1089 – Carpet Condition and Material Price Comparison (Fraud Multiplier Analysis)

Carpet condition upstairs and stairway prior to move-out

Carpeted area showing clean wear pattern and maintained condition

Home Depot or Lowe’s pricing page showing $0.88 per sq ft Believer Shadow Gray polyester carpet

This exhibit demonstrates that the claimed $7,835 “carpet replacement” billed by Ly Construction (Exhibit 1087) far exceeds the market value for identical carpet materials readily available in Huntington Beach at the time of the eviction. Photographs show the carpet’s maintained condition, proving no legitimate basis for replacement or odor claim.

Condition Evidence

Photos taken prior to vacate inspection (May 2024) show uniform gray polyester carpet with no pet damage or staining.
Carpet professionally vacuumed and cleaned in accordance with lease terms; condition rated “good, minor traffic wear.”
Owner falsely claimed “dog pee smell” (Exhibit 1084) to justify remodel costs and inflate offsets against security deposit.

Price Comparison Table

Material Cost vs. Fraudulent Invoice
Source	Description	Unit Price	Sq. Ft. (approx.)	Extended Cost	Difference from Claimed $7,835
Home Depot / Lowe’s	Believer Shadow Gray 14.6-oz Textured Polyester Carpet	$0.88/sq.ft.	950 sq.ft.	$836.00	$6,999 (Overbilled)
Ly Construction Invoice (Ex. 1087)	“Replace carpet due to dog pee bad smell” + vinyl install	—	—	$7,835.00	—

Fraud Indicators

Markup of over 900% compared to market cost per sq. ft.
Materials shown (vinyl plank, baseboard paint) inconsistent with carpet replacement.
No invoice or receipt from a licensed carpet vendor; all payments routed through Ly Construction (family of realtor Anna Ly).
Photographs taken before vacate show no discoloration, urine staining, or odor-based replacement justification.

Legal Analysis

The excessive billing supports a pattern of fraudulent misrepresentation and unjust enrichment in violation of Cal. Civ. Code §1950.5 and Cal. Bus. & Prof. Code §17200. The evidence further supports predicate acts under 18 U.S.C. §1341 (Mail Fraud) and §1343 (Wire Fraud) for the transmission of false invoices through electronic and postal channels.

Corroborating Exhibits

1084 – Move-Out Clearance Report: Shows same $7,835 figure listed without supporting inspection data.
1087 – Ly Construction Invoice: Confirms remodel billing after eviction, not preexisting damage repair.
1088 – Airbnb Remodel Evidence: Confirms complete vinyl flooring conversion, disproving carpet claim.

Conclusion

The Home Depot and Lowe’s pricing establishes a true market rate of under $1 per sq. ft., while the fraudulent invoice inflated costs by nearly tenfold. This overbilling—combined with photographic evidence of undamaged carpet—proves falsified damage claims and intentional conversion of tenant funds.