Overview

On September 9, 2025 — forty-seven days after Plaintiff Kevin Moda obtained a Temporary Restraining Order blocking his physical lockout from Unit 801 — Defendant Argam Aghazarian filed a separate unlawful detainer action to obtain formal judicial authority to evict Moda. The UD action was assigned Case No. 25STUD09596 and proceeded in Department 46, running in parallel with the main civil case (25STCV19732) in Department 85.

The UD filing is notable for several reasons: it was filed by Aghazarian's own counsel, Sitora Reznikov — the same attorney whose June 2025 "lost flash drive" request Plaintiff alleges was a pretext for the surveillance of Plaintiff's computer activity. The UD action does not allege nonpayment of rent. And it was filed only after the TRO entered — suggesting its purpose was to obtain a judicial eviction mechanism after the self-help lockout was enjoined.

Case Details

Relationship to the Main Civil Action

The UD filing on September 9, 2025 came at a legally significant moment:

The sequence supports Plaintiff's argument in the main case that the UD action is a continuation of the same campaign to remove Moda from Unit 801 — originally attempted through the self-help lockout (July 17, 2025), then converted to a judicial proceeding after that lockout was enjoined.

Grounds for the UD Action

The UD complaint is not based on nonpayment of rent — Aghazarian checked "No" in response to the question whether the action is based "in whole or in part, on an alleged default in payment of rent or other charges." This is consistent with the fact that Moda did not pay rent directly to Aghazarian; Moda was a subtenant of Illana Stuppel, who in turn held the lease from Aghazarian.

The Sublease Issue

The HOA Rules and Regulations governing Metropolis I expressly prohibit subleasing. Section 1 of the "Rental of Condominiums" section states: "An Owner shall be entitled to rent the Owner's Condominium (but not a portion thereof) for a term of not less than one (1) year… Subleasing is expressly prohibited."

The structure of the occupancy at Unit 801 was as follows: Aghazarian owned Unit 801 and leased it to Illana Stuppel. Stuppel, according to the July 3, 2025 Notice of Decision signed by Aghazarian as "Owner/Landlord," then allowed Moda to occupy the unit. Aghazarian's position is that this arrangement constituted an unauthorized sublease that he did not approve.

Plaintiff contends that Aghazarian was aware of and acquiesced to Moda's occupancy, and that the "unauthorized subtenant" characterization is itself pretextual — a legal theory constructed to justify removing Moda specifically, not a good-faith enforcement of the sublease prohibition that Aghazarian and other unit owners may routinely ignore. The fact that the Notice of Decision on July 3, 2025 was signed by Aghazarian himself as "Owner/Landlord" — not by the HOA board — further supports that Aghazarian was acting as Moda's de facto landlord in revoking access.

The sublease issue is one of the central factual disputes in both the UD proceeding and the main civil case. Resolution of the occupancy status question will have consequences in both proceedings.

The Reznikov Connection

Sitora Reznikov — the attorney who filed the UD complaint on behalf of Aghazarian — is the same attorney identified in Plaintiff's surveillance allegations as having made the pretextual "lost flash drive" request to Cieszynski in June 2025.

Plaintiff's anti-SLAPP opposition and surveillance section describe the following sequence: In June 2025, before the UD was filed, Reznikov allegedly contacted Cieszynski claiming she had "lost a flash drive" in the Business Center. Plaintiff alleges this was a manufactured pretext for Cieszynski to conduct a targeted review of surveillance footage showing Plaintiff's computer screen — from which the "computer hacking" accusation was then constructed. That accusation was presented at the June 30 board hearing. The board hearing resulted in the Notice of Decision stripping Moda of his access — which became the predicate for both the physical lockout and, ultimately, the UD action.

The causal chain Plaintiff alleges runs directly through Reznikov's office: Reznikov's flash-drive pretext → Cieszynski's surveillance review → fabricated hacking accusation → board hearing → access revocation → lockout → UD. Reznikov's dual role as both a central actor in the alleged fabrication and as counsel of record in the resulting UD proceeding is a factual connection Plaintiff highlights in the main case.

UD Proceeding Chronology