Purpose: This matrix identifies predicate acts establishing a coordinated RICO enterprise involving wire fraud, mail fraud, forgery, and retaliatory eviction.
Each actor’s conduct is categorized by statutory violations and tied directly to evidentiary exhibits.
Phat Tran — Owner
| Predicate Act | Statutes | Exhibits | Count |
| Accepted rent payment, then denied receipt in court. |
18 U.S.C. §1343Wire Fraud — knowingly transmitting false information via interstate wire for financial gain.,
PC §487Grand Theft — unlawful taking exceeding $950.
|
EX-005, EX-006, Bank Records |
3 |
| Directed payments into private accounts; concealed tender. |
18 U.S.C. §1341 Mail Fraud, RICO §1962Establishes enterprise pattern of related criminal acts for economic advantage. |
EX-025, EX-037 |
2 |
| Evicted elder tenant without notice; ignored interpreter requests. |
WIC §15610.07 Elder Abuse, ADA §1232 |
EX-012, EX-019 |
2 |
| Retaliatory eviction after mold complaints. |
Civ. Code §1942.5 Retaliation |
EX-008, EX-081 |
1 |
| Total Predicate Acts: 8+ |
Hanson Le — Agent
| Predicate Act | Statutes | Exhibits | Count |
| Accepted rent after resignation; concealed payment from owner. |
Wire Fraud §1343, PC §470 Forgery |
EX-005, EX-006 |
2 |
| Threatened eviction unless fraudulent contract signed. |
18 U.S.C. §1951 Hobbs Act Extortion |
EX-045 |
1 |
| Filed fraudulent lease as “new applicant.” |
PC §470 Forgery, PC §115 False Filing |
EX-003, EX-036 |
2 |
| Total Predicate Acts: 5+ |
Steven Silverstein — Attorney
| Predicate Act | Statutes | Exhibits | Count |
| Filed unlawful detainer despite proof of rent payment. |
18 U.S.C. §4 Misprision, Fraud on the Court |
EX-015, EX-016 |
2 |
| Concealed USPS evidence in filing and oral argument. |
Mail Fraud §1341, PC §182 Subornation |
EX-011, Court Records |
2 |
| Extorted settlement threat of $20,980 outside courtroom. |
Extortion §1951 |
Notes, Witness Statement |
1 |
| Total Predicate Acts: 5+ |
Richard Rosiak — Attorney
| Predicate Act | Statutes | Exhibits | Count |
| Accepted retainer; abandoned client before court hearing. |
Bus. & Prof. §6103, PC §6128 — Attorney Misconduct |
Retainer Records, Certified Mail |
1 |
| Suppressed critical evidence files previously submitted via email. |
18 U.S.C. §1503 Obstruction of Justice |
Email Trail, Binder Index |
2 |
| Defrauded client of full defense service; breached fiduciary oath. |
Civ. §3294 Malice; Fraudulent Intent |
Fee Agreement, Correspondence |
2 |
| Total Predicate Acts: 5+ |
Anna Ly — Realtor
| Predicate Act | Statutes | Exhibits | Count |
| Issued fraudulent invoice post-tenancy to conceal renovation. |
Wire Fraud §1343, PC §470 Forgery |
EX-054, EX-057 |
2 |
| Falsified advertising (Ocean View, laundry in unit). |
Bus. & Prof. §17500 False Representation |
EX-041, EX-042 |
2 |
| Filed lease extension without property inspection; concealed defects. |
Civ. Code §1710 Deceit |
EX-035, EX-036 |
1 |
| Total Predicate Acts: 5+ |
Collectively, the above actors demonstrate a continuous scheme violating 18 U.S.C. §1961–1968 (Racketeer Influenced and Corrupt Organizations Act).
Predicate offenses align under mail and wire fraud, obstruction, and extortion statutes constituting enterprise coordination for unlawful enrichment.