DALE LAWRENCE GROSSMAN AUGUST 27, 2008314.621.6173 888.462.2780ESQUIRE DEPOSITION SERVICES, LLP - ST.LOUIS
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A. It was real estate related.
2 Q. And was that -- who were you working with3at the time?4
A. LaSalle Bank.
5 Q. Okay. And did that deposition pertain to6your duties and responsibilities at LaSalle Bank?7
A. Yes.
8 Q. All right. Was LaSalle the defendant or9the plaintiff, if you recall?10
A. Defendant.
11 Q. What kind of -- you said it involved real12estate.13 More specifically, what kind of 14litigation was it, in terms of the allegations that15were made?16
A. Um, a loan had been applied for, it
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wasn't funded, and I believe we were being sued for,
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for -- to fund the loan.
19 Q. Do you recall what -- when that happened,20the circumstances that led to the litigation?21
A. I do not recall when, with any sense of,
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any certainty. I believe, in the due diligence for
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the loan, misstatements by the borrower came to
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light, and we elected not to fund the loan.
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1 Q. Was this, was this a loan that was to be2securitized?3
A. Yes.
4 Q. It was?5 Was this a loan that was, at least6initially, proposed as part of the MFG group?7
A. No.
8 Q. Okay. What, what group at LaSalle was9the loan initially proposed, as part of?10
A. CCG.
11 Q. So would this have been prior to 2000,12can you recall one way or another?13
A. I began working for LaSalle in
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January of 2000, and so while I do not know when it
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occurred, it doesn't seem likely that it would have
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occurred prior to 2000, January of 2000.
17 Q. That's a good, good guess, I would18suspect.19 All right. And how was that matter20resolved, if you know?21
A. I don't know. I do not know.
22 Q. Okay. Did you testify at trial?23
A. No.
24 Q. And have you testified at trial?
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A. No.
2 Q. Let me mention a couple of things, I3guess rules or guidelines that could help us as we4proceed further in the deposition.5 The first request I'd make of you is that6if, during your deposition, I ask a question that7does not make sense to you, that you do not8understand, would you agree to let me know so I have9the opportunity to re-ask the question in a way that10is understandable for you; would you agree to do11that?12
A. Yes, I would.
13 Q. Okay. And I will assume that if you14answer my question, that you understood the15question; is that fair?16
A. Well, I understood the question in the
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manner in which I understood the question.
18 Q. And at least, if you had any -- well, all19I'm asking you is when I ask a question, if there's20anything about it that you don't understand or that21you feel you need clarification, will you agree to22speak up and let me know that?23
A. Yes, I will.
24 Q. All right. And you may recall from the
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1prior time you were deposed, one of the other2important rules is that we speak one at a time, for3the reason that the court reporter is attempting to4take down everything that we say. So I'll make5every effort to wait until you're done answering a6question before I ask the next one, and if you could7do the same and try to defer from answering until8I'm done asking the question, the court reporter9would appreciate that, and things will proceed a10little more smoothly.11 So do you agree to try to do that?12
A. Yes, I do.
13 Q. All right. If you need to take a break14at any time, just let us know. We'll be happy to15accommodate you, all right?16
A. Yes.
17 Q. To prepare for your deposition today, and18let me kind of, as a caveat, before I get into these19questions, I'm going to ask you some questions about20meetings that you've had with your counsel, if any.21I want you to understand that in my questioning I'm22not trying to elicit any actual communications, the23substance of the communications, okay. I understand24that's privileged, and that's not my goal in asking
Case 3:07-cv-00449-MRM Document 95 Filed 01/21/09 Page 3 of 132
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