Defenders-Northwest-Litigation-Information_Complaint_FILED_
                     Electronically Filed by Superior Court of California, County of Orange, 09/16/2022 09:23:33 AM.
30-2022-01281344-CU-BC-CJC - ROA # 2 - DAVID H. YAMASAKI, Clerk of the Court By A. Gill, Deputy Clerk.
1 Alessandro G. Assanti, Esq. (SBN 181368)
A.G. ASSANTI & ASSOCIATE, P.C. 
2  9841 Irvine Center Dr., Suite 100  
3 Irvine, CA. 92618
v: 949-540-0439;  f: 949-540-0458
4 email: [email protected]  
email: [email protected]
5
6
Attorneys for Plaintiffs Chad Ullery and Belmont Business Solutions, LLC
7
8
9
SUPERIOR COURT FOR THE STATE CALIFORNIA
10
IN AND FOR THE COUNTY OF ORANGE, CENTRAL JUSTICE CENTER
11
12 Assigned for All Purposes
13
BELMONT ASSET SOLUTIONS, LLC., a Case No.:  
14 Wyoming Limited Liability Company, and 
15  CHAD ULLERY, an individual,
Plaintiffs, COMPLAINT FOR:16 1. BREACH OF 
17 vs. CWORNITTREANCT;
2. NEGLIGENCE;
18 BRIAN T. HALL, an individual;  3. FRAUD;  
19 DEFENDERS NORTHWEST, LLC, a
4. CONVERSION;
Washington Limited Liability Company;  5. FRAUDULENT TRANSFER;  
20 MICHELE A. HALL aka MICHELE HALL, an 6. CONSTRUCTIVE FRAUDULENT
individual; AUTOHOME USA, INC., a Nevada TRANSFER;
21  Corporation; and DOES 1 through 25 7. QUIET TITLE;
22 inclusive,
8. INTENTIONAL INFLICTION OF
Defendants. EMOTIONAL DISTRESS;
23 9. NEGLIGENT INFLICTION 
EOMF OTIONAL DISTRESS;
24 10. ACCOUNTING; AND
11. CONSTRUCTIVE TRUST.
25
26
27
28
COMPLAINT FOR DAMAGES
001
1
GENERAL ALLEGATIONS
2
3 1. Plaintiff, CHAD ULLERY, (hereinafter referred to as “Plaintiff” or “ULLERY”) is an
4
individual residing in the county of Orange, State of California.
5 2.Plaintiff, BELMONT ASSET SOLUTIONS, LLC., (hereinafter referred to as “Plaintiff”
6
or “BELMONT”) is a Wyoming limited liability company in good standing and qualified to  
7
conduct business in the State of California, with its principal offices located in, County of
8
Orange, State of California.
9
3. At all times, ULLERY and BELMONT are collectively referred to as “Plaintiffs.”
10
4. At the time of the subject incident (hereinafter described below), which gave rise to this
11
complaint, any and all the acts committed upon Plaintiffs occurred within the city of Irvine,
12
County of Orange, California.
13 5. The  Defendant,   BRIAN T. HALL   aka BRIAN HALL,   (hereinafter referred to  as
14 “Defendant Brian Hall”) is an individual residing in the city of Gig Harbor, in the State of  
15 Washington at 14716 48th Avenue NW, Gig Harbor, WA 98332, and has been previously a  
16 resident of Laguna Niguel, County of Orange, California.   Defendant Brian Hall jointly with
17 other Defendants committed the acts against Plaintiffs as herein complained of.
18 6. Plaintiffs based on information and belief herein allege that the Defendant MICHELE  HALL 
19 aka MICHELE ANN HALL aka Michele A. Hall, (hereinafter referred to as “Defendant  Michele 
20 Hall”) is an individual and a resident of the State of Washington, and is believed to  reside at 
21 3723 42nd Street Court, Unit B, Gig Harbor, WA 98335. Plaintiffs reserve the right to  amend this 
22 complaint when Plaintiffs further ascertain the city, state and county of Defendant
23 Michele Hall’s actual residence.
24 7. Defendant, Defenders Northwest, LLC (hereinafter “Defenders Northwest”) is  
25 believed to be a validly formed Washington Limited Liability Company and is alleged to have  
26 committed each and all of the acts as herein complained at all times within the County of
27
28
COMPLAINT FOR DAMAGES
002
1
Orange, State of California. Defenders Northwest was organized by Shawn K. Harju, an  
2
attorney licensed to practice law in the State of Washington; Shawn K. Harju has claimed to be  
3
“partners” with Defendants and purports to operate a yoga studio called Three Trees Yoga,  
4
LLC and a consulting business called Chrysalis Solutions PLLC. Plaintiffs further allege on  
5
information and belief that Harju is a principal at Defenders Northwest. Plaintiff reserves the  
6
right to amend this complaint to name Harju as a defendant in the event that it is found that she  
7
acted on behalf of Defenders Northwest to defraud the Plaintiffs in the manner as herein
8
alleged.
9
8.Defendant, Autohome USA, Inc. (hereinafter “Autohome”) is alleged to be a Nevada  
10
Corporation doing business from the same physical location in Gig Harbor, Washington as  
11
the other Defendants, and is alleged to have committed each and all of the acts as herein  
12
complained within the State of California, County of Orange.
13
9. The true names and capacities, whether individual, corporate, associate, or otherwise,
14
of the Defendants sued herein as DOES 1 to 25 hereinafter also referred to as the  
15
“Fictitiously Named Defendants”, are currently unknown to Plaintiffs who, therefore, sue  
16
said Defendants by such fictitious names. Plaintiffs are informed and believe, and based  
17
upon such information and belief allege, that each of the Fictitiously Named Defendants are  
18
responsible to Plaintiffs in some manner for the acts, omissions, or other conduct as  
19
hereinafter alleged, or each such defendant is a necessary party for the relief sought herein  
20
and is subject to the jurisdiction of this Court; and further the Fictitiously Named  
21
Defendants are being sued in both their individual and official capacity. Plaintiffs will seek  
22
leave of Court to amend this Complaint to allege each of their true names and capacities  
23
when same have been ascertained.
24
10. Each reference to “Defendant” or “Defendants”, herein is intended to be a reference to
25
all Defendants named herein, unless otherwise expressly indicated or the context otherwise  
26
requires.
27
28
COMPLAINT FOR DAMAGES
003
1
11. Plaintiffs are informed and believe, and based upon such information and belief allege,
2
that at all times herein relevant, each of the Defendant was and is the principal, agent,
3
representative, supervisor, employee, servant, alter ego, partner, shareholder, director,  
4
officer, joint venturer, parent corporation, subsidiary corporation, co-conspirator, licensor,  
5
licensee, inviter, invitee, predecessor-in-interest, successor-in-interest, assignor and/or  
6
assignee (hereinafter referred to as an “Interrelationship”), as may be applicable, of each the  
7
other Defendants, and, in doing the things hereinafter alleged, was (a) acting in concert with  
8
all of the other Defendants; (b) under the direction, instruction, demand, requirement, and/or  
9
control of some or all of the other Defendants; (c) in furtherance of a common plan, scheme,  
10
enterprise and/or control of some or all of the other Defendants; (d) in furtherance of a  
11
common plan, scheme, enterprise and/or conspiracy with some or all of the Defendants;  
12
and/or (e) with the knowledge, consent, acquiescence, and/or prior or subsequent ratification  
13
of some or all of the other Defendants.
14
12.Plaintiffs further allege that each of said Defendants proximately caused the injuries  and 
15
damages by reason of negligent, careless, deliberately indifferent, intentional, willful or  
16
wanton misconduct, including the negligent, careless, deliberately indifferent, intentional,  
17
willful or wanton misconduct in creating and otherwise causing the incidents, conditions and 
18
 circumstances hereinafter set forth, or by reason of the direct or imputed negligence or  
19
vicarious fault or breach of duty arising out of the matters herein alleged.
20
13.Plaintiffs herein allege on information and belief that Defendants entered into a  written 
21
agreement with Plaintiffs and Plaintiffs’ representatives to restore a 1984 Land  Rover 
22
Defender vehicle occasionally referred to by its model reference as “Defender 130”  
23
(hereinafter the “Vehicle”), which, upon execution of said agreement, was promptly  
24
delivered to Defendants’ restoration shop in Gig Harbor, Washington, in February 2015. A  
25
true and correct copy of the subject Agreement is attached hereto and incorporated by  
26
reference as “Exhibit 1”. As part of the Agreement, the parties have agreed that in the event
27
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COMPLAINT FOR DAMAGES
004
1
that a dispute arises out of the Agreement, that the dispute shall be resolved in the State of
2
California, County of Orange.
3
14.Defendants claim through their website (www.defendersnorthwest.com) and through  
4
various social media and chat room posts (i.e. Instagram, LinkedIn, etc.) that they operate a  
5
Land Rover parts sales and restoration business, and source and broker mostly vintage Land  
6
Rover parts and accessories in U.S. and worldwide. Specifically, Defendants allege that  
7
Defenders Northwest is a restoration parts supplier “for the ever-growing community of  
8
Defender owners and enthusiasts in the USA.” They further claim that in Gig Harbor,  
9
Washington they “import and stock a full selection of parts, supplies, and tools to support  
10
the restoration, enhancement, and maintenance of the Defender platform. From simple  
11
service parts like oil-filters, to full restoration foundation items like replacement chassis…,”  
12
Defendants claim that they stock only parts for the Defender 90, 110, and 130,” and  
13
accessories such as roof racks and safari-type tools, including safari sleeping tents/systems  
14
under the brand Autohome USA. Defendants claim that they perform limited repair and  
15
fabrication projects in-house as production schedules permit, specializing in 300Tdi  
16
powered Defender 110 frame-off restorations for expedition, recreation, or daily-use. The  
17
Plaintiffs allege that recently the majority of the Defendants’ business is predicated on  
18
illegal modifications to bypass import restrictions and filing of fraudulent insurance claims  
19
and police reports. Plaintiffs fell victims relying on Defendants’ pitch to restore the Vehicle  
20
in a few months and the curated social media campaign designed to lure in new “clients”  
21
that Defendants aim to defraud.
22
15.Plaintiffs further allege on information and belief that Defendants never intended to  
23
complete the restoration project of the Vehicle. Rather, Defendants and each of them acting  
24
in coordination and unison intended to defraud Plaintiffs. To that end, Defendants from  
25
approximately February 2015 through 2018 electronically (via email) sent Plaintiffs  
26
fraudulent invoices for auto parts to be installed and for labor and miscellaneous expenses
27
28
COMPLAINT FOR DAMAGES
005
1
(i.e., import duties, shipping, freight, etc.). Unfortunately, Defendants never acquired the
2
invoiced parts and did not perform any material work on the Vehicle as they represented to
3
the Plaintiffs. Moreover, Defendants striped and sold the existing parts and then decided to  
4
hold the vehicle hostage unless additional unsubstantiated payments would be made.
5
16.Defendant Brian Hall began to come up with numerous made-up arguments and  
6
outrageous lies to explain delays in completion to perpetuate the fraudulent scheme. These  
7
fake excuses included two staged incidents of burglary and vandalism. In both instances  
8
Defendants filed false police reports and fraudulent insurance claims to defraud their  
9
insurance company and create additional delays – pushing back the inevitable truth that they  
10
shamelessly defrauded Plaintiffs. Additionally, Defendants alleged that COVID-19 and  
11
scarcity of parts created prolonged delays. Finally, Defendants fabricated mystery  
12
mechanical bugs that were challenging to diagnose and fix in order to create further delays.  
13
In all, the “restoration project” which was started in or about February 2015 and was  
14
supposed to be completed in a few months or earlier, has taken almost 8 years. And  
15
presently Defendants claim that the Vehicle “is not roadworthy”, as they stated in the  
16
general release, they demanded that Plaintiffs sign before Defendants release the Vehicle. A  
17
true and correct copy of the release is attached hereto and incorporated by reference as  
18
“Exhibit 2”.
19
17. This demand was made suddenly and “last minute” just days before the Vehicle was to
20
be released to Plaintiff on August 8, 2022, as was proposed by Defendants themselves and  
21
agreed to by Plaintiffs.
22
18.It was recently discovered that Defendant Brian Hall filed for personal bankruptcy  
23
(Chapter 7) in February 19, 2016 (which was discharged August 26, 2016); however,  
24
Defendant Brian Hall never notified Plaintiffs of his financial woes, and affirmed that he  
25
owed the restored Vehicle to Plaintiffs in numerous emails and communications, as per the  
26
terms of the Agreement.
27
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COMPLAINT FOR DAMAGES
006
1
19. In August 2022, Plaintiff unequivocally confirmed that there was no money owed on
2
the Vehicle and during several years of communication with Plaintiffs and their
3
representatives, Defendants never tendered any invoices for work, parts, storage, etc., and  
4
never questioned the title of the Vehicle or the authority of the Plaintiffs and their  
5
representatives to, inter alia, set up delivery, guide direction of restoration, and process  
6
payments. A true and correct copy of the emails/communication showing that the only  
7
topics discussed were delivery and mysterious mechanical issues is attached hereto and  
8
referenced hereinafter as “Exhibit 3”.
9
20. Plaintiffs allege on information and belief that in total, Plaintiffs have paid in excess of
10
$140,000.00 (One Hundred Forty Thousand Dollars) for the restoration (parts,  
11
miscellaneous expenses, and labor) of the Vehicle.
12
21. Presently Defendants have refused to release the Vehicle to Plaintiffs after admitting
13
that there is no money owed, and that the Vehicle is still not in drivable condition due to an
14
alleged “no-run” issue – one of numerous that would come up every time delivery was  
15
scheduled. Instead, after Plaintiffs challenged and questioned a last minute unreasonable  
16
condition for the release of the Vehicle that required Plaintiffs to sign a general release,  
17
which the Plaintiffs had not seen at the time the condition was imposed via an email from  
18
Defendant Michele Hall, Defendants refused to release the Vehicle and suddenly demanded  
19
ridiculous, illegal and baseless “storage fees”, and phantom interest, and additional bogus  
20
charges after admitting that no money was owed and committing to releasing the Vehicle on  
21
August 8, 2022. No invoices were ever tendered to Plaintiffs to reflect the made-up demand  
22
for payment made by Defendants who also fabricated another fake excuse for refusing to  
23
deliver the vehicle, claiming that they need proof that Plaintiffs have the title to the Vehicle.  
24
A true and correct (redacted) copy of the title is attached hereto and incorporated by  
25
reference as “Exhibit 4”.
26
27
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COMPLAINT FOR DAMAGES
007
1
22. Many years of written electronic communication between Defendants and Plaintiffs
2
and Plaintiff representatives (emails and texts) dispositively show that title to the Vehicle
3
was never in dispute and that there was no money owed on the project. Moreover, when  
4
Defendant Brian Hall feigned scheduling delivery dates in the past (which were nothing  
5
more than calculated ruse – a delay tactics), neither title nor additional fees were ever  
6
requested. Suddenly, a day before the Defendants were to release the Vehicle to an auto  
7
transport company, did the Defendants come up with new reasons why they were not  
8
releasing the Vehicle. Defendants’ partner and part-time lawyer while copied on previous  
9
emails admitting that nothing was owed and there were no conditions to release the Vehicle  
10
on August 8, 2022, sent an email demanding storage payments, other payments and interest  
11
and threatened to sell the Vehicle; a copy of Harju’s threats is attached hereto and  
12
incorporated by reference as “Exhibit 5”. Defendant Brian Hall and Defendant Michele  Hall 
13
had not only taken almost 8 years to work on the Vehicle, which they admit is not “in  
14
roadworthy condition” and has been in pieces taken apart as of the date that this complaint is 
15
 filed, but the Defendants also breached the Agreement failing to complete the restoration  
16
project.
17
23. By way of background, Plaintiffs made numerous timely payments to Defendants;
18
majority of the payments were made by credit cards and through PayPal. For example, on  
19
January 6, 2015 and January 22, 2015, Plaintiff paid 3 invoices for a total of $14,286.35.  
20
One was for Al Tokin, an alleged vendor used by Defendants. On January 29, 2015,  
21
Defendants requested additional payments for “steamship line wants another $6,280.00 for  
22
additional demurrage (they have indicated that demurrage keeps adding up even though the  
23
container left the terminal for exam they say the exam site is an extension of the terminal)  
24
before they will deliver the container to you.”
25
24.The Vehicle was delivered to Defendants February 2, 2015. On March 27, 2015, after  
26
Parties executed the Agreement, Defendant Brian Hall emailed Plaintiff representative,
27
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COMPLAINT FOR DAMAGES
008
1
Aaron Cuha explaining that he wanted to sell some of the older stock parts of the Vehicle to
2
offset some of the expenses of the restoration project as follows:
3
4 Q. What would the cost be [in] total, it is still vague? So, price FOB in WA  
5 and with everything swapped. (We realize there can always be extras etc.… 
6  but need the final base figure)
7
A. The estimate will vary depending on the cost of the donor (configuration, 
8
 condition, location) and the scope of work to configure and assemble -  
9
fortunately better condition donor parts mean less labor costs
10
11 For budgeting you should consider the following rough numbers…” $30K to
12 $45K for the donor DDP to our shop (TDI - TDCI)
13 $9K to $18K in labor
14 $12K to $22K in parts - $5K transmission conversion - $5K 
15  suspension/upgrades
End product is an original paint (no respray) mechanically 
16
complete
17 functioning vehicle configured as externally appearing 2007+ TDCI styled 
18  Defender 130 HiCap DC
19
Q. What exactly do you think you can get for the current parts and axels…
20
21 A. Roughly $30K, Both Axles are $1k together. Front axle is likely worth  
22 more parted out as it is sided (RHD), discs/calipers have rust, stubs & balls 
23  are pitted, without arms - ~$350+/-
24 Rear is standard D90 - better condition and has late type disc brakes, no rear 
25  pivot or arms - $650+/-
26
27
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COMPLAINT FOR DAMAGES
009
1 130 Body Parts - $13K-$17K as it sits - possible to pick some parts first  
2 (bulkhead/doors) and replace with non-puma spec from donor and still pull 
3  the same amount (have current customer with $15k offer)
4 110DC - body parts/motors; without a VIN the truck can be parted out for
$6k-$12K
5
$1K for chassis from donor
6
$1K to $4K from donor parts not needed/used (factory suspension, 
7
 wheels/tires, etc...)
8
9
25. In an email between Plaintiffs and Defendant dated September 30, 2015,
10
Defendant Brian Hall discusses recommendations with Plaintiffs and Plaintiff’s
11
12 representatives regarding optimal registration for the Vehicle, clearly acknowledging that
13 attorney Yuri Vanetik (and Defendant officer) and Aaron Cuha represent Plaintiff in all
14 respects related to the Vehicle.
15
26. Subsequently, Plaintiffs represented by Yuri Vanetik who also facilitated invoice  
16
payments and communication with Defendant Brian Hall and Defendant Michele Hall, made
17
18 a series of timely payments, prepaying all alleged labor and parts purchases, and
19 miscellaneous expenses. Ultimately, Plaintiffs learned and based on information and belief
20 allege that Defendants never purchased the parts for which invoices were tendered and never
21
performed invoiced labor on the Vehicle.
22
27. Instead, Defendants, acting in coordination from the beginning orchestrated a scheme  
23
24 to defraud Plaintiffs by diverting the funds they received for the vehicle restoration project to
25 pay for their lifestyle and to poach and ultimately steal the Vehicle, defraud their insurance
26 carrier by filing false claims, and defraud the local law enforcement by filing false police
27
28
COMPLAINT FOR DAMAGES
010
1 reports. On April 24, 2015, Defendant Brian Hall sent an email to Plaintiffs stating the
2 following:
3
a.$6653 Custom fabricated ZF conversion kit from Ashcroft for 300tdi  
4
into TDCI cabin including console/linkage, etc.
5
b.$4410 300Tdi with performance ported head (minimum needed to push  
6 the auto transmission).
7 c. $1500 Turbo, intake plenum, missing/replaced ancillaries from engine
8 delivered.
9 d.$1543 Front & Rear Defender 130 Propshafts (130 rear propshaft is an  
10 expensive item from LR).
e. $1805 LT230 Transfer Box - rebuilt no core charge.
11
f. Additional parts needed but ones we stock on a regular basis.
12
g. $945 Adwest LHD 4-bolt Power steering box.
13
h.~$4k Suspension (shocks, springs, spring seats, bushing set, trailing  
14 arms, rear A-arm).
15 i.~$4k misc. large parts (exhaust system, fuel tank, hardware, steering  
16 arm & linkage, engine & rear wiring harness, etc.).
17 j.Defendant Brian Hall claimed in the same email that they have a  
18 container ready to ship.
19
28. Based on information and belief Plaintiffs allege that this was another 
20 ruse to
21 induce payment.  On September 2nd Defendants received a $2,000.00 deposit as part of the
22 fraudulent “labor retainer.” Aaron Cuha, Yuri Vanetik (representing the Plaintiffs) and all
23 the Defendants except for Shawn Harju and her consulting company were copied on most of
24 the paid invoices.
25
29. In  an  email  dated  September  1,  2015,  Defendant  Brian  Hall  wrote 
26  to Mr.
27 Vanetik and Mr. Cuha that he has “laid the keel”, explaining that he has set the frame in
28
COMPLAINT FOR DAMAGES
011
1 place is preparing to put axles under it “next week”. This email as well as most of the others
2 sent by Defendants was a complete fabrication – a scam.
3
30. On August 7, 2015, Defendant Brian Hall acknowledged additional payment  
4
for $5,000.00 and $6,453.00 and confirmed that Defendants “received payment for the
5
6 engine”. Subsequent emails confirmed that all invoices had been paid as follows:
7 a. Engine - invoice # 0000008688,
8 b. Transfer box - invoice# 0000008689,
9 c. Front Axle - invoice# 0000008718,
10 d. Suspension - Invoice# 0000008719, Turbo + manifold- invoice# 
 0000008720,
11
e. IP + ancillaries, invoice# 0000008721,
12
f. Driveline - invoice# 0000008722,
13
g. Electrical Harnesses - invoice# 0000008722,
14 h. Chassis - 0000008449,
15 i. Transmission – 0000008688,
16 j. Rear Axle housing- 0000000000,
17 k. Wheels/Tires , and
18 l. Dash + cluster.
19
20
21 31.  In February 20, 2015, after executing the Agreement, Plaintiffs were invoiced
22 for $45,988.46, which represented estimated the total cost of the restoration project of the
23 Vehicle. However, as of the date of this complaint, Plaintiffs have paid Defendants in  
24 (estimated) excess of $140,000.00. After numerous delays based on outrageous lies that  
25 were meticulously forged into fake excuses, the fraudsters refused to release the Vehicle,  
26 attempting to extort more money from Plaintiffs – after admitting in writing that there is no
27
28
COMPLAINT FOR DAMAGES
012
1
money owed and agreeing to release the Vehicle to a vehicle transport currier on the
2
morning of August 8, 2022 without any conditions, but admittedly in a non-operational  
3
state.
4
32. Not  only  did  the  Defendants  demand  money  on  Sunday  the  day  before
5
Monday 8, 2022, the day that pick up of the Vehicle was scheduled, but they also  
6
demanded that Plaintiffs sign a general release. It was a last minute introduced condition  to 
7
releasing the Vehicle, and it was never sent by Shawn Harju or Defendants for Plaintiffs  
8
and Plaintiffs’ counsel to even read before the scheduled release date. When Plaintiffs  
9
protested that it appeared unreasonable to demand a general release, Shawn Harju sent a  
10
threatening email, incredulously claiming, inter alia, that there was money owed for  
11
labor/parts and for storage, and that Defendants would not release the Vehicle until and  
12
unless Plaintiffs prove that they are the title holders because of made up “confusion” about  
13
ownership. In fact, empirical evidence shows that there was no money owed and there was  
14
no confusion or dispute about title. Only after refusing to release the Vehicle and making  
15
threats and demands predicated on truly absurd allegations (which Harju incredulously  
16
dismissed as her way of “Advocating” for the Defendants) – only then – did Miss Harju  
17
sent a proposed general release, which opaquely described the Vehicle as “NOT road  
18
worthy” and demanded a payment of $20,000.00 as ransom for its release. This was an  
19
effort to deliver a stripped chassis and some salvage parts that Defendants stripped but  
20
have not been able to sell. The madness of Defendants’ claims and demands clearly  
21
showed their desperation and exposed their scheme to defraud Plaintiffs. Sadly projecting  
22
their sociopathy, Defendants misinterpreted Plaintiffs kindness, patience and generosity for  
23
weakness and stupidity.
24
33.In fact, Plaintiffs are informed and believe, and based upon such information  
25
and beliefs allege that Defendants never purchased or installed an engine in the Vehicle or  
26
any other parts. On July 23, 2015, Defendants sent another set of fraudulent invoices and
27
28
COMPLAINT FOR DAMAGES
013
1
summarized  them.  These  included  payments  for  the  engine,  transfer  box,  front   axle,
2
suspension, turbo and manifold, IP and ancillaries, driveline, electrical harnesses.  Pending
3
payments were for wheels and tires and the dash and cluster. In the same email, Defendant  
4
Brian Hall acknowledged that most of the parts had already been “funded” by the Plaintiffs  
5
and indicated that he will be back in Orange County again staying in Laguna Beach to  
6
suggest that Plaintiffs’ representatives meet him for coffee. Ultimately, Defendants have  
7
shamelessly schemed to defraud Plaintiffs and have perpetrated their fraudulent scheme for  
8
almost 8 years.
9
10
FIRST CAUSE OF ACTION FOR BREACH OF WRITTEN CONTRACT
11
BREACH OF THE WRITTEN AGREEMENT DATED February 2, 2015, AS TO ALL 
12  DEFENDANTS, AND DOES 1 THROUGH 25, INCLUSIVE.
13
14 34. Plaintiffs incorporate paragraphs 1 through 33 as though fully pled herein.
15
35. On or about February 2, 2015, Plaintiffs, as individuals and as a managing member
16
and/or agents of Belmont, entered into a written agreement with Defendants on behalf of himself
17
and as the managing member of Belmont (together with Aaron Cuha, who acted as Plaintiffs’
18
19 representative). The contract between parties titled as the Defender 130 Master Restoration
20 Agreement (hereinafter the “Agreement”) memorialized in writing the core terms of the
21
restoration project for the Vehicle. The subject agreement is incorporated fully herein and
22
referred to as Exhibit 1.
23
36. Exhibit 1 is the Agreement to restore a 1984 Land Rover Defender vehicle between  
24
25 Defenders Northwest, LLC represented by its owners Brian Troy Hall and Michele Ann Hall,
26 with Brian Hall singing the Agreement in his personal capacity and as the defendants in this
27
28
COMPLAINT FOR DAMAGES
014
1 action and managing members of Defenders Northwest, LLC and Autohouse USA an entity that
2 Plaintiffs believe is owned and operated by Defendants on one hand and Plaintiffs on the other.
3
37. The Agreement was executed in Orange County, California and the parties agreed to in  
4
the Agreement to resolve any and all disputes in Orange County, California. Pursuant to the
5
6 Agreement, Defendants were to complete the restoration project with 2-5 months based on
7 invoices and the Agreement; the invoices and estimate submitted with the Agreement estimated
8 the total cost of the project to be under $60,000.00.
9
38.Defendants were to maintain insurance for the value of the vehicle as it was being  worked on 
10
and stored and provide quarterly updates on the project.
11
12 39.Plaintiffs are informed and believe, and based upon such information and belief allege,  that 
13 Defendants failed to perform any material obligations in the Agreement, and never intended
14 to do so, but rather planned to defraud Plaintiffs and strip and fence the Vehicle.
15
40. Amongst other promises that were made by Defendants, and each of them, were that they  
16
would deliver the Vehicle completely restored and in a timely manner in Orange County,
17
18 California as directed by Plaintiff and/or Plaintiffs’ counsel or representative(s).
19 41. Further, in the Agreement, Plaintiffs are informed and believe, and based upon such  
20 information and belief allege, that Defendant Brian Hall and Defendant Michele Hall as further
21
consideration for each of the promises, assurances, and consideration, and because of the delays
22
in delivering the Vehicle personally guaranteed each and all of the obligations contained in
23
24 Exhibit 1 or as further herein alleged in the event of breach. Moreover, Plaintiffs are informed
25 and believe, and based upon such information and belief allege, that Defendants operated and
26 continue to operate Defenders Northwest, LLC as though it was their sole proprietorship, with
27
28
COMPLAINT FOR DAMAGES
015
1 complete disregard for corporate form, comingling their own funds with the funds of Defenders
2 Northwest, LLC and Autohome USA to where the corporate veil can be pierced, and Defendant
3
Brian Hall and Defendant Michele Hall are liable for the debts and malfeasance of Defenders
4
Northwest LLC.
5
6 42. Plaintiffs performed all promises, covenants, and representations of Exhibit 1.
7 43.As of the date of this complaint, Defendants, and each of them, failed to perform on the  
8
promises as contained in Exhibit 1 and/or as herein alleged.
9
44.As a result of the Defendants’ breach, Plaintiffs have been damaged in an amount that is  in 
10
excess of the minimum jurisdictional limit to be proven at the time of trial.
11
12 45.As result of Defendants’ breach of terms of the agreements and the amendments thereto  as 
13 herein identified, Plaintiffs have suffered extensive and severe damages in an amount of at
14 least $300,000.00 or more to be proven at the time of trial. Plaintiffs reserve the right to amend
15
this Complaint upon their complete discovery of damages caused by Defendants according to
16
proof.
17
18
19 SECOND CAUSE OF ACTION FOR NEGLIGENCE
20 AGAINST BRIAN T. HALL, MICHELE A. HALL, DEFENDERS NORTHWEST, LLC, 
21  AUTOHOME USA, , AND DOES 1 THROUGH 25, INCLUSIVE
22
23 46. Plaintiffs incorporate paragraphs 1 through 45 as though fully pled herein.
24 47. On or about February 20 of 2015 and continuing until present time, Defendants, as herein
25 alleged, promised Plaintiffs and further owed Plaintiffs a duty to conduct the restoration of the
26
Vehicle in accordance with all California laws, including but not limited to maintaining proper
27
28
COMPLAINT FOR DAMAGES
016
1 bond and Washington State DMV licensing so as to protect the Vehicle against burglars and
2 vandals.
3
48. At the time of entering into the Agreement, on February 2, 2015, and each time  
4
Agreement was or modified by additional invoice and payment, Defendants, and each of them
5
6 knew that the Vehicle was parked in an unsafe area when stored, and that they did not exercise
7 timeliness or diligence in restoring the Vehicle, ignoring not only the Agreement, but also
8 accepted industry standards of service, and diligence.
9
49. Defendants and each of them were also aware that at the time of entering into said  
10
Agreement that they were financially incapable of performing the restoration they were
11
12 contracted to perform. In the same fashion they did not disclose their personal bankruptcy in
13 2016 or the multiple infractions Defendant Brian Hall was sanctioned for, which according to the
14 Agreement gave the right to Plaintiffs to terminate any and all payments owed for the Vehicle, if
15
any were owed.
16
50. Defendants and each of them had a duty to disclose these facts and that Defendants could  
17
18 not possibly perform the Agreement for restoration of the Vehicle because they lacked resources
19 to operate; however, each and all of the Defendants failed to disclose this fact, despite it being
20 known to them that they could not operate their business.
21
51. Plaintiffs are informed and believe, and based upon such information and belief allege,  
22
that Defendants were able to sell parts as brokers, but did not have the experience and expertise
23
24 that they claimed they had to restore a vintage Land Rover.
25
26
27
28
COMPLAINT FOR DAMAGES
017
1 52. As a result of this failure to disclose their financial condition Defendants persuaded
2
Plaintiffs to enter into said Agreement, and wherein Defendants made no effort or attempt to
3
restore the Vehicle.
4
53. Owners and operators of a business which sells, restores motor vehicles and motor  
5
6 vehicle parts had a duty to restore the Vehicle in a timely matter consistent with the Agreement
7 and industry standards, especially since Defendants represented themselves as experts,
8 specializing in restoring and selling Land Rover Defenders.
9
54. Defendants, and each of them, negligently failed to timely restore the Vehicle, secure  
10
proper insurance and licenses, fix electrical or related problems, and protect the vehicle from
11
12 neglect, vandalism, and multiple burglaries.
13 55. As a result of Defendants’ negligence, as herein described, and their further failure to  
14 properly transfer said Vehicle to Plaintiffs, Defendants when requests were made, as alleged
15
herein, have caused and continue to cause Plaintiffs injury and damage in the form of exposure
16
to business losses and costs therein.
17
18 56. Defendants and each of them breached this duty of care by not, restoring the vehicle,  
19 failing to make it roadworthy in almost 8 years, and refusing to transfer said Vehicle, which
20 therein caused Plaintiffs damages in an amount that is in excess of the minimum jurisdictional
21
limit of this Court of at least $300,000.00 to be proven at the time of trial.
22
57. As a result of each and all of Defendants’ negligent, malicious and purposeful acts, they  
23
24 so failed to properly complete the restoration of the Vehicle and comply with industry standards
25 of care.
26
27
28
COMPLAINT FOR DAMAGES
018
1 THIRD CAUSE OF ACTION FOR FRAUD
2 AGAINST DEFENDANTS BRIAN HALL, MICHELE HALL, AND DEFENDERS NORTHWEST, 
3  AND DOES 1 THROUGH 25, INCLUSIVE
4
5 58. Plaintiffs incorporate paragraphs 1 through 57 as though fully pled herein.
6 59. On or about February 20, 2015 Defendants Brian Hall, Michele Hall, as principals of
7 Defenders Northwest, LLC and Defenders Northwest LLC entered into the Agreement with
8
Plaintiffs represented by Aaron Cuha and Yuri Vanetik, who were representing, advising and
9
assisting Plaintiffs in planning a restoration project for the Vehicle (a 1984 Land Rover
10
11 Defender) as herein alleged and specified in Exhibit 1. More specifically, each and all
12 Defendants made affirmative representations that they would timely and professionally restore
13 the Vehicle within a period of approximately 3-5 months or sooner. It was during this time
14
period that Plaintiffs believed that Defendants would purchase parts pursuant to the invoices for,
15
inter alia, parts and labor that they would send to Aaron Cuha and subsequently to Yuri Vanetik,
16
17 attorney and director of Belmont. Vanetik and Cuha would get the invoice paid, assuming that
18 Defendants actually performed the tasks described in the invoices.
19 60. From the middle of 2015 through present day, Defendants claimed that the Vehicle was  
20
complete, but lacked miscellaneous parts that were “back ordered” from England and other
21
countries where Defendants claimed they were sourcing the parts for the restoration project. The
22
23 parts delays were predicated on COVID-19 delays and shutdown and 2 claimed incidents of
24 burglary and vandalism. Then, Defendants claimed that there were delays because of phantom
25 non-run issues that had plagued the Vehicle. There were delays after delay and excuses after
26
excuses  to  the  point  that  Defendants  lost  any  possible  credibility. This  deterioration  of
27
28
COMPLAINT FOR DAMAGES
019
1 credibility culminated in a grotesque farce when on the eve of the day that the Vehicle was
2 scheduled to be picked up and delivered to Plaintiffs, Miss Harju sent off a bizarre demand letter
3
claiming that various random and fake payments had to be made and threatening to lien and sell
4
the Vehicle. Plaintiff represented by Mr. Vanetik, who is an attorney and Officer of Belmont,
5
6 initially trusted and agreed to accommodate the Defendants because of their online reputation,
7 which turned out to be carefully curated to enable the Defendants to perpetrate the fraud.
8 Defendant Brian Hall and Defendant Michele Hall operating through Defenders Northwest
9
indexed themselves in the Defender restoration community as Land Rover restoration experts.
10
Initially, the excuses they were coming up with appeared on their face plausible, but multiple
11
12 last-minute breakdowns, peculiar schedule delays, COVID-19 delays, repeated incidents of
13 burglary and vandalism and Defendants’ shameless efforts to commit to any delivery date
14 ultimately made it clear that the fraudsters were just buying time, and that the Vehicle was never
15
restored.
16
61. Then, as time progressed, Defendants’ reasons for not committing to a delivery date  
17
18 became progressively more bizarre. Defendant Brian Hall would come up with new problems
19 during the test drives of the Vehicle, even though all the parts were supposed to be legitimate
20 Land  Rover  parts. Defendants, relying on Plaintiff’s good will and patience shamelessly  
21
continued to play games, finally coming up with two staged burglaries and vandalism incidents,
22
sending Plaintiffs copies of police reports and pictures, and insurance claims.
23
24 62. Plaintiffs are informed and believe, and based upon such information and belief allege,  
25 that Defendants filed false claims with their insurance carrier and fabricating documents and
26 facts to create further delays, and just like Ponzi Scheme operators, Defendants were desperately
27
28
COMPLAINT FOR DAMAGES
020
1 buying time and placating Plaintiffs with detailed but fake descriptions of their efforts to work on
2 the Vehicle.
3
63. After Plaintiffs retained counsel and demanded that the vehicle be released regardless of  
4
the claimed “no-run” issues, it became clear to the Plaintiffs who allege on information and
5
6 belief that Defendants were stalling because they had lied from the inception, and never had the
7 resources or inclination to restore the Vehicle, but rather misappropriated the invoice payments
8 and just poached the Vehicle to line their own pockets.
9
64. Plaintiffs are informed and believe, and based upon such information and belief allege,  
10
that scammers Brian T. Hall and Michele A. Hall tricked Aaron Cuha and Yuri Vanetik and
11
12 Plaintiffs into believing that they had experience in restoring vintage Land Rovers and that they
13 would restore the Vehicle. In reality, Defendants acting in unison were nothing more than
14 shameless, small-time fraudsters who never intended to perform any work on the Vehicle and
15
never intended to return it in any condition to Plaintiffs, disgracing the Land Rover Defender
16
restoration industry and the community of Defender enthusiasts.
17
18 65. More specifically, throughout February 2015 to present day Defendants and each of them  
19 represented that they would restore the Vehicle according to specifications in the Agreement and
20 subsequent invoices but failed to do any of the work.  As further material misrepresentations,
21
each and all of the Defendants as named herein promised to personally complete the restoration
22
project in a timely manner.
23
24 66. Plaintiffs reasonably relied upon each, and all representations made by Defendants; and  
25 had no reason to know that Brian Hall and Michele Hall and Defenders Northwest had no
26
27
28
COMPLAINT FOR DAMAGES
021
1 intention to perform on the Agreement. At the time each and all representations were made by
2 Defendants, Plaintiffs believed them to be true.
3
67. Each and all representations made by Defendants were knowingly false and made without  
4
any promise to perform upon the representations as herein alleged and those made in writing and  
5
6 those Exhibit 1 referenced herein. Defendants could not complete the restoration project  because 
7 they lacked the resources and know-how since they embezzled the invoiced funds paid
8 to them by Plaintiffs. Defendants knew of this impossibility yet led Plaintiffs to believe they
9
could complete the restoration and that it had been completed, but for last minute no-run glitches
10
and burglaries and vandalism – all devious and shameless lies concocted by Brian Hall, Michele
11
12 Hall, Defenders Northwest and potentially Shawn Harju.
13 68. As a result of each and all of the false representations made herein as alleged, Plaintiffs  
14 have suffered special and general damages in excess of the jurisdictional limit to be proven at the
15
time of trial.
16
69. The conduct of each and all of the -Defendants as alleged herein was oppressive,  
17
18 malicious and intentional to justify imposition of punitive damages pursuant to California Civil
19 Code§ 3294, which also was a substantial factor in causing Plaintiffs’ harm.
20 70. Plaintiffs are informed and believe, and based upon such information and belief allege,  
21
that on or about February 20, 2015, Defendants, and each of them, made material representations
22
that they would honestly and competently conduct the restoration of the Vehicle in a timely
23
24 manner and pursuant to industry standards, and in a manner so as not to violate any laws or cause
25 financial hardship to or harm to Plaintiffs.
26
27
28
COMPLAINT FOR DAMAGES
022
1 71. At  the  time  that  each  and  all  of  the  representations  were  made,  as  herein  alleged,
2
Defendants made such representations knowing that they were false, without any intention of
3
performing on those promises and with specific intent to induce reliance of Plaintiffs to allow
4
each and all Defendants to tender invoices for labor and parts and import duties and related costs.
5
6 72. At the time that each and all of the representations were made, Plaintiffs had no  
7 knowledge that said representations were false, or that Defendants made such representations
8 without any intention to perform any of them; and therefore, Plaintiffs’ reliance was justifiable.
9
73. As a result of Plaintiffs’ justifiable reliance upon each and all representations of  
10
Defendants, Plaintiffs have suffered great injury and damages which include but are not limited
11
12 to financial hardship, loss of income, special damages in an amount unknown but exceeding
13 $300,000.00, and extreme emotional distress.
14 74. The conduct of each and all of the -Defendants as alleged herein was oppressive,  
15
malicious and intentional to justify imposition of punitive damages pursuant to California Civil
16
Code§ 3294, which also was a substantial factor in causing Plaintiffs’ harm.
17
18 75. As a result of each and all of the representations made as herein alleged, Plaintiffs  
19 suffered further and excessive injury in that there were other vehicles that had to be purchased by
20 Defendants for which damages were incurred that were the direct result of the intentional,
21
oppressive, malicious and fraudulent misrepresentations of each and all Defendants named
22
herein amount to in excess of $300,000.00, and Plaintiffs herein reserved the right to amend this
23
24 Complaint upon further proof of damages at the time of trial.
25 76. The conduct of each and all of the -Defendants as alleged herein was oppressive,  
26 malicious and intentional to justify imposition of punitive damages pursuant to California Civil
27
28
COMPLAINT FOR DAMAGES
023
1 Code§ 3294, which also was a substantial factor in causing Plaintiffs harm and therefore
2 Plaintiffs seek Punitive damages in an amount to be proven at the time of trial in order to punish
3
the Defendants and to deter others from engaging in such fraudulent conduct.
4
5
6 FOURTH CAUSE OF ACTION FOR CONVERSION
7 AGAINST BRIAN T. HALL, MICHELE A. HALL, DEFENDERS NORTHWEST, LLC, 
8  AUTOHOME USA, AND DOES 1 THROUGH 25, INCLUSIVE
9
77. Plaintiffs incorporate paragraphs 1 through 76 as though fully pled herein.
10
11 78. From February of 2015 through present day, Defendants and each of them intentionally
12 took and embezzled cash, and credit card payments and the Vehicle in an amount estimated to be
13 $300,000, to be proven at the time of trial.
14
79. At this time Plaintiffs are informed and believe that Defendants took in, in excess of
15
$140,000.00 and the Vehicle, and vehicle parts.
16
17 80.It is also alleged that during the same time Defendants and each of them intentionally  
18 exercised dominion and control over personal property, vehicles parts, other unknown items to
19 be proven at the time of trial; which were owned by Plaintiffs.
20
81.Plaintiffs did not consent or authorize Defendants’ taking of their property, which  exceeds a 
21
monetary amount exceeding $300,000.00, and to be proven at the time of trial.
22
23 82.Such unauthorized taking and exercised dominion and control over said property, theft of  
24 funds and embezzlement is a direct and proximate result of Plaintiffs’ substantial monetary
25 damage to be proven at the time of trial.
26
27
28
COMPLAINT FOR DAMAGES
024
1 83. The  conduct  of  each  and  all  of  the  Defendants  as  alleged  herein  was  oppressive,
2
malicious and intentional to justify imposition of punitive damages pursuant to California Civil
3
Code §3294 which also was a substantial factor in causing Plaintiffs harm and seek punitive
4
damages in an amount to be proven at the time of trial to punish the Defendants and to deter
5
6 others from engaging in such conduct.
7
8 FIFTH CAUSE OF ACTION FOR FRAUDULENT TRANSFER
9
AGAINST BRIAN T. HALL, MICHELE A. HALL, DEFENDERS NORTHWEST, LLC, 
10  AUTOHOME USA, AND DOES 1 THROUGH 25, INCLUSIVE
11
12 84. Plaintiffs incorporate paragraphs 1 through 83 as though fully pled herein.
13 85. Plaintiff s are informed and believe and based upon such information and belief allege
14
that on or about February of 2015 up through April of 2021 the Defendants and each of them
15
entered into a series of financial transactions involving the Vehicle and its parts to secure lines of
16
17 credit and financial assistance from the U.S. government.
18 86.At present the Plaintiffs are unaware of the true gravity of the theft and transfer and  hereby 
19 reserve their right to seek leave to amend when additional information is obtained.
20
87.Each and all Defendants, as alleged herein, transferred certain vehicle parts into their own  
21
names or entities operated by Defendants in such a manner with the specific intent to hinder,
22
23 delay or defraud Plaintiffs.
24 88. It is further alleged that each and all Defendants named herein, operated, and conducted  
25 themselves illegally, in that they did not have proper authorization from the state of Washington
26
or California to involve themselves in motor vehicle transactions as Plaintiffs are the true owners
27
28
COMPLAINT FOR DAMAGES
025
1 of said vehicle as shown in the redacted title in Exhibit 4 of this complaint. In all times during
2 the alleged transactions that were conducted by each and all of the Defendants there was a
3
specific intent to defraud Plaintiffs.
4
89. As a direct result of the intentional, malicious and oppressive acts as herein alleged,  
5
6 Plaintiffs have been damaged in an amount that is in excess of the minimum jurisdictional limit
7 of this Court to be proven at the time of trial.
8 90. The conduct as alleged herein by each and all of the -Defendants was a substantial factor  
9
in causing Plaintiffs harm, which was oppressive malicious and intentional so as to justify an
10
award punitive damages against them pursuant to California Civil Code § 3294 in order to
11
12 punish the Defendants and to deter others from engaging in such illegal activity.
13
14 SIXTH CAUSE OF ACTION FOR CONSTRUCTIVELY FRAUDULENT TRANSFER
15
AGAINST BRIAN T. HALL, MICHELE A. HALL, DEFENDERS NORTHWEST, LLC, 
16  AUTOHOME USA, AND DOES 1 THROUGH 25, INCLUSIVE
17
18 91. Plaintiffs incorporate paragraphs 1 through 90 as though fully pled herein.
19 92. That at all times, each and all of the alleged Defendants have now become creditors to
20
these complaining parties by the results of their own actions as alleged herein.
21
93.That on or about February of 2015 through April of 2021, Defendants and each of them,  as 
22
23 alleged herein, engaged in or were about to engage in vehicle transactions and vehicle parts
24 transactions, for vehicles known to have been personally guaranteed by Plaintiffs, said vehicles
25 and parts (the assets) were transferred for value, which was unreasonably small in relation to the
26
encumbrances and claimed rights of Plaintiffs as incorporated herein.
27
28
COMPLAINT FOR DAMAGES
026
1 94. Defendants  and  each  of  them  specifically  intended  to  incur,  believed  or  reasonably
2
believed a transfer for value that was unconscionable, unfair and unreasonably small in relation
3
to the property that Defendants were acquiring, was known to be converted property guaranteed
4
by Plaintiffs and wrongfully appropriated for each and all of the Defendants’ personal and
5
6 financial gain.
7 95. Plaintiffs have a right to repayment, attachment, return or injunctive relief from said  
8 Defendants in an amount that substantially exceeds the minimum jurisdiction of this Court to be
9
proven at the time of trial.
10
11
12 SEVENTH CAUSE OF ACTION FOR QUIET TITLE
13 AGAINST BRIAN T. HALL, MICHELE A. HALL, DEFENDERS NORTHWEST, LLC, 
14  AUTOHOME USA, AND DOES 1 THROUGH 25, INCLUSIVE
15
96. Plaintiffs incorporate paragraphs 1 through 95 as though fully pled herein.
16
17 97. Plaintiffs  are  informed  and  believe  that  Defendants  and  each  of  them  have  gained
18 possession to certain Vehicle and property for which Plaintiffs are the rightful and lawful owners
19 as shown in Exhibit 4.
20
21
98. At present the Plaintiffs are unaware of the true gravity of the theft and transfer and
22
23 hereby reserve their right to seek leave to amend when additional information is obtained.
24 99.Plaintiffs herein allege that the rights and interest have been violated and they have been  
25 damaged by such wrongful possession by Defendants.
26
27
28
COMPLAINT FOR DAMAGES
027
1 100. At this time, Plaintiffs are aware of the dispute as to the ownership rights and interest in
2
said parts and property and request that an order be granted quieting title to the Vehicle and
3
property to Plaintiffs and as against Defendants and any persons known to be claiming legal and
4
or equitable right, title, interest or otherwise state a lien or interest in said property and vehicles.
5
6 101. At this time, Plaintiffs are informed and believe that the subject vehicles are in the  
7 possession of these named Defendants and further reserves the right to seek attachment
8 possession and or orders of this Court preventing the sale disposition and or further injury of
9
Plaintiffs in amount to be proven at the time of any motion and or trial.
10
11
12 EIGHTH CAUSE OF ACTION FOR INTENTIONAL INFLICTION OF EMOTIONAL
13 DISTRESS
14 AGAINST BRIAN T. HALL, MICHELE A. HALL, DEFENDERS NORTHWEST, LLC, 
15  AUTOHOME USA, AND DOES 1 THROUGH 25, INCLUSIVE
16
17 102. Plaintiffs incorporate paragraphs 1 through 101 as though fully pled herein.
18 103. From a period beginning on or about February of 2015 up until present day, Defendants,
19 and each of them, were aware that Plaintiffs had invested a great deal of time and effort in
20
financing the Vehicle, and that the expense of paying for the Vehicle has caused Chad Ullery to
21
fall into a state of distress and depression. This has further exacerbated the effect of his head and
22
23 other injuries incurred during his mixed martial arts career and work as a bodyguard.
24 104. At all times, Defendants and each of them so knowingly and intentionally and  
25 maliciously and oppressively engaged in outrageous conduct, which was an abuse of their
26
relationship with Plaintiffs, and abuse of their position, which gave them power to damage
27
28
COMPLAINT FOR DAMAGES
028
1 Plaintiffs’ financial and personal health as they made representations that the Vehicle would be
2 road worthy and would be delivered on multiple occasions, only to fabricated ridiculous and fake
3
reasons why the Vehicle cannot delivered, mocking and tormenting Plaintiffs.
4
105. -Defendants further engaged in a pattern of conduct by alleging and representing that all  
5
6 the restoration parts were received and installed in a timely manner, knowing that the lies once
7 discovered would cause Plaintiffs great distress.
8 106. At all times, Defendants engaged in the acts as so herein complained of; that each and all  
9
of them knew, or with certainty or with reckless disregard of knowing that said conduct would
10
and or could cause Plaintiffs severe emotional distress.
11
12 107. More specifically, each and all of the Defendants continued on a scheme to embezzle  
13 money personal goods and the Vehicle and cause damage to Plaintiffs, knowing that the ongoing
14 fraudulent scheme would cause Plaintiff severe emotional distress.
15
108. Each and all of these representations were knowingly false at the time they were made  
16
and further Defendants knew or were substantially certain that said misrepresentations, would
17
18 result in financial harm to Complainant, or with reckless disregard knew that such
19 misrepresentations and subsequent acts, as herein alleged, were substantially certain to cause;
20 and did cause Plaintiffs severe emotional distress.
21
109. The true facts are that each and all of the Defendants, never intended to restore the  
22
Vehicle or acquire parts for the Vehicle; instead, Defendants engaged in fraudulent transactions
23
24 where Plaintiffs were personally liable, so as to cause extreme and ongoing emotional distress.
25
26
27
28
COMPLAINT FOR DAMAGES
029
1 110. As a further and continuing damage to Plaintiffs, each and all of the Defendants knew
2
that the acts that are complained of herein were outrageous and done with the specific intent to
3
cause or with reckless disregard of causing severe emotional distress to Plaintiffs.
4
111.As a further and ongoing harm Plaintiffs has suffered extensive and severe emotional  
5
6 distress as a direct result of each and all the actions complained of herein.
7 112.Each of the Plaintiffs’ injuries and damages are substantial and in an amount in excess of  the 
8 minimum jurisdiction of this Court and seek right to prove said damages at the time of trial.
9
113.The conduct of each and all of the Defendants as herein alleged was oppressive reckless  
10
intentional and or malicious and seek an imposition of an award of punitive damages against said
11
12 -Defendants pursuant to civil code §3294 to punish the Defendants and to deter others from
13 engaging in such harmful activity in the future.
14
15
NINTH CAUSE OF ACTION FOR NEGLIGENT INFLICTION OF EMOTIONAL
16
DISTRESS
17
18 AGAINST BRIAN T. HALL, MICHELE A. HALL, DEFENDERS NORTHWEST, LLC, 
 AUTOHOME USA, AND DOES 1 THROUGH 25, INCLUSIVE
19
20
114. Plaintiffs incorporate paragraphs 1 through 113 as though fully pled 
herein.
21 115. At all times, Defendants and each of them made representations and promises that they
22
23 would diligently and timely restore the Vehicle pursuant to the Agreement and the invoices.
24 116.At all times during the restoration project, which As Plaintiffs learned never took place,  
25 Defendants owed certain duties; Defendants had a specific relationship and duty toward
26
Plaintiffs, as herein alleged, and as further referenced throughout this complaint.
27
28
COMPLAINT FOR DAMAGES
030
1 117. The  true  facts  are  that  each  and  all  of  the  -Defendants  named  herein  negligently
2
discharged their duties by failing to honor the promises and obligations to Plaintiffs, which
3
resulted in Plaintiffs’ financial harm, as well as and exacerbated Chad Ullery’s health problems.
4
118. As a direct and proximate cause of the negligence as herein alleged Plaintiffs and each of  
5
6 them suffered severe and ongoing emotional distress, which is in excess of the minimum
7 jurisdiction of this Court to be proven at the time of trial.
8
9
10 TENTH CAUSE OF ACTION FOR ACCOUNTING
11 AGAINST BRIAN T. HALL, MICHELE A. HALL, DEFENDERS NORTHWEST, LLC, 
12  AUTOHOME USA, AND DOES 1 THROUGH 25, INCLUSIVE
13
14 119. Plaintiffs incorporate paragraphs 1 through 118 as though fully pled herein.
15 120. The Defendants and each of them have received monies from Plaintiffs.
16 121. The amount of money due from the Defendants, and each of them, are unknown and
17
cannot be ascertained without an investigation and accounting of the whereabouts, of such funds,
18
the receipts of said moneys and the disbursements if any made. Plaintiffs are informed and
19
20 believe that the amounts wrongfully taken and kept, including the interest therein, exceeds the
21 minimum jurisdictional limit of the Court.
22 122. Each and all -Defendants, as alleged herein, were fiduciaries of the Plaintiffs who held  
23
vehicle and funds and owed a duty of care to Plaintiffs, so as not to engage in illegal vehicle
24
transactions, take actions that could harm Plaintiffs’ financial interests that were tied to the
25
26
27
28
COMPLAINT FOR DAMAGES
031
1 Agreement, herein alleged and incorporated in Exhibit 1, and not take actions that could injure
2 Plaintiffs, which include failing to pay for parts and to pay contractors for labor.
3
123. Each and all of the transactions involved in by Defendants could not have taken place  
4
without any direct negative effect on the contracting parties’ ability to pay for their obligations
5
6 under Exhibit 1.
7 124. As a direct result of the negligent, illegal, oppressive,
8 fraudulent and false  representations, Plaintiffs were harmed and Defendants, and each of 
9
tehnermich, ewde.re unjustly
10
125. -Complaints are entitled to accounting of all business dealings, business transactions,  
11
12 books of operations and business operations of Defendants, and unknown Defendants hereinafter
13 named as DOES 1 through 25, Inclusive.
14 126. Each and all parties owed a fiduciary duty to Plaintiffs, as herein alleged, and have  
15
breached said fiduciary duties entitling them to an accounting of their operations, which so
16
damaged Plaintiffs as herein, alleged, in order to trace and recover money and property they have
17
18 wrongfully taken from this complaint in an amount unknown but at least $300,000.00 to be
19 proven at the time of trial.
20
21
22
///
23
24 ///
25 ///
26 ///
27
28
COMPLAINT FOR DAMAGES
032
1
2 ELEVENTH CAUSE OF ACTION FOR CONSTRUCTIVE TRUST
3
AGAINST BRIAN T. HALL, MICHELE A. HALL, DEFENDERS NORTHWEST, LLC, 
4  AUTOHOME USA, AND DOES 1 THROUGH 25, INCLUSIVE
5
6 127. Plaintiffs incorporate paragraphs 1 through 126 as though fully pled herein.
7 128. Defendants are in possession of one 1984 Land Rover Defender whose VIN numbers end
8
in xxx 9342. Please find the attached title Exhibit 4.
9
129.The Plaintiffs as shown in Exhibit 4 are the true owners of the subject property, and  
10
11 Defendants and each of them took possession to restore said Vehicle and are currently actively
12 engaging to sell and dispose of said vehicle.
13 130. Plaintiffs seek the Court’s to order and awarded a constructive trust over said vehicle in  
14
order to prevent its destruction and loss.
15
16
17 DEMAND FOR JURY TRIAL FOR DETERMINATION OF ALL CAUSES OF ACTION
18 Plaintiffs hereby demand trial by jury for determination as to all causes of action as herein
19 alleged.
20
21
WHEREFORE, Plaintiffs pray for judgment against -Defendants as follows:
22
23 1. For any and all economic damages according to proof;
24 2. For general damages in an amount to be determined according to proof at trial; 
25 3.  For costs of suit incurred herein;
26 4. For any and all prejudgment interest, post judgment interest according to 
27 proof;
28
COMPLAINT FOR DAMAGES
033
1
5. For attorneys’ fees and costs according to contract and in pursuit of the recovery of
2
property and damages pursuant to California Civil Code §3336;
3
6.For punitive damages against each and all -Defendants in an amount to be determined  
4
according to proof at trial, where applicable;
5
7. For an accounting;
6
8. For a constructive trust of the subject vehicle and its parts;
7
9. For attorneys' fees and costs pursuant to contract;
8
10. For any and all contractual and equitable relief allowed by law; and
9
11. For such other and further relief as the Court deems just and proper.
10
11
12
DATED: September 13, 2022, A.G. ASSANTI & ASSOCIATE, 
13 P.C.
14
15
By: 
16 Alessandro G. Assanti, Esq., Attorney for  
Plaintiffs, Chad Ullery and Belmont Asset 
17
 Solutions, LLC.
18
19
20
21
22
23
24
25
26
27
28
COMPLAINT FOR DAMAGES
034
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25 Exhibit 1
26
27
28
COMPLAINT FOR DAMAGES
035
036
037
038
039
040
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25 Exhibit 2
26
27
28
COMPLAINT FOR DAMAGES
041

043
044
045
046
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25 Exhibit 3
26
27
28
COMPLAINT FOR DAMAGES
047
048
049
050
051
052
053
054
055
056
057
058
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25 Exhibit 4
26
27
28
COMPLAINT FOR DAMAGES
059

1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25 Exhibit 5
26
27
28
COMPLAINT FOR DAMAGES
061
062
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28 COMPLAINT FOR DAMAGES
063