113632+WHITE.BRIAN+061411 0001 1 2 CASE NO.

53-2007-CA-007222-0000-WH 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 0002 1 2 3 4 5 Attorney for NATIONSTAR MORTGAGE, LLC 6 7 8 9 10 11 12 13 14 15 16 17 18 19 MICHAEL ALEX WASYLIK, ESQUIRE Ricardo, Wasylik & Kamuk PL Post Office Box 2245 Dade City, Florida 33526 352-567-3173 Attorney for HENRY REDILLO A/K/A HENRY REDILLO, SR. Tuesday, June 14, 2011 2:51 p.m. - 4:03 p.m. Esquire Deposition Solutions 4927 Southfork Drive Lakeland, Florida 33813 --------------------------------------------Defendant(s). _________________________________/ DEPOSITION OF BRIAN WHITE PAGE 1 - 61 NATIONSTAR MORTGAGE, LLC, Plaintiff, vs. HENRY REDILLO A/K/A HENRY REDILLO, SR., IN THE CIRCUIT COURT OF THE TENTH JUDICIAL CIRCUIT IN AND FOR POLK COUNTY, FLORIDA

REPORTED BY: Evelyn M. Adrean, RPR, FPR Notary Public State of Florida at Large Esquire Deposition Services - Tampa, Florida 813-221-2535 (800-838-2814) Job No.: 228291 APPEARANCES: RIA SANKAR BALRAM, ESQUIRE Law Offices of Marshall C. Watson, P.A. 1800 NW 49th Street, Suite 120 Fort Lauderdale, Florida 33309 954-453-0365

ALSO PRESENT: Henry Redillo, Defendant Page 1

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I N D E X DEPOSITION OF BRIAN WHITE Direct Examination by Mr. Wasylik Cross-Examination by Ms. Balram Redirect Examination by Mr. Wasylik Certificate of Reporter Deposition Errata Sheet Certificate of Oath DEFENDANT'S EXHIBITS DESCRIPTION Affidavit of Lost Original Document 66-Page Collection History

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The deposition of BRIAN WHITE was taken pursuant to Notice by counsel for the Defendant on Tuesday, June 14, 2011, commencing at 2:51 p.m. at Esquire Deposition Solutions, 4927 Southfork Drive, Lakeland, Florida 33813. Said deposition was reported by Evelyn M. Adrean, RPR, FPR, Notary Public, State of Florida at Large. - - - - - - - - - THEREUPON: THE REPORTER: Raise your right hand, please. Do you swear or affirm that the testimony you give today will be the truth, the whole truth and nothing but the truth? THE WITNESS: Yes. BRIAN WHITE, a witness, having been duly sworn to tell the truth, the whole truth and nothing but the truth, was examined and testified as follows: DIRECT EXAMINATION BY MR. WASYLIK: Q Good afternoon. We've briefly been introduced a moment ago. My name again is Mike Wasylik. I am the attorney for the defendant, Henry Redillo who is present here with me, and you here with your counsel. We are here today pursuant to a notice of rescheduled deposition, the scheduling coordinated with your lawyers. You are here -- or we have requested the presence of a corporate representative for Nationstar Mortgage with the certain designated areas of knowledge Page 2

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113632+WHITE.BRIAN+061411 with respect to this case. And you are here pursuant to that notice, I take it? A Yes. Q Can you please state your full name for the record. A Brian White. Q And Mr. White, what is your employment? A What's my function? Q What is -- yes. A Or who do I work for? Q We'll start with what is your function. A I'm a default litigation -- default litigation. Q And is that your title? A Yes. Q And with who are you employed? A Nationstar Mortgage. Q And as a -- in the course of your duties in default litigation, what is your relationship to this particular file? A We own the file, we own the note. Q By "we," Nationstar? A Nationstar owns it. Q Now, the deposition here today is unlike a deposition where I'd be taking the personal testimony of a particular witness. We've noticed a corporate representative to that, and we've asked that you be the witness with areas of knowledge that we've designated in our notice. We are actually taking the deposition of the corporate plaintiff in this case, and you are the physical flesh and blood embodiment of that person. As such, when I asks questions, I'm not necessarily for questions that are related to your personal knowledge although we do expect that you have done the preparation necessary to be able to answer the question. I am asking for the knowledge and position of the corporate plaintiff. Generally speaking when I ask you a question, I am going to be asking for the position, knowledge, information of the plaintiff, that being Nationstar. Do you understand that? A Yes. If I'm able to answer, then I will answer and do so. Q And with respect to any question that I ask you, if it's unclear whether I'm asking more the knowledge of the plaintiff or your individual knowledge, if it's a big issue at all to you, please let me know, I will clarify. A Okay. Q And to that extent, if there's any question I ask you that's at all unclear or ambiguous, please let me know, I will clarify. A Okay. Q Okay? And I don't know if you've had your deposition taken before, we'll get into that in a moment. But today I'm going to ask you a series of questions about the case, and you will answer hopefully to the best of your ability. And, you know, if at any time you need a break to talk to your lawyer, for personal comfort, for whatever reason, go ahead and let me know. This is not a water boarding session, we're just here to get information about the case. Page 3

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113632+WHITE.BRIAN+061411 A That's fine. Q Okay? All right. Do you have any other questions about what we're going to undergo today? A No. Q All right. What is your specific connection to this mortgage loan that is the subject of this litigation? A Can you clarify that? Q Yes. Other than today's deposition, do you have any role in overseeing the mortgage loan that is the subject of this litigation? A In a function -- clarify further, please. Q Any role at all. MS. BALRAM: Objection to the form of question. If you ask a specific question, he'd be able to give you a specific answer. It's kind of vague. BY MR. WASYLIK: Q Well, let's start with the day-to-day function. What is your day-to-day involvement with this loan? A Again, clarify the question. Q Let's go back. Let's go back and talk about your duties as in default litigation. What specifically are your duties? A Specifically, my duties entail that I attend at trial, I attend at depositions, I review the note, review the mortgage, review the figures, review -review the account in and of itself. Q Prior to receiving today's -- the notice of deposition for this deposition, had you done any review of this particular file? A Yes. Q And when was that? A When did you -- when did you send us notice or on this? Q The original notice was approximately two months ago. It was April? MS. BALRAM: No. The notice that went out was on, I believe, the 9th of April. When I requested Brian to attend the deposition, is what -THE WITNESS: It was in April or -MS. BALRAM: No. Sorry, June. THE WITNESS: June, okay. So we -- let's see. This was early June some time. BY MR. WASYLIK: Q Okay. Prior to that, did you have any involvement with this specific loan file at all? A No. Q Okay. Now, I see that you have a copy of the notice in front of you; is that correct? A Uh-huh. Q All right. The areas of knowledge that we've requested are set forth in that notice. No. 1 asks for a person of knowledge of the facts asserted in the pleadings. Are you the person for Nationstar who'd have the best knowledge of the facts asserted in the pleadings? A At this very moment, yes. Q Can you tell me what preparation you have done Page 4

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113632+WHITE.BRIAN+061411 to answer questions related to the facts asserted in the pleadings? A I the pulled note, I pulled the mortgage, I pulled what documents are available to me, I have reviewed account histories, reviewed paid histories, went through the account in general. Q Did you review the complaint? A Yes, I did. Q Did you review any answer to the complaint? A Not aware that I did. Q Did you review any other court paper with respect to No. 1? A More specifically? Q Okay. Did you -- besides the complaint, did you review any of the other pleadings that have been filed in this case? A More specifically what? Q Well, I've asked you as to the answer, and you said you don't remember. Okay. Have you reviewed any amended answer? THE WITNESS: Ria? MS. BALRAM: I'm sorry? BY MR. WASYLIK: Q Did you -A I've told you what that I've reviewed. If it's regarding an answer, to my knowledge I've not reviewed an answer. I am familiar with the complaint, I'm familiar with the outline of the status of the account. Q Okay. With respect to area of knowledge number 2, we've asked for a person with knowledge of the facts asserted in any affidavit submitted by the plaintiff. How did you prepare for today to answer questions about that area of knowledge? A Again -MS. BALRAM: Object to the form. Specific questions, please. BY MR. WASYLIK: Q Did you review any documents, specifically affidavits, with respect to -- I'm sorry, let me withdraw that. In order to prepare to answer questions about the facts asserted in affidavits submitted by the plaintiff, did you actually review any affidavits? A Affidavits, no. I didn't have interrogatories to review. Q I didn't ask you about interrogatories, I asked you about affidavits. A Right. Typically prior to depositions, I actually have something to review provided to my counsel with regard to what opposing counsel is prepared to ask other than five points represented within the notice of deposition. I wasn't allotted very much to prepare for. Q I see. So when you received this notice of deposition and you saw that we were asking for a person who had knowledge of facts asserted in affidavits submitted by the plaintiff, which is Nationstar, did you determine that any investigation was necessary as to what facts were asserted in those affidavits? MS. BALRAM: Objection: Form. Please be specific. MR. WASYLIK: All right. Let me be perfectly Page 5

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113632+WHITE.BRIAN+061411 clear. THE WITNESS: Yes. MS. BALRAM: Please. THE WITNESS: Please. BY MR. WASYLIK: Q When I ask for a witness who has knowledge of facts asserted in the affidavit, normally the people who are responding to that have actually reviewed the affidavits that the plaintiff has submitted to the Court. And what you're telling me is, that hasn't happened in this case. MS. BALRAM: The affidavits that were submitted in this case, there were only three affidavits that have been submitted by plaintiff in this case. Brian is able to testify as to the contents of the affidavits of indebtedness which was prepared according to their business records; correct? THE WITNESS: Correct. MS. BALRAM: The other two affidavits that were submitted were an affidavit of costs which was prepared by plaintiff based on costs expended to file the foreclosure and affidavit as to attorneys fees which is plaintiff's counsels cost. So Brian, you know, that was not given to him because that was prepared by plaintiff's counsel. BY MR. WASYLIK: Q I see. So you counsel did not provide you a counsel of the affidavit of indebtedness? A Not to my knowledge, no. Q And did not provide you a copy of the affidavit of costs? A Not to my knowledge, no. Q And did not provide you a copy of the affidavit of fees? A Not to my knowledge, no. Q Okay. With respect to No. 3, we've asked for a representative with knowledge of facts supporting plaintiff's standing. Did you make any investigation with respect to the plaintiff's standing? A Yes, I did. Q And tell me how you conducted that investigation? A Can you -- again, can you ask more specifically what you ware wanting to know from me? Q Absolutely. With respect to the investigation that you conducted as to the plaintiff's standing, did you have any conversations with anyone about the plaintiff's standing? MS. BALRAM: Objection: Privileged. MR. WASYLIK: I'm not asking for contents of the conversation, I'm asking if the conversation existed. Q With that clarification, can you answer the question. A My attorney and I, we had our day-to-day conversations regarding the file, the case. Q Did you review any documents related to the plaintiff's standing? A Specifically which documents? Q Any documents. Page 6

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113632+WHITE.BRIAN+061411 A Which documents -- which documents are you asking me about? If you ask me a specific question about a document, I can tell you if I reviewed it or not. Ambiguous or vague documents, I can't tell you if I reviewed them or not. Q All right. If you needed to know whether or not the plaintiff has standing, what documents would you need to see? MS. BALRAM: Objection. Our witness has knowledge of the loan, the servicing of the loan. Questions of standing is a legal issue, and that's not my client's field of expertise. MR. WASYLIK: Well again, we've asked for a person with knowledge of facts supporting plaintiff's standing. And the plaintiff has a duty to produce somebody who is properly prepared to answer questions about that. MS. BALRAM: If you ask a specific regarding, you know, exactly what you want to know about standing, he can do his best to answer the question. But if you ask about all documents regarding standing, you know -MR. WASYLIK: Well, I'm asking -MS. BALRAM: Name a document. MR. WASYLIK: -- what he did to prepare in order to answer questions about standing. I presume that you prepared him for that. MS. BALRAM: Yes. MR. WASYLIK: Okay. Well, we'll get into that in a moment, then. BY MR. WASYLIK: Q Now, with respect to No. 4, we've asked for a person with knowledge of the authenticity of any notes and assignments on which plaintiff relies. In the course of preparing to answer questions about that area of knowledge, have you reviewed the note? A Yes. Q Have you reviewed any assignment? A Let me see what I have here. The assignment is -- since it is a Nationstar loan, the assignment is ours, it's never transferred. Q With respect to the note that you reviewed, can you tell me, was that the original note that you reviewed, or was it an electronic or a Xerox copy of the note? A It's a copy of the note. Q And from where did you obtain that copy? A My attorney provided me that note. Q Besides the copy of the note that your attorney provided, did you review to any other copies of the note? A The note was filed with the Court to my knowledge. Q Besides the copy of the note that your attorney provided to you, did you review any other copy of the note? A No. Q The area of knowledge, number 5, we've asked for personal knowledge of the performance of any conditions precedent to acceleration in foreclosure. Do Page 7

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113632+WHITE.BRIAN+061411 you know what conditions precedent were performed by the plaintiff? A More specifically? Q I'm not asking you to list them, I'm asking if you -- do you know what conditions precedent were performed? A More specifically, what are you -Q Okay. I'm asking you if you know what acts the plaintiff took that were conditions precedent. If you don't know, feel free to let me know; if you do know, it's a yes or no question. A Condition precedent to what? Q To acceleration of foreclosure as provided in the notice. A Yes. We breached the account. We sent the defendant a breach letter, as well, letting him know that he was in default and when the default was due by to bring the account clear. Q Do you have a copy of the complaint with you? A Yes, I do. Q I'm going to ask you to turn to that. The first page of the complaint, Paragraph 3, says, plaintiff is the owner of said note. Can you tell me whether that statement is true? A It is true. Q How do you know it is true? A Because the note indicates that Centex Home Equity Company is listed on the note. Q So the basis of your knowledge that the plaintiff is the owner of the note is the copy of the note that you reviewed that was provided to you by counsel? A No. Nationstar Mortgage is Centex. Q Okay. And you know that -- well, let me rephrase that. You a moment ago testified that the note says that Centex is the original lender on the note? A Correct. They're one in the same. Q Right. And that Centex and Nationstar are the same? A That's right. Q Okay. So far I understand you. The note that you reviewed that bears the name of Centex is the photocopy that your counsel provided to you; correct? A That's right. Q Okay. So your testimony today is not based on the records of Nationstar, but is it based on the records provided to you by counsel? A Ask that question again? Q The testimony that you have just given is based upon not the records of Nationstar, put based upon the records that were provided to you by counsel? A More specifically -MS. BALRAM: Object to form. BY MR. WASYLIK: Q What part of that don't you understand, so that I can help you -- help rephase the question? A Ask the question again more -- it's a little -- it's a little ambiguous so ask it -Q All right. You've testified just a moment ago that the note has the name of Centex on it. And I'm assuming by that you mean -- well, let me clarify that. Page 8

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113632+WHITE.BRIAN+061411 Are you referring to Centex Home Equity Company, LLC? A Yes, I am. Q And when I say "Centex," that's what we're talking about, we can agree on that? A That's fine. Q Okay. You testified a moment ago that the reason you know that the plaintiff, Nationstar, owns the note -A Uh-huh. Q -- is because the copy of the note that you reviewed had Centex as the payee; is that correct? A That's right. And because we are now -Centex is now merged with Nationstar. Nationstar is Centex, Centex is Nationstar. Q I see. With respect to that information, in order for that -- in order for the plaintiff to own the note, you would have to be correct the note has Centex on it; is that right? A The note does have Centex on it. Q And the reason you know that the note has Centex on it is because you've reviewed a photocopy of the note provided by your counsel? A I reviewed a copy of note which is filed with the Court which has Centex on it, which was the original document that the defendant signed at origination. Q Okay. You said a lot of things there, and I want to unpack them one at a time. Earlier today, just a few minutes ago, you testified that the only copy of the note you reviewed was a photocopy of the note provided to you by your counsel. Is that answer still correct? A That answer is correct, too. Q And you've reviewed no other copy of the note? A I have not. Q Okay. You've never seen the original note? A I've not seen the original note, no. Q You weren't present at the closing? A No. Q So other than the photocopy of the note that your counsel provided to you, there is no other document that you've reviewed that says that Centex is the payee on the original note. It's a yes or no question. A I believe I've already answered that question. The name on the note is Centex. Q Okay. The name on the photocopy that you reviewed is Centex? MS. BALRAM: Objection: Asked and answered several times now. MR. WASYLIK: All right. BY MR. WASYLIK: Q Is that correct? A The name on the note is Centex. Q Well, I think we've established that you're talking about the photocopy of the note, so let me direct you to paragraph No. 4 of the complaint. It says the original promissory note was lost or destroyed subsequent to the plaintiff's acquisition thereof. The exact time and manner of said loss or destruction being unknown to plaintiff. When you reviewed the complaint, sir, did you determine whether or not paragraph 4 is Page 9

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113632+WHITE.BRIAN+061411 true or false? MS. BALRAM: Objection. Count 1 is a pleading in the alternative. We've established that the original note has been filed with the Court. So Count 1 is void and can be dropped from this action. MR. WASYLIK: Okay. Have you dropped that count? MS. BALRAM: We have not. Usually, it's done at the summary judgment. MR. WASYLIK: Well -MS. BALRAM: It's moot, so -MR. WASYLIK: It's not moot because you haven't amended your complaint, you haven't dropped it. So I'm entitled to ask a question about it. And if you're instructing your witness not to answer, please do that on the record; otherwise, he can answer the question. BY MR. WASYLIK: Q When you reviewed the complaint, sir, did you determine whether or not paragraph 4 was true or false? A No. I didn't need to, because I had the note. Q You had the original note? A We've already established that I didn't have the original note. Q Paragraph 4 says the original promissory note was lost or destroyed. Did you make any investigation as to whether or not that was true? A No. Q As you sit here today, do you know whether the original promissory note was lost or destroyed? MS. BALRAM: Asked and answered. He's already established that it's been filed with the Court. MR. WASYLIK: No, you have testified to that effect. I am asking him what he knows as the corporate plaintiff. A And again, I've answered no, I don't know if it's been lost or destroyed. I have -- I have a note that has Centex on it with defendant's signature. BY MR. WASYLIK: Q You have a photocopy of the note? A I have the note here -Q That is not the original note? A -- provided to me my attorney. I've already established that this is not the original note. Q So you keep saying you have the note. What you have is a photocopy of the note. And so you understand that there's a difference between the two, do you? A Q Yes, I do. Okay. THE WITNESS: Off the record, if we can lay the ground of respect, you to my attorney, you to me, and vice versa. MR. WASYLIK: I have treated you with respect, sir, and I ask that you treat me with the same. THE WITNESS: I will continue to do so. MR. WASYLIK: Thank you. BY MR. WASYLIK: Q What I will ask you again is: Not whether you made an investigation of whether a photocopy of the note was in your possession, but whether -- and I understand Page 10

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113632+WHITE.BRIAN+061411 you didn't make an investigation in to paragraph 4. But other than the investigation, is there any other basis that you have of knowledge whether or not Paragraph 4 where it says the original note was lost or destroyed, whether or not that's true? A Well, it doesn't say original note, it says promissory note. Q Paragraph 4 says the original promissory note -A My apologies. Q -- was lost or destroyed? A My apologies. Q Okay. A And again my answer is, I didn't investigate that. Q And because you didn't investigate that, you don't have knowledge of it? A I have a note provided to me by my attorney. Q Okay. My question -- let me rephrase my question, because I think that's the source of your confusion. A I'm not confused, I'm answering the question as I know it to be. Q I asked you first whether you did an investigation as to that paragraph, and you told me no; then I asked you whether you had knowledge of the truth of the paragraph. Now, if you made no investigation, it is very likely that your answer is going to be no, but you may have independent knowledge of that. So that's what I'm trying to get at here. Do you have any other knowledge as to the truth of that paragraph? A No. Q Paragraph 5 says the plaintiff was in possession of the promissory note and was entitled to enforce it when loss of possession occurred. Let me take the first half of that. Do you know whether plaintiff was ever in possession of the original promissory note? A To my knowledge, we were. Q How do you have that knowledge? A This was -- we -- Centex which is now Nationstar made the loan. Q Correct. A So therefore, we would have the original. Q All right. My question is not whether you would have had the original, my question is whether you did have the original. And if you're making an inference, that's fine, let me know that. But I'm asking what you do know? A It's an inference. Q Besides the inference, do you have any actual knowledge of whether Nationstar, whether it's Centex or Nationstar in name had possession of the note at any time? A I wasn't at origination, so I can't answer that. Q Your counsel has asserted that there is an original note somewhere that's been filed with the Court or is going be filed with the court. Do you have any knowledge as to that? A Ask that question again to me. Page 11

113632+WHITE.BRIAN+061411 0027 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 0028 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 0029 1 2 3 4 5 6 7 8 9 10 Q Your counsel has asserted that there's an original note somewhere that is filed with the Court or is going to be filed with the Court. Do you know whether that is true or false? A Where the note is, or whether they're going to file it? Q Whether there's an original note that either has been filed or will be filed? A To my knowledge, the original note has been filed. Q How do you know that? A Again, because Centex made the note, and because it -- and because in conversations with my attorney, the note has been filed with the court. Q I see. Let's move to Count 2, please. With respect to Paragraph 11, there are a number of facts asserted in there. Did you make investigation into any of the facts asserted in Paragraph 11 related to the execution and delivery of note? MS. BALRAM: Objection to form. Can you be more specific. BY MR. WASYLIK: Q Was there any single fact in Paragraph 11 that you investigated? A Yes. I looked at the mortgage, and I looked at the note. Q Is there any part of Paragraph 11 -- I'm going to withdraw. Paragraph 12, where it says Plaintiff is the owner of said note, you've testified that's because the note was made to Centex which is Nationstar. Is there any other basis for asserting that? A No. Q Has the note ever been endorsed to any third party? A Not to my knowledge, no. Q Has the note ever been transferred to any third party? A Not to my knowledge, no. Q Is there any way you could tell if it had been? A The mortgage has not been or the note has not been transferred. It's still -- it's still with Nationstar. Q Paragraph 14 asserts that there's been no payment on the note since August 1st of 2007. Did you determine whether or not that is true? A I did. Q And what was your conclusion? A That would be correct. Q How did you make that determination? A I reviewed the account. Q Specifically what do you mean by you "reviewed the account"? A I looked at pay history, I looked at the last payment made, I reviewed the notes of the account. Q All of those being business records of the plaintiff? A That is correct. Q Is the plaintiff servicing its own loan? A We are the owner of the note, so yes. Page 12

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113632+WHITE.BRIAN+061411 Q No one else is servicing it for the plaintiff? A No. Q Has anyone else ever serviced this loan? A Not to my knowledge, no. Q Paragraph 18 asserts that there's a John Doe and a Jane Doe who are unknown tenants who might be in possession of the subject property. Do you see that paragraph? A I do. Q Did you make any determination whether or not there's unknown tenants in the property? A No. Q Do you know if there are any costs attributable to attempting to serve John Doe and Jane Doe? A Because I didn't see the -- what's the word I'm looking for -MS. BALRAM: The costs. A There you go. Because I didn't see the amount of indebtedness as far as the costs. The answer is no, I didn't. I can't attest to. Q All right. Can you tell me, sir, exhibits to the complaint, what exhibits are attached to the complaint you reviewed? A I have -- again, I have reviewed the note and the mortgage and the account history and the pay history and any documents subsequent as far as with -- that's within my purview. Q Let me rephrase the question. The complaint purports to attach at least one exhibit. Specifically, I'll refer you to Paragraph 11 where it says a copy of the mortgage is attached hereto and made a part hereof. And that's the last sentence in the paragraph. A Okay. Q When you reviewed the complaint, did you review any attachments to the complaint? A I have reviewed the mortgage. Q Okay. And a copy of the complaint that you reviewed had the mortgage attached to it? A It does. Q Was there any other exhibit attached to the complaint? A Not to my knowledge. Q The copy of the complaint that you reviewed, where did you obtain that? A From my attorney. Q You did not obtain it from Nationstar's own records? A The complaint would come from my attorney. So it would come from my attorney. Q The answer is no, it didn't come from Nationstar's records? A No, it did not. Q And you've testified that you did not review any answer filed by the defendant? A Correct. Q So you did not review any of the affirmative defenses contained in that answer? A That is correct. Q And you did not review any of the denials contained in that answer? Page 13

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113632+WHITE.BRIAN+061411 A That is correct. Q And you would not, then, be able to provide testimony as to the truth of facts for any of the defenses raised in that answer? MS. BALRAM: Object to form. If you ask a specific question and he has the knowledge, he would be able to testify to that. MR. WASYLIK: Okay. BY MR. WASYLIK: Q Did you understand my question? A I did. Q Can you answer it? A I would concur with my attorney that if you ask me a specific question, I can more than likely answer it. Q The question is whether you have knowledge of any fact related to any affirmative defense raised by the defendant? A I have not reviewed the affirmative defenses. Q Okay. So you do not know whether you have knowledge of those facts? A If you can ask me a specific question, I can answer it. Q I'm asking you about the affirmative defenses in the answer. MS. BALRAM: Objection. He's already stated that he has not reviewed the answer in affirmative defenses, so unless you specify exactly what you want to know, he's not going to be able to answer it. MR. WASYLIK: I'm just trying to determine -MS. BALRAM: I'm just trying to keep going. MR. WASYLIK: -- what the extent this witness' knowledge is. I'm sorry? MS. BALRAM: I'm sorry. MR. WASYLIK: I didn't -MS. BALRAM: I was just going to say I'm just trying to keep this moving because he's already answered and he's already said that he has not reviewed the answer in affirmative defenses, therefore he wouldn't know what was raised in those affirmative defenses. However, if it's something pertaining to the servicing of the mortgage, then, you know, if it's within his knowledge he'd be able to answer if you ask a specific question. MR. WASYLIK: Well, I think we've already established that you haven't reviewed all the pleadings despite our request, so I'll move on. BY MR. WASYLIK: Q With respect to the affidavit of indebtedness, did you seek with a person who signed that affidavit? A I've not seen any affidavits. MR. WASYLIK: Counsel, I'll just tell you now I think that the -- I think that the plaintiff has failed to do its job in producing a witness that has knowledge of the areas of knowledge requested. Obviously, Mr. White is knowledgeable about the file generally, but when a witness hasn't reviewed any affidavit when we've asked for a witness with knowledge of the fact asserted in the affidavit, I Page 14

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113632+WHITE.BRIAN+061411 do not think that you have complied with the notice. And I will tell you now that we are probably going to seek judicial review of that question. Without waiving that, I'm going to continue. BY MR. WASYLIK: Q You have broadly said you've not reviewed any affidavits. I'm going to ask you a I specific question about a specific affidavit, and you can tell me if you can answer it, if you can answer it or not. Did you have an opportunity to review a document entitled Affidavit of Lost Original Document? A No. To my knowledge, the -- depending on what document you're referring to, to my knowledge, the document's not lost. Q Were you aware that the plaintiff prepared and executed an affidavit that said that the note, the original note, was lost or destroyed? A No. Q With respect to area of knowledge No. 4, knowledge of the authenticity of the notes -A On which count? Q -- on which plaintiff relies. Area of knowledge No. 4 with respect to the amended notice. The amended notice is first page -A Okay. Q -- in your packet there. When I use the phrase "authenticity of any notes," do you understand what that means? A Yes. Q Did you make any determination as to whether the note that plaintiff relies on was or was not authentic? A Yes. Q How did you make that determination? A Through discussions with my counsel. Q Are there any records of the plaintiff that would show that the note on which the plaintiff relies is authentic? A Are there any records? Q Yes. A I can't answer that. Q Let me ask you this: Does the plaintiff retain a copy of the note in its own records? A To my knowledge, yes. Q You did not review that copy, though? A That is kept in a -- off site, and it takes a while to get. By the time that I received notice of deposition, there was not time to have that ordered and delivered to me in my office. Q The copy is kept off site? A The documents are kept off site. Q Which documents are you referring to? A What was your question to me? Q My question to you is whether or not there are any records that the plaintiff as to authenticity of note and you answered -A The records are kept off site. Q Does the plaintiff retain any electronic records like images of notes? A I reviewed for those images, and they were not there. Page 15

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113632+WHITE.BRIAN+061411 Q Does the plaintiff retain any photocopies of the notes? A Those would be images that you've just referred to. Q So when you say you reviewed for images and they were not there, you mean you reviewed for electronic images and also for photocopies? A I reviewed for any images able, any images available. Q And let me make sure I understand, then, what your testimony is. When you reviewed for available images in the plaintiffs records, you found that there were no images in the plaintiff's records of the note? A There were no images available for my review. It does not mean that they're not there, it means that I just can't see them. Q Okay. Thank you for clarifying that. Can you please explain to me what it means when you say they were not available for your review? A Sure. When I access the system, they weren't there for my review, they -- they weren't there for my review. And I didn't have time to request them, it would take too long. I inquired about them. By the time that I was able to get them, I would already be in Florida, so therefore I could not get them in time to review them. Q All right. Would it be correct to say that the plaintiff might have photocopies or electronic images of the note that were beyond your access level, in other words, that you didn't have permission to review? MS. BALRAM: Objection to the form of the question. Brian's already testified that he has access to the entire loan file. BY MR. WASYLIK: Q Well let's start with that, then. If the plaintiff had a photocopy or an electronic image of this note, would it be in the loan file that you have access to? A Yes. Q Okay. And so when you reviewed the loan file and found that there was no photocopy or electronic image of the note, would it be fair to say that the plaintiff, then, does not have a copy, either a photocopy or an electronic image of that document in its records? A It would not be fair to say. Q You have access to the entire file? A Yes. Q They weren't there when you looked for them? A No. Q Okay. A That does not mean that they're not there, just means that when I accessed the record, it -- they were not there. And again, our documents are kept off site. And by the time that I could get the file, the servicing file or the origination file, it would already be too late as I would be in Florida at this deposition. Q A I see. There are paper copies kept off site? Our files are kept off site, Nationstar, Page 16

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113632+WHITE.BRIAN+061411 Centex files are kept off site. Q Are they paper files or electronic files? A It's the entire origination file. Their servicing file. Q And what form are those in? Are they something you can pull up on a computer screen, or are they physically paper files? A They're in a warehouse. Q Do you know the answer to my question? A They're in a box, they're in a file, they're in a warehouse. Q What is it box, is it paper, is it a computer disk, what is it? MS. BALRAM: Objection. Brian' s already testified that he didn't get the document, so he has no idea what's in there. BY MR. WASYLIK: Q There's a document in a box in a warehouse somewhere, and you don't know if it's a paper or electronic document; is that a correct statement of your testimony? A To my knowledge, it's paper. Q Okay. That's was the -- what I was asking you. A The file is paper in a box in a warehouse. Q Thank you. A We've established that it wasn't electronic, or I could pull it up. Q And the only reason that you didn't have access to what was in the box is because you didn't have time to physically retrieve it or have the retrieved for you? A That's correct. Q So you don't know what's in that box? A I'm aware of what's in the file. MR. WASYLIK: And Counsel, again I'm going to say that I think there's a problem here, that we've asked for a witness who's, you know, got certain areas of knowledge. I would think that reviewing the records that are in the possession of the plaintiff is going to be something that's part of your duty to do. But again, I think we'll probably have to take that up with the Court. MS. BALRAM: The entire origination file was copied and produced to Counsel. I don't know if it was yourself or prior counsel. It was produced, so at one point, that file was copied in its entirety and produced over to defense counsel. MR. WASYLIK: But not produced to the witness whose deposition I'm taking today. MS. BALRAM: I mean, obviously I cannot testify for Brian. But Brian, the response to plaintiff's request for production is what you reviewed earlier. But no, it was not produced prior to today -MR. WASYLIK: All right. MS. BALRAM: -- to the witness. BY MR. WASYLIK: Q Let's talk about the 5th area of knowledge, please. You are -- strike that. Earlier I asked you about the performance and conditions precedent, and you Page 17

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113632+WHITE.BRIAN+061411 made a reference to a breach letter. Do you have a copy of that breach letter? A I believe my attorney has that copy. Q You reviewed it? A Yes. Q Can you please describe for me what that breach letter says? A The breach letter typically is -- lists the amount of default, the date of default, when the acceleration is -- to clear the default is due by, and it goes to the address of record. Q And the breach letter you reviewed, this was a photocopy provided to you by your counsel? A Yes. Q Did you review any other breach letter? A No. Q When was the breach letter sent? A Do you have the breach letter, and I can tell you when it was sent. Q I'm looking for my copy. But I guess if you needed to know when the breach letter was sent, how would you find out? A It would be in the top left-hand corner of the breach letter. Q So the date of the breach letter itself? A Right. Or it would be in our system which would indicate when we breached the account. Q Did you determine whether or not the breach letter was actually sent? A The breach letter that I reviewed indicated that it was sent. Q And how did it make that indication? A By the mailing address on the breach letter. Q Okay. So there was a date and an address, and based on that you've concluded that it was, in fact, sent? A Yes. Q Is there any other log or record that shows that that document was mailed? A I have a date of breach which typically indicates that we at that time sent out a breach letter. Q Okay. Was there any postage incurred for mailing the letter? A I don't know that. Q No postage reflected in the affidavits of cost -- I'm sorry, I'll withdraw that -MS. BALRAM: Objection. Q -- you said you didn't review the affidavit of cost. In your review of the loan file, was there any cost reflected for the postage of mailing default letter? A I haven't reviewed the affidavit of cost. Q When you reviewed the loan file, were costs included in the document reviewed? A Fees and costs, what, judgment figures, what? Q Costs. The expenses that you've incurred in servicing the loan? A To my knowledge, yes. Q And you reviewed those cost figures? A I reviewed them in our system, what the unpaid principal balance would be. Page 18

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Q

I see.

113632+WHITE.BRIAN+061411 You did not, then, review a specific

breakdown of costs? A I believe that would refer back to affidavits which I've indicated I have not reviewed. Q Well, I'm not asking about the affidavits, I'm asking about the records that Nationstar had that you reviewed. Or let me -- I'm sorry, you said you didn't review Nationstar's record. Let me rephase that. A No. I didn't say that. MS. BALRAM: Objection. MR. WASYLIK: All right. Let me rephrase. BY MR. WASYLIK: Q Did you review any documents in preparation for today that showed a breakdown of the costs that Nationstar has incurred in servicing the loan? A More specifically, which costs are looking for? Q Well specifically, I'm asking about cost of postage of mailing the default letter? A Right. And I've answered that I can't answer that. Q When you reviewed the breach letter itself, were you aware of any contractual obligations as to its contents? MS. BALRAM: Objection. What specifically are you asking? What specific -MR. WASYLIK: Well, I'm allowed to ask nonspecific questions. MS. BALRAM: Yes. MR. WASYLIK: Okay. MS. BALRAM: I object to the form of the question. BY MR. WASYLIK: Q Can you understand the question? A No, honestly. Q Good. I'll rephrase. Are you aware of any requirements, any information that is required to be contained in the breach letter? A I don't write the breach letter, so that's not within my purview to know what verbiage should be there. I'm not an attorney. Q Okay. Assume for a moment that the mortgage contract, the mortgage itself, the security interest, that 20-something page paper that's attached to the complaint that you reviewed, lists certain specific items that are required to be in a notice of default. Would you know whether or not those items are in the breach letter or not? A Again, I'm not an attorney, and I can't tell you what is required to be in the breach letter. Q I'm not asking you what can -- I'm asking whether you would know. So would it be fair to say your answer to that question is no? A I'm not required to know what is in the breach letter or as far as what -- how it's made up, what -how it should be promulgated, what verbiage should be there, specifically outside of dates and when it was sent and address. Q Because you're not required to know that, would it be fair to say that you don't know that? Page 19

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113632+WHITE.BRIAN+061411 A It's not within my scope to know that. Q Okay. And so you don't. There's nothing wrong with something you don't, I just want to know whether you do or you don't. MS. BALRAM: You've asked and he's answered. MR. WASYLIK: No. He's evading my question, and I'm trying to ask very specific questions. THE WITNESS: I'm not evading, I'm answering you -- I feel a little badgered, but I am doing my best to answer your questions, sir. BY MR. WASYLIK: Q All right. I had asked you whether you do know, you have told me you're not required to know, and you've told me it's outside your scope. I am asking you a simple yes or no question. Do you know? A Do I know what words should be in that breach letter, no. Q Thank you. Where is your physical office? A Physical office is 350 Highland Drive, Lewisville, Texas. Q Is that Betton County? A Betton? Q Benton? A Denton? Q Denton County? A Denton, yes. Q Denton County, sorry. A That's okay. Q I'm going to give you a document here. And I understand that you've not reviewed it, but I'm going to -- it is an affidavit that the plaintiff has submitted to us. A Are you going to make it an exhibit? Q I will in just a moment. First I want you to take a look at it. MR. WASYLIK: Could you mark this, please, as Defendant's 1. BY MR. WASYLIK: Q Do you see the name of the person who signed this affidavit? A Yes. Q What I've handed you is a document entitled Affidavit of Lost Original Document. The name there appears -- it's Sherry, and I can't read the last name. Do you know the last name? A I do. Q Is this a person that you know? A Yes. Q Can you spell the name for me since it's kind of illegible? A No, I cannot. No. Q Do you know how to say it? A Sumerauer. Q So it appears to be S-u-m-e-r-a-u-e-r. A Right. Q Okay. How do you know Ms. Sumerauer? A Yes. Q How do you know her? A She's in the foreclosure department. Q Would she have had access to the records relating to this loan file? Page 20

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113632+WHITE.BRIAN+061411 MS. BALRAM: Objection. Brian isn't expected to know what Sherry has access to. MR. WASYLIK: Well again, we asked for a person with knowledge of affidavits and even though he hasn't reviewed the affidavits, you've asserted that he would have knowledge of the underlying facts. So I'm entitled to ask that. MS. BALRAM: But he's not able to testify as to someone else's scope of knowledge. MR. WASYLIK: He can testify as to anything he has knowledge of that relates to something we've asked about, so can you please -MS. BALRAM: Object to form. MR. WASYLIK: Well, that's not an objection. You're trying to backdoor an instruction not to answer. Please don't do that. BY MR. WASYLIK: Q Do you know whether or not Ms. Sumerauer would have had access to the information, to the records for this loan file? A I concur with my attorney, I don't know what Ms. Sumerauer knows. MR. WASYLIK: All right. I have no further questions on that exhibit, if you could please hand it back to the court reporter. Counsel, I'm going to give you the chance to redirect on anything we've already covered. I will tell you that we will be adjourning this deposition to continue because I believe that the plaintiff has not met its obligations with respect to the notice to produce; however, at this time if you have any redirect, you may. MS. BALRAN: Yes. CROSS EXAMINATION BY MS. BALRAM: Q Brian, have you reviewed the Nationstar file with respect to this loan? A Yes. Q Can you give -- what is the status of this loan currently? A It's currently in default. Q What is the date of default? A Specifically, the date of default is 8/1 of '07. Q You've previously testified that Nationstar is the owner and the servicer of this loan? A Correct. Q Has Nationstar as the owner and servicer received any payments after the default date? A No. Q So as it stands to date, what is the current status of this loan, is it still default? A Yes. Q Has the defendant -- have you reviewed the collection notes in this file? A Yes. Q Based on your collection notes, does it reflect that a breach letter was sent to the borrower? A To my knowledge, yes. Q Based on the collection notes, does it show Page 21

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113632+WHITE.BRIAN+061411 that the borrower has attempted to reinstate the loan or make any payments on the loan after the date of breach? A No. MS. BALRAM: No further questions. MR. WASYLIK: I'm going to redirect on that. REDIRECT EXAMINATION BY MR. WASYLIK: Q You answered just a moment ago in response to your counsel's questions whether you'd review the collection notes and whether the collection notes reflect whether a default letter was sent? A Yes. Q And your answer to that was yes. What in your collection note reflects that the default letter was sent besides what you've already discussed with me when you were discussing the default letter earlier? A The date of breach -- as I testified earlier, the date of breach on the account, typically within 30 days after that point, we send out a breach letter. Q Now, what you just testified to is that it's typically the case. But when your counsel asked you the question, you said -- you gave an unqualified yes. A That is correct. We sent a breach letter. Q But the collection notes don't actually reflect that the default letter was sent, just that the default occurred? A If you give me a moment, I can look and see if it's in there. Q Please do. A It's five years' worth of history, so if you give me a moment, I can look and see. MR. WASYLIK: Take as much time as you need. MS. BALRAM: For the record, counsel, a copy of the collection notes was also provided in the request for production, in response to request for production. (Pause.) MS. BALRAM: Counsel, in the interest of time, would it help for me to direct my client to the date that it says so in the collection notes which has been produced to your office or would you rather him to continue looking through the file? MR. WASYLIK: That's fine. If the plaintiff has the position that you can identify that will save us time. MS. BALRAM: Because it is five years' worth of a loan, a payment history. Brian, I mean I guess I can direct you, if you want to look in your own notes or here, the breach date as you testified previously was in August. THE WITNESS: Yes. Thank you. You saved some time. MS. BALRAM: Right. THE WITNESS: August 27th of '07. MR. WASYLIK: Can you show me what you're referring to specifically. MS. BALRAM: Yes. BY MR. WASYLIK: Q You've circled an entry in the payment history -MS. BALRAM: The collection history. Page 22

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113632+WHITE.BRIAN+061411 Q The collection history, I apologize. You've circled an entry in the collection history which says that a pre-demand letter was sent. And is there any cost associated with that? A I don't know that. Q Okay. You can't tell from this document here? A No. Q Does that reflect the date on which the pre-demand letter was sent? A No, it's not a demand letter -Q I'm sorry. A -- shows you the pre-demand letter sent. So it could be the day after, it could be within three days, I don't know. Q So the date of this entry is not the exact day, but it's close to the time? A Yes. Q Within a few days? A Yes. MR. WASYLIK: Can we attach a copy of this as an exhibit? Is this your only -MS. BALRAM: Do you want entire collection comment, or you just want that one excerpt out of it? MR. WASYLIK: Right now, I just want the one for this purpose. MS. BALRAM: Let's see. MR. WASYLIK: Actually -MS. BALRAM: If you have a copy of this, we can certainly attach it. MR. WASYLIK: Okay. MS. BALRAM: Also, further down it does show when the demand letter, as well, the last entry. And it continues to the other page, as well. I'm asking if you wanted the whole thing or just that part? MR. WASYLIK: You know, I think you're right. Let's go ahead and attach this whole thing. MS. BALRAM: We'll just make a copy of this for you. MR. WASYLIK: And this is Page 13 of the collection log, the collection notes. MS. BALRAM: Are you going to mark it? MR. WASYLIK: Let's mark the whole thing. MS. BALRAM: Sure. MR. WASYLIK: And get your client to authenticate the entire thing. MS. BALRAM: Just note for the record, this is a 66-page collection history, and also I would like the record to note that this collection history is the one that was sent in response to request for production, and it's valid through this particular one, February 25th, 2010, because that's when we served our response, okay? MR. WASYLIK: Okay. MS. BALRAM: Do you have any further questions on your redirect? MR. WASYLIK: I'm reviewing my notes. (Pause.) MR. WASYLIK: Go ahead if you have further Page 23

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113632+WHITE.BRIAN+061411 questions. MS. BALRAM: You were redirecting. MR. WASYLIK: My redirect is concluded. MS. BALRAM: I have no further questions. MR. WASYLIK: Once again, I'd like to state for the record that I am suspending this deposition not terminating it because I believe that the witness produced was not completely responsive to our requests. I reserve the right to pursue that with the Court. That being said, I think we're done for today, but with the understanding that we're suspending. MS. BALRAM: Plaintiff objects to Counsel's characterization. Plaintiff's representative is familiar with the loan and able to testify to all of the -- is able to testify regarding the scope of this loan as well as the servicing of this loan, and we have complied with the notice of deposition. MR. WASYLIK: Anything else? MS. BALRAM: Nothing further. (The reading and signing of this deposition is not waived, and the deposition was concluded at 4:03 p.m.) CERTIFICATE OF REPORTER STATE OF FLORIDA COUNTY OF POLK ) )

I, Evelyn M. Adrean, RPR, FPR, certify that I was authorized to and did stenographically report the deposition; that a review of the transcript was requested; and that the foregoing pages are a true and complete record of my stenographic notes taken during said deposition. I further certify that I am not a relative, employee, attorney, or counsel of any of the parties, nor am I a relative or employee of any of the parties' attorneys or counsel connected with the action, nor am I financially interested in the action. Dated this 14th day of June, 2011.

_______________________________ Evelyn M. Adrean Registered Professional Reporter Florida Professional Reporter DEPOSITION ERRATA SHEET Our Assignment No. 228291 Case Caption: NATIONSTAR MORTGAGE LLC vs. HENRY REDILLO A/K/A HENRY REDILLO, SR., et al DECLARATION UNDER PENALTY OF PERJURY I declare under penalty of perjury that I have read the entire transcript of my Deposition taken in the captioned matter or the same has been read to me, and Page 24

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113632+WHITE.BRIAN+061411 the same is true and accurate, save and except for changes and/or corrections, if any, as indicated by me on the DEPOSITION ERRATA SHEET hereof, with the understanding that I offer these changes as if still under oath. Signed on the ___________ day of ________________, 20__.

DEPOSITION ERRATA SHEET Page No. _____ Line No. _____ Change to:________________ ________________________________________________________ Reason for change: _____________________________________ Page No. _____ Line No. _____ Change to:________________ ________________________________________________________ Reason for change: _____________________________________ Page No. _____ Line No. _____ Change to:________________ ________________________________________________________ Reason for change: _____________________________________ Page No. _____ Line No. _____ Change to:________________ ________________________________________________________ Reason for change: _____________________________________ Page No. _____ Line No. _____ Change to:________________ ________________________________________________________ Reason for change: _____________________________________ Page No. _____ Line No. _____ Change to:________________ ________________________________________________________ Reason for change: _____________________________________ Page No. _____ Line No. _____ Change to:________________ ________________________________________________________ Reason for change: _____________________________________ Page No. _____ Line No. _____ Change to:________________ ________________________________________________________ Reason for change: _____________________________________ Page No. _____ Line No. _____ Change to:________________ ________________________________________________________ Reason for change: _____________________________________ Page No. _____ Line No. _____ Change to:________________ ________________________________________________________ Reason for change: _____________________________________ Page No. _____ Line No. _____ Change to:________________ ________________________________________________________ Reason for change: _____________________________________ Page No. _____ Line No. _____ Change to:________________ ________________________________________________________ Reason for change: _____________________________________ Page No. _____ Line No. _____ Change to:________________ ________________________________________________________ Reason for change: _____________________________________ Page No. _____ Line No. _____ Change to:________________ ________________________________________________________ Reason for change: _____________________________________ SIGNATURE:___________________________ DATE:_____________ BRIAN WHITE Page 25

113632+WHITE.BRIAN+061411 0060 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 0061 1 2 3 4 5 6 7 8 9 10 11 12 13 14 SIGNATURE:___________________________ DATE:_____________ BRIAN WHITE CERTIFICATE OF OATH ) ) DEPOSITION ERRATA SHEET Page No. _____ Line No. _____ Change to:________________ ________________________________________________________ Reason for change: _____________________________________ Page No. _____ Line No. _____ Change to:________________ ________________________________________________________ Reason for change: _____________________________________ Page No. _____ Line No. _____ Change to:________________ ________________________________________________________ Reason for change: _____________________________________ Page No. _____ Line No. _____ Change to:________________ ________________________________________________________ Reason for change: _____________________________________ Page No. _____ Line No. _____ Change to:________________ ________________________________________________________ Reason for change: _____________________________________ Page No. _____ Line No. _____ Change to:________________ ________________________________________________________ Reason for change: _____________________________________ Page No. _____ Line No. _____ Change to:________________ ________________________________________________________ Reason for change: _____________________________________ Page No. _____ Line No. _____ Change to:________________ ________________________________________________________ Reason for change: _____________________________________ Page No. _____ Line No. _____ Change to:________________ ________________________________________________________ Reason for change: _____________________________________ Page No. _____ Line No. _____ Change to:________________ ________________________________________________________ Reason for change: _____________________________________ Page No. _____ Line No. _____ Change to:________________ ________________________________________________________ Reason for change: _____________________________________ Page No. _____ Line No. _____ Change to:________________ ________________________________________________________ Reason for change: _____________________________________ Page No. _____ Line No. _____ Change to:________________ ________________________________________________________ Reason for change: _____________________________________ Page No. _____ Line No. _____ Change to:________________ ________________________________________________________ Reason for change: _____________________________________

STATE OF FLORIDA COUNTY OF POLK

I, the undersigned authority, certify that the witness in this matter personally appeared before me and was duly sworn on the 14th day of June, 2011. WITNESS my hand and official seal this 14th of June, 2011. Page 26

113632+WHITE.BRIAN+061411 15 16 17 18 19 20 21 22 23 24 25 _______________________________ Evelyn M. Adrean, RPR, FPR Notary Public State of Florida at Large My Commission Number: DD816645 Expires: 10/05/2012

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