Mozillo Transcript

FILED: NEW YORK COUNTY CLERK 12/10/2012
NYSCEF DOC. NO. 3811
INDEX NO. 602825/2008

RECEIVED NYSCEF: 12/10/2012
EXHIBIT 187
In The Matter Of:

MBIAINSURANCECORPORATION
v.
COUNTRYWIDEHOMELOANS,INC.,
___________________________________________________
MOZILO,ANGELOVol.1
June21,2011
___________________________________________________
ANGELO MOZILO - 6/21/2011

Page 1
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF NEW YORK
-------------------------------------x
MBIA INSURANCE CORPORATION,
Plaintiff,
- against Index No.
COUNTRYWIDE HOME LOANS, INC.,
08/60285
COUNTRYWIDE SECURITIES CORP.,
COUNTRYWIDE FINANCIAL CORP.,
Pages 1 - 352
COUNTRYWIDE HOME LOANS SERVICING, LP
and BANK OF AMERICA CORP.,
Defendants.
------------------------------------ x
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VIDEOTAPED DEPOSITION OF ANGELO MOZILO 18
TUESDAY, JUNE 21, 2011, 8:38 A.M.
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REPORTED BY: PHILIP D. NORRIS
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C.S.R. No. 4980
Page 3
Videotaped deposition of Angelo Mozilo, the
witness, taken on behalf of the Plaintiff,
commencing at 8:38 a m., on Tuesday, June 21, 2011,
at 2 Dole Drive, Westlake Village, California,
before Philip D. Norris, C.S.R. No. 4980.
APPEARANCES OF COUNSEL
FOR PLAINTIFF:
QUINN EMANUEL URQUHART & SULLIVAN, LLP
BY: PHILIPPE SELENDY, ESQ.
ALICIA COBB, ESQ.
51 Madison Avenue
22nd Floor
New York, New York 10010
(212) 849-7441
- AND QUINN EMANUEL URQUHART & SULLIVAN, LLP
BY: DANIELLE L. GILLMORE, ESQ.
865 South Figueroa Street
10th Floor
Los Angeles, California 90017
(213) 443-3206
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SUPERIOR COURT OF THE STATE OF CALIFORNIA

FOR THE COUNTY OF LOS ANGELES
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MBIA INSURANCE CORPORATION, )
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a New York corporation,
)
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Plaintiff, ) Case No.
6
vs.
) BC417572
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BANK OF AMERICA CORPORATION, )
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a Delaware corporation, et al., )
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Defendants. )
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)
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VIDEOTAPED DEPOSITION OF ANGELO MOZILO 17
TUESDAY, JUNE 21, 2011, 8:38 A.M.
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REPORTED BY: PHILIP D. NORRIS
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C.S.R. No. 4980
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Page 4
APPEARANCES:
FOR COUNTRYWIDE DEFENDANTS:
GOODWIN PROCTER
BY: SARAH HEATON CONCANNON, ESQ.
Exchange Place
Boston, Massachusetts 02109
(617) 570-1000
FOR ANGELO MOZILO:
IRELL & MANELLA LLP
BY: DAVID SIEGEL, ESQ.
ALLISON L. LIBEU, ESQ.
1800 Avenue of the Stars
Suite 900
Los Angeles, California 90067-4276
(310) 277-1010
FOR DAVID SAMBOL:
ORRICK, HERRINGTON & SUTCLIFFE, LLP
BY: MICHAEL C. TU ESQ.
777 South Figueroa Street
Suite 3200
(213) 612-2433
1 (Pages 1 to 4)
Merrill Corporation - New York
1-800-325-3376
www.merrillcorp.com/law

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APPEARANCES:
FOR ERIC SIERACKI:
DLA PIPER, LLP (US)
BY: NICOLAS MORGAN, ESQ.
1999 Avenue of the Stars
Suite 400
(310) 595-3020
FOR THE UNDERWRITER DEFENDANTS:
GIBSON, DUNN & CRUTCHER LLP
BY: J. CHRISTOPHER JENNINGS, ESQ.
333 South Grand Avenue
(213) 229-7836
FOR THE DEFENDANT STANFORD KURLAND:
CALDWELL, LESLIE & PROCTOR
BY: ERIC S. PETTIT, ESQ.
1000 Wilshire Boulevard
Suite 600
(213) 629-9040
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INDEX
WITNESS
EXAMINATION
ANGELO MOZILO (By Mr. Selendy)
EXHIBITS
NO.
PAGE DESCRIPTION
Exhibit 1395 43 Final Judgment as to Defendant
Angelo Mozilo, three pages
Exhibit 1396 44 Consent o Angelo Mozilo,
three pages
Exhibit 1397 48 Complaint for Violations of
the Federal Securities Laws,
29 pages
Exhibit 1398 92 E-mails, Bates number CWMBIA
001100155, with attachments
Exhibit 1399 106 Event Transcript, 1/27/04,
13 pages
Exhibit 1400 114 E-mail from Dave Sambol,
2/22/04, Bates number CWMBIA
0010047224
Exhibit 1401 134 E-mails, Bates numbers CWMBIA
001597091 to 942
Exhibit 1402 141 E-mail from Angelo Mozilo,
9/1/04, Bates number CWMBIAG0000096887
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APPEARANCES:
1
2
FOR RON KRIPALANI AND JENNIFER SANDEFUR: 3
4
PAUL HASTING JANOFSKY & WALKER
5
BY: JOSHUA HAMILTON, ESQ.
6
515 South Flower Street
7
25th Floor
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9
(213) 683-6186
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FOR BANK OF AMERICA:
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O'MELVENY & MYERS LLP
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BY: MATTHEW W. CLOSE, ESQ.
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400 South Hope Street
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(213) 430-6000
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ALSO APPEARING:
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JEMAL JUDKINS, VIDEOGRAPHER
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MICHELE KENAUSIS
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JONATHAN C. HARRIS, ESQ.
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PAGE
15
Page 8
INDEX
EXHIBITS
NO.
PAGE DESCRIPTION
Exhibit 1403 153 E-mails, Bates number CWMBIA
15776882, with attachment
Exhibit 1404 164 E-mail from Richard Soto,
12/2/04, Bates numbers CWMBIA
0012527229 to 241
9/17/05, Bates number CWMBIAG0000110171
Exhibit 1406 176 E-Mails, Bates numbers CWMBIA
0012263394 to 402
0015971512 to 513
Exhibit 1408 204 E-mail from Jennifer Pitcock,
0009554935 to 946
Exhibit 1409 210 Form 10-K, 190 pages
0012048907 to 909
0011468069 to 070
///
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INDEX
EXHIBITS
NO.
PAGE DESCRIPTION
0009523759 to 761
Exhibit 1413 244 E-mail from Marc Moss, 7/28/06,
Bates numbers CWMBIA 0011524659
to 667
0011006407 to 410
Exhibit 1415 250 "Key Observations and Lessons
Learned From the Crisis," Bates
numbers CWMBIA-G0000092601
to 610
Exhibit 1416 277 Event Transcript, 4/21/04,
25 pages
Exhibit 1417 302 Transcript of the testimony of
Angelo Mozilo before the SEC,
11/9/07, 175 pages
8/20/08, 133 pages
8/21/08, 238 pages
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INDEX
EXHIBITS
NO.
PAGE DESCRIPTION
Exhibit 1425 307 FCIC Staff Interview with
Angelo Mozilo, 2/17/01,
35 pages
Angelo Mozilo in Syncora v
Countrywide Home Loans, et al.,
2/25/11, Bates numbers
CWMBIA-G000109795 to 874
0014070251 to 254
4/21/05, Bates numbers
CWMBIA-G0000110172 to 173
0012568762 to 767
7/27/05, Bates number CWMBIA
0012525795 to 796
0015980647 to 650
///
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INDEX
EXHIBITS
NO.
PAGE DESCRIPTION
10/2/08, 235 pages
10/3/08, 93 pages
Angelo Mozilo in In Re
Countrywide Financial
Corporation Securities
Litigation, 1/26/10, Volume I
Litigation, 1/27/10, Volume II
Litigation, 1/28/10, Volume III
///
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INDEX
EXHIBITS
NO.
PAGE DESCRIPTION
Exhibit 1432 346 E-mail from Aratha Johnson,
Bates numbers CWMBIA0011533794
to 799
(Exhibits 107, 949, 1056, 1140, 1142, 1168,
1172, 1325, 1343, 1344, 1351 and 1356, previously
marked exhibits, are included in this transcript for
reference.)
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Page 15
WESTLAKE VILLAGE, CALIFORNIA; TUESDAY, JUNE 21, 2011 1

8:38 A.M.
2
THE VIDEOGRAPHER: Here begins Volume No.

1, Videotape No. 1, in the deposition of Angelo
Mozilo, in the matter of MBIA versus Countrywide, in
the Supreme Court for the State of New York, in New
York County. The case number is 0860285. And in
the matter of MBIA versus Countrywide, in the Los
Angeles County Superior Court. The case number is
BC 417572.
Today's date is June 21st, 2011. The time
on the video monitor is 8:38. The video operator
today is Jemal Judkins, a notary public contracted
by Merrill Legal Solutions at 20750 Ventura
Boulevard, Suite 205, Woodland Hills, California.
This video deposition is taking place at the Four
Seasons Resort in Westlake Village, California.
Counsel, please voice identify yourselves
and state whom you represent.
MR. SELENDY: Philippe Selendy of Quinn
Emanuel for plaintiff MBIA.
MS. COBB: Alicia Cobb, also with Quinn
Emanuel, for plaintiff MBIA.
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MS. LIBEU: Allison Libeu, Irell & Manella,

for Mr. Mozilo.
MR. SIEGEL: David Siegel with Irell &
Manella for the witness.
THE VIDEOGRAPHER: The court reporter today
is Philip Norris of Merrill Legal Solutions.
Would the reporter please swear in the
witness.
ANGELO MOZILO,
having been first duly sworn, was
examined and testified as follows:
EXAMINATION
MR. SELENDY: Before we start, I'll note
for the record that Manisha Sheth of our side may be
listening to part of the proceeding.
Q. Are you ready, Mr. Mozilo?
A. I am.
Q. You have testified before, have you not?
A. I have.
Q. You know the rules of the proceeding?
A. Yes.
Q. You're obligated to answer every question
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MS. KENAUSIS: Michele Kenausis on behalf

of same.
MR. HARRIS: Jonathan Harris, deputy
general counsel, MBIA.
MS. GILLMORE: Danielle Gillmore, Quinn
Emanuel, for plaintiff MBIA.
MR. HAMILTON: Joshua Hamilton, Paul
Hastings, for Ron Kripalani and Jennifer Sandefur in
the Los Angeles action.
MR. MORGAN: Nic Morgan from DLA Piper for
Eric Sieracki in the Los Angeles action.
MR. TU: Michael Tu of Orrick Herrington &
Sutcliffe for David Sambol in the Los Angeles
action.
MR. PETTIT: Eric Pettit, Caldwell Leslie &
Proctor, for Stanford Kurland in the Los Angeles
action.
MR. CLOSE: Matthew Close, O'Melveny &
Myers, LLP, for Bank of America Corporation.
MR. JENNINGS: Chris Jennings, Gibson, Dunn
& Crutcher, for UBS Securities, Branch Capital
Markets and HSBC Securities in the California
action.
MS. CONCANNON: Sarah Concannon, Goodwin
Procter, on behalf of the Countrywide defendants.
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truthfully and to the best of your ability, unless

your counsel instructs you not to answer.
Do you understand that?
A. I do.
Q. In which proceedings have you previously
given testimony?
A. Many.
Q. Do you recall the names of the proceedings?
A. No, but my attorney can give them to you.
Q. Do you recall the names of any of those
proceedings?
A. No.
Q. Is the testimony that you gave in those
proceedings truthful and correct?
A. Yes.
Q. Is there any reason why you can't testify
today?
A. No.
Q. How did you prepare for today's deposition?
A. I spoke to counsel.
Q. Which counsel did you meet with?
A. David Siegel.
Q. Did you meet with anyone else?
A. No.
Q. Did you speak with David Sambol?
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A. No.
Q. Okay. How long were you CEO of
Countrywide?
A. I co-founded the company in 1968. I became
CEO -- I don't recall the year, frankly.
Q. Was it 1998?
A. If you know the year, then fine. I don't
know.
Q. What was the last year that you were CEO of
Countrywide?
A. 2008.
Q. Okay. So approximately 10 years?
A. If that's what it works out to be. I don't
know the date.
Q. Are you familiar with President Truman's
motto that "the buck stops here"?
A. I've heard of it, yes.
Q. Okay. Did you live by that standard when
you were CEO of Countrywide?
MS. CONCANNON: Objection.
THE WITNESS: I -- I operated the company
to the best of my ability and to make sure that I
maintained the integrity of the company and make
sure that everyone operated in a proper and trustful
and honest manner.
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ultimately responsible for Countrywide?

MR. SIEGEL: Question's argumentative,
vague, and asked and answered.
THE WITNESS: Yeah, I don't -- I just don't
know where you're going. Look, I can answer the
question in the manner in which I answered it. And
it's not a matter of if I'm comfortable or
uncomfortable, I just think it's not a fair
question.
BY MR. SELENDY:
Q. So that's not a term you would use to
describe your responsibility for the company?
A. No. My responsibility was to make certain
that the company operated according to the rules and
regulations that we were required to operate under,
and I did the best I could to make sure that
happened. But more importantly, I hired the best
and the brightest people to help me do that.
Q. Okay. Let me show you a document
previously marked as Exhibit 1351. I'm going to ask
you about the e-mail which is on the second page of
the document.
A. I'll read the whole document, if you don't
mind.
MR. CLOSE: We're short a copy.
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BY MR. SELENDY:
Q. Were you ultimately responsible for the
acts of Countrywide?
MR. SIEGEL: Calls for legal conclusion.
Object to the form of the question.
THE WITNESS: The company was 60,000
people, requires the participation of many
executives to make sure that the company operates
properly every day. There is no way that a CEO can
know intimately what's happening on three continents
with 66,000 employees.
BY MR. SELENDY:
Q. As CEO of Countrywide, were you ultimately
responsible for the acts of the corporation?
MR. SIEGEL: Asked and answered, calls for
a legal conclusion.
THE WITNESS: I would term it this way:
That I -- I managed the company in the best way I
knew -- knew how, and with the documents that I
signed, I believed to be true and correct. When you
talk about "ultimately responsible," it's a very
broad term. And as I said, I managed the company
the best way I knew how to do it.
BY MR. SELENDY:
Q. Are you uncomfortable saying that you were
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MS. CONCANNON: Mr. Selendy, before we went

on the record, we agreed that an objection by one is
an objection by all on all grounds; is that correct?
MR. SELENDY: That's the stipulation, yes.
MS. CONCANNON: Thank you.
THE WITNESS: This is very small type. I
can hardly read this thing.
MR. SELENDY: I will read to you the one
sentence that I want to ask you about.
THE WITNESS: I'm concerned about the
entirety of the e-mail.
MR. SELENDY: You're free to read as much
as you like. This is in the form that it was
produced to us by Countrywide.
THE WITNESS: Ask your question.
BY MR. SELENDY:
Q. On the second page of the document, with
the Bates number ending in 590, there's an e-mail
from you to Carlos Garcia, among others; do you see
that e-mail?
A. Yeah.
MR. SIEGEL: I have a different document.
I've been reading something else.
MS. CONCANNON: Do you have another copy?
MR. SELENDY: This is Exhibit 1351.
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MR. SIEGEL: I'm sorry, now I do. I was

handed the wrong document.
MR. SELENDY: Okay. If you'll refer to the
second page of that document, there's an e-mail from
Mr. Mozilo.
Q. In your e-mail, sir, you state, toward the
bottom of the e-mail, with reference to the issue of
retention of pay-option products, you say:
"More importantly, all of the decisions that
were made relative to the retention instead of
sale of the pay-options were made without my
knowledge and participation in the process, and
I don't appreciate it since I am the one
ultimately responsible for the overall
performance of the company."
Do you see that?
A. Yeah.
Q. And that was a true statement at the time
you made it, sir; correct?
A. Yes.
Q. Okay. And to be responsible for the
performance of the company you had to know and
understand how your company operated; correct?
MR. SIEGEL: Question's vague,
argumentative.
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BY MR. SELENDY:
Q. At this time do you think it's fair to say
that you were ultimately responsible for the overall
performance of the company?
MR. SIEGEL: Question's argumentative.
It's been asked and answered. It calls for a legal
conclusion.
THE WITNESS: Let me -- let me answer it
this way: I had, as I said, many executives at the
company that I relied upon to assure that they were
carrying out the direction that I provided. And I
don't care how you term it. I took responsibility
by signing the 10-Qs, the 10-Ks. That's it.
BY MR. SELENDY:
Q. Did you take steps to ensure that you had
knowledge of and participation in important
decisions on behalf of the company?
MR. SIEGEL: Question's vague.
THE WITNESS: As best I could. As best you
could when you had literally millions of
transactions per year, thousands of transactions per
day, as best as humanly possible. I worked as hard
as any human being could work to make sure that this
company was -- was a profitable and best-of-class
company, and it was.
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THE WITNESS: This is a complex company.

Countrywide had many, many operations. There is no
way that I was intimate with every aspect of the
company, no different than the CEO of Boeing knows
how to build an airplane or the CEO of -- of NBC
knows how to -- or General Electric knows how to
make light bulbs and run a camera. This was a
complex company.
This was written four years ago. I don't
know what context it was written in. And to pluck
one sentence out of it I think is somewhat unfair.
And that's my reaction to it, is that obviously as
CEO you have a legal responsibility and a moral
responsibility to do the best you can every day to
run a company properly.
This company was my sixth child. I was
emotionally attached to this company and financially
attached to this company. I was the single or one
of the largest individual shareholders in
Countrywide and therefore I was intent about
management of the company, did the best I could to
manage it. This is one sentence in thousand of
e-mails that I wrote. That was my feeling at that
moment, at that time.
///
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BY MR. SELENDY:
Q. Did you take steps to ensure that your
senior managers reported important issues and events
to you?
A. As best I can. I relied on them reporting
them to me.
Q. Did they -- did you rely upon a certain
number of senior managers more than others?
A. I did. The higher ranked employees, such
as Stan Kurland and Dave Sambol and Eric Sieracki
and Carlos Garcia, who ran the bank, yes, I relied
more heavily upon them because they were the ones I
was in contact with.
Q. Would you include John McMurray in that
group?
A. Yes.
Q. Would you include anyone else in that
group?
THE WITNESS: Kevin Bartlett, Jennifer
Sandefur, our chief economist. I don't recall his
name at the moment. There were certain people that
I interacted with -- it wasn't on a daily basis -if I was in -- in the office.
///
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BY MR. SELENDY:
Q. Did you know what product types Countrywide
offered for the period here of 2004 through 2008?
MR. SIEGEL: Question's vague, and it's
compound.
THE WITNESS: I mean, the products -product lines were changing continuously. Did I
know the instant that they were being incorporated
into Countrywide's product line? In some cases, I
might have; in some cases, I might not have.
BY MR. SELENDY:
Q. Were there particular instances where you
required of your senior managers that they seek your
approval before Countrywide offered a new product
type?
A. Not all the time. Again, there was a
protocol, an exhaustive protocol, in the development
of products. There was a whole team that did that,
a product development team that had to go through
our lawyers, our accountants, our underwriters. And
in some cases it was perfunctory, and in some cases
where we went into a totally different product they
may have come to me.
Q. Are you able to describe generally the
circumstances under which the introduction of a new
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mind.
Q. Okay. As the former CEO of a company built
on mortgage origination, you had a general
understanding of how your company actually
originated those mortgages; correct?
THE WITNESS: Yes.
BY MR. SELENDY:
Q. Okay. And are you aware that Countrywide
published guidelines as to how it originated loans?
A. Published guidelines as to how we
originated loans? We published guidelines
internally to make sure that our people adhered to
the guidelines.
Q. Okay. Would you agree with me that a
responsible lender adopts prudent underwriting
guidelines and adheres to them?
A. That's correct.
Q. Okay. How closely do prudent underwriters
adhere to guidelines?
MR. SIEGEL: Question's vague, compound.
THE WITNESS: And ridiculous.
I mean, you have guidelines. Those -exactly what they mean. They're not the Ten
Commandments, they're guidelines. And those
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product would have to be approved by you?

MR. SIEGEL: Question's compound. Vague as
to time.
THE WITNESS: I don't -MR. SELENDY: For the same time period,
2004.
THE WITNESS: Look, first of all, it's
years ago. I don't recall exactly how it worked,
but unless it was something very different from what
we had -- it was a total variation from a theme. We
had fixed-rate mortgages. We had variable rate
mortgages of all types. I think we had 89, 90
different products.
Unless it was something fundamentally
different than what we had -- for example,
pay-options, pay-option loans, that was very
different. Although it had been in the marketplace
for 30 years, we had not done that product. No
particular reason, we just never engaged in it. And
when that product was introduced, they -- they came
to me and asked me to approve that product.
BY MR. SELENDY:
Q. Can you think of other examples, as you sit
here today?
A. Not -- that's one that stands out in my
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guidelines vary -- in terms of the underwriter

looking at those guidelines, they'll vary from
those guidelines based upon other compensating
issues in that particular transaction. And so a
down payment, size of down payment, is a factor
that may compensate for other deficiencies in the
loan.
So they are what they are. Look up
"guidelines" in Webster's Dictionary, you'll find
that that's what they are, general guidelines as
what to be followed in terms of us being able to
accept that loan.
BY MR. SELENDY:
Q. Do you feel the same way about the
representations and warranties that Countrywide made
with respect to loans that it included in the
Countrywide RMBS?
MR. SIEGEL: Question's -MS. CONCANNON: Lacks foundation.
MR. SIEGEL: Question's vague and
ambiguous.
THE WITNESS: The reps and warranties are
what they are. They're in writing. You read them.
That's what they are.
///
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BY MR. SELENDY:
Q. Would you agree with me that Countrywide
had to adhere to the representations and warranties
it made with respect to the loans it included in the
Countrywide RMBS?
MR. SIEGEL: Question's argumentative, and
it's vague as to its reference to Countrywide and
various entities.
THE WITNESS: The company had written reps
and warranties and -- and we respected those reps
and warranties.
BY MR. SELENDY:
Q. As the CEO of Countrywide, did you think it
was acceptable for Countrywide to deviate from the
representations and warranties in its RMBS?
MR. SIEGEL: Question's argumentative as
framed, and vague as to entities.
THE WITNESS: I'm not even aware of what
you're talking about.
MR. SELENDY: Okay.
Q. So are you aware that MBIA wrote multiple
billions of dollars of financial guarantee insurance
on RMBS created by Countrywide?
A. I only know that as a result of this
deposition.
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and the other monolines were underwriters and

were -- assessed risk. They had access to all the
information that they wanted, could ask any
questions to assess their risk, and they insured
that product based upon that assessment. That's
what I assumed.
BY MR. SELENDY:
Q. Was MBIA and the other monolines entitled
to accept the representations and warranties made by
Countrywide as truthful?
MR. SIEGEL: Go ahead.
MR. SELENDY: We have it.
MR. SIEGEL: Oh, question's vague and
argumentative.
MR. TU: Also calls for a legal conclusion.
THE WITNESS: I have no -- I have no idea
what you're talking about.
MR. SELENDY: Okay.
Q. Was Countrywide -- was MBIA, as a monoline
writing protection on Countrywide's transactions,
entitled to treat as truthful the representations
and warranties that Countrywide made in connection
with Countrywide RMBS?
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Q. Prior to your preparation for this

deposition, were you unaware of the role that MBIA
played in insuring Countrywide transactions?
A. Absolutely unaware that it was MBIA. I
knew that they were insured. But I never met a
person from MBIA. No one from MBIA came to speak to
me, no one from MBIA came to talk to me about the
company, about our reps and warranties, about our
guidelines, about anything. I never met anyone from
MBIA. And I -- they had full access to me, by the
way.
Q. So you knew that there were monolines that
provided coverage, but you didn't know which
monolines those were?
A. That's correct.
Q. Did you understand that it was important
for MBIA -- let me strike that.
Did you understand that it was important
for the monolines that wrote financial guarantee
coverage on the Countrywide transactions that
Countrywide adhere to its stated representations and
warranties?
MR. SIEGEL: Question's argumentative, and
vague as framed.
THE WITNESS: This is what I assumed: MBIA
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assumes facts not in evidence.

THE WITNESS: Look, I don't know what's in
MBIA's head. We gave reps and warranties. I don't
know how they accepted them. Our reps and
warranties were what they were. They were in
writing. And they, again, they insured that
product, should have insured that product, based
upon an intense review on their part as to the risk.
And they competed -- as I understood it, the
monolines competed heavily for our product.
BY MR. SELENDY:
Q. So let me try this a different way.
As the CEO of Countrywide, did you care to
ensure that the representations and warranties that
your company made were truthful and correct?
A. Yes, I assumed they were truthful and
correct.
Q. Okay. Did you think that any deviation
from reps and warranties would be acceptable?
A. I wasn't aware of any deviations.
THE WITNESS: I'm sorry, I didn't mean to
do that.
BY MR. SELENDY:
Q. Would you agree with me that a deviation
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rate in excess of 25 percent would be unacceptable?

MS. CONCANNON: Objection. Incomplete
hypothetical, calls for speculation, vague and
overbroad.
THE WITNESS: I don't know if I ever heard
of a deviation rate, and I don't know if your number
is -- I don't know. I have no idea what you're
talking about.
MR. SELENDY: Okay. Let me try it again.
Q. If you were presented with facts showing
that Countrywide had, in fact, breached those
representations and warranties at a level exceeding
25 percent of all the loans in its securitizations,
would you agree with me that that would show that
the underwriting by Countrywide for those loans was
not prudent?
MR. SIEGEL: Question -THE WITNESS: No.
MS. CONCANNON: Same objections.
MR. SIEGEL: Let me get on the record the
objections before you answer.
The question is vague, ambiguous,
argumentative, calls for a legal conclusion.
THE WITNESS: I couldn't respond to that
question until I reviewed personally the elements
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BY MR. SELENDY:
Q. What was the purpose of the representations
and warranties, to your understanding?
MR. SIEGEL: Same objections.
THE WITNESS: My understanding was part of
the process, part of the requirements.
BY MR. SELENDY:
Q. Do you know why it was part of the
requirements?
A. You'd have to -- you'd have to ask that of
MBIA.
Q. Okay. You understood it was a precondition
for MBIA to enter into the transaction that there be
such representations and warranties?
MR. SIEGEL: Question calls for
speculation, and it's vague.
THE WITNESS: Again, let me restate. I
had -- I have no -- I had no idea of MBIA's -MBIA's participation with Countrywide. None. So I
don't know anything about MBIA or what their
expectations were.
MR. SELENDY: Okay.
THE WITNESS: I do know that MBIA is
supposed to be -- is a public company responsible to
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behind what you're talking about. I know nothing

about a deviation. I know nothing about 25 percent.
So I can't agree with something that you're coming
out with that I know nothing about.
MR. SELENDY: Okay.
Q. What you can agree with is that Countrywide
had to live by its representations and warranties;
is that fair?
MR. TU: Mischaracterizes the testimony.
THE WITNESS: What I would agree with is
that Countrywide made reps and warranties. They
were in writing. And that's all that I know.
BY MR. SELENDY:
Q. What was the purpose of the representations
and warranties?
MR. SIEGEL: Question's -MR. SELENDY: To your understanding.
MR. SIEGEL: Question's vague. It's hard
to even know what representations you're talking
about.
MS. CONCANNON: Also calls for a legal
conclusion.
THE WITNESS: Wait a minute.
What was what?
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shareholders to make sure they underwrite loans

properly, that they underwrite the risk properly,
that they do the proper due diligence on the product
that they're insuring. And they had access to all
the details, every single detail on every loan, and
could make their own assessment; that was the
expertise -- that was their expertise, not ours.
BY MR. SELENDY:
Q. Do you understand that MBIA, as one of the
monolines wrapping Countrywide's products, relied
upon the truthfulness of Countrywide's
representations and warranties in its own
underwriting of those deals?
MR. SIEGEL: Calls for speculation.
THE WITNESS: I don't know what the rules
of MBIA were. I don't know what they relied upon.
I'm not a monoline underwriter.
BY MR. SELENDY:
Q. Okay. Did you ever take any steps to
figure out what was of interest to the monolines in
writing billions of dollars of protection for
Countrywide's products?
THE WITNESS: I had really -- not my role
to worry about the interests of MBIA. I had enough
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problems worrying about the interests of

Countrywide.
BY MR. SELENDY:
Q. Who at Countrywide was responsible for
dealing with the monolines?
A. There was a team of people. I would
assume, I can only assume, these -- Carlos Garcia,
Stan Kurland, Dave Sambol, Eric Sieracki, Jennifer
Sandefur, Kevin Bartlett, John -Who's the chief underwriter?
MR. SIEGEL: McMurray.
THE WITNESS: -- McMurray. John McMurray.
I assume it's that team.
BY MR. SELENDY:
Q. What were -- you just referred to John
McMurray as the chief underwriter. What were
Mr. McMurray's responsibilities for the period of
2004 through 2008?
MR. SIEGEL: Don't speculate.
THE WITNESS: I can't talk about the
period. I don't know how long he worked for us.
But his responsibility was to make sure that the
loans that we were underwriting were within our
guidelines, and helped establish our guidelines and
helped -- and assessed risk.
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Q. I'm asking you, sir: Did you ever have any

reason to doubt the reports given to you by
Mr. McMurray as being thoughtful and comprehensive
and based on fact?
THE WITNESS: I don't recall. I don't
recall ever feeling that way.
MR. SELENDY: Okay.
Q. Let me ask you a question I asked Dave
Sambol.
Do you have any regrets about the way you
ran Countrywide?
MR. SIEGEL: Question's irrelevant and not
reasonably likely to lead to the discovery of
relevant information.
MR. SELENDY: Let me be more specific.
Q. After all the foreclosures and ruined lives
and lawsuits, including the losses to MBIA, do you
have any regrets about the way you ran Countrywide?
A. No.
MR. SIEGEL: Now the question is -MS. CONCANNON: Objection.
MR. SIEGEL: -- argumentative, compound.
THE WITNESS: Let me -- let me just go
further with this.
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BY MR. SELENDY:
Q. Do you understand how he exercised that
responsibility?
A. No.
Q. Okay. Did he report to you from time to
time as to his conclusions with respect to whether
Countrywide's underwriting was within its
guidelines?
A. Yeah, I had several meetings with John
about, you know, a variety of issues. I don't
recall the issues. Many years have gone by now.
But I had a good relationship with him, and I
considered him a first-class individual.
Q. You would include him as the group within
the best-in-class group of employees that you
referred to earlier?
A. I would.
Q. Was there any occasion on which you had a
report from Mr. McMurray that you thought was not
based strictly on fact?
MS. CONCANNON: Objection. Vague and
overbroad.
THE WITNESS: I have no idea what that
question is about.
MR. SELENDY: Okay.
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This is a matter of record. The cause of

the problems of foreclosures is not created by
Countrywide, nor MBIA. This is all about an
unprecedented, cataclysmic situation, unprecedented
in te history of this country. Values in this
country dropped 50 percent. When MBIA -- if MBIA
knew that, if I knew that at the time these loans
originated, I would not have been in the business.
You've had thousands of banks go bankrupt
and been seized. You've had AAA companies like AIG
go bankrupt, 150-year-old companies go bankrupt,
federal government agencies, Fannie Mae and Freddie
Mac, go bankrupt.
This is not caused by any act of
Countrywide or by any act of MBIA. It was caused by
an event that was unforeseen by anyone, because if
anybody foresaw it, you would. Never have insured
it, we would never have originated the loan. And it
spread across the world.
So that's the issue. All these lawsuits
is -- was created by nothing that anyone did, any
one company did. Any judgment made on a
foreclosure -- on a loan being made is because
values deteriorated. And for the first time in the
history of this country people decided that they
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were going to leave their homes because the value of

their home was below the mortgage amount. Never in
the history of this country did that ever happen,
and that could never have been assessed in the risk
profile.
These people didn't lose their jobs. They
didn't lose their health. They didn't lose their
marriage. Those are the three factors that cause
foreclosure. They left their home because the
values went below the mortgage. That's what caused
the problem.
So I have no regrets about how I -- how
Countrywide was run. It was a world-class company.
We had 40 years of incredible success, rated No. 1.
The highest rated company in the country, mortgage
company, by S&P and Moody's and Fitch. Rated No. 1
by Fannie and Freddie and FHA in our servicing. We
were a world-class company in every respect.
So your tirade about foreclosures and
lawsuits is nonsensical and insulting. Countrywide
did not cause this problem. We made no loans in
Greece. We made no loans in Ireland. We made no
loans in Portugal. This is a worldwide financial
crisis that was totally a shock to the system.
///
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statement of the ground for the objection.

MR. SIEGEL: Argumentative, misstates the
record.
THE WITNESS: First of all, I didn't pay
$67 million, but I paid a lot of money. I paid 22
1/2 million dollars to the SEC, and the reason for
it had nothing to do with anything that I did at
Countrywide or anything I did in my personal life.
I have nine grandchildren and five children. They
were being harassed. They were being harassed in
school. My name was in the paper every day
nationally and internationally, accusing me of
things that were absolutely untrue. But I -- I
could not have my family go through it anymore. And
that's why I settled.
MR. SELENDY: Have the reporter mark as
Exhibit 1395 the Final Judgment As to Defendant
Angelo Mozilo, entered in the United States District
Court for the Central District of California,
Western Division.
(The document referred to was marked by the
reporter as Exhibit 1395 for identification and is
attached hereto.)
BY MR. SELENDY:
Q. Is this the Final Judgment that was entered
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BY MR. SELENDY:
Q. In fact, sir, long before the end of the
housing bubble Countrywide expected that its
borrowers would default in massive numbers; isn't
that correct?
A. Incorrect.
Q. Your testimony is that's incorrect?
A. That's incorrect. Incorrect.
Q. Do you understand why the SEC, the Federal
Securities and Exchange Commission, required you to
pay $67.5 million to settle claims that you violated
personally the Federal Securities Acts?
MR. SIEGEL: Well, first, misstates the
facts, deliberately so, perhaps. Misstates the -MR. SELENDY: No speaking objections.
MR. SIEGEL: Well, in our jurisdiction I'm
supposed to give you an opportunity to fix
objectionable questions. If you waive that, I'll
just say object as to form and argumentative.
Object as to form and argumentative.
Do you waive that opportunity to -- that I
point out -MR. SELENDY: I would like to -MR. SIEGEL: What's your preference?
MR. SELENDY: You can give a one-word
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against you?
MR. SIEGEL: I'm going to object. Document
is not reasonably calculated to lead to the
discovery of material or relevant information.
THE WITNESS: I've never seen it before.
BY MR. SELENDY:
Q. You've never seen it?
A. No.
MR. SELENDY: Let's have the reporter mark
as Exhibit 1396 the Consent of Angelo Mozilo in the
same proceeding.
attached hereto.)
BY MR. SELENDY:
Q. I take it you've seen this document before,
sir.
MR. SIEGEL: Take your time.
I'll object that the document -- questions
relating to a settlement that doesn't -- that on its
face says it's inadmissible for any purposes is
irrelevant and immaterial line of questioning,
argumentative.
THE WITNESS: Yeah.
///
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BY MR. SELENDY:
Q. You've seen this document before; correct?
A. Yes.
Q. This is the consent to the entry of the
Final Judgment which I had marked as Exhibit 1395;
correct?
MR. SIEGEL: Same objections. Irrelevant,
not reasonably calculated to lead to the discovery
of -THE WITNESS: Mine shows 1396.
BY MR. SELENDY:
Q. This consent marked as Exhibit 1396 is a
consent to the entry of the Final Judgment, which is
marked 1395; correct?
MR. SIEGEL: Same objections.
THE WITNESS: It is what it is.
MR. SELENDY: Okay.
Q. In the second paragraph, it states:
"Mozilo herby consents as part of a knowing
and voluntarily settlement of this action to
the entry of the Final Judgment in the form
attached hereto (the Final Judgment)."
And you signed this consent; correct?
A. Correct.
Q. And the Final Judgment was attached to the
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lead to the discovery of relevant testimony, and

takes the statement deliberately out of context.
THE WITNESS: If you look at 2-C, that's
what I paid, twenty-two five.
BY MR. SELENDY:
Q. You paid the civil penalty of $22.5
million?
A. That's correct.
Q. Did Bank of America pay the $45 million
disgorgement that is referenced in this proceeding?
MR. CLOSE: Objection. Vague and
ambiguous, lacks foundation, calls for speculation.
MR. SIEGEL: Misstates the document. It's
argumentative and irrelevant. Misstates the
document.
THE WITNESS: I don't know who paid it.
MR. SELENDY: You don't know who paid it.
Okay.
Q. Paragraph 4 you state that you knowingly
and voluntarily agree, quote, that you, quote:
"Shall not serve as an officer or director
of any issuer that has a class of securities
registered pursuant to Section 12 of the
Exchange Act."
Do you see that?
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Consent at the time you signed it; correct?

THE WITNESS: I assume it was.
MR. SELENDY: Okay.
Q. You had stated you hadn't seen it before,
so I wanted to ask you: Does this refresh your
recollection that you have seen the Final Judgment?
A. Yeah, let me say this to you: I relied
upon my counsel to direct me in this area in terms
of -- I took the advice of counsel, understood what
they were informing me of, my responsibilities under
this agreement, And that was good enough for me.
Q. Okay. You see in paragraph 2-B that it
states that, under the Final Judgment, under point
B, that:
"Requires payment of disgorgement in the
amount of 44,706,304, plus prejudgment interest
thereon in the amount of 293,696, for a total
of $45,000,000."
Do you see that?
A. Yes.
Q. And that was a payment of disgorgement that
was charged to you; correct?
MR. SIEGEL: Question is argumentative,
vague and irrelevant, not reasonably calculated to
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A. I do.
Q. You agreed that you would not again serve
as an officer or director of any public company;
correct?
MR. SIEGEL: Question's irrelevant,
argumentative and truly harassing. Also, relevance
of admissibility.
BY MR. SELENDY:
Q. Today you are not the officer or director
of any public company; correct?
A. That's correct.
MR. SELENDY: Let's mark as Exhibit 1397
the complaint filed by the SEC against Angelo
Mozilo, David Sambol and Eric Sieracki.
attached hereto.)
BY MR. SELENDY:
Q. Going to ask you questions about particular
allegations in this complaint. You're free to
review as much of it as you feel is necessary. My
first question will be on paragraph 4 of the
complaint.
A. I'm not going to read the whole complaint
because it takes me seven hours to do that.
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Q. I'm going to give you specific statements

and just ask you whether those statements are
truthful or not, or accurate or not.
A. Is this in the summary?
Q. In paragraph 4 of the summary, yes.
The SEC alleges, quote:
"From 2005 through 2007 Mozilo, along with
David Sambol, chief operating officer and
president, and Eric Sieracki, chief financial
officer, held Countrywide out as primarily a
maker of prime quality mortgages loans,
qualitatively different from competitors who
engaged primarily in riskier lending."
Is that statement accurate?
MR. SIEGEL: Calls for speculation,
irrelevant.
THE WITNESS: Statement is, in essence,
correct. We were a prime mortgage lender. Ninety
percent of our loans were prime, 10 percent was
category of subprime.
BY MR. SELENDY:
Q. Okay. Turning to the next page, at the top
it states:
"Countrywide" -This is line 1.
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company in any one industry you had to have about a

25 to 30 percent market share. We all agreed that
we would make that public, that would be our goal,
but that under no circumstances did we -- would we
try to achieve that goal if we had to -- to move
away from our standards, take greater risk. We
wouldn't do that.
And the bottom line of that is we never got
more than 2 percent higher than we were, I think 15
to 17 percent, because to do so we'd have to compete
against the subprime lenders, monolines, and we were
not willing to violate our standards, and therefore
never did it.
BY MR. SELENDY:
Q. Why was it so important for you, for
Countrywide, to have a dominant position in the
mortgage lending space?
Mischaracterizes prior testimony.
THE WITNESS: Because you can either, as a
company, take the position that you're going to be
second, third or fourth place, or you're going to
try to be in first place. Our goal all along since
the founding in 1968 was to be a leader in the
industry. That's what drove us. That's what
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-- "Countrywide, in an effort to increase

market share, engaged in an unprecedented
expansion of its underwriting guidelines from
2005 and into 2007."
Is that correct?
MR. SIEGEL: Objection.
THE WITNESS: Absolutely incorrect.
MR. SIEGEL: Excuse me.
THE WITNESS: I'm sorry.
compound, irrelevant.
BY MR. SELENDY:
Q. Is it correct that Countrywide was seeking
aggressively to increase market share during that
time period?
THE WITNESS: We had engaged a professor
out of the Anderson School of UCLA to determine how
Countrywide can maintain its dominant position in
the mortgage industry and, if possible, increase
that position. We spent a year with Eric Flamholz
out of the Anderson School, wrote many books on the
subject as to if it was possible, and if so, how.
The conclusion after this year-long process
of all the management team was that to be a dominant
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motivated us. And it was an important part of our

culture to be a leader.
BY MR. SELENDY:
Q. Did Countrywide, in fact, expand its
underwriting guidelines from 2005 and into 2007?
MR. SIEGEL: Question's compound and vague.
THE WITNESS: I would view it this way:
That there were many product changes put forth by -by -- including Fannie Mae, Freddie Mac and the
private market, conventional private market, many
product changes, and we, in some cases, adopted
those products, in other cases didn't. But you can
term that expansion of underwriting guidelines or
change in products. There was substantial increase
in the product line in that period.
BY MR. SELENDY:
Q. And would you agree also that, as stated in
the complaint, at line 3, "Countrywide developed
what was referred to as a," quote, "'supermarket'
strategy where it attempted to offer any product
that was offered by any competitor"?
MR. SIEGEL: Question's compound,
irrelevant.
THE WITNESS: We -- we used that term
"supermarket strategy." I don't know what years
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that -- what year that developed, whether it was

2006, 2007, but it was the latter part of
Countrywide's life. But we felt that there was -unless there was compelling circumstances as a
mortgage lender, that we should be able to compete
with the banks and our, rather, mortgage banking
competitors. And if a borrower wanted a certain
loan, we should have the product for them, unless
there's compelling reasons not to have that product.
So we didn't have 125 percent loan. We didn't have
400 FICO loans. It was not our product line.
But we wanted to be able to offer our
customers, if they came to us, the product that they
wanted and could get any place else. There was no
product, by the way, that Countrywide ever invented.
We never created a new product. Every product that
Countrywide had was already in the marketplace.
BY MR. SELENDY:
Q. So during the period from 2005 through
2007, is it fair to say that Countrywide generally
attempted to match the products offered by its
competitors?
MR. SIEGEL: Question misstates the prior
testimony.
THE WITNESS: My understanding was that we
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Q. Isn't that another way of describing the

supermarket strategy?
THE WITNESS: Those are your words. I
don't know if it's the same thing.
BY MR. SELENDY:
Q. What's your understanding of the meaning of
the term within Countrywide?
A. I told you.
THE WITNESS: I'm not sure what it meant in
Countrywide.
BY MR. SELENDY:
Q. You said you'd heard the term. What was
the context in which you heard the term?
A. I think it was in this context.
Q. Okay. On line 5 the complaint states:
"By the end of 2006, Countrywide's
underwriting guidelines were as wide as they
had ever been and Countrywide was writing
riskier and riskier loans."
Is that correct, in your view?
MR. SIEGEL: Question's compound and
irrelevant.
THE WITNESS: Absolutely incorrect. These
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constantly surveyed the market and also determined

what the customer was looking for in terms of
product line and tried to accommodate the customer
where we could. Many cases we couldn't.
BY MR. SELENDY:
Q. Is that a "yes"? I'm not sure that I have
an answer to the question.
MR. SIEGEL: There's no question pending.
THE WITNESS: That's my answer.
MR. SELENDY: Okay. Well, let me try it
again.
Q. Is it fair to say that Countrywide
generally attempted to match the products offered by
its competitors during this time period?
MR. SIEGEL: Asked and answered.
overbroad.
THE WITNESS: My answer to that is no.
There are many products we did not do.
BY MR. SELENDY:
Q. So are you -- are you familiar with the use
of the term "matching strategy" within Countrywide
for this period 2005, '6, '7?
A. I'm not completely familiar with the term.
I've heard the term, but I'm not sure what it meant.
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are the SEC statements. These are not mine.

BY MR. SELENDY:
Q. And what's your basis for saying that this
statement is incorrect, sir?
A. Because it's not correct.
Q. Uh-huh. Is it your statement -- is it your
testimony that Countrywide was not aggressively
expanding into riskier loans during this time
period?
A. That's correct. And the evidence of that
would be we had -- we enjoyed the lowest
delinquency -- one of the lowest delinquency ratios
in the country, one of the lowest foreclosure rates
in the country, maintained the highest rating from
S&P in terms of our servicing, and -- and investors
and insurers and monoline insurers wanted to do
business with Countrywide because of the performance
of our loans.
Q. When you say that Countrywide enjoyed the
lowest delinquency and -A. One of the lowest.
Q. -- one of the lowest delinquency rates,
you're referring to the period during the housing
bubble itself before it came to an end; right?
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THE WITNESS: No, I'm talking about a
period of 40 years.
BY MR. SELENDY:
Q. Okay. Well, I'm asking you specifically
about the period from 2005 through 2007, and my
question again is: Isn't it -- isn't it right that
Countrywide was aggressively expanding into riskier
loans during this time period, by contrast, if you
like, to the preceding history of conservative
underwriting?
argumentative.
THE WITNESS: No. Countrywide -- we had
our standards. We never made a loan knowingly -and it would be stupid to do so -- that we knew the
borrower could not pay. Never. And I'm sure that
MBIA never insured product where they knew the
borrower could not pay. All our loans had that one
standard from 1968 to the end of my rein at
Countrywide. We would not make a loan where we were
not confident that they could repay the loan.
BY MR. SELENDY:
Q. Is it your testimony that the pay-option
products and HELOCs and closed-end seconds that
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very high quality loans which, again, were reflected

in the delinquency rates and the foreclosure rates.
BY MR. SELENDY:
Q. To be clear, your testimony is that the
pay-options and HELOCs and closed-end seconds that
Countrywide wrote were no riskier than the loans of
its prior period?
MR. SIEGEL: Misstates the testimony,
argumentative and compound.
BY MR. SELENDY:
Q. What is the answer? Is that your testimony
or not, sir?
A. My testimony is that those loans that we
made were no lesser in quality than we had
originated in the past.
Q. When you say "lesser in quality," do you
mean something other than lesser in risk?
THE WITNESS: Yes. The, again, the
standards that we applied throughout our history
were, one, that the borrower had to have the ability
to pay, and the loan had to be able to be sold in
the secondary market or the loan had to be eligible
to be purchased by our bank. And they had to meet
all the regulatory standards. The loans that we
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Countrywide was originating in the time period 2005

'6 and '7 were no riskier than the loans it had
written as prime, conforming loans in the preceding
40 years?
THE WITNESS: I would -- let me -- let me
put it this -- put this in perspective for you,
since you're not in the business, know nothing of
the business, were never a CEO. The loans we made
for most of our career, most of our history, were
FHA loans with 3 percent down to blue collar
workers. And the loans we made, other loans we
made, went to veterans with zero down, not a penny
down, not a penny of closing costs. Those are the
loans we made for much of our history.
In today's market that would be called
subprime. So these loans that we made later on, and
the pay-option loans with FICO scores of 700 and
above, which was -- which is considered in the
industry to be the benchmark for quality, and so our
pay-option loans, our average pay-option product, as
I recall, was over 700 FICO scores, and our average
loan to value was around 75 percent before the
collapse.
So, no, I think we continued to originate
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originated met the regulatory standards.

The subprime product was a -- originated
out of a subsidiary of Countrywide, but, again,
salable in the secondary market. And it must be
remembered that in every case, every loan originated
we retained a contingent liability, so we had every
incentive to make sure we were making loans that had
a risk profile that was acceptable to us.
BY MR. SELENDY:
Q. Would you agree with me that it would be
reckless for an underwriter to write loans to a
borrower that was not expected to repay?
A. Yes.
BY MR. SELENDY:
Q. In line 16 of the complaint, on -- in
paragraph 5, it states:
"Mozilo and the company's chief risk
officer" -That's McMurray; right?
A. Yes.
Q. "Mozilo and the company's chief risk
officer warned Sambol and Sieracki about the
increased risk that Countrywide was assuming."
Did you, in fact, warn Sambol and Sieracki
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about increased risk during this period 2005 through

2007?
MR. SIEGEL: Don't speculate about what's
meant here.
Question's vague, argumentative,
irrelevant.
THE WITNESS: My -- my primary
responsibility as CEO is to worry about everything
that we do. This is not -- this warning or
discussion or e-mails to my people about risk has
nothing to do with 2005 - 2007. I started writing
these memos before e-mails in 1968. It's a constant
concern. If you are a concerned and responsible
CEO, you're concerned about risk, and you're always
relating to your people to be concerned, to be
careful about risk.
This is an interpretation of the SEC. This
is not how it happened. It was a continuum of
discussions to all the people in the company, before
there was a Dave Sambol in Countrywide, before there
was a Stan Kurland, before there was an Eric
Sieracki, before there was any of these people,
about risk, because we have financial risk and
reputational risk.
So it's -- I wouldn't confine it to 2005 -
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So I'm not going to comment that this is

their interpretation of it. I'm telling you I did
this continuously.
BY MR. SELENDY:
Q. Okay. What I'm asking you is without
regard to the complaint right now. Isn't it the
case that your concerns about risk increased during
the period from 2005 to 2007 with regard to the
quality of the loans that Countrywide was
originating?
A. No.
Q. If you turn to page 4, the second to last
bullet from the bottom of the page states:
"Countrywide's definition of prime loans
included loans made to borrowers with FICO
scores well below any industry standard
definition of prime credit quality."
Do you see that?
A. Yeah, I do.
Q. How did Countrywide define prime loans in
the period for the last -- for the last five years
that you were the CEO of the company?
A. Prime loans to me were defined by FICO
scores.
Q. And what differentiated a prime from a
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subprime loan?
A. Well, that was really defined by the
regulators. It was 660 or above.
Q. So below 660 would be subprime?
A. Well, not by my standards, but that was the
regulatory standards.
Q. Well, what were your standards?
A. It's not that simple. A loan could be 640,
but the borrower has 50 percent down, so even though
his credit is not up to standard, he's got a
substantial amount of equity. That's a compensating
issue. So that's just a -- it's a guide. But
they -- they -- so I don't -First of all, our average was over 700. So
again, I don't know where this -- this comes from,
from the SEC. Were there loans that were 640 and
630? But I would not qualify them as subprime
necessarily because I'd have to look at the entire
loan itself. There may have been an individual
circumstance that the individual went through; had
great credit up until a divorce, great credit up
until they got sick, and now they're back -- their
life is coming back together again. That would be a
prime loan for me.
Q. If you'll turn to page 9, paragraph 21 of
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2007.
BY MR. SELENDY:
Q. Without regard to the SEC's complaint, is
it correct that you, in fact, gave warnings to
Sambol and Sieracki in the period from 2005 through
2007 about the increased risk that Countrywide was
assuming?
A. I can't comment on that because I don't
know what the SEC has in mind.
Q. Without regard to the SEC complaint, is it
correct that you gave warnings to Sambol and
Sieracki about increased risk that Countrywide was
assuming during the period from 2005 to 2007?
MR. TU: Objection. Vague and ambiguous.
THE WITNESS: I don't know if I -- specific
as to this. I'm telling you that I continuously
warned my people to be concerned about risk and was
involved in making sure I communicated that concern
to everyone in the company. And my e-mails, my
memos, you can see by examination, cascaded down
throughout the company to the lawyers in the
company, to the underwriters in the company. I was
always concerned about risk. It was my primary
concern because we were the lender, and we had a
contingent liability in every loan we made.
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the complaint states:

"While guidance issued by the banking
regulators referenced a credit score (FICO
score)" -MR. SIEGEL: Where are you?
MR. SELENDY: At the bottom of page 9.
Q. It states:
"While guidance issued by the banking
regulators referenced a credit score (FICO
score) at 660 or below as being an indicator of
a subprime loan, some within the banking
industry drew the distinction at a score of 620
or below. Countrywide, however, did not
consider any FICO score to be too low to be
characterized within prime."
Is that a fair statement?
A. No. It's a ridiculous statement.
Q. In what way is that statement inconsistent
with your prior testimony on what counts as
subprime?
THE WITNESS: To say that Countrywide
didn't consider any FICO score to be too low to be
categorized as prime.
///
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BY MR. SELENDY:
Q. Did you track it every month?
A. No.
Q. Did you track it every quarter?
A. I believe that I wouldn't track it at all
unless people came to me and told me what our market
share was.
Q. Nonetheless, it was a stated goal of yours
as of the end of 2003 to reach a 30 percent market
share by 2008; correct?
THE WITNESS: That's correct.
BY MR. SELENDY:
Q. If you would turn to page 11.
A. I said before that was our goal, but I said
publicly we would not seek that goal if it meant
that we had to violate or mitigate our standards.
And as you can see, as far as we got was 15.7
percent. Got halfway there.
Q. If you would turn to page 11, paragraph 25,
the SEC states that, quote:
"Countrywide's matching strategy, also known
as the supermarket strategy, was a key driver
of the company's aggressive expansion of
underwriting guidelines."
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BY MR. SELENDY:
Q. Okay. At what point would a FICO score be
too low to be characterized as prime?
THE WITNESS: 400.
BY MR. SELENDY:
Q. If you'll turn to page 23 -- sorry, page
10, in paragraph 23 the document states, in the
second sentence:
"As of December 31, 2003, based on its own
internal estimates, Countrywide had an 11.4
share of the United States mortgage market. By
September 30th, 2006 it had a 15.7 percent
share of the market."
Do those numbers appear accurate to you?
A. I have no idea.
Q. Did you track the market share regularly
while you were CEO?
THE WITNESS: No. I don't know what you
mean by "regularly." Every day? Every week? Every
month? Every year? You know, what do you mean by
"regularly"?
///
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Do you agree with that statement?

MR. SIEGEL: Question's irrelevant, not
reasonably calculated to lead to the discovery of
relevant testimony, calls for speculation, and it's
vague.
THE WITNESS: I'm not going to comment on
the way that SEC interpreted, took their position.
BY MR. SELENDY:
Q. Well, let me ask you, sir, and I would like
an answer to this: Is it correct that Countrywide's
matching strategy was a key driver of the company's
aggressive expansion of underwriting guidelines for
the period 2005 to 2007?
THE WITNESS: I don't believe so.
BY MR. SELENDY:
Q. Why is that?
A. Because I don't believe it's true. I don't
believe it's the case. We had standards. That was
our standard. There was no strategy that was going
to cause us to violate our standards.
Q. Your standards included seeking to offer
any legitimate loan offered by a competitor; isn't
that right?
MR. SIEGEL: Misstates the testimony.
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THE WITNESS: Now it misstates the

testimony. It's obvious you don't understand the
issue. Standards are -BY MR. SELENDY:
Q. So Dave Sambol -A. -- underwriting standards -- underwriting
standards, I told you what they were, that we would
not make a loan to anyone that we believed could not
repay the loan. We would not make a loan that would
not be able to be sold in the secondary market or
bought, purchased by our bank. That's our standard.
Period, end. That is the standard.
Q. Your strategy included seeking to offer any
legitimate loan offered by a competitor; isn't that
right?
MS. CONCANNON: Objection. Asked and
answered, argumentative.
THE WITNESS: The strategy was to be
competitive.
MR. SELENDY: I'd like an answer to my
question.
THE WITNESS: That's -- that's my answer to
your question.
BY MR. SELENDY:
Q. Is it correct that your strategy included
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Countrywide was seeking to expand market share by

offering any legitimate loan offered by a competitor
during this time period, 2005, '6 and '7?
MR. TU: Vague and ambiguous.
THE WITNESS: Our objective was to make
loans that fit within our guidelines, that met
our -- our core standard, where we believed the
borrower had the ability and the willingness to pay,
that the loan was salable in the secondary market,
or met the guidelines of our bank.
BY MR. SELENDY:
Q. Is it fair to say that your objective was
also during this period to expand your guidelines to
include products offered by legitimate competitors?
A. First of all, I don't know what you mean by
"legitimate competitor." A subprime lender could
have been a legitimate competitor, but we would not
try to compete with them.
Our -- our -- the culture of Countrywide,
the goals of Countrywide, the objectives of
Countrywide never changed from its founding to its
ending.
Q. You didn't have the supermarket strategy at
all points in Countrywide's existence, did you, sir?
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seeking to offer any legitimate loan offered by a

competitor?
THE WITNESS: I don't believe so because
there could be legitimate loans that Countrywide
would not make.
BY MR. SELENDY:
Q. Under what circumstances?
A. $10 million loan.
MS. CONCANNON: Objection. Vague,
overbroad.
THE WITNESS: It could be legitimate. We
would not make it.
BY MR. SELENDY:
Q. Okay. With rare exceptions, would you
agree with me that it's a correct statement?
MR. SIEGEL: Question's argumentative and
vague.
BY MR. SELENDY:
Q. Isn't that a fair description of what you
were trying to do, sir, during this time period?
MR. SIEGEL: Which question do you want him
to answer?
BY MR. SELENDY:
Q. Isn't it a fair description that
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A. We didn't have the ability to -- to

originate loans of all types or most types for many
of the years of our existence. When we had the
financial strength to compete against the larger
players, who had the financial strength to compete
against us, we were able to expand the product line.
Q. You adopted the supermarket strategy at
about the time you adopted a 30 percent market share
goal; correct?
MS. CONCANNON: Objection. Assumes facts
not in evidence.
THE WITNESS: I don't know the answer to
that question.
BY MR. SELENDY:
Q. Is that because you just don't recall?
THE WITNESS: I don't recall.
MR. SELENDY: Okay.
Q. In paragraph 26, on the same page, it
states:
"The impact of the matching strategy was
intensified by Countrywide's 'no brokering'
policy which precluded Countrywide's loan
officers from referring loan applicants to
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other brokers and/or institutions."

Do you see that?
A. Yeah.
Q. What was Countrywide's no brokering policy?
A. No objections?
Countrywide never, ever in its entire
history permitted our salespeople to broker loans
that they obtained under the Countrywide umbrella to
broker to a competitor. That's what it means.
Q. So did that create incentives for
Countrywide's sales personnel to originate loans
in-house?
A. You'll have to rephrase the question.
Q. Did the no brokering strategy -- excuse me.
Did the no brokering policy create
incentives for Countrywide's sale personnel to
originate loans in-house?
MR. HAMILTON: Calls for speculation.
THE WITNESS: These were employees of
Countrywide. Every loan they originated was for
Countrywide. So I don't know what you mean by
"in-house" or -MR. SELENDY: Okay.
Q. Did the fact that a Countrywide broker was
not allowed to refer loans to other lenders create
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MR. SIEGEL: Objection. The question's

vague.
BY MR. SELENDY:
Q. You made reference earlier to compensating
factors justifying a departure from guidelines. How
would you define "compensating factors," sir?
A. Down payment, a unusual situation in
someone's life that was not part of their pattern
throughout their life. I'll give you specific
examples.
Minorities may have -- a minority may have
a lower FICO score because they've had substantial
job changes, but yet have always been in the same
profession, be it painting or plumbing or whatever
it might be, for many years. The underwriting
standards may have been that -- that they had to be
on the job for two years or three years, the same
employer. That situation doesn't exist for many
people in our society. And so that factor would
have to be looked at as a compensating factor.
As I said before, the situation may have
happened in someone's life. As I said before,
additional down payment, a co-signer, various issues
like that.
Q. Okay. If we were to generalize from the
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incentives for that broker to ensure the loan would

be originated by Countrywide itself?
THE WITNESS: And ridiculous.
I don't even understand the question. Let
me explain the structure to you.
These were not brokers, these are employees
that went out in the field, called on customers to
obtain the loans if -For example, real estate brokers. They'd
call on real estate agents. If they sold a house,
please come to Countrywide for the loan. So that
was their job. It wasn't an incentive. It was
their job to originate loans, to bring sales
contracts into the office so they could be processed
and ultimately become a loan.
BY MR. SELENDY:
Q. Is it your testimony that the no brokering
policy was the same throughout Countrywide's
existence?
A. Absolutely.
Q. So your testimony is that Countrywide did
not adopt a specific no brokering strategy in the
period from 2004 to 2007?
A. No. That's why this document is flawed.
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examples you gave, is it fair to say that the

compensating factor had to concern a variable that
wasn't already assessed as part of guidelines?
overbroad.
BY MR. SELENDY:
Q. Is that clear?
A. It's -- no, I have no idea what you're
saying.
Q. Okay. So in the ordinary process of
underwriting the loan, you're going to look at FICO
score, LTV, owner -- owner occupancy, among other
things; correct?
A. Among other things.
BY MR. SELENDY:
Q. And so a compensating factor has to concern
something other than one of the values already
assessed as part of the underwriting process;
correct?
overbroad, lacks foundation.
THE REPORTER: I didn't hear an answer.
MR. SIEGEL: He said, "Incorrect."
///
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BY MR. SELENDY:
Q. Can you explain your testimony, sir, as to
how you can have as a compensating factor a value
which was already assessed as part of the attempt to
determine whether there was conformity with
guidelines?
THE WITNESS: It's an -- I can't believe
the -- look, I think I've been pretty clear. First
of all, compensating factors are considered as part
of the underwriting process. It's not after the
underwriting process; it's part of the process.
MR. SELENDY: I'm distinguishing guidelines
from compensating factors, if there is a
distinction. Perhaps there isn't for you.
THE WITNESS: Yeah. There is none for me
because -- because the guidelines -- you know, I
don't recall exactly what the guidelines say, but I
feel relatively confident that somewhere along the
line in -- the guidelines said there is -- there
are -- there could be compensating factors that
could cause you to approve this loan. Certainly, if
it was not in writing, it was understood.
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THE WITNESS: I have no idea what -First of all, let me say this: You're
working from a document not produced by Countrywide.
MR. SELENDY: That's correct, sir, it's a
complaint against you personally.
THE WITNESS: That's correct. And
doesn't -- and does not, in my opinion, reflect the
facts. Okay? And I don't know if they're correct
because one of these things says that -- that the
Countrywide underwriting manuals were amended and
explicitly prohibit this practice in mid-2007. But
I -- I don't think -- my recollection, I don't think
that's true. Okay? And the reason being this: If
you understand the whole context of this,
Countrywide -- we had -- we created a
underwriting -- automated underwriting system -- It
was the first one created in the United States -called CLUES, an acronym for Countrywide Loan
Underwriting Exception System, I believe.
That system did one of two things. It
approved the loan immediately when put through the
system, or it referred the loan to a manual
underwriter. Because the variables run in the
millions on these loans, there's no way that you can
program a system to take all those variables into
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BY MR. SELENDY:
Q. Well, let me see if I can try and make it
clearer. If you'll turn to page 13 of the
complaint, and paragraph 30, starting with the
second sentence, it states:
"According to Countrywide's official
underwriting guidelines, exceptions were only
proper where compensating factors were
identified which offset the risks caused by the
loan being outside of guidelines. In practice,
however, Countrywide used as compensating
factors variables such as FICO and loan to
value, which had already been assessed by CLUES
in issuing a refer finding. Countrywide's
underwriting manuals were amended to explicitly
prohibit this practice in mid-2007, so forth."
Do you see that?
A. I see it.
Q. Okay. Does that help at all for you to
distinguish between compensating factors being
values which are assessed as part of the initial
attempt to determine whether loans conform with
guidelines or not?
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consideration. And we wanted to make sure that

every borrower, Black, White, Hispanic, Asian,
whatever, had an equal opportunity to be approved
once the fact -- once everything in that -- in those
documents were carefully reviewed. And if CLUES
referred it, that meant it had to go to a manual
underwriter.
I'm not -- you're asking me whether or not
manuals were amended explicitly to prohibit this
practice. I can't believe that because the system
can only do one of two things: approve or refer.
And if you took away the referral, you would reject
50 to 60 percent of the loans.
BY MR. SELENDY:
Q. Did Countrywide create the CLUES system to
enable the automated processing of loans which would
be exceptions from its guidelines?
MS. CONCANNON: Mischaracterizes prior
testimony.
THE WITNESS: CLUES embedded our guidelines
into algorithms. It wasn't to bypass them, it was
to embed them. But it was created, one, to make
sure we had consistency -- consistency in
underwriting and to remove, hopefully remove, the
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possibility of discrimination because of race. We

had -- we had branches throughout this country,
thousands of branches. We had inconsistent
underwriting over those years. We tried to get
consistency so everybody had a fair chance and
people would not be -- their credit-worthiness not
be determined by -- by either their sex or
orientation or their race or whatever. That's the
reason for CLUES.
BY MR. SELENDY:
Q. You just told me the acronym stands for
Countrywide Loan Underwriting Exception Processing
System.
A. I said I think it did.
Q. Right.
And so exception is an exception to what,
sir -MS. CONCANNON: Objection.
BY MR. SELENDY:
Q. -- if not an exception to guidelines?
THE WITNESS: The "E" is Exception? Is
that what it is?
MR. SELENDY: You can't ask your counsel
for the answer to the question.
MR. SIEGEL: He can do whatever he likes.
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certain that everyone was treated fairly in the

process.
This was mandated, by the way, by the
Federal Reserve and by Congress. Congress passed
the Home Mortgage Disclosure Act, HMDA, which
required all lenders to submit all of their
rejections to the Federal Reserve in Boston. In
1992 that created a report demonstrating that four
times African-Americans and four times Hispanics
being rejected versus Whites. The government
concluded that there was discrimination and there
was unfairness in the underwriting process.
In fact, just recently, the Obama
Administration mandated that lenders take a second
look at loans that they've rejected. Now, you can
call that anything you want, but it's -- it's to
make certain that everyone, every loan was reviewed
in a fair manner, and that they were given every
opportunity to obtain a loan to purchase a home
where they demonstrated the ultimate ability and
willingness to pay. You can't do that by computers
and by algorithms.
And, again, we were -- it was mandated
under the Home Mortgage Disclosure Act, the action
of the Federal Reserve of Boston in 1992, that came
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You can object to it.

MR. SELENDY: I'm sorry, excuse me. You
have to abide by the same rules as any other witness
in this proceeding.
THE WITNESS: Look, I don't know -- the
"E," that's the part -- I'm not sure if it was
Exception or had some other meaning.
But go ahead with your question.
BY MR. SELENDY:
Q. Do you understand what an exception is if
not an exception to guidelines?
overbroad, mischaracterizes prior testimony.
BY MR. SELENDY:
Q. What is an exception loan, sir?
A. It's a loan that we have -- we have
specific guidelines that are easily translated into
algorithms, but there are many factors in the human
experience that cannot be -- you cannot put an
algorithm to it; requires someone to look at it and
review it. If it was as simple as putting these
algorithms in and putting them in a computer, I
would not have 66,000 employees, I would have 5,000
employees. But our responsibility, our moral
responsibility, our legal responsibility was to make
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out, all of the advocates for housing, particularly

in minority communities, their mandate to banks,
CRA, Community Reinvestment Act, back a long time
ago. Same thing. There are exceptions. Nobody can
fit in the same -- everybody can't fit in that same
mould. But everybody has an opportunity, should
have an opportunity to own a home where they can
demonstrate the ability to pay. And to do that
properly and effectively and honestly and truthfully
is to do it right, referring the loan out and have
somebody take a look at it to see what was missed in
the system.
Q. Mr. Mozilo, I agree with much of what you
said, but I still need an answer to my question,
which is: Is an exception loan a loan that is an
exception to guidelines?
A. Could be.
Q. Isn't that the definition of an exception
loan?
MR. SIEGEL: Asked and answered. Just gave
you a definition.
THE WITNESS: Well, I don't know, you know.
I can't answer your question. I don't know, can't
define exactly the global meaning or the universal
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meaning of an exception. It was simply an exception

from the guidelines. There could be other reasons
for it.
BY MR. SELENDY:
Q. What other reasons can you think of?
THE WITNESS: I can't think of any at the
moment, but the nature of the business which you -well, you're going to go down whatever track you're
going to go down, but the cornerstone of
underwriting is making an underwriting decision.
You have basic guidelines that you follow, but in
certain circumstances there has -- a deviation of
those guidelines -- you want to call it deviation,
exception -- is not only required, but as a
responsible lender is mandated.
MR. SELENDY: Okay.
Q. Could you refer to page 19 of the document,
paragraph 45? The complaint states:
"By no later than 2006, Mozilo and Sambol
were on notice that Countrywide's exotic loan
products might not continue to be salable into
the secondary market."
Do you see that?
A. I do.
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Q. So if you used that loan -- if you used

that term in the past, why would that have been,
sir?
MR. SIEGEL: Question calls for
speculation.
MR. SELENDY: Okay. I'll withdraw that
question.
Q. Did you make exceptions to guidelines for
personal friends of yours, sir?
THE WITNESS: I never made an exception to
a guideline for personal friends that wouldn't have
been made to anyone that I didn't know.
BY MR. SELENDY:
Q. You didn't give approvals for loans that
otherwise would not have satisfied Countrywide's
underwriting criteria?
MR. SIEGEL: Different question.
THE WITNESS: I approved some loans that
were outside of our guidelines. My recollection is
I did, but that they were sound loans, and the
evidence of that was to the delinquency and
foreclosure rate, which was virtually nonexistent in
the loans that I approved.
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Q. Do you have any understanding of the

content of that statement?
MR. SIEGEL: Question's irrelevant, calls
for speculation and argumentative.
THE WITNESS: Absolutely none.
BY MR. SELENDY:
Q. Did you ever use the term "exotic loan
products" to refer to Countrywide's loans?
A. Excuse me, what was the question?
Q. Did you ever use the term "exotic" to refer
to Countrywide's loans?
MR. SIEGEL: Vague.
THE WITNESS: You know, I've used -- said a
lot of words over the -- my 72 years of life. I may
have said that word, but it's not something that was
common to me because I didn't even know what that
means, "exotic."
BY MR. SELENDY:
Q. Are there loan types that were offered by
Countrywide that you regard as "exotic"?
overbroad.
THE WITNESS: No. I would not term any
loan made as "exotic."
MR. SELENDY: Okay.
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BY MR. SELENDY:
Q. What were the reasons for your approval of
loans outside of guidelines?
MR. SIEGEL: Question's compound, vague and
irrelevant, not reasonably calculated to lead to the
discovery of relevant evidence.
THE WITNESS: The same reason that I've
explained over and over again, that the down
payment, co-signing, other factors, compensating
factors, made a loan a good loan, in my opinion.
BY MR. SELENDY:
Q. You had personal involvement in ensuring
that loans were given to public officials on
favorable terms; isn't that right?
MR. SIEGEL: Vague and irrelevant.
I don't think you insured any of those.
THE WITNESS: Not only that, but I think
that there is no loan that I made to anyone where,
one, they couldn't get that loan or a better loan
someplace else with thousands of competitors out
there.
And secondly, one that I didn't believe was
a good loan for Countrywide.
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BY MR. SELENDY:
Q. Can I have an answer to the question?
A. That's the answer to your question.
Q. My question was whether you had personal
involvement in ensuring that loans were given to
certain public officials on favorable terms?
MR. SIEGEL: The question's vague,
argumentative.
BY MR. SELENDY:
Q. Is the answer "yes"?
MR. SIEGEL: The question's vague,
argumentative, misstates the testimony, and it's
irrelevant.
THE WITNESS: I recall making some loans
to -- actually, I didn't make any loans to anybody.
I referred loans over to the underwriters who
underwrote those loans, and from time to time I'd be
called for whether or not the exception was
acceptable or not acceptable. Sometimes they were
acceptable, sometimes they weren't.
BY MR. SELENDY:
Q. Did you try to achieve political objectives
in approving loans outside of guidelines?
MR. SIEGEL: Question's irrelevant,
argumentative and asked and answered.
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Q. What does that refer to?

A. Friends of Angelo, but it was not a
program.
Q. Okay. What was it, sir?
A. My understanding of it was when a file was
put on my desk one day that had "FOA" on it, I
asked, "What does this mean?"
And they said, "Friends of Angelo."
And I said, "Why are you doing that?"
Because I originate a lot of loans. Almost
everybody I come in contact with, that was my job,
was to originate loans. That's who I was. That's
why I started the company. With taxi drivers -Do you have any interest in this answer
or -Q. I do have an interest.
A. Then I'll just wait until you're finished.
Q. Continue, sir. Every statement you make is
on the record. It's recorded both in the -A. I know it is.
Q. -- in the transcript and the video.
You can continue, sir.
A. I made it known to anyone who had an
interest that I was in the mortgage business -waiters, taxi drivers, limo drivers, stewardesses,
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THE WITNESS: And insulting. And

insulting.
BY MR. SELENDY:
Q. Can I have an answer?
A. It's insulting, number one.
Number two, it's the least political
company you'll ever find, was Countrywide. There
was never an act, an action, an event, anything,
that politicians did in favor of Countrywide, ever.
Q. I don't think I have an answer to my
question.
Did you try to achieve political objectives
by approving loans outside of guidelines?
A. No.
MR. SIEGEL: Question's vague, ambiguous,
irrelevant.
THE WITNESS: Never.
BY MR. SELENDY:
Q. Was there a program called "The Friends of
Angelo Program" at Countrywide?
MR. SIEGEL: Question's irrelevant.
THE WITNESS: No.
BY MR. SELENDY:
Q. Did you ever hear the term "FOA loan"?
A. Yes.
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gardeners -- and I'd give them my card, and when

they called, I put those loans into our underwriting
system. My people decided to label "FOA." They
were not friends. But it was business. That was my
business, to originate loans.
And I asked the people, "Why did you put
FOA? Why are you doing this?"
And they said, "Because you referred them
to our underwriting system. If we reject the loan,
we want to warn you in advance so you're not
blind-sided."
And that was the purpose of it. That was
fine by me. And that's the way it continued.
Q. Okay. Let's mark as Exhibit 1399 a
compilation exhibit including the series of -A. Are you finished with this?
Q. Yes.
-- a series of FOA-type loans produced by
Countrywide. 1398. Excuse me.
MS. CONCANNON: Objection to the
characterization of the document.
attached hereto.)
///
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BY MR. SELENDY:
Q. First document is dated December 17th,
2004. In the subject line it states "Re: FOA
)." And you state in
your e-mail:
"In case you didn't receive my first
message, you are to approve and close this
loan. Next time you have a request of this
nature from a former senior executive of
Countrywide you should contact me directly."
Do you see that, sir?
A. Uh-huh.
Q. And this is an example of a Friend of
Angelo Loan; correct?
MR. SIEGEL: Argumentative.
BY MR. SELENDY:
Q. Correct?
A. This is an example that you placed in this
category of Friend of Angelo. As I said, I was a -I was the originator of tens of thousands of loans
since 1968.
Q. Well, you say I placed it in the category,
but that's actually in the subject line of the
internal Countrywide e-mail; correct?
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BY MR. SELENDY:
Q. Do you see that?
A. If that's what it says. I mean, I'm trying
to digest this entire document. But if that's what
it says, it says that.
Q. Right.
And so did you have any basis, from an
underwriting perspective, in determining that this
was, in fact, a good loan for Countrywide to
originate, or was it simply that this was somebody
that you knew?
MS. CONCANNON: Assumes facts not in
evidence, lacks foundation.
MR. SIEGEL: Irrelevant.
MS. CONCANNON: Calls for speculation.
THE WITNESS: Is this a loan that MBIA
insured?
MR. SELENDY: I'm not here to answer your
questions, sir.
THE WITNESS: Well -MR. SELENDY: I'd like an answer to mine.
THE WITNESS: Look, there could be -MR. SIEGEL: Why don't you -- why don't you
read the whole document. You'll see the answer.
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A. Yeah, but this whole package is this -- you

created this.
What your question is -- so yeah, I made
that statement seven years ago.
Q. Right. And -A. Seven and a half years ago to be exact.
Q. If you'll notice, the e-mail that's sent to
you states, starting in the second line:
"The loan exceeds guidelines based on the
following: LTV exceeds guidelines by 9.9
percent, cash out exceeded by $200,000, FICO
627 should be 616."
Do you see that?
A. Where are you reading this from?
Q. This is in the middle of the page in the
e-mail that's sent to you on the FOA loan.
A. Yeah.
Q. Do you see that?
A. Uh-huh.
Q. And the Structured Loan Desk stated that
they were unable to grant an exception for that
loan; right, as reflected in the top paragraph?
MR. SIEGEL: Document speaks for itself.
MR. SIEGEL: It's irrelevant.
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Argumentative, irrelevant and -THE WITNESS: The problem is I'm having a

problem reading this stuff.
MR. SIEGEL: The question is: Did you have
any basis from an underwriting -THE WITNESS: This is a 59 percent LTV? Is
that what this says here?
MR. SELENDY: That's what the document
states.
THE WITNESS: Okay. That's the reason,
because 40 percent down.
BY MR. SELENDY:
Q. So you decided that although that attribute
had already been considered by guidelines and by the
Structured Loan Desk, for you, because this was
somebody you knew, that was sufficient?
MR. SIEGEL: That misstates the document.
It's argumentative and it misstates facts not in
evidence.
THE WITNESS: I'll go back to my original
statement. I would make this loan to anybody,
whether they were a friend or not.
BY MR. SELENDY:
Q. So did you make any effort to instruct the
Structured Loan Desk to change their processing so
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they would give this kind of loan to anybody, even

though they had told you they would not grant it
under their existing protocol?
THE WITNESS: No.
BY MR. SELENDY:
Q. Okay. Why is that?
A. Because it didn't require that.
And secondly, I didn't -- that was not my
role, to go in and change guidelines. My role was
to deal with situations like this. I'm an
underwriter. Somebody puts 40 percent down, I'm
comfortable.
Q. But you didn't want to be comfortable for
everybody, huh, just people who -MR. SIEGEL: Oh, boy, that's argumentative,
asked and answered.
THE WITNESS: As I said, my role is not to
change guidelines.
BY MR. SELENDY:
Q. Can you turn ahead to the document that has
a Bates number ending in 5921? It's dated April
6th, 2006.
A. This one to
?
Q. Yes.
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THE WITNESS: I don't see that.
BY MR. SELENDY:
Q. It's the sixth line up, seventh line up
from the bottom.
A. Uh-huh.
Q. Do you see that?
A. Yes.
Q. What does that mean, "Verified income is
5,848 versus 20,833 stated"?
A. I don't know.
Q. Doesn't it mean that he said on his
application he earns 20,833 per month, whereas all
Countrywide could verify was 5,848?
A. I'm not sure.
Q. You don't know.
Did you know at the time?
A. Did I know in 2006? I don't know what I
knew in 2006.
Q. Would you have wanted to know that in order
to be able to decide whether the loan should be
closed right away?
overbroad.
MR. SIEGEL: Irrelevant.
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You say in that, in that request, you say:

"Close the loan right away, and thank
for this business. He is a close,
personal friend."
Do you see that?
MR. SIEGEL: Hang on a second, Angelo,
while I try to find this document.
THE WITNESS: Towards the end.
MR. SIEGEL: Oh, it's towards the end.
Okay.
Got it.
MR. SELENDY: Okay.
Q. Again, my question is: Do you see that you
stated: "Close the loan right away, and thank
for this business. He is a close,
personal friend"? Do you see that?
A. Yes.
Q. And was that true?
MR. SIEGEL: Question's irrelevant.
THE WITNESS: A close friend, yeah.
BY MR. SELENDY:
Q. Okay. And in the e-mail that came to you,
do you notice that it states, in the list of
attributes, "Verified income is $5,848 versus 20,833
stated"? Do you see that?
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THE WITNESS: Again, there are many factors

in underwriting a loan. This, again, is a loan that
came to me. I'd approve it for everybody. This is
a loan that had a -- he had reserves of a million
one hundred fifty-five thousand -- one hundred
fifty-six thousand dollars. It was a -- trying to
look at the total CLTV here.
The LTV was 40 percent loan to value, had
60 percent against the first, and he had a -- and he
had a 39 percent second, so total was 79 percent.
That's over 20 percent down with a 1,155,000
reserve. And more important to me is the loan
performed and performed well.
BY MR. SELENDY:
Q. Does it matter to you that the stated
income appeared to be false based on Countrywide's
verification?
MR. SIEGEL: That's argumentative, calls
for speculation, misstates the document.
THE WITNESS: I think the real issue is
what his real income is, and I'm not making a
judgment.
BY MR. SELENDY:
Q. In general, is it a problem if a borrower
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states an income that is significantly in excess of

the real income?
overbroad, incomplete hypothetical, assumes facts.
THE WITNESS: It's a complex question to me
because I don't know what "real income" means. In
many cases -- this is self-employed. In many cases,
a self-employed borrower will make substantially
more than they're reporting to the government.
That's just the way it is. So I don't know what
"real income" is.
My concern in this case is how much down
payment does he have, how much equity does he have
and how much in reserve does he have in the event
there's an interruption in his earnings. He had
more in reserve than the loan amount. It's a good
borrower.
BY MR. SELENDY:
Q. So as a prudent underwriter, is it a
concern that a borrower may misstate income on the
loan application?
THE WITNESS: My concern would be what is
the real income and does he have the real ability to
pay. In this case, it was obvious to me -- you're
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issues, so it was -- it wasn't a relevant issue.

MR. SELENDY: I'm talking generally.
MR. SIEGEL: He answered the question. It
was a relevant issue.
BY MR. SELENDY:
Q. You said it was a relevant issue?
A. Was not.
Q. Was not a relevant issue?
A. In this case. In this case. Generally
speaking, we expect, as I said, the answer was, we
expect what people tell us they make, what they -what their earnings are. Under the stated income
concept, which was a relatively new concept that was
adopted by Fannie Mae, Freddie Mac and by the
private mortgage insurers -- because private
mortgage insurers knew whether loans originated on
stated income or not. They had all the details.
They could go -- private insurers could go back and
determine whether or not they had a problem with a
loan where the stated -- where our verified income
was less than stated income. All that information
was disclosed.
But on a general basis, it would concern me
that people were lying on the loan application.
///
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bringing this case to my attention -- that this man

had to make substantially more than he's reporting
because he saved over a million and a half dollars,
a million one fifty-five. So it was obvious to me
that he was making more. This concern me morally?
I think it's their issue, not mine.
BY MR. SELENDY:
Q. I'm asking: Generally, as a prudent
underwriter, is it one of the concerns of a loan
originator to ensure the borrower is accurately
stating income on the loan application?
overbroad, incomplete hypothetical.
MR. TU: Asked and answered.
THE WITNESS: We assumed -- we assumed that
when -- what they were telling us on the loan
application was true and correct.
BY MR. SELENDY:
Q. Did you keep that assumption even if your
verification didn't corroborate the statement?
MR. SIEGEL: Question's vague, use of the
word "your."
THE WITNESS: We -- we looked for -- again,
this had -- this had substantial compensating
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BY MR. SELENDY:
Q. In fact, you saw evidence that the
incidents of borrower fraud was increasing
dramatically in this period from 2004 through 2007;
correct?
MR. SIEGEL: Question's compound.
Mischaracterizes testimony.
THE WITNESS: Are those your words?
"Dramatically," is that your word?
MR. SELENDY: That's a question to you,
sir.
THE WITNESS: No, is that your word,
"dramatically"?
MR. SELENDY: That is the word in my
question.
THE WITNESS: I don't know if it was
increasing dramatically. There was no question
that -- that there was more evidence of fraud as the
bubble was continuing to grow, and I made that -that assertion on my part that -- I made that
public, that it was a concern. Fraud -- appeared to
be increasing fraud and I was concerned.
BY MR. SELENDY:
Q. By the way, sir, do you understand that
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MBIA is a monoline insurer, not a private mortgage

insurer?
MR. SIEGEL: Calls for speculation. I
guess not.
BY MR. SELENDY:
Q. You don't know one way or the other?
A. No. As I said, I know nothing about them.
I never met anybody from there.
MR. SELENDY: I can keep going another 45
minutes or we can take a break, if you like.
MR. SIEGEL: Let's keep going.
THE VIDEOGRAPHER: Ten minutes left on the
tape.
MR. SIEGEL: Let's at least keep going the
10 minutes.
MR. SELENDY: So we'll do the 10 minutes.
Q. In general, I'm just going to keep going
until you tell me you'd like a break, so...
But I don't want you to feel that I'm not
going to take breaks when you need them.
MR. SIEGEL: Don't count on that.
MR. SELENDY: What number? What number?
Okay. Let's mark as 1399 a transcript of a
conference call Q4 2003 for Countrywide Financial.
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correct? You can determine that on the first page.

You see it says "Angelo Mozilo, Countrywide
Financial Corporation, Chairman/CEO"?
A. Uh-huh. Okay.
Q. So this is you speaking; right?
A. That's what it says.
Q. Do you recall giving presentations at
events like this from time to time where you
described the earnings of the corporation, among
other things?
A. Earnings conference I did every quarter.
Q. Right.
So if you'll turn to page 3, you say at the
bottom:
"As I mentioned earlier, we have a very
aggressive market share goal -- we have very
aggressive market share goals."
Do you have see that?
A. No.
Is this the bottom of page 3?
Q. Bottom of page 3.
MR. SIEGEL: It's actually the fourth page
of the -MR. SELENDY: The page number in the gray
says "3," because they don't appear to label the
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attached hereto.)
THE WITNESS: Have we finished with this?
MR. SELENDY: Yes.
MR. SIEGEL: We're putting -- I just
realized I've been putting your copies in this pile.
BY MR. SELENDY:
Q. As always, you're free to look at what you
want, but I'm going to direct your attention to page
3, starting at the bottom of the page.
A. I just want to make sure I'm looking at the
right document here. This is an eight-year-old
document?
Q. We are concerned in this case with events
from 2004 through 2007.
A. This is 2003.
Q. The event date is January 27th, 2004; do
you see that?
A. But it's Q4 for 2003.
Q. Correct.
A. What is your question?
Q. If you'll turn to the bottom of page 3, you
see there is -- in fact, just so you're clear,
you're speaking here at this investor conference;
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first page.
MR. SIEGEL: Here.
THE WITNESS: Okay. Where is it? Where
are you quoting from?
MR. SELENDY: At the bottom.
Q. Do you see that you say: As I mentioned
earlier, we have very aggressive market share
goals"? Do you see that?
A. Yes.
Q. And that's fair as of the beginning of
2004, you did have very aggressive market share
goals; correct?
A. I don't remember.
Q. Well, you wouldn't have said it, would you,
if it wasn't true?
A. What?
MS. CONCANNON: Sorry?
BY MR. SELENDY:
Q. You wouldn't have made the statement if it
wasn't true, would you?
A. It speaks for itself. I don't recall what
our market share goals were or whether they were
aggressive or not aggressive. I'm just going based
on what the document says.
Q. Let me see if I can help you out.
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On the next page, in the middle, second -second column, you have a paragraph that says:
"Our goal is market dominance and we're
talking 30 percent origination market share by
2008."
Do you see that?
A. Where? Where are you on this page?
Q. Okay. It's in the middle of the page,
second column, starting with "our goal."
A. Okay.
Q. Do you see that?
A. Yes.
Q. You do say that your goal is market
dominance and you're talking 30 percent origination
market share?
A. Right.
BY MR. SELENDY:
Q. And that -- that was a very aggressive
market share goal for you at the time; right?
THE WITNESS: It was -- it was a -- I use
the term "aggressive" to start with, and that's the
term I'll stay with, is "aggressive."
MR. SELENDY: Yes.
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correct?
A. Yes.
BY MR. SELENDY:
Q. Is it fair to say that domination of the
mortgage lending space was one of the foremost goals
that you had starting with this period beginning of
2004?
argumentative.
THE WITNESS: No. The operative words here
are "those who can qualify."
BY MR. SELENDY:
Q. I didn't hear what you said, sir.
A. Those who can qualify. I think that's in
the word here.
Q. Okay. But is it fair to say that one of
your foremost goals was domination of the mortgage
space as of the beginning of 2004?
argumentative.
THE WITNESS: Again, putting it in
perspective, that was one of our goals. Primary
goal was to make sure that we were making loans that
people can repay. Secondary goal was to increase
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Q. Flipping back to the -- well, actually,

just turning to the column next to that, second full
paragraph states:
"Another key component of our strategy is to
maintain the industry's broadest product menu."
Do you see that?
A. Yes.
Q. And you're saying here that a key component
of your strategy to get to this aggressive market
share goal is to have the industry's broadest
product menu; correct?
A. Correct.
BY MR. SELENDY:
Q. And you say:
"Many of our competitors have limited
product lines. Our strategy is to be able to
offer one-stop shop solutions to our business
partners, mortgage brokers, realtors and
builders, for example, so if they have a
customer who can qualify for a loan, we will
have the product that meets their needs."
Do you see that?
A. Yes.
Q. And that was your objective at the time;
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our market share and dominate the industry.

BY MR. SELENDY:
Q. And as you said, the requirement to
originate loans only to people who can repay is the
fundamental first requirement of responsible loan
origination; right?
THE WITNESS: Correct.
BY MR. SELENDY:
Q. What steps did you put in place to try and
reach this goal of domination? Do you recall?
BY MR. SELENDY:
Q. Other than the supermarket strategy.
argumentative.
MS. CONCANNON: And mischaracterizes prior
testimony.
THE WITNESS: I can't tell you
specifically. We had, again, we had a large team
that -- that required a buy-in by the entire team.
Being a dominant player is a good thing, it's a
positive thing for a company, and as long as you did
it responsibly. And this team was mobilized. And I
think primarily was by the expansion of our branch
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system, I believe -THE VIDEOGRAPHER: Two minutes, counsel.

THE WITNESS: -- by placing more branches
in areas of the country we were not located in. And
that was one method.
The other was to size our branches so that
they could economically support going into small
towns. Larger branches couldn't afford to work in
small towns. There was not enough revenue. So it
was restructuring our branches, expanding our branch
system, is what comes to my mind as to how we did
it.
But the entire team was involved in this.
And it was determined that we couldn't do it, that
we couldn't meet our standards and at the same time
meet the 30 percent goal.
BY MR. SELENDY:
Q. When did you make that determination?
A. I have no idea.
MR. SELENDY: Okay. We have to change the
tape, so we'll resume.
THE VIDEOGRAPHER: This marks the end of
Videotape No. 1 in the deposition of Angelo Mozilo.
Time on the video monitor is 10:30.
(Recess to change tapes.)
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A. Uh-huh.
Q. Do you have any recollection of what you
meant by that?
A. No. That's -- that was the theme of
Countrywide from its inception. That's why the name
is Countrywide.
Q. Domination?
A. It's one of the reasons.
Q. Okay. And you state:
"In order for us to make certain that we not
only maintain momentum but gain dominance over
Wells and WAMU, we have to accelerate the
growth of our sales force in all of our
channels and particularly in CMD."
Do you see that?
A. I do.
Q. Why did you select Wells and WAMU as
benchmarks?
A. Because they were second and third.
Q. Okay. And what was the reason why you said
it's particularly important to accelerate growth in
CMD?
MR. TU: Objection. Misstates the
document.
///
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THE VIDEOGRAPHER: This marks the beginning

of Videotape No. 2 in the deposition of Angelo
Mozilo. Time on the video monitor is 10:43.
MR. SELENDY: I've asked the reporter to
mark as Exhibit 1400 a one-page document reflecting
an e-mail exchange between yourself and David
Sambol.
attached hereto.)
BY MR. SELENDY:
Q. So the bottom part of this document
reflects an e-mail that you sent to David Sambol;
correct?
A. Yes.
Q. And this is following up on the statements
you made about domination in the earnings call in
the document we just reviewed; right?
argumentative.
THE WITNESS: I don't know if it relates to
it at all.
BY MR. SELENDY:
Q. You see the subject is "Domination"?
That's your subject line; right?
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BY MR. SELENDY:
Q. That is what you say; right?
A. I say "particularly in CMD." This is 2004,
seven years ago. I don't -- I don't recall.
BY MR. SELENDY:
Q. Do you have any recollection as to the
strategic importance of CMD with respect to your
agenda of achieving dominance?
THE WITNESS: It was one of three channels
that we had, and I don't know why I put particular
emphasis on CMD.
BY MR. SELENDY:
Q. Is it fair to say that a key objective in
increasing market share was to accelerate the growth
of the sales force?
THE WITNESS: That's what it says here,
yes.
MR. SELENDY: Okay. Let's mark as Exhibit
1401 -- I'm sorry, this is -- I'm going to show you
a document that's been previously marked as 1142.
It's another transcript of a conference call. And
my first question is:
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Q. Does this reflect the transcript of a

Countrywide Financial Corporation analyst meeting on
May 24th, 2005?
Q. Okay. And turning to the page with Bates
number ending in 105350, there's a statement made in
the fourth full paragraph. This is Stan Kurland
talking, as you can see from the preceding page.
Statement is:
"Today Countrywide's strategy has evolved
into a diverse multi" -A. Stop a second. Am I on the right -Q. It's the fourth paragraph, second sentence
of that paragraph.
A. Oh, second sentence of it.
Q. Do you see that?
A. "Today Countrywide," is that what you're
saying?
Q. Yes.
A. Okay.
Q. "Countrywide's strategy has evolved into a
diverse, multifaceted approach. On the one
hand, our mission remains to dominate
residential mortgage lending space. We extend
this through the profitable origination market
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been working on developing a new set of goals

relative to our primary metrics. These new
2010 goals, which were also articulated in a
press release this morning, include the
following: For mortgage bank originations, the
goal is for market share to approach 30
percent, with total annual originations
approaching one trillion dollars. Mortgage
servicing goals include market share in excess
of 20 percent with a portfolio exceeding 2.5
trillion dollars."
Do you have see those statements?
MR. PETTIT: Objection.
THE WITNESS: I do.
BY MR. SELENDY:
Q. In the next paragraph it states,
Mr. Kurland states:
"In the past we talked about origination of
market share reaching 30 percent by 2008, and
as we've noted, this was intended to be a
stretch goal as it was part of our culture,
part of our nature to set aggressive targets."
Was that statement by Mr. Kurland fair?
THE WITNESS: I think it's a fair
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share growth driven by infrastructure,

expansion, product menu, leadership and
leading-edge technology."
See that?
A. Yes, I do.
Q. And that was a fair statement of the
mission as of May 24th, 2005; correct?
MR. SIEGEL: Question's argumentative and
vague.
THE WITNESS: Based upon my recollection, I
think it's a fair statement.
MR. SELENDY: Okay.
Q. And if you turn ahead to the Bates numbered
page ending in 353, there's a further statement by
Mr. Kurland, and I'm looking at the paragraph
roughly just down from the middle of the page,
beginning "for the years beyond 2005."
MR. SIEGEL: And this is from Mr. Kurland?
MR. SELENDY: Yes.
THE WITNESS: Yeah.
BY MR. SELENDY:
Q. Do you see that paragraph?
A. I do.
Q. Mr. Kurland states:
"For the years beyond 2005, Countrywide has
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statement.
BY MR. SELENDY:
Q. Countrywide by nature was an aggressive
company; right?
THE WITNESS: We were by nature a
responsible company that had aggressive goals.
BY MR. SELENDY:
Q. If you'll turn to the next page, the third
full paragraph begins:
"Risk management is also a major strategic
initiative."
Do you see that?
A. Yes.
Q. Mr. Kurland states:
"Countrywide is committed to a highly
effective enterprise-wide risk management, and
today's program features Nick Krsnich, our
chief investment officer, and John McMurray,
our chief credit officer, who will cover this
topic in more detail."
Do you see that?
A. I do.
///
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BY MR. SELENDY:
Q. Was there an effort made, at the time you
adopted the goal of 30 percent market share and
expansion in sales force, was there an effort made
to increase the size of the credit risk organization
under Mr. McMurray's leadership?
MS. CONCANNON: Objection to form.
THE WITNESS: I think that Mr. Kurland
covered that in the previous statement, but I don't
know if I can find it again. The -- in order to
expand to the volumes that we had projected, if we
were successful, all of our operations and our
structure had to be strengthened, and I -- I can
only assume that that was true of the credit risk
area.
BY MR. SELENDY:
Q. Do you say you can only assume that because
you don't have any recollection of that with respect
to the credit risk area?
THE WITNESS: Based upon the culture of
Countrywide and how we operated, that technology,
credit risk, all the risk areas of the company
received enormous attention from the management
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made by David Sambol. It begins on page 355, but

I'm going to ask you a question as of 358. And this
is up from the bottom of the page, the second to
last full paragraph, beginning "another big factor."
Q. Do you see that?
A. Uh-huh.
Q. Mr. Sambol states:
"Another big factor supporting the growth in
the mortgage market is the expansion of
products and loan types offered to the
marketplace. This includes products with new
terms and new features and qualification
criteria that has also allowed more consumers
to qualify for the purchase of a home, and has
served to offset some of the affordability
issues which have come with significantly
higher home prices in many markets in the U.S."
Do you see that?
A. Yes.
Q. Is it fair to say that Countrywide was
actively rolling out products that were designed to
increase home ownership by borrowers that would not
have qualified under the guidelines previously
applied by Countrywide?
MR. SIEGEL: Question's vague, misstates
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team. And I don't recall specifically what was

done, but I feel confident in saying that every area
of the operation was -- was strengthened, new people
brought in, in order to make sure that we -- that
our operation remained at the highest quality.
MR. SELENDY: Okay.
Q. So to be clear, that's an assumption you're
making based on the strength of your management
team; is that fair?
THE WITNESS: In the history of the company
that's always what we did.
BY MR. SELENDY:
Q. You personally didn't direct any aggressive
expansion of the credit risk arm of the company, did
you?
THE WITNESS: I don't know if I did or not.
BY MR. SELENDY:
Q. You just don't recall?
A. I don't recall.
Q. So it's possible that you did not?
THE WITNESS: It's possible that I did.
MR. SELENDY: Let's turn to the statements
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the document.
THE WITNESS: I'm not certain.
BY MR. SELENDY:
Q. You are aware that Countrywide rolled out
expanded products and loan types as of 2005 and
continuing forward through 2007?
THE WITNESS: I'm aware of that, but it
doesn't mean that those people wouldn't have
qualified for the -- for the other loans.
BY MR. SELENDY:
Q. On the next page, in the middle of the
page, there's a paragraph beginning "and our market
share growth strategies." That's page 359.
A. Yeah.
Q. In that paragraph, the last sentence
states:
"It is Countrywide's desire and intent to
not only participate, but to be a leader in
every market, every channel and every segment
of the mortgage market, whether those segments
of the market are defined by geography,
consumer demographic profiles or product
preference."
Do you see that?
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A. Yes.
Q. Was that a true statement as of the time
Mr. Sambol made it?
A. I believe it to be true.
Q. Okay. And do you know roughly how much
Countrywide in fact grew its sales force in the
period from 2004 to 2007?
A. No.
BY MR. SELENDY:
Q. Did you more than double the size of the
sales force?
A. I don't know.
Q. Turn to the next page, page 360. Top of
the page Mr. Sambol states:
"The message that we conveyed to the market
and to our recruits is account and sales" -I think it's supposed to be "our recruit
account and salespeople."
-- "can grow their business and originate
more volume if they come to Countrywide, and
that's the primary explanation for historical
success and our future success relative to
sales force growth."
Do you see that?
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aggressively drive up sales?

THE WITNESS: I have no knowledge of any
incentives.
BY MR. SELENDY:
Q. The paragraph following that Mr. Sambol
states:
"Now, with respect to product lines, I
mention that the key aspect of our value
proposition to both our salespeople and our
customers is that we maintain without question
the broadest product line in the mortgage
banking industry."
Do you see that?
A. I don't see it.
Where are you now?
Q. It's the paragraph immediately below the
paragraph we just read.
MR. SIEGEL: This one.
BY MR. SELENDY:
Q. Do you see that statement by Mr. Sambol?
A. Yes.
Q. Would you agree with Mr. Sambol, as of this
point in time, that was the key aspect of the
Countrywide value proposition?
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A. Yes.
Q. Was it the case that Countrywide was trying
to induce people to come and be salespeople at
Countrywide in part on the basis that they could
sell more product at Countrywide relative to
their -- relative to your competitors?
MR. TU: Objection. Vague.
THE WITNESS: I wasn't involved in
recruiting of the sales force.
MR. SELENDY: Okay.
Q. Do you know whether you were encouraging
your management team to give incentives to the sales
force to come to Countrywide and sell more product?
MR. TU: Calls for speculation.
THE WITNESS: Yeah, I don't know what -what incentives were provided.
BY MR. SELENDY:
Q. Was it one of your objectives to try and
give incentives to the sales force to maximize
sales?
A. To my knowledge, we were trying to expand
our sales force.
Q. And were you trying to give incentives to
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MS. CONCANNON: Objection. Vague.

MR. TU: Objection. Misleading.
THE WITNESS: Countrywide, as indicated by
both Kurland and Sambol, was attempting to grow its
market share in all channels. I consider that to be
very good as long as you do it responsibly, and that
was the guideline, doing it responsibly.
I'm not -- I don't recall any specifics as
to that expansion program.
BY MR. SELENDY:
Q. Mr. Mozilo, do you see any tension between
a strategy of aggressive expansion in a bubble
market and problems arising with responsible
lending?
THE WITNESS: First of all, and foremost,
nobody knew it was a bubble market. No one. There
was no indication it was a bubble market. The
Federal Reserve didn't think it was a bubble market.
My competitors were aggressive. Wells Fargo was
close behind me, as was Washington Mutual, very
close. And you either grow a company or you go
backwards. You don't stand still.
So the use of the word "aggressive," the
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use of the word "dominance," as long as you do it

responsibly, is positive for a company, particularly
for a public company. You've got to grow a company.
And this is the way we grew it.
And so your -- your question is framed in a
manner which is -- which is void of the -- of the
environment that we understood at the time. We did
not know it was a bubble environment. We did not
know values would collapse 50 percent. And if we
did, we would not have proceeded as we did.
We were confident, as everybody else was,
that the real estate market was stable, and that we
were expanding the company in a positive, safe
environment and in a positive, safe manner.
BY MR. SELENDY:
Q. Did you at any time in the period from 2004
until 2008 see any conflict between Countrywide's
stated goal of aggressively achieving market
dominance and Countrywide's responsibility to lend
only in a responsible and prudent manner?
A. No.
Q. Didn't see any conflict or tension between
those two objectives?
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I assumed comfortably, that the people in

Countrywide Securities operated in a proper and -proper manner, understood their responsibilities,
understood the importance of the reps and
warranties, and executed the process properly. I
was not involved with those companies.
BY MR. SELENDY:
Q. Did you have any discussions about the
legal and reputational risks to Countrywide
Securities Corporation if it did not make truthful
representations and warranties?
overbroad, assumes facts not in evidence.
THE WITNESS: I don't -MS. CONCANNON: Calls for a legal
conclusion.
And to the extent it calls for any
communications that you may have had with other
Countrywide counsel or outside counsel, I would
instruct not to answer.
MR. SELENDY: I don't want to ask about any
questions with counsel on that subject. But
otherwise, I'd like you to answer the question.
THE WITNESS: Restate the question.
///
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THE WITNESS: Our -- our goals, our

objectives, our mandates to our people were clear:
Don't violate our standards. Make sure you're
making loans to people who can repay the loan.
BY MR. SELENDY:
Q. Did you also mandate that loans should only
be made in conformity with representations and
warranties?
THE WITNESS: I think you're -- you're
mixing apples and oranges. We -- we made loans. We
had a responsibility to the borrower. The borrower
had a responsibility to us. Those loans were
ultimately securitized by subsidiary companies that
issued reps and warranties.
BY MR. SELENDY:
Q. Did you regard it as the mandate of
Countrywide Securities Corporation to only make
representations and warranties that conformed to the
facts?
overbroad, assumes facts not in evidence.
THE WITNESS: Yeah, I can only assume, and
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BY MR. SELENDY:
Q. Do you recall any discussions about the
risks to Countrywide Securities Corporation if it
did not make truthful representations and
warranties?
THE WITNESS: I don't.
MR. SELENDY: Let's turn ahead to the page
ending in 5396. This reflects testimony from you.
MR. SIEGEL: Well -MR. SELENDY: Excuse me. This reflects
statements from you at that analyst conference.
Q. In the third paragraph down, the paragraph
begins "I'm going to"; do you see that?
A. Uh-huh.
Q. And you say -- you say:
"It's a question of dominance. You have
heard this before, we have no intention to
structure the company to be in second place or
third place. It's not what we are about. It's
never what we are about from our inception back
30 years. We could dominate our space,
dominate the space."
Do you see that?
A. Yes.
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Q. And that's consistent with your statement

made earlier today, that your objective has always
been to dominate the space; right?
THE WITNESS: I consider dominance a good
thing, yes.
BY MR. SELENDY:
Q. And you never -- your testimony is that you
never saw conflict between that obsession for
dominance and the need to conform with the rules of
responsible origination -MR. SIEGEL: Question's argumentative,
vague.
BY MR. SELENDY:
Q. -- is that right?
MS. CONCANNON: And asked and answered.
THE WITNESS: I didn't consider it an
obsession at all. I considered it our
responsibility to do the best we could for our
shareholders.
BY MR. SELENDY:
Q. Well, doing the best you can for your
shareholders if you're a mortgage originator means
lending responsibly, doesn't it, sir?
A. That's correct.
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A. Yeah.
Q. Okay. Does this reflect a message that you
sent to all Countrywide personnel on June 6, 2006?
A. Yes.
Q. And in your message you refer to the
effects from the rise in interest rates on the
housing market; right?
A. Correct.
Q. You say:
"As interest rates have risen, the housing
market, as expected, has been negatively
impacted."
Right?
A. Correct.
Q. And, in fact, Countrywide did expect that
the housing market would be negatively impacted as
interest rates rose; correct?
THE WITNESS: That's what it says. I don't
want to go over those words again.
Is that exactly what it says?
MR. SELENDY: I'm asking the -- as a
question:
Q. Countrywide did, in fact, expect that the
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THE WITNESS: Which we did.
BY MR. SELENDY:
Q. In fact, sir, you steadily favored
production over other concerns during the period of
increasing volatility leading up to 2007, didn't
you?
MR. SIEGEL: Question's -THE WITNESS: No.
MR. SIEGEL: -- vague and argumentative.
THE WITNESS: No.
BY MR. SELENDY:
Q. You favored production over credit risk,
didn't you?
argumentative.
THE WITNESS: No.
MR. SELENDY: Let's mark as 1401 CWMBIA
15970941 to 42.
attached hereto.)
BY MR. SELENDY:
Q. I'm going to focus on the first page, but
feel free to read as much as you need to.
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housing market would be negatively impacted as

interest rates rose?
A. Correct.
Q. And you say:
"My message" -This is in the middle of your paragraph
there.
"My message relative to this period of
significant change is simple: Be aggressive
during this period of competitive advantage to
gain market share.
And you go on to say:
"I am therefore encouraging each and every
one of you to put forth as much effort as
possible to both increase your production and
productivity to ensure that we continue to
maintain our dominant position in the
industry."
Do you see that?
A. I do.
Q. That's the message you sent to all
Countrywide personnel in the middle of 2006; right?
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MS. CONCANNON: Also, vague and overbroad

as to "all Countrywide personnel."
MR. SIEGEL: Takes sentences out of
context.
MR. SELENDY: You have a stipulation, guys.
THE WITNESS: You are, you know, you are
adversely selecting sentences from here to make a
case. The whole -- look at the theme -BY MR. SELENDY:
Q. I'm reading what you said, sir; right?
A. I said -MR. SIEGEL: Please don't argue with the
witness and don't interrupt him.
THE WITNESS: I said -- what I said was
clear here. The history of Countrywide's growth was
to -- when -- when markets became upset, when
volumes decreased, our competition historically laid
off great talent, and it's very difficult to get
talent when the markets are good. There's no reason
for them to leave. The only time you can get great
talent is when the markets are poor, and that's when
Countrywide seizes the opportunity to get those
people. And as I state in here, it gets us people
and it gets us customers because they bring their
customers with them. That was my message here.
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MR. TU: Objection. Document speaks for
itself, argumentative.
THE WITNESS: That's a given. Expect
everybody to adhere to our standards.
MR. SELENDY: Uh-huh.
Q. You say it's a given, but at the top
Christian Ingerslev is writing to John McMurray, the
chief of credit risk, saying:
"See bold below. Gives license to
production for all they are pushing for. Given
your recent discussions with him" -Meaning you.
-- "it's surprising he didn't mention
anything about prudence and lending risks."
Do you see that?
THE WITNESS: That's Mr. Ingerslev -that's Ingerslev's opinion. I have continuously, if
you get all the documents, emphasized the importance
of making certain that we had prudent underwriting.
I was very risk averse. And that's the reason why
Countrywide survived when very few did.
///
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BY MR. SELENDY:
Q. Your simple message was to do everything
possible to gain productivity and market share;
correct?
MR. SIEGEL: Misstates the document.
THE WITNESS: Let me -- let me -- I'm going
to read this to you:
"As competitors merge we're able to attract
new talent into the company, as well as a new
and broader base of customers. My message
relative to this period of significant change
is simple: Be aggressive during the period of
competitive advantage to gain market share."
That is to get these people, to get this
talent. Because Countrywide was nothing more than
very talented people. Our advantage over our
competition was not product or price, was quality of
people. That's my message here.
BY MR. SELENDY:
Q. And, sir, at the same time that you're
saying that each and every one of you should put
forth as much effort as possible to increase both
your production and productivity, you weren't making
any statement about prudence in lending risks, are
you?
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BY MR. SELENDY:
Q. So do you find it just perplexing that
Mr. Ingerslev would say you gave license to
production for all they're pushing for?
MR. SIEGEL: Well, don't speculate.
THE WITNESS: I have no idea who he is.
Never met the man.
BY MR. SELENDY:
Q. Do you know who Mr. McMurray is?
A. I do.
Q. Do you recall discussions you'd had with
Mr. McMurray at about this point in time about the
importance of prudence and lending risks?
A. No.
Q. Okay. And you clearly didn't mention
anything about it in your message to all personnel;
right?
MR. SIEGEL: Objection. Document speaks
for itself.
answered.
THE WITNESS: I think review of the
documentation sent to my people give an indication
that they understood the importance of prudent
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underwriting.
BY MR. SELENDY:
Q. There's no such message in this document,
though; right?
It's argumentative, asked and answered.
BY MR. SELENDY:
Q. And if I missed it, just tell me where.
A. I think it's a given with my people.
MR. SELENDY: Let me show you a document
that -- is this our case? Okay. Let's mark as
Exhibit 1402 CWMBIA-G96887.
attached hereto.)
BY MR. SELENDY:
Q. Just let me know when you're ready.
A. Okay.
Q. Okay. By September of 2004, you saw a
clear deterioration in the quality of loans
originated both at Countrywide and elsewhere;
correct?
THE WITNESS: That's my statement.
///
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Do you see that?

A. I do.
Q. And that's the warning you were delivering
to Stan Kurland at the time with respect to loan
origination; correct?
THE WITNESS: And it clear -- I'm sorry.
And a clear indication of my concern of credit risk.
MR. SELENDY: Right.
Q. And that's a risk that you foresaw as of
September 2004?
overbroad, mischaracterizes the document.
THE WITNESS: I didn't foresee this. These
are things that I was concerned about and expressing
it to my management team.
MR. SELENDY: Right.
Q. And what was the solution, among others,
what was the solution that you were trying to
encourage your management team to adopt?
MR. PETTIT: Objection. Lacks foundation,
assumes facts.
THE WITNESS: I think it's the last
sentence. And I relied heavily in my -- my e-mails
fell into three categories. One is observations and
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BY MR. SELENDY:
Q. And you're referring to the e-mail that you
sent on September 1st, 2004 to Stan Kurland, among
others?
A. Correct.
Q. And you state:
"In addition, from my point of view, the
trend is getting worse as the competition for
subprime Alt-A and nonconforming in general
continues to accelerate."
You see that?
A. I do.
Q. And that was what you believed to be true
at the time; correct?
overbroad.
THE WITNESS: That's correct.
BY MR. SELENDY:
Q. In the second paragraph you say, in the
second sentence:
"The type of loans currently being
originated, combined with the unprecedented
stretching of all aspects of credit standards,
could cause a bump in the road that could bring
with it catastrophic consequences."
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concerns. Secondly was to -- to provoke their

response. And the third type was to give direction.
This was in the first category of observation,
concern. And the last sentence is, "I would like
you to consider my concerns and let me know your
thoughts." These are the key people in the company,
and I wanted to see if they shared my concerns.
I came from one perspective, very often
they came from another, and so I wanted to get their
response to these concerns.
BY MR. SELENDY:
Q. And one thing that you recommended
specifically was to securitize the risk rather than
have Countrywide retain it on its balance sheet;
isn't that right?
MR. SELENDY: Looking at the end of the
first paragraph.
THE WITNESS: Countrywide securitized most
of its risk on its product, so it was not unusual.
BY MR. SELENDY:
Q. Well, you say:
"The bottom line of my perspective on this
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trend is that we should seriously consider

securitizing and selling (NIMS) a substantial
portion of our current and future subprime
residuals even though the value in retaining
such residuals 'appears' to be a better
economic execution than a NIMS execution."
Do you see that?
A. Yes.
Q. And so you were encouraging Mr. Kurland to
consider expanding the securitization of these
residuals rather than retain those risks on
Countrywide's balance sheet -MS. CONCANNON: Objection.
BY MR. SELENDY:
Q. -- correct?
overbroad, mischaracterizations the document.
THE WITNESS: My recollection is that we -that it was relatively common for us to securitize
the NIMS and retain some, and that judgment was made
by our financial team, what to securitize and what
to retain. And so here I was encouraging them to
think about securitizing more of our subprime
residuals, although it says -- pointed out as -- it
was pointed out to me over and over again it's very
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loans?
misunderstands the prior testimony.
THE WITNESS: The nature of a mortgage
banker is to hold nothing on its balance sheet,
nothing. Because we have no source of funding to
hold assets long term. We only have short-term
financing. The only assets we could hold is in the
bank. So we held assets at -- at Countrywide
funding level, Countrywide Home Loans level, just
because it was the best of the alternatives that we
had for a period of time, and as soon as we could
offload it, we could. We had no long-term funding
sources.
BY MR. SELENDY:
Q. Okay. My question was specifically as to
Countrywide Bank, which was able to hold assets long
term; correct?
A. We couldn't hold these assets. We're not
permitted to hold these assets.
Q. Right. Let me step back a little bit.
Was it generally the case, as to the types
of assets that Countrywide Bank was permitted to
hold, that you made a selection and retained only
the higher quality assets by contrast to what you
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profitable and it's a mistake to securitize.

BY MR. SELENDY:
Q. And you wanted to securitize it because you
saw it as risky to hold on to it; right?
THE WITNESS: As I pointed out to you
before, I was always concerned about risk, and this
is just one of the categories I was concerned about.
BY MR. SELENDY:
Q. In general, did Countrywide seek to
securitize risk that it did not wish to hold on its
own balance sheet?
THE WITNESS: First of all, Countrywide
held very little on its balance sheet historically.
It was the bank that held it on its balance sheet,
and the bank was not permitted by regulation to hold
that kind of an asset on its balance sheet. Could
only hold 660 or greater. It was first mortgage
loans and HELOCs, as I recall.
BY MR. SELENDY:
Q. In general, even with respect to the types
of loans that Countrywide Bank could hold, is it
fair to say that the directive was to securitize
rather than retain on the balance sheet riskier
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were willing to securitize?

overbroad, incomplete hypothetical, assumes facts.
THE WITNESS: Because it -- I'm sorry.
MR. SIEGEL: Go ahead.
THE WITNESS: Because of the regulatory -my regulatory -- our regulatory concerns, it was in
our best interest to put the highest quality assets
in the bank. We always operated under assumption,
all of these years in securitizations, that the
buyer of the securities or the insurer of those
securities was prudent enough to do their due
diligence and to price the risk accordingly. So to
us it was a matter of price.
BY MR. SELENDY:
Q. The investor or insurer can only price the
risk if the loan attributes are correctly disclosed;
correct?
MR. SIEGEL: That's a -- argumentative.
MR. SELENDY: It's a question.
You can answer it.
MR. SIEGEL: It's argumentative.
MS. CONCANNON: It's also vague and
overbroad, and assumes facts.
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THE WITNESS: My understanding of that,

counselor, is that we -- there were no secrets at
Countrywide. We were an open book in that if asked,
everything and -- all the information was available
to the investor or insurer anytime they -- they
requested it. There was no information that wasn't
available to them.
BY MR. SELENDY:
Q. Is it your understanding that in order for
the insurer to adequately price the insurance
policies it required Countrywide to make truthful
disclosures as to the facts of the loans in the
securitizations?
argumentative.
BY MR. SELENDY:
Q. That's fair, isn't it, sir?
MR. SIEGEL: And calls for speculation.
THE WITNESS: The disclosures, you know,
I -- again, the disclosures were part of the process
of Countrywide. I'm not privy to what those
disclosures were. I can only assume that they met
all of the necessary disclosure requirements.
And, again, if there were any concerns
about the quality or quantity of disclosure, they
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THE WITNESS: I don't know. I mean, if an
insurer wanted to go -- wanted to look at loans
preclosing, you know, whether or not, you know,
that's possible, probable or acceptable, I don't
know. But -- but that's not the practice. To my
knowledge, no insurer, no investor looked at loans
preclosing for any -- for any company.
BY MR. SELENDY:
Q. And so in deciding whether to insure or
invest, the insurer and investor had to rely on
Countrywide's disclosures as to those loans being
included in the securitization; right?
MS. CONCANNON: Overbroad, incomplete
hypothetical.
MR. SELENDY: You can answer.
MR. TU: Calls for speculation.
MR. SELENDY: There's no point in a
stipulation if everybody's going to say the same
thing, guys.
Q. You can answer the question.
MR. TU: Those are all separate grounds for
objection. That's the point. The stipulation is to
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had access, the buyer or the insurer, had access at

a loan-level basis to all of the information they
needed that went beyond the reps and warranties, if
that was the case.
BY MR. SELENDY:
Q. In fact, sir, investors and monoline
insurers did not have access preclosing to the loan
documentation that Countrywide held; isn't that
right?
MS. CONCANNON: Incomplete hypothetical.
BY MR. SELENDY:
Q. You just said that they had access, but
that's not the case, is it, sir?
THE WITNESS: Loans are not securitized
preclosing. You cannot -- you cannot securitize
something you don't own or have. It only becomes a
securitizable asset unless it's closed. Once it's
closed, all the documents are available.
MR. SELENDY: Right.
Q. So preclosing the insurer does not have
access to the loan files which are held by
Countrywide; correct?
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state the grounds.

MR. SELENDY: No, the point of the
stipulation was to allow one of you to speak, and it
would cover all grounds. But if you want to undo
the stipulation, we can do that. One way or the
other, I just want to move forward.
MR. TU: So you're saying a simple
objection covers all conceivable objections?
MR. SELENDY: Can we -MR. TU: Is that what you're saying?
Otherwise, in California you're required to state
the grounds for your objection.
MR. SELENDY: Okay.
MR. SIEGEL: I just think he didn't hear me
because someone was talking over me, counsel.
MR. SELENDY: Can you -- can you repeat the
question?
(Whereupon the record was read as follows:
"Q. And so in deciding whether to insure
or invest, the insurer and investor had to rely
on Countrywide's disclosures as to those loans
being included in the securitization; right?")
THE WITNESS: I would -MS. CONCANNON: Same objections.
THE WITNESS: I would think so. I wasn't
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involved in the process. You know, as a general

comment.
But again, I -- I think the overwhelming
issue here is that MBIA or any of these insurers or
investors are sophisticated insurers and investors
who are familiar with credit risk and credit quality
and had every right and responsibility on a
loan-level basis, if they were concerned, to go into
the files after closing and look at what they're
insuring or buying. We never prevented anybody from
doing that.
157767882 through 87. This is a fairly lengthy
e-mail exchange. I'm going to direct your attention
just to your e-mail, which starts on page 6885.
It's entitled "Bank Assets."
attached hereto.)
THE WITNESS: Okay.
BY MR. SELENDY:
Q. Okay. You are in this e-mail expressing
views to Carlos Garcia as to what assets should be
held in the Countrywide Bank; correct?
A. That's correct.
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And you say:

"In fact, if there was little to no growth
over the next six months until we can assure
ourselves of high quality performing assets, I
would be the supporter of little to no growth."
That was a statement you made only as to
Countrywide Bank and not as to Countrywide Home
Loans generally; right?
THE WITNESS: I was -- this was related to
the bank.
BY MR. SELENDY:
Q. It was a different concern for the bank
than for the loans that Countrywide was
securitizing; correct?
evidence and prior testimony.
THE WITNESS: There's a couple things I
want to point out. First of all, I'm the CEO of
Countrywide, not MBIA or the insurers or the
investors. They should be concerned about the same
things I'm concerned about. The same information
that I'm accessing is available to them. So I'm not
operating in a vacuum. I'm responding to what I'm
feeling and seeing and hearing in the environment,
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Q. And you say, in the second paragraph:

"We must therefore rethink what assets
should be putting into the bank."
You go on to say as to pay-options:
"The focus should be 700 and above
(owner-occupied) for this product. The simple
reason is that when the loan resets in five
years, there will be an enormous payment shock.
And if the borrower is not sufficiently
sophisticated to truly understand this
consequence, then the bank will be dealing with
foreclosure and potentially a deflated real
estate market. This would be both a financial
and reputational catastrophe."
Do you see that?
A. Uh-huh.
Q. This is another observation and warning to
your senior management; correct?
THE WITNESS: And also to -- I made this
public.
MR. SELENDY: Yes.
Q. And you say, in the following paragraph:
"Frankly, I'm no longer concerned about the
pace of growth of the bank."
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reading about. The CEOs of these other companies

should be as responsible and sensitive and
reactionary as I was. So this was not done as
mysteriously.
Secondly, my concerns here -- two things.
Because you can't have it both ways, either. You
can't accuse me of not being concerned about risk or
concerned about production. When I say here I don't
care about production, I care about risk. So my
concern about risk is clear here, and that emanated
whether it be the bank or whether it be Countrywide,
because we -- we had -- we had risk in Countrywide
Home Loans, the same risk. We have a contingent
liability.
So the third thing I want to point out is I
was wrong here. These loans didn't default because
interest rates rose, interest rates have collapsed.
The interest rate on these pay-option loans is
virtually zero today that people are paying.
So very often my observations are not
correct, and that's why I distribute it to my
people, so they can react to it. So -- and in terms
of Dade County and Broward County, I made that
public. Countrywide was no longer doing loans in
those areas. It's not that we were doing loans and
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securitizing, we weren't doing the loans.

So you have to take the entirety of this
e-mail and not suppose that I was not concerned
about Countrywide Home Loans, because I was equally
concerned about what was going on at Countrywide
Home Loans as I was here in the bank.
BY MR. SELENDY:
Q. In fact, sir, you were more concerned about
the loans retained on the bank than you were about
the quality of the loans that Countrywide was
securitizing; isn't that the truth?
A. That's not the truth.
BY MR. SELENDY:
Q. Isn't it the truth that you insisted that
the bank retain higher quality loans than
Countrywide was prepared to securitize and sell off
to investors and insurers?
THE WITNESS: That's not the truth.
BY MR. SELENDY:
Q. Sir, your testimony is -MR. SIEGEL: Hold on. Let him finish his
answer.
///
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the puzzle. The other part of the puzzle is

management carrying out its due diligence to make
certain that it knows and understands what it's
buying, because, my understanding is, looked at the
MBIA documents, is they're attesting to their
shareholders that they're prudent underwriters, that
they're diligent underwriters.
BY MR. SELENDY:
Q. Let me show you a document that's been
previously marked as Exhibit 1344. It's a
continuation of some other individuals of the same
sequence, starting with your e-mail about bank
assets.
A. What am I supposed to be looking at here?
Q. In the second e-mail down, on the first
page, Mr. Sambol's writing back saying, in response
to this chain that you began:
"While it makes sense for us to be
selective as to the loans which the bank
retains, we need to analyze the securitization
implications on what remains if the bank is
only cherry picking and what remains to be
securitized/ sold is overly concentrated with
higher risk loans. This concern and issue gets
magnified as we put a bigger percentage of our
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BY MR. SELENDY:
Q. Go ahead.
A. There's several issues here. One, again,
is that the management of these investors and
insurers had a responsibility to look at what they
were insuring or buying, examine it. That's their
responsibility, that's the responsibility themselves
as a company and to their shareholders.
Secondly, I had regulatory issues at the
bank that I didn't have at the mortgage company. I
had to be very concerned about what was going into
the bank because I didn't want to violate any of the
regulations or any of the mandates that they imposed
upon the bank. So I had to look at both of them
differently.
Q. MBIA, like other insurers, looks at what
Countrywide represents to be true, doesn't it?
BY MR. SELENDY:
Q. That's the whole point of representations
and warranties, isn't it?
MR. SIEGEL: Argumentative, calls for
speculation.
THE WITNESS: Seems to me that's part of
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pay-option production into the bank because the

remaining production then increasingly looks
like an adversely selected pool."
That was his response to the e-mail
sequence that you started; right?
A. Right.
Q. And in -- in response to Mr. Sambol, you
wrote back saying:
"I absolutely understand your position.
However, there's a price we will pay no matter
what we do. The difference being that by
placing less attractive loans in the secondary
market, we will know exactly the economic price
we will pay when the sales settle. By placing
even at 50 percent into the bank, we have no
idea what economic and reputational losses we
will suffer, not to say anything about
restrictions placed upon us by the regulators."
That's your response; right?
A. Right.
Q. And so you said yes, adverse selection is
the way you want to go because at least that way you
know the price to be paid in the secondary
securitization market -MR. SIEGEL: Argumentative.
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BY MR. SELENDY:
Q. -- isn't that true?
MR. SIEGEL: Argumentative and misstates
the document.
BY MR. SELENDY:
Q. Isn't that exactly what you say?
MR. SIEGEL: It misstates the document.
MR. SELENDY: No speaking objections.
MR. SIEGEL: That's not -- let's not add
three words and say isn't that what the document
says when we're looking at the document and those
word don't appear. That's lying.
MR. SELENDY: I've noticed, Mr. Siegel,
that you have a tendency to both answer questions to
the witness and give speaking objections in prior
depositions. I'm just putting you on notice that
we'll have the judge be the judge of that.
MR. SIEGEL: That's fine. The judge will
be the judge of that.
MR. SELENDY: Limit yourself to one-word
speaking objections.
MR. SIEGEL: You have a tenancy, sir, to
argue with the witness and invent things that aren't
there and say that's what it says.
MR. SELENDY: Okay.
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their perspective and put a price on that risk.

That's the common way that banks holding assets
determine what's the value of those assets in
portfolios. You don't know until you get to a sale
position when you have to sell.
I was -- the end result of this is that we
did nothing. That's why we have this iterative
process at Countrywide, the back-and-forth process.
We held to the restrictions placed on us by the -by the regulators and sold the balance in the
secondary market because of the concerns raised by
Dave Sambol.
BY MR. SELENDY:
Q. When Mr. Sambol is raising concerns of
cherry picking assets, that's the same as raising a
concern of adverse selection, isn't it?
Mischaracterizes the document.
THE WITNESS: As I said, we didn't go that
route.
BY MR. SELENDY:
Q. That's the same thing, isn't it, cherry
picking, adverse selection?
MS. CONCANNON: Objection. Lacks
foundation.
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MR. SELENDY: I reserve my rights, sir.
Please follow the rules in this jurisdiction as
in -MR. SIEGEL: You too.
MR. SELENDY: Again, Mr. Mozilo, I would -MR. SIEGEL: No jurisdiction permits that.
MR. SELENDY: Are you done? I'd like to
have my question read back. Both of the two
questions. I think I was interrupted.
(Whereupon the record was read as follows:
"Q. So you said yes, adverse
selection is the way you want to go
because at least that way you know the
price to be paid in the secondary
securitization market; isn't that true?
Isn't that exactly what you say?")
MR. SIEGEL: Misstates the record and
the -MR. CLOSE: Objection. Cumulative.
THE WITNESS: Adverse selection wasn't the
theme of my proposal. One of the ways we determined
the value of what we're holding in our portfolio is
by selling into the secondary market. We're relying
on the secondary market to assess the risk from
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THE WITNESS: I'm really not, you know,
equipped intellectually to tell you whether cherry
picking, adverse selection are one and the same. I
don't know.
MR. SELENDY: Okay.
Q. Did you ever receive Internal Audit reports
from time to time?
A. I did.
Q. Did you take those reports seriously?
A. I took all reports seriously.
MR. SELENDY: What number are we on?
THE REPORTER: 1404.
12527229 through 41.
attached hereto.)
BY MR. SELENDY:
Q. I'm going to ask you about the second
attachment, which is the actual Internal Audit
dependent review, dated October 19th, 2004.
If you would turn to page -- well, first:
You're on the distribution of this Internal Audit
department review; correct?
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MR. SIEGEL: Why don't we have a page

number on the record, counsel.
MR. SELENDY: Ends in 232.
MR. SIEGEL: You said the second document.
He looked on one.
THE WITNESS: Yes.
BY MR. SELENDY:
Q. And if you would turn to the findings,
"Findings, Recommendations, Management Action Plan,"
which begins on page 5 of that document, Bates
number ending 237. The first finding, which is
classified as moderate risk, is the following:
"Controls over underwriting policy
exceptions do not sufficiently mitigate the
credit portfolio risk."
And the Internal Audit department goes on
to say:
"For 2004, CMD has established a target to
achieve a 20 percent growth in purchase market
share, with a final market share of 5.25
percent or more. One component of the
strategic plan is -- is to 'price all salable
loans' using risk-based pricing. In order to
implement risk-based pricing, the SLD was
created to review underwriting policy
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THE WITNESS: Wasn't specifically aware of
that policy, but it sounds logical to me. That's
what we do.
BY MR. SELENDY:
Q. And do you recall how you responded, if at
all, to the finding that controls over underwriting
policy exceptions do not sufficiently mitigate the
credit portfolio risk?
A. There was a whole team of people that this
went to, as you see. Those people all assigned to
taking the corrective action necessary to get it
corrected.
Q. Who was the head of the Internal Audit
department?
A. I don't recall.
MS. CONCANNON: Objection. Vague as to
time period.
BY MR. SELENDY:
Q. Do you -- do you recall at any point
between 2004 and 2008 who the head of the Internal
Audit department was?
A. No.
Q. Did you ever speak with the head of the
Internal Audit department?
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exceptions, make a decision to approve, decline

or provide a counteroffer, and assign price
add-ons based on the level of risk associated
with the exception."
Do you see that?
A. Yes.
Q. First, what does "the SLD" refer to here?
A. Structured Loan Desk.
Q. Okay. And why was the Structured Loan Desk
created?
A. I believe they looked at loans that were
outside of Fannie, Freddie, FHA and VA eligible
loans.
Q. Were they specifically created to review
exception loans?
A. I don't believe so, but I don't know.
Q. Do you understand the reference to the
strategic plan to, quote, "price all salable loans"?
THE WITNESS: No.
BY MR. SELENDY:
Q. Were you aware of any strategy by which
Countrywide had determined that it would price all
loans that couldn't be securitized into the
secondary market?
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A. I'm sure I did.

Q. But it wasn't sufficiently important for
you to recall who that person was?
testimony.
THE WITNESS: We had a large organization.
It was complex. Also many years have gone by. My
memory has faded. I left the company four years
ago, so I don't specifically remember everybody that
was in the organization. This was very important to
me. I wouldn't have employed the resources
necessary to -- and put the team together -- unless
it was important. Everything was important to me.
BY MR. SELENDY:
Q. Do you recall whether you made any effort
starting in 2004 and thereafter to increase the
resources that went to the Internal Audit department
as you were in the period of aggressive expansion of
market share?
THE WITNESS: I don't recall, but I -- I
know -- I feel confident that every area of the
company was strengthened as well as that area.
Again, I repeat, that I not only had an emotional
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attachment to this company, I had a financial

attachment to this company.
BY MR. SELENDY:
Q. What were you compensated, your total
compensation in 2004? Do you remember?
A. No.
Q. 2005?
A. No.
Q. 2006?
A. No.
Q. Was your 2007 compensation in excess of
$140 million?
THE WITNESS: Sounds like a lot to me. I
don't think so, but I don't know.
BY MR. SELENDY:
Q. Was it over a hundred million dollars?
A. I don't know.
Q. Was it over $50 million?
A. Let's take the compensation apart for a
second. I was paid around $2 million a year, I
believe, 2 or 2 1/2 million a year base salary.
Everything else I received was based upon earnings
and stock price, period. So anything above the $2
1/2 million or $2 million, whatever that number was,
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BY MR. SELENDY:
Q. Most -- most people would know, don't you
think, whether they made more than a hundred million
dollars in a particular year?
MR. SIEGEL: The question is argumentative.
You don't have to answer that. That's
harassing.
THE WITNESS: My focus was on the company,
not on my compensation. I wanted to make sure the
company came first. And so I don't know what I
made.
CWMBIA-G110171.
attached hereto.)
BY MR. SELENDY:
Q. By the way, did you receive -- did you
enter into any severance agreement with Bank of
America?
MR. CLOSE: Objection. Vague, ambiguous,
lacks foundation.
THE WITNESS: Severance agreement?
MR. SELENDY: Let me -- let me restate
that.
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was based upon the performance of the company, was

performance-related.
It was also what they counted in that. I
had a lot of stock and a lot of options over the 40
years, many of which I had never exercised. And I
was getting close to retirement and so I was
exercising options, and when you exercise those
options, it's counted as part of your income.
So it's not income as you're trying to
convey here. It wasn't salary. My salary was 2
1/2 -- 2 to $2 1/2 million.
Q. Sir, the money that you got from
Countrywide, whether through cash or options or
otherwise, exceeded a hundred million dollars in
2007; isn't that true?
A. I don't know.
answered.
BY MR. SELENDY:
Q. You just don't know?
A. I just don't know.
Q. Do you know what -- do you know whether in
2006 it exceeded a hundred million dollars?
THE WITNESS: I don't know.
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Q. Did you enter into any agreement with Bank

of America upon the sale of Countrywide to Bank of
America?
A. The only agreement I -MR. CLOSE: Objection. Vague and
ambiguous, lacks foundation.
THE WITNESS: The only agreement I entered
into was I gave them back $40 million of my money
that was due to me under the contract for change of
control. I gave it back to Bank of America to save
jobs.
BY MR. SELENDY:
Q. Did you enter into any agreement to
testify?
THE WITNESS: Any agreement to what?
MR. SELENDY: To testify.
THE WITNESS: I don't recall any such
agreement.
BY MR. SELENDY:
Q. You don't recall at any point agreeing with
Bank of America that you would testify in
depositions if asked?
A. I might have. I don't know.
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Q. Okay. Let's take a look at this document.

A. I read it.
Q. Okay. This is an e-mail that you sent to
Dave Sambol, Steve Bailey and Stan Kurland as of
September 17, 2005; correct?
MR. PETTIT: Objection. Misstates the
document.
BY MR. SELENDY:
Q. Isn't that correct?
A. It's a memo, appears to be a memo, I sent,
yes.
Q. And the subject of your e-mail is "Loan
Quality"; correct?
A. That's correct.
Q. You say in the first line:
"In light of the focus on 'exotic loans,'
and to make certain that we are always
originating in a responsible manner, you and
your staff should be reviewing monthly the
performance of all seasoned loans by category."
Do you recall what you meant by "the focus
on exotic loans"?
A. I believe I meant the public commentary
about all the new product that was out there. It
was in the media. It was at conferences I attended.
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because we didn't know how loans would perform once

we made them. Had no idea. Particularly if you're
going into new types of loans.
And so I'm encouraging him to do the same
thing I did for 40 years, is contact the head of
servicing on how are loans performing. And where
certain types of loans are not performing, stop
them. Change the credit underwriting or stop making
them. That is a clear indication of my concern in
the mortgage company, not a bank, about the quality
of loans, whether it be securitized or put into
the -- put into the bank.
BY MR. SELENDY:
Q. I showed this document to you, sir, and one
of my questions is whether you were warning David
Sambol to be careful of too much of an emphasize on
production at the expense of loan quality.
A. I said to the public that we would never
compromise quality for volume. It was a public
comment I made both in investor conferences,
teleconferences, to the media. It was a constant
theme at Countrywide. Never compromise volume for
quality.
Q. Were you concerned that David Sambol didn't
share the same focus that you had?
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So prime issue, pay-option issue, all of these

issues were a focus of a lot of these meetings I
attended and also in the media.
Q. So what -- what loan types would fall
within that?
BY MR. SELENDY:
Q. You mentioned subprime and pay-option.
Were there others as well?
THE WITNESS: Well, I didn't consider
pay-options to be exotic, but there were various
types of loans that were categorized as exotic
loans, and I don't recall exactly what they were,
but it was anything that -- 125 percent loan, for
example, exotic or stated income loans may have been
perceived that way. I mean, I didn't have a
definition for it, but I was concerned enough to -Again, your allegation about me not being
concerned about quality in the mortgage company is
certainly impacted by this e-mail where I'm very
concerned about quality. Always been concerned. I
said from the beginning of the company, from day
one, I was always in touch with the head of
servicing to find out how loans were performing,
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MR. TU: Objection. Vague.

THE WITNESS: Not at all. Where I was -he was new to this position. It was a position I
held for all these years, and I wanted to give him
some direction as to how he could -- the best way to
monitor quality is to see how these loans perform.
BY MR. SELENDY:
Q. At the end of your e-mail, after giving him
advice, you say:
"An undisciplined intake of loans over a
protracted period of time solely for
production's sake will ultimately create an
unwanted burden for our company."
And that's obvious; right?
A. It's axiomatic. Another warning.
12263394 through 3402.
attached hereto.)
THE WITNESS: What's your question?
BY MR. SELENDY:
Q. Okay. First, in the e-mail, at the top,
Mr. McMurray writes to Nick Krsnich and states, in
the second paragraph:
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"Keith" -Referring to Keith McLaughlin.

-- "Keith told me that Angelo had asked him
whether our credit risk was increasing or
decreasing. I told Keith that I thought our
credit risk was increasing and prepared this
e-mail to provide further explanation."
Referring to an e-mail he wrote in
September of 2004.
"This e-mail was also shared with bank
management and Carlos, Jim, etcetera. At the
same time I provided it to Keith since the bank
is one of the key areas where we're growing
credit risk. I don't know whether Keith shared
my e-mail directly with Angelo or just had a
discussion."
So my first question is: Did
Mr. McLaughlin share this e-mail, the below e-mail,
directly with you, or did he have a discussion with
you?
A. 2004?
THE WITNESS: Seven years ago? I'm sorry.
BY MR. SELENDY:
Q. You don't know?
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that risk is increasing both here at

Countrywide and in the industry in general,
please consider my opinion in the following
context. We generally earn an expected return
for retaining credit risk. We realized
diversification benefits since this return is
not -- is well-consistent with other risks we
face, primarily interest rate risk. Many of
the factors driving the increase in credit risk
are the result of economic forces. In
addition, the trends we're seeing are evident
throughout the market. They're not unique to
Countrywide. Increases in our credit risk
position may be the most attractive opportunity
in the current market to sustain and grow
earnings."
This is from my credit risk officer. I
took comfort in this.
Q. Okay. So you do believe you heard, if not
this e-mail, you heard similar things from your
credit risk officer?
THE WITNESS: That's my recollection.
BY MR. SELENDY:
Q. Okay. And specifically you agreed that
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A. I don't have any recollection whatsoever.

Q. Okay. Looking at the underlying e-mail
from Mr. McMurray, do you have any recollection of
that e-mail?
THE WITNESS: I don't.
MR. SELENDY: Okay.
Q. Mr. McMurray was, both in 2004 and 2005,
the chief of credit risk; correct?
A. That's correct.
Q. And in his September 2004 e-mail, he is
giving his own warnings that basically credit risk
is increasing; right?
BY MR. SELENDY:
Q. That's what it states in the first line of
the document; right?
A. I rather -- yes, it does state that in the
first line of the document, but it also then goes on
to say why that risk is a prudent risk. And I want
to read that for the record.
"First of all, I'm going to point out,
again, another indication of my concern over
risk in the mortgage company. While I do think
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increasing credit risk to grow earnings was an

appropriate strategy for Countrywide at this time?
A. A prudent and monitored increase in credit
risk, if properly managed, could increase earnings.
Q. Okay. And if you turn to the next page of
Mr. McMurray's e-mail, I take it you also agree with
his statement that, "Loan quality throughout the
primary market is deteriorating due to competitive
factors and an excellent housing market, coupled
with very favorable credit performance over the past
several years."
MR. SIEGEL: You're asking him today?
BY MR. SELENDY:
Q. Did you agree with that as of September
2004?
THE WITNESS: I don't know if it was 2004,
but you showed me an e-mail where I said the same
words.
MR. SELENDY: Right.
Q. And specifically he states, "Underwriting
standards for collateral and borrowers have become
more aggressive"; that's true, right?
THE WITNESS: I'm going by his statement,
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yeah. It appears to me it was true at the time.

BY MR. SELENDY:
Q. And he also states:
"More loans are being originated under
riskier loan programs (e.g. ARMs) with riskier
features (e.g. low no doc IO) and at higher
CLTV/LTVs."
That's also a true statement; right?
THE WITNESS: I'm taking -- I'm accepting
this document as what it says.
BY MR. SELENDY:
Q. And in the section below that he says:
"Our loan and execution mix is deteriorating
along with the rest of the market."
That's correct as well; right?
THE WITNESS: But I think you're ignoring
his first summary, but all of this leads to that.
BY MR. SELENDY:
Q. And in Section 5-E, Mr. McMurray states:
"We should judicially choose the
opportunities to take additional credit risk."
That's fair; right? You were trying to
decide what kind of credit risk you wanted to keep?
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BY MR. SELENDY:
Q. -- right?
MS. CONCANNON: Mischaracterizes the
document, lacks foundation, assumes facts, calls for
speculation.
THE WITNESS: Yeah, I don't know
specifically what he -- what he meant here. I'm
just -- I don't -- let me -- let me frame this, this
way, because you're down the same track over and
over again.
It's very easy for you in 2011 to judge
what we did in 2004. The decisions we made in 2004
was our best judgment for what we knew at that time.
We had no idea, obviously, like anyone else, that we
would have a market disruption of the magnitude that
we had.
The second thing that was important to us
was validation. If we're unable to sell the product
to the secondary market, the secondary market would
send them a clear message: This is unacceptable
risk. But MBIA and all the other monoline insurers
were a validation point for us, is this product
okay, is this product acceptable. Not only
validation for us, but was a validation for the
rating agencies, which assumed that the proper due
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THE WITNESS: Had nothing to do with what
we were going to keep and going to sell. This is
totally unrelated to that.
MR. SELENDY: Okay.
Q. Well, let's look at 1-A under the more
detailed summary. Under 1-A, "Context," "Expected
Return," he states, subpoint 1, "Opportunities to
Consider," and then subpoint 2, "Opportunities to
Avoid." And under "Opportunities to Avoid," he
says:
"We should avoid those 'opportunities' to
take credit risk which do not provide an
adequate return. For example, most of our Fast
& Easy production is done with no risk-based
pricing adjustment, even though we now know it
performs worse than comparable loans without
this feature. We plan to continue selling this
particular, uncompensated risk, away."
That's what he says; right?
BY MR. SELENDY:
Q. That has to do with judicially choosing
which opportunities to keep and which to sell -MS. CONCANNON: Objection.
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diligence was being done by the monoline insurers.

So these were all -- the sale of loans was
always a validation in price and in quality for us.
And the fact that we decided to -- to manage our
risk in such a way to sell certain loans into the
secondary market that we felt was beyond our risk
profile was a management decision, and it should
have been a management decision whether or not
people wanted to buy it or insure it.
BY MR. SELENDY:
Q. So boiling that down, I take it you agree
that, in fact, there was a decision to choose to
keep the better risk and sell away the risk that you
didn't want to retain?
the testimony.
MS. CONCANNON: And asked and answered.
THE WITNESS: Whether or not it was greater
risk would only be determined later on whether or
not these loans performed, and we had no way of
determining how they ultimately would, in fact,
perform. We had to rely upon the appetite of the
secondary market to determine whether they thought
they were going to perform or not.
We had our judgment; they had their
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judgment. Their judgment was to buy it because they

thought it was profitable to buy it. Their judgment
was to insure it because it was profitable for them
to insure it.
BY MR. SELENDY:
Q. You did have a judgment as to expected
performance; right?
argumentative.
THE WITNESS: We had judgment for expected
performance. Some of those judgements were correct
and some were incorrect. For example, in the
pay-option loans, our judgement was interest rates
were going to rise and have substantial resets. It
never happened.
BY MR. SELENDY:
Q. And based upon your expectations as to risk
and performance, you engaged in a strategy to
securitize away the riskier products and retain the
higher quality products; right?
overbroad, argumentative, mischaracterizes prior
testimony, assumes facts.
THE WITNESS: I think that's overly
simplistic because our balance sheet, we had NIMS,
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particularly the market's move to more

aggressive underwriting guidelines, have
increased credit risk."
And then he goes on to explain why.
Q. Now, you would agree with that statement;
right?
BY MR. SELENDY:
Q. His statement that developments in loan
quality, particularly the market's move to more
aggressive underwriting guidelines, have increased
credit risk.
THE WITNESS: I would think so.
MR. SELENDY: Okay.
Q. And then if you would turn to page 399,
Bates number ending 399, under the overall heading
"Loan Mix," he describes the nonconforming loans
under subsection C, toward the bottom of the page;
do you see that?
A. Yes.
Q. He states, under the term "loan quality,"
he says:
"Guidelines have become more aggressive in
all of the dimensions described in loan quality
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we had subprime residuals that we did securitize.

We kept product on our balance sheet that was not
securitized. We also were limited what we could
keep in the bank. So we had -- we had structural
issues that we had to deal with, so we had no choice
in many cases but to sell into the secondary market.
BY MR. SELENDY:
Q. More aggressive guidelines obviously
increase credit risk, other things being equal;
right?
overbroad, incomplete hypothetical, lacks
foundation.
THE WITNESS: Again, overly simplistic.
Increasing the maximum loan that we would accept
could be perceived as a credit risk by some and not
by others. So, again, it's taking something very
complicated and trying to oversimplify it, and I
can't respond to that.
MR. SELENDY: Okay. Let's look at what
your chief credit officer said on page 397, under
the heading "Loan Quality," point 3 on that page.
He states "loan quality," and then he says:
"Loan quality is a significant credit risk
factor. Developments in this vein,
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above. Furthermore, the portion of our

nonconforming loans that are expanded criteria
has increased."
Those are accurate statements; right?
THE WITNESS: I can only assume they are.
I mean, I don't know. I've got nothing to measure
against.
BY MR. SELENDY:
Q. And then on the last page of the document,
402, under his subheading F for "Credit
Initiatives," subpoint 4 states:
"Shore up R&W defenses, rep and warranty
defenses."
And he says:
"We are working with legal to shore up our
defenses against repurchase indemnification and
claim denial requests as a result of alleged
representation and warranty breaches."
Do you see that?
A. Huh?
BY MR. SELENDY:
Q. Are you aware of an initiative by your
credit risk department to increase the hurdles to
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investors and insurers in making representation and

warranty put-back claims?
Mischaracterizes the document, assumes facts not in
evidence.
THE WITNESS: I was not aware of this at
all.
MR. SELENDY: Now, we can continue on or
break for lunch, as you choose.
MR. SIEGEL: Do you want to take your
break?
THE WITNESS: I want to point out, however,
all of this is done to protect the company, as
investors, insurers should have done to protect
their company. This is just to protect Countrywide,
its interests, its integrity and shareholders.
That's the purpose of this.
MR. SELENDY: Would you like to continue on
or have lunch?
THE WITNESS: Where are we?
MR. SIEGEL: If we -- if we break now, it's
before he starts a new area, and my guess is you'd
prefer -MR. SELENDY: I don't care. It's entirely
up to you.
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WESTLAKE VILLAGE, CALIFORNIA; TUESDAY, JUNE 21, 2011

1:10 P.M.
THE VIDEOGRAPHER: We're back for the

afternoon. This marks the beginning of Videotape
No. 3 in the deposition of Angelo Mozilo. Time on
the video monitor is 1:10.
FURTHER EXAMINATION
BY MR. SELENDY:
Q. Mr. Mozilo, was Ron Kripalani one of the
senior managers that you supervised?
A. Yes.
Q. What was his responsibility?
A. He was head of Countrywide Securities.
Q. Okay. Would he report to you from time to
time as to the activities at Countrywide Securities?
MR. HAMILTON: Vague.
THE WITNESS: We would have discussions
when I went down to his office to ask what was going
on from time to time.
BY MR. SELENDY:
Q. Okay. What type of direction would you
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THE WITNESS: I would like to break for

something to eat. Fifteen minutes, 20 minutes.
MR. SIEGEL: We'll need a little more time.
MR. SELENDY: Half an hour. Whatever time
you need.
MR. SIEGEL: I don't know what we'll need
to get food there. Forty-five minutes.
THE VIDEOGRAPHER: Off the record. The
time is 12:13.
(Lunch recess.)
///
///
///
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give Mr. Kripalani?

MR. HAMILTON: Objection. Vague.
THE WITNESS: Frankly, I don't recall
having to give him any substantial amount of
direction. He was a world-class executive, and I
wasn't involved in the securities operation. He ran
it. I think most of his interaction, I believe, was
with Stan Kurland.
BY MR. SELENDY:
Q. Let me show you a document previously
marked as Exhibit 107. My first question on this
document will be whether you've seen it before. On
the page ending 805 it states "Countrywide Financial
Secondary Marketing Department Securitization Policy
and Procedures Manual."
A. I don't recall ever seeing it.
Q. Okay. I'll just ask you, then, about a
couple of statements on the page ending 807. Under
the heading "Permissible Securitization Activities,"
the manual states, quote:
"The CFC Asset Liability Management
Committee (ALCO) holds primary responsibility
for creating and implementing policies and
procedures to achieve CFC's asset liability
goals and objectives as prescribed by the
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board. As all securitization activity is

included in CFC's asset liability activity,
ALCO holds oversight responsibility for
securitization procedures, policies and
approvals."
Are those statements accurate as to the
function of the CFC Asset Liability Committee?
MS. CONCANNON: Lacks foundation.
BY MR. SELENDY:
Q. Did you -- were you ever part of the Asset
Liability Committee?
A. I don't believe so.
Q. Did you oversee the function of that
committee in your capacity as CEO of Countrywide
Financial?
MR. SIEGEL: Question's vague, calls for a
legal conclusion.
THE WITNESS: No, I don't recall being
involved in that committee.
BY MR. SELENDY:
Q. You don't recall any oversight function
that you had with respect to that committee?
A. I don't recall, no.
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Mr. Sambol states:

"These percentages of low to no down
payment purchase transactions and related
first/second mortgage financing structures has
not been unique to Countrywide. These programs
have been pervasively offered in the
marketplace by our competitors on both the
prime and the subprime side. In fact, it's our
view that the broad availability of high LTV
and hundred percent financing in part fueled
the housing boom of the last several years."
Do you see that statement, those
statements?
A. Uh-huh.
Q. And is it correct, in your understanding,
that the programs with low to no down payment were
pervasively offered not just by Countrywide but also
by Countrywide's competitors?
THE WITNESS: I'm not aware of it
personally. I'm just going by the statements in the
document, e-mail.
BY MR. SELENDY:
Q. Did Mr. Sambol discuss with you
Countrywide's view that the broad availability of
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Q. Okay. Show you a document that has been

previously marked as Exhibit 1172. This is an
e-mail from David Sambol to yourself, dated March
24th, 2006.
Okay. As of early 2006, had you asked
Mr. Sambol what percentage of Countrywide -Countrywide's loans had low or no down payment
financing?
A. I don't recall.
Q. Is that the subject of this e-mail?
THE WITNESS: The subject of the e-mail's
hundred percent financing, is what it says.
BY MR. SELENDY:
Q. Okay. In the first sentence, it says:
"Angelo, you seem surprised by the estimates
I conveyed regarding the percentage of purchase
deals with little or no equity."
Do you see that?
A. I do.
MR. TU: Objection. Misstates the
document.
BY MR. SELENDY:
Q. And then in the second to last paragraph,
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high LTV and a hundred percent financing, in part,

fueled the housing boom?
A. I don't recall.
Q. Does it make sense to you that it would?
A. It makes sense to me -MS. CONCANNON: Objection.
THE WITNESS: -- that the demand for
housing caused the housing boom.
BY MR. SELENDY:
Q. And the supply of mortgages at high LTV and
hundred percent financing helped facilitate that
boom; right?
MS. CONCANNON: Objection. Calls for an
expert opinion.
THE WITNESS: Well, my only response to
that is I don't believe so because zero down
financing by the VA and 3 percent down by the FHA
has been available since 1934.
BY MR. SELENDY:
Q. That wasn't available to all Americans, was
it, sir?
A. Yes. Even non-citizens.
Q. So did you tell Mr. Sambol well, I disagree
with you, your view, that this fueled the housing
boom?
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A. Five years ago, I have no idea what -- what

I said or if I said anything.
Q. Okay. I couldn't find any disagreement
with the e-mail, so I'm asking.
MR. SIEGEL: There's no question.
MR. SELENDY: So let's mark as Exhibit 1407
CWMBIA 15971512 to 1513.
attached hereto.)
THE WITNESS: Okay.
BY MR. SELENDY:
Q. Okay. Do you recall this e-mail exchange
with John McMurray?
A. No.
Q. If you'd look at the e-mail from
Mr. McMurray to yourself on page 1512, he writes:
"I was very happy to see your e-mail
because I personally share the same sentiment
that we should be shedding rather than adding
pay-option credit risk to the portfolio."
And then he goes on to explain why.
If you look at point 3, do you see the
heading "Deteriorating Credit Environment"?
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just looking at Furash's response to me, which says,

you know, he stopped buying loans.
BY MR. SELENDY:
Q. Okay. And I was asking you specifically
about Mr. McMurray's statement, whether you
understood that to be a warning, that the impending
down cycle could be more severe than prior
downturns -MS. CONCANNON: Objection.
BY MR. SELENDY:
Q. -- a warning coming from your chief credit
officer.
THE WITNESS: I have no recollection as to
this e-mail. I'm accepting the document for what it
says.
MR. SELENDY: Okay.
Q. Mr. McMurray went on to say, under point A:
"The industry has expanded credit
guidelines aggressively during the favorable
environment. There are a lot more loans with
very high CLTVs, stated or reduced
documentation, ARMs, interest-only or
payment-option features, high levels of
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A. I do.
Q. And he writes to you, quote:
"The extremely favorable environment we've
had for credit seems to have peaked and is now
deteriorating. It's plausible that the
impending down cycle could be more severe than
previous downturns."
And this is a warning he was raising as of
September 2006; right?
THE WITNESS: Just take the document for
what it says. I have no recollection of it.
BY MR. SELENDY:
Q. And it is a warning that he's giving there,
isn't it?
THE WITNESS: It's a -- I think you left
out the first -- my -- my part was to stop buying
third-party product.
MR. SIEGEL: That's the subsequent -- I'm
not sure the witness -Did you look -- it's a two-page document,
double-sided.
THE WITNESS: Well, I'm looking at -- I'm
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investor properties, etcetera, etcetera."

That was an accurate statement at the time;
right?
THE WITNESS: I take it for what it says.
It's his statement.
MR. SELENDY: Okay.
Q. And he was reporting to you in his capacity
as chief credit officer of Countrywide; right?
A. That's correct. He was responding to the
fact that I stopped third-party originations of
pay-option loans.
Q. And then he states, under point B:
"The recent housing environment has been
extraordinarily favorable. It's been long,
strong and wide. An adjustment back to the
mean could suggest a fairly adverse housing
market."
Was that a fair statement by him?
THE WITNESS: Well, that it could, yeah.
BY MR. SELENDY:
Q. Okay. And then in the next point, he
states:
"The recent weakening we've seen in housing
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was not triggered by adverse economic

conditions. Interest rates, unemployment and
other relevant economic factors are still
favorable by historical standards."
Were those statements also fair?
THE WITNESS: This is back -- back five
years ago. I -- I don't know what was -- what were
the -- what were the employment rate. I have no
idea.
BY MR. SELENDY:
Q. Okay. When you wrote back to him, you
didn't -- you didn't say well, I disagree with your
statements, you said, "I want the bank to stop all
third-party bidding for this product" -MR. SIEGEL: Misstates the document.
BY MR. SELENDY:
Q. -- right?
THE WITNESS: The way I read it, just
reverse.
BY MR. SELENDY:
Q. Well, if you look at the time signatures,
contrary to your counsel's statement, you are
responding to Mr. McMurray, your e-mail's at 11:14
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disagreement with the views given to you by your

chief credit officer; right?
A. My chief credit officer is saying I was
very happy to see your e-mail.
Q. So in general you agreed with his
statements?
overbroad.
THE WITNESS: These were -- this was his
opinion as the chief credit officer and, you know,
again, I don't recall what my reaction was at the
time.
BY MR. SELENDY:
Q. Is it fair to say he was one of the persons
best positioned in the company to make those
assessments? Indeed, that was his responsibility?
A. That was his responsibility. Again, we all
were deeply concerned about the credit situation.
You can see e-mail after e-mail of mine in terms of
being concerned about types of loans and what's
happening and credit underwriting. You can see
those e-mails. So I share, upon looking at this, I
share his concerns.
CWMBIA 9554935 through 46.
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isn't it, and his e-mail's at 10:45 a.m.?

MR. SIEGEL: That wasn't the basis for
counsel's statement. You've asked me not to point
out, but I will, since you just misrepresented the
document. Mr. McMurray's not on the "to" line of
the document you're pointing to, claiming is a
response to him, which is a misrepresentation.
MS. CONCANNON: And the e-mail chain begins
with an e-mail dated 9/26/2006, at 10:15 a.m., from
Mr. Mozilo to Mr. Sambol.
MR. SIEGEL: Now, with all of that, Angelo,
let's have the question.
BY MR. SELENDY:
Q. Mr. Mozilo, once again, didn't you respond,
after receiving Mr. McMurray's 10:45 a.m., by
sending your e-mail, as your counsel points out, to
Dave Sambol and others that you want the bank to
stop all third-party bidding?
THE WITNESS: That's what -- this is 11:14.
MR. SIEGEL: Yes.
THE WITNESS: Yeah. Document speaks for
itself.
MR. SELENDY: Right.
Q. And so you didn't -- you didn't express
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attached hereto.)
BY MR. SELENDY:
Q. Okay. My first question is whether the
document that begins on page 4937 is a memorandum
that you provided to the board of directors of
Countrywide on December 7th, 2006.
A. Yes.
Q. Okay. What prompted you to write that
memorandum?
A. I think it says here, article in The Wall
Street Journal.
Q. You felt the article was significant enough
to warrant a report to the board of directors?
A. I think that the -- what preceded this was
a lot of media attention to these type of loans, and
it was important for me to bring the board up to
date as to our views on it, and in order to make
sure that those views were properly matched with
that of our credit risk officer, John McMurray, I
asked him to author this. So even though it's under
my name, he created this entire document.
Q. I take it when you sent it to the board of
directors of Countrywide, you agreed with all of the
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statements in the memorandum under your name.

A. Yeah, I generally -- I reviewed it and
approved it.
Q. Okay. So if we go to "Background," on the
first page, you say:
"We offer substantially all of the
residential mortgage products available in the
industry as part of our 'supermarket'
strategy."
And that was correct as of the time; right?
A. Yes, I believe so.
Q. Okay. And then if you would turn to the
second page of the memorandum, under the heading
"2006 Vintage," memorandum states, in the first
line:
"Vintage means the year in which a loan was
originated. The article asserts that 2006 will
be one of the worst vintages on record and
cites a study by UBS. We agree with this
assertion and believe that the poor performance
will be driven by the combination of wider
guidelines and the transitional economic
environment mentioned above."
See that?
A. Uh-huh.
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THE WITNESS: When this was prepared, it

was my best understanding of the facts that existed
at the time.
MR. SELENDY: Okay.
Q. Then if you'd look at the next page, under
the heading "Guideline Expansion," you state:
"Consistent with the broader industry, we
have expanded our subprime menu over recent
years. Since 2003, the industry aggressively
expanded product offerings and guidelines to
promote more purchase business."
What did you mean by that?
A. I don't know. I don't recall.
Q. What does -A. Again, I didn't author this. This was done
by -- this is -- we -- purchase business was an
important part of our -- of our product mix versus
refinances, and it was always important for us to
increase our position in the industry in terms of
purchase business. I mean, that's all I can recall
on this.
Q. Okay. Do you recall any discussion with
the board about this memorandum?
A. I believe that -- my recollection is, and
it's faint, but my recollection is I had John at
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Q. What did you mean by the reference to

"wider guidelines"?
A. We've been discussing the guidelines had -had been expanded over the years, and I think that's
been fairly well-documented in this deposition.
Q. Okay. Then if you go two paragraphs down,
you state:
"From the low set by the 2002 vintage,
performance has deteriorated in each successive
year as a result of guideline expansion."
And that statement was based on your best
understanding at the time; correct?
MR. SIEGEL: Misstates the record.
THE WITNESS: If I'm reading this
correctly, I mean, I have to -- I don't recall the
document specifically, but the -- these were the
subprime product, which was 10 percent of our
business. And the vintage issue was a -- known to
the industry, was widely distributed throughout the
industry as to expected performance of the vintages.
BY MR. SELENDY:
Q. And with those caveats, sir, is it fair to
say the statement was based on your best
understanding at the time?
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this meeting to walk through it with him and to

explain it to him since he authored it.
Q. Okay. Do you recall presenting any of the
issues in the memorandum under your name to the
board?
A. No, I do not.
Q. Was Mr. McMurray present at other board of
directors' meetings with you?
A. Yes.
Q. Do you recall the subject matter addressed
at those other meetings?
overbroad.
MR. SELENDY: Let's define it.
Q. With respect to the time period 2004 until
2008, do you recall whether he was present at other
board of directors' meetings with you?
A. I believe he was.
Q. And do you recall what subjects he
addressed at those meetings?
THE WITNESS: I would only -- I don't
remember specifically what he covered, but it would
be his area of expertise, and also he reported
directly to the Credit Committee of the board, and
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so he would generally be present when the Credit

Committee was reporting to the board.
BY MR. SELENDY:
Q. How would you define Mr. McMurray's area of
expertise?
A. He was a classic credit risk officer that
had to assess risk and give his views as to what he
thought -- how he thought loans would perform in the
various categories, as best as he could determine,
and provide us with justification for his opinion,
because at the end of the day, nobody predicted a
collapse in values and nobody predicted unemployment
rates going from 5 percent to 10 percent. But
that obviously was not in the equation, but that was
his role.
Q. Did Mr. McMurray have responsibility for
the reverification of loan documentation?
MR. SELENDY: Let's mark this as Exhibit
1409. It's a copy of the 10-K, Countrywide
Financial Corporation, for the fiscal year ended
December 31, 2004.
///
///
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necessary, a fraud investigation."

And then it goes on.
Do you see those statements?
A. Uh-huh.
Q. This is part of the 10-K that you signed;
right?
A. Yes.
Q. Do you know what process, if any, was
performed relative to this point of reverification
of loan documentation?
A. I do not.
Q. What about the in-depth underwriting and
appraisal review, do you know anything about that
process?
A. I do not.
Q. How about the fraud investigation?
A. I do not.
Q. Okay. Is it accurate that Mr. McMurray, as
the chief credit officer, oversaw the quality
control department?
A. This document was put together by
attorneys, by accountants, inside and outside the
company. I assumed everything in this document is
correct.
Q. Do you have any independent understanding
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attached hereto.)
MR. SELENDY: And for your reference, my
only question will be on page 77 of the document.
MR. SIEGEL: Counsel, based on the top or
the bottom?
MR. SELENDY: Top right-hand.
MR. SIEGEL: Okay. Because the pages don't
align.
BY MR. SELENDY:
Q. Do you see the heading "Loan Quality" at
the top of the page?
A. I do.
Q. Okay. If you would go to the last
paragraph in that heading, Countrywide's 10-K
states:
"In addition to our prefunding controls and
procedures, we employ an extensive post-funding
quality control process. Our quality control
department, under the direction of the chief
credit officer, is responsible for completing
comprehensive loan audits that consist of
reverification of loan documentation and indepth underwriting and appraisal review and, if
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of whether Mr. McMurray oversaw the quality control

department at Countrywide?
A. I just read that he did.
Q. Okay. Okay. Show you a document that's
previously been marked as Exhibit 949. This is
entitled "Internal Audit Department Review of
Enterprise-Wide Business Development and Product
Management," dated September 30th, 2006. It's
distributed to you, among many others.
And my question for you is on page 4 of the
document. It's Bates No. 7562. At the top of the
page, it states:
"Internal Audit has classified the following
as moderate risk findings: 1, formal
escalation procedures for new products or
product changes allow the chief production
officer to summarily override any objections by
the chief credit officer."
Do you see that?
A. I do.
Q. Do you have an understanding of why the
Internal Audit department flagged this as a moderate
risk problem for Countrywide?
A. No.
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BY MR. SELENDY:
Q. Did you understand that the chief
production officer could, as stated in this report
distributed to you, could override the chief credit
officer?
MR. SIEGEL: Vague as to time.
MS. CONCANNON: Lacks foundation,
mischaracterizes the document.
THE WITNESS: I had no specific knowledge
of that.
BY MR. SELENDY:
Q. Did Mr. McMurray ever explain to you that
he was not -- that his views were overridden by
David Sambol?
A. Not to my recollection.
Mischaracterizes the document, assumes facts not in
evidence.
THE WITNESS: Not to my recollection.
MR. SELENDY: Okay.
Q. Do you recall Mr. Murray ever making any
complaint that the production side of Countrywide
was given too much leeway at the expense of his
concerns as the chief credit officer?
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procedures as to loan origination and not the

quality control department?
Mischaracterizes the document, assumes facts.
THE WITNESS: I don't recall making such a
statement. I do know for a fact that there's no
reason to have product quality control or credit
underwriting if we don't have loans.
BY MR. SELENDY:
Q. What do you mean by that, sir?
A. Loans have to be originated. They're
originated through the branch system. Without that
origination process, there's no need to have a
company, so there is a importance to that operation.
Q. Meaning that quality control should not be
allowed to shut down production?
Mischaracterizes.
THE WITNESS: Well, I would say quality
control doesn't have the authority to shut down
production; otherwise, would be no, you know, no
reason to have a management team.
BY MR. SELENDY:
Q. So how would you balance the concerns of
quality control with the concerns of production?
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overbroad.
BY MR. SELENDY:
Q. You just don't remember?
12048907 to 8909.
attached hereto.)
THE WITNESS: I can't read this.
MR. SELENDY: Okay.
Q. At the top -- I'll represent to you the top
line states, in the e-mail from you:
"The bottom line is that the driving force
of this company must emanate from the branches
and not from QC."
I don't know if that helps you at all in
being able to decipher the rest of the document.
A. No, I can't read it.
Q. Okay. Do you ever recall -- sorry, do you
recall ever making the statement that it is the
branches of Countrywide that should control
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A. It's day to day. You know, it's day-to-day

review of the company's operations, trying to keep
things in balance, trying to keep -- make sure that
we have sufficient originations to support the
economics of the company, and on the other hand make
sure it's a quality product that won't cause a
financial problem for the company. But it's a
day-to-day, hour-to-hour responsibility of the CEO
and the management team.
MR. SELENDY: Okay. We can mark as Exhibit
1411 CWMBIA 11468069 through 8070.
attached hereto.)
MR. SIEGEL: Mr. Mozilo, you should know
it's a two-sided document, and it begins with the
e-mail strings, so all of these do begin from the
bottom up.
THE WITNESS: Okay.
BY MR. SELENDY:
Q. Starting with the last e-mail on -- in this
document, which is the first in the timing of the
chain, is it fair to say that you were writing to
Mr. Garcia, asking why the bank has increased loss
reserves as of April of 2006?
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Q. Okay. And Mr. Garcia responds to you in
the second paragraph of his e-mail, he says:
"The 2005 book has seen a slight decline in
the weighted average FICO and equity of the
collateral (increase in LTV) coupled with
significant expansion of reduced documentation
underwriting. As predicted, the aforementioned
risk factors have resulted in the 2005 book
experiencing faster development of defaults
than the 2004 and 2003 vintages."
Do you see that?
A. Yeah, I do.
Q. Is it fair to say that each of FICO, LTV
and documentation type are all drivers of
performance for mortgage loans?
overbroad, incomplete hypothetical, calls for expert
testimony.
BY MR. SELENDY:
Q. Do you understand my question?
A. I'm not sure I'd say that. This is five
years old. I've not had a chance to personally
review the performance of loans and put them in
those categories. I don't know the answer to your
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experience as the CEO of Countrywide.

overbroad.
MR. SELENDY: Okay.
THE WITNESS: I don't know if those are
significant issues. I only know that after the fact
of being able to study the loans that went into
default. But the drivers of default, in my opinion,
have little to do with any of this. Had to do with
the collapse in real estate values.
BY MR. SELENDY:
Q. Do you understand why Mr. Garcia says, "As
predicted, the aforementioned risk factors have
resulted in the 2005 book experiencing faster
development of defaults than the 2004 and 2003
vintages"?
MS. CONCANNON: Objection. Calls for
speculation, lacks foundation.
THE WITNESS: No, I don't. Just seems to
me, I saw something here, that the book was still
performing better than other product that we had. I
think I saw that somewhere in here.
MR. SELENDY: Yes.
Q. In the next sentence Mr. Garcia says:
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question.
Q. Let me -- let me see if I can ask it more
generally. If you're trying to isolate the
variables that are most relevant to the performance
of a mortgage loan, what variables do you regard as
the most significant?
A. Down payment.
BY MR. SELENDY:
Q. What else?
A. And FICO score.
Q. Okay. So down payment, is that relevant to
LTV, loan to value?
A. Yes.
Q. And FICO score, as listed here, that's the
borrower credit score; right?
A. That's correct.
Q. And is it also the case that the level of
documentation, whether full doc, reduced doc or no
doc, is a significant predictor of the performance
of the loan?
MR. SIEGEL: Are you asking for his opinion
now, then?
MR. SELENDY: I'm asking based on your
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"Although delinquency is up in the bank's

2005 book, it is still performing significantly
better than Countrywide Home Loans' 2005 book
in line with CHL's best performing vintage and
generally consistent with the bank's pricing
models."
Do you see that?
A. I do.
Q. So he's saying that the performance of the
2005 book on the bank is significantly better than
the performance of the 2005 book for Countrywide
Home Loans; right?
Mischaracterizes the document, calls for
speculation.
BY MR. SELENDY:
Q. Isn't that what he's saying?
THE WITNESS: Yeah, I do think it speaks
for itself. I didn't craft the document. I'm
reading the same thing you're reading.
BY MR. SELENDY:
Q. And is that your understanding of what he's
saying?
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Page 223
THE WITNESS: My understanding of what he's

saying is what's written here.
BY MR. SELENDY:
Q. Is it your understanding that he's saying
the bank's 2005 book performed significantly better
than Countrywide Home Loan's 2005 book?
Mischaracterizes the document, vague, overbroad,
calls for speculation.
THE WITNESS: I think it's clear here,
that's what he's stating.
MR. SELENDY: Yes.
Q. Do you understand what Mr. Garcia's
referring to by the reference to "bank's pricing
models"?
A. I have a general understanding that they
have a, just like the mortgage company or any credit
underwriter, they have to price to the product, and
they have to model the pricing to the product. It's
based upon experience with that product.
Q. By "the mortgage company," are you
referring to Countrywide Home Loans?
A. Well, you asked me about bank.
Q. Yes, I did. And you said "just like the
mortgage company."
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A. Yeah, Countrywide Home Loans.

Q. Okay. What was the pricing model used by
Countrywide Home Loans?
A. I have no idea. I don't know.
Q. Do you have any familiarity with models
used by Countrywide Home Loans to predict the
likelihood of default?
A. No. I had nothing to do with predictive
models. We had experts to do that.
Q. Who were the experts within your
organization who handled that?
A. I believe -- I believe that Kevin Bartlett
was one of them. Stan Kurland was deeply involved
in that. Dave Sambol was involved in that. There
are other people. It was a big team that was
involved in pricing models. People that were
physicists as their background, their academic
backgrounds. Was quite a complicated process. But
those are the people that come to mind.
Q. What use did Countrywide make of the
Countrywide Home Loans pricing models?
THE WITNESS: That's how we priced loans.
BY MR. SELENDY:
Q. Okay. Did you price based on expectancy of
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default and delinquency?

A. When they talk about models, in these
models, it would seem to me, that they would have to
have a complexity of bullet points or targets
that -- that the loan has to hit to be priced
accordingly. So it's not a single item, it's a, as
I said, a complex process.
Q. Ultimately, were the models designed to
give you some prediction of performance so you could
price relative to expected performance?
MR. SIEGEL: Question is vague in the use
of "you."
THE WITNESS: I think the purpose of a
model is to model out expectations.
BY MR. SELENDY:
Q. Are you agreeing or disagree with me? I
can't tell.
A. Neither. Just making a statement.
Q. Okay. Were the models designed to give
Countrywide some expected performance metrics so
that it could price the loans based upon those
expectations of performance?
THE WITNESS: I believe so.
MR. SELENDY: Okay. Okay. Let me show you
Page 224
a document previously marked as Exhibit 1325.

THE WITNESS: Okay.
BY MR. SELENDY:
Q. Okay. What is the issue that this exchange
of e-mails is dealing with?
A. I have no idea.
Q. Okay. Let's go through it. The first
e-mail in the chain is on page 8433. It's your
e-mail to Carlos Garcia, copying David Sambol and
Eric Sieracki, and you state on December 24th, 2007,
under the -MR. SIEGEL: It's this one. It's the
first.
BY MR. SELENDY:
Q. See that?
A. I don't see it. You're saying -- oh,
December 24th.
Q. Okay. And the subject is "HELOCs," and you
ask:
"What years were these HELOC transactions
done? Who within Countrywide architected these
transactions? Was the use of these monoline
insurance companies under the same terms
typical of industry practices? What was the
value of this insurance if, in fact, the
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insurance company had no risk?"

Do you have any recollection of what you
were asking about?
A. No.
Q. Do you know why there's the heading on the
bottom "Privileged and Confidential Attorney/Client
Communication"?
A. No.
Q. Mr. Sambol responds to you, saying:
"I'll give you my understanding. These were
2006 and 2007 deals which were structured by
Kevin's area. Deals with monoline wraps are
not unusual, and I believe the terms of these
policies which mitigate the insurer's exposure
are normal. Our primary motivation for putting
on this credit enhancement was to improve the
securitization execution more so than to lay
off some of our credit risk."
A. Could you read that over again?
Q. He states:
"Our primary motivation for putting on this
credit enhancement was to improve the
securitization execution more so than to lay
off some of our credit risk."
A. Right.
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was to get an enhanced credit rating from the rating

agencies so we get better execution on the security.
What he's saying here is that -- that the benefit we
get from the AAA rating is greater than the cost of
the insurance. That's what I get out of this. And
I would agree with that, if that's true.
BY MR. SELENDY:
Q. So it was important for Countrywide to
involve the monolines in order to increase investor
appetite for its securitization products; right?
MR. SIEGEL: Misstates -MS. CONCANNON: Objection.
MR. SIEGEL: Misstates the document, calls
for speculation.
BY MR. SELENDY:
Q. Is that fair?
MS. CONCANNON: Misstates prior testimony.
THE WITNESS: No, I don't think it's fair
at all because it's not a Countrywide -- this is an
industry practice. This is not a
Countrywide-exclusive practice. This would happen
in the industry.
MR. SELENDY: I didn't suggest that it was
exclusive. Let me try the question again.
Q. Was it important for Countrywide to get the
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monoline wraps in order to increase investor demand

for its securitizations?
MR. SIEGEL: Misstates the prior -MR. SELENDY: It's a question. It's not -MR. SIEGEL: Okay. I'll withdraw that
objection. Calls for speculation.
THE WITNESS: It's very important,
generally speaking, for Countrywide to get the best
execution on all these transactions.
BY MR. SELENDY:
Q. And was Countrywide able to get better
execution by getting the monoline wraps?
MS. CONCANNON: Vague, overbroad.
BY MR. SELENDY:
Q. Do you know whether having those wraps
increased investor demand for its securitization
products?
A. I don't have to make an assumption on that
part. I don't know. I wasn't involved in it.
Q. Do you agree with the statement by
Mr. Sambol, that "these deals are structured with
the intent that the likelihood of loss to the
insurer is very remote and the objective is to
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Q. "The incremental securitization gain we

enjoyed as a result of the insurance policies
was greater than the incremental insurance
premium. These deals are structured with the
intent that the likelihood of loss to the
insurer is very remote and the objective is to
essentially rent their AAA rating. It is
somewhat analogous to paying FNMA a guarantee
fee, even if you were doing a recourse deal
with them."
A. Right.
Q. Does that refresh your recollection at all?
A. No.
Q. Do you agree with Mr. Sambol that the deals
with the monoline insurers was primarily to improve
the securitization execution?
speculation.
MR. SELENDY: As stated by Mr. Sambol in
the third and fourth lines of this e-mail.
MR. TU: Same objections.
THE WITNESS: My general understanding was
the reason for wrapping and paying those premiums
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essentially rent their AAA rating"?

foundation, calls for speculation.
THE WITNESS: I just accept what's on this
page. I have no opinion.
MR. SELENDY: Okay.
Q. You have no reason to disagree with that
statement?
THE WITNESS: I have no reason to agree or
disagree. I'm just accepting the way it is, way
it's stated.
BY MR. SELENDY:
Q. And when he wrote to you expressing his
understanding, you wrote back, "I understand the
justification"; right?
A. (Witness nods head.)
Q. So at the time you didn't express
disagreement, did you?
A. No, I didn't.
Q. Okay. And you wrote:
"I don't understand why a potential loss of
this magnitude was discovered after we had
given guidance for the fourth quarter and no
one in senior management nor the board was
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until recently nobody would have envisioned

this trigger being tripped."
Do you see that?
A. Uh-huh.
Q. Do you have any understanding of what
"trigger" he's talking about?
A. No.
THE WITNESS: I don't have any recall on
it.
BY MR. SELENDY:
Q. This is a document that's been marked as
Exhibit 1140. It's an e-mail from Stan Kurland to
Julie Scammahorn, forwarding an e-mail from Ron
Kripalani to David Sambol, copying you and Stan
Kurland, and attaching a memorandum from Michael
Schloessmann.
A. This is a very long, complex e-mail. It
will take me a long time to read.
Q. Yes. I can try and focus your attention.
A. Well, I don't know if it's fair because you
don't approach it fairly, so I've got to make
sure -Q. I'd like you to read the whole document,
sir. I'm trying to be fair with you. Read the
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aware of this potentially."

What potential loss are you talking about
there?
A. I have no idea, no recollection of it.
Q. Could it be loss in connection with
litigation with monolines?
speculation, vague, overbroad, lacks foundation.
THE WITNESS: I have no idea.
BY MR. SELENDY:
Q. Mr. Sambol writes back to you, saying:
"It appears there was" -First he says:
"We should have been aware of this exposure
earlier."
And then he says:
"It appears that there was a disconnect
between our Secondary Marketing and Credit
areas, which I'm sure a number of factors
contributed to: The number of issues they've
been dealing with, their staffing and capacity
constraints, the change in the credit
department leadership with McMurray's
departure, Kevin's absence, the rapid pace of
credit deterioration, and the fact that up
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whole document as always.

A. As I look at this document, I have no -- no
recall on this document whatsoever.
Q. Okay. Mr. Schloessmann is conveying a
concern with respect to Countrywide's repurchase
policies; correct?
THE WITNESS: I think there's -- there's a
lot of issues in here, so I -- that may be one of
them, but, you know, there's a lot of issues raised
here. I don't recall ever seeing this document.
BY MR. SELENDY:
Q. Let's start with the problem on the first
page. Under heading 1, "Problem," Mr. Schloessmann
states:
"There is a mounting chorus of discontent
expressed by buyers of Countrywide's
credit-sensitive bonds in the prime and Alt-A
credit markets, which can be averagely
attributable to the following two factors: 1,
the observed performance, particularly in the
early stages of Countrywide's prime and Alt-A
deals, is inferior to our peer group after
normalizing for collateral differences; and, 2,
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Page 235
Countrywide's unwillingness to repurchase loans

absent a clear showing of a rep and warranty
breach irrespective of the nature of default,
e.g. fraud."
Do you see that under the heading one?
A. Yeah.
Q. At this time what was Mr. Schloessmann's
responsibility?
A. I have no idea. I don't remember his name.
Q. He was in the -- in CSC, was he not,
securitization group?
answered.
THE WITNESS: I was not in the
securitization group. I was not part of that,
Countrywide securitizations. I was not involved in
the securitizations.
BY MR. SELENDY:
Q. Mr. Kripalani reported to you, did he not?
A. He reported to me as head of one of the
subsidiaries, I think. I don't remember how the
organizational chart worked. But I was not an
officer in any of the securitization activities.
Q. So when you got this e-mail that stated,
from Mr. Kripalani to Dave Sambol, copying you,
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"When convenient, please read the detailed and

comprehensive attachment below from Michael
Schloessmann, which clearly describes and outlines
the challenges that we face with institutional
investors with respect to the credit tranches in our
prime Alt-A securitizations," how did you respond?
A. I don't recall the document.
Q. Is this an e-mail you just would have
ignored, or do you not remember because it's several
years ago?
MR. SIEGEL: Objection.
MS. CONCANNON: Compound.
THE WITNESS: It is a long time ago.
Secondly, we had a whole team to address these
issues, and I relied heavily upon my team. But I
don't recall this document at all.
BY MR. SELENDY:
Q. Would it have been your practice not to
review documents of this nature?
overbroad.
THE WITNESS: I received many, many
e-mails. My practice was to review as many as I
possibly could. It's very possible I reviewed this,
but I don't have -- I don't have any recollection of
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it.
BY MR. SELENDY:
Q. Do you have any reason to disagree with
Mr. Schloessmann's statements, either the first or
second of the statements, under the heading
"Problem"?
overbroad, lacks foundation, calls for speculation.
THE WITNESS: I have no basis to agree or
disagree with him.
BY MR. SELENDY:
Q. If you'll turn to page 69 (sic) of the
memorandum, under point 3, "What Issuers Do."
MR. SIEGEL: "What other."
MR. SELENDY: "What Other Issuers Do."
Mr. Schloessmann states:
"Contributing to the market's perception
that Countrywide's jumbo and Alt-A deals
underperform its peer group is the consensus
view among sub buyers that Countrywide does not
stand behind its product by repurchasing bad
loans from deals, irrespective of whether
there's a clear breach of reps and warranties."
Q. That's a significant concern, isn't that,
sir?
Page 236

speculation, mischaracterizes the document, lacks
foundation.
THE WITNESS: No, I don't -- I can't -- I
don't know. Look, if there's a breach, there's a
breach, and we have to honor the breach. Then you
get into a Never-Never Land, you know, there's not a
breach. You know, I have no recall on this
document, and I have no -- I'm not going to make any
judgments.
BY MR. SELENDY:
Q. This document is sent to you after the -approximately a year, I guess, after Mr. McMurray's
description of an initiative by credit risk to try
and change the process for rep and warranty
breaches, isn't it?
BY MR. SELENDY:
Q. You recall we looked at the 2005 document
from Mr. McMurray earlier?
A. Yeah -MS. CONCANNON: Objection.
Mischaracterizes the record.
MR. SIEGEL: Document -MS. CONCANNON: Assume facts.
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Page 239
MR. SIEGEL: Document will speak for
1
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THE WITNESS: Yeah, document does speak for
4
itself.
5
BY MR. SELENDY:
6
Q. Does it refresh your recollection at all as
7
to any initiative by Countrywide to make it more
8
difficult for insurers and investors to push through
9
repurchases for breaches of representations and
10
warranties?
11
12
Mischaracterizes the documents, prior testimony,
13
assumes facts.
14
THE WITNESS: The first answer to your
15
question is no, I don't recall.
16
Secondly, the criticism was that they
17
wanted this repurchased without a breach.
18
BY MR. SELENDY:
19
Q. The statement by Mr. Schloessmann is that
20
Countrywide does not stand behind its product by
21
repurchasing bad loans from deals, irrespective of
whether there's a clear breach of reps and warranty; 22
23
right?
24
A. I have no comment.
25
itself.
THE WITNESS: My response to that is look,

I was out in the community speaking to investors.
We had a investor conference. No one ever came to
me, no investor, complaining about this issue.
BY MR. SELENDY:
Q. So did you think Mr. Schloessmann, in his
capacity as one of the officers and directors of
Countrywide Securities Corporation, was just out in
left field when he said this is a major problem for
us?
MS. CONCANNON: Objection. Argumentative,
assumes facts, mischaracterizes Schloessmann's role.
THE WITNESS: As I said, I have no -- no
recall of the document, and I don't know
Mr. Schloessmann.
BY MR. SELENDY:
Q. The last page of the document, under
subheading C, he states:
"Modify Repurchase Policy. The single most
important prerequisite for turning around this
problem is to adopt a more reasonable
repurchase standard, one that is better aligned
with that of our competition and the reasonable
expectations of our bondholders."
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THE WITNESS: I don't know anything about

it.
BY MR. SELENDY:
Q. Okay. Under point 3-C, Mr. Schloessmann
states:
"Investors universally indicated that
Countrywide is at or near the bottom of issuers
when it comes to the processing, consideration
and satisfactory resolution of repurchase
claims. Not only is our process viewed as
unresponsive and otherwise unfavorably, but
more important, investors are continually
frustrated by Countrywide's most narrow of
interpretations when it comes to the reps and
warranties. This is really the crux of the
problem, and one that will continue to -continue to result in the erosion of liquidity
for Countrywide's credit-sensitive paper."
Do you see that?
A. I read it.
Q. That's a -- that's a major problem, isn't
it, sir?
Mischaracterizes the document, vague, overbroad,
assumes facts and argumentative.
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Were you part of any discussions on or

after May of 2006 in Countrywide adopting a more
reasonable repurchase policy?
A. Not that I recall.
BY MR. SELENDY:
Q. Did Mr. Kripalani, to your knowledge, ever
report that steps had been made in dealing with this
problem by Countrywide Securities Corporation?
Mischaracterizes, assumes facts not in evidence.
MR. HAMILTON: Lacks foundation.
MR. SELENDY: Let's mark as Exhibit 1412 -I'm sorry?
MR. SIEGEL: We're getting some coffee for
the witness.
MR. SELENDY: Sure.
Let's go off the record.
MR. SIEGEL: We can -THE WITNESS: Are you going to -MR. SELENDY: Let's mark as Exhibit 1412
///
///
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attached hereto.)
THE WITNESS: Okay.
BY MR. SELENDY:
Q. Okay. What was the HSBC issue?
A. I have some recall on this issue because it
was -- although a very, very small part of our
business. I believe they were subprime seconds. It
was a tiny, tiny portion of our business. But it
was a situation where clearly there was a breakdown
administratively, documentation breakdown, and so it
involved primarily the fact that the sale to HSBC
gave them a right of a put-back if there was
deficiency in documentation. And they exercised
that put-back, and there should have never been a
deficiency.
Again, it was a tiny part of our operation.
It did cause a loss in a quarter, as I recall, and
this is one of the three categories. This is a
directive. Even in the directive I say let me know
if you have any questions concerning any aspect of
this e-mail.
Q. Now, in the document, at page 6408, on the
last paragraph on that page, you say:
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one in a series.
MR. SELENDY: Same issue. Let me just ask
a different -- okay. I can ask the same question.
The second to last paragraph you state, on 761:
"It is important that we tackle all of the
corrective measures to resolve the outstanding
issues with this product, but more important to
establish all of the necessary protocols to
ensure that we are originating these loans in a
manner that takes us out of harm's way and the
loans are sold in a manner to avoid further and
unnecessary exposure to the company."
Q. What did you mean by that?
A. Just what it says.
Q. Right. And -A. There's no other meaning to it. Again, I
don't believe this was securitization. I think it
was a whole loan sale. Was a whole loan sale to
HSBC, I believe. And the two issues were the terms
of the contract, and secondly was the documentation
on loans. So I want to make sure that -- that this
was not repeated in any other area of the
operations. Simple as that.
Q. Did you give a directive generally as to
the origination of loans to ensure that guidelines
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"Bottom line, from the negotiation of the

deal with HSBC through the delivery of the
product we have compounded one error after
another."
And then you say:
"Therefore, I want Sambol to take all steps
necessary to ensure that our origination
operation 'follows guidelines' for every
product that we originate."
What did you mean by following guidelines
there? And why did you put that in quotation marks?
A. Well, I don't recall why I did that. This
was a very important issue to me because it was -nothing was unimportant to me.
MR. HAMILTON: I don't know if we have the
same document.
THE WITNESS: It is not on mine either, but
I know what he's talking about.
MR. SELENDY: I'm sorry. It might be my
copy is a different page number.
MR. SIEGEL: I don't see the language.
Maybe you're looking at a different document.
MR. SELENDY: It's the same -- is this a
different one?
MR. SIEGEL: Yeah, I think it's a different
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were followed?
A. This document, you know, this document
speaks for itself. You just read it. I think it
says what -- what I meant at the time.
Q. Right. I'm not restricting it now to whole
loans or not. My question is: Did you give a
general directive as a result of the HSBC situation
that guidelines be followed with respect to the
origination of all loans? If you recall.
A. I don't recall. Whatever is in this e-mail
is in this e-mail. I don't recall anything beyond
that or before that.
1413 CWMBIA 11524659 through 67.
attached hereto.)
MR. SELENDY: Okay. Just hold that one for
a moment. I'd like to mark as Exhibit 1414 CWMBIA
11006407 through 6410 just to close out the
discussion on HSBC.
attached hereto.)
THE WITNESS: Okay.
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BY MR. SELENDY:
Q. Here, if you could look at page 6408, do
you see at the bottom paragraph the sentence in the
second -- second sentence there, where you state, "I
want Sambol to take all steps necessary to assure
that our origination operation 'follows guidelines'
for every product that we originate"? Do you see
that?
A. That answers your question.
Q. Okay. And so you made this directive as to
all products; right?
A. Right.
Q. Again, what did you mean by "follows
guidelines" in this document?
A. I don't recall.
Q. Do you have any idea?
A. No.
Q. What kind of guidelines did Countrywide's
loan operation work under? What kind of guidelines
were there?
THE WITNESS: The credit guidelines,
documentation guidelines. The HSBC transaction
was -- was a documentation -- violation of
documentation guidelines, as I recall -- as best as
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BY MR. SELENDY:
Q. I'm referring specifically to Enterprise
Risk Assessments.
A. And I'm referring specifically to I don't
recall.
Q. Okay. I made that clarification in light
of your counsel's objection.
If you would turn to page 4665 of the
document. And I'll note this assessment is dated as
of July 24th, 2006, as reflected on the first page.
A. Do you have a distribution list on this?
Q. I believe one was given to us with the
document. On the last page it says: "Prepared by
Sharif Shakhshir, first vice president Market Risk
Assessment Group."
A. There is a distribution list. It went to
Tim Lemon and Sharif Shakhshir, whatever her name
is. The first page. So I didn't see this.
Q. Okay. That's the e-mail. I don't know if
that's consistent with the distribution list or not,
sir.
On page 665, under the heading "Credit
Risk," do you see the statement: "Potential decline
in home prices"? It's the second point -A. Yes, I do.
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I recall.
BY MR. SELENDY:
Q. Other than credit guidelines and
documentation guidelines, are there other types of
guidelines that limited or controlled the loan
origination function at Countrywide?
THE WITNESS: May have been, but I can't
recall any right now.
overbroad, lacks foundation.
MR. SELENDY: All right. Turning back to
Exhibit 1413, the Enterprise Risk Assessment. My
first question to you, when you've had a chance to
look at the document, is:
Q. Which unit within Countrywide generated
this document? If you know.
foundation.
BY MR. SELENDY:
Q. Have you seen documents of this nature
before?
///
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Q. -- below "Credit Risk."

Okay. And your Enterprise Risk Assessment
Group states:
"The predicted collapse of the housing
bubble is likely to lead to record levels of
mortgage defaults and losses to owners of
mortgage assets, such as residuals."
You see that?
A. Yes.
Q. Do you recall whether that was conveyed to
you as of July 2006 by anyone associated with the
Risk -- Enterprise Risk Assessment Group?
A. I don't recall.
Q. Do you know, what's the purpose of these
Enterprise Risk Assessments?
A. Is to assess risk.
Q. Okay. For which group within Countrywide?
A. Within the entire organization, entire
enterprise.
Q. Are these distributed to the Credit Risk
Group? Do you know?
A. I'm not sure how it's distributed.
Q. Who's in charge of the ERA?
A. Don't know.
Q. When you say it's for the entire
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organization, is it distributed typically to the

entire organization?
MR. SIEGEL: Question's compound, vague.
MR. HAMILTON: Calls for speculation.
THE WITNESS: I don't know who gets -- who
gets distribution.
BY MR. SELENDY:
Q. Why did you say it's for the entire
organization?
A. Because it says "enterprise." I'm assuming
that's what "enterprise" means. We have no
department by that name.
Q. Okay. So your inference is that the
appropriate management across the enterprise would
receive and review these documents?
BY MR. SELENDY:
Q. Is that fair?
speculation, mischaracterizes prior testimony.
BY MR. SELENDY:
Q. You can answer the question.
THE WITNESS: I don't -- I don't really
know. I don't know.
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THE WITNESS: I'm not sure of this. I
didn't participate in it. And the -- my
understanding is -- I don't know if it's correct or
not -- it was asked to be produced by one of our
directors and a team was put together. I don't know
who was a member of that team that produced this
document.
BY MR. SELENDY:
Q. Was the purpose of the exercise to try and
understand any shortfalls within Countrywide's
operations that could yield lessons learned going
forward?
speculation.
MR. SELENDY: There's no characterization
of the document. It's a question.
speculation, lacks foundation.
MR. SELENDY: Okay.
Q. You can answer.
A. I don't know what was in the mind of the
director when he -- I think, you know, if that was
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1415 CWMBIA-G92601 through 610.
attached hereto.)
MR. SELENDY: This document is entitled
"Key Observations and Lessons Learned From the
Crisis."
THE WITNESS: What's your question?
BY MR. SELENDY:
Q. Have you seen the document before?
A. No.
Have I seen this before?
MR. SIEGEL: You're asking me if you've
seen it before?
THE WITNESS: Yeah. I don't recall seeing
it. I've heard about it. I've heard about the
document, but I don't recall seeing the document.
BY MR. SELENDY:
Q. In what context did you hear about the
document?
A. Well, I've been deposed 14 times, so I'm
sure one of those depositions.
Q. Okay. What is your understanding as to why
the document was created?
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the case, whoever directed this, I don't know what

their purpose was.
Q. Did you have any discussion with any member
of the board of directors of Countrywide about the
lessons learned from the crisis?
A. I don't recall. I don't recall because I
don't know what the date of this thing is, but...
Is there a date on this? Does anybody see
a date on it?
Q. I don't see a date on it.
Do you recall any discussion generally
about the subject matter of lessons learned from the
crisis?
A. As I said, I didn't participate in this
process.
Q. Okay. But in the outcome of the process,
do you recall any discussions after the process was
complete about lessons learned from the crisis?
overbroad.
BY MR. SELENDY:
Q. Do you have any views as to lessons learned
from the crisis?
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overbroad, calls for expert testimony.

MR. SELENDY: And to be clear, I'm asking
for your testimony in your capacity as the former
CEO of Countrywide as to what lessons Countrywide
should have learned from the period running through
2007, 2008.
overbroad, assumes facts not in evidence,
argumentative.
THE WITNESS: I don't think there was
anything that Countrywide could have done to avoid
the tsunami that hit the financial services industry
and that destroyed most of the industry and we
survived it. I don't think there's anything I would
do differently.
BY MR. SELENDY:
Q. Do you think Countrywide should have
reconsidered expanding its guidelines, which your
own senior directors said partly fueled the housing
boom?
THE WITNESS: I don't interpret it that
way, and I think we did the best job we could to
preserve the integrity of the company at all times.
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credit models. Delinquencies were rising and

models predicted worse to come."
I take it you do understand what that
bullet point is saying?
mischaracterizes the document, vague, calls for
speculation.
MR. SELENDY: What is the
mischaracterization you're referring to,
Ms. Goodwin?
MS. CONCANNON: Ms. Goodwin?
Ms. Concannon.
MR. SELENDY: Ms. Concannon.
MS. CONCANNON: You are asking the witness
about a document that was assembled from multiple
different people. He knows nothing about the way in
which the document was assembled. You are then
asking him whether he agrees or whether there are
fair statements -MR. SELENDY: I said do you -MS. CONCANNON: -- documents that are taken
out of context.
MR. SELENDY: Okay.
MS. CONCANNON: There's nothing for him to
understand or not understand. You've laid
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BY MR. SELENDY:
Q. Well, let's look at some of the statements
made in response to the exercise that your board
director asked to have made. Starting at the
heading "Pre Crisis, Market Expectation and
Anticipation," the first bullet point states:
"Deteriorating credit conditions were
clear, but the expectation was that spreads
would widen, which could be reflected in the
pricing. Nobody expected liquidity to seize up
at such a rapid pace. Had the spread movement
been a continuous function, Countrywide could
have exited."
Do you understand what that bullet point
means?
THE WITNESS: No.
BY MR. SELENDY:
Q. No understanding?
A. No. Could have exited what? The business?
Q. I'm not going to answer the question, but
if you have no understanding of it, I'll move on.
In the next point, it states:
"We did not fully heed the warnings of our
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absolutely no foundation in asking this question of

this witness. And I'm not objecting, I'm answering
the basis question that you raised, counsel.
MR. SELENDY: Okay.
Q. I take it you understand what the second
bullet point is saying?
foundation.
THE WITNESS: Yeah, I -- I think it's very
easy for people to look back and analyze the way
life should have been, so I don't, you know, I don't
agree with the process to start with. I was in the
middle of trying to save this company and people
were spending their time on this.
So I don't, frankly -- you know, I can't
agree, disagree with any of this because it's all
done retrospectively, not done on the basis of what
we were dealing with every moment of every day,
every month of every year. It's a very dynamic
industry, things change rapidly, and we dealt with
them as best we could.
BY MR. SELENDY:
Q. Do you resent the fact that people look
back to figure out if there were problems in the way
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the company was operated during the crisis and

preceding the crisis?
A. I don't resent any intellectual exercise
that people want to go through.
Q. Okay. Earlier today you testified that had
you known a housing collapse was coming you would
have acted differently. In what way would you have
acted differently?
A. If I knew than unemployment rates were
going to double, that housing values were going to
be halved, that people would leave their house
simply because the value of their home was below the
mortgage, I would have sold the company years before
that, if I knew that.
Q. You would have sold the risk to someone
else?
A. Sold the company. Somebody could make an
assessment as to whether or not they want that risk.
Q. What if you would have known that borrowers
were increasingly likely to default based on widened
guidelines?
THE WITNESS: This is all speculation, you
know, and I'm -MR. SELENDY: It's not speculation.
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people's conduct relative to leaving their home

simply because the value went down was
unprecedented. So that was not clear in any of the
documents, and that was the cause -The real cause of this was collapse in real
estate values. We've had deterioration in real
estate values before. Countrywide operated for 40
years with 17 1/2 percent mortgage rates through
major wars, through crisis after crisis, and we
survived it. This was unprecedented, evidenced by
the world around you. Major companies, 150-year-old
companies went down.
So there was nothing in the documents that
you showed me, or anybody else showed me, or ever
read any place, that said we're going to face the
problems that this country faced in the financial
markets where liquidity would disappear overnight.
Q. Let's look at the document right in front
of you, sir, where Countrywide itself is concluding,
quote:
"We did not fully heed the warnings of our
credit models. Delinquencies were rising and
models predicted worse to come."
It's not an ambiguous statement, is it,
sir?
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THE WITNESS: Sure it is.

BY MR. SELENDY:
Q. That was clear in the documents, isn't it,
sir?
Mischaracterizes the documents.
Excuse me, even, co-counsel.
That's argumentative. Put a proper
question to the witness.
MR. SELENDY: Okay. It is a question.
MR. SIEGEL: What's your question?
BY MR. SELENDY:
Q. That was clear in the documents, wasn't it?
MR. SIEGEL: Which documents? The
question's vague.
BY MR. SELENDY:
Q. Documents you've reviewed today, among
others.
A. Absolutely not clear. There was nothing in
the documents that said housing values were going to
be cut in half, unemployment was going to 10
percent, that people would leave -- that you would
have decrease in value across the United States,
which did not even happen in the Depression; that
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A. It's very ambiguous. Give me the numbers.

speculation.
BY MR. SELENDY:
Q. Is the statement that "we did not fully
heed the warnings of our credit models" unclear to
you?
A. I don't even know if it's correct.
Unclear.
Q. You don't know?
A. You see e-mail after e-mail, document after
document tightening guidelines, requiring increased
down payments. We heeded our concerns.
Q. Why don't you turn to the next page of the
same document, under the third bullet point, it
states:
"We continued to grow aggressively through
Q2, second quarter, despite warnings of credit
models. Continued to focus on shared growth
and hiring. Initiatives regarding
manufacturing quality did not turn into
meaningful action until Q2."
Do you see that?
A. Uh-huh.
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Q. Do you think that's ambiguous as well?

MR. SIEGEL: It's ambiguous.
THE WITNESS: I think it's irresponsible,
the statement. Nobody came to me and ever said that
these are the issues that we must address until
after the crisis hit. Now, there's no date. Second
quarter of what year? Has anybody found a date on
this document?
BY MR. SELENDY:
Q. You say nobody came to you, but you have
the document I showed you earlier reflecting John
McMurray's summary of credit risk long before 2007
A. We managed to that risk. We managed to
that risk. We stopped taking third-party pay-option
loans. We did lots of things. Stopped subprime
seconds. We continued to manage to the risk. It's
wonderful to be in a position to go back, you
shouldn't have done this, you shouldn't have done
that. We did the best job we could based on the
knowledge we had at the time.
Q. You continued to originate loans under
massively widened guidelines and securitize those
risks out away from the company; isn't that true?
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document.
BY MR. SELENDY:
Q. Turn to the next page, please, under the
heading "Business Model." First bullet states:
"We need to find the right balance between
our value proposition to production and our
duty to the investors."
And then the next bullet states:
"Historically, production has had too much
weight in product, credit, market share and
balance sheet decisions."
Is that a fair assessment?
A. No.
Q. Do you regard it as ambiguous?
A. No.
Q. Go down two bullet points, it states:
"Broad guidelines were a central tenet of
our value proposition."
You agree with that; right?
A. No. Product -- the product line that we
had and our distribution network and our efficiency
and our technology and our lower cost to the
consumer was the cornerstone of Countrywide's
success.
Q. You agree that a central tenet of the value
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assumes facts not in evidence.

THE WITNESS: And terribly overstated.
We have a contingent liability in
everything we originate.
BY MR. SELENDY:
Q. What is the contingent liability you're
referring to?
A. That -- just what we're referring to here
in terms of buy-backs, put-backs, with Fannie, with
Freddie, with FHA, with private insurance companies.
Q. The risk that an entity like MBIA might
come back and sue Countrywide for breach of -A. That's a contingent liability.
Q. Okay. Could you turn down on the same page
under "Risk Governance," first bullet states:
"Early indicators of credit risk exposure
existed. Internal control systems highlighted
many of the risks that eventually transpired."
Is that ambiguous to you, sir?
A. I don't know if it's true.
Q. You just don't know one way or the other?
THE WITNESS: I don't know the team that
put this together. I don't know their level of
knowledge. I don't know anything about this
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proposition was the broad supermarket category of

loans; right?
BY MR. SELENDY:
Q. Right?
A. We tried to create a product line that was
relevant to the consumer's needs, to meet the
mandates of the government, to meet the mandates of
the social issues in this country, and to carry out
corporate responsibilities. That's what we tried to
do.
Q. In the same bullet point, it states:
"We believed we could lay off most of the
risk. "
That was one of the core strategic
imperatives of the company, to transfer most of the
risk off of the company balance sheet; right?
Mischaracterizations the document, asked and
answered.
THE WITNESS: Let me go back. You used the
word "core." Those are your words, not mine. Let
me go back to several hours ago I told you a
mortgage banker's objective, because we don't have a
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funding source, is to keep loans on our balance

sheet, so therefore, we must sell those loans. As
part of selling those loans, you're offloading risk.
MR. SELENDY: Right.
THE WITNESS: And you're assuming those who
are buying that risk have priced it favorably to
themselves.
MR. SELENDY: Yeah.
Q. Only if the disclosures are accurate,
though; right?
MR. SIEGEL: That's argumentative.
You don't have to answer that. He can save
his argument for juries or wherever.
BY MR. SELENDY:
Q. You agree with that; right? The
disclosures have to be accurate to price it?
BY MR. SELENDY:
Q. You can answer.
MS. CONCANNON: Vague, overbroad, asked and
answered.
THE WITNESS: Disclosures should be
accurate.
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BY MR. SELENDY:
Q. Okay. Do you agree with the statement
under the first sub bullet, "This was very
attractive to loan officers and allowed them to be
highly market focused"?
A. I have no idea what that means.
Q. Was that decentralized structure attractive
to loan officers at Countrywide?
BY MR. SELENDY:
Q. How about the following bullet, "The
downside was fewer risk controls and less focus on
risk as the local decision-makers were not directly
measured on risk"? Is that fair?
A. No, it's not fair. Plus, it's incorrect.
There was penalties for lack of quality under a QC
system, financial penalties, so they were incented
to -- to the opposite of what you think -- they were
incented to do. That's my recollection.
Q. Didn't you disagree with the initiative to
introduce penalties on the sales staff where there
were nonperforming loans originated?
THE WITNESS: I don't recall that.
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BY MR. SELENDY:
Q. If you'll go down to the next bullet point,
it states:
"Decentralization and local decision-making
were another characteristic of our model and
differentiated us versus our competitors."
And you testified earlier that that
decentralization was part of your strategic
initiative; right, to increase market share?
MS. CONCANNON: Objection to form.
MR. SIEGEL: Misstates the record.
THE WITNESS: I can't answer that question
simply.
Countrywide's method of gathering product
was done through a Countrywide branch system,
nationwide branch system, so we decentralized how we
originated loans. It wasn't through one source.
Secondly, we decentralized the process so
that it would be efficient and that it would meet
the customer's demands in terms of time.
Thirdly, we controlled the underwriting
through CLUES and through our stated guidelines and
through management of those guidelines and through
our referral system and our exception system.
Decentralization was a good thing for us.
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MS. CONCANNON: Broad.

BY MR. SELENDY:
Q. I thought you were opposed to a penalty
system like that on your employees?
THE WITNESS: I don't recall the financial
structure of a branch, but a branch was penalized
for quality control or lack of quality control. How
that worked, I'm not sure. I am generally opposed
to a negative system, system that penalizes people
because the salesmen had no input on underwriting.
They're not responsible for the underwriting.
They're responsible for bringing the loan
application, period. So to penalize a salesman for
something they're not responsible for seemed to be
unfair to me.
BY MR. SELENDY:
Q. Isn't it fair to say that the Countrywide
salespeople were basically compensated based on
their production?
THE WITNESS: I'm not sure how they were
compensated. I don't think it was that simple.
That's my recollection. I think it was a complex
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system.
BY MR. SELENDY:
Q. Did you make use of a commission incentive
system for salespeople at Countrywide? Do you know?
MR. SIEGEL: Question's compound and vague
as to time.
THE WITNESS: As I said, I don't know how
they were compensated.
MR. SELENDY: Okay. If you'd turn to the
next page of this document, page ending in 2604, the
third bullet point states:
"Our model of matching products put us at
the mercy of irrational market behavior.
Irrational behavior began with brokers, and in
an effort to retain the book of business we
matched product. Those products then made
their way into retail. We were under
significant pressure from all of our partners,
builders, real estate agents, brokers to get
deals done, putting further pressure on
guidelines. We gave into the market."
Q. That's not ambiguous, is it?
THE WITNESS: I think it's wrong.
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the product line -- was the right thing to do.

MR. SELENDY: Okay. Last point on this
document. On page 5, second bullet point states:
"We were driven by market share and wouldn't
say no (to guideline expansion). Given our
leading position, what if we said no?"
Q. Do you see that?
A. Yeah.
Q. And it's true, isn't it, that the basic
mandate was to rarely, if ever, say no to an
opportunity to originate loans that were consistent
with competitor's guidelines?
Mischaracterizes prior testimony, asked and
THE WITNESS: No, your statement's
incorrect. We originated loans consistent with our
guidelines. And I think, again, the statement here
is just wrong and -- at least from my viewpoint. We
never, and I made it public, sacrificed quality for
volume. I made that public on many occasions, and
that was my mandate as CEO to the company. Where
this is coming from, I have no idea.
BY MR. SELENDY:
Q. Did you ever consider the possibility, sir,
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BY MR. SELENDY:
Q. You think it's wrong?
A. Yeah, I think it is wrong. I don't know
who wrote this stuff. But based upon my
understanding of how this company was run and
managed, this is a terribly prepared document
without, in my opinion, without understanding the
real issues.
Now, the fact is that customers always put
pressure on. Builders want their deals to close;
real estate brokers want their deal to close.
That's the nature of the business.
Q. You're aware that Countrywide did, in fact,
have a matching or supermarket strategy under which
Countrywide's own guidelines expanded to meet the
guidelines of its competitors?
MR. MORGAN: Objection. Asked and
answered.
MS. CONCANNON: Mischaracterizes prior
testimony.
THE WITNESS: I think I testified that -- I
don't know about the matching strategy, and I think
the strategy of matching products where we could
match products -- many cases we couldn't. We
couldn't compete with certain companies because of
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that your sales staff, motivated by incentives to

produce, may have disregarded general public
statements about quality and instead focused on the
overriding mandate to produce?
THE WITNESS: I relied upon a very large
and deep team to review quality, to review our
underwriting, to review the individual loans
themselves. So we had a large commitment, major
commitment, to make sure that we were following the
company's guidelines, its mandate, and its expressed
policies that we expressed to the world that these
are our guidelines, these are what our objectives
are, and this is what we want to do.
And we had a whole team looking at this
stuff. These people didn't go out and originate
loans on their own. We reviewed all the loans that
they originated. We rejected some 15 to 20 percent
of loans that came to us from these people.
BY MR. SELENDY:
Q. When you say "from these people," who are
you referring to?
A. Field people, people you're talking about,
salespeople.
MR. SELENDY: Okay. We can take a break.
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THE VIDEOGRAPHER: This marks the end of

Videotape No. 3 in the deposition of Angelo Mozilo.
Time on the video monitor is 2:53.
(Brief recess.)
THE VIDEOGRAPHER: This marks the beginning
of Videotape No. 4 in the deposition of Angelo
Mozilo. Time on the video monitor is 3:15.
BY MR. SELENDY:
Q. Mr. Mozilo, before the break you made a
comparison to 150-year-old companies that didn't
survive, and my question to you: Do you think Bank
of America is happy with the transaction with
Countrywide?
MR. CLOSE: Objection. Calls for
speculation, lacks foundation -MS. CONCANNON: Objection.
MR. CLOSE: -- Vague and ambiguous.
THE WITNESS: It's irrelevant. I have no
idea.
BY MR. SELENDY:
Q. You have no idea?
A. No.
Q. You also made a statement that 15 to 20
percent of the loans approved by -- the loans
suggested by Countrywide sales force were not
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THE WITNESS: This is a guess on my part.
I don't believe so. I believe the Structured Loan
Desk was there -- at least my knowledge, the reason
for he Structured Loan Desk was to look at loans
that were not conforming loans for the secondary
market, and whether or not -- and generally, I
think, were whole loan transactions -- whether or
not they could find a buyer on a whole loan basis.
That's my understanding. May not be the correct
understanding, but that's my understanding of the
Structured Home Loan Desk.
Let me just make a correction for the
record, is that you asked me some time back whether
Kripalani reported to me, and I don't think I was
clear on that. Kripalani, Ron Kripalani, did not
report to me. That's why I asked about the
organizational chart. And upon reflection, there's
only two people that reported to me, Stan Kurland
and Sandy Samuels, who is the general counsel. When
Stan Kurland left the company, then Dave Sambol
reported to me. But it's always been two people
reporting to me.
BY MR. SELENDY:
Q. Your statement is that Kripalani reported
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approved by the company.

What's the basis for your recitation of
data there?
A. It's just -- it's been historically about
the same number for many years. Sometimes it's 10
percent, sometimes it's 25 percent. Depends upon
the market.
Q. Have you seen any more data on that figure
from the period 2004 through 2008?
A. I don't recall seeing any data. It's just
my experience.
Q. Would it surprise you to know that only 1
to 3 percent of the loans referred ultimately to the
Structured Loan Desk were not approved?
not in evidence, mischaracterizes prior testimony.
THE WITNESS: It wouldn't surprise me
because you're talking about a small portion of
loans that go through one desk. It's not the entire
body of loans that come through the system.
BY MR. SELENDY:
Q. Well, isn't it correct that a huge number
of loans that didn't satisfy guidelines ultimately
made their way to the Structured Loan Desk?
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to someone else who then reported to you; is that

your point?
A. Reported to, I believe, Stan Kurland, and
Stan Kurland reported me.
Q. Right. So he wasn't a direct report, he
was an indirect report?
A. Well, everybody was an indirect report.
Q. Ultimately, Ron Kripalani had to answer to
you for his performance; correct?
MR. SIEGEL: Mischaracterizes the
testimony.
THE WITNESS: That's not correct. That's
not entirely correct because his compensation, his
review was done by Stan Kurland, not by me.
BY MR. SELENDY:
Q. And did you have to approve the
recommendations made by Stan Kurland as to
Mr. Kripalani's compensation?
A. I'm not sure about his -- about his
compensation. What I -- what I do recall is that
Stan came to me once a year with a list of
executives and his proposed compensation for those
executives, and I generally approved it.
Q. And that would include the compensation for
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Ron Kripalani; correct?

MR. SIEGEL: Speculation.
THE WITNESS: I would guess so. I don't -I don't know for a fact.
BY MR. SELENDY:
Q. And as part of your consideration whether
to approve compensation you would evaluate
performance, wouldn't you?
A. Primarily rely upon Stan Kurland's
recommendation, because he was best informed to
assess performance, not me.
Q. Yes, understood. But together with -strike that.
Let's introduce as Exhibit 1416 the first
quarter 2004 Countrywide Financial Corporation
Earnings Conference Call Event Transcript.
attached hereto.)
BY MR. SELENDY:
Q. Now, this I'm just going to direct you to
page 9 of the transcript in the lower right-hand
corner. You're free to look at as much of the rest
of the document as you want, but since you seem to
be unsure about how the sales staff was compensated
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continuing to grow that commission sales force,

being driven by our desire to get to that 30
percent market share by 2008."
Do you see that?
A. I see it.
Q. And you go on to make other statements.
Does this refresh your recollection that,
in fact, you shifted to a commission sales force in
order to drive up production to try and reach your
30 percent market share objective?
the prior record.
THE WITNESS: The reason for the shift to
the commission sales force was unrelated, to my
recollection, to increase in market share. The
issue that we faced is that we were the only ones in
the industry, to my knowledge, that didn't have a
commission sales force. The only ones. We relied
upon driving loans into the branch system to loan
processors, and that concept, that method of
operation, worked very well for us in a refinance
boom environment, because no one had the capacity
that we had, because we were techno-centric. We had
the technology to virtually create unlimited
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I thought this might refresh your recollection. And

you'll notice -A. Where are you going on 9, page 9?
Q. Okay. Page 9, the upper left-hand corner
states "Angelo Mozilo," and then you're answering a
question. The question is from Jonathan Gray, who
says:
"I wonder, as a final question, since folks
seem be to inclined to ask multipart questions,
if you could discuss with us how you visualize
the change in your head count over the course
of the year in terms of the reduction in
salary, staff and the growth of commission
salesmen and how they might connect to some
understanding of how your market share's likely
to evolve and expand."
And you respond:
"John, I think those are, from what I
understand, you asked, I think, two different
issues. One, let me take the last part of it,
the B part of it, is in terms of the market
share, you can see the dramatic change in
market share is a result of shift in strategy
to a commissioned sales force and expanding
commission sales force, and we are actively
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capacity. Our competition didn't opt for technology

and therefore when refinance booms happened, they
got backed up and couldn't close loans. We could
close loans. We made a lot of money in a refinance
environment because our people were processors,
bureaucrats in the branches.
However, when the refinance boom was over
with, our earnings dropped dramatically. As a
publicly-held company, it was very difficult for
investors or analysts to determine how we were going
to do in environments, in various interest rate
environments, because you couldn't predict interest
rates.
In order to even out the income stream of
the company, we had to find a way to develop
relationships with real estate agents and with home
builders. And since our people in the branches were
processors and did not leave the branch to get
business, we decided, after many years of the
other -- of the other method of operation, to begin
hiring salespeople so that we could generate and
even out earnings for the company so our volumes
wouldn't vacillate the way they had historically.
That was the reason for it.
That's the reason for our commission sales
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force.
BY MR. SELENDY:
Q. In the first part of the answer you just
gave, you said the reason for the shift was
unrelated to the market share objective?
A. I believe so.
Q. So I'm just curious: Were you telling the
truth then when you said, "We are aggressively
continuing to grow that commission sales force being
driven by our desire to get to that 30 percent
market share by 2008"?
A. I don't think my first statement is
mutually exclusive from this statement. They
both -- one was to even out our earnings, two was to
get to increased market share. That's the only way
we could get there.
Q. Okay. So part of the reason for moving to
a commission sales force was to get to your 30
percent market share as you stated then?
A. That's correct.
Q. Okay. Now, you made reference to
guidelines before, and I wanted to ask you: Are you
familiar with the loan program guides that
Countrywide put together?
A. No.
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outside of the process. And we have established

guidelines within CLUES that try to capture as much
as we can to approve loans that meet -- strictly
meet those guidelines. Many loans don't meet. I
don't know the percentages, but a substantial amount
of loans do not meet those guidelines. They're
referred out.
To me it's all part of a comprehensive
guideline because once it's referred out, they have
guidelines. They must have guidelines. You can't
approve every loan that's referred. They will not
approve every loan.
BY MR. SELENDY:
Q. So when you say "they must have
guidelines," is there a name for those guidelines
that you say must exist?
THE WITNESS: I don't know if there's a
name.
BY MR. SELENDY:
Q. Does the Structured Loan Desk, to your
knowledge, have any guidelines?
MR. SELENDY: The Secondary Structured Loan
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Q. Have you ever seen the so-called seller

guides that Countrywide put together?
THE WITNESS: I don't believe so.
BY MR. SELENDY:
Q. Do you know what shadow guidelines are?
THE WITNESS: I've heard the term, but I
don't know what it means.
BY MR. SELENDY:
Q. Do you know what branch guidelines are?
THE WITNESS: Those are the underwriting
guidelines that the branches use to underwrite their
loans.
BY MR. SELENDY:
Q. When you described compensating factors, is
it your understanding that exception loans with
compensating factors are within guidelines or
outside of guidelines?
MS. CONCANNON: Objection. Vague, lacks
foundation, asked and answered.
THE WITNESS: Exception loans are a
fundamental aspect of underwriting loans. It's part
of the underwriting process. It's not something
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Desk.
foundation.
THE WITNESS: I can only assume that they
have guidelines, but they're unrelated to the
referral process generally for conforming loans.
BY MR. SELENDY:
Q. If approval of a nonconforming loan is
based upon compensating factors, as you use that
term, is there any obligation on the part of the
loan originator to document what those compensating
factors are?
overbroad, lacks foundation, incomplete
hypothetical.
THE WITNESS: You're mixing a lot of stuff
together. But let me just say this: That every
underwriter has guidelines, whether loans be
referred or not. Structured Loan Desk, I'm
confident, has guidelines. It can't operate without
guidelines, can't underwrite without guidelines.
You underwrite to something. You're underwriting to
guidelines.
BY MR. SELENDY:
Q. Are all the guidelines provided to
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investors and insurers, to your knowledge, for

the -MS. CONCANNON: Objection.
BY MR. SELENDY:
Q. -- for the securitizations in dispute?
MR. SIEGEL: Compound.
MS. CONCANNON: Overbroad, lacks -MR. SELENDY: Let me step back a little
bit.
Q. Do you understand the securitizations in
dispute concern securitizations of HELOCs and
closed-end seconds?
A. No.
Q. Okay. I'll represent to you that those are
the second lien deals in dispute in this case. Do
you have any understanding of whether the guidelines
applicable to those products are provided to
investors and insurers?
MS. CONCANNON: Objection. Vague as to
"investors and insurers," lacks foundation.
THE WITNESS: I don't know. I would only
say that if they asked for them they could have
them. They're public.
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to go into our guidelines, there's no reason I can

imagine where we would say no.
BY MR. SELENDY:
Q. Where did Countrywide publish its
guidelines?
MS. CONCANNON: Vague and ambiguous.
THE WITNESS: I don't know where -- where
they were published. I think they were -- I don't
know if they're published publicly, but they were
available publicly.
BY MR. SELENDY:
Q. Are you aware that Countrywide made use of
guidelines which it did not, in fact, provide to
MBIA until after the middle of 2006?
foundation, assumes facts.
THE WITNESS: I'm going to repeat this one
more time. I was not involved in the securitization
process. I was not involved in any negotiation with
MBIA. I don't know anything about MBIA. I had no
involvement. So any question you have about MBIA
and Countrywide I have no knowledge of.
BY MR. SELENDY:
Q. What specific steps did you take to ensure
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BY MR. SELENDY:
Q. Which guidelines are public?
A. All guidelines. Anything -- we were -we're a transparent company. Anything that they
asked for, Fannie Mae asked for, whatever -- they
knew exactly our guidelines because they adopted our
guidelines in our CLUES system. So our guidelines
were not a secret. Anybody could have had them. It
was not a trade secret.
Q. Is it fair to say that in order to
understand how Countrywide originated the loans, one
has to look at the guidelines that Countrywide used?
overbroad, compound.
THE WITNESS: Who?
MR. SELENDY: Let's start with MBIA, the
monoline insurer that's the plaintiff here.
THE WITNESS: Look -MR. SIEGEL: Calls for speculation.
THE WITNESS: -- based upon just logic -First of all, we publicized every month the
type of loans we were originating, the FICO scores
in those loans, all the products publicly, issued a
public report every month. If it was Fannie or
Freddie, the insurers or MBIA, or whoever, wanted it
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that loans were properly underwritten in conformity

with guidelines?
A. I relied upon a very talented, very
experienced, time-tested management team that was
with me, on average, for over 25 years, and had a
25-year track record that was unparalleled in the
industry. That's what I did.
Q. Can you think of any specific directions or
initiatives that you caused to be underway which
were designed to ensure that loans were properly
underwritten?
overbroad.
THE WITNESS: You provided me with e-mails
with my direction. That's what I recall.
BY MR. SELENDY:
Q. If compensating factors were not written
down, how would your deep management team be able to
assess whether the underwriting of those loans was
proper?
THE WITNESS: Experience.
MS. CONCANNON: Vague, overbroad.
BY MR. SELENDY:
Q. Experience?
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A. Experience, yeah.
Q. Can you be more specific?
A. No. It's just experience. If you have
experience underwriting, you have -- you've seen
thousands and thousands of loans in a pattern, you
have a certain expectation, and you have a comfort
level that -- of which you rely upon. Judgment.
Underwriting is about judgment.
Q. What kind of training did Countrywide
require for its loan originators in order to
understand what could be accepted as a compensating
factor?
MR. SIEGEL: Compound, vague, and calls for
speculation.
THE WITNESS: Loan underwrite -- loan
originators did not underwrite loans.
BY MR. SELENDY:
Q. Okay. Which unit within Countrywide would
you say underwrote loans?
A. Underwriters.
Q. Okay. What training did Countrywide
provide to its underwriters in order to assess
whether a factor was adequate to be acceptable as a
compensating factor?
MR. SIEGEL: Compound, calls for
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answered, vague and overbroad.

THE WITNESS: We would not compete directly
with monoline subprime originators that originated
loans far below what our standards are.
BY MR. SELENDY:
Q. Can you be specific as to what loan types
you had in mind?
A. No.
Q. Can you name any loan type that a
competitor offered and Countrywide did not?
THE WITNESS: 450 FICOs, 420 FICOs, 500
FICOs. It's all they did. Company just specialized
in that.
BY MR. SELENDY:
Q. Okay. So you're saying that Countrywide
would not match loans where FICO scores were below
500?
A. I'm not saying that specifically. What I'm
saying is, generally speaking, that category of loan
was not a product we would do. Could a 500 loan -500 FICO loan find its way -- a loan into the
millions of loans that we originate? Maybe.
Q. How would you refer or describe that
category of loan?
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speculation.
THE WITNESS: I don't know the specifics of
the training programs, but I know that we had -that our training programs produced exceptional
people, and the proof of that was our people were
always in demand by our competition.
BY MR. SELENDY:
Q. How do you know that your underwriters were
even comparable to the underwriters at your
competitors?
A. Because our delinquency rates and
foreclosure rates were below our competition
consistently.
Q. For what period of time?
A. From 1968 until the collapse.
Q. Is it your testimony that after 2007
Countrywide's loans had equivalent performance to
its competitors?
A. I don't know what it was. I left in 2008,
so I don't know what the performance has been.
Q. When you stated earlier that there were
loan products that Countrywide would not match of
its competitors, could you give me any examples of
loan types that Countrywide did not match?
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THE WITNESS: A FICO loan, a FICO score of
450.
BY MR. SELENDY:
Q. So there's no loan type associated with
that, in your mind?
A. No. FICO applies to every type of loan
it's originating.
Q. Okay. Again, going back to my question.
Is there any loan type that a competitor offered and
Countrywide did not, to your knowledge?
THE WITNESS: I just said -- I repeated.
I'll repeat it over again.
MR. SELENDY: Okay, sir. What I'm trying
to do is find out -- I understand you said there's
certain FICO scores that ordinarily Countrywide
would not want to go below.
Q. Beyond that, is there any loan type that
Countrywide would not offer?
answered, mischaracterizes, argumentative.
THE WITNESS: 125 percent loans, you know,
that's what comes to mind now. I mean, I'm sure
there's other products that I was -- that I'm not
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aware of.
BY MR. SELENDY:
Q. By "125 loans" you mean loans where the
value was 125 percent of the value of the property?
A. Correct.
Q. Okay. Stands to reason not to offer that
product.
A. Well, a lot of it was done.
THE WITNESS: And insured.
MR. SELENDY: This is a document previously
marked as 1356.
Q. The subject line makes reference to a
Compensation Committee. Are you familiar with the
Compensation Committee of Countrywide?
A. I'm familiar with the formation of the
committee.
Q. Was that a committee that was part of the
board of directors?
A. No, only as it related to me.
Q. Okay. And what was the reason for the
formation of the Compensation Committee?
A. The Compensation Committee was not a board.
To my knowledge, this was not a board. I'd have to
read this, but I don't think it was a board
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because it talks about -- I don't recall seeing this

document, but it talks about the top three to five
executives in the 75 percentile of CFC's pay group.
So I think this had to be a board committee, I would
imagine.
Q. Yes. So if you look at the first
attachment, the memo from Stan Kurland to Carlos
Garcia, are you able to determine the different
components of the compensation being awarded to
Carlos Garcia?
A. Am I able to determine from this e-mail?
Q. From the memorandum that has the subject
"2006 Senior Management Annual Incentive Plan."
THE WITNESS: I see here that he had a base
salary of $850,000. Is this Carlos?
MR. SELENDY: Yes.
THE WITNESS: Yeah. And a target of a
million eight if he met certain targets in the plan.
So I think the targets were driven by, primarily,
EPS, I think.
BY MR. SELENDY:
Q. "EPS" meaning earning per share?
A. Right.
Q. Is there any component of compensation here
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committee. There was a board committee that dealt

with compensation. I think it was my compensation,
some of the higher-ups in the company, I think,
whatever the SEC required, the top 10, top 15,
whatever it was, and that committee of the board was
responsible for developing compensation plans for
senior management.
Then within the bowels of Countrywide, I
believe, there was a Compensation Committee that
dealt with all bonus plans for other levels in the
company. I believe that to be the case. I'm not
confident on that.
Q. Okay. Could you take a quick look at the
document and let me know if this allows you to
determine which Compensation Committee is at issue
here?
A. What page are you starting at? Page 1 of
4?
Q. Well, the first page is the e-mail from
Marshall Gates to you, Stan Kurland and Dave Sambol
and then the first attachment is a memorandum from
Stan Kurland to Carlos Garcia, and there are further
memos from Stan Kurland to Eric Sieracki, and from
David Sambol to Drew Gissinger and so forth.
A. This appears to me to be a board committee,
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that you can find that relates to prudent

origination of loans?
THE WITNESS: Yeah, I'm not -- I'm not
familiar with this document, and I'm not prepared to
comment.
BY MR. SELENDY:
Q. Well, it was sent to you, wasn't it, sir?
A. It was sent to me, but I don't recall.
This document was back in -- five years ago.
Q. Okay. Well, let's take a moment to look at
it and see if it helps refresh your recollection.
On the first page, as you stated, there's the
listing of base salary and target award, and then
the corporate earnings per share; is that correct?
A. I think the document says that.
Q. Okay. On the second page there's something
for diversity performance, and it reflects an award
pay-out under the heading of "Women," as an example
of the calculation, of 5,000 and "Minorities" 2,317.
Does that have any relation to the compensation paid
to Carlos Garcia for performance in the category of
"Women" and "Minorities"?
A. I have no idea.
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BY MR. SELENDY:
Q. On page 3 of the memo there is something
that states "Corporate Compliance Internal Audit
Risk Assessment Performance," and there's a box that
shows award pay-out with various percentages, zero
percent, 65 percent, and then 100 percent for the
last three items; do you see that?
A. I see it.
Q. And is it correct that you get a hundred
percent of whatever this element of compensation is
if you meet -- meet the requirement?
A. I don't know.
MS. CONCANNON: Objection. Vague, lacks
foundation.
BY MR. SELENDY:
Q. Well, if you look at hundred percent,
there's the number -A. I don't know.
Q. -- three, says "meets three."
A. I don't know. I don't know what it means.
Q. You don't know.
Did you ever suggest that well, we ought to
have a significant component of senior management
compensation which is based on issues such as
compliance and Internal Audit and risk assessment --
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for the extraordinary annual year results."

So these were all relationships to a peer
group. And I believe, if my memory serves me
correctly, that the board used outside help to
develop this. I had no input into it.
Q. Okay. If you would turn ahead to Bates
numbered page 1567, in the lower right-hand corner,
there's a memorandum from David Sambol to Ranjit
Kripalani; do you see that?
A. Yeah.
Q. Okay. And this shows a base salary as of
January 1st, 2006 of 550,000, with a target award of
6,015,625; correct?
A. That's correct.
Q. And it states, under "Overview," that your
overall award for 2006 is determined primarily on
the basis of net income before taxes for CCM; do you
see that?
A. Uh-huh, yes.
Q. What is CCM?
A. I don't recall.
Q. If you look in the next sentence, maybe it
will help you. It states: "NIBT is defined as the
net income before taxes and before application of
CFC corporate overhead allocations for the CCM
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Mischaracterizes the document and assumes facts not
no evidence.
BY MR. SELENDY:
Q. -- as opposed to earnings per share?
MR. SIEGEL: It's argumentative and
THE WITNESS: This was a -- this was a
program that was developed by the board, and my
understanding was it was based upon a comparison
with other similar financial companies. And the
criteria, my understanding was, all the criteria
of -- of similar companies was examined by the
board. What was incorporated in it, I don't know.
BY MR. SELENDY:
Q. What's the basis of that understanding of
yours?
A. About the board? It says right here in the
beginning.
Q. Okay.
A. "The Comp Committee has asked management to
make its recommendation into its peer group.
The next tier of executives are targeted
between 50 and 75 percentile award to reserve
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companies consisting of CSC, CSE, CAMC" and so

forth.
A. I think "CCM" is Countrywide Capital
Markets.
Q. Right.
A. If you know the answer, why are you asking
me?
Q. Because I need your testimony, sir. I
can't give testimony in this proceeding.
So is it correct -- is it consistent with
your understanding that the overall award for Ron
Kripalani was based primarily on net income before
taxes for CCM?
Mischaracterizes the document, assumes facts, lacks
foundation.
THE WITNESS: I have to rely upon the same
thing you're relying on, that's this document.
That's what it says.
MR. SELENDY: Okay.
THE WITNESS: This was six years ago, six
and a half years ago, and six and a half years ago,
2005, the country -- the company was very, very
profitable, and Ron Kripalani was very instrumental
in that profitability and should have been awarded
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accordingly.
BY MR. SELENDY:
Q. When you say "Ron Kripalani was very
instrumental in that profitability," what's your
basis for that statement?
A. The profitability of the -- get paid a $6
million bonus based upon net income before taxes.
That's my basis.
Q. You said he was instrumental in that. In
what capacity was he instrumental?
A. He ran -- he was a senior executive running
Countrywide Capital Markets.
Q. At the beginning of the deposition I asked
you about your prior testimony. You didn't recall
all the proceedings in which you've given testimony.
I'm not going to ask you about what you said in all
of those proceedings, but I am going to introduce as
exhibits the transcripts of that testimony. I just
want you to confirm in each case that the testimony
you gave was truthful and accurate, to the best of
your ability.
I don't think we have 16 copies of this,
but everybody knows what these are, and I'm not
going to ask questions about each one.
Let's mark as 1417 the transcript of the
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it's very voluminous. But I can assure you, as I'm

doing today, any testimony I give is truthful, to
the best of my knowledge, and based upon what I know
at the time.
MR. SELENDY: Okay. If it helps, these are
apparently in the form that they were produced to us
by Countrywide.
BY MR. SELENDY:
Q. Did you, in fact, testify before the
Securities and Exchange Commission?
A. Yes, I did.
Q. On the date reflected on that document?
A. I don't know about the date.
Q. Let's introduce as 1418 the transcript of
the testimony of Angelo Mozilo before the Securities
and Exchange Commission on August 20th, 2008.
attached hereto.)
MR. SIEGEL: And is that in the matter
of -- is that in the matter of Countrywide Financial
with the SEC file number?
MR. SELENDY: It's in the matter of
Countrywide Financial Corporation, yes.
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proceeding with the United States Securities and

Exchange Commission dated November 9th, 2007.
MR. CLOSE: Counsel, just so we have a good
record, these are complete copies of the one day
mentioned with or without exhibits?
MR. SELENDY: Without exhibits.
MR. CLOSE: Complete copy of the day?
MR. SELENDY: Yes, that's my understanding.
MR. CLOSE: And signed or unsigned?
MR. SELENDY: I believe our copies are not
the signed copies.
MR. CLOSE: Okay. Thank you.
attached hereto.)
MR. SELENDY: And for each of these, if you
could just confirm this reflects your testimony,
first, and secondly, that your testimony was
truthful and accurate.
THE WITNESS: I can't -MS. CONCANNON: Objection to form. Vague
and overbroad.
THE WITNESS: I can't testify that this was
my testimony. It was four years ago. Secondly,
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MR. SIEGEL: Thanks.

THE WITNESS: My response is the same.
Do you want me to keep on repeating it?
MR. SELENDY: I just want your confirmation
that your response is the same.
THE WITNESS: My response is the same.
MR. SELENDY: Let's introduce as 1419 the
transcript of the testimony of Angelo Mozilo before
the Securities and Exchange Commission on August 21,
2008 in the matter of Countrywide Financial
Corporation.
attached hereto.)
BY MR. SELENDY:
Q. Same response?
A. Same response.
MR. SELENDY: Okay. Let's introduce as
1420 the transcript of the testimony of Angelo
Mozilo on October 2nd, 2008 in the matter of
Countrywide Financial Corporation before the United
States Securities and Exchange Commission.
attached hereto.)
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THE WITNESS: Any counsel find this to be

relevant, or just keep on going?
MR. SIEGEL: This is just something he
needs to do for his record. You answer his
questions.
THE WITNESS: My answer again is the same.
MR. SELENDY: Introduce as 1421 the
transcript of the testimony of Angelo Mozilo on
October 3rd, 2008 before the Securities and Exchange
Commission in the matter of Countrywide Financial
Corporation.
attached hereto.)
THE WITNESS: Same.
MR. SELENDY: Okay. I'd like to introduce
as 1422 the testimony of Angelo Mozilo on January
26th, 2010 in the matter of In Re Countrywide
Financial Corporation Securities Litigation, in the
United States District Court, for the Central
District of California, Western Division.
MR. SIEGEL: Class action.
THE WITNESS: This is a deposition?
MR. SIEGEL: Yes.
///
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attached hereto.)
THE WITNESS: Same response.
MR. SELENDY: And let's introduce as 1425 a
transcript of the FCIC staff interview with Angelo
Mozilo, dated February 17, 2011.
attached hereto.)
BY MR. SELENDY:
Q. My understanding is your testimony in this
proceeding is truthful and accurate, to the best of
your ability at that time?
A. Yes, it was.
MS. CONCANNON: Counsel, do you have a copy
of that? Do you have something I could look at?
MR. SELENDY: It's the same thing. We'll
pass it on down to you.
MS. CONCANNON: Is it Bates numbered in
this action?
MR. SELENDY: No, there's no Bates number
on this one. We'll get you a copy by -- as soon as
we can.
MS. CONCANNON: I'm unaware of how you came
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attached hereto.)
MR. SELENDY: And let's introduce as
1423 -MR. SIEGEL: That's right. Next one's
1423.
MR. SELENDY: -- 1423 the transcript of
Angelo Mozilo on January 27th, 2010 in the matter of
In Re Countrywide Financial Corporation Securities
Litigation. Same proceeding before the United
States District Court, for the Central District of
California, Western Division.
MR. SIEGEL: Day two.
attached hereto.)
MR. SELENDY: And I'd like to introduce as
1424 the third day of testimony of Angelo Mozilo in
the same proceeding, January 28th, 2010, In Re
Countrywide Financial Corporation Securities
Litigation.
///
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to be in possession of that particular transcript;

therefore, I'm unaware of whether that is a full and
complete transcript of his testimony.
MR. SIEGEL: Well, he's not able to attest
that it is a full and complete transcript.
Counsel's question was -- well, you might be able
to, counsel, but I thought your question and the
same response, and he's already answered it, was to
the best of his ability on that day he testified
truthfully, to the best of his knowledge.
MR. SELENDY: That's correct. That's
correct. It's a transcript of the recording made
publicly available by FCIC.
MS. CONCANNON: Thank you.
MR. SELENDY: Let's introduce as 1426 a
transcript of the deposition of Angelo Mozilo, dated
February 25, 2011, in the matter of Syncora
Guarantee versus Countrywide Home Loans.
attached hereto.)
BY MR. SELENDY:
Q. Same question for you, sir.
MR. SIEGEL: I do want -- counsel, with
respect to 1425, just so the record's clear, the
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date on the transcript is February 17, 2011. That's

the date of the transcription, not the date of the
interview.
MR. SELENDY: Okay. What date do you have
showing for the date of the interview?
MR. SIEGEL: It indicates on the first line
the officer from the FCIC said September 24, 2010,
and I think that's clearly more likely to be
accurate.
MR. SELENDY: Yes, let's correct the record
to reflect that.
MR. SIEGEL: Okay.
THE WITNESS: Response here is the same.
MR. SELENDY: Okay. Thank you.
Q. By the way, are you aware of the Bank of
America settlement with Assure Guarantee?
A. No.
BY MR. SELENDY:
Q. No awareness of that at all?
A. No.
Q. Didn't read anything in the press about it?
A. No.
Q. Didn't talk to anybody about it?
A. No.
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were doing things because their competitors

were doing it. They all went broke. We should
not be involved in programs and products simply
because our competitors have them. We should
only conduct activities in the best interests
of our company and shareholders."
Do you see that?
A. Yeah. Another example of my concern over
quality and underwriting.
Q. Yes. You were objecting to the
implementation of the matching strategy by your head
of production, David Sambol; isn't that so?
THE WITNESS: I'm sorry about -Go ahead.
MR. SIEGEL: She objected it
THE WITNESS: Certainly does.
MS. CONCANNON: Correct.
MR. SIEGEL: You can answer.
THE WITNESS: I -- my issue here was -- the
subject was subprime seconds, and my recollection is
as a result of this e-mail, and I believe maybe some
other documentation, we ultimately exited this
product.
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Q. Show you a document that's been marked as

Exhibit 1168.
A. It was about subprime seconds.
Q. Right. And in here David Sambol is
justifying the origination of the subprime seconds
based on the fact that competitors offer the same
product; right?
characterization of the document.
THE WITNESS: I haven't read the entirety
of his...
MR. TU: And the document speaks for
itself.
THE WITNESS: I read the first part of it.
MR. SELENDY: Okay.
Q. Do you see his statement that, "Our current
guidelines for this product are not more aggressive
than those offered in the general market"?
A. Yeah.
Q. And so he's justifying the origination of
these loans on the basis that competitors are
offering it; right?
A. He's entitled to his opinion.
Q. Right. And you respond, saying:
"There was a time when savings and loans
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BY MR. SELENDY:
Q. Again, you were objecting to the
implementation of the matching strategy, in this
case as to subprime seconds, by your head of
production David Sambol; isn't that right?
Mischaracterizes the document and prior testimony.
THE WITNESS: I wouldn't characterize -I'm objecting to subprime seconds, not to the
matching strategy.
BY MR. SELENDY:
Q. So what did you mean when you said, "There
was a time when savings and loans were doing things
because their competitors were doing it and they all
went broke. We should not be involved in programs
of products simply because our competitors have
them"?
A. That's correct.
Q. Weren't you objecting to the idea that a
match itself should be sufficient for your head of
production?
A. No. Totally unrelated to that. My
position is that you have to separate matching from
quality, pricing. We didn't match every loan that's
out there because we felt it was imprudent to do so.
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We got into this product, thought it was a good

product to be into, otherwise we wouldn't be in it.
We thought it would be profitable. I don't know if
this is a result of the HSBC issue. I'm not sure,
because was subprime second issue, what prompted it.
But anytime you do something simply because
your competitors are doing it, irrespective of what
they're doing, you're going to find yourself in
trouble. That's been my experience.
Q. How long was David Sambol head of
production for you?
A. I don't remember. Long time.
Q. And he was primarily responsible for the
origination of loans by Countrywide Home Loans;
correct?
overbroad.
THE WITNESS: That's correct, he was the
leader of that area, and he had multiple
responsibilities. That was one of them.
BY MR. SELENDY:
Q. What were his other responsibilities? Do
you recall?
A. He was involved with Countrywide
Securities. In fact, he helped years ago form it.
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Q. Well, first, does that appear to be

correct?
A. What?
Q. That you asked these nine questions, Steve
Bailey responded with the text in that e-mail?
A. As I said, I don't recall the document, but
this is the -- I don't think I asked nine questions.
Do you -- tell me where I asked nine questions.
Q. I'm just looking at your e-mail, which
says, "I have the following questions," and then
there are nine questions -A. Why don't I have that?
Q. -- in your e-mail. The ninth is on page
3744.
A. Oh, okay. Now I understand it.
Q. First, who was -- what was Steve Bailey's
responsibility as of June 2007?
A. He was head of servicing, loan
administration.
Q. All right. And did you from time to time
ask questions about the status of the servicing
portfolio?
A. As I testified earlier, I -- that's how I
monitored the products, performance of the product,
is through him.
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He was involved with certain aspects of the bank,

with Carlos, because they had an interrelationship.
He's originating the loans; they're buying the
loans. So his tentacles touched a lot of people
just because of the nature of the role he was in.
Q. Show you a document 1343.
A. I don't have any recollection of this
document. I'm having a problem even following it.
Q. Does it appear, sir, that your questions
are the questions in bold, and the text underneath
each of your questions is provided by Steve Bailey?
If you look at his e-mail, it says, "Below are my
comments." It looks like he interspersed his
comments in response to your questions.
MR. SIEGEL: Is that a question?
THE WITNESS: A appears to be, yeah. I
can't tell the bold on this thing because the print
is so small.
MR. SELENDY: The bold text is always with
the numbers.
THE WITNESS: I didn't know that.
MR. SELENDY: No. 1, 2, 3, 4, 5, 6, 7, 8,
9, being nine questions.
THE WITNESS: What's your questions?
MR. SELENDY: Okay.
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Q. Okay.
A. That's the only way I ultimately knew how
they performed.
Q. Okay. And do you recall whether there was
any particular reason at this point in time why you
were asking about the momentum of delinquencies?
A. As I said, this is a company that I was
always deeply concerned about, every aspect of it,
and I don't know what prompted me to ask the
questions, but I asked them.
Q. If you would turn to the -- in the first
question:
"Has momentum of delinquencies abated or are
the percentages continuing to increase?"
Mr. Bailey responds:
"Although there are always seasonality
trends and issues related to the days in the
calendar, fall (i.e., number of days in a
month, etcetera) the general momentum of
increasing delinquencies continues. This is
true in the aggregate and on specific books."
See that?
A. Yes.
Q. Then on the next page, at the bottom of the
page, it states:
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"At the heart of this ongoing increase" -Referring to increase in delinquencies.

-- "is" -And then he gives a series of factors:
"General aging of the portfolio. Higher mix
of riskier products (what was available to the
market); a comparatively high mix of ARM
product that was/is affected by the many
consecutive rate hikes; and, a generally poor
performing '06 book (result of expanded
underwriting criteria)."
Do you see that?
A. What page are you on?
Q. This is the page ending 3742.
MR. SIEGEL: He's referring to this
portion.
THE WITNESS: Okay.
BY MR. SELENDY:
Q. The bottom of the page. Do you see these
factors listed under the statement "at the heart of
this ongoing increase"?
A. Yeah, I do.
Q. Okay. So, in fact, as of June 2007, the
ARM products were being adversely affected by the
many consecutive interest rate hikes; correct?
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beginning of the deposition.

A. When you get to overall and short-term
delinquency, this is a number -- there's a number of
days, months, etcetera, as you stated. And it says:
"In general, lament of increasing
delinquency continues. It is true, in the
aggregate, and on specific books, if you
consider the relatively short term, we enjoyed
a reprieve during the last few months in local
delinquency performance, but it is mostly
seasonal."
Q. "Total delinquency performance."
A. Now, in addition to that, these, as he
said, delinquencies depend on number of days in a
month, but one of the factors you're raising is that
delinquencies have increased because interest rates
have gone up. Interest rates also have come down.
That's why people opt for ARM loans. We don't
mandate anybody to take any loan. We offer them.
Every product they can take what they believe
they're best qualified for.
So that just happened -- at that time
interest rates were rising. I made note of that in
various depositions. I wrote about it and then it
proved to be very wrong, because right after I wrote
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THE WITNESS: Yeah, that -- that's what
he's saying. I accept that.
BY MR. SELENDY:
Q. And in addition, he states that:
"The poor performing '06 book was the result
of expanding underwriting criteria."
Do you see that?
A. That's what he says.
BY MR. SELENDY:
Q. And you accept that as well?
A. I accept as on the face of what he said,
yes.
Q. If you'd turn to question 7, you ask:
"How is the bank" -This is page ending 3744.
Are you there?
A. You know, you keep on doing this out of
context. As I said, I don't recall the document,
but I just want to make sure that this testimony
refers the fact that you're quoting things out of
context.
Q. Well, sir, please feel read to anything
that you need to, as has been the case since the
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about it interest rates started dropping and never

stopped.
Q. All right. If you're done, I wanted to
direct your attention to question No. 7, which is on
page 3744. You ask:
"How is the bank portfolio performing versus
the CHL port?"
Is that the CHL portfolio?
A. That's right.
Q. Let me stop right there.
Why were you asking how the bank portfolio
was performing compared to the CHL portfolio?
A. It was a legitimate question to see if
there was any questions.
Q. When you refer to the "CHL portfolio," what
are you referring to?
A. The loans serviced by Countrywide Home
Loans. Serviced.
Q. So that would include the loans that are in
the securitizations for which Countrywide Home Loans
servicing acts as the servicer?
A. That's correct. It also includes all the
loans in the bank that we're servicing.
Q. And then in your second question, you ask:
"How have the option ARMs performed versus
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hybrids and conforming fixed?"

Do you see that?
A. Where is that?
Q. That's the second part of question 7.
A. Okay. Yeah.
Q. Mr. Bailey responds:
"The bank port is outperforming the nonbank
port across the board as expected, mostly due
to the age of the bank port and the higher
underwriting (bank investment grade) criteria
used in selecting product."
Was that statement by Mr. Bailey accurate,
to the best of your knowledge?
A. Best of my knowledge, it was. First of
all, we had a -- we had a 660 minimum or maximum put
forth by the regulators, so by its very nature, the
loans that were going into the bank had to meet the
regulatory guidelines.
And secondly, pay-option loans, bank
portfolio was hundred percent pay-option loans and
home equity loans. Home equity loans were
typically, as I remember, were interest-only loans,
so the payment was low. Pay-option loans, they had
four different options they could take. So by the
very nature of the product you would expect lower
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customer service department, as well as from

other areas of our servicing division."
Do you see that?
A. Yes.
Q. And you say:
"This is without regard to the Daria
matter, which is a failure whose magnitude is
beyond comprehension."
Let me stop there for a second. What is
the Daria matter?
A. I have no recollection.
Q. That was a servicing failure, I take it.
A. I would assume so. I'm writing to
servicing about it.
Q. In the next paragraph, you write:
"It is clear to me that over the past
several years a tolerance for mediocrity and
ineptitude has been permitted to creep into our
system."
What was your basis for making that
assertion?
A. I expected perfection from the people in
the company, and I expected them to operate at the
highest level all the time. I wanted Countrywide to
be better than great, that required great people.
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delinquencies, versus FHA loans in the portfolio of

Countrywide, which historically had high
delinquencies. And Fannie Mae loans that were
serving certain segments of our society you would
expect higher delinquencies. And that's mixed into
Countrywide Home Loans. It's not in the bank
portfolio. Plus, my job was to try to get as much
information as I could about what's going on in the
company.
Q. Okay. Let's mark as Exhibit 1427 CWMBIA
14070251 through 0254.
attached hereto.)
THE WITNESS: Okay. What's your question?
BY MR. SELENDY:
Q. Okay. You said Mr. Bailey was in charge of
servicing; is that right?
A. Yes.
Q. And on March 24th, 2005 you write an e-mail
to him entitled "Mediocrity," and you say:
"I'm receiving an enormous amount of
complaints from customers who have become so
frustrated with either the complete lack of
response or inadequate response from our
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Mediocrity to me is a cancer, and once you tolerate

mediocrity, you have no chance of success because
good people will not work with mediocre people and
they leave, if we don't (sic) tolerate mediocrity,
and to me, as I said, is a cancer.
And I kept on emphasizing this from 1968
on. I insisted that people operate at the highest
level, and if they're unable to operate at the
highest level, then they leave the company. They
got to bat three fifty for us. If they can't bat
three fifty for us, let them bat three fifty for
another team. That's what it's about.
When I get complaints at my level -- they
have to go to a lot of people to get to me -- that
means that these people are totally frustrated.
That's not good for Countrywide's brand, it's not
good for Countrywide's future.
And so I reacted to it. This is what a
good CEO does, don't ignore what's happening to
their reputation, don't ignore what's happening to
their customers. We were a customer-focused
company. And that kind of situation where I'm
getting calls from customers, complaining about
non- -- being nonresponsive is -- will not be
tolerated by me.
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And that's what this is about.

Q. Did it occur to you that your servicing
operations were extraordinarily stressed by your
mandate to aggressively drive up market share?
THE WITNESS: Totally unrelated.
BY MR. SELENDY:
Q. Really?
A. Totally unrelated, yes. The -MR. SIEGEL: There's no question pending.
THE WITNESS: What?
MR. SIEGEL: There's no question pending.
BY MR. SELENDY:
Q. When you double the size of the loan
portfolio that the servicing arm has to address,
that imposes strains on their ability to service
effectively, doesn't it?
not in evidence.
THE WITNESS: If I doubled it overnight,
yeah. Countrywide portfolio grew incrementally over
years, and we applied a huge amount of technology to
that process. It was more technology applied
than -- needed than personnel. So we were able to
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Countrywide securitizations?
overbroad.
THE WITNESS: I don't know what you're
saying. What are you talking about?
BY MR. SELENDY:
Q. Wasn't that part of your strategy, you
would originate and then service the loans that went
through the securitizations?
A. That's been our strategy since 1968.
Q. Right. So increased originations was tied
directly to increased servicing fees and servicing
responsibilities?
overbroad.
THE WITNESS: Yes. But you're talking
about loans that are processed through a Structured
Loan Desk, which is not technological, which is done
by hand, to one that's -- that's run primarily by
technology. They're very different operations.
Servicing is totally different than originations.
You can service hundreds, thousands of loans per
employee. You can only originate 10 or 12 per
employee.
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service many more loans per employee than they were

prior to the implementation of various technologies.
So I didn't detect any strain on our people relative
to volumes of servicing. What I detected was people
not responding in the manner that I expect them to
respond.
BY MR. SELENDY:
Q. Do you know how much Countrywide, in fact,
grew between 2004 and 2007?
THE WITNESS: No, I don't.
BY MR. SELENDY:
Q. Do you know whether, in fact, to take one
example, the Structured Loan Desk was processing
between 15,000 and 20,000 loans a month as of 2006?
THE WITNESS: I think you better get
yourself straightened out. You want to talk about
originations or want to talk about servicing?
MR. SELENDY: Talking about both, sir.
THE WITNESS: Yeah, you can't talk about
both because they're totally unrelated issues.
MR. SELENDY: Really?
Q. Didn't you, in fact, seek to service the
loans that Countrywide was originating for the
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BY MR. SELENDY:
Q. Is it correct that Countrywide was trying
to service thousands of loans per employee in its
servicing arm?
A. It's correct that we try to be as efficient
as possible and lower our cost of servicing.
Q. But is that number that you gave me,
thousands of loans per employee, accurate as to
Countrywide's servicing operation? Was it accurate?
A. I don't know -- I don't know the specific
number, but it's much larger than the origination
side because the origination side is very
people-intensive. The servicing side is not. Only
gets people involved when a loan goes delinquent.
And if you have a 5 percent delinquency rate, which
we ran about 3 to 5 percent delinquency, I think was
the number, 3 to 5 percent of the loans originated
by the origination department, which they had to do
a hundred percent of the loans. They were only
dealing with 3 to 5 percent of those originations.
So you have to keep it in proper context.
Q. Do you know roughly the size of
Countrywide's servicing operation as of 2007?
A. I only know -- I believe when we sold it to
Bank of America it was about 1.3 trillion, I
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believe.
Q. And in terms of the number of employees in
the servicing operation, do you have any idea?
A. No idea. Despite my criticism, by the way,
our servicing operation was -- was rated very high,
not the highest, by S&P, by Fannie Mae, by Freddie
Mac. We enjoyed special pricing from both Fannie
Mae and Freddie Mac, as well as pricing -- but -access to FHA products because of our servicing. It
was exemplary.
Q. And Mr. Bailey's response to you on page
ending 252, under "customer service response times,"
the last sentence of his e-mail states:
"We simply got too greedy trying to lower
costs last fall and have not adequately caught
up."
Do you understand what he's referring to
there?
THE WITNESS: No.
BY MR. SELENDY:
Q. Did you direct the servicing arm to try and
lower costs even while the overall operation was
expanding in size?
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A. It is.
Q. And what was Jack Schackett's
responsibility at the time?
A. I believe that, but I'm not sure, that
Bailey reported to him.
Q. Okay. And you state in the fourth
paragraph -- sorry, the third paragraph:
"My concerns are further exacerbated by the
fact that it is our strategic plan to double
the size of our servicing portfolio over the
next three years."
Do you see that?
A. Yeah.
Q. That was, in fact, the plan, to double the
size of the portfolio over three years; right?
THE WITNESS: Yeah. I don't know if it was
or not. I'm going by what I've said here, so I
assume it was correct. That was the plan.
BY MR. SELENDY:
Q. You wouldn't have said it internally if it
wasn't true; right?
A. Yes. So you should accept it that way.
///
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THE WITNESS: I wouldn't do that. I want

to make sure that the loans are properly serviced.
And I wouldn't be writing this memo if I was
directing them to lower the amount of employees at
the same time increasing the amount of loans.
BY MR. SELENDY:
Q. So are you saying the servicing side tried
to lower costs on their own without direction from
senior management?
not in evidence, mischaracterizes prior testimony.
MS. CONCANNON: Overbroad.
THE WITNESS: I'm not aware of what caused
him to make that comment.
MR. SELENDY: Are we 1428?
Let's mark as 1428 CWMBIAG-110172 to 73.
attached hereto.)
THE WITNESS: Yeah, what's your question?
MR. SELENDY: Okay.
Q. This is an e-mail that you sent about one
month later to Jack Schackett on the subject of
"Loan Administration"; right?
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BY MR. SELENDY:
Q. In your second paragraph, you say:
"As you are aware, over the past year or so
we've seen substantial deterioration in the
quality of performance both internally and to
our external customers as to the level of
service that we are providing. The issues run
from outrageous disregard for the needs of
customers who have simple and traditional-type
questions, to the same mistake being repeated
time and time again, to putting out to the
public insulting and insensitive
correspondence, to an epidemic of passing the
buck, no sense of ownership whatsoever, to
placing the company in harm's way relative to
the legal implications of irresponsible
behavior, and generally a frightening and rapid
trend toward subpar performance on a large
scale."
Do you see that?
A. Yeah.
Q. And you said "as you are aware" to Jack
Schackett. Had you had prior discussions on the
same subject with him?
A. I don't recall.
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Q. Why did you say, "As you're aware"?

A. I have no idea why I said that.
Q. And you -A. I don't know if I had -- he was copied on
memos that I sent, e-mails I sent.
Q. You were describing your concerns with the
level of servicing performance by Countrywide;
correct, as of April 2005?
A. That's right.
Q. Okay.
A. That was my responsibility as CEO. I might
say that our delinquency ratio is low, foreclosure
ratio was very low. Our performance, overall
performance, in terms of where we were compared to
the industry, was excellent. However, it wasn't
good enough.
Two, I speak in very strong terms to get
people's attention and get them to respond, and
that's what's reflected here.
Q. You weren't stretching the truth to get
people to respond, were you?
THE WITNESS: It's not stretching the
truth, it's emphasizing my concerns, emphasizing my
concerns. That's how I find out the truth.
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his resignation?
MR. SELENDY: What's the objection?
MS. CONCANNON: Assumes facts not in
evidence.
MR. SELENDY: Okay. Let me ask you -- I'll
try to address that objection.
Q. On the first page, 8762, do you see that
Mr. McLaughlin states, "Regrettably, from this note
it is clear to me that I can no longer work for
you," referring to Stan Kurland, "in the capacity of
CFO"? Do you see that?
A. Yes.
Q. Was he tendering his resignation as CFO at
that time?
BY MR. SELENDY:
Q. Do you have any understanding of what led
him to make the statement to Mr. Kurland?
A. I do not. I don't think it was his
resignation if he says, "Therefore, I would like to
discuss how I can transition with another role
within the company."
Q. Right. So resign out of that position and
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MR. SELENDY: Okay. Let's mark as 1429

CWMBIA 12568762 to 8767.
attached hereto.)
THE WITNESS: Yes.
BY MR. SELENDY:
Q. Is this an e-mail exchange you had with
Dave Sambol on July 27, 010?
A. No, I didn't see that.
MR. SIEGEL: Mischaracterizes the document,
I think, inadvertently.
MR. SELENDY: Let's go off the record just
one second.
THE VIDEOGRAPHER: Off the record. The
time is 4:28.
(Discussion held off the record.)
THE VIDEOGRAPHER: Back on the record. The
time is 4:29.
MR. SELENDY: Okay.
Q. What was Keith McLaughlin's responsibility
as of February 8th, 2005?
A. Best of my recollection, he was CFO.
Q. Do you understand what led him to tender
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take some other position?

A. That's what it appears to me.
Q. Okay. You don't have any understanding of
what led him to that point?
A. I don't.
Q. Had he raised concerns about the compliance
of Countrywide with its guidelines? Do you recall?
overbroad.
THE WITNESS: To the best of my
recollection, never with me.
BY MR. SELENDY:
Q. Mr. Kurland has a rather long e-mail to
him. I'd just like to direct your attention to the
bottom of page 662 where Mr. Kurland says:
"Public airing of internal disagreements,
particularly those that have not been fully
disclosed, debated among the executive team, is
not only dysfunctional, but destructive. It is
your responsibility to raise issues, present
your position and participate in the ensuing
debate discussion with the members of the
executive team. It is critical that every
significant financial position or determination
be reviewed with me prior to presentation to
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the board or to the public."

Do you have any understanding of what that
relates to, sir?
THE WITNESS: On the face of it, it seems
to be a reasonable request from the president of the
company to the CFO.
BY MR. SELENDY:
Q. Are you aware of any instances in which the
CFO here made statements that were not consistent
with statements Mr. Kurland once had made?
A. No.
BY MR. SELENDY:
Q. So when this e-mail chain was forwarded to
you and you responded to Keith McLaughlin, did you
make any attempt to determine what the nature of the
falling out was between Mr. Kurland and
Mr. McLaughlin?
MR. PETTIT: Objection. Lacks foundation,
assumes facts.
MR. SELENDY: Let me rephrase the question
in light of the objection.
Q. This e-mail was, in fact, forwarded to you;
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A. No.
Q. -- why that happened?
A. I don't have a recall as to why it
happened.
Q. All right.
A. I think it was just a personality, my
guess, a personality issue.
THE WITNESS: Okay.
MR. SELENDY: Okay. Let's mark as 1430
attached hereto.)
THE WITNESS: Okay.
BY MR. SELENDY:
Q. Okay. This e-mail exchange between
yourself and Dave Sambol concerns an issue relating
to the 1 percent start rate on pay-option ARMs
originated by Countrywide; correct?
A. Correct.
Q. And you raised a concern as to how
Countrywide could justify originating loans with a 1
percent start rate; right?
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correct?
A. Correct.
Q. And then you responded to Mr. McLaughlin;
correct?
A. Correct.
Q. After you responded to Mr. McLaughlin, did
you make any effort to figure out what led to this
falling out -MR. PETTIT: Objection.
BY MR. SELENDY:
Q. -- between Mr. McLaughlin and Mr. Kurland?
characterization, assumes facts.
BY MR. SELENDY:
Q. You can answer that one.
A. I just recall trying to reconcile it,
because I had very high regard for both men. I
thought they were people of enormous integrity and
enormous talent, and I was, as I expressed here -it hurt me personally to see this going on. I never
saw it coming. And I think it resulted ultimately
in -- in Keith deciding to leave the company, is my
recollection.
Q. Again, do you have any specific
understanding of why --
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THE WITNESS: I don't know if I used those

words. My goal here was to get it increased to 2
percent.
BY MR. SELENDY:
Q. You said, "How can we justify originating
loans with a 1 percent start rate"?
A. Yeah. And he told me why, because our
competition's doing it.
Q. And you said, "Thanks for the explanation";
right?
THE WITNESS: I don't know. Where did -MR. SELENDY: At the top of page 795.
Q. You accepted the explanation?
A. It's hard to read this.
Yeah, I accepted it.
Q. Show you a document marked as 1967.
Apparently we have to mark this. Let's mark that as
Exhibit 1431. Yes, Mr. Mozilo, if you could just
hand that to the reporter. This was marked in a
different deposition.
attached hereto.)
THE WITNESS: Okay.
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BY MR. SELENDY:
Q. Mr. Kurland wrote you a memo entitled
"Transition Thoughts" on November 20th, 2005;
correct?
A. Correct.
Q. At the time he wrote that memo was it
intended that he succeed to your position as CEO of
Countrywide?
A. That was my plan.
Q. And why didn't that happen, sir?
A. The transition became difficult and the
board decided that it would not take place. It was
a board decision.
Q. Why did the transition become difficult?
What do you mean by that?
A. There was -- there was a question at the
end of the day. I believe the question of the board
was whether or not, while he served very well as a
second in command, whether or not he'd be the right
person for the command position. It was strictly a
board decision.
Q. When you say "it was strictly a board
decision," wasn't it your view as well that he could
not serve as the CEO after he sent this e-mail to
you?
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in terms of communication, and they asked me to step

aside and they took over. I have no idea what
happened after that.
Q. What was the Michael Dougherty's role?
A. Lead director.
Q. And what was the second incident that you
described?
A. It was a -- as I recall, it was either a
proposal for bonuses or change in compensation for
various executives of the company that was never
sent to me, and Michael Dougherty got very upset
about that.
Q. What was the -MR. PETTIT: Objection. Move to strike the
last portion of that answer as nonresponsive.
BY MR. SELENDY:
Q. What was the problem of the -- what was the
problem with respect to the proposal advanced by
Mr. Kurland?
A. It was no problem with the proposal, as I
recall. It was -- the problem was that he went
through the wrong channels.
Q. And in what respect did he go through the
wrong channels?
A. He went -- he gave it to Mike Dougherty
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THE WITNESS: No. Because after he sent
the e-mail to me, we went through it and reconciled.
BY MR. SELENDY:
Q. So your testimony is that you did not
convey to the board your perception that he was not
appropriate to be CEO of the company?
THE WITNESS: That's not what I said. I
had discussions with the lead director, Mike
Dougherty, about my concerns because of this e-mail,
which I found very unusual, and -- but we resolved
it over time.
BY MR. SELENDY:
Q. So is it correct that you did convey to the
board your perception that he was not appropriate to
be CEO of the company -MS. CONCANNON: Objection.
BY MR. SELENDY:
Q. -- after this e-mail?
A. No. Again, let me state that I had these
discussions with Mike Dougherty. It was resolved
that he would be my successor, and I agreed to that.
And there was a -- months down the line there was
another incident that the board became upset about
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without informing me.

Q. Okay. Let's take a short break and then
we'll -A. Why?
Q. -- conclude the deposition.
I'm sorry?
A. Why?
Q. Because I would like to take a short break
to marshall the rest of our points, and then we'll
conclude the deposition.
A. How much time do we have left?
THE VIDEOGRAPHER: Let's go off the record.
The time is 4:41.
(Brief recess.)
THE VIDEOGRAPHER: Back on the record. The
time is 4:51.
MR. SELENDY: Let me show you a document
that previously has been marked as 1056. And while
you can read the whole document, my focus will be on
Ron Kripalani's statement in his e-mail on the first
page.
THE WITNESS: I don't think I was copied on
this, was I?
MR. SELENDY: No.
THE WITNESS: I'm not familiar with the
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document.
MR. SELENDY: All right.
THE WITNESS: Let me just focus your
attention on the paragraph -- first paragraph in Ron
Kripalani's e-mail to David Sambol. He says:
"FYI, I completely agree with Spector's
note, and this is precisely the type of
behavior and attitude we get from McMurray. If
you read his note below, you begin to see the
type of bureaucrat he is and his office has
become. From our perspective, McMurray is an
obstacle to business who oversteps his domain
as chief credit officer in the sense that he
goes beyond the boundary of his role into the
business unit decision-making process."
Q. Do you see that?
A. Uh-huh.
Q. Did Mr. Kripalani ever share this view with
you?
A. Never.
Q. Were you completely unaware of this tension
between the CSC group and Credit Risk?
THE WITNESS: This is not CFC, this is, I
believe, CCM. Kripalani was in charge of
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"Here's the soft copy of the draft," from John

McMurray to Aratha Johnson. And my first question
is whether this is another memorandum that
Mr. McMurray prepared for you to present to the CFC
board of directors.
A. I'm not sure.
Q. Do you recall whether, in fact, you
presented a memorandum to the board of directors on
the subject of pay-option loans in or about August
of 2005?
MR. SIEGEL: 2006.
MR. SELENDY: 2006. Excuse me.
THE WITNESS: I don't recall specifically
in August 2006, but I think the document speaks for
itself.
BY MR. SELENDY:
Q. Did you agree with the statements in this
memorandum?
overbroad.
THE WITNESS: I wouldn't present it to the
board unless I agreed with it.
BY MR. SELENDY:
Q. And if you would turn to page 2 of the
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Countrywide Securities.
Did you say -MR. SELENDY: I said -THE WITNESS: Yeah, I wasn't -- I wasn't
familiar with this particular tension, but there's
always tension. It's natural in any organization.
There's tension between underwriting and production.
And if that's -- the tension has to be properly
managed. And you'll see through the e-mails that
you've shown me that my ultimate support was for
McMurray, and I supported had his position. So Ron
Kripalani was not the CEO of Countrywide Financial.
BY MR. SELENDY:
Q. So with respect to the ultimate issues of
credit risk, you supported McMurray?
A. Absolutely.
MR. SELENDY: Let's mark as Exhibit 1432 a
memorandum that you sent to the CFC board of
directors entitled "Pay-Option Loans." It's CWMBIA
11533794 through 99.
attached hereto.)
BY MR. SELENDY:
Q. There's a cover attachment stating:
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document, under "Retained Risk Portfolio," the

memorandum states:
"For most loans the company seeks to
transfer as much of the credit risk as possible
through securitizations, loan sales and other
credit enhancements."
Was that an accurate statement as of August
2006?
overbroad.
THE WITNESS: It is a correct statement.
BY MR. SELENDY:
Q. The memorandum goes on to say:
"There is no execution which allows us to
shed all of a loan's credit risk."
Is that for the reason you stated before,
that it's contingent liability?
A. Yes. Plus, many cases we retain a subpiece
on our balance sheet in order to get better
execution, plus the residuals.
Q. Okay. Looking two paragraphs up, there's
the statement that:
"Many argue that current underwriting
standards for option ARMs (which allows
borrowers to state income but do not require
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Page 351
supporting documentation) are not adequate to

address the added credit risk posed by the
aforementioned product features."
Do you have any understanding as to what
that issue concerns as to underwriting standards for
option ARMs?
THE WITNESS: Well, option ARMs were a -my recollection is it was a topic of much
discussion, particularly in the media, and gave
birth to my Wall Street Journal e-mail. As I go
through this, it appears to me this is from -- this
is crafted by John McMurray. And he states here
that:
"Countrywide's management team is
well-aware of the added risk and its potential
magnitude and has exercised extreme diligence
in ensuring the implementation of the most
appropriate and moderate risk mitigation and
management strategies."
Now, this is written by my head of Credit
Risk. If he's comfortable with it, I'm comfortable
with it.
BY MR. SELENDY:
Q. Do you recall having this discussion with
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the board of directors?

A. I don't know what discussion took place.
Obviously I presented it. I'd have to speculate on
whether John was there, what discussion took place.
This is what, five years ago. I don't know how many
years ago it was. Yeah, five years ago.
MR. SELENDY: Okay. That's it. We're
done.
THE WITNESS: Thank you.
MR. SELENDY: Thank you.
THE VIDEOGRAPHER: Well, this concludes the
deposition of Angelo Mozilo, Volume No. 1. The
number of tapes used was four. And the original
videotapes will be retained by Merrill Legal
Solutions at 20750 Ventura Boulevard, Suite 205,
Woodland Hills, California. Going off the record.
The time is 4:57.
///
///
///
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Declaration
I hereby declare I am the deponent in the

within matter; that I have read the foregoing
deposition and know the contents thereof, and I
declare that the same is true of my knowledge,
except as to the matters which are therein stated
upon my information or belief, and as to those
matters, I believe it to be true.
I declare under the penalties of perjury of
the State of California that the foregoing is true
and correct.
Executed on the
day of
,
2011, at
, California.
Witness
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Page 352
I, Philip D. Norris, a Certified Shorthand

Reporter for the State of California, do hereby
certify:
That prior to being examined, Angelo
Mozilo, the witness named in the foregoing
deposition, was by me duly sworn to testify the
truth;
That said deposition is a true record of
the testimony given and was taken before me at the
time and place therein set forth, and was taken down
by me in shorthand and thereafter reduced to
typewriting via computer-aided transcription under
my direction;
I further certify that I am neither counsel
for, nor related to, any party to said action, nor
in anywise interested in the outcome thereof.
In witness whereof, I have hereunto
subscribed my name this
day of
,
2011.
Philip D. Norris
CSR NO. 4980
24
25
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MOZILO - 6/21/2011
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MOZILO - 6/21/2011
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cltvs 199:23
clues 78:13 79:18

80:5,15,21 81:9
266:22 283:2
286:7
cmd 115:14,22
116:3,7,13 165:18
cobb 3:12 13:24,24
cocounsel 258:8
coffee 240:16
cofounded 17:4
collapse 58:24
129:9 209:12
219:11 248:4
257:6 259:5
290:15
collapsed 156:17
collar 58:11
collateral 180:22
217:6 232:25
column 109:2,9
110:2
combination
205:21
combined 142:22
come 25:23 74:12
91:11 123:16
125:21 126:3,14
222:19 255:2
259:23 262:12
274:20 319:17
comes 64:15
113:11 238:8,14
292:24
comfort 179:18
289:6
comfortable 19:7
97:13,14 349:22
349:22
comfortably 131:1
coming 34:3 64:23
199:11 257:6
271:23 338:21
command 341:19
341:20
commandments
27:25
commencing 3:3
comment 62:8 63:1
68:6 153:2 175:20
237:24 296:6
330:15
commentary
173:23
comments 314:13
314:14
commission 42:10
269:3 278:13,25
279:1,8,15,19
280:25 281:9,18
302:2 303:11,17
304:9,22 305:10
commissioned
278:24
commitment 272:9
272:10
committed 120:16
committee 192:22
193:7,13,16,21,24
208:25 209:2
293:14,15,17,18
293:22,23 294:1,1
294:5,9,15,25
295:4 298:22
common 86:16
145:19 163:2
communicated
62:18
communication
225:7 343:1
communications
131:18
communities 84:2
community 84:3
239:2
comp 298:22
companies 40:10
40:11 130:15
131:6 156:1
224:23 259:11,12
262:10 270:25
273:10 298:12,14
300:1

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company 17:4,21
17:23 18:6,8,18
18:22 19:12,14
21:15,22,23 22:1
22:4,8,15,16,17
22:18,21 23:4,10
23:17,24,25 27:2
27:4 29:9 30:8
32:15 35:25 40:22
41:13,15,16,18
48:3,10 51:1,21
61:19 62:19,21,22
62:22 63:22 90:7
91:13 112:23
120:4,7 121:24
122:11,15 128:23
129:2,3,3,13
132:19 138:9
144:6 151:8 158:8
158:10 168:8,24
169:1,2 170:1
171:8,10 174:20
174:23 175:10
176:13 178:25
189:13,15 203:15
211:23 214:18
215:14 216:5,7
221:17,21,25
225:1 243:12
253:25 256:14
257:1,13,17
261:24 264:17,18
270:5 271:22
274:1 275:21
280:9,15,22 286:4
291:13 294:3,11
300:23 311:6
316:7 322:9
323:23 324:9,22
332:15 335:24
337:8 338:22
342:7,17 343:10
348:3
companys 60:18,22
67:24 68:11 216:2
272:11
1-800-325-3376
comparable 182:17
290:9
comparatively
317:7
compared 320:12
333:14
comparison 273:10
298:11
compelling 53:4,9
compensate 28:6
compensated 169:4
268:20,24 269:8
277:25
compensating 28:3
64:11 75:4,6,20
76:2,17 77:3,11
77:15,23 78:8,11
78:20 88:9 102:25
282:17,19 284:9
284:11 288:17
289:11,24
compensation
169:5,11,20 171:9
276:14,19,21,23
276:25 277:7
293:14,15,22,23
294:2,2,6,9,15
295:9,25 296:21
297:10,24 343:9
compete 51:10 53:5
71:19 72:4,5
270:25 291:2
competed 32:9,10
competition 137:17
138:17 142:8
239:24 280:1
290:6,12
competitions 340:8
competitive 69:19
136:10 138:13
180:8
competitor 52:21
68:23 69:14 70:2
71:2,17,18 73:9
291:10 292:10
competitors 49:12
53:7,22 54:14
71:15 88:22
110:16 126:6
128:21 138:8
195:7,18 266:6
270:16 271:12
290:10,18,23
310:6,21 311:1,4
312:14,16 313:7
compilation 92:15
complaining 239:4
324:23
complaint 7:11
48:13,20,23,24
52:18 55:17 60:16
62:3,10 63:6 65:1
78:4 79:5 85:19
213:23
complaints 322:23
324:13
complete 252:18
302:4,7 308:3,5
322:24
completely 54:24
345:6,21
completing 210:22
complex 22:1,8
101:5 168:7 223:7
231:18 268:25
complexity 223:4
compliance 297:3
297:25 336:6
complicated
186:18 222:18
component 110:4,8
165:21 295:25
297:23
components 295:9
compound 25:5
26:2 27:21 39:23
50:11 52:6,22
55:23 59:9 88:4
104:6 234:12
249:3 269:5 285:7
286:14 289:13,25
302:23 347:21
compounded 242:3
comprehension
323:8
comprehensive
39:3 210:23 234:2
283:8
compromise
175:19,22
computer 82:22
computeraided
352:13
computers 83:21
concannon 4:5
14:24,24 17:20
20:1,5,24 28:19
31:11 32:21 33:2
33:19 34:22 35:15
36:23 38:21 39:5
39:22 51:18 54:16
55:10 56:25 60:14
66:4 67:11 69:16
70:10 72:11 76:4
76:15,21 77:7
78:25 80:19 81:18
82:12 84:20 86:21
87:19 88:16 92:20
93:15 94:24 95:13
95:16 97:4 99:23
100:18 101:3,22
102:12,21 104:7
105:3 108:17
109:21 110:13
111:3 112:7,17
116:9,18 120:5
121:7,20 122:10
122:17 124:7
126:7 127:2 128:1
128:16 129:24
130:9,22 131:12
131:15 132:6
133:4,16 134:1
135:18 136:24
137:1 139:1,17
140:20 141:23
142:15 143:6,12
144:19 145:13,16
146:5 148:2,20,24
150:11 151:1,14
151:16 152:24
154:19 155:9
157:13,19 158:19
163:17,24 166:19
167:1,17 168:20
170:17,24 174:6
174:10 177:22
178:14 179:22
180:16,24 181:9
181:17 182:21,25
183:3 184:17
185:21 186:11
187:7 188:5,22
189:3 193:9
194:11 195:19
196:6,13 197:5
198:10,16 199:9
199:13 200:4,20
201:6 202:8,19
203:7 206:25
208:12,21 209:18
212:25 213:6,8,17
214:1,6 215:3,17
217:17 218:8,22
219:3,18 220:13
220:25 221:7
223:23 226:17,22
227:12,17 228:13
228:15 229:2,9
230:7 231:8 232:7
233:12 234:12,20
235:7 236:1,17,22
236:25 237:11,25
238:23 239:11
240:5,10 246:9,17
249:16,19,23
251:1,15,20
252:19,25 253:7
253:21 254:16
255:5,11,12,13,14
255:21,24 256:7
257:22 258:5
260:2 261:2,25
264:3,19 265:17

ANGELO
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265:21 266:10
267:24 268:1,5,22
269:23 270:19
271:13 272:5
273:16 274:15,25
276:10 279:11
282:3,7,12,21
283:17,24 284:2
284:13 285:3,6,8
285:20 287:7,16
288:12,21,23
290:25 291:11
292:1,12,21 293:9
295:14 296:25
297:13 298:1,6
300:14 302:21
303:8 307:16,20
307:25 308:14
309:18 310:8
311:13,19 312:6
313:16 318:1,10
325:5,18 326:10
326:16 327:2,15
329:19,25 330:10
330:13 331:16,24
333:22 334:11
335:2,4,16 336:8
337:4,14 338:12
339:25 342:1,18
345:23 347:19
348:9 349:7
conceivable 152:8
concentrated
159:23
concept 103:13,13
279:21
concern 61:13
62:18,24 76:2,17
101:12,20,23
102:5 103:23
104:22 143:8
144:4 155:13
156:10 159:24
163:16 175:9
178:24 232:5
235:24 285:12
1-800-325-3376
311:8 339:22
concerned 20:10
61:13,14,15 62:17
62:23 104:23
106:15 143:15
146:7,8 153:8
154:24 155:21,22
156:7,8 157:3,5,8
158:11 174:18,20
174:22,22 175:24
203:18,20 316:8
concerning 241:22
concerns 63:7
102:9 134:5 144:1
144:5,7,10 148:7
149:24 156:5
163:11,14 203:23
213:25 215:24,25
260:14 331:8
333:6,24,25 336:6
339:18 342:11
349:5
conclude 344:5,10
concluded 83:11
concludes 350:11
concluding 259:19
conclusion 18:4,16
23:7 31:16 33:23
34:23 50:24
131:16 193:19
conclusions 38:6
conditions 201:2
254:7
conduct 259:1
311:5
conference 105:25
106:25 107:11
116:24 132:12
239:3 277:16
conferences 173:25
175:20
confident 57:22
77:21 122:2
129:11 168:23
284:20 294:12
confidential 225:6
confine 61:25
confirm 301:19
302:17
confirmation 304:4
conflict 129:17,22
133:9
conform 78:22
133:10
conformed 130:20
conforming 58:3
275:6 284:6 321:1
conformity 77:5
130:7 288:1
congress 83:4,4
connect 278:14
connection 31:23
230:5
consecutive 317:9
317:25
consensus 235:19
consent 7:9 44:10
45:4,12,13,23
46:1
consents 45:19
consequence
154:11
consequences
142:25
conservative 57:10
consider 65:14,23
128:5 133:5,17
144:5 145:1,10
174:11 179:3
182:9 271:25
319:8
consideration 80:1
238:8 277:6
considered 38:13
58:19 77:11 96:14
133:18
consist 210:23
consistency 80:24
80:24 81:5
consistent 133:1
207:7 220:5
247:20 271:11,17
300:10 337:11
consistently 290:13
consisting 300:1
constant 61:12
175:21
constantly 54:1
constraints 230:22
consumer 124:23
263:23
consumers 123:13
264:8
contact 24:13
91:11 93:10 175:5
content 86:2
contents 351:7
context 22:10 47:2
55:15,16 79:14
137:4 179:4 182:7
250:20 255:22
318:20,23 328:21
continents 18:10
contingent 60:6
62:25 156:13
262:3,6,13 348:17
continually 238:12
continuation
159:11
continue 85:22
91:18,22 136:16
182:18 189:8,18
238:16,17
continued 58:25
92:13 260:18,20
261:17,22
continues 142:10
316:20 319:6
continuing 104:20
124:6 279:1 281:9
316:14
continuous 254:12
continuously 25:7
62:16 63:3 139:20
continuum 61:18
contract 172:9
243:20
contracted 13:15
contracts 74:15
contrary 201:24
contrast 57:9
147:25
contributed 230:20
contributing
235:17
control 172:10
210:20,20 211:20
212:1 214:25
215:2,7,15,20,25
262:17 268:9,9
controlled 246:5
266:21
controls 165:13
167:7 210:18
267:13
convenient 234:1
conventional 52:10
convey 170:10
342:6,15
conveyed 125:16
194:18 248:10
conveying 232:4
copied 333:4
344:22
copies 106:7
301:22 302:4,10
302:11
copy 19:25 20:24
209:21 242:20
302:7 307:16,23
347:1
copying 224:9
231:15 233:25
core 71:8 264:16,23
corner 277:23
278:4 299:7
cornerstone 85:10
263:23
corp 1:7,8,9
corporate 264:11
296:15 297:3
299:25
corporation 1:4 2:4
2:5,8,9 10:13,18

ANGELO
MOZILO - 6/21/2011
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10:23 14:19 18:14

107:3,9 117:2
130:19 131:10
132:3 209:22
239:8 240:9
277:15 303:25
304:11,21 305:11
305:19 306:11,23
correct 16:14 18:20
20:3 21:19,23
27:5,18 30:15
32:15,17 42:5
45:2,6,14,23,24
46:1,23 47:8 48:4
48:10,11 49:18
50:5,13 55:22
56:5,10 62:4,11
67:10,12 68:10
69:25 70:16 72:9
76:13,20 79:4,6,8
93:14,18,25
102:17 104:5
106:21 107:1
108:12 110:11,12
111:1 112:8
114:14 118:7
133:25 135:8,14
135:17 136:3
138:4 141:22
142:5,14,17 143:5
145:15 147:18
148:18 150:24
153:24,25 154:18
155:15 156:21
164:25 173:5,9,13
173:14 178:9,10
181:16 185:11
195:15 200:10
205:10 206:12
211:24 218:17
232:6 251:5 260:9
274:22 275:10
276:9,13,14 277:1
281:20 293:5
296:15 297:9
299:13,14 300:10
1-800-325-3376
308:11,12 309:10 country 40:5,6,25

41:3,15 56:13,14
311:19 312:18
81:2 113:4 259:16
313:15,18 315:2
264:10 300:23
317:25 320:22
countrywide 1:7,7
328:2,5 331:19
1:8,8 4:3 10:12,17
333:8 338:1,2,4,5
10:22 11:9 13:7
339:20,21 341:4,5
13:10 14:25 17:3
342:15 348:11
17:10,19 18:3,13
351:14
19:1 20:14 22:2
corrected 167:13
22:20 25:2,14
correction 275:13
27:9 28:15,17
corrective 167:12
29:2,5,7,13,14,23
243:6
30:3,20,21 31:10
correctly 148:17
31:20,23,24 32:13
206:15 299:4
33:11,15 34:6,12
correspondence
35:20 37:2,4
332:13
39:12,19 40:3,15
corroborate 102:20
41:13,20 42:3
cosigner 75:23
43:8 49:10,24
cosigning 88:9
50:1,13,19 51:16
cost 227:4 263:22
52:4,18 53:15,17
328:6
53:20 54:12,22
costs 58:14 329:15
55:8,12,20 56:7
329:23 330:8
56:17,19 57:8,14
couldnt 33:24 54:4
57:21 58:1 59:6
88:21 113:8,14,15
60:3,24 61:20
147:19 166:24
62:6,12 63:9,20
197:3 270:24,25
65:13,22 66:12
280:3,12
70:5 71:1,20,21
counsel 3:7 13:20
71:22 73:6,8,20
14:4 16:2,20,21
73:21,24 74:2,12
46:9,10 81:23
74:22 78:11 79:3
113:2 131:19,19
79:10,15,18 80:15
131:22 152:15
81:12 86:20 88:25
165:2 202:16
90:7,9,20 92:19
210:6 256:3
93:10,25 95:9
275:20 302:3
99:14 105:25
305:1 307:16
107:2 115:5,6
308:7,24 352:15
117:2,17 118:25
counselor 149:2
120:3,16 121:23
counsels 201:24
123:20,24 124:4
202:3 247:7 308:6
125:6,21 126:2,4
count 105:22
126:5,14 127:25
278:11
128:3 130:19
counted 170:3,8
131:2,9,19 132:3
counteroffer 166:2
135:3,15,25
136:22 137:2,22
138:15 139:24
141:21 144:14,21
146:10,14,23
147:9,10,17,23
149:3,11,21 150:8
150:24 153:24
155:7,7,14,20
156:11,12,24
157:4,5,10,17
158:17 163:8
166:23 170:13
172:2 175:22
179:2,13 180:2
189:15 191:17,19
192:13 193:16
194:6 195:5,17
200:9 204:8,25
209:21 212:2,23
213:23 214:25
219:1 220:3,11
221:6,22 222:1,3
222:6,20,21
223:20 224:21
227:8,19,25 228:8
228:11 233:16
235:20 237:7,20
238:7 239:8 240:2
240:9 246:6,15
248:17 252:4
253:4,4,11,17
254:12 259:7,19
262:12 266:15
267:8 268:19
269:4 270:13
273:13,25 277:15
281:24 282:2
286:11,12 287:4
287:13,23 289:9
289:18,21 290:22
290:24 291:10,16
292:11,17,20
293:15 294:8
300:3 301:12
303:7,22,25
304:10,21 305:10
305:18 306:11,23
308:18 313:14,24
320:17,20 322:2,6
323:24 325:22
326:8,25 327:1
328:2 333:7 336:7
339:20,23 341:8
346:1,12
countrywideexcl...
227:21
countrywides 25:9
31:21 36:10,11,22
38:7 53:3 55:18
63:14 67:22 68:10
71:25 72:23,24
73:4,11,16 74:19
78:6,14 85:21
86:8,11 87:16
100:16 117:10,21
124:18 129:17,19
137:15 145:12
151:12 152:21
194:7 195:18,25
210:16 232:5,18
232:23 233:1
235:18 238:13,18
245:18 251:12
263:23 266:14
270:15 290:17
324:16,17 328:9
328:23 349:15
counts 65:19
county 1:2 2:2 13:9
13:11 156:23,23
couple 155:18
192:18
coupled 180:9
217:6
course 278:11
court 1:1 2:1 13:8
13:11 15:5 43:19
305:20 306:13
cover 120:20 152:4
346:25
coverage 30:13,20

ANGELO
MOZILO - 6/21/2011
Page 362
covered 121:9
208:23
covers 152:8
cra 84:3
craft 220:20
crafted 349:13
create 73:10,15,25
80:15 176:12
264:7 279:25
created 29:23 40:2
40:21 53:16 79:15
79:17 80:23 83:8
94:2 165:25
166:10,14 204:23
250:25
creating 192:23
credit 63:17 64:10
64:21,21 65:3,9
120:20 121:5,14
121:19,24 122:15
134:13 139:9
142:23 143:8
153:6,6 165:15
167:9 175:8 177:4
177:6,14 178:9,12
179:5,9,13,17,21
180:1,3,10 181:23
181:25 182:13
186:9,16,21,24
187:3,12 188:11
188:25 197:22,25
198:4 199:11,20
200:9 203:2,3,10
203:18,21 204:21
208:25 209:1,6
210:22 211:19
212:18 213:4,25
215:7 218:16
221:17 225:16,18
225:22,24 227:1
230:18,22,25
232:20 234:5
236:14 245:22
246:3 247:22
248:1,20 254:7
255:1 259:22
1-800-325-3376
260:7,19 261:13
262:16 263:10
345:13,22 346:15
348:4,6,15 349:2
349:21
creditsensitive
232:19 238:18
creditworthiness
81:6
creep 323:18
crisis 9:12 41:24
250:8 252:5,13,18
252:24 254:5
257:1,2 259:9,9
261:7
criteria 87:17
123:13 188:2
298:13,13 317:11
318:7 321:10
critical 336:23
criticism 237:16
329:4
crutcher 5:12
14:21
crux 238:15
cruz 97:24
csc 233:10 300:1
345:22
cse 300:1
csr 352:23
culture 52:2 71:20
119:21 121:22
cumulative 162:20
curious 281:7
current 145:3
179:15 310:16
348:23
currently 142:21
customer 54:2,3
110:21 323:1
329:12
customerfocused
324:21
customers 53:13
74:8 127:11
137:24,25 138:10
266:20 270:9
322:23 324:21,23
332:6,9
cut 258:22
cwmbia 7:14,19,21
7:24 8:4,7,10,12
8:14,17,21,23 9:4
9:7,9 11:12,18,21
11:23 134:18
153:12 164:14
176:16 197:8
203:25 214:8
216:11 240:23
244:14,19 322:10
334:2 339:11
346:19
cwmbia00115337...
12:5
cwmbiag0000092...
9:13
cwmbiag0000110...
11:16
cwmbiag0001097...
11:11
cwmbiag110171
171:13
cwmbiag110172
330:17
cwmbiag92601
250:2
cwmbiag96887
141:12
cycle 198:6 199:7
D
d 1:24 2:24 3:5 7:1
8:1 9:1 10:1 11:1
12:1 352:2,23
dade 156:23
daily 24:23
danielle 3:19 14:5
daria 323:6,10
data 274:3,8,10
date 13:13 17:14
106:18 204:19
252:7,8,9,10
261:7,8 303:13,14
309:1,2,2,4,5
dated 93:2 97:22
164:22 194:3
202:9 212:8 247:9
302:2 307:7
308:16
daughter 93:4
dave 7:18 24:10
37:8 39:9 61:20
69:5 163:12 173:4
202:17 222:14
233:25 275:21
294:20 334:9
339:18
david 4:12,19
14:13 15:3 16:22
16:25 48:14 49:8
114:6,13 123:1
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64:16 70:5 71:7
101:16,21 102:9
72:2 73:7,11,17
102:11,16 103:20
73:25 74:9,14
103:24 110:21
78:22 79:24 80:13
112:5 123:10
80:16 83:15 86:8
124:5 130:4 143:4
86:11 87:15,20,22
148:17 150:7,23
87:25 88:3,13
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89:5,14,15,16,17
173:12 174:4,15
89:23 90:13 91:10
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93:21 103:16
111:24 112:4
124:10 130:4,6,12
130:14 141:20
142:21 146:20,23
147:1,10 149:12
150:16 151:3,7,12
152:21 155:8,14
156:13,16,18,24
156:25 157:1,4,6
157:9,10,16
159:19,24 160:12
165:23 166:11,13
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326:15,25 327:9
327:18,23 328:3,8
328:17,19 330:2,5
339:23 340:6
346:19 347:9
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local 266:4 267:14
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logic 286:20
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long 17:2 37:21
42:2 84:3 112:23
128:6 129:1 147:7
147:17 200:15
231:18,19 234:13
261:13 313:10,12
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longer 154:24
156:24 335:10
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look 19:5 26:7 28:8
32:2 47:3 64:18
76:11 77:10 82:5
82:20 83:15 84:11
95:23 100:7 106:9
137:8 151:3 153:9
158:5,14 173:1
182:6 186:20
197:17,24 198:23
201:23 207:5
232:2 236:5 239:1
245:2 246:14
254:2 256:11,24
259:18 275:5
277:23 286:12,18
294:13 295:6
296:11 297:16
299:22 307:17
314:12
looked 75:20
102:24 151:7
159:4 165:5
166:11 236:19
looking 28:2 54:2
106:12 118:15
144:17 159:14
161:11 178:2
198:25 199:1
203:22 242:22
272:15 315:9
348:21
looks 158:16 160:2
314:13
los 2:2 3:22 4:16,24
5:8,15,23 6:8,15
13:10 14:9,11,13
14:16
lose 41:6,7,7
loss 216:24 226:5
228:24 229:22
230:2,5 241:19
losses 39:18 160:16
248:6
lot 43:5 86:14
91:10 169:14
170:4,4 174:2
199:22 204:17
232:10,11 280:4
284:16 293:8
314:4 324:14
lots 261:16
low 65:14,23 66:3
181:6 194:7 195:2
195:16 206:8
321:23 333:12,13
lower 75:12 263:22
277:22 299:7
321:25 328:6
329:14,23 330:4,8
lowest 56:11,12,13
56:20,21,22
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123:9 124:13,20
124:21,22 125:16
128:5,13,18,19,20
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114:1 191:6
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massachusetts 4:7
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270:24 290:22,24
291:17 312:20,24
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269:16
matching 54:22
67:22 68:11 72:22
269:12 270:14,22
270:23 311:11
312:3,10,23
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matter 13:7,10
19:7 40:1 100:15
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303:21,22,24
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351:6
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matthew 6:13
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13:10,23,25 14:4
14:6 29:21 30:2,4
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35:21,24 36:9,16
36:25 39:18 40:3
40:6,6,15 57:18
95:17 105:1 153:4
155:20 158:16
159:5 183:21
262:11 286:16,25
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35:20
mclaughlin 177:2
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337:17,20 338:3,6
338:11
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mind 19:24 27:1
62:9 113:11
222:19 251:24
291:7 292:6,24
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183:2 185:7,20
186:10 187:6
188:4 196:12
198:9 200:3,9
201:18 202:24
203:2 205:10
211:6 218:16
220:12 225:25
226:11 227:10
229:16 237:23
241:14 243:15
244:5 245:11,12
246:8,11 259:18
263:5,19 264:2,6
264:18 265:4,10
265:15 266:9
271:1 276:5
295:24 298:19
300:5 306:7 310:4
310:7,22,24 312:5
315:20 319:25
320:3,9,10 322:18
327:12 330:25
331:15,22 333:9
335:25 339:5,24
340:10 341:19
345:2
righthand 210:8
277:22 299:7
rights 162:2
rise 135:6 185:14
risen 135:10
rising 255:1 259:22
319:23
risk 31:2,4 32:8
36:2 37:25 41:4
51:6 59:17 60:8
60:18,22,24 61:1
61:10,14,16,23,23
61:24 62:6,12,17
62:23 63:7 120:11
120:17 121:5,14
121:19,24,24
122:15 134:13
139:9,23 143:8,10
144:13,22 146:7
146:11 148:13,17
153:6 156:7,9,10
156:12,13 159:24
162:25 163:1
165:12,15 166:3
167:9 177:4,6,14
178:9,12,21,21,25
179:1,5,8,9,13,17
179:21 180:1,4
181:23,25 182:13
182:19 183:21
184:5,6,13,13,19
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248:12,15,16,20
257:15,18 261:13
261:14,15,17
262:11,15,16
264:15,18 265:3,6
267:13,14,15
297:4,25 345:22
346:15 348:1,4,15
349:2,16,19,22
riskbased 165:23
165:24 182:15
riskier 49:13 55:21
55:21 56:8 57:8
58:2 59:6 146:25
181:5,5 185:19
317:6
risks 78:9 131:9
132:3 138:24
139:15 140:13
145:11 179:7
261:24 262:18
risky 146:4
rmbs 28:17 29:5,15
29:23 31:24
road 142:24
role 30:2 36:24
97:10,10,18
209:15 239:12
314:5 335:23
343:4 345:14
rolled 124:4
rolling 123:21
ron 6:3 14:8 191:13
231:14 275:16
276:8 277:1
300:11,24 301:3
344:20 345:4
346:11
rose 135:17 136:2
1-800-325-3376
156:17
278:14
roughly 118:16
salespeople 73:7
125:5 328:22
125:19 126:3
route 163:20
127:10 268:20
ruined 39:17
269:4 272:24
rules 15:23 19:14
280:21
36:15 82:3 133:10 sambol 4:19 7:18
162:3
14:13 16:25 24:10
run 22:7,15 41:13
37:8 39:10 48:14
79:23 270:5
49:8 60:23,25
327:20 332:7
61:20 62:5,11
running 253:5
69:5 85:20 114:7
301:11
114:13 123:1,7
125:3,15 127:6,21
S
127:23 128:4
s 1:25 2:25 3:5 5:20
160:7 163:12,14
7:5 8:2 9:2 10:2
173:4 175:16,24
11:2 12:2 41:16
194:3,6 195:1,24
56:15 123:17
196:23 202:10,17
329:6 351:19,19
213:15 222:14
sacrificed 271:20
224:9 225:9
safe 129:13,14
226:14,20 228:23
sake 176:12
230:11 231:15
salable 60:4 71:10
233:25 242:6
85:22 165:22
245:5 275:21
166:18
294:20,24 299:8
salary 169:22
310:4 311:12
170:10,10 278:13
312:5 313:10
295:16 296:14
334:9 339:18
299:11
345:5
sale 21:11 73:16
sambols 159:16
163:4 172:2 184:2 samuels 275:20
241:13 243:18,18 sandefur 6:3 14:8
sales 73:11 74:14
24:21 37:9
115:13 116:17
sandy 275:20
121:4 125:6,12,17 sarah 4:5 14:24
125:24 126:10,13 satisfactory 238:9
126:21,22,24
satisfied 87:16
127:1 160:14
satisfy 274:23
267:22 272:1
save 172:10 256:14
273:25 277:25
265:12
278:24,25 279:1,8 saved 102:3
279:15,19 280:25 savings 310:25
281:9,18 348:5
312:13
salesman 268:15
saw 104:2 133:9
salesmen 268:12
141:19 146:4
219:21,23 338:21
saying 18:25 56:3
76:9 110:8 117:18
122:2 138:21
139:9 152:7,10
159:16 160:8
203:3 220:9,17,24
221:2,4 224:16
225:9 227:3
230:11 255:4
256:6 291:16,19
291:20 310:24
318:3 327:6 330:7
says 44:21 79:9
95:3,5,5 96:7
107:2,6,25 108:24
109:2 116:19
117:4 135:19,21
145:24 161:11,24
181:11,13 182:11
182:20 186:23
187:23 188:15
194:14,16 198:12
199:1,17 200:5
204:12 217:1,3
219:13,25 230:13
230:16 243:14
244:4 247:13
249:10 278:7
296:16 297:19
298:19 300:19
314:12 315:10
318:9 319:4
335:22 336:15
345:5
scale 332:19
scammahorn
231:14
schackett 330:24
332:23
schacketts 331:2
schloessmann
231:17 232:4,15
234:3 235:16
237:19 238:4
239:6,16
schloessmanns
233:7 235:4
239:12
school 43:11 50:18
50:22
score 65:3,4,9,10
65:12,14,23 66:2
75:12 76:12
218:11,15,16
292:2
scores 58:18,22
63:16,24 286:22
291:17 292:17
seasonal 319:11
seasonality 316:16
seasoned 173:20
seasons 13:19
sec 9:18,21,24 10:5
10:8 42:9 43:6
48:13 49:6 56:1
61:17 62:9,10
64:16 67:21 68:7
294:4 303:23
second 19:21 20:17
21:4 45:18 51:22
63:12 66:10 78:5
83:14 94:8 98:6
100:10 109:1,2,9
110:2 115:19
117:12,13,15
123:3 132:19
142:19,20 154:1
159:15 164:20
165:4 169:21
176:25 183:17
194:25 195:4
205:13 217:3
235:5 243:4 245:4
245:4 247:24
256:5 260:19
261:7 271:3
285:16 296:17
313:5 320:24
321:4 323:9 332:2
334:15 341:19
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60:4 69:10 71:10
85:23 111:25
160:12,23 162:15
162:24,25 163:11
166:25 183:19,19
184:6,23 186:6
192:14 230:18
275:6 283:25
secondly 88:24
97:9 144:1 156:5
158:9 234:14
237:16 243:20
266:18 302:18,25
321:19
seconds 57:25 59:5
241:9 261:17
285:13 310:3,5
311:22 312:4,9
secret 286:8,9
secrets 149:2
secs 62:3
section 47:23
181:13,21
securities 1:7 7:12
10:13,18,23 14:21
14:22 42:10,12
47:22 130:19
131:2,10 132:3
148:11,12 191:17
191:19 192:6
239:8 240:9 302:1
303:11,16 304:9
304:22 305:9,19
306:11,23 313:25
346:1
securitizable
150:19
securitization
145:10 151:13
152:22 159:20
160:24 162:16
192:14,19 193:1,4
225:17,23 226:1
226:16 227:10
228:18 233:11,15
1-800-325-3376
233:23 243:17
287:19
securitizations
33:13 148:10
149:13 228:2
233:16,17 234:6
285:5,11,12
320:20 327:1,10
348:5
securitize 144:13
145:19,21 146:1,3
146:11,24 148:1
150:17 157:17
185:19 186:1
261:23
securitized 130:15
144:21 150:16
159:23 166:24
175:11 186:3
securitizing 145:2
145:23 155:15
157:1,11
security 227:2
see 20:19 21:16
46:13,20 47:25
62:20 63:18 67:18
73:2 78:2,17,18
84:11 85:24 93:11
94:13,18 95:2,25
98:5,13,16,25
99:2,7 106:19,24
107:2,18 108:6,8
108:25 109:6,11
110:6,23 114:24
115:15 117:8,16
118:4,22 119:12
120:13,22 123:5
123:18 124:25
125:25 127:14,15
127:21 128:11
129:17,22 132:14
132:24 136:19
139:10,16 142:11
143:1 144:7 145:7
154:15 166:5
167:11 176:6
187:20 188:20
194:20 195:12
197:19,24 203:4
203:19,21 205:24
210:12 211:3
212:19 217:12
218:2 220:7
224:15,16 231:3
233:5 238:19
242:21 245:3,7
247:18,23 248:8
252:8,10 260:12
260:24 271:7
278:22 279:4,5
295:15 296:12
297:7,8 299:9,18
310:16 311:7
316:22 317:12,19
318:8 320:13
321:2 323:3
331:12 332:20
334:10 335:8,12
338:20 345:9,16
346:9
seeing 155:25
179:11 192:16
232:12 250:16,18
274:10 295:1
seek 25:13 67:16
146:10 326:24
seeking 50:13
68:22 69:13 70:1
71:1
seeks 348:3
seen 44:5,7,16 45:2
46:5,7 192:12
200:25 217:4
246:21 250:11,13
250:15 274:8
282:1 289:4 332:4
segment 124:20
segments 124:21
322:4
seize 254:10
seized 40:10
seizes 137:22
select 115:17
selected 160:3
selecting 137:7
321:11
selection 147:24
160:21 162:13,21
163:16,23 164:4
selective 159:19
selendy 3:11 7:3
13:22,22 15:16
18:1,12,24 19:10
20:1,4,8,12,16,25
21:3 23:1,14 24:1
25:1,11 26:5,22
27:8 28:13 29:1
29:12,20 31:7,13
31:19 32:11,24
33:9 34:5,14,18
35:1,7,23 36:8,18
37:3,14 38:1,25
39:8,16 42:1,15
42:23,25 43:16,24
44:6,9,15 45:1,11
45:17 46:4 47:5
47:17 48:8,12,18
49:21 50:12 51:14
52:3,16 53:18
54:5,10,20 55:6
55:13 56:2 57:4
57:23 59:3,10
60:9,15 62:2 63:4
65:6 66:1,7 67:1
67:13 68:8,16
69:4,20,24 70:7
70:14,19,24 71:12
72:15,19 73:23
74:17 75:3 76:6
76:16 77:1,14
78:1 79:4 80:14
81:10,19,23 82:2
82:9,14 85:4,17
86:6,18,25 87:6
87:14 88:1,11
89:1,9,21 90:3,18
90:23 93:1,17
95:1,19,22 96:8
96:12,23 97:6,20
98:12,21 99:3
100:14,24 101:18
102:7,18 103:2,5
104:1,11,15,24
105:6,10,17,23
106:5,8 107:24
108:5,18 109:18
109:25 110:14
111:4,13 112:2,9
112:13 113:17,20
114:4,11,23 116:1
116:5,14,21
118:12,19,21
119:15 120:2,8
121:1,16 122:6,13
122:19,25 124:3
124:11 125:10
126:11,19 127:5
127:20 128:10
129:15 130:5,17
131:7,21 132:1,8
132:11 133:7,14
133:21 134:3,12
134:18,23 135:23
137:5,9 138:1,19
139:6 140:1,8
141:2,7,10,16
142:1,18 143:9,17
144:11,17,23
145:14 146:2,9,21
147:15 148:15,21
149:8,16 150:5,12
150:21 151:9,18
151:20 152:2,9,13
152:16 153:12,21
154:22 155:12
157:7,14,21 158:1
158:20 159:8
161:1,5,8,13,20
161:25 162:2,6,8
163:13,21 164:6
164:12,14,19
165:3,7 166:21
167:5,19 168:14
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173:8 174:7
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178:7,16 179:24
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181:12,20 182:5
182:22 183:1
184:10 185:5,16
186:7,20 187:8,15
188:9,23 189:8,18
189:24 190:4
191:12,24 192:9
193:11,22 194:15
194:24 195:23
196:9,19 197:7,13
198:13 199:3,10
199:18 200:7,22
201:11,17,22
202:13,24 203:13
203:24 204:4
206:21 207:4
208:14 209:3,20
210:4,8,11 213:1
213:12,21 214:4,8
214:14 215:9,23
216:10,20 217:20
218:9,25 219:5,12
219:24 220:16,22
221:3,12 222:24
223:15,25 224:3
224:14 226:20
227:7,15,23 228:4
228:10,16 229:6
229:13 230:10
231:11 232:13
233:18 234:17
235:2,11,15
236:11,18 237:5
237:18 238:3
239:5,17 240:6,14
240:18,22 241:5
242:19,23 243:2
244:13,18 245:1
246:2,11,20 247:1
1-800-325-3376
249:7,17,21 250:1
250:6,10,19
251:10,18,22
252:22 253:2,16
254:1,19 255:8,13
255:20,23 256:4
256:23 257:25
258:2,11,13,17
260:5 261:10
262:5 263:2 264:5
265:4,8,14,19
266:1 267:1,11
268:2,18 269:2,9
270:1 271:2,24
272:20,25 273:8
273:20 274:21
275:24 276:16
277:5,20 281:2
282:5,10,16
283:13,21,25
284:7,24 285:4,9
286:1,16 287:3,12
287:24 288:16,24
289:17 290:7
291:5,15 292:4,15
293:2,11 295:17
295:22 296:7
297:1,15 298:4,16
300:20 301:2
302:6,8,10,16
303:5,9,24 304:4
304:7,15,18 305:7
305:16 306:5,9,20
307:5,11,18,22
308:11,15,22
309:4,10,14,19
310:15 312:1,11
313:21 314:19,22
314:25 317:18
318:4,11 322:16
325:7,13 326:7,12
326:20,23 327:7
328:1 329:21
330:6,16,22
331:20 332:1
334:1,7,14,21
335:3,6,18 336:12
337:9,15,23
338:10,14 339:10
339:16 340:4,13
341:1 342:4,14,19
343:16 344:17,24
345:2 346:3,13,17
346:24 347:12,16
347:24 348:12
349:24 350:7,10
selfemployed 101:7
101:8
sell 126:5,14
157:17 163:5
182:3,24 183:18
184:5,13 186:6
265:2
seller 282:1
selling 145:2
162:24 182:18
265:3
send 183:20
sending 202:16
senior 24:3,8 25:13
93:9 154:18
191:14 229:25
253:19 294:7
295:13 297:23
301:11 330:9
sense 159:18 196:4
196:5 332:14
345:13
sensitive 156:2
sent 94:7,16 114:13
135:3 136:21
140:24 142:3
173:3,10 204:24
236:12 296:8,9
330:23 333:5,5
341:24 342:2
343:11 346:18
sentence 20:9
22:11,22 66:10
78:5 117:13,15
124:16 142:20
143:24 144:4
194:16 219:25
245:3,4 299:22
329:13
sentences 137:3,7
sentiment 197:20
separate 151:24
312:23
september 66:14
141:19 142:3
143:11 173:5
177:9 178:11
180:14 198:9
212:8 309:7
sequence 159:12
160:5
series 92:15,18
243:1 317:4
seriously 145:1
164:10,11
serve 47:21 48:2
341:24
served 123:15
341:18
serves 299:3
service 323:1
325:16 326:1,24
327:9,23 328:3
329:12 332:7
serviced 320:17,18
330:2
servicer 320:21
services 253:12
servicing 1:8 41:17
56:15 119:9
174:25 175:6
315:18,21 320:21
320:23 322:18
323:2,12,14 325:2
325:15 326:4,19
327:13,13,22
328:4,6,9,13,23
329:3,5,9,22
330:7 331:10
333:7
serving 322:4
set 119:1,22 206:8
352:11
settle 42:11 160:14
settled 43:15
settlement 44:20
45:20 309:16
seven 48:25 94:4,6
116:4 177:23
seventh 99:4
severance 171:19
171:23
severe 198:6 199:7
sex 81:7
shadow 282:6
shakhshir 247:14
247:17
share 50:2,14 51:2
66:13,15,18 67:7
67:10 71:1 72:8
107:16,17 108:7
108:11,22 109:4
109:15,20 110:10
112:1 116:16
118:1 119:6,9,19
121:3 124:14
128:5 136:11
138:3,13 165:20
165:20 168:19
175:25 177:18
197:20 203:22,23
263:10 266:9
271:4 278:22,23
279:3,10,16 281:5
281:11,15,19
295:23 296:15
298:5 325:4
345:18
shared 144:7
177:10,14 260:20
shareholders 22:19
36:1 133:20,23
158:8 159:6
189:16 311:6
shares 278:15
sharif 247:14,17
shed 348:15
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145:12 146:12,15
146:16,18,25
147:5 185:25
186:2 263:11
264:18 265:2
348:19
sheth 15:17
shift 278:23 279:14
281:4
shifted 279:8
shock 41:24 154:8
shop 110:18
shore 188:13,16
short 19:25 319:8
344:2,8
shortfalls 251:12
shorthand 352:2
352:12
shortterm 147:7
319:2
shouldnt 261:19,19
show 19:19 33:14
116:22 141:10
159:9 192:10
194:1 212:4
223:25 310:1
314:6 340:17
344:17
showed 175:14
180:18 259:14,14
261:12
showing 33:10
233:2 309:5
shown 346:10
shows 45:10 297:5
299:11
shut 215:16,20
sic 235:12 324:4
sick 64:22
side 15:17 195:8
213:23 328:12,12
328:13 330:7
siegel 4:12 15:3,3
16:22 18:4,15
19:2 20:22 21:1
1-800-325-3376
21:24 23:5,18
24:19 25:4 26:2
27:6,21 28:18,20
29:6,16 30:23
31:12,14,25 33:17
33:20 34:9,17,19
35:4,16 36:14
37:11,19 39:13,21
39:23 42:13,16,24
43:2 44:2,18 45:7
45:15 46:2,24
47:13 48:5 49:15
50:6,8,10,16 52:6
52:22 53:23 54:8
54:15 55:3,23
57:1,12 58:5 59:8
59:18 61:3 65:5
65:21 66:5,20
68:2,14,25 70:3
70:17,22 71:4
72:10,17 74:3
75:1 76:24 77:17
78:24 80:18 81:25
84:21 85:6 86:3
86:12 87:4,10,18
88:4,15,17 89:7
89:11,24 90:15,21
93:16 94:23,25
95:12,15,24 96:4
96:17 97:16 98:6
98:9,19 99:1,25
100:19 102:22
103:3 104:6 105:4
105:12,15,22
106:6 107:22
108:2 109:17
111:9,20 112:12
112:15 114:19
116:10 118:8,18
121:21 122:23
123:25 125:9
126:15 127:19
128:15 130:10,24
132:10 133:12
134:8,10,15
135:22 136:23,25
137:3,12 138:5
139:18 140:5,18
140:22 141:5
144:16,20 146:13
147:2 148:5,19,23
149:14,18 150:10
150:15,25 151:15
152:14 155:16
157:23 158:18,23
160:25 161:3,7,9
161:13,18,22
162:1,5,7,18
164:1 165:1,4
168:4,21 169:13
171:5 172:15,18
178:5,15 180:12
182:1 184:15
185:8 187:13
189:10,21 190:3,6
193:8,18 194:12
197:6 198:17,21
201:16,19 202:2
202:11,21 206:13
210:6,9 213:7
216:15 218:23
220:18 222:22
223:11 224:12
227:11,13 228:3,5
234:11 235:14
236:24 237:1
239:13 240:16,20
242:21,25 245:21
246:23 249:3
250:14 256:9
258:7,12,15 261:3
262:22 264:4
265:11,18 266:11
267:9 268:6 269:5
275:1 276:11
277:2 279:12
283:18 285:7
286:13,19 287:6
289:13,25 296:3
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155 100:11
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19 85:18
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169:5 177:9,21
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1968 17:4 51:24
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62:5,13 63:8
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333:8 334:23
169:24,25,25
341:3 347:10
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232:25 259:8
99:18,19 135:3
273:3 296:20
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314:22 340:2
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20 9:22 98:24 99:10
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240:2 247:10
190:2 272:18
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273:23 326:15
295:13 299:12,16
200 94:11
326:15 347:11,12
2002 206:8
347:14 348:8
2003 66:11 67:9
2007 49:7 50:4 52:5
105:25 106:17,20
53:2,20 57:6 61:2
207:9 217:11
61:11 62:1,6,13
219:16
63:8 68:13 74:24
2004 25:3 26:6
104:4 106:16
37:18 74:24 93:3
124:6 125:7 134:6
104:4 106:16,18
169:11 170:15
108:11 111:8,19
224:10 225:11
116:3 125:7
253:6 261:13
129:16 141:19
290:16 302:2
142:3 143:11
315:17 317:23
164:22 165:18
326:9 328:23
2008 17:11 25:3

37:18 67:10 109:5
119:19 129:17
167:21 208:16
253:6 274:9 279:3
281:11 290:19
303:17 304:10,20
305:9
2010 119:3 305:18
306:10,22 309:7
2011 1:18 2:18 3:3
13:1,13 183:11
191:1 307:7
308:17 309:1
351:16 352:20
204 8:16
205 13:17 350:15
20750 13:16 350:15
20th 303:17 341:3
21 1:18 2:18 3:3
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13:1 64:25 191:1
304:9
210 8:19
212 3:16
213 3:23 4:25 5:16
5:24 6:9,16
214 8:20
216 8:23
21st 13:13
22 7:19 43:5 47:6
2297836 5:16
22nd 3:14
23 66:8,9
232 165:3
235 10:6
237 165:11
238 9:25
24 309:7
241 8:8 9:4
244 9:6,9
24th 117:3 118:7
194:4 224:10,17
247:10 322:20
25 9:16 11:10 33:1
33:13 34:2 51:2
67:20 165:20
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308:17
250 9:11
252 329:12
254 11:13
25th 6:7
25year 288:6
26 10:14 72:20
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2604 269:10
26th 305:18
27 7:16 10:19 11:21
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277 9:15
2771010 4:17
27th 106:18 306:10
28 9:6 10:24 334:17
28th 306:22
29 7:13 334:20
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2c 47:3
2nd 304:20
3
3 10:9 52:18 58:11
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328:20,25
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303 9:20
304 9:23 10:4 46:17
305 10:7
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72 86:14
73 330:17
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600 5:22
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777 4:22
610 9:14 250:2
79 100:10
6122433 4:25
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616 94:12
796 11:22
617 4:8
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620 65:12
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625 299:13
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627 94:12
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35 11:6
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355 123:1
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359 124:14
360 125:14
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949 12:8 212:5
9523759 240:23
9554935 203:25
96 339:11
99 346:20
9th 302:2


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FILED: NEW YORK COUNTY CLERK 12/10/2012

NYSCEF DOC. NO. 3811

INDEX NO. 602825/2008

In The Matter Of:

ANGELO MOZILO - 6/21/2011

SUPERIOR COURT OF THE STATE OF CALIFORNIA

ANGELO MOZILO - 6/21/2011

ANGELO MOZILO - 6/21/2011

ANGELO MOZILO - 6/21/2011

WESTLAKE VILLAGE, CALIFORNIA; TUESDAY, JUNE 21, 2011 1

THE VIDEOGRAPHER: Here begins Volume No.

MS. LIBEU: Allison Libeu, Irell & Manella,

MS. KENAUSIS: Michele Kenausis on behalf

truthfully and to the best of your ability, unless

ANGELO MOZILO - 6/21/2011

ultimately responsible for Countrywide?

MS. CONCANNON: Mr. Selendy, before we went

ANGELO MOZILO - 6/21/2011

MR. SIEGEL: I'm sorry, now I do. I was

THE WITNESS: This is a complex company.

ANGELO MOZILO - 6/21/2011

product would have to be approved by you?

guidelines vary -- in terms of the underwriter

ANGELO MOZILO - 6/21/2011

and the other monolines were underwriters and

Q. Prior to your preparation for this

assumes facts not in evidence.

ANGELO MOZILO - 6/21/2011

rate in excess of 25 percent would be unacceptable?

behind what you're talking about. I know nothing

shareholders to make sure they underwrite loans

ANGELO MOZILO - 6/21/2011

problems worrying about the interests of

Q. I'm asking you, sir: Did you ever have any

This is a matter of record. The cause of

ANGELO MOZILO - 6/21/2011

were going to leave their homes because the value of

statement of the ground for the objection.

ANGELO MOZILO - 6/21/2011

lead to the discovery of relevant testimony, and

Consent at the time you signed it; correct?

ANGELO MOZILO - 6/21/2011

Q. I'm going to give you specific statements

company in any one industry you had to have about a

-- "Countrywide, in an effort to increase

motivated us. And it was an important part of our

ANGELO MOZILO - 6/21/2011

that -- what year that developed, whether it was

Q. Isn't that another way of describing the

constantly surveyed the market and also determined

are the SEC statements. These are not mine.

ANGELO MOZILO - 6/21/2011

MR. SIEGEL: Question's vague.

very high quality loans which, again, were reflected

Countrywide was originating in the time period 2005

originated met the regulatory standards.

ANGELO MOZILO - 6/21/2011

about increased risk during this period 2005 through

So I'm not going to comment that this is

ANGELO MOZILO - 6/21/2011

the complaint states:

Do you agree with that statement?

ANGELO MOZILO - 6/21/2011

THE WITNESS: Now it misstates the