Attorney Information

Name: Kyle Genovese
Law Firm: Kimball, Tirey & St. John LLP (KTS Law)
Role: Attorney representing Greystar California, Inc.
Case Involved: Workplace Violence Restraining Order (WVRO)
Case Number: 25LBRO02423
Court: Superior Court of California, County of Los Angeles – Long Beach

Nature of the Complaint

I am filing this complaint because I believe Attorney Kyle Genovese may have violated multiple provisions of the California Rules of Professional Conduct by submitting a Workplace Violence Restraining Order (WVRO) containing false, fabricated, misleading, and unverified statements, including a misrepresentation of a legally adult individual as a “minor child”, and by recycling allegations from prior disputes despite admitting there has been no contact whatsoever for over eight months.

This raises serious concerns about:

• factual accuracy,
• ethical compliance,
• good-faith filing obligations, and
• potential misuse of the Workplace Violence TRO procedure.

Specific Ethical Concerns

1. Filing False, Fabricated, and Misleading Statements

The WVRO contains numerous statements that appear to be:

• factually incorrect,
• contradicted by evidence,
• exaggerated,
• taken out of context, or
• entirely fabricated.

The petition includes claims attributed to individuals who:

• were not present,
• did not witness the events, or
• repeated unverified hearsay.

Attorneys have a duty to ensure all factual assertions have evidentiary support before filing.

2. Misrepresentation of a “Minor Child” Who Is Actually an Adult

The TRO lists a “minor child” of a Greystar employee as a protected person.

However:

✔ This individual is not a minor

✔ He is an adult

This is a material misrepresentation in a sworn petition.
This is not a clerical error — it misleads the court and misuses a workplace violence statute intended to protect employees, not adult family members.

This may violate:

• Rule 3.3 (Candor Toward the Court)
• Rule 8.4(c) (Misrepresentation / deceit)

3. Improper Inclusion of Non-Employees

The petition includes:

• a spouse of an employee, and
• a fully grown adult child falsely labeled a “minor”

These individuals are not employees and are not eligible for protection under CCP § 527.8.

Submitting a TRO that knowingly includes non-eligible, non-employee individuals misuses the statute and misleads the judge.

4. Recycling Prior Allegations Despite Admitted Lack of Contact Since 3/6/2025

This is one of the most serious issues:

✔ The TRO recycles allegations from months earlier

✔ Kyle previously submitted claims regarding the same incidents

✔ Yet all parties now admit there has been no contact with Kathy since 3/6/2025

✔ Despite that, he resubmitted the same allegations as if they are current “workplace violence”

This contradicts the nature of a workplace violence petition, which requires:

• recent conduct
• active threats
• ongoing incidents

Instead, Kyle presented stale, unrelated, previously resolved, and outdated complaints from over eight months prior as if they were current, active threats.

This is extremely misleading and appears to violate:

• Rule 3.1 – Filing only meritorious claims
• Rule 3.3 – Truthfulness to the court
• Rule 8.4(c) – Dishonesty, fraud, misrepresentation

Filing a TRO based on events from early March — when even Greystar concedes no further contact occurred — is a red flag for bad-faith litigation.

5. Reliance on Hearsay Instead of Evidence

The TRO relies extensively on unverified hearsay, including:

• forwarded emails
• statements from people not present
• opinions rather than facts
• contradictions between staff
• unsupported claims absent any physical evidence

No sworn firsthand declarations were provided.
No police evidence was submitted.
No video was included despite the property having cameras.

Submitting a petition without sufficient evidentiary foundation violates ethical duties.

6. Omission of Critical Context

The TRO omits:

• months of tenant complaints about harassment by staff,
• prior misconduct by on-site employees,
• the complete absence of contact between the tenant and staff since 3/6/2025,
• pre-existing retaliatory actions by the property office,
• and the earlier TRO filed the SAME DAY that was dismissed.

Omitting these facts creates a false and misleading narrative for the court.

Harm Caused

The TRO filing, based on false, misleading, and outdated allegations, resulted in:

• wrongful initiation of a serious legal proceeding,
• misuse of a workplace violence statute,
• reputational harm,
• emotional distress,
• misleading the court,
• and improper escalation of a situation that had not involved any contact since March.

Requested Action

Requests for California State Bar:

• Investigate Attorney Kyle Genovese’s conduct in filing the WVRO
• Review whether he knowingly filed false or misleading information
• Examine whether his reuse of stale allegations constitutes bad-faith TRO filing
• Determine whether he violated Rules 3.1, 3.3, 3.4, or 8.4(c)

Provided:

• The TRO packet
• Prior filings by Kyle
• Evidence contradicting the TRO allegations
• Proof of no contact since 3/6/2025
• Emails, videos, and timelines

How to File a Complaint Against an Attorney With the California Bar Association:

https://www.calbar.ca.gov/Public/Complaints-Claims/How-to-File-A-Complaint

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