Case 1:05-cv-01483-JDB Document 33-8 Filed 06/21/2007 Page 1 of 74 EXHIBIT F Case 1:05-cv-01483-JDB Document 33-8 Filed 06/21/2007 Page 2 of 74 Marialice Williams Page 132 UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA -------------------------x MARIALICE BATHRUS : WILLIAMS, : Plaintiff : Civil Action No. : 1:05CV01483 v. : Judge John Bates : PAGES 132 through 312 FEDERAL NATIONAL : MORTGAGE ASSOCIATION, et : al., : Defendants : -------------------------x VOLUME II Continued Videotaped Deposition of Marialice Bathrus Williams Washington, DC Monday, May 7, 2007 Reported by: Joanne Liverani, RMR JOB NO. 180771 Esquire Deposition Services MD - 1-800-539-6398 D.C. - 1-800-441-3376 VA - 1-800-752-8979 a77cbcf5-7ff0-478d-a5f4-3a9a93751c41 Case 1:05-cv-01483-JDB Document 33-8 Filed 06/21/2007 Page 3 of 74 Marialice Williams Page 133 Page 135 1 1 -and- 2 2 Fannie Mae 3 3 3900 Wisconsin Avenue, Northwest 4 May 7, 2007 4 Washington, DC 20016 5 10:29 A.m. 5 (202)752-6167 6 6 BY: Jonathan Griffith, Esq. 7 Continued Videotaped Deposition of Marialice Bathrus 7 8 Williams, held at the offices of: 8 Also Present: 9 9 Edward Diggs, Videographer 10 O'Melveny & Myers LLP 10 11 1625 Eye Street 11 12 Washington, DC 20006 12 13 13 14 Pursuant to notice, before Joanne Liverani, RMR, a 14 15 Notary Public of the District of Columbia. 15 16 16 17 17 18 18 19 19 20 20 21 21 22 22 Page 134 Page 136 1 APPEARANCES: 1 CONTENTS 2 EXAMINATION OF THE WITNESS: PAGE 2 For the Plaintiff, MARIALICE BATHRUS WILLIAMS 3 Examination By Ms. Becker 138 3 Law Offices of Harley Jay Daniels 4 MARIALICE BATHRUS WILLIAMS 5 Deposition Exhibits PAGE 4 303 Van Ness Street, Northwest 6 9 Bates stamp FNMA.MBW.008129 through 139 5 Suite W228 8133 7 6 Washington, DC 20008 10 one-page e-mail, Subject: Your 147 7 (202)468-7737 8 January 25, 2007 correspondence 9 11 Bates stamp FNMA.MBW.008139 through 150 8 BY: Harley Jay Daniels, Esq. 8144 9 -and- 10 12 Amended Complaint 185 10 Brian Lederer, Esq. 11 11 3003 Van Ness Street, Northwest 13 Plaintiff's Answers to Defendants' 198 12 Interrogatories 12 Washington, DC 20008 13 14 Statement of Financial Affairs from 248 13 (202)244-1715 the United States Bankruptcy Court, 14 District of Columbia 14 15 15 Notice of Chapter 7 Bankruptcy Case, 254 15 For the Defendants, FEDERAL NATIONAL MORTGAGE Meeting of Creditors & Deadlines, 16 United States Bankruptcy Court, 16 ASSOCIATION, ET AL. District of Columbia (DC) 17 O'Melveny & Myers, LLP 17 16 2001 Form 1040, U.S.Individual Income 262 18 1625 Eye Street, Northwest 18 Tax Return for the witness 19 Washington, DC 20006-4001 19 17 2002 Form 1040, U.S.Individual Income 281 Tax Return for the witness 20 (202)383-5300 20 21 BY: Evelyn L. Becker, Esq. 18 2003 Form 1040, U.S. Individual 298 21 Income Tax Return for the witness 22 Kyra A. Grundeman, Esq. 22 2 (Pages 133 to 136) Esquire Deposition Services MD - 1-800-539-6398 D.C. - 1-800-441-3376 VA - 1-800-752-8979 a77cbcf5-7ff0-478d-a5f4-3a9a93751c41 Case 1:05-cv-01483-JDB Document 33-8 Filed 06/21/2007 Page 4 of 74 Marialice Williams Page 137 Page 139 1 VIDEOGRAPHER: Good morning. 1 here today? 2 Here begins videotape number one, Volume II of the 2 A Yes. 3 deposition of Marialice Bathrus Williams in the 3 Q If at any time during the day you feel 4 matter of Marialice Bathrus Williams versus Federal 4 that you're no longer able to give full and 5 National Mortgage Association, et al., in the 5 truthful testimony, will you please let me know 6 United States District Court for the District of 6 that? 7 Columbia. Case No. 1:05CV01483. 7 A Yes. 8 Today's date is May 7th, 2007. The 8 MS. BECKER: 'd like to hand you 9 time is 10:29:14 a.m. This deposition is being 9 what will be marked by the court reporter as 10 taken at the law firm O'Melveny & Myers at 1625 I 10 Exhibit 9. 11 Street, Northwest, Washington, DC and is made at 11 Thank you. 12 the request of Evelyn Becker of the law offices of 12 (Deposition Exhibit No. 9 - Bates stamp 13 O'Melveny & Myers. 13 FNMA.MBW.008129 through 8133 - was marked for 14 The videographer is Edward Diggs. The 14 identification.) 15 court reporter is Joanne Liverani, here on behalf 15 BY MS. BECKER: 16 of Esquire Deposition Services located at 1020 19th 16 Q Can you identify Exhibit 9? 17 Street, Northwest, Washington, DC. 17 A Exhibit 9 is a subpoena issued by the 18 Would counsel and all present please 18 United States District Court in the matter of Cam 19 identify yourselves and state whom you represent. 19 Financial Services, Incorporated versus General 20 MR. DANIELS: My name is Harley 20 Star National Insurance Company. 21 Daniels. I represent the plaintiff. 21 Q Who's the subpoena directed to? 22 MR. LEDERER: My name is Brian 22 A It is to me. Page 138 Page 140 1 Lederer. I represent the plaintiff. 1 Q What is the date of the subpoena? 2 MS. BECKER: Evelyn Becker, on 2 A The date is April 24th, 2002. 3 behalf of Fannie Mae, Richard Lawch, and Grace 3 Q Do you recall receiving this subpoena? 4 Huebscher. 4 A Yes. 5 MS. GRUNDEMAN: Kyra Grundeman, 5 Q Did you search for documents in response 6 on behalf of Fannie Mae, Richard Lawch, and Grace 6 to this subpoena? 7 Huebscher. 7 A Yes. 8 MR. GRIFFITH: Jonathan 8 Q Did you produce documents in response to 9 Griffith, on behalf of Fannie Mae. 9 this subpoena? 10 Thereupon, 10 A Yes. 11 MARIALICE BATHRUS WILLIAMS, 11 Q I'd like to turn your attention to 12 the Witness, called for examination by counsel for the 12 Page 8131 of this exhibit, which is the third page 13 Defendants, and, after having been sworn by the notary, 13 in the exhibit. 14 was examined and testified as follows: 14 Under where it says "documents 15 EXAMINATION BY COUNSEL FOR THE DEFENDANTS, FEDERAL 15 requested," can you tell me what the third category 16 NATIONAL MORTGAGE ASSOCIATION, ET AL. 16 of documents requested is? 17 BY MS. BECKER: 17 A All documents that refer to or relate to 18 Q Good morning, Ms. Williams. 18 Fannie Mae. 19 A Good morning. 19 Q Did you search for documents in response 20 Q This is a continuation of your 20 to document request number three? 21 deposition from March 28, 2007. Do you feel that 21 A Yes, I did. 22 you are able to give full and truthful testimony 22 Q Did you produce any documents that you 3 (Pages 137 to 140) Esquire Deposition Services MD - 1-800-539-6398 D.C. - 1-800-441-3376 VA - 1-800-752-8979 a77cbcf5-7ff0-478d-a5f4-3a9a93751c41 Case 1:05-cv-01483-JDB Document 33-8 Filed 06/21/2007 Page 5 of 74 Marialice Williams Page 141 Page 143 1 had in your possession relating to document request 1 Q Are you saying that you did less than an 2 number three? 2 exhaustive search in response to a subpoena issued 3 A I believe I did. 3 in the Cam litigation on April 24, 2002? 4 Q What is document request number six? 4 A If you notice -- if you notice the -- it 5 A All documents that constitute, 5 says "April 24, 2002." And it asks that this 6 represent, refer to, or relate to communications 6 information be retrieved by Friday, May 10th, 7 between you and anyone else regarding Fannie Mae. 7 2002. And I am certain that I searched very hard 8 Q Did you search for documents responsive 8 at that time, but I had documents in a -- in a 9 to document request number six? 9 storage area. I had them in boxes in a garage. I 10 A Yes, I did. 10 had them in my office. I'd had a computer crash 11 Q Did you produce any documents that you 11 earlier. 12 had in your possession in response to document 12 So I -- I -- I can tell you that I 13 request number six? 13 searched through what I thought I had, and I 14 A I believe I did. 14 thought I'd given -- I gave whatever I could find 15 Q What is document request number seven? 15 in that time frame. 16 A All documents that constitute, 16 Q What did you search for -- let me 17 represent, refer to, or relate to communications 17 rephrase the question. 18 between you and anyone employed or retained by 18 Where did you search for documents in 19 Fannie Mae following the termination of your 19 response to the subpoena issued to you on -- on 20 employment with Fannie Mae. 20 April 24th, 2002? 21 Q Did you search for documents in response 21 A Oh, I don't -- I -- I can't -- I can't 22 to document request number seven? 22 recall precisely. Page 142 Page 144 1 A Yes, I did. 1 Q Did you search in all the places that 2 Q Did you produce any documents that you 2 you just identified, including your -- 3 had in your possession responsive to document 3 A I believe I did. 4 request number seven? 4 Q I'm sorry, if I could just finish my 5 A I -- I believe I did. I know that I 5 question. It'll make the record a little bit 6 delivered a doc -- a box of documents to Fannie Mae 6 easier. 7 which were never returned to me so I really can't 7 Did you search for documents that you 8 say what was in it and which of these it was 8 had on your computer? 9 specifically related to. So you're asking me about 9 A Yes, I did. 10 these specifics, but I can't tell you whether or 10 Q Did you search for any documents you had 11 not they were marked for these or whatever. 11 in storage? 12 Q Would it be fair to say, though, that to 12 A Yes, I did. 13 the extent you had documents in your possession 13 Q Did you search for any documents you had 14 responsive to any of the documents requested in the 14 in your office? 15 subpoena, dated April 24, 2002, that you produced 15 A Yes. 16 those documents in the Cam litigation? 16 Q And did you produce any responsive 17 A In April of 2002, I had a great deal of 17 documents that you found? 18 mat -- things, boxes and materials in storage. And 18 A I produced a box of documents that I 19 it was a very -- it was a transitional time in my 19 took to 3900 Wisconsin Avenue, Northwest, by the 20 life, and I probably gave whatever I had at the 20 time it was requested. I cannot tell you precisely 21 time that I could put my hands on. I can't tell 21 what was in that box, and those materials were 22 you if it was exhaustive of what I possessed. 22 never returned to me. 4 (Pages 141 to 144) Esquire Deposition Services MD - 1-800-539-6398 D.C. - 1-800-441-3376 VA - 1-800-752-8979 a77cbcf5-7ff0-478d-a5f4-3a9a93751c41 Case 1:05-cv-01483-JDB Document 33-8 Filed 06/21/2007 Page 6 of 74 Marialice Williams Page 145 Page 147 1 Q Can you tell me whether you produced any 1 I only now understand how to back up 2 documents that you found that were responsive to 2 that information so you don't lose it. 3 the documents requested in the April 24, 2002 3 Q You testified that you had three 4 subpoena? 4 computer crashes. Can you tell me what the dates 5 A I believe they were all responsive to 5 of those three crashes were? 6 whatever the request was, but I cannot tell you 6 A One was approximately two years ago. 7 specifically what they were. I cannot tell you. I 7 One was approximately nin -- 2000, I believe, and 8 don't have them. 8 then I think one was in 2002 or '3. But I -- I 9 Q Do you have any reason to believe that 9 cannot say that for absolute certainty but those -- 10 there were documents in your possession as of April 10 that's what I'm remembering. 11 or May of 2002 responsive to the documents 11 MS. BECKER: I'm handing you 12 requested in the subpoena issued April 24, 2002 12 what I'll ask the court reporter to mark as 13 that you did not produce in the Cam litigation? 13 Exhibit 10. 14 A I think there may have been some records 14 (Deposition Exhibit No. 10 - one-page e-mail, 15 that I may have found later. 15 Subject: Your January 25, 2007 16 Q Do you remember what those records were? 16 correspondence - was marked for 17 A Whatever the balance of materials that I 17 identification.) 18 produced in response to the defendants' request for 18 MS. BECKER: Exhibit 10 is an 19 documents in this particular matter. 19 e-mail sent to me, Kyra Grundeman, and Sarah 20 Q So at some point in time you found 20 Goldfrank. 21 additional documents beyond the documents that you 21 THE WITNESS: Mm-hmm. 22 found when you searched in the April 2002 time 22 BY MS. BECKER: Page 146 Page 148 1 frame; is that correct? 1 Q Do you recognize this e-mail? 2 A I believe that is correct. 2 A Yes, it says what I just said except it 3 Q And did you produce those documents? 3 says two crashes instead of three. 4 A I produced those documents in response 4 Q Does this e-mail refresh your 5 to defendants' request for documents in this 5 recollection as to the date of the -- of two of the 6 matter. 6 crashes? 7 Q Between the two productions that you 7 A Yes, 2004 and 2001, I think I said that 8 made to Fannie Mae, did you produce all documents 8 pretty much. Close to that. 9 in your possession responsive to the April 24, 2002 9 Q So 2004 and 2001 are -- are two of the 10 subpoena that you had in your possession as of 10 accurate dates; is that correct? 11 April or May of 2002? 11 A I believe they are. 12 A No. Well, yes and no. 12 Q What was the third crash? 13 Yes, I produced what I had. But there 13 A There may only have been two. I 14 were many other e-mails, telephone records or 14 think -- I think there were two. 2001 and 2004. I 15 whatever that I was not able to retrieve at two 15 think that's correct. I did have a laptop that 16 different points in which -- actually, I've had 16 crashed but that was not as serious. 17 three computer crashes in the last ten years, but 17 Q Did you keep documents on your laptop 18 two of them during the time that I was working on 18 relating to Fannie Mae? 19 this Fannie Mae product. So there would be e-mails 19 A Yes. 20 I would not be able to retrieve, as well as 20 Q When did your laptop crash? 21 documents that I would not be able to retrieve 21 A Let's see. Oh, gosh, actually there 22 because they were only on that particular computer. 22 were two com -- two crashes. One was last year, 5 (Pages 145 to 148) Esquire Deposition Services MD - 1-800-539-6398 D.C. - 1-800-441-3376 VA - 1-800-752-8979 a77cbcf5-7ff0-478d-a5f4-3a9a93751c41 Case 1:05-cv-01483-JDB Document 33-8 Filed 06/21/2007 Page 7 of 74 Marialice Williams Page 149 Page 151 1 which would be 2006. And one would be, I think, 1 question -- 2 around 2003 or '4. Yes -- 2 THE WITNESS: I'm sorry, are you 3 Q What documents -- 3 waiting for me? 4 A -- 2004. 4 BY MS. BECKER: 5 Q What documents relating to Fannie Mae 5 Q Can you identify Exhibit 11? 6 were stored on your laptop? 6 A It's a subpoena for me to be deposed in 7 A I -- I can't say precisely but whatever 7 the Fannie Mae -- excuse me, in the Cam Financial 8 e-mails or materials that I had prepared for 8 Services and GenStar Insurance matter. 9 presentations to prospective insurance companies or 9 Q Did a deposition in fact take place on 10 to various and large cross-section of potential 10 March 17, 2003? 11 clients. And there would've been newsletters that 11 A I don't recall, but if that's the date 12 I did explaining what type of structure we were 12 that's in here, it must have been the correct date. 13 looking at for credit enhancement and that type of 13 Q Were you asked to produce documents in 14 thing. 14 connection with that deposition? 15 Q In response to the subpoena issued 15 A I didn't remember that I was, but I 16 April 24, 2002, did you search for documents on 16 guess I was. Says here you as well as documents. 17 your laptop? 17 Right. That's what it says. 18 A I believe I did. 18 Q Would you have searched for documents 19 Q Did you produce any documents responsive 19 responsive to document -- documents requested in 20 to the subpoena of April 24, 2002, that were on 20 the subpoena dated January 6th, 2003? 21 your laptop, in the Cam litigation? 21 A I really don't remember. 22 A I -- I suspect those were generally 22 Q Do you have any reason to believe that Page 150 Page 152 1 duplicates of whatever was on my larger computer. 1 you didn't search for documents responsive to this 2 I generally didn't print from my laptop. I used it 2 subpoena? 3 largely for traveling. 3 A I'm sure I did. I just don't recall. 4 Q Between the documents on your laptop and 4 Q I'd like to direct your attention to 5 the documents on your main computer, would you have 5 Page 8142, which is Page 4 of Exhibit 11. 6 produced any documents relating to the April 24, 6 Do you see under number eight where it 7 2002 subpoena that were stored on either of those 7 defines the term "MCRI"? 8 computers? 8 A Yes. 9 A Oh, I'm sure that I would've used both 9 Q How does this subpoena define MCRI? 10 of those sources to look for documents in response 10 A It says: Multifamily credit risk 11 to the sus -- subpoena. 11 insurance, multifamily collateral replacement 12 Q And you would've produced any that you 12 insurance or similar devices. 13 had in your possession; is that correct? 13 I know what MCRI is 'cause I created it. 14 A I would have produced what I had on 14 Q Can you explain to me what MCRI is? 15 those two computers at that time. 15 A Certainly. It is a form of credit 16 MS. BECKER: I'd like to hand 16 enhancement which enables a -- an -- a company that 17 you what I will ask the court reporter to mark as 17 is selling a portfolio of mortgage loans to Fannie 18 Exhibit 11. 18 Mae in exchange for -- well, excuse me, as 19 (Deposition Exhibit No. 11 - Bates stamp 19 exchanging mortgage loans for mortgage-backed 20 FNMA.MBW.008139 through 8144 - was marked for 20 securities. And in those transactions, Fannie Mae 21 identification.) 21 generally requires, once those loans are reviewed 22 MR. DANIELS: Is there a 22 and those properties are reviewed, a certain level 6 (Pages 149 to 152) Esquire Deposition Services MD - 1-800-539-6398 D.C. - 1-800-441-3376 VA - 1-800-752-8979 a77cbcf5-7ff0-478d-a5f4-3a9a93751c41 Case 1:05-cv-01483-JDB Document 33-8 Filed 06/21/2007 Page 8 of 74 Marialice Williams Page 153 Page 155 1 of -- of credit risk is assessed, not just credit 1 in those transactions where affordable housing 2 risk, other real estate risk and other risk is 2 deals were being done with market -- with tax 3 assessed against that portfolio. And once it is 3 credits. So we were going to use it on everything, 4 determined how much that risk is, there's a certain 4 including the May 2001 DUS proposal. 5 percentage with respect to the actual amount of the 5 Q I'd like to ask you to turn to the next 6 mortgage loans themselves which must be set aside 6 page of the document, under document request number 7 traditionally to cover the losses on those loans 7 seven. Can you identify document request number 8 during the lifetime of those mortgage-backed 8 seven? 9 securities. 9 A All documents that refer to or relate to 10 What I created was, for the first time 10 any type of mortgage collateral insurance, 11 in the multifamily securitization marketplace, as I 11 including but not limited to, MCRI, environmental 12 had done with other things I had created for Fannie 12 hazard insurance, single family credit risk 13 Mae, in this particular instance what I did was I 13 insurance, single family collateral replacement 14 was able to take the responsibility for the loss 14 insurance, or captive insurance. 15 coverage outside of the pool of mortgages so that 15 Q As you sit here today do you believe 16 when Fannie Mae actually issued the securities, all 16 that you searched for documents in response to 17 of the securities were issued at AAA plus, and the 17 document request number seven in connection with 18 credit enhancement or the loss coverage piece was 18 the January 6, 2003 subpoena? 19 an independent insurance policy, which was designed 19 A I believe I did look for information on 20 to cover any losses on those loans during the 20 all of those things. 21 lifetime of that mortgage-backed security. 21 Q Would you have produced those documents 22 And so that's why we called it 22 if you had them in your possession? Page 154 Page 156 1 "multifamily," meaning pools of multifamily 1 A Whatever was in my possession I would 2 mortgage loans, credit risk insurance, because it 2 have produced. Which was not everything I did, 3 was in fact insuring against the losses that would 3 just what I had in my possession. 4 be associated with any of those mortgage loans 4 Q What would you have done that you did 5 during the lifetime of the security, which would be 5 not have in your possession? 6 occasioned -- those losses would be occasioned by 6 A As I stated earlier in this deposition, 7 the parameters of what's described within the 7 there were considerable number of e-mails, 8 Fannie Mae credit model, which I had a fortunate 8 telephone calls I would not have had in my 9 opportunity to have a great deal of input on. 9 possession. There would even have been strategy 10 Q You'll recall in your last deposition we 10 papers and other things which would have been 11 talked about your May 2001 proposal. Do you -- do 11 created and put in the computer, which I would not 12 you remember that? 12 necessarily have had access to. And again, I think 13 A Yes, we did talk about that. That was a 13 there were a number of places in storage where I 14 DUS-related proposal. 14 may not have seen that there were boxes that may 15 Q Does MCRI, as you've described it, 15 have related to Fannie Mae. 16 relate to your May 2001 proposal? 16 So there -- there are any number of ways 17 A MCRI relates to every single type of 17 in which whatever I gave in response to this may 18 proposal that I took to Fannie Mae, including the 18 not have been an exhaustive, although I attempted 19 DUS proposal, affordable housing, even the 19 to locate everything, it may not have been as 20 insurance of environmental losses; it ran the whole 20 exhaustive as it might have been. 21 gamut, even in the terms of their equity program, 21 Q With respect to the e-mails and strategy 22 substituting an insurance policy rather than cash 22 papers that you believe you may have had, is the 7 (Pages 153 to 156) Esquire Deposition Services MD - 1-800-539-6398 D.C. - 1-800-441-3376 VA - 1-800-752-8979 a77cbcf5-7ff0-478d-a5f4-3a9a93751c41 Case 1:05-cv-01483-JDB Document 33-8 Filed 06/21/2007 Page 9 of 74 Marialice Williams Page 157 Page 159 1 reason that you would not have had those in your 1 so forth, and it was packed to the rafters. 2 possession relating to the computer crashes that 2 My mother died. I had all of her things 3 you've already testified about? 3 that I had moved in there. It was just very 4 A Computer crashes, yes, and loss of 4 difficult to see what was in that garage and to 5 storage documents. I had a storage bin on U Street 5 really get -- find one box. 6 which -- and I was doing a lot of traveling at the 6 Because of that situation, records were 7 time because of personal reasons and -- to help out 7 ruined, a -- a $10,000 rug of my mother's was 8 someone in my family, and somehow in there my 8 ruined. All kinds of things happened in that 9 possessions were taken into custody by the storage 9 garage, but that was the deterioration that 10 people and sold at some auction which I did not 10 occurred in that garage. 11 know anything about. And I was unable to retrieve 11 Okay. So then I moved from there into 12 anything from that. 12 where I'm moving -- where I'm living now, and I 13 Q When were your possessions taken from 13 store boxes in a storage area. Meanwhile, it's 14 the storage unit? 14 very difficult to keep up with what's -- so what 15 A In 2006, I believe it was. Or maybe it 15 you keep close to you is what you're work -- 16 was 2005. August of 2005 or 2006, early June -- 16 working on currently, which is a great deal of 17 January, February, March, in that area. 17 what -- is what I produced when it was time to 18 Q So those documents in your storage unit 18 respond to defendants' request for documents in 19 on U Street would have been there in the 2002 and 19 this case. 20 2003 time frames; is that correct? 20 I did have an opportunity then to pull a 21 A Some of them might have been. Well, 21 lot of things out that I had not seen before. But 22 I'll go into great detail so you will understand 22 then I also did lose that storage area. So that's Page 158 Page 160 1 the complexity of my storage situation. 1 the -- the story of my storage and boxes, and 2 When I left Fannie Mae in 1998, I took 2 that's as well as I can put it. 3 an office at the Watergate office building. I 3 Q In response to the 2002 and 2003 4 began working in earnest to do a project with 4 subpoenas, did you search the storage area? 5 Fannie Mae and kept documents and everything in 5 A Yes, I did. 6 that office for some length of time. In 2001, 6 Q And did you produce any documents that 7 right after 9/11, the -- I remember having a 7 were in the storage area? 8 computer crash, then 2001, a number of documents 8 A I don't recall. 9 that we might have ordinarily stored, due to the 9 Q Do you have any reason to believe you 10 fact that we were all aware that the insurance 10 didn't produce the documents that were in the 11 market had dried up a number of things that I was 11 storage area? 12 working on, we disposed of at the time we moved out 12 A No, I don't. No. 13 of the office building at the Watergate. 13 Q As far as e-mails that you would've had 14 When I was living at the Watergate as 14 with Fannie Mae, would those have been generally 15 well, during that time, I had a storage area, 15 kept on your computers? 16 because I was living in a co-op, and I had moved 16 A Yes. 17 out of a house. 17 Q Is the only reason that you would not 18 So I had huge numbers of boxes at that 18 have had those e-mails in your possession based on 19 storage area. I had boxes in my office. I had -- 19 the computer crashes that you've already described? 20 then I -- then I moved and I tried to consolidate 20 A Yes. 21 in -- back into a house and had a huge garage there 21 Q When did you move out of the Watergate? 22 in which I put a great deal of papers and boxes and 22 A I believe it was -- I have -- I -- I 8 (Pages 157 to 160) Esquire Deposition Services MD - 1-800-539-6398 D.C. - 1-800-441-3376 VA - 1-800-752-8979 a77cbcf5-7ff0-478d-a5f4-3a9a93751c41 Case 1:05-cv-01483-JDB Document 33-8 Filed 06/21/2007 Page 10 of 74 Marialice Williams Page 161 Page 163 1 don't have it with me. Either 2001 or 2002. I 1 Watergate? 2 believe it was 2001. 2 A Yes, I did. 3 Q Do you remember when in 2001? 3 Q Did you have a home in the Watergate? 4 A I filed bankruptcy. I had to sell my 4 A Yes, I did. 5 property and pay off my business debts I had 5 Q Did you vacate both the -- both the home 6 acquired from trying to do business with Fannie 6 and the office at the same time? 7 Mae. I think it was around 2000 -- 2001 or 2002. 7 A Yes, I did. 8 I just cannot remember precisely when it 8 Q Do you recall when the Cam litigation 9 was. I just can't. 9 was filed? 10 Q How did -- 10 A No, I don't. 11 A It's on -- should be on my tax records, 11 Q Do you have any recollection of when you 12 I think. It should be on my forms I gave to 12 first knew about the Cam litigation? 13 somebody here. 13 A Let's see. It would have to have been 14 Q How does the timing of your bankruptcy 14 prior to May -- April 24th, 2002. 15 relate to when you moved out of the Watergate? 15 Q Was the subpoena that you received in 16 A Well, I could no longer afford to live 16 the Cam litigation the first that you had heard of 17 there. I could no longer afford to have an office 17 the Cam litigation? 18 in the Watergate. I didn't get any of the business 18 A Of the litigation, yes. 19 I thought I was going to get from Fannie Mae, and 19 Q What was your involvement in the Cam 20 so I had to move. 20 litigation? 21 Q Did you move before or after you filed 21 A I didn't have any involvement in the Cam 22 bankruptcy? 22 litigation except as a -- as a person who was Page 162 Page 164 1 A I moved after I filed bankruptcy. 1 deposed because I probably had more information 2 Q How long after? 2 about the product that was under -- in question 3 A No. I moved before I filed bankruptcy. 3 than anyone else. It was five, I think, five or 4 I think I moved in 2001 and filed bankruptcy in 4 six or seven very grueling days. 5 2002. I spent the -- the balance of my retirement 5 Q Did anyone from Fannie Mae ever contact 6 funds from Fannie Mae just eking out a living 6 you about the Cam litigation? 7 through the next year and then filed bankruptcy. 7 A No. Yes -- well, Fannie Mae's 8 When I sold my unit at the Watergate, I 8 representative, yes. 9 had to pay off a $200,000 business debt I had 9 Q Who was that? 10 acquired which became -- meant that I virtually had 10 A His name was Gerard Wimberly. 11 no -- nothing left on the sale because I had to 11 Q And Mr. Wimberly is with the McGlinchey 12 split it with my mother who was the joint owner of 12 Stafford firm; is that correct? 13 the apartment with me. 13 A Correct. 14 Q Did you move out of the Watergate after 14 Q What was the reason that Mr. Wimberly 15 September 11, 2001? 15 contacted you, as you recall? 16 A Yes. I believe so. 16 A He contacted me prior to serving me with 17 Q Was it shortly thereafter or -- 17 any documentation, having me served, about 18 A I just don't recall and I -- I would 18 defending Fannie Mae -- Fannie Mae's position 19 like to tell you. I'm trying to think if I have 19 against Bob Jones from Cam Financial. 20 anything in my possession that would let me know. 20 Q Was he asking for your cooperation in 21 I just don't recall when it was. 21 defending Fannie Mae's position against Bob Jones? 22 Q Did you have office space in the 22 A Yes. 9 (Pages 161 to 164) Esquire Deposition Services MD - 1-800-539-6398 D.C. - 1-800-441-3376 VA - 1-800-752-8979 a77cbcf5-7ff0-478d-a5f4-3a9a93751c41 Case 1:05-cv-01483-JDB Document 33-8 Filed 06/21/2007 Page 11 of 74 Marialice Williams Page 165 Page 167 1 Q What was your response? 1 whatever it took to try to keep Bob Jones from 2 A My attorney at the time, Julia Williams, 2 getting the business he might have deserved. 3 spoke to him and I -- I'm not certain exactly what 3 Q Why would Mr. Lawch have done that, in 4 she said, but I believe she told him that -- I 4 your view? 5 don't remember what she told him. 5 A Because he didn't like Bob Jones and he 6 Q Were you willing to cooperate in 6 didn't -- and I think Richard was very torn because 7 defending Fannie Mae's position against Bob Jones? 7 he had pad -- virtually paid no attention to the 8 A I did not believe that Fannie Mae 8 development of this entire product, and then once 9 treated Bob Jones in a fair manner based on my 9 it turned out that it was something really good, he 10 personal involvement in Bob Jones's development of 10 was very reluctant not to try to take, you know, 11 MCRI along with me. 11 credit for it. He wanted the -- you know, to be 12 Q Did you make that known to Fannie Mae? 12 the -- the lead person, but he didn't have any 13 A I made that known to Fannie Mae before I 13 knowledge about how it was done. So he basically 14 left Fannie Mae because I had been asked about the 14 just went at the whole thing all wrong, but -- 15 exact same issue before I left, as well as being 15 MR. DANIELS: Speak up. 16 asked about it in the deposition. 16 THE WITNESS: Mm? 17 Q Do you remember the time frame in which 17 MR. DANIELS: Speak up. You 18 you were contacted by Mr. Wimberly? 18 were trailing off in your answer. Please. 19 A It was just prior to this subpoena being 19 THE WITNESS: Yes, he -- Richard 20 issued, I believe. 20 was -- it was common knowledge how Richard felt 21 Q So that would've been in the winter or 21 about Cam, and it was pretty common knowledge how 22 early spring of 2002? 22 he felt about me generally, too. But in this -- Page 166 Page 168 1 A Correct. 1 that instance, I was working there and since I had 2 Q And did you make it known to Fannie Mae 2 been consistently producing products that enabled 3 that you were not willing to cooperate in -- 3 Fannie Mae to compete effectively in the secondary 4 A I told Fannie Mae I would cooperate with 4 marketplace, Richard wasn't really able to do 5 them as -- as it was required by me of the law. I 5 anything more than simply limit my compensation, 6 believe that's what we said, and I did cooperate. 6 et cetera. 7 Q Do you remember whether Fannie Mae 7 So -- but he did call Bob Jones several 8 wanted to meet with you? 8 times a redneck, quite a few times. He just really 9 A Yes. 9 had great contempt for him. 10 Q Did you meet with Fannie Mae? 10 BY MS. BECKER: 11 A No. 11 Q You said it was common knowledge how he 12 Q Why not? 12 felt about you? 13 A Because they made it clear that, you 13 A Mm-hmm. 14 know, that -- you know, they didn't have anything 14 Q And how did he feel about you? 15 to offer me. They weren't -- still weren't 15 A Yes. 16 attempting to, you know, do the right thing with 16 Richard and I did not have a good 17 me, so I didn't see what there was to -- to gain 17 relationship after a time at Fannie Mae. He was 18 except to be honest and truthful about what I 18 fond of telling people that I had withheld 19 remembered and what I knew. And I knew that Fannie 19 information from him when he arrived, and I never 20 Mae had acted in a certain manner toward Bob Jones, 20 understood what he meant. But I did unfortunately 21 and I knew that they were going to -- as long as 21 meet one of his prior employers and I mentioned to 22 Richard Lawch was in charge, he was going to do 22 him that I didn't, and from that day forward, 10 (Pages 165 to 168) Esquire Deposition Services MD - 1-800-539-6398 D.C. - 1-800-441-3376 VA - 1-800-752-8979 a77cbcf5-7ff0-478d-a5f4-3a9a93751c41 Case 1:05-cv-01483-JDB Document 33-8 Filed 06/21/2007 Page 12 of 74 Marialice Williams Page 169 Page 171 1 Richard was very unkind to me. 1 that information to anyone else. 2 Q And that was while you were at -- 2 Q Was -- 3 working at Fannie Mae? 3 A It was a corporate environment. 4 A Yes. 4 Q Who's the prior employer that you're 5 But I always thought he respected my 5 referring to? 6 ability. But he didn't really. 6 A A law firm that he worked for. 7 Q At what point did you believe that he 7 Q What's the name of the law firm? 8 respected your ability? 8 A I don't recall the name of it. 9 A I believe he respected my ability when I 9 Q When did Mr. Lawch become aware that you 10 was able to convince Rob Levin, who was at that 10 were aware of his relationship with this law firm? 11 time the -- responsible for the business side of 11 A I spoke at a -- at a -- an American Bar 12 Fannie Mae, when I convinced him to assign someone 12 Association conference to a session that was -- a 13 from the REMIC office to the multifamily division 13 panel that was put together by an African-American 14 so that we could jointly have Fannie Mae issue the 14 man who was attempting to do business at Fannie Mae 15 first senior subordinate securities ever. And at 15 at the time in the affordable housing area. And 16 that time, I -- Richard was still relatively new, 16 while I was at that conference, I virtually ran 17 and he was a little more cooperative. And product 17 into this other person whom I had known when he was 18 development at Fannie Mae takes a very long time, 18 a freshman at Harvard. And he asked me what I was 19 and we were on a very fast track and we were able 19 doing and I told him I'm -- was working at Fannie 20 to do it and able to accomplish that particular 20 Mae and that I had a new vice president and -- gave 21 task. 21 him his name. And he said, oh, he used to work for 22 And then over time, I think, it -- the 22 me. Page 170 Page 172 1 personal side of the relationship, based on, you 1 And when I left that conference and went 2 know, your typical dog-eat-dog kind of environment, 2 back to my office, I said to Richard, oh, I met, 3 I had several people working for me and Richard 3 you know, someone you used to work for. And that's 4 managed to change that working relationship, and 4 when I think things started to go downhill. 5 those people then began to report directly to 5 Q Who was this person? 6 Richard and that was fine, you know. I still -- I 6 A Chuck Hamilton. 7 still created and -- and developed new products for 7 Q And when was the conference? 8 Fannie Mae to make a lot more money, so I was happy 8 A Oh, I really -- sometime after Richard 9 to be able to do that and to bring in the -- the 9 arrived at Fannie Mae, and I can't really recall 10 kind of product I thought Fannie Mae ought to be 10 when that was. Let's see. 11 securitizing. 11 I can't recall when that was. 12 Q Do you believe that Mr. Lawch's view of 12 Q Was this while you were still working at 13 you changed at some point in time? 13 Fannie Mae? 14 A I think it changed at some point in 14 A It was -- oh, absolutely. Yes. 15 time, and I think it was exactly when I mentioned 15 Q Did Mr. Hamilton express to you 16 it; when he was made aware that I knew his prior 16 something negative about Mr. Lawch? 17 employer, and he knew if I knew his prior employer, 17 A Yes. 18 what his prior employer was going to say about him. 18 Q What was that? 19 And therefore I think he felt somewhat concerned 19 A I guess I could summarize it by saying 20 that I would know that information. And I'm 20 he didn't think he was a very good lawyer. 21 certain he would be concerned like everyone else 21 Q Did he express anything else negative 22 would in their job whether or not I would impart 22 about Mr. Lawch? 11 (Pages 169 to 172) Esquire Deposition Services MD - 1-800-539-6398 D.C. - 1-800-441-3376 VA - 1-800-752-8979 a77cbcf5-7ff0-478d-a5f4-3a9a93751c41 Case 1:05-cv-01483-JDB Document 33-8 Filed 06/21/2007 Page 13 of 74 Marialice Williams Page 173 Page 175 1 A No. Just that he was let go by that 1 town, something important is going to happen at the 2 comp -- by that firm. 2 conference. 3 Q Why did you tell Mr. Lawch about your 3 I happen to run into Deborah McKinnon, 4 meeting with Mr. Hamilton? 4 and Deborah was a director also and responsible in 5 A Because I had been to a conference that 5 the multifamily division for the disposal of 6 Fannie Mae had authorized me to go to, and knowing 6 properties. And I said to Deborah I was excited 7 how small the world is, it would've gotten back to 7 that I was going out of town, and she said you 8 Richard one way or the other that I had met Chuck, 8 can't go out of town, and I said why not. And she 9 so I decided to tell him that I met Chuck. He was 9 said because you're getting an award for your MCRI 10 very familiar with Richard, his family -- he knew 10 product. I said, oh, gee, I just told Richard I 11 his wife, you know. It wasn't a casual 11 was leaving town. 12 relationship. 12 And so when I got to the -- I -- I did 13 Q Did Mr. Lawch have any reaction to being 13 go to the ceremony, and as Bob Jones stated in his 14 told about your meeting with Mr. Hamilton? 14 deposition and as everyone at Fannie Mae will tell 15 A Not initially, no. 15 you, I pretty much created that product by myself, 16 Q Did he have a reaction at some point 16 with a lot of people's help, but I clearly was the 17 later? 17 person who worked on it on a day-to-day basis. And 18 A I believe he did. 18 Mr. Lawch arranged it so that I would not get an 19 Q What was that reaction? 19 individual award, which would probably have been 20 A I believe he simply started to treat me 20 about $10,000. Instead, he made it a team award. 21 in a less respectful manner. 21 And when I rose to get the team award when it was 22 Q When did that begin? 22 announced, the people at my table yelled in unison, Page 174 Page 176 1 A After I told him about Chuck Hamilton. 1 what team? Which I found rather interesting that I 2 And I don't recall, as I said, the year that that 2 wasn't the only person who took offense that -- but 3 occurred, but it was after the time that Mr. Lawch 3 I did not mention anything to Mr. Lawch about it, 4 came to Fannie Mae and before I left there in 1998. 4 but I did get my $1,500 reward. 5 And I was in the multifamily division from 1990 5 And then Mr. Lawch began to give me 6 until 1998. 6 reviews that were not reflective of my productivity 7 Q Did Mr. Lawch's treatment of you in a 7 at Fannie Mae. And I don't think there's anyone at 8 less respectful manner start while you were still 8 Fannie Mae who knew my productivity who would agree 9 working at Fannie Mae? 9 with Mr. Lawch's assessment. He virtually said I 10 A Yes. 10 could not write. That I thought more of myself 11 Q Can you describe what he did to treat 11 than anyone else. And such mean and unbecoming 12 you in a less respectful manner? 12 things of a vice president of Fannie Mae as I've 13 A Yes. The -- probably the biggest thing, 13 ever seen. And this was all while I was producing 14 which was really very hurtful, was that there was 14 products that were enabling Fannie Mae to play a 15 no question when I created MCRI that I was going to 15 substantial role in the secondary market in a 16 get some kind of award. 16 productive and competitive way. 17 Well, at the sales and marketing 17 So it just became a personal matter. 18 conference at Fannie Mae, it's a really big deal 18 And I loved my job so much at Fannie Mae, I was not 19 when you get an award there. Number one, I was 19 going to let his feelings and his issues affect me 20 getting ready to go out of town the particular 20 and my productivity. And I would not have left 21 weekend of that conference and Mr. Lawch was aware 21 there had I not thought Fannie Mae was not going to 22 of that. He did not say to me, don't go out of 22 ultimately live up to her commitment to me to give 12 (Pages 173 to 176) Esquire Deposition Services MD - 1-800-539-6398 D.C. - 1-800-441-3376 VA - 1-800-752-8979 a77cbcf5-7ff0-478d-a5f4-3a9a93751c41 Case 1:05-cv-01483-JDB Document 33-8 Filed 06/21/2007 Page 14 of 74 Marialice Williams Page 177 Page 179 1 me the business that I had developed. 1 A I don't think I was the only 2 Q Why do you think that Mr. Lawch turned 2 African-American person at Fannie Mae who felt that 3 against you and decided to make your business 3 he had an issue with African-American people. We 4 relationship with him personal? 4 knew -- we knew, for example, that certain 5 A I believe he's human, like any other 5 attitudes had to exist within his home, because his 6 person, and I believe that personal embarrassment 6 children expressed very interesting thoughts about 7 that he may have felt at someone actually knowing 7 black people and slaves and so forth. And if you 8 his history may have caused him to do whatever he 8 ask Betty Dance, I'm sure she'll give you the whole 9 did. 9 litany on what it was like being there with him and 10 Q Do you believe that he treated you 10 his children being so disrespectful. And there -- 11 differently while you were at Fannie Mae based on 11 and I would say any other black person that was 12 your race? 12 there at the time could tell you. 13 A Yes. 13 Q Did you talk to other African-Americans 14 Q And what's that based on? 14 while you were at Fannie Mae about Mr. Lawch? 15 A That's based on, number one, what he did 15 A I talked to a lot of African-Americans 16 about my award; number two, the way that he treated 16 and a lot of women who gravitated to my office 17 me with respect to my supervisory responsibilities; 17 frequently about EEO issues. And my recommendation 18 number three, when he -- Mr. -- Mr. Lawch, for 18 was always to people, talk to the person that 19 example, was such a poor manager that he had -- was 19 you're involved in the situation with because you 20 required to go to classes that involved him 20 have to remember that if you file an EEO complaint, 21 becoming more sensitive to employees and with 21 you better be sure you're going to win it because 22 respect to women and racial issues. 22 otherwise your career is going to be over here. Page 178 Page 180 1 And he -- if -- if somebody's not doing 1 And that had been proven time and time again. 2 well in a position, if I wasn't doing well as a 2 And it was not easy for 3 supervisor, I would've thought I should've been 3 African-Americans and women in the levels at Fannie 4 given the same courtesy as everybody else; well, 4 Mae where I was to survive unless you had a mentor 5 give me some training that would make me a better 5 who was at a much higher level who was willing to 6 one, not just, you know, invite my staff into your 6 help you and -- and push your career along. It did 7 office and pal around with them and play golf in 7 not matter whether you were productive, smart, 8 your office, putt in your office with them. 8 intelligent or anything. It only mattered who your 9 And -- you know, and I mean it was a 9 mentor was and if you had someone to -- to champion 10 real -- and I was the one excluded from the 10 your cause. 11 knowledge of whatever was going on in the office. 11 Q Do you feel that you had a mentor or 12 He excluded me from discussions about the business, 12 someone to champion your cause at Fannie Mae? 13 and I was the director for capital markets. And he 13 A No. At Fannie Mae the tasks were given 14 had his little cronies and his pets and that's the 14 out for assignments that could either make or break 15 way it worked, and that's the way it works in 15 your career. And there was no question who was 16 corporate America and there's nothing anybody can 16 getting the good assignments. 17 do about that. But he definitely had a preference 17 I made my mark at Fannie Mae because I 18 for certain people, and they certainly weren't 18 created the concepts that I developed, and 19 black. 19 therefore was fortunate enough to -- to have some 20 Q Why do you attribute this to the race of 20 impact on -- in -- in the sense of change at Fannie 21 the people that he was dealing with as opposed to 21 Mae. But I was not given the assignments that -- 22 him simply being a poor manager? 22 that were the achievements of my career, from day 13 (Pages 177 to 180) Esquire Deposition Services MD - 1-800-539-6398 D.C. - 1-800-441-3376 VA - 1-800-752-8979 a77cbcf5-7ff0-478d-a5f4-3a9a93751c41 Case 1:05-cv-01483-JDB Document 33-8 Filed 06/21/2007 Page 15 of 74 Marialice Williams Page 181 Page 183 1 one, including creating the first data -- database 1 certainly lured me by saying they were going to put 2 that gave you consistent information on pools of 2 me on their board, et cetera, et cetera, et cetera, 3 multifamily mortgages. I mean that was my -- you 3 but you know, it wasn't going to matter one way or 4 know, I created that with $65,000. Show me 4 the other. I knew that there was a great deal more 5 anybody's system that can be done for that price 5 to be done in the marketplace on this product, and 6 now. Took them $3 million to upgrade it. 6 that I had the capability of doing it and would do 7 So I know I had to have some kind of -- 7 it with Cam or with ever -- whomever else had the 8 of capacity there. But I did not get assignments 8 ability to finance the -- the amount of time that 9 because I was get -- they were handed to me. I 9 it would take to do the product development. 10 made my way at Fannie Mae. 10 Q Did you file an internal complaint of 11 Q Why did you leave Fannie Mae? 11 discrimination while you were at Fannie Mae? 12 A I left Fannie Mae because I had a long 12 A I certainly did not. 13 conversation with Lou Hoyes, and told him that I 13 Q Why not? 14 was so happy that we had issued the first 14 A Because I had watched what happened to 15 securities based on this MCRI concept, and that it 15 people who did file complaints. Been there for a 16 was going to make a huge difference for the 16 long time. 17 communities I was concerned about, which were the 17 Q Did you tell anybody at Fannie Mae that 18 inner cities, or the rural areas where mortgages 18 you believed that Mr. Lawch treated you differently 19 tended to be smaller and less -- less than standard 19 based on your race? 20 according to Fannie Mae's underwriting, and that I 20 A Certainly. 21 thought that I would take that opportunity, become 21 Q Did you tell anybody at Fannie Mae that? 22 an insurance broker and do the MCRI business. And 22 A Certainly. Page 182 Page 184 1 he assured me that, you know, that would not be an 1 Q Who did you tell at Fannie Mae? 2 issue, that we would continue to work together. 2 A I had that conversation frequently with 3 And that is why I left Fannie Mae. 3 one of the vice president -- one of the -- I can't 4 And he specifically said to me, are you 4 remember what level he was. In credit policy there 5 leaving Fannie Mae for something or are you leaving 5 were quite a few people that I was very close to 6 because you don't want to be here? And he then 6 there. I also discussed it with people within the 7 also said to me, if you do want to stay here, I can 7 multifamily division who were African-American. 8 change your supervisory person to be Wendell Johns 8 I don't believe I mentioned it to anyone 9 tomorrow. I can do that. To which I said to him, 9 white, but -- yes, I did, Stuart Levy. Who was 10 I have been trying to explain to you about Richard 10 also in credit policy. 11 Lawch for a long time. I'm sorry that you waited 11 Q Who's the most senior person that you 12 until this moment, but my mind's made up. I have 12 told at Fannie Mae? 13 the opportunities. I really want to go out and see 13 A I think I told vice president for 14 that this product gets out into the marketplace, 14 diversity, Maria Johnson. 15 that Fannie Mae can start to do the kind of 15 Q What was Ms. Johnson's reaction? 16 affordable housing program on the capital markets 16 A Same as mine; well, don't file a 17 side that I felt it should be doing according to 17 complaint because that's the end of your career. 18 its charter. And so I left. 18 Q Were those Ms. Johnson's exact words? 19 Q Did you leave understanding you would 19 A Or something to that effect, yes. I've 20 have a position with Cam Financial? 20 known her a long time. I introduced her to Rob 21 A I wasn't certain that I was going to 21 Levin. He hired her because I introduced him to 22 have a position with Cam Financial. They had 22 her. 14 (Pages 181 to 184) Esquire Deposition Services MD - 1-800-539-6398 D.C. - 1-800-441-3376 VA - 1-800-752-8979 a77cbcf5-7ff0-478d-a5f4-3a9a93751c41 Case 1:05-cv-01483-JDB Document 33-8 Filed 06/21/2007 Page 16 of 74 Marialice Williams Page 185 Page 187 1 Q When did you have this conversation with 1 A Yes, it is. 2 Ms. Johnson? 2 Q And your understanding is this is the 3 A I don't recall. Probably all the way 3 operative complaint in the case; is that correct? 4 through 'til 1998 when I left. From the time she 4 A Correct. 5 arrived until the time I left. 5 Q I'd like to ask you to look at 6 MS. BECKER: Can we go off the 6 Paragraph 19 of the complaint on Page 7. 7 record for a few minutes. 7 A Mm-hmm. 8 VIDEOGRAPHER: Off the record at 8 Q Can you read that? 9 11:38:36. 9 A In June 1998 Plaintiff Williams left the 10 (Thereupon, a recess was taken.) 10 employment of Fannie Mae pursuant to a negotiated 11 VIDEOGRAPHER: On the record at 11 settlement agreement which ostensibly resolved 12 11:54:19. 12 issues of alleged unlawful discrimination and 13 BY MS. BECKER: 13 retaliation on the bases of race and sex charges 14 Q I'm handing you what will be marked as 14 which have been stated by Plaintiff Williams prior 15 Exhibit 12. 15 to her departure from Fannie Mae employment in 16 (Deposition Exhibit No. 12 - Amended 16 which constituted protected activities as defined 17 Complaint - was marked for identification.) 17 by the civil rights laws of the United States. 18 MR. DANIELS: May I take up a 18 Q Did you make allegations of unlawful 19 preliminary matter before you continue your 19 discrimination and retaliation on the basis of race 20 questioning? Today we handed you certain copies 20 and sex prior to leaving Fannie Mae? 21 of -- of Ms. Williams' tax records, and I want to 21 A Yes, I did. 22 be certain that we are giving them to you under a 22 Q Who did you make those allegations to? Page 186 Page 188 1 confidentiality agreement. Will they be used only 1 A I made them to Tom Nieds (ph), I believe 2 in connection with this litigation and not 2 was his name, who was the first person who was 3 shared -- the same confidentiality agreement we 3 charged with working out my settlement agreement 4 signed when we -- when you gave us your documents? 4 for my departure from Fannie Mae. 5 MS. BECKER: I'm going to need 5 Q Who is Tom Nieds? 6 to consult with my client before we make a final 6 A That's a good question. I don't really 7 decision on that. We will -- we'll discuss that 7 know who he is, what -- where he came from or what 8 later in the deposition before we take up those 8 his claim to fame is. He certainly didn't ever do 9 records. 9 anything I ever thought was particularly 10 MR. DANIELS: Okay. But I -- I 10 significant. He was just an officer and somebody's 11 handed them over in good faith that we would agree 11 friend. What kind of -- I think he was Jim 12 to this confidentiality. I should've raised it 12 Johnson's friend. Or Jim Johnson's wife's friend 13 before I gave them to Sarah earlier today. 13 or something like that. 14 BY MS. BECKER: 14 Q What were the allegations of 15 Q Ms. Williams, can you identify 15 discrimination and retaliation on the basis of race 16 Exhibit 12? 16 and sex that you made to Mr. Nieds? 17 A Yes, it is the amended complaint in the 17 A I told him that I thought that the 18 civil action of Marialice Bathrus Williams versus 18 settlement agreement that they were offering me was 19 the -- Fannie Mae, Richard Lawch, and Grace 19 absolutely not reflective of my contributions to 20 Huebscher. 20 Fannie Mae, and that the offer was basically the -- 21 Q This is the complaint that you filed; is 21 what was -- if you were getting ready to be 22 that correct? 22 terminated for cause from Fannie Mae, you pretty 15 (Pages 185 to 188) Esquire Deposition Services MD - 1-800-539-6398 D.C. - 1-800-441-3376 VA - 1-800-752-8979 a77cbcf5-7ff0-478d-a5f4-3a9a93751c41 Case 1:05-cv-01483-JDB Document 33-8 Filed 06/21/2007 Page 17 of 74 Marialice Williams Page 189 Page 191 1 much got the settlement that I got, whether you'd 1 Q Who did you call? 2 ever produced anything or not. And at that point I 2 A I called Brian Lederer. 3 just simply said to him, you know, I -- you know, 3 Q Did Mr. Lederer represent you in 4 white people leave here and they don't get this 4 relation to the settlement agreement that you 5 kind of settlement. You know, they get an enhanced 5 negotiated with Fannie Mae in June of 1998? 6 settlement and all I'm getting is this. And number 6 A Yes. 7 two, you wouldn't even extend the time for me to 7 Q Other than Mr. Lederer, did you talk to 8 exercise my options, which meant I was -- I was 8 anybody else about your settlement agreement? 9 going to have a huge taxable event. You know, I 9 A I think I called Tom White, who had been 10 mean just little petty crap they could've been 10 a senior vice president for multifamily. I -- I 11 nicer about. 11 believe I called him because I was just so stunned 12 But again, you know, I'm sure Mr. Nieds 12 at the offer, but I -- I -- I can't tell you 13 was taking his instructions from Mr. Lawch, and he 13 honestly what -- I thought I had called Tom White. 14 sure didn't care. And didn't care about my 14 Q Did you talk to anybody else about your 15 accomplishments and eventually was taken off the 15 settlement agreement? 16 negotiations. Someone else was put on it. 16 A I don't think so. 17 Q Do you believe that Mr. Lawch was behind 17 Q I'd like to turn your attention to 18 the original settlement offer? 18 Paragraph 51 of the complaint. Do you remember a 19 A Yes. 19 meeting on the subject of captive insurance 20 Q And you believe that that original 20 companies? 21 settlement offer was the product of discrimination 21 A Yes. Had several. Before and after I 22 and retaliation by Mr. Lawch? 22 left Fannie Mae. Page 190 Page 192 1 A Yes. 1 Q What meetings did you have before you 2 Q Did Fannie Mae subsequently make you a 2 left Fannie Mae? 3 different offer? 3 A Before I left Fannie Mae I had meetings 4 A No. They modified it to some extent but 4 with the credit officers in credit policy with the 5 not much. 5 division, Fannie Mae members of the multifamily 6 Q Was the modification an enhancement of 6 division, with -- I brought in -- prior to the 7 your compensation under the settlement agreement? 7 merger with Marsh Mac, oh, Lord, I forgot the name. 8 A Modest amendment, mod -- modest. 8 There was another major insurance brokerage which 9 Q My question is: Was the modest 9 merged with Marsh Mac and we brought in very, very, 10 amendment giving you more money than you had 10 very high-level officials from Marsh Mac, GenStar, 11 originally been offered? 11 and other place and a couple of other places, very 12 A It was giving me a little more than 12 high-level individuals, to discuss the basic 13 someone who was about to be terminated from the 13 concept of captive insurance. And then I wrote a 14 company. 14 proposal following that meeting to Fannie Mae. I 15 Q Do you remember when these negotiations 15 was still an employee at the time. 16 with Mr. Nieds took place, in relation to when you 16 Then over the next few years, a 17 left Fannie Mae? 17 significant number of developments occurred which 18 A In June of 1998. 18 made it far more feasible for corporations like 19 Q Do you remember when in June? 19 Fannie Mae to form captive insurance companies 20 A No, I think it took the whole month of 20 because an Internal Revenue Service opinion came 21 June. I met with him several times and then I had 21 out that in fact captive insurance companies are 22 to call a lawyer. 22 true insurance companies, and therefore the 16 (Pages 189 to 192) Esquire Deposition Services MD - 1-800-539-6398 D.C. - 1-800-441-3376 VA - 1-800-752-8979 a77cbcf5-7ff0-478d-a5f4-3a9a93751c41 Case 1:05-cv-01483-JDB Document 33-8 Filed 06/21/2007 Page 18 of 74 Marialice Williams Page 193 Page 195 1 expenses of operating that insurance company were 1 securities and banking. And Kate is an 2 deductible by the owner. Even though it might've 2 international expert on captives and was discussing 3 been a subsidiary of Fannie Mae, it could -- it 3 the concept that we had that either Fannie Mae 4 could still deduct those expenses, et cetera, 4 could own a captive and rent out cells to various 5 et cetera. 5 individuals so that they use their own individual 6 And because of that -- my friend Harvey 6 captive cell as a credit enhancement or Fannie Mae 7 Hartsfield and I had been extremely active with the 7 would simply have the option of utilizing credit -- 8 DC office of insurance, securities, and -- DISB, 8 the -- the captive for credit enhancement for 9 insurance, securities, and banking, and I had 9 itself and charging the customers for that service. 10 explained the concept to them. I'd gone back to 10 Q Were there any materials handed out at 11 Fannie Mae and explained that the DC had the -- a 11 the meeting? 12 new captive law and that we would prefer to use the 12 A Yes, I know that we did di -- diagrams 13 captive in DC if we were going to pursue this. 13 because it's a -- a somewhat complicated -- 14 We had a gentleman from Atlanta, whose 14 somewhat complex structure in that you have 15 name is escaping me, plus Bob Jones, all of us were 15 several, quite a few parties. You have a 16 pursuing this concept of captive insurance 16 reinsurer, you have -- and -- and we had done 17 companies, either being located in the Cayman 17 diagrams with arrows and so forth indicating the 18 Islands, the Virgin Islands, which also had a new 18 actual process of securitization utilizing this 19 captive insurance law, and the District of 19 captive insurance as -- as a credit enhancement 20 Columbia. And those discussions continued, my 20 vehicle. 21 discussions on that still continuing to the 21 Q Was that done in something like a 22 present, but with Fannie Mae certainly until, as 22 PowerPoint presentation? Page 194 Page 196 1 far as I can remember, into 2002 and beyond. 1 A I think we used a PowerPoint as well 2 Q You reference a particular meeting here 2 as -- no, I think we had hard copy in that meeting. 3 in Washington, DC? 3 And -- but they were depictions of our whole -- our 4 A Mm-hmm. 4 whole concept. Our whole captive insurance 5 Q Who was -- who was at that meeting? 5 concept. And we talked about the various parties 6 A The individuals listed there: Harvey 6 and clients of ours whom we had discussed the 7 Hartsfield, Kate Westover, Grace Huebscher, Rhoda 7 concept with. 8 Newman. There was an attorney whom I did not know. 8 Because again, you know, you can't just 9 I thought her name was Carol or Carolyn. She was 9 come to Fannie Mae with an idea, you have to come 10 new to Fannie Mae at that time, relatively new, and 10 with the whole package. So you've got a lot of 11 she was serving as counsel. And I had been 11 product development to do prior to -- to going to 12 instructed to work through Rhoda Newman as the 12 Fannie Mae and certainly prior to presenting any 13 staff contact person for any business I had. And 13 transaction utilizing a particular structure. 14 those were the people who were at the meeting. 14 Q I'd like to turn your attention to 15 Q What occurred at the meeting? 15 Paragraph 53 of the complaint. 16 A Kate Westover and Harvey Hartsfield and 16 What happened after that meeting to make 17 I made an add -- an additional presentation to 17 you believe that you had been blackballed by Fannie 18 Fannie Mae about the feasibility of using the DC as 18 Mae? 19 a captive jurisdiction, largely because the 19 A I really didn't get any further com -- 20 implementing regulations for DC were being written 20 communication or correspondence from them after 21 by Kate. We had recommended her to Larry Mirel, 21 attempting to contact them. I still continued to 22 who at the time was the commissioner for insurance 22 cc Fannie Mae on e-mails regarding the development 17 (Pages 193 to 196) Esquire Deposition Services MD - 1-800-539-6398 D.C. - 1-800-441-3376 VA - 1-800-752-8979 a77cbcf5-7ff0-478d-a5f4-3a9a93751c41 Case 1:05-cv-01483-JDB Document 33-8 Filed 06/21/2007 Page 19 of 74 Marialice Williams Page 197 Page 199 1 of that concept. But I think by then Bob Jones had 1 A I believe they are. 2 amended his complaint to include Fannie Mae, 2 Q I'd like to direct your attention to 3 because as I recall, initially Fannie Mae was not a 3 your answer to interrogatory number one. Is your 4 party to the Cam litigation. Initially it was only 4 answer to interrogatory number one complete or is 5 GenStar and GenRe, which were failing to -- to 5 there any additional information that you believe 6 honor the confidentiality agreement and exclusivity 6 is responsive to the question posed in interrog -- 7 agreement that he had with them. 7 interrogatory number one? 8 But then I believe the judge said that 8 A You said is that my -- 9 Fannie Mae was an indispensable party, given that 9 Q Is your answer to interrogatory number 10 she was actually distributing the funds that were 10 one complete or is there any additional information 11 going to these various places and -- and were -- 11 that you would like to add to your answer? 12 and had knowledge of the agreements that Bob and 12 A In the second paragraph of my answer on 13 Cam had with these companies. 13 Page 1, it says: It was the actions, not the 14 MS. BECKER: Let's go off the 14 statements, that made me aware that Fannie Mae was 15 record for just a minute. 15 excluding me from the pool of insurance brokers. 16 VIDEOGRAPHER: Off the record at 16 And I'd have to say that based on that, 17 12:13:57. 17 the actions, right, it was the actions that made me 18 (Thereupon, at this point in the proceedings 18 know. 19 a luncheon recess was taken.) 19 Q You referred to a statement by Richard 20 VIDEOGRAPHER: On the record at 20 Lawch that he was, quote, working with an 21 1:16:18. 21 international broker for doing some insurance 22 MS. BECKER: Ms. Williams, I'm 22 business for the MBS pools. Page 198 Page 200 1 handing you what I'll ask the court reporter to 1 Do you see that? 2 mark as Exhibit 13. 2 A Mm-hmm. Yes. 3 (Deposition Exhibit No. 13 - Plaintiff's 3 Q How does that support your claims in 4 Answers to Defendants' Interrogatories - was 4 this case? 5 marked for identification.) 5 A Mr. Lawch was fully aware that I was 6 MR. DANIELS: Before we -- did 6 capable of doing the business that Fannie Mae 7 you get an answer on the tax returns? Did you -- 7 wanted to do, using the insurance concept that I 8 MS. BECKER: Let -- let's cover 8 had developed. He was fully aware that I had left 9 it -- when -- before we get to the tax returns. 9 Fannie Mae in order to pursue the insurance 10 MR. DANIELS: Okay. 10 business, with respect to MCRI, and therefore when 11 BY MS. BECKER: 11 I approached him and he said that he had hired a, 12 Q Do you recognize that document? 12 quote/unquote, international broker, I knew that 13 A Yes. 13 what he was saying was that he was looking at 14 Q What is it? 14 someone other than me for doing that business, and 15 A Plaintiff's Answers to Defendants' 15 I knew that the person was Craig Ott, who is a 16 Interrogatories in the case of Marialice Bathrus 16 white man, and I am a black woman. And I know that 17 Williams versus Fannie Mae, et al. 17 I knew much more than Craig Ott will ever know 18 Q Did you prepare these interrogatory 18 about anything related to Fannie Mae or ins -- or 19 responses? 19 the MCRI business, and therefore I knew that that 20 A With my attorney. Attorneys. 20 was a discriminatory remark. That he was selecting 21 Q Are these interrogatory responses 21 a white man with no experience or knowledge over 22 accurate? 22 me, a black person, to do the aggregation business. 18 (Pages 197 to 200) Esquire Deposition Services MD - 1-800-539-6398 D.C. - 1-800-441-3376 VA - 1-800-752-8979 a77cbcf5-7ff0-478d-a5f4-3a9a93751c41 Case 1:05-cv-01483-JDB Document 33-8 Filed 06/21/2007 Page 20 of 74 Marialice Williams Page 201 Page 203 1 Q How many insurance deals did you do 1 was asked to write this letter was that Fannie Mae 2 while you were at Fannie Mae? 2 was continuing to do business with Cam Financial, 3 A I closed the very first deal at Fannie 3 not just old business, but new business with Cam 4 Mae, was working on a second one when I left. I 4 Financial. And it's business that they could have 5 closed my deal with Metropolitan just before I left 5 done with me, which I did not know then. I thought 6 Fannie Mae. 6 Fannie Mae was asking me to write this letter to 7 Q So you closed one deal while you were at 7 say that I was not in business with Bob Jones in 8 Fannie Mae? 8 order to -- because they were concerned that Bob 9 A One deal using MCRI, while I was at 9 would get business through me, when in reality Bob 10 Fannie Mae, yes. 10 was already getting business through Fannie Mae 11 Q When did you start working on that deal? 11 that I was not included in. 12 A Three years before it closed, and I left 12 Q How does that demonstrate that Fannie 13 in '98, so it was probably be -- about '95, '94, 13 Mae tortiously interfered with your relationship 14 maybe even '93. 14 with Cam? 15 Q When did you first become a mortgage 15 A Well, if they're telling me I'm can't -- 16 broker? 16 I'm not to do business with Cam, they're giving me 17 A I'm not a mortgage broker. 17 the impression that Cam is undesirable and someone 18 Q When did you first get your insurance 18 with whom they would not want to do business, when 19 broker's license? 19 in reality they were doing business with Cam, 20 A The summer after I left Fannie Mae. I 20 business that at that point I would be completely 21 believe it was around August of 1998. 21 excluded from because the relationship was between 22 Q Do you still have that license? 22 Cam and Fannie Mae. Page 202 Page 204 1 A No, I don't. 1 Q How did that affect your relationship 2 Q When did the license expire? 2 with Cam? 3 A I think it was about two years ago. 3 A It meant that I could not do business 4 Q So that would've been 2005? 4 with Cam if I wanted to continue to work with 5 A I believe it was 2005. I'm not 5 Fannie Mae, which turned out to be a joke anyway, 6 absolutely certain. 6 since Fannie Mae never did anything with me. It 7 Q How many insurance transactions have you 7 was just one more stalling technique, one more 8 brokered since you left Fannie Mae? 8 tactic that Richard and his crew designed to 9 A None. 9 exclude me from the business that I had created, 10 Q I'd like to turn your attention to 10 which is one more obfuscation of the real point, 11 interrogatory number two and your answer. 11 which was we're not going to do this business with 12 I'd like to ask you to refer to what was 12 Marialice; we are just going to lead her on. And, 13 previously marked as Exhibit 2, which I believe the 13 oh, today we'll get her -- to write a letter that 14 court reporter has. 14 she doesn't work with Cam. Oh, tomorrow we'll ask 15 A This says Exhibit 1. 15 her some -- to do something else. 16 Q If you turn to Exhibit 2. Is Exhibit 2 16 And that's the way it went. On and on 17 the letter that you're referring to in your answer 17 and on 'til I was broke. And no business. And you 18 to interrogatory number two? 18 can look in my tax returns and see that I relied on 19 A Yes. 19 them, that I spent my entire settlement trying to 20 Q How does this -- how does Exhibit 2 20 do this business with Fannie Mae. 21 support your tortious interference claim? 21 Q Does Exhibit 2 accurately describe your 22 A What I did not know at the time that I 22 relationship with Cam? 19 (Pages 201 to 204) Esquire Deposition Services MD - 1-800-539-6398 D.C. - 1-800-441-3376 VA - 1-800-752-8979 a77cbcf5-7ff0-478d-a5f4-3a9a93751c41 Case 1:05-cv-01483-JDB Document 33-8 Filed 06/21/2007 Page 21 of 74 Marialice Williams Page 205 Page 207 1 A Yes, it does. At that point. 1 don't know how much of it -- I don't know how much 2 Q I'd like to ask you to look at 2 went to Craig Ott. I just don't know. 3 interrogatory number three. And in particular, 3 I guess we could go to Bond Buyer and 4 your response on Page 3. Are you calculating your 4 find out, find out how many aggregation pools. 5 damages at $22 million? 5 Q I'd like you to look at your answer to 6 A No. That's -- I didn't ask for 6 interrogatory number seven. 7 $22 million. I believe I asked for more than that. 7 A Mm-hmm. 8 That was just on the DUS program. After I read all 8 Q Was your co-brokerage agreement with Cam 9 the documents that Fannie Mae provided, you know, 9 Financial ever reduced to writing? 10 it turned out that they did a great deal of 10 A Ever? 11 business other than DUS business. They did not do 11 Q Reduced to writing? 12 the DUS business; they did other business with 12 A I believe we did have a one-pager that 13 insurance. And I believe when I get the answers 13 said simply exactly what was in here. We'll just 14 from Fannie Mae I'll know how much that is, and it 14 split the insurance if we do a deal together. 15 certainly is a lot more than 22 million. 15 Q Did you produce that one-pager? 16 Q So your understanding is that Fannie Mae 16 A I -- I don't remember. I think I did. 17 did not do DUS business; is that correct? 17 Yes, yes, I did produce I think a number of 18 A My understanding is that they didn't. 18 iterations of it, and I think I produced it in the 19 But I wouldn't know. They never told me the truth 19 document request from Fannie Mae. 20 about anything. 20 And I believe it's the same thing I 21 Q I'd like to ask you to look at 21 described in here, in this other Exhibit 2 over 22 interrogatory number five. Do you stand by that 22 here. Page 206 Page 208 1 answer or -- or do you wish to amend your response 1 Q You're referring to Exhibit 2? 2 in any way? 2 A Yes. 3 A I believe that that is an accurate 3 Q We've been unable to locate a written 4 response because I don't know how much business 4 document that would be a co-brokerage agreement 5 Fannie Mae gave -- gave to Craig Ott precisely. I 5 between you and Cam in your discovery responses. 6 don't know how much business they gave to Bob 6 Would you be willing to allow your attorneys to 7 Jones. I don't know the complete answer to that. 7 direct us to the production number of the document 8 All I know is there's an aggregation 8 that you're referring to? 9 product on the market. It is anonymous as to who 9 A I believe the last -- my last deposition 10 the broker may have been on the deals, and 10 you gave me as an exhibit a co-brokerage agreement 11 therefore I cannot say how much business was given 11 between Cam and myself. You handed it to me and 12 to Craig Ott, but Fannie Mae certainly knows how 12 marked it as an exhibit. 13 much they gave to Craig Ott, and they certainly 13 Q Can you identify it? 14 know how much they gave to Bob Jones. And in the 14 MR. DANIELS: You think it was 15 information that was given to me or, excuse me, 15 Bob Jones's deposition that that happened? 16 that Mr. Daniels and Mr. Lederer's law clerk gave 16 THE WITNESS: No, it was the 17 to them regard -- from -- that was taken from the 17 last time I was here. 18 Bob Jones/Cam Financial case, there were certain 18 MR. DANIELS: Okay. 19 indications as to how much business Fannie Mae was 19 THE WITNESS: There was a 20 doing in both aggregation and on the regular MCRI 20 document that someone handed me. It was -- and 21 business, and it -- indications were that it was 21 said -- 22 a -- a very substantial amount of money. And I 22 MR. DANIELS: I think the 20 (Pages 205 to 208) Esquire Deposition Services MD - 1-800-539-6398 D.C. - 1-800-441-3376 VA - 1-800-752-8979 a77cbcf5-7ff0-478d-a5f4-3a9a93751c41 Case 1:05-cv-01483-JDB Document 33-8 Filed 06/21/2007 Page 22 of 74 Marialice Williams Page 209 Page 211 1 question was whether -- 1 A No, if -- if it's not here then -- and I 2 BY MS. BECKER: 2 didn't give it to you in the other -- then -- then 3 Q I'm sorry. Ms. Williams, can you review 3 maybe it's not. Maybe it's lost. But I thought 4 the exhibits from your -- the previous day of your 4 there was one signed and I thought we had given it 5 deposition and see if you can identify that 5 to you. But I could be mistaken. 6 document? 6 And by that time Bob was giving me the 7 A Those are here? 7 runaround just like Fannie Mae was 'cause they were 8 Q Yes. 8 all lying and stealing and not paying me anything, 9 A Well, here's one right here at 9 and I had created the whole thing. So I guess 10 Exhibit 4, unsigned. And then here's one I think 10 maybe we didn't sign one in final. It's all just a 11 that Harvey mailed to them, that's exhibit -- 11 big runaround. I was the only one that took it 12 excuse me, it's Page 10546 to Danny Groves from 12 seriously. 13 Harvey Hartsfield. These were -- and that's 13 Q Are you able to identify the exact terms 14 January 14th, 2002. And that's -- you know, we 14 of the co-brokerage agreement that you allegedly 15 kept trying to go at it to try and get something 15 had with Cam? 16 that we could all agree with. 16 A In Exhibit 2 I have described it, and I 17 And let's see, there's another one here 17 don't think there's any better description. I've 18 at 10548/49. That one's unsigned as well. I 18 also shown you in Exhibit 3 and 4 that there were 19 thought we had a one -- perhaps we never did sign 19 several instances, and I told you that the 20 a -- a final one, but I -- I thought we had. 20 agreement is pretty much exactly what Exhibit 4 21 Perhaps I'm mistaken. 21 says: That if we do any business together, there 22 MR. DANIELS: What was the 22 will be a 50/50 split between the two of us. And Page 210 Page 212 1 question that was on the table, please. Could you 1 that was pretty much the extent of the agreement. 2 go back? 2 And you could have that agreement with 3 MADAM REPORTER: Sure. The 3 any broker, anywhere, any day of the week, any 4 original question? 4 time. It's just a very simple, plain, clear 50/50 5 MR. DANIELS: Yes. The one 5 split on commissions. 6 that -- 6 Q So in the event that you did a deal with 7 (The reporter read the record as requested.) 7 Fannie Mae, the co-brokerage agreement meant that 8 MR. DANIELS: And the answer. 8 you would have to split any proceeds with Cam 9 THE WITNESS: The -- 9 50/50? 10 (The reporter read the record as requested.) 10 A If I did what? 11 THE WITNESS: And that's pretty 11 MS. BECKER: Can you read back 12 much what these agreements say, with some other 12 the question. 13 language. But I -- if there was a signed one and 13 (The reporter read the record as requested.) 14 it's not in here, then it's probably that I can't 14 THE WITNESS: Not necessarily. 15 locate the signed copy. I thought we did actually 15 Depended on who the insurance company was. If it 16 have a signed agreement. Because as late as 2002, 16 was an insurance company that I had an exclusive 17 Bob Jones and I went to Baltimore to meet with a -- 17 arrangement with, no, I wouldn't have to split 18 a major rated insurance company to talk more about 18 anything with Bob. If Bob located the insurance 19 both MCRI as well as captive insurance/reinsurance. 19 company, certainly I would have to split that with 20 BY MS. BECKER: 20 him, and that's -- it's just a standard kind of a 21 Q Do you have any evidence of a signed 21 co-brokerage agreement, which I explained in here 22 co-brokerage agreement between you and Cam? 22 to Fannie Mae: It's just a plain co-brokerage 21 (Pages 209 to 212) Esquire Deposition Services MD - 1-800-539-6398 D.C. - 1-800-441-3376 VA - 1-800-752-8979 a77cbcf5-7ff0-478d-a5f4-3a9a93751c41 Case 1:05-cv-01483-JDB Document 33-8 Filed 06/21/2007 Page 23 of 74 Marialice Williams Page 213 Page 215 1 agreement. 1 years, spending every dime I had doing product 2 You could sometimes in the insurance 2 development, in order to see that Fannie Mae 3 business split commission with somebody you never 3 adhered to its chartered obligation by doing 4 seen or heard of in your entire life. It'd just 4 affordable housing loans, which was what my whole 5 depend on who -- would depend on who was the 5 point was of my whole program. But they weren't 6 procurer of the actual insurance itself. 6 particularly interested in doing that business 7 BY MS. BECKER: 7 anyway. 8 Q In what way did Fannie Mae interfere 8 So that's where I am on this. You 9 with your co-brokerage agreement with Cam? 9 can -- I'm sure you can imagine my frustration. I 10 A Fannie Mae interfered with my 10 don't understand it any more than you do. I don't 11 relationship with Cam Financial by saying that they 11 understand why they had me write the letter. I 12 sen -- essentially did not want me doing business 12 don't understand why Bob Jones lied. I don't 13 with them. That is why I was asked to write this 13 understand why Fannie Mae lied about what they were 14 letter, which I wrote, which is in here, which 14 doing. I don't understand it either. I just know 15 basically says to Cam Financial, you know, Fannie 15 that I'm the one that wound up being hurt and 16 Mae doesn't want you doing business with Cam 16 having no money and no business. 17 Financial. 17 Q So fundamentally your claim related to 18 And for two people who had been working 18 the co-brokerage agreement is that Fannie Mae 19 together for five years, it was a little bit 19 didn't do any business with you; is that fair to 20 strange to have somebody come out of left field and 20 say? 21 ask you to write that kind of letter. I don't know 21 A That's right. 22 what their motivation was. But it certainly did 22 Q I'd like to ask you to look at your Page 214 Page 216 1 destroy what -- whatever relationship I had with 1 answer to interrogatory number nine. 2 Cam at that point, because obviously Fannie Mae -- 2 VIDEOGRAPHER: Excuse me, 3 and then Fannie Mae wasn't even being truthful then 3 Ms. Becker, but we are about to run out of tape. 4 because they weren't going to give me any business 4 This is the end of videotape number one 5 whether I was doing it with Bob or not. But I did 5 of the testimony of Marialice Bathrus Williams, May 6 not know that at the time, and I also did not know 6 7th, 2007. Off the record at 1:45:40. 7 they were still doing business with Bob, which is 7 (Discussion held off the record.) 8 why it doesn't all make sense at all. 8 VIDEOGRAPHER: This is the 9 So you wonder what kind of subterfuge or 9 videotape tape number two, Volume II, of the 10 crap they are handing you when you -- you know, 10 testimony of Marialice Bathrus Williams, May 7th, 11 you're told to do one thing and then you discover 11 2007. On the record at 1:50:54. 12 later on, well, they told you not to do business 12 BY MS. BECKER: 13 with them, but then they weren't doing business 13 Q I'd like to ask you to look at your 14 with you, but then they were doing business with 14 answer to interrogatory number nine. What phone 15 him. And -- so was it that they didn't want you to 15 conversations between you and Bob Jones are you 16 do business with him 'cause you'd get part of what 16 referring to? 17 they're getting. Or did they not want Bob to get 17 A Conversations with Bob Jones regarding 18 something you might get. Well, obviously that 18 business he was doing with Fannie Mae that I was 19 wasn't true because they weren't giving you 19 not aware of. And he indicated in one of those 20 anything. 20 conversations that, you know, he evidently had the 21 So, you know, it was -- it was me 21 same kind of discussion with Fannie Mae that I had 22 spinning around like a whirling dervish for several 22 about not doing business with him, but for some 22 (Pages 213 to 216) Esquire Deposition Services MD - 1-800-539-6398 D.C. - 1-800-441-3376 VA - 1-800-752-8979 a77cbcf5-7ff0-478d-a5f4-3a9a93751c41 Case 1:05-cv-01483-JDB Document 33-8 Filed 06/21/2007 Page 24 of 74 Marialice Williams Page 217 Page 219 1 reason he was still getting business, and I was 1 they were trying to convince insurers or reinsurers 2 not. 2 to participate in this particular type of insurance 3 Q What did he tell you that led you to 3 program. And likewise, if -- if there was 4 believe that Fannie Mae was discouraging Cam 4 something that I needed on the insurance side, 5 Financial from doing business with you? 5 the -- one of the consultants that we worked with 6 A He said, I don't think Fannie Mae wants 6 on the -- in -- on the captive insurance was a 7 to do business with you. 7 personal friend of Cam Financial, so we started 8 Q Did he say that Fannie Mae was 8 using Cam Financial in order to access this 9 discouraging Cam from doing business with you? 9 particular individual. It was prior to the time 10 A Yes. 10 that we started working with Kate Westover. 11 Q What did he say in that regard? 11 BY MS. BECKER: 12 A Cam didn't want Fannie -- him to do 12 Q Do you remember when your conversation 13 business with me. 13 with Bob Jones took place? 14 Q I'm sorry, can you repeat that? 14 A I can't remember the exact dates, but it 15 A Fannie -- Fannie Mae did not want Cam 15 was 2002/2003. Late into the game, after we 16 Financial to do business with me. 16 were -- late into the game, 2002/2003. 17 Q What specifically did he say about that? 17 Q How do you recall that? 18 A Fannie Mae did not want Cam Financial to 18 A Because it didn't -- I didn't know 19 do business with me. 19 really until that time that -- well, really 20 Q What business were you doing with Cam 20 honestly, 2005/2006, and 2006 I really learned the 21 Financial at that time? 21 extent of Cam's relationship with Fannie Mae. And 22 A I -- I think we've gone through this 22 I repeated to Mr. Jones that I was just absolutely Page 218 Page 220 1 whole litany of things that I tried to do with Cam 1 shocked at the amount of business that they had 2 Financial and Fannie Mae and then I was asked not 2 done with Fannie Mae, at which time he reiterated 3 to do business with Cam Financial, Cam Financial 3 that, well, you know, Fannie Mae just didn't want 4 was asked not to do business with me. I still had 4 to do business with you, didn't want us to do 5 to continue to try to do business. I -- I mean I'm 5 business with you. 6 not sure of what answer you want or are looking for 6 Q You said that he reiterated that? 7 because I can't remember what your question was, 7 A Mm-hmm. 8 really. 8 Q That's Mr. Jones? 9 MS. BECKER: Can you read back 9 A Mr. Jones, yes. 10 the question. 10 Q And when is the first time that he said 11 (The reporter read the record as requested.) 11 that? 12 THE WITNESS: I was -- Cam 12 A We had the discussions initially when I 13 Financial and I were visiting various insurance 13 received the e -- e-mail from Betty Dance in 2001 14 companies together, depending upon who had the 14 about the DUS proposal. But we had so many other 15 contact. It was often that I had the knowledge. 15 things on the table, of course, I just assumed that 16 It was known that I had the knowledge of the 16 that was only about the DUS proposal and that 17 secondary market and that I had the knowledge of 17 perhaps Fannie Mae still was sincere since it did 18 the processes and functions at Fannie Mae and was 18 in fact meet with me and have lunch with me after 19 familiar with the process that one goes through in 19 that time about doing some other business other 20 order to do securitization at Fannie Mae. 20 than the DUS business. Or the -- I mean I -- I 21 Therefore, it was important to Fam -- to Cam in 21 forgot the question. 22 many instances that I be present at meetings where 22 (The reporter read the record as requested.) 23 (Pages 217 to 220) Esquire Deposition Services MD - 1-800-539-6398 D.C. - 1-800-441-3376 VA - 1-800-752-8979 a77cbcf5-7ff0-478d-a5f4-3a9a93751c41 Case 1:05-cv-01483-JDB Document 33-8 Filed 06/21/2007 Page 25 of 74 Marialice Williams Page 221 Page 223 1 THE WITNESS: Right. The first 1 Q Do you know what any of these unpleasant 2 time was right after the receipt of the e-mail from 2 or terrible things were? 3 Betty Dance, indicating that Grace Huebscher was 3 A That I was stupid, that I didn't know 4 going to use Craig Ott rather than me for her 4 anything about the business. Et cetera. 5 aggregation program. 5 Q What other statements other than that 6 MR. DANIELS: Is there a 6 you were stupid and that you didn't know the 7 question pending? Where are we? 7 business? 8 MS. BECKER: No. I'm waiting 8 A I don't know. I think people sometimes 9 for an exhibit. 9 don't like to tell you the specific words, but he 10 MR. DANIELS: Do you need a 10 told me Fannie Mae said some pretty terrible things 11 break to get this together? 11 about you. I don't think I'd tell Bob Jones, for 12 MS. BECKER: It'll just be a 12 example, that Richard called him a redneck -- no, I 13 second. 13 think I did tell him that. But that's, you know, 14 MR. DANIELS: Is it something we 14 that's the way Richard Lawch is. 15 can come back to? I have never seen anything -- 15 If you know him as a person he -- he 16 huh? 16 makes cutting and sarcastic and cynical and 17 BY MS. BECKER: 17 defamatory and false statements about lots of 18 Q I'd like to turn your attention to your 18 people. But he particularly says them about people 19 answer to interrogatory number ten. 19 that he doesn't like, like me. 20 MR. DANIELS: Thank you. 20 Q Is it accurate that you don't recall the 21 BY MS. BECKER: 21 dates of these conversations? 22 Q What false and defamatory information 22 A I don't recall the dates, no. Page 222 Page 224 1 was communicated to Cam about you? 1 Q Turning your attention to interrogatory 2 A I had several conversations with Bob 2 number 11, do you know when the co-brokerage 3 Jones where I was told of negative and defamatory 3 agreement with Cam that you allege existed expired? 4 things that were said about me. Did he tell me 4 A No, I really don't know. I don't recall 5 what they were precisely? No. But we know they 5 when it expired. I'm not sure if it had a term in 6 were said. He knows they were said. Richard Lawch 6 here. Let's see. Does this say? 7 knows they were said. You have to ask them. 7 This doesn't say so I don't know. 8 Q Is it fair to say you don't know what 8 Well, it certainly had to expire when I 9 was said? 9 was no longer a broker. I haven't been a broker 10 A I know it was false and defamatory. 10 for two years. I don't believe it's -- I think 11 Q How do you know that? 11 it's been two years now. 12 A Because I was told that it was. 12 Q Turning your attention to interrogatory 13 Q Did Mr. Jones use the words "false" and 13 number 13. Can you explain to me how you calculate 14 "defamatory"? 14 your damages in this case? 15 A Maybe not the words false and 15 A The losses were calculated based upon 16 defamatory, but he certainly said unpleasant and 16 the amount of potential business that Fannie Mae 17 terrible things were said about me to Washington 17 did using structures developed by me. Generally 18 Mortgage and, let's see, in one instance I know of 18 speaking, the fees ranged about 25 basis points 19 specifically, and to Red Mortgage Capital. And 19 annually for the insurance. In some instances the 20 there was just a lot of negative things that 20 fees were as high as 56 basis points. And the 21 Richard would say about me to various people, Bob 21 broker's fee is approximately 10 percent of the 22 Jones being one of them. 22 premium fee. 24 (Pages 221 to 224) Esquire Deposition Services MD - 1-800-539-6398 D.C. - 1-800-441-3376 VA - 1-800-752-8979 a77cbcf5-7ff0-478d-a5f4-3a9a93751c41 Case 1:05-cv-01483-JDB Document 33-8 Filed 06/21/2007 Page 26 of 74 Marialice Williams Page 225 Page 227 1 Annual reports from Fannie Mae reflect 1 me, which would be 50 percent of the 10 percent of 2 about $2 billion of MBS, one-off transactions which 2 the actual fee charged. And then I don't have any 3 were closed andually -- an -- annually, 3 idea how much the aggregation program did, and I 4 substantially more MBS were issued with the DUS 4 don't know if that's the extent of it. As I said, 5 portfolio. I would have no way of knowing exactly 5 here again, because I don't know how much the DUS 6 what the credit enhancement arrangements were for 6 portfolio was credit enhanced with any kind of 7 all those transactions and the extent to which the 7 insurance project -- product. So -- 8 insurance was used, but Fannie Mae would know all 8 Q So is the 5.1 million that you're 9 of that including how much was closed under the 9 alleging, does that have anything to do with DUS 10 aggregation program, how much was closed under the 10 deals? 11 one-off transaction specifically. Only Fannie Mae 11 A No, I don't know how much the DUS deals 12 would be able to answer that. 12 were. This was only one small part that was 13 However, in looking at the documents 13 recorded, said 2 billion -- annual reports from 14 that were filed in the court in Mississippi, it was 14 Fannie Mae reflect that 2 billion -- that's just 15 pretty apparent that several hundred million 15 for one year. So let's see, '98, '99, '2000, '1, 16 dollars, more than a billion, actually, I think, of 16 '2, '3, '4, '5. When did I file in '5? So that's 17 business was done with using some form of the 17 seven times five, that's 35 million right there 18 insurance concept, all of which were knockoffs of 18 without me knowing the balance of what else 19 the concept that I developed, and all of the 19 would've been there. 20 relationships were those which I brought to Fannie 20 Q And that amount that you're identifying 21 Mae with Bob under signed confidentiality 21 is unrelated to DUS deals; is that correct? 22 agreements. So it would be fairly simple I guess 22 A Right. I didn't leave there just to do Page 226 Page 228 1 for Fannie Mae to track that. 1 DUS deals. I left there to do MCRI. MCRI could've 2 But the only tracking I could do was 2 been used on the equity program, could've been used 3 through, as I said, looking at their annual reports 3 on aggregation, affordable housing, DUS, the 4 to see how much they did, and then looking at Bob 4 standard one-off negotiated transactions, the DUS 5 Jones's account when he was assessing his 5 securitization transactions as well. I don't -- I 6 calculations for damages in his case. And that 6 don't know how much they did on that. 7 information you have as well. 7 I can only tell you based on what was in 8 Q Based on the calculations that you have 8 this particular thing and what's in Bob's notes 9 done, using the annual reports and information 9 that we're talking about at least 35 million for 10 relating to Bob Jones, how do you calculate your 10 those few years. 11 damages in this case? 11 Q Have you calculated any damages relating 12 A Ten percent of the premium fee that was 12 to DUS deals? 13 charged for the insurance would be what the insurer 13 A I don't know that any DUS deals were 14 would receive minus -- oh, no, 10 percent was the 14 done, but we know what the fees would've been, yes. 15 premium. So if I was entitled to 50 percent of 15 And the only reason Fan -- and Fannie Mae didn't do 16 that, then we're looking at, let's see -- I can 16 the DUS deals because she didn't feel like it, not 17 tell you real fast what that would be. It would 17 that it wasn't needed in the marketplace and 18 be -- well, I can only tell you what it would be on 18 wouldn't have opened it up to other people. She 19 the 2 billion -- 112, 1.2, 12, 11.2. It would be 19 just decided whether or not -- I don't know whether 20 5.1 million in actual fees that would be derived 20 she decided to do it or not. It had to do with 21 from that particular package. 21 accounting for its own customers, but, you know, 22 I believe that's what it would be for 22 Fannie Mae does what it wants to do. And she 25 (Pages 225 to 228) Esquire Deposition Services MD - 1-800-539-6398 D.C. - 1-800-441-3376 VA - 1-800-752-8979 a77cbcf5-7ff0-478d-a5f4-3a9a93751c41 Case 1:05-cv-01483-JDB Document 33-8 Filed 06/21/2007 Page 27 of 74 Marialice Williams Page 229 Page 231 1 wouldn't even permit as -- and as long as I knew, 1 mean I had extraordinary expenses, living expenses. 2 she wouldn't even permit her own people to use it. 2 Q Do you have any documents reflecting the 3 So I don't know who that was hurting except the 3 rent that you paid to the Watergate on the business 4 American public. 4 offices? 5 Remember, the proposal for the meeting, 5 A Yes, it's on my tax return. And I have 6 the captive concept, that was not necessarily to be 6 a lease. 7 used for dusk -- DUS people. That was to be used 7 Q Did you produce that lease? 8 in their standard program, securitization program, 8 A I don't know whether I did or not. I 9 and then negotiated transactions program. Or 9 don't know if I could find it. I don't think it 10 one-off deals is what they called them. 10 would be too difficult to find it or to have an 11 Q I'd like to turn your attention to your 11 affidavit done by Gigi Winston and her father who 12 answer to interrogatory number 14. You've 12 rented the -- found the space for me and rented it 13 identified certain expenses in response to this 13 to me and all the people that came to visit me 14 interrogatory. Can you tell me how you calculate 14 there. I don't think it was any secret that I 15 rent at $1,450 a month? 15 actually rented the apartment, so I don't think 16 A That's what my lease was. 16 there would be any problem getting documentation to 17 Q This was your lease at the Watergate? 17 prove that I actually had a space there. And the 18 A Watergate. 18 fact that Harvey Hartsfield and Rob Robinson worked 19 Q Was that the lease on your personal 19 there on a daily basis, so. 20 apartment or on your business -- 20 And Bob Johns -- Jones came to visit 21 A No, I had an office. It had three 21 there, and people from Fannie Mae came to visit 22 offices. It had an office for someone who came in 22 there, Washington Mortgage came there, Red Mortgage Page 230 Page 232 1 occasionally and did secretarial work. It had an 1 Capital came there, Chris Tawa came there. I mean 2 office for first Rob Robinson and then Harvey 2 it's -- you know, obviously I was there. 3 Hartsfield. And then I had my own office and then 3 Q Was that office the headquarters for 4 the outer office was a conference area. And it was 4 RMS? 5 a unit number 701 in the Watergate office building 5 A It was the headquarters for Marialice 6 itself. 6 Williams & Associates; it was the headquarters for 7 My apartment was in the south building 7 RMS, LLC and the headquarters for RMS without the 8 at the Watergate. And although I did use a portion 8 LLC. 9 of my apartment for my -- for office, I did not -- 9 Q How did you calculate phone and office 10 I worked every day in my office in the Watergate 10 equipment at $1,000 a month? 11 office building. 11 A That's what it cost. I just went to the 12 And that does not include what I had to 12 bills. I had three telephone lines since there 13 pay in order to make the office suitable for use. 13 were three people in the office. I had fax 14 I had it reconfigured slightly, to the tune of 14 machines, copiers; I had everything that you would 15 quite a few thousand dollars. And it also doesn't 15 have in a typical office. And the -- and the 16 reflect that, you know, I had to live during that 16 commercial phone lines and -- and the cell phones' 17 period, and I basically lived off of my money that 17 cost, I'm sure that's not even -- that's probably a 18 I got from Fannie Mae at retirement and a $200,000 18 gross understatement of what it cost. 19 loan I took out on my apartment with Bank of 19 Q Do you still have those bills? 20 America that had to be paid off when I did my 20 A No, but I have a tax return and the 21 apartment -- you know, when I left my apartment. I 21 backup documentation, yes. I think one year I had 22 mean when I paid off my -- sold my apartment. So I 22 $140,000 -- she has my tax re -- you have my tax 26 (Pages 229 to 232) Esquire Deposition Services MD - 1-800-539-6398 D.C. - 1-800-441-3376 VA - 1-800-752-8979 a77cbcf5-7ff0-478d-a5f4-3a9a93751c41 Case 1:05-cv-01483-JDB Document 33-8 Filed 06/21/2007 Page 28 of 74 Marialice Williams Page 233 Page 235 1 returns, just look at them and you can see how much 1 Q How long did you have an office 2 it cost me. 2 assistant? 3 Q My question is do you have the bills 3 A That's really not quite accurate in 4 that reflect -- 4 terms of "office assistant." It's really a person 5 A Of course I have them. I had to prepare 5 who was working as a consultant, doing a lot of the 6 my tax returns; therefore, I have all my backup 6 marketing work and so forth with me; and I had them 7 documentation and it's all on my tax returns. 7 from the day I started until the day I left the 8 Q So you do have those bills? 8 Watergate and even really beyond that time, I 9 A Yes. 9 believe. 10 Q How did you calculate 15,000 -- I'm 10 Q Who is this individual? 11 sorry, 1500 a month in travel costs? 11 A There were two different individuals; 12 A By the expenses that I used to travel 12 one is Rob Robinson, Robert Robinson, was the first 13 to -- I mean the same way you have phone and 13 person. I paid him two grand a month. And the 14 office -- yes, I have those receipts as well. 14 second person was Harvey Hartsfield, who was paid 15 Q Did you have expense reports that you 15 $3,000 a month. We went on all of our -- we went 16 prepared for these trips or did you simply keep 16 on all of our business calls together and business 17 receipts somewhere? 17 trips, conferences. 18 A I just kept receipts. I was just an 18 MR. DANIELS: Marialice, do you 19 individual. 19 have to put more quarters in the -- 20 Q And where did you keep these receipts? 20 THE WITNESS: Yeah, in about 20 21 A Oh, Jesus. In a file. 21 minutes. 22 Q Do you still have that file? 22 BY MS. BECKER: Page 234 Page 236 1 A Yes, I did my tax returns and I have my 1 Q What was the time frame in which 2 backup documentation. 2 Mr. Robinson worked for you? 3 Q When did these travel expenses start? 3 A From -- I believe it was from 1998 until 4 A The day I left Fannie Mae. 4 19 -- until 2000, I think, almost 2000. 5 Q And they were consistently 1500 a month 5 Q What was the time frame during which -- 6 every month? 6 A The balance of the time from about 1999 7 A That was an average. In a -- in a 7 or 2000 through till 2002, '3, something like that, 8 typical month, I would go to New York two or three 8 because he was still working with me when I moved 9 times to meet with Marsh Mac. I would go to 9 out of the Watergate and moved to 5722 First 10 Dallas, Texas to meet with Lend Lease. I would go 10 Street. 11 to California to meet with Countrywide Mortgage. 11 Q Just so that the record is clear, we're 12 These were not inexpensive travel trips at all. 12 talking about Harvey Hartsfield here? 13 Q Did you calculate this based on an 13 A Correct. 14 average or did you look at the actual receipts and 14 Q And what were the dates he was employed 15 add them up? 15 with you? 16 A I prepared my tax returns from actual 16 A I don't recall the exact dates. 17 receipts. When this question was responded to, I'm 17 Q What's your best estimate? 18 certain I gave an average number. I could have 18 A He started when Rob Robinson stopped and 19 given an exact number on all of these things. And 19 then he stopped in 2003, I believe it was. And 20 I believe you will see the exact numbers on my tax 20 we're still working together. 21 returns that are backed up by large manila 21 Q When did you stop paying him 3,000 a 22 envelopes filled with receipts. 22 month? 27 (Pages 233 to 236) Esquire Deposition Services MD - 1-800-539-6398 D.C. - 1-800-441-3376 VA - 1-800-752-8979 a77cbcf5-7ff0-478d-a5f4-3a9a93751c41 Case 1:05-cv-01483-JDB Document 33-8 Filed 06/21/2007 Page 29 of 74 Marialice Williams Page 237 Page 239 1 A I don't recall. 1 Mississippi and got the records and does certain 2 Q Do you have any records that would 2 legal research at Mr. Daniels' and Mr. Lederer's 3 indicate that? 3 direction. 4 A I'm sure that the exact amount would be 4 Q Has he ever represented you? 5 on my tax returns and that's how we could estimate 5 A No. 6 when it would've been. Mr. Hartsfield and I are 6 Q Who else represents you in this 7 still working together. I do not pay him myself; 7 litigation -- or who does represent you in this 8 we're paid out of other funds from a contractor. 8 litigation? 9 MS. BECKER: Do you want to take 9 A Michael Beasley, Brian Lederer, and 10 a short break so you can go put money in the meter? 10 Harley Daniels. 11 THE WITNESS: Mm-hmm. 11 Q Did you also have a personal 12 MS. BECKER: Okay. 12 relationship with Mr. Daniels? 13 VIDEOGRAPHER: Off the record at 13 A I was married to Mr. Daniels from 1980 14 2:22:54. 14 to 1990. 15 (Thereupon, a recess was taken.) 15 Q So you were married to Mr. Daniels when 16 VIDEOGRAPHER: On the record at 16 you were working at Fannie Mae; is that correct? 17 2:40. 17 A Yes, for part of the time, yes. 18 BY MS. BECKER: 18 Q Did you ever discuss with Mr. Daniels 19 Q Ms. Williams, directing your attention 19 your working relationship with Richard Lawch? 20 to your response to interrogatory number 15, who is 20 A Absolutely. 21 Conway Downing? 21 Q What did you tell him about that 22 A Conway Downing is -- has been the sort 22 relationship? Page 238 Page 240 1 of law -- law clerk for this transaction with us, 1 A I told him Richard was the worst boss 2 works with Mr. Daniels and Mr. Lederer. And he -- 2 I've ever had and that he was a miserable son of a 3 I was married to him -- I'm marr -- still married 3 gun and that he did not like me and treated me 4 to him, although we've been separated for some 4 poorly and that I would -- that I was being taken 5 time, but we still have a number of business 5 advantage of, that I was being treated unfairly, 6 transactions together. And he worked in the office 6 et cetera. 7 at the Watergate, one of the three offices, over 7 Q Did you tell Mr. Daniels that you 8 the time that we were trying to do this business 8 believed that Mr. Lawch discriminated against you 9 with Fannie Mae. 9 on basis of your race? 10 And as recently as two weeks ago on 10 A Yes, I did. 11 Friday, I think I mentioned it to you in the last 11 Q Did Mr. Daniels provide you with any 12 part of the deposition, we have -- he's still 12 advice on how to deal with Fannie Mae? 13 arranging meetings with people to talk about 13 A No, not at that time. 14 potential business, with Fannie Mae, using a con -- 14 Q Did he provide you with any advice in 15 a -- another concept that's not mentioned in this 15 connection with your settlement agreement with 16 document. 16 Fannie Mae? 17 Q Is he a licensed attorney? 17 A I did discuss it with him to some extent 18 A In the state of Virginia. 18 but I -- Brian Lederer actually represented me. 19 Q Does he represent you in connection with 19 Q What was the nature of your discussions 20 this litigation? 20 with Mr. Daniels regarding your settlement 21 A No, doesn't represent me. He's serving 21 agreement? 22 as a clerk. He's the person that went to 22 A How unfair, how could they do this. All 28 (Pages 237 to 240) Esquire Deposition Services MD - 1-800-539-6398 D.C. - 1-800-441-3376 VA - 1-800-752-8979 a77cbcf5-7ff0-478d-a5f4-3a9a93751c41 Case 1:05-cv-01483-JDB Document 33-8 Filed 06/21/2007 Page 30 of 74 Marialice Williams Page 241 Page 243 1 those years I put in. All that money I made for 1 Q Does December 16, 2003 sound like the 2 them. How could they treat me like I'm just some 2 last date that you were deposed in connection with 3 piece of crap that's leaving there under pressure. 3 the Cam litigation? 4 I can't believe they're only paying me this and I 4 A It could've been. 5 made them all that money. 5 Q When in relation to that last deposition 6 Let's see, what else did I discuss with 6 did Mr. Williams first represent -- I'm sorry, did 7 him? Just general matters that -- that we 7 Mr. Daniels first represent you? 8 discussed -- that I discussed earlier. The 8 A When in relation to it? 9 unfairness, how awful Richard Lawch was. How he 9 Q Yes. 10 stepped in the middle of my negotiations and 10 A He went to that deposition with me. 11 probably caused Tom Nieds to treat me like crap, 11 Q Was that the first time that he 12 which he did. He was really nasty and crappy to 12 represented you in connection with Fannie Mae? 13 me. 13 A As far as I know. 14 Q What was Mr. Daniels' reaction to the 14 Q At the time that you were negotiating 15 situation? 15 your settlement agreement with Fannie Mae, what was 16 MR. DANIELS: I'm going to 16 Mr. Daniels reaction to the situation? 17 object to that. At that point we were no longer 17 A I don't know. 18 married, and I was speaking to her in the capacity 18 MR. DANIELS: Yeah, I'm -- I'm 19 as an attorney and I gave her advice at that time, 19 going to ask you not to answer that question. 20 so I ask her not to answer that question. 20 THE WITNESS: Okay. 21 BY MS. BECKER: 21 MR. DANIELS: It involves legal 22 Q What was the date of your divorce? 22 advice. Page 242 Page 244 1 A I don't remember. 1 MS. BECKER: On what basis? 2 MR. DANIELS: August 1993. 2 MR. DANIELS: Lawyer-client 3 BY MS. BECKER: 3 privilege. 4 Q When did Mr. Daniels first represent you 4 MS. BECKER: The witness has 5 in a legal capacity? 5 just testified that there was no attorney-client 6 A In 1987, in Hobbs, New Mexico, in a 6 relationship at that time. 7 matter involving an automobile that was defective. 7 MR. DANIELS: 1988? 8 Q When did Mr. Daniels first represent you 8 MR. LEDERER: 1998 -- 9 in connection with Fannie Mae? 9 MR. DANIELS: '98. I -- I still 10 A I don't recall the exact date. But it 10 invoke client -- attorney-client relationship. 11 would have been the same time I met with 11 THE WITNESS: You did 12 Mr. Lederer, Mr. Beasley, and Mr. Daniels at the 12 represent -- yes, right, I did seek his counsel 13 same time. And I believe it was before the 13 first. I -- I misspoke. He did represent me. 14 depositions were concluded because they attended 14 BY MS. BECKER: 15 the final deposition after the death of Julia 15 Q When did Mr. Daniels first represent you 16 Williams, my -- my attorney prior to that time. So 16 in connection with Fannie Mae? 17 at the last deposition in the Cam Financial matter, 17 A Prior to my departure. That's right. I 18 where I was deposed, Mr. -- all three of my counsel 18 do remember that now. 19 were present at that time. 19 MR. DANIELS: Mm-hmm. 20 Q What was the date of that last 20 BY MS. BECKER: 21 deposition? 21 Q Are you going to follow Mr. Daniels' 22 A I don't remember. 22 instruction and not answer my question? 29 (Pages 241 to 244) Esquire Deposition Services MD - 1-800-539-6398 D.C. - 1-800-441-3376 VA - 1-800-752-8979 a77cbcf5-7ff0-478d-a5f4-3a9a93751c41 Case 1:05-cv-01483-JDB Document 33-8 Filed 06/21/2007 Page 31 of 74 Marialice Williams Page 245 Page 247 1 A Right. 1 him and his predecessor, Larry Mirel, who's the 2 Q About Mr. Daniels? 2 former commissioner of the DC Department of 3 A No, I'm not going to answer the 3 Insurance, Securities and Banking. Met with him 4 question. 4 several times. They hired Kate Westover as our -- 5 Q If I could just finish my question, then 5 our representative to write the actual implementing 6 you can answer. Are you going to follow 6 regulations for the Department of Insurance, 7 Mr. Daniels' instruction and not answer the 7 Securities and Banking with respect to captive 8 question that I posed to you about Mr. Daniels' 8 insurance. 9 reaction to your settlement agreement with Fannie 9 Q Other than the individuals on the list 10 Mae? 10 that you've identified in response to interrogatory 11 A Are you going to -- I'm sorry. I'm 11 number 15, are there any other individuals who have 12 totally lost on the question. 12 information relating to your claims? 13 MR. DANIELS: I asked you not to 13 A I believe those were the persons that 14 answer the question. She wants to know whether 14 we -- that I was able to identify by going through 15 you're going to follow my advice. 15 the records that I sent to Fannie Mae in response 16 THE WITNESS: I'm not going to 16 to their request for interrogatories. There may 17 answer the question. 17 have been some others but these were the majority 18 BY MS. BECKER: 18 of the ones, I believe, that we sent to you as 19 Q If I were to ask you any other questions 19 response to your request for information. 20 about your communications with Mr. Daniels relating 20 Q Is there anybody else that you can think 21 to Fannie Mae, would you also decline to answer 21 of who has information relating to your claims? 22 those questions? 22 A Not -- not at this time, I cannot say Page 246 Page 248 1 A Yes, as far as him representing me, yes. 1 who else would have. 2 He would've been my counsel and I would -- right. 2 Q When did you file for bankruptcy? 3 That would be privileged. 3 A You know, I can't remember. I think it 4 Q Who's Jane Harrison? 4 was 2001 or 2002. 5 A She is a close associate of Bob Jones, 5 MS. BECKER: I'm going to ask 6 and she was with two or three different DUS lenders 6 the court reporter to mark this as Exhibit 14, I 7 while I knew her. 7 believe. 8 Q When is the last conversation that you 8 MADAM REPORTER: Thank you. 9 had with Ms. Harrison? 9 MS. BECKER: Mm-hmm. 10 A I don't remember. 10 (Deposition Exhibit No. 14 - Statement of 11 Q Can you give me a ballpark? 11 Financial Affairs from the United States 12 A No. 12 Bankruptcy Court, District of Columbia - was 13 Q Was it in the last two years? 13 marked for identification.) 14 A Maybe. 14 THE WITNESS: Boy, everybody 15 Q Was it in the last year? 15 messes up the spelling of my name, don't they? 16 A I don't think so. 16 BY MS. BECKER: 17 Q Who at the DC Department of Insurance, 17 Q Do you recognize this document? 18 Securities and Banking has information relevant to 18 A No. 19 this case? 19 Q I'd like to ask you to turn to the last 20 A Tom Hampton is the new commissioner at 20 page of the document. 21 the department, and he's fully aware of the 21 A Mm-hmm. 22 concepts that we were trying to do. We met with 22 Q Do you see where it says "signature of 30 (Pages 245 to 248) Esquire Deposition Services MD - 1-800-539-6398 D.C. - 1-800-441-3376 VA - 1-800-752-8979 a77cbcf5-7ff0-478d-a5f4-3a9a93751c41 Case 1:05-cv-01483-JDB Document 33-8 Filed 06/21/2007 Page 32 of 74 Marialice Williams Page 249 Page 251 1 debtor"? 1 A Mm-hmm. 2 A Mm-hmm. 2 Q Do you see where it says "none," and 3 Q Is that your signature? 3 there's a box checked there? 4 A It sure is. 4 A Mm-hmm. 5 Q Did you prepare this document? 5 Q Did you check none in response to the 6 A No. 6 question in Section 18? 7 Q Did you review it? 7 A Identify any business listed in response 8 A I think I did. 8 that is a single asset real estate. Yeah, I -- I 9 Q Who prepared it? 9 didn't have any business that was a single asset 10 A My bankruptcy attorney, Richard Gins. 10 real estate. 11 Q Did your signature indicate under 11 Q Do you see where it says: If the debtor 12 penalty of perjury that you'd read the answers 12 is an individual list the names, addresses, 13 contained in the foregoing statement of financial 13 taxpayer identification numbers, nature of the 14 affairs and any attachments thereto and that 14 businesses, and beginning and ending dates of all 15 they're true and correct? 15 businesses in which the debtor was an officer, 16 A I'm sorry, you lost me in your question. 16 director, partner, or managing executive of a 17 It was too long. 17 corporation, partnership, or sole proprietorship? 18 THE WITNESS: Could you tell me 18 A If -- I'm sorry, was -- was that the 19 what her question because I don't know what I'm 19 first, second, or third paragraph you read? 20 answering? 20 Q The first paragraph. 21 Do you want to know did I sign this and 21 A If the debtor's an individual, mm-hmm. 22 say that I believe that what's in here is true? 22 Okay. Yes, I see that. Page 250 Page 252 1 BY MS. BECKER: 1 Q Why didn't you identify RMS? 2 Q Yes. 2 A I don't know. I thought I did. 3 A Yes, I do. 3 Q Can you explain that? 4 Q Does this refresh your recollection as 4 A This isn't even -- I don't know what 5 to when you filed for bankruptcy? 5 copy this is, but this doesn't have everything on 6 A No, it doesn't because I don't see it on 6 here that it should have on here. So I don't know 7 here. And there's no date on here either. 7 where you got this, but it doesn't look to me like 8 Q In Section 1, income from employment or 8 it's complete or final. Because my attorney 9 operation of business, it says: To state the gross 9 certainly knew that I was -- he certainly knew 10 amounts received during the two years immediately 10 everything about me, saw my tax returns and 11 preceding this calendar year; do you see that? 11 everything. 12 A Mm-hmm. 12 Q You signed this document; correct? 13 Q And here there's information listed for 13 A Mm-hmm. Yes. 14 2000, 2001, and 2002. Do you see that? 14 Q Do you agree that indicating "none" 15 A Mm-hmm. 15 under Section 18 is incorrect? 16 Q So would it be fair to assume that this 16 A No, I don't agree because it says: 17 document was filed in 2002 or 2003? 17 Identify any business listed in response to 18 A Yes, I think it was filed in 2002, which 18 subdivision A. And there is no response to 19 is what I said from the beginning. It was either 19 subdivision A here, so wherever the response to 20 to 2001 or 2002. It appears that it was 2002. 20 subdivision A is must be where all that information 21 Q I'd like to turn your attention to the 21 is located, and it's not on here. 22 last page of this document under Section 18. 22 Q You're looking at B; is that correct? 31 (Pages 249 to 252) Esquire Deposition Services MD - 1-800-539-6398 D.C. - 1-800-441-3376 VA - 1-800-752-8979 a77cbcf5-7ff0-478d-a5f4-3a9a93751c41 Case 1:05-cv-01483-JDB Document 33-8 Filed 06/21/2007 Page 33 of 74 Marialice Williams Page 253 Page 255 1 A Mm-hmm. 1 holding -- you said E? 2 Q Look up under 18A. 2 Q F? 3 A Right. You know, I don't know. My 3 A Yes, it says: Schedule F, creditors 4 attorney prepared this, Richard Gins. You can ask 4 holding unsecured non-priority claims. 5 him why he didn't put it on there. I'm sure that I 5 Q Did you have an American Express card? 6 looked at it just as I'm looking at it now, saw 6 A Yes, I did. 7 this B section, said none, and signed it. 7 Q Did you use that for personal or for 8 But again, like I said, it's not dated, 8 business expenses? 9 and he certainly had knowledge of exactly what I 9 A Business. 10 was doing. So I guess you have to call my 10 Q Did you use it exclusively for business 11 bankruptcy attorney and ask him why he didn't put 11 expenses? 12 it on there. 12 A Yes. Pretty much. 13 Q Do you agree that RMS was a business in 13 Q Does that mean that you also used it for 14 which you were an officer, director, partner, or 14 some personal expenses? 15 managing executive? 15 A I -- I don't recall. This is really a 16 A I was the owner of RMS. 16 long time ago, and I'm sure that I used my American 17 MS. BECKER: I'd like to hand 17 Express travel largely for travel for business. I 18 you what I'll ask the court reporter to mark as 18 may have used my American Express card for personal 19 Exhibit 15. 19 but not my travel part of it, no. 20 (Deposition Exhibit No. 15 - Notice of 20 Oh, also I might have been going to 21 Chapter 7 Bankruptcy Case, Meeting of 21 American Bar Association conferences be -- a lot 22 Creditors & Deadlines, United States 22 because I was chairman of one of the -- of a Page 254 Page 256 1 Bankruptcy Court, District of Columbia (DC) - 1 subcommittee for the ABA at that time, I believe. 2 was marked for identification.) 2 Or at least active on Affordable Housing Committee. 3 THE WITNESS: Maybe he didn't 3 And I was also going to places like Mortgage 4 put it on there because there's no -- I didn't make 4 Bankers Association conferences to meet with Fannie 5 any money from it. And had a negative cash flow. 5 Mae and clients. 6 I don't know why he didn't put it on there. 6 So a lot of that travel was on -- it -- 7 BY MS. BECKER: 7 it was mostly business travel. I didn't have any 8 Q Do you recognize this document? 8 extra money. I was spending it all trying to 9 A No. 9 develop this business with Fannie Mae. 10 Q Have you ever seen this document before? 10 Q Your work as ABA conference chairperson, 11 A I don't know. 11 was that related in any way to expenses that you 12 Yes, I've seen this document. 12 incurred related to Fannie Mae? 13 Q What is it? 13 A Fannie Mae. Sure, I talked about Fannie 14 A It's my petition for bankruptcy. 14 Mae while I was in those conferences and, you know, 15 Q I'd like to turn your attention to 15 the potential solutions I had found that -- to 16 Schedule F, which is creditors holding unsecured 16 problems. It was affordable housing. I mean 17 non-priority claims. 17 that's the whole thrust of what I've been trying to 18 A Mm-hmm. 18 do with Fannie Mae and everyplace else was 19 Q Is this a statement of the outstanding 19 affordable housing. How to get access to the 20 credit card debts that you had at the time that you 20 secondary market for individuals who were not 21 filed bankruptcy? 21 middle class or white, and therefore I was always 22 A That's what it says. Un -- creditors 22 trying to come up with concepts for how to provide 32 (Pages 253 to 256) Esquire Deposition Services MD - 1-800-539-6398 D.C. - 1-800-441-3376 VA - 1-800-752-8979 a77cbcf5-7ff0-478d-a5f4-3a9a93751c41 Case 1:05-cv-01483-JDB Document 33-8 Filed 06/21/2007 Page 34 of 74 Marialice Williams Page 257 Page 259 1 housing for inner city, disabled individuals. 1 taxes. So I have receipts for what I claimed on my 2 I'm still doing that. Right now I'm 2 tax returns. 3 working on a project for affordable housing for 3 BY MS. BECKER: 4 people recovering from mental illness. That's -- 4 Q Can you tell me what the business -- 5 that's what I do. It's all related. 5 A And that doesn't have anything to do 6 Q Do you have any documentation that would 6 with what's on a bankruptcy petition, so I don't 7 indicate that your business expenses from American 7 understand the relevance of your question. Because 8 Express travel related to Fannie Mae? 8 you're asking me about this particular exhibit 9 A If they -- if they're on a particular -- 9 which has nothing to do with my tax return. 10 sure. If they're -- if it was an expense, it was 10 Q I'm asking you about receipts that you 11 on an American Express bill. And if it was on an 11 have that would back up the notion that -- 12 Express bill and I did -- deducted it from my -- 12 A The notion? 13 used it as an expense, then there would be a record 13 Q The notion that the American Express 14 in my tax records, as there is for every year that 14 travel expenses that you're identifying here were 15 I prepared my tax returns. I have all my receipts, 15 related to Fannie Mae. Are you willing to turn 16 pretty much. 16 over those receipts or not? 17 Q Are you willing to turn those receipts 17 A No. 18 over in this litigation? 18 Q Your Bank of America card that's listed 19 A No. 19 here, did you use that for business expenses or for 20 Q Why not? 20 personal expenses? 21 A Because it's none of your business. I 21 A For both. I've answered this question. 22 mean I have my tax returns, they're signed. I mean 22 The answer's going to be the same for every credit Page 258 Page 260 1 if you want to go to the IRS and ask them for the 1 card that's in here. For many of these credit 2 information, I'm sure they might give it to you. 2 cards, the reason I had the credit card was to 3 They do anything else they want to do. 3 write a check so that I could pay my bills for my 4 Q Do you have the information in your 4 office because I wasn't getting any business from 5 possession? 5 Fannie Mae. So I ran up credit card ch -- writing 6 A Yes, I do. 6 checks. I ran up credit card bills with American 7 Q Are you refusing to turn it over? 7 Express. 8 A I'm sorry, is this -- is this okay? 8 You see all of these individuals here 9 MR. DANIELS: Yeah. 9 that are listed, that is largely what I used my 10 THE WITNESS: Yeah, you know, 10 money for, was in order to survive to keep myself 11 I -- I prepared my tax returns just the way you do. 11 going, because I was convinced any day I was going 12 From receipts, it goes onto a schedule, and it gets 12 to get this in -- this business from Fannie Mae. 13 filed with the IRS. That is the way tax returns 13 And as it turned out, I didn't get it soon enough 14 are prepared. 14 so I had to file bankruptcy. 15 How do you get the receipts? You have 15 Q It lists under Bank of America bankcard 16 them in a package. You save them from your trips. 16 services, did you use that for business expenses or 17 You save them from your luncheons. You save them 17 for personal expenses? 18 from whatever you have. You put them in a package. 18 A Both. If you ask me that question about 19 When it's time to do your taxes, you add up those 19 every single thing in here, I'm going to give you 20 receipts and you put them into your tax return. 20 the same answer. So if you want to waste all of 21 And that's how it is done and that is how I do it 21 our time asking me, go right ahead and I'll answer 22 and that is how I believe most people do their 22 it all, but I have to be out of here at 4:00. 33 (Pages 257 to 260) Esquire Deposition Services MD - 1-800-539-6398 D.C. - 1-800-441-3376 VA - 1-800-752-8979 a77cbcf5-7ff0-478d-a5f4-3a9a93751c41 Case 1:05-cv-01483-JDB Document 33-8 Filed 06/21/2007 Page 35 of 74 Marialice Williams Page 261 Page 263 1 Q For each of these credit cards, is -- is 1 Q Yeah. 2 it your testimony that you used them partly for 2 A This is a copy. I did not keep copies 3 business expenses and partly for personal expenses? 3 of the ones that were signed. But these were in my 4 A Yes. 4 computer. My accountant sent them to me in the 5 Q Can you tell me how much -- 5 computer. When I printed them out, Mr. Dan -- 6 A No. 6 Mr. Down -- Downing and I signed them and sent them 7 Q -- you used for business expenses -- 7 in. I did not make a copy of the -- of the return 8 A No, I cannot. 8 with the signatures. 9 Q -- and how much you used for personal 9 Q Is this the original tax return that you 10 expenses? 10 filed for the year 2001 or is this an amended tax 11 A No, I cannot. 11 return? 12 My business expenses are listed on my 12 A This is the only tax return I have filed 13 tax returns and all that information comes from 13 for 2001. 14 receipts that were provided to my accountant. 14 Q And when was this tax return prepared? 15 MS. BECKER: I'm going to ask 15 A In 2004. 16 the court reporter to mark this is as Exhibit 15 or 16 Q Why wasn't the tax return filed at the 17 16? 17 time that it was prepared? 18 MADAM REPORTER: Sixteen. 18 THE WITNESS: Do I answer this? 19 MS. BECKER: Sixteen. 19 MR. DANIELS: No, I'm going to 20 (Deposition Exhibit No. 16 - 2001 Form 1040, 20 direct you not to answer that. Not relevant to 21 U.S.Individual Income Tax Return for the 21 this lawsuit. 22 witness - was marked for identification.) 22 MS. BECKER: Is there any other Page 262 Page 264 1 BY MS. BECKER: 1 basis -- 2 Q Is this a copy of your 2001 tax return? 2 MR. DANIELS: Can we have a 3 A Yes, it is. 3 proffer as to what you intend to prove by this? 4 Q When was this filed with the IRS? 4 MS. BECKER: Is there any other 5 A In September of 2006. 5 basis for your objection? 6 Q Why didn't you file before September of 6 MR. DANIELS: Do you have a 7 2006? 7 proffer? 8 A Becau -- 8 MS. BECKER: Is there any other 9 MR. DANIELS: I'm going to 9 basis for your objection? 10 direct her not to answer that question. 10 MR. LEDERER: Yeah, it's 11 MS. BECKER: On what grounds? 11 intrusive, it's immaterial. 12 MR. DANIELS: On the ground that 12 MR. DANIELS: And it's 13 it's not relevant to this lawsuit. 13 irrelevant. 14 MS. BECKER: Is that the only 14 MR. LEDERER: It's irrelevant. 15 basis of your objection? 15 If fact, if you want to -- 16 MR. DANIELS: For the moment, 16 MR. DANIELS: That's okay. 17 yes. 17 MS. BECKER: Is there any other 18 BY MS. BECKER: 18 basis for your objection? 19 Q If you turn to Page 2 of this tax 19 MR. DANIELS: No, ma'am. 20 return, you'll see where there's a place for your 20 MR. LEDERER: At the moment. 21 signature. Is this tax return signed? 21 BY MS. BECKER: 22 A Yes, it was signed when it was filed. 22 Q Are you going to decline to answer the 34 (Pages 261 to 264) Esquire Deposition Services MD - 1-800-539-6398 D.C. - 1-800-441-3376 VA - 1-800-752-8979 a77cbcf5-7ff0-478d-a5f4-3a9a93751c41 Case 1:05-cv-01483-JDB Document 33-8 Filed 06/21/2007 Page 36 of 74 Marialice Williams Page 265 Page 267 1 question? 1 MS. BECKER: Do you have any 2 A I am going to follow my attorney's 2 other basis for your objection? 3 advice. 3 MR. DANIELS: Do you have any 4 MR. DANIELS: I direct you to 4 more to proffer? 5 not answer that question. 5 MS. BECKER: I don't know what 6 MR. LEDERER: You asked for a 6 her testimony would be so I can't tell you what it 7 proffer. 7 be -- 8 MR. DANIELS: Are you going to 8 MR. DANIELS: I don't know what 9 give me your proffer, or you decline to give me 9 you're looking for so I have to say from my point 10 your -- 10 of view it looks irrelevant, immaterial, 11 MS. BECKER: I believe that her 11 oppressive, and none of your business for the 12 tax returns are directly relevant to her statement 12 purposes of this lawsuit. 13 of damages in this case and directly relevant to 13 MS. BECKER: Again, I believe it 14 the proof -- 14 goes to her damages and to her credibility. 15 MR. DANIELS: But she's given 15 MR. DANIELS: Okay. 16 you those tax returns. 16 BY MS. BECKER: 17 MS. BECKER: -- that she would 17 Q I would like to direct your attention to 18 offer relating to those -- those damages. I'm 18 page -- 19 entitled -- 19 A Well, you can pay me what it says on 20 MR. DANIELS: When it was filed 20 here is my losses for each one of those years 21 has nothing to do with her damages. 21 and -- 22 MS. BECKER: It -- it also goes 22 Q I'd like to turn -- Page 266 Page 268 1 to -- to her credibility in this case. 1 A -- and then we won't have any more 2 THE WITNESS: My credibility? 2 discussion. 'Cause it's only because of Fannie Mae 3 This is my tax return. 3 that I had those losses, so they can pay me those 4 MR. LEDERER: Can you make a 4 losses there and I will forfeit the 35 million they 5 proffer on that -- how that goes to her 5 owe me. 6 credibility? 6 Q You have backup documentation, 7 MR. DANIELS: Yes. 7 Ms. Williams, is that correct, relating to your 8 MS. BECKER: I don't know what 8 2001 tax return? 9 her testimony would be so I can't tell you what the 9 A Of course I do. 10 testimony would be. But -- 10 Q And you're not -- not willing to produce 11 MR. LEDERER: Yeah, but what 11 those; is that correct? 12 makes you think inquiring into how she filed her 12 A No, I'm not. 13 tax returns, when she filed her tax returns, why 13 Q Okay. Looking to Page 4 of your tax 14 she filed them then instead of later has anything 14 return, you identify under expenses in line 17 15 to do with her credibility? These are financial 15 legal and professional services in the amount of 16 figures going to damages. They are signed, filed 16 $36,000. Do you see that? 17 returns. 17 A Yes, I do see it and I showed you where 18 So we're just asking for your proffer, 18 it came from. I showed you that I paid someone 19 other than an inquiry into her financial affairs. 19 $2,000 a year and someone 3,000. Twelve times 20 MR. DANIELS: We've -- we've got 20 three is 36. 21 a record on it. Let's go on. 21 MR. DANIELS: A month. A month. 22 MR. LEDERER: Yeah. 22 You said a year. 35 (Pages 265 to 268) Esquire Deposition Services MD - 1-800-539-6398 D.C. - 1-800-441-3376 VA - 1-800-752-8979 a77cbcf5-7ff0-478d-a5f4-3a9a93751c41 Case 1:05-cv-01483-JDB Document 33-8 Filed 06/21/2007 Page 37 of 74 Marialice Williams Page 269 Page 271 1 THE WITNESS: Huh? 1 going from receipts and that's largely where it 2 MR. DANIELS: You said a year. 2 came from. Some receipts perhaps weren't there. 3 You meant a month. 3 There's nothing inconsistent with my tax 4 THE WITNESS: A year. $36,000 I 4 return, my bankruptcy petition, and my statements 5 paid. 5 in my interrogatories. It is 100 percent 6 MR. DANIELS: But you said 6 consistent. 7 2,000. 7 Q Did you add up the amount of your 8 THE WITNESS: Two thousand 8 travel, meal, and entertainment expenses based on 9 versus 3,000 per -- month, right, which totals then 9 the receipts that you had from the year 2001? 10 the 36,000. That's completely consistent with what 10 A I didn't add them up. The -- someone 11 I put in my thing there. 11 who worked for my accountant added them up. 12 BY MS. BECKER: 12 Q Did you review those receipts yourself? 13 Q Who did you pay for legal and 13 A No, I put them in the file. She re -- 14 professional services? 14 she added them up. You're not required to 15 A I paid Harvey Hartsfield. In this 15 independently add up your own receipts as far as I 16 particular year. 16 know. I thought it was the job of the accountant 17 Q What was the nature of his legal and 17 and their bookkeeper. I thought they were better 18 professional services? 18 at adding than I was. 19 A Professional services. For that he was 19 Q Do you have any basis to say whether you 20 a marketing consultant; he was also an insurance 20 actually incurred $10,000 in travel, meals, and 21 broker. We jointly went out to look at projects 21 entertainment expenses? 22 together. He did a great deal of research, a great 22 A I probably incurred more than that. And Page 270 Page 272 1 deal of marketing stuff. He was constantly in 1 some of it may not even be recorded. 2 contact because he was -- had been in the insurance 2 Q Do you have any basis to say that you 3 business longer than I had. He was constantly in 3 definitely incurred $10,000 in travel, meal, and 4 contact with the various sources we were trying to 4 entertainment -- 5 use, like Swiss Re, Aon, White Mountain, Risk 5 A I have receipts. I have told you on 6 Mountains, Goldman Sachs, Bear Stearns. You name 6 every single return I have filed, I have backup 7 it. Forbes, Alexander Forbes in Europe. He was 7 receipts which my accountant used to add up to come 8 constantly in touch with these people in order to 8 to the decisions about what should be placed on my 9 come up with the -- the type of insurance that we 9 return. I do not have one entry on my tax returns 10 would need for whatever execution might be 10 that does not have corresponding receipts. 11 necessary. 11 I have just spent almost $10,000 trying 12 We did presentations to Fannie Mae, we 12 to get all of my tax returns filed accurately, and 13 did presentations to everybody you can think of. 13 I am now -- 14 In this business. 14 MR. DANIELS: Marialice, I don't 15 Q You identify $10,000 in travel meals and 15 think you need to go on. 16 entertainment expenses. Do you see that? 16 THE WITNESS: I'm just so sick 17 A That would be consistent with the 1500 17 of this. 18 that I talked about per month on an average in my 18 MR. DANIELS: I mean this 19 response in the interrogatory that you referred me 19 question's been asked and asked and asked and 20 to earlier. And as you can see that's even less 20 asked. I think she gave a generic answer to -- 21 than what I believe the actual amount might have 21 to -- to your questions: Yes, she has receipts. 22 been. It was probably more than that. But we were 22 BY MS. BECKER: 36 (Pages 269 to 272) Esquire Deposition Services MD - 1-800-539-6398 D.C. - 1-800-441-3376 VA - 1-800-752-8979 a77cbcf5-7ff0-478d-a5f4-3a9a93751c41 Case 1:05-cv-01483-JDB Document 33-8 Filed 06/21/2007 Page 38 of 74 Marialice Williams Page 273 Page 275 1 Q Did you independently review those 1 A No. Temporary services. It's an -- a 2 receipts to verify whether you had incurred $10,000 2 term of art. I believe it's defined as people who 3 of expenses in meals, travel, and entertainment for 3 do work on a temporary basis. 4 the year 2001? 4 Q Who are the individuals that you 5 A I don't remember. I don't remember. 5 retained for temporary services? 6 I provided the information to my 6 A I can't tell you their names right now. 7 accountant, and my accountant used a calculator and 7 I have the receipts. 8 added it up and put it on the return. I do not 8 Q Are you willing to produce those 9 recall whether I independently sat down and added 9 receipts? 10 up each receipt. Do you do that? I don't gen -- 10 A No. 11 generally do that on my tax returns. I rely on a 11 Q Can you give me any more information 12 professional person to do it. 12 about what expenses that you're claiming in 13 Q What's the name of the person who 13 temporary services on your 2001 tax return? 14 prepared your tax returns? 14 A They went to individuals who performed 15 A It's right here on the return. Just 15 temporary services for me, such as administrative 16 look at it and see. It's right here on the return. 16 typing, filing, and that kind of thing. I was 17 The DMP Group, LLC, 5600 Colorado Avenue, 17 running a -- a very -- a very serious business and 18 Northwest. 18 making no money. I could not hire someone 19 Q What's the -- 19 full-time. I had to hire some different people at 20 A Washington, DC 20011. Employer ID 20 different times to perform those services which 21 number 68-049-7011. I believe her -- her social 21 were necessary to keep me on track so that I could 22 security number is and her telephone 22 keep my eye on the prize, which I never got. Page 274 Page 276 1 number is (202)726-2630. 1 Q Can you explain the $7,200 in telephone 2 MS. BECKER: Move to strike as 2 expenses and what those were based on? 3 non-responsive. 3 A What was it based on? It was based on 4 BY MS. BECKER: 4 the usage of my telephones. 5 Q Who's the individual at the DMP Group 5 Q How many telephones did you have? 6 who prepared this return? 6 A Several. I don't know. Maybe seven, 7 A The DMP Group prepared my return. I 7 maybe five. They were commercial lines. Anybody 8 cannot tell you whether it was Schlimb (ph) or 8 who runs any kind of business, including a law 9 Schlomb (ph). It was the DMP Group who prepared 9 firm, should know that commercial phone costs are 10 the return. 10 higher than residential. And if you also have 11 Q You referred to a she? Was there a 11 services for computers, that gets added in. If you 12 person you were referring to -- 12 have a fax machine that gets added in. 13 A Dana Lucas was the person who was there 13 Q Were you paying a flat rate? 14 who did some of the work, and there were other 14 A Is there an issue here about whether or 15 people who worked on it. 15 not I was running a bona fide business, whether or 16 Q On Page 5 of your tax return, you 16 not I was actually at the Watergate? This seems to 17 identified $12,000 in temporary services. Do you 17 be coming up consistently from you. If -- if you 18 see that? 18 want to know, I have filed a tax return. That is 19 A Yes. Uh-huh. 19 the evidence that I had the expense. 20 Q And what is that for? 20 Where did the tax return come from? 21 A Temporary services. 21 I've told you over and over again I have receipts. 22 Q Can you explain what that means? 22 I've told you over and over again that the receipts 37 (Pages 273 to 276) Esquire Deposition Services MD - 1-800-539-6398 D.C. - 1-800-441-3376 VA - 1-800-752-8979 a77cbcf5-7ff0-478d-a5f4-3a9a93751c41 Case 1:05-cv-01483-JDB Document 33-8 Filed 06/21/2007 Page 39 of 74 Marialice Williams Page 277 Page 279 1 are the basis for this. Do you think that I just 1 somebody's crazy or the law is really crazy, 2 sat around and made some stuff up to put in a tax 2 because this is outrageous. There's nothing I'm 3 return because it -- it would satisfy my desire 3 going to say to you on any one of those returns 4 to -- whatever? I mean I -- I don't understand 4 that's any different from what I've said to you 5 your questioning and it's dragging on and on, and 5 about 2001. I have my backup. 6 it is the worst interrogation I've ever had in my 6 You can see -- I guess what you're upset 7 life over something that's completely irrelevant. 7 about is that it really shows that I paid all this 8 If you can't take my tax return that I 8 stuff and that you all didn't pay me and therefore 9 filed with the Internal Revenue Service and use it 9 I went bankrupt. And nearly lost my mind. All 10 and look at it and say, okay, do you have receipts 10 because of lying and cheating and backstabbing and 11 for this, yes, well, what else do you want me to 11 everything else that Fannie Mae does to cover 12 tell you? There's nothing else to say. Here's my 12 itself up. So if you want to go through all that, 13 tax return. I have the receipts. Dana Lucas and 13 that's fine, and I'll go through it if my attorney 14 the DMP Group prepared the return. I filed it with 14 tells me I have to. But I think you're wasting 15 the IRS. Don't you think it's the IRS's job to 15 everybody's money and time. 16 look into it? 16 I'm not going to give you any different 17 Q Did you have a flat rate with your 17 answer on any question you give me on my tax 18 telephone companies or were you paying based on -- 18 returns, other than the ones you've just gotten. 19 A I don't remember what it was. That was 19 Now I'm sorry that I gave you my tax returns. 20 so long ago. Do you have a flat rate? Do you know 20 Because obviously you don't even know what to do 21 whether or not in 2001 you had a flat rate on your 21 with them. 22 commercial telephone? I don't remember. I'm 22 MS. BECKER: Have you marked Page 278 Page 280 1 sorry. But we can certainly call Verizon or 1 this as exhibit -- 2 whoever it was, and we can get the answer to that 2 MADAM REPORTER: Haven't seen 3 for you. 3 it -- 4 Q Are you willing to provide your receipts 4 THE WITNESS: Do I have to sit 5 relating to your telephone costs? 5 here and do this with every one of these tax 6 A No. 6 returns? 7 MS. BECKER: I'd like to ask the 7 MR. DANIELS: You have to bear 8 court reporter to mark this as -- 8 under the way she does things. 9 THE WITNESS: Are we going to go 9 THE WITNESS: Well, she can't 10 through this on every return? I can't do this 10 cause me to lose my -- my livelihood. She's -- 11 today. I'm sorry, I can't give you any more 11 that's not fair. I mean they didn't give me -- 12 answers. I've got to go. You did not tell me I 12 MR. DANIELS: Four -- 4:00 -- 13 was going to be here for seven hours today. I was 13 THE WITNESS: -- a livelihood to 14 told it was going to be a couple of hours, that you 14 begin with and now they want to take away the one I 15 only had a couple hours more to do. And you're now 15 have. 16 into five and a half hours. 16 MR. DANIELS: Well, what I would 17 And I work for a living and the reason I 17 propose is that we go until four and reconvene. 18 have any income at all is because I have to work 18 THE WITNESS: I can't go until 19 for a living on an hourly basis. And I really 19 four. I have to go 'til ten minutes of four. 20 can't go through this crap. And if my lawyer tells 20 MR. DANIELS: Ten minutes of 21 me I have to sit here and go through the same thing 21 four and then we reconvene to finish what they want 22 on every one of these returns, I'm going to say 22 to do and for our redirect. 'Cause there's no way 38 (Pages 277 to 280) Esquire Deposition Services MD - 1-800-539-6398 D.C. - 1-800-441-3376 VA - 1-800-752-8979 a77cbcf5-7ff0-478d-a5f4-3a9a93751c41 Case 1:05-cv-01483-JDB Document 33-8 Filed 06/21/2007 Page 40 of 74 Marialice Williams Page 281 Page 283 1 I'm going to finish my redirect, giving where we 1 amended returns that were prepared by this same 2 are right now. 2 individual but they were amended. So -- that's the 3 MADAM REPORTER: I don't have 3 same question. You're going to ask me the same 4 that -- 4 question. Go ahead. How do you know these are 5 MS. BECKER: I'd like to ask the 5 your receipts, how do you know you had this? 6 court reporter to mark this as Exhibit 17. 6 Because I had the receipts. 7 THE WITNESS: I would never hire 7 Q When did you provide information to the 8 this law firm. All this wasting time -- 8 DPM Group in connection with your 2002 tax return? 9 (Deposition Exhibit No. 17 - 2002 Form 1040, 9 A In 2003. Or '4. Or maybe it was '5. 10 U.S.Individual Income Tax Return for the 10 I'm not sure. 11 witness - was marked for identification.) 11 Q When was this filed with the IRS? 12 MR. DANIELS: Let me ask -- I 12 A Same time I told you I filed them. I've 13 mean I -- are we going to have -- can we proceed to 13 already answered that question, 2000 -- zero, 2001, 14 quarter to four -- ten to four and reset it for 14 2002, '3, '4, and '5 were filed in September of 15 another date to finish this and to do my redirect? 15 2005 -- '6. 16 MS. BECKER: I'd like to finish 16 MR. DANIELS: Six. 17 today if we can. 17 BY MS. BECKER: 18 THE WITNESS: I cannot stay 18 Q You've not provided us with any tax 19 here. 19 returns for 2004; is that correct? 20 MR. DANIELS: We can -- she says 20 A I explained that to you when I gave you 21 she can't. And I -- I'm going to need time for 21 the returns. I said the 2004 is being reviewed and 22 my -- 22 will be finalized by the end of this week. I gave Page 282 Page 284 1 THE WITNESS: You told me two 1 you the original of 2005 which will be filed 2 hours and it's not fair for you to keep me five and 2 tomorrow. 2000 is being reworked because there's 3 a half. So if you can't be honest about what 3 some questions about whether or not my spouse filed 4 you're doing, then I don't see why I have to be 4 an independent return in that year; therefore, 5 responsive to you. I think you need to accommodate 5 another return may have to be prepared. 6 me. You have a job. 6 MR. DANIELS: Did you get back 7 MR. DANIELS: Marialice -- 7 your originals, Marialice? 8 THE WITNESS: I don't have a 8 THE WITNESS: Yes, she gave me 9 job. 9 back the original. 10 BY MS. BECKER: 10 BY MS. BECKER: 11 Q Are you looking at your 2002 tax return? 11 Q Do you have an original return that you 12 A I don't have it. 12 filed for 2004? 13 Q When was this document prepared? 13 A I just told you that 2004 is being 14 A I don't know. 14 reviewed and reworked and will be filed before the 15 Q Was it prepared in 2003? 15 end of the week, and I will send you a copy. 2005 16 A I don't know. 16 is in its original form, which I gave you this 17 Q Who prepared this document? 17 morning, which has been returned to me. 2003, '2, 18 A The DMP Group. Dana Lucas, I imagine. 18 and '1 you have been given copies of. 19 Q When did you provide -- 19 And 2000 -- listen carefully because 20 A All of my tax returns were prepared by 20 you're going to ask me again -- 2000 is not -- has 21 the same individual for the years 2000, 2001, 2002, 21 been filed and will be amended because there's some 22 and 2003. 2004 and 2005 were prepared -- were 22 question as to whether or not my husband filed a 39 (Pages 281 to 284) Esquire Deposition Services MD - 1-800-539-6398 D.C. - 1-800-441-3376 VA - 1-800-752-8979 a77cbcf5-7ff0-478d-a5f4-3a9a93751c41 Case 1:05-cv-01483-JDB Document 33-8 Filed 06/21/2007 Page 41 of 74 Marialice Williams Page 285 Page 287 1 separate return in that year. 1 been asked and answered. Please, Evelyn, please. 2 MR. DANIELS: In the 2 MS. BECKER: What -- what is it 3 communication concerning these tax returns we said 3 about -- what is it about the -- that was -- 4 we wouldn't have all the tax returns today, that we 4 MR. DANIELS: I mean she's -- 5 would provide the rest of them as soon as they're 5 she's -- she's explained it three times to you 6 available and give you an opportunity to ex -- 6 already, four times. 7 examine her on them in this deposition. On Friday 7 MS. BECKER: What is it about -- 8 that was communication. 8 THE WITNESS: Because my 9 BY MS. BECKER: 9 attorney said, give them the tax returns. I gave 10 Q Have you already filed the tax return 10 them to you, told you why you didn't have the ones 11 for 2004? 11 you didn't have, then I come in here, you want to 12 A No -- yes. And I just told you it is 12 ask me every detail again. 13 being reworked and amended. Did you understand 13 I've told you four times why you have 14 that? 14 exactly what you do and what you don't have. I've 15 Q Are you willing to provide the original 15 explained to you when you're going to have them. 16 2004 return that you filed? 16 But you keep asking me the same thing over and over 17 A No. 17 again. And I can't answer it any other way. 18 Q Why not? 18 I mean what's more important? I could 19 A Because it's incorrect and I needed to 19 give you some questions to ask me about the tax 20 amend it; that's why I had to go pay another $5,000 20 returns, like, gee, you had $170,000 loss in 2002. 21 to another accountant. 21 I bet that was because Fannie Mae didn't give you 22 Q What's incorrect about it? 22 any business and you had to spend your entire Page 286 Page 288 1 A I don't know. It's incorrect. I'm not 1 retirement in that little pissy package they gave 2 an accountant. My name is not CPA, it's JD. 2 you to stay alive and do this business until Fannie 3 Q Is your testimony that you don't know 3 Mae did some with you, which they ultimately never 4 what's incorrect -- 4 did, and therefore you had to find another means of 5 A I don't know what's incorrect on the 5 making a living. If you want to ask me that, I can 6 return. 6 answer those questions. But you're going through 7 Q -- on your 2004 tax return? 7 nonsense. 8 A No, I don't know what's incorrect on the 8 I mean the return is here. I told you 9 aturn [sic]. I had to hire a second -- a -- a CPA 9 it was filed and signed and that this is a copy 10 to fix the first one. If I knew, I would've done 10 that I printed off of my computer this morning. I 11 it myself. 11 did not save a copy of the signed return. Now, if 12 Q Did you know what's incorrect about your 12 you want me to get a verification from IRS that 13 2000 tax return? 13 this is in fact a correct return, that's fine, but 14 A I just told you that it appears that my 14 it's all clear as a bell to me. And if I tell you 15 husband filed separately. 15 that I have backup documentation for each one of 16 Don't you listen? I am so tired of 16 these numbers, what is the issue? Other than 17 repeating this over and over again. You are so 17 harassment. 18 irritating. Want to ask me again? 18 BY MS. BECKER: 19 Q Yes. I'd -- I'd like to know -- 19 Q I'm asking about your 2000 tax return. 20 A You can ask me as many times as you 20 A And I told you -- 21 like. 21 MR. DANIELS: What's your 22 MR. DANIELS: All right. It's 22 question, Evelyn, on the 2000 tax return? 40 (Pages 285 to 288) Esquire Deposition Services MD - 1-800-539-6398 D.C. - 1-800-441-3376 VA - 1-800-752-8979 a77cbcf5-7ff0-478d-a5f4-3a9a93751c41 Case 1:05-cv-01483-JDB Document 33-8 Filed 06/21/2007 Page 42 of 74 Marialice Williams Page 289 Page 291 1 BY MS. BECKER: 1 Now, you want me to say it again? 2 Q My question is: What is it about the 2 BY MS. BECKER: 3 2000 tax return as it was filed that's inaccurate? 3 Q Directing your attention to your 2002 4 A I -- 4 tax return and looking specifically at Page 2 of 5 MR. DANIELS: Marialice, I 5 this return, you did sign a copy of this return at 6 direct you not to answer the question. 6 some time; is that correct? 7 THE WITNESS: Okay. 7 A As I've stated previously, I signed all 8 MR. DANIELS: You've answered it 8 of these returns when I filed them. 9 four -- four or five times already. And Evelyn can 9 Q What's the date on which you signed this 10 look at the -- 10 return? 11 THE WITNESS: Records and see. 11 A I don't recall. 12 MR. DANIELS: -- transcript and 12 Q Turning your attention to page -- 13 see what the answer is. 13 A As I also told you, they were all filed 14 MS. BECKER: What's the basis 14 in September of 2006. I have said that four times 15 for your instruction? 15 also. 16 MR. DANIELS: Asked and 16 Q Is that when you would've signed them? 17 answered. The same exact question. The same exact 17 MR. DANIELS: Just answer yes 18 question. 18 or no. 19 MS. BECKER: That's not a 19 THE WITNESS: I -- yes. 20 legitimate basis for an instruction not to answer. 20 MR. DANIELS: Good. 21 If you want to follow -- 21 THE WITNESS: God. 22 MR. DANIELS: Well, I mean if -- 22 BY MS. BECKER: Page 290 Page 292 1 if you were -- you were asking probing questions 1 Q Turning your attention to Page 4 of this 2 which -- which went to -- to question her 2 return. You're identifying your business as Risk 3 response -- 3 Mitigation Strategist, LLC; is that correct? 4 THE WITNESS: Well, let's just 4 A That is on there. That may or may not 5 tell her one more time because -- 5 be correct. 6 MR. DANIELS: Well, go ahead and 6 Q What may be incorrect about it? 7 answer -- 7 A The LLC may be incorrect for 2002. I 8 THE WITNESS: -- obviously she 8 would have to go back and check. 9 has an issue with her hearing. 9 Q Can you explain why you identified your 10 MR. DANIELS: Okay. Ask her one 10 business or profession as legal consultant? 11 more time. 11 A That's actually -- it should be legal, 12 THE WITNESS: And her memory. 12 comma, consultant. 13 Because she can't even remember what questions she 13 Q You indicate in part one of this return 14 asks me. 14 $13,272 in income. Do you see that? 15 MR. DANIELS: Go ahead. 15 A Yes. 16 Tell her -- tell her the answer. 16 Q Where does that $13,272 in income come 17 THE WITNESS: My 2000 return is 17 from? 18 not filed because I filed it originally with -- as 18 A I don't know because I'm not looking at 19 a joint tax return with my husband. As I've told 19 the backup information. 20 you five times now, it appears he may have filed 20 Q Do you know whether you received income 21 his own return individually for that year. As a 21 in 2002 from any source? 22 result, I think I have to file a different return. 22 A I know what's listed on my tax retet -- 41 (Pages 289 to 292) Esquire Deposition Services MD - 1-800-539-6398 D.C. - 1-800-441-3376 VA - 1-800-752-8979 a77cbcf5-7ff0-478d-a5f4-3a9a93751c41 Case 1:05-cv-01483-JDB Document 33-8 Filed 06/21/2007 Page 43 of 74 Marialice Williams Page 293 Page 295 1 return is a reflection of what is in my records. 1 amount of $389; do you see that? 2 Q Can you give me any -- more information 2 A Yes -- no, I don't -- yes, I see that, 3 about -- 3 mm-hmm. 4 A No, I can't. 4 Q Do you know what that was for? 5 Q -- the source -- the source -- 5 A No. It's in my records. 6 A No. 6 Q In 2002 you identify $10,000 in travel, 7 Q -- of your income in 2002? 7 meal, and entertainment expenses. Do you see that? 8 A I can't. No, I can't. And I'm not 8 A Yes, I do. 9 looking at the records. 9 Q Does it strike you as unusual that your 10 Q And the only place -- 10 travel, meal, and entertainment expenses in 2001 11 A It was not from Fannie Mae. 11 and 2002 were identical? 12 Q Is the only place that I would know 12 A No. 13 where that income came from by looking at your 13 Q Why not? 14 backup documentation? 14 A I don't know. I don't know. I'm sorry. 15 A For $13,000? I don't -- 15 I don't know. If you look at the backup, maybe 16 MR. DANIELS: I don't -- I don't 16 we'll know, but I don't have the backup with me. 17 see the relevance of that at all. I mean if she 17 I'm sorry. 18 received money from Fannie Mae, that -- you'd all 18 Q And you're not willing to provide it? 19 know about that. Other than that, her sources of 19 A And I'm not going to show it to you. 20 income have nothing to do with this whatsoever. 20 It's my stated tax return that I've agreed in 21 BY MS. BECKER: 21 writing, that I signed. So every question you ask 22 Q Do you know what your sources of income 22 me, you're asking me did you sign this tax return, Page 294 Page 296 1 were in 2002? 1 did you look at those numbers and are they correct? 2 MR. DANIELS: Marialice, don't 2 And all I can say to you is I don't know what any 3 answer the question any further. 3 of these numbers. 4 BY MS. BECKER: 4 So you can ask me all of them 5 Q Are you going to follow your counsel's 5 individually, which I'm sure you will, but I'm 6 instruction? 6 telling you right now unless I'm looking at the 7 A I have nothing to say. 7 backup, I'm not going to have an answer for you. I 8 Q You identify in part two under expenses 8 apologize but I just don't. I don't memorize my 9 $40,930 in legal and professional services. Do you 9 expenses for a year. 10 see that? 10 Q Looking to the next page of your tax 11 A Yes. 11 return in 2002, you identify $1,150 in dues and 12 Q Do you know what that's for? 12 subscriptions. Do you see that? 13 A No. It's in my records. 13 A Yes, I do. 14 Q Other than looking at your records, is 14 Q Do you know what that's for? 15 there any way that I can determine what your 15 A No. I don't. I'm sure it's in my 16 expenses for legal and professional services in 16 expenses but I just don't know. 17 2002 were? 17 BY MS. BECKER: 18 A No. 18 Q Do you know what the conference that you 19 Q Are you willing to provide those 19 list under part five other expenses is? 20 records? 20 A I don't remember. 21 A No. 21 Q You don't know what that conference was? 22 Q You identify office expenses in the 22 A I don't remember. It was 2002. I just 42 (Pages 293 to 296) Esquire Deposition Services MD - 1-800-539-6398 D.C. - 1-800-441-3376 VA - 1-800-752-8979 a77cbcf5-7ff0-478d-a5f4-3a9a93751c41 Case 1:05-cv-01483-JDB Document 33-8 Filed 06/21/2007 Page 44 of 74 Marialice Williams Page 297 Page 299 1 don't remember, I'm sorry. 1 L -- RMS was an LLC in 2002 either. RMS is a -- is 2 Q Do you know what the temporary services 2 the name of a part of the business that I do. I do 3 are that you claimed? 3 four different or five different things. RMS is 4 A I'm sure they're the same ones I had 4 one of them. 5 from the year before. That I explained to you. I 5 Q Is there a reason that you don't list 6 had someone come in and do administrative stuff 6 RMS here on your 2003 tax return? 7 and -- from time to time. 7 A Yes, because it's not an independent 8 Q Do you remember the name of any of those 8 entity so I didn't list it. 9 individuals? 9 Q What do you mean by "it's not an 10 A No, I don't remember anybody from 2002. 10 independent entity"? 11 I'd have to look in my records. 11 A Just what I said. And it didn't have 12 Q Did you work with a temporary service 12 any income, so therefore I put down where I had the 13 agency? 13 income from. And that's what's under my income for 14 A No, I did not. 14 that year. RMS didn't have any income. 15 Q How did you hire the individuals that 15 Q Why -- 16 you identified -- 16 A It only existed -- it had some 17 A I don't remember. 17 tangential income because of some work I might've 18 Q Are these individuals different from the 18 done for somebody in the mortgage industry. But -- 19 office assistant that you identified in your 19 you know, my RMS business was formed to do business 20 interrogatory responses? 20 with Fannie Mae. Do you know of any business 21 A I don't know. I don't remember. 21 Fannie Mae gave me? I don't know of any. 22 MS. BECKER: I'd like to ask the 22 Therefore, there was no reason to keep RMS as a -- Page 298 Page 300 1 court reporter to mark this as Exhibit 18. 1 and -- and if it had no income, there was no reason 2 (Deposition Exhibit No. 18 - 2003 Form 1040, 2 in 2003 to put it on the tax return. 3 U.S. Individual Income Tax Return for the 3 Q Why did you list Risk Mitigation 4 witness - was marked for identification.) 4 Strategists, LLC on your 2002 tax return? 5 BY MS. BECKER: 5 A I didn't list it. My accountant listed 6 Q Turning your attention to Page 4 of this 6 it and it's probably incorrect. 7 exhibit -- 7 Q Do you intend to go back and amend your 8 MR. LEDERER: What year is that 8 2002 tax return? 9 return? 9 A I don't know. 10 MS. BECKER: 2003. 10 Q You identify in your 2003 tax return 11 MR. DANIELS: 2003. 11 $108,343 in income. Do you see that? 12 MR. LEDERER: Thank you. 12 A I certainly do. 13 BY MS. BECKER: 13 Q And what's the source of that income? 14 Q You identify again under business name, 14 A Non-Fannie Mae work. 15 M. Williams and Associates; do you see that? 15 Q Can you be more specific? 16 A That's right, and it doesn't have LLC 16 A No, I can't. It's consulting fees. I 17 next to it. 17 think that's what it says here. Consultant, 18 Q And is this accurate for 2003? 18 consulting fees. 19 A Yes, it is. 19 Q Who paid you the consulting fees in 20 Q Is that because RMS was dissolved as of 20 2003? 21 2003? 21 A The DC Department of Mental Health and 22 A No. RMS, as I said, and I don't believe 22 others. And I don't recall the others. 43 (Pages 297 to 300) Esquire Deposition Services MD - 1-800-539-6398 D.C. - 1-800-441-3376 VA - 1-800-752-8979 a77cbcf5-7ff0-478d-a5f4-3a9a93751c41 Case 1:05-cv-01483-JDB Document 33-8 Filed 06/21/2007 Page 45 of 74 Marialice Williams Page 301 Page 303 1 Q Do you remember how much the DC 1 number? 2 Department of Mental Health paid you in consulting 2 A I did -- it was not my job to verify the 3 fees? 3 number. My job is to provide an accountant with 4 A No, I don't remember what it was 4 receipts. When the accountant adds up the 5 specifically. 5 receipts, they put them on this form. 6 Q Do you remember whether they were the 6 Q What steps did you take to make sure 7 majority of this amount? 7 that the tax returns that you filed with the IRS 8 A Probably so. 8 were accurate? 9 Q How would I determine what your income 9 A I hired an accountant who was licensed 10 was from consulting fees in 2003? 10 by the state of Washington, DC, whose 11 A By what I put on my tax return, what I 11 responsibility was to complete returns based on 12 turned into the Internal Revenue Service, and from 12 information provided by the customer. I then hired 13 the receipts I have in my own files. 13 someone who was former head of the tax division for 14 Are you saying I'm a liar and that this 14 the United States Internal Revenue, and he went 15 is -- I did not make this money? I don't get what 15 back and redid 2004 and 2005. I gave him the same 16 your point is if it's sitting right here in front 16 receipts. So I guess they must be accurate. 17 of you. And it has a specific number and it says: 17 Q What's the name of the individual who 18 Reported to you on Form W-2 on the 18 redid your 2004 and 2005 tax returns? 19 statutory employee -- blah -- blah, blah, blah, 19 A It's on the tax return I gave you for 20 blah, blah, blah. 20 2005. You can get the correct spelling of his 21 Well, this is my gross receipts. My 21 name. It's Daniel Black, CPA. 22 gross receipts were 108,000 in 2003. My accountant 22 THE WITNESS: I have to go. I Page 302 Page 304 1 obviously added it up from numbers that I gave her 1 cannot stay any longer. You told me you were going 2 from receipts and so forth. I have the receipts. 2 to be two hours, and I'm sorry, I -- I can't -- I 3 That's what it is. 3 can't do this anymore. Because I -- I have things 4 What else? It's not from Fannie Mae. 4 I have to do. 5 It's not from Bob Jones. 5 MR. DANIELS: You have to do -- 6 Q You're not willing to provide those 6 THE WITNESS: So this is -- I've 7 receipts; is that correct? 7 given you now four hours more than you said it was 8 A No, I'm not giving you that. If it's 8 going to take, and had you told me it was going to 9 not from you, what do you care? Fannie Mae didn't 9 be six hours, I could've prepared for that. But 10 pay it. 10 I'm really sorry. I do have to make a living, and 11 Q Looking at your expenses in part two 11 I can't let you keep me -- 12 under legal and professional services expenses, you 12 MR. DANIELS: Can we -- can we 13 identified $19,793; do you see that? 13 set another date to finish up? 14 A Right, mm-hmm. 14 MS. BECKER: What is the basis 15 Q What is that for? 15 for your statement that we told you that this would 16 A I can't remember. It's paid to 16 be two hours? 17 individuals. The receipts are in the file. 17 THE WITNESS: You told me two 18 Q And again, you identified $10,000 in 18 hours the last -- when we left here the last time, 19 travel, meals, and entertainment expenses; do you 19 you said a couple of hours. 20 see that? 20 MS. BECKER: That's not what I 21 A Yes, I do. 21 said, ma'am. 22 Q Did you do anything to verify that 22 THE WITNESS: Well -- 44 (Pages 301 to 304) Esquire Deposition Services MD - 1-800-539-6398 D.C. - 1-800-441-3376 VA - 1-800-752-8979 a77cbcf5-7ff0-478d-a5f4-3a9a93751c41 Case 1:05-cv-01483-JDB Document 33-8 Filed 06/21/2007 Page 46 of 74 Marialice Williams Page 305 Page 307 1 MR. DANIELS: Marialice -- 1 original exhibits, by the way. 2 THE WITNESS: -- you can think 2 MR. DANIELS: Is she taking -- 3 that's not what you said; that is what you said to 3 MS. GRUNDEMAN: Yeah. 4 me. And if you didn't mean to say that, then you 4 MR. LEDERER: Marialice -- 5 said it inadvertently, which I will accept, but you 5 MR. DANIELS: I -- I'd say the 6 have to understand that I was -- 6 23rd or the 24th and we can finish up -- that -- 7 MR. DANIELS: We can do this 7 that'd be the end of everything. 8 again. 8 THE WITNESS: These are not for 9 THE WITNESS: -- led to believe 9 me? 10 that it was two hours by you -- 10 MR. LEDERER: There -- there -- 11 MR. LEDERER: You're supposed 11 their original marked exhibits. We have copies. 12 to -- 12 MR. DANIELS: And I -- I'll have 13 THE WITNESS: -- and if it was 13 an hour, hour and a half of cross-examination. 14 not two hours, you should have let me know. 14 MS. BECKER: We will check the 15 MR. LEDERER: You're going to 15 schedule and our calendars and make a determination 16 get the 2005 return. 16 as to whether we'll continue -- 17 MR. DANIELS: How can we finish 17 MR. DANIELS: Fair enough. 18 up without -- reasonably. I know he's anxious to 18 MS. BECKER: -- the deposition 19 file his -- his stuff, but -- 19 on those dates -- 20 MS. BECKER: When is -- 20 MR. DANIELS: Okay. Thank you 21 MR. DANIELS: Lawyers are 21 very much. 22 supposed to work this out. 22 MS. BECKER: -- or propose other Page 306 Page 308 1 VIDEOGRAPHER: Excuse me. 1 dates. Thank you. 2 MS. BECKER: When is your client 2 MR. LEDERER: Or -- or propose 3 available? 3 other dates and then -- that's fine. 4 MR. DANIELS: June -- 4 VIDEOGRAPHER: This testimony is 5 VIDEOGRAPHER: Do you want to 5 con -- ended for the day at 3:51:35. 6 stay on the record? 6 (Thereupon, at 3:52 p.m. the deposition was 7 MS. BECKER: Yes. 7 adjourned sine die.) 8 MR. DANIELS: Yeah, I think so. 8 (The witness reserved signature.) 9 MS. BECKER: When is your client 9 10 available for deposition to continue -- 10 11 MR. DANIELS: Well, my client's 11 12 available but I'm not. I -- I'll be back -- I'll 12 13 be back the 19th, so -- and we've got a status 13 14 conference on the 22nd. I -- I could do it -- 14 15 what is your schedule, Marialice? 15 16 THE WITNESS: I'm -- whenever 16 17 you all are available as long as you give me some 17 18 idea of the amount of time it's going to take. 18 19 MR. DANIELS: Okay. I -- you -- 19 20 you're my ride so hold on. And I don't know your 20 21 car -- 21 22 MS. GRUNDEMAN: We need the 22 45 (Pages 305 to 308) Esquire Deposition Services MD - 1-800-539-6398 D.C. - 1-800-441-3376 VA - 1-800-752-8979 a77cbcf5-7ff0-478d-a5f4-3a9a93751c41 Case 1:05-cv-01483-JDB Document 33-8 Filed 06/21/2007 Page 47 of 74 Marialice Williams Page 309 Page 311 1 1 Harley Jay Daniels, Esq. 2 2 Law Offices of Harley Jay Daniels 3 * * * 3003 Van Ness Street, Northwest 4 3 Suite W228 Washington, DC 20008 5 ACKNOWLEDGMENT OF DEPONENT 4 6 IN RE: WILLIAMS V. FNMA, ET AL. 5 CONTINUED DEPO OF: MARIALICE B. WILLIAMS 7 I, Marialice Bathrus Williams, do hereby 6 8 acknowledge I have read and examined the foregoing pages 7 Dear Mr. Daniels: 8 Enclosed for review is your copy of the above referenced 9 of testimony, and the same is a true, correct and deposition. Please have the deponent read the copy of 10 complete transcription of the testimony given by me, and 9 the transcript and sign the enclosed certificate of 11 any changes and/or corrections, if any, appear in the deponent. Also enclosed is an errata sheet which the 10 deponent should use to note corrections and the reasons 12 attached errata sheet signed by me. for such corrections. This and any additional errata 13 11 sheets should be signed and dated by the deponent. 12 The deponent has thirty days in which to read and sign 14 ____________________ _______________________ the transcript. After the deponent has reviewed the 15 Date Marialice Bathrus Williams 13 copy of the transcript, please return the certificate of 16 deponent and any errata sheets to 1020 19th Street, 14 Northwest, Suite 620, Washington, D.C. 20036. 17 15 Sincerely, 18 16 Joanne Liverani 17 19 18 20 19 20 21 21 22 22 Page 310 Page 312 1 CERTIFICATE OF NOTARY PUBLIC 1 ESQUIRE DEPOSITION SERVICES 2 I, Joanne Liverani, the officer before whom the 1020 19TH STREET, NORTHWEST 3 foregoing deposition was taken, do hereby certify that 2 SUITE 620 WASHINGTON, D.C. 20036 4 the witness whose testimony appears in the foregoing 3 5 deposition was duly sworn by me; that the testimony of ERRATA SHEET 6 said witness was taken by me in stenotype and thereafter 4 7 reduced to typewriting under my direction; that said Case Name: WILLIAMS V. FNMA, ET AL. 8 deposition is a true record of the testimony given by 5 Witness Name: MARIALICE BATHRUS WILLIAMS 9 said witness; that I am neither counsel for, related to, Deposition Date: 5/7/07 10 nor employed by any of the parties to the action in 6 Job No.: 180771 11 which this deposition was taken; and, further, that I am 7 Page No. Line No. Change 8 12 not a relative or employee of any attorney or counsel 9 13 employed by the parties hereto, nor financially or 10 14 otherwise interested in the outcome of this action. 11 15 12 16 13 Joanne Liverani, 14 17 Registered Merit Reporter 15 and Notary Public for the 16 17 18 District of Columbia 18 My Commission expires: 19 19 July 31, 2010 20 20 21 _____________________________ ____________ 21 Signature Date 22 22 46 (Pages 309 to 312) Esquire Deposition Services MD - 1-800-539-6398 D.C. - 1-800-441-3376 VA - 1-800-752-8979 a77cbcf5-7ff0-478d-a5f4-3a9a93751c41 Case 1:05-cv-01483-JDB Document 33-8 Filed 06/21/2007 Page 48 of 74 Marialice Williams Page 1 A acted 166:20 184:7 185:16 186:17 290:7,16 291:17 AAA 153:17 action 132:6 African-America... 197:2 263:10 294:3 296:7 ABA 256:1,10 186:18 310:10,14 179:13,15 180:3 283:1,2 284:21 answered 259:21 ability 169:6,8,9 actions 199:13,17 agency 297:13 285:13 283:13 287:1 183:8 199:17 aggregation 200:22 amendment 190:8 289:8,17 able 138:22 139:4 active 193:7 256:2 206:8,20 207:4 190:10 answering 249:20 146:15,20,21 activities 187:16 221:5 225:10 America 178:16 answers 136:11 153:14 168:4 actual 153:5 227:3 228:3 230:20 259:18 198:4,15 205:13 169:10,19,20 195:18 213:6 ago 147:6 202:3 260:15 249:12 278:12 170:9 211:13 226:20 227:2 238:10 255:16 American 171:11 answer's 259:22 225:12 247:14 234:14,16 247:5 277:20 229:4 255:5,16,18 anxious 305:18 absolute 147:9 270:21 agree 176:8 186:11 255:21 257:7,11 anybody 178:16 absolutely 172:14 add 194:17 199:11 209:16 252:14,16 259:13 260:6 183:17,21 191:8 188:19 202:6 234:15 258:19 253:13 amount 153:5 191:14 247:20 219:22 239:20 271:7,10,15 272:7 agreed 295:20 183:8 206:22 276:7 297:10 accept 305:5 added 271:11,14 agreement 186:1,3 220:1 224:16 anybody's 181:5 access 156:12 273:8,9 276:11,12 187:11 188:3,18 227:20 237:4 anymore 304:3 219:8 256:19 302:1 190:7 191:4,8,15 268:15 270:21 anyway 204:5 accommodate adding 271:18 197:6,7 207:8 271:7 295:1 301:7 215:7 282:5 additional 145:21 208:4,10 210:16 306:18 Aon 270:5 accomplish 169:20 194:17 199:5,10 210:22 211:14,20 amounts 250:10 apartment 162:13 accomplishments 311:10 212:1,2,7,21 andually 225:3 229:20 230:7,9,19 189:15 addresses 251:12 213:1,9 215:18 and/or 309:11 230:21,21,22 account 226:5 adds 303:4 224:3 240:15,21 announced 175:22 231:15 accountant 261:14 adhered 215:3 243:15 245:9 annual 225:1 226:3 apologize 296:8 263:4 271:11,16 adjourned 308:7 agreements 197:12 226:9 227:13 apparent 225:15 272:7 273:7,7 administrative 210:12 225:22 annually 224:19 appear 309:11 285:21 286:2 275:15 297:6 ahead 260:21 283:4 225:3 APPEARANCES 300:5 301:22 advantage 240:5 290:6,15 anonymous 206:9 134:1 303:3,4,9 advice 240:12,14 al 132:12 134:16 answer 167:18 appears 250:20 accounting 228:21 241:19 243:22 137:5 138:16 198:7 199:3,4,9 286:14 290:20 accurate 148:10 245:15 265:3 198:17 311:4 199:11,12 202:11 310:4 198:22 206:3 affairs 136:13 312:4 202:17 206:1,7 approached 200:11 223:20 235:3 248:11 249:14 Alexander 270:7 207:5 210:8 216:1 approximately 298:18 303:8,16 266:19 alive 288:2 216:14 218:6 147:6,7 224:21 accurately 204:21 affect 176:19 204:1 allegations 187:18 221:19 225:12 April 140:2 142:15 272:12 affidavit 231:11 187:22 188:14 229:12 241:20 142:17 143:3,5,20 achievements afford 161:16,17 allege 224:3 243:19 244:22 145:3,10,12,22 180:22 affordable 154:19 alleged 187:12 245:3,6,7,14,17 146:9,11 149:16 acknowledge 309:8 155:1 171:15 allegedly 211:14 245:21 260:20,21 149:20 150:6 ACKNOWLED... 182:16 215:4 alleging 227:9 262:10 263:18,20 163:14 309:5 228:3 256:2,16,19 allow 208:6 264:22 265:5 area 143:9 157:17 acquired 161:6 257:3 amend 206:1 272:20 278:2 158:15,19 159:13 162:10 African-American 285:20 300:7 279:17 287:17 159:22 160:4,7,11 171:13 179:2,3 amended 136:10 288:6 289:6,13,20 171:15 230:4 Esquire Deposition Services MD - 1-800-539-6398 D.C. - 1-800-441-3376 VA - 1-800-752-8979 Case 1:05-cv-01483-JDB Document 33-8 Filed 06/21/2007 Page 49 of 74 Marialice Williams Page 2 areas 181:18 assumed 220:15 award 174:16,19 136:15,16 161:4 138:2,2,17 139:8 arranged 175:18 assured 182:1 175:9,19,20,21 161:14,22 162:1,3 139:15 147:11,18 arrangement Atlanta 193:14 177:16 162:4,7 248:2,12 147:22 150:16 212:17 attached 309:12 aware 158:10 249:10 250:5 151:4 168:10 arrangements attachments 170:16 171:9,10 253:11,21 254:1 185:6,13 186:5,14 225:6 249:14 174:21 199:14 254:14,21 259:6 197:14,22 198:8 arranging 238:13 attempted 156:18 200:5,8 216:19 260:14 271:4 198:11 209:2 arrived 168:19 attempting 166:16 246:21 Bar 171:11 255:21 210:20 212:11 172:9 185:5 171:14 196:21 awful 241:9 based 160:18 165:9 213:7 216:3,12 arrows 195:17 attended 242:14 a.m 133:5 137:9 170:1 177:11,14 218:9 219:11 art 275:2 attention 140:11 177:15 181:15 221:8,12,17,21 aside 153:6 152:4 167:7 B 183:19 199:16 235:22 237:9,12 asked 151:13 191:17 196:14 B 252:22 253:7 224:15 226:8 237:18 241:21 165:14,16 171:18 199:2 202:10 311:5 228:7 234:13 242:3 244:1,4,14 203:1 205:7 221:18 224:1,12 back 147:1 158:21 271:8 276:2,3,3 244:20 245:18 213:13 218:2,4 229:11 237:19 172:2 173:7 277:18 303:11 248:5,9,16 250:1 245:13 265:6 250:21 254:15 193:10 210:2 bases 187:13 253:17 254:7 272:19,19,19,20 267:17 291:3,12 212:11 218:9 basic 192:12 259:3 261:15,19 287:1 289:16 292:1 298:6 221:15 259:11 basically 167:13 262:1,11,14,18 asking 142:9 attitudes 179:5 284:6,9 292:8 188:20 213:15 263:22 264:4,8,17 164:20 203:6 attorney 165:2 300:7 303:15 230:17 264:21 265:11,17 259:8,10 260:21 194:8 198:20 306:12,13 basis 175:17 265:22 266:8 266:18 287:16 238:17 241:19 backed 234:21 187:19 188:15 267:1,5,13,16 288:19 290:1 242:16 249:10 backstabbing 224:18,20 231:19 269:12 272:22 295:22 252:8 253:4,11 279:10 240:9 244:1 274:2,4 278:7 asks 143:5 290:14 279:13 287:9 backup 232:21 262:15 264:1,5,9 279:22 281:5,16 assessed 153:1,3 310:12 233:6 234:2 268:6 264:18 267:2 282:10 283:17 assessing 226:5 attorneys 198:20 272:6 279:5 271:19 272:2 284:10 285:9 assessment 176:9 208:6 288:15 292:19 275:3 277:1 287:2,7 288:18 asset 251:8,9 attorney's 265:2 293:14 295:15,16 278:19 289:14,20 289:1,14,19 291:2 assign 169:12 attorney-client 296:7 304:14 291:22 293:21 assignments 244:5,10 balance 145:17 Bates 132:8 136:6,9 294:4 296:17 180:14,16,21 attribute 178:20 162:5 227:18 139:12 150:19 297:22 298:5,10 181:8 aturn 286:9 236:6 Bathrus 132:4,16 298:13 304:14,20 assistant 235:2,4 auction 157:10 ballpark 246:11 133:7 134:2 136:4 305:20 306:2,7,9 297:19 August 157:16 Baltimore 210:17 137:3,4 138:11 307:14,18,22 associate 246:5 201:21 242:2 Bank 230:19 186:18 198:16 becoming 177:21 associated 154:4 authorized 173:6 259:18 260:15 216:5,10 309:7,15 began 158:4 170:5 Associates 232:6 automobile 242:7 bankcard 260:15 312:5 176:5 298:15 available 285:6 Bankers 256:4 bear 270:6 280:7 beginning 250:19 Association 132:11 306:3,10,12,17 banking 193:9 Beasley 239:9 251:14 134:16 137:5 Avenue 135:3 195:1 246:18 242:12 begins 137:2 138:16 171:12 144:19 273:17 247:3,7 Becau 262:8 behalf 137:15 255:21 256:4 average 234:7,14 bankrupt 279:9 Becker 134:21 138:3,6,9 assume 250:16 234:18 270:18 bankruptcy 136:13 136:3 137:12 believe 141:3,14 Esquire Deposition Services MD - 1-800-539-6398 D.C. - 1-800-441-3376 VA - 1-800-752-8979 Case 1:05-cv-01483-JDB Document 33-8 Filed 06/21/2007 Page 50 of 74 Marialice Williams Page 3 142:5 144:3 145:5 bit 144:5 213:19 212:3 224:9,9 299:19,20 224:3 242:17 145:9 146:2 147:7 black 178:19 179:7 269:21 businesses 251:14 243:3 148:11 149:18 179:11 200:16,22 brokerage 192:8 251:15 Cam's 219:21 151:22 155:15,19 303:21 brokered 202:8 Buyer 207:3 capability 183:6 156:22 157:15 blackballed 196:17 brokers 199:15 capable 200:6 160:9,22 161:2 blah 301:19,19,19 broker's 201:19 C capacity 181:8 162:16 165:4,8,20 301:19,20,20,20 224:21 C 136:1 241:18 242:5 166:6 169:7,9 board 183:2 brought 192:6,9 calculate 224:13 capital 178:13 170:12 173:18,20 Bob 164:19,21 225:20 226:10 229:14 182:16 222:19 177:5,6,10 184:8 165:7,9,10 166:20 building 158:3,13 232:9 233:10 232:1 188:1 189:17,20 167:1,5 168:7 230:5,7,11 234:13 captive 155:14 191:11 196:17 175:13 193:15 business 161:5,6,18 calculated 224:15 191:19 192:13,19 197:8 199:1,5 197:1,12 203:7,8 162:9 167:2 228:11 192:21 193:12,13 201:21 202:5,13 203:9 206:6,14,18 169:11 171:14 calculating 205:4 193:16,19 194:19 205:7,13 206:3 208:15 210:17 177:1,3 178:12 calculations 226:6 195:4,6,8,19 207:12,20 208:9 211:6 212:18,18 181:22 194:13 226:8 196:4 210:19 217:4 224:10 214:5,7,17 215:12 199:22 200:6,10 calculator 273:7 219:6 229:6 247:7 226:22 234:20 216:15,17 219:13 200:14,19,22 calendar 250:11 captives 195:2 235:9 236:3,19 222:2,21 223:11 203:2,3,3,4,7,9,10 calendars 307:15 car 306:21 241:4 242:13 225:21 226:4,10 203:16,18,19,20 California 234:11 card 254:20 255:5 247:13,18 248:7 231:20 246:5 204:3,9,11,17,20 call 168:7 190:22 255:18 259:18 249:22 256:1 302:5 205:11,11,12,12 191:1 253:10 260:1,2,5,6 258:22 265:11 Bob's 228:8 205:17 206:4,6,11 278:1 cards 260:2 261:1 267:13 270:21 bona 276:15 206:19,21 211:21 called 138:12 care 189:14,14 273:21 275:2 Bond 207:3 213:3,12,16 214:4 153:22 191:2,9,11 302:9 298:22 305:9 bookkeeper 271:17 214:7,12,13,14,16 191:13 223:12 career 179:22 believed 183:18 boss 240:1 215:6,16,19 229:10 180:6,15,22 240:8 box 142:6 144:18 216:18,22 217:1,5 calls 156:8 235:16 184:17 bell 288:14 144:21 159:5 217:7,9,13,16,19 Cam 139:18 142:16 carefully 284:19 best 236:17 251:3 217:20 218:3,4,5 143:3 145:13 Carol 194:9 bet 287:21 boxes 142:18 143:9 220:1,4,5,19,20 149:21 151:7 Carolyn 194:9 better 178:5 179:21 156:14 158:18,19 223:4,7 224:16 163:8,12,16,17,19 case 136:15 137:7 211:17 271:17 158:22 159:13 225:17 229:20 163:21 164:6,19 159:19 187:3 Betty 179:8 220:13 160:1 231:3 235:16,16 167:21 182:20,22 198:16 200:4 221:3 Boy 248:14 238:5,8,14 250:9 183:7 197:4,13 206:18 224:14 beyond 145:21 break 180:14 251:7,9 252:17 203:2,3,14,16,17 226:6,11 246:19 194:1 235:8 221:11 237:10 253:13 255:8,9,10 203:19,22 204:2,4 253:21 265:13 big 174:18 211:11 Brian 134:10 255:17 256:7,9 204:14,22 207:8 266:1 312:4 biggest 174:13 137:22 191:2 257:7,21 259:4,19 208:5,11 210:22 cash 154:22 254:5 bill 257:11,12 239:9 240:18 260:4,12,16 261:3 211:15 212:8 casual 173:11 billion 225:2,16 bring 170:9 261:7,12 267:11 213:9,11,15,16 category 140:15 226:19 227:13,14 broke 204:17 270:3,14 275:17 214:2 217:4,9,12 cause 152:13 bills 232:12,19 broker 181:22 276:8,15 287:22 217:15,18,20 180:10,12 188:22 233:3,8 260:3,6 199:21 200:12 288:2 292:2,10 218:1,3,3,12,21 211:7 214:16 bin 157:5 201:16,17 206:10 298:14 299:2,19 219:7,8 222:1 268:2 280:10,22 Esquire Deposition Services MD - 1-800-539-6398 D.C. - 1-800-441-3376 VA - 1-800-752-8979 Case 1:05-cv-01483-JDB Document 33-8 Filed 06/21/2007 Page 51 of 74 Marialice Williams Page 4 caused 177:8 charges 187:13 133:15 136:14,16 compensation 173:5 174:18,21 241:11 charging 195:9 137:7 193:20 168:5 190:7 175:2 230:4 Cayman 193:17 charter 182:18 248:12 254:1 compete 168:3 256:10 296:18,21 cc 196:22 chartered 215:3 310:18 competitive 176:16 306:14 cell 195:6 232:16 cheating 279:10 com 148:22 196:19 complaint 136:10 conferences 235:17 cells 195:4 check 251:5 260:3 come 196:9,9 179:20 183:10 255:21 256:4,14 ceremony 175:13 292:8 307:14 213:20 221:15 184:17 185:17 confidentiality certain 143:7 checked 251:3 256:22 270:9 186:17,21 187:3,6 186:1,3,12 197:6 152:22 153:4 checks 260:6 272:7 276:20 191:18 196:15 225:21 165:3 166:20 children 179:6,10 287:11 292:16 197:2 connection 151:14 170:21 178:18 Chris 232:1 297:6 complaints 183:15 155:17 186:2 179:4 182:21 Chuck 172:6 173:8 comes 261:13 complete 199:4,10 238:19 240:15 185:20,22 202:6 173:9 174:1 coming 276:17 206:7 252:8 242:9 243:2,12 206:18 229:13 cities 181:18 comma 292:12 303:11 309:10 244:16 283:8 234:18 239:1 city 257:1 commercial 232:16 completely 203:20 considerable 156:7 certainly 152:15 civil 132:6 186:18 276:7,9 277:22 269:10 277:7 consistent 181:2 178:18 183:1,12 187:17 commission 213:3 complex 195:14 269:10 270:17 183:20,22 188:8 claim 188:8 202:21 310:18 complexity 158:1 271:6 193:22 196:12 215:17 commissioner complicated consistently 168:2 205:15 206:12,13 claimed 259:1 194:22 246:20 195:13 234:5 276:17 212:19 213:22 297:3 247:2 computer 143:10 consolidate 158:20 222:16 224:8 claiming 275:12 commissions 212:5 144:8 146:17,22 constantly 270:1,3 252:9,9 253:9 claims 200:3 commitment 147:4 150:1,5 270:8 278:1 300:12 247:12,21 254:17 176:22 156:11 157:2,4 constitute 141:5,16 certainty 147:9 255:4 Committee 256:2 158:8 160:19 constituted 187:16 certificate 310:1 class 256:21 common 167:20,21 263:4,5 288:10 consult 186:6 311:9,13 classes 177:20 168:11 computers 150:8 consultant 235:5 certify 310:3 clear 166:13 212:4 communicated 150:15 160:15 269:20 292:10,12 cetera 168:6 183:2 236:11 288:14 222:1 276:11 300:17 183:2,2 193:4,5 clearly 175:16 communication con 238:14 308:5 consultants 219:5 223:4 240:6 clerk 206:16 238:1 196:20 285:3,8 concept 181:15 consulting 300:16 ch 260:5 238:22 communications 192:13 193:10,16 300:18,19 301:2 chairman 255:22 client 186:6 244:10 141:6,17 245:20 195:3 196:4,5,7 301:10 chairperson 256:10 306:2,9 communities 197:1 200:7 contact 164:5 champion 180:9,12 clients 149:11 181:17 225:18,19 229:6 194:13 196:21 change 170:4 196:6 256:5 comp 173:2 238:15 218:15 270:2,4 180:20 182:8 client's 306:11 companies 149:9 concepts 180:18 contacted 164:15 312:7 close 148:8 159:15 191:20 192:19,21 246:22 256:22 164:16 165:18 changed 170:13,14 184:5 246:5 192:22 193:17 concerned 170:19 contained 249:13 changes 309:11 closed 201:3,5,7,12 197:13 218:14 170:21 181:17 contempt 168:9 Chapter 136:15 225:3,9,10 277:18 203:8 continuation 253:21 collateral 152:11 company 139:20 concerning 285:3 138:20 charge 166:22 155:10,13 152:16 190:14 concluded 242:14 continue 182:2 charged 188:3 Colorado 273:17 193:1 210:18 conference 171:12 185:19 204:4 226:13 227:2 Columbia 132:2 212:15,16,19 171:16 172:1,7 218:5 306:10 Esquire Deposition Services MD - 1-800-539-6398 D.C. - 1-800-441-3376 VA - 1-800-752-8979 Case 1:05-cv-01483-JDB Document 33-8 Filed 06/21/2007 Page 52 of 74 Marialice Williams Page 5 307:16 236:13 239:16 207:8 208:4,10 307:13 265:15,20 266:7 continued 132:15 249:15 252:12,22 210:22 211:14 cross-section 266:20 267:3,8,15 133:7 193:20 268:7,11 283:19 212:7,21,22 213:9 149:10 268:21 269:2,6 196:21 311:5 288:13 291:6 215:18 224:2 currently 159:16 272:14,18 280:7 continuing 193:21 292:3,5 296:1 co-op 158:16 custody 157:9 280:12,16,20 203:2 302:7 303:20 CPA 286:2,9 customer 303:12 281:12,20 282:7 contractor 237:8 309:9 303:21 customers 195:9 283:16 284:6 contributions corrections 309:11 Craig 200:15,17 228:21 285:2 286:22 188:19 311:10,10 206:5,12,13 207:2 cutting 223:16 287:4 288:21 conversation correspondence 221:4 cynical 223:16 289:5,8,12,16,22 181:13 184:2 136:8 147:16 crap 189:10 214:10 290:6,10,15 185:1 219:12 196:20 241:3,11 278:20 D 291:17,20 293:16 246:8 corresponding crappy 241:12 d 139:8 294:2 298:11 conversations 272:10 crash 143:10 daily 231:19 304:5,12 305:1,7 216:15,17,20 cost 232:11,17,18 148:12,20 158:8 Dallas 234:10 305:17,21 306:4,8 222:2 223:21 233:2 crashed 148:16 damages 205:5 306:11,19 307:2,5 convince 169:10 costs 233:11 276:9 crashes 146:17 224:14 226:6,11 307:12,17,20 219:1 278:5 147:4,5 148:3,6 228:11 265:13,18 311:1,2,7 convinced 169:12 could've 189:10 148:22 157:2,4 265:21 266:16 Danny 209:12 260:11 228:1,2 243:4 160:19 267:14 data 181:1 Conway 237:21,22 304:9 crazy 279:1,1 Dan 263:5 database 181:1 cooperate 165:6 counsel 137:18 created 152:13 Dana 274:13 date 137:8 140:1,2 166:3,4,6 138:12,15 194:11 153:10,12 156:11 277:13 282:18 148:5 151:11,12 cooperation 164:20 242:18 244:12 170:7 174:15 Dance 179:8 241:22 242:10,20 cooperative 169:17 246:2 310:9,12 175:15 180:18 220:13 221:3 243:2 250:7 copiers 232:14 counsel's 294:5 181:4 204:9 211:9 Daniel 303:21 281:15 291:9 copies 185:20 Countrywide creating 181:1 Daniels 134:3,8 304:13 309:15 263:2 284:18 234:11 credibility 266:1,2 137:20,21 150:22 312:5,21 307:11 couple 192:11 266:6,15 267:14 167:15,17 185:18 dated 142:15 copy 196:2 210:15 278:14,15 304:19 credit 149:13 186:10 198:6,10 151:20 253:8 252:5 262:2 263:2 course 220:15 152:10,15 153:1,1 206:16 208:14,18 311:11 263:7 284:15 233:5 268:9 153:18 154:2,8 208:22 209:22 dates 147:4 148:10 288:9,11 291:5 court 132:1 136:13 155:12 167:11 210:5,8 221:6,10 219:14 223:21,22 311:8,8,13 136:16 137:6,15 184:4,10 192:4,4 221:14,20 235:18 236:14,16 251:14 corporate 171:3 139:9,18 147:12 195:6,7,8,19 238:2 239:2,10,12 307:19 308:1,3 178:16 150:17 198:1 225:6 227:6 239:13,15,18 day 139:3 168:22 corporation 251:17 202:14 225:14 254:20 259:22 240:7,11,20 180:22 209:4 corporations 248:6,12 253:18 260:1,2,5,6 261:1 241:14,16 242:2,4 212:3 230:10 192:18 254:1 261:16 creditors 136:15 242:8,12 243:7,16 234:4 235:7,7 correct 146:1,2 278:8 281:6 298:1 253:22 254:16,22 243:18,21 244:2,7 260:11 308:5 148:10,15 150:13 courtesy 178:4 255:3 244:9,15,19,21 days 164:4 311:12 151:12 157:20 cover 153:7,20 credits 155:3 245:2,7,8,13,20 day-to-day 175:17 164:12,13 166:1 198:8 279:11 crew 204:8 258:9 262:9,12,16 DC 132:17 133:12 186:22 187:3,4 coverage 153:15,18 cronies 178:14 263:19 264:2,6,12 134:6,12,19 135:4 205:17 227:21 co-brokerage cross-examination 264:16,19 265:4,8 136:16 137:11,17 Esquire Deposition Services MD - 1-800-539-6398 D.C. - 1-800-441-3376 VA - 1-800-752-8979 Case 1:05-cv-01483-JDB Document 33-8 Filed 06/21/2007 Page 53 of 74 Marialice Williams Page 6 193:8,11,13 194:3 146:5 159:18 310:11 311:8 279:4,16 290:22 240:19 194:18,20 246:17 198:4,15 312:1,5 297:18 299:3,3 disposal 175:5 247:2 254:1 defending 164:18 depositions 242:14 differently 177:11 disposed 158:12 273:20 300:21 164:21 165:7 derived 226:20 183:18 disrespectful 301:1 303:10 define 152:9 dervish 214:22 difficult 159:4,14 179:10 311:3 defined 187:16 describe 174:11 231:10 dissolved 298:20 Deadlines 136:15 275:2 204:21 Diggs 135:9 137:14 distributing 197:10 253:22 defines 152:7 described 154:7,15 dime 215:1 District 132:1,2 deal 142:17 154:9 definitely 178:17 160:19 207:21 direct 152:4 199:2 133:15 136:14,16 158:22 159:16 272:3 211:16 208:7 262:10 137:6,6 139:18 174:18 183:4 delivered 142:6 description 211:17 263:20 265:4 193:19 248:12 201:3,5,7,9,11 demonstrate deserved 167:2 267:17 289:6 254:1 310:18 205:10 207:14 203:12 designed 153:19 directed 139:21 diversity 184:14 212:6 240:12 department 246:17 204:8 directing 237:19 division 169:13 269:22 270:1 246:21 247:2,6 desire 277:3 291:3 174:5 175:5 184:7 dealing 178:21 300:21 301:2 destroy 214:1 direction 239:3 192:5,6 303:13 deals 155:2 201:1 departure 187:15 detail 157:22 310:7 divorce 241:22 206:10 227:10,11 188:4 244:17 287:12 directly 170:5 DMP 273:17 274:5 227:21 228:1,12 depend 213:5,5 deterioration 159:9 265:12,13 274:7,9 277:14 228:13,16 229:10 Depended 212:15 determination director 175:4 282:18 Dear 311:7 depending 218:14 307:15 178:13 251:16 doc 142:6 death 242:15 depictions 196:3 determine 294:15 253:14 document 140:20 Deborah 175:3,4,6 DEPO 311:5 301:9 disabled 257:1 141:1,4,9,12,15 debt 162:9 deponent 309:5 determined 153:4 DISB 193:8 141:22 142:3 debtor 249:1 311:8,9,10,11,12 develop 256:9 discouraging 217:4 151:19 155:6,6,7 251:11,15 311:12,13 developed 170:7 217:9 155:17 198:12 debtor's 251:21 deposed 151:6 177:1 180:18 discover 214:11 207:19 208:4,7,20 debts 161:5 254:20 164:1 242:18 200:8 224:17 discovery 208:5 209:6 238:16 December 243:1 243:2 225:19 discriminated 248:17,20 249:5 decided 173:9 deposition 132:15 development 240:8 250:17,22 252:12 177:3 228:19,20 133:7 136:5 137:3 165:10 167:8 discrimination 254:8,10,12 decision 186:7 137:9,16 138:21 169:18 183:9 183:11 187:12,19 282:13,17 decisions 272:8 139:12 147:14 196:11,22 215:2 188:15 189:21 documentation decline 245:21 150:19 151:9,14 developments discriminatory 164:17 231:16 264:22 265:9 154:10 156:6 192:17 200:20 232:21 233:7 deduct 193:4 165:16 175:14 devices 152:12 discuss 186:7 234:2 257:6 268:6 deducted 257:12 185:16 186:8 di 195:12 192:12 239:18 288:15 293:14 deductible 193:2 198:3 208:9,15 diagrams 195:12 240:17 241:6 documents 140:5,8 defamatory 221:22 209:5 238:12 195:17 discussed 184:6 140:14,16,17,19 222:3,10,14,16 242:15,17,21 die 308:7 196:6 241:8,8 140:22 141:5,8,11 223:17 243:5,10 248:10 died 159:2 discussing 195:2 141:16,21 142:2,6 defective 242:7 253:20 261:20 difference 181:16 discussion 216:7,21 142:13,14,16 defendants 132:13 281:9 285:7 298:2 different 146:16 268:2 143:8,18 144:7,10 134:15 136:11 306:10 307:18 190:3 235:11 discussions 178:12 144:13,17,18 138:13,15 145:18 308:6 310:3,5,8 246:6 275:19,20 193:20,21 220:12 145:2,3,10,11,19 Esquire Deposition Services MD - 1-800-539-6398 D.C. - 1-800-441-3376 VA - 1-800-752-8979 Case 1:05-cv-01483-JDB Document 33-8 Filed 06/21/2007 Page 54 of 74 Marialice Williams Page 7 145:21,21 146:3,4 E 149:13 152:16 eventually 189:15 exhibit 139:10,12 146:5,8,21 148:17 e 136:1 220:13 153:18 190:6 everybody 178:4 139:16,17 140:12 149:3,5,16,19 255:1 195:6,8,19 225:6 248:14 270:13 140:13 147:13,14 150:4,5,6,10 earlier 143:11 entertainment everybody's 279:15 147:18 150:18,19 151:13,16,18,19 156:6 186:13 270:16 271:8,21 everyplace 256:18 151:5 152:5 152:1 155:9,16,21 241:8 270:20 272:4 273:3 295:7 evidence 210:21 185:15,16 186:16 157:5,18 158:5,8 early 157:16 295:10 302:19 276:19 198:2,3 202:13,15 159:18 160:6,10 165:22 entire 167:8 204:19 evidently 216:20 202:16,16,20 186:4 205:9 earnest 158:4 213:4 287:22 ex 285:6 204:21 207:21 225:13 231:2 easier 144:6 entitled 226:15 exact 165:15 208:1,10,12 dog-eat-dog 170:2 easy 180:2 265:19 184:18 211:13 209:10,11 211:16 doing 157:6 171:19 Edward 135:9 entity 299:8,10 219:14 234:19,20 211:18,20 221:9 178:1,2 182:17 137:14 entry 272:9 236:16 237:4 248:6,10 253:19 183:6 199:21 EEO 179:17,20 envelopes 234:22 242:10 289:17,17 253:20 259:8 200:6,14 203:19 effect 184:19 environment 170:2 exactly 165:3 261:16,20 280:1 206:20 213:12,16 effectively 168:3 171:3 170:15 207:13 281:6,9 298:1,2,7 214:5,7,13,14 eight 152:6 environmental 211:20 225:5 exhibits 136:5 215:1,3,6,14 either 150:7 161:1 154:20 155:11 253:9 287:14 209:4 307:1,11 216:18,22 217:5,9 180:14 193:17 equipment 232:10 examination 136:2 exist 179:5 217:20 220:19 195:3 215:14 equity 154:21 136:3 138:12,15 existed 224:3 235:5 253:10 250:7,19 299:1 228:2 examine 285:7 299:16 257:2 282:4 eking 162:6 errata 309:12 examined 138:14 expense 233:15 dollars 225:16 embarrassment 311:9,10,13 312:3 309:8 257:10,13 276:19 230:15 177:6 escaping 193:15 example 177:19 expenses 193:1,4 downhill 172:4 employed 141:18 Esq 134:8,10,21,22 179:4 223:12 229:13 231:1,1 Downing 237:21,22 236:14 310:10,13 135:6 311:1 exchange 152:18 233:12 234:3 263:6 employee 192:15 Esquire 137:16 exchanging 152:19 255:8,11,14 DPM 283:8 301:19 310:12 312:1 excited 175:6 256:11 257:7 dragging 277:5 employees 177:21 essentially 213:12 exclude 204:9 259:14,19,20 dried 158:11 employer 170:17 estate 153:2 251:8 excluded 178:10,12 260:16,17 261:3,3 due 158:9 170:17,18 171:4 251:10 203:21 261:7,10,12 dues 296:11 273:20 estimate 236:17 excluding 199:15 268:14 270:16 duly 310:5 employers 168:21 237:5 exclusive 212:16 271:8,21 273:3 duplicates 150:1 employment et 132:11 134:16 exclusively 255:10 275:12 276:2 DUS 154:19 155:4 141:20 187:10,15 137:5 138:16 exclusivity 197:6 294:8,16,22 295:7 205:8,11,12,17 250:8 168:6 183:2,2,2 excuse 151:7 295:10 296:9,16 220:14,16,20 enabled 168:2 193:4,5 198:17 152:18 206:15 296:19 302:11,12 225:4 227:5,9,11 enables 152:16 223:4 240:6 311:4 209:12 216:2 302:19 227:21 228:1,3,4 enabling 176:14 312:4 306:1 experience 200:21 228:12,13,16 enclosed 311:8,9,9 Europe 270:7 execution 270:10 expert 195:2 229:7 246:6 ended 308:5 Evelyn 134:21 executive 251:16 expire 202:2 224:8 dusk 229:7 enhanced 189:5 137:12 138:2 253:15 expired 224:3,5 DUS-related 227:6 287:1 288:22 exercise 189:8 expires 310:18 154:14 enhancement 289:9 exhaustive 142:22 explain 152:14 D.C 311:14 312:2 event 189:9 212:6 143:2 156:18,20 182:10 224:13 Esquire Deposition Services MD - 1-800-539-6398 D.C. - 1-800-441-3376 VA - 1-800-752-8979 Case 1:05-cv-01483-JDB Document 33-8 Filed 06/21/2007 Page 55 of 74 Marialice Williams Page 8 252:3 274:22 Fam 218:21 204:20 205:9,14 226:20 228:14 207:9 213:11,15 276:1 292:9 fame 188:8 205:16 206:5,12 300:16,18,19 213:17 217:5,16 explained 193:10 familiar 173:10 206:19 207:19 301:3,10 217:18,21 218:2,3 193:11 212:21 218:19 211:7 212:7,22 felt 167:20,22 218:3,13 219:7,8 283:20 287:5,15 family 155:12,13 213:8,10,15 214:2 168:12 170:19 242:17 248:11 297:5 157:8 173:10 214:3 215:2,13,18 177:7 179:2 249:13 266:15,19 explaining 149:12 Fan 228:15 216:18,21 217:4,6 182:17 financially 310:13 express 172:15,21 Fannie 135:2 138:3 217:8,12,15,15,18 fide 276:15 find 143:14 159:5 255:5,17,18 257:8 138:6,9 140:18 218:2,18,20 field 213:20 207:4,4 231:9,10 257:11,12 259:13 141:7,19,20 142:6 219:21 220:2,3,17 figures 266:16 288:4 260:7 146:8,19 148:18 223:10 224:16 file 179:20 183:10 fine 170:6 279:13 expressed 179:6 149:5 151:7 225:1,8,11,20 183:15 184:16 288:13 308:3 extend 189:7 152:17,20 153:12 226:1 227:14 227:16 233:21,22 finish 144:4 245:5 extent 142:13 153:16 154:8,18 228:15,22 230:18 248:2 260:14 280:21 281:1,15 190:4 212:1 156:15 158:2,5 231:21 234:4 262:6 271:13 281:16 304:13 219:21 225:7 160:14 161:6,19 238:9,14 239:16 290:22 302:17 305:17 307:6 227:4 240:17 162:6 164:5,7,18 240:12,16 242:9 305:19 firm 137:10 164:12 extra 256:8 164:18,21 165:7,8 243:12,15 244:16 filed 161:4,21 171:6,7,10 173:2 extraordinary 165:12,13,14 245:9,21 247:15 162:1,3,4,7 163:9 276:9 281:8 231:1 166:2,4,7,10,19 256:4,9,12,13,13 186:21 225:14 first 153:10 163:12 extremely 193:7 168:3,17 169:3,12 256:18 257:8 250:5,17,18 163:16 169:15 eye 133:11 134:18 169:14,18 170:8 259:15 260:5,12 254:21 258:13 181:1,14 188:2 275:22 170:10 171:14,19 268:2 270:12 262:4,22 263:10 201:3,15,18 e-mail 136:7 172:9,13 173:6 279:11 287:21 263:12,16 265:20 220:10 221:1 147:14,19 148:1,4 174:4,9,18 175:14 288:2 293:11,18 266:12,13,14,16 230:2 235:12 220:13 221:2 176:7,8,12,14,18 299:20,21 302:4,9 272:6,12 276:18 236:9 242:4,8 e-mails 146:14,19 176:21 177:11 far 160:13 192:18 277:9,14 283:11 243:6,7,11 244:13 149:8 156:7,21 179:2,14 180:3,12 194:1 243:13 283:12,14 284:1,3 244:15 251:19,20 160:13,18 196:22 180:13,17,20 246:1 271:15 284:12,14,21,22 286:10 181:10,11,12,20 fast 169:19 226:17 285:10,16 286:15 five 164:3,3 205:22 F 182:3,5,15 183:11 father 231:11 288:9 289:3 213:19 227:17 F 254:16 255:2,3 183:17,21 184:1 fax 232:13 276:12 290:18,18,20 276:7 278:16 fact 151:9 154:3 184:12 186:19 feasibility 194:18 291:8,13 303:7 282:2 289:9 158:10 192:21 187:10,15,20 feasible 192:18 files 301:13 290:20 296:19 220:18 231:18 188:4,20,22 190:2 February 157:17 filing 275:16 299:3 264:15 288:13 190:17 191:5,22 Federal 132:10 filled 234:22 fix 286:10 failing 197:5 192:2,3,5,14,19 134:15 137:4 final 186:6 209:20 flat 276:13 277:17 fair 142:12 165:9 193:3,11,22 138:15 211:10 242:15 277:20,21 215:19 222:8 194:10,18 195:3,6 fee 224:21,22 252:8 flow 254:5 250:16 280:11 196:9,12,17,22 226:12 227:2 finalized 283:22 FNMA 311:4 312:4 282:2 307:17 197:2,3,9 198:17 feel 138:21 139:3 finance 183:8 FNMA.MBW.00... fairly 225:22 199:14 200:6,9,18 168:14 180:11 financial 136:13 136:6 139:13 faith 186:11 201:2,3,6,8,10,20 228:16 139:19 151:7 FNMA.MBW.00... false 221:22 222:10 202:8 203:1,6,10 feelings 176:19 164:19 182:20,22 136:9 150:20 222:13,15 223:17 203:12,22 204:5,6 fees 224:18,20 203:2,4 206:18 follow 244:21 Esquire Deposition Services MD - 1-800-539-6398 D.C. - 1-800-441-3376 VA - 1-800-752-8979 Case 1:05-cv-01483-JDB Document 33-8 Filed 06/21/2007 Page 56 of 74 Marialice Williams Page 9 245:6,15 265:2 friend 188:11,12,12 176:5,22 178:5 197:11 204:11,12 grounds 262:11 289:21 294:5 193:6 219:7 179:8 211:2 214:4 214:4 221:4 Group 273:17 following 141:19 front 301:16 246:11 258:2 241:16 243:19 274:5,7,9 277:14 192:14 frustration 215:9 260:19 265:9,9 244:21 245:3,6,11 282:18 283:8 follows 138:14 full 138:22 139:4 275:11 278:11 245:15,16 247:14 Groves 209:12 fond 168:18 fully 200:5,8 279:16,17 280:11 248:5 255:20 grueling 164:4 Forbes 270:7,7 246:21 285:6 287:9,19,21 256:3 259:22 Grundeman foregoing 249:13 full-time 275:19 293:2 306:17 260:11,11,19 134:22 138:5,5 309:8 310:3,4 functions 218:18 given 143:14 178:4 261:15 262:9 147:19 306:22 forfeit 268:4 fundamentally 180:13,21 197:9 263:19 264:22 307:3 forgot 192:7 215:17 206:11,15 211:4 265:2,8 266:16 guess 151:16 220:21 funds 162:6 197:10 234:19 265:15 271:1 278:9,13,14 172:19 207:3 form 136:17,19,20 237:8 284:18 304:7 278:22 279:3,16 211:9 225:22 152:15 192:19 further 196:19 309:10 310:8 281:1,13,21 283:3 253:10 279:6 225:17 261:20 294:3 310:11 giving 185:22 284:20 287:15 303:16 281:9 284:16 190:10,12 203:16 288:6 294:5 gun 240:3 298:2 301:18 G 211:6 214:19 295:19 296:7 303:5 gain 166:17 281:1 302:8 304:1,8,8 305:15 H formed 299:19 game 219:15,16 go 157:22 172:4 306:18 half 278:16 282:3 former 247:2 gamut 154:21 173:1,6 174:20,22 Goldfrank 147:20 307:13 303:13 garage 143:9 175:8,13 177:20 Goldman 270:6 Hamilton 172:6,15 forms 161:12 158:21 159:4,9,10 182:13 185:6 golf 178:7 173:4,14 174:1 forth 159:1 179:7 gee 175:10 287:20 197:14 207:3 good 137:1 138:18 Hampton 246:20 195:17 235:6 gen 273:10 209:15 210:2 138:19 167:9 hand 139:8 150:16 302:2 general 139:19 234:8,9,10 237:10 168:16 172:20 253:17 fortunate 154:8 241:7 258:1 260:21 180:16 186:11 handed 181:9 180:19 generally 149:22 266:21 272:15 188:6 291:20 185:20 186:11 forward 168:22 150:2 152:21 278:9,12,20,21 gosh 148:21 195:10 208:11,20 found 144:17 145:2 160:14 167:22 279:12,13 280:17 gotten 173:7 handing 147:11 145:15,20,22 224:17 273:11 280:18,19 283:4 279:18 185:14 198:1 176:1 231:12 generic 272:20 285:20 290:6,15 Grace 138:3,6 214:10 256:15 GenRe 197:5 292:8 300:7 186:19 194:7 hands 142:21 four 280:12,17,19 GenStar 151:8 303:22 221:3 happen 175:1,3 280:19,21 281:14 192:10 197:5 God 291:21 grand 235:13 happened 159:8 281:14 287:6,13 gentleman 193:14 goes 218:19 258:12 gravitated 179:16 183:14 196:16 289:9,9 291:14 Gerard 164:10 265:22 266:5 great 142:17 154:9 208:15 299:3 304:7 getting 167:2 267:14 157:22 158:22 happy 170:8 frame 143:15 146:1 174:20 175:9 going 155:3 161:19 159:16 168:9 181:14 165:17 236:1,5 180:16 188:21 166:21,22 170:18 183:4 205:10 harassment 288:17 frames 157:20 189:6 203:10 174:15 175:1,7 269:22,22 hard 143:7 196:2 frequently 179:17 214:17 217:1 176:19,21 178:11 Griffith 135:6 Harley 134:3,8 184:2 231:16 260:4 179:21,22 181:16 138:8,9 137:20 239:10 freshman 171:18 Gigi 231:11 182:21 183:1,3 gross 232:18 250:9 311:1,2 Friday 143:6 Gins 249:10 253:4 186:5 189:9 301:21,22 Harrison 246:4,9 238:11 285:7 give 138:22 139:4 193:13 196:11 ground 262:12 Hartsfield 193:7 Esquire Deposition Services MD - 1-800-539-6398 D.C. - 1-800-441-3376 VA - 1-800-752-8979 Case 1:05-cv-01483-JDB Document 33-8 Filed 06/21/2007 Page 57 of 74 Marialice Williams Page 10 194:7,16 209:13 hourly 278:19 155:7 186:15 Incorporated 170:20 171:1 230:3 231:18 hours 278:13,14,15 208:13 209:5 139:19 181:2 199:5,10 235:14 236:12 278:16 282:2 211:13 247:14 incorrect 252:15 206:15 221:22 237:6 269:15 304:2,7,9,16,18 251:7 252:1,17 285:19,22 286:1,4 226:7,9 246:18 Harvard 171:18 304:19 305:10,14 268:14 270:15 286:5,8,12 292:6 247:12,19,21 Harvey 193:6 house 158:17,21 294:8,22 295:6 292:7 300:6 250:13 252:20 194:6,16 209:11 housing 154:19 296:11 298:14 incurred 256:12 258:2,4 261:13 209:13 230:2 155:1 171:15 300:10 271:20,22 272:3 273:6 275:11 231:18 235:14 182:16 215:4 identifying 227:20 273:2 283:7 292:19 236:12 269:15 228:3 256:2,16,19 259:14 292:2 independent 293:2 303:12 hazard 155:12 257:1,3 II 132:14 137:2 153:19 284:4 initially 173:15 head 303:13 Hoyes 181:13 216:9 299:7,10 197:3,4 220:12 headquarters Huebscher 138:4,7 illness 257:4 independently inner 181:18 257:1 232:3,5,6,7 186:20 194:7 imagine 215:9 271:15 273:1,9 input 154:9 Health 300:21 221:3 282:18 indicate 237:3 inquiring 266:12 301:2 huge 158:18,21 immaterial 264:11 249:11 257:7 inquiry 266:19 heard 163:16 213:4 181:16 189:9 267:10 292:13 ins 200:18 hearing 290:9 huh 221:16 269:1 immediately indicated 216:19 instance 153:13 held 133:8 216:7 human 177:5 250:10 indicating 195:17 168:1 222:18 help 157:7 175:16 hundred 225:15 impact 180:20 221:3 252:14 instances 211:19 180:6 hurt 215:15 impart 170:22 indications 206:19 218:22 224:19 hereto 310:13 hurtful 174:14 implementing 206:21 instructed 194:12 high 224:20 hurting 229:3 194:20 247:5 indispensable instruction 244:22 higher 180:5 husband 284:22 important 175:1 197:9 245:7 289:15,20 276:10 286:15 290:19 218:21 287:18 individual 136:20 294:6 high-level 192:10 impression 203:17 175:19 195:5 instructions 189:13 192:12 I inaccurate 289:3 219:9 233:19 insurance 139:20 hire 275:18,19 ID 273:20 inadvertently 235:10 251:12,21 149:9 151:8 281:7 286:9 idea 196:9 227:3 305:5 274:5 282:21 152:11,12 153:19 297:15 306:18 include 197:2 283:2 298:3 154:2,20,22 hired 184:21 identical 295:11 230:12 303:17 155:10,12,13,14 200:11 247:4 identification included 203:11 individually 290:21 155:14 158:10 303:9,12 139:14 147:17 including 144:2 296:5 181:22 191:19 history 177:8 150:21 185:17 154:18 155:4,11 individuals 192:12 192:8,13,19,21,22 Hobbs 242:6 198:5 248:13 181:1 225:9 276:8 194:6 195:5 193:1,8,9,16,19 hold 306:20 251:13 254:2 income 136:17,19 235:11 247:9,11 194:22 195:19 holding 254:16 261:22 281:11 136:21 250:8 256:20 257:1 196:4 199:15,21 255:1,4 298:4 261:21 278:18 260:8 275:4,14 200:7,9 201:1,18 home 163:3,5 179:5 identified 144:2 281:10 292:14,16 297:9,15,18 202:7 205:13 honest 166:18 229:13 247:10 292:20 293:7,13 302:17 207:14 210:18 282:3 274:17 292:9 293:20,22 298:3 industry 299:18 212:15,16,18 honestly 191:13 297:16,19 302:13 299:12,13,13,14 inexpensive 234:12 213:2,6 218:13 219:20 302:18 299:17 300:1,11 information 143:6 219:2,4,6 224:19 honor 197:6 identify 137:19 300:13 301:9 147:2 155:19 225:8,18 226:13 hour 307:13,13 139:16 151:5 inconsistent 271:3 164:1 168:19 227:7 246:17 Esquire Deposition Services MD - 1-800-539-6398 D.C. - 1-800-441-3376 VA - 1-800-752-8979 Case 1:05-cv-01483-JDB Document 33-8 Filed 06/21/2007 Page 58 of 74 Marialice Williams Page 11 247:3,6,8 269:20 involvement 303:2,3 312:6 299:22 304:11 231:8,9 232:2 270:2,9 163:19,21 165:10 John 132:8 kept 158:5 160:15 243:13,17 245:14 insurance/reinsu... involves 243:21 Johns 182:8 231:20 209:15 233:18 248:3 249:19,21 210:19 involving 242:7 Johnson 184:14 kind 170:2,10 252:2,4,6 253:3,3 insurer 226:13 irrelevant 264:13 185:2 174:16 181:7 254:6,11 256:14 insurers 219:1 264:14 267:10 Johnson's 184:15 182:15 188:11 258:10 266:8 insuring 154:3 277:7 184:18 188:12,12 189:5 212:20 267:5,8 271:16 intelligent 180:8 irritating 286:18 joint 162:12 290:19213:21 214:9 276:6,9,18 277:20 intend 264:3 300:7 IRS 258:1,13 262:4 jointly 169:14 216:21 227:6 279:20 282:14,16 interested 215:6 277:15 283:11 269:21 275:16 276:8 283:4,5 286:1,3,5 310:14 288:12 303:7 joke 204:5 kinds 159:8 286:8,12,19 interesting 176:1 IRS's 277:15 Jonathan 135:6 knew 163:12 292:18,20,22 179:6 Islands 193:18,18 138:8 166:19,19,21 293:12,19,22 interfere 213:8 issue 165:15 169:14 Jones 164:19,21 170:16,17,17 294:12 295:4,14 interfered 203:13 179:3 182:2 165:7,9 166:20 173:10 176:8 295:14,15,16 213:10 276:14 288:16 167:1,5 168:7 179:4,4 183:4 296:2,14,16,18,21 interference 290:9 175:13 193:15 200:12,15,17,19 297:2,21 299:19 202:21 issued 139:17 197:1 203:7 206:7229:1 246:7 252:9 299:20,21 300:9 internal 183:10 143:2,19 145:12 206:14 210:17 252:9 286:10 305:14,18 306:20 192:20 277:9 149:15 153:16,17 215:12 216:15,17 knockoffs 225:18 knowing 173:6 301:12 303:14 165:20 181:14 219:13,22 220:8,9 know 139:5 142:5 177:7 225:5 international 195:2 225:4 222:3,13,22 152:13 157:11 227:18 199:21 200:12 issues 176:19 223:11 226:10 162:20 166:14,14 knowledge 167:13 interrog 199:6 177:22 179:17 231:20 246:5 166:16 167:10,11 167:20,21 168:11 interrogation 187:12 302:5 170:2,6,20 172:3 178:11 197:12 277:6 iterations 207:18 Jones's 165:10 173:11 178:6,9 200:21 218:15,16 interrogatories It'd 213:4 208:15 226:5 181:4,7 182:1 218:17 253:9 136:12 198:4,16 It'll 144:5 221:12 Jones/Cam 206:18 183:3 188:7 189:3 known 165:12,13 247:16 271:5 judge 132:8 197:8 189:3,5,9,12 166:2 171:17 interrogatory J Julia 165:2 242:15 194:8 195:12 184:20 218:16 198:18,21 199:3,4 Jane 246:4 July 310:19 196:8 199:18 knows 206:12 199:7,9 202:11,18 January 136:8 June 157:16 187:9 200:16,17 202:22 222:6,7 205:3,22 207:6 147:15 151:20 190:18,19,21 203:5 205:9,14,19 Kyra 134:22 138:5 216:1,14 221:19 155:18 157:17 191:5 306:4 206:4,6,7,8,14 147:19 224:1,12 229:12 209:14 jurisdiction 194:19207:1,1,2 209:14 229:14 237:20 Jay 134:3,8 311:1,2 213:15,21 214:6,6 L 247:10 270:19 JD 286:2 K 214:10,21 215:14 L 134:21 299:1 297:20 Jesus 233:21 Kate 194:7,16,21 216:20 219:18 language 210:13 introduced 184:20 Jim 188:11,12 195:1 219:10 220:3 222:5,8,10 laptop 148:15,17 184:21 Joanne 132:20 247:4 222:11,18 223:1,3 148:20 149:6,17 intrusive 264:11 133:14 137:15 keep 148:17 159:14 223:6,8,13,15 149:21 150:2,4 invite 178:6 310:2,16 311:16 159:15 167:1 224:2,4,7 225:8 large 149:10 invoke 244:10 job 132:21 170:22 233:16,20 260:10 227:4,5,11 228:6 234:21 involved 177:20 176:18 271:16 263:2 275:21,22 228:13,14,19,21 largely 150:3 179:19 277:15 282:6,9 282:2 287:16 229:3 230:16,21 194:19 255:17 Esquire Deposition Services MD - 1-800-539-6398 D.C. - 1-800-441-3376 VA - 1-800-752-8979 Case 1:05-cv-01483-JDB Document 33-8 Filed 06/21/2007 Page 59 of 74 Marialice Williams Page 12 260:9 271:1 137:22 138:1 Levin 169:10 lived 230:17 looked 253:6 larger 150:1 191:2,3,7 238:2 184:21 livelihood 280:10 looking 149:13 Larry 194:21 247:1 239:9 240:18 Levy 184:9 280:13 200:13 218:6 late 210:16 219:15 242:12 244:8 liar 301:14 Liverani 132:20 225:13 226:3,4,16 219:16 264:10,14,20 license 201:19,22 133:14 137:15 252:22 253:6 law 134:3 137:10 265:6 266:4,11,22 202:2 310:2,16 311:16 267:9 268:13 137:12 166:5 298:8,12 305:11 licensed 238:17 living 158:14,16 282:11 291:4 171:6,7,10 193:12 305:15 307:4,10 303:9 159:12 162:6 292:18 293:9,13 193:19 206:16 308:2 lied 215:12,13 231:1 278:17,19 294:14 296:6,10 238:1,1 276:8 Lederer's 206:16 life 142:20 213:4 288:5 304:10 302:11 279:1 281:8 311:2 239:2 277:7 LLC 232:7,8 looks 267:10 Lawch 138:3,6 left 158:2 162:11 lifetime 153:8,21 273:17 292:3,7 Lord 192:7 166:22 167:3 165:14,15 172:1 154:5 298:16 299:1 lose 147:2 159:22 171:9 172:16,22 174:4 176:20 likewise 219:3 300:4 280:10 173:3,13 174:3,21 181:12 182:3,18 limit 168:5 LLP 133:10 134:17 loss 153:14,18 175:18 176:3,5 185:4,5 187:9 limited 155:11 loan 230:19 157:4 287:20 177:2,18 179:14 190:17 191:22 line 268:14 312:7 loans 152:17,19,21 losses 153:7,20 182:11 183:18 192:2,3 200:8 lines 232:12,16 153:6,7,20 154:2 154:3,6,20 224:15 186:19 189:13,17 201:4,5,12,20 276:7 154:4 215:4 267:20 268:3,4 189:22 199:20 202:8 213:20 list 247:9 251:12 locate 156:19 208:3 lost 211:3 245:12 200:5 222:6 228:1 230:21 296:19 299:5,8 210:15 249:16 279:9 223:14 239:19 234:4 235:7 300:3,5 located 137:16 lot 157:6 159:21 240:8 241:9 304:18 listed 194:6 250:13 193:17 212:18 170:8 175:16 Lawch's 170:12 legal 239:2 242:5 251:7 252:17 252:21 179:15,16 196:10 174:7 176:9 243:21 268:15 259:18 260:9 long 162:2 166:21 205:15 222:20 laws 187:17 269:13,17 292:10 261:12 292:22 169:18 181:12 235:5 255:21 lawsuit 262:13 292:11 294:9,16 300:5 182:11 183:16 256:6 263:21 267:12 302:12 listen 284:19 184:20 229:1 lots 223:17 lawyer 172:20 legitimate 289:20 286:16 235:1 249:17 Lou 181:13 190:22 278:20 Lend 234:10 lists 260:15 255:16 277:20 loved 176:18 Lawyers 305:21 lenders 246:6 litany 179:9 218:1 306:17 Lucas 274:13 Lawyer-client length 158:6 litigation 142:16 longer 139:4 277:13 282:18 244:2 letter 202:17 203:1 143:3 145:13 161:16,17 224:9 lunch 220:18 lead 167:12 204:12 203:6 204:13 149:21 163:8,12 241:17 270:3 luncheon 197:19 learned 219:20 213:14,21 215:11 163:16,17,18,20 304:1 luncheons 258:17 lease 229:16,17,19 let's 148:21 163:13 163:22 164:6 look 150:10 155:19 lured 183:1 231:6,7 234:10 172:10 197:14 186:2 197:4 187:5 204:18 lying 211:8 279:10 leave 181:11 198:8 209:17 238:20 239:7,8 205:2,21 207:5 182:19 189:4 222:18 224:6 243:3 257:18 215:22 216:13 M 227:22 226:16 227:15 little 144:5 169:17 233:1 234:14 M 298:15 leaving 175:11 241:6 266:21 178:14 189:10 252:7 253:2 Mac 192:7,9,10 182:5,5 187:20 290:4 190:12 213:19 269:21 273:16 234:9 241:3 level 152:22 180:5 288:1 277:10,16 289:10 machine 276:12 led 217:3 305:9 184:4 live 161:16 176:22 295:15 296:1 machines 232:14 Lederer 134:10 levels 180:3 230:16 297:11 MADAM 210:3 Esquire Deposition Services MD - 1-800-539-6398 D.C. - 1-800-441-3376 VA - 1-800-752-8979 Case 1:05-cv-01483-JDB Document 33-8 Filed 06/21/2007 Page 60 of 74 Marialice Williams Page 13 248:8 261:18 216:18,21 217:4,6 Marialice 132:4,16 149:8 195:10 168:20 189:8 280:2 281:3 217:8,15,18 218:2 133:7 134:2 136:4 matter 137:4 204:3 212:7 269:3 Mae 135:2 138:3,6 218:18,20 219:21 137:3,4 138:11 139:18 145:19 meet 166:8,10 138:9 140:18 220:2,3,17 223:10 186:18 198:16 146:6 151:8 168:21 210:17 141:7,19,20 142:6 224:16 225:1,8,11 204:12 216:5,10 176:17 180:7 220:18 234:9,10 146:8,19 148:18 225:21 226:1 232:5 235:18 183:3 185:19 234:11 256:4 149:5 151:7 227:14 228:15,22 272:14 282:7 242:7,17 meeting 136:15 152:18,20 153:13 230:18 231:21 284:7 289:5 294:2 mattered 180:8 173:4,14 191:19 153:16 154:8,18 234:4 238:9,14 305:1 306:15 matters 241:7 192:14 194:2,5,14 156:15 158:2,5 239:16 240:12,16 307:4 309:7,15 ma'am 264:19 194:15 195:11 160:14 161:7,19 242:9 243:12,15 311:5 312:5 304:21 196:2,16 229:5 162:6 164:5,18 244:16 245:10,21 mark 147:12 MBS 199:22 225:2 253:21 165:8,12,13,14 247:15 256:5,9,12 150:17 180:17 225:4 meetings 192:1,3 166:2,4,7,10,20 256:13,14,18 198:2 248:6 McGlinchey 218:22 238:13 168:3,17 169:3,12 257:8 259:15 253:18 261:16 164:11 members 192:5 169:14,18 170:8 260:5,12 268:2 278:8 281:6 298:1 McKinnon 175:3 memorize 296:8 170:10 171:14,20 270:12 279:11 marked 139:9,13 MCRI 152:7,9,13 memory 290:12 172:9,13 173:6 287:21 288:3 142:11 147:16 152:14 154:15,17 mental 257:4 174:4,9,18 175:14 293:11,18 299:20 150:20 185:14,17 155:11 165:11 300:21 301:2 176:7,8,12,14,18 299:21 300:14 198:5 202:13 174:15 175:9 mention 176:3 176:21 177:11 302:4,9 208:12 248:13 181:15,22 200:10 mentioned 168:21 179:2,14 180:4,12 Mae's 164:7,18,21 254:2 261:22 200:19 201:9 170:15 184:8 180:13,17,21 165:7 181:20 279:22 281:11 206:20 210:19 238:11,15 181:10,11,12 mailed 209:11 298:4 307:11 228:1,1 mentor 180:4,9,11 182:3,5,15 183:11 main 150:5 market 155:2 meal 271:8 272:3 merged 192:9 183:17,21 184:1 major 192:8 158:11 176:15 295:7,10 merger 192:7 184:12 186:19 210:18 206:9 218:17 meals 270:15 Merit 310:17 187:10,15,20 majority 247:17 256:20 271:20 273:3 messes 248:15 188:4,20,22 190:2 301:7 marketing 174:17 302:19 met 172:2 173:8,9 190:17 191:5,22 making 275:18 235:6 269:20 mean 176:11 178:9 190:21 242:11 192:2,3,5,14,19 288:5 270:1 181:3 189:10 246:22 247:3 193:3,11,22 man 171:14 200:16 marketplace 218:5 220:20 meter 237:10 194:10,18 195:3,6 200:21 153:11 168:4 230:22 231:1 Metropolitan 196:9,12,18,22 managed 170:4 182:14 183:5 232:1 233:13 201:5 197:2,3,9 198:17 manager 177:19 228:17 255:13 256:16 Mexico 242:6 199:14 200:6,9,18 178:22 markets 178:13 257:22,22 272:18 Michael 239:9 201:2,4,6,8,10,20 managing 251:16 182:16 277:4 280:11 middle 241:10 202:8 203:1,6,10 253:15 marr 238:3 281:13 287:4,18 256:21 203:13,22 204:5,6 manila 234:21 married 238:3,3 288:8 289:22 might've 193:2 204:20 205:9,14 manner 165:9 239:13,15 241:18 293:17 299:9 299:17 205:16 206:5,12 166:20 173:21 Marsh 192:7,9,10 305:4 million 181:6 205:5 206:19 207:19 174:8,12 234:9 meaning 154:1 205:7,15 225:15 211:7 212:7,22 March 138:21 mat 142:18 means 274:22 226:20 227:8,17 213:8,10,16 214:2 151:10 157:17 materials 142:18 288:4 228:9 268:4 214:3 215:2,13,18 Maria 184:14 144:21 145:17 meant 162:10 mind 279:9 Esquire Deposition Services MD - 1-800-539-6398 D.C. - 1-800-441-3376 VA - 1-800-752-8979 Case 1:05-cv-01483-JDB Document 33-8 Filed 06/21/2007 Page 61 of 74 Marialice Williams Page 14 mind's 182:12 268:21,21 269:3,9 193:15 194:9 234:8 242:6 237:20 238:5 mine 184:16 270:18 248:15 270:6 246:20 247:11 273:21,22 minus 226:14 morning 137:1 273:13 286:2 Newman 194:8,12 274:1 301:17 minute 197:15 138:18,19 284:17 297:8 298:14 newsletters 149:11 303:1,3 minutes 185:7 288:10 299:2 303:17,21 nicer 189:11 numbers 158:18 235:21 280:19,20 mortgage 132:11 312:4,5 Nieds 188:1,5,16 234:20 251:13 Mirel 194:21 247:1 134:15 137:5 names 251:12 189:12 190:16 288:16 296:1,3 miserable 240:2 138:16 152:17,19 275:6 241:11 302:1 Mississippi 225:14 153:6 154:2,4 nasty 241:12 nin 147:7 239:1 155:10 201:15,17 National 132:10 nine 216:1,14 O misspoke 244:13 222:18,19 231:22 134:15 137:5 nonsense 288:7 O 136:1 mistaken 209:21 231:22 234:11 138:16 139:20 Non-Fannie 300:14 obfuscation 204:10 211:5 256:3 299:18 nature 240:19 non-priority object 241:17 Mitigation 292:3 mortgages 153:15 251:13 269:17 254:17 255:4 objection 262:15 300:3 181:3,18 nearly 279:9 non-responsive 264:5,9,18 267:2 Mm 167:16 mortgage-backed necessarily 156:12 274:3 obligation 215:3 mm-hmm 147:21 152:19 153:8,21 212:14 229:6 Northwest 134:4 obviously 214:2,18 168:13 187:7 mother 159:2 necessary 270:11 134:11,18 135:3 232:2 279:20 194:4 200:2 207:7 162:12 275:21 137:11,17 144:19 290:8 302:1 220:7 237:11 mother's 159:7 need 186:5 221:10 273:18 311:2,14 occasionally 230:1 244:19 248:9,21 motivation 213:22 270:10 272:15 312:1 occasioned 154:6,6 249:2 250:12,15 Mountain 270:5 281:21 282:5 notary 133:15 occurred 159:10 251:1,4,21 252:13 Mountains 270:6 306:22 138:13 310:1,17 174:3 192:17 253:1 254:18 move 160:21 needed 219:4 note 311:10 194:15 295:3 302:14 161:20,21 162:14 228:17 285:19 notes 228:8 offense 176:2 mod 190:8 274:2 negative 172:16,21 notice 133:14 offer 166:15 188:20 model 154:8 moved 158:12,16 222:3,20 254:5 136:15 143:4,4 189:18,21 190:3 modest 190:8,8,9 158:20 159:3,11 negotiated 187:10 253:20 191:12 265:18 modification 190:6 161:15 162:1,3,4 191:5 228:4 229:9 notion 259:11,12 offered 190:11 modified 190:4 236:8,9 negotiating 243:14 259:13 offering 188:18 moment 182:12 moving 159:12 negotiations number 137:2 office 143:10 262:16 264:20 multifamily 152:10 189:16 190:15 140:20 141:2,4,9 144:14 158:3,3,6 Monday 132:18 152:11 153:11 241:10 141:13,15,22 158:13,19 161:17 money 170:8 154:1,1 169:13 neither 310:9 142:4 152:6 155:6 162:22 163:6 190:10 206:22 174:5 175:5 181:3 Ness 134:4,11 155:7,17 156:7,13 169:13 172:2 215:16 230:17 184:7 191:10 311:2 156:16 158:8,11 178:7,8,8,11 237:10 241:1,5 192:5 never 142:7 144:22 174:19 177:15,16 179:16 193:8 254:5 256:8 Myers 133:10 168:19 204:6 177:18 189:6 229:21,22 230:2,3 260:10 275:18 134:17 137:10,13 205:19 209:19 192:17 199:3,4,7 230:4,5,9,10,11 279:15 293:18 213:3 221:15 199:9 202:11,18 230:13 232:3,9,13 301:15 N 275:22 281:7 205:3,22 207:6,17 232:15 233:14 month 190:20 N 136:1,1 288:3 208:7 216:1,4,9 235:1,4 238:6 229:15 232:10 name 137:20,22 new 169:16 170:7 216:14 221:19 260:4 294:22 233:11 234:5,6,8 164:10 171:7,8,21 171:20 193:12,18 224:2,13 229:12 297:19 235:13,15 236:22 188:2 192:7 194:10,10 203:3 230:5 234:18,19 officer 188:10 Esquire Deposition Services MD - 1-800-539-6398 D.C. - 1-800-441-3376 VA - 1-800-752-8979 Case 1:05-cv-01483-JDB Document 33-8 Filed 06/21/2007 Page 62 of 74 Marialice Williams Page 15 251:15 253:14 oppressive 267:11 292:1 296:10 302:10 255:18 259:20 310:2 option 195:7 298:6 312:7 paying 211:8 260:17 261:3,9 officers 192:4 options 189:8 pages 132:9 309:8 236:21 241:4 persons 247:13 offices 133:8 134:3 order 200:9 203:8 paid 167:7 230:20 276:13 277:18 petition 254:14 137:12 229:22 215:2 218:20 230:22 231:3 penalty 249:12 259:6 271:4 231:4 238:7 311:2 219:8 230:13 235:13,14 237:8 pending 221:7 pets 178:14 officials 192:10 260:10 270:8 268:18 269:5,15 people 157:10 petty 189:10 oh 143:21 148:21 ordinarily 158:9 279:7 300:19 168:18 170:3,5 ph 188:1 274:8,9 150:9 171:21 original 189:18,20 301:2 302:16 175:22 178:18,21 phone 216:14 172:2,8,14 175:10 210:4 263:9 284:1pal 178:7 179:3,7,18 183:15 232:9,16 233:13 192:7 204:13,14 284:9,11,16 panel 171:13 184:5,6 189:4 276:9 226:14 233:21 285:15 307:1,11 papers 156:10,22 194:14 213:18 phones 232:16 255:20 originally 190:11 158:22 222:21 223:8,18 piece 153:18 241:3 okay 159:11 186:10 290:18 paragraph 187:6 223:18 228:18 pissy 288:1 198:10 208:18 originals 284:7 191:18 196:15 229:2,7 231:13,21 place 151:9 190:16 237:12 243:20 ostensibly 187:11 199:12 251:19,20 232:13 238:13 192:11 219:13 251:22 258:8 Ott 200:15,17 parameters 154:7 257:4 258:22 262:20 293:10,12 264:16 267:15 206:5,12,13 207:2part 214:16 227:12 270:8 274:15 placed 272:8 268:13 277:10 221:4 238:12 239:17 275:2,19 places 144:1 289:7 290:10 ought 170:10 255:19 292:13 people's 175:16 156:13 192:11 306:19 307:20 outcome 310:14 294:8 296:19 percent 224:21 197:11 256:3 old 203:3 outer 230:4 299:2 302:11 226:12,14,15 plain 212:4,22 once 152:21 153:3 outrageous 279:2 participate 219:2 227:1,1 271:5 plaintiff 132:6 167:8 outside 153:15 particular 145:19 percentage 153:5 134:2 137:21 ones 247:18 263:3 outstanding 254:19 146:22 153:13 perform 275:20 138:1 187:9,14 279:18 287:10 owe 268:5 169:20 174:20 performed 275:14 Plaintiff's 136:11 297:4 owner 162:12 194:2 196:13 period 230:17 198:3,15 one's 209:18 193:2 253:16 205:3 219:2,9 perjury 249:12 play 176:14 178:7 one-off 225:2,11 O'Melveny 133:10 226:21 228:8 permit 229:1,2 please 137:18 228:4 229:10 134:17 137:10,13 257:9 259:8 person 163:22 139:5 167:18 one-page 136:7 269:16 167:12 171:17 210:1 287:1,1 147:14 P particularly 188:9 172:5 175:17 311:8,13 one-pager 207:12 package 196:10 215:6 223:18 176:2 177:6 179:2 plus 153:17 193:15 207:15 226:21 258:16,18 parties 195:15 179:11,18 182:8 point 145:20 169:7 opened 228:18 288:1 196:5 310:10,13 184:11 188:2 170:13,14 173:16 operating 193:1 packed 159:1 partly 261:2,3 194:13 200:15,22 189:2 197:18 operation 250:9 pad 167:7 partner 251:16 223:15 235:4,13 203:20 204:10 operative 187:3 page 136:2,5 253:14 235:14 238:22 205:1 214:2 215:5 opinion 192:20 140:12,12 152:5,5 partnership 251:17 273:12,13 274:12 241:17 267:9 opportunities 155:6 187:6 party 197:4,9 274:13 301:16 182:13 199:13 205:4 pay 161:5 162:9 personal 157:7 points 146:16 opportunity 154:9 209:12 248:20 230:13 237:7 165:10 170:1 224:18,20 159:20 181:21 250:22 262:19 260:3 267:19 176:17 177:4,6 policy 153:19 285:6 267:18 268:13 268:3 269:13 219:7 229:19 154:22 184:4,10 opposed 178:21 274:16 291:4,12 279:8 285:20 239:11 255:7,14 192:4 Esquire Deposition Services MD - 1-800-539-6398 D.C. - 1-800-441-3376 VA - 1-800-752-8979 Case 1:05-cv-01483-JDB Document 33-8 Filed 06/21/2007 Page 63 of 74 Marialice Williams Page 16 pool 153:15 199:15 282:13,15,17,20 probing 290:1 proffer 264:3,7 push 180:6 pools 154:1 181:2 282:22 283:1 problem 231:16 265:7,9 266:5,18 put 142:21 156:11 199:22 207:4 284:5 304:9 problems 256:16 267:4 158:22 160:2 poor 177:19 178:22 present 135:8 proceed 281:13 program 154:21 171:13 183:1 poorly 240:4 137:18 193:22 proceedings 197:18 182:16 205:8 189:16 235:19 portfolio 152:17 218:22 242:19 proceeds 212:8 215:5 219:3 221:5 237:10 241:1 153:3 225:5 227:6 presentation process 195:18 225:10 227:3 253:5,11 254:4,6 portion 230:8 194:17 195:22 218:19 228:2 229:8,8,9 258:18,20 269:11 posed 199:6 245:8 presentations processes 218:18 project 158:4 227:7 271:13 273:8 position 164:18,21 149:9 270:12,13 procurer 213:6 257:3 277:2 299:12 165:7 178:2 presenting 196:12 produce 140:8,22 projects 269:21 300:2 301:11 182:20,22 president 171:20 141:11 142:2 proof 265:14 303:5 possessed 142:22 176:12 184:3,13 144:16 145:13 properties 152:22 putt 178:8 possession 141:1 191:10 146:3,8 149:19 175:6 p.m 308:6 141:12 142:3,13 pressure 241:3 151:13 160:6,10 property 161:5 145:10 146:9,10 pretty 148:8 207:15,17 231:7 proposal 154:11,14 Q 150:13 155:22 167:21 175:15 268:10 275:8 154:16,18,19 quarter 281:14 156:1,3,5,9 157:2 188:22 210:11 produced 142:15 155:4 192:14 quarters 235:19 160:18 162:20 211:20 212:1 144:18 145:1,18 220:14,16 229:5 question 143:17 258:5 223:10 225:15 146:4,13 150:6,12 propose 280:17 144:5 151:1 164:2 possessions 157:9 255:12 257:16 150:14 155:21 307:22 308:2 174:15 180:15 157:13 previous 209:4 156:2 159:17 proprietorship 188:6 190:9 199:6 potential 149:10 previously 202:13 189:2 207:18 251:17 209:1 210:1,4 224:16 238:14 291:7 producing 168:2 prospective 149:9 212:12 218:7,10 256:15 price 181:5 176:13 protected 187:16 220:21 221:7 PowerPoint 195:22 print 150:2 product 146:19 prove 231:17 264:3 233:3 234:17 196:1 printed 263:5 164:2 167:8 proven 180:1 241:20 243:19 preceding 250:11 288:10 169:17 170:10 provide 240:11,14 244:22 245:4,5,8 precisely 143:22 prior 163:14 175:10,15 182:14 256:22 278:4 245:12,14,17 144:20 149:7 164:16 165:19 183:5,9 189:21 282:19 283:7 249:16,19 251:6 161:8 206:5 222:5 168:21 170:16,17 196:11 206:9 285:5,15 294:19 259:7,21 260:18 predecessor 247:1 170:18 171:4 215:1 227:7 295:18 302:6 262:10 265:1,5 prefer 193:12 187:14,20 192:6 production 208:7 303:3 279:17 283:3,4,13 preference 178:17 196:11,12 219:9 productions 146:7 provided 205:9 284:22 288:22 preliminary 185:19 242:16 244:17 productive 176:16 261:14 273:6 289:2,6,17,18 premium 224:22 privilege 244:3 180:7 283:18 303:12 290:2 294:3 226:12,15 privileged 246:3 productivity 176:6 public 133:15 295:21 prepare 198:18 prize 275:22 176:8,20 229:4 310:1,17 questioning 185:20 233:5 249:5 probably 142:20 products 168:2 pull 159:20 277:5 prepared 149:8 164:1 174:13 170:7 176:14 purposes 267:12 questions 245:19 233:16 234:16 175:19 185:3 profession 292:10 pursuant 133:14 245:22 272:21 249:9 253:4 201:13 210:14 professional 187:10 284:3 287:19 257:15 258:11,14 232:17 241:11 268:15 269:14,18 pursue 193:13 288:6 290:1,13 263:14,17 273:14 270:22 271:22 269:19 273:12 200:9 question's 272:19 274:6,7,9 277:14 300:6 301:8 294:9,16 302:12 pursuing 193:16 quite 168:8 184:5 Esquire Deposition Services MD - 1-800-539-6398 D.C. - 1-800-441-3376 VA - 1-800-752-8979 Case 1:05-cv-01483-JDB Document 33-8 Filed 06/21/2007 Page 64 of 74 Marialice Williams Page 17 195:15 230:15 304:10 recognize 148:1 referenced 311:8 relationship 168:17 235:3 reason 145:9 198:12 248:17 referred 199:19 170:1,4 171:10 quote 199:20 151:22 157:1 254:8 270:19 274:11 173:12 177:4 quote/unquote 160:9,17 164:14 recollection 148:5 referring 171:5 203:13,21 204:1 200:12 217:1 228:15 163:11 250:4 202:17 208:1,8 204:22 213:11 260:2 278:17 recommendation 216:16 274:12 214:1 219:21 R 299:5,22 300:1 179:17 reflect 225:1 239:12,19,22 race 177:12 178:20 reasonably 305:18 recommended 227:14 230:16 244:6,10 183:19 187:13,19 reasons 157:7 194:21 233:4 relationships 188:15 240:9 311:10 reconfigured reflecting 231:2 225:20 racial 177:22 recall 140:3 143:22 230:14 reflection 293:1 relative 310:12 rafters 159:1 151:11 152:3 reconvene 280:17 reflective 176:6 relatively 169:16 raised 186:12 154:10 160:8 280:21 188:19 194:10 ran 154:20 171:16 162:18,21 163:8 record 144:5 185:7 refresh 148:4 250:4 relevance 259:7 260:5,6 164:15 171:8 185:8,11 197:15 refusing 258:7 293:17 ranged 224:18 172:9,11 174:2 197:16,20 210:7 regard 206:17 relevant 246:18 rate 276:13 277:17 185:3 197:3 210:10 212:13 217:11 262:13 263:20 277:20,21 219:17 223:20,22 216:6,7,11 218:11 regarding 141:7 265:12,13 rated 210:18 224:4 236:16 220:22 236:11 196:22 216:17 relied 204:18 reaction 173:13,16 237:1 242:10 237:13,16 257:13 240:20 reluctant 167:10 173:19 184:15 255:15 273:9 266:21 306:6 Registered 310:17 rely 273:11 241:14 243:16 291:11 300:22 310:8 regular 206:20 remark 200:20 245:9 receipt 221:2 recorded 227:13 regulations 194:20 remember 145:16 read 187:8 205:8 273:10 272:1 247:6 151:15,21 154:12 210:7,10 212:11 receipts 233:14,17 records 145:14,16 reinsurer 195:16 158:7 161:3,8 212:13 218:9,11 233:18,20 234:14 146:14 159:6 reinsurers 219:1 165:5,17 166:7 220:22 249:12 234:17,22 257:15 161:11 185:21 reiterated 220:2,6 179:20 184:4 251:19 309:8 257:17 258:12,15 186:9 237:2 239:1 relate 140:17 141:6 190:15,19 191:18 311:8,12 258:20 259:1,10 247:15 257:14 141:17 154:16 194:1 207:16 ready 174:20 259:16 261:14 289:11 293:1,9 155:9 161:15 218:7 219:12,14 188:21 271:1,2,9,12,15 294:13,14,20 related 142:9 229:5 242:1,22 real 153:2 178:10 272:5,7,10,21 295:5 297:11 156:15 200:18 244:18 246:10 204:10 226:17 273:2 275:7,9 recovering 257:4 215:17 256:11,12 248:3 273:5,5 251:8,10 276:21,22 277:10 Red 222:19 231:22 257:5,8 259:15 277:19,22 290:13 reality 203:9,19 277:13 278:4 redid 303:15,18 310:9 296:20,22 297:1,8 really 142:7 151:21 283:5,6 301:13,21 redirect 280:22 relates 154:17 297:10,17,21 159:5 167:9 168:4 301:22 302:2,2,7 281:1,15 relating 141:1 301:1,4,6 302:16 168:8 169:6 172:8 302:17 303:4,5,16 redneck 168:8 148:18 149:5 remembered 172:9 174:14,18 receive 226:14 223:12 150:6 157:2 166:19 182:13 188:6 received 163:15 reduced 207:9,11 226:10 228:11 remembering 196:19 218:8 220:13 250:10 310:7 245:20 247:12,21 147:10 219:19,19,20 292:20 293:18 refer 140:17 141:6 265:18 268:7 REMIC 169:13 224:4 235:3,4,8 receiving 140:3 141:17 155:9 278:5 rent 195:4 229:15 241:12 255:15 recess 185:10 202:12 relation 190:16 231:3 278:19 279:1,7 197:19 237:15 reference 194:2 191:4 243:5,8 rented 231:12,12 Esquire Deposition Services MD - 1-800-539-6398 D.C. - 1-800-441-3376 VA - 1-800-752-8979 Case 1:05-cv-01483-JDB Document 33-8 Filed 06/21/2007 Page 65 of 74 Marialice Williams Page 18 231:15 151:19 210:7,10 152:1 199:6 282:5 234:1,16,21 237:5 273:15,16 275:6 repeat 217:14 212:13 218:11 rest 285:5 252:10 257:15,22 281:2 286:22 repeated 219:22 220:22 result 290:22 258:11,13 259:2 296:6 298:16 repeating 286:17 required 166:5 retained 141:18 261:13 265:12,16 301:16 302:14 rephrase 143:17 177:20 271:14 275:5 266:13,13,17 rights 187:17 replacement requires 152:21 retaliation 187:13 272:9,12 273:11 risk 152:10 153:1,2 152:11 155:13 research 239:2 187:19 188:15 273:14 278:22 153:2,2,4 154:2 report 170:5 269:22 189:22 279:3,18,19 280:6 155:12 270:5 Reported 132:20 reserved 308:8 retet 292:22 282:20 283:1,19 292:2 300:3 301:18 reset 281:14 retirement 162:5 283:21 285:3,4 RMR 132:20 reporter 137:15 residential 276:10 230:18 288:1 287:9,20 291:8 133:14 139:9 147:12 resolved 187:11 retrieve 146:15,20 303:7,11,18 RMS 232:4,7,7 150:17 198:1 respect 153:5 146:21 157:11 Revenue 192:20 252:1 253:13,16 202:14 210:3,7,10 156:21 177:17,22 retrieved 143:6 277:9 301:12 298:20,22 299:1,1 212:13 218:11 200:10 247:7 return 136:18,19 303:14 299:3,6,14,19,22 220:22 248:6,8 respected 169:5,8,9 136:21 231:5 review 209:3 249:7 Rob 169:10 184:20 253:18 261:16,18 respectful 173:21 232:20 258:20 271:12 273:1 230:2 231:18 278:8 280:2 281:3 174:8,12 259:9 261:21 311:8 235:12 236:18 281:6 298:1 respond 159:18 262:2,20,21 263:7 reviewed 152:21,22 Robert 235:12 310:17 responded 234:17 263:9,11,12,14,16 283:21 284:14 Robinson 230:2 reports 225:1 response 140:5,8 266:3 268:8,14 311:12 231:18 235:12,12 226:3,9 227:13 140:19 141:12,21 271:4 272:6,9 reviews 176:6 236:2,18 233:15 143:2,19 145:18 273:8,15,16 274:6 reward 176:4 role 176:15 represent 137:19 146:4 149:15 274:7,10,16 reworked 284:2,14 rose 175:21 137:21 138:1 150:10 155:16 275:13 276:18,20 285:13 rug 159:7 141:6,17 191:3 156:17 160:3 277:3,8,13,14 Rhoda 194:7,12 ruined 159:7,8 238:19,21 239:7 165:1 205:4 206:1 278:10 281:10 Richard 138:3,6 run 175:3 216:3 242:4,8 243:6,7 206:4 229:13 282:11 283:8 166:22 167:6,19 runaround 211:7 244:12,13,15 237:20 247:10,15 284:4,5,11 285:1 167:20 168:4,16 211:11 representative 247:19 251:5,7 285:10,16 286:6,7 169:1,16 170:3,6 running 275:17 164:8 247:5 252:17,18,19 286:13 288:8,11 172:2,8 173:8,10 276:15 represented 239:4 270:19 290:3 288:13,19,22 175:10 182:10 runs 276:8 240:18 243:12 responses 198:19 289:3 290:17,19 186:19 199:19 rural 181:18 representing 246:1 198:21 208:5 290:21,22 291:4,5 204:8 222:6,21 represents 239:6 297:20 291:5,10 292:2,13 223:12,14 239:19 S request 137:12 responsibilities 293:1 295:20,22 240:1 241:9 S 136:1 140:20 141:1,4,9 177:17 296:11 298:3,9 249:10 253:4 Sachs 270:6 141:13,15,22 responsibility 299:6 300:2,4,8 ride 306:20 sale 162:11 142:4 145:6,18 153:14 303:11 300:10 301:11 right 151:17 158:7 sales 174:17 146:5 155:6,7,17 responsible 169:11 303:19 305:16 166:16 199:17 Sarah 147:19 159:18 207:19 175:4 311:13 209:9 215:21 186:13 247:16,19 responsive 141:8 returned 142:7 221:1,2 227:17,22 sarcastic 223:16 requested 140:15 142:3,14 144:16 144:22 284:17 244:12,17 245:1 sat 273:9 277:2 140:16 142:14 145:2,5,11 146:9 returns 198:7,9 246:2 253:3 257:2 satisfy 277:3 144:20 145:3,12 149:19 151:19 204:18 233:1,6,7 260:21 269:9 save 258:16,17,17 Esquire Deposition Services MD - 1-800-539-6398 D.C. - 1-800-441-3376 VA - 1-800-752-8979 Case 1:05-cv-01483-JDB Document 33-8 Filed 06/21/2007 Page 66 of 74 Marialice Williams Page 19 288:11 246:18 247:3,7 separated 238:4 shortly 162:17 situation 158:1 saw 252:10 253:6 securitization separately 286:15 should've 178:3 159:6 179:19 saying 143:1 153:11 195:18 September 162:15 186:12 241:15 243:16 172:19 183:1 218:20 228:5 262:5,6 283:14 show 181:4 295:19 six 141:4,9,13 200:13 213:11 229:8 291:14 showed 268:17,18 164:4 283:16 301:14 securitizing 170:11 serious 148:16 shown 211:18 304:9 says 140:14 143:5 security 153:21 275:17 shows 279:7 Sixteen 261:18,19 148:2,3 151:16,17 154:5 273:22 seriously 211:12 sic 286:9 slaves 179:7 152:10 199:13 see 148:21 152:6 served 164:17 sick 272:16 slightly 230:14 202:15 211:21 159:4 163:13 service 192:20 side 169:11 170:1 small 173:7 227:12 213:15 223:18 166:17 172:10 195:9 277:9 182:17 219:4 smaller 181:19 248:22 250:9 182:13 200:1 297:12 301:12 sign 209:19 211:10 smart 180:7 251:2,11 252:16 204:18 209:5,17 services 137:16 249:21 291:5 social 273:21 254:22 255:3 215:2 222:18 139:19 151:8 295:22 311:9,12 sold 157:10 162:8 267:19 281:20 224:6 226:4,16 260:16 268:15 signature 248:22 230:22 300:17 301:17 227:15 233:1 269:14,18,19 249:3,11 262:21 sole 251:17 schedule 254:16 234:20 241:6 274:17,21 275:1,5 308:8 312:21 solutions 256:15 255:3 258:12 248:22 250:6,11 275:13,15,20 signatures 263:8 somebody 161:13 306:15 307:15 250:14 251:2,11 276:11 294:9,16 signed 186:4 213:3,20 299:18 Schlimb 274:8 251:22 260:8 297:2 302:12 210:13,15,16,21 somebody's 178:1 Schlomb 274:9 262:20 268:16,17 312:1 211:4 225:21 188:10 279:1 search 140:5,19 270:16,20 273:16 serving 164:16 252:12 253:7 somewhat 170:19 141:8,21 143:2,16 274:18 279:6 194:11 238:21 257:22 262:21,22 195:13,14 143:18 144:1,7,10 282:4 289:11,13 session 171:12 263:3,6 266:16 son 240:2 144:13 149:16 292:14 293:17 set 153:6 304:13 288:9,11 291:7,9 soon 260:13 285:5 152:1 160:4 294:10 295:1,2,7 settlement 187:11 291:16 295:21 sorry 144:4 151:2 searched 143:7,13 296:12 298:15 188:3,18 189:1,5 309:12 311:11 182:11 209:3 145:22 151:18 300:11 302:13,20 189:6,18,21 190:7 significant 188:10 217:14 233:11 155:16 seek 244:12 191:4,8,15 204:19 192:17 243:6 245:11 second 199:12 seen 156:14 159:21 240:15,20 243:15 similar 152:12 249:16 251:18 201:4 221:13 176:13 213:4 245:9 simple 212:4 258:8 278:1,11 235:14 251:19 221:15 254:10,12 seven 141:15,22 225:22 279:19 295:14,17 286:9 280:2 142:4 155:7,8,17 simply 168:5 297:1 304:2,10 secondary 168:3 selecting 200:20 164:4 207:6 173:20 178:22 sort 237:22 176:15 218:17 sell 161:4 227:17 276:6 189:3 195:7 sound 243:1 256:20 selling 152:17 278:13 207:13 233:16 source 292:21 secret 231:14 sen 213:12 sex 187:13,20 sincere 220:17 293:5,5 300:13 secretarial 230:1 send 284:15 188:16 Sincerely 311:15 sources 150:10 section 250:8,22 senior 169:15 shared 186:3 sine 308:7 270:4 293:19,22 251:6 252:15 184:11 191:10 sheet 309:12 311:9 single 154:17 south 230:7 253:7 sense 180:20 214:8 312:3 155:12,13 251:8,9 space 162:22 securities 152:20 sensitive 177:21 sheets 311:11,13 260:19 272:6 231:12,17 153:9,16,17 sent 147:19 247:15 she'll 179:8 sit 155:15 278:21 Speak 167:15,17 169:15 181:15 247:18 263:4,6 shocked 220:1 280:4 speaking 224:18 193:8,9 195:1 separate 285:1 short 237:10 sitting 301:16 241:18 Esquire Deposition Services MD - 1-800-539-6398 D.C. - 1-800-441-3376 VA - 1-800-752-8979 Case 1:05-cv-01483-JDB Document 33-8 Filed 06/21/2007 Page 67 of 74 Marialice Williams Page 20 specific 223:9 265:12 304:15 279:8 297:6 232:17 237:4 155:2 161:11 300:15 301:17 statements 199:14 305:19 249:4 253:5 185:21 198:7,9 specifically 142:9 223:5,17 271:4 stunned 191:11 255:16 256:13 204:18 231:5 145:7 182:4 States 132:1 136:13 stupid 223:3,6 257:10 258:2 232:20,22,22 217:17 222:19 136:16 137:6 subcommittee 283:10 296:5,15 233:6,7 234:1,16 225:11 291:4 139:18 187:17 256:1 297:4 303:6 234:20 237:5 301:5 248:11 253:22 subdivision 252:18 survive 180:4 252:10 257:14,15 specifics 142:10 303:14 252:19,20 260:10 257:22 258:11,13 spelling 248:15 status 306:13 subject 136:7 sus 150:11 258:20 259:2,9 303:20 statutory 301:19 147:15 191:19 suspect 149:22 261:13,21 262:2 spend 287:22 stay 182:7 281:18 subordinate 169:15 Swiss 270:5 262:19,21 263:9 spending 215:1 288:2 304:1 306:6 subpoena 139:17 sworn 138:13 310:5 263:10,12,14,16 256:8 stealing 211:8 139:21 140:1,3,6 system 181:5 265:12,16 266:3 spent 162:5 204:19 Stearns 270:6 140:9 142:15 266:13,13 268:8 272:11 stenotype 310:6 143:2,19 145:4,12 T 268:13 271:3 spinning 214:22 stepped 241:10 146:10 149:15,20 T 136:1,1 272:9,12 273:11 split 162:12 207:14 steps 303:6 150:7,11 151:6,20 table 175:22 210:1 273:14 274:16 211:22 212:5,8,17 stop 236:21 152:2,9 155:18 220:15 275:13 276:18,20 212:19 213:3 stopped 236:18,19 163:15 165:19 tactic 204:8 277:2,8,13 279:17 spoke 165:3 171:11 storage 142:18 subpoenas 160:4 take 151:9 153:14 279:19 280:5 spouse 284:3 143:9 144:11 subscriptions 167:10 181:21 281:10 282:11,20 spring 165:22 156:13 157:5,5,9 296:12 183:9 185:18 283:8,18 285:3,4 staff 178:6 194:13 157:14,18 158:1 subsequently 190:2 186:8 237:9 277:8 285:10 286:7,13 Stafford 164:12 158:15,19 159:13 subsidiary 193:3 280:14 303:6 287:9,19 288:19 stalling 204:7 159:22 160:1,4,7 substantial 176:15 304:8 306:18 288:22 289:3 stamp 136:6,9 160:11 206:22 taken 137:10 157:9 290:19 291:4 139:12 150:19 store 159:13 substantially 225:4 157:13 185:10 292:22 295:20,22 stand 205:22 stored 149:6 150:7 substituting 154:22 189:15 197:19 296:10 298:3 standard 181:19 158:9 subterfuge 214:9 206:17 237:15 299:6 300:2,4,8 212:20 228:4 story 160:1 suitable 230:13 240:4 310:3,6,11 300:10 301:11 229:8 strange 213:20 Suite 134:5 311:3 takes 169:18 303:7,13,18,19 Star 139:20 Strategist 292:3 311:14 312:2 talk 154:13 179:13 taxable 189:9 start 174:8 182:15 Strategists 300:4 summarize 172:19 179:18 191:7,14 taxes 258:19 259:1 201:11 234:3 strategy 156:9,21 summer 201:20 210:18 238:13 taxpayer 251:13 started 172:4 Street 133:11 134:4 supervisor 178:3 talked 154:11 team 175:20,21 173:20 219:7,10 134:11,18 137:11 supervisory 177:17 179:15 196:5 176:1 235:7 236:18 137:17 157:5,19 182:8 256:13 270:18 technique 204:7 state 137:19 238:18 236:10 311:2,13 support 200:3 talking 228:9 telephone 146:14 250:9 303:10 312:1 202:21 236:12 156:8 232:12 stated 156:6 175:13 strike 274:2 295:9 supposed 305:11 tangential 299:17 273:22 276:1 187:14 291:7 structure 149:12 305:22 tape 216:3,9 277:18,22 278:5 295:20 195:14 196:13 sure 150:9 152:3 task 169:21 telephones 276:4,5 statement 136:13 structures 224:17 179:8,21 189:12 tasks 180:13 tell 140:15 142:10 199:19 248:10 Stuart 184:9 189:14 210:3 Tawa 232:1 142:21 143:12 249:13 254:19 stuff 270:1 277:2 215:9 218:6 224:5 tax 136:18,19,21 144:20 145:1,6,7 Esquire Deposition Services MD - 1-800-539-6398 D.C. - 1-800-441-3376 VA - 1-800-752-8979 Case 1:05-cv-01483-JDB Document 33-8 Filed 06/21/2007 Page 68 of 74 Marialice Williams Page 21 147:4 162:19 298:12 307:20 300:17 305:2 217:21 219:9,19 191:13 241:11 173:3,9 175:14 308:1 306:8 220:2,10,19 221:2 246:20 179:12 183:17,21 that'd 307:7 third 140:12,15 235:8 236:1,5,6 tomorrow 182:9 184:1 191:12 thereto 249:14 148:12 251:19 238:5,8 239:17 204:14 284:2 217:3 222:4 223:9 thing 149:14 thirty 311:12 240:13 241:19 torn 167:6 223:11,13 226:17 166:16 167:14 thought 143:13,14 242:11,13,16,19 tortious 202:21 226:18 228:7 174:13 207:20 161:19 169:5 243:11,14 244:6 tortiously 203:13 229:14 239:21 211:9 214:11 170:10 176:10,21 247:22 254:20 totally 245:12 240:7 249:18 228:8 260:19 178:3 181:21 255:16 256:1 totals 269:9 259:4 261:5 266:9 269:11 275:16 188:9,17 191:13 258:19 260:21 touch 270:8 267:6 274:8 275:6 278:21 287:16 194:9 203:5 263:17 279:15 town 174:20 175:1 277:12 278:12 things 142:18 209:19,20 210:15 281:8,21 283:12 175:7,8,11 288:14 290:5,16 153:12 155:20 211:3,4 252:2 290:5,11 291:6 track 169:19 226:1 290:16 156:10 158:11 271:16,17 297:7,7 304:18 275:21 telling 168:18 159:2,8,21 172:4 thoughts 179:6 306:18 tracking 226:2 203:15 296:6 176:12 218:1 thousand 230:15 times 168:8,8 traditionally 153:7 tells 278:20 279:14 220:15 222:4,17 269:8 190:21 227:17 trailing 167:18 temporary 274:17 222:20 223:2,10 three 140:20 141:2 234:9 247:4 training 178:5 274:21 275:1,3,5 234:19 280:8 146:17 147:3,5 268:19 275:20 transaction 196:13 275:13,15 297:2 299:3 304:3 148:3 177:18 286:20 287:5,6,13 225:11 238:1 297:12 think 145:14 147:8 201:12 205:3 289:9 290:20 transactions ten 146:17 221:19 148:7,14,14,15 229:21 232:12,13 291:14 152:20 155:1 226:12 280:19,20 149:1 156:12 234:8 238:7 timing 161:14 202:7 225:2,7 281:14 161:7,12 162:4,19 242:18 246:6 tired 286:16 228:4,5 229:9 tended 181:19 164:3 167:6 268:20 287:5 today 139:1 155:15 238:6 term 152:7 224:5 169:22 170:14,15 thrust 256:17 185:20 186:13 transcript 289:12 275:2 170:19 172:4,20 till 236:7 204:13 278:11,13 311:9,12,13 terminated 188:22 176:7 177:2 179:1 time 137:9 139:3 281:17 285:4 transcription 190:13 184:13 188:11 142:19,21 143:8 Today's 137:8 309:10 termination 141:19 190:20 191:9,16 143:15 144:20 told 165:4,5 166:4 transitional 142:19 terms 154:21 196:1,2 197:1 145:20,22 146:18 171:19 173:14 travel 233:11,12 211:13 235:4 202:3 207:16,17 150:15 153:10 174:1 175:10 234:3,12 255:17 terrible 222:17 207:18 208:14,22 157:7,20 158:6,12 181:13 184:12,13 255:17,19 256:6,7 223:2,10 209:10 211:17 158:15 159:17 188:17 205:19 257:8 259:14 testified 138:14 217:6,22 223:8,11 163:6 165:2,17 211:19 214:11,12 270:15 271:8,20 147:3 157:3 244:5 223:13 224:10 168:17 169:11,16 222:3,12 223:10 272:3 273:3 295:6 testimony 138:22 225:16 231:9,14 169:18,22 170:13 240:1 272:5 295:10 302:19 139:5 216:5,10 231:15 232:21 170:15 171:15 276:21,22 278:14 traveling 150:3 261:2 266:9,10 236:4 238:11 174:3 179:12 282:1 283:12 157:6 267:6 286:3 308:4 246:16 247:20 180:1,1 182:11 284:13 285:12 treat 173:20 174:11 309:9,10 310:4,5 248:3 249:8 183:8,16 184:20 286:14 287:10,13 241:2,11 310:8 250:18 266:12 185:4,5 189:7 288:8,20 290:19 treated 165:9 Texas 234:10 270:13 272:15,20 192:15 194:10,22 291:13 304:1,8,15 177:10,16 183:18 Thank 139:11 277:1,15 279:14 202:22 208:17 304:17 240:3,5 221:20 248:8 282:5 290:22 211:6 212:4 214:6 Tom 188:1,5 191:9 treatment 174:7 Esquire Deposition Services MD - 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1-800-539-6398 D.C. - 1-800-441-3376 VA - 1-800-752-8979 Case 1:05-cv-01483-JDB Document 33-8 Filed 06/21/2007 Page 72 of 74 Marialice Williams Page 25 7 7 132:18 133:4 136:15 187:6 253:21 7th 137:8 216:6,10 701 230:5 8 8131 140:12 8133 136:6 139:13 8142 152:5 8144 136:9 150:20 9 9 136:6 139:10,12 139:16,17 9/11 158:7 93 201:14 94 201:13 95 201:13 98 201:13 227:15 244:9 99 227:15 Esquire Deposition Services MD - 1-800-539-6398 D.C. - 1-800-441-3376 VA - 1-800-752-8979 Case 1:05-cv-01483-JDB Document 33-8 Filed 06/21/2007 Page 73 of 74 1 Case 1:05-cv-01483-JDB Document 33-8 Filed 06/21/2007 Page 74 of 74