Declaration of Robert I. Lester — United States v. Tamara Dadyan (No. 2:20-cr-00579)

Summary

Declaration of Robert I. Lester, an Assistant United States Attorney, filed August 11, 2023 as Document 1402-1 in United States v. Tamara Dadyan, CR 20-0579-SVW-4. He states that on July 10, 2023 the United States moved for an order forfeiting bail for defendant Tamara Dadyan and for a default judgment against her and her three sureties, with a hearing set for August 14, 2023. He describes emails and a telephone call on August 9 and 10, 2023 from counsel for the sureties, including Jerry Kaplan, Esq., who asked that the hearing be continued 60 days to negotiate a resolution. He says he agreed to a continuance and to bring the request to the Court's attention.

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Full text

 Case 2:20-cr-00579-SVW Document 1402-1 Filed 08/11/23 Page 1 of 1 Page ID #:20961




1                       DECLARATION OF ROBERT I. LESTER
2          I, ROBERT I. LESTER, declare:
3    1.    I am an Assistant United States Attorney, assigned to represent the
4    government in United States v. Tamara Dadyan, CR 20-0579-SVW-4. As such,
5    I have personal knowledge of the following facts and, if called as a witness, I could
6    and would testify competently thereto.
7    2.    On July 10, 2023, the United States moved for an order forfeiting the bail
8    for defendant Tamara Dadyan and requested the entry of a default judgment
9    against Ms. Dadyan and her three sureties. The government scheduled the hearing
10   on the motion for August 14, 2023. Until August 9, 2023, I had not received
11   any kind of a response to the bail bond forfeiture motion.
12   3.    Then, on August 9, 2023, an attorney who stated that he was just hired
13   to represent the sureties with respect to the bail bond forfeiture motion emailed me,
14   stating that the sureties just realized that counsel for Ms. Dadyan would not be
15   responding to the bond forfeiture motion on their behalf, and therefore the sureties
16   were retaining counsel who needed additional time to respond to the government’s
17   motion. I responded that he would agree to a continuance.
18   4.    However, the next day, on August 10, 2023, I received a telephone call from
19   Jerry Kaplan, Esq., who stated that he was replacing the lawyer who had sent me
20   the August 9, 2023, email, and that the sureties were now requesting that the bond
21   forfeiture hearing be continued for 60 days so that they could negotiate a resolution
22   to the bond forfeiture motion with the government. I responded that I would agree
23   to a continuance. I also agreed, as a courtesy, to bring this request to the Court’s
24   attention on the new counsel’s behalf.
25         I declare under penalty of perjury that the foregoing is true and correct.
26         Executed on August 11, 2023, at Los Angeles, California.
27                                                 /s/ Robert I. Lester
28                                                 ROBERT I. LESTER

                                               1


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