Background: February 2024 — The Hidden Termination
| Date | Event |
|---|---|
| Feb. 28, 2024 | Property Management Agreement between the Metropolis I Owners' Association and Metro Property Management, LLC is dated (per contract preamble). Plaintiff alleges HOA Board President Oleg Pariser signed the contract unilaterally without a board vote or competitive bidding, and that the contract's Page 17 still bore the name "Action Property Management, Inc." — indicating plagiarism from a competitor's template. |
| Feb. 29, 2024 | Joshua Cieszynski is terminated from Action Property Management, Inc. This fact is confirmed by a sworn declaration from Matthew Davidson, Action's Chief Operating Officer (filed as Exhibit J in Plaintiff's Anti-SLAPP opposition). From this date forward, Cieszynski had no employment relationship with any licensed management entity. |
| Mar. 4, 2024 | Per the Pariser Declaration, Metro Property Management's on-site retention begins. Plaintiff alleges this gap between the contract date (Feb. 28) and the start date (Mar. 4) reflects retroactive execution, indicating no formal board approval preceded operations. Cieszynski begins operating the building through Metro Property Management, LLC — an unlicensed single-member LLC. |
2024–2025: Alleged Surveillance of Plaintiff
| Period | Event |
|---|---|
| 2024–June 2025 | Over 14 distinct sessions in the building's Business Center, Cieszynski and Metro Property Management staff allegedly manipulated security cameras to zoom and focus on Plaintiff's laptop screen and keyboard. Plaintiff alleges this constitutes violations of the Federal Wiretap Act (18 U.S.C. §§ 2511, 2520), California Penal Code §§ 631 and 632, and California's constitutional right to privacy. Activity logs allegedly match the times Plaintiff used the Business Center with corresponding manual camera operations by Cieszynski and staff. |
| June 2, 2025 | Building staff member Frank Marenco sends an email stating he "smelled" an odor in the sauna. No eyewitness claim of any specific act is made. |
| June 16, 2025 | Plaintiff alleges Defendant Aghazarian's attorney, Sitora Reznikov, contacted Cieszynski claiming she "lost a flash drive" in the Business Center, providing a pretext for Cieszynski to review days of surveillance footage targeting Plaintiff's computer activity. |
| June 20, 2025 | Cieszynski sends notice of a disciplinary board hearing to landlord Aghazarian at his Porter Ranch address — not to Plaintiff and not to the unit. Plaintiff alleges this violates Davis-Stirling Act § 5855(a), which requires 10 days' written notice to the affected party, and the CC&Rs § 5.1.22. |
| June 30, 2025 | Board hearing held. Plaintiff received no notice of the hearing, did not attend, and was given no opportunity to respond. Plaintiff alleges the hearing was conducted in his absence in violation of Civil Code § 5855(b)–(c). |
July 2025: The Lockout
| Date | Event |
|---|---|
| July 2, 2025 | Cieszynski issues a "Notice of Decision" revoking Plaintiff's key fobs, package delivery, and building access privileges effective immediately. The Notice affects "all tenants, guests, etc." of Unit 801 and imposes a 30-day blanket revocation of common-area access — including elevator access in a 38-story high-rise. Plaintiff alleges this far exceeds the $100-per-violation cap under Civil Code § 5850 and is void under § 5855(g) for failure to follow required procedures. |
| July 7–8, 2025 | Plaintiff files the Verified Complaint initiating Case No. 25STCV19732 in Los Angeles County Superior Court. Action filed July 8, 2025. |
| July 17–18, 2025 | Cieszynski executes a physical lockout of Plaintiff's unit. Pariser is present during the lockout and interacts with responding LAPD officers regarding Plaintiff's attempted re-entry. On July 18, Marenco physically bars Plaintiff from re-entering the building entirely. |
| July 24, 2025 | Court (Dept. 85, Hon. James C. Chalfant) enters a Temporary Restraining Order enjoining the lockout conduct and ordering Plaintiff's access to be restored. |
| Late July 2025 | Three-Day Notice to Quit — drafted by Defendant Aghazarian's counsel — is served on Plaintiff. The Notice escalates Marenco's June 2 "smelled an odor" email to an accusation that Plaintiff was "witnessed by two people urinating in public," and adds fabricated accusations of voyeurism. Plaintiff alleges the escalation from "smelled an odor" to "witnessed by two people" over 28 days, with no corroborating evidence, constitutes evidence fabrication deployed as an eviction predicate against a whistleblower who had been inquiring about HOA finances. |
August – December 2025: Early Litigation
| Date | Event |
|---|---|
| Aug. 7, 2025 | Declaration of Matthew Davidson (COO, Action Property Management) filed, confirming under penalty of perjury that Cieszynski was terminated on February 29, 2024. |
| Aug. 30–31, 2025 | Metropolis I Owners' Association Board terminates Cieszynski and Metro Property Management's contract. Plaintiff alleges the termination was directly caused by the TRO and the Board's realization that the contract was void for licensing violations — not "unrelated" to the litigation as claimed in the Pariser Declaration. |
| Sept. 4, 2025 | Preliminary Injunction granted (Hon. James C. Chalfant, Dept. 85). Judge Chalfant finds "limited probability of success" and enters the injunction ordering Cieszynski and Marenco not to deny Plaintiff access to Unit 801, refuse package delivery, or restrict access to common areas. The preliminary injunction remains in effect. |
| Nov. 14, 2025 | Ruling on Anti-SLAPP motion. (Details in the Motions & Rulings page.) |
| Dec. 15, 2025 | Metro Property Management, LLC is added as a Doe defendant. |
2026: Motions Practice
| Date | Event |
|---|---|
| Jan. 12, 2026 | Court (Dept. 15, Hon. Stuart M. Rice) denies Cieszynski's anti-SLAPP motion on the merits. This ruling is later affirmed by the Second District Court of Appeal. |
| Jan. 30, 2026 | Court denies Metro Property Management's CCP § 170.6 peremptory challenge as untimely. |
| Feb. 11, 2026 | Oleg Pariser files a declaration (with the management agreement attached as Exhibit 1) in connection with HOA-related briefing on the peremptory challenge. Plaintiff alleges the declaration contains multiple false statements, including the claim that the MPM termination was "unrelated" to the litigation. |
| Feb. 17, 2026 | HOA's peremptory challenge under CCP § 170.6 is granted; case is reassigned. |
| Feb. 26, 2026 | Metro Property Management files "Amended" anti-SLAPP motion — 73 days after being added as a defendant. Plaintiff contends this motion is untimely (exceeding the 60-day window under CCP § 425.16(f)) and constitutes an improper successive application. |
| Mar. 4, 2026 | Hearings set for Plaintiff's motions for summary adjudication against Cieszynski and Pariser. |
| Mar. 5, 2026 | Second District Court of Appeal (Writ No. B352287) denies the writ petition challenging the § 170.6 ruling. The trial court's January 2026 merits-denial of the Cieszynski anti-SLAPP motion is left undisturbed. |
| Apr. 24, 2026 | Ex parte application filed in Department 14 by Plaintiff's counsel regarding sealed submission and jurisdictional issues. |
| May 4–14, 2026 | Ex parte applications and notice of filing of original pages of exhibits filed in Department 14. Notice provided to all parties by telephone and electronic mail. |
| May 18, 2026 | Anti-SLAPP motion hearing (Dept. 14, Hon. Cherol J. Nellon) and Case Management Conference. |
| Aug. 12, 2026 | Upcoming Hearing on Metro Property Management's Anti-SLAPP motion, Dept. 39, Stanley Mosk Courthouse, 8:30 a.m. |