Case 1:05-cv-01483-JOB Document 3a-23 Filed 06/21/2007 Page Tots

IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF COLUMBIA

MARIALICE BATHRUS WILLIAMS,

Plaintiff,

Civil Action No. 1:05CV01483
Vs. .
Judge John D. Bates
FEDERAL NATIONAL MORTGAGE

ASSOCIATION, et al.
: DECLARATION OF KYRA
Defendants. GRUNDEMAN
I, Kyra A. Grundeman, hereby declare as follows:
1. Tam counsel for defendant Federal National Mortgage Association (“Fannie

Mae”), Richard Lawch, and Grace Huebscher (collectively, “defendants”’) in the above-captioned
action. I am over eighteen years of age, and the statements made herein are based on my
personal knowledge, unless otherwise indicated.

2. Attached to defendants’ Memorandum in Support of Motion for Summary
Judgment are true and correct copies of the following documents:

Exh. A Declaration of Grace Huebscher, with true and correct copies of excerpts
of depositions taken in the lawsuit entitled CAM Financial Services, Inc. v.
General Star Nat’l Insurance Co., et al., Civil Action No. 01-314 (S8.D.
Miss.) (“CAM Financial lawsuit”) attached at Tab 1 of Exhibit A.

Exh.B ~~ March 28, 2007 Deposition of Marialice Williams, with a true and correct
copy of Exhibit 1 of this deposition, Bates-labeled FNMA.MBW.008015-
8018, attached at Tab 1 of Exhibit B.

Exh.C Defendant Fannie Mae’s Response to Plaintiffs First Set of
Interrogatories.

Exh. D Declaration of Richard Lawch.

Exh. E Excerpts from the March 21, 2003 Deposition of Marialice Williams,


Case 1:05-cv-01483-JOB Document3a-23 Filed 06/21/2007 Page Zot

Exh. F

Exh. G

Exh. H

Exh. I
Exh. J
Exh. K

Exh. L

Exh. M

Exh. N

Exh. O

Exh. P

Exh. Q

Exh. R

Exh. §

Exh. T

taken in the CAM Financial lawsuit.

May 7, 2007 Deposition of Marialice Williams, with a true and correct
copy of Exhibit 10 of this deposition, attached at Tab 1 of Exhibit F.

District of Columbia Certificate of Revocation.

April 11, 2007 Deposition of Robert Jones, with a true and correct copy of
Exhibit 2 of this deposition, Bates-labeled FNMA.MBW.008002-8004,
attached at Tab 1 of Exhibit H; a true and correct copy of Exhibit 4 of this
deposition, Bates-labeled FNMA.MBW.007369-7370, attached at Tab 2
of Exhibit H; and a true and correct copy of Exhibit 7 of this deposition,
Bates-labeled FNMA.MBW.006230-6232, FNMA.MBW.008031,
attached at Tab 3 of Exhibit H.

CAM Financial Litigation Amended Complaint.
CAM Financial Litigation Dismissal Order.
Plaintiff's Answer to Defendants’ Interrogatory Requests.

Excerpts from the March 17, 2003 Deposition of Marialice Williams,
taken in the CAM Financial lawsuit.

_ District of Columbia Department of Insurance, Securities & Banking

Licensee Look-Up.
Marialice Williams’ Draft Complaint.

Excerpts from the May 5, 2003 Deposition of Marialice Williams, taken in
the CAM Financial lawsuit.

Excerpts from the May 6, 2003 Deposition of Marialice Williams, taken in
the CAM Financial lawsuit.

Declaration of Kathryn Westover.

Document Bates-labeled FNMA.MBW.008057, produced by defendants
in this litigation.

Excerpts from the Jan. 19, 2004 Deposition of Craig Ott, taken in the
CAM Financial lawsuit.

Document Bates-labeled FNMA.MBW.007996-7998, produced by
defendants in this litigation.


Case 1:05-cv-01483-JOB Document3a-23 Filed 06/21/2007 Page Sots

I declare under penalty of perjury that the foregoing is true and correct. Executed on

June 21, 2007 at Washington, D.C.

YRA A. GRUNDEMAN