Superior Court of California  ·  County of Los Angeles  ·  Case Nos. 25STCV19732 · 25STUD09596 · 25APLC00398
Plaintiff's Submission — August 2026
The Explosive
Submission 889 Francisco Street · The Deeds · The Inspector · The Building
LASC No. 25STCV19732  ·  UD No. 25STUD09596  ·  Appeal No. 25APLC00398
Hon. Chalfant  ·  Hon. Fruin  ·  Hon. Nellon  ·  Hon. Boyle  ·  Hon. McKay
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"The building is still there. The people are still in it. The Certificate of Occupancy that says it is safe for human habitation was signed by a man whose family member came into possession of a unit in that building — financed through his own employer."
Plaintiff's Submission — 889 S. Francisco Street Deed Chain & Certificate of Occupancy Analysis — August 2026
All allegations described herein reflect Plaintiff's pleadings and the public deed record. They are contested claims. Court filings and recorder's instruments cited herein are matters of public record.
Unit
801
889 Francisco St.
Defendant — Landlord — Unit Owner
Argam Aghazarian

Purchase: Argam Aghazarian acquired Unit 801 from XiaoLong Zhang and Qingqing Dong by grant deed signed at the U.S. Consulate in Shanghai, China on June 11, 2020 (Vice Consul: Meredith Davis). Recorded July 15, 2020, Inst. No. 20200815338. Purchase price: $650,000 — a $100,000 loss to the sellers relative to their 2017 acquisition price of approximately $750,000.

Financing: Aghazarian financed through Thrivent Federal Credit Union (Inst. No. 20200690104, $487,500) — the same institution where he serves as Market Director. His employer financed his purchase.

Prior owners: Zhang and Dong acquired Unit 801 from Greenland LA Metropolis Development I LLC on April 5, 2017, recorded July 5, 2017 (Inst. No. 20170743476). The deed was signed at the U.S. Embassy in Beijing, China on June 26, 2017 (Vice Consul: Joshua Kamp). Chao Wu executed as "V/P" of Greenland. East West Bank provided the purchase money deed of trust.

Inst. 20170743476 Inst. 20200815338 Inst. 20200690104 — Thrivent FCU $100,000 Loss — Sellers
801 — First Buyers
ZHANG
DONG
Beijing Embassy
June 26, 2017
Unit 801 — Original Buyers From Greenland
XiaoLong Zhang & Qingqing Dong

Acquisition: Acquired Unit 801 from Greenland LA Metropolis Development I LLC for approximately $750,000 with East West Bank financing. Deed executed at the U.S. Embassy in Beijing, China on June 26, 2017, by Vice Consul Joshua Kamp. Recorded: July 5, 2017, Inst. No. 20170743476.

Template notation: The deed was prepared using a template: "KTT\Greenland\Metropolis I\Purchasers Deed\7C — 12-9-2016" — indicating a standardized form prepared months before the individual sales were executed.

Resale at a loss: Zhang and Dong sold to Aghazarian in June 2020 for $650,000 — approximately $100,000 below their acquisition price — to a buyer who financed through his own employer.

U.S. Embassy Beijing June 26, 2017 — V.C. Joshua Kamp Inst. 20170743476 Sold at Loss — June 2020
Unit
2003
Absent Buyer
Unit 2003 — Shanghai Signing, No Buyer Present
Ao Yang

Acquisition: Ao Yang acquired Unit 2003 from Greenland LA Metropolis Development I LLC for $1,005,000 — cash, no financing. Deed recorded July 14, 2017, Inst. No. 20170788955. Executed March 20, 2017. Chao Wu executed as "VP" for Greenland.

Attorney-in-fact: Ao Yang was not present at signing. Chengyun Quan executed the deed as attorney-in-fact — acknowledged at a notary in Shanghai, China. The buyer did not personally appear to accept title to a $1,005,000 property in Los Angeles.

All-cash purchase: Zero financing. No lender's counsel present to review the deed or the grantor's authority. The template notation on this deed matches others in the series.

Inst. 20170788955 $1,005,000 — Zero Financing Buyer Absent — Chengyun Quan AIF Notarized Shanghai, China
Unit
3703
Entity Not in
CA SOS
Unit 3703 — Buyer Not Found in California Records
VS Systems, Inc.

Acquisition: VS Systems, Inc. acquired Unit 3703 from Greenland LA Metropolis Development I LLC for $1,268,000 — cash, zero financing. Deed executed December 27, 2016, recorded July 24, 2017, Inst. No. 20170825258. Chao Wu executed as "President" for Greenland.

Entity status: VS Systems, Inc. does not appear in the California Secretary of State's entity records under that name. A $1,268,000 cash purchase of Los Angeles real estate by an entity not registered with the California SOS.

No lender review: All-cash, zero financing. No lender's counsel present to scrutinize the grantor's title, the buyer's existence, or the authorization chain.

Inst. 20170825258 $1,268,000 — Zero Financing VS Systems, Inc. — Not Found in CA SOS Chao Wu "President" — Greenland
Unit
1802
Cooperative Assn.
Not an LLC
Unit 1802 — Entity Type Mismatch
WR Investment Associates LLC

Acquisition: WR Investment Associates LLC acquired Unit 1802 from Greenland LA Metropolis Development I LLC for $784,000 — cash, zero financing. Executed March 20, 2017, recorded September 25, 2017, Inst. No. 20171092079. Chao Wu executed as "VP" for Greenland.

Entity type: WR Investment Associates is organized as a Cooperative Association under California law — not a limited liability company as named in the deed. The deed names an "LLC" that is legally a cooperative association. The discrepancy was not caught at closing.

All-cash purchase: Zero financing. No lender present to verify the entity type or authority to convey.

Inst. 20171092079 $784,000 — Zero Financing Deed: "LLC" — Actually: Cooperative Assn.
Unit
3709
Ocean 2020 LLC
San Marino
Unit 3709 — 2021 Resale, All Cash
Ocean 2020 LLC

Acquisition: Ocean 2020 LLC (San Marino, California) acquired Unit 3709 for $980,000 — cash, zero financing. Executed October 20, 2021, recorded January 19, 2022, Inst. No. 20220070189. Xiaoying Yan executed as "EVP."

Pattern: The all-cash, no-lender pattern continues through 2021 — four years after the initial Greenland sales. No lender's counsel to scrutinize the chain of title, the prior conveyances, or the building's structural and permitting status.

Inst. 20220070189 $980,000 — Zero Financing Xiaoying Yan — EVP San Marino, CA
Greenland Pre-CofO Deed Chain — Public Record
Five Units.
One Signatory.
All five deeds below were executed by a single Greenland officer — Chao Wu — using a standard template prepared in December 2016. Four of five transactions were all-cash, zero financing. The fifth (Unit 801) used East West Bank. In every case, the buyer's lender — if any — is the only party whose counsel would independently review the grantor's authority and the chain of title.
Unit Buyer Deed Signed Recorded Instrument Price Financing Signatory / Location Note
3703 VS Systems, Inc. Dec. 27, 2016 Jul. 24, 2017 20170825258 $1,268,000 Zero / Cash Chao Wu "President" Not found CA SOS
1802 WR Investment Associates LLC Mar. 20, 2017 Sep. 25, 2017 20171092079 $784,000 Zero / Cash Chao Wu "VP" Deed: "LLC" — Actually Cooperative Assn.
801 XiaoLong Zhang & Qingqing Dong Apr. 5, 2017 Jul. 5, 2017 20170743476 ~$750,000 East West Bank DOT Chao Wu "V/P" — Beijing Embassy Buyers in China at signing; V.C. Joshua Kamp
2003 Ao Yang (AIF: Chengyun Quan) Mar. 20, 2017 Jul. 14, 2017 20170788955 $1,005,000 Zero / Cash Chao Wu "VP" — Shanghai Notary Buyer absent; AIF signed Shanghai
3709 Ocean 2020 LLC (San Marino) Oct. 20, 2021 Jan. 19, 2022 20220070189 $980,000 Zero / Cash Xiaoying Yan "EVP" 2021 resale — cash-only pattern continues

Template notation appearing on deeds in this series: "KTT\Greenland\Metropolis I\Purchasers Deed\7C — 12-9-2016"
All deeds reflect pre-Certificate of Occupancy sales. CofO (Permit No. 142128) was finalized November 14, 2019 — between 18 months and nearly three years after most of these sales were executed.

⚠ The Inspector Connection — Public Record
The Certificate of Occupancy
Was Signed by His Family Member.
Building Inspector
Sako S. Aghazarian
LADBS Senior Inspector
~37–38 Years of Service
Unit 801 Owner
Argam Aghazarian
Defendant — Market Director
Thrivent Federal Credit Union
Relationship
Blood Relatives
Same surname, family connection alleged
Certificate of Occupancy
Permit No. 142128
Finalized November 14, 2019
Fireproofing inspections signed: Sako S. Aghazarian
Purchase Date
Argam acquires Unit 801
June 11, 2020 (Shanghai) — financed through Thrivent FCU, his employer
Sequence
Inspector signs CofO → Family member buys unit
November 2019 → June 2020 (7 months)
November 14, 2019
LADBS finalizes Certificate of Occupancy for Metropolis I Tower I, Permit No. 142128. Sako S. Aghazarian, Senior Inspector (~37 years), signs the fireproofing inspection certifications that clear the building for habitation.
LADBS Permit No. 142128 — CofO Finalized
June 11, 2020 — Shanghai
Argam Aghazarian executes grant deed at the U.S. Consulate in Shanghai, China. Vice Consul Meredith Davis. Purchase price: $650,000 — $100,000 below what the prior owners paid. Financed through Aghazarian's own employer, Thrivent Federal Credit Union.
Inst. No. 20200815338 — Recorded July 15, 2020
July 8, 2025
Kevin Moda files LASC Case No. 25STCV19732. The inspector connection, the deed chain, and the building's structural issues are among the facts placed before the court.
LASC No. 25STCV19732 — Filed
"The unit was compensation: a unit in a building whose fireproofing was certified by a family member, acquired from sellers who never entered the United States, at a $100,000 loss to the sellers, financed through the buyer's own employer."
Plaintiff's Submission — 889 S. Francisco Street Analysis — August 2026
Unit 801 Market Data — 20-Comp Analysis
The Cash-Only Market

A 20-comparable analysis of comparable units at 889 Francisco Street during 2025–2026 reveals that the overwhelming majority of recent transactions are all-cash. No lender. No lender's counsel to read the deeds or audit the chain of title.

$771
Aghazarian — $/SF (June 2020)
$714
Current Market Avg $/SF (20 Comps)
$540K
Current Median Sale Price
ALL CASH
Dominant Transaction Type — 20 Comps

"The instruction to sell cash-only is the instruction to sell without scrutiny — and without the lender's counsel who would read these deeds and see that the signatory's title does not exist within the grantor's legal structure."
Plaintiff's Submission — August 2026

Structural & Permitting Record — LADBS Public Files
The Building's Own Record

The following are matters of public record from the LADBS permit file, the Certificate of Occupancy, and Plaintiff's filings.

Cassette Curtain Wall

The exterior cladding system uses a cassette curtain wall design. This system is inaccessible for inspection or remediation without demolition of interior finishes. Defects in the wall cavity cannot be detected through routine inspection.

Building Permit Records — 889 S. Francisco St.

Pool Permit — Rubber-Stamped

The pool permit was finalized on May 3, 201741 days before the Grenfell Tower fire (June 14, 2017) that killed 72 people in London and triggered global review of building safety certifications. No mechanical permit for pool systems was ever finalized.

LADBS Pool Permit — May 3, 2017

Carbon Fiber Column Wrapping

Permit No. 23016-10000-41125 ($1,000,000) authorized carbon fiber wrapping of structural columns — a technique used to strengthen columns that are structurally deficient. The permit itself is confirmation that the building's original structural capacity required reinforcement.

Permit 23016-10000-41125 — $1,000,000

Fireproofing Sign-Off

The fireproofing inspections underlying the Certificate of Occupancy (Permit No. 142128, finalized November 14, 2019) were signed by LADBS Senior Inspector Sako S. Aghazarian. His family member acquired a unit in the building seven months later.

CofO Permit No. 142128 — Finalized Nov. 14, 2019

Pre-CofO Sales

Most units in the deed chain above were sold before the Certificate of Occupancy was finalized — some by nearly three years. Buyers in China signed deeds for a building that had not yet been certified as safe for habitation under California law.

CofO Nov. 14, 2019 — First Deeds: Dec. 2016 – Apr. 2017

Unlicensed Property Management

From March 4, 2024 onward, the building was managed by Metro Property Management, LLC — a single-member LLC that cannot hold a California DRE broker's license. Joshua Cieszynski had been terminated by the prior management company on February 29, 2024.

Bus. & Prof. Code §§ 10130–10131 — LASC No. 25STCV19732
"I leave it with the Court."
Plaintiff Kevin Moda — Closing Line, Explosive Submission — August 2026
LASC No. 25STCV19732 — 25STUD09596 — 25APLC00398