Government’s First Amended Bill of Particulars re Forfeiture Allegations (No. 2:20-cr-00579)

Summary

Government's First Amended Bill of Particulars re Forfeiture Allegations, Document 407, filed June 3, 2021, in the U.S. District Court for the Central District of California, No. CR 20-00579(A)-SVW, against Richard Ayvazyan and others. The government gives notice that, under the forfeiture allegations in the First Superseding Indictment, it intends to seek criminal forfeiture of specific property. The list begins with $12,520.00 in U.S. Currency seized on November 5, 2020, and includes $74,557.79 in bank funds, $451,185.00 in U.S. Currency, watches, gold bullion coins, a cryptocurrency hardware wallet ledger, and real property described by its legal description. It is dated June 3, 2021, with the signature of an Assistant United States Attorney in the Asset Forfeiture Section.

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     Case 2:20-cr-00579-SVW Document 407 Filed 06/03/21 Page 1 of 9 Page ID #:4145



1    TRACY L. WILKISON
     Acting United States Attorney
2    SCOTT M. GARRINGER
     Assistant United States Attorney
3    Chief, Criminal Division
     SCOTT PAETTY (Cal. Bar No. 274719)
4    CATHERINE AHN (Cal. Bar No. 248286)
     BRIAN FAERSTEIN (Cal. Bar No. 274850)
5    Assistant United States Attorneys
6    Major Frauds/Environmental and Community Safety Crimes Sections
          1100/1300 United States Courthouse
7         312 North Spring Street
          Los Angeles, California 90012
8         Telephone: (213) 894-6527/2424/3819
          Facsimile: (213) 894-6269/0141
9         E-mail:    Scott.Paetty@usdoj.gov
                     Catherine.S.Ahn@usdoj.gov
10                   Brian.Faerstein@usdoj.gov
11   DANIEL S. KAHN
     Acting Chief, Fraud Section
12   Criminal Division, U.S. Department of Justice
     CHRISTOPHER FENTON
13   Trial Attorney, Fraud Section
     Criminal Division, U.S. Department of Justice
14        1400 New York Avenue NW, 3rd Floor
          Washington, DC 20530
15        Telephone: (202) 320-0539
16        Facsimile: (202) 514-0152
          E-mail:    Christopher.Fenton@usdoj.gov
17
     Attorneys for Plaintiff
18   UNITED STATES OF AMERICA

19                            UNITED STATES DISTRICT COURT

20                     FOR THE CENTRAL DISTRICT OF CALIFORNIA
21   UNITED STATES OF AMERICA,                No. CR 20-00579(A)-SVW
22              Plaintiff,                    GOVERNMENT’S FIRST AMENDED BILL OF
                                              PARTICULARS RE FORFEITURE
23                    v.                      ALLEGATIONS
24   RICHARD AYVAZYAN,
          Aka “Richard Ayazian” and
25   “Iuliia Zhadko,” et al.
26
                Defendants.
27
28
     Case 2:20-cr-00579-SVW Document 407 Filed 06/03/21 Page 2 of 9 Page ID #:4146



1          Notice is hereby given that the government, pursuant to the
2    forfeiture allegations set out in the First Superseding Indictment,
3    intends to seek the criminal forfeiture of the following specific
4    property:
5          a.    $12,520.00 in U.S. Currency seized during the execution of
6    a federal search warrant on November 5, 2020, in Encino, California,
7    at the residence of defendants Tamara Dadyan (“Dadyan”) and Artur
8    Ayvazyan (“A. Ayvazyan”);
9          b.    $74,557.79 in Bank funds seized pursuant to a federal
10
     seizure warrant executed on November 20, 2020, from Bank of America
11
     account number ending in 7695 held in the name of Allstate Towing &
12
     Transport LLC;
13
           c.    $451,185.00 in U.S. Currency seized on November 5, 2020,
14
     during the execution of a federal search warrant in various areas and
15
     back yard of a Tarzana, California residence (APN: 2176-029-031);
16
           d.    Miscellaneous jewelry and precious items seized on November
17
     5, 2020, during the execution of a federal search warrant at a
18
     Tarzana, California residence (APN: 2176-029-031), consisting of:
19
20                I.   One Audermars Piguet, Royal Oak 18 carat rose gold

21                     wrist watch, model 26331, serial number J52335;

22               II.   One Rolex Datajust stainless steel wrist watch, model

23                     126334, serial number 4U95Z313;

24              III.   One Cartier Chronoscaph 21 stainless steel wrist
25                     watch, model 2424, serial number 880317LX;
26               IV.   One Audemars Piguet, Royal Oak Offshore black ceramic
27                     wrist watch, serial number K23313;
28



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     Case 2:20-cr-00579-SVW Document 407 Filed 06/03/21 Page 3 of 9 Page ID #:4147



1                  V.   One Audemars Piguet Royal Oak Offshore black ceramic
2                       wrist watch, serial number LU44845K;
3                 VI.   Audemars Piguet Royal Oak stainless steel wrist watch,
4                       serial number LW3397N;
5                VII.   One 1979 Gold Bullion Coin;
6
                VIII.   Two 1980 Gold Bullion Coins;
7
                  IX.   Ten 1982 Gold Bullion Coins;
8
                   X.   Seventeen 1983 Gold Bullion Coins;
9
                  XI.   Five 1984 Gold Bullion Coins;
10
                 XII.   Five 1985 Gold Bullion Coins;
11
                XIII.   Ten 1986 Gold Bullion Coins;
12
                 XIV.   Ten 1987 Gold Bullion Coins;
13
                  XV.   One 14 carat rose tint gold pendant, cross-shaped; and
14
           e.     Miscellaneous jewelry and precious items seized on October
15
16   20, 2020, from R. Ayvazyan and Terabelian at Miami International

17   Airport, consisting of:

18                 I.   One Rolex Yacht-Master II watch, model 116681, serial

19                      number C32K8231;

20                II.   One Rolex Day-Date 40 watch, model W6685656;
21               III.   One Rolex Day-Date watch, serial number W44P7238;
22                IV.   One Pair of 14 carat white gold earrings with diamond
23                      studs;
24                 V.   One pair of 18 carat white gold earrings with
25                      diamonds;
26
                  VI.   One 14 carat white gold bracelet with 2 rows of
27
                        diamonds;
28
                 VII.   One 14 carat yellow gold 24” neck chain;



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     Case 2:20-cr-00579-SVW Document 407 Filed 06/03/21 Page 4 of 9 Page ID #:4148



1               VIII.   One 14 carat yellow gold cross pendant;
2                 IX.   One 14 carat yellow gold 16” neck chain;
3                  X.   One 18 carat white gold bracelet double chain link
4                       “Evil Eye” with diamonds; and
5                 XI.   One fabric cord bracelet with 18 carat white gold
6
                        clasp and diamond “Evil Eye”;
7
           f.     $3,422.00.00 in U.S. Currency seized on November 20, 2020,
8
     from R. Ayvazyan and Terabelian at the Miami International Airport;
9
           g.     Ledger re Nanos Cryptocurrency Hardware Wallet seized on
10
     November 5, 2020, during the execution of a federal search warrant at
11
     a Tarzana, California residence (APN:2176-029-031); and
12
           h.     $65,990.43 in Bank funds seized pursuant to a federal
13
     seizure warrant executed on December 2, 2020, from Bank of America
14
     account ending in ‘9700 in the name of Runyan Tax Service Inc.
15
16         i.     Real Property located in Tarzana, California more

17   particularly described as follows:

18                DESCRIPTION: THE LAND REFERRED TO HEREIN IS SITUATED IN THE

19         COUNTY OF LOS ANGELES, STATE OF CALIFORNIA, AND IS DESCRIBED AS

20         FOLLOWS:
21                PARCEL 1:
22                THOSE PORTIONS OF LOT 71 and 72 OF TRACT 2605, IN THE CITY
23         OF LOS ANGELES, COUNTY OF LOS ANGELES, STATE OF CALIFORNIA, AS
24         PER MAP RECORDED IN BOOK 27 PAGE 55 ET SEQ. OF MAPS, AND THAT
25         PORTION OF PARCEL "A” OF PARCEL MAP L.A. NO. 2015 AS PER MAP
26
           FILED IN BOOK 32 PAGE 19 OF PARCEL MAPS, IN THE OFFICE OF THE
27
           COUNTY RECORDER OF SAID COUNTY, DESCRIBED AS FOLLOWS:
28



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     Case 2:20-cr-00579-SVW Document 407 Filed 06/03/21 Page 5 of 9 Page ID #:4149



1                  BEGINNING AT A POINT IN THE CENTERLINE OF TOPEKA DRIVE, 40
2          FEET WIDE, AS SHOWN ON SAID MAP, DISTANT THEREON SOUTH 15° 10'
3          00" WEST 178.55 FEET FROM THE NORTHEASTERLY TERMINUS OF THAT
4          CERTAIN COURSE IN THE CENTERLINE OF TOPEKA DRIVE SHOWN ON SAID
5          MAP AS HAVING A BEARING OF NORTH 15° 10' 00" EAST AND LENGTH OP
6
           1055.19 FEET;
7
                   THENCE SOUTH 74° 50' 00" EAST 56.09 FEET TO THE BEGINNING
8
           OF A TANGENT CURVE, CONCAVE TO THE NORTHWEST, HAVING A RADIUS OF
9
           129.86 FEET;
10
                   THENCE EASTERLY ALONG SAID CURVE 128.40 FEET; TO THE TRUE
11
           POINT OF BEGINNING;
12
                   THENCE TANGENT TO SAID CURVE NORTH 48° 30' 50" EAST 147.14
13
           FEET TO THE BEGINNING OF A TANGENT CURVE, CONCAVE TO THE
14
           SOUTHEAST, HAVING A RADIUS OF 100.05 FEET;
15
16                 THENCE EASTERLY ALONG SAID CURVE, 125.14 FEET, A RADIAL

17         LINE TO SAID POINT BEARS NORTH 30° 10' 46" EAST;

18                 THENCE NORTH 10° 52' 46" EAST 45.32 FEET;

19                 THENCE SOUTH 84° 29' 18" EAST 182.82 FEET;

20                 THENCE SOUTH 04° 13' 10" WEST 195.63 FEET TO A POINT IN A
21         CURVE CONCAVE WESTERLY HAVING A RADIUS OF 175.31 FEET; A RADIAL
22         LINE TO SAID POINT BEARS NORTH 62° 22' 50” EAST;
23                 THENCE CONTINUING EASTERLY AND SOUTHERLY ALONG SAID CURVE
24         THROUGH A CENTRAL ANGLE OF 50° 06' 30" AN ARC DISTANCE OF 153.32
25         FEET;
26
                   THENCE TANGENT TO SAID CURVE SOUTH 22° 29' 20" WEST 63.38
27
           FEET TO THE BEGINNING OF A TANGENT CURVE CONCAVE TO THE
28
           NORTHWEST HAVING A RADIUS OF 375.00 FEET;



                                             5
     Case 2:20-cr-00579-SVW Document 407 Filed 06/03/21 Page 6 of 9 Page ID #:4150



1                THENCE SOUTHWESTERLY ALONG SAID CURVE, THROUGH A CENTRAL
2          ANGLE OF 13° 52' 00" 90.76 FEET TO THE BEGINNING OF A REVERSE
3          CURVE CONCAVE TO THE SOUTHEAST HAVING A RADIUS OF 161.89 FEET;
4                THENCE SOUTHEASTERLY ALONG SAID CURVE, THROUGH A CENTRAL
5          ANGLE OF 17° 46' 00" 50.20 FEET TO THE BEGINNING OF A REVERSE
6
           CURVE CONCAVE TO THE NORTHWEST HAVING A RADIUS OF 75.69 FEET;
7
                 THENCE SOUTHWESTERLY AND WESTERLY ALONG SAID CURVE, THROUGH
8
           A CENTRAL ANGLE OF 33° 58' 30" 44.88 FEET TO A POINT OF CUSP IN
9
           THE NORTHERLY LINE OF SAID PARCEL "A" SAID NORTHERLY LINE BEING
10
           A CURVE CONCAVE SOUTHWESTERLY HAVING A RADIUS OF 30.00'; A
11
           RADIAL LINE TO SAID POINT BEARS SOUTH 38° 26' 10" EAST;
12
                 THENCE EASTERLY ALONG SAID CURVE THROUGH A CENTRAL ANGLE
13
           116° 31' 20" AN ARC DISTANCE OF 61.01 FEET;
14
                 THENCE SOUTH 10° 54' 50" EAST 92.71 FEET;
15
16               THENCE SOUTH 80° 16' 17" WEST 20.00 FEET;

17               THENCE NORTH 31° 28' 33" WEST 120.33 FEET;

18               THENCE NORTH 22° 17' 48" WEST 20.00 FEET TO THE BEGINNING

19         OF A CURVE CONCAVE NORTHWESTERLY HAVING A RADIUS OF 55.69 FEET;

20               THENCE NORTHEASTERLY ALONG SAID CURVE THROUGH A CENTRAL
21         ANGLE OF 49° 06' 52" AN ARC DISTANCE OF 47.74 FEET TO THE
22         BEGINNING OF A REVERSE CURVE CONCAVE SOUTHEASTERLY HAVING A
23         RADIUS OF 181.89 FEET;
24               THENCE NORTHEASTERLY ALONG SAID CURVE THROUGH A CENTRAL
25         ANGLE OF 17° 46' 00" AN ARC DISTANCE OF 56.40 FEET TO THE
26
           BEGINNING OF A REVERSE CURVE CONCAVE NORTHWESTERLY HAVING A
27
           RADIUS OF 355.00 FEET;
28



                                             6
     Case 2:20-cr-00579-SVW Document 407 Filed 06/03/21 Page 7 of 9 Page ID #:4151



1                THENCE NORTHEASTERLY ALONG SAID CURVE THROUGH A CENTRAL
2          ANGLE OF 12° 45' 16" AN ARC DISTANCE OF 79.03 FEET;
3                THENCE NORTH 67° 12' 02" WEST 268.30 FEET;
4                THENCE NORTH 15° 10' 00" EAST 43.00 FEET;
5                THENCE NORTH 47° 02' 30" WEST 175.00 FEET TO THE TRUE POINT
6
           OF BEGINNING.
7
                 PARCEL 2:
8
                 THE RIGHT OF INGRESS AND EGRESS FOR SAID PROPERTY OVER A
9
           ROADWAY EASEMENT FROM TOPEKA DRIVE OVER THAT PORTION OF LOT 71,
10
           OF TRACT NO. 2605, IN THE CITY OF LOS ANGELES, COUNTY OF LOS
11
           ANGELES, STATE OF CALIFORNIA, AS PER MAP RECORDED IN BOOK 27,
12
           PAGE 55, ET SEQ., OF MAPS, IN THE OFFICE OF THE COUNTY RECORDER
13
           OF SAID COUNTY, INCLUDED WITHIN A STRIP OF LAND 30.00 FEET IN
14
           WITH, LYING 15.00 FEET ON EACH SIDE OF THE FOLLOWING DESCRIBED
15
16         CENTER LINE:

17               BEGINNING AT THE SOUTHWESTERLY CORNER OF THE LAND CONVEYED

18         TO CIRELLA G. SMITH AND HUSBAND, BY DEED RECORDED JULY 8, 1943

19         AS INSTRUMENT NO. 118, IN BOOK 20132 PAGE 100, OFFICIAL RECORDS,

20         SAID CORNER BEING DISTANT 261.45 FEET NORTHERLY FROM THE
21         SOUTHWESTERLY CORNER OF LOT 71, SAID TRACT 2605; THENCE NORMAL
22         TO THE EASTERLY LINE OF TOPEKA DRIVE, SOUTH 74° 50' 00” EAST
23         36.09 FEET TO THE BEGINNING OF A TANGENT CURVE CONCAVE TO THE
24         NORTHWEST HAVING A RADIUS OF 129.86 FEET; THENCE NORTHEASTERLY
25         ALONG SAID CURVE, 128.40 FEET; THENCE TANGENT TO SAID CURVE,
26
           NORTH 48° 30' 50" EAST 147.14 FEET TO THE BEGINNING OF A TANGENT
27
           CURVE CONCAVE SOUTHERLY, HAVING A RADIUS OF 100.05 FEET; THENCE
28
           EASTERLY ALONG SAID CURVE, 144.70 FEET; THENCE TANGENT TO SAID



                                             7
     Case 2:20-cr-00579-SVW Document 407 Filed 06/03/21 Page 8 of 9 Page ID #:4152



1          CURVE, SOUTH 48° 37' 10" EAST, 161.06 FEET TO THE BEGINNING OF A
2          TANGENT CURVE CONCAVE WESTERLY, HAVING A RADIUS OF 175.31 FEET,
3          THENCE SOUTHERLY ALONG SAID CURVE, 217.57 FEET; THENCE TANGENT
4          TO SAID CURVE, SOUTH 22° 29' 20" WEST 42.15 FEET TO A POINT.
5          APN: 2176-029-031
6
           j.    Real Property located in Glendale, California more
7
     particularly described as follows:
8
                 Parcel 1:
9
                 Lot 56 of Tract No. 45375, in the City of Glendale, County
10
           of Los Angeles, State of California, as per map recorded in Book
11
           1128, Page(s) 55 to 63 inclusive of Maps, in the office of the
12
           County Recorder of said County.
13
                 Except therefrom all oil and minerals in, on and under said
14
           land as reserved by Benjamin Dreyfus in deeds recorded in Book
15
16         101, Pages 551 and in Book 107, Page 447 both of Deeds, in said

17         Office of the County Recorder.

18               Parcel 2:

19               Non-exclusive easements for access, ingress, egress,

20         encroachments, maintenance, repair, drainage, support and other
21         purposes, all as described in the Master Declaration recorded
22         March 7, 1989 as Instrument No. 1989-354873 and any amendments
23         thereto.
24         APN: 5663-036-033
25         k.    Real Property located in Palm Desert, California more
26
     particularly described as follows:
27
                 Described real property in the County of Riverside, State
28
           of California:



                                             8
     Case 2:20-cr-00579-SVW Document 407 Filed 06/03/21 Page 9 of 9 Page ID #:4153



1                PARCEL 1:
2                LOT 8 OF TRACT NO. 36554-1 IN THE CITY OF PALM DESERT,
3          COUNTY OF RIVERSIDE, STATE OF CALIFORNIA AS PER MAP RECORDED IN
4          THE BOOK 438 PAGES 98 AND 99, INCLUSIVE, OF MAPS, IN THE OFFICE
5          OF THE COUNTY RECORDER OF CALIFORNIA.
6
                 PARCEL 2:
7
                 NON-EXCLUSIVE EASEMENTS APPURTENANT TO PARCEL 1 ABOVE, ON
8
           AND OVER THE “COMMON AREA” AS DEFINED IN THE DECLARATION OF
9
           COVENANTS, CONDITIONS, RESTRICTIONS AND RESERVATION OF EASEMENTS
10
           FOR ENCORE PALM DESERT (“DECLARATION”) RECORDED IN THE OFFICE OF
11
           SAID COUNTY RECORDER OF CALIFORNIA ON DECEMER 23, 2013 AS
12
           INSTRUMENT NO. 2013-0591271, FOR ACCESS, USE, OCCUPANCY,
13
           ENJOYMENT, INGRESS AND EGRESS OF THE AMENITIES LOCATED THEREON.
14
           THE COMMON AREA IS FOR THE USE OF OWNERS OF LOTS WHICH ARE
15
16         SUBJECT TO THE DECLARATION AND IS NOT FOR THE USE OF THE GENERAL

17         PUBLIC.

18         APN: 694-331-008.

19    Dated: June 3, 2021                  Respectfully submitted,

20                                         TRACY L. WILKISON
                                           Acting United States Attorney
21
                                           SCOTT M. GARRINGER
22                                         Assistant United States Attorney
                                           Chief, Criminal Division
23
24                                               /s/
                                           DAN G. BOYLE
25                                         Assistant United States Attorney
26                                         Asset Forfeiture Section

27                                         Attorney for Plaintiff
                                           UNITED STATES OF AMERICA
28



                                             9


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