Exhibit T12 – Listing Detail – False Representation of Appliances and Square Footage

Listing Date2022 (Original Lease Period)
Property19235 Brynn Ct, Huntington Beach, CA 92648
Advertised AppliancesDryer, Washer – In-Unit
Advertised Area2,000 sq. ft. livable area, 3,049 sq. ft. lot
Parcel Number11115066
AgentAnna Ly – Sun Realty (Landlord’s Daughter)
Source FileT12.jpg

This exhibit displays the original property listing details advertising a home with in-unit washer and dryer and a total livable space of 2,000 sq. ft. Upon move-in, tenants discovered that no washer or dryer was provided and that the actual usable area was smaller than represented. When Michael’s mother-in-law asked about the missing washer, Anna Ly reportedly responded:

“The owner just bought you a house and does not want to buy you a washer. Move out by noon.”

This conduct demonstrates material misrepresentation under California Civil Code §§1709–1710, where false statements or omissions were made to induce tenancy. The false advertising of in-unit appliances and the hostile response when tenants raised concerns also support claims of retaliatory behavior and breach of the implied warranty of habitability. The listing served as a key inducement in the decision to lease the property.

Exhibit T12 – Listing Detail – False Representation of Appliances and Square Footage