 31, 2021 as Document 900-1 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 supports a request for permission to travel and recounts that Paronyan was charged by the First Superseding indictment on March 9, 2021 (Dkt. 154), was released on a $75,000 bond later secured by real property, and signed a revised plea agreement that the Court accepted on June 11, 2021 (Dkt. 524). The declaration states that his release conditions prohibit overnight travel without permission and that he seeks to travel to Palm Springs from September 3, 2021 until September 6, 2021. It reports that the government and Pretrial oppose the request.

Summary drafted by a model from the document's text below and checked by script against that text before publication. It is a navigation aid, not a reading of what the document proves. Where AI is used

Full text

DECLARATION OF COUNSEL 
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 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 prohibit him from travelling  
overnight without permission from the Court. 
6. Mr. Paronyan hopes to take his family (wife and two young children) to  
Case 2:20-cr-00579-SVW     Document 900-1     Filed 08/31/21     Page 1 of 2   Page ID
#:15720

 
DECLARATION OF COUNSEL 
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
Palm Springs for the Labor Day weekend.  Specifically, he seeks to travel to Palm 
Springs on Friday, September 3, 2021 and remain there until Monday, September 
6, 2021, returning home to Los Angeles on September 6, 2021. 
7. I have communicated with Assistant United States Attorney Catherine Ahn,  
who represents the government in this matter. Ms. Ahn advised me that the 
government opposes the relief sought in this application.  I have also 
communicated with United States Pretrial Officer Devona Gardner who advised 
me that Pretrial opposes 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 August 31, 2021. 
/s/Michael G. Freedman  
 
 
 
 
 
 
 
Michael G. Freedman 
Counsel for Defendant  
Edvard Paronyan  
Case 2:20-cr-00579-SVW     Document 900-1     Filed 08/31/21     Page 2 of 2   Page ID
#:15721

File and source

File

gov.uscourts.cacd.813905.900.1.pdf

Size

164,717 bytes

SHA-256

88fc3c6ff0f41f4826df828b89b573d38381051b2089a3f06cb1400e4bb8113b

Our copy

gov.uscourts.cacd.813905.900.1.pdf

Original

PACER (login required)