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 ORAL DEPOSITION OF 11 NEBOJSA SIKIMIC APRIL 9, 2004 12 Volume 1 of 1 13 ************************************************************** 14 15 16 ORAL DEPOSITION OF NEBOJSA SIKIMIC, 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: NEBOJSA SIKIMIC 5 Examination by Mr. Ray ----------------------- 5 Examination by Mr. Pullman ------------------- 100 6 SIGNATURE AND CHANGES ---------------------------- 136 7 REPORTER'S CERTIFICATE --------------------------- 138 8 E X H I B I T S 9 10 11 EXHIBIT DESCRIPTION PAGE IDENTIFIED 12 1 Resignation letter 31 13 2 Notice to Staff 6 3 Release 41 14 4 Severance package 41 5 Subpoena 12 15 16 17 18 19 20 21 22 23 24 25 VICKI HUMPHREY, CSR MANSFIELD, TX METRO(817)477-2035 NEBOJSA SIKIMIC 4 1 MR. RAY: Before we get started, I just want to 2 ask Carl -- I think you've already stated this -- to Carl 3 Bolton. You are the representative for Great Canadian here 4 today? 5 MR. PULLMAN: He's not here being deposed. He 6 is here as a representative of the Defendants. 7 MR. RAY: That's all I want to know, Richard. 8 That's enough. Okay. Richard, on the agreements here, I 9 thought we'd see if we could agree to take this, you know, the 10 way we do it in the state, you know, objections, you know, 11 waived unless contemporaneously made; and, you know, you can 12 say object as to form, and if I've got some problem with 13 something, I can ask you what your problem is with the 14 question and you can tell me. And otherwise, we'll proceed 15 under the federal rules if that's agreeable. 16 MR. PULLMAN: That's fine. 17 MR. RAY: Okay. 18 19 20 NEBOJSA SIKIMIC, 21 the witness, first being duly cautioned and sworn to tell the 22 truth, the whole truth and nothing but the truth, so help him 23 God, testified as follows, to-wit: 24 25 VICKI HUMPHREY, CSR MANSFIELD, TX METRO(817)477-2035 NEBOJSA SIKIMIC 5 1 EXAMINATION 2 BY MR. RAY: 3 Q. Okay. Mr. Sikimic, before we get started here, I 4 want to tell you that you need to make a verbal response to 5 the questions I'm asking you so that the court reporter can 6 take them down. 7 A. Okay. 8 Q. You know, no head shaking or nodding or other 9 gesticulations because she can't record those, okay? 10 A. Okay. 11 Q. And if I ask you a question that you don't 12 understand, doesn't make sense to you, just say so; just stop 13 me and say I don't understand it. I'll try to rephrase it and 14 try to get it to where you can understand it. 15 A. Okay. 16 MR. PULLMAN: I need to go on the record, if I 17 may, before we start. There's been no notice that I've seen. 18 We received a letter and then a letter rescheduling. There 19 might have been a notice at the beginning. I don't even 20 remember. But it's my position that we're here by agreement, 21 and there are no specific terms other than the fact that you 22 asked me to come to these depositions. If there's some notice 23 that I don't recall, I need to see it as to both of these. I 24 don't know, is there a notice for both of these? I don't 25 know. VICKI HUMPHREY, CSR MANSFIELD, TX METRO(817)477-2035 NEBOJSA SIKIMIC 6 1 MR. WILEY: Yeah, there's a notice of deposition 2 or subpoenas for both. 3 MR. PULLMAN: For both? All right. If there 4 is, let's get them on the record. 5 MR. RAY: Yeah. I'm going to get to that 6 here -- 7 MR. PULLMAN: That's fine. If you've got them, 8 let's get them on. I just didn't remember. 9 MR. RAY: I notice that you have -- Well, let me 10 just finish up what I was saying. 11 Q. (By Mr. Ray) When I'm asking you the question or 12 if -- Mr. Pullman has a right to ask you questions too. If 13 you'd wait until the question is finished before you answer, 14 we'd appreciate that so the court reporter can take one at a 15 time. 16 A. Okay. 17 Q. We're going to take breaks from time to time, and 18 since I'm drinking a lot of water here, I'm probably going to 19 be taking more than usual. Before we proceed, though, I 20 notice that you've brought some papers here with you and I 21 thought we might take a look at those, maybe get those marked. 22 A. That's my resignation letter. That's the notice to 23 the staff from the president, and that's my release form and 24 my agreement with the company. I've got a copy of the same 25 thing. VICKI HUMPHREY, CSR MANSFIELD, TX METRO(817)477-2035 NEBOJSA SIKIMIC 7 1 Q. Okay. I want to make sure each one of those is 2 segregated separately. Is David getting the -- 3 MR. CHO: Yeah, he's getting the subpoena and 4 notice. 5 A. This says I'm not allowed to show anybody, but I 6 checked with a lawyer in Vancouver and she says in the case 7 of -- in a court case or subpoena that I'm allowed to present 8 this release form and -- 9 MR. PULLMAN: Object to all of that response as 10 being nonresponsive, move that it be stricken. 11 MR. RAY: I'm going to ask you to mark each one 12 of these as Plaintiff's Exhibit No. 1 through 4. 13 (Deposition Exhibits Nos. 1 through 4 were 14 marked for identification purposes.) 15 Q. Mr. Sikimic, have you reviewed any documents to 16 prepare you for this deposition? 17 A. No. 18 Q. Okay. Have you had any conversations with officers, 19 directors or other personnel employed by Great Canadian Gaming 20 Corporation or any of its subsidiaries concerning the 21 deposition? 22 A. Yes. 23 Q. Okay. Who did you have conversations with? 24 A. Adrian Thomas. 25 Q. Okay. What position does Mr. Thomas hold with Great VICKI HUMPHREY, CSR MANSFIELD, TX METRO(817)477-2035 NEBOJSA SIKIMIC 8 1 Canadian Gaming Corporation, if you know? 2 A. Right now I don't know. I think he's advisor or 3 consultant to Mr. McLeod, but at that time I think -- I know 4 he was president of Great Canadian Casino. 5 MR. PULLMAN: Object to all of the answer except 6 for "at that time I don't know". The rest of it's 7 nonresponsive. 8 Q. What position did he hold at the time that you talked 9 with him? 10 A. President of Great Canadian Casino. 11 Q. President of Great Canadian Gaming Corporation? 12 A. Incorporated, Inc., Great Canadian Casino, Inc. 13 Q. Great Canadian Casinos, Inc. 14 A. Yeah. 15 MR. PULLMAN: Object to the answer. 16 Q. Okay. Do you know whether or not he holds any 17 position with Great Canadian Gaming Corporation? 18 A. No. 19 Q. All right. What was the substance of your discussion 20 with Mr. Thomas concerning this deposition? 21 A. I told Mr. Thomas that somehow firm from Texas get my 22 phone number and I've been contacted by the lawyer, and the 23 lawyer's going to serve a subpoena and they want me as a 24 witness on some matters on the ship. So I show him subpoena. 25 I give him that subpoena. He's looking at that to check, you VICKI HUMPHREY, CSR MANSFIELD, TX METRO(817)477-2035 NEBOJSA SIKIMIC 9 1 know, do I have to go or not. And that's all. And the 2 last -- the last time I talked to him, I left a message that 3 I'm leaving to Dallas, Texas for the deposition or whatever up 4 here. 5 Q. Okay. He took the subpoena and you said he had it 6 checked to see whether or not you had to go? 7 A. Yeah. 8 Q. Okay. Do you know -- Did he tell you who he checked 9 with? 10 A. No. 11 Q. Okay. Did he -- 12 A. I know it's a lawyer, but I don't know what was the 13 name. He didn't say. He checked with a lawyer because in the 14 first place, you know, I didn't like to go. I don't want 15 something-something new just from no where, so I says, do I 16 have to go, so he took that to check, and he told me that I 17 don't have to go. 18 MR. PULLMAN: Object to the answer as being 19 nonresponsive, move it be stricken beyond what the answer -- 20 the question was. 21 Q. Okay. Did you talk with anyone else concerning the 22 deposition at Great Canadian Gaming Corporation or one of its 23 subsidiaries? 24 A. No. 25 Q. Okay. Has any person offered you any money or other VICKI HUMPHREY, CSR MANSFIELD, TX METRO(817)477-2035 NEBOJSA SIKIMIC 10 1 benefits in return for you refraining from cooperating or 2 testifying in this matter? 3 A. No. 4 Q. Can you give us a description of any conversation 5 that you -- or every conversation that you've had with anyone 6 regarding Allegiance Capital Corporation? 7 MR. PULLMAN: Object to the answer as calls for 8 a narrative; and to the question, object to the form of the 9 question. 10 Q. Have you had any question -- I mean, have you had any 11 conversations with anyone at Great Canadian Gaming Corporation 12 or one of its subsidiaries prior to coming here -- let me 13 finish -- prior to coming here to give your deposition 14 regarding Allegiance Capital Corporation? 15 MR. PULLMAN: Object to the form of the 16 question. Starting when? 17 MR. RAY: Well, at any time is what I'm asking 18 right now, Richard. 19 MR. PULLMAN: All right. From the beginning of 20 the world to today. 21 MR. RAY: From the beginning of the world to 22 right now, yeah. 23 MR. PULLMAN: That's fine. 24 A. Yeah, I discuss. I didn't know really, you know, 25 what's the reason was going on, and I mentioned that to Adrian VICKI HUMPHREY, CSR MANSFIELD, TX METRO(817)477-2035 NEBOJSA SIKIMIC 11 1 Thomas, the president, and at that time I've been told that he 2 doesn't know what's the reason and there is no chance the 3 company from Texas to get anything because they got what 4 they're supposed to get, now they're asking for more, and he 5 was under impression that, you know, there is no way, it's 6 just no case, and there's no reason to bother, but on the 7 other conversation -- 8 Q. Now, that's one conversation. Are you talking about 9 another conversation took -- 10 A. Yeah. 11 Q. When did the first conversation you just talked about 12 take place? 13 A. First conversation, I don't know. I have to check 14 back when I receive the call. I don't want to, you know, 15 state exactly the date, but say approximately four, five 16 months ago. 17 Q. All right. 18 A. And the second conversation is maybe a month, month 19 and a half ago. That was the last time I saw Mr. Thomas. And 20 that's when he brought up that the -- that company deserved 21 that, and if it goes to the court, there's some amount the 22 corporation is going to cover, and if they find him guilty, 23 the rest is going to go after the personal assets of 24 directors, and he mentioned Michael, his name, Ross. That's 25 the only thing. I didn't really know about numbers. All what VICKI HUMPHREY, CSR MANSFIELD, TX METRO(817)477-2035 NEBOJSA SIKIMIC 12 1 I heard it was like investing five, asking for 45 or something 2 like that. But, no, nobody mention, you know, exact amount or 3 what was the investment, what was he asking back. I don't 4 know that. He never mentioned that to me. 5 Q. Okay. What is your residence right now? 6 A. Port Moody, Number Two, Unit Number 2, 3343 Dewdney, 7 D-e-w-d-n-e-y, Trunk Road, Port Moody, B.C., postal code 8 V3H2E4. 9 MR. RAY: Okay. I'm going to just pause here 10 just for a minute. We had some discussion earlier about a 11 subpoena. This is the subpoena right here. Okay. Mr. 12 Pullman, I think, wanted to see this. 13 MR. PULLMAN: Just put it in the record is fine. 14 MR. RAY: Yeah, we'll just -- I guess we can 15 mark this Plaintiff's Exhibit No. 5. 16 (Deposition Exhibit No. 5 was marked for 17 identification purposes.) 18 Q. I'm showing you an exhibit there marked Plaintiff's 19 Exhibit No. 5. Could you identify that for the record, 20 please, sir? 21 A. Yeah. That's subpoena that I have been served with 22 my name. 23 Q. All right. While ago you stated your residence 24 address. How long have you lived there? 25 A. Approximately 12 years. VICKI HUMPHREY, CSR MANSFIELD, TX METRO(817)477-2035 NEBOJSA SIKIMIC 13 1 Q. Okay. And who lives with you at that address? 2 A. My wife and two kids. 3 Q. Okay. Where did you reside before that? 4 A. Pardon me? 5 Q. Where did you reside before that? I'm sorry. 6 A. It was same -- Coquitlam. Are you asking for address 7 or -- 8 Q. Well, did you -- How long have you lived in the city 9 that you're living in now? 10 A. Okay. When I move, '87, 1987. 11 Q. Okay. Why did you move to the address that you're 12 living in now? 13 A. I move in 1990. 14 Q. No, no, no, why? Why did you move? 15 A. We just get a -- it's a better deal. Townhouse from 16 two bedroom apartment, move to townhouse, bigger. 17 Q. All right. Were you born in Canada? 18 A. No. I was born in Yugoslavia. 19 Q. Okay. How did you come to go to Canada? 20 A. My sister, my uncle, my grandmother, they lives in 21 Vancouver, so in 1987 we discuss and I decide to come here and 22 try, you know, better life -- 23 Q. Okay. 24 A. -- new things, and we all move to Canada. 25 Q. You had family that was already in Canada. VICKI HUMPHREY, CSR MANSFIELD, TX METRO(817)477-2035 NEBOJSA SIKIMIC 14 1 A. Yeah, my sister, my grandmother, my uncle. 2 Q. All right. Did you seek employment with Great 3 Canadian Gaming Corporation? 4 A. Yeah. 5 Q. Pardon? 6 A. Yes. 7 Q. Okay. 8 MR. PULLMAN: I don't have any problems, but 9 let's lead less. Let's just ask him questions, otherwise I 10 will start objecting. 11 Q. All right. What was -- Why did you seek employment 12 with this company? 13 A. Why? 14 Q. Yeah. 15 A. It was good pay, pretty much at that time I 16 understand an easy job, and I start as a dealer in 1989 and go 17 from there. 18 Q. All right. How did you get the idea to seek 19 employment with the company? 20 A. There was ad in newspaper they're looking for 21 croupiers, new dealers for blackjack, and I went and ask on 22 the border because I used to work for the customs back home, 23 and at that time I wasn't citizen and supposed to have a 24 citizenship in order to work for government, so I don't have a 25 choice. So I went to work for the casino and stay there. VICKI HUMPHREY, CSR MANSFIELD, TX METRO(817)477-2035 NEBOJSA SIKIMIC 15 1 Q. Okay. Whom did you interview with when you first 2 approached them? 3 A. The interview was -- the manager was Walter. Yeah, 4 Walter Soo and Randy Soo. Those two brothers, they're 5 managers in -- one was the manager in Gilford, one was the 6 manager in Richmond. 7 Q. Randy Soo, was that the second one? 8 A. Yeah. 9 Q. R-a-n-d-y? 10 A. Yeah. 11 Q. Okay. Where did you interview? 12 A. In the Gilford Casino before I went to the head 13 office. I think it was on Dawson Street. And I don't know 14 what was the name of the lady, the administration. She works 15 there, took the name and -- 16 Q. All right. You said Gilford Casino. Is that 17 G-i-l-f-o-r-d? 18 A. Yeah. 19 Q. Okay. Was anyone present other than those 20 individuals at the interview that you named? 21 A. No. 22 Q. Okay. What were the questions that you were asked, 23 just generally speaking, in connection with your interview to 24 go to work for Great Canadian Gaming Corporation? 25 A. Why did I choose Great Canadian, how did I find out. VICKI HUMPHREY, CSR MANSFIELD, TX METRO(817)477-2035 NEBOJSA SIKIMIC 16 1 I mean, I went on a course before that was two -- two or three 2 weeks, blackjack course, that was going through the Great 3 Canadian Gaming Institute. So in order to get in there, you 4 have to pass the course. You get marks on the course, you 5 know, how you did, what you learn. So I pass that. They told 6 me go to the interview. They asked me why. Okay. There is 7 probation three months. There is another probation three 8 months. When you pass, I remember, you know, they give you a 9 little piece of paper that you pass probation. I have a 10 different code. Now you have a, say, steady job or whatever 11 and go from there. 12 Q. All right. Who actually hired you? 13 A. Walter Soo. 14 Q. Okay. Do you remember the date that you were hired 15 on? 16 A. Yeah. It was New Year 19 -- 1989, December 31st, 17 1989. 18 Q. All right. New Years Eve. 19 A. Yeah. He asked me if I want to work for New Years 20 Eve and that was my first shift. 21 Q. Okay. What I'd asked before was Great Canadian 22 Gaming Corporation. Was that the company that you were 23 working for or was it some other subsidiary? 24 A. At that time it was just Great Canadian Casino. 25 Q. Great Canadian Casinos? VICKI HUMPHREY, CSR MANSFIELD, TX METRO(817)477-2035 NEBOJSA SIKIMIC 17 1 A. Limited. 2 Q. Limited? 3 A. Yeah, Great Canadian Casino, Limited. Later on they 4 change the name and it get bigger and bigger, but -- 5 Q. Okay. 6 MR. PULLMAN: Object to the balance of the 7 answer as being nonresponsive. 8 Q. After you went to work for the company, did you 9 continue to work for the company with the name Great Canadian 10 Casinos or did you go to some other section or department or 11 subsidiary of the company after a while? 12 A. It was Great Canadian Casino for sure, and I was a 13 dealer. I was with the operation. They called that part 14 operation because I was a dealer. Since 1993, in June, July 15 1993 when we opened the Renaissance, I've been asked to move 16 to security department. 17 Q. The Renaissance. What exactly is the Renaissance? 18 A. Renaissance is the name of the hotel where we open 19 the new casino. 20 Q. I see. Is it called the Renaissance Casino? Is that 21 what -- 22 A. Yeah. 23 Q. Okay. When you went to the Renaissance, were you 24 still working for Great Canadian Casinos, Limited? 25 A. Yeah, it was Great Canadian Casino, security VICKI HUMPHREY, CSR MANSFIELD, TX METRO(817)477-2035 NEBOJSA SIKIMIC 18 1 department. 2 Q. Security. What were your duties in that connection? 3 A. At that time I was floor security, you know, make 4 sure that nobody under-age walks in and play and look after 5 the staff. That's when I get train to surveillance. Same. 6 That was, you know, watching the games, monitoring the games 7 because I had the game experience, I was a blackjack dealer, 8 roulette dealer, all the games, so they thought that was a 9 good idea. So I was trained there for surveillance. I was 10 move after five, six months. I went for seven, eight weeks on 11 the island when we opened the new casino. 12 Q. Let me just stop you just for a minute. 13 A. Victoria. 14 Q. You said you were trained for surveillance. 15 A. Yeah. 16 Q. What did that training involve? 17 A. Showing how to -- you know, how to operate, I think 18 that was at that time 9500 Pelco system, you know, how you 19 press the buttons, how you move the cameras, what you do and 20 how you change the tapes and basic -- you know, nothing really 21 special. 22 Q. Were you only trained to use the equipment 23 technologically or were you trained in any other regard about 24 what to look for? 25 A. What to look for you get through the experience, you VICKI HUMPHREY, CSR MANSFIELD, TX METRO(817)477-2035 NEBOJSA SIKIMIC 19 1 know, through the -- I mean, you deal with different 2 situations every night, you know. Doesn't matter if you kick 3 somebody out, if somebody tried to cheat. It's not every 4 night. Sometimes they try. But you're watching for some 5 suspicious moves and try to keep that on the tapes and look 6 after that, inform your boss what's going on and go from 7 there. But there's no special training or -- 8 Q. Was this surveillance over just the customers or did 9 it also include the employees? 10 A. Whole casino, you know, customers, employees, 11 everybody. 12 Q. All right. The date that you went from the 13 Renaissance to the next position, what was that? 14 A. That's what I mentioned earlier, that Pelco 9500 15 system that's in surveillance. At that time that was the 16 newest that they use in casino. So when we open casino on 17 Mayfair, Victoria Island, there was -- they put the same 18 system and I was apparently the only one who knew how to 19 operate that, so I went with another guy and spend there a 20 couple of months training the staff and -- 21 Q. All right. The Mayfair, could you give me the actual 22 name of that operation? 23 A. That's Victoria, B.C., Great Canadian Casino, 24 Victoria. 25 Q. Great Canadian Casino, Victoria? VICKI HUMPHREY, CSR MANSFIELD, TX METRO(817)477-2035 NEBOJSA SIKIMIC 20 1 A. Yeah. That's on the island, yeah. 2 Q. Okay. What does this name Mayfair, what does that 3 mean? 4 A. Mayfair, it's -- I think it's a mall or square or 5 part of the -- I'm not sure. I don't know if -- 6 Q. The area which the casino operated? 7 A. It's on the Victoria Island. 8 Q. And Mayfair was the name of a -- 9 A. Maybe it's the mall across the casino. 10 Q. All right. And you went there a few -- You went to 11 the Renaissance in '93. When did you go to this Mayfair 12 operation? 13 A. Maybe '94. 14 Q. '94? 15 A. About '94, yeah. 16 Q. Okay. And then from there where did you go? 17 A. When I come back, I get transferred to Richmond as a 18 security supervisor. 19 Q. And when was that? 20 A. That was '94. 21 Q. Okay. So you were only at the Mayfair then a short 22 time? 23 A. Yeah, just for a couple of months. 24 Q. Okay. And you were in Richmond -- I'm sorry. Say it 25 again. VICKI HUMPHREY, CSR MANSFIELD, TX METRO(817)477-2035 NEBOJSA SIKIMIC 21 1 A. Supervisor. 2 Q. Okay. Supervisor of what? 3 A. Security supervisor. 4 Q. Okay. And what is the casino in Richmond known as? 5 Has it got a name? 6 A. Richmond Casino. 7 Q. Okay. All right. And how long were you there in 8 that capacity? 9 A. Three, four years. Between three and four years. 10 Q. Okay. So you would have left in either '97 or '98; 11 is that correct? 12 A. Yeah. 13 Q. Okay. Where did you go from there? 14 A. From there I went to Holiday Inn Casino. 15 Q. I'm sorry? 16 A. Holiday Inn. 17 Q. Holiday Inn? 18 A. It's on West Broadway in hotel Holiday Inn. 19 Q. West Broadway in Vancouver? 20 A. Vancouver. 21 Q. Okay. What were your duties there? 22 A. Security manager. 23 Q. Okay. And how long were you there? 24 A. I was there actually up to the last day. My office 25 was there later on when I get promoted. I get the office at VICKI HUMPHREY, CSR MANSFIELD, TX METRO(817)477-2035 NEBOJSA SIKIMIC 22 1 the Holiday Inn, so I was there until 2003 only with a 2 different title. 3 Q. Okay. Right up until the time -- 4 A. Yeah. 2000 I was promoted to director of 5 surveillance. No, no, sorry. Before I was a regional 6 manager, regional manager for Holiday Inn and the 7 Renaissance. That's the two casinos. I mean, I have to go 8 into detail. Sorry, but -- 9 Q. All right. Let me back up just a minute and make 10 sure we get this clarified then. When you came to the 11 Richmond Casino in '94 -- 12 A. Yeah, I was a supervisor. 13 Q. You were a supervisor just to the Richmond Casino? 14 A. Yes. I moved to Holiday Inn -- 15 Q. In '97 or '98. 16 A. -- '97, '98 for the security manager. In about 17 '99 -- 18 Q. Hold it just a minute. Security manager of what? 19 A. Security manager of Holiday Inn Casino. 20 Q. Just the Holiday Inn Casino. 21 A. Yeah. 22 Q. Okay. And then what from there? 23 A. From there I was promoted to regional manager of 24 security for the two casinos: Holiday Inn and the 25 Renaissance. VICKI HUMPHREY, CSR MANSFIELD, TX METRO(817)477-2035 NEBOJSA SIKIMIC 23 1 Q. Okay. When did that take place? 2 A. '99. 3 Q. Okay. And then what? 4 A. And in 2000, I was promoted to director of 5 surveillance. We split department. Government was requiring 6 of their DA's to split security and surveillance. 7 Q. Okay. Hold on just a minute. You say in 2000 you 8 were appointed director of surveillance. What did that cover? 9 A. All the casinos, Great Canadian Casinos. 10 Q. All the casinos of Great Canadian Casinos, Limited? 11 Is it still known as that by then? 12 A. Now it's Inc., Incorporated. 13 Q. Okay. All right. You became -- in 2000 you became 14 security director of -- 15 A. No, surveillance director. 16 Q. Surveillance. I'm sorry. Surveillance director. 17 A. Surveillance director of all the Great Canadian 18 Casinos. 19 Q. Of all Great Canadian Casinos, period, anywhere in 20 the world. Would that be so? 21 A. Yeah. And six or eight months after that, the 22 director of security -- they were split -- he got sick, so 23 he's in the long-term disability. So at that time they give 24 me both departments. It's about 2001, I would say. So now 25 I'm director of security and surveillance. So all the VICKI HUMPHREY, CSR MANSFIELD, TX METRO(817)477-2035 NEBOJSA SIKIMIC 24 1 security was under me. 2 Q. Okay. As director of surveillance, who did you 3 answer to? 4 A. Executive vice-president, Brian Egli. 5 Q. You didn't have to answer to the director of 6 security? 7 A. As -- 8 Q. Director of surveillance. 9 A. No. That was higher than director of security. 10 Q. Oh, okay. 11 A. Surveillance was higher than security. 12 Q. All right. That's what I wanted to know. Okay. And 13 then so as director of surveillance, you answered to Brian -- 14 I'm sorry. What was his last name? 15 A. Brian Egli, executive vice-president. 16 Q. Could you spell that last name for the court 17 reporter? 18 A. E-g-l-i. E-g-l-i. 19 Q. Okay. And you said he was executive vice-president? 20 A. Yeah. 21 Q. Of Great Canadian Casinos, Inc.? 22 A. Inc., yeah. He was before director of security. So 23 he move up to executive vice-president and I took his spot. 24 Q. Okay. All right. How many people were you 25 responsible for supervising when you were director of both VICKI HUMPHREY, CSR MANSFIELD, TX METRO(817)477-2035 NEBOJSA SIKIMIC 25 1 security and surveillance? 2 A. It's about 160. 3 Q. Okay. Did these people -- Scratch that. How many of 4 these people were required to make reports to you? 5 A. All of them. 6 Q. Well, I mean, were there any sort of tiers of 7 responsibility here? 8 A. Yeah. There is a policy that any report made by 9 security or surveillance should go through me, so I was aware 10 of any -- anything that happened in casino. They write a 11 report and send it to me, so... 12 Q. All right. Well, if something happened at the very 13 lowest level by some individual out here and he had a report 14 to make, would he make that directly to you or would he make 15 it to someone else that -- 16 A. To the manager. 17 Q. All right. That's what I'm looking for. There were 18 managers under you. Is that what you're saying? 19 A. Yeah, managers and supervisors. 20 Q. Okay. What I'm trying to get a picture of is what 21 the organization was. Who were the individuals that were 22 directly under you? 23 A. Under me was assistant director of security. 24 Q. Okay. 25 A. There was regional manager of compliance and VICKI HUMPHREY, CSR MANSFIELD, TX METRO(817)477-2035 NEBOJSA SIKIMIC 26 1 investigation. There's casino managers and supervisors. 2 Q. Casino managers, you're talking about managers of the 3 casinos, just security. 4 A. I'm talking about security only. 5 Q. Okay. All right. And these managers, were they on a 6 lower level than the -- I know you had an assistant there, but 7 once you get past him, I'm trying to get the hierarchy here, 8 okay, if you understand what I'm saying. 9 A. We had a chart, so... 10 Q. There was a chart? 11 A. Yeah. It's myself, it's assistant director, it's the 12 regional manager, managers, supervisors. 13 Q. Okay. All right. And if there was a report made 14 about anything that happened having to do with security in the 15 casinos, would the report travel up through that hierarchy or 16 was it possible for certain people to be skipped there and 17 come directly to you? 18 A. They didn't skip. They send to the manager and copy 19 was sent to me, so manager got it. You know, when I see it's 20 something that they can handle, I don't bother. If it's 21 something that needs my involvement, I'll do it. 22 Q. Okay. And I think you said earlier -- I want to make 23 sure I understand it correctly. Although you got promoted 24 after '97 or '98, your office remained at the Holiday Inn -- 25 A. Yeah. VICKI HUMPHREY, CSR MANSFIELD, TX METRO(817)477-2035 NEBOJSA SIKIMIC 27 1 Q. -- up until the end of your employment; is that 2 correct? 3 A. Yes. 4 Q. What was your -- At the time that you arrived at the 5 end of your employment, what was your compensation? 6 A. The end of my employment? 7 Q. Yes, up to that point, at that point. Let's say in 8 the last year of your employment. 9 A. What would you like to know exactly? 10 Q. Well, how much were you paid, what was your salary? 11 A. I was -- I get $85,000.00 a year. 12 Q. Is that Canadian? 13 A. Yeah. 14 Q. All right. And what else? 15 A. I get profit-sharing. 16 Q. Describe that, if you would, please. 17 A. Profit-sharing, it's a public company. You know, 18 whenever we make a profit in company, you know, so there is 19 extra amount that on the end of the year every year we split 20 with the employees. All depends on the level how much you 21 get. And say it's between ten and 15,000 a year. I get a 22 company car, I get all expenses. And when we're in the car, 23 you know, that car was burned a couple of days ago. 24 Q. Your company car was burned? 25 A. Yeah. When I -- two days after I left there, I VICKI HUMPHREY, CSR MANSFIELD, TX METRO(817)477-2035 NEBOJSA SIKIMIC 28 1 received the call and I get a -- I can provide you with the 2 claim number that it's arson. That's what the story from the 3 fire department, so... 4 Q. And that happened how long ago? 5 A. Two days ago. 6 Q. Two days ago. 7 A. Yes. 8 Q. What kind of a car was it? 9 A. It's a Jaguar XJR. 10 Q. What year? 11 A. '97. 12 Q. Did you have an employment contract with the company, 13 a written contract, I mean? 14 MR. PULLMAN: I object to all of that stuff 15 about the car as being nonresponsive and hearsay. 16 Q. Okay. Did you have -- Did you have a written 17 contract with the company? 18 A. On what? On my salary or -- No, I did not have a 19 contract, no. I was just normal. 20 Q. Okay. When you received a paycheck, what name was on 21 the check, what company? 22 A. Great Canadian Casino, Inc. 23 MR. PULLMAN: Object to the answer as being 24 hearsay, best evidence. 25 Q. And who signed your checks? VICKI HUMPHREY, CSR MANSFIELD, TX METRO(817)477-2035 NEBOJSA SIKIMIC 29 1 A. There's Adrian Thomas, Grace Su, Brian Egli. That's 2 the people I know that was signing authority, so... 3 MR. PULLMAN: Object to the answer as being 4 hearsay. 5 Q. Okay. Were those -- Are you telling me that those 6 signatures appeared on your checks from time to time or just 7 one? 8 A. No, we got direct pay through some company that I 9 don't think that's -- even they don't sign the check. I don't 10 see. Somebody else sign through the electronic data or -- 11 Q. All right. Fair enough. 12 A. It's direct payment through the bank, so... 13 Q. Okay. During the last year of your employment, can 14 you give me some sort of a description of what you might do, 15 say, on an average day or an average week? Kind of lead me 16 through it here a little bit. 17 A. Sure. The first thing I go and -- first thing in the 18 morning go to Holiday Inn where is my office, check the 19 e-mail, check the audit reports; and from there, if there's 20 any problem on the locations, go and try to fix the problem. 21 Actually in the last year, most of the time I spend in 22 Coquitlam because that was the new area that -- you know, new 23 casino that was open with the slots and number one casino, so 24 I spent quite a lot of time in Coquitlam, and the other one 25 that I spend time is Richmond because that's where the most VICKI HUMPHREY, CSR MANSFIELD, TX METRO(817)477-2035 NEBOJSA SIKIMIC 30 1 other problems and things that I have to deal. 2 Q. It was your -- Are you saying that it was your duty 3 to move around from casino to casino and check on things? 4 A. Yeah, yeah. Also my duty was the budget, you know, 5 doing budget for security and surveillance, promotion, hiring, 6 firing. 7 Q. As far as you know, were there any records kept with 8 regards to your performance on the job? 9 A. I'm sure it is, yeah. 10 Q. Okay. Did you ever see those records? 11 A. '98 or '97 when I get promoted to the manager, they 12 show me that it was high mark, all the best, never had a 13 problem, everything was -- 14 Q. Okay. Do you know whether or not you ever got 15 written up for any deficiencies of any kind? 16 A. Never. 17 Q. Okay. Did you ever receive any special commendations 18 of any sort? Do you understand what I'm saying there? 19 A. No. 20 Q. See if I can rephrase that. 21 MR. PULLMAN: Awards. 22 Q. Yeah. Did you ever receive any awards for exemplary 23 performance at -- 24 A. Yeah, I receive -- That could be awards. I got 25 25,000 stock options as $2.25. That was one part, you know. VICKI HUMPHREY, CSR MANSFIELD, TX METRO(817)477-2035 NEBOJSA SIKIMIC 31 1 The other one, you know, we used to have the Christmas bonus. 2 Got two or $3,000.00 for that. And as I mention, after we 3 change that and it's profit-sharing, and I think the last one 4 was $13,000.00 that I get. 5 Q. Was this something that was just done as a matter of 6 course or was it tied to your performance? 7 A. I don't know. 8 Q. Okay. Fair enough. Are you still working for Great 9 Canadian Casinos, Inc.? 10 A. No. I resigned May 12th, last year, and I'm still 11 under contract. I still get paid until May 13th, I guess. 12 Q. May 12th of '03; is that right? 13 A. Yeah. 14 Q. Okay. I'm going to show you what's been marked as 15 Plaintiff's Exhibit No. 1. Could you identify that for us, 16 please, sir? 17 A. Yeah. That's my resignation letter. 18 Q. Okay. All right. Who did you actually give this 19 letter to? 20 A. To Mr. Adrian Thomas, president of the Great 21 Canadian, Inc. 22 Q. Now, we're talking about Great Canadian Casinos, Inc. 23 or are we talking about -- 24 A. Great Canadian Casinos, Inc., yeah. 25 Q. Okay. All right. That's who you gave this letter VICKI HUMPHREY, CSR MANSFIELD, TX METRO(817)477-2035 NEBOJSA SIKIMIC 32 1 marked Plaintiff's Exhibit No. 1 to. 2 A. Yes. 3 Q. Why did you terminate your employment? 4 A. There was a problem in the -- one of our casinos, the 5 Richmond Casino. There's report of chip theft, missing chips 6 from the table, and at that time I was present in the casino, 7 and there was an investigation. During that investigation, 8 tapes are missing, tapes are over-recorded, there's -- 9 Q. Let me stop you just for a minute. You say tapes are 10 over-recorded. What do you mean by that? 11 A. That means something that was recorded is not there. 12 Somebody record something on the top of that, so you don't see 13 the -- what happened. Like when you record the tape, you can 14 over-record, you can erase, okay, erase from the tapes. 15 Q. How can you tell that? 16 A. I've been told because that's the evidence that's 17 missing, you know. When they got -- they did investigation 18 and now there is a part that's missing from those tapes. You 19 know, that's -- I mention here because of everything, one of 20 the reasons that I quit, it's also that thing, so... 21 Q. Okay. Let me see if I can understand what you're 22 talking about there. And I'm just trying to kind of rephrase 23 what you said. If I'm saying it wrong, tell me. My 24 understanding of what you said is that there were some tapes 25 made and that they had been changed, and let me ask you this: VICKI HUMPHREY, CSR MANSFIELD, TX METRO(817)477-2035 NEBOJSA SIKIMIC 33 1 Do the tapes have like dates and times on them -- 2 A. Yes. 3 Q. -- as they flow? Okay. And when I ask you how they 4 could be changed, can you explain to me, you know, about these 5 dates and times? I don't know much about this myself. I'm 6 trying to get it from you. 7 A. When you put the tape back, you record. Like every 8 seven days we change the tapes. 9 Q. Uh-huh. 10 A. So whatever was recorded on the tape, you put there 11 and record it again and keep doing that, keep doing that. So 12 apparently somebody -- I didn't see it. I was on the case for 13 three days, I guess, and after that I resigned and I've been 14 told to stay away because it's my brother-in-law, my friends 15 involved, so I don't know yet what's official. I don't know 16 if -- you know, officially what they're blaming. I didn't get 17 it. I understand I was told I was under investigation by the 18 GPEB. That's the -- what's the short for GPEB? They're in -- 19 Q. Give me the initials first. What are you saying? G 20 what? 21 A. G-P-E-B. 22 Q. G-P-E-B. 23 A. Gaming Public Enforcement Branch. Gaming Public 24 Enforcement Branch. They're in charge for, you know, issuing 25 the license to work in the casino, check your background, you VICKI HUMPHREY, CSR MANSFIELD, TX METRO(817)477-2035 NEBOJSA SIKIMIC 34 1 know, they do the interview, check -- they have all rights to 2 check everything about you. You sign the release that they 3 can -- 4 Q. They are a government entity? 5 A. Yes, yes. 6 Q. Okay. 7 A. And I was -- 8 Q. Who else was involved in this investigation with the 9 company besides you? 10 A. Everybody that I know: Brian Egli, Patrick Ennis, 11 Adrian Thomas, Milan, original manager for investigation. 12 Q. That last person you named? 13 A. Milan, M-i-l-a-n. 14 Q. Okay. Do you know any other name -- 15 MR. PULLMAN: Object to the answer as being 16 hearsay. 17 Q. Can you tell me -- Can you tell me what that 18 person's -- Milan's name -- is that a first name or a last 19 name? 20 A. First name. 21 Q. Okay. What was his last name? 22 A. Bajcic, B-a-j-c-i-c. 23 Q. Okay. How did you know these people were involved in 24 the investigation? 25 A. Because it's their job and they took the tapes. They VICKI HUMPHREY, CSR MANSFIELD, TX METRO(817)477-2035 NEBOJSA SIKIMIC 35 1 took possession of the tapes. Adrian, Patrick, Brian, they 2 have the tapes in their possession for a few days looking at 3 them in the head office. 4 Q. Okay. Did any of them discuss the investigation with 5 you? 6 A. Not really. I saw -- the last time that I remember, 7 that Saturday or Sunday I was there, I saw -- they show me 8 some tapes. Nothing particularly discuss about, you know -- 9 That's when I find out that there's missing -- some parts on 10 the tapes are missing. I think still it's under investigation 11 as far as I know, so... 12 Q. Were there any other reasons for you terminating your 13 employment? 14 A. Yeah, yeah. One of the -- 15 Q. Can you state what those are, please? 16 A. Everything dealing with loan sharks, dealing with 17 problems not getting back up from your bosses and -- 18 Q. Okay. Hold it just a minute. You mentioned loan 19 sharks. 20 A. Yes. 21 Q. What are we talking about here? 22 A. We're talking about people that lend you money and if 23 you don't pay them, they go after you on many, many different 24 ways. 25 Q. Okay. What has that got to do with the casinos, VICKI HUMPHREY, CSR MANSFIELD, TX METRO(817)477-2035 NEBOJSA SIKIMIC 36 1 though? 2 A. Every casino has -- they operate in our casinos. 3 They're a part of business. 4 Q. Okay. I'm going to see if I can understand what 5 you're saying. Are you saying that individuals are operating 6 as loan sharks in the casinos or are you saying -- 7 A. Yeah, individuals are operating in the casinos as 8 loan sharks. 9 Q. Okay. Did you ever make any reports concerning loan 10 sharks while you were there? 11 A. Yes, yes. 12 Q. Who did you make those to? 13 A. I made reports to Brian Egli, Adrian Thomas, even 14 when we brought ex-director from GPEB, Mr. Carl Bolton, he was 15 aware of that. 16 Q. Are you talking about Mr. Bolton that's here in this 17 room? 18 A. Yes. 19 Q. Okay. Mr. Bolton was the director of -- 20 A. GPEB. That's the -- that I brought earlier. That's 21 the Gaming Public Enforcement Branch. That's the company that 22 go out, you know, issue the license to people who work in the 23 casino, check your background and criminal record and 24 everything else. We have to do total disclosure, you know, 25 that we signed and -- VICKI HUMPHREY, CSR MANSFIELD, TX METRO(817)477-2035 NEBOJSA SIKIMIC 37 1 Q. All right. You made these reports to these 2 individuals. Did you name all the individuals you made the 3 reports to just then? 4 A. Yes. Also Patrick Ennis was -- that was my 5 assistant. He was -- he knew about that. 6 Q. All right. Can you give me the dates that you made 7 the reports, approximately? 8 A. Approximately, the last one that I made about loan 9 sharks activities specifically was maybe two or three weeks 10 before I resigned. 11 Q. Okay. How many reports did you make concerning loan 12 sharks while you were holding this position of director of 13 surveillance and security? 14 A. More than six maybe. I don't know. Seven, eight at 15 least. 16 Q. Okay. Can you give me some kind of idea over what 17 time period? 18 A. What time period? 19 Q. Yes, sir. 20 A. Maybe a year. 21 Q. Okay. I'm still not quite sure I totally understand 22 the situation there with the loan sharks. Could you describe 23 to me what you're actually talking about here that you made 24 your reports on to your superiors, what activity? Could you 25 describe the activity for us, please? VICKI HUMPHREY, CSR MANSFIELD, TX METRO(817)477-2035 NEBOJSA SIKIMIC 38 1 A. The activity, it's the biggest problem. Government 2 is -- they know what's going on. Even police knows, the GPEB. 3 Q. No, no, excuse me. I'm not asking you who knows. 4 I'm asking you to describe -- 5 A. You walk in the casino -- 6 Q. When you say loan sharking, what's happening there 7 specifically? 8 A. I walk in the casino and I see you playing and you 9 have only a couple of hundred left, so I offer you money. I 10 says, You want 10,000? He says yes. I give you 10,000 and I 11 tell you -- I say tomorrow you're going to give me 11,000. I 12 come to see you tomorrow. If I don't see you tomorrow, it's 13 not 11,000, it's 12,000. Next week it's 15,000. Two weeks 14 after that it's your car. Doesn't matter if it's Mercedes, 15 BMW or whatever. You sign the car to loan sharks, they sell 16 it, and that's how the things work. 17 Q. Okay. And this is what you were reporting to your 18 superiors? 19 A. There is activities. They knew. They knew that. I 20 did report and they knew, and the few times we went -- well, 21 the first one they actually barred 19 people from loan 22 sharking, but you bar 19, the top three stays there and they 23 bring another 15 runners and they keep doing that. It's 24 just -- it's a part of the casino, so that's -- 25 Q. The top three, what do you mean by the top three? VICKI HUMPHREY, CSR MANSFIELD, TX METRO(817)477-2035 NEBOJSA SIKIMIC 39 1 A. The big three lenders, the big three guys. Say, you 2 know, you're the one that handle $500,000.00 through all of 3 us, give us 50 each and we go -- you know, we are runners. We 4 lend the money, and if you don't pay, we probably go break 5 your legs or do something else. There was shooting, there was 6 people found dead in the car and everything, and everything 7 was connected to the loan sharks, so it's not a group of, you 8 know, people that you would mess with, so... 9 MR. PULLMAN: I object to this line of 10 questioning. I think it's clear that you're entitled to go 11 into his background. I don't see in any way what this has to 12 do with the motions and the issues on the table today. And 13 with your permission, I would like to not have to object every 14 time you ask the question, but if you want me to, I will. 15 It's up to you. 16 MR. RAY: Well, Richard, you can make a running 17 objection, I guess, to all the questions concerning the loan 18 sharks if you want to. I'm still trying to completely 19 understand what we're talking about here. 20 MR. PULLMAN: Okay. So I'll just object when I 21 deem necessary. 22 MR. RAY: Okay. 23 MR. PULLMAN: That's fine. 24 MR. RAY: Yeah, I understand your problem there, 25 but I need to kind of follow up here just a little bit. VICKI HUMPHREY, CSR MANSFIELD, TX METRO(817)477-2035 NEBOJSA SIKIMIC 40 1 MR. PULLMAN: And for the record, I think you're 2 clearly entitled to get the record square as to why he chose 3 to resign, and it's the same issues that I'm going to cover if 4 I don't think you've covered it right, but I also take the 5 position that anything other than the issues before this court 6 today are not relevant to this deposition, so we'll just go as 7 we may. And I think in this situation we both are entitled to 8 get as much background to square it out, so just play as we 9 play. 10 MR. RAY: All right. Fair enough. 11 Q. (By Mr. Ray) Mr. Sikimic, I think you told us that 12 these loan sharks were operating as individuals. 13 A. Yes. 14 Q. Okay. Was there any connection that you know of 15 between them and the company that you worked for? 16 A. No. 17 Q. Okay. Was there any way for the -- your superiors to 18 be aware of that without you telling them? 19 A. Yes. 20 Q. Okay. What would that way have been? 21 A. They heard from their managers, probably from 22 operation managers, they heard from government. 23 Q. Okay. 24 A. So they're asking for -- you know, for details. 25 Q. What -- How could the casinos benefit from the loan VICKI HUMPHREY, CSR MANSFIELD, TX METRO(817)477-2035 NEBOJSA SIKIMIC 41 1 shark operations? 2 A. If you don't have money with you, you stop playing. 3 If you get the money, you're going to keep playing and 4 unfortunately going to lose. 5 Q. All right. Did you have any other issues with the 6 company in connection with your severance here -- 7 A. No. 8 Q. -- that you were upset about? Sorry? 9 MR. PULLMAN: He said no. 10 Q. Okay. Did you have a severance agreement with the 11 company when you left? 12 A. I beg your pardon? Did I have a severance agreement 13 with the company when I left? 14 Q. Yes, sir. Yes. Do you understand that question? 15 A. Yeah. The day after I resign they gave me that 16 agreement. That's the severance here. 17 Q. Okay. Are you talking about -- I'm going to show you 18 what's been marked Plaintiff's Exhibit No. 3. Could you 19 identify for us, please, this document? 20 A. Yeah, that's release between Great Canadian Casino, 21 Incorporated and myself as employee. This is the release that 22 tells that I'm not allowed to -- this is -- this one is about 23 my severance. That's the package. That's the deal that I 24 got, Exhibit 4. 25 Q. Your severance package. VICKI HUMPHREY, CSR MANSFIELD, TX METRO(817)477-2035 NEBOJSA SIKIMIC 42 1 A. Yeah. 2 Q. Okay. This is -- You're speaking of a document 3 marked Plaintiff's Exhibit No. 4; is that correct? 4 A. Yes. 5 Q. Okay. Before I -- much to Richard's chagrin here, 6 before I leave the loan sharking business here, did anyone, 7 any one of your superiors with the company ever instruct you 8 to leave the loan sharking alone? 9 MR. PULLMAN: Object to that question. It's 10 totally irrelevant. 11 A. Yes. 12 MR. PULLMAN: Excuse me. You cannot answer a 13 question until I'm finished with objecting, so I'd move that 14 to be stricken. Right now I'm going to finish my -- 15 MR. RAY: Go ahead. 16 MR. PULLMAN: Are you going to allow -- 17 MR. RAY: Go ahead, Richard. 18 MR. PULLMAN: I object to that question as being 19 totally irrelevant to the issues before this court. 20 Q. Okay. Now you can answer it. I'm sorry. What was 21 your answer again? 22 A. I said yes. 23 Q. Okay. Who told you this? 24 A. Casino manager and president. 25 Q. Casino manager. Can you give me a name? VICKI HUMPHREY, CSR MANSFIELD, TX METRO(817)477-2035 NEBOJSA SIKIMIC 43 1 A. Casino managers probably knew who are the big -- 2 MR. PULLMAN: I object to this answer. You 3 asked him his name and he's not telling you a name. 4 A. Ellis McLean. 5 Q. Okay. And who else? 6 A. I mean, you have to -- I have to be very specific, so 7 okay, give me time. If you want specific, we're going to go 8 very specific. In order -- say if I want to try to explain 9 something, you know, let me explain. I don't -- If you ask me 10 question, let me answer. 11 MR. PULLMAN: Object to all that stuff. There's 12 a question on the table: Tell me the names. 13 MR. RAY: Well, he's telling me the names, 14 Richard. 15 MR. PULLMAN: Right, but I'm objecting to all 16 that -- Excuse me. I'm speaking. 17 THE WITNESS: I'm speaking too. 18 MR. PULLMAN: I'm out of here in about one 19 second. 20 MR. RAY: Richard, you can make your 21 objections. I don't have any problems with that. There's no 22 reason to get overwrought here. Just go ahead and make your 23 objection. 24 MR. PULLMAN: I object to all of that talk as 25 being totally nonresponsive and would ask you to instruct your VICKI HUMPHREY, CSR MANSFIELD, TX METRO(817)477-2035 NEBOJSA SIKIMIC 44 1 witness to answer your question or tell you he can't as to who 2 told you. 3 MR. RAY: All right. Are you finished? 4 MR. PULLMAN: Yeah. 5 A. May I talk? 6 Q. Yes. 7 A. I can tell you one name. 8 Q. Mr. Sikimic, what I'm asking you here is the -- you 9 said while ago in response to my question about if anyone told 10 you to leave the loan sharking alone, that someone did tell 11 you that, and we're trying to get the names of those who told 12 you that. And you've already given us one name. Can you give 13 us any other names and their titles, please? 14 A. It's different locations. So on this one I 15 mentioned, that's Ellis McLean. 16 Q. All right. And what occasion was that? Can you 17 remember a date? 18 A. No. 19 Q. Approximate? 20 A. Say March, somewhere in March. 21 Q. March of what year? 22 A. 2003, yeah, the year that I quit. 23 Q. Okay. 24 A. You know, there is another -- the older casinos I can 25 tell you that how they get the names, they get the names VICKI HUMPHREY, CSR MANSFIELD, TX METRO(817)477-2035 NEBOJSA SIKIMIC 45 1 through the managers. 2 Q. I understand. All I'm asking you, though -- 3 MR. PULLMAN: Object to that response as being 4 nonresponsive to the answer on the table -- question on the 5 table and move it be stricken. 6 Q. All I'm asking you is, after we get past Mr. McLean 7 here, you said there was someone else that told you to leave 8 the loan sharking alone. What I'm asking you, what the name 9 of that person is and what position that person held with the 10 company, please. 11 A. Can I answer you the way that I like it or I have to 12 be -- I mean, I don't understand. 13 Q. Okay. I would ask you just to give me the name and 14 the title of the person. 15 A. Okay. Never strictly, Adrian Thomas never strictly 16 told me, but on the way we discuss that and, yes, we leave 17 some of them alone, we kick some of them out. And I was the 18 one that go talk to them, kick them out and, you know, tell 19 them that they can't do their business and stuff like that. 20 MR. PULLMAN: Move that that answer be stricken 21 because I have no idea what he's saying. It's totally 22 incomprehensible. 23 Q. Okay. When you said Adrian Thomas told you to kick 24 some of them out and leave some of them alone, what do you 25 mean by that? I'm talking about loan sharking, loan sharks. VICKI HUMPHREY, CSR MANSFIELD, TX METRO(817)477-2035 NEBOJSA SIKIMIC 46 1 A. I mean by that that, okay, we're going to go and 2 we're going to kick John and Peter, they're small times, to 3 show everybody that we are doing something and we're going to 4 leave Mike and Al alone. 5 Q. Why would you leave Mike and Al alone? 6 A. Because they're big-timers. They're the big one. 7 Q. Okay. Anyone else ever tell you to leave the loan 8 sharks alone? 9 A. No, because I couldn't get an order from anybody but 10 Adrian. 11 MR. PULLMAN: Object to the balance of the 12 answer beyond "no" as being nonresponsive. The answer "no" 13 does answer the question did anybody else. 14 Q. Okay. The severance agreement that we talked about 15 while ago, Plaintiff's Exhibit No. 3 I think it's marked; is 16 that correct? 17 A. Severance is No. 4. 18 Q. Well, is it -- What happened to No. 3 here? 19 MR. PULLMAN: 3 is the release. 3 is the 20 release and 4 is the appendix to the release. It's the same 21 document. 22 MR. RAY: Well, that's what I thought to begin 23 with too, but he said it wasn't. 24 MR. PULLMAN: It's referenced in 3. It says 25 Exhibit A attached -- Appendix A attached. VICKI HUMPHREY, CSR MANSFIELD, TX METRO(817)477-2035 NEBOJSA SIKIMIC 47 1 Q. (By Mr. Ray) Okay. Who proposed the severance 2 agreement? 3 A. Adrian Thomas. 4 Q. Okay. And let's see. After you -- Scratch that. 5 After your employment ended, did Great Canadian Casinos, Inc. 6 require you to return any documents, computers or computer 7 files? 8 A. Yes. 9 Q. Okay. And what were those? Could you describe them, 10 please? 11 A. I've been told to return everything that belongs 12 to -- on release, everything that belongs to Great Canadian 13 Casino: keys, tapes, paperworks, everything, everything. And 14 on the top, I've been told to release and give back everything 15 from the ship that I received. 16 Q. From the ship? 17 A. Yeah. 18 Q. What ship are we talking about here? 19 A. China Sea Discovery, the one that was in Hong Kong. 20 Q. Okay. Did you give back everything you were told to 21 give back? 22 A. Everything. Reports, logbooks, pictures. 23 Q. All right. Who told you to give it back? 24 A. Adrian Thomas. 25 Q. Who did you give it back to? VICKI HUMPHREY, CSR MANSFIELD, TX METRO(817)477-2035 NEBOJSA SIKIMIC 48 1 A. Adrian Thomas. 2 Q. You mentioned the China Sea Discovery. How did you 3 first become aware of this ship? 4 A. I've been told by Mr. Adrian Thomas and Mr. Brian 5 Egli to recruit seven, eight people that I trust, good people 6 that we send to the ship to do the surveillance and security. 7 Q. Okay. When was that approximately? 8 A. 2000. 2000, I think. 9 Q. Can you remember about what month or season of the 10 year? 11 A. Give me couple of months up and down. Say October, 12 November. 13 Q. Of 2000. 14 A. Yeah. 15 Q. All right. Did you do that? 16 A. Yes. Yes, I did. I provide list of the people that 17 are qualified to go there and do the job as security and 18 surveillance. 19 Q. All right. Did you have any meetings with any of the 20 personnel with your company to discuss the employment of 21 personnel to work on the ship? 22 A. Well, yeah, we discuss with Brian Egli, myself and 23 Adrian Thomas. We discuss how much we're going to pay the 24 people, how we're going to pay them, what they're going to 25 get, how long they're going to stay and what they're supposed VICKI HUMPHREY, CSR MANSFIELD, TX METRO(817)477-2035 NEBOJSA SIKIMIC 49 1 to do there and -- 2 Q. Did these discussions -- When did these discussions 3 take place? 4 A. I would say week before they left, week before they 5 left. So I don't know if they left in October or November. 6 People that are going to the ship, yeah. 7 Q. Okay. We're talking about October, November of 2000? 8 A. Yes. 9 Q. All right. And these people were supposed to do what 10 again? Could you describe what they were supposed to do 11 specifically? 12 A. They're supposed to be in charge of security and 13 surveillance of the ship of the Great Canadian Casino assets 14 like we do that on the mainland in all our other casinos. 15 Q. Okay. All right. Do you know who was in control of 16 the ship? 17 A. Can you be -- 18 Q. Well, you're sending security personnel to the ship, 19 you say. 20 A. Yeah. 21 Q. All right. Who are they working for? 22 MR. PULLMAN: I object to the -- 23 A. Great Canadian -- 24 MR. PULLMAN: Excuse me, sir. I object, calls 25 for a legal conclusion. VICKI HUMPHREY, CSR MANSFIELD, TX METRO(817)477-2035 NEBOJSA SIKIMIC 50 1 Q. You can answer the question. 2 A. Great Canadian Casinos. 3 Q. Okay. Did you -- Where did you get -- Where did you 4 find these people? 5 A. They already work for Great Canadian Casino. They're 6 all licensed at the GPEB. They're our employees. And, you 7 know, I pick the manager, assistant manager, surveillance 8 operator. They agree. They know it's great people and we 9 send them there. 10 Q. Okay. These people that were sent to the ship, who 11 did they report to? Who were they supposed to report to? 12 A. Me, myself. 13 Q. Did they in fact report to you? 14 A. Yes. 15 Q. Okay. As far as you know, who was in the management 16 control of the ship? 17 MR. PULLMAN: Object to that, it calls for a 18 legal conclusion. 19 Q. If you know. 20 A. Walter, Dennis. 21 Q. Walter who? 22 A. Walter Soo. 23 Q. And who else? You said Dennis? 24 A. Yeah, Dennis Kwan. 25 Q. Can you spell the last name, please? VICKI HUMPHREY, CSR MANSFIELD, TX METRO(817)477-2035 NEBOJSA SIKIMIC 51 1 A. Grace. I think it's K-w-a-n. 2 Q. Okay. Who did these people work for? 3 A. They work for Great Canadian Casino. 4 Q. Okay. Do you know what their job titles or their 5 position titles were with Great Canadian? 6 A. Yeah. I think Walter Soo was president of some 7 development or something like that. I don't know. I can't 8 tell you exactly what was his title. He was some president. 9 Q. What was Dennis' position? 10 A. Dennis was casino manager. And Grace was director 11 of, I think finance or something. 12 Q. Grace who? 13 A. Grace Chow. 14 Q. Grace Chow? 15 A. No. Yeah, Grace Chow, yeah. 16 Q. Okay. Can you spell her last name, please? 17 A. C-h-o-w. 18 Q. Okay. Who did Grace Chow work for? 19 A. Great Canadian Casino. 20 Q. Okay. All right. Who specifically assigned you the 21 responsibility of overseeing this security on the cruise ship? 22 A. Adrian Thomas. 23 Q. All right. Who was your direct supervisor in 24 connection with your supervising the security on the cruise 25 ship? VICKI HUMPHREY, CSR MANSFIELD, TX METRO(817)477-2035 NEBOJSA SIKIMIC 52 1 A. Brian Egli and Adrian Thomas. 2 Q. Okay. If you were to make a report, for instance, 3 about something that occurred on the ship, who would you make 4 that report to, or who would you have made that report to? 5 A. I suppose to go to Brian Egli. 6 Q. Okay. Did you ever make any reports directly to 7 Adrian Thomas? 8 A. Yes. 9 Q. Okay. Were those reports in writing? 10 A. No. 11 Q. You just made them verbally? 12 A. All of them or we are talking about specific reports? 13 Q. Just -- right now I'm just talking in general. 14 A. Some of them are in writing, some of them it's 15 verbally. Some of them I show that -- once I receive from the 16 ship. They used to send me like twice a month. If it's 17 something interesting, they send me tape, they send me the 18 reports. So I have a writing from the ship from the people 19 that work there. 20 Q. Okay. What you're saying, you would pass them along 21 to Mr. Thomas or Mr. Egli? 22 A. Yeah, I show him. I, you know, inform him what's 23 going on, and that stays there, stays in my file cabinet, 24 locked. 25 Q. All right. Did you ever make any written reports VICKI HUMPHREY, CSR MANSFIELD, TX METRO(817)477-2035 NEBOJSA SIKIMIC 53 1 yourself to Mr. Egli or Mr. Thomas? 2 A. No. 3 Q. Okay. Did you ever visit the cruise ship yourself? 4 A. No. 5 MR. PULLMAN: How close are you to a stopping or 6 break point? 7 MR. RAY: Do you need to take a break, Richard? 8 MR. PULLMAN: I can wait about -- it's a matter 9 of minutes, not hours. It's above seconds, but it's minutes. 10 MR. RAY: We can go ahead and take a break now, 11 Richard. It's all right with me. This is fine. 12 (Off the record.) 13 Q. Okay. When we went for a break, Mr. Sikimic, we were 14 talking about reports that you got from the ship. 15 A. Yes. 16 Q. Okay. Can you -- Can you describe the reports that 17 you got for us? 18 A. That's normal security report with any incidents, any 19 unusual activities they write reports. Actually we have a 20 logbook that you write every move, everything that's going on 21 minute by minute, hour by hour. And on top of that, if 22 something happens, say there's fight in the casino, there's 23 MSR, you write a report, explain how that happened. 24 Q. Excuse me. MSR, what does that mean? 25 A. Miscellaneous security report. VICKI HUMPHREY, CSR MANSFIELD, TX METRO(817)477-2035 NEBOJSA SIKIMIC 54 1 Q. All right. Okay. And I think I understood you to 2 say earlier there were tapes that were sent back also. 3 Surveillance tapes? 4 A. Yes, yeah. 5 Q. Okay. And did those accompany the reports? Did they 6 come with the reports? 7 A. Yes. 8 Q. Okay. Did the reports ever refer to the surveillance 9 tapes? 10 A. Yes. 11 Q. Okay. All right. And I think you've already told me 12 where you sent the reports. Let me ask you this: Do you 13 know -- Do you know where the reports were stored? 14 A. All the reports that I receive and the tapes are 15 stored in my cabinet that I get a key. 16 Q. They were stored in your cabinet in your office? 17 A. Yeah. 18 Q. Okay. Do you know the name of your successor, if 19 there is one? 20 A. Successor? 21 Q. That is, who occupied your job after you left? 22 MR. PULLMAN: Took your place. 23 A. Oh, yeah. Patrick Ennis. 24 Q. Patrick -- sorry? 25 A. Patrick Ennis, E-n-n-i-s. VICKI HUMPHREY, CSR MANSFIELD, TX METRO(817)477-2035 NEBOJSA SIKIMIC 55 1 Q. Okay. 2 A. He was my deputy assistant. 3 Q. Okay. And he's holding the job that you held now? 4 A. Yes. 5 Q. Okay. All right. 6 A. Sorry. He got it and after few months they brought 7 somebody for director of surveillance and I don't know the -- 8 Q. Okay. So now he's holding just the position of 9 director of security? 10 A. Patrick is director of security and the new guy is 11 director of surveillance. 12 Q. All right. And that happened just recently. Is that 13 what you're saying? 14 A. I'm aware like four or five months. 15 Q. All right. Do you know who that gentleman's name is? 16 A. Doug Morrison. 17 Q. Can you spell the last name for us? 18 A. No. 19 Q. Morrison? 20 A. Yeah. 21 Q. Okay. I think we can get pretty close there. In the 22 reports that you got, were there any problems on the ship that 23 you could tell us about? 24 A. Definitely. Like I says, if I get a report, that 25 means there is some problem. VICKI HUMPHREY, CSR MANSFIELD, TX METRO(817)477-2035 NEBOJSA SIKIMIC 56 1 Q. Okay. You only get a report if there's a problem; is 2 that what you're saying? 3 A. Yeah. 4 Q. Okay. Could you tell us what some of the problems 5 were? 6 MR. PULLMAN: Object to this area of problems on 7 the ship as having nothing to do with the background and 8 nothing to do with the pending motion. 9 Q. Okay. Go ahead, answer the question. 10 A. For example, it's the suspicious activity in the cash 11 cage. 12 Q. All right. What are we talking about there 13 specifically? 14 A. Specifically that there is a tape and report that -- 15 we see the person unknown to me comes and grab the money from 16 the pile of the money in the cash cage. You see the guy grabs 17 the money and walk. That's on the tape. And the report says 18 that he's some agent for the junket players, whatever they 19 call him. He's an agent. And I remember making comments of 20 whoever he is, you know, there is no way he can just get in. 21 I need a count. It's the count. We don't know how much he 22 took or whatever. That's the one that I remember. I was 23 really upset about it. 24 Q. Okay. Well, was there a safe in the cage or was the 25 money just lying loose? VICKI HUMPHREY, CSR MANSFIELD, TX METRO(817)477-2035 NEBOJSA SIKIMIC 57 1 A. No, you have the drawers in the cage. You keep the 2 money in the drawers, but on the end when everybody leaves, 3 you get the money to get your float plus your winning and 4 everything is together. So now you should count, okay, this 5 is the float that we start. Say 30,000 we start. We count 6 30. There's another ten, it's our profit or whatever, and 7 before they did it, the guy takes the money, so... 8 Q. Okay. I need to get a little clarification on terms 9 here. Float, you used the term "float". Do you mean that's 10 the amount of money that you started with when you started -- 11 when the casino started opening on a particular night? 12 A. Yes. 13 Q. Okay. All right. As opposed to profit and what came 14 over was earned in profits; is that -- 15 A. Yes. 16 Q. Okay. All right. I understand. Okay. Anything 17 else with the cage that you observed? 18 A. The report that money is not in the safe. They 19 didn't keep the money in the safe. 20 Q. All right. I'm a little bit confused. You said the 21 money was kept in the drawers. 22 A. Cash cage. You have a count room where is the big 23 safe, where is your back-up or whenever you need money in case 24 of emergency or -- You don't bring all the money on the floor 25 in case of robbery or something. So you're supposed to keep VICKI HUMPHREY, CSR MANSFIELD, TX METRO(817)477-2035 NEBOJSA SIKIMIC 58 1 the rest of the money in the safe like any other casinos do. 2 Q. All right. Where is the safe located? 3 A. Safe is located usually on the back of the count 4 room, in the count room. 5 Q. And that's a separate place from the cage? 6 A. Separate place from the cage, yeah. 7 Q. All right. So -- Let me see if I can understand 8 this. You're telling me that the money flows from the cage at 9 some point to the safe. Would that be correct? 10 A. Yeah, they should. Overnight you should keep the 11 money in the safe. You can't keep it in the drawer because 12 it's not that safe. 13 Q. All right. In other words, at the end of the -- when 14 you're getting ready to close up, you take all the money out 15 of the cage and put it in the safe? Is that right then? 16 A. No. As I says before, you separate your float plus 17 your winning. You put in two different bags, and the one you 18 write down as float and couple of us sign, okay, that's the 19 float and the other one is the money what we made. In our 20 casinos on the mainland, they come and pick up the money first 21 thing in the morning. The rest stays in the safe with the 22 float. So whatever we win goes to the bank, we deposit. 23 Q. What goes to the safe when you close up? 24 A. Everything. 25 Q. Everything. VICKI HUMPHREY, CSR MANSFIELD, TX METRO(817)477-2035 NEBOJSA SIKIMIC 59 1 A. Float and whatever we made. 2 Q. All right. Good. Okay. Are there any other 3 problems that you can describe with the safe and the cage that 4 you observed? 5 A. On the end -- on the end of the, say, business 6 cruise -- I don't know how to call that -- I received phone 7 call that money was stolen, that manager stole the money. 8 Q. The manager stole the money. 9 A. Yeah. 10 Q. Who would that be? 11 A. Dennis Kwan. And I says, do you have that on tape? 12 Says no. Okay, write me a report, so they -- 13 Q. Who gave you that report? 14 A. Vlada Vasiljevic. 15 Q. Can you spell that name for the -- 16 A. Sure. They're all Yugos. V-l-a-d-a first name, last 17 name V-a-s-i-l-j-e-v-i-c. 18 Q. Okay. 19 A. He was the manager of security/surveillance on the 20 ship. 21 Q. Okay. And he gave you a report? 22 A. Yeah. I said send me something in writing, you 23 know. He send me in writing that Dennis Kwan took -- amount 24 I'm not sure, so I can't tell you is it 30 or 40,000, but 25 there is probably somewhere on the report exact amount VICKI HUMPHREY, CSR MANSFIELD, TX METRO(817)477-2035 NEBOJSA SIKIMIC 60 1 exactly. Maybe he remember how much was there. And I went 2 with that to Brian Egli, report that. I says, what are we 3 going to do? Okay. We've got a guy stole the money, you 4 know. Oh, let me see. Okay. We're going to talk to him. So 5 we called Adrian. Adrian told me that he didn't steal the 6 money, that he told him to take the money. That's explanation 7 and no question ask. I told him to do it. I never saw the -- 8 and I never heard where that money went, they bring it back or 9 not, that's -- 10 Q. Okay. 11 A. Another one is when they kick one of the -- that's in 12 the early beginning stage. They kick one of the working girls 13 from the ship. She's going crazy and they kick her out. 14 Q. What do you mean when you say "working girl"? 15 A. Prostitute, hooker, prostitute. What's the nice -- I 16 don't know how -- 17 Q. You received a report about a prostitute being kicked 18 off the ship? 19 A. Yes. 20 Q. Okay. 21 A. There was also report to the Hong Kong police because 22 they arrived. They remove her, they help. That Vlada 23 Vasiljevic, he remove her physically, grab her and remove 24 because she was screaming, she was upset. I don't know. 25 Q. Okay. Did you receive any other reports concerning VICKI HUMPHREY, CSR MANSFIELD, TX METRO(817)477-2035 NEBOJSA SIKIMIC 61 1 prostitutes? 2 A. No. Other ones are okay, so there is no -- they 3 didn't make any problem. 4 Q. You received no actual reports other than that one 5 concerning prostitution? 6 A. That was the only one that we -- they have a problem. 7 Q. Okay. Have a problem, I'm not sure -- Oh, you mean 8 the only one that was acting up? 9 A. Yeah. 10 Q. Okay. Did any -- Well, let me see. These officers 11 that you had, these security officers on the ship, I think you 12 said before there were eight of them; is that correct? 13 A. No, I can't go name by name. 14 Q. Okay. I understand. 15 A. We hire some gurkas after that. That's -- 16 Q. Gurkas, could you describe what you're talking about 17 there, please? 18 A. Those are the cheap, very good labor. I think 19 they're from England. They have some special training. They 20 told me they're trained to do whatever you want, the best one, 21 and they're pretty, you know, cheap. I don't know. I think, 22 say, five, 600 bucks a month or something like that. What I 23 remember, it's gurkas. They are from England, from -- I don't 24 know what place. 25 Q. Okay. How were these people paid, these security VICKI HUMPHREY, CSR MANSFIELD, TX METRO(817)477-2035 NEBOJSA SIKIMIC 62 1 people on the ship? 2 A. Security people get paid through Great Canadian 3 Casino. They get a check -- originally the deal was they're 4 going to get 5,000 U.S. and they're under the impression 5 they're going to get 5,000 U.S. cash. When the first payment 6 arrived, first paycheck, they did have 5,000 U.S. transfer 7 to -- they did take taxes, you know. They deduct right away. 8 They don't give them cash. 9 Q. Okay. Who was responsible for getting these people 10 paid, these security people on the ship? 11 A. Great Canadian Casino. 12 Q. Yeah, but what person with Great Canadian Casinos; do 13 you know? 14 A. I mean, I was there when they signed the contracts. 15 I talked to them about money. I didn't sign anything. I was 16 just the one that find the people, talk to them, bring them to 17 head office and they signed the contract. The contract was -- 18 who was involved. Brian, Grace and Adrian. 19 Q. Do you know how often they were paid? 20 A. Twice a week -- twice a month, yeah. 21 Q. Twice a month. 22 A. Yeah, biweekly (sic). 23 Q. All right. And I'm not sure I understood what you 24 were saying earlier. Were they paid by check or cash? 25 A. Check. VICKI HUMPHREY, CSR MANSFIELD, TX METRO(817)477-2035 NEBOJSA SIKIMIC 63 1 Q. Okay. Has Great Canadian Casinos stopped providing 2 security on the ship? 3 MR. PULLMAN: Object to the answer as being 4 hearsay. He doesn't work for the company anymore. 5 Q. Did Great Canadian Casinos stop providing security on 6 the ship during your tenure with the company? 7 A. Yes. 8 Q. Okay. When was that? 9 A. I don't know for sure. 10 Q. Could you give me a month and a year? 11 A. That's when the guys returned from Taiwan, when we 12 get the ship to Taiwan and they start packing stuff and -- 13 Q. All right. Do you remember what year that was, first 14 of all? 15 A. 2002. 16 Q. Okay. Would it have been in the -- 17 A. Early, beginning of 2002, I would say. 18 Q. Okay. 19 A. Or before. Sorry. Before, yeah, 2002. Yeah, it's 20 before, so it's 2001, 2001. 21 Q. All right. 22 A. Maybe September, around September. 23 Q. All right. You mentioned while ago that there was a 24 prostitute ejected from the ship, and we talked about that 25 just a little bit. I want to make sure I understand that VICKI HUMPHREY, CSR MANSFIELD, TX METRO(817)477-2035 NEBOJSA SIKIMIC 64 1 clearly. Did I understand you to say that there were no other 2 reports concerning prostitution on the ship to you? 3 A. Written, no. There was only one written report. 4 There's the problem with that prostitute that they have to 5 kick out and call the Hong Kong police. 6 Q. Well, were there any verbal reports? 7 A. Yeah, on the phone, yeah. I talked to the guys. 8 They tell me they have girls working there, and even the 9 manager explain there was kissing his foot when he was kicking 10 the other one and calling him master like -- 11 MR. PULLMAN: Object to all this as being 12 totally irrelevant to what's on the -- excuse me. Let me 13 finish -- to the issues before the court. 14 Q. Okay. What manager are we talking about? 15 A. Vlada Vasiljevic, security and surveillance manager. 16 Q. All right. Were these other women permitted to 17 remain on the ship? 18 A. Yes. 19 MR. PULLMAN: Same objection. 20 Q. Were they permitted to continue their operations as 21 prostitutes? 22 A. Yes. 23 MR. PULLMAN: Object to this also as being 24 irrelevant as to the issues before the court. 25 Q. Did you report these communications made to you VICKI HUMPHREY, CSR MANSFIELD, TX METRO(817)477-2035 NEBOJSA SIKIMIC 65 1 concerning prostitutes to anyone? 2 MR. PULLMAN: Object to this as being not 3 relevant to the issues before the court. 4 A. Yes, I did. 5 Q. Who did you report it to? 6 A. I report to Adrian and Brian, but they knew that they 7 was on the ship before, so they probably knew that there 8 was -- 9 Q. Did they tell you they knew it? 10 A. No, no, but they told me that it's normal. It's like 11 massage. 12 Q. And we're talking about Adrian Thomas and Brian -- 13 what was his last name? 14 A. Egli. 15 Q. Egli. All right. Did you have any -- That 16 occurrence we just talked about, before I leave that, when you 17 got that -- those verbal reports that we just talked about, 18 when was that; can you tell me? 19 A. Before -- before December, so say maybe around 20 December 2000. 21 Q. 2000? 22 A. Yeah. 23 Q. Okay. 24 A. When they start there, I think, like I says before, 25 September, October they start, so maybe a month or two. VICKI HUMPHREY, CSR MANSFIELD, TX METRO(817)477-2035 NEBOJSA SIKIMIC 66 1 Q. All right. We discussed earlier when we were talking 2 about when you first went to work for Great Canadian Casinos 3 you took some sort of test or something. Did you have some 4 kind of previous experience with casino operations before you 5 went to work for them? 6 A. No. 7 Q. Okay. All of your experience would have been working 8 for Great Canadian Casinos; is that right? 9 A. That's from the casino experience, yeah. 10 Q. Okay. All right. And I just want to backtrack on 11 that just a little bit. The casinos you worked at were -- 12 before you got into security, when you were just in general, 13 that was -- I can't remember the name of it now. What was 14 that one? 15 A. Gilford. 16 Q. Gilford, right. All right. Did you have an 17 opportunity when you worked with these casinos to observe how 18 money was handled -- 19 A. Yes. 20 Q. -- how they were operated? 21 A. Oh, yeah. 22 Q. Okay. Can you describe for us, you know, in the way 23 of handling money, what happens from the time a customer comes 24 into the casino to gamble until the time he or she leaves? 25 MR. PULLMAN: I object to that question as being VICKI HUMPHREY, CSR MANSFIELD, TX METRO(817)477-2035 NEBOJSA SIKIMIC 67 1 totally irrelevant to the issues before this court, and I 2 think we've gone far enough with the background. 3 Q. Okay. You can answer the question. 4 A. You walk in the casino, you sit in a table, put the 5 money on the table, buy the chips, you get -- 6 Q. Where do you buy the chips? 7 A. At the table. 8 Q. At the table you buy the chips? 9 A. Yeah. You can buy only at the table. 10 Q. Okay. All right. When you finish gambling, then 11 what do you do then? 12 A. You go to cash cage. Bring your chips to the cash 13 cage. There's a special part of the casino called the cash 14 cage. Bring the chips, give them the chips, they count the 15 chips, give you cash. 16 Q. Is that the kind of cage we were talking about before 17 on the ship? 18 A. Yes. 19 Q. All right. And what kind of security is provided 20 there to watch over the money? I think you said earlier there 21 was a safe, but what else? Anything else? 22 A. Cameras, yeah. There is surveillance system, you 23 know, you've got the cameras all over recording everything. 24 Q. Who's in charge of the cage? 25 A. Cage manager. VICKI HUMPHREY, CSR MANSFIELD, TX METRO(817)477-2035 NEBOJSA SIKIMIC 68 1 Q. Okay. Is anyone there with the cage manager besides 2 just that one person generally? 3 A. It's cashiers and cage managers. They supposed to 4 check each other and sign, both of them sign any amount and 5 it's paperwork on any transaction. 6 Q. Are you familiar with the policies of Great Canadian 7 Casinos, Inc. and the operation of its casinos generally? 8 A. Oh, yeah. Yes. 9 Q. How did you become aware of these policies? 10 MR. PULLMAN: Same objection that we have as 11 being irrelevant to the issues before this court. 12 Q. How did you become aware of the policies? 13 A. I was involved with some of them, bringing up and 14 working on procedures and policies, and went through all 15 departments. There is a book. There's policies and 16 procedures that you have to follow. 17 Q. Did you have to familiarize yourself with that book? 18 A. Oh, yeah. Yes. 19 Q. And are you telling me right now that there is such a 20 book in existence as far as you know? 21 A. Yes. 22 Q. All right. There was one in existence at the time 23 you worked for the company? 24 A. The one time we have two. We have one from Great 25 Canadian Casino and one from the government. VICKI HUMPHREY, CSR MANSFIELD, TX METRO(817)477-2035 NEBOJSA SIKIMIC 69 1 Q. Okay. What was the one from Great Canadian Casinos 2 called? 3 A. Great Canadian Casino Gaming policy or procedures, 4 but it was our own policy. After that the government took 5 part of that. They got their own policy that we supposed to 6 follow. 7 Q. All right. Did you have an opportunity while you 8 were working there to observe what the average profits from 9 the casinos would be? 10 MR. PULLMAN: Object to that as being totally 11 unrelated to issues before this court. 12 A. Yes, yes, I was. Actually we receive -- every two 13 hours we receive the numbers, the count, and what's the drop, 14 what's the hold on the end. We receive the paperwork, how 15 much casino made, so I was aware of that. 16 Q. Okay. How is that connected with security? What's 17 the connection there? 18 A. Connection is that you receive all those information 19 in order to find out if something's really bad like the table 20 is going down 50,000, 100,000. You can see that on the 21 paperwork so you can pay more attention if there's no other 22 ways to get -- 23 Q. Okay. Can you give me some kind of idea about what 24 the average profit on the casinos with the operations were, 25 say, in a given night, or a given day I should say? Could you VICKI HUMPHREY, CSR MANSFIELD, TX METRO(817)477-2035 NEBOJSA SIKIMIC 70 1 give me some kind of an idea there? Or within any time 2 period. 3 A. I can tell you the time that I was working. I don't 4 know now. I'm not there for a year. 5 Q. No, what I meant was, you know, something like on the 6 average day while you were there. 7 A. Are you interested in hold or drop, how much money -- 8 Q. I'm talking about profits. I'm not talking about -- 9 A. Profit? 10 Q. Yes. 11 A. 200,000. And you have to pay, I think -- we paid 40, 12 50, 60 percent to government, so... 13 Q. All right. Well, not counting that. What kind of -- 14 Was there some kind of book that was followed in dealing with 15 the casino practices on the China Sea Discovery ship? 16 A. That should be the same book like we have at the 17 Great Canadian. 18 MR. PULLMAN: I object to that. He doesn't know 19 is what he's saying. That's not a responsive answer. 20 Q. Do you know if -- 21 A. I ordered those guy to do, so they have to follow the 22 procedures and policies. 23 Q. You ordered them to follow the procedures in the 24 book; is that what you're saying? 25 A. Yeah, the one that we have from security and VICKI HUMPHREY, CSR MANSFIELD, TX METRO(817)477-2035 NEBOJSA SIKIMIC 71 1 surveillance. 2 Q. The one that you just told me about. 3 A. Yes. 4 MR. PULLMAN: The question on the table is: Was 5 there a book on the boat, and his answer was "I don't know". 6 MR. RAY: Well, I'll ask the questions, Richard. 7 MR. PULLMAN: Well, I'm objecting. 8 MR. RAY: You can object. I'll let you do that. 9 Q. All right. Was the casino on the ship run pretty 10 much like any other casino with Great Canadian Cruises, Inc.? 11 A. No. 12 Q. Describe how it differed, if you can. 13 A. How different? I mean, right away it's different. 14 It's on a ship, so everything is different than the casino on 15 the mainland. And the reports that I'd receive, the 16 operation, there is some difference, like in our casino, as I 17 says, you can't get money or chips. Down there you have 18 individuals walk in and just -- they've been given money from 19 the cash cage. 20 Q. Okay. Let's just stop just for a second here now. 21 Okay. What are the normal practices in accordance with that 22 book you talked about in dealing with money in the cage? How 23 is it dealt with? Can you tell me that? 24 A. No. That part, no. Security/surveillance, yes, and 25 I was going on the book. VICKI HUMPHREY, CSR MANSFIELD, TX METRO(817)477-2035 NEBOJSA SIKIMIC 72 1 Q. Okay. Well, tell me the security and surveillance 2 part of it then. 3 A. Security and surveillance part there is that any 4 transaction, like, for example, right now, if the $100.00 5 chip -- actually a year ago -- if the $100.00 chip goes on the 6 floor, they're supposed to call surveillance, inform them. 7 They go pick up the chip from the floor, put on the tray. 8 Q. Oh, you mean if a chip just falls off the table or 9 something, a gambling table? 10 A. Yes. They cannot pick up the chip and put back. 11 They're supposed to call surveillance, advise surveillance 12 what they're going to do and place the chip back, and we 13 supposed to write on a logbook, table five, table four. 14 Q. All right. Was that done on the China Sea 15 Discovery? Was that practice followed? 16 A. No. 17 Q. Okay. Do you know why? 18 A. Whenever I ask when I had a problem, they says, oh, 19 that's the way they're doing -- that's how they do there, so 20 it's -- 21 Q. All right. Who told you that, what you just said? 22 A. Walter, Adrian, whoever was going back and forth. 23 Q. Back and forth, you mean back and forth to the ship? 24 A. Yeah, travel and go there, come back, you know. I 25 don't know how many times. VICKI HUMPHREY, CSR MANSFIELD, TX METRO(817)477-2035 NEBOJSA SIKIMIC 73 1 Q. Okay. All right. Can you tell me -- Can you tell me 2 more about the security and surveillance aspects of dealing 3 with the money and the chips? 4 A. Money and the chips, it was totally ignored after the 5 one period. They didn't report to security/surveillance. 6 Q. I'm not sure I understand what you're saying there. 7 A. They don't report. Like I said, somebody come and 8 the guy says give him 200,000. I have to say the guy because 9 I don't know his name and they don't know the name. He is one 10 of the agents. He's the one that represents somebody. He 11 says give him 200. Now, from those 200, I've been told they 12 get commission. They get five percent because they bring -- 13 Q. All right. Let's just stop just for a second. 14 Normally when someone wants money from the cage in the casino 15 operated by Great Canadian Casinos, Inc., how would they go 16 about getting it? 17 A. Only if you have the chips. You're not going to get 18 any money. If you've got the chips or U.S. money, that's the 19 only thing that you can exchange, or Traveler's Cheques in 20 casinos. 21 Q. Okay. But what about somebody from the corporation 22 that comes in and wants some money? 23 A. No, you won't get it. You won't get it. Only if 24 it's emergency that one of our casinos doesn't have money in 25 the float, say we are losing at Holiday Inn, they call me, we VICKI HUMPHREY, CSR MANSFIELD, TX METRO(817)477-2035 NEBOJSA SIKIMIC 74 1 have to go pick up the money from Richmond. We go in the 2 safe. It's two of us. We call surveillance, okay, going to 3 come and pick up the money from Richmond, and there is piece 4 of paper that you sign, three of us sign, pick up 100,000 or 5 50,000. 6 Q. You have to sign a receipt; is that what you're 7 saying? 8 A. Yeah, you sign a receipt. There is a policy that -- 9 and I was working on that policy -- that you're supposed to 10 phone, give where you're going, how you're going, how long 11 it's going to take you to be there, staying in touch, two 12 casinos. 13 Q. Are you saying you helped formulate that policy? 14 A. Yes, I did. 15 Q. Okay. Was that procedure followed on the ship? 16 A. No. 17 Q. Okay. I think you told me while ago that people came 18 in to get money from the cage from time to time. 19 A. Yeah. 20 Q. Did these people sign receipts for the money? 21 A. Nothing. Sometimes it was in a -- one case they send 22 me the picture report. It was signed on the newspaper, you 23 know, the white part from the newspaper. 24 Q. Yeah. 25 A. He just write down amount. That was the receipt or VICKI HUMPHREY, CSR MANSFIELD, TX METRO(817)477-2035 NEBOJSA SIKIMIC 75 1 whatever. 2 Q. Okay. Were there any situations where people came in 3 and got money from the cage without signing receipts? 4 A. Yes. I told you that, specifically that I saw that 5 when the guy grabbed the money and just -- 6 Q. Okay. How many times did you see this? 7 A. Grabbing the money without anything? Only once. 8 That's that tape that they send me. 9 Q. Okay. Did you have any reports concerning this 10 activity? 11 A. Many of them, yes. 12 Q. From the people that worked on the ship? 13 A. From the people that work in surveillance, my people. 14 Q. Okay. And what did you do with those reports? 15 A. I asked vice-president and president -- that's Brian 16 Egli and Adrian Thomas -- what are we going to do about that. 17 Q. Okay. And what were you told in that regard? 18 A. Like I says before, that's the way they do things 19 there. 20 Q. Okay. I think you said -- I'm not sure I'm 21 understanding this correctly, but I think you said there were 22 logs kept; is that right? 23 A. Yes. 24 Q. Okay. And that's the normal procedure according to 25 the book we're talking about here in the casino operations in VICKI HUMPHREY, CSR MANSFIELD, TX METRO(817)477-2035 NEBOJSA SIKIMIC 76 1 dealing with money in the cage? 2 A. Not only with the money in the cage. 3 Q. Everywhere? 4 A. They have separate paperwork for the money in the 5 cage and the cage operation and everything, but we, 6 surveillance, we write down money transfer, box pull. 7 Anything to do with the cage you write down, what time it 8 happen, and supposed to follow that. 9 Q. Were these logs kept with regards to the China Sea 10 Discovery? 11 A. Yes. 12 Q. Okay. Do you know where those logs were stored? 13 A. In my -- after -- when they come back to my cabinet? 14 Q. Okay. 15 A. I have all the logbooks. 16 Q. Where are the video records stored from the China Sea 17 Discovery? 18 A. Ones that they send to me? 19 Q. Yes. 20 A. In my cabinet, locked. 21 Q. Were there others other than those that were sent to 22 you? 23 A. One day of the end, I don't know. They send 24 somewhere. I don't know where they send all the paperwork and 25 tapes. VICKI HUMPHREY, CSR MANSFIELD, TX METRO(817)477-2035 NEBOJSA SIKIMIC 77 1 Q. On the end, what are you talking about "on the end"? 2 A. When our people left the ship. 3 Q. Okay. Those didn't go to you, they went someplace 4 else; is that what you're saying? 5 A. Yeah. 6 Q. All right. You mentioned junkets while ago. Let me 7 ask you first, can you tell -- did you have reports that 8 indicated what the average number of gamblers were per day on 9 the ship? 10 MR. PULLMAN: Same issue, same -- Can we just -- 11 Can I just reserve my objections as to being outside your 12 special -- I'm sorry. Strike that. May I reserve my 13 objections or do you want me to continue to make them as to 14 issues that are -- 15 MR. RAY: Richard, if you would make them as to 16 each general issue, I'll consider it to be a running objection 17 if you want it to be. 18 MR. PULLMAN: All right. I'm making that 19 objection as to junkets. 20 MR. RAY: Okay. 21 MR. PULLMAN: Same objection we've had as to not 22 being relevant to the issues before the court. 23 MR. RAY: All right. 24 MR. PULLMAN: I think we already have 25 prostitutes. We already have operations. So now we're VICKI HUMPHREY, CSR MANSFIELD, TX METRO(817)477-2035 NEBOJSA SIKIMIC 78 1 talking junkets. 2 MR. RAY: Junkets, yes, sir. 3 Q. (By Mr. Ray) Okay. Can you tell me, if you know, 4 what the average number of gamblers per day was on the ship 5 when the casino was in operation while your people were on 6 board? 7 A. On a few occasions, I receive report that -- I can 8 recall one. 600, one was 800. I think the best one was 1200 9 people. Those are the three numbers that I can remember. 10 There was other small ones, 200. 11 Q. How long would these gamblers be on the ship? 12 A. I don't know. 13 Q. You don't know how long it cruised for? 14 A. No. That's something -- 15 Q. All right. Fair enough. How many tables did the 16 ship have, do you know that, approximately? 17 A. Approximately? 18 Q. Yes. 19 A. 80. 20 Q. Okay. What type of tables were these? 21 A. Blackjack, baccarat, sic/bo, roulette. 22 Q. Blackjack, baccarat and what? 23 A. Sic/bo. 24 Q. Can you spell that? 25 A. S-i-c b-o. VICKI HUMPHREY, CSR MANSFIELD, TX METRO(817)477-2035 NEBOJSA SIKIMIC 79 1 Q. Okay. You're dealing with a person here that knows 2 nothing about gambling, so you're going to have to help me 3 here. Okay. Slot machines, how many? 4 A. There was, say, between 60 and 80. 5 Q. Okay. 6 A. I'm not really sure because they didn't keep any 7 record about slots. I know that I saw the tape with slots. 8 Few people play small time, but I didn't see any record about 9 slots, so I can't really recall because they didn't have any 10 paper on slots. 11 Q. All right. You mentioned -- I'm going to close up 12 the junkets here. Who arranged the junkets; do you know? 13 A. Somebody. Honestly I don't know who. 14 Q. If you don't know, it's all right. 15 MR. PULLMAN: The answer is "no". 16 Q. It's all right. 17 A. They're there. I don't know who arranged. 18 Q. All right. That's fine. Do you know if compensation 19 was paid to those people arranging the junkets? 20 A. Yes. Agents are paid and junkets are paid, so 21 probably agents are the people that bring the junkets. I 22 don't know the terminology that -- 23 Q. What was the practice with Great Canadian Casinos in 24 general regarding junkets? 25 A. We don't have that here. VICKI HUMPHREY, CSR MANSFIELD, TX METRO(817)477-2035 NEBOJSA SIKIMIC 80 1 Q. Okay. All right. Did you observe any activities 2 that you would consider to be irregular in regards to these 3 junkets? 4 A. Yes. 5 Q. All right. What would that have been? 6 A. As I said, you know, getting money from the cage 7 without any -- I mean -- 8 Q. Now, are you talking about -- getting money from the 9 cage, are you talking about somebody that's a member of the 10 junket party or something? What are you talking about? 11 A. Like I told you, I don't know if he's an agent or a 12 junket. 13 Q. You didn't know who this person was. 14 A. I don't know. He's taking the money, but the way 15 they're supposed to do, say you're the junket, you bring me on 16 the ship. If I buy 100,000 chips -- I don't know what was the 17 deal. You get 5,000 or 10,000. You get 100,000, you made 18 10,000. My guy send me a report that there's so many of them 19 don't play. They just grab the 10,000 profit or 5,000 -- 20 don't get me wrong. I don't know what was the percentage -- 21 and they don't play, or they just go play few hands and they 22 leave. 23 Q. Okay. Are you telling me that these people -- I'm 24 trying to understand this. Are you telling me that these 25 people that came in and got money out of the cage were just VICKI HUMPHREY, CSR MANSFIELD, TX METRO(817)477-2035 NEBOJSA SIKIMIC 81 1 people you didn't recognize? 2 A. No, they're some new faces. I don't know -- 3 Q. Some new faces? Okay. I think earlier you said you 4 got some reports about that problem. 5 A. Yes. 6 Q. Okay. The flow of money into the cage on the ship, 7 was it comparable to the other casinos within the Great 8 Canadian Casino operations? 9 A. No, no. It's less. 10 Q. Okay. Have you ever heard of a company called 11 Mexteam? 12 A. I think it's the one that they had in Hong Kong. I 13 heard the name, but I think it's Hong Kong, yeah. 14 Q. Did you have any information or knowledge of what was 15 being paid to operate the ship? 16 MR. PULLMAN: I object to that as being not 17 relevant as to the issues before the court. I think you're in 18 a new area. 19 MR. RAY: Yeah. Okay. That's good. 20 MR. PULLMAN: We're not talking about junkets or 21 prostitutes now, are we? 22 MR. RAY: No. We're into something else now. 23 MR. PULLMAN: All right. Wanted to make sure. 24 A. The only numbers that I heard that Great Canadian 25 paid $15,000,000.00 for the -- VICKI HUMPHREY, CSR MANSFIELD, TX METRO(817)477-2035 NEBOJSA SIKIMIC 82 1 Q. No, I'm not talking about what was paid for the 2 ship. I'm talking about -- Were you aware of any information 3 concerning the cost of operations of that ship? 4 A. The cost is huge. All the time they ask for money. 5 I know that. They're losing all the time. They're asking to 6 send more money, and I don't know what was the amount, how 7 much they did send, who they did send. The only problem we 8 have, I know that's in Hainan when we have to send money to 9 pay -- they took the ship. Somebody took the ship and -- 10 Q. Did you receive any information about a comparable 11 cost of operations of the other gambling ships operating in 12 the same area? 13 A. Oh, I heard that we are the -- 14 MR. PULLMAN: I'm not sure if this is the same 15 or not, but I object. 16 MR. RAY: Yeah, go ahead. 17 MR. PULLMAN: Probably it's the same. 18 A. The cost, I heard -- actually that's where my guys 19 send me the list, how much is everybody paid, and this says 20 our ship was most paid more than anybody else, you know, 21 people that work on the ships. 22 Q. Was there ever any discussion about that between you 23 and anyone else, about the cost of operation of the ship? 24 MR. PULLMAN: I object. I object to the answer 25 as being nonresponsive. The question was the cost of VICKI HUMPHREY, CSR MANSFIELD, TX METRO(817)477-2035 NEBOJSA SIKIMIC 83 1 operations, and he said our people got paid the most, and I 2 assert that's nonresponsive. 3 MR. RAY: Well, no, I think the last question I 4 asked was about the comparable -- 5 MR. PULLMAN: Operation costs. 6 MR. RAY: Yeah, comparable to other ships 7 operating in the area. 8 MR. PULLMAN: Okay. So you only wanted him to 9 answer about -- as to just salaries of the employees. 10 MR. RAY: No, I'm talking about cost in general. 11 MR. PULLMAN: Okay. Well, then, I object to the 12 answer as being nonresponsive. He answered salaries. He said 13 our people got paid the most, so I object as that being 14 nonresponsive. 15 A. Just for the record, I didn't mean our people. Our 16 people is Great Canadian. The other people working on the 17 ship was paid more. That's why they send. They thought they 18 should pay more. 19 Q. You mean -- "our people" meaning security people? 20 A. No, no, no. The people on the ship, the cook, 21 waiters, whatever, everybody else on the V-ship that was 22 working there. 23 Q. Okay. I'm sorry. When I asked you before had you 24 ever heard of a company called Mexteam, what -- 25 A. I heard, yeah. VICKI HUMPHREY, CSR MANSFIELD, TX METRO(817)477-2035 NEBOJSA SIKIMIC 84 1 Q. Okay. What do you know about Mexteam, if anything? 2 A. They're in Hong Kong. Those guys, the one there, I 3 think they had an office there, Walter and other people. 4 They're in some connection, but for the record I don't know 5 what exactly. 6 Q. Okay. Some connection, you mean connection with the 7 ship or what? What do you mean by that? 8 A. I think with the ship and Great Canadian. Probably 9 it's Charles' company. I don't know. I think it's his 10 company. 11 MR. RAY: All right. I'm about to peel off into 12 something else here just briefly here, Richard. Do you want 13 to take a lunch break now? 14 MR. PULLMAN: Whatever. You don't see any hope 15 of killing this thing off at a reasonable time? It's not up 16 to me. It's up to the witness. I'm happy to take a break any 17 time anybody else wants to. 18 MR. RAY: No. I've got about another hour to go 19 with this guy. 20 MR. PULLMAN: Then let's just quit. It's a good 21 time to break. 22 (Lunch break.) 23 Q. (By Mr. Ray) Okay. We're back on the record. Mr. 24 Sikimic, are you familiar with a fellow by the name of Gary 25 Lu, L-u? VICKI HUMPHREY, CSR MANSFIELD, TX METRO(817)477-2035 NEBOJSA SIKIMIC 85 1 A. Yes. 2 Q. Okay. How do you know Gary Lu? 3 A. I met him in our casino originally. 4 Q. "Our casino", you mean which one? 5 A. Yeah, Richmond. 6 Q. Okay. 7 A. I met him as a player and later I met him as Adrian's 8 friend. 9 Q. Okay. 10 A. After that, I saw him quite a few times in head 11 office. 12 Q. Do you mean that you actually met him, you were 13 introduced to him; is that -- Were you introduced to him? 14 A. No, I saw him. You know, when I saw him first time, 15 he was just a player. I didn't know the guy. And after that, 16 I heard he's Adrian's friend and Adrian introduced me to him 17 one day, okay, Gary is my friend. That's maybe, I don't know, 18 five, six years ago. And after that, I find out that he's 19 involved in the ship as a -- 20 Q. Okay. Do you know whether or not he has any 21 connection with Great Canadian Casinos, Inc.? 22 A. That's the only thing that I think is connected. 23 There's the ship and he was doing some project for the new 24 casino in Richmond, blueprint or something his company was 25 doing, and that was turned down and -- VICKI HUMPHREY, CSR MANSFIELD, TX METRO(817)477-2035 NEBOJSA SIKIMIC 86 1 Q. Was he doing those for Great Canadian Gaming 2 Corporation or Great Canadian Casinos, Inc., if you know? 3 A. I don't know. 4 Q. Okay. When was the last time you saw Mr. Lu? 5 A. Last year. I would say like everything, this is 6 giving months in between. Say maybe April; March, April. 7 Q. April of 2003? 8 A. Yeah, 2003, yeah. 9 Q. Okay. And what was he doing then when you saw him 10 the last time? 11 A. He was in head office to have a meeting with Ross and 12 Adrian, and I think he mentioned Michael's name because he 13 wants some, you know, more money to help him for the ship 14 that's in Taiwan. 15 Q. Okay. Do you know what Mr. Lu's -- Do you know if 16 Mr. Lu has any connection with the ship at this time? 17 A. I heard that -- 18 MR. PULLMAN: Object to any hearsay. 19 Q. Go ahead. 20 A. I heard that he sold ship back to Hong Kong week ago. 21 Q. Who specifically in Hong Kong; can you tell me? 22 A. No. 23 Q. You don't know who it was that bought it? 24 A. (Witness nods negatively.) That's what I heard, that 25 he doesn't own the ship anymore, that he sold it to Hong Kong. VICKI HUMPHREY, CSR MANSFIELD, TX METRO(817)477-2035 NEBOJSA SIKIMIC 87 1 Q. Well, he sold it back, that sort of -- Well, was it 2 your understanding then that he owned the ship, that he could 3 sell it? 4 A. Don't understand. That's what everybody knew that he 5 owns the ship. 6 MR. PULLMAN: Object as being nonresponsive. 7 Q. Okay. When did you -- When did you first find out 8 about him owning the ship? 9 A. When the ship moved to Taiwan. That was the only 10 safe place that they can go without paying some dues or -- 11 Q. Okay. Well, when was that approximately, if you 12 know? 13 A. Year before I saw him, so that should be 2002, say 14 maybe summer 2002. 15 Q. Okay. All right. 16 A. For the courts, it's easy to track. Just see the 17 guys that went there. They have a date in their passport and 18 if they want, they can find out exactly. 19 MR. PULLMAN: I object to all that as being 20 nonresponsive. He's not here as an agent of the court. 21 Q. Okay. The security personnel that were sent to work 22 on the ship that we discussed earlier -- 23 A. Yeah. 24 Q. -- did their duties -- do you know whether or not 25 their duties included escorting money to and from the ship? VICKI HUMPHREY, CSR MANSFIELD, TX METRO(817)477-2035 NEBOJSA SIKIMIC 88 1 MR. PULLMAN: Object to the form of the 2 question. Object to the question as being leading. Object to 3 the area as to the duties of security as being not relevant to 4 the issues before the court today. 5 Q. Okay. You can answer the question. 6 A. They supposed to be involved in any kind of money 7 transfer or -- 8 Q. Okay. Did you have any involvement with any money 9 transfers to or off the ship, you personally? 10 A. Well, I tell you the story, so I don't know if that's 11 involvement or not. One night I get a call to meet Brian in 12 head office. It's 1:00 o'clock in the morning. Meet him 13 there. They supposed to give me a check to give to Proka 14 that's going -- supposed to go tomorrow to the ship. It's 15 Proka, P-r-o-k-a. I went to head office 1:00 o'clock in the 16 morning. It was Brian Egli and Grace Su. They give me the 17 envelope. I don't know to who. They says here's a check for 18 Proka, and Brian says, actually, no, I'm going to come 19 tomorrow to airport. I'll give him the check. So if it's any 20 involvement, I don't know. I'm just telling you what 21 happened. I don't know if I was involved or not. I went 22 there, they give him check and he went to Hong Kong. 23 Q. Okay. Did you actually see the check? 24 A. I saw the check, but I don't know the -- I don't know 25 the amount. I heard amount from Brian Egli. Brian Egli told VICKI HUMPHREY, CSR MANSFIELD, TX METRO(817)477-2035 NEBOJSA SIKIMIC 89 1 me. I didn't see it, but vice-president told me that it's 2 $900,000.00 Canadian. 3 Q. All right. And the check was supposed to go to China 4 Sea Discovery, is that what you said, the ship? That's what 5 we're talking about? 6 A. To Hong Kong. I don't know if it's ship or -- 7 Q. It was going to Hong Kong. 8 A. Yeah. 9 Q. All right. Was the China Sea Discovery ever 10 mentioned by anyone as to where the money was going? 11 A. Well, that was money for the ship. I don't know, you 12 know, if the -- 13 MR. PULLMAN: Object to the response -- to the 14 answer as being nonresponsive. 15 Q. Just told you that it was money for the ship; is that 16 what you're saying? 17 A. Yeah. They need money and -- again they need money. 18 That's what Brian says. And we are spending money all the 19 time, so here's another 900,000. That's what he says. I 20 never saw the check or -- 21 Q. Okay. Do you know the names of any specific security 22 personnel that were involved in handling documents created 23 with operating the ship? Well, let me back up. We've talked 24 about this before, how some of them made reports and, you 25 know, I'm talking now about documents in general, documents VICKI HUMPHREY, CSR MANSFIELD, TX METRO(817)477-2035 NEBOJSA SIKIMIC 90 1 that came to the ship, documents that moved off the ship, 2 okay? I don't care what they had to do with. Were security 3 personnel involved with getting documents ready to go off the 4 ship? 5 A. Yes. 6 Q. Okay. Can you tell me the names of any of those 7 personnel that were involved with that? 8 MR. PULLMAN: I object as to any questions 9 regarding documents going on and off ship as having nothing to 10 do with the issues before the court. 11 Q. Okay. You can answer the question. 12 A. Yeah, Proka told me, P-r-o-k-a. 13 MR. PULLMAN: Object further as hearsay. 14 Q. All right. Do you have any personal knowledge about 15 documents leaving off the ship and who was involved in packing 16 them up or escorting them? 17 A. No. 18 Q. When I say -- Okay. Did -- In the reports that you 19 got from the security personnel, did any of those reports 20 address the issue about how the ship was being operated? 21 A. Yeah. Messy, bad procedures, they don't follow 22 procedures, they have their own procedures, so they're not 23 exactly the same way we do and operate our casinos in 24 mainland. 25 Q. Who was the person that made these reports? VICKI HUMPHREY, CSR MANSFIELD, TX METRO(817)477-2035 NEBOJSA SIKIMIC 91 1 A. Get ready. Vlada, V-l-a-d-a; Milo, M-i-l-o; Sasha, 2 S -- well, everybody that was working. I can go through the 3 list after that, write all the names, but everybody that was 4 on the ship from security and surveillance side, they report 5 to me. They're reporting the mess and they're running 6 totally, you know, unorganized and -- 7 Q. You were getting reports from all the personnel that 8 were on the ship then in the security? 9 A. Written from Vlada and Sasha. Those two guys are 10 giving written reports. Everybody else, they're on the phone, 11 when they come back, when they're coming here for holidays. 12 They used to come here for holiday and go back. 13 Q. All right. Who did you convey, if anyone -- Scratch 14 that. Did you convey these reports to anyone? 15 A. Brian and Adrian. Nobody else. Everything I had 16 with the ship, I discuss with Brian and Adrian. 17 Q. Brian -- 18 A. Egli. 19 Q. And Adrian Thomas. 20 A. Exactly. The vice-president and the president. 21 Q. Okay. How much of a delay was there from the time 22 you got the reports and the time you passed them on to those 23 individuals? 24 A. Sorry. How much was the delay of the time? 25 Q. Was there -- When you got the reports, when you VICKI HUMPHREY, CSR MANSFIELD, TX METRO(817)477-2035 NEBOJSA SIKIMIC 92 1 received the reports, how much time passed before you passed 2 them on to these other people? 3 A. Hour, half an hour; maximum, couple of hours if 4 they're not in the office or -- 5 Q. Okay. All right. Were you aware of what the 6 ownership of the ship was? 7 MR. PULLMAN: Asked and answered. 8 MR. RAY: I don't think I've asked that. 9 MR. PULLMAN: That's fine. 10 MR. RAY: I don't think I have asked that 11 specific question. 12 MR. PULLMAN: See if he gives the same answer he 13 gave before. 14 Q. Do you know who owned the ship? 15 A. I says, the best of my knowledge is Great Canadian. 16 I thought it was a Great Canadian ship. 17 MR. PULLMAN: Yeah. 18 Q. With regard to the reports we just talked about -- 19 MR. PULLMAN: Consistent. 20 MR. RAY: I'm sorry, Richard, I didn't want 21 to -- 22 MR. PULLMAN: I apologize. 23 Q. With regards to the reports we just talked about that 24 you passed on to your superiors, did you get any response from 25 them relative to those reports? VICKI HUMPHREY, CSR MANSFIELD, TX METRO(817)477-2035 NEBOJSA SIKIMIC 93 1 A. Yes. Brian is -- executive vice-president is more 2 against all those things that was going on, you know. He was 3 more for legal stuff and he thought there was lots of things 4 that's illegal down there, he didn't like it. He's ex-RCMP 5 and the way that he looks is very strict. He didn't like it. 6 That's what he tells me, so I don't know when he talk to 7 Adrian what's the story, like comes to Adrian and stays 8 there. So I don't know. Those two made decision. They're 9 vice-president and president, so they get together and decide 10 what they're going to do. 11 Q. Did Adrian ever tell you anything in response to the 12 reports? 13 A. No. Like I says before, anything you do, that's the 14 way they do there. That's the way that they do there, that's 15 the way they do on the ship. 16 Q. Is Brian still employed with Great Canadian? 17 A. Yes. As far as I know, yeah. 18 Q. Does he still hold the same title -- 19 A. I think so. 20 Q. -- that he held when you were there? 21 A. Yeah. Executive vice-president, yeah. 22 Q. You can't ask for somebody else to help you. Just 23 say what you know. 24 A. That's what I -- the best of my knowledge. 25 Q. All right. Okay. Are you familiar with the places VICKI HUMPHREY, CSR MANSFIELD, TX METRO(817)477-2035 NEBOJSA SIKIMIC 94 1 that the ship visited, the ports it called on? 2 A. Yes. 3 Q. Okay. What were those? 4 A. Hong Kong, Hainan was the name of the China island 5 over there, Vietnam. I don't know what was the name of the 6 city, but they just call me and says we are in Vietnam and 7 it's beautiful, rich country. 8 Q. When you say Hainan, are you referring to the island 9 that we had the problem with the plane, force landed on it? 10 A. Yeah, that's correct. I remember. 11 Q. Okay. Any other ports? 12 A. After that, they went to -- what's the real word when 13 they put the boat that's not in the sea? They dock. They get 14 some construction in the Hong Kong and -- 15 Q. Are you talking about dry docking it? 16 A. Yeah, dry docking it or whatever. It was there. And 17 after that, I think they had a problem. They hit something in 18 Hainan. They hit the barge, so they fix that. But 19 everything -- the reports that I receive, they're running 20 away, all money to Hong Kong. I don't know who. They owe 21 money to China. They been paid some Mr. Y or White. He wants 22 to take the ship. I remember guys sending reports there was 23 guns on the ship. Everybody is, you know, running scared for 24 their lives from operation and -- 25 Q. And so what happened then with the ship? VICKI HUMPHREY, CSR MANSFIELD, TX METRO(817)477-2035 NEBOJSA SIKIMIC 95 1 A. What happened, Gary, I think, shows up like a savior, 2 says, okay, I have connections in Taiwan, we're going to go to 3 Taiwan, we don't have to pay for docking or taxes or whatever, 4 the cheapest way to, you know, to get the ship into Taiwan. 5 They don't have money for gas apparently, so they have to go 6 slow speed, just move. 7 Q. Okay. Are you familiar with a gentleman named Tom 8 Bell? 9 A. Yes. 10 Q. Do you know whether or not Tom Bell ever visited the 11 ship? 12 A. Yes. 13 Q. Okay. 14 MR. PULLMAN: I think this is probably a similar 15 area, so in case it is, I would object as it being not 16 relevant to the issues before the court. 17 Q. Okay. Do you know how many times Tom Bell visited 18 the ship? 19 A. He went on a trip more than once. I don't know if he 20 was going -- he was at the ship, I know, but how many times I 21 don't know. He was in Hong Kong, going back and forth. 22 Q. Was he operating out of Hong Kong or going back and 23 forth to -- 24 A. He stays for a long time, I would say, in Hong Kong. 25 He stays for quite a long time. Could be more than a month VICKI HUMPHREY, CSR MANSFIELD, TX METRO(817)477-2035 NEBOJSA SIKIMIC 96 1 or -- 2 Q. Okay. All right. Do you know -- Are you familiar 3 with Michael Scholz? 4 A. The name? Yes. 5 Q. Okay. Do you know whether Mr. Scholz ever visited 6 the ship or not? 7 A. I saw him on the ship. I've got a tape of him on the 8 ship, so yes, he was on the ship. 9 Q. Okay. Do you have any knowledge about what he was 10 doing on the ship? 11 A. No. Having fun. It's opening, you know, be there 12 like all the big shots, whatever. 13 Q. All right. Are you familiar with Mr. Charles Ming? 14 A. Yes, I am. 15 Q. All right. Do you know whether or not Mr. Charles 16 Ming ever visited the ship? 17 A. Yes, he was at the ship. 18 Q. Okay. Do you know what prompted Mr. Ming to visit 19 the ship? 20 A. As far as I know, he's a partner. He's a 21 shareholder, he's a partner of the Great Canadian Casino. 22 He's connected. 23 MR. PULLMAN: I object to the answer as being 24 nonresponsive. 25 Q. Okay. I think you said earlier you were familiar VICKI HUMPHREY, CSR MANSFIELD, TX METRO(817)477-2035 NEBOJSA SIKIMIC 97 1 with Mr. Walter Soo. You've already said that. 2 A. Yes. 3 Q. Did Mr. Walter Soo visit the ship? 4 A. Yeah. Yes, yes, yes. 5 Q. I'm not sure I'm remembering this correct. I think 6 you said he was doing something on the ship. Can you tell us 7 what he was doing on the ship? 8 A. He was -- He is the guy that put -- To my 9 understanding, he is the guy that put everything together, you 10 know. He's walking around with a piece of paper with all the 11 numbers. Here we are going to make 80, hundred million 12 dollars, bla-bla. I think he was a director of -- manager of 13 project development, something like that. That was his baby, 14 how we call that. So he was doing all the numbers. And I 15 think he was -- you know, he was in charge. He was there 16 for -- 17 Q. Did you see him -- Excuse me. Did you see him on the 18 tapes ever on the ship, that were made on the ship, the 19 videotapes? 20 A. Yes, but he spend most of the time -- I get the 21 reports. They told me that he was more in the office or hotel 22 in Hong Kong. 23 Q. Okay. Are you familiar with Mr. Ross McLeod? 24 A. Yes. 25 Q. Okay. Did you ever see -- or did you ever have VICKI HUMPHREY, CSR MANSFIELD, TX METRO(817)477-2035 NEBOJSA SIKIMIC 98 1 knowledge of Mr. McLeod visiting the ship? 2 A. No. 3 Q. Okay. What is your understanding of the position 4 that Mr. McLeod, if any, that he holds with regards to Great 5 Canadian Cruises, Inc.; do you know? 6 A. Can you repeat, please? 7 Q. Okay. Let me ask it this way: Do you know whether 8 or not Mr. Ross McLeod has any position with Great Canadian 9 Casinos, Inc.? That's what I meant to say. There's so many 10 of them I get them mixed up. 11 A. I thought he bought the ship. 12 Q. Pardon? 13 A. My understanding is he bought the ship. 14 Q. Okay. All right. 15 MR. PULLMAN: I object to that as being 16 nonresponsive. The question was: What's his position with 17 Great Canadian Casinos. 18 Q. Do you know what his position with Great Canadian 19 Casinos -- 20 A. He is the owner, yeah. 21 Q. Okay. Do you know what his position is with Great 22 Canadian Gaming Corporation? 23 A. He's chairman. When I left, he was the chairman. 24 Q. Okay. All right. Are you familiar with a gentleman 25 by the name of Mr. Steven Ming? VICKI HUMPHREY, CSR MANSFIELD, TX METRO(817)477-2035 NEBOJSA SIKIMIC 99 1 A. I heard that name, yeah. 2 Q. But you're not familiar with him? 3 A. I saw him on a tape and on the reports. I have to 4 say exactly. They call him an idiot. The people from 5 surveillance send a report, says he's an idiot. He wants 6 to -- he thinks he is a big boss, he runs the show, he owns 7 this and that, and he was just showing off there, so... 8 Q. Okay. Well -- 9 A. They didn't like him, so... 10 Q. Did the report say what he was trying to run, what it 11 was he was trying to run specifically? 12 A. One of the reports I remember they mention that he 13 was -- equipment, change the speakers on the theater or 14 whatever. They have to play something. You know, he was 15 spending money changing speakers and he didn't care about some 16 other things that are more important. Really people that was 17 on the ship they know more. I just -- When I ask who's the 18 guy, you know, and they call him the names, knowing that 19 Charles Ming is a partner, I says just leave him alone, don't 20 give him really a hard time because somebody mention -- I 21 don't know, Proka or Vlada -- they're going to push him off 22 the ship or something like that. I don't know if it's not 23 serious, but they just didn't like him. That's how much -- 24 MR. RAY: All right. I need to take a little 25 break here, Richard, and I think I'm pretty close to being VICKI HUMPHREY, CSR MANSFIELD, TX METRO(817)477-2035 NEBOJSA SIKIMIC 100 1 through, but I may have just a few questions when we come back 2 on. 3 MR. PULLMAN: Great. Can we take a real quick 4 one or -- 5 MR. RAY: Yeah, just a quick one. How about six 6 or seven minutes? Is that okay with you? 7 MR. PULLMAN: Sure. 8 (Off the record.) 9 MR. RAY: I'm going to pass the witness. 10 11 EXAMINATION 12 BY MR. PULLMAN: 13 Q. I'm a very poor pronouncer here. Sikimic, is that 14 all right or -- 15 A. No, you're there. 16 Q. All right. Mr. Sikimic, how did you come to receive 17 Exhibit -- well, your -- it's disappeared -- Exhibit 5? How 18 did you get this thing? Not this one exactly, but your copy 19 of it. 20 A. There is a guy that give me this in the hotel. 21 Q. Who was this guy? 22 A. I don't know. 23 Q. Some man walked up to you and handed this to you? 24 A. No. He asked receptionist where I am. Receptionist 25 says they're waiting for me, somebody is waiting for me to VICKI HUMPHREY, CSR MANSFIELD, TX METRO(817)477-2035 NEBOJSA SIKIMIC 101 1 serve me some paperwork, and the guy show up, give it to me, I 2 read it, ask him do I have to sign, he says no, and that's it. 3 Q. What were you doing? Is the hotel where you work or 4 live or own or something? How did they know -- How did they 5 find you in this hotel to the best of your knowledge? 6 A. I don't know. 7 Q. What were you doing in the hotel? Were you just 8 eating lunch or something? 9 A. No. My son has three days tournament in water polo, 10 play for B.C., so we were playing against Oregon. There's 11 tournament there. It's an Oregon team, Portland. 12 Q. So you were in Portland, Oregon. 13 A. Yes. 14 Q. Oh, so you're in the United States. Somebody 15 determined -- learned that you were in the United States and 16 then somebody showed up and served Exhibit 5 on you. 17 A. Yeah. 18 Q. When was the first time -- Strike that. Had you ever 19 spoken to anybody about this case prior to showing up in 20 Portland, Oregon? 21 A. Yes. 22 Q. Who did you talk to? 23 A. Dave. 24 Q. Dave -- Help me. 25 MR. WILEY: Oh, I'm sorry. Wiley. VICKI HUMPHREY, CSR MANSFIELD, TX METRO(817)477-2035 NEBOJSA SIKIMIC 102 1 Q. Wiley. How did you get in touch with Mr. Wiley, for 2 the record, who's attorney for Mr. Mahmood, correct? 3 A. He got my phone number. He gives me a call. 4 Q. Okay. And what did he tell you? Tell me about -- 5 When was that conversation? Put it into a time frame. It 6 looks like you got served sometime between January -- December 7 16th and January 20th. Do you know when you were down in 8 Portland for that tournament? 9 A. I think it was December. 10 Q. Okay. Probably after the 16th. Doesn't say on the 11 back when you were served. Okay. So before that, you got a 12 call from Mr. Wiley, attorney for the Plaintiff. 13 A. Yes. He says, you know, hi, my name is David Wiley, 14 I represent this and that, and then -- 15 Q. You need to slow down, and you need to kind of -- 16 please, if you would, not this and that. Hello, my name is 17 David Wiley, I represent... Just everything you can recall. 18 A. He told me who he represent. 19 Q. Who did he tell you he represented? 20 A. What was the name of the company? Alliance or -- 21 Q. Well, let's look. Did he say he represented 22 Allegiance Capital Corporation? 23 A. Yes. 24 Q. Okay. Did he say I'm an attorney? 25 A. Yes. VICKI HUMPHREY, CSR MANSFIELD, TX METRO(817)477-2035 NEBOJSA SIKIMIC 103 1 Q. Okay. And then what did he tell you next? 2 A. He told me that he understood that I'm not with the 3 company anymore. I says yes. And he asked me do I know 4 anything about the ship. So I told him at that time, I said, 5 I cannot talk. I have a contract with the Great Canadian 6 Casino. I'm still paid by the Great Canadian Casino. I'm not 7 allowed to talk about anything that has to do with the casino. 8 Q. The casino. The whole company, not just the ship. 9 A. Yeah. 10 Q. Okay. 11 A. So I didn't release any information. I didn't say 12 anything. I did ask him how he got my number. 13 Q. What did he say? 14 A. He received a phone call. 15 Q. From? 16 A. I don't know. 17 Q. He just said -- Now, let's get through this. You're 18 a security guy and that's your job to follow through on 19 issues, correct? 20 A. (Witness nods affirmatively.) 21 Q. And you're pretty much of a professional guy in that 22 area, correct? 23 A. Yes. 24 Q. Would you call yourself -- consider yourself to be an 25 investigator? Did you investigate things when you were with VICKI HUMPHREY, CSR MANSFIELD, TX METRO(817)477-2035 NEBOJSA SIKIMIC 104 1 the company? 2 A. Yes. 3 Q. Okay. So a lawyer calls you out of the blue and you 4 ask him who -- how did you get my name, and he said, I got 5 your phone number from a guy. 6 A. I don't know if he says from a guy. It was from -- 7 He just get a phone number from somebody. 8 Q. But he didn't tell you who the somebody was. 9 A. No. 10 Q. Did you ask him who was the somebody? 11 A. Yes. 12 Q. What did he say? 13 A. He doesn't know. The person didn't give their name 14 or -- they just give him my phone number and my name. 15 Q. Okay. So he told you -- It's your testimony that he 16 told you that he got an anonymous call who said, call Mr. 17 Sikimic, here's his phone number, he may know something about 18 this case. 19 A. Yes. 20 Q. Okay. What else did you discuss? 21 A. Nothing. In that case, I told him that if he needs 22 more, I give him the name of my lawyer that represent me in 23 Vancouver. 24 Q. And did you give him the name? 25 A. Yes. VICKI HUMPHREY, CSR MANSFIELD, TX METRO(817)477-2035 NEBOJSA SIKIMIC 105 1 Q. And who was that lawyer? 2 A. Reg Harris. 3 Q. Reg Harris? 4 A. Yeah. 5 Q. And that doesn't sound like a Yugoslavian name. 6 A. No, no. He's a -- 7 Q. Irish guy? 8 A. Ex-Vancouver police, he works for them, and now he's 9 a lawyer. I just went and asked him because I don't want to 10 put myself in jeopardy, you know. You get a phone call, you 11 want to do something, so I went and says -- and that's when he 12 told me that -- 13 Q. Let's slow down. We're losing the pronouns as to who 14 they are. You said if you need to know anything else, call 15 Reg Harris. 16 A. If you want to know more, you should talk to my 17 lawyer. What's his name? I give him the name of the lawyer. 18 I went to my lawyer -- 19 Q. No, no, no. Let's finish the conversation with 20 Allegiance's lawyer first. Is that it? You hung up and said 21 bye? 22 A. Yeah. 23 Q. Okay. You never told him that you were going to be 24 in the United States in December, or did you in that 25 conversation? VICKI HUMPHREY, CSR MANSFIELD, TX METRO(817)477-2035 NEBOJSA SIKIMIC 106 1 A. Maybe. Maybe. I can't recall because I told him I 2 suppose to go to Vegas and I suppose to go, I guess, in 3 August, September. 4 Q. September of this year. You talked to him in 5 December. 6 A. No, no. I talked to him before December. I received 7 this in December. 8 Q. How long before December was this conversation? 9 A. I guess it was during investigation. I didn't write 10 it down. I can check the -- 11 Q. Let's make an estimate. You must have -- If you told 12 him you were going to Las Vegas in August, it was before 13 August. 14 A. Maybe in August. 15 MR. RAY: I'm going to object to this whole line 16 of questioning as being irrelevant. 17 Q. Okay. All right. So sometime before August you had 18 this conversation with the attorney for Allegiance. 19 A. Yes. 20 Q. Okay. Tell me what else you can recall. You might 21 have told him you were going to Las Vegas in August. 22 A. Do I plan -- I think he asked me do I plan any trips 23 to states so that they can meet me, they can see me. So I 24 said there is a possibility. I remember mentioning Vegas, I 25 remember mentioning Seattle, and I'm not sure if I mentioned VICKI HUMPHREY, CSR MANSFIELD, TX METRO(817)477-2035 NEBOJSA SIKIMIC 107 1 Portland, but everybody -- everybody knew that I'm going to 2 Portland because that was a very important game. I told 3 everybody. It wasn't a secret. So it was easy to find out. 4 Q. But Mr. Wood (sic) wasn't everybody. In your group 5 of everybody who knew you were going to go to this tournament 6 with your child, he wouldn't have learned it, I wouldn't have 7 known it. You can't imagine that somebody in Texas would know 8 that you were going to Portland for a tournament. You meant 9 everybody up in Richmond. 10 A. Probably I meant that, yes. 11 Q. All right. What else can you recall from that 12 conversation? 13 A. Not much. 14 Q. Did you have any other conversations with any 15 attorneys for the Plaintiff prior to you being served Exhibit 16 5? 17 MR. RAY: Again, we're going to reiterate our 18 objection as being irrelevant to the issues in the case. 19 A. No. 20 Q. Okay. Did you talk to your attorney about this? Did 21 you go back and talk to Mr. Harris about, hey, did this guy 22 ever call you? 23 A. Yes. 24 Q. What did he say? 25 A. He did call him. They did talk. VICKI HUMPHREY, CSR MANSFIELD, TX METRO(817)477-2035 NEBOJSA SIKIMIC 108 1 Q. What did they discuss? What did you learn they 2 talked about? 3 A. I learned -- My lawyer called me and says, okay, 4 don't ask me why. I'm going to ask you a few questions. Are 5 you aware there is prostitution on the ship? I says yes. Are 6 you aware that they tried to hijack the ship? Yes. Are you 7 aware there was some -- I don't know how -- what he used, some 8 lawyer's word for the non-normal activities or whatever. Says 9 yes. That's all. And I asked him what should I do. He says, 10 if you get a subpoena, you have to go. When I discussed with 11 Adrian Thomas that he has a -- 12 Q. We're going to do it piece by piece. Okay. So 13 that's all the conversations you had with your lawyer prior to 14 you getting this Exhibit 5. 15 A. Yes. 16 Q. Did you have any more discussions? 17 A. With the lawyer? 18 Q. Yeah, before you got served this thing on -- this 19 Exhibit 5 regarding this issue. I don't care if you talked 20 about something else. 21 A. No. 22 Q. Okay. Now, who else did you talk about this case 23 prior to you receiving the subpoena, Exhibit 5? 24 A. Adrian Thomas. 25 Q. Okay. How many times was that? VICKI HUMPHREY, CSR MANSFIELD, TX METRO(817)477-2035 NEBOJSA SIKIMIC 109 1 A. At least twice. 2 Q. Twice before being served the subpoena? 3 A. Yeah. 4 Q. And at the time you spoke to Adrian Thomas, he was an 5 officer of one of the Defendant companies, correct? 6 A. President, yes. 7 Q. Of? Do you recall which company? 8 A. Great Canadian Casino, Inc. 9 Q. And tell me about the conversations -- Tell me about 10 the first conversation you had. I think you probably already 11 talked about this, but let's please tie them down one by one. 12 When was the first conversation you had? 13 A. Hard to get a time. I don't want to go on the time, 14 but it's obviously when I received the call, which we 15 mentioned could be July, August, so let's use July. 16 Q. Sometime before you were going to Las Vegas, whenever 17 it was. 18 A. Yeah. 19 Q. Go ahead. 20 A. I told him I received the phone call, and at that 21 time he says that's Proka, P-r-o-k-a. He thought that he 22 phoned David and told him about me because he wants to stir 23 some -- 24 Q. Proka is one of the guys that went to the ship? 25 A. Yes. VICKI HUMPHREY, CSR MANSFIELD, TX METRO(817)477-2035 NEBOJSA SIKIMIC 110 1 Q. Now, he's not the guy that's out in the hall now that 2 we're going to depose later, is he? 3 A. Yes. 4 Q. Oh, that's Proka. 5 A. Yeah. 6 Q. Okay. Is he a cousin of yours? 7 A. No. 8 Q. You said some of these guys are your relatives, but 9 not him. 10 A. Yeah. 11 Q. Okay. So what else did you and Adrian Thomas discuss 12 in this first conversation? 13 A. He told me that he doesn't know why they need me, how 14 I can help them, so he says at that time -- the only thing he 15 says they're interested in is what I heard that's 16 prostitution, which I did not answer. I told David I cannot 17 talk about that because I'm under a contract with the Great 18 Canadian Casino. 19 Q. Did David ask you each of the questions that your 20 lawyer asked you later? 21 A. No. 22 Q. Okay. David only asked you about prostitution? 23 A. Yes. 24 Q. You can't recall anything else? 25 A. No. VICKI HUMPHREY, CSR MANSFIELD, TX METRO(817)477-2035 NEBOJSA SIKIMIC 111 1 Q. Okay. All right. What else did you discuss with Mr. 2 Thomas in this first discussion about the -- 3 A. You know, we are thinking doing an investigation who 4 was -- who could have been the person that made the phone 5 call, and it was inconclusive at that time. 6 Q. Have you learned today who made the phone call to 7 David? 8 A. No. 9 Q. Have you asked him? 10 A. Yes. 11 Q. You asked him again recently? 12 A. Recently, no. 13 Q. When did you ask him again? 14 A. Last time when we talked. Could be maybe couple of 15 weeks or -- I think when I phone him and my wife's sick, so 16 she has to leave the country, couldn't make it, so that was 17 when we talk and -- 18 Q. To reschedule? 19 A. Yeah. No, he doesn't know. 20 Q. He doesn't know who called him. 21 A. No. 22 Q. Okay. All right. Now, is that all you can recall of 23 this next conversation with Adrian Thomas? 24 A. The next conversation with Adrian -- 25 Q. Was that it? That's it with this -- you finished the VICKI HUMPHREY, CSR MANSFIELD, TX METRO(817)477-2035 NEBOJSA SIKIMIC 112 1 first one? 2 A. Yeah. 3 Q. Okay. Let's talk about when was the next one? 4 A. Next one is after I talk to my lawyer, yeah, and -- 5 Q. Okay. So the order is first you hear from David, 6 then you talk to Adrian, and then you talk to your lawyer, now 7 you talk to Adrian again. That's where we are now. 8 A. Yes. I've been told -- I missed that part, but 9 thanks for reminding me. They offered me to pay the lawyer's 10 fee, Great Canadian Casino. Adrian offer me to pay the 11 lawyer's fee if I go and chat with the lawyer, do I have to 12 go, do I have to come here. 13 Q. Okay. That's the first conversation. 14 A. Second. 15 Q. Second one. Okay. But your lawyer had already told 16 you you did -- no, no, that's -- he didn't. You just reported 17 it to him. So now you talked to Adrian the second time and he 18 says go check with your lawyer to see if you have to go. 19 A. Yeah. 20 Q. Anything else in that second conversation? 21 A. No. I tried to -- He never told me the numbers. I 22 tried to find out, says what's this all about. I read in the 23 newspaper some numbers, but what's this all about. Oh, don't 24 worry, they don't have a chance, you know. 25 Q. All right. So then you talked to your lawyer again VICKI HUMPHREY, CSR MANSFIELD, TX METRO(817)477-2035 NEBOJSA SIKIMIC 113 1 and he asked you a bunch of questions. 2 A. I didn't talk to him. He phoned me and he says, 3 don't ask any questions, like I says before, just answer the 4 questions, and he asked me those three or four questions that 5 I says. 6 Q. And then he said -- 7 A. I says yes, yes, yes, yes. He says, okay, that's 8 all. That was the conversation. I call him on different 9 things and I ask him, by the way, did you call the people from 10 Texas, did you talk to the people from Texas, he says yes, and 11 give me the names for all the -- your friends there on the 12 ship. He still wants me to stay, do not go and just give the 13 names and send those guys -- or I don't know what was his 14 idea. It's lawyer's business. You know probably better. But 15 he wants all the names. I says, okay, I give him all the 16 names. I don't know if he ever send the names or give 17 somebody else those names, but I give the names and he says, 18 you should for now stay there. If you get subpoena, you have 19 to go. 20 Q. Okay. 21 A. I asked him -- I remember telling my lawyer and 22 Adrian that I planned to move to Vegas and work, I have 23 opportunity to work there, and I said I don't want to have any 24 trouble with United States, you know, authority like that I'm 25 hiding something or -- so I want to make everything clear, VICKI HUMPHREY, CSR MANSFIELD, TX METRO(817)477-2035 NEBOJSA SIKIMIC 114 1 finish what I have to and I'm done. So he says in that case, 2 go for it. 3 Q. Go for what? 4 A. For where I am right now. 5 Q. Okay. 6 A. Nobody tried to stop me, not even Adrian or my 7 lawyer. 8 Q. Okay. Now, you said that Adrian spoke to you -- 9 You've already discussed that. Okay. So then you end up in 10 Portland and you're at the hotel for your child's polo match, 11 tournament. 12 A. Uh-huh. 13 Q. And here comes somebody that hands you Exhibit 5. 14 A. Yeah. 15 Q. And Adrian knew you were going to be in Portland? 16 A. Yeah. 17 Q. Everybody did. Do you believe that the man we're 18 going to depose next -- 19 A. Yeah, yeah, yeah. 20 Q. He knew. Proka? 21 A. He knew. All the friends knew. 22 Q. All right. Everybody knew you were going there. You 23 never got any phone call in advance from any lawyer or anybody 24 else that says, by the way, while you're in Portland, they're 25 going to serve you with a subpoena. You were surprised. VICKI HUMPHREY, CSR MANSFIELD, TX METRO(817)477-2035 NEBOJSA SIKIMIC 115 1 A. I can't recall. 2 Q. Were you surprised then? 3 A. Honestly, no. 4 Q. Why? 5 A. I'm waiting for that. I know it's going to happen. 6 Why would I be surprised? 7 Q. Okay. So you basically understood that as soon as 8 you set foot in the United States, if somebody could find you, 9 they were going to bring you the service. 10 A. They asked me lots of questions on the border. I 11 remember that. I'm telling Adrian that. 12 Q. What? I'm sorry. I didn't understand. 13 A. They asked me lots of questions at the border, like 14 where I'm going, why I'm going, and I'm like with the four 15 kids -- three kids in the car. That's -- where are you going 16 to stay? I told them. So I thought that they have maybe -- 17 they, whoever, send information to border, they have in 18 computer. They find out through that where I'm going, where 19 I'm staying, what I'm doing. I also had -- he ask me if 20 they're going to renew. I had that working permit for United 21 States, A-3. Are you going to renew this? I says no, I'm not 22 with the casino anymore. I just need that for the casino when 23 I was coming to casino in Washington. So you're not going to 24 renew it. I don't think so. 25 Q. All right. Now, let's go to the next question. VICKI HUMPHREY, CSR MANSFIELD, TX METRO(817)477-2035 NEBOJSA SIKIMIC 116 1 Totally unrelated. You testified earlier, I think, that Great 2 Canadian Casinos invested $15,000,000.00 into this casino 3 boat. 4 A. That's what I heard. 5 Q. Right. And you know of at least $9,000,000.00 -- no, 6 I'm sorry -- $900,000.00 that you sort of saw and heard was 7 sent over to help support this boat. 8 A. No. I heard. It was never questioned. The question 9 was if I ever was involved in any money sending or 10 transferring or whatever, so I says I don't know if that's 11 involvement, but that's the only time I was close to anything 12 being sent. 13 MR. RAY: Yeah, I'm going to object to the 14 question as it doesn't state what the original question was. 15 Q. Did you understand that the $900,000.00 Canadian was 16 going to Hong Kong for the benefit of the ship? 17 A. Yes. 18 Q. Okay. Did you further understand or were you aware 19 of any more money sent over there? 20 A. I heard that our total was $27,000,000.00. 21 Q. Okay. 22 A. You know, smoking room, Brian, everybody else talking 23 about that. Our loss was about 27. That's what I heard. 24 Q. And you worked and were the head of security at one 25 point, you worked for Great Canadian for 12 years. VICKI HUMPHREY, CSR MANSFIELD, TX METRO(817)477-2035 NEBOJSA SIKIMIC 117 1 A. 14. 2 Q. 14 years. More than 12 years. 3 A. Yeah. 4 Q. And from what I heard you say -- pardon the pun -- 5 Great Canadian in Canada ran a tight ship, ran a good ship. 6 A. Exactly. 7 Q. And can you tell this Court and jury any way under 8 the sun that Great Canadian wanted to lose $27,000,000.00 on 9 that casino boat, it was the desire to lose -- its goal was to 10 lose $27,000,000.00? 11 A. Probably the way -- 12 MR. RAY: Object as to form. 13 Q. Is that a -- You don't understand what I'm saying? 14 Let me try again. Based on your involvement and your 15 experience with Great Canadian, do you believe that Great 16 Canadian wanted to lose $27,000,000.00 on that boat? 17 MR. RAY: Object as to form. 18 A. No, I don't believe they want to lose $27,000,000.00. 19 Q. Okay. Do you really understand how things are done 20 in the far east with casinos and casino ships? 21 A. Really means hundred percent or -- 22 Q. Yeah, hundred percent. 23 A. Close to really. 24 Q. No, no, hundred percent. 25 A. Hundred percent, no. VICKI HUMPHREY, CSR MANSFIELD, TX METRO(817)477-2035 NEBOJSA SIKIMIC 118 1 Q. When Adrian Thomas told you -- Let's stop. Let's 2 back off that. Adrian Thomas told you several times that's 3 the way they do things over there. 4 A. Yes. 5 Q. Do you believe that Adrian Thomas was lying to you or 6 is that -- or do you believe that's the way he understood 7 that's the way they do things over there? 8 A. That's two questions. What should I answer? 9 Q. No, it's either/or. 10 A. Do I believe that he lied or -- 11 Q. Or do you believe that he believed -- 12 A. At that time -- 13 Q. Okay. Do you believe he lied? 14 A. I can't answer that. Even if I believe, I can't 15 answer because -- 16 MR. RAY: We're going to object to that question 17 as to form. 18 A. I worked for the guy. I was ready to give my life at 19 the time for him, so why would I believe he lied? Maybe now I 20 think -- 21 Q. No, that's all I wanted. You answered it. Do you 22 believe that Mr. Thomas believed that's the way they did 23 things over there when he told you that? 24 A. I don't know. 25 Q. Okay. That's fine. All right. So now you get VICKI HUMPHREY, CSR MANSFIELD, TX METRO(817)477-2035 NEBOJSA SIKIMIC 119 1 served with Exhibit 5. We're up to sometime in mid to late 2 December, correct? 3 A. Yeah. 4 Q. You're in Portland. 5 A. Yes. 6 Q. From that day, when was the next time you spoke to 7 any attorney representing Great -- Allegiance? When is the 8 next time you spoke to one of those guys? 9 MR. RAY: I'm going to continue my objection 10 here since we're back on that subject again. It's irrelevant. 11 A. Maybe a month. 12 Q. Okay. 13 A. Whatever we discuss now, it's easy to find. There's 14 a telephone record, you know. 15 Q. I understand. The purpose of this is to really do 16 your best recollection like you've been doing. 17 A. Probably a month, say. You know, you have to give 18 me -- I can't be strict on the time. 19 Q. Well, let's look at this. You were supposed to 20 testify on January 20th, so you must have spoken to them 21 before that, one, to say that your wife was ill. 22 A. Yeah. No, it's not January 20th. That one was, I 23 think, canceled because of your case, so I did talk -- you 24 have something, you cancel, you move one day or something. 25 Q. Maybe so. VICKI HUMPHREY, CSR MANSFIELD, TX METRO(817)477-2035 NEBOJSA SIKIMIC 120 1 A. And I told them there's no way I can drive in 2 January. I think that's the reason it's not January. So we 3 move for March, whatever was date, and that happened -- I did 4 fax all the documents here, plane tickets where my daughter 5 and my wife went to emergency to Yugoslavia. I want to just 6 make clear why I didn't come -- 7 Q. Sure. 8 A. -- all the proof. And after that I phone him and I 9 says, yeah, I'm coming and we get the date for -- so maybe I 10 talk to him three times. 11 Q. All right. During those three times, did you discuss 12 anything about your testimony or were you only discussing when 13 you were going to get here? 14 A. On the phone we didn't really discuss anything. On 15 the phone I didn't discuss anything. He didn't ask me too 16 many things. I remember the only thing that I mentioned, it 17 was what if I don't come, what's going to -- just in case, if 18 something happen. He says it's going to be very difficult. 19 They would like to do that, you know, as soon as possible to 20 get over with that. And so the last conversation, I think I 21 told him I'll be there dead or alive. 22 Q. So the end of the story is until you got here, you 23 didn't discuss anything other about your testimony. 24 A. Not really, no, no. 25 Q. Okay. If you did, you don't remember it today. VICKI HUMPHREY, CSR MANSFIELD, TX METRO(817)477-2035 NEBOJSA SIKIMIC 121 1 A. Why? Do you think I wouldn't tell you or -- 2 Q. No, I'm saying if you did discuss something, you just 3 don't remember it. 4 A. I thought I'm supposed to tell the truth and only 5 truth. I said no, I didn't. I said I didn't. It was no 6 details, nothing. Even they didn't want to keep last night 7 when I bring the documents. I says keep it for tomorrow. 8 They says no, no, no, you take them and bring them tomorrow. 9 Q. All right. What caused you to bring these documents 10 with you? How did you know to bring those documents? 11 A. I've been told, yeah. 12 Q. By whom? 13 A. By lawyers from the other side. 14 Q. So that is one thing you did discuss with them, to 15 bring -- How did it come around? 16 A. I mentioned that. I says, if you go back, you're 17 going to see that in August when he talked to me I told him 18 that I'm in contract, that I cannot talk about anything in the 19 casino because I still get paid by casino, and that release 20 form says I shouldn't talk anything about casino, anything 21 about directors and et cetera. So he told me to bring that. 22 Q. Back in August? 23 A. No. 24 Q. When did he tell you to bring that? 25 A. When we decide we're going to see each other. So it VICKI HUMPHREY, CSR MANSFIELD, TX METRO(817)477-2035 NEBOJSA SIKIMIC 122 1 could be a week, two ago, ten days. 2 Q. All right. But that's the only thing other than 3 scheduling that you now recall that you discussed. 4 A. Yeah. 5 Q. Okay. How much are you being paid to testify? 6 A. 85,000 a year. What I paid from casino or -- 7 Q. No, paid to come here today. I like the answer, but 8 I don't think it's what you wanted to give. 9 A. Is it a joke or -- No, nothing. I get paid for my 10 expenses and that's all. 11 Q. And how do you calculate your expenses? 12 A. Those things they call receipts. So whatever you 13 spend, you bring it. And I used to do that. I have 14 experience doing that in the casino. So all expenses is going 15 to be paid. It's not going to be from my pocket. I won't 16 make any profit, just get paid for whatever I spent for the 17 trip. 18 Q. Have you been advanced any or are you advancing it 19 yourself? 20 A. No. I asked for advance and they send me $3,000.00 21 check, and on the check the memo says travel expenses. 22 Q. Okay. 23 A. I did cash that check. I put $2,000.00 on a Visa 24 which I use for all the -- for the gas, for rental, for 25 hotels, sleep, and I do have -- if that's what you call the VICKI HUMPHREY, CSR MANSFIELD, TX METRO(817)477-2035 NEBOJSA SIKIMIC 123 1 receipts. I keep everything and I'm going to give them that 2 and -- 3 Q. Did you drive here? 4 A. Yes. 5 Q. Okay. Do you not fly? 6 A. I don't like flying. 7 Q. Okay. I guess you've got to fly to get to Europe. 8 A. Oh, I did that about 20 times, but I didn't enjoy, so 9 usually -- why push if I don't like it. 10 Q. Okay. When was the first time you met or spoke to 11 Mr. Mahmood? 12 A. Last night. 13 Q. Okay. 14 A. Around 8:00 o'clock, 7:00, 8:00. 15 Q. You met with -- Is that the next -- When was the next 16 time you saw the lawyers for -- 17 A. That's the very first time I saw the lawyers too. 18 Q. Saw everybody at the same time. 19 A. Maybe half an hour different. I says, okay, here I 20 am, give me the address, punch in computer, here's 21 destination, I come here, introduce myself, met those guys, 22 and we went to hotel. They send us to hotel. Yeah, that's 23 about 3:00 o'clock we arrive. We go to hotel, I took a 24 shower, we come back. Only Michael was there. We're sitting 25 in the restaurant. Michael was there and that's when I find VICKI HUMPHREY, CSR MANSFIELD, TX METRO(817)477-2035 NEBOJSA SIKIMIC 124 1 out that he come from San Antonio. We talk about sports, 2 basketball, Dallas. I ask him what's better. I'm Dallas fan 3 for the record. And, you know, talking about sports and 4 everybody show up. 5 Q. Where was the hotel? 6 A. Oh, I don't know. Few, couple of blocks. I don't 7 know what was the name. 8 Q. Did you stay at the Mansion? 9 A. No, no. 10 Q. Did you stay at the Crescent? 11 A. No. 12 Q. You don't know where your hotel is? 13 A. Yeah, I know. 14 Q. What's its address? 15 A. I hope my car is going to stay there. This is the 16 card. I don't know exactly address. I don't know the address 17 really. It's two blocks. If you go right and -- I can show 18 you if it's important. I don't know the address. 19 Q. Okay. And who did you come down here with? 20 A. Proka. 21 Q. Okay. The two of you drove down here. 22 A. Yeah. 23 Q. Okay. What was your business in Yugoslavia? 24 A. What was my business? 25 Q. Yeah. What did you do before you came over here? VICKI HUMPHREY, CSR MANSFIELD, TX METRO(817)477-2035 NEBOJSA SIKIMIC 125 1 A. I was a senior customs officer, charge for truck 2 terminal. 3 Q. And what made you come to Canada? 4 A. 30 percent my sister, 30 percent my wife, and the 5 rest better opportunity, try new life. 6 Q. You had 25,000 stock options at $2.25. 7 A. Yes. 8 Q. How much did you sell them for? How much money did 9 you make off the stock options? 10 MR. RAY: Objection, form. 11 Q. Did you make any money off of the stock options? 12 A. Sure. 13 Q. How much did you make? 14 A. About 150, 200,000. 15 Q. Okay. When did you sell them? 16 A. Some of them in May, some of them in August, some of 17 them in -- I don't know. It's three, four times. The last 18 one I sold May -- 19 Q. May of what year? 20 A. 2003. 21 Q. Okay. Because your agreement says you had to sell 22 them all in 30 days. 23 A. Yeah. 66,000 was the last check, 66,000 Canadian. 24 Q. So you've sold all of your options. 25 A. Yes. VICKI HUMPHREY, CSR MANSFIELD, TX METRO(817)477-2035 NEBOJSA SIKIMIC 126 1 Q. Okay. And you resigned because you were concerned 2 about the missing chip issue; is that correct? 3 A. Yeah. 4 Q. And that was under your watch, wasn't it? 5 A. Yes. 6 Q. And you felt -- When you wrote that letter, you felt 7 that it was an appropriate letter to write, which of course I 8 can't find any more, your letter of resignation. 9 MR. RAY: I'm going to object that the question 10 misstates the -- what he said. 11 Q. When you wrote Deposition Exhibit 1, did you think 12 this letter was appropriate? 13 A. If I sign it, probably I thought that it's 14 appropriate, yeah. 15 Q. Okay. And you also knew that this issue of loan 16 sharks, it was your responsibility if you weren't comfortable 17 that management was handling things, it was your 18 responsibility to report it to the authorities; is that 19 correct? 20 A. Yes. 21 Q. Under Section 86 of the Gaming Control Act, right? 22 A. Right. I'm ready to serve whatever I have to with 23 everybody else involved in that, so I admit my mistake, yeah. 24 Q. Yes, sir. 25 A. And also I was afraid for my life and life of my VICKI HUMPHREY, CSR MANSFIELD, TX METRO(817)477-2035 NEBOJSA SIKIMIC 127 1 family if I go further. 2 Q. But you understand that your resignation was 3 appropriate as you said earlier, correct? 4 A. I signed it, so what can I do? Maybe I don't feel 5 now, but I sign it, so it's there. 6 Q. Okay. And your, whatever you want to call it, 7 departure package was pretty liberal, wasn't it? The company 8 paid you well upon your resignation. You got a year's pay. 9 A. Yeah. I check with a lawyer. He says it's fair. 10 Q. Okay. Is this the same guy, Harris? 11 A. Yes. 12 Q. Okay. Do they use markers in the east in the 13 casinos? 14 A. Markers? 15 Q. Do you know what a marker is? 16 A. No. 17 Q. Have you ever been to a casino in Las Vegas? 18 A. Yeah. 19 Q. Did you ever see somebody at a table sign something 20 and he gets chips in trade for it? 21 A. Yeah, I saw that. 22 Q. All right. 23 A. Getting chips. 24 Q. For signing something. 25 A. Yeah, getting chips for signing something, I saw VICKI HUMPHREY, CSR MANSFIELD, TX METRO(817)477-2035 NEBOJSA SIKIMIC 128 1 that. 2 Q. Do you know whether or not in Hong Kong you can get 3 chips for signing something? 4 A. Yes. 5 Q. Yes, you can. 6 A. Yes, you can. 7 Q. Okay. So that's something different that happens in 8 Hong Kong that doesn't happen in Canada. Canada, you can't 9 sign something and get chips, can you? Or at least at the 10 Great Canadian Casinos, you can't sign something and get 11 chips. 12 A. Yeah. We can do the chip transfer, yeah, in the -- 13 No, no, you can't. 14 Q. You can't. I'm talking about a player, not -- A 15 player in Las Vegas can go to a table and sign something and 16 get chips, correct? 17 A. Correct. 18 Q. And a player in Hong Kong can do the same to the best 19 of your knowledge. 20 A. I heard about Hong Kong; I saw in Las Vegas, so... 21 Q. Okay. You don't know what the deal was with the 22 junket operator as far as -- 23 A. As far as percentage goes. 24 Q. You really didn't know his deal. 25 A. No. VICKI HUMPHREY, CSR MANSFIELD, TX METRO(817)477-2035 NEBOJSA SIKIMIC 129 1 Q. And you can't tell this Court and jury that his deal 2 didn't allow him to get cash from the cage. You just didn't 3 like the way it was done, just grabbing a handful of money. 4 A. Exactly. 5 MR. RAY: Objection, form. 6 Q. All right. And you don't really know how much money 7 this junket operator took. You didn't count it. 8 A. I didn't count it. 9 Q. And nobody's told you how much he took that day. 10 A. Just something -- I says earlier that I don't know if 11 it's junket or agent or whatever. I just saw -- so I don't 12 know who was the guy, so... 13 Q. But you don't know how much was taken either. 14 A. No. 15 Q. Okay. And you don't have any knowledge that the 16 other times when people took money by signing things that that 17 wasn't some form of credit/debit and that they had to pay it 18 back. 19 A. I says earlier that there was -- 20 MR. RAY: Objection. It misstates what he said 21 earlier. 22 A. I says I saw one of the receipts. It's a piece of 23 newspaper, the white part, just the amount. So there was -- 24 if that's legal, that's okay. 25 Q. That's my question. You don't know that when that VICKI HUMPHREY, CSR MANSFIELD, TX METRO(817)477-2035 NEBOJSA SIKIMIC 130 1 guy or woman signed on that piece of paper, the newspaper, 2 that that wasn't a receipt and that it wasn't some 3 credit/debit system. You can't tell this Court to the 4 contrary. 5 A. No, no, no. I tell this Court that I saw -- they 6 zoom in and it's only number, and if I can recall, it's 60,000 7 on a piece of paper, just write down 60,000 and -- 8 Q. All right. But you don't know today if that 60,000 9 Hong Kong or 60,000 whatever they were, was a receipt for 10 getting some money that was owed, i.e. trading in chips, or a 11 receipt for like a marker we discussed earlier and that he 12 owed it back. You can't tell the Court -- 13 A. It's not a marker. 14 Q. How do you know? 15 A. I can guarantee it's not a marker. 16 Q. How do you guarantee that? 17 A. Because as I says before, we see how the things works 18 with the marker in Vegas. I saw the things, how they did on 19 the tape. This is totally illegal. Doesn't matter what 20 country on earth you are. There's no way you're going to 21 write down on a piece of paper just a number and that's going 22 to be a receipt. 23 Q. That's just based on your knowledge of common 24 business practices in Las Vegas. It's not based on your 25 knowledge of procedures in Hong Kong. VICKI HUMPHREY, CSR MANSFIELD, TX METRO(817)477-2035 NEBOJSA SIKIMIC 131 1 A. That didn't say on the procedures that we have. We 2 did have some procedures and policies on the ship and none of 3 them says that you can write on a piece of paper, and so I 4 don't know where you're driving, but that's not a receipt. 5 Q. All right. That's not my question. 6 A. Definitely it's not a receipt. 7 Q. You can't tell me and this Court and jury that that 8 piece of paper caused somebody to either acknowledge receipt 9 of cash in trade for chips or acknowledge that he was going to 10 owe that $60,000.00 later, period. You can't tell this Court 11 and jury that you know for a fact, can you? 12 A. No, but I will fight that. 13 Q. That's fine. The balance is nonresponsive. You said 14 "no". If you want to explain it later, you can. 15 A. I will. 16 Q. That's fine. You're entitled. Who did you have 17 lunch with today? There were the three lawyers, there was Mr. 18 Mahmood, there was you, there was Proka. Is that how you say 19 it? 20 A. Yeah. 21 Q. And there was a seventh guy. Who was that? 22 A. I think the guy that works in the next office. 23 Q. Another lawyer. So there were four lawyers. 24 A. Yeah. 25 Q. Okay. What did you discuss at lunch? VICKI HUMPHREY, CSR MANSFIELD, TX METRO(817)477-2035 NEBOJSA SIKIMIC 132 1 A. What we going to eat and that we have to hurry up 2 because we don't have time. 3 Q. You didn't discuss anything about your testimony? 4 A. No. I don't think all of those -- those guys know 5 better, so... 6 Q. Okay. What did you discuss about your testimony from 7 the minute you -- what have you ever discussed about your 8 testimony with the lawyers for Allegiance or Mr. Mahmood or 9 anybody else representing Allegiance that you haven't told me 10 today up until right now? Tell me every other discussions 11 you've had regarding your testimony, what you were going to 12 talk about. 13 A. Regarding my testimony? 14 Q. Did they ask you any questions? 15 A. No, not really. I asked them, I says, when I start 16 talking and he says "objection", am I allowed to keep talking, 17 and they says, no, you have to let him finish, then you can 18 talk. 19 Q. Okay. 20 A. I didn't know that rule, so I did ask them about that 21 because you get upset, then I get upset, so I want to clear 22 that one. 23 Q. How did you know I was going to get upset? 24 A. You throw the pen. 25 Q. How did you know that in advance? VICKI HUMPHREY, CSR MANSFIELD, TX METRO(817)477-2035 NEBOJSA SIKIMIC 133 1 A. No, no, no. We discuss at lunch. 2 MR. RAY: We told him what a character you were, 3 Richard. 4 Q. All right. What else -- 5 A. They says you're good. They thought you were going 6 to be worse. So we did discuss. I asked them about -- 7 Q. Most times the other witnesses are smaller than I 8 am. You're a pretty big guy. If I was over there, I might 9 not be good. What else? 10 A. No, really we didn't discuss anything about the case 11 or -- 12 Q. At lunch or since you've been here? 13 A. No. 14 Q. Okay. How do you believe that prostitutes on the 15 ship impaired its profitability? 16 A. To who? 17 Q. How do you believe or -- 18 MR. RAY: Objection, form. 19 Q. Do you believe that having prostitutes on the ship 20 had a negative impact upon the profitability of the ship, or 21 do you not know? 22 A. No, but that -- you know, that's two ways. Could be 23 plus, could be minus. All depends who you deal with. 24 Q. Okay. That's a fair answer. Now, who's this idiot? 25 Steven Ming? Is that the idiot? VICKI HUMPHREY, CSR MANSFIELD, TX METRO(817)477-2035 NEBOJSA SIKIMIC 134 1 A. That's what they told me. 2 Q. Now, is he a relative of Charles Ming? 3 A. I think it's his son. 4 Q. Okay. How old of a man is he? 5 A. I have no idea. 6 Q. You just saw him on a camera? 7 A. Yeah, but, you know, oriental, it's hard to tell 8 between 20 and 40. Really it's hard for me. 9 Q. Okay. Tell me a little bit. How old is Charles 10 Ming? 11 A. Oh, Charles Ming is probably, I would say, 65, 70. 12 Q. Okay. So Steven Ming could be any age from about 30 13 to 50 under that arithmetic if Charles Ming is 70. 14 A. He can be 15. 15 Q. Yeah, but you've seen him. 16 A. Yeah, I saw him, saw him on the tape. 17 Q. So you think he's between 20 and 40. 18 A. I would say so, yeah. I mean, I have to be careful. 19 I don't want to give exactly something because I remember 20 asking oriental guy for an I.D., and he says, you're going to 21 look like an idiot when I show you. I says, still show me, 22 and he was 33 years old, and I did feel like an idiot. 23 Q. I kind of like it if somebody asks me for an I.D. 24 They don't. 25 A. If I still have connections, I make them ask you for VICKI HUMPHREY, CSR MANSFIELD, TX METRO(817)477-2035 NEBOJSA SIKIMIC 135 1 I.D. if you come to the city. 2 MR. PULLMAN: That's a deal. Thank you. Let's 3 take a break. 4 MR. RAY: Yes, I think I better do that. 5 (Off the record.) 6 MR. PULLMAN: Mr. Sikimic, I want to thank you 7 for your responsiveness and we pass the witness. Thank you. 8 THE WITNESS: Thank you. 9 MR. RAY: We're not going to have any further 10 questions, so that will wrap it up. Signature before any 11 notary. What is it now? 30 days? Used to be 20. Now it's 12 30, I think. It's got to go up to Canada. I don't know 13 whether it's going to make much difference or not. Do you 14 want to go 20? Is that okay? 15 MR. PULLMAN: I'm happy to go 30. I don't care. 16 MR. RAY: Okay. We'll go 20 if you think you 17 can get it back okay. 18 MR. PULLMAN: If there's a problem, he'll know 19 to call the court reporter and say I'm not getting it done. 20 MR. RAY: Yeah, we'll go 20 days on that. 21 Signature before any notary. Is that agreeable, Richard? 22 MR. PULLMAN: Absolutely. 23 24 (Whereupon, the deposition was concluded.) 25 VICKI HUMPHREY, CSR MANSFIELD, TX METRO(817)477-2035 136 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 137 1 I, NEBOJSA SIKIMIC, have read the foregoing 2 deposition and hereby affix my signature that same is true and 3 correct, except as noted above. 4 5 NEBOJSA SIKIMIC 6 7 THE STATE OF ) 8 COUNTY OF ) 9 Before me, , on this day personally appeared NEBOJSA SIKIMIC, 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 138 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 NEBOJSA SIKIMIC 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, NEBOJSA SIKIMIC, 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 139 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 9 VICKI HUMPHREY, Texas CSR No. 994 Expiration Date: 12-31-2004 10 5 Katie Ct. Mansfield, Texas 76063 11 Metro (817)477-2035 12 13 14 15 16 17 18 19 20 21 22 23 24 25 VICKI HUMPHREY, CSR MANSFIELD, TX METRO(817)477-2035