Deposition Frank Dean Deutsche T Soundview Home Loan Trust 2005-4 V Holden

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IN THE COURT OF COMMON PLEAS
OF SUMMIT COUNTY, OHIO
DEUTSCHE BANK NATIONAL TRUST
COMPANY AS TRUSTEE FOR
SOUNDVIEW HOME LOAN TRUST
2005 - 4, ASSET-BACKED
CERTIFICATES, SERIES 2005-4,
C/0 CHASE MANHATTAN MORTGAGE
COMPANY,
vs.
216-523-1313
Plaintiff,
Case No.
et al.,
Defendants.
2011 08 4500
Deposition of
FRANK A. DEAN, JR.
November 1, 2012
2:22 p .m.
Taken at:
Thompson Hine, LLP
3900 Key Tower
Cleveland, Ohio
Donnalee Cotone, RPR, CRR
Rennillo Deposition & Discovery
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1 APPEARANCES:
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216-523-1313
On behalf of the Plaintiff:
Thompson Hine, LLP, by
RICHARD A. FRESHWATER, ESQ.
3900 Key Tower
127 Public Square
Cleveland, Ohio 44114-1216
(216) 566-5500
richard.freshwater@thompsonhine.com
On behalf of the Defendants:
Dann, Doberdruk & Wellen, LLC, by
GRACE M. DOBERDRUK, ESQ.
4600 Prospect Avenue
Cleveland, Ohio 44103
(216) 373-0539
grace@dannlaw.com
A V critcxt Company 888-391-3376
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1 TRANSCRIPT INDEX
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3 APPEARANCES .. 2
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5 INDEX OF EXHIBITS .. . .............. . .... . . . 4
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7 EXAMINATION OF FRANK A. DEAN, JR.:
8 BY MS. DOBERDRUK ...... . ...... . ... .
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10 REPORTER'S CERTIFICATE . . ..... .
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13 EXHIBIT CUSTODY
14 EXHIBITS RETAINED BY COURT REPORTER
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21 l l ~ ' \ 2 1 - l l 1 1
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NUMBER
Exhibit A
Exhibit B
Exhibit C
Exhibit D
INDEX OF EXHIBITS
DESCRIPTION
Complaint for Forccloourc.
Pooling and Servicing ..
Agreement - cover Page
Assignment-MERS/Novastar
Mortgage, Inc., Assignor
Note for 1050 Shadybrook
Drive, Akron, Ohio, Dated
September 1, . 2005
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MARKED
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888-391-3376
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1 FRANK A. DEAN, JR., of lawful age, called
2 for examination, as provided by the Ohio Rules
3 of Civil being by me first duly
4 sworn, as hereinafter certified, deposed and
5 said as follows:
EXAMINATION OF FRANK A. DEAN, JR.
7 BY MS . DOBERDRUK:
8 Q. Hi. My name is Grace Doberdruk.
9 I'm representing the defendants in this
10 foreclosure case.
11 Can you state your name for the
12 record, please?
13 A. Frank Dean.
14 Q. Have you ever had your deposition
15 taken before?
16 A.
17 Q.
18 A.
19 Q.
20 A.
21 Q.
22 A.
23 Q.
24 A.
25 Q.
216-523-1313
Yes.
How many times?
Less than 12.
In what types of cases?
Residential mortgages.
All the times?
Yes .
Have you ever testified at trial?
Yes.
About how many times?
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1 A. Several dozen.
2 Q. Have you ever testified in Ohio
3 before at a trial?
4 A. Yes.
5 Q. And do you remember what case that
6 was?
7 A. No.
8 Q. Who was the plaintiff in the case?
9 Who were you there testifying for?
10 A. So many cases, several dozen. I
11 c.: an ' L' z: e c.: a 11 a ll o f t he m .
12 Q. Who are you currently employed by?
13 A. JPMorgan Chase Bank.
14 o. So every time you gave a
15 deposition, was it always with Chase?
16 A. No.
17 Q. Who else did you give a deposition
18 for?
19 A . As a Chase employee on behalf o.f
20 the plaintiff in each of those cases, which may
21 be a named different party.
22 o.
23 for Chase?
24 A.
25 Q.
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And do you go to trial and testify
Yes .
What is your educational
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1 background?
2 A. Be a little more descriptive of
3 what you're asking.
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A.
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Did you attend college?
I did.
WhPrP n id yon go t . o school?
Ohio University.
And did you get a degree?
No.
What were you majoring in?
Businees.
And what did you do after college?
Work.
And where was your first job?
Mr. Moneysworth.
And what is that?
Grocery store.
Did you have any other bank
19 positions before you worked at Chase?
20 A.
21 Q.
22 A.
23 a sampling?
24 Q.
25 A.
216-523-1313
Yes.
And where else did you work?
Do you want a complete list or just
I'll take the complete list.
Equitable Federal Savings and Loan.
Rcnnillo Deposition & Discovery
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13 A.
14 Q.
15' positions?
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23 Q.
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25 Q.
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And when did you work there?
Why?
When did you start there?
I don't recall.
How long did you stay?
I don't rt?call.
Was it within the last ten years?
No.
Oh, okay.
I'm much older than that.
All right. Where was the next 3pot
Beneficial Finance.
What did you do at these last two
Teller and a loan officer.
Where were you a loan officer at?
Beneficial.
Did you originate mortgages?
Yes.
In Ohio?
Yes.
And how long did you work there?
I don't recall.
Where did you go to next?
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Old Stone Bank.
As a loan officer?
That wasn't the title.
What was your title there?
manager.
Anrl what wAs the next spot?
Equicredit. E-Q-U-I-C-R-E-D-I-T.
And were was your job duties there?
I held various positions with that
Did you do any work with
12 foreclosures?
13 MR. FRESHWATER: Objection. Can
14 you clarify what kind of work you're talking
15 about?
16 BY MS. DOBERDRUK:
17 Q. Did you review files in foreclosure
18 cases?
19 A. No.
20 Q. Did you execute assignments of
21 mortgages?
22 A. No.
23 Q. Have you ever had a position where
24 you executed assignments of mortgages?
2 5
216-523-1313
MR. FRESHWATER: Objection.
Page 10
1 Relevance.
2 THE WITNESS: No .
3 BY MS.
4 Q. Where did you work after
5 Equicredit?
6 Meritage,
7 Mortgage.
8 Q. And what was your position there?
9 A. Area sales manager.
10 Q. Could you describe what you did as
ll a salc::J munagcr?
12 "
A. Supervised account executives in a
13 multistate territory.
14 Q. Was this for brokering mortgages?
15 A. No.
16 Q. What yuur next
17 A. IndyMac Bank.
18 Q. And do you remember when you
19 started working at IndyMac?
20 A. I do.
21 Q. What year was that?
22 A. 2003.
23 Q. And what was your position there?
24 A. I believe it was titled
25 vice president sales manager.
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1 Q. When you,.re a sales manaqer, what
2 are you managing in terms of sales? What is
3 the product?
4 A. Residential loans.
5 Q. Were these subprime loans?
6 MR . FRESHWATER: Objection.
7 You can answer .
8 THE WITNESS: It would be based
9 upon your de f in i t ion o f
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s. u b p r i me .
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11 Q. Borrowero with low credit
12 not documented income, high interest rates .
13 A. I have a hard time agreeing --
14 Q. What --
15 A. I have a hard time agreeing to call
16 that of clients subprlme, but
17 those were some of the qualifications that went
18 into those residential loans, yes .
19 Q.
20 A.
21 Q.
22 A.
23 Q.
21 A.
25 Q.
216-523-1313
How long did you work at IndyMac?
Two years.
And then where did you go to?
Aurora Loan Services .
And what was your title there?
Saleo manager.
How l ong did you work for Aurora?
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Two years.
so around 2005 to 2007?
Yes.
And what was your next position?
Relationship manager .
At. A11rora?
No.
Where was that at?
Silver Hill Financial.
Is this more of a sales position?
Yes.
And how long were you at Silver
Eight months.
Can I ask how you went from one
posllion to another to anoLheL-? Dld you just
apply for new jobs that opened up? Did you
18 know somebody at these companies?
19 MR. FRESHWATER: Objection. Are
20 you referring to a particular transition from
21 one company to another?
23 Q. I'm talking about in general, when
24 you chose to leave one company, why did you
25 choose to leave that company.
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1 So we
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ll say: When you chose to
2 leave IndyMac, why did you choose to go from
3 IndyMac to Aurora?
4 A. Personal reasons.
5 Q. Did you submit job applications for
6 all these
7 A. Submit meaning initiate?
8 Q. Apply for the job through a written
9 application.
10 A. Absolutely.
11 Q. Where did you work after Silver
12 Hill?
13 A. Accredited Home Lenders.
14 Q. How long did you work for
15 Accredited?
1.6 A. Twu monlhs.
17 Q. In 2008?
18 A. Yes.
19 Q. And what did you do at Accredited?
20 A . Account executive.
21 Q. What did you do on a typical day as
22 account executive?
23 A. Visited mortgage brokers, reviewed
24 loan applications.
25 Q.
216-523-1313
Why did you leave Accredited?
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1 A. They closed.
2 Q. And where did you go next?
3 A. Chase Bank.
4 Q. So you were hired by Chase in 2008;
5 is that right?
6 A. Yes.
7 Q. And what was your first position at
8 Chase?
A. Bank branch loan officer . 9
10 Q. What was your next position there?
J.l A. I did not hold another position
12 there at that time.
13 Q. So are you currently a bank branch
14 loan officer at Chase?
15 A. No.
16 Q. What
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17 A. Horne loan research officer .
18 Q. And how long have you had that
19 title?
20 A. Since April 2011.
21 Q. What is your address for your
22 office location?
23 A. 350 South Cleveland Avenue,
24 Westerville, Ohio.
25 Q. Have you been at that office the
? 16-5??.-1113
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1 entire time you've worked for Chase?
2 A. That is my assigned office, yes.
3 Q. What knowledge do you have about
4 note?
5 MR. FRESHWATER: Objection. It's
6 k ind of vague . Can you be mo r e spec i fic?
8 Q . When was the first time you looked
9 at Glenn Holden's note?
10 A. Within the last two business weeks
11 come time . I don't remember the exact date.
12 Q. Did you look at his note because
13 you were preparing for deposition?
14 A. Yes.
15 Q. Were you familiar with the Holdens'
16 lutin fill':! tiL till f? L luL Lu preparing for t his
17 deposition?
18 A. No.
19 0 . Did you talk to anybody at
20 about note?
21 A. No .
22 Q. Did you talk to anybody at
23 Deutsche Bank about his note?
24 A.
25 Q.
216-523-1313
No.
Did you talk to anybody at
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1 Financial Asset Securities Corporation about
3 A . No.
4 Q. Did you talk to anybody at Wells
6 MR. FRESHWATER: Objection.
7 You can answer if you can.
8 THE WITNESS: No.
9 BY MS. DOBERDRUK:
10 Q. Did you talk to anybody at MERS
11 about note?
12 A. No.
13 Q. Have you ever talked to anybody at
14 DP.lJt:sc:he Bank r . ~ b o u t and
15 thei r loan documents?
16 A. No.
17 Q. Have you ever talked to anybody at
18 the Soundview Home Loan Trust about -and
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No.
How did you find out that you were
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By e-mail.
And do you know how the decision
25 was made to choose you personally to come here?
216-523- 1313
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1 A. I have a vague understanding of how
2 our process works, yes.
3 Q. can you explain to me how the
4 - process works?
5 A. A request is made by counsel and
6 submitted to a ma]lbox. The mailbox manager
7 reviews the requests, then reviews the calendar
8 to see which person on the staff is not
9 assigned, and then assigns them.
10 Q. Does the request from counsel go to
11 Lender Services?
13 You can answer.
14 THE WITNESS: I dont know.
16 Q. Have you ever communicated with
17 anybody at Lender Processing Services?
18 MR. FRESHWATER: Objection . Youre
19 asking about in general for
21 Q. In general.
22 A. No .
23 Q. As part of your job duties, do you
24 use any computer systems with Chase?
25 A.
. 216-523-1313
Yes.
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1 Q. And what is your software system
2 for mortgage loan records?
3 A . There are many, and probably ones
4 I'm not even -- I don't even access. But the
5 ones I access regularly are -- I refer to as
6 M.SP .
7 Q. Are you aware that MSP is a
8 software program made by Lender Processing
9 Services?
10 MR. FRESHWATER: Objection .
11 THE WITNESS: No.
13 Q. Have you ever communicated with
14 anyone at LPS Default Solutions?
15 A. Not that I'm aware of.
16 Q. What about Fide1lly?
17 A.. No.
18 Q. Have you ever used a program called
19 LPS Desktop?
20 A. Yes.
21 Q. And what do you use that for?
22 A. Looking up contact information .
23 Q. Did the request from counsel come
24 through LPS Desktop?
25 A.
216-523-1313
Not that I'm aware of.
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1 Q. Do you see documents on the
2 LPS Desktop screens, notes and mortgage
3 document: s :'
4 MR. FRESHWATER: Grace, I'm going
5 to object. Are you talking in general? And if
6 you are . I would object to I f
7 you're talking about a specific case, that's
S okay.
9 BY MS. DOBERDRUK:
10 Q. Have you viewed note
11 on any computer screen?
12 A. Yes.
13 Q. In LPS Desktop?
14 A. No.
15 Q. What computer screen did you look
16 at?
17 A. My laptop's.
18 Q. Can you tell me how you looked at
19 his note, what you had to do to access to be
20 able to view his note?
21 A. Yeah. Internally, JPMorgan has a
22 site referred to as Financial Services Desktop.
23 And then once I open that link, I then open
24 a n othar program referred to as iVault, . the
25 letter I, V-A-U-L-T. And then I search for the
216-523-1313
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r'age 20
1 borrower's loan number, and it brings up all
2 imaged documents from that file.
Q. so it has the note, the mortgage?
4 A. Yep. Yes.
5 Q. Does it have assignments of
6 mortgage?
7 A. Yes.
8 Q. Does it have other closing
9 documents?
10 A. In most instances, yes.
11 Q. Do you know if C h u ~ e referred the
12 case to foreclosure?
13 A. I believe they did.
14 Q. And do you know if that referral
15 went through LPS Desktop?
17 THE WITNESS: I don't.
19 Q. What does Chase do to refer a case
20 to foreclosure? What's the process that they
21 use?
22 MR. FRESHWATER: Grace, I'm going
23 to object because I don't believe this is one
24 of the topics identified in your notice of
25 deposition.
216-523-l313
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1 BY MS. DOBERDRUK:
2 Q. Does Chase provide documents to
3 counsel in order to file the foreclosure
4 complaint?
5 A. Yes.
6 MS. DOBERDRUK: Can we mark the
7 complaint as Exhibit A?
8
9 (Thereupon, Deposition Exhibit A,
10 Complaint for Foreclosure, was
~ 1 marked for purposes of
12 identification.)
1 3
14
o. So you've been handed the compla int
15 that was filed against
16 Can you tell me who filed this
17 complaint?
18 MR. FRESHWATER: Objection. Are
19 you talking about who physically filed it?
20 MS. DOBERDRUK: No.
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Q.
A.
Q.
Who's the plaintiff --
Oh.
-- in the case?
25 THE WITNESS: Well tha t ' s -- thank
216-523-1313
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1 you for clarify ing. That's where it went, was
2 to the attorney.
3 Deutsche Bank National company As
4 Trustee For Soundview Home Loan Trust 2005-4,
5 Asset-Backed Certificates, Series 2005-4 .
6 Then C/0 Chase Manhattan Mortgage
7 Corporation, 3415 Vision Drive, Columbus,
8 Ohio 43219.
9 BY MS. DOBERDRUK:
10 Q. Hav e you ever worked for Chase
ll Manhattan Mortgage?
12 A. No.
13 Q. Do you know when Chase Manhattan
14 Mortgage went out of business?
16 You can answer .
17 THE WITNESS: I don't believe they
18 went out of business. I believe they were
19 merged Home
21 Q. Do you know when that happened?
22 A. I am guessing, for the better part,
23 but I believe it was 2004. But I could be
24 wrong.
25 Q. Can you turn to Exhibit A, to the
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1 complaint?
2 A. Yes, ma'am.
3 Q. Do you see a little bit down where
4 it says -- it's cert i fied as a true copy?
5 A. Uh-huh.
6 Q . I s t ha t certified -- is there a
7 signature there by somebody who's certifying
8 that this is a true copy?
9 A. There is a scribbling of a
10 signature, yes.
11 Q. And can you turn to -- it's going.
12 to be the third page of the note with writing
13 on it. Do you see signature?
14 A. Yes.
15 Q. Do you see any other marks on this
16 page, any accempt to endorse the note? or is
17 it just a blank space under the signature?
18 A. There are just empty lines.
19 Q. When I asked you if Chase gives the
20 documents to counsel to file the foreclosure,
21 do you believe that Chase gave this note to
22 counsel --
24 BY MS. DOBERDRUK;
25 Q.
216-523-U t3
when this case was filed?
]:}age 24
1 MR. FRESHWATER: You can answer if
2 you know.
3 THE WITNESS: I dont know tor
4 certain that Chase gave this to counsel.
5 BY MS. DOBERDRUK:
6 Q. If the general process is for Chase
7 to turn over documents, do you have any reason
8 to believe that this note was given to counsel
9 by Chase?
10 A. I do not.
11 Q. And is there any way that counsel
12 could obtain a note other than getting it from
13 the lender? rll rephrase it as this way._
14 You know that mortgages are
15 recorded.
16 A. Yes.
17 Q. The note is not recorded anywhere,
18 its not made a public record; is that true?
19 A. Thats my understanding, yes .
20 Q. And do you understand what it means
21 to securitize a note and mortgage?
23 You may answer if you know .
24 THE WITNESS; I would say that I
25 have a mortgage industry general knowledge of
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1 what a securitization is. But if you ask me to
2 define it, I'm not going to be able to.
3 BY MS.
4 Q. When you were working at some of
5 your prior positions and you were selling
were you selling thnRP trusts ,
7 that you know of?
8 A. Yeah. In my capacity either as
9 account executive, bank branch loan officer,
10 sales manager, I was only the front end of
11 mortguge origination. I don't know how the
12 back end after closing transpired.
13 Q. Have you ever seen the pooling and
14 servicing agreement for the trust that filed
15 this foreclosure?
16 A. I have.
17 Q. When did you view it?
18 A. This week.
19 Q. In preparation for the deposition?
20 A . Yes.
21 MS. DOBERDRUK: Can we discuss the
22 pooling and servicing agreement now?
23 MR. FRESHWATER: Absolutely.
24 DY MS. DOBERDRUK :
25 Q. I'm going to show you the title
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1 page for this trust .
2 MS. DOBERDRUK: And we've
3 stipulated this is the accurate pooling and
4 servicing agreement for the trust?
5 MR. FRESHWATER: Let me just make
6 surs that I didn't print out ths wrong copy for
7 me of that.
8 Yes. It appears to be such.
9 BY MS. DOBERDRUK:
10 Q. Okay. Can you look at the title
11 page and tell me who the depositor of the trust
12 is?
13 A. Financial Asset Securities Corp.
14 Q. And have you seen that name on any
15 documents that you've reviewed for the
16 deposicion in regards co
17 note and mortgage?
18 A. Beyond this document/ I'm going to
1g say no.
20 Q. And you've never spoken to anybody
21 there?
22 A. Correct.
23 MR. FRESHWATER: This is the first
24 part, and this is just the continuation. So
25 this is the first
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1 MS. DOBERDRUK : Okay .
2 MR. FRESHWATER: Grace, this is the
3 first half, I think, which will have most of
4 the pages you want to ask questions about it.
5 MS. DOBERDRUK : Oh, and you put
6 your tab on it .
7 BY MS. DOBERDRUK:
8 Q. Let me show you -- in the
9 definition section of t he trust on page 32,
10 could you identify the closing date of the
J.l trust?
12 A. Closing date, December 21st, 2005.
13 MS. DOBERDRUK: Let me just mark
14 this . So the pooling and servicing agreement
15 is going to be Exhibit B, and this will be
16 Exhibit C .
17 (Discussion held off the record . )
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(Thereupon, Depooition Exhibit B,
Pooling and Servicing Agreement -
Cover Page, was marked for purposes
of identification.)
(Thereupon, Deposition Exhibit C,
A Ve.r\text l.ompany
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1 Assignment-MERS/Novastar Mortgage,
2 Inc . , Assignor , was mark e d for
3 purposes of identification.)
4
5 BY MS. DOBERDRUK :
6 Q. All r i ght. I'm now handing you
7 what's been marked as Exhibit C, which is the
8 assignment of mortgage that was attached to the
9 foreclosure complaint in this case.
10 Can you tell me when this mortgage
11 was signed?
12 A. September 17th, 2 0 1 0 .
13 Q. And do you see who signed this
14 mortgage?
15 A. Yes.
16 MR. FRESHWATER: I'm sorry.
17 Objection. You're referring to the mortgage
18 assignment
19 MS. DOBERDRUK: The assignment of
20 mortgage, yes.
22 Q.
23 A.
24 Q.
25 A.
216-523-1313
Wanda Chapman?
Yes.
Do you know who that is?
No.
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1 Q. Do you know if Wanda Chapman works
2 for Chase?
3 A. No.
4 Q. Do you have a position at Chase
5 called operations management lead?
6 MR. FRESHWATER: I'll object that
7 that wasn't on the topics for deposition.
8 But you can answer if you know.
9 THE WITNESS: Operations management
10 lead, is that what you asked?
12 Q. Yeah. Operations -- do you have an
13 operations department at Chase?
14 A. Yes.
15 Q. What does the operations department
16 do?
17 A. There are operation departments in
18 all facets of Chase, whether it be mortgage
19 banking, investments, securities. So
20 Q. Do you have an operations
21 department at Chase that executes assignments
22 of mortgages?
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24
25
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But you can answer.
THE WITNESS: I don't know.
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1 BY MS. DOBERDRUK:
2 Q. I'm going to show you Section 2.01
3 of the pooling and servicing agreement.
4 MR. FRESHWATER: And, Grace, you're
5 referring to Article II
6 MS. DOBERDRUK: Yes.
7 MR. FRESHWATER: which we have
8 identified as page 79 of 1356.
9 BY MS. DOBERDRUK:
10 Q. And if you can just tell me, what's
11 the title for Article II?
12 A. "Conveyance of mortgage loans,
13 original issuance of certificates."
14 Q. Could you read the first paragraph
15 in Section 2.01?
16 A. "The de.E:Jositor concurrently with
17 the execution and delivery hereof does hereby
18 transfer, assign, set over and otherwise convey
l9 in trust to the trustee without recourse for
20 the benefit of the certificate holders, all of
21 the right, title and interest of the depositor,
22 including any security interest therein for
23 the
11
24 MS. DOBERDRUK : We can stop there
25 unless Richard has an objection.
216-523-1313
Page 31
1 MR. FRESHWATER: No, no. That's
2 fine.
3 BY MS. DOBERDRUK:
4 Q. Okay. I want to show you the title
5 page again. Could you tell me who the
6 depositor of the trust is?
7 A. Financial Asset Securities Corp.
8 Q. And I'll have you look at your copy
9 of the complaint, Exhibit A to the complaint.
10 A. Uh-huh.
11 Q. Do you see -- I'll let you get it
12 over because we're going to go to Exhibit A.
13 A . You want me in the note or the
J 4 mo:t"tgage?
15 Q. At the note.
16 A. Okay . I'm there.
17 Q. Do you see any endorsement from
18 Financial Asset Securities Corporation?
19 A. Nu.
20 Q. Do you see any endorsement to
2 2 A .
23 Q.
24 more minute.
25
216-523-1313
Nn _
All right. Let me see that for one
Thank you.
All right. Could you read to me
Page 32
1 Section I?
2 A. So we're back to Exhibit B, page 79
3 of 1356, Subparagraph I .
4 "The original mortgage note
5 endorsed either, A, in blank or, B, in the
6 following form, pay to the order of
7 Deutsche Bank National Trust Company as trustee
8 without recourse, or with r e s ~ e c t to any lost
9 mortgage note" do you want me to continue?
10 Q. No, you don't have to.
11 !'... Okay.
12 MR. FRESHWATER: Grace, if I may,
13 it may be helpful -- this is your deposition,
14 but -- to go over the previous paragraph in
15 terms of why we're talking about the original
16 mortgage nole. You:r.- deposit ion.
Q. What I asked you about was how the
19 pooling and servicing agreement says that the
20 original note should be endorsed; is that
21 correct?
22 A. May I see that one more time?
23 Q. Yes.
24 A. Yes. You asked me to read the
25 paragraph about the endorsement of the original
216-523-1313
A V eritext Company 888-391-3376
Page 33
1 mortgage note.
2 Q. And that section tells how the note
3 should be endorsed to be conveyed to the trust .
4 MR. FRESHWATER: Is that a
5 question, Grace? Objection. Is that a
6 question?
7 BY MS. DOBERDRUK:
8 Q. I'm aski11g: .From your
9 understanding, from what you're reading there,
10 does it look like Section 2.01, which is titled
11 Conveyance of a Mortgage, that they're
12 describing how the note should be endorsed
13 A. Yes.
14 Q. -- the method?
15 And we looked at the complaint, and
16 you did not see any endorsement, did you, to
17 the note in the complaint?
18 A. Correct.
19 Q. And I asked you to look at the
20 fi-rst sentence in Section 2.01. Who did it say
21 sells the note to the trust?
22 A. Well, since I m not well versed in
23 PSAs, I think I'm going to read the sentence --
24 Q . Okay.
25 A. rather than attempt to answer by
216-523-1313
A Vcritcxt Company 888-391-33 76
Page 34
1 my own definition.
2 "The depositor concurrently with
3 the execution and delivery hereof does hereby
4 transfer, assign, set over and otherwise convey
5 in trust to the trustee without recourse for
6 the benefit of the certificate holders, all the
7 right, title and interest of the depositor,
8 including any security interest therein for the
9 benefit of the depositor."
10 MS. DOBERDRUK: Okay. Did you say
~ ~ you had the collateral file here today?
12 MR. FRESHWATER: I do.
13 MS. DOBERDRUK: Do ' you want me to
14 show him this or the copy?
15 MR. FRESHWATER: If you're willing
~ 6 tu stipulate that the copies are accurate,
17 let 's just show him the copies.
18 same ones we used in the
19 MS. DOBERDRUK: Okay.
They're the
depositions.
If you don't
20 mind, I do want to show him something on that.
22 Q. I'm going to show you what's been
23 produced as the original -- as the note in the
24 collateral file.
25 Can you tell me if that note has an
216-523-1313
Page 35
1 on it?
2 A. Yes.
3 Q. Okay. And who was the signer of
4 that endorsement?
5 A. Steve Haslam, H-A-S-L-A-M, Sr.,
6 Dresident.
7 Q. And does it look like that's signed
8 by him in pen, or does it look . like it's been
9 stamped on there?
10 A. I cannot tell.
11 Q. Is it to cay that it doesn't
12 look like an original signature by Steve
13 Haslam?
14 And I'll just point to this mark
15 here. Would you say it looks more like it's a
16 copy as opposed to pen, if you thaL Lo
17 what looks like fresh ink?
18 MR. FRESHWATER: On
19 signature?
20 THE WITNESS: State your question
21 one more time. I want to make sure I answer it
22 accurately.
23 BY MS, DOBERDRUK:
24 Q. I want to know if this -- Steve
25 Haslam's signature looks like i t was a stamp as
216-523-1313
Page 36
1 opposed to signed by him in person in pen.
2 A. I'm going to indicate that I cannot
3 make that distinction.
4 Q. Would you admit it's possible that
5 it was a stamp as opposed to an original
6 signature?
7 A. Yes.
8 Q. And would you agree that that
9 endorsement on this note in the collateral file
10 does not appear on the note attached to the
11 complaint?
12 A. Yes.
13 Q. Do you have any explanation for why
14 the complaint would be filed with a note that
15 didn't contain.this endorsement?
16 MR. FRESHWATER: Objection. Calls
17 for speculation.
18 You can answer if you know.
19 THE WITNESS: Yes.
21 Q. Did you bring this document -- this
22 file with you when you came today?
23 A. No.
24 Q. Do you know -- have you ever viewed
25 this manila file before coming here today?
216-523-1313
A Veritex.t Company 888-391-3376
J:Jage 37
1 A. No.
2 Q. If you've never viewed this file
3 here before, how do you know that the piece of
4 paper you're holding in your hand is the
5 official note?
6 A. For a couple reasons. First, it
7 contains the borrower,
8 original signature.
9 Secondly, the manila file indicates
10 that it was sent to our attorney from our
~ ~ Monroe, Louisiana custodial facility.
12 Q. When you say it was sent from the
13 Monroe, Louisiana custodial facility, whose
14. facility are you talkins about?
15 A. JPMorgan Chase.
l6 Q. All right. Have you ever heard in
17 securitized mortgages that when the notes are
18 sold to the trust, that there's a custodian for
19 the t . ru!=:t. ?
20 A. Yes, I've heard that.
21 Q. And the custodian maintains records
22 for the trust?
23 A. I'll assume that that's correct.
24 I, again, don't know much detail about
25 Q. Is Chase the custodian of records
216-523-1313
Page 38
1 for the Soundview Home Loan Trust 2005-4?
3 THE WITN.c;SS: Yeah, I don't know.
4 BY MS. DOBERDRUK:
5 Q. If we go back to Exhibit B, the
6 pooling and servicing agreement, I'm going to
7 show you the definition section of the pooling
8 and servicing agreement. Could you identify
9 who the ' custodian of. the trust is?
10 A. Wells Fargo Bank, NA.
11 Q. So if Wells Fargo Bank, NA, is the
12 custodian of the trust., isn't it fair to say
13 that Wells Fargo would have a copy of
14 original note if this note was
15 part of the trust?
16 A. I don't know.
17 Q. And I asked you previously if you
18 had ever spoken to anybody at Wells Fargo about
19 note. And have you ever talked
20 to anybody at Wells Fargo?
21 A. No.
22 Q. So in preparing for the deposition,
23 was your review of the records a review of
24 Chase's records?
A.
216-523-1313
Oh, I'm sorry. Was that a
Page 39
1 question?
2 Q. Yes.
3 A. I apologize.
4 Q. That's all right.
5 Did you review any records other
6 than Chase's records?
7 A. No.
8 Q. If there
9 MS. DOBERDRUK: I can give him a
10 copy of the note now. We'll mark this
11 Exhibit D.
12
13 (Thereupon, Deposition Exhibit D,
14 Note for 1050 Shadybrook Drive,
15 Akron, Ohio, Dated September 1,
16 2005, was marked for purposes of
17 identification.)
18
19 (Discussion held off the record . )
20 MS. DOBERDRUK: Would you mind if I
21 asked him about this?
22 MR. FRESHWATER: No, go ahead. The
23 assignment of mortgage, I think you have as
24 Exhibit C.
25
216-523- 1313
MS . DOBERDRUK: All right.
A Veritext Company
This is
888-391-3376
Page 40
1 a copy though; this isn't the original, right?
2 MR. FRESHWATER: That's the
3 original, 1 believe.
4 MS. DOBERDRUK: Well, I'll let you
5 look and see if you think it is.
MR .. F'RF.SHWA'T'F.R ~ Yeah .
7 sticker from the fiscal officer, which would
8 indicate
9 BY MS. DOBERDRUK:
10 Q. All right. I'm going to show you
11 this Qooignment of mortgQgc that came out of
12 the collateral file, which is supposed to be
13 the original assignment of mortgage.
14 Could you look on the second page?
15 Does it look like Wanda Chapman's signature was
16 signed in ink? And I'm talking to her actual
17 signature.
18 A. .Yes.
19 Q. Would you agree that the printed
20 Wanda Chapman looks like it was written in pen?
21 A. Yes.
22 Q. And would you look at the bottom
23 where Manley Deas' address is crossed out?
24 A.
25 Q.
. 216-523-1313
Ye:s.
Does that also look like it was
A Veritext Company 888-391 -33 76
Page 41
1 written in the same pen?
2 A. Your question wasn't very clear.
3 Q. The same type of black ink .
4 A. Yes. They appear to be both black
5 ink.
6
Q_
Can you think of any reason why
7 Wanda Chapman would cross out Manley Deas
8 address if
10 There's no evidence that Wanda Chapman is the
11 one who crossed it out.
12 MS. DOBERDRUK: I agree that .I
13 don't believe Wanda Chapman crossed it out.
14 BY MS .. DOBERDRUK:
15 Q. Would you agree that the black ink
16 in the printed Wanda Chapman appears different
17 than the Wanda Chapman signature which does not
18 appear to be in black ink to me?
19 A. I think we're splitting hairs.
20 They both are black, but one appears to be a
21 different type of black pen or black ink.
22 Q. Or possibly a stamp?
23 MR. FRESHWATER: Objection .
25 Q. Is it possible it could be a stamp?
216-523-1313
Page 42
1 A. On this document, no. It appears
2 as though an authentic signature was made .
3 Q. But you will -- let's see.
4 You can clearly see that the
5 Wanda Chapman that's printed out is made in a
marking the Wanda Chapman that is
7 printed out is in black pen - -
8 A.
9 Q.
10 .
Yes.
-- undoubtedly.
11 urc you going to ask a question?
12 MS. DOBERDRUK: Okay.
Grace,
14 Q. Does the Wanda Chapman's signature
15 appear a different color than the Wanda Chapman
16 pen?
17 MR. FRESHWATER: Objection. Asked
18 and answered.
19 You again.
20 MS. DOBERDRUK: I asked about
21 color .
23 Q. Is it a different shade of color?
24 A. So your question is pertaining to
25 this signature and that printed, correct?
216-523-1313
Page 43
1 Q. Yes.
2 A. They both are black. Different
3 texture possibly, yes. Ditterent tipped pen.
4 Q. Definitely.
5 MR. FRESHWATER: Objection. Is
6 that a question, Grace.
8 Q. Sorry.
9 You can agree that those definitely
10 look like they were written in different pen.
11 I mean, just from a viewing of the eye --
12 MR. FRESHWATER : Objection.
13 BY MS. DOBERDRUK :
14 Q. -- will y o u admit that they
15 definitely look like they were written in a
16 different pen?
17 MR. FRESHWATER: Objection . Grace,
1 8 will you ask --
19 MS. DOBERDRUK : Okay.
20 MR . FRESHWATER: Will you ask a
21 question as opposed to testifying?
23 Q. Do the Wanda Chapman signature and
24 the Wanda Chapman printed name appear to be
25 written in a different pen color and texture?
216-523-1313
Page 44
2 Compound.
3 But go ahead and answer.
4 THE WITNESS: A different type of
5 pen -- as an example, felt tip versus
6 yes . Rut they are both the same
7 color.
8 BY MS. DOBERDRUK:
9 Q. The date this assignment of
10 mortgage was made, would you agree that the
11 September 17th and the Wanda Chapman print are
12 in the same style and color pen?
13 MR. FRESHWATER: Objection to the
14 extent hes not an expert on pens.
15 But answer if you know.
16 THE WITNESS: I'm going to you
17 to repeat the question. I think I lost track,
18 listening to you two .
19 You asked me about this date.
21 Q. rm only looking here.
22 A. Oh.
23 MR. FRESHWATER: Let the record
21 reflect shes pointing to the top of the
25 assignment.
216-523-1313
Page 45
1 THE WITNESS: Okay . Tell me
2 your -- ask me your question, please.
4
Q. That the September 17th date at the
5 top of the assignment and the Wanda Chapman
6 printed name appear in a different color than
7 the Wanda Chapman signature .
8 MR. FRESHWATER: Objection. Can
9 you ask a question, Grace?
11 Q. Do the September 17th d ~ t c at the
12 top of the assignment of mortgage and the
13 Wanda Chapman printed name appear to have been
14 made in the same color and texture pen?
15 A. Yes, they appear to be the same.
16 Q. Thank you .
17 MR. FRESHWATER: Are we
18 MS . DOBERDRUK: Yes, I'm done with
19 that _ Thanks .
21 Q. I'm going to hand you a copy of the
22 o riginal note fr o m the c o llateral file, which
23 has been marked as Exhibit D.
24 Can you turn to the page with the
25 endo rsement?
216-523-1313
Page 46
1 A. Yes.
2 Q. All right. Do you see an
J endorsement to Financial Asset securities
4 Corporation?
5 A. No.
6 Q. Do you see an endorsement from
8
9
10
11
12
13
A.
Q.
A.
Q.
A.
Q.
No.
Do you know who Mary Collins is?
State that name again.
Ma.ry Collin::;.
No.
Do you know another Mary at Chase
14 that has a name that sounds like Collins?
15 A. No.
16
Q. Do you know someone aL Chase named
17 Mary?
2 2 Q.
23 A.
24 Q.
25
216-523-1313
What is her job title?
Teller.
She'::; a teller.
Do you know anybody named Teri,
A Veritext Company 888-3 91-3376
Page 47
1 female?
2 A. Yes.
3 Q. And what is her job position?
4 A. Bank branch loan officer.
5 Q. Does she review documents for
6 modificQtions?
7 A. No.
8 Q. Does she originate loans?
9 A. At last conversation with her,
10 which would probably have been over six months
11 ct9u, yes.
12 Q. What is Teri's last name?
13 A. I can't remember.
14 0. Do you know if her name is spelled
15 with an I or with an Y?
16 A. Yeah. I believe it was T-E-R-1.
17 Or two Rs and an I, I can't remember which.
18 Q. Do you know how long she's worked
19 at Chase?
20 A. No.
21 Q. At least for the last two years?
22 A. I don't know. She may not even
23 still be with us.
24 Q.
25 location?
216-5/.J-1313
How many people work at your office
Page 48
1 A. I don't know.
2 Q. Okay. More than 50?
3 A. Yes.
4 Q. Do you say at the Chase location
5 that you work at, do people sign assignments to
6 in the office?
7 A. I do not know.
8 Q. What do you do on a daily basis for
9 Chase?
10 MR. FRESHWATER: Objection. Vague.
12 Q. As part of your job, what's the
13 typical day like?
14 A . day is different. There is
15 no typicality to my job. I could either be at
16 home prepping for an appearance, I could be in
17 a deposition, I could be in a plane headed to
18 an assignment all day.
19 Q. Wheu yuu "assignmeul," ls that
20 court-related?
21 A. Not necessarily, unless you
22 this court-related.
2 3 Q. Yeah.
24 A. Okay. So, to me, that means being
25 in a courtroom.
216-523-1313
But, no, not all my
A Vcritcxt Company 888 391-3376
Page 49
1 assignments are in a courtroom.
2 Q. Does the vast majority of your job
3 involve testifying at depositions or trial?
4 A.
5 Q.
6 deposition?
7 A.
8 Q.
I wouldn't say vast.
How often a week do you do a
Normally, not weekly.
And do you know how many
9 depositions you've done for Chase?
10 A. I think I answered previously less
11 than a dozen. I'm not sure.
12 Q. Do you remember when the first one
13 you did was, what yeari
14 A . YP.!='. .
15 Q. Can you tell me what year it was?
16 A. Yes.
17 Q. What year was the first time you
18 took a deposition with Chase?
19 A. 2011.
20 Q. Do you take depositions about only
21 foreclosure cases, or do you
22 MR. FRESHWATER: Objection . I
23 don't believe he said he takes depositions.
24 BY MS . DOBERDRUK :
25 Q.
216-523-1313
Do you attend depositions in
Page 50
1 foreclosure and bankruptcy cases, or only
2 foreclosure?
3 A. I can't say that I paid enough
4 attention to make that distinction.
5 Q. Okay. When you're not
6 participa.ting in a deposition, do you do other
7 work that's related to foreclosures?
8 A. I'm sorry.
10 THE WITNESS: Will you reask that
11 question?
13 Q. As part of your job, are you
14 involven in, wF;'l1 say, filing .::l rnmpl;=l:int.
15 against somebody or reviewing documents? Have
16 you ever signed an affidavit for a summary
17 judgment motion?
18 MR. FRESHWATER: Objection. That
19 was three
20 THE WITNESS: I have not signed an
21 affidavit for a summary judgment motion.
22 BY MS . DCYRF.RDRUK:
23 Q. Have you referred a case to
24 foreclosure yourself?
25 A.
216 523-1313
No.
A V critcxt Company 888-391-3376
Page 51
1 Q. Can I ask what you.do as part of
2 your job that doesn
1
t involve testifying in
3 court or attending depositions?
4 A. I think the answer to that is yes,
5 because your question was, Can I ask?
6 Q. What else do you do that doesn't
7 involve depositions and testifying in trial?
8 A. Mediations.
9 Q. You attend mediations as a
10 corporate representative of Chase?
11 A. Yes.
12 Q. In Ohio?
13 A. Yes.
14 Q. Do you have to review any documents
15 for when you att e nd mediations?
16 A. Yes.
17 Q. Do you review pooling and servicing
18 agreements? Sometimes . do you review pooling
19 and servicing agreements?
20 MR. FRESHWATER: For mediation,
21 Grace, or in general?
23 Q. For mediation . That
1
S all right .
24 I
1
ll just move on t o -- 1
1
m go1ng to ask you
25 one more question about the note, and then
216-523-1313
A Vcritcx.t Company 888-391-33 76
Page 52
1 we'll wrap it up.
2 Do you have any way of knowing
3 when, if ever, this endorsement was placed on
4 the note?
5 A. Yes.
6 Q. Okay. And how would y o ~ know when?
7 A. Based on my review of the poo ling
8 and servicing agreement as well as Chase
9 records.
10 Q. When you say and Chase records,
11 what records do you mean?
12 A. System notes as well as collateral
13 file.
14 Q. So when you say
11
sys tern notes, rr
15 what do these system notes say?
l6 A. There is a note in there that
17 confirms the time of our acquisition of the
18 collateral file.
19 Q. Would you agree that acquisition o f
20 the collateral file does not -- the time that
21 you see on your computer, when you acquire the
22 file, does not indicate what the file looks
23 like. Is that fair to say?
24 If you look at a computer screen
25 that says a time period that you obtained
216-523-1313
Page :,3
1 something, it doesn't show what was obtained;
2 it only gives you the day and time.
MR. FRESHWATER: Objection. Is
4 there a question?
5 MS. DOBERDRUK: I asked if he would
t=; <3gree that, by looking at a date and time, it
7 only shows when you received something, not
8 what exactly was received.
9 THE WITNESS: But an appropriate
10 home loan research officer such as myself would
11 go to the iVault to confirm that those
12 documents were imaged near or at the time of
13 the acquisition date note entry, which I did.
15 Q. If this case was referred to
16 foreclosure by Chase, Lht:!u why d o t : ~ the note
17 attached to the complaint not contain an
18 endorsement?
19 MR. FRESHWATER: Objection. Calls
20 for speculation.
21 But you can answer if you know.
22 THE WITNESS: It's my opinion
23 that -- well, let me ask . Have you ever
24 attended a loan closing, oo I can try and put
25 this into context? A real estate loan closing .
216-523-1313
Page 54
1 BY MS. DOBERDRUK;
2
3
Q.
A.
Yes.
Okay. They're -- at the time the
4 closing agent is done settling the documents,
5 they're required to submit packages to several
6 various locations. Within those packages are
7 copies of the note and the mortgage to be
8 recorded, along with -- one of those packages
9 contains the original note.
10 It's my opinion that we were in
ll receipt not only of the original note, but a
12 certified true copy of the note. And whoever
13 provided the -- whoever went into the image
14 vault and extracted a copy of the mortgage for
15 foreclosure counsel extracted the unendorsed
16 copy rather than the endorsed copy.
17 Q. When you reviewed records for
18 coming here to today, did you happen to notice
19 a motion for relief from stay that Chase had
20 filed in the bankruptcy case?
21 MR. FRESHWATER: Objection. The
22 bankruptcy wasn't a topic of discussion for
23 deposition.
24
25
216-523-1313
But you can answer if you know.
THE WITNESS: I did not notice a
Page 55
1 mot ion for relief of stay.
2 BY MS. DOBERDRUK:
3 Q. In your records, did you happen to
4 see any indication that Chase had moved for
5 relief from stay, or that Deutsche Bank had
6 moved for relief from stay in the
7 bankruptcy?
8 MR. FRESHWATER: Again, the same
9 objection.
11 Q. Does Chase keep their bankruptcy
12 and foreclosure records in the same loan file?
13 A. No. The same system, yes.
14 Q. Same system.
15 Are all the records for one
16 person's loan kept in some file that could be
17 accessed?
18 A. Yes.
19 Q . The note that has been produced
20 today as the original came from what custodian
21 of records?
22 A.
23 Q.
24 t . ; d ~ e ?
25 A.
216-523-1313
JPMorgan Chase Bank.
And who is the plaintiff in this
Deutsche Bank National Trust
Page 56
1 Company, as trustee for Soundview Home Loan
2 Trust 2005-4 Asset-Backed Certificates,
3 Series 2000-4 -- excuse me -- 2005-4, care of
4 Chase Manhattan Mortgage Corporation,
5 3415 Vision Drive , Columbus, Ohio.
6 Q. Does Chase get copies of pleadings
7 that are filed in foreclosure cases?
8 By pleadings, I mean if somebody
9 files -- if the homeowner files a motion to
10 dismiss, does Chase get a copy of that on their
computer screen?
14 THE WITNESS: I dont know how that
15 process is handled.
BY MS . DOBERDRUK:
17 Q. If it was pointed out to Chase that
18 the note attached to the complaint did not have
19 an endorsAment anrl poRRARRed a with
20 an endorsement, then why did Chase never
21 correct the matter with the court?
22 MR. FRESHWATER: Objection. Grace,
23 you just posed an hypothetical in there that we
24 havent agreed to, that that was e v er pointed
25 out to Chase .
216-523-1313
Page 57
2 Q. Do you know if Chase referred this
3 case to foreclosure?
4 A. I'm going to ask if that's a trick
5 question, because isn't this the foreclosure
ti r.ompl;=d_nt?
7 Q. Yes.
s A. So yes, Chase referred the loan to
9 foreclosure.
10 Q. And when Chase refers a loan to
11 forcclooure, do the y have communications with
12 counsel about the cases?
16 Q. So is it reasonable Lo say Lhat if
17 Chase noticed that the note attached to the
18 complaint was not correct, that Chase would do
19 something to substitute a note with the court?
20 MR . FRESHWATER: Objection, because
~ 1 we haven't stipulated that they ever noticed
22 that, and that's also a hypothetical.
Q. I'm just going to ask you again to
25 verify that you have not communicated with
216-523-1313
A Veritext Company 888-3 91-33 76
1 Deutsche Bank about
2 note; is that correct?
3 A. I personally have n o ~ communicated
4 with Deutsche Bank.
5 Q. And before coming here, did you
6 make any effort to determine whethe r
7 Deutsche Bank or Wells Fargo had different
8 records of the note than what Chase had?
9 A. No.
10 MS. DOBERDRUK: Okay. Thank you.
11 THE WITNESS; You're welcome.
12 MR. FRESHWATER: Are you going to
13 go off the record?
14 MS. DOBERDRUK: Sure.
15 (Discussion held off the record.)
MS. DOBERDRUK: Do you want to read
17 the transcript and then sign, or waive
18 signature?
19
20
21
22
23
24
25
216-523-1313
THE WITNESS: Waive.
MS. DOBERDRUK: Okay.
(The deposition was concluded.)
Page 59
1 Whereupon, counsel was requested to give
2 instruction regarding the witness's review of
3 the transcript pursuant to the civil Rules.
4
5 SIGNATURE:
6 It was agreed by and between counsel and the
7 parties that the reading and signing of the
8 transcript of said deposition be, and the same
9 is hereby waived.
10
11 TRANSCRIPT DELIVERY :
12 Counsel was requested to give instruction
13 regarding delivery date of transcript.
14
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216-523-1313
Original: MS. DOBERDRUK
Copy: MR. FRESHWATER
Page 60
1 REPORTER
1
S CERTIFICATE
2 The State of Ohio,
3 SS:
4 County of Cuyahoga.
5
6 I, Donnalee Cotone, a Notary Public
7 within and for the State of Ohio, duly
8 commissioned and qualified, do hereby certify
9 that the within named witness, FRANK A. DEAN,
10 JR., was by me first duly sworn to testify the
11 truth, the whole truth and nothing but the
12 truth in the cause aforesaid; that the
13 testimony then given by the above-referenced
14 witness was by me reduced to stenotypy in the
15 presence of said witness; afterwards
16 transcribed, and that the toregoing is a true
17 and correct transcription of the testimony so
18 given by the above-referenced witness.
19 I do further certify that this
20 deposition was taken at the time and place in
21 the foregoing caption specified and was
22 completed without adjournment.
23
24
25
216-523-1313
A Veritext Company 8R8-391-33 76
Page 61
1 I do further certify that I am not
2 a relative, counsel or attorney for either
3 party, or otherwise interested in the event ot
4 this action.
5 IN WITNESS WHEREOF, I have hereunto
6 set my hand and affixed my seal of office at
7 '
Cleveland, Ohio, on this day of
8 2012.
9
10
11
12
13
14 Donnalee Cotone, Notary Public
15 within and for the State of Ohio
16
17 My commission expires February 7, 2017.
18
19
20
21
22
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216-523-1313
A V critext Company 888-391-33 76
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Renmllo Deposition & Discovery
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A Veritext Company
Page 9
888-391 -3376

Deposition Frank Dean Deutsche T Soundview Home Loan Trust 2005-4 V Holden

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Deposition Frank Dean Deutsche T Soundview Home Loan Trust 2005-4 V Holden

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