-1

-
Joseph Zernik
1853 Foothill Blvd
LV, CA 91750
Tel: (310) 435 9107
Fax: (801) 998 0917
jz12345@earthlink.net
Pro Se Petitioner
UNITED STATES COURT
DISTRICT OF COLUMBIA
JOSEPH H ZERNIK
Petitioner
vs
KENNETH MELSON ET AL
Respondants

CASE No 1:09-cv-00805



VERIFIED NOTICE #7: NOTICE #3 – EXHIBITS VOLUME A
FILED WITH THE COURT OF THE HONORABLE JEFF BOHME, U.S.
JUDGE, TX
PETITIONER FILES HEREBY NOTICE OF THE FOLLOWING RECORD:
NOTICE #3 – EXHIBITS VOLUME A FILED WITH THE COURT OF THE
HONORABLE JEFF BOHM, U.S. JUDGE, TX.



Dated: May 18, 2009 Respectfully submitted, by:





______________________
JOSEPH H ZERNIK
PRO SE PETITIONER
VOLUME A 1/210
Digitally signed by Joseph
Zernik
DN: cn=Joseph Zernik,
email=jz12345@earthlink.
net, c=US
Date: 2009.05.18 16:33:37
-07'00'

-2-


Joseph Zernik
1853 Foothill Blvd
LV, CA 91750
Tel: (310) 435 9107
Fax: (801) 998 0917
jz12345@earthlink.net
Pro Se Interested Party
UNITED STATES COURT
WESTERN DISTRICT OF PENNSYLVANIA
SHARON DIANE HILL
Borrower
CASE No 01-22574



VERIFIED NOTICE #7: NOTICE #3 – EXHIBITS VOLUME A
FILED WITH THE COURT OF THE HONORABLE JEFF BOHME, U.S.
JUDGE, TX
PETITIONER FILES HEREBY NOTICE OF THE FOLLOWING RECORD:
NOTICE #3 – EXHIBITS VOLUME A FILED WITH THE COURT OF THE HONORABLE
JEFF BOHM, U.S. JUDGE, TX.

Dated: May 18, 2009 Respectfully submitted, by:




______________________
JOSEPH H ZERNIK
PRO SE INTERESTED PARTY
VOLUME A 2/210

-3-




PRO SE PETITIONER in Zernik v Melson et al, U.S. Court, District of Columbia,
who is also Interested Party, case of Borrower Parsley, U.S. Court, Southern District of
Texas, and who is also requesting designation as Interested Party in case of Borrower
Hill, U.S. Court, Western District of Pennsylvania, hereby files
1
Notice #7, which is
Notice #3 Exhibits Volume A filed in the Texas Court of the Honorable Jeff Bohm,
U.,S. Judge.
///
I.
TABLE OF CONTENTS
Alternative Cover Pages …………………………… 1-3
I. TOC …………………………… 4
II. List of Exhibits …….………..…………… 5
III. Request for Lenience by Pro Se Filer …………………………… 5
IV. Significance of the Records Noticed Herein …….………..……………. 6
V. Statement of Verification …….………..……………. 7
VI. Exhibits …….………..……………. 8
///

1
Copy is concomitantly filed with TARP Oversight Board, and with TARP Inspector General, as
a request for urgent investigation into matters related to TARP and the Bailout.
Copy is concurrently filed with Lawrence Summer, Director, U.S. President National Economic
Council
Copy is concurrently filed with Paul Volker, Chairman, U.S. President Economic Recovery
Advisory Board, as request for investigation of the allegation that widespread corruption in LA
County, California, involving Countrywide, gave rise, at least in part, to the sub-prime crisis.
Copy is concurrently filed with Carol E. Dinkins., Chairwoman, U.S. President Privacy and Civil
Liberties Advisory Board, as a request for investigation of alleged widespread corruption and
civil rights and human rights violation of historic proportions in LA County, California.
Copies are concomitantly filed with U.S. Congress, as a request for urgent hearings on
underlying matters.
Copy is concomitantly filed with the Israeli Embassy in Washington DC, with request for
monitoring and protection of the rights of dual citizen, Joseph Zernik, per Universal Declaration
of Human Rights, ratified International Law.
VOLUME A 3/210

-4-

///



II.
LIST OF EXHIBITS IN CURRENT NOTICE
EXHIBIT 1. 09-05-08-NOTICE #3, EXHIBITS VOLUME A FILED IN THE COURT OF
THE HONORABLE JEFF BOHM, U.S. JUDGE, TX.
III.
REQUEST FOR LENIENCE BY PRO SE FILER
While I make substantial efforts to comply with court procedures, and study
applicable law, I request special lenience as a pro se filer:
A document filed pro se is “to be liberally construed,” Estelle, 429 U. S.,
at 106, and “a pro se complaint, however inartfully pleaded, must be held
to less stringent standards than formal pleadings drafted by lawyers,”
ibid. (internal quotation marks omitted). Cf. Fed. Rule Civ. Proc. 8(f) (“All
pleadings shall be so construed as to do substantial justice”). (Erickson
v Pardus et al, 2007)
In particular, I am unqualified in assessing the validity of legal theories. I ask the
Honorable Court to ignore any irrelevant or erroneous legal theory I claim, and do take
into consideration the facts and the claims themselves, and if they can support some
other valid theory, assign such legal theory to them, and review them pursuant to such
valid legal theory (Haddock v Cal Board of Dental Examiner, 1985).
The Honorable Court is requested to entirely disregard my comments,
explanations, or legal arguments pertaining to such papers, when my writings appear to
be of the nature of legal theories, or legal arguments, and are deemed erroneous, or
irrelevant.
If it pleases the Honorable Court, let the Honorable Court act of its own volition
whenever permitted to do so by law:
a. To initiate action pursuant to the Code of Conduct of U.S. Judges, Canon
VOLUME A 4/210

-5-

3B(3):
(3) A judge should initiate appropriate action when the judge
becomes aware of reliable evidence indicating the likelihood of
unprofessional conduct by a judge or a lawyer.
b. To act pursuant to Fed. Rule Civ. Proc. 8(f) “to do substantial justice” for
Plaintiffs who claim to have been inflicted substantial harms by the Los
Angeles justice system.
Dated: May 18, 2009 Respectfully submitted, by:



________________________
JOSEPH H ZERNIK
PRO SE PETITIONER
IV.
SIGNIFICANCE OF RECORDS NOTICED HEREIN
This notice provides more detailed evidence of the alleged frauds perpetrated by Countrywide,
and later – Bank of America. While this notice, #7, EXHIBITS VOLUME A is only the
peripheral evidence for the frauds, it provides the framework, and Volume B – which is the
group of 6 Key Records, which Petitioner alleges to be the essence of the fraud, and which Mr
Mozilo, Mr Samuels, Mr Lewis, and Mr Mayopoulos would not answer on, while making any
possible effort to harass, intimidate, and retaliate. A reasonable person would consider the
evidence overwhelming, yet FBI and USDOJ – for two years refused to provide me protection,
and allow such frauds to go on.
Dated: May 18, 2009 Respectfully submitted, by:





BY:_________________
JOSEPH H ZERNIK
VOLUME A 5/210

-6-

PRO SE PETITIONER
Joseph Zernik
1853 Foothill Blvd
LV, CA 91750
Tel: (310) 435 9107
Fax: (801) 998 0917
jz12345@earthlink.net
V.
STATEMENT OF VERIFICATAION

I, Joseph H Zernik, have written and re-read the foregoing:
VERIFIED NOTICE #7: NOTICE #3 EXHIBITS VOLUME A, FILED WITH THE
HONORABLE JEFF BOHM, U.S. JUDGE, TX.
I know the content thereof to be true and correct. It is true and correct based on
my own personal knowledge, except as to those matters therein stated as based upon
information and belief, and as to those matters, I believe them to be true and correct as
well.
I make this declaration that the foregoing is true and correct under penalty of
perjury pursuant to the laws of the United States.
Executed here in La Verne, County of Los Angeles on this 18
th
day in May, 2009.






_____________________
JOSEPH ZERNIK
pro se Plaintiff
VOLUME A 6/210

-7-


VI.
EXHIBITS




































VOLUME A 7/210

-8-





































EXHIBIT 1
VOLUME A 8/210
Case 05-90374 Document 259 Filed in TXSB on 05/08/09 Page 1 of 35
Date:
2009.04.15
0&36:12 -07'00'
UNITED STATES COURTS)
SOUTHERN D1ST,'ICT OF TEXAS
FIL,l:O
MAY 0 8 LU09
UNITED STATES BANKRUPTCY COURT
HOUSTON, TEXAS 9
1 Joseph Zernik, in pro se
PO Box 526
2 La Verne, CA 91750
3 Tel: (310) 435 9107
Fax: (801) 9980917
4 Email: j Z12345@earthlink.net
5
6
7
8
10 WILLIAMALLENPARSLEY
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
Borrower
CASE #: 05-903-74
VERIFIED NOTICE #3 TO HONJEFF
BOHM, PURSUANT TO MEMO, DOC
#248, MARCH 5, 2008, STATING:
"the court will continue to verify that its
trust is well-placed."
VOLUME A
LETfERS, EMAIL NOTES & MISC.
KEY RECORDS, PART OF INARTFUL
FILING - AS EVIDENCE OF ALLEGED
WRONGDOING BYCOUNTRYWIDE,
BRYAN CAVE, LLP, AND OTHERS.
IF IT PLEASES THE COURT, LET THE
COURTACT OF ITS OWNVOLITION
"TO DO SUBSTANTIAL JUSTICE"
FULL DISCLOSURE OF THE
ALLEGED CONDUCT DETAILED
HEREIN IS OF HIGH PUBLIC POll
SIGNIFICANCE RELATIVE TO THE
TRUE NATURE OF THE SUB-PRIME
SCANDALAND BAILOUT.
April 12, 2009; NOTICE #2, RE: CFC/BAC
William Allen Parsley, Borrower
Case # 05-90374
Exhibits Volume A
Letters, Email Notes & Mise
A -1
VOLUME A 9/210
Case 05-90374 Document 259 Filed in TXSB on 05/08/09 Page 2 of 35
2
3
4
5
6
7
VQLUMEA.
Letters, Email Notes &Miscellenaous
TABLE OF EXHIBITS
(in chronological order)
8 A(l)a September 7, 2004 Niuie Samaan's Prequalification Letter
9
10 h«p:/linproperinla.com/04-09-07-samaan-s-pregualification-Ietter. pdf
A-5
11 A(l)b In re: September 7, 2004 Nivie Samaan's Prequalification Letter
12 - Fraud Expert/Record Examiner report A-8
13 h«p:1linproperinla.com/04-09-07-opinion-Ie«er-fraud-in-prequalificaion-Ietter-s.pdf
14 A(2) July 10, 2006 Samaan's Deposition
A-25
15 h«p:/linproperinla.com/06-07-1 O-samaan-deposition.pdf
16 A(3) March 16, 2007my Meet & Confer Letter
17 h«p:/linproperinla.com/07-03-16-Countrywide-meet-&-confer-s.pdf
18 A(4) June 23, 2007my Letters to Mozilo & Samuels
................. A-55
A-63
19
20
21
22
23
24
25
26
27
28
h«p:/linproperinla.com/07-07-03-moldawsky-notice-of-ex-parte-gag-order.pdf
A(S) July 3, 2007Att Jenna Moldawsky, Bryan Cave, LLP, Letter
................. A-lll
htlp:/linproperinla.com/07-D7-03-moldawsky-notice-of-ex-parte-gag-order.pdf
A(6) July 11, 2007 Countrywide Legal Department Att Todd Boock
Decl(lration ................• A-1l4
h«p:llinproperinla.com/07-07-11-countrywide-boock-declaration-for-motion-july-23-2007-for-protective-gag-order-
s.pdf
A(7) October 22, 2007Att Moldawsky, Bryan Cave, LLP, Email Note
.......••••..•..• A-120
h«p:/linproperinla.com/07-1 0-22-brvan-cave-moldawsky-on-appearance-entirely-proper-s.pdf
April 12, 2009; NOTICE #2, RE: CFC/BAC
William Allen Parsley, Borrower
Case # 05-90374
VOLUME A 10/210
Case 05-90374 Document 259 Filed in TXSB on 05/08/09 Page 3 of 35
2
3
~ ' ( 8 ) October, 2007- Att John Amberg, Bryan Cave, LLP, Email note
.••••••••.•.•..•• A-122
http://inproperinla.com/07-1 0-02-bryan-berg-att-amberg-decline-to-get-further-involved-s.pdf
4 ,i A(9) In re: November-December 2007Att David Pasternak's Grant
Deeds - Fraud Expert/Document Examiner report
...............~ .. A-128
http://inproperinla.com/07-12-17-wedick.memo.notarized.deeds.zernik.2009.02.0S-s.pdf
http://inproperinla.com/07-12-17-grant-deeds-wedick-s-opinion-s. pdf
January 27, 2008 Table: Countrywide's Party Designations
............. A-157
httpJlinproperinla.com/08-01-27-countrvwide-in-samaan-v-zernik-s.pdf
';(l1)February 4,2008, my letter to Kenneth Lewis III, President, BAC,
& February 12, 2008 responsefrom Lewis's office ......• A-163
http://inproperinla.com/08-02-04-letter-to-officers-of-bac-re-countrywide-s.pdf
http://inproperinla.com/08-02-12-bac-lewis-response-from-office-of-chair-to-Ietter-re-countrywide-s.pdf
{12) December 9, 2008 Countrywide, Legal Department, Att Todd
Boock, Email note A-167
http://inproperinla.com/08-12-09-countrywide-todd-boock-refusal-to-respond-december-2008-lo-march-2009-
s.pdf
! J/:l)California State Bar - Rules ofProfessional Conduct
................. A-179
http://inproperinla.com/og-04-13-california-state-bar-rules professional-conduct-s.pdf
25
26
27
April 12, 2009; NOTICE #2, RE: CFC/BAC
William Allen Parsley, Borrower
Case # 05-90374
VOLUME A 11/210
Case 05-90374 Document 259 Filed in TXSB on 05/08/09 Page 4 of 35
TO THE CLERK OF THE COURT:
Three documents with individual face pages are submitted in four copies each, for filing
in the court, in a total of five priority mail boxes.
Respectfully Submitted,
April 16, 2009, La Verne, California
Joseph Zernik
III pro se
VOLUME A 12/210
Case 05-90374 Document 259 Filed in TXSB on 05/08/09 Page 5 of 35
2
3
4
5
6
7
8
9
10
11
12
l ~
14
I r
1r
II
i;
18
19
20
21
22
23
24
25
26
27
28 Exhibits
April 12, 2009; NOTICE #2, RE: CFC/BAC
William Allen Parsley, Borrower
Case # 05-90374
Exhibits Volume A
Letters, Email Notes & Mise
A-4
VOLUME A 13/210
Case 05-90374 Document 259 Filed in TXSB on 05/08/09 Page 6 of 35
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
Exhibit A(l)
27
28
April 12, 2009; NOTICE #2, RE: CFC/BAC
William Allen Parsley, Borrower
Case # 05-90374
EXhibits Volume A
Letters, Email Notes & Mise
A-5
VOLUME A 14/210
Case 05-90374 Document 259 Filed in TXSB on 05/08/09 Page 7 of 35
Hello Mr, Ubow:
Ms, S"<lmaanhasbeert an 8011 011 0. JumpqfJl1 4:315%
and a 4;5%Interest Only zromortgage. She has excellent Fico).
ratios and over $200.,OOOil1 venned liquefiable assets,
p.l
!:I3)lNVS' 113N,Q1C:J :;,e IN3S
SOf! 271 78.. S
MbInDer uI' ....9....; 2
(,nC!tJdIl>;jWllllr)
o Please Rcvievw
PMC 0405:12p
Respectfully,
Victor Parks
C V(gel'!t
September 7, 2004
CornllMl'lts: Nivie S(imaan Prequalffieation Letter
From: Victor Parks
1'0: MicMellibow
VICtor Parks
..
Fax
Pacific Mortgage Consultants
.. Fax Cover
VOLUME A 15/210
Case 05-90374 Document 259 Filed in TXSB on 05/08/09 Page 8 of 35
p.2
Pndfi-c MQ."t7J9(:
11275

':&*!} :):.-w::
:>7 .... lf::l+.S t=.".,y."
vr:·. !+t:i ':V:i ().,
271 7845
I Im.k 11\ with you to :t c!osopf l,;Sl;row. $f'NI!l{ yOtl dcsircadditiM,11
pk;I"Ctcl,;l frl,)C.l(1 Cl}lltilcl 575·5693.
Vkit" I';lrks
I,M,' COI1.'Ultallt
My tcam:mdJ arc ltl giving .. and product anywhcrc!Wc.im:
<:qlllic.lcl\{ thtll ym,willl"ind ,Jur 'o.IW' (J( NjI"Vicc and t:t)lllll\;II\\.. ttl Il<>HI:!
'11':lI1k ytW lhr lIn; ttl l'l,lI'W >'0". OUI' "me': 1l;J"; t";"'I;WiX! yo\lr itlClII'rl\!.
credit.. and fundS. am. that you've hoxn prc-quolili<.'dlo
home with 8()/H1lI 0 ill wtittcl1vcrification
mlc.ll'illl am)!'!.""••l
1)(.::lr Nivic:
Nivlc Samalm

l.os AngcllOs. C/\ 900J5
04 12p
VOLUME A 16/210
Case 05-90374 Document 259 Filed in TXSB on 05/08/09 Page 9 of 35
Powered By Pitney Bowes Page 1of 1
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Cut on dotted line
Instructions Online Label Record
Delivery Confirmation Number:
42090027910112888230 0388948641
Print Date: 08/19/08 (GMT) Ship Date: 08119/08
Priority Mail Postage: $4.75
Electronic Option Delivery Confirmation Fee: NONE
Flat Rate Envelope: Yes
From: Forgery Finders, LLC
120 N. Mill Creek Rd.
Noblesville IN 46062
To: JOSEPH ZERNIK
2415 Saint George
LOS ANGELES CA 90027
1. Adhere the shipping label to the package. A self-
adhesive label is recommended. If tape or glue is
used, DO NOT TAPE OVER SARCODE. Se sure all
edges are secure.
2. Place the label so it does not wrap around the edge of
the paCkage.
3. Photocopying or other counterfeiting of US Postage is
punishable by fine or imprisonment. 18 U.S.C. Section
501.
4. Please use this shipping label on the ship dale
selected when you requested the label.
5. For information on pickup options. go to the USPS
Pickup page at .
http://www.usps.com/pickup/welcome.htm.
Shipping label technology provided by Pitney Bowes, Inc.
Exhibits Volume A
Email NQies & Mise
https:/libdswebpl-ext.pb.com/imageslUSPSIHTMLFoldersIHTML151f9c!f.'/JtP7i-aIJ31J-4n... 8/19/2008
VOLUME A 17/210
Case 05-90374 Document 259 Filed in TXSB on 05/08/09 Page 10 of 35
August 19, 2008
Joseph Zemik DMD Phd
2415 Saint George St.
Los Feliz, CA 90027
Dear Mr. Zernik,
Enclosed is our professional opinion concerning the authenticity of the documents that
you fumished to us. We are identifying these as Case 2 and Case 3.
We are including a copy ofthe submitted documents, together with the professional
opinions of Robert Meister and Scott Meister.
Additionally, we are including the CV from each of us.
We appreciate this opportunity to perform our analysis and provide you with our written
opinion.
If you should have any further questions or concerns, please do not hesitate to call me at,
(317) 443 -1616
Sincerely,
Robert Meister, FDE
Enclosures
Exhibits Volume A
Letters, Email Notes & Mise
A-9
VOLUME A 18/210
Case 05-90374 Document 259 Filed in TXSB on 05/08/09 Page 11 of 35
Robert A. Meister
Certified Document Examiner
120 N. Mill Creek Road, Noblesville, IN 46062
Office: 317.770.1000· Fall.: 800.786.2629
Email:experts@forgeryfinders.com
www..J:Otg(!tyJ:indets.com
Questioned Document Examiner Letter
Questioned Signature of Victor Parks - Case 2
Date: August 19,2008
I have examined three ·(3) submitted signatures. One signature, the questioned signature of
Victor Parks, found on the PRE-QUALIFICATION LETTER dated September 7, 2004
identified herein as "Ql." Two (2) :signatures were presented as "known signatures" of Victor
Parks. The first "known signature" found on the SUPPLEMENTAL DECLARATION OF
VICTOR PARKS executed on November 6, 2006 is identified herein as "Kl." The second
"known signature" found on the DECLARATION OF VICTOR PARKS executed on October 27,
2006 is identified herein as "K2." These "known signatures" were used to determine the
authenticity with the "Q1" signature. For the purpose of this examination, a comparison was
made between "Ql" and the aforementioned "known signatures."
Today I have compared the "known signatures" of Victor Parks to the questioned signature of
Victor Parks "Q1," to determine the authenticity of the questioned signature.
The signatures provided for this examination were viewed side-by-side and enlarged at multiple
scales by the use of a computer to aid the examination and comparison process. Common
features of the "known signatures" were compared to the questioned signature. Additionally,
unusual features of "Q1" were compared to the "known signatures."
Based upon thorough analysis of these items, and from an application of accepted forensic
document examination tools, principles and techniques, it is my professional expert opinion that
a different person authored the name of Victor Parks on "QI." The author of the known Victor
Parks signatures is not the author of the Victor Parks signature on the questioned document,
"QL"
I am willing to testify to thisfact in a court of law.
Respectfully submitted,
~ ~
Robert A Meister
SWORN BEFORE ME on this' 19
th
day of August, 2008
Robert A. Meister did appear before me.
STATE OF INDIANA
COUNTY OF HAMILTON
ary Public'-' State ofI ana
My Commission Expires I ~ , la,,;}pI(}
Exhibits Volume A
Letters, Email Notes & Mise
A -10
VOLUME A 19/210
Case 05-90374 Document 259 Filed in TXSB on 05/08/09 Page 12 of 35
Scott R. Meister
Certified Questioned Document Examiner
120 N. Mill Creek Road, Noblesville, IN 46062
Office: 317.770.1000 Fax: 800.786.2629
Email:scott@forgeryfinders.com
www.r:OtgQtyl="indQts.com
Questioned Signatures of Victor Parks - Case 2
Date: August 15,2008
I have examined three (3) submitted signatures. One signature, the questioned signature of Victor
Parks, found on the PRE-QUALIFICATION LETTER dated September 7,2004 identified herein as
"QI." Two (2) signatures were presented as "known signatures" of Victor Parks. The first "known
signature" found on the SUPPLEMENTAL DECLARATION OF VICTOR PARKS executed on
November 6, 2006 is identified herein as "KL" The second "known signature" found on the
DECLARATION OF VICTOR PARKS executed on October 27, 2006 is identified herein as "K2."
These «known signatures" were used to determine the authenticity with the "Q1" signature. For the
purpose of this examination, a comparison was made between "Q1" and the aforementioned
"known signatures."
Today I have compared the "known signatures" of Victor Parks to the questioned signature of
Victor Parks "Ql," to determine the authenticity ofthe questioned signature.
The signatures provided for this examination were viewed side-by-side and enlarged at multiple
scales by the use of a computer to aid the examination and comparison process. Common features
of the "known signatures" were compared to the questioned signature. Additionally, unusual
features of"Ql" were compared to the "known signatures."
Based upon thorough analysis of these items, and from an application of accepted forensic
document examination tools, principles and techniques, it is my professional expert opinion that a
different person authored the name of Victor Parks on "Ql." The author ofthe known Victor Parks
signatures is not the author ofthe Victor Parks signature on the questioned document, "QI."
I am willing to testify to this fact in a court of law and 1 will prove to the Court that my opinion is
correct.
Respectfully submitted,
l _
Scott R. Meister
SWORN BEFORE MEon this 15
th
day of August, 2008
Scott R. Meister did appear before me.
STATE OF INDIANA
COUNTY OF HAMILTON
Exhibits Volume A
Letters, Email Notes & Mise
A -11
VOLUME A 20/210
Case 05-90374 Document 259 Filed in TXSB on 05/08/09 Page 13 of 35
Scott R. Meister
Certified Questioned Document Examiner
120 N. Mill Creek Road, Noblesville, IN 46062
Office: 317.770.1000 Fax: 800.786.2629
Email:scott@forgeryfinders.com
WWW.I=OtgQtyJ:ihdQts.com
Questioned Signatures of Victor Parks - Case 3
D a t ~ : August 15, 2008
I have examined four (4) submitted signatures.. Two signatures, questioned signatures of Victor
Parks, found on the UNIFORM RESIDENTIAL LOAN' APPLICATION (for the amount of
1,374,400) dated September 7, 2004 identified herein as "QI" and on the UNIFORM
RESIDENTIAL LOAN APPLICATION (for the amount of 171,800) dated September 7, 2004
identified herein as "Q2." Two (2)' signatures were presented as "known signatures" of Victor
Parks. The first "known signature" found on the SUPPLEMENTAL DECLARATION OF
VICTOR PARKS executed on November 6, 2006 is identified herein as "Kl." The second "known
signature" found on the DECLARATION OF VICTOR PARKS executed on October 27, 2006 is
identified herein as "K2." These "known signatures" were used to determine the authenticity with
the "Q1" and "Q2" signatures. For the purpose of this examination, a comparison was made
between "Q1" and "Q2" and the aforementioned "known signatures."
Today I have compared the "known signatures" of Victor Parks to the questioned signatures of
Victor Parks "QI" and "Q2," to determine the authenticity of the questioned signatures.
The signatures provided for this examination were viewed side-by-side and enlarged at multiple
scales by the use of a computer to aid the examination and comparison process. Common features
of the "known signatures" were compared to the questioned signatures. Additionally, unusual
features of"QI" and HQ2" were compared to the "known signatures."
Based upon thorough analysis of these items, and from an application of accepted forensic
document examination tools, principles and techniques, it is my professional expert opinion that a
different person authored the name of Victor Parks on "Ql" and HQ2.. " The author of the known
Victor Parks signatures is not the author of the Victor Parks signatures on the questioned documents,
"Q1" and "Q2."
I am willing to testifY to this fact in a court of law and I will prove to the Court that my opinion is
correct.
Respectfully submitted,
~ 1 f 2. Me:Jter
Scott R. Meister
SWORN BEFORE ME on this 15
th
day ofAugust, 2008
Scott R. Meister did appear before me.
STATE OF INDIANA
COUNTY OF HAMILTON
Exhibits Volume A
Letters, Email Notes & Mise
A -12
VOLUME A 21/210
Case 05-90374 Document 259 Filed in TXSB on 05/08/09 Page 14 of 35
,........-
Robert A. Meister
Certified Document Examiner
120 N. Mill Creek Road, Noblesville, IN 46062
Office: 317.770.1000 *' Fax: 800.786.2629
Emai1:experts@forgeryfinders.com
www.J:.otgetyl=il1dets.com
Questioned Document Examiner Letter
Questioned Signature of Victor Parks - Case 3
Date: August 19,2008
I have examined four (4) submitted signatures. Two signatures, questioned signatures of Victor
Parks, found on the UNIFORM RESIDENTIAL LOAN APPLICATION (for the amount of
1,374,400) dated September 7, 2Q04 identified herein as "Ql" and on the UNIFORM
RESIDENTIAL LOAN APPLICATION (for the amount of 171,800) dated September 7, 2004
identified herein as "Q2:' Two (2) signatures were presented as "known signatures" of Victor
Parks. The first "known signature" found on the SUPPLEMENTAL DECLARATION OF
VICTOR PARKS executed on November 6, 2006 is identified herein as "Kl." The second
"known signature" found on the DECLARATION OF VICTOR PARKS executed on October 27,
2006 is identified herein as "K2." These "known signatures" were used to determine the
authenticity with the "Ql" and "Q2" signatures. For the purpose of this examination, a
comparison was made between "QI" and "Q2" and the aforementioned "known signatures."
Today I have compared the "known signatures" of Victor Parks to the questioned signatures of
Victor Parks "Ql" and "Q2," to determine the authenticity of the questioned signatures
The signatures provided for this examination were viewed side-by-side and enlarged at multiple
scales by the use of a computer to aid the examination and comparison process. Common
features of the "known signatures" were compared to the questioned signatures. Additionally,
unusual features of "QI" and "Q2" were compared to the "known signatures."
Based upon thorough analysis of these items, and from an application of accepted forensic
document examination tools, principles and techniques, it is my professional expert opinion that
a different person authored the name of Victor Parks on "QI" and "Q2." The author of the
known Victor Parks signatures is not the author of the Victor Parks signatures on the questioned
documents, "Ql" and "Q2."
I am willing to testify to this fact in a court of law.
Z ? ~ i ~
Robert A: Meister
SWORN BEFORE ME on this 19
th
day of August, 2008
Robert A. Meister did appear before me.
STATE OF INDIANA
COUNTY OF HAMILTON
Exhibits Volume A
Letters, Email Notes & Mise
A -13
VOLUME A 22/210
Case 05-90374 Document 259 Filed in TXSB on 05/08/09 Page 15 of 35
Robert A. Meister
Forensic Document Examiner
Forgery Finders, LLC
120 N. Mill Creek Road
Noblesville, In 46062
Phone: (317) 770-1000 Fax: (800) 786-2629
Forensic Examination Provid,ed For:
Disputed documents or signatures, including wills, checks, contracts, deeds, account
ledgers, medical records, and autograph authentication.
Education
BS Civil Engineering, Bradley University, 1968
MS Engineering Administration, Bradley University, 1975
Certificate in Electronics, DeVry Institute, 1972
Training and Apprenticeship
School of Forensic Document Examination
Training Completed between 10/2004 - 10/2006
Certification as a Forensic Document Examiner, 10/2006
Analyzed Documents from over 70 Cases in 28 States, Canada and D.C.
Instructor for Handwriting University's School of Forensic Document Examination,
2006 - 2007
American Institute of Applied Science
Certification In Questioned Documents, 9/2005
Specific Areas of Training:
Handwriting Identification and Discrimination
Signature Comparison
Techniques for Distinguishing Forged Signatures
Disguised Handwriting
Altered Numbers
Anonymous Writing
Laboratory Procedures
Ethics in Business and the Legal System
Exhibits Volume A
Letters, Email Notes & Mise
A-14
VOLUME A 23/210
Case 05-90374 Document 259 Filed in TXSB on 05/08/09 Page 16 of 35
Robert A. Meister, FOE
Laboratory Equipment used for examination:
Precision Nikon Digital Camera
Precision Flat Bed Optical Document Scanner
AmScope Stereo Microscope ST60 5x-30x, with Digital Output Camera
Assorted lighting devices and measuring scales and rulers
Library
Page 2
Handwriting Identification: Facts and Fundamentals, Roy Huber, 1999
Document Examiner Textbook, Jess E. Dines, 1998
Between the Lines, Reed Hayes, 1993
Dishonesty in Handwriting, Andrea McNichol, 1993
Scientific Examination of Questioned Documents, Ordway Hilton, 1993
Red Flags on Forged Checks, Joe Lucas, 1995
Written In Crime, Reed Hayes
Forensic Handwriting Examination, Reed Hayes 2006
Attorney's Guide to Document Examination, Katherine Koppenhaver, 2002
Document Examination manuals from American Institute of Applied Science
Black's Law Dictionary
Barron's Law Dictionary
Conferences Attended &Presenter
2005 Document Examination Training Conference.
2006 Document Examination Training Conference
Dallas, Texas
Publications
"The Concise Technique for Forgery Detection",
Co-Authored Robert & Scott Meister
"Use of PowerPoint in Determining Document Authenticity"
Co-Authored Robert & Scott Meister
"Advanced Computerized Techniques in Exhibit Preparation"
PC Video Presentation + Paper
Co-Authored Robert & Scott Meister
Professional Affiliations
Registered Professional Engineer, Illinois and Indiana
Exhibits Voiume A
Letters, Email Notes & Mise
A -15
VOLUME A 24/210
Case 05-90374 Document 259 Filed in TXSB on 05/08/09 Page 17 of 35
Scott Meister
Forensic Document Examiner
Forensic Document Examiners, LLC
120 N. Mill creek Rd
Noblesville, IN 46062
Phone: (317.) 441-4845 Fax: (317) 770-7788
. www.forgertfjoders.g>m
.
,
Forensic EKamination Provided For:
Includes but not limited to disputed documents or signatures, including wllls, checks,
contracts, deeds, account ledgers, medical records, and autograph authentication.
Education
Bachelor of Science in Business .Administration, May 2000
Masters of Science in Accounting, July 2001
Training and Apprenticeship
School of Forensic Document Examination
Training completed between 10/2004 - 10/2006
Certification as a Forensic Document Examiner, 10/2006
Analyzed Documents from OVer 63 Cases in 23 States
Instructor for Handwriting Universlty's School of Forensic Document Examination
2006-2007
American Institute of Applied SCience
Certification In Questioned Documents, 9/2005
Specific Areas of Tr.'n'ng:
HandWriting Identification and Discrimination
Signature Comparison
Techniques for Distinguishing Forged Signatures
Disguised Handwriting
Altered Numbers
Anonymous Writing
Laboratory Procedures
Ethics in Business and the Legal System
Exhibits Volume A
Letters, Email Notes & Mise
A-16
VOLUME A 25/210
Case 05-90374 Document 259 Filed in TXSB on 05/08/09 Page 18 of 35
--
Laboratory EquIpment used for examination:
Computer
Adobe Photoshop
Photocopier
Scanner
Magnifying devices
Stereo Microscope 30x, with Digital Output Camera
Library
Handwriting Identificatioh: facts and fundamentals, Roy Huber, 1999
Document Examiner Textbook, Jess E. Dines, 1998
Between the Lines, Reed Hayes, 1993
Dishonesty In Handwriting, Andrea McNichol, 1993
Red Flags on Forged Checks, Joe Lucas, 1995
Written In Crime, Reed Hayes,
Conffifrences Attended
2006 Document Examination Training Conference
Dallas, Texas
2005 Document Examination Training Conference
Dallas, Texas
2004 Document examination Training Conference
Dallas, Texas
Publications
"IThe Concise Technique for Forgery Detection",
Robert & Scott Meister
of PowerPoint in Determining Document Authenticity"
Co-Authored Robert &Scott Meister
"Advanced Computerized Techniques in Exhibit Preparation"
PC Video Presentation + Paper
CO-Authored Robert: &, Scott Meister
Exhibits Volume A
Letters, Email Notes & Mise
A -17
# I
VOLUME A 26/210
Case 05-90374 Document 259 Filed in TXSB on 05/08/09 Page 19 of 35
p.2

(Sea}
V,t .:, l( t);, •••. I
P<'Jcif"te Mortrlg<:
IJ
lXi' ?-19.l9
50f!. 271 7845
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My team :md I :lre d\.'dlc'lll:d lo giving you the and product nnywhCT(l! lire
c\lt\litlcnllh;ll )'"" willl-'nd ,Illr l..'Vcl (If ;lIld m 1ll>lle!
I lutlk rl\fWlItJ 1<' with )'00 to :t of cscr(.w. you desire l'ldditi\lR.11
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crl.""it.. and sourCe or Hll'ldll.. and wc'no: happy to Cl.1JIlion Iflllt you've bIx.'fl pre-quulHicd 10 a
SI.7U1.00() with SO/10l10 Thill p1z-qtlalifiCAtian ill lluhjoet to written verification
:nul rnll :lIlP'l'\w.11 from (\lll'lIlldcrwrilillj::, (jl;(",rfm.:nl.
RE: l'W.E-QUALIFICAT10N
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VOLUME A 27/210
Case 05-90374 Document 259 Filed in TXSB on 05/08/09 Page 20 of 35
1 SUPPLEMENTAI.. DECLARhnON OF VICTOR PARKS
2 I. Victor Parks. state and declare as follows:
3
4 1. I am a Senior Loan Consultant with Pacific Mortgage Loan
5 Consultants. I submit this declaration in support ofNivie Samaan's Sur-Reply to
6 defendant Jospeh Zemik's ("?emik") Motion to Expunge Lis Pendens. I have personal
7 knowledge ofthe facts set forth herein. which are known by me to be true and correct, and
8 ifcaUed as a witness. I could and would competently testify thereto.
I declare under penalty of perjury under the laws ofthe State of California
that the foregoing is true and correct.
3. Attached hereto as Exhibit 28, is a true and correct copy ofa letter I
received from Countrywide Home L o ~ Inc., dated November 6, 2006. confmning that
on or around October 14.2004. Countrywide suspended the processing ofMs. Samaan's
loan because they had not yet received Qcopy ofthe fully executed Purcb.a$e Agreement.
This letter is accompanied by the actual Notice of Suspension that Countrywide sent me in
Executed on November 6, 2006 at San Diego. California.
document was not signed or initialed by the defendant
October 2004.
9
2. Attached hereto as Exhibit 27 is a true and correct copy of the
10
Purcbase Agreement that Mara Escrow me on October 22, 2004. The fax line on the top of
11
the documents shows that .Mara E'scrow sent it on October 22, 2004, at 3:42 p.m. This
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VOLUME A 28/210
Case 05-90374 Document 259 Filed in TXSB on 05/08/09 Page 21 of 35
, California.
Executed on October ~ 2006 at Sr&! nfg",*
r declare under penalty ofpetjwy under the Jaws ofthe State ofCalifomia
that the foregoing is true and correct.
1 Contingency by October 11. We bad one full week before the deadline for close of
2 escrow. It would have only taken a few days for the loan documents to be prepared.
3 Based on my experience I believe that the parties could have closed escrow by November
4 1,2()04.
S
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VOLUME A 29/210
Case 05-90374 Document 259 Filed in TXSB on 05/08/09 Page 22 of 35
I . VI. .ASSETS AND
1$cIloPllIurflulEslllct OwIt!l\l gr.d lIfO_uucon.....Uon
.....dlIlg.. TVIlelll Pres",,' AmounIaI Gtoso
or Ill!....tal bIllIl!I Midlot mille) PtoP'l'l1 Markel Va10e & Ue", J\I>nlaI '- l'e)'menla
I
InsUnmcal
Nel
Tlous &Mise. Renl3llneMlt
$ $ $ $
90_Co-IIOIJOwer
V,.. No Y"" No
ClIilQO
0&100
Clli! 00
0&100
0&1 00
0 &I 0 0
0 1m Cl 0
0 1m 0 Cl
0 Ii! 0 0
Ii! 0 0 0
0 &I 00
&I 0 0 0
0 1m 0 0
TO!III$ $ $ $ $
ust IIIl)' .1kIW_, ...11I.. ullderwtllollomllt/lll pJVVloillll> Ill"" "'_ lllld lndIollla tpproPJlala ClOll1lUIW11f(sl end 00_11I numllllJ OIl
AlIoINl8ram. A=unlN....b..
FtodIllaNol_1l51lt1ll4
'OOiI ........opp.ttna 0Ul4 Computer Genemed,.;o 3 01
Handwritten 1003
J 8#3
Exhibits Volume A . P. GE 5
Letters, Email Notes & Mise
A -21
VOLUME A 30/210
Case 05-90374 Document 259 Filed in TXSB on 05/08/09 Page 23 of 35

(
o ... hlel. Owned QI eddillonal prop life awned, U58 OQIl1inuatlOn sheel)
PrOlltll1} Addrestl (enter S II sold. PS II penlllng ssIe Type 01 PresllfIt Amount of Gross Mortgage
or Rif rentelbelng held lot I_mel PtoPtll1} Milk'll Voluo Mrlrll/llUlls &Lilln. Renlal Income Po_nls
Insurance,
Malnlenan<:e, Net
r...... &Mlle. Rentallncomt
$ $ $ $
Tolals $ $ $ $ $ $
Lllt.ny addlllonol name. undor wblch crodll h3a ",o... IoU"y been re.olved and Indlc.te approprlale creditor namel') .nd accounl number(sl:
A1terllllte Name Credllllf Name Account Numbflt
01Il00

0111 00
DO
DO
DO
DO
DO
DO
00
v•• No

0111

0111
0111
0111
mo
0111
1110
0111
a. PIlrcha" IllJce $ 1,118,000
b. AlW.llonil, hnpr_mentl, replli..
£!orr gnallltll al' C<)< owe'" SIgllatur.
X (:1' ....,)
-,\,2};,Ji;,'i
F
r',i!i.;!,':Yi;;:;;r(X',:: I?U. ".liE§'4!ii;::";;;1r
-la. !lie Ihtnl .. _JanningjuUgRll!N. agoInsI yoU7
,..jb. HoI"e j'QU beon ba<tlwpl whllin !lie po.t 7
=•• f -lc Ha'lej'QU had Iofedosecl upon or 0..... tiU. ord.lId In I... Ih.rool
I. EslllMled closlng coolS In lb. In' 7y....?
:;O.;..:P,;;M:;;I.:..;M:;;lP:..:,..:,F;;;;Ufidl:;.;;;;;ng::..;.FflIl;;;;.",--...,.- f -td. Are j'QU. patlylO11_0117
11. OlsllCMMll (K £!0ITIlWllf will pay) •• Hov. j'QU dltaclly or In<lIraoUy been obigalad on..., 'Ollnwtllcl1 ",$IIIled In
I. Tola/costa (addllelllll'lhrough hi 1718000.00 torllC!llaur.. kansteroltilleln ••uoIforet::1l!SlJre.orjudgmenn
""---.:..;....:..-I---"-'-·.....:--l
k. BorrOW81's closlngcol5 paid bv Seier
l. Olller Credllt(a.orplalnl I, Are you prMenIl\' delIn'l""'" or lrI defaUl on ..... Fllder.ll dab! Of Iny 0Iher
Cash DepoeII 30.000.00
g, Ate you oIlIIgaied l<l /Ill' alln1<my, cl1IkI .....l>IJl'1, or lCPlIr. momJanlnce?
Isanyp.rtcfllll>"-'P"l"'*'!bouowed1
New Flrsl Moftgage 1.374.400,00 l Are you a """""hr or tIldorM< on. notl?
New1et MIg Clo.''''' C""b1 (28,115.331 •.•• ' ..
---,-----------.f--,.".,,.,..,,=="- Arej'QUeU.S.cIlIun?
m.L__nt 111.800,00 k.Artj'QU.permanenlr.sillel11.liIln?
(excIlldlPMI.MlP. Fullding F.. hn<:oll
......,=_--:__...,.-...".._......,__-!- --II. 00 yoUInland to ocC\IPYthe property," )'OlIr prlml/Y ruld....?
n, PMf.t.l'P,Foodlng"•• flnanced •••••••_ .. _".,""""',
.....loallol.!llnolrlordarlof1ll)flllarU..land.... compllaec8wllheqU.lcredll
opporlunity.J8lrbouslllglllldllolM1tlIJl'lllIIl.dlIclOlltlttlM. Vo....tlOlrtqllltedlobnlllllhlsfnfomle1loll.llUIllfllllllCOtlfl08dlOdoiO. ThelllWlllO\lld&elllllalelldlltlllllt
dlscriMnal811lllll1atonlhebaol.oIlfllslnlarmaioll,noronwhelhefl'\lUCIIOOseloltJlnlshllll)'OUltJlliahU1oinformatIOn. pf"seJlfOVklebolhelhnldly...drace. Forrace.)IOtI
....ChlCk""""lI1enon......'gn,I• .",.llyoudonolti.omlol>.'IInIclty.""'.,or-.omdarF.daraln19ulat1orls,II...landerlsNl<l......
ob>.....lIooor$lllfllllll••II)'Ol>donolwlollloll>mbhlhelnlormallon.pIe•••CheckU1obOlCbeloW. (L........mllSl'evlewlheabovllmal.rlallO.nw.lhlll llIll_"'.....IIs/Y
1Il1 <eqw«tt_ 10whIcl1l11. kll\der IS $II\lj8CI undllf applcabla _ law for II1e pel1lcular Iype or loinapplied fOf.)
80RROWER 01.... 1lOI wllllllOr."rQltun fnformallcin Co-eORROWEA Or .... not_ll>f\lInlOh lhI,lnlormllll...
Race: OAmadcenindianOf 0...- OBlec;kor Raca: O __lndll.or DAtil" o iliaci< ar
Alalka NeUv. 1I1lICIII AfIIlIdclon -... Nlliv. Aldcen.....1Ilcen
o"'olNa Haoo..... tit III WIllie 0 N'lNa """"'""" or 0 'MlIle
0IIll>, f'lIdIlc:-""" 01hII PaQIlc I'-
StlC I1IF........ 0 Mala Sax: OF....... OM.o
FreddlouaeFormG5 011114
Calp Form 01104
<:omputer' .Geueroted
WOSPaoa 2 of
Fomnle MlIaFDfllll01l3 01/04
Exhibits
Letters, Email i Mise
A-22
VOLUME A 31/210
Case 05-90374 Document 259 Filed in TXSB on 05/08/09 Page 24 of 35
• California.
ExeCuted on October '!L2006 at SI!-l!. Dr",...
1 Contingency by 11. We had one full week before the deadline for. close of
2 escrow. It would have only taken a 1l:wdays for the loan documents to be prepared.
3 Based on my experience I believe that the parties could have closed escrowby November
4 1,2(104.
S
6 r declare under penalty ofperjury under the Jaws ofthe State ofCalifornia
7 that the foregoing is true and oorrect.
8
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DECLARAtlONOF. VJOTOlt: 1"A.RKS- "
.. 2..2 __
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JOB #3
A-24
VOLUME A 32/210
Case 05-90374 Document 259 Filed in TXSB on 05/08/09 Page 25 of 35
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Exhibit A(2)
April 12, 2009; NOTICE #2, RE: CFC/BAC
William Allen Parsley, Borrower
Case # 05-90374
EXhibits Volume A
Letters, Email Notes & Mise
A-25
VOLUME A 33/210
Case 05-90374 Document 259 Filed in TXSB on 05/08/09 Page 26 of 35
31()'312-1111 SOUSA COURT REPORTER 111
P a g ~ I
310--3
~ - - - ~ - - - - - - - - - - - - ,
I
USA COURT REPORTERS 714-571-0111
Pagel
SUPERIOR COURT Of THE STATE OF CALIFORNIA
COUNTY OF LOS ANGELES - WEST DISTRICT
NIVIE SAMAAN, AN INDIVIDUAL,
PLAINTIFF,
THE DEPOSITION OF NIVIE SAMAAN, TAKEN ON BEHALf OF
DEFENDANT AND CROSS-COMPLAINANT JOSEPH ZERNIK, AT 800 SOUTH
FIGUEROA STREET, 12TH FLOOR, LOS ANGELES, CALIFORNIA, AT
10:08 A.M., MONDAY, JULY 10, 2006, BEFORE PATRICIA E.
NAKANO, C.S.R. NO. 5624, A SHORTHAND REPORTER FOR THE STATE
OF CALIFORNIA, PURSUANT TO NOTICE.
10
11
12
VS.
JOSEPH ZERNIK, AN INDIVIDUAL, AND
DOES 1 THROUGH 20, INCLUSIVE,
DE FENDANTS .
AND ALL RELATED CROSS-ACTIONS.
CASE NO. SC 087400
10
11
12
13
14
APPEARANCES OF COUNSEL:
FOR PLAINTIFF:
LAW OFFICES OF JAY R. STEIN
BY: JAY R. STEIN, ESQ.
1801 CENTURY PARK EAST
SUITE 2400
13 15 LOS ANGELES, CALIFORNIA 90067-2326
14
16
15
16 DEPOSITION OF NIVIE SAMAAN
17
17 LOS ANGELES, CALIFORNIA
18 FOR DE FENDANT AND CRaSS-COMPLAINANT JaSEPH ZERNIK:
18 MONDAY, JULY 10, 2006
19 SULLIVAN, WORKMAN Ii. DEE, LLP
19
20 20 BY: CHARLES D. CUMMINGS, ESQ.
21 REPORTED BY:
21 800 SOUTH FIGUEROA STREET
PATRICIA E. NAKANO
22 12TH FLOOR
22 C.S.R. NO. 5624
JOB NO. 547246 23 LOS ANGELES, CALIFORNIA 90017
23
24
24
25
25
,
i
NIVIE SAMAAN 7/10/06 NlVIE SAMAAN 7/10106 I
I
,---_._-
- - ~
310-372-1111 SOUSA COURT R£PORTERS 114-571-0111 310-312-1111 SOUSA COURT REPORTERS 714-571-0111
Page) Pag,.
1 APPEARANCES OF COUNSEL: (CONT. ) 1 I N DE X
2
2 WITNESS:
3 NIVI E SAMAAN
3 FOR CROSS-DEFENDANTS COLDWELL BANKER RESIDENTIAL
4
4 BROKERAGE AND MICHAEL LIBOW:
5 EXAMINATION BY: PAGE:
5 COLDWELL BANKER RESIDENTIAL BROKERAGE COMPANY 6 MR. CUMMINGS 5
6 THE LAW DEPARTMENT
7
8
7 11611 SAN VICENTE BOULEVARD
9 EXHIBITS
8 NINTH FLOOR
10
9 LOS ANGELES, CALIFORNIA 90049-6510 DEFENDANT'S PAGE:
10 (NOT PRESENT) 11
1 - NOTICE OF DEPOSITION AND DOCUMENT PRODUCTION 18
11
12 OF NIVIE SAMAAN, SEVEN PAGES
12 ALSO PRESENT:
13 2 - VARIOUS DOCUMENTS r BATES STAMPED SOO01 18
13 JAE LLOYD
THROUGH 50116, lIE PAGES
14 JOSEPH ZERNI K. (PAGE 9 TO PAGE 57) 14
3 - PHOTOCOPY OF CHECK NO. 1074, DATED 9/24/04, 59
15
15 IN THE AMOUNT OF $15,000, ONE PAGE
16
16 4 - LETTER, DATED SEPTEMBER 30, 2004, ONE PAGE 91
17
17 5 - LETTER, DATED SEPTEMBER 30, 2004, ONE PAGE 92
18 18 6 - LETTER, DATED OCTOBER 6, 2004, ONE PAGE 92
19 7 - LETTER, DATED SEPTEMBER 23, 2004, ONE PAGE 93
19
20 B - LETTER, DATED SEPTEMBER 23, 2004, ONE PAGE 94
20
21 LETTER, DATED OCTOBER 5, 97 9 - 2004, ONE PAGE
21
22 10 - FAX COVER SHEET FROM MICHAEL J. LIBOW, 99
22 10/15/04, WITH ATTACHED DOCUMENTS, SIX PAGES
23
23
11 - DOCUMENT, DATED NOVEMBER 8, 2004, FRoM GAIL 101
24
24 HERSHaWITZ, ONE PAGE
25
25
Exhibits Volume A
NIVIE SAMAAN 7110/06
LeUer \}W;leS (X IVIlse
A-26
VOLUME A 34/210
Case 05-90374 Document 259 Filed in TXSB on 05/08/09 Page 27 of 35 --------
]10-312-1111 SOUSA COURT REPORTER: III 310-3 lJSA COURT REPORTERS 714·571·0111
Pagc5
P3.Bl: 6
LOS ANGELES, CALIFORNIA; MONDAY, JULY la, 2006 EVEN THOUGH THESE ARE INFORMAL PROCEEDINGS, AND
10:08 A.M. THEY'RE IN MY OFFICE, THE OATH YOU'VE TAKEN IS THE SAME
OATH THAT YOU WOULD TAKE IF YOU WERE IN COURT, AND
NIVIE SAMAAN', YOU'RE SUBJECT TO THE SAME PENALTIES I F YOU DON'T TELL
THE WITNESS HEREIN, HAVING BEEN FIRST THE TRUTH AS IF YOU WERE IN COURT AND DIDN'T TELL THE
DULY ADMINISTERED THE OATH, WAS EXAMINED TRUTH.
AND TESTIFIED AS FOLLOWS; DO YOU UNDERSTAND THAT?
A. YES_
EXAMINATION Q. I F YOU DON'T UNDERSTAND A QUESTION, I DON'T
10 BY MR. CUMMINGS: 10 WANT YOU TO ANSWER THE QUESTION. I WANT YOU TO TELL ME
11 Q. CAN YOU PLEASE STATE AND SPELL YOUR FULL NAME 11 YOU DON'T UNDERSTAND IT, WHY IT IS YOU DON I T UNDERSTAND
12 FOR THE RECORD. 12 IT. I I LL ATTEMPT TO REPHRASE IT SO THAT YOU DO
1.3 A. NIVIE SAMAAN, N-I-V-I-E S-A-M-A-A-N. 13 UNDERSTAND IT.
14 Q. I'M GOING TO GIVE YOU SOME INSTRUCTIONS NOW 14 IF MY VOICE DROPS AND YOU DON'T CLEARLY HEAR A
15 THAT WE TRY TO FOLLOW IN A DEPOSITION. 15 QUESTION, LET ME KNOW. I'LL EITHER RESTATE THE QUESTION
16 ONE OF THE MOST IMPORTANT THINGS IS THAT ONLY 16 OR ASK THE REPORTER TO READ THE QUESTION BACK TO YOU.
17 ONE OF US SPEAK AT A TIME; AND, THEREFORE, IF AT ANY 17 IF YOU ANSWER A QUESTION, I'LL ASSUME THAT YOU
18 TIME DURING THESE PROCEEDINGS START A QUESTION BEFORE 18 HEARD THE QUESTION, YOU UNDERSTOOD THE QUESTION, YOU'RE
19 YOU'VE COMPLETED YOUR ANSWER, PLEASE TELL ME, AND I'LL 19 ANSWERING THAT QUESTION, NOT SOME OTHER QUESTION.
20 LET YOU COMPLETE YOUR ANSWER. 20 IF, AS WE GO THROUGH THE PROCEEDINGS, YOU THINK
21 IT'S IMPORTANT THAT ALL OF YOUR ANSWERS BE IN 21 OF SOMETHING THAT WOULD CLARIFY OR MODIFY A PRIOR ANSWER
22 AUDIBLE WORDS IN THE ENGLISH LANGUAGE, RATHER THAN NODS 22 YOU'VE GIVEN TO A PRIOR QUESTION, YOU JUST TELL US, AND
23 OR SHAKES OF THE HEAD OR UTTERANCES SUCH AS "UH-HUH" OR 23 YOU CAN GO BACK AND MODIFY YOUR ANSWER.
2·1 "HUH-UH." THE REASON FOR THAT IS SO THAT WE HAVE A 24 IF YOU WANT TO GET WATER OR COFFEE OR USE THE
C:I..EAR RECORD. 25 RESTROOM, JUST TELL US, AND WE'LL TAKE A BREAK.
NIVIE SAMAAN 7/lOfO(j NIVIE SAMAAN 7/10106
__J- . .. __
310-372·1111 SOUSA COURT REPORTERS 714-511-Vlll 310-312-1111 SOUSA COURT REPORTERS 114·571·0111
Page? Page 8
ARE YOU AWARE O ~ ANY PHYSICAL OR MEDICAL THE DEPOSITION NOTICE THAT WE RECEIVEDi IS THAT CORRECT?
CONDITION THAT YOU HAVE THAT WOULD PREVENT YOU FROM MR. CUMMINGS: THAT IS CORRECT.
GIVING YOUR BEST TESTIMONY HERE TODAY? MR. STEIN: OKAY. THANK YOU.
A. NO. BY MR. CUMMINGS:
Q. ARE YOU CURRENTLY TAKING ANY MEDICATIONS OF ANY Q. ALSO, AF'I'ER THESE PROCEEDINGS ARE CONCLUDED,
KIND THAT WOULD AFFECT YOUR ABILITY TO RECALL AND YOU I LL HAVE AN OPPORTUNITY TO REVIEW YOUR DEPOSITION,
RECOLLECT EVENTS? MAKE ANY CHANGES IN IT AND ANY CORRECTIONS THAT YOU WANT
A. NO. TO; SO TO THE EXTENT YOU DO SO, I'LL HAVE THE
Q. WHAT'S YOUR DATE OF BIRTH? OPPORTUNITY TO COMMENT ON THOSE AT THE TRIAL OR OTHER
10 A. 11/6/66. 10 PROCEEDINGS IN THIS ACTION. SO TRY TO GIVE YOUR BEST
11 MR. STEIN: COUNSEL, BEFORE WE GO WITH SUBSTANTIVE 11 TESTIMONY.
12 QUESTIONS, CAN WE PUT ON THE RECORD THE STATUS OF 12 WILL YOU PLEASE LOOK AT THE NOTICE OF
13 MR. LIBOW'S REPRESENTATION OR LACK HEREOF AT THIS 13 DEPOSITION.
14 DEPOSITION? I I D LIKE IT ON THE RECORD THAT THEY CHOSE 14 HAVE YOU HAD A CHANCE TO READ OVER THAT?
15 NOT TO APPEAR. 15 A. NO.
16 MR. CUMMINGS: SURE. I CALLED A FEW MINUTES AGO BY 16 Q. WOULD YOU TAKE A CHANCE TO READ OVER THAT,
17 TELEPHONE MR. SHULKIN'S OFFICE. I SPOKE TO SOMEBODY, 17 PARTICULARLY IF YOU COULD LOOK AT WHAT IS REFERRED TO AS
18 WHOSE NAME I DON'T REMEMBER, BUT WHO IDENTIFIED HERSELF, 18 EXHIBIT A, AND IF YOU COULD TELL ME IF YOU HAVE BROUGHT
19 A WOMAN, WHO IS ONE OF HIS ASSISTANTS, WHO SAID HE WAS 19 WITH YOU ALL THE DOCUMENTS DESCRIBED ON EXHIBIT A, TO
20 NOT IN. I ASKED IF HE WAS COMING TO THE DEPOSITION OF 20 THE BEST OF YOUR KNOWLEDGE.
21 MS. SAMAAN TODAY IN THE ZERNIK!SAMAAN MATTER, AND I WAS 21 A. I HAVE DOCUMENTS WITH ME. I DON1T KNOW IF
22 INFORMED THAT NOBODY FROM THEIR OFFICE WAS COMING, AND 22 THOSE ARE THE DOCUMENTS OR NOT.
23 THAT'S WHY WE COMMENCED WITH THE DEPOSITION. 23 Q. MAYBE YOUR COUNSEL CAN.
24 MR. STEIN: AND JUST FOR THE RECORD, THEY DID 24 MR. STEIN: FOR THE RECORD, WE ARE PRODUCING
A-27
DOCUMENTS NOS. SOOl THROUGH 30116, WHICH ARE RESPONSIVE
Exhibits Volume A
Leller I l?ltQ.les 0< IVIlse
2S
NIVlE SAMAAN 7110106
RECEIVE NOTICE OF THE DEPOSITION IN ADVANCE PURSUANT TO 25
VOLUME A 35/210
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310-J72-1111 SOUSA COURT REPORTER.
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III 310-3 USA COURT REPORTERS 714·571·0111
Pagt: lU
'F.OUESTS. IN ADDITION, THE PLAINTIFF HAS
COPIES OF THE FILES Of' COLDWELL BANKER
'''if WHICH ARE NOT INCLUDED WITHIN THIS
'10U WOULD LIKE, WE CAN MAKE THIS AN
I DON'T KNOW. THAT'S UP TO YOU, AS YOU
Q.
A.
Q.
A.
Q.
ARE YoU CURRENTLY MARRIED?
YES.
WHAT'S THE DATE OF YOUR MARRIAGE?
SEPTEMBER 19, 2004.
WHERE WERE YOU MARRIED?
A. HAWAII.
THEY I RE BATES STAMPED. THAT'S FINE.
(MR. ZERNIK ENTERS THE DEPOSITION
Q.
A.
WHAT'S THE NA.'1E OF YOUR SPOUSE?
JAE R. LLOYD.
Q. WHERE DO YOU CURRENTLY RESIDE?
'tulAAN, I'LL ASK YOU TO SIMPLY LOOK AT THIS
- ~ ' l - l A T YOUR COUNSEL'S PRODUCED.
LOOKED AT THE DOCUMENTS YOU BROUGHT
l!\Y?
f ;';:NQWLEDGE, OTHER THAN THE DOCUMENTS
YOUR ATTORNEY'S RECEIVED IN THIS
ESCROW COMPANY AND fROM COLDWELL
,qp.RE or ANY OTHER DOCUMENTS THAT RELATE
,.Jl'HER THAN COMMUNICATIONS WITH YOUR
10
11
12
13 .
14
15
16
17
18
19
20
A.
90212.
Q.
A.
Q.
A.
Q.
A.
Q.
A.
Q.
133 SOUTH PECK DRIVE, NO. 104, BEVERLY HILLS,
DO YOU OWN THAT PROPERTY?
NO.
DO YOU RENT THAT PROPERTY?
YES.
WHEN DID YOU MOVE INTO THAT PROPERTY?
ARE YOU ASKING WHEN I MOVED INTO THE PROPERTY?
YES.
SEPTEMBER OF 2004.
DID YOUR HUSBAND RENT THE PROPERTY BEFORE YOU
21 MOVED IN?
YOU EVER BEING KNOWN BY ANY OTHER
22
23
A.
Q.
YES.
IS THAT ADDRESS ON PECK THE LOCATION WHERE YOU
24 AND YOUR HUSBAND HAVE RESIDED SINCE YOU WERE MARRIED?
NIVIE SAMAAN 11lQi06
Ltl SOUSA COURT REPORTERS 114-511-0111
Page II
"] EVER BEEN CONVICTED OF A FELONY?
,JeJ'.E YOU BORN?
EGYPT.
i! I DID YOU COME TO THE UNITED STATES?
Ii] GRADUATE FROM HIGH SCHOOL?
25 A.
Q.
A.
Q.
THAT?
A.
Q.
A.
Q.
YES.
NlVIE SAMAAN 1/10/06
311).372-1111 SOUSA COURT REPORTERS 114-571-0111
WHAT YEAR DID YOU ATTEND THERE OR OBTAIN THAT?
I BELIEVE IT WAS '88 TO '90.
DID YOU TAKE ANY OTHER FORMAL EDUCATION AFTER
I OBTAINED MY REAL ESTATE LICENSE.
WHEN DID YOU DO THAT?
IN MARCH OF 2003.
WHAT COURSE OF STUDY DID YOU TAKE TO OBTAIN
!EAR? YOUR REAL ESTATE LICENSE?
10 A. I WENT THROUGH A REAL ESTATE COURSE THROUGH
II'.GH SCHOOL? 11 CENTURY 21.
HIGH SCHOOL IN MODESTO, CALIFORNIA.
HOW DO YOU SPELL THAT?
.y -F;·-R.
YOU ATTEND COLLEGE?
WHAT" S THE FIRST COLLEGE YOU ATTENDED?
12
13
14
15
16
17
IT?
Q.
A.
Q.
A.
Q.
HOW LONG DID YOU TAKE THOSE COURSES?
SIX MONTHS.
DID YOU PASS THE TEST THE FIRST TIME YOU TOOK
YES.
HAD YOU EVER WORKED IN THE REAL ESTATE BUSINESS
[{ATIQNAL EDUCATION CENTER. IT'S A TRADE 18 BEFORE YOU PASSED YOUR TEST FOR A REAL ESTATE AGENT 1 S
19 LICENSE?
IS THAT?
(IF' COMMERCE.
20
21
A.
Q.
NO.
DESCRIBE YOUR WORK EXPERIENCE IN A
COURSE OF STUDY CAN YOU TAKE THERE?
1 1\1" BUSINESS.
ymJ OBTAIN ANY CERTIFICATE?
22
23
24
CHRONOLOGICAL ORDER AFTER YOU GRADUATED FROM YOUR
BUSINESS SCHOOL UNTIL YOU OBTAINED YOUR REAL ESTATE
LICENSE.
;., •.71.. DEGREE IN BUSINESS.
NIVIE SAMAAN 1/10106
25 A. I WORKED IN AN INVESTMENT BANKING COMPANY AS AN
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A-28
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310·312·1111 SOUSA COURT REPORTER
PagelJ
ASSISTANT TO THE PRESIDENT. I WORKED IN THREE DOCTORS' GRIFFIN?
3 1 ( ) . ~
------- - ---_..
!USA COURT REPORTERS 114·511-0]11
Page ]4
OFFICES; ONE AS AN OFFICE MANAGER; ONE AS A BUILDING
MANAGER; AND THE OTHER AS A RECEPTIONIST, VARIOUS OfFICE
WORK, AND THEN I GOT INTO RETAIL AND COSMETICS.
A.
NOTES.
Q.
I DON I T RECALL. I WOULD HAVE TO LOOK AT MY
CAN YOU GIVE ME YOUR BEST ESTIMATE?
Q. OKAY. AFTER YOU OBTAINED YOUR REAL ESTATE A. EITHER APRIL OR MAY OF 2004 -- 2003.
LICENSE, HAS YOUR LICENSE BEEN PLACED WITH ANY BROKER? Q. BETWEEN THE TIME THAT YOU FIRST WENT TO
A.
Q.
A.
YES.
HAS IT BEEN PLACED WITH MORE THAN ONE BROKER?
NO.
GILLERAN GRIFFIN AND BEFORE YOU EVER DID ANYTHING
REGARDING PROPERTY INVOLVED IN THIS LAWSUIT. WERE YOU AN
AGENT ON ANY TRANSACTIONS THAT CLOSED?
10
11
12
13
14
15
16
Q. WHAT BROKER HAS IT BEEN PLACED WITH?
A. GI LLERAN GRI FFIN REALTORS.
Q. WHERE ARE THEY LOCATED?
A.' WESTWOOD.'
Q. WHAT'S THE ADDRESS?
A. 1575 WESTWOOD BOULEVARD, SUITE 300, LOS ANGELES
90024.
10
11
12
13
14
15
16
A.
Q.
A.
Q.
A.
Q.
A.
NO.
DID YOU WORK ON ANY TRANSACTIONS?
NO.
WHAT DID YOU DO DURING THAT TIME AS AN AGENT?
I DIDN'T DO ANYTHING.
DID YOU CONTINUE TO WORK IN OTHER EMPLOYMENT?
YES.
17 Q. WHAT'S THE NAME OF THE RESPONSIBLE BROKER IN 17 Q. WHAT OTHER EMPLOYMENT?
18 THE OFFICE? 18 A. BARNEY'S NEW YORK.
19 A. THERE ARE TWO: THE OWNER IS T. J. GILLERAN; THE 19 Q. WHAT IS THAT?
20
21
MANAGER OF THE OFFICE, WHICH IS ALSO A BROKER, IS RANDY
SPAULDING.
20
21
A. A RETAIL ESTABLISHMENT.
Q. WHERE IS IT LOCATED?
22
23
24
Q.
A.
Q.
IS T. J. GILLERAN A MAN OR A WOMAN?
A MAN.
AFTER YOU GOT YOUR REAL ESTATE LICENSE --
22
23
24
A.
Q.
A.
9575 WILSHIRE BOULEVARD, BEVERLY HILLS. 90212.
WHAT KIND OF RETAIL ESTABLISHMENT IS IT?
IT'S A DEPARTMENT STORE.
25 EXCUSE ME -- WHEN WAS IT FIRST PLACED WITH GILLERAN
NIVIE SAMAAN 111O/()6
310-312-1111 SOUSA COURT REPORTERS 114-511.Q111
Page 15
25 Q. AND WHAT IS YOUR POSITION THERE?
NIVIE SAMAAN 1/10/06
31()..312·1111 SOUSA COURT REPORTERS 714·511·0111
Page 16
A. I WAS IN COSMETI CS AS A SALES PERSON. BUYER AND THE SELLER?
Q.
A.
ARE YOU STILL THERE?
NO.
A.
Q.
YES.
AND DID YOU LEARN THAT ANY CHANGES TO THE
Q.
A.
WHEN DID YOU CEASE THAT EMPLOYMENT?
AUGUST OF 2004.
CONTRACT HAVE TO BE IN WRITING SIGNED BY THE BUYER AND
THE SELLER?
Q.
BARNEY'S?
AND WHEN DID YOU COMMENCE YOUR EMPLOYMENT WITH A.
Q.
YES.
AND DID YOU LEARN THAT IF YOU WERE GOING TO BE
10
11
A.
Q.
A.
Q.
WHEN DID I BEGIN MY EMPLOYMENT WITH BARNEY'S?
CORRECT.
FIVE YEARS PRIOR TO THAT.
IN CONNECTION WITH YOUR EDUCATION, THE COURSE
10
11
A REAL ESTATE AGENT FOR A PARTY TO A CONTRACT -- STRIKE
THAT -- IF YOU'RE GOING TO BE A REAL ESTATE AGENT TO A
SELLER TO A CONTRACT, YOU HAD TO HAVE AN AGREEMENT IN
WRITING?
12
13
OF STUDY THAT YOU TOOK TO OBTAIN YOUR REAL ESTATE
LICENSE, DID YOU TAKE ANY COURSES THAT DEALT WITH
12
13
A.
Q.
YES.
AND DI D YOU UNDERSTAND THAT AN AGENT I S
14 CONTRACTS? 14 AUTHORITY TO ACT FOR THE SELLER TO MODIFY ANY TERMS OF
15
16
A.
Q.
CAN YOU REPEAT THAT?
IN CONNECTION WITH YOUR REAL ESTATE COURSES
15
16
AN AGREEMENT ENTERED INTO FOR THE PURCHASE OR SALE OF
PROPERTY HAD TO BE IN WRITING?
17
18
THAT YOU TOOK, DID ANY OF THOSE COURSES INVOLVE
CONTRACTS FOR THE PURCHASE OR SALE OF PROPERTY?
17
18
MR. STEIN: I'M GOING TO OBJECT TO THAT BECAUSE IT
CALLS FOR LEGAL CONCLUSION TO BE RENDERED BY HER. ON
19 A. THEY MADE US FAMILIAR WITH THE PURCHASE 19 THE OTHER HAND, I F SHE CAN RES POND, SHE SHALL.
20 AGREEMENT CONTRACT. 20 BY MR. CUMMINGS:
21
22
23
Q.
A.
Q.
STANDARD CALIFORNIA ASSOCIATION REALTOR FORMS?
YES.
IN CONNECTION WITH THAT COURSE OF STUDY, DID
21
22
23
Q.
A.
Q.
GO AHEAD.
CAN YOU REPEAT THAT.
SURE. WHAT I WANT TO KNOW IS IN CONNECTION
24
25
YOU LEARN THAT IN ORDER TO HAVE A CONTRACT FOR SALE OF
PROPERTY, THAT IT HAS TO BE IN WRITING SIGNED BY THE
NIVlE SAMAAN 1/10/06
24
25
WITH YOUR COURSE OF STUDY, DID YOU LEARN THAT FOR THE
AGENT TO BE AUTHORIZED TO MODIFY ANY CHANGES IN A
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A-29
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310·372-1111 SOUSA COURT REPORTER )III 31[}'] )lJSA CQURT REPORTERS 714·571·0111
Page 17 Page 18
CONTRACT THAT HAD BEEN ENTERED INTO BY A SELLER, THE DE POS IT I ON?
SELLER HAD TO GIVE THE AGENT THAT AUTHORITY IN WRITING? MR. CUMMINGS: EXHIBIT 1 IS THE NOTICE OF
MR. STEIN: SAME OBJECTION. DEPOSITION. I I LL MARK AS EXHIBIT 2 THE DOCUMENTS THAT
THE WITNESS: I DON'T RECALL I:' THAT WAS SOMETHING WERE PRODUCED BY THE DEPONENT AND HAVE BEEN MARKED 50001
THAT I LEARNED OR NOT. THROUGH 50116.
BY MR. CUMMINGS: MR. STEIN: THAT WILL BE THE COURT REPORTER'S COPY,
Q. DID YOU ACT AS YOUR OWN AGENT IN THIS AND I HAVE A COPY E'OR HER RIGHT HERE.
TRANSACTION? MR. CUMMINGS: ALL RIGHT. FINE. THANK YOU.
A. YES. (WHEREUPON THE AFOREMENTIONED DOCUMENTS
10 Q. WAS THERE ANYBODY IN YOUR OFFICE THAT YOU 10 WERE SUBSEQUENTLY MARKED BY THE REPORTER AS
11 CONSULTED WITH REGARDING THIS TRANSACTION? 11 DEFENDANT I S EXHIBITS 1 AND 2 FOR
12 A. IF I HAD QUESTIONS, I WOULD CALL MY MANAGING 12 IDENTH'ICATION AND ARE HERETO ATTACHED.)
13 BROKER AND ASK HIM. 13 BY MR. CUMMINGS:
14 Q. AND THAT PERSON I S NAME? 14 Q. WHERE DID YOU LEARN ABOUT THE PROPERTY AT 320
15 A. RANDY SPAULDING. 15 SOUTH PECK DRIVE IN BEVERLY HILLS BEING AVAILABLE, BEING
16 I ALSO WANT TO NOTE FOR THE RECORD THAT I AM 16 LISTED FOR SALE?
17 ALSO A CERTIFIED NOTARY; SO I HAVE TAKEN COURSES IN THAT 17 A. THROUGH MY HUSBAND.
18 AS WELL. 18 Q. WHAT DID HE TELL YOU WHEN HE FIRST TALKED TO
19 Q. HOW LONG HAVE YOU BEEN A NOTARY? 19 YOU ABOUT IT?
20 A. FOR ABOUT A YEAR NOW. 20 A. HE JUST SAl D HE WAS TAKING A WALK, AND HE
21 Q. SO SOMETIME IN 2005 YOU GOT YOUR LICENSE? 21 NOTICED THERE WAS A SIGN FOR A HOME FOR SALE ON OUR
22 A. EITHER 2005 DR TOWARDS THE END OF -- YES, 2005. 22 STREET, AND WE SHOULD TAKE A LOOK AT IT.
23 Q. THANK YOU. 23 Q. WHEN WAS THAT?
24 I WILL MARK AS EXHIBIT 2 -- 24 A. I DON'T RECALL.
310-312·1111 SOUSA COURT REPORTERS 71-1.. 571·01 J 1
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f---- ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ - - - - - - - . - . - - - ~ ~ - + ~ - - ~ - - -
Page 20
310-372·11 J 1 SOUSA COURT REPORTERS 714·57I-OI1 I
Q. WHAT DID YOU DO IN ORDER TO TAKE A LOOK AT THE
____________N_I_VI_£_SA_M_A_A_N_7_/l_OI_G5 ~
I
25
NIVIE SAMAAN 7/10/00
MR. STEIN: COUNSEL, IS EXHIBIT 1 THE NOTICE OF 25
PROPERTY? ACCOUNT?
A. I CHECKED IT OUT ON THE MLS TO SEE HOW MUCH IT A. I DON'T RECALL EXACTLY HOW MUCH I HAD IN THE
WAS BEING SOLD FOR AND LOOKED AT SOME OF THE SPECI FICS ACCOUNT.
ON THE PROPERTY. AND THEN WE WENT TO AN OPEN HOUSE. Q. DO YOU HAVE RECORDS THAT SHOW THOSE AMOUNTS?
Q. AT THE OPEN HOUSE. WAS THE OWNER OF THE A. YES, I BELIEVE SO.
PROPERTY THERE? MR. CUMMINGS: I DON I T BELl EVE THOS E WERE PRODUCED.
A. NO. I THINK THEY WERE REQUESTED.
Q. WAS A BROKER THERE? MR. STEIN: AT THE BACK, IN THE LATTER PORTION THERE
A. I DONIT BELIEVE IT WAS THE BROKER. I BELIEVE WERE TWO BANK ACCOUNTS LISTED.
10 IT MAY HAVE BEEN HIS ASSISTANT. 10 MR. CUMMINGS: THEN I STAND CORRECTED.
11 Q. DO YOU RECALL WHO WAS THERE FOR THE SELLER I S 11 Q. CAN YOU LOOK AT THE DOCUMENTS THAT ARE MARKED
12 REP? 12 AS PART OF THE EXHIBIT 2, S0112 THROUGH S0116.
13 A. I BELIEVE IT WAS AN ASSISTANT. 13 ARE THOSE THE TWO ACCOUNTS, THE WASHINGTON
14 Q. DO YOU RECALL THE NAME? 14 MUTUAL ACCOUNT THAT'S IDENTIFIED ON THE 50112 AND THE
15 A. NO. 15 WELLS FARGO ACCOUNT THAT I 5 IDENTIFIED ON 50113 THROUGH
16 Q. WAS IT A MAN OR A WOMAN? 16 50116 FROM WHAT YOU WERE GOING TO HAVE THE SOURCE OF THE
17 A. I BELIEVE IT WAS A WOMAN. 17 DOWN PAYMENT?
18 Q. WHAT WAS TO BE THE SOURCE OF INCOME FOR THE 18 A. YES.
19 DOWN PAYMENT FOR THE PROPERTY? 19 Q. ANY arHER ACCOUNTS?
20 A. MONEY FROM OUR ACCOUNT. 20 A. MY HUSBAND'S -- MY HUSBAND'S ACCOUNT WAS ALSO
21 Q. WHAT ACCOUNT? 21 AVAILABLE FOR FUNDS.
22 A. OUR BANKING ACCOUNT. 22 Q. WHERE WAS THAT ACCOUNT?
23 Q. WITH WHAT BANK? 23 A. WASHINGTON MUTUAL.
24 A. WELLS FARGO. 24 MR. STEIN: JUST FOR THE RECORD, COUNSEL, THE
25 Q. AND HOW MUCH MONEY DID YOU HAVE IN THAT 25 DOCUMENTS SOl14 THROUGH 116 REFLECT TWO DIFFERENT BANK
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,-
310-372-1111 SOUSA COURT REPORTER'
ACCOUNTS
JIll
Page2l
A
310-3
MY MOTHER
)USA COURT REPORTERS 714-571-0111
Pagel2
MR. CUMMINGS: I DON'T HAVE AN S0114. Q. AND WHAT INTEREST DOES YOUR MOTHER HAVE IN IT,
MR. STEIN: SORRY. AND WHAT INTEREST DO YOU HAVE IN IT?
THE WITNESS: I DON I T EITHER. A. WE HAVE DIFfERENT BUSINESS TRANSACTIONS
MR. STEIN: IS EVERYBODY MISSING IT?
THE WITNESS: YES.
TOGETHER; so WE BOTH HJ>..VE MONEY IN IT. I DON'T RECALL
THE AMOUNTS OF EACH_
MR. CUMMINGS: WHY DON'T YOU JUST GIVE IT TO ME, AND
I'LL GO COPY IT.
Q.
A.
WHAT BUSINESS ARE YOU IN WITH YOUR MOTHER?
IT'S NOT A BUSINESS. IT'S JUST DIFFERENT --
10
MR. STEIN: YES. HERE. COPY THIS TOO.
IS THAT THE ONLY PAGE MISSING? 10
DIfrE:RENT THINGS THAT WE DO TOGETHER. IT'S JUST AN
ACCOUNT WITH BOTH OF OUR NAMES.
11 MR. CUMMINGS: I BELIEVE SO. 11 Q. ACCORDING TO 50113, THERE WAS A BALANCE or
12
13
(BRIEF RECESS.)
BY MR. CUMMINGS:
12
13
APPROXIMATELY $181,000.
HOW MUCH OF THAT WAS YOURS r AND HOW MUCH WAS
14 Q. WE CAN LOOK AT 50113. THAT'S A -- I'M SORRY. 14 YOUR MOTHER' 5?
15
16
17
LET t S GO BACK TO 50112. THAT' S A WASHINGTON MUTUAL
ACCOUNT.
IS THAT JUST A REGULAR SAVINGS ACCOUNT?
15
16
17
A.
Q.
A.
I DON'T KNOW. I DON'T RECALL.
DO YOU HAVE ANY ESTIMATE AT ALL?
NO.
18
19
A.
Q.
I DON'T KNOW. MY HUSBAND HANDLES THE FINANCES.
WELL, THIS WAS YOUR ACCOUNT, THOUGH, BEFORE YOU
18
19
Q.
A.
WAS IT ALL YOUR MOTHER'S?
NO.
20 GOT MARRIED. 20 Q. WAS IT ALL YOURS?
21 A. I BELIEVE THIS IS MY CHECKING ACCOUNT. 21 A. NO.
22 Q. OKAY. AND LOOKING AT EXHIBIT -- BATES STAMPED 22 Q. ARE THERE ANY RECORDS THAT REFLECT HOW MUCH WAS
23 NUMBERS 50113 AND 50114, WHAT ACCOUNT IS THAT? 23 YOURS AND HOW MUCH WAS YOUR MOTHER'S?
24
25
A.
Q.
THIS IS MINE AND MY MOTHER'S ACCOUNT.
YOURS AND WHOSE?
NrVIE SAMAAN 7110/06
24
25
A.
Q.
NO.
HOW WOULD YOU DETERMINE THAT?
NIVIE SAMAAN 7I1tl,,%
1---------------------.--.-....---..----------------+-.------------.-.-------- _
310..372.1111 SOUSA COURT REPORTERS 714-511-0111
A. WE WOULDN'T. IF ANYTHING WERE TO HAPPEN TO ME,
THE MONEY WOULD GO TO MY MOTHER; VICE VERSA.
Q. OUT OF THAT ACCOUNT, HOW MUCH IN SEPTEMBER AND
Pagel3
310-312·1111 SOUSA COURT REPORTERS 114-511·0111
PlIgc24
Q. AND YOU STATED THERE WAS ALSO AN ACCOUNT THAT
YOUR HUSBAND HAD AT WASHINGTON MUTUAL THAT WAS
AVAILABLE?
OCTOBER OF 2004 DID YOU HAVE THE RIGHT TO USE? A. YES.
A.
Q.
A.
Q.
AS MUCH AS I NEEDED.
ALL OF IT?
IF SO NEEDED, YES.
DO YOU HAVE ANY AGREEMENT WITH YOUR MOTHER IN
MR. CUMMINGS: I WJo.NT TO SEE THOSE RECORDS, COUNSEL.
MR. STEIN: I DON'T HAVE THEM HERE TODAY. I'LL
PROVIDE THEM TO YOU r THOUGH.
MR. CUMMINGS: WE HAVE AN AGREEMENT THAT YOU'LL
9 WRITING TO THAT EFFECT? PROVIDE THEM WITHIN A WEEK?
10
11
A.
Q.
NO.
WHERE DOES YOUR MOTHER LIVE?
10
11
MR. STEIN: SURE.
MR. CUMMINGS: THANK YOU.
12 A. MODESTO, CALIFORNIA. 12 Q. WHOSE NAME WAS ON THAT ACCOUNT IN THE TIME
13 Q. AND HER NAME IS MARGARET SAMAAN? 13 PERIOD SEPTEMBER, OCTOBER OF 2004?
14
15
A.
Q.
YES.
WHAT'S HER ADDRESS?
14
15
A.
Q.
ON WHICH ACCOUNT?
THE ONE THAT YOU JUST REFERRED TO AS YOUR
16 A. 3208 JONATHAN LANE, MODESTO, CALIFORNIA 90 -- 16 HUSBAND I S ACCOUNT.
17
18
95355.
Q. IS YOUR MOTHER RETIRED, OR DOES SHE WORK?
17
18
A.
Q.
I BELIEVE HIS NAME WAS ON IT. I I M NOT SURE.
WHEN YOU FIRST MADE AN OFFER ON THE PROPERTY --
19
20
21
22
23
A.
Q.
SHE OWNS?
A.
Q.
SHE NEVER WORKED.
THE ADDRESS YOU GAVE ME IS THE PROPERTY THAT
YES.
LOOKING AT THE ACCOUNT FOR 50115 AND 50116,
19
20
21
22
23
I'M JUST GOING TO REFER TO IT AS THE PECK DRIVE
PROPERTYI THE PROPERTY AT 320 SOUTH PECK DRIVE. WHEN
YOU FIRST MADE AN OFFER ON THAT PROPERTYI DID YOU MAKE
THAT OFFER IN YOUR NAME ALONE OR ALSO IN THE NAME OF
YOUR HUSBAND?
24 WHOSE ACCOUNT IS THAT? 24 A. IN MY NAME.
25 A. THIS IS MY ACCOUNT.
NIVlE SAMAAN 1110106
25 Q. DID YOU EVER MAKE AN OFFER THAT WAS JOINTLY IN
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I
I
I
I
310-372-1111 SOUSA COURT III
25
YOUR NAME AND YOOR HUSBAND'S NAME?
A. NO.
Q. IS THERE ANY REASON FOR THAT?
A. NO.
Q. DID YOU INTEND THE PROPERTY TO BE YOUR SEPARATE
PROPERTY?
A. WE WERE BOTH GOING TO LIVE IN IT TOGETHER.
310-3 IUSACOURTRF,PORTERS 714-571-0111
Pagt:26
A. SOME OF THEM, I BELIEVE.
Q. DO YOU HAVE ANY DOCUMENTS RELATING TO THIS
MATTE:R THAT YOU HAVEN'T PROVIDED TO YOUR ATTORNEY?
A. I DON'T BELIEVE SO.
Q. WHAT I WANT TO DO, JUST SO THERE'S NO SURPRISES
OR ANYTHING, I WANT TO GO THROUGH THE TRANSACTION
CHRONOLOGICALLY FROM THE BEGINNING TO THE END. I'M JUST
Q- DID yOU INTEND TO TAKE TITLE TO IT IN YOUR NAME GOING TO, BASICALLY 1 BE ASKING YOU A SERIES OF QUESTIONS
ALONE? THAT SAY WHATfS THE. NEXT THING THAT OCCURRED, AND WE'LL
10 A_ 10 GO THROUGH THE DOCUMENT S. I WANT TO GO THROUGH
11 Q, DID YOUR HUSBAND EVER FILL OUT A LOAN 11 CONVERSATIONS YOU HAD WITH PEOPLE. I'M NOT ASKING YOU
12 APPLICATION IN CONNECTION WITH THE ACQUISITION OF THAT 12 FOR CONVE.RSATIONS YOU HAD WITH YOUR ATTORNEY ON
13 PROPERTY? 13 ANYTHING -- OKAY? -- OR ANY WRITTEN COMMUNICATIONS
14 A_ WHAT DO YOU MEAN? 14 BETWEEN YOU AND YOUR ATTORNEY; SO WE I LL AGREE THAT THOSE
15 Q, DID HE EVER SIGN A LOAN APP FOR THE PECK DRIVE 15 ARE NOT BEING CALLED FOR BY ANY OF MY QUESTIONS. OKAY?
16 PROPERTY? 16 A, (THE WITNESS NODS HEAD UP AND DOWN.)
17 A. I DON'T BELIEVE SO. 17 Q, DO YOU UNDERSTAND THAT?
18 Q- NOW, THE DOCUMENTS THAT WE HAVE MARKED AS 18 A, YES.
19 EXHIBIT 2, THIS STACK OF DOCUMENTS THAT COUNSEL 19 Q- OKAY. NOW, YOU WENT TO THE OPEN HOUSE, AND WAS
20 PROVIDED, DID THESE COME FROM YOU? WERE THEY YOUR 20 IT ON A SUNDAY OR SATURDAY?
21 PERSONAL FILE ON THE MATTER? 21 A, I DON I T KNOW WHAT DATE THAT WAS.
22 A. NO. 22 Q. WAS ON IT A WEEKEND, THOUGH?
23 Q. WHERE DID THEY COME FROM? 23 A_ IT MAY HAVE BEEN.
24 A. MY ATTORNEY. 24 Q- YOU WENT TO THE OPEN HOUSE.
25 Q- DID YOU PROVIDE THEM TO YOUR ATTORNEY? 25 DID YOU PICK UP A FLIER ON THE. PROPERTY?
NIVIE SAMAAN 7/10100

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NIVIE SAMAAN 7110,'1)6
310-372-1111 SOUSA COURT REPORTERS 714·571_0111
Page 2;
Pagt:2S
A. I BELIEVE I ALREADY HAD A FLIER. I HAD PRINTED
Q- DID YOU PREPARE THE OFFER?
IT OUT FROM THE MLS. A_ YES.
Q- DID YOU SPEAK TO THE PERSON WHO -- MR. LIBOW'S
Q- DID YOU DO IT AT YOUR OFFICE?
ASSISTANT THAT WAS AT THE OPEN HOUSE? A_ NO_
A. WE MAY HAVE SPOKEN.
Q- WHERE DID YOU DO IT?
Q. DO YOU RECALL WHAT WAS SAID, IF ANYTHING? A. AT MY HOME.
A_ NO. I BELIEVE SHE JUST ASKED IF WE HAD ANY
Q- DID YOU HAVE THE FORM AT HOME?
QUESTIONS, OR SHE JUST EXPLAINED SOME OF THE PROPERTY TO A. YES.
US, AND THAT WAS IT.
Q- WAS ON IT YOUR COMPUTER, DR WAS IT A HARD COPY?
10 Q. DID YOU WALK THROUGH THE ENTIRE PROPERTY? 10 A, COMPUTER.
11 A. YES. 11 Q. OKAY. AND TAKE A LOOK AT PAGES S0002 THROUGH
12 Q- AT THAT TIME DID YOU DECIDE TO MAKE AN OFFER? 12 009. WOULD YOU LOOK AT ALL OF THOSE.
13 A. NO_ 13 WERE THOSE THE DOCUMENTS THAT COMPOSE YOUR
14 Q- WHEN DID YOU DECIDE TO MAKE AN OFFER? 14 OFFER?
15 A_ I DONIT KNOW. I DON'T RECALL. 15 A, YES.
16 Q, DID YOU AND YOUR HUSBAND BOTH WALK THROUGH IT? 16 Q- YOUR OFFER REQUESTED THAT THE SELLER CARRY BACK
17 A. YES. 17 10 PERCENT OF THE PURCHASE PRICE?
18 Q- DID ANYBODY ELSE ACCOMPANY YOU? 18 A. AT WHAT POINT ARE YOU REFERRING TO ON THE
19 A. NO. 19 DOCUMENT?
20 Q. AFTER YOU WALKED THROUGH AND BEFORE SUBMITTING 20 Q. PARAGRAPH 2-D ON PAGE 2, 0002.
21 THE OFFER, DID YOU DISCUSS SUBMITTING AN OFFER TO 21 OR WERE YOU GOING TO GET A SECOND DEED OF TRUST
22 ANYBODY ELSE 22 FROM A THIRD PARTY?
23 A, NO. 23 A, YES.
24 Q, -- WITH ANYBODY ELSE? 24 Q. SO YOU WERE GOING TO GET A FI RST TRUST DEED FOR
A-32
1,336,000 AND A SECOND TRUST DEED FOR 167, 000; CORRECT?
Exhibits Volume A
Laue . c:lt Mise
25
NlVlE SAMAAN 7/l01()(j
NO. A. 25
VOLUME A 40/210
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310-372-1111 SOUSA COURT REPORTER,
1----

III
Page29
3W-3 .uSA COURT REPORTERS 714-571-0111
Pa8c)U
A. I BELIEVE SO. Q. DID YOU KNOW THE PERSON WHO WAS HIS ASSISTANT
Q. AND YOU WERE GOING TO DEPOSIT $167,000 AT THE OPEN HOUSE BEFORE THIS TRANSACTION?
ALTOGETHER; CORRECT?
A. YES.
YOU SUBMITTED THAT OFFER ACTING AS YOUR OWN
(MR. ZERNIK LEFT THE DEPOSITION ROOM.)
BY MR. CUMMINGS:
AGENT; CORRECT? IF YOU CAN LOOK AT PAGES S0013 THROUGH S0015.
A. YES. DO YOU SEE THOSE PAGES?
WOULD IT BE CORRECT THAT YOU UNDERSTOOD THAT IN
THIS TRANSACTION, MICHAEL LISON AND COLDWELL BANKER WERE
YES.
NOW, IS THAT SOMETHING THAT YOU RECEIVED BACK
10 NOT YOUR AGENTS OR BROKERS? 10 FROM MR. LIBOW?
11
12
A. YES.
AND PAGE S0010 AND SOOll, DID YOU PREPARE THAT
11
12
A. YES.
OKAY. FIRST OF ALL, DID YOU SUBMIT YOUR
13 BUYER I 5 INSPECTION ADVISORY? 13 ON SEPTEMBER 4 r 2004?
14
15
A.
Q.
YES.
DID YOU SUBMIT THAT AT THE TIME YOU SUBMITTED
14
15
MR. STEIN: YOU'RE REFERRING TO 5002 THROUGH 9?
MR. CUMMINGS: YE5 .
16 YOUR OFFER? 16 THE WITNESS: YES.
17
18
A. YES.
NOW, DID YOU SUBMIT THAT OFFER IN PERSON TO
17
18
BY MR. CUMMINGS:
THEN YOU'VE GOT A RESPONSE BACK ON SEPTEMBER 10
19 MR. LIBOW? 19 BY IS THAT CORRECT?
20
21
A.
Q.
NO. IT WAS BY FAX.
ALL RIGHT. DID YOU CALL MR. LIBOW UP BEFORE
20
21
A. YES.
WAS THAT FAXED TO YOUR OFFICE OR YOUR HOME?
22 YOU SUBMITTED IT? 22 TO MY HOME.
23
24
25
A.
A.
I DON'T RECALL IF I CALLED HIM BEFORE OR AF'TER.
DID YOU KNOW MR. LIBOW BEFORE THIS TRANSACTION?
NO.
NIVIE SAMAAN 7/10106
23
24
25
TO YOUR RECOLLECTION, WERE THERE ANY FAXES FROM
MR LIBOW TO YOUR IN CONNECTION WITH THIS MATTER,
OR DID THEY ALL GO TO YOUR HOME?
NlvtE SAMAAN 7110/06
--------------------------------1
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310-372-1111 SOUSA COURT REPORTERS 714·571-0111
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A.
OFFICE.
I BELIEVE THEY ALL WENT TO MY HOME, WHICH IS MY WHAT DOES IT DO AS FAR AS THE DEPOSIT?
THEY WANTED TO INCREASE THE DEPOSIT.
Q. WELL, IT I S NOT THE GILLERAN GRIFFIN OFFICE?
NO, IT I S NOT, BUT IT IS WHERE I WORK OUT OF.
Q.
A.
WHAT DOES IT DO AS FAR AS THE LOAN TERMS?
READING WHAT IT SAYS, IT SAYS "LOAN TO BE
A.
YOU WORK OUT OF THERE FOR YOUR COSMETIC WORK?
NO.
FOR WHAT KIND OF WORK?
FOR MY REAL ESTATE WORK, IF I DID ANY
OBTAINED AT MARKET RATES AND TERMS."
NOW, DID YOU ACCEPT THAT COUNTER?
DID YOU ALSO RECEIVE MR. LIBOW AN ADDENDUM
9 TRANSACTION, BECAUSE EVERYTHING WAS ON MY COMPUTER AT
10 HOME. 10
TO REAL ESTATE PURCHASE AGREEMENT THAT HAD CERTAIN
01SCLOSURES?
11 Q. OKAY. NOW-- 11 A. YES.
12 A. BUT I WOULD ALSO DO COSMETIC WORK OUTSIDE OF 12 Q. AND YOU RECEIVED THAT ON SEPTEMBER 10, 2004;
13
14
BARNEY'S OF NEW YORK; SO I DID COSMETIC WORK, I GUESS
YOU WOULD SAY, OUT OF MY HOME.
13
14
CORRECT?
A. YES.
15 Q. NOW, YOUR OFFER WAS FOR 1,670,000; CORRECT? 15 Q. THEN BETWEEN SUBMITTING THE OFFER TO MR. LIBON
16
17
A.
Q.
YES.
THEN YOU RECEIVED A COUNTER OFFER, WHICH IS
16
17
ON SEPTEMBER 4 AND RECEIVING THE RESPONSE BACK FROM HIM
ON SEPTEMBER 10, DID YOU SPEAK TO MR. LIBOH?
18
19
ENTITLED "COUNTER OFFER NO.1. II
THAT'S PAGES S0014 AND -- S0014; CORRECT?
18
19 Q.
I DON'T RECALL. I MAY HAVE.
WOULD IT BE CORRECT THAT IF YOU DID SPEAK TO
20
21
22
A. YES.
Q. WHAT DOES THAT DO AS FAR AS OF THE PURCHASE
PRICE?
20
21
22
HIM DURING THAT TIME, YOU DON'T RECALL ANYTHING ABOUT
THAT CONVERSATION?
YES.
23
24
25
A.
Q.
A.
IT INCREASES IT.
TO WHAT AMOUNT?
1, 71B, 000.
NIVIE SAMAAN 1110106
23
24
25
NOW, AS WE GO THROUGH THE DEPOSITION, I MAY ASK
YOU FOR ESTIMATES ON TIME OR OTHER ISSUES.
DO YOU UNDERSTAND THE D1 FFERENCE BETWEEN AN
Exhibits Volume A
LeIter liIJ,MeS c5< MiSe
A-33
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--_... _----_...
310-312-1111 SOUSA COURT REPORTER. ,ill
Page}3
31{)') AJSA COURT REPORTERS 714·571·0111
Pag«J4
ESTIMATE AND A GUESS? NOW, S0016, WHAT IS THAT DOCUMENT?
A.
Q.
NO.
LET ME GIVE YOU AN EXAMPLE. IF I ASKED YOU HOW
A.
Q.
IT SAYS "COUNTER OFFER NO. I."
DID YOU SIMPLY SIGN THE: ONE THAT MR. LIBOW HAD
MUCH MONEY WAS IN YOUR WALLET, YOU MIGHT HAVE AN SENT YOU AND SEND IT BACK?
ESTIMATE. IF I ASKED YOU HOW MUCH MONEY WAS IN YOUR A. I SIGNED IT, AND I MARKED WITH AN "X," SUBJECT
ATTORNEY'S WALLET, I WOULD PRESUME THAT WOULD BE A
GUESS.
TO THE ATTACHED COUNTER OFFER. I SENT A COUNTER OFFER
ALONG WITH IT.
10
A.
Q.
WOULD THAT BE A FAIR STATEMENT?
YES.
OKAY. AND IF I ASKED YOU HOW LONG THIS TABLE 10
Q.
A.
Q.
AND THE ATTACHED COUNTER OFFER IS S0017?
YES.
THE ONLY SUBSTANTIVE CHANGE WAS THE CHANGE IN
11
12
13
14
WAS, YOU COULD PROBABLY GIVE ME AN ESTIMATE, BUT IF I
ASKED YOU HOW LONG THE TABLE WAS IN THE CONFERENCE ROOM
ON THE OTHER SIDE OF THE OFFICE THAT YOU'VE NEVER BEEN
IN, THAT WOULD BE A GUESS; CORRECT?
11
12
13
14
THE AMOUNT or THE DEPOSIT AND WHEN THE DEPOSIT WOULD BE
MADE?
A. YES.
Q. AND THE INITIAL DEPOSIT, DID YOU UNDERSTAND
15
16
A.
Q.
YES.
YOU'RE ENTITLED, IF YOU DON'T RECALL SOMETHING
15
16
THAT TO BE THE DEPOSIT AT THE TIME THAT YOU SUBMIT THE
OFFER?
17
1B
SPECIFICALLY, TO STATE YOUR RESPONSE IN TERMS OF AN
ESTIMATE, BUT I AM ENTITLED TO AN ESTIMATE, IF YOU HAVE
17
18
A.
Q.
I'M SORRy. I DON'T UNDERSTAND THE QUESTION.
I'M LOOKING AT S0017. UNDER ITEM C, IT SAYS,
NIVIE SAMAAN 7/10106
19
20
21
22
23
24
25
AN ESTIMATE. IF YOU DON'T HAVE AN ESTIMATE AND IT WOULD
JUST BE A TOTAL GUESS, I DON'T WANT THAT, AND I'M NOT
REQUESTING YOU TO EVER GUESS. OKAY? BUT I WILL BE
REQUESTING YOU TO GIVE ME YOUR BEST ESTIMATE BECAUSE
PEOPLE DO NOT RECALL THINGS WITH 100 PERCENT CERTAINTY,
AT LEAST MOST PEOPLE DON'T; AND, THEREFORE, IT IS NORMAL
fOR PEOPLE TO GIVE ESTIMATES.
NIVIE SAMAAN 7110/06
310-372·1111 SOUSA COURT REPORTERS 714-571-0111
Page 35
14 DAYS AFTER THE ACCEPTANCE; CORRECT?
19
20
21
22
23
24
25
"ITEM 2. INITIAL DEPOSIT TO BE 15, 000 WITH INCREASED
DEPOSIT OF AN ADDITIQNJI.L 15,000 WITHIN 14 DAYS FROM
ACCEPTANCE. "
WHEN DID YOU UNDERSTAND THE INITIAL DEPOSIT TO
BE DUE? IS THAT WITH THE ACCEPTANCE?
A. YES, THAT WAS MY UNDERSTANDING.
Q. AND THEN 15, 000 ADDITIONAL DEPOSIT WOULD BE DUE
-II
311l-312·1111 SOUSA COURT REPORTERS 71'·571·0111 I
Page 36
WHAT STOCK WERE YOU LIQUIDATING?
A. YES.
(MR. ZERNIK ENTERED THE DEPOSITIoN
ROOM. )
A.
THAT.
Q.
I DON'T KNOW. MY HUSBAND WAS DEALING WITH
WAS THAT STOCK THAT WAS IN ANY ACCOUNT THAT
BY MR. CUMMINGS: WE'VE REFERENCED BEFORE?
Q. DID YOU SEND YQUR COUNTER OFFER NO. 1 TO A. I DON'T KNOW.
MR. LIBOW WITH YOUR FAX THAT CONTAINED THE PAGES 50018
THROUGH S0021?
Q.
A.
WAS THAT STOCK THAT WAS OWNED BY YOU?
NO, I DON'T BELIEVE SO.
A. ARE YOU ASKING IF I ATTACHED HIS COUNTER OFFER Q. DID YOU SPEAK TO MR. LIBOW BETWEEN THE TIME
10 AS WELL? I HAVE 519 THROUGH 521. 10 THAT YOU RECEIVED THE COUNTER OFFER NO. 1 FROM
11 Q. THAT'S EXACTLY WHAT I'M ASKING. THEY'RE ALL 11 DR. ZERNIK ON SEPTEMBER 10 UNTIL YOU SENT YOUR COUNTER
12 STAPLED TOGETHER, AND I DIDN'T STAPLE THEM. 12 OFFER NO. 1 -- OR COUNTER OE"FER NO. 2 BACK TO MR. LIBOW?
13
14
A.
Q.
QKAY.
SO I'M JUST WONDERING
13
14
A.
Q.
I MAY HAVE. I DON'T RECALL.
WOULD IT BE CORRECT THAT IF YOU DID SPEAK TO
15 MR. STEIN: I'M THE ONE THAT STAPLED THEM. 15 HIM, THAT YOU DON'T RECALL THAT --
16
17
THE WITNESS: YES, HE STAPLED THEM.
BY MR. CUMMINGS:
16
17
A.
Q.
YES.
-- RECALL ANYTHING THAT WAS SAID ABOUT IT?
1B Q. I'M JUST WONDERING IF THIS WENT AS A PACKAGE 1B A. YES.
19 BECAUSE IT SAYS FOUR PAGES ON THE COVER SHEET, AND THEN 19 Q. NOW, ON PAGE -- YOUR COVER SHEET, ON 50018, ON
20
21
22
THERE'S THREE PAGES ATTACHED TO IT. AND I'M WONDERING
IF THIS PACKAGE FROM 50018 THROUGH S0021 WENT BACK TO
MR. LIBOW.
20
21
22
YOUR FAX, IT'S DATED SEPTEMBER 10, BUT I NOTE THAT ON
PAGE S0020, WHICH HAS YOUR NAME ON IT, IT'S DATED
SEPTEMBER 11, 2004, AT 6:00 P.M.; CORRECT?
23
24
A.
Q.
YES, I BELIEVE SO.
OKAY. AND YOU MENTIONED THERE, "I'M
23
24
A.
Q.
YES.
SO DID YOU SEND THIS BACK? DID YOU SEND PAGES
25 LIQUIDATING STOCK FOR THE DOWN PAYMENT."
NlVlE SAMAAN 7flOItXi
25 S0018 THROUGH 50021 BACK TO MR. LIBOW ON SEPTEMBER 11,
Exhibits Volume A
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A-34
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2004?
2004, HAD YOU EVER MET MICHAEL LIBOW?
A.
Q.
A.
Q.
PROBABLY SO.
THAT WOULD BE YOUR BEST ESTIMATE?
YES.
TURNING NOW TO PAGE 50022, DID YOU SEND THAT TO
A.
Q.
A.
Q.
UP TO THIS DATE IN TIME?
YES.
I DON'T BELIEVE SO.
SO WOULD IT BE CORRECT THAT ALL YOUR
6 MR. LIBOW ON SEPTEMBER 13? COMMUNICATIONS WITH MR. LIBOW HAD EITHER BEEN IN WRITING
A. YES. OR ON THE PHONE?
Q. AND YOU'RE GIVING A DEADLINE FOR THE ACCEPTANCE A. YES.
OF YOUR OFFER; CORRECT? Q. HAVE YOU TOLD ME EVERYTHING YOU RECALL ABOUT
10
11
A.
Q.
YES.
THAT DEADLINE BEING 12:00 P.M. ON SEPTEMBER 14,
10
11
ANY TELEPHONE CONVERSATION WITH MR. LIBOW UP THROUGH AND
INCLUDING SEPTEMBER 13, 2004?
12 2004; CORRECT? 12 A. I'M SORRY. REPEAT THAT.
13 A. YES. 13 Q. YOU MENTIONED THAT YOU HAD TOLD MR. LIBQW THAT
14 Q. THEN DID YOU HAVE UP TO THIS PERIOD OF TIME 14 YOU WOULD BE LEAVING THE COUNTRY TO GET MARRIED, AND
15 WHEN yOU SENT THE FAX OF SEPTEMBER 13, 2004 -- DID YOU 15 YOU WANTED TO GET THIS FINALIZED BEFORE YOU LEFT.
16 HAVE ANY CONVERSATION WITH MR. LIBaN? 16 A. YES.
17
18
19
A.
Q.
A.
I'M SURE I DID.
DO YOU RECALL WHAT WAS SAID?
NOT EXACTLY, BUT I'M ESTIMATING THAT I TOLD HIM
17
18
19
Q.
A.
Q.
HAD YOU TOLD HIM ANYTHING ELSE?
NO, I DON'T BELIEVE SO.
HAD HE TOLD YOU ANYTHING ELSE?
20 THAT I DIDN'T WANT TO BE DEALING WITH THIS WHEN I LEFT 20 A. I BELIEVE HE HAD TOLD ME THAT THEY HAD ANOTHER
21
22
OUT OF TOWN TO GET MARRIED; SO WE DID NEED TO TAKE CARE
OF THIS AS SOON AS POSSIBLE.
21
22
CLIENT THAT WAS INTERESTED IN THE PROPERTY, AND THEY
WERE TRYING TO DECIDE EETWEEN US, THAT THEY HAD ANOTHER
23 Q. WAS THAT ON THE PHONE? 23 COUNTER OFFER OR SOMETH ING.
24 A. YES. 24 Q. DO YOU RECALL ANYTHING ELSE THAT MR. LISOW HAD
25 Q. UP TO THIS DATE -- POINT IN TIME, SEPTEMBER 13,
NIVIE SAMAAN 1/10106
25 TOLD YOU OR YOU HAD TOLD MR. LISON UP THROUGH AND
NIVIE SAMAAN 7110106
- ...
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310-372·1111 SOUSA COURT REPORTERS 714-571-0111
Pagc:4Q
INCLUDING SEPTEMBER 13, 20047 Q. DO YOU KNOW WHO YOUR HUSBAND WAS DEALING WITH?
A.
Q.
NO.
HAD YOU SPOKEN TO ANYBODY IN YOUR OFFICE --
A.
Q.
VICTOR PARKS.
WHO IS VICTOR PARKS?
YOUR OFFICE MEANING THE GILLERAN GRI FFIN OFFICE --
REGARDING THIS TRANSACTION UP THROUGH THE TIME PERIOD aF
SEPTEMBER 13, 2004?
A.
Q.
A.
THE LOAN OFFICER.
WHO DOES HE WORK WITH?
I DON'T KNOW. I BELIEVE HE WORKS FOR HIMSELF.
A. ONLY IF I WOULD HAVE HAD QUESTIONS ON WORDING Q. HAD YOU EVER DEALT WITH VICTOR PARKS ON ANY
AND HOW TO DO A COUNTER OFFER AND THINGS OF THAT NATURE MATTER PRIOR TO THIS TRANSACTION?
10
BECAUSE I HAD NEVER WRITTEN UP AN OFFER BEFORE; SO I
WOULD ASK MY BROKER ABOUT -- 10
A.
Q.
HE'S RELATED TO MY HUSBAND.
WHAT'S HIS RELATIONSHIP TO YOUR HUSBAND?
11
12
13
Q.
A.
Q.
DO YOU RECALL DOING THAT?
YES.
SO YOU RECALL SPEAKING TO RANDY SPAULDING ABOUT
11
12
13
A.
Q.
A.
THEY ARE COUS INS.
WHAT BUSINESS IS YOUR HUSBAND IN?
HE I 5 A MORTGAGE BROKER.
14 HOW TO DO A COUNTER OFFER? 14 Q. DOES HE AND VICTOR PARK WORK IN THE SAME
15
16
A.
Q.
UH-HUH.
IS THAT "YES"?
15
16
OFFICE?
A. THEY WORK ON THE SAME NETWORK.
17
18
19
20
A. YES.
Q. AND DO YOU RECALL TALKING TO HIM ABOUT ANY
OTHER ASPECTS OF THE TRANSACTION UP THROUGH AND
INCLUDING SEPTEMBER 13, 2004?
17
18
19
20
Q.
A.
Q.
A.
WHAT NETWORK IS THAT?
A COMPUTER NETWORK.
I MEAN DO THEY HAVE A JOINT BUSINESS?
I BELIEVE SO, YES.
21 A. NO, I DON'T BELIEVE SO. 21 Q. WHAT'S THE NAME OF IT?
22
23
24
Q. NOW, HAD YOU SPOKEN TO ANYBODY ABOUT OBTAINING
A LOAN FOR THE PROPERTY UP THROUGH AND INCLUDING
SEPTEMBER 13, 2004?
22
23
24
A.
Q.
A.
DELTA PACIFIC.
IS DELTA PACIFIC A MORTGAGE LOAN BROKER?
YES.
25 A. MY HUSBAND WAS DEALING WITH THE LOAN PROCESS.
NIVlE SAMAAN 1110106
25 Q. IS IT A CORPORATION?
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Leuer li1J,MeS Ot MIse
L

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Date: Tue, 19 Jun 200718:58:30 -0700
To: Todd_Boock@Countrywide.Com
From: jz12345@earthlink.net
Subject: URGENT: TIMED RESPONSE REQUIRED! RE: Normal Course of Business clarifications -
please respond by 6/22/07. 5:00pm
6/19/07
URGENT: TIMED RESPONSE REQUIREDI
RE: Normal Course of Business clarifications· please respond by 6/22/07. 5:00pm
Att Boock:
The following is not part of any discovery in this case, and you are asked to respond, but not as part of
discovery in this case:
1) Per Declaration of Loan Broker Victor Parks -
On October 18, 2004, he learnt from Countrywide* that Samaan's loan was approved. This was not
done through an Underwriting Decision/Condition Letter. In fact, such statement contradicted the
Underwriting Letter valid at that time (10/14/04), or later (up to 11/3/04).
If found true, would such statement by a Branch Manager be part of the normal course of business in
Countrywide?
2) Per Declaration of McLaurin -
Underwriting Decision/Condition Letter was issued on 10/26, 2004 in the name of Diane Frazier,
without hand signature of Frazier, and stating that the loan was suspended, where in fact on 10/25/04
following actions were taken by McLaurin herself to expedite approval of this loan against the
Decisions/Conditions what were set by the Underwriter:
a) Branch request for Exception Approval
b) Order for Review Appraisal.
Is issuing such Underwriting Letter, unsigned, in the name of an Underwriter who was no longer in
charge of the loan file, and contradicting the true state of the loan application part of the normal course
of business in Countrywide?
3) Per your production of documents:
Uniform Loan Applications (1003) had their date received stamps defaced, and new stamps affixed
with no documentation of who, when, why, and under what justification did it.
Is such done under as part of the normal course of business in Countrywide?
Joseph Zernik
* Countrywide here refers to CFC, Inc, and all its subdivisions and affiliates.
Printed for jz12345@earthlink.net
Exhibits Volume A
Letters, Email Notes & Mise
A -71
1
VOLUME A 79/210
Case 05-90374 Document 259-2 Filed in TXSB on 05/08/09 Page 2 of 35
• Page 7
--
June 21, 2007
ATIACHMENT#3
Adulterated, fraudulent Samaan's Uniform Residential Loan Applications (1003)
Exhibits Volume A
Letters. Email Notes & Mise
A-72
VOLUME A 80/210
Case 05-90374 Document 259-2 Filed in TXSB on 05/08/09 Page 3 of 35

unifort Residential Loan Ap'cation
This appllcaUon Is designed 10 be tompleted by1hs applicanl{s) Wilh ilia Lande(SassWance.1\jlJIliCalIts should t:>mplelll1/lis form as·Borro...."!" Dr"CO-Bon1lwe1", as
appicab1e, Co-IlOlTOwer Information mUll! olso 00 provided (and the appropriale box cIletkell) ..hen 0 lI>e InCllmB Dr assel5 0111 person .lher 1l1.. 1hs -eo""....,..
(lndudlng Itle Bonnwor's speU"") ",11 be usad ... a basis Illrloan quallficallon or 0 Olalncome or assets ofll\e .pause wig IlDt O. used a$ a basi. for loan
quaUfitallon. but bl$ or her Rabilliias must bet:>n.ldere.d t:ec:ause the Borrower resides In a ClImmlmlly psopelly s1ala. the securily property I. located In II oommunll)'
propelty 61ale, or ilia Bomlwer i••elying on oll\er property Illcated In ncommunlty pl1lpertym\e asa ba9l. forropaylllell\ cIlhe Io;Jn.
Omado Olobemado
SamBan
Pu/posll 01 RefJlt)nce
L TYPE OF'MoRTGAGEAND:rERMS OFLOAN,
oOther (eJqllaln); Agency case Nwnber
Nivle Sarnean
1,374;400
Tltl. will b. held In whal Name(s)
Puspose olloan pUIct1ase BConsIrucfon Oille. [explaIn):
o RafinilOOl ConSUUcion-Permanent
Completolhlsline II this Is D Il!r",ance lo.n.
Voar Original Cos! Am.unl Eldsting Uens

CampJer.thiSIino/l consrroctIon 0' constructIon-pormanent loan.
Y""r Lol Original Co.t nl ElclsUng Uens la) Pl1lSllnl VaJueofLol
Acqulmd
Es1Dte will ba bold In:
FeD Simple
---'-------------lI'Lnasehold
Checklng/Savlngs (__IOn ....)
Amount
S
Co-I!gllil\W(S Name Jr. o. Sr. II e.ppIIcallI8)
... Scl1Dol
1227112 S. Alfred Str.et
Los Angekls, CA 90035
MaIllng il dUi",enllmm Present Ad<1rass
Unuid"rng Of pnlsent DddfDss 'or/cs$lh
F""""r Acldn!ss (suceL ciIy,ltate. ZIP)
.Bo!towilr
Name II IeS$ of Employer
SpeUbaund Enterprise, Inc.
133 S. Peck Drive, Suite 104
Boverly Hills, CA 90212
g:
VB. Form... Addnlss (streel,
NT'INFORMATION "
rs.onllllsjoD Name &Ad<lrenof Employor
4yr(sl
VIS. employed In this
Une or wlHl<IprofO$$lon
20
VI5. employed n!hls
DnD"r""rI<Iprolesslon
Po!llllo II )'It' 0/ Business
President
Business P_(Incl. area cod.)
If .mp/oyad/11 <:umurtpo$/UOII for Ie"" IhMll'wo orHr:mrrmtlyomployod III mol'&than onepa.lUon fcHoWing'
Name 80 _s01 Emplcyl!' o Sell Emplcyl!d
Dales (f",,,,,Io) Name &AddtessalEmplO)'9l'
OselfEmlllo!'ed
Dates (tram-to)
MllIIlhIylncomo Monlhlylncomo
S S
PaslllDnlnUeITyJle of Business
... PlIo.....f
llld
•aoea code)
POSilioltlTlUeIType of Business
IBUSlness Phone onct, ""'" code)
NameII Address 0/ Employe. o Self Employed
Dates (lllltIHD) NllIIIl! & Address Of Employar o Sell Employed Datl!s (lmm-'o)
Monti'JyIn""",,, Monllllylncomo
S S
PosltionfJil1elType of Buslness rUSinoss.Phone (Incl........ <:ode)
PoslUDnfTlDelTl'lle 01 Business IBlIlilness Phone (inel. area coda)
Fl1Iddie..,.o Form 65 OTIlM
Cl>Iyx Fonn 1003 Lllo,_1.lrm 01J04
Computer Generate9ll\1e10/4
Handwritten 1003
Bcrrowet
Co-Ilo _
fennlo"", Fann 1003 01104
Exhibits Volume A
Letters, Email Notes & Mise
A-73
VOLUME A 81/210
Case 05-90374 Document 259-2 Filed in TXSB on 05/08/09 Page 4 of 35
Sell Empl "l"d BorroWillls) mll)'be ..qulredlo proride IlddlUea.. documenlaUonQO;h aslalC ..turns..,d r",orn:lalslDtements.
DO"5crlbo other In=rne NoUce: AUmcny, chHd-euppoft, orlap.tlle rnallrtenence Income need nat bo revealed If Ute
Borrower {B) or co.SOfTovmlCjdoc&not ohooselOlI..ell cllllSlderedfor ",p.yfng this I.....

..
I V. MONWiXINcOMEAND HOUSINGEXPENSE INFORMATION
"
I
Gros. Monlhly Income aorroWllf COaBorroW9r Total
Comblnud Monthly
Pnlscnt Proposed
Housing Expons.
Basa EmpllllCllme' S 33.333.00 S $ 33,333.00 Rent $ 3,390.00
Overtime Fu&t Morlgage(P&lj $ 6,299.33
llonuses other l'lnanclng (P&l) 1,128.60
Commissions Hazanllnsurance 400.87
Oivldendollnlerest Real EstateTaxes 1,189.58
Net Renlalllll:Ome Morlgeg: inswance
ather (...... """"'......" Ho"""""".......... Dues

....,-.........) other.
Total
IS
. 33,333.00 $ $ 33,333.00 Total $ 3.390.00 $ 9,818.38
.

VI. ·ASSETS AND LIABiLiTIES ..
ThisSlalemlllliandenyappucablo suppwtingschedoles m.ybecompleted[einIIy SOODa Illes ares cienUr
pinedsa thallll&Slalemenl canbemeanlnglu!lysndfailIyPresentsd oneccmblnBdbasls;ollla-. separaleStatamentssndSchodulesOlllroqulrecl.lflheCo-BoJTower
seclion was about aspo.... thIs Slatement and sUPPDrUng sdledules musl be completed about tIIal.pause aloo.
Completed DJoinlly IilJ Nol JolnUy
ASSETS CosII 0' M.rket
LlabDlU.. and Pledged A!Isl!ls. LIst til. nam.. addlus aa:ount nurnberforol oulSlilndlntl
OllscrlpUon Value dab\$, indlsding automobb Io&u, rnvalWO chalgo ilCtOU1I!!, mal 05lal!> Icam, alimony. clIi1d suppor1.
COsh dopasUtaMlItl puren... nold by: S
.Iol:k pledges. etc. Use conlinu.tion sheeL UlIl!alSSIllY.1ndicaIa by{') _eijabilitioswhldlwill be
Mara Escrow 30.000
Illti$lled upon ••1e 01 .....-ned or UPeJll rWlantlng of Illosubjec:l proPIfiY.
LlABIUTlES
Monthly Paymont &
Unpe/d Bolanco
Months I.llItIoPay
Usl chockJng anll slJVlng$ ••""U"'" belolY Nalllll and address of Company $ PlIJIIIlllnllMcnlhS S
Name and 01 Bonl<, S&L. or crean UnIOn FlRSTUSA
Walls Fargo Bank
POBOX291i20
P.O. BOl< 6995
PHOENIX, AZ 85038
Portland, OR 97228-&995
Al:cl. no. 433237001i1040372 197 9,870
Acct. no. 681-4098380 1$ 181,097 Nama and address of Company SPsyrnotltIMlllllhs S
Namo and address of Bani<, S&l., orcreall Union FSTENTRMNT
won. Fargo Bank
8735 FOREST LAWN
P.O. BOl< 8995
HOLLYWOOD. CA 90068
portland, OR 9722B·mS
At:<\. no. 9258401i00 266/60 9,033
Acct. no. 760.0184399 $ 82.326 Name end ad"""'. 0' Company $ PaymonllMlltIths S
Name and _,es. or Bant SaL, or credit Unlen WASHlNGTON MUlUAl. BANK
PO BOX1093
NORTHRIDGE, CA 91328
Acct. no. 1001000000000629063611 102 7,904
=no. S
Nameand a_ss of Compeny SpaymenllMcntll. S
Nama and address of Bank. S&L. or Credll UniOn cm
POB8241
SIOUX FAlLS, SO 87117
Al:cl. no. 642418069919 132 6,347
Acct. nO. S Name and adOres. 01 Company SPaymentlMonll1s S
Stow& Sonds (Companynemel S BARNEVSNY CRED CO
numbar &descriptionj U01 VALlEYBROOKAVE
LYNDHURST. NJ 07071
Al:cl. no. 60033556B2 114 1,477
Name end addfllSS 01 COmpany $
UI.lnsuran"" nat cash valua S
F=srnauntS 600,000
Subll>lal UquldA!r.lels $ 293,422
Real estala owned lentor mar1cet ValualS
Acct.na.
lromschedule ollila! esta19 OWMd) Name and 01 Company $ PayrnenlIM<II\IhS
::>
VCSIedInterest In IIlUlement fund $ 44,OOD
Net wol\!l of bUsiness<es) lIW\\ed S
500,000
(BIllIch finandal.1a1e1'nenl)
Automoblll!3 owned (make andY.'r) $
Acct. no.
Z002 Honda Accord Z6,000

S
..
Olller Assets (lIemize) S
Furniture 150,000 Job Related Expense (child care. \IllIan dues, elc.) S
JOWlllty 100.000
TOI., Monlhly PlIymenls $ 811
.. .. :
TolaIA!r.lets .. S 1,112,4Z2
ilot w0.n:;\
=>:1
5 1.077,791 Total UablIIU.. h. $ 34,631
I ammu;.-b .
FredWe ''''''' Form 65 01104
CoIyx Form 1003 LoonaPP2-frm 01,Q.!
Computer Generate9.;e z aI.
Handwritten 1003
IloITowot

Fsnnlo Mo. FcmI ,_ 01/ll4
Exhibits Volume A
Letters, Email Notes & Mise
A-74
VOLUME A 82/210
Case 05-90374 Document 259-2 Filed in TXSB on 05/08/09 Page 5 of 35
-
,
'-1 VI•.ASSETS AND l1ABli,m5$ (cent.),"
of Real EslJllo (If addltional propellles are ownoo. use oanlinUeliOn $lleeQ
Propelty Addnls. (enler Shold. PS if !>"ruling suJe Type of Presenl Amounlof I Gross Mcrtg.ge
0' Rif ,enlsll>elng held fo, income) Property Mark.1Value & Liens Remalll10ame Payments
Insurance,
Malnlenance. N.t
TI1Xi!S &Mlsc. Renlallneome
5 $ 5 $ 5
TQIsls 5
LIst any .ddlUonal n.m.... erOOll h.... baon meelve
An_male Name Nome
VII. DETAII.;$· OF· TRANSACTION· 'VIII,
p. Cash Immllo Bonower
(aubhatll, k,' &0 lrem
o 0 D
o 00
o &l 0 D
Bam:wm
Ye. No Yes No
o 00
o 00
o @J DO
00
00
00
00
00
DO
00 Olill



lilIo
DUD
lilIo
____________ Am)'01JaU.S. dlizen?
m.l.Ilenemounl 1,374,400.00 I<. Are)'O<lapermanent,..ldenIBllen?
(exclude MIP, Funding Fe. finan
,.....__:."......".":"__---+------III. Doyo. Int!lnd to""cupy tho propaJly DO yourpnmary ..sklDnee?
II. PM!. MIP, FlI1ding Foo financed ••.' _'".....t!oA.. below.
____________-----+-..,.-,===,.j,m. He•• vau had onownirShlp 11I1""'111I a propollyln 1h01a>tlhnleyclll$1
o. Lean OII\Dunl(add In & n) 1,374,400.00 (1) Whllllypo orplO!>"<tydkl 1'011 ClWll-Prlncipahesklente (PRJ.
oecond horne (St!). 0: II>1I'es1menI properiy (lP)?
169,916.33 (2) Hewd1d)'llu hold 1iIl.1J>1llellome-t»lO!t hy)'ClJlSlllrls),
)<lInIy willi spou,. ($P), orjalnllYwith onolher """"" [O)?
a, PurcIla._ S 1,718,000.00 1I,0u .""Wllt'Yes"lOenyquesUonsalhrough ple.s.uaaeonunuallon
h, A1la",Oons,lmprovemenls, reoairs aheet forOllplarlotton.
c. lan<l (hClllllred sepamleiy) a, _Ul."'.ny
d. Ralinanea [<ncl. dehl!llo he paid am h, tia.el'llU b _aredIlan!<lulJl v.1lhln \hep..l7 yea",?
e. Eslima1el!pmoaldilems 6,299.33 c.
I. Eslim.led cloolng oaSIS 21,816.00 In lhela>t7 yeass?
g. PMI. MIP. Funding Fe_ d. Are)'O<l • pally to._11
h. Discount Of Bonowerwlll pay) e. Havel"lU di<eeUy or Indlmc:lly been oblig.led en anylean whlch mulled In
l Totalcoslsladdlt.ms.throvghhl 1,746,115.33
SubonIinaietinanciJlg 171,800,00
to Bo.rrowefls closing costs paid by SeIler 1lfd18llcf lenaer, RiA crVACBAru@lt.IrIn1.l1ldtllUo1fl&bCllectiln)
l OlllarCredlIs(explain) l Areyou pl8$enUy delinquentorl<l de!aul10ll8<tyFederaldebl.runy01her
cash Deposit 30,000.00
9. _you 0l>Ii9D1lld 10pay .&m.ony, dIBd support, or separate maJn1eIlanee7
h. Is lI1'r/ 01 1110 d....npaymanll><lmmed'l
l Are J'OU aa><naker Of endorser on anote?
..

'x. iNF.ORMATlON FOR GO\lERliI/l!:tff:MONITClR!N.G ·PURPOSES

oppMunlty,falrhouslngandhlllllllmortgooed"osdosuralaws. YOUar&nolJ8!luinldl.fumisbl/ll5lnCllllIIlIIItm,hulareencoumgedtodos•• Thelawprcvldeslbalalendarmay
FOJ18te.


.n requirements 10 whlcll tho lander Is subjeclunder applll:allla state lIr"forlllaplll!jcular type ollean _ppIlOOlor.)
BORROWER 0 Id.not ...hlofuml.h 1hls I_.n CO-BORROWER 01de nolwlslJ III rUmw, Ihts InronnatJon
Elhnlclly: 0 I-Jlpllllle or l.eIInD (il] Nl>llli.panio or l.eIInD nlclly: 0 IfoponIeor l.alinD 0 Net HbpanIc or Latino
Raca: OAnlonca.lndlanor 0 AoIill1 OSbtcl<D' co: DAm_indian.. oAslan DSlaokor
AJ"l<DNa1Iw __ AAlsteaNo1lvo AJrican",""""",
ONalivo_.. li!J WbllD O_HAwal""" OWhlIo
OIhc<POdfi1:IoID_ Olhotl'ildlic_.
Sox: li!JI'llmDlo Sox: OF_ oMala
TOheComplo:1edhylnlllrvlaww Inl!! Nameancl_. of Inlerview..... Employer
ThIs epplieallon was laken by. Pacific Mortgage Consultants
OFace-to-Iace InteJVlew 1DD larlcspurLandlng Circle tn:15
OMan larkspur. CA 94939
IXlTelephone (p) 888-575-5693
olnlemol IF) 310049G-3256
fllldlSo MDO Fcrm es 01104
Folm 10D31.oDnapp3.frm 011D¢
Computer Generat".,.J
Paga 3 014
Handwritten 1003
FlIMl. Mao Fonn 1D1l3 01J04
Exhibits Volume A
Letters, Email Notes & Mise
A-75
VOLUME A 83/210
Case 05-90374 Document 259-2 Filed in TXSB on 05/08/09 Page 6 of 35
• Page 8
June 21,2007
ATTACHMENT #3
Adulterated, fraudulent Samaan's Uniform Residential Loan Applications (1003)
Samaan's Uniform Loan Application 1003 represents fraud on many levels, induding fraud perpetrated by Samaan, Lloyd and
Parks, and fraud perpetrated by collaborators inside Countrywide, San Rafael, during the time of Underwriting, and then additional
fraud perpetrated during preparation of the loan file for subpoena, apparently both in San Rafael and in the Legal Department in
Las Virgines, where Sanford Samuels is Chief Legal Counsel.
The document would be deemed in violation of both Countrywide's own policies and Federal law and regulations: Therefore,
Countrywide, knowingly has kept in place a Branch Manager who was implicated in gross violations of Fair Housing and Fair
Credit State and Federal Laws.
Therefore, the Legal Department under Sandor Samuels made a conscious decision to allow deceit of the Court and fraud against
Zemik to proceed unabated, to allowZemik to lose his home and his life's savings, and to protect the Fraud Perpetrators, Branch
Manager, Maria McLaurin, Borrower Samaan, her husband, Mortgage seller Lloyd, and Mortgage Broker Parks. The alternative,
that is providing the true information, would require honest examination of management practices in the San Rafael Branch,and
beyond that in the Wholesale Division. and probably require reporting to Regulatory and Stock Exchange agencies.
So far, the Legal Department under Sandor Samuel stuck to the first alternative. This document is written in the hope that the
President of Bet Tzedek - House of Justice, will decide to dean house.
ELEMENTS OF FRAUD IN SAMAAN'S UNIFORM LOAN APPLICATIONS 1003
When was the application submitted? Was it submitted once, twice, three times?
1. Date Received stamp was adulterated, but Countrywide Legal Department could not or would not explain by whom,
when, where, why, and under what authority. Leaving such adulterated document unexplained is in violation of
Countrywide's policies and banking regulations.
2. Many documents indicate that the loan was allowed to be continuously reviewed longer than permitted by Regulation B,
through manipulation of the Date Received data. That may be the reason that the Legal Department would not answer
questions in this regard.
3. The Legal Department refused to produce in response to legal subpoena any documentation of the correct Date(s)
Received of Samaan's loan application. Records of the Date(s) Received must be found in multiple reports as part of
compliance with Regulation B, e.g. in Pipeline Reports for the relevant months - September, October, November 2004.
PrOViding such a date of course would refute Samaan's claims, and may result in immediate dismissal of the case. It may
also incriminate both Samaan and McLaurin, but at present both are shielded by Countrywide's Legal Department
Who prepared the loan application? Was it ever prepared by Loan Broker Parks whose signature is affixed to it?
4. The signature on the 1003, purported to be Parks' does not show any resemblance to that of Loan Broker Victor Parks as
it appears in his dedarations in court. It is unlikely that he ever signed the Application.
5. Parks most likely never prepared the 1003 either. In the 1003 Parks is listed as the telephone interviewer, but Samaan
stated in deposition that the loan broker never even talked with her
7. Samaan stated in deposition that her husband, Jae Arre Lloyd (Formerly Timothy Lloyd Morrow) who does not hold any
relevant license, and probably is prevented from ever holding any such license, was the one who prepared the
applications. That would be in violation of the law, and in violation of Parks' Broker's License.
8. That Loan Application, prepared by the newly-wed husband listed his wife as an Unmarried Woman. If indeed their claim
to have been married in September was true, this false statement is in violation of laws and regulations in a Community
Property State such as California, and could potentially derail the Closing of the Escrow.
Was there any basis in reality to the financial and income data entered in the application?
9. Samaan. according to her bank statements and credit reports: at the time made her living on the Payroll 'of a department
store as a cosmetics saleswoman. But on the 1003 she claimed that she was the President and Sole Owner of a
corporation - Spellbound Enterprise, Inc - for at least 4 years, with no other employment, and with income of $400,000
per year.
10. That corporation was established less than a year earlier, and according to its web page, engaged in web retail sales of
products followers of the psychic and the occult - "The Supernatural Superstore" - providing Tarot cards, divining objects,
anointment oils, and crystal balls. But when asked by a probing Underwriter to provide business license or tax documents
for Spellbound, Samaan produced a document issued to Trades/Professions, probably for her occupation as a
beautician.
Exhibits Volume A
Letters, Email Notes & Mise
A-76
VOLUME A 84/210
Case 05-90374 Document 259-2 Filed in TXSB on 05/08/09 Page 7 of 35
• Page 9
June 21, 2007
The legitimate Underwriter saw through the fraud, but McLaurin undercut her authority and allowed fraud to be
accelerated. Why is the Legal Department protecting the perpetrators of fraud in expense of Zernik?
11. Subsequently, the Underwriter issued a Condition that Samaan declares "Type of Business" in the space provided in the
1003. Samaan would not comply with this condition, and Mclaurin would not try to enforce it either.
12. As clearly indicated in the Clues Expert System report and also in conditions set by the duly assigned Underwriter
Diane Farzier, this application had some of the cardinal signs of fraud - discrepancies in employment, in residence, in
source of income, in source of funds.
13. In addition, Credit Reports find Samaan listed in fraud alert data bases.
14. The explanation applicant provided for discrepancies in residence statements as part of Verification of Residence were
deemed unacceptable by Underwriter. Indeed these were false statements. For example, while in one document
Samaan describes the apartment in Beverly Hills as new large office space for her growing corporation, in another
document she describes it as a cramped apartment where she moved in with her husband and his daughters.
15. Telephone numbers provided by the applicant did not match up in reverse look up with other business and residence
information provided.
The evidence is clear that McLaurin submitted Fraudulent Exception Request to Demetrio Gadi in Division Underwriting
Support. Whey is the Legal Department trying to hide that?
16. When the loan was not approved by the Underwriter, McLaurin filed an Exception Request where the income was
"erroneously" increased 1G-fold, from the fictitious $400,000 to $4,000,000 a year
17. In same Exception Request- Branch Input by McLaurin, credit determinations made by the Clues Expert System
and the duly assigned Underwriter Frazier were turned upside down by McLaurin. Poor became Excellent, without any
foundation, in violation of both Countrywide's policies and State and Federal Laws and Regulations. These violations are
of course obvious to the Legal Department, and were also pointed out in Meet and Confer by Zernik.
18. The Exception Request - Branch Input in and of itself, issued prior to Samaan's submitting valid Loan Applications,
was in violation of the Decisions/Conditions set forth by the duly assigned Underwriter, Frazier. But the Exception
Request Approval by Demetrio Gadi instructed McLaurin to uphold the Branch Underwriter's Decisions/Conditions. The
Exception Request Approval also states that if information presented in the Branch Input was not true, than the
approval was null and void. Therefore, the Exception Request was never valid, but McLaurin was trying to expedite the
funding.
19. Similarly - Demetrio Gadi, who no doubt knewthat the whole request was a charade, instructed McLaurin to obtain
Independent Mortgage Insurance for this loan, which he apparently considered unusually risky. McLaurin never
obtained such insurance, but proceeded as if the loan was approved free and clear.
20. The whole loan file shows nowhere any signature that even resembles Parks' true signature as it appears in court
documents.
21. In the Loan file was prominently missing Broker's signature on the Broker's Certification document - that the documents
were true copies of the originals. The duly assigned Underwriter set forth an Approval Condition that Parks must sign that
standard form. Parks never signed it, and McLaurin never enforced that condition either.
22. Given the many deficiencies, starting with absence of valid Loan Applications 1003, and ending with missing Broker
Ceritifcation, and many suspicious documents and conflicting data entries, the Underwriter set a condition that Appraisal
Review not be performed prior to Corporate Approval. McLaurin violated that Decision/Condition on the first day she
usurped Underwriting authority, Octohber 25, 2007 - McLaurin proceeded to order Appraisal Review, and never enforced
the Decision/Condition that Samaan must submit valid Loan Applications 1003. That was of course in gross violation of
Countrywide's policies and also in violation of State and Federal Fair Credit and Fair Housing laws and regulations.
23. Given that Samaan still never submitted a valid application by the time McLaurin filed for Exception Request - Branch
Input, one can only guess how McLaurin made her Underwriting Determinations. Most likely those credit determinations
were made off the top of her head. (Excellent, Good Loan). Making such false credit determinations is of course in
violation of Countrywide's policies, and also in violation of State and Federal laws and regulations.
24. In order to discredit the valid credit determinations of the duly assigned Underwriter, Frazier, and the Clues Expert System
McLaurin claimed that the Frazier's Clues report Was based on error in data. In fact, 'Frazier did not make her
determinations based on Clues Report alone, but also backed them up with handwritten calculations, which she
documented in the Loan File. McLaurin, in contrast, made no attempt to substantiate her credit determination with a
revised Clues Report, neither did she present any hand written calculations. She just made up credit determinations as
she pleased, in violation of the law and Countrywide policies.
25. The legal department of Countrywide must understand all of this very well at least since August 2006, when they had to
prepare the first Subpoena production. If not then, at least since December 2006, when Zemik explicitly explained to the
Legal Department his findings regarding fraud by Mclaurin relative to Samaan's loan applications. Such fraud or
attempted fraud would also be Material Deficiency given the executive position of McLaurin, who by some estimates
was approving investments at approximately $50m per day all backed up by
Exhibits Volume A
Letters, Email Notes &Mise
A-77
VOLUME A 85/210
Case 05-90374 Document 259-2 Filed in TXSB on 05/08/09 Page 8 of 35
• Page 10
the Federal government!
June 21, 2007
How many of these loan applications were like Samaan?
We may only guess. In phone interview, the duly assigned Underwriter, Diane Frazier, explained that she was one of only three
Senior Underwriters in San Rafael at that time, that McLaurin was applying pressure on them to approve funding of substandard
loans, since McLaurin benefited from large bonuses based on volume of loans funded. Therefore, a system was created where
there was constant pressure to fund bad loans, but no negative implications for loan defaults, or bad Underwriting decisions. Still
the Underwriter explained that some of these loan applications, like Samaan's - which was basically entirely invalid, made the
Underwriter uncomfortable. In such cases, the loans were approved through the special track, described above for Samaan's
loan. The Underwriter estimated those loans at 1 in 20. That could translate into $2.5m in extremely fraudulent loans per day, or
$500m per year for one Branch Manager!
Why were particularly bad loan applications from particular brokers attracted to particular branches?
We will probably never know.
Why did Branch Manager McLaurin fail to enforce real interest rates on Samaan, in fact giving her over $10,000 discount in
reward for an exceptionally bad loan application?
We will probably never know.
There is no indication that any of these violations and material deficiencies were ever reported to regulatory agencies as required,
even as suspicions, or internal investigations that deared those involved from any suspicios. There also is no evidence that the
attomeys in the Legal Department reported such concerns to supervisors, as required by the aftermath of Enron and the Sarbane-
Oxley Act
26. Instead, the Legal Department, in arranging the production of documents in response to subpoena, tried to make the
impression that there was only one loan application submission, on October 12, 2004. In response to direct questions in
this regard they adamantly denied that there was more than one submission of these loan applications. They also denied
that there is any data elsewhere in Countrywide that could confirm or refute that daim. In fact, the Legal Department of a
giant publidy traded corporation was busy covering up violations by McLaurin, Branch Manager, who in conspiracy with
Samaan, Lloyd, and Parks, were engaged in fraud against a Federally backed mortgage lender. With that, the Legal
Department was also busy ensuring the Zernik not obtain any evidence that would allow him to find out the true facts in
this matter, or prove his case in court.
IN FACT, THE LEGAL DEPARTMENT IN COUNTRYWIDE, HEADED BY SANDOR SAMUELS WAS AND IS AN
ACCOMPUICE IN FRAUD AND IN A CONSPIRACY TO DECEIVE THE COURTS AND DEFRAUD ZERNIK OF HIS
PROPERTY AND HIS UFE SAVINGS.
Exhibits Volume A
Letters, Email Notes & Misc
A-78
VOLUME A 86/210
Case 05-90374 Document 259-2 Filed in TXSB on 05/08/09 Page 9 of 35
• Page 11
June 21, 2007
ATTACHMENT #4
Unauthenticated, invalid Underwriting Decision/Condition Letter, October 26, 2006
Exhibits Volume A
Letters, Email Notes & Mise
A-79
VOLUME A 87/210
Case 05-90374 Document 259-2 Filed in TXSB on 05/08/09 Page 10 of 35
------------------
COUNTAYW[DE HOME LOANS, INC.
Bmkoc;
r1ICflA!::lo Ul\,l1ES O'?$rI.I.i: DW\ PACIFlC
HORTGlIGl!. CONSULTANTS
Bl;anch f: 0000933
VICTOR PARKS
750 LXNDI\RO S1:R5E. au 110
--'----'----------------
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Exhibits Volume A
Letters, Email Notes & Mise
A-80
VOLUME A 88/210
Case 05-90374 Document 259-2 Filed in TXSB on 05/08/09 Page 11 of 35
Low! 61731375 Bom>won "'"""" ---::.SlllW\N:..::::=:..:.,-:.:M:,:IIl,;..I:::;E=--....,.. _
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Exhibits Volume A
Letters, Email Notes & Mise
A-81
VOLUME A 89/210
Case 05-90374 Document 259-2 Filed in TXSB on 05/08/09 Page 12 of 35
• Page 12
June 21,2007
ATTACHMENT #4
Unauthenticated, invalid Underwriting Decision/Condition Letter, October 26, 2006
1. This document would be deemed in violation of both Countrywide's own polides and Federal law and regulations. For
example, the Underwriting Decision/Condition Letter contradicts Countrywide's policy on fax usage - Outbound
Faxing - Loan Decision/Condition Letter and Fee Sheet (SLG), or Document Retention policies, and also in violation
of the Federal Regulation B:
2. This letter was never produced by Countrywide's Legal Department in four (4) subpoenas from August 2006- February
2007. Those four subpoenas were each represented as the complete loan file and complete response to the sUbpoena's
request, but in fact, these productions of documents were. a concerted effort by Countrywide's Legal Department to cover
up and protect a criminal Branch Manager (white collar crime is crime).
3. During the same period, in November 2006, Maria Mdaurin, Branch Manager, San Rafael Wholesale Branch, felt free to
submit to court a signed letter, on Countrywide's letterhead, together with the Underwriting document attached here, in
support of Plaintiffs groundless daims. Mdaurin's contribution was critical in effecting Deceit of the Court and Fraud
against Zemik in that Court Motion (November 2006). It appeared that the first time the letter was seen by the Legal
Department was when I presented it to them in early April 2007, in Meet and Confer following the 2007 production, and
requested that they explain its relationship to the loan file.
4. In response to Zernik's demands, the Legal Department produced the end-tip of email correspondence between Plaintiffs
husband, Jae Arre Lloyd (prior to 2003 named Timothy Lloyd Morrow), who appeared to be on personal basis with
McLaurin, and Plaintiffs Counsel, Att Keshavarzi, where they ask her help in produdng support for Plaintiffs position in
court. All of them are aware that there is no valid authentic document to support it, and they concoct a fraudulent
document to deceive the court. Previous to that, Plaintiffs position was that Zernik's daims regarding an inordinate
relationship between Plaintiff and McLaurin, which was the background for the irregularities in the Underwriting of this loan
was a "conspiracy theorY'.
5. Claims made by Plaintiff and McLaurin, Countrywide Branch Manager relative to this document, in effect endorsed by the
Legal Department through acqUiescence and stonewalling, induded the following:
1) The Letter was a valid Countrywide's Underwriting Decision/Condition Letter.
/n fact:
It was not signed by a duly appointed Underwriter, in violation of Countrywide's own policies
It was not part of the Loan file
It was represented as if issued by Diane Frazier, the duly assigned Underwriter of this loan. But by October 25,
2004, Maria McLaurin, Branch Manager, usurped the Underwriter's authority and acted relative to this loan in
violation of Decisions/Conditions previously set forth by Diane Frazier.
2) The Letter was dated October 14, 2004.
In fact:
it was dated October 26, 2004, when escrow was already canceled.
3) The Letter indicated that the loan application was suspended on or about October 14,2004
In fact:
It was dated October 26, 2004, when escrow was already canceled.
The Letter never mentioned any suspension on October 14, 2004
On October 26, 2004 the loan application was never suspended either. On the contrary, starting October 25,
2004, and in violation of Underwriting Decisions/Conditions, McLaurin was expediting approval of this loan
(among other ways - by stating a $4,000,000 annual income for the applicant - a cosmetics saleswoman in a
department store
4) The Letter indicated that the loan was suspended by Countrywide because of missing Zemik's initials or
signature on the Purchase Agreement
In fact:
The first time Plaintiff faxed a Purchase Agreement to Countrywide as part 'of her·loan application, was October
22, 2004 (Closing Date was November 1, 2004f), and that copy, a strange collection of pages, was missing her
signature on the Purchase Agreement, page 8, which is required to establish a valid offer, and her initials on the
final counter offer (in this case - Counter Offer No 2), paragraph 8, required to conclude execution of the
Agreement, as Acknowledgement of Acceptance). And there is no mention of Zemik's name in any Underwriting
Decision/Condition Letter before or after October 26, 2004
Exhibits Volume A
Letters, Email Notes & Mise
A-82
VOLUME A 90/210
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bettzedek.org 6/20/07
Bet Tzedek Website Contact Us I Volunteer I Donate Online
)
Call Bet Tzedek
By Sandor Samuels, BT Board President 2006-2007
Whom do you call if you are elderly and someone is trying
to evict you from your apartment or your house? Whom
do you call if you are a holocaust survivor and are being
denied your rightful reparations? Whom do you call if you
need to care for an abandoned grandchild or niece or
nephew? Whom do you call if you live in a nursing home
and are being denied appropriate care or treatment?
And whom do you call if you are being denied your rightful
wages or are being forced to work in substandard
conditions?
The answer to these and other legal problems afflicting the
poor and the elderly in our community iliXlhimtsJ);){tjh.t;rlftf1\
TZEDEK. I'm proud to be the an organization.
I'm especially proud of Bet Tzedek new outreach campaign that we conducted
on March 17th and 18th.
VOLUME A 91/210
Case 05-90374 Document 259-2 Filed in TXSB on 05/08/09 Page 14 of 35
:cram oe"C"CZeaeK. a r ~ bj "L,Uj U-'
WELCOME NEW BOARD PRESIDENT
We would like to congratulate and
welcome new Bet Tzedek Board
President Sandor E. Samuels.
Sandor E. Samuels
Exhibits Volume A
Letters, Email Notes &Mise
A-84
6/20/2007
VOLUME A 92/210
Case 05-90374 Document 259-2 Filed in TXSB on 05/08/09 Page 15 of 35
Sandor E. Samuels is Senior
Managing Director and Chief Legal
Officer for Countrywide Financial
Corporation (NYSE: CFC), a
diversified financial services
provider and member of the S&P
500. He also serves on the
Executive Committee of
CountryWide FinanCial Corporation.
As the organization's Chief Legal
Officer, he oversees the
transactional, regulatory and
litigation affairs of Countrywide and
advises senior management on
legal issues. Samuels' previous
executive positions at CountryWide
include Managing Director, General
Counsel and Secretary. He joined
CountryWide in 1990.
A 1974 graduate of Princeton
University, Samuels received his
law degree in 1977 from the School
of Law at the University of
California, Los Angeles. After
graduating from law school, he
served as Law Clerk for U.S. District
Judge Irving Hill.
Samuels is a member of the Board
of Directors of the University of
Judaism, Ziegler School of Rabbinic
:3 Studies, Bet Tzedek Legal Services
- and Adat Ari EI synagogue. He also
E of the Legal
of the Mortgage
Mff8rica.
A -85
VOLUME A 93/210
Case 05-90374 Document 259-2 Filed in TXSB on 05/08/09 Page 16 of 35
I
HOME PAGE FOR THE WORLD'S BUSINESS
LEADERS

Free Trial
Issue
MARKETS ENTREPRENEURS LEADERSHIP PERSONAL FINANCE FOR
Bonds Commodities Currencies Economy Emerging Markets Equities 01
Countrywide Financial Corp. I Executives
Click on column headers to resort, click on executives'
names to view people details.
1 - 21 of 21
Total cash
compo at
Name Title Age CFC
Mr Kevin W Bartlett Managing Director/Other Executive 49
Officer
Henry G Cisneros Director 59
Jeffrey M Cunningham Director 54
Robert J Donato Director 67
Carlos M Garcia Managing Director, Divisionial 51 4,846,391 USD
Mr Marshall M Gates Chief Administrative 55
Officer/Managing Director
Mr Andrew Gissinger III Managing Director, Divisionial 47
Mr Ranjit M Kripalani Managing Director, Divisionial 47 6,887,416 USD
Ms Anne D McCallion Managing Director/Other Executive 52
Officer
Martin R Melone Director 65
Laura K Milleman Chief Accounting Officer/Managing 46
Director
Angelo R Mozilo Founder/CEO/Chairman of the 68 48,133,155 USD
Board/Director
Robert T Parry Director 67
Oscar P Robertson Director 68
Keith P Russell Director 61
David Sambol President/COO/Chairman of the 47 11,965,711 USD
Board, Subsidiary/CEO, Subsidiary
Sandor E Samuels Managing Director/Other Executive 54
Officer
Mr Jack W Schakett Managing Director/Other Executive 55
Officer
Eric P Sieracki CFO/Managing Director 50 2,606,045 USD
Harley W Snyder Director
Exhibits Volume A
74
Jeffrey K Speakes
Managing &1!Misc
,
A-86
ihlink.net
VOLUME A 94/210
Case 05-90374 Document 259-2 Filed in TXSB on 05/08/09 Page 17 of 35
From biz.Yahoo.coJI!. 6/20/07

EDGARbnline
COUNTRYWIDE FNL CP
Officer
NYSE:CFC
profile, SEC, other insiders)
8-May-07
149,167 Direct
Insider & restricted shareholder transactions reported over the last two years
8-May-07 24,936 CFC
Option Exercise at $11.68 per share.
(Cost of $291 ,252)
2-Apr-07 12,222 CFC Acquisition (Non Open Market) at $0 per share.
13-Feb-07 365 CFC Disposition (Non Open Market) at $0 per share.
2-Feb-07
2,220 CFC Disposition (Non Open Market) at $45.03 per share.
(Value of $99,966)
15-Nov-06 750 CFC Disposition (Non Open Market) at $0 per share.
27-0ct-06
Sale at $38.20 per share.
39,500 CFC (Proceeds of $1,508,900)
25-0ct-06 25,044 CFC
Automatic Sale at $38 per share.
(Proceeds of $951,672)
4-Aug-06 12,522 CFC
Option Exercise at $6.77 per share.
(Cost of$84,773)
3-Jul-06
12,522 CFC Option Exercise at $6.77 per share.
(Cost of $84,773)
Exhibits Volume A
Letters, Email Notes & Mise
A-8?
VOLUME A 95/210
Case 05-90374 Document 259-2 Filed in TXSB on 05/08/09 Page 18 of 35
48,990 CFC Option Exercise at $5.80 per
(Cost of$284,142)
l-lun-06 12,522 CFC
Automatic Sale at $38 per share.
(Proceeds of$475,836)
I-May-06 12,522
CFC Automatic Sale at $40.26 per share.
(Proceeds of $504, 135)
19-Apr-06 26,344 CFC
Automatic Sale at $38 per share.
(Proceeds of $1 ,001,072)
18-Apr-06 23,744 CFC
Automatic Sale at $38 per share.
(Proceeds of $902,272)
15-Nov-05 11,008 CFC
Automatic Sale at $35 per share.
(Proceeds of $385,280)
2-Sep-05
6,000 CFC Option Exercise at $5.80 per share.
(Cost of $34,800)
l-Aug-05
6,000 CFC Automatic Sale at $35.80 per share.
(Proceeds of $214,799)
l-lul-05
6,000 CFC Automatic Sale at $38.88 per share.
(Proceeds of $233,280)
Exhibits Volume A
Letters, Email Notes &Mise
A -88
VOLUME A 96/210
Case 05-90374 Document 259-2 Filed in TXSB on 05/08/09 Page 19 of 35
JosepI'I ZelrJiIcINIIIIJfIhIJ 320 South Peck Drive, B e v e ~ y HilisCA 90212 Tel: (310) 286-9567 Fax: (801) 998-0917 Cell: (310) 435-9107
URGENT! TIMED RESPONSE REQUIRED! TIME IS OF THE ESSNECE!
EMAILED TO ANGELO_MOZILO@COUNTRYWIDE.COMANDSENTVIA CERTIFIED MAIL
June 23, 2007
Mr Angelo Mozilo, Chainnan
Intemal Audit Committee
Countrywide*
RE: Samaan v Zernik, Samaan's lSI Lien Loan Application #8137375
Dear Mr Mozilo:
I am approaching you as Chainnan ofCountrywide's Internal Audit Committee, demanding actions to mitigate harm
and damages to Zemik by Countrywide, and to prevent further fraud perpetrated by San Rafael Branch Manager Maria
McLaurin and her associates.
In 2004 Zemik listed his residence in Beverly Hills for sale. Nivie Samaan made an offer, which was eventually
accepted by Zemik. As later uncovered, Samaan was never qualified to purchase the Property. She was a cosmetics
saleswoman who fraudulently represented herselfto Zemik as a realtor who closed several deals a year, and who
fraudulently represented herself in her 1003 (Attachment #1) as solely deriving her income as President of a
Corporation. Her Prequalification Letter was a product offraud and an instrument of Fraudulent Inducement to obtain
Zemik's consent to the Purchase Agreement.
Maria McLaurin, Branch Manager, buyer Nivie Samaan, buyer's husband and McLaurin's friend Jae Arre Lloyd
(fonnerly Timothy Lloyd Morrow), and his cousin and business associate Victor Park, alI operating in the field ofreal
estate and mortgages, initiated in 2004, several types of fraud, alI related one way or another to the pending sale ofmy
residence. McLaurin and Lloyd were most likely well versed in mortgage fraud, but this fraud scheme did not work on
schedule - approval ofthe 1
51
Lien Loan #8137375 was considerably delayed, possibly because Lloyd and McLaurin
were trying to outdo themselves this time and issue a fraudulent jumbo mortgage, with no documentation, and at
reduced interest rate. The latter proved more difficult than anticipated (Attachment #,2,#3, #4).
Following Samaan's failure to perfonn, and the realization, on several accounts, that she was not dealing honestly,
Zernik issued Notice to Perfonn, and later, after Samaan refused to perfonn, he issued Instructions to Cancel Escrow.
A year later, in 2005, once the price ofthe Property considerably appreciated, Samaan filed claims for Specific
Perfonnance, and placed lis pendens on the Property. Samaan's claims initially appeared unsustainable and absurd,
but false and fraudulent statements and documents (Attachment #5) brought or supported by McLaurin kept the case
in court for the second year now.
I demand your help in mitigating the damages resulting from unlawful, fraudulent conduct of Maria
McLaurin. To mitigate damages, and to help in stemming the ongoing fraud and deceit perpetrated against
Zernik, please persona"y ensure that I am provided by Friday, June 29, 2007, 5:00pm, a declaration by an
authorized officer of Countrywide, outlining relevant details shown below (Attachment #6).
Sincerely,
) . ~
Joseph Zemik
* Countrywide here refers to CFC, Inc and all its subsidiaries and affiliates
Exhibits Volume A
Letters, Email Notes & Mise
A-89
VOLUME A 97/210
Case 05-90374 Document 259-2 Filed in TXSB on 05/08/09 Page 20 of 35
• Page2
March 14,2009
ATIACHMENT #1
Adulterated, fraudulent Samaan's Uniform Residential Loan Applications (1003)
Samaan, with full support from Countrywide's Legal Department, would have us believe that
Samaan's 1003 was first received on 10/12/04. The Legal Department refused to provide any
explanation for the defaced (presumably older) Date Received stamps found on all 1003's, and the
duplicate "Date Received" found on all 1003's.. ..
Exhibits Volume A
Letters, Email Notes & Mise
A-90
VOLUME A 98/210
Case 05-90374 Document 259-2 Filed in TXSB on 05/08/09 Page 21 of 35
• Page3
March 14,2009
Unitor! Residential Loan Aplcation
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Exhibits Volume A
Letters, Email Notes & Mise
A-91
VOLUME A 99/210
Case 05-90374 Document 259-2 Filed in TXSB on 05/08/09 Page 22 of 35
• Page4 March 14,2009
1,1/19.18
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Exhibits Volume A
Letters, Email Notes & Mise
A-92
VOLUME A 100/210
Case 05-90374 Document 259-2 Filed in TXSB on 05/08/09 Page 23 of 35
• Page5
O'UI/ot

Computer Generatet.-....
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March 14,2009
..-.- _ ....- .... ;::... =
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Exhibits Volume A
Letters, Email Notes & Mise
A-93
VOLUME A 101/210
Case 05-90374 Document 259-2 Filed in TXSB on 05/08/09 Page 24 of 35
• Page6
March 14, 2009
ATIACHMENT #2
Underwriting Decisions/Conditions Letter of October 14, 2004
This Underwriting Decisions/Conditions Letter, dated 10/14/04 requires that Samaan resubmit
Uniform Loan Applications (1003) with the correct interest rate applied to the requested loan,
following true and correct Loan Program guidelines.
Countrywide's Legal Department would have us believe that this was the first underwriting
consideration of this loan application, and accordingly made false representations in subpoena
productions, while refusing to provide any explanations for conflicting evidence.
But the loan file does not lend itself to coherent interpretation under those premises. Moreover,
based on information received from the underwriter, it is apparent that the 1003 was first submitted
earlier than October 12, 2004, and was "resubmitted" on October 12, 2004, by defacing the earlier
Date Received stamp, affixing a new "Date Received" stamp instead, and scanning it again as a
fresh arrival. The legal department refused to provide any explanation for the finding of defaced
stamps and duplicate stamps on all 1003's.
Exhibits Volume A
Letters, Email Notes & Mise
A-94
VOLUME A 102/210
Case 05-90374 Document 259-2 Filed in TXSB on 05/08/09 Page 25 of 35
Ilrancl> .' 0000933
7SO LINllAAO S1'1lSll1' S'l:'E 110
SllN l'J\I'UJ.. c:A 9U01
'bone' (US) 257-2701
II" p..,. No., (415)259-08116
• Page 7 March 14,2009
_ Il1Clll\l1I. JJ\IISS 0' lIEltiLYDllA eACli'IC
-
COr.1o<t VICTClR P1lI\KS
-
_.,
........
SQ_llllD by. FU.#; .. _
Du.m: FAAZI£R l0ll4m04 p • ;.fq(p. r-{" !1fi6. tt7j..
11118lstolllfOrm you t111lt your IlllIJl swmls$IOll was nwl!lWed lit the_listedbdom
817313n _._.""SJlHl\lIIl==:L'_It::.IVt"'=Il'- _
Pu;'poso: :l'1JI\CIlASll,_ OCClIl!IED,llEDUCllD
Slort_ 5.500 _T_ 60 L'lV: ,,80::.·:..;,0;.;:0'- _
lOANMIOUNT: 1,3'4.400.00
Subj....t to tba spac>.tte CQl1<l.!.tio"" U"tod belo", .... wiUbe able to "l'?""""
your 10iOn "libels"i"". Po", 1011. subftlS.ssioos, pan<ll.nq final approvlll, "" change
in ttle berr"""" Is) finanCial ,t..tus or _loyment ..1l0 """ur, and the ere<lit
doe.......,U and appraisal must .,""'..... current.
10 IlVOL:! 1l1l"ill9 1'OUl': s\lbOU.eeion el"sod for iilO_"et_u, any items U.ated
1>910>< as 'l\eepUrl!d Prio., to lIpproval' muse be received "ithio 10 day... of the
dAt6 shown ..
C<A1d_et Plm.., 2· AppmvaI, 17
10/1412004
Exhibits Volume A
Letters, Email Notes & Mise
A-95
VOLUME A 103/210
Case 05-90374 Document 259-2 Filed in TXSB on 05/08/09 Page 26 of 35
• Page 8
• •
March 14,2009
IlOCU!£lITJI
-
_s
0ft:Il
FWI):t!lG OI'ElI/
mmII1G Ol'£lI
l'UllllIllG OPEN
I11NllIIlG 0PE11
l'UllllIllG 0l'&lI
twl):tI!(l i)P£Il
ADDENDUM TO UltDE:RWfUI1NG PCClSlOl'lJCOWmON l.ETTEfl
(pAGU OF2 )
$1, 71a, 060 prog*'_ at cost 't;o b%w.t, d:l:!::J:: C)_lin" flftti"':'
..wp .,vovld-
0&4, C:OUlSe:ran/SX_ 1003 lA-I l.cel(-nHIATE)
'- __ t;ytJ<> of ...""
0_ COllIlnIOIl 6
VOR pre.eM; l:"e51c.nc."'t ;r;eq'd f02: 2nd
CllL/llEfi' Al'l'iU\ts;u, (HlP
U ""t; flmd.e4 loy UJ:l ,,_de a .w.".b)' Qld: ..... ""oerlO
010. lU'l'RAISIlL-N!l?IIl\!SEII ro l!ROYIIl"& CIIlUIEIlT I.1_
I1rwilloo abo All _tl.<ll>o>l ....< of col"" pbotb.
028. _ CERrInc:aTIOlt = lIU. COl':a:S .l\lIl nm: lIND COllII£t;T
017. allf.OC - COPI Ol' "lIST liOlI7<lAG&
C...c:urrect .1...... with 2D<1 .1: n 7UOO • pr""ide co""
093. I __IIST£/SIGllllIl roN! t506 J 95-01
14.0. __nOll'
cellO¢. s400 _a..l...l Ueld r."i... iN frOll brwr io ncro"
FIlIWNCllIII/
.. -D£llISillWCOIllOloltJn"h!A
2CllfOllS(GllIJCI

Exhibits Volume A
Letters, Email Notes & Mise
A-96
VOLUME A 104/210
Case 05-90374 Document 259-2 Filed in TXSB on 05/08/09 Page 27 of 35
• Page9
March 14,2009
ATTACHMENT #3
Clues Report, October 14,2004
The Underwriting Decision/Conditions Letter of October 14, 2004, and respective
underwriting determinations, were based on this legitimate Clues Report and additional
manual calculations and investigations, fully documented by the duly assigned Underwriter,
Exhibits Volume A
Letters, Email Notes & Mise
A-97
VOLUME A 105/210
Case 05-90374 Document 259-2 Filed in TXSB on 05/08/09 Page 28 of 35
• Page 10
• •
March 14, 2009
CLUES LOAN ANALYSIS REPORT
- CLUES -
Countrywide Loan Underwriting
Expert System
Loan Report
Date:
Credit Decision:
Thursday, October 14. 2004 11:49 AM
REFER
Loan Number: 81737375
Credit: Acceptable (MERGE-CREDIT)
Ability: Questionable
PrOdU.ct Compliance, __
Documentation: :::::>
Appraisal Eligibility: Standard Full Appraisal or 2055 I&E,
with an additiona1 Pield Review
Ability:
The information provided indicates a combination of layered risk
factors which may include insufficient liquid assets, high LTV,
credit history, and/or high debt ratios for the loan program
selected.
This loan has been referred by CLUES due to the following reasons:

compliance- GeneraJ.:
A minimum of 6 months reserves are required on the Non-Con! ARM Fixed
Period LlBOR Interest Only program. (18869),
Reduced documentation is not allowed on a Non-Conforming Mega Loan.
{lS172).
The max loan amount is $3.,000,000 on Non-Conf ARM Fixed Period LIBOR
Interest Only loans. (5998).
Borrower: Nivie Samaan
property Address:' 320 S Peck Dr
Beverly Hills, CA 90212-3715
. Loan program Name: Ne 5/1 LIBR ARM InterestOnly
Loan Type:
Loan Purpose:
Loan Program 10:
conventional
Purchase
657
Loan Amount!
Cashout Amount:
. $ 1,374,4()(l
n/a
Exhibits Volume A
Letters, Email Notes & Mise
A-98
VOLUME A 106/210
Case 05-90374 Document 259-2 Filed in TXSB on 05/08/09 Page 29 of 35
• Page 11 March 14, 2009
Exhibits Volume A
Letters, Email Notes &Mise
A-99
VOLUME A 107/210
Case 05-90374 Document 259-2 Filed in TXSB on 05/08/09 Page 30 of 35
• Page 12
March 14, 2009

•• •
l'a.ek ''ife. 04. .211
l!'A1J5iI:i!!tJls :E'ale'" VJ!(t. Ii Oil .1M, ul01120(li 12 iiI1 I
D'Ul'1tJH:.hJ.N {1$$.
klhllcibllcm::Ito!LC: BU.ClClOSlI (:I'll)
Ref1!reIlQll CC1;",l;PGi; POS13
1M" (In;
aILn'Y
'cmtlIr'
JU'E'rJl.tsltL
I
Dcc1.s:!.an.
:t:lIIIttll
:r.c.u YIU:,.iou:
POClJl.

N/'"
m
;!,O ;J,4 ;g QQ4
C
Exhibits Volume A
Letters, Email Notes & Mise
A -100
VOLUME A 108/210
Case 05-90374 Document 259-2 Filed in TXSB on 05/08/09 Page 31 of 35
• Page 13
March 14,2009
ATIACHMENT #4
EXCEPTION REQUEST- BRANCH INPUT BY MARIA MCLAURIN, 10125/04, AND
EXCEPTION APPROVAL BY DEMETRIO GADI, DIVISION UNDERWRITING SUPPORT,
10129/04
This fraudulent Exception Request-Branch Input, dated 10/25/04 submitted by Maria McLaurin on
that date to Division Underwriting Support. In and of itself it constituted a violation of the
Conditions/Decisions set forth in the Underwriting letter of 10/14/04, since Samaan had never
provided a revised, correct 1003.
In this Exception Request- Branch Input, McLaurin listed Samaan's annual income at $4,000,000
per year. The document shown here shows a blatant adulteration, whereby the printed income
figure was eliminated, and an new income figure was entered by hand. Despite repeated
requests, the Legal Department refused to provide a true and correct printout from the system
without the hand-written correction.
This Exception Request- Branch Input contained credit determinations that had no base in the true
facts in reality. These credit determinations were made without obtaining a true, valid 1003
Uniform Loan Application, and without running a Clues Report.
In addition, this Exception Request- Branch Input by Maria McLaurin attempted to undermine the
credibility of the true and correct determinations by the duly assigned underwriter, Diane Frazier.
McLaurin's Exception Request falsely and misleadingly stated that the Clues Report of 10/14/04
was in error.
Exception Approval by Demetrio Gadi, dated 10/29/04, included (but was not limited) to the
following conditions, none of which was satisfied:
a) that data provided to him in Exception Request - Branch Input was true and correct, and
b) that all conditions set forth by the local branch underwriter be upheld, and
c) that Samaan provide a new, correct 1003 with the applicable interest rate applied to the loan,
and
d) that a new Clues Report be then generated, and
e) that the branch issue non-delegated Mortgage Insurance at branch expense for this loan.
Exhibits Volume A
Letters, Email Notes & Mise
A -101
VOLUME A 109/210
Case 05-90374 Document 259-2 Filed in TXSB on 05/08/09 Page 32 of 35
• Page 14
March 14,2009
EXCEPTION REQUEST· BRANCH INPUT BY MARIA MCLAURIN
10/25/04

WLD EXCEPTION FORM - BRANCH
INPUT r
tJCti
"6::tr319793 .
Qealedon 1012512OQ402:59PM by MadaMc:l.aIlril'llKrisIlJlOrlon
1
0/d.5 I J3d-.5
I using COli Wov.llh.150%addIDfee for Doc
FIleln8nmi:h
Yll$
I E!rllJ1 Qh Infllrmeticm
8nmcll Number
I
Region
I
8mneh COnlact
I
CoJllactexL e""Jlell Requeslor
0000933 8S Marla mclaurln 2103 krisUn
ortonIWLDlCF/CCl
BP Informallon
BP Soume cede
I
BPNarne
I
09894 Pacillc Mortgage
COIl$Ultants
1,31·4,400.00
Loa" Informs
N
[Jves
LTV CLTV Ml
No
2IIC1uenoraw
Amolll'll:
$171800.00
AfIlIIlIIsaIValIle
1.71ll,OOI),l11l
PlOjleItySlaIe
CA
Property-,.ype
SFR
::: __u_e_-JIL.-__v: __ ..l-I__SPos_eIf_EmpIoyedI_lic>nITllllI>_. ----I
Exhibits Volume A
Letters, Email Notes & Mise
A -102
VOLUME A 110/210
Case 05-90374 Document 259-2 Filed in TXSB on 05/08/09 Page 33 of 35
-
• Page 15 March 14, 2009
EXCEPTION APPROVAL BY DEMETRIO GADI, DIVISION UNDERWRITING SUPPORT,
10129/04

Demetrio GadllWlOlCF1CC1
10l29f200410:46AM

To Kri&til OrtonMll.DlCF/CCI@Counlrywida
cc MllltaMoLaulinlWhclesaleICFlCCl@COUNTRYWIDE
bc¢
Subject Exception Certlfioale~ Result: Final ApprovalflSamaanI
JUMBO'
PRINTTHISDOCUMENT FORTHE LOAN FILE
excePTION REQUEST RESULT: FINAL APPROVAL
Reasonfor Oecllne:
Termsof Counteroffer:
...............u" **,. * , u ~ _ " " " ' .
Pricing Informallon: /
1st MIg Risk·Based AcIcI-on: 0.750
Applies To; Fee
2nd MIg Risk-Based Add-on:
Applies To:
: The 'Ri&k·based add-ons' posted above, do not contain adjusllnentsfor: lowloan amount. escrow
waiver. oon+Approve. 45-day and grealer re1Inance.1.TV>60 and F i ~ (Cont only}. or TAMI
tncenllw, Before quoting Pfk;e. whereW8rraJlt$d, addthe appropriate adiustments for these
cllaracterlslles toWholesale Pricing Desk'Risk-based add-ons' above.
Priclng Commenls: Demetrio Gacll,10f29J2004 10:20:37AM-';>Based onthe current loao characteristics
noted on this form. standard add-ons must beapplied as disclosed In ed.ge plus the base pricemust be
adjusted by 0.70 piafor Enhanced 8OIllO reduced doo..
Borrower Nl!me: NMe Samaaol JUMBO" Braoch Number: 0000933
PropertyAddress: 320 S. PeckDrive, Beverly HIlls. CA
Braneh Requestor: IttlsIin ortonlWlDlCF1CCI
OlllelTlme R ~ 10J25J2004 02:59 PM DaleIT1me DecIsion: Demetrio
GadI,10J29J20041G:29:01 AM->Finsl Approval
"•.'"'-"."11I' ..n.u _ ..,. · u · "' "' , '• .... it ** ''''''iIi'....

1.oao Purpose: Purchase Cashollt Amount:

Exhibits Volume A
Letters, Email Notes & Mise
A-103
VOLUME A 111/210
Case 05-90374 Document 259-2 Filed in TXSB on 05/08/09 Page 34 of 35
• Page 16

March 14,2009

1st UenAmount: 1,374,400.00
Appraisal Value: 1.718,000.00
2nd Loan Amount: 171.800.00
PropertyType: SFR Doc Type: Reduced 000
LTV: 80.00% CLTV: 90.00%· Ml:No
••11I... "••••••"",.",,,••U*.iLlt.*••••iZl4 "", •••",Ul"""_""."••". :L, a.' ""44th'''''' III , , * , til." * ilI
Excepllon Request Delalls:
: 80190 to 105Musing Core Jumbo wIth .750%add to fee for Reduced Doc
KrIstinOrton,1012512004 3."08:49 PM,;>9ormwer's Income Should Be $33,333Not $333,333
Michelle Pettl,10121lJ2004 3:03:14 PM->Recelved loan file today
DemetrioGadl,1012912004 10:29:57AM->File is approvedwith noeXQep!lons under the Enhanced 80190
program•
...i ••' "' ""** , nJ:.uiil.UU' l•• It ..!
Conditions:
/PR10RTODOCUMENTS (PTO) CONDITIONS/ BRANCHTOREVIEW&SIGNOFF
/ ..-FIeld reviewbyCHl approved reviewappraiser to be ordered bybranch suPPOt1lng valu" of no Iesslhan
S1,718,000
Satisfyall branoh underwriting conditions &all CLUESoondltlons
CLUES10be ac:curate at close based on 'linal EPS
aualilyVerifk:atlanand DollUltlElOtatlooChecldlst completed and executed by underwriter
,I')L ~ -Lelterftomco-owner of Wells Fargo account #6814098380 stating relationship 10 borrower and that
~ bon'OWeI' has unrestricted aooess to all funds
;tk.tI--.("-AppraiserwllhAGor ARdesignatiOn to oo-sign appraisal &mark boxIndicating"Did Inspect Property"
~ C a l r l 1 y REOon credit report· 5353SenVicente Blvd
PRIORTO FUNDING(PTF) CONDlTlONS/:BRANCHTO REVIEW&SIGN OFF
-""..-aorroweratoslgnldate4506-1
---COpyofiinrtmartgage note for 2nd tdfile
..-<-'1st&2nd td's to oIose concurrent
NOTE: clear toclose
: Reduced doc, purchase,5I1 Ubor 10, Enhanced 80190, 1st to $1,374,400 &belao$171,800; no
exc:eption
GU10EUNE excePTIONS
Exhibits Volume A
Letters, Email Notes &Mise
A-104
VOLUME A 112/210
Case 05-90374 Document 259-2 Filed in TXSB on 05/08/09 Page 35 of 35
• Page 17
March 14, 2009

IF ALL CONDITIONSABOVE ARENOTMETTHIS EXCEPTION IS NULLANDVOID!
THIS ISAN EXCEPTIONDECISIONONLYAND NOT ALOANAPPROVAL
"This represents the risk-based add-ons for the loan program. AU other
add-ons such as CWBCfee, escrowWfli\lerfee, etc. will still apply, as
applicable.
Branch Entty Screen - > ~
Exhibits Volume A
Letters, Email Notes & Mise
A -105
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VOLUME A 206/210
Case 05-90374 Document 259-5 Filed in TXSB on 05/08/09 Page 24 of 27
VOLUME A 207/210
Case 05-90374 Document 259-5 Filed in TXSB on 05/08/09 Page 25 of 27
VOLUME A 208/210
Case 05-90374 Document 259-5 Filed in TXSB on 05/08/09 Page 26 of 27
VOLUME A 209/210
Case 05-90374 Document 259-5 Filed in TXSB on 05/08/09 Page 27 of 27
VOLUME A 210/210

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