Hanson Le – Wire Fraud & Contract Substitution Scheme

DA Submission – Page 1 Berkshire Hathaway

1. Direct Attempt to Divert Rent Into Hanson’s Personal Account

Hanson sends you a text message requesting your bank name so he can provide his personal routing/account number:

“What bank do you use? So I can provide you my bank account number to transfer monthly rent to me instead of the owner.”

This statement proves:

A. Intentional money-redirection scheme
He knowingly instructs the tenant to bypass the legal payee and reroute rent to himself.

B. Unauthorized collection activity
He is not a licensed property manager of record and was not authorized to collect funds.

C. Bank-fraud trigger
He initiates a scheme to obtain funds through an interstate financial system (Wells Fargo), satisfying the elements of:
– 18 U.S.C. §1344 – Bank Fraud
– 18 U.S.C. §1343 – Wire Fraud
– 18 U.S.C. §1028A – Aggravated Identity Theft

2. Owner’s Text Confirms Hanson Received the Payment for a "leese renewal"

Phat Tran directly confirms in writing:

“Sorry I did not know you did pay your rent to the Hanson account. I just texted him to find out - you did not want to sign .”

This accomplishes 3 critical prosecutorial elements:

A. Admission that money was transferred to Hanson — the owner acknowledges the payment was sent to “the Hanson account.”

B. Admission the owner did not authorize Hanson to intercept the money after it arived to office — proving Hanson acted outside any authority.

C. Owner confirms they discussed it privately — “I just texted him…” shows coordination, knowledge, and concealment knowlage.

This is a conspiracy nexus under 18 U.S.C. §371.

3. The Contract Substitution Fraud (The “New Lease” Scam)

Hanson tells you he is preparing a new lease agreement even though you already had an existing signed contract and paid early.

A. Hanson pushes a brand-new lease disguised as a "renewal"
“Our lease agreement will be expired 5/1/24.”
This is false—the prior extension was already signed and he was email this information.

B. He creates a 13-month term disguised as “one year”
Start date 6/1/24 and rent $5,350 reveal a 13-month term. This is fraudulent contract substitution.

C. He excludes deposits and pet fees already paid
Your text correctly states:
“You do not show the $6,000 deposit, the $1,000 for the pet, the $350 for the keys…”
This shows intentional omission to create false dog pee debt.

4. Phat’s Messages Confirm the Fraud and Collusion

Phat contradicts Hanson repeatedly.

A. Phat admits confusion about the “67k contract”
Meaning Hanson represented false figures to him.

B. Phat admits they are “filling out new paperwork”
This confirms a scheme to replace the valid Berkshire lease with a counterfeit document.

5. Evidence of Intent and Timing (Phat & Hanson Coordinated Response)

Hanson claimed he was “traveling in Europe,” but he:

– immediately answered messages
– created contracts
– requested financial info
– processed rental discussions

This establishes:

A. Intent to defraud
B. Consciousness of guilt
C. Multi-party coordination

6. Legal Framework for DA – All Elements Are Met

Wire Fraud – 18 U.S.C. §1343
Messaging + bank account diversion + misrepresentations.

Bank Fraud – 18 U.S.C. §1344
Attempt to obtain funds via Wells Fargo through false pretenses.

Theft by False Pretenses – CA Penal Code §532

Grand Theft – CA Penal Code §487

Real Estate Fraud – CA Penal Code §115 / §487

Unauthorized Real Estate Activity – B&P 10130

Conspiracy – 18 U.S.C. §371 / CA PC §182

Elder Financial Abuse – W&I Code §15610.30