Ly Construction

Section 01Identity of Record

The contractor of record on Invoice No. 2412 dated August 14, 2024 is identified on the California Contractors State License Board ("CSLB") database as set forth below. All facts in this section are drawn from the CSLB public license record as displayed on the License Detail and License History pages.

The address listed on the CSLB License Detail page is not the address printed on Invoice No. 2412. Both addresses are residential single-family parcels in Garden Grove, California, sharing the same telephone number. The relationship between the licensee and each property is set out in the next section.

Section 02Property Ownership Context

Four parcels are observable in the public record in connection with this licensee's address footprint. Two Garden Grove parcels are referenced as business addresses; two Fountain Valley parcels receive the tax mailings for those Garden Grove parcels. The Orange County Assessor records reflect the assessment status, exemption status, and last-recorded sale information for each parcel below. Owner-of-record identities for all four parcels are publicly available through Orange County Clerk-Recorder records and are not asserted on this page.

Observations

Both Garden Grove parcels are assessed by the OC Assessor as non-owner-occupied — no California homeowner's exemption is filed against either. The two Garden Grove parcels' property-tax mailings are diverted to separate addresses in Fountain Valley, both within ZIP 92708. Both Fountain Valley parcels are assessed as owner-occupied primary residences with homeowner's exemptions on file. Both Fountain Valley residences were constructed in 1969 and held long-term (16–18 years to date). The Hummingbird Ln parcel, which the CSLB lists as the licensee's address of record, was acquired in June 2022 — twenty-two months after the August 2020 license issuance date.

Section 03Workers' Compensation History

The Workers' Compensation History page at CSLB reflects three consecutive exemption certifications covering the full licensure period from July 14, 2020 to the present. Each exemption is filed on CSLB Form 13L-1 under penalty of perjury, certifying that the licensee operates without employees who would require workers' compensation coverage under California Labor Code section 3700.

The licensure period — August 28, 2020 to present — has at no point reflected workers' compensation insurance coverage on file at CSLB. The exemption certification is renewed biennially; each renewal is a discrete sworn statement that the licensee has no employees.

Section 04Contractor's Bond History

The Contractor's Bond History page at CSLB reflects four bond filings under license #1068334 across three surety companies in five years. The continuous-bonding requirement is set out at California Business & Professions Code sections 7071.6 and 7071.11.

Twelve-day interval, August 24 — September 5, 2024

Between the cancellation date of the Old Republic Surety bond (August 24, 2024) and the effective date of the North River Insurance bond (September 5, 2024), the CSLB Bond History page reflects an interval of twelve calendar days during which no contractor's bond is shown on file.

Bond identifier on Invoice No. 2412

Invoice No. 2412 — Ly Construction, dated August 14, 2024 — references "Bond #: GCL5928963." That bond was cancelled by the surety ten days after the invoice was issued. The bond identifier currently in force at the time of this dossier is American Contractors Indemnity Company bond No. 100981238, issued September 5, 2025.

Section 05License Scope Considerations

License #1068334 is classified by CSLB under B — General Building only. The licensee does not hold a C-10 Electrical classification, a C-39 Roofing classification, a C-15 Flooring classification, or any other specialty C-code.

Statutory framework — B&P §7057(b)

A General Building (B) contractor may prime-contract for projects requiring at least two unrelated trades, or projects involving framing or carpentry, or projects for which the contractor either holds the relevant specialty classification or subcontracts the specialty work to an appropriately licensed contractor. A B-only licensee may not prime-contract for single-trade specialty work such as standalone electrical service, standalone roofing repair, or standalone mold-remediation work that involves only one trade.

No Home Improvement Contract on the record

California Business & Professions Code section 7159 requires that any home improvement contract for residential work in excess of $500 be reduced to a written contract containing statutorily prescribed disclosures, including a notice of cancellation, payment-schedule limitations, and contractor identification block. The record in this matter reflects an invoice issued post-vacancy on August 14, 2024 but no Home Improvement Contract executed in advance of the work described therein.

B&P §7031 disgorgement framework

California Business & Professions Code section 7031, as construed by the California Supreme Court in Hydrotech Systems, Ltd. v. Oasis Waterpark (1991) 52 Cal.3d 988, bars an unlicensed contractor — or a contractor acting outside the active scope of his license at any point during a project — from recovering compensation for that work and authorizes the paying party to require disgorgement of any compensation already paid. Section 7031 operates independently of any disciplinary or criminal track and operates by force of statute.

Section 06On-Site Persons Observed

During the tenancy at 19235 Brynn Court, Huntington Beach, three distinct individuals appeared at the property at different times performing work characterized to the tenant as work for the owner. Each individual is described below by observable characteristics and trade performed. The relationship, if any, of these individuals to the licensee of record is not established on this dossier.

Per the tenant's contemporaneous observation, the post-vacancy renovation work at the property involved a whole-house interior spray-paint operation completed in a single coordinated session. Such an operation is not consistent with single-person execution within a one-day window.

Section 07Invoice No. 2412 — Documentary Features

Invoice No. 2412, Ly Construction, dated August 14, 2024, is transmitted within DocuSign Envelope F5D247C2 — the same DocuSign envelope as the Move-Out Clearance Report executed August 5, 2024. The invoice is dated nine days after the move-out clearance was signed and references work allegedly already performed.

Line-item observations

Seven line items aggregate to a whole-dollar subtotal with no cents and no sales tax. The invoice describes carpet removal and disposal, vinyl flooring installation at 950 square feet (material rate of $2.00 per square foot, install at $2,175 labor), stairnose material and installation, and a paint line described as "Paint and install 2nd floor basemoding — Material and Labor — $800." The total corresponds to the residual security deposit balance reflected on the Move-Out Clearance Report after the other deductions documented on that form.

Absence of supporting business records

The documentary record in this matter does not reflect the production of underlying business records that would ordinarily accompany a construction invoice for residential repair work of the scope described in Invoice No. 2412. The categories of supporting record listed below are not present on the record reviewed in this dossier.

The tenant was not personally served with the invoice in physical form, separate from the DocuSign envelope (F5D247C2) used to transmit the Move-Out Clearance package. The version of Invoice No. 2412 entered into the court record is a black photocopy reproduction, not a scanned original or digital business-records output.

Time-and-labor estimate · scope versus window

Visual evidence in Section 08 establishes that the post-vacancy renovation work at the subject premises included a whole-house interior spray-paint operation, refinishing of the handrails from worn natural wood to white, removal of upstairs carpet, installation of luxury vinyl plank flooring throughout approximately 2,000 square feet on both floors, fourteen stair-tread installations with stairnose, and trim and baseboard painting. Industry-standard solo-labor estimates for that scope drawn from National Association of Home Builders construction-time data, National Wood Flooring Association installation guidelines, and Painting and Decorating Contractors of America productivity data are as follows.

At eight hours per day, the aggregate solo labor-hour range corresponds to approximately twenty-four to thirty-four working days for a single person operating alone. The window between the move-out date (August 5, 2024) and the date of Invoice No. 2412 (August 14, 2024) is nine calendar days. Compression of 189 to 275 person-hours into a seven-working-day window requires the equivalent of two to four workers operating in parallel at standard work-day hours, or a smaller number working extended hours over the full nine days. These figures are industry-standard rule-of-thumb estimates; a licensed independent contractor's formal estimate would lock the analysis as expert testimony.

Subcontracted work and the absent underlying bills

California Business & Professions Code section 7057(c) authorizes a B General Building contractor to subcontract specialty trade work to appropriately licensed specialty contractors. Where a B contractor subcontracts, the subcontractor must hold the appropriate specialty classification at the relevant time (for example, C-33 Painting and Decorating, or C-15 Flooring and Floor Covering), must maintain its own workers' compensation coverage or properly filed exemption, must issue invoices to the prime contractor under its own business name and license number, must be paid in a manner reflecting independent-contractor status (1099-NEC at year end where calendar-year payments exceed $600), and must satisfy the California ABC test under Labor Code section 2775.

The documentary record in this matter does not reflect the production of any subcontractor invoice issued to Ly Construction in connection with the work described in Invoice No. 2412. No separately invoiced C-33 Painting subcontractor bill is on the record for the whole-house spray-paint operation. No separately invoiced C-15 Flooring subcontractor bill is on the record for the upstairs-and-downstairs LVP installation. The Ly Construction Invoice No. 2412 was tendered to the deposit accounting and to the court as a single consolidated charge without any underlying subcontractor cost breakdown.

Section 08Visual Evidence

The visual exhibits below depict the subject premises during the tenancy and the subject premises in the post-vacancy listing presentation. The exhibits are presented as observable photographic record. Photo source: post-vacancy exhibits from the Zillow listing presentation at the current asking price of $1,563,300; tenancy-period exhibits from the tenant's contemporaneous photographic record; carpet-product exhibit from the Lowe's retail website for the Huntington Beach location.

Observations on the visual record

The carpet visible in Exhibit V-2 is consistent in pile, color, and texture with the Style Selections Believer Shadow Gray polyester product shown in Exhibit V-6, currently retailing at $0.88 per square foot at the local Lowe's. The material cost of equivalent replacement carpet for 950 square feet at current retail pricing is approximately $836 plus tax, before installation labor. The flooring depicted in the post-vacancy state (Exhibits V-1, V-3) is luxury vinyl plank installed uniformly across upstairs and downstairs, with stairnose at tread edges. The pre- and post-state visual comparison establishes a flooring substitution from worn polyester carpet (upstairs) and dark hardwood (downstairs) to luxury vinyl plank throughout. Painting work documented in the post-state extends to the handrail system, the wall and ceiling surfaces, and trim. The Move-Out Clearance Report deduction for these line items was charged against the tenant's security deposit.

Aggregate deposit on the documentary record

The Move-In Costs schedule of the Authentisign rental envelope for the subject premises (Authentisign Envelope 46CC8725-F703-EF11-96F5-6045BDD68161, dated April 26, 2024, premises 19235 Brynn Ct, Huntington Beach 92648) reflects three deposit categories held by the landlord:

Section 09Statutory Authority & Case Law

The dossier preserves the documentary record. Determinations of liability are reserved to the appropriate adjudicative bodies. The statutory and case-law authorities below are listed for reference only and are not asserted as findings against any named person or entity on this page.

California Business & Professions Code

• § 7028 · Contracting without a license (misdemeanor; aggravated penalties for repeat offense)
• § 7031 · Unlicensed contractor / out-of-scope work: bar to compensation and authorization of disgorgement (Hydrotech Systems v. Oasis Waterpark (1991) 52 Cal.3d 988)
• § 7057(b) · General Building contractor scope: prime contracts limited to multi-trade projects or projects involving framing/carpentry
• § 7068.1 · Allowing license to be used by an unlicensed person
• § 7071.6 & § 7071.11 · Continuous bonding requirement; automatic license suspension for bond cancellation
• § 7083 · Address-of-record notification within 90 days of change
• § 7110 · Unprofessional conduct
• § 7124.6 · Disclosable Actions framework
• § 7159 · Home Improvement Contract statutory requirements

California Labor Code & Insurance Code

• Labor Code § 3700 · Workers' compensation insurance requirement
• Labor Code § 2775 · ABC test for independent-contractor classification, codifying Dynamex Operations West, Inc. v. Superior Court (2018) 4 Cal.5th 903
• Labor Code § 226.8 · Willful misclassification of independent contractors — civil penalties $5,000 to $25,000 per violation
• Insurance Code § 1871.4 · Workers' compensation insurance fraud (felony if intentional)

California Civil Code

• Civ. Code § 1950.5(b), (e), (g), (l) · Security-deposit deduction limits, itemization, bad-faith withholding
• Granberry v. Islay Investments (1995) 9 Cal.4th 738 · Improvements and wear-and-tear not deductible from deposit

California Evidence Code

• Evid. Code § 1271 · Business records exception to the hearsay rule — foundational requirements
• Evid. Code §§ 1400–1402 · Authentication of writings required before admission
• Evid. Code §§ 1500–1521 · Best-evidence and secondary-evidence framework

California Penal Code

• Pen. Code § 115 · Filing false document
• Pen. Code § 118 · Perjury (sworn statements signed under penalty of perjury)
• Pen. Code § 132 · Offering false written evidence at a trial, proceeding, inquiry, or investigation authorized by law
• Pen. Code § 134 · Preparing false or ante-dated documents for use as genuine in a trial, proceeding, or inquiry authorized by law
• People v. Lucero (2019) 41 Cal.App.5th 370 · Section 134 reaches content-based falsity in documents prepared for court proceedings even when documents are not forged or physically altered
• People v. Clark (1977) 72 Cal.App.3d 80 · "Proceeding or inquiry authorized by law" construed broadly to include administrative hearings
• People v. Pereira (1989) 207 Cal.App.3d 1057 · Knowingly submitting fraudulently altered documents in response to subpoenas falls within § 134
• People v. Morrison (2011) 191 Cal.App.4th 1551 · Falsification within court-supervised monitoring violates § 134