Court
OC Superior Court · Dept. C61
Criminal Counts · California Penal Code & Federal Criminal Code
Criminal Counts
Catalogued for evidentiary preservation. Each count anchored to the controlling statute, the elements as articulated by the legislature, the documentary record on which the question presents, the controlling case authority where one has been identified, and the maximum statutory exposure. Criminal liability is determined by qualified prosecutors and by courts — not by narrators of documentary records. No finding has been made.
California Penal Code · 13 Counts
Title 18 Federal · 8 Counts
Title 42 Federal · 1 Count
Method · how to read this page
- Statute. Each count opens with the operative statute citation and a direct link to the public statutory text at Cornell Legal Information Institute or leginfo.ca.gov.
- Elements. The element list reproduces the statutory elements as enacted. Where a controlling judicial construction narrows an element, the construction is identified with its citation.
- Documentary mapping. The mapping field identifies, by date and by primary-document reference, where the documentary record presents the element question. The mapping is a question presented for review — not a finding.
- Controlling authority. Where a published California or federal decision addresses the application of the statute to a closely-analogous fact pattern, the citation is provided. Verifiable at Justia or the official reporter.
- Maximum exposure. Stated in the statutory terms. Aggregation across counts and across defendants is reserved to charging discretion.
I
California Penal Code · Document-Preparation and Filing Cluster
PC §§115 · 118 · 132 · 134 · 182 · 470The six-statute cluster reaches the conduct architecture of a false written instrument intended for use in a proceeding. Each statute addresses a distinct stage in the instrument’s life cycle. The cluster operates independently — a single instrument may present elements of multiple statutes depending on its preparation, attestation, offering, and filing.
Count 01 · California
Cal. Pen. Code § 134
Preparation of False Documentary Evidence for Use in Proceeding
Statute
Elements
(1) Preparation of any false or ante-dated book, paper, record, instrument in writing, or other matter or thing; (2) with intent to produce it, or allow it to be produced, in a trial, proceeding, or inquiry authorized by law; (3) for a fraudulent or deceitful purpose; (4) as genuine or true.
Documentary mapping
Move-Out Clearance Report, DocuSign Envelope
F5D247C2-A1A9-4991-B91F-6A333347A87D, executed August 5, 2024, attached to plaintiff’s opening trial preparation in Department C61, contains on its face a date column reciting “Rent Paid Through: 5/1/2024” and a dollar column demanding $10,833 — an amount that mathematically represents two months and five days at the contractual rate. The five-thousand-dollar gap between the two columns corresponds, to the cent, to the May 2024 wire transfer that cleared on April 19, 2024 (Wells Fargo confirmation OW00004382456864, $5,000.00) and was acknowledged by the property owner by text message the same day at 11:53 AM Pacific time. Three-Day Notice to Pay Rent or Quit, served June 21, 2024, identifies the originator and sender on the DocuSign envelope as Anna Tran Ly (DRE Broker License #01894348), who is not an attorney and was not the broker of record for the subject property at the time of transmission. Source: missing-month.html · notice.html · instrument-authorship.htmlControlling authority
In re Horowitz, 33 Cal.2d 534 (1949) — preparation with the requisite intent completes the offense; subsequent use not required. Williams v. Superior Court, 46 Cal.App.4th 320 (1996) — misleading a tribunal is sanctionable regardless of motives. justia.com/in-re-horowitz · justia.com/williams-v-superior-court
Referral status
California Penal Code §134 Referral Package transmitted to the Office of the Honorable Todd Spitzer, Orange County District Attorney, on May 11, 2026 by United States Postal Service Certified Mail Return Receipt Requested (Tracking
9589 0710 5270 3530 1127 14; delivery confirmed approximately May 13, 2026). Supplemental PC §134 Resubmission Package mailed May 18, 2026. Resubmission pending · neutral tone · no finding has been made.Maximum exposure
Felony. Punishable by imprisonment in the state prison for up to three (3) years.
Count 02 · California
Cal. Pen. Code § 115
Procuring or Offering False or Forged Instrument for Filing
Statute
Elements
(1) Knowing procurement or offering of any false or forged instrument; (2) to be filed, registered, or recorded in any public office in California; (3) which instrument, if genuine, might be filed, registered, or recorded under any California law or under any law of the United States.
Documentary mapping
Three-Day Notice to Pay Rent or Quit attached as exhibit to the Complaint for Unlawful Detainer filed in OCSC on July 3, 2024, under Case No. 30-2024-01410991-CL-UD-CJC. The Notice on its face directs payment to a Wells Fargo bank branch, identifies a payee account in the personal name of the property owner not named on either executed lease, omits the service-and-expiration paragraph, drops the statutory “OR QUIT” disposition alternative, and bears no attorney signature line. Move-Out Clearance Report attached as basis for the rent-owed calculation in the March 27, 2025 Under Submission Ruling (Court Document ID
74522578), Department C61. Source: instrument-authorship.html · court-record.htmlControlling authority
In re Horowitz, 33 Cal.2d 534 (1949) — section 115 occupies a distinct doctrinal space from section 134, addressing the filing stage of the same conduct architecture.
Maximum exposure
Felony. Punishable by imprisonment in the state prison.
Count 03 · California
Cal. Pen. Code § 132
Offering False Documentary Evidence in a Trial or Proceeding
Statute
Elements
(1) Knowing offer in evidence; (2) of any book, paper, document, record, or other instrument in writing; (3) which the offeror knows has been forged or fraudulently altered or antedated; (4) in any trial, proceeding, inquiry, or investigation whatever.
Documentary mapping
The Move-Out Clearance Report referenced at the January 27, 2025 trial and recited in the March 27, 2025 Under Submission Ruling (Court Document ID
74522578) as the basis for the $6,375 security-deposit-credit calculation. The form contains, on its face, a pre-formatted Attorney Fees deduction line with the entry $2,005 — a deduction California Civil Code §1950.5(b) does not authorize against a residential security deposit (closed list of four enumerated purposes). The form bears the same DocuSign Envelope ID as the blank template publicly distributed by Silverstein Eviction Law at stevendsilverstein.com. Source: notice.htmlMaximum exposure
Felony. Punishable by imprisonment in the state prison.
Count 04 · California
Cal. Pen. Code § 118
Perjury
Statute
Elements
(1) A statement made willfully and contrary to an oath; (2) by a person taking an oath that he or she will testify, declare, depose, or certify truly; (3) before any competent tribunal, officer, or person, in any of the cases in which the oath may by law of the State of California be administered; or (4) in any declaration, deposition, affidavit, verification, certificate, or statement signed under penalty of perjury.
Documentary mapping
Verifications attached to filings in OCSC Case 30-2024-01410991-CL-UD-CJC by the named plaintiff Phat L.K. Tran, D.M.D., asserting facts as to non-receipt of rent during the period in which the bank record reflects receipt at the owner-designated account ending in …9166 (Wells Fargo account number
1005959166) on April 19, 2024 (Confirmation OW00004382456864, $5,000.00) and on June 28, 2024 (Confirmation OW00004652829145, $5,350.00). Substitution of Attorney form filed January 21, 2025 by process server Jeremy Ryan Carpenter under penalty of perjury, certifying service of substitution on opposing counsel Steven D. Silverstein (USPS Certified Mail Tracking 9589 0710 5270 0842 6487 26). Source: lease-and-accounts.html · chronology.htmlMaximum exposure
Felony. Punishable by imprisonment in the state prison for two, three, or four years.
Count 05 · California
Cal. Pen. Code § 470
Forgery
Statute
Elements
(1) With intent to defraud; (2) signs the name of another person, or of a fictitious person, knowing that he or she has no authority to do so; or (3) counterfeits or forges the seal or handwriting of another; or (4) alters, corrupts, or falsifies any document or instrument with respect to title, payment, or other operative term.
Documentary mapping
Preservation count. Reaches the alteration of any instrument where the alteration is supported by a documentary handwriting comparison. The cashier’s check of May 30, 2024 in the amount of $4,338.48, payable to Berkshire Hathaway HomeServices, sealed on receipt by an individual whose initials were recorded by USPS as “H H” (USPS Certified Mail Tracking
9534914882764149935944, delivered Huntington Beach 92649 at 3:43 PM on May 30, 2024), sits sealed today, available for forensic latent-fingerprint and ink-and-paper examination by qualified investigators. Source: cure-tender.htmlMaximum exposure
Felony or misdemeanor (wobbler). Felony exposure: imprisonment in the state prison.
Count 06 · California
Cal. Pen. Code § 182
Conspiracy
Statute
Elements
(1) Two or more persons; (2) conspire together to commit any crime; (3) accompanied by an overt act in furtherance of the conspiracy by one or more of the parties.
Documentary mapping
Preservation count. The documentary record indexes interactions among named persons across the April 2024 lease-substitution period, the May 2024 cure-tender window, the June 2024 Three-Day Notice sequence, the August 2024 Move-Out Clearance Report execution, and the January 2025 trial preparation, in each of which two or more named persons of record acted in coordination on operative documents (the April 26, 2024 lease bearing the broker’s personal account; the Three-Day Notice routing rent to the owner’s personal account; the Move-Out Clearance Report on the firm-distributed template). Whether the documentary record presents the conspiracy elements is a question for the prosecutorial authority. Source: charging-summary.html · lease-and-accounts.html
Maximum exposure
Variable. Conspiracy to commit a felony is punishable in the same manner and to the same extent as the felony itself.
II
California Penal Code · Property and Trust-Fund Cluster
PC §§484 · 487 · 503 · 504 · 530.5 · 532The property-and-trust-fund cluster reaches the wrongful taking, retention, or misapplication of money or property entrusted to a person in a position of agency or fiduciary responsibility. The cluster is the criminal counterpart to the California Business & Professions Code §10145 broker trust-funds regime addressed at the state-civil-counts page.
Count 07 · California
Cal. Pen. Code §§ 484 · 487
Theft / Grand Theft
Elements
(1) Wrongful taking, stealing, or fraudulent appropriation; (2) of the personal property of another; (3) with intent to permanently deprive the owner; (4) where the value of the property exceeds $950 (felony grand theft).
Documentary mapping
The June 28, 2024 wire transfer of $5,350.00 (Wells Fargo Confirmation
OW00004652829145) from plaintiffs’ Wells Fargo Premier Checking ending …0732 to Wells Fargo account 1005959166 in the personal name of the property owner, was made under written protest in the wire memo: “Unknown Contract for July payment 27 of 37 on contracts.” The transmission occurred seven days after service of the Three-Day Notice. The funds settled at the personal account. Representations were thereafter made on the trial record that a refund had been mailed to the plaintiffs; no documentary evidence of any such refund appears on the plaintiffs’ receiving-account bank record at any point. Source: missing-month.htmlMaximum exposure
Grand theft is a wobbler. Felony exposure: imprisonment in the state prison for sixteen months, two years, or three years.
Count 08 · California
Cal. Pen. Code §§ 503 · 504
Embezzlement · Fraudulent Appropriation by a Person Entrusted
Statute
Elements
(1) Fraudulent appropriation of property; (2) by a person to whom it has been entrusted; (3) with intent to deprive the owner.
Documentary mapping
The pre-execution renewal-proposal sequence transmitted on or before April 26, 2024 from the contact line subsequently identified as Hanson Le (DRE Broker License #01358448) included, in writing, the question and proposal: “Also what bank do you use? So I can provide you my bank account number to transfer monthly rent to me instead of to the owner.” The same solicitation was repeated by SMS on April 26, 2024, the day the new lease was executed. The 2024 executed lease then identified Wells Fargo account ending …
3297 in the personal name of Hanson Le as the rent-receiving account. California Business & Professions Code §10145 requires that funds received by a real-estate licensee on behalf of another, in connection with a transaction, be placed into a broker trust account established for that purpose, and not into a personal account. The licensee was the designated rent-receiver. The account designated was personal. Source: lease-and-accounts.htmlMaximum exposure
Punished as theft. Wobbler exposure scales with value of the property appropriated.
Count 09 · California
Cal. Pen. Code § 532
False Pretenses · Obtaining Money or Property by Trick or Device
Statute
Elements
(1) Knowingly and designedly; (2) by any false or fraudulent representation or pretense; (3) defrauds any other person of money, labor, or property; (4) or so obtains the money or property.
Documentary mapping
The Three-Day Notice of June 21, 2024 directed the plaintiffs to deliver rent in person to a specific Wells Fargo bank branch during banking hours, naming an account in the personal name of the property owner not named in the executed 2024 lease as the rent-receiving payee. The same Wells Fargo account number
1005959166 had received the recurring monthly wire payments throughout 2022, 2023, and the first quarter of 2024 — sixteen wires in total, all designated to PHAT L TRAN. The owner’s June 22, 2024 written admission read: “Sorry I did nt know you did pay your rent to the Hanson account.” The owner’s representation, on the face of the Notice, was that rent was due. The contemporaneous documentary record reflects that rent had been wired to the owner’s designated account on the customary schedule. Source: lease-and-accounts.htmlMaximum exposure
Punished in the manner provided for theft.
Count 10 · California
Cal. Pen. Code §§ 518–520
Extortion · Obtaining Property by Threat · Preservation
Statute
Elements
(1) Obtaining property of another, or the official act of any public officer; (2) with the other’s consent; (3) induced by a wrongful use of force, fear, or threat. Section 519 enumerates the qualifying threats.
Documentary mapping
Preservation count. Documentary record reflects pre-execution telephone communications during the April 25–26, 2024 window in which the listing-licensee communicated, in substance and as memorialized in plaintiff’s contemporaneous written communications, that the owner would commence eviction proceedings on the following Monday if the new lease was not signed. The new lease was executed by all parties on April 26, 2024 under those telephone-communicated conditions. Civ. Code §1567 makes apparent consent not real or free where obtained through duress, menace, fraud, undue influence, or mistake. Whether the documentary record presents the section 518 elements is a question for the prosecutorial authority. Source: lease-and-accounts.html
Maximum exposure
Felony. Punishable by imprisonment in the state prison for two, three, or four years.
III
Federal Criminal Code · Title 18 Cluster
18 U.S.C. §§ 1341 · 1343 · 1344 · 1708 · 1951 · 1957 · 1961–1962Federal counts catalogued for evidentiary preservation. Each count is referenced in submissions to the United States Postal Inspection Service, the Federal Bureau of Investigation Los Angeles Field Office, the Internet Crime Complaint Center, and the United States Department of Housing and Urban Development Office of Inspector General. Each is reachable by primary-document anchor.
Count 11 · Federal
18 U.S.C. § 1341
Mail Fraud
Statute
Elements
(1) A scheme to defraud; (2) intent to defraud; (3) use of the United States mail or any private or commercial interstate carrier in furtherance of the scheme.
Documentary mapping
The cashier’s check tender of May 30, 2024 in the amount of $4,338.48, payable to Berkshire Hathaway HomeServices, transmitted by USPS Certified Mail (Tracking
9534914882764149935944), delivered Huntington Beach 92649 at 3:43 PM, signed for as “H H” — sealed by the recipient and never credited. The Three-Day Notice subsequently served on June 21, 2024 represented that rent was due and unpaid. Representations were thereafter made on the trial record that a refund had been mailed to plaintiffs; no documentary evidence of any such refund appears on plaintiffs’ receiving-account bank record. The (PROPOSED) AMENDED JUDGMENT transmitted to plaintiffs by Silverstein Eviction Law via United States Certified Mail on the firm’s letterhead, with a blank judge’s signature line and the case caption pre-filled. Source: cure-tender.htmlReferral status
Submitted to USPIS in the eleven-agency packet mailed April 25, 2026. Pending · no finding has been made.
Maximum exposure
Imprisonment up to 20 years; fine up to $1,000,000 if the violation affects a financial institution.
Count 12 · Federal
18 U.S.C. § 1343
Wire Fraud
Statute
Elements
(1) A scheme to defraud; (2) intent to defraud; (3) use of interstate wire, radio, or television communication in furtherance of the scheme.
Documentary mapping
The June 28, 2024 wire transfer of $5,350.00 (Wells Fargo Confirmation
OW00004652829145) transmitted to Wells Fargo account 1005959166 in the personal name of the property owner, on telephone demand during the cure window seven days after Three-Day Notice service. The wire memo records the plaintiff’s contemporaneous protest at being directed off-contract: “Unknown Contract for July payment 27 of 37 on contracts.” The interstate wire-transmission infrastructure of a federally regulated depository institution was the instrument of the transmission. The sixteen-wire ledger preserved on the lease-and-accounts page, totaling $80,350.00 in tenant payments through the same designated account ending …9166 between January 23, 2023 and June 28, 2024, provides the broader continuity record. Source: lease-and-accounts.htmlReferral status
Submitted to FBI Los Angeles Field Office and to the Internet Crime Complaint Center (IC3) in December 2025. Pending · no finding has been made.
Maximum exposure
Imprisonment up to 20 years; fine up to $1,000,000 if the violation affects a financial institution.
Count 13 · Federal
18 U.S.C. § 1344
Bank Fraud
Statute
Elements
(1) Knowingly executing or attempting to execute a scheme or artifice; (2) to defraud a financial institution; or (3) to obtain money, funds, credits, assets, securities, or other property owned by or under the custody or control of a financial institution; (4) by means of false or fraudulent pretenses, representations, or promises.
Documentary mapping
The financial institution executing both the receipt of the April 19, 2024 contractual-modification wire ($5,000.00, Confirmation
OW00004382456864, memo “New lease 24 one payment at 5000”) and the June 28, 2024 off-contract wire ($5,350.00, Confirmation OW00004652829145) is Wells Fargo Bank, N.A., a federally insured depository institution. The wire memo on the second transmission reflects plaintiff’s contemporaneous protest at being directed off-contract by an instrument (the Three-Day Notice) directing payment to a payee not named in the executed lease. Source: lease-and-accounts.htmlMaximum exposure
Imprisonment up to 30 years; fine up to $1,000,000.
Count 14 · Federal
18 U.S.C. § 1708
Theft or Receipt of Stolen Mail Matter
Statute
Elements
(1) Theft, taking, embezzlement, abstraction, or destruction of mail; (2) from a Post Office, letter box, mail receptacle, authorized depository, or carrier; (3) or unlawful possession thereof with knowledge of unlawful taking.
Documentary mapping
Preservation count. The May 30, 2024 cashier’s check tendered by USPS Certified Mail (Tracking
9534914882764149935944) was signed for at the addressee’s receiving location by an individual whose initials were recorded as “H H”. The check was thereafter sealed and never credited, never deposited, and never returned to plaintiffs by mail. Whether the chain of custody after receipt presents the section 1708 elements is a question for USPIS investigative authority. Source: cure-tender.htmlMaximum exposure
Imprisonment up to 5 years; fine.
Count 15 · Federal
18 U.S.C. § 1951
Hobbs Act · Interference with Commerce by Extortion · Preservation
Statute
Elements
(1) Obstruction, delay, or affecting commerce or the movement of any article or commodity in commerce; (2) by robbery or extortion; (3) where extortion is the obtaining of property from another, with consent, induced by wrongful use of actual or threatened force, violence, or fear, or under color of official right.
Documentary mapping
Catalogued for evidentiary preservation only. The interstate wire infrastructure used in the wire-fraud and bank-fraud counts is an instrument of interstate commerce. No assertion of element satisfaction is made on the present record.
Maximum exposure
Imprisonment up to 20 years; fine.
Count 16 · Federal
18 U.S.C. § 1957
Engaging in Monetary Transactions in Property Derived from Specified Unlawful Activity · Preservation
Statute
Elements
(1) Knowingly engaging or attempting to engage; (2) in a monetary transaction of greater than $10,000; (3) in criminally derived property; (4) by, through, or to a financial institution; (5) where the property is derived from specified unlawful activity.
Documentary mapping
Catalogued for evidentiary preservation in connection with the sixteen-wire ledger preserved on the lease-and-accounts page. No assertion of element satisfaction is made on the present record.
Maximum exposure
Imprisonment up to 10 years; fine up to twice the value of the property.
Count 17 · Federal
18 U.S.C. §§ 1961–1962
RICO · Racketeer Influenced and Corrupt Organizations · Preservation
Statute
law.cornell.edu/uscode/18/1961 (definitions) · §1962 (prohibited activities)
Elements
(1) Conduct; (2) of an enterprise; (3) through a pattern; (4) of racketeering activity. Predicate acts under §1961(1) include the mail-fraud, wire-fraud, bank-fraud, and extortion offenses preserved above.
Documentary mapping
Preservation count. The documentary record reflects a continuing course of related conduct across the 2018, 2021, and 2024 unlawful-detainer dockets on the publicly indexed Orange County Superior Court online index (Tran v. Bach 30-2018-00982394, Harman v. Tran, Gasio v. Tran et al. 30-2024-01410991) with overlap in plaintiff’s counsel of record and overlap in named plaintiff family network. The H.J. Inc. continuity-plus-relationship standard is the controlling authority on pattern. See related-cases.html
Controlling authority
H.J. Inc. v. Northwestern Bell Telephone Co., 492 U.S. 229 (1989) — continuity-plus-relationship pattern standard. Global-Tech Appliances, Inc. v. SEB S.A., 563 U.S. 754 (2011) — willful blindness as actual knowledge for scienter on RICO predicates. justia/hj-inc · justia/global-tech
Maximum exposure
Imprisonment up to 20 years per count; fines; forfeiture of interest in the enterprise. Civil treble damages under §1964(c).
Count 18 · Federal
42 U.S.C. § 3631
Criminal Interference with Fair Housing Rights
Statute
Elements
(1) By force or threat of force; (2) willfully injuring, intimidating, or interfering with, or attempting to injure, intimidate, or interfere with; (3) any person; (4) because of his race, color, religion, sex, handicap, familial status, or national origin; (5) and because of his lawful occupation of any dwelling.
Documentary mapping
The named occupants of the residential premises at 19235 Brynn Court included a senior limited-English-proficient woman of Ukrainian national origin (Tetyana Zvyagintseva, age 65+, named at ¶1.B of both the 2022 and 2024 executed leases). The listing licensee received written notice prior to the April 26, 2024 lease execution that this resident did not speak English; no translated lease review was arranged. The Three-Day Notice subsequently served on June 21, 2024 was served in English only and was not served on this resident at all (service was on only one of three named tenants). Post-eviction the property was converted to short-term rental at a per-month base rate 122 percent above the contractual rent at which the senior LEP resident had occupied. Source: lease-and-accounts.html
Referral status
Submitted to DOJ Civil Rights Division Housing Section and HUD OIG in the eleven-agency packet mailed April 25, 2026. Pending · no finding has been made.
Maximum exposure
Imprisonment up to 1 year for cases without bodily injury; up to 10 years where bodily injury results; up to life imprisonment where death results.
IV
Charging Coordination · Where the Counts Sit
Cross-referenceThe eighteen counts catalogued above are presented in the format a reviewing prosecutorial agency would expect on a prosecutorial intake submission. Aggregation across counts and across defendants is reserved to charging discretion. The named persons of record — eight individuals plus one entity, indexed at the Jeopardy Matrix — are each entitled to respond to the documentary record on the merits, or to remain silent on the merits and accept the documentary inference that follows from silence.
| Forum | Authority | Status |
|---|---|---|
| Orange County District Attorney | Office of the Hon. Todd Spitzer · Real Estate Fraud Unit | California Penal Code §134 Referral Package mailed May 11, 2026 (USPS Cert 9589 0710 5270 3530 1127 14); supplemental package mailed May 18, 2026. Resubmission pending · neutral tone · no finding has been made. |
| FBI Los Angeles | Los Angeles Field Office · SA H. Nguyen | December 2025 submission perfected. Pending. |
| Internet Crime Complaint Center | IC3 · Federal Bureau of Investigation | December 2025 submission perfected. Pending. |
| USPS Inspection Service | USPIS | April 25, 2026 eleven-agency packet mailing. Pending. |
| DOJ Civil Rights Division | Housing Section · 950 Pennsylvania Ave NW, Washington DC 20530 | April 25, 2026 eleven-agency packet mailing. Pending. |
| HUD OIG | U.S. Department of Housing and Urban Development · Office of Inspector General | April 25, 2026 eleven-agency packet mailing. Pending. |
| Huntington Beach PD | HBPD Internal Affairs · AI 26-0003 · Sgt. Trent Tunstall #1178 · Chief Eric Parra | Concluded “Unfounded” February 18, 2026 supplemental April 2, 2026. California Penal Code §134 referral mailed May 18, 2026. Pending resubmission · no finding has been made. |
Cross-reference to other sections of this portal
The criminal counts catalogued on this page connect to the civil counts at state-civil-counts.html and federal-civil-counts.html through the same documentary record. The damages scaffolding at damages.html indexes the statutory multipliers applicable to the two-senior framework (Michael 72 + Tetyana 65+ with co-plaintiff Yulia 42). The primary-document index at evidence-index.html catalogues the sixteen-wire ledger, the four payment channels, the WF account #1005959166 four-document continuity anchor, the USPS Certified Mail tracking records, the cashier’s checks, and the DocuSign envelope evidence on which each count is anchored.