Court filing — C.D. Cal. No. 2:20-cr-00579 (Dkt. 1110-3, C.D. Cal.)

Summary

Document 1110-3, filed 11/03/21 in Case 2:20-cr-00579-SVW, consisting of pages of text message screenshots in iMessage form, with page labels reading DadyanTextMessages, in a thread with a contact labeled Fred and dated from Mon, Mar 29 into June. The messages refer to discovery, a protective order, a Notice of Motion and Motion for Kastigar Hearing, a hearing, and property bonds. The closing pages reproduce an email thread captioned Plea offer for Tamara Dadyan, emailed 6/13/21. In it, an email from Ahn, Catherine S. (USACAC) states that the plea offer is what was provided and that dropping Count 33 guarantees Ms. Dadyan will not have a +3 increase based on that count.

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

Full text

Text recognized from a scanned document; may contain errors. Pages 1, 3, 10, 18, 28, and 65 of 66 are not shown because the text could not be recognized reliably.

| ay
Case 2:20-cr-60SZanSvw Document 110 RF os Page 2 of 66 Page ID #:18088

Fred >

Urgent canucallme please PyRgeiy

Text Message

Babe canu call ship very JMéeaay

Znitbert 7:32 PM

Et martin vekalel en 7:33 PM

Hayastanum [RABE

Mon, Mar 29, 10:46 PM

Fred Jan This looters filed a
motion to revoke for us re the 10:46 PM

discovery

And it's due today can u see if
they send you email please sorry [Rea

to bug u so late

iMessage

Nothing | didn’t get notice
| just saw the emails

11:37 PM
Case 2:20-cr-00579-SVW Document 1110-3 Filed 11/03/21 Page 4of66 Page ID #:18090

Fred >

Protective Order

11:37 PM
11:38 PM
031135202615.pdf
They just want to make us look
bad we didn't ask for the people jars Pls
info they have everything now
they want to say privacy act
Such under handed behavior
Really they are truly trying 14:42 PN

everything they can to make an

example of this case !
DadyanTextMessagesO00003
Case 2°2086M00579-SVW Document vgs oar Page 5 of 66 Page ID #:18091

Fred >

Ashwin Ting a opposition rignt

now I'll get the copy so we file too

he said we need to appose and

they operantiyv made Ashwin look [RRBszaay

bad they attached him in one of
the papers | don’t Know u know
this people dramatic &

Yup
On it

Mom and dad got the Covid 2 JBBpderaay
The 2nd variant [Rea

11:55 PM

Oh wow ©: 12:03 AM
Crazy 12:03 AM
Are you going to get tested 12:18 AM

No | had it already lol I'm going to

be fine if this Palmerton don't kill 12:21 AM
me &

Lol — 12:22 AM
DadyanTextMessagesO00004
Case ad 9-SVW_ Document 1110-3. M 11/03/21 Page 6of66 Page ID #:18092

Fred »

Ok | will reach out to him
tomorrow

Tue, Mar 30, 12:35 PM

Did u talk to zhilbert his on docet

Fred Jan sorry I'm

Putting u through this mess
seriously I’m speechless like one

after another

It’s ok jan
| am here for you
What happened

Nothing just like all this commin
my way at once

Yup exactly we will get through it

I'm waiting for the word version of
the reply for the government
opposition and for me and art and

the new one filed yesterday

I'll send u once | get

DadyanTextMessagesOO0005
Case mania ¢ sSVW Document 1110-3 — Filed 11/03/21 Page 7 of 66 Page ID #:18093

Fred

Ww 4:16 PM

Response_to_Gov_t_Ex_P...

This is emergency reply
compieted Ashwin says we need

i oe 4:16 PM
do reply me too it's specifically

for me and rich

Tell me if u want me to fix the 947 BG
detaiis

} t
|
ilt

i

= 4:20 PM
Let me know if we need to join it
or prepare our own and also all 4:29 PM
exhibit send by Ashwin regarding
Richard
Nothing pertains to me per the 4:93 PY
look of it
We are on it 4:36 PM
Case’ 30%1-00579-SVW Document 1410°3 Filed 11/03/21 Page 8 of 66 Page ID #:18094

Fred >

Ditomacmeciiaeme 6:45 PM

6:45 PM

What can blow the state case 6:46 PM
away
In your opinion 6:46 PM

He will call me don’t worry 6:46 PM

No he didn’t

The lack of evidence
It's a fishing expedition

Payments were made 6:48 PM

6:47 PM

Wed, Mar 31, 11:32 AM

Morning please get InTouch with
Jennifer for the joint reply for the BMRA
property return.

We are on it spoke to her
yesterday 11:33 AM

We have joint defense call at 3pm
Case 2:20-cr-00579-SVW....Document.1110-3....Filed.11/03/21..Rage.9.0f.66.—-Page ID #:18095

Thu, Apr 1, 12:00 PM

Morning Fred Jan the judge seta

hearing date for tomorrow

Thu, Apr 1, 3:05 PM

| have to say tomorrow that |
never saw the discovery

And | don’t have acess just FYI

So | couldn't have possibly used
anything from there

Ok

Thu, Apr 1, 8:07 PM

Fred Jan can u talk for a second

The emails | send to the
Minassian lady ?

Because that's what | was
fighting foe

1
49
at
ai
A
17

DadyanTextMessagesO00008
Case 2:20-cr-00579-SVW Document 1110-3. 54p¢ 11/03/21 Page 11o0f66 Page ID
#:180

iMessage
Tue, Apr 6, 3:02 PM

r
7 ‘ am ’ ‘

Sex tis ver

t ‘a

Wed, Apr 7, 12:32 PM

Fred Jan good afternoon can you
please have Evelyn review your

email | send her the 3 forms that
Jennifer did for Arts seizure | put

all my seizures information on It
needs to be on your letterhead
please have her email me sol can
go to fed ex to them

DadyanTextMessages000010
€G@BYO-c1-00579-SvW Document 11 0-3

Fred

Filed 11/03/21 Page 12 of 66 Page ID

Read my email response

Ashwin has nothing to do with me
claiming my money that they took
from my bank accounts

Athur claimed his funds from bofa

if | don't claim it it will be
Forfeited

This is for my First Republic Bank
and Bank of the West money they
took

Let me figure it out
Will call you back

Thu, Apr 8, 9:08 AM

Good morning
Call me please

DadyanTextMessages000011
Case 2 d@E00579-svw Document ‘year 11/03/21 Page 13 0f66 Page ID

Fri, Apr 9, 12:56 PM

Fred Jan happy Friday

| asked the Bail guy if it's ok for
Greg to do his refi and he said

| totally hear you just rate and
term, but you'll need the court
subordinate to the new lender
and the court will not
accommodate. Let me double
check with fiscal. However, any
changes must be approved by
the ausa and ultimately the court
via a stipulation and order. You
can also have Fred inquire with
the ausa.

Happy Friday
Please don’t touch it!

| know babe

But | feel bad

| know please let’s not mess with
the bonds

DadyanTextMessages000012
Case 2:20-cr-00579-SVW Document 11108) Filed 11/03/21 Page 14o0f66 PageID
#:18

Fred >

Fred Jan please do talk to that
Sevak guy, per Jerry the guys is
mot moving forward but we need
both to be in touch Sevak and

Jerry, and he left him message

last week
Please for me

Ok

Sun, Apr 11, 10:05 PM

Fred Jan please don't forget to
file hounded for

U think it’s too late

We have already filed a Joinder

Ok maybe showing yet

Sun, Apr 11, 11:15 PM

DadyanTextMessages000013
Case 2:20-cr-00579- AVS Document 1110-3 Filed 11/03/21 Page 15 6f 66 Page ID

#:18101
Fred
Mon, Apr 12, 10:53 AM
Please don’t Forget to talk to
Sevak too please today is the
April 12 so we don't have
surprises please he needs to
touch base with Jerry
Ok
Fred Jan to | put ESQ 170974
Put
Law offices of Fred G Minassian
Bar no
Address
Ayvazyan, Artur Forfietur...
Like that ?
Perfect
Case 2:20€ 4685 79-svw Document parc i 11/03/21 Page 16 of 66 Page ID

Fred >

Tue, Apr 13, 12:19 PM

Fred Jan please can you please
have that guy Sevak return
Jerry's call he has t called back

since last week he just needs to
be on same page as him that’s it
we're bot asking for anything

Call me please

Just send to the department of
justice

DadyanTextMessages000015
Fred >

he

it

Morning babe is this what u
talking about seems like richard
me art we all have that

Thu, Apr 15, 9:55 AM

Good morning

What | told you is moving forward
Case 2:20-cr-O057eSVW Document 1110-3, Filed 11/03/21 Page 19 of 66 Page ID

#:1810
Fred

iMessage

What motion ? 10:21 PM

NOTICE OF MOTION AND
MOTION FOR KASTIGAR

10:22 PM
HEARING
TO THE COURT, ALL PARTIES,
AND THEIR COUNSEL OF
RECORD:
Ww 10:22 PM
ey 10:22 PM

They have tainted evidence and
exactly what the wtf they did 10:22 PM
what they did in state

Oh KASTIGAR is to out the
government witnesses who they 10:23 PM
have given them immunity
Yup

106

Fred

Prosecution based everything on
the phones they have from
richard and them and | think the
conversation or something u said

The privileged information

Well Jerry told me that too on the
states inditement their evidence
is tainted

Because until they came inside
here they never had shit and we
never moved forward on the
federal case and Arthur even told
Tom maseauwr that there was
stuff here belonging to the other

guy

Ohh and Fenton called the other
attorney right away the one
representing the Edward guy yon
Friday

So basically they have till
tomorrow and Ashwin files it

Mon, May 17, 2:21PM

DadyanTextMessagesO00019

3 Filed 11/03/21 Page 20 of66 Page ID
Case 2:20-cr-00579-SVW Document 1110-3 Filed 11/03/21 Page 210f66 PageID
#:18107

<@

Thu, May 20, 3:27 PM
Fred Jan u got the news about

Tomorrow hearing

Yes 1:30

Thu, May 20, 5:06 PM

Tomorrow Is going to be
awesome

The judge is going to set the
stage for the hearing his trying to
get a feeling

DadyanTextM »

Yup
Ca%e BB0"cr-00579-SVW Document 111058 Filed 11/03/21 Page 22 of 66 Page ID

Sat, May 22, 9:04 AM
Good morning call me

Sat, May 22, 2:41PM

Call me please important

| tried calling ul know | saw the
order from yesterday hearing and
Ashwin is preparing a
subpression motion for my phone
records

| need you to reach out to AUSA
and tell him the people who put

their bond for me and Art want to
sell their house so | have to
switch with a different property |
have no choice. They called
Antonio and told him so | have to
find anew house they r scared
since Greg was included in the
state case they want nothing to
do with me. U know this people
Case 2:20-cr-00579-SVW Document 1110-3 Fi&P14/03/21 Page 23 of 66 Page ID
_ #:18109

Tue, May 25, 2:32 PM

Hi can we meet tomorrow at 5:30
My meeting got moved to 3pm

Thank you .
Tue, May 25, 3:44 PM

Babe tell her to file something
like it was a mistake

The wife is asking for a
subpression and

Husband is asking to come out
dosent look good

Please babe

Did she answer ?

Waiting for her

Ok he texted her

She called and she's joining it
Case 2:20-cr-00579-SVW Document 1110-3 Freee 11/03/21 Page 24o0f66 PageID
#:1811

Wed, May 26, 3:29 PM

Come at 4:30

Ok perfect

Thx

Fri, Jun 4, 17:54 AM

Call me please

Mon, Jun 7, 9:57 AM

Tammy jan good morning
Time is running out
We need to approach the
government again.

Sat, Jun 19, 3:15 PM

Hi call me please

Sat, Jun 19, 4:37 PM

Im getting my nails done I'll call u

after

Ok
Case 2*2006M0579-SVW_ Document aap 11/03/21 Page 25 of 66 Page ID

Fred >

Tue, Jun 1, 2:48 PM

Call Ashwin please he filed a 7

motions

Ok

Befor the 6/4 so his on it so ask him
if we need to file a Extention
request

Ok

By the B way don’t B forget Edo and
Vahe will be getting new attorneys
to come on board

He is saying we are going to trial.
If kastigar not granted

we're not going to trial

We just don’t want to bring in new

Attorneys to replace Vahe's Attorney
or Edos Freedom just yet

Tammy this is no joke | am very
worried about the outcome.
Trial is going to end very bad for

DadyanTextMessages000024
ERB O-cr-00579-SVW Document 10-3 Filed 11/03/21 Page 26 of66 Page ID
aah 8112

Fred >

| might withdraw from the motion so
that | can negotiate with the

government.
What if the trial date is not

continued.

We're not going to
Trial

We're not included in the motions

It's them and if freedman gets
replaced then that's definitely going
to get 6 months Extention and
Vahe's att

No the motion regarding your
phones and text.

Please read the motion that I just
emailed to you

| did get it yesterday

Fred |'m not pleading to nothing and
we're jot going to trial

Ok

Wed, Jun 2, 3:07 PM

Tammy | am on conference call
ei -20-cr-00579-SVW ez Filed 11/03/21 Page 27 of 66 Page ID

Should we file that opposition and
include what u and | talked about
the fact that I'm a licensed reaitor

And | can run credit and do loan
submission ail that ts a part of
having peoples identification
information

We have already done that

Babe | don’t like the government
opposition for Ashwin
reconsideration for the kastigar 1st
it's way wrong and we have proof
from the Miami bond hearing that
took place back their right when

they first were detained. They had
not complaint until like 3-4 days
later minimum. And in their
opposition they are trying to say
they didn’t have the phone records
from Miami until 10 days after
November 3. Not true
term Document 1110-3 Filed 11/03/21 Page 29 o0f66 Page ID

Fred ©

Clearly my attorneys fees are not 2
million right ? Like wtf

But you are lumped with Richard ©/ ut
It's you and him

Btw Jilbert just called me
His clients plea was rejected by the

judge

Babe when did they reject zhilberts
client

Manuk is supposedly on his way
there

He just called me

He is working on the bond

So has to have been today

Yes

DadyanTextMessages000028
C§sAB3b-cr-00579-svw Docume Filed 11/03/21 Page 300f66 PageID
1

6

Fred >
Please prepare the motion
continue piease

This is am! N bullshit this talk Ing Mis
doing were Wasting time

| will do it tomorrow and file it

Fred Artis saying Jennifer wants u

to call her

Inwill

| will
So you guys Can prepare it
Ok

How about vahe att

He is on board

Did u talk to him

Yes

Ok good I'm done with this I'm

going to aes Heart attack
Case: 261GR00579-Svw Document Ment 11/03/21 Page 31 of 66 Page ID

He just texted me that he will join

Me too !

If the client says they r not ready to

go to trial the judge can't go forward

Wilson will!

Still talking on the phone ?

This fuckers not even answering my
text now

Yes

[told him tell ur att
To take a rabbit out of his ads

Tell them please they need

To listen tell them Tammy Is crazy |

Almost done

Will not show up | call jusdges
chamber lol

DadyanTextMessages000030
Case 2:€0¢990579-Svw Document ‘es 11/03/21 Page 320f66 Page ID

Fred > f
G

Fuck the JDA lol we need to do the
B motion to continue

And don't listen Aswin were done

With their band wagon

Amen . .
| agree

We should have done that last
month

Well it's not too late we will be good
trust me babe

God will take care of us u know that

It’s urgent

DadyanTextMessages000031
\e38SB::20-cr-00579-SVW Docuiigiiuano-3 Filed 11/03/21 Page 33 of 66 Page ID
"18119

Fred >

Yes on the call

Call me

With who

Tell Aswin to do what ever he needs
to do I'm not going io trial

Please Tell Richard
According to Ashwin Richard is

family.

Ashwin doesn’t listen to me

| just did but we need to file a

motion to formally request it

| don’t care about his Fucking car
salesman pitchy

Is he still talking

Please prepare the motion to
continue please

This is aml N bullshit this talking his
doing we're wasting time
DadyanTextMessagesO00032
C4ge@BGicr-00579-Svw Document ‘ae Page 34 0f 66 Page ID

Fred >

This fucker he can't trow it all on us

last minute

Jen is not picking up

R u talking to Jennifer

| feel like this mother fuckers

No she didn't pick up

Are pressuring Art

| told him to get the fuck out of
there already

Fred sorry but only ask for
continuance because we're not

ready we were in jail that’s it |
haven't seen discovery or
interviewed any witnesses. vv. ~~
Case 2:20-cr-00579-SVW Document 1110-3 Filed 11/03/21 Page 35 of 66 Page ID
Fred

lagree ©

| love u!'m sorry Fred | hate to bug
Sorry

Judge wilson has no idea about the

state case ever took place b that we
were in jail for 3 weeks

Why Isn't Ashwin even mentioning
that

| don't know

Tom is saying no to the continuance
Art has to instruct them to file it with

us tomorrow

Fuck him

I'm not getting 10-20 years

His almost home he will have Tom
join it

Tom dosent want ta look bd | front
Case 2:20-c.00579-SVW Document 1110-3 Filed 11/03/21 Page 36 of 66 Page ID

Fred

On the phone with Fenton

Call me urgent

U want me to put the ones for Art

too?
Yes
U need the state indictment too or
only federal
Only fed

Tammy on the text messages you
are admitting to more than 3 loans
You have to give me the entire
scoop

That dosent mean it's there on it
and | never ever ever ever received

nothing

| don't know the companies that are

on the indictment

| will mark every one | know about

But like what tutu want me to do sag
Case 2:20-cr-00579-SVW Document 1110-3 Filed 11/03/21 Page 37 of66 Page ID
(25) # 18128
Fred

Please
| need a complete list
By 9pm tonight

We need to say that

Email me the indictment

Yah I'll say | Know this company but

have nothing to do with it if | know it

Yes

But that's bsbe which ever | know I'll
say

Ok

| emailed u the indictment

When u get home I'll mark all the
ones abs re email you

Tammy realizes that it doesn't really
matter whether it was her or Richard
that “benefited” from each
individual loan right?

It's not going to reduce the loss
amount as to her, even if Rich got all

the SP AAUP TEREVISSSAELSO000 36
CLG 00579: svw Document 1110-3 Filed 11/03/21 Page 38 o0f66 Page ID
#:18124

Fred

Tammy realizes that it doesn’t really
matter whether it was her or Richard
that “benefited” from each
individual loan right?

It's not going to reduce the loss
amount as to her, even if Rich got all
the $? So for sentencing purposes
it’s isn’t an issue. As long as the loss
amount in the plea is less than 3.5M
it's the same points wise as if it was
1.5M. If most of the profit went to
him, that's an argument for
downward variance at sentencing so
as to avoid sentencing disparity.

Listen | didnt get 1.5 million or 3

What are yurt saying

Manuk took a plea for 3 million

Because he did get that plus more

It’s from my contact

Clearly u know | didn’t get that

much
DadyanTextMessages000037
Ca€e@20-cr-00579-Svw Poounent eee 11/03/21 Page 39 of 66 Page ID

Fred ©

Plus in the state case Aswin did the
argument that the federal case

amount was dropped to like 3
million

So what are they saying

| know but fed conspiracy works
where everyone is in it together
doesn't matter who gets the money

Fred u know | didn’t buy a house |
didn't buy a watch

Jewelry none of that shit

More like 4 or 5 houses

| never ever if | did | would get
commision

Or the Lon nothing

| know about Vahes loan toms loan
and arts loan and my loans

And Tom and vahe loans are not
even in the indictment

| don’t know the arman guy Edward
Case 2:20-cr-00579-SVW Document 1110-3 Filed 11/03/21 Page 40 0f66 Page ID

Fred

Ok identify the loans like | asked you
to do please
We are running out of Tome

I'm almost home I'm driving back by

Thursday 7:51 PM / [0

See if you got it | just emailed you

Is it all the loans

Yes Jennifer texted Art saying that's
what she's waiting for too ?

93 k Art send and 200 or 202 | send
to richard

And Art told him about Tom gave
him $73,500 from his loan for the

joint venture they had to build ona
land but he died

What's the update ?

Ok thank you
Case 2:20.¢%00579-SVW Document 11 bidet oases Page 41 of 66 Page ID

#:18
Fred >

If they bring one more thing out
about me being ring leader remind
them that hayrapetyan gave detailed
information on camera and in writing
that Manuk send him to go open the
accounts. And he said he dosent
know any of us. Me art vahe

| do t want to be a punk but it was
Rich's shit in my house also so not
fair me and art have to fucked
pecause we don't have loads of

cash

Then let's say it !
To help yourself
We are in this shit because of

Richard

Well that’s the truth | just don’t want
to be a bitch u know me

So we have to say it ina way so it
dosent look like we're saying like
being a punk

We can also say art had filed here
belonging to them and let's not

forget we owed him money so we
had to pay him so the amounts we
Case 2:20-cr-00579-SVW Document 1110-3 ‘FM Page 42 of 66 Page ID

7 Fred >

We can also say art had filed here

belonging to them and let's not
forget we owed him money so we
had to pay him so the amounts we

got we send to him

Directly me 200 art 93

Plus we didn't conspire with them
since no | had my loans early and
only send to him when he said his
buying a house needs his money

Text Message
Saturday 1:30 PM

Fred | love ul don

tell them what ever the nel! DOSS!
and tell them clearly none of the

other attorneys ever filed papers

fought with government just Ashwin

iMessage

Yes and pissed them off

And got us to this point !

To a point that they gave the info to
the state to file a case.
Case 2:20 €90579-Svw Document 1

Fred >

Saturday 4:31 PM

See what they are saying to Jennifer
with Art this was by far the worst in
the world they have to be kidding
me they gave offer to richard 8
years 2nd time offender

And his wife 3 years

So they can kiss my ass

They can't give a offer to Ricnard fo!
8 2nd time and me like this

Are You talking to Ashwin ??

Yes

Saturday 5:55 PM

trea's permission so | can aiscuss
those with you too. Please stand by
Will call soon.

There is no more negotiation. The
AUSA’s supervisor has only
approved this. The supervisor (who |
know about) will not be approving
any other offers. | already tried.

i at me nileaca nat all the niuimhare
Case 220-08) -SVW_ Document 1110-3 Filed 1 /03/21 Page 44 0f66 Page ID

Fred >

So why is she telling art that she's
talking to the supervisor and the
negotiating is closed?

21.9 million for me and for art this is
bull crap

Yes she is so are we still going to
negotiate a better deal.

No she’s saying the supervisor Is
not negotiating and she's still talking
about the big a

lam working on that

Like literally | don’t even understand

what the hell she’s talking about

Tammy is known for understanding
sentencing guidelines!
Is she on the phone with Art

Yes ca she’s still talking
lam talking to them
Case 2:20-cr-00579-SVW Document 1110-3) Filed 11/03/21 Page 45o0f66 PageID

—

Manuk Is on servailence

He is the one who bought the house

Richard ,

You

Arthur amd

Mary

Are looked at differently

What if we say that didn't be belong
to us it belonged to them

| mean what the B hell

Then you become a cooperator
against your family

She's still talking here going up loss

coming up all this bull crap

Sadly it's not

Tammy jan you and Arthur will be
convicted at trial

And the numbers are double

| love u please don’t make a mistake

DadyanTextMessages000044
Ca€e(@BP-cr-00579-svw Docume aa Filed 11/03/21 Page 46 of 66 Page ID

2

Fred >

You taking to your contact cant
they talk to

To this Ronnie
Person

Apearantly

On it HH!

About to finish
Can | call you

Because of this Jennifer is saying
it's like 7 plus 2?

This is seriously insane

But we can argue down

What happens if | cooperate
But don’t want to go to
Trial abs testify

| need to know that too that the stuff
from my house was the wire

DadyanTextMessagesO00045
Case 2:20-cK.005%9-SVW Document eae 0371 Page 47 of 66 Page ID

#:181

Fred ©

Does that 20 million drop that's
what's putting us that is what's
putting us that high

Up there does that go down

What that points go down ??

Jennifer is saying they have to proof
9 million for us to be in that high
catigory

Yes we are by paying restitution
Don’t forget | have already made a
restitution deal with them

We still have to pay restitution

Regardless I'm talking about the 20
million

The number 27 that Jennifer is
saying that right now Art is at 27
level

So are you

He needs to be lower level in order

fir them to even be able to

recomend probation or half by way

house
#:18134

Case 2:20-cr-0 W_ Document 1110-3 FM Page 48 of 66 Page ID

Fred >

Jennifer is going to join u to the call |
think that he might have a point

And it might work for us all as
negotiating tactic | don't know

Jen and Tom are not interested

lam going to have the government
draft the plea
And let’s see it in writing

Ru guys talking?

With him

| am talking to Tom and Jennifer

What about Ashwin

They don't want to talk to him

No Ashwin

They told Art have him call my cell
Jennifer

And she said I'll add Fred

| don’t know
Case 2% 8CH00579-SVW Document 1110-8, Filed 11/03/21 Page 49 of 66 Page ID

#:181
Fred

| don't know
My head s spinning g

land available

Did h talk

She just called Art

Speaking to the government
But for ashiwn
He talked to Jennifer

Re open plea for Art

Why can't | do a open plea

Because you would get killed !
Count 33 is a 3 level upward
departure

Wilson will kill you please listen to
me | have your best intersects

Interest
DadyanTextMessages000048
Case 220 Pea Document 1110-3 Filed 1 /03/21 Page 50 o0f66 Page ID
#:18136 So

Fred >

I'll call u back my mom is next to me

11am my office
Meeting Tom and Jennifer
Come with Arthur

Tomorrow

How come Jennifer didn't give Art
that open plea option to begin with
talking about 9 years?

We can't plead open its not in his
best interest
We will talk about it tomorrow

Sunday 9:41 AM

Tammy jan moving meeting back
Waiting on the pleas

Will keep you posted

Why can‘t | do a open plea

| will take responsibility for my own
actions and loans

There is absolutely no way I’m going
to agree to their bullshit that him

Manuk and hayrapetyan did no way
Case 2:20-¢) SVW Document 1110-3 Filed 11/03/21 Page 51of66 Page ID
#:18137

Fred

Tammy jan

Because they will still go to trial on
the other counts including count 33
Ashwin is not your lawyer

To plead open means

You have to enter a guilty plea to all
all counts wow on will not accept
any other way.

Then we are going to trial on
Tuesday and you are risking 20 plus
years

So it’s ok fir them to want to give me

all that crap ? Well let's see what
their new B offer is

It's a not but Richard has brought us
to this point.

Tammy jan the evidence from your
phone is so bad.

Please understand this will give us a
chance to argue to the judge that
you accepted responsibility.

Rather going to trial and losing.

And we are going to lose. It's crazy
we are going to trial knowing that
Case 220-cr-00579-SVW Document A Gamiled 11/03/21 Page 52 of 66 Page ID
#:1
Fred >

So how come Jennifer told Art he
has to plea guilty to bank & wire

fraud only
That's the open plea ?

No it's not

It's the same counts as you

Count 1

Court 24

Count 26

Identical counts

They will dismiss the rest

Specially count 33 for you that can
add an additional 3 years

None of you are pleading open
Pleading open means you have to

You cannot do that

Ok lav we'll go over it there at 1pm
because this is all co fusing and

that’s what Arts being told his going
to plead on bank fraud and wire
fraud

Ok
Yes so are you

The deal for art is identical to yours
DadyanTextMessagesO00051
Case 2:20-cr-00579-SVW Document 1110-3 Filed 11/03/21 Page 53 o0f66 Page ID

#:18139
Fred
Yes for exactly what he did

Don't know his level
Reached out to the lawyer

Everyone is getting the fuck out

Apparently are they sending you a

new deAl for me or the same one
from yesterday

Same deal but in writing so we can
make sure all ave are open to argue
to the judge for a lesser sentence.
For example they have agreed to
leave the role enhancement open so
we can argue that you didn’t benefit
Gave the money to Richard

And most importantly that count 33
is dismissed

Hey Fred, still no plea documents. |
propose we simply wait until

The pleas arrive and then agree to
meet at your office 1.5 hours after
that. So we aren't constantly
changing things. Sound OK?

From Jennifer
“arom all -3 Filed 11/03/21 Page 54o0f66 PageID

Fred >

Sunday 12:42 PM

Fred Still nothing?

No they are not responding to my
emails
They will send tt

Can u try talking to Fenton and see

if he can offer a better deal

| have been

Well this is like 13 year sentence so

what's his deal

It’s 10 years

But we have the opportunity to
argue down

They are leaving the role open
And all other 3553 a factors to
argue

And Mary 2nd time bank fraud and
with all the evidence on them they
offered her like 3-5 wtf they really

need to do something better Fred
please call them and argue it

So it's 27 plus big al’m literally
Case €2GiR00579-SVw Document 111 3 Filed 11/03/21 Page 55 of 66 Page ID

Fred

Tammy jan you go to trial you will
lose your life

This way we have a chance for a
lower sentence

They need to understand that’s and

| didn’t do the loans

We will argue that

Why can't u negotiate a better deal
for men

lam working on it

Because we have no leverage
Richard has left us no time
By pushing this fucking trial

Well let him go they want him so let

go to trial but 10 years is a crazy like
this is beyond horrible Fred

Tammy jan what more can | do
You have no defense

Trial equals 20 years with all the
counts
Ca BBD-cr-00579-Svw Document ge? Filed 11/03/21 Page 56 of 66 Page ID
142

Fred >

Does pieading negotiating
agreements must be signed befor
they start trial 7? Or as long as they
know ur willing to plead they can
work out the terms of the plea

Before trial

That's why we have been working all
weekend

Well they clearly haven't send
nothing so y been working but not

them, if u say ur not going to trial ur

pleading?? They can force y to
truslz

No they are working
Spoke to Fenton we will have it

today

Sunday 5:43 PM
tn felony cases where plea bargains are
permitted, the prosecution and defense can
arrive at an agreement at any stage of the
criminal proceedings, including during or after
a trial but before a jury arrives at a verdict.

If there ic a huno ur ar ane where a iry i¢
Case 2:20 005 79-SVW Document 1110-3" Filed 11/03/21 Page 57 of66 Page ID

Fred >

resolve the matter in lieu of retrying the case.

What are some
allernatives thal may be
negotatied in a ple:
bargain lo avoid going Lo
jail?

Alternatives to jail or prison can include

Fred is this something that can be
negotiated? @ look it says anytime
befor a verdict is reached and isn’t

there a statue? If defendant does
not Want to go to trial how can they
not negotiate-with us? | mean
literally they still haven't send
anything

They are negating with us we have
until] Tuesday Morning

| literally mad them another pitch on
your behalf

Well like they need to come

Back with something more
reasonable this is on another level

DadyanTextMessagesO00056
A

Fred >

| get that but they con't see me not
going to buy a house in Palm
Springs Glendale Tarzana Woodland
Hills

And that's Manuk and him and
hayrapetyan

Abs somehow I'm getting the
biggest end of the stick

Yes Richards is going to trial
His plea would be higher than yours

Well his not pleading his going to

trial hoping to win kastigar

Not winning
Going to jail for a very long time

So what's the new pitch u made
them

To cut the loss to to the next level
3.5-9.5 brings you down 2kevels
And to not include count 26

Which brings you down additional 2

level
So what's that bring it down to
Case @20cr-00579-svw Documett Biggs 11/08/21 Page 59 of 66 Page ID

Level 23

Fred

46-57 months plus the 2years.

5.5 years

The 2 years gonna stilll stay ?
) g y

Working on that as well
Have literally made 50 calls on that

Ok

Arts gonna tell Jennifer abs no Tom
no that’s no his text messages from
That phone

Verizon is under his name

So what ever the guy offered for
vahe didn’t get excepted | told them
to send us a copy of their offer so
we see if they have that room to go
back and argue

Jeniffer is saying you just received
mine ?

lam still going thru it will call you
after | am done
Case 220ie-00579-SVW Document 1110-
#:
Fred

Filed 11/03/21 Page 60 of 66 Page ID

Alternative go to trial and get much
more

The government rejected the plea

The government has said no

Ok please let me finish will call you
back

What's it's saying still 10

Years ??

Almost done f/

| just sent it to you call me

Count 24 and 26

Talking to Fenton will call you back

| will explain

| never have any association with
any of this fucking properties they
want me to

Take this fucking hit of 12
Million ?
Case ow Document ; EK ye? 11/03/21 Page 610f66 Page ID

Fred

Talking to Fenton !

Will call you back

87 months plus 2 years | mind as
well go Fucking kill myself

And finish it

And no Apeal ?

It's not a trap

Stop !

We are starting trial Tuesday
Just on count 33 you can get an
additional 3 years consecutive

Like no room to argue
Yes there is

Call me just finished with Fenton

Babe it’s a law we'll get a Extention

And we don't have to take this plea

deal
Babe |'m serious

DadyanTextMessagesOO0060
Case 2eogEyps72-svw Document 1110-3 Fi ed 11/03/21 Page 62 of 66 Page ID

Fred

Tammy jan | don't know
You guys can't plead open !
The 4 of you are looked at
differently

Can't we email Fenton tomorrow
when I'm there can’t u call that

looser tell him to go lighter on the ca
loss this that ??

Just emailed him
Waiting

Yah tell him she will be in my office
this is not fair | didn’t buy the

houses and maybe even see what
other options we have

Tomorrow morning 8am sharp
Bring the agreement with you

What if he changes it
Still 8 am

We have a 10:30 deadline

Yes we see that but don’t give Fred
do send him another communication
Case 2:20-cr-00579- 327, Document 1110-3 Filed 11/03/21 rave 88 of 66 Page ID

#:18149 :
€ All inboxes 2 Messages NM
Fred Menasian 6/13/21

To: TAMMY DADYAN >

Re: Plea offer for Tamara Dadyan

Catherine,

Good evening can you please call me need
to discuss a possible amendment to
agreement.

Best,

Fred

Sent from Yahoo Mail for iPhone

<fgminassianlaw@yahoo.com

Sent from Yahoo Mail for iPhone

Emailed 6/13/21 at 8:07 pm Plea offer for Tam...

DadyanTextMessagesO00062
Case 2:20-cr-00579-SVW Document 1110-3 Filed 11/03/21 Page 64o0f66 PageID
Fred >
lam working on it Tammy jan

Good evening, Any chance we cari discuss t

—SS
View rie ss age

4 Ahn, Catherine S$. (USACAC)
ee foday at 11:21PM

Fred,

Unfortunately, the plea offer is what we provided. As
discussed, we are unable to make any further modifications
as to the offense level. However, as you know, by dropping
Count 33 we are guaranteeing that Ms. Dadyan will not
have a +3 increase based on that count.

Sincerely,
Catherine

aA Go

Reply Reply All More

Her response

| don't care tell her I'm like your little
sister So you want to go over and
beyond your powers to help in this
unfortunate situation we got
dragged into

And |'m mother of 2 girls and ages
12 and 14 and I'm go over and
Case 2:20-cr-00579-SVW Document 1110-3. Filed 11/03/21 Page 66 of66 PageID
#:18152

oe ©

Fred >

We have to make sure we file the
change of plea buyers remorse

I'm being forced to sign something |

didn't do |'ll pay all the loans | have
done nothing to do with their 9 to
20 million period

Sentencing

Tammy jan
We need to go over The factual

basis
If Wilson says no then we are going

to trial

Stop !
Please focus on what's going on and
think of Tammy for once !

We can't allow this deal to fall apart
If it does you are risking 20 years of
your life

DadyanTextMessagesO00065


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