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Trial Preliminary Matters:

1. All parties have been properly served.


2. The original note, mortgage and assignment of mortgage have been filed with the court.
If you can proceed to damages:
Witness
Please state your name for the record.
Who is your employer?
Whats your position with Ocwen?
What in are your duties in that role?
What is Ocwens relationship to the Plaintiff?
Are you familiar with Ocwens business practices, processes and procedures as it pertains to the
origination and servicing of mortgages?
Are you familiar with Ocwens business practices, processes and procedures as it pertains to the creation,
maintenance and storage of documents relating to the origination and servicing of mortgage loans?
Are the records/entries made into the system made at or near the time of the transaction for the account
that they reflect?
Are the entries made by a person with knowledge of the transaction?
Do you utilize these systems as part of your regular job duties?
Are you familiar with the business records of your employer for the loan related to Defendants loan?
Did you have an opportunity to review the business records related to the Defendants loan prior to
coming to trial today?
Is the testimony you are about to give your personal knowledge of your own business records?
Amounts due and owing
Let the record reflect that I am handing the witness a copy of the Final Judgment of Foreclosure.
Did you have an opportunity to review proposed Final Judgment?
Did you review the Final Judgment against your business records for accuracy?
Based on your review of the business records associated with Defendants loan, are the amounts due and
owing in the Proposed Final Judgment accurate and consistent with the amount due and owing for your
records?
Your honor, at this time Plaintiffs rests and asks that judgment be entered on behalf.

If you need to go through everything:


Note
Plaintiff asks that the Court take Judicial Notice of the Original Note filed with the Court on 01/21/08.
I am handing the witness a copy of the Original Note previously filed with this Court.
What is the date on the Note?
Who is the original lender on the note?
What is the value of the Note?
Who executed the Note?
Mortgage
Plaintiff asks that the Court take Judicial Notice of the Original Mortgage filed with the Court on
01/21/08?
I am handing the witness a copy of Original Mortgage previously filed with this Court.
What is the date on the Mortgage?

Who is the Lender on the Mortgage?


What is the property address on the Mortgage?
What is the value of the mortgage?
Who executed the Mortgage?
Payment History
Let the record reflect that I am handing the witness a copy of Plaintiffs exhibit 1 for identification?
Are you familiar with Plaintiffs Exhibit 1 for identification?
Please identify this document for the Court?
Is this document prepared or maintained in the ordinary scope of your employers business?
Is it a regular part of your companys business to keep and maintain records of this type?
Is this the type of document that would be kept under your custody and control?
What does this document reflect?
Did you review this document to ensure that the information was accurate?
Based on your review is this loan in default?
YOUR HONOR, AT THIS TIME I OFFER PLAINTIFFs EXHIBIT 1 FOR I
DENTIFICATION INTO EVIDENCE AS PLAINTIFFs EXHIBIT 1
Breach Letter
Let the record reflect that I am handing the witness a copy of Plaintiffs exhibit 2 for identification?
Are you familiar with Plaintiffs Exhibit 2 for identification?
Please identify this document for the Court?
Is this document prepared or maintained in the ordinary scope of your employers business?
Is it a regular part of your companys business to keep and maintain records of this type?
Where are document of this type stored after they are prepared or received?
Is this the type of document that would be kept under your custody and control?
To whom was this letter sent?
To what address was this letter sent?
What does this letter reflect?
Based upon your review of the business records associated with the Defendants loan was this letter ever
returned as undeliverable?
Did you receive any correspondence from Defendants notifying you of a change in address?
Based upon your review of the records relating to the subject loan, was a payment ever received that
would be sufficient to cure the default?
YOUR HONOR, AT THIS TIME I OFFER PLAINTIFFs EXHIBIT 2 FOR
IDENTIFICATION INTO EVIDENCE AS PLAINTIFFs EXHIBIT 2
Amounts due and owing
Let the record reflect that I am handing the witness a copy of the Final Judgment of Foreclosure
Did you have an opportunity to review proposed Final Judgment?
Did you review the Final Judgment against your business records for accuracy?
Based on your review of the business records associated with Defendants loan, what is the current
principal amount of the loan?
Based on your review of the business records associated with Defendants loan, what is the amount of
interest due through today?
Did Plaintiff advance any costs or payments on behalf of the mortgage?
Did you advance hazard insurance premiums?
What amount did you advance for hazard insurance?
Did you advance property taxes?
What amount did you advance for property taxes?
Did you spend any money to preserve the property?

Excluding the attorneys fees and costs, what is the total amount of damages you are seeking today?
Did you hire QPWB to represent you in this foreclosure action?
Did you agree to pay QPWB its reasonable attorneys fee in connection with that representation?
Your honor I ask that judgment be entered on behalf of the Plaintiff in the amount of $ 195,183.84 which
is inclusive of $2,920.00 of attorneys fees.