Parties to the Litigation

Plaintiff alleges Aghazarian coordinated with the property manager and HOA to effectuate an unlawful eviction — retaining counsel who drafted a fabricated Three-Day Notice to Quit escalating a minor alleged incident into criminal accusations (public urination, voyeurism, computer hacking). Aghazarian filed a separate unlawful detainer action (25STUD09596, Dept. 46) on September 9, 2025 — five days after his injunction was denied — seeking judicial eviction authority after the self-help lockout was enjoined.

Plaintiff alleges Cieszynski 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 without a license, as required by Business & Professions Code §§ 10130–10131. A DRE license search confirms no broker's license for either entity. Plaintiff further alleges Cieszynski used the building's security cameras to monitor Plaintiff's personal laptop screen across 14 sessions, constructing a fabricated "computer hacking" accusation that formed the predicate for the June 30 board hearing and subsequent lockout. Anti-SLAPP motion denied June 15, 2026 (Dept. 300).

Plaintiff alleges Metro Property Management is the alter ego of Cieszynski and is categorically incapable of holding a California DRE broker's license — a corporate LLC cannot hold a broker's license in California, only an individual or a general partnership whose designated officer holds the license. The management contract with the HOA is therefore void ab initio under California law, making each act performed under it an independent statutory violation. Anti-SLAPP motion denied June 15, 2026 (Dept. 300).

Plaintiff alleges Pariser signed the management agreement unilaterally — without a board vote, competitive bidding, or legal review required by the CC&Rs and California Corporations Code § 7210. A forensic review of the contract (Exhibit 1, Pariser Declaration) found 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. Cross-complaint allegations: Pariser concealed the $11M Greenland settlement from unit owners and HOA members to "pocket the money from Green." Motion for Summary Adjudication filed.

Plaintiff alleges Marenco sent the initial June 2, 2025 email describing only that he "smelled" an odor in the sauna — with no eyewitness claim and no accusation of misconduct. This account was later escalated in a Three-Day Notice to Quit drafted by Defendant Aghazarian's counsel into an accusation that Plaintiff was "witnessed by two people urinating in public." Twenty-eight days. One anonymous email to criminal accusation in a formal legal notice. Plaintiff further alleges Marenco physically barred Plaintiff's re-entry to the building on July 18, 2025.

The Davidson Declaration — filed as Exhibit J in the Anti-SLAPP opposition — confirms under penalty of perjury that Joshua Cieszynski was terminated from Action Property Management on February 29, 2024. Matthew Davidson, Chief Operating Officer, signed this declaration. Its existence establishes the precise date Cieszynski stopped being a licensed agent and started operating without one. The record created by Cieszynski's unauthorized continuation of management is built on that single termination date.