Defenders Northwest Brian Hall Complaint FILED 09162022

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Electronically Filed by Superior Court of
California, County of Orange, 09/16/2022 092333
AM. 30-2022-01281344-CU-BC-CJC - ROA 2 - DAVID
H. YAMASAKI, Clerk of the Court By A. Gill,
Deputy Clerk.
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Alessandro G. Assanti, Esq. (SBN 181368) A.G.
ASSANTI ASSOCIATE, P.C. 9841 Irvine Center Dr.,
Suite 100 Irvine, CA. 92618 v 949-540-0439 f
949-540-0458 email aassanti_at_assantilaw.com
email litigation_at_assantilaw.com
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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
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Assigned for All Purposes
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BELMONT ASSET SOLUTIONS, LLC., a Wyoming Limited
Liability Company, and CHAD ULLERY, an
individual, Plaintiffs,
Case No.
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______________________________
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COMPLAINT FOR
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1. BREACH OF WRITTEN
CONTRACT
vs.
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NEGLIGENCE
2. 3. 4. 5. 6.
FRAUD CONVERSION FRAUDULENT TRANSFER
CONSTRUCTIVE FRAUDULENT
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BRIAN T. HALL, an individual DEFENDERS
NORTHWEST, LLC, a Washington Limited Liability
Company MICHELE A. HALL aka MICHELE HALL,
an individual AUTOHOME USA, INC., a Nevada
Corporation and DOES 1 through 25
inclusive, Defendants.
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TRANSFER
7. 8.
QUIET TITLE INTENTIONAL INFLICTION OF
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EMOTIONAL DISTRESS
9. NEGLIGENT INFLICTION OF
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EMOTIONAL DISTRESS

1. ACCOUNTING AND
2. CONSTRUCTIVE TRUST.

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COMPLAINT FOR DAMAGES
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GENERAL ALLEGATIONS
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• Plaintiff, CHAD ULLERY, (hereinafter referred to
  as Plaintiff or ULLERY) is an
• individual residing in the county of Orange,
  State of California.
• Plaintiff, BELMONT ASSET SOLUTIONS, LLC.,
  (hereinafter referred to as Plaintiff
• or BELMONT) is a Wyoming limited liability
  company in good standing and qualified to conduct
  business in the State of California, with its
  principal offices located in, County of

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Orange, State of California.
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1. At all times, ULLERY and BELMONT are collectively
   referred to as Plaintiffs.
2. At the time of the subject incident (hereinafter
   described below), which gave rise to this

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complaint, any and all the acts committed upon
Plaintiffs occurred within the city of Irvine,
County of Orange, California. 5. The Defendant,
BRIAN T. HALL aka BRIAN HALL, (hereinafter
referred to as Defendant Brian Hall) is an
individual residing in the city of Gig Harbor, in
the State of Washington at 14716 48th Avenue NW,
Gig Harbor, WA 98332, and has been previously a
resident of Laguna Niguel, County of Orange,
California. Defendant Brian Hall jointly with
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other Defendants committed the acts against
Plaintiffs as herein complained of. 6.
Plaintiffs based on information and belief herein
allege that the Defendant MICHELE HALL aka
MICHELE ANN HALL aka Michele A. Hall,
(hereinafter referred to as Defendant Michele
Hall) is an individual and a resident of the
State of Washington, and is believed to reside at
3723 42nd Street Court, Unit B, Gig Harbor, WA
98335. Plaintiffs reserve the right to amend this
complaint when Plaintiffs further ascertain the
city, state and county of Defendant
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Michele Halls actual residence.
7. Defendant, Defenders Northwest, LLC
(hereinafter Defenders Northwest) is believed
to be a validly formed Washington Limited
Liability Company and is alleged to have
committed each and all of the acts as herein
complained at all times within the County of
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COMPLAINT FOR DAMAGES
002
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Orange, State of California. Defenders Northwest
was organized by Shawn K. Harju, an attorney
licensed to practice law in the State of
Washington Shawn K. Harju has claimed to be
partners with Defendants and purports to
operate a yoga studio called Three Trees Yoga,
LLC and a consulting business called Chrysalis
Solutions PLLC. Plaintiffs further allege on
information and belief that Harju is a principal
at Defenders Northwest. Plaintiff reserves the
right to amend this complaint to name Harju as a
defendant in the event that it is found that she
acted on behalf of Defenders Northwest to defraud
the Plaintiffs in the manner as herein
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• alleged.
• Defendant, Autohome USA, Inc. (hereinafter
  Autohome) is alleged to be a Nevada Corporation
  doing business from the same physical location in
  Gig Harbor, Washington as the other Defendants,
  and is alleged to have committed each and all of
  the acts as herein complained within the State of
  California, County of Orange.
• The true names and capacities, whether
  individual, corporate, associate, or otherwise,
• of the Defendants sued herein as DOES 1 to 25
  hereinafter also referred to as the Fictitiously
  Named Defendants, are currently unknown to
  Plaintiffs who, therefore, sue said Defendants by
  such fictitious names. Plaintiffs are informed
  and believe, and based upon such information and
  belief allege, that each of the Fictitiously
  Named Defendants are responsible to Plaintiffs in
  some manner for the acts, omissions, or other
  conduct as hereinafter alleged, or each such
  defendant is a necessary party for the relief
  sought herein and is subject to the jurisdiction
  of this Court and further the Fictitiously Named
  Defendants are being sued in both their
  individual and official capacity. Plaintiffs will
  seek leave of Court to amend this Complaint to
  allege each of their true names and capacities
  when same have been ascertained.
• Each reference to Defendant or Defendants,
  herein is intended to be a reference to
• all Defendants named herein, unless otherwise
  expressly indicated or the context otherwise
  requires.

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COMPLAINT FOR DAMAGES
003
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• Plaintiffs are informed and believe, and based
  upon such information and belief allege,
• that at all times herein relevant, each of the
  Defendant was and is the principal, agent,
• representative, supervisor, employee, servant,
  alter ego, partner, shareholder, director,
  officer, joint venturer, parent corporation,
  subsidiary corporation, co-conspirator, licensor,
  licensee, inviter, invitee, predecessor-in-inte
  rest, successor-in-interest, assignor and/or
  assignee (hereinafter referred to as an
  Interrelationship), as may be applicable, of
  each the other Defendants, and, in doing the
  things hereinafter alleged, was (a) acting in
  concert with all of the other Defendants (b)
  under the direction, instruction, demand,
  requirement, and/or control of some or all of the
  other Defendants (c) in furtherance of a common
  plan, scheme, enterprise and/or control of some
  or all of the other Defendants (d) in
  furtherance of a common plan, scheme, enterprise
  and/or conspiracy with some or all of the
  Defendants and/or (e) with the knowledge,
  consent, acquiescence, and/or prior or subsequent
  ratification of some or all of the other
  Defendants.
• Plaintiffs further allege that each of said
  Defendants proximately caused the injuries and
  damages by reason of negligent, careless,
  deliberately indifferent, intentional, willful or
  wanton misconduct, including the negligent,
  careless, deliberately indifferent, intentional,
  willful or wanton misconduct in creating and
  otherwise causing the incidents, conditions and
  circumstances hereinafter set forth, or by reason
  of the direct or imputed negligence or vicarious
  fault or breach of duty arising out of the
  matters herein alleged.
• Plaintiffs herein allege on information and
  belief that Defendants entered into a written
  agreement with Plaintiffs and Plaintiffs
  representatives to restore a 1984 Land Rover
  Defender vehicle occasionally referred to by its
  model reference as Defender 130 (hereinafter
  the Vehicle), which, upon execution of said
  agreement, was promptly delivered to Defendants
  restoration shop in Gig Harbor, Washington, in
  February 2015. A true and correct copy of the
  subject Agreement is attached hereto and
  incorporated by reference as Exhibit 1. As part
  of the Agreement, the parties have agreed that in
  the event

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COMPLAINT FOR DAMAGES
004
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• that a dispute arises out of the Agreement, that
  the dispute shall be resolved in the State of
• California, County of Orange.
• Defendants claim through their website
  (www.defendersnorthwest.com) and through various
  social media and chat room posts (i.e. Instagram,
  LinkedIn, etc.) that they operate a Land Rover
  parts sales and restoration business, and source
  and broker mostly vintage Land Rover parts and
  accessories in U.S. and worldwide. Specifically,
  Defendants allege that Defenders Northwest is a
  restoration parts supplier for the ever-growing
  community of Defender owners and enthusiasts in
  the USA. They further claim that in Gig Harbor,
  Washington they import and stock a full
  selection of parts, supplies, and tools to
  support the restoration, enhancement, and
  maintenance of the Defender platform. From
  simple service parts like oil-filters, to full
  restoration foundation items like replacement
  chassis, Defendants claim that they stock only
  parts for the Defender 90, 110, and 130, and
  accessories such as roof racks and safari-type
  tools, including safari sleeping tents/systems
  under the brand Autohome USA. Defendants claim
  that they perform limited repair and fabrication
  projects in-house as production schedules permit,
  specializing in 300Tdi powered Defender 110
  frame-off restorations for expedition,
  recreation, or daily-use. The Plaintiffs allege
  that recently the majority of the Defendants
  business is predicated on illegal modifications
  to bypass import restrictions and filing of
  fraudulent insurance claims and police reports.
  Plaintiffs fell victims relying on Defendants
  pitch to restore the Vehicle in a few months and
  the curated social media campaign designed to
  lure in new clients that Defendants aim to
  defraud.
• Plaintiffs further allege on information and
  belief that Defendants never intended to complete
  the restoration project of the Vehicle. Rather,
  Defendants and each of them acting in
  coordination and unison intended to defraud
  Plaintiffs. To that end, Defendants from
  approximately February 2015 through 2018
  electronically (via email) sent Plaintiffs
  fraudulent invoices for auto parts to be
  installed and for labor and miscellaneous expenses

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COMPLAINT FOR DAMAGES
005
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• (i.e., import duties, shipping, freight, etc.).
  Unfortunately, Defendants never acquired the
• invoiced parts and did not perform any material
  work on the Vehicle as they represented to
• the Plaintiffs. Moreover, Defendants striped and
  sold the existing parts and then decided to hold
  the vehicle hostage unless additional
  unsubstantiated payments would be made.
• Defendant Brian Hall began to come up with
  numerous made-up arguments and outrageous lies to
  explain delays in completion to perpetuate the
  fraudulent scheme. These fake excuses included
  two staged incidents of burglary and vandalism.
  In both instances Defendants filed false police
  reports and fraudulent insurance claims to
  defraud their insurance company and create
  additional delays pushing back the inevitable
  truth that they shamelessly defrauded Plaintiffs.
  Additionally, Defendants alleged that COVID-19
  and scarcity of parts created prolonged delays.
  Finally, Defendants fabricated mystery
  mechanical bugs that were challenging to diagnose
  and fix in order to create further delays. In
  all, the restoration project which was started
  in or about February 2015 and was supposed to be
  completed in a few months or earlier, has taken
  almost 8 years. And presently Defendants claim
  that the Vehicle is not roadworthy, as they
  stated in the general release, they demanded that
  Plaintiffs sign before Defendants release the
  Vehicle. A true and correct copy of the release
  is attached hereto and incorporated by reference
  as Exhibit 2.
• This demand was made suddenly and last minute
  just days before the Vehicle was to
• be released to Plaintiff on August 8, 2022, as
  was proposed by Defendants themselves and agreed
  to by Plaintiffs.
• It was recently discovered that Defendant Brian
  Hall filed for personal bankruptcy (Chapter 7) in
  February 19, 2016 (which was discharged August
  26, 2016) however, Defendant Brian Hall never
  notified Plaintiffs of his financial woes, and
  affirmed that he owed the restored Vehicle to
  Plaintiffs in numerous emails and communications,
  as per the terms of the Agreement.

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COMPLAINT FOR DAMAGES
006
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• In August 2022, Plaintiff unequivocally confirmed
  that there was no money owed on
• the Vehicle and during several years of
  communication with Plaintiffs and their
• representatives, Defendants never tendered any
  invoices for work, parts, storage, etc., and
  never questioned the title of the Vehicle or the
  authority of the Plaintiffs and their
  representatives to, inter alia, set up delivery,
  guide direction of restoration, and process
  payments. A true and correct copy of the
  emails/communication showing that the only topics
  discussed were delivery and mysterious mechanical
  issues is attached hereto and referenced
  hereinafter as Exhibit 3.
• Plaintiffs allege on information and belief that
  in total, Plaintiffs have paid in excess of
• 140,000.00 (One Hundred Forty Thousand
  Dollars) for the restoration (parts,
  miscellaneous expenses, and labor) of the
  Vehicle.
• Presently Defendants have refused to release the
  Vehicle to Plaintiffs after admitting
• that there is no money owed, and that the Vehicle
  is still not in drivable condition due to an
• alleged no-run issue one of numerous that
  would come up every time delivery was scheduled.
  Instead, after Plaintiffs challenged and
  questioned a last minute unreasonable condition
  for the release of the Vehicle that required
  Plaintiffs to sign a general release, which the
  Plaintiffs had not seen at the time the condition
  was imposed via an email from Defendant Michele
  Hall, Defendants refused to release the Vehicle
  and suddenly demanded ridiculous, illegal and
  baseless storage fees, and phantom interest,
  and additional bogus charges after admitting that
  no money was owed and committing to releasing the
  Vehicle on August 8, 2022. No invoices were ever
  tendered to Plaintiffs to reflect the made-up
  demand for payment made by Defendants who also
  fabricated another fake excuse for refusing to
  deliver the vehicle, claiming that they need
  proof that Plaintiffs have the title to the
  Vehicle. A true and correct (redacted) copy of
  the title is attached hereto and incorporated by
  reference as Exhibit 4.

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COMPLAINT FOR DAMAGES
007
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• Many years of written electronic communication
  between Defendants and Plaintiffs
• and Plaintiff representatives (emails and texts)
  dispositively show that title to the Vehicle
• was never in dispute and that there was no money
  owed on the project. Moreover, when Defendant
  Brian Hall feigned scheduling delivery dates in
  the past (which were nothing more than calculated
  ruse a delay tactics), neither title nor
  additional fees were ever requested. Suddenly, a
  day before the Defendants were to release the
  Vehicle to an auto transport company, did the
  Defendants come up with new reasons why they were
  not releasing the Vehicle. Defendants partner
  and part-time lawyer while copied on previous
  emails admitting that nothing was owed and there
  were no conditions to release the Vehicle on
  August 8, 2022, sent an email demanding storage
  payments, other payments and interest and
  threatened to sell the Vehicle a copy of Harjus
  threats is attached hereto and incorporated by
  reference as Exhibit 5. Defendant Brian Hall
  and Defendant Michele Hall had not only taken
  almost 8 years to work on the Vehicle, which they
  admit is not in roadworthy condition and has
  been in pieces taken apart as of the date that
  this complaint is filed, but the Defendants also
  breached the Agreement failing to complete the
  restoration project.
• By way of background, Plaintiffs made numerous
  timely payments to Defendants
• majority of the payments were made by credit
  cards and through PayPal. For example, on January
  6, 2015 and January 22, 2015, Plaintiff paid 3
  invoices for a total of 14,286.35. One was for
  Al Tokin, an alleged vendor used by Defendants.
  On January 29, 2015, Defendants requested
  additional payments for steamship line wants
  another 6,280.00 for additional demurrage (they
  have indicated that demurrage keeps adding up
  even though the container left the terminal for
  exam they say the exam site is an extension of
  the terminal) before they will deliver the
  container to you.
• The Vehicle was delivered to Defendants February
  2, 2015. On March 27, 2015, after Parties
  executed the Agreement, Defendant Brian Hall
  emailed Plaintiff representative,

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COMPLAINT FOR DAMAGES
008
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Aaron Cuha explaining that he wanted to sell some
of the older stock parts of the Vehicle to offset
some of the expenses of the restoration project
as follows
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Q. What would the cost be in total, it is still
vague? So, price FOB in WA and with everything
swapped. (We realize there can always be extras
etc. but need the final base figure)
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A. The estimate will vary depending on the cost
of the donor (configuration, condition, location)
and the scope of work to configure and assemble -
fortunately better condition donor parts mean
less labor costs
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For budgeting you should consider the following
rough numbers 30K to 45K for the donor DDP to
our shop (TDI - TDCI) 9K to 18K in labor 12K
to 22K in parts - 5K transmission conversion -
5K suspension/upgrades End product is an
original paint (no respray) mechanically
complete functioning vehicle configured as
externally appearing 2007 TDCI styled Defender
130 HiCap DC
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Q. What exactly do you think you can get for the
current parts and axels
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A. Roughly 30K, Both Axles are 1k together.
Front axle is likely worth more parted out as it
is sided (RHD), discs/calipers have rust, stubs
balls are pitted, without arms - 350/- Rear is
standard D90 - better condition and has late type
disc brakes, no rear pivot or arms - 650/-
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COMPLAINT FOR DAMAGES
009
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130 Body Parts - 13K-17K as it sits - possible
to pick some parts first (bulkhead/doors) and
replace with non-puma spec from donor and still
pull the same amount (have current customer with
15k offer) 110DC - body parts/motors without a
VIN the truck can be parted out for 6k-12K 1K
for chassis from donor 1K to 4K from donor
parts not needed/used (factory suspension,
wheels/tires, etc...)
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25. In an email between Plaintiffs and Defendant
dated September 30, 2015,
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Defendant Brian Hall discusses recommendations wit
h Plaintiffs and Plaintiffs
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representatives regarding optimal registration
for the Vehicle, clearly acknowledging that
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attorney Yuri Vanetik (and Defendant officer) and
Aaron Cuha represent Plaintiff in all
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respects related to the Vehicle. 26. Subsequently,
Plaintiffs represented by Yuri Vanetik who also
facilitated invoice payments and communication
with Defendant Brian Hall and Defendant Michele
Hall, made
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a series of timely payments, prepaying all
alleged labor and parts purchases, and
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miscellaneous expenses. Ultimately, Plaintiffs
learned and based on information and belief
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allege that Defendants never purchased the parts
for which invoices were tendered and never
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performed invoiced labor on the
Vehicle. 27. Instead, Defendants, acting in
coordination from the beginning orchestrated a
scheme to defraud Plaintiffs by diverting the
funds they received for the vehicle restoration
project to
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pay for their lifestyle and to poach and
ultimately steal the Vehicle, defraud their
insurance
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carrier by filing false claims, and defraud the
local law enforcement by filing false police
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COMPLAINT FOR DAMAGES
010
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reports. On April 24, 2015, Defendant Brian Hall
sent an email to Plaintiffs stating the
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following
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• 6653 Custom fabricated ZF conversion kit from
  Ashcroft for 300tdi into TDCI cabin including
  console/linkage, etc.
• 4410 300Tdi with performance ported head
  (minimum needed to push the auto transmission).
• 1500 Turbo, intake plenum, missing/replaced
  ancillaries from engine
• delivered.
• 1543 Front Rear Defender 130 Propshafts (130
  rear propshaft is an expensive item from LR).
• 1805 LT230 Transfer Box - rebuilt no core
  charge.
• Additional parts needed but ones we stock on a
  regular basis.
• 945 Adwest LHD 4-bolt Power steering box.
• 4k Suspension (shocks, springs, spring seats,
  bushing set, trailing arms, rear A-arm).
• 4k misc. large parts (exhaust system, fuel
  tank, hardware, steering arm linkage, engine
  rear wiring harness, etc.).
• Defendant Brian Hall claimed in the same email
  that they have a container ready to ship.

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28. Based on information and belief Plaintiffs
allege that this was another ruse to induce
payment. On September 2nd Defendants received a
2,000.00 deposit as part of the
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fraudulent labor retainer. Aaron Cuha, Yuri
Vanetik (representing the Plaintiffs) and all
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the Defendants except for Shawn Harju and her
consulting company were copied on most of
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the paid invoices. 29. In an email dated
September 1, 2015, Defendant Brian Hall wrote to
Mr. Vanetik and Mr. Cuha that he has laid the
keel, explaining that he has set the frame in
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COMPLAINT FOR DAMAGES
011
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place is preparing to put axles under it next
week. This email as well as most of the others
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sent by Defendants was a complete fabrication a
scam. 30. On August 7, 2015, Defendant Brian Hall
acknowledged additional payment for 5,000.00 and
6,453.00 and confirmed that Defendants received
payment for the
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engine. Subsequent emails confirmed that all
invoices had been paid as follows
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1. Engine - invoice 0000008688,
2. Transfer box - invoice 0000008689,
3. Front Axle - invoice 0000008718,
4. Suspension - Invoice 0000008719, Turbo
   manifold- invoice 0000008720,
5. IP ancillaries, invoice 0000008721,
6. Driveline - invoice 0000008722,
7. Electrical Harnesses - invoice 0000008722,
8. Chassis - 0000008449,
9. Transmission 0000008688,
10. Rear Axle housing- 0000000000,
11. Wheels/Tires , and
12. Dash cluster.

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31. In February 20, 2015, after executing the
Agreement, Plaintiffs were invoiced for
45,988.46, which represented estimated the total
cost of the restoration project of the Vehicle.
However, as of the date of this complaint,
Plaintiffs have paid Defendants in (estimated)
excess of 140,000.00. After numerous delays
based on outrageous lies that were meticulously
forged into fake excuses, the fraudsters refused
to release the Vehicle, attempting to extort more
money from Plaintiffs after admitting in
writing that there is no
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COMPLAINT FOR DAMAGES
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• money owed and agreeing to release the Vehicle to
  a vehicle transport currier on the
• morning of August 8, 2022 without any conditions,
  but admittedly in a non-operational state.
• Not only did the Defendants demand money on
  Sunday the day before
• Monday 8, 2022, the day that pick up of the
  Vehicle was scheduled, but they also demanded
  that Plaintiffs sign a general release. It was a
  last minute introduced condition to releasing the
  Vehicle, and it was never sent by Shawn Harju or
  Defendants for Plaintiffs and Plaintiffs counsel
  to even read before the scheduled release date.
  When Plaintiffs protested that it appeared
  unreasonable to demand a general release, Shawn
  Harju sent a threatening email, incredulously
  claiming, inter alia, that there was money owed
  for labor/parts and for storage, and that
  Defendants would not release the Vehicle until
  and unless Plaintiffs prove that they are the
  title holders because of made up confusion
  about ownership. In fact, empirical evidence
  shows that there was no money owed and there was
  no confusion or dispute about title. Only after
  refusing to release the Vehicle and making
  threats and demands predicated on truly absurd
  allegations (which Harju incredulously dismissed
  as her way of Advocating for the Defendants)
  only then did Miss Harju sent a proposed
  general release, which opaquely described the
  Vehicle as NOT road worthy and demanded a
  payment of 20,000.00 as ransom for its release.
  This was an effort to deliver a stripped chassis
  and some salvage parts that Defendants stripped
  but have not been able to sell. The madness of
  Defendants claims and demands clearly showed
  their desperation and exposed their scheme to
  defraud Plaintiffs. Sadly projecting their
  sociopathy, Defendants misinterpreted Plaintiffs
  kindness, patience and generosity for weakness
  and stupidity.
• In fact, Plaintiffs are informed and believe, and
  based upon such information and beliefs allege
  that Defendants never purchased or installed an
  engine in the Vehicle or any other parts. On July
  23, 2015, Defendants sent another set of
  fraudulent invoices and

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COMPLAINT FOR DAMAGES
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summarized them. These included payments for the
engine, transfer box, front axle, suspension,
turbo and manifold, IP and ancillaries,
driveline, electrical harnesses. Pending payments
were for wheels and tires and the dash and
cluster. In the same email, Defendant Brian Hall
acknowledged that most of the parts had already
been funded by the Plaintiffs and indicated
that he will be back in Orange County again
staying in Laguna Beach to suggest that
Plaintiffs representatives meet him for coffee.
Ultimately, Defendants have shamelessly schemed
to defraud Plaintiffs and have perpetrated their
fraudulent scheme for almost 8 years.
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FIRST CAUSE OF ACTION FOR BREACH OF WRITTEN
CONTRACT
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BREACH OF THE WRITTEN AGREEMENT DATED February 2,
2015, AS TO ALL DEFENDANTS, AND DOES 1 THROUGH
25, INCLUSIVE.
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34. Plaintiffs incorporate paragraphs 1 through
33 as though fully pled herein.
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35. On or about February 2, 2015, Plaintiffs, as
individuals and as a managing member and/or
agents of Belmont, entered into a written
agreement with Defendants on behalf of himself
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and as the managing member of Belmont (together
with Aaron Cuha, who acted as Plaintiffs
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representative). The contract between parties
titled as the Defender 130 Master Restoration
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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. 36. Exhibit 1 is the
Agreement to restore a 1984 Land Rover Defender
vehicle between Defenders Northwest, LLC
represented by its owners Brian Troy Hall and
Michele Ann Hall,
23
24
25
26
with Brian Hall singing the Agreement in his
personal capacity and as the defendants in this
27 28
COMPLAINT FOR DAMAGES
014
15
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. 37. The Agreement was executed in Orange
County, California and the parties agreed to in
the Agreement to resolve any and all disputes in
Orange County, California. Pursuant to the
3
4
5
Agreement, Defendants were to complete the
restoration project with 2-5 months based on
6
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.
• Defendants were to maintain insurance for the
  value of the vehicle as it was being worked on
  and stored and provide quarterly updates on the
  project.
• Plaintiffs are informed and believe, and based
  upon such information and belief allege, that
  Defendants failed to perform any material
  obligations in the Agreement, and never intended

9
10
11
12
13
14
to do so, but rather planned to defraud
Plaintiffs and strip and fence the
Vehicle. 40. Amongst other promises that were
made by Defendants, and each of them, were that
they would deliver the Vehicle completely
restored and in a timely manner in Orange County,
15
16
17
California as directed by Plaintiff and/or
Plaintiffs counsel or representative(s). 41. Furt
her, in the Agreement, Plaintiffs are informed
and believe, and based upon such information and
belief allege, that Defendant Brian Hall and
Defendant Michele Hall as further
18
19
20
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
Exhibit 1 or as further herein alleged in the
event of breach. Moreover, Plaintiffs are informed
24
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
16
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.
• Plaintiffs performed all promises, covenants, and
  representations of Exhibit 1.
• As of the date of this complaint, Defendants, and
  each of them, failed to perform on the promises
  as contained in Exhibit 1 and/or as herein
  alleged.
• As a result of the Defendants breach, Plaintiffs
  have been damaged in an amount that is in excess
  of the minimum jurisdictional limit to be proven
  at the time of trial.
• As result of Defendants breach of terms of the
  agreements and the amendments thereto as herein
  identified, Plaintiffs have suffered extensive
  and severe damages in an amount of at

5
6
7
8
9
10
11
12
13
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, AUTOHOME USA, , AND DOES 1
THROUGH 25, INCLUSIVE
21
22
46. Plaintiffs incorporate paragraphs 1 through
45 as though fully pled herein.
23
47. On or about February 20 of 2015 and
continuing until present time, Defendants, as
herein alleged, promised Plaintiffs and further
owed Plaintiffs a duty to conduct the restoration
of the
24
25
26 Vehicle in accordance with all California
laws, including but not limited to maintaining
proper 27 28 COMPLAINT FOR DAMAGES
016
17
1
bond and Washington State DMV licensing so as to
protect the Vehicle against burglars and
2
vandals. 48. At the time of entering into the
Agreement, on February 2, 2015, and each time
Agreement was or modified by additional invoice
and payment, Defendants, and each of them
3
4
5
knew that the Vehicle was parked in an unsafe
area when stored, and that they did not exercise
6
7
timeliness or diligence in restoring the Vehicle,
ignoring not only the Agreement, but also
8
accepted industry standards of service, and
diligence. 49. Defendants and each of them were
also aware that at the time of entering into said
Agreement that they were financially incapable of
performing the restoration they were
9
10
11
contracted to perform. In the same fashion they
did not disclose their personal bankruptcy in
12
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. 50. Defendants and each of them
had a duty to disclose these facts and that
Defendants could not possibly perform the
Agreement for restoration of the Vehicle because
they lacked resources
16
17
18
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. 51. Plaintiffs are informed and
believe, and based upon such information and
belief allege, that Defendants were able to sell
parts as brokers, but did not have the experience
and expertise
21
22
23
that they claimed they had to restore a vintage
Land Rover.
24
25 26 27 28
COMPLAINT FOR DAMAGES
017
18
1
52. As a result of this failure to disclose their
financial condition Defendants persuaded Plaintif
fs to enter into said Agreement, and wherein
Defendants made no effort or attempt to
2
3
restore the Vehicle. 53. Owners and operators of
a business which sells, restores motor vehicles
and motor vehicle parts had a duty to restore the
Vehicle in a timely matter consistent with the
Agreement
4
5
6
7
and industry standards, especially since
Defendants represented themselves as experts,
8
specializing in restoring and selling Land Rover
Defenders. 54. Defendants, and each of them,
negligently failed to timely restore the Vehicle,
secure proper insurance and licenses, fix
electrical or related problems, and protect the
vehicle from
9
10
11
neglect, vandalism, and multiple
burglaries. 55. As a result of Defendants
negligence, as herein described, and their
further failure to properly transfer said Vehicle
to Plaintiffs, Defendants when requests were
made, as alleged
12
13
14
15 herein, have caused and continue to cause
Plaintiffs injury and damage in the form of
exposure 16
to business losses and costs therein. 56. Defendan
ts and each of them breached this duty of care by
not, restoring the vehicle, failing to make it
roadworthy in almost 8 years, and refusing to
transfer said Vehicle, which
17
18
19
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. 57. As a result of
each and all of Defendants negligent, malicious
and purposeful acts, they so failed to properly
complete the restoration of the Vehicle and
comply with industry standards
22
23
24
25
of care.
26 27 28
COMPLAINT FOR DAMAGES
018
19
1
THIRD CAUSE OF ACTION FOR FRAUD
2
AGAINST DEFENDANTS BRIAN HALL, MICHELE HALL, AND
DEFENDERS NORTHWEST, AND DOES 1 THROUGH 25,
INCLUSIVE
3
4
58. Plaintiffs incorporate paragraphs 1 through
57 as though fully pled herein.
5
59. On or about February 20, 2015 Defendants
Brian Hall, Michele Hall, as principals
of Defenders Northwest, LLC and Defenders
Northwest LLC entered into the Agreement with
6
7
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
Defender) as herein alleged and specified in
Exhibit 1. More specifically, each and all
11
Defendants made affirmative representations that
they would timely and professionally restore
12
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
attorney and director of Belmont. Vanetik and
Cuha would get the invoice paid, assuming that
17
Defendants actually performed the tasks described
in the invoices. 60. From the middle of 2015
through present day, Defendants claimed that the
Vehicle was complete, but lacked miscellaneous
parts that were back ordered from England and
other
18
19
20
21
countries where Defendants claimed they were
sourcing the parts for the restoration project.
The
22
parts delays were predicated on COVID-19 delays
and shutdown and 2 claimed incidents of
23
burglary and vandalism. Then, Defendants claimed
that there were delays because of phantom
24
25
non-run issues that had plagued the Vehicle.
There were delays after delay and excuses
after excuses to the point that Defendants lost
any possible credibility. This deterioration of
26
27 28
COMPLAINT FOR DAMAGES
019
20
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
initially trusted and agreed to accommodate the
Defendants because of their online reputation,
6
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
last-minute breakdowns, peculiar schedule delays,
COVID-19 delays, repeated incidents of
12
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. 61. Then, as time progressed,
Defendants reasons for not committing to a
delivery date became progressively more bizarre.
Defendant Brian Hall would come up with new
problems
16
17
18
19
during the test drives of the Vehicle, even
though all the parts were supposed to be
legitimate Land Rover parts. Defendants, relying
on Plaintiffs good will and patience shamelessly
continued to play games, finally coming up with
two staged burglaries and vandalism incidents,
20
21
22
sending Plaintiffs copies of police reports and
pictures, and insurance claims. 62. Plaintiffs
are informed and believe, and based upon such
information and belief allege, that Defendants
filed false claims with their insurance carrier
and fabricating documents and
23
24
25
26
facts to create further delays, and just like
Ponzi Scheme operators, Defendants were
desperately
27 28
COMPLAINT FOR DAMAGES
020
21
1
buying time and placating Plaintiffs with
detailed but fake descriptions of their efforts
to work on
2
the Vehicle. 63. After Plaintiffs retained
counsel and demanded that the vehicle be released
regardless of the claimed no-run issues, it
became clear to the Plaintiffs who allege on
information and
3
4
5
belief that Defendants were stalling because they
had lied from the inception, and never had the
6
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. 64. Plaintiffs are informed and believe,
and based upon such information and belief
allege, that scammers Brian T. Hall and Michele
A. Hall tricked Aaron Cuha and Yuri Vanetik and
9
10
11
Plaintiffs into believing that they had
experience in restoring vintage Land Rovers and
that they
12
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. 65. More specifically,
throughout February 2015 to present day
Defendants and each of them represented that they
would restore the Vehicle according to
specifications in the Agreement and
17
18
19
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. 66. Plaintiffs
reasonably relied upon each, and all
representations made by Defendants and had no
reason to know that Brian Hall and Michele Hall
and Defenders Northwest had no
23
24
25
26 27 28
COMPLAINT FOR DAMAGES
021
22
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. 67. Each and all representations made by
Defendants were knowingly false and made without
any promise to perform upon the representations
as herein alleged and those made in writing and
those Exhibit 1 referenced herein. Defendants
could not complete the restoration project
because they lacked the resources and know-how
since they embezzled the invoiced funds paid
3
4
5
6
7
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
Hall, Defenders Northwest and potentially Shawn
Harju. 68. As a result of each and all of the
false representations made herein as alleged,
Plaintiffs have suffered special and general
damages in excess of the jurisdictional limit to
be proven at the
12
13
14
15
time of trial. 69. The conduct of each and all of
the -Defendants as alleged herein was oppressive,
malicious and intentional to justify imposition
of punitive damages pursuant to California Civil
16
17
18
19
Code 3294, which also was a substantial factor
in causing Plaintiffs harm. 70. Plaintiffs are
informed and believe, and based upon such
information and belief allege, that on or about
February 20, 2015, Defendants, and each of them,
made material representations
20
21
22
that they would honestly and competently conduct
the restoration of the Vehicle in a timely
23
manner and pursuant to industry standards, and in
a manner so as not to violate any laws or cause
24
25
financial hardship to or harm to Plaintiffs.
26 27 28
COMPLAINT FOR DAMAGES
022
23
1
71. At the time that each and all of the
representations were made, as herein
alleged, Defendants made such representations
knowing that they were false, without any
intention of
2
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. 72. At the time that each and all of the
representations were made, Plaintiffs had no
knowledge that said representations were false,
or that Defendants made such representations
5
6
7
8
without any intention to perform any of them and
therefore, Plaintiffs reliance was
justifiable. 73. As a result of Plaintiffs
justifiable reliance upon each and all
representations of Defendants, Plaintiffs have
suffered great injury and damages which include
but are not limited
9
10
11
to financial hardship, loss of income, special
damages in an amount unknown but exceeding
12
13
300,000.00, and extreme emotional
distress. 74. The conduct of each and all of the
-Defendants as alleged herein was oppressive,
malicious and intentional to justify imposition
of punitive damages pursuant to California Civil
14
15
16
Code 3294, which also was a substantial factor
in causing Plaintiffs harm. 75. As a result of
each and all of the representations made as
herein alleged, Plaintiffs suffered further and
excessive injury in that there were other
vehicles that had to be purchased by
17
18
19
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
Complaint upon further proof of damages at the
time of trial. 76. The conduct of each and all of
the -Defendants as alleged herein was oppressive,
malicious and intentional to justify imposition
of punitive damages pursuant to California Civil
24
25
26
27 28
COMPLAINT FOR DAMAGES
023
24
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
FOURTH CAUSE OF ACTION FOR CONVERSION
6
AGAINST BRIAN T. HALL, MICHELE A. HALL, DEFENDERS
NORTHWEST, LLC, AUTOHOME USA, AND DOES 1 THROUGH
25, INCLUSIVE
7
8
9
77. Plaintiffs incorporate paragraphs 1 through
76 as though fully pled herein.
10
78. From February of 2015 through present day,
Defendants and each of them intentionally took
and embezzled cash, and credit card payments and
the Vehicle in an amount estimated to be
11
12
13

• 300,000, to be proven at the time of trial.
• At this time Plaintiffs are informed and believe
  that Defendants took in, in excess of
• 140,000.00 and the Vehicle, and vehicle parts.
• It is also alleged that during the same time
  Defendants and each of them intentionally
  exercised dominion and control over personal
  property, vehicles parts, other unknown items to

14
15
16
17
18
19

• be proven at the time of trial which were owned
  by Plaintiffs.
• Plaintiffs did not consent or authorize
  Defendants taking of their property, which
  exceeds a monetary amount exceeding 300,000.00,
  and to be proven at the time of trial.
• Such unauthorized taking and exercised dominion
  and control over said property, theft of funds
  and embezzlement is a direct and proximate result
  of Plaintiffs substantial monetary

20
21
22
23
24
25
damage to be proven at the time of trial.
26 27 28
COMPLAINT FOR DAMAGES
024
25
1
83. The conduct of each and all of the Defendants
as alleged herein was oppressive, malicious and
intentional to justify imposition of punitive
damages pursuant to California Civil
2
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
others from engaging in such conduct.
6
7
8
FIFTH CAUSE OF ACTION FOR FRAUDULENT TRANSFER
9
AGAINST BRIAN T. HALL, MICHELE A. HALL, DEFENDERS
NORTHWEST, LLC, AUTOHOME USA, AND DOES 1 THROUGH
25, INCLUSIVE
10
11
84. Plaintiffs incorporate paragraphs 1 through
83 as though fully pled herein.
12
13
85. Plaintiff s are informed and believe and
based upon such information and belief
allege that on or about February of 2015 up
through April of 2021 the Defendants and each of
them
14
15
entered into a series of financial transactions
involving the Vehicle and its parts to secure
lines of
16

• credit and financial assistance from the U.S.
  government.
• At present the Plaintiffs are unaware of the true
  gravity of the theft and transfer and hereby
  reserve their right to seek leave to amend when
  additional information is obtained.
• Each and all Defendants, as alleged herein,
  transferred certain vehicle parts into their own
  names or entities operated by Defendants in such
  a manner with the specific intent to hinder,

17
18
19
20
21
22
delay or defraud Plaintiffs. 88. It is further
alleged that each and all Defendants named
herein, operated, and conducted themselves
illegally, in that they did not have proper
authorization from the state of Washington
23
24
25
26 or California to involve themselves in motor
vehicle transactions as Plaintiffs are the true
owners 27 28 COMPLAINT FOR DAMAGES
025
26
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. 89. As a
direct result of the intentional, malicious and
oppressive acts as herein alleged, Plaintiffs
have been damaged in an amount that is in excess
of the minimum jurisdictional limit
4
5
6
7
of this Court to be proven at the time of
trial. 90. The conduct as alleged herein by each
and all of the -Defendants was a substantial
factor in causing Plaintiffs harm, which was
oppressive malicious and intentional so as to
justify an
8
9
10
award punitive damages against them pursuant to
California Civil Code 3294 in order to
11
punish the Defendants and to deter others from
engaging in such illegal activity.
12
13
14
SIXTH CAUSE OF ACTION FOR CONSTRUCTIVELY
FRAUDULENT TRANSFER
15
AGAINST BRIAN T. HALL, MICHELE A. HALL, DEFENDERS
NORTHWEST, LLC, AUTOHOME USA, AND DOES 1 THROUGH
25, INCLUSIVE
16
17
91. Plaintiffs incorporate paragraphs 1 through
90 as though fully pled herein.
18
19

• That at all times, each and all of the alleged
  Defendants have now become creditors to
• these complaining parties by the results of their
  own actions as alleged herein.
• That on or about February of 2015 through April
  of 2021, Defendants and each of them, as alleged
  herein, engaged in or were about to engage in
  vehicle transactions and vehicle parts

20
21
22
23
transactions, for vehicles known to have been
personally guaranteed by Plaintiffs, said vehicles
24
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
27
1
94. Defendants and each of them specifically
intended to incur, believed or reasonably believe
d a transfer for value that was unconscionable,
unfair and unreasonably small in relation
2
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
financial gain. 95. Plaintiffs have a right to
repayment, attachment, return or injunctive
relief from said Defendants in an amount that
substantially exceeds the minimum jurisdiction of
this Court to be
6
7
8
9 proven at the time of trial. 10 11
SEVENTH CAUSE OF ACTION FOR QUIET TITLE
12
AGAINST BRIAN T. HALL, MICHELE A. HALL, DEFENDERS
NORTHWEST, LLC, AUTOHOME USA, AND DOES 1 THROUGH
25, INCLUSIVE
13
14
15
96. Plaintiffs incorporate paragraphs 1 through
95 as though fully pled herein.
16
97. Plaintiffs are informed and believe that
Defendants and each of them have
gained possession to certain Vehicle and
property for which Plaintiffs are the rightful
and lawful owners
17
18
19
as shown in Exhibit 4.
20 21

• At present the Plaintiffs are unaware of the true
  gravity of the theft and transfer and
• hereby reserve their right to seek leave to amend
  when additional information is obtained.
• Plaintiffs herein allege that the rights and
  interest have been violated and they have been
  damaged by such wrongful possession by Defendants.

22
23
24
25
26 27 28
COMPLAINT FOR DAMAGES
027
28
1
100. At this time, Plaintiffs are aware of the
dispute as to the ownership rights and interest
in said parts and property and request that an
order be granted quieting title to the Vehicle and
2
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. 101. At this time, Plaintiffs are
informed and believe that the subject vehicles
are in the possession of these named Defendants
and further reserves the right to seek attachment
5
6
7
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
EIGHTH CAUSE OF ACTION FOR INTENTIONAL INFLICTION
OF EMOTIONAL
12
13
DISTRESS
14
AGAINST BRIAN T. HALL, MICHELE A. HALL, DEFENDERS
NORTHWEST, LLC, AUTOHOME USA, AND DOES 1 THROUGH
25, INCLUSIVE
15
16
102. Plaintiffs incorporate paragraphs 1 through
101 as though fully pled herein.
17
103. From a period beginning on or about February
of 2015 up until present day, Defendants, and
each of them, were aware that Plaintiffs had
invested a great deal of time and effort in
18
19
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
other injuries incurred during his mixed martial
arts career and work as a bodyguard. 104. At all
times, Defendants and each of them so knowingly
and intentionally and maliciously and
oppressively engaged in outrageous conduct, which
was an abuse of their
23
24
25
26 relationship with Plaintiffs, and abuse of
their position, which gave them power to
damage 27 28 COMPLAINT FOR DAMAGES
028