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Defendant's Supplement to Her Sentencing Memorandum — United States v. Tamara Dadyan (Document 1175)

Summary

Defendant's Supplement to Her Sentencing Memorandum, filed November 30, 2021 as Document 1175 by counsel for Tamara Dadyan in No. 2:20-CR-00579-SVW-4. It says defense counsel erroneously concluded, from information in the presentence investigation report, that her husband and co-defendant Artur Ayvazyan was likely to be deported. The supplement states that he is a United States citizen and is not in danger of deportation, and withdraws any assertion that he will be or is in danger of deportation. It also submits additional letters of support, attached to the supplement.

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“Defendant's Supplement to Her Sentencing Memorandum — United States v. Tamara Dadyan (Document 1175).” Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/court-filing-c-d-cal-no-2-20-cr-00579-dkt-1175-c-d-cal-de37bcb9bf/, SHA-256 c001875ac68a5bec2cf78eff028edf83c966a1f92c03bb72c69de16fa93c46ec.

Full text

     Case 2:20-cr-00579-SVW Document 1175 Filed 11/30/21 Page 1 of 2 Page ID #:18895



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
      Attorneys for Defendant
7     TAMARA DADYAN
8
                                  UNITED STATES DISTRICT COURT
9

10                              CENTRAL DISTRICT OF CALIFORNIA

11

12     THE UNITED STATES OF AMERICA                 CASE NO.       2:20-CR-00579-SVW-4
13
              Plaintiff,                            DEFENDANT'S SUPPLEMENT TO HER
14                                                  SENTENCING MEMORANDUM
15     vs.

16     TAMARA DADYAN,
17
              Defendant.
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20           Defendant Tamara Dadyan respectfully submits this Supplement to her Sentencing
21
      Memorandum as follows:
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             1.      Defense counsel erroneously concluded that defendant’s husband, co-defendant
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24    Artur Ayvazyan, was likely to be deported, based on information contained in the presentence

25    investigation report. This was an error. Artur Ayvazyan is a United States citizen and is not in
26    danger of deportation. Defendant respectfully withdraws any assertion that her husband will be
27
      or is in danger of being deported.
28
             2.      Defendant submits additional letters of support, attached to this Supplement.

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                     DEFENDANT'S SUPPLEMENT TO HER SENTENCING MEMORANDUM
     Case 2:20-cr-00579-SVW Document 1175 Filed 11/30/21 Page 2 of 2 Page ID #:18896



1     Date: November 30, 2021                  Respectfully submitted,
2
                                                 /s/ Jerry Kaplan
3                                              JERRY KAPLAN
                                               Attorneys for Defendant
4                                              TAMARA DADYAN
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                  DEFENDANT'S SUPPLEMENT TO HER SENTENCING MEMORANDUM

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