Moda v. Aghazarian, et al. | Case No. 25STCV19732

I have lived in Unit 801
for two years.

Kevin Moda, Plaintiff · LASC No. 25STCV19732

A couple of months in, I started noticing the HOA doing things that didn’t sit right. It didn’t take long before Oleg Pariser — the HOA President — and Joshua Cieszynski created what I can only call a star chamber: a secret proceeding, no notice to me, where they convicted me of wrongs I would never commit. Vile things. Painful to me.

So I sued. Oleg Pariser, the unit owner, the building manager, and the management company — all of them, for what they had done.

I am particularly fond of Oleg. In July 2025, he tried to make me homeless. He had my access revoked and would not let me back into the building. I called the police for assistance.

“Either Moda gets back in, or we arrange room, food, and bedding for you tonight.” Responding officers to Oleg Pariser — July 2025

Oleg, Chermenskyh, and the unit owner relented. I was allowed back in. My personal experience of being subjected to a self-help eviction — that is an experience Oleg will not forget.

A court saw the bigger picture. In 2025 I was awarded a Preliminary Injunction, and since that order came down I have not paid so much as my electricity bill here — and there is a reason for that too.

II · The Meter

Every resident in this building gets billed by a company called AMPS. What AMPS does is straightforward: it submeters each unit, charges residents at the higher consumption tiers, then keeps buying power from LADWP at the lower base rate and pockets the spread. On top of that, they were sending the bills in the name of the original lease holder — not the person actually living there and using the power. California law requires that utility bills be issued in the name of the person actually consuming the service.

I wrote to Ms. Ho, the owner of AMPS — a company built to sell building owners submeters they never needed and then profit off the margin. My message was simple:

“Send me one bill with my name on it. Just one.”

That was the last I heard from any of them. No bill. No AMPS. No Ho.

III · The Building

Then the unit owner sued me. That brought in my attorneys — people who saw what was happening and showed up. What they found went well beyond broken appliances and a hostile HOA president.

They ran this building through what I would call a fraud matrix — a pattern analysis of the ownership, the financing, the construction, all of it. What emerged was this: this building was never built for human habitation. It was built as an EB-5 fraud scheme. The original buyers of Unit 801 signed their purchase documents at the same moment they applied at the U.S. Embassy — the deed of trust was notarized there. They were never in this country. They never saw this place.

In 2020, Mr. Aghazarian — the current title holder of the unit — purchased it, with financing flowing through something called Thrivadent, a union financial facility that exists largely on paper. His uncle, Sako Aghazarian, had been the special inspector assigned by LADBS to this building.

151

Occupancy permits
issued in one day

Three minutes per unit.
Do you feel safe?

The bribe was the unit itself. That is when the FBI got involved. The head of LADBS received prison time. The council member who participated in the corruption received a fourteen-year sentence and remains in prison today. Sako is no longer with LADBS. More on all of that later.

IV · What Is Left Unbuilt

You see the pool. It is heated. But no one can use it between 11 p.m. and 6 a.m. — that is illegal. The pool and jacuzzi are both uncovered, and neither can legally be used as they stand. That violates the California Health and Safety Code sections governing residential pool access and enclosure requirements.

And for those of you who own units here: you are exposed to a clawback of the property tax reductions you received when this building was handed green building certification. Fake certification. Imagine the penalties when that unravels.

This site exists because the public record matters. What happened to me in Unit 801 did not happen in a vacuum. It happened inside a building conceived in fraud, permitted by corruption, and managed by people who believed no one was paying close enough attention.

I was. I am.

Every document on this site is real. Every allegation is supported by a filing, a declaration, a court order, or a public record. The case is LASC No. 25STCV19732 — look it up. The docket is public and so is everything in it.

And I am still in Unit 801.

The Global Mediation
That Wasn't

Greenland LA Metropolis Development I LLC, et al. v. Metropolis I Condominium Owners' Association, et al.

“

This case remains stayed. The arbitration as between Greenland and Met 1 has not been completed. The parties, including Metropolis Master have agreed to attend a mediation session on August 4, 2025 which is intended as a global mediation and would resolve Met 1's claims against Metropolis Master if successful.

Paul W. Windust, Berding & Weil LLP — for Cross-Defendant Metropolis Master Association
Case Management Statement (CM-110), Filed July 10, 2025 — OC Case No. 30-2023-01346055-CU-NP-CJC, ROA #274

Mar. 14, 2025

HOA & Pariser withdraw proposed judgment of dismissal — Moda already circulating $11M records from OC case

OC ROA #272 — Metropolis I COA; Oleg Pariser

Jul. 7, 2025

Moda files suit in Los Angeles County Superior Court — names Cieszynski, Pariser, Metro Property Management, and HOA

LASC No. 25STCV19732

Jul. 10, 2025

Master Association tells OC court the case is stayed and a "global mediation" on August 4 will resolve all claims if successful — three days after Moda files

OC ROA #274 — Paul W. Windust

May 29, 2026

Kim names Greenland US Commercial Holding, Inc. as ROE 7 in cross-complaint — after Cieszynski's anti-SLAPP fails and he refuses to exit the LASC case

OC ROA #304 — Michael G. Kim, APC

Case Overview

This action arises from events at 889 Francisco Street, Los Angeles, within the Metropolis I condominium community. Plaintiff Kevin Moda, a tenant of Unit 801, alleges a coordinated campaign of tenant harassment, an unlawful lockout, and privacy violations orchestrated by an unlicensed property manager and HOA personnel who lacked authority to act.

Filed July 8, 2025 in Los Angeles County Superior Court, this case has proceeded through a temporary restraining order, a preliminary injunction (granted September 4, 2025), multiple anti-SLAPP motions, judicial-assignment challenges, and cross-claims.

Causes of Action

Named Defendants

Navigate This Case

Section 00

The Plaintiff’s Statement

Kevin Moda in his own words — the star chamber, the lockout, the meter, and a building built on fraud.

Section 01

Parties

Plaintiff, defendants, counsel, and the roles each party played at 889 Francisco Street.

Section 02

Full Timeline

Chronological record from the manager's termination in February 2024 through current proceedings.

Section 03

Claims & Causes of Action

All seven causes of action — constructive eviction, harassment, fraud, privacy violations, and more.

Section 04

Motions & Rulings

TRO, preliminary injunction, anti-SLAPP motions, peremptory challenges, and judicial rulings.

Section 05

Surveillance & Privacy

The Business Center computer monitoring at issue in the Federal Wiretap Act and invasion-of-privacy claims.

Section 06

889 Submission

The deed chain, the inspector connection, building defects, and the cash-only market — the explosive record.

Section 07

The Building

889 Francisco Street, Tower I — structural record, pool permit, and the London fire that preceded it by 41 days.

Section 08

Public Filings

Index of documents in the public court record, organized by date and category.

Key Alleged Facts

The following facts are drawn from Plaintiff's pleadings and declarations. They are contested by the defendants.

The Unlicensed Property Manager

Joshua Cieszynski was terminated by Action Property Management, Inc. on February 29, 2024, as confirmed by a sworn declaration from Action's Chief Operating Officer, Matthew Davidson. Cieszynski then formed Metro Property Management, LLC — a single-member LLC categorically incapable of holding a California DRE broker's license — and continued managing the Metropolis I building as if nothing had changed. A DRE license search shows no broker license for either Cieszynski or Metro Property Management, LLC.

The HOA Contract & Pariser's Role

HOA Board President Oleg Pariser executed the property management agreement with Metro Property Management, LLC on February 28, 2024. Plaintiff contends Pariser signed unilaterally, without a board vote or competitive bidding required by the CC&Rs. A forensic review of the contract (Exhibit 1 to the Pariser Declaration) revealed that Page 17 still contained the name "Action Property Management, Inc." in its pricing clause — indicating the contract was plagiarized from a competitor's template. Plaintiff alleges Pariser did not read the contract before signing.

The Fabrication Timeline

On June 2, 2025, staff member Frank Marenco sent an email stating only that he "smelled" an odor in the sauna. Twenty-eight days later, a Three-Day Notice to Quit — drafted by Defendant Aghazarian's counsel — escalated this to a claim that Plaintiff was "witnessed by two people urinating in public," added accusations of voyeurism, and demanded vacation within three days.

The Lockout

On July 2, 2025, Cieszynski issued a "Notice of Decision" revoking Plaintiff's key fobs and all building access. On July 17, 2025, a physical lockout of Unit 801 was executed. The court entered a Temporary Restraining Order on July 24, 2025 and a Preliminary Injunction on September 4, 2025 (Judge Chalfant, Dept. 85), ordering that Plaintiff's access be restored and maintained.

Current Procedural Status

Matter	Status
Preliminary Injunction (access to Unit 801)	In Effect Granted Sept. 4, 2025
Anti-SLAPP Motion (Cieszynski & Metro Property Management)	Denied June 15, 2026 — Hon. Cherol J. Nellon, Dept. 300
Motion for Summary Adjudication (Cieszynski)	Filed
Motion for Summary Adjudication (Pariser)	Filed