1087 – False Invoice Fabrication – Ly Construction $7,837 Remodel After Eviction
Invoice No. 2412 dated August 14 2024 from Ly Construction (license #1068334)
was issued to Phat Tran for work at 19235 Brynn Court.
The invoice claims $7,837 in carpet, stair, and vinyl flooring replacement,
performed immediately after eviction. No final walk-through, photographs, or tenant sign-off were provided.
Critical Irregularities
No lawful move-out or joint inspection under California Civil Code §1950.5(f).
Billed work is a remodel, not repair — vinyl installation and base-molding repainting are capital improvements.
Cost of $3,000 for carpet on a 3-year-old rental far exceeds Home Depot’s 98 ¢/sq ft rate (recorded in Exhibit T20 pricing).
Invoice falsely attributes “dog pee smell” despite pets being approved and documented in the lease addendum (Exhibit T10).
Paint and vinyl upgrades without notice constitute post-tenancy renovation, not tenant damage.
Repairs were completed by owner’s known associate Dave Ly, connecting back to Berkshire Hathaway agent Anna Ly — indicating self-dealing.
Indicators of Fraud and Mail/Wire Violations
Invoice transmitted by email between Tran and Ly (Exhibit email header) → 18 U.S.C. §1343 Wire Fraud.
Use of interstate email and banking instructions for inflated repairs → potential 18 U.S.C. §1957 Money Laundering.
Billing padded to support false “damages” claim → civil fraud under Cal. Civ. Code §1709 and §1710.
Constructive eviction supported by false repair justification → criminal theft by deception Penal Code §484.
Exhibit T10 – Pet Addendum: Authorizes dogs under lease; invalidates claim of “pet odor damage.”
Conclusion
The invoice is a post-eviction fabrication used to inflate loss values and legitimize fraudulent charges.
No inspection, photographs, or receipts were produced. The billing pattern matches predicate acts of mail and wire fraud.
This evidence establishes motive and financial gain in the unlawful removal of tenants.
