(15-00293 403-12) Ex 12 6.22.2017 Solomon Declaration

Case 1:15-cv-00293-LTS-RWL Document 403-12 Filed 05/10/19 Page 1 of 20
([KLELW
Case 1:15-cv-00293-LTS-RWL
Case 1:15-cv-00293-LTS-JCFDocument
Document403-12 Filed06/29/17
201 Filed 05/10/19 Page
Page1 2ofof3 20
UNITED STATES DISTRICT COURT

SOUTHERN DISTRICT OF NEW YORK
- - - - - - - - - - - - - - - - - - - - - - - - - - - - - - X
S&A CAPITAL PARTNERS, INC.,

MORTGAGE RESOLUTION SERVICING, No. 15-cv-00293-LTS-JCF
LLC, and 1ST FIDELITY LOAN
SERVICING, LLC,
Plaintiffs,
... V. -
JPMORGAN CHASE BANK, N.A., CHASE

HOME FINANCE, LLC, and JPMORGAN
CHASE & CO,,
Defendants. x
DECLARATION OF LAUNI SOLOMON
I, Launi Solomon, declare as follows:
1. I am a business analyst at JPMorgan Chase Bank, N.A. ("Chase") in Phoenix,
Arizona in the Recovery M01igage Depmiment. I have been employed in that department since
approximately 2007. Except as otherwise stated, I make this declaration based on my own
personal knowledge and experience at Chase and my review of Chase's business records.
2. I understand that this litigation concerns certain distressed mortgage debt that was
purchased by the Plaintiff entities from Chase in and before 2009. During the period from 2007
until 2014, my job responsibilities including providing post-sale supp01i to third parties that
purchased distressed mortgage debt from Chase. In that capacity, I was the primary point of
contact for the principal of the Plaintiff entities, Laurence Schneider, and other employees of the
Plaintiff entities.
201 Filed 05/10/19 Page
Page2 3ofof3 20
3. At all times prior to 2013, I provided Plaintiffs with the documents and data that
they requested from Chase, including original loan files, to the extent that they existed within
Chase. In 2013, after Mr. Schneider threatened legal action against Chase, Mr. Schneider and I
were informed that future requests for support by Mr. Schneider should be directed to counsel for
Chase. Attached hereto as Exhibit 1 is an excerpt from my May 17, 2017, deposition testimony
relating to this topic.
4. In 2009, Plaintiff Mortgage Resolution Servicing, LLC ("MRS") purchased a
large number of distressed mortgage loans from Chase in a bulk sale. I was informed of the bulk
sale shortly after it occurred by Chase employees Victor Fox and Eddie Guerrero. Messrs. Fox
and Guerrero told me that (1) Mr. Schneider was aware that many of the loans included in the
bulk sale were unsecured and/or otherwise valueless, (2) Mr. Schneider did not intend to attempt
to "work" or collect upon all of the loans included in the loan pool, and (3) Mr. Schneider
therefore did not want or need documents relating to all of the loans included in the sale.
Instead, Mr. Schneider would request documents and data on an "as needed" basis for specific
loans or groups of loans on which he might try to collect.
5. For several years after the bulk sale, the course of my dealings with Mr. Schneider
was consistent with that understanding. As discussed above, whenever Mr. Schneider requested
documents or data from me regarding loans included in the bulk sale, I provided them to the best
of my ability. See, e.g., Exhibit 2.
6. I understand Mr. Schneider has complained that he did not receive certain
assignments of mortgage from Chase relating to the loans included in the bulk sale. After the
bulk sale was completed, however, Chase and Mr. Schneider agreed that MRS (not Chase)
would prepare any assignments that MRS determined were necessary. Attached hereto as
2
201 Filed 05/10/19 Page
Page3 4ofof3 20
Exhibit 3 is an email exchange dated January 26, 2010, between Mr. Schneider and myself in
which Mr. Schneider stated "I told Eddie [Guerrero] that we would prepare assignments as we
need them and send them to you for execution" as a " gesture of good will for future business."
Also attached hereto as Exhibit 4 is an excerpt from my May 17, 2017 , deposition testimony
relating to this topic.
I declare under penalty of perjury that the foregoing is true and correct.
Executed on Jun ' ~2017 in Phoenix, Arizona.
3
Case
Case1:15-cv-00293-LTS-RWL
1:15-cv-00293-LTS-JCF Document
Document403-12 Filed 06/29/17
201-1 Filed 05/10/19 Page
Page 15 of
of 620

(;+,%,7
Case
201-1 Filed 05/10/19 Page
Page 26 of
of 620
rrrrrrrrr
6/*5&%45"5&4%*453*$5$0635
rr
rrrrrrrrr
4065)&3/%*453*$50'/&8:03,
rr
rr
rr
rr
rr
rr
rr4"$"1*5"-1"35/&34 */$ FUrrrr
rrBM rrrrrrrrrrrrrrrrr
rrrrr
1MBJOUJGGT rrrrrrrrrrr
rrrrrrrrrrrrrrrrrrrrr

rrWTrrrrrrrrrrrrrrrrrr
/P

DW-54
rr+1.03("/$)"4&#"/, /" FUBM rr
+$'

rrrrr
%FGFOEBOUTrrrrrrrrrrr

rr
rr
rr
rr
rr
rr
rrrrrrr
7*%&05"1&%%&104*5*0/0'-"6/*40-0.0/
rr
rr
rr
rrrrrrrrrrrr
1IPFOJY "SJ[POB
rrrrrrrrrrrrr
.BZ
rr
rr
rr
rr
rr
rr
rr
rr
rr3FQPSUFECZrr.BSL.JMMFS 3.3
rrrrrrrrr
$FSUJGJFE3FQPSUFS /P
rrrrrrrrr
3
rrrrrrrrr
XXXQIPFOJYEFQPTJUJPOTFSWJDFTDPN
Case
201-1 Filed 05/10/19 Page
Page 37 of
of 620
1BHF
rrrrrrrrrrrrrr
&9".*/"5*0/
rrr
rrrrr
2rr#:.31*45*--*rr+VTUBDPVQMFRVFTUJPOT .T
rrr4PMPNPO
rrrrrrrrrr
:PVUFTUJGJFEFBSMJFSUIBUJOZPVXFSF
rrrBTLFEOPMPOHFSQFSTPOBMMZUPQSPWJEFTVQQPSUUP.S
rrr4DIOFJEFSBOEIJTDPNQBOJFT
rrrrr
"rr:FT
rrrrr
2rr"OEUIBUXBTCFDBVTFIFIBEUISFBUFOFEMJUJHBUJPO
rrBHBJOTU$IBTF
rrrr
"rr:FT
rrrr
2rr"OEZPVUPMEIJNBUUIBUUJNFJGIFIBEGVUVSF
rrSFRVFTUTIFXPVMEOFFEUPGJMFUIFNUISPVHIUIFMFHBM
rrEFQBSUNFOU
rrrr
"rr:FT
rrrr
2rr4PIFXBTTUJMMQFSNJUUFEUPSFRVFTUTVQQPSUCVU
rrUIBUUIFSFRVFTUOFFEFEUPHPUISPVHIUIFMFHBM
rrEFQBSUNFOU
rrrr
"rr:FT
rrrr
2rr1SJPSUPUIBUUJNFJOXFSFZPV.S
rr4DIOFJEFShTQSJNBSZQPJOUPGDPOUBDUGPSTVQQPSUPOUIF
rrMPBOTUIBUIFQVSDIBTFE
rrrr
"rr:FT
rrrr
2rr"OEXFSFZPVJOSPVUJOFDPOUBDUXJUIIJN
rrrr
"rr:FT
Case
201-1 Filed 05/10/19 Page
Page 48 of
of 620
1BHF
rrrrr
2rr)FDBNFUPZPVXJUISFRVFTUTSFHBSEJOHMPBOTIF
rrrQVSDIBTFE
rrrrr
"rr:FT
rrrrr
2rr%JEZPVFWFSEFDMJOFUPGVMGJMMPOFPGIJT
rrrSFRVFTUT
rrrrr
"rr/P
rrrrr
2rr4PGPSJOTUBODFDPVMEZPVUBLFBMPPLBU
rrr&YIJCJU
rrrrr
"rr
rrrr
2rr1MFBTF
rrrr
"rr:FT
rrrrrrrrr
*UIJOLUIBUJTXIFSFXFHPUPVUPGPSEFSPS
rrTPNFUIJOH
rrrr
2rr4P&YIJCJUJTBDUVBMMZ
rrrr
"rr)FSFJUJT
rrrr
2rr*UJTUXPTFQBSBUFMZTUBQMFEEPDVNFOUTBOEFNBJM
rrBOEUIFOBLJOEPGMPOHQSJOUPVUPGBO&YDFMTQSFBETIFFU
rrrrrrrrr
%PZPVIBWFJU
rrrr
"rr:FT
rrrr
2rr"OEUIJTSFGMFDUTZPVSTFOEJOHEBUBSFHBSEJOH
rrMPBOTUIBU.34QVSDIBTFEUP.S4DIOFJEFS
rrrr
"rr:FT
rrrr
2rr"OEUIFOUIFOFYUEBZEJEZPVGPMMPXVQCZ
rrQSPWJEJOHBEEJUJPOBMJOGPSNBUJPOSFHBSEJOHUIFTFMPBOTUP
rr.S4DIOFJEFS
Case
201-1 Filed 05/10/19 Page
Page 59 of
of 620
1BHF
rrrrr
"rr:FT
rrrrr
2rr"UUIBUUJNFEJEZPVQSPWJEFIJNBMMPGUIFEBUB
rrrFMFNFOUTUIBUIFSFRVFTUFE
rrrrr
"rr:FT
rrrrr
2rr%JEUIFSFDPNFBQPJOUJOUJNFUIFSFXIFOIF
rrrSFRVFTUFEBEEJUJPOBMEBUBFMFNFOUT
rrrrr
"rr:FT
rrrrr
2rr%JEZPVQSPWJEFIJNUIPTFEBUBFMFNFOUT
rrrrr
"rr:FT
rrrr
2rr8FSFUIFSFFWFSBOZEBUBFMFNFOUTUIBUIF
rrSFRVFTUFEUIBUZPVEJEOhUQSPWJEFIJN
rrrr
"rr/P
rrrr
2rr%JE.S4DIOFJEFSDPNFUPZPVGSPNUJNFUPUJNF
rrXJUIRVFTUJPOTSFHBSEJOHJOEJWJEVBMMPBOGJMFT
rrrr
"rr:FT
rrrr
2rr%JEZPVSFTQPOEUPUIPTFJORVJSJFTUPUIFCFTUPG
rrZPVSBCJMJUZ
rrrr
"rr:FT
rrrr
2rr*GIFSFRVFTUFEBEPDVNFOUBOEZPVXFSFBCMFUP
rrGJOEJU ZPVTFOUJUUPIJN
rrrr
"rr:FT
rrrr
2rr3FHBSEJOHUIFMPBOTQVSDIBTFECZ.34JOUIFEFCU
rrTBMF EJEUIFSFDPNFBUJNFUIBU.S4DIOFJEFSSFRVFTUFE
rrDFSUBJOPSJHJOBMMPBOGJMFTGSPNZPV
rrrr
"rr:FT
Case 1:15-cv-00293-LTS-JCF Document
Document403-12
201-1 Filed
Filed 05/10/19
06/29/17 Page
Page 10
6 ofof620
1BHF
rrrrr
2rr)PXEJEUIBUXPSL rr%JEIFQSPWJEFZPVBMJTUPG
rrrBMMMPBOTGPSXIJDIIFXBOUFEPSJHJOBMGJMFT
rrrrr
"rr:FT
rrrrr
2rr"OEUIFOEJEZPVTFUBCPVUUPQSPWJEFIJNXJUI
rrrUIPTFPSJHJOBMGJMFT
rrrrr
"rr:FT
rrrrr
2rr4PJGUIFZFYJTUFEUIFZXFSFTFOUUPIJNBUUIF
rrrUJNFPGIJTSFRVFTU
rrrrr
"rr:FT
rrrrrrrrr
.31*45*--*rr/PGVSUIFSRVFTUJPOT
rrrrrrrrr
.35"/5*--0rr/PGVSUIFSRVFTUJPOT
rrrrrrrrr
5IFEFQPTJUJPOJTDPNQMFUF
rrrrrrrrr
5IBOLZPVTPNVDI
rrrrrrrrr
5)&7*%&0(3"1)&3rr5IFUJNFJTQN
rrrrrrrrr
5IJTDPODMVEFTUIFEFQPTJUJPO XJUINFEJB
rr/P
rrrrrrrrr
8IFSFVQPOUIFEFQPTJUJPODPODMVEFEBU
rrQN
rr
rrrrrrrrrrrrrrrrr

rrrrrrrrrrrrrrrrrr
-BVOJ4PMPNPO
rr
rr
rr
rr
Document403-12
201-2 Filed
Filed 05/10/19
06/29/17 Page
Page 11
1 ofof320
(;+,%,7
Document403-12
201-2 Filed
Filed 05/10/19
06/29/17 Page
Page 12
2 ofof320
From: launi .l.solomon@chase.com

Sent: Thursday, March 26, 2009 1:50 PM
To: wendi.x.miller@chase.com
Cc: Larry Schneider
Subject: Fw: massfile request fails as of 3.24 .09.xls
Attachments: massfile request fails as of 3.24.09.xls
Wendi,
Pis pull the notes/deeds from ivault on all these accts and get them to Larry.
Larry, would you prefer we just mail rather than a bunch of emails?
Loss Recovery Si-ipport Si-iperoisor

Chase Home Finance
PH. 602-627-8174
e-Fax· 602-914-7348
----- Forwarded by Launi L Solomon/JPMCHASE on 03/26/2009 10:48 AM-----
Wendi X Miller/JPMCHASE To larry@sacapitalpartners.com
cc
03/24/2009 08:08 AM Subject massfile request fails as of 3.24.09.xls
Larry-
Here is a list of all of the accounts (to date) that have been requested where no file was located. As we receive further
updates, I will forward them to you.
602-627-8148 o/c 602-535-3940 /ax
This transmission may contain information that is privileged, confidential, legally privileged, and/or exempt
from disclosure under applicable law. If you are not the intended recipient, you are hereby notified that any
1
SA00277438
Document403-12
201-2 Filed
Filed 05/10/19
06/29/17 Page
Page 13
3 ofof320
disclosure, copying, distribution, or use of the information contained herein (including any reliance thereon) is
STRICTLY PROHIBITED. Although this transmission and any attachments are believed to be free of any virus
or other defect that might affect any computer system into which it is received and opened, it is the
responsibility of the recipient to ensure that it is virus free and no responsibility is accepted by JPMorgan Chase
& Co., its subsidiaries and affiliates, as applicable, for any loss or damage arising in any way from its use. If
you received this transmission in error, please immediately contact the sender and destroy the material in its
entirety, whether in electronic or hard copy format. Thank you.
SA00277439
Document403-12
201-3 Filed
Filed 05/10/19
06/29/17 Page
Page 14
1 ofof420
(;+,%,7
Document403-12
201-3 Filed
Filed 05/10/19
06/29/17 Page
Page 15
2 ofof420
From: Launi L Solomon
To: 'Larry Schneider'
CC: McGrane , Jeffrey S
Sent: 1/26/2010 4:28: 13 PM
Subject: RE: Bulk Sale
Jeff, I cant find that email on that acct they need an assignment on can we get it over ot Larry to do it?
Larry- he's hiring a "note/asset sale "manager - to handle stuff like this, so I foresee it happening in the future
yes.
Loss RecoYery Support SupetYisor
Chase Home Finance
( 480-902-6950
7 602-914- 7348
Uave AGreat Day
From: Larry Schneider [mailto:Larry@sacapitalpartners.com]

Sent: Tuesday, January 26, 2010 9:25 AM
To: La uni L Solomon
No blanket assignment. We had to prepare each assignment of mortgage separately. As a gesture of good will for
future business, I told Eddie that we would prepare assignments as we need them and send them to your for execution
to save Chase money but more importantly, to make your life easier (seriously) ...
Is Mike Boyle recently sell or transfer a pool?
Larry
Confidential Treatment Requested by JPMC JPMC-MRS-00001530

Document403-12
201-3 Filed
Filed 05/10/19
06/29/17 Page
Page 16
3 ofof420
From: Launi L Solomon [mailto:launi.l.solomon@chase.com]

To: Larry Schneider; Jeffrey S McGrane
that was funny.
Larry, this is for the Mort Resolution asset sale in March that you did w / eddie.
Loss Recowry Support Supen isor
Chase Honie Finance
( 480-902-6950
7 602-914- 7348
From: Larry Schneider [mailto:Larry@sacapitalpartners.com]

To: Jeffrey S McGrane
Cc: Launi L Solomon
Jeff,
Is there more to this email? I 'm not sure w hich loans you are referring to.
Thanks,

Document403-12
201-3 Filed
Filed 05/10/19
06/29/17 Page
Page 17
4 ofof420
Larry Schneider
1st Fidelity Loan Servicing
2101 NW Corporate Blvd., Suite 102
Boca Raton, FL 33431
Tel: 561-893-9805 x 204
Fax: 561-893-9808
From: Jeffrey S McGrane [mailto:jeffrey.s.mcgrane@chase.com]

To: Larry Schneider
Cc: Launi L Solomon
Subject: Bulk Sale
Larry,
Did you get a blanket assignment letter for these loans?
Jeff McGrane - Chase Home Finance - Recovery Supervisor- Phone 480-902-6952 - Fax 602-680-1452
This transmission may contain information that is privileged, confidential, legally privileged, and/or exempt from
disclosure under applicable law. If you are not the intended recipient, you are hereby notified that any disclosure,
copying, distribution, or use of the information contained herein (including any reliance thereon) is STRICTLY
PROHIBITED. Although this transmission and any attachments are believed to be free of any virus or other defect
that might affect any computer system into which it is received and opened, it is the responsibility of the recipient to
ensure that it is virus free and no responsibility is accepted by JPMorgan Chase &Co., its subsidiaries and affiliates,
as applicable, for any loss or damage arising in any way from its use. If you received this transmission in error, please
immediately contact the sender and destroy the material in its entirety, whether in electronic or hard copy format.
Thank you.

Document403-12
201-4 Filed
Filed 05/10/19
06/29/17 Page
Page 18
1 ofof320
(;+,%,7
Document403-12
201-4 Filed
Filed 05/10/19
06/29/17 Page
Page 19
2 ofof320
rrrrrrrrr
6/*5&%45"5&4%*453*$5$0635
rr
rrrrrrrrr
4065)&3/%*453*$50'/&8:03,
rr
rr
rr
rr
rr
rr
rr4"$"1*5"-1"35/&34 */$ FUrrrr
rrBM rrrrrrrrrrrrrrrrr
rrrrr
1MBJOUJGGT rrrrrrrrrrr

rrWTrrrrrrrrrrrrrrrrrr
/P

DW-54
rr+1.03("/$)"4&#"/, /" FUBM rr
+$'

rrrrr
%FGFOEBOUTrrrrrrrrrrr

rr
rr
rr
rr
rr
rr
rrrrrrr
7*%&05"1&%%&104*5*0/0'-"6/*40-0.0/
rr
rr
rr
rrrrrrrrrrrr
1IPFOJY "SJ[POB
rrrrrrrrrrrrr
.BZ
rr
rr
rr
rr
rr
rr
rr
rr
rr3FQPSUFECZrr.BSL.JMMFS 3.3
rrrrrrrrr
$FSUJGJFE3FQPSUFS /P
rrrrrrrrr
3
rrrrrrrrr
XXXQIPFOJYEFQPTJUJPOTFSWJDFTDPN
Document403-12
201-4 Filed
Filed 05/10/19
06/29/17 Page
Page 20
3 ofof320
1BHF
rrrBOESFMFBTF
rrrrr
"rr:FT
rrrrr
2rr)PXEJEZPVLOPXUIBUJUXBTOFWFSBTTJHOFEUP
rrrUIFN
rrrrr
"rr#FDBVTFUIFFNBJMSJHIUCFMPXJUTBZT 8FEPOhU
rrrIBWFBOBTTJHONFOUGPSUIJTGJMF
rrrrr
2rr"OEBTZPVTUBUFEQSFWJPVTMZ ZPVXFSFOPU
rrrJOWPMWFEJOBOZUZQFTPGBTTJHONFOUTXJUIUIF.PSUHBHF
rrr3FTPMVUJPO4FSWJDJOH
rrrr
"rr/P
rrrr
2rr/PBTNFBOJOH*BNXSPOHPSOP
rrrr
"rr/P *XBTOhUJOWPMWFEJOEPJOHUIFBTTJHONFOUT
rrrr
2rr"OEBTZPVTUBUFEQSFWJPVTMZ ZPVEPOhULOPXXIP
rrXBTTVQQPTFEUPEPJU
rrrr
"rr/P
rrrr
2rr0LBZ
rrrr
"rr*LOPXBUTPNFQPJOUJUXBTEFDJEFEPOUIBU-BSSZ
rrXBTHPJOHUPEPUIFNBOETFOEUIFNUPVTUPTJHOBTIF
rrOFFEFEUIFN
rrrr
2rr0LBZ
rrrr
"rr#VUBTGPSTPNFPOFBU$IBTF XFXFSFOhUEPJOH
rrUIFN
rrrr
2rr/PXDBOZPVUFMMNFBMJUUMFCJUBCPVUXIBUB
rrCMBOLFUBTTJHONFOUJT
rrrr
"rr*BNOPUTVSFrr*IBWFOFWFSTFFOPOF

(15-00293 403-12) Ex 12 6.22.2017 Solomon Declaration

Uploaded by

Document Information

Original Description:

Original Title

Copyright

Available Formats

Share this document

Share or Embed Document

Sharing Options

Did you find this document useful?

Is this content inappropriate?

Copyright:

Available Formats

(15-00293 403-12) Ex 12 6.22.2017 Solomon Declaration

Uploaded by

Copyright:

Available Formats

Case 1:15-cv-00293-LTS-RWL Document 403-12 Filed 05/10/19 Page 1 of 20

UNITED STATES DISTRICT COURT

S&A CAPITAL PARTNERS, INC.,

JPMORGAN CHASE BANK, N.A., CHASE

DECLARATION OF LAUNI SOLOMON

I, Launi Solomon, declare as follows:

1. I am a business analyst at JPMorgan Chase Bank, N.A. ("Chase") in Phoenix,

relating to this topic.

4. In 2009, Plaintiff Mortgage Resolution Servicing, LLC ("MRS") purchased a

loans or groups of loans on which he might try to collect.

of my ability. See, e.g., Exhibit 2.

relating to this topic.

Executed on Jun ' ~2017 in Phoenix, Arizona.

From: launi .l.solomon@chase.com

Loss Recovery Si-ipport Si-iperoisor

602-627-8148 o/c 602-535-3940 /ax

Loss RecoYery Support SupetYisor

Chase Home Finance

Uave AGreat Day

From: Larry Schneider [mailto:Larry@sacapitalpartners.com]

Is Mike Boyle recently sell or transfer a pool?

Confidential Treatment Requested by JPMC JPMC-MRS-00001530

From: Launi L Solomon [mailto:launi.l.solomon@chase.com]

that was funny.

Loss Recowry Support Supen isor

Chase Honie Finance

From: Larry Schneider [mailto:Larry@sacapitalpartners.com]

Confidential Treatment Requested by JPMC JPMC-MRS-00001531

1st Fidelity Loan Servicing

2101 NW Corporate Blvd., Suite 102

Boca Raton, FL 33431

Tel: 561-893-9805 x 204

From: Jeffrey S McGrane [mailto:jeffrey.s.mcgrane@chase.com]

Did you get a blanket assignment letter for these loans?

Confidential Treatment Requested by JPMC JPMC-MRS-00001532

You might also like