United States v. Arsen Terzyan — Plea Agreement, Central District of California (Document 95)

Summary

The plea agreement between Arsen Terzyan, aka Steven Terzaki, and the United States Attorney's Office for the Central District of California in United States v. Terzyan, No. CR 25-456-MWC, filed January 30, 2026 as Document 95. The defendant agrees to plead guilty to counts one and seven, wire fraud under 18 U.S.C. § 1343, and count eight, transactional money laundering under 18 U.S.C. § 1957, and the parties agree that restitution of $1,166,670 is due to the U.S. Small Business Administration. The parties stipulate to a total offense level of 22, including a sophisticated means enhancement. In the factual basis the defendant admits that SBA wired $1,864,830 in Grub House RRF proceeds to the JPMC 3502 account and that the defendant misused $1,023,308 of it, including $505,889 to establish a marijuana grow business.

Summary drafted by a model from the text of the original file linked on this page and checked by script against that text before publication. It is a navigation aid, not a reading of what the document proves. Where AI is used

Full text

Text recognized from a scanned document; may contain errors.

Ca

10
12
13
14
16
17
18
19
20
21
22
23
24
25
26
27

28

TODD BLANCHE
Deputy Attorney General
BILAL A. ESSAYLI
First Assistant United States Attorney
ALEXANDER B. SCHWAB
Assistant United States Attorney
Acting Chief, Criminal Division
MARK AVEIS (Cal. Bar No. 107881)
Assistant United States Attorney
Major Frauds Section
1100 United States Courthouse
312 North Spring Street
Los Angeles, California 90012
Telephone: (213) 894-4477
Facsimile: (213) 894-0141
E-mail: mark.aveis@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 25-456-MWC

Plaintiff, PLEA AGREEMENT FOR DEFENDANT
ARSEN TERZYAN

ARSEN TERZYAN, aka Steven
Terzaki,

Defendant.

iL This constitutes the plea agreement between DEFENDANT ARSEN
TERZYAN, aka “Steven Terzaki,” (“defendant”) and the United States
Attorney’s Office for the Central District of California (the “USAO”)
in the above-captioned case. This agreement is limited to the USAO
and cannot bind any other federal, state, local, or foreign
prosecuting, enforcement, administrative, or regulatory authorities.

2s Defendant agrees to:
10
12
L3
14
15
16
17
18
19
20
21
22
23
24
29
26
27

28

eb)

Se 2:25-cr-00456-MWC Document95_ Filed 01/30/26 Page2of26 Page ID #:278

a. At the earliest opportunity requested by the USAO and
provided by the Court, appear and plead guilty to counts one, seven,
and eight of the indictment in United States v. Arsen Terzyan, CR No.
25-456-MWC, which charges defendant, in counts one and seven, with
wire fraud in violation of 18 U.S.C. § 1343, and, in count eight,
with transactional money laundering in violation of 18 U.S.C. § 1957.

b. Not contest facts agreed to in this agreement.

on 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.

cle Pay the applicable special assessments at or before
the time of sentencing unless defendant has demonstrated a lack of
ability to pay such assessments.

RESTITUTION

35 Defendant agrees that any and all criminal debt ordered by
the Court will be due in full and immediately. The government is not

precluded from pursuing, in excess of any payment schedule set by the

Court, any and all available remedies by which to satisfy defendant’s
payment of the full financial obligation, including referral to the

Treasury Offset Program.
Ca

10
12
13
14
16
17
18
19
20
21
22
23
24
25
26
27

28

se 2:25-cr-00456-MWC Document 95 Filed 01/30/26 Page3of26 Page ID #:279

4. Defendant further agrees to:

a. Complete the Financial Disclosure Statement on a form
provided by the USAO and, within 30 days of defendant’s entry of a
guilty plea, deliver the signed and dated statement, along with all
of the documents requested therein, to the USAO by either email at
usacac.FinLit@usdoj.gov (preferred) or mail to the USAO Financial
Litigation Section at 300 North Los Angeles Street, Suite 7516, Los
Angeles, CA 90012. Defendant agrees that defendant’s ability to pay
criminal debt shall be assessed based on the completed Financial
Disclosure Statement and all required supporting documents, as well
as other relevant information relating to ability to pay.

b. Authorize the USAO to obtain a credit report upon
returning a signed copy of this plea agreement.
Consent to the USAO inspecting and copying all of defendant’s
financial documents and financial information held by the United
States Probation and Pretrial Services Office.

THE USAO’S OBLIGATIONS

5. The USAO agrees to:
a. Not contest facts agreed to in this agreement.
bie Abide by all agreements regarding sentencing contained

in this agreement.

Cx At the time of sentencing, move to dismiss the
remaining counts of the indictment and all counts against defendant
in the complaint in 25-MJ-3138-DUTY as against defendant. Defendant
agrees, however, that at the time of sentencing the Court may
consider any dismissed charge(s) in determining the applicable
Sentencing Guidelines range, the propriety and extent of any
departure from that range, and the sentence to be imposed.

2
Ca

10
12
14
15
16
17
18
L9
20
22
23
24
25
26
27

28

Se 2:25-cr-00456-MWC Document95_ Filed 01/30/26 Page4of26 Page ID #:280

d. At the time of sentencing, provided that defendant
demonstrates an acceptance of responsibility for the offenses up to
and including the time of sentencing, recommend a two-level reduction
in the applicable Sentencing Guidelines offense level, pursuant to
U.S.S.G. § 3E1.1, and recommend and, if necessary, move for an
additional one-level reduction if available under that section.

NATURE OF THE OFFENSES

6. Defendant understands that for defendant to be guilty of
the crime charged in counts one and seven of the indictment, that is,
wire fraud, in violation of Title 18, United States Code, Section
1343, the following must be true: (1) defendant knowingly
participated in or devised a scheme or plan to defraud, or a scheme
or plan for obtaining money or property by means of false or
fraudulent pretenses, representations, or promises; (2) the
statements made as part of the scheme were material; that is, they
had a natural tendency to influence, or were capable of influencing,
a person to part with money or property; (3) defendant acted with the
intent to defraud, that is, the intent to deceive and cheat; and (4)
defendant used, or caused to be used, an interstate wire
communication to carry out or attempt to carry out an essential part
of the scheme. Defendant understands that for defendant to be guilty
of the crime charged in count eight of the indictment, that is,
transactional money laundering, in violation of Title 18, United
States Code, Section 1957, the following must be true: (1) defendant
knowingly engaged or attempted to engage in a monetary transaction;
(2) defendant knew the transaction involved criminally derived
property; (3) the property had a value greater than $10,000; (4) the
property was, in fact, derived from the mail and wire fraud scheme

4
10
11
12
13
14
16
17
18
19
20
21
22
23
24
25
26
27

28

Leb)

se 2:25-cr-00456-MWC Document 95 Filed 01/30/26 Page5of26 Page ID #:281

alleged in the indictment; and (5) the transaction occurred in the
United States.

PENALTIES AND RESTITUTION

ts Defendant understands that the statutory maximum sentence
that the Court can impose for a violation of Title 18, United States
Code, Section 1343, is: twenty years’ imprisonment; a five-year
period of supervised release; a fine of $250,000 or twice the gross
gain or gross loss resulting from the offense, whichever is greatest;
and a mandatory special assessment of $100. Defendant understands
that the statutory maximum sentence that the Court can impose for a
violation of Title 18, United States Code, Section 1957, is: ten
years’ imprisonment; a five-year period of supervised release; a fine
of $250,000 or twice the amount of the criminally derived property
involved in the transaction, whichever is greatest; and a mandatory
special assessment of $100. Defendant understands that, therefore,
the total statutory maximum sentence that the Court can impose in
this case is: fifty years’ imprisonment; a five-year period of
supervised release; a fine of $750,000 or twice the gross gain or
gross loss resulting from the offense, or twice the amount of the
criminally derived property involved in the transaction, whichever is
greatest; and a mandatory special assessment of $300.

8. 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 United States’ 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 greater than those alleged in the counts to which defendant

5
10
11
12
13
14
16
17
18
19
20
21
22
23
24
25
26
27

28

Case 2:25-cr-00456-MWC Document95_ Filed 01/30/26 Page6of26 Page ID #:282

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 offense to
which defendant is pleading guilty; and (b) any counts dismissed
pursuant to this agreement as well as all relevant conduct, as
defined in U.S.S.G. § 1B1.3, in connection with those counts. The
parties agree that the total amount of restitution due is $1,166,670,
payable to the U.S. Small Business Administration.

9. 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.

10. 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 he is pleading guilty to felonies and that
it is a federal crime for a convicted felon to possess a firearm or
ammunition. Defendant understands that the convictions in this case
may also subject defendant to various other collateral consequences,
including but not limited to revocation of probation, parole, or
supervised release in another case and suspension or revocation of a

6
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27

28

fab}

se 2:25-cr-00456-MWC Document 95 Filed 01/30/26 Page7of26 Page ID #:283

professional license. Defendant understands that unanticipated
collateral consequences will not serve as grounds to withdraw
defendant’s guilty pleas.

11. Defendant and his counsel have discussed the fact that,
and defendant understands that, if defendant is not a United States
citizen, the convictions in this case, or any one of them, make 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 his attorney or the Court, can
predict to an absolute certainty the effect of his convictions on his
immigration status. Defendant nevertheless affirms that he wants to
plead guilty regardless of any immigration consequences that his
pleas may entail, even if the consequence is automatic removal from
the United States.

FACTUAL BASIS

Lis 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 in Exhibit A
attached hereto and incorporated herein by this reference, 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 in paragraph 14 below but is

7
10
12
13
14
15
16
17
18
19
20
21
ne
23
24
25
26
27

28

eb)

Se 2:25-cr-00456-MWC Document95_ Filed 01/30/26 Page8of26 Page ID #:284

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.

SENTENCING FACTORS

13. 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 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.

14. Defendant and the USAO agree to the following applicable
Sentencing Guidelines factors:

Base Offense Level: 7 [U.S.S.G. § 2Bl1.1(a)]

Specific Offense
Characteristics (loss between

$$550K and $1.5MM): 14 [U.S.S.G. § 2B1.1(b) (1) (H)]
Money Laundering: 2 [U.S.S.G. § 2581.1 (b) (2) (A) ]
Sophisticated Means 2 [U.S.S.G. § 2B1.1(b) (10) ]
Acceptance of Responsibility -3 [U.S.S.G. § 3E1.1]
Total Offense Level 22

The USAO will agree to a two-level downward adjustment for acceptance

of responsibility (and, if applicable, move for an additional one-
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27

28

level downward adjustment under U.S.S.G. § 3E1.1(b)) only if the
conditions set forth in paragraph 2 are met and if defendant has not
committed, and refrains from committing, acts constituting
obstruction of justice within the meaning of U.S.S.G. § 3C1.1, as
discussed below. Subject to paragraph 28 below, defendant and the
USAO agree not to seek, argue, or suggest in any way, either orally
or in writing, that any other specific offense characteristics,
adjustments, or departures relating to the offense level be imposed.
Defendant agrees, however, that if, after signing this agreement but
prior to sentencing, defendant were to commit an act, or the USAO
were to discover a previously undiscovered act committed by defendant
prior to signing this agreement, which act, in the judgment of the
USAO, constituted obstruction of justice within the meaning of
U.S.S.G. § 3C1.1, the USAO would be free to seek the enhancement set
forth in that section and to argue that defendant is not entitled to
a downward adjustment for acceptance of responsibility under U.S.S.G.
§ 3El.1.

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

16. 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

AT Defendant understands that by pleading guilty, defendant
gives up the following rights:
a. The right to persist in a plea of not guilty.
bi. The right to a speedy and public trial by jury.

9
10
LL
12
13
14
15
16
17
18
19
20
2:1.
22
23
24
25
26
27

28

Case 2:25-cr-00456-MWC Document95_ Filed 01/30/26 Page 10of26 Page ID

#:286
on 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.
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.

Lia 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.

Ag 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.

WAIVER OF APPEAL OF CONVICTIONS

18. 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. Defendant understands that this waiver
includes, but is not limited to, arguments that the statutes to which

defendant is pleading guilty are unconstitutional, and any and all

10
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
29
26
27

28

Case 2:25-cr-00456-MWC Document 95 Filed 01/30/26 Page1iof26 PageID
#:287

Claims that the statement of facts provided herein is insufficient to
support defendant’s pleas of guilty.

LIMITED MUTUAL WAIVER OF APPEAL OF SENTENCE

19. Defendant agrees that, provided the Court imposes a total
term of imprisonment on all counts of conviction of not more than the
statutory maximum, defendant gives up the 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) to the extent permitted by law,
the constitutionality or legality of defendant’s sentence, provided
it is within the statutory maximum; (e) the amount and terms of any
restitution order; (f) the term of probation or supervised release
imposed by the Court, provided it is within the statutory maximum;
and (g) any of the following conditions of probation or supervised
release imposed by the Court: the conditions set forth in Second
Amended General Order 20-04 of this Court; and the drug testing
conditions mandated by 18 U.S.C. §§ 3563(a) (5) and 3583(d).

20. The USAO agrees that, provided all portions of the
sentence are at or below the statutory maximum specified above, the
USAO gives up its right to appeal any portion of the sentence.

WAIVER OF RIGHTS CONCERNING PLEA COLLOQUY AND FACTUAL BASIS

21% Defendant agrees that: (i) any statements made by
defendant, under oath, at the guilty plea hearing; (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 action against defendant, and defendant waives and gives up
any claim under the United States Constitution, any statute, Rule 410

11
10
11
12
13
14
15
16
La
18
19
20
21
22
23
24
25
26
27

28

Case 2:25-cr-00456-MWC Document95_ Filed 01/30/26 Page 12of26 Page ID
#:288

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.

Defendant further agrees that this paragraph of the agreement is
severable. Thus, defendant’s waivers are binding and effective even
if, subsequent to defendant’s signing this agreement, defendant
declines to plead guilty, the Court declines to accept his guilty
plea, or, if this agreement is of the type described in Federal Rule
of Criminal Procedure 11(c) (1) (A) or (c) (1) (C), the Court rejects
this agreement. Defendant also agrees that his waivers are binding
and effective even if some other portion of this agreement is found
to be invalid by this Court or the Ninth Circuit.

RESULT OF WITHDRAWAL OF GUILTY PLEA

22 3 Defendant agrees that if, after entering a guilty plea or
pleas pursuant to this agreement, defendant seeks to withdraw and
succeeds in withdrawing defendant’s guilty plea or 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
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

12
10
13
14
LS
18
19
20
22
23
24
25
26
27

28

Case 2:25-cr-00456-MWC Document 95 Filed 01/30/26 Page13o0f26 PageID

#:289

that such defenses existed as of the date of defendant’s signing this
agreement.

RESULT OF VACATUR, REVERSAL, OR SET-ASIDE

23 x Defendant agrees that if any count of conviction is
vacated, reversed, or set aside the USAO may: (a) ask the Court to
resentence defendant on any remaining counts of conviction, with both
the USAO and defendant being released from any stipulations regarding
sentencing contained in this agreement, (b) ask the Court to void the
entire plea agreement and vacate defendant’s guilty pleas on any
remaining counts of conviction, with both the USAO and defendant
being released from all their obligations under this agreement, or
(c) leave defendant’s remaining convictions, sentence, and plea
agreement intact. Defendant agrees that the choice among these three
options rests in the exclusive discretion of the USAO.

EFFECTIVE DATE OF AGREEMENT

24. 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

25. Defendant agrees that if defendant, at any time after the
effective date of this agreement, 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

13
10
11
12
13
14
Lo
16
17
18
19
20
21
22
23
24
20
26
27

28

Case 2:25-cr-00456-MWC Document95_ Filed 01/30/26 Page 14of26 Page ID
#:290

occurred, then: (a) if defendant has previously entered guilty pleas
pursuant to this agreement, defendant will not be able to withdraw
the guilty pleas, and (b) the USAO will be relieved of all its
obligations under this agreement.

26. Following the Court’s finding of a knowing breach of this
agreement by defendant, should the USAO choose to pursue any charge
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; and

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.

COURT AND UNITED STATES PROBATION AND PRETRIAL SERVICES

OFFICE NOT PARTIES

21 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.

28. 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

14
10
11
12
13
14
LS
16
18
19
20
21
22
23
24
25
26
27

28

pase 2:25-cr-00456-MWC Document95_ Filed 01/30/26 Page 15of26 Page ID
#:291

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 paragraph 14 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.

29. 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.

NO ADDITIONAL AGREEMENTS

30. 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 ina

writing signed by all parties or on the record in court.

15
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27

28

(ase 2:25-cr-00456-MWC Document 95 _ Filed 01/30/26 Page1i6of26 PageID

#:292

PLEA AGREEMENT PART OF THE GUILTY PLEA HEARING

i 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
TODD BLANCHE
Deputy Attorney General

BILAL A. ESSAYLI
First Assistant United States

Attorney
Wark v0 January 30, 2026
MARK AVEIS Date
Assistant eee Attorney
PO _ fo

ARSEN TERZYAN, aka Steven Terzaki Date
Defendafit

ANNA Date
Attor forxDefendant ARSEN
TERZYAN

CERTIFICATION OF DEFENDANT

I have read this agreement in its entirety. 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, 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

16
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27

28

Case 2:25-cr-00456-MWC Document95_ Filed 01/30/26 Page17of26 Page ID
#:293

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. we

LO \-30—20%

ARSEN TERZYAN, aka Steven Terzaki Date
Defendant

CERTIFICATION OF DEFENDANT’ S ATTORNEY

I am ARSEN TERZYAN’s attorney. I have carefully and thoroughly
discussed every part of this agreement with my client. Further, I
have fully advised my client of his 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 plea ursuant to this agreement.

ANNA O Date

17
10
11
12
LS
14
15
16
17
18
19
20
21
22
23
24
25
26
27

28

Case 2:25-cr-00456-MWC Document 95

#:294

Attorney for Defendant ARSEN
TERZYAN

18

|- 30-206
10
12
is
14
15
16
17
18
19
20
21
22
23
24
25
26
27

28

#:295

EXHIBIT A (Stipulated Factual Basis)

The parties agree that the following stipulated factual basis
meets the requirements of Fed.R.Crim.P. 11(b) (3).

At all relevant times:

Defendant was a resident of Los Angeles County, California, in
the Central District of California, a location in which he performed
all of the acts described below.

All funds that were transferred for the benefit of defendant
involved the deposit, withdrawal, transfer, or exchange by, through,
or to a financial institution engaged in interstate commerce and
located in the Central District of California.

COVID-19 Pandemic Stimulus Funds

The Coronavirus Aid, Relief, and Economic Security (“CARES”) Act
was a federal law enacted in or about March 2020 that was designed to
provide emergency financial assistance to Americans suffering
economic harm as a result of the COVID-19 pandemic (the “pandemic”).
The CARES Act authorized taxpayer funds under the Economic Injury
Disaster Loan program (individually, an “EIDL,” or collectively,
“EIDLs”). The EIDL program provided low-interest funding to small
businesses, renters, and homeowners affected by the pandemic.

In order to obtain an EIDL, a qualifying business was required
to submit an application to the United States Small Business
Administration (“SBA”), typically through an online portal, and
provide information about its operations, such as the nature of the
applicant’s business, the number of its employees, and gross revenues
for the 12-month period preceding the pandemic. EIDL applicants were

required to certify that all information in the application as

19
10
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27

28

(Case 2:25-cr-00456-MWC Document95_ Filed 01/30/26 Page 20o0f26 Page ID

#:296

provided by the applicant or on behalf of the applicant by their
authorized representative was true and correct.

An applicant’s representative was required to sign an EIDL “Loan
Authorization and Agreement” (“LA&A”) as a condition of receipt of
EIDL proceeds. The LA&A required that the applicant use the EIDL
proceeds only for purposes stated in EIDL rules, such as for employee
payroll expenses, employee sick leave, and business obligations and
expenses such as business debts, rent, and mortgage payments. EIDL
funds could not be used other than for those purposes, including that
such funds could not be deposited or held for future business
operations, used to capitalize a new business or for business start-
up expenses, or used for purposes not associated with the operation
of the specified going concern.

The amount of an EIDL was determined, in part, by the
applicant’s representations in the EIDL application about the nature
of the applicant’s business and the applicant’s statements about
employees, and revenue.

Any funds paid under an EIDL were issued directly by the SBA
from CARES Act appropriations by Congress, the source of which were
taxpayer funds.

EIDL applicants were also obligated to provide true and correct
information in response to requests by the SBA as part of the EIDL
vetting process, such as requests to clarify business ownership and
requests to provide genuine payroll tax documents including genuine
federal income tax returns.

///
///
20
10
Lal.
iz
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27

28

pase 2:25-cr-00456-MWC Document95_ Filed 01/30/26 Page 21of26 Page ID
#:297

EIDL Fraud and Transactional Money Laundering (Counts One and

Eight)

On January 30, 2021, defendant submitted, online via a wire
communication that traveled in interstate commerce, an application to
the SBA for a $150,000 EIDL on behalf of “Grub House, Inc.” (“Grub
House” or the “Grub House EIDL”). Grub House was a purported
restaurant or food service business wholly owned by defendant, and
defendant was the sole signer on its business bank account at
JPMorgan Chase Bank (“JPMC”,) account ending in 3502 (the “JPMC
3502”). In the Grub House EIDL application, defendant falsely
represented that Grub House’s revenue for the 12 months preceding
January 31, 2020, was $433,441. As defendant then well knew, Grub
House’s revenue for that period was not more than $50,000. Defendant
further then well knew that the amount of the EIDL was tied to the
revenue amount that he had misrepresented and that the amount of the
EIDL would have been substantially less, if approved at all, had
defendant truthfully represented Grub House’s revenue for that
period.

In March 2021, defendant e-signed the standard form EIDL LA&A on
behalf of Grub House in which he promised that “[Grub House] will use
all the proceeds of this Loan solely as working capital to alleviate
economic injury caused by disaster occurring in the month of January
31, 2020 and continuing thereafter[.]” At the time that defendant
applied for the Grub House EIDL and signed the LA&A, defendant
intended to use the Grub House EIDL proceeds for impermissible
purposes, including for his personal use and to fund a marijuana grow

business.

21
10
11
12
14
16
17
18
19
20
21
22
23
24
25
26
27

28

#:298

Defendant designated on the Grub House EIDL application the JPMC
3502, an account held at a JPMC branch in the Central District of
California and solely controlled by defendant, as the bank account
into which the Grub House EIDL proceeds should be wire-transferred.
On April 2, 2021, in reliance on defendant’s misrepresentations
described above, which misrepresentations defendant admits were
material to SBA’s decision to approve the Grub House EIDL, the SBA
approved the Grub House EIDL application and caused proceeds of
$149,900 (net of fees) to be wire-transferred from the SBA to the
JPMC 3502.

The balance in the JPMC 3502 before the deposit of the Grub
House BIDL proceeds was $1,361. Defendant admits that he spent
substantially all of the Grub House EIDL proceeds within 30 days of
receipt and substantially none of those funds was used for a
permissible purpose as required under EIDL rules and the Grub House
EIDL LA&A that defendant had signed. By way of example, defendant
admits that he fraudulently misused $143,362 of the $149,900 Grub

House EIDL proceeds for at least the following impermissible

purposes:
Date/Date Range Amount Payee
April 2, 2021 $8,500.00 Defendant
April 2, 2021 $9,892.00 Defendant
April 1 -— April 3, 2021 $50,000 “No Limit Cargo”
April 6, 2021 $24,970 Humboldt Wholesale
April 6 - April 9, 2021 $17,700.00 A.G.
April 7, 2021 $9,150.00 “Home Energy Rating”
April 7, 2021 $9,150.00 “Hers Raters”

22
10
11
12
14
5
16
17
18
19
20
21
22
23
24
25
26
27

28

#:299

April 14, 2021 $14,000.00 Marianna Sarkisyan!

As to the April 6, 2021 check for $24,970, to Humboldt
Wholesale, defendant admits as sock check was a monetary
transaction, in and affecting interstate commerce, whose source was
wire fraud as alleged in counts one through seven, inclusive, of the
indictment and as described herein.

Defendant further admits that he “structured” the amounts of

those above-described transfers of under $10,000 for the purpose of

evading reporting requirements to the Internal Revenue Service.

In April 2021, Terzyan submitted an application to modify and
increase the Grub House EIDL by approximately $350,000, to total
$500,000. To satisfy SBA’s requirement that defendant provide
genuine and accurate tax returns for Grub House to justify the EIDL
modification, defendant caused accountant L.F. to prepare, and
defendant caused to be filed, fraudulent tax returns for Grub House
that falsely reported Grub House’s revenue.

Grub House RRF Fraud (Count Seven)

In March 2021, the American Rescue Plan Act became law and
established the Restaurant Revitalization Fund (“RRF”) for which
Congress appropriated taxpayer funds for the SBA to award emergency
assistance to qualifying businesses that served food or drink, to
include catering businesses and restaurants. Entitlement was
substantially based on pandemic-caused revenue loss. The RRF was a

conditional grant program, meaning that RRF recipients were not

1 Marianna Sarkisyan was defendant’s sister-in-law and is a co-
defendant, charged with pandemic stimulus wire fraud in case no. 25-
MJ-3138-DUTY now pending in this district.

23
10
12
13
14
15
16
17
18
19
20
21
22
24
25
26
27

28

f-ase 2:25-cr-00456-MWC Document95_ Filed 01/30/26 Page 24o0f26 Page ID

#:300

required to repay the funds so long as those funds were used for
specific expenses and by a certain deadline.

RRF applicants submitted personal and business information,
typically through an online SBA portal, in support of each RRF
application. RRF recipients were required to certify that they would
use RRF proceeds for normal business operations such as for payroll
costs, health care, business mortgages or rent. Recipients were then
required to submit a “post-award report” in which they certified that
their RRF proceeds had actually been used in compliance with the
program.

On May 11, 2021, defendant submitted, online, an application to
the SBA for an RRF on behalf of Grub House (the “Grub House RRF”).
Defendant identified himself as Grub House’s “100%” owner. Defendant
falsely claimed that Grub House’s 2019 calendar year gross receipts
were $1,423,441, or approximately one million dollars more than
defendant had four months earlier claimed (also falsely) on the Grub
House EIDL application for the same period.

Defendant also falsely represented on the Grub House RRF
application that RRF proceeds would be used solely for Grub House’s
business expenses such as payroll costs, rent, utilities, food and
beverage purchases, construction of outdoor seating, supplies, and
other permissible operating expenses. At the time that defendant
submitted the Grub House RRF application, defendant intended to use
the RRF proceeds for impermissible purposes, including as seed
capital for a marijuana grow business.

The SBA prioritized RRF awards to small businesses at
least 51% owned and controlled by women, veterans, and/or the
socially and economically disadvantaged.

24
10
12
14
1.5
16
17
18
19
20
21
22
23
24
25
26
27

28

Case 2:25-cr-00456-MWC Document95_ Filed 01/30/26 Page 25of26 Page ID

#:301

Defendant further admits that he knowingly misrepresented on the
Grub House RRF application that Grub House was at least 51 percent
owned and controlled by “[a] socially and economically disadvantaged
individual[]” in order to qualify for the Grub House RRF. Defendant
admits that he then well knew that he was not a “socially [or]
economically disadvantaged individual” under RRF rules.

On May 28, 2021, in reliance on defendant’s misrepresentations,
which misrepresentations defendant admits were material, the SBA
approved the Grub House RRF application and wire-transferred proceeds
of $1,864,830 to the JPMC 3502 in interstate commerce. The balance
in the account was $524 before the RRF proceeds were deposited.
Defendant admits that he paid out substantially all of the Grub House
RRF proceeds within about three months of the proceeds’ deposit and
that substantially none of those payments was for a permissible
purpose under RRF rules or the Grub House RRF application. Defendant
admits that he fraudulently misused $1,023,308 of the $1,864,830 in
Grub House RRF proceeds including $505,889 to establish a marijuana
grow business.

RRF recipients were required to certify that RRF proceeds were
used in compliance with RRF rules. Such compliance was required via
a “post-award report.” Acknowledging on the post-award report that
“[a]ny false statement or misrepresentation to SBA may result in
criminal, civil or administrative sanctions including, but not
limited to, [] fines and imprisonment[,]” defendant electronically
signed and submitted that report in December 2021 and falsely
represented that all of the Grub House RRF proceeds were used for

Grub House business expenses, including, for example, that defendant

25
10
11
12
13
14
L5
16
17
18
19
20
21
22
23
24
25
26
27

28

(Case 2:25-cr-00456-MWC Document95_ Filed 01/30/26 Page 26o0f26 Page ID
#:302

had used more than $500,000 for a marijuana grow business that was
unrelated to Grub House.

Defendant agrees that, for the purpose of establishing his
stipulated Sentencing Guidelines loss in paragraph 14 of this plea
agreement, the aggregate actual loss that defendant caused by the
misrepresentations and misuse of pandemic stimulus funds described
above was $1,166,670. The parties agree that the actual loss figure

is legally appropriate under USSG § 2Bl1.1(b) (1) et seq.

26


File and source

File

95-plea-agreement-as-to-arsen-terzyan.pdf

Size

22,325,604 bytes

SHA-256

70b74c11e326d2d735d904196d8d0e235249e9e9e3ca271487872617d40ed5d4

Our copy

95-plea-agreement-as-to-arsen-terzyan.pdf

Original

PACER (login required)