Plea Agreement for Defendant Tamara Dadyan (Document 525)
Summary
Plea Agreement for Defendant Tamara Dadyan, filed June 14, 2021 as Document 525 in No. CR 20-579(A)-SVW-4, between her and the United States Attorney's Office and the Fraud Section, referred to as the Offices. She agrees to plead guilty to counts 1, 24, and 26 of the first superseding indictment, charging conspiracy to commit wire fraud and bank fraud, aggravated identity theft and conspiracy to commit money laundering. She agrees to forfeit $12,520.00 in U.S. Currency, $3,032.23 and $189,430.85 in bank funds, and residential properties. The Offices agree to move to dismiss the remaining counts and to recommend a two-level reduction for acceptance of responsibility.
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“Plea Agreement for Defendant Tamara Dadyan (Document 525).”
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Case 2:20-cr-00579-SVW Document 525 Filed 06/14/21 Page 1 of 31 Page ID #:6300
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 S. AHN (Cal. Bar No. 248286)
BRIAN FAERSTEIN (Cal. Bar No. 274850)
5 Assistant United States Attorneys
Major Frauds/Environmental and Community Safety Crimes Sections
6 1100/1300 United States Courthouse
312 North Spring Street
7 Los Angeles, California 90012
Telephone: (213) 894-6527/2424/3819
8 Facsimile: (213) 894-6269/0141
E-mail: Scott.Paetty@usdoj.gov
9 Catherine.S.Ahn@usdoj.gov
Brian.Faerstein@usdoj.gov
10
DANIEL S. KAHN
11 Acting Chief, Fraud Section
Criminal Division, U.S. Department of Justice
12 CHRISTOPHER FENTON
Trial Attorney, Fraud Section
13 Criminal Division, U.S. Department of Justice
1400 New York Avenue NW, 3rd Floor
14 Washington, DC 20530
Telephone: (202) 320-0539
15 Facsimile: (202) 514-0152
E-mail: Christopher.Fenton@usdoj.gov
16
Attorneys for Plaintiff
17 UNITED STATES OF AMERICA
18 UNITED STATES DISTRICT COURT
19 FOR THE CENTRAL DISTRICT OF CALIFORNIA
20 UNITED STATES OF AMERICA, No. CR 20-579(A)-SVW-4
21 Plaintiff, PLEA AGREEMENT FOR DEFENDANT
TAMARA DADYAN
22 v.
23 RICHARD AYVAZYAN,
aka “Richard Avazian” and
24 “Iuliia Zhadko,”
MARIETTA TERABELIAN,
25 aka “Marietta Abelian” and
“Viktoria Kauichko,”
26 ARTUR AYVAZYAN,
aka “Arthur Ayvazyan,” and
27 TAMARA DADYAN,
MANUK GRIGORYAN,
28 aka “Mike Grigoryan,” and
Case 2:20-cr-00579-SVW Document 525 Filed 06/14/21 Page 2 of 31 Page ID #:6301
1 “Anton Kudiumov,”
ARMAN HAYRAPETYAN,
2 EDVARD PARONYAN,
aka “Edvard Paronian” and
3 “Edward Paronyan,” and
VAHE DADYAN,
4
Defendants.
5
6
1. This constitutes the plea agreement between TAMARA DADYAN
7
(“defendant”) and the United States Attorney’s Office for the Central
8
District of California and the United States Department of Justice,
9
Criminal Division, Fraud Section (collectively referred to herein as
10
“the Offices”) in the above-captioned case. This agreement is
11
limited to the Offices and cannot bind any other federal, state,
12
local, or foreign prosecuting, enforcement, administrative, or
13
regulatory authorities.
14
DEFENDANT’S OBLIGATIONS
15
2. Defendant agrees to:
16
a. At the earliest opportunity requested by the Offices
17
and provided by the Court, appear and plead guilty to counts 1, 24,
18
and 26 of the first superseding indictment in United States v.
19
Richard Ayvazyan et al., CR No. 20-579(A)-SVW, which charge defendant
20
with conspiracy to commit wire fraud and bank fraud, aggravated
21
identity theft, and conspiracy to commit money laundering, in
22
violation of 18 U.S.C. § 1349, 18 U.S.C. § 1028A(a)(1), and 18 U.S.C.
23
§ 1956(h), respectively.
24
b. Not contest facts agreed to in this agreement.
25
c. Abide by all agreements regarding sentencing contained
26
in this agreement.
27
28
2
Case 2:20-cr-00579-SVW Document 525 Filed 06/14/21 Page 3 of 31 Page ID #:6302
1 d. Appear for all court appearances, surrender as ordered
2 for service of sentence, obey all conditions of any bond, and obey
3 any other ongoing court order in this matter.
4 e. Not commit any crime; however, offenses that would be
5 excluded for sentencing purposes under United States Sentencing
6 Guidelines (“U.S.S.G.” or “Sentencing Guidelines”) § 4A1.2(c) are not
7 within the scope of this agreement.
8 f. Be truthful at all times with the United States
9 Probation and Pretrial Services Office and the Court.
10 g. Pay the applicable special assessments at or before
11 the time of sentencing unless defendant has demonstrated a lack of
12 ability to pay such assessments.
13 h. Ability to pay shall be assessed based on the
14 Financial Disclosure Statement, referenced below, and all other
15 relevant information relating to ability to pay.
16 i. Defendant agrees that any and all restitution/fine
17 obligations ordered by the Court will be due in full and immediately.
18 The government is not precluded from pursuing, in excess of any
19 payment schedule set by the Court, any and all available remedies by
20 which to satisfy defendant’s payment of the full financial
21 obligation, including referral to the Treasury Offset Program.
22 j. Complete the Financial Disclosure Statement on a form
23 provided by the Offices and, within 30 days of defendant’s entry of a
24 guilty plea, deliver the signed and dated statement, along with all
25 of the documents requested therein, to the Offices by either email at
26 usacac.FinLit@usdoj.gov (preferred) or mail to the United States
27 Attorney’s Office Financial Litigation Section at 300 N. Los Angeles
28 St., Suite 7516, Los Angeles, CA 90012.
3
Case 2:20-cr-00579-SVW Document 525 Filed 06/14/21 Page 4 of 31 Page ID #:6303
1 k. Authorize the Offices to obtain a credit report upon
2 returning a signed copy of this plea agreement.
3 l. Consent to the Offices inspecting and copying all of
4 defendant’s financial documents and financial information held by the
5 United States Probation and Pretrial Services Office.
6 3. Defendant further agrees:
7 a. To forfeit all right, title, and interest in and to
8 any and all monies, properties, and/or assets of any kind, derived
9 from or acquired as a result of the illegal activity to which
10 defendant is pleading guilty, specifically including, but not limited
11 to, the following:
12 i. $12,520.00 in U.S. Currency seized during the
13 execution of a federal search warrant on November 5, 2020, in Encino,
14 California, at the residence of defendant and Artur Ayvazyan;
15 ii. $3,032.23 in bank funds seized pursuant to a
16 federal seizure warrant executed on or about January 22, 2021, from
17 Bank of the West account ending in ‘0531 in the name of Tamara
18 Dadyan; and
19 iii. $189,430.85 in bank funds seized pursuant to a
20 federal seizure warrant executed on or about January 22, 2021, from
21 Bank of the West account ending in ‘5682 in the name of Proactive
22 Home Health Care Inc.
23 iv. Certain real property referred to in the first
24 superseding indictment as Residential Property 1, located at 4910
25 Topeka Drive, Tarzana, in the County of Los Angeles, State of
26 California, APN 2176-029-031;
27 v. Certain real property referred to in the first
28 superseding indictment as Residential Property 2, located at 834
4
Case 2:20-cr-00579-SVW Document 525 Filed 06/14/21 Page 5 of 31 Page ID #:6304
1 Calle La Primavera, Glendale, in the County of Los Angeles, State of
2 California, APN 5663-036-033; and
3 vi. Certain real property referred to in the first
4 superseding indictment as Residential Property 3, located at 74203
5 Anastacia Lane, Palm Desert, in the County of Riverside, State of
6 California, APN 694-331-008(collectively, the “Forfeitable
7 Property”).
8 (collectively, the “Forfeitable Property”).
9 b. To the Court’s entry of an order of forfeiture at or
10 before sentencing with respect to the Forfeitable Property and to the
11 forfeiture of the assets.
12 c. That the Preliminary Order of Forfeiture shall become
13 final as to the defendant upon entry.
14 d. To take whatever steps are necessary to pass to the
15 United States clear title to the Forfeitable Property, including,
16 without limitation, the execution of a consent decree of forfeiture
17 and the completing of any other legal documents required for the
18 transfer of title to the United States.
19 e. Not to contest any administrative forfeiture
20 proceedings or civil judicial proceedings commenced against the
21 Forfeitable Property. If defendant submitted a claim and/or petition
22 for remission for all or part of the Forfeitable Property on behalf
23 of herself or any other individual or entity, defendant shall and
24 hereby does withdraw any such claims or petitions, and further agrees
25 to waive any right she may have to seek remission or mitigation of
26 the forfeiture of the Forfeitable Property. Defendant further waives
27 any and all notice requirements of 18 U.S.C. § 983(a)(1)(A).
28
5
Case 2:20-cr-00579-SVW Document 525 Filed 06/14/21 Page 6 of 31 Page ID #:6305
1 f. Not to assist any other individual in any effort
2 falsely to contest the forfeiture of the Forfeitable Property.
3 g. Not to claim that reasonable cause to seize the
4 Forfeitable Property was lacking.
5 h. To prevent the transfer, sale, destruction, or loss of
6 the Forfeitable Property to the extent defendant has the ability to
7 do so.
8 i. To fill out and deliver to the Offices a completed
9 financial statement listing defendant’s assets on a form provided by
10 the Offices.
11 j. That forfeiture of Forfeitable Property shall not be
12 counted toward satisfaction of any special assessment, fine,
13 restitution, costs, or other penalty the Court may impose.
14 k. With respect to any criminal forfeiture ordered as a
15 result of this plea agreement, defendant waives: (1) the requirements
16 of Federal Rules of Criminal Procedure 32.2 and 43(a) regarding
17 notice of the forfeiture in the charging instrument, announcements of
18 the forfeiture at sentencing, and incorporation of the forfeiture in
19 the judgment; (2) all constitutional and statutory challenges to the
20 forfeiture (including by direct appeal, habeas corpus or any other
21 means); and (3) all constitutional, legal, and equitable defenses to
22 the forfeiture of the Forfeitable Property in any proceeding on any
23 grounds including, without limitation, that the forfeiture
24 constitutes an excessive fine or punishment. Defendant acknowledges
25 that the forfeiture of the Forfeitable Property is part of the
26 sentence that may be imposed in this case and waives any failure by
27 the Court to advise defendant of this, pursuant to Federal Rule of
28
6
Case 2:20-cr-00579-SVW Document 525 Filed 06/14/21 Page 7 of 31 Page ID #:6306
1 Criminal Procedure 11(b)(1)(J), at the time the Court accepts
2 defendant’s guilty plea.
3 THE OFFICES’ OBLIGATIONS
4 4. The Offices agree to:
5 a. Not contest facts agreed to in this agreement.
6 b. Abide by all agreements regarding sentencing contained
7 in this agreement.
8 c. At the time of sentencing, move to dismiss the
9 remaining counts of the first superseding indictment and the
10 underlying indictment as against defendant. Defendant agrees,
11 however, that at the time of sentencing the Court may consider any
12 dismissed charges in determining the applicable Sentencing Guidelines
13 range, the propriety and extent of any departure from that range, and
14 the sentence to be imposed.
15 d. At the time of sentencing, provided that defendant
16 demonstrates an acceptance of responsibility for the offense up to
17 and including the time of sentencing, recommend a two-level reduction
18 in the applicable Sentencing Guidelines offense level, pursuant to
19 U.S.S.G. § 3E1.1. The defendant understands and agrees that the
20 Offices will not move for a third point for acceptance of
21 responsibility, pursuant to U.S.S.G. § 3E1.1(b), and defendant agrees
22 that a reduction pursuant to U.S.S.G. § 3E1.1(b) for acceptance of
23 responsibility is not appropriate or warranted based on defendant’s
24 plea one (1) day prior to trial.
25 NATURE OF THE OFFENSES
26 5. Defendant understands that for defendant to be guilty of
27 the crime charged in count one, that is, Conspiracy to commit wire
28
7
Case 2:20-cr-00579-SVW Document 525 Filed 06/14/21 Page 8 of 31 Page ID #:6307
1 fraud and bank fraud, in violation of Title 18, United States Code,
2 Section 1349, the following must be true:
3 First, beginning by at least in or about March 2020, and
4 continuing to at least in or about October 2020, there was an
5 agreement between two or more persons to commit at wire fraud, in
6 violation of Section 1343 of Title 18 of the United States Code,
7 and/or bank fraud, in violation of Section 1344(2) of Title 18 of the
8 United States Code; and
9 Second, the defendant became a member of the conspiracy
10 knowing of at least one of its objects and intending to help
11 accomplish it.
12 6. The objects of the conspiracy charged in count one are wire
13 fraud and bank fraud. In order for a person to be found guilty of
14 wire fraud, in violation of 18 U.S.C. § 1343, the following must be
15 true:
16 First, the person knowingly participated in or devised a
17 scheme or plan to defraud, or a scheme or plan for obtaining money or
18 property by means of false or fraudulent pretenses, representations,
19 or promises. Deceitful statements of half-truths may constitute
20 false or fraudulent representations;
21 Second, the statements made or facts omitted as part of the
22 scheme were material; that is, they had a natural tendency to
23 influence, or were capable of influencing, another person to part
24 with money or property;
25 Third, the person acted with the intent to defraud, that
26 is, the intent to deceive and cheat; and
27
28
8
Case 2:20-cr-00579-SVW Document 525 Filed 06/14/21 Page 9 of 31 Page ID #:6308
1 Fourth, the person used, or caused to be used, an
2 interstate wire communication to carry out or attempt to carry out an
3 essential part of the scheme.
4 In order for a person to be found guilty of bank fraud, in
5 violation of 18 U.S.C. § 1344(2), the following must be true:
6 First, the person knowingly carried out a scheme or plan to
7 obtain money or property from a financial institution by making false
8 statements or promises;
9 Second, the person knew that the statements or promises
10 were false;
11 Third, the statements or promises were material; that is,
12 they had a natural tendency to influence, or were capable of
13 influencing, a financial institution to part with money or property;
14 Fourth, the person acted with the intent to defraud; and
15 Fifth, the financial institution was federally insured.
16 7. Defendant understands that for defendant to be guilty of
17 the crime charged in count 24, that is, aggravated identity theft, in
18 violation of Title 18, United States Code, Section 1028A(a)(1), the
19 following must be true:
20 First, defendant knowingly possessed without legal
21 authority a means of identification of another person;
22 Second, defendant knew that the means of identification
23 belonged to a real person; and
24 Third, defendant did so during and in relation to bank
25 fraud, in violation of 18 U.S.C. § 1344(2), as charged in count
26 nineteen of the first superseding indictment. The government need
27 not establish that the means of identification of another person was
28 stolen.
9
Case 2:20-cr-00579-SVW Document 525 Filed 06/14/21 Page 10 of 31 Page ID #:6309
1 8. Defendant understands that for defendant to be guilty of
2 the crime charged in count 26, that is, Conspiracy to commit money
3 laundering, in violation of Title 18, United States Code, Section
4 1956(h), the following must be true:
5 First, Defendant agreed with one of more co-conspirators to
6 engage in money laundering, in violation of Section 1956(a)(1)(B)(i)
7 of Title 18 of the United States Code; and
8 Second, the defendant became a member of the conspiracy
9 knowing of its object and intending to help accomplish it.
10 9. The object of the conspiracy charged in count 26 is money
11 laundering, in violation of Section 1956(a)(1)(B)(i) of Title 18. In
12 order for a person to be found guilty of that offense, the following
13 must be true:
14 First, the person conducted a financial transaction
15 involving property that represented the proceeds of wire fraud;
16 Second, the person knew that the property represented the
17 proceeds of some form of unlawful activity; and
18 Third, the person knew that the transaction was designed in
19 whole or in part to conceal or disguise the nature, location, source,
20 ownership, and/or control of such proceeds.
21 PENALTIES AND RESTITUTION
22 10. Defendant understands that the statutory maximum sentence
23 that the Court can impose for a violation of Title 18, United States
24 Code, Section 1349, as charged in count one, is: 30 years’
25 imprisonment; a five-year period of supervised release; a fine of
26 $1,000,000 or twice the gross gain or gross loss resulting from the
27 offense, whichever is greatest; and a mandatory special assessment of
28 $100.
10
Case 2:20-cr-00579-SVW Document 525 Filed 06/14/21 Page 11 of 31 Page ID #:6310
1 11. Defendant understands that the statutory maximum sentence
2 that the Court can impose for a violation of Title 18, United States
3 Code, Section 1028A(a)(1), as charged in count 24 of the first
4 superseding indictment, is: two years’ imprisonment; a three-year
5 period of supervised release; a fine of $250,000 or twice the gross
6 gain or gross loss resulting from the offense, whichever is greatest;
7 and a mandatory special assessment of $100.
8 12. Defendant understands that the statutory mandatory minimum
9 sentence that the Court must impose for a violation of Title 18,
10 United States Code, Section 1028A(a)(1), as charged in count 24 of
11 the first superseding indictment, is a two-year term of imprisonment,
12 which must run consecutive to any other sentence of imprisonment, and
13 a mandatory special assessment of $100.
14 13. Defendant understands that the statutory maximum sentence
15 that the Court can impose for a violation of Title 18, United States
16 Code, Section 1956(h), as charged in count 26, is: 20 years’
17 imprisonment; a three-year period of supervised release; a fine of
18 $500,000 or twice the gross gain or gross loss resulting from the
19 offense, whichever is greatest; and a mandatory special assessment of
20 $100.
21 14. Defendant understands, therefore, that the total maximum
22 sentence for all offenses to which defendant is pleading guilty is:
23 52 years’ imprisonment; a 5-year period of supervised release; a fine
24 of $1,750,000 or twice the gross gain or gross loss resulting from
25
26
27
28
11
Case 2:20-cr-00579-SVW Document 525 Filed 06/14/21 Page 12 of 31 Page ID #:6311
1 the offenses, whichever is greatest; and a mandatory special
2 assessment of $300. 1
3 15. Defendant understands that defendant will be required to
4 pay full restitution to the victims of the offenses to which
5 defendant is pleading guilty. Defendant agrees that, in return for
6 the Offices’ compliance with its obligations under this agreement,
7 the Court may order restitution to persons other than the victims of
8 the offenses to which defendant is pleading guilty and in amounts
9 greater than those alleged in the counts to which defendant is
10 pleading guilty. In particular, defendant agrees that the Court may
11 order restitution to any victim of any of the following for any
12 losses suffered by that victim as a result: (a) any relevant conduct,
13 as defined in U.S.S.G. § 1B1.3, in connection with the offenses to
14 which defendant is pleading guilty; and (b) any counts dismissed and
15 charges not prosecuted pursuant to this agreement as well as all
16 relevant conduct, as defined in U.S.S.G. § 1B1.3, in connection with
17 those counts and charges. The parties currently believe that the
18 applicable amount of restitution is approximately $18,016,141.26, but
19 recognize and agree that this amount could change based on facts that
20 come to the attention of the parties prior to sentencing.
21 16. Defendant understands that supervised release is a period
22 of time following imprisonment during which defendant will be subject
23 to various restrictions and requirements. Defendant understands that
24
25 1Defendant understands that there is case law suggesting that
the term of supervised release on count 24 could be imposed to run
26 consecutively to the term of supervised release imposed on counts one
and 26. While the Offices do not intend to seek a consecutive term
27 of supervised release, defendant understands that if the Court were
to impose a consecutive term of supervised release, the maximum term
28 of supervised release for the counts of conviction would be eight
years, rather than five years as stated in the text above.
12
Case 2:20-cr-00579-SVW Document 525 Filed 06/14/21 Page 13 of 31 Page ID #:6312
1 if defendant violates one or more of the conditions of any supervised
2 release imposed, defendant may be returned to prison for all or part
3 of the term of supervised release authorized by statute for the
4 offense that resulted in the term of supervised release, which could
5 result in defendant serving a total term of imprisonment greater than
6 the statutory maximum stated above.
7 17. Defendant understands that, by pleading guilty, defendant
8 may be giving up valuable government benefits and valuable civic
9 rights, such as the right to vote, the right to possess a firearm,
10 the right to hold office, and the right to serve on a jury. Defendant
11 understands that she is pleading guilty to felonies and that it is a
12 federal crime for a convicted felon to possess a firearm or
13 ammunition. Defendant understands that the convictions in this case
14 may also subject defendant to various other collateral consequences,
15 including but not limited to revocation of probation, parole, or
16 supervised release in another case and suspension or revocation of a
17 professional license. Defendant understands that unanticipated
18 collateral consequences will not serve as grounds to withdraw
19 defendant’s guilty pleas.
20 18. Defendant and her counsel have discussed the fact that, and
21 defendant understands that, if defendant is not a United States
22 citizen, the convictions in this case make it practically inevitable
23 and a virtual certainty that defendant will be removed or deported
24 from the United States. Defendant may also be denied United States
25 citizenship and admission to the United States in the future.
26 Defendant understands that while there may be arguments that
27 defendant can raise in immigration proceedings to avoid or delay
28 removal, removal is presumptively mandatory and a virtual certainty
13
Case 2:20-cr-00579-SVW Document 525 Filed 06/14/21 Page 14 of 31 Page ID #:6313
1 in this case. Defendant further understands that removal and
2 immigration consequences are the subject of a separate proceeding and
3 that no one, including his/her attorney or the Court, can predict to
4 an absolute certainty the effect of his/her convictions on his/her
5 immigration status. Defendant nevertheless affirms that he/she wants
6 to plead guilty regardless of any immigration consequences that
7 his/her pleas may entail, even if the consequence is automatic
8 removal from the United States.
9 FACTUAL BASIS
10 19. Defendant admits that defendant is, in fact, guilty of the
11 offenses to which defendant is agreeing to plead guilty. Defendant
12 and the Offices agree to the statement of facts provided below and
13 agree that this statement of facts is sufficient to support pleas of
14 guilty to the charges described in this agreement and to establish
15 the Sentencing Guidelines factors set forth in paragraph 21 below but
16 is not meant to be a complete recitation of all facts relevant to the
17 underlying criminal conduct or all facts known to either party that
18 relate to that conduct.
19 Beginning in or about March 2020, defendant agreed with her
20 husband, co-defendant Artur Ayvazyan; her brother-in-law, co-
21 defendant Richard Ayvazyan; her sister-in-law, co-defendant Marietta
22 Terabelian; her cousin, co-defendant Vahe Dadyan, and others to
23 submit fraudulent applications for loans through the Paycheck
24 Protection Program (“PPP”) and the Economic Injury Disaster Loan
25 (“EIDL”) program to lenders, including federally-insured financial
26 institutions A, B, C, D, E, G, and H, and non-federally insured
27 lending institution F, as identified in the first superseding
28 indictment, and the United States Small Business Administration
14
Case 2:20-cr-00579-SVW Document 525 Filed 06/14/21 Page 15 of 31 Page ID #:6314
1 (“SBA”). The false and fraudulent information defendant agreed with
2 co-defendants Richard Ayvazyan, Marietta Terabelian, Artur Ayvazyan,
3 Vahe Dadyan and others to provide to those lenders and the SBA
4 included: false applicant names, false information about the number
5 of employees and payroll of the businesses purportedly applying for
6 the loans, and false information about the owners of the bank
7 accounts into which the loan proceeds would be deposited, all of
8 which information was material to the SBA and the lenders.
9 Defendant and her co-conspirators, Richard Ayvazyan, Artur
10 Ayvazyan, Marietta Terebelian, and others used and caused to be used
11 stolen, fictitious, and synthetic identities of other individuals,
12 including persons out of the country and a dead person, as well as
13 the names of businesses not controlled by defendant or her co-
14 conspirators, in order to submit false and fraudulent applications
15 for EIDL and PPP loans. This information included, but was not
16 limited to, names used by co-defendant Richard Ayvazyan like “Iuliia
17 Zhadko,” and names used by co-defendant Marietta Terabelian, like
18 “Viktoria Kauichko.” The information also included false and
19 fraudulent payroll reports and IRS Forms 940 and 941 that purported
20 to confirm the number of employees and amount of payroll expenses;
21 false certifications that the loan proceeds would be used for
22 permissible business purposes; and the names of identity theft
23 victims, including the names of dead people.
24 Defendant further conspired and agreed with her husband, Artur
25 Ayvazyan, to create false and fraudulent documentation in support of
26 loans, including through the use of templates for creating false and
27 fraudulent documents that were found on Artur Ayvazyan’s phone.
28 Defendant further admits that records and items found at her
15
Case 2:20-cr-00579-SVW Document 525 Filed 06/14/21 Page 16 of 31 Page ID #:6315
1 residence, at which she lived with co-defendant Artur Ayvazyan,
2 included: fake identification documents; fraudulently obtained credit
3 cards belonging to fake, synthetic and stolen identities including
4 names used to apply for PPP and EIDL loans; checks and checkbooks in
5 the names of individuals and businesses who applied for PPP and EIDL
6 loans; copies of PPP and EIDL loan applications including in her own
7 name and the names of others; and fake and stolen notary stamps and
8 seals belonging to state and federal courts.
9 Defendant submitted and caused to be submitted, and aided and
10 abetted the submission of at least 151 fraudulent PPP and EIDL
11 applications as part of the conspiracy and scheme in which she was a
12 participant along with Richard Ayvazyan, Marietta Terabelian, Artur
13 Ayvazyan, Vahe Dadyan, and others. Furthermore, text messages
14 obtained from defendant’s phone showed that defendant explicitly
15 discussed plans for the conspiracy with co-defendant Richard
16 Ayvazyan, including how to submit PPP and EIDL applications; how to
17 obtain and falsify Employer Identification Numbers (“EINs”) for
18 businesses in PPP and EIDL applications; and how to create fake
19 payroll reports.
20 Defendant also agreed with co-defendants Richard Ayvazyan,
21 Marietta Terabelian, Artur Ayvazyan, Vahe Dadyan, and others that the
22 fraudulently obtained loan proceeds would be used to pay for personal
23 expenses and not used to pay for authorized expenses under the PPP
24 and EIDL programs. In order to make these unauthorized payments,
25 including for personal expenses, defendant agreed with co-defendants
26 Richard Ayvazyan, Marietta Terabelian, Artur Ayvazyan, Vahe Dadyan,
27 and others to cause the fraudulently obtained loan proceeds to move
28 through bank accounts over which defendant and co-defendants Richard
16
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1 Ayvazyan, Marietta Terabelian, Artur Ayvazyan, and Vahe Dadyan, and
2 others had signatory authority, in order to conceal the true nature
3 and source of the funds flowing through the accounts.
4 For example, in furtherance of the conspiracy to commit wire
5 fraud and bank fraud, on or about April 22, 2020, defendant, together
6 with co-defendants Richard Ayvazyan, Marietta Terabelian, Artur
7 Ayvazyan, and others, submitted and caused to be submitted to Wells
8 Fargo bank an application in the name of Secureline Realty and
9 Funding, Inc. (“Secureline Realty”) seeking a PPP loan in the amount
10 of $122,838, which application: (a) falsely represented that
11 Secureline Realty had eight employees, including employees for whom
12 it had paid wages and payroll taxes; and (b) falsely certified
13 Secureline Realty would use the loan proceeds only for permissible
14 business purposes. On or about May 9, 2020, defendant, together with
15 other co-conspirators, submitted and caused to be submitted to
16 Comerica Bank another application in the name of Secureline Realty
17 seeking a second PPP loan, this one in the amount of $137,500, which
18 application again falsely represented that Secureline Realty had
19 eight employees, including employees for whom it had paid wages and
20 payroll taxes, and falsely certified Secureline Realty would use the
21 loan proceeds only for permissible business purposes.
22 In reliance on the false statements and representations in the
23 applications, on or about May 7, 2020, Wells Fargo identified as
24 Lender D in the first superseding indictment) deposited, by means of
25 interstate wire, approximately $122,838 into a Wells Fargo bank
26 account in the name of Secureline Realty, and on or about May 11,
27 2020, Comerica Bank (identified as Lender E in the first superseding
28
17
Case 2:20-cr-00579-SVW Document 525 Filed 06/14/21 Page 18 of 31 Page ID #:6317
1 indictment) deposited, by means of interstate wire, $137,500 into a
2 Comerica Bank account in the name of Secureline Realty.
3 Thereafter, defendant, together with co-defendant Richard
4 Ayvazyan and others, caused a check for approximately $136,000 to be
5 drawn on May 27, 2020, on the Secureline Realty account at Comerica
6 Bank, and a check for approximately $120,010 to be drawn on June 12,
7 2020, on the Secureline Realty account at Wells Fargo. Defendant,
8 together with co-defendant Richard Ayvazyan and others, caused both
9 checks to be deposited into other bank accounts, including a Bank of
10 America account for Inception Ventures for which co-defendant Richard
11 Ayvazyan was the sole signatory. As defendant knew and agreed, these
12 monies were the proceeds of unlawful activity, and specifically, the
13 PPP and EIDL bank and wire fraud scheme. The defendant and her co-
14 conspirators then wired and caused to be wired these fraud proceeds
15 to Encore Escrow, and co-defendants Richard Ayvazyan and Marietta
16 Terebelian used such proceeds as part of the purchase price of their
17 personal residence on Topeka Avenue, in Tarzana, California.
18 As another example of the actions taken in furtherance of the
19 conspiracy, defendant agreed with co-defendant Vahe Dadyan to
20 fraudulently apply for a PPP loan in the name of Vahe Dadyan’s
21 company Voyage Limo. On May 18, 2020, defendant and her co-
22 conspirators submitted and caused the submission of a PPP loan
23 application to Celtic Bank that falsely stated that Voyage Limo had
24 11 employees and average monthly payroll expenses of $63,000, and
25 that Voyage Limo would use the loan proceeds solely for business-
26 related purposes. Defendant and her co-conspirators also submitted
27 and caused the submission of fake IRS Forms 940 and 941 to Celtic
28 Bank in support of the PPP loan application. On May 18, 2020, in
18
Case 2:20-cr-00579-SVW Document 525 Filed 06/14/21 Page 19 of 31 Page ID #:6318
1 reliance on the false information in the application, Celtic Bank
2 deposited, by means of an interstate wire, $157,000 to a Voyage Limo
3 bank account over which co-defendant Vahe Dadyan had signatory
4 authority. In furtherance of the conspiracy, on July 3, 2020, co-
5 defendant Vahe Dadyan, working together with the defendant and
6 others, caused $155,000 of the fraudulently obtained PPP loan
7 proceeds to be wired to a Bank of America account in the name of
8 Runyan Tax Services, held in the name of “Viktoria Kauichko,” a name
9 defendant knew was used in furtherance of the bank fraud and wire
10 fraud and money laundering conspiracy. The co-conspirators,
11 including Richard Ayvazyan and Marietta Terebelian, then used these
12 PPP-derived funds as part of a down payment on a property located on
13 Calle La Primavera, in Glendale, California, which was purchased in
14 the name of “Iuliia Zhadko,” which the defendant and her co-
15 conspirators knew was used by co-defendant Richard Ayvazyan.
16 As a further example of the conspiracy, on or about August 13,
17 2020, defendant and her husband, co-defendant Artur Ayvazyan,
18 submitted via interstate wiring an application for a $244,500 PPP
19 loan to Newtek Small Business Finance in the name of “A.D. DBA Six
20 Star Farms.” Defendant and co-defendant Artur Ayvazyan knew that the
21 application included false information; namely, that the business had
22 22 employees including employees for whom A.D. paid wages and payroll
23 taxes, and that A.D. would use the loan proceeds only for permissible
24 purposes. In support of the application, defendant and co-defendant
25 Artur Ayvazyan submitted to Newtek Small Business Finance a
26 California Driver’s license purportedly belonging to A.D., and a fake
27 Form 941, which falsely represented that it had been prepared by
28 A.F., a professional tax preparer, and signed by A.D. Defendant knew
19
Case 2:20-cr-00579-SVW Document 525 Filed 06/14/21 Page 20 of 31 Page ID #:6319
1 that A.D. and A.F. were real persons. In truth and in fact, as the
2 defendant well knew, neither A.D. nor A.F. authorized the defendant,
3 co-defendant Artur Ayvazyan, or any of the other co-conspirators to
4 use their names or identifying information. On or about August 17,
5 2020, in reliance on the false and fraudulent information included in
6 the PPP loan application defendant and co-defendant Artur Ayvazyan
7 had submitted, Newtek Small Business Finance deposited by means of an
8 interstate wire approximately $244,500 to a bank account at Capital
9 One in the name of A.D. that co-defendant Artur Ayvazyan controlled.
10 During the course of the conspiracy and in furtherance of it,
11 defendant and her co-conspirators, Richard Ayvazyan, Marietta
12 Terebelian, Artur Ayvazyan, and others, submitted and caused the
13 submission of approximately 151 PPP and EIDL loan applications
14 containing false and fraudulent information by which they attempted
15 to obtain approximately $21.9 million and did obtain approximately
16 $18,016,141.26. By submitting materially false and fraudulent
17 documentation in support of the PPP and EIDL loan applications, and
18 by making materially false and fraudulent statements to SBA-approved
19 and FDIC-insured lenders, defendant knowingly, and with the intent to
20 defraud, schemed to obtain, and obtained, funds under the custody and
21 control of Lenders A, B, C, D, E, G, and H, and placed such lenders
22 at risk of financial loss. The conspiracy was carried out using
23 sophisticated means, including the use of false businesses, stolen
24 identities, a network of bank accounts opened in the names of those
25 false businesses, and the production of fraudulent documents
26 including identity documents. Indeed, the defendant used coordinated
27 and repetitive steps to carry out and conceal the scheme, including
28 falsifying tax and payroll documents and using bank accounts with
20
Case 2:20-cr-00579-SVW Document 525 Filed 06/14/21 Page 21 of 31 Page ID #:6320
1 deceptive names to conceal the nature, location, source, and
2 ownership of PPP and EIDL loan proceeds.
3 SENTENCING FACTORS
4 20. Defendant understands that in determining defendant’s
5 sentence the Court is required to calculate the applicable Sentencing
6 Guidelines range and to consider that range, possible departures
7 under the Sentencing Guidelines, and the other sentencing factors set
8 forth in 18 U.S.C. § 3553(a). Defendant understands that the
9 Sentencing Guidelines are advisory only, that defendant cannot have
10 any expectation of receiving a sentence within the calculated
11 Sentencing Guidelines range, and that after considering the
12 Sentencing Guidelines and the other § 3553(a) factors, the Court will
13 be free to exercise its discretion to impose any sentence it finds
14 appropriate between the mandatory minimum and up to the maximum set
15 by statute for the crimes of conviction.
16 21. Defendant and the USAO agree to the following applicable
17 Sentencing Guidelines factors:
18 Base Offense Level: 7 [U.S.S.G.
§§ 2X1,1; 2b1.1(a)(1)]
19 Specific Offense
Characteristics
20 [U.S.S.G. §§ 2X1,1;
Amount of loss >$9,500,000 +20 2B1.1(b)(1)(K)]
21
Sophisticated Means: +2 [U.S.S.G. § §§ 2X1,1;
22 2B1.1(b)(10)(C)] ]
Conviction under 18 U.S.C. +2
23 § 1956 [U.S.S.G. § 2S1.1(b)(2)(B)
24
Defendant and the Offices reserve the right to argue that additional
25
specific offense characteristics, adjustments, and departures under
26
the Sentencing Guidelines are appropriate. Defendant further
27
understands that the Court must sentence defendant to a term of two
28
21
Case 2:20-cr-00579-SVW Document 525 Filed 06/14/21 Page 22 of 31 Page ID #:6321
1 (2) years imprisonment on count 24, which must run consecutive to any
2 term of imprisonment imposed for counts one and 26.
3 22. Defendant understands that there is no agreement as to
4 defendant’s criminal history or criminal history category.
5 23. Defendant and the Offices reserve the right to argue for a
6 sentence outside the sentencing range established by the Sentencing
7 Guidelines based on the factors set forth in 18 U.S.C. § 3553(a)(1),
8 (a)(2), (a)(3), (a)(6), and (a)(7).
9 WAIVER OF CONSTITUTIONAL RIGHTS
10 24. Defendant understands that by pleading guilty, defendant
11 gives up the following rights:
12 a. The right to persist in a plea of not guilty.
13 b. The right to a speedy and public trial by jury.
14 c. The right to be represented by counsel –- and if
15 necessary have the Court appoint counsel – at trial. Defendant
16 understands, however, that, defendant retains the right to be
17 represented by counsel –- and if necessary have the Court appoint
18 counsel –- at every other stage of the proceeding.
19 d. The right to be presumed innocent and to have the
20 burden of proof placed on the government to prove defendant guilty
21 beyond a reasonable doubt.
22 e. The right to confront and cross-examine witnesses
23 against defendant.
24 f. The right to testify and to present evidence in
25 opposition to the charges, including the right to compel the
26 attendance of witnesses to testify.
27
28
22
Case 2:20-cr-00579-SVW Document 525 Filed 06/14/21 Page 23 of 31 Page ID #:6322
1 g. The right not to be compelled to testify, and, if
2 defendant chose not to testify or present evidence, to have that
3 choice not be used against defendant.
4 h. Any and all rights to pursue any affirmative defenses,
5 Fourth Amendment or Fifth Amendment claims, and other pretrial
6 motions that have been filed or could be filed.
7 WAIVER OF APPEAL OF CONVICTION
8 25. Defendant understands that, with the exception of an appeal
9 based on a claim that defendant’s guilty pleas were involuntary, by
10 pleading guilty defendant is waiving and giving up any right to
11 appeal defendant’s convictions on the offenses to which defendant is
12 pleading guilty. Defendant understands that this waiver includes,
13 but is not limited to, arguments that the statutes to which defendant
14 is pleading guilty are unconstitutional, and any and all claims that
15 the statement of facts provided herein is insufficient to support
16 defendant’s pleas of guilty.
17 LIMITED MUTUAL WAIVER OF APPEAL OF SENTENCE
18 26. Defendant agrees that, provided the Court, before
19 imposition of the mandatory consecutive sentence of two (2) years’
20 imprisonment on count 24, imposes a term of imprisonment no more than
21 the high-end of the Sentencing Guidelines range calculated by the
22 Court, defendant gives up the right to appeal all of the following:
23 (a) the procedures and calculations used to determine and impose any
24 portion of the sentence; (b) the term of imprisonment imposed by the
25 Court; (c) the fine imposed by the Court, provided it is within the
26 statutory maximum; (d) to the extent permitted by law, the
27 constitutionality or legality of defendant’s sentence, provided it is
28 within the statutory maximum; (e) the amount and terms of any
23
Case 2:20-cr-00579-SVW Document 525 Filed 06/14/21 Page 24 of 31 Page ID #:6323
1 restitution order, provided it requires payment of no more than
2 $18,016,141.26; (f) the term of probation or supervised release
3 imposed by the Court, provided it is within the statutory maximum;
4 and (g) any of the following conditions of probation or supervised
5 release imposed by the Court: the conditions set forth in Second
6 Amended General Order 20-04 of this Court; the drug testing
7 conditions mandated by 18 U.S.C. §§ 3563(a)(5) and 3583(d); and the
8 alcohol and drug use conditions authorized by 18 U.S.C. § 3563(b)(7).
9 27. The Offices agree that, provided (a) all portions of the
10 sentence are at or above the statutory minimum and at or below the
11 statutory maximum specified above and (b) before imposition of the
12 mandatory consecutive sentence of two (2) years’ imprisonment on
13 count 24, the Court imposes a term of imprisonment no less than the
14 low-end of the Sentencing Guidelines range calculated by the Court,
15 the Offices give up their right to appeal any portion of the
16 sentence, with the exception that the Offices reserve the right to
17 appeal the amount of restitution ordered if that amount is less than
18 $18,016,141.26.
19 RESULT OF WITHDRAWAL OF GUILTY PLEA
20 28. Defendant agrees that if, after entering guilty pleas
21 pursuant to this agreement, defendant seeks to withdraw and succeeds
22 in withdrawing defendant’s guilty pleas on any basis other than a
23 claim and finding that entry into this plea agreement was
24 involuntary, then (a) the Offices will be relieved of all of their
25 obligations under this agreement; and (b) should the Offices choose
26 to pursue any charge that was either dismissed or not filed as a
27 result of this agreement, then (i) any applicable statute of
28 limitations will be tolled between the date of defendant’s signing of
24
Case 2:20-cr-00579-SVW Document 525 Filed 06/14/21 Page 25 of 31 Page ID #:6324
1 this agreement and the filing commencing any such action; and
2 (ii) defendant waives and gives up all defenses based on the statute
3 of limitations, any claim of pre-indictment delay, or any speedy
4 trial claim with respect to any such action, except to the extent
5 that such defenses existed as of the date of defendant’s signing this
6 agreement.
7 RESULT OF VACATUR, REVERSAL OR SET-ASIDE
8 29. Defendant agrees that if any count of conviction is
9 vacated, reversed, or set aside, the Offices may: (a) ask the Court
10 to resentence defendant on any remaining counts of conviction, with
11 both the Offices and defendant being released from any stipulations
12 regarding sentencing contained in this agreement, (b) ask the Court
13 to void the entire plea agreement and vacate defendant’s guilty pleas
14 on any remaining counts of conviction, with the Offices and defendant
15 being released from all their obligations under this agreement, or
16 (c) leave defendant’s remaining convictions, sentence, and plea
17 agreement intact. Defendant agrees that the choice among these three
18 options rests in the exclusive discretion of the Offices.
19 EFFECTIVE DATE OF AGREEMENT
20 30. This agreement is effective upon signature and execution of
21 all required certifications by defendant, defendant’s counsel, and an
22 attorney for the Offices.
23 BREACH OF AGREEMENT
24 31. Defendant agrees that if defendant, at any time after the
25 effective date of this agreement, knowingly violates or fails to
26 perform any of defendant’s obligations under this agreement (“a
27 breach”), the Offices may declare this agreement breached. All of
28 defendant’s obligations are material, a single breach of this
25
Case 2:20-cr-00579-SVW Document 525 Filed 06/14/21 Page 26 of 31 Page ID #:6325
1 agreement is sufficient for the Offices to declare a breach, and
2 defendant shall not be deemed to have cured a breach without the
3 express agreement of the Offices in writing. If the Offices declares
4 this agreement breached, and the Court finds such a breach to have
5 occurred, then: (a) if defendant has previously entered guilty pleas
6 pursuant to this agreement, defendant will not be able to withdraw
7 the guilty pleas, and (b) the Offices will be relieved of all their
8 obligations under this agreement.
9 32. Following the Court’s finding of a knowing breach of this
10 agreement by defendant, should the Offices choose to pursue any
11 charge that was either dismissed or not filed as a result of this
12 agreement, then:
13 a. Defendant agrees that any applicable statute of
14 limitations is tolled between the date of defendant’s signing of this
15 agreement and the filing commencing any such action.
16 b. Defendant waives and gives up all defenses based on
17 the statute of limitations, any claim of pre-indictment delay, or any
18 speedy trial claim with respect to any such action, except to the
19 extent that such defenses existed as of the date of defendant’s
20 signing this agreement.
21 c. Defendant agrees that: (i) any statements made by
22 defendant, under oath, at the guilty plea hearing (if such a hearing
23 occurred prior to the breach); (ii) the agreed to factual basis
24 statement in this agreement; and (iii) any evidence derived from such
25 statements, shall be admissible against defendant in any such action
26 against defendant, and defendant waives and gives up any claim under
27 the United States Constitution, any statute, Rule 410 of the Federal
28 Rules of Evidence, Rule 11(f) of the Federal Rules of Criminal
26
Case 2:20-cr-00579-SVW Document 525 Filed 06/14/21 Page 27 of 31 Page ID #:6326
1 Procedure, or any other federal rule, that the statements or any
2 evidence derived from the statements should be suppressed or are
3 inadmissible. Defendant also agrees that any such statements can be
4 used to cross-examine her should she take the stand at trial of any
5 co-defendant or in any other matter.
6 COURT AND UNITED STATES PROBATION AND PRETRIAL SERVICES
7 OFFICE NOT PARTIES
8 33. Defendant understands that the Court and the United States
9 Probation and Pretrial Services Office are not parties to this
10 agreement and need not accept any of the Offices’ sentencing
11 recommendations or the parties’ agreements to facts or sentencing
12 factors.
13 34. Defendant understands that defendant and the Offices are
14 free to: (a) supplement the facts by supplying relevant information
15 to the United States Probation and Pretrial Services Office and the
16 Court, (b) correct any and all factual misstatements relating to the
17 Court’s Sentencing Guidelines calculations and determination of
18 sentence, and (c) argue on appeal and collateral review that the
19 Court’s Sentencing Guidelines calculations and the sentence it
20 chooses to impose are not error, although each party agrees to
21 maintain its view that the calculations in paragraph 21 are
22 consistent with the facts of this case. While this paragraph permits
23 the Offices and defendant to submit full and complete factual
24 information to the United States Probation and Pretrial Services
25 Office and the Court, even if that factual information may be viewed
26 as inconsistent with the facts agreed to in this agreement, this
27 paragraph does not affect defendant’s and the Offices’ obligations
28 not to contest the facts agreed to in this agreement.
27
Case 2:20-cr-00579-SVW Document 525 Filed 06/14/21 Page 28 of 31 Page ID #:6327
1 35. Defendant understands that even if the Court ignores any
2 sentencing recommendation, finds facts or reaches conclusions
3 different from those agreed to, and/or imposes any sentence up to the
4 maximum established by statute, defendant cannot, for that reason,
5 withdraw defendant’s guilty pleas, and defendant will remain bound to
6 fulfill all defendant’s obligations under this agreement. Defendant
7 understands that no one –- not the prosecutor, defendant’s attorney,
8 or the Court –- can make a binding prediction or promise regarding
9 the sentence defendant will receive, except that it will be between
10 the statutory mandatory minimum and the statutory maximum.
11 NO ADDITIONAL AGREEMENTS
12 36. Defendant understands that, except as set forth herein,
13 there are no promises, understandings, or agreements between the
14 Offices and defendant or defendant’s attorney, and that no additional
15 promise, understanding, or agreement may be entered into unless in a
16 writing signed by all parties or on the record in court.
17 //
18 //
19 //
20 //
21 //
22 //
23 //
24 //
25 //
26 //
27 //
28 //
28
Case 2:20-cr-00579-SVW Document 525 Filed 06/14/21 Page 29 of 31 Page ID #:6328
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Case 2:20-cr-00579-SVW Document 525 Filed 06/14/21 Page 30 of 31 Page ID #:6329
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R rep=c~;<'nt.,.il ions of •.my kind h.:ivP boan rnadt: Lo me other Lh,Hl these
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25 provi!,;)Onf>, . -=!nd 01 Lhu c;c-mscqucnt.:-ti:-; o f entc r i nq i n lo thi!:i uqrtwment .
26 To my know l<'dgc- : 110 pr-om i ses , i nduce ments , or rr·p resenLat i m1 :-. o i any
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28 agr<>0mun1· : ne> on e- h,rn t hr·catc,ncd or I c,rcc d my cl ; ••n t in an y w,1 y to
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Case 2:20-cr-00579-SVW Document 525 Filed 06/14/21 Page 31 of 31 Page ID #:6330
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