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.
Document text
4 page(s), 3,977 characters, read from page images by OCR, so expect some character errors · plain text.
Full text
Case 1:05-cv-01483-JDB Document 33-22 Filed 06/21/2007 Page 1of4
EXHIBIT T
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. a . Subject: Re: Fannie Mae Draft letéer .
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Case 1:05-cv-01483-JDB Document ds-22 Filed 06/21/2007 Page 2 al 4
_ Date: Wed, 02 May 2001 15:55:54 -0s00-
From: Bob Jories <bobjones@cam-fnancial. com>
' *., To: Marialice Williams <marialice@worldnet.att.net>
os Bob Jones wrote:
_ - Marialice, although this is- somewhat sensitive, I don't have a. problem with the |
‘letter and I believe you should send it to ‘Grace.’ I believe RMS and.CAM will oe
- "protect each ‘other. in our prior agreed to Brokers Agreement on this coverage for
. Fannie Mae., 7. coat ° TS oo, . Coe! . "
_. Marialice Willians wrote: §,
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| CONFIDENTIAL
Case 1:05-cv-01483-JDB Document 33-22
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1, Dear, Grace:
no ° First, | want to thank you
" "the best and lowest cost insurance available
vs Before | left Fannie Mae, | assisted in ne
ried 06/21/2007 Page 3 al 4
DE RO ALF TOS ee
for the delighifUl iunch last week with Rhoda’ ttwas <--
“2, good catching up with you two. Second, 't want to-thank you for the opportunity - ©.
’” to pursue a Solution for our Clients to obtain relief from their mezzanine loss.
_’ - average obligation under the DUS program. Therefore, | welcome the.
'... . Opportunity to clearly define the relationship batween my comipariy, Risk a
_: Mitigation Strategists, LLC ("RMS") and CAM Financial Services, inc. ("GAM"). "_-- oe
La . Vwas in Atlanta yesterday and had lunch with Bob Jones, President of CAM...
ob indicated that he had transmitted an e-mail to you and Rhoda indicating that .- ~
',_ ’ AIG may have an interest in providing insurance coverage for mezzanine levels
*. Of risk. ESE vers
- My ‘company, RMS, is licensed to do business in Washington, D.C. CAM and |<" .
RMS do not have any connection with respect to ownership and no one from : |
CAM or RMS has an interest in the other’s business ventures. ‘However, CAM
"and RMS have a broker agreement that is common in the insurance business. °_
The agreement indicates that when CAM locates an insurance company for a
_ Project that RMS is working on, RMS agrees to compensate CAM through some. re
form of split commission, However, it does not mean that CAM plays any role in.
the development of the program or project that RMS is working on nor does CAM a
interface with the customers,
_ My company has relationships with numerous insurance brokers and carers’.
with whom we have signed confidentiality agreements. Due to the innovative’
__ and unique ways that our customers utilize insurance to solve their problems of. -
- . Covering different types of risk, we plan to continue to use our network of
resources to assist our customers, many of whom are DUS lenders, in obtaining
to meet their needs.
gotiating an agreement between CAMs 0
and Fannie Mae that provided CAM with the opportunity to seek insurance-based .-...
solutions for risk coverage in the securitization program of the Negotiated ~~...
Transaction'’s department. } do nol believe that the agreement between Fannie
Mae and CAM contemplated extending CAM'’s authority to work on any aspect of
_‘Visk coverage for Fannie Mae’s DUS program. | CC
Therefore, unless otherwise instructed by you,-RMS will continue to work on<-
_ behalf of its clients to obtain insurance that will cover the 5-20% risk coverage
obligation or mezzanine level or risk Coverage as required by Fannie Mae under -
its DUS pregram.
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_ _ a 97
; | * ENMA.MBW.0079
| | CONFIDENTIAL
+s, Sincerely,
Case 1:05-cv-01483-JDB Document 33-22
Ce
Marialice Wiliams _
ried 06/21/2007
Page 4 af 4
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ENMA.MBW.007998
CONFIDENTIAL