Court filing

Sentencing Memorandum filed by Defendant Edvard Paronyan — USA v. Ayvazyan et al. (Dkt. 963, C.D. Cal.)

Filed September 13, 2021 in USA v. Ayvazyan et al.; one of 40 filings from this case.

Record facts

Court	U.S. District Court for the Central District of California
Filed	2021-09-13

U.S. District Court for the Central District of California · No. 2:20-cr-00579-SVW · Doc. 963 · 2021-09-13 · Docket on CourtListener

Full text

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MICHAEL G. FREEDMAN (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
WESTERN DIVISION

UNITED STATES OF AMERICA,

Plaintiff,
v.
EDVARD PARONYAN,

Defendant.
Case No. 20-579-SVW
DEFENDANT EDVARD
PARONYAN’S POSITION
REGARDING SENTENCING;
EXHIBITS
Hearing Date: September 27, 2021
Hearing Time: 11:00 a.m.

Edvard Paronyan, by and through his attorney of record, hereby files his position
regarding sentencing. This position is based upon the following memorandum, the
presentence report prepared by the United States Probation Office, the documents and
records on file in this matter, and any argument or evidence presented at the hearing on
this matter or which the Court may wish to consider.
Respectfully submitted,

DATED: September 13, 2021
By /s/ Michael G. Freedman
MICHAEL G. FREEDMAN
Attorney for Defendant
Edvard Paronyan

Case 2:20-cr-00579-SVW Document 963 Filed 09/13/21 Page 1 of 88 Page ID #:16386

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TABLE OF CONTENTS

MEMORANDUM OF POINTS AND AUTHORITIES .................................................. 1
I. INTRODUCTION ......................................................................................................... 1
II. SENTENCING GUIDELINES CALCULATIONS AND OBJECTIONS TO
THE PRESENTENCE REPORT ........................................................................... 2
A.
Mr. Paronyan Qualifies for a Four-Level Mitigating Role Adjustment ...... 2
B.
The Criminal History Category Overstates the Seriousness of Mr.
Paronyan’s Criminal History ....................................................................... 5
III. THE APPROPRIATE SENTENCE ........................................................................... 6
A.
Mr. Paronyan’s History and Characteristics ................................................ 7
B.
Circumstances of the Offense .................................................................... 10
C.
The Need to Provide Just Punishment ....................................................... 10
D.
The Need to Avoid Unwarranted Sentencing Disparities .......................... 12
E.
A Lengthy Prison Term Is Unnecessary to Deter Mr. Paronyan ............... 13
F.
A Lengthy Prison Term Would Delay Restitution for the Victims ........... 14
IV. CONCLUSION ........................................................................................................ 14

Case 2:20-cr-00579-SVW Document 963 Filed 09/13/21 Page 2 of 88 Page ID #:16387

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TABLE OF AUTHORITIES
PAGE
Cases
Gall v. United States,
552 U.S. 38 (2007) .................................................................................................. 6
Jordan v. De George,
341 U.S. 223 (1951) ................................................................................................ 12
Kimbrough v. United States,
552 U.S. 85 (2007) .................................................................................................. 6
Nelson v. United States,
555 U.S. 350 (2009) ................................................................................................ 6
United States v. Adkins,
937 F.2d 947 (4th Cir. 1991) .................................................................................. 5
United States v. Booker,
543 U.S. 220 (2005) ................................................................................................ 6
United States v. Gaind,
829 F. Supp. 669 (S.D.N.Y. 1993) ......................................................................... 11
United States v. Johnson,
No. 21-CR-60017 (S.D. Fla.) .................................................................................. 12
United States v. MacKay,
20 F.Supp.3d 1287 (D. Utah 2014),
aff’d, 610 F. App’x 797 (10th Cir. 2015) ............................................................... 11
United States v. Mendez-Velarde,
798 F. Supp. 2d 1249 (D.N.M. 2011) ..................................................................... 12
United States v. Quintero-Leyva,
823 F.3d 519 (9th Cir. 2016) .................................................................................. 3

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United States v. Tezna,
No. 21-CR-77 (E.D.V.A.) ....................................................................................... 12
United States v. Trosin,
No. 20-CR-4066 (N.D. Iowa) ................................................................................. 12
United States v. Vigil,
476 F.Supp.2d 1231 (D.N.M. 2007) ....................................................................... 11
United States v. Walker,
No. 20-CR-60159 (S.D. Fla.) .................................................................................. 12
United States v. Whitehead,
532 F.3d 991 (9th Cir. 2008) .................................................................................. 6

Statutes
18 U.S.C. § 3553 .................................................................................................... 1, 6, 13
Sentencing Guidelines
U.S.S.G. § 3B1.2 ......................................................................................................... 2, 3
U.S.S.G. § 4A1.3 ........................................................................................................ 2, 3

Other Authorities
Pub. L. No. 98-473, § 239, 98 Stat. 1987, 2039 (1984) ............................................. 13
U.S. Sent’g Comm’n, Measuring Recidivism: The Criminal History
Computation of the Federal Sentencing Guidelines (2016) ....................................... 13
David Weisburd, et al., SPECIFIC DETERRENCE IN A SAMPLE OF
OFFENDERS CONVICTED OF WHITE COLLAR CRIMES,
33 Criminology 587 (1995) .................................................................................... 13
Zvi D. Gabbay, Exploring the Limits of the Restorative Justice Paradigm:
Restorative Justice and White Collar Crime, 8 Cardozo J. Conflict Resol.
421, 448-49 (2007) ................................................................................................. 13

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MEMORANDUM OF POINTS AND AUTHORITIES
I. INTRODUCTION
Edvard Paronyan is a hard-working immigrant and devoted family man who
mistakenly and improperly obtained more PPP and EIDL loans than his legitimate
business was lawfully entitled to, in part to help keep his employees employed during
the pandemic. In contrast to Mr. Paronyan, the other defendants in this case were part
of a conspiracy involving fake identities and businesses and obtained far larger sums
than Mr. Paronyan, which they laundered for real estate purchases. Also unlike the
other defendants involved in that conspiracy, Mr. Paronyan took responsibility for his
misconduct early in this case through a guilty plea. After Mr. Paronyan’s first plea
agreement, the Court recognized he was not a member of the conspiracy, and Mr.
Paronyan continued negotiating with the government to plead guilty and take
responsibility for his own fraudulent conduct. And unlike the lead defendants, Mr.
Paronyan has not fled following his conviction and is prepared to be sentenced.
For the numerous reasons discussed below, Mr. Paronyan believes a sentence of
probation or home arrest is sufficient, but not greater than necessary. First, the PSR
calculated Mr. Paronyan’s sentencing range as 27-33 months based on a total offense
level of 16 and a criminal history category of III. But Mr. Paronyan should qualify for
a four-level mitigating role departure and his criminal history category is overstated, so
his sentencing range should be calculated as 12-18 months, placing him in Zone C.
Second, a sentence of probation or home confinement is a fair and just sentence
for Mr. Paronyan for numerous reasons under the factors enumerated in 18 U.S.C.
§ 3553(a). Mr. Paronyan overcame considerable hardships early in life, has built an
exemplary life for himself, and is devoted to his family, community, and employees as
described in dozens of letters to the Court. Indeed, the initial reason he obtained PPP
and EIDL loans was to be able to continue paying his employees, who praise him as a
boss. Of course, he ultimately violated the law by obtaining a higher amount than his
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business was entitled to and not using the loans only for his business, but he recognizes
his mistake and has experienced deep shame in his community. In addition to that
punishment, he will also face the severe punishment of likely deportation to Armenia,
where he has not lived since he was ten. These forms of punishment make it
unnecessary to further punish Mr. Paronyan with a lengthy term of imprisonment. A
lengthy term of imprisonment would also create a disparity between Mr. Paronyan and
other defendants nationwide who have stolen far larger sums in PPP loans, without any
legitimate businesses, much like the other defendants in this case too. A lengthy prison
term is also unnecessary to deter Mr. Paronyan, and would delay his ability to make full
restitution, which he intends to do as he rebuilds his life and career following the
pandemic and the mistakes he has made.
II. SENTENCING GUIDELINES CALCULATIONS AND OBJECTIONS
TO THE PRESENTENCE REPORT
The Probation Office calculated Mr. Paronyan’s sentencing guidelines range as
27-33 months. (PSR at 3.) This range was based on a total offense level of 16 and a
criminal history category of III. (Id.) As noted further below, Mr. Paronyan
respectfully disagrees with the Probation Office’s guidelines calculations.
A.
Mr. Paronyan Qualifies for a Four-Level Mitigating Role Adjustment1
Section 3B1.2 of the Sentencing Guidelines provides for a mitigating role
adjustment when the defendant is substantially less culpable than the average
participant. “The fact that a defendant performs an essential or indispensable role in
the criminal activity is not determinative. Such a defendant may receive an adjustment
under this guideline if he or she is substantially less culpable than the average

1 Although the PSR states that the parties agree not to argue for additional
specific offense characteristics, adjustments, and departures under the Sentencing
Guidelines, in fact the plea agreement provides an exception stating that Mr. Paronyan
reserves the right to argue for -- and the government reserves the right to contest -- that
an adjustment for mitigating role under U.S.S.G. § 3B1.2 applies. (PSR ¶ 5; Dkt. 469
at p. 16:1-3.)
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participant in the criminal activity.” U.S.S.G. § 3B1.2, comment. n. 3(C). “The
determination . . . is based on the totality of the circumstances and is heavily dependent
on the facts of the particular case.” Id. The Guidelines provide the following non-
exhaustive list of factors for the Court to consider:
(i) the degree to which the defendant understood the scope and structure
of the criminal activity; (ii) the degree to which the defendant participated
in planning or organizing the criminal activity; (iii) the degree to which the
defendant exercised decision-making authority or influenced the exercise
of decision-making authority; (iv) the nature and extent of the defendant's
participation in the commission of the criminal activity, including the acts
the defendant performed and the responsibility and discretion the defendant
had in performing those acts; (v) the degree to which the defendant stood to
benefit from the criminal activity.
Id.

And the Ninth Circuit has explained that:
Once the court has considered all the factors, however, it may grant or
deny a reduction even if some of the factors weigh toward the opposite
result. A district court, therefore, may grant a minor role reduction even
if some of the factors weigh against doing so, and it may deny a minor
role reduction even if some of the factors weigh in favor of granting a
reduction. And because the factors set forth in the Amendment are non-
exhaustive, a district court may also consider other reasons for granting or
denying a minor role reduction

United States v. Quintero-Leyva, 823 F.3d 519, 523 (9th Cir. 2016).
The PSR declined to apply a mitigating role adjustment based on its conclusion
that Mr. Paronyan “does not appear substantially less culpable than the average
participant: he alone stood to benefit from the funding of his fraudulent loan
applications; he alone applied for the EIDL loans and maintained full discretion in
applying for the loans; and Paronyan exercised all decision making authority over two
of the three loan applications.” (PSR ¶ 55.)
But this conclusion is incorrect for several reasons, and numerous of the
applicable factors make clear that Mr. Paronyan qualifies for a mitigating role
adjustment. Mr. Paronyan had very little knowledge, if any, of the scope and structure
of the criminal conspiracy in this case, no role in planning or organizing it, no decision-
making authority or influence, and his participation was tangential at best. The
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criminal activity in this case involved a wide-ranging conspiracy by other defendants to
use fake and stolen identities and fake companies to fraudulently obtain PPP funds and
then launder them into real estate purchases. As the Court recognized in rejecting Mr.
Paronyan’s first plea agreement, he was not a member of this conspiracy and did not
launder money. In contrast to the other defendants, Mr. Paronyan’s fraudulent loans
were obtained in connection with a legitimate business and were used in part for
legitimate payroll expenses. Mr. Paronyan does not deny the wrongful acts he
performed and his own responsibility for them, but even the PPP loan he obtained was
processed by others, who exercised their own discretion in setting the fraudulent
amounts. The PSR focuses on the fact that Mr. Paronyan alone benefitted from the
loans, but even on that issue Mr. Paronyan’s benefit was minor compared to the other
defendants. Mr. Paronyan received far less money than the other defendants, and spent
it far less exorbitantly. Whereas other defendants bought houses and watches with the
millions they stole, Mr. Paronyan used the several hundred thousand dollars he
obtained in part for legitimate payroll expenses and has admitted to using some of the
loan proceeds for improper purposes, primarily clothing and travel and other living
expenses. And he also loaned a significant portion of the proceeds to defendants
Ayvazyan and Terabelian, meaning they, not he, were the primary beneficiary. The
Court correctly recognized that this loan did not constitute money laundering, as Mr.
Paronyan expected to be paid back. Of course, Mr. Paronyan was never paid back by
these defendants, who have now fled following their own conviction at trial, but Mr.
Paronyan nonetheless will make full restitution for the loans he obtained. In contrast to
them, Mr. Paronyan has taken full responsibility for his misconduct, but his role was
minimal compared to them and every other defendant.
//
//
//
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B.
The Criminal History Category Overstates the Seriousness of Mr.
Paronyan’s Criminal History
Section 4A1.3 of the Sentencing Guidelines recognizes that there may be cases
where “a defendant’s criminal history category significantly over-represents the
seriousness of a defendant’s criminal history or the likelihood that the defendant will
commit further crimes.” U.S.S.G. § 4A1.3(b)(1). As one court has explained:
‘Criminal history’ is, relatively, one of the most flexible concepts in the
guidelines. While it is possible to classify the severity of current federal
offenses with a reasonable degree of precision, mathematically accurate
evaluation of the countless possible permutations of criminal history,
involving offenses high and petty committed in numerous jurisdictions,
would be at best unwieldy.

United States v. Adkins, 937 F.2d 947, 952 (4th Cir. 1991). As a result, a downward
departure based on criminal history over-representation is allowable under this section.
The facts surrounding Mr. Paronyan’s criminal history warrant a departure in this
case. Mr. Paronyan’s only prior convictions are for two misdemeanors. The first, for
auto theft, involved an incident from over a decade ago when Mr. Paronyan worked at a
wrecking yard, which, unbeknownst to him, had a stolen vehicle on the premises. (PSR
¶ 68.) Ultimately, Mr. Paronyan’s probationary sentence was terminated early and the
court ordered his plea set aside, and a plea of not guilty entered, and the matter was
dismissed. (Id.) This conviction accounts for one criminal history point. (Id.)
Mr. Paronyan’s only other conviction was for a DUI in 2018. (Id., ¶ 69.) While
admittedly serious and inexcusable, this conviction nonetheless has had an outsize and
disproportionate impact on Mr. Paronyan’s criminal history. In addition to the two
points it adds to his criminal history, Mr. Paronyan was also still on probation for one
more year at the time he was charged in this case, which means this single
misdemeanor conviction resulted in yet another two points being added to his criminal
history. (PSR ¶¶ 69, 71.)
Here, these two convictions take on much greater significance than they should
because they serve to increase Mr. Paronyan’s criminal history to 5 points. This results
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in a criminal history category III, as opposed to II if he had 2 or 3 points. Such a
dramatic change over-represents the seriousness of these prior convictions. As a result,
Mr. Paronyan believes that the Court should find that category II is the appropriate one
in this case.
Mr. Paronyan thus believes that a properly-calculated offense level is 12 and a
properly calculated criminal history category is II, resulting in a sentencing range of 12-
18 months and placing him in Zone C. Regardless, although the sentencing guidelines
are the starting point for the Court’s consideration of sentencing, Mr. Paronyan does
not believe that the guidelines adequately address all of Mr. Paronyan’s life
circumstances, the circumstances of his offense, and the other punishment he has and
will continue to suffer as a result of his offense.
III. THE APPROPRIATE SENTENCE
The core principles of sentencing have been resolved by the Supreme Court in
United States v. Booker, 543 U.S. 220 (2005), Gall v. United States, 552 U.S. 38
(2007), and Kimbrough v. United States, 552 U.S. 85 (2007). “The guidelines are not
only not mandatory on sentencing courts; they are also not to be presumed reasonable.”
Nelson v. United States, 555 U.S. 350, 352 (2009). Factors justifying a sentence
outside the guideline range are no longer required to be “extraordinary.” Gall, 552 U.S.
at 47. “One theme” runs through the Supreme Court’s recent sentencing decisions:
“Booker empowered district courts, not appellate courts . . . [and] breathe[d] life into
the authority of district court judges to engage in individualized sentencing. . . .” United
States v. Whitehead, 532 F.3d 991, 993 (9th Cir. 2008). Although the guidelines
remain the starting point for the Court’s consideration of Mr. Paronyan’s sentence, Mr.
Paronyan submits that they do not adequately address Mr. Paronyan’s unique life
circumstances. Mr. Paronyan submits that when the factors set forth in 18 U.S.C.
§ 3553(a) are considered, a sentence of probation or house arrest is sufficient, but not
greater than necessary, to achieve the aims of sentencing.
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A.
Mr. Paronyan’s History and Characteristics
From a young age, Mr. Paronyan has faced substantial hardships but has
overcome them to become a loving family man and a pillar of support to all who know
him. While this does not excuse his actions in this case, it does provide a context in
which to better understand his actions and it demonstrates that a significant downward
variance is warranted.
Mr. Paronyan was born in Armenia in 1980 and enjoyed a stable childhood with
his parents and younger brother until 1990, when the Soviet Union collapsed and
uprooted his and his family’s life. (PSR ¶¶ 77-80.) Mr. Paronyan was just ten years
old, but he was left in Armenia for three years to take care of his mother, while his
father and younger brother emigrated to Los Angeles. (PSR ¶ 80.) Armenia was in
crisis, with little energy or basic consumer goods, and Mr. Paronyan had to venture into
the woods to cut wood to keep himself and his mother warm and had to line up before
dawn in the hopes of finding bread for himself and his mother. (Id.)
Mr. Paronyan and his mother were finally able to join his father and brother in
Los Angeles after three years, but their financial circumstances were never the same as
they had been, and ultimately the turmoil caused Mr. Paronyan’s parents to divorce.
(PSR ¶¶ 80, 83.) Mr. Paronyan only learned English upon enrolling in middle school,
and has worked consistently since his early teenage years to help support his family.
(PSR ¶ 81-82.) His younger brother, Zaven, describes the sacrifices Mr. Paronyan
made for his family even at a young age:
Edvard had to grow up fast and be the man of the house when we left
them behind. . . . His dream to play college football was cut short after
1 year at Valley College our parents went through a divorce and he was
forced to drop out. He found a job and when I received scholarship to
play football in college he supported me financially. He didn’t let me
quit and he put my dream and goals over his. He supported my mom
also to get through the hard times. Because of his hard work I was the
first in family to graduate college. (Letter of Zaven Paronian, Ex. 1)

After dropping out of college to support his family, Mr. Paronyan spent
approximately a decade working in a junkyard and driving big rigs, before he decided
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to start his own business, Redline Auto Collision, in 2013. (PSR ¶¶ 97-101.) During
this time, Mr. Paronyan met his wife, Emily in 2005 and they wed in 2008, and now
have two children, Christopher, 11, and Milanna, 6. (PSR ¶ 84.) As numerous letters2
show, it is hard to overstate what an excellent husband and father Mr. Paronyan is:
He is smart and works very hard to make us happy and keep us safe.
My dad has a very big heart and always takes care of everyone . . .
My dad is the best dad in the world and I hope that he can stay with
us forever. (Letter of Chris Paronian, Ex. 2)
There are not enough words to explain what and amazing, loving
and caring person he is. He is so loved and respected from his family,
friends and anyone that knows him. (Letter of Emily Ghazakhetsyan, Ex. 3)
undoubtedly one of the greatest fathers I have ever come across.
Edvard is a devoted father who is always there for his children,
emotionally and physically. Seeing how attentive and caring Edvard
is with his children and all children is a breath of fresh air. My
children love Edvard like a second father. (Letter of K. Avakyan, Ex. 8)
As devoted as Mr. Paronyan is to his family, he is equally devoted to everyone in
his life, as dozens of letters demonstrate:
He is the closest thing I have to a brother. When asked who my family
is I think of him. Edvard has been by my side through all the worst and
best times of my life, from the loss of my mother, to the birth of my son.
He is a wonderful man. . . . I hope to have the same relationship with my
daughter as he does with his. The way they are bonded to each other is
something out of a novel. (Letter of G. Bastrmajyan, Ex. 10)
My neighbor's house had caught on fire, I had no idea what was going on,
I woke up to Mr. Paronyan banging on my door alongside firefighters to get
me and my son out. I was confused and terrified. If it had not been for his
calm and quick thinking I wouldn’t have been able to get out of there safely.
He had evacuated his family from the area and came back for us. That
is something I can never thank him enough for. (Letter of T. Davtian, Ex. 11)
I know Ed’s always there for me when I’m in need of guidance, His
positivity is unwavering and his commitment to family is unmatched,
I can honestly say that he is without a doubt one of the reasons I’m here
today. . . The world needs more people like Ed. (Letter of Arman
Gambaryan Ex. 15)
He has a genuine heart that will go above and beyond for someone he
2 The examples discussed here are just excerpts of the dozens of letters submitted
as exhibits along with this brief for the Court’s reference. Many of the writers will
attend Mr. Paronyan’s sentencing. Rather than express himself in a letter, Mr.
Paronyan intends to address the Court directly at sentencing.
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loves and someone who is in need. (Letter of Ani Gambaryan, Ex. 14)
Honesty, hard work, pure soul, love, dedication and “coolness” is what
sums up Edvard . . . his two beautiful kids will miss not only him, but
his emotionally indispensable presence. His wife loves him in so out
of control way that I cannot even imagine how she is going to handle
his absence. (Letter of A. Ilangesyan, Ex. 19)
a generous, kindhearted and a loyal friend . . . I know in my heart Ed is
still a good man that is capable of learning from this experience and
becoming even a better person because of it. (Letter of E. Kang, Ex. 20)
a selfless father putting his children’s needs ahead of everyone else . . .
the person you want as a friend. He will always be there and help in
any way. (Letter of A. Karabeyan, Ex. 21)
It wasn’t until I met Edvard that I learned what it’s like to have an older
brother. For the first time in a long time, I was able to feel what it was
like to have someone watch out for me, to care for me, and to help me
with whatever issue came my way. (Letter of A. Kesishvan, Ex. 22)
Meeting Eddy, I was 13 or 14 and I remember from the very first
interaction how kind, sweet, and warm hearted he was, and how
comfortable he made me feel. He took time to get to know me. . . .
No matter how small, big, or embarrassing my issues may be I have
never felt anything but love and genuine care in his feedback. I am
now 30 years old, and to this day he is the one person I know I can
count on always to support me. (Letter of L. Khachatryan, Ex. 23)
My car broke down in the middle of the street. . . Edvard helped me
push my car to a safe area on the road. He was a complete stranger . . .
he helped me, no questions asked. (Letter of H. Kim, Ex. 24)
fine and responsible character . . .a business owner [] known for being a
dedicated husband and father . . . a reliable, trustworthy, and decent
person. (Letter of A. Nath, Ex. 26)
My uncle, Edvards father, lives alone and has many health problems,
Edvard [is] one of the most caring and dependable sons I have the pleasure
of knowing. My uncle always makes sure to thank Edvard for being his
lifeline. Always making sure he has food to eat for the week, has a ride
to his doctor’s appointments. Edvard has showed to be a critical part of his
father’s life and is ready to lend a hand anytime he is needed. (Letter of S.
Pembedjian, Ex. 27)
a loyal friend, a motivator, and a helping hand . . . spreading positivity
wherever he went . . . he truly has a heart of gold. (Letter of A. Polaydan,
Ex. 28)
After her husband died suddenly, “Edvard spent everyday being there
for my children as an uncle to make sure they grieve and have a male
figure in their lives. He helped me grieve by being my by side everyday
and making sure I am able to hope again. He continues to be the supportive
friend as I continue to heal. (Letter of M. Tsotsikyan, Ex. 29)
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B.
Circumstances of the Offense
Mr. Paronyan’s offense involves three loans he obtained for his business, Redline
Auto Collision, during the Covid-19 pandemic in the spring and summer of 2020.
(PSR ¶¶ 31-39.). Although Mr. Paronyan knowingly obtained more PPP and EIDL
loan proceeds than his business was actually entitled to and did not use all the proceeds
as required for his business, the primary reason he sought the loans was so that he could
continue paying his employees during the pandemic. Mr. Paronyan accepts
responsibility for his unlawful conduct in connection with the loans, but believes that
his initially legitimate purpose in seeking the loans is a significant mitigating factor,
consistent with his exemplary character as described above. For example, many of the
letters that describe Mr. Paronyan’s work ethic and loyalty also specifically discuss his
attempts to keep his employees employed during the pandemic:
Through his positivity, perseverance and hard work he grew that business
to 10 times the size where he started. He is definitely a very successful
businessman. Some of success is owed to his caring a loving persona. It
is more fitting to describe his relationship with his staff as family than as
employees. (Letter of Y. Ghazakhetsyan, Ex. 17)
During pandemic when his business was struggling he made sure everyone
that works for him had money to put food on their tables. Pandemic changed
everyone’s life, but my husband made sure to protect and take care of his
work family as well. (Letter of E. Ghazakhetsyan, Ex. 3)
His business went through hard times during Covid and he didn’t let go
any of his employees even though he was losing money he didn’t want
to impact them and their families. (Letter of Z. Paronian, Ex. 1)
He is a great boss. He cares about his employees and treats them as
We are a family. During the difficult times, when pandemic started,
the business was very slow, we were hearing businesses closing left
and right, but Edvard was doing his best to pay his employees on
time and making sure were all doing well. (Letter of A. Yakhszyan, Ex. 30)
C.
The Need to Provide Just Punishment
Probation is a just punishment in this case for at least two unique reasons. First,
Mr. Paronyan has already suffered reputationally and financially since his arrest.
Second, Mr. Paronyan is almost certain to be deported back to Armenia, where has not
lived since he was ten years old, as a result of his conviction in this case.
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First, given Mr. Paronyan’s reputation in the community, as recounted above, his
mistake in this case has already cost him his standing in the community and caused
humiliation, stress, and financial hardship. These are factors the court should consider
in fashioning an appropriate sentence. See United States v. MacKay, 20 F.Supp.3d
1287, 1297 (D. Utah 2014), aff’d, 610 F. App’x 797 (10th Cir. 2015) (“[R]ecognizing
that the sentence imposed on MacKay must be just, the Court does not entirely
disregard the considerable negative impacts this case has already had on him and his
family. He has already lost standing in his community, faced the humiliation of a public
trial, lost his job, spent a great deal of money on his defense, and otherwise experienced
major financial setbacks, and has no doubt suffered many emotional pains and negative
health consequences that accompany such a process”); United States v. Gaind, 829 F.
Supp. 669, 671 (S.D.N.Y. 1993) (granting downward departure where defendant was
punished by the loss of his business); United States v. Vigil, 476 F.Supp.2d 1231, 1235
(D.N.M. 2007) (finding variance appropriate where defendant was collaterally punished
by loss of his position and reputation and widespread media coverage).
Consistent with his character, Mr. Paronyan has taken responsibility for his
mistake and has spoken openly about it with his community, sharing his remorse and
using his own mistake to encourage others to do better:
The fact his kids got to see his Dad being arrested at the house was
when he realized how he let his family down. Edvard has always
bounced back when things have not gone right and his ready and
has been working towards that since he was arrested. (Letter of Z.
Paronian, Ex. 1)

In a million years, I could not have imagined Edo doing the wrong
thing or hurting a fly. I am not sure in what state of desperation he
must have been in, to much such a wrong decision. . . . Even with
this sad situation, till this day he is super positive and encouraging.
He motivates all the young kids in our family to make the right
decisions in life. The other day, he pulled my 14 year old daughter
aside and said, “Higher Education is so important in life” I wish I
had such an education I would have thought twice before making a
rush or stupid decision.” (Letter of H. Arutunyan, Ex. 5)
He understands that his actions/decisions involved in this case
were not right. He deeply regrets the actions he took. (Letter of M.
Artunyan, Ex. 7)

Case 2:20-cr-00579-SVW Document 963 Filed 09/13/21 Page 15 of 88 Page ID #:16400

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He has shared the details of his case and clearly feels the shame and
pain of this mistake that has put him and his family in the current
situation. . . . There is no doubt he has made the biggest mistake
of his entire life and his entire family will be sharing in the punishment
with his absence. (Letter of S. Yi, Ex. 31)

Second, Mr. Paronyan is a permanent resident of the United States, but not a
citizen, unlike the rest of his family. By virtue of this felony conviction, he will likely
face removal proceedings to Armenia, where he has no relatives and has not lived since
he was ten years old. (PSR ¶ 87.) This is a severe consequence, which Mr. Paronyan
accepted in pleading guilty and taking responsibility for his offense. It is also a
significant mitigating factor in considering the amount of imprisonment necessary to
punish. See United States v. Mendez-Velarde, 798 F. Supp. 2d 1249, 1257 (D.N.M.
2011) (varying downward eighty months for myriad reasons, including defendant’s
deportation following his sentence); Jordan v. De George, 341 U.S. 223, 232 (1951)
(Jackson, J., dissenting) (deportation is “a life sentence of banishment in addition to the
punishment which a citizen would suffer from the identical acts.”).
D.
The Need to Avoid Unwarranted Sentencing Disparities
In addition to being less culpable than the other defendants in this case, Mr.
Paronyan is also less culpable than other defendants who have been sentenced for PPP
fraud both in terms of the total amount of money obtained and the fact that he did in
fact have a legitimate business. A downward departure therefore also is warranted to
avoid disparities with the sentences other PPP fraud defendants have received. See,
e.g., U.S. v. Trosin, No. 20-CR-4066 (N.D. Iowa), Dkt. 73 (40-month sentence for $1.3
million PPP and EIDL fraud scheme); Florida (33-month sentence for over $7 million
PPP fraud scheme); U.S. v. Tezna, No. 21-CR-77 (E.D.V.A.), Dkt. 19 (18-month
sentence for $350,000 PPP fraud scheme based on nonexistent payroll expenses); US.
v. Johnson, No. 21-CR-60017 (S.D. Fla.) Dkt. 54 (18-month sentence for $389,627 PPP
loan scheme); U.S. v Walker, No. 20-CR-60159 (S.D. Fla.), Dkt. 13 (12 months and a
Case 2:20-cr-00579-SVW Document 963 Filed 09/13/21 Page 16 of 88 Page ID #:16401

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day sentence for $258,575 PPP loan scheme for legitimate company but inflated payroll
numbers).
E.
A Lengthy Prison Term Is Unnecessary to Deter Mr. Paronyan
Section 3553(a)(2) requires courts to consider the need for a sentence to prevent
a defendant from engaging in future criminal conduct or endangering society. See 18
U.S.C. § 3553(a)(2)(B)-(C). In this vein, Congress has advised that “sentencing
decisions should be designed to ensure that prison resources are, first and foremost,
reserved for those violent and serious criminal offenders who pose the most dangerous
threat to society ….” See Pub. L. No. 98-473, § 239, 98 Stat. 1987, 2039 (1984) (note
to 18 U.S.C. § 3551). The empirical facts show that Mr. Paronyan poses virtually no
threat of recidivism or danger to society. As a married 40-year-old, Mr. Paronyan is
among the offenders least likely to recidivate in the entire criminal justice system. See
U.S. Sent’g Comm’n, Measuring Recidivism: The Criminal History Computation of the
Federal Sentencing Guidelines at 7, 12-13 & Exs. 2, 9- 11 (2016). This is particularly
true given the nature of Mr. Paronyan’s offense. See Measuring Recidivism, supra, at
Ex. 11 (first-time fraud offenders least likely to recidivate); David Weisburd, et al.,
SPECIFIC DETERRENCE IN A SAMPLE OF OFFENDERS CONVICTED OF
WHITE COLLAR CRIMES, 33 Criminology 587 (1995) (finding no difference in the
deterrent effect of prison and probation for white-collar offenders); Zvi D. Gabbay,
Exploring the Limits of the Restorative Justice Paradigm: Restorative Justice and White
Collar Crime, 8 Cardozo J. Conflict Resol. 421, 448-49 (2007) (finding “no decisive
evidence” supporting “conclusion that harsh sentences actually have a general and
specific deterrent effect on potential white collar offenders”). Mr. Paronyan has
accepted responsibility for his conduct during the pandemic, has already felt the effects
of his mistake on his business, family, and community, and faces deportation. A term
of imprisonment is unnecessary to deter him.
Case 2:20-cr-00579-SVW Document 963 Filed 09/13/21 Page 17 of 88 Page ID #:16402

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F.
A Lengthy Prison Term Would Delay Restitution for the Victims
Mr. Paronyan took responsibility early on in this case for his misconduct and
plans to make full restitution. (PSR ¶ 88.) He plans to do so by continuing to work at
Redline Auto Collision, which he will not be able to do if he is imprisoned. A lengthy
term of imprisonment would therefore delay restitution, which further justifies a
downward departure.
IV. CONCLUSION
Based on the foregoing, Mr. Paronyan respectfully requests that the Court
impose a sentence of probation or house arrest.
Respectfully submitted,

DATED: September 13, 2021
By /s/ Michael G. Freedman
MICHAEL G. FREEDMAN
Attorney for Defendant
Edvard Paronyan

Case 2:20-cr-00579-SVW Document 963 Filed 09/13/21 Page 18 of 88 Page ID #:16403

Ex. 1
Letter of Zaven Paronian
Case 2:20-cr-00579-SVW Document 963 Filed 09/13/21 Page 19 of 88 Page ID #:16404

Case 2:20-cr-00579-SVW Document 963 Filed 09/13/21 Page 20 of 88 Page ID #:16405

Case 2:20-cr-00579-SVW Document 963 Filed 09/13/21 Page 21 of 88 Page ID #:16406

Ex. 2
Letter of Chris Paronian
Case 2:20-cr-00579-SVW Document 963 Filed 09/13/21 Page 22 of 88 Page ID #:16407

Hi my name is Chris Paronian. I'm Edvard Paronyan’s son. I live with my dad,
mom,sister and 2 dogs. I want to tell you a little about my dad. He is smart and works
very hard to make us happy and keep us safe. My dad has a very big heart and
always takes care of everyone. I love playing video games with him and swimming
in the pool. Our favorite thing to do together is going fishing but this year we couldn’t
go. I am hoping soon he will be able to take me . My dad is the best dad in the world
and I hope that he can stay with us forever .
Case 2:20-cr-00579-SVW Document 963 Filed 09/13/21 Page 23 of 88 Page ID #:16408

Ex. 3
Letter of Emilya Ghazakhetsyan
Case 2:20-cr-00579-SVW Document 963 Filed 09/13/21 Page 24 of 88 Page ID #:16409

My name is Emilya Ghazakhetsyan. I am writing you today on behalf of my husband
Edvard Paronian who is scheduled to appear in your court for sentencing on
September 27th .I have known Edvard for over 15 years and been married to him
for over 13 years. We have 2 beautiful children . Our son Christopher is 11 years old
and looks up to his dad so much. And our daughter Milana is 6 years old and her
daddy is her idol and hero. My husband is our family's sole provider. I can tell you
that he is a good person, an intelligent and driven man, and by no means a danger
to society. He is one of the most hardworking and loyal man I know. He is loving
,caring and forgiving. We had a lot of ups and downs in life but he always worked so
hard to make sure his family was taking care of. He also is an amazing boss who
would do anything for his employees. During pandemic when his business was
struggling he made sure everyone that works for him had money to put food on their
tables. Pandemic changed everyone’s life , but my husband made sure to protect
and take care of his work family as well. There are not enough words to explain what
and amazing, loving and caring person he is . He is so loved and respected from his
family , friends and anyone that knows him.
I respectfully ask Your Honer to take these words into consideration when
sentencing him, I beg to Your Honer to give him a second change to prove himself
and that Your sentencing be merciful . Please take into account all the people whose
lives he has touched who will miss him, and especially how his absence will affect
the lives of our children.
Case 2:20-cr-00579-SVW Document 963 Filed 09/13/21 Page 25 of 88 Page ID #:16410

Ex. 4
Letter of Susanna Apoyan
Case 2:20-cr-00579-SVW Document 963 Filed 09/13/21 Page 26 of 88 Page ID #:16411

Honorable Judge Wilson,
I am writing to you in regards to Edvard Paronyan. I am Susanna Apoyan, the relative person of
his family. I am full time worker for grocery store and full-time student of university. I have known
Edvard Paronyan and his beautiful family for several years. He is a very humble and respectful man. He
always motivates everyone to be a better person. He is a very caring, loving, happy, respectful family
man and father. Thank you.
Respectfully submitted,
Susanna Apoyan
Case 2:20-cr-00579-SVW Document 963 Filed 09/13/21 Page 27 of 88 Page ID #:16412

Ex. 5
Letter of Helena Arutunyan
Case 2:20-cr-00579-SVW Document 963 Filed 09/13/21 Page 28 of 88 Page ID #:16413

Case 2:20-cr-00579-SVW Document 963 Filed 09/13/21 Page 29 of 88 Page ID #:16414

Case 2:20-cr-00579-SVW Document 963 Filed 09/13/21 Page 30 of 88 Page ID #:16415

Ex. 6
Letter of Maria Arutunyan
Case 2:20-cr-00579-SVW Document 963 Filed 09/13/21 Page 31 of 88 Page ID #:16416

Dear Judge Wilson,
Thank you for taking the time to read my letter. I am writing in regards to Edvard
Paronyan. My name is Maria Arutunyan, and I am a long time family friend of
Edvard. I am married to his friend who he has grown up with since the 90’s. I met
him through my husband in 2001 and we have been good friends since.
Edvard is not only a good friend, but also an amazing father, husband and son. He
is honest, hard working, loyal and always there for everyone that he can help. We
consider him our brother. We feel blessed to have him in our lives and to have
made many memories with him and his family. We are truly heart broken that
Edvard is in this situation. The thought of him being away from his wonderful
family, especially his children who are so attached to him is just devastating. He
has a very special bond with both his children from helping them with their
homework to tucking them eat at night. We are praying for Edvard to be with his
family and to be given another chance. We have faith in him and we want you to
know that nothing like this will ever happen again. As with all human beings, no
one is guaranteed to make perfect choices all the time. We all pray that we will
have a chance to make ourselves better and we can become better for us and
everyone around us. We ask for that chance for him.
Thank you again. Have a blessed day.
-Maria Arutunyan
Case 2:20-cr-00579-SVW Document 963 Filed 09/13/21 Page 32 of 88 Page ID #:16417

Ex. 7
Letter of Mher Arutunyan
Case 2:20-cr-00579-SVW Document 963 Filed 09/13/21 Page 33 of 88 Page ID #:16418

Case 2:20-cr-00579-SVW Document 963 Filed 09/13/21 Page 34 of 88 Page ID #:16419

Ex. 8
Letter of Katherine Avakyan
Case 2:20-cr-00579-SVW Document 963 Filed 09/13/21 Page 35 of 88 Page ID #:16420

Dear Judge Wilson,
My name is Katherine Avakyan and I have spoken with Edward about his case and Edward
explained what he has done and that he will be sentenced in the near future.
My husband, Ashot Keshishyan has also written a letter regarding our dearest Edvard. I am a 35
year old mother of three and a paralegal, though I have taken time off from my career to care
for my children. My relationship with Edvard grew once I started dating Ashot, however I first
met Ed when I was about 13 years old, as he is cousins with my best friend Suzie.
Growing up with Suzie was an exciting experience. Suzie and I are amongst a group of twelve
best friends who have remained friends for over 25 years! I take pride in the longevity of our
friendship, as it quickly grew to more than just a friendship, but a sisterhood where all of our
children are now best friends with one another. As teenagers, Edvard would watch over Suzie
and I all the time and always made sure we were safe and happy. I remember one hot summer
day when Suzie and I were walking home from summer school and Edvard “happened” to be
driving by at that exact same time. To no surprise, Edvard drove us home safely that day and
every other day for the remainder of our summer session. This is just one small example of how
large Edvard’s heart is. As a mother, I aspire for my children to grow up and befriend people like
Edvard, people who would go the extra mile for their friend without expecting anything in
return.
Edvard is not only an amazing cousin to my friend Suzie and an amazing friend to me and my
husband, but he is undoubtedly one of the greatest fathers I have ever come across. Edvard is a
devoted father who is always there for his children, emotionally and physically. Seeing how
attentive and caring Edvard is with his children and all children is a breath of fresh air. My
children love Edvard like a second father. Ever since my son Ben was about 2 years old he
would get Edvard to carry him and dance across the room. Edvard truly is a unique human with
one of the kindest hearts.
Though it is with great sadness that Ed will have to say his farewells to his children and to my
children, I pray that you take the above refences into consideration during sentencing. Thank
you for your time.
Best Regards,
Katherine Avakyan
Case 2:20-cr-00579-SVW Document 963 Filed 09/13/21 Page 36 of 88 Page ID #:16421

Ex. 9
Letter of Serine Ayvazyan
Case 2:20-cr-00579-SVW Document 963 Filed 09/13/21 Page 37 of 88 Page ID #:16422

Dear Judge Wilson,
I am Serine Ayvazyan, a licensed insurance agent. I work at State Farm insurance
as an insurance producer. In this letter I want to speak about Edvard Paronyan’s
personality traits and I truly hope it will help you get an impression of his character.
Edvard Paronian is my childhood friend’s husband and I have known him for about
fifteen years. First, I would like to describe Edvard as a parent, because his parenting
skills have always been outstanding. The bond that he has with his children is hard
to describe. He is a loving and caring father, who has active participation in the
process of bringing up his children. Through these years, I have witnessed how he
took care of his two children by always being there for them. He travelled with them
to help them explore the world surrounding them, trained with them, as his son loves
playing basketball, and his daughter loves to swim. Recently Emily (Edvard’s wife
and my best friend) had to take care of her mother in the hospital, as she has gone
through a life threatening surgery. I was amused how Edvard, all by himself, took
such good care of his children, as it was really hard for all of them to be apart for
almost a month.
Next, I want to describe Edvard as a husband. Through all these years he was a
responsible and very committed husband for Emily, always there through good and
also tough times. He has always been very respectful and attentive towards his wife,
and always worked hard to provide for his family.
Finally, I want to describe Edvard as a friend. He is the kind of friend that is always
there when you need him, a very cheerful person to be around, and the spirit of the
company. But most of all, I know I can always rely on him during difficult times.
None of these words are exaggerated to a single degree. Edward is a man of good
heart, who is loved and respected by all.
Best Regards,
--
Serine Ayvazyan
Case 2:20-cr-00579-SVW Document 963 Filed 09/13/21 Page 38 of 88 Page ID #:16423

Ex. 10
Letter of Gevork Bastrmajyan
Case 2:20-cr-00579-SVW Document 963 Filed 09/13/21 Page 39 of 88 Page ID #:16424

Dear Jude Wilson,
I, Gevork Bastrmajyan am writing this letter for my friend and now brother Edvard
Paronyan. He and I have known each other for 30 years. He is the closest thing I
have to a brother. When asked who my family is I think of him. Edvard has been by
my side through all the worst and best times of my life, from the loss of my mother,
to the birth of my son. He is a wonderful man.
I travel a lot for work and constantly have to leave my wife and son home alone. I
feel reassured leaving them knowing. Edvard is right down the street ready to help
at any moment. He has guided me through difficult personal and work choices I am
so thankful for.
Edvard is also a wonderful family man. He is devoted to his wife and children. He is
always planning activities with them and making sure his friends do the same with
their families. Even now in his difficult time he does not allow anyone to see it. He is
a great father figure, I hope to have the same relationship with my daughter as he
does with his. The way they are bonded to each other is something out of a novel.
Edvard has been a wonderful son figure to my dad as well. Despite my father having
so many others around him he can call his first phone call after me is to Edvard. He
makes sure my dad is okay and taken care of. He lives alone so Edvard does his
best to make sure he has food in the fridge and all of his affairs are in order. Despite
having parents of his own and he takes the time to drive him to and from doctor
appointments when I am unavailable.
I thank you for taking the time to read this letter and I hope you’ll take into
consideration what a great
human being Edvard is.
-Gevork Bastrmajyan
Case 2:20-cr-00579-SVW Document 963 Filed 09/13/21 Page 40 of 88 Page ID #:16425

Ex. 11
Letter of Tina Davtian
Case 2:20-cr-00579-SVW Document 963 Filed 09/13/21 Page 41 of 88 Page ID #:16426

Dear Judge Wilson,
My name is Tina Davtian, I am a 3rd year medical student at Keck Medicine of USC.
I am writing this letter for my dear friend Edvard Paronyan. He and I have know each
other for over 12 years, he has become part of my family. Edvard has been a great
supporter in my difficult journey to becoming a doctor. He has helped me study for
exams and given me the motivation I needed to continue. Not to mention he has
become one of the best and most reliable babysitters for my 4 year old son. He’s
there anytime we need him. These days those are very hard to come by. Two years
ago we decided to pack up and move to Granada Hills to be closer to Edvard and
his family because we rely on them so much.
Last year during the terrible brush fires of Granada Hills, my husband was out of the
country and I was home alone asleep with our son when they started evacuations.
My neighbor's house had caught on fire, I had no idea what was going on, I woke up
to Mr. Paronyan banging on my door alongside firefighters to get me and my son
out. I was confused and terrified. If it had not been for his calm and quick thinking I
wouldn’t have been able to get out of there safely. He had evacuated his family from
the area and came back for us. That is something I can never thank him enough for.
My family is not the only one who values and loves him so dearly. He is a pillar of
strength for many people. He is loved and treasured by those who know him. He’s
the kind of man the community needs. He is the kind of friend we all need in our
lives. I say with great certainty that we will all suffer a great loss if he is not around,
even for a short period of time. I hope you’ll take this letter into consideration. Thank
you.
-Tina Davtian
Case 2:20-cr-00579-SVW Document 963 Filed 09/13/21 Page 42 of 88 Page ID #:16427

Ex. 12
Letter of David Dermenjian
Case 2:20-cr-00579-SVW Document 963 Filed 09/13/21 Page 43 of 88 Page ID #:16428

David Dermenjian
11980 Wood Ranch Rd.
Granada Hills, Ca 91344
Honorary Judge Wilson,
My name is David Dermenjian and I am writing this letter in regards to Edward Paronyan.
I am 53 years old, happily married and a father of three beautiful daughters.
I am the owner/CEO of Bakersfield Community Healthcare located in Bakersfield, California.
Bakersfield Community Healthcare consists of Home Health, Hospice and Adult Day Healthcare
Center and has over 55 employees and has been in business since 2012.
I’ve known Edward Paronyan for little over 20 years, as he is a cousin of my wife. Edward and I
did build a very close relationship, as he is a very down to earth, smart, respectful, good parent
to his kids, family man and trustworthy individual. I did watch him grow, get married and build a
beautiful family. My wife and I have left our kids to stay with Edwards family on several
occasions when we left the country on vacations. My family and I feel fortunate to have Edward
in our family.
I have had several long conversation with Edward about his current situation with the law as he
is waiting to be sentenced. In my 33 years of living in US, I have never had issues with the law
and I take big pride in it. This is the first time I am writing a letter in this character.
Edward looks up to me and takes my words very serious. He considers me like an older brother
to him. I am not going to talk about Edwards business, employees as I don’t know too much
about it. I have visited his shop several times and no one seemed to be complaining.
I prefer not to get into details of the case, as I am not the prosecutor nor the defense attorney on
the case or about his sentencing that’s coming up, as it is truly in your hands as a Judge.
All I would ask of you is be gentle on him, he is a good man and his two kids need him buy their
side.
Dear Judge, If the need arrises, I am ready to come in anytime and discuss with you and put in
good word for Edward.
I am available any time if you need me to stop by and talk to you. I can be contacted at
(818)400-2300.
Honorary Judge Wilson,
I thank you very much for reading my letter.
Thank you,
God Bless You and our country of USA.
Sincerely, David Dermenjian
Case 2:20-cr-00579-SVW Document 963 Filed 09/13/21 Page 44 of 88 Page ID #:16429

Ex. 13
Letter of Christine Gabrielian
Case 2:20-cr-00579-SVW Document 963 Filed 09/13/21 Page 45 of 88 Page ID #:16430

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Ex. 14
Letter of Ani Gambaryan
Case 2:20-cr-00579-SVW Document 963 Filed 09/13/21 Page 47 of 88 Page ID #:16432

1
Honorable Judge Wilson,
The purpose of this letter is to provide a character reference for Mr. Edvard Paronyan whom I have known as a
brother/family for over 10 years. One word that would describe Edvard Paronyan is, caring. He has a genuine heart
that will go above and beyond for someone he loves and someone who is in need. He’s a hard working man that
provides for his family. He’s a devoted husband and an amazing father to his two beautiful children. Edvard is loved
man by his family and friends. Wherever he is, his cheerful character captivates the people around him. His positive
energy is something his family and friends would not want to miss. I trust you will take this letter into consideration
as you determine the resolution of the matter before you.
Sincerely,
Ani Gambaryan
Sent from my iPhone
Case 2:20-cr-00579-SVW Document 963 Filed 09/13/21 Page 48 of 88 Page ID #:16433

Ex. 15
Letter of Arman Gambaryan
Case 2:20-cr-00579-SVW Document 963 Filed 09/13/21 Page 49 of 88 Page ID #:16434

August 19, 2021
Arman Gambaryan
1144 N Edgemont st.#2
Los Angeles, CA 90029
Dear Honorable Judge Wilson,
I’m Arman Gambaryan. I own a small business in Van Nuys that provides for my
growing family. I’ve known Edvard Paronyan (or as I call him, “Ed”) since I was a sixteen
year-old kid. Ed, quickly became family in no time.
I’ll try to keep this short. Trying to fit Ed into a few paragraphs is not an easy thing
to do. I should probably start with his sense of humor because that’s one of the first things
I noticed about him, He’s always up for a laugh or corny joke. No matter the situation his
spirit is up high! I then have to mention what a determined and dedicated dad he is to his
kids; what a great husband he is to his wife; and what a solid big bro he’s been to me.
When my life was in the pits and I was struggling with my depression, I knew Ed
cared. If it wasn’t a phone call every week, it was a funny video he found on YouTube. He
would always check in on me. It’s sometimes the little things people do that help us get
through our day to day. I know Ed’s always there for me when I’m in need of guidance, His
positivity is unwavering and his commitment to family is unmatched, I can honestly say that
he is without a doubt one of the reasons I’m here today.
P.S. The world needs more people like, Ed.
- Arman G.
Case 2:20-cr-00579-SVW Document 963 Filed 09/13/21 Page 50 of 88 Page ID #:16435

Ex. 16
Letter of Narine Gambaryan
Case 2:20-cr-00579-SVW Document 963 Filed 09/13/21 Page 51 of 88 Page ID #:16436

Honorable Judge Wilson,
I am writing to you in regards to Edvard Paronyan and I just want portray what kind
of role he plays in life. I am Narine Gambaryan, the sister in law of his wife. I am
currently a stay at home mother of a beautiful little girl and another on the way.
Edvard was the best man at my wedding and his wife Emily was maid of honor. They
continue to be Godparents to our children. I have known Edvard for 10 years, I
remember the day I met him and Emily, it felt as if I had known him all my life. He is
the kind of man that wears his heart on his sleeve and it shows from the instant you
meet him. He made sure I felt apart of the family from day one, he even let my
husband know in front of everyone (50 plus people) that he approved of me and that
I was a keeper. From that day on we became a family not from when I got married
but from that very first day we met. He has been there for my husband and I through
our toughest times. He would take time away from work and his kids to sit there and
listen to us and give us guidance in our relationship. Edvard loves to be surrounded
by his family and friends. He is always doing barbecue and calling us over for family
time. He is the ultimate family man that everybody loves and respects. He is such a
positive energy to be around. Edvard is the man everybody goes to when they need
to be lifted or just need some words of encouragement and some positivity. He
wanted us to start a family since the second we were married. When we had our little
girl he was so ecstatic he said okay now try for baby number two. My daughter views
him as gentle giant. She loves her godfather and loves to fall asleep in his arms. He
is the most giving man I know, he gives without waiting for anything in return. When
I wanted to start my career as a makeup artist he said do it without thinking twice
and he gave me the money I needed for my courses. My entire family, my father my
mother my siblings my aunts and uncles and cousins all love Edvard. He is definitely
one of a kind and it breaks my heart the thought of not being able to see him for
some time. He is an amazing husband and father of two beautiful children that love
and look up to him. He is his daughters hero. In fact he is everybody’s hero. Please
find it in your heart to give him leniency in his sentencing. Thank you. Respectfully
submitted,
Narine Gambaryan
Case 2:20-cr-00579-SVW Document 963 Filed 09/13/21 Page 52 of 88 Page ID #:16437

Ex. 17
Letter of Yurik Ghazakhetsyan
Case 2:20-cr-00579-SVW Document 963 Filed 09/13/21 Page 53 of 88 Page ID #:16438

Honorable Judge Wilson,
I am addressing this letter in an attempt to depict Edvard Paronyan for who he is.
My Name is Yurik Ghazakhetsyan, I own a small State Farm Insurance agency in
North Hollywood. My relationship to Edvard goes a long way as I have known him
for over 14 years. Edvard is married to my sister and quite frankly I could not ask for
a better person to be next to my sister. Edvard was also the best man at my wedding
along with my sister as maid of honor. In addition, they are the godparents to our
beautiful daughter Eliana and her sister who is due be welcomed this December. Not
to mention he is also a dear friend. Edvard has always been a pillar for those around
him. Enough cannot be said about this man. Through thick and thin his always been
the same loving, positive, caring and supportive individual. His always been
hardworking, since the first day he opened his Collision center some years ago, in a
small 800sqft facility. Through his positivity, perseverance and hard work he grew
that business to 10 times the size where he started. He is definitely a very successful
businessman. Some of success is owed to his caring a loving persona. It is more
fitting to describe his relationship with his staff as family than as employees. Most
importantly, he is an amazing husband and an amazing father to two beautiful
children. It’s safe to say that his two kids and his wife are the center of his universe.
If at all possible, please consider these facts at his sentencing hearing.
Regards,
Yurik Ghazakhetsyan
Case 2:20-cr-00579-SVW Document 963 Filed 09/13/21 Page 54 of 88 Page ID #:16439

Ex. 18
Letter of Rita Hagopian
Case 2:20-cr-00579-SVW Document 963 Filed 09/13/21 Page 55 of 88 Page ID #:16440

Dear Judge Wilson,
My name is Rita Hagopian; I am a local business owner for the past 15 years and I have known the
defendant, Edvard Paronyan, since 2015. For the past 6 years, I have gotten to know him very well and
can say with the utmost confidence that he is a loving, warm, caring, and compassionate individual.
When I first met him, I was going through some very difficult times, and he not only helped myself but
my kids as well, feel safe and loved. His laugh is infectious and would always brighten our room and help
keep us all focused on the good in life rather than all the negative. As our families got closer and closer
we would go on vacations together and he became a part of our family. He loves my children like his
own and is the best uncle possible. They absolutely love being around him. He is so considerate as a
parent and friend. You never have to worry about needing a friend to help in any situation. He will
always be there to help out.
Every weekend we are together for barbeques, birthdays, or just to watch the Lakers. He is a homely,
good man and gives back to the community. He loves his Armenian roots which he is very proud of,
always tries to help his community and the school his kids attend. He employs multiple individuals at his
place of business and helps keep food on those families’ tables.
Edvard is extremely conscious of people’s feelings and wants to help anyone when they are down. He is
an amazing cheerleader for personal development and for self-confidence. He can make anyone feel on
top of the world with one of his great pep-talks. Edvard is a great friend, father, boss, and leader.
I am aware he is going to be sentenced soon, and I hope that his personality and who he really is, a
hardworking - loving father and friend is taken into consideration. Thank you for your time.
Best,
Rita Hagopian
818-256-5453
Case 2:20-cr-00579-SVW Document 963 Filed 09/13/21 Page 56 of 88 Page ID #:16441

Ex. 19
Letter of Arthur Ilangesyan
Case 2:20-cr-00579-SVW Document 963 Filed 09/13/21 Page 57 of 88 Page ID #:16442

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Ex. 20
Letter of Eric Kang
Case 2:20-cr-00579-SVW Document 963 Filed 09/13/21 Page 60 of 88 Page ID #:16445

Eric Kang
11280 La Maida St #203
North Hollywood, CA 91601
Dear Honorable Judge Wilson,
My name is Eric Kang. I have operated a business and worked in the travel industry for 25 years. I am
currently looking for another business opportunity.
I first met Edvard (Ed) Paronyan approximately 5 years ago at a social gathering. We became friends
soon after. Over these years, I have known him to be a generous, kindhearted and a loyal friend. To give
some examples, he is the type of person that would be the first one to “grab” the dinner tab when out
with friends. When he would ask how things were going on in my life, he would listen carefully to my
responses and then offer a kind word or suggestion. In these conversations he would also share with me
how much he cared for and loved his family. His family means the world to him. I found his approach to
our conversations sincere and genuine; never embellished or exaggerated. Although I never found
myself needing to ask him for a favor or assistance, I know he could be counted on if needed.
To say the least, I was taken aback when he told me about his legal situation. With great remorse in his
voice, he explained to me what he did and what he was facing as possible punishment for his actions.
Understanding what he was going through, it was difficult knowing there was little or nothing I could do
other than being a source of moral support. When he finally asked if I could help by writing a letter on
his behalf, I did not hesitate. I do so willingly because I know in my heart Ed is still a good man that is
capable of learning from this experience and becoming even a better person because of it.
Thank you very much for this opportunity to share my thoughts.
Sincerely,
Eric Kang
Case 2:20-cr-00579-SVW Document 963 Filed 09/13/21 Page 61 of 88 Page ID #:16446

Ex. 21
Letter of Anna Karabeyan
Case 2:20-cr-00579-SVW Document 963 Filed 09/13/21 Page 62 of 88 Page ID #:16447

Dear Judge Wilson,
My name is Anna Karabeyan and I am a close family friend of Edvard Paronyan I
have been an educator for over 20years working with underserved children in the
Los Angeles Unified School District. I am writing this letter because I have come to
know and respect Edvard for the kind person he is. I have witnessed Edvard show
kindness to everyone from young children to the elderly. As an educator I tend to
pay close attention to people’s character traits and Edvard most definitely got my
attention for the amazing person he is.
I have seen him be a selfless father putting his children’s needs ahead of everyone
else. As an educator I know how important it is for a child to have their parent’s
presence and how devastating it could be on a child’s mental and emotional state
not to have their parent around. I hope and pray there is a way Edvard’s children
never feel the absence of their father. He is a great friend who goes above and
beyond for everyone in his life. I have witnessed on many occasions Edvard offering
his help when someone was in dire need. It is simple acts of kindness that we tend
not to forget. I will never forget how good he has been towards my family. Any time
my husband and I go out of town Edward is the first one to check on my children.
Although my kids have always been taken care of, he still checks in to see how he
could be of service. Those things are so important, it gives a person a sense of
community. Edvard is the person you want as a friend. He will always be there and
help in any way, as long as he thinks you’re in need of help. I have known many
people professionally and personally and can wholeheartedly say Edvard is one of
the best people I know. He is a good father, husband, friend, and overall person.
Thank you for your time.
Yours Truly,
Anna Karabeyan
Case 2:20-cr-00579-SVW Document 963 Filed 09/13/21 Page 63 of 88 Page ID #:16448

Ex. 22
Letter of Ashot Keshishyan
Case 2:20-cr-00579-SVW Document 963 Filed 09/13/21 Page 64 of 88 Page ID #:16449

Dear Judge Wilson,
My name is Ashot Benjaminovich Keshishyan, and I am writing to you today regarding my
dearest friend and companion, Edvard Paronian. I have spoken with Edvard about his case and
Edvard explained what he has done and that he will be sentenced in the near future.
In order to provide some background, I would like to introduce myself. I am a 36 year old father
of three, my children are 5, 4 and 6 months. My oldest child, Natalie, is the same age as I was
when I first immigrated to the United States with my parents and younger brother. Similar to
numerous immigrant families, upon arriving to the states my family and I started our uphill
journey assimilating to the American culture. As the eldest child, I had to grow up fast and look
over my little brother, and soon to be born baby sister. When I was about 18 years old my
father took me to work with him at an auto body shop in the San Fernando Valley. Little did I
know that this new job was going to lead to a life-long friendship with Edvard Paronian.
Edvard and I started off as co-workers and our friendship progressed so rapidly that I find it
extremely difficult to remember a time where we weren’t best friends. Growing up as the
oldest child always had its shortcomings. Having a sister 10 years younger than me, and a father
who was working over 10 hours a day, 7 days a week, I found myself taking on both the role of
a father to my little sister and an older brother to my younger brother. It wasn’t until I met
Edvard that I learned what it’s like to have an older brother. For the first time in a long time, I
was able to feel what it was like to have someone watch out for me, to care for me, and to help
me with whatever issue came my way. Though we are not blood related, Edvard and I have
always been and always will be brothers.
Edvard and I quickly grew up together. Before I knew it Edvard was the first one amongst our
friends to marry and have a child. Seeing Edvard as a husband and father was inspirational, and
that’s not a compliment I take lightly (as my own father set a really high standard). Edvard is not
only an amazing husband, but he is an exceptional father, always making time for his children
and putting their needs first. Edvard is also a loving uncle to his brother’s child and to my three
children. When my kids see Edvard walking up my driveway, they run into his arms yelling
“uncle Ed.” When it comes down to it, I know that Edvard will walk to the ends of the earth to
help his family, his friends, or anyone who he sees in need. Edvard is a loyal friend, a devoted
father and a loving husband. After spending almost 20 years together, I can wholeheartedly say
that Edvard is a very special human being. Though his exterior may be misleading, internally he
is the kindest most gentle human I have ever met.
Though it is with great sadness that I must part ways with my best friend Ed, I plead with you
Judge Wilson to take the aforementioned into consideration during sentencing. Thank you for
taking the time to read my letter and to hear what I have to say about my dearest friend
Edvard.
Best Regards,
Ashot B. Keshishyan
Case 2:20-cr-00579-SVW Document 963 Filed 09/13/21 Page 65 of 88 Page ID #:16450

Ex. 23
Letter of Linda Khachatryan
Case 2:20-cr-00579-SVW Document 963 Filed 09/13/21 Page 66 of 88 Page ID #:16451

Linda Khachatryan
818.442.8277
LKhachatryan@me.com
RE: Edvard Paronyan
To Whom It May Concern:
My name is Linda Khachatryan, I am a Leasing Manager for Unibail Rodamco Westfield. I am writing to
you on behalf of Edvard Paronyan’s character and what he means to me. Firstly, I am related to Edvard
Paronyan by way of marriage, his wife Emilia is my cousin. I have known Eddy for as long as he has been
in my cousin’s life. When I first heard about this case, I was shocked and heartbroken. Please know, I
was never asked to write this letter, however I felt an internal obligation to do so based on knowing
Eddy, his heart, and who he is at his core, at his purest and most vulnerable. It is easy to read
information about someone on paper and keep it very black and white. However, to know Eddy it’s hard
to imagine life, even momentarily, without him by our side – and that’s where our world turns to gray.
I grew up being the oldest of 3 girls, with a very relaxed man for a Father. He was an amazing dad,
worked extremely hard from the moment he stepped foot in the United States to provide for us - but all
he knew was work, dinner, and sleep. Rarely do I remember sitting down for conversations with him,
getting direction or feedback, much less vacations or time spent hanging out and this is the case to this
day. Meeting Eddy, I was 13 or 14 and I remember from the very first interaction how kind, sweet, and
warm hearted he was, and how comfortable he made me feel. He took time to get to know me. As his
life progressed with my cousin, he made sure to include me in everything, and I felt welcomed. Emilia is
my family, but Eddy is the reason we became so close. I have male cousins, but for the first time in my
life I felt like I had a brother, someone I can depend on and count on to help me, give me advice, and no
matter what time he was always a phone call away. No matter how small, big, or embarrassing my
issues may be I have never felt anything but love and genuine care in his feedback. I am now 30 years
old, and to this day he is the one person I know I can count on always to support me. He was the first
person to find out about my boyfriend, and he gave me honest advice about how to move forward and
how to introduce him to everyone else. He is the person I go to when I’m having a bad day and need
honest feedback, he’s the first person I think of sharing news with when I have something great happen
in my life. My boyfriend has two older brothers, but when he needs an honest opinion or a friend to talk
to, Eddy is the first person he thinks of. When we talk about marriage Eddy is the only person we think
of to be the best man, when we talk about having our own children and who we would want to be there
for them Eddy is the only person we think of as a Godfather. When we talk about the future and buying
a home, we always talk about how amazing it would be to be neighbors, because living 15 minutes away
is too far. In every conversation we have about our lives and the future, the 2nd or 3rd sentence always
has to do with how we can include Eddy in it. Edvard has a remarkable way of touching lives and leaving
a warm imprint on everyone who meets him, you immediately build a bond. I love his son and daughter
DocuSign Envelope ID: 17531FCC-1DEE-443A-AECC-9BBDB06DE124
Case 2:20-cr-00579-SVW Document 963 Filed 09/13/21 Page 67 of 88 Page ID #:16452

and so much of that loves for them comes from the love I have seen from Eddy. Every good moment in
my life goes back to Eddy, every happy memory has him in it, and so much of who I am as a person
today has to do with his guidance and support. When I was changing careers and getting into leasing, I
was scared out of my mind and Eddy sat down with me and talked to me about my concerns and fears,
he makes me feel like I can never fail if I just try and believe in myself. Stepping into every promotion
and every step up professionally and personally has been with his hand on my back. As an aunt to his
children, I can only hope to someday be as important and impactful to them, as Eddy has been to me. I
hope to show them the love and support their father has shown me and continues to show me through
my most crucial years and most important decisions. And some day as a mother, I hope to give my
children the love, support, and courage to go after every dream they have the way he has done with me.
I see his support of my cousin and their children. No matter how bad his day has been he never allows
those around him to feel it. My aunt has cancer and last March her colon exploded, Emily was stuck in
the hospital for days at a time and Eddy was there to be her strength mentally and emotionally and was
there to make sure his kids never missed a beat with meals, school, homework, or life. When she was
released from the hospital the world went into lockdown, and Eddy had my aunt and her husband stay
with them, so they were taken care of and did not have to leave the house for anything. This may seem
like a small thing to do, except he didn’t have to give up his home, comfort, and freedom within his own
4 walls to have his in-laws move in. In his hardest of times, he has put himself aside to ensure my cousin
feels supported – the strength he has given her to fight through for her mom when most men would not
be capable of seeing outside themselves makes me love him so much more each and every day. My
niece has an incredible bond with her mom, but the world is set aside when Eddy is around, she would
much rather be at home watching movies with him then be anywhere else in the world with anyone
else. When my nephew speaks about Eddy, his eyes light up like he’s talking about his favorite
superhero from a movie – there is so much pride in every word he speaks of his dad. My heart aches
imagining a day where my nephew won’t have that pride when he speaks of him, or a day when my
niece won’t have her “daddio” to snuggle up to on the couch to watch another movie or learn more
about football, soccer, and basketball.
When the time comes, I ask the courts to please consider not just Edvard in his sentencing, but his
family. To think of his 6-year-old daughter who would rather be home next to her dad than anywhere,
and his 11-year-old son whose hero he is and not allow that to fade into “was”. To consider his wife who
looks for his support and strength each and every day. To not take away our foundation. He truly is an
exceptional human being and outstanding member of society.
To know Edvard is genuinely is my honor, to know Edvard is to love him.
Thank you,
Linda Khachatryan
DocuSign Envelope ID: 17531FCC-1DEE-443A-AECC-9BBDB06DE124
Case 2:20-cr-00579-SVW Document 963 Filed 09/13/21 Page 68 of 88 Page ID #:16453

Ex. 24
Letter of Hana Kim
Case 2:20-cr-00579-SVW Document 963 Filed 09/13/21 Page 69 of 88 Page ID #:16454

Case 2:20-cr-00579-SVW Document 963 Filed 09/13/21 Page 70 of 88 Page ID #:16455

Ex. 25
Letter of Vram Manukyan
Case 2:20-cr-00579-SVW Document 963 Filed 09/13/21 Page 71 of 88 Page ID #:16456

Dear Judge Wilson,
My name is Vram Manukyan. I am a U.S. citizen, the United States has been my
home for almost 28 years. Edward Paronyan has been my best friend since 1994. Our
friendship began at Joseph LeConte Middle School. After graduating middle school I
transferred to Hollywood High School. After attending a year of high school, Edward
graduated middle school and joined me in Hollywood High School.
During our teenage years we spent most of our time together. He was always very
respectful towards everybody, he was helpful, and always made sure everyone around
him was happy. I have never seen or heard anything bad about him.
After many years, we both got married and grew our friendship even tighter because
our families are close to each other as well. Then we both had our own kids. They
became really close like brothers and sisters. Till this day they have the same bond.
In 2021, I decided to Christian my kids. There was no better candidate to be the
godfather than Edward Paronyan because my kids love him very much. He is kind
hearted, caring, and the funnest person to be around. He became the godfather of my
kids in Saint Peter Armenian Apostolic Church.
Dear Judge Wilson, I hope you will find forgiveness in your heart and give a second
chance to our caring friend, father, and godfather. Thank you for taking the time to read
this letter and getting to know Edward better.
Thank you,
Vram Manukyan
Case 2:20-cr-00579-SVW Document 963 Filed 09/13/21 Page 72 of 88 Page ID #:16457

Ex. 26
Letter of Amit James Nath
Case 2:20-cr-00579-SVW Document 963 Filed 09/13/21 Page 73 of 88 Page ID #:16458

Amit James Nath
17048 Itasca St.
Northridge CA 91325
August 19, 2021
RE: Edvard Paronyan
To The Honorable Judge Wilson
I would like to introduce myself as Amit James Nath, working in the position of an executive for Bank Leumi
USA. I am writing this letter to you to provide a character reference about Mr. Edvard Poronyan. Ed and I
have been close friends for over 7 years. In this time, he has proven to be a fine and responsible character.
In general, Mr. Paronyan a business owner is known for being a dedicated husband and father. As a reliable
member of the community, Mr. Paronyan’s charges were quite unexpected, and I’m provide this reference
in full knowledge of them.
Mr Paronyan confessed to me the serious lack of judgement he exhibited and expressed remorse. I believe
Ed has every intention of improving since, since he has already started volunteering at various
organizations. Ed and I became friend through little league for our kids. I can confirm that in all the time I
have know him, Edvard Paronyan has been a reliable, trustworthy, and decent person.
Ed has thus far shown a steadfast and resolute demeanor in moving past this mistake in a constructive and
successful manner. It is my hope that this letter regarding Mr. Paronyan and his case will act as a positive
and contributing factor when the court decides this matter.
Sincerely,

Amit James Nath
Case 2:20-cr-00579-SVW Document 963 Filed 09/13/21 Page 74 of 88 Page ID #:16459

Ex. 27
Letter of Suzanna Pembedijan
Case 2:20-cr-00579-SVW Document 963 Filed 09/13/21 Page 75 of 88 Page ID #:16460

1
Suzanna Pembedjian
Spembedjian@gmail.com
08/20/2021
Dear Judge Wilson,
I would like to begin my introducing myself, my name is Suzanna Pembedjian I am
35 years old and immigrated to the United States with my family at the age of 4. My parents
sacrificed the love of living in their homeland to give my siblings and I a better future. I am
currently working as a Licensed Register Nurse and continuing my education as a family
Nurse Practitioner. Edvard Paronyan and I are second cousins, his father and my mother are
siblings, Edvard has been a part of my life for as long as I remember myself. I have always
looked up to him as a bother to me, he has been a close friend and confidant since childhood.
Edvard was instrumental in my early development, he has become a role model and guide to
me due to his unexpendable values of dependability, compassion, and respect.
Edvard has, over the years, showed compassion and kindness to his family and the
larger society. When we were children my mom would take us over to my uncle’s house
weekly, every Sunday. Edvard, was deeply involved in charity work organized by religious
organizations at his church directly next to their Hollywood Apartment. This is one of the
earliest memories I share with Edvard, he has always been very athletic and he would use that
energy to assist the church organize basketball and football games for all the children in the
community. Every Sunday he would take me over to the church with him, and I would watch
him help so many kids in the community find a sense of belonging. He has never lost touch
of these characteristic as he has aged throughout the years, he has carried with him the idea of
bringing people together and always positively influencing our lives. He will never hesitate to
gather our family and extended family together in one place so we can always stay close and
Case 2:20-cr-00579-SVW Document 963 Filed 09/13/21 Page 76 of 88 Page ID #:16461

2
our children can have the opportunity to grow up together, as we have. He values family,
togetherness, and always has a lot of love to share.
He is a very compassionate person. His compassion is also demonstrated by his
regular calls to me and checking in on me but most of all to his parents and their well-being.
Edvard also regularly takes responsibility for his aging parents without necessarily being
obliged to, demonstrating his deep concern and care. My uncle, Edvards father, lives alone
and has many health problems, Edvard one of the most caring and dependable sons I have the
pleasure of knowing. My uncle always makes sure to thank Edvard for being his lifeline.
Always making sure he has food to eat for the week, has a ride to his doctor’s appointments.
Edvard has showed to be a critical part of his father’s life and is ready to lend a hand anytime
he is needed. I know that this day in age, time is very precious and when you have someone
always ready to be there for you and give you their time, for me, it has been irreplaceable.
Furthermore, I know Edvard Paronyan to be a dependable father, son, friend, and
sibling. Edvard cares deeply about his young family, to whom he tirelessly works to provide
a comfortable and meaningful life. He is respectful to people regardless of their age,
relations, race, or socioeconomic status. His compassion and selflessness has led him to be
loved by everyone who is surrounded by him.
Sincerely,
Suzanna Pembedjian
Case 2:20-cr-00579-SVW Document 963 Filed 09/13/21 Page 77 of 88 Page ID #:16462

Ex. 28
Letter of Anait Ana Poladyan
Case 2:20-cr-00579-SVW Document 963 Filed 09/13/21 Page 78 of 88 Page ID #:16463

Anait Poladyan
650 E. Palm Ave. # 102
Burbank, CA 91501
August 18, 2021
RE: Mr. Edvard Paronyan
To The Honorable Judge Wilson,
My name is Anait Ana Poladyan. I am the managing attorney and founder of Poladyan Law
Firm, APC located at 1525 W. Magnolia Blvd Burbank, CA 91506. I have known Edvard my
entire life (31 years) and have always viewed him as an older brother. Edvard has been in my
family since before I was born, as he is the nephew of my uncle’s wife. However, Edvard isn’t
only family. He has been there for my family as a brother, a loyal friend, a motivator, and a
helping hand.
I am aware of Edvard’s current involvement with the case for which I am composing this letter.
Edvard and I have spoken about his connection with the case, and he has explained the charges
brought forth against him. I am aware that he will be sentenced soon. Thus, if I can be of any
assistance and do so much as shine some light on the character of Edvard, I find that it is not
only my duty, but my desire to do so. It really takes a circumstance as the one brought upon us
now to make one really think about what effect someone has had on their life and what qualities
he portrays.
Case 2:20-cr-00579-SVW Document 963 Filed 09/13/21 Page 79 of 88 Page ID #:16464

Rather than talk about general characteristics of Edvard, I prefer to discuss specific qualities that
I have personally noticed in Edvard throughout my life.
Seventeen years ago, when I was fourteen years old and living in Glendale, CA, I was accepted
to Providence High School in Burbank. My father was working early mornings, and my mother
was caring for my two young sisters, a four-year-old and a newborn. I recall being let down
because my parents decided that the school wasn’t going to work for us as it was a private school
with no transportation, and my parents were unable to make the commute. As I reluctantly made
arrangements to go to a local high school, my father let me know that Edvard had offered to go
out of his way and take me to my desired school every weekday before heading in the opposite
direction for his work. For the next four years, every morning, Edvard was waiting for me
outside of the vehicle at 7:30 AM. It was because of him that I was able to go to the school I
wanted. He was my hero. I speak about this because it only shows how selfless, giving, and
trustworthy Edvard is. Not only did he lend a helping hand when he had no obligation to do so,
but he had my parents’ full trust in transporting their young daughter to school daily. Our
commutes were always filled with interesting conversations, and Edvard always inspiring me to
achieve greatness.
Several years later, Edvard found the love of his life and was soon married, creating a family of
his own. I saw him as a newlywed, adapting to being the sole provider of the house and working
tirelessly every day and every night to provide a life for his new family. I spent a great deal of
time with Edvard’s wife during the first couple of years of marriage, and always recognized
Edvard’s ability to simultaneously give equal care and attention to his wife and his work. The
Case 2:20-cr-00579-SVW Document 963 Filed 09/13/21 Page 80 of 88 Page ID #:16465

little free time he had was spent with his wife, and shortly after, his son. I was there when his
family went through tough times. However, it was the way Edvard carried himself during those
times that stood out to me, always with a smile on his face. He remained diligent and easy to talk
to, spreading positivity wherever he went.
As I became an adult, and the age gap between Edvard became less apparent, Edvard was no
longer my big brother but my friend. When I had my own personal issues between my father and
current husband, it was Edvard who took on the role of mediator. He sat for hours to listen, to
provide advice, and to assist me with whatever issues were going on in my life. His time, effort,
and patience gave me the confidence and assurance that I never knew I was lacking. He truly has
a heart of gold.
Today, Edvard and I are both married with children, and our kids call each other cousins. Edvard
is an amazing father and role model to his children. Whether it is playing football with his son or
barbies with his daughter, his children have become his main priority. It is Edvard who is
constantly trying to gather us all together, so the children can get to see one another and build
bonds. Our large family is persistent to plan day trips, weekend trips, and even simple get
togethers to spend time with one another. Edvard is always the easy going, cheerful one that can
lighten up anyone’s mood. Regardless of what he is going through, he is smiling, grateful, and
positive.
Case 2:20-cr-00579-SVW Document 963 Filed 09/13/21 Page 81 of 88 Page ID #:16466

It is my sincere hope that the court takes this letter into consideration at the time of sentencing.
Despite the mistakes Edvard has made, he is still the same loyal and selfless friend and hard-
working and loving father and husband.
Respectfully,
Anait Ana Poladyan
Case 2:20-cr-00579-SVW Document 963 Filed 09/13/21 Page 82 of 88 Page ID #:16467

Ex. 29
Letter of Mariana Tsotsikyan
Case 2:20-cr-00579-SVW Document 963 Filed 09/13/21 Page 83 of 88 Page ID #:16468

Dear Judge Wilson,
My name is Mariana Tsotsikyan. I am forty-one years old and an United States
citizen. I am the CEO of Security Specialists. Edvard Paronyan is a good friend of
mine over a decade. Since 2005, all I have seen from Edvard is the active conscious
concern he has for others. I have seen him serve his community, friends and family
with the best of his abilities.
I am a widow since 2018, since my husband suddenly passed, leaving our two
children, Nicole and Chris, for me to take the role as a mother and a father. Edvard
spent everyday being there for my children as an uncle to make sure they grieve and
have a male figure in their lives. He helped me grieve by being my by side everyday
and making sure I am able to hope again. He continues to be the supportive friend
as I continue to heal.
Edvard Paronyan is an amazing father. One who has looked to righteous morals to
discipline his children. As a husband, he has and is always respectful and loving to
his wife. Edvard makes sure his family’s joy is his joy. Edvard is a good friend to
everyone. His heart aches to see someone else upset or in pain. He is the funniest
person I have ever met. He will make the saddest moment into the most joyful
memory to never be forgotten. Edvard is a good citizen of his home, neighborhood
and city. He is the one to lend a hand when the neighbor needs moving, or the church
down the street needs donations. As years passed I have witnessed the maturity,
wisdom and strength he has gained. I understand Edvard Paronyan will soon be
sentenced and I hope you take the consideration of his true character.
Thank you for your time and God bless you.
Sincerely,
Mariana Tsotsikyan
(818)378-4882
Mzbrunette1@yahoo.com
Case 2:20-cr-00579-SVW Document 963 Filed 09/13/21 Page 84 of 88 Page ID #:16469

Ex. 30
Letter of Armen Yakhszyan
Case 2:20-cr-00579-SVW Document 963 Filed 09/13/21 Page 85 of 88 Page ID #:16470

08/12/2021
Armen Yakhszyan
714 East orange Grove Ave, unit b
Burbank, CA 91501
Dear Judge Wilson.
I’ve known Edvard Paronyan for a long time; he is one of my best friends for almost about 18 years.
Additionally, I stared working for him for 4 years at Red Line Auto Collision.
All I can say about Edvard is that he is a great man with a very kind heart. He’s is very hard working
family oriented, honest and polite. He is a very good friend and always offers a helping hand to someone
in need. His love to his family and friends is unconditional. He is an intelligent human being of good
character.
He is a great boss. He cares about his employees and treats them as we are a family. During the difficult
times, when pandemic started, the business was very slow, we were hearing businesses closing left and
right, but Edvard was doing his best to pay his employees on time and making sure were all doing well.
Despite the current case, I still believe Edvard Paronyan to be an honorable individual, a good human
being and a valuable member of our community
Sincerely
Armen Yakhszyan
Case 2:20-cr-00579-SVW Document 963 Filed 09/13/21 Page 86 of 88 Page ID #:16471

Ex. 31
Letter of Sung Yi
Case 2:20-cr-00579-SVW Document 963 Filed 09/13/21 Page 87 of 88 Page ID #:16472

Dear Judge Wilson,
My name is Sung Yi. I'm one of Ed's many friends who feel great sorrow for the
circumstances of writing this letter. I'm a father of 3 and like Ed, I'm an immigrant to
the USA. I was born in Korea, raised in Hawaii and eventually moved to Los Angeles
after high school to attend school at Cal State University, Northridge. I'm currently a
business owner in the textile industry and have been so for the past 19 years. I've
known Ed for the past 6 years after being introduced to him through a mutual friend.
Until recently, Ed has always been a happy go lucky person and an extremely loyal
and dependable friend. He's the type of friend that is upbeat, has positive energy
and one that raises the energy and mood in every situation. A person that will always
help a friend or stranger in need. In fact that is how I have come to know Ed. A
mutual friend shared his story of how Ed helped him when his car had stalled on the
street and Ed was there to help him push his car out of traffic. He has shared the
details of his case and clearly feels the shame and pain of this mistake that has put
him and his family in the current situation. Being a parent, one of the greatest fears
is to not be able to be there for your kids. Whether it's simply being there to pick
them up from school, reading a bed time story or giving them a warm hug when you
come home from work. These are some of the things that he will miss the most.
There is no doubt he has made the biggest mistake of his entire life and his entire
family will be sharing in the punishment with his absence. Everyone that knows Ed
will be missing a bright positive energy while he is gone. Yes, he has made a mistake
and will have to accept the punishment given to him but Ed is truly a good soul and
deserves to be seen for all the good he has done and will continue to do for his family
and friends and for his community.
Judge Wilson, I hope you will judge Ed not only by the one big mistake he has made
but all the positive things he has done with his life as well. The positive impact that
he has on others who in turn will pass on the positive energy into the world. A
butterfly effect of amazing energy. He is one of the good ones that truly contributes
to society and I pray you can and will see that from the letters written by his friends
and family.
Sincerely,
Sung Yi
Case 2:20-cr-00579-SVW Document 963 Filed 09/13/21 Page 88 of 88 Page ID #:16473

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Sentencing Memorandum filed by Defendant Edvard Paronyan — USA v. Ayvazyan et al. (Dkt. 963, C.D. Cal.)

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