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