Q. BY Mr. BROWN: And is it your understanding that each of these trial plan payments were applied as partial payments because they were less than the total amount due?
MR. MCGARRY: Objection. Lack of foundation.
THE WITNESS: Yes.
Q. BY MR. BROWN: And the difference between the partial payment and the total amount due, total amount due was added to the indebtedness, was it not?
MR. MCGARRY: Objection to the form and foundation.
THE WITNESS: Yes.
Q. BY MR. BROWN: And adding it to the indebtedness would increase the forbearance amount ultimately in a modification?
MR. MCGARRY: Objection to the form.
THE WITNESS: Yes.
. BY MR. BROWN: So a borrower--the longer a borrower stayed in the trial plan, the greater amount of the forbearance that Bank of America was considering itself to have to make with a permanent modification?
MR. MCGARRY: Objection to the form and foundation.
THE WITNESS: Yes.
Q. BY MR. BROWN: And that could lead --ultimately, it could lead to a finding of excessive forbearance, if the amount got high enough --
MR. MCGARRY: Objection to the form.
MR. BROWN: -- month after month?
MR. MCGARRY: Excuse me. Objection to the form. Improper hypothetical.
THE WITNESS: Yes.
Original Title
120509 - Depo Tawnya Schoolitz in Re BAC HAMP Contract USD MA
Q. BY Mr. BROWN: And is it your understanding that each of these trial plan payments were applied as partial payments because they were less than the total amount due?
MR. MCGARRY: Objection. Lack of foundation.
THE WITNESS: Yes.
Q. BY MR. BROWN: And the difference between the partial payment and the total amount due, total amount due was added to the indebtedness, was it not?
MR. MCGARRY: Objection to the form and foundation.
THE WITNESS: Yes.
Q. BY MR. BROWN: And adding it to the indebtedness would increase the forbearance amount ultimately in a modification?
MR. MCGARRY: Objection to the form.
THE WITNESS: Yes.
. BY MR. BROWN: So a borrower--the longer a borrower stayed in the trial plan, the greater amount of the forbearance that Bank of America was considering itself to have to make with a permanent modification?
MR. MCGARRY: Objection to the form and foundation.
THE WITNESS: Yes.
Q. BY MR. BROWN: And that could lead --ultimately, it could lead to a finding of excessive forbearance, if the amount got high enough --
MR. MCGARRY: Objection to the form.
MR. BROWN: -- month after month?
MR. MCGARRY: Excuse me. Objection to the form. Improper hypothetical.
THE WITNESS: Yes.
Q. BY Mr. BROWN: And is it your understanding that each of these trial plan payments were applied as partial payments because they were less than the total amount due?
MR. MCGARRY: Objection. Lack of foundation.
THE WITNESS: Yes.
Q. BY MR. BROWN: And the difference between the partial payment and the total amount due, total amount due was added to the indebtedness, was it not?
MR. MCGARRY: Objection to the form and foundation.
THE WITNESS: Yes.
Q. BY MR. BROWN: And adding it to the indebtedness would increase the forbearance amount ultimately in a modification?
MR. MCGARRY: Objection to the form.
THE WITNESS: Yes.
. BY MR. BROWN: So a borrower--the longer a borrower stayed in the trial plan, the greater amount of the forbearance that Bank of America was considering itself to have to make with a permanent modification?
MR. MCGARRY: Objection to the form and foundation.
THE WITNESS: Yes.
Q. BY MR. BROWN: And that could lead --ultimately, it could lead to a finding of excessive forbearance, if the amount got high enough --
MR. MCGARRY: Objection to the form.
MR. BROWN: -- month after month?
MR. MCGARRY: Excuse me. Objection to the form. Improper hypothetical.
THE WITNESS: Yes.