Electronically Filed by Superior Court of California
                     Electronically Filed by Superior Court of California, County of Orange, 11/23/2022 02:54:19 
PM.
30-2022-01294260-CU-DF-CJC - ROA # 2 - DAVID H. YAMASAKI, Clerk of the Court By K. Trent, 
Deputy Clerk.
1 ALESSANDRO G. ASSANTI, ESQ. (State Bar No. 
181368)
A.G. ASSANTI & ASSOCIATES, PC
2 9841 Irvine Center Dr Suite 100, 
 Irvine, CA 92618
3 v. (949) 540-0439 f. (949) 540-
0439
email: [email protected]
4
Attorneys for Plaintiff, Yuri Vanetik
5
6 SUPERIOR COURT OF THE STATE OF CALIFORNIA 
 IN AND FOR THE COUNTY OF ORANGE
7
8 Yuri Vanetik, an individual, ) CASE NO.:
)
9 )
Plaintiff ) COMPLAINT FOR:10 ) 1) DEFAMATION PER SE
) 2)TORTIOUS INTERFERENCE WITH  11
vs. ) PERSPECTIVE ECONOMIC  
12 ) ADVANTAGE;
) 3)INTENTIONAL INFLICTION OF  
13 Brian T. Hall, Michelle A. Hall and DOES 1- ) EMOTIONAL DISTRESS; and
 50, inclusive, ) 9) HARRASSMENT14 )
Defendants.
15 ) DEMAND FOR JURY TRIAL
)
16 ) Assigned for All Purposes
)
17 )
)
18
)
19
 )
20   ) )
21
22 Plaintiff Yuri Vanetik (“Vanetik” or “Plaintiff Vanetik”) brings his Complaint against the
23 Defendants listed below and alleges as follows:
24
25
267
28 1
COMPLAINT FOR DAMAGES
1 1.   Plaintiff Yuri Vanetik is an American attorney, political activist and businessman who 
has
served as California Lottery Commissioner and Criminal Justice Commissioner, appointed
2
by Governor Arnold Schwarzenegger. Vanetik resides in Newport Beach, in the County of
3
4 Orange, state of California.
5 2.   The Defendant, Brian Troy Hall aka Brian Hall aka Brian T. Hall (“Brian Hall” or
6 “Defendant Brian Hall”) and Michelle A. Hall are residents of Gig Harbor, Washington,
7
residing at 6515 43rd Avenue Court, Gig Harbor, WA 98335.
8
3.   Defendant Brian T. Hall together with his wife, Michele A. Hall aka Michele Hall operates
9
an importation and sales of ROW-vintage and legacy Land Rover Defender parts, vehicles,
10
11 and restoration services business under the name Defenders Northwest, LLC
12 (www.defendersnorthwest.com).
13 4.   Brian Hall is also a purported owner of a related business called Autohome USA
14 (www.autohomeusa.com).
15
5.   Defendants Brian Hall and Michele Hall are also defendants in an unrelated lawsuit brought
16
in Orange County, Superior Court, where they are accused, inter alia, of defrauding
17
customers through fake automotive restoration projects and operating an illegal automotive
18
19 parts marketing, sales and distribution business.
20 6.   The true names and capacities, whether individual, corporate, limited liability company,
21 associate, or otherwise, of the named Defendants sued herein as DOES 1 through 50,
22 inclusive, hereinafter also referred to as the “Fictitiously Named Defendants” or (“DOES”),
23
are currently unknown to Plaintiff who, therefore, sues said Defendants by such fictitious
24
names. Plaintiff is informed and believes, and based upon such information and belief
25
alleges, that each of the Fictitiously Named Defendants are responsible to Plaintiff in some
26
27
28 2
COMPLAINT FOR DAMAGES
1 manner for the acts, omissions, or other conduct as hereinafter alleged, or is a necessary party
2 for the relief sought herein and is subject to the jurisdiction of this court; and further are
3
being sued in both their individual and official capacity. Plaintiff will seek leave of court to
4
amend this Complaint to allege each of their true names and capacities when same have been
5
ascertained.
6
7 7.   Each reference to “Defendant,” “Defendants,” “DEFENDANT” and/or “DEFENDANTS”
8 herein is intended to be a reference to all Defendants named herein, including the Fictitiously
9 Named Defendants, unless otherwise expressly indicated or the context otherwise requires.
10 8.   Plaintiff Vanetik is informed and believes, and based upon such information and belief
11
alleges, that at all times herein relevant, each of the Defendants was and is the principal,
12
agent, representative, supervisor, employee, servant, alter ego, partner, shareholder, director,
13
officer, joint venture, parent corporation,  subsidiary corporation, co-conspirator, licensor,
14
15 licensee, inviter, invitee, predecessor-in-interest, successor-in-interest, assignor and/or
16 assignee (hereinafter referred to as an “Interrelationship”), as may be applicable, of each the
17 other Defendants, and, in doing the things hereinafter alleged, was (a) acting in concert with
18 all of the other Defendants; (b) under the direction, instruction, demand, requirement, and/or
19
control of some or all of the other Defendants; (c) in furtherance of a common plan, scheme,
20
enterprise and/or control of some or all of the other Defendants; (d) in furtherance of a
21
common plan, scheme, enterprise and/or conspiracy with some or all of the Defendants;
22
23 and/or (e) with the knowledge, consent, acquiescence, and/or prior or subsequent ratification
24 of some or all of the other Defendants. Plaintiff Vanetik is further informed and believes and
25 based thereon alleges that the acts and conduct herein alleged of each such Defendant were
26
known to, authorized by, and/or ratified by the other Defendants, and each of them.
27
28 3
COMPLAINT FOR DAMAGES
1
2 9.   Plaintiff Vanetik further alleges that each of said Defendants proximately caused the injuries
3
and damages by reason of negligent, careless, deliberately indifferent, intentional, willful or
4
wanton misconduct, including the negligent, careless, deliberately indifferent, intentional,
5
willful or wanton misconduct in creating and otherwise causing the incidents, conditions and
6
7 circumstances hereinafter set forth, or by reason of the direct or imputed intentional acts,
8 negligence or vicarious fault or breach of duty arising out of the matters herein alleged.
9 10. Plaintiff Vanetik is informed and believes and, on that basis, alleges that in connection with
10 the acts set forth herein, each of the Defendants acted willingly, intentionally, and
11
knowingly, both for himself, herself, or itself, and in concert with each other Defendant, and
12
as an agent for each other Defendant, and was at all times acting within the course and scope
13
of such agency, with the consent, authorization and/or ratification of each other Defendant,
14
15 and in furtherance of a common scheme to defame Vanetik and interfere with and destroy
16 his business interests globally, as further discussed below.
17 11. Plaintiff is informed and believes, and based upon such information and belief alleges, that at
18 all times herein relevant, each of the Defendants was and is the principal, agent,
19
representative, supervisor, employee, servant, alter ego, partner, shareholder, director,
20
officer, joint venture, parent corporation,  subsidiary corporation, co-conspirator, licensor,
21
licensee, inviter, invitee, predecessor-in-interest, successor-in-interest, assignor   and/or
22
23 assignee (hereinafter referred to as an “Interrelationship”), as may be applicable, of each the
24 other Defendants, and, in doing the things hereinafter alleged, was (a) acting in concert with
25 all of the other Defendants; (b) under the direction, instruction, demand, requirement, and/or
26
control of some or all of the other Defendants; (c) in furtherance of a common plan, scheme,
27
28 4
COMPLAINT FOR DAMAGES
1 enterprise and/or control of some or all of the other Defendants; (d) in furtherance of a
2 common plan, scheme, enterprise and/or conspiracy with some or all of the Defendants;
3
and/or (e) with the knowledge, consent, acquiescence, and/or prior or subsequent ratification
4
of some or all of the other Defendants.
5
12. Plaintiff further alleges that each of said Defendants proximately caused the injuries and
6
7 damages by reason of negligent, careless, deliberately indifferent, intentional, willful or
8 wanton misconduct, including the negligent, careless, deliberately indifferent, intentional,
9 willful or wanton misconduct in creating and otherwise causing the incidents, conditions and
10 circumstances hereinafter set forth, or by reason of the direct or imputed negligence or
11
vicarious fault or breach of duty arising out of the matters herein alleged.
12
13. The lawsuit that has been filed against Defendant Brian Hall and his wife, Michele Hall has
13
been featured in the multiple media domestically and
14
15 overseas:  https://
16 vwewd=w2.gaohoUgKleE.cwoimPo/ufqrlp?3saZ=Pt7&ArchtV=jL&LqU=Q&IeHsrUci=0sC&igsoQuFrcneo=EwCeAbU&QcdA=Q&&caudrl==rhjatt&psu%ac3t=A8%&2F%2F
17 pledgetimes.com%2Fwashington-state-auto-restorer-defenders-northwest-sued-for-
18 fraud%2F&usg=AOvVaw2cVnpetf2SVBHXNenDOPJU;
19
https://www.google.com/url?sa=t&rct=j&q=&esrc=s&source=web&cd=&cad=rja&uact=8
20
&ved=2ahUKEwiA7Jma0Z37AhX_DkQIHZ7HDuoQFnoECBYQAw&url=https%3A%2F
21
%2Ftheprint.in%2Ftheprint-valuead-initiative%2Fwashington-state-couple-brian-hall-and-
22
23 michele-hall-accused-of-major-auto-repair-
24 scam%2F1202118%2F%23%3A~%3Atext%3DA%2520lawsuit%2520for%2520fraud%252
25 0filed%2Cscam%252C%2520defrauding%2520automotive%2520restoration%2520custome
26
rs.&usg=AOvVaw2EUySfDQMuD0M3-y7KnZlR
27
28 5
COMPLAINT FOR DAMAGES
1
2 14. Plaintiff, Vanetik is informed and believes that Defendant Brian Hall is a serial scammer
3
who has been caught cheating Plaintiff, Vanetik’s clients and is blaming Plaintiff,
4
Vanetik for having been exposed and sued.
5
15. Plaintiff, Vanetik is informed and believes that Defendant Brian Hall and Michelle Hall
6
7 decided to retaliate against Plaintiff Vanetik whom they blame for exposing Defendant
8 Brian Hall and Michelle Halls’ scheme to defraud Defenders Northwest customers as set
9 out in an unrelated action
10 https://www.google.com/url?sa=t&rct=j&q=&esrc=s&source=web&cd=&cad=rja&uact=
11
8&ved=2ahUKEwid2dff0Z37AhXCKEQIHSWfB7oQFnoECA0QAQ&url=https%3A%
12
2F%2Fissuu.com%2Fdefendersnw%2Fdocs%2Fbrian_hall_defenders_northwest_noti_5f
13
3c89402c3445&usg=AOvVaw0Y0pFp-AsluA6yUiEcZRcr
14
15 16. Plaintiff Vanetik is informed and believes and on that basis alleges that Defendants Brian
16 Hall, Michelle Hall and DOES have chosen to retaliate against Plaintiff Vanetik by
17 attacking him online via social media such as Twitter and Facebook by creating fake
18 name accounts such as “Purple Rain”, “Greg MacDonald”, “Bill Cosby”, “Michael
19
Huntsman”, and multiple others.
20
17. Plaintiff, Vanetik is informed and believes and on that basis alleges that Defendants
21
began their acts described herein in approximately in October 2022 started posting
22
23 vicious ad hominem attacks against Plaintiff Vanetik to cause emotional distress,
24 financial harm, and reputational harm to Plaintiff Vanetik. All statements are knowingly
25 untrue.
26
27
28 6
COMPLAINT FOR DAMAGES
1 18. Plaintiff Vanetik is informed and believes and on that bases alleges that the documented
2 and ongoing posts have been subject to forensic analysis and clearly show that they
3
originate from the Defendants and reference an imposter web site created by the
4
Defendants, using Plaintiff Vanetik’s full name (Yuri_Vanetik.com) where Defendants
5
posted false and malicious claims about Plaintiff Vanetik and his family, and business.
6
7 19. Plaintiff Vanetik is informed and believes and on that basis alleges that Defendant Brian
8 Hall, using the imposter web site, and fake accounts on Twitter and Facebook started
9 posting claims that Plaintiff Vanetik is a member of fringe terrorist organizations, is a
10 criminal, and a client of notorious convicted pedophile and sex trafficker Jeffrey Epstein.
11
20. Plaintiff Vanetik is informed and believes and on that basis alleges that Defendants and
12
each of them used fake web sites and accounts and are engaged and continue to
13
systematically harass Plaintiff Vanetik, attacking his ethnicity, physical characteristics,
14
15 and alleging that he is, inter alia, did not pass law school and college exams and is
16 engaged in criminal activity; despite the outlandish and false nature of the Defendants’
17 claims they have been including hashtags and posting on chat of Plaintiff Vanetik’s
18 associates and clients causing him grave economic and reputational harm and emotional
19
distress.
20
21. Plaintiff Vanetik is informed and believes and on that basis alleges that the Defendants
21
and each of them posted false and malicious statements about Plaintiff Vanetik’s parents,
22
23 asserting that they are criminals.
24 22. Plaintiff Vanetik is informed and believes that the Defendants have been actively
25 working on an ongoing basis to defame Vanetik and interfere with his business interests
26
not only in U.S., but globally.
27
28 7
COMPLAINT FOR DAMAGES
1
2 FACTS COMMON TO ALL CLAIMS FOR RELIEF
3
23. Plaintiff, Vanetik is informed and believes and on that basis alleges that approximately
4
between October 2022 to present time Defendant Brian Hall and DOES engage in a
5
vicious campaign to libel him by using an imposter web site registered as a domain with
6
7 his name – Yuri Vanetik and fake accounts on twitter and Facebook.
8 24. Plaintiff Vanetik is informed and believes and on that basis alleges that Defendants, used
9 direct posts, guest posts on Plaintiff Vanetik’s Facebook page and twitter page, and by
10 posting using hashtags and in conversations between third parties on the two aforementioned
11
social media platforms posted, inter alia, insults and expletives in reference to Plaintiff
12
Vanetik and his family, allegations that Plaintiff Vanetik is a criminal, terrorist, pedophile,
13
lied about his education, professional licensing, social standing, etc.
14
15 DEFENDANTS’ ACTIONABLE BEHAVIOR
16 25. Plaintiff Vanetik is informed and believes and, based thereon alleges that Defendant Brian
17 Hall and Michelle Hall, and at all times relevant hereto was, an individual doing business in
18 the County of Orange, State of California and used the Internet to defame Vanetik and
19
interfere and damage his business and cause him severe emotional distress.
20
26. Plaintiff Vanetik is informed and believes and based thereon alleges that the Halls and
21
DOES from October 2022 through present have been engaged in deliberate smear campaign
22
23 against Plaintiff Vanetik, his family, and his businesses.
24 27. Plaintiff Vanetik is informed and believes and, based thereon alleges that the fake posts by 
 25 Defendants allege that Plaintiff is a notorious criminal and sex trafficker, that he has ties to
26
dubious criminals, that he is bankrupt and that he engages in criminal behavior and is being
27
28 8
COMPLAINT FOR DAMAGES
1 investigated by U.S. State Department and various law enforcement agencies. All these
2 claims are patently false and made with knowledge of their falsity out of utter malice
3
directed at Plaintiff Vanetik by the Defendants.
4
5 FIRST CLAIM FOR RELIEF
6 (Defamation Per Se)  
(Against All Defendants)
7
8 28. Plaintiff realleges and incorporates by references paragraphs 1 through 27 as though fully set
9
forth herein.
10
29. Defendants Brian and Michelle Hall and DOES, continue to conspire and make these false
11
representations and statements as alleged herein, while knowing that their representations
12
13 were materially false and designed with the intent to specifically injure the reputation of
14 Plaintiff Vanetik. Each and all of those false, material representations were published to
15 various media sources including Western media, East European media, and various internet
16
third parties, and third parties that Plaintiff Vanetik has social, business, and political
17
relationships with or that are aware of Plaintiff Vanetik’s business and exert influence on it
18
directly or indirectly.
19
20 30. Defendants made these false representations, false submissions to social media and
21 published on fake web sites in the hopes of damaging and destroying Vanetik’s reputation
22 and ultimately his interests in ventures that he is involved in globally. These false
23 representations and false submissions were relied on by the various business leaders,
24
politicians, and members of the legitimate press.
25
26
27
28 9
COMPLAINT FOR DAMAGES
1 31. Plaintiff Vanetik has been substantially harmed as a result of the Defendant Brian Hall’s
2 defamatory conduct which injured the reputation and his business interests in an amount that
3
is presently unknown but certainly in excess of the minimum jurisdiction of this Court.
4
32. Defendants knew that the representations, allegations against the Plaintiff were knowingly
5
false and were made with the intent to harm and injure Vanetik.
6
7 33. The Defendants and each of them are guilty of recklessness, oppression, fraud and malice
8 and, therefore, Plaintiff Vanetik is entitled to compensatory, punitive damages and recovery
9 of attorney fees against each of them in an amount to be proven at the time of trial.
10 34. Defendants have caused general damages according to proof. They further have caused
11
damage to Plaintiff’s reputation and businesses in an amount of at least $10,000,000.00 in
12
monetary damages to be proven at the time of trial.
13
14
SECOND CLAIM FOR RELIEF
15
Tortious Interference with Perspective Economic Advantage  
16
(Against Defendant Brian Hall and DOES 1-50 Inclusive)
17
18 35. Plaintiff realleges and incorporates by references, as though set forth in
19
full, paragraphs 1 through 34, above.
20
36. Defendants at all times were aware of various business relationships and contracts that
21
Plaintiff Vanetik had with various businesses in Ukraine, Israel, Germany, and the U.S.
22
23 based on his study of Plaintiff Vanetik’s online and media footprint.
24 37. By engaging in a social media campaign aimed to harass and damage Plaintiff Vanetik, the  
25 Defendants Brian and Michelle Hall and DOES’ activity as alleged herein, has caused loss
26
of business and reputation to Plaintiff Vanetik, in that the person who read the statements
27
28 10
COMPLAINT FOR DAMAGES
1 that stated Plaintiff was a criminal, sex trafficker, pedophile and client of Jeffrey Epstein
2 were made with knowledge of their falsity.
3
38. Furthermore, the statements are online and expose Plaintiff to millions of readers who would
4
understand that the statements were made about Plaintiff and could be believed by the
5
readers of such statements and therefore cause the readers including clients, acquaintances
6
7 and prospective business contacts to avoid having any interaction with Plaintiff, due solely
8 to the false and harmful allegations.
9 39. Defendants are guilty of recklessness, oppression, fraud and malice within the meaning of
10 Civil Code § 3294. An award of punitive and exemplary damages is justified in an amount
11
according to proof, which is unknown but in excess of the minimum jurisdiction of this
12
Court.
13
40. Plaintiff further alleges that such conduct has damaged Plaintiff and his business interest in
14
15 an amount that is at least $10,000,000.00 to be proven at the time of trial.
16
17 THIRD CLAIM FOR RELIEF
18 Intentional Infliction of Emotional Distress  
19 (Against Defendant Brian Hall and Does 1-50, Inclusive)
41. Plaintiff realleges and incorporates by reference, as though set forth in
20
21 full, paragraphs 1-40, above.
22 42. As stated above, in October 2022 Defendants Brian and Michelle Hall and DOES have
23 chosen to retaliate against Plaintiff Vanetik by attacking him online via social media such as
24
Twitter and Facebook by creating fake name accounts such as “Purple Rain”, “Greg
25
MacDonald”, “Bill Cosby”, “Michael Huntsman”, and multiple others.
26
27
28 11
COMPLAINT FOR DAMAGES
1 43. Plaintiff Vanetik is informed and believes and on that basis alleges that 
Defendants,
beginning approximately in October 2022, started posting vicious ad hominem attacks
2
against Plaintiff Vanetik to cause emotional distress, financial harm, and reputational harm
3
4 to Plaintiff Vanetik.
5 44. Plaintiff Vanetik is informed and believes and on that bases alleges that the documented and
6 ongoing posts have been subject to forensic analysis and clearly show that they originate
7
from the Defendants Brian and Michelle Hall and potentially DOES and reference an
8
imposter web site created by the Defendants where they use Plaintiff Vanetik’s full name
9
(Yuri_Vanetik.com) where Defendants have posted false and malicious claims about
10
11 Plaintiff Vanetik, his family, and business.
12 45. Plaintiff Vanetik is informed and believes and on that basis alleges that Defendants are
13 using an imposter web site, and fake accounts on Twitter and Facebook and are posting
14 claims that Plaintiff Vanetik is a member of fringe terrorist organizations, is a criminal, and
15
a client of notorious convicted pedophile and sex trafficker Jeffrey Epstein.
16
46. Plaintiff Vanetik is informed and believes and on that basis alleges that Defendants use fake
17
web sites and accounts; and engage and continue to systematically harass Plaintiff Vanetik,
18
19 by attacking his ethnicity, physical characteristics, and alleging that he is, inter alia, did not
20 pass law school and college exams and is engaged in criminal activity. Despite the
21 outlandish and false nature of Defendants’ claims each and all Defendants have been
22 including hashtags and posting on chat of Plaintiff Vanetik’s associates and clients causing
23
him grave economic harm and reputational harm.
24
25
26
27
28 12
COMPLAINT FOR DAMAGES
1 47. Plaintiff Vanetik is informed and believes and on that basis alleges that Defendants and 
each
of them have also posted false and malicious statements about Plaintiff Vanetik’s parents,
2
asserting that they are criminals.
3
4 48. The above conduct by definition is extreme and outrageous behavior that was undertaken by
5 Defendants and others who are presently unknown and are hereby known only as DOES at
6 this point in time.
7
49. The Defendants acted intentionally as their threats and actions were designed to cause and
8
did cause extreme emotional distress. In fact, the actions were tantamount to a terrorist
9
threat, as the Defendants and each of them unlawfully claimed that Plaintiff Vanetik is a
10
11 criminal and sex offender who lied about his education and professional licensing.
12 50. The conduct has injured, harmed Plaintiff in an amount that is in excess of the minimum
13 jurisdiction of this court, which will be proven at the time of trial.
14 51. Plaintiff also prays for punitive damages in an amount that will punish and deter others from
15
engaging in such extreme, outrageous, malicious and vile conduct in an amount that will
16
exceed the minimum jurisdiction of this Court.
17
18
19 DEMAND FOR JURY TRIAL
20 Plaintiff hereby demands a trial by jury of all issues so triable in the present action.
21
22 ///
23 ///
24 ///
25 ///
26 ///
27
28 13
COMPLAINT FOR DAMAGES
1 WHEREFORE, Plaintiff prays for judgment against Defendants, as follows:
2
3 On The First Claim for Relief
4 1. For general damages according to proof;
5 2. For Special Damages of at least $10,000,000.00;
6 3. For Punitive Damages according to Proof;
7 4. For prejudgment interest according to statute;
8 5. For Plaintiffs’ reasonable attorneys’ fees and costs according to statute; and
96. For Attorney’s fees and costs according to statute.  10
11 On Causes of Action 2 and 3 Claims for 
Relief:
12 1. For general damages according to proof;
132. For compensatory, and Special Damages according to proof but amounting to at least  14
$10,000,000.00;
15 3. For prejudgment interest on all amounts found to be due to Plaintiff from Defendants,
16 at the legal rate.
17 4. For punitive damages and exemplary damages according to proof at the time of trail,
18 5. For attorney’s fees according to statute according to proof, and
19 6. For such other and further relief in favor of Plaintiff as the Court deems
20just and proper.  21
22 DATED: November 16, 2022 
 23
A.G. ASSANTI & ASSOCIATES, PC
24
25
26 Alessandro G. Assanti, Esq.,  
Attorney for Plaintiff Yuri Vanetik
27
28 14
COMPLAINT FOR DAMAGES