121101 - Deposition Frank Dean Deutsche t Soundview Home Loan Trust 2005-4 v Holden

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

IN THE COURT OF COMMON PLEAS

OF SUMMIT COUNTY, OHIO

DEUTSCHE BANK NATIONAL TRUST

COMPANY AS TRUSTEE FOR

SOUNDVIEW HOME LOAN TRUST

2005 - 4, ASSET-BACKED

CERTIFICATES, SERIES 2005-4,

C/0 CHASE MANHATTAN MORTGAGE

COMPANY,

vs.

216-523-1313

Plaintiff,

Case No.

et al.,

Defendants.

2011 08 4500

Deposition of

FRANK A. DEAN, JR.

November 1, 2012

2:22 p .m.

Taken at:

Thompson Hine, LLP

3900 Key Tower

Cleveland, Ohio

Donnalee Cotone, RPR, CRR

Rennillo Deposition & Discovery A Veri text Company 888-391-3376

1 APPEARANCES:

2

3

4

5

6

7

8

9

10

11

12

13

14

15·

16

17

18

19

20

21

22

23

24

25

216-523-1313

On behalf of the Plaintiff:

Thompson Hine, LLP, by

RICHARD A . FRESHWATER, ESQ.

3900 Key Tower

127 Public Square

Cleveland, Ohio 44114-1216

(216) 566-5500

[email protected]

On behalf of the Defendants:

Dann, Doberdruk & Wellen, LLC, by

GRACE M. DOBERDRUK, ESQ.

4600 Prospect Avenue

Cleveland, Ohio 44103

(216) 373-0539

[email protected]

Rennillo Deposition & Discovery A V critcxt Company 888-391-3376

1 TRANSCRIPT INDEX

2

3 APPEARANCES .. 2

4

5 INDEX OF EXHIBITS .. . .............. . .... . . . 4

6

7 EXAMINATION OF FRANK A. DEAN, JR.:

8 BY MS. DOBERDRUK ...... . ...... . ... .

9

10 REPORTER'S CERTIFICATE . . ..... .

1.1

12

13 EXHIBIT CUSTODY

14 EXHIBITS RETAINED BY COURT REPORTER

15

16

17

18

1.9

20

21

22

23

24

25

21 ll~'\21-ll11 Rennillo Deposition & Discovery

A Veritext Company

5

60

1

2

3

4

5

6

7

8

9

10

ll

12

l3

14

15

16

17

18

19

20

21

22

23

24

25

NUMBER

Exhibit A

Exhibit B

Exhibit C

Exhibit D

INDEX OF EXHIBITS

DESCRIPTION

Complaint for Forccloourc.

Pooling and Servicing ..

Agreement - cover Page

Assignment-MERS/Novastar

Mortgage, Inc., Assignor

Note for 1050 Shadybrook

Drive, Akron, Ohio, Dated

September 1, . 2005

Rennillo Deposition & Discovery A Veritext Company

MARKED

21

27

28

39

888-391-3376

1 FRANK A. DEAN, JR., of lawful age, called

2 for examination, as provided by the Ohio Rules

3 of Civil ~rocedure, being by me first duly

4 sworn, as hereinafter certified, deposed and

5 said as follows:

EXAMINATION OF FRANK A. DEAN, JR.

7 BY MS . DOBERDRUK:

8 Q. Hi. My name is Grace Doberdruk.

9 I'm representing the defendants in this

10 foreclosure case.

11 Can you state your name for the

12 record, please?

13 A. Frank Dean.

14 Q. Have you ever had your deposition

15 taken before?

16 A.

17 Q.

18 A.

19 Q.

20 A.

21 Q.

22 A.

23 Q.

24 A.

25 Q.

216-523-1313

Yes.

How many times?

Less than 12.

In what types of cases?

Residential mortgages.

All the times?

Yes .

Have you ever testified at trial?

Yes.

About how many times?

Rennillo Deposition & Discovery A Veritext Company 888-391-33 76

1 A. Several dozen.

2 Q. Have you ever testified in Ohio

3 before at a trial?

4 A. Yes.

5 Q. And do you remember what case that

6 was?

7 A. No.

8 Q. Who was the plaintiff in the case?

9 Who were you there testifying for?

10 A. So many cases, several dozen. I

11 c.: an ' L' z:· e c.: a 11 a ll o f t he m .

12 Q. Who are you currently employed by?

13 A. JPMorgan Chase Bank.

14 o . So every time you gave a

15 deposition, was it always with Chase?

16 A. No.

17 Q. Who else did you give a deposition

18 for?

19 A . As a Chase employee on behalf o .f

20 the plaintiff in each of those cases, which may

21 be a named different party.

22 o. 23 for Chase?

24 A.

25 Q.

216-523-1313

And do you go to trial and testify

Yes .

What is your educational

Rennillo Deposition & Discovery A Veritext Company 888-391-3376

1 background?

2 A. Be a little more descriptive of

3 what you're asking.

4

5

7

8

9

10

11

12

13

14

15

16

17

18

Q.

A.

Q.

A.

Q.

A.

Q.

A.

Q.

A.

Q.

A.

Q.

A.

Q.

Did you attend college?

I did.

WhPrP n id yon go t .o school?

Ohio University.

And did you get a degree?

No.

What were you majoring in?

Businees.

And what did you do after college?

Work.

And where was your first job?

Mr. Moneysworth.

And what is that?

Grocery store.

Did you have any other bank

19 positions before you worked at Chase?

20 A.

21 Q.

22 A.

23 a sampling?

24 Q.

25 A.

216-523-1313

Yes.

And where else did you work?

Do you want a complete list or just

I'll take the complete list.

Equitable Federal Savings and Loan.

Rcnnillo Deposition & Discovery A Veritext Company 888-391-3376

1

2

3

4

5

6

7

8

9

10

11

Q.

A.

Q.

A.

Q.

A.

Q.

A.

Q.

A.

Q.

12 you worked?

13 A.

14 Q.

15' positions?

16 A.

17 Q .

18 A.

19 Q.

20 A.

21 Q .

22 A.

23 Q.

24 A.

25 Q.

216-523-1313

And when did you work there?

Why?

When did you start there?

I don't recall.

How long did you stay?

I don't rt?call.

Was it within the last ten years?

No.

Oh, okay.

I'm much older than that.

All right. Where was the next 3pot

Beneficial Finance.

What did you do at these last two

Teller and a loan officer.

Where were you a loan officer at?

Beneficial.

Did you originate mortgages?

Yes.

In Ohio?

Yes.

And how long did you work there?

I don't recall.

Where did you go to next?


1

2

3

4

5

7

8

9

A .

Q.

A.

Q.

A.

Q .

A.

Q.

A.

1 o company.

11 Q.

Old Stone Bank.

As a loan officer?

That wasn't the title.

What was your title there?

~ssistant manager.

Anrl ~hen what wAs the next spot?

Equicredit. E-Q-U-I-C-R-E-D-I-T.

And were was your job duties there?

I held various positions with that

Did you do any work with

12 foreclosures?

13 MR. FRESHWATER: Objection. Can

14 you clarify what kind of work you're talking

15 about?

16 BY MS. DOBERDRUK:

17 Q. Did you review files in foreclosure

18 cases?

19 A. No.

20 Q. Did you execute assignments of

21 mortgages?

22 A. No.

23 Q. Have you ever had a position where

24 you executed assignments of mortgages?

2 5·

216-523-1313

MR. FRESHWATER: Objection.


1 Relevance.

2 THE WITNESS: No .

3 BY MS. UOB~RURUK:

4 Q. Where did you work after

5 Equicredit?

6 Meritage, M-~ - R-J-T-A-G-E,

7 Mortgage.

8 Q. And what was your position there?

9 A. Area sales manager.

10 Q. Could you describe what you did as

ll a salc::J munagcr?

12 " A. Supervised account executives in a

13 multistate territory.

14 Q. Was this for brokering mortgages?

15 A. No.

16 Q. What wa~ yuur next pu~ition?

17 A. IndyMac Bank.

18 Q. And do you remember when you

19 started working at IndyMac?

20 A. I do.

21 Q. What year was that?

22 A. 2003.

23 Q. And what was your position there?

24 A. I believe it was titled

25 vice president sales manager.

216-523-1313 Rennillo Deposition & Discovery

A Veritext Company 888-391-3376

1 Q. When you,.re a sales manaqer, what

2 are you managing in terms of sales? What is

3 the product?

4 A. Residential loans.

5 Q. Were these subprime loans?

6 MR . FRESHWATER: Objection.

7 You can answer .

8 THE WITNESS: It would be based

9 upon your de f in i t ion o f 11 s. u b p r i me . 11


11 Q. Borrowero with low credit ~coreo,

12 not documented income, high interest rates .

13 A. I have a hard time agreeing --

14 Q. What --

15 A. I have a hard time agreeing to call

16 that cld~~lrlcat i on of clients subprlme, but

17 those were some of the qualifications that went

18 into those residential loans, yes .

19 Q.

20 A .

21 Q .

22 A.

23 Q.

21 A.

25 Q.

216-523-1313

How long did you work at IndyMac?

Two years.

And then where did you go to?

Aurora Loan Services .

And what was your title there?

Saleo manager.

How l ong did you work for Aurora?


1

2

3

4

5

7

8

9

10

11

12

13

14

15

16

17

A.

Q.

A.

Q.

A.

0 -

A.

Q.

A.

Q.

1\..

Q.

Hill?

A.

Q.

Two years.

·so around 2005 to 2007?

Yes.

And what was your next position?

Relationship manager .

At. A11rora?

No.

Where was that at?

Silver Hill Financial.

Is this more of a sales position?

Yes.

And how long were you at Silver

Eight months.

Can I ask how you went from one

posllion to another to anoLheL-? Dld you just

apply for new jobs that opened up? Did you

18 know somebody at these companies?

19 MR. FRESHWATER: Objection. Are

20 you referring to a particular transition from

21 one company to another?


23 Q. I'm talking about in general, when

24 you chose to leave one company, why did you

25 choose to leave that company.


A Veritext Company 888-391-33 76

1 So we 1 ll say: When you chose to

2 leave IndyMac, why did you choose to go from

3 IndyMac to Aurora?

4 A. Personal reasons.

5 Q. Did you submit job applications for

6 all these pos1tion~? .

7 A. Submit meaning initiate?

8 Q. Apply for the job through a written

9 application.

10 A. Absolutely.

11 Q. Where did you work after Silver

12 Hill?

13 A. Accredited Home Lenders.

14 Q. How long did you work for

15 Accredited?

1.6 A. Twu monlhs.

17 Q. In 2008?

18 A . Yes.

19 Q. And what did you do at Accredited?

20 A . Account executive.

21 Q. What did you do on a typical day as

22 account executive?

23 A. Visited mortgage brokers, reviewed

24 loan applications.

25 Q.

216-523-1313

Why did you leave Accredited?


1 A. They closed.

2 Q. And where did you go next?

3 A. Chase Bank.

4 Q. So you were hired by Chase in 2008;

5 is that right?

6 A. Yes.

7 Q. And what was your first position at

8 Chase?

A. Bank branch loan officer . 9

10 Q. What was your next position there?

J.l A. I did not hold another position

12 there at that time. ·

13 Q. So are you currently a bank branch

14 loan officer at Chase?

15 A. No.

16 Q. What 1 s your current title?

17 A. Horne loan research officer .

18 Q. And how long have you had that

19 title?

20 A. Since April 2011.

21 Q. What is your address for your

22 office location?

23 A. 350 South Cleveland Avenue,

24 Westerville, Ohio.

25 Q. Have you been at that office the

? 16-5??.-1113 Rennillo Deposition & Discovery

A Veritext r.omp:my 888-391-3376

1 entire time you've worked for Chase?

2 A. That is my assigned office, yes.

3 Q . What knowledge do you have about

4 note?

5 MR. FRESHWATER: Objection. It's

6 k ind of vague . Can you be mo r e spec i fic?


8 Q . When was the first time you looked

9 at Glenn Holden's note?

10 A . Within the last two business weeks

11 com e tim e . I don't remember the exact date.

12 Q. Did you look at his note because

13 you were preparing for deposition?

14 A . Yes.

15 Q . Were you familiar with the Holdens'

16 lutin fill':! tiL till f? L luL Lu preparing for t his

17 deposition?

18 A . No.

19 0 . Did you talk to anybody at

20 about note?

21 A. No .

22 Q . Did you talk to anybody at

23 Deutsche Bank about his note?

24 A.

25 Q.

216-523-1313

No.

Did you talk to anybody at

Rcnnillo Deposition & Discovery A V eritext Company

NovaS tar

888-391-33 76

1 Financial Asset Securities Corporation about

3 A . No.

4 Q. Did you talk to anybody at Wells

6 MR. FRES HWATER: Objection.

7 You can answer if you can.

8 THE WITNESS: No.

9 BY MS. DOBERDRUK:

10 Q. Did you talk to anybody at MERS

11 about note?

12 A. No.

13 Q. Have you ever talked to anybody at

14 DP.lJt:sc:he Bank r.~bout and

15 thei r loan documents?

16 A. No.

17 Q. Have you ever talked to anybody at

18 the Soundview Home Loan Trust about -and

20

21

A.

Q.

No.

How did you find out that you were

22 go ing to appear here for deposition?

23

24

A.

Q.

By e-mail.

And do you know how the decision

25 was made to choose you personally to come here?

216-523-1313 Renni1lo Deposition & Discovery

A Veritext Company 888 391-3376

1 A. I have a vague understanding of how

2 our process works, yes.

3 Q. can you explain to me how the

4 - process works?

5 A. A request is made by counsel and

6 submitted to a ma]lbox. The mailbox manager

7 reviews the requests, then reviews the calendar

8 to see which person on the staff is not

9 assigned, and then assigns them.

10 Q. Does the request from counsel go to

11 Lender Pro~essing Services?

12 MR. FRESHWATER: Objection.

13 You can answer.

14 THE WITNESS: I don•t know.


16 Q. Have you ever communicated with

17 anybody at Lender Processing Services?

18 MR. FRESHWATER: Objection . You•re

19 asking about in general for


21 Q. In general.

22 A . No .

23 Q. As part of your job duties, do you

24 use any computer systems with Chase?

25 A.

. 216-523-1313

Yes.


Page l8

1 Q . And what is your software system

2 for mortgage loan records?

3 A . There are many, and probably ones

4 I'm not even -- I don't even access. But the

5 ones I access regularly are -- I refer to as

6 M.SP .

7 Q. Are you aware that MSP is a

8 software program made by Lender Processing

9 Services?

10 MR. FRESHWATER: Objection .

11 THE WITNESS: No.


13 Q. Have you ever communicated with

14 anyone at LPS Default Solutions?

15 A. Not that I'm aware of.

16 Q. What about Fide1lly?

17 A.. No.

18 Q. Have you ever used a program called

19 LPS Desktop?

20 A. Yes.

21 Q. And what do you use that for?

22 A. Looking up contact information .

23 Q. Did the request from counsel come

24 through LPS Desktop?

25 A.

216-523-1313

Not that I'm aware of.


1 Q. Do you see documents on the

2 LPS Desktop screens, notes and mortgage

3 document: s ·:'

4 MR. FRESHWATER: Grace, I'm going

5 to object. Are you talking in general? And if

6 you ar e . I would object to relevanc~. I f

7 you're talking about a specific case, that's

S okay.

9 BY MS. DOBERDRUK:

10 Q. Have you viewed note

11 on any computer screen?

12 A. Yes.

13 Q. In LPS Desktop?

14 A. No.

15 Q. What computer screen did you look

16 at?

17 A. My laptop's.

18 Q. Can you tell me how you looked at

19 his note, what you had to do to access to be

20 able to view his note?

21 A. Yeah. Internally, JPMorgan has a

22 site referred to as Financial Services Desktop.

23 And then once I open that link, I then open

24 a n othar program referred to as iVault, . the

25 letter I, V-A-U-L-T. And then I search for the


A Vcritext Company 888-391-3376

r'age 20

1 borrower's loan number, and it brings up all

2 imaged documents from that file.

Q. so it has the note, the mortgage?

4 A. Yep. Yes.

5 Q. Does it have assignments of

6 mortgage?

7 A. Yes.

8 Q. Does it have other closing

9 documents?

10 A. In most instances, yes.

11 Q. Do you know if Chu~e referred the

12 case to foreclosure?

13 A. I believe they did.

14 Q. And do you know if that referral

15 went through LPS Desktop?

16 MR. · FRESHWATER: Objection.

17 THE WITNESS: I don't.


19 Q. What does Chase do to refer a case

20 to foreclosure? What's the process that they

21 use?

22 MR. FRESHWATER: Grace, I'm going

23 to object because I don't believe this is one

24 of the topics identified in your notice of

25 deposition.

216-523-l313 Rennillo Deposition & Discovery

A V critext Company 888-391-3376

1 BY MS. DOBERDRUK:

2 Q. Does Chase provide documents to

3 counsel in order to file the foreclosure

4 complaint?

5 A. Yes.

6 MS. DOBERDRUK: Can we mark the

7 complaint as Exhibit A?

8

9 (Thereupon, Deposition Exhibit A,

10 Complaint for Foreclosure, was

~1 marked for purposes of

12 identification.)

1 3

14 o. So you've been handed the compla int

15 that was filed against

16 Can you tell me who filed this

17 complaint?

18 MR. FRESHWATER: Objection. Are

19 you talking about who physically filed it?

20 MS. DOBERDRUK: No.


22

23

24

Q.

A.

Q.

Who's the plaintiff --

Oh.

-- in the case?

25 THE WITNESS: Well tha t ' s -- thank


A Veritext Company 88&-39l -3376

1 you for clarify ing. That's where it went, was

2 to the attorney.

3 Deutsche Bank National company As

4 Trustee For Soundview Home Loan Trust 2005-4,

5 Asset-Backed Certificates, Series 2005-4 .

6 Then C/0 Chase Manhattan Mortgage

7 Corporation, 3415 Vision Drive, Columbus,

8 Ohio 43219.

9 BY MS. DOBERDRUK:

10 Q. Hav e you ever worked for Chase

ll Manhattan Mortgage?

12 A. No.

13 Q. Do you know when Chase Manhattan

14 Mortgage went out of business?


16 You can answer .

17 THE WITNESS: I don't believe they

18 went out of business. I believe they were

19 merged inr~ ~h~~~ Home Fjnan~~ -


21 Q . Do you know when that happened?

22 A. I am guessing, for the better part,

23 but I believe it was 2004. But I could be

24 wrong.

25 Q. Can you turn to Exhibit A, to the

216-523-1313 Rcnnillo Deposition & Discovery

A Vcritext Company 888-391-33 76

1 complaint?

2 A. Yes, ma'am.

3 Q. Do you see a little bit down where

4 it says -- it's cert i fied as a true copy?

5 A. Uh-huh.

6 Q . I s t ha t certified -- is there a

7 signature there by somebody who's certifying

8 that this is a true copy?

9 A. There is a scribbling of a

10 signature, yes.

11 Q. And can you turn to -- it's going.

12 to be the third page of the note with writing

13 on it. Do you see signature?

14 A. Yes.

15 Q. Do you see any other marks on this

16 page, any accempt to endorse the note? or is

17 it just a blank space under the signature?

18 A. There are just empty lines.

19 Q. When I asked you if Chase gives the

20 documents to counsel to file the foreclosure,

21 do you believe that Chase gave this note to

22 counsel --


24 BY MS. DOBERDRUK;

25 Q.

216-523-U t3

when this case was filed?


]:}age 24

1 MR. FRESHWATER: You can answer if

2 you know.

3 THE WITNESS: I don•t know tor

4 certain that Chase gave this to counsel.

5 BY MS. DOBERDRUK:

6 Q. If the general process is for Chase

7 to turn over documents, do you have any reason

8 to believe that this note was given to counsel

9 by Chase?

10 A. I do not.

11 Q. And is there any way that counsel

12 could obtain a note other than getting it from

13 the lender? r•ll rephrase it as this way._

14 You know that mortgages are

15 recorded.

16 A. Yes.

17 Q. The note is not recorded anywhere,

18 it•s not made a public record; is that true?

19 A. That•s my understanding, yes .

20 Q. And do you understand what it means

21 to securitize a note and mortgage?


23 You may answer if you know .

24 THE WITNESS; I would say that I

25 have a mortgage industry general knowledge of

216-523-1313 Rcnnillo Deposition & Discovery


1 what a securitization is. But if you ask me to

2 define it, I'm not going to be able to.

3 BY MS. DOB~RDRUK:

4 Q. When you were working at some of

5 your prior positions and you were selling

~ mnr~gages, were you selling thnRP ~o trusts ,

7 that you know of?

8 A. Yeah. In my capacity either as

9 account executive, bank branch loan officer,

10 sales manager, I was only the front end of

11 mortguge origination. I don't know how the

12 back end after closing transpired.

13 Q. Have you ever seen the pooling and

14 servicing agreement for the trust that filed

15 this foreclosure?

16 A. I have.

17 Q. When did you view it?

18 A. This week.

19 Q. In preparation for the deposition?

20 A . Yes.

21 MS. DOBERDRUK: Can we discuss the

22 pooling and servicing agreement now?

23 MR. FRESHWATER: Absolutely.

24 DY MS. DOBERDRUK :

25 Q . I'm going to show you the title



1 page for this trust .

2 MS. DOBERDRUK: And we've

3 stipulated this is the accurate pooling and

4 servicing agreement for the trust?

5 MR. FRESHWATER: Let me just make

6 surs that I didn't print out ths wrong copy for

7 me of that.

8 Yes. It appears to be such.

9 BY MS. DOBERDRUK:

10 Q. Okay. Can you look at the title

11 page and tell me who the depositor of the trust

12 is?

13 A. Financial Asset Securities Corp.

14 Q. And have you seen that name on any

15 documents that you've reviewed for the

16 deposicion in regards co

17 note and mortgage?

18 A. Beyond this document/ I'm going to

1g say no.

20 Q. And you've never spoken to anybody

21 there?

22 A. Correct.

23 MR. FRESHWATER: This is the first

24 part, and this is just the continuation. So

25 this is the first



1 MS. DOBERDRUK : Okay .

2 MR. FRESHWATER: Grace, this is the

3 first half, I think, which will have most of

4 the pages you want to ask questions about it.

5 MS. DOBERDRUK : Oh, and you put

6 your tab on it .

7 BY MS. DOBERDRUK:

8 Q. Let me show you -- in the

9 definition section of t he trust on page 32,

10 could you identify the closing date of the

J.l trust?

12 A. Closing date, December 21st, 2005.

13 MS. DOBERDRUK: Let me just mark

14 this . So the pooling and servicing agreement

15 is going to be Exhibit B, and this will be

16 Exhibit C .

17 (Discussion held off the record . )

18

J.9

20

21

22

23

24

25

21 {)M521M 1113

(Thereupon, Depooition Exhibit B,

Pooling and Servicing Agreement -

Cover Page, was marked for purposes

of identification.)

(Thereupon, Deposition Exhibit C,

Rennillo Deposition & Discovery A V e.r\text l.ompany

1 Assignment-MERS/Novastar Mortgage,

2 Inc . , Assignor , was mark e d for

3 purposes of identification.)

4

5 BY MS. DOBERDRUK :

6 Q. All r i ght. I'm now handing you

7 what's been marked as Exhibit C, which is the

8 assignment of mortgage that was attached to the

9 foreclosure complaint in this case.

10 Can you tell me when this mortgage

11 was signed?

12 A. September 17th, 2 0 1 0 .

13 Q. And do you see who signed this

14 mortgage?

15 A. Yes.

16 MR. FRESHWATER: I'm sorry.

17 Objection. You're referring to the mortgage

18 assignment

19 MS. DOBERDRUK: The assignment of

20 mortgage, yes.


22 Q.

23 A .

24 Q.

25 A.

216-523-1313

Wanda Chapman?

Yes.

Do you know who that is?

No.


1 Q . Do you know if Wanda Chapman works

2 for Chase?

3 A. No.

4 Q. Do you have a position at Chase

5 called operations management lead?

6 MR. FRESHWATER: I'll object that

7 that wasn't on the topics for deposition.

8 But you can answer if you know.

9 THE WITNESS: Operations management

10 lead, is that what you asked?


12 Q. Yeah. Operations -- do you have an

13 operations department at Chase?

14 A. Yes.

15 Q . What does the operations department

16 do?

17 A. There are operation departments in

18 all facets of Chase, whether it be mortgage

19 banking, investments, securities. So

20 Q. Do you have an operations

21 department at Chase that executes assignments

22 of mortgages?

23

24

25

216-523-1313


But you can answer.

THE WITNESS: I don't know.

Rennillo Deposition & Discovery A Veritext Comp~my 888-391-3376

1 BY MS. DOBERDRUK:

2 Q . I'm going to show you Section 2.01

3 of the pooling and servicing agreement.

4 MR. FRESHWATER: And, Grace, you're

5 referring to Article II

6 MS. DOBERDRUK: Yes.

7 MR. FRESHWATER: which we have

8 identified as page 79 of 1356.

9 BY MS. DOBERDRUK:

10 Q. And if you can just tell me, what's

11 the title for Article II?

12 A. "Conveyance of mortgage loans,

13 original issuance of certificates."

14 Q. Could you read the first paragraph

15 in Section 2.01?

16 A. "The de.E:Jositor concurrently with

17 the execution and delivery hereof does hereby

18 transfer, assign, set over and otherwise convey

l9 in trust to the trustee without recourse for

20 the benefit of the certificate holders, all of

21 the right, title and interest of the depositor,

22 including any security interest therein for

23 the 11

24 MS. DOBERDRUK : We can stop there

25 unless Richard has an objection.



1 MR. FRESHWATER: No, no. That's

2 fine.

3 BY MS. DOBERDRUK:

4 Q. Okay. I want to show you the title

5 page again. Could you tell me who the

6 depositor of the trust is?

7 A. Financial Asset Securities Corp.

8 Q. And I'll have you look at your copy

9 of the complaint, Exhibit A to the complaint.

10 A. Uh-huh.

11 Q. Do you see -- I'll let you get it

12 over because we're going to go to Exhibit A.

13 A . You want me in the note or the

J 4 mo:t"tgage?

15 Q. At the note.

16 A. Okay . I'm there.

17 Q. Do you see any endorsement from

18 Financial Asset Securities Corporation?

19 A. Nu.

20 Q. Do you see any endorsement to


2 2 A .

23 Q.

24 more minute.

25

216-523-1313

Nn _

All right. Let me see that for one

Thank you.

All right. Could you read to me


1 Section I?

2 A. So we're back to Exhibit B, page 79

3 of 1356, Subparagraph I .

4 "The original mortgage note

5 endorsed either, A, in blank or, B, in the

6 following form, pay to the order of

7 Deutsche Bank National Trust Company as trustee

8 without recourse, or with res~ect to any lost

9 mortgage note" do you want me to continue?

10 Q. No, you don't have to.

11 !'... Okay.

12 MR. FRESHWATER: Grace, if I may,

13 it may be helpful -- this is your deposition,

14 but -- to go over the previous paragraph in

15 terms of why we're talking about the original

16 mortgage nole. You:r.- deposit ion.


Q. What I asked you about was how the

19 pooling and servicing agreement says that the

20 original note should be endorsed; is that

21 correct?

22 A. May I see that one more time?

23 Q . Yes.

24 A. Yes. You asked me to read the

25 paragraph about the endorsement of the original


A V eritext Company 888-391-3376

1 mortgage note.

2 Q . And that section tells how the note

3 should be endorsed to be conveyed to the trust .

4 MR. FRESHWATER: Is that a

5 question, Grace? Objection. Is that a

6 question?

7 BY MS. DOBERDRUK:

8 Q. I'm aski11g: .From your

9 understanding, from what you're reading there,

10 does it look like Section 2.01, which is titled

11 Conveyance of a Mortgage, that they're

12 describing how the note should be endorsed

13 A. Yes.

14 Q. -- the method?

15· And we looked at the complaint, and

16 you did not see any endorsement, did you, to

17 the note in the complaint?

18 A. Correct.

19 Q. And I asked you to look at the

20 fi-rst sentence in Section 2.01. Who did it say

21 sells the note to the trust?

22 A. Well, since I • m not well versed in

23 PSAs, I think I'm going to read the sentence --

24 Q . Okay.

25 A . rather than attempt to answer by


A Vcritcxt Company 888-391-33 76

1 my own definition.

2 "The depositor concurrently with

3 the execution and delivery hereof does hereby

4 transfer, assign, set over and otherwise convey

5 in trust to the trustee without recourse for

6 the benefit of the certificate holders, all the

7 right, title and interest of the depositor,

8 including any security interest therein for the

9 benefit of the depositor."

10 MS. DOBERDRUK: Okay. Did you say

~~ you had the collateral file here today?

12 MR. FRESHWATER: I do.

13 MS. DOBERDRUK: Do ' you want me to

14 show him this or the copy?

15 MR. FRESHWATER: If you're willing

~6 tu stipulate that the copies are accurate,

17 let 's just show him the copies.

18 same ones we used in the

19 MS. DOBERDRUK: Okay.

They're the

depositions.

If you don't

20 mind, I do want to show him something on that.


22 Q. I'm going to show you what's been

23 produced as the original -- as the note in the

24 collateral file.

25 Can you tell me if that note has an


A Veri text Company 888-391-3376

1 endor~ement on it?

2 A. Yes.

3 Q. Okay. And who was the signer of

4 that endorsement?

5 A. Steve Haslam, H-A-S-L-A-M, Sr.,

6 vi~P. Dresident.

7 Q. And does it look like that's signed

8 by him in pen, or does it look . like it's been

9 stamped on there?

10 A. I cannot tell.

11 Q. Is it f~ir to cay that it doesn't

12 look like an original signature by Steve

13 Haslam?

14 And I'll jus t point to this mark

15 here. Would you say it looks more like it's a

16 copy as opposed to pen, if you comp~re thaL Lo

17 what looks like fresh ink?

18 MR. FRESHWATER: On

19 signature?

20 THE WITNESS: State your question

21 one more time. I want to make sure I answer it

22 accurately.

23 BY MS, DOBERDRUK:

24 Q. I want to know if this -- Steve

25 Haslam's signature looks like i t was a stamp as



1 opposed to signed by him in person in pen.

2 A. I'm going to indicate that I cannot

3 make that distinction.

4 Q. Would you admit it's possible that

5 it was a stamp as opposed to an original

6 signature?

7 A. Yes.

8 Q. And would you agree that that

9 endorsement on this note in the collateral file

10 does not appear on the note attached to the

11 complaint?

12 A. Yes.

13 Q . Do you have any explanation for why

14 the complaint would be filed with a note that

15 didn't contain.this endorsement?

16 MR. FRESHWATER: Objection. Calls

17 for speculation.

18 You can answer if you know.

19 THE WITNESS: Yes.


21 Q. Did you bring this document -- this

22 file with you when you came today?

23 A. No.

24 Q. Do you know -- have you ever viewed

25 this manila file before coming here today?


A Veritex.t Company 888-391-3376

J:Jage 37

1 A. No.

2 Q. If you've never viewed this file

3 here before, how do you know that the piece of

4 paper you're holding in your hand is the

5 official note?

6 A. For a couple reasons. First, it

7 contains the borrower,

8 original signature.

9 Secondly, the manila file indicates

10 that it was sent to our attorney from our

~~ Monroe, Louisiana custodial facility.

12 Q. When you say it was sent from the

13 Monroe, Louisiana custodial facility, whose

14. facility are you talkins about?

15 A. JPMorgan Chase.

l6 Q. All right. Have you ever heard in

17 securitized mortgages that when the notes are

18 sold to the trust, that there's a custodian for

19 the t . ru!=:t. ?

20 A. Yes, I've heard that.

21 Q. And the custodian maintains records

22 for the trust?

23 A. I'll assume that that's correct.

24 I, again, don't know much detail about

25 Q. Is Chase the custodian of records



1 for the Soundview Home Loan Trust 2005-4?


3 THE WITN.c;SS: Yeah, I don't know.

4 BY MS. DOBERDRUK:

5 Q. If we go back to Exhibit B, the

6 pooling and servicing agreement, I'm going to

7 show you the definition section of the pooling

8 and servicing agreement. Could you identify

9 who the 'custodian of . the trust is?

10 A. Wells Fargo Bank, NA.

11 Q. So if Wells Fargo Bank, NA, is the

12 custodian of the trust., isn't it fair to say

13 that Wells Fargo would have a copy of

14 original note if this note was

15 part of the trust?

16 A. I don't know.

17 Q. And I asked you previously if you

18 had ever spoken to anybody at Wells Fargo about

19 note. And have you ever talked

20 to anybody at Wells Fargo?

21 A. No.

22 Q. So in preparing for the deposition,

23 was your review of the records a review of

24 Chase's records?

A.

216-523-1313

Oh, I'm sorry. Was that a


1 question?

2 Q. Yes.

3 A. I apologize.

4 Q. That's all right.

5 Did you review any records other

6 than Chase's records?

7 A. No.

8 Q. If there

9 MS. DOBERDRUK: I can give him a

10 copy of the note now. We'll mark this

11 Exhibit D.

12

13 (Thereupon, Deposition Exhibit D,

14 Note for 1050 Shadybrook Drive,

15 Akron, Ohio, Dated September 1,

16 2005, was marked for purposes of

17 identification.)

18

19 (Discussion held off the record . )

20 MS. DOBERDRUK: Would you mind if I

21 asked him about this?

22 MR. FRESHWATER: No, go ahead. The

23 assignment of mortgage, I think you have as

24 Exhibit C.

25

216-523-1313

MS . DOBERDRUK: All right.

Rcnnillo Deposition & Discovery A Veritext Company

This is

888-391-3376

1 a copy though; this isn't the original, right?

2 MR. FRESHWATER: That's the

3 original, 1 believe.

4 MS. DOBERDRUK: Well, I'll let you

5 look and see if you think it is.

MR .. F'RF.SHWA'T'F.R ~ Yeah .

7 sticker from the fiscal officer, which would

8 indicate

9 BY MS. DOBERDRUK:

10 Q. All right. I'm going to show you

11 this Qooignment of mortgQgc that came out of

12 the collateral file, which is supposed to be

13 the original assignment of mortgage.

14 Could you look on the second page?

15 Does it look like Wanda Chapman's signature was

16 signed in ink? And I'm talking to her actual

17 signature.

18 A. .Yes.

19 Q. Would you agree that the printed

20 Wanda Chapman looks like it was written in pen?

21 A . Yes.

22 Q. And would you look at the bottom

23 where Manley Deas' address is crossed out?

24 A.

25 Q.

. 216-523-1313

Ye:s.

Does that also look like it was

Rennillo Deposition & Discovery A Veritext Company 888-391 -33 76

1 written in the same pen?

2 A. Your question wasn't very clear.

3 Q. The same type of black ink .

4 A. Yes. They appear to be both black

5 ink.

6 Q_ Can you think of any reason why

7 Wanda Chapman would cross out Manley Deas•

8 address if


10 There's no evidence that Wanda Chapman is the

11 one who crossed it out.

12 MS. DOBERDRUK: I agree that .I

13 don't believe Wanda Chapman crossed it out.

14 BY MS .. DOBERDRUK:

15 Q. Would you agree that the black ink

16 in the printed Wanda Chapman appears different

17 than the Wanda Chapman signature which does not

18 appear to be in black ink to me?

19 A. I think we're splitting hairs.

20 They both are black, but one appears to be a

21 different type of black pen or black ink.

22 Q . Or possibly a stamp?

23 MR. FRESHWATER: Objection .


25 Q. Is it possible it could be a stamp?



1 A. On this document, no. It appears

2 as though an authentic signature was made .

3 Q. But you will -- let's see.

4 You can clearly see that the

5 Wanda Chapman that's printed out is made in a

diffP~ent marking the Wanda Chapman that is

7 printed out is in black pen - -

8 A.

9 Q.

10 .

Yes.

-- undoubtedly.


11 urc you going to ask a question?

12 MS. DOBERDRUK: Okay.


Grace,

14 Q. Does the Wanda Chapman's signature

15 appear a different color than the Wanda Chapman

16 pen?

17 MR. FRESHWATER: Objection. Asked

18 and answered.

19 You ~~n ~nRwP.r again.

20 MS. DOBERDRUK: I asked about

21 color .


23 Q. Is it a different shade of color?

24 A. So your question is pertaining to

25 this signature and that printed, correct?



1 Q. Yes.

2 A. They both are black. Different

3 texture possibly, yes. Ditterent tipped pen.

4 Q. Definitely.

5 MR. FRESHWATER: Objection. Is

6 that a question, Grace.


8 Q. Sorry.

9 You can agree that those definitely

10 look like they were written in different pen.

11 I mean, just from a viewing of the eye --

12 MR. FRESHWATER : Objection.

13 BY MS. DOBERDRUK :

14 Q. -- will y o u admit that they

15 definitely look like they were written in a

16 different pen?

17 MR. FRESHWATER: Objection . Grace,

1 8 will you ask --

19 MS. DOBERDRUK : Okay.

20 MR . FRESHWATER: Will you ask a

21 question as opposed to testifying?


23 Q. Do the Wanda Chapman signature and

24 the Wanda Chapman printed name appear to be

25 written in a different pen color and texture?




2 Compound.

3 But go ahead and answer.

4 THE WITNESS: A different type of

5 pen -- as an example, felt tip versus

6 b~11po:int yes . Rut they are both the same

7 color.

8 BY MS. DOBERDRUK:

9 Q. The date ~hat this assignment of

10 mortgage was made, would you agree that the

11 September 17th and the Wanda Chapman print are

12 in the same style and color pen?

13 MR. FRESHWATER: Objection to the

14 extent he•s not an expert on pens.

15 But answer if you know.

16 THE WITNESS: I'm going to a~k you

17 to repeat the question. I think I lost track,

18 listening to you two .

19 You asked me about this date.


21 Q. r•m only looking here.

22 A. Oh.

23 MR. FRESHWATER: Let the record

21 reflect she•s pointing to the top of the

25 assignment.



1 THE WITNESS: Okay . Tell me

2 your -- ask me your question, please.


4 Q. That the September 17th date at the

5 top of the assignment and the Wanda Chapman

6 printed name appear in a different color than

7 the Wanda Chapman signature .

8 MR. FRESHWATER: Objection. Can

9 you ask a question, Grace?


11 Q. Do the September 17th d~tc at the

12 top of the assignment of mortgage and the

13 Wanda Chapman printed name appear to have been

14 made in the same color and texture pen?

15 A. Yes, they appear to be the same.

16 Q. Thank you .

17 MR. FRESHWATER: Are we

18 MS . DOBERDRUK: Yes, I'm done with

19 that _ Thanks .


21 Q . I'm going to hand you a copy of the

22 o riginal note fr o m the c o llateral file, which

23 has been marked as Exhibit D.

24 Can you turn to the page with the

25 endo rsement?



1 A. Yes.

2 Q. All right. Do you see an

J endorsement to Financial Asset securities

4 Corporation?

5 A. No.

6 Q. Do you see an endorsement from


8

9

10

11

12

13

A.

Q.

A.

Q.

A.

Q.

No.

Do you know who Mary Collins is?

State that name again.

Ma.ry Collin::;.

No.

Do you know another Mary at Chase

14 that has a name that sounds like Collins?

15 A. No.

16 Q. Do you know someone aL Chase named

17 Mary?





·2 2 Q.

23 A.

24 Q.

25

216-523-1313

What is her job title?

Teller.

She'::; a teller.

Do you know anybody named Teri,

Rennillo Deposition & Discovery A Veritext Company 888-3 91-3376

1 female?

2 A. Yes.

3 Q. And what is her job position?

4 A. Bank branch loan officer.

5 Q. Does she review documents for

6 modificQtions?

7 A. No.

8 Q. Does she originate loans?

9 A. At last conversation with her,

10 which would probably have been over six months

11 ct9u, yes.

12 Q. What is Teri's last name?

13 A. I can't remember.

14 0. Do you know if her name is spelled

15 with an I or with an Y?

16 A. Yeah. I believe it was T-E-R-1.

17 Or two Rs and an I, I can't remember which.

18 Q. Do you know how long she's worked

19 at Chase?

20 A. No.

21 Q. At least for the last two years?

22 A. I don't know. She may not even

23 still be with us.

24 Q.

25 location?

216-5/.J-1313

How many people work at your office


1 A. I don't know.

2 Q. Okay. More than 50?

3 A. Yes.

4 Q. Do you say at the Chase location

5 that you work at, do people sign assignments to

6 mo~tgngcs in the office?

7 A. I do not know.

8 Q. What do you do on a daily basis for

9 Chase?

10 MR. FRESHWATER: Objection. Vague.


12 Q. As part of your job, what's the

13 typical day like?

14 A . F.v~ry day is different. There is

15 no typicality to my job. I could either be at

16 home prepping for an appearance, I could be in

17 a deposition, I could be in a plane headed to

18 an assignment all day.

19 Q. Wheu yuu ~dY "assignmeul," ls that

20 court-related?

21 A. Not necessarily, unless you

22 consid~r this court-related.

2 3 Q. Yeah.

24 A. Okay. So, to me, that means being

25 in a courtroom.

216-523-1313

But, no, not all my

Rennillo Deposition & Discovery A Vcritcxt Company 888 391-3376

1 assignments are in a courtroom.

2 Q. Does the vast majority of your job

3 involve testifying at depositions or trial?

4 A.

5 Q.

6 deposition?

7 A.

8 Q.

I wouldn't say vast.

How often a week do you do a

Normally, not weekly.

And do you know how many

9 depositions you've done for Chase?

10 A. I think I answered previously less

11 than a dozen. I'm not sure.

12 Q. Do you remember when the first one

13 you did was, what yeari

14 A . YP.!='. .

15 Q. Can you tell me what year it was?

16 A. Yes.

17 Q. What year was the first time you

18 took a deposition with Chase?

19 A. 2011.

20 Q. Do you take depositions about only

21 foreclosure cases, or do you

22 MR. FRESHWATER: Objection . I

23 don't believe he said he takes depositions.

24 BY MS . DOBERDRUK :

25 Q.

216-523-1313

Do you attend depositions in


1 foreclosure and bankruptcy cases, or only

2 foreclosure?

3 A. I can't say that I paid enough

4 attention to make that distinction.

5 Q. Okay. When you're not

6 participa.ting in a deposition, do you do other

7 work that's related to foreclosures?

8 A. I'm sorry.


10 THE WITNESS: Will you reask that

11 question?


13 Q. As part of your job, are you

14 involven in, wF;'l1 say, filing .::l rnmpl;=l:int.

15 against somebody or reviewing documents? Have

16 you ever signed an affidavit for a summary

17 judgment motion?

18 MR. FRESHWATER: Objection. That

19 was three que~Lions.

20 THE WITNESS: I have not signed an

21 affidavit for a summary judgment motion.

22 BY MS . DCYRF.RDRUK:

23 Q. Have you referred a case to

24 foreclosure yourself?

25 A.

216 523-1313

No.

Rennillo Deposition & Discovery A V critcxt Company 888-391-3376

1 Q. Can I ask what you.do as part of

2 your job that doesn 1 t involve testifying in

3 court or attending depositions?

4 A. I think the answer to that is yes,

5 because your question was, Can I ask?

6 Q. What else do you do that doesn't

7 involve depositions and testifying in trial?

8 A. Mediations.

9 Q. You attend mediations as a

10 corporate representative of Chase?

11 A. Yes.

12 Q. In Ohio?

13 A. Yes.

14 Q. Do you have to review any documents

15 for when you att e nd mediations?

16 A. Yes.

17 Q. Do you review pooling and servicing

18 agreements? Sometimes . do you review pooling

19 and servicing agreements?

20 MR. FRESHWATER: For mediation,

21 Grace, or in general?


23 Q. For mediation . That 1 S all right .

24 I 1 ll just move on t o -- 1 1 m go1ng to ask you

25 one more question about the note, and then


A Vcritcx.t Company 888-391-33 76

2

1 we'll wrap it up.

2 Do you have any way of knowing

3 when, if ever, this endorsement was placed on

4 the note?

5 A. Yes.

6 Q. Okay. And how would yo~ know when?

7 A. Based on my review of the poo ling

8 and servicing agreement as well as Chase

9 records.

10 Q. When you say and Chase records,

11 what records do you mean?

12 A. System notes as well as collateral

13 file.

14 Q . So when you say 11 sys tern notes, rr

15 what do these system notes say?

l6 A . There is a note in there that

17 confirms the time of our acquisition of the

18 collateral file.

19 Q. Would you agree that acquisition o f

20 the collateral file does not -- the time that

21 you see on your computer, when you acquire the

22 file, does not indicate what the file looks

23 like. Is that fair to say?

24 If you look at a computer screen

25 that says a time period that you obtained



Page :,3

1 something, it doesn't show what was obtained;

2 it only gives you the day and time.

MR. FRESHWATER: Objection. Is

4 there a question?

5 MS. DOBERDRUK: I asked if he would

t=; <3gree that, by looking at a date and time, it

7 only shows when you received ·something, not

8 what exactly was received.

9 THE WITNESS: But an appropriate

10 home loan research officer such as myself would

11 go to the iVault to confirm that those

12 documents were imaged near or at the time of

13 the acquisition date note entry, which I did.


15 Q. If this case was referred to

16 foreclosure by Chase, Lht:!u why dot:~ the note

17 attached to the complaint not contain an

18 endorsement?

19 MR. FRESHWATER: Objection. Calls

20 for speculation.

21 But you can answer if you know.

22 THE WITNESS: It's my opinion

23 that -- well, let me ask . Have you ever

24 attended a loan closing, oo I can try and put

25 this into context? A real estate loan closing .



1 BY MS. DOBERDRUK;

2

3

Q.

A.

Yes.

Okay. They're -- at the time the

4 closing agent is done settling the documents,

5 they're required to submit packages to several

6 various locations. Within those packages are

7 copies of the note and the mortgage to be

8 recorded, along with -- one of those packages

9 contains the original note.

10 It's my opinion that we were in

ll receipt not only of the original note, but a

12 certified true copy of the note. And whoever

13 provided the -- whoever went into the image

14 vault and extracted a copy of the mortgage for

15 foreclosure counsel extracted the unendorsed

16 copy rather than the endorsed copy.

17 Q. When you reviewed records for

18 coming here to today, did you happen to notice

19 a motion for relief from stay that Chase had

20 filed in the bankruptcy case?

21 MR. FRESHWATER: Objection. The

22 bankruptcy wasn't a topic of discussion for

23 deposition.

24

25

216-523-1313

But you can answer if you know.

THE WITNESS: I did not notice a


1 mot ion for relief of stay.

2 BY MS. DOBERDRUK:

3 Q. In your records, did you happen to

4 see any indication that Chase had moved for

5 relief from stay, or that Deutsche Bank had

6 moved for relief from stay in the

7 bankruptcy?

8 MR. FRESHWATER: Again, the same

9 objection.


11 Q. Does Chase keep their bankruptcy

12 and foreclosure records in the same loan file?

13 A. No. The same system, yes.

14 Q. Same system.

15 Are all the records for one

16 person's loan kept in some file that could be

17 accessed?

18 A. Yes.

19 Q . The note that has been produced

20 today as the original came from what custodian

21 of records?

22 A.

23 Q.

24 t.;d~e?

25 A.

216-523-1313

JPMorgan Chase Bank.

And who is the plaintiff in this

Deutsche Bank National Trust


1 Company, as trustee for Soundview Home Loan

2 Trust 2005-4 Asset-Backed Certificates,

3 Series 2000-4 -- excuse me -- 2005-4, care of

4 Chase Manhattan Mortgage Corporation,

5 3415 Vision Drive , Columbus, Ohio.

6 Q. Does Chase get copies of pleadings

7 that are filed in foreclosure cases?

8 By pleadings, I mean if somebody

9 files -- if the homeowner files a motion to

10 dismiss, does Chase get a copy of that on their

~~ computer screen?



14 THE WITNESS: I don•t know how that

15 process is handled.

~6 BY MS . DOBERDRUK:

17 Q. If it was pointed out to Chase that

18 the note attached to the complaint did not have

19 an endorsAment anrl ~hase poRRARRed a nn~A with

20 an endorsement, then why did Chase never

21 correct the matter with the court?

22 MR. FRESHWATER: Objection. Grace,

23 you just posed an hypothetical in there that we

24 haven•t agreed to, that that was e v er pointed

25 out to Chase .




2 Q. Do you know if Chase referred this

3 case to foreclosure?

4 A. I'm going to ask if that's a trick

5 question, because isn't this the foreclosure

ti r.ompl;=d_nt?

7 Q. Yes.

· s A. So yes, Chase referred the loan to

9 foreclosure.

10 Q. And when Chase refers a loan to

11 forcclooure, do the y have communications with

12 counsel about the cases?




16 Q. So is it reasonable Lo say Lhat if

17 Chase noticed that the note attached to the

18 complaint was not correct, that Chase would do

19 something to substitute a note with the court?

20 MR . FRESHWATER: Objection, because

~1 we haven't stipulated that they ever noticed

22 that, and that's also a hypothetical.


Q. I'm just going to ask you again to

25 verify that you have not communicated with


A Veritext Company 888-3 91-33 76

1 Deutsche Bank about

2 note; is that correct?

3 A. I personally have no~ communicated

4 with Deutsche Bank.

5 Q. And before coming here, did you

6 make any effort to determine whethe r

7 Deutsche Bank or Wells Fargo had different

8 records of the note than what Chase had?

9 A. No.

10 MS. DOBERDRUK: Okay. Thank you.

11 THE WITNESS; You're welcome.

12 MR. FRESHWATER: Are you going to

13 go off the record?

14 MS. DOBERDRUK: Sure.

15 (Discussion held off the record.)

MS. DOBERDRUK: Do you want to read

17 the transcript and then sign, or waive

18 signature?

19

20

21

22

23

24

25

216-523-1313

THE WITNESS: Waive.

MS. DOBERDRUK: Okay.

(The deposition was concluded.)

Rennillo Deposition & Discovery A Veri text Company 888-391-3376

1 Whereupon, counsel was requested to give

2 instruction regarding the witness's review of

3 the transcript pursuant to the civil Rules.

4

5 SIGNATURE:

6 It was agreed by and between counsel and the

7 parties that the reading and signing of the

8 transcript of said deposition be, and the same

9 is hereby waived.

10

11 TRANSCRIPT DELIVERY :

12 Counsel was requested to give instruction

13 regarding delivery date of transcript.

14

15

16

17

18

19

20

21

22

23

24

25

216-523-1313

Original: MS. DOBERDRUK

Copy: MR. FRESHWATER


1 REPORTER 1 S CERTIFICATE

2 The State of Ohio,

3 SS:

4 County of Cuyahoga.

5

6 I, Donnalee Cotone, a Notary Public

7 within and for the State of Ohio, duly

8 commissioned and qualified, do hereby certify

9 that the within named witness, FRANK A. DEAN,

10 JR., was by me first duly sworn to testify the

11 truth, the whole truth and nothing but the

12 truth in the cause aforesaid; that the

13 testimony then given by the above-referenced

14 witness was by me reduced to stenotypy in the

15 presence of said witness; afterwards

16 transcribed, and that the toregoing is a true

17 and correct transcription of the testimony so

18 given by the above-referenced witness.

19 I do further certify that this

20 deposition was taken at the time and place in

21 the foregoing caption specified and was

22 completed without adjournment.

23

24

25


A Veritext Company 8R8-391-33 76

1 I do further certify that I am not

2 a relative, counsel or attorney for either

3 party, or otherwise interested in the event ot

4 this action.

5 IN WITNESS WHEREOF, I have hereunto

6 set my hand and affixed my seal of office at

7 ' Cleveland, Ohio, on this day of

8 2012.

9

10

11

12

13

14 Donnalee Cotone, Notary Public

15 within and for the State of Ohio

16

17 My commission expires February 7, 2017.

18

19

20

21

22

23

24

25


A V critext Company 888-391-33 76

[&- b]

& 39 4:7 r-&--2:-13__:::..::___ ___ 3900 1 :23 2:6

2

2 3:3 2.01 30:2,15 33:10 2.01. 33:20 2000-4 56:3 2003 10:22

4

2004 22:23 2005 4:8 12:2 27:12 able 19:20 25:2

39:16 absolutely 13:10

2005-4 1:7,8 22:4,5 25

:23

38:1 56:2,3 access 18:4,5 19:19 2007 12:2 accessed 55:17 2008 13:17 14:4 account 10:12 13:20 2010 28:12 13:22 25:9 2011 1:13 14:20 accredited 13:13,15

49:19 13:19,25 accurate 26.3 34.-1 G

2012 1:20 61:8 2017 61:1 7 accurately 35:22 21 4:3 acquire 52:21 216 2:9,17 acquisition 52:17,19

21st 27:12 53:13 27 4:4 action 61 :4 28 4:5 actual 40:16 2:22 1:20 address 14:21 40:23 r-----=--3 ___ _j 41:8 1----___:::__ ___ adjournment 60:22

32 27:9 admit 36:443:14 3415 22:7 56:5 affirlavit '\0: 1 (),21 350 14:23 affixed 61:6 373-0539 2:17

216-523-1313 Renmllo Deposition & Discovery

A Veritext Company

Page 1

888-391-33 76

[back- corporation]

back 25:12 32:2 38:5

backed 1:7 22:5 56:2

background 7:1 ballpoint 44:6 bank 1:46:137:18

9:1 10:17 14:3,9,13 15:23 16:14 22:3 25:9 32:7 38:10,11 47:4 55:5,22,25 58:1,4,7

banking 29:19 bankruptcy 50:1

54:20,22 55:7,11 based 11:8 52:7 basis 4~:~

behalf 2:3,12 6:19 believe 10:24 20:13

20:23 22:17,18,23 23:21 24:8 40:3 41:13 47:16 49:23

beneficial 8: 13,18 benefit 30:20 34:6,9 better 22:22 beyond 26:18 bit 23:3 black 41:3,4, 15,18

41 :20,21,21 42:7 43:2

blank 23:17 32:5 borrower 37:7 borrower's 20: 1 borrowers 11: 11 bottom 40:22 branch 14:9,13 25:9

47:4 bring 36:21 brings 20:1 brokering 10:14 brokers 13:23 business 7:1115:10

22:14,18

216-523-1313

c

c 1:9 4:5 9:7 22:6 27: 16,25 28:7 39:24

calendar 17:7 call 11 :15 called 5:118:18

29:5 calls 36:16 53:19 capacity 25:8 caption 60:21 care 56:3 case 1:135:106:5,8

19:7 20:12,19 21:24 23:25 28:9 50:23 53:15 54:20 55:24 57:3

cases 5:196:10,20 9:18 49:21 50:1 56:7 57:12

cause 60:12 certain 24:4 certificate 3:10

30:20 34:6 60:1 certificates 1:8 22:5

30:13 56:2 certified 5:4 23:4,6

54:12 certify 60:8,19 61:1 certifying 23:7 chapman 28:22 29:1

40:20 41:7,10,13,16 41:17 42:5,6,15 43:23,24 44:11 45:5 45:7,13

chapman's 40:15 4?.: 14

chase 1:9 6:13,15,19 6:23 7:19 14:3,4,8 14:1415:1 17:24 20: 11 '19 21 :2 22:6 22:10,13,19 23:19 23:21 24:4,6,9 29:2 29:4,13,18,21 37:15 37:25 46:13,16

47:19 48:4,9 49:9 49:18 51:10 52:8,10 53:16 54:19 55:4,11 55:22 56:4,6,10,17 56:19,20,25 57:2,8 57:10,17,18 58:8

chase's 38:24 39:6 choose 12:25 13:2

16:25 chose 12:24 13:1 ciYi( 5:3 59:3 clarify 9:14 clarifying 22:1 classification 11:16 clear 41:2 clearly 42:4 cleveland 1:23 2:8

2:16 14:23 61:7 clients 11:16 closed 14:1 closing 20:8 25:12

27:10,12 53:24,25 54:4

collateral 34:11,24 36:9 40:12 45:22 52:12,18,20

coiJege 7:4,12 collins 46:9,11,14 color 42:15,21,23

43:25 44:7,12 45:6 45:14

columbus 22:7 56:5 come 16:25 18:23 coming 36:25 54:18

58:5 commission 61:17 commissioned 60:8 common 1:1 communicated

17:1618:13 57:25 58:3

communications 57:11

companies 12:18


Page 2

company 1:5,10 9:10 12:21,24,25 22:3 32:7 56:1

compare 35:16 complaint 4:3 21 :4

21:7,10,14,17 23: I 28 :9 31:9,9 33:15

·33:17 36:11,14 50:14 53:17 56:18 57:6,18

complete 7:22,24 completed 60:22 compound 44:2 computer 17:24

19:11,15 52:21,24. 56:11

concluded 5~:22

concurrently 30:16 34:2

confirm 53:11 confirms 52:17 consider 48:22 contact 18:22 contain 36:15 53:17 contains 37:7 54:9 context 53:25 continuation 26:24 continue 32:9 conversation 47:9 convey 30:18 34:4 conveyance 30: 12

33:11 conveyed 33:3 copies 34:16, 17 54:7

56:6 copy 23:4,8 26:6

31:8 34:14 35 :16 38:13 39:10 40:1 45:21 54:12,14,16 54:16 56:10 59:15

corp 26:13 31:7 corporate 51: 1 0 corporation 16:1

22:7 31:18,21 46:4 46:7 56:4

888-391-33 76

rcorrect- execution]

correct 26:22 32:21 33:18 37:23 42:25 56:21 57:18 58:2 60:17

co tone 1:25 60:11 61:14

counsel 17:5,10 18:23 21:3 23:20,22 24:4,8,11 54:15 57:12 59:1,6,12 61:2

county 1:2 60:4 couple 37:6 court 1:1 3:14 48:20

48:22 51 :3 56:21 57:19

courtroom 4~:25

49:1 cover 4:4 27:21 credit 11: 11 cross 41:7 crossed 40:23 41: ll

41:13 err 1:25 current 14:16 currently 6:12

14:13 custodial 37:11,13 custodian 3 7: 18,2 l

37:25 38:9,12 55:20 custody 3: 13 cuyahoga 60:4

d

d 4:79:739:11,13 45:23

daily 48:8 dann 2:13 dannlaw.com 2: 18 date 15:1 1 27:10,12

44:9,19 45:4,11 53:6,13 59:13

dated 4:7 39:15 day 13:21 48:13,14

48:18 53 :2 61:7

216-523-1313

dean 1:19 3:7 5:1,6 5:13 60:9

deas 40:23 41:7 december 27:12 decision 111:24 default 18:14 defend ants 1:16

2:12 5:9 define 25:2 definitely 43:4,9,15 definition 11:9 27:9

34:1 38:7 degree 7:8 delivery 30: 1 7 34:3

59:11,13 department 29: 13

29:15,21 departments 29:17 deposed 5:4 deposition 1:18 5:14

6:15,17 15:13,17 16:22 20:25 21:9 25:19 26:16 27:19 27:25 29:7 32:13,16 3 8:22 39:13 48: 1 7 49:6,18 50:6 54:23 58:22 59:8 60:20

depositions 34: 18 49:3,9,20,23 ,25 51:3,7

depositor 26:11 30: 16,21 31 :6 34:2 34:7,9

describe 10:10 describing 33:12 description 4:2 descriptive 7:2 desktop 18:19,24

19:2,13,22 20: 15 detail 3 7:24 determine 58:6 denhche 1:4 lS:n

16:14 22:3 32:7 55 :5,25 58:1,4,7

different 6:21 41:16 41 :21 42:6,15,23 43:2,3,10,16,25 44:4 45:6 48:14 5R:7

discuss 25:21 discussion 27:17

39:19 5-1:22 58:15 dismiss 56:10 distinction 36:3

50:4 doberdruk 2:13,14

3:8 5:7,8 9:16 10:3 11:10 12:22 15:7 16:9 17:15,20 18:12 19:9 20: 18 21:1,6 21:20,21 22:9,20 23:24 24:5 25:3,21 25:24 26:2,9 27:1,5 27:7,13 28:5,19,21 29:11 30: 1 ,6,9,24 31:3 32:17 33:7 34:10,13,19,21 35:23 36:20 38:4 39:9,20,25 40:4,9 41:12,14,24 42:12 42:13,20,22 43:7,13 43:19,22 44:8,20 45:3,10,18,20 46:21 48:11 49:24 50:12 50:22 51:22 53:5,14 54:1 55:2,10 56:16 57:1,15,23 58:10,14 58: 16,20 .59: 14

document 26: 18 36:21 42:1

documented 11:12 documents 16:15,19

19:1,3 20:2,9 21:2 23:20 24:7 26:15 47:5 50:15 51:14 53:12 54:4

donnalee 1 :25 60:6 61:14


Page 3

dozen 6:1,10 49:11 drive 4:7 22:7 39:14

56:5 duly 5:3 60:7,10 duties 9:8 17:21

e

e 1:159:7,710:6,6 16:23 37:7 47:16

educational 6:25 effort 58:6 eight 12:14 either 25:8 32:5

48:15 61:2 employed 6:12 employee 6:19 emptY 21: 1 R endorse 23:16 endorsed 32:5,20

33:3,12 54:16 endorsement 31:17

31:20 32:25 33:16 . 35:1,4 36:9,15

45:25 46:3,6 52:3 53:18 56:19,20

entire 15:1 entry 53:13 equicredit 9:7 10:5 equitable 7:25 esq 2:5,14 estate 53 :25 et 1: 15 event 61:3 evidence 41: I 0 exact 15:11 exactly 53:8 examination 3:7 5:2

5:6 example 44:5 excuse 56:3 execute 9:20 executed 9:24 executes 29:21 execution 30:17

34:3

888-391-33 76

[executive- identify]

executive 13:20,22 25:9

executives 10:12 exhibit 3:13 4:3,4,5

4:7 21:7,9 22:25 27:15,16,19,25 28:7 31:9,12 32:2 38:5 39:11,13,24 45 :23

exhibits 3:5,14 4:1 expert 44: 14 expires 61:17

find 16:21 fine 31:2 first 5:3 7:14 14:7

15:8 26:23,25 27:3 30:14 33:20 37:6 49:12,17 60:10

fiscal 40:7 following 32·6 follows 5:5 foreclosure 4:3 5:10

9:17 20:12,20 21:3 explain 17:3 21:1023:2025:15 explanation 36:13 28:9 49:21 50:1,2 extent 44:14 50:2453:1654:15 extracted 54:14,15 55:12 56:7 57:3,5,9 ~e 43:11 57:11

r-=---------=-f ___ _j foreclosures 9:12

facets 29:18 50:7 fadlity 37:11 ,13,14 foregoing 60:16,21 fair 35:11 38:12 form 32:6

52:23 frank 1:19 3:7 5:1,6 fnmilinr 15:15 5:13 60:9 fargo 16:538:10,1 1 fresh 35:17

38:13,18,20 58:7 freshwater 2:5 9:13 febmary 61:17 9:25 11:6 12:19 federal 7:25 15:5 16:6 17:12,18 felt 44:5 18:10 19:4 20: I 6,22 female 47:1 21:1R22:1523:23 fidelity 18:16 24:1,22 25:23 26:5 file 15:16 20:2 21 :3 26:23 27:2 28:16

23:20 34: 11 ,24 36:9 29:6,23 30:4,7 31: 1 36:22,25 3 7:2,9 32: 12 33:4 34: 12,15

Page 4

r---:-::-~g~--~ happen 54:18 55:3 g 10:6 happened 22:21

general 12:23 17:19 17:21 19:5 24:6,25 51:21

getting 24:12 give 6:17 39:9 59: 1

59:12 given 24:8 60:13,18 gives 23:19 53:2 glenn 1:15 15:4,9,20

16:2,5,11,14,18 19:1021:15 23:13 26:16 37:7 38:14,19 58:1

go 6:22 7:6 8:25 11:21 13:2 14:2 17:10 31:12 32:14 38:5 39:22 44:3 53:1158:13

going 16:22 19:4 20:22 23:11 25:2,25

26:18 27:15 30:2 31:12 33:23 34:22 36:2 38:6 40:10 42:11 44:16 45:21 51 :24 57:4,24 58:12

grace 2:14,18 5:8 19:4 20:22 27:2 30:4 32:12 33:5 42:10 43:6,17 45:9 51:2156:22

hard 11:13,15 haslam 35:5,13 haslam's 35:25 headed 48:17 heard 3 7: 16,20 held 9:9 27:17 39·1 q

58:15 -

helpful 32: 13 hcrcinnftcr 5:4 hereof 30: 17 34:3 hereunto 61:5 hi 5:8 high 11:12 hill 12:9,13 13:12 bine 1:22 2:4 hired 14:4 hold 14:11 holden 1: 15 16: 14

21 :15 holden's 15:4,9,20

16:2,5,11,1919:10 23:13 26:16 35:18 37:7 38: 14,19 58: 1

holdens 15:15 20:12 34:18 54:20 55:6

holders 30:20 34:6 holding 37:4 home 1:6 13:13

14:17 16:18 22:11, 19 38:1 48:16 53:10 56:1 40:12 45:22 52:13 35:18 36:16 38:2

52:18,20,22,22 39:22 40:2,6 41:9 grocery 7:17 55:12,16 41:23 42:10,17 43:S

1gu_e_ss_in___,g"------=2=-=2-=-=:2:=2 __ homt:uwnt:r 56:9

filed 21:15,16,19 43 :12,17,20 44:1,13 h huh 23:5 31:10 23:2525:1436:14 44:2345:~, 1746:!8 h 35:5 -hypothetical 56:23

5 48 0

57:22 4:20 56:7 :1 49:22 50:9,18 hairs 41:19 , ______ _J

files 9:17 56:9,9 51:20 53:3,19 54:21 half 27:3 filing 50:14 55:8 56:12,22 57:13 hand 37:4 45:21

finance 8:1322:19 57:2058:1259:15 61 :6 finam:ial 12:9 16:1 front 25:10

19:22 26:13 31:7,18 further 60:19 61:1

handed 21:14 handing 28:6 handled 56:15

31:21 46:3,7


A Veritext Company

identification 21: 12 27:22 28:3 39: 17

identified 20:24 30:8

identify 27:10 38:8

888-391-3376

(ii - multistate]

ii 30:5,11 image 54:13 imaged 20:2 53:12 including 30:22

34:8 income 11:12 index 3:1,5 4:1 indicate 36:2 40:8

52:22 indicates 37:9 indication 55:4 industry 24:25 indymac 10:17,19

key 1:23 2:6 location 14:22 47:25 kind 9:14 15:6 48:4 know 12: 18 16:24 locations 54:6

17:1420:11,14 long 8:5,2311:19,25 22: 11,21 ?.4·?.,3,14 12. ·12. 11:14 14:1R 24:23 25:7,11 28:24 47:18 29:1,8,25 35:24 look 15:12 19:15 36:18,24 37:3,24 26:10 31:8 33:10,19 38:3,16 44:15 46:9 35:7,8,12 40:5,14 46:13,16,19,25 40:15,22,25 43:10 47:14,18,22 48:1,7 43:15 52:24 49:8 52:6 53:21 looked 15:8 19:18 54:24 56:13,14 57:2 . 33:15

marking 42:6 marks 23:15

PageS

mary 46:9,11,13,17 matter 56:21 mP.an 41 :115?.:11

56:8 meaning 13:7 means 24:20 48:24 mediation 51 :20,23 mediations 51:8,9

51:15 merged 22: 19 meritage 10:6

ll: 19 13:2,3 knowing 52:2 looking 18:22 44:21 mers 4:5 16:10 28: 1 method 33:14 information 18:22 knowledge 15:3 53:6

initiate 13:7 1----24_:_2_:_5 ____ --1 looks 35 :15,17,25 ink 35:1740:1641:3 1 40:2052:22

mind 34:20 39:20 minute 31:24 modifications 47:6 moneysworth 7:15 monroe 37:11,13 months 12:14 13:16

41:5,15,18,21 1 19:25 35:5 lost 32:8 44:17 instances 20:10 louisiana 37:11,13 instruction 59:2,12 laptop':s 19:17 low 11:11

lawful 5:1 interest 11 :12 30:21 1 d 29 5 10

Ips 18:14,19,2419:2 ea : , 47:10 30:22 34:7,8 leave 12:24,25 13:2 19:13 20:15

interested 61:3· 13

:25 mortgage 1 :9 4:6

r-·---- ------1 10:7 13 :23 18:2 lender 17:11 ,171 8:8 m 2:1410:635:5

internally 19:21 investments 29: 19 involve 49:3 51 :2,7 involved 50:14 issuance 30: 13 ivault 19:24 53:11

j

job 7:14 9:8 13:5,8 17:23 46:22 47:3 48:12,15 49:2 50:13 51:2

jobs 12:17 jpmorgan 6:13

19:21 37:15 55:22 jr 1:19 3:7 5:1,6

60:10 judgment 50:17,21

k

keep 55:11 kept 55:16

I .

216-523-1313

m

24:13 ma'am ZJ:Z 19:2 20:3,6 22:6,1'1

lenders 13:13 mail 16:23 22:1424:21,25 letter 19:25 mailbox 17:6,6 25

=1126:1 7 28:1,8

lines 23: 18 maintains 37:21 28=

10•14•17

,20 29:18 30:12 31:14

link 19:23 majoring 7:10 list 7:22,24 majority 49:2 32:4,9,16 33:1,11

l . t . 44 18 t 29 59 39:23 40:11,13 IS enmg : managemen : , little 7:2 23:3 manager 9:5 10:9 44:10 45:12 54:7,14

56:4 He 2:13 10:1 1,25 11:1,24 Up 1:222:4 12:517:6 25:10 mortgages 5:20 8:19 loan 1:67:25 8: 16 managing 11:2 9:21,24J0:1424:14

8:17 9:2 11 :22 manhattan 1:9 22:6 25:6 29:22 37:17 48:6

13:24 14:9,14,17 22:11,13 56:4 0 7 21 motion 5 :1 ,

15:1 6 16:15,18 18:2 manila 36:25 37:9 20 122 4 25 9 38 1 l 40 23 41 7

54:19 55:1 5n:9 : : : : man ey : :

move 51:24 47:4 53:10,24,25 mark 21:6 27:13

moved 55:4,6 55:12,16 56:157:8 35:14 39:10 57: 10 marked 4:2 21:11 msp 18

=6•7

multistate 10:13 loans 11 :4,5,18 27:21 28:2,7 39:16

30:12 47:8 45:23 i

Rennillo Deposition & Discovery A V P.ri tP.xt r.omp::my RRR-391-137n

~·~~~~~~~~~ Page 6

~----=n:_ __ _j objection 9:13,25 order 21:3 32:6 name 5:8,1 126:1'1 11 :612:1915:5 piece 37:3

43:24 45 :6,13 46:10 16:6 17:12,18 18:10 original 30:13 32:4 place 60:20 46:1447:12,14 20:1621:1822:1S

32:15

•20

•2534

:23 placed 52:3 35:12 36:5 37:8 named 6:2146:16 23:23 24:22 28:1? plaintiff 1:11 2:3

46:25 60.·9 29 23 30 38

:144

0:l,3

,13

t) 8 20 21 2 : :25 33:5 45:22 54:9,11 55:20 : ' . : 2 55:23

national 1:4 22:3 36:16 38:2 41 :9,23 59:14 plane 48:17 32:7 55:25 4'"'·10 17-13 5 12 17 pleadings 56.·6,8

~. ' :' ' originate 8:1947:8 near 53 :12 44:1,1345 :846:18 origination 25:11 pleas 1:1 necessarily 48:2

1 48:10 49:22 50:9,18 --=-::.::...:.:......:..::..::~:..:...:...:~_j please 5:12 45 :2

never 26:20 37:2 53:3,19 54:21 55 :9 P point 35:14 56:20 56:12,22 57:13,20 p.m. 1:20 pointed 5G: 17,24

new 12:17 obtain 24:12 packages 54:5,6,8 pointing 44:24 normally 49:7 obtained 52:25 53 :1 page 4:4 23:12,16 pooling 4:4 25:13 22 notary 60:6 61:14 office 14:22,25 15:2 26:1,11 27:9,21 26:3 27:14,20 30;3 note 4:7 15:4,9,12 47:24 48:6 61:6 30:8 31:5 32:2 32:19 38:6,7 51:17

15:20,23 1"6:2,5,11 officer 8:16,17 9:2 40:14 45:24 51 :18 52:7 19:10,19,2020:} 14:9,14,1725:9 pages 27:4 posed 56:23 23:12,16,212-1:8,

12 40:7 47:4 53:10 paid 50:3 position 9:23 10:8

24:17,21 26:17 official 37:5 paper 37:4 10:16,23 12:4,10,16 31:13,15 32:4,9,16 oh 8:9 21 :23 27:5 paragraph 30:14 14:7,10,11 29:4

32:20 33:1,2,12,17 38:25 44:22 32:14,25 47:3 33 :21 34:23,25 36:9 ohio 1:2,23 2:8,16 part 17:23 22:22 positions 7:19 8:15 36:10,14 37:5 38:14 4:7 5:2 6:2 7:7 8:21 26:24 38:15 48:12 9:9 13:6 25:5 38:14,1939:10,!

4 14:2422:839:15 50:1351:1 possessed 56:19

45:22 51:25 52:4,16

51:12 56:5 60:2,7 participating 50:6 possible 36:441:25

53:13,16 54:7,9,11

6 1:7,15 particular 12:20 possibly 41:22 43:3 54:12 55:19 56:18 okay 8:919:8 26:LO parties 59:7 preparation 25:19 56:19 57:17,19 58:2 27:1 31:4,16 32:11 party 6:21 61:3 preparing 15:13, 16 58:8 33:24 34:10,19 3S :3 pay 32:6 38:22

notes 19:237:17 42:1243:1945:1 pen 35:8.1636:1 prepping 48:16 52:12,14,15 48:2,24 50:5 52:6 40:20 41:1,21 42:7 presence 60:15

notir.e 2.0:24 54:18 54:3 58:10,20 42:16 43:3,10,16,25 president 10;25 54:25 old 9:1 44:5,12 45:14 35:6

noticed 57:17,2! older 8:10 pens 44:14 previous 32:14 novastar 4:5 15:

19 once 19:23 people 47;24 48:5 previously 38:17

28':1 ones 18:3,5 34:l8 period 52:25 49:10 november 1:20 open 19:23,23 person 17:8 36:1 print 26:6 44:1 1 number 4:220:

1 opened 12.:17 person's 55:16 printed 40:1941:16

l_---=..::.____:o~~~_j operation 29:17 personal 13:4 42:5,7,25 43:24

ro~2=-:2:-:6 _ _:_ ___ _J operations 29:5,9,12 personally 16:25 45:6,1 3

b

29.·13,15,20 58:3 prior 15·1625·5

0 ject 19:5,6 20:23 · · 29:6 opinion 53:22 54: 10 pertaining 4 2:24 probably 18:3 4 7' l a opposed 35:16 36:l physically 21:19 procedure 5:3

36:5 43:21 process 17:2,4 20:20 24:6 56:15

[name- process]

Rennillo Depost'ti'on & D s 1 covery 21 ti-523-1313 A Veritext Company RRR-191-317()

[processing -signature]

processing 17:11,17 recorded 24: 15,17 18:8 54:8

produced 34:23 records 18:2 37:21 55:19 37:25 38:23,24 39:5

proclnl.'t 11·3 39:6 52:9,10,11 program 18:8,18 54:17 55:3,12,15,21

19:24 58:8 prospect 2:15 recourse 30:1932:8 provide 21:2 34:5 provided 5:2 54:13 reduced 60: 14 psas 33:23 r·efer 18:5 20: 19 public 2:7 24:18 referenced 60:13,18

60:6 61:14 referral 20:14 purposes 21: 11 referred 19:22,24

27:21 28:3 39:16 20:11 50:23 53: 15 pursuant 59:3 57:2,8 put 27:5 53:24 referring 12:20

f-L-----q------1 28:17 30:5

refers 57:10 qualifications 11: 17 reflect 44:24 qualified 60:8

question 33:5,6 regarding 59:2,13 35:20 39:1 41:2 regards 26:16

regularly 18:5 42:11,24 43:6,21 8

related 4 :20,22 44:17 45:2,9 50: 11 50:7 51:5,25 53:4 57:5

questions 27:4 relationship 12:5 SO: 19 relative 61 :2

-------1 relevance 10:1 19:6

r------r----1 relief 54:19 55:1,5,6 r 9:7 10:6 47:16 rates 11:12 read 30:14 31 :25

32:24 33:23 58:16 reading 33:9 59:7 real 53:25 reask 50:10 reason 24:7 41 :6 reasonable 57: 16 reasons 13:4 37:6 recall 6:11 8:4,6,24 receipt 54:11 received 53:7,8 record 5:1224:18

27:17 39:19 44:23 58:13,15

remember 6:5 10:18 15:1147:13,17 49:12

repeat 44:17 rephrase 24: 13 reporter 3:14 reporter's 3:10 60:1 representative

51:10 rPprP~Pnting 'i :9 request 17:5,10

18:23 requested 59:1,12 requests 17:7 required 54:5

Page 7

research 14:17 section 27:9 30:2,15 53:10 32:1 33:2,10,20

residential 5:20 38:7 11 :4,18 securities 16:1

respect 32:8 26:13 /9:19 31 :7,18 retained 3:14 31:21 46:3,7 review 9:17 38:23 securitization 25:1

38:23 39:5 4 7:5 securitize 24:21 51:14,17,18 52:7 securitized 37:17 59:2 security 30:22 34:8

r·eviewed 13.23 see 17:8 19:1 23:3 26:15 54:17 23:13,15 28:13

reviewing 50: I 5 31:11,17,20,23 reviews 17:7,7 32:22 33:16 40:5 richard 2:5 30:25 42:3,4 46:2,6 52:21 richard.freshwater" 55:4

2:10 seen 25:13 26:14 right 8:11 14:5 28:6 selling 25:5,6

30:21 31:23,25 34:7 sells 33:21 37:16 39:4,25 40:1 sent 37:10,12 40: 10 46:2 51 :23 sentence 33:20,23

rpr 1:25 september 4:8 28:12 rs 47:17 39:1544:1145:4,11 rules 5:2 59:3 series 1:8 22:5 56:3

r---=--=~s::....:....:..::.....__----l services 11:22 17:11 1--------·-

s 35:5 sales 10:9,11,25

11:1,2,24 12:10 25:10

sampling 7:23 savings 7:25 says 23:4 32:19

52:25 school 7:6 scores 11 : 11 screen 19: 11 , 15

52:24 56:11 screens 19:2 scribbling 23:9 seal 61:6 search 19:25 second 40: 14 secondly 37:9

17:17 18:9 19:22 servicing 4:4 25 :14

25:22 26:4 27:14,20 30:3 32:19 38:6,8 51:17,19 52:8

set 30:18 34:4 61:6 settling 54:4 shade 42:23 shadybrook 4:7

39:14 show 25:25 27:8

30:2 31 :4 34:14,17 34:20,22 38:7 40:10 51:1

shows 53:7 sign 48:5 58:17 signature 23:7,10,13

23 :17 35:12,19,25 36:6 37:8 40:15,17 41:17 42:2,14,25

216-5?3-1313 Rennillo Deposition & Discovery


rsignature- unendorsed]

43:23 45:7 58:18 59:5

signed 28:11,13 35:7 36:140:16 50:16,20

signer 35:3 signing 59:7 silvPr 1?_:9, 12 13:11 site 19:22 six 47:10 software 18:1,8 sold 37:18 solutions 18:14 somebody 12:18

23:7 50:15 56:8 sorry 28: 16 38:25

43:8 50:8 sounds 46: 14 soundview 1 :6

16:18 22:4 38:1 56:1

south 14:23 space 23:17 specific 15:6 19:7 specified 60:21 speculation 36:17

53 :20 spelled 47:14 splitting 41: 19 spoken 26:20 38:18 spot 8:11 9:6 square 2:7 sr 35:5 ss 60:3 staff 17:8 stamp 35:25 36:5

41:22,25 stamped 35:9 start 8:3 started 10: 19 state 5:11 35:20

46:10 60:2,7 61:15 stay 8:5 54:19 55:1

55:5,6

216-523-1313

stenotypy 60:14 teller 8:16 46:23,24 steve 35:5,12,24 tells 33:2 sticker 40:7 ten 8:7 stipulate 34:16 teri 46:25 stipulated 26:3 teri's 4 7:12

57:21 terms 11:2 32:15 stone 9:1 territory 10: 13 stop 30:24 testified 5 ·23 6:2 store 7:17 testify 6:22 60:10 style 44:12 testifying 6:9 43:21 submit 13:5,7 54:5 (\9:3 51:2,7 submitted 17:6 testimony 60:13,17 subparagraph 32:3 texture 43:3,25 subpdme 11:5,9,1 G 45:14 substitute 57:19 thank 21:25 31:24 summary 50:16,21 45:16 58 :10 summit 1 :2 thanks 45:19 supervised 10:12 think 27:3 33:23 supposed 40:12 39:23 40:5 41:6,19 sure 26:6 35:21 44:17 49:10 51:4

49:11 58:14 third 23:12 sworn 5:4 60:10 thompson 1:22 2:4 system 18: 1 52:12 thompsonhine.com

52:14,15 55:13,14 2:10 systems 17:24 three 50:19 ~------------~

t time 6:14 11:13,15 1-t- 9-:7- 1-0.-·6-1-9:-25- -----j 14:12 15:1 ,8 32:22

47:16 35:21 49:17 52:17 tab 27:6 52:20,25 53:2,6,12

take 7:24 49:20 54:3 60:20 taken l:ll 5:15 times 5:17,21 ,25

60:20 tip 44:5 takes 49:23 tipped 43 :3

talk 15:19,22,25 title 9:3•4 11:23

16:4,10 146:160,3190 25:225 3 4 talked 16:13,17 2 :1 :11• 1 l :

34:7 46:22 38

:19

titled 10:24 33:10 talking 9:14 12:23

today 34:11 36:22 19:5,7 21:19 32:15 36:25 54:18 55:20 37:14 40:16

tell 19:18 21:16 top 44:24 45:5,12 26:11 28: 10 30:10 topic 54:22

31 :5 34:25 35:10 topics 20:24 29:7

45:1 49:15 tower 1:23 2:6


Page 8

track 44:17 transcribed 60:16 transcript 3:1 58:17

59:3,8,1 1' 13 transcription 60: 17 transfer 30: 18 34:4 transition 12:20 transpired 25: 12 trial 5:23 6:3,22

49:3 51:7 trick 57:1 true 23:4,8 24:18

54:12 60:16 trust l :4,6 16:18

22:4 25:14 26:1,4 26:1127:9,1130:19 31 :6 32:7 33:3,21 34:5 37:18,19,22 38:1,9,12,15 55:25 56:2

trustee 1:5 22:4 30:19 32:7 34:5 56:1

trusts 25:6 truth 60:11,11,12 .try 53:24 turn 22:25 23:11

24:7 45:24 two 8:14 11:20 12:1

13:16 15:10 44:18 47:17,21

type 41:3,21 44:4 types 5:19 typkal 13:2 1 48; 13 typicality 48: 15

u

u 9:7 19:25 uh 23:5 31:10 understand 24:20 understanding 17:1

24:19 33:9 undoubtedly 42:9 unendorsed 54:15

888-391-3376

[university- yep]

university 7:7 westerville 14:24 use 17:24 18:21 whereof 61 :5

r---2-0-:2:.;,_,;1~---__J willing 34:15

1 ___ v ___ __J witness 10:2 11 :8

v 19:25 16:8 17:1418:11

vague 15:617:1 20:17 21:25 22:17 48:] 0 24:3,24 29:9,25

various 9:9 54:6 35:20 36: 19 3 8:3 vast 49:2,4 44:4,16 45:1 46:20 vault 54:14 50:10,20 53:9,22 verify 57:25 54:25 56:14 57:14 versed 33:22 58:11,19 60:9,14,15 versus 44:5 60:18 61:5 vice 10:25 35:6 witness's 59:2 view 19:2025:17 work 7:13,218:1,23 viewed 19:10 36:2-1 9:11,1410:411:19

37:2 11:25 13:11,14

viewing 43:11 47:24 48:5 50:7 vision 22:7 56:5 worked 7:19 8:12 visited 13:23 15:1 22:10 47:18 vs 1:13 working 10:19 25:4

l __ :._w--~- works. 17:?.,4 ?.9: 1 r----:---_:__ ___ wrap 52:1

waive 58:17,19 writing 23:12 WlliVI?d 59:9 wanda 28:22 29:1 written 13:8 40:20

40:15,2041:7,10,13 41:143:10,15,25 41 :16,1742:5,6,14 wrong 22:2426:6

42:15 43:23,24 y 44: 1 1 4 5 : 5, 7, 13 y 4 7 : 15

want 7:2227:431:4 yeah 19:2 1 25:R 31:13 32:9 34:13,20 29:12 3 8:3 40:6 35:21,24 58:16 47:16 48:23

way 24:11,13 52:2 year 10:21 49:13,15

we've 26:2 49:17 week 25:18 49:5 years 8:7 11:20 12:1 weekly 49:7 47:21 weeks 15: I 0 yep 20:4

welcome 5R: 11 wellen 2:13 wells 16:4 38:1 O, 11

38:13,18,20.58:7 went 11:17 12:15

20:15 22:1,14,18 54:13

216-523- 1313 Rennillo Deposition & Discovery

A Veritext Company

Page 9

888-391 -3376

121101 - Deposition Frank Dean Deutsche t Soundview Home Loan Trust 2005-4 v Holden

Documents

Transcript of 121101 - Deposition Frank Dean Deutsche t Soundview Home Loan Trust 2005-4 v Holden