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Franklin County Ohio Clerk of Courts of the Common Pleas- 2024 Feb 12 4:21 PM-24CV001236
0G727 - F80
IN THE COURT OF COMMON PLEAS, FRANKLIN COUNTY, OHIO
CIVIL DIVISION
Star Leasing Company, LLC
fik/a Star Leasing Co.
4080 Business Park Drive
Columbus, OH 43204
Plaintiff,
Vv.
Case No.
Zariz Transport Inc.
Attn: Yaakov Guzelgul, Pres. Judge
7601 N Federal Hwy Ste 230B
Boca Raton, FL 33487-1668
and
Yaakov Guzelgul
4770 Fox Hunt Trail
Boca Raton, FL 33487
MOTION OF PLAINTIFF STAR LEASING COMPANY, LLC FOR
TEMPORARY RESTRAINING ORDER AND FOR PRELIMINARY
INJUNCTION
Pursuant to Rule 65 (A) of the Ohio Rules of Civil Procedure, plaintiff Star Leasing
Company, LLC (“Star”) hereby moves this Court for a Temporary Restraining Order
restraining and enjoining the defendant Zariz Transport, Inc., its officers, agents, servants,
employees, assigns, attorneys, and all other persons and entities in active concert or
participation with defendant Zariz Transport, Inc., from further use of the van trailers
(“Outstanding Trailers”) identified in the Affidavit of Keith Dixon in Support of Star
Leasing Company's Motion for Temporary Restraining Order and Preliminary Injunction
J
attached hereto as Exhibit 1 (“Dixon Affidavit’); and ordering that defendant Zariz
Franklin County Ohio Clerk of Courts of the Common Pleas- 2024 Feb 12 4:21 PM-24CV001236
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Transport, Inc. turn over immediate possession of those trailers to Star pending a hearing
on Star's Motion for Preliminary Injunction.
The remedy at law as contained in the Ohio replevin statute at R,C. §§2737.01 to
2737.19 is not available to Star in this case, since the defendant Zariz Transport, Inc. is a
foreign corporation; and all of the trailers that are the subject of this Motion for Temporary
Restraining Order are to Star’s knowledge located outside of the State of Ohio.
R.C, 2737.20 provides as follows:
In addition to, or in lieu of, any — other relief available under
sections 2737.01 to 2737.19 of the Revised Code, the court may grant_a
temporary restraining order, preliminary injunction, or permanent injunction
in accordance with the Rules of Civil Procedure. (Emphasis added).
Star would be entitled to seck temporary relief in the form of an Order for
Possession pursuant to the Ohio replevin statute at O.R.C. §§2737.01 to 2737.19 but for
defendant Zariz Transport, Inc,’s possession of the Outstanding Trailers outside of the State
of Ohio. Since the replevin remedy at law as contained in the Ohio replevin statute is not
available and therefore inadequate, Star is entitled to use injunctive relief to recover its
trailers. EBSCO Industries, Inc. v. Lilly, 840 F.2d 333, 335 (6th Cir, 1988), Furthermore,
O.R.C. §2737.20 expressly entitles Star to injunctive relief granting to Star the immediate
right to possess the Outstanding Trailers,
Indeed, the Tenth District Court of Appeals has confirmed Star’s right to injunctive
relief in a previous case involving Star as a plaintiff. In Star Leasing Co., v. G & S Metal
Cor nsultants, Inc., 2009 WL 714146 (Ohio 10" Dist.), the Court specifically held that Star
is entitled to injunctive relief and immediate return of its trailers, The facts in G&S were
substantially the same as the instant case, In G&S, the court aptly recognized that G&S
was an out of state defendant and the trailers that were subject of Star’s lease agreement
Franklin County Ohio Clerk of Courts of the Common Pleas- 2024 Feb 12 4:21 PM-24CV001236
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were located in Indiana. In that case, the trial court granted judgment to Star for injunctive
relief and ordered the defendant to return the trailers. After, the defendant failed to return
the trailers, the trial court held G&S in contempt. The Tenth District upheld the contempt
order and thus the order granting Star injunctive relief. Although G&S did involve post-
judgment equitable relief, the analysis of whether a court should grant the injunctive relief
does not change. In other words, regardless of whether Star seeks injunctive relief prior to
final judgment like in the instant case, or whether Star seeks injunctive relief post-
judgment, the courts will avail a creditor like Star injunctive relief when its collateral is
being wrongly withheld.
Finally, Star respectfully submits that unless the status quo is maintained by way
of an order (i) restraining defendant Zariz Transport, Inc., its respective officers, agents,
servants, employees, assigns, attorneys, and all other persons and entities in active concert
or participation with them, from further use of the Outstanding Trailers; and (ii) ordering
defendants defendant Zariz Transport, Inc., its respective officers, agents, servants,
employees, assigns, attorneys, and all other persons and entities in active concert or
participation with them to turn over possession of the Outstanding Trailers to Star, Star
will be irreparably harmed by their continued use of the Outstanding Trailers, Defendant
Zariz Transport, Inc. has ignored Star’s request for immediate turnover of the Outstanding
Trailers, (See Dixon Affidavit, 99, 10.
Respectfully submitted,
/s/ James H. Gordon
James H, Gordon (0017155)
Gordon Law Firm Co., LPA
7677 Patterson Road
Hilliard, OH 43026
(614) 529-0888
Franklin County Ohio Clerk of Courts of the Common Pleas- 2024 Feb 12 4:21 PM-24CV001236
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(614) 529-0850 (fax)
jgordon@gordonlawco,com
/s/ Steven E. Miller
Steven E. Miller (0066489)
Amundsen Davis, LLC
500 S. Front Street, Suite 1200
Columbus, OH 43215
(614) 229-4537
(614) 220-4559 (fax)
Attorneys for Plaintiff
Star Leasing Company, LLC
fik/a Star Leasing Co.
Franklin County Ohio Clerk of Courts of the Common Pleas- 2024 Feb 12 4:21 PM-24CV001236
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EXHIBIT t
IN THE COURT OF COMMON PLEAS, FRANKLIN COUNTY, OHIO
CIVIL DIVISION
Star Leasing Company, LLC
f/k/a Star Leasing Co,
4080 Business Park Drive
Columbus, OH 43204
Plaintiff,
¥.
i Case No.
Zariz Transport Inc,
Attn: Yaakov Guzelgul, Pres, : Judge
7601 N Federal Hwy Ste 230B
Boca Raton, FL 33487-1668
and
Yaakoy Guzelgul
4770 Fox Hunt Trail
Boca Raton, FL 33487
AFFIDAVIT OF KEITH DIXON IN SUPPORT OF MOTION OF PLAINTIFF
STAR LEASING COMPANY, LLC FOR TEMPORARY RESTRAINING ORDER
AND PRELIMINARY INJUNCTION
STATE OF OHIO )
SS:
COUNTY OF FRANKLIN)
Now comes the undersigned, being first duly cautioned and sworn, and states the
following according to his personal information and belief:
1 Iam Keith Dixon, Credit Manager of Star Leasing Company, LLC, (“Star”),
the plaintiff in this litigation, As such I am primary custodian of Star’s records,
2. Star is engaged in the business of leasing, sale, maintenance, and repair of
van and flatbed trailers and intermodal chassis.
Franklin County Ohio Clerk of Courts of the Common Pleas- 2024 Feb 12 4:21 PM-24CV001236
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3. Defendant Zariz Transport, Inc, is a Florida corporation licensed and
authorized to do business in the state of Florida and other states,
4. On March 21, 2019, Zariz Transport, Inc. entered into a Master Trailer
Lease and Service Agreement (“Lease”) with Star, ultimately for the lease of 29 chassis.
True copies of the Lease, with related Schedules A, Normal Wear Schedule, and related
documents are attached to Star’s Complaint and collectively marked Exhibit 1,
5 Upon execution of the Lease, and in increments thereafter, Star made
chassis available to Zariz Transport, Inc. according to the specifications identified in the
Lease and Schedules A. Star has delivered all of the chassis to Zariz Transport, Inc., and
Zariz Transport, Inc. has accepted all of the chassis.
6. Star has complied with all of the terms and conditions of the Lease and is
not in default thereof, Star has performed everything required of it to be performed in order
to entitle Stat to lease and maintenance service payments from Zatiz Transport, Inc.
7 Zariz Transport, Inc, has defaulted under the payment terms of the Lease,
having failed to make payments thereunder due June 20, 2023 and thereafter,
8 Zariz Transport, Inc. owes to Star on the Lease the sum of $105,414.95 as
of February 5, 2024, representing the amount then recoverable pursuant to the default
provisions of the Lease before acceleration of Fixed Charges due under the Lease, as well
as the assessment of physical damage charges, interest, attorney fees, and court costs,
9. Based upon Zariz Transport, Inc,’s default as aforesaid, Star terminated the
Lease on October 5, 2023 and demanded return of its chassis, Despite that termination and
demand, Zariz Transport, Inc, has wrongfully failed to return its chassis as further detailed
below.
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10. As of January 29, 2024, the following twenty-nine (29) chassis owned by
Star remained in the possession or control of Zariz Transport, Inc., whose principal place
of business is in the State of Florida:
LEST ARS
16403CQ540 LIRC41372G1013605 40" CHASSIS 2016 $15,500.00
1702CWQ530 LIRC41263H1001392 40" CHASSIS 2017 $14,800.00
1702CWQ531 LJRC41262H1001397. 40" CHASSIS 2017 $14,800.00
1702CWQ532 LJRC41269H1001400 40" CHASSIS 2017 $14,800.00
1702CWQ534 LIRC41268H1001422 40" CHASSIS 2017 $14,800.00
1702CWQ537 LJRC41264H1001448 40" CHASSIS 2017 $14,800.00
17402CQ201 LJRC41269H1044554— 40" CHASSIS 2017 $15,000.00
17402CQ211 LIRC41260H1044569 40" CHASSIS 2017 $15,000,00
17403CQ875 LJRC41373H1030303 40" CHASSIS 2017 $17,000.00
17403CQ876 LIRC41375H1030304 40" CHASSIS 2017 $17,000.00
20402CQ790 LIRC41264LT007666 40" CHASSIS 2020 $17,500,00
20402CQ791 LJRC41263LT007674 40" CHASSIS 2020 $17,500.00
20402CQ792 LIRC41265LT007675 40" CHASSIS 2020 $17,500.00
20402CQ793 LIRC41269LT007677 40" CHASSIS 2020 $17,500.00
20402CQ794 LJRC41261LT007723 40" CHASSIS 2020 $17,500.00
20402CQ795 LJRC41263LT007724 40" CHASSIS 2020 $17,500.00
20402CQ796 LIRC41265LT007725 40" CHASSIS 2020 $17,500.00
20402CQ797 LIRC41267LT007726 40" CHASSIS 2020 $17,500.00
20402CQ798 LIRC4126XLT007736 40" CHASSIS 2020 $17,500.00
20402CQ799 LJRC41265LT007739 40" CHASSIS 2020 $17,500.00
20402CQ800 LIRC41265LT007742 40" CHASSIS 2020 $17,500,00
20402CQ801 LJRC41264LT007750 40" CHASSIS 2020 $17,500.00
20402CQ802 LJRC41265LT007756 40" CHASSIS 2020 $17,500.00
20402CQ803 LJRC41267LT007774 40" CHASSIS 2020 $17,500.00
20402CQ804 LIRC41260LT007776 40" CHASSIS 2020 $17,500.00
22403CQ832 SJYMP403SNPC24575 40" CHASSIS 2022 $29,000.00
22403CQ833 SJYMP4037NPC24576 40". CHASSIS 2022 $29,000.00
22403CQ834 SJYMP4039NPC24577 40" CHASSIS 2022 $29,000.00
22403CQ835 SJYMP4030NPC24578 40" CHASSIS 2022 $29,000.00
Franklin County Ohio Clerk of Courts of the Common Pleas- 2024 Feb 12 4:21 PM-24CV001236
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(“Outstanding Chassis”).
lt. Zariz Transport, Inc., under the direction and control of its president,
Yaakov Guzelgul, continues to operate or otherwise use the Outstanding Chassis, which
are depreciating daily by that use.
12, Zariz Transport, Inc, and its President Yaakov Guzelgul are wrongfully
detaining the Outstanding Chassis.
13, In the event the requested Temporary Restraining Order is delayed until
Zariz Transport, Inc. is given the opportunity for hearing on this matter, there is present
danger that (a) Zariz Transport, Inc. and Yaakov Guzelgul may conceal the Outstanding
Chassis or otherwise keep the Outstanding Chassis beyond the jurisdiction of this Court
and out of the rightful possession of Star; and (b) the value of the Outstanding Chassis will
be substantially further impaired.
14. Star will be irreparably injured if an Order of Possession and a Restraining
Order are delayed until Zariz Transport, Inc, and Yaakov Guzelgul are given the
opportunity for hearing.
15. Star’s Outstanding Trailers were not taken for a tax, assessment, or fine
pursuant to statute or seized under execution of judgment against Star,
FURTHER AFFIANT SAYETH NAUGHT,
Keith Dixon
Sworn to before me and subscribed in my presence this st day of February, 2024.
STUART J SPRIGLER
Gig
Se Sp
ae Notary Public
State of Ohio
ay Fo= fy Comm, Expires Notary Public’
December 22, 2024
Preview
Franklin County Ohio Clerk of Courts of the Common Pleas- 2024 Feb 12 4:21 PM-24CV001236 0G727 - F80 IN THE COURT OF COMMON PLEAS, FRANKLIN COUNTY, OHIO CIVIL DIVISION Star Leasing Company, LLC fik/a Star Leasing Co. 4080 Business Park Drive Columbus, OH 43204 Plaintiff, Vv. Case No. Zariz Transport Inc. Attn: Yaakov Guzelgul, Pres. Judge 7601 N Federal Hwy Ste 230B Boca Raton, FL 33487-1668 and Yaakov Guzelgul 4770 Fox Hunt Trail Boca Raton, FL 33487 MOTION OF PLAINTIFF STAR LEASING COMPANY, LLC FOR TEMPORARY RESTRAINING ORDER AND FOR PRELIMINARY INJUNCTION Pursuant to Rule 65 (A) of the Ohio Rules of Civil Procedure, plaintiff Star Leasing Company, LLC (“Star”) hereby moves this Court for a Temporary Restraining Order restraining and enjoining the defendant Zariz Transport, Inc., its officers, agents, servants, employees, assigns, attorneys, and all other persons and entities in active concert or participation with defendant Zariz Transport, Inc., from further use of the van trailers (“Outstanding Trailers”) identified in the Affidavit of Keith Dixon in Support of Star Leasing Company's Motion for Temporary Restraining Order and Preliminary Injunction J attached hereto as Exhibit 1 (“Dixon Affidavit’); and ordering that defendant Zariz Franklin County Ohio Clerk of Courts of the Common Pleas- 2024 Feb 12 4:21 PM-24CV001236 0G727 - F81 Transport, Inc. turn over immediate possession of those trailers to Star pending a hearing on Star's Motion for Preliminary Injunction. The remedy at law as contained in the Ohio replevin statute at R,C. §§2737.01 to 2737.19 is not available to Star in this case, since the defendant Zariz Transport, Inc. is a foreign corporation; and all of the trailers that are the subject of this Motion for Temporary Restraining Order are to Star’s knowledge located outside of the State of Ohio. R.C, 2737.20 provides as follows: In addition to, or in lieu of, any — other relief available under sections 2737.01 to 2737.19 of the Revised Code, the court may grant_a temporary restraining order, preliminary injunction, or permanent injunction in accordance with the Rules of Civil Procedure. (Emphasis added). Star would be entitled to seck temporary relief in the form of an Order for Possession pursuant to the Ohio replevin statute at O.R.C. §§2737.01 to 2737.19 but for defendant Zariz Transport, Inc,’s possession of the Outstanding Trailers outside of the State of Ohio. Since the replevin remedy at law as contained in the Ohio replevin statute is not available and therefore inadequate, Star is entitled to use injunctive relief to recover its trailers. EBSCO Industries, Inc. v. Lilly, 840 F.2d 333, 335 (6th Cir, 1988), Furthermore, O.R.C. §2737.20 expressly entitles Star to injunctive relief granting to Star the immediate right to possess the Outstanding Trailers, Indeed, the Tenth District Court of Appeals has confirmed Star’s right to injunctive relief in a previous case involving Star as a plaintiff. In Star Leasing Co., v. G & S Metal Cor nsultants, Inc., 2009 WL 714146 (Ohio 10" Dist.), the Court specifically held that Star is entitled to injunctive relief and immediate return of its trailers, The facts in G&S were substantially the same as the instant case, In G&S, the court aptly recognized that G&S was an out of state defendant and the trailers that were subject of Star’s lease agreement Franklin County Ohio Clerk of Courts of the Common Pleas- 2024 Feb 12 4:21 PM-24CV001236 0G727 - F8 were located in Indiana. In that case, the trial court granted judgment to Star for injunctive relief and ordered the defendant to return the trailers. After, the defendant failed to return the trailers, the trial court held G&S in contempt. The Tenth District upheld the contempt order and thus the order granting Star injunctive relief. Although G&S did involve post- judgment equitable relief, the analysis of whether a court should grant the injunctive relief does not change. In other words, regardless of whether Star seeks injunctive relief prior to final judgment like in the instant case, or whether Star seeks injunctive relief post- judgment, the courts will avail a creditor like Star injunctive relief when its collateral is being wrongly withheld. Finally, Star respectfully submits that unless the status quo is maintained by way of an order (i) restraining defendant Zariz Transport, Inc., its respective officers, agents, servants, employees, assigns, attorneys, and all other persons and entities in active concert or participation with them, from further use of the Outstanding Trailers; and (ii) ordering defendants defendant Zariz Transport, Inc., its respective officers, agents, servants, employees, assigns, attorneys, and all other persons and entities in active concert or participation with them to turn over possession of the Outstanding Trailers to Star, Star will be irreparably harmed by their continued use of the Outstanding Trailers, Defendant Zariz Transport, Inc. has ignored Star’s request for immediate turnover of the Outstanding Trailers, (See Dixon Affidavit, 99, 10. Respectfully submitted, /s/ James H. Gordon James H, Gordon (0017155) Gordon Law Firm Co., LPA 7677 Patterson Road Hilliard, OH 43026 (614) 529-0888 Franklin County Ohio Clerk of Courts of the Common Pleas- 2024 Feb 12 4:21 PM-24CV001236 0G727 - F8 (614) 529-0850 (fax) jgordon@gordonlawco,com /s/ Steven E. Miller Steven E. Miller (0066489) Amundsen Davis, LLC 500 S. Front Street, Suite 1200 Columbus, OH 43215 (614) 229-4537 (614) 220-4559 (fax) Attorneys for Plaintiff Star Leasing Company, LLC fik/a Star Leasing Co. Franklin County Ohio Clerk of Courts of the Common Pleas- 2024 Feb 12 4:21 PM-24CV001236 0G727 - F84 EXHIBIT t IN THE COURT OF COMMON PLEAS, FRANKLIN COUNTY, OHIO CIVIL DIVISION Star Leasing Company, LLC f/k/a Star Leasing Co, 4080 Business Park Drive Columbus, OH 43204 Plaintiff, ¥. i Case No. Zariz Transport Inc, Attn: Yaakov Guzelgul, Pres, : Judge 7601 N Federal Hwy Ste 230B Boca Raton, FL 33487-1668 and Yaakoy Guzelgul 4770 Fox Hunt Trail Boca Raton, FL 33487 AFFIDAVIT OF KEITH DIXON IN SUPPORT OF MOTION OF PLAINTIFF STAR LEASING COMPANY, LLC FOR TEMPORARY RESTRAINING ORDER AND PRELIMINARY INJUNCTION STATE OF OHIO ) SS: COUNTY OF FRANKLIN) Now comes the undersigned, being first duly cautioned and sworn, and states the following according to his personal information and belief: 1 Iam Keith Dixon, Credit Manager of Star Leasing Company, LLC, (“Star”), the plaintiff in this litigation, As such I am primary custodian of Star’s records, 2. Star is engaged in the business of leasing, sale, maintenance, and repair of van and flatbed trailers and intermodal chassis. Franklin County Ohio Clerk of Courts of the Common Pleas- 2024 Feb 12 4:21 PM-24CV001236 0G727 - F8 3. Defendant Zariz Transport, Inc, is a Florida corporation licensed and authorized to do business in the state of Florida and other states, 4. On March 21, 2019, Zariz Transport, Inc. entered into a Master Trailer Lease and Service Agreement (“Lease”) with Star, ultimately for the lease of 29 chassis. True copies of the Lease, with related Schedules A, Normal Wear Schedule, and related documents are attached to Star’s Complaint and collectively marked Exhibit 1, 5 Upon execution of the Lease, and in increments thereafter, Star made chassis available to Zariz Transport, Inc. according to the specifications identified in the Lease and Schedules A. Star has delivered all of the chassis to Zariz Transport, Inc., and Zariz Transport, Inc. has accepted all of the chassis. 6. Star has complied with all of the terms and conditions of the Lease and is not in default thereof, Star has performed everything required of it to be performed in order to entitle Stat to lease and maintenance service payments from Zatiz Transport, Inc. 7 Zariz Transport, Inc, has defaulted under the payment terms of the Lease, having failed to make payments thereunder due June 20, 2023 and thereafter, 8 Zariz Transport, Inc. owes to Star on the Lease the sum of $105,414.95 as of February 5, 2024, representing the amount then recoverable pursuant to the default provisions of the Lease before acceleration of Fixed Charges due under the Lease, as well as the assessment of physical damage charges, interest, attorney fees, and court costs, 9. Based upon Zariz Transport, Inc,’s default as aforesaid, Star terminated the Lease on October 5, 2023 and demanded return of its chassis, Despite that termination and demand, Zariz Transport, Inc, has wrongfully failed to return its chassis as further detailed below. Franklin County Ohio Clerk of Courts of the Common Pleas- 2024 Feb 12 4:21 PM-24CV001236 0G727 - F8 10. As of January 29, 2024, the following twenty-nine (29) chassis owned by Star remained in the possession or control of Zariz Transport, Inc., whose principal place of business is in the State of Florida: LEST ARS 16403CQ540 LIRC41372G1013605 40" CHASSIS 2016 $15,500.00 1702CWQ530 LIRC41263H1001392 40" CHASSIS 2017 $14,800.00 1702CWQ531 LJRC41262H1001397. 40" CHASSIS 2017 $14,800.00 1702CWQ532 LJRC41269H1001400 40" CHASSIS 2017 $14,800.00 1702CWQ534 LIRC41268H1001422 40" CHASSIS 2017 $14,800.00 1702CWQ537 LJRC41264H1001448 40" CHASSIS 2017 $14,800.00 17402CQ201 LJRC41269H1044554— 40" CHASSIS 2017 $15,000.00 17402CQ211 LIRC41260H1044569 40" CHASSIS 2017 $15,000,00 17403CQ875 LJRC41373H1030303 40" CHASSIS 2017 $17,000.00 17403CQ876 LIRC41375H1030304 40" CHASSIS 2017 $17,000.00 20402CQ790 LIRC41264LT007666 40" CHASSIS 2020 $17,500,00 20402CQ791 LJRC41263LT007674 40" CHASSIS 2020 $17,500.00 20402CQ792 LIRC41265LT007675 40" CHASSIS 2020 $17,500.00 20402CQ793 LIRC41269LT007677 40" CHASSIS 2020 $17,500.00 20402CQ794 LJRC41261LT007723 40" CHASSIS 2020 $17,500.00 20402CQ795 LJRC41263LT007724 40" CHASSIS 2020 $17,500.00 20402CQ796 LIRC41265LT007725 40" CHASSIS 2020 $17,500.00 20402CQ797 LIRC41267LT007726 40" CHASSIS 2020 $17,500.00 20402CQ798 LIRC4126XLT007736 40" CHASSIS 2020 $17,500.00 20402CQ799 LJRC41265LT007739 40" CHASSIS 2020 $17,500.00 20402CQ800 LIRC41265LT007742 40" CHASSIS 2020 $17,500,00 20402CQ801 LJRC41264LT007750 40" CHASSIS 2020 $17,500.00 20402CQ802 LJRC41265LT007756 40" CHASSIS 2020 $17,500.00 20402CQ803 LJRC41267LT007774 40" CHASSIS 2020 $17,500.00 20402CQ804 LIRC41260LT007776 40" CHASSIS 2020 $17,500.00 22403CQ832 SJYMP403SNPC24575 40" CHASSIS 2022 $29,000.00 22403CQ833 SJYMP4037NPC24576 40". CHASSIS 2022 $29,000.00 22403CQ834 SJYMP4039NPC24577 40" CHASSIS 2022 $29,000.00 22403CQ835 SJYMP4030NPC24578 40" CHASSIS 2022 $29,000.00 Franklin County Ohio Clerk of Courts of the Common Pleas- 2024 Feb 12 4:21 PM-24CV001236 0G727 - F87 (“Outstanding Chassis”). lt. Zariz Transport, Inc., under the direction and control of its president, Yaakov Guzelgul, continues to operate or otherwise use the Outstanding Chassis, which are depreciating daily by that use. 12, Zariz Transport, Inc, and its President Yaakov Guzelgul are wrongfully detaining the Outstanding Chassis. 13, In the event the requested Temporary Restraining Order is delayed until Zariz Transport, Inc. is given the opportunity for hearing on this matter, there is present danger that (a) Zariz Transport, Inc. and Yaakov Guzelgul may conceal the Outstanding Chassis or otherwise keep the Outstanding Chassis beyond the jurisdiction of this Court and out of the rightful possession of Star; and (b) the value of the Outstanding Chassis will be substantially further impaired. 14. Star will be irreparably injured if an Order of Possession and a Restraining Order are delayed until Zariz Transport, Inc, and Yaakov Guzelgul are given the opportunity for hearing. 15. Star’s Outstanding Trailers were not taken for a tax, assessment, or fine pursuant to statute or seized under execution of judgment against Star, FURTHER AFFIANT SAYETH NAUGHT, Keith Dixon Sworn to before me and subscribed in my presence this st day of February, 2024. STUART J SPRIGLER Gig Se Sp ae Notary Public State of Ohio ay Fo= fy Comm, Expires Notary Public’ December 22, 2024