Deposition Questions – Anna Ly (Realtor)

Why did you claim tenants caused carpet damage when unit had no carpet?

Statutes: PC §487 (Grand Theft), PC §118 (Perjury)

Penalty: Felony theft; 3–4 years prison

Evidence: Clearance invoice vs. photo evidence of vinyl flooring.

Why did you conceal your relationship to Ly Construction while funneling invoices through them?

Statutes: B&P §17200, Fraudulent Self-Dealing

Penalty: Civil disgorgement; treble damages

Evidence: Invoices issued by family business after eviction.

Why did you misrepresent renewal terms, adding an unauthorized 13th month?

Statutes: PC §470 (Forgery), B&P §10176

Penalty: Felony forgery; license discipline

Evidence: Lease copy showing unauthorized extension.

Why did you conceal habitability defects such as mold during contract renewals?

Statutes: Civ. Code §1941.1, Tenant Protection

Penalty: Treble damages

Evidence: Mold inspection report vs. lease renewal email.

Why did you use Berkshire Hathaway branding after disclaiming responsibility?

Statutes: PC §470 (Forgery), RICO 18 U.S.C. §1962

Penalty: 20 years federal

Evidence: Contracts issued under BHHS platform.

Why did you fail to provide complete records to the Department of Real Estate?

Statutes: B&P §10148 (Record Retention)

Penalty: License revocation

Evidence: No DocuSign transmission logs produced.

Why did you claim tenants were “new applicants” despite lease extensions on file?

Statutes: Civ. Code §1945 (Automatic Renewal), Fraudulent Misrepresentation

Penalty: Civil damages; treble penalties

Evidence: Renewal emails showing continuity of tenancy.

Why did you misrepresent security deposit accounting?

Statutes: Civ. Code §1950.5

Penalty: Treble damages

Evidence: No deposit itemization provided after eviction.

Why did you participate in eviction filings that omitted two lawful tenants?

Statutes: CCP §1161, Civil Rights Violations

Penalty: Eviction void; civil penalties

Evidence: UD notice listing one name vs. three signatories.

Why did you ignore tenant’s certified notices about fraud and habitability?

Statutes: 18 U.S.C. §1341 (Mail Fraud)

Penalty: 30 years federal

Evidence: USPS certified mail receipts addressed to you.

Why did you provide misleading disclosures to HOA regarding occupancy?

Statutes: PC §115 (False Documents)

Penalty: Felony; 3 years prison

Evidence: HOA records vs. lease showing multiple occupants.

Why did you fail to disclose rent cap limitations under AB 1482 to tenants?

Statutes: Civ. Code §1947.12

Penalty: Treble damages; civil liability

Evidence: Lease showing increases beyond CPI limits.

Why did you coordinate with Silverstein to inflate damage claims for Airbnb conversion?

Statutes: PC §182 (Conspiracy), RICO §1962

Penalty: 20 years federal

Evidence: Emails linking clearance invoices to Silverstein filings.

Why did you route tenant communications to Phat Tran instead of resolving them as agent?

Statutes: Breach of Fiduciary Duty, B&P §10176

Penalty: License suspension; civil liability

Evidence: Emails redirecting issues back to landlord.

Why did you conceal your beneficial interest in Tran family property transactions?

Statutes: Civ. Code §3439, 26 U.S.C. §7201 (Tax Evasion)

Penalty: Felony; prison + IRS penalties

Evidence: Recorder searches linking Rawhide and Sand Dune Lane.

Why did you produce falsified rent receipts showing non-existent “pet charges”?

Statutes: PC §532 (False Pretenses)

Penalty: Felony; 3 years prison

Evidence: Receipts with fabricated $1,000 “pet fee.”

Why did you instruct tenants to pay into non-BHHS accounts?

Statutes: PC §470 (Forgery), Wire Fraud §1343

Penalty: Felony; 20 years federal

Evidence: Email directing payment to Tran’s personal account.

Why did you provide inconsistent testimony about who managed the property?

Statutes: PC §118 (Perjury)

Penalty: Felony; 4 years state prison

Evidence: Emails vs. court testimony.

Why did you withhold tenant history in an attempt to restart the lease clock?

Statutes: PC §470 (Forgery), Tenant Protection Act

Penalty: Felony forgery; civil treble damages

Evidence: Lease applications that erased tenancy continuity.

Why did you ignore statutory duty to inform tenants of mold remediation?

Statutes: Health & Safety Code §17920.3

Penalty: Civil fines; treble damages

Evidence: Inspector report confirming mold hazard.

Why did you claim “pet urine” damage when independent inspector refuted it?

Statutes: PC §532 (False Pretenses)

Penalty: Felony; 3 years prison

Evidence: Inspection report showing no pet odor or stains.

Why did you fail to document rent increases with lawful CPI calculations?

Statutes: Civ. Code §1947.12

Penalty: Rent rollback; treble damages

Evidence: Renewal demanding >10% increase.

Why did you collude with Tran and Hanson to conceal receipt of cashier’s checks?

Statutes: RICO 18 U.S.C. §1962(c), Conspiracy PC §182

Penalty: 20 years federal

Evidence: Emails tying all three in payment concealment scheme.

Why did you misrepresent your status to tenants, claiming you no longer managed while still acting as agent?

Statutes: PC §470 (Forgery), B&P §10176

Penalty: License revocation; felony

Evidence: Emails disclaiming responsibility while still issuing contracts.