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DEPOSITION OF LONA HUNT

October 17, 2014

CERTIFIED
ORIGINAL TRANSCRIPT

IN THE CIRCUIT COURT OF THE ELEVENTH JUDICIAL CIRCUIT


IN AND FOR MIAMI-DADE COUNTY, FLORIDA
CASE NO.:

- - - - - - - - - - - - -

FEDERAL NATIONAL MORTGAGE


ASSOCIATION,
Plaintiff,
vs.

Defendants.

- - - - - - - - x
Durham, North Carolina
Friday, October 17, 2014
Deposition via Skype videoconference of
LONA HUNT, a witness herein, called for examination
by counsel for the Defendants in the above-entitled
matter, pursuant to notice, the witness being duly
sworn by MAREN M. FAWCETT, RPR, Notary Public in and
for the State of North Carolina, taken at Chapel Hill
Reporting, LLC, 2530 Meridian Parkway, Third Floor,
Durham, North Carolina at 2:07 p.m., on Friday,
October 17, 2014, and the proceedings being taken
down by Stenotype by MAREN M. FAWCETT, and
transcribed under her direction.
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DEPOSITION OF LONA HUNT


October 17, 2014

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APPEARANCES:
On behalf of the Plaintiffs, via teleconference:

MARY STELLA, ESQ.

LAUREN SCHWARZFELD, ESQ.

Law Offices of Popkin & Rosaler, P.A.

1701 W. Hillsboro Boulevard

Deerfield Beach, FL

(954) 360-9030

E-mail: mstella@popkinrosaler.com

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33442

E-mail: lschwarzfeld@popkinrosaler.com

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On behalf of the Defendants, via Skype

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videoconference:

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EVAN M. ROSEN, ESQ.

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Law Offices of Evan M. Rosen, P.A.

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2028 Harrison Street, Suite 204

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Hollywood, FL

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(754) 400-5150

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E-mail: eservice@evanmrosen.com

33020

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Also Present:

Nakeita Ellington, Law Office of

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Evan M. Rosen, via Skype

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videoconf erence

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DEPOSITION OF LONA HUNT


October 17, 2014

C 0 N T E N T S

THE WITNESS

LONA HUNT

By Mr. Rosen

By Ms. Stella

EXAMINATION

54

-ooo-

E X H I B I T S

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EXHIBIT
Defendants' 1

DESCRIPTION
Summons, Lis Pendens

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Verified Complaint

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Mortgage

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13

IDENTIFIED

(Exhibit attached.)
-oOo-

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DEPOSITION OF LONA HUNT


October 17, 2014

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P R 0 C E E D I N G S
Whereupon,

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LONA HUNT,
residence address at

was called as a witness by counsel

for the Defendants and, having been duly sworn by the

Notary Public, was examined and testified as follows:

DIRECT EXAMINATION

10

BY MR. ROSEN:
Q.

Good afternoon, Ms. Hunt.

I'm Evan Rosen.

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I represent Mr. and Mrs.

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you could please state your name, your age and your

13

address?

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A.

Lona Hunt, 58.

in this action.

If

I live at

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16

MS. STELLA:

Mr. Rosen, do you mind if we

17

do not make her home address part of the

18

transcript?

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MR. ROSEN:

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MS. STELLA:

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I think she's already said it.


Court reporter, can we strike

that?

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MR. ROSEN:

I don't think you can strike it

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after the fact.

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protective order or something, you're welcome to

25

do so.

If you want to move for

I have no intention of doing anything

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DEPOSITION OF LONA HUNT


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wi th that in any way , shape or form.

here to harass Ms. Hunt with her address.

MS . STELLA:

Okay.

I ' m not

Well, if you file the

transcript with the court, can we just have her

address taken out?

MR. ROSEN:

record or later .

for now.

Let's continue with the depo

BY MR. ROSEN :

10

We can talk about that off the

Q.

At the time of the verification of this

11

complaint , which was apparently around January 10th ,

12

2012 , where did you live?

13

address at this point.

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city, county and state.

I don ' t need the specific

Let ' s start with maybe the

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A.

Durham .

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Q.

January 10th, 2012 , where did you live?

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A.

Durham , North Carolina .

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Q.

I'm sorry , what was that?

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A.

Durham, North Carolina.

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Q.

Durham .

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A.

No.

22

Q.

And the city that you live in now is?

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A.

Raleigh.

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Q.

Raleigh?

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A.

Yes.

Is that where you live now?

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DEPOSITION OF LONA HUNT


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As of January 10 , 2012, where were you

working , what city and state?

A.

RTP.

Q.

RTP, Raleigh?

A.

Well, it ' s Research Triangle Park.

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Raleigh , in RTP.

That

would probably be Durham.

Q.

Okay.

So you ' re working in Durham and

living in Durham around January 10th of 2012; is that

what you ' re saying?

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11

A.

Yes .
MR. ROSEN :

Guys , there is a delay between

12

the conference and what I ' m seeing on the video

13

and it ' s kind of hard to follow both .

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it ' s okay, what I'm going to try and do is mute

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the conference call and try it over Skype and

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let ' s see if that works.

17

Q.

MS. STELLA:

So if

No , we can't do that because

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then there's a delay and we won ' t have time to

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object before she answers.

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MR. ROSEN:

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MS. STELLA:

So --

There's a delay --- like you just said , there

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is a delay.

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before we hear it or we would --

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25

So if she would answer on Skype

MR . ROSEN:

Yeah, Skype is behind the

conference call , not before though.

So it's

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DEPOSITION OF LONA HUNT


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hard for me to follow along.

MS. STELLA:

Okay.

But the problem is then

we would hear you through Skype and not by the

conference call?

MR. ROSEN:

MS. STELLA:

Then we will have two audios

on, won't we?


MR. ROSEN:

Right.

Well, you'll object -- no, you

know, you would still hear me through

as I

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understand it, there would be a delay on your

11

end as well hearing me through the conference

12

let me just test it for a second and see what

13

it's like.

Hold on.

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Can everyone hear me?

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MS. STELLA:

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hear an echo.
THE REPORTER:

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record for a minute.

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MR. ROSEN:

Yeah, not a problem.

BY MR. ROSEN:

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Evan, if we can go off the

(Discussion off the record.)

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can't hear you well and I

Q.

Ms. Hunt, besides the court reporter, Ms.

Fawcett, is there anyone in the room with you?

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A.

No.

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Q.

We have on the phone with us two other

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October 17, 2014

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attorneys, Lauren Schwarzfeld and Ms. Ste l la.

represent the plaintiff in this case.

is Federal National Mortgage Association .

have a personal attorney there with you?

MS. STELLA:

BY MR. ROSEN:

Q.

They

The plaintiff
Do you

We represent her also.

Do you have any writing, Ms. Hunt , that

indicates that those attorneys that are on the phone

represent you as well?

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A.

I don't understand what you ' re saying .

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Q.

Do you have anything in writing that

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indicates that those two women on the phone, the two

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individuals on the phone represent you as well?

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A.

Yes .

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Q.

You have something in writing that says

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that they represent you?


MS. STELLA:

Form.

I don't think she's

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understanding the question.

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You can take my word for it .

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the carrier.

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MR. ROSEN:

We represent her.
We also represent

Ms . Scharzfeld, if you have an

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objection , please state it clearly and concisely

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for the record.

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is you're instructing the witness how to answer

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and that's improper.

What you ' re doing by speaking

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DEPOSITION OF LONA HUNT


October 17, 2014

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MS. STELLA:
speaking.

MR. ROSEN:

Well, not during the depo

you ' re not.

clearly and concisely pursuant to 1.310 .

Speaking objections are not permitted.

You ' re going to state an objection

MS . STELLA :

I ' m the one making the

objections and defending the deposition .

me , Ms . Stella.

10

MR. ROSEN :

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MS . STELLA:

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BY MR. ROSEN:

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Q.

I t's

Okay .
Just trying to be clear.

So my question, Ms . Hunt, and we ' ll get to

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that in a second about the objections , et cetera, do

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you have anything in writing that indicates that

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you ' re represented by these attorneys that are on the

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phone?

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MS . STELLA :

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BY MR. ROSEN:

Form.

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Q.

You can still answer.

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A.

I ' m -- I still don ' t understand what you ' re

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(""

I' m the one who is going to be

trying to ask me.


Q.

Sure .

Ms. Hunt, do you have anything in

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writing that indicates that you're represented by any

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attorney in this action?


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DEPOSITION OF LONA HUNT


October 17, 2014

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MS. STELLA:

MR. ROSEN:

And she ' s not a party .

You can answer the question .

Again, Ms. Stella , you're instructing the

witness and suggesting and under l.310(c)

specifically, objections, quote , during

depositions must be stated concisely and in a

non- argumentative and non-suggestive manner.

MS . STELLA :

THE WITNESS :

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Form .
I ' m.

BY MR. ROSEN:

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Form .

Q.

If you're looking at any papers, you really

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can ' t do that at this point .

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tell me , " I don't know."

If you don ' t

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A.

I don't know.

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Q.

If you don ' t know then tell me.

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Okay.

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MS. STELLA:

know, just

Fair enough .
If we can just, for the

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record, be clear, court reporter , can you please

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have the record reflect that we , Popkin and

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Rosaler represent Ms. Lona Hunt with respect to

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this deposition and in this case.

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BY MR. ROSEN:
Q.

Ms. Hunt , you heard what was just said .

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you have any reason other than what was said to

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believe -- I've asked you if you have anything in


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DEPOSITION OF LONA HUNT


October 17, 2014

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writing and you don ' t know.

o t her than what you just heard that you ' re

represented by anyone in this case?

Please repeat .

MS . STELLA :

BY MR. ROSEN:

Q.

Form.

Do you have any reason to believe that

you ' re represented by an attorney other than what you

just heard from the person speaking on the phone?

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A.

I don ' t know.

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Q.

Okay .

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MS. STELLA:

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minute, please?

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MR . ROSEN :

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16

Can we go off the record for a

No , we can ' t.

We ' re going to

continue on with the deposition.


MS. STELLA:

If we're going to have an

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issue as to whether or not she is represented

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it ' s going to be a problem.

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to be a problem, then we're going to have to end

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the deposition.

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represent her?

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A.

Any reason to believe

MR . ROSEN :
record .

And if it ' s going

So can we establish that we

You ' re testifying on the

Let's go forward .

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MS . STELLA :

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and you refused.

I asked to go off the record


So if you prefer to go off the

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record, we can talk about it then.


MR. ROSEN:

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obstructing my ability to take a deposition.

I'm going to move for a protective order and

certify the pending questions and I'm going to

get a judge on the phone now.

continue the deposition or you can take your own

deposition.

later.

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You can let me

You can ask your own questions

You have an opportunity to do that, but

I'd like to continue the deposition, please.


MS. STELLA:

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Ms. Stella, you're now

We can get a judge on the

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phone if you'd like.

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establish that we represent her.


MR. ROSEN:

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That's going to help

If you're going to continue to

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obstruct, then I have no choice.

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continue on with the deposition.

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MS . STELLA:

Let me just

I'm asking to just establish

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that we represent her.

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right now, which should be sufficient.

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MR. ROSEN:

I'm telling you that

You're testifying on the record

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on my deposition -- during my deposition.

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you've said what you want to say, we can move

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on.

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Thank you.
BY MR. ROSEN:

Q.

Ms. Hunt, have you ever been deposed

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DEPOSITION OF LONA HUNT


October 17, 2014

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before?

A.

No.

Q.

Any reason you ' re unable to answer

truthfu l ly today?

A.

No.

Q.

I ' ll ask you to please give full answers to

questions.

Okay?

A.

Yes.

Q.

And if there are any documents that can

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help you answer a question , if you'll please let me

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know.

Okay?

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A.

Okay.

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Q.

Now , there ' s a court reporter there who is

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taking down the questions and answers.

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verbalize your answer.

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head or say "uh- huh" or "huh- huh" .

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that?

You have to

You can't just shake your


Do you understand

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A.

Yes .

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Q.

And you understand that we're here asking

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you questions under oath to gather information.

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if you answer a question, I ' m going to assume and

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we ' re all going to assume that you understood the

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quest i on .

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us know that you don't understand.

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And

If you don ' t understand , you'll please let


Okay?

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DEPOSITION OF LONA HUNT


October 17, 2014

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Q.

Just like you ' ve done that already,

so that ' s good .


If you need to take a break or use the rest

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room, please just let us know, we'll be happy to

accommodate you.
Once we ask a question , you can ' t speak to

Okay .

anyone once a question is pending, okay.

understand that?

A.

Okay.

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Q.

Okay.

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A.

Yes .

12

Q.

Okay.

Do you

Are you taking any medication?

I don't want to pry , but any

13

medication that would affect your ability to testify

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truthfully and to understand the questions being --

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any questions being posed to you normally?

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A.

No .

17

Q.

And are you feeling well today , no cold or

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illness?

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A.

Yes , I

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Q.

Great.

feel fine.
I

have to ask, unfortunately , are

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you under the influence of any drugs or alcohol at

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the moment?

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A.

No .

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Q.

Good.

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Now, as you've heard, there may be

some objections from the lawyers on the phone .

In

I
J

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very limited circumstances can a lawyer advise you

not to answer.

is an objection the rules requ i re that you still

answer, even when the objection is pending.

okay

Are you

do you understand that?

A.

Yes.

Q.

Okay .

So unless someone tells you not to

answer, you just can go ahead and answer and ignore

the objection for your purposes .

Okay?

10

A.

Yes.

11

Q.

Did you prepare for this deposition?

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A.

Yes.

13

Q.

Okay.

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A.

I looked at the loan.

15

Q.

When you say you looked at the loan, what

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do you mean?

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A.

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r'

Generally, in a deposition when there

How did you prepare?

I pulled it up and looked who it was and

looked at the information that was on the verified.


Q.

When you say you looked it up, what were

you looking at, were you looking at the computer?

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A.

Our -- yes.

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Q.

And what is that computer system, what is

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that called?

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MS. STELLA:

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BY MR. ROSEN:

Form.

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DEPOSITION OF LONA HUNT


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Q.

You can answer.

Again, she's objecting to

form, but you can go ahead and answer.

A.

It's just a computer report.

Q.

Okay.

report?

A.

PULS.

Q.

I'm sorry, I couldn't hear that.

A.

PULS.

Q.

PULS?

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A.

Yes.

11

Q.

Is that p-a-1-s?

12

A.

P-u-1-s.

13

Q.

Okay.

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A.

I don't know .

15

Q.

What did you see in the PULS system while

16

What is that called, the computer

And what does that stand for?

preparing for this deposition?

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A.

Just the name, the address and the dates.

18

Q.

You saw the borrowers' names, Mr. and

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A.

Yes.

21

Q.

The address of the property?

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A.

Yes.

23

Q.

And the date you said?

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A.

Yes.

25

Q.

What dates are you ref erring to?

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Mrs.

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DEPOSITION OF LONA HUNT


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A.

The date that they have their owed for.

Q.

Anything else that you reviewed in the PULS

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4

A.

That was it.

Q.

Any -- you said you earlier had looked at

the l oan.

loan, so really was it the name, the address and the

dates?

So when you said you were looking at the

A.

Yes.

10

Q.

And that's the date of the default, the

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system while preparing for this deposition?

amount or - - rather, the date that ' s owed?

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A.

Yes.

13

Q.

Okay.

14

A.

That was it .

15

Q.

And these were a l l on a computer screen or

16

And anything else you looked at?

you printed these things out, the PULS report?

17

A.

On the screen.

18

Q.

When did you do this?

19

A.

Today .

20

Q.

Are you able to do that on your own or did

21

someone else print it for you?

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MS. STELLA :

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24
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Form .

She said that it wasn ' t

printed.
MR . ROSEN:

Again, feel free to object.

Obviously, I don ' t want to impede your ability


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DEPOSITION OF LONA HUNT


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to object, but the question is pending.

BY MR. ROSEN:

Ms. Hunt, you can go right ahead and

Q.

answer.

A.

On the screen.

Q.

Did you pull it up on the screen yourself?

A.

Yes.

Q.

Okay.

Was anyone in the room with you when

you pulled this up on the screen?

A.

There's people in different cubes around

12

Q.

Okay.

13

A.

No.

14

Q.

Okay.

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11

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me.
Anyone in your cube?

Did you have a conversation with any

attorneys in preparation for today?


MS. STELLA:

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I'm going to object.

And,

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Lona, you can answer it to the extent that how

18

you prepared, but any kind of our communication,

19

any communications with the attorneys is

20

privileged and I will direct you not to answer.

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To the extent you can answer without divulging

22

the contents of our discussions, you can answer.

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24

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BY MR. ROSEN:

Q.

And just to be clear, I don't want to know

what was said.

I just want to know did you -- did

I
. = ___/

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you meet with them to start?

that I'm going to ask you that I want to know what

was said, I don't want to know and I ' m not asking.

Well, I may want to know, but I'm not asking.


Tell me, to answer your question, did you

('

If there's something

meet with the attorney, any attorneys in preparation

for today?

A.

Yes.

Q.

And when was that?

10

A.

At 9:00 , 9 o'clock this morning.

11

Q.

Okay.

12

How many times did you meet with the

attorneys in preparation for this?

13

A.

Once.

14

Q.

Did you meet in person?

15

A.

Can you repeat that, please?

16

Q.

Sure.

17

How did you meet, in person or over

the phone or some other method?

18

A.

Phone.

19

Q.

And who else was on the phone call?

20

A.

What ' s her name?

21

Q.

So Lauren, yourself and anyone else?

22

A.

Mary.

23

Q.

Okay .

Lauren.

Let's talk about where you work now .

24

Do you still work for Seterus?

25

that's the right way to pronounce it.

And I never know if


Is that how

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it's pronounced, Seterus?

A.

Seterus, yes.

Q.

I've heard some people say Seterus , but I

don't know .

So it ' s Seterus, okay.

Anyplace else that you work for?

MS. STELLA:

BY MR. ROSEN:

Form.

Q.

You can answer.

A.

Yes.

10

Q.

Okay.

11

A.

Oh, I'm not understanding what you mean.

12

Q.

Do you work for another company in addition

13

to Seterus?

14

A.

Oh, no.

15

Q.

Okay.

16

Do you work anyplace else?

Where else do you work?

And where is the location that you

work for Seterus?

17

A.

Please specify what you mean.

18

Q.

Sure .

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22

What is the address of where you go

to work for Seterus?


A.

3039 East Cornwallis Road, Durham, North

Carolina.
Q.

And at the time of the -- of January 10 ,

23

2012 was that where you were working, in that same

24

location?
A.
Yes.

25

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DEPOSITION OF LONA HUNT


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(''
Q.

1
2

looks like back in January 2011; is that right?

MS. STELLA:

THE WITNESS:

BY MR . ROSEN:

Form .
2010 .

Q.

Do you know what month?

A.

April.

Q.

What is your job title with Seterus now?

A.

Time management specialist.

10

Q.

What was your job title as of January 10,

12

A.

Foreclosure specialist.

13

Q.

When you started with Seterus what was your

11

And you started working with Seterus it

14

2012?

job title?

15

A.

Foreclosure specialist.

16

Q.

And did it stay foreclosure specialist all

17

the way through January 10, 2012?

18

MS. STELLA:

19

BY MR. ROSEN:

20

Q.

Form.

In other words, were you a foreclosure

21

specialist from the time you started to the time you

22

signed the complaint?

23

after that.

And then we'll talk about

24

A.

Yes.

25

Q.

And at some point your title changed

'- .

Chapel Hill Reporting, LLC, Serving North Carolina


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apparently.

A.

January 2014.

Q.

And what did that change to?

A.

Time line management or specialty.

Q.

And that would be your title today?

A.

Pardon me?

Q.

That is your job title still today,

timeline management specialist?

A.

Yes .

10

Q.

Just to be clear , your title is not record

11

custodian , correct?

12

A.

Correct.

13

Q.

It ' s never been record custodian while at

14

Seterus?

15

MS . STELLA:

16

BY MR . ROSEN :

Form.

17

Q.

You can answer.

18

A.

Repeat, please.

19

Q.

Sure .

20

Your job t i tle has never been record

custodian since you ' ve been with Seterus , right?

21

A.

Correct .

22

Q.

As a foreclosure specialist back in

23
24

When did your title first change?

25

January 2012 , what were your job responsibilities?


A.

To get documents that the attorneys needed.

I did the verified complaint.


Chapel Hill Reporting, LLC, Serving North Carolina
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1

Q.

Anything else?

A.

That was it.

Q.

When you said get documents that attorneys

needed , what did you mean by that?

A.

The note and the mortgage.

Q.

So tell me, would an attorney request that

from you?

A.

Yes.

Q.

And how would you go about getting the note

10

and the mortgage to the attorney?

A.

11
12

our system and I would just -- I don ' t

13

put it, how to say it.

14

15
16

know how to

It would already be imaged .

would just send it in a DDF.

Q.

Okay .

Was it an e-mail or some sort of

other program that you did that?

17

A.

It was in another program.

18

Q.

Do you remember the name of that program?

19

A.

LPS.

20

Q.

LPS, okay.

21
22

Uploading it into our system or it was in

Any other responsibilities around January


of 2012?

23

A.

No.

24

Q.

And prior to January 2012, from the time

25

you started with Seterus, have your responsibilities


-~ .. -

--- -

........._. ...... ..1. _ _ _

- - - -" \ -

Chapel Hill Reporting, LLC, Serving North Carolina


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DEPOSITION OF LONA HUNT


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1

A.

No .

Q.

So have you had your responsibilities

No .

change after January 10, 2012?

A.

No.

Q.

How about when your job title changed in

January of this year, did your responsibilities

change then?

A.

Yes .

10

Q.

And how so?

11

A.

I don ' t do verified complaints anymore .

12

Q.

Okay .

13

A.

How do I put that?

What do you do now?


I

don ' t

know how to say

14

it .

15

the proper processes to move forward on the next

16

milestone.

17
18
19

changed?

I check -- I make sure that the attorneys are at

Q.

Could you please explain a little bit more

about that for us?


A.

I put loans on hold , remove holds and just

20

make sure that the loans are moving towards the

21

f oreclosure .

22

Q.

It sounds like you ' re interacting with

23

attorneys, and you just correct me if I ' m wrong,

24

you ' re interacting with attorneys to help move cases

25

along that are in foreclosure; is that right?


Chapel Hill Reporting, LLC, Serving North Carolina
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A.

Correct, yes.

Q.

And you said to meet certain milestones.

What are those milestones?

A.

Like judgment, NODs and sell dates.

Q.

Any other milestones?

A.

No.

Q.

Is referral or filing suit , is that

considered a milestone?
MS. STELLA:

9
10

Form .

BY MR. ROSEN:

11

Q.

You can answer.

12

A.

The referral is already completed by the

13
14
15

time I get the loan.


Q.

Okay.

So you're working with loans that

are in default at this point?

16

A.

Yes.

17

Q.

And the same for as of January 10, 2012 you

18

were working only with l oans that were in default as

19

a foreclosure specialist , right?

20

MS. STELLA:

21

BY MR. ROSEN:

Form.

22

Q.

Again, you can answer .

23

A.

Okay.

Can you repeat, please?

24

Q.

Sure .

January 10 , 2012 your involvement

25

with Seterus was for loans that were in default,


Chapel Hill Reporting, LLC, Serving North Carolina
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1

correct?

A.

Yes.

Q.

You didn ' t have any involvement with loans

that people were current on their mortgage , right?

A.

Correct .

Q.

Do you supervise anyone?

A.

No.

Q.

And this location that you gave us, your

work l ocation in Durham, is that an office?

10

A.

It ' s a -- yeah .

11

Q.

It's a building , but it ' s an office for

12

Seterus?

13

home let ' s say or some other place?

I ' m asking you ' re not working out of your

14

A.

It's a building for Seterus .

15

Q.

Okay.

16

18

Have you ever signed anything other

than verifications for Seterus in a foreclosure - MS . STELLA:

17
Q.

MS. STELLA:

20

BY MR . ROSEN :

22

Q.

Form.

-- proceeding?

19

21

It ' s a building.

Form .

You can answer.

I ' ll repeat it if you need

me to .

23

A.

Please repeat .

24

Q.

Have you signed anything else other than

25

verifications for Seterus?


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1

A.

No.

Q.

Prior to working for Seterus, if you could

give us a little bit about your background .

other type of work did you do?

A.

I worked for Nortel .

Q.

Nortel Networks like the cell phone

communications company?

A.

Yes .

Q.

It looks like you were there for a very

10

long time , 26 or so years; is that right?

11

A.

Yes .

12

Q.

That ' s a milestone.

13

achievement.

14

me ask you just briefly, what did you do for Nortel

15

roughly?

That ' s quite an

And prior to that you were with -- let

16

A.

Data entry, inventory control .

17

Q.

And prior to that you were with Barclays

18

~-

What

and then Wachovia; is that right?

19

A.

Yes.

20

Q.

And what did you do for those companies?

21

A.

I was foreclosu r e.

22

Q.

What about foreclosure did you do?

23

A.

Bids .

24

Q.

Bids?

25
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1
2

So you helped Wachovia or Barclays purchase

foreclosures, is that what you did?

A.

No.

Q.

Okay.

A.

I would prepare the bid for the attorney to

go to sale.

8
9

Please describe what you mean by

bid .

Q.

The process of preparing the bid for the

attorney to go to sale, other than that , is there

10

anything else that you did with Wachovia or Barclays

11

while you worked there?

12

A.

No.

13

Q.

And how long were you at Barclays and

14

Wachovia?

15

MS. STELLA:

16

BY MR. ROSEN:

17
18

Q.

How long were you at those

companies?
MS . STELLA:

20

THE WITNESS:

21

BY MR . ROSEN :

23

Form.

You can answer.

19

22

Q.

Q.

Form.
Almost ten years.

What ' s the highest level of education

you ' ve received?

24

A.

GED.

25

Q.

Now, we're here to testify -- you're here

l
I

lI

lI
I

"--'

Chapel Hill Reporting, LLC, Serving North Carolina


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to testify about a particular case .

The case is a

Miami - Dade County, Florida case.

the Federal National Mortgage Association .

defendants , among others , are

The plaintiff is
The
and

I'd like the court reporter to hand you the

documents that we sent .

It should be a complete copy

of the complaint.

have a copy of that, I ' ll gladly e-mail it to you now

And , Mary and Lauren, if you don't

10

what I sent to the court reporter.

11

summons.

12

the last page being the last page of the note.

It's

13

the summons that was served on

It is

14

the complete package, includes a lis pendens, et

15

cetera , but it is the verified complaint that was

16

filed in this case.

17

copy .

18
19

It starts with the summons and ends with

MS. STELLA:

If you'd like I can send you a

Will you be questioning her on

the summons?

20

MR. ROSEN:

21

MS. STELLA:

22

It was the

No.

No, I will not.

I just have the complaint , so

that ' s fine.

23

MR. ROSEN:

24

sure you have a copy.

25

look at the complaint and at the package in

Okay.

So you have it.

I 'm

Let me ask you to take a

Chapel Hill Reporting, LLC, Serving North Carolina


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1

front of you.

could just mark this for identification

purposes.

(Exhibit 1 marked for

identification.)
BY MR. ROSEN:

6
Q.

('

And, madam court reporter, if you

And I want to call your attention there a

few pages in where it says "verified complaint".

you see that?

10

A.

Yes.

11

Q.

And I want you to flip over to the next

Do

12

page where it shows "Seterus, Inc., as servicer for

13

Federal National Mortgage Association," midway down

14

the page.

Do you see that?

15

A.

Yes.

16

Q.

Is that your signature?

17

A.

Yes.

18

Q.

Okay.

And it says the date lS


Is that the date that you

19

January 10th, 2012.

20

actually signed that document?

21

A.

Yes.

22

Q.

You're shaking your head.

24

A.

Oh, no.

25

Q.

Okay.

23

Are you not

sure?
Yes, it's on the document.
If you don't remember feel free to

Chapel Hill Reporting, LLC, Serving North Carolina


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1

say, "I don't remember," but that's what it shows.

don ' t want to put words in your mouth, okay.

A.

Okay.

Q.

Did you undertake any training to verify a

complaint for Seterus prior to January 10, 2012?

A.

Yes.

Q.

And what was that training?

A.

It was where the managers train us on how

9
10

to -- or trained me on how to verify and to look at


the document.

11

12

Q.

Okay.

Who was it that trained you?

I 'm

sorry, it broke up a little bit.

13

A.

My team lead .

14

Q.

And who was that person, what is their

16

A.

Richard Adams.

17

Q.

And when did Richard Adams train you?

18

A.

Repeat, please.

19

Q.

Sure.

20

A.

I don't remember.

21

Q.

Would it have been when you first started

15

22

name?

When did Richard Adams train you?

working for Seterus?

23

A.

No.

24

Q.

Would it have been within a year roughly

25

after you started working for Seterus?


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1

A.

Yes.

Q.

And how many times did you meet with -- or

train with Mr. Adams?

A.

A couple of times.

Q.

A couple meaning two?

A.

Yes .

Q.

And what did you - - what did Mr. Adams

explain to you or what did your training consist of,

rather?

10

A.

The verified complaint and what to look for

11

on the verified complaint that was on our computer

12

report.

13

Q.

14

So explain that to me just briefly.

would go over a verified complaint on the computer?

15

MS. STELLA:

16

BY MR. ROSEN:

17
18
19

You

Q.

Form.

You can answer.

You went over a verified

complaint on the computer?


A.

Would look at the document that we received

20

and we would look at the computer report on what I

21

was supposed to look at to make sure that both

22

matched.

23
24
25

Q.

So the document that you received, what are

you referring to , what document did you receive?


A.

The verified complaint .

Chapel Hill Reporting, LLC, Serving North Carolina


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DEPOSITION OF LONA HUNT


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33
1
2

So that would come in to you in paper or on

computer?

A.

Paper.

Q.

Okay.

A.

In a box.

Q.

Do you know who put that paper in the box?

A.

No.

Q.

And did you have a box to start at the

Q.

And how did that get to you?

beginning of each day with verified complaints?

10

A.

Yes.

11

Q.

And roughly how many did you have in the

12

box at the beginning of each day?

13

A.

It varied.

14

Q.

Okay.

15

More or less , if you could tell us a

high number or a low number for a day?

16

MS . STELLA:

Form.

17

BY MR . ROSEN :

18

Q.

You can answer, if you know .

19

A.

I don ' t.

20

Q.

You don ' t know roughly the range of how

21

many verified complaints would be in the box each

22

day?

23

MS. STELLA:

24

BY MR. ROSEN:

25

Q.

Form.

You can answer .

Chapel Hill Reporting, LLC, Serving North Carolina


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DEPOSITION OF LONA HUNT


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1

A.

Roughly maybe 60 .

Q.

And approximately how many of those did you

view each day?

MS. STELLA :

THE WITNESS :

BY MR. ROSEN:

Q.

Form .
Thirty .

MS . STELLA :

Form.

THE WITNESS:

Yes .

11

remember .

And did you verify those 30 each day?

10

I can ' t

BY MR . ROSEN:
Q.

Apparently then there must have been a

12

backlog that was getting created if 60 are coming in

13

roughly and 30 are being verified roughly, the box

14

must have been building up?

15

MS. STELLA:

16

BY MR . ROSEN :

17

Q.

18
19

Is there a time that you caught up -MS. STELLA :

Q.

Form.

Form.

-- on the verifications?

20

MS. STELLA :

21

MR. ROSEN :

22

finish the question .

23

MS . STELLA:

24

MR. ROSEN :

25

Form.
If you could please let me

There is a lag.
There is an objection in the

middle of my question.
Chapel Hill Reporting, LLC, Serving North Carolina
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DEPOSITION OF LONA HUNT


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1

MS . STELLA:

MR. ROSEN:

I hear you on that.

intended or pun intended.

Q.

MS. STELLA:

BY MR. ROSEN:
Q.

filings?

11

along as best we can.


A.

Was there a backlog of

Note counsel's objection .

objection to form.

12

Form.

You can answer.

10

13

Yes.

So was there a backlog?

No pun

BY MR. ROSEN:

There is a break -- sorry.

There is an

I'm trying to help move this

Backlog as -- what do you mean by a

backlog?

14

Q.

Sure.

You're telling us that about 60

15

roughly per day came in to your box of verified

16

complaints and that you got to verify about 30 of

17

them.

18

did they remain in the box?

My question is what happened to the other 30,

19

A.

They were put in a cabinet.

20

Q.

And were those extra 30 then returned back

21
22

to you the next day?


A.

Yes.

23

MS . STELLA:

24

BY MR. ROSEN:

25

Q.

Okay.

Form.

And then more verifications

Chapel Hill Reporting, LLC, Serving North Carolina


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DEPOSITION OF LONA HUNT


October 17, 2014

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1

verified complaints would be added to that box for

you to continue to work on each day, is that how that

worked?

A.

Yes.

Q.

Okay.

As far as the training that you

started to talk about with Mr. Adams, so it sounds

like now that you got the verified complaint and he

trained you how to look at the computer , is that what

you were saying , to look at the computer and look at

10

the documents and compare things?


MS. STELLA :

11

Ii

Form .

BY MR. ROSEN:

12
13

Q.

You can answer.

14

A.

Yes.

15

Q.

Tell us a little bit about that.

What is

16

it that you were looking for to compare between the

17

verified complaint and what was on the computer?

18

A.

The defendant ' s name , the county .

19

Q.

If you could just

it looks like you're

20

looking down at some paper.

21

testify as to personal knowledge.

22

any paper to refresh your recollection, we can

23

certainly explore that, but just as far as what you

24

know rather than looking at anything .

25

A.

I just want you to


If we need to use

Just --

i
Chapel Hill Reporting, LLC, Serving North Carolina
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DEPOSITION OF LONA HUNT


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1

Q.

The defendant's name, the county?

A.

The UPB and the date.

Q.

And that's the date of?

A.

The default.

Q.

Okay.

at between the verified complaint and what was on the

computer screen?

MS. STELLA:

Form.

THE WITNESS:

No.

BY MR. ROSEN:

10

('

Anything else that you were looking

11

Q.

What was on the computer screen?

12

A.

Their loan number, their name, their

13

address, their UBP and the default date.

14

Q.

And was that through that PULS system as

16

A.

Yes.

17

Q.

And PULS, you've been using PULS the entire

15

well?

18

time you've been with Seterus?

19

MS. STELLA:

20

THE WITNESS:

21

BY MR. ROSEN:

22

Q.

Okay.

Form.
Yes.

Is there anything else that you

23

looked at other than the PULS report when looking at

24

the complaint?

25

MS. STELLA:

Form.

Chapel Hill Reporting, LLC, Serving North Carolina


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DEPOSITION OF LONA HUNT


October 17, 2014

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1

THE WITNESS:

BY MR. ROSEN:

Q.

Please say it again.

Was there anything else you looked at other

than the PULS report when also looking at the

complaint?

MS. STELLA:

Form.

THE WITNESS:

BY MR. ROSEN:

You can answer.

The note and the mortgage.

Q.

Anything else?

10

A.

No.

11

Q.

And how did you view the note and mortgage?

12

A.

In the package.

13

Q.

Was that a printed package?

14

A.

Yes.

15

Q.

So in the package was a blank verified

16

complaint and a note and a mortgage?

17

A.

Yes.

18

Q.

Okay.

And so that's what we were talking

19

about, those packages were in your box in the

20

morning

21

A.

Yes.

22

Q.

-- right?

23

A.

Yes.

24

Q.

Was there anything else in the package?

25

MS. STELLA:

Form.

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DEPOSITION OF LONA HUNT


October 17, 2014

39

THE WITNESS:

BY MR . ROSEN:
Q.

When you were done comparing what was on

PULS and looking over the package and let's say you

signed and -- you signed the complaint, what happened

to the complaint next, what did you do with it?

A.

Put it in a FedEx box .

Q.

And where did that document then -- where

did that package then go?

10

A.

To the attorney.

11

Q.

Did the package contain the original note

12

and mortgage?

13

A.

No .

14

Q.

Anything else that you went over with

15

Mr . Adams in your training?

16

A.

No.

17

Q.

Approximately how long did you train with

18

Mr. Adams those two times that you met with him?

19

A.

I don ' t remember.

20

Q.

Would it be less than an hour each time

21

r"

I can ' t remember .

roughly?

22

A.

No .

23

Q.

Okay.

It would be longer .
And as part of your training did you

24

actual l y sign some comp l aints while he supervised

25

you?
Chapel Hill Reporting, LLC, Serving North Carolina
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DEPOSITION OF LONA HUNT


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1

A.

I don't remember.

Q.

Did he sign any complaints while you

watched him?

A.

I don ' t remember .

Q.

Now, you talked earlier about a cubicle.

Is that what you were working in a cubicle in January

of 2012 when you signed this complaint?

A.

Yes.

Q.

If you could just describe for us briefly

10

the office space area, help us get a picture , how

11

many cubicles were in the area in which you worked?

12

MS. STELLA:

13

THE WITNESS:

14

BY MR. ROSEN:

15

Q.

Four.

Form.
Four.

And were there any -- if there four

16

cubicles in the room, was there anything else in that

17

room besides the four cubi cles?

18

MS . STELLA:

19

THE WITNESS :

20

BY MR. ROSEN:

Form .
Filing cabinet.

21

Q.

And anything else?

22

A.

No .

23

Q.

Were the other people in the other cubicles

24
25

doing the same thing that you were doing?


A.

No.

Chapel Hill Reporting, LLC, Serving North Carolina


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(""
2

doing?

MS. STELLA:

THE WITNESS:

BY MR. ROSEN:

6
7

Q.

Form.
I don't remember.

But you know they were not doing the same

work as you, right?

A.

Right.

Q.

Okay.

10

What type of work were the other people

Q.

Did you ever sign notarized

documents?

11

MS. STELLA:

12

THE WITNESS:

13

BY MR. ROSEN:

14

Q.

Sure.

Form.
Not sure what you're asking.

Did you ever sign in the presence

15

of a

a notarized document, meaning that you sign

16

and then a notary will sign and stamp it, did you

17

ever do that for Seterus where you're signing

18

something that is then notarized?

19

MS. STELLA:

20

THE WITNESS:

21

BY MR. ROSEN:

22
23

Q.

Okay.

Form.
No.

Anyone else in those cubicles that

were signing things that are then notarized?

24

MS. STELLA:

Form.

25

THE WITNESS:

I don't remember.

Chapel Hill Reporting, LLC, Serving North Carolina


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DEPOSITION OF LONA HUNT


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42

BY MR . ROSEN:

Q.

How much time does it take you to review

the documents in the package and what ' s on the screen

when you ' re undertaking this process that you did in

this case where you ' re signing the complaint?

MS. STELLA:

THE WITNESS :

BY MR . ROSEN :

Q.

Form.
Five to ten minutes.

Do you know in this case who the owner of

10

the loan is?

11

if you know.

12

A.

Repeat, please.

13

Q.

Sure .

14

Do you know who the owner of the

loan is in this case?

15

A.

16

Q.

17

Without looking at any documents , just

And do you know who the servicer of the

loan is in this case?


A.

Fannie Mae.

19

Q.

And what is Seterus ' s -- I mean, back up

for one second , I ' m sorry .

21
22

Hold on for one second.

Do you know where the original note and


mortgage was kept around January 10th of 2012?

23

::~ ::::~:~: F:::~ all -- repeat .

24
25

..
--n"";'lt-..

18

20

I
I

BY MR . ROSEN:
-=-<=1"- .....--- ...~-'" ..,,.,.. ~..
"l'-1'-f...

lI

l
Il
I
11

......-

- - - - - - -.... , ._

........

..,;.1._ .........

~ ..... ~~ ....... -

- - -..

Chapel Hill Reporting, LLC, Serving North Carolina


(919) 969-1169

DEPOSITION OF LONA HUNT


October 17, 2014

43

~
1

Q.

Sure .

Do you know where the original note

was kept at the time of January 20 1 2?

MS . STELLA:

THE WITNESS:

BY MR. ROSEN:

Q.

Form .
No .

And you never saw the original documents ,

the original note when you reviewed the complaint and

the documents we talked about , right?

A.

Right .

10

Q.

Let's take a look at the complaint .

11

of all, before you signed, did you read the

12

complaint?

First

13

A.

No.

14

Q.

It says in paragraph 1 that this is an

15

action to foreclose a mortgage on real property

16

located in Miami-Dade County , Florida.

17

know or how do you know, if you know, that this

18

property is l ocated in Miami - Dade County, Florida?

How did you

19

A.

The mortgage .

20

Q.

And also in paragraph 1 there is the word

21

" conditions precedent".

22

precedent mean?

23

24
25

MS . STELLA:

What does conditions

Objection.

It ' s a legal

conclusion.
BY MR. ROSEN:
Chapel Hill Reporting, LLC, Serving North Carolina
( 919) 969-1169

DEPOSITION OF LONA HUNT


October 17, 2014

44
1

Q.

You can answer.

A.

I'm not sure .


MS . STELLA:

If you understand the

question, you can answer.

THE WITNESS :

MS. STELLA:

I didn ' t hear what she said .


If you understand the

question, you can answer , but we ' re objecting on

the basis that it ' s a legal conclusion .


THE WITNESS:

MR. ROSEN:

10

I don't understand.
It ' s a speaking objection .

11

you can just limit it.

12

BY MR . ROSEN:

If

13

Q.

Ms. Hunt?

14

A.

Sir?

15

Q.

I just want to know if you know what that

16

means?

17

A.

I don't understand , no .

18

Q.

Okay .

You understand my question , you just

19

don ' t understand what conditions precedent means , is

20

that what you ' re saying?

21

A.

Yes.

22

Q.

How did you know, if at all , whether or not

23

conditions precedent to the filing of this matter had

24

been completed or waived, if you knew?

25

MS. STELLA:

Objection, lega l conclusion.

Chapel Hill Reporting, LLC, Serving North Carolina


(919) 969-1169

-I

DEPOSITION OF LONA HUNT


October 17, 2014

45

~
BY MR. ROSEN:

1
2

Q.

You can answer.

A.

I didn't know.

Q.

Okay.

In paragraph 2 it says subject


How do you

property owned by defendant

know that or do you know that?

A.

The mortgage and the note.

Q.

And something in the mortgage and note

9
10

tells you that they own

A.

Repeat, please.

12

Q.

Sure.

owns the

Something in the mortgage and note


owned the property?

tel l s you that

14

A.

Yes.

15

Q.

Okay.

16

that

subject property?

11

13

("'

I don ' t know.

Again , if you could just not refer

to any paper.

17

A.

Oh , okay .

18

Q.

Thank you so much.

In paragraph 3, and

19

this you're welcome to refer to as I ' m reading from

20

the paragraph , I don ' t mind, just so you can follow

21

along .

22

possession, occupants, and it has an address there,

23

may claim some interest in the subject property by

24

virtue of their possession or occupancy of the same.

25

Did you know if that was the case that there were any

Paragraph 3 says that unknown tenants in

Chapel Hill Reporting, LLC, Serving North Carolina


(919) 969-1169

DEPOSITION OF LONA HUNT


October 17, 2014

46

tenants in possession of the property?

A.

No.

Q.

And what does it mean to be subordinate,

junior and inferior to the lien of plaintiff's

mortgage?

MS. STELLA:

THE WITNESS:

BY MR. ROSEN:

Q.

Objection, legal conclusion.


I'm not sure.

And in the next paragraph, paragraph 4,

10

that in addition to all other defendants and it says,

11

"Unknown spouses, heirs, devisees, grantees,

12

assignees, creditors, trustees, successors in

13

interest or other parties claiming interest in the

14

subject property by, through or against any said

15

defendants, whether natural or corporate, who are not

16

known to be alive or dead, dissolved or existing, are

17

joined as defendants herein."

18

those other specifically -- how did you know that

19

that was the case?

20

MS. STELLA:

21

THE WITNESS:

22

BY MR. ROSEN:

23

Q.

Okay.

How did you know about

Objection, legal conclusion.


I don't know.

It then says, "The claims of said

24

parties are subject, subordinate and inferior to the

25

interests of the plaintiff."

How did you know that

Chapel Hill Reporting, LLC, Serving North Carolina


(919) 969-1169

DEPOSITION OF LONA HUNT


October 17, 2014

f'1"

47
1

that was correct?

MS . STELLA:

THE WITNESS:

BY MR. ROSEN:

defendant ,

promissory note ."

10

A.

I didn ' t know.

Then it says , " On December 20th , 2007

Q.

Objection, legal conclusion.

executed and delivered a


How did you know that was true?

The note.

The date on the note in our

system, the computer report.


Q.

The PULS report shows the date that


allegedly signed the note?

11
12

A.

The origination date, yes .

13

Q.

Okay .

And the same thing for executing the

14

mortgage , is that in PULS as well?

15

all part of the origination date then?

16

A.

I guess that ' s

Yes.

17

MS . STELLA :

Form.

18

BY MR . ROSEN:

19

Q.

I ' m sorry , you have to verbalize your

20

answer .

21

all part of origination; is that right?

The mortgage and the note signature date is

22

MS . STELLA:

Form .

23

BY MR . ROSEN :

24

Q.

You can answer .

25

A.

Yes.

Chapel Hill Reporting, LLC, Servi ng North Carolina


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DEPOSITION OF LONA HUNT


October 17, 2014

48

What does it mean that the mortgage --

Q.

excuse me.

What does it mean securing payment of the

note to JPMorgan Chase Bank , N. A., what does that

mean?

A.

That ' s who had it .

Q.

Okay.

I ' m not for sure.

How did you know that the mortgage

was recorded on January 2nd , 2008 in official records

book 26139 , page 2017?

10

A.

The mortgage.

11

Q.

And how did you know that the property

12

described in the mortgage was owned and in

13

possession

14

possession of it?

or who owned it and who was in

15

A.

Fannie Mae.

16

Q.

How did you know that?

17

MS. STELLA:

18

THE WITNESS :

19

BY MR . ROSEN:

20

Form.
The note .

So, just to clarify ,

Q.

I ' m asking you how did

21

you know who owned and was in possession of the

22

property at the time of -- at the time of

23

origination?

24

A.

Please repeat.

25

Q.

Sure.

"'

I'm asking how did you know who

- -.. . . . .......... ......


..
Chapel Hill Reporting, LLC, Serving North Carolina
(919) 969-1169
..... ;= .~

--

. .. ............

... ~""'"--"""' .0..-.1- - ~- ~--~

~,

- .~--

--~~-

DEPOSITION OF LONA HUNT


October 17, 2014

49
1

owned the property and who possessed the property at

the time of origination?

A.

By the note.

I can't look at the page.

Q.

Let ' s take a look at the note.

It ' s

attached to the complaint, Exhibit B.

me where in the note it says who owned and possesses

the property?

MS . STELLA:

THE WITNESS :

10

13
14
15
16
17

Q.

The back page it ' s telling you who owns the

property?

A.

It says pay to the order of Federal

National Mortgage Association.


Q.

Okay.

What does it mean to be the

mortgagor?
MS. STELLA:

19

BY MR . ROSEN:

21

Q.

Legal conclusion.

You can answer .

If you don ' t

know, you can

tell me.

22

MS. STELLA:

23

THE WITNESS:

24

BY MR. ROSEN:

25

Federal National Mortgage

BY MR . ROSEN :

18

20

Form.

Association , the back page.

11
12

Can you show

Q.

Form .
I ' m not sure .

How did you know that Fannie Mae is the

Chapel Hill Reporting, LLC, Serving North Carolina


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DEPOSITION OF LONA HUNT


October 17, 2014

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1

owner and holder of the note?


A.

2
3

saying that Fannie Mae - - pay to the order of Fannie

Mae in our system.

Q.

5
6

Okay.

What does it mean to be an owner and .

holder of a note?

MS. STELLA:

THE WITNESS:
sure .

Don ' t

Objection , legal conclusion.


I'm not - - I ' m not quite

know.

BY MR. ROSEN:

10

The note where it's stamped at the back

11

Q.

What does it mean to be defaulted?

12

A.

Behind in your payments.

13

Q.

And the screen , the PULS report told you


was defaulted on the note and

14

that

15

mortgage by failing to pay the payment due on

16

January 1, 2010 and all subsequent payments; is that

17

right?

18

A.

Can I turn the page or no?

19

Q.

Yeah.

Thank you so much for asking.

20

Absolutely .

What are you turning the page to?

21

are you looking for?

What

22

A.

23

delinquent .

24

t.~:::~~~:_:_::_a~~~r:~~n:~~:~:~~~~:~~a~:u o::~. I

25

January 1st , 2010 is when it was

Chapel Hill Reporting, LLC, Serving North Carolina


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DEPOSITION OF LONA HUNT


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1

that

I just want to confirm -- how did you know

-- and I believe I know the answer ,

defau l ted on the note and mortgage by failing

to pay the payment due January 1 , 2010 and all

subsequent payments?

A.

The computer report system .

Q.

Okay.

What does it mean in number 8 that

the plaintiff declares the full amount payable on the

note and mortgage to be due?

10

MS . STELLA:

Objection, legal conclusion.

11

BY MR. ROSEN:

12

Q.

Feel free to answer , if you know .

13

A.

I'm not sure.

14

Q.

And in paragraph 9, the amount that

15

plaintiff owes, i s that in your PULS report , the

16

239 , 639.41?

17

A.

Yes .

18

Q.

What does indebtedness has been

19

acce l erated , what does that mean?

20

9 , second sentence there .

21

MS. STELLA:

22

THE WITNESS:

23

BY MR . ROSEN:

24

Q.

It ' s in paragraph

Form.
I ' m not sure.

How did you know the plaintiff is obligated


i

25
to

~~~:":~-~"::=~-a-=::~~:.-~:~_:~ th-~~
Chapel Hill Reporting, LLC, Serving North Carolina
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DEPOSITION OF LONA HUNT


October 17, 2014

52

services?

A.

I don't.

Q.

Sure.

Can you repeat what you mean?

I ' m just asking paragraph 10 , how do

you know that plaintiff is obligated to pay its

attorneys a reasonable fee for their services?

A.

I don't.

Q.

And how do you know the plaintiff is

entitled to recover its attorneys' fees pursuant to

Florida statute and the promissory note?

10

A.

I'm not sure.

11

Q.

What is a deficiency judgment?

In the

12

wherefore clause it says def i ciency judgment .

13

is that?

14

MS. STELLA:

15

THE WITNESS:

16

BY MR. ROSEN :

17

Q.

What

Objection, legal conclusion.


Not sure.

And it says here beneath that , "If borrower

18

has not been discharged in bankruptcy, " what does

19

that mean, borrower has not been discharged in

20

bankruptcy?

21

MS . STELLA:

Objection , legal conclusion.

22

THE WITNESS:

I don ' t see where it says

23

that .

24
25

I don't know .
BY MR. ROSEN :

Q.

On your -- a little further down it says ,

Chapel Hill Reporting, LLC, Serving North Carolina


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DEPOSITION OF LONA HUNT


October 17, 2014

53
1

"Seterus, as servicer for Federal National Mortgage

Association. "

servicer for Federal National Mortgage Association on

this loan?
A.

How do you know that Seterus is the

Seterus services for Fannie Mae.

I ' m not

for sure.

Q.

In this case do you recall if you verified

the first draft that was -- or you signed, rather ,

the first draft that was presented to you?

10

A.

I don ' t know what you mean.

11

Q.

Sure.

So the package would have come in

12

the box and would you have -- in this case did you

13

sign the first one that was presented to you in the

14

package or were there changes made and edits before

15

you signed?

16

A.

So you ' re saying -- I ' m not sure what you

Q.

Sure .

17
18

19

mean .
I ' m asking in this case did you sign

the document as it was presented to you?

20

MS . STELLA:

21

THE WITNESS:

22

25

After verifying the

information .

BY MR . ROSEN:

23

24

Form .

Q.

After doing what you did with the computer

and the papers , right, did you sign the very first

I!
!t
I

I
l

.-I
Chapel Hill Reporting, LLC, Serving North Carolina
(919) 969-1169

DEPOSITION OF LONA HUNT


October 17, 2014

(6"'

54
1

draft that was given to you?

A.

Yes.

Q.

Okay.

What happens if you found an error

in a complaint?

A.

Trashed it.

Q.

Okay.

A.

Yes.

Q.

As far as this process that you testified

9
10

to today , anything else that you ' d like to add?

A.

11
12

Has that ever happened?

No.
MR. ROSEN:

Okay.

I have no further

questions at this time.

13

MS. STELLA:

I'd like to do a brief

14

rehabilitation , but if we can just take a short

15

break .

16
17

MR. ROSEN :

MS. STELLA:

MR. ROSEN:
minutes.

My time is 3 : 23.

So you want

Okay.

See you in seven

Yeah.

22

(Brief recess . )

23

CROSS - EXAMINATION

24
25

How much

to say 3 : 30?

20
21

Be happy to.

time do you need or would you like?

18
19

Sure.

BY MS . STELLA :
Q.

Hi, Lona.

Chapel Hill Reporting, LLC, Serving North Carolina


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DEPOSITION OF LONA HUNT


October 17, 2014

55
1

A.

Hi.

Q.

Can you hear me?

A.

Yes.

Q.

I can ' t hear her .

A.

Oh , I ' m sorry .

6
7

this piece of candy out of my mouth.

Q.

Okay .

BY MS . STELLA :

Q.

While we were on break I heard you say that

11

this was nerve wracking and uncomfortable.

12

you ' re nervous.

13

want to clarify some things that were said and make

14

sure we have accurate responses.

15
16

This is your first time .

I know
So I

just

Do you have a copy of the verified


complaint in front of you?

17

A.

Yes .

18

Q.

Okay.

Now, when you received that

19

complaint , the draft to review for execution , did you

20

read it first?

21

A.

No.

22

Q.

Did you read it as you were going through

23
24

I ' ll give you a minute .


(Discussion off the record . )

9
10

I probably need to take

25

to verify the various facts that are set forth in the

comp::.t~:R~~~~::-.~~j=~~~~:~=~- .--~ _mj


Chapel Hill Reporting, LLC, Serving North Carolina
(919) 969-1169

DEPOSITION OF LONA HUNT


October 17, 2014

56

BY MS. STELLA :

Q.

You can answer.

A.

Yes.

Q.

Okay.

Now, you ' re an employee of Seterus

and Seterus is a servicer of loans?

A.

Yes.

Q.

Okay.

A.

Fannie Mae.

10

Q.

Okay.

11

And who does Seterus service loans

for?

And does Seterus service loans for

anyone other than Fannie Mae?

12

A.

No.

13

Q.

In January of 2012 did Seterus service

A.
16

Q.

They only service loans owned by Fannie

18

A.

Yes.

19

Q.

I didn ' t hear your answer .

20

A.

Yes.

21

Q.

Okay .

17

Mae?

Now, if we look at the complaint

22

there seems to be some confusion between ownership .

23

We're referring to two different types of ownership,

24

the owner of the property, the person who lives in

25

the property - - or owns it I should say and the owner

- I
Chapel Hill Reporting, LLC, Serving North Carolina
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DEPOSITION OF LONA HUNT


October 17, 2014

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57
1

of the loan.

Now, paragraph 6 of the complaint ,

which is on page 2 , says, " Plaintiff is the owner of

the note ."

MR. ROSEN:

Objection , form.

BY MS. STELLA:

Q.

Did you find it?

A.

Okay.

Q.

Okay .

A.

Okay.

10

Q.

Paragraph 6.

11

A.

Okay.

12

Q.

It says , "Plaintiff is the owner. "

13

you verify?

Page 2, okay .

Would you repeat?

I found it now .

14

MR . ROSEN:

15

BY MS. STELLA:

16
17

Q.

How did

Objection, form .

How did you verify that the plaintiff,

Federal National Mortgage Association , was the owner?


A.

18

The back of the note is stamped pay to the

19

order of Fannie Mae and then our system, the computer

20

report system.

21

Q.

Okay.

Now, if we can go one paragraph

22

down

23

Number 2 , that says the property is owned by

24
25

I ' m sorry, let ' s go on to the previous page.

How did you verify that?


A.

~..:o.--

By the note , the mortgage and our system.


............ u. . ...... .

- ....

,,a.a~- .,,._~.

..:--

_,__ __ _ _ _ _

..._n...._~ .. ...

- . . . . - i ; . ..,

4 , . i , . . , , ; . - - - ' - .r-.

l
I

~--.,-------dl

Chapel Hill Reporting, LLC, Serving North Carolina


(919) 969-1169

II

DEPOSITION OF LONA HUNT


October 17, 2014

58
1

Q.

Okay.

A.

Yes.

So the property was owned by

2
3
4

MR. ROSEN:

BY MS. STELLA :
Q.

Objection, form.

And the note was owned by Fannie Mae?

MR. ROSEN:

THE WITNESS:

BY MS. STELLA:

Objection, form.
Yes.

Did you hear?

10

Q.

It was owned by Fannie Mae?

11

A.

Yes.

12

MR. ROSEN:

13

BY MS. STELLA:
Q.

14

Same objection.

And the note was serviced by Seterus?

15

MR. ROSEN:

Objection, form, leading.

16

BY MS. STELLA:
Q.

Who was the servicer of the note or the

19

A.

Servicer would be Seterus.

20

Q.

And who was the owner of the loan?

21

A.

Fannie Mae.

22

Q.

Okay.

17
18

loan?

Now, when you received the complaint

23

did you know whether a notice of intent or NOI had

24

been sent to the borrower?

25

A.

No.

Chapel Hill Reporting, LLC, Serving North Carolina


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DEPOSITION OF LONA HUNT


October 17, 2014

59
Q.

1
2

MR. ROSEN:

THE WITNESS:

BY MS . STELLA:
Q.

Objection, leading.
Can you repeat , please?

The NOI, the notice of intent, prior to you

receiving a complaint for verification , would you

know that the notice of intent or the NOI had been

sent?
MR. ROSEN:

9
10

Did you know that it had been sent?

Objection, asked and answered .

BY MS. STELLA :

11

Q.

You can answer .

12

A.

No.

13

Q.

Before coming to you , before the verified

14

complaint would be brought to you , the NOI would have

15

to have been sent , correct?

16
17

MR . ROSEN:

Objection , leading; calls for

speculation .

18

THE WITNESS :

19

BY MS . STELLA:

20

Q.

Okay.

Yes.

Now , when you were verifying

21

complaints in January of 2012 , were you supervised by

22

anyone?

23

A.

Yes .

24

Q.

And if

25

you testified before that if

there was a problem you would trash it and if you had


Chapel Hill Reporting, LLC, Serving North Carolina
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DEPOSITION OF LONA HUNT


October 17, 2014

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1

a question, if you were unsure of something , was

there anyone else you could go to to verify , any

other outlets to make sure the information was

correct?

A.

Yes.

Q.

Okay .

A.

That would have been Richard Adams.

Q.

And what if Richard was unable to answer

And who was that?

the question?

10

A.

He would call somebody in Beaverton .

11

Q.

Okay.

12
13

Would you ever just sign the note

without -- without knowing the facts were correct?


A.

No .

14

MR. ROSEN:

15

BY MS. STELLA:

16

Q.

Objection , leading.

And were the facts contained in the

17

complaint, this specific complaint of Fannie Mae

18

versus

19

January 10th , 2012 were the facts true and correct to

20

the best of your knowledge and belief?

21

when you signed your name on

A.

Yes.

22

MR. ROSEN :

23

MS. STELLA:

24

MR. ROSEN:

25

Objection, leading .
No further questions.
Okay.

quick brief redirect .

I may have just one

I'm just going to put you IJ

. . . . . . ~; . .,,_--"-------.. . .,. . . . . ...-.. --~-....~. _.._,. ~. ., _,_. .__.. _~-~---. --~~~-~-~~Jj


Chapel Hill Reporting, LLC, Serving North Carolina
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DEPOSITION OF LONA HUNT


October 17, 2014

61
1
2

guys on hold for one second , okay.


MS. STELLA:

(Pause . )

3
4

Okay .

MR. ROSEN :

So I have no further questions .

I just want to inform you pursuant to Florida

Rules of Civil Procedure you have the right to

read the deposition transcript , Ms. Hunt , and

you would then fill out what ' s called an errata

sheet if there ' s anything that you would like to

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make changes to.

The errata sheet would then be

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attached to the deposition .

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deposition for those purposes or you can waive

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that right to read.

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MS. STELLA:

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MR . ROSEN:

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MS . STELLA:

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MR . ROSEN:

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She's going to read .

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no other questions .

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deposition .

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You can read the

She ' ll read.


The choice is
She ' s going to read .
Okay.

Very good .

That's it .

That ' s fine.

And I have

That concludes the

(Continued on the following page . )

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Chapel Hill Reporting, LLC, Serving North Carolina
(919) 969-1 1 69

DEPOSITION OF LONA HUNT


October 17, 2014

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{Whereupon, at 3 : 40 p.m., the deposition in


the above - entitled matter ceased . )

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LONA HUNT

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SUBSCRIBED AND SWORN to before me this


day of

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NOTARY PUBLIC

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My Commission Expires :

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Chapel Hill Reporting, LLC, Serving North Carolina
(919) 969 - 1169

DEPOSITION OF LONA HUNT


October 17, 2014

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RPTR:

MMF

DATE:

October 17, 2014

T R A N S C R I P T I 0 N

C 0 R R E C T I 0 N S

CASE NAME: FEDERAL NATIONAL MORTGAGE vs.

WITNESS NAME :

CASE NO . :

LONA HUNT

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PAGE

LINE

READS

SHOULD READ

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("'

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Chapel Hill Reporting, LLC, Serving North Carolina
(919) 969-1169

DEPOSITION OF LONA HUNT


October 17, 2014

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CERTIFICATE OF REPORTER

STATE OF NORTH CAROLINA

COUNTY OF WAKE

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I, Maren M. Fawcett, RPR, the officer before

whom the foregoing deposition was taken, do hereby

certify that the witness whose testimony appears in

the foregoing deposition was duly sworn by me; that

the testimony of said witness was taken by me to the

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best of my ability and thereafter reduced to

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typewriting under my direction; that I am neither

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counsel for, related to, nor employed by any of the

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parties to the action in which this deposition was

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taken, and further that I am not a relative or

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employee of any attorney or counsel employed by the

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parties thereto, nor financially or otherwise

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interested in the outcome of the action.

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This the 28th day of October, 2014.

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MAREN M. FAWCETT, RPR

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Notary Public in and for

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County of Wake

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State of North Carolina

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Notary Public No. 200621500068


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..=.,._.......-,,.,.4r..... ..... __... --~--------..------ _ . _ _____ _... _.,........... -.;..,,; .. ______ ____IJ

Chapel Hill Report i ng, LLC, Serving North Carolina


(919) 969-1169