1) Martha Mosier — Berkshire Hathaway Executive

Focus: corporate notice, investigation duty, apparent agency, RICO knowledge chain.

1. Did you personally receive certified mail from the Plaintiff outlining lease fraud and wire fraud?

2. When did you first become aware Berkshire agents were accused of forgery?

3. Did you instruct anyone at Berkshire to investigate those claims?

4. If no investigation was conducted, why not?

5. Do you acknowledge that Berkshire’s name was on the lease agreements in question?

6. Did you forward any of the Plaintiff’s letters to legal counsel?

7. Did you ever speak with Hanson Le or Anna Ly regarding these complaints?

8. Did you instruct David Beard to ignore the Plaintiff’s communications?

9. Do you deny that Berkshire’s brand was used to execute a fraudulent eviction?

10. Isn’t it true that ignoring repeated fraud reports can constitute corporate complicity?

11. Did Berkshire benefit financially from the franchise involved?

12. Were you warned that RICO exposure applied to Berkshire’s franchisor level?

13. Do you deny receipt of the USPS delivery tracking showing your office signed for notice?

14. Did you advise your risk or compliance team?

15. Why did you not notify regulators of suspected agent misconduct?

16. Do you accept responsibility for protecting the public under the Berkshire brand?

17. Did you approve or endorse the letter sent to the Plaintiff telling him to stop contacting Berkshire?

18. Were you aware that Hanson Le had resigned but his lease was still used in court?

19. Did you notify law enforcement once you became aware of forged documents?

20. Can you explain why Berkshire responded to the Plaintiff only after the eviction was completed?

21. Isn’t silence in the face of fraud a form of concealment?

22. Did Berkshire track franchise compliance at the Huntington Beach office?

23. Were you told that Plaintiff’s mother-in-law, a senior, was listed as a tenant?

24. Did you ignore the Plaintiff’s ADA accommodation request?

25. Do you accept that under apparent agency law, Berkshire bears liability for its franchisees?

26. Did you seek to avoid involvement because Berkshire considered itself “independent”?

27. Did you ever deny the authenticity of the Plaintiff’s lease agreements?

28. Did you destroy or withhold any communications from Berkshire’s records?

29. Do you deny knowledge that the Plaintiff warned Berkshire of RICO liability?

30. Isn’t it true that Berkshire’s inaction directly enabled a fraudulent eviction?

2) Richard Rosiak — Plaintiff’s Former Attorney

Focus: malpractice, abandonment, failure to file, prejudice to client.

1. Did you accept $8,000 in fees from the Plaintiff?

2. Did you ever file a substantive motion on his behalf?

3. Why did you fail to upload critical evidence into the court record?

4. Did you knowingly withdraw days before trial?

5. Did you ever advise your client that Hanson Le had resigned?

6. Did you review the signed lease extension before withdrawing?

7. Did you speak with Silverstein about settlement without informing your client?

8. Do you admit you failed to meet filing deadlines?

9. Did you ignore emails from your client regarding evidence?

10. Did you ever submit the cashier’s check as evidence?

11. Did you notify the judge that your client was disabled and under cardiac monitoring?

12. Why did you abandon the case at its most critical stage?

13. Do you agree that legal malpractice occurs when an attorney fails to protect a client’s rights?

14. Did you ever object to the use of a forged lease?

15. Did you warn your client you would withdraw?

16. Did you communicate with opposing counsel about your withdrawal?

17. Did you ever review the timeline provided to you?

18. Did you file a substitution of attorney form properly?

19. Isn’t it true your withdrawal prejudiced the Plaintiff irreparably?

20. Do you deny liability for malpractice damages?

21. Did you ever explain why you ignored the damages table provided to you?

22. Do you admit to abandoning discovery obligations?

23. Were you aware your client was pro se after your withdrawal?

24. Did you ever deliver the Plaintiff’s binder of exhibits to the court?

25. Did you fail to advise your client of court deadlines?

26. Did you benefit financially by taking fees and performing little to no work?

27. Do you agree attorneys have a duty of loyalty and diligence?

28. Isn’t it true you knowingly left your client to lose by default?

29. Did you ever explain your actions to the State Bar?

30. Do you accept that your conduct constitutes malpractice and potential fraud?

3) Hanson Le — Realtor / Agent (BHHS)

Focus: resignation, payment diversion, coercion, wire fraud.

1. Did you sign a lease renewal in April 2024?

2. Did you later resign on May 13, 2024?

3. Did you still accept rent after your resignation?

4. Did you instruct the tenants to pay into your private bank account?

5. Did you ever forward those funds to Berkshire Hathaway?

6. Did you tell the tenants, “Sign by Monday or be evicted”?

7. Did you ever disclose your resignation to the court?

8. Did you inform Silverstein you were no longer the agent?

9. Did you ever admit “I’ve transferred the money” in writing?

10. Did you instruct tenants not to contact the owner?

11. Did you threaten tenants with eviction while unlicensed?

12. Did you conceal knowledge of mold problems?

13. Did you continue using Berkshire branding after resignation?

14. Did you lie under oath about payments?

15. Did you tell tenants, “I’m no longer the agent”?

16. Did you still attend to matters after quitting?

17. Isn’t it true you invoked the Fifth Amendment when questioned by police?

18. Did you ever disclose to the DRE that you resigned?

19. Did you personally profit from rent diversion?

20. Did you attempt to erase tenant history by creating a “new applicant” file?

21. Did you collude with Phat Tran in directing payments?

22. Did you coordinate with Anna Ly in issuing the DocuSign lease?

23. Do you deny responsibility for coercing tenants into a forged contract?

24. Did you threaten to file eviction at noon if not signed?

25. Did you send tenants bank details outside the lease?

26. Did you confirm receipt of $5,350 in April 2024?

27. Did you knowingly allow Silverstein to file a lease you disclaimed?

28. Did you ever tell the owner you had the check?

29. Did you obstruct communication between Berkshire and tenants?

30. Isn’t it true your conduct constitutes wire fraud under federal law?

4) David Beard — Berkshire Hathaway Legal

Focus: receipt of notice, suppression, corporate policy, complicity.

1. Did you personally respond to Plaintiff’s certified notices?

2. Did you ever instruct the Plaintiff not to write you again?

3. Do you confirm you were aware of agent misconduct?

4. Did you forward fraud reports to compliance?

5. Did you warn Martha Mosier about liability?

6. Did you advise Berkshire to deny responsibility for its franchises?

7. Did you know Hanson resigned before Silverstein filed eviction?

8. Did you review the fraudulent lease yourself?

9. Did you ever tell Plaintiff his lease “didn’t matter”?

10. Did you withhold any correspondence from regulators?

11. Did you confirm that certified mail was received?

12. Did you deny that Berkshire had apparent agency obligations?

13. Did you refuse to investigate because of liability risk?

14. Did you receive USPS certified receipt showing delivery?

15. Did you open any letters addressed “To Manager”?

16. Did you intentionally suppress Plaintiff’s evidence?

17. Did you advise Berkshire that ignoring RICO notice was acceptable?

18. Did you seek legal cover for ignoring tenant complaints?

19. Do you admit that Berkshire benefited from franchise fees?

20. Did you notify Berkshire’s insurance about this claim?

21. Were you aware of the elder tenant in this case?

22. Did you fail to act on ADA accommodation notices?

23. Did you ever deny receipt of Plaintiff’s documentation?

24. Did you knowingly allow false filings in court?

25. Did you advise BHHS to deny corporate liability across the board?

26. Did you conceal knowledge of Hanson’s resignation?

27. Did you approve Silverstein’s filing?

28. Did you instruct Berkshire staff to “stay out” of this matter?

29. Do you admit silence equals complicity?

30. Isn’t it true you enabled fraud by deliberate inaction?

5) Phat Tran — Owner / Landlord

Focus: payment chain, concealment, intimidation, retaliation, elder abuse.

1. Did you admit in writing “you lived here 3 years and I never raised your rent”?

2. Did you receive a cashier’s check for $5,350 in April 2024?

3. Did you ever cash that check?

4. Did you return the funds in full?

5. Did you provide proof of return to Plaintiff?

6. Did you ask Hanson to collect funds into his private account?

7. Did you benefit financially from concealing rent payments?

8. Did you admit in court that you saw the check?

9. Did you ever credit payments made to your private account?

10. Did you demand new baseboards and locks for Airbnb?

11. Did you authorize Hanson to threaten eviction?

12. Did you send a pickup truck to intimidate Plaintiff?

13. Did you use a drone to surveil Plaintiff’s property?

14. Did you fail to remediate mold reported by inspectors?

15. Did you ever honor habitability obligations?

16. Did you deny requests for ADA accommodations?

17. Did you profit from re-renting at $7,500?

18. Did you misrepresent lease terms in court filings?

19. Did you instruct Silverstein to file without valid standing?

20. Did you tell Plaintiff “I will never speak to you again”?

21. Did you ever provide an itemized deposit return?

22. Did you demand reissued checks in different names?

23. Did you admit “what we’re doing is business”?

24. Did you intentionally conceal rent checks?

25. Did you request tenants sign fraudulent contracts?

26. Did you refuse to meet at Wells Fargo for resolution?

27. Did you intentionally obstruct payments to Berkshire Hathaway?

28. Did you profit from tax benefits of eviction?

29. Did you instruct LY Construction to assist in fraud?

30. Isn’t it true your actions constitute wire fraud and elder abuse?

6) Steven D. Silverstein — Eviction Counsel

Focus: filing with invalid lease, ethical duties, fraud on the court.

1. Did you file eviction using a lease signed by a resigned agent?

2. Were you aware Hanson had resigned on May 13?

3. Did you confirm that Plaintiff’s rent was paid?

4. Did you review USPS delivery confirmations?

5. Did you refuse to enter Plaintiff’s evidence into record?

6. Did you proceed after being notified of fraudulent lease?

7. Did you knowingly mislead the court about tenancy length?

8. Did you claim nonpayment despite proof of payment?

9. Did you review the DocuSign renewal from Anna Ly?

10. Did you admit in filings that Plaintiff was a “new applicant”?

11. Did you conceal knowledge of certified mail notices?

12. Did you meet ethical standards under CCP §128.7?

13. Did you misrepresent facts under oath?

14. Did you advise your client to conceal check return?

15. Did you obstruct Plaintiff’s ADA requests?

16. Did you accept false testimony knowingly?

17. Did you submit a defective 3-day notice?

18. Did you refuse mediation offers?

19. Did you attempt to profit from repeated evictions?

20. Did you collude with Berkshire Hathaway to shield liability?

21. Did you file on behalf of a party lacking standing?

22. Did you ignore Plaintiff’s police filings?

23. Did you fail to notify the court of conflicting contracts?

24. Did you conceal Hanson’s resignation from judge?

25. Did you ignore Plaintiff’s binder of exhibits?

26. Did you file on evidence you knew was invalid?

27. Did you mislead about property damage?

28. Did you obstruct justice by concealment?

29. Did you ever notify the court of contradictory leases?

30. Isn’t it true your conduct constitutes fraud on the court?

7) Anna Ly — Realtor

Focus: origin lease, renewal contradictions, misrepresentation, 13-month term.

1. Did you originate the first lease at $5,000 + $500 for pets?

2. Did you approve two 100-pound dogs via email?

3. Did you later disclaim renewal responsibility?

4. Did you send a DocuSign renewal in May 2024?

5. Did you deny issuing that same renewal later?

6. Did you hand off the lease to ConsensYs?

7. Did you omit the deposit clause intentionally?

8. Did you coordinate with Hanson in the “new applicant” lease?

9. Did you ignore mold complaints?

10. Did you notify Phat Tran of defects before move-in?

11. Did you conceal lease continuity from Berkshire?

12. Did you coordinate with LY Construction?

13. Did you benefit from commissions despite fraud?

14. Did you approve a 13-month lease without disclosure?

15. Did you send a renewal then deny its validity?

16. Did you collude with Silverstein to misclassify tenants?

17. Did you sign off on a fraudulent eviction filing?

18. Did you misrepresent agency authority?

19. Did you knowingly facilitate RICO predicate acts?

20. Did you respond to certified letters?

21. Did you tell tenants they were “new applicants”?

22. Did you contradict yourself under oath?

23. Did you conceal knowledge of Hanson’s resignation?

24. Did you deflect responsibility to third parties?

25. Did you fail to notify the DRE about fraudulent leases?

26. Did you mislead about who managed lease renewals?

27. Did you omit lease protections on purpose?

28. Did you benefit from rent escalation fraud?

29. Did you knowingly approve a forged contract?

30. Isn’t it true your role enabled RICO fraud?

8) LY Construction — Corporate Conspirator

Focus: trespass, fabricated damage, intimidation, turnover profit.

1. Were you contracted by Phat Tran for property work?

2. Did you have access to tenant property during lease?

3. Did you communicate with Hanson Le about tenancy?

4. Were you aware of ongoing litigation?

5. Did you enter the property without notice?

6. Did you perform work tied to eviction preparation?

7. Did you remove landscaping or fixtures?

8. Did you benefit financially from eviction?

9. Did you conspire to intimidate tenants?

10. Did you trespass during tenancy?

11. Did you help conceal mold conditions?

12. Did you provide false damage reports?

13. Did you coordinate with Silverstein?

14. Did you collude with Anna Ly?

15. Did you provide estimates for fabricated damages?

16. Did you conceal preexisting defects?

17. Did you profit from turnover repairs?

18. Did you mislead about scope of damage?

19. Did you falsify property condition records?

20. Did you have inside knowledge of fraudulent lease?

21. Did you act as enforcer for Phat Tran?

22. Did you trespass with truck incident parties?

23. Did you threaten tenants directly?

24. Did you profit from replacement contracts?

25. Did you have liability coverage for fraudulent work?

26. Did you coordinate with Phat’s family members?

27. Did you act beyond licensed scope of work?

28. Did you ignore tenant repair requests?

29. Did you fabricate invoices for eviction?

30. Isn’t it true LY Construction enabled RICO fraud?

9) Dennis Rosas — Marina Manager (BHHS Franchise)

Focus: branch oversight, “moonlighting” statement, failure to report, facilitation.

1. Did you serve as manager at the Berkshire Hathaway Marina office during 2022–2024?

2. Were you responsible for supervising agents including Hanson Le and Anna Ly?

3. Did you ever review Plaintiff’s lease agreements?

4. Did you communicate with the Plaintiff regarding fraud concerns?

5. Did you state that Hanson’s activities were “moonlighting”?

6. Were you aware Hanson was using Berkshire’s name after resigning?

7. Did you ever notify Berkshire’s legal department of these issues?

8. Did you review or approve any contracts involving the Plaintiff?

9. Did you ever tell the Plaintiff his lease extension was invalid?

10. Did you receive certified mail regarding this case?

11. Did you forward tenant complaints to corporate headquarters?

12. Did you ever investigate misconduct at your branch?

13. Were you aware of the pickup truck intimidation incident?

14. Did you inform Phat Tran that Berkshire would not back him?

15. Did you communicate with Silverstein Evictions?

16. Did you fail to discipline Hanson for taking payments?

17. Did you knowingly allow BHHS branding to be used after Hanson’s resignation?

18. Did you coordinate with Anna Ly regarding leases?

19. Did you conceal knowledge of fraud from Plaintiff?

20. Did you deny that Berkshire had responsibility for its agents?

21. Were you pressured by Berkshire corporate to ignore complaints?

22. Did you destroy or fail to preserve records related to Plaintiff’s tenancy?

23. Did you conceal knowledge of fraudulent lease documents?

24. Did you fail to report Hanson to the Department of Real Estate?

25. Did you ever admit to Plaintiff that this was “moonlighting” outside the brand?

26. Do you deny that your inaction allowed fraud to continue?

27. Did you ever benefit financially from lease renewals?

28. Did you resign to avoid accountability?

29. Do you deny liability for the misuse of your franchise office?

30. Isn’t it true your conduct as manager enabled a RICO scheme under Berkshire’s name?

10) Angie Sandoval — Manager (Marina/Springdale, BHHS Franchise)

Focus: management knowledge, notice handling, DRE reporting, concealment.

1. Did you serve as manager at the Berkshire Hathaway Marina/Springdale office?

2. Were you responsible for supervising agents including Hanson Le and Anna Ly?

3. Did you ever review Plaintiff’s lease agreements?

4. Did you ever receive or open certified mail regarding this case?

5. Did you forward tenant complaints to Berkshire corporate?

6. Did you investigate misconduct at your branch when notified?

7. Were you aware of Hanson’s resignation?

8. Did you continue to let him act under BHHS branding afterward?

9. Did you meet with Phat Tran regarding tenancy issues?

10. Did you tell anyone this was “moonlighting”?

11. Did you inform Berkshire risk/legal about these problems?

12. Did you ever communicate with Silverstein about the case?

13. Did you approve contracts or filings involving the Plaintiff?

14. Did you ignore Plaintiff’s reports of mold and habitability violations?

15. Were you aware of intimidation tactics used at the property?

16. Did you ever deny responsibility for supervising your agents?

17. Did you preserve or destroy records tied to this tenancy?

18. Did you conceal lease continuity or tenant history from regulators?

19. Did you fail to report Hanson’s conduct to the DRE?

20. Did you communicate with Anna Ly about renewal disputes?

21. Did you profit from franchise fees tied to the Plaintiff’s lease?

22. Were you pressured by corporate to downplay complaints?

23. Did you warn agents not to put things in writing?

24. Did you ignore ADA or senior-related notices?

25. Did you help deflect liability by saying “corporate isn’t responsible”?

26. Did you resign or transfer to avoid accountability?

27. Did you ever disclose to regulators that this was handled as “moonlighting”?

28. Do you deny your failure to act enabled fraudulent eviction?

29. Isn’t it true you had actual notice of ongoing RICO predicates?

30. Do you accept that your silence made you complicit in fraud under BHHS’s name?