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Khojayan and Associates

SAMPLES OF RECENT WRITTEN MOTIONS

We fight and defend all federal criminal cases including those accusing people of access fraud, fraudulent use of identification documents under 18 USC 1028A and 18 USC 1029 and aggravated identity theft.  Please click thumbnail below to view PDF examples of motions and appeals submitted that shows our detailed work on behalf of our clients.

Khojayan and Associates

HOUSE ARREST FOR DEFENDANT FACING 10 YEAR MANDATORY MINIMUM IN FEDERAL NARCOTICS DISTRIBUTION CONSPIRACY.

LOS ANGELES, CALIFORNIA – February 28, 2019 – Defendant was charged in a 20 count indictment involving 26 defendants. All of them including Shaun Khojayan’s client were accused of distributing and possessing with intent to distribute narcotics, cocaine, heroin and marijuana. Specifically, Mr. Khojayan’s client distributed at least 156 grams of narcotics. He faced a 10 year mandatory minimum sentence

Khojayan and Associates

STRAIGHT PROBATION FOR POSSESSION OF KETAMINE WITH INTENT TO DISTRIBUTE WHEN ORIGINALLY FACING 5 YEARS MINIMUM IN PRISON

LOS ANGELES, CALIFORNIA — Mr. Khojayan’s client was in custody without bail and facing 5 years minimum in prison for possession of narcotics and ketamine with intent to distribute. Mr. Khojayan negotiated with the Assistant United States Attorney (AUSA) for his client to be released to a drug treatment center with an unsecured signature bond. He then negotiated that his client only plead guilty to the charge of possession of ketamine that did not carry any minimum mandatory sentence

Khojayan and Associates

COURT GRANTS MOTION TO VACATE CONVICTION DUE TO IMMIGRATION CONSEQUENCES

GAINESVILLE, GA –Defendant was arrested and charged with Possession for Sale of Cocaine (Health and Safety code §11351) in Los Angeles, California, in 1991. He received a short jail sentence and probation. However, he was a legal permanent resident, not an U.S. Citizen, when he was convicted. He had since relocated to Georgia, raised a family and now, many years later, desired to become a U.S. Citizen. Furthermore, having a possession for sale conviction made him deportable

Khojayan and Associates

NINTH CIRCUIT COURT OF APPEALS GRANTS MR. KHOJAYAN’S APPEAL, VACATES HIS CLIENT’S CONVICTION AND SENTENCE

Pasadena, California. The Ninth Circuit Court of Appeals reversed the conviction of Shaun Khojayan’s client and remanded the case for a new trial in a victory for justice and the Constitutional Right to a Fair Trial. District Court Judge Percy Anderson had disallowed the insanity defense despite there being evidence that the defendant was insane at the time of the assault

Khojayan and Associates

COURT DISMISSES CASE AFTER GRANTING MOTION TO VACATE CONVICTION UNDER—CALIFORNIA PENAL CODES 1016.5 AND 1473.7 BASED ON THE CLIENT’S ADVERSE—IMMIGRATION CONSEQUENCES RESULTING FROM THE PLEA

Sammy was convicted of insurance fraud when he was 21 years old and a Legal Permanent Resident. He received a sentence of probation with restitution. At the time he accepted the guilty plea, Sammy had only been in the United States for a few years after escaping Iran due to the Iranian’s government’s persecution of him and his family based on their religion. Now, at 30 years old and about to start a new family, the U.S. Immigration and Customs Service (ICE) notified him that they were beginning removal proceedings to deport him from the United States based on his prior insurance fraud conviction years qualifying as an aggravated felony under the immigration laws

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