LY Construction

Construction Contractor — Mold & Habitability Concealment — False Invoicing — Coordination with Owner & Agents — Evidence Pattern Supporting RICO Enterprise Theory.

I. Summary of Role

LY Construction functioned as the maintenance and “repair” contractor for Phat Tran’s rental property. Evidence shows the company performed superficial and cosmetic work that concealed water intrusion, mold, rotted subflooring, and structural hazards — rather than performing lawful remediation.

LY Construction’s activity forms one part of the multi-actor enterprise: conceal defects → raise rent → evict → remodel for profit. Their presence is consistent with collusion between owner, agents, and attorney to create false conditions supporting eviction and subsequent rent inflation.

II. Identity & Operations

Name: LY Construction (unverified licensing)
Function: Contractor used by landlord to conduct repair & patchwork operations
Affiliation: Tied to Anna Ly and the broader Tran family cluster
Business Practices: Conducted repairs without proper disclosures or permits

The evidence strongly suggests LY Construction was not merely a contractor, but part of a coordinated concealment effort spanning 2022–2024.

III. Timeline of Conduct

2022 Move-In: Prior work by LY Construction concealed mold and water-damage under laminate.
2023 Repairs: 5–6 days of wall and cabinet “repairs” performed after tenant complaints — work was cosmetic only, not compliant with safety or abatement standards.
Early 2024: Further patching done without addressing structural issues.
July 2024: After tenant reports mold to city, LY Construction re-enters property during landlord conflict; alleged “carpet repairs” priced at $7,837 appear falsified.
Post-Eviction: Contractor activity aligns with preparing property for inflated listing.

IV. Evidence Relevant to This Actor

Mold Photos: Pre-existing mold visible under laminate and cabinets.
Wall Damage: Repairs done without addressing water source.
Electrical Hazards: Rusted AC receptacle in wall left unrepaired.
Garage & Cabinet Rot: Covered with paint rather than replaced.
False Invoice: Post-move-out invoice for “carpet repairs” totaling $7,837 inconsistent with city inspection showing no pet-damage.
Timing: Repairs always occurred only after tenant complaints or legal risk.

All evidence supports conclusion that LY Construction’s work was used to hide defects, not fix them.

V. Statutory Exposure

A. California Penal Code

PC § 470 — Forgery (Accessory): Falsified invoice, used as basis for damage claims.
PC § 487 — Grand Theft: False billing exceeding $950.
PC § 532 — False Pretenses: Misrepresentation of repairs for financial gain.
PC § 135 — Evidence Destruction: Supporting owner in covering habitability defects.
PC § 182 — Criminal Conspiracy: Joint actions with owner and agents.

B. Health & Safety

H&S § 17920.3: Substandard housing conditions created or concealed.
H&S § 17920.10: Mold hazard concealment.

C. Federal

18 U.S.C. § 1962 — RICO: Conduct contributes to enterprise continuity (conceal defects → justify eviction → raise rent).

VI. Misconduct Pattern

Performed superficial work to hide structural hazards.
Issued false invoices inconsistent with inspector findings.
Work timeline correlates to retaliation cycle.
Assisted landlord in concealing evidence of uninhabitable conditions.
Enabled forged narrative of “tenant damage” contradicted by city inspector.

VII. Enterprise Connections

To Phat Tran: Directly hired by owner to conceal habitability issues.
To Anna Ly: Shared identity / business linkage indicators.
To Silverstein: False invoices used in litigation narrative.
To BHHS: Work supported fraudulent rent increases and marketing photos.

VIII. Notes for Investigators

Obtain invoice and licensing records for authenticity.
Review building permits — likely none were issued.
Cross-check LY Construction with Tran family ties.
Inspect repair quality to confirm concealment rather than remediation.
Assess coordination between LY Construction timelines and legal filings.

LY Construction is not an incidental contractor — it is part of the operational mechanism that enabled the fraudulent eviction and subsequent profit scheme.