1 DISCLAIMER 2 THIS IS A ROUGH DRAFT TRANSCRIPT. IT HAS BEEN 3 TRANSLATED FROM STENO TO ENGLISH BY COMPUTER. THIS 4 TRANSCRIPT HAS BEEN NEITHER EDITED NOR PROOFREAD BY THE 5 COURT REPORTER. 6 PARRISH REPORTING 7 8 9 BY MS. ARMENTA: 10 Q. Could you please state your full legal name. 11 A. Michael Hilton. 12 Q. Do you have any other names, sir? 13 A. I used to before I changed legally. 14 Q. Did you change it legally? 15 A. Yes, ma'am. 16 Q. In what state? 17 A. California. I can fax you a copy of the 18 court -- 19 Q. Just tell me approximately what year did you 20 change it? 21 A. 1980. 22 Q. And was it in Los Angeles County? 23 A. No. Orange County. 24 Q. Orange County. Okay. We met yesterday. My 25 name is Chris Armenta. I'm an attorney. And I 1 1 represent Richard Earnhart who is here. The court 2 reporter is going to be writing down everything 3 everyone says so it's important that you don't speak 4 over me because she can only take one person speaking 5 at a time. It's also important that you give an 6 audible response, because while I might understand a 7 nod of the head or shake of the head, it won't come 8 across in the transcript. 9 A. Uh-huh. 10 Q. Is that a yes? 11 A. Yes. 12 Q. So the huh-uh and uh-huhs won't work? 13 A. Yes and nos. Okay. 14 Q. Do you know Richard Earnhart? 15 A. Yes, I do. 16 Q. How do you know him? 17 A. I met him through a girlfriend. 18 Q. And that was a family member of his? 19 A. Yes, niece. 20 Q. I'm here to conduct what's called a judgment 21 debtor's examination. What that means is because 22 there's a judgment against you for money, Mr. Earnhart 23 has the right to examine you about your assets and 24 income because he's trying to recover on his judgment. 25 The judgment was entered in May of 2000 for $339,950. 2 1 The legal rate of interest in California for judgments 2 is 10 percent per year. So this judgment is now valued 3 at about $700,000. Now, are you prepared to pay 4 Mr. Earnhart the money that you owe him? 5 A. No, because I don't have it. 6 Q. Let's talk about the money you do have 7 because he'll take anything at this point. What is 8 your profession? 9 A. I work for a security company. 10 Q. What's the name of the company you work for? 11 A. American Police Force. 12 Q. Who owns that company? 13 A. Actually the company is not -- shares not 14 setup yet. I was incorporated but the shares are not 15 setup yet. 16 Q. Who is supposed to own that company? 17 A. I don't know yet. The attorney has the 18 books. 19 Q. You incorporated the company? 20 A. Yes, I did. In March 2 this year. 21 Q. Did anyone else assist you in incorporating 22 that company? 23 A. No. 24 Q. You did it all by yourself? 25 A. No. I did it through my corporation. 3 1 Q. What corporation? 2 A. That's the name. The corporation. My 3 corporation. 4 Q. So this is your corporation, American 5 Private Police Force? 6 A. I established it. Yes. 7 Q. You established it. Are you the sole owner 8 of all the stock of American Private Police Force at 9 this time? 10 A. No. 11 Q. Who's the owner? 12 A. Nobody. We didn't distribute any shares. 13 Q. No shares have been distributed. 14 A. No. 15 Q. Have you made any promises to distribute any 16 of the shares? 17 A. Yes. 18 Q. To whom? 19 A. Well, that attorney knows because I have no 20 idea who the investors are. 21 Q. You don't know who the investors in American 22 Private Police Force are? 23 A. No, I really don't. 24 Q. What attorney are you referring to? 25 A. Mazir Mafi. 4 1 Q. Hasn't Mazir Mafi resigned as attorney for 2 you and American Private Police Force? 3 A. Three weeks, ago, yes. 4 Q. Where are the books and records for American 5 Private Police Force? 6 A. He has it. 7 Q. What did you bring with you today? 8 A. Just Articles of Incorporation. That's it. 9 Q. Let me take a look. 10 How do you spell Mr. Mazir's last name? 11 A. M-a-f-i. 12 Q. Mr. Hilton you've handed me -- 13 A. That's Mafi's records. 14 Q. Mr. Hilton, you've given me two pages which 15 we'll mark as Exhibit A to the transcript. It's a 16 faxed copy of Articles of Incorporation. 17 (PLFDF Exhibit EXNUM 18 was marked for identification by the Reporter.) 19 BY MS. ARMENTA: 20 Q. Are these the Articles of Incorporation of 21 American Private Police Force Org., Inc.? 22 A. Yes. 23 Q. Did you invent that name American Private 24 Police Force, Inc.? 25 A. Yes, I did. 5 1 Q. What's the purpose of the company? 2 A. To do investigation and security. 3 Q. Does it have any employees currently? 4 A. It did. Not anymore. 5 Q. No employees? 6 A. Not anymore. 7 Q. And it hasn't issued any stock? 8 A. No. 9 Q. Who are the officers and directors of 10 American Private Police Force Org., Inc.? 11 A. We havent set it up yet. He hasn't set it 12 up yet. 13 Q. Well, he's not going to set it up because 14 he's not your attorney any more; right? 15 A. That was his idea. He's supposed to set it 16 up. 17 Q. Does American Private Police Force Org have 18 a parent company? 19 A. No. 20 Q. Did Michael Cohen ever work for American 21 Private Police Force? 22 A. No. We tried to higher him but -- 23 Q. Did Richard Culver ever work for American 24 Private Police Force? 25 A. No. How do you spell Culver? 6 1 Q. C-u-l-v-e-r. 2 A. No. It's spelled C-o-u-l-v-e-r. 3 Q. And where does he live? 4 A. Overseas. It's British. 5 MS. ARMENTA: Off the record. 6 (Discussion held off the record.) 7 BY MS. ARMENTA: 8 Q. Mr. Hilton, I've just gotten off the phone 9 with your former attorney who has informed me that the 10 only person who would know the identity of the 11 investors in American Private Police Force is you. Is 12 your former attorney lying or telling the truth? 13 A. I have no investors. 14 Q. You have no investors. 15 A. No. 16 Q. Did American Private Police Force Org ever 17 open any bank accounts? 18 A. Yes. 19 Q. Where is the bank account held? 20 A. US Bank account. I'll give you a copy. 21 Q. Thank you. You've handed me a 22 non-negotiatable check for American Private Police 23 Force -- 24 A. It's a deposit slip. 25 Q. We'll mark this as Exhibit B and we'll give 7 1 you back your original copies when we're done here. 2 (PLFDF Exhibit EXNUM 3 was marked for identification by the Reporter.) 4 BY MS. ARMENTA: 5 Q. What's the amount in American Private Police 6 Force currently? 7 A. About 2,000 some minus. 8 Q. Who deposited money into that account? 9 A. My father and I did. 10 Q. When you say 2,000 minus you mean it's 11 overdrawn by $2,000? 12 A. Yes, ma'am. 13 Q. Other than this US Bank account for which 14 you've handed me a deposit slip and we've marked as 15 Exhibit B, does American Private Police Force have any 16 other bank accounts? 17 A. No ma'am. 18 Q. Does it have any assets whatsoever? 19 A. No. 20 Q. Does it own any vehicles? 21 A. Leased vehicle, yes. 22 Q. American Private Police Force leased a 23 vehicle? 24 A. Vehicles. 25 Q. What vehicles did American Private Police 8 1 Force lease? 2 A. We got two GLK Mercedes which Mr. Mafi is in 3 possession of. 4 Q. And is title to those vehicles in the name 5 of American Private Police Force? 6 A. Registration yes. And Mafi. Mazir Mafi. 7 Q. That would be your former attorney? 8 A. Right. 9 Q. Where were -- what dealerships were the 10 Mercedes leased from? 11 A. Southland Mercedes. I forgot. 12 Q. Was it House of Imports? 13 A. Yes. 14 Q. Who filled out the paperwork at the 15 dealership for the lease of these two vehicles? 16 A. Mr. Mafi. 17 Q. Did you go with him? 18 A. Yes, I did. 19 Q. Did you sign any paperwork? 20 A. On behalf of corporation, yes. 21 Q. On behalf of the corporation. Did the House 22 of Imports ask you for any information about the 23 finances of American Private Police Force in order to 24 lease those vehicles? 25 A. No. 9 1 Q. Did you -- was an application for credit or 2 for lease filled out? 3 A. Both. 4 Q. Was any information given to House of 5 Imports about the assets of American Private Police 6 Force? 7 A. No. 8 Q. Is Mr. Mafi the guarantor for the leases? 9 A. Yes, ma'am. 10 Q. So has American Private Police Force made 11 any payments on those leases? 12 A. I did make 3,000 down payment for one. 13 Q. So let's go -- $3,000 on one? 14 A. And another check which didn't go through. 15 Another check for 3,000 that didn't go through. 16 Q. So one check for $3,000 didn't go through. 17 Do you mean it bounced? 18 A. It's uncollected funds. 19 Q. Uncollected funds. What does that mean? 20 A. It means when you have checks deposit and it 21 bounced. Deposit it bounce. 22 Q. Let's talk about the one American Private 23 Police Force did pay for. American Private Police 24 Force gave house of imports $3,000 for one of the 25 vehicles? 10 1 A. Yes. 2 Q. And where did that money come from? 3 A. From the account. 4 Q. And so a check was written from Exhibit B's 5 bank account and it was given to House of Imports? 6 A. Yes, ma'am. 7 Q. And that check cleared? 8 A. Yes. 9 Q. How did the money get in the account? 10 A. From we deposit it. 11 Q. Who deposited it? 12 A. My father deposited it. 13 Q. What's your father's full name? 14 A. C-h-e-d-o-m-i-r. D-j-o-k-i-c-h. 15 Q. What's your father's address? 16 A. It's the same. 10501 Brookhurst. Same as 17 mine. 18 Q. He lives in the United States? 19 A. Yes. 20 Q. How old is your father? 21 A. 75. 22 Q. Why did he deposit money into American 23 Private Police Force? 24 A. Why? 25 Q. Why? 11 1 A. Because he opened the account. He's on the 2 account. 3 Q. Does your father -- 4 A. He's a primary signature on the account. 5 Q. He's the primary signature. 6 A. Yes, ma'am. 7 Q. So is he a director and officer of the 8 company? 9 A. We don't establish that. Director I guess. 10 Q. Didn't he have to give US Bank a copy of 11 your statement of information as to -- 12 A. Yes, we did. 13 Q. What did the statement of information say? 14 A. I forgot. 15 Q. Do you have it with you? 16 A. No, I don't. I give it to the bank. So the 17 bank -- 18 Q. I can send them a subpoena, so don't worry 19 about that. 20 A. I'm not worried. 21 Q. Is the money that your father gave to 22 American Private Police Force, was that money given to 23 them on your behalf? 24 A. No. We borrowed the money, yes. On my 25 behalf. 12 1 Q. American Private Police Force owes your 2 father money? 3 A. No. I borrowed that money. He doesn't -- 4 Q. You borrowed the money from your father. 5 A. Yes. 6 Q. Were there any other deposits made to the US 7 bank account other than those made from loans from your 8 father? 9 A. Yes. 10 Q. Who did the money come from? 11 A. 35,000 came from Mafi. 12 Q. Any others? 13 A. And 35,000 one of his clients. 14 Q. What's that person's name? 15 A. Ron Bugarskey. 16 Q. Ron -- 17 A. Bugarskey, B-u-g-a-r-s-k-e-y. And Allen 18 Crumnack. 19 Q. Spell Crumnack, please. 20 A. C-r-u-m-n-a-c-k. 21 Q. So each of those gentleman -- was that a 22 loan or was that to purchase stock in the company? 23 A. No. That was a partnership agreement. 24 Q. Where's the partnership agreement? 25 A. Still Mafi has it. I don't have it. 13 1 Q. Partnership agreement between whom and whom? 2 A. Partnership agreement between Mafi's wife 3 and myself. 4 Q. And what's the nature of that partnership 5 agreement? 6 A. That was regarding the contract, Two Rivers, 7 Montana. 8 Q. You were going to open a contract in 9 Montana? 10 A. Yes. I have copies here. 11 Q. Is that to run a prison in Hardin? 12 A. Yes. 13 Q. What experience do you have running a 14 prison? 15 A. None. 16 Q. What experience do you have in the security 17 business other than having been imprisonated? 18 A. That's good. 19 Q. None? Okay. Does Mafi's wife have any 20 experience in running a prison? 21 A. No. 22 Q. Does she have any experience in security? 23 A. No. 24 Q. Do you hold a license from the Department of 25 Consumer Affairs in California for Investigative or 14 1 Security License? 2 A. No. You don't need to. 3 Q. Other than these deposits, 35,000 from Mafi 4 and 35,000 from Ron Bugarskey, Allen Crumnack and some 5 money from your father, did any other money come into 6 American Private Police Force's account? 7 A. Yes. 8 Q. What other money? 9 A. My girlfriend. She put 20,000. 10 Q. What's your girlfriend's name? 11 A. Becky Nguyen. 12 Q. Spell the last name. 13 A. N-g-u-y-n [sic]. 14 Q. Does she also live at 10501 Brookhurst? 15 A. No. 16 Q. What's her address? 17 A. She's in Placentia. I don't know the 18 address. 19 Q. Anyone else deposit money into American 20 Private Police Force? 21 A. No. 22 Q. Was the money that came from Becky Nguyen 23 was that a loan or to purchase stock? 24 A. A loan. 25 Q. So American Private Police Force owes Becky 15 1 $20,000. It owes Ron Becky 35,000. It owns Allen 2 Crumnack $35,000 -- 3 A. No. Those guys the same guys. 4 Q. So they split that. And it owes Mafi 5 $35,000. 6 A. Right. 7 Q. And where did you intend to get the money to 8 pay these folks back? 9 A. Mr. Mafi prepared a contract so he should 10 know. He prepared a contract for the wife and me. 11 Q. Well, Mr. Mafi is not here so I'm only 12 entitled to your testimony. 13 A. I'm telling you. He's supposed to get money 14 back from the prison revenues. 15 Q. Who came up with the idea to run a prison in 16 Hardin? 17 A. Originally, yes. 18 Q. How did you hear about Hardin's empty 19 prison? 20 A. Everybody. It's on television. 21 Q. Let me ask you about some of the things 22 American Private Police Force spent the money on. It 23 took in close to $90,000? 24 A. Right. 25 Q. Plus the money from your father. Where did 16 1 the money go? 2 A. Travel expenses. People coming from Montana 3 here. People flying from here to Montana. 4 Q. What people? 5 A. The consultants. The telephone consultants. 6 Camera consultants. 7 Q. Did American Private Police Force ever pay 8 you any salary or compensation for your time? 9 A. No. Once we signed a contract for $250,000. 10 I'll get $250,000. 11 Q. You're entitled to $250,000? 12 A. Once the contract is signed, yes. 13 Q. Is there a writing to that effect? 14 A. No. But -- 15 Q. That's your agreement with yourself? 16 A. Other people too. Everybody else. 17 Q. All these investors? 18 A. Yes. 19 Q. When was the last time you had any income on 20 a personal level? 21 A. What do you mean? 22 Q. Let me back up. Do you pay rent at your 23 residence? 24 A. I'm behind four months. 25 Q. So when you paid your rent five months ago 17 1 where did you get that money to pay it? 2 A. My father. 3 Q. Your father. 4 A. Uh-huh. 5 Q. Do you have a cell phone? 6 A. Uh-huh. 7 Q. Yes? 8 A. Yes. 9 Q. How do you pay the bill? 10 A. I just got it a month ago. I haven't paid 11 the bill yet. 12 Q. Do you have any credit cards? 13 A. No. 14 Q. Do you have your wallet on you? 15 A. Yes. 16 Q. Do you have any credit cards at all? 17 A. No. 18 Q. Do you have any money in your wallet? 19 A. I have about $80, $90. Here. Here's my 20 wallet. 21 Q. I'll look at it. 22 A. No credit cards. Only medical stuff. 23 Q. You buy things at Wallgreens? 24 A. Yes. That's not a credit card. 25 Q. Do you buy things at Wallgreens? 18 1 A. Yes. 2 Q. How do you pay for them? 3 A. I have a plan. I pay only 20 percent. 4 Q. So you have health insurance? 5 A. Through them, yes. Medication only. 6 Q. How do you pay for that? 7 A. MSI. 8 Q. How do you pay for that? 9 A. I pay cash. 10 Q. Where do you get the cash? 11 A. From a bank. 12 Q. Okay. Do you have a bank account? 13 A. No. 14 Q. The bank just gives you money? 15 A. If you have money they give you the money. 16 Q. Do you have a bank account? 17 A. No, I don't. 18 Q. You don't have a bank account? 19 A. No. 20 Q. Do you own stock in any company other than 21 American Private Police Force? 22 A. No, ma'am. 23 Q. Do you own any art? 24 A. Art? We sold the art. 25 Q. Do you currently own any art, sir? 19 1 A. Yes. 2 Q. What do you own? 3 A. Paintings. 4 Q. Describe it. How many paintings do you own? 5 A. My ex-wife sold it and she never got paid. 6 Local guy. 7 Q. Do you currently have any pieces of artwork 8 in your possession? 9 A. No. Except the ones that I paint. 10 Q. The ones that you paint? 11 A. Right. 12 Q. What's your ex-wife's name? 13 A. Erica. 14 Q. E-r-i-c-a? 15 A. Uh-huh. 16 Q. What's her last name? 17 A. Hilton. Same. 18 Q. Does she live in Chicago? 19 A. Yes. 20 Q. When were you divorced? 21 A. 1988, '89. 22 Q. What state? 23 A. Illinois. 24 Q. Do you have any children? 25 A. Three. 20 1 Q. Do they all live in Illinois? 2 A. Two of them. 3 Q. Do any live in California? 4 A. Yes. 5 Q. Is anyone in the world currently holding any 6 money for you that is yours? 7 A. No. 8 Q. So you come here completely destitute? 9 A. Pretty much. 10 Q. You have no money. 11 A. Pretty much. 12 Q. When is the last time you worked? 13 A. I work every day. 14 Q. When is the last time you got paid for your 15 work? 16 A. Back in April. 17 Q. April. Okay. That's not too long ago. 18 April 2009? 19 A. Yes. 20 Q. Who was your employer? 21 A. I took it myself from the account. 22 Q. You're self-employed. What account did you 23 take money from? 24 A. From APF. 25 Q. How much money did you take out? 21 1 A. 4,000. 2 Q. And that was to pay you compensation? 3 A. Yes. 4 Q. And what did you do with that money? 5 A. Paid the rent, bills. 6 Q. Now, when you took the money out, did you 7 take it out in cash or did you write a check to 8 yourself? 9 A. My father wrote a check for cash. 10 Q. It was cashed. 11 A. Yes. You can have the records. 12 Q. Oh, I will get them. I assure you. Do you 13 currently have any artwork in your possession other 14 than items you made yourself? 15 A. No, ma'am. 16 Q. When was the last time you bought new 17 eyeglasses? 18 A. Three years ago, four years ago. 19 Q. How did you pay for them? 20 A. It was cash. I don't know. 21 Q. So you have no bank accounts whatsoever, you 22 own no stock, you own no art. How did you get here 23 today? 24 A. I drove. 25 Q. What did you drive? 22 1 A. I drove the car I lease, Mercedes. 2 Q. I thought you said it was parked at Mafi's 3 house. 4 A. No. We have three cars. 5 Q. Is that a Mercedes too? 6 A. Yes, ma'am. 7 Q. For a man who has no art, no bank account 8 you certainly have a luxurious life-style. 9 A. I don't think so. 10 Q. Is it a brand-new Mercedes? 11 A. 2009. 12 Q. Is it leased by American Private Police 13 Force? 14 A. Yes, ma'am. 15 Q. So the company provides you a company car? 16 A. Yes. 17 Q. And is the lease current? 18 A. Yes. 19 Q. So the lease payment was made in October? 20 A. Yes. 21 Q. And who mailed the lease payment? 22 A. I did. 23 Q. And did you use American Private Police 24 Force to do so? 25 A. Yes, ma'am. 23 1 Q. Did the check clear? 2 A. Yes, ma'am. 3 Q. How do you intend to make the payment next 4 month? 5 A. That I don't know. I'm trying to figure it 6 out. 7 Q. Well, I will tell you that I intend to 8 attach every asset that you or American Private Police 9 Force owns. So if that $250,000 ever comes into that 10 account, I'm going to place a lien on that account and 11 that money would pay Richard Earnhart. Do understand 12 that? 13 A. First of all, why is it $300,000? How much 14 did he put in the company -- 15 Q. The default judgment -- 16 A. I understand. How much money he put in in 17 Regency Villas? I never see a penny for that. I gave 18 it to Ivano Stamegna. 19 Q. Well, had you done anything in 2000 to 20 defend the case you would be entitled to ask those 21 questions now. Let me tell you that this procedure 22 does not entitle you to ask questions. This procedure 23 entitles me to ask questions. 24 A. Okay. So it's a one side story, right? 25 Q. Where did these American Private Police 24 1 Force cards get printed? 2 A. Costa Mesa. 3 Q. What's the name of the printer? 4 A. It's Copy for Less. 5 Q. What street is it on? 6 A. I think it's Ettinger and Golden West. 7 Q. Who paid for the cards? 8 A. I did. APF. 9 Q. Using what funds? 10 A. APF funds. 11 Q. Did you write a check to them? 12 A. I think so. 13 Q. How long ago was that? 14 A. Four months ago. 15 Q. Now, you said APF paid for an office. Where 16 is that office located? 17 A. 1225 17th Street, Suite 200. 18 Q. Did APF lease office space at that location? 19 A. No. We share. 20 Q. Who do you share with? 21 A. A clinic. 22 Q. A clinic? 23 A. Yes. 24 Q. Did American Private Police Force pay rent 25 for that shared space? 25 1 A. Yes, we did. 2 Q. When was the last time American Private 3 Police Force paid a rental payment for that space? 4 A. About two months ago. 5 Q. Is it current on its rent? 6 A. No. 7 Q. Is it still in that location? 8 A. No. They take it back. 9 Q. They took the space back? 10 A. Uh-huh. 11 Q. When you say "they," you mean the medical 12 clinic? 13 A. Right. 14 Q. You said there was travel. You said 15 American Private Police Force paid for travel. 16 A. Uh-huh. 17 Q. Yes? 18 A. Yes. 19 Q. Whose travel did American Private Police 20 Force pay for? 21 A. Everybody's. Five, six employees. 22 Q. Five, six employees of American Private 23 Police Force? 24 A. Contracts. 25 Q. Give me their names. 26 1 A. I gave you before. Allen Crumnack and Ron 2 Burgarskey. Twice. 3 Q. Becky Nguyen? 4 A. No. She didn't go. 5 Q. You? 6 A. Yes. Twice. 7 Q. Was this for plane travel? 8 A. No. I can't fly. 9 Q. You can't fly? 10 A. No. Because I have a stent. I drove twice. 11 Q. Did American Private Police Force spend 12 money to pay for travel for anyone coming from Montana 13 to Los Angeles? 14 A. Yes. 15 Q. Who? 16 A. Carrie Smith. 17 Q. Carrie Smith? 18 A. Uh-huh. 19 Q. Anyone else? 20 A. That's it. 21 Q. Did American Private Police Force pay any 22 money to anyone in Montana? 23 A. No. 24 Q. Has American Private Police Force had any 25 employees in Montana? 27 1 A. We got Becky Shay. 2 Q. Who is Becky Shay? 3 A. Becky Shay she's a spokesman I think. 4 Q. Did American Private Police Force employee 5 her? 6 A. We did. 7 Q. Do you have an employment agreement? 8 A. No, not with me. 9 Q. But there is one in existence? 10 A. Yes, I do have a copy. 11 Q. And did Becky Shay get paid any money from 12 American Private Police Force? 13 A. No. 14 Q. Never? 15 A. Never. 16 Q. Did American Private Police Force pay her a 17 signing bonus? 18 A. No. 19 Q. Did any of the funds go to pay for anything 20 on behalf of Becky Shay like her mortgage or anything 21 like that? 22 A. No. 23 Q. So no money changed hands between American 24 Private Police Force and Becky Shay? 25 A. No. 28 1 Q. Did any money change hands between American 2 Private Police Force and Carrie Smith? 3 A. No. 4 Q. Did any money change hands between the city 5 of Hardin or the Three Rivers Authority and American 6 Private Police Force? 7 A. No. 8 Q. When they took your picture in the newspaper 9 you had a badge. 10 A. Uh-huh. 11 Q. That said American Private Police Force. 12 A. Yes. 13 Q. Do you remember that? 14 A. Yes. 15 Q. Where was that badge manufactured? 16 A. Here in California. 17 Q. Where? 18 A. In California here. 19 Q. Yes. Could you be more specific. The state 20 is rather large. 21 A. I don't have the name but it's in Reseda 22 California. I forget the name. Uniform unlimited, 23 something like that. 24 Q. They make badges? 25 A. Yes. Uniforms and badges. 29 1 Q. And it's in Reseda? 2 A. Yes. 3 Q. Do you remember what street it's on? 4 A. I forgot. It's in Reseda. They're listed. 5 Q. How did American Private Police Force 6 purchase those badges? 7 A. We paid. 8 Q. Did you pay by check? 9 A. Yes, we did. 10 Q. Did you bring any other documents with you 11 today? 12 A. Like what? 13 Q. I gave you a list of documents I wanted. 14 A. That's all I have. 15 Q. Mr. Hilton has handed me a document entitled 16 Two Rivers Detention Center Operation and Management 17 Agreement which I'm going to mark as Exhibit C to this 18 transcript. 19 (PLFDF Exhibit EXNUM 20 was marked for identification by the Reporter.) 21 BY MS. ARMENTA: 22 Q. It appears to be signed by Michael Hilton 23 and Greg Smith and Albert Peterson. There's a 24 signature space for Lawrence Bell of US Bank which is 25 unsigned. 30 1 Mr. Hilton, other than this document which 2 I've marked as Exhibit C and small purchases for badges 3 and uniforms and the leases, has American Private 4 Police Force entered into any other contracts with any 5 other person or entity? 6 A. Yes. We had a contract with the police 7 department but I don't have any copies. Mr. Mafi it. 8 Q. Can you repeat what you just said? 9 A. We had an agreement to set up a police 10 department in Hardin. Not to run it. To set it up. 11 For that we were supposed to receive 250,000. 12 Q. So the fee for setting up the police 13 department was going to be $250,000? 14 A. Yes, ma'am. 15 Q. And that was a fee that the city of Hardin 16 was going to pay to American Private Police Force? 17 A. Yes, ma'am. 18 Q. Did any of that money change hands? 19 A. No. 20 Q. Do you have the agreement somewhere? 21 A. Probably do but they should have it. I 22 think Mr. Mafi has it. I gave him a copy. I actually 23 gave him the original. 24 Q. Mr. Hilton, does anyone, you or anyone else, 25 any of the investors have any experience whatsoever in 31 1 military? 2 A. I have experience in military. 3 Q. In this country? 4 A. No. 5 Q. In your native country? 6 A. Uh-huh. 7 Q. Is that yes? 8 A. Yes. 9 Q. That's Montenegro? 10 A. Yes. 11 Q. What experience? 12 A. I was MP. I was stationed in Cypress, 13 Turkey. 14 Q. How long ago was that? 15 A. '72. 16 Q. Other than your experience in Cypress in 17 1972, between 1972 and the present have you had any 18 experience in the military? 19 A. No. 20 Q. Any experience in private security? 21 A. No. 22 Q. Any experience working for a police force? 23 A. No. 24 Q. Any experience setting up a police 25 department? 32 1 A. No. 2 Q. Any experience whatsoever that would qualify 3 you for employment with American Private Police Force? 4 A. I don't know what you're talking about. Be 5 specific. 6 Q. Let's talk about American Private Police 7 Force's website. Who created that website? 8 A. It's a professional company. 9 Q. What's the name of the company? 10 A. Green Point. 11 Q. Who's your contact there? 12 A. Paul. 13 Q. What's Paul's last name? 14 A. I forgot. 15 Q. Do you have a phone number for Paul? 16 A. Not with me. 17 Q. How did you get in contact with him? 18 A. Someone called me and recommended him. 19 Q. Who called you and recommended him? 20 A. Friends. He had done work for them. 21 Q. You're aware that American Private Police 22 Force makes certain representations on the site about 23 experience in military and training and security 24 investigation; correct? 25 A. Uh-huh. 33 1 Q. Yes? 2 A. Yes. 3 Q. What experience if any does anyone 4 whatsoever affiliated with American Private Police 5 Force have with respect to the representations made on 6 the website? 7 A. Can I ask you a question? 8 Q. Yes. 9 A. Are you talking about APF or are you talking 10 about the judgment debtor here? 11 Q. I'm trying to find the assets of APF. 12 A. You got the assets right here. 13 Q. So I have a checking account that has 14 negative $2,000 in it. 15 A. Right. 16 Q. Do you have the registration for the 17 Mercedes with you? 18 A. Yes. 19 Q. Let me see it. Mr. Hilton has handed me a 20 registration card for a 2009 Mercedes which I'm going 21 to mark as D to this transcript. 22 (PLFDF Exhibit EXNUM 23 was marked for identification by the Reporter.) 24 BY MS. ARMENTA: 25 Q. Do you personally own any vehicles? 34 1 A. No, ma'am. 2 Q. Do you have any assets in any other country? 3 A. I don't. 4 Q. Do you have any bank accounts in your native 5 country? 6 A. No. I haven't been there -- 7 Q. Is your father holding any money that 8 belongs to you? 9 A. No. 10 Q. Is your ex-wife holding any assets or 11 property that belongs to you? 12 A. No. 13 Q. Are your children holding any assets or 14 property that belongs to you? 15 A. No. 16 Q. Does anyone in the world have any assets 17 that belong to you? 18 A. No. 19 Q. How do you intend to live for the rest of 20 your life, Mr. Hilton? 21 A. I have to find a job. 22 Q. What is the last employment you had other 23 than with American Private Police Force? 24 A. I commission paint. 25 Q. A commission painter? 35 1 A. Uh-huh. 2 Q. And what was the amount of the last painting 3 that you sold? How much did you get for it? 4 A. About 8,000. 5 Q. How many pieces of art do you have in your 6 house? 7 A. My own art? 8 Q. Yes. 9 A. Four. 10 Q. Are they named or titled? 11 A. Uh-huh. 12 Q. Please give me the titles. 13 A. Mother Theresa. 14 Q. Is that oil and canvas? 15 A. Yes. 16 Q. How big is it? 17 A. I don't know. I forgot. 18 Q. I have to know because I have to describe it 19 in the writ of attachment that I'm going to get to take 20 your artwork from you. So how would you describe it? 21 Is it a three by three? 22 A. No. It's four -- 23 Q. Four feet? 24 A. 48 inches. 25 Q. Where is it currently? 36 1 A. At the office. 2 Q. At the office that you used to share with 3 the clinic? 4 A. Yes. 5 Q. Do you have a value on that artwork? 6 A. No, I don't. 7 Q. I would ask you to leave it exactly where it 8 is because I plan to go there with the sheriff and take 9 it. Do you understand that? 10 A. Uh-huh. 11 Q. What's the second piece of artwork you have? 12 A. It's a portrait. 13 Q. Does it have a name? 14 A. No. 15 Q. Is it a self-portrait? 16 A. No. 17 Q. That would be valuable. I tell you. Okay. 18 And how big is it? 19 A. It's about the same size. 20 Q. And where's it currently located? 21 A. At the office. 22 Q. The office that you used to share with the 23 clinic? 24 A. Uh-huh. 25 Q. Is that a yes? 37 1 A. Yes. 2 Q. I need an audible response for the 3 transcript. I would ask you to leave that painting 4 exactly where it is because I plan to go there with a 5 sheriff and a writ of attachment. Do you understand 6 that? 7 A. Okay. 8 Q. What's the third painting that you own? 9 A. Those are not paintings. 10 Q. What other artwork do you own? 11 A. A leopard. Rick Garcia is the artist. 12 Q. Is they -- what medium is this piece of 13 artwork in? 14 A. It's a serigraph. 15 Q. And where was it purchased? 16 A. Years ago in Chicago. 17 Q. I'm sorry. I'm is not familiar with Rick 18 Garcia. Where is he from? 19 A. United States. 20 Q. Where is that serigraph currently located? 21 A. At my house. 22 Q. 10501 Brookhurst? 23 A. Yes. 24 Q. Where exactly in the house? 25 A. In the bedroom. 38 1 Q. In your bedroom? 2 A. Yes. 3 Q. Is that located in the main house or a 4 different structure? 5 A. Main house, downstairs. 6 Q. Downstairs. In the main level? 7 A. Uh-huh. 8 Q. Or in a basement? 9 A. There's no basement. Main level. 10 Q. It's the main level. Sorry. I'm from 11 Montana. We all have basements. So it's a bedroom. 12 Is it hanging above the bed? 13 A. Uh-huh. 14 Q. Is that a yes? 15 A. Yes. 16 Q. And how big is that? 17 A. I forgot the dimensions. 30 by 32. 18 Q. Is that -- it's a serigraph. Was the 19 portrait -- not the Mother Theresa but the portrait, 20 was that oil and canvas? 21 A. Huh-huh. 22 Q. Is that yes? 23 A. Yes. 24 Q. Now, you said there were four pieces of art. 25 What's the fourth piece? 39 1 A. A tiger by Rick Garcia. 2 Q. Where is it located? 3 A. Same bedroom. 4 Q. Same bedroom. Is it about the same size? 5 A. Yeah. 6 Q. Is it a serigraph also? 7 A. Yes. 8 Q. What's its value? 9 A. I have no idea. 10 Q. I would ask you to -- unless you want to 11 deliver them to me directly to my office, then I would 12 ask you to leave the leopard and tiger where they are 13 because I'll have a sheriffs execute a writ of 14 attachment. Do you understand that? 15 A. Yes. 16 Q. Would you rather bring these pieces of 17 artwork to my office so we can collect partially on the 18 judgment? 19 A. Okay. 20 Q. Then I won't have to bring the sheriffs to 21 your house. 22 A. Okay. 23 Q. When can you bring them? 24 A. Tomorrow. 25 Q. How about today? 40 1 A. I'm sick. I can hardly even breathe. 2 Q. Okay. No problem. How about Monday? 3 A. Monday would be good. 4 Q. Maybe you'll be feeling better by then. 5 A. Thank you. 6 Q. I'll give you my card and you can bring them 7 to my office on Monday. If they're not in my office on 8 Monday, I will get a writ of attachment and bring the 9 sheriffs to your house. 10 A. You can have this. That's what Ivano 11 Stamegna owes. $70,000. 12 Q. I'm going to mark this letter as Exhibit E. 13 It's a letter Mr. Hilton handed me dated April 23, 2003 14 with a fax header on it of the same date from Becky 15 Nguyen, N-g-u-y-e-n. 16 A. He took $70,000. 17 Q. So you're saying this is proof that 18 Mr. Stamegna took $70,000 from your girlfriend? 19 A. Yes. That's for another project. There's 20 assisted living houses. I spoke to Llan. He said he 21 took the money. 22 Q. Has Becky Nguyen filed any criminal case 23 against Ivano Stamegna for defrauding her? 24 A. We went to Llan to dicuss it and Llan said 25 Ivano took it and we went to his office and it's shut 41 1 down in Costa Mesa. She spoke to Ivano many times and 2 he said next month, next month and finally he told her 3 he's filing bankruptcy. 4 Q. Do you know where Ivano Stamegna lives now? 5 A. Same address. 6 Q. On Glenmont in Irvine? 7 A. Go after him. 8 Q. Don't worry. We're going to go after him 9 for a judgment against him too. 10 A. If you can collect 70,000 go ahead. 11 Q. Just so you understand, any money that we 12 collect comes off the money that you owe Mr. Earnhart. 13 A. I'd better have him have it than Ivano. 14 Q. Great. Do you have any money that you can 15 give him today? 16 A. No. 17 Q. So I'm going to give you my card. So if you 18 have any money ever you can send it to me and I will 19 give it to Mr. Earnhart and we'll subtract it from the 20 money you owe him. 21 A. Can I have a copy of this back? 22 Q. You can have a copy of everything. 23 A. That's the address of Llan. I spoke to Llan 24 twice. 25 Q. I have his correct address. This is my 42 1 service list. 2 A. That's how I got a copy. 3 Q. Let me mark this as Exhibit F. 4 (PLFDF Exhibit EXNUM 5 was marked for identification by the Reporter.) 6 BY MS. ARMENTA: 7 Q. Exhibit F is a service listed dated 10-21-09 8 that my office generated. It has Ivano Stamegna's 9 address on it and Mr. Hilton is confirming that's his 10 current address? 11 A. Yes. 12 Q. Does anyone else other than Ivano Stamegna 13 owe you money? 14 A. Yeah, but I can fax you that bill. It's not 15 mine but my ex-wife and me. For artwork. 16 Q. Who owes you money? 17 A. Some guy in Hermosa Beach. 18 Q. What's his name? 19 A. I forgot. I fax you the whole -- 20 Q. Yeah, because anyone that owes you money my 21 view is they owe Mr. Earnhart money. 22 A. Let him take it. 23 Q. We'll collect it for you. We'll take all 24 your assignments of anyone that owes any money to you. 25 A. Okay. I'll do it. 43 1 Q. Will you assign your creditor rights to 2 Mr. Earnhart? 3 A. Yes. 4 Q. Wonderful. 5 A. Because he took $60,000 right here. 6 Q. Is there anything that you can think of 7 other than people owing you money that would enable 8 Mr. Hilton to collect any money from you -- 9 Mr. Earnhart to collect any money from you? 10 A. No. I have to look for a job. 11 Q. Where is Llan? 12 A. Llan is in Orange. 13 Q. Do you have his address? 14 A. You have it on the list. 15 Q. Is that Cal-Rio LLC? 16 A. Llan Brand. 17 Q. And that's the correct address on Joan D'Arc 18 Drive? 19 A. That's the last time I spoke to him. 20 Q. Don't worry. These folks will be in court 21 next month. They have their turn in December. So if 22 you can think of any questions they should be asked, 23 feel free to send them my way. 24 A. I want to fax you the copies. 25 Q. Wonderful. Let me take a quick break and 44 1 speak to my client and maybe we can be done here. 2 (Recess taken.) 3 Q. I have no further questions. Thank you 4 Mr. Hilton for coming voluntarily. I will tell you 5 that although this particular part of the judgment 6 debtor proceeding is over for today, we will continue 7 to make every effort to collect on this judgment until 8 it's paid if full. So should you be so lucky as to win 9 the Lotto, we'll attach those earnings as well. And 10 you have my card. Please bring the artwork on Monday. 11 We will organize a proper way to auction the items off 12 or evaluate them using a professional art appraiser and 13 that money that we get from that will be taken off your 14 judgment. 15 A. What about if I fax you the people owing me 16 money in Hermosa. 17 Q. We'll try to put a valuation on anything you 18 send me. 19 A. It's 75,000 at least. 20 Q. We want the money. So if we collect on it, 21 it will come off your balance so to speak. 22 Would you just wait while we make copies of 23 all of these things for you? 24 A. Yeah. 25 Q. Thank you. 45 1 (At which time the proceedings were 2 concluded.) 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 46