Exhibit T100 – False Testimony & Fraud on the Court

Core Statement: In sworn testimony and filings, Dr. Phat Tran stated, “I never received payment.”
However, the April 22, 2022 DocuSign certificate proves the lease was executed and consideration tendered, making that statement perjury and fraud upon the court.

1. DocuSign Evidence

Signers: Anna Ly (Broker), Michael A. Gasio, Yulia S. Gasio
Execution Time: April 22, 2022, between 12:39–2:28 PM PT
IPs: 99.83.6.36 (Anna Ly), 107.184.22.75 (Michael & Yulia Gasio)
Source: certificate.pdf – DocuSign Completion Record

2. Prima Facie Evidence

The executed rental agreement and subsequent bank transfers constitute 27 independent predicate acts of wire and bank fraud under 18 U.S.C. §§ 1343 and 1344. Each act represents an electronic or banking event used to transmit, process, or later deny lawful funds, establishing a pattern of racketeering activity under 18 U.S.C. § 1962(c).

3. Predicate Acts Matrix

Act #	Date	Medium	Statute	Evidence
1–3	Apr 22 2022	DocuSign transmission	18 U.S.C. §1343	Certificate metadata
4–6	Apr 23 2022	Wire transfer authorization	§1343, §1344	Bank routing instructions
7–9	Apr–May 2022	Wells Fargo receipt processing	§1344	Bank confirmation
10–12	Jul 2023	Certified mail rejection	§1341	Return envelope & USPS tracking
13–18	Aug 2024	False accounting submission	§1343, Cal. Pen. Code §118	T98 clearance report
19–23	Feb 2025	Email & report to BHHS / HBPD	§1503, §1962(c)	C-series correspondence
24–27	Mar 2025	False testimony in open court	§118, §1962(d)	Court transcript

4. Legal Framework

18 U.S.C. §1341 – Mail Fraud
18 U.S.C. §1343 – Wire Fraud (each digital transmission is a separate count)
18 U.S.C. §1344 – Bank Fraud (false denial of bank-processed funds)
18 U.S.C. §1503 – Obstruction of Justice (misleading the court)
18 U.S.C. §§1621 & 1623 – Perjury under oath
18 U.S.C. §§1961–1964 – RICO predicate framework
Cal. Pen. Code §§118 & 182 – False statements and conspiracy
Cal. Civ. Proc. §1209 – Fraud upon the court as contempt

5. Case Law and Precedents

Hazel-Atlas Glass Co. v. Hartford-Empire Co., 322 U.S. 238 (1944) – Fraud on the court vitiates judgments.
Chambers v. NASCO, Inc., 501 U.S. 32 (1991) – Courts have inherent power to sanction bad faith conduct.
United States v. Cochran, 109 F.3d 660 (10th Cir. 1997) – Each wire transmission is a separate offense.
United States v. Ciccone, 219 F.3d 1078 (9th Cir. 2000) – Bank-related misrepresentations qualify under §1344.
Levander v. Prober (In re Levander), 180 F.3d 1114 (9th Cir. 2001) – Courts may vacate judgments obtained by fraud.
In re Intermagnetics America, Inc., 926 F.2d 912 (9th Cir. 1989) – Fraud on the court undermines judicial integrity.

6. Fraud on the Court Doctrine

Definition: Fraud on the court occurs when a party or counsel intentionally deceives the judiciary, subverting the integrity of the process. It encompasses perjury, fabrication, and concealment of material evidence.
Effect: Such fraud nullifies prior rulings, empowers the court to reopen judgments, and exposes offenders to criminal prosecution and disciplinary referral under 18 U.S.C. §3057.

7. Remedies and Actions

Motion to vacate judgment under the court’s inherent authority (Hazel-Atlas).
Referral to DOJ/FBI for bank and wire fraud investigation under §3057.
Sanctions under Chambers v. NASCO for bad faith litigation conduct.
Restitution and damages under RICO §1964(c).

Summary: The executed contract, banking trail, and sworn falsehoods form a closed circuit of fraud: execution → transfer → denial → concealment. Each act constitutes a discrete chargeable offense, collectively satisfying RICO’s continuity and enterprise requirements.