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1 COMPLAINT FOR ABATEMENT AND INJUNCTION

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MICHAEL N. FEUER, City Attorney, SBN 111529 MARY CLARE MOLIDOR, Chief, Crim. & Special Lit. Branch, SBN 82404 ARTURO A. MARTINEZ, Deputy Chief, Safe Neighborhoods & Gang Division, SBN 180355 JONATHAN CRISTALL, Assistant City Attorney, SBN 191935 LIORA FORMAN-ECHOLS, Assistant Supervising Deputy City Attorney, SBN 184135 JOSEPH L. GONZALEZ, Deputy City Attorney, SBN 303389 200 North Main Street, Room 966 Los Angeles, California 90012 Telephone: (213) 978-4090 Fax: (213) 978-8717 E-Mail: [email protected] Attorneys for Plaintiff [NO FEE - GOV’T CODE § 6103]

SUPERIOR COURT OF THE STATE OF CALIFORNIA

COUNTY OF LOS ANGELES, CENTRAL DISTRICT

THE PEOPLE OF THE STATE OF CALIFORNIA, Plaintiff, vs. HOVO STEPANIAN, aka OGANES STEPANIAN, an individual; and DOES 1 through 50, inclusive, Defendants.

) ) ) ) ) ) ) ) ) ) ) ) ) ) ) )

Case No.: COMPLAINT FOR ABATEMENT AND INJUNCTION

[CIVIL CODE SECTION 3479, ET SEQ.; HEALTH & SAFETY CODE SECTION 11570, ET SEQ.] [Unlimited Action]

Electronically FILED by Superior Court of California, County of Los Angeles on 02/02/2021 04:41 PM Sherri R. Carter, Executive Officer/Clerk of Court, by N. Alvarez,Deputy Clerk

Assigned for all purposes to: Stanley Mosk Courthouse, Judicial Officer: John Doyle

21STCV04201


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I. INTRODUCTION

1. THE PEOPLE OF THE STATE OF CALIFORNIA (the “People”) bring this action to

abate a dangerous gang stronghold and narcotics nuisance existing at 14697 Plummer St.,

Panorama City, CA 91402 (the “Property”). The Property, a single-family residence in a

residential neighborhood, is being used for gang-related crime by “Pacoima,” a notorious and

violent criminal street gang known to traffic narcotics throughout the San Fernando Valley.

Since Defendant HOVO STEPANIAN purchased the Property in 2019, Pacoima has used the

Property as a compound to store, distribute, and sell large quantities of methamphetamine and

for other gang-related business such as the storage of firearms and even attempted murders.

In the past seven months alone, the Los Angeles Police Department (“LAPD”) has had to use

its limited resources to conduct two separate widespread pursuits for criminal suspects at the

Property, requiring the deployment of numerous police officers and the use of police

helicopters: one after a shooting at the Property and another for armed gang members running

through the Property fleeing police. Over the same seven-month period, members of law

enforcement executed two search warrants at the Property, and both times recovered

narcotics, firearms, and ammunition there. The activity at the Property is an ongoing and

significant danger to people in the surrounding community and must be stopped in order to

protect their health and safety. The People bring this action pursuant to Civil Code section

3479, et seq. (the “Public Nuisance Law” or “PNL”) and Health and Safety Code section

11570, et seq. (the “Narcotics Abatement Law” or “NAL”).

2. On January 10, 2019, defendant HOVO STEPANIAN, 59, purchased the sprawling half-

acre Property with a 2,200 square foot four-bedroom, three-bath ranch style house for

$735,000 but, upon information and belief, never resided there and actually lives in an

apartment in Hollywood. This type of arrangement is not unusual for the Pacoima gang, which

has been known to use straw purchasers to acquire real property for the gang’s money-making

operations, including the trafficking and sale of narcotics, and, according to law enforcement,

the pattern of activity at the Property under defendant STEPANIAN’s ownership is consistent

with this practice.


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3. Almost immediately after STEPANIAN purchased the Property, narcotics-related and

other nuisance activity at the Property began. In or around January 2019, LAPD began

receiving complaints from members of the community about suspicious and inordinate

amounts of foot and vehicle traffic coming to and from the Property at all hours. According to

LAPD, the level of foot and vehicle traffic at the Property was consistent with narcotics sales.

Sure enough, in February 2019, LAPD made its first arrest for possession of

methamphetamine at the Property. Over the ensuing months, the Property quickly developed

a reputation in the community and among law enforcement as a place where narcotics are

sold.

4. In 2020, criminal activity at the Property escalated dramatically. On the evening of June

18, 2020, LAPD received a call of shots fired at the Property. LAPD responded with a large

police presence, including a police helicopter. Upon arrival at the Property, officers found

victim Juan Flores (a self-admitted North Hollywood Boys gang member known as “Skipper”)

with a gunshot wound to his chest. LAPD conducted a large-scale sweep of the area

searching for suspects, but were unable to locate the shooter. The next day, LAPD executed a

search warrant at the Property and recovered a firearm, ammunition, and methamphetamine

there. Upon investigating, LAPD identified the shooter as Richard Sanchez, a self-admitted

Pacoima Humphrey Boys gang member known as “Peter Guns,” who was living in an RV on

the Property. Sanchez was arrested and charged with attempted murder for this shooting.

5. On September 21, 2020, just three months after the shooting, LAPD was forced to

conduct another large-scale pursuit of a criminal suspect at the Property. On that evening,

officers patrolling the area observed a vehicle parked in front of the Property with multiple

passengers inside. As officers approached, passengers exited the vehicle and started walking

toward the Property. One of the passengers then tossed a gun on the ground, jumped the

fence onto the Property, and ran through the Property in an effort to escape police. Officers

immediately requested backup, including a police helicopter, and a chase for the suspect

ensued. Officers surrounded the Property and eventually apprehended the suspect.

6. In October 2020, the Los Angeles County Sheriff’s Department (“LASD”) received


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information about a Pacoima gang member selling large amounts of methamphetamine at the

Property. For two weeks, deputies surveilled the Property and observed heavy vehicle traffic

coming to and from the location. On October 13, 2020, LASD obtained and executed a search

warrant at the Property. During the search warrant, deputies encountered and detained 17

individuals at the Property. In one of the bedrooms, deputies found methamphetamine, heroin,

fentanyl, a digital scale, and plastic baggies, and arrested the individual who lived in the

bedroom for possession of controlled substances for sale. Deputies also recovered three

firearms throughout the Property, including a handgun with a silencer and an AR-15, all

believed to belong to Pacoima street gang members.

7. In yet another incident demonstrating the danger at the Property, on January 11, 2021,

officers arrested a Pacoima gang member leaving there with a loaded firearm. The incident

began when officers observed a vehicle leaving the Property and stopped it for a Vehicle Code

violation. During the stop, officers searched the car after learning the passenger was on

probation with search conditions and found a loaded 9mm handgun next to the driver’s seat, a

spent 9mm shell casing on the floor of the car, and a plastic bag containing additional

ammunition. The driver, a self-admitted Pacoima gang member and convicted felon, admitted

that the handgun and the ammunition were his, and officers arrested him.

8. In sum, under defendant STEPANIAN’s ownership, the Property has become a

dangerous Pacoima gang stronghold where shootings occur, where gang members carry and

keep firearms, and where narcotics are stored, distributed, and sold. To protect the health and

safety of the community from the ongoing dangerous and illegal activity at the Property,

immediate and substantial action must be taken. The intent of this nuisance abatement

prosecution is to compel such action as is necessary to bring the violence and other unlawful

activity at the Property to a swift and permanent halt.

II. THE PARTIES AND THE PROPERTY

A. Plaintiff

9. Plaintiff, the People, is the sovereign power of the State of California designated in

Code of Civil Procedure section 731 and California Health and Safety Code section 11571 to


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be the complaining party in public law enforcement actions brought to abate, enjoin, and

penalize public and narcotics nuisances.

B. The Defendants

10. Defendant HOVO STEPANIAN, aka OGANES STEPANIAN, 59, an individual, is the

owner of the Property. He has owned the Property since January 10, 2019.

11. The true names and capacities of defendants sued herein as Does 1 through 50,

inclusive, are unknown to Plaintiff, who therefore sues said defendants by such fictitious

names. When the true names and capacities of said defendants have been ascertained,

Plaintiff will ask leave of the court to amend this complaint and to insert in lieu of such fictitious

names the true names and capacities of said fictitiously named defendants.

C. The Property

12. The Property’s common address is 14697 Plummer St., Panorama City, CA 91402.

The Property’s APN is: 2650-025-009. The Property’s legal description is as follows: Parcel 1: That Portion of the West 765.00 feet of Lot 27 of Tract No. 1584, in the City of Los Angeles, County of Los Angeles, State of California, As Per Map Recorded in Book 22, Pages 174 and 175 of Maps, in the Office of the County Recorder of Said County; Bounded as Follows: Bounded on the North by the Southerly Line of Tract No. 21982, in Said City, County and State, As Per Map Recorded in Book 598 Pages 51 and 52 of Maps, Records of the Said County; Bounded on the East by East Line of the West 75.00 of Said Lot; Bounded on the South by the North Line of the South 266.67 Feet of Said Lot; Bounded On the West by the West Line of Said Lot. Parcel 2: The Southerly 266.67 Feet of the Westerly 75.00 Feet of Lot 27 of Tract No. 1584, in the City of Los Angeles, County of Los Angeles, State of California, As Per Map Recorded in Book 22 Pages 174 and 175 of Maps, in the Office of the County Recorder of Said County.


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14697 Plummer St. (street view)

14697 Plummer St. (aerial view)

III. THE PUBLIC NUISANCE LAW

13. Civil Code section 3479 defines a public nuisance as “[a]nything which is injurious to

health, including, but not limited to, the illegal sale of controlled substances, or is indecent or

offensive to the senses, or an obstruction to the free use of property, so as to interfere with the

comfortable enjoyment of life or property. . . .” (See City of Bakersfield v. Miller (1966) 64

Cal.2d 93, 99 [“The Legislature has defined in general terms the word 'nuisance' in Civil Code

section 3479. . . .”].)

14. Civil Code section 3480 defines a public nuisance as “one which affects at the same

time an entire community or neighborhood, or any considerable number of persons, although


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the extent of the annoyance or damage inflicted upon individuals may be unequal.” In

particular, drug dealing, loitering, consumption of alcohol and illegal drugs, and boisterous

conduct which creates a hooligan-like “atmosphere” constitutes a public nuisance. (People ex

rel. Gallo v. Acuna (1997) 14 Cal.4th 1090, 1120.)

15. Under Civil Code section 3491, the “remedies against a public nuisance are: 1.

Indictment or information; 2. A civil action; or, 3. Abatement.” “An abatement of a nuisance is

accomplished by a court of equity by means of an injunction proper and suitable to the facts of

each case.” (Sullivan v. Royer (1887) 72 Cal. 248, 249.)

16. Code of Civil Procedure section 731 authorizes a city attorney to bring an action to

enjoin or abate a public nuisance. It provides, in pertinent part, “A civil action may be brought

in the name of the people of the State of California to abate a public nuisance . . . by the city

attorney of any town or city in which the nuisance exists.” (Ibid.)

IV. THE NARCOTICS ABATEMENT LAW

17. Since its enactment in 1972, the principal purpose of the NAL (Health & Saf. Code, §

11570, et seq.) is the abatement of buildings and places “used for the purpose of unlawfully

selling, serving, storing, keeping, manufacturing, or giving away any controlled substance,

precursor, or analog specified in this division . . . .” (Health & Saf. Code, § 11570).

18. The NAL provides that every building or place used for the purpose of unlawfully selling,

serving, storing, keeping, manufacturing, or giving away any controlled substance, precursor,

or analog inter alia, “is a nuisance which shall be enjoined, abated, and prevented . . . whether

it is a public or private nuisance.” (Health & Saf. Code, § 11570 (emphasis added); People ex

rel Lungren v. Peron (1997) 59 Cal.App.4th 1383, 1389; Lew v. Superior Court (1993) 20

Cal.App.4th 866, 870-871.)

19. Health and Safety Code section 11571 authorizes a city attorney to bring an action to

abate, prevent and perpetually enjoin such nuisances. It provides in relevant part: “Whenever

there is reason to believe that a nuisance as described in Section 11570 is kept, maintained, or

exists in any county, the district attorney of the county, or the city attorney of any incorporated

city or of any city and county, in the name of the people, may . . . maintain an action to abate


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and prevent the nuisance and perpetually to enjoin the person conducting or maintaining it,

and the owner, lessee, or agent of the building or place in or upon which the nuisance exists

from directly or indirectly maintaining or permitting the nuisance.”

20. Health and Safety Code section 11581 provides for, as a potential remedy, the removal

and sale of all fixtures and movable property on the premises used in aiding or abetting the

nuisance, and for the closure of the building for up to one year.

V. FIRST CAUSE OF ACTION FOR PUBLIC NUISANCE

[Civil Code section 3479, et seq.

Against All Defendants]

21. Plaintiff incorporates by reference Paragraphs 1 through 20 of this Complaint and

makes them part of this First Cause of Action as though fully set forth herein.

22. From January 10, 2019 to the present, the Property has been owned, operated,

managed and used, and/or directly or indirectly permitted to be occupied and used, in such a

manner as to constitute a public nuisance under Civil Code sections 3479 and 3480. The

public nuisance, as described herein, is injurious to health, indecent or offensive to the senses,

and/or an obstruction to the free use of property, so as to substantially and unreasonably

interfere with the comfortable enjoyment of life or property by those in the surrounding

community. The public nuisance consists of, but is not limited to: shootings; unlawfully armed

gang members at, and coming to and from, the Property; the illegal presence of firearms at the

Property; and the storage and sale of narcotics at the Property.

23. Defendant STEPANIAN, who owns and controls the Property, knew or should have

known of the nuisance, and has failed to take reasonable steps to prevent or abate it. As a

result of this failure and mismanagement of the Property, STEPANIAN has permitted and

allowed the Property to become a serious threat to the safety and welfare of persons in the

surrounding community.

24. Unless defendant STEPANIAN is restrained and enjoined by order of this Court, he will

continue to own and maintain the Property, together with the fixtures and appurtenances


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located therein, for the purpose complained of herein, to the great and irreparable damage of

the People, and in violation of California law.

VI. SECOND CAUSE OF ACTION FOR NARCOTICS ABATEMENT

[Health and Safety Code Section 11570, et seq. --

Against All Defendants]

25. Plaintiff hereby incorporates by reference paragraphs 1 through 24 of this Complaint

and makes them part of the Second Cause of Action, as if fully set forth herein.

26. Since at least January 2019, the Property has been, and continues to be, used to store,

distribute, and/or sell methamphetamine, in violation of Health and Safety Code section 11570,

et seq.

27. The Property has a reputation in the community and amongst law enforcement as place

where narcotics are stored, distributed, sold and/or used.

28. Defendant STEPANIAN is responsible for conducting, maintaining, and/or directly or

indirectly permitting the nuisance as alleged herein. Plaintiff has no plain, speedy, and

adequate remedy at law, and unless defendant STEPANIAN is restrained and enjoined by

order of this Court, he will continue to maintain or permit, directly or indirectly, the use,

occupation and maintenance of the Property, together with the fixtures and appurtenances

located therein, for the nuisance complained of herein, to the great and irreparable damage of

the public and in violation of California law.

PRAYER

WHEREFORE, PLAINTIFF PRAYS THAT THIS COURT ORDER, ADJUDGE, AND

DECREE AS FOLLOWS:

AS TO THE FIRST CAUSE OF ACTION

1. That the Property, together with the fixtures and moveable property therein and thereon,

be declared a public nuisance and be permanently abated as such in accordance with Civil

Code section 3491.

2. That defendant STEPANIAN, and DOES 1 through 50, and their agents, officers,

employees, and anyone acting on their behalf, and their heirs and assignees, be preliminarily


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and perpetually enjoined from operating, conducting, using, occupying, or in any way

permitting the use of the Property as a public nuisance. Such orders should include, but not

be limited to: termination of the tenancy of all current occupants at the Property; a requirement

that defendant STEPANIAN, and DOES 1 through 50, reside at the Property until the nuisance

is abated; and any such other orders as are appropriate to remedy the nuisance on the

Property.

3. That Plaintiff be granted such other and further relief as the Court deems just and

proper, including, if necessary, closure of the Property with monetary relocation assistance

paid by defendant STEPANIAN, and DOES 1 through 50, to qualified tenants, as provided by

applicable laws, rules and regulations.

4. Such costs as may occur in abating the nuisance at the Property and such other costs

as the Court shall deem just and proper.

AS TO THE SECOND CAUSE OF ACTION

5. That defendant STEPANIAN, and DOES 1 through 50, be declared in violation of Health

and Safety Code section 11570, et seq.

6. That the Property, together with the fixtures and moveable property therein and thereon,

be found to constitute a public nuisance and be permanently abated as such in accordance

with Section 11581 of the California Health and Safety Code.

7. That the Court grant a preliminary injunction, permanent injunction, and order of

abatement in accordance with Section 11570, et. seq., of the California Health and Safety

Code, enjoining and restraining defendant STEPANIAN, and DOES 1 through 50, and their

agents, officers, employees and anyone acting on their behalf, from unlawfully selling, serving,

storing, keeping, manufacturing, or giving away controlled substances on the Property, and/or

directly or indirectly maintaining or permitting such nuisance activity.

8. That the Court order managerial improvements to the Property in accordance with

California Health and Safety Code section 11573.5, and such orders as are otherwise

appropriate, to remedy the nuisance on the Property and enhance the abatement process,

including but not limited to, termination of the tenancy of all current tenants at the Property and


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a requirement that defendant STEPANIAN, and DOES 1 through 50, reside at the Property

until the nuisance is abated.

9. That as part of the Judgment, an Order of Abatement be issued, and that the Property

be closed for a period of one year, not to be used for any purpose, and be under the control

and custody of this Court for said period of time; or, in the alternative, if the Court deems such

closure to be unduly harmful to the community, that defendant STEPANIAN, and DOES 1

through 50, pay an amount of damages equal to the fair market rental value of the Property for

one year to the City or County in whose jurisdiction the nuisance is located in accordance with

Health and Safety Code section 11581 subdivision (c)(1).

10. That defendant STEPANIAN, and DOES 1 through 50, each be assessed a civil penalty

in an amount not to exceed twenty-five thousand dollars ($25,000.00).

11. That defendant STEPANIAN, and DOES 1 through 50, and their agents, trustees,

officers, employees and anyone acting on their behalf, and their heirs and assignees, be

perpetually enjoined from transferring, conveying, or encumbering any portion of the Property,

for consideration or otherwise, without first obtaining the Court’s prior approval.

12. That defendant STEPANIAN, and DOES 1 through 50, be ordered to immediately notify

any transferees, purchasers, commercial lessees, or other successors in interest to the subject

Property of the existence and application of any temporary restraining order, preliminary

injunction, or permanent injunction to all prospective transferees, purchasers, commercial

lessees, or other successors in interest, before entering into any agreement to sell, lease or

transfer the Property, for consideration or otherwise, all or any portion of the Property that is

the subject of this action.

13. That defendant STEPANIAN, and DOES 1 through 50, be ordered to immediately give a

complete, legible copy of any temporary restraining order and preliminary and permanent

injunctions to all prospective transferees, purchasers, lessees, or other successors in interest

to the Property.

14. That defendant STEPANIAN, and DOES 1 through 50, be ordered to immediately

request and procure signatures from all prospective transferees, purchasers, lessees, or other


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successors in interest to the subject Property, which acknowledges his/her respective receipt

of a complete, legible copy of any temporary restraining order, preliminary and permanent

injunction, at least 30 days prior to the close of escrow, and deliver a copy of such

acknowledgment to the Los Angeles City Attorney’s Office, c/o Deputy City Attorney Joseph L.

Gonzalez or his designee.

15. That the People recover the costs of this action, including law enforcement investigative

costs and any fees, including attorneys’ fees, authorized by law, not to exceed $1,000,000.00,

from defendant STEPANIAN and DOES 1 through 50.

16. That the People recover the amount of the filing fees and the amount of the fee for the

service of process or notices which would have been paid but for Government Code section

6103.5, designating it as such. The fees may, at the Court’s discretion, include the amount of

the fees for certifying and preparing transcripts.

17. That the People be granted such other and further relief as the Court deems just and

proper.

AS TO ALL CAUSES OF ACTION

18. That Plaintiff recover the amount of the filing fees and the amount of the fee for the

service of process or notices which would have been paid but for Government Code section

6103.5, designating it as such. The fees may, at the Court’s discretion, include the amount of

the fees for certifying and preparing transcripts.

19. That Plaintiff be granted such other and further relief as the Court deems just and

proper, including the appointment of a receiver to carry the Court’s judgment into effect.

//

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DATED: February 2, 2021

Respectfully submitted, MICHAEL N. FEUER, City Attorney JONATHAN CRISTALL, Assistant City Attorney By: /s/ Joseph L. Gonzalez_____ Deputy City Attorney Attorneys for Plaintiff, THE PEOPLE OF THE STATE OF CALIFORNIA

Documents

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