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In Re Hill Supplemental Proffer of Anticipated Testimony of Charles TOWNSEND 26 Jan 2011

In Re Hill Supplemental Proffer of Anticipated Testimony of Charles TOWNSEND 26 Jan 2011

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This document is the January 26, 2011, Supplemental Proffer of Anticipated Testimony of Charles Townsend in the case In Re Hill, Case Number 01-22574, a matter before the U.S. Bankruptcy Court for the Western District of Pennsylvania. The supplemental proffer relates to the trial regarding a Rule relating to the imposition of sanctions upon attorney Charles TOWNSEND, a former Asst. General Counsel of CountryWide and Bank of America. The Court had previously found that there was reason to believe that Attorney TOWNSEND had made false statements under oath in a deposition relating to his involvement in the In Re Hill case.
This document is the January 26, 2011, Supplemental Proffer of Anticipated Testimony of Charles Townsend in the case In Re Hill, Case Number 01-22574, a matter before the U.S. Bankruptcy Court for the Western District of Pennsylvania. The supplemental proffer relates to the trial regarding a Rule relating to the imposition of sanctions upon attorney Charles TOWNSEND, a former Asst. General Counsel of CountryWide and Bank of America. The Court had previously found that there was reason to believe that Attorney TOWNSEND had made false statements under oath in a deposition relating to his involvement in the In Re Hill case.

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Published by: William A. Roper Jr. on Mar 31, 2011
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 1IN THE UNITED STATES BANKRUPTCY COURTFOR THE WESTERN DISTRICT OF PENNSYLVANIAIn Re: ))SHARON DIANE HILL ) Case Number 01-22574 JADDebtor, ) Chapter 13)ROBERTA A. DeANGELIS, ) Related to Doc. No. 560 and 570Acting United States Trustee )For Region 3, )Movant, ))v. ))COUNTRYWIDE HOME LOANS, )INC., GOLDBECK, McCAFFERTY )AND McKEEVER, and )ATTORNEY LESLIE PUIDA )Respondents )
SUPPLEMENTAL PROFFER OF ANTICIPATEDTESTIMONY OF C. CHARLES TOWNSEND
AND NOW, comes C. Charles Townsend, by and through his attorneys, PietragalloGordon Alfano Bosick & Raspanti, LLP, who, in consultation with the United States Trustee,hereby submits the following Supplemental Proffer of Anticipated Testimony.
I. SUPPLEMENTAL PROFFER OF ANTICIPATED TESTIMONY
For the sake of clarification, Mr. Townsend will provide testimony that he had a
particular interest in the Sharon Hill Motion to Enforce Discharge (“Sharon Hill matter”)
because of its relationship to the
Notices of Rule 2004 Examinations
filed by the United States
Trustee (“UST Litigation”) and the 293 Motions to Compel and for Sanctions filed by theChapter 13 Trustee (“Chapter 13 Litigation”). However, prior to December 20, 2007, Mr.
Townsend was not formally involved in the Motion to Enforce Discharge; although he was incharge of the UST and Chapter 13 Litigation.
Case 01-22574-JAD Doc 605 Filed 01/26/11 Entered 01/26/11 12:59:33 Desc MainDocument Page 1 of 3
 
 2In late October, 2007, Mr. Townsend was particularly interested in having the discreet
“Sharon Hill matter” settled. Mr. Townsend co
mmunicated that interest to the Bankruptcy andReal Estate Management Division of his company, and specifically to John Smith. Mr.
Townsend was concerned with the settlement as it could have an effect on the “UST Litigation”and “Chapter 13 Litigation.”
Mr. Townsend encouraged the settlement.Mr. Townsend is prepared to discuss his specific involvement and understanding of eachand every email that was a part of the Court record. In particular, Mr. Townsend will testify withrespect to Court Exhibit #6 which includes an email that he authored on October 25, 2007 at 4:55p.m. to Michael McKeever, Gary McCafferty, John Smith and Leslie Puida. In that email, he
states “Please understand the UST issue, of which this case is now a part, is very significant t
othe company and is being reported to the highest levels. We need to be sure everything is being
expedited.” Mr. Townsend will acknowledge that the “Sharon Hill matter” was a part of the two
other matters that had been specifically assigned to him. He will further explain a resolution inthe "Sharon Hill matter" was important to Countrywide's strategy in the "UST Litigation." Mr.
Townsend will clarify that he used the term “we” in the last sentence to mean himself, those
individuals who received the e-mail, and their respective employers.Mr. Townsend was not focused on the investigation, interpretation, or legal analysis of 
the facts of the discreet “Sharon Hill matter.” He was involved in overall strategy and he
encouraged either a prompt settlement or postponement of any hearings in the Sharon Hillbankruptcy, including the one set for October 31, 2007, until a settlement was achieved.In conclusion, Mr. Townsend will recognize he endeavored to be very careful and veryprecise in his deposition testimony. Because he was very careful during the deposition to answer only the question asked, his resulting testimony did not give a fully-developed picture of his
Case 01-22574-JAD Doc 605 Filed 01/26/11 Entered 01/26/11 12:59:33 Desc MainDocument Page 2 of 3
 
 3involvement. He will express his regret that his deposition did not provide a clear picture of hisinvolvement in the "Sharon Hill matter," and apologizes to the Court and the UST. Mr.Townsend again appreciates the opportunity to present himself to the Court and the United StatesTrustee, and to supplement his deposition with this more-complete statement; providingbackground, context, and completeness that will enable the Court and the United States Trusteeto address and hopefully eliminate their concerns.Respectfully submitted,PIETRAGALLO GORDON ALFANO BOSICK &RASPANTI, LLP/s/ William Pietragallo, IIWilliam Pietragallo, II, EsquirePA I.D. #16413wp@pietragallo.comRichard J. Parks, EsquirePA I.D. #40477rjp@pietragallo.comPIETRAGALLO GORDON ALFANOBOSICK & RASPANTI, LLP.One Oxford Centre38TH Floor Pittsburgh, PA 15219(412) 263-2000
Attorneys for C. Charles Townsend 
 
Case 01-22574-JAD Doc 605 Filed 01/26/11 Entered 01/26/11 12:59:33 Desc MainDocument Page 3 of 3

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