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
- FANNIE MAE
- WILLIAMS
Why we have it
We follow this case because it names a company we track, although that company is not a party:
- Marathon Digital: its subsidiary “Sullivan Company” appears in a filing in this case.
…recruited away by another firm known as John 19 F. Sullivan Company in Philadelphia, 20 Pennsylvania. 21 Q.…
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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Case 1:05-cv-01483-JDB Document 33-10 Filed 06/21/2007 Page 1 of 52
EXHIBIT H
Case 1:05-cv-01483-JDB Document 33-10 Filed 06/21/2007 Page 2 of 52
Robert G. Jones
Page 1
IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF COLUMBIA
MARIALICE BATHRUS WILLIAMS, CIVIL ACTION
Plaintiff, NO. 1:05CV01483
VERSUS Judge John D. Bates
FEDERAL NATIONAL MORTGAGE
ASSOCIATION, et al.
Defendants.
Videotaped Deposition of ROBERT G.
JONES, No. 3 Palmer Place, Gulfport,
Mississippi, taken in the Law Offices of
McGlinchey Stafford, PLLC, 643 Magazine
Street, New Orleans, Louisiana, 70130, on
Wednesday, the 11th day of April, 2007,
commencing at 9:16 a.m. and concluding at
12:22 p.m.
APPEARANCES:
(Via telephone)
HARLEY DANIELS, ESQUIRE
BRIAN LEDERER, ESQUIRE
3003 Van Ness Street, N.W.
Suite #W228
Washington, D.C. 20008
(Attorneys for the Plaintiff,
Marialice Bathrus Williams)
FANNIE MAE
(By: Jonathan L. Griffith, Esquire)
3900 Wisconsin Avenue, NW
Washington, DC 20016-2892
(Attorneys for the Defendant,
Fannie Mae)
O'MELVENY & MYERS, LLP
(By: Sarah Alexander Goldfrank, Esq.)
1625 Eye Street, NW
Washington, D.C. 20006-4001
(Attorneys for the Defendant,
Fannie Mae, Richard Lawch, Grace
Huebscher)
ESQUIRE DEPOSITION SERVICES
DC 1-800-441-3376 MD 1-800-539-6398 VA 1-800-752-8979
0ae31a4e-e891-4cb9-849f-fd525208370c
Case 1:05-cv-01483-JDB Document 33-10 Filed 06/21/2007 Page 3 of 52
Robert G. Jones
Page 2 Page 4
1 APPEARANCES: (Continued)
2
1 STIPULATION
SETH M. HUNTER 2
3 ATTORNEY & COUNSELOR AT LAW, PLLC
404 Hemphill Street 3 It is stipulated and agreed by and
4 Hattiesburg, Mississippi 39401
(Attorney for Robert G. Jones) 4 between counsel for the parties hereto that
5
6
5 the deposition of the aforementioned witness
VIDEOGRAPHER: 6 is hereby being taken under the Federal Rules
7
KARL STIEGMAN, CLVS 7 of Civil Procedure, for all purposes, in
8
REPORTED BY:
8 accordance with law;
9
NANCY LAPORTE
9 That the formalities of reading and
10 Certified Court Reporter 10 signing are specifically not waived;
State of Louisiana
11 11 That the formalities of sealing,
12
13 * * *
12 certification, and filing are specifically
14 13 waived;
INDEX
15 14 That all objections, save those as to
Exhibits:
16 15 the form of the question and the
17
Defendant's 16 responsiveness of the answer, are hereby
Jones 1 - Bates No. 6907, excerpts of "First 17 reserved until such time as this deposition,
18 Amended Complaint"
19 Jones 2 - Bates Nos. 8002-8004, e-mail dated 18 or any part thereof, may be used or sought to
May 3, 2001, from Marialice Williams to Rhoda
20 Newman, Grace Huebscher, Bob Jones, and Harvey
19 be used in evidence.
21
Hartsfield 20 *****
Jones 3 - Excerpt from deposition testimony 21 NANCY LAPORTE, Certified Court Reporter,
22 given by Robert Jones on January 30, 2004
23 Jones 4 - Letter from Marialice Williams to 22 in and for the Parish of Orleans, State of
24
Lou Hoyes, dated February 2nd, 1999 23 Louisiana, officiated in administering the
Jones 5 - Bates No. 7918, e-mail from 24 oath to the witness.
25 Ms. Williams to Bob Jones, "CC-ing"
H. Hartsfield 25
Page 3 Page 5
1 Exhibits: (Continued) 1 THE VIDEOGRAPHER:
2 Jones 6 - Bates Nos. 8015-8017, e-mail dated 2 This is the videotape deposition
May 15th, 2001, from Bob Jones to Stephen
3 Noble
3 of Robert G. Jones. This deposition is being
4 Jones 7 - Bates Nos. 6230-6232 and 8031, 4 held at 643 Magazine Street in New Orleans,
e-mail 5 Louisiana on April 11th, 2007, at the time
5 6 indicated on the video screen, 9:16. My name
Plaintiff's: 7 is Karl Stiegman, and I am a certified legal
6 8 video specialist with Depo-Vue. The court
Exhibit 1 - Bates No. 7232, e-mail from Robert 9 reporter is Nancy Laporte with Esquire
7 Jones to Danny Groves
8 10 Reporting.
9 * * * 11 Would counsel please introduce
10 12 themselves?
11 13 MR. GRIFFITH:
12 14 Jonathan Griffith for Fannie Mae.
13 15 MS. GOLDFRANK:
14
15
16 Sarah Goldfrank for Fannie Mae,
16 17 Richard Lawch and Grace Huebscher.
17 18 MR. HUNTER:
18 19 Seth Hunter representing Bob
19 20 Jones.
20 21 MR. DANIELS:
21
22
22 Harley Daniels and Brian Lederer
23 23 representing Marialice B. Williams.
24 24 THE VIDEOGRAPHER:
25 25 Would the court reporter please
2 (Pages 2 to 5)
ESQUIRE DEPOSITION SERVICES
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Case 1:05-cv-01483-JDB Document 33-10 Filed 06/21/2007 Page 4 of 52
Robert G. Jones
Page 6 Page 8
1 swear in the witness? 1 Q. At one point in time, were you
2 Thereupon, 2 president of CAM Financial Services?
3 ROBERT G. JONES, 3 A. I was.
4 having been first duly sworn, was examined and 4 Q. Can you tell me when you first
5 testified as follows: 5 became president of CAM Financial Services?
6 EXAMINATION BY MR. GRIFFITH: 6 A. When CAM was incorporated in
7 Q. Mr. Jones, can you state your 7 1991.
8 full name and address for the record, please? 8 Q. When did you step down as
9 A. Robert Gayle Jones, No. 3 Palmer 9 president?
10 Place, Gulfport, Mississippi. 10 A. In June of 2005.
11 Q. Is there any reason why you 11 Q. And do you have any other current
12 cannot testify fully and honestly today? 12 relationship with CAM Financial Services,
13 A. No. 13 other than being a stockholder?
14 Q. Mr. Jones, did you receive a 14 A. That would be it.
15 subpoena for documents in connection with your 15 Q. And is CAM Financial Services
16 testimony in this matter? 16 still doing business?
17 A. I believe my counsel did. I did 17 A. I couldn't tell you.
18 not. 18 Q. And can you tell me if Hurricane
19 Q. And did you have any documents 19 Katrina had an impact on CAM Financial
20 that were responsive to this subpoena? 20 Services?
21 A. I had no documents. I had a C.D. 21 A. Yes, it did.
22 that were all Bates-stamped documents that was 22 Q. What was that impact?
23 used in the Fannie Mae litigation, and I gave 23 A. CAM Financial Services' building,
24 that to Mr. Hunter, and he talked to your 24 documents, its operation was completely wiped
25 counsel. 25 out by Hurricane Katrina.
Page 7 Page 9
1 Q. So the only documents you had 1 Q. Are you aware of any new
2 were documents that had been produced in the 2 transactions that CAM Financial Services has
3 CAM litigation; is that correct? 3 done since Hurricane Katrina?
4 A. That were produced, yes. 4 A. I have no idea.
5 Q. Mr. Jones, can you tell me, what 5 Q. And how long has CAM Financial
6 is CAM Financial Services, Inc.? 6 Services been in the insurance business?
7 MR. HUNTER: 7 A. I can't tell you how long, but up
8 Before we get started on that, I 8 until 19 -- up until 2005, during product
9 want to make a statement for the record that 9 development, taking -- going back to the
10 Mr. Jones is here as representing Mr. Jones 10 product development days, since 1992, '93 is
11 and not as a representative of CAM Financial 11 when product development first began.
12 Services, Incorporated. 12 Q. And can you tell me what
13 You can go ahead and answer it, 13 qualifications CAM had as an insurance broker?
14 Bob. 14 A. It's -- several of its
15 THE WITNESS: 15 principals, Groves and Rumsey, had an
16 CAM Financial Services was 16 insurance background, and on the mortgage
17 incorporated in 1991 as a financial services 17 brokerage side, I was at -- I had that
18 company to do both insurance brokerage for -- 18 expertise.
19 and mortgage brokerage of multi-family 19 Q. And can you tell me what your
20 properties. 20 experience was -- has been on the insurance
21 EXAMINATION BY MR. GRIFFITH: 21 side?
22 Q. And Mr. Jones, what is your 22 A. You will have to go further with
23 relationship with CAM Financial Services? 23 that.
24 A. I am a stockholder of CAM 24 Q. Let me start with this.
25 Financial Services. 25 How many years have you been in
3 (Pages 6 to 9)
ESQUIRE DEPOSITION SERVICES
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Robert G. Jones
Page 10 Page 12
1 the insurance business? 1 securities transaction in the United States,
2 A. My first job out of college, and 2 whereby Fannie Mae was able to transfer all of
3 while I was in college, I worked for State 3 the risk of loss, as opposed to merely
4 Farm Insurance Agencies, and I was employed, I 4 insuring the loss to a third-party insurer,
5 guess you could go back to 1966 through the 5 AIG."
6 early '70s, I worked with State Farm -- Great 6 Mr. Jones, is Ms. Williams'
7 -- um, I can't -- Coastal. I can't tell you 7 statement that she had solely created and
8 the name of Coastal, but there was another 8 developed the products and processes related
9 insurance company. It was property casualty, 9 to the AIG transaction accurate?
10 and also life insurance in that arena, and 10 A. From a Fannie Mae perspective,
11 I've always stayed active with -- on the 11 she represented Fannie Mae, and a number of
12 insurance side, but not employed by any 12 other players at Fannie Mae would have been a
13 insurance companies until they -- we started 13 party to that, but she was the lead person at
14 working on product development for Fannie Mae. 14 Fannie Mae, and it's reasonably accurate,
15 Q. And that was in the early 1990s? 15 because, from what I understand, Fannie Mae
16 A. 1990s. 16 appointed her as the point person for the
17 Q. And you mentioned two other 17 creation of that product, and it took some
18 members of CAM Financial, Mr. Groves and 18 three years to develop and for --
19 Mr. Rumsey, I believe? 19 Q. You mentioned she was the point
20 A. Correct. 20 person.
21 Q. Can you tell me about Mr. Groves' 21 Were you aware of others at
22 background in the insurance industry? 22 Fannie Mae who were also involved in the
23 A. He had some 20, 25 years 23 project?
24 working -- well, off and on, either as a 24 A. Yes. I think I just mentioned
25 general agency. Prior to that, he was an 25 that, others at Fannie Mae.
Page 11 Page 13
1 employee of Nationwide Insurance for a number 1 Q. Can you tell me who those others
2 of years. 2 are?
3 Q. Can you describe any other 3 A. Lots of lawyers. It was
4 experience or qualifications that Mr. Groves 4 practically all lawyers. The names escape me
5 had with respect to insurance? 5 at this time. Paul Van Hook would have been
6 A. You would probably have to ask 6 the mortgage -- would be the multi-family
7 him that. 7 attorney. There would have been --
8 Q. How about Mr. Rumsey? Can you 8 Mr. Griffin (sic), my memory is not as good as
9 describe his experience in the insurance 9 it used to be, but there were securities
10 industry? 10 attorneys at Fannie Mae that were involved in
11 A. He had a surplus lines broker's 11 this, but probably Paul Van Hook would have
12 license. He also had a general agency for -- 12 been the primary attorney for the mortgage
13 I think it was called South Coast Insurance, 13 company.
14 and probably early '90s, and I couldn't tell 14 Q. Would Richard Lawch have been
15 you if South Coast is still in business or 15 involved?
16 not. I assume it must be. 16 A. He just would have been -- not
17 Q. Mr. Jones, I am going to read for 17 day-to-day, no. He was involved in, I guess
18 you a paragraph from Ms. Williams' complaint 18 giving -- well, not guess -- in direction, and
19 against Fannie Mae and ask you some questions 19 he would have been the party, along with Lou
20 about it. 20 Hoyes, that would have given Marialice the
21 In Paragraph 16 of her complaint, 21 freedom to develop -- Marialice Williams the
22 Ms. Williams alleges the following: "In 1997, 22 freedom to develop this product for Fannie
23 utilizing products and processes which she had 23 Mae.
24 solely created and developed, Plaintiff 24 Q. We have been talking, Mr. Jones,
25 Williams closed the first mortgage-backed 25 about Fannie Mae, Fannie Mae's involvement in
4 (Pages 10 to 13)
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Robert G. Jones
Page 14 Page 16
1 the products and processes related to the AIG 1 that one did not close, and they took --
2 transaction. 2 Fannie Mae took Marialice off of that -- off
3 Were any other entities involved 3 of the Bay View Capital case. It was a seven
4 in developing those products and processes? 4 hundred million dollar case, and for some
5 A. From the outside of Fannie Mae, 5 reason, Mr. Lawch wouldn't let her work on it
6 yes. CAM Financial. 6 after she had created this product for Fannie
7 Q. And what was CAM's role in 7 Mae, and that was the demise of the Bay View
8 developing these products and processes? 8 transaction. It did not close, and CAM didn't
9 A. We were the party that developed 9 get paid on that either.
10 the -- or worked with Fannie Mae with outside 10 Q. Mr. Jones, at some point in time,
11 lawyers from AIG, the business people, the 11 CAM Financial filed a lawsuit against Fannie
12 business group from AIG in the product 12 Mae; is that correct?
13 development. Mr. Groves was pretty involved. 13 A. That is correct.
14 I was the point person on the CAM side, but 14 Q. And do you recall when that
15 we -- drafts after drafts that were gone 15 lawsuit was filed against Fannie Mae?
16 through, and CAM was the author, I guess you 16 A. In -- I believe it was in
17 could say. All drafts came through me, and I 17 December of -- December 2001. It was the
18 made the appropriate pen-and-ink changes, and 18 first amended complaint.
19 we would send the drafts to AIG's lawyers, and 19 Q. Mr. Jones, I am going to show you
20 then there was ASLICK lawyers, the surplus 20 what's been marked as Jones Exhibit 1. It's a
21 lines company for AIG. There were business 21 document, the first page of which is entitled
22 people from AIG also involved. There was a 22 "First Amended Complaint." The Bates number
23 number of people. 23 on the first page is 6907, and it is -- I will
24 Q. And did CAM Financial introduce 24 tell you -- an excerpt of that document. We
25 the products and processes to Fannie Mae? 25 didn't copy the whole thing.
Page 15 Page 17
1 A. Yes. 1 Do you recognize this document,
2 Q. And at what point in time did 2 Mr. Jones?
3 Ms. Williams become involved in the process? 3 A. You said it's excerpts?
4 A. She became involved after CAM 4 Q. Yes.
5 brought the first DUS lender to Fannie Mae. 5 A. I believe I do, yes.
6 She was involved -- she was in the first 6 Q. And is this the complaint that
7 meeting, along with some credit policy people 7 CAM Financial Services filed against Fannie
8 from Fannie Mae, and the DUS lender, 8 Mae in December of 2001?
9 Eichler-Fein. That was in '93 or '94. I 9 A. I believe it is.
10 think it was early '94 probably, and prior to 10 Q. And I will ask you to turn to the
11 that, CAM had a -- was working with Mr. Groves 11 last page of the exhibit, which is Bates
12 through a Nationwide subsidiary called 12 numbered 63 -- excuse me -- 6936.
13 Scottsdale -- no -- yes, Scottsdale Insurance, 13 A. I am there.
14 and we actually had a draft policy and -- 14 Q. Can you read for me the sentence,
15 well, it was a term sheet. It wasn't a 15 kind of halfway down Paragraph 84 starting,
16 policy. That was the first product that we 16 "In order to compensate CAM..."?
17 took to Fannie Mae. 17 A. Sure.
18 Q. Mr. Jones, while Ms. Williams was 18 Q. Actually, why don't you read the
19 at Fannie Mae, how many insurance transactions 19 full two sentences so the folks on the phone
20 did CAM and AIG do with Fannie Mae? 20 can hear you.
21 A. There was the -- the first one 21 A. Starting with "in order"?
22 was in 1997, and there was a second one in 22 Q. Yes, please.
23 early '98 -- no -- that was working for ten 23 A. "In order to compensate CAM for
24 months with Bay View Capital, Bay View Savings 24 its time, efforts, expertise and expense, CAM
25 Bank, while Marialice was at Fannie Mae, but 25 was to be the sole and exclusive agent for
5 (Pages 14 to 17)
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Robert G. Jones
Page 18 Page 20
1 Fannie Mae in the procurement of the MCRI 1 Ms. Williams at any point in time?
2 insurance. CAM has fulfilled its commitment 2 A. It's been a long time ago. I am
3 to Fannie Mae, and Fannie Mae has breached 3 not -- I just couldn't give you an absolute
4 this agreement by failing and refusing to 4 answer on that. I don't know. I don't
5 allow CAM to serve as agent for Fannie Mae and 5 recall.
6 instead is using other entities for the 6 Q. So you don't recall talking to
7 procurement of the MCRI insurance and other 7 her about the allegations prior to filing
8 derivative first loss risk coverage." 8 suit?
9 Q. Thank you, Mr. Jones. 9 A. Prior to?
10 And, Mr. Jones, is it your 10 Q. Yes, prior to.
11 understanding that CAM was to be the sole and 11 A. I don't recall.
12 exclusive agent for Fannie Mae in procurement 12 Q. Did Ms. Williams give a sworn
13 of MCRI insurance? 13 statement to CAM before it -- and CAM's
14 A. That is correct. 14 attorney -- before CAM filed suit against
15 Q. And can you tell me what MCRI 15 Fannie Mae?
16 insurance is? 16 A. You are helping me out now.
17 A. It stands for multi-family 17 There was a deposition that was taken by
18 credit. It's the acronym for multi-family 18 Mr. Wiser prior to Fannie Mae being brought
19 credit risk insurance. 19 into the lawsuit.
20 Q. And what is multi-family credit 20 Q. Would you have discussed your
21 risk insurance? 21 allegations, or potential allegations against
22 A. That's exactly what it is. 22 Fannie Mae, with Ms. Williams at that time?
23 Q. Can you describe it a little more 23 A. I don't know if I would have.
24 fully? 24 Mr. Wiser might have.
25 A. It's designed to insure various 25 Q. But she was aware at that time
Page 19 Page 21
1 levels of tranche risk for Fannie Mae. 1 about a potential lawsuit; is that correct?
2 Q. And does this insurance include 2 A. I would say that is true.
3 insurance for Fannie Mae's aggregation 3 Q. Mr. Jones, are you familiar with
4 program? 4 Marialice Williams?
5 A. It was expanded to -- during the 5 A. "Familiar" is a broad term.
6 product development -- to cover aggregation, 6 Q. Do you know who Ms. Williams is?
7 which is a first-loss tranche risk, but it was 7 A. Yes.
8 designed broad enough that it could cover 8 Q. How long have you known
9 various levels of DUS risk. It could not only 9 Ms. Williams?
10 do first loss. Various tranches. In fact, 10 A. I first met Ms. Williams at the
11 when we first went to Fannie Mae, that was the 11 first introduction of the DUS lender
12 -- so that the goal was, make it broad enough 12 Eichler-Fein in early 1994 when she was
13 that -- at that time, we didn't have too much 13 working at Fannie Mae.
14 success with insurance companies covering 14 Q. When was the last time you spoke
15 first loss, because of the thrift debacle. 15 with Ms. Williams?
16 Q. Mr. Jones, the complaint alleged 16 A. It was either the death of her
17 that Fannie Mae refused to allow CAM to serve 17 mother, which I can't give you a date on that,
18 as agent, and instead used other entities for 18 or it was shortly after Hurricane Katrina hit,
19 the procurement of MCRI insurance. 19 because she had -- was trying to locate us.
20 Was Craig Ott one of the entities 20 Q. And have you spoken with her on
21 that CAM claimed Fannie Mae was using to 21 any other occasion?
22 procure MCRI insurance? 22 A. I don't believe so.
23 A. Yes. 23 Q. And do you recall whether the
24 Q. And did you discuss the 24 conversation regarding the death of her mother
25 allegations contained in CAM's complaint with 25 was before Hurricane Katrina or after?
6 (Pages 18 to 21)
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Robert G. Jones
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1 A. It may have been the same 1 do business in Washington, D.C. CAM and RMS
2 conversation. Things were pretty upside-down 2 do not have any connection with respect to
3 after Katrina. 3 ownership and no one from CAM or RMS has an
4 Q. And what did that discussion -- 4 interest in the other's business ventures.
5 what did you talk about during that 5 However, CAM and RMS have a broker agreement
6 discussion? 6 that is common in the insurance business. The
7 A. She just asked if we were okay 7 agreement indicates that when CAM locates an
8 after she finally got a call through on the 8 insurance company for a project that RMS is
9 cell phone. In fact, we lost the signal, and 9 working on, RMS agrees to compensate CAM
10 she tried several times to get us back. It 10 through some form of split commission.
11 was my wife and I, and we weren't even on the 11 However, it does not mean that CAM plays any
12 Coast. We hadn't even been able to get back 12 role in the development of the program or
13 to our home at that time. 13 project that RMS is working on nor does CAM
14 Q. Mr. Jones, are you familiar with 14 interface with RMS' customers."
15 a company called Risk Mitigation Strategies, 15 Q. Does this document refresh your
16 LLC? 16 recollection as to whether CAM's co-brokerage
17 A. Yes. 17 agreement was with Risk Mitigation Strategies,
18 Q. And can you tell me what Risk 18 LLC or with Marialice Associates?
19 Mitigation Strategies, LLC is? 19 A. I think, again, Danny Groves did
20 A. I don't know the complete make-up 20 the brokerage agreement, and I think it's a
21 of what Risk Mitigation does, but I know that 21 pretty good indication that that is true.
22 she was -- formed that company to lay off risk 22 Q. Do you have any reason to believe
23 for mortgage companies, and a certificate 23 that the statement that Ms. Williams makes in
24 company, I believe. She was also working on 24 this letter is inaccurate in any way?
25 some Fannie Mae programs, the DUS program at 25 A. No.
Page 23 Page 25
1 Fannie Mae, and a captive program at Fannie 1 Q. Are you aware of whether CAM
2 Mae, and I think that was all done for Fannie 2 Financial Services ever had a written
3 Mae. I think that was all done through Risk 3 co-brokerage agreement with either Risk
4 Mitigation. 4 Mitigation Strategies, LLC, or with Marialice
5 Q. Did CAM Financial Services ever 5 Williams, or any other entity controlled by
6 have a co-brokerage agreement with Risk 6 her?
7 Mitigation strategies? 7 A. Again, Mr. Groves did the
8 A. Either Risk Mitigation 8 brokerage agreement, and if -- assuming that
9 Strategists, or Marialice Williams & 9 -- not assuming, but that would have been
10 Associates, and I wasn't completely familiar 10 produced in CAM's documents to Fannie Mae.
11 with this, because Danny Groves handled the 11 Q. I have actually never seen one.
12 brokerage setup with Marialice Williams. I am 12 I am just asking. I am not saying there is or
13 pretty sure it was consummated. In fact, I 13 isn't. Maybe just to refresh your
14 know it was. 14 recollection, I am going to show you what I am
15 Q. Let me show you what I am marking 15 marking as Jones 3, and it is an excerpt from
16 as Jones Exhibit 2, and it is a -- an e-mail 16 deposition testimony given by Mr. Jones on
17 with an attachment. The e-mail is dated May 17 January 30, 2004, and if you could just look
18 3, 2001, from Marialice Williams to a group of 18 at -- starting with line 20. Maybe you could
19 people, including Rhoda Newman, Grace 19 read that for the record.
20 Huebscher, Bob Jones, and Harvey Hartsfield, 20 A. "Did CAM have any written
21 and the Bates numbers are 8002 through 8004. 21 agreements with Ms. Williams or her business
22 I would ask you to read for me, 22 at the time?"
23 please, the third paragraph in the letter 23 "I know that Ms. Williams
24 attached to the e-mail. 24 discussed and worked with Danny Groves on
25 A. "My company, RMS, is licensed to 25 several different brokers agreements. I don't
7 (Pages 22 to 25)
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Robert G. Jones
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1 know that any of them were ever consummated." 1 agreement described in Ms. Williams'
2 Q. At that point in time, Mr. Jones, 2 interrogatory responses, did CAM Financial
3 was it accurate to say that you weren't sure 3 Services have any other co-brokerage
4 whether a signed agreement had actually been 4 agreements with RMS? And "RMS" I am using as
5 entered into? 5 a shorthand for Risk Mitigation Strategies,
6 A. I know that there were verbals 6 LLC.
7 that she -- that we had a 50/50 split on 7 A. They would have -- on DUS
8 commissions, and there were e-mails and 8 portfolio customers that Ms. Williams had, I
9 correspondence to that effect, and I know that 9 had -- was -- had made several proposals, I
10 Mr. Groves went through a number of draft 10 think both to AIG and to Zurich, that if she
11 brokerage agreements with Ms. Williams, but we 11 brought a customer in that would again be
12 had an agreement, for sure, verbal, that there 12 tranche risk, and we would pay her for
13 was a 50/50 split on any deal she brought to 13 bringing those to the table.
14 CAM. 14 Q. Was that part of the same
15 Q. Let me read for you Ms. Williams' 15 co-brokerage agreement, or was it a separate
16 interrogatory response to Fannie Mae, and the 16 agreement?
17 interrogatory asked Ms. Williams to describe 17 A. No, it would be part of the
18 the contents and scope of her joint venture or 18 general. It would encompass anything she
19 co-brokerage agreement. Her response to that 19 brought us.
20 was, quote: I had a simple, common 20 Q. And we've been talking about Risk
21 co-brokerage agreement with CAM Financial that 21 Mitigation Strategies.
22 entailed paying them a commission in the event 22 Did CAM Financial have any
23 that they secured the insurance that I needed 23 co-brokerage agreements with Marialice
24 on any of the proposals that I was working on. 24 Williams as opposed to Risk Mitigation?
25 These proposals ranged from insuring pools of 25 A. I am not understanding the
Page 27 Page 29
1 automobile loans, charter school loans, 1 question.
2 captive insurance, and reinsurance, etc. 2 Q. We've talked a little bit about
3 Is that an accurate 3 an agreement that CAM Financial Services had
4 characterization of Risk Mitigation 4 with Risk Mitigation Strategies, LLC, and my
5 Strategies' agreement with CAM? 5 question to you is whether CAM had a separate
6 A. Could you repeat that? 6 agreement, co-brokerage agreement with
7 Q. Sure. 7 Ms. Williams?
8 "I had a simple, common 8 A. I couldn't answer that because of
9 co-brokerage agreement with CAM Financial that 9 whether it entailed how her surplus lines
10 entailed paying them a commission in the event 10 license read. I think a surplus lines license
11 that they secured the insurance that I needed 11 is for an individual, but again, it would be
12 on any of the proposals that I was working on. 12 part of the overall agreement.
13 These proposals ranged from insuring pools of 13 Q. Do you recall, Mr. Jones, when
14 automobile loans, charter school loans, 14 the co-brokerage agreement was first entered
15 captive insurance, and reinsurance." 15 into?
16 A. I would say that was a reasonably 16 A. It would have been shortly after,
17 accurate statement. I think when she means 17 or in the three months, four months following
18 reinsurance and captive, that she's referring 18 her leaving Fannie Mae. It would have been in
19 to tranche risk, and that would include 19 the fall of '98 if I would put a time frame on
20 mortgages. 20 it. That's when Mr. Groves was working with
21 Q. And with that caveat, you think 21 her on brokerage agreements.
22 that her characterization is accurate? 22 Q. Mr. Jones, I am going to show you
23 A. I have no reason to disagree with 23 what's been marked as Jones Exhibit 4. It's a
24 it. 24 letter from Marialice Williams to Lou Hoyes,
25 Q. Other than the co-brokerage 25 and it is dated February 2nd, 1999.
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1 Just for the record, I would ask 1 Q. By February 2nd, 1999, it was
2 you to read the second paragraph of that 2 clear that was not going to happen; is that
3 letter. 3 correct?
4 A. "As you are aware, I left Fannie 4 A. Well, we were still -- I don't
5 Mae in July after being offered an appointment 5 think we were asking for it any further at
6 and ownership opportunities with CAM Financial 6 that time, and we were just trying to continue
7 Services, Inc.; however, after months of 7 to do some kind of business together, which
8 negotiations with its cast of principals, I 8 would help Ms. Williams.
9 was unable to reach any agreement with them 9 Q. And did -- I asked you whether
10 whatsoever. With Mr. Lee and Mr. Moore, RMS, 10 CAM Financial Services and Risk Mitigation
11 made a bid last year to purchase CAM, but this 11 Strategies had ever joined into a joint
12 offer, too, was rebuffed." 12 venture.
13 Q. Is it fair to say as of February 13 Did CAM Financial Services and
14 2nd, 1999, the only agreement between CAM 14 Marialice Williams ever enter into a joint
15 Financial Services and RMS for Marialice was 15 venture?
16 the co-brokerage agreement? 16 A. We did not, or they did not. I
17 A. I believe that's a correct 17 can't -- I am here to appear as an individual.
18 statement, and there's something in here about 18 Q. Did you work on any non-Fannie
19 the opportunities for appointment. The cast 19 Mae projects with either Ms. Williams or Risk
20 of principals at CAM had asked that Marialice 20 Mitigation Strategies?
21 be able to get a letter from Lou Hoyes that 21 A. Yes, we did. We worked on --
22 indicated her leaving, that she did not have a 22 with Mr. Hoyes' permission, we worked on a
23 non-compete clause with Fannie Mae, and I 23 commercial certificates coverage for a -- it
24 don't know, for some reason or other, 24 wasn't certificates -- it was commercial
25 Ms. Williams could not get that letter from 25 mortgage portfolio for Metropolitan Bank.
Page 31 Page 33
1 Mr. Hoyes. 1 Mr. Hoyes gave us permission, Ms. Williams and
2 Q. So I can get back to the 2 I, to pursue that, because Fannie Mae could
3 question, just to make sure I have a clean 3 not provide, or could not purchase the
4 answer, but the question was: Is it fair to 4 mortgage back that had a significant amount of
5 say, as of early February, as of February 2nd, 5 commercial loans in it as Metropolitan had
6 1999, the only agreement between CAM and the 6 requested, and that was the first venture
7 Risk Mitigation Strategists, LLC with 7 outside of a Fannie Mae portfolio, and we
8 Ms. Williams was a co-brokerage agreement? 8 were -- she and I continued to work on captive
9 A. To the best of my knowledge. 9 insurance. I think it's part of my
10 Q. And is it also fair to say that 10 deposition. She -- to some certain extent
11 no other agreements, to use the language of 11 worked with her on First Atlantic on a
12 the letter, whatsoever had been reached? 12 certificate coverage. Again, we were -- CAM's
13 A. I think that's an accurate 13 role would have been to find the insurance
14 statement. 14 capacity. It was policies -- that particular
15 Q. Did CAM Financial Services and 15 policy Marialice Williams had developed for
16 Risk Mitigation Strategies, LLC ever enter 16 certificate coverage.
17 into a joint venture? 17 Q. And how long did you continue to
18 A. No. That was part of the 18 do business with Ms. Williams or RMS?
19 agreement that was supposed to be coming from 19 A. Again, this was product
20 Mr. Hoyes that would have enabled Ms. Williams 20 development. Probably the DUS transactions
21 to form an MWOB? MWOB, yeah, and that would 21 for DUS customers. We were pursuing tranche
22 be tied together with marketing with CAM 22 coverage. That would have been Fannie Mae
23 Financial Services. That was something that 23 2000 -- Mr. Griffin, I can't remember when,
24 Mr. Hoyes had promised Ms. Williams at her 24 but it would have been 2001, I would say in
25 exit. 25 August -- well, actually, it was May, June,
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1 July, and August, and we were looking for 1 we off?
2 tranche coverage for the DUS portfolios. She 2 MR. GRIFFITH:
3 asked us if we could find insurance companies. 3 Yes. Off the record.
4 That was the project she was working on for 4 THE VIDEOGRAPHER:
5 Fannie Mae, and we were only working on it 5 Going off of the record. It's
6 from the insurance perspective. 6 10:05. Videotape No. 1.
7 Q. And were there any other product 7 (Brief Recess.)
8 development projects that you were working on 8 THE VIDEOGRAPHER:
9 with Ms. Williams, other than the DUS project? 9 We are back on the record. It's
10 A. And the others that we talked 10 10:13. Beginning of videotape No. 2.
11 about. 11 EXAMINATION BY MR. GRIFFITH:
12 Q. And the others that we talked 12 Q. Mr. Jones, did you have anything
13 about, yes. 13 you wanted to clarify on the record?
14 A. She brought a charter, or 14 A. I do. You asked if there were
15 introduced a charter loan program for charter 15 any transactions that were ever consummated
16 schools, but I don't believe we got involved 16 between CAM and Risk Mitigation. There was an
17 in that with her. I am not sure how far that 17 application fee of $10,000 that was taken from
18 went. 18 -- I believe the company was First Atlantic,
19 Q. And you mentioned that the work 19 and it was for the purpose of developing a
20 you were doing with her was product 20 captive insurance policy for captive coverage,
21 development work. 21 and those fees were split between Risk
22 Did you do any actual 22 Mitigation and CAM.
23 transactions with Ms. Williams, or with her 23 Q. Do you recall when that
24 company, Risk Mitigation Strategists, LLC? 24 transaction took place?
25 A. I don't recall any actual 25 A. I don't.
Page 35 Page 37
1 transactions. 1 Q. And we talked a little bit, prior
2 Q. Did CAM ever breach its 2 to the break, about a DUS transaction
3 co-brokerage agreement with Risk Mitigation 3 involving Fannie Mae and several other --
4 Strategists, LLC? 4 several other product development projects
5 A. I didn't hear you. 5 that CAM worked on with Ms. Williams or Risk
6 Q. Did CAM Financial Services ever 6 Mitigation Strategists, and I believe you
7 breach its co-brokerage agreement with Risk 7 testified about the timing of the DUS
8 Mitigation Strategists, LLC? 8 transaction. On the non-Fannie Mae
9 A. I am not aware if we did. I 9 transactions, can you give me a time frame for
10 don't know how broad breach is. 10 those?
11 Q. Is the co-brokerage agreement 11 A. The commercial transaction that
12 still in effect? 12 Marialice Williams and CAM worked on for
13 A. I don't know. I am not at CAM 13 Metropolitan, this did not close, but it was
14 anymore. 14 in August -- August of 1998 is to the best of
15 Q. Was it in effect as of the date 15 my recollection of when she and I talked to --
16 that you stepped down as president of CAM 16 had a conference call with Lou Hoyes, and that
17 Financial? 17 was the non-Fannie Mae transaction.
18 A. I know no reason why it was ever 18 Q. And then you've testified about
19 terminated, I just couldn't answer that, 19 the First Atlantic transaction.
20 because Mr. Groves was responsible for 20 What about the charter
21 brokerage agreements. 21 transaction?
22 Q. Would you like to take a quick 22 A. That was just product development
23 break, Mr. Jones? 23 that Ms. Williams was working on, and she may
24 THE WITNESS: 24 have sent a term sheet to me, but we did not
25 Sure. Get some fresh water. Are 25 get involved in that. CAM did not get
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1 involved in that. 1 those sentences mean?
2 Q. Mr. Jones, are you familiar with 2 A. I think this is something --
3 Grace Huebscher? 3 Danny Groves had been talking with Zurich
4 A. I am. 4 Insurance, or Zurich North American, and it
5 Q. Who is Ms. Huebscher? 5 was like to tweak their interest. They had, I
6 A. Grace Huebscher, at the time I 6 believe, something called asset deficiency,
7 knew her, was heading the -- Fannie Mae's 7 and Mr. Groves was looking at perhaps
8 aggregation program. 8 modifying the MCRI program. I don't recall
9 Q. And can you tell me a little bit 9 whether there was a separate policy that
10 about what that aggregation program is? 10 Zurich had. I think there was a separate
11 A. The aggregation program was where 11 policy that Zurich had called "asset
12 Fannie Mae purchased whole loans from 12 deficiency insurance."
13 seller/servicers to do whole loans. I am 13 Q. I want to get back to a
14 referring strictly to multi-family whole loans 14 discussion we started about Ms. Huebscher.
15 now for approved Fannie Mae seller/servicers, 15 Did you ever have any discussions
16 and then those loans are purchased for cash, 16 with Ms. Huebscher about Marialice Williams or
17 and Fannie Mae then holds those loans in 17 Risk Mitigation Strategies, LLC after
18 portfolio, and were the -- using the MCRI 18 Ms. Williams left Fannie Mae?
19 insurance product to insure -- to lay off the 19 A. Yes.
20 risk of first-loss exposure. 20 Q. And when would have those
21 Q. Mr. Jones, I am going to show you 21 discussions have occurred?
22 what I am going to mark as Jones Exhibit 5. 22 A. We were at a mortgage bankers
23 It's a document with the Bates label 7918, and 23 CREF conference. When I say "we,"
24 at the top it appears to be an e-mail from 24 Ms. Williams, Ms. Huebscher, and me, and we
25 Ms. Williams to Bob Jones "CC-ing" an 25 would have -- we had some conversation with
Page 39 Page 41
1 H. Hartsfield. 1 Grace Huebscher at that conference about the
2 Take a look at that document. 2 mortgage insurance programs.
3 A. (Witness reviews document.) 3 Q. And do you recall when those
4 Q. My first question on this 4 conversations would have taken place?
5 document is whether this document relates to 5 A. After Marialice Williams left
6 the DUS proposal that we previously discussed 6 Fannie Mae. I'm trying to remember where that
7 involving Risk Mitigation Strategists? 7 conference -- there's an annual CREF
8 A. I believe Marialice Williams was 8 conference. I can picture us standing
9 talking with Fannie Mae at this time with -- 9 together, but I can just tell you it was after
10 it appears to be with Ken Bacon -- and there 10 Marialice Williams left Fannie Mae, and it's
11 was apparently some concern about risk-based 11 probably about this same time frame here.
12 capital and covering a mezzanine level, either 12 Q. By "this same time frame," in the
13 first loss -- it appears that it's above the 13 early to mid part of 2001?
14 first five percent, and, yes, this would be 14 A. Correct.
15 during that same time frame that she was 15 Q. And that was a discussion --
16 pursuing this coverage for three DUS lenders. 16 A. Something jogged. Ms. Williams,
17 Q. In the top of the -- there is two 17 at the same conference, talked to Ken Bacon
18 e-mails. It looks like one is responding to 18 about the -- insuring the DUS risk.
19 the other, and in the bottom e-mail, the top 19 Q. And the conversation you had
20 of that it reads, "Bob Jones wrote: Danny and 20 about Ms. Williams and RMS, Ms. Williams was
21 I have talked. We would like to treat this as 21 present for that conversation?
22 a separate business relationship from CAM's 22 A. Repeat that question?
23 relationship with Fannie Mae and Aggregation 23 Q. I asked you whether you had had
24 and MBS." 24 any discussions with Ms. Huebscher about
25 Can you tell me what that means, 25 Marialice Williams or Risk Mitigation
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1 Strategies, LLC, and you mentioned this one 1 Q. Okay.
2 meeting at the conference with yourself and 2 Did Ms. Huebscher make any
3 Ms. Williams and Ms. Huebscher. 3 disparaging remarks about Ms. Williams or Risk
4 Other than that conversation, did 4 Mitigation Strategists, LLC to you?
5 you have any other conversations with 5 A. I don't recall.
6 Ms. Huebscher about Marialice Williams or Risk 6 Q. Did Ms. Huebscher ever -- strike
7 Mitigation Strategists, LLC? 7 that.
8 A. I don't recall specific 8 Did Ms. Huebscher ever discuss
9 conversations, but they could have occurred in 9 Ms. Williams' business acumen with CAM
10 e-mails. I am not going to rule out that 10 Financial or with you?
11 there -- I just remember that one specific 11 A. I don't have any knowledge or
12 one, and then there was a specific 12 recall.
13 conversation with Ken Bacon with Marialice 13 Q. Do you recall whether
14 Williams and myself, and Mr. Bacon had said 14 Ms. Huebscher ever made any false statements
15 for Marialice to please get in touch with him 15 to you about Ms. Williams or Risk Mitigation
16 afterward -- got back to Washington. 16 Strategists, LLC?
17 Q. And the conversation you had with 17 A. I have no recall. I don't think
18 Ms. Huebscher, Ms. Williams was present for 18 so.
19 that conversation? 19 Q. Are you familiar with Richard
20 A. Correct. 20 Lawch?
21 Q. And do you recall any other 21 A. I am.
22 specific conversations with Ms. Huebscher 22 Q. Who is Mr. Lawch?
23 about Marialice Williams or Risk Mitigation 23 A. He's a Fannie Mae employee, a
24 Strategists, LLC? 24 vice president, and at the time I knew him, he
25 A. I am thinking. My memory's not 25 was the number-two person in multi-family as
Page 43 Page 45
1 as good as it used to be. Lou Hoyes, Rhoda 1 far as the organization structure was
2 Newman. There was conversations with Mari -- 2 concerned, and I guess you could say he was
3 I just don't know that -- Rhoda Newman, after 3 Marialice Williams' direct boss.
4 Marialice Williams left, reported to Grace 4 Q. Did you have any discussions with
5 Huebscher. I believe that's correct, and I 5 Mr. Lawch regarding Marialice Williams or Risk
6 know there were conversations with Rhoda 6 Mitigation Strategies, LLC after she -- after
7 Newman, Marialice Williams, and myself. I 7 Ms. Williams left Fannie Mae?
8 just don't know that Grace Huebscher was ever 8 A. After she left?
9 a party to those calls or not. 9 Q. Yes.
10 Q. Did you ever have any 10 A. I had conversations with Richard
11 conversations with Ms. Huebscher about 11 Lawch before she left. I am trying to think
12 Marialice Williams or Risk Mitigation 12 if there is any e-mails that involved me with
13 Strategists, LLC, for which Ms. Williams was 13 either Richard or Grace with Marialice after
14 not present? 14 she left Fannie Mae. At another CREF
15 A. I just don't recall. 15 conference, I remember Marialice and I were
16 Q. Did Ms. Huebscher ever tell CAM 16 walking toward Richard. This was after she
17 Financial Services not to do business with 17 left Fannie Mae, and Richard turned his back
18 Ms. Williams or Risk Mitigation Strategists, 18 on us and refused to speak to us, and this was
19 LLC? 19 in a lobby of one of the main hotels, and he
20 A. Not that I recall. 20 just got involved in some other conversations
21 Q. Do you recall any disparaging 21 with some other people, but it was obvious he
22 remarks that Ms. Huebscher made to you about 22 didn't want to have any -- for some reason,
23 Ms. Williams or Risk Mitigation Strategists, 23 and I thought it was strange why he would not
24 LLC? 24 have -- why he would -- because he saw me, and
25 A. Repeat that question again? 25 I was walking into this reception area, I
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1 think it was. 1 A. You are going to have to
2 Q. Do you recall when this 2 elaborate on that. It's professional. It's a
3 conference was? 3 professional relationship.
4 A. It's a different one from the -- 4 Q. Is it a close professional
5 it might have been the same CREF conference 5 relationship?
6 where Marialice -- I think it was the same 6 A. I am sorry?
7 CREF conference where Marialice Williams and I 7 Q. A close professional
8 had a conversation with Richard -- with Grace 8 relationship?
9 Huebscher and Ken Bacon. 9 A. Reasonable -- yes. I treated
10 Q. Thank you for that. 10 Marialice as a friend, very good friend, but
11 I want to return to my original 11 it was professional, but family friend.
12 question, because I don't think you actually 12 Q. And we've been talking a little
13 answered the question, so let me ask it again. 13 bit about a proposal involving DUS loans, and
14 The question was whether you had 14 I wanted to focus you on a couple of documents
15 any discussions with Mr. Lawch about Marialice 15 to make sure I understand what the proposal
16 Williams or Risk Mitigation Strategies, LLC 16 entailed, and let me show you what I am going
17 after Ms. Williams left Fannie Mae. 17 to mark as Jones Exhibit 6. It is an e-mail
18 A. I don't recall. 18 dated May 15th, 2001, from Bob Jones to
19 Q. You don't recall any? 19 Stephen Noble, and it's got Bates numbers 8015
20 A. No. 20 through 8017.
21 Q. Other than -- strike that. 21 Mr. Jones, do you recognize this
22 Did you talk to anybody else at 22 document?
23 Fannie Mae about Marialice Williams or Risk 23 A. I do.
24 Mitigation Strategies, LLC after Ms. Williams 24 Q. And does this reflect the DUS
25 left Fannie Mae? 25 proposal that we've been discussing here
Page 47 Page 49
1 A. Rhoda Newman and I would have had 1 today?
2 several conversations. I can't tell you the 2 A. Yes. This is the -- this is that
3 content of any of them, but Rhoda Newman and 3 DUS proposal.
4 Marialice Williams were very good friends, and 4 Q. And in her interrogatory
5 so was Betty Dance. There would be 5 responses, Ms. Williams, in a response to a
6 conversations that would come up. "We saw 6 question about a May 2001 proposal, indicated
7 Ms. Williams -- we saw Marialice. She came by 7 that the May 2001 proposal entailed the laying
8 this past week," or something like that to 8 off of risks associated with the Delegated
9 their offices there at Fannie Mae. Those kind 9 Underwriting Servicing program.
10 of conversations occurred. 10 Is this the same transaction or
11 Q. Just to make sure I understand 11 the same proposal?
12 who those conversations were with, they would 12 A. May of 2001?
13 have been with Rhoda Newman or Betty Dance? 13 Q. Yes.
14 A. That's correct. 14 A. I wasn't a party to that
15 Q. Did either Ms. Newman or 15 interrogatory, but I would -- it's the same
16 Ms. Dance make any disparaging remarks about 16 time frame, and it involves the same 26 DUS
17 Ms. Williams? 17 lenders. Yes.
18 A. Not that I recall, other than 18 Q. And can I ask you to read -- to
19 that Marialice was trying to drum up business. 19 turn to the third page of the exhibit, Bates
20 That's probably all related to that DUS 20 labeled 8017, and read for me the first
21 program I was talking about. I am assuming 21 sentence under "laying off the risk "?
22 that's why she was there. That and the 22 A. "RMS is seeking insurance
23 captive company. 23 coverage for three DUS lenders who want to lay
24 Q. Can I ask you just what type of 24 off their risk obligation on their DUS
25 relationship you have with Ms. Williams? 25 portfolio."
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1 Q. Does this accurately reflect the 1 were involved in this proposal?
2 DUS proposal that we, or the May proposal that 2 A. The specific insurance company
3 we've been discussing? 3 that we were writing to here is Zurich U.S.,
4 A. I believe it is, yes. I believe 4 or Zurich North American, and then I had had
5 it is. 5 some conversation with AIG also. Danny had
6 Q. The sentence talks about three 6 the first conversation with Zurich, Danny
7 DUS lenders. 7 Groves.
8 Do you recall who those lenders 8 Q. And were there any other
9 were? And I don't want to make this a memory 9 insurance companies that you discussed this
10 test. If you look at the paragraph above it, 10 proposal with?
11 there is a discussion, so that may jog your 11 A. Not me. Mr. Groves may have,
12 memory. 12 but...
13 A. That is the same three lenders. 13 Q. Sitting here today, you don't
14 Q. That is HomeStreet Capital, Lend 14 know whether Mr. Groves would have discussed
15 Lease (Bovis) Real Estate Investments, and Red 15 this with other ones, or that he did discuss
16 Mortgage Capital Group? 16 this with other insurance carriers?
17 A. That is correct. 17 A. I don't know.
18 Q. And did the proposal involve any 18 Q. And in this proposal, is it fair
19 other specific lenders? 19 to say that you didn't identify any specific
20 A. It could. This was the 20 lenders, other than the three DUS lenders that
21 preliminary, and this was the first three 21 are listed on -- in the fourth paragraph of
22 lenders that Marialice was working with. 22 Page 3 of this exhibit?
23 Q. So this specific proposal only 23 A. Well, I did not in my e-mail -- I
24 related to these three, but there was a 24 did not identify those lenders, but they were
25 possibility for future -- 25 identified by Ms. Williams in her opportunity
Page 51 Page 53
1 A. For others. I think they -- 1 to provide insurance coverage from mezzanine
2 these were three of the large ones, and -- 2 tranche risk.
3 Q. And it hadn't gotten to the point 3 Q. And does this document refresh
4 where the proposal actually involved those 4 your recollection as to whether -- strike
5 other lenders? 5 that.
6 A. She indicates in there that 6 Was this proposal being made by
7 there's 65 billion or so in the write-up 7 Risk Mitigation Strategies, LLC and CAM as
8 somewhere. 64 billion that would probably 8 co-brokers?
9 encompass the majority of those. 9 A. Yes, it would be. No, let me
10 Q. Let me ask you to turn to the 10 elaborate on that. The clients would be
11 first page, in the second paragraph, and the 11 Ms. Williams and Fannie Mae. The insurance
12 second sentence reads, "There may also be 12 companies are co-brokerage -- would be CAM
13 several other DUS Lenders having an interest 13 Financial Services for the insurance coverage.
14 in this coverage at some point in time." 14 Q. And can you tell me what CAM
15 And so, what can you tell me what 15 Financial Services' role was in this
16 that sentence means? 16 particular proposal?
17 A. Well, I think it's what she's 17 A. To locate the insurance coverage
18 referring to is this broker could be expanded 18 for Ms. Williams and Fannie Mae.
19 to other lenders. 19 Q. And what was Risk Mitigation
20 Q. Is it fair to say that the 20 Strategies' role in this proposal?
21 proposal that you were submitting to Mr. Noble 21 A. In representing those three --
22 at Zurich involved three particular lenders, 22 those DUS lenders to lay off the risk on their
23 but then also -- involved three and also -- 23 portfolios, and in conjunction with Fannie
24 actually, just strike that. 24 Mae, not just the three DUS lenders. The
25 Can you tell me what insurers 25 Fannie Mae and the DUS lender are responsible,
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1 because that is Fannie Mae risk also. It's 1 Richard Lawch, my notes reflected that CAM
2 not just the DUS lender's risk. 2 was -- there were ten-page notes on those
3 Q. Mr. Jones -- 3 yellow legal pads that it was our
4 A. In fact, it's a pair of pursuit. 4 understanding, CAM's understanding that we
5 It is both lenders, both Fannie Mae and the 5 were exclusive.
6 DUS lender. 6 Q. Did you have these -- did you
7 Q. When was the last work that 7 have these discussions with Marialice Williams
8 you -- that CAM Financial did on this 8 while she was at Fannie Mae? Is that correct?
9 proposal? 9 A. I don't know if we had specific
10 A. With Zurich -- I think we had the 10 conversations to that effect. She was
11 open door with Zurich and AIG, and it was 11 thinking -- I think she was of the same
12 another company that came along later, but I 12 opinion that, under Mr. Lawch's direction,
13 think it was a captive. It would have been 13 that there was going to be MOUs with each new
14 this time frame from May to -- I would say the 14 insurance company, and in fact, Ms. Williams
15 window would have probably been May to August, 15 is the one that reflected on that for us to
16 and we were waiting for Ms. Williams and 16 bring the GenStar, GenRe, Crump, and others,
17 Fannie Mae to give us direction. 17 in addition to AIG, and that was under the
18 Q. And did you ever get any 18 direction of Mr. Lawch.
19 direction from Ms. Williams or Fannie Mae? 19 Q. Did you have any discussions with
20 A. Later from Ms. Williams that 20 Ms. Williams after she left Fannie Mae about
21 Fannie Mae wasn't pursuing this coverage, but 21 CAM's exclusive relationship with Fannie Mae?
22 they asked her to come in to make a captive 22 A. The conversations would have
23 insurance proposal for Fannie Mae, and again, 23 been, when she was in the process of leaving,
24 we would have been involved in that. 24 during the time where -- from May to June, or
25 Q. And can you tell me about the 25 May to July when she was leaving Fannie Mae
Page 55 Page 57
1 captive insurance proposal? 1 that -- I think we all believed that CAM had
2 A. I only know that -- I think maybe 2 the exclusive with Fannie Mae and that
3 I was copied on some e-mails that Ms. Williams 3 Ms. Williams was negotiating with Lou Hoyes to
4 was making a captive presentation in about 4 expand that exclusive where she would -- where
5 August of 2001. It's somewhere in that time 5 Ms. Williams would have the marketing
6 frame, August, September, and on the direction 6 exclusive with her lenders, and that that
7 of Rhoda Newman and Grace Huebscher. 7 would -- that business would be coming to
8 Q. Is it your understanding of CAM's 8 Fannie Mae, and then CAM would be insuring
9 agreement with Fannie Mae that -- I think 9 that business. That was, to my knowledge, was
10 you've actually testified to this before, so 10 what she had discussed with Mr. Hoyes prior to
11 just let me confirm it, that Fannie Mae agreed 11 her leaving Fannie Mae. That's when I
12 that CAM was to be the sole and exclusive 12 mentioned the MWOB.
13 agent for Fannie Mae in the procurement of 13 Q. Was it -- is it -- was it CAM's
14 MCRI insurance? 14 understanding that Fannie Mae had to do any
15 A. That's my testimony. 15 business, any MCRI business involving GenStar
16 Q. And did you ever discuss this 16 or GenRe through CAM?
17 exclusive relationship with Ms. Williams? 17 A. Yes.
18 A. Yes. Once she was at Fannie Mae. 18 Q. And CAM also had an exclusive
19 We went through a -- those MOUs, as you are 19 relationship with GenStar through Crump; is
20 very much aware of, and some subsequent MOUs, 20 that correct?
21 and I think it was everybody's, at that time, 21 A. That was the brokerage. We had a
22 it was of everybody's opinion that -- I think 22 wholesaler between us. When I say "we," CAM
23 you have seen my notes that, from two 23 and Fannie Mae would go through Crump as its
24 conversations, one that involved Marialice 24 wholesaler -- not Fannie Mae, but CAM would,
25 Williams and Richard Lawch, and the other with 25 because that's the insurance side of the
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Robert G. Jones
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1 transaction, and that's -- I think there's 1 making any disparaging remarks about
2 agreements to that. 2 Ms. Williams to you, and you also testified
3 Q. Just to make sure I understand 3 that you didn't recall having any
4 it, Crump agreed to exclusively write MCRI 4 conversations about Ms. Williams or RMS, Risk
5 through CAM, and GenStar committed to write 5 Mitigation Strategies, with Mr. Lawch.
6 MCRI exclusively through Crump; is that 6 My question now is: Do you
7 correct? 7 recall discussing that type of conversation
8 A. That's correct. Worked both 8 with Ms. Williams?
9 ways. And that same exclusive with Crump was 9 A. Before or after she departed
10 to be developed with other insurance carriers. 10 Fannie Mae? I'm not with you.
11 MR. GRIFFITH: 11 Q. After she departed Fannie Mae.
12 Can we go off the record for a 12 A. With either Mr. Lawch or
13 little bit? 13 Ms. Huebscher?
14 THE VIDEOGRAPHER: 14 Q. Yes.
15 We are going off the record. 15 A. Only -- the only one I am
16 This is videotape No. 2. 16 somewhat familiar with, or would be familiar
17 (Brief recess) 17 with is an e-mail that Ms. Williams told me
18 THE VIDEOGRAPHER: 18 about that was in late May or early June of
19 We are going back on the record. 19 2001, of which you know about, and that's of
20 It's 11:13. This is videotape No. 2. 20 whether or not they were going to pursue this
21 EXAMINATION BY MR. GRIFFITH: 21 coverage with Ms. Williams, and that e-mail --
22 Q. Mr. Jones, we have discussed 22 that's a long time ago, and we furnished the
23 today a May 2001 proposal involving DUS loans, 23 original of that e-mail to Fannie Mae. I
24 and we've also touched on a discussion 24 think it was part of my deposition, but that
25 regarding captive insurance, both of which 25 something about Fannie Mae was pursuing
Page 59 Page 61
1 involved Ms. Williams. 1 different strategies or something, or
2 Are you aware of any other 2 considering Craig Ott for that type of
3 proposals that Ms. Williams made to Fannie Mae 3 coverage, depending on Mr. Lawch's comments,
4 after the time she left? 4 depending on risk-based -- what OFHEO said
5 A. I am thinking, but I am not sure. 5 about risk-based capital.
6 She may have made some. I don't know. 6 Q. Other than that, you are not
7 Q. But sitting here today, you can't 7 aware of anything?
8 -- 8 A. That's the -- at this time, I
9 A. These are the ones I am familiar 9 can't think of any others. We gave you that.
10 with. 10 Could we take a time out
11 Q. These two are the ones that you 11 technically for a technical problem?
12 recall? 12 MR. GRIFFITH:
13 A. Correct. 13 Sure. Let's go off the record.
14 Q. And you don't recall today any 14 THE VIDEOGRAPHER:
15 others? 15 We are going off of the record.
16 A. Not offhand. 16 It's 11:17. This is videotape No. 2.
17 Q. Now, you testified earlier that 17 (Brief recess)
18 you don't recall any conversations with 18 THE VIDEOGRAPHER:
19 Ms. Huebscher regarding -- 19 We are back on the record. It's
20 A. I am sorry. I am having some 20 11:19. This is videotape No. 2.
21 trouble. Some technical problems. 21 EXAMINATION BY MR. GRIFFITH:
22 Q. Just let me know if you don't 22 Q. Mr. Jones, I am going to give you
23 hear me. I will try to speak loudly. 23 what's been marked as Jones Exhibit 7. It's a
24 Mr. Jones, you testified earlier 24 document, Bates labeled 6230 through 6232, and
25 today that you didn't recall Ms. Huebscher 25 I have also included, attached to that is a
16 (Pages 58 to 61)
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1 document that's Bates labeled 8031. 1 We couldn't hear you over hear.
2 Can you take a look at that 2 EXAMINATION BY MR. DANIELS:
3 document for me, please? 3 Q. Isn't it true, Mr. Jones, that
4 A. (Witness reviews document.) 4 you are a person of the --
5 Okay. 5 THE COURT REPORTER:
6 Q. And Mr. Jones, is Exhibit 7 the 6 The white race?
7 e-mail that you were referring to in your 7 MS. GOLDFRANK:
8 previous testimony? 8 Yes.
9 A. That's correct. 9 EXAMINATION BY MR. DANIELS:
10 Q. Thank you. 10 Q. -- white race?
11 Mr. Jones, you testified 11 A. Caucasian, white.
12 previously that you did not recall speaking 12 Q. Isn't it true that Mr. Groves is
13 with Mr. Lawch about Marialice Williams or 13 a member of the Caucasian race?
14 Risk Mitigation Strategies, LLC, correct? 14 A. That's correct.
15 A. After... 15 Q. Isn't it true that Mr. Rumsey is
16 Q. After Ms. Williams left Fannie 16 a member of the Caucasian race?
17 Mae; is that correct? 17 A. Yes.
18 A. That is correct. 18 Q. Isn't it true that Mr. Craig Ott
19 Q. And after Ms. Williams left 19 is a member of the Caucasian race?
20 Fannie Mae, I take it then that you don't 20 A. I believe so, yes.
21 recall any conversation in which Mr. Lawch 21 Q. Did CAM have any -- isn't it true
22 told CAM not to do business with Ms. Williams? 22 that all of the CAM shareholders were members
23 A. I don't recall of any 23 of the Caucasian race?
24 conversations. 24 A. That's correct.
25 Q. And you don't recall any 25 Q. Now, isn't it true that you began
Page 63 Page 65
1 conversations in which Mr. Lawch made any 1 to seek business from Fannie Mae in
2 disparaging remarks about Ms. Williams after 2 approximately 1992, 1993?
3 she left Fannie Mae? 3 A. Our first meeting with Fannie
4 A. I don't recall of any. 4 Mae -- well, with DUS lenders, I was already
5 Q. And you don't recall any false 5 doing -- CAM was already doing business with
6 statements that Mr. Lawch made to you about 6 DUS lenders, and then, yes, that's correct.
7 Ms. Williams after she left Fannie Mae? 7 We went to Fannie Mae. CAM went to Fannie Mae
8 A. Well, same answer; same question. 8 with one of those DUS lenders in either late
9 Q. Really just the same question. 9 '93 or early '94.
10 MR. GRIFFITH: 10 Q. And what was the nature of that
11 I don't have anything further. 11 business?
12 EXAMINATION BY MR. DANIELS: (Via telephone) 12 A. Prior to Fannie Mae, it was
13 Q. This is Harley Daniels asking 13 multi-family mortgage brokerage, and then
14 questions of Mr. Jones. 14 involving Fannie Mae was the introduction and
15 Are you receiving me? 15 development of a multi-family mortgage
16 A. I hear you, Mr. Daniels. 16 insurance coverage policy in the early
17 Q. For the record, Mr. Jones, isn't 17 development stages.
18 it true that you are a person of the -- 18 Q. Now, at that time, did Mr. Groves
19 THE COURT REPORTER: 19 have any experience in the area of the
20 I'm sorry. I can't understand 20 secondary mortgage market?
21 that. 21 A. Is he saying Mr. Groves?
22 THE WITNESS: 22 Q. Yes.
23 I can't hear that. 23 A. Only on the -- can you repeat
24 MS. GOLDFRANK: 24 that question?
25 You'll have to repeat yourself. 25 MR. GRIFFITH:
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1 Maybe we'll see if the court 1 (Court reporter reads back previous question)
2 reporter can repeat it. 2 EXAMINATION BY MR. DANIELS:
3 MR. DANIELS: 3 Q. That was the development of
4 Certainly, please. In fact, if 4 low-income housing.
5 Mr. Jones would direct those questions to the 5 A. That is correct. On the
6 court reporter, I'd appreciate it. 6 inner-city, mid-city properties on low to
7 (Court reporter reads back prior question) 7 "mod" incoming housing, there was not an
8 THE WITNESS: 8 execution that was efficient in the
9 Not to my knowledge. 9 marketplace.
10 EXAMINATION BY MR. DANIELS: 10 Q. And was this fact, the fact that
11 Q. Did Mr. Rumsey have any 11 it would improve the ability of Fannie Mae to
12 experience in that area? 12 issue loans in urban areas more efficiently,
13 A. With -- only with REO, real 13 was this generally known to Richard Lawch and
14 estate owned. Multi-family REO with Freddie 14 Grace Huebscher and the people you were
15 Mac and Fannie Mae. 15 dealing with at Fannie Mae?
16 Q. You would agree it was not a 16 A. No. Only Marialice Williams.
17 major part of his expertise at that time; is 17 Q. Now --
18 that correct? 18 A. Well, wait, wait.
19 A. On the secondary market, that is 19 MR. GRIFFITH:
20 correct. This is the property set that 20 Hold on a second. I think
21 tanked. 21 Mr. Jones is going to finish his answer.
22 Q. And, Mr. Jones, your experience 22 THE WITNESS:
23 was basically in the insurance area; isn't 23 There were some changes in
24 that correct? 24 accounting in how risk-based capital was
25 A. No. My experience was mortgage 25 reported at the thrift and at the -- for
Page 67 Page 69
1 banking. My background was mortgage banking, 1 commercial banks that Mr. Lawch would have
2 and yes, I had some insurance experience. 2 known about, because the -- that particular
3 Q. And isn't it fair to say that the 3 type transaction had -- there was a void in
4 general subject of what you were trying to 4 the marketplace, and for that -- for those
5 accomplish with Fannie Mae would be the merger 5 portfolios to be sold to Fannie Mae, and that
6 of insurance and mortgage -- secure-type 6 was the -- I would -- I can't speak for
7 mortgages? 7 certain that Mr. Lawch would have known about
8 A. That is correct. In laying off 8 that, but Fannie Mae's volume had dried up
9 risk in hard to -- in the inner-city of 9 for -- from those banks and thrifts that were
10 America where thrifts and commercial banks -- 10 trying to sell their mortgages, and both
11 where there was a void there, and it was to -- 11 Fannie Mae and Freddie Mac corporately would
12 our -- the objective that we were wanting to 12 have known that that execution was no longer
13 -- that CAM or that Bob Jones wanted to -- it 13 available because of the changings in the
14 was combining those two experiences to improve 14 general accounting standards, and that's why
15 the efficiency of a transaction, and for those 15 it was so important to -- for Ms. Williams,
16 thrifts and small commercial banks to lay -- 16 from the Fannie Mae perspective, to develop
17 to be able to put those mortgages in 17 this type of coverage with -- with CAM and its
18 securities. 18 insurance contacts, to open that back up in
19 Q. And wouldn't you agree that it 19 the marketplace. There was a void of those
20 was that that was Marialice's passion for this 20 transactions for affordable housing.
21 particular issue? 21 EXAMINATION BY MR. DANIELS:
22 MR. GRIFFITH: 22 Q. Now, do you think it would be
23 I'm going to ask the court 23 fair to call all of these various products
24 reporter to read that back, because I don't 24 involving insurance and the secondary mortgage
25 think Mr. Jones heard you. 25 market, would you call them credit-enhancement
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1 products? 1 note from our videographer here. We are just
2 A. Absolutely. 2 changing the tapes.
3 Q. Would you mean some of the 3 THE VIDEOGRAPHER:
4 programs that Fannie Mae was involved in that 4 We are going off the record.
5 caused for a credit-enhancement using these 5 It's 11:33. It's the end of videotape No. 2.
6 various insurance pools? 6 (Off the record)
7 MR. GRIFFITH: 7 THE VIDEOGRAPHER:
8 Objection, vague. 8 We are back on the record. It's
9 THE WITNESS: 9 11:36. This is videotape No. 3.
10 You heard the question, but I 10 EXAMINATION BY MR. DANIELS:
11 couldn't. 11 Q. Mr. Jones, wouldn't you agree
12 MR. DANIELS: 12 that the -- that the products you developed
13 Would you ask the question to 13 for credit-enhancement were also applicable to
14 Mr. Jones, please, and let's let him determine 14 Fannie Mae's aggregation program?
15 whether it was vague or not. 15 A. Yes.
16 (Court reporter reads back previous question) 16 MR. GRIFFITH:
17 MR. GRIFFITH: 17 Objection. Objection.
18 Objection, foundation and 18 MR. DANIELS:
19 vagueness. Go ahead. 19 He answered yes?
20 EXAMINATION BY MR. DANIELS: 20 THE WITNESS:
21 Q. Can I ask the witness to answer 21 Yes.
22 the question, please? 22 EXAMINATION BY MR. DANIELS:
23 A. You are going to have to repeat 23 Q. And wouldn't you agree that they
24 it one more time. 24 would also be applicable to the negotiated
25 Q. Now, you've agreed that the 25 transactions program?
Page 71 Page 73
1 merger of insurance and the secondary mortgage 1 A. Yes, I would agree.
2 market, in general, could be categorized or 2 Q. And wouldn't you agree that they
3 called credit enhancement; is that correct? 3 would also be applicable to the captive
4 A. In the insuring of the first 4 insurance program?
5 level of risk, or even the mezzanine level of 5 MR. GRIFFITH:
6 risk, yes. And that enhancement became a 6 Objection.
7 triple-A-rated insurance policy. 7 THE WITNESS:
8 Q. And that enhancement could apply 8 Yes, I would agree.
9 to DUS programs; is that correct? 9 EXAMINATION BY MR. DANIELS:
10 MR. GRIFFITH: 10 Q. And would they also apply to the
11 Objection. 11 face amount certificate program that you and
12 THE WITNESS: 12 Marialice worked on with First Atlantic, I
13 I don't understand the question. 13 believe it was?
14 EXAMINATION BY MR. DANIELS: 14 MR. GRIFFITH:
15 Q. Would you call what you were 15 Objection.
16 proposing to Fannie Mae, in the DUS program, 16 THE WITNESS:
17 as a credit enhancement? 17 That is correct.
18 A. Yes. That is correct. That's 18 EXAMINATION BY MR. DANIELS:
19 the first proposal that was made to Fannie Mae 19 Q. Now, moving on, I have got an
20 in the presence of Marialice Williams, and 20 exhibit which I haven't marked, but it has the
21 also people from credit policy, was to -- was 21 numbers 9703 on it.
22 a credit-enhancement for the DUS lender. 22 MS. GOLDFRANK:
23 Q. Now -- was that also true -- 23 Is it something we sent down to
24 MR. GRIFFITH: 24 you?
25 Hold on one second. We've got a 25 MR. DANIELS:
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1 Yes. It's a memo -- it's an 1 did not have a non-compete clause, and that
2 e-mail from Bob Jones to probably D. Groves 2 she was free to move forward with CAM, because
3 dated September 7th, 1998 . 3 we did not have the Fannie Mae agreement that
4 MS. GOLDFRANK: 4 she had been trying -- that she thought she
5 Is it 7297? 5 was going to get from Mr. Hoyes when she left
6 MR. DANIELS: 6 Fannie Mae. Mr. Rumsey would not move forward
7 9703 is on the right on the 7 with Ms. Williams without the comfort level
8 bottom MBW 007232. I think it was sort of 8 that there was no non-compete clause, so in
9 partially referred to in one of the questions 9 trying to keep the -- our entire effort, the
10 that came earlier. 10 CAM corporate strategy to expand its business
11 MS. GOLDFRANK: 11 with Fannie Mae, I was proposing that -- and I
12 You think we used it earlier? 12 don't have what the document is here, but that
13 MR. DANIELS: 13 CAM be purchased, or we join with an equity
14 That number was referred to 14 partner to raise capital, and that suitor
15 earlier. I don't think you asked a question 15 could have been a suitor by Ms. Williams, and
16 about it. 16 there was someone from -- a group from Crump
17 MR. GRIFFITH: 17 had -- Crump, who was our wholesale broker,
18 What's the number again? 18 had indicated an interest in buying CAM, and
19 MR. DANIELS: 19 that was the purpose of this e-mail was about.
20 007232. 20 Q. And so when you are referring to
21 THE VIDEOGRAPHER: 21 the recent developments involving Marialice
22 Going off of the record. It's 22 leaving Fannie Mae, are you -- you are only
23 11:39. This is videotape No. 3. 23 referring to the fact that she didn't supply
24 (Off the record) 24 you, or Fannie wouldn't give you a non-compete
25 THE VIDEOGRAPHER: 25 assurance, or were there other elements
Page 75 Page 77
1 Going back on the record. It's 1 involved?
2 11:40. This is videotape No. 3. 2 A. The assurance -- this is from
3 EXAMINATION BY MR. DANIELS: 3 Mr. Rumsey's perspective -- that he didn't
4 Q. Mr. Jones, do you have what we've 4 want to get sued by Fannie Mae for pursuing
5 marked as Plaintiff's 1? Is that what we are 5 marketing with Marialice and Fannie Mae
6 calling it? 6 customers, and had asked that she be able to
7 A. 7232? Yes, I do. 7 get -- I guess it's a comfort letter -- that
8 Q. Now, this is -- this is an e-mail 8 there was no -- that she wouldn't be violating
9 that you wrote to Danny Groves, right? 9 any kind of non-compete clauses in her leaving
10 A. That is correct. 10 Fannie Mae.
11 Q. And in there you say, "In light 11 Q. Now, this was, in effect,
12 of all of the recent developments involving 12 devastating for CAM, obviously, because isn't
13 Marialice leaving Fannie Mae," what did you 13 it true, after you realized that Marialice was
14 mean by that? What were the recent 14 not going to be part of your package, that CAM
15 developments you were referring to? 15 was in serious trouble and needed to attract
16 A. Let me read the entire e-mail 16 additional capital to carry its program
17 first. 17 forward?
18 Q. Certainly. 18 MR. GRIFFITH:
19 A. This is where Chuck -- like me to 19 Objection.
20 answer that question? 20 THE WITNESS:
21 Q. Please, yes. 21 I think it's twofold. The Bay
22 A. Chuck here, I am referring to 22 View portfolio did not close, and it -- after
23 Chuck Rumsey, had been asking that Marialice 23 CAM had spent ten months on that and had
24 Williams furnish a -- something from Lou Hoyes 24 incurred a lot of -- a lot of costs of
25 that would just say that Marialice Williams 25 underwriting the loans out at Bay View, all of
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1 the structuring of the -- getting the approval 1 ideas with Fannie Mae.
2 of the portfolio from AIG. Richard Lawch had 2 A. She's -- Ms. Williams was, in my
3 signed the binder accepting the coverage for 3 opinion, critical to making those transactions
4 Fannie Mae, and then the -- while the 4 work, because she understood the efficiency of
5 mortgages were in the process of being 5 the execution and was the point person on the
6 delivered to Fannie Mae, there was a 6 insurance product for Fannie Mae. Nobody
7 substantial amount of what CAM had spent and 7 else -- this Green -- Alan Greenwald had no
8 didn't collect a dime on, and then Marialice, 8 clue how that transaction should work and had
9 in the same process, leaves Fannie Mae at the 9 no idea about the execution, and Richard Lawch
10 very same time during the same time period, 10 put him in charge of it.
11 because -- and like I had mentioned, Mr. Lawch 11 Q. Now, you worked with
12 refused to let Ms. Williams work on the Bay 12 Marialice from approximately 1992, '93 to 2000
13 View transaction, so CAM was in much need of 13 into the 21st century; is that correct?
14 attracting an equity partner. 14 A. 1994, early 1994 to at least
15 EXAMINATION BY MR. DANIELS: 15 2001.
16 Q. How did you find out that Richard 16 Q. Did you form any opinions as to
17 Lawch had refused to let Marialice work on the 17 the quality of the work she was doing in
18 transaction? 18 working with you on this Fannie Mae?
19 A. Can that question be repeated? 19 A. The quality of her work was very
20 (Court reporter reads back previous question) 20 good. She understood the insurance execution.
21 THE WITNESS: 21 Now, she learned a lot more about the
22 It was my personal involvement 22 insurance side. As time went on, she went
23 with Bay View Capital. They did not have an 23 through every one of those drafts of
24 investment banker, and CAM was the 24 40-some-odd insurance drafts to -- before the
25 intermediary between Bay View and Fannie Mae, 25 first transaction was closed with Metropolitan
Page 79 Page 81
1 and I specifically asked Richard for Marialice 1 Savings Bank, and her knowledge was -- there
2 to stay on that -- to stay on that 2 was no -- I don't think there was anybody else
3 transaction, and he refused, and he put two 3 that understood small loans, the small loan
4 subordinates on the transaction, and to quote 4 program for multi-family for Fannie Mae at
5 Bay View, that -- Bay View Capital, Bay View 5 Fannie Mae. Nobody had any higher level of
6 Savings Bank, they -- Lawrence Schwartz, their 6 expertise on the small loan programs that --
7 director of secondary marketing says, "Fannie 7 in my opinion anyway. Now, that's just my
8 Mae has just beat this to death. We are 8 opinion.
9 stopping the transaction," and that was in the 9 Q. Now, after she left Fannie Mae,
10 middle of mortgages being delivered to Fannie 10 you had an opportunity to observe her work
11 Mae. 11 with triple A insurance companies, didn't you?
12 EXAMINATION BY MR. DANIELS: 12 MR. GRIFFITH:
13 Q. And what -- Mr. Jones, do you 13 Objection.
14 remember exactly when that occurred, or 14 THE WITNESS:
15 essentially when that occurred? 15 With -- after she left Fannie
16 A. We started working on it in -- 16 Mae, she worked with CAM on the Zurich program
17 CAM started working on it at Richard Lawch and 17 and was -- that was for the Fannie Mae DUS,
18 Marialice's direction in the fall of '97, 18 and then she wrote her own policies, to my
19 right after the Metropolitan transaction 19 knowledge. She and probably -- she may have
20 closed, which was a milestone for Fannie Mae, 20 had some assistance from Eric and John at
21 and it went until August of 1998, July -- July 21 First Atlantic on the certificate policies,
22 of 1998, before Bay View pulled out. 22 but what I saw was good quality work.
23 Q. And please explain to -- why 23 EXAMINATION BY MR. DANIELS:
24 Marialice Williams' involvement was so 24 Q. Now, are you familiar with
25 critical to moving forward on your original 25 Mr. Craig Ott?
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1 THE WITNESS: 1 Q. And what were the fundamental
2 I can't hear the question. 2 allegations in your complaint against Fannie
3 (Court reporter reads back previous question) 3 Mae? What was the basis, in sort of laymen's
4 THE WITNESS: 4 terms --
5 Much more so than I would like to 5 A. That Fannie Mae was not honoring
6 be. 6 the terms of the exclusive that had been
7 EXAMINATION BY MR. DANIELS: 7 promised us and was taking this insurance
8 Q. Now, were you familiar with 8 company to other insurance carriers. This
9 Mr. Ott's qualifications to broker this 9 insurance coverage to other insurance
10 business with Fannie Mae? 10 carriers.
11 THE WITNESS: 11 Q. So that if Fannie Mae at some
12 I don't understand the question. 12 point said that the reason they didn't do
13 MR. GRIFFITH: 13 business with Marialice was because you had an
14 Could you read back the question? 14 exclusive on this product, you would have to
15 (Court reporter reads back prior question) 15 say that that would not be true; is that
16 THE WITNESS: 16 right?
17 "Familiar" bothers me. When 17 MR. GRIFFITH:
18 Crump first introduced CAM to Craig Ott, he 18 Objection.
19 knew nothing about this particular insurance 19 THE WITNESS:
20 product. He had no knowledge, in my opinion, 20 I'm not following that.
21 of the insurance product that we developed, 21 MR. DANIELS:
22 and in turn tried to change it on his own to 22 Read the question back. If it
23 go around CAM to -- on several transactions. 23 doesn't work, I'll ask it again.
24 EXAMINATION BY MR. DANIELS: 24 (Court reporter reads back previous question)
25 Q. Now, earlier in your testimony 25 THE WITNESS:
Page 83 Page 85
1 you stated that you believed you had an 1 I don't feel I am qualified to
2 exclusive agreement with Fannie Mae to do 2 answer your question.
3 credit enhancement using your insurance 3 EXAMINATION BY MR. DANIELS:
4 product; is that correct? 4 Q. Well, I mean, at some point, they
5 A. That is correct. 5 actually gave the business that you thought
6 Q. Now, did that belief prove to be 6 you were entitled to to others; isn't that
7 true? 7 correct?
8 A. In my opinion, we still have the 8 A. That is correct. They gave it to
9 exclusivity based on the agreements with 9 Craig Ott.
10 Richard Lawch, but the tweaking of MOUs at 10 Q. Now, can you tell us, for the
11 Fannie Mae, and then the pressure from 11 record, the amount of commission you received
12 Mr. Lawch for us to sign the MOU -- "Either, 12 from Fannie Mae pursuing the business that
13 sign it, or we are not going to do business 13 Marialice was not a part of?
14 with you." There was the exclusivity in that 14 A. I think that's probably in CAM's
15 MOU, and reduced it to the specific insurance 15 litigation and in documents that are
16 companies that were in the MOU, and then 16 disclosed, but I couldn't answer that
17 Mr. Lawch refused to do future MOUs with us. 17 question.
18 Q. In other words, in your opinion 18 Q. Would it be more or less than
19 at least, Mr. Lawch breached his commitments 19 three million dollars?
20 to CAM to do this business? 20 A. I am sure it's less than that.
21 A. In my opinion, yes. 21 It's in expert reports.
22 Q. And, in fact, you -- CAM sued 22 Q. Now --
23 Craig Ott, as a party, and sued Fannie Mae; is 23 A. Or I am reasonably sure it's less
24 that correct? 24 than that. It would be in CAM's expert
25 A. That is correct. 25 reports.
22 (Pages 82 to 85)
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1 Q. Do you think it was more than two 1 was appalled to learn that there were -- was
2 million dollars? 2 the number of aggregation transactions that
3 A. I would have to refer to the 3 had -- that had been closed. I don't think
4 reports. 4 there was anything other than maybe something
5 Q. Wouldn't you agree that Marialice 5 that was -- you-all picked up in the CAM -- in
6 was unaware of the level of commissions that 6 the CAM litigation.
7 you received from Fannie Mae? 7 Q. Perhaps you said what I suggested
8 A. Probably so, yes. 8 to Conway Downing.
9 Q. And -- 9 Is that possible?
10 MS. GOLDFRANK: 10 THE WITNESS:
11 Harley, he wasn't finished with 11 I didn't hear the question.
12 his answer. 12 MR. GRIFFITH:
13 MR. DANIELS: 13 Can you repeat the question?
14 I'm sorry. 14 MR. DANIELS:
15 THE WITNESS: 15 Yes.
16 I think I said probably so, 16 EXAMINATION BY MR. DANIELS:
17 because she was not familiar with the volume 17 Q. You recall that I was trying to
18 of business in the aggregate -- that was being 18 bring -- sort of refresh your memory on a
19 done under aggregation that Grace Huebscher 19 conversation with Marialice held in the summer
20 and Richard Lawch had strategized and insured. 20 of 2006.
21 EXAMINATION BY MR. DANIELS: 21 Do you recall a conversation with
22 Q. And isn't it true that she only 22 Conway Downing in the late summer of 2006
23 became aware of this sometime this summer, 23 where you expressed similar sentiments
24 summer of 2006? 24 about --
25 MR. GRIFFITH: 25 A. In the -- Conway Downing was in
Page 87 Page 89
1 Objection. 1 Gulfport to -- and he -- I am not -- that must
2 THE WITNESS: 2 be where the CAM litigation files came up, and
3 I don't know. 3 that's -- perhaps that's where the numbers
4 EXAMINATION BY MR. DANIELS: 4 were generated, and because he went through
5 Q. Did she call you? Did you 5 the federal courthouse documents in 2006, and
6 receive a telephone call from her after she 6 that may be where that information came from.
7 began to review the CAM litigation files 7 Q. I mean, your comment or your -- I
8 raising the issue with you? 8 am trying to get at the comment you made to
9 A. I don't recall a telephone call. 9 Conway about Marialice not being happy about
10 There -- I believe -- there was an e-mail 10 what she's going to see in the CAM litigation
11 sometime that -- something about the -- either 11 file.
12 commissions or something in the litigation 12 MR. GRIFFITH:
13 with CAM, yes. That would have been -- 13 Objection.
14 something in the CAM litigation documents that 14 THE WITNESS:
15 I am assuming that you-all had. 15 I think Conway may have already
16 Q. And during the course of one of 16 had gotten those documents, or when we spoke.
17 those conversations, didn't you say to 17 I don't recall exactly how that happened. I
18 Marialice, "Marialice, I know you are going to 18 did have breakfast with Conway one morning
19 have a problem with what you see," or, "This 19 when he was in Gulfport, but the conversation
20 is going to surprise you," or, "I know you are 20 I had with Ms. Williams was before the CAM
21 going to have feelings about it"? Something 21 lawsuit and our -- after she -- the CAM
22 to that effect? 22 lawsuit litigation was going on, but it was --
23 A. I don't think that was 2006. She 23 it was either 2001 or 2002, and she and I had
24 and I had a conversation not too long -- 24 the conversation about how much -- how many
25 probably in 2000 or 2001 when she and I -- she 25 aggregation transactions had been done, and
23 (Pages 86 to 89)
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1 she was just not -- she was not aware of 1 Mae entered into these contracts for the
2 those. She thought we had only done the MBS 2 products that you and Marialice were offering?
3 with "Met." 3 MR. GRIFFITH:
4 EXAMINATION BY MR. DANIELS: 4 Objection.
5 Q. Now, were you present at the 5 THE WITNESS:
6 fourth day of Marialice's deposition in 6 To my knowledge, Fannie Mae had
7 Washington in November of 2003? 7 never entered into a contract like the
8 A. Yes, I was. 8 CAM/Fannie Mae MOU. They never -- it had
9 Q. And do you recall Marialice's 9 never been done before. I can't specifically
10 testimony with regard to Richard Ross' 10 say how Fannie Mae otherwise entered into
11 attitude toward you? 11 those type of contracts that had never been
12 A. Yes, I do. 12 done.
13 Q. And what was that, to the extent 13 EXAMINATION BY MR. DANIELS:
14 that you remember? 14 Q. Now, it's true that Fannie Mae
15 A. Well, the attitude that -- which 15 did not issue a request for proposals for your
16 I couldn't -- had some difficulty believing, 16 product; is that right? That you were aware
17 Mr. Lawch referred to the -- to me as a 17 of.
18 "redneck" from Mississippi, and that 18 A. They did not specifically. No,
19 apparently it was common knowledge around 19 they did not.
20 Fannie Mae. 20 Q. And when was the first time you
21 Q. That that's how he regarded you? 21 approached Fannie Mae to make -- proposing
22 A. That is correct. 22 that business be done in this area of
23 MR. GRIFFITH: 23 credit-enhancement?
24 Harley, it's John Griffith here 24 A. You are going to have to repeat
25 for a second. How much longer do you have? 25 the question.
Page 91 Page 93
1 MR. DANIELS: 1 Q. When was the first time that CAM
2 If I could put you on mute so I 2 made a proposal to Fannie Mae for
3 could confer with my colleague, I may be 3 credit-enhancement products?
4 toward one, two, or three questions. 4 A. In May of -- either February or
5 MR. GRIFFITH: 5 May of 1994 when I met with Marialice
6 Can we go off for five minutes? 6 Williams, Bill Batts from credit policy, and I
7 I just have to step out for two seconds. 7 think several people from Eichler-Fein, one of
8 MR. DANIELS: 8 the DUS lenders.
9 Why don't you re-call us, and 9 Q. Did Fannie Mae, at that time,
10 we'll be ready to go. 10 accept your proposal?
11 THE VIDEOGRAPHER: 11 A. They -- the credit -- Marialice
12 Going off of the record. It's 12 Williams brought credit policy, a member of
13 12:06. This is videotape No. 3. 13 credit policy, who had been a mortgage banker,
14 (Brief Recess.) 14 or investment banker in New York, Bill
15 THE VIDEOGRAPHER: 15 Batts -- Bill Batts from Fannie Mae credit
16 We are back on the record. It's 16 policy says, "I like the proposal. Bring me a
17 12:13. This is videotape No. 3. 17 triple A -- bring Fannie Mae a triple-A-rated
18 EXAMINATION BY MR. DANIELS: 18 insurance carrier, and then -- and develop
19 Q. Mr. Jones, you've -- between, I 19 that policy with Fannie Mae and the insurance
20 would say 1993 and 2002, you sent off in an 20 companies, and I think we've got an
21 effort to secure business from Fannie Mae; is 21 execution."
22 that not correct? 22 Q. When?
23 A. That is correct. 23 A. Three years later.
24 Q. Now, would you describe for us 24 Q. So they didn't -- the process was
25 the process that you observed for how Fannie 25 different from you making a proposal and their
24 (Pages 90 to 93)
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1 accepting your proposal? 1 the -- in fact, there are some e-mails. I
2 A. That is correct. That was all 2 don't know where they are. They were in
3 product development. 3 disclosed documents, that discloses either a
4 Q. And during that process, in fact, 4 joint venture or an MWOB-owned business for
5 you made many, many proposals to Fannie Mae on 5 Marialice Williams.
6 this product; is that correct? 6 EXAMINATION BY MR. DANIELS:
7 A. There were many drafts of the 7 Q. Did you understand that that
8 policy. If each one of those is a proposal, 8 would enhance your ability to do business with
9 it was -- it was all part of product 9 Fannie Mae?
10 development with AIG, Fannie Mae, and CAM. 10 A. I believe that was an important
11 Q. But you would agree it's not a 11 part of it, yes.
12 simple -- you know, a simple contract proposal 12 Q. And do you know whether Marialice
13 where there is an offer and an acceptance, and 13 was ever designated an MWOB?
14 then you have a contract? 14 A. I do not know. I do not know.
15 A. That's correct. CAM was working 15 Q. After Marialice left Fannie Mae,
16 with Fannie Mae as a partner, and that's the 16 did you, after that, hear any discussion of
17 jargon, or how Richard Lawch identified CAM 17 the MWOB process in connection with what you
18 as -- that it was a partner. It was a 18 were trying to accomplish with Marialice?
19 partnership. 19 A. I can't answer that, because I
20 Q. And Marialice was not part of 20 don't recall, but I am sure that, in general
21 your partnership between Fannie Mae and CAM on 21 terms, that we all were thinking that this
22 the MCRI business; is that correct? 22 would enhance her business, and I don't think
23 A. No, Marialice Williams was an 23 she had any stockholders initially, so she
24 integral part of the development. 24 would have been a solely-owned MWOB business.
25 Q. After she left Fannie Mae? 25 MR. DANIELS:
Page 95 Page 97
1 A. Oh, not after she left Fannie 1 Mr. Jones, I want to thank you
2 Mae, no. 2 for your transparent and truthful testimony
3 Q. Now, you used the term "MWOB" 3 today, and no further questions.
4 earlier in your testimony. 4 MR. HUNTER:
5 Do you know what those initials 5 I've got a couple of questions,
6 stand for? 6 if that's all right, or if you-all would
7 A. A woman -- 7 rather me wait till you-all get finished.
8 Q. Let me give it a try, and you 8 MR. GRIFFITH:
9 tell me whether -- 9 No, I think we're done.
10 A. No. MWOB is a minority 10 MR. HUNTER:
11 woman-owned business. 11 I have two questions to ask
12 Q. Minority business program? 12 Mr. Jones.
13 A. Well, in this, MWOB would have a 13 MR. DANIELS:
14 woman. 14 Who is speaking now? I am sorry.
15 Q. Owned business? 15 MR. HUNTER:
16 A. Yes. 16 This is Seth Hunter, counsel for
17 Q. And was it your understanding 17 Mr. Jones.
18 that part of the reason that Fannie Mae -- 18 MR. DANIELS:
19 that Lou Hoyes was proposing that Marialice be 19 Thank you, Mr. Hunter.
20 set up as an MWOB? 20 EXAMINATION BY MR. HUNTER:
21 MR. GRIFFITH: 21 Q. I just want to clarify a couple
22 Objection. 22 of things.
23 THE WITNESS: 23 Mr. Jones, when you left CAM
24 I was aware of conversations that 24 Financial Services as president and CEO, was
25 Marialice had with Lou Hoyes, and that was 25 that voluntary?
25 (Pages 94 to 97)
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Page 98
1 A. No.
2 Q. And when you were speaking
3 earlier of product development, and you were
4 working with Marialice Williams, was that
5 product development as a -- were you working
6 for CAM Financial Services, Incorporated
7 developing the product?
8 A. Was I working for CAM Financial
9 Services?
10 Q. Yes.
11 A. Absolutely.
12 MR. HUNTER:
13 That's all I have.
14
15 * * *
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Page 99
1 REPORTER'S CERTIFICATE
2
3
4 I, NANCY LAPORTE, Certified Court
5 Reporter, State of Louisiana, do hereby
6 certify that the above-mentioned witness,
7 after having been first duly sworn by me to
8 testify to the truth, did testify as
9 hereinabove set forth;
10 That the testimony was reported by me in
11 shorthand transcribed under my personal
12 direction and supervision, and is a true and
13 correct transcript, to the best of my ability
14 and understanding;
15 That I am not of counsel, not related to
16 counsel or the parties hereto, and not in any
17 way interested in the outcome of this matter.
18
19
20
21
22
NANCY LAPORTE
23 Certified Court Reporter
State of Louisiana
24
25
26 (Pages 98 to 99)
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A agree 66:16 67:19 85:16 86:12 96:19 24:18 91:16
ability 68:11 96:8 72:11,23 73:1,2,8 answered 46:13 ASSOCIATION background 9:16
99:13 86:5 94:11 72:19 1:6 10:22 67:1
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30:21 67:17 77:6 58:4 70:25 81:2 assuming 25:8,9 42:13,14 46:9
above-mentioned agreement 18:4 anymore 35:14 47:21 87:15 Bank 15:25 32:25
99:6 23:6 24:5,7,17,20 anyway 81:7 assurance 76:25 79:6 81:1
absolute 20:3 25:3,8 26:4,12,19 appalled 88:1 77:2 banker 78:24 93:13
Absolutely 70:2 26:21 27:5,9 28:1 apparently 39:11 Atlantic 33:11 93:14
98:11 28:15,16 29:3,6,6 90:19 36:18 37:19 73:12 bankers 40:22
accept 93:10 29:12,14 30:9,14 appear 32:17 81:21 banking 67:1,1
acceptance 94:13 30:16 31:6,8,19 APPEARANCES attached 23:24 banks 67:10,16
accepting 78:3 94:1 35:3,7,11 55:9 1:13 2:1 61:25 69:1,9
accomplish 67:5 76:3 83:2 appears 38:24 attachment 23:17 based 83:9
96:18 agreements 25:21 39:10,13 attitude 90:11,15 basically 66:23
accounting 68:24 25:25 26:11 28:4 applicable 72:13 attorney 2:3,4 13:7 basis 84:3
69:14 28:23 29:21 31:11 72:24 73:3 13:12 20:14 Bates 1:5 2:17,19
accurate 12:9,14 35:21 58:2 83:9 application 36:17 attorneys 1:17,21 2:24 3:2,4,6 16:22
26:3 27:3,17,22 agrees 24:9 apply 71:8 73:10 1:24 13:10 17:11 23:21 38:23
31:13 ahead 7:13 70:19 appointed 12:16 attract 77:15 48:19 49:19 61:24
accurately 50:1 AIG 12:5,9 14:1,11 appointment 30:5 attracting 78:14 62:1
acronym 18:18 14:12,21,22 15:20 30:19 August 33:25 34:1 Bates-stamped
ACTION 1:3 28:10 52:5 54:11 appreciate 66:6 37:14,14 54:15 6:22
active 10:11 56:17 78:2 94:10 approached 92:21 55:5,6 79:21 Bathrus 1:3,18
actual 34:22,25 AIG's 14:19 appropriate 14:18 author 14:16 Batts 93:6,15,15
acumen 44:9 al 1:6 approval 78:1 automobile 27:1,14 Bay 15:24,24 16:3
addition 56:17 Alan 80:7 approved 38:15 available 69:13 16:7 77:21,25
additional 77:16 Alexander 1:23 approximately Avenue 1:20 78:12,23,25 79:5
address 6:8 allegations 19:25 65:2 80:12 aware 9:1 12:21 79:5,5,22
administering 4:23 20:7,21,21 84:2 April 1:11 5:5 20:25 25:1 30:4 beat 79:8
affordable 69:20 alleged 19:16 area 45:25 65:19 35:9 55:20 59:2 began 9:11 64:25
aforementioned alleges 11:22 66:12,23 92:22 61:7 86:23 90:1 87:7
4:5 allow 18:5 19:17 areas 68:12 92:16 95:24 Beginning 36:10
afterward 42:16 amended 2:18 arena 10:10 a.m 1:11 belief 83:6
Agencies 10:4 16:18,22 asked 22:7 26:17 believe 6:17 10:19
America 67:10 30:20 32:9 34:3 B 16:16 17:5,9
agency 10:25 11:12
agent 17:25 18:5,12 American 40:4 36:14 41:23 54:22 B 5:23 21:22 22:24 24:22
19:18 55:13 52:4 74:15 77:6 79:1 back 9:9 10:5 22:10 30:17 34:16 36:18
aggregate 86:18 amount 33:4 73:11 asking 25:12 32:5 22:12 31:2 33:4 37:6 39:8 40:6
aggregation 19:3,6 78:7 85:11 63:13 75:23 36:9 40:13 42:16 43:5 50:4,4 64:20
38:8,10,11 39:23 annual 41:7 ASLICK 14:20 45:17 58:19 61:19 73:13 87:10 96:10
72:14 86:19 88:2 answer 4:16 7:13 asset 40:6,11 66:7 67:24 68:1 believed 57:1 83:1
89:25 20:4 29:8 31:4 assistance 81:20 69:18 70:16 72:8 believing 90:16
ago 20:2 60:22 35:19 63:8 68:21 associated 49:8 75:1 78:20 82:3 best 31:9 37:14
70:21 75:20 85:2 Associates 23:10 82:14,15 84:22,24 99:13
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Betty 47:5,13 47:19 57:7,9,15 78:24 79:17 81:16 81:21 99:1 comments 61:3
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Bill 93:6,14,15 65:5,11 76:10 87:7,13,14 88:5,6 32:24 32:24 33:5 37:11
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