On April 02, 2019 a
Order
was filed
involving a dispute between
Sergev Firsov,
and
Ekaterina Berman,
Kitanoff Group International,
Luba Chernov,
Omar Kitanoff,
State Of California, Department Of Justice,
Yevgeniy Babichev,
for civil
in the District Court of Santa Clara County.
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From: Sergey Firsov iLE
333:Escuela avenue, apt 141
Mountain view, CA 94040 MAY 0 5 2020
+1 (650) 210-6804 rt
Clerk of the hy Cou
of Banta Clara
Email: sfirsov1972@gmail.com
pePI
In Pro Per
SUPERIOR COURT OF THE STATE OF CALIFO! IRNIA, SANTA CLARA COUNTY |
191 N. First street, San Jose, CA, 95113
SERGEY FIRSOV Civil unlimited case Ne 19CV345499
Plaintiff
vs PLAINTIFF’S REPLY IN SUPPORT OF HIS
YEVGENTY BABICHEV et al MOTION TO RECONSIDER THE 02/28/2020 ORDER
Defendants GRANTING LUBA CHERNOV ANTI-SLAPP MOTION
Hearing: 05/21/2020, 9.00 am
Honor: |
Thang Barret! Department 2D
CC: To Defendant and to her attorney of record:
Plaintiff SERGEY FIRSOV submits reply\objection in support of his motion to reconsider anti-SLAPP
motion from Defendant Luba Chernov.
Facts
Luba Chernov is court certified translator. She has license to translate from Bel ian
(registered), French (registered) and Ukrainian (registered) languages.
On February 2019 she translated my email from Russian language to English and presented jit as
evidence in civil harassment case 19CH008591 “Berman vs Firsov”. She ‘translated Russian ord
“mochit” as “kill”. Due her translation I was arrested for death threat and spent in jail 1 day.
On March 2019 another court certified translator Alexander Bantov translated my email from
Russian language to English. He translated Russian word “mochit” as “oppose”.
Police closed my criminal case for death threat, because there i is no evidence.
At February 5, 2020 I filed declaration of expert in Russian language Asya Pereltsvang, in
which she made conclusion that Russian word “mochit” does mean only “oppose” and could not be
translated as “kill”.
On February 28, 2020 court Granted anti-SLAPP motion.
On March 6, 2020 Plaintiff filed motion for reconsideration.
On March 6, Defendant Luba Chernov filed opposition to my motion to reconsider.
Arguments
I presented new interpretation of law and explained judge what will happen if order isi going forward.
Anybody can tell\write false statements to the court and then be protected by anti-SLAPP law with
reference to this order. At least in California, where order is issued. And second one, translator
declared by signature under penalty of perjury about wrong translation, so Constitution does not protect
lie in the court.
Conclusion
For the reasons set forth above, Petitioner respectfully requests the Court to reconsider and DENY anti-
SLAPP motion.
I declare under penalty of perjury under the laws of the Si
29 April 2020
aon the foregoing is true & correct.
/ Sergey Firsov /
PLAINTIFF’S REPLY IN SUPPORT OF HIS MOTION TO RECONSIDER
Document Filed Date
May 05, 2020
Case Filing Date
April 02, 2019
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From: Sergey Firsov iLE 333:Escuela avenue, apt 141 Mountain view, CA 94040 MAY 0 5 2020 +1 (650) 210-6804 rt Clerk of the hy Cou of Banta Clara Email: sfirsov1972@gmail.com pePI In Pro Per SUPERIOR COURT OF THE STATE OF CALIFO! IRNIA, SANTA CLARA COUNTY | 191 N. First street, San Jose, CA, 95113 SERGEY FIRSOV Civil unlimited case Ne 19CV345499 Plaintiff vs PLAINTIFF’S REPLY IN SUPPORT OF HIS YEVGENTY BABICHEV et al MOTION TO RECONSIDER THE 02/28/2020 ORDER Defendants GRANTING LUBA CHERNOV ANTI-SLAPP MOTION Hearing: 05/21/2020, 9.00 am Honor: | Thang Barret! Department 2D CC: To Defendant and to her attorney of record: Plaintiff SERGEY FIRSOV submits reply\objection in support of his motion to reconsider anti-SLAPP motion from Defendant Luba Chernov. Facts Luba Chernov is court certified translator. She has license to translate from Bel ian (registered), French (registered) and Ukrainian (registered) languages. On February 2019 she translated my email from Russian language to English and presented jit as evidence in civil harassment case 19CH008591 “Berman vs Firsov”. She ‘translated Russian ord “mochit” as “kill”. Due her translation I was arrested for death threat and spent in jail 1 day. On March 2019 another court certified translator Alexander Bantov translated my email from Russian language to English. He translated Russian word “mochit” as “oppose”. Police closed my criminal case for death threat, because there i is no evidence. At February 5, 2020 I filed declaration of expert in Russian language Asya Pereltsvang, in which she made conclusion that Russian word “mochit” does mean only “oppose” and could not be translated as “kill”. On February 28, 2020 court Granted anti-SLAPP motion. On March 6, 2020 Plaintiff filed motion for reconsideration. On March 6, Defendant Luba Chernov filed opposition to my motion to reconsider. Arguments I presented new interpretation of law and explained judge what will happen if order isi going forward. Anybody can tell\write false statements to the court and then be protected by anti-SLAPP law with reference to this order. At least in California, where order is issued. And second one, translator declared by signature under penalty of perjury about wrong translation, so Constitution does not protect lie in the court. Conclusion For the reasons set forth above, Petitioner respectfully requests the Court to reconsider and DENY anti- SLAPP motion. I declare under penalty of perjury under the laws of the Si 29 April 2020 aon the foregoing is true & correct. / Sergey Firsov / PLAINTIFF’S REPLY IN SUPPORT OF HIS MOTION TO RECONSIDER