On September 07, 2021 a
Motion-Secondary
was filed
involving a dispute between
Novalk, Llc,
and
Cirit, Denis Baran,
Cirit, Fatma Handan,
Cirit, Semih,
C-Tech, Inc,
Does 1-100,
Kim, Yun Kyung,
Kyung, Yun,
Nc Queen, Inc.,
Sargent, Sarina Berna,
for Other Real Property Unlimited
in the District Court of San Bernardino County.
Preview
’
ORIGINAL
ANDREW RAUCH, APC ‘
-
SUPERIORfi-zolufi'rgi:
(“DALIFORNM
.__n
AndrewK. Ranch, Esq. (SBN 137657) V Cgfiygggmgm BERNAR DWO
12526 High Bluff Dave, Suite #300 D'NO “STRICT
San Diego,CA 92130
SEP 15
FAX
BY
Telephone. (619) 515- 1140
Facsxmile:
Attorne
NOVA
(619) 235—9100
Email: rauch@rauchapc.com
s for
LLC
Real Party in Interest,
By 5% 'M. W
2021
Deputy
K,
©MQQMAWN
FILED
SUPERIOR COURT 0F THE STATE OF CALIFORNIA
COUNTY OF SAN BERNARDINO, JUSTICE CENTER
NOVALK, LLC, ) Case No.: CIVSB2122277
'
.
)
Plaintiff, ) DECLARATION OF
v. ) RAMON CARDENAS IN SUPPORT 0F
‘
) EX PARTE APPLICATION 0F
SEMIH FATMA HANDAN CIRIT;
CIRIT; ) NOVALK, LLC FOR TEMPORARY
-— DENIS BARAN CIRIT; SARINA BERNA ) RESTRAINING ORDER AND
SARGENT; C-TECH, INC.; ) PRELIMINARY INJUNCTION
NC QUEEN, {NC.; YUN KYUNG;
'
)
and, DOES 1-100, inclusive ) [IMAGED]
_
)
Defendants. ) General Jurisdiction — Civil
) Jury Trial Requested on all Issues s0 Triable
) .
) Judge: Honorable Wilfred J. Schneider, Jr.
) Dept: S32
) Date: September 16, 2021
) Time: 9:00 a.m.
)
MNNNNNNNNQ
I, Ramon Cardenas, hereby declare as follows:
1. I am an adult over the age of 18 years, a resident of the State of California, and a
licensed real estate broker. Ihave personal knowledge of the matters set forth herein, unless I
have indicated my knowledge is based on information and belief, and if called upon and could
and would testify competently to these matters.
-1-
DECLARATION OF RAMON CARDENAS IN SUPPORT OF EX PARTE APPLICATION OF
NOVALK, LLC FOR TEMPORARY RESTRAINING ORDER AND PRELIMINARY INJUNCTION
THE PROJECT
2. Novalk, LLC (“Novalk”) i; the owner of the real property located in the City and
County of San Berfiardino, generally described as 2065 E. Highland Avenue, including San
Bernardino County Assessor Parcel Numbers (APN) 1191-01 1-14-0—000 and 1191-01
1-19-0—000
(the “Property.”)
IWOOQONUI-D-MN
la
3. The Property is located in shopping center southeast of the intersection of
Stirling and East Highland in San Bernardino (the “Shopping Center”). ‘
4. I have provided real estate services to Novalk LLC and its principal, Dr. Victor
Khalil for many years, including in the location of tenants for its commercial or retail buildings.
10 5. I specifically Worked on finding a tenant for the Property at the Shopping Center.
11 6. Prior to concluding any lease agreement with the current tenant, Dr.
_
Khalil and I
12 pamicipated in ajoint telephone conference with Semih who
Cirit, represented himself to be the
l3 manager ofthe Shopping Center.
I
l4 7. ,
Mr. Cirit confirmed to us that the ownels of the Shopping Center were leaving the
15 3'“ space open on the two pylon signs of the Shopping Center for a national tenant to
join the
16’ center.
17 8. In the telephone conversation, Mr. Cirit confirmed he understood
that that we
l8 intended to lease the space and that it was important to know if the tenant could use the space on
-19 the large signs.
20 9. Mr. Chit again confirmed that our national tenant would have use of this sign
2] space.
'
22 10. I was extremely pleased to be able to obtain BioLife as a potential tenant in the
23 Shopping Center. BioLife Plasma Services is a national tenant with over 120 locations, in over
24 30 States throughofit the U.S with a growth plan of reaching 300 locations in the next 24 - 36
25 months and excellent tenant reputation.
26 1 1. Mr. Cirit told us he was excited to have another national tenantjoining the center.
27 He knew the sign was part of the negotiation with the prospective tenant and told Dr. Khalil that
~28 he can g0 back to the tenant and offer the 3rd space on the pylons in order to help the negotiation
-2-
DECLARATION OF RAMON CARDENAS IN SUPPORT 0F EX PARTE APPLICATION 0F
NOVALK, LLC FOR TEMPORARY RESTRAINING ORDER AND PRELIMINARY INJUNCTION
Document Filed Date
September 15, 2021
Case Filing Date
September 07, 2021
Category
Other Real Property Unlimited
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’ ORIGINAL ANDREW RAUCH, APC ‘ - SUPERIORfi-zolufi'rgi: (“DALIFORNM .__n AndrewK. Ranch, Esq. (SBN 137657) V Cgfiygggmgm BERNAR DWO 12526 High Bluff Dave, Suite #300 D'NO “STRICT San Diego,CA 92130 SEP 15 FAX BY Telephone. (619) 515- 1140 Facsxmile: Attorne NOVA (619) 235—9100 Email: rauch@rauchapc.com s for LLC Real Party in Interest, By 5% 'M. W 2021 Deputy K, ©MQQMAWN FILED SUPERIOR COURT 0F THE STATE OF CALIFORNIA COUNTY OF SAN BERNARDINO, JUSTICE CENTER NOVALK, LLC, ) Case No.: CIVSB2122277 ' . ) Plaintiff, ) DECLARATION OF v. ) RAMON CARDENAS IN SUPPORT 0F ‘ ) EX PARTE APPLICATION 0F SEMIH FATMA HANDAN CIRIT; CIRIT; ) NOVALK, LLC FOR TEMPORARY -— DENIS BARAN CIRIT; SARINA BERNA ) RESTRAINING ORDER AND SARGENT; C-TECH, INC.; ) PRELIMINARY INJUNCTION NC QUEEN, {NC.; YUN KYUNG; ' ) and, DOES 1-100, inclusive ) [IMAGED] _ ) Defendants. ) General Jurisdiction — Civil ) Jury Trial Requested on all Issues s0 Triable ) . ) Judge: Honorable Wilfred J. Schneider, Jr. ) Dept: S32 ) Date: September 16, 2021 ) Time: 9:00 a.m. ) MNNNNNNNNQ I, Ramon Cardenas, hereby declare as follows: 1. I am an adult over the age of 18 years, a resident of the State of California, and a licensed real estate broker. Ihave personal knowledge of the matters set forth herein, unless I have indicated my knowledge is based on information and belief, and if called upon and could and would testify competently to these matters. -1- DECLARATION OF RAMON CARDENAS IN SUPPORT OF EX PARTE APPLICATION OF NOVALK, LLC FOR TEMPORARY RESTRAINING ORDER AND PRELIMINARY INJUNCTION THE PROJECT 2. Novalk, LLC (“Novalk”) i; the owner of the real property located in the City and County of San Berfiardino, generally described as 2065 E. Highland Avenue, including San Bernardino County Assessor Parcel Numbers (APN) 1191-01 1-14-0—000 and 1191-01 1-19-0—000 (the “Property.”) IWOOQONUI-D-MN la 3. The Property is located in shopping center southeast of the intersection of Stirling and East Highland in San Bernardino (the “Shopping Center”). ‘ 4. I have provided real estate services to Novalk LLC and its principal, Dr. Victor Khalil for many years, including in the location of tenants for its commercial or retail buildings. 10 5. I specifically Worked on finding a tenant for the Property at the Shopping Center. 11 6. Prior to concluding any lease agreement with the current tenant, Dr. _ Khalil and I 12 pamicipated in ajoint telephone conference with Semih who Cirit, represented himself to be the l3 manager ofthe Shopping Center. I l4 7. , Mr. Cirit confirmed to us that the ownels of the Shopping Center were leaving the 15 3'“ space open on the two pylon signs of the Shopping Center for a national tenant to join the 16’ center. 17 8. In the telephone conversation, Mr. Cirit confirmed he understood that that we l8 intended to lease the space and that it was important to know if the tenant could use the space on -19 the large signs. 20 9. Mr. Chit again confirmed that our national tenant would have use of this sign 2] space. ' 22 10. I was extremely pleased to be able to obtain BioLife as a potential tenant in the 23 Shopping Center. BioLife Plasma Services is a national tenant with over 120 locations, in over 24 30 States throughofit the U.S with a growth plan of reaching 300 locations in the next 24 - 36 25 months and excellent tenant reputation. 26 1 1. Mr. Cirit told us he was excited to have another national tenantjoining the center. 27 He knew the sign was part of the negotiation with the prospective tenant and told Dr. Khalil that ~28 he can g0 back to the tenant and offer the 3rd space on the pylons in order to help the negotiation -2- DECLARATION OF RAMON CARDENAS IN SUPPORT 0F EX PARTE APPLICATION 0F NOVALK, LLC FOR TEMPORARY RESTRAINING ORDER AND PRELIMINARY INJUNCTION