The deposition transcript summarizes Cindy Riley's deposition regarding a case between JP Morgan Chase Bank and Eduardo Orozco. Ms. Riley has worked in the banking industry for 25 years, starting with Chase and acquired banks. She testified about her employment history, including working for an oil and gas company, JCPenney, and an insurance company after graduating college with a business degree. She met with attorneys from Chase and her own attorney to prepare for the deposition.
The deposition transcript summarizes Cindy Riley's deposition regarding a case between JP Morgan Chase Bank and Eduardo Orozco. Ms. Riley has worked in the banking industry for 25 years, starting with Chase and acquired banks. She testified about her employment history, including working for an oil and gas company, JCPenney, and an insurance company after graduating college with a business degree. She met with attorneys from Chase and her own attorney to prepare for the deposition.
The deposition transcript summarizes Cindy Riley's deposition regarding a case between JP Morgan Chase Bank and Eduardo Orozco. Ms. Riley has worked in the banking industry for 25 years, starting with Chase and acquired banks. She testified about her employment history, including working for an oil and gas company, JCPenney, and an insurance company after graduating college with a business degree. She met with attorneys from Chase and her own attorney to prepare for the deposition.
The deposition transcript summarizes Cindy Riley's deposition regarding a case between JP Morgan Chase Bank and Eduardo Orozco. Ms. Riley has worked in the banking industry for 25 years, starting with Chase and acquired banks. She testified about her employment history, including working for an oil and gas company, JCPenney, and an insurance company after graduating college with a business degree. She met with attorneys from Chase and her own attorney to prepare for the deposition.
2 3 CASE NO.: 09-29997 CA (11) 4 JP MORGAN CHASE BANK, N.A., 5 Plaintiff, 6 vs. 7 EDUARDO OROZCO, et al., 8 Defendants. 9 ________________________________________________________ 10 DEPOSITION OF 11 CINDY RILEY 12 13 DATE TAKEN: January 15, 2013 14 TIME: 10:00 a.m. - 12:23 p.m. 15 PLACE: 345 East Forsyth Street 16 Jacksonville, Florida 32202 17 18 19 Examination of the witness taken before: 20 Samantha Cordova, FPR, Notary Public 21 Hedquist & Associates Reporters, Inc. 345 East Forsyth Street 22 Jacksonville, Florida 32202 23 24 25 Hedquist & Associates Reporters, Inc. Page 1 Veritext Florida Reporting Co. 800-726-7007 305-376-8800 1 APPEARANCES FOR THE PLAINTIFF 2 3 ROLAND E. SCHWARTZ, Esquire 4 GrayRobinson 401 East Las Olas Boulevard 5 Suite 1850 Fort Lauderdale, Florida 33301 6 7 8 APPEARANCES FOR THE DEFENDANTS 9 10 MICHAEL J. WRUBEL, Esquire 11 Michael Jay Wrubel, P.A. 4801 South University Drive 12 Suite 251 Davie, Florida 33328 13 14 APPEARANCES FOR CINDY RILEY 15 16 JONATHAN WEISS, Esquire 17 Simpson, Thacher & Bartlett, LLP 18 1999 Avenue of the Stars 29th Floor 19 Los Angeles, California 900067 20 21 ALSO PRESENT 22 Eduardo Orozco, Defendant 23 24 25 Page 2 Veritext Florida Reporting Co. 800-726-7007 305-376-8800 1 I N D E X 2 E X A M I N A T I O N S WITNESS Page 3 CYNTHIA RILEY 4 4 DIRECT EXAMINATION BY MR. WRUBEL 4 5 CROSS-EXAMINATION BY MR. SCHWARTZ 77 6 7 E X H I B I T S 8 FOR IDENTIFICATION Page 9 Defendants' Exhibit 1 69 10 Plaintiff's Exhibit 1 83 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 3 Veritext Florida Reporting Co. 800-726-7007 305-376-8800 1 MR. SCHWARTZ: Hi. My name is Roland Schwartz. 2 I'm with the law firm of GrayRobinson. We represent 3 Chase. We also represent Ms. Riley as an employee 4 of the bank. There was a request by the borrower to 5 record -- audio record this deposition, which was 6 refused. And the borrower will not be recording 7 this deposition. 8 CYNTHIA RILEY, 9 acknowledged having been duly sworn to tell the truth 10 and testified upon her oath as follows: 11 THE WITNESS: Yes. 12 DIRECT EXAMINATION 13 BY MR. WRUBEL: 14 Q Okay. Could you state your name for the 15 record, please? 16 A Cynthia Riley. 17 Q And by whom are you employed? 18 A JP Morgan Chase. 19 Q Okay. And how long have you been employed by 20 them? 21 A I've been with Chase or Chase affiliates for 22 25 years. 23 Q Okay. And when you say Chase affiliates, I 24 take it you're referring to banks that were acquired 25 or -- Page 4 Veritext Florida Reporting Co. 800-726-7007 305-376-8800 1 A Right. 2 Q -- institutions that were acquired? 3 A Correct. 4 Q All right. Before we get into your work 5 history, have you ever given a deposition before? 6 A Yes. 7 Q Okay. Have you ever given a deposition with 8 reference to your work with either JP Morgan, WaMu, or 9 any of the predecessors? 10 A Yes. 11 Q How many times have you given a deposition so 12 far? 13 A Twice. 14 Q Twice. 15 A I think twice. 16 Q And when were they? 17 A I can't be sure of when they were. 18 Q To the best of your ability. 19 A I would want to say the last year sometime. 20 Q Okay. And I take it one of them was -- 21 A Maybe two years ago. 22 Q One of them was in Tavares? 23 A Yes. 24 Q Okay. And the other one was where? 25 A New York. Page 5 Veritext Florida Reporting Co. 800-726-7007 305-376-8800 1 Q In New York? 2 A (Nods head.) 3 Q Okay. Do you know what the name of that case 4 was? 5 A Don't recall. 6 Q Okay. Do you recall when you gave the 7 deposition? 8 A I -- I'm guessing -- I don't really know for 9 sure. 10 Q Okay. In any case, this will be your third 11 deposition with reference to this subject matter? 12 A Correct. 13 Q All right. And with reference to your 14 education, how far did you go? 15 A College. I went through college. 16 (Brief interruption.) 17 THE WITNESS: I'm sorry. My phone is obviously 18 on. 19 MR. WRUBEL: Take your time. 20 THE WITNESS: Took care of that. Thank you. 21 MR. WRUBEL: No worries. 22 THE WITNESS: My apologies. 23 MR. WRUBEL: Things like that happen all the 24 time. 25 THE WITNESS: Nobody ever calls me. Okay. Page 6 Veritext Florida Reporting Co. 800-726-7007 305-376-8800 1 BY MR. WRUBEL: 2 Q Okay. You were mentioning you went to college. 3 A Yes. 4 Q Where'd you go? 5 A University of Colorado. 6 Q And what did you major in? 7 A Business administration. 8 Q And did you get a degree in business 9 administration? 10 A Yes, I did. 11 Q Did you do any post-college work? 12 A Some. Couple of years. 13 Q Couple years. Where? 14 A University of Colorado. 15 Q In what capacity did you do post-graduate? 16 A I started out a master's program and left that 17 for a job. 18 Q Okay. And what were you trying to get a 19 master's in? 20 A Accounting. 21 Q And from the language you're using, I take it 22 that you did not get a master's degree? 23 A I did not. 24 Q But you took courses towards it? 25 A I took some courses in the master's program. Page 7 Veritext Florida Reporting Co. 800-726-7007 305-376-8800 1 Q Okay. Anything else besides accounting that 2 you took courses in master's area? 3 A No. 4 Q All right. Once you -- you said you left 5 because of a job? 6 A Yes. 7 Q And what job was that? 8 A I went to work for Hand Miller & Associates. 9 Q In what capacity? 10 A At the time they were called Landman Oil and 11 Gas Industry. 12 Q Can you spell that, please, Laman? 13 A Landman. 14 Q Oh, Landman. 15 A One word. 16 Q All right. So they were in the gas industry? 17 A They were a contractor providing services to 18 gas industries, yes. 19 Q And how did you assist them? 20 A I went out and researched legal records for 21 mineral ownership. 22 Q And how long did you have that job for? 23 A Year or two. 24 Q Okay. Did you do anything else for them 25 besides research legal records? Page 8 Veritext Florida Reporting Co. 800-726-7007 305-376-8800 1 A No. 2 Q Okay. Where did you work after that? 3 A That's a long time ago. 4 Q Approximately. Okay. Well, we know that you 5 go back 25 years in the banking industry from what 6 you've told us so far. 7 A I think that's when I went to work. 8 MR. SCHWARTZ: Don't guess if you don't know. 9 A Yeah. I don't know the order anymore. 10 Q Okay. Without knowing the order, can you tell 11 me where -- if you had any other jobs before you entered 12 the banking industry? 13 A I worked at JP -- JC- -- 14 Q JCPenny's? 15 A Penny's. 16 Q Okay. 17 A Yes. I worked at JCPenny's for a little while. 18 Q In what capacity? 19 A Sales. 20 Q And do you know approximately how long you 21 worked for JCPenny? 22 A Maybe a year. 23 Q Okay. And did you have any other jobs before 24 you got into the banking industry? 25 A Just the normal ones, you know, growing up. Is Page 9 Veritext Florida Reporting Co. 800-726-7007 305-376-8800 1 that what you're interested in? 2 Q I'll tell you what -- 3 A Sixteen-year-old I was a bus girl. 4 Q I'm going to let you go for precollege. We 5 don't need to know that. 6 A Okay. All right. 7 Q Just simply post college. Anything else before 8 you got into the banking industry? 9 A No, not that I can think of. 10 Q Okay. Before we get into your banking 11 history -- 12 A Excuse me. I was in the insurance. I was 13 account executive for a health insurance company right 14 after college, Peak Health. 15 Q Peak, P-e-a-k? 16 A Uh-huh. 17 Q And as an account executive, what were your 18 duties? 19 A Sales. 20 Q And was that in Colorado also? 21 A That was in Colorado. 22 Q What city? 23 A Colorado Springs. 24 Q What about for Hand Miller & Associates? Where 25 was that located? Page 10 Veritext Florida Reporting Co. 800-726-7007 305-376-8800 1 A That was in Denver, Denver, Colorado. 2 Q And JP -- JCPenny? 3 A That was Stockton, California. That would be 4 the third in the list. 5 Q Got it. So we're getting some clarity here. 6 Without telling me what was said, did you 7 prepare for this deposition with anybody? 8 A I met with Roland and Jonathan yesterday. 9 Q All right. And other than meeting with them 10 yesterday, did you meet with anybody? Was that the 11 first time? 12 A It was. 13 Q In preparation for this deposition. 14 A The first time we met for this deposition, yes. 15 Q All right. And approximately how much time did 16 you spend preparing? 17 A Two hours. 18 Q Okay. Did you review any of the documents with 19 reference to Mr. Orozco in your preparation? 20 A I saw the note. 21 Q Okay. 22 A And that's it. 23 Q All right. Okay. Back to your work history. 24 You say that you go back 25 years. Who was your first 25 job with, if you recall? Page 11 Veritext Florida Reporting Co. 800-726-7007 305-376-8800 1 A American Savings Bank. 2 Q And where were they located? 3 A Stockton, California. 4 Q In what capacity did you start working for 5 them? 6 A I was in the records area where files were 7 moved in and out of records. 8 Q And what did you do with regards to the 9 records, if anything? 10 A I was a supervisor. I supervised a team of 11 people responsible for tracking files as they were 12 shipped in, as they came in and shipped out. 13 Q Okay. And as a supervisor of the team, what 14 types of things would they do? 15 A They looked at images that came through from 16 the files to make sure that they were quality checked 17 and jacketed them. 18 Q Right. 19 A Meaning they cut them, put them into jackets. 20 In terms of the shipping, we would write transmittals of 21 files in boxes and ship them to secure storage. 22 Q When the files came in, would you make copies 23 of notes and things of that nature and copies of the 24 loan? 25 A No. Page 12 Veritext Florida Reporting Co. 800-726-7007 305-376-8800 1 Q Would there be any records made of the notes as 2 they came in? 3 A That was not an area I was involved in. I 4 really can't speak to that. 5 Q Okay. So as far as taking care of the files, 6 what would your team do? 7 MR. SCHWARTZ: I'll object as to relevance, 8 but go ahead. 9 Q Go ahead. 10 A They were the credit files. And they simply -- 11 our job was to box them and send them to shipping after 12 the images had been verified and jacketed. 13 Q Okay. What images are you referring to? 14 A Of the loan files. 15 Q All right. And so images would be made 16 elsewhere and you would check to make sure that they 17 were accurate? 18 MR. SCHWARTZ: We make a standing objection as 19 to what specifically she did at that bank so I don't 20 have to interrupt you. 21 MR. WRUBEL: That's fine. 22 A Yes. The files were imaged somewhere. They 23 came in and rolled the film. Those rolls of films were 24 reviewed, cut, and jacketed for each borrower. 25 BY MR. WRUBEL: Page 13 Veritext Florida Reporting Co. 800-726-7007 305-376-8800 1 Q Right. 2 A And then once that was done, then the credit 3 file is boxed up and shipped out. 4 Q Okay. And just so I can be clear, when you say 5 films, are we talking microfilm? 6 A Yes. 7 Q And so there would be a microfilm of the note 8 as it came in? 9 A I don't know if the note was in that or not. 10 Q I understand. But it would be loan documents 11 that would be filmed? 12 A Credit file was -- we dealt with the credit 13 file, and that's what was imaged and that we worked 14 with. 15 Q All right. And when you're referring to the 16 credit file, what would normally be in that? 17 A Everything except the letter. 18 Q Okay. But I need to know what everything is. 19 A Underwriting documents, your -- your loan 20 application, tax forms. 21 Q Okay. In other words, records that were 22 provided by the borrower or forms that they filled out 23 in the process of getting the loan? 24 A Correct. 25 Q Anything else besides those types of documents? Page 14 Veritext Florida Reporting Co. 800-726-7007 305-376-8800 1 A Generally what's in a credit file. 2 Q Okay. And I apologize. I'm just not an expert 3 in this area. 4 A That's all right. 5 Q So you're going to have to tell me as we go 6 through this. 7 And how long did you supervise these teams that 8 were doing this work for American Savings? 9 A Year, year and a half. 10 Q Okay. And where were you working at that time? 11 A Stockton, California. 12 Q Was that the headquarters of American Savings 13 at the time? 14 A Yes, it was. 15 Q All right. And you mentioned that we go back 16 25 years. So are we talking about approximately 1987, 17 in that area, 1988? 18 A Yes. 19 Q Okay. What did you do after the year and a 20 half of supervising the team that were reviewing credit 21 files and checking credit files? 22 A I moved into a group of trainers and became a 23 trainer. 24 Q All right. So you actually trained other 25 individuals? Page 15 Veritext Florida Reporting Co. 800-726-7007 305-376-8800 1 A Yes. 2 Q In what capacities? 3 A We were responsible for training of any 4 employee at American Savings Bank, so... 5 Q Regardless of their responsibilities? 6 A Right. We wrote training material from 7 procedures, things like that. And then we trained new 8 employees. 9 Q Were you the head of that team as well? 10 A No. 11 Q Who was, if you recall? 12 A Karen Moran. 13 Q Good memory. 14 And how long did you do training for? 15 A Maybe a year, year and a half. 16 Q Okay. What did you do after you did the 17 training? 18 A Went to a supervisor in customer service. 19 Q And what does that job entail? 20 A That's a call center. Borrowers calls in, and 21 the team would respond to the questions. 22 Q For customers? 23 A Yes. 24 Q Okay. How long did you do that for 25 approximately? Page 16 Veritext Florida Reporting Co. 800-726-7007 305-376-8800 1 A Couple years. 2 Q And you're still with American Savings at this 3 point? 4 A Yes. 5 Q Okay. Was American Savings acquired by 6 anybody? 7 A Later Washington Mutual, yes. 8 Q What was the next thing that you did for 9 American Savings after you supervised in the customer 10 service center? 11 A Tax and insurance supervisor. 12 Q And what does that entail? 13 A Making sure the tax escrow account, making sure 14 taxes get paid, forced order insurance, dealing with 15 correspondence regarding forced order insurance -- 16 Q Okay. 17 A -- tracking, placement. 18 Q And were you doing the physical work, or were 19 you again supervising? 20 A I'm supervising. It is work. 21 Q Pardon me? 22 A That's work as well. 23 Q I understand. We all understand that. 24 And how long did you supervise in the tax and 25 insurance area? Page 17 Veritext Florida Reporting Co. 800-726-7007 305-376-8800 1 A Probably a couple years. 2 Q What was your next position with American 3 Savings? 4 A Purchase servicing. 5 Q What does purchase servicing do? 6 A It was a -- a team of individuals that 7 coordinated the service transfers and bringing them on 8 board to the servicing systems. 9 Q Okay. When we're talking about service 10 transfers, are we talking about loans that are being 11 serviced by American Savings? 12 A No. We're talking about loans serviced by 13 somebody else that American Savings bought the servicing 14 and that American Savings was going to service. 15 Q So American Savings was doing the servicing 16 work? 17 A After it was moved on board, yes. 18 Q Right. 19 A My job as purchase servicer was to get those 20 loans on board, yes. 21 Q All right. And so you would go to other 22 entities to purchase the servicing rights to the loans; 23 am I understanding you correctly? 24 A I did not. The bank did that activity where 25 they purchase a servicing of loans and then moved it Page 18 Veritext Florida Reporting Co. 800-726-7007 305-376-8800 1 over to mark in savings for servicing. 2 Q Okay. And your responsibilities would be? 3 A When the deal was -- was arranged and done, all 4 of the due diligence was done. My job was coordination 5 of all the departments and the information that had to 6 come in order to make that transfer happen. 7 Q Okay. And what types of departments are we 8 talking about that had to be brought on board? 9 A Every department is affected, so your 10 foreclosures, collections, modifications, payments, 11 customer service. Every loan servicing department is 12 generally affected by a purchase. 13 Q Okay. And, again, just so I'm clear on your 14 responsibilities, they were to make sure that the 15 records were transferred over to you so you could 16 effectively take care of the servicing obligations? 17 A That's correct. It could be the records, yes. 18 It's data records. It could be files. Uh-huh. 19 Q All right. So there'd be physical files that 20 were brought on board as well? 21 A Yes. 22 Q What types of physical files would be brought 23 on board? 24 A The credit file. 25 Q Okay. Page 19 Veritext Florida Reporting Co. 800-726-7007 305-376-8800 1 A Collateral files could be part of the deal. 2 Q And what would be in the collateral files? 3 MR. SCHWARTZ: Object as to relevance, again, 4 but go ahead. 5 A Notes, sometimes title policies, deeds. 6 Q And when notes were brought on board, would 7 they be stored in a central location? 8 MR. WEISS: Objection to the form of the 9 question. 10 Q You can answer. 11 A If they go to a vault. 12 Q Okay. And did American Savings have more than 13 one vault that they would go to? 14 A At that time, no. 15 Q And where was the vault located? 16 A In the basement. 17 Q In Stockton? 18 A In Stockton. 19 Q What types of entities was American Savings 20 purchasing servicing rights from? 21 A I can't really speak to that. I don't know 22 that. 23 Q You didn't know where they were coming from, 24 the loans? 25 A I would know -- at the time I would know the Page 20 Veritext Florida Reporting Co. 800-726-7007 305-376-8800 1 servicer we were getting the loans from. 2 Q Okay. 3 A Whether -- when you ask the entities, I don't 4 know if you're -- is that asking who owned the loans? I 5 don't know. I only know that we would service transfer 6 loans in, and at that time I would have known the 7 companies that we were getting them from. 8 Q Okay. I may be confused. But just so I'm 9 clear on this, would you all be getting the servicing 10 rights from other servicers or from entities that had 11 just freshly issued the loans or both? 12 A We did both. 13 Q Okay. And how long did you do the purchasing 14 of the -- 15 MR. WEISS: I'm going to object, Mike. We've 16 spent 20 minutes talking about her job 17 responsibilities for a job 25 years ago. If you 18 want to get to something that's relevant, let's do 19 that, but at this pace we're going to be here all 20 day. 21 MR. SCHWARTZ: I'll join in that objection. I 22 mean, I already have a standing objection as to 23 relevance. We're talking about American Savings 24 Bank, has nothing to do with this case whatsoever. 25 Obviously I can't instruct her not to answer at this Page 21 Veritext Florida Reporting Co. 800-726-7007 305-376-8800 1 point; but at some point, you know, if we continue 2 for the next 20 minutes about irrelevant stuff, 3 we'll consider it. Go ahead. 4 MR. WRUBEL: It's up to you. 5 BY MR. WRUBEL: 6 Q How long did you do purchasing and servicing 7 for? 8 A I want to say a number of years in that that 9 job would evolve. 10 Q Okay. 11 A As -- so I want to say it was probably several 12 years. 13 Q Okay. And when you say the job evolved, did 14 the responsibilities change? Is that what you're 15 referring to? 16 A Departments changed or grew, absorbed into 17 other departments, things like that. 18 Q Okay. And what did you do after the purchasing 19 and servicing? 20 A Purchase and servicing is more title. That was 21 really a department and a function that I was then 22 involved in up until November of 2006 then. 23 Q Okay. And I take it you're saying that your 24 responsibilities remained in servicing until November of 25 2006? Page 22 Veritext Florida Reporting Co. 800-726-7007 305-376-8800 1 A In servicing, that's correct, yes. 2 Q Okay. What other responsibilities did you have 3 that we haven't talked about in servicing? 4 A That's -- that's pretty much the history. I 5 was in that department. 6 Q Okay. 7 A I grew with them. I did have other 8 responsibilities. 9 Q That's what I'm trying to understand. I'd like 10 to know what your history of your responsibilities were 11 in servicing. 12 A All right. 13 MR. WEISS: Object to the form of the question. 14 Vague and ambiguous as to the time period. 15 Q Okay. Let's take our time, then. 16 A Okay. 17 Q We'll take our time, then. We'll do it 18 chronologically. Please advise me how your servicing 19 responsibilities evolved from a chronological 20 standpoint. 21 A Oh, I stayed in a department. It was -- became 22 secondary delivery operations. The purchase of 23 servicing and movement of whole loan sales and so on 24 occurred in that department, along with -- and that's 25 what my -- my functions were, related to that. Page 23 Veritext Florida Reporting Co. 800-726-7007 305-376-8800 1 Then I took on, in Stockton, the note review 2 unit and team and was also involved in special projects 3 outside of those functions. 4 Q Okay. What were your responsibilities with 5 regards to the movement of home loan sales? 6 A Whole loan sales. 7 Q Whole loan. I'm sorry. What does whole loan 8 sales mean? 9 A The loan file is sold along with the servicing. 10 Again, the -- the files would be collected. The 11 collateral would be collected and shipped to servicers, 12 purchasers of that. 13 Q Okay. And we're saying whole loans -- whole 14 loans were sold. I presume you're saying that the notes 15 as well as the servicing rights were sold? 16 A Yes. 17 MR. SCHWARTZ: Object. Calls for a legal 18 conclusion. Go ahead. 19 A Yes. 20 Q And these were loans that were originated by 21 American Savings or -- or WaMu? 22 A It could have been a combination of originated 23 or not originated by American Savings. 24 Q Okay. And I think you understand when I say 25 WaMu we're referring to Washington Mutual? Page 24 Veritext Florida Reporting Co. 800-726-7007 305-376-8800 1 A Yes. 2 Q And you also indicated that you were involved 3 in Stockton with note review? 4 A Yes. 5 Q And what were your responsibilities with regard 6 to note review? 7 A I supervised the unit that did note review. 8 Q And what were their responsibilities with 9 regards to note review? 10 A They would ensure that the data that came on 11 the note matched what was on our servicing systems. 12 Q Do you know who would input that data? 13 A The data was not inputted. It came from our 14 originations systems and were fed to our servicing 15 systems. 16 Q Okay. And, I mean, what I'm trying to 17 understand is was it fed electronically, or was there 18 paper data? 19 A We got electronic data. 20 Q Okay. And -- 21 A And we had the note. 22 Q And do you know who inputted the electronic 23 data? 24 A The origination centers. 25 Q Okay. And back when you first took over these Page 25 Veritext Florida Reporting Co. 800-726-7007 305-376-8800 1 responsibilities, was American Savings located in 2 anywhere besides California? 3 A I -- 4 MR. SCHWARTZ: If you know. 5 Q If you know. 6 A If we're -- if it's American Savings was 7 California only, I -- I don't remember when Washington 8 Mutual would have taken over, and I don't remember when 9 that -- it was seamless to me. I had the same job 10 functions. 11 Q Okay. 12 A So I can't answer that. I don't know if that 13 was Washington Mutual or American Savings at that 14 particular time. 15 Q Okay. I take it what you're saying, then, is 16 when it was American Savings alone, that was only in 17 California; but when WaMu acquired American Savings, it 18 became multi- -- 19 MR. WEISS: Objection. Misstated her prior 20 testimony. I think she said she didn't know for 21 sure. 22 A I -- I don't know for sure that American 23 Savings was only in California. 24 Q Okay. 25 A I know for sure that Washington Mutual was Page 26 Veritext Florida Reporting Co. 800-726-7007 305-376-8800 1 bigger than California. 2 Q Got you. 3 A Okay. 4 Q And you've indicated you don't know when 5 Washington Mutual acquired American Savings? 6 A No. 7 Q I don't want you to guess, but do you have any 8 range or idea? 9 MR. SCHWARTZ: Asked and answered. Go ahead. 10 A I really don't. 11 Q Okay. 12 A '89. I don't know. 13 MR. SCHWARTZ: Don't guess. 14 THE WITNESS: Okay. Thank you. 15 BY MR. WRUBEL: 16 Q All right. With reference to the notes that 17 were originated, they would be brought to Stockton? 18 MR. WEISS: Object to the form. Vague and 19 ambiguous. 20 A Yes. 21 Q Okay. And let me rephrase the question. How 22 did -- how were the notes originated that came to 23 Stockton, California, with American Savings? 24 A I don't understand the question. Say that 25 again, please. Page 27 Veritext Florida Reporting Co. 800-726-7007 305-376-8800 1 Q What entities would originate the notes that 2 would come to Stockton, California, that you would 3 review? 4 A American Savings. 5 Q Okay. Anybody besides American Savings 6 initially? 7 MR. WEISS: Object to the form. 8 A I can't -- I don't know for sure. My unit 9 reviewed American Savings. 10 Q Okay. And what things would they review with 11 regards to the notes and the loans? 12 A The data in the notes, the term, maturity date, 13 borrower name, address, that it's all correct, matching 14 the system. 15 Q Okay. Anything that your team would do besides 16 making sure that all the information matched? 17 A And -- in Stockton? 18 Q Yes. 19 A The notes were endorsed, and they were shipped 20 to the custodian. 21 Q Okay. And where was the custodian located? 22 A In the same building. 23 Q All right. And when you say that the notes 24 were endorsed, are we going -- approximately what year 25 are we going back to approximately, if you know? Page 28 Veritext Florida Reporting Co. 800-726-7007 305-376-8800 1 A Prior to 2004. 2 Q Do you know how long before 2004? 3 A No. 4 MR. WEISS: Object to the form. Are you asking 5 her for what period of time were notes endorsed, or 6 are you asking her -- 7 MR. WRUBEL: I'm trying to -- I'm trying to 8 ascertain at what point in time they began endorsing 9 notes when they came into the Stockton facility. 10 MR. WEISS: Who's they? 11 MR. WRUBEL: Her team. 12 MR. WEISS: So you're asking her when she 13 worked in note review, when did people start 14 endorsing notes? 15 MR. WRUBEL: Effectively yes. 16 A I don't think that's one and the same. I 17 did -- I was the supervisor for that unit sometime 2002 18 I would say. 19 BY MR. WRUBEL: 20 Q Okay. 21 A We were endorsing the notes at that time. 22 Q All right. So you're saying back in 2002 your 23 team that was reviewing the data were also endorsing the 24 notes? 25 A Yes. Page 29 Veritext Florida Reporting Co. 800-726-7007 305-376-8800 1 Q All right. And do you know if notes were 2 endorsed before 2002 when they came into your -- 3 A I would only be guessing. 4 Q Okay. And -- but you are certain that in 2002 5 notes that were being reviewed for data were also being 6 endorsed when they came through your unit -- 7 A Correct. 8 Q -- as supervisor? 9 A Correct. 10 Q Okay. And how were the notes endorsed? 11 A They were endorsed with an endorsement stamp. 12 Q Okay. And whose signature would be on the 13 endorsement stamp? 14 A Jess Alamanza. 15 Q Can you spell that, please? 16 A A-l-a-m-a-n-z-a. 17 Q Okay. And were these blank endorsements, or 18 were they specific endorsements? 19 MR. WEISS: Object to the form of the question. 20 MR. SCHWARTZ: I'll join. It's irrelevant. Go 21 ahead. 22 A That was a blank endorsement. 23 BY MR. WRUBEL: 24 Q Okay. And you indicated that it was placed 25 there with a stamp? Page 30 Veritext Florida Reporting Co. 800-726-7007 305-376-8800 1 A Yes. 2 Q Okay. Jess Alamanza was whom? 3 A My boss. 4 Q Okay. And what was his position? 5 A VP secondary delivery operations. 6 Q And was there more than one stamp that was 7 being used? 8 A No. 9 Q Do you know how many people were using that 10 stamp? 11 A I don't remember specifically. 12 Q Okay. Do you recall approximately how many 13 people were in the team that you supervised? 14 MR. SCHWARTZ: I'll object, again. Relevance. 15 Thirty minutes now we have not talked about 16 Ms. Riley's endorsement or signature. It's been 17 30 minutes. 18 MR. WRUBEL: That's fine. 19 BY MR. WRUBEL: 20 Q You can answer. 21 A Ten to twelve. 22 Q And, to your knowledge, would all 10 to 12 be 23 using the endorsement stamp? 24 A I don't remember if we had 10 to 12 doing the 25 endorsements at that time. Page 31 Veritext Florida Reporting Co. 800-726-7007 305-376-8800 1 Q Okay. And the time we're talking about is in 2 2002? 3 A It is while I supervised that unit. 4 Q And the time that you supervised that unit was 5 what period of time? 6 A I'm saying it should be around 2002, 2004 to 7 then. 8 Q Do you recall the names of anybody in that team 9 that was using the Jess Alamanza stamp? 10 A No. 11 Q And you indicated that once the notes were 12 endorsed they'd be sent to the custodian? 13 A Correct. 14 Q All right. And I take it the custodian would 15 place the notes in the vault? 16 A That's correct. 17 Q Did the custodian have any other 18 responsibilities, to your knowledge? 19 MR. SCHWARTZ: Don't guess. 20 A I -- I don't know what their responsibilities 21 would be. 22 Q Okay. Were you yourself endorsing any of 23 the -- any of the notes? 24 MR. WEISS: Object to the form of the question. 25 Q You can answer. Page 32 Veritext Florida Reporting Co. 800-726-7007 305-376-8800 1 A I was not endorsing those notes, no. 2 Q Okay. And you weren't using the Jess Alamanza 3 stamp to endorse the notes either personally? 4 A I was not. 5 Q Okay. While you were in Stockton -- by the 6 way, how long were you in Stockton till? 7 A 2004. 8 Q Do you know what month? 9 A June. 10 Q So until June 2004 the only endorsement stamp 11 that was used in the Stockton area was the Jess Alamanza 12 stamp? 13 MR. SCHWARTZ: Form. Leading. 14 A The Jess Alamanza stamp was used in Stockton 15 prior to that. Uh-huh. 16 Q Okay. Did you ever have a stamp that was used 17 in the Stockton area? 18 A No. 19 Q What happened in June 2004? 20 MR. WEISS: Object to the form of the question. 21 Vague and ambiguous. 22 MR. SCHWARTZ: I'll join. Many things happened 23 in 2004, but go ahead. 24 A I moved to Jacksonville, Florida. 25 BY MR. WRUBEL: Page 33 Veritext Florida Reporting Co. 800-726-7007 305-376-8800 1 Q Okay. As far as moving, were you requested to 2 make the move? 3 A Yes. 4 Q By whom? 5 A My manager. 6 Q And who was your manager? 7 A Brenda Brendle. 8 Q I'm sorry? 9 A Brenda Brendle. 10 Q And do you know what her title was? 11 A Vice president, first vice president. 12 Q Of -- at that time I presume it's WaMu? 13 A Yes. 14 Q Okay. And do you know if she's still with 15 JP Morgan? 16 A She is not. 17 Q Do you know where she is at this time? 18 A She's -- she's in Jacksonville. 19 Q Do you know if she's working for anyone? 20 A She's working. 21 Q For whom? 22 A I can't think of their name right now. 23 Q Okay. Is it a bank or credit agency or -- 24 A It's a mortgage company. 25 Q Okay. And so you've indicated that Ms. Brendle Page 34 Veritext Florida Reporting Co. 800-726-7007 305-376-8800 1 requested that you be transferred? 2 A I was offered a relocation package. 3 Q Okay. Was Stockton closing or -- 4 A Yes, Stockton closed. 5 Q Okay. And when did Stockton close? 6 A January 2004, that -- that's when we were 7 notified that they were going to be shutting down. 8 Q Okay. And when did they actually shut down? 9 A Later 2004 I would... 10 Q And what was the relocation offer that was made 11 to you by Ms. Brendle? 12 MR. SCHWARTZ: Object. Proprietary 13 information. 14 MR. WEISS: Object to the form of the question. 15 Object on -- 16 MR. SCHWARTZ: Confidential. 17 MR. WEISS: -- privacy grounds. 18 MR. SCHWARTZ: Exactly. Join. 19 BY MR. WRUBEL: 20 Q Were you told what your duties would be with 21 respect to your relocation? 22 A I was promoted and -- 23 Q Okay. 24 A -- and took over the responsibilities of 25 secondary delivery operations in Jacksonville. Page 35 Veritext Florida Reporting Co. 800-726-7007 305-376-8800 1 Q When you say you were promoted, can you tell me 2 what part of the promotion was? I mean, was it title? 3 Was it money? 4 MR. WEISS: Object to the form of the question. 5 Objection on privacy grounds. 6 MR. SCHWARTZ: Privacy. Proprietary 7 information. Confidential. Go ahead. 8 A I was promoted to a vice president and became 9 the department manager for secondary delivery operations 10 in Jacksonville, Florida. 11 BY MR. WRUBEL: 12 Q And when did this promotion become effective? 13 A Effective date I don't know. 14 Q Okay. Do you know if it was while you're still 15 in Stockton, California, or Jacksonville? 16 A I was making a transition between January and 17 June of 2004. I was offered that job, travelled back 18 and forth, and moved here in June 2004. 19 Q And would June of 2004 or couple months before 20 then be the first time that you were ever a vice 21 president with the bank? 22 A Correct. 23 Q Are you still a vice president with the bank? 24 A I am not. 25 Q When did you cease being a vice president with Page 36 Veritext Florida Reporting Co. 800-726-7007 305-376-8800 1 the bank? 2 A 2008. 3 Q Do you know what month? 4 A January I would guess. 5 MR. SCHWARTZ: Don't guess. 6 A January 2008. 7 Q As a vice president did you have greater 8 authority than you had before they made you vice 9 president? 10 MR. WEISS: Object to the form of the question. 11 Vague and ambiguous. 12 MR. SCHWARTZ: Join. 13 BY MR. WRUBEL: 14 Q You can answer. 15 A I was managing a department as a vice president 16 versus leading a team. Responsibilities were different. 17 Q Okay. Briefly can you tell me what the 18 difference is between managing a team and leading a 19 team? 20 A Managing a department and leading a team? 21 Q Yes, please. 22 A The team is one piece of the department. The 23 department encompassed other responsibilities -- 24 Q Okay. 25 A -- than my responsibility in note review as it Page 37 Veritext Florida Reporting Co. 800-726-7007 305-376-8800 1 was as a team leader. 2 Q Okay. I recognize that it may vary. But when 3 you're managing a department, approximately how many 4 employees would be under your supervision? 5 MR. WEISS: Object to the form of the question. 6 Vague and ambiguous. 7 MR. SCHWARTZ: Overly broad as to what time 8 we're talking about. 9 A Thirty -- thirty to forty people. 10 BY MR. WRUBEL: 11 Q Okay. Did you manage any other departments 12 besides secondary delivery? 13 A No. 14 Q Okay. And how long did you manage secondary 15 delivery for? 16 A Till 11 of 2006. 17 Q And I take it you're saying you managed 18 secondary delivery approximately from June of 2004 to 19 November of 2006? 20 A Correct. 21 Q And during that period of time you had 22 approximately 30 to 40 employees under your supervision? 23 A Yes. 24 Q And tell us please what is secondary delivery? 25 A Secondary delivery operations, it was the name Page 38 Veritext Florida Reporting Co. 800-726-7007 305-376-8800 1 of the department. 2 Q Okay. 3 A Secondary -- sorry. It's the name of the 4 department, but we delivered on the deals that were made 5 by secondary marketing. 6 Q Okay. And when you say you delivered on the 7 deals that were made in secondary marketing, are we 8 talking about the fact that notes were sold to other 9 entities from American Savings? 10 MR. WEISS: Object to the form of the question. 11 Q You can answer. 12 A That, yes. 13 Q And other things? 14 A Loans sold to Freddie and Fannie. 15 Q Do you know what percentage of Washington 16 Mutual's loans were sold to Fannie and Freddie between 17 June of 2004 and November of 2006? 18 MR. WEISS: Objection. Object to the form of 19 the question. You're asking her what percentage of 20 WaMu originated loans were sold to Fannie and 21 Freddie? How is she possibly going to be able to 22 answer that question? 23 MR. WRUBEL: I don't know. If she can't answer 24 it, she can't answer that. 25 A I don't know that percentage. Page 39 Veritext Florida Reporting Co. 800-726-7007 305-376-8800 1 MR. SCHWARTZ: My issue is it's been 40 minutes 2 now. We haven't spoken about the note or the -- 3 MR. WRUBEL: I don't care that we haven't 4 spoken about the note. I've got a right to take a 5 deposition, and I'm going to take it. 6 MR. WEISS: You have a right to take a 7 deposition. 8 MR. WRUBEL: I don't care about 30, 40 minutes. 9 And you guys can keep interrupting if you want, but 10 we're 30, 40 minutes. And if this takes all day, 11 it's going to take all day. 12 MR. SCHWARTZ: Well -- 13 MR. WRUBEL: But I absolutely have a right to 14 get background and everything that I'm getting. 15 MR. SCHWARTZ: Background -- background is one 16 thing, and I didn't object as to background. But 17 when you started talking about what specifically was 18 done at American Savings by whom, what relevance 19 does it have to this case? I'm just struggling with 20 that. 21 MR. WRUBEL: I'm trying to learn what her 22 background was. All right. We're beyond that. So 23 if you want to keep talking about that and wasting 24 time, then you can object to it. 25 MR. SCHWARTZ: No, I won't, but -- Page 40 Veritext Florida Reporting Co. 800-726-7007 305-376-8800 1 MR. WRUBEL: We're -- 2 MR. SCHWARTZ: -- I have a right to object, and 3 I will. 4 MR. WRUBEL: -- into the note. We're into the 5 note. We're into endorsements. And I intend to 6 thoroughly explore the area. 7 MR. SCHWARTZ: I told you what my objection is. 8 Go ahead. 9 MR. WRUBEL: Okay. 10 A Was there a question? 11 BY MR. WRUBEL: 12 Q Yes. I'll rephrase the question. You were 13 passing loans to the secondary market, and you've 14 indicated that Freddie and Fannie included some of 15 the -- 16 MR. WEISS: Object to the form of the question. 17 Vague and ambiguous as respects passing loans. 18 A We -- we sold loans for Freddie and Fannie. 19 The actual percentage I have -- I do not know. The bulk 20 of our work was sold to Freddie and Fannie. 21 Q Okay. And that's where my question goes. As 22 far as the bulk of your work going to Freddie and 23 Fannie, were there also private investors besides 24 Freddie and Fannie that were buying loans in the 25 secondary market? Page 41 Veritext Florida Reporting Co. 800-726-7007 305-376-8800 1 A Yes. 2 Q Okay. And those entities would be entities 3 such as? 4 A Lehman comes to mind, Ocwen comes to mind, 5 Bayview. 6 Q Deutsche Bank, Goldman Sachs. 7 A GMC. I don't remember Deutsche Bank. I 8 don't -- I don't know Sachs. 9 Q Okay. All right. And my question to you is 10 with regards to Washington Mutual, if you know: Of all 11 the loans that were being sold on the secondary 12 delivery, you said that the bulk of them went to Fannie 13 and Freddie; is that correct? 14 MR. WEISS: Object -- 15 MR. SCHWARTZ: Form. 16 MR. WEISS: -- to the form of the question. 17 You're asking her about when she was working in the 18 secondary delivery operations department from June 19 2004 until November of 2006 if she knew that the 20 bulk of the loans that came in through that 21 department went to Fannie and Freddie. 22 MR. WRUBEL: That's what she testified to. 23 MR. WEISS: I just want to be clear, she's not 24 talking about WaMu originated the loan -- 25 MR. WRUBEL: No. Page 42 Veritext Florida Reporting Co. 800-726-7007 305-376-8800 1 MR. WEISS: -- generally. 2 MR. WRUBEL: No. I'm just talking about -- 3 MR. WEISS: That's the way you asked the 4 question. 5 A The bulk of the loans were sold to Freddie and 6 Fannie. 7 BY MR. WRUBEL: 8 Q And when you say the bulk of the loans, 9 approximately what percentage are you talking about? 10 A I can't speak to percentage. I don't know 11 that. 12 Q All right. When you say the bulk, you know if 13 we're talking more than 50 percent or less than 50 14 percent? 15 MR. SCHWARTZ: Form. Speculative. Asked and 16 answered. Go ahead. 17 A I don't know that. 18 Q Okay. Did you review any screens with regards 19 to Mr. Orozco's loan before -- 20 MR. SCHWARTZ: Form. 21 Q -- coming into this deposition? 22 MR. SCHWARTZ: Vague and ambiguous. Go ahead. 23 A Are you -- if I personally? 24 Q Yeah. Yes. 25 A No, I did not. Page 43 Veritext Florida Reporting Co. 800-726-7007 305-376-8800 1 Q All right. And you understand when I say 2 screen, I'm talking about computer screens? 3 A Yes. 4 Q Okay. And you indicated you personally did not 5 for this deposition; correct? 6 A I did not review that note personally to a 7 screen. 8 Q Okay. You only reviewed the note? 9 A I didn't review the note. 10 MR. WEISS: Objection. Are you talking about 11 contemporaneously with the origination of the loan, 12 or are you talking about since then? 13 MR. SCHWARTZ: Yeah. I'm confused. Are you 14 talking in preparation for deposition? Can you put 15 some time frame on it? 16 MR. WRUBEL: I asked -- if you want her to read 17 it back -- the question was -- 18 MR. SCHWARTZ: Yeah, please, because I'm 19 confused. 20 MR. WRUBEL: Well, the question was -- 21 THE WITNESS: I'm confused now. 22 MR. WRUBEL: The question was before -- I mean, 23 you guys can keep interrupting, but the question was 24 for the deposition. And if you want her to read it 25 back, she can. Page 44 Veritext Florida Reporting Co. 800-726-7007 305-376-8800 1 MR. SCHWARTZ: Oh, she already answered that at 2 the beginning of the -- 3 A In the beginning I saw the note. Yesterday I 4 did not review it. 5 BY MR. WRUBEL: 6 Q Okay. And I asked about screens. And I did 7 not ask about screen before. 8 MR. WRUBEL: But if you guys want to keep 9 interrupting, just go ahead. 10 MR. WEISS: Mike -- 11 MR. WRUBEL: We can take this deposition as 12 long as we want. 13 MR. WEISS: It's not about interrupting. You 14 can read back the record if you want. What you said 15 was very unclear. You asked if she'd seen any 16 screens in connection with the note. We made 17 objections as to form because it was vague and 18 ambiguous. You later asked a follow-on question 19 where you said in preparation for this deposition. 20 MR. WRUBEL: Yeah. 21 MR. WEISS: It's absolutely unclear if you were 22 talking about contemporaneously with the origination 23 with the loan if she viewed any screens that 24 reflected any information about the note or if in 25 the context of preparing for deposition she viewed a Page 45 Veritext Florida Reporting Co. 800-726-7007 305-376-8800 1 screen that reflected any information about this 2 note. So let's make it clear. 3 MR. WRUBEL: Well, the record speaks for 4 itself. 5 MR. WEISS: That's right. It's absolutely 6 unclear. 7 MR. SCHWARTZ: And we've objected, so go ahead. 8 BY MR. WRUBEL: 9 Q All right. With regards to your work here in 10 Jacksonville between June of 2004 and November of 2006, 11 what types of things would you supervise being done in 12 order for loans to be sold to the secondary market? 13 MR. WEISS: Object to the form of the question. 14 A The unit -- I managed one of the units related 15 to the notes that -- the notes comes in the door. It's 16 reviewed for accuracy and moved to the custodian. It's 17 endorsed and moved to the custodian. That was one of 18 the units in secondary delivery operations. 19 Q Is there a name for that unit? 20 A The note review unit. 21 Q Okay. Were there other things that were done? 22 A Done to what? 23 Q In order to process the loans so they could be 24 sold on a secondary market. 25 A We cured loans that -- something was wrong with Page 46 Veritext Florida Reporting Co. 800-726-7007 305-376-8800 1 the note, for example. We cured that. 2 Q Okay. 3 A I had a unit that would find a cure for that. 4 Q And when you say cure, can you elaborate on 5 what you mean? 6 A The borrower may not have signed. They signed 7 the note different from the typed name on the note. 8 That would be corrected. 9 Q Okay. 10 A Is an example. 11 Q Any other examples? 12 A Not coming to mind. 13 Q What other things were done in order to process 14 the loan so that they could be sold on the secondary 15 market that you would supervise or manage? 16 A That would be the answer to that question. We 17 did the note review. We ensured the accuracy and sent 18 them to the custodian. 19 Q Okay. And would anything be done to the notes 20 while they were in your unit or in your department? 21 A Anything -- 22 MR. SCHWARTZ: Form. Asked and answered. 23 A -- else? 24 MR. SCHWARTZ: Go ahead. 25 Q Yes. Page 47 Veritext Florida Reporting Co. 800-726-7007 305-376-8800 1 A They were reviewed. They were reviewed. They 2 were checked to the system for accuracy. They were 3 moved to the custodian. And they were endorsed. 4 Q Okay. So they were endorsed when they were in 5 your department as well? 6 A That's correct. 7 Q Okay. And who were they endorsed by? 8 A It was a facsimile signature stamp that was 9 used for the endorsements on the note. 10 Q Okay. But who would be the ones that would be 11 using the facsimile stamp? 12 A My staff. 13 Q All right. And how many people were in your 14 staff that were endorsing notes? 15 A Ten to twelve. 16 Q Do you remember the names of any of those 17 people? 18 A Not particularly that were endorsing the notes, 19 no. 20 Q Okay. What was the name of the -- the name of 21 the unit if I were to try to acquire the names of the 22 people that were in this unit? 23 A Note review unit. 24 Q Okay. And would all 10 to 12 people that were 25 in the note review unit have authority -- or strike Page 48 Veritext Florida Reporting Co. 800-726-7007 305-376-8800 1 that. 2 Would all 10 to 12 people that were in the unit 3 be using that facsimile stamp? 4 MR. WEISS: Object to the form of the question. 5 Vague and ambiguous. 6 A They certainly could in doing their job would 7 use that stamp. That's right. 8 Q Okay. 9 A They were a note reviewer. They would use that 10 stamp in their note review process. 11 Q All right. And I -- you're saying that stamp. 12 There's only one stamp? 13 A No. There was multiple stamps, nine to ten 14 stamps. 15 Q And the stamps had your name on it? 16 A Yes, my signature. 17 Q Do you know when the stamps were made? 18 A Not exactly. 19 Q I take it would have been sometime after 20 June 2004? 21 A Sometime in that range, yes. I don't know that 22 it was after June 2004. 23 Q Okay. And with regards to the stamp, did you 24 provide a signature for the stamps? 25 A Yes, I did. Page 49 Veritext Florida Reporting Co. 800-726-7007 305-376-8800 1 Q Did you provide more than one signature for the 2 stamps? 3 A I don't remember that process, whether I signed 4 multiple times or once. I don't know what the creator 5 of stamps needs. 6 Q Do you know if the stamps were secured when 7 they were not being used? 8 A We had full procedures around the security of 9 those stamps, and they were in a secured location 10 requiring card access only by the collateral note review 11 people. 12 Q And when you say that you had full security and 13 procedures, can you elaborate on what those were? 14 A The procedures, they were in a locked cabinet. 15 The lead manager of that unit would unlock the cabinets. 16 In the morning the stamps would be checked out on a log. 17 They would be used as the representative needed to do 18 during the day. At the end of the night they were 19 checked back in and logged back in to the secured 20 cabinet. And, again, the room that the note review 21 occurred in was a secured access only. 22 Q Was there more than one lead manager to this 23 team? 24 A I had a manager over that team. She had a 25 lead. Page 50 Veritext Florida Reporting Co. 800-726-7007 305-376-8800 1 Q Okay. And what -- who is that manager? 2 A Pat Eyles. 3 Q Can you spell the last name, please? 4 A E-y-l-e-s. 5 Q And is Pat male or female? 6 A Female. 7 Q Is she still with JP Morgan? 8 A Yes. 9 Q Here in Jacksonville? 10 A Yes. 11 Q And you've indicated that there was a secure 12 room where the note review would take place; is that 13 correct? 14 A Yes. 15 Q Can you elaborate on what -- how that was set 16 up? 17 A It's a partitioned off area, work area, that we 18 were in, and the doors to that were secured. You had to 19 have special card access to get in. 20 Q Again, was this a blank -- strike that. 21 With regards to the endorsement stamp, was it a 22 blank endorsement? 23 A Yes, it was. 24 Q To your knowledge, were the stamps always the 25 same as far as the facsimile signature of yours? Page 51 Veritext Florida Reporting Co. 800-726-7007 305-376-8800 1 MR. WEISS: Object to the form of the question. 2 MR. SCHWARTZ: I join. What time period are we 3 talking about? 4 MR. WRUBEL: We're always talking about from 5 June -- June 2004 to November of 2006 right now. 6 A The stamps -- I don't know if they were always 7 the same. The facsimile signature, I don't have any 8 reason to think that they wouldn't have been the same on 9 a facsimile signature stamp. 10 BY MR. WRUBEL: 11 Q Okay. Excuse me one sec. 12 With regards to the notes once they were 13 endorsed, where would they go after they left that room? 14 A To the custodian. 15 Q And do you know what the custodian would do 16 with the notes? 17 A Put them in the vault. 18 Q Okay. And was there more than one vault that 19 they would be put in? 20 A The notes that came through Jacksonville, 21 Florida, they were -- there were different custodial 22 vaults at that time. 23 Q Right. 24 A Our notes went -- continued to go to Stockton. 25 Q Okay. Page 52 Veritext Florida Reporting Co. 800-726-7007 305-376-8800 1 A Until Stockton was shipped out, and I don't 2 remember when that was. 3 Q Okay. So I think what you're telling me is 4 that Stockton did continue to function for a short 5 period of time after you left. 6 A Yes. 7 Q And when you first came to Jacksonville, were 8 the notes always shipped back to Stockton initially? 9 A Yes. 10 Q Okay. And then were there other locations 11 where the notes were shipped to? 12 A There was a location in Vernon Hills. 13 Q Vernon Hills where? What state? 14 A In Illinois. 15 Q And during what period of time were they 16 shipped to Vernon Hills, Illinois, if you know? 17 A I don't know. 18 Q Were they shipped anywhere else besides Vernon 19 Hills and Stockton? 20 A I can't be certain of that. 21 Q Okay. Were there any other vaults that WaMu 22 had besides in Vernon Hills and Stockton? 23 A A vault was built in Florence, South Carolina. 24 Q You know when that was built? 25 A No, not exactly. Page 53 Veritext Florida Reporting Co. 800-726-7007 305-376-8800 1 Q Approximately? 2 A I would -- 3 MR. SCHWARTZ: Don't guess. 4 Q I mean, are we talking in the 1990s? Was it in 5 2000, 2005? 6 A 2008. I don't know that it was in 2008. Let's 7 be clear. I don't know that it was 2008. 8 Q Okay. It was not in the 1990s? 9 A It was not in 1990s. 10 Q I'd like to just go back to the endorsements a 11 little bit. You'd indicated that there were nine to ten 12 stamps that were made; is that correct? 13 A Correct. 14 Q All right. And, to the best of your knowledge, 15 were they all made at the same time approximately? 16 A Yes. 17 Q Okay. So they all came back in from whoever 18 made them to WaMu at the same time, to your knowledge? 19 A Yes. 20 Q Do you know who made them? 21 A No. 22 Q Okay. And you've indicated that you have no 23 reason to think that the signatures were different on 24 any of the stamps; correct? 25 MR. WEISS: Object to the form of the question. Page 54 Veritext Florida Reporting Co. 800-726-7007 305-376-8800 1 Q You can answer. 2 MR. WEISS: Objection. She testified that she 3 didn't know how the process exactly worked with 4 respect to getting the signature from her sample 5 signatures that she provided to the stamp. She 6 testified that she didn't know if -- what the 7 process was that captured her -- 8 MR. WRUBEL: Mr. Weiss, just object to the 9 form. You don't have to coach the witness any 10 further. She testified -- 11 MR. WEISS: I'm not coaching the witness. 12 MR. WRUBEL: And I'm instructing you not -- 13 MR. WEISS: I'm not coaching the witness. 14 MR. WRUBEL: I'm telling you -- 15 MR. WEISS: I'm trying to clarify a question. 16 MR. WRUBEL: You don't need to clarify, 17 Mr. Weiss. 18 MR. WEISS: The testimony that -- 19 MR. WRUBEL: I don't want you coaching the 20 witness. 21 THE REPORTER: One at a time, please. 22 MR. WRUBEL: You got an objection to the form? 23 MR. WEISS: I've made my objection for the 24 record. I've stated it for the record. 25 BY MR. WRUBEL: Page 55 Veritext Florida Reporting Co. 800-726-7007 305-376-8800 1 Q Now, as I was saying, you indicated earlier you 2 had no reason -- these are your words: You have no 3 reason to think that the signatures were different on 4 any of the stamps; is that correct? 5 A What I said was exactly that I don't know what 6 the process was to make those stamps, whether or not I 7 signed several times and they took one of those 8 signatures or not. I don't know what that process was. 9 Q Okay. But as far as you know you never saw any 10 differences with regards to the signatures on the 11 stamps? 12 MR. WEISS: Objection. Object to the form of 13 the question. 14 Q You can answer. 15 A I never inspected the stamps to ensure that the 16 signatures were all exactly the same. 17 Q Okay. All right. Now, you've indicated that 18 the notes were initially shipped to Stockton and then to 19 Vernon Hills? 20 MR. WEISS: Objection. Misstates prior 21 testimony. 22 A We were -- we shipped the notes to the 23 custodian. 24 Q Okay. 25 A And at the time frames from when that custodian Page 56 Veritext Florida Reporting Co. 800-726-7007 305-376-8800 1 was in Stockton or Vernon Hills I can't speak to that. 2 Q Okay. Did you ship to any other custodians in 3 any locations other than Vernon Hills and Stockton? 4 MR. SCHWARTZ: Asked and answered. Form. Go 5 ahead. 6 A I just don't know at what time frames we were 7 shipping to some place other than those two. 8 Q Okay. Did there come a point in time that you 9 shipped to Florence, South Carolina? 10 A When the vault was built -- I don't know if 11 that -- I can't answer that. 12 MR. SCHWARTZ: If you don't know, say you don't 13 know. 14 A I left the department. 15 Q Okay. When did you leave the department? 16 A In November of 2006. 17 MR. SCHWARTZ: You need a break? 18 THE WITNESS: I think that would be nice if we 19 did. 20 MR. SCHWARTZ: You mind if she takes a break? 21 MR. WRUBEL: No. 22 (Break taken.) 23 BY MR. WRUBEL: 24 Q You've indicated that it was your team that did 25 the endorsements of the stamps in Jacksonville. Did you Page 57 Veritext Florida Reporting Co. 800-726-7007 305-376-8800 1 yourself ever endorse any of the notes? 2 A No. 3 Q Never? 4 A I never put an endorsement stamp on the notes. 5 Q Okay. How many notes a day were coming into 6 the Jacksonville area, if you know, approximately? 7 A 2- to 3,000. 8 Q Assuming you only had 10, not 12, just if we 9 can get through the question, am I correct then that 10 your team would be each reviewing approximately 200 to 11 300 notes a day? 12 MR. SCHWARTZ: Form. Speculating. Go ahead. 13 A That sounds reasonable. 14 Q And they would be checking the notes and the 15 data for the loans -- strike that. 16 Each individual that was on the team would be 17 checking the notes as well as the data with regards to 18 the loans approximately 2- to 300 a day? 19 A They compared the data -- certain data on the 20 note to what was on the system. 21 Q Would they be comparing any other data besides 22 the data on the note to the system when they would go 23 through the system? 24 A Other data like what? 25 Q Information from the mortgage perhaps. Page 58 Veritext Florida Reporting Co. 800-726-7007 305-376-8800 1 A They have a note. The notes is all they had. 2 Q That was the only information? 3 A Yeah, note review. 4 Q Okay. I'm curious. Being the supervisor or 5 the manager of the unit -- you've indicated that the 6 team leader was Pat Eyles; correct? 7 A Yes. 8 Q Okay. Would they have ever come to you with 9 problems with regards to the note review unit? 10 A Problems like what? 11 Q I don't know. I mean, I'm just kind of curious 12 as to what type of things you would be managing with 13 regards to the unit during this two-year period. 14 A Productivity is what we managed to. 15 Q Okay. 16 A We tracked how well each individual did 17 their -- did their job. 18 Q Okay. So your responsibilities were basically 19 to make sure the unit was working efficiently? 20 MR. WEISS: Object to the form of the question. 21 A I oversaw that unit, that we were following the 22 procedures that we did our quality checks on, the 23 results of those quality checks, and personnel. 24 Q Okay. Did you ever find that there were 25 problems with regards to the quality of the work that Page 59 Veritext Florida Reporting Co. 800-726-7007 305-376-8800 1 the unit did from time to time? 2 A Yes. 3 Q What types of problems were they having? 4 A When we did a QC check, we might see that they 5 didn't properly check a -- a data element or that it 6 needed a correction. It could be that they -- live 7 signature versus a copy signature on a note. 8 Q Okay. And when you say QC, I take it you're 9 referring to quality control? 10 A Correct. 11 Q Okay. Who would be the individual or 12 individuals who would be doing the review of the work? 13 A The lead or the manager of the unit. 14 Q Okay. And in the case of the note review unit, 15 that would have been Pat Eyles? 16 A Pat or her lead. 17 Q Who was her lead? 18 A Karen Woodward. 19 Q Can you spell Woodward, please? 20 A Woodward, W-o-o-d-w-a-r-d. 21 Q To your knowledge, is she still with JP Morgan? 22 A Yes. 23 Q Here in Jacksonville? 24 A Yes. 25 Q Okay. With respect to your responsibilities, Page 60 Veritext Florida Reporting Co. 800-726-7007 305-376-8800 1 what happened in November of 2006? What changed? 2 MR. WEISS: Object to the form of the question. 3 Vague and ambiguous. 4 A The department was closed and moved to the -- 5 the Florence, South Carolina, office. 6 Q And when you say the department, we're talking 7 about which department? 8 A Secondary delivery operations. 9 Q Did you move to Florence, South Carolina, also? 10 A No. 11 Q Where did you stay? 12 A Jacksonville. 13 Q Okay. I'm going to go back just before we come 14 into this area. No, we can go to this area. What 15 responsibilities did you take on after June 2006, 16 immediately thereafter? 17 A After June of 2000- -- 18 Q I'm sorry. November of 2006. 19 A I did project management work for about 20 12 months. 21 Q What type of project management? 22 A At that time we were moving -- the project that 23 I was involved with was helping to move the custodial 24 vault from Stockton to Florence, South Carolina. 25 Q I'm a little bit confused. I thought Stockton Page 61 Veritext Florida Reporting Co. 800-726-7007 305-376-8800 1 closed somewhere between 2004? 2 A No. 3 Q It continued to operate? 4 A Yes. 5 Q Okay. When did the Stockton plant close down? 6 A That's what I can't be specific about. The 7 custodial vault was still there when I moved to 8 Jacksonville. 9 Q And, to your knowledge, you continued to ship 10 notes back to Stockton and Vernon Hills during the 11 period -- although you're not exactly sure when it 12 ended, somewhere between the period of June 2004 and 13 November of 2006? 14 MR. SCHWARTZ: Form. Compound question. Go 15 ahead. 16 A Yes. We would have been shipping to the 17 custodial vault in one of those two locations. 18 Q And come November of 2006 you got involved with 19 the project of doing exactly what? 20 A I project managed for about the next 12 months. 21 One of the projects was the movement of the vault from 22 Stockton to Florence, South Carolina. 23 Q What types of things would you have to do 24 during this period of time to oversee or help move the 25 vault from Stockton to Florence, South Carolina? Page 62 Veritext Florida Reporting Co. 800-726-7007 305-376-8800 1 A I coordinated, you know, meetings, meetings and 2 the activities. Generally we'd have a weekly meeting of 3 what needed to be done, progress. A building was built. 4 So I helped on the project management side. 5 Q Okay. And during this period of time you've 6 indicated that the secondary... 7 A Delivery operations. 8 Q Thank you. Secondary delivery operations was 9 shut down in November of 2006? 10 A Jacksonville -- secondary delivery operations 11 was shut down in Jacksonville. The Florence, South 12 Carolina, office was a -- part of it was a -- we had 13 secondary delivery operations in two locations. That 14 location continued. The Jacksonville office shut down. 15 Q Okay. And I take it you're saying that 16 Florence, South Carolina, secondary delivery operations 17 picked up around November of 2006, December 2006? 18 A No, that's not correct. They were in parallel 19 with Jacksonville -- 20 Q Okay. 21 A -- for sometime -- 22 Q Okay. 23 A -- prior. 24 Q All right. So they started up before November 25 of 2006? Page 63 Veritext Florida Reporting Co. 800-726-7007 305-376-8800 1 A Yeah. 2 Q When I say they, I'm referring to Florence, 3 South Carolina. 4 A They were in existence before November of 2006. 5 Q Okay. Do you know approximately how long 6 before November of 2006, approximately? 7 A They were in existence prior to 2004. 8 Q Okay. Did they have a vault there before 2004? 9 A Yes. 10 MR. SCHWARTZ: Form. 11 Q And there I'm referring to Florence, South 12 Carolina. 13 A Yes. 14 Q Okay. Are you clear that Jacksonville's 15 operation, as far as secondary delivery operations, 16 closed down in November of 2006? 17 MR. WEISS: Object to the form of the question. 18 A We were laid off the end of that year. 19 Q Okay. And so is your answer yes, there was -- 20 strike that. 21 Is it your answer that there were no secondary 22 delivery operations going on in Jacksonville by the end 23 of 2006? 24 A Correct. 25 Q And when you say you were laid off, you were Page 64 Veritext Florida Reporting Co. 800-726-7007 305-376-8800 1 laid off from that department. You continued to work 2 for JP Morgan; correct? 3 MR. SCHWARTZ: Form. 4 A I was laid off and subsequently got a job back 5 with JP Morgan in January. 6 Q January of what year? 7 A 2009. 8 Q And when were you laid off? 9 A It had to have been 11, November. 10 Q Okay. When you came back in January 2009, what 11 did you do? 12 A I went to work in MIS, management information 13 systems, in the default division. 14 Q And I take it you no longer had the title of 15 vice president? 16 A That's correct. 17 Q And would I be correct in -- strike that. 18 With regards to defaults and management 19 information systems, what were your responsibilities 20 there? 21 A Management information systems, I provided 22 information to the auditing agencies. 23 Q What types of auditing -- auditing entities are 24 we talking about? 25 A Moody's, S&P, Fitch. Page 65 Veritext Florida Reporting Co. 800-726-7007 305-376-8800 1 Q Did MIS provide any information to anyone 2 besides Moody's, S&P, Fitch? Was the -- 3 A I'm sure they did. 4 Q Was the information used for other purposes, I 5 guess is my question? 6 A Other purposes like what? 7 Q I don't know. But, I mean, you're saying that 8 the name of the unit was management information systems. 9 Was it strictly for auditing purposes? 10 A Wait a minute. I was speaking of my 11 responsibilities at MIS. 12 Q Okay. 13 A And your question is those responsibilities? 14 Q Right. 15 A Okay. My responsibilities, I provided data for 16 the auditing. 17 Q Okay. And I take it you're implying that 18 management information system was used for other 19 purposes, but that was not your responsibility? 20 MR. SCHWARTZ: Form. 21 MR. WEISS: Object to the form of the question. 22 A That was one function in MIS. 23 BY MR. WRUBEL: 24 Q Okay. What were the other functions? 25 A They provide reporting to all the departments. Page 66 Veritext Florida Reporting Co. 800-726-7007 305-376-8800 1 Q And how long did you provide the information 2 for auditing purposes? 3 MR. WEISS: Object to the form. Vague and 4 ambiguous. 5 A I'm still at MIS with other responsibilities. 6 Q Okay. What types of responsibilities do you 7 have now? 8 A I'm doing reporting for our borrowers' systems 9 groups. 10 Q What are you referring to as borrowers' systems 11 groups? I'm not sure I understand the term. 12 A Customers that call in looking for assistance. 13 Q Okay. And you also mentioned that you were 14 involved with defaults when you came back on board? 15 A Originally MIS was a default under the default 16 umbrella. 17 Q Is it still under the default umbrella? 18 MR. SCHWARTZ: If you don't -- 19 A I don't know. 20 Q Okay. When you said originally, I thought 21 things may have changed. 22 Have you worked in any other units besides MIS 23 since you came back in 2009? 24 A No. Any other departments -- 25 Q Yes. Page 67 Veritext Florida Reporting Co. 800-726-7007 305-376-8800 1 A -- at MIS? No. 2 Q Were there any other projects that you worked 3 on besides helping transfer everything to the Florence, 4 South Carolina, vault? 5 A Yes. 6 Q During that 12-month period that you referred 7 to after November of 2006. 8 A Yes, there were other projects that I worked 9 on. 10 Q Okay. What other types of projects? 11 A They were like a Z state -- I want to call 12 it -- where you're -- process improvement. 13 Q Process? 14 A Improvement. 15 Q Okay. What does that entail? 16 A We looked at -- we helped implement projects in 17 departments where they saw improvements and needed to 18 make changes. 19 Q Any other projects besides project improvements 20 and working on the vault during that 12-month period? 21 A No. Unh-unh. 22 Q Okay. And at the end of that 12-month period 23 that's when you were laid off? 24 A That was -- I was laid off and went to the job 25 in MIS. Page 68 Veritext Florida Reporting Co. 800-726-7007 305-376-8800 1 Q Okay. 2 A I applied and got a new job in MIS, yes. 3 Q Okay. Did you ever supervise any of the 4 employees in Florence, South Carolina? 5 A I did not. 6 Q And none of them were under your authority? 7 MR. WEISS: Object to the form of the question. 8 MR. SCHWARTZ: Join. 9 BY MR. WRUBEL: 10 Q None of the employees in Florence, South 11 Carolina, were ever under your direction? 12 A They were not. 13 Q Or your supervision? 14 A They were not. 15 MR. WRUBEL: I take it you have seen this note? 16 MR. SCHWARTZ: Which one is it? I don't know. 17 MR. WRUBEL: It's the only one relevant to this 18 litigation. 19 Mark this as Defense Exhibit 1. 20 (Defendants' Exhibit 1 was marked for 21 identification.) 22 BY MR. WRUBEL: 23 Q Ms. Riley, I'm showing you what's been marked 24 as Defense Exhibit 1. And I'll ask you if you've ever 25 seen a copy or -- of this document. Page 69 Veritext Florida Reporting Co. 800-726-7007 305-376-8800 1 A Yesterday. 2 Q That was the first time? 3 A I believe so. 4 Q Okay. And with reference to the endorsement, 5 which is on the last page, does that appear to be your 6 signature? 7 A Yes, my signature. 8 Q Okay. And does that appear to be similar to 9 the facsimile stamps that were used during your time 10 when you managed the -- the secondary delivery unit? 11 MR. WEISS: Object to the form of the question. 12 MR. SCHWARTZ: I'll join. Calls for 13 speculation. Lacks predicate. Lacks foundation. 14 Go ahead. 15 A Say the question, again. Would you, please? 16 BY MR. WRUBEL: 17 Q I'll be glad to. Does the signature that 18 appears there appear similar to the -- to the facsimile 19 stamps that were used during your tenure between June of 20 2004 and November of 2006? 21 A This is my signature, yes. 22 Q Okay. And does your signature vary materially 23 at any time? 24 MR. SCHWARTZ: Objection. Calls for 25 speculation. Page 70 Veritext Florida Reporting Co. 800-726-7007 305-376-8800 1 MR. WRUBEL: You can just say form. 2 MR. SCHWARTZ: Lack of predicate. Lack of 3 foundation. 4 MR. WRUBEL: You can say form. 5 A My signature's certainly over time made 6 changes. 7 BY MR. WRUBEL: 8 Q Okay. 9 MR. WRUBEL: I'd like to take a break for a 10 couple of minutes. 11 (Break taken.) 12 BY MR. WRUBEL: 13 Q Ms. Riley, I don't know if you're aware of it 14 or not, but some of the attorneys moved for a protective 15 order before we took this deposition. Is there any 16 reason that you're concerned about any of the testimony 17 that you've provided here that may be confidential, or 18 do you have other concerns with regard to your 19 testimony? 20 A Well, I'm not sure about the protective order 21 that you're talking about, but yes, I have concerns on 22 where it ends up and where it's going. 23 Q Okay. 24 A Yes. 25 Q Okay. And can you elaborate on what your Page 71 Veritext Florida Reporting Co. 800-726-7007 305-376-8800 1 concerns are? 2 A Well, I've seen things on the Internet that has 3 gone way beyond, that has -- frankly, there's phrases in 4 there that are threatening. Going to run me down, run 5 me out of breath. That sounds pretty threatening. So 6 yes, I have concerns about where this kind of 7 information ends up. 8 Q Okay. Is there any other concerns that you 9 have besides that it may end up on the Internet that 10 you're aware of or that you -- 11 A You're saying it may end up on the Internet? 12 Q It won't. It won't. I can assure you it 13 won't. 14 A Okay. I have no concerns about what I told you 15 today. 16 Q Right. 17 A I have -- I can't speak to specific dates that 18 you've asked about. 19 Q Right. 20 A But what we've -- I've told you what I know. 21 Q No. No. And just so you're clear on it, there 22 already is a protective order in place which says that 23 it's not to go on the Internet. So I just want you to 24 be aware of that and seems to be -- but you're saying 25 other than that you really don't have any other concerns Page 72 Veritext Florida Reporting Co. 800-726-7007 305-376-8800 1 with any of the other -- 2 MR. SCHWARTZ: Form. 3 A I don't have concerns about what I said today. 4 Q Okay. 5 MR. WEISS: Objection to the form of the 6 question. Just to clarify, I'm -- you're asking her 7 if -- she seems to be responding to, Do you have any 8 concerns what you've testified about? You're asking 9 her, Do you have any concerns about this deposition? 10 MR. WRUBEL: I'm asking her both. 11 MR. SCHWARTZ: Let's be clear. She's not a 12 lawyer. The legal concerns are not under her 13 purview. 14 MR. WRUBEL: I understand. 15 MR. SCHWARTZ: She's talking about the facts. 16 MR. WRUBEL: Right. She's concerned from her 17 own personal standpoint about it going on the 18 Internet, and I'm assuring her it will not. 19 MR. WEISS: So are you asking -- but are you 20 asking her does she have any other concerns about it 21 being publicly disseminated? 22 MR. WRUBEL: I've asked her what I've asked 23 her. That's it. 24 MR. SCHWARTZ: All right. 25 MR. WEISS: All right. Page 73 Veritext Florida Reporting Co. 800-726-7007 305-376-8800 1 BY MR. WRUBEL: 2 Q There's issue as to whether or not you were 3 actually subpoenaed for today or not. If this matter 4 goes to trial, and it's set in March, I would like to be 5 able to subpoena you to come to trial. Now, I presume 6 that you don't want to be harassed with a subpoena, but 7 I want to be in a position where I can serve you. Is 8 there a place where I can serve you with a subpoena, or 9 would you be willing to indicate that the attorneys at 10 GrayRobinson can accept a subpoena for you? 11 MR. SCHWARTZ: Any subpoenas that are 12 appropriate under the Florida law and applicable to 13 Ms. Riley can be served on me. 14 MR. WRUBEL: Okay. That takes care of that. 15 MR. SCHWARTZ: And we reserve all rights to 16 object to any improprieties as related to the 17 subpoenas. 18 MR. WRUBEL: Improprieties such as? 19 MR. SCHWARTZ: To the extent your subpoena form 20 or substance is improper, I reserve the right to 21 object, but you can serve me, yes. 22 MR. WRUBEL: Okay. For her. 23 MR. SCHWARTZ: Yes. 24 MR. WEISS: Let's just clarify. He's saying 25 for purposes of an address, service address? Page 74 Veritext Florida Reporting Co. 800-726-7007 305-376-8800 1 MR. WRUBEL: No. 2 MR. WEISS: He said care of Roland Schwartz? 3 MR. WRUBEL: Right. 4 MR. WEISS: Whether or not, you know, it's 5 within the subpoena power of the court. He's not -- 6 MR. SCHWARTZ: That's what I said. 7 MR. WEISS: He's not waiving the formality -- 8 MR. SCHWARTZ: That's why I said for purposes 9 of the address serve subpoenas on me. To the extent 10 that there's an impropriety with respect to the 11 subpoena, we reserve the right to object. But 12 that's a legal issue, obviously. 13 MR. WRUBEL: Obviously. 14 MR. SCHWARTZ: But no, you don't need to go to 15 her house to serve her. 16 MR. WRUBEL: You're authorized to accept for 17 her. 18 MR. SCHWARTZ: Correct. 19 MR. WRUBEL: That's all I need. 20 MR. SCHWARTZ: Okay. But reserve the rights to 21 still object once -- once I'm served. 22 MR. WEISS: You're not stipulating -- 23 MR. SCHWARTZ: Correct. 24 MR. WEISS -- that -- 25 MR. SCHWARTZ: Right. Page 75 Veritext Florida Reporting Co. 800-726-7007 305-376-8800 1 MR. WEISS: -- that's service -- 2 MR. SCHWARTZ: Right. 3 MR. WEISS: -- or anything from you. 4 MR. WRUBEL: I understand. 5 MR. SCHWARTZ: Can be addressed to me, and then 6 we'll take it from there. 7 MR. WRUBEL: Okay. 8 BY MR. WRUBEL: 9 Q For the record, what is the address that you 10 work at? 11 A 7757 Bayberry. 12 Q 7757? 13 A Bayberry Road. 14 Q And I take it that's part of Jacksonville 15 proper? 16 A Yes, it is. 17 Q Does -- Jacksonville proper is the whole county 18 still? 19 A I don't think it is. 20 Q I don't know. I just remember years ago they 21 did it that way. 22 MR. WRUBEL: I got nothing else. You got 23 anything? 24 MR. OROZCO: No. 25 MR. SCHWARTZ: Let's take five minutes, and Page 76 Veritext Florida Reporting Co. 800-726-7007 305-376-8800 1 then we'll have some questions. 2 CROSS-EXAMINATION 3 BY MR. SCHWARTZ: 4 Q Ms. Riley, there was some testimony about the 5 fact that you did not directly supervise the employees 6 in South Carolina. Remember that testimony? 7 A Yes. 8 Q Okay. You do know some of the supervisors who 9 oversaw the South Carolina operations, don't you? 10 A Yes. We worked together for some time. 11 Q In Jacksonville? 12 A No. They were in Florence. I was in 13 Jacksonville. 14 Q Isn't it true that along with some of those 15 supervisors you were involved in developing and 16 implementing note endorsement procedures? 17 A Yes. We had procedures on both sides that were 18 developed and put together and followed. 19 Q And some of the supervisors that were involved 20 in developing those endorsement procedures with you were 21 tasked with overseeing those same procedures in South 22 Carolina? 23 A That's correct. 24 MR. WRUBEL: Objection to the form. 25 Q Who oversaw the procedures of endorsing notes Page 77 Veritext Florida Reporting Co. 800-726-7007 305-376-8800 1 in South Carolina? 2 A My counterparts. 3 Q What were they tasked with? 4 MR. WRUBEL: Objection to the form. 5 Q Go ahead. 6 A Their functions would be the same as mine. 7 There was dual operations in Jacksonville and South 8 Carolina. 9 Q Okay. You know for a fact that those 10 endorsement procedures stayed the same -- 11 MR. WRUBEL: Objection. 12 Q -- once the operations were moved to South 13 Carolina? 14 MR. WRUBEL: Objection to the form. 15 A Yes. I helped move those procedures to South 16 Carolina, and they had the dual operations already in 17 effect. 18 Q You also testified that you provide -- while 19 you were in Jacksonville from 2004 to 2006 you provided 20 a few sample signatures from which stamps were made; is 21 that fair? 22 A Yes. 23 Q Okay. Let's just -- 24 MR. WRUBEL: Objection to the form of the last 25 question. Page 78 Veritext Florida Reporting Co. 800-726-7007 305-376-8800 1 MR. SCHWARTZ: You need to object before I ask 2 the question, but that's fine -- before she answers 3 actually, not before I ask the question. 4 MR. WRUBEL: It's all right. 5 BY MR. SCHWARTZ: 6 Q Were you involved in any way, shape, or form in 7 actually manufacturing the stamps? 8 A No. 9 Q Do you know which sample signatures were picked 10 for what stamp? 11 MR. WRUBEL: Objection to the form. 12 A No. 13 Q You also testified you were not endorsing notes 14 yourself with a stamp; is that accurate? 15 A That's correct. I was not. 16 Q Do you know for sure that one sample signature 17 was picked for all of the stamps that were made? 18 A I don't know. 19 Q So can you be sure that all of the stamps were 20 assigned the same sample signature? 21 MR. WRUBEL: Objection to the form. 22 A I don't know that I can be sure of that. I can 23 be sure it's my signature. 24 Q Also while in Jacksonville from 2004 to 2006 25 did you endorse notes by hand, yes or no? Page 79 Veritext Florida Reporting Co. 800-726-7007 305-376-8800 1 A Yes. 2 Q Let's go back to Stockton before 2004. Was 3 there a stamp made with your name to endorse notes while 4 at -- while in Stockton? 5 A There was a stamp with my name on it, yes, 6 without a signature. 7 Q Was there -- and you would, then, sign 8 endorsements by hand while in Stockton? 9 A I would have to sign. 10 Q Was there one version of the stamp made while 11 in Stockton or more? 12 A There could -- there were other versions in 13 Stockton. There were other versions of the stamp, yes. 14 Q How -- how were the versions different? 15 A In the case there would be Cindy Riley on a 16 stamp, and in another case it would be Cynthia A. Riley. 17 Q In both cases it was you? 18 A It was me. 19 Q And you would sign that by hand? 20 A And I would -- there were occasions where I 21 signed by hand, yes. 22 Q Were you authorized by your employer to sign 23 notes by hand? 24 MR. WRUBEL: Objection. Form. 25 A Yes, I had authorization. Page 80 Veritext Florida Reporting Co. 800-726-7007 305-376-8800 1 Q Did you authorize other people to use stamps 2 with your name on it? 3 A Yes. 4 MR. WRUBEL: Objection. Form. 5 Q Did your employer authorize you to allow other 6 name -- stamp your name on notes? 7 MR. WRUBEL: Objection. Form. 8 A I don't understand the question actually. 9 Q The whole process of stamping the name on 10 notes, did that come from your supervisor? 11 MR. WRUBEL: Objection. Form. 12 A Yes. It was the procedures that we used, and 13 there was authorization. 14 Q Was there any secrecy or fraud about it? 15 A No. 16 MR. WRUBEL: Objection. Form. 17 Q Was it all in the open? 18 MR. WRUBEL: Objection. Form. 19 A It was all in the open. 20 Q Your employers received communication from 21 supervisors as far as policies and procedures -- 22 MR. WRUBEL: Objection. Form. 23 Q -- as far as what policies and procedures to 24 follow? 25 A Yes. Page 81 Veritext Florida Reporting Co. 800-726-7007 305-376-8800 1 Q And they followed those policies and 2 procedures? 3 A Absolutely. 4 MR. WRUBEL: Objection. Form. 5 Q Is it -- the Exhibit 1 that was presented to 6 you during this deposition, is that your signature on 7 the note? 8 A Yes, it is. 9 MR. SCHWARTZ: You go ahead. I'll think. 10 MR. WEISS: Okay. 11 MR. WRUBEL: I'm going to object to you asking 12 any questions, Mr. Weiss. You're not a party to 13 this litigation. 14 MR. WEISS: Okay. 15 MR. SCHWARTZ: We can take a two-minute break. 16 I mean, we can short-circuit this, but that's no 17 problem. 18 (Break taken.) 19 BY MR. SCHWARTZ: 20 Q Ms. Riley, when you were in Jacksonville from 21 2004 to 2006, as a matter of business practice how soon 22 would notes get endorsed after the deed of closing? 23 MR. WRUBEL: Objection. Form. 24 A The notes after closing occurred were shipped 25 into our office, and we would go through the note review Page 82 Veritext Florida Reporting Co. 800-726-7007 305-376-8800 1 process, endorse them, send them to the custodian. And 2 that would just be a matter of days. 3 Q So the endorsement would be placed on the note 4 within days after closing as a matter of business 5 practice? 6 A Yes. 7 MR. WRUBEL: Objection to the form. 8 MR. SCHWARTZ: This is what I'll show Ms. Riley 9 next (tenders document). 10 MR. WRUBEL: I'd like a chance to review it 11 before you show her. 12 MR. SCHWARTZ: Fine. 13 MR. WRUBEL: Okay. 14 MR. SCHWARTZ: Okay. We'll call this -- what 15 are we doing, numbers or letters? We'll call this 16 Plaintiff's Exhibit 1 to the deposition. It says A, 17 so we'll just change it. 18 Do you want to mark it before I ask questions? 19 (Plaintiff's Exhibit 1 was marked for 20 identification.) 21 BY MR. SCHWARTZ: 22 Q Ms. Riley, on top of what's been marked as 23 Plaintiff's Exhibit 1 on top of Page 1 it has a 24 reference to foreclosure hamlet. 25 A Yes. Page 83 Veritext Florida Reporting Co. 800-726-7007 305-376-8800 1 Q Have you heard of foreclosure hamlet before? 2 A I have, yes. 3 Q How so? 4 A In -- on the Internet with association with my 5 name. 6 Q Do you recognize this as a printout from that 7 website? 8 A It appears to be, absolutely. 9 Q If you go to Page 6 of this exhibit, the 10 comment in the middle of the page that's dated June 10th 11 of 2010, do you see that? 12 A Yes. 13 Q At 12:56 p.m.? 14 A Yes. 15 Q In the middle of that paragraph that starts 16 with, Riley is not one of the corporate executives, you 17 see that? 18 A Yes. 19 Q She's just a low-level secretary now being used 20 to take away homes. I've been quietly watching her for 21 over seven months. Then down below it says, They're 22 trying to hide her, but for how long? She's on the run. 23 Let's run her down and run her out of breath. 24 Does this provide you with a feeling of safety 25 and security? Page 84 Veritext Florida Reporting Co. 800-726-7007 305-376-8800 1 A Absolutely not. 2 Q Do you feel like you're being hunted and 3 watched by someone out there? 4 A Yes. 5 Q When you said that you had no concerns with 6 what you said today during your deposition, did you mean 7 you had no reservations how you did your job at 8 Washington Mutual? 9 MR. WRUBEL: Objection to the form. 10 A I have no reservations about my job at 11 Washington Mutual and what I did, correct. 12 Q And instead your reservation comes from people 13 like this, misconstruing what you did and putting it in 14 a threatening fashion; is that correct? 15 MR. WRUBEL: Objection to the form. 16 A Absolutely what's on here is -- is very 17 threatening. 18 Q On the same chain in this exhibit, which is a 19 blog chain, on Page 2, do you see -- the first entry at 20 6:24 p.m., do you see the name of Eduardo Orozco in the 21 same chain? 22 A Yes. 23 Q Is that the borrower in this case? 24 A Yes. 25 Q In fact, is that the gentleman sitting in front Page 85 Veritext Florida Reporting Co. 800-726-7007 305-376-8800 1 of you today? 2 A Yes. 3 Q Do you have reservations about people 4 misconstruing what you did and making it a matter of 5 public report? 6 MR. WRUBEL: Objection to the form. 7 Q Go ahead. 8 A Absolutely, yes. 9 Q Do you get unanimous calls today? 10 A I get unanimous calls. Yes, I do. 11 Q When was the most recent call? 12 A I had a call just last week. Somebody calling 13 up asking where 7757 was located. 14 Q What did you say? 15 A I asked who was calling. They would not 16 identify themselves initially. Then they'd claim to be 17 60 Minutes and -- and that they were looking to find the 18 location. And I -- I did not help them with that, and 19 the call was ended. 20 Q Have you had people calling you and telling you 21 that your career's going to go down the toilet? 22 MR. WRUBEL: Objection to form. 23 A I've had a number of calls, and that was one of 24 them where it was -- he kept calling back, and he called 25 back several times. Finally he left a message that Page 86 Veritext Florida Reporting Co. 800-726-7007 305-376-8800 1 said, This is what's going to happen with your career, 2 and it's going down the toilet, yes. That's happened as 3 well. 4 Q Does this seem -- these calls, these 5 threatening, unanimous call, is there any end in 6 sight -- 7 MR. WRUBEL: Objection to the form. 8 Q -- as far as you know? 9 A It doesn't seem like it, no 10 Q Have they decreased over time in frequency? 11 MR. WRUBEL: Objection to the form. 12 A No. They've -- actually I've been getting more 13 recently. 14 Q Are they pleasant? 15 A No. I generally screen the calls now. 16 MR. WRUBEL: Form. 17 A If I don't recognize the area code on the phone 18 or the phone number, I let it go to message. 19 Q Do you want them to stop? 20 A Of course I do. 21 MR. WRUBEL: Form. 22 Q Would you wish what's in Exhibit -- in 23 Plaintiff's Exhibit 1 upon somebody? 24 A Absolutely not. 25 Q Did you do anything wrong? Page 87 Veritext Florida Reporting Co. 800-726-7007 305-376-8800 1 MR. WRUBEL: Objection to form. 2 A I did not do anything wrong. 3 Q Do you know if someone used your stamp without 4 authority? 5 MR. WRUBEL: Objection to the form. 6 Q Go ahead. 7 A I don't believe anybody used my stamp without 8 authority. 9 Q And if you knew about it, you would have not 10 authorized it; right? 11 MR. WRUBEL: Objection. 12 A It would not be authorized in any manner. 13 Q All you did was follow the process, didn't you? 14 MR. WRUBEL: Same. Form. 15 A I followed the procedures in the department. 16 MR. SCHWARTZ: By the way, not that we're 17 stipulating to your objection. Jonathan couldn't 18 testify. But I would like to know what that 19 objection is for the record so that we can preserve 20 it for the Judge, if necessary. 21 MR. WRUBEL: He's not a party to the 22 litigation. There's no reason for him to be, you 23 know, asking questions. If he wants to protect her 24 with regards to the questions that I ask, that's 25 fine. But as far as him being involved in this Page 88 Veritext Florida Reporting Co. 800-726-7007 305-376-8800 1 litigation, I see no reason for it. 2 MR. SCHWARTZ: Thanks for stating that on the 3 record. 4 BY MR. SCHWARTZ: 5 Q Do you -- do -- these Internet postings and 6 phone calls, does that affect your personal life in any 7 way once you go home? 8 MR. WRUBEL: Objection to the form. 9 A Well, it does in that I've had a server come to 10 the door. I walk out the building looking around to see 11 if somebody is lurking in the parking lot. I'm 12 screening my phone calls. It's upsetting that my name 13 is on the Internet like this. Having -- I did my job. 14 I followed the procedures. And this kind of stuff on 15 the Internet is very disturbing. 16 Q Do you sometimes take it out on your husband? 17 MR. WRUBEL: Objection to the form. 18 Q Go ahead. Go ahead. 19 A My husband -- I certainly have said things 20 like, Can you believe this? And so I have had 21 discussions with him about -- I called him the other day 22 and said, Somebody called and asked for my address. 23 Q So you share your angst with him? 24 A I do, absolutely. 25 Q Oh, have you had borrowers' lawyers call you at Page 89 Veritext Florida Reporting Co. 800-726-7007 305-376-8800 1 work? 2 MR. WRUBEL: Objection to the form. 3 A I had a law office -- I had a phone call. 4 They -- the number popped up. They hung up. I said, 5 What is this about? I called them back, and it turned 6 out to be a law office. 7 Q Did they tell you what the call was about? 8 A They called a second time -- 9 MR. WRUBEL: Wait a minute. Let her finish. 10 A They called a second time on a number that 11 wasn't recognized then, and I called them back. And I 12 said, Did you just call me? And it was in fact a law 13 office, yes. 14 Q And you recognized that as being one of the 15 borrower's counsel? Not in this case but -- 16 A Not in this. Yeah, I -- I don't remember now 17 whose counsel it was, but it was a law office related 18 to -- 19 Q Did they give you a reason as to why they 20 called -- 21 MR. WRUBEL: Objection to form. 22 Q -- when you called them back? 23 A No. They wouldn't talk to me. 24 MR. SCHWARTZ: No more questions. 25 (Break taken.) Page 90 Veritext Florida Reporting Co. 800-726-7007 305-376-8800 1 MR. WRUBEL: We've got no questions. 2 Ms. Riley, you're allowed to read this 3 deposition. 4 MR. SCHWARTZ: We'll read. 5 MR. WRUBEL: Pardon me? 6 MR. SCHWARTZ: We'll read it. 7 MR. WRUBEL: Okay. We're done. 8 (Witness excused.) 9 (Deposition concluded at 12:23 p.m.) 10 - - - 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 91 Veritext Florida Reporting Co. 800-726-7007 305-376-8800 1 CERTIFICATE OF OATH 2 3 STATE OF FLORIDA) 4 COUNTY OF DUVAL ) 5 6 I, 7 Samantha Cordova, FPR, and a Notary Public, State of 8 Florida, certify that CYNTHIA RILEY personally appeared 9 before me on January 15, 2013, and was duly sworn. 10 WITNESS 11 my hand and official seal on this 18th of January 2013. 12 13 14 15 Samantha Cordova, FPR 16 17 18 19 20 21 22 23 24 25 Page 92 Veritext Florida Reporting Co. 800-726-7007 305-376-8800 1 REPORTER'S CERTIFICATE 2 3 STATE OF FLORIDA) 4 COUNTY OF DUVAL ) 5 6 I, 7 Samantha Cordova, FPR, certify that I was authorized to 8 and did stenographically report the deposition of 9 CYNTHIA RILEY; that a review of the transcript was 10 requested; and that the foregoing transcript, pages 1 11 through 92, is a true record of my stenographic notes. 12 I further 13 certify that I am not a relative, employee, attorney, or 14 counsel of any of the parties, nor am I a relative or 15 employee of any of the parties' attorney or counsel 16 connected with the action, nor am I financially 17 interested in the action. 18 19 DATED on 20 this 18th of January, 2013, Jacksonville, Duval County, 21 Florida. 22 23 24 Samantha 25 Cordova, FPR Page 93 Veritext Florida Reporting Co. 800-726-7007 305-376-8800 1 In re: JP MORGAN CHASE BANK, N.A. vs. EDUARDO OROZCO, et al, 09-29997 CA (11) 2 DEPOSITION OF CYNTHIA RILEY 3 TAKEN - 01/15/2013 4 DATE SENT TO WITNESS: January 18, 2013 5 6 TO: CYNTHIA RILEY c/o Mr. Jonathan Weiss 7 Simpson, Thacher & Bartlett, LLP 1999 Avenue of the Stars 8 29th Floor Los Angeles, California 900067 9 Dear Mr. Weiss: 10 The referenced transcript has been completed and 11 awaits reading and signing. 12 Please arrange to have Ms. Riley read and sign the transcript. The transcript is 92 pages long, and you 13 should allow her sufficient time. 14 Please complete by February 18, 2013. 15 The original of this deposition has been forwarded to the ordering party, and your Errata Sheet, once 16 received, will be forwarded to all ordering parties as listed below. 17 Thank you. 18 19 20 21 22 Samantha Cordova, FPR 23 24 25 cc: ROLAND E. SCHWARTZ, Esquire MICHAEL J. WRUBEL, Esquire Page 94 Veritext Florida Reporting Co. 800-726-7007 305-376-8800 1 2 E R R A T A S H E E T 3 DO NOT WRITE ON TRANSCRIPT - ENTER CHANGES 4 In Re: JP MORGAN CHASE BANK, N.A. vs. EDUARDO OROZCO, et al, 09-29997 CA (11) 5 DEPOSITION OF CYNTHIA RILEY 6 TAKEN - 01/15/2013 7 PAGE NUMBER LINE 8 NUMBER CHANGE/REASON 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 Under penalties of perjury, I declare that I have read the foregoing document and that the facts stated in it 24 are true. 25 ____ Page 95 Veritext Florida Reporting Co. 800-726-7007 305-376-8800 1 Date CYNTHIA RILEY 2 cc: SAMANTHA CORDOVA 3 ROLAND E. SCHWARTZ, Esquire MICHAEL J. WRUBEL, Esquire 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 96 Veritext Florida Reporting Co. 800-726-7007 305-376-8800 & & 1:21,25 2:17 8:8 10:24 94:7 0 01/15/2013 94:3 95:6 09-29997 1:3 94:1 95:4 1 1 3:9,10 69:19,20,24 82:5 83:16,19,23,23 87:23 93:10 10 31:22,24 48:24 49:2 58:8 10:00 1:14 10th 84:10 11 1:3 38:16 65:9 94:1 95:4 11th 1:1 12 31:22,24 48:24 49:2 58:8 61:20 62:20 68:6,20,22 12:23 1:14 91:9 12:56 84:13 15 1:13 92:9 18 94:4,14 1850 2:5 18th 92:11 93:20 1987 15:16 1988 15:17 1990s 54:4,8,9 1999 2:18 94:7 2 2 58:7,18 85:19 20 21:16 22:2 200 58:10 2000 54:5 61:17 2002 29:17,22 30:2 30:4 32:2,6 2004 29:1,2 32:6 33:7,10,19,23 35:6 35:9 36:17,18,19 38:18 39:17 42:19 46:10 49:20,22 52:5 62:1,12 64:7,8 70:20 78:19 79:24 80:2 82:21 2005 54:5 2006 22:22,25 38:16 38:19 39:17 42:19 46:10 52:5 57:16 61:1,15,18 62:13,18 63:9,17,17,25 64:4 64:6,16,23 68:7 70:20 78:19 79:24 82:21 2008 37:2,6 54:6,6,7 2009 65:7,10 67:23 2010 84:11 2013 1:13 92:9,11 93:20 94:4,14 25 4:22 9:5 11:24 15:16 21:17 251 2:12 29th 2:18 94:8 3 3,000 58:7 30 31:17 38:22 40:8 40:10 300 58:11,18 32202 1:16,22 33301 2:5 33328 2:12 345 1:15,21 4 4 3:3,4 40 38:22 40:1,8,10 401 2:4 4801 2:11 5 50 43:13,13 6 6 84:9 60 86:17 69 3:9 6:24 85:20 7 77 3:5 7757 76:11,12 86:13 8 83 3:10 89 27:12 9 900067 2:19 94:8 92 93:11 94:12 a a.m. 1:14 ability 5:18 able 39:21 74:5 absolutely 40:13 45:21 46:5 82:3 84:8 85:1,16 86:8 87:24 89:24 absorbed 22:16 accept 74:10 75:16 access 50:10,21 51:19 account 10:13,17 17:13 accounting 7:20 8:1 accuracy 46:16 47:17 48:2 accurate 13:17 79:14 acknowledged 4:9 acquire 48:21 acquired 4:24 5:2 17:5 26:17 27:5 action 93:16,17 activities 63:2 activity 18:24 actual 41:19 address 28:13 74:25 74:25 75:9 76:9 89:22 addressed 76:5 administration 7:7 7:9 advise 23:18 affect 89:6 affiliates 4:21,23 agencies 65:22 agency 34:23 ago 5:21 9:3 21:17 76:20 ahead 13:8,9 20:4 22:3 24:18 27:9 30:21 33:23 36:7 41:8 43:16,22 45:9 46:7 47:24 57:5 58:12 62:15 70:14 78:5 82:9 86:7 88:6 89:18,18 al 1:7 94:1 95:4 alamanza 30:14 31:2 32:9 33:2,11 33:14 allow 81:5 94:13 allowed 91:2 ambiguous 23:14 27:19 33:21 37:11 38:6 41:17 43:22 45:18 49:5 61:3 67:4 american 12:1 15:8 15:12 16:4 17:2,5,9 18:2,11,13,14,15 20:12,19 21:23 24:21,23 26:1,6,13 26:16,17,22 27:5,23 28:4,5,9 39:9 40:18 angeles 2:19 94:8 angst 89:23 answer 20:10 21:25 26:12 31:20 32:25 37:14 39:11,22,23 39:24 47:16 55:1 56:14 57:11 64:19 64:21 answered 27:9 43:16 45:1 47:22 57:4 [& - answered] Page 97 Veritext Florida Reporting Co. 800-726-7007 305-376-8800 answers 79:2 anybody 11:7,10 17:6 28:5 32:8 88:7 anymore 9:9 apologies 6:22 apologize 15:2 appear 70:5,8,18 appearances 2:1,8 2:14 appeared 92:8 appears 70:18 84:8 applicable 74:12 application 14:20 applied 69:2 appropriate 74:12 approximately 9:4 9:20 11:15 15:16 16:25 28:24,25 31:12 38:3,18,22 43:9 54:1,15 58:6 58:10,18 64:5,6 area 8:2 12:6 13:3 15:3,17 17:25 33:11 33:17 41:6 51:17,17 58:6 61:14,14 87:17 arrange 94:12 arranged 19:3 ascertain 29:8 asked 27:9 43:3,15 44:16 45:6,15,18 47:22 57:4 72:18 73:22,22 86:15 89:22 asking 21:4 29:4,6 29:12 39:19 42:17 73:6,8,10,19,20 82:11 86:13 88:23 assigned 79:20 assist 8:19 assistance 67:12 associates 1:21,25 8:8 10:24 association 84:4 assuming 58:8 assure 72:12 assuring 73:18 attorney 93:13,15 attorneys 71:14 74:9 audio 4:5 auditing 65:22,23 65:23 66:9,16 67:2 authority 37:8 48:25 69:6 88:4,8 authorization 80:25 81:13 authorize 81:1,5 authorized 75:16 80:22 88:10,12 93:7 avenue 2:18 94:7 awaits 94:11 aware 71:13 72:10 72:24 b b 3:7 back 9:5 11:23,24 15:15 25:25 28:25 29:22 36:17 44:17 44:25 45:14 50:19 50:19 53:8 54:10,17 61:13 62:10 65:4,10 67:14,23 80:2 86:24 86:25 90:5,11,22 background 40:14 40:15,15,16,22 bank 1:4 4:4 12:1 13:19 16:4 18:24 21:24 34:23 36:21 36:23 37:1 42:6,7 94:1 95:4 banking 9:5,12,24 10:8,10 banks 4:24 bartlett 2:17 94:7 basement 20:16 basically 59:18 bayberry 76:11,13 bayview 42:5 began 29:8 beginning 45:2,3 believe 70:3 88:7 89:20 best 5:18 54:14 beyond 40:22 72:3 bigger 27:1 bit 54:11 61:25 blank 30:17,22 51:20,22 blog 85:19 board 18:8,17,20 19:8,20,23 20:6 67:14 borrower 4:4,6 13:24 14:22 28:13 47:6 85:23 borrower's 90:15 borrowers 16:20 67:8,10 89:25 boss 31:3 bought 18:13 boulevard 2:4 box 13:11 boxed 14:3 boxes 12:21 break 57:17,20,22 71:9,11 82:15,18 90:25 breath 72:5 84:23 brenda 34:7,9 brendle 34:7,9,25 35:11 brief 6:16 briefly 37:17 bringing 18:7 broad 38:7 brought 19:8,20,22 20:6 27:17 building 28:22 63:3 89:10 built 53:23,24 57:10 63:3 bulk 41:19,22 42:12 42:20 43:5,8,12 bus 10:3 business 7:7,8 82:21 83:4 buying 41:24 c c 94:6 ca 1:3 94:1 95:4 cabinet 50:14,20 cabinets 50:15 california 2:19 11:3 12:3 15:11 26:2,7 26:17,23 27:1,23 28:2 36:15 94:8 call 16:20 67:12 68:11 83:14,15 86:11,12,19 87:5 89:25 90:3,7,12 called 8:10 86:24 89:21,22 90:5,8,10 90:11,20,22 calling 86:12,15,20 86:24 calls 6:25 16:20 24:17 70:12,24 86:9 86:10,23 87:4,15 89:6,12 capacities 16:2 capacity 7:15 8:9 9:18 12:4 captured 55:7 card 50:10 51:19 care 6:20 13:5 19:16 40:3,8 74:14 75:2 career 87:1 career's 86:21 carolina 53:23 57:9 61:5,9,24 62:22,25 63:12,16 64:3,12 68:4 69:4,11 77:6,9 77:22 78:1,8,13,16 case 1:3 6:3,10 21:24 40:19 60:14 [answers - case] Page 98 Veritext Florida Reporting Co. 800-726-7007 305-376-8800 80:15,16 85:23 90:15 cases 80:17 cc 94:25 96:2 cease 36:25 center 16:20 17:10 centers 25:24 central 20:7 certain 30:4 53:20 58:19 certainly 49:6 71:5 89:19 certificate 92:1 93:1 certify 92:8 93:7,13 chain 85:18,19,21 chance 83:10 change 22:14 83:17 95:8 changed 22:16 61:1 67:21 changes 68:18 71:6 95:3 chase 1:4 4:3,18,21 4:21,23 94:1 95:4 check 13:16 60:4,5 checked 12:16 48:2 50:16,19 checking 15:21 58:14,17 checks 59:22,23 chronological 23:19 chronologically 23:18 cindy 1:11 2:14 80:15 circuit 1:1,1 82:16 city 10:22 claim 86:16 clarify 55:15,16 73:6 74:24 clarity 11:5 clear 14:4 19:13 21:9 42:23 46:2 54:7 64:14 72:21 73:11 close 35:5 62:5 closed 35:4 61:4 62:1 64:16 closing 35:3 82:22 82:24 83:4 coach 55:9 coaching 55:11,13 55:19 code 87:17 collateral 20:1,2 24:11 50:10 collected 24:10,11 collections 19:10 college 6:15,15 7:2 7:11 10:7,14 colorado 7:5,14 10:20,21,23 11:1 combination 24:22 come 19:6 28:2 57:8 59:8 61:13 62:18 74:5 81:10 89:9 comes 42:4,4 46:15 85:12 coming 20:23 43:21 47:12 58:5 comment 84:10 communication 81:20 companies 21:7 company 10:13 34:24 compared 58:19 comparing 58:21 complete 94:14 completed 94:10 compound 62:14 computer 44:2 concerned 71:16 73:16 concerns 71:18,21 72:1,6,8,14,25 73:3 73:8,9,12,20 85:5 concluded 91:9 conclusion 24:18 confidential 35:16 36:7 71:17 confused 21:8 44:13 44:19,21 61:25 connected 93:16 connection 45:16 consider 22:3 contemporaneously 44:11 45:22 context 45:25 continue 22:1 53:4 continued 52:24 62:3,9 63:14 65:1 contractor 8:17 control 60:9 coordinated 18:7 63:1 coordination 19:4 copies 12:22,23 copy 60:7 69:25 cordova 1:20 92:7 92:15 93:7,25 94:22 96:2 corporate 84:16 correct 5:3 6:12 14:24 19:17 23:1 28:13 30:7,9 32:13 32:16 36:22 38:20 42:13 44:5 48:6 51:13 54:12,13,24 56:4 58:9 59:6 60:10 63:18 64:24 65:2,16,17 75:18,23 77:23 79:15 85:11 85:14 corrected 47:8 correction 60:6 correctly 18:23 correspondence 17:15 counsel 90:15,17 93:14,15 counterparts 78:2 county 1:1 76:17 92:4 93:4,20 couple 7:12,13 17:1 18:1 36:19 71:10 course 87:20 courses 7:24,25 8:2 court 1:1 75:5 creator 50:4 credit 13:10 14:2,12 14:12,16 15:1,20,21 19:24 34:23 cross 3:5 77:2 cure 47:3,4 cured 46:25 47:1 curious 59:4,11 custodial 52:21 61:23 62:7,17 custodian 28:20,21 32:12,14,17 46:16 46:17 47:18 48:3 52:14,15 56:23,25 83:1 custodians 57:2 customer 16:18 17:9 19:11 customers 16:22 67:12 cut 12:19 13:24 cynthia 3:3 4:8,16 80:16 92:8 93:9 94:2,6 95:5 96:1 d d 3:1 60:20,20 dade 1:1 data 19:18 25:10,12 25:13,18,19,23 28:12 29:23 30:5 58:15,17,19,19,21 58:22,24 60:5 66:15 date 1:13 28:12 36:13 94:4 96:1 dated 84:10 93:19 dates 72:17 davie 2:12 day 21:20 40:10,11 50:18 58:5,11,18 [case - day] Page 99 Veritext Florida Reporting Co. 800-726-7007 305-376-8800 89:21 days 83:2,4 deal 19:3 20:1 dealing 17:14 deals 39:4,7 dealt 14:12 dear 94:9 december 63:17 declare 95:23 decreased 87:10 deed 82:22 deeds 20:5 default 65:13 67:15 67:15,17 defaults 65:18 67:14 defendant 2:22 defendants 1:8 2:8 3:9 69:20 defense 69:19,24 degree 7:8,22 delivered 39:4,6 delivery 23:22 31:5 35:25 36:9 38:12,15 38:18,24,25 42:12 42:18 46:18 61:8 63:7,8,10,13,16 64:15,22 70:10 denver 11:1,1 department 19:9,11 22:21 23:5,21,24 36:9 37:15,20,22,23 38:3 39:1,4 42:18 42:21 47:20 48:5 57:14,15 61:4,6,7 65:1 88:15 departments 19:5,7 22:16,17 38:11 66:25 67:24 68:17 deposition 1:10 4:5 4:7 5:5,7,11 6:7,11 11:7,13,14 40:5,7 43:21 44:5,14,24 45:11,19,25 71:15 73:9 82:6 83:16 85:6 91:3,9 93:8 94:2,15 95:5 deutsche 42:6,7 developed 77:18 developing 77:15,20 difference 37:18 differences 56:10 different 37:16 47:7 52:21 54:23 56:3 80:14 diligence 19:4 direct 3:4 4:12 direction 69:11 directly 77:5 discussions 89:21 disseminated 73:21 disturbing 89:15 division 65:13 document 69:25 83:9 95:23 documents 11:18 14:10,19,25 doing 15:8 17:18 18:15 31:24 49:6 60:12 62:19 67:8 83:15 door 46:15 89:10 doors 51:18 drive 2:11 dual 78:7,16 due 19:4 duly 4:9 92:9 duties 10:18 35:20 duval 92:4 93:4,20 e e 2:3 3:1,2,7 10:15 51:4,4 94:25 95:2,2 95:2 96:3 earlier 56:1 east 1:15,21 2:4 eduardo 1:7 2:22 85:20 94:1 95:4 education 6:14 effect 78:17 effective 36:12,13 effectively 19:16 29:15 efficiently 59:19 either 5:8 33:3 elaborate 47:4 50:13 51:15 71:25 electronic 25:19,22 electronically 25:17 element 60:5 employed 4:17,19 employee 4:3 16:4 93:13,15 employees 16:8 38:4 38:22 69:4,10 77:5 employer 80:22 81:5 employers 81:20 encompassed 37:23 ended 62:12 86:19 endorse 33:3 58:1 79:25 80:3 83:1 endorsed 28:19,24 29:5 30:2,6,10,11 32:12 46:17 48:3,4 48:7 52:13 82:22 endorsement 30:11 30:13,22 31:16,23 33:10 51:21,22 58:4 70:4 77:16,20 78:10 83:3 endorsements 30:17 30:18 31:25 41:5 48:9 54:10 57:25 80:8 endorsing 29:8,14 29:21,23 32:22 33:1 48:14,18 77:25 79:13 ends 71:22 72:7 ensure 25:10 56:15 ensured 47:17 entail 16:19 17:12 68:15 enter 95:3 entered 9:11 entities 18:22 20:19 21:3,10 28:1 39:9 42:2,2 65:23 entry 85:19 errata 94:15 escrow 17:13 esquire 2:3,10,16 94:25,25 96:3,3 et 1:7 94:1 95:4 evolve 22:9 evolved 22:13 23:19 exactly 35:18 49:18 53:25 55:3 56:5,16 62:11,19 examination 1:19 3:4,5 4:12 77:2 example 47:1,10 examples 47:11 excuse 10:12 52:11 excused 91:8 executive 10:13,17 executives 84:16 exhibit 3:9,10 69:19 69:20,24 82:5 83:16 83:19,23 84:9 85:18 87:22,23 existence 64:4,7 expert 15:2 explore 41:6 extent 74:19 75:9 eyles 51:2 59:6 60:15 f facility 29:9 facsimile 48:8,11 49:3 51:25 52:7,9 70:9,18 fact 39:8 77:5 78:9 85:25 90:12 facts 73:15 95:23 fair 78:21 [day - fair] Page 100 Veritext Florida Reporting Co. 800-726-7007 305-376-8800 fannie 39:14,16,20 41:14,18,20,23,24 42:12,21 43:6 far 5:12 6:14 9:6 13:5 34:1 41:22 51:25 56:9 64:15 81:21,23 87:8 88:25 fashion 85:14 february 94:14 fed 25:14,17 feel 85:2 feeling 84:24 female 51:5,6 file 14:3,12,13,16 15:1 19:24 24:9 files 12:6,11,16,21 12:22 13:5,10,14,22 15:21,21 19:18,19 19:22 20:1,2 24:10 filled 14:22 film 13:23 filmed 14:11 films 13:23 14:5 finally 86:25 financially 93:16 find 47:3 59:24 86:17 fine 13:21 31:18 79:2 83:12 88:25 finish 90:9 firm 4:2 first 11:11,14,24 25:25 34:11 36:20 53:7 70:2 85:19 fitch 65:25 66:2 five 76:25 floor 2:18 94:8 florence 53:23 57:9 61:5,9,24 62:22,25 63:11,16 64:2,11 68:3 69:4,10 77:12 florida 1:1,16,22 2:5 2:12 33:24 36:10 52:21 74:12 92:3,8 93:3,21 follow 45:18 81:24 88:13 followed 77:18 82:1 88:15 89:14 following 59:21 follows 4:10 forced 17:14,15 foreclosure 83:24 84:1 foreclosures 19:10 foregoing 93:10 95:23 form 20:8 23:13 27:18 28:7 29:4 30:19 32:24 33:13 33:20 35:14 36:4 37:10 38:5 39:10,18 41:16 42:15,16 43:15,20 45:17 46:13 47:22 49:4 52:1 54:25 55:9,22 56:12 57:4 58:12 59:20 61:2 62:14 64:10,17 65:3 66:20 66:21 67:3 69:7 70:11 71:1,4 73:2,5 74:19 77:24 78:4,14 78:24 79:6,11,21 80:24 81:4,7,11,16 81:18,22 82:4,23 83:7 85:9,15 86:6 86:22 87:7,11,16,21 88:1,5,14 89:8,17 90:2,21 formality 75:7 forms 14:20,22 forsyth 1:15,21 fort 2:5 forth 36:18 forty 38:9 forwarded 94:15,16 foundation 70:13 71:3 fpr 1:20 92:7,15 93:7,25 94:22 frame 44:15 frames 56:25 57:6 frankly 72:3 fraud 81:14 freddie 39:14,16,21 41:14,18,20,22,24 42:13,21 43:5 frequency 87:10 freshly 21:11 front 85:25 full 50:8,12 function 22:21 53:4 66:22 functions 23:25 24:3 26:10 66:24 78:6 further 55:10 93:12 g gas 8:11,16,18 generally 15:1 19:12 43:1 63:2 87:15 gentleman 85:25 getting 11:5 14:23 21:1,7,9 40:14 55:4 87:12 girl 10:3 give 90:19 given 5:5,7,11 glad 70:17 gmc 42:7 go 6:14 7:4 9:5 10:4 11:24 13:8,9 15:5 15:15 18:21 20:4,11 20:13 22:3 24:18 27:9 30:20 33:23 36:7 41:8 43:16,22 45:9 46:7 47:24 52:13,24 54:10 57:4 58:12,22 61:13,14 62:14 70:14 72:23 75:14 78:5 80:2 82:9,25 84:9 86:7 86:21 87:18 88:6 89:7,18,18 goes 41:21 74:4 going 10:4 15:5 18:14 21:15,19 28:24,25 35:7 39:21 40:5,11 41:22 61:13 64:22 71:22 72:4 73:17 82:11 86:21 87:1,2 goldman 42:6 good 16:13 graduate 7:15 grayrobinson 2:4 4:2 74:10 greater 37:7 grew 22:16 23:7 grounds 35:17 36:5 group 15:22 groups 67:9,11 growing 9:25 guess 9:8 27:7,13 32:19 37:4,5 54:3 66:5 guessing 6:8 30:3 guys 40:9 44:23 45:8 h h 3:7 95:2 half 15:9,20 16:15 hamlet 83:24 84:1 hand 8:8 10:24 79:25 80:8,19,21,23 92:11 happen 6:23 19:6 87:1 happened 33:19,22 61:1 87:2 harassed 74:6 head 6:2 16:9 headquarters 15:12 health 10:13,14 heard 84:1 hedquist 1:21,25 help 62:24 86:18 [fannie - help] Page 101 Veritext Florida Reporting Co. 800-726-7007 305-376-8800 helped 63:4 68:16 78:15 helping 61:23 68:3 hi 4:1 hide 84:22 hills 53:12,13,16,19 53:22 56:19 57:1,3 62:10 history 5:5 10:11 11:23 23:4,10 home 24:5 89:7 homes 84:20 hours 11:17 house 75:15 huh 10:16 19:18 33:15 hung 90:4 hunted 85:2 husband 89:16,19 i idea 27:8 identification 3:8 69:21 83:20 identify 86:16 illinois 53:14,16 imaged 13:22 14:13 images 12:15 13:12 13:13,15 immediately 61:16 implement 68:16 implementing 77:16 implying 66:17 improper 74:20 improprieties 74:16 74:18 impropriety 75:10 improvement 68:12 68:14 improvements 68:17,19 included 41:14 indicate 74:9 indicated 25:2 27:4 30:24 32:11 34:25 41:14 44:4 51:11 54:11,22 56:1,17 57:24 59:5 63:6 individual 58:16 59:16 60:11 individuals 15:25 18:6 60:12 industries 8:18 industry 8:11,16 9:5 9:12,24 10:8 information 19:5 28:16 35:13 36:7 45:24 46:1 58:25 59:2 65:12,19,21,22 66:1,4,8,18 67:1 72:7 initially 28:6 53:8 56:18 86:16 input 25:12 inputted 25:13,22 inspected 56:15 institutions 5:2 instruct 21:25 instructing 55:12 insurance 10:12,13 17:11,14,15,25 intend 41:5 interested 10:1 93:17 internet 72:2,9,11 72:23 73:18 84:4 89:5,13,15 interrupt 13:20 interrupting 40:9 44:23 45:9,13 interruption 6:16 investors 41:23 involved 13:3 22:22 24:2 25:2 61:23 62:18 67:14 77:15 77:19 79:6 88:25 irrelevant 22:2 30:20 issue 40:1 74:2 75:12 issued 21:11 j j 2:10 94:25 96:3 jacketed 12:17 13:12,24 jackets 12:19 jacksonville 1:16,22 33:24 34:18 35:25 36:10,15 46:10 51:9 52:20 53:7 57:25 58:6 60:23 61:12 62:8 63:10,11,14,19 64:22 76:14,17 77:11,13 78:7,19 79:24 82:20 93:20 jacksonville's 64:14 january 1:13 35:6 36:16 37:4,6 65:5,6 65:10 92:9,11 93:20 94:4 jay 2:11 jc 9:13 jcpenny 9:21 11:2 jcpenny's 9:14,17 jess 30:14 31:2 32:9 33:2,11,14 job 7:17 8:5,7,22 11:25 13:11 16:19 18:19 19:4 21:16,17 22:9,13 26:9 36:17 49:6 59:17 65:4 68:24 69:2 85:7,10 89:13 jobs 9:11,23 join 21:21 30:20 33:22 35:18 37:12 52:2 69:8 70:12 jonathan 2:16 11:8 88:17 94:6 jp 1:4 4:18 5:8 9:13 11:2 34:15 51:7 60:21 65:2,5 94:1 95:4 judge 88:20 judicial 1:1 june 33:9,10,19 36:17,18,19 38:18 39:17 42:18 46:10 49:20,22 52:5,5 61:15,17 62:12 70:19 84:10 k k 10:15 karen 16:12 60:18 keep 40:9,23 44:23 45:8 kept 86:24 kind 59:11 72:6 89:14 knew 42:19 88:9 know 6:3,8 9:4,8,9 9:20,25 10:5 14:9 14:18 20:21,23,25 20:25 21:4,5,5 22:1 23:10 25:12,22 26:4 26:5,12,20,22,25 27:4,12 28:8,25 29:2 30:1 31:9 32:20 33:8 34:10,14 34:17,19 36:13,14 37:3 39:15,23,25 41:19 42:8,10 43:10 43:12,17 49:17,21 50:4,6 52:6,15 53:16,17,24 54:6,7 54:20 55:3,6 56:5,8 56:9 57:6,10,12,13 58:6 59:11 63:1 64:5 66:7 67:19 69:16 71:13 72:20 75:4 76:20 77:8 78:9 79:9,16,18,22 87:8 88:3,18,23 knowing 9:10 knowledge 31:22 32:18 51:24 54:14 54:18 60:21 62:9 [helped - knowledge] Page 102 Veritext Florida Reporting Co. 800-726-7007 305-376-8800 known 21:6 l l 30:16 51:4 lack 71:2,2 lacks 70:13,13 laid 64:18,25 65:1,4 65:8 68:23,24 laman 8:12 landman 8:10,13,14 language 7:21 las 2:4 lauderdale 2:5 law 4:2 74:12 90:3,6 90:12,17 lawyer 73:12 lawyers 89:25 lead 50:15,22,25 60:13,16,17 leader 38:1 59:6 leading 33:13 37:16 37:18,20 learn 40:21 leave 57:15 left 7:16 8:4 52:13 53:5 57:14 86:25 legal 8:20,25 24:17 73:12 75:12 lehman 42:4 letter 14:17 letters 83:15 level 84:19 life 89:6 line 95:7 list 11:4 listed 94:16 litigation 69:18 82:13 88:22 89:1 little 9:17 54:11 61:25 live 60:6 llp 2:17 94:7 loan 12:24 13:14 14:10,19,23 19:11 23:23 24:5,6,7,7,9 42:24 43:19 44:11 45:23 47:14 loans 18:10,12,20,22 18:25 20:24 21:1,4 21:6,11 24:13,14,20 28:11 39:14,16,20 41:13,17,18,24 42:11,20 43:5,8 46:12,23,25 58:15 58:18 located 10:25 12:2 20:15 26:1 28:21 86:13 location 20:7 50:9 53:12 63:14 86:18 locations 53:10 57:3 62:17 63:13 locked 50:14 log 50:16 logged 50:19 long 4:19 8:22 9:3 9:20 15:7 16:14,24 17:24 21:13 22:6 29:2 33:6 38:14 45:12 64:5 67:1 84:22 94:12 longer 65:14 looked 12:15 68:16 looking 67:12 86:17 89:10 los 2:19 94:8 lot 89:11 low 84:19 lurking 89:11 m m 3:2 30:16 major 7:6 making 17:13,13 28:16 36:16 86:4 male 51:5 manage 38:11,14 47:15 managed 38:17 46:14 59:14 62:20 70:10 management 61:19 61:21 63:4 65:12,18 65:21 66:8,18 manager 34:5,6 36:9 50:15,22,24 51:1 59:5 60:13 managing 37:15,18 37:20 38:3 59:12 manner 88:12 manufacturing 79:7 march 74:4 mark 19:1 69:19 83:18 marked 69:20,23 83:19,22 market 41:13,25 46:12,24 47:15 marketing 39:5,7 master's 7:16,19,22 7:25 8:2 matched 25:11 28:16 matching 28:13 material 16:6 materially 70:22 matter 6:11 74:3 82:21 83:2,4 86:4 maturity 28:12 mean 21:22 24:8 25:16 36:2 44:22 47:5 54:4 59:11 66:7 82:16 85:6 meaning 12:19 meet 11:10 meeting 11:9 63:2 meetings 63:1,1 memory 16:13 mentioned 15:15 67:13 mentioning 7:2 message 86:25 87:18 met 11:8,14 miami 1:1 michael 2:10,11 94:25 96:3 microfilm 14:5,7 middle 84:10,15 mike 21:15 45:10 miller 8:8 10:24 mind 42:4,4 47:12 57:20 mine 78:6 mineral 8:21 minute 66:10 82:15 90:9 minutes 21:16 22:2 31:15,17 40:1,8,10 71:10 76:25 86:17 mis 65:12 66:1,11 66:22 67:5,15,22 68:1,25 69:2 misconstruing 85:13 86:4 misstated 26:19 misstates 56:20 modifications 19:10 money 36:3 month 33:8 37:3 68:6,20,22 months 36:19 61:20 62:20 84:21 moody's 65:25 66:2 moran 16:12 morgan 1:4 4:18 5:8 34:15 51:7 60:21 65:2,5 94:1 95:4 morning 50:16 mortgage 34:24 58:25 move 34:2 61:9,23 62:24 78:15 moved 12:7 15:22 18:17,25 33:24 36:18 46:16,17 48:3 61:4 62:7 71:14 78:12 [known - moved] Page 103 Veritext Florida Reporting Co. 800-726-7007 305-376-8800 movement 23:23 24:5 62:21 moving 34:1 61:22 multi 26:18 multiple 49:13 50:4 mutual 17:7 24:25 26:8,13,25 27:5 42:10 85:8,11 mutual's 39:16 n n 3:1,2,2 30:16 n.a. 1:4 94:1 95:4 name 4:1,14 6:3 28:13 34:22 38:25 39:3 46:19 47:7 48:20,20 49:15 51:3 66:8 80:3,5 81:2,6,6 81:9 84:5 85:20 89:12 names 32:8 48:16,21 nature 12:23 necessary 88:20 need 10:5 14:18 55:16 57:17 75:14 75:19 79:1 needed 50:17 60:6 63:3 68:17 needs 50:5 never 56:9,15 58:3,4 new 5:25 6:1 16:7 69:2 nice 57:18 night 50:18 nine 49:13 54:11 nods 6:2 normal 9:25 normally 14:16 notary 1:20 92:7 note 11:20 14:7,9 24:1 25:3,6,7,9,11 25:21 29:13 37:25 40:2,4 41:4,5 44:6,8 44:9 45:3,16,24 46:2,20 47:1,7,7,17 48:9,23,25 49:9,10 50:10,20 51:12 58:20,22 59:1,3,9 60:7,14 69:15 77:16 82:7,25 83:3 notes 12:23 13:1 20:5,6 24:14 27:16 27:22 28:1,11,12,19 28:23 29:5,9,14,21 29:24 30:1,5,10 32:11,15,23 33:1,3 39:8 46:15,15 47:19 48:14,18 52:12,16 52:20,24 53:8,11 56:18,22 58:1,4,5 58:11,14,17 59:1 62:10 77:25 79:13 79:25 80:3,23 81:6 81:10 82:22,24 93:11 notified 35:7 november 22:22,24 38:19 39:17 42:19 46:10 52:5 57:16 61:1,18 62:13,18 63:9,17,24 64:4,6 64:16 65:9 68:7 70:20 number 22:8 86:23 87:18 90:4,10 95:7 95:8 numbers 83:15 o o 3:2 60:20,20 94:6 oath 4:10 92:1 object 13:7 20:3 21:15 23:13 24:17 27:18 28:7 29:4 30:19 31:14 32:24 33:20 35:12,14,15 36:4 37:10 38:5 39:10,18 40:16,24 41:2,16 42:14 46:13 49:4 52:1 54:25 55:8 56:12 59:20 61:2 64:17 66:21 67:3 69:7 70:11 74:16,21 75:11,21 79:1 82:11 objected 46:7 objection 13:18 20:8 21:21,22 26:19 36:5 39:18 41:7 44:10 55:2,22,23 56:12,20 70:24 73:5 77:24 78:4,11,14,24 79:11 79:21 80:24 81:4,7 81:11,16,18,22 82:4 82:23 83:7 85:9,15 86:6,22 87:7,11 88:1,5,11,17,19 89:8,17 90:2,21 objections 45:17 obligations 19:16 obviously 6:17 21:25 75:12,13 occasions 80:20 occurred 23:24 50:21 82:24 ocwen 42:4 offer 35:10 offered 35:2 36:17 office 61:5 63:12,14 82:25 90:3,6,13,17 official 92:11 oh 8:14 23:21 45:1 89:25 oil 8:10 okay 4:14,19,23 5:7 5:20,24 6:3,6,10,25 7:2,18 8:1,24 9:2,4 9:10,16,23 10:6,10 11:18,21,23 12:13 13:5,13 14:4,18,21 15:2,10,19 16:16,24 17:5,16 18:9 19:2,7 19:13,25 20:12 21:2 21:8,13 22:10,13,18 22:23 23:2,6,15,16 24:4,13,24 25:16,20 25:25 26:11,15,24 27:3,11,14,21 28:5 28:10,15,21 29:20 30:4,10,12,17,24 31:2,4,12 32:1,22 33:2,5,16 34:1,14 34:23,25 35:3,5,8 35:23 36:14 37:17 37:24 38:2,11,14 39:2,6 41:9,21 42:2 42:9 43:18 44:4,8 45:6 46:21 47:2,9 47:19 48:4,7,10,20 48:24 49:8,23 51:1 52:11,18,25 53:3,10 53:21 54:8,17,22 56:9,17,24 57:2,8 57:15 58:5 59:4,8 59:15,18,24 60:8,11 60:14,25 61:13 62:5 63:5,15,20,22 64:5 64:8,14,19 65:10 66:12,15,17,24 67:6 67:13,20 68:10,15 68:22 69:1,3 70:4,8 70:22 71:8,23,25 72:8,14 73:4 74:14 74:22 75:20 76:7 77:8 78:9,23 82:10 82:14 83:13,14 91:7 olas 2:4 old 10:3 once 8:4 14:2 32:11 50:4 52:12 75:21,21 78:12 89:7 94:15 ones 9:25 48:10 open 81:17,19 operate 62:3 operation 64:15 operations 23:22 31:5 35:25 36:9 38:25 42:18 46:18 61:8 63:7,8,10,13 63:16 64:15,22 77:9 [movement - operations] Page 104 Veritext Florida Reporting Co. 800-726-7007 305-376-8800 78:7,12,16 order 9:9,10 17:14 17:15 19:6 46:12,23 47:13 71:15,20 72:22 ordering 94:15,16 original 94:15 originally 67:15,20 originate 28:1 originated 24:20,22 24:23 27:17,22 39:20 42:24 origination 25:24 44:11 45:22 originations 25:14 orozco 1:7 2:22 11:19 76:24 85:20 94:1 95:4 orozco's 43:19 outside 24:3 overly 38:7 oversaw 59:21 77:9 77:25 oversee 62:24 overseeing 77:21 owned 21:4 ownership 8:21 p p 10:15 p.a. 2:11 p.m. 1:14 84:13 85:20 91:9 pace 21:19 package 35:2 page 3:2,8 70:5 83:23 84:9,10 85:19 95:7 pages 93:10 94:12 paid 17:14 paper 25:18 paragraph 84:15 parallel 63:18 pardon 17:21 91:5 parking 89:11 part 20:1 36:2 63:12 76:14 particular 26:14 particularly 48:18 parties 93:14,15 94:16 partitioned 51:17 party 82:12 88:21 94:15 passing 41:13,17 pat 51:2,5 59:6 60:15,16 payments 19:10 peak 10:14,15 penalties 95:23 penny's 9:15 people 12:11 29:13 31:9,13 38:9 48:13 48:17,22,24 49:2 50:11 81:1 85:12 86:3,20 percent 43:13,14 percentage 39:15,19 39:25 41:19 43:9,10 period 23:14 29:5 32:5 38:21 52:2 53:5,15 59:13 62:11 62:12,24 63:5 68:6 68:20,22 perjury 95:23 personal 73:17 89:6 personally 33:3 43:23 44:4,6 92:8 personnel 59:23 phone 6:17 87:17,18 89:6,12 90:3 phrases 72:3 physical 17:18 19:19,22 picked 63:17 79:9 79:17 piece 37:22 place 1:15 32:15 51:12 57:7 72:22 74:8 placed 30:24 83:3 placement 17:17 plaintiff 1:5 2:1 plaintiff's 3:10 83:16,19,23 87:23 plant 62:5 pleasant 87:14 please 4:15 8:12 23:18 27:25 30:15 37:21 38:24 44:18 51:3 55:21 60:19 70:15 94:12,14 point 17:3 22:1,1 29:8 57:8 policies 20:5 81:21 81:23 82:1 popped 90:4 position 18:2 31:4 74:7 possibly 39:21 post 7:11,15 10:7 postings 89:5 power 75:5 practice 82:21 83:5 precollege 10:4 predecessors 5:9 predicate 70:13 71:2 preparation 11:13 11:19 44:14 45:19 prepare 11:7 preparing 11:16 45:25 present 2:21 presented 82:5 preserve 88:19 president 34:11,11 36:8,21,23,25 37:7 37:9,15 65:15 presume 24:14 34:12 74:5 pretty 23:4 72:5 printout 84:6 prior 26:19 29:1 33:15 56:20 63:23 64:7 privacy 35:17 36:5,6 private 41:23 probably 18:1 22:11 problem 82:17 problems 59:9,10,25 60:3 procedures 16:7 50:8,13,14 59:22 77:16,17,20,21,25 78:10,15 81:12,21 81:23 82:2 88:15 89:14 process 14:23 46:23 47:13 49:10 50:3 55:3,7 56:6,8 68:12 68:13 81:9 83:1 88:13 productivity 59:14 program 7:16,25 progress 63:3 project 61:19,21,22 62:19,20 63:4 68:19 projects 24:2 62:21 68:2,8,10,16,19 promoted 35:22 36:1,8 promotion 36:2,12 proper 76:15,17 properly 60:5 proprietary 35:12 36:6 protect 88:23 protective 71:14,20 72:22 provide 49:24 50:1 66:1,25 67:1 78:18 84:24 provided 14:22 55:5 65:21 66:15 71:17 78:19 providing 8:17 [operations - providing] Page 105 Veritext Florida Reporting Co. 800-726-7007 305-376-8800 public 1:20 86:5 92:7 publicly 73:21 purchase 18:4,5,19 18:22,25 19:12 22:20 23:22 purchasers 24:12 purchasing 20:20 21:13 22:6,18 purposes 66:4,6,9 66:19 67:2 74:25 75:8 purview 73:13 put 12:19 44:14 52:17,19 58:4 77:18 putting 85:13 q qc 60:4,8 quality 12:16 59:22 59:23,25 60:9 question 20:9 23:13 27:21,24 30:19 32:24 33:20 35:14 36:4 37:10 38:5 39:10,19,22 41:10 41:12,16,21 42:9,16 43:4 44:17,20,22,23 45:18 46:13 47:16 49:4 52:1 54:25 55:15 56:13 58:9 59:20 61:2 62:14 64:17 66:5,13,21 69:7 70:11,15 73:6 78:25 79:2,3 81:8 questions 16:21 77:1 82:12 83:18 88:23,24 90:24 91:1 quietly 84:20 r r 60:20 95:2,2 range 27:8 49:21 read 44:16,24 45:14 91:2,4,6 94:12 95:23 reading 94:11 really 6:8 13:4 20:21 22:21 27:10 72:25 reason 52:8 54:23 56:2,3 71:16 88:22 89:1 90:19 95:8 reasonable 58:13 recall 6:5,6 11:25 16:11 31:12 32:8 received 81:20 94:16 recognize 38:2 84:6 87:17 recognized 90:11,14 record 4:5,5,15 45:14 46:3 55:24,24 76:9 88:19 89:3 93:11 recording 4:6 records 8:20,25 12:6 12:7,9 13:1 14:21 19:15,17,18 reference 5:8 6:11 6:13 11:19 27:16 70:4 83:24 referenced 94:10 referred 68:6 referring 4:24 13:13 14:15 22:15 24:25 60:9 64:2,11 67:10 reflected 45:24 46:1 refused 4:6 regard 25:5 71:18 regarding 17:15 regardless 16:5 regards 12:8 24:5 25:9 28:11 42:10 43:18 46:9 49:23 51:21 52:12 56:10 58:17 59:9,13,25 65:18 88:24 related 23:25 46:14 74:16 90:17 relative 93:13,14 relevance 13:7 20:3 21:23 31:14 40:18 relevant 21:18 69:17 relocation 35:2,10 35:21 remained 22:24 remember 26:7,8 31:11,24 42:7 48:16 50:3 53:2 76:20 77:6 90:16 rephrase 27:21 41:12 report 86:5 93:8 reporter 55:21 reporter's 93:1 reporters 1:21,25 reporting 66:25 67:8 represent 4:2,3 representative 50:17 request 4:4 requested 34:1 35:1 93:10 requiring 50:10 research 8:25 researched 8:20 reservation 85:12 reservations 85:7,10 86:3 reserve 74:15,20 75:11,20 respect 35:21 55:4 60:25 75:10 respects 41:17 respond 16:21 responding 73:7 responsibilities 16:5 19:2,14 21:17 22:14 22:24 23:2,8,10,19 24:4 25:5,8 26:1 32:18,20 35:24 37:16,23 59:18 60:25 61:15 65:19 66:11,13,15 67:5,6 responsibility 37:25 66:19 responsible 12:11 16:3 results 59:23 review 11:18 24:1 25:3,6,7,9 28:3,10 29:13 37:25 43:18 44:6,9 45:4 46:20 47:17 48:23,25 49:10 50:10,20 51:12 59:3,9 60:12 60:14 82:25 83:10 93:9 reviewed 13:24 28:9 30:5 44:8 46:16 48:1,1 reviewer 49:9 reviewing 15:20 29:23 58:10 right 5:1,4 6:13 8:4 8:16 10:6,13 11:9 11:15,23 12:18 13:15 14:1,15 15:4 15:15,24 16:6 18:18 18:21 19:19 23:12 27:16 28:23 29:22 30:1 32:14 34:22 40:4,6,13,22 41:2 42:9 43:12 44:1 46:5,9 48:13 49:7 49:11 52:5,23 54:14 56:17 63:24 66:14 72:16,19 73:16,24 73:25 74:20 75:3,11 75:25 76:2 79:4 88:10 rights 18:22 20:20 21:10 24:15 74:15 75:20 riley 1:11 2:14 3:3 4:3,8,16 69:23 71:13 74:13 77:4 80:15,16 82:20 83:8 [public - riley] Page 106 Veritext Florida Reporting Co. 800-726-7007 305-376-8800 83:22 84:16 91:2 92:8 93:9 94:2,6,12 95:5 96:1 riley's 31:16 road 76:13 roland 2:3 4:1 11:8 75:2 94:25 96:3 rolled 13:23 rolls 13:23 room 50:20 51:12 52:13 run 72:4,4 84:22,23 84:23 s s 3:2,7 51:4 95:2 s&p 65:25 66:2 sachs 42:6,8 safety 84:24 sales 9:19 10:19 23:23 24:5,6,8 samantha 1:20 92:7 92:15 93:7,24 94:22 96:2 sample 55:4 78:20 79:9,16,20 savings 12:1 15:8,12 16:4 17:2,5,9 18:3 18:11,13,14,15 19:1 20:12,19 21:23 24:21,23 26:1,6,13 26:16,17,23 27:5,23 28:4,5,9 39:9 40:18 saw 11:20 45:3 56:9 68:17 saying 22:23 24:13 24:14 26:15 29:22 32:6 38:17 49:11 56:1 63:15 66:7 72:11,24 74:24 says 72:22 83:16 84:21 schwartz 2:3 3:5 4:1 4:1 9:8 13:7,18 20:3 21:21 24:17 26:4 27:9,13 30:20 31:14 32:19 33:13,22 35:12,16,18 36:6 37:5,12 38:7 40:1 40:12,15,25 41:2,7 42:15 43:15,20,22 44:13,18 45:1 46:7 47:22,24 52:2 54:3 57:4,12,17,20 58:12 62:14 64:10 65:3 66:20 67:18 69:8,16 70:12,24 71:2 73:2 73:11,15,24 74:11 74:15,19,23 75:2,6 75:8,14,18,20,23,25 76:2,5,25 77:3 79:1 79:5 82:9,15,19 83:8,12,14,21 88:16 89:2,4 90:24 91:4,6 94:25 96:3 screen 44:2,7 45:7 46:1 87:15 screening 89:12 screens 43:18 44:2 45:6,16,23 seal 92:11 seamless 26:9 sec 52:11 second 90:8,10 secondary 23:22 31:5 35:25 36:9 38:12,14,18,24,25 39:3,5,7 41:13,25 42:11,18 46:12,18 46:24 47:14 61:8 63:6,8,10,13,16 64:15,21 70:10 secrecy 81:14 secretary 84:19 secure 12:21 51:11 secured 50:6,9,19 50:21 51:18 security 50:8,12 84:25 see 60:4 84:11,17 85:19,20 89:1,10 seen 45:15 69:15,25 72:2 send 13:11 83:1 sent 32:12 47:17 94:4 serve 74:7,8,21 75:9 75:15 served 74:13 75:21 server 89:9 service 16:18 17:10 18:7,9,14 19:11 21:5 74:25 76:1 serviced 18:11,12 servicer 18:19 21:1 servicers 21:10 24:11 services 8:17 servicing 18:4,5,8 18:13,15,22,25 19:1 19:11,16 20:20 21:9 22:6,19,20,24 23:1 23:3,11,18,23 24:9 24:15 25:11,14 set 51:15 74:4 seven 84:21 shape 79:6 share 89:23 she'd 45:15 sheet 94:15 ship 12:21 57:2 62:9 shipped 12:12,12 14:3 24:11 28:19 53:1,8,11,16,18 56:18,22 57:9 82:24 shipping 12:20 13:11 57:7 62:16 short 53:4 82:16 show 83:8,11 showing 69:23 shut 35:8 63:9,11,14 shutting 35:7 side 63:4 sides 77:17 sight 87:6 sign 80:7,9,19,22 94:12 signature 30:12 31:16 48:8 49:16,24 50:1 51:25 52:7,9 55:4 60:7,7 70:6,7 70:17,21,22 79:16 79:20,23 80:6 82:6 signature's 71:5 signatures 54:23 55:5 56:3,8,10,16 78:20 79:9 signed 47:6,6 50:3 56:7 80:21 signing 94:11 similar 70:8,18 simply 10:7 13:10 simpson 2:17 94:7 sitting 85:25 sixteen 10:3 sold 24:9,14,15 39:8 39:14,16,20 41:18 41:20 42:11 43:5 46:12,24 47:14 somebody 18:13 86:12 87:23 89:11 89:22 soon 82:21 sorry 6:17 24:7 34:8 39:3 61:18 sounds 58:13 72:5 south 2:11 53:23 57:9 61:5,9,24 62:22,25 63:11,16 64:3,11 68:4 69:4 69:10 77:6,9,21 78:1,7,12,15 speak 13:4 20:21 43:10 57:1 72:17 speaking 66:10 speaks 46:3 special 24:2 51:19 [riley - special] Page 107 Veritext Florida Reporting Co. 800-726-7007 305-376-8800 specific 30:18 62:6 72:17 specifically 13:19 31:11 40:17 speculating 58:12 speculation 70:13 70:25 speculative 43:15 spell 8:12 30:15 51:3 60:19 spend 11:16 spent 21:16 spoken 40:2,4 springs 10:23 staff 48:12,14 stamp 30:11,13,25 31:6,10,23 32:9 33:3,10,12,14,16 48:8,11 49:3,7,10 49:11,12,23 51:21 52:9 55:5 58:4 79:10,14 80:3,5,10 80:13,16 81:6 88:3 88:7 stamping 81:9 stamps 49:13,14,15 49:17,24 50:2,5,6,9 50:16 51:24 52:6 54:12,24 56:4,6,11 56:15 57:25 70:9,19 78:20 79:7,17,19 81:1 standing 13:18 21:22 standpoint 23:20 73:17 stars 2:18 94:7 start 12:4 29:13 started 7:16 40:17 63:24 starts 84:15 state 4:14 53:13 68:11 92:3,7 93:3 stated 55:24 95:23 stating 89:2 stay 61:11 stayed 23:21 78:10 stenographic 93:11 stenographically 93:8 stipulating 75:22 88:17 stockton 11:3 12:3 15:11 20:17,18 24:1 25:3 27:17,23 28:2 28:17 29:9 33:5,6 33:11,14,17 35:3,4 35:5 36:15 52:24 53:1,4,8,19,22 56:18 57:1,3 61:24 61:25 62:5,10,22,25 80:2,4,8,11,13 stop 87:19 storage 12:21 stored 20:7 street 1:15,21 strictly 66:9 strike 48:25 51:20 58:15 64:20 65:17 struggling 40:19 stuff 22:2 89:14 subject 6:11 subpoena 74:5,6,8 74:10,19 75:5,11 subpoenaed 74:3 subpoenas 74:11,17 75:9 subsequently 65:4 substance 74:20 sufficient 94:13 suite 2:5,12 supervise 15:7 17:24 46:11 47:15 69:3 77:5 supervised 12:10 17:9 25:7 31:13 32:3,4 supervising 15:20 17:19,20 supervision 38:4,22 69:13 supervisor 12:10,13 16:18 17:11 29:17 30:8 59:4 81:10 supervisors 77:8,15 77:19 81:21 sure 5:17 6:9 12:16 13:16 17:13,13 19:14 26:21,22,25 28:8,16 59:19 62:11 66:3 67:11 71:20 79:16,19,22,23 sworn 4:9 92:9 system 28:14 48:2 58:20,22,23 66:18 systems 18:8 25:11 25:14,15 65:13,19 65:21 66:8 67:8,10 t t 3:2,7 95:2,2 take 4:24 5:20 6:19 7:21 19:16 22:23 23:15,17 26:15 32:14 38:17 40:4,5 40:6,11 45:11 49:19 51:12 60:8 61:15 63:15 65:14 66:17 69:15 71:9 76:6,14 76:25 82:15 84:20 89:16 taken 1:13,19 26:8 57:22 71:11 82:18 90:25 94:3 95:6 takes 40:10 57:20 74:14 talk 90:23 talked 23:3 31:15 talking 14:5 15:16 18:9,10,12 19:8 21:16,23 32:1 38:8 39:8 40:17,23 42:24 43:2,9,13 44:2,10 44:12,14 45:22 52:3 52:4 54:4 61:6 65:24 71:21 73:15 tasked 77:21 78:3 tavares 5:22 tax 14:20 17:11,13 17:24 taxes 17:14 team 12:10,13 13:6 15:20 16:9,21 18:6 24:2 28:15 29:11,23 31:13 32:8 37:16,18 37:19,20,22 38:1 50:23,24 57:24 58:10,16 59:6 teams 15:7 tell 4:9 9:10 10:2 15:5 36:1 37:17 38:24 90:7 telling 11:6 53:3 55:14 86:20 ten 31:21 48:15 49:13 54:11 tenders 83:9 tenure 70:19 term 28:12 67:11 terms 12:20 testified 4:10 42:22 55:2,6,10 73:8 78:18 79:13 testify 88:18 testimony 26:20 55:18 56:21 71:16 71:19 77:4,6 thacher 2:17 94:7 thank 6:20 27:14 63:8 94:17 thanks 89:2 thing 17:8 40:16 things 6:23 12:14,23 16:7 22:17 28:10 33:22 39:13 46:11 46:21 47:13 59:12 62:23 67:21 72:2 89:19 [specific - things] Page 108 Veritext Florida Reporting Co. 800-726-7007 305-376-8800 think 5:15 9:7 10:9 24:24 26:20 29:16 34:22 52:8 53:3 54:23 56:3 57:18 76:19 82:9 third 6:10 11:4 thirty 31:15 38:9,9 thoroughly 41:6 thought 61:25 67:20 threatening 72:4,5 85:14,17 87:5 till 33:6 38:16 time 1:14 6:19,24 8:10 9:3 11:11,14 11:15 15:10,13 20:14,25 21:6 23:14 23:15,17 26:14 29:5 29:8,21 31:25 32:1 32:4,5 34:12,17 36:20 38:7,21 40:24 44:15 52:2,22 53:5 53:15 54:15,18 55:21 56:25 57:6,8 60:1,1 61:22 62:24 63:5 70:2,9,23 71:5 77:10 87:10 90:8,10 94:13 times 5:11 50:4 56:7 86:25 title 20:5 22:20 34:10 36:2 65:14 today 72:15 73:3 74:3 85:6 86:1,9 toilet 86:21 87:2 told 9:6 35:20 41:7 72:14,20 top 83:22,23 tracked 59:16 tracking 12:11 17:17 trained 15:24 16:7 trainer 15:23 trainers 15:22 training 16:3,6,14 16:17 transcript 93:9,10 94:10,12,12 95:3 transfer 19:6 21:5 68:3 transferred 19:15 35:1 transfers 18:7,10 transition 36:16 transmittals 12:20 travelled 36:17 trial 74:4,5 true 77:14 93:11 95:24 truth 4:9 try 48:21 trying 7:18 23:9 25:16 29:7,7 40:21 55:15 84:22 turned 90:5 twelve 31:21 48:15 twice 5:13,14,15 two 5:21 8:23 11:17 57:7 59:13 62:17 63:13 82:15 type 59:12 61:21 typed 47:7 types 12:14 14:25 19:7,22 20:19 46:11 60:3 62:23 65:23 67:6 68:10 u uh 10:16 19:18 33:15 umbrella 67:16,17 unanimous 86:9,10 87:5 unclear 45:15,21 46:6 understand 14:10 17:23,23 23:9 24:24 25:17 27:24 44:1 67:11 73:14 76:4 81:8 understanding 18:23 underwriting 14:19 unh 68:21,21 unit 24:2 25:7 28:8 29:17 30:6 32:3,4 46:14,19,20 47:3,20 48:21,22,23,25 49:2 50:15 59:5,9,13,19 59:21 60:1,13,14 66:8 70:10 units 46:14,18 67:22 university 2:11 7:5 7:14 unlock 50:15 upsetting 89:12 use 49:7,9 81:1 v vague 23:14 27:18 33:21 37:11 38:6 41:17 43:22 45:17 49:5 61:3 67:3 vary 38:2 70:22 vault 20:11,13,15 32:15 52:17,18 53:23 57:10 61:24 62:7,17,21,25 64:8 68:4,20 vaults 52:22 53:21 verified 13:12 vernon 53:12,13,16 53:18,22 56:19 57:1 57:3 62:10 version 80:10 versions 80:12,13,14 versus 37:16 60:7 vice 34:11,11 36:8 36:20,23,25 37:7,8 37:15 65:15 viewed 45:23,25 vp 31:5 vs 1:6 94:1 95:4 w w 60:20,20 wait 66:10 90:9 waiving 75:7 walk 89:10 wamu 5:8 24:21,25 26:17 34:12 39:20 42:24 53:21 54:18 want 5:19 21:18 22:8,11 27:7 40:9 40:23 42:23 44:16 44:24 45:8,12,14 55:19 68:11 72:23 74:6,7 83:18 87:19 wants 88:23 washington 17:7 24:25 26:7,13,25 27:5 39:15 42:10 85:8,11 wasting 40:23 watched 85:3 watching 84:20 way 33:6 43:3 72:3 76:21 79:6 88:16 89:7 we've 21:15 46:7 72:20 91:1 website 84:7 week 86:12 weekly 63:2 weiss 2:16 20:8 21:15 23:13 26:19 27:18 28:7 29:4,10 29:12 30:19 32:24 33:20 35:14,17 36:4 37:10 38:5 39:10,18 40:6 41:16 42:14,16 42:23 43:1,3 44:10 45:10,13,21 46:5,13 49:4 52:1 54:25 55:2,8,11,13,15,17 55:18,23 56:12,20 59:20 61:2 64:17 66:21 67:3 69:7 [think - weiss] Page 109 Veritext Florida Reporting Co. 800-726-7007 305-376-8800 70:11 73:5,19,25 74:24 75:2,4,7,22 75:24 76:1,3 82:10 82:12,14 94:6,9 went 6:15 7:2 8:8,20 9:7 16:18 42:12,21 52:24 65:12 68:24 whatsoever 21:24 where'd 7:4 willing 74:9 wish 87:22 witness 1:19 3:2 4:11 6:17,20,22,25 27:14 44:21 55:9,11 55:13,20 57:18 91:8 92:10 94:4 woodward 60:18,19 60:20 word 8:15 words 14:21 56:2 work 5:4,8 7:11 8:8 9:2,7 11:23 15:8 17:18,20,22 18:16 41:20,22 46:9 51:17 59:25 60:12 61:19 65:1,12 76:10 90:1 worked 9:13,17,21 14:13 29:13 55:3 67:22 68:2,8 77:10 working 12:4 15:10 34:19,20 42:17 59:19 68:20 worries 6:21 write 12:20 95:3 wrong 46:25 87:25 88:2 wrote 16:6 wrubel 2:10,11 3:4 4:13 6:19,21,23 7:1 13:21,25 22:4,5 27:15 29:7,11,15,19 30:23 31:18,19 33:25 35:19 36:11 37:13 38:10 39:23 40:3,8,13,21 41:1,4 41:9,11 42:22,25 43:2,7 44:16,20,22 45:5,8,11,20 46:3,8 52:4,10 55:8,12,14 55:16,19,22,25 57:21,23 66:23 69:9 69:15,17,22 70:16 71:1,4,7,9,12 73:10 73:14,16,22 74:1,14 74:18,22 75:1,3,13 75:16,19 76:4,7,8 76:22 77:24 78:4,11 78:14,24 79:4,11,21 80:24 81:4,7,11,16 81:18,22 82:4,11,23 83:7,10,13 85:9,15 86:6,22 87:7,11,16 87:21 88:1,5,11,14 88:21 89:8,17 90:2 90:9,21 91:1,5,7 94:25 96:3 x x 3:1,2,7 y y 51:4 yeah 9:9 43:24 44:13,18 45:20 59:3 64:1 90:16 year 5:19 8:23 9:22 10:3 15:9,9,19 16:15,15 28:24 59:13 64:18 65:6 years 4:22 5:21 7:12 7:13 9:5 11:24 15:16 17:1 18:1 21:17 22:8,12 76:20 yesterday 11:8,10 45:3 70:1 york 5:25 6:1 z z 30:16 68:11 [weiss - 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