Deposition LH

DEPOSITION OF LONA HUNT
October 17, 2014
CERTIFIED
ORIGINAL TRANSCRIPT
IN THE CIRCUIT COURT OF THE ELEVENTH JUDICIAL CIRCUIT

IN AND FOR MIAMI-DADE COUNTY, FLORIDA
CASE NO.:
- - - - - - - - - - - - -
FEDERAL NATIONAL MORTGAGE

ASSOCIATION,
Plaintiff,
vs.
Defendants.
- - - - - - - - x
Durham, North Carolina
Friday, October 17, 2014
Deposition via Skype videoconference of
LONA HUNT, a witness herein, called for examination
by counsel for the Defendants in the above-entitled
matter, pursuant to notice, the witness being duly
sworn by MAREN M. FAWCETT, RPR, Notary Public in and
for the State of North Carolina, taken at Chapel Hill
Reporting, LLC, 2530 Meridian Parkway, Third Floor,
Durham, North Carolina at 2:07 p.m., on Friday,
October 17, 2014, and the proceedings being taken
down by Stenotype by MAREN M. FAWCETT, and
transcribed under her direction.
Chapel Hill Reporting, LLC, Serving North Carolina
(919) 969-1169

October 17, 2014
2
1
APPEARANCES:
On behalf of the Plaintiffs, via teleconference:
MARY STELLA, ESQ.
LAUREN SCHWARZFELD, ESQ.
Law Offices of Popkin & Rosaler, P.A.
1701 W. Hillsboro Boulevard
Deerfield Beach, FL
(954) 360-9030
E-mail: mstella@popkinrosaler.com
10
33442
E-mail: lschwarzfeld@popkinrosaler.com
11
12
On behalf of the Defendants, via Skype
13
videoconference:
14
EVAN M. ROSEN, ESQ.
15
Law Offices of Evan M. Rosen, P.A.
16
2028 Harrison Street, Suite 204
17
Hollywood, FL
18
(754) 400-5150
19
E-mail: eservice@evanmrosen.com
33020
20
21
Also Present:
Nakeita Ellington, Law Office of
22
Evan M. Rosen, via Skype
23
videoconf erence
24
25
(919) 969-1169

October 17, 2014
C 0 N T E N T S
THE WITNESS
LONA HUNT
By Mr. Rosen
By Ms. Stella
EXAMINATION
54
-ooo-
E X H I B I T S
8
9
EXHIBIT
Defendants' 1
DESCRIPTION
Summons, Lis Pendens
10
Verified Complaint
11
Mortgage
12
13
IDENTIFIED
(Exhibit attached.)
-oOo-
14
15
16
17
18
19
20
21
22
23
24
r'
25
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30

October 17, 2014
1
2
P R 0 C E E D I N G S
Whereupon,
3
4
LONA HUNT,
residence address at
was called as a witness by counsel
for the Defendants and, having been duly sworn by the
Notary Public, was examined and testified as follows:
DIRECT EXAMINATION
10
BY MR. ROSEN:
Q.
Good afternoon, Ms. Hunt.
I'm Evan Rosen.
11
I represent Mr. and Mrs.
12
you could please state your name, your age and your
13
address?
14
A.
Lona Hunt, 58.
in this action.
If
I live at
15
16
MS. STELLA:
Mr. Rosen, do you mind if we
17
do not make her home address part of the
18
transcript?
19
MR. ROSEN:
20
MS. STELLA:
21
I think she's already said it.

Court reporter, can we strike
that?
22
MR. ROSEN:
I don't think you can strike it
23
after the fact.
24
protective order or something, you're welcome to
25
do so.
If you want to move for
I have no intention of doing anything

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5
1
wi th that in any way , shape or form.
here to harass Ms. Hunt with her address.
MS . STELLA:
Okay.
I ' m not
Well, if you file the
transcript with the court, can we just have her
address taken out?
MR. ROSEN:
record or later .
for now.
Let's continue with the depo
BY MR. ROSEN :
10
We can talk about that off the
Q.
At the time of the verification of this
11
complaint , which was apparently around January 10th ,
12
2012 , where did you live?
13
address at this point.
14
city, county and state.
I don ' t need the specific
Let ' s start with maybe the
15
A.
Durham .
16
Q.
January 10th, 2012 , where did you live?
17
A.
Durham , North Carolina .
18
Q.
I'm sorry , what was that?
19
A.
Durham, North Carolina.
20
Q.
Durham .
21
A.
No.
22
Q.
And the city that you live in now is?
23
A.
Raleigh.
24
Q.
Raleigh?
25
A.
Yes.
Is that where you live now?

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1
2
As of January 10 , 2012, where were you
working , what city and state?
A.
RTP.
Q.
RTP, Raleigh?
A.
Well, it ' s Research Triangle Park.
6
7
Raleigh , in RTP.
That
would probably be Durham.
Q.
Okay.
So you ' re working in Durham and
living in Durham around January 10th of 2012; is that
what you ' re saying?
10
11
A.
Yes .
MR. ROSEN :
Guys , there is a delay between
12
the conference and what I ' m seeing on the video
13
and it ' s kind of hard to follow both .
14
it ' s okay, what I'm going to try and do is mute
15
the conference call and try it over Skype and
16
let ' s see if that works.
17
Q.
MS. STELLA:
So if
No , we can't do that because
18
then there's a delay and we won ' t have time to
19
object before she answers.
20
MR. ROSEN:
21
MS. STELLA:
So --
There's a delay --- like you just said , there
22
is a delay.
23
before we hear it or we would --
24
25
So if she would answer on Skype
MR . ROSEN:
Yeah, Skype is behind the
conference call , not before though.
So it's
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(919) 969 - 1169

October 17, 2014
t'
hard for me to follow along.
MS. STELLA:
Okay.
But the problem is then
we would hear you through Skype and not by the
conference call?
MR. ROSEN:
MS. STELLA:
Then we will have two audios
on, won't we?

MR. ROSEN:
Right.
Well, you'll object -- no, you
know, you would still hear me through
as I
10
understand it, there would be a delay on your
11
end as well hearing me through the conference
12
let me just test it for a second and see what
13
it's like.
Hold on.
14
Can everyone hear me?
15
MS. STELLA:
16
hear an echo.
THE REPORTER:
17
18
record for a minute.
19
MR. ROSEN:
Yeah, not a problem.
BY MR. ROSEN:
21
23
Evan, if we can go off the
(Discussion off the record.)
20
22
can't hear you well and I
Q.
Ms. Hunt, besides the court reporter, Ms.
Fawcett, is there anyone in the room with you?
24
A.
No.
25
Q.
We have on the phone with us two other

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October 17, 2014
8
1
attorneys, Lauren Schwarzfeld and Ms. Ste l la.
represent the plaintiff in this case.
is Federal National Mortgage Association .
have a personal attorney there with you?
MS. STELLA:
BY MR. ROSEN:
Q.
They
The plaintiff
Do you
We represent her also.
Do you have any writing, Ms. Hunt , that
indicates that those attorneys that are on the phone
represent you as well?
10
A.
I don't understand what you ' re saying .
11
Q.
Do you have anything in writing that
12
indicates that those two women on the phone, the two
13
individuals on the phone represent you as well?
14
A.
Yes .
15
Q.
You have something in writing that says
16
17
that they represent you?

MS. STELLA:
Form.
I don't think she's
18
understanding the question.
19
You can take my word for it .
20
the carrier.
21
MR. ROSEN:
We represent her.
We also represent
Ms . Scharzfeld, if you have an
22
objection , please state it clearly and concisely
23
for the record.
24
is you're instructing the witness how to answer
25
and that's improper.
What you ' re doing by speaking

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October 17, 2014
1
2
MS. STELLA:
speaking.
MR. ROSEN:
Well, not during the depo
you ' re not.
clearly and concisely pursuant to 1.310 .
Speaking objections are not permitted.
You ' re going to state an objection
MS . STELLA :
I ' m the one making the
objections and defending the deposition .
me , Ms . Stella.
10
MR. ROSEN :
11
MS . STELLA:
12
BY MR. ROSEN:
13
Q.
I t's
Okay .
Just trying to be clear.
So my question, Ms . Hunt, and we ' ll get to
14
that in a second about the objections , et cetera, do
15
you have anything in writing that indicates that
16
you ' re represented by these attorneys that are on the
17
phone?
18
MS . STELLA :
19
BY MR. ROSEN:
Form.
20
Q.
You can still answer.
21
A.
I ' m -- I still don ' t understand what you ' re
22
23
(""
I' m the one who is going to be
trying to ask me.

Q.
Sure .
Ms. Hunt, do you have anything in
24
writing that indicates that you're represented by any
25
attorney in this action?

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October 17, 2014
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1
MS. STELLA:
MR. ROSEN:
And she ' s not a party .
You can answer the question .
Again, Ms. Stella , you're instructing the
witness and suggesting and under l.310(c)
specifically, objections, quote , during
depositions must be stated concisely and in a
non- argumentative and non-suggestive manner.
MS . STELLA :
THE WITNESS :
11
Form .
I ' m.
BY MR. ROSEN:
10
Form .
Q.
If you're looking at any papers, you really
12
can ' t do that at this point .
13
tell me , " I don't know."
If you don ' t
14
A.
I don't know.
15
Q.
If you don ' t know then tell me.
16
Okay.
17
MS. STELLA:
know, just
Fair enough .
If we can just, for the
18
record, be clear, court reporter , can you please
19
have the record reflect that we , Popkin and
20
Rosaler represent Ms. Lona Hunt with respect to
21
this deposition and in this case.
22
23
BY MR. ROSEN:
Q.
Ms. Hunt , you heard what was just said .
24
you have any reason other than what was said to
25
believe -- I've asked you if you have anything in

(919} 969-1169
Do

October 17, 2014
11
1
writing and you don ' t know.
o t her than what you just heard that you ' re
represented by anyone in this case?
Please repeat .
MS . STELLA :
BY MR. ROSEN:
Q.
Form.
Do you have any reason to believe that
you ' re represented by an attorney other than what you
just heard from the person speaking on the phone?
10
A.
I don ' t know.
11
Q.
Okay .
12
MS. STELLA:
13
minute, please?
14
MR . ROSEN :
15
16
Can we go off the record for a
No , we can ' t.
We ' re going to
continue on with the deposition.

MS. STELLA:
If we're going to have an
17
issue as to whether or not she is represented
18
it ' s going to be a problem.
19
to be a problem, then we're going to have to end
20
the deposition.
21
represent her?
22
23
A.
Any reason to believe
MR . ROSEN :
record .
And if it ' s going
So can we establish that we
You ' re testifying on the
Let's go forward .
24
MS . STELLA :
25
and you refused.
I asked to go off the record

So if you prefer to go off the

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October 17, 2014
12
1
record, we can talk about it then.

MR. ROSEN:
2
3
obstructing my ability to take a deposition.
I'm going to move for a protective order and
certify the pending questions and I'm going to
get a judge on the phone now.
continue the deposition or you can take your own
deposition.
later.
10
You can let me
You can ask your own questions
You have an opportunity to do that, but
I'd like to continue the deposition, please.

MS. STELLA:
11
r-
Ms. Stella, you're now
We can get a judge on the
12
phone if you'd like.
13
establish that we represent her.

MR. ROSEN:
14
That's going to help
If you're going to continue to
15
obstruct, then I have no choice.
16
continue on with the deposition.
17
MS . STELLA:
Let me just
I'm asking to just establish
18
that we represent her.
19
right now, which should be sufficient.
20
MR. ROSEN:
I'm telling you that
You're testifying on the record
21
on my deposition -- during my deposition.
22
you've said what you want to say, we can move
23
on.
24
25
Thank you.
BY MR. ROSEN:
Q.
Ms. Hunt, have you ever been deposed

(919) 969-1169
Now,

October 17, 2014
13
before?
A.
No.
Q.
Any reason you ' re unable to answer
truthfu l ly today?
A.
No.
Q.
I ' ll ask you to please give full answers to
questions.
Okay?
A.
Yes.
Q.
And if there are any documents that can
10
help you answer a question , if you'll please let me
11
know.
Okay?
12
A.
Okay.
13
Q.
Now , there ' s a court reporter there who is
14
taking down the questions and answers.
15
verbalize your answer.
16
head or say "uh- huh" or "huh- huh" .
17
that?
You have to
You can't just shake your

Do you understand
18
A.
Yes .
19
Q.
And you understand that we're here asking
20
you questions under oath to gather information.
21
if you answer a question, I ' m going to assume and
22
we ' re all going to assume that you understood the
23
quest i on .
24
us know that you don't understand.
25
And
If you don ' t understand , you'll please let

Okay?
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October 17, 2014
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1
2
Q.
Just like you ' ve done that already,
so that ' s good .

If you need to take a break or use the rest
3
4
room, please just let us know, we'll be happy to
accommodate you.
Once we ask a question , you can ' t speak to
Okay .
anyone once a question is pending, okay.
understand that?
A.
Okay.
10
Q.
Okay.
11
A.
Yes .
12
Q.
Okay.
Do you
Are you taking any medication?
I don't want to pry , but any
13
medication that would affect your ability to testify
14
truthfully and to understand the questions being --
15
any questions being posed to you normally?
16
A.
No .
17
Q.
And are you feeling well today , no cold or
18
illness?
19
A.
Yes , I
20
Q.
Great.
feel fine.
I
have to ask, unfortunately , are
21
you under the influence of any drugs or alcohol at
22
the moment?
23
A.
No .
24
Q.
Good.
25
Now, as you've heard, there may be
some objections from the lawyers on the phone .
In
I
J

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October 17, 2014
15
r"
1
very limited circumstances can a lawyer advise you
not to answer.
is an objection the rules requ i re that you still
answer, even when the objection is pending.
okay
Are you
do you understand that?
A.
Yes.
Q.
Okay .
So unless someone tells you not to
answer, you just can go ahead and answer and ignore
the objection for your purposes .
Okay?
10
A.
Yes.
11
Q.
Did you prepare for this deposition?
12
A.
Yes.
13
Q.
Okay.
14
A.
I looked at the loan.
15
Q.
When you say you looked at the loan, what
16
do you mean?
17
A.
18
19
20
r'
Generally, in a deposition when there
How did you prepare?
I pulled it up and looked who it was and
looked at the information that was on the verified.

Q.
When you say you looked it up, what were
you looking at, were you looking at the computer?
21
A.
Our -- yes.
22
Q.
And what is that computer system, what is
23
that called?
24
MS. STELLA:
25
BY MR. ROSEN:
Form.

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October 17, 2014
16
Q.
You can answer.
Again, she's objecting to
form, but you can go ahead and answer.
A.
It's just a computer report.
Q.
Okay.
report?
A.
PULS.
Q.
I'm sorry, I couldn't hear that.
A.
PULS.
Q.
PULS?
10
A.
Yes.
11
Q.
Is that p-a-1-s?
12
A.
P-u-1-s.
13
Q.
Okay.
14
A.
I don't know .
15
Q.
What did you see in the PULS system while
16
What is that called, the computer
And what does that stand for?
preparing for this deposition?
17
A.
Just the name, the address and the dates.
18
Q.
You saw the borrowers' names, Mr. and
20
A.
Yes.
21
Q.
The address of the property?
22
A.
Yes.
23
Q.
And the date you said?
24
A.
Yes.
25
Q.
What dates are you ref erring to?
19
Mrs.

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October 17, 2014
17
~
1
A.
The date that they have their owed for.
Q.
Anything else that you reviewed in the PULS
3
4
A.
That was it.
Q.
Any -- you said you earlier had looked at
the l oan.
loan, so really was it the name, the address and the
dates?
So when you said you were looking at the
A.
Yes.
10
Q.
And that's the date of the default, the
11
r'
system while preparing for this deposition?
amount or - - rather, the date that ' s owed?
12
A.
Yes.
13
Q.
Okay.
14
A.
That was it .
15
Q.
And these were a l l on a computer screen or
16
And anything else you looked at?
you printed these things out, the PULS report?
17
A.
On the screen.
18
Q.
When did you do this?
19
A.
Today .
20
Q.
Are you able to do that on your own or did
21
someone else print it for you?
22
MS. STELLA :
23
24
25
Form .
She said that it wasn ' t
printed.
MR . ROSEN:
Again, feel free to object.
Obviously, I don ' t want to impede your ability

( 919} 969 - 1169

October 17, 2014
18
to object, but the question is pending.
BY MR. ROSEN:
Ms. Hunt, you can go right ahead and
Q.
answer.
A.
On the screen.
Q.
Did you pull it up on the screen yourself?
A.
Yes.
Q.
Okay.
Was anyone in the room with you when
you pulled this up on the screen?
A.
There's people in different cubes around
12
Q.
Okay.
13
A.
No.
14
Q.
Okay.
10
11
15
me.
Anyone in your cube?
Did you have a conversation with any
attorneys in preparation for today?

MS. STELLA:
16
I'm going to object.
And,
17
Lona, you can answer it to the extent that how
18
you prepared, but any kind of our communication,
19
any communications with the attorneys is
20
privileged and I will direct you not to answer.
21
To the extent you can answer without divulging
22
the contents of our discussions, you can answer.
23
24
25
BY MR. ROSEN:
Q.
And just to be clear, I don't want to know
what was said.
I just want to know did you -- did
I
. = ___/

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October 17, 2014
19
1
you meet with them to start?
that I'm going to ask you that I want to know what
was said, I don't want to know and I ' m not asking.
Well, I may want to know, but I'm not asking.

Tell me, to answer your question, did you
('
If there's something
meet with the attorney, any attorneys in preparation
for today?
A.
Yes.
Q.
And when was that?
10
A.
At 9:00 , 9 o'clock this morning.
11
Q.
Okay.
12
How many times did you meet with the
attorneys in preparation for this?
13
A.
Once.
14
Q.
Did you meet in person?
15
A.
Can you repeat that, please?
16
Q.
Sure.
17
How did you meet, in person or over
the phone or some other method?
18
A.
Phone.
19
Q.
And who else was on the phone call?
20
A.
What ' s her name?
21
Q.
So Lauren, yourself and anyone else?
22
A.
Mary.
23
Q.
Okay .
Lauren.
Let's talk about where you work now .
24
Do you still work for Seterus?
25
that's the right way to pronounce it.
And I never know if

Is that how

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October 17, 2014
20
1
it's pronounced, Seterus?
A.
Seterus, yes.
Q.
I've heard some people say Seterus , but I
don't know .
So it ' s Seterus, okay.
Anyplace else that you work for?
MS. STELLA:
BY MR. ROSEN:
Form.
Q.
You can answer.
A.
Yes.
10
Q.
Okay.
11
A.
Oh, I'm not understanding what you mean.
12
Q.
Do you work for another company in addition
13
to Seterus?
14
A.
Oh, no.
15
Q.
Okay.
16
Do you work anyplace else?
Where else do you work?
And where is the location that you
work for Seterus?
17
A.
Please specify what you mean.
18
Q.
Sure .
19
20
21
22
What is the address of where you go
to work for Seterus?

A.
3039 East Cornwallis Road, Durham, North
Carolina.
Q.
And at the time of the -- of January 10 ,
23
2012 was that where you were working, in that same
24
location?
A.
Yes.
25
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21
(''
Q.
1
2
looks like back in January 2011; is that right?
MS. STELLA:
THE WITNESS:
BY MR . ROSEN:
Form .
2010 .
Q.
Do you know what month?
A.
April.
Q.
What is your job title with Seterus now?
A.
Time management specialist.
10
Q.
What was your job title as of January 10,
12
A.
Foreclosure specialist.
13
Q.
When you started with Seterus what was your
11
And you started working with Seterus it
14
2012?
job title?
15
A.
Foreclosure specialist.
16
Q.
And did it stay foreclosure specialist all
17
the way through January 10, 2012?
18
MS. STELLA:
19
BY MR. ROSEN:
20
Q.
Form.
In other words, were you a foreclosure
21
specialist from the time you started to the time you
22
signed the complaint?
23
after that.
And then we'll talk about
24
A.
Yes.
25
Q.
And at some point your title changed
'- .

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October 17, 2014
22
apparently.
A.
January 2014.
Q.
And what did that change to?
A.
Time line management or specialty.
Q.
And that would be your title today?
A.
Pardon me?
Q.
That is your job title still today,
timeline management specialist?
A.
Yes .
10
Q.
Just to be clear , your title is not record
11
custodian , correct?
12
A.
Correct.
13
Q.
It ' s never been record custodian while at
14
Seterus?
15
MS . STELLA:
16
BY MR . ROSEN :
Form.
17
Q.
You can answer.
18
A.
Repeat, please.
19
Q.
Sure .
20
Your job t i tle has never been record
custodian since you ' ve been with Seterus , right?
21
A.
Correct .
22
Q.
As a foreclosure specialist back in
23
24
When did your title first change?
25
January 2012 , what were your job responsibilities?

A.
To get documents that the attorneys needed.
I did the verified complaint.

(919) 969-1169

October 17, 2014
23
1
Q.
Anything else?
A.
That was it.
Q.
When you said get documents that attorneys
needed , what did you mean by that?
A.
The note and the mortgage.
Q.
So tell me, would an attorney request that
from you?
A.
Yes.
Q.
And how would you go about getting the note
10
and the mortgage to the attorney?
A.
11
12
our system and I would just -- I don ' t
13
put it, how to say it.
14
15
16
know how to
It would already be imaged .
would just send it in a DDF.
Q.
Okay .
Was it an e-mail or some sort of
other program that you did that?
17
A.
It was in another program.
18
Q.
Do you remember the name of that program?
19
A.
LPS.
20
Q.
LPS, okay.
21
22
Uploading it into our system or it was in
Any other responsibilities around January

of 2012?
23
A.
No.
24
Q.
And prior to January 2012, from the time
25
you started with Seterus, have your responsibilities

-~ .. -
--- -
........._. ...... ..1. _ _ _
- - - -" \ -

{919) 969-1169

October 17, 2014
24
1
A.
No .
Q.
So have you had your responsibilities
No .
change after January 10, 2012?
A.
No.
Q.
How about when your job title changed in
January of this year, did your responsibilities
change then?
A.
Yes .
10
Q.
And how so?
11
A.
I don ' t do verified complaints anymore .
12
Q.
Okay .
13
A.
How do I put that?
What do you do now?

I
don ' t
know how to say
14
it .
15
the proper processes to move forward on the next
16
milestone.
17
18
19
changed?
I check -- I make sure that the attorneys are at
Q.
Could you please explain a little bit more
about that for us?

A.
I put loans on hold , remove holds and just
20
make sure that the loans are moving towards the
21
f oreclosure .
22
Q.
It sounds like you ' re interacting with
23
attorneys, and you just correct me if I ' m wrong,
24
you ' re interacting with attorneys to help move cases
25
along that are in foreclosure; is that right?

(919) 969-1169

October 17, 2014
25
A.
Correct, yes.
Q.
And you said to meet certain milestones.
What are those milestones?
A.
Like judgment, NODs and sell dates.
Q.
Any other milestones?
A.
No.
Q.
Is referral or filing suit , is that
considered a milestone?
MS. STELLA:
9
10
Form .
BY MR. ROSEN:
11
Q.
You can answer.
12
A.
The referral is already completed by the
13
14
15
time I get the loan.

Q.
Okay.
So you're working with loans that
are in default at this point?
16
A.
Yes.
17
Q.
And the same for as of January 10, 2012 you
18
were working only with l oans that were in default as
19
a foreclosure specialist , right?
20
MS. STELLA:
21
BY MR. ROSEN:
Form.
22
Q.
Again, you can answer .
23
A.
Okay.
Can you repeat, please?
24
Q.
Sure .
January 10 , 2012 your involvement
25
with Seterus was for loans that were in default,

(919) 969-1169

October 17, 2014
26
1
correct?
A.
Yes.
Q.
You didn ' t have any involvement with loans
that people were current on their mortgage , right?
A.
Correct .
Q.
Do you supervise anyone?
A.
No.
Q.
And this location that you gave us, your
work l ocation in Durham, is that an office?
10
A.
It ' s a -- yeah .
11
Q.
It's a building , but it ' s an office for
12
Seterus?
13
home let ' s say or some other place?
I ' m asking you ' re not working out of your
14
A.
It's a building for Seterus .
15
Q.
Okay.
16
18
Have you ever signed anything other
than verifications for Seterus in a foreclosure - MS . STELLA:
17
Q.
MS. STELLA:
20
BY MR . ROSEN :
22
Q.
Form.
-- proceeding?
19
21
It ' s a building.
Form .
You can answer.
I ' ll repeat it if you need
me to .
23
A.
Please repeat .
24
Q.
Have you signed anything else other than
25
verifications for Seterus?

(919) 969-1169

October 17, 2014
27
1
A.
No.
Q.
Prior to working for Seterus, if you could
give us a little bit about your background .
other type of work did you do?
A.
I worked for Nortel .
Q.
Nortel Networks like the cell phone
communications company?
A.
Yes .
Q.
It looks like you were there for a very
10
long time , 26 or so years; is that right?
11
A.
Yes .
12
Q.
That ' s a milestone.
13
achievement.
14
me ask you just briefly, what did you do for Nortel
15
roughly?
That ' s quite an
And prior to that you were with -- let
16
A.
Data entry, inventory control .
17
Q.
And prior to that you were with Barclays
18
~-
What
and then Wachovia; is that right?
19
A.
Yes.
20
Q.
And what did you do for those companies?
21
A.
I was foreclosu r e.
22
Q.
What about foreclosure did you do?
23
A.
Bids .
24
Q.
Bids?
25
(919) 969-1169

October 17, 2014
28
1
2
So you helped Wachovia or Barclays purchase
foreclosures, is that what you did?
A.
No.
Q.
Okay.
A.
I would prepare the bid for the attorney to
go to sale.
8
9
Please describe what you mean by
bid .
Q.
The process of preparing the bid for the
attorney to go to sale, other than that , is there
10
anything else that you did with Wachovia or Barclays
11
while you worked there?
12
A.
No.
13
Q.
And how long were you at Barclays and
14
Wachovia?
15
MS. STELLA:
16
BY MR. ROSEN:
17
18
Q.
How long were you at those
companies?
MS . STELLA:
20
THE WITNESS:
21
BY MR . ROSEN :
23
Form.
You can answer.
19
22
Q.
Q.
Form.
Almost ten years.
What ' s the highest level of education
you ' ve received?
24
A.
GED.
25
Q.
Now, we're here to testify -- you're here
l
I
lI
lI
I
"--'

(919) 969-1169

October 17, 2014
29
to testify about a particular case .
The case is a
Miami - Dade County, Florida case.
the Federal National Mortgage Association .
defendants , among others , are
The plaintiff is
The
and
I'd like the court reporter to hand you the
documents that we sent .
It should be a complete copy
of the complaint.
have a copy of that, I ' ll gladly e-mail it to you now
And , Mary and Lauren, if you don't
10
what I sent to the court reporter.
11
summons.
12
the last page being the last page of the note.
It's
13
the summons that was served on
It is
14
the complete package, includes a lis pendens, et
15
cetera , but it is the verified complaint that was
16
filed in this case.
17
copy .
18
19
It starts with the summons and ends with
MS. STELLA:
If you'd like I can send you a
Will you be questioning her on
the summons?
20
MR. ROSEN:
21
MS. STELLA:
22
It was the
No.
No, I will not.
I just have the complaint , so
that ' s fine.
23
MR. ROSEN:
24
sure you have a copy.
25
look at the complaint and at the package in
Okay.
So you have it.
I 'm
Let me ask you to take a

(919) 969-1169

October 17, 2014
30
1
front of you.
could just mark this for identification
purposes.
(Exhibit 1 marked for
identification.)
BY MR. ROSEN:
6
Q.
('
And, madam court reporter, if you
And I want to call your attention there a
few pages in where it says "verified complaint".
you see that?
10
A.
Yes.
11
Q.
And I want you to flip over to the next
Do
12
page where it shows "Seterus, Inc., as servicer for
13
Federal National Mortgage Association," midway down
14
the page.
Do you see that?
15
A.
Yes.
16
Q.
Is that your signature?
17
A.
Yes.
18
Q.
Okay.
And it says the date lS

Is that the date that you
19
January 10th, 2012.
20
actually signed that document?
21
A.
Yes.
22
Q.
You're shaking your head.
24
A.
Oh, no.
25
Q.
Okay.
23
Are you not
sure?
Yes, it's on the document.
If you don't remember feel free to

(919) 969-1169

October 17, 2014
31
1
say, "I don't remember," but that's what it shows.
don ' t want to put words in your mouth, okay.
A.
Okay.
Q.
Did you undertake any training to verify a
complaint for Seterus prior to January 10, 2012?
A.
Yes.
Q.
And what was that training?
A.
It was where the managers train us on how
9
10
to -- or trained me on how to verify and to look at

the document.
11
12
Q.
Okay.
Who was it that trained you?
I 'm
sorry, it broke up a little bit.
13
A.
My team lead .
14
Q.
And who was that person, what is their
16
A.
Richard Adams.
17
Q.
And when did Richard Adams train you?
18
A.
Repeat, please.
19
Q.
Sure.
20
A.
I don't remember.
21
Q.
Would it have been when you first started
15
22
name?
When did Richard Adams train you?
working for Seterus?
23
A.
No.
24
Q.
Would it have been within a year roughly
25
after you started working for Seterus?

(919) 969-1169

October 17, 2014
r:
32
1
A.
Yes.
Q.
And how many times did you meet with -- or
train with Mr. Adams?
A.
A couple of times.
Q.
A couple meaning two?
A.
Yes .
Q.
And what did you - - what did Mr. Adams
explain to you or what did your training consist of,
rather?
10
A.
The verified complaint and what to look for
11
on the verified complaint that was on our computer
12
report.
13
Q.
14
So explain that to me just briefly.
would go over a verified complaint on the computer?
15
MS. STELLA:
16
BY MR. ROSEN:
17
18
19
You
Q.
Form.
You can answer.
You went over a verified
complaint on the computer?

A.
Would look at the document that we received
20
and we would look at the computer report on what I
21
was supposed to look at to make sure that both
22
matched.
23
24
25
Q.
So the document that you received, what are
you referring to , what document did you receive?

A.
The verified complaint .

(919) 969 - 1169

October 17, 2014
r-
33
1
2
So that would come in to you in paper or on
computer?
A.
Paper.
Q.
Okay.
A.
In a box.
Q.
Do you know who put that paper in the box?
A.
No.
Q.
And did you have a box to start at the
Q.
And how did that get to you?
beginning of each day with verified complaints?
10
A.
Yes.
11
Q.
And roughly how many did you have in the
12
box at the beginning of each day?
13
A.
It varied.
14
Q.
Okay.
15
More or less , if you could tell us a
high number or a low number for a day?
16
MS . STELLA:
Form.
17
BY MR . ROSEN :
18
Q.
You can answer, if you know .
19
A.
I don ' t.
20
Q.
You don ' t know roughly the range of how
21
many verified complaints would be in the box each
22
day?
23
MS. STELLA:
24
BY MR. ROSEN:
25
Q.
Form.
You can answer .

(919) 969-1169

October 17, 2014
34
1
A.
Roughly maybe 60 .
Q.
And approximately how many of those did you
view each day?
MS. STELLA :
THE WITNESS :
BY MR. ROSEN:
Q.
Form .
Thirty .
MS . STELLA :
Form.
THE WITNESS:
Yes .
11
remember .
And did you verify those 30 each day?
10
I can ' t
BY MR . ROSEN:
Q.
Apparently then there must have been a
12
backlog that was getting created if 60 are coming in
13
roughly and 30 are being verified roughly, the box
14
must have been building up?
15
MS. STELLA:
16
BY MR . ROSEN :
17
Q.
18
19
Is there a time that you caught up -MS. STELLA :
Q.
Form.
Form.
-- on the verifications?
20
MS. STELLA :
21
MR. ROSEN :
22
finish the question .
23
MS . STELLA:
24
MR. ROSEN :
25
Form.
If you could please let me
There is a lag.
There is an objection in the
middle of my question.
(919) 969-1169

October 17, 2014
35
1
MS . STELLA:
MR. ROSEN:
I hear you on that.
intended or pun intended.
Q.
MS. STELLA:
BY MR. ROSEN:
Q.
filings?
11
along as best we can.

A.
Was there a backlog of
Note counsel's objection .
objection to form.
12
Form.
You can answer.
10
13
Yes.
So was there a backlog?
No pun
BY MR. ROSEN:
There is a break -- sorry.
There is an
I'm trying to help move this
Backlog as -- what do you mean by a
backlog?
14
Q.
Sure.
You're telling us that about 60
15
roughly per day came in to your box of verified
16
complaints and that you got to verify about 30 of
17
them.
18
did they remain in the box?
My question is what happened to the other 30,
19
A.
They were put in a cabinet.
20
Q.
And were those extra 30 then returned back
21
22
to you the next day?

A.
Yes.
23
MS . STELLA:
24
BY MR. ROSEN:
25
Q.
Okay.
Form.
And then more verifications

(919) 969-1169
like

October 17, 2014
36
1
verified complaints would be added to that box for
you to continue to work on each day, is that how that
worked?
A.
Yes.
Q.
Okay.
As far as the training that you
started to talk about with Mr. Adams, so it sounds
like now that you got the verified complaint and he
trained you how to look at the computer , is that what
you were saying , to look at the computer and look at
10
the documents and compare things?

MS. STELLA :
11
Ii
Form .
BY MR. ROSEN:
12
13
Q.
You can answer.
14
A.
Yes.
15
Q.
Tell us a little bit about that.
What is
16
it that you were looking for to compare between the
17
verified complaint and what was on the computer?
18
A.
The defendant ' s name , the county .
19
Q.
If you could just
it looks like you're
20
looking down at some paper.
21
testify as to personal knowledge.
22
any paper to refresh your recollection, we can
23
certainly explore that, but just as far as what you
24
know rather than looking at anything .
25
A.
I just want you to

If we need to use
Just --
i
(919) 969-1169

October 17, 2014
37
1
Q.
The defendant's name, the county?
A.
The UPB and the date.
Q.
And that's the date of?
A.
The default.
Q.
Okay.
at between the verified complaint and what was on the
computer screen?
MS. STELLA:
Form.
THE WITNESS:
No.
BY MR. ROSEN:
10
('
Anything else that you were looking
11
Q.
What was on the computer screen?
12
A.
Their loan number, their name, their
13
address, their UBP and the default date.
14
Q.
And was that through that PULS system as
16
A.
Yes.
17
Q.
And PULS, you've been using PULS the entire
15
well?
18
time you've been with Seterus?
19
MS. STELLA:
20
THE WITNESS:
21
BY MR. ROSEN:
22
Q.
Okay.
Form.
Yes.
Is there anything else that you
23
looked at other than the PULS report when looking at
24
the complaint?
25
MS. STELLA:
Form.

(919) 969-1169

October 17, 2014
38
1
THE WITNESS:
BY MR. ROSEN:
Q.
Please say it again.
Was there anything else you looked at other
than the PULS report when also looking at the
complaint?
MS. STELLA:
Form.
THE WITNESS:
BY MR. ROSEN:
You can answer.
The note and the mortgage.
Q.
Anything else?
10
A.
No.
11
Q.
And how did you view the note and mortgage?
12
A.
In the package.
13
Q.
Was that a printed package?
14
A.
Yes.
15
Q.
So in the package was a blank verified
16
complaint and a note and a mortgage?
17
A.
Yes.
18
Q.
Okay.
And so that's what we were talking
19
about, those packages were in your box in the
20
morning
21
A.
Yes.
22
Q.
-- right?
23
A.
Yes.
24
Q.
Was there anything else in the package?
25
MS. STELLA:
Form.

(919) 969-1169

October 17, 2014
39
THE WITNESS:
BY MR . ROSEN:
Q.
When you were done comparing what was on
PULS and looking over the package and let's say you
signed and -- you signed the complaint, what happened
to the complaint next, what did you do with it?
A.
Put it in a FedEx box .
Q.
And where did that document then -- where
did that package then go?
10
A.
To the attorney.
11
Q.
Did the package contain the original note
12
and mortgage?
13
A.
No .
14
Q.
Anything else that you went over with
15
Mr . Adams in your training?
16
A.
No.
17
Q.
Approximately how long did you train with
18
Mr. Adams those two times that you met with him?
19
A.
I don ' t remember.
20
Q.
Would it be less than an hour each time
21
r"
I can ' t remember .
roughly?
22
A.
No .
23
Q.
Okay.
It would be longer .
And as part of your training did you
24
actual l y sign some comp l aints while he supervised
25
you?
(919)
969-1169

October 17, 2014
40
1
A.
I don't remember.
Q.
Did he sign any complaints while you
watched him?
A.
I don ' t remember .
Q.
Now, you talked earlier about a cubicle.
Is that what you were working in a cubicle in January
of 2012 when you signed this complaint?
A.
Yes.
Q.
If you could just describe for us briefly
10
the office space area, help us get a picture , how
11
many cubicles were in the area in which you worked?
12
MS. STELLA:
13
THE WITNESS:
14
BY MR. ROSEN:
15
Q.
Four.
Form.
Four.
And were there any -- if there four
16
cubicles in the room, was there anything else in that
17
room besides the four cubi cles?
18
MS . STELLA:
19
THE WITNESS :
20
BY MR. ROSEN:
Form .
Filing cabinet.
21
Q.
And anything else?
22
A.
No .
23
Q.
Were the other people in the other cubicles
24
25
doing the same thing that you were doing?

A.
No.

(919) 969-1169

October 17, 2014
41
(""
2
doing?
MS. STELLA:
THE WITNESS:
BY MR. ROSEN:
6
7
Q.
Form.
I don't remember.
But you know they were not doing the same
work as you, right?
A.
Right.
Q.
Okay.
10
What type of work were the other people
Q.
Did you ever sign notarized
documents?
11
MS. STELLA:
12
THE WITNESS:
13
BY MR. ROSEN:
14
Q.
Sure.
Form.
Not sure what you're asking.
Did you ever sign in the presence
15
of a
a notarized document, meaning that you sign
16
and then a notary will sign and stamp it, did you
17
ever do that for Seterus where you're signing
18
something that is then notarized?
19
MS. STELLA:
20
THE WITNESS:
21
BY MR. ROSEN:
22
23
Q.
Okay.
Form.
No.
Anyone else in those cubicles that
were signing things that are then notarized?
24
MS. STELLA:
Form.
25
THE WITNESS:
I don't remember.

(919) 969-1169

October 17, 2014
42
BY MR . ROSEN:
Q.
How much time does it take you to review
the documents in the package and what ' s on the screen
when you ' re undertaking this process that you did in
this case where you ' re signing the complaint?
MS. STELLA:
THE WITNESS :
BY MR . ROSEN :
Q.
Form.
Five to ten minutes.
Do you know in this case who the owner of
10
the loan is?
11
if you know.
12
A.
Repeat, please.
13
Q.
Sure .
14
Do you know who the owner of the
loan is in this case?
15
A.
16
Q.
17
Without looking at any documents , just
And do you know who the servicer of the
loan is in this case?

A.
Fannie Mae.
19
Q.
And what is Seterus ' s -- I mean, back up
for one second , I ' m sorry .
21
22
Hold on for one second.
Do you know where the original note and

mortgage was kept around January 10th of 2012?
23
::~ ::::~:~: F:::~ all -- repeat .
24
25
..
--n"";'lt-..
18
20
I
I
BY MR . ROSEN:
-=-<=1"- .....--- ...~-'" ..,,.,.. ~..
"l'-1'-f...
lI
l
Il
I
11
......-
- - - - - - -.... , ._
........
..,;.1._ .........
~ ..... ~~ ....... -
- - -..

(919) 969-1169

October 17, 2014
43
~
1
Q.
Sure .
Do you know where the original note
was kept at the time of January 20 1 2?
MS . STELLA:
THE WITNESS:
BY MR. ROSEN:
Q.
Form .
No .
And you never saw the original documents ,
the original note when you reviewed the complaint and
the documents we talked about , right?
A.
Right .
10
Q.
Let's take a look at the complaint .
11
of all, before you signed, did you read the
12
complaint?
First
13
A.
No.
14
Q.
It says in paragraph 1 that this is an
15
action to foreclose a mortgage on real property
16
located in Miami-Dade County , Florida.
17
know or how do you know, if you know, that this
18
property is l ocated in Miami - Dade County, Florida?
How did you
19
A.
The mortgage .
20
Q.
And also in paragraph 1 there is the word
21
" conditions precedent".
22
precedent mean?
23
24
25
MS . STELLA:
What does conditions
Objection.
It ' s a legal
conclusion.
BY MR. ROSEN:
( 919) 969-1169

October 17, 2014
44
1
Q.
You can answer.
A.
I'm not sure .

MS . STELLA:
If you understand the
question, you can answer.
THE WITNESS :
MS. STELLA:
I didn ' t hear what she said .

If you understand the
question, you can answer , but we ' re objecting on
the basis that it ' s a legal conclusion .

THE WITNESS:
MR. ROSEN:
10
I don't understand.
It ' s a speaking objection .
11
you can just limit it.
12
BY MR . ROSEN:
If
13
Q.
Ms. Hunt?
14
A.
Sir?
15
Q.
I just want to know if you know what that
16
means?
17
A.
I don't understand , no .
18
Q.
Okay .
You understand my question , you just
19
don ' t understand what conditions precedent means , is
20
that what you ' re saying?
21
A.
Yes.
22
Q.
How did you know, if at all , whether or not
23
conditions precedent to the filing of this matter had
24
been completed or waived, if you knew?
25
MS. STELLA:
Objection, lega l conclusion.

(919) 969-1169
-I

October 17, 2014
45
~
BY MR. ROSEN:
1
2
Q.
You can answer.
A.
I didn't know.
Q.
Okay.
In paragraph 2 it says subject

How do you
property owned by defendant
know that or do you know that?
A.
The mortgage and the note.
Q.
And something in the mortgage and note
9
10
tells you that they own
A.
Repeat, please.
12
Q.
Sure.
owns the
Something in the mortgage and note

owned the property?
tel l s you that
14
A.
Yes.
15
Q.
Okay.
16
that
subject property?
11
13
("'
I don ' t know.
Again , if you could just not refer
to any paper.
17
A.
Oh , okay .
18
Q.
Thank you so much.
In paragraph 3, and
19
this you're welcome to refer to as I ' m reading from
20
the paragraph , I don ' t mind, just so you can follow
21
along .
22
possession, occupants, and it has an address there,
23
may claim some interest in the subject property by
24
virtue of their possession or occupancy of the same.
25
Did you know if that was the case that there were any
Paragraph 3 says that unknown tenants in

(919) 969-1169

October 17, 2014
46
tenants in possession of the property?
A.
No.
Q.
And what does it mean to be subordinate,
junior and inferior to the lien of plaintiff's
mortgage?
MS. STELLA:
THE WITNESS:
BY MR. ROSEN:
Q.
Objection, legal conclusion.

I'm not sure.
And in the next paragraph, paragraph 4,
10
that in addition to all other defendants and it says,
11
"Unknown spouses, heirs, devisees, grantees,
12
assignees, creditors, trustees, successors in
13
interest or other parties claiming interest in the
14
subject property by, through or against any said
15
defendants, whether natural or corporate, who are not
16
known to be alive or dead, dissolved or existing, are
17
joined as defendants herein."
18
those other specifically -- how did you know that
19
that was the case?
20
MS. STELLA:
21
THE WITNESS:
22
BY MR. ROSEN:
23
Q.
Okay.
How did you know about

I don't know.
It then says, "The claims of said
24
parties are subject, subordinate and inferior to the
25
interests of the plaintiff."
How did you know that

(919) 969-1169

October 17, 2014
f'1"
47
1
that was correct?
MS . STELLA:
THE WITNESS:
BY MR. ROSEN:
defendant ,
promissory note ."
10
A.
I didn ' t know.
Then it says , " On December 20th , 2007
Q.
executed and delivered a

How did you know that was true?
The note.
The date on the note in our
system, the computer report.

Q.
The PULS report shows the date that

allegedly signed the note?
11
12
A.
The origination date, yes .
13
Q.
Okay .
And the same thing for executing the
14
mortgage , is that in PULS as well?
15
all part of the origination date then?
16
A.
I guess that ' s
Yes.
17
MS . STELLA :
Form.
18
BY MR . ROSEN:
19
Q.
I ' m sorry , you have to verbalize your
20
answer .
21
all part of origination; is that right?
The mortgage and the note signature date is
22
MS . STELLA:
Form .
23
BY MR . ROSEN :
24
Q.
You can answer .
25
A.
Yes.
Chapel Hill Reporting, LLC, Servi ng North Carolina

(919) 969-1169

October 17, 2014
48
What does it mean that the mortgage --
Q.
excuse me.
What does it mean securing payment of the
note to JPMorgan Chase Bank , N. A., what does that
mean?
A.
That ' s who had it .
Q.
Okay.
I ' m not for sure.
How did you know that the mortgage
was recorded on January 2nd , 2008 in official records
book 26139 , page 2017?
10
A.
The mortgage.
11
Q.
And how did you know that the property
12
described in the mortgage was owned and in
13
possession
14
possession of it?
or who owned it and who was in
15
A.
Fannie Mae.
16
Q.
How did you know that?
17
MS. STELLA:
18
THE WITNESS :
19
BY MR . ROSEN:
20
Form.
The note .
So, just to clarify ,
Q.
I ' m asking you how did
21
you know who owned and was in possession of the
22
property at the time of -- at the time of
23
origination?
24
A.
Please repeat.
25
Q.
Sure.
"'
I'm asking how did you know who
- -.. . . . .......... ......

..
(919) 969-1169
..... ;= .~
--
. .. ............
... ~""'"--"""' .0..-.1- - ~- ~--~
~,
- .~--
--~~-

October 17, 2014
49
1
owned the property and who possessed the property at
the time of origination?
A.
By the note.
I can't look at the page.
Q.
Let ' s take a look at the note.
It ' s
attached to the complaint, Exhibit B.
me where in the note it says who owned and possesses
the property?
MS . STELLA:
THE WITNESS :
10
13
14
15
16
17
Q.
The back page it ' s telling you who owns the
property?
A.
It says pay to the order of Federal
National Mortgage Association.

Q.
Okay.
What does it mean to be the
mortgagor?
MS. STELLA:
19
BY MR . ROSEN:
21
Q.
Legal conclusion.
You can answer .
If you don ' t
know, you can
tell me.
22
MS. STELLA:
23
THE WITNESS:
24
BY MR. ROSEN:
25
Federal National Mortgage
BY MR . ROSEN :
18
20
Form.
Association , the back page.
11
12
Can you show
Q.
Form .
I ' m not sure .
How did you know that Fannie Mae is the

(919) 969-1169

October 17, 2014
50
1
owner and holder of the note?

A.
2
3
saying that Fannie Mae - - pay to the order of Fannie
Mae in our system.
Q.
5
6
Okay.
What does it mean to be an owner and .
holder of a note?
MS. STELLA:
THE WITNESS:
sure .
Don ' t
Objection , legal conclusion.

I'm not - - I ' m not quite
know.
BY MR. ROSEN:
10
The note where it's stamped at the back
11
Q.
What does it mean to be defaulted?
12
A.
Behind in your payments.
13
Q.
And the screen , the PULS report told you

was defaulted on the note and
14
that
15
mortgage by failing to pay the payment due on
16
January 1, 2010 and all subsequent payments; is that
17
right?
18
A.
Can I turn the page or no?
19
Q.
Yeah.
Thank you so much for asking.
20
Absolutely .
What are you turning the page to?
21
are you looking for?
What
22
A.
23
delinquent .
24
t.~:::~~~:_:_::_a~~~r:~~n:~~:~:~~~~:~~a~:u o::~. I
25
January 1st , 2010 is when it was

(919) 969-1169

October 17, 2014
51
1
that
I just want to confirm -- how did you know
-- and I believe I know the answer ,
defau l ted on the note and mortgage by failing
to pay the payment due January 1 , 2010 and all
subsequent payments?
A.
The computer report system .
Q.
Okay.
What does it mean in number 8 that
the plaintiff declares the full amount payable on the
note and mortgage to be due?
10
MS . STELLA:
11
BY MR. ROSEN:
12
Q.
Feel free to answer , if you know .
13
A.
I'm not sure.
14
Q.
And in paragraph 9, the amount that
15
plaintiff owes, i s that in your PULS report , the
16
239 , 639.41?
17
A.
Yes .
18
Q.
What does indebtedness has been
19
acce l erated , what does that mean?
20
9 , second sentence there .
21
MS. STELLA:
22
THE WITNESS:
23
BY MR . ROSEN:
24
Q.
It ' s in paragraph
Form.
I ' m not sure.
How did you know the plaintiff is obligated

i
25
to
~~~:":~-~"::=~-a-=::~~:.-~:~_:~ th-~~
(919) 969-1169

October 17, 2014
52
services?
A.
I don't.
Q.
Sure.
Can you repeat what you mean?
I ' m just asking paragraph 10 , how do
you know that plaintiff is obligated to pay its
attorneys a reasonable fee for their services?
A.
I don't.
Q.
And how do you know the plaintiff is
entitled to recover its attorneys' fees pursuant to
Florida statute and the promissory note?
10
A.
I'm not sure.
11
Q.
What is a deficiency judgment?
In the
12
wherefore clause it says def i ciency judgment .
13
is that?
14
MS. STELLA:
15
THE WITNESS:
16
BY MR. ROSEN :
17
Q.
What

Not sure.
And it says here beneath that , "If borrower
18
has not been discharged in bankruptcy, " what does
19
that mean, borrower has not been discharged in
20
bankruptcy?
21
MS . STELLA:
Objection , legal conclusion.
22
THE WITNESS:
I don ' t see where it says
23
that .
24
25
I don't know .
BY MR. ROSEN :
Q.
On your -- a little further down it says ,

(919) 969-1169

October 17, 2014
53
1
"Seterus, as servicer for Federal National Mortgage
Association. "
servicer for Federal National Mortgage Association on
this loan?
A.
How do you know that Seterus is the
Seterus services for Fannie Mae.
I ' m not
for sure.
Q.
In this case do you recall if you verified
the first draft that was -- or you signed, rather ,
the first draft that was presented to you?
10
A.
I don ' t know what you mean.
11
Q.
Sure.
So the package would have come in
12
the box and would you have -- in this case did you
13
sign the first one that was presented to you in the
14
package or were there changes made and edits before
15
you signed?
16
A.
So you ' re saying -- I ' m not sure what you
Q.
Sure .
17
18
19
mean .
I ' m asking in this case did you sign
the document as it was presented to you?
20
MS . STELLA:
21
THE WITNESS:
22
25
After verifying the
information .
BY MR . ROSEN:
23
24
Form .
Q.
After doing what you did with the computer
and the papers , right, did you sign the very first
I!
!t
I
I
l
.-I
(919) 969-1169

October 17, 2014
(6"'
54
1
draft that was given to you?
A.
Yes.
Q.
Okay.
What happens if you found an error
in a complaint?
A.
Trashed it.
Q.
Okay.
A.
Yes.
Q.
As far as this process that you testified
9
10
to today , anything else that you ' d like to add?
A.
11
12
Has that ever happened?
No.
MR. ROSEN:
Okay.
I have no further
questions at this time.
13
MS. STELLA:
I'd like to do a brief
14
rehabilitation , but if we can just take a short
15
break .
16
17
MR. ROSEN :
MS. STELLA:
MR. ROSEN:
minutes.
My time is 3 : 23.
So you want
Okay.
See you in seven
Yeah.
22
(Brief recess . )
23
CROSS - EXAMINATION
24
25
How much
to say 3 : 30?
20
21
Be happy to.
time do you need or would you like?
18
19
Sure.
BY MS . STELLA :
Q.
Hi, Lona.

(919) 969-1169

October 17, 2014
55
1
A.
Hi.
Q.
Can you hear me?
A.
Yes.
Q.
I can ' t hear her .
A.
Oh , I ' m sorry .
6
7
this piece of candy out of my mouth.
Q.
Okay .
BY MS . STELLA :
Q.
While we were on break I heard you say that
11
this was nerve wracking and uncomfortable.
12
you ' re nervous.
13
want to clarify some things that were said and make
14
sure we have accurate responses.
15
16
This is your first time .
I know
So I
just
Do you have a copy of the verified

complaint in front of you?
17
A.
Yes .
18
Q.
Okay.
Now, when you received that
19
complaint , the draft to review for execution , did you
20
read it first?
21
A.
No.
22
Q.
Did you read it as you were going through
23
24
I ' ll give you a minute .

(Discussion off the record . )
9
10
I probably need to take
25
to verify the various facts that are set forth in the
comp::.t~:R~~~~::-.~~j=~~~~:~=~- .--~ _mj

(919) 969-1169

October 17, 2014
56
BY MS. STELLA :
Q.
You can answer.
A.
Yes.
Q.
Okay.
Now, you ' re an employee of Seterus
and Seterus is a servicer of loans?
A.
Yes.
Q.
Okay.
A.
Fannie Mae.
10
Q.
Okay.
11
And who does Seterus service loans
for?
And does Seterus service loans for
anyone other than Fannie Mae?
12
A.
No.
13
Q.
In January of 2012 did Seterus service
A.
16
Q.
They only service loans owned by Fannie
18
A.
Yes.
19
Q.
I didn ' t hear your answer .
20
A.
Yes.
21
Q.
Okay .
17
Mae?
Now, if we look at the complaint
22
there seems to be some confusion between ownership .
23
We're referring to two different types of ownership,
24
the owner of the property, the person who lives in
25
the property - - or owns it I should say and the owner
- I
(919) 969-1169

October 17, 2014
r--
57
1
of the loan.
Now, paragraph 6 of the complaint ,
which is on page 2 , says, " Plaintiff is the owner of
the note ."
MR. ROSEN:
Objection , form.
BY MS. STELLA:
Q.
Did you find it?
A.
Okay.
Q.
Okay .
A.
Okay.
10
Q.
Paragraph 6.
11
A.
Okay.
12
Q.
It says , "Plaintiff is the owner. "
13
you verify?
Page 2, okay .
Would you repeat?
I found it now .
14
MR . ROSEN:
15
BY MS. STELLA:
16
17
Q.
How did
Objection, form .
How did you verify that the plaintiff,
Federal National Mortgage Association , was the owner?

A.
18
The back of the note is stamped pay to the
19
order of Fannie Mae and then our system, the computer
20
report system.
21
Q.
Okay.
Now, if we can go one paragraph
22
down
23
Number 2 , that says the property is owned by
24
25
I ' m sorry, let ' s go on to the previous page.
How did you verify that?

A.
~..:o.--
By the note , the mortgage and our system.

............ u. . ...... .
- ....
,,a.a~- .,,._~.
..:--
_,__ __ _ _ _ _
..._n...._~ .. ...
- . . . . - i ; . ..,
4 , . i , . . , , ; . - - - ' - .r-.
l
I
~--.,-------dl

(919) 969-1169
II

October 17, 2014
58
1
Q.
Okay.
A.
Yes.
So the property was owned by
2
3
4
MR. ROSEN:
BY MS. STELLA :
Q.
Objection, form.
And the note was owned by Fannie Mae?
MR. ROSEN:
THE WITNESS:
BY MS. STELLA:
Objection, form.
Yes.
Did you hear?
10
Q.
It was owned by Fannie Mae?
11
A.
Yes.
12
MR. ROSEN:
13
BY MS. STELLA:
Q.
14
Same objection.
And the note was serviced by Seterus?
15
MR. ROSEN:
Objection, form, leading.
16
BY MS. STELLA:
Q.
Who was the servicer of the note or the
19
A.
Servicer would be Seterus.
20
Q.
And who was the owner of the loan?
21
A.
Fannie Mae.
22
Q.
Okay.
17
18
loan?
Now, when you received the complaint
23
did you know whether a notice of intent or NOI had
24
been sent to the borrower?
25
A.
No.

(919) 969 - 1169

October 17, 2014
59
Q.
1
2
MR. ROSEN:
THE WITNESS:
BY MS . STELLA:
Q.
Objection, leading.
Can you repeat , please?
The NOI, the notice of intent, prior to you
receiving a complaint for verification , would you
know that the notice of intent or the NOI had been
sent?
MR. ROSEN:
9
10
Did you know that it had been sent?
Objection, asked and answered .
BY MS. STELLA :
11
Q.
You can answer .
12
A.
No.
13
Q.
Before coming to you , before the verified
14
complaint would be brought to you , the NOI would have
15
to have been sent , correct?
16
17
MR . ROSEN:
Objection , leading; calls for
speculation .
18
THE WITNESS :
19
BY MS . STELLA:
20
Q.
Okay.
Yes.
Now , when you were verifying
21
complaints in January of 2012 , were you supervised by
22
anyone?
23
A.
Yes .
24
Q.
And if
25
you testified before that if
there was a problem you would trash it and if you had

(919) 969-1169

October 17, 2014
60
1
a question, if you were unsure of something , was
there anyone else you could go to to verify , any
other outlets to make sure the information was
correct?
A.
Yes.
Q.
Okay .
A.
That would have been Richard Adams.
Q.
And what if Richard was unable to answer
And who was that?
the question?
10
A.
He would call somebody in Beaverton .
11
Q.
Okay.
12
13
Would you ever just sign the note
without -- without knowing the facts were correct?

A.
No .
14
MR. ROSEN:
15
BY MS. STELLA:
16
Q.
Objection , leading.
And were the facts contained in the
17
complaint, this specific complaint of Fannie Mae
18
versus
19
January 10th , 2012 were the facts true and correct to
20
the best of your knowledge and belief?
21
when you signed your name on
A.
Yes.
22
MR. ROSEN :
23
MS. STELLA:
24
MR. ROSEN:
25
Objection, leading .
No further questions.
Okay.
quick brief redirect .
I may have just one
I'm just going to put you IJ
. . . . . . ~; . .,,_--"-------.. . .,. . . . . ...-.. --~-....~. _.._,. ~. ., _,_. .__.. _~-~---. --~~~-~-~~Jj

(919) 969-1169

October 17, 2014
61
1
2
guys on hold for one second , okay.

MS. STELLA:
(Pause . )
3
4
Okay .
MR. ROSEN :
So I have no further questions .
I just want to inform you pursuant to Florida
Rules of Civil Procedure you have the right to
read the deposition transcript , Ms. Hunt , and
you would then fill out what ' s called an errata
sheet if there ' s anything that you would like to
10
make changes to.
The errata sheet would then be
11
attached to the deposition .
12
deposition for those purposes or you can waive
13
that right to read.
14
MS. STELLA:
15
MR . ROSEN:
16
MS . STELLA:
17
MR . ROSEN:
18
She's going to read .
19
no other questions .
20
deposition .
21
You can read the
She ' ll read.

The choice is
She ' s going to read .
Okay.
Very good .
That's it .
That ' s fine.
And I have
That concludes the
(Continued on the following page . )
22
I
I
I
l
ll
23
24
I
~~
25
(919) 969-1 1 69

October 17, 2014
62
1
2
{Whereupon, at 3 : 40 p.m., the deposition in

the above - entitled matter ceased . )
3
4
LONA HUNT
6
7
8
SUBSCRIBED AND SWORN to before me this

day of
10
11
NOTARY PUBLIC
12
13
My Commission Expires :
14
15
16
17
18
19
20
21
22
23
24
25
(919) 969 - 1169

October 17, 2014
63
1
RPTR:
MMF
DATE:
October 17, 2014
T R A N S C R I P T I 0 N
C 0 R R E C T I 0 N S
CASE NAME: FEDERAL NATIONAL MORTGAGE vs.
WITNESS NAME :
CASE NO . :
LONA HUNT
7
8
PAGE
LINE
READS
SHOULD READ
9
10
11
("'
12
13
14
15
16
17
18
19
20
21
22
23
24
25
(919) 969-1169

October 17, 2014
64
1
CERTIFICATE OF REPORTER
STATE OF NORTH CAROLINA
COUNTY OF WAKE
4
5
I, Maren M. Fawcett, RPR, the officer before
whom the foregoing deposition was taken, do hereby
certify that the witness whose testimony appears in
the foregoing deposition was duly sworn by me; that
the testimony of said witness was taken by me to the
10
best of my ability and thereafter reduced to
11
typewriting under my direction; that I am neither
12
counsel for, related to, nor employed by any of the
13
parties to the action in which this deposition was
14
taken, and further that I am not a relative or
15
employee of any attorney or counsel employed by the
16
parties thereto, nor financially or otherwise
17
interested in the outcome of the action.
18
This the 28th day of October, 2014.
19
20
21
MAREN M. FAWCETT, RPR
22
Notary Public in and for
23
County of Wake
24
State of North Carolina
25
Notary Public No. 200621500068

.
~~~---=---=-...iz:...
.-.:a. ..
..=.,._.......-,,.,.4r..... ..... __... --~--------..------ _ . _ _____ _... _.,........... -.;..,,; .. ______ ____IJ
Chapel Hill Report i ng, LLC, Serving North Carolina

(919) 969-1169

Deposition LH

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DEPOSITION OF LONA HUNT

October 17, 2014

IN THE CIRCUIT COURT OF THE ELEVENTH JUDICIAL CIRCUIT

FEDERAL NATIONAL MORTGAGE

DEPOSITION OF LONA HUNT

MARY STELLA, ESQ.

LAUREN SCHWARZFELD, ESQ.

Law Offices of Popkin & Rosaler, P.A.

1701 W. Hillsboro Boulevard

On behalf of the Defendants, via Skype

EVAN M. ROSEN, ESQ.

Law Offices of Evan M. Rosen, P.A.

2028 Harrison Street, Suite 204

Nakeita Ellington, Law Office of

Evan M. Rosen, via Skype

DEPOSITION OF LONA HUNT

DEPOSITION OF LONA HUNT

was called as a witness by counsel

for the Defendants and, having been duly sworn by the

Notary Public, was examined and testified as follows:

Good afternoon, Ms. Hunt.

I'm Evan Rosen.

I represent Mr. and Mrs.

Lona Hunt, 58.

Mr. Rosen, do you mind if we

do not make her home address part of the

I think she's already said it.

I don't think you can strike it

after the fact.

protective order or something, you're welcome to

If you want to move for

I have no intention of doing anything

Chapel Hill Reporting, LLC, Serving North Carolina

DEPOSITION OF LONA HUNT

wi th that in any way , shape or form.

here to harass Ms. Hunt with her address.

Well, if you file the

transcript with the court, can we just have her

address taken out?

Let's continue with the depo

We can talk about that off the

At the time of the verification of this

complaint , which was apparently around January 10th ,

2012 , where did you live?

address at this point.

city, county and state.

I don ' t need the specific

Let ' s start with maybe the

January 10th, 2012 , where did you live?

Durham , North Carolina .

I'm sorry , what was that?

Durham, North Carolina.

And the city that you live in now is?

Is that where you live now?

Chapel Hill Reporting, LLC, Serving North Carolina

DEPOSITION OF LONA HUNT

As of January 10 , 2012, where were you

working , what city and state?

Well, it ' s Research Triangle Park.

would probably be Durham.

So you ' re working in Durham and

living in Durham around January 10th of 2012; is that

what you ' re saying?

Guys , there is a delay between