On September 07, 2021 a
Order to Show Cause
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
To: + 1 9097088586 Page: 15 of 16 GMT
2021 -1 0-06 17:56:03 19497435837 From: EdwardWa lace
\u y-
Bdward S. Wallace, Esq. (SBN 134973)
LAW OFFICES OF EDWARD S. WALLACE F | L E D WORMA
3 1371 Rancho Viejo Road, Suite 202 SUPERIOR gggillgggfikmmo.
éf322§’CA92675 CQESTBYEWARD‘NOD'STR'CT
$231333)?
Fax: (949) 743-5837 .
_ OCT—-6 2021 .
Email: ewallace.legal@yahoo.com
Attorney for Defendant SEMIH CIRIT and C-TECH-INC.; BY
Specially Appearing for Defendants FATMA HANDAN CIRIT;
DENIS BARAN CIRIT and SARINA BARAN SARGENT
\OOOxIOxM-pwma
SUPERIOR COURT OF THE STATE 0F CALIFORNIA
FOR THE COUNTY OF SAN BERNANDINO, JUSTICE CENTER
NQVALK, LLC,‘ ) Case No: CIv3132122277
)
'
J
Plaintiff,
I
)
)
SUPPLEMENTAL DECLARATION 0F
VS. )
FATMA HANDAN CIRIT IN OPPOSITION 7m
-
> To osc RE PRELIMINARY INJUNCTION p
SEMIH CIRIT; FATMA HANDAN CIRIT; > --
DENIS BARAN CIRIT; SARINA BERNA
i
SARGENT; C-TECH, INC.; NC QUEEN, INC.; >
Judge: .Hon. Wilfred J.Schneider, Jr.
-
YUN KYUNG; and DOES 1-100, inclusive. )
Dept: S32
‘
> Date: October 7,2021
) Tlmc: 9:00 am.
Defendants‘ )
NNNNNNNMNI—IflHHup—Aflwa—IH
)
I Fatma'Handan Cirit, declare as follows:
1. I am a competent adult over the age of 18 years and am a resident of the State of California
and a party defendant t0 the within action. The facts setvforth in this declaration are of me personal
knowledge, except for those matters stated. upon information and belief, and as to those matters, Ibelieve
them to be true. If called as a witness to testify, I c'ould And would competently testify to the folloWing:
2. My son Denis Cirit, who ls one 0f the Cirit Defendants sued by the Plaintiff herein, and ls
the owner of the parcel of property (Parcel Map 10583 Parcel 5) that has a pylon and upon which Plaintiff
is seeking install signage.
Page l
SUPPLEMENTAL DECLARATION OF FATMA HANDAN CIRIT
To:+19097088586 Page: 16 of 16 GMT
2021-1 0-06 17:56:03 19497435837
v _
‘
\a
From: Edward Wallace
1 3. In review of the Plaintiffs ex parte papers which now
are deemed the moving papers,
2 particularly the declaration of Dr. Khalil, I have found that the representations made therein are ndt
3 accurate and are in fact false.
4 4. Specifically, Exhibit D to the declaration of.Dr. Khalil represents that a city s_ign pgnnit has
5
been obtained for installation of signs on the pylon which on
.
sits the Defendant’s property. Upon close
6
inspection, itis apparent that Ekhibit D isnot a city sign permit for the pylons but rather pictfires and a
7
drawing depicting the pylon sign, and a receipt for a sign permit fee paid to the city for an unrelated sign
8
More specifically, a wall sign on the Plaintiff’s building at Parcel Map 153 19 Parcel
‘
3 for the Plaintiffs
9 I
tenant Biolife
_
10
5. Attached as part of Exhibit 1 to the Supplemental Qpposition filed concurrently herewith is
11
a picture of the building sign that corresponds to the permit that Plaintiff obtained and is referenced as
12
.
Exhibit D to Dr. Khalil’s declaration. It is not a permit for signage on the Defendant’s pylon but rather
I3
for the Plaintist pronertvf Also attached as part of Exhibit 1 t0 the Supplemental Opposition filed
14
concurrently herewith are documents which further identify the sign permit
and receipts as referencing the
15
sign permit for the building sign 0n Plaintiff’s property, not a sign permit to install signage on the
I ‘
Dcfendant’ s pylon
:j I
u
6. Attached as Exhibit 2 to the Supplemental Opposition filed concurrently herewith
18 I
isa Sign
Permit Application form from the City of San Bernardino which shows that the applicant for sign permit
19
must obtain authorization from the owner of the property upon which the
20 sign isintended to be situated
Plaintiff has not obtained the Defendant’ s authorization to
21 install a sign on the pylon on the Defendant’s
prbperty.
22
I
I declare under the penalty of perjury under the laws of the State
23 of California that the fo‘fegoing is
24 true and correct and that this declaration was executed this 5th day of October 2021 in Orange’County,
25 califomia.
26
27 mm film
FATIMA HANDAN CIRIT
28
Page 2
SUPPLEMENTAL DECLARATION 0F FATMA ,HANDAN CIRIT '7
Document Filed Date
October 06, 2021
Case Filing Date
September 07, 2021
Category
Other Real Property Unlimited
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To: + 1 9097088586 Page: 15 of 16 GMT 2021 -1 0-06 17:56:03 19497435837 From: EdwardWa lace \u y- Bdward S. Wallace, Esq. (SBN 134973) LAW OFFICES OF EDWARD S. WALLACE F | L E D WORMA 3 1371 Rancho Viejo Road, Suite 202 SUPERIOR gggillgggfikmmo. éf322§’CA92675 CQESTBYEWARD‘NOD'STR'CT $231333)? Fax: (949) 743-5837 . _ OCT—-6 2021 . Email: ewallace.legal@yahoo.com Attorney for Defendant SEMIH CIRIT and C-TECH-INC.; BY Specially Appearing for Defendants FATMA HANDAN CIRIT; DENIS BARAN CIRIT and SARINA BARAN SARGENT \OOOxIOxM-pwma SUPERIOR COURT OF THE STATE 0F CALIFORNIA FOR THE COUNTY OF SAN BERNANDINO, JUSTICE CENTER NQVALK, LLC,‘ ) Case No: CIv3132122277 ) ' J Plaintiff, I ) ) SUPPLEMENTAL DECLARATION 0F VS. ) FATMA HANDAN CIRIT IN OPPOSITION 7m - > To osc RE PRELIMINARY INJUNCTION p SEMIH CIRIT; FATMA HANDAN CIRIT; > -- DENIS BARAN CIRIT; SARINA BERNA i SARGENT; C-TECH, INC.; NC QUEEN, INC.; > Judge: .Hon. Wilfred J.Schneider, Jr. - YUN KYUNG; and DOES 1-100, inclusive. ) Dept: S32 ‘ > Date: October 7,2021 ) Tlmc: 9:00 am. Defendants‘ ) NNNNNNNMNI—IflHHup—Aflwa—IH ) I Fatma'Handan Cirit, declare as follows: 1. I am a competent adult over the age of 18 years and am a resident of the State of California and a party defendant t0 the within action. The facts setvforth in this declaration are of me personal knowledge, except for those matters stated. upon information and belief, and as to those matters, Ibelieve them to be true. If called as a witness to testify, I c'ould And would competently testify to the folloWing: 2. My son Denis Cirit, who ls one 0f the Cirit Defendants sued by the Plaintiff herein, and ls the owner of the parcel of property (Parcel Map 10583 Parcel 5) that has a pylon and upon which Plaintiff is seeking install signage. Page l SUPPLEMENTAL DECLARATION OF FATMA HANDAN CIRIT To:+19097088586 Page: 16 of 16 GMT 2021-1 0-06 17:56:03 19497435837 v _ ‘ \a From: Edward Wallace 1 3. In review of the Plaintiffs ex parte papers which now are deemed the moving papers, 2 particularly the declaration of Dr. Khalil, I have found that the representations made therein are ndt 3 accurate and are in fact false. 4 4. Specifically, Exhibit D to the declaration of.Dr. Khalil represents that a city s_ign pgnnit has 5 been obtained for installation of signs on the pylon which on . sits the Defendant’s property. Upon close 6 inspection, itis apparent that Ekhibit D isnot a city sign permit for the pylons but rather pictfires and a 7 drawing depicting the pylon sign, and a receipt for a sign permit fee paid to the city for an unrelated sign 8 More specifically, a wall sign on the Plaintiff’s building at Parcel Map 153 19 Parcel ‘ 3 for the Plaintiffs 9 I tenant Biolife _ 10 5. Attached as part of Exhibit 1 to the Supplemental Qpposition filed concurrently herewith is 11 a picture of the building sign that corresponds to the permit that Plaintiff obtained and is referenced as 12 . Exhibit D to Dr. Khalil’s declaration. It is not a permit for signage on the Defendant’s pylon but rather I3 for the Plaintist pronertvf Also attached as part of Exhibit 1 t0 the Supplemental Opposition filed 14 concurrently herewith are documents which further identify the sign permit and receipts as referencing the 15 sign permit for the building sign 0n Plaintiff’s property, not a sign permit to install signage on the I ‘ Dcfendant’ s pylon :j I u 6. Attached as Exhibit 2 to the Supplemental Opposition filed concurrently herewith 18 I isa Sign Permit Application form from the City of San Bernardino which shows that the applicant for sign permit 19 must obtain authorization from the owner of the property upon which the 20 sign isintended to be situated Plaintiff has not obtained the Defendant’ s authorization to 21 install a sign on the pylon on the Defendant’s prbperty. 22 I I declare under the penalty of perjury under the laws of the State 23 of California that the fo‘fegoing is 24 true and correct and that this declaration was executed this 5th day of October 2021 in Orange’County, 25 califomia. 26 27 mm film FATIMA HANDAN CIRIT 28 Page 2 SUPPLEMENTAL DECLARATION 0F FATMA ,HANDAN CIRIT '7