Case 1:15-cv-00293-LTS-RWL Document 403-30 Filed 05/10/19 Page 1 of 16

Exhibit 30
 Case 1:15-cv-00293-LTS-RWL Document 403-30 Filed 05/10/19 Page 2 of 16

UNITED STATES DISTRICT COURT

SOUTHERN DISTRICT OF NEW YORK

-------------------------------------- x
MORTGAGE RESOLUTION SERVICES, LLC, 1ST :
FIDELITY LOAN SERVICING, LLC, and S & A :
CAPITAL PARTNERS, INC., :
:
Plaintiffs, :
: No. 15 CV 293-LTS-JCF
:
-against-
:
:
JPMORGAN CHASE BANK, N.A., CHASE HOME
:
FINANCE LLC, and JPMORGAN CHASE & CO., :
:
Defendants.
-------------------------------------- X

SUPPLEMENTAL OBJECTIONS AND RESPONSES OF PLAINTIFFS S&A

CAPITAL PARTNERS, INC. AND 1ST FIDELITY LOAN SERVICING, LLC TO
THE THIRD SET OF INTERROGATORIES OF DEFENDANT JPMORGAN
CHASE BANK, N.A.

Pursuant to Federal Rules of Civil Procedure 26 and 33, Plaintiffs S&A Capital

Partners, Inc. ("S&A") and 1st Fidelity Loan Servicing, LLC ("1st Fidelity") (collectively,

“Plaintiffs”) hereby submit their Supplemental Objections and Responses to the Third Set of

Interrogatories (“Interrogatory” or “Interrogatories”) of Defendant JPMorgan Chase Bank,

N.A. (“Chase”).

GENERAL OBJECTIONS

1. Plaintiffs object to the Interrogatories to the extent that they seek information

that may be protected from disclosure by the attorney-client or other privileges, or the work

product doctrine.

2. Plaintiffs object to the Interrogatories to the extent that they seek opinion that

is the proper subject of expert testimony. Such material, if otherwise discoverable, will be

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provided at the appropriate time in the appropriate context.

3. Plaintiffs object to the Interrogatories to the extent that they seek information

and material that is beyond the scope permitted by the Federal Rules of Civil Procedure,

Local Civil Rules, the Individual Rules and Practices of Judge Swain and/or Magistrate Judge

Lehrburger, and any Orders in this case.

4. Plaintiffs object to the Interrogatories to the extent that they are ambiguous,

vague, overbroad, unduly burdensome, oppressive, designed to harass, or not proportional to

the need of the case, the resources of the parties and to the extent that they do not take into

account the relative access of the parties to relevant information.

5. Plaintiffs object to the Interrogatories to the extent that they prematurely ask for

an opinion or contention that relates to fact or the application of law to fact prior to designated

discovery is completed.

6. By responding to the Interrogatories, Plaintiffs do not adopt the definitions

given within, or concede that the Responses demanded are relevant to the subject matter of

the lawsuit or the claims or defenses, nor do they concede that the demanded responses are

proportional to the needs of the case, the resources of the parties or take into account the

relative access of the parties to relevant information.

7. All responses submitted herein are based on the present knowledge,

information and belief of Plaintiffs at this stage of discovery and are provided subject to such

information as may be recalled or produced in the future. Plaintiffs reserve their right to

revise or amend their responses as more information becomes known.

8. Plaintiffs object to the definitions to the extent that they purport to change the

common meaning of the English language with regard to any word or phrase, to the extent

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that they attempt to alter the scope of discovery under the Federal Rules of Civil Procedure

and the Local Rules of the Southern District of New York, and to the extent that the

definitions define terms differently than such terms are defined under the Federal Rules of

Procedure, the Local Rules of the Southern District of New York, and/or common law.

Plaintiffs also object to the definitions to the extent that they are argumentative, prejudicial,

improper, incorrect, misleading, vague or ambiguous.

9. Plaintiffs object to the instructions and definitions of the terms “MLPA”

“MLPA Loan”, “Lien Release”, “Rescission”, “Debt Forgiveness Letter”, “Identify” or

“Identification” and “State the Basis” on the grounds of the foregoing objections and that

Chase has not identified and produced all of said documents related to these definitions.

SPECIFIC OBJECTIONS AND RESPONSES

Interrogatory No. 1

Identify each loan that You claim to have purchased from Chase. Your response should

identify any proof that You purchased the loan (including any purchase contracts or assignments),

include the purchase date, purchase price and lien position for each loan, and state whether (and

when) You subsequently sold the loan back to Chase.

Response

Plaintiffs hereby supplements its response to this Interrogatory as required by the Rules,

and pursuant to a stipulation of the Parties to supplement Plaintiffs’ responses.1 Plaintiffs further

object to this Interrogatory as overbroad and unduly burdensome to the extent it calls for Plaintiffs

to reproduce, in narrative answer format, material from third parties that has already been

1
These responses are also propounded pursuant to the Court’s June 23, 2018 Order.

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produced to Defendant. Plaintiffs further object to this Interrogatory in so far as it requires

information from the Plaintiffs that is readily available to the Defendant or which Defendant, who

are the original sellers of the loans, have been unable to produce themselves due to claims that it

is unduly burdensome to do so, and because the loans sold differ from document to document

produced by Defendant.

Further answering, all of the depositions taken of individuals, all documents produced by

the individuals and entities, all of the correspondence from such individuals and entities, and all

expert reports of the Plaintiffs’ experts have already been produced to the Defendant. See Federal

Rule of Civil Procedure 33(d); July 9, 2018 Expert Report of Richard W. Payne, III (Exhibit 1);

Jeffrey S. Andrien (Exhibit 2); and Zachary Allen Bumpus (Exhibit 3).

Furthermore, Plaintiffs have previously provided a “Master Loan List,” containing the list

of loans known to Plaintiffs that were purchased from Chase (Exhibit 4). Moreover, as the party

who sold the loans, and to the extent applicable, repurchased them, said information is within the

possession of Chase.

In addition, and as opined by Plaintiffs’ experts, because Defendant failed to provide

necessary information regarding many of the loans Plaintiffs purchased, it is impossible to

determine, for many of the loans, what Plaintiffs’ received (Exhibit 1-3). As such information is

in the sole possession of the Defendant, Plaintiffs defer to Defendant for a more complete

response to the extent Defendant deems same necessary, which Plaintiffs do not concede.

Interrogatory No. 2

Identify each loan that You purchased from Chase with respect to which You contend that

Chase improperly recorded a Lien Release, and State the Basis for your contention. Your response

should include an Identification of the Lien Release (including by date and bates number).

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Response

Plaintiffs hereby supplements its response to this Interrogatory as required by the Rules,

and pursuant to a stipulation of the Parties to supplement Plaintiffs responses. Plaintiffs further

object to this Interrogatory as overbroad and unduly burdensome to the extent it calls for Plaintiffs

to reproduce, in narrative answer format, material from third parties that has already been

produced to Defendant. Plaintiffs further object to this Interrogatory in so far as it requires

information from the Plaintiffs that is readily available to the Defendant or which Defendant, who

is the original drafter of such Lien Releases, has been unable to produce itself due to claims that it

is unduly burdensome to do so.

Further answering, all of the depositions taken of individuals, all documents produced by

the individuals and entities, all of the correspondence from such individuals and entities, and all

expert reports of the Plaintiffs’ experts have already been produced to the Defendant. See Federal

Rule of Civil Procedure 33(d); July 9, 2018 Expert Report of Richard W. Payne, III (Exhibit 1);

Jeffrey S. Andrien (Exhibit 2); and Zachary Allen Bumpus (Exhibit 3).

Subject to the foregoing objections, and subject to the previous response to this

Interrogatory, Plaintiff further states that Plaintiff has attached a list of Lien Releases currently

known as of this date (Exhibit 5), which includes Lien Releases previously disclosed within

Attachment VIII of Mr. Andrien’s Report (Exhibit 2). The list attached to Mr. Andrien’s Report

identifies (by date and bates number) 399 loans which Defendant sold to Plaintiffs and later issued

either a Lien Release or Debt Forgiveness Letter (“DFL”) after March 1, 2012. Exhibit 5

contains two lists, a “Discovery List” which identifies 621 loans where Defendant issued a Lien

Release; and a list titled “Other Releases” which identifies an additional 171 loans identified by

Plaintiffs’ experts through their examination of all the discovery produced in this case where

Defendant issued some form of “consumer relief” (Exhibit 5 - Other Releases; Exhibit 2, pp. 48-

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49).2

Moreover, upon information and belief, Defendant is continuing to issue Lien Release

letters to borrowers on loans sold to and owned by the Plaintiffs.

Interrogatory No. 3

For each loan for which You contend that Chase improperly recorded a Lien Release, state

whether you believe that Chase did or did not subsequently record a Rescission of the Lien

Release, and State the Basis for Your contention (if any) that any such Rescission was

"fraudulent" or otherwise ineffective.

Response

Plaintiffs hereby supplement their response to this Interrogatory as required by the Rules,

and pursuant to a stipulation of the Parties to supplement Plaintiffs’ responses. Plaintiffs further

object to this Interrogatory as overbroad and unduly burdensome to the extent it calls for Plaintiffs

to reproduce, in narrative answer format, material from third parties that has already been

produced to Defendant. Plaintiffs further object to this Interrogatory in so far as it requires

information from the Plaintiffs that is readily available to the Defendant or which Defendant, who

is the original drafter of such Rescissions of Lien Releases, have been unable to produce itself due

to claims that it is unduly burdensome to do so.

Further answering, all of the depositions taken of individuals, all documents produced by

the individuals and entities, all of the correspondence from such individuals and entities, and all

expert reports of the Plaintiffs’ experts have already been produced to the Defendant. See Federal

Rule of Civil Procedure 33(d); July 9, 2018 Expert Report of: Richard W. Payne, III (Exhibit 1);

2
The “Discovery List” as used herein is the list produced by Defendant wherein Chase produced information for all
liens which it identified the issuance of either a Lien Release or Debt Forgiveness Letter.

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Jeffrey S. Andrien (Exhibit 2); and Zachary Allen Bumpus (Exhibit 3).

Subject to the foregoing objections, and subject to the previous response to this

Interrogatory, based on Page 59 of the testimony of Erika Lance of Nationwide Title Clearing,

Inc. (“NTC”), from her deposition of October 5, 2017, Chase did not send out all recorded

documents, including Lien Releases. As such, Chase has admittedly recorded title documents on

the chain of title without notice to the homeowners thus impacted. It is highly impractical and

burdensome to research each and every Loan to determine whether a Rescission of Lien Release

has been recorded on each and every Property.

Nevertheless, as part of Attachment VIII of Mr. Andrien’s Report (Exhibit 2) and Exhibit

5, there is a column which indicates whether or not Plaintiffs are aware of whether a Recession of

Lien Release was sent to the borrower.

As for whether Plaintiffs believe a Rescission was “improper”, “fraudulent” or

“ineffective”, same calls for a legal conclusion and or opinion and as such, is not a proper inquiry

for an interrogatory. Moreover, Plaintiffs’ experts opined that the issuance of a Rescission, in

most instances, is entirely ineffective (Exhibit 1-3).

Interrogatory No. 4

Identify each loan that You purchased from Chase with respect to which You contend that

Chase sent the borrower a Debt Forgiveness Letter, and State the Basis for Your contention.

Response

Plaintiffs hereby supplement their response to this Interrogatory as required by the Rules,

and pursuant to a stipulation of the Parties to supplement Plaintiffs’ responses. Plaintiffs further

object to this Interrogatory as overbroad and unduly burdensome to the extent it calls for Plaintiffs

to reproduce, in narrative answer format, material from third parties that has already been

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produced to Defendant. Plaintiffs further object to this Interrogatory in so far as it requires

information from the Plaintiffs that is readily available to the Defendant or which Defendant, who

is the original drafter of such Rescissions of Lien Releases, have been unable to produce itself due

to claims that it is unduly burdensome to do so.

Further answering, all of the depositions taken of individuals, all documents produced by

the individuals and entities, all of the correspondence from such individuals and entities, and all

expert reports of the Plaintiffs’ experts have already been produced to the Defendant. See Federal

Rule of Civil Procedure 33(d); July 9, 2018 Expert Report of Richard W. Payne, III (Exhibit 1);

Jeffrey S. Andrien (Exhibit 2); and Zachary Allen Bumpus (Exhibit 3).

Subject to the foregoing objections, and subject to the previous response to this

Interrogatory, Plaintiffs further state that Plaintiffs have attached a list of loans for which they are

presently aware that Defendant sent a Debt Forgiveness Letter (identified as “DFL” on the list)

(Exhibit 5); which includes DFLs previously disclosed within Attachment VIII of Mr. Andrien’s

Report (Exhibit 2). Exhibit 5 identifies 23 loans on the “Discovery List” where a DFL was

issued by Defendant, and an additional 171 loans were identified by Plaintiffs’ experts through

their examination of all the discovery produced in this case where Defendant issued some form of

“consumer relief.” (Exhibit 5 “Other Releases”; Exhibit 2, pp. 48-49)

Moreover, upon information and belief, Defendant is continuing to issue Debt Forgiveness

Letter to borrowers on loans sold to and owned by the Plaintiffs.

Interrogatory No. 5

Identify (including by borrower name and loan number) each instance in which You

contend that a borrower's payments to You ceased or were interrupted by (i) the borrower

receiving a Debt Forgiveness Letter from Chase or (ii) Chase's recordation of a Lien Release

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with respect to the loan. Your response should Identify the dates and amounts of any payments

that You received on the loan before and after the Debt Forgiveness Letter or Lien Release and

State the Basis for Your contention that the borrower ceased making payments as a result of the

Lien Release and/or Debt Forgiveness Letter.

Response

Plaintiffs hereby supplement their response to this Interrogatory as required by the Rules,

and pursuant to a stipulation of the Parties to supplement Plaintiffs’ responses. Plaintiffs further

object to this Interrogatory as overbroad and unduly burdensome to the extent it calls for Plaintiffs

to reproduce, in narrative answer format, material from third parties that has already been

produced to Defendant.

Further answering, all of the depositions taken of individuals, all documents produced by

the individuals and entities, all of the correspondence from such individuals and entities, and all

expert reports of the Plaintiffs’ experts have already been produced to the Defendant. See Federal

Rule of Civil Procedure 33(d); July 9, 2018 Expert Report of Richard W. Payne, III (Exhibit 1);

Jeffrey S. Andrien (Exhibit 2); and Zachary Allen Bumpus (Exhibit 3).

Moreover, Plaintiffs cannot ascertain with any certainty why borrowers from whom

they previously received payments stopped making payments and/or why payments were

interrupted as a result of: (i) the borrower receiving a Debt Forgiveness Letter from Chase or

(ii) Chase's recordation of a Lien Release with respect to the loan; because such information

could only be determined if: a) Chase provided such information to the Plaintiffs, which

Chase has indicated they cannot do, and/or b) the borrower informed Plaintiffs of that fact.

That being said, Plaintiffs are aware that this happened from time to time, but are unable to

specifically identify any particular loan numbers at this time for the reasons stated herein.

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Interrogatory No. 6

Identify (including by date, loan number, payment amount, and payor) each instance in

which You contend that Chase improperly accepted and retained a payment on a loan that You

purchased from Chase. Your response should include the date(s) and amount(s) of the alleged

payment(s), and State the Basis for Your contention that Chase improperly accepted and retained

a payment on the loan.

Response

Plaintiffs hereby supplement their response to this Interrogatory as required by the Rules,

and pursuant to a stipulation of the Parties to supplement Plaintiffs’ responses. Plaintiffs further

object to this Interrogatory as overbroad and unduly burdensome to the extent it calls for Plaintiffs

to reproduce, in narrative answer format, material from third parties that has already been

produced to Defendant. Plaintiffs further object to this Interrogatory in so far as it requires

information from the Plaintiffs that is readily available to the Defendant or which Defendant, who

is the original keeper of the records of ownership of the S&A and 1st Fidelity Loans, has been

unable to produce itself due to claims that it is unduly burdensome to do so.

Further answering, all of the depositions taken of individuals, all documents produced by

the individuals and entities, all of the correspondence from such individuals and entities, and all

expert reports of the Plaintiffs’ experts have already been produced to the Defendant. See Federal

Rule of Civil Procedure 33(d); July 9, 2018 Expert Report of Richard W. Payne, III (Exhibit 1);

Jeffrey S. Andrien (Exhibit 2); and Zachary Allen Bumpus (Exhibit 3).

Over said objections, each and every Loan which was not properly transferred as would be

evidenced by the existence of a “RESPA transfer letter”, and even some which were, could be

subject to payment by the borrower to the Defendant without Plaintiffs’ ability to determine if,

when and/or in what amounts such payments were made and or received.

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Moreover, Plaintiffs’ Expert Reports outline that Chase breached the various Agreements

at issue herein in that it failed to provide the Plaintiffs with necessary and required information

regarding the loans which prohibited Plaintiffs from boarding the loans and in many instances,

identifying what type of loans they received, including whether and if a “RESPA transfer letter”

was sent by Chase, and Plaintiffs would only know if Chase received payments if: a) Chase told

the Plaintiffs, and/or b) the payor provided proof of payment to Chase. In so much as either of the

above occurred, Plaintiffs are not now in possession of such information. As such, it is nearly

impossible to answer this question more fully at this time and or as posed by the Defendant. See

Expert Reports, Exhibit 1-3.

Interrogatory No. 7

Identify (including by date, amount, and payee) any expenses or costs, including but not

limited to legal fees or extra staff or overhead costs, that You contend You incurred as a result

of Chase's alleged wrongdoing and that You claim as damages in this case, and State the

Basis for Your contention.

Response

Plaintiffs hereby supplement their response to this Interrogatory as required by the Rules,

and pursuant to a stipulation of the Parties to supplement Plaintiffs’ responses. Plaintiffs further

object to this Interrogatory as overbroad and unduly burdensome to the extent it calls for Plaintiffs

to reproduce, in narrative answer format, material from third parties that has already been

produced to Defendant.

To the extent this Interrogatory calls for notes and/or memoranda prepared by the potential

testifying expert witnesses, Plaintiffs object to the Interrogatory as premature and expressly

reserve the right to supplement, clarify, revise, or correct any or all responses to the Interrogatory,

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and to assert additional objections and/or privileges, in one or more subsequent supplemental

response(s) in accordance with the time period for exchanging expert reports set by the Court.

Further answering, all of the depositions taken of individuals, all documents produced by

the individuals and entities, all of the correspondence from such individuals and entities, and all

expert reports of the Plaintiffs’ experts have already been produced to the Defendant. See Federal

Rule of Civil Procedure 33(d); July 9, 2018 Expert Report of Richard W. Payne, III (Exhibit 1);

Jeffrey S. Andrien (Exhibit 2); and Zachary Allen Bumpus (Exhibit 3).

In particular, the Report of Mr. Andrien outlines costs anticipated and or incurred by MRS

as a result of the MLPA Transaction, as well as costs associated with Defendant’s breach (Exhibit

2, p. 30-36 (Table 5)). Mr. Andrien’s Report also details the expenses anticipated and incurred,

and discusses that certain expenses were in fact transferred to and or absorbed by S&A or 1st

Fidelity (Exhibit 2). Also included in Mr. Andrien’s Report as Attachment VI A and VI B are the

Profit and Loss Statements for S&A and 1st Fidelity for the Fiscal Years 2009 – 2018YTD, which

outline expenses incurred (Exhibit 2).

Plaintiff has also previously disclosed legal expenses (SA00449478-503). That disclosure

was for expenses through July 2017 for Tantillo Law PLLC and October 2016 for Walker Di

Marco, P.A., and totaled $1,891,459. Obviously, further legal expenses have been incurred since

July 2017 and October 2016 respectively, including costs associates with the preparation of the

Expert Reports produced on July 9, 2018, for which Plaintiffs have yet to receive invoices.

Interrogatory No. 8

Identify (including by date and bates number) each contract between You and Chase,

whether written or oral, that You contend Chase breached. Your response should State the Basis

for your contention that Chase breached the contract and Identify any damages that You contend

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occurred as a result of the alleged breach.

Response

Plaintiffs hereby supplement their response to this Interrogatory as required by the Rules,

and pursuant to a stipulation of the Parties to supplement Plaintiffs’ responses. Plaintiffs further

object to this Interrogatory as overbroad and unduly burdensome to the extent it calls for Plaintiffs

to reproduce, in narrative answer format, material from third parties that has already been

produced to Defendant. Plaintiffs further object to this Interrogatory in so far as it requires

information from the Plaintiffs that is readily available to the Defendant or which Defendant, who

is the original drafter of the applicable Agreements, and made all representations contained

therein, has been unable to produce itself due to claims that it is unduly burdensome to do so.

To the extent this Interrogatory calls for notes and/or memoranda prepared by any

potential testifying expert witness, Plaintiffs object to the Interrogatory as such information is

attorney work product and prepared in anticipation of litigation.

Further answering, all of the depositions taken of individuals, all documents produced by

the individuals and entities, all of the correspondence from such individuals and entities, and all

expert reports of the Plaintiffs’ experts have already been produced to the Defendant. See Federal

Rule of Civil Procedure 33(d); July 9, 2018 Expert Report of Richard W. Payne, III (Exhibit 1);

Jeffrey S. Andrien (Exhibit 2); and Zachary Allen Bumpus (Exhibit 3).

Over said objections, and without waiving same, Plaintiffs S&A and 1st Fidelity are aware

of the following Contracts:

JPMC and S&A agreed to sale of mortgage loans pursuant to an

agreement dated April 12, 2005 (“Master Mortgage Loan Sale
Agreement”)(“MMLSA”) between Chase Home Finance LLC and
S & A Capital Partners, Inc.;

JPMC and 1st Fidelity agreed to sale of mortgage loans pursuant to

an agreement dated September 20, 2010 (“Master Mortgage Loan

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Sale Agreement”)(“MMLSA”) between JP Morgan Chase Bank,

NA and 1st Fidelity Loan Servicing, LLC.

Defendant breached the above Contracts by sending borrowers Lien Releases and or Debt

Forgiveness Letters; failing to properly, or at all, assign to the Plaintiffs loans which had been sold

to them, including a failure to comply with RESPA rules and regulations; and or not owning the

loans sold in the first instance. -

See
- Exhibits 1-3.

As for the damages sustained by the Plaintiffs as a result of Defendant’s breaches,

Plaintiffs suffered lost profits in an amount yet to be determined as damages continue to accrue

since Defendant continues to breach the Agreements by sending releases and forgiveness letters.

Moreover, the Defendant was unjustly enriched by at least $557 million in that by issuing Debt

Forgiveness Letters and Lien Releases, which negatively impacted the Plaintiffs, Defendant

received HAMP payments of at least $550 million from the US Government that they would not

have been eligible to receive, had they not engaged in the bad-acts alleged by the Plaintiffs

(Exhibit 2).

Defendant also engaged in consumer relief initiatives that affected loans previously sold to

the Plaintiffs. The principal balance on these loans totaled approximately $6 million. To the

extent that these loans were used to satisfy the consumer relief requirements, under the terms of

the various settlement agreements the Defendant entered into with the U.S. Government (the

“Lender Settlements”), the Defendant was unjustly enriched (Exhibit 2).

Plaintiffs have also incurred significant legal fees and expenses to prosecute this action,

and to defend actions brought by borrowers and others because of Defendant’s breaches, as

outlined herein above.

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SIGNED UNDER THE PAINS AND PENALTIES OF PERJURY nns 1I th DAY OF JULY, 2018.
-----
Laurence Schneider
AS TO OBJECTIONS:

Rob · rto L. Di Marco, BBO #645157

rdimarco@ walkerd imarcopc.com
Jennifer Martin Foster, BBO #644796
jfoster@walkerdimarcopc.com
Walker & Di Marco, P.C
350 Main Street, First Floor
Malden, MA 02148
Tel: (781) 322-3700
Fax: (781) 322-3757

Dated: July 11, 2018