Criminal Complaint — United States v. Ayvazyan and Terabelian (Central District of California)
Summary
A criminal complaint, Document 1 in United States v. Richard Ayvazyan, aka "Iuliia Zhadko," and Marietta Terabelian, aka "Viktoria Kauichko," Case 2:20-cr-00579-SVW, filed 10/20/20 in the Central District of California and running 19 pages. The complaint form charges conspiracy to commit wire fraud and bank fraud under 18 U.S.C. § 1349 and is signed /S/ Justin Palmerton, Special Agent. Palmerton's attached affidavit alleges that from about March 2020 through at least July 2020 the defendants and co-conspirators sought PPP and EIDL loans using stolen, fictitious or synthetic identities, then used the proceeds to buy residential properties. It also describes an October 19, 2020 stop by Customs and Border Protection at Miami International Airport, where credit cards in the names "Iuliia Zhadko" and "Viktoria Kauichko" were found.
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“Criminal Complaint — United States v. Ayvazyan and Terabelian (Central District of California).”
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Case 2:20-cr-00579-SVW Document 1 Filed 10/20/20 Page 1 of 19 Page ID #:49
AO 91 (Rev. 11/11) Criminal Complaint (Rev. by USAO on 3/12/20) ܆Original ܆Duplicate Original
LODGED
CLERK, U.S. DISTRICT COURT UNITED STATES DISTRICT COURT
10/20/2020 for the 10/20/2020
CENTRAL DISTRICT OF CALIFORNIA SP
jb
BY: ____________BB______ DEPUTY Central District of California
UNITED STATES OF AMERICA,
v.
RICHARD AYVAZYAN,
aka “Iuliia Zhadko,” and Case No.
2:20-mj-05081-duty
MARIETTA TERABELIAN,
aka “Viktoria Kauichko,”
Defendants.
CRIMINAL COMPLAINT BY TELEPHONE
OR OTHER RELIABLE ELECTRONIC MEANS
I, the complainant in this case, state that the following is true to the best of my knowledge and belief.
As described in the accompanying attachment, defendants violated the following statute:
Code Section Offense Description
18 U.S.C. § 1349 Conspiracy to Commit Wire Fraud
and Bank Fraud
This criminal complaint is based on these facts:
Please see attached affidavit.
_ Continued on the attached sheet.
/S/
Complainant’s signature
Justin Palmerton, Special Agent
Printed name and title
Attested to by the applicant in accordance with the requirements of Fed. R. Crim. P. 4.1 by telephone.
Date: 10/20/20 /S/ CHARLES F. EICK
Judge’s signature
City and state: Los Angeles, California Hon. Charles Eick, U.S. Magistrate Judge
Printed name and title
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Case 2:20-cr-00579-SVW Document 1 Filed 10/20/20 Page 2 of 19 Page ID #:50
Complaint Attachment
Statement of Facts Constituting the Offense
[18 U.S.C. § 1349]
Beginning in or around March 2020 and continuing through at
least in or around July 2020, in Los Angeles County, within the
Central District of California, and elsewhere, defendant RICHARD
AYVAZYAN, also known as (“aka”) “Iuliia Zhadko” (“AYVAZYAN”),
and defendant MARIETTA TERABELIAN, aka “Viktoria Kauichko”
(“TERABELIAN”), together with others known and unknown,
conspired to commit wire fraud, in violation of Title 18, United
States Code, Section 1343, and bank fraud in violation Title 18,
United States Code, Section 1344. The objects of the conspiracy
were carried out, and to be carried out, in substance as
follows:
Defendants AYVAZYAN and TERABELIAN, and their co-
conspirators, would apply for Paycheck Protection Program
(“PPP”) and Economic Injury Disaster Loan (“EIDL”) loans using
stolen, fictitious, or synthetic identities and businesses.
Defendants AYVAZYAN and TERABELIAN, and their co-conspirators,
would submit false and fictitious documents in support of the
PPP and EIDL loan applications. Defendants AYVAZYAN and
TERABELIAN, and their co-conspirators would direct that the PPP
and EIDL loan proceeds be deposited into bank accounts
defendants AYVAZYAN and TERABELIAN, and their co-conspirators,
controlled. Defendants AYVAZYAN and TERABELIAN, and their co-
conspirators, would use the fraudulently obtained PPP and EIDL
loan proceeds for their own personal purposes.
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AFFIDAVIT
I, Justin Palmerton, being duly sworn, declare and state as
follows:
I. INTRODUCTION
1. I am a Special Agent with the Federal Bureau of
Investigation (“FBI”) and have been so employed since January
2018. I am currently assigned to a Los Angeles Field Division
White Collar Crimes Squad, which is responsible for
investigating complex financial crimes. Prior to being employed
by the FBI as a Special Agent, I was employed as a Certified
Public Accountant at a public accounting firm. My roles and
responsibilities included financial statement audits, tax return
preparation and accounting consulting work.
2. Since becoming an FBI Special Agent in 2018, I have
received 21 weeks of formal training at the FBI Training Academy
in Quantico, Virginia. During the time I have been employed by
the FBI, I have participated in investigations relating to wire
fraud, mail fraud, and various types of complex financial
crimes. I have participated in many aspects of criminal
investigations including reviewing evidence, analyzing financial
documents, conducting physical and electronic surveillance,
working with informants, and executing search and arrest
warrants.
II. PURPOSE OF AFFIDAVIT
3. This affidavit is made in support of a criminal
complaint against, and arrest warrants for, RICHARD AYVAZYAN
(born 1978) (“AYVAZYAN”) and MARIETTA TERABELIAN (born 1984)
Case 2:20-cr-00579-SVW Document 1 Filed 10/20/20 Page 4 of 19 Page ID #:52
(“TERABELIAN”) for violations of 18 U.S.C. § 1349 (Conspiracy to
Commit Bank and Wire Fraud).
4. The facts set forth in this affidavit are based upon
my personal observations, my training and experience, and
information obtained from various law enforcement personnel and
witnesses. This affidavit is intended to show merely that there
is sufficient probable cause for the requested complaint and
warrants and does not purport to set forth all of my knowledge
of or investigation into this matter. Unless specifically
indicated otherwise, all conversations and statements described
in this affidavit are related in substance and in part only.
III. SUMMARY OF PROBABLE CAUSE
5. From in or around March 2020 through at least in or
around July 2020, stolen and/or fake identities were used to
fraudulently obtain disaster loans authorized by the Coronavirus
Aid, Relief, and Economic Security (“CARES”) Act through various
lenders and the Small Business Administration (“SBA”). The
stolen and/or fake identities used to fraudulently obtain
disaster loan proceeds included “Viktoria Kauichko” and “Iuliia
Zhadko,” among others. The fraudulently obtained disaster loan
proceeds were directed to accounts owned and/or controlled by
AYVAZYAN and TERABELIAN, among other co-conspirators, and then
used to purchase residential properties in the name of AYVAZYAN
and TERABELIAN, who are married, and in the name of “Iuliia
Zhadko.” Using disaster loan proceeds as part of a down payment
on a residence for an individual’s personal benefit is also
fraudulent and violates the requirements for PPP and EIDL loans.
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6. On or about October 19, 2020, upon being stopped by
Customs and Border Protection (“CBP”) while re-entering the
United States at the Miami International Airport, AYVAZYAN was
found to be in possession of contraband, including credit cards
in the name of “Iuliia Zhadko” and “Viktoria Kauichko,” as well
as a digital photograph of a California driver’s license in the
name of “Iuliia Zhadko.” TERABELIAN was found to be in
possession of contraband, including at least one credit card in
the name of “Viktoria Kauichko.”
IV. STATEMENT OF PROBABLE CAUSE
7. Based on witness interviews I have conducted, my
review of documents obtained from third parties, reports of
interviews conducted by other law enforcement officers,
conversations with other law enforcement officers, and publicly
filed documents, I know the following:
A. The Paycheck Protection Program (“PPP”)
8. The CARES Act is a federal law enacted in or around
March 2020 and designed to provide emergency financial
assistance to the millions of Americans who are suffering the
economic effects caused by the COVID-19 pandemic. One source of
relief provided by the CARES Act was the authorization of up to
$349 billion in forgivable loans to small businesses for job
retention and certain other expenses, through the Paycheck
Protection Program, which is referred to as the PPP. In or
around April 2020, Congress authorized over $300 billion in
additional PPP funding.
3
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9. In order to obtain a PPP loan, a qualifying business
must submit a PPP loan application, which is signed by an
authorized representative of the business. The PPP loan
application requires the business (through its authorized
representative) to acknowledge the program rules and make
certain affirmative certifications in order to be eligible to
obtain the PPP loan. In the PPP loan application, the small
business (through its authorized representative) must state,
among other things, its: (a) average monthly payroll expenses;
and (b) number of employees. These figures are used to
calculate the amount of money the small business is eligible to
receive under the PPP. In addition, businesses applying for a
PPP loan must provide documentation showing their payroll
expenses.
10. A PPP loan application must be processed by a
participating financial institution (the lender). If a PPP loan
application is approved, the participating financial institution
funds the PPP loan using its own monies, which are 100%
guaranteed by the SBA. Data from the application, including
information about the borrower, the total amount of the loan,
and the listed number of employees, is transmitted by the lender
to the SBA in the course of processing the loan.
11. PPP loan proceeds must be used by the business on
certain permissible expenses—payroll costs, interest on
mortgages, rent, and utilities. The PPP allows the interest and
principal on the PPP loan to be entirely forgiven if the
business spends the loan proceeds on these expense items within
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a designated period of time and uses a certain percentage of the
PPP loan proceeds on payroll expenses.
B. The Economic Injury Disaster Relief Program (“EIDL”)
12. The EIDL program is an SBA program that provides low-
interest financing to small businesses, renters, and homeowners
in regions affected by declared disasters.
13. The CARES Act authorized the SBA to provide EIDLs of
up to $2 million to eligible small businesses experiencing
substantial financial disruption due to the COVID-19 pandemic.
In addition, the CARES Act authorized the SBA to issue advances
of up to $10,000 to small businesses within three days of
applying for an EIDL. The amount of the advance is determined
by the number of employees the applicant certifies having. The
advances do not have to be repaid.
14. In order to obtain an EIDL and advance, a qualifying
business must submit an application to the SBA and provide
information about its operations, such as the number of
employees, gross revenues for the 12-month period preceding the
disaster, and cost of goods sold in the 12-month period
preceding the disaster. In the case of EIDLs for COVID-19
relief, the 12-month period was that preceding January 31, 2020.
The applicant must also certify that all of the information in
the application is true and correct to the best of the
applicant’s knowledge.
15. EIDL applications are submitted directly to the SBA
and processed by the agency with support from a government
contractor. The amount of the loan, if the application is
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approved, is determined based, in part, on the information
provided by the application about employment, revenue, and cost
of goods, as described above. Any funds issued under an EIDL or
advance are issued directly by the SBA. EIDL funds can be used
for payroll expenses, sick leave, production costs, and business
obligations, such as debts, rent, and mortgage payments. If the
applicant also obtains a loan under the PPP, the EIDL funds
cannot be used for the same purpose as the PPP funds.
C. Fraudulently Obtained Disaster Loan Proceeds Used to
Purchase Real Estate in the Name of AYVAZYAN and
TERABELIAN
16. Based on my review of loan documents provided by the
SBA, I know that on or about June 15, 2020, the SBA received an
application in the name of Timeline Transport, Inc. (“Timeline
Transport”) seeking an EIDL loan in the amount of $150,000. The
application was submitted in the name of Iuliia Zhadko via the
SBA’s online portal.
17. In the application, an individual purporting to be
Zhadko represented that, as of January 31, 2020, Timeline
Transport employed 22 individuals and had gross revenues of
$1,601,840. “Zhadko” further represented that he was the Chief
Executive Officer (”CEO”) and that he had owned Timeline
Transport since 2016. The Employer Identification Number
(“EIN”) listed for Timeline Transport on the loan application is
85-0925228.
18. The SBA approved Timeline Transport’s application and
funded the loan. On or about June 22, 2020, the SBA wired
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$149,900 to a bank account at Financial Institution 1 ending in
0172, for which “Iuliia Zhadko” was the sole signatory.
19. The government’s investigation has revealed that
Timeline Transport’s application to the SBA contained materially
false and misleading information. For example:
a. The application states that Timeline Transport
had 22 employees as of January 31, 2020.
b. Based on my review of publicly available filings
with the California Secretary of State, I know that Timeline
Transport was first registered on May 1, 2020.
c. Based on my review of records provided by the
State of California’s Employment Development (“CA EDD”), I know
that CA EDD was unable to locate any record of Timeline
Transport having employees in 2019 or 2020.
d. The application states that the EIN for Timeline
Transport is 85-0925228. Based on information provided to me
from other law enforcement agencies, I know that the earliest an
“85” EIN prefix could be issued online was on March 23, 2020.
e. The Internal Revenue Service (“IRS”) has
confirmed that there is no record of Timeline Transport filing
employment tax or federal income tax returns with the IRS in
2019.
20. “Iuliia Zhadko” appears to be a fake or synthetic 1
identity used by AYVAZYAN. Among other things, law enforcement
1
Synthetic identities are false identities created with
certain key details, such as personally identifiable information
or Social Security numbers stolen from real people. Based on my
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agents involved in this investigation have not been able locate
any record of a “Iuliia Zhadko” in California Department of
Motor Vehicles’ (“CA DMV”) records. Nonetheless, as discussed
below, AYVAZYAN was found in possession of digital image of a
purported California Driver’s License (“CADL”) in the name of
“Iuliia Zhadko.” In addition, AYVAZYAN possessed credit cards
in the name of “Iuliia Zhadko.”
21. The application directed the EIDL loan proceeds to be
sent to a bank account at Financial Institution 1 ending in
0172. Based on bank records from Financial Institution 1, I
know that the account ending in 0172 was only opened on May 4,
2020. On or about June 24, 2020 -- just two days after the EIDL
loan proceeds were received on June 22, 2020 -- a $110,000 wire
was sent from the account ending 0172 to Encore Escrow. The
entirety of the $110,000 appears to have been derived from the
EIDL funds Timeline Transport obtained on June 22, 2020.
22. I reviewed records provided by Encore Escrow and
determined that the $110,000 wired from the account ending in
0172 went into an escrow account to fund a portion of a down-
payment on the purchase of a residential property at Address 1
in Tarzana, California. The purchase price of this property was
$3,250,000. An e-mail sent from an individual identifying
himself “Richard Ayvazyan” to the escrow agent on or about June
24, 2020, stated: “This one went through for 65k. The other one
training and experience, these false identities are used to
defraud financial institutions, government agencies, or
individuals.
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for 110k I don’t have confirmation yet. I will send that over as
soon as I get it.”
23. Based on my review of records provided by Encore
Escrow, the residential property at Address 1 was purchased in
the names of AYVAZYAN and TERABELIAN.
24. My review of records provided by Encore Escrow further
revealed that, in addition to the $110,000 wire from the 0172
account at Financial Institution 1, on or about June 22, 2020, a
$565,000 wire transfer was sent from the bank account at
Financial Institution 2 ending in 1475 to Encore Escrow.
25. Based on my review of bank records provided by
Financial Institution 2, I know that TERABELIAN was the only
signatory on the account ending in 1475.
26. Bank records for TERABELIAN’s account at Financial
Institution 2 further revealed that the funds for the $565,000
wire transfer came from approximately nine preceding wire
transfers to TERABELIAN’s account. Several of these preceding
wire transfers were made from bank accounts that had recently
received disaster loan funds. For example:
a. Based on records provided by Lender 3, on or
about May 3, 2020, Person 1 applied for a PPP loan in the amount
of $113,750 on behalf of G&A Diamonds. Lender 3 approved the
application and on or about May 5, 2020, funded the loan by
wiring $113,750 to G&A Diamonds’ bank account at Financial
Institution 4 ending 1964.
b. Based on records provided by the SBA, on or about
April 8, 2020, Person 1 applied for an EIDL loan in the amount
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of $145,000 on behalf of G&A Diamonds. The SBA approved the
application and on or about June 16, 2020, funded the loan by
wiring $144,900 to G&A Diamonds’ bank account at Financial
Institution 4 ending 1964. G&A Diamonds did not use the PPP or
EIDL funds to pay employees. Instead, on or about June 19,
2020, Person 1 wired $100,000 from the account at Financial
Institution 4 ending in 1964 to TERABELIAN’s account at
Financial Institution 2 ending 1475.
c. Based on my review of loan documents provided by
the SBA, I know that on or about June 2, 2020, the SBA received
an application in the name of Redline Auto Collision (“Redline
Auto Collision”) seeking an EIDL loan in the amount of $150,000.
The application was submitted by Person 2.
d. On or about June 8, 2020, the SBA approved the
application and funded the loan by wiring $149,900 into an
account held at Financial Institution 5 ending in 1732. Based
on a review of records provided by Financial Institution 5, I
know that Person 2 is the sole signatory on this account.
Redline Auto Collision did not use the EIDL loan to pay
employees but instead wired $150,000 to TERABELIAN’s account at
Financial Institution 2 ending 1475, on or about June 17, 2020.
e. Using disaster loan proceeds as part of a down
payment on a residence for an individual’s personal benefit is
fraudulent and violates the requirements for PPP and EIDL loans.
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D. Fraudulently Obtained PPP Loan Proceeds Used to
Purchase Real Estate in the Name of “Zhadko”
27. Based on my review of loan documents provided by the
SBA and Lender 1, which is an FDIC-insured financial
institution, I know that on or about July 13, 2020, Lender 1
received a PPP loan application in the name of Runyan Tax
Services, Inc. (“Runyan Tax Services”) seeking a PPP loan in the
amount of $276,653. The application was submitted by an
individual purporting to be “Viktoria Kauichko.” “Kauichko”
purported to be the CEO and 100% owner of Runyan Tax Services
and represented that Runyan Tax Services employed 22 individuals
as of January 31, 2020.
28. In support of the application, an individual
purporting to be “Kauichko” submitted a copy of her CADL with
the license number D3257870.
29. Lender 1 approved Runyan Tax Services’ application and
funded the loan. On or about July 21, 2020, Lender 1 sent a
wire in the amount of $276,653 to a bank account at Financial
Institution 2 ending in 9700, for which “Viktoria Kauichko” was
the sole signatory.
30. The government’s investigation has revealed that
Runyan Tax Service’s application to the SBA contained materially
false and misleading information. For example:
a. The application states that Runyan Tax Service
had 22 employees as of January 31, 2020. Information provided
by CA EDD show that no employment records exist for Runyan Tax
Services for 2019 and 2020.
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b. The CADL provided by “Kauichko” in support of the
application is fake. A review of records provided by CA DMV
revealed that there was no CADL for a Viktoria Kauichko and that
the CADL number listed on the license provided by “Kauichko” is
actually registered to a different individual.
31. Based on bank records provided by Financial
Institution 2, I know that the account ending in 9700 was only
opened on July 1, 2020 (i.e., less than two weeks before the
individual purporting to be “Kauichko” submitted the PPP loan
application for Runyan Tax Services).
32. Based on bank records provided by Financial
Institution 2, on July 23, 2020, a wire transfer in the amount
of $238,614 was sent from the bank account at Financial
Institution 2 ending in 9700 to Beverly Hills Escrow. The
entirety of the $238,614 wire transfers appears to have derived
from the $276,653 in PPP loan proceeds Runyan Tax Services
received on July 21, 2020.
33. After reviewing records provided by Beverly Hills
Escrow, I learned that the $238,614 wire was used for the down
payment on a property at Address 2 in Glendale, California being
purchased by “Iuliia Zhadko” for approximately $1,000,000.
E. Fraudulent PPP Application Submitted on Behalf of Top
Quality Contracting Using a Stolen Identity
34. Based on my review of loan documents provided by the
SBA and Lender 2, also an FDIC-insured financial institution, I
know that on or about April 30, 2020, Lender 2 received a PPP
loan application in the name of Top Quality Contracting (“TQC”),
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seeking a PPP loan in the amount of $130,000. The application
was submitted by an individual purporting to be Victim 1.
35. The application represented that Victim 1 was TQC’s
sole owner, that the average monthly payroll was $52,000, and
that TQC had 12 employees.
36. In support of the application, the individual
purporting to be Victim 1 submitted: (i) an IRS Form 940
purportedly prepared by Victim 1 listing TQC’s EIN as 82-
5088385; and (ii) a purported copy of Victim 1’s CADL with the
CADL number F0059222.
37. Lender 2 approved TQC’s application and funded the
loan. On or about May 8, 2020, Lender 2 wired $130,000 to a
bank account at Financial Institution 3 ending in 3517. Based
on bank records provided by Financial Institution 3, the account
was a business checking account titled “Iuliia Zhadko dba Top
Quality Contracting.” The signatories on the account were
“Iuliia Zhadko” as TQC’s sole owner and Victim 1 as a secondary
signer.
38. The government’s investigation has revealed that TQC’s
application to Lender 2 contained materially false and
misleading information. For example:
a. The CADL for Victim 1 submitted with TQC’s
application is fake and did not match CA DMV’s records.
b. Information provided by CA EDD shows that no
employment records existed for TQC for 2019.
c. The IRS has indicated that the EIN number listed
in the Form 940 submitted in support of TQC’s PPP loan
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application is incorrect, and confirmed that there is no record
of TQC filing employment tax or federal income tax returns with
the IRS in 2019.
39. Upon being interviewed by law enforcement, Victim 1
stated that he had not applied for any PPP loans and had not
authorized anyone to apply for a PPP loan on his or TQC’s
behalf. Victim 1 did not recognize the PPP loan application
submitted to Lender 2 and had not applied for any type of
government assistance. According to Victim 1, TQC was a sole-
proprietorship and did not have any employees. In addition,
Victim 1 did not recognize the CADL submitted with the
application. Victim 1 also stated that he had not opened the
bank account at Financial Institution 3 ending in 3517.
F. Other Disaster Loan Applications Submitted in the
Names of “Zhadko,” “Kauichko” and Victim 1
40. In addition to the disaster loan applications
described above, based on information obtained from the SBA,
several other PPP and EIDL loan applications were submitted in
the names of “Zhadko” and “Kaiuchko,” including:
Approx.
Company Applicant Application Amount Lender Status
Date
Timeline
Iuliia Zhadko 05/04/2020 $113,750 Lender 2 Cancelled
Transport
Timeline
Iuliia Zhadko 06/25/2020 $122,400 Lender 2 Approved
Transport
Timeline Not
Iuliia Zhadko 07/01/2020 $122,400 Lender 4
Transport Disbursed
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TQC Iuliia Zhadko 04/13/2020 $185,000 Lender 5 Approved
TQC Iuliia Zhadko 04/08/2020 $185,000 Lender 6 Withdrawn
TQC Iuliia Zhadko 03/30/2020 $112,100 SBA Approved
Classic
Iuliia Zhadko 05/26/2020 $150,000 SBA Cancelled
Nursery
Viktoria Viktoria
07/01/2020 $150,000 SBA Approved
Kauichko Kauichko
Journeyman Viktoria
05/19/2020 $150,000 SBA Approved
Construction Kauichko
Fiber One Viktoria
06/15/2020 $150,000 SBA Approved
Media Kauichko
Fiber One Viktoria
06/17/2020 $150,000 SBA Approved
Media, Inc. Kauichko
Fiber One Viktoria
06/17/2020 $276,652 Lender 7 Cancelled
Media, Inc. Kauichko
Fiber One Viktoria
04/15/2020 $130,000 Lender 5 Approved
Media, Inc. Kauichko
Fiber One Viktoria
05/01/2020 $130,000 Lender 2 Cancelled
Media, Inc. Kauichko
G. CBP Stop at Miami International Airport
41. Based on my discussions with CBP officers and other
federal law enforcement agents in Miami, Florida, I understand
that on October 19, 2020, AYVAZYAN and TERABELIAN re-entered the
United States at Miami International Airport as they returned
from a trip to Providenciales, which is a resort island in Turks
and Caicos. AYVAZYAN and TERABELIAN were subject to a border
stop by CBP, during which they were searched for contraband.
Among other things, CBP’s search revealed that AYVAZYAN was in
possession of credit cards in the names of “Viktoria Kauichko”
and “Iuliia Zhadko.” During a manual search of AYVAZYAN’s
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cellphone for digital contraband, CBP also discovered a digital
image of a CADL in the name of “Iuliia Zhadko” bearing
AYVAZYAN’s address. CBP’s search further revealed that
TERABELIAN was in possession of at least one credit card in the
name of “Viktoria Kauichko.” CBP also conducted a manual search
of TERABELIAN’s cellphone for digital contraband and discovered
text messages in which TERABELIAN appeared to be using the
identity of “Viktoria Kauichko” to communicate with others.
G. Prior Convictions
42. Based on my review of public court records, I know
that AYVAZYAN and TERABELIAN were previously convicted of
violation of 18 U.S.C. § 371 (Conspiracy to Commit Bank Fraud)
in the Central District of California in 2012, United States v.
Ayvazyan, et al, No. SA CR 11-180-CJC.
* * * *
43. Based on the above information, there is probable
cause to believe that AYVAZYAN and TERABELIAN together, and with
others known and unknown, knowingly combined, conspired,
confederated, and agreed to submit, and caused to be submitted,
fraudulent loan applications to various financial institutions
and the SBA, seeking funds through the PPP and EIDL programs,
and improperly used those funds for their own personal benefit
rather than for the business expenses for which the loan
applications certified they would be used.
16
Case 2:20-cr-00579-SVW Document 1 Filed 10/20/20 Page 19 of 19 Page ID #:67
V. CONCLUSION
44. For all the reasons described above, there is probable
cause to believe that AYVAZYAN and TERABELIAN violated 18 U.S.C.
§ 1349 (Conspiracy to Commit Bank and Wire Fraud)
/S/
Justin Palmerton
Special Agent
Federal Bureau of
Investigation
Attested to by the applicant in
accordance with the requirements
of Fed. R. Crim. P. 4.1 by
telephone on this 20th day of
October, 2020.
/S/ CHARLES F. EICK
HONORABLE CHARLES EICK
UNITED STATES MAGISTRATE JUDGE
17
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