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Cheryl Thomas Depo

Cheryl Thomas Depo

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IN THE CIRCUIT COURT OF THE NINTH JUDICIAL CIRCUIT IN AND FOR ORANGE COUNTY, FLORIDA

WELLS FARGO BANK, N.A.,

AS TRUSTEE FOR OPTION ONE MORTGAGE LOAN TRUST 2007-4 ASSET-BACKED CERTIFICATES, SERIES 2007-4,

Plaintiffs,

vs.

Case No.: 2009-CA-007640-0

STANLEY W. MARISKOVIC, JR., ET AL,

Defendants.

_____________________________ 1

Deposition of CHERYL DENISE THOMAS, held on

March 23, 2011, at 1755 North Brown Road, Lawrenceville,

Georgia, commencing at 9:53 a.m., before Mary Ann Hanham,

Court Reporter and Notary Public in and for the State of

Georgia.

2

C, THOMAS

2

1 APPEARANCES:

3 On behalf of the Plaintiff:

5 Robertson, Anschutz & Schneid, PL

4

BY:

AMY SUMACEWSKI I Esquire

7

6 3010 North Military Trail Suite 300

Boca Raton, Florida

33431

8 (561) 241-6901

9 (561) 241-9181 (facsimile)

11

10 als@rasflaw.com

13

12 On behalf of the Defendants:

14 The Law Office of Kaufman, Englett & Lynd

BY:

JONATHON C, A. BLEVINS, Esquire

16

15 111 North Magnolia Avenue Suite 1500

17 (407) 513-1901

Orlando, Florida

18 (407) 389-5144 (facsimile)

32801

20

19 jblevins@kelattorneys.com

21 22 23 24 25

3
C. THOMAS
1 INDEX TO EXHIBITS
2
3 DESCRIPTION MARKED
4
5 Exhibit-A 35
6 certificate of Appointment of Notary Public,
7 consisting of one page
8
9 Exhibit-B 39
10 Assignment of Mortgage, Stanley

11 consisting of three pages.
12
13 Exhibit-C 42
14 Assignment of Mortgage, Jason ...

15 consisting of two pages
16
17 Exhibit-C-2 42
18 Assignment of Mortgage, Jason _.

19 consisting of two pages
20
21 Exhibit-C-3 42
22 Assignment of Mortgage, William ••
23 consisting of two pages.
24
25 4
C. THOMAS
1 INDEX TO EXHIBITS (CONT' D. )
2
3 DESCRIPTION MARKED
4
5 Exhibit-C-4 42
6 Assignment of Mortgage, Asher

7 consisting of two pages
8
9 Exhibit-C-5 42
10 Assignment of Mortgage, Leticia 'I

11 consisting of two pages
12
13 Exhibit-C-6 42
14 Assignment of Mortgage, Timothy • .R • db
IS consisting of two pages
16
17 Exhibit-C-7 42
18 Assignment of Mortgage, Dillon

19 consisting of two pages
20
21 Exhibit-C-8 42
22 Assignment of Mortgage, steven_
23 consisting of two pages.
24
25 1 2

5

C. THOMAS

INDEX TO EXHIBITS (CONT'D.)

DESCRIPTION

Exhihit-C-9

6 Assignment of Mortgage I Brenda

3 4

5

7 consisting of two pages.

8 9

Exhihit-C-10

10 Assignment of Mortgage I Jack

11 consisting of two pages

12

13 14 15 16 17 18 19 20

21

22 23 24

25

MARKED

42

42

6

C. THOMAS

DEPOSITION OF CHERYL DENISE THOMAS

1 2 3

MARCH 23, 2011

Okay.

We're on the

MR. BLEVINS:

4 record in Wells Fargo Bank versus Stanley

5 Mariskovic, 2009-CA-007640, out of Orange

6 County, Florida.

7

We I re here wi th Ms. Cheryl Denise

8 Thomas.

9

My name is Jonathon Blevins, and I

10 represent the Defendant as well as

11

MS. SUMACEWSKI:

Amy Sumacewski.

12 represent Wells Fargo.

13 THEREUPON,

14 CHERYL DENISE THOMAS,

15 having been first duly sworn, was examined

16 and testified as follows:

17 EXAMINATION

18 BY-MR. BLEVINS:

19

Okay.

Ms. Thomas, we t re here for a

Q.

20 depos it ion pertaining to your authority as a

21 notary and some other things regarding

22 assignments of mortgages in some cases.

23 24 25

Have you ever been deposed before?

A.

Never.

Okay.

Basically, the process is I

Q.

I

1

7

c. THOMAS

I'm going to ask you a few questions about

2 what your involvement is in some certain

3 4

situations.

5 truthful and honest answer, that's a full

All I ask is that you give me a

7 your head, because it won't come up on the

6

8 9 10

11

12

13

14

15

answer.

You can't nod your head or shake

reporting.

So if you're going to answer,

make it audible yes/no.

I might ask you to

follow up your answer with a yes/no.

I'm

really not trying to be rude.

I'm just

trying to make sure the record is clear I

okay.

Plaintiff r S Counsel may object to

16 You'll still have to answer most questions,

certain things whi Le we 1 re going through.

17 unless it comes to a time where you believe

18 you 1 re not going to answer, then we'll take

19

20

21

22

23

24

25

that up, if that becomes necessary.

But really all I'm doing is trying

to ask you some questions about your

invol vement in some of these cases, and we r 11

just go from there I okay?

A.

Okay.

Q.

If my questions are harassing or

2

8

C. THOMAS

unclear or if you have an issue wi th me

asking questions, just tell me.

I'll try to

3 correct the question or ask it in a

4 different way, to try to kind of get the

5 answer that I r m looking for, or to help you

6 better answer your question, okay?

7

8

A.

Okay.

Q.

So with that, can you, please, state

9 your full name?

10

11

12

Cheryl Denise Thomas.

A.

Q.

And where are you currently residing?

A.

474 _, that's Lawrenceville,

13 Georgia .-.

14

15 Thomas?

16 17 18 19

20

21

22 past?

23 24 25

A.

A.

Q.

Okay.

Are you related to Tywanna

A.

Yes.

Q.

In what way are you related?

A.

I'm her mother.

Q.

Okay.

Are you currently employed?

A.

No.

Q.

Okay.

Have you been employed in the

Yes.

Q.

Who were your prior employers?

Wow.

I've been here seven years, so

3

9

C. THOMAS

just DOCX.

It was LPS.

Once they let

2 everybody go I they closed the office.

4

MS. SUMACEWSKI:

Excuse me one

moment.

I just would like to make a

5 standing obj ection

6

7

8

MR. BLEVINS:

Sure.

MS. SUMACEWSKI:

as to

as so

that I don't continually interrupt.

9 obj ecting to the relevancy of this testimony I

10 also the fact that the subpoena and the

11 Notice of Deposition are on Ms. Thomas in

12 her indi v i dua.L -capa cd ty1' not as a corporate

13 r ep r e s en t-a t Lve of any corporation.

14

15 have a standing obj ect ion as to relevancy and

So I just would 1 ike the record to

16 to the individual capacity of this witness.

17 BY-MR.BLEVINS:

18 19

Q.

Okay.

Ms. Thomas I before we go any

20 correct I to this?

further I too I you did receive the subpoena I

21 22 23 24

A.

Correct.

Q.

Did you bring any of the documents

that were listed as part of the subpoena?

A.

I did.

And I also

25 have my notary stamp certificate.

I have my ID.

1

'98 and

10

C. THOMAS

Q.

Okay.

2

3

A.

And I also have my tax forms for

4 believe, '08.

I'm sorry, '09, '10, and, I

5

6 please?

7

8

A.

Q.

Okay.

May I see those documents i

Sure.

MS. SUMACEWSKI:

Again, I obj ect to

9 the relevancy of these documents.

10

11

MR. BLEVINS:

Thank you.

I don't know if we need to

can

12 we make copies to put as part of the

13

14 things?

exhibits, if I ask her questions about those

15

16 BY-MR.BLEVINS:

THE COURT REPORTER:

(Nodding head.)

17

Q.

Okay.

Ms. Thomas, you

you stated

18 before that you were working for DOCX and

19

then for LPS I whenever they took over for

20 DOCX I when it became LPS I correct?

21 22 23

A.

Q.

your

Correct.

Okay.

What was your position or

24 were working for DOCX?

and your duties as far as when you

25

A.

WeIl, I

positions.

I held

I

1

2

3

11

C. THOMAS

did a lot of different departments.

They

did a lot of lateral moves for me.

The

4 rej ect department, when it was upon clos ing,

last thing that I was doing was in the

5 that was the last job title that I held, but

6 I held different ones.

7

8 9

10 11

12

13 14 15

Q.

What is the reject department?

A.

That's when a document might go out

and it has an error on it.

And the company

would send it back.

And we correct the

error and send it back out again.

Q.

What kind of documents are we

talking about?

Any kind of loan documents.

A.

It

could be, like, a modification.

It could be

16 an assignment, just the loan number, the

17 amount could be wrong, the spelling of the

18 name and address could be wrong, something to

19 tha t nature.

20

21

Q.

And when you say 1I10an documents,"

22 documents, are we talking about the actual

are we talking about the

or modification

23

24 about something different?

new mortgages and notes or are we talking

25

A.

There were mortgages that came.

1 2 3

12

C. THOMAS

Q.

Okay.

A.

And different leases.

Q.

Where did the

the documents

4 originate, do you know?

9 But when they would receive the documents in,

10 they would C-date them as to what date it

5

6

7

8

11

12

13

14

15

To my knowledge, they came in the

A.

door.

And there was a department that we

They called it

wow

it's

had also.

like

I forgot the name of the department.

came in.

And we had so many days to get

it back out the door.

So, to my knowledge,

they came out of the door.

Okay.

So as far as you know, they

Q.

just

they came to DOCX, when you were

16 working there, and then you performed your

17 duties and then the documents left?

18

19

A.

Correct.

Q.

So did you have any role in creating

20 any of these documents?

21 22 23 24

25

A.

No, not at all.

Q.

So you never actually input any of

the data that was on the documents, your

role was to edit them, I guess, or to

correct errors?

1

2

3 4 5 6

7 8 9

13

C. THOMAS

A.

It was

MS. SUMACEWSKI:

Form.

Excuse me.

I'm sorry.

If I obj ect, I don't mean to

interrupt you, but I have to 'put it on the
record.
Q. I'll fix it.
Was your role just to edit the
documents? A.

In the rej ect department, it's, more

10 or less, edit, like, maybe the loan amount

11 12 13 14

15 16

17

18

19

whoever did the

if it was wrong, what

input of the documents, if it was wrong as

far as the loan amount or maybe the address I

that I s the only kind of edi t we I ve done,

because it would come on

they would scan

a document.

So it would come back on a

screen.

And we can edit the document like

that, print it back out I and send it.

Q.

And then who would advise you as to

20 what corrections to make?

21

The supervisor would tell us.

And

A.

22 we learned different types of codes and

23

24

25

different things that you would know how to

correct it.

Q.

Okay.

Who was your supervisor?

1

A.

14

C. THOMAS

At that time. it was

Wow.

2 _. and then from her, it became Renee

3 Gaglione.

4

5

I r m just going to ask you, because

Q.

the ..

Do you have any

6 relation to

7

8

9

10

11

12

13

A.

No, sir.

Q.

And when you say at the time, what

time are we talking about?

months?

about?

What years,

Can you ballpark what you r re talking

A.

Within the

within that last year,

But then upon

I was under

14 the closing, within about five/six months, I

15 became more underneath Renee.

16

17 about?

18

19

Q.

Okay.

And what year are we talking

A.

2009.

20 with DOCX at that time?

Q.

Okay.

And how long had you been

21

22 23 24 25

A.

A.

Seven years.

Upon the closing?

Q.

Yes.

Seven years.

Q.

Okay.

So the supervisor, either

4

A.

15

C. THOMAS

...... or Renee Gaglione, wOlJ,~"'.",,· .\.~

2 a~dvis~ you as to what needs to be changed on

3 the documents, correct?

well, they would tea-

we would

5 learn from them how to c<;trrect the document.

6 So once you ,;.- you . know r ypu understood how

7 to correct the document, you didn't go to

8 them, you know, constantly, but they would

9 they had told us how to correct the

10 documents, correct.

11

Okay.

If

if I understand your

Q.

12 prior testimony, though, you were just

13 14

changing 10an'5tamount:;t :9r wIfl"ever the receiver

was.

How would you know, through that

15

training, what to change?

16

MS. SUMACEWSKI:

Formi

17 mischaracterization.

18

THE WITNESS:

It was different temps

19 that did a lot of the documents,

20 21 22 23 24 25

Q.

By "temps," you mean temporary

workers?

A,

Correct",

Q.

Okay.

So if a

if a

if a temp

A.

didn I t know exactly what to look for, if you

4

16

C. THOMAS

1 • didn 't; know" exactly, on the document, what to

2 look for, they would either overlook

3 something or something to that effect, so if

that would be a reason that something

5 would come back, because maybe they

6 overlooked something or there was some type

7 of oversight on their part.

8

And so when we would see it, the

9 document, when it comes back, it will

10 actually have a cover sheet on it stating

11

12 missing in the document, so we would just

what the problem is or maybe something is

13

14

fix that and send it back out.

Q.

Well, how would you know what you

15 were looking for?

16 17 18 19 20

21

22

23

A.

I knew personally.

Because, 1 ike I

said, I I d been there seven years.

And I

held different

been in different

departments.

I actually started as a prep.

So I knew what a loan was.

I knew what a

note was, knew what a modification was, and

stuff of that nature.

Q.

But I assume, and correct me if I 1m

24 wrong, that DOCX is receiving these documents

25

from a host of different lenders, correct?

1

17

C. THO~S

A.

Correct.

2

3 many different lenders or different banks,

Q.

Okay.

So if you're dealing with so

4 how would you know, given whatever set of

5 documents you were looking at, what needed to

6 be changed?

7

A.

Because all of the documents were

8 pretty much the same as far as the standard

9

procedure, formwise.

They were

so you

10 would know what particular document to go and

11

look for something, if it was a schedule

12 they paid, the type, but you would know

13

exactly where to go and look for something.

14 Because they were all kind of like the same

15

16

documents, just a di fferent, you know I bank

17 pretty much the same standard document.

name or something like that.

But it was all

20

21

22

23

18

19

Q.

Okay.

If

if they were all

standard then

I I m sorry, maybe I I masking

the question incorrectly.

But how would you know, you know,

what names to change or

or loan amounts

25

24 actual lender of what to change?

to change, without being advised from the

A.

Again, it I S

it's di fferent

1

departments.

18

C. THOMAS

Because, 1 ike I said it from

2 the beginning, when the documents come in the

4 documents come in the door, they have a

3

5 6

7 8 9

10

11

12

13

14

15

16

17

18

19

20

21

22

23 24 25

door

this is my knowledge of it, when the

C-dating process that

Q.

I'm sorry, what was that?

They have a C-dating process.

They

A.

call it C-dating.
Q. Like the letter C dating?
A. Yeah, the letter C
Q. Okay.
A. and then dash dating. They call it a C-dating process.

When the document

comes in the door, they see the document.

They note the document come in.

And it's

filled with papers.

It F s, like, a folder

that I s filled wi th papers, probably anywhere

from 20 to 30 papers, depending upon the

document.

And once that document comes in the

door, it F S an original document, so then it's

another process.

I could be skipping

different processes.

But I'm just going with

the flow.

There's another process that scans

this document, okay.

So we have it on the

1

19

C. THOMAS system, because it's scanned.

So if that

2 document goes back out the door incorrectly,

3 because of the scanning system that we have,

4 we would know that that was correct.

6 doing something with the document, I can't

5

So if

if

onc e somebody is

7 say exactly what they might be doing with

8 the document, but say a temp was doing

9 10 11

something with the document.

Say they was

looking up a name and maybe the name was

12 was different than the name on the title

a name on the document, the loan document,

13 page, so the temp went in and said, well,

14

15

this title page should have the same name as

16 change the document.

the loan documents and they might go in and

17

18

19

20

21

22

23

24

25

Why?

I couldn't tell you.

Whatever

their job duties was, that's something

totally different.

NOw, they call that data

entry.

So if they change the document, we

already have it scanned, so we know what the
correct name and everything that was on the
document.
So if it went out the door and they
said that name shouldn't have been changed. 1

20

C. THOMAS

2 on the door with a cover sheet, that I s when

Why was it changed?

So once it come back

3 they would question us, why was this document

4

5

So we would change the name

changed name?

back and send it back out.

And they said,

6 okay f yeah f the document is correct f

7 something like that.

8

And when you say they I re saying it I s

Q.

9 correct f are you talking about the

10 supervisors or the lender on the documents?

11

12 13

A.

The lender.

Q.

Okay.

Now i when you said you would

14 doing the data entry, would change the name

the temps f or whoever it was that was

15

16 name in the actual loan documentation?

on a title sheet, would they ever change the

17 18

A.

sometimes.

It depends on whatever

19 may not be just a name change on the title

data entry process they I re doing.

It

it

20 21

22

23

24

25

page.

It could be a schedule date.

It

could be anything.

11m

11m not sure of

the process of the data entry part of it, so

while they would be doing whatever with the

loan.

Q.

Okay.

what kind of

How

21

C. THOMAS

1 verification would you guys do, or whoever it

2 was that was input ting the names, to know

3 whether the title page name was correct or

4 the name in the loan documentation was

5 correct?

9 different schedule days or different

6

7 8

10

11

12 13 14 15

16

A.

That's another department that would

make sure that it's

different bank names

tha t would have di fferent codes.

There's

assignments that may be attached to a loan.

So the supervisor or f you know,

someone would have already gathered that

information from whatever bank.

And so

they'll know exactly which code or which name

It's just

should be on there.

they

17 gotten from the lender to know exactly, you

they would have a code that they would have

18 know, what should be correct and what's

19

20

21

22

23

24

25

incorrect or something to that nature.

And

they

tha t ' s I again I the data entry

department.

Q.

Okay.

And the coding I does that

refer to the borrowers and the lenders or

just the lenders?

It could be ei the.r / or.

A.

I've seen

3 different departments, I guess, within DOCX,

4 whenever you were there?

7 departments, do you think, are involved in

1

2

5 6

22

C. THOMAS

either/or.

Q.

Okay.

Now, you said there's

A.

Correct.

Q.

Was it

how many different

8 this process?

9

that's really hard to say.

A.

That's

10 Me, mysel f, I've probably only done three or

II 12

13

14 15 16

17

18

19

20

21

22

23

But it

it

four different departments.

could be anywhere from six

six to ten

di f f e ren t departments.

It depends on

whatever, you know, they're doing at that
time. Because we had other different things
that we did at the job as well.
You know, once the mortgage company
got like it did. You know, the mortgage is
going down, and, you know, all of the flexibil i ty with that.

You know, we did

other things like foreclosures.

So it just

depends on what department.

There's

24 was there.

there's a lot of different departments that

25

Q.

And how many people are we talking

1

A.

23

C. THOMAS

I mean, do you have any idea of how

2 many people were working at DOCX during that

about?

3 time?

4 5

about 30.

A.

See, when I started, it was probably

6 probably a good 100, 150, maybe.

By the time we ended, it was

7

Q.

And when did

when is the da te

8 that you refer to as the ending date?

9

A.

10 actual due date, but they let us go April

April 1st or April 2nd was the

11 the 1st.

12 13

Q.

A.

Of what year?

2009.

Okay.

So were

were you also

14

Q.

15 employed at DOCX and LPS as a notary?

16

A.

Yes.

Okay.

Did you notarize different

17

Q.

Yes.

How many

abou t how many documents

18 documents?

19 20 21

A.

Q.

would you notarize on any given

23

25 one day.

at any

22 given time?

That's flexible.

It could be

24 anywhere from one to a thousand documents in

2

Q.

Okay.

24

C. THOMAS

And how was that setup?

I

3 in order to notarize them?

mean, how

how did you get the documents

4

5

A.

It was different processes.

So some

sometimes we would go into a room and,

6 you know, we sat around the table and the

7 different people named that might have been

8 on the documents, those people were in there

9

10

11

12

13

as well.

And so as they signed, you know,

we just kind of passed the documents.

And

you

you got to the end, which was the

notary.

Because there might be three or

four persons I names on the documents.

So by

14 the time it got to the notary, then all of

15

16

17

those persons would have signed it.

And sometimes it would depend upon

the work schedule.

You got in there when

18 you got in there.

19

21

20 earlier about the documents and the data

Q.

And when you were talking about

22 guys did with the documents, did you guys

input and all of the other things that you

23 were you guys responsible for creating the

25

24 as signment of mortgages as well?

A.

I can I t say that for sure, because

1

2

3

25

C. THOMAS

I've never been a part

a part of that

department, if it was.

To my knowledge,

like I said, they came in the door already

4 with all of that in it, the assignments, the

6 of that was in the documents when it came in

5

7

8

9

10

11

you know, the note, the title page, all

the door.

If anything was created, I don 1 t

know.

I haven 1 t seen it.

So you just

personally, you know

Q.

that you r ve never been involved in creating

12 mortgage or any of those documents?

an assignment of mortgage or a note or a

13 14 15

A.

Right.

Right.

Q.

Okay.

Now, back to the

the room

16 you could get there when you could get

where people are signing, when you say that

17

18 mean everybody was there or how would that

there, what do you mean?

Does that always

19 20

21

22

23 24

25

work?

A.

Well, it

it depends, again, on

the

on the supervisor.

Somet imes she r 11

tell you you have to do your own work and

you get in there when you get in there.

It

just

it really depended upon the

supervisor.

1

26

C. THOMAS

And, of course, we questioned it.

2 Because it's like, well, why can't I be in

7 want to get at is, when you say you

3

4

5

6

there?

If they're signing their name, I

need to see it.

Well, just do what you're

told.

And so you did what you were told.

Q.

Okay.

Now I that I s kind of what I

8 questioned it, what do you mean by

9 10

11

"questioned it II?

A.

Quest ioned it in terms of if

12 notary, I have to see that person sign the

somebody I S name is on the document and I I m a

13 14 15

16 17 18

And so when I

document.

when I say

that, I've said ita number of times I you

know, to my supervisors.

And they were,

like, well, you

you got your own work to

do.

And you go in there, you know all of

19 you just go in there and sign when it's your

those people are already in the room signing,

20 21 22 23

time, stuff like that.

So it depends on

what day.

Q.

Okay.

So if I understand your

testimony correctly then, either

24 _.. or Renee Gaglione, whoever it may be,

25

actually instructed you not to be in the

1

27

C. THOMAS

room, in some circumstances, when these

2 things were being signed?

3

4

A.

Correct.

Q.

So there were times that you would

5 notarize something where you didn I tactually

6 physically watch the person sign the

7 document?

8

9

A.

Correct.

DO you have any idea

Q.

you may

10 not, but do you have any idea of how many

11

of those documents you would have notarized

12 without actually seeing the person sign?

13

I really couldn r t sayan idea.

I

A.

14 really couldn 1 t say a number to be accurate.

15 16 17 18 19 20 21

22

23

24

25

I couldn r t even say close to a number.

It

it could be a thousand document s .

I

I

it could be more or it could be less.

I really couldn 1 t give an exact number.

I

just know there was a lot of times that we

didnlt.

We knew the person was in there,

but we didn't physically see them sign.
Q. SO the setup of, I guess, your
offices is that there is a room ~ere t\ese
. 'I;>
~'ople" are signing these documents? A.

Correct.

1

2 four walls and a door?

Q.

28

C. THOMAS

Like the room we're in now I with

3

4

A.

Correct.

Okay.

So you

so you wouldn't

Q.

5 actually be able to see the people who are

6 7

in the room while this is happening?

in

A.

At the beginning of the day, you'll

8 know if you're on a document.

9 10 11

How do I say it?

It I S almost like a

whenever they

12 dropdown box that they would pick a certain

were creating documents, it t s, like, a

13 14 15

16

17

18

19

20

21

22

23

24

25

So if you knew that

if

if

name.

they knew that you were going to be on the
documents that day because some days you
might not be on the documents. But if they
knew you were going to be on the documents,
the supervisor in the room, at that time, was Jeffrey

I don I t even know his last

I think it was _. knew that you were going to be on the

name.

So if he

documents that day I he would come to you and

say they I re using you as a notary today, so

you need to come in the room today.

So I

would take it upon myself and go into the

1 2 3 4

29

C. THOMAS

room and see who was in the room.

If I knew that it was, again, going

to be a fight with Renee to say you need to

5 you know the last person has signed, whatever

stay at your desk and, you know, you go once

6

the case may be.

Jeffrey would come and get

7 you or Jeffrey would e-mail you to come in

8

9 10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

the room, stuff like that.

But I would

I would go in the room myself and see that

the persons that are on those documents are

in the room.

Q. Okay. So is it true or is it
accurate for me to say that it was the
procedure for DOCX to tell you and other
notaries not to be in the room, in some
circumstances, when signing these documents?
MS. SUMACEWSKI: Form; objection. THE WITNESS:

Obj ection means I

don r t have to answer it?

Q.

NO, you still ha.f'ie· tOI, answer it.

A.

Oh, okay.

Sometimes I in some cases,

yes, they said, we didn r t

they wouldn r t

let us in the room.

They said you do your

own work.

You do what you need to do

Q.

Okay.

1

A.

Q.

30

C. THOMAS you go in there ...

And when we're saying u they, II we're

3 meaning the supervisors that you've described?

2

4

5

A.

Q.

Correct.

NOw, when it

DOCX became LPS, did

6 that procedure change?

7

A.

Slowly, it did, not right away, but

8 it progressed to a better change.

9

Q.

Were those supervisors still in place

10 at the time when LPS took over?

11 12

13

14

15

16

17

18

A.

Q.

Yes.

Okay.

Are you familiar with the

rules of a notary?

I mean, I ask that and

I'm not trying to be facetious I but you

understand what the role of a notary is,

correct?

A.

Q.

Correct.

19 what needs to be done before you could

DO you know the rules as far as

20

21

22

23

24

25

notarize something?

A. Correct.

Q.

describe your understanding of what those

Okay.

Can you, please, briefly

rules are?

A.

The bank

the main thing was you

1

31

C. THOMAS

see a person sign a document, you know what

2 was on the document, so that when you

3 notarize it, it's an accurate signature.

4

Now, when you would notarize

Q.

Okay.

5 these documents, whether you would watch them

6 sign it or not, some of these people signed

7 as corporate officers, correct, vice

8 presidents, secretaries, stuff like that?

9

10

11

12 13 14

A.

Correct.

Q.

Were you ever provided any

informa t ion regarding thei r authori ty to sign

in those capacities?

A.

NO, that is another question that

we, of course

T have, o·f·· course, aroused

15 many times.

16

Q.

When you say you raised that issue,

17 can you describe how that situation went?

18 19 20

21

MS. SUMACEWSKI:

Relevancy.

THE WITNESS:

Again, you do what

you I re told.

You just

it's covered. We

22 That r S really all you would get from them.

have legal documentation.

It's covered.

23 24

Q.

Okay.

So when these people would

sign as these corporate officers, they never

25 produced, to you, anything that shows that I

3 4

And

32

C. THOMAS

1 am this officer, whatever that position may

2 be?

A.

No.

Q.

Okay.

And when you raised this

5 issue with them, they just told you to do

6 what you were required to do?

7

Yeah, we got it covered.

We're

A.

8

legal.

You can do it.

Tha t 's fine, jus t

9 notarize it.

10 11

Q.

Now, you said that Tywanna is your

daughter?

12 13

A.

Correct.

Q.

DO you have any information or know

14 any information about her being a corporate

15 officer?

16

A.

No.

17 18 19

Q.

Are you currently a notary?

A.

No.

Q.

Okay.

Did you just not reinstate

20 your license or what happened?

21 A. Once I moved because we the

22 company was in Fulton County. So once I

23 moved, I addressed that with Renee, which was

24 25

such a blessing for me.

And I'm in

Gwinnett.

So I'm like, I'm no more.

1

that's when they

33

C. THOMAS

well, upon us leaving

2 anyway, they took up our notary stamps and

3

4 relieved of my duties once I moved to

everything and destroyed them.

But I was

5 Gwinnett County.

10 the supervisor in the signing room at that

6

7

8 9

11

Q. Who who I'm sorry, did I miss
that? Who destroyed those documents?
A. I can't say exactly who destroyed
them. All I know is that Jeffrey - 12 notaries' stamps.

time, he picked up everyone's stamp, the

13

14

15

16

17 18

19

20

21

Q.

He took your stamps?

And

and

A.

He took our stamps.

they were destroying them.

Q.

How were they destroying them?

A.

I don't know how.

He just said

they were picking up all of the stamps, all

of the notary stamps.

And they were going

to destroy them, because the company was

22 used for that company.

closing.

And they were only supposed to be

23 24 25

Q.

DO you know the names of any of the

other notaries that were there at the time?

Wow.

I can't say, because, at that

A.

1

34

C. THOMAS

time, upon the closing, they had hired a lot

2 of temps that became notaries, so I didn't

3 4

5 6

7

8 9

10

11

12

13

14

15

16

17

18

19

20

21

22 23 24

25

know them personal I y.

I didn't know them by

name.

And it was different notaries that

were there, but I don't know whether they
were active. Once they hired other notaries
once LPS kind of took over, they hired
another, maybe, eight notaries.
Q. What about the notaries th~t '1 ..
werElt there during the seven years that you worked

for DOCX?

A. I only knew a few.
was one.
Q. And that's

A. Correct.
Q. Any, relation?
A. She's my niece.
Wow. ....... HI was one.
Thomas

Bailey

(phonetic) . I can't I can't
spell her last name . I just know it starts
with a K. She was one. III was

one. That's really all the ones I could
think of at this time.
Q. Okay. So during the seven years you
were with DOCX or thereabouts, these were 1

35

C. THOMAS

some of the notaries that were working wi th

2 you?

3 4

5

Right.

A.

Q.

And they would have been under the

6 under?

same procedures or guidelines that you were

7 8

A.

Correct.

that was another

9 one.

And

10

11

12

13

14

15

Correct I same guidelines.

Q.

Now I when you got your notary stamp

can I see your certificate, again? 1'm

sorry.

(Whereupon, .. handing documenlt.)

MR • BLEVINS:

And I guess for

16 purposes I if we could I document this as

17 18

19 20 21

22 23 24 25

Exhibi t -A since I didn't have this

previously.

"

.. " (Whereupon, Exhibi t-A was marked for

identification.)

BY-MR.BLEVINS:

·t

. _", ...

Q.

The certificate you got here that

says you r re from Fulton County I Georgia I

Cathelene Robinson is the Clerk of the Court

for Cheryl Denise Thomas I correct?

1 2

36

C. THOMAS

A.

Correct.

Q.

Okay.

And this was done on or

3 about, it looks like, the 8th day of Apri I

4

Can you tell me what

5 those dates are?

of

is this '06?

6

7 8 9

10

A.

April 8, 2007, is when it was done,

and it

expired 2012.

Q.

A.

It would have expired 2012.

Q.

Now , this is

this notary is in

11 your individual capacity I correct?

12 13

14 15

16 17 18 19 20 21 22 23 24 25

A. The stamp?
Q. Yes.
A. No, they took it up upon the office
closing, they took it from us.
Q. When you applied to become a notary,
did you apply to become a notary as Cheryl
Denise Thomas
A. Yes.
Q. or as Cheryl Denise Thomas as
employee for?
A. Well, when they they paid for everything, the

the company.

DOCX paid

for everything.

So they let us know that it

was for that company specifically.

You don 't

2 3 4

5

37

C. THOMAS

notarize anything else outside the company.

In other words, we wasn't

we

couldn't even take them home.

They had to

stay in the office.

So you notarized only

6 outside the office.

in the office.

You didn't do anything

7

Q.

Okay.

Then based on your notary

8 certificate here, your notary stamp still

9 would have been active when DOCX or LPS

10 closed in 2009?

11

12

13

14

15

A.

Correct.

Q.

Okay.

And is this your correct

signature here on your application?

A.

Correct.

Okay.

Okay.

MS • Thomas, what I

Q.

16 would like to do now is I r m going to ask

17 you some questions about some particular

18 19

20

21

22 23 24 25

documents, okay?

A.

Okay.

Q.

I've already showed these to

Plaintiff's Counsel, but I just want you to
take a look at this.
Can you do you recognize this
document in any way? Do you have any
independent knowledge of this document? 6 I I ve worked with everyone here t so I know

1

2

3

4

5

7

A.

Those

38

C. THOMAS

this is the documents, like

I say, when

when we go into that room

Q.

Uh-huh.

you would know the people.

I

A.

know

I know everybody on this document.

their names.

And I would know, when I

8 walked into that room, that they I re actually

9 in that room when I would go and do my

10

11

12

13 14 15 16

when it would

if it was a time that she

said you do your work, you sign later, I
would go into the room and make sure that
those people were in that room.
Q. Okay. And just before we go any
further, I have this marked as Exhibit-B. 17 Mortgage, in the instant case that we're here

And this is the Assignment of

18 to talk about, between American Home Mortgage

19 20

21

22

Servicing, Incorporated, as

successor- in- interest to Option One Mortgage

Corporation.

The borrower I s name is Stanley

Mariskovic, a single person.

Original

23 mortgagee was Option One.

24 25

But you don't have any independent

knowledge whether this is one of the

4

39

C. THOMAS

documents where you were actually present in

2 the room or if this was one of the times

3 when you were told not to be in the room?

(Whereupon I Exhibi t-B was marked for

5 identification.)

6 7

Obj ect to form.

MS. SUMACEWSKI:

THE WITNESS:

Correct I I can r t say

8 whether I was in the room for this document

9 or not, I cannot.

10 BY-MR.BLEVINS:

11

Q.

Okay.

And you say you recognize the

12 names of the people who were on that

13

14

15

16

document?

A.

Correct.

Q.

Okay.

Can you list off those names?

A.

Dawn Williams, Korell Harp. Christina

17 Huang, and Tywanna Thomas.

18

Q.

Okay.

Now, Korell Harp signed as a

19 vice president, correct

20

21

22

23 24 25

A.

Correct.

Q.

at least, as far as this document

is concerned?

A.

Correct.

MS • SUMACEWSKI:

Objection.

It

calls for a legal conclusion.

1

Q.

Okay.

40

C. THOMAS

And Tywanna Thomas I she

2 signed as an assistant vice president?

3 4

5

Same obj ect ion.

MS. SUMACEWSKI:

THE WITNESS:

Correct.

Q.

And are those signatures accurate?

6 Is that Tywanna 1 s signature?

7

8

TO my knowledge, it is, yes.

A.

Q.

Okay.

And on the back page is

9 where you notarized it?

10

11

12

13 14

15 16

A. Correct.
Q. And is that your signature?
A. Yes.
Q. Okay. Now, when you notarized this
document, did either Korell Harp or Tywanna Thomas present to you any information

17 president, or an assistant vice president

regarding their ability to sign as a vice

18

19 20 21

22

23 24 25

respectively?

A.

No.

Q.

And did you have any hand or have

any independent knowledge as to the creation

of thi s document?

A.

I

I know that there was a

document that was created at DOCX, because I

can

because of the names that are on it.

8 of Mortgages, yes.

2

3 4 5 6

7

9

41
C. THOMAS
Q. And it also says that it's recorded
and returned to DOCX at the top left-hand
corner, correct?
A. Correct.
Q. So this is what your documents would
have looked like from DOCX? Well, yes, Assignment

Assignment

A.

Do you know if

based on

Q.

Okay.

10 your prior test imony, about the editing of

11

12

13

14

Do you know if either the

the documents?

date of the mortgage, the recording date., the

loan amount I document number, or any of the

names listed in the

the paragraphs of the

15 Assignment of Mortgage were changed?

16

17 18

19

20

21

A.

To my knowl edge, no.

Q.

But it was your testimony, though,

that if the lender told you to change

something that that would have occurred?

MS. SUMACEWSKI:

Obj ect to form.

THE WITNESS:

Correct, if it came

22 back as a rej ect and something needed to be

23 24 25

changed, correct.

Q.

Okay.

Thank you, Ms. Thomas.

A.

Uh-huh.

1

Q.

42

C. THOMAS

I would like to show you another

2

3

document.

We're going to call it Defense

Exhibit-C.

Actually, what we'll do is we'll

4 call this Compos i te Exhibit - C, because there's

5 going to be mul tiple documents here.

6

7 were marked for identification.)

(Whereupon, Exhibit-C through C-10

8

MS. SUMACEWSKI:

Obj ection to

9 relevancy, authenticity to these documents.

10 BY-MR.BLEVINS:

11 12 13 14 15 16

17

18

19

20

21

22

23

24

25

Q.

Ms. Thomas, is this another familiar

type of form that you witnessed while you

were working at DOCX?

A.

Correct.

Q.

Okay.

This is another Assignment of

Mortgage, correct?

A. Correct.

Q.

Okay.

NOw, this one is from

Mortgage Electronic Registration Systems as

the nominee for American Home Mortgage

Acceptance, Incorporated, correct?

A.

Correct.

Q.

Do you know the people who signed

this document?

A.

Yes.

1

Q.

43

C. THOMAS

Do you have any independent knowledge

2 as to whether or not you were in the room

3 when this document was created or when you

4 signed it?

5 6

7 room?

8

9

A.

I was.

Q.

Okay.

Were you actually in the

A.

Yes.

Q.

And how do you know that you were

10 actually in the room?

11

12

13

14

15

capacity?

A.

Because I actually signed.

Q.

Okay.

And you signed in what

A.

As a vice president.

Q.

Are you or do you have any documents

16 to show that you are, in fact, a vice

17 president of any company?

18

19

20

21

raised.

A.

Again, another question that we

No, not at all.

Q.

Okay.

So as to your knowledge,

you I re neither a vice president for Mortgage

22 Electronic Registration Systems, Incorporated?

23 24

A.

Correct.

Q.

Or for American Home Mortgage

25 Acceptance, Incorporated?

1

44

C. THOMAS

A.

Correct.

2

Q.

Okay.

Now, the other people who

3 signed this, can you list off the people who

4 signed this document as well?

5

A.

·s

Linda Green, and

6 Tywanna Thomas.

7

8

9 10

Q. Now, is ~ is she
related to Jeffrey &I 7 Eli or is she how
is she involved with the company?
A. I don1t think she1s related to 11 Jeffrey at all.

12

NOW, the

but the witnesses that

Q.

13 signed, would they just go into that room as

14 well and sign the documents?

15 16

A.

Yes.

Q.

Okay.

Now, did Tywanna Thomas also

17 sign this document?

18

19 20

To my knowledge, yes.

A.

Q.

Is that her accurate signature?

A.

As far as I know.

I mean, you sign

21 so many documents, of course, the signature

22 23 24

25

changes a lot.

But as far as I know, yes.

Q.

Okay.

And this was notarized by

--?

A.

Yes.

1

2

3

4

5

6

7 8

Q.

45

C. THOMAS

Was she in the room when you all

signed this document?

A.

I

I really couldn I t say

Q.

Okay.

A. '-- horae a t.Ly,

Q.

And just for clarification, this is

the Assignment of MOlrtgage" 'betWieen Jason

9 Registration Systems as nominee for American

Cross, signed by Mqrtgage Electronic

10

11 12

13 14 15 16

17 18

19

20

21

22

23

24

25

Home Mortgage Acceptance, Incorporated.

MS. SUMACEWSKI:

Obj ection as to

relevancy.

Q.

Okay.

Now, the remainder of the

documents, Ms. Thomas, are other Assignments

of Mortgages, if you want to take an

opportuni ty just to look through those real

quick.

These all look fairly familiar to

you?

A.

The di fferent names and the people,

yes.

Q.

Okay.

I do know that some

some of

A.

I

the sig,natures are changing.

And I

I can

truthfully say it's because they have

1

2 3

46

C. THOMAS

surrogate signers.

Q.

Okay.

That's what I want to talk

4 Assignment of Mortgage I which is another

to you about.

Let's start from the first

5 Assignment of Mortgage from Jason Cross I from

6 Mortgage Electronic Registration Systems as

7 nominee for American Home Mortgage Acceptance,

8 Incorporated, which is Composite C and we'll

9 call this 2.

10 11 12

13 14 15 16

17

18

19

20

21

22

23

24

25

MS. SUMACEWSKI;

Obj ection to

relevancy; authenticity.

Q.

Now, these people who signed this

document, you didn't notarize this one,

correct?

A.

Correct.

Q.

Okay.

But do you recognize the

signatures of those who did sign the

document?

A.

I kind of recognize them, yes, from

again, you sign so many documents.

But

to my knowledge I that's kind of their

signature, yes.

Okay.

And the one I want you to

Q.

pay potential attention to

or part i cular

attention to is Tywanna Thomas r s signature.

2

47

C. THOMAS Is that her signature?

A.

Once again, they change so much, but

3

I do know that she was one of the ones that

4 had a surrogate signer

5 6

7 8

Q.

Okay.

A.

so ...

Q.

So

A.

If I

if I look through these

9 documents, I can see that her signature has

10 changed a lot.

11 12

13

14 15

Q.

Okay.

A.

So I don't know which one is a

surrogate and which one ...

Q.

Well, what I want to ask you,

16 definitively whether or not this one on

though, is, I'm going to need you to tell me

17 on C- 2 is Tywanna Thomas's signature.

18

19

20

21

22

23

A.

C-2?

Q.

Yes, this document right here, yes

(indicating)

A.

To my knowledge, that's the way she

signs, yes.

Q.

Okay.

NOw, turn to the next

24 Assignment of Mortgage, which we will call

25

C-3.

This Assignment of Mortgage also has

2 3 4 5

48

C. THOMAS

1 Tywanna Thomas's signature on it, correct?

A.

Correct.

Q.

Is that her signature?

A.

That's also close.

I will say yes.

MS. SUMACEWSKI:

Obj ection to f oz'm r

6 relevancy i and authenticity.

7

MR. BLEVINS:

DO you want to make

8 that standing, because I'm going to ask the

9 same question for all of them?

10 11

MS. SUMACEWSKI:

Yeah, for all of

12 relevancy, and form.

these assignments as to authenticity f

13 BY-MR.BLEVINS:

14

15

16

Q.

Okay.

Now, Ms. Thomas, I want to

talk to you about C-4, which you're looking

at right now.

Is that

do you see that

17 Tywanna Thomas signed this assignment as

18 well?

19

20

21

22

23

24

25

A.

I would say that's different.

I

that would probably be a surrogate.

Q.

That's a surrogate?

A.

Yes.

Q.

Are you sure?

A.

I said that would probably be a

surrogate.

I would think so, yes.

1

2

3

4

5

6

7 8 9

Q.

Okay.

49

C. THOMAS

And, also, she, at this time,

signed as an assistant vice president.

Now,

you've said before, though, that you don't
believe that you've ever seen any
documentation showing that she actually is an
assistant vice president?
A. Correct.
Q. But on the very first document, she signed as an assistant secretary.

Are you

10 aware of any documentation or anything that

11

12 position?

would have occurred that changed her

13 14 15 16

17

18 19 20 21

22

23

A.

No.

Okay.

I want to talk to you about,

Q.

what we'll call, C-5. should be Leticia ......

The borrowe r 's name

Okay.

Tywanna

Thomas signed this Assignment of Mortgage?
A. That looks like a surrogate signer.
Q. Okay. And why do you say that?
A. Her name is more fuller, the first
name would be more fuller. And she don't
her T is not like that. Okay.

Now, when you

we III come

24 back to that.

Q.

25

I would like you to turn to C-6.

1

2

3

50

C. THOMAS

Do you recognize these signatures?

I'm not fami liar with Veronica

is

A.

that veronica'_?

I'm not familiar wi th

4 that, but the other two, Chris Pendley and

5 6 7 8 9

10 11 12

13

14

15

16

17

18

19

20

21

22

23

24

25

Lisa and Christina, yes.

Q.

Okay.

Are those their signatures?

A.

To my knowledge, yes.

Q.

Okay.

I would like you to turn to

C-7.

The borrower's name should be Dillon

Campbell.

Do you recognize these signatures?

A.

That Tywanna is a little shady, but

it could have been one of those times she

was probably moving through the documents.

So I wouldn't say yes or no to t.ha t; one.

Okay.

So you don't know?

Q.

A.

I wouldn't - - " yeah, I wouldn't say

yes or no to that, because it's

it's

close. But I I wouldn't say yes or no
to that, whether it was a surrogate signer
on that one or not.
Q. And, again, this time she's signing
as an assistant vice president? A.

Correct.

Q.

Okay.

Now, I would 1 ike you to

turn to C-8.

The borrower's name should be

1

Steven

51

C. THOMAS

Do you recognize these

s.

2 signatures?

3 4 5 6 7

A.

Tywan~a, ct~p.in, is

that's a

is

surrogate signer.

And Linda Green, that's a

surrogate signer.

8 signer?

9 10

11

12

13

14

15

And how do you know that?

Q.

A.

How do I know she had a surrogate

Q.

Yes, rna' am.

A.

It was several people in the office

that had surrogate signers, that I do know.

I know that because of notary purposes.

Okay.

Q.

A.

It's one of the questions that came

up when Linda Green d i dn ' t look 1 ike Linda

16 Green and you asked me to notarize it.

17

Q.

Okay.

And we'll call this one C- 9.

18 Do you recognize these signatures for the

19 Assignment of Mortgage and the borrower's

20

21

22

23

name is Brenda

-_.?

A.

I recognize those signatures, yes.

Q.

Okay.

Let's turn to C-IO.

This is

the borrower I s name is Jack

3.

24 This one do e an ' t have Tywanna Thomas I s

25

signature on it, correct?

1

52

C. THOMAS

A.

Correct.

2

Q.

Would that have been a problem for

3 you all as far as notarizing these documents

4

if that doc-

if that signature was

5 missing?

6 7 8 9

Obj ect to form.

MS. SUMACEWSKI:

THE WITNESS:

Let's just say it

would have

it would have came back to

bi te us more than it would them.

But with

10 the process, like I say, the way they have

11

12

13

14

15

16

us doing work, they

t.hey i r e getting stuff

out the door.

They want you to go in the

room later.

And if you miss a signature or

or you miss something or it's

it just

comes back to bi te you in the butt later,

17 door, because there's always a timetable.

but they

they're rushing stuff out the

18 There's always a time limit, I should say.

19

Now, when you say come back to hi te

20 us versus them, who is us and who is them?

Q.

21

22

23

24

25

A. Us in terms of notaries.
Q. And them?
A. Them would be the managers.
Q. So you think
A. We would take the fall for it before 5 be like, well, you should have paid

6 attention, but you're constantly rushing stuff

1

2 3 4

7

53

C. THOMAS

they would.

Q.

You would take the fall?

A.

We

we wouldn't have a choice but

to take the fall for it.

Because they would

out the door.

You're

you know, you Ire

8 you're constantly running us here and there

9 10 11

12

13

and saying do this and do that.

So

sometimes you get there, you just sign it

and you keep on going.

Sometimes

I've

I've known of

incidents of some notaries that probably

14 would have been in the room and signed, so

15

they could go do what they had to do.

It's

16 it I S just it just depends on the

17 manager and what day she how she was

18

19

20

21

feeling that day.

Okay.

Now I I want to go back to

Q.

something you touched on here in a second,

22 want to take a minute and flip through it I

but I would 1 ike to ask you I and if you

23

24 of these documents being signed wi thout the

that I s fine I but do you have any knowledge

25

presence of a notary?

4 type of documents that would have been

1

2 3

54

C. THOMAS

A.

I

I don't have any

I can't say.

knowledge of it.

I can't say yes or no.

Q.

Okay.

But these would have been the

5 potentially notarized without one of you

6 notaries being in the room?

7 8 9

10

11

12

13

14

15

MS. SUMACEWSKI:

Form.

THE WITNESS:

Possibly.

Q.

Okay.

NOw, the surrogate signers I

how did that work?

How did the surrogate

signing si tua t ion occur?

A.

I can't say how i toccurred.

Q.

Okay.

A.

When it was brought to my attention,

16 day it was, but we were all in the room and

it was a particular day f I can't say what

17 we were informed that we were going to have

18

19 people that were on the documents had a lot

surrogate signers.

Because some of the

20 of work to do, so they brought in different

21

22

23

24

25

temps to sign for them.

And they let us

they told us that it was legal and it was

okay.

And they even had a form that

let's just say Tywanna, for instance lit

would be a

it was a form that we would

1

2

55

C. THOMAS

see and Tywanna would sign her name the way

3 her surrogate signer, he would sign Tywanna' s

she signs her name.

4

5

6

7

8

9

10

11

12

13

And if John

was

name the way he signs Tywanna's name.
Sometimes it was close. Sometimes it wasn't.
But they told us that it was legal
documentation, that it was okay for Joe
to sign Tywanna's name this way, because of the form that they had, so ...

Q.

Can you

can you describe the form

for me?

I really can't.

It's been a long

A.

time.

And it was just that one time.

I've

14 never seen the form after that.

15

16 wha t the form was?

Q.

And what was your understanding of

17 18 19 20 21

22

23 24 25

A.

That it was a legal form that

Tywanna Thomas would sign her name a certain

way and Joe

•••• would sign it close or

however

however he signs it.

And it was

legal for him to do that, because Tywanna

had a lot more work to do.

And she didn't

have time to sign the documents.

So, in other words, we would have

had to wait on Tywanna to come in, in which

1

56

C. THOMAS

Tywanna wasn I t the only one that had a

2 surrogate signer, but we would have,···,~o wai t

3 for Tywanna to come in before we could

4

5 6

finish out the document.

So they had, like,

four or five different surrogate signers.

Q.

NOw, when you say they told you that

7 this was legal or they told you to fill out

8 this form, who is "they"?

9

10 11 12 13 14

The managers, Renee Gaglione again,

A.

Jeffrey _ also, and Shelly.

Shelly

Scheffey was also one of the supervisors.

She informed us.

She was in there during

that conversation.

Kim French, she was a

She was also in there.

And I

15 want to say that the HR person was in there,

manager.

16

17 18

19

20

21

22

23

24

25

Carol _.

I want to say she was also

in

in the room at that time.

That

that I S basically it, I think, for supervisors

that were i'P- th6b room, that I can remember

that I can recall.

There could have been

I just

it was mainly people in

more.

the room, more I ike notaries and, you know I

some of the people's names that were actually

on the documents.

Q.

Okay.

1

A.

57

C. THOMAS

It was, like, maybe 30 to 40 people

2 in the room, so ...

3

Q.

And the process that you're

4 describing or the procedures you Ire

5 describing, that occurred at DOCX?

6 7 8 9

10 11

12

13

A.

Correct.

Q.

Did it also occur at LPS?

A.

It

it was still going on during

LPS, yes, and it

and then it tapered off

more towafds th~ end.

You know, they kind

of got rid of all of the surrogate signers

towards the end.

When you say you guys

and you

Q.

14 mentioned thi s before, that you raised an

15

16

issue about this, what was the explanation

that was giveh to you as to why this was

17 okay?

18

19

20

21

A.

They just said legal documents. Well,

it was mainly Renee.

I shouldn't say they.

It was mainly Renee.

She would just say

22 we have authorization to do it this way, you

this is a legal document, you know.

We

23

24

25

know.

We know what we're doing, just

just do it, just sign your name.

We got to

get this out the door, just do what you're

6 after you all signed it or notarized these

1

2 3 4 5

58

C. THOMAS

told.

Q.

Did you ever notarize any documents

that you knew a surrogate had signed?

A.

Yes.

Q.

What happened to these documents

7 documents?

8 9

A.

They were shipped out.

Q.

Were you asked to keep track of

10 different state jurisdictions, county

11

12

13 14

jurisdictions as far as what was required on

these documents?

A.

As

as what?

Q.

For example, if you were given an

15 Assignment of Mortgage from Florida, would

16 you handle that differently than if you were

17 handed an Assignment of Mortgage from, say,

18

19

20

21

22

23

24

25

Georgia?

A.

I wouldn't personally, no I I wasn't

given anything pertaining to that.

I know

there was different jurisdictions, but it

wasn't something that I had memorized or had

any knowledge of.

That would be data entry

that would, you know, do something upon that.

Q.

Do you know what goes into or what's

59

C. THOMAS

required for these Assignment of Mortgages to

2 be valid?

3 4

5

6

7

MS. SUMACEWSKI:

Obj ect to form.

THE WITNESS:

No, I don 't.

Okay.

So the

I'm sorry, let me

Q.

flip through these real quick.

Okay.

8 about before, where you signed as a vice

So referring to C-l that we talked

9 president

10

11

12

13

A.

Uh-huh.

Q.

Are you looking at that document?

A.

Yes.

Q.

The Assignment of Mortgage says that

14 this was conveyed for good and valuable

15

consideration from Mortgage Electronic

16 Registration Systems, Incorporated, as nominee

17

18 Bank National Association as Indenture Trustee

for American Home Mortgage Acceptance to U. S.

19

20

21

22

23

24

25

for American Home Mortgage Investment Trust

and a list

kind of a long list for the

trust.

Do you know or have any actual

knowledge as to what valuable or good or

consideration was given for this assignment?

A.

No.

1

Q.

60

C. THOMAS

And you don r t know that even though

2 you signed as a vice president?

3

4

5

Q.

Obj ect to form.

MS. SUMACEWSKI;

THE WITNESS:

No.

6 corporate position in any corporation as far

Okay.

Have you ever held any

7

8

9

as your

A.

Q.

10 meeting?

11

12

13 14 15 16 17 18 19 20 21

22

23 24

25

A.

Q.

as far as you know?

No.

Have you ever been to a board

No.

have you ever been paid out any dividends or

Okay.

Have you ever been asked

anything like that from a corporation?

A.

Q.

No.

Registration, Incorporated, or American Home

Okay.

So has Mortgage Electronic

Mortgage Acceptance , Incorporated, ever

contacted you as being a corporate officer?

A.

Q.

No.

Okay.

And is that the same for

Tywanna Thoma s ?

I know she r s your daughter.

But are you aware of any of the

same ci rcumstances with her?

Has she ever

2 by

3

4

1

5 6

61

C. THOMAS

been to a board meeting, ever being contacted

A.

To my knowledge, no.

Q.

Have you been in contact with

anybody from DOCX or LPS regarding any of

7 these Assignment of Mortgages or any other

these circumstances or situations, regarding

8 9 10

11 12

13

14

15

16

17

18

19

20

21

22

23

24

25

documents?

A.

Since the layoff?

Q.

Yes.

A.

No.

Q.

Have you talked to anybody about any

of these circumstances, any of the

signatories, or anybody else who used to work

at DOCX or LPS?

A.

Other than Tywanna, no.

Okay.

Okay.

I don r t

MR. BLEVINS:

think I have any further questions, unless

you have any questions.

EXAMINATION

BY-MS.SUMACEWSKI:

Q.

I just have a couple of questions.

with regard to Exhibit-B, the

Assignment of Mortgage having to do with this

case, the Stanley Mariskovic assignment, your

62

C. THOMAS

1 only involvement on this assignment was as

2 the notary public I correct?

3 4

A.

Correct.

Q.

You were not involved in the

5 reviewing of this document?

6

7

8 9

Reviewing it in terms of it be ing

A.

Q.

Auditing or editing the document.

A.

No.

No.

Q.

And about how many departments would

10 you say that this document had gone to

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

before it went to the signing process?

A.

I really can 1 t sayan accurate

number, because there 1 s different departments

and I don 1 t know the procedure.

I just know

once it 1 S in the room, I do the signing

I don 1 t know.

I don 1 t know who

process.

does the printing or anything like that.

I

don 1 t know.

All I know is it starts with

data entry and it

it gets to the signing

room.

Q.

And as a notary fat that point, your

only concern is that the people signing the

document are the people that signed the

document, correct?

A.

Unless they had a surrogate signer f

1

2

63

C. THOMAS

correct.

Q.

And when the signings took place,

3 you said that you made sure you knew who was

4 in the room?

5 6

7 8

9

10

11

12

13 14

15 16 17 18

A. Sometimes I would go in there. If
I if they told me, ahead of time, that I
was going to be a notary today because
sometimes Jeffrey made it a point he
he was a pretty decent guy. And he made it a point to

to tell you sometimes.

If he

could get to you and say I you know, you're

going to be a notary today or

or if he

could shoot you an e-mail and say that.

I

don't know else who he was doing it to.

I

know he would do it to me from time to

time.

And when he did that, I would go and

I would look to see if somebody is in that

room that's, chances are, on that document.

19 And I know that I'm going to be a notary

20 21

for that particular document.

So chances are for

when you

Q.

22 notarized this assignment, Exhibit-B, you

23 24

25

checked to make sure that Dawn Williams,

Christina Huang, Korell Harp, and Tywanna

Thomas were

1 2

A.

64

C. THOMAS

Looking at that signature there, that

that could have very well been one of

3 Tywanna1s surrogates on that one (indicating).

4

5

6

7

8 9

10

11

You would have made sure that the

Q.

surrogate was

was there, though?

A. Yes.
Q. And did anybody keep you from the
room saying that you1re not allowed to go in
the room, that it1s none of your business
whols in the room?
A. Renee would say that from time to 12 time I yes.

13

you personally checked

Q.

But you

14 yourself?

15

Sometimes when

you know I unless

A.

16 you 1 re going to have a run- in with her and,

17 you know, t he r e ' s your job, you just kind of

18 did what you were told

19

20

21

Q.

Was that

A.

stay out of the room, you know.

When it's time for you to go in, they'll

22 call you.

23

Q.

Was that for expediency purposes,

24 though?

25

Yes, but, yet again, it IS

it

A.

1

2

65

C. THOMAS

still questioned my character as a notary,

but to her, that didn't matter.

I mean, you

3 do what you do.

4

5

6

7

8

In other words, she treated

she

treated everybody like they were on those

documents as just names.

The notaries

even though you

you had a more

9 matter to her.

responsible side of it, it

it didn't

10

11

12

13

14

15

16

17 18 19 20 21 22 23

Q.

But she wasn't doing it to deceive

anybody to not have the correct signer sign

a document?

A.

I don't think anybody would have

well, I

I shouldn't say I don't think.

I know if

if Tywanna had a surrogate

signer and I

and when I would come into

that room, I

it could be 2, 000 documents

in that room.

I may only sign, as a notary, 500

documents, say, that day.

If I go into that

room and they're through with my 500, those

three or four people that are on that

24 notary, my 500, those people are still in

document and it's time for me to sign, as a

25

the room, chances are, because they're on the

1

2

3

66

C. THOMAS

other 2,000 or 3,000 documents, so they're

still in the room.

So I could look over and say I okay I

4 Tywanna is here I or I okay I you know I there I s

5

6

7

her surrogate.

I

I can truthfully

I

say that, they were still in the room.

Chances are I they were there.

They wasn I t

8 gone out of the room when it came time for

9 me to sign.

10

11

12

13

14

15 16 17 18 19 20 21 22 23 24 25

Q.

You knew the people you were

notarizing for?

A.

Right.

Okay.

Did you have any seminars or

Q.

training on how to be a notary?

A.

No.

Q.

Were you aware of any power of

attorneys or corporate documents that

appointed certain people to act in certain

capacities?

A.

No.

Q.

Is there a chance that there could

be some power of attorneys naming you as

as assistant secretary that you just don't

know about?

It could be.

I

I don I t know

A.

7

67

C. THOMAS

2

1 about it.

Q.

Are you familiar with how power of

4

3 attorneys work?

If someone is incapable of doing for

5 themse 1 ves, someone has that authority to do

6 it for them?

8

A.

Q.

In some circumstances, yes.

9 need to know if you I re someone' s power of

And do you know if you necessarily

10 attorney?

11

12

A.

I think it's neces sary to know it.

Q.

Only

before

13 you're asked to act on the power of

we II, when you're

15

14 attorney?

A.

I would

I would hope that I

17

16 would know it, that I'm going to do

18

19

something if I'm given that power as opposed

to just telling me I have that power.

21

20 notaries in the office?

Q.

Now, you said that you left your

22

23

A.

Yeah, they picked them up.

Well,

they picked up mine.

They said

at that

time, Jeffrey said we r re

we're picking up

25

24 all notary stamps.

Q.

I took it to

to seem that when

68

C. THOMAS

1 you left the office for the day, you left

2 3

4

your notaries in the office.

Did you take

your notaries with you?

Did you always have

your notary with you whi Le

during your

5 employment with DOCX?

6 7 8 9

10 11 12 13

A. No, I never never took it home.
Q. It was in the office?
A. It was always in the office.
Q. Was it locked up?
A. Sometimes. It depends on like I
said, I moved around a lot. They they had me in different departments.

So

sometimes it wasn't locked up.

But, you

14 know, everybody in the office didn't

15 particularly know who all were notaries, per

16

se, or act i ve notaries.

So, I mean,

17 everybody kind of stayed to their own

18

station.

They wouldn't just, you know, take

19 things or whatever, you know, to my

20 knowledge.

21

22

23

24

25

Q. You felt it was pretty secure?
A. Yeah.
Q. And you and you felt that the
supervisor wanted to to keep the notaries
in the office for security purposes? 69

C. THOMAS

A. That, plus to make sure that you

2 don r t notarize anything outside of that,

3

they paid

4 for you to do specific work for them, that's

because they only paid you to

5

6

it.

Q.

Now, by looking at these documents

7 today, do you know with certainty that these

8 documents were actually signed by who they

9 say they were signed and that the contents

10 of these documents are the exact copies of

11

12 presented to you?

the originals that were housed, that were

l3

14

15

16

17

18

19

A. r r can't say for sure. r just
they they look familiar. That's all I
can say. And the signers, some of the
signatures look familiar, like r said, with
different ones that had maybe a surrogate signer attached to it or not, but I

I

It was so many documents.

If

20 my life depended on it, r couldn't tell you,

can r t say.

21

22

23

24

25

because you sign so many.

Q.

So Exhibit-C, C-l through 10, you

you would not be able to say that with

specificity that these are actual documents

in the content and form that the copies

70

C. THOMAS

1 presented to you today?

3 documents that we have signed throughout the

4 course of working there I but to just say

2

5 6 7 8 9

10 11 12

13

A.

I can say that looks like the

I wouldn't

it would be kind of hard to

say that it's something that's made up or
that is not exactly a copy of something that
I'm used to seeing
Q. And you
A. I would say it's something I'm used to seeing.

Q.

And you weren't present during the

14 probably not present?

ones that don 1 t have your signature or

15

16

17

18

19

20

21

22

23 24 25

A.

Correct.

Q.

And you I re not a handwri ting expert?

A.

No.

Q.

Have you ever had any handwriting

training?

A.

No.

Q.

And as a notary I was it your duty

to check

I might have asked you this

already.

Was it your duty to check and make

sure the names were accurate as to the banks

and the borrowers

2

3

71

C. THOMAS

A. No.

Q.

on the assignment?

4 necessary to sign the assignments?

Were you told how many signers are

5 6

A.

No.

So if a name is left off, you

it

Q.

7 was okay that you notarized, because you

8 weren't notarizing a signature, you didn't

9 know if that person's name could be left

10 11 12

13

14 15 16 17 18

19

20

21

22

23

24

25

off, that they needed four signatures or not?

It depends on the document.

Some of

A.

them need three.

Some of them might need

Some might have needed two.

It just

four.

depends on the document.

Q.

But in your notary capacity, it

didn't matter to you, you were just

notarizing the signatures that were there?

A.

That's hard to say.

Because, again,

you

you're to sign a document after

everybody has signed, that

that was what

we were told as a notary.

That's what you

were told.

But in this off ice, because they

were sweeping stuff out the door, there would

be times that you would miss something,

1

2

3

because of

I

72

C. THOMAS

I want to say because of

the

the pressure that they would put on

4 documents, I might have missed 20.

you.

There would be times that out of 500

5

6 just because of the pressure that was on you

To honestly say, I

I could have,

7

to

you go in there, you got an hour to

8 go in there and do whatever and get back.

9 10

11

I mean, you

so it I S a chance you would

miss something.

Nobody

it I s plenty I' m

sure went out the door.

And I know

12 specifically it went out the door, because

13 when I was in the rej ect department I when

14 they would come back, there would be times

15

16

17

18

like that one signature was missing,

that

I' ve seen that many times.

Q.

You noticed things like a missing

19 Like somebody

signature, but not like an odd signature?

20

21

A.

The surrogate signer?

22 name?

Q.

that you didn I t recognize the

23

24

25

A.

Only if it was a surrogate signer.

Q.

But I I m talking about the person

whose name is typewritten underneath, if you

1

73

C. THOMAS

didn't recognize the name, would you ask to

2 see that person?

3

4

5

I haven I t really signed any I didn It

A.

I didn I t recognize the name.

Q.

Okay.

That I s what I was trying to

6 get at.

7

8

A.

Okay.

Q.

Were you ever

ever told to forge

9 any signatures?

10

11

12

13 14 15 16 17 18 19 20 21

22

23 24 25

A.

No.

Q.

When

the meeting about the

surrogate signers I were the surrogate signers

told to forge the person I s signature?

A.

They didn I t use the word forge.

They used the word as a surrogate signer.

And they

they said it was legal.

So

they never

they didn't use the word forge

Q.

And they said

A.

they didn't say forge the name.

They just said this is legal.

This person

is going to be this person I s surrogate

signer I because this person has a lot to do.

Q.

And they didn I t tell you that this

person had to sign their signature the way I

1

2

3

4

5

6

74

C. THOMAS like, Tywanna signed

A.

Right.

Q.

they could sign their own?

A.

Right, I could look at one here wi th

Ri ta Knowles.

She definitely don't sign like

that, but she has a surrogate signer.

So

7 the surrogate signer could sign however they

8

9 that's the form that we were shown, that the

want 1 that's the way we were told.

10 11 12 13 14 15 16

And

surrogate signer could sign any way they want

to sign that name.

Q.

And when they showed you that f o rrm ,

did they tell you it was prepared by legal

counsel?

A.

No I they just said it's legal and

this

this is the process that we have

17 done, so now we can do it this way and this

18 19

is legal.

And you kind of raise your

20 you could say.

eyebrow, but other than that, nothing more

21

Q.

This Assignment of Mortgagel

22 Exhibit-BI was there any oath to this

23

24

25

assignment or sworn to materials?

A.

You mean wi thin

in the writing

part of it?

1

2 3 4 5 6 7

75

C. THOMAS

Q.

Right, where

was it necessary to

take any oaths?

Did they swear to the

information being true and accurate?

To my knowledge, you signed it.

You

A.

You signed it.

I don I t

didn' tread it.

think any of these signers

and I know

I don' t want to say think.

I know none 0 f

8 these signers took the time to read that,

9 10

11

12

13

because you couldn I t do that.

You had to

sign, flip, keep going.

You didn r t

you

didn I t read every document.

There was no

They would

you couldn r t do that.

way.

Q.

But, I mean, did you take oaths? Did

14 you swear these people in and take oaths?

15

Every time I went in to sign as a

A.

16 notary I no.

17

18

19

20

21

22

23

But there r s no requirement on here

Q.

for you to take in

to swear them in

A.

No.

Q.

or take oaths?

A.

No.

Q.

And do you know, firsthand, which

24 not?

assignments were read and which ones were

25

A.

By the signers?

2

76

C. THOMAS

Q. If you signed an assignment, would

you have read it?
A. No.
Q. As the notary?
A. No.
Q. And do you see anything that would raise any

any suspicion on this Assignment

3 4 5 6 7 8 9

of Mortgage, that

of any Assignment of

Mortgage in Exhibit-B that you've seen?

Is

10 there anything on this Assignment of Mortgage

11 that raises any issue with you?

12

A.

It wouldn't raise an issue with me,

13 no I because I again, that would be one of her

14 surrogate signers and I wouldn't question

15

this document.

I would notarize it and keep

16 going.

17

18 this Exhibit-B?

Q.

So today, you would still notarize

19 20

A.

Correct.

MS. SUMACEWSKI:

Okay.

I don't have

21 anything further.

22 FURTHER EXAMINATION

n BY-MR.BLEVINS:

24

Q.

Ms. Thomas I I just have a couple of

25 follow-ups.

1

77

C. THOMAS

When you said you would come in and

2 identify the people in the room, you said

3 something about there is her surrogate,

4 5

6

7 8

talking about Tywanna Thomas.

Do you know

A.

Or whoever.

Q.

Okay.

Or whoever.

Do you know specifically who Tywanna

9 Thomas 1 s surrogate was?

10

11 12 13

A.

I believe she had a couple.

Again,

like I said, when

when they hired a lot

of the temps, they

they hired them mainly

for that purpose.

Some

for that purpose.

14 And, 1 ike, they hired some for notaries as

15

16

well.

But they hired a lot of temps for

tha t purpose.

At that time, her surrogate

17 was a & .

18

19 20 21

22

23 24 25

Q.

S d ?

A.

Uh-huh.

Q.

What's

do you have a last name?

A.

_.

Q.

._" like

A.

Correct.

At one time,

don't want

I don't want to mess up her

last name,

(phonetic), something like

I

1

2

4

5 6

7

8

9

10

11

that.

signers.

78

C. THOMAS

Q.

Could you spell it the best you

A.

I want to say.

3 know?

Q.

Okay.

And you said

A.

spelled like Tywanna, but

Q.

Okay.

A.

She was also one of her surrogate

So to my knowledge, she had two.

If there was more, I e an t t recall.

But to

12 my knowledge, she had two.

13

Q.

How about the rest of the signers,

14 did they all have surrogates as we II?

15 16

17 18

19 20 21 22 23 24 25

A.

Rita Knowles had a surrogate.

I

don 1 t remember the guy 1 s last name, but I

know hi-s first name.

His

He was a temp.

Linda Green also had

first name was Andrew.

The guy 1 s name was Chris

a surrogate.

40 .... '·, I want to say.

temp.

He was also a

Q.

~ or !IIIl •••• r?

A.

I think he was on one of

these documents here, _, I think

it is.

Yeah,

I guess that

2

Q.

1 is.

Q.

3 4 5 6

A.

Q.

A.

79

C. THOMAS

And which are we looking at there?

That document (indicating).

MS. SUMAC-EWSKI:

C-6.

C-6.

Okay.

And he was

he was a surrogate

7 signer for Linda Green.

8

Q.

IIIl1ris

was a surrogate for

9 Linda Green?

10

A.

Correct.

I think

to my

11 knowledge, that r s the only ones I can think

12 of at this moment

13 14

Q.

A.

Okay.

that I know that had surrogate

17 t ha t r s K - n - 0 - w - 1 - e - s ?

And just to go back, Rita Knowles,

15 signers.

16

Q.

18 A. Correct.

19 20

Q.

Okay.

NOw, do you have contact

information for any of these people?

Do you

21 have phone numbers, addresses, or have you

22 talked to these people at all?

23

A.

24 worked

25

Surrogate signers or the people that

Any of them,

2

3

4

80
" C. THOMAS
$ Linda Green, Rita Knowles, d22
~I i. t 7 FIJ, any of these people.

A. Can I say something off of the record and

and you could put it back on

5 if you need to?

6

Q.

To be honest with you, Ms. Thomas,

7 it's probably best that it all be on the

8 9 10 11

12

13

14

15

record ... .l

Okay.

Well

A.

Q.

because neither me or her

represent your interest, so I can't

Okay.

To my know I edge

A.

you're

you're aware that the FBI is doing what

they're doing.

So they have that

information.

I don't have that information.

16 The only person I know is Tywanna Thomas I

17

18

19

20

21

22

23

24

25

because she's my daughter.

She stays with

me.

All of the other people, you know, I r m

I know Rita, but I

I can't say

well, I have a phone number for her.

I

can't say where she stays.

Q.

You have a phone number for Rita

Knowles?

A.

Yes.

Q.

Okay.

1 2

A.

81

C. THOMAS

But I don't know where she stays.

Other than that, I don't

I don't really

3 have that many that I contact after the job.

4 I don't really.

5 MS. SUMACEWSKI: I obj ect to the

6 relevancy of any people that are not included

7 on the Assignment of Mortgage, Exhibit-B.

8 9 10

11 12

13

Q .

Okay.

Do you have her phone number?

A.

. . )

Q.

Uh-huh.

A.

-- ...

Q.

Okay.

I guess,

And so you are

based on your

you're talking about the

16 17

18 form.

19

20 21 22 23

24

14 FBI, you're aware of the investigation into

15 DOCX and LPS, as far as the fraud issues?

A.

Right.

MS. SUMACEWSKI:

Objection; relevancy;

Q.

Have they contacted you

A.

Yes.

Q.

about that?

Have you talked to them?

A.

Yes.

Q.

Okay.

Is it

was it similar to

25 what we're doing here today?

1

2

3

82

C. THOMAS

A.

Yes.

Q.

And is everything you've told them

4 correct as you told us here today?

I mean, as best as you know, accurate and

5

6

7

A.

Yes.

Correct.

Q.

Is there anything, Ms. Thomas, that

I didn't

haven't asked you or we haven't

8 asked you collectively that you believe that

9 we need bOif know?

10 11 12

13 14 T5

16 17 18 19 20 21

22

23 24 25

MS. SUMACEWSKI:

Obj ection to

relevancy.

THE WITNESS:

NO, I can't think of

anything.

You've pretty much asked

everything that the company did or we did at

the company.

I

I can't think of anything

else.

Okay.

I don't have

MR. BLEVINS:

any more questions.

Do you have any more questions?

MS. SUMACEWSKI:

No, I'm done.

All right.

Thank you.

MR. BLEVINS:

(Whereupon, the Depos i tion of CHERYL

DENISE THOMAS concluded at 11: 06 a.m.)

1

2

5 6

83

C. THOMAS CERTIFICATE

7 transcript was reported, as stated in the

I hereby certify that the foregoing

3 STATE OF GEORGIA:

4 COUNTY OF FORSYTH:

8 caption, and the questions and answers

9 thereto were reduced to typewriting under my

10 direction; that the foregoing pages represent

11 a true, complete and correct transcript of

12 the evidence given upon said hearing, and I

13 14 15 16 17

18 19 20 21

22 23

24 25

further certify that I am not of kin or
counsel to the parties in the casei am not
in the employ of counsel for any of said
parties; nor am I in any way interested in
the result of said case. Mary Ann Hanham

DATE:

March 23, 2011

1 2

March 24, 2011.

84

C. THOMAS CERTIFICATE

3

I, Mary Ann Hanham, a Court Reporter

4 and Notary Public in the State of New York,

5 do hereby certify that the foregoing record

6 taken by me at the time and place as noted

7 in the heading hereof, is a true and

8 accurate transcript of same, to the best of

9 my knowledge and belief.

10

11 12

13 14 15 16 17 18 19 20

Mary Ann Hanham

Dated:

21

22 23 24 25

1

2

85

c. THOMAS CAPTION

3 THOMAS, taken in the matter, on the date,

The Deposition of CHERYL DENISE

10 and the parties that the Deponent will read

11 and sign the transcript of said deposition.

4 5 6 7 8 9

12

13 14 15 16 17 18 19 20 21

22 23 24

25

a.nd at the time and place set out on the
title page hereof.
It was requested that the deposition
be taken by the reporter and that same be
reduced to typewritten form. It was agreed by and between counsel

86

4

Notary Public

C. THOMAS

1 CERTIFICATE

2 STATE OF ___

3 COUNTY/CITY OF __

Before me, this day, personally

5 appeared, CHERYL DENISE THOMAS, who, being duly

6 sworn, states that the foregoing transcript

7 of his/her Deposition, taken in the matter,

8 on the date, and at the time and place set

9 out on the ti tIe page hereof, constitutes a

10 true and accurate transcript of said

11 deposition.

12

13 14 15

CHERYL DENISE THOMAS

SUBSCRIBED and SWORN to before me thi s

16

day of _

2010 in the

17 jurisdiction aforesaid.

18

19 20 21

My Commission Expires

22 23 24 25

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