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
5 page(s), 3,793 characters, read from page images by OCR, so expect some character errors · plain text.
Full text
Case 1:05-cv-01483-JDB Document 33-18 Filed 06/21/2007 Page1of5 EXHIBIT P Case 1:05-cv-01483-JOB Document 33-16 Filed 06/21/2007 Page 2of5 00001 ] IN THE UNITED STATES DISTRICT COURT 2 SOUTHERN DISTRICT OF MISSISSIPPI 3 SOUTHERN DIVISION 5 CAM FINANCIAL SERVICES, INC., : 6 Plaintiff, : Case No.1:01cv314BrR 7 Vv. 8 GENERAL STAR NATIONAL INSURANCE : 9 COMPANY; GENERAL STAR INDEMNITY : 10 COMPANY; GENERAL STAR MANAGEMENT: 11 COMPANY, GENERAL RE CORPORATION:;: 12 GENERAL REINSURANCE CORPORATION:;: 13 CRUMP INSURANCE SERVICES OF 14 MEMPHIS, INC.; CRAIG OTT, 15 INDIVIDUALLY AND IN HIS 16 REPRESENTATIVE CAPACITY AS VICE : 17 PRESIDENT OF GENERAL STAR 18 MANAGEMENT COMPANY 19 FEDERAL NATIONAL MORTGAGE 20 ASSOCIATION 21 (FANNIE MAB), 22 Defendants. > VOL.IV 23 ------ ee ee eee ee X CONFIDENTIAL 24 Washington, D.C. 25 Tuesday, May 6, 2003 May 6, 2003 FM of MAW Page I CONFIDENTIAL FNMA.MBW.003184 Case 1:05-cv-01463-JD8 Document33-16 Filed 06/21/2007 Page ofS 00002 1 Videotaped Deposition of MARIALICE 2 WILLIAMS, a witness herein, called for examination by 3 counsel for Defendant, Fannie Mae, in the 4 above-entitled matter, the witness being previously 3 duly sworn, taken at the offices of Steptoe & 6 Johnson, 1330 Connecticut Avenue, N.W., Washington, 7 D.C., at 9:37 a.m., Tuesday, May 6, 2003, and the 8 proceedings being taken down by Stenotype by PENNY M. 9 DEAN, RPR, and transcribed under her direction. 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 May 6, 2003 FM of MAW Page 2 CONFIDENTIAL FNMA.MBW.003185 Case 1:05-cv-01483-JDB Document 33-18 Filed 06/21/2007 Page 4o0f5 00128 1 A. Yes, it does. 2 Q. Was this E-mail send on or about August 3 6th, 20017 | 4 <A. It appears that way. 5 Q. Would you read the first paragraph, 6 please? 7 <A. “We are looking forward to meeting with 8 you on the 21st of August. However, we want to make 9 certain that Kate is on target with her presentation. 10 Could you please let us know if you are looking at 11 the captive as a potential credit enhancement tool 12 for Fannie Mae or as a tool that the DUS lenders 13 could use.” 14 QQ. And then the third paragraph beginning 15 finally, there is just one sentence, can you read 16 that for the record? 17 A. "Finally, could we spend a little time 18 discussing the other two questions from the insurance 19 companies that we posed to you at the end of May." 20 Q. And then lastly, just read the next 21 sentence, please? 22. A. "My partner, Harvey Hartsfield, will be 23 working with Kate on her presentation, so please cc 24 him on your response." 25 Q. Did you in fact have that meeting on the May 6, 2003 FM of MAW Page 128 CONFIDENTIAL FNMA.MBW.003311 Case 1:05-cv-01483-JOB Document33-16 Filed 06/21/2007 Page Sots 00129 1 21st of August? 2 A. Yes, we did. 3 Q. And who was there? 4 A. Kate Westover. 3 Q. And what was her position? 6 A. Kate Westover is an international 7 authority on captive insurance. 8 Q. Where did the meeting occur? 9 A. At Fannie Mae. 10 QQ. Who was there for Fannie Mae? 11. A. Grace Huebscher, an attorney whom | did 12 not know and I believe Rhoda Newman, but I'm not 13 certain, and Harvey Hartsfield. 14 (Williams Exhibit No. 42 was 15 marked for identification.) 16 BY MR. WIMBERLY: 17 Q. I'm going to hand your counsel a document 18 marked Exhibit 42. And when youre satisfied it is 19 not objectionable, Ms. Williams, if you would hand it 20 to your client, I would appreciate it. 21 MS. WILLIAMS: It starts -- the document 22 starts with page 2, 3, 4. 23 MR. WIMBERLY: The document bears Bates 24 numbers 10524, 525, 526, 527, and it's from CAM's 25 business records. And this is the way it was May 6, 2003 FM of MAW Page 129 CONFIDENTIAL FNMA.MBW.003312