AO 91 (Rev. 11/11) Criminal Complaint (Rev. by USAO on 3/12/20) ܆Original ܆Duplicate Original

Date: 2020-03-12

Summary

A criminal complaint in United States v. Eduard Gasparyan, Case No. 2:22-mj-03431-DUTY, in the U.S. District Court for the Central District of California, filed August 30, 2022 as Document 1 in Case 2:22-cr-00448-JLS. It charges conspiracy to commit bank fraud and aggravated identity theft under 18 U.S.C. §§ 1344, 1349, 1028A, alleging the use of stolen identities to obtain California EDD debit cards, with actual losses well in excess of $800,000. The supporting affidavit of a Department of Labor Office of Inspector General special agent states that EDD paid approximately $544,089 on at least 32 claims and approximately $307,012 on at least 16 claims listing addresses it links to the defendant. It also cites Bank of America ATM surveillance images and approximately 1,700 images produced by ID.me. The 27-page complaint was attested by telephone before Magistrate Judge Alka Sagar.

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Case 2:22-cr-00448-JLS Document 1 Filed 08/30/22 Page 1 of 27 Page ID #:1
AO 91 (Rev. 11/11) Criminal Complaint (Rev. by USAO on 3/12/20) ‫ ܆‬Original ‫ ܆‬Duplicate Original

UNITED STATES DISTRICT COURT LODGED
CLERK, U.S. DISTRICT COURT

for the 8/30/2022
CENTRAL DISTRICT OF CALIFORNIA
jb
BY: ____________BB______ DEPUTY
Central District of California

United States of America
v.
EDUARD GASPARYAN,
aka “Rudy Pineda”, 2:22-mj-03431-DUTY
Case No.
aka “Papin Galstyan”,
FILED
CLERK, U.S. DISTRICT COURT

Defendant(s)
August 30, 2022
CENTRAL DISTRICT OF CALIFORNIA
CRIMINAL COMPLAINT BY TELEPHONE CD
BY: ___________________ DEPUTY

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, defendant violated the following statutes:

Code Section Offense Description

18 U.S.C. §§ 1344, 1349, 1028A Conspiracy to Commit Bank Fraud,
Aggravated Identity Theft

This criminal complaint is based on these facts:

Please see attached affidavit.

_ Continued on the attached sheet.

/s Marcus Johnson
Complainant’s signature

Marcus Johnson, 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: August 30, 2022
Judge’s signature

City and state: Los Angeles, California Hon. Alka Sagar, U.S. Magistrate Judge
Printed name and title

AUSA Andrew Brown, 11th Floor, x0102
Case 2:22-cr-00448-JLS Document 1 Filed 08/30/22 Page 2 of 27 Page ID #:2

Complaint Attachment

Count One, 18 U.S.C. § 1349
Beginning in or before 2019, and continuing through at least August 30, 2022, in Los Angeles
County, within the Central District of California, and elsewhere, defendant EDUARD GASPARYAN,
aka “Rudy Pineda,” aka “Papin Galstyan” (“Defendant”), and others, conspired to commit bank fraud, in
violation of Title 18, United States Code, Section 1344. The object of the conspiracy was carried out,
and to be carried out, in substance, as follows: Defendant and his co-conspirators would steal the
identities of victims. Defendant would impersonate those victims and apply for unemployment benefits
in their names, as well as in multiple variations of his own name, in order to obtain California EDD
debit cards. Defendant would use the EDD debit cards, which were issued by Bank of America, a
federally-insured financial institution, to withdraw cash from ATMs, resulting in actual losses well in
excess of $800,000.

Count Two, 18 U.S.C. § 1028A
Beginning in or before 2019, and continuing through at least August 30, 2022, in Los Angeles
County, within the Central District of California, and elsewhere, defendant EDUARD GASPARYAN,
aka “Rudy Pineda,” aka “Papin Galstyan,” knowingly transferred, possessed, and used, without lawful
authority, a means of identification of another person during and in relation to a felony violation of Title
18, United States Code, Section 1349, Conspiracy to Commit Bank Fraud, as charged in Count One,
knowing that the means of identification belonged to another actual person.
Case 2:22-cr-00448-JLS Document 1 Filed 08/30/22 Page 3 of 27 Page ID #:3

AFFIDAVIT
I, Marcus Johnson being duly sworn, declare and state as

follows:
INTRODUCTION

1. I am a Special Agent (“SA”) with the United States

Department of Labor – Office of Inspector General (“DOL-OIG”),

and have been so employed since January 2022. My

responsibilities as a DOL-OIG SA include investigating

Unemployment Insurance (“UI”) fraud, bank fraud, mail fraud,

identity theft, employee misconduct, and other related crimes.

Prior to my employment with DOL-OIG, I was a SA with the United

States Railroad Retirement Board – Office of Inspector General

(“RRB-OIG”) where I investigated allegations of UI fraud and

disability program fraud.

2. I am a graduate of the Federal Law Enforcement

Training Centers (“FLETC”) in Glynco, Georgia. As part of the

training provided at FLETC, I successfully completed the Basic

Training course, which included, but was not limited to, courses

in criminal and constitutional law. I have a Bachelor’s degree

in Political Science, a Bachelor’s degree in Criminal Justice,

and a Master’s degree in Emergency Management and Homeland

Security. I have experience in conducting surveillances,

interviews of subjects and witnesses, financial analysis of

individuals, executing warrants in connection with fraud
investigations, and collaborating with other law enforcement

agencies.

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SEEKING COMPLAINT AND ARREST WARRANT

3. This affidavit is made in support of a complaint

against EDUARD GASPARYAN (“GASPARYAN”) for conspiracy to commit

bank fraud and aggravated identity theft, in violation of Title

18, United States Code, Sections 1028A, 1344, and 1349.

4. The information set forth in this affidavit is based

upon my participation in the investigation, encompassing my

personal knowledge, observations and experience, as well as

information obtained through my review of evidence,

investigative reports, and information provided by others,

including other law enforcement partners. As this affidavit is

being submitted for the limited purpose of securing the

requested warrant, I have not included each and every fact known

to me concerning this investigation. I have set forth only the

facts that I believe are necessary to establish probable cause

for the requested warrants.

STATEMENT OF PROBABLE CAUSE

A. GASPARYAN’s Fraud Scheme

5. EDUARD GASPARYAN (GASPARYAN) is suspected of operating

an unemployment insurance (“UI”) fraud and identity theft

scheme. As described below, the scheme involves using other

individuals’ identities to apply for EDD UI benefits. As

described below, GASPARYAN uses other individuals’ identities to

apply for EDD UI benefits. From there, he uses a few addresses

to receive dozens of EDD cards in his own name or variations

thereof, and in the names of others, who may be the victims of
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identity theft, or may be complicit. Often times he slightly

alters the address he lists on the unemployment insurance

application, which might reflect “Apt. 3,” or “Apt. 03,” or

“Unit 3,” for example.

6. In my training and experience, many fraudsters know

that EDD tries to detect when an unusual number of debit cards

are being sent to a single address, and so they alter the

addresses they use in ways that will not prevent mail deliver,

but that they hope would prevent a computer from finding an

exact match. Additionally, fraudsters will attempt to avoid EDD

detection by altering the SSN on the claim they submit, or by

altering the claimants’ name somewhat. As described below,

GASPARYAN has sometimes reversed the order of his name, or

tweaked his SSN, in an apparent effort to prevent his different

claims from matching each other.

B. Over $500,000 in Benefits Were Mailed to GASPARYAN’s
Sherman Way Address in the Form of Bank of America Debit
Cards

7. According to California EDD records, from February

2020 to the present, EDD has paid out approximately $544,089 on

UI benefits under the PUA program on at least 32 claims using

13823 Sherman Way Apt 3, Van Nuys, CA, 91405, or variations

thereof 1, as the named claimant’s mailing address.

1 At least 32 claims submitted to EDD list “13823 Sherman Way
Apt 3”, or variations of “Apt 3” as the claimant mailing address.
These variations include “Apt 03, Apt 003, Apt 103, Apt 0103, Unit
3, Unit 003, Unit 0103, #3”. Applying for numerous claims under
slight variations of the same address is a common tactic seen in UI
fraud submissions as a method of attempting to avoid detection.
3
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8. According to California Department of Motor Vehicles,

GASPARYAN provided that address (13823 Sherman Way Apt 3, Van

Nuys, CA 91405) as his mailing address. Law enforcement

databases also confirm the same address as belonging to

GASPARYAN.

9. On or about February 10, 2021, a California EDD UI

claim was submitted under GASPARYAN’s name, with 13823 Sherman

Way Apt 03, Van Nuys, CA 91405 as the mailing address, however

the SSN on this claim was slightly altered from GASPARYAN’s true

SSN. This claim was subsequently paid out by EDD.

10. On or about April 24, 2021, a California EDD UI claim

was submitted under the name “Papin Galstyan”, with 13823

Sherman Way, Apt 3, Van Nuys, CA 91405, as the mailing address.

As described later in this affidavit, “Papin Galstyan” is one of

the identities GASPARYAN uses in his fraud.

C. Over $300,000 in Benefits Were Mailed to an Encino Ave
Address Used by GASPARYAN in the form of Bank of America
Debit Cards

11. According to California EDD records, from February

2020 to the present, EDD has paid out approximately $307,012 in

UI benefits under the PUA program on at least 16 claims using

10832 Encino Ave, or variations thereof, as the named claimant’s

mailing address. EDD records further show:

a. On or about July 16, 2021, a California EDD UI

claim was submitted under the name “Gasparyan Eduard,” that is

reversing the order of GASPARYAN’s true name, with 10832 Encino

Ave house 1, San Fernando CA 91344, as the mailing address.
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GASPARYAN’s true date of birth was listed on the application,

however, the SSN on the application is an altered variation of

his own. (In several other claims, GASPARYAN’s name also appears

reversed).

b. On or about August 26, 2021, a California EDD UI

claim was submitted under the name “Eduard Gasparyan”, with

10832 Encino Ave, Granada Hills CA 91344, as the mailing

address. GASPARYAN’s true date of birth was listed on the

application, however, the SSN on the application was not his.

c. On or about August 29, 2021, a California EDD UI

claim was submitted under the name “Gasparyan Eduard”, with

10832 Encino Ave, Granada Hills, CA 91344, as the mailing

address. GASPARYAN’s true date of birth was listed on the

application, however, the SSN on the application is an altered

variation of his own.

D. Bank of America ATM Surveillance Photos Show GASPARYAN and
Angela Karchyan Making Over 200 Withdrawals Using Debit
Cards in Other Persons’ Names

12. Based on records provided by Bank of America,

GASPARYAN was captured via Automated Teller Machine (“ATM”)

surveillance footage making numerous cash withdrawals from debit

cards in other persons’ names. I recognize these images to be

GASPARYAN based on a comparison with his California DMV photo.

In many of the photos, GASPARYAN also wears the same pairs of

sunglasses, a silver watch, and other consistent accessories.

These videos and bank records show:

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a. On or about March 9, 2021, GASPARYAN was captured

via surveillance camera located within a Bank of America ATM

unit making numerous cash withdrawals from debit cards.

Specifically, within a time span of approximately five minutes,

$2,860 is withdrawn from six debit cards. None of the cards were

issued in GASPARYAN’s name.

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b. On or about July 5, 2021, GASPARYAN was captured

via surveillance camera located within a Bank of America ATM

unit making numerous cash withdrawals from debit cards.

Specifically, within a time span of approximately two minutes,

$3,000 is withdrawn from three debit cards. None of the cards

were issued in GASPARYAN’s name.

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c. On or about August 9, 2021, GASPARYAN was

captured via surveillance camera located within a Bank of

America ATM unit making numerous cash withdrawals from debit

cards. Specifically, within a time span of approximately six

minutes, $10,000 was withdrawn from ten debit cards. Three of

the debit cards were issued in GASPARYAN’s name, and seven of

the debit cards are in the names of other individuals.

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d. On or about August 23, 2021, GASPARYAN was

captured via surveillance camera located within a Bank of

America ATM unit making numerous cash withdrawals from debit

cards. Specifically, within a time span of approximately seven

minutes, $4,500 was withdrawn from nine debit cards. Three of

the debit cards were issued in GASPARYAN’s name, and six of the

debit cards are in the names of other individuals. The UI

applications linked to the three debit cards issued to GASPARYAN

were each submitted using a different SSN, causing the

applications to bypass EDD detection.

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e. There were similar images taken from transactions

on at least 50 dates involving over 200 withdrawals through

December of 2021. Most of these showed GASPARYAN doing the

withdrawals, but many showed Angela Karchyan doing them as well.

There is a lag between requesting images and receiving them, and

my last request was in January 2022, but Bank of America has not

yet fulfilled that entire request.

E. GASPARYAN Uses the ID.me Verification System to Submit
Fraudulent EDD UI Claims

13. I reviewed records from ID.me identity verification

systems, which shows that GASPARYAN uses their platform to

submit supporting documentation for EDD UI claims. ID.me is a

website that attempts to verify the identities of persons using

it by asking them for biographical information, photographs,

identification cards, proof of address, and similar information.

Many government agencies contract out identity verification to
ID.me, as does EDD. As a result of these fraudulently submitted

identity verification documents, the claims were approved and UI
benefits were subsequently issued. ID.me provided approximately

1,700 images associated with UI claim records requested in this

investigation. The images include close-up headshot pictures of

the user submitting the claims, driver’s licenses, utility

statements, IRS Form W-2s, U.S. Employment Authorization cards,

Social Security cards, U.S. Passports, and other identity

documents, many of which were apparently altered. From my

review of ID.me records, I learned the following:

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a. In over 200 images, GASPARYAN’s close-up headshot

picture is submitted. I recognize this to be GASPARYAN based on

a comparison with his California DMV photo, and other

identification documents reviewed in this investigation. Because

of variations in GASPARYAN’s clothing, the background of the

images, and changes in hair and facial hair, these images appear

to be taken at different points in time.

b. In over 200 images, GASPARYAN’s California DMV

photo, or other headshot picture, appear on various

identification documents not in his name, including the

following:

i. In at least one image, GASPARYAN’s picture

is seen on California Driver’s License under the name “Ming X

Jan Han”, used in a UI claim submission.

ii. In at least one image, GASPARYAN’s picture

is seen on a California Driver’s License under the name “Yuchen

Chan Yang”, used in a UI claim submission.
iii. In at least one image, GASPARYAN’s picture
is seen on a California Driver’s License under the name “Yanru

Zhou”, used in a UI claim submission.

iv. In at least one image, GASPARYAN’s picture

is seen on a California Driver’s License under the name

“Christen Gadrielian”, used in a UI claim submission.

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F. The First Search of GASPARYAN’s Residence Reveals Identity
Theft Evidence, Firearms, and Suspected Narcotics

14. On July 12, 2022, California Highway Patrol (CHP)

executed several search warrants at addresses believed to be

controlled by GASPARYAN. DOL-OIG assisted with the search of

what was believed to be GASPARYAN’s primary residence, located

at 17843 Rinaldi St., Granada Hills, CA. During the search of

GASPARYAN’s residence, officers and agents discovered the

following, in part:

a. Bulk amounts of personal identifying information

– including Social Security cards, Driver’s Licenses, Department

of Homeland Security Employment Authorization Cards, and other

identity documents not in GASPARYAN’s or KARCHYAN’s name;

b. Bulk amounts of mail in other individuals’ names

– including mail from Bank of America, California EDD, and the
Internal Revenue Service;

c. Bulk bank documents – including bank cards,
monetary instruments, and personal checks addressed to

individuals other than GASPARYAN and KARCHYAN, drawn from

accounts under the names of various individuals;

d. Indicia of occupancy, including pictures in the

living room of GASPARYAN and what appears to be his family;

e. Two handguns, at least one of which was a “ghost

gun”, which is a firearm manufactured without traceable serial

numbers;

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f. One “ghost” AR-15 style rifle;

g. One high capacity 33-round pistol magazine, and

two 10-round rifle magazines;

h. Several bags, containers, magazines, and/or boxes

of firearm ammunition;

i. Approximately 109 grams of suspected

methamphetamine (net weight with packaging);

j. Approximately 61.9 grams of suspected heroin (net

weight with packaging).

G. GASPARYAN lives at 17823 Rinaldi St. Granada Hills, CA.

15. During the July 12, 2022 search of the Rinaldi St.

residence, an individual (“O.A.”) arrived and identified

themselves as the landlord of the residence. DOL-OIG agents

interviewed O.A., and O.A. identified GASPARYAN and ANGELA

KARCHYAN (KARCHYAN) via photograph as living at SUBJECT

PREMISES. O.A. stated GASPARYAN and KARCHYAN are their tenants,

and GASPARYAN and KARCHYAN have lived there since October 2021.

O.A. also knows GASPARYAN and KARCHYAN to be married.

16. O.A. verbally stated GASPARYAN used the identity “Rudy

Pinedd” when renting SUBJECT PREMISES. Investigator Dasilva

stated O.A. identified GASPARYAN as “Rudy Pineda”.

H. GASPARYAN Uses the Identity “Rudy Pineda” in this Fraud
Scheme

17. Rudy Pineda (Pineda) is a suspected identity theft

victim that DOL-OIG agents have interviewed previously in this

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investigation. During the interview, Pineda stated he does not

know who GASPARYAN is, and did not give him permission to use

his identification to file for unemployment benefits.

18. During GASPARYAN’s arrest in April 2022 in Las Vegas,

Nevada, officers recovered a Chase Bank Debit Card embossed with

the name “Rudy Pineda”, according to police reports.

19. I reviewed a UI claim submitted under the name “Yun

Chin Tung” using ID.me verification software, and discovered the

following associated with this claim submission:

a. GASPARYAN submitted an apparently altered

California Driver’s License with his image, bearing the name

“Isaac Rudy Pineda,” a variation of his “Rudy Pineda” identity.

(GASPARYAN also submitted another apparently altered California

Driver’s License with his image, bearing the name “Yun Chin

Tung,” so it appears that he mistakenly used the wrong

counterfeit license with this fraudulent application before

correcting his error);
b. GASPARYAN submitted a Social Security card
bearing the name “Yun Chin Tung”, and a social security number

that is not his;

c. GASPARYAN submitted a “selfie” with a clear,

unobstructed image of his face;

d. GASPARYAN submitted an apparently altered U.S.

Department of Homeland Security Employment Authorization Card

with his image, bearing the name “Yun Chin Tung” in this claim

submission.

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I. GASPARYAN Uses the Identity “Papin Galstyan” in this Fraud
Scheme

20. Papin Galstyan is the true identity of an individual

who, according to U.S. Department of Homeland Security records,

has not entered the U.S. since October 12, 2020.

21. I reviewed a UI claim submitted under the name “Papin

D Galstyan” using ID.me verification software, and discovered

the following associated with this claim submission:

a. GASPARYAN submitted a California Driver’s License

with an image that is not of him, bearing the name “Papin Daviti

Galstyan”;

b. GASPARYAN submitted an Internal Revenue Service

form W-2, containing the name “Papin D Galstyan”, but with the

address listed of “13823 Sherman Way, Apt 3, Van Nuys, CA

91405”. Per DMV records, this is the address listed on

GASPARYAN’s California’s License;

c. GASPARYAN submitted an apparently altered
Spectrum utility statement containing the name “Papin D

Galstyan”, but with the address listed of “13823 Sherman Way Apt
103, Van Nuys, CA 91405”. Per DMV records, this is a slight

variation of the address listed on GASPARYAN’s California

Driver’s License;

d. GASPARYAN submitted a “selfie” with a clear,

unobstructed image of his face.

22. Several hours after the July 12, 2022, search of the

Rinaldi St. residence was concluded, I observed a vehicle

registered to “Papin Daviti Galstyan” parked on the street

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outside of the Rinaldi St. residence. On August 5, 2022, CHP

Investigator Dasilva contacted the finance company (e.g.

lienholder), and confirmed the vehicle was purchased on March

10, 2022 from a dealership in the city of Mission Hills,

California. According to the finance company representative,

only the first payment was made and the account has gone

delinquent since. Due to Papin Galstyan being out of the country

since October 12, 2020, the finance company signed a stolen

vehicle report.

23. During GASPARYAN’s arrest in April 2022 in Las Vegas,

Nevada, officers recovered a California Driver’s License

belonging to “Papin Daviti Galstyan”. Per California DMV

records, this appears to be the true driver’s license issued to

Papin Daviti Galstyan; GASPARYAN is not depicted on this

driver’s license.

J. The Methamphetamine and Ghost Guns Found in GASPARYAN’s
Residence Indicate He Is a Drug Trafficker

24. I spoke with DEA SA Giordano, who has over 3 years of
experience conducting investigations about the trafficking of

methamphetamine. He explained to me that methamphetamine

quantities in excess of a few grams are commonly possessed for

distribution rather than personal use. He said that quantities

of 100 grams or so, such as what was recovered from GASPARYAN’s

residence, were certainly for distribution. He explained to me

that drug traffickers commonly possess firearms to defend their

cash and drug stashes because otherwise they would be vulnerable

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to robbery; they cannot very well complain to the police if

robbed, and must of necessity possess valuable stashes of drugs

and cash. He told me that increasingly drug traffickers are

relying on so-called ghost guns, like those recovered from

GASPARYAN’s residence, because they are easy to obtain through

the black market and are untraceable, which helps drug

traffickers distance themselves from the firearms when they are

recovered by law enforcement. Further evidence that the ghost

guns belonged to GASPARYAN was found when he was arrested in

Chino, California in a car with ammunition for handguns and

rifles, discussed in more detail later in this affidavit. I

know from my training that the rifle rounds GASPARYAN possessed

both in his apartment and in his car are powerful enough to

penetrate the bullet-resistant vests that police officers

typically wear.

K. GASPARYAN Is a Citizen of Armenia, Which Does Not Extradite

25. I reviewed GASPARYAN’s criminal history and saw that
he was born in and a citizen of Armenia, and later became a

naturalized citizen of the U.S., too. According to DOJ’s Office

of International Affairs website, “No extradition treaty is

currently in force between the United States and Armenia.”

L. GASPARYAN Has Engaged in Many New Offenses While on State
Probation

26. According to Los Angeles County Probation Department,

GASPARYAN is on probation from March 22, 2021 to March 21, 2023

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in connection with state fraud/identity theft offenses. The

conditions of GASPARYAN’s probation also include, but are not

limited to:

a. The prohibition of owning, purchasing, receiving,

possessing or having any firearms, ammunitions, and magazines;

b. The requirement to submit GASPARYAN’s person and

property to search and seizure at any time of the day or night,

by any probation officer or other peace officer, with or without

a warrant, probable cause or reasonable suspicion

c. The requirement to disclose to the probation

officer all electronic mail accounts, all Internet accounts, and

any other means of access to any computer or computer network,

all-passwords and access codes. The defendant shall consent to

the search of that electronic mail and internet accounts at any

time and the seizure of any information or data contained

therein without a search warrant or probable cause;

d. The requirement for GASPARYAN to use only his
true name, date of birth, and address.

1. GASPARYAN’s April Arrest in Las Vegas with Drugs,
Cash, and Checks in Other Persons’ Names, During
Which He Fails to Provide His Real Address

27. On April 5, 2022, GASPARYAN was arrested by Las Vegas

Metropolitan Police Department for embezzlement of an

automobile, possession of a stolen vehicle, and possession of a

controlled substance. During this arrest, officers noted

GASPARYAN also had an outstanding warrant out of Nevada Justice

Court for embezzlement of an automobile from 2018. During this
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arrest, GASPARYAN failed to obey officers’ commands and

continued to walk into the hotel/casino. Officers ultimately

located GASPARYAN in one of the hotel rooms. Officers discovered

the following:

a. Stacks of $100 bills wrapped in a $5,000 bank

currency strap, mixed with other loose bills of various

denominations;

b. Vehicle titles not in his name, bearing the name

“Papin Daviti Galstyan” and “Rudy Pineda”;

c. Over $60,000 in cashier’s checks;

d. Numerous personal bank checks not in his name,

bearing the name “Papin Daviti Galstyan” and “Rudy Pineda”, some

of which were signed and made out to “DMV”, “Rudy P”, or “Angela

Karchyan”;

e. A white powdery substance, which was tested and

returned positive for cocaine.

28. GASPARYAN posted bail to secure his release on April
6, 2022. A future court date is scheduled for September 12,
2022. The arrest report reflects GASPARYAN’s parents’ address

(Sherman Way in Van Nuys) as his own. As explained elsewhere in

this affidavit, GASPARYAN actually resides on Rinaldi in Granada

Hills under an assumed name.

2. GASPARYAN’s June Arrest in San Bernardino, During
Which He Provides a False Identity Instead of His
True Name and Date of Birth

29. I spoke with San Bernardino County Sheriff Deputy J.

Tamayo who advised me that on June 2, 2022, he encountered an
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individual who identified himself as “Papin Galstyan”, later

determined to be GASPARYAN, at San Manuel Casino, as described

below:

a. On June 2, 2022, Department of Public Safety

Officers advised they conducted a welfare check on an individual

asleep in his vehicle, who appeared to be under the influence.

When encountered by Dep. Tamayo, GASPARYAN identified himself as

“Papin Galstyan”. Officers discovered the following on

GASPARYAN’s person and in the vehicle:

a. Three clear baggies containing a white
powdery substance, consistent with cocaine,
weighing approximately 27.5 grams total.
GASPARYAN also stated he believes the drug
found in the vehicle to be “crystal”.
According to CHP Investigator Dasilva,
“crystal” is a common street name for
crystal methamphetamine, which is a white
crystalline drug that resembles glass
fragments;

b. $5,487 cash in various denominations.

b. GASPARYAN was able to avoid this arrest showing

on his criminal record by providing the arresting officers with

a false identity. When Dep. Tamayo was shown a picture of

GASPARYAN, he confirmed that the person he encountered who

presented himself as “Papin Galstyan” was indeed GASPARYAN.

c. The arrest report reflects GASPARYAN’s parents’

address (Sherman Way in Van Nuys) as his own. As explained

elsewhere in this affidavit, GASPARYAN actually resides on

Rinaldi in Granada Hills under an assumed name.

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3. GASPARYAN’s July Arrest in Chino with Ammunition,
During Which He Fails to Provide His Real Address

30. On July 29, 2022, GASPARYAN was arrested by Chino

Police Department for possession of a stolen vehicle, and

possession of ammunition by a prohibited person. During a search

of the vehicle, officers discovered 145 rounds of handgun and

rifle ammunition. GASPARYAN subsequently provided a Miranda-

waived statement to officers and admitted to having knowledge of

the ammunition found in the center console, but stated he did

not know about the ammunition found elsewhere in the vehicle.

GASPARYAN stated an individual named “Parkev” was possibly

responsible for the ammunition, but was unable to provide any

information regarding “Parkev”. GASPARYAN also told officers he

knew he was not allowed to have ammunition.

31. GASPARYAN was released on August 3, 2022, and a

$50,000 bond was posted on August 12, 2022. His future court

date is scheduled for September 19, 2022. The arrest report

reflects GASPARYAN’s parents’ address (Sherman Way in Van Nuys)

as his own. As explained elsewhere in this affidavit, GASPARYAN

actually resides on Rinaldi in Granada Hills under an assumed

name.

4. GASPARYAN’s August Arrest in Arizona with Drugs,
Bank Cards in Other Persons’ Names, During Which
He Fails to Provide His Real Address

32. On August 10, 2022, GASPARYAN was arrested by Northern

Arizona University Police Department and charged with possession

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of a stolen vehicle, and felony possession of narcotics for use

and for sale. Officers discovered the following:

a. 28.86 gross grams of a white powdery substance in

a bag;

b. A pill bottle cap with a thick black tar

residence, and a Ziplock bag with thick black tar residue, which

later returned a positive test for heroin;

c. An apparently altered California Driver’s License

in the name of “Rudy Pineda”, but with GASPARYAN’s image;

d. Paperwork including checks, a high amount of

blank checks, receipts, temporary tags, and insurance paperwork,

some of which in other persons’ names;

e. GASPARYAN was released, and a $40,000 bond was

posted on August 11, 2022. GASPARYAN’s address listed on all

the court forms was the Sherman Way one in Van Nuys that he used

for many of his fraudulent EDD claims, which is his parents’

residence. As explained elsewhere in this affidavit, GASPARYAN
actually resides on Rinaldi in Granada Hills under an assumed
name. His court paperwork for this arrest warned him that he

must “KEEP YOUR ADDRESS UPDATED WITH THE COURT FOR ONE YEAR.”

This same paperwork erroneously listed his first name as

“Eduardo” rather than “EDUARD.” In my training and experience,

criminals often alter their names slightly to make it harder to

track or match them to other records, much as GASPARYAN did with

slight variations in addresses he used for his fraudulent EDD

applications.

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M. GASPARYAN Failed to Appear

33. As noted above, during his April 5, 2022 arrest in Las

Vegas, officers noted GASPARYAN had an outstanding warrant in

the Nevada Justice Court in 2018 for felony embezzlement of an

automobile. GASPARYAN was released on his own recognizance in

connection with that investigation on April 6, 2022, and a

future court date was scheduled for May 4, 2022. Gasparyan

failed to appear at that hearing, and a bench warrant has been

issued. A bench warrant for failure to appear was also issued

for GASPARYAN based on a Nevada speeding ticket.

N. GASPARYAN Is Living Under an Assumed Identity

34. According to GASPARYAN’s landlord, GASPARYAN rented

his Rinaldi house under the assumed identity “Rudy Pinedd”, or

“Rudy Pineda”, and has further used that identity to obtain EDD

benefits, obtain an apparently altered U.S. Department of

Homeland Security Employment Authorization Card with his image

but the name of “Isaac Rudy Pineda”, an apparently altered

California Driver’s License with his image but the name of “

Isaac Rudy Pineda”, and engage in further fraud related to

vehicle title washing. Los Angeles County Probation Officer A.

Espinoza, who has over 22 years of law enforcement experience,

explained to me that criminals like GASPARYAN who are subject to

search conditions as part of probation or parole will typically

lie to their probation officers about where they live to avoid

having their new crimes uncovered during a probation search. He

explained that only the most sophisticated and cagey
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probationers, however, go the next step, as GASPARYAN did, of

assuming an entirely new identity so that no attempt to locate

him under his true name would lead back to him and his true

address.

O. I Have Not Been Able to Locate the Fraud Proceeds

35. As described above, the minimum actual loss EDD

suffered from this fraud through March 2022, the last date for

which I have loss data from Bank of America, is over $800,000.

I have attempted to locate these proceeds along with a Special

Agent from the IRS, but we have so far been unsuccessful. It

may be that GASPARYAN keeps the proceeds largely in cash, which

is untraceable. It may also be that he transfers the money

abroad, where it is extremely difficult for me to locate assets.

FBI SA Mark Newhouse, who is on the Eurasian Organized Crime

Task Force and has 18 years’ experience as an agent, told me

that it is common for fraudsters who are dual citizens to send
the proceeds of their crimes back to their home country to
prevent it from being seized by law enforcement here

investigating their crimes.

P. There Will Be a Probation Hold on GASPARYAN

36. I told Probation Officer Espinoza of the Special

Enforcement Operations Unit I planned to arrest GASPARYAN on

this complaint. He said he would wait until GASPARYAN was in

custody on this complaint before placing a probation hold on

him.
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CONCLUSION
37. Based upon the foregoing facts, I believe there is

probable cause to believe that GASPARYAN violated Title 18,

United States Code, Sections 1028A, 1344, and 1349.

Attested to by the applicant in accordance
with the requirements of Fed. R. Crim. P. 4.1
30THday of August,
by telephone on this ____
2022.

UNITED STATES MAGISTRATE JUDGE
ALKA SAGAR

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