Charisse L. Smith
Director of Civil Code Enforcement
(909) 466-4907
[email protected]
Best Best & Krieger LLP | 2855 E. Guasti Road, Suite 400, Ontario, California 91761 Phone: (909) 989-8584 | Fax: (909) 944-1441 | bbklaw.com File No. 65318.30003
September 2, 2026
Via U.S.P.S. Regular & Certified, Return-Receipt Mail
ROYAL EXPRESS DELIVERY, INC.
5329 Baldwin Ave.
Temple City, CA 91730
ROYAL EXPRESS DELIVERY, INC.
Attn.: Sergey Vershinin, Agent for Service of Process
20132 Allentown Dr.
Woodland Hills, CA 91364
ROYAL EXPRESS DELIVERY, INC.
Attn.: Sergey Vershinin, Agent for Service of Process
22510 La Quilla Dr.
Chatsworth, CA 91311-1221
ROYAL EXPRESS DELIVERY, INC.
Attn.: Sergey Vershinin, Agent for Service of Process
20401 Lanark St.
Winnetka, CA 91306-1821
Re: 2295 N. Garey Avenue, Pomona, CA 91767-2330
APN: 8371-015-040 (“Subject Property”)
3-DAY NOTICE OF INTENT TO FILE LAWSUIT AND RECEIVERSHIP PETITION Dear Property Owner:
BEST BEST AND KRIEGER LLP serves as the City Attorney for the CITY OF POMONA (the “City”). In that capacity, we have been authorized and directed to write this 3-DAY NOTICE OF INTENT TO FILE LAWSUIT AND RECEIVERSHIP PETITION (the “Notice”) regarding the above-referenced Subject Property in which title records reflect that you are the owner. As such, you are responsible for maintaining the Subject Property in compliance with all local and state laws, including but not limited to the Pomona City Code (“PCC”), Pomona Zoning and Development Code (“PZD”), California Building Code (“CBC”), California Electrical Code (“CEC”), California Plumbing Code (“CPC”), California Health and Safety Code (“H&SC”), and the International Property Maintenance Code (“IPMC”) among others. Furthermore, if rental income is generated from the Subject Property, you are also responsible to adhere to the California Revenue and Taxation Code and Franchise Tax Board.
As you are aware, inspectors determined that substandard conditions exist at the Subject Property, using the definitions of substandard conditions found in California Health and Safety Code (“H&SC”) as stated in the attached Notices and Orders to Repair dated December 3, 2025 and December 12, 2025. The Notices and Orders were issued after numerous Administrative Citations had been issued and no action was taken to correct the violations. City officials have determined that the ongoing code violations and substandard conditions observed at the Subject Property constitute a nuisance, and your failure to abate, correct or remedy said violations has caused the City to proceed with all available recourse, including, but not limited to civil action to seek a court-appointed receiver to correct all violations. Please be advised ATTACHMENT NO. 1
65318.30003\45402301.1
2295 N. Garey Avenue, Pomona
September 2, 2026
Best Best & Krieger LLP
that in no less than three days following service of this Notice, the City intends to file a lawsuit and petition with the Superior Court of California, County of Los Angeles, for the appointment of a receiver to abate the nuisance conditions at the Subject Property referenced above, in accordance with H&SC section 17980, et seq. This Notice is being served to all parties in interest pursuant to H&SC § 17980.7(c).
The City intends to seek recovery of all fees and costs incurred for nuisance abatement pursuant to H&SC 17980.7(c)(11) and (d)(1) and applicable sections of the PCC . At the time of final resolution of this matter, these fees and costs could exceed $50,000.00, not including any abatement costs already incurred, fines and penalties issued, the cost of rehabilitation, or the receiver’s fees and costs. The Court may authorize the appointed receiver to sell the Subject Property free and clear of all liens and encumbrances before or after rehabilitation, to pay for all costs of the receivership action. To potentially avoid this litigation, you must contact me at the number listed below to discuss a viable plan to voluntarily bring the Subject Property into compliance with the City’s Notices in a timely and professional manner within 3 days from the receipt of this Notice. You must respond to this Notice in writing in order to avoid this office taking further legal action.
If you have any questions regarding the contents of this Notice and to discuss a viable rehabilitation plan, you may contact me at (909) 466-4907.
Sincerely,
BEST BEST & KRIEGER LLP
Charisse L. Smith
CLS:mtc
Enclosures: Notices and Orders to Repair dated December 3, 2025 and December 12, 2025 cc: Betty Donavanik (via email, [email protected] J.D. Whitaker (via email, [email protected])
C I T Y O F P O M O N A
5 0 5 S O U T H G A R E Y A V E N U E , P O M O N A , C A 9 1 7 6 6 w w w . p o m o n a c a . g o v
THE CITY OF
POMONA
December 3, 2025
Royal Express Delivery Inc.
20132 Allentown Drive
Woodland Hills, CA 91364
c/o Ivan Molchanov
2295 N. Garey Avenue
Pomona, CA 91767
NOTICE AND ORDER TO
REPAIR OR ABATE
Property Location:
VRed (“Subject Property”)
2295 N. Garey Avenue
Pomona, CA 91767
APN 8371-015-040
Case No.: CE 002680 2024
Dear Property Owner(s):
The City of Pomona (the “City”) Development Services Department, including Code Compliance Division and Building & Safety Division, are working with its citizens to improve its community. To achieve this goal, we are notifying owners of real property, including but not limited to residential, business, industrial and vacant lots, to promptly abate any and all conditions which constitute a public nuisance, and to thereafter maintain the property in good repair and in a clean condition at all times, pursuant to all applicable municipal, state and federal codes, including but not limited to the Pomona City Code (“PCC”), see https://library.municode.com/ca/pomona/codes/city_code?nodeId=SPAGEOR.
It has been determined by Development Services Department officials that the Subject Property contains unlawful conditions that constitute a public nuisance and which pose a substantial danger to the health, safety, and general welfare of the occupants, the surrounding community, and the public. These unlawful conditions are in violation of multiple provisions of law, including, but not limited to, the California Health and Safety Code (“HSC”) and PCC, among other applicable laws.
A. Violations Constituting a Public Nuisance; Order to Abate.
An inspection of your property on December 3, 2025 revealed condition(s) that constitute municipal code violations and a public nuisance. The noted item(s) on the violation and correction list below is/are present at the Subject Property.
VRED
2295 N. Garey Ave., Pomona, CA 91767
P A G E 2 O F 4
You are ordered to correct and fully abate the violations listed below in the Violations and Corrections List in the manner described on or by December 31, 2025.
B. Consequences for Maintaining a Public Nuisance.
It is a misdemeanor offense to maintain a public nuisance. Offenders are subject to prosecution and, if convicted, face fines and/or penalty assessments exceeding $1,000.00, probation, and/or jail. To avoid further legal action, you must comply with this notice in a timely manner. City forces may, at the option of the City, enter the Subject Property with a court order and abate the public nuisance.
Abatement and/or administrative fees and costs may be assessed, and if not paid, a lien may be placed against the Subject Property. Additionally, if the City undertakes an abatement action, items removed from the Subject Property may be disposed of without regard to salvage value. You may still be prosecuted even if the City selects this remedy.
C. Violations and Corrections List.
An investigation of the Subject Property was conducted on December 3, 2025, and the following unlawful conditions have been identified1, including violations of the PCC, Pomona Zoning and Development Code (“PZD”), California Building Code (“CBC”), California Electrical Code (“CEC”), California Plumbing Code (“CPC”) and/or the International Property Maintenance Code (“IPMC”) were observed and need your immediate attention to repair or abate:
Violation Code Description Action Required
PCC Sec. 18
222 (D)
The failure to secure and maintain against public access through any doorways, windows, and other openings into vacant or abandoned buildings or structures, and the failure to provide fencing to secure and prevent access to any vacant or abandoned building, structure or lot.
The building must be secured
within at all times.
PZD
Sec.620.E.3.c.3
All walls, fences and gates must be maintained in good repair and must be kept vertical,
Repair the damaged fence.
PZD
Sec.1310.F.1.
The following types of signs are prohibited:
Abandoned Signs. Remove the abandoned sign from
the property.
PCC Sec. 18
704(d)(2)
Properties shall be maintained free of graffiti, tagging, or similar markings by removal or painting over with an exterior grade paint that matches the color of the exterior of the surface.
Remove all graffiti on the
property.
PCC Sec. 18
222(J)
Any overgrown, unmaintained, under maintained, dead, decayed, diseased or hazardous tree, weeds, grass, vegetation.
All vegetation on the property
must be maintained and free of
weeds.
PCC Sec. 18
222 (C)
Any building or structure which is partially destroyed, damaged, abandoned, boarded up, dilapidated, or permitted to remain in a state of partial construction.
Repair the damage to the
building.
PCC Sec. 18
222(II)
II. Any real property, or any building or structure thereon, that is used by person to cause, allow, contribute to, permit, or suffer any of the following acts:
1. Disturbances of the peace;
2. Excessive and/or loud noise disturbances;
Remove all type of nuisance
activity from the property.
1 This may not be an exhaustive list of all violations, and the City retains the right to identify further violations as they are discovered.
VRED
2295 N. Garey Ave., Pomona, CA 91767
P A G E 3 O F 4
Violation Code Description Action Required
3. Consumption of alcohol in public and/or public intoxication;
4. Urination in public;
5. Harassment of passersby;
6. Theft, assault, battery, or vandalism;
7. Storage or sale of stolen goods;
8. Excessive littering;
9. Illegal parking or traffic violations;
10. Curfew violations;
11. School attendance violations;
12. Lewd and/or lascivious conduct; and/or
13. Excessive responses by the Police Department or other law enforcement personnel.
PCC Sec. 18
222(L)
The accumulation of dirt, litter, trash, junk, feces, or debris in doorways, adjoining sidewalks, walkways, courtyards, patios, parking lots, planters, yard areas, landscaped or other areas.
Remove all junk, trash and debris
from the entire property.
PCC Sec. 18
222(LL)
Any building or structure in a state of deterioration, including, but not limited to, peeling paint on a facade, broken windows, roof in disrepair, damaged porch, broken steps or other deterioration or disrepair, that is visible from the public right-of-way or from neighboring properties.
Repair the trim and remove any
chipping paint.
Corrective action for the above-listed violations must be taken by: 12/20/2025 Failure to correct the violation(s) by the indicated date may result in the issuance of an Administrative Citation and the imposition of an Administrative fine up to $1,000.00 per violation, per day the violation(s) continue to exist.
Failure to correct the violation(s) of the Building and Safety Code by the indicated date may result in the issuance of an Administrative Citation and the imposition of an Administrate fine up to $2,500.00 per violation (or more), per day the violation(s) continues to exist. You may also be subject to additional enforcement action including but not limited to criminal prosecution.
D. Right to Appeal.
You have the right to appeal this notice and order pursuant to Section 18-229 of the Pomona Zoning Ordinance. To exercise this right, you must submit a written request for a hearing to the City of Pomona, Development Services Department, 505 S. Garey Avenue, Pomona, CA 91766 within fifteen (15) days from the date of the first class mailing of this notice or from the date this notice is personally served upon you. If you fail to exercise your right to appeal, or if you do so in an untimely manner, your right of appeal shall be deemed waived.
A written request for a hearing must contain your name and daytime telephone number, the Subject Property address, and a statement why you believe the Code Compliance Inspector is incorrect or mistaken in determining that a public nuisance exists at the Subject Property. Upon receipt of a timely written request, you shall be notified of the date, time, and place to attend a hearing before a hearing officer. This individual shall determine the validity of the order to abate and/or correct a public nuisance. The officer shall also determine whether the Code Compliance Inspector has interpreted the Zoning Ordinance correctly and applied the law fairly and equitably in the handling of your case.
VRED
2295 N. Garey Ave., Pomona, CA 91767
P A G E 4 O F 4
Pursuant to HSC section 17980.6(c), you are hereby notified that you cannot retaliate against lessees of the Subject Property pursuant to Civil Code section 1942.5. Pursuant to HSC section 17980(d), you are hereby notified that, in accordance with Revenue and Taxation Code sections 17274 and 24436.5, a tax deduction may not be allowed for interest, taxes, depreciation, or amortization paid or incurred in this taxable year for the Subject Property.
Thank you for your prompt attention to the items listed above. If you have any questions or require additional information, please do not hesitate to contact the undersigned.
Sincerely,
_________________________________ _________________________________ Carlos Hernandez, Code Compliance Supervisor
Development Services Department
Code Compliance Division
Tele: (909) 620-2374
Email: [email protected]
CITY OF POMONA
505 S. Garey Avenue
Pomona, CA 91766
Office Hours: Monday – Thursday from 7:30 a.m. - 6:00 p.m.
Please Note: City Hall is closed on Fridays and Holidays.
THE CITY OF
POMONA
December 16,2025
Royal Express Delivery Inc.
20132 Allentown Drive
Woodland Hills, CA 91364
do Sergey Vershinin
Ivan Molchanov
2295 N. Garey Avenue
Pomona, CA 91767
NOTICE AND ORDER TO
REPAIR OR ABATE
Property Location:
VRed ("Subject Property")
2295 N. Garey Avenue
Pomona, CA 91767
APN 8371-015-040
Case No.: CE002680-2024
Dear Property Owner(s):
The City of Pomona (the "City") Development Services Department, including Code Compliance Division and Building & Safety Division, are working with its citizens to improve its community. To achieve this goal, we are notifying owners of real property, including but not limited to residential, business, industrial and vacant lots, to promptly abate any and all conditions which constitute a public nuisance, and to thereafter maintain the property in good repair and in a clean condition at all times, pursuant to all applicable municipal, state and federal codes, including but not limited to the Pomona City Code ("PCC"), see https://library.municode.com/ca/pomona/codeskity code?nodeId—SPAGEOR.
It has been determined by Development Services Depal Ejilent officials that the Subject Property contains unlawful conditions that constitute a public nuisance, and which pose a substantial danger to the health, safety, and general welfare ofthe occupants, the surrounding community, and the public. These unlawful conditions are in violation of multiple provisions of law, including, but not limited to, the California Health and Safety Code ("HSC") and PCC, among other applicable laws.
A. Violations Constituting a Public Nuisance; Order to Abate.
An inspection ofyour property on December 3, 2025, revealed condition(s) that constitute municipal code violations and a public nuisance. The noted item(s) on the violation and correction list below is/are present at the Subject Property.
CITY OF POMONA
505 SOUTH GAREY AVENUE, POMONA, CA 91766
www.pornonaca.gov
You are ordered to correct and fully abate the violations listed below in the Violations and Corrections List in the manner described on or by January 6, 2026.
B. Consequences for Maintaining a Public Nuisance.
It is a misdemeanor offense to maintain a public nuisance. Offenders are subject to prosecution and, if convicted, face fines and/or penalty assessments exceeding $1,000.00, probation, and/orjail. To avoid further legal action, you must comply with this notice in a timely manner. City forces may, at the option ofthe City, enter the Subject Property with a court order and abate the public nuisance.
Abatement and/or administrative fees and costs may be assessed, and if not paid, a lien may be placed against the Subject Property. Additionally, if the City undertakes an abatement action, items removed from the Subject Property may be disposed ofwithout regard to salvage value. You may still be prosecuted even ifthe City selects this remedy.
C. Violations and Corrections List.
An investigation ofthe Subject Property was conducted on December 3, 2025, and the following unlawful conditions have been identified% including violations of the PCC, Pomona Zoning and Development Code ("PZD"), California Building Code ("CBC"), California Electrical Code ("CEC"), California Plumbing Code ("CPC") and/or the International Property Maintenance Code ("IPMC") were observed and need your immediate attention to repair or abate:
Violation Code Description Action Required
PCC Sec. 18
222 (D)
The failure to secure and maintain against public access through any doorways, windows, and other openings into vacant or abandoned buildings or structures, and the failure to provide fencing to secure and prevent access to any vacant or abandoned building, structure or lot.
The building must be secured
within at all times.
PZD
Sec.620.E.3.c.3
All walls, fences and gates must be maintained in good repair and must be kept vertical, Repair the damaged fence.
PZD
Sec.1310.F.1.
The following types ofsigns are prohibited:
Abandoned Signs. Remove the abandoned sign from
the property.
PCC Sec. 18
704(d)(2)
Properties shall be maintained free of graffiti, tagging, or similar markings by removal or painting over with an exterior grade paint that matches the color ofthe exterior ofthe surface.
Remove all graffiti on the
property.
PCC Sec. 18
222(J)
Any overgrown, unmaintained, under maintained, dead, decayed, diseased or hazardous tree, weeds, grass, vegetation.
All vegetation on the property
must be maintained and free of
weeds.
PCC Sec. 18
222 (C)
Any building or structure which is partially destroyed, damaged, abandoned, boarded up, dilapidated, or permitted to remain in a state of partial construction.
Repair the damage to the
building.
This may not be an exhaustive list of all violations, and the City retains the right to identify further violations as they are discovered.
PAGE 2 OF 4
Violation Code Description Action Required
PCC Sec. 18
222(11)
II. Any real property, or any building or structure thereon, that is used by person to cause, allow, contribute to, permit, or suffer any ofthe following acts:
1. Disturbances ofthe peace;
2. Excessive and/or loud noise disturbances;
3. Consumption of alcohol in public and/or public intoxication;
4. Urination in public;
5. Harassment of passersby;
6. Theft, assault, battery, or vandalism;
7. Storage or sale ofstolen goods;
8. Excessive littering;
9. Illegal parking or traffic violations;
10. Curfew violations;
11. School attendance violations;
12. Lewd and/or lascivious conduct; and/or
13. Excessive responses by the Police Department or other law enforcement personnel.
Remove any/all type(s) of
nuisance activity from the
property.
PCC Sec. 18
222(L)
The accumulation of dirt, litter, trash, junk, feces, or debris in doorways, adjoining sidewalks, walkways, courtyards, patios, parking lots, planters, yard areas, landscaped or other areas.
Remove all junk, trash and debris
from the entire property.
PCC Sec. 18
222(LL)
Any building or structure in a state of deterioration, including, but not limited to, peeling paint on a facade, broken windows, roofin disrepair, damaged porch, broken steps or other
deterioration or disrepair, that is visible from the public right-of-way or from neighboring properties.
Repair the trim and remove any
chipping paint.
Corrective action for the above-listed violations must be taken by: 01/06/2026 c> Failure to correct the violation(s) by the indicated date may result in the issuance of an Administrative Citation and the imposition ofan Administrative fine up to $1,000.00 per violation, per day the violation(s) continue to exist.
=> Failure to correct the violation(s) ofthe Building and Safety Code by the indicated date may result in the issuance of an Administrative Citation and the imposition of an Administrate fine up to $2,500.00 per violation (or more), per day the violation(s) continues to exist. => You may also be subject to additional enforcement action including but not limited to criminal prosecution.
D. Right to Appeal.
You have the right to appeal this notice and order pursuant to Section 18-229 ofthe Pomona Zoning Ordinance. To exercise this right, you must submit a written request for a hearing to the City of Pomona, Development Services Department, 505 S. Garey Avenue, Pomona, CA 91766 within fifteen (15) days from the date ofthe first class mailing ofthis notice or from the date this notice is personally served upon you. Ifyou fail to exercise your right to appeal, or ifyou do so in an untimely manner, your right of appeal shall be deemed waived.
A written request for a hearing must contain your name and daytime telephone number, the Subject Property address, and a statement why you believe the Code Compliance Inspector is incorrect or mistaken PAGE 3 OF 4
in determining that a public nuisance exists at the Subject Property. Upon receipt of a timely written request, you shall be notified ofthe date, time, and place to attend a hearing before a hearing officer. This individual shall determine the validity ofthe order to abate and/or correct a public nuisance. The officer shall also determine whether the Code Compliance Inspector has interpreted the Zoning Ordinance correctly and applied the law fairly and equitably in the handling of your case.
Pursuant to HSC section 17980.6(c), you are hereby notified that you cannot retaliate against lessees ofthe Subject Property pursuant to Civil Code section 1942.5. Pursuant to HSC section 17980(d), you are hereby notified that, in accordance with Revenue and Taxation Code sections 17274 and 24436.5, a tax deduction may not be allowed for interest, taxes, depreciation, or amortization paid or incurred in this taxable year for the Subject Property.
Thank you for your prompt attention to the items listed above. Ifyou have any questions or require additional information, please do not hesitate to contact the undersigned. nc ly,
itaker, Code Compliance Manager
D velopment Services Department
C e Compliance Division
Tele: (909) 620-2374
Email: [email protected]
CITY OF POMONA
505 S. Garey Avenue
Pomona, CA 91766
Office Hours: Monday — Thursday from 7:30 a.m. - 6:00 p.m.
Please Note: City Hall is closed on Fridays and Holidays.
PAGE 4 OF 4
CERTIFIED MAILTM
CODE COMPLIANCE
CITY OF POMONA JA2680-2024
505 S GAREY AVE
POMONA CA 91766-3320 II
SANTA ANA CA 926
USPS CERTIFIED MAIL
II1ll 11
9414 8098 9864 3076 6767 00
ROYAL EXPRESS DELIV
20132 ALLENTOWN DR
WOODLAND HILLS CA
PITNEY BOWES
$9.449 US POSTAGEnm
FIRST-CLASS
028W0002311246
2000456282
ZIP 91766
DEC 12 2025
NI XI. 9
4., E 1 60.12/20/25
RETURN TO.ENDER Nr11-- ELIEWLE sS)1'
UNABLE TO F ORWARD
8C: 917E6332005 '''1677 -012.14-13-43
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