False, Fabricated, and Misleading Claims Submitted Under Her Authority

Introduction

This article documents what appears to be a troubling pattern of negligence, misrepresentation, and failure of oversight by Tran Banh, Regional Property Manager for Greystar, in connection with the Workplace Violence Restraining Order filed on November 18, 2025, in Case No. 25LBRO02423.

The filing contains false, fabricated, and misleading statements, including:

• incorrectly labeling an adult as a “minor child,”
• including non-employees in a Workplace Violence TRO,
• recycling allegations from months prior,
• ignoring the fact that there has been no contact since 3/6/2025,
• submitting narratives contradicted by evidence, and
• omitting months of tenant complaints about harassment and retaliation by staff.

Although attorney Kyle Genovese filed the documents, the petition was signed under penalty of perjury by Tran Banh, meaning the responsibility for the factual accuracy rests directly with her.

1. Misrepresentation of a “Minor Child” Who Is in Fact an Adult

One of the most concerning errors in the TRO is the listing of a “minor child” as a protected person.

This individual is not a minor, but a fully grown adult.

This is not a small clerical oversight — this is a material misrepresentation of:

• age,
• vulnerability,
• legal standing, and
• eligibility for protection.

This false statement was included in a sworn TRO and submitted to the court without correction.
Such an error demonstrates either reckless disregard for accuracy or complete failure to review the content before signing.

Either way, it reflects a serious failure in Tran’s managerial oversight.

2. Improper Inclusion of Non-Employees in a Workplace Violence TRO

Workplace Violence TROs under CCP §527.8 apply only to employees.

Yet the TRO included:

• a spouse, and
• a fully grown adult child falsely labeled as a minor.

Neither of these individuals is legally eligible.

Submitting a Workplace Violence TRO that includes non-employees is a misuse of the statute and shows that Tran either:

• did not understand the law,
• did not review the petition, or
• knowingly allowed improper expansion of the filing.

All reflect failures in professional responsibility.

3. Recycling Old Allegations Despite Zero Contact Since 3/6/2025

This is one of the most significant contradictions:

✔ There has been no contact between the tenant and Kathy since March 6, 2025

✔ Yet the TRO filed in November recycles old allegations as if they are new

✔ Those same allegations were submitted previously by the same office

✔ The earlier TRO filed the same morning was dismissed

This means the TRO signed by Tran:

• relied on stale events,
• ignored the lack of contact for 8+ months,
• recycled prior claims as if they are current threats,
• failed to provide any recent or ongoing conduct,
• and presented a misleading sense of danger to the court.

A Workplace Violence TRO requires recent threatening behavior, not outdated incidents from early March.

This is a fundamental defect that Tran should have recognized before signing.

4. Signing the TRO Without Verifying Facts

Attorney Kyle Genovese graduated law school in 2021 and is early in his career.
However, Tran is the regional manager who signed the sworn petition, meaning she accepted full responsibility for:

• every statement,
• every allegation,
• every listed name, and
• every claimed “fact.”

Yet the document contains:

• false information,
• misidentified individuals,
• eligibility errors,
• hearsay presented as fact,
• unverified narratives,
• contradictory accounts, and
• recycled, outdated incidents.

This strongly suggests that Tran did not review the contents for accuracy before signing.

Negligently signing a flawed legal document is a serious breach of professional responsibility.

5. Reliance on Hearsay Instead of Evidence

The TRO relies overwhelmingly on:

• third-hand statements,
• emotional narratives,
• forwarded comments,
• hearsay,
• speculation,
• and assumptions.

It does not contain:

• sworn witness declarations,
• video evidence,
• police bodycam footage,
• timestamps,
• photographs,
• or neutral witness accounts.

This is not a lawful basis for a Workplace Violence TRO.
It reflects a complete lack of verification.

As regional manager, Tran had the duty to ensure accuracy before authorizing the filing. She did not.

6. Omission of Critical Context and Prior Complaints

The TRO packet omits months of:

• harassment by on-site staff,
• retaliatory actions,
• discriminatory remarks,
• misuse of property authority,
• unlawful photographs and monitoring of a tenant,
• refused access to leasing records,
• and numerous complaints escalated to regional management.

Tran received these complaints months before the TRO yet failed to respond or investigate.

By signing the TRO without including this context, she contributed to a distorted and misleading narrative.

7. TRO Filed as Retaliation, Not Protection

When reviewing the:

• timeline,
• lack of contact since 3/6/2025,
• recycled allegations,
• misrepresentation of a “minor,”
• inclusion of non-employees,
• exaggerated narratives,
• ignored tenant complaints, and
• absence of evidence,

The TRO appears to be retaliatory, not protective.

It reads as an attempt to silence or punish a tenant who repeatedly reported harassment, discrimination, and misconduct by property staff.

Conclusion

The Workplace Violence TRO filed by Greystar and signed by Tran Banh contains:

• false statements,
• fabricated claims,
• misrepresented individuals,
• ineligible protected persons,
• hearsay instead of evidence,
• recycled allegations, and
• events from months prior despite zero contact since 3/6/2025.

As the regional manager supervising the office, Tran had the obligation to:

• investigate tenant complaints,
• verify facts,
• confirm eligibility,
• review the petition for accuracy,
• and prevent misuse of legal processes.

Instead, she signed a petition riddled with inaccuracies, omissions, and misrepresentations.

This represents a clear failure in managerial oversight and raises serious concerns about Greystar’s internal practices and integrity.

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