Opinion
Ramona Featherby d.b.a. California Judicial Recovery Specialists San Diego, CAL
AFFIDAVIT OF RAMONA FEATHERBY IN SUPPORT OF EXAMINATION OF THIRD PARTY
I, the undersigned, declare:
1. I am the Assignee of Record. I have personal knowledge of the facts set forth in this declaration, except as to those matters which are stated on information and belief, and as to those matters, I believe them to be true.
2. The Judgment against Larry and Aida Esacove and their entities remains unsatisfied with an outstanding balance exceeding $15 million.
3. On or about November 5th and 6th, 2010, Larry Esacove proceeded to liquidate his personal property (upon which I hold a lien) by hiring Hughes Estate Sales, Inc. [Hughes'] to sell the contents of his second home at 1240 Ladan Drive in Solvang, California. [Exhibit 1]
4. On November 12, 2010 I served a levy and a subpoena upon Hughes.
5. The information received pursuant to subpoena shows that Hughes is holding $55, 884.55 in funds from the sale, and is also holding unsold inventory.
6. Despite numerous requests, Hughes has refused and continues to refuse to answer the Marshal's levy and turn over funds to the U.S. Marshal.
7. I wish to examine Todd Hughes, managing owner of Hughes in reference to the monies he is holding for the judgment debtors, as the first step toward seeking a turnover order of those funds.
8. I believe that Hughes is holding funds in which the Judgment Debtors hold an interest in excess of $250.00 and can thus be examined as a third party as provided by CCP § 708.120(a).
9. F.R. 69(a)(2) allows a judgment creditor to obtain discovery from any person as provided by the procedure of the state where the court is located. CCP § 708.130 provides that witnesses may be required to appear in an examination proceeding.
I declare under penalty of perjury under the United States of America that the foregoing is true and correct and that this Affidavit was executed on December 18, 2010 at San Diego, California.
EXHIBIT 1
Past Sales
IMMACULATE SOLVANG ESTATE
Save the date! Make a day of it and take a trip into the beautiful Santa Ynez Valley. Attend our sale, and later, enjoy a relaxing conversation over a bottle of wine from one of the area's fine wineries.
Situated on a amazing property in the serene setting of the Regency Hills Estates with endless hilltop views and gentle wildlife visitors sits a seasoned collector's home. The home is an immaculate showcase to decades of antiquing throughout America and Europe.
Bohemian glass in many colors, original American Western art and bronzes, Victorian antiques, Lalique crystal, and carved ivories. Also, expensive designer fashions including high-end handbags and luggage and much more await visitors to charming Solvang to shop this exciting collection of beautiful things.
ORIGINAL ANTIQUE VICTORIAN FURNITURE AND QUALITY VICTORIAN REPRODUCTIONS:
Wonderful 1800's rosewood carved double bookstand
A beautiful carved wood Victorian settee created in the "Belter" style Carved wood Chippendale style settee
7' formal style sofa upholstered in blue and gold damask with tapestry pillows
Hepplewhite style serpentine sofa with paisley upholstery in rich, warm colors
A beautiful wood framed wing chair and matching ottoman
A nice selection of comfortably over-stuffed armchairs
French Louis XV style walnut armchair with tapestry seat and back
An over scaled, beautifully carved oval cocktail table with wonderful details
Also, a handsome, square wood and glass cocktail table with barley twist legs
Victorian style low table with white marble top
Antique mahogany trestle style library table
Wood, brass and glass curio table with figural mounts
Turn of the century oak china cabinet with elegant bent glass front doors display an extensive collection of European porcelain figurines 1930's two-tone mahogany sideboard
William and Mary style English dining room table with 8 caned high back chairs
Late Victorian English oak buffet with beveled mirrors
Vintage 1960's Italian teacart with exotic inlaid woods
Bedroom furnishings include an antique queen size spindle bed, a pair of Victorian style night stands, a tufted ottoman, and a newer serpentine front dresser
Mahogany Chippendale style console desk
Bentwood chair with a beautifully detailed wooden seat
A nice collection of brass and copper urns and kettles, perfect for holding firewood
Henry I style French oak and glass vitrine with gallery top (70"H x 30"W × 16"D)
Mid-Victorian walnut carved alms plate on ornate base (30" H)
Miniature French gilded fire screen with petit point oval insert (33"H × 20"W)
English oak hall tree/umbrella stand
LIGHTING AND OTHER ACCESSORIES:
A wonderful 1930's wood and nickel mantle clock
A beautiful selection of Oriental carpets
A monumental, brass Chippendale style chandelier
Several Victorian Gone with the Wind' lamps, most notably a pair of spectacular RED SATIN GLASS parlor lamps (25" H). An extra-large Gone with the Wind' lamp in a rare "Thistle Flower" pattern, with original shade (28" H). An impressive pair of red Bohemian glass table lamps (40" H)
A pair of Aladdin "Lincoln drape" oil lamps
A nice selection of Victorian and non-vintage Victorian style parlor lamps
We also have several nice contemporary leaded glass lamps
A monumental pair of medieval style hunting horn lamps
MANY BEAUTIFUL COLLECTIONS CAREFULLY CHOSEN OVER DECADES OF ANTIQUING:
A wide selection of porcelain figurines
A nice variety of Lalique
A large variety of Bohemian glass in categories including stemware, serving, and display pieces in cobalt, emerald, and cranberry, each exquisitely painted with gold and floral decoration.
A beautiful assortment of Bohemian clear cut glass vases and centerpiece bowls.
Several nice liquor decanters and character liquor bottles, as well as bar and stemware.
Over a dozen Victorian silver plate and ART GLASS BRIDE'S BASKETS A magnificent pair of covered urns, an impressive 37"H x 20"W with painted scenes and figures in intricate relief. Wonderfully carved ivories, and a beautiful collection of soapstone carvings Elegant traditional pocket watches and gentlemen's dress watches Quality ladies jewelry and beautiful old and vintage style hair combs
ART AND SCULPTURE:
Wonderful original Western art and bronzes, watercolors, woodblocks and drawings, and high quality prints
ROBERT PERRIN (20th Century)
An extensive collection of Western themed watercolors, drawings, and prints
"Courage Under Attack" (19"H × 24"W) has the distinction of being "the only print made from the original owned by Ronald Regan, and now in the RR museum in Simi Valley."
In the Western theme, we also have work by noted artists JUSTIN TSO and J. OATES
ERVIN KAPLAN These are really cool!!!
A personal friend of the homeowner, this really talented California illustrator held some very important positions with Hanna-Barbara and other great companies. We have a HILARIOUS collection of 10 etchings, watercolors, and wood blocks that are Comedic in a "gentle, yet amusing erotic style" making fun of the male psyche.
DESIGNER CLOTHING AND ACCESSORIES:
An extensive collection of Men's and Ladies designer clothing, leather and shearling coats
Beautiful quality gentlemen's dress hats
Several nice walking sticks
AND...
Chanel handbags
Louis Vuitton garment bags
Men's and Ladies perfume and cologne bottles including Cartier, Gucci, Armani Versace Shalimar, Balmain, and more
USEFUL EVERYDAY ITEMS:
Sun Welding safe company, model #C34FL Cavalry safe (60"H x 30"W × 24"D)
Nearly new Maytag Deluxe washer and dryer 2 piece unit Many nice, gently used quality household appliances, including smoker BBQ, some nice outdoor furniture, a nice selection of exterior decorative garden pottery.
A very nice collection of quality Christmas decorations, and much more not seen in photos!