Defendant Tamara Dadyan's Reply on Motion to Withdraw Guilty Plea (Document 1110)

Summary

Defendant Tamara Dadyan's Reply to Government's Response to Her Motion to Withdraw Guilty Plea in United States v. Tamara Dadyan, No. 2:20-CR-00579-SVW-4, filed November 3, 2021 as Document 1110, with a hearing date of November 10, 2021. Her counsel argues that her former attorney, Fred Minassian, failed to review discovery, relied on co-counsel's motions and pressured her to accept a plea agreement requiring an untrue factual basis. The filing sets out a dated timeline of her communications with him and with the government. It concludes that she has a non-frivolous defense, timely acquired new counsel, and asks that her plea be withdrawn so she can proceed to trial.

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“Defendant Tamara Dadyan's Reply on Motion to Withdraw Guilty Plea (Document 1110).” Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/court-filing-c-d-cal-no-2-20-cr-00579-dkt-1110-c-d-cal-d85b0816ee/, SHA-256 734c2678a838cf89a140a076b25cf031f97302c0108321f19b349058de8293cf.

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Case 2:20-cr-00579-SVW Document 1110 Filed 11/03/21 Page 1 of 13 Page ID #:18042

1 JERRY KAPLAN, ESQ. Bar No. 49142
JOSEPH BENINCASA, ESQ. Bar. No. 251347
2
Kaplan, Kenegos and Kadin
3 Attorneys at Law
9150 Wilshire Boulevard Suite 175
4 Beverly Hills, California 90212
Email: kapkenkd@pacbell.net
5
Telephone:(310) 859-7700
6 Facsimile:(310) 859-7773

7 Attorneys for Defendant
8 TAMARA DADYAN

9
UNITED STATES DISTRICT COURT
10
CENTRAL DISTRICT OF CALIFORNIA
11

12
THE UNITED STATES OF AMERICA CASE NO. 2:20-CR-00579-SVW-4
13

14 Plaintiff, DEFENDANT TAMARA DADYAN’S REPLY
15 TO GOVERNMENT’S RESPONSE TO HER
vs. MOTION TO WITHDRAW GUILTY PLEA
16

17 TAMARA DADYAN, DATE: NOVEMBER 10, 2021
TIME: 1:30 PM
18
Defendant. COURT: HON. STEPHEN V. WILSON
19

21 Defendant Tamara Dadyan’s attorney, Fred Minassian, failed to review any discovery,

22 pinned his hopes on his co-counsel’s motions to dismiss the case, and when a panicked Motion
23
to Continue was denied, pressured the defendant to accept a plea agreement that required her to
24
admit an untrue factual basis. 1
25

27
1
Mr. Minassian has been under federal indictment since July 27, 2017 for Conspiracy to
28 distribute controlled substance; Conspiracy to falsify a material fact, engage in witness tampering, and falsify
records; Making and using a false writing containing false statements within federal jurisdiction; Making a false
1
DEFENDANT TAMARA DADYAN REPLY TO GOVERNMENT’S RESPONSE TO HER MOTION TO
WITHDRAW HER GUILTY PLEA
Case 2:20-cr-00579-SVW Document 1110 Filed 11/03/21 Page 2 of 13 Page ID #:18043

1 Notwithstanding the government’s claim that the evidence against her was
2
“overwhelming”, the defendant should not have been permitted to admit to an untrue factual
3
basis and should have been permitted to plead guilty to the charges of which she was actually
4
guilty and proceed to trial on the remaining counts. Due to the dereliction of her counsel she
5

6 now faces a significantly higher sentence and should be permitted to withdraw her plea and

7 proceed to trial.
8

9
Date: November 3, 2021 Respectfully submitted,
10
/s/ Jerry Kaplan
11
JERRY KAPLAN
12 Attorneys for Defendant
TAMARA DADYAN
13

28 statement to a law enforcement officer; and Falsification of records. 2:17-cr-00480-PSG-6, USDC, Central
District of California.
2
DEFENDANT TAMARA DADYAN REPLY TO GOVERNMENT’S RESPONSE TO HER MOTION TO
WITHDRAW HER GUILTY PLEA
Case 2:20-cr-00579-SVW Document 1110 Filed 11/03/21 Page 3 of 13 Page ID #:18044

1 I.
2
TIMELINE OF EVENTS
3
The following timeline of communication between the defendant and Mr. Minassian,
4
and between Mr. Minassian and the government, show that Mr. Minassian was wholly
5

6 unprepared for trial and desperately sought to get the defendant to plead to an improper plea

7 agreement.
8
November 5, 2020. Defendant is arrested on a criminal complaint.
9
November 17, 2020. Indictment filed against the defendant and three co-conspirators,
10
which included her husband, Artur Ayvazyan, and her brother-in-law, Richard Ayvazyan.
11

12 December 6, 2020 and January 13, 2021. Mr. Minassian accesses the Steptoe database

13 and views a grand total of two (2) items (Bates 94 and 16828) and downloads the audio
14
recording noted by 16828. The recording is less than 5 minutes long.
15
These two items are the only discovery accessed by Mr. Minassian from the database
16
for the entirety of his representation of the defendant. (Exhibit A).
17

18 February 18 and February 24, 2021. Bank of the West released to the defendant

19 $100,000 from accounts that had been froze by the government. (See Exhibit E). Mr.
20
Minassian told Ms. Dadyan to deposit the monies into her Trust account to protect it from the
21
government seizing it. Ms. Dadyan gave the money to Mr. Minassian’s Trust account. To date,
22
he has retained these funds despite the fact that these monies are part of the loss calculation and
23

24 likely restitution order, and he has informed Ms. Dadyan that he was using that money for

25 attorney’s fees.
26
March 9, 2021. The First Superseding Indictment was filed, adding four (4) new
27
defendants and twenty-one (21) new charges.
28

3
DEFENDANT TAMARA DADYAN REPLY TO GOVERNMENT’S RESPONSE TO HER MOTION TO
WITHDRAW HER GUILTY PLEA
Case 2:20-cr-00579-SVW Document 1110 Filed 11/03/21 Page 4 of 13 Page ID #:18045

1 March 15, 2021. The defendant and co-defendant Artur Ayvazyan move to suppress
2
evidence seized pursuant to warrant. Contrary to the government’s assertion, no discovery had
3
been reviewed by the defendant by this date. The motion was prepared by counsel for Artur
4
Ayvazyan, and Mr. Minassian merely joined the motion. Indeed, Mr. Minassian did not file a
5

6 single motion excepting a stipulation to continue. (Exhibit B)

7 March 29, 2021. The government files an Ex Parte motion seeking to prevent the
8
defendants from accessing discovery. The Court set the hearing for April 2, 2021.
9
April 1, 2021. The defendant texts Mr. Minassian regarding the next day’s hearing on
10
the government’s discovery motion: “I have to say tomorrow that I never saw the discovery.
11

12 And I don’t have access just FYI. So I couldn’t have possibly used anything from there.”

13 (Exhibit C, p. 8)
14
April 2, 2021. The Court denies the government’s request for a stricter protective order.
15
April 28-30, 2021. Mr. Minassian contacts the government to request a “reverse proffer”
16
where the government would show the defendant and Mr. Minassian what evidence they have
17

18 against Ms. Dadyan. Defendant is informed and believes that this meeting was called off after

19 Mr. Minassian joined a motion to dismiss the case for prosecutorial misconduct, pursuant to
20
government policy. No plea negotiations are held. (Kastigar Hearing, Day 2, 87:10-22).
21
May 21, 2021. The court denies permission for the defendant to join the Kastigar
22
motion.
23

24 May 22, 2021. Mr. Minassian texts Ms. Dadyan stating “Call me please important.”

25 (Exhibit C, p. 21). They plan to meet on May 26, presumably to discuss the way forward after
26
the denial of the Kastigar motion. Mr. Minassian told Ms. Dadyan that he had spent the
27
$30,000 on a “contact” that would remove the 1028A charge. Despite the fact that trial was
28

4
DEFENDANT TAMARA DADYAN REPLY TO GOVERNMENT’S RESPONSE TO HER MOTION TO
WITHDRAW HER GUILTY PLEA
Case 2:20-cr-00579-SVW Document 1110 Filed 11/03/21 Page 5 of 13 Page ID #:18046

1 scheduled 3 weeks away, Mr. Minassian still did not talk about a plan for trial or show the
2
defendant any discovery.
3
June 1-2, 2021. Mr. Minassian expresses by text that he is concerned about trial and
4
wants to withdraw from the newest suppression motions so he can negotiate with the
5

6 government for a plea. (Exhibit C, p. 24-25). Ms. Dadyan states that she doesn’t understand

7 why they are accusing her of “150 loans”: “I only got loans on my business I don’t sell their
8
houses or did their loans none of this shit.” (Exhibit C, p. 27).
9
June 7, 2021. Mr. Minassian texts to Ms. Dadyan “Tammy jan good morning. Time is
10
running out. We need to approach the government again.” (Exhibit C, p.23).
11

12 June 8, 2021. Ms. Dadyan requests that Mr. Minassian begins working on a Motion to

13 Continue. She states “Fred sorry but only ask for continuance because we’re not ready we
14
were in jail that’s it I haven’t seen discovery or interviewed any witnesses. Do not mention
15
severance. He won’t grant per Jerry.” Mr. Minassian replies: “I agree.” 2 (Exhibit C, p.33-34).
16
Thursday, June 10, 2021. Mr. Minassian contacts the government and requests a phone
17

18 call to discuss a possible plea. Trial is set to begin on Monday, June 14. This is the first

19 request for plea negotiations since the start of the case.
20
Also on June 10, 2021, Mr. Minassian asks Ms. Dadyan to give him a spreadsheet
21
showing which loans she was a part of. She emails him the spread sheet. (Exhibit D). She
22
advises him that she wasn’t involved in all the loans they thinks she was and the following text
23

24 exchanges follows:

25 FM: “Tammy on the text messages you are admitting to more than 3 loans.”
26

28 2
Notably, Mr. Minassian does not deny that she hasn’t seen any discovery and that no witnesses
have been interviewed.
5
DEFENDANT TAMARA DADYAN REPLY TO GOVERNMENT’S RESPONSE TO HER MOTION TO
WITHDRAW HER GUILTY PLEA
Case 2:20-cr-00579-SVW Document 1110 Filed 11/03/21 Page 6 of 13 Page ID #:18047

1 TD: “That doesn’t mean it’s there on it and I never ever ever ever received nothing. I
2
don’t know the companies that are on the indictment. I will mark every one I know about. But
3
like what tutu [do you] want me to do sag [sp?] it belongs to rich?”
4
FM: “Please I need a complete list by 9pm tonight. We need to say that. Email me the
5

6 indictment.”

7 TD: “Yah I’ll say I know this company but have nothing to do with it if I know it.”
8
FM: “Yes.”
9
TD: “But that’s bsbe [BS] which ever I know I’ll say
10
FM: “Ok.”
11

12 (Exhibit C, p.35-36).

13 Later the discussion continues with Mr. Minassian stating that the loss amount can’t be
14
reduced “even if Rich got all the $”. Ms. Dadyan states:
15
TM: “Listen I didn’t get 1.5 million or 3. What are yurt[you] saying. Manuk took a
16
plea for 3 million because he did get that plus more”
17

18 FM: It’s from my contact 3

19 TM: “Clearly u know I didn’t get that much.”
20
(Exhibit C, p. 37).
21
She tells Mr. Minassian that she never got any of the money, that she didn’t do the
22
loans or she would’ve gotten a commission, and that she only knows about Vahe’s loan, Tom’s
23

24 loan, Art’s loan, and her loan. “I don’t know the arman guy Edward…93k Art send and 200 or

25 202 I send to Richard. And art told him about Tom gave him $73,500 from his loan for the
26

28 3
Mr. Minassian repeatedly told Ms. Dadyan he had a “contact” with the United States’
Attorneys office that would get her a better deal if she paid him extra money.
6
DEFENDANT TAMARA DADYAN REPLY TO GOVERNMENT’S RESPONSE TO HER MOTION TO
WITHDRAW HER GUILTY PLEA
Case 2:20-cr-00579-SVW Document 1110 Filed 11/03/21 Page 7 of 13 Page ID #:18048

1 joint venture…but he died….I don’t want to be a punk but it was Rich’s shit in my house also
2
so not fair me and art have to fucked because we don’t have loads of cash….let’s not forget we
3
owed him [Richard] money so we had to pay him so the amounts we got we send to him.
4
Directly me 200 art 93. So wtf. Plus we didn’t conspire with them since no I had my loans
5

6 early and only send to him when he said his buying a house needs his money.” (Exhibit C,

7 p.38-40).
8
On Saturday, June 12, 2021, Ms. Dadyan denies being involved in 21 million of loans
9
and Mr. Minassian tries to reassure her “we still going to negotiate a better deal.” (Exhibit C, p.
10
43). He also tells her that she will be treated differently than Richard. (Exhibit C, p. 44).
11

12 TM: “This is seriously insane.”

13 FM: “But we can argue down.”
14
(Exhibit C, p. 45).
15
TM: “Why can’t I do a open plea?”
16
FM: “Because you would get killed!...Wilson will kill you please listen to me I have
17

18 your best interest.”

19 (Exhibit C, p. 48).
20
Ms. Dadyan again asks about an open plea for her and her husband and again is
21
rebuffed:
22
TM: “Why can’t I do a open plea. I will take responsibility for my own actions and
23

24 loans. There is absolutely no way I’m going to agree to their bullshit that him Manuk and

25 Hayrapetyan did no way.”
26
FM: “Tammy Jan. Because they will still go to trial on the other counts including
27
count 33…To plead open means you have to enter a guilty plea to all counts wow on [Wilson]
28

7
DEFENDANT TAMARA DADYAN REPLY TO GOVERNMENT’S RESPONSE TO HER MOTION TO
WITHDRAW HER GUILTY PLEA
Case 2:20-cr-00579-SVW Document 1110 Filed 11/03/21 Page 8 of 13 Page ID #:18049

1 will not accept any other way. Then we are going to trial on Tuesday and you are risking 20
2
plus years….Please understand this will give us a chance to argue that you accepted
3
responsibility...Pleading open means you have to say guilty to every single count!!!”
4
(Exhibit C., p. 49-51)
5

6 Sunday, June 13, 2021:

7 FM: “Tammy jan you go to trial you will lose your life. This way we have a chance
8
for a lower sentence.”
9
TM: “They need to understand that and I didn’t do the loans.”
10
FM: “We will argue that.”
11

12 (Exhibit C, p. 54).

13 TM: “I never have any association with any of this fucking properties they want me
14
to take this fucking hit of 12 Million?”
15
(Exhibit C, p. 59).
16
TM: “We don’t have to take the plea deal.”
17

18 FM: “Tammy jan I don’t know. You guys can’t plead open! The 4 of you are

19 looked at differently.” (Exhibit C, p. 60-61).
20
On Monday, June 14, 2021, at 9:55a.m., 35 minutes before the deadline, the following
21
exchange took place:
22
TM: “I’m being forced to sign something I didn’t do I’ll pay all the loans I have done
23

24 nothing to do with their 9 to 20 million period.”

25 FM: “Tammy jan. We need to go over the factual basis. If Wilson says no then we
26
are going to trial…We can’t allow this deal to fall apart.” (Exhibit C, p. 65).
27
Ms. Dadyan signed the agreement and entered the plea a few hours later.
28

8
DEFENDANT TAMARA DADYAN REPLY TO GOVERNMENT’S RESPONSE TO HER MOTION TO
WITHDRAW HER GUILTY PLEA
Case 2:20-cr-00579-SVW Document 1110 Filed 11/03/21 Page 9 of 13 Page ID #:18050

1 II.
2
THE CONDUCT OF DEFENDANT’S COUNSEL FELL BELOW THE STANDARD OF
3
CARE REQUIRED OF THE SIXTH AMENDMENT AND SHE SHOULD BE
4
PERMITTED TO WITHDRAW HER PLEA 4
5

6 But for her counsel’s failure to review the discovery with her and prepare for trial, to

7 negotiate with the government in a timely manner, and his insistence that she enter a plea they
8
both knew required her to admit facts that were untrue, the defendant would have not entered
9
the plea and instead pleaded open only to those counts of which she was guilty and went to
10
trial on the rest of counts. She would have admitted her conduct in her own loan and that of
11

12 her husband and cousin, and would have denied participating in the loans of her brother-in-law,

13 the mastermind of the conspiracy, and shown that the money she sent to him was money she
14
owed him that he requested be paid for his property purchase. Because her counsel’s conduct
15
fell below the reasonable standard of care, she was denied her constitution right to counsel and
16
to trial. Wherefore her Motion to Withdraw her plea should be granted.
17

18 A. COUNSEL FAILED TO REVIEW DISCOVERY OR CONDUCT

19 INVESTIGATION
20
Although Mr. Minassian claims he thoroughly reviewed the discovery and spent 30
21
hours per week on this case, this is clearly a lie. In addition to admitting such directly to his
22
client, he accessed the discovery database only two times for two documents, out of over
23

24 200,000 documents. In addition, when his client noted that they needed a continuance because

26
4
In defendant’s Motion, Mr. Minassian is accused of misadvising Ms. Dadyan on the guideline
27 range of her plea, stating that it was for a level 23 and 46-57 months plus 2 years, or 5.5 years, in prison. While
this text exchange did occur, upon a subsequent reading of the text exchange, defense counsel realized that Mr.
28 Minassian was discussing his counter offer to the government, and not the actual plea agreement. Counsel
apologies and withdraws this particular accusation.
9
DEFENDANT TAMARA DADYAN REPLY TO GOVERNMENT’S RESPONSE TO HER MOTION TO
WITHDRAW HER GUILTY PLEA
Case 2:20-cr-00579-SVW Document 1110 Filed 11/03/21 Page 10 of 13 Page ID #:18051

1 she hadn’t seen any discovery and they hadn’t interviewed a single witness, Mr. Minassian
2
stated “I agree.”
3
The government argues in its opposition that Mr. Minassian could not have filed a
4
Motion to Suppress without having reviewed the discovery. This is simply false. First, a
5

6 Motion to Suppress does not require a review of the evidence uncovered by the search. The

7 very nature of a Motion to Suppress renders the actual uncovered evidence irrelevant to the
8
motion. The question is whether, prior to seizing the evidence, a valid warrant or warrant
9
exception permitted the search and seizure in the first place.
10
Secondly, and more to the point, Mr. Minassian did not draft the Motion. It was written
11

12 by counsel for her husband and emailed to Mr. Minassian, which he promptly emailed to his

13 client. In fact, Mr. Minassian did not author a single motion or filing excepting only a joinder
14
to another defendant’s motion or stipulation to continue. He admittedly permitted the attorney
15
for Richard Ayvazyan to lead the case and prepare and file all the motions.
16
The closest Mr. Minassian came to reviewing discovery was when he requested a
17

18 reverse proffer so the government could present the relevant discovery directly to his client.

19 However, this proffer never happened and so Ms. Dadyan never reviewed any discovery with
20
her attorney. In short, Mr. Minassian was wholly unprepared for trial and within 2 hours of the
21
continuance being denied, he contacted the government and tried to quickly get a plea to avoid
22
trial. Mr. Minassian even failed to mention or discuss with the defendant the potential impact
23

24 her plea would have on her husband’s case, which the Court specifically noted in the plea

25 colloquy to Ms. Dadyan.
26

10
DEFENDANT TAMARA DADYAN REPLY TO GOVERNMENT’S RESPONSE TO HER MOTION TO
WITHDRAW HER GUILTY PLEA
Case 2:20-cr-00579-SVW Document 1110 Filed 11/03/21 Page 11 of 13 Page ID #:18052

1 B. COUNSEL PRESSUED DEFENDANT TO ADMIT AN INCORRECT
2
FACTUAL BASIS
3
The government, and likely Mr. Minassian, argue that Ms. Dadyan was guilty of at
4
least some crimes, and in fact she is better off with the benefit of the plea rather than going to
5

6 trial on the counts of which she claims innocence. The Constitution, however, does not treat a

7 guilty plea to a crime that involves incarceration so lightly. The question is not whether she is
8
better off with the plea, the question is whether the guilty plea is true. It contains false
9
statements of facts, and because she was so unduly pressured to sign it, it rendered the plea
10
involuntary. It is irrelevant for this motion whether she will ultimately face a longer prison
11

12 sentence if she is permitted her constitutionally guaranteed jury trial. What is relevant is that

13 any plea entered before a court of the United States be true, voluntary, and just. This plea
14
agreement is none of those. Unless the government is willing to stipulate that the plea
15
agreement’s factual basis and loss calculation are incorrect, it is disingenuous to claim that
16
there is no harm to such false statements remaining in the record.
17

18 The loss amount and the factual basis are both false statements of the facts of this case.

19 The truth is that Ms. Dadyan did not participate in anywhere near 151 loans, and she did not
20
participate in a conspiracy involving 21 million dollars. She denies that the factual basis and
21
the loss calculation in the plea agreement are truthful and she has a defense to the crimes to
22
which she does not admit. She very clearly and explicitly told her attorney this, and he very
23

24 clearly and explicitly told her to plea to it anyway. In the below exchange, after Mr. Minassian

25 tells her that she needs to admit to more than three loans, even though she denies taking part in
26
them, Ms. Dadyan tells him that she’ll say the B.S. he’s telling her to say, and Mr. Minassian
27
clearly approves:
28

11
DEFENDANT TAMARA DADYAN REPLY TO GOVERNMENT’S RESPONSE TO HER MOTION TO
WITHDRAW HER GUILTY PLEA
Case 2:20-cr-00579-SVW Document 1110 Filed 11/03/21 Page 12 of 13 Page ID #:18053

1 TD: “Yah I’ll say I know this company but have nothing to do with it if I know it.”
2
FM: “Yes.”
3
TD: “But that’s bsbe [BS] which ever I know I’ll say
4
FM: “Ok.”
5

6 (Exhibit C, p.35-36).

7 The defendant denies that the loss amount in the plea agreement, calculated from all
8
151 loans, was a reasonably foreseeable loss based on her conduct. The government’s opinion
9
notwithstanding, she has a defense to this and very clearly let her attorney know that she
10
wasn’t involved in that amount and didn’t believe she was legally responsible for it. Indeed,
11

12 she pleaded with Mr. Minassian to let her do the only honorable thing: plead open to the counts

13 of which she was guilty and go to trial on the rest, rather than admit to a lie in court:
14
“Why can’t I do a open plea. I will take responsibility for my own actions and loans.
15
There is absolutely no way I’m going to agree to their bullshit that him Manuk and
16
Hayrapetyan did no way.”
17

18 Mr. Minassian, however, not only insisted that she take the deal, but also misadvised

19 her regarding open plea, telling her that the only way to do it was to plead to everything.
20
Whether this was a misunderstanding of the law or another desperate attempt to avoid having
21
to conduct a trial for which he was not prepared is something only Mr. Minassian knows.
22

24 C. DEFENDANT TIMELY NOTIFIED, HAD A DEFENSE, ASSERTED HER

25 INNOCENCE EARLY ON, AND SUFFERED STRICKLAND ERROR
26
The Defendant has met the criteria for withdrawing her plea. She asserted her
27
innocence to some of the charges early on to her attorney – well before the plea agreement was
28

12
DEFENDANT TAMARA DADYAN REPLY TO GOVERNMENT’S RESPONSE TO HER MOTION TO
WITHDRAW HER GUILTY PLEA
Case 2:20-cr-00579-SVW Document 1110 Filed 11/03/21 Page 13 of 13 Page ID #:18054

1 entered into. She has a non-frivolous defense to those crimes and that loss amount. She timely
2
acquired subsequent counsel who immediately notified the court of her intention to withdraw
3
the plea. And she very clearly suffered Strickland error when her counsel failed to prepare the
4
case and then pressured her to sign a plea agreement that he knew contained false statements of
5

6 fact. But for his dereliction, Ms. Dadyan would have exercised her right to trial. Wherefore

7 the defendant is entitled to have her plea withdrawn and to proceed to trial, and she respectfully
8
requests her motion be granted.
9

10
IV.
11

12 CONCLUSION

13 Based on the foregoing, the defendant respectfully requests a hearing on this motion
14
and that the Court grant her request to withdraw her plea.
15

16
Date: November 3, 2021 Respectfully submitted,
17

18 /s/ Jerry Kaplan
JERRY KAPLAN
19 Attorneys for Defendant
TAMARA DADYAN
20

13
DEFENDANT TAMARA DADYAN REPLY TO GOVERNMENT’S RESPONSE TO HER MOTION TO
WITHDRAW HER GUILTY PLEA

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