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WILLIAMS v. FANNIE MAE — Entry #33: MOTION for Summary Judgment by FANNIE MAE, RICHARD LAWCH, GRACE HUERSCHER

Case: WILLIAMS v. FANNIE MAE dcd · 1:05-cv-01483

filed July 28, 2005

What this document is

Docket entry #33 · filed June 21, 2007

MOTION for Summary Judgment by FANNIE MAE, RICHARD LAWCH, GRACE HUERSCHER (Attachments: # (1) Memorandum in Support of Motion for Summary Judgment# (2) Exhibit Exhibit A - Declaration of Grace Huebscher and Deposition Excerpts# (3) Exhibit Exhibit B - 3-28-2007 Williams Dep and Exhibit# (4) Exhibit Exhibit C - Fannie Mae's Interrogatory Responses# (5) Exhibit Exhibit D - Declaration of Richard Lawch# (6) Exhibit Exhibit E - 3-21-2003 Williams Deposition Excerpts# (7) Exhibit Exhibit F - 5-7-2007 Williams Deposition and Exhibit# (8) Exhibit Exhibit G - DC Certificate# (9) Exhibit Exhibit H - Jones Deposition and Exhibits# (10) Exhibit Exhibit I - CAM Amended Complaint# (11) Exhibit Exhibit J - CAM Dismissal Order# (12) Exhibit Exhibit K - Williams Interrogatory Responses# (13) Exhibit Exhibit L - 3-17-2003 Williams Deposition# (14) Exhibit Exhibit M - DC License Document# (15) Exhibit Exhibit N - Draft Complaint# (16) Exhibit Exhibit O - 5-5-2003 Williams Deposition Excerpts# (17) Exhibit Exhibit P - 5-6-2003 Williams Deposition Excerpts# (18) Exhibit Exhibit Q - Westover Declaration# (19) Exhibit Exhibit R - Production Document# (20) Exhibit Exhibit S - Ott Deposition Excerpts# (21) Exhibit Exhibit T - Production Document# (22) Affidavit Declaration of K Grundeman# (23) Statement of Facts Statement of Undisputed Facts# (24) Text of Proposed Order # (25) Certificate of Service)(Goldfrank, Sarah)

Who is involved

Why we have it

We follow this case because it names a company we track, although that company is not a party:

A free copy from the RECAP archive of federal court filings (mirrored at the Internet Archive), retrieved November 07, 2026. Federal court filings are public records.

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Full text
Case 1:05-cv-01483-JDB Document 33-17 Filed 06/21/2007 Page1of5

EXHIBIT O


Case 1:05-cv-01483-JOB Document33-17 Filed 06/21/2007 Page 2of5

00001
1 IN THE UNITED STATES DISTRICT COURT

2 SOUTHERN DISTRICT OF MISSISSIPPI
3 SOUTHERN DIVISION

5 CAM FINANCIAL SERVICES, INC.,
6 Plaintiff,  ; Case No.1:01cv314BrR
7 Vv.

8 GENERAL STAR NATIONAL INSURANCE :
9 COMPANY; GENERAL STAR INDEMNITY :
10 COMPANY; GENERAL STAR MANAGEMENT :
11 COMPANY, GENERAL RE CORPORATION; :
12 GENERAL REINSURANCE CORPORATION; :
13 CRUMP INSURANCE SERVICES OF

14 MEMPHIS, INC.; CRAIG OTT,

15 INDIVIDUALLY AND IN HIS

16 REPRESENTATIVE CAPACITY AS VICE :

17 PRESIDENT OF GENERAL STAR

18 MANAGEMENT COMPANY

19 FEDERAL NATIONAL MORTGAGE

20 ASSOCIATION

21 (FANNIE MAB),

22 Defendants.

23 ----------------- x

24

25

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00002
1 Washington, D.C.
2 Monday, May 5, 2003
3 Videotaped Deposition of MARIALICE

4 WILLIAMS, a witness herein, called for examination by
5 counsel for Defendant, Fannie Mae, in the

6 above-entitled matter, pursuant to subpoena and

7 agreement, the witness being duly sworn by PENNY M.
8 DEAN, a Notary Public in and for the District of

9 Columbia, taken at the offices of Steptoe & Johnson,

10 1330 Connecticut Avenue, N.W., Washington, D.C., at
11 9:55 a.m., Monday, May 5, 2003, and the proceedings
12 being taken down by Stenotype by PENNY M. DEAN, RPR,
13 and transcribed under her direction.

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00032
1 was also giving Grace Huebscher the decision-making

2 power and she clearly indicated that she did not want
3 todo any further business with me.

4 BY MR. WIMBERLY:

5 QQ. And how was he giving Ms. Huebscher the

6 decision-making power?

7 ~~ +A. I met with Ms. Huebscher at a restaurant

8 along with Rhoda Newman who used to work for me when
9 I was at Fannie Mae. And Ms. Huebscher indicated
10 that she was looking for new and innovative ways to
11 lay off risk and I told her that ] had several brand

12 new concepts that I had developed and she indicated
13 that she would like to sign a confidentiality

14 agreement with me at that time and after doing so --
15 and it was a five-page confidentiality agreement

16 which covered all the ideas which I would disclose to
17 Ms. Huebscher. After that, and I brought in at great
18 expense and difficulty the internationally renowned
19 expert on captive insurance companies who had just
20 completed writing the regulations for the District of
21 Columbia and the application for the District of

22 Columbia's new captive program, she listened to all
23 of my ideas, I then began to corresponded with her by
24 e-mail and she would not respond to me at all, she

25 would not respond, I would cc Mr. Lawch, she would

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00033
1 not respond. So I received no response to any of my

2 efforts and therefore could not press any further
3 with Fannie Mae.
4 QQ. When was that?
5 A. Some time -- it was over a very long
6 period of time, I spent a great deal of effort trying
7 todo business with Fannie Mae. It was over the
8 years between 1998 -- well, not really, probably
_ 9 around 1999 after the -- the 12-month period had
10 elapsed in which I could not be considered for
11 employment and felt they probably wouldn't utilize me
12 as aconsultant either. In fact, I did get
13 rejections of my efforts to get hired as a consultant
14 from Mr. Lawch so that was when I was working with
15 the former owner of the Denver Bullets, Denver, is it
16 Denver, whatever the Denver basketball team is --
17 —s_ Q._-—s Nuggets.
18 A. Nuggets, right. And he approached
19 directly -- yes, ] know that Washington was the
20 Bullets and now they are the Wizards and I think they
21 are both horrible names, buy anyway when I was
22 working -- J attempted to work with everybody, let me
23 just put it that way. I tried to go through Frank
24 Rains, I tried to go through Richard Lawch, I tried

25 to go through Rob Levin. I tried -- and these were

May 5, 2003, FM of MAW | Page 33

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