1 IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF TEXAS 2 ALLEGIANCE CAPITAL ) 3 CORPORATION, ) Plaintiff, ) 4 ) vs. ) CIVIL ACTION NO. 3:03-CV-0751-R 5 ) GREAT CANADIAN GAMING ) 6 CORPORATION, GREAT ) CANADIAN CASINOS, INC., ) U.S. District Judge Jerry Buchmeyer 7 ROSS MCLEOD, and MICHAEL ) SCHOLZ, ) U.S. Magistrate Judge Jeff Kaplan 8 Defendants. ) 9 ************************************************************** 10 11 ORAL DEPOSITION OF PROKA AVRAMOVIC 12 APRIL 9, 2004 Volume 1 of 1 13 14 ************************************************************** 15 16 ORAL DEPOSITION OF PROKA AVRAMOVIC, produced as a 17 witness at the instance of the Plaintiff, and duly sworn, was 18 taken in the above-styled and numbered cause on the 9th day of 19 April, 2004, before Vicki Humphrey, CSR in and for the State 20 of Texas, reported by machine shorthand method, at the offices 21 of Ray, Cho & Wiley, P.L.L.C., 3102 Maple Avenue, Suite 240, 22 Dallas, Texas 75201, pursuant to the Federal Rules of Civil 23 Procedure and the provisions stated on the record or attached 24 hereto. 25 VICKI HUMPHREY, CSR MANSFIELD, TX METRO(817)477-2035 2 1 A P P E A R A N C E S: 2 FOR THE PLAINTIFF: 3 DONALD A. RAY, Attorney at Law MICHAEL S. CHO, Attorney at Law 4 DAVID L. WILEY, Attorney at Law Ray, Cho & Wiley, P.L.L.C. 5 3102 Maple Avenue, Suite 240 Dallas, Texas 75201 6 FOR THE DEFENDANTS: 7 Richard D. Pullman, Attorney at Law 8 Vial, Hamilton, Koch & Knox 1700 Pacific, Suite 2800 9 Dallas, Texas 75201 10 ALSO PRESENT: DAVID MAHMOOD and CARL BOLTON 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 VICKI HUMPHREY, CSR MANSFIELD, TX METRO(817)477-2035 3 1 INDEX 2 PAGE 3 APPEARANCES -------------------------------------- 2 4 WITNESS: PROKA AVRAMOVIC 5 Examination by Mr. Ray ----------------------- 4 Examination by Mr. Pullman ------------------- 72 6 SIGNATURE AND CHANGES ---------------------------- 119 7 REPORTER'S CERTIFICATE --------------------------- 121 8 E X H I B I T S 9 10 11 EXHIBIT DESCRIPTION PAGE IDENTIFIED 12 6 Subpoena 4 13 7 Release 5 8 Handwritten notes 24 14 15 16 17 18 19 20 21 22 23 24 25 VICKI HUMPHREY, CSR MANSFIELD, TX METRO(817)477-2035 PROKA AVRAMOVIC 4 1 PROKA AVRAMOVIC, 2 the witness, first being duly cautioned and sworn to tell the 3 truth, the whole truth and nothing but the truth, so help him 4 God, testified as follows, to-wit: 5 6 EXAMINATION 7 BY MR. RAY: 8 Q. I know that you've already spelled your name for the 9 court reporter, but I'd like for you to state your name again, 10 please, sir, if you would. 11 A. Okay. My name is Proka Avramovic, P-r-o-k-a, last 12 name A-v-r-a-m-o-v-i-c. 13 Q. Okay. I just want to -- Avramovic is the way you 14 like -- that's the correct pronunciation? 15 A. Avramovic is close enough. 16 Q. Okay. 17 (Deposition Exhibits Nos. 6 and 7 were 18 marked for identification purposes.) 19 Q. Mr. Avramovic, am I saying that right? 20 A. You can call me by first name. Proka is easier. 21 Q. Proka is easier for me to say, yeah. I'm going to 22 show you what's been marked Deposition -- Plaintiff's 23 Deposition Exhibit No. 6, ask you to identify it for the 24 record, please, sir. 25 A. Yeah, I did receive this on April 7th. VICKI HUMPHREY, CSR MANSFIELD, TX METRO(817)477-2035 PROKA AVRAMOVIC 5 1 Q. You received that doc -- Could you tell for the 2 record what it is? 3 A. It's a subpoena. 4 Q. Okay. A subpoena for you to appear and testify in 5 this deposition? 6 A. Yeah, on Friday, April the 9th, which is today. 7 Q. Okay. Thank you. And I'm going to show you another 8 document here that's been marked Plaintiff's Deposition 9 Exhibit No. 7, ask you to identify that, please, sir. 10 A. That is a copy of my release letter. 11 Q. Your release letter from whom? 12 A. From Great Canadian Casinos, Incorporated. 13 Q. Okay. Thank you. 14 MR. RAY: All right. We're going to continue on 15 under the same agreement that we had earlier, right, Richard? 16 MR. PULLMAN: Yeah. 17 MR. RAY: Okay. 18 Q. (By Mr. Ray) I'm going to have to go over a few 19 preliminary things here with you, Proka. Number one, you need 20 to give a verbal response here for the court reporter to take 21 it down. No head shakings or nods or other gesticulations, 22 okay? 23 A. I understand. 24 Q. And if I ask you a question you don't understand, 25 doesn't make sense to you, you just tell me so and stop me and VICKI HUMPHREY, CSR MANSFIELD, TX METRO(817)477-2035 PROKA AVRAMOVIC 6 1 I'll try to rephrase it the best I can so that you can 2 understand it, okay? 3 A. That's okay. 4 Q. And I would ask you to allow me to finish asking the 5 question, and Mr. Pullman as well, before you try to give an 6 answer so we won't be talking over each other. 7 A. Okay. 8 Q. And from time to time, Mr. Pullman may have some 9 objections, and if he has an objection, you need to allow him 10 to finish making it and then you can proceed, okay? 11 A. Okay. 12 Q. All right. Did you review any documents to get 13 prepared for appearing for this deposition? 14 A. No. 15 Q. Okay. Did you have any conversations with any 16 officers or directors or other personnel employed by Great 17 Canadian Casinos, Inc. prior to appearing for this deposition? 18 A. No. 19 Q. Okay. Has anyone offered you any money or other 20 benefit in return for refraining from cooperating in this 21 deposition? 22 A. No. 23 Q. What is your current residence? 24 A. It's -- 25 Q. Address. VICKI HUMPHREY, CSR MANSFIELD, TX METRO(817)477-2035 PROKA AVRAMOVIC 7 1 A. Oh, this is, yeah, P.O. Box. Okay. It's 1021133 2 Barclay Street, Vancouver, B.C. 3 Q. Could you spell that street name for us, please, sir? 4 A. It's B-a-c -- I'm sorry. It's B-a-r-c-l-a-y Street. 5 Q. Okay. 6 A. I guess I didn't say -- 7 Q. Did you -- Is there like a zip code on that? 8 A. Yeah. It's V6E1G8. 9 Q. Okay. Could you also give us your telephone number, 10 please, sir? 11 A. Area code 604/417-0989. 12 Q. Okay. What was your -- I mean -- Scratch that. How 13 long have you lived in your current address? 14 A. For about two years. 15 Q. Okay. Do you remember what your address was before 16 that? 17 A. I could probably recall. It's 3387 Somerset Street, 18 Port Coquitlam, B.C. 19 Q. Okay. Could you spell Somerset for us, please, sir? 20 A. It's S-o-m-e-r-s-e-t. 21 Q. Proka, have you been employed with Great Canadian 22 Casinos, Inc.? 23 A. Yes, for about nine years. 24 Q. Okay. Are you employed -- obviously because you have 25 this release, you're not employed by them now, are you? VICKI HUMPHREY, CSR MANSFIELD, TX METRO(817)477-2035 PROKA AVRAMOVIC 8 1 A. No. 2 Q. Okay. When did your employment cease? 3 A. You mean when I stopped working for them? 4 Q. Yes, sir. 5 A. The exact date I have to look up on my release. The 6 last day of work was on 24th of June, and release letter has 7 been signed on the 25th of June. 8 Q. That's of what year? 9 A. June 2003. 10 Q. All right. 11 MR. PULLMAN: You're referring to Exhibit 7? Is 12 that what you're looking at? 13 THE WITNESS: Yes. 14 MR. PULLMAN: I just want to make a clean 15 record. 16 Q. All right. For the record, you were referring to 17 Plaintiff's Exhibit No. 7 to get that date; is that correct? 18 A. Yes. 19 Q. Okay. How did you come to seek employment with Great 20 Canadian Casinos? 21 A. You mean when and how I start working for them? 22 Q. Yes, yes. 23 A. I start as a dealer, like card dealer, like cards and 24 roulette. 25 Q. Okay. Before we get to that issue, though, I mean, VICKI HUMPHREY, CSR MANSFIELD, TX METRO(817)477-2035 PROKA AVRAMOVIC 9 1 how did you -- how did you come to go to work for them? What 2 got you interested in going to work for them? 3 A. Well, I knew couple of people that worked for Great 4 Canadian Casino. It was different name. It was Great 5 Canadian Casino, Ltd. I heard that it's interesting job and 6 it was flexible shifts. I did actually met Boki Sikimic at 7 that time. He was telling me that there was a course for 8 dealers. I hesitated on the beginning, but I finally took a 9 course, I think, August '94. 10 Q. Okay. Did you have to interview with someone? 11 A. Yes. It was -- I had to pass few interviews. I 12 remember one name, Mona Nowak. 13 Q. Pardon? Say that again. 14 A. Mona Nowak was -- 15 Q. Could you spell the last name, please? 16 A. It's N-o-w-a-k. 17 Q. Okay. 18 A. I had interview with her, and after that interview I 19 begin with the course. 20 Q. Okay. You said you took some sort of examination 21 before you interviewed? 22 A. Yeah. It was whole bunch of questions. Mostly they 23 try to find out like my calculation skills, like can I count 24 the cards quick enough and numbers. 25 Q. I see. Do you remember about the date that you were VICKI HUMPHREY, CSR MANSFIELD, TX METRO(817)477-2035 PROKA AVRAMOVIC 10 1 hired on? 2 A. Well, I look at my record of employment and it says 3 that I start working for them full-time on March '95. I can't 4 recall the date, exact date. 5 Q. That's close enough. What was your initial position? 6 A. I start as a blackjack dealer. 7 Q. Okay. And how long were you engaged with that 8 position? 9 A. I was a dealer for almost three years. 10 Q. Okay. And after you were a blackjack dealer, then 11 what did you go to from there? 12 A. It was a couple of steps actually in that ladder. 13 It's blackjack dealer and then there is a course that you take 14 for roulette, so I took that course as well. So I was a 15 double-skilled dealer. That's how they call people who have 16 both skills: card and roulette. 17 Q. Did you start operating a roulette table? 18 A. Yeah, that I did, I did. And altogether it's, I 19 think, little less than three years. 20 Q. That you operated a roulette table? 21 A. As blackjack dealer and card dealer. It's just -- 22 it's sometimes you're dealing roulette, sometimes you're 23 dealing blackjack. It depends what shift you have, so... 24 Q. Okay. So -- I want to make sure I'm understanding 25 you correctly. So we go back. You were a blackjack dealer VICKI HUMPHREY, CSR MANSFIELD, TX METRO(817)477-2035 PROKA AVRAMOVIC 11 1 for four years and then you were -- 2 A. No. Altogether in those three years period -- 3 Q. Yeah. 4 A. -- I was a dealer. I can't recall when was exactly I 5 took the course, but altogether I deal blackjack and roulette 6 for three years. 7 Q. Okay. All right. What did you do after that? 8 A. There was open position in the security department. 9 I had some background from back home in security. 10 Q. Back home. Now, where is back home? 11 A. Back home was Yugoslavia, now known as Serbian 12 Montenegro. 13 Q. Okay. 14 A. I work there for a year and a half as a floor 15 security. 16 Q. As a four security in -- 17 A. Floor security. 18 Q. In Montenegro? 19 A. It's Yugoslavia. It's formerly Yugoslavia, but now 20 that country now called Serbian Montenegro. It's not 21 Yugoslavia any more. 22 Q. Okay. That security work that you did in Serbia, 23 that was -- was that for a gambling casino? 24 A. Yeah. 25 Q. Okay. And how long did you work in that connection? VICKI HUMPHREY, CSR MANSFIELD, TX METRO(817)477-2035 PROKA AVRAMOVIC 12 1 A. It was a little less than two years. 2 Q. Okay. All right. 3 A. Then I move to Canada. 4 Q. Okay. So how did you come to apply for the security 5 position here? 6 A. It was opening position. Usually the practice with 7 Great Canadian is they post the opening position. So I 8 applied and I have an interview with director of security 9 there. Back then was Lu Cliff. 10 Q. Could you spell that for us, please, sir? 11 A. I don't know. Like Lu. I assume his real name is 12 Louis. And Cliff, I believe it's with two F. 13 Q. C-l-i-f-f? You think that might -- 14 A. Yeah, I believe so. So I got interviewed by him, and 15 because of my gaming experience, background, I start working 16 as floor security. 17 Q. Okay. Now, did you have to take an examination for 18 that? 19 A. No. 20 Q. Okay. And you started working floor security where 21 exactly? 22 A. It was the Holiday Inn location in Vancouver. That's 23 one of the Great Canadian Casinos location. 24 Q. Okay. What were your duties working there in 25 security? VICKI HUMPHREY, CSR MANSFIELD, TX METRO(817)477-2035 PROKA AVRAMOVIC 13 1 A. Mainly as a floor security, I was spending most of 2 the time on floor just observing customers and staff, making 3 sure that everything is in order and reporting every 4 discrepancy to the surveillance people. 5 Q. Okay. Were there any company policies that you had 6 to familiarize yourself with, a manual or anything like that? 7 A. Yeah, we used -- actually I have a floor security 8 manual and also a surveillance manual provide by Great 9 Canadian at that time. 10 Q. Okay. Did you have to familiarize yourself with that 11 before you could start working? 12 A. Yeah, a little bit. I had a chance for about couple 13 of weeks to figure out what the rules are. And then during 14 the work, I just get familiar with the rules. 15 Q. Was it -- Well, was it something that you referred to 16 from time to time if you were in doubt about something or not? 17 A. Well, I could always ask my superior. I was always 18 able to contact my superior and ask if I ever have any 19 questions. 20 Q. All right. How long did you act in floor security in 21 the Holiday Inn? That's Holiday Inn Richmond, did you say? 22 A. No. I start as a floor security at the Holiday Inn 23 Casino. 24 Q. And say that again. 25 A. At the Holiday Inn Casino. That's the Vancouver VICKI HUMPHREY, CSR MANSFIELD, TX METRO(817)477-2035 PROKA AVRAMOVIC 14 1 location. 2 Q. Oh, Vancouver. I'm sorry. 3 A. In about, I would say, 14 or 15 months -- I can't 4 recall right now the exact date -- it was opening position for 5 surveillance, and I applied for that position as well. I went 6 through the interviews again and -- 7 Q. Who did you interview with this time? 8 A. I think that I was interviewed by Brian Egli and Vane 9 Sebastian. He was one of the head of the security back then. 10 Q. Could you spell that name for us, please, sir? 11 A. Vane, it's like Vane. And Sebastian is just -- I 12 don't really know. 13 Q. Vane? Are you saying V-a-n-e or something like that? 14 A. Well, I'm not quite sure about the spelling. 15 Q. Okay. 16 A. I mean, I can try, but I don't know if it's -- 17 Q. Yeah, I understand. Okay. I'm just trying to get 18 spellings as much as I can for the court reporter here. 19 Okay. And after you interviewed, were you given the position? 20 A. Yes. 21 Q. Okay. And so this position was in surveillance. Was 22 it at the same location? 23 A. Yeah, it was at the same location. 24 Q. Okay. What did you do in that connection? 25 A. Okay. The responsibility were to -- Obviously VICKI HUMPHREY, CSR MANSFIELD, TX METRO(817)477-2035 PROKA AVRAMOVIC 15 1 surveillance is very sensitive part of the casino, so there 2 was responsibility like making sure that everything in the 3 casino is recording for 24 hours, it's nonstop, report any 4 discrepancy in the casino, wrongdoing, any suspect 5 activities -- suspicious activities, and we used to report to 6 our manager. 7 Q. Who was your manager? 8 A. Back then it was Patricia Headstrom (phonetic). 9 Q. Headstrom? 10 A. Yeah. Again, with the spelling, I mean, I can try, 11 but I don't know if it's right. I don't think she's employed 12 by Great Canadian anymore. 13 Q. Okay. Patricia Headstrom. Okay. You said -- Let me 14 just stop you for a minute. You said that you'd make sure 15 everything was recorded for 24 hours. Recorded how? 16 A. We had VCRs, video recorders. Basically every table 17 and every angle of the casino was covered by camera, and all 18 those cameras supposed to record 24/7. 19 Q. How can you tell that? 20 A. Well, it's -- Well, back then casino was small, so we 21 didn't have that many VCRs. Now it's a little more 22 sophisticated. Well, it's now -- the equipment now, it's 23 better, so if VCR stops, it will tell you right away. But 24 back then we just had like VCRs, and usually if VCR stops for 25 some reason, you can hear the click. Every once in a while VICKI HUMPHREY, CSR MANSFIELD, TX METRO(817)477-2035 PROKA AVRAMOVIC 16 1 you just get up and check all VCRs, check the recording light. 2 Q. Well, I mean, was there some sort of little boxes and 3 the film that was being made showing what time it was and what 4 date it -- 5 A. Yeah. Well, at the same time we actually kept a 6 logbook. Logbook in surveillance is a very important document 7 because it tells you everything what's happening in the 8 surveillance room and on the floor, and of course every little 9 discrepancy. 10 Q. Okay. We're going to talk about the logbook in just 11 a minute, but let me go back just for a second back to the 12 film. If I was looking at a film that was made in the 13 casino -- 14 A. Okay. 15 Q. -- would I be able to see as I was looking at it, you 16 know, the date and time? Would it be -- 17 A. Yeah, there is a date and time, yeah. 18 Q. Okay. All right. That's all I want to know. With 19 the logbook, tell me about the logbook. How was it kept and 20 who kept it? 21 A. Well, every time you come to the shift, you enter 22 your name and time. 23 Q. But, I mean, before we get to the shift. I'm talking 24 about just a casino in general. 25 A. Yeah, I'm just talking -- VICKI HUMPHREY, CSR MANSFIELD, TX METRO(817)477-2035 PROKA AVRAMOVIC 17 1 Q. Yeah, yeah. 2 A. Regularly you just show up for a shift. You relieve 3 the person who was on the shift before you. You log your 4 name. Every single movement you're making surveillance like 5 changing the tapes, reviewing something, you're supposed to 6 log in the book. Of course every discrepancy you're supposed 7 to log in the book, any reports, miscellaneous reports. 8 Q. And you said shift. I thought you said ship. Shift, 9 s-h-i-f-t, right? 10 A. Shift, yeah. 11 Q. Okay. I'm sorry. I misunderstood you. All right. 12 Whose responsibility is it specifically to make entries in the 13 logbook? 14 A. Usually it's the guy in charge. Also, when I start 15 in surveillance, I was second guy. 16 Q. Okay. 17 A. Usually there was a manager or supervisor on the 18 shift. He's responsible to make that book, you know, and 19 truthfully enter correct information in the book. 20 Q. Okay. So if there was some sort of discrepancy that 21 someone else observed, they would tell him and he would log 22 it? Would that be correct? 23 A. Yes. 24 Q. Okay. All right. And how long did you work in that 25 capacity? VICKI HUMPHREY, CSR MANSFIELD, TX METRO(817)477-2035 PROKA AVRAMOVIC 18 1 A. For, again, around 12 to 13 months. 2 Q. Okay. All right. And where did you go from there? 3 A. There was again another position open, this time for 4 surveillance supervisor. Back then -- 5 Q. Let me just stop you just for a minute there. When 6 you say surveillance supervisor, do you mean like someone 7 who's a supervisor of a shift? 8 A. Yes. 9 Q. Okay. 10 A. Back then we had -- surveillance was in charge of the 11 floor security as well. So if you are in charge of the 12 surveillance, that means you're in charge of the security as 13 well. So basically I was applying for a position of being a 14 supervisor of the surveillance and the same time in charge of 15 the -- shift when I work in charge of the whole security in 16 casino. 17 Q. All right. How many people did you have working 18 under you at that point? 19 A. On the beginning, between four and five. And our 20 casino operation progress. At one point I was managing 50 21 people. 22 Q. Okay. We're still talking about Holiday Inn here in 23 Vancouver? 24 A. Well, what I mention to you right now, I'm talking 25 about one of the biggest casinos in British Columbia, VICKI HUMPHREY, CSR MANSFIELD, TX METRO(817)477-2035 PROKA AVRAMOVIC 19 1 Coquitlam Casino. That was about a couple of years ago. When 2 we open, I had about 50 people below me. 3 Q. Okay. Let me back up then and just kind of clarify 4 this. When you first took this job as a surveillance shift 5 supervisor, were you still at Holiday Inn at that time? 6 A. Yes. Well, no. Actually I apply when I was at the 7 Holiday Inn, and then as soon as I got promoted, I be 8 transferred to the other Great Canadian location and that was 9 the Renaissance Casino. It's in Vancouver as well. 10 Q. Yeah, we've talked about Renaissance before. So when 11 you first took this job as a surveillance supervisor, you took 12 it at the Renaissance location; is that correct? 13 A. Yes. 14 Q. Okay. And then where did you go from there? I mean, 15 how long were you there at the Renaissance operation? 16 A. Again, about 13, 14, 15 months, a little over a year. 17 Q. All right. And then where did you go from 18 Renaissance? 19 A. I get transferred to Holiday Inn location, back to 20 the Holiday Inn location. 21 Q. Back to the Holiday. 22 A. Yes. I was doing the job of assistant manager there. 23 Q. Assistant manager? 24 A. Yeah. 25 Q. Okay. Now, before we get to that, you said there was VICKI HUMPHREY, CSR MANSFIELD, TX METRO(817)477-2035 PROKA AVRAMOVIC 20 1 a point while you were a surveillance supervisor that you had 2 50 people working for you. Was that while you were at 3 Renaissance? 4 A. No, no. That's later on in my career. 5 Q. Okay. That's later on. Okay. So we've got an 6 intervening thing in here that you took a -- you got 7 transferred back from Renaissance back to Holiday Inn -- 8 A. Yeah. 9 Q. -- with a different kind of job. 10 A. Yes. This time it was assistant manager. 11 Q. Assistant manager of the casino? 12 A. No, assistant manager of the surveillance. 13 Q. Of surveillance. 14 A. Yeah. 15 Q. Okay. 16 A. Which was in charge of the security as well at that 17 time. 18 Q. Okay. Now, I'm trying to understand the framework 19 here. We have the surveillance and security personnel, and 20 there's a shift supervisor as each shift comes and goes; is 21 that correct? 22 A. Yes. 23 Q. All right. And then over that shift supervisor, 24 what's the next level over that? 25 A. Well, see, at each location you supposed to have four VICKI HUMPHREY, CSR MANSFIELD, TX METRO(817)477-2035 PROKA AVRAMOVIC 21 1 to five people who we call management, like management 2 security and surveillance management. Every shift is supposed 3 to run with some guy who has a management level. So usually 4 goes by manager, assistant manager and two to three 5 supervisors. 6 Q. You mean the shift supervisors? 7 A. Yeah. 8 Q. Okay. So the hierarchy there would be the manager at 9 the top -- 10 A. Yeah. 11 Q. -- of surveillance and security, and then he would 12 have an assistant manager under him; is that right? 13 A. Yeah. 14 Q. And then you'd have shift supervisors under the -- 15 A. Yeah. Well, we didn't call them shift supervisors, 16 but basically that's what they're doing. 17 Q. That's what they're doing. 18 A. Yeah. 19 Q. Okay. What did you actually call them, what was the 20 title of them? 21 A. It was security supervisor. 22 Q. Okay. 23 A. Or surveillance supervisor. 24 Q. All right. Fair enough. Okay. So you got 25 transferred back to Holiday Inn this time as an assistant VICKI HUMPHREY, CSR MANSFIELD, TX METRO(817)477-2035 PROKA AVRAMOVIC 22 1 manager of surveillance? 2 A. Of surveillance, yeah, and security. 3 Q. And security. Okay. And how long were you there in 4 that position? 5 A. Well, again, I mean, exact dates, I can probably, you 6 know, go back and see. 7 Q. Well, just -- you know, if you can give me an 8 approximation. 9 A. Again, it's been like around a year doing that. 10 Q. Okay. All right. And what did you do after that? 11 A. After actually Holiday Inn -- Actually I was still at 12 the Holiday Inn when Boki Sikimic, he was the manager there, 13 he got promotion and he became, I believe, director of the 14 security. 15 Q. I see. Now, the director of the security, is that a 16 person that's above the managers? 17 A. Back then we actually had Vane Sebastian, security -- 18 director of security, and Boki Sikimic was director of 19 surveillance. 20 Q. Okay. All right. But these directors, were they 21 over all of the casinos or some of them or what? 22 A. I think Boki -- actually I'm pretty sure that Boki 23 was in charge for everything, every single surveillance in the 24 GCC, and Vane Sebastian was in charge for every single 25 security guy involved in GCC. VICKI HUMPHREY, CSR MANSFIELD, TX METRO(817)477-2035 PROKA AVRAMOVIC 23 1 Q. Okay. You were about to tell me what you did after 2 you left your assistant manager's job at Holiday Inn. 3 A. Well, eventually I became manager of the Holiday Inn. 4 Q. You went on to become manager there. 5 A. Yeah, after Boki moved to the -- 6 Q. After -- Okay. And how long were you manager at that 7 institution? 8 A. I was actually acting manager. I was acting manager 9 for approximately six to seven months. 10 Q. Okay. And then what did you do after that? 11 A. I went to China. GCC bought the ship. Name of the 12 ship was China Sea Discovery. 13 Q. Okay. Now, tell us the details by which you were 14 assigned to that ship, if you would, please, sir. 15 A. The purpose of my trip to Hong Kong was to relieve 16 existing manager there. 17 Q. Okay. I see that you've got some notes there that 18 you're looking at. What are those, please, sir? 19 A. Okay. I'm just going to tell you now the name and 20 the date. 21 Q. Are these notes that you've written down to help 22 refresh your memory? 23 A. Yes, yes. 24 MR. PULLMAN: I want a copy of those notes. 25 Let's just make a copy and let him read off of them and put VICKI HUMPHREY, CSR MANSFIELD, TX METRO(817)477-2035 PROKA AVRAMOVIC 24 1 them in the record. 2 MR. RAY: We can do that now if you want to. 3 MR. PULLMAN: Yeah, let's do it now. 4 MR. RAY: Yeah, let's just go ahead and do that 5 now. 6 THE WITNESS: Can we just do it later? 7 MR. PULLMAN: No, no, no. Want to do it now. 8 MR. RAY: Well, it's a house cleaning deal 9 here. Trust us, we need to go ahead and do it. 10 Q. How many pages are there? 11 A. Just a couple of pages. 12 Q. Okay. Yeah, we need to go ahead and do it now and 13 get it marked. 14 MR. WILEY: Let's take a break. 15 MR. RAY: Yeah, we can take a quick break. 16 (Off the record.) 17 (Deposition Exhibit No. 8 was marked for 18 identification purposes.) 19 MR. RAY: We're back on the record now. 20 Q. Proka, I'm going to show you an exhibit that's been 21 marked Plaintiff's Deposition Exhibit No. 8. Would you 22 identify it for the record, please, sir? 23 A. Yes. It's a little notebook and little notes that I 24 took on April 9th, just a little recollection, mostly the 25 names. VICKI HUMPHREY, CSR MANSFIELD, TX METRO(817)477-2035 PROKA AVRAMOVIC 25 1 Q. Okay. All right. Good deal. You were going -- We 2 were trying to figure out where we left off here. We were -- 3 Do you recall my last question? 4 A. I think it was I've been sent to China. 5 Q. Yeah, what were the circumstances -- I think I asked 6 you what the circumstances were of you being sent to China. 7 A. The reason I've been sent to Hong Kong, China, to the 8 cruise ship, China Sea Discovery, was to relieve existing 9 manager there, security/surveillance manager. His name is 10 Vlada Vasiljeyic. I'm going to try to spell this for you. 11 It's V-l-a-d-a, last name V-a-s-i-l-j-e-y-i-c. He was 12 security and surveillance manager on the ship. 13 Q. Okay. 14 A. His contract was -- his contract was that after six 15 months of working there he's entitled for four weeks vacation, 16 so that was my purpose of going there. 17 Q. Okay. Who was it that hired you to go -- or that put 18 you into the new position at China Sea Discovery? 19 A. I've been asked by director of surveillance, Boki 20 Sikimic, if I'm willing to go and work there for a bit. 21 Q. Okay. 22 A. Originally supposed to be four weeks. I stay there 23 for about seven. 24 Q. All right. Did you work on the ship itself then? 25 A. Yeah. I sail couple of times from Hong Kong, I sail VICKI HUMPHREY, CSR MANSFIELD, TX METRO(817)477-2035 PROKA AVRAMOVIC 26 1 couple of times from China, and mostly we've been stationed at 2 Kaohsiung. That's Taiwan. It's Chinese name. I have it in 3 passport, so I can -- 4 Q. If you've got something you can look at to get the 5 spelling off of, appreciate it; help the court reporter. 6 A. Yeah, they have it here, so... the right spelling. 7 It's K-a-o-h-s-i-u-n-g. Is it I? 8 Q. Let the record show he's reading from his passport 9 entry. 10 MR. PULLMAN: I have no idea. It could be a T 11 even. 12 A. It's second largest city in Taiwan after Taipei. 13 That's what I learn while I was there. 14 Q. Okay. And what were your duties on the ship while 15 you were there? 16 A. Okay. First of all, I arrive in Hong Kong on April 17 the 7th, 2001. 18 Q. Okay. 19 A. And I'm using this little notebook to just recollect 20 memory. 21 Q. Right. 22 A. As soon as I arrive there, I was briefed by security 23 and surveillance manager, Vlada Vasiljeyic, about status of 24 the ship and -- 25 Q. About the what of the ship? VICKI HUMPHREY, CSR MANSFIELD, TX METRO(817)477-2035 PROKA AVRAMOVIC 27 1 A. About the whole status of the ship. 2 Q. Status of the ship. Okay. 3 A. About what was going on on the ship, what to expect. 4 MR. PULLMAN: I think again we're getting 5 outside the range of the motion and I just want to object to 6 protect the record. 7 MR. RAY: Okay. All right. 8 A. Well, I still -- 9 MR. PULLMAN: Can I just have an objection 10 through his whole story in Hong Kong? 11 MR. RAY: To the whole story? You mean as to 12 relevance? 13 MR. PULLMAN: Yeah. 14 MR. RAY: Yeah, I don't have a problem with 15 that. 16 MR. PULLMAN: Thank you. 17 MR. RAY: Okay. Richard, I will -- 18 MR. PULLMAN: I'm also letting you -- I'm 19 letting you lead a little bit too. See what happens when you 20 boil somebody in these rooms. 21 MR. RAY: Richard, I'm just trying to make sure 22 I understand. I'm not trying to lead. 23 MR. PULLMAN: You and me both. Let's just get 24 his story. I'll cross-examine later. 25 Q. Okay. Now, where we left off was you were describing VICKI HUMPHREY, CSR MANSFIELD, TX METRO(817)477-2035 PROKA AVRAMOVIC 28 1 to me what your duties were as manager, and you started out by 2 telling me that you were being briefed by the old manager, 3 so -- 4 A. Yes, right away, as soon as I actually board the ship 5 on April the 7th. April the 7th, the night of April the 7th, 6 it was scheduled sailing to -- usually to nowhere, to just 7 international waters and back. And right before that sailing 8 I was -- he start briefing me about what's going on on the 9 ship and -- 10 Q. Okay. Well, before we get to what's going on on the 11 ship, can you tell me what your duties were as manager? 12 A. Okay. Well, originally I was told that my duty was 13 to just observe casino and casino employees and customers. It 14 turns out that I was managing the whole security on the ship. 15 So basically my duty was like 24/7. 16 Q. Wait a minute. Are you telling me that when you 17 arrived there you were under the impression that you were only 18 going to manage the casinos? Is that what you're saying? 19 A. Yes. 20 Q. Okay. And then when you got there, you found out it 21 was a bigger scope. 22 A. Yes. 23 MR. PULLMAN: So he was originally going to 24 observe the employees, not manage them. 25 MR. RAY: Yeah, I think it was originally VICKI HUMPHREY, CSR MANSFIELD, TX METRO(817)477-2035 PROKA AVRAMOVIC 29 1 limited to casinos and then it expanded to security on the 2 whole ship. 3 A. Yeah, managing security and the surveillance during 4 the casino hours in the casino. 5 Q. Yeah, but after you got there, I think you said -- 6 correct me if I'm wrong -- you said that you found out your 7 job was going to include security for the whole ship then. 8 A. Very soon I found out that -- that my duty's 9 basically 24/7, so even when the casino is closed, I was still 10 in charge of the security on the ship. I was -- you know, 11 call in reports, disputes from the crew. It was about 800 12 people on the ship like crew members. I was also in charge of 13 the -- making sure that everybody comes back on the ship. I 14 was -- 15 Q. "Comes back on the ship" -- excuse me -- what do you 16 mean by that? 17 A. When we not operating, when we're not sailing -- 18 Q. Yes. 19 A. -- there is little ferry boat that comes and picks up 20 whoever wants to go on the shore. So actually I end up now 21 reading all those ship manuals about the security, and I end 22 up searching the people when they're coming back from the 23 ship. 24 Q. What were you -- 25 A. I mean, coming back from the shore, not to bring, you VICKI HUMPHREY, CSR MANSFIELD, TX METRO(817)477-2035 PROKA AVRAMOVIC 30 1 know, some objects, food and those sort of stuff. 2 Q. Is that all you were searching for was food? 3 A. Well, I was searching for like, you know, any 4 weapons, food, alcohol. 5 Q. All right. Did anyone bring back any weapons, try to 6 bring back weapons? 7 A. Well, I run into this situation in China, that 8 people -- passengers were bringing weapons on the ship. But 9 that was later on when we actually went to China. 10 Q. Okay. Well, I guess we need to talk about that now 11 since we've gotten there. Passengers -- You're saying 12 passengers attempted to bring weapons onto the ship. 13 A. Yeah. That was in China. 14 Q. Okay. What did you -- 15 A. Well, actually, for a matter of fact, they were not 16 attempting; they were bringing them on the ship. 17 Q. Well, okay. But, I mean, what did you do about that? 18 A. Well, my staff wasn't armed, so we did not really 19 want to interfere with that. The staff of the ship, like the 20 security staff that I was in charge of, we were never armed, 21 so we never had a firearm, so I mean, obviously it was a smart 22 choice not to bother those people, and I've been advised by 23 one of the GCC representatives, Howard Blank -- 24 Q. Blank? Can you spell his name for us, please? 25 A. Blank. It's B-l-a-n-k, I think. It's B-l-a-n-k, VICKI HUMPHREY, CSR MANSFIELD, TX METRO(817)477-2035 PROKA AVRAMOVIC 31 1 Howard. 2 Q. All right. You were advised by him what? 3 A. He was a GCC representative. I was conducting the 4 search and I notice there was some firearms. We used to have 5 metal detectors in the door that will detect anything -- 6 Q. The door that you walk through that will detect 7 metal? 8 A. Yeah. I noticed that some of the passengers that are 9 boarding the ship, they're armed. 10 Q. And that was in where? 11 A. That was in China. 12 Q. Where in China? 13 A. That was Hainan. 14 Q. Hainan? Okay. 15 A. Hainan, whatever. So of course, I didn't want to 16 interfere. I didn't want to jeopardize, you know, anyone's 17 safety on the ship because, I mean, obviously the custom 18 officer, Chinese custom officer will let them go. 19 Q. Okay. Well, who did you report that to, if anyone? 20 A. I was directly reporting to director of the 21 surveillance. 22 Q. Who was? 23 A. That was Boki Sikimic. 24 Q. Okay. Did you report that to Boki? 25 A. Yeah, I did report every miscellaneous thing. VICKI HUMPHREY, CSR MANSFIELD, TX METRO(817)477-2035 PROKA AVRAMOVIC 32 1 Q. Okay. Now, you mentioned the name Howard Blank. 2 What was he? 3 A. He was there -- I don't think he had any title except 4 he was introducing himself as a GCC representative. 5 Q. Okay. 6 A. So he told me not to bother those people. 7 Q. Okay. So -- 8 A. That it's okay to let them go. 9 Q. Okay. 10 A. So, I mean, I don't take orders from him, but I mean, 11 that was really a natural decision not to bother them. 12 Q. All right. But I think you said you did report it to 13 Boki. 14 A. Yeah, I did report incident to Boki. 15 Q. Okay. Did you make a written report to Boki? 16 A. Yes, I did a written report as well. 17 Q. Okay. Can you remember about when that was that you 18 did that? 19 A. Well, it was definitely in the logbook. It was 20 definitely in a miscellaneous report. The date I can't really 21 recall. Witness to the infraction was right before when 22 actually old manager went back, so he was -- Vlada was witness 23 to that infraction. 24 Q. Okay. These people that boarded the ship with 25 weapons, could you tell what race they were from? VICKI HUMPHREY, CSR MANSFIELD, TX METRO(817)477-2035 PROKA AVRAMOVIC 33 1 A. We're talking about the Asian people, so -- 2 Q. Were they Asian or white or black? 3 A. We were in China, so I strongly believe they're 4 Chinese, Asian. 5 Q. Did they look Asian to you is what I'm asking? 6 A. They were definitely Asian and most likely Chinese. 7 Q. Okay. 8 A. There was a name of the guy who was kind of -- that 9 was his crew is known as Mr. Y, Mr. Y. I never -- 10 Q. Could you spell that? 11 A. I never spell his name. That's just what I heard how 12 people calling him, Mr. Y, so I -- 13 Q. When you say "his crew", what do you mean by that 14 exactly? 15 A. Well, apparently he was well-known as a mobster. 16 Q. A mobster? 17 A. Yeah. 18 Q. Okay. 19 MR. PULLMAN: We object to all this as hearsay. 20 This is going way too far. Move that it be stricken. 21 Q. All right. Now, during the time that you were 22 serving on the ship, you were -- were you paid a salary? 23 A. The people who I relieved had a contract signed by 24 GCC, and I was just there on a regular salary, so I never 25 signed any contract with the GCC, so I was just paid the same VICKI HUMPHREY, CSR MANSFIELD, TX METRO(817)477-2035 PROKA AVRAMOVIC 34 1 as -- 2 Q. All right. Who paid you then? 3 A. I used to have checks by Great Canadian Casinos, 4 Incorporated. 5 Q. While you were on the ship? 6 A. Yeah. 7 Q. Okay. All right. Do you remember what signature 8 was on your checks? 9 A. Well, it was just the normal paycheck like every 10 other employee. 11 Q. Yeah, I know, but do you remember whose signature was 12 on it? 13 A. I can't recall. 14 Q. That's fair enough. Okay. All right. 15 A. I would like to go back now what I was briefed on the 16 first night that -- 17 MR. PULLMAN: I object to that. He's here to 18 answer questions on the table. 19 Q. When you -- Are you talking about the brief by Vlada? 20 A. Yeah, Vlada Vasiljeyic. 21 Q. Okay. What did Vlada tell you on his brief? 22 A. Okay. The very first thing that he mentioned to me 23 was that couple of days before my arrival they had a problem 24 with girls that were working on the ship, and he call them 25 prostitutes. VICKI HUMPHREY, CSR MANSFIELD, TX METRO(817)477-2035 PROKA AVRAMOVIC 35 1 Q. Okay. And what was the problem? 2 A. Somehow those girls were working on the ship and they 3 had the room. He showed me the room. And one of the girls 4 weren't part of the crew, just try -- she was trying to work 5 on her own, so that's why he kick her out. 6 Q. Okay. "Wasn't part of the crew", what do you mean by 7 that? 8 A. Well, my understanding was somebody arranged those 9 girls to be on the ship and work. 10 Q. Do you know who that was? 11 A. No. 12 Q. Okay. All right. Go ahead. 13 A. I also -- I've been told by him that one of the staff 14 employed by Great Canadian has been having a service and 15 paying for the service. 16 Q. What service? 17 A. Well, I guess those girls are prostitutes. I mean, 18 we can just imagine what kind of service. 19 Q. Oh, well, okay. You mean service from the 20 prostitutes. 21 A. Yeah. 22 Q. Okay. And who are we talking about? 23 A. His name is Milo Jovicevic. I can spell that for 24 you. It's M-i-l-o J-o-v-i-c-e-v-i-c. 25 MR. PULLMAN: We're continuing our objection VICKI HUMPHREY, CSR MANSFIELD, TX METRO(817)477-2035 PROKA AVRAMOVIC 36 1 obviously as to prostitutes, but also now we've got hearsay. 2 Q. Okay. All right. 3 A. I also approached the guy personally and I confront 4 him and he admit that to me. 5 Q. Okay. All right. Did you make a report of this to 6 anyone? 7 A. Yes. Everything out of ordinary I was reporting 8 directly, sometimes right away even by the phone to Boki 9 Sikimic, but mostly I was creating reports as well. 10 Q. Okay. Do you know whether there was ever any record 11 kept of your performance with Great Canadian Casinos, Inc. 12 while you were employed with them? 13 A. Well, I'm assuming so. 14 Q. Okay. Did you ever see any copies of those records? 15 A. No. I never ask any receipt. 16 Q. Do you know whether or not you were ever written up 17 for any performance deficiencies? 18 A. I think maybe once. 19 Q. Okay. What was that about? 20 A. I think one of the VCR was stopped. 21 Q. Where was that now? 22 A. That was at the Renaissance. The year, I can't 23 really tell you the year. 24 Q. Okay. While you were at the Renaissance -- Let me 25 see. I've lost track of all these years and everything. You VICKI HUMPHREY, CSR MANSFIELD, TX METRO(817)477-2035 PROKA AVRAMOVIC 37 1 were at the Renaissance fairly early on in your employment, 2 though, weren't you? 3 A. Yeah. 4 Q. Okay. All right. What was the result of that 5 performance deficiency, what happened? 6 A. I think I was -- I just receive one or two day 7 suspension. That was all. And that was the first and last 8 time that I ever had in my nine years. 9 Q. Okay. Did you ever get any commendations of any sort 10 from the company? 11 A. When I was there? 12 Q. Yes. 13 A. Okay. Well, as soon as I arrive there, I board the 14 ship immediately. 15 Q. No, no, I mean -- 16 MR. PULLMAN: Awards. 17 Q. Awards. 18 MR. RAY: Yes, Richard, I should have said that. 19 A. Awards. 20 Q. Yes. 21 A. Well, I don't know what you mean about awards. 22 Q. Well, I mean, did anyone ever give you any reward for 23 doing anything that they considered to be exemplary, I guess? 24 A. When I came back from the ship, I receive some 25 payment which I assuming supposed to make up for that I VICKI HUMPHREY, CSR MANSFIELD, TX METRO(817)477-2035 PROKA AVRAMOVIC 38 1 supposed to stay four weeks and I stay for seven, so on top of 2 my regular paycheck, I receive some -- I can't recall how much 3 was it. 4 Q. All right. Okay. I think you said earlier you were 5 supposed to be on the ship for four weeks, but you wound up 6 being on it for seven; is that right? 7 A. Yeah, I end up being there for seven. 8 Q. Okay. While you were there, did you -- did you have 9 occasion to see who was in charge of the casinos, running 10 them? 11 A. To my knowledge, from very first day, GCC was making 12 every single call. 13 Q. What was their man that was operating as the actual 14 manager? 15 A. When I arrived there, I met with Adrian Thomas. He 16 was president of the company. 17 Q. You met with Adrian Thomas in China? 18 A. Yeah. As soon as I arrive in Hong Kong, I met with 19 Adrian Thomas. I also deliver the check of $900,000.00. 20 Q. All right. The check of $900,000.00, now what was 21 that about? 22 A. I have no idea, just -- I can recall it's been signed 23 by two people. 24 Q. Who were the two people that signed it? 25 A. The one was Grace Su. She's, I believe, director of VICKI HUMPHREY, CSR MANSFIELD, TX METRO(817)477-2035 PROKA AVRAMOVIC 39 1 treasury for Great Canadian Gaming Corporation, and the other 2 one was Brian Egli, at the time vice-president of Great 3 Canadian Casinos, Incorporated. So I deliver the check to 4 Adrian Thomas, the first thing that I did. 5 Q. Okay. What company was the check made on? 6 A. I don't want to speculate on that. 7 Q. If you remember. 8 A. It's either Great Canadian Casinos or Great Canadian 9 Gaming Corporation. 10 MR. PULLMAN: I object to the answer beyond "I 11 don't want to speculate" being nonresponsive. 12 Q. Okay. Who did you deliver this -- who did you pick 13 the check up from? 14 A. I've been given the check by Brian Egli. 15 Q. Okay. In Canada? 16 A. On airport, Brian Egli. 17 Q. Okay. But was that in Canada? 18 A. Yeah, that was in Canada, the Vancouver Airport, 19 right before I left. 20 Q. All right. And who did you deliver it to? 21 A. I deliver personally to Mr. Adrian Thomas. 22 Q. Okay. We're getting back now to again you were about 23 to tell me who the man was that was running things on the ship 24 for Great Canadian Casinos. 25 A. The main guy in Hong Kong and all the way to China VICKI HUMPHREY, CSR MANSFIELD, TX METRO(817)477-2035 PROKA AVRAMOVIC 40 1 and then run off the ship was Walter Soo. 2 Q. Okay. Now, did Walter -- 3 A. He was director of project or something like that. 4 Q. Okay. Did Walter Soo stay on the ship while it was 5 operating? 6 A. He was on and off. Sometimes he was on the ship, 7 sometimes he was off the ship. 8 Q. Even when it was sailing, sometimes he was off of it? 9 A. Yeah. 10 Q. Okay. All right. Was anyone on the ship all the 11 time that it was sailing acting for the corporation? 12 A. We had the club director. His name is Dennis Kwan, 13 last K-w-a-n. He was club director, Club 21 director. I 14 can't really recall what was the exact name of the casino on 15 the ship. He was the director of the casino operation. 16 Q. All right. What did this Dennis Kwan do? 17 A. He was clearly following the orders of Walter Soo. 18 MR. PULLMAN: Object to the answer as being 19 nonresponsive. 20 Q. But what did he actually do, though, is what I'm 21 asking? 22 A. He was assigned to be club director, running casino 23 operation day-to-day basis, operating casino, running casino 24 through like, you know, opening hours, closing the casino. 25 Q. All right. What led you to believe that he was VICKI HUMPHREY, CSR MANSFIELD, TX METRO(817)477-2035 PROKA AVRAMOVIC 41 1 following the directions or orders of Walter Soo? 2 A. They were pretty strict and you could tell that -- 3 who was really in charge and who was making the calls. 4 Q. Okay. 5 A. Our department didn't report to Walter Soo, though. 6 MR. PULLMAN: Object to the answer as being 7 nonresponsive. 8 Q. I'm sorry. What did you say? 9 A. We never report to Walter Soo. 10 MR. PULLMAN: Object to the answer as being 11 nonresponsive. The question on the table is what made you 12 believe that he reported to Walter Soo. 13 A. I was pretty sure, though. 14 MR. PULLMAN: Object to all that stuff and ask 15 that it be stricken from the record also. 16 Q. Okay. Let's see. When you arrived on the ship, did 17 anyone tell you that you were supposed to ignore normal 18 company policies as to how the casinos were run? 19 A. Well, first of all, we didn't have any policies. I 20 never saw anything like it. 21 Q. You never saw anything like what? I'm sorry. 22 A. It was such unorganize. Lots of suspicious thing 23 during the operating hours. 24 Q. Like what, for instance? 25 A. They used to call them junket players. Surveillance VICKI HUMPHREY, CSR MANSFIELD, TX METRO(817)477-2035 PROKA AVRAMOVIC 42 1 just receive a phone call and we've been telling by Dennis 2 Kwan or someone from the cage that they're going to be giving 3 them some sum, like some money to them. We didn't know who 4 those people are. We didn't know if they return the money 5 later on or not. 6 Q. Well, where was the money given to them? 7 A. Well, that was the funny part because we were there 8 not to ask questions. We were there to just observe and 9 report. So we did report those discrepancies to our 10 director. We had a problem because we didn't know exactly 11 names who -- 12 Q. You didn't recognize these individuals? Is that what 13 you're saying? 14 A. Well, most of the times the money was given to the 15 individuals that we didn't know. 16 Q. Okay. Where did they go to get it, though? 17 A. We asked for explanation. 18 Q. No, no, no. Where did they go to actually get the 19 money? 20 A. Well, they supposed to go to play, but we notice that 21 few times the people just receive the money from the cage and 22 they just left. 23 MR. PULLMAN: Object to the answer as being 24 nonresponsive. 25 Q. Did they go into the cage? VICKI HUMPHREY, CSR MANSFIELD, TX METRO(817)477-2035 PROKA AVRAMOVIC 43 1 MR. PULLMAN: Object to the question as being 2 leading. The question is, where did they get the money. 3 MR. RAY: I know what the question is. 4 MR. PULLMAN: Well, he apparently doesn't 5 because he -- 6 A. Okay. They went to the cash cage and they've been 7 paid by cashier person, and sometimes they go and play and 8 sometimes they just go and disappear. 9 Q. Okay. When they went in and they got money from 10 wherever they got it, did you observe whether or not they 11 signed anything in connection with getting the money? 12 A. According to the -- my knowledge, I never saw any of 13 those junket players signing anything either when they take 14 the money or when they return the money. 15 Q. Okay. All right. Was there a person that actually 16 managed the cage? 17 A. Yeah. That was the responsibility of Dennis Kwan. 18 Q. Okay. Excuse me. Was anyone else in there with him? 19 A. It was his crew. His crew, I mean the people from 20 Great Canadian. 21 Q. Great Canadian Casinos, Inc.? 22 A. Yeah. They were employed by Great Canadian Casino as 23 a cashier or cage manager, but they were working for Dennis 24 Kwan. 25 Q. Dennis Kwan was their supervisor? VICKI HUMPHREY, CSR MANSFIELD, TX METRO(817)477-2035 PROKA AVRAMOVIC 44 1 A. Well, he was director of the casino club. 2 Q. Okay. All right. Did you -- You said earlier that 3 you made reports to Boki. 4 A. Yeah, only to Boki. 5 Q. All right. What would cause you to make a report to 6 Boki? 7 A. Anything out of the ordinary, like -- well, it was 8 funny because I probably send lots of reports and spend lots 9 of time -- I mean, lots of -- almost every day I had to 10 actually call him and report something because it was a real 11 mess. So there wasn't any procedures set for security, wasn't 12 any procedures set for dealers stuff. So it was a real mess. 13 Q. Okay. In your previous operations in security and 14 surveillance, did you make as many reports, say, on a weekly 15 basis as you did with the China Sea Discovery? 16 A. No. 17 Q. Can you give me some kind of an estimate or idea of 18 how many reports you made on a weekly basis while you were on 19 China Sea Discovery? 20 A. Well, every time when we sail the ship, we open the 21 casino, so it's like I've been sending three to four reports 22 on average. 23 Q. On the average per week? 24 A. No, per sailing period, like per night. 25 Q. Per sailing. Okay. How long would a sailing last VICKI HUMPHREY, CSR MANSFIELD, TX METRO(817)477-2035 PROKA AVRAMOVIC 45 1 typically? 2 A. Usually for a night. We sail for like, say, ten 3 hours. 4 Q. So what you're telling me -- I'm trying to under -- 5 You're telling me that you were making three or four reports 6 every time the ship goes out? Is that what you're saying? 7 A. Yeah. 8 Q. Okay. How many times did the ship go out while you 9 were on board? 10 A. Okay. The first time, the very first night on the 11 7th, we just -- we sail and we came back the next day on April 12 the 8th. Then on the following day, April the 9th, we went to 13 China and that island Hainan, I think. 14 Q. Yeah. 15 A. And I don't know exactly days there, but I remember 16 sailing from China to Vietnam, I believe, a couple of times. 17 Q. Okay. All right. When you worked with Great 18 Canadian -- 19 MR. PULLMAN: Object to the answer as being 20 nonresponsive. 21 Q. Okay. Can you tell me exactly how many times the 22 ship sailed while you were on board? 23 A. Okay. It was -- 24 Q. Just how many times. You can think about it for a 25 while if you need to. VICKI HUMPHREY, CSR MANSFIELD, TX METRO(817)477-2035 PROKA AVRAMOVIC 46 1 A. Okay. Once from Hong Kong to nowhere and back, just 2 international waters and back, and from China twice to 3 Vietnam. 4 Q. Okay. Is that it? 5 A. Yeah. The rest of the time was spend docking in 6 Kaohsiung and Taiwan. 7 Q. Okay. While you were docking, was there any 8 gambling? 9 A. No. 10 Q. Okay. With your previous employment with Great 11 Canadian Cruises (sic) before you got on the ship, were people 12 allowed to come into the cage and take money without signing 13 for it? 14 A. Well, to my knowledge, no. I never witness anything 15 like it, you know. That wasn't a GCC practice. 16 Q. Okay. Do you remember how many tables there were on 17 the ship approximately? 18 A. Say 26, maybe more. 19 Q. Okay. What kind of tables were they? 20 A. Baccarat, blackjack, sic/bo, pai gow. 21 Q. That's that same thing that Boki said. I don't know 22 what it means. 23 COURT REPORTER: Would you spell those last two? 24 THE WITNESS: Pai gow, it's p-a-i -- pai gow. 25 It's a Chinese name. VICKI HUMPHREY, CSR MANSFIELD, TX METRO(817)477-2035 PROKA AVRAMOVIC 47 1 COURT REPORTER: What was the other one, though, 2 you said before that? 3 THE WITNESS: Sic/bo? 4 COURT REPORTER: Yeah. How do you spell that 5 one? 6 THE WITNESS: It's s-i-c slash b-o. Some type 7 of Chinese game. 8 Q. Can you tell me on average how many -- what the 9 number of gamblers there were per sailing? 10 A. The biggest sailing that I attend was 1200 11 passengers. So casino was averaging between seven and 800 12 people at that time. 13 Q. Okay. Was the flow of money into the ship comparable 14 to the other casinos within the Great Canadian Casinos 15 operation on a per sailing, per night basis? 16 A. We're still talking about the ship, right? 17 Q. Yeah, ship. 18 A. Well, it's funny because surveillance was supposed to 19 know how much money was exactly in the safe and how much money 20 is exactly in float. We were rarely informed of the money. 21 We never actually witnessed anything. We've been just told 22 how much money was there. The money's being taken away by 23 Dennis Kwan to the shore and he was coming back with them. I 24 guess they trust that guy so much because -- 25 MR. PULLMAN: Object to every bit of that as VICKI HUMPHREY, CSR MANSFIELD, TX METRO(817)477-2035 PROKA AVRAMOVIC 48 1 being nonresponsive. 2 Q. All right. So -- 3 MR. PULLMAN: Move that it be stricken. 4 Q. Are you telling me that -- 5 MR. PULLMAN: Leading. 6 Q. I'm trying to understand what you're telling me 7 here. Were you aware of how much money was coming into the 8 ship? 9 A. No. 10 Q. Okay. Is that -- Was that a usual practice with 11 Great Canadian Casinos in Canada and their operations? 12 A. I used to manage four different places, and I was 13 always able to tell how much money is at any given time in 14 casino and how much is casino float. 15 Q. How were you able to do that? 16 A. We kept the paperwork in surveillance room, and if 17 it's required, we will just go and find that information. 18 Q. Are you telling me that was part of your job? 19 A. That was part of my job as well. 20 Q. But you didn't do that on the ship? 21 A. No, we never had -- we never had the knowledge of how 22 much money was in and out. 23 Q. Okay. Did you make a report about that to anyone? 24 A. Several times. 25 Q. Who did you make the report to? VICKI HUMPHREY, CSR MANSFIELD, TX METRO(817)477-2035 PROKA AVRAMOVIC 49 1 A. Again, I strictly report to Boki and no one else. 2 Q. All right. Can you give me any kind of indication as 3 to why you weren't told how much money there was flowing into 4 the ship? 5 MR. PULLMAN: Asked and answered. 6 Q. You can answer the question. 7 A. Can you -- 8 Q. Did anyone ever tell you or give you some kind of 9 information as to why you weren't being able to find out how 10 much money was flowing into the ship? 11 MR. PULLMAN: I object to the question as 12 being -- 13 A. No. 14 MR. PULLMAN: Excuse me. I'm making an 15 objection. 16 THE WITNESS: Objection for the record and my 17 answer is for record as well. 18 Q. Go ahead. 19 MR. PULLMAN: I object to the question as it's 20 already been asked and answered. 21 Q. Okay. All right. You can answer it now. 22 A. Well, I did answer it. 23 MR. PULLMAN: That answer didn't count. 24 Q. I didn't hear your answer. I'm sorry. 25 A. No, nobody ever gave us explanation why. VICKI HUMPHREY, CSR MANSFIELD, TX METRO(817)477-2035 PROKA AVRAMOVIC 50 1 Q. All right. Thank you. While you were on the ship, 2 did you have any occasion to observe what the cost of goods 3 and services were that were being provided to the ship? 4 A. No. 5 Q. Okay. Have you ever heard of a company called 6 Mexteam? 7 A. Yes. 8 Q. Okay. What can you tell me about Mexteam? 9 A. I saw couple of business cards of Howard Blank and 10 Tom Bell. They have business cards. They had the business 11 cards with their name on it and the company name was -- 12 Q. Mexteam? 13 A. Yeah, Mexteam. 14 Q. Are you telling me that Howard Blank had a business 15 card with Mexteam on it? 16 A. Yeah. 17 Q. All right. 18 A. And what's the other guy? Tom Bell. 19 Q. Tom Bell? Okay. Is there anything else you can tell 20 me about Mexteam? 21 A. To my impression, all purchase for the ship went 22 through that company. 23 Q. Mexteam? 24 A. Yeah. 25 Q. Okay. Did you have anything to do with that? VICKI HUMPHREY, CSR MANSFIELD, TX METRO(817)477-2035 PROKA AVRAMOVIC 51 1 A. No. 2 Q. Okay. Are you familiar with a gentleman named Gary 3 Lu? 4 A. Yes. 5 Q. Okay. How do you know Gary Lu? 6 A. First I met the guy at -- he was playing at one of 7 our location. 8 Q. Do you remember what location it was? 9 A. Richmond whenever I used to deal. 10 Q. Okay. Do you remember about when that -- 11 approximately what year that was? 12 A. '95, '96. 13 Q. Okay. 14 A. He became -- obviously he became really good friend 15 with Adrian Thomas. To my knowledge, he didn't have anything 16 to do with the Great Canadian there in Vancouver in Canada, 17 but he was investor in the China Ship Discovery. I don't want 18 to speculate on the numbers, how much he invest. 19 Q. No, I'm not asking you that. Did you actually ever 20 see Gary Lu on the ship? 21 A. Yes, I do. He actually played there too. 22 Q. Okay. Did you observe him doing anything else on the 23 ship besides playing? 24 A. Well, he was playing when I was in Hong Kong and when 25 we moved to Taiwan he was taking over operations there in VICKI HUMPHREY, CSR MANSFIELD, TX METRO(817)477-2035 PROKA AVRAMOVIC 52 1 Taiwan. 2 Q. Were you there when he took over operations in 3 Taiwan? 4 A. Yes. 5 Q. Okay. Can you tell me what happened there? 6 A. Well, we run away from China from the Mr. Y guy. 7 Q. Wait a minute. You ran away from China, what do you 8 mean by that? 9 A. Well, we had an unpleasant experience in China like I 10 mention before. We had real trouble with Mr. Y, that mob 11 guy. He's been threatening some of the Great Canadian 12 employees there, to be more specific, Walter Soo, Grace Chow, 13 Tyrone White and Dennis Kwan. They, I mean, literally ran off 14 the ship. 15 Q. They literally did what? I'm sorry. 16 A. Like ran off the ship. 17 Q. They ran off the ship? 18 A. Yeah. 19 Q. Okay. Because of Mr. Y? 20 A. Yeah. I mean -- 21 Q. All right. 22 MR. PULLMAN: No, I want him to finish. He said 23 "I mean" and you cut him off. 24 A. Mr. Y was making some demands about the money that he 25 invest and Walter Soo tried to resolve the issues, then Walter VICKI HUMPHREY, CSR MANSFIELD, TX METRO(817)477-2035 PROKA AVRAMOVIC 53 1 Soo's being threatened by him. 2 Q. Being what by him? I'm sorry. 3 A. Threatened. 4 Q. Threatened. Okay. 5 A. Okay. Mr. Y wanted money back in order to free the 6 ship from China. Right after that meeting, the whole GCC crew 7 just disappear, like ran off. The only guys who's staying on 8 the ship were myself and my assistant, Chris Prayley. 9 Q. Can you spell his name for us? 10 A. Okay. Chris Prayley. It's P-r-a-y-l-e-y. 11 Q. Okay. And then what happened after they left the 12 ship? 13 A. Like I receive my passport and I receive the plane 14 ticket of Hainan to Vancouver, actually Hong Kong, Hong Kong, 15 Vancouver, and I wasn't aware that I was going anywhere. So I 16 made the call to again my director and I was asking him what 17 was going on and -- 18 Q. You mean Boki? I'm sorry. 19 A. Yes. He didn't have explanation, and he says as far 20 as he's concerned that myself and assistant are staying and 21 those guys, they can go and run away. 22 Q. Okay. And then what happened after that? 23 A. Well, then GCC send another guy. His name was Jim 24 Slater. 25 Q. Okay. Can you give us the spelling on that name? VICKI HUMPHREY, CSR MANSFIELD, TX METRO(817)477-2035 PROKA AVRAMOVIC 54 1 A. It's Jim Slater. It's S-l-a-t-e-r. He's supposed to 2 replace Dennis Kwan as director of the club. 3 Q. All right. And then what happened then? 4 A. It was standby situation for about three to four 5 days. I've been called to cabin of the captain, Captain 6 Sococ. He was Greek. 7 Q. Can you spell that name? 8 A. I believe it's S-o-c-o-c. He was captain of the 9 ship. 10 Q. Okay. 11 A. He was asking me what we going to do, if GCC is going 12 to pay their guys so that we can -- Mr. Y so we can just free 13 the ship and go. And he also had the conversation with Jim 14 Slater. I've been trying to find out what's going on. Boki 15 wasn't aware of, you know, what's going on. I even call 16 couple of times, you know, captain's cabin. I didn't give him 17 any answers because I didn't know any answers. 18 Q. Okay. What happened after you had these discussions 19 with the captain? 20 A. After about three or four days, I've been informed 21 that now we are free to go. 22 Q. Okay. Who told you that? 23 A. I heard that from Captain Sococ. 24 Q. Okay. And then what did you -- what happened? 25 A. Well, we just sailed to Taiwan. VICKI HUMPHREY, CSR MANSFIELD, TX METRO(817)477-2035 PROKA AVRAMOVIC 55 1 Q. Okay. And when you arrived in Taiwan -- How long was 2 it from the time you left until you arrived in Taiwan? 3 A. I think it's about two days trip. 4 Q. Okay. And when you arrived in Taiwan, what happened? 5 A. As soon as we got there, we actually had Mr. Gary Lu, 6 he was boarding the ship. Shortly after that, Adrian Thomas 7 show up. He arrive from Vancouver. And it was clear to me 8 that they try to start running operations from Taiwan. I 9 noticed that Gary's father -- I can't recall his name -- he 10 was getting involved as well, and they were starting preparing 11 the ship for future sails. 12 Q. Okay. How long did you remain on the ship after it 13 arrived in Taiwan? 14 A. Probably a couple of weeks. 15 Q. Okay. What did you do while you were in Taiwan? 16 Same thing or what? 17 A. We didn't do actually anything. We just stay on the 18 ship. We just -- we keep maintaining our cameras and VCRs and 19 we didn't have a float. 20 Q. Was the casino operating during that time? 21 A. No, casino was -- actually nothing was operating. 22 Q. When you say you didn't have a float, would you tell 23 me what that means for the record, please, sir? 24 A. Well, float means casino float. It's operating funds 25 that casino would operate like you -- to open a casino for VICKI HUMPHREY, CSR MANSFIELD, TX METRO(817)477-2035 PROKA AVRAMOVIC 56 1 business, you have to have some certain amount of money to 2 back up the chips that you have on the floor. So that's what 3 we call a float. 4 Q. Okay. When did the float disappear? 5 A. The float disappear together with -- when GCC staff 6 took off. 7 Q. You mean -- Okay. Are you talking about -- 8 A. China. 9 Q. Back in China. Okay. Is that when Walter Soo and 10 them left the ship or was it some other time? 11 A. No, that was the time when they left the ship. The 12 funny thing is the money was on and off, so I cannot tell you 13 exactly when the money actually leave the safe because we're 14 never aware of when the money was going in. 15 MR. PULLMAN: I object to all of that as being 16 nonresponsive except for the part he doesn't know. 17 A. Can I make clear that now? What was the question? 18 Q. That's okay. That's all right. Let's see. Do you 19 know -- All right. Scratch that. What were the circumstances 20 surrounding your leaving the ship? Can you tell me that? 21 A. The manager, whoever, leave. He came back. So he 22 spend about a week and a half in Taiwan together with me. 23 They didn't know what they were going to do with the ship, so 24 Boki tried to extend my stay there. I didn't have no 25 contract, I didn't have no insurance or anything. I was out VICKI HUMPHREY, CSR MANSFIELD, TX METRO(817)477-2035 PROKA AVRAMOVIC 57 1 of Canada, so I just refused to stay there unless they offer 2 me a contract, so I came back. 3 Q. All right. Do you remember -- do you remember the 4 approximate day you left the ship? 5 A. I believe it was May 25th, 2001. 6 Q. How was your traveling back arranged? 7 A. GCC paid for a ticket. Well, actually I had the 8 return ticket. 9 Q. Oh, you still had -- Okay. All right. 10 A. So I flew from Kaohsiung to Hong Kong, Hong Kong to 11 Vancouver. 12 Q. All right. When you got back to Canada, were you 13 still employed by GCC? 14 A. Yes, I was. 15 Q. Okay. What did you do then? 16 A. I went back to my previous position and I was acting 17 manager of the Holiday Inn Casino. Shortly after that, I've 18 been manager of the new location, Coquitlam Casino. 19 Q. Shortly after that. How long? 20 A. We can find that out when Coquitlam location opened. 21 October 2002. 22 Q. Okay. And you became -- I'm sorry. You became 23 manager of -- 24 A. Manager of security and surveillance for the whole 25 casino, and I had about 50 people working around me. VICKI HUMPHREY, CSR MANSFIELD, TX METRO(817)477-2035 PROKA AVRAMOVIC 58 1 Q. Okay. Are you talking about the job that Boki had? 2 A. No. 3 Q. I'm getting a little bit confused here. 4 A. Okay. Well, during this period, casino operation in 5 Vancouver expand, right, meaning whole British Columbia. So 6 when I was -- when I started, we used to have two people on 7 the floor and two people in the room, so it was four people. 8 According to the new regulations, now we have way more 9 customers, the square footage of the casino gaming floor is 10 bigger, we have slot machines. So according to the 11 regulations by government, we supposed to employ now way more 12 people. 13 Q. Okay. 14 A. So we're talking about 3500 square feet. 15 Q. Yeah. Okay. 16 A. Actually 35,000 square feet building, casino floor. 17 Q. At this one casino that you're manager of. 18 A. Yeah. 19 Q. Yeah, I think Boki was director. I was getting that 20 confused. 21 A. Well, he's the director. 22 Q. Yeah, he's the director. You were the manager of 23 this casino. Is that what you're saying? 24 A. I was the manager of the security and surveillance. 25 Q. Okay. As of October of -- VICKI HUMPHREY, CSR MANSFIELD, TX METRO(817)477-2035 PROKA AVRAMOVIC 59 1 A. I don't know what time they opened. 2 Q. Do you remember what year it was, though? 3 A. 2001, I think, or 2002. 4 Q. All right. How long were you in that post? 5 A. For about a year. 6 Q. Okay. And then where did you go from there? 7 A. I went back to manager of Renaissance Casino. 8 Q. Okay. And how long were you there? 9 A. I was there for again about a year. 10 Q. Okay. And then where did you go from there? 11 A. I transfer -- they transfer me again back to the 12 Holiday Inn as a manager all the time. 13 Q. Okay. And how long were you there that second time? 14 A. Since I asked to be released, which is June the 24th. 15 Q. June 24th of -- 16 A. 2003. 17 Q. All right. Did you have a severance agreement with 18 Great Canadian Casinos? 19 A. Yes, I did. 20 Q. Okay. I think we talked about that while ago. 21 MR. PULLMAN: Exhibit 7. 22 Q. Right, we've already identified that. Okay. Who 23 proposed the severance agreement? 24 A. I advise vice-president, Brian Egli, that I'm not 25 going to be able to work for Great Gaming Casino anymore. VICKI HUMPHREY, CSR MANSFIELD, TX METRO(817)477-2035 PROKA AVRAMOVIC 60 1 Q. Yes, but who proposed the severance agreement is what 2 I'm asking. 3 A. Brian Egli and he asked me to agree with a sum -- I 4 mean, an amount and I did agree. 5 Q. Okay. What caused you to terminate your employment 6 with Great Canadian Casinos, Inc.? 7 A. Well, several -- it was -- the main purpose of me 8 leaving Great Canadian Casino was I didn't want to get 9 involved in some stuff that they were illegal. 10 Q. Okay. What are you talking about specifically? 11 MR. PULLMAN: Object to all of this as being 12 irrelevant to -- 13 A. Specifically -- 14 MR. PULLMAN: Excuse me. 15 THE WITNESS: I'm sorry. 16 MR. PULLMAN: Object to this as being irrelevant 17 to the issues before this court. 18 Q. Okay. Go ahead. 19 A. Okay. Specifically -- 20 THE WITNESS: You don't have to scream. I can 21 hear you. 22 A. Loan sharks activities, selected barring of loan 23 sharks. 24 Q. Loan shark activities, can you tell me what you're 25 talking about there? VICKI HUMPHREY, CSR MANSFIELD, TX METRO(817)477-2035 PROKA AVRAMOVIC 61 1 A. Loan sharks are the people who lend money to the 2 customers, to the gamblers, and they are charging some amount 3 back, like, for instance, if they lent you $5,000.00 today, 4 you're going to owe them 6,000 tomorrow and you progress by 5 week. 6 Q. Okay. What was your problem with these activities? 7 A. Well, I notice that the company and some people at 8 the head office, including my director, were very selective 9 who they're going to bar. 10 Q. Who they were going to what? I'm sorry. 11 A. Who they're going to bar, mean -- 12 Q. I'm still not understanding what -- who they're going 13 to -- 14 A. Bar. 15 Q. Bar. Okay. 16 A. So some loan sharks were allowed to stay and some 17 small-timer loan sharks were asked to leave. We also collect 18 evidence that one of the casino lead manager, Ellis McLean, 19 Ellis McLean, M-c-L-e-a-n, was involved in this transaction 20 and he was borrowing money of them. We also report that one 21 of the loan sharks rape one of the dealers which never been 22 report to authorities, never been investigate. I've been 23 reporting that illegal cigarettes have been selling at the 24 Holiday Inn concession casino. 25 MR. PULLMAN: Object to this response also as VICKI HUMPHREY, CSR MANSFIELD, TX METRO(817)477-2035 PROKA AVRAMOVIC 62 1 being irrelevant to the issues before this case today. 2 Q. Were you making reports about these things to your 3 superiors? 4 A. Yes, I do, and I always report straight to Boki, and 5 to me appears he was covering up or someone was covering up 6 because the authorities were never aware of such incidents. 7 Q. Okay. Were there any other reasons for your 8 termination of your employment? 9 A. The guy who supposed to relieve -- I mean, take 10 Boki's position, Patrick Ennis, he was the guy who offered me 11 drugs. 12 Q. Who offered you drugs, did you say? 13 A. Yeah. 14 MR. PULLMAN: Object to this as being 15 nonresponsive and irrelevant to the issues before the court 16 today. Move it be stricken. 17 A. I made several reports regarding this. 18 Q. You made several reports regarding what? I'm sorry. 19 A. That I've been offering to use drugs by Pat Ennis. 20 Q. All right. Were there any other reasons that you 21 decided to terminate your employment? 22 A. Well, I just -- I just couldn't take it any more 23 because some people were probably getting into some illegal 24 stuff that I didn't really want to be part of. 25 Q. Okay. VICKI HUMPHREY, CSR MANSFIELD, TX METRO(817)477-2035 PROKA AVRAMOVIC 63 1 A. And I did contact the authorities back home as well. 2 Q. All right. Let me just jump back to the cruise ship 3 just real quickly. Did you ever see a fellow by the name 4 of -- Well, scratch that. Are you familiar with a person 5 named Steven Ming? 6 A. Steven Ming, yes, I am. I met the guy in Hong Kong. 7 He's the son of Charles Ming. 8 Q. Okay. Did Steven Ming ever come onto the ship while 9 you were there? 10 A. He was on the ship the day that -- right before when 11 we sail to China. I would say April the 9th, 2001. 12 Q. Okay. And what did you -- what was he doing? 13 A. I can't tell you that. I mean, I don't know. 14 Q. You just saw him on the ship. 15 A. He was acting like that he's -- I don't know. I 16 don't really know what was his position. 17 Q. Okay. How many times did you see him come on the 18 ship while you were on the ship? 19 A. Just once. That was the first and last time. I 20 notice that he forget his stuff on the ship and then he phone 21 couple of times and ask Vlada, the manager, to put it in a box 22 and send those things to him back to Hong Kong. 23 Q. All right. Is that all you know about Steven Ming? 24 A. Yeah. 25 Q. Okay. Who is Grace Chow? I think that's spelled VICKI HUMPHREY, CSR MANSFIELD, TX METRO(817)477-2035 PROKA AVRAMOVIC 64 1 C-h-o-w. I'm not positive. 2 A. C-h-o-w, yeah. Grace Chow was -- he was director 3 of -- 4 Q. That's a he or a she? 5 A. It's a she. Actually Grace Chow. She was director 6 of the cage operations. 7 Q. On the ship? 8 A. Well, I don't know what was her title on the ship, 9 but back home she was the cage director, director of the cage. 10 Q. All right. Did you see her on the ship? 11 A. Yeah, I saw her on the ship. 12 Q. Okay. And what was she doing when you saw her on the 13 ship? 14 A. She was with Walter Soo all the time and -- 15 Q. What did she do with Walter Soo? 16 A. They've been seen together and apparently they've 17 been having affair and we have -- 18 MR. PULLMAN: Object to that as being 19 nonresponsive. 20 MR. RAY: I'm asking what she was doing with 21 him. 22 MR. PULLMAN: What did he see her doing with 23 him. 24 A. Well, she was spending the time with Walter Soo, and 25 according to our statements, she's been having affair with VICKI HUMPHREY, CSR MANSFIELD, TX METRO(817)477-2035 PROKA AVRAMOVIC 65 1 Walter Soo, and that was well documented by tapes and reports. 2 MR. PULLMAN: Object to that as being 3 nonresponsive. 4 Q. Okay. 5 MR. PULLMAN: Move to strike. 6 Q. Do you know what -- do you know if she served any 7 function on the ship other than with Walter Soo? 8 A. Well, obviously she was working whatever Walter Soo 9 was telling her, but to be specific what was her purpose 10 there, I can't tell you. 11 Q. Okay. You weren't able to make that determination; 12 is that what you're saying? 13 A. No. 14 Q. Okay. Let me see. 15 MR. RAY: Gentlemen, if we can take a brief 16 break here, I think I may be able to wrap this thing up pretty 17 soon. 18 (Off the record.) 19 Q. Just a few more questions, Proka. You mentioned 20 earlier -- and I can't remember this guy's last name -- 21 Patrick. Do you remember his last name? Well, the one that 22 you said that offered you drugs. 23 A. Yeah. And I did report that several times. 24 Q. Okay. What kind of drugs were you offered? 25 A. To my knowledge, it was cocaine. VICKI HUMPHREY, CSR MANSFIELD, TX METRO(817)477-2035 PROKA AVRAMOVIC 66 1 Q. Okay. 2 A. His last name is E-n-n-i-s. 3 Q. Okay. Patrick Ennis. Okay. You were giving me a 4 list of what you described as illegal activities that prompted 5 your resignation from Great Canadian Casinos, Inc. To the 6 extent that you haven't already done so, can you list any 7 more? Are there any more that you haven't listed? 8 MR. PULLMAN: My old objection's still good. 9 MR. RAY: Yeah, I understand, Richard, yeah. 10 MR. PULLMAN: Thank you. 11 Q. I'm not talking to reiterate what you've already 12 said. 13 MR. PULLMAN: Please. It's 4:30. 14 Q. I'm just saying if there's any more, you know, that 15 you forgot. 16 A. One of the security/surveillance managers meeting, 17 I've been advised by my director, who was Boki Sikimic, that I 18 supposed to direct my people to turn their heads the other way 19 when they see those big loan sharks around because that's good 20 for business. I also been advised by -- someone else was 21 present on that meeting. It was Carl Bolton, who's sitting 22 right there. 23 Q. You mean Carl Bolton in this room? 24 A. Yeah. He's been explaining how to avoid to report 25 everything to the authorities. VICKI HUMPHREY, CSR MANSFIELD, TX METRO(817)477-2035 PROKA AVRAMOVIC 67 1 Q. To what authority, for instance? 2 A. For instance, British Columbia Lottery Corporation 3 and GPEB. That's -- 4 Q. Is that GBEP? 5 A. It's G-P-E-B. 6 Q. Okay. All right. Anything else? 7 A. I knew that -- you know, after that meeting that I 8 don't want to work for company that start covering up in 9 excuse of doing a good business, covering up some illegal 10 activities. 11 MR. PULLMAN: Object as being nonresponsive and 12 move it be stricken. 13 Q. Okay. When you -- when you got ready to leave the 14 ship that we talked about earlier, was it necessary for you to 15 become engaged in any kind of operations to gather up your -- 16 the documents that you had accumulated and everything there? 17 A. Yeah. In Taiwan, as soon as we -- as soon as Vlada 18 came back, the manager who came back from the vacation, we 19 went over there to start preparing and packing all audit -- 20 Q. Packing what? I'm sorry. 21 A. All paperwork and all audit. 22 Q. Audits? 23 A. Audits from like casino operation and send to 24 Vancouver. 25 Q. Send to where? I'm sorry. VICKI HUMPHREY, CSR MANSFIELD, TX METRO(817)477-2035 PROKA AVRAMOVIC 68 1 A. To Vancouver. 2 Q. Okay. Who ordered you to do that? 3 A. I had order directly from Boki. 4 Q. Okay. And -- Okay. Who did you send this stuff to 5 in Vancouver? 6 A. Vlada and I, we pack, and then he went to post office 7 and send -- I believe that he send to Brian Egli. 8 Q. Okay. And what was the volume of stuff that was 9 sent? How much stuff? 10 A. I would say approximately about -- between six and 11 ten boxes. I can't recall. 12 Q. All right. Give me an idea of the size of each box. 13 A. It's -- 14 Q. Can you tell me how many feet by how many feet, how 15 many feet high, how many feet wide, how many -- that sort of 16 thing? 17 A. Say maybe this, feet and a half by feet and a half. 18 Q. She can't record that. 19 MR. PULLMAN: He said a foot and a half by a 20 foot and a half. 21 Q. Foot and a half by foot and a half? 22 A. Yeah. 23 Q. Do you normally think of in feet or do you think in 24 metric -- are you used to metric? 25 A. Well, I'm aware of how big feet and a half is. So I VICKI HUMPHREY, CSR MANSFIELD, TX METRO(817)477-2035 PROKA AVRAMOVIC 69 1 could go by feet and a half by feet and a half. 2 Q. A foot and a half by a foot and a half, you say? 3 A. Yeah. 4 Q. Okay. What was included in those materials generally 5 speaking? Like, for instance, papers, videos, whatever? 6 A. All paperwork, all cash transfer slips, revenue 7 reports, we sent some equipment as well, some VCRs, some 8 shuffling machines, some cameras. 9 Q. Did you send the tapes with the cameras too? 10 A. I'm sorry? 11 Q. The tapes that were made, did you send any of those? 12 A. All those miscellaneous tapes has been sent to 13 Vancouver. Actually Vlada took possession of those tapes, I 14 believe, when he was leaving the ship and he give that to 15 Boki. 16 Q. Okay. All right. 17 A. Miscellaneous tapes, yeah. 18 Q. Okay. Do you know whether or not Great Canadian 19 Casinos, Inc. has any operations or activities in the United 20 States? 21 A. Yes, they do. They have Tukwila Casino. 22 Q. Where is that? 23 A. It's near Tacoma Airport. 24 Q. What state is that in? 25 A. It's Washington State. Actually I've been sent there VICKI HUMPHREY, CSR MANSFIELD, TX METRO(817)477-2035 PROKA AVRAMOVIC 70 1 to overlook their operation as well. 2 Q. Oh, you were? 3 A. Yeah. 4 Q. Okay. When was that? 5 A. I'm really bad with dates because it's just -- 6 Q. Can you remember what year? 7 A. I think it was before we went to the ship, so it was 8 probably in 2000. 9 Q. Okay. All right. And how long were you there? 10 A. We spent a whole day, morning and afternoon. 11 Q. Okay. And what did you do there? 12 A. We made reports of our observations there. 13 Q. Okay. Do you know of any other operations or 14 activities GCC has in the United States? 15 A. Well, just through the GCC website. I know that they 16 acquire small casino up north in British Columbia. 17 Q. I'm talking about in the United States. 18 MR. PULLMAN: Object to being nonresponsive. 19 Q. I'm talking about activities and operations in the 20 United States. 21 A. Oh. Big Al. 22 Q. Big Al? 23 A. Yeah. That's, I think, in Tacoma. 24 Q. Is that the name of the casino or what? 25 A. I believe that's the name of the casino. VICKI HUMPHREY, CSR MANSFIELD, TX METRO(817)477-2035 PROKA AVRAMOVIC 71 1 Q. Okay. It's in Tacoma, Washington? 2 A. Yeah. 3 Q. Okay. Are there any others that you know of? 4 A. I know -- Well, in states? 5 Q. Yes, the United States, anywhere in the United 6 States. 7 A. Just those two in the states. 8 Q. Okay. Good deal. Do you have any knowledge 9 surrounding Boki's resignation from Great Canadian Casinos, 10 Inc.? 11 A. Well, I assume that was another cover-up in GCC. 12 Q. But do you have any knowledge surrounding it? 13 A. Yes, I do. 14 Q. Okay. What knowledge do you have? 15 A. Well, I knew -- I know that the chips were missing 16 from that location. I know that several people's been 17 accused. I know that it was in evidence. I know that Boki 18 immediately after that resigned. I know that he got one year 19 package, his car. The people who were involved, they were 20 getting the packages as well. 21 Q. All right. 22 A. Case is still under investigation in British 23 Columbia. 24 MR. RAY: Okay. Good enough. I'm going to pass 25 the witness then. VICKI HUMPHREY, CSR MANSFIELD, TX METRO(817)477-2035 PROKA AVRAMOVIC 72 1 MR. PULLMAN: Would you please ask Mr. Sikimic 2 to come in here, please, Carl? 3 MR. RAY: Mr. who? 4 MR. PULLMAN: Sikimic. 5 MR. RAY: Boki? 6 (At this time Mr. Sikimic enters the 7 deposition proceedings.) 8 9 EXAMINATION 10 BY MR. PULLMAN: 11 Q. You went to Tukwila for one day to review the -- to 12 overlook the operations; is that correct? 13 A. Yes. 14 Q. And Big Al, you learned about that on the website? 15 A. Yeah. 16 Q. So the only firsthand knowledge you have of any 17 entity that Great Canadian has any involvement in is when you 18 went to Tukwila and you observed it; is that correct? 19 A. No. Before that, security manager of Tukwila Casino 20 surveillance, we've been hosting at the Holiday Inn and we've 21 been showing him how the things are in our casinos, and I 22 notice that now there is a possibility that maybe some people 23 from Canada is going to go there and start working at Tukwila 24 as a part of the -- 25 Q. When did you learn that? VICKI HUMPHREY, CSR MANSFIELD, TX METRO(817)477-2035 PROKA AVRAMOVIC 73 1 A. Well, it's all on the website. 2 Q. Oh, on the website. You personally went to Tukwila 3 one day and you saw some people from Tukwila in Canada. 4 A. Yes. 5 Q. Okay. That's it. That's all you personally saw 6 except what you've read on the website. Is that correct or 7 not? 8 A. Well, do you want me to answer yes or no? 9 Q. I just want you to tell the truth. 10 A. Oh, truth. Okay. Well -- 11 Q. You went to Tukwila -- 12 A. I've been telling the truth all the way. 13 Q. You went to Tukwila once and somebody from Tukwila 14 came to Canada; is that correct? 15 A. Well, first of all -- 16 Q. Is that correct, I'm asking you. You went to Tukwila 17 once and somebody from Tukwila came -- some people -- 18 A. It's the other way around. 19 Q. Okay. Some people from Tukwila came to Canada and 20 you went to Tukwila for one day. 21 A. Yes. 22 Q. Okay. Now, when did you first learn that there were 23 loan sharks at any casino in Canada that you worked for? When 24 did you first observe that? 25 A. I believe that was the Holiday Inn Casino. VICKI HUMPHREY, CSR MANSFIELD, TX METRO(817)477-2035 PROKA AVRAMOVIC 74 1 Q. What year? 2 A. There's a report. 3 Q. What year? 4 A. Again, I don't want to speculate on the date because 5 there's a report. 6 Q. Approximately what year? How long into your 7 employment with the company would you observe loan sharks? 8 A. Again, I don't want to speculate on the date. 9 Q. Are you refusing to answer? 10 A. I'm not refusing to answer. 11 MR. RAY: Objection, form. 12 A. I can't speculate on a date. I mean, there is a 13 report and I can think about it and get back to you. 14 Q. When did you come to work at Great Canadian Casinos, 15 what year? 16 A. March '95. 17 Q. All right. Between March '95 and 2000, did you ever 18 come to be aware that there were loan sharks at the Canadian 19 casinos? 20 A. Before that time? 21 Q. Between the time you got there and 2000. 22 A. Oh, yeah. 23 Q. Okay. Between the time you got there and one year 24 after, did you observe loan sharks? 25 A. Yeah. VICKI HUMPHREY, CSR MANSFIELD, TX METRO(817)477-2035 PROKA AVRAMOVIC 75 1 Q. Okay. So sometime within your first year with Great 2 Canadian you observed loan sharks; is that correct? 3 A. Yes. 4 Q. And every time you observed it you reported it; is 5 that correct? 6 A. Yes. 7 Q. And how much period of that time did you report that 8 to Mr. Sikimic? During the period of time that you were 9 reporting loan sharks, what period -- how often was Mr. 10 Sikimic your direct supervisor? 11 A. Well, first he was my manager and then he was 12 director, so basically I've been reporting pretty much every 13 discrepancy for a long time to Boki. 14 Q. And when did Mr. Sikimic tell you or -- tell you to 15 turn the other cheek and ignore that stuff? 16 A. That was Mr. Sikimic and Mr. -- 17 Q. When did Mr. Sikimic first tell you, we're going to 18 ignore -- to ignore this? 19 A. It was in a meeting, I believe, April of 2003. 20 Q. So in April of 2003 is the first time Mr. Sikimic 21 told you do not report -- we're not -- we're ignoring this. 22 A. No, he told me to turn the camera the other way, 23 advised myself to turn the camera the other way when we see 24 something like that. 25 Q. Okay. That's the first time. VICKI HUMPHREY, CSR MANSFIELD, TX METRO(817)477-2035 PROKA AVRAMOVIC 76 1 A. Officially, yeah. 2 Q. Did he ever unofficially tell you that? 3 A. Yes, he did. 4 Q. When did he tell you that? 5 A. Probably six months before that. 6 Q. Okay. Did he tell you why? 7 A. He was telling me that it was in best company 8 interest and that we don't have to see everything. 9 Q. Is Mr. Sikimic an honest person? 10 A. To my knowledge, yes. 11 Q. Why would he tell you to do something dishonest that 12 violates -- You are aware, are you not, of Canadian Statute 13 Section 86 of the Gaming Control Act, are you not? 14 MR. RAY: Objection, form. 15 A. Yes. Yes, I'm aware of that. 16 Q. So you're telling this Court and jury that Mr. 17 Sikimic told you to ignore that statute. 18 A. Yes. 19 Q. That makes him dishonest, does it not? 20 MR. RAY: Objection, form. 21 A. Not to my knowledge. 22 Q. Oh. So that's honest to ignore Canadian Section 86 23 of the Gaming Control Act. Is that being honest or dishonest? 24 A. Well, he honestly told me what to do and I didn't 25 agree with it. VICKI HUMPHREY, CSR MANSFIELD, TX METRO(817)477-2035 PROKA AVRAMOVIC 77 1 Q. Is it honest or dishonest to tell somebody -- 2 MR. RAY: Objection, form. 3 Q. Is it honest or dishonest to tell somebody to violate 4 Section 86 of the Gaming Control Act? 5 A. Well, I don't know how to respond. 6 Q. You don't know how to answer that? Are you telling 7 this Court and jury you can't answer that question? 8 A. I don't know what to say. 9 Q. I can't help that. 10 A. If he's honest or -- 11 MR. RAY: Well, I think the witness has answered 12 to the best of his ability. 13 A. Well, I can answer the question. I don't want to 14 argue. At that point I did trust Boki to be a respectable, 15 honest person and doing his job honestly, and after that I 16 lost that respect for Mr. Sikimic, and my feeling was that I 17 didn't want to work for the guy anymore. 18 Q. Did you come here voluntarily? 19 A. Yes, I did. 20 Q. What caused you to do that? 21 A. I spoke to Mr. David on the phone and he's been 22 asking me if I'm interested to come here and give testimony 23 about what was going on on the ship. 24 Q. When did you first speak to Mr. David? Is that the 25 same -- What's the rest of Mr. David's name? VICKI HUMPHREY, CSR MANSFIELD, TX METRO(817)477-2035 PROKA AVRAMOVIC 78 1 A. Is it here, or maybe right there. David Wiley. 2 Q. Okay. David Wiley spoke to you on the phone. Who 3 contacted who? 4 A. He contacted me. 5 Q. And when was this? 6 A. That was about couple of weeks ago. 7 Q. Couple of weeks ago. And where were you when he 8 contacted you? 9 A. I was on my cell phone. 10 Q. Where were you when he contacted you? 11 A. Oh, coffee shop. 12 Q. What city, what state, what country? 13 A. In Vancouver, Canada, and I've been having espresso. 14 Q. And where -- Object and move that the -- he was 15 having espresso be stricken as being nonresponsive. Where -- 16 I'm sorry. What were you paid to come here? 17 A. Zero. 18 Q. Zero. Not even expenses? 19 A. I never talk to David about expenses. I didn't even 20 ask for expenses. 21 Q. You were paid zero. 22 A. Yeah. 23 Q. What caused you -- 24 A. Actually I did get $40.00 for showing up here, but 25 that's law, I believe. VICKI HUMPHREY, CSR MANSFIELD, TX METRO(817)477-2035 PROKA AVRAMOVIC 79 1 Q. Okay. So where did you study this law? 2 A. Well, I've been told when they give me subpoena that 3 according to the law I suppose to receive $40.00 which is -- I 4 don't really need, and I'm just glad that somebody wanted to 5 hear the truth, so I just drove all the way from Canada to 6 here. 7 Q. Why were you really fired? 8 A. Fired? 9 Q. Were you fired or not? 10 A. No, I'm not fired. 11 Q. I'd like you to carefully read this Exhibit 7. Were 12 you ever involved in any kind of fights or anything at the 13 casino? 14 A. Me? 15 Q. Yeah, you. 16 A. No. 17 Q. No, never. Okay. Please read and review Exhibit 18 7 -- 19 A. Well -- 20 Q. -- until you fully understand it. What was that 21 "well"? Do you want to say something? 22 A. Well, it's pretty clear to me that I approach 23 employee and twice he's -- that I was -- that I wanted to 24 leave for personal reasons. 25 Q. Object to the answer as being nonresponsive. Please VICKI HUMPHREY, CSR MANSFIELD, TX METRO(817)477-2035 PROKA AVRAMOVIC 80 1 read Exhibit 7, make sure you fully understand it. Maybe you 2 already do understand it. 3 A. Yes, I do understand it. 4 Q. Okay. Do you notice -- Please turn to the second 5 page. 6 A. Uh-huh. 7 Q. The third paragraph. 8 A. Uh-huh. 9 Q. Is that a yes or a no? Third paragraph, do you see 10 that? 11 A. One, two, three. Yeah. I've been asking that 12 paragraph to be add to the release. 13 Q. I've asked you just to please look at the third 14 paragraph on the second page. 15 A. Okay. I'm looking at the paragraph. 16 Q. And you fully understood that that paragraph was in 17 there. 18 A. Yes, I do. 19 Q. And you of course reported everything to the casino 20 commission. 21 A. Yes, to British Columbia Lottery Corporation and to 22 Gaming Policy and Enforcement Branch. 23 Q. And what actions have been brought so far? 24 A. I've been told by both agencies that that information 25 is going to be processed. All those discrepancy that I VICKI HUMPHREY, CSR MANSFIELD, TX METRO(817)477-2035 PROKA AVRAMOVIC 81 1 mention, not on the ship, that I mention about the drugs, 2 rape, selling the illegal cigarettes, loan sharks problem, 3 they've been telling me that they were going to look into it 4 and then right now it's not good time because it's expansion 5 of the gaming industry there, so definitely somebody will look 6 after that and somebody will contact me. 7 Q. So I think what I heard you say in all that was that 8 all of this that you reported occurred after you got back from 9 the boat. 10 A. No, after when I resigned from the company. 11 Q. Were the activities that you reported to the casino, 12 the British -- 13 A. I never report anything regarding the ship to any of 14 those agencies. 15 Q. Did all the activities that you reported occur after 16 you returned from -- 17 A. No. 18 Q. -- the ship? 19 A. Before and after. 20 Q. So some of these activities occurred before. 21 A. Before and after, yeah. 22 Q. It's hard for me to read your arithmetic, but you 23 were back at least two years from the time you resigned back 24 to when you got back from the casino (sic), almost two years 25 to the day; is that correct? VICKI HUMPHREY, CSR MANSFIELD, TX METRO(817)477-2035 PROKA AVRAMOVIC 82 1 A. From the ship? 2 Q. When did you get back from the ship? May '01? 3 A. It was 2001, I guess. 4 Q. All right. And you resigned in June of 2003. 5 A. Yeah. 6 Q. Two years and one month later. 7 A. Yeah. So I've been reporting discrepancy all the 8 time to those agency during my work for GCC before and after I 9 left the ship. There's records of that as well. 10 Q. So you've made many reports. 11 A. Many reports. I'm well known to those agency and I 12 have a good reputation through those agency. I mean, you can 13 check that easily, I guess. 14 Q. I move that all be stricken as being nonresponsive. 15 Tell me something. Of the reports that you made prior to your 16 going to the ship in China, how many of those in any way 17 related to Mr. Sikimic? 18 A. Well, every single report I sent to Mr. Sikimic. 19 Q. No, no. I'm talking about the reports that you made 20 to the public agency. They all related to Mr. Sikimic because 21 everything you had already reported to him first; is that 22 correct? 23 A. That's correct. 24 Q. Okay. 25 A. Is my English that bad or -- just let me clarify VICKI HUMPHREY, CSR MANSFIELD, TX METRO(817)477-2035 PROKA AVRAMOVIC 83 1 something. I was on the ship. I directly reporting to Boki, 2 right? I can't contact those agency from China, right? I 3 can't pick up the phone and contact those agency from China. 4 So I guess that he's supposed to be reporting those incidents 5 to those agency, right? 6 Q. Let's try again. 7 A. Okay. Let's try again. Do you have a problem with 8 my English? 9 Q. I have a problem with your rudeness. Now, do you 10 want to move on or do you want to just keep talking? 11 A. Sure. 12 Q. It's your call. 13 A. Let's move on. 14 MR. RAY: Objection, form. 15 A. You don't have to raise your voice because I can hear 16 you. 17 Q. I'm beginning to wonder. 18 A. That's good. 19 Q. Yeah. Now, what I was asking you was: You also 20 reported things to the Gaming Policy and Enforcement Branch, 21 the British Columbia Lottery Corporation. 22 A. Both things. Ship, before ship, after ship. What 23 specifically things? 24 Q. Well, once again, I'm going to ask you to let me 25 finish the question. It has nothing to do with your VICKI HUMPHREY, CSR MANSFIELD, TX METRO(817)477-2035 PROKA AVRAMOVIC 84 1 understanding English. It's just that you're rude. Do you 2 understand that? 3 MR. RAY: Objection, form. 4 A. I'm just trying to accommodate your question. 5 Q. Well, let me finish the question and you'll get a 6 chance to answer it. 7 A. But you're telling me that I'm fired. Is that what 8 you're telling me before? 9 MR. RAY: Richard, I don't have any problems 10 with you asking questions, but -- 11 A. You're telling me that I'm fired. 12 MR. RAY: You don't need to make statements, 13 okay? 14 Q. Are you telling -- I'm not having anything to do with 15 you being fired. I'm trying to ask you a question. 16 A. So I was fired. I mean, you're telling me that I was 17 fired. I look at the section, whatever -- 18 Q. Let me know when we're ready to convene this 19 deposition. I'm getting tired of listening to his brain. 20 A. Well, I'm here until Sunday. 21 Q. Well, then maybe we may go until Sunday. 22 MR. RAY: Objection, form. 23 Q. Prior to your going to the ship -- 24 A. Okay. 25 Q. -- you reported incidents, or did you not, to the VICKI HUMPHREY, CSR MANSFIELD, TX METRO(817)477-2035 PROKA AVRAMOVIC 85 1 Gaming Policy and Enforcement Branch, British Columbia Lottery 2 Corporation? 3 A. Can I answer now? Yes, I did. 4 Q. Okay. And every one of these things that you 5 reported were also issues that you also reported to Mr. 6 Sikimic. 7 A. Yes, I did. 8 Q. And why did you deem it necessary to report something 9 to the authorities that you had already reported to Mr. 10 Sikimic? 11 A. That's part of the regulations that at the same time 12 when I report discrepancy to Mr. Sikimic that I have to make 13 another couple of reports, send to the British Columbia 14 Lottery Corporation and also the government agency. 15 Q. What level of discrepancies must you report? 16 A. Any loan sharking for sure. 17 Q. All right. 18 A. Any criminal activity, any suspicious activity, 19 cheating at play and so on. 20 Q. So every -- So you were making these reports from 21 soon after you came to work. 22 A. As soon as I start being in charge and as soon as 23 that policy took place, I start reporting discrepancies to the 24 designated agencies including Mr. Sikimic. 25 Q. How many reports do you think you made to the VICKI HUMPHREY, CSR MANSFIELD, TX METRO(817)477-2035 PROKA AVRAMOVIC 86 1 designated agencies? 2 A. A lot. 3 Q. More than three, more than 300? 4 A. I don't want to speculate with the numbers. That 5 could be easily checked. 6 Q. I don't intend to check them. I want you to tell me 7 how many you believe -- 8 A. And I don't want to speculate. 9 Q. Are you refusing to answer? 10 A. I don't refusing to answer. I'm just refusing to 11 speculate. It's more than three, less than 300. 12 Q. Is it more than a hundred? 13 A. Less than a hundred. 14 Q. Is it more than 50? 15 A. Somewhere around 50. 16 Q. So you're really not speculating. If you just 17 concentrate, you could answer, couldn't you? 18 MR. RAY: Objection, form. 19 Q. You're refusing to answer my questions; is that 20 right? 21 MR. RAY: Objection, form. 22 A. I do not refuse to answer your question. I'm just 23 telling you that all those reports are easily to be -- you 24 know, to find out how many exactly. 25 Q. Were you able to calculate approximately 50 just VICKI HUMPHREY, CSR MANSFIELD, TX METRO(817)477-2035 PROKA AVRAMOVIC 87 1 now? 2 A. Ah -- 3 Q. You did that, didn't you? 4 A. I just come up with the 50. I believe it's 50 at 5 least. 6 Q. Okay. 7 A. It could be more, it could be less. 8 Q. Okay. Is that a speculation or is that your best 9 estimate? 10 A. My best estimate. 11 Q. Thank you. Now, let's turn back to your agreement, 12 and look at the last paragraph on the first page. Make sure 13 you understand that. 14 A. Okay. 15 Q. Was that your idea to put that in or was that theirs? 16 A. No. That's theirs. The third paragraph was my idea. 17 Q. Was the fourth paragraph, the last paragraph -- Which 18 is the third paragraph you're talking about? 19 A. Well, the one that you mention to me. "It is 20 expressly understood and agreed that" -- 21 Q. Please turn to the first page. I think we're 22 talking -- 23 A. Oh, now we're back to the first page. 24 Q. That's what I asked you. I said look at the last 25 paragraph on the first page. VICKI HUMPHREY, CSR MANSFIELD, TX METRO(817)477-2035 PROKA AVRAMOVIC 88 1 A. Okay. I'm there. 2 Q. Do you understand that? 3 A. Yeah. 4 Q. Whose idea was it to put that in there? 5 A. It's Brian Egli. He was the vice-president. The 6 only thing that we didn't like about the release letter was 7 the three years globally that I'm not permitted to go to Great 8 Canadian Casino, and he personally promised me on several 9 occasions that from January I'm going to be able to actually 10 go to Great Canadian Casinos, Incorporated. And it wasn't my 11 idea. That was my only objection on this thing. 12 Q. Why did -- Was it explained to you why Great Canadian 13 wanted that in there? 14 A. He says that he probably slipped three years. 15 MR. RAY: Objection, form. 16 A. Usually it's -- I was still answering the question. 17 Q. Did anybody explain to you why the last paragraph was 18 put in there by Great Canadian? 19 A. Yes. Brian Egli said that he thinks it's too much 20 and that it probably slipped and that he's going to make sure 21 that I'm going to be able to return to casino after six 22 months, which is standard for anybody who resigns. 23 Q. Okay. Did anybody explain to you why it should be 24 six months? 25 A. That was a standard procedure with people who we fire VICKI HUMPHREY, CSR MANSFIELD, TX METRO(817)477-2035 PROKA AVRAMOVIC 89 1 or people who resign, the common practice for Great Canadian 2 Casinos. 3 Q. When did Brian Egli tell you that it was really going 4 to be six months? 5 A. He was telling me when I signed this on the 25th. 6 And I also made the phone call in late December and he said 7 that he's going to make sure that -- he's going to fix that. 8 Q. Has it been fixed? 9 A. I assume so. I never call him back. 10 Q. Have you been into the casinos? 11 A. No. 12 Q. Look at the last page, please. 13 A. Okay. 14 Q. Is that your handwriting? 15 A. Which one? 16 Q. "This will acknowledge that I..." 17 A. That's his writing, Brian Egli's writing. 18 Q. Can you read it? 19 A. No. 20 Q. You don't know what it says? 21 A. No. 22 Q. You can't read that? 23 A. No. I mean, it's crappy writing. Can't blame me. 24 Q. You're telling this Court and jury that you cannot 25 read what that says. VICKI HUMPHREY, CSR MANSFIELD, TX METRO(817)477-2035 PROKA AVRAMOVIC 90 1 A. No, I cannot tell. 2 Q. Well, let me try to read it with you, see if you can 3 disagree. 4 MR. RAY: Objection, form. 5 MR. PULLMAN: If he can't read, I have to read 6 for him. 7 MR. RAY: Well, you know, I mean, you're getting 8 argumentative with the witness, Richard. Either he can read 9 it or he can't. You know, if -- 10 A. Well, I'm not going to be arguing. I'm just -- 11 MR. RAY: Yeah. If you want to read it to him, 12 that's fine. 13 MR. PULLMAN: He has testified that he can't 14 read it and it's crappy writing. 15 MR. RAY: So why don't you read it to him? 16 MR. PULLMAN: I'm going to move forward. 17 MR. RAY: Okay. 18 Q. (By Mr. Pullman) Did anybody read it to you? 19 A. Yes, he did. 20 Q. Did you understand it? 21 A. Yes, I did. 22 Q. Do you have any reason to believe that anything on 23 there -- that there's some words that you can't read that he 24 told you differently? 25 A. No. VICKI HUMPHREY, CSR MANSFIELD, TX METRO(817)477-2035 PROKA AVRAMOVIC 91 1 Q. Did you understand you had 24 hours to review this 2 and acknowledge this? 3 A. Yes. 4 Q. Did you understand that you had the chance to consult 5 a lawyer? 6 A. Yes. 7 Q. Did you consult a lawyer? 8 A. Yes. 9 Q. You did? 10 A. Yeah. 11 Q. Then why did you say "which I waive" and initial 12 that? 13 A. Well, I consult a lawyer and lawyer says everything 14 is fine, go ahead and sign. 15 Q. So you did consult a lawyer. 16 A. Yeah. 17 Q. And Mr. Egli told you prior to your consulting the 18 lawyer -- 19 A. No. 20 Q. Did you just say "no"? Did Mr. Egli tell you prior 21 to consulting the lawyer that the three years was a mistake? 22 A. Yeah. 23 Q. Why didn't you fix it right then and there, pen on 24 there six months instead of three years on the first page? 25 A. Okay. There's a reason. VICKI HUMPHREY, CSR MANSFIELD, TX METRO(817)477-2035 PROKA AVRAMOVIC 92 1 Q. Yeah, I'm interested in that reason. 2 A. First of all, I don't really care if I'm going to go 3 tomorrow or three or ten years back to the casino. It's just 4 a matter of I didn't kill anyone there. I mean, three years. 5 The standard procedure is six months. I believe Mr. Brian 6 Egli that that was a mistake and I believe that he's going to 7 correct, but personally I don't really care if it's six months 8 or three years or for life, so that's why I didn't bother to 9 change. 10 Q. Okay. Let me make sure I've got your story straight. 11 A. Okay. 12 MR. RAY: Objection, form. 13 Q. You discussed the first page with Mr. Egli and he 14 said that was a mistake. 15 A. Yeah. 16 Q. You called him again, but you never had it changed. 17 A. Never had it changed, no. 18 Q. You called him again in December to see if he had 19 changed it and fixed it. 20 A. Yeah. 21 Q. But you really don't care. 22 A. The purpose of my call was second payment of my 23 severance agreement, and by the way I was just mentioning that 24 to him. 25 Q. Object as being nonresponsive. You spoke to Mr. Egli VICKI HUMPHREY, CSR MANSFIELD, TX METRO(817)477-2035 PROKA AVRAMOVIC 93 1 in December. 2 A. Okay. 3 Q. And you asked him during that conversation if it had 4 been fixed. 5 A. Yeah. 6 Q. But you didn't really care. You don't care if you 7 ever go back. 8 A. No. 9 Q. Okay. Let's look at the -- please go down further on 10 the second page, the first paragraph. Do you understand that 11 first paragraph? 12 A. Yes, I do. 13 Q. When was the first time you contacted anybody in 14 violation of that paragraph? 15 MR. RAY: Objection, form. 16 A. Okay. Could you be more specific? 17 Q. No. I don't know how to. When was -- I'll try 18 again, though. You testified that you understand that first 19 paragraph. 20 A. Yes. 21 Q. When was the first time you violated it? 22 MR. RAY: Objection, form. 23 A. My wife works there, my couple of cousins work 24 there. If that's a violation, I mean, I was obligated to -- 25 Q. Excuse me? VICKI HUMPHREY, CSR MANSFIELD, TX METRO(817)477-2035 PROKA AVRAMOVIC 94 1 A. I had to go home and see my wife. She's working for 2 them. And I have my cousins too, so I didn't -- I still see 3 my cousins maybe a couple of days after this. 4 Q. You're telling this Court and jury you understand 5 that first paragraph. 6 A. Yes, I do. 7 Q. What does it say? What do you understand it to say? 8 A. Well, that I can't go to the media, I can't 9 communicate with any employee or family members or customers, 10 persons doing business with employees or like so on and so on. 11 Q. For the purpose of -- Do you understand those last 12 two lines? 13 A. Yeah. 14 Q. When was the first time you communicated with anybody 15 in the world for the purpose of harming, maligning, bringing 16 into disrepute, or in any other way, form or manner of 17 impugning the reputation of the company? 18 MR. RAY: Objection, form. That's like asking 19 someone when was the first time you beat your wife, Richard. 20 Come on. 21 MR. RAY: I've never beat my wife. Maybe you 22 have. 23 A. Immediately after release I went to those agency and 24 I tell them everything I know. 25 Q. Well -- VICKI HUMPHREY, CSR MANSFIELD, TX METRO(817)477-2035 PROKA AVRAMOVIC 95 1 A. I never told -- I never told my cousins about -- 2 Q. You've never told anybody in the world other than the 3 agencies or said anything that would in any way harm, malign, 4 bringing into disrepute or in any other way harm -- 5 A. No, huh-uh. 6 Q. -- the reputation of the company? 7 A. No. 8 Q. Never. 9 A. Never. 10 Q. Okay. Now, you testified earlier that the -- that 11 the ship in the time that you were there those seven weeks 12 only went out to sea three times? 13 A. Yeah. 14 Q. So therefore, the most that the cash could have been 15 off was three times. 16 A. Well, I didn't see much cash on the ship. 17 Q. How many reports did you give regarding money and the 18 problem that you had no way to understand what was going on 19 with the cash? How many times did you report that? 20 A. Well, all three times we sail I send report. 21 Q. Regarding the cash? 22 A. Regarding the cash, yeah. 23 Q. Okay. How many times did that ship sail in the seven 24 weeks before you came on board? 25 A. How many times before when I came -- VICKI HUMPHREY, CSR MANSFIELD, TX METRO(817)477-2035 PROKA AVRAMOVIC 96 1 Q. Yeah. 2 A. I don't know. 3 Q. So when you were being prepped by the person that you 4 replaced, he didn't tell you how frequently it had sailed in 5 the past? You don't have any idea? Is that your testimony 6 before this Court? You had no idea how often that ship had 7 sailed before you got on it? 8 A. Twice a week. 9 Q. Twice a week. Okay. So on average, in the seven 10 weeks before you got on board, there were 14 sailings, and on 11 the seven weeks you were on board there were only three. 12 A. Yeah. 13 Q. Okay. 14 A. We were just riding around. That's all. Actually it 15 wasn't really sailing. 16 Q. I object as that being nonresponsive, move that it be 17 stricken. What deal was made with Mr. Y which enabled the 18 ship to leave? 19 A. I believe the best people to ask was Mr. Walter Soo 20 because he was directly in contact with him, and he did 21 receive some threats and that's why he left the ship. There 22 was obviously argument. We document that on tape and did a 23 report, and exactly words, you would have to, I believe, ask 24 Mr. Walter Soo. 25 Q. I move that that be stricken as being nonresponsive. VICKI HUMPHREY, CSR MANSFIELD, TX METRO(817)477-2035 PROKA AVRAMOVIC 97 1 Let me try again. Do you know what deal, if any, was made 2 with Mr. Y? 3 A. Well, he got free. 4 Q. Do you know what deal, if any, was made with Mr. Y? 5 A. No. 6 Q. Okay. You don't even know if Mr. Y was making any 7 claim firsthand, do you? Mr. Y ever tell you -- 8 A. Well, you don't ask the guy with a gun. 9 Q. Did Mr. Y ever tell you or say in your presence, if 10 you don't make a deal with me, this ship is not leaving? 11 A. No. He was taking good care of the security, so we 12 didn't have a reason to be pissed off. He offered us body 13 massaging in Vietnam, which we refuse. 14 Q. Move to strike that as being nonresponsive. Did Mr. 15 Y ever tell you that if you guys don't make a deal with me, 16 this ship's not leaving? 17 A. Did he specifically made that statement to me? No. 18 Q. Okay. So you don't know as you sit here today 19 whether or not any deal was required to be made with Mr. Y. 20 A. Well, those people were shaking and they're telling 21 me what Mr. Y told them. 22 Q. Do you know today whether or not any deal was made 23 with Mr. Y? Yes or no. 24 A. No. 25 Q. Okay. This guy comes on board with a gun. Where was VICKI HUMPHREY, CSR MANSFIELD, TX METRO(817)477-2035 PROKA AVRAMOVIC 98 1 the gun? 2 A. He had one in his pocket and a couple larger pieces 3 in his bag that he didn't want to open. 4 Q. But it set off the metal detector? 5 A. He didn't even want to go through the metal detector. 6 Q. Well, how did you know he had the guns? 7 A. Well, I saw it. 8 Q. You saw it through the bag? You said he didn't open 9 the bag. 10 A. He didn't open the bag. I was asking him what's in 11 the bag. He refused to answer. Then I kind of started 12 feeling around and I saw that he has more guns than the one 13 that he was wearing, you know, in his pocket. It wasn't his 14 pocket. It was a little gun holder right there. 15 Q. Okay. Did anybody -- Did he shoot anybody? 16 A. No, he didn't shoot anyone. 17 Q. So you made a wise -- 18 MR. RAY: Hold on, Richard. You know, he was 19 making a gesticulation there. Just for the record, I want to 20 clear it up that he was putting the gun somewhere and that 21 wasn't really recorded in the record. 22 Q. The gun was in his belt, is that what you're saying, 23 a holster? 24 A. Well, it's a little holder for a gun. 25 Q. On his belt? VICKI HUMPHREY, CSR MANSFIELD, TX METRO(817)477-2035 PROKA AVRAMOVIC 99 1 MR. RAY: Little clip-on holster? 2 THE WITNESS: Yeah. 3 MR. RAY: Okay. 4 Q. (By Mr. Pullman) Were any other people on the boat 5 with guns? 6 A. Well, he was coming first and my intention wasn't to 7 go and check all of his friends, so I just let him go. So I 8 assume that all of them had a piece. 9 Q. You can't tell this Court and jury whether anybody in 10 the world had any guns other than Mr. Y on the boat. 11 A. I didn't say that Mr. Y had a gun. I said one of Mr. 12 Y's boys had a gun. 13 Q. Oh, so it was one of his boys that had the gun in the 14 holster. 15 A. Yeah. 16 Q. Is that correct? 17 A. Yeah. 18 Q. And so you can't tell this Court and jury that 19 anybody in the world had guns other than one of Mr. Y's boys. 20 A. I guess not. 21 Q. Is that a I can or I cannot? Can you tell this jury 22 that anybody else had a gun other than -- 23 A. How about a yes or no? No. 24 Q. I don't know what the question is, do you? Did 25 anybody other than Mr. Y's boy have a gun to your firsthand VICKI HUMPHREY, CSR MANSFIELD, TX METRO(817)477-2035 PROKA AVRAMOVIC 100 1 knowledge? 2 A. No. 3 Q. Do you know whether in the bag if it was a gun or a 4 water pistol or a toy cap gun? 5 A. I can't tell. 6 Q. Do you know whether the gun in his holster was a toy 7 cap gun or a real gun? 8 A. I can't tell that. 9 Q. For all you know, the guy was crazy and he liked to 10 carry toy cap guns. 11 A. See, that's interesting thought. I never thought 12 about it. 13 Q. I bet there's a lot of things you haven't thought 14 about. 15 MR. RAY: Objection, form. 16 Q. Do you know whether or not this guy just liked to 17 carry toy cap guns? 18 A. That was a real gun. I have military experience and 19 that was a real gun. 20 Q. Oh, so now you're changing your testimony. Earlier 21 you said you didn't know if it was a real gun or not and you 22 said that's a good thought. So now you're telling me it is a 23 gun. 24 MR. RAY: Objection, form, argumentative. 25 A. Well, they're making real guns and they're making VICKI HUMPHREY, CSR MANSFIELD, TX METRO(817)477-2035 PROKA AVRAMOVIC 101 1 fake guns that look like real guns. To me, that gun looked 2 real. 3 Q. Okay. It looked real, but you don't know whether it 4 was real or not. 5 A. Well, you can say that. 6 Q. I don't care what I can say. Do you know whether or 7 not -- 8 A. To me, that was a real gun. To you, that was -- 9 could be something else. Let's stick with your story. It 10 could be something else. To me, it was a real gun. 11 Q. That's a very interesting story, but I'd like you to 12 please answer my question. 13 MR. PULLMAN: Would you please read it back? 14 MR. RAY: We're going to object. Sounds to us 15 that he's answered the question twice. 16 MR. PULLMAN: Can you tell me what -- 17 MR. RAY: I think he said to him it was a real 18 gun is what he said, Richard. 19 MR. PULLMAN: Okay. 20 MR. RAY: That's what I understood him to say 21 twice. 22 MR. PULLMAN: That's not what I heard him to 23 say, so let's just -- let me just try again. 24 MR. RAY: You want to have the court reporter 25 read it back? VICKI HUMPHREY, CSR MANSFIELD, TX METRO(817)477-2035 PROKA AVRAMOVIC 102 1 MR. PULLMAN: No, it's not worth it. I'll try 2 again. 3 MR. RAY: Okay. 4 Q. (By Mr. Pullman) You cannot tell this Court today 5 whether or not that was or was not a real gun. 6 A. To me, that was a real gun. 7 Q. Can you tell this Court that it was a real gun, not 8 to you in your perception, that you know it was a real gun? 9 MR. RAY: Objection, form. You know, we're 10 getting into semantics here arguing about, you know, to you 11 what it was or wasn't. We can go on -- I mean, look here, 12 perception is what everything is based on, Richard. 13 MR. PULLMAN: Fine. We'll let the judge decide. 14 MR. RAY: That's what you're going to have to 15 do, I guess. 16 MR. PULLMAN: I'm entitled to get a straight 17 answer from him. 18 MR. RAY: Well, you know, I don't know -- 19 MR. PULLMAN: And I object to your 20 instructing -- 21 A. That gun looks real to me and -- 22 MR. RAY: I'm not trying to instruct him or 23 trying to do anything. 24 A. -- I was pretty sure that was a real gun. 25 Q. Okay. You are not positive that that was a real gun. VICKI HUMPHREY, CSR MANSFIELD, TX METRO(817)477-2035 PROKA AVRAMOVIC 103 1 Yes or no. 2 A. I was positive it was real gun. 3 Q. Oh, now you're positive it was. I just want to get a 4 straight answer. 5 MR. RAY: You got a straight answer. Aren't you 6 satisfied with it? 7 MR. PULLMAN: No. This deposition's about to 8 end. 9 MR. RAY: Well, that's fine with me. 10 MR. PULLMAN: And it's not going to be concluded 11 because you're refusing to let me ask questions. 12 MR. RAY: I'm not refusing to let you ask 13 questions, Richard. You asked the question, you got an answer 14 and you're trying to ask it again. 15 MR. PULLMAN: You'll see on the record I've 16 gotten five different answers, in fact one that he said -- Let 17 me finish. 18 MR. RAY: That's fine. I wasn't saying 19 anything. 20 MR. PULLMAN: And don't -- you don't need to nod 21 your head yes or no. 22 MR. RAY: I can do anything I want to, Richard. 23 MR. PULLMAN: No, you can't. 24 MR. RAY: Yes, I can. 25 MR. PULLMAN: Then I guess you're going to tell VICKI HUMPHREY, CSR MANSFIELD, TX METRO(817)477-2035 PROKA AVRAMOVIC 104 1 him how to testify. 2 MR. RAY: I'm not going to do that because I 3 don't want to. 4 MR. PULLMAN: Well, you've been wanting to for 5 the last 30 minutes. 6 MR. RAY: No, I haven't either, and I'm not 7 going to sit here and argue with you any more. 8 MR. PULLMAN: There is a record -- there is an 9 answer on the record that he said, That's a good idea, that's 10 a possibility. He said, I think it's a real gun, you think it 11 wasn't. Let's go with your answer. 12 MR. RAY: Okay. 13 A. Let's go with my answer. I think it was a real gun. 14 MR. RAY: Your point is, Richard? 15 Q. So now we're going to go with your answer. 16 A. I'm the guy who you asked. To me, that was a real 17 gun. End of the story. Like I can't add anything. To me, 18 that was a real gun. The guy was avoiding to go through the 19 metal detector. He was going around. I asked him to show me 20 the gun. He refused. He refused to speak English. I didn't 21 know what to do. To me, that was a real gun. I can't add 22 anything or I can't take anything. And I'm not going to go 23 and speculate it was like gun for my son or it was a plastic 24 gun or, I mean -- 25 Q. And I appreciate that. And I'm not denying that you VICKI HUMPHREY, CSR MANSFIELD, TX METRO(817)477-2035 PROKA AVRAMOVIC 105 1 thought it was a real gun and believed it was a real gun. My 2 question is: Can you prove to this Court and jury that it was 3 a real gun? 4 MR. RAY: Objection, form. 5 A. Can I prove? No, I cannot prove. 6 Q. Thank you. 7 A. I mean, how I going to prove? 8 Q. And you can't prove to this Court and jury that he 9 just didn't enjoy toy guns. 10 MR. RAY: Objection, form. 11 Q. You cannot prove that to a court and jury that this 12 guy just liked carrying toy guns. 13 A. I don't see a jury and I don't see a judge. 14 Q. This deposition is before a court and jury. 15 A. So we assume. 16 Q. Yeah. 17 A. Okay. Well, I don't know. Maybe it was a plastic 18 gun. It wasn't yellow, that's for sure. 19 Q. That's fine. Thank you. 20 A. Let's just move on. I'm going to answer yes or no. 21 How's that? 22 Q. I would love it. 23 A. Let's go. 24 Q. Why did the boat leave Hong Kong? 25 A. Well, I can't answer that question with yes or no, VICKI HUMPHREY, CSR MANSFIELD, TX METRO(817)477-2035 PROKA AVRAMOVIC 106 1 but to my knowledge, from what I heard, they didn't pay some 2 bills, so they have to leave Hong Kong. If that's true, I 3 don't know. That's what I heard. 4 Q. Do you know anything about Mexteam other than you saw 5 some business cards? 6 A. I heard that all purchase for the ship were going 7 through the Mexteam. 8 Q. You heard. 9 A. Yeah, I heard. 10 Q. Did you ever see anything delivered? 11 A. I haven't seen. I heard. 12 Q. Did you ever see anything delivered with -- by a 13 truck or a delivery person that said we're from Mexteam? 14 A. No. 15 Q. Okay. Did you ever see any money go to Mexteam? 16 A. No. 17 Q. How did Mr. -- did Plaintiff's lawyers come to know 18 the name Mexteam; do you know? Did you ever tell them that 19 name? 20 MR. RAY: Objection, form, speculation. 21 MR. PULLMAN: Apparently you're not listening to 22 my questions either. I said, did you ever tell them the name 23 Mexteam. 24 MR. RAY: Huh-uh. 25 Q. Did you ever tell them the name Mexteam? VICKI HUMPHREY, CSR MANSFIELD, TX METRO(817)477-2035 PROKA AVRAMOVIC 107 1 A. Did I ever tell them? No. 2 Q. Okay. When was the first time you spoke to 3 somebody -- Mr. Wiley about two weeks ago, you said. 4 A. Yeah. 5 Q. All right. Did Mr. Wiley tell you that Mr. Sikimic 6 was coming down and you could get a ride with him? 7 A. No. He was offering me a plane ticket. 8 Q. Did you take it? 9 A. No. I said that I would think about it. 10 Q. Did you take the plane ticket? 11 A. No, I did not take the plane ticket. 12 Q. Okay. 13 A. I didn't even say that I'm going to come. I said 14 that I will think about it. 15 Q. Well, when did you let him know that you would come? 16 A. I made a promise that I'm going to give him a call in 17 a couple of days and I did. 18 Q. When did you call him? 19 A. I think it was a Friday. 20 Q. Well, today's a Friday. So was it two weeks ago 21 today? 22 A. Two weeks ago. 23 Q. Okay. And tell me all the conversations you had with 24 anybody representing Allegiance Capital from that day when you 25 told him -- from the first time you spoke to Mr. Wiley until VICKI HUMPHREY, CSR MANSFIELD, TX METRO(817)477-2035 PROKA AVRAMOVIC 108 1 today at lunch, every conversation you had. 2 A. Okay. Mr. Wiley -- I introduced myself on the phone, 3 he introduced himself on the phone, then he was asking me what 4 was my position with the GCC, did I ever work on the ship for 5 the China Sea Discovery, who I work for. He also asked me if 6 I'm interested to come and testify what was going on on the 7 ship. He told me that -- if I'm aware of the prostitution on 8 the ship. I said that I was. He asked me did I ever saw any 9 prostitution on the ship. I said no. And that was pretty 10 much it. And then he offers me to come. And he said that -- 11 actually I refuse the first time to take the plane ticket, and 12 then when I call him back, I said that I will probably take 13 the ride with Mr. Sikimic, and Mr. David told me that when I 14 come here that he's going to pay for my expenses and that's 15 it. 16 Q. Has he paid for your expenses? 17 A. No. I didn't even ask. 18 Q. Are you going to? 19 A. Probably not. 20 Q. What business are you in today? 21 A. I'm on unemployment insurance. I'm not employed. 22 Q. When did you have your last job? 23 A. That was March -- no, June -- with GCC, June 24, 24 2003. 25 Q. Okay. Have you actively sought employment? VICKI HUMPHREY, CSR MANSFIELD, TX METRO(817)477-2035 PROKA AVRAMOVIC 109 1 A. Yes. I'm looking to get a job with the British 2 Columbia Lottery Corporation. 3 Q. Have you applied? 4 A. I did apply and I've been having some meetings with 5 them. 6 Q. Okay. Now, tell me all the other conversations you 7 had with Mr. Mahmood or anybody representing Allegiance 8 Capital. 9 A. We came here. We meet -- we met you, David. 10 Q. You've got to tell their names. 11 A. I'm sorry. 12 MR. RAY: Don Ray. 13 A. Ray and Mr. Michael Chu. 14 MR. CHO: Cho, C-h-o. 15 A. And David -- well -- 16 Q. When was this? 17 A. That was last -- yeah, yesterday afternoon. 18 Q. So even though the subpoena is dated Wednesday, you 19 got it yesterday? 20 A. No, 7th. 21 Q. I think today is the 9th. So you got the subpoena on 22 the 8th. It's dated the 7th, correct? 23 A. Yeah, I believe so. 24 Q. Okay. Tell me what other conversations you had. 25 A. Well, we just come here and they take me -- thank me VICKI HUMPHREY, CSR MANSFIELD, TX METRO(817)477-2035 PROKA AVRAMOVIC 110 1 for coming here. They ask me to tell the truth and not to 2 lie. It's in their interest to find the truth. And after 3 that, we didn't talk much about -- we went to dinner with Mr. 4 Dave -- 5 MR. RAY: Mahmood. 6 A. Mahmood, yeah. 7 Q. Okay. Did you and Mr. Sikimic discuss your 8 recollection regarding what you were going to testify to, your 9 recollection of the events? 10 A. In the car on the way here? No. 11 Q. Any time during your life. 12 A. What I'm going to testify here? No. 13 Q. Did you and Mr. Sikimic ever discuss the issues and 14 compare recollection or memory relating to what you've 15 testified -- about the stuff you've testified today? 16 A. No. 17 Q. Never. 18 A. Never. 19 Q. Okay. Why is it then for almost ten years you've 20 been making these complaints to the casino commission, or 21 whatever it's called, and nothing's ever been done to your 22 knowledge? 23 A. Yeah, they're -- 24 Q. What's been done? 25 A. Mr. Li (phonetic), one of the biggest fugitives from VICKI HUMPHREY, CSR MANSFIELD, TX METRO(817)477-2035 PROKA AVRAMOVIC 111 1 China, has been finally -- 2 MR. RAY: Objection, form. 3 A. -- barred from the British Columbia Lottery 4 Corporations. 5 Q. Okay. What else? 6 A. Well, you know, after he had that -- yeah, right 7 after when I left casino, I made sure that Holiday Inn, my 8 last location, was loan shark free, so I sent some tapes and 9 reports before when I left and I authorized some people to 10 give those reports to the agencies so those people could be 11 barred, and that's what the agency did. They went and they 12 contacted people who are still employed by GCC, which name I 13 refuse to testify, and agency contact those people and they 14 collect some tapes and evidence and they barred some of the 15 loan sharks from the Holiday Inn Casino. 16 Q. I don't understand what you're saying, which names 17 you refuse to testify. What are you talking about? 18 A. Before -- right before when I left my job with Great 19 Canadian Casinos, I actually kept a record of some big loan 20 sharks in our casino, which I was secretly tape and record 21 because I was -- been advised to do differently. So as soon 22 as I left, I left those tapes and reports in the possession of 23 the guy who is still employed by GCC. Agency contact that 24 employee and obtained those evidence and they barred those 25 loan sharks right after my departure from the Great Canadian VICKI HUMPHREY, CSR MANSFIELD, TX METRO(817)477-2035 PROKA AVRAMOVIC 112 1 Casino. If you ask me about the name, I refuse to tell you. 2 Q. Who told you to secretly tape things? 3 A. No one. 4 Q. Why did you choose to secretly tape and not advise 5 your employer that you were taping illegal activities? 6 A. I've been advised to turn my head. I've been advised 7 to break the law. How's that? And I don't like breaking the 8 law, so I was just keep doing my job secretly and preparing 9 myself for departure, and at the same time when I got 10 departure, I make sure that those people are barred from the 11 Holiday Inn Casino. 12 Q. And you're refusing to tell this Court and jury -- 13 A. Yes, the name of the currently employed GCC 14 employee. Agency knows, so... I'm not going to be the person 15 who's going to respond. 16 Q. I need to finish the question. You're refusing to 17 tell this Court and jury who you delivered these tapes to. 18 A. I didn't deliver the tapes. Everything was left in 19 the surveillance room, so I never took possession of any 20 documents. After when I left, I put it in a place that the 21 guy who I worked with told him that someone from agency will 22 come, that I will recommend that he will give those tapes and 23 evidence to agency. 24 Q. So let me make sure I understand this. You secretly 25 taped something. VICKI HUMPHREY, CSR MANSFIELD, TX METRO(817)477-2035 PROKA AVRAMOVIC 113 1 A. Yes. 2 Q. You left them behind. 3 A. Yes. 4 Q. Why didn't you -- If you're secretly taping them, why 5 didn't you take them directly to the agency? 6 A. Because I wasn't allowed to take any tapes or any 7 documents as soon as I was released. I mean, I signed this 8 release letter and it stated I can't take anything with me, so 9 I couldn't just take the tapes from the surveillance or take 10 the evidence. I mean, that's not the right way of doing it. 11 Q. When did you make these tapes? 12 A. All the time like I've been advised to turn my head, 13 you know, the other way I didn't. 14 Q. All right. Let's start over. We're not 15 communicating. 16 A. Okay. 17 Q. You testified earlier that you secretly made tapes. 18 A. Yes. 19 Q. You clearly secretly made the tapes prior to June 20 24th -- 21 A. Yes, statements and tapes. 22 Q. -- prior to June 24th, 2003; is that correct? 23 A. Yeah. 24 Q. When did you start secretly taping things? 25 A. Well, secretly, I had to do secretly because I have VICKI HUMPHREY, CSR MANSFIELD, TX METRO(817)477-2035 PROKA AVRAMOVIC 114 1 been told to do otherwise, and to my knowledge that was 2 illegal, so I was just keeping my job. And I had to keep 3 doing that secretly because I've been advised otherwise. 4 Q. When did you start secretly taping? 5 A. First time I've been told not to do that, I just kept 6 doing it, so we can call that I start like maybe as soon as I 7 come back from the ship. 8 Q. May of 2001? 9 A. Yeah. 10 Q. All right. So for two years you were secretly taping 11 things. 12 A. Yeah. 13 Q. That's a whole lot of tapes, isn't it? 14 A. Yeah. 15 Q. And you never took any of them out and took them to 16 the commission. 17 A. No, no. You don't understand how everything works. 18 Q. I'm asking you a question. Do you -- 19 A. You can't take the tape. Like first you have to 20 understand how everything works. You can tape secretly 21 whatever you want. You cannot physically remove the tape from 22 the surveillance room. You can place in a certain place in 23 the surveillance room and then let authorities know and then 24 they will come and request for that tape, and usually that's 25 how we, you know, get things done. VICKI HUMPHREY, CSR MANSFIELD, TX METRO(817)477-2035 PROKA AVRAMOVIC 115 1 Q. Why did you not go to the authorities between May of 2 2001 and June of 2003 and say -- 3 A. I did. 4 Q. I'm going to try again. If you let me finish the 5 question, we'll probably get finished quicker unless you know 6 my next question. Do you know the question? 7 A. I can guess. 8 MR. RAY: Objection, form. 9 Q. Well, that's the problem. 10 A. Because we've been guessing about those numbers, I 11 can guess your question. 12 Q. That's a good point. Why between May of 2001 and 13 June 23rd -- that's the day before you resigned -- 14 A. Uh-huh. 15 Q. -- did you not simply -- since you were making these 16 reports anyway to the casino commission, why didn't you tell 17 them to come pick up the tapes? 18 A. Well, I've been working with those people for almost 19 five years, and every time when I've been advised not to bar 20 someone, I always go to them confidential and I always make 21 that happen because I was telling them where the tapes are and 22 where the reports are, and they've been coming and asking for 23 that and that's how we end up getting rid of most of the loan 24 sharks. I couldn't go the proper channels because obviously 25 the company was refusing to deal with them. VICKI HUMPHREY, CSR MANSFIELD, TX METRO(817)477-2035 PROKA AVRAMOVIC 116 1 Q. Wait a minute. Did you or did you not make reports 2 between May of 2001 and June of 2003 to the commission? Yes 3 or no. 4 A. Sometimes. 5 Q. So you did make reports. 6 A. Yeah. 7 Q. Did you secretly tape between May of 2001 and 2003? 8 A. I think I used the wrong word "secretly tape". I 9 just keep doing my job. 10 Q. Did you continue to keep doing your job between May 11 of 2001 and June of 2003? 12 A. Yes, I did. 13 Q. And that was contrary to what your supervisor said, 14 don't tape this any more? 15 A. Yes. 16 Q. Okay. Why between May of 2001 and June 22nd of 2003 17 did you not simply with your report say, hey, there's tapes 18 here, come get them? 19 A. Well, because I would get in trouble with my 20 director. 21 Q. Oh, so you're telling this Court and jury that you 22 could get in trouble with your director by reporting something 23 to the -- 24 A. Yes. 25 Q. -- authorities? VICKI HUMPHREY, CSR MANSFIELD, TX METRO(817)477-2035 PROKA AVRAMOVIC 117 1 A. Authorities, yes. 2 Q. So for nine years you reported stuff to the 3 authorities -- 4 A. While I was a dealer, I didn't report when I was a 5 dealer. 6 Q. Okay. Starting with your security, you regularly 7 reported things to the authorities and it never bothered you? 8 A. When the policy took place. 9 Q. Do what? 10 A. When the policy took place. It wasn't always that 11 policy. 12 Q. When was the policy? 13 A. I don't know. We can speculate again, but we can 14 find that exactly. 15 Q. For many years you've been reporting to the 16 authorities. Is that correct or not? 17 A. Yes, five or six years. 18 Q. All of a sudden in June of 2001 -- May of 2001, you 19 decided to continue to do your job and continue to make 20 reports, and that's what you did. You continued to tape 21 despite what your supervisors told you not to do. 22 A. Yes. 23 Q. And you never told the authorities with these 24 reports, by the way, there's tapes, why don't you come pick 25 them up? VICKI HUMPHREY, CSR MANSFIELD, TX METRO(817)477-2035 PROKA AVRAMOVIC 118 1 A. I was always making calls on the side. 2 Q. Did you ever -- while you were there, did these 3 reports ever say, hey, by the way, there's tapes here, please 4 send somebody to pick them up? 5 A. Usually that was authorities that I've been telling 6 them, you know -- 7 Q. Let's try again. Did the reports ever say, there's 8 tapes here, come pick them up? 9 A. No. 10 Q. So you were just saving it so you could blackmail 11 your employer, isn't that correct, those tapes? 12 A. Well, it's not my fault because I realized that I'm 13 working for a crooked company. 14 Q. I see. 15 MR. PULLMAN: Let's take a break. 16 (Off the record.) 17 MR. PULLMAN: I'll pass the witness. Thank you. 18 MR. RAY: We have no further questions of the 19 witness. 20 21 (Whereupon, the deposition was concluded.) 22 23 ******* 24 25 VICKI HUMPHREY, CSR MANSFIELD, TX METRO(817)477-2035 119 1 CHANGES AND SIGNATURE 2 PAGE LINE CHANGE REASON 3 ________________________________________________________ 4 ________________________________________________________ 5 ________________________________________________________ 6 ________________________________________________________ 7 ________________________________________________________ 8 ________________________________________________________ 9 ________________________________________________________ 10 ________________________________________________________ 11 ________________________________________________________ 12 ________________________________________________________ 13 ________________________________________________________ 14 ________________________________________________________ 15 ________________________________________________________ 16 ________________________________________________________ 17 ________________________________________________________ 18 ________________________________________________________ 19 ________________________________________________________ 20 ________________________________________________________ 21 ________________________________________________________ 22 ________________________________________________________ 23 ________________________________________________________ 24 ________________________________________________________ 25 ________________________________________________________ VICKI HUMPHREY, CSR MANSFIELD, TX METRO(817)477-2035 120 1 I, PROKA AVRAMOVIC, have read the foregoing 2 deposition and hereby affix my signature that same is true and 3 correct, except as noted above. 4 5 PROKA AVRAMOVIC 6 7 THE STATE OF ) 8 COUNTY OF ) 9 Before me, , on this day personally appeared PROKA AVRAMOVIC, known to me (or 10 proved to me under oath or through ) (description of identity card or other document) to be the 11 person whose name is subscribed to the foregoing instrument and acknowledged to me that they executed the same for the 12 purposes and consideration therein expressed. 13 Given under my hand and seal of office this day of , 2004. 14 15 16 Notary Public in and for the State of 17 18 19 20 21 22 23 24 25 VICKI HUMPHREY, CSR MANSFIELD, TX METRO(817)477-2035 121 1 IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF TEXAS 2 ALLEGIANCE CAPITAL ) 3 CORPORATION, ) Plaintiff, ) 4 ) vs. ) CIVIL ACTION NO. 3:03-CV-0751-R 5 ) GREAT CANADIAN GAMING ) 6 CORPORATION, GREAT ) CANADIAN CASINOS, INC., ) U.S. District Judge Jerry Buchmeyer 7 ROSS MCLEOD, and MICHAEL ) SCHOLZ, ) U.S. Magistrate Judge Jeff Kaplan 8 Defendants. ) 9 10 REPORTER'S CERTIFICATION 11 DEPOSITION OF PROKA AVRAMOVIC 12 APRIL 9, 2004 13 I, Vicki Humphrey, Certified Shorthand Reporter in 14 and for the State of Texas, hereby certify to the following: 15 That the witness, PROKA AVRAMOVIC, was duly sworn by 16 the officer and that the transcript of the oral deposition is 17 a true record of the testimony given by the witness; 18 That pursuant to information given to the deposition 19 officer at the time said testimony was taken, the following 20 includes counsel for all parties of record: 21 DONALD A. RAY, MICHAEL S. CHO and DAVID L. WILEY, Attorneys for the Plaintiff 22 RICHARD D. PULLMAN, Attorney for the Defendants 23 24 I further certify that I am neither counsel for, 25 related to, nor employed by any of the parties or attorneys in VICKI HUMPHREY, CSR MANSFIELD, TX METRO(817)477-2035 122 1 the action in which this proceeding was taken, and further 2 that I am not financially or otherwise interested in the 3 outcome of the action. 4 Certified to by me this 3rd day of May, 2004. 5 6 7 8 VICKI HUMPHREY, Texas CSR No. 994 9 Expiration Date: 12-31-2004 5 Katie Court 10 Mansfield, Texas 76063 Metro 817/477-2035 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 VICKI HUMPHREY, CSR MANSFIELD, TX METRO(817)477-2035