United States v. Ashot Bejanyan — Plea Agreement, Central District of California (Dkt. 156)

Summary

In this plea agreement filed 06/09/25 in the Central District of California, Ashot Bejanyan, aka Alex Benjamin, agrees to plead guilty to a two-count information charging bank fraud under 18 U.S.C. § 1344(2) and conspiracy to commit money laundering under 18 U.S.C. § 1956(h). In the factual basis Bejanyan admits scheming with others in January 2025 to defraud First Citizens Bank and Trust Co. of North Carolina with papers falsely showing that a fake business qualified to borrow approximately $2.6 million. Bejanyan also admits causing at least approximately 255 transfers, for a total of approximately $3,570,000, through a US Bank account opened to conceal fraud proceeds, including from Paycheck Protection and Economic Injury Disaster Loan applications. The parties believe restitution will be at least approximately $2 million.

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FILED
CLERK, U.S. DISTRICT COURT

BILAL A. ESSAYLI
United States Attorney
CHRISTINA T. SHAY 6/9/2025
Assistant United States Attorney CENTRAL DISTRICT OF CALIFORNIA
Chief, Criminal Division SS
MARK AVEIS (Cal. Bar No. 107881)
GREGG MARMARO (Cal. Bar No. 338627)
Assistant United States Attorneys
Major Frauds Section

1100 United States Courthouse

312 North Spring Street

Los Angeles, California 90012

Telephone: (213) 894-4477/8500

Facsimile: (213) 894-6269

E-mail: mark.aveis@usdoj.gov

gregg.marmaro@usdoj.gov

Attorneys for Plaintiff
UNITED STATES OF AMERICA

UNITED STATES DISTRICT COURT
FOR THE CENTRAL DISTRICT OF CALIFORNIA
UNITED STATES OF AMERICA, No. CR 2:25-CR-00450-CV

Plaintiff, PLEA AGREEMENT FOR DEFENDANT
ASHOT BEJANYAN

ASHOT BEJANYAN,
aka Alex Benjamin,

Defendant.

1. This constitutes the plea agreement between ASHOT BENJAYAN
(“defendant”), and the United States Attorney’s Office for the
Central District of California (the “USAO”) in the investigation
regarding fraud and money laundering in connection with pandemic
stimulus and Small Business Administration loans. This agreement is
limited to the USAO and cannot bind any other federal, state, local,
or foreign prosecuting, enforcement, administrative, or regulatory

authorities.
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Pase 2:25-cr-00450-CV Document156-~ Filed 06/09/25 Page2of18 Page ID #:202

DEFENDANT’ S OBLIGATIONS

2. Defendant agrees to:

a) At the earliest opportunity requested by the USAO and
provided by the Court, appear and plead guilty to a two-count
information that charges defendant with bank fraud, in violation of
18 U.S.C. § 1344(2), and conspiracy to commit money laundering, in
violation of 18 U.S.C. § 1956(h).

b) Not contest facts agreed to in this agreement.

c) Abide by all agreements regarding sentencing
contained in this agreement.

d) Appear for all court appearances, surrender as
ordered for service of sentence, obey all conditions of any bond,
and obey any other ongoing court order in this matter.

e) Not commit any crime; however, offenses that would be
excluded for sentencing purposes under United States Sentencing
Guidelines (“U.S.S.G.” or “Sentencing Guidelines”) § 4A1.2(c) are
not within the scope of this agreement.

f) Be truthful at all times with the United States
Probation and Pretrial Services Office and the Court.

g) Pay the applicable special assessments at or before
the time of sentencing unless defendant lacks the ability to pay and
prior to sentencing submits a completed financial statement on a
form to be provided by the USAO.

h) Not bring a post-conviction collateral attack on the
convictions or sentence except a post-conviction collateral attack
based on a claim of ineffective assistance of counsel.

i) Not move to withdraw defendant's guilty pleas.
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Pase 2:25-cr-00450-CV Document156-~ Filed 06/09/25 Page3of18 Page ID #:203

5) Not file a notice of appeal, unless the term of
imprisonment imposed exceeds ten years.

THE USAO’S OBLIGATIONS

3. The USAO agrees to:
a) Not contest facts agreed to in this agreement.
b) At the time of sentencing, move to dismiss the

complaint against defendant in case no. 2:25-MJ-03132-DUTY.
Defendant understands, however, that at the time of sentencing the
Court may consider any dismissed charges in determining the
applicable Sentencing Guidelines range, the propriety and extent of
any departure from that range, and the sentence to be imposed.

Cc) Except for criminal tax violations (including
conspiracy to commit such violations chargeable under 18 U.S.C.
§ 371), not further criminally prosecute defendant for violations of
18 U.S.C. S$§ 286, 287, 1341, 1956(a), or 1957 based on facts alleged
in the above-referenced complaint or in discovery. Defendant
understands that the USAO is free to criminally prosecute defendant
for any other unlawful past conduct or any unlawful conduct that
occurs after the date of this agreement. Defendant agrees that at
the time of sentencing the Court may consider the uncharged conduct
in determining the applicable Sentencing Guidelines range, the
propriety and extent of any departure from that range, and the
sentence to be imposed after consideration of the Sentencing
Guidelines and all other relevant factors under 18 U.S.C. § 3553(a).

NATURE OF THE OFFENSES

4. Defendant understands that for defendant to be guilty of
bank fraud, in violation of Title 18, United States Code, Section

1344(2), the following must be true: First, defendant knowingly

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Pase 2:25-cr-00450-CV Document156-~ Filed 06/09/25 Page4of18 Page ID #:204

carried out a scheme or plan to obtain money or property from a
financial institution by making false statements or promises;
Second, defendant knew that the statements or promises were false;
Third, the statements or promises were material, that is, they hada
natural tendency to influence, or were capable of influencing, a
financial institution to part with money or property; Fourth, the
defendant acted with the intent to deceive and cheat; and Fifth, the
financial institution was federally insured. For defendant to be
guilty of conspiracy to commit money laundering in violation of
Title 18, United States Code, Section 1956(h), the following must be
true: First, during the time period alleged in the information there
was an agreement between two or more persons to commit money
laundering; Second, defendant became a member of the conspiracy
knowing of its object and intending to help accomplish it. The
elements of money laundering, in violation of Title 18, United
States Code, Section 1956(a)(1)(B), in turn, are as follows: First,
the defendant conducted a financial transaction involving property
that represented the proceeds of bank fraud; Second, the defendant
knew that the property represented the proceeds of some form of
unlawful activity; and Third, the defendant knew that the
transaction was designed in whole or in part to conceal or disguise
the nature, source, or control of the proceeds.

PENALTIES AND RESTITUION

5. Defendant understands that the statutory maximum sentence
that the Court can impose for a violation of Title 18, United States
Code, Section 1344(2), is: 30 years’ imprisonment; a five-year
period of supervised release; a fine of $1,000,000, or twice the

gross gain or loss, whichever is greatest; and a mandatory special

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Pase 2:25-cr-00450-CV Document156-~ Filed 06/09/25 Page5of18 Page ID #:205

assessment of $100. Defendant further understands that the
statutory maximum sentence that the Court can impose for a violation
of Title 18, United States Code, Section 1956(h), is: 20 years’
imprisonment; a five-year period of supervised release; a fine of
$500,000, or twice the value of the monetary instrument or funds
involved, whichever is greatest; and a mandatory special assessment
of $100. Therefore, the total statutory maximum sentence that the
Court can impose is: 50 years’ imprisonment; a five-year period of
supervised release; a fine of $1,500,000, or twice the gross gain or
loss or value of the monetary instrument or funds involved,
whichever is greatest; and a mandatory special assessment of $200.

6. Defendant understands that supervised release is a period
of time following imprisonment during which defendant will be
subject to various restrictions and requirements. Defendant
understands that if defendant violates one or more of the conditions
of any supervised release imposed, defendant may be returned to
prison for all or part of the term of supervised release authorized
by statute for the offense that resulted in the term of supervised
release, which could result in defendant serving a total term of
imprisonment greater than the statutory maximum stated above.

7. Defendant understands that, by pleading guilty, defendant
may be giving up valuable government benefits and valuable civic
rights, such as the right to vote, the right to possess a firearm,
the right to hold office, and the right to serve on a jury.
Defendant understands that once the court accepts defendant’s guilty
pleas, it will be a federal felony for defendant to possess a
firearm or ammunition. Defendant understands that the convictions

in this case may also subject defendant to various other collateral

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Pase 2:25-cr-00450-CV Document156~ Filed 06/09/25 Page6ofi8 Page ID #:206

consequences, including but not limited to revocation of probation,
parole, or supervised release in another case and suspension or
revocation of a professional license. Defendant understands that
unanticipated collateral consequences will not serve as grounds to
withdraw defendant’s guilty pleas.

8. Defendant and his counsel have discussed the fact that,
and defendant understands that, because defendant is not a United
States citizen, the conviction in this case makes it practically
inevitable and a virtual certainty that defendant will be removed or
deported from the United States. Defendant may also be denied
United States citizenship and admission to the United States in the
future. Defendant understands that while there may be arguments
that defendant can raise in immigration proceedings to avoid or
delay removal, removal is presumptively mandatory and a virtual
certainty in this case. Defendant further understands that removal
and immigration consequences are the subject of a separate
proceeding and that no one, including defendant’s attorney or the
Court, can predict to an absolute certainty the effect of
defendant’s conviction on defendant’s immigration status. Defendant
nevertheless affirms that defendant wants to plead guilty regardless
of any immigration consequences that this plea may entail, even if
the consequence is automatic removal from the United States.

9, Defendant understands that defendant will be required to
pay full restitution to the victims of the offenses to which
defendant is pleading guilty. Defendant agrees that, in return for
the USAO’s compliance with its obligations under this agreement, the
Court may order restitution to persons other than the victims of the

offenses to which defendant is pleading guilty and in amounts

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Pase 2:25-cr-00450-CV Document156-~ Filed 06/09/25 Page 7of18 Page ID #:207

greater than those alleged in the counts to which defendant is
pleading guilty. In particular, defendant agrees that the Court may
order restitution to any victim of any of the following for any
losses suffered by that victim as a result: (a) any relevant
conduct, as defined in U.S.S.G. § 1B1.3, in connection with the
offenses to which defendant is pleading guilty; and (b) any counts
dismissed and charges not prosecuted pursuant to this agreement as
well as all relevant conduct, as defined in U.S.S.G. § 1B1.3, in
connection with those counts and charges. The parties currently
believe that the applicable amount of restitution will be determined
at sentencing but is at least approximately $2 million, but
recognize and agree that this amount could increase based on facts
that come to the attention of the parties prior to sentencing.

FACTUAL BASIS

10. Defendant admits that defendant is, in fact, guilty of the
offenses to which defendant is agreeing to plead guilty. Defendant
and the USAO agree to the statement of facts provided below and
agree that this statement of facts is sufficient to support pleas of
guilty to the charges described in this agreement and to establish
the Sentencing Guidelines factors set forth below but is not meant
to be a complete recitation of all facts relevant to the underlying
criminal conduct or all facts known to either party that

relate to that conduct.

Bank Fraud: In January 2025, in the Central District of
California, defendant schemed with others to defraud First
Citizens Bank and Trust Co. of North Carolina (the “bank”), a
bank whose deposits were at all relevant times insured by the
Federal Deposit Insurance Corporation. Among other material
fraudulent statements and actions in furtherance of the scheme,
defendant and others created and caused to be sent or made
available to the bank a purchase agreement, tax returns, income

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Pase 2:25-cr-00450-CV Document156-~ Filed 06/09/25 Page 8of18 Page ID #:208

and expense statements, and related papers that fraudulently
represented that defendant’s (fake) business qualified to
borrow approximately $2.6 million from the bank to buy a co-
schemer’s (fake) business; and defendant made material false
statements to the bank’s underwriters during the course of
vetting the loan, including that defendant falsely stated that
his business was a going concern that had not yet taken
possession of new office space pending fumigation. In fact, as
defendant then well knew, defendant’s and a co-schemer’s
“businesses” were fake, never going concerns, and that the
purported new office space was rented solely to stage and
create the appearance that defendant’s and a co-schemer’s
businesses were genuine, which they were not.

Money Laundering: In or about October 2022, at the direction of
a co-schemer, defendant opened US Bank account ending in 1787
(the “USB 1787”) for the sole purpose of concealing and
disguising money that had been fraudulently obtained from banks
in a manner similar to the bank fraud in which defendant was
engaged, as described above, and from banks and the government
in connection with fraudulently sought Covid-19 pandemic
stimulus funding applications under the Paycheck Protection and
Economic Injury Disaster Loan programs. Between about October
24, 2022, and July 3, 2023, in the Central District of
California, defendant caused at least approximately 255
transfers of funds from and to the USB 1787, averaging $14,000
each, for a total of approximately $3,570,000, knowing such
funds were the proceeds of some form of unlawful activity and
knowing that such transfers were designed in whole or in part
to conceal or disguise the nature, source, and control of the
proceeds of bank fraud.

SENTENCING FACTORS

11. Defendant understands that in determining defendant’s
sentence the Court is required to calculate the applicable
Sentencing Guidelines range and to consider that range, possible
departures under the Sentencing Guidelines, and the other sentencing
factors set forth in 18 U.S.C. § 3553(a). Defendant understands
that the Sentencing Guidelines are advisory only, that defendant
cannot have any expectation of receiving a sentence within the

calculated Sentencing Guidelines range, and that after considering
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Pase 2:25-cr-00450-CV Document156-~ Filed 06/09/25 Page9of18 Page ID #:209

the Sentencing Guidelines and the other § 3553(a) factors, the Court
will be free to exercise its discretion to impose any sentence it
finds appropriate up to the maximum set by statute for the crimes of
conviction.

12. Defendant and the USAO agree to the following applicable

Sentencing Guidelines factors:

Base Offense Level: 8 [U.S.S.G. § 2S1.1(a) (2) ]
Value of Laundered Funds:+18 [U.S.S.G. § 2Bl.1(a) (1) (J) ]
Sophisticated Means: +2 [U.S.S.G. § 2Bl1.1(b) (11)]
Money Laundering: +2 [U.S.S.G. § 251.1 (b) (2) (B) ]

Defendant and the USAO reserve the right to argue that additional
specific offense characteristics, adjustments, and departures under
the Sentencing Guidelines are appropriate.

13. Defendant understands that there is no agreement as to
defendant’s criminal history score or category.

14. Defendant and the USAO reserve the right to argue for a
sentence outside the sentencing range established by the Sentencing
Guidelines based on the factors set forth in 18 U.S.C. § 3553(a) (1),
(a) (2), (a) (3), (a) (6), and (a) (7).

WAIVER OF CONSTITUTIONAL RIGHTS

15. Defendant understands that by pleading guilty, defendant

gives up the following rights:

a) The right to persist in a plea of not guilty.

b) The right to a speedy and public trial by jury.

c) The right to be represented by counsel - and if
necessary have the court appoint counsel - at trial. Defendant

understands, however, that, defendant retains the right to be
represented by counsel - and if necessary have the court appoint

counsel - at every other stage of the proceeding.

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Case 2:25-cr-00450-CV Document156-~ Filed 06/09/25 Page10of18 Page ID
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d) The right to be presumed innocent and to have the
burden of proof placed on the government to prove defendant guilty
beyond a reasonable doubt.

e) The right to confront and cross-examine witnesses
against defendant.

£) The right to testify and to present evidence in
opposition to the charges, including the right to compel the
attendance of witnesses to testify.

g) The right not to be compelled to testify, and, if
defendant chose not to testify or present evidence, to have that
choice not be used against defendant.

h) Any and all rights to pursue any affirmative
defenses, Fourth Amendment or Fifth Amendment claims, and other
pretrial motions that have been filed or could be filed.

LIMITED WAIVER OF DISCOVERY

16. In exchange for the government's obligations under this
agreement, defendant gives up any right he may have had to review
the discovery beyond that which he has already received.

WAIVER OF APPEAL OF CONVICTIONS

17. Defendant understands that, with the exception of an
appeal based on a claim that defendant’s guilty pleas were
involuntary, by pleading guilty defendant is waiving and giving up
any right to appeal defendant’s convictions on the offenses to which
defendant is pleading guilty.

LIMITED MUTUAL WAIVER OF APPEAL OF SENTENCE AND WAIVER OF COLLATERAL

ATTACK
18. Defendant agrees that, provided the Court imposes a term

of imprisonment of no more than ten years, defendant gives up the

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Case 2:25-cr-00450-CV Document156-~ Filed 06/09/25 Pageilof18 Page ID
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right to appeal all of the following: (a) the procedures and
calculations used to determine and impose any portion of the
sentence; (b) the term of imprisonment imposed by the Court; (c) the
fine imposed by the court, provided it is within the statutory
maximum; (d) the term of probation or supervised release imposed by
the Court, provided it is within the statutory maximum; (e) the
amount and terms of any restitution order, provided it requires
payment of no more than $5,000,000; and (f) the conditions of
probation or supervised release imposed by the Court.

19. Defendant also gives up any right to bring a post-
conviction collateral attack on the convictions or sentence,
including any order of restitution, except a post-conviction
collateral attack based on a claim of ineffective assistance of
counsel, a claim of newly discovered evidence, or an explicitly
retroactive change in the applicable Sentencing Guidelines,
sentencing statutes, or statutes of conviction.

20. The USAO gives up its right to appeal any portion of the
sentence.

RESULT OF WITHDRAWAL OF GUILTY PLEA

21. Defendant agrees that if, after entering guilty pleas
pursuant to this agreement, defendant seeks to withdraw and succeeds
in withdrawing defendant’s guilty pleas on any basis other than a
claim and finding that entry into this plea agreement was
involuntary, then (a) the USAO will be relieved of all of its
obligations under this agreement; and (b) should the USAO choose to
pursue any charge that was either dismissed or not filed as a result
of this agreement, then (i) any applicable statute of limitations

will be tolled between the date of defendant’s signing of this

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Case 2:25-cr-00450-CV Document156-~ Filed 06/09/25 Page12of18 Page !D
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agreement and the filing commencing any such action; and

(ii) defendant waives and gives up all defenses based on the statute
of limitations, any claim of pre-indictment delay, or any speedy
trial claim with respect to any such action, except to the extent
that such defenses existed as of the date of defendant’s signing
this agreement.

BRFFECTIVE DATE OF AGREEMENT

22. This agreement is effective upon signature and execution
of all required certifications by defendant, defendant’s counsel,
and an Assistant United States Attorney.

BREACH OF AGREEMENT

23. Defendant agrees that if defendant, at any time after the
effective date, knowingly violates or fails to perform any of
defendant’s obligations under this agreement (“a breach”), the USAO
may declare this agreement breached. All of defendant’s obligations
are material, a single breach of this agreement is sufficient for
the USAO to declare a breach, and defendant shall not be deemed to
have cured a breach without the express agreement of the USAO in
writing. If the USAO declares this agreement breached, and the
Court finds such a breach to have occurred, then: (a) if defendant
has previously entered guilty pleas pursuant to this agreement,
defendant will not be able to withdraw the guilty pleas, (b) the
USAO will be relieved of all its obligations under this agreement,
and (c) defendant will still be bound by defendant’s obligations
under this agreement.

24. Following the Court’s finding of a knowing breach of this

agreement by defendant, should the USAO choose to pursue any charge

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that was either dismissed or not filed as a result of this
agreement, then:

a) Defendant agrees that any applicable statute of
limitations is tolled between the date of defendant’s signing of
this agreement and the filing commencing any such action.

b) Defendant waives and gives up all defenses based on
the statute of limitations, any claim of pre-indictment delay, or
any speedy trial claim with respect to any such action, except to
the extent that such defenses existed as of the date of defendant’s
Signing this agreement.

Cc) Defendant agrees that: (i) any statements made by
defendant, under oath, at the guilty plea hearing (if such a hearing
occurred prior to the breach); (ii) the agreed to factual basis
statement in this agreement; and (iii) any evidence derived from
such statements, shall be admissible against defendant in any such
action against defendant, and defendant waives and gives up any
claim under the United States Constitution, any statute, Rule 410 of
the Federal Rules of Evidence, Rule 11(f) of the Federal Rules of
Criminal Procedure, or any other federal rule, that the statements
or any evidence derived from the statements should be suppressed or
are inadmissible.

COURT AND PROBATION AND PRETRIAL SERVICES OFFICE NOT PARTIES

25. Defendant understands that the Court and the United States
Probation and Pretrial Services Office are not parties to this
agreement and need not accept any of the USAO’s sentencing
recommendations or the parties’ agreements to facts or sentencing

factors.

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Case 2:25-cr-00450-CV Document156- Filed 06/09/25 Page14of18 Page ID
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26. Defendant understands that both defendant and the USAO are
free to: (a) supplement the facts by supplying relevant information
to the United States Probation and Pretrial Services Office and the
Court, (b) correct any and all factual misstatements relating to the
Court’s Sentencing Guidelines calculations and determination of
sentence, and (c) argue on appeal and collateral review that the
Court’s Sentencing Guidelines calculations and the sentence it
chooses to impose are not error, although each party agrees to
maintain its view that the calculations in the plea agreement are
consistent with the facts of this case. While this paragraph
permits both the USAO and defendant to submit full and complete
factual information to the United States Probation and Pretrial
Services Office and the Court, even if that factual information may
be viewed as inconsistent with the facts agreed to in this
agreement, this paragraph does not affect defendant’s and the USAO’s
obligations not to contest the facts agreed to in this agreement.

27. Defendant understands that even if the Court ignores any
sentencing recommendation, finds facts or reaches conclusions
different from those agreed to, and/or imposes any sentence up to
the maximum established by statute, defendant cannot, for that
reason, withdraw defendant’s guilty pleas, and defendant will remain
bound to fulfill all defendant’s obligations under this agreement.
Defendant understands that no one -—- not the prosecutor, defendant’s
attorney, or the Court -- can make a binding prediction or promise
regarding the sentence defendant will receive, except that it will

be within the statutory maximum.

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NO ADDITIONAL AGREEMENTS

28. Defendant understands that, except as set forth herein,
there are no promises, understandings, or agreements between the
USAO and defendant or defendant’s attorney, and that no additional
promise, understanding, or agreement may be entered into unless in a
writing signed by all parties or on the record in court.

PLEA AGREEMENT PART OF THE GUILTY PLEA HEARING

29. The parties agree that this agreement will be considered
part of the record of defendant’s guilty plea hearing as if the

entire agreement had been read into the record of the proceeding.

AGREED AND ACCEPTED

UNITED STATES ATTORNEY’S OFFICE
FOR THE CENTRAL DISTRICT OF CALIFORNIA

BILAL A. ESSAYLI
United States Attorney

Mark Avey June 4, 2025
MARK AVEIS Date
Assistant/United tes Attorney
June 5, 2025

ASHOT BEJANYAN, aka Alex Benjamin Date
Defendant

award ebineen June 5, 2025
EDWARD ROBINSON Date

Attorney for Defendant
ASHOT BEJANYAN, aka Alex Benjamin

CERTIFICATION OF DEFENDANT

This agreement has been read to me in Armenian, the language I
understand best. I have had enough time to review and consider this
agreement, and I have carefully and thoroughly discussed every part

of it with my attorney. I understand the terms of this agreement,

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Case 2:25-cr-00450-CV Document156-~ Filed 06/09/25 Page1i6of18 Page !D
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and I voluntarily agree to those terms. I have discussed the
evidence with my attorney, and my attorney has advised me of my
rights, of possible pretrial motions that might be filed, of
possible defenses that might be asserted either prior to or at
trial, of the sentencing factors set forth in 18 U.S.C. § 3553(a),
of relevant Sentencing Guidelines provisions, and of the
consequences of entering into this agreement. No promises,
inducements, or representations of any kind have been made to me
other than those contained in this agreement. No one has threatened
or forced me in any way to enter into this agreement. I am
satisfied with the representation of my attorney in this matter, and
I am pleading guilty because I am guilty of the charges and wish to
take advantage of the promises set forth in this agreement, and not

for any other reason.

(
/

(J f June 5, 2025
ASHOT BEJANYAN, aka Alex Benjamin Date
Defendant

CERTIFICATION OF INTERPRETER

I, , am fluent in the written and spoken English

and Armenian languages. I accurately translated this entire
agreement from English into Armenian to defendant Ashot Bejanyan on

this date.

INTERPRETER Date

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#:217
and I voluntarily agree to those terms. I have discussed the
evidence with my attorney, and my attorney has advised me of my
rights, of possible pretrial motions that might be filed, of
possible defenses that might be asserted either prior to or at
trial, of the sentencing factors set forth in 18 U.S.C. § 3553(a),
of relevant Sentencing Guidelines provisions, and of the
consequences of entering into this agreement. No promises,
inducements, or representations of any kind have been made to me
other than those contained in this agreement. No one has threatened
or forced me in any way to enter into this agreement. I am
satisfied with the representation of my attorney in this matter, and
I am pleading guilty because I am guilty of the charges and wish to
take advantage of the promises set forth in this agreement, and not

for any other reason.

ASHOT BEJANYAN, aka Alex Benjamin Date
Defendant

CERTIFICATION OF INTERPRETER

lL ffac Ainity dev am fluent in the written and spoken English

and Armenian languages. I accurately translated this entire

agreement from English into Armenian to defendant Ashot Bejanyan on

this date.

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#:218

CERTIFICATION OF DEFENDANT’S ATTORNEY

I am ASHOT BEJANYAN’s attorney. I have carefully and
thoroughly discussed every part of this agreement with my client.
Further, I have fully advised my client of my client’s rights, of
possible pretrial motions that might be filed, of possible defenses
that might be asserted either prior to or at trial, of the
sentencing factors set forth in 18 U.S.C. § 3553(a), of relevant
Sentencing Guidelines provisions, and of the consequences of
entering into this agreement. To my knowledge: no promises,
inducements, or representations of any kind have been made to my
client other than those contained in this agreement; no one has
threatened or forced my client in any way to enter into this
agreement; my client’s decision to enter into this agreement is an
informed and voluntary one; and the factual basis set forth in this
agreement is sufficient to support my client’s entry of guilty

pleas pursuant to this agreement.

Caward ebaaeonr June 5, 2025

EDWARD ROBINSON Date
Attorney for Defendant
ASHOT BEJANYAN, aka Alex Benjamin

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