This fully expanded briefing consolidates all verified evidence, statutory violations, enterprise relationships, concealment patterns, and predicate acts linked to Berkshire Hathaway HomeServices (BHHS), affiliated agents, attorneys, and the property owner. This document is written at DOJ criminal-RICO brief standard, integrating every known fact gathered from 2022–2025 and presenting it as a unified prosecutorial theory.
This is the final, maximum-substance version for law-enforcement intake (DA, FBI, DOJ, USPS-OIG, DRE Enforcement).
1. Mail Fraud — 18 U.S.C. §1341 (Expanded )
Between April and May 2024, the tenant delivered a certified USPS payment to the official Berkshire Hathaway Huntington Beach rental address dictated by the lease. The USPS scan shows it was signed for by “H.” — confirmed to be BHHS agent Hanson Le. The check was never returned, deposited, acknowledged, or disclosed. Instead, its disappearance was used to manufacture a fabricated rent-default scenario.
This act constitutes the foundational mail-fraud predicate in the RICO chain. The check’s disappearance allowed defendants to:
assert a false arrears,”
issue a fraudulent 3-Day Notice,
initiate unlawful detainer proceedings under false pretenses,
coerce a second payment,
and create a paper trail of “tenant nonpayment” that was entirely fictional.
The deliberate concealment of a certified instrument — followed by making sworn statements denying its existence — satisfies the intent to defraud element under §1341 and supports corporate liability due to BHHS’s failure to escalate or preserve evidence upon notice.
2. Wire Fraud — 18 U.S.C. §1343 (Expanded )
Rent was paid early every month via Wells Fargo transfers. Agent Hanson Le directed the tenant to continue sending rent to a private account outside the Berkshire Hathaway contractual payment pathway. These payments were received, acknowledged, and then retroactively denied in written and sworn statements months later.
The wire-fraud pattern includes:
Electronic misrepresentations about acceptable payment methods.
Instructions to route payments to accounts not listed in the lease.
Denial of those same payments later in court filings.
Transmission of knowingly false payment histories to legal counsel.
Use of email/text threats to coerce a duplicate payment under duress.
Exhibit: DL012 – May/June Deposits Action: Payment accepted electronically → then denied in filings Penalty: Up to 20 years imprisonment per fraudulent transmission Related Statutes: PC §532 (False Pretenses), PC §487 (Grand Theft)
This series of events constitutes a multi-actor wire-fraud conspiracy with BHHS agents communicating through email and SMS to advance a falsified arrears narrative.
3. Extortion — CA Penal Code §518 (Expanded )
After engineering the appearance of nonpayment, the defendants issued threats: pay immediately or suffer credit destruction. The demanded amount — approximately $20,000 — was not contractually owed, not judicially ordered, and not supported by any ledger. This constitutes pure extortion under color of legal authority.
The extortion scheme involved:
immediate threats to ruin a senior tenant’s credit rating,
demands for payment outside the lease and outside BHHS channels,
use of court filings to apply pressure (litigation extortion),
and financial coercion during a period of medical vulnerability.
Throughout 2022–2025, BHHS branding — including letterhead, lease templates, email signatures, corporate addresses, and franchise contracts — were used to induce trust and facilitate the tenancy.
Only after criminal activity was reported did corporate BHHS claim:
“We are not responsible for our affiliates. Stop contacting us.”
This constitutes:
B&P §17500 — False Business Representation
Corporate concealment of agent misconduct
Failure to preserve evidence upon formal notice
Possible vicarious liability under franchise law
Conspiracy through deliberate inaction
A franchise cannot use a national brand to gain trust and then claim no relationship when the brand’s agents commit fraud.
6. Perjury, Intent to Defraud & False Statements to Court (Expanded)
Attorney filings — including declarations of nonpayment — were made even after:
USPS proof of delivery,
bank deposit records,
owner admissions (“Hanson has the check”),
and certified letters to BHHS legal
A lawyer who continues to file false statements under these conditions commits:
CCP §128.7 — False Filings
PC §118 — Perjury
ABA Model Rule 3.3 — Failure of Candor to Tribunal
No reasonable attorney could “believe” nonpayment occurred once the certified tracking, digital banking records, and owner-confession text were presented.
7. Elder Targeting, Medical Harm & Civil Rights Violations (Expanded)
The tenant (age 72) and a co-resident elderly family member were subjected to:
eviction threats under false pretenses,
credit ruin threats,
forced relocation,
emotional trauma,
medical destabilization (cardiac monitor placed),
and police dismissal of clear fraud.
Legal implications:
WIC §15610.30 — Elder Financial Abuse
WIC §15610.07 — Neglect / Emotional Harm
Penal Code §368 — Elder Abuse
The eviction conduct foreseeably caused medical collapse — strengthening liability for emotional and consequential damages.