Exhibit Title: DL-A03-E — Corporate Pattern of Fraud, Extortion, and Misrepresentation under Berkshire Hathaway HomeServices California Properties
Core Assertion: A coordinated enterprise operated under the Berkshire Hathaway HomeServices (BHHS) brand engaged in interstate communications and contractual fraud through its agents and associates, including Hanson Le, Anna Ly, Phat Tran, and Ethos Property. The communications demonstrate continuity of representation, use of the BHHS corporate seal and branding, and execution of falsified contracts for private enrichment, constituting predicate acts under 18 U.S.C. § 1961–1968 (RICO).
Evidence: Authentisign confirmation showing Hanson Le (hansonle@bhhscaprops.com) completed an electronic signature for a lease renewal using the BHHS credentialed email and platform license.
Legal Relevance: Confirms electronic contract execution within BHHS systems, proving authority under company credentials.
Evidence: Form submission on berkshirehathawayhomeservices.com by Michael Gasio reporting that Hanson Le instructed payments to a private bank account.
Legal Relevance: Establishes notice to Berkshire Hathaway’s corporate web portal prior to eviction, binding BHHS via its own service channel and creating record of consumer fraud complaint.
Evidence: Documented incoming call and message logs from Berkshire Hathaway (Omaha NE) and from BHHS manager Dennis Rosas (Huntington Beach CA).
Legal Relevance: Demonstrates escalation to corporate chain-of-command; BHHS management had direct communication with the victim prior to eviction, confirming knowledge of ongoing dispute.
"We are aware you have contacted us, thank you good bye".
"Call Hanson he is 'moonlighting' they all do it - he is a good guy"
Evidence: After notification that police sought to speak with him regarding contract counterfeiting, Hanson Le sent a letter from his official BHHS email and letterhead disclaiming involvement but still using the corporate seal and CalBRE # 01358448.
Legal Relevance: Confirms ongoing representation and potential misrepresentation under Bus.&Prof.Code § 10176(a),(b); use of official marks post-notice supports counterfeit-instrument charge.
Evidence: SMS from Property Manager relaying police assessment: using the BHHS corporate seal in a contract “becomes counterfeiting … like printing your own money.”
Legal Relevance: Law-enforcement acknowledgment of counterfeit activity under Penal Code § 470 et seq.
Evidence: Email titled “Final attempt to negotiate a settlement,” sent to Hanson Le and Ethos Property before eviction, notifying them of unlawful activity and medical distress caused by their actions.
Legal Relevance: Establishes early notification and intent to resolve civilly; any subsequent eviction constitutes willful continuation of enterprise conduct post-notice.
This evidentiary chain demonstrates a continuous course of conduct linking BHHS agents and brand identifiers to a pattern of fraudulent leasing, document counterfeiting, and coordinated concealment of payments. The material satisfies the RICO continuity and relationship tests: multiple predicate acts, common participants, common purpose (rent diversion), and common enterprise identity (Berkshire Hathaway HomeServices California Properties).