Case 1:05-cv-01483-JDB Document 33-4 Filed 06/21/2007 Page 1 of 54 EXHIBIT B Case 1:05-cv-01483-JDB Document 33-4 Filed 06/21/2007 Page 2 of 54 Marialice Williams Page 1 UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA ------------------------- X MARIALICE BATHRUS ) WILLIAMS, ) Civil Action No. Plaintiff, ) 1:05CV01483 vs. ) Judge John Bates FEDERAL NATIONAL MORTGAGE) ASSOCIATION, et al., ) Defendants. ) ------------------------- X Videotaped Deposition of Marialice Bathrus Williams Wednesday, March 28, 2007 Washington, D.C. Pages 1 - 131 Volume 1 Job No.: 179392 Reported by: Deborah Larson Hommer, RPR Esquire Deposition Services MD - 1-800-539-6398 D.C. - 1-800-441-3376 VA - 1-800-752-8979 af779bd1-e112-4d83-87a0-2544073c0e93 Case 1:05-cv-01483-JDB Document 33-4 Filed 06/21/2007 Page 3 of 54 Marialice Williams Page 2 Page 4 1 1 Fannie Mae 2 2 3900 Wisconsin Avenue, N.W. 3 Wednesday, March 28, 2007 3 Washington, D.C. 20016 4 10:30 a.m. 4 (202) 752-6167 5 5 jonathan_griffith@fanniemae.com 6 6 BY: Jonathan Griffith, Esquire 7 Videotaped Deposition of MARIALICE BATHRUS 7 8 WILLIAMS held at the offices of: 8 Also Present: 9 9 Robert Cherouny, Videographer 10 O'Melveny & Myers LLP 10 11 1625 Eye Street, N.W. 11 12 Conference Room 10D 12 13 Washington, D.C. 20006 13 14 14 15 Pursuant to notice, before Deborah Larson 15 16 Hommer, Registered Professional Reporter and 16 17 Notary Public in and for the District of 17 18 Columbia. 18 19 19 20 20 21 21 22 22 Page 3 Page 5 1 APPEARANCES: 1 INDEX 2 On Behalf of Plaintiff MARIALICE WILLIAMS 2 3 Law Offices of Harley Jay Daniels 3 EXAMINATION OF WILLIAMS BY PAGE 4 5511 Second Street, N.W. 4 Ms. Becker 7 5 Washington, D.C. 20011 5 6 (202) 468-7737 6 WILLIAMS DEPOSITION EXHIBITS: PAGE 7 harleydaniels@hotmail.com 7 1 - E-mail and attachment from Jones to 8 BY: Harley Jay Daniels, Esquire 8 Noble, et al., dated 5/15/01 33 9 9 2 - Unsigned letter from Williams to 10 On Behalf of the Defendants FEDERAL NATIONAL 10 Huebscher 75 11 MORTGAGE ASSOCIATION, et al. 11 3 - E-mail from Williams to Newman, 12 O'Melveny & Myers LLP 12 et al., dated 5/3/01 79 13 1625 Eye Street, N.W. 13 4 - Unsigned letter from Jones to 14 Washington, D.C. 20006-4001 14 Williams dated 8/6/00 79 15 (202) 383-5300 15 5 - E-mail and attachments from 16 ebecker@omm.com 16 Hartsfield to Grove dated 6/14/02 80 17 kgrundeman@omm.com 17 6 - Mutual non-disclosure agreement 87 18 sgoldfrank@omm.com 18 7 - Defendants' first set of requests 19 BY: Evelyn L. Becker, Esquire 19 for production of documents 90 20 Kyra A. Grundeman, Esquire 20 8 - Deposition of Marialice Williams 21 Sarah Alexander Goldfrank, Esquire 21 dated 3/17/03 109 22 22 (Exhibits retained by the reporter.) 2 (Pages 2 to 5) Esquire Deposition Services MD - 1-800-539-6398 D.C. - 1-800-441-3376 VA - 1-800-752-8979 af779bd1-e112-4d83-87a0-2544073c0e93 Case 1:05-cv-01483-JDB Document 33-4 Filed 06/21/2007 Page 4 of 54 Marialice Williams Page 6 Page 8 1 PROCEEDINGS 1 Q. Good morning, Ms. Williams. 2 THE VIDEOGRAPHER: This is tape 2 A. Good morning. 3 number 1 of the videotaped deposition of 3 Q. My name is Evelyn Becker. I am 4 Marialice Williams taken by the Defendant in 4 going to ask you some questions today. Could 5 the matter of Williams versus Fannie Mae. 5 you please state your name for the record. 6 This case is taking place in the United States 6 A. Marialice Bathrus Williams. 7 District Court for the District of Columbia. 7 Q. What is your current address? 8 It's case number 1:05CV01483. This deposition 8 A. 1922 First Street, Northwest, 9 is being held at the offices of O'Melveny & 9 Washington, D.C., 20001. 10 Myers, 1625 Eye Street, Northwest, Washington, 10 Q. How long have you lived at that 11 D.C. Today's date is March 28, 2007, and the 11 address? 12 time indicated at the lower portion of the 12 A. A little over -- two years and 13 television screen currently reads 10:30 a.m. 13 three months. 14 And my name is Robert Cherouny from 14 Q. What was your address immediately 15 the firm of Esquire Deposition Services. I am 15 prior? 16 the certified legal video specialist. And the 16 A. 5722 First Street, Northwest, 17 court reporter is Deborah Hommer, also in 17 Washington, D.C., 20011. 18 association with Esquire Deposition Services. 18 Q. How long did you live at that 19 And will the counsel please introduce 19 address? 20 themselves and indicate which party they 20 A. Since 1980 -- the last time I lived 21 represent. 21 there -- it was a rental property of mine, and 22 MS. BECKER: My name is Evelyn 22 I moved into it. I think for a couple of -- Page 7 Page 9 1 Becker. I represent Fannie Mae, Grace 1 just a couple of years the last time. 2 Huebscher and Richard Lawch. 2 Q. What was your residence immediately 3 MS. GRUNDEMAN: Kyra Grundeman, 3 prior to that? 4 representing Fannie Mae, Grace Huebscher and 4 A. I know this is crazy. I'm nervous, 5 Richard Lawch. 5 so I can't remember the -- oh, 700 New 6 MS. GOLDFRANK: Sarah Goldfrank, 6 Hampshire Avenue, Northwest, Washington, D.C., 7 representing Fannie Mae, Grace Huebscher, 7 20037, I believe. 8 Richard Lawch. 8 Q. How long did you live at that 9 MR. GRIFFITH: Jonathan Griffith 9 address? 10 from Fannie Mae. 10 A. Just about six years, I think. 11 MR. DANIELS: Harley Daniels for 11 Q. You have been deposed before; is 12 Plaintiff Marialice Bathrus Williams. 12 that correct? 13 THE VIDEOGRAPHER: And will the 13 A. Yes. 14 court reporter please swear in the witness. 14 Q. How many times? 15 Thereupon, 15 A. Oh, I don't -- I don't recall. You 16 MARIALICE BATHRUS WILLIAMS, 16 mean overall, like in your life? 17 the Witness, called for examination by counsel 17 Q. Yes. 18 for the Defendants, and, after having been 18 A. Maybe five times, three -- three or 19 sworn by the notary, was examined and 19 four times, I think. I'm 61. I haven't 20 testified as follows: 20 really been in the law much in the last few 21 EXAMINATION BY COUNSEL FOR THE DEFENDANTS 21 years. 22 BY MS. BECKER: 22 Q. You were deposed in the course of 3 (Pages 6 to 9) Esquire Deposition Services MD - 1-800-539-6398 D.C. - 1-800-441-3376 VA - 1-800-752-8979 af779bd1-e112-4d83-87a0-2544073c0e93 Case 1:05-cv-01483-JDB Document 33-4 Filed 06/21/2007 Page 5 of 54 Marialice Williams Page 10 Page 12 1 the CAM Financial litigation; is that correct? 1 General Motors dealer, and it was never 2 A. Yes. 2 corrected. And the car eventually basically 3 Q. Other than the depositions that you 3 blew up. 4 testified at in the course of the CAM 4 Q. Did you receive any money as a 5 Financial litigation, have you been deposed in 5 result of that litigation? 6 any other matters? 6 A. Yes, I did. I'm -- it was -- I 7 A. Yes. 7 think it was whatever was determined to be the 8 Q. What were those matters? 8 value of that automobile, and it was not an 9 A. The members of the board of 9 expensive automobile -- it was 9 or $10,000 or 10 directors of -- the advisory board of WPFW 10 something like that. 11 radio station sued the Pacifica Network on an 11 Q. Did a lawyer represent you in that 12 issue involving governance, and I was deposed 12 case? 13 in that matter. 13 A. Yes. 14 Q. Have you been deposed in any other 14 Q. Who was the lawyer? 15 matters? 15 A. Harley Daniels. 16 A. I'm thinking. I -- I just can't 16 Q. Other than the lawsuits that you've 17 remember if there was any other -- I'm just 17 already testified about, have you been 18 trying to remember. Oh, there was a -- I 18 involved in any lawsuits as a witness? 19 believe there was a deposition at Fannie Mae 19 A. No. 20 in a Fannie Mae case regarding a multi-family 20 Q. Have you been involved in any other 21 securitization between Fannie Mae and a west 21 lawsuits as a party? 22 coast savings & loan, and I thought it was 22 A. No. Page 11 Page 13 1 Coast Savings Bank, which I don't think now 1 Q. You're a lawyer; is that correct? 2 has the same name. I think it has changed 2 A. Yes. 3 names. 3 Q. Are you currently licensed to 4 Q. Have you given testimony in any 4 practice? 5 other depositions? 5 A. Yes, I am. 6 A. Not that I can recall right now. 6 Q. Where? 7 Q. Have you ever given testimony in 7 A. In the District of Columbia. 8 court? 8 Q. Do you currently have an active 9 A. Yes. 9 practice? 10 Q. When was that? 10 A. No. 11 A. In New Mexico I had a suit 11 Q. When is the last time that you had 12 against -- I believe it was General Motors. 12 an active law practice? 13 This was a very long time ago. And I had to 13 A. It would be 1980 -- maybe '81 or 14 testify as to the facts in the case. 14 '82. 15 Q. Can you give me an estimate of the 15 Q. Were you practicing in the District 16 year? 16 of Columbia at that time? 17 A. Approximately 19 -- 1987. 17 A. Yes. 18 Q. Did you sue General Motors? 18 Q. What was the nature of your 19 A. Yes, I did. 19 practice? 20 Q. For what? 20 A. Oh, I'm sorry. I was assistant 21 A. I had an automobile that had a 21 general counsel of the Office of Management 22 major defect, and I had been taking it to the 22 and Budget. It wasn't private practice. I'm 4 (Pages 10 to 13) Esquire Deposition Services MD - 1-800-539-6398 D.C. - 1-800-441-3376 VA - 1-800-752-8979 af779bd1-e112-4d83-87a0-2544073c0e93 Case 1:05-cv-01483-JDB Document 33-4 Filed 06/21/2007 Page 6 of 54 Marialice Williams Page 14 Page 16 1 sorry. 1 position? 2 Q. How long did you serve in that 2 A. No. 3 capacity? 3 Q. What was your next position? 4 A. Only about two years. Maybe less 4 A. My next position was -- when I left 5 than that. 5 there, I went to -- I worked at HUD, Housing 6 Q. Outside of that position, was there 6 and Urban Development. And I worked as a 7 any other time that you practiced law 7 senior legislative assistant to Patricia 8 actively? 8 Roberts Harris who was the Secretary of HUD at 9 A. Only with the government when I 9 the time. 10 graduated from law school and I went to the 10 Q. Did you practice law in that 11 Department of Justice. 11 position? 12 Q. What was your first position at the 12 A. No. 13 Department of Justice? 13 Q. What was your next position? 14 A. I believe it was just -- they 14 A. I went to OMB and I was the 15 called it just attorney. It was on, I think, 15 assistant director of the civil rights office. 16 a separate schedule from if you were like a -- 16 And then, when David Stockman came in, the 17 some other type of position. 17 titles were changed to -- my title was changed 18 Q. Was that also in the Office of 18 to assistant general counsel. I believe 19 Management and Budget? 19 that's the title. 20 A. No. That was in the civil rights 20 Q. When your title was assistant 21 division in the employment section. 21 general counsel, were you still in the civil 22 Q. How long did you practice in the 22 rights division? Page 15 Page 17 1 civil rights division of the employment 1 A. Yes. 2 section at the Department of Justice? 2 Q. Were you practicing law in that 3 A. Eighteen months. 3 capacity? 4 Q. After that position, did you go to 4 A. No. 5 OMB? 5 Q. Other than the 18 months that you 6 A. No. I went to the Equal Employment 6 were at the civil rights division practicing 7 Opportunity Commission as special assistant to 7 in the employment section, is there any other 8 the chairman. 8 time that you were actively practicing law? 9 Q. How long were you in that position? 9 A. Between working at the 10 A. Just about 18 months there, I 10 administrative office of the U.S. courts and 11 think. 11 before -- no. I'm sorry. I should have 12 Q. What was your next position in the 12 brought my resume. 13 government? 13 My father was an attorney in the 14 A. I worked at the administrative 14 District of Columbia, and from time to time I 15 office of the U.S. courts for the Supreme 15 would practice in his office. When I came 16 Court. 16 back from New Mexico in 1988 before I worked 17 Q. What did you do there? 17 at Fannie Mae I worked with my father in his 18 A. I was -- I performed management 18 office. 19 studies of the east -- of the eastern district 19 Q. How long -- 20 of Virginia federal court and the Connecticut 20 A. In his law office. 21 court. 21 Q. How long did you work there? 22 Q. Were you practicing law in that 22 A. Just a few months. 5 (Pages 14 to 17) Esquire Deposition Services MD - 1-800-539-6398 D.C. - 1-800-441-3376 VA - 1-800-752-8979 af779bd1-e112-4d83-87a0-2544073c0e93 Case 1:05-cv-01483-JDB Document 33-4 Filed 06/21/2007 Page 7 of 54 Marialice Williams Page 18 Page 20 1 Q. Between the few months that you 1 A. No. 2 worked in your father's office and the 2 Q. Did you meet with your attorney? 3 18 months that you worked in the civil rights 3 A. No, we didn't meet -- well, we had 4 division, are those the only times that you 4 one phone conversation. 5 actively practiced law? 5 Q. When was that? 6 A. I have in the last five years had 6 A. Yesterday. 7 an occasional instance where I've practiced. 7 Q. How long was the conversation? 8 For example, I think I may have done a will 8 A. Five minutes. 9 for someone, for one person -- two people. I 9 Q. Did you bring any documents with 10 represented, as a favor to a friend -- the 10 you today? 11 National Association of University Women had a 11 A. No, I did not. 12 dispute with their interior designer of their 12 Q. Other than your attorney, did you 13 new building. 13 discuss your deposition with anybody else? 14 I'm trying to remember if there are 14 A. No. 15 any other matters. And that's pretty much it. 15 Q. What is Risk Mitigation 16 Q. Were you paid for those 16 Strategists, LLC? 17 representations? 17 A. It doesn't exist anymore, but what 18 A. I was paid by -- yes, I was paid. 18 it was was a company that was formed when I 19 Q. I got a little bit of ahead of 19 left Fannie Mae to continue to pursue the 20 myself in some of those questions, but let me 20 business that I had been doing at Fannie Mae 21 go back and ask if there is any reason that 21 prior to my departure. 22 you're not able to give full and truthful 22 MS. BECKER: Can you read back her Page 19 Page 21 1 testimony here today? 1 answer. 2 A. No. 2 (The reporter read the record as 3 Q. Are you on any medication that 3 requested.) 4 would preclude you from giving complete and 4 BY MS. BECKER: 5 full testimony today? 5 Q. When was it formed? 6 A. No. 6 A. 19 -- I believe in 1988. 7 Q. Did you do anything to prepare for 7 Q. You said it no longer exists. When 8 your deposition today? 8 did it stop existing? 9 A. Yes. 9 A. It still exists, but not as an LLC. 10 Q. What did you do? 10 Q. What does it exist as currently? 11 A. I reviewed a number of the 11 A. I have a person with whom I have 12 information -- a number of -- some of the 12 been working over a number of years who, along 13 information that was provided by O'Melveny & 13 with myself, we still get a show of interest 14 Myers as a result of a request for documents. 14 from people who want to pursue the product 15 Q. These were documents produced by 15 that I developed at Fannie Mae. 16 Fannie Mae? 16 Q. What type of entity is it 17 A. Yes. 17 currently? 18 Q. Did you review all of those 18 A. It's just my own business. It's 19 documents? 19 under sole proprietorship. 20 A. I reviewed a great deal of it. 20 Q. Who is this other person that you 21 Q. Did you do anything else to prepare 21 were referring to? 22 for your deposition? 22 A. I work with Harvey Hartsfield. 6 (Pages 18 to 21) Esquire Deposition Services MD - 1-800-539-6398 D.C. - 1-800-441-3376 VA - 1-800-752-8979 af779bd1-e112-4d83-87a0-2544073c0e93 Case 1:05-cv-01483-JDB Document 33-4 Filed 06/21/2007 Page 8 of 54 Marialice Williams Page 22 Page 24 1 Q. How is it that it stopped being an 1 A. No, not the LLC. 2 LLC? 2 Q. Has anyone else been associated 3 A. When I moved out of my offices in 3 with RMS since its LLC status lapsed? 4 the Watergate office building and moved 4 A. Yes. 5 into -- my office into my home at 5722 First 5 Q. Who was that? 6 Street, I just don't think I paid the annual 6 A. Tim Webb worked with me as RMS on a 7 fee. And then your -- you know, the -- the 7 project at the Department -- D.C. Department 8 District of Columbia government regulates 8 of Mental Health, attempting to procure 9 that. It just lapsed. 9 financing for the new St. Elizabeth's 10 Q. When did you move out of the 10 Hospital. 11 Watergate? 11 Q. When did that occur? 12 A. I think it was 2001. 12 A. That was three years ago, I 13 Q. What month? 13 believe. Let's see. 2007... 14 A. I believe -- it was May or June, I 14 Q. During both the time when RMS was 15 believe, of that year. 15 an LLC and the time when it was not an LLC, 16 Q. Do you know when the status of RMS 16 can you identify the clients of RMS? 17 as an LLC lapsed? 17 A. RMS worked with Red Mortgage 18 A. I really don't recall exactly. 18 Capital. It was a DUS lender of Fannie Mae. 19 Q. Do you have any documentation from 19 They worked with Aries Capital. We worked 20 the government indicating that its status as 20 with, for a short time, Washington Mortgage. 21 an LLC lapsed? 21 Oh, goodness. We worked with Countrywide. We 22 A. No. 22 worked with First Atlantic Guarantee Page 23 Page 25 1 Q. Are there any documents that could 1 Corporation. We worked with Swiss Re. We 2 identify when the status of RMS as an LLC 2 worked with Marsh Mac. 3 lapsed? 3 We worked with -- we worked with 4 A. I don't think so. 4 Lend Lease Bovis. We worked with -- we worked 5 Q. When is the last time that you paid 5 with Pinnacle Mortgage. We worked with the 6 the annual fee for the LLC? 6 Thurgood Marshall Center. We worked with 7 A. I don't recall. 7 Zurich AIG Insurance Companies. We worked 8 Q. Was it sometime in 2001? 8 with quite a few reinsurers. Morgan Stanley, 9 A. I don't recall. 9 Metropolitan Savings. We worked for Eric 10 Q. Who were the officers of Risk 10 Rosenfield, investment banker. 11 Mitigation Strategists, LLC? 11 We worked with -- that's not a 12 A. Myself and Harvey Hartsfield. 12 complete list, but that's a lot of them. Some 13 Q. What was your title? 13 of them were short relationships and didn't -- 14 A. President. 14 you know, I just, you know, can't recall all 15 Q. What was Mr. Hartsfield's title? 15 of them, sitting here. 16 A. Vice president. 16 We worked with Fannie Mae. I think 17 Q. Were there any employees -- 17 I said that. We worked with CAM Financial. I 18 A. No. 18 forgot to put them in there, I think. 19 Q. -- of RMS? 19 Q. Can you recall any other clients of 20 A. No. 20 RMS? 21 Q. Was there anyone else associated 21 A. We worked with -- oh, goodness. 22 with RMS? 22 Just -- what's his name? Let's see. That's 7 (Pages 22 to 25) Esquire Deposition Services MD - 1-800-539-6398 D.C. - 1-800-441-3376 VA - 1-800-752-8979 af779bd1-e112-4d83-87a0-2544073c0e93 Case 1:05-cv-01483-JDB Document 33-4 Filed 06/21/2007 Page 9 of 54 Marialice Williams Page 26 Page 28 1 about all I can -- I know there were other 1 to insure -- the risk is what they call 2 people. I can even see some of them. I just 2 pari passu so that when you're reaching 3 am not able to put names to them. If they 3 through the second level of risk, it's shared 4 come out later, I can -- I will write them. 4 by Fannie Mae and the lender. And the cost 5 Q. What was the nature of the work 5 was going to be much less expensive if Fannie 6 that you did with Red Mortgage Capital? 6 Mae would join with the lender and also lay 7 A. We were pursuing the possibility of 7 off that same -- its portion of that secondary 8 laying off risk associated with pools of 8 risk level. 9 mortgages and individual loans that had been 9 BY MS. BECKER: 10 originated by a number of DUS lenders. And I 10 Q. How long were you in discussions 11 don't know if you're familiar with how the 11 with Red Mortgage Capital? 12 structure works on the DUS loans, how the risk 12 A. For about two years, I believe. 13 is borne between the parties or split between 13 Q. What time frame was that? 14 the parties. Are you familiar with how that's 14 A. It would be beginning in 1998. 15 done on that? 15 Q. So it would have been 1998 to 2000, 16 Q. I'm sorry. This is your 16 approximately? 17 deposition. 17 A. It could have been longer than 18 A. Well, I was -- 18 that. The -- yes, it could have been longer 19 MR. DANIELS: We have a question -- 19 than that. 2001, perhaps. 20 THE WITNESS: -- just asking so 20 Q. Do you have any recollection of any 21 that -- 21 discussions with Red Mortgage Capital that 22 MR. DANIELS: Go ahead. 22 extended beyond 2000 or 2001? Page 27 Page 29 1 THE WITNESS: -- I could answer 1 A. There could have -- could have been 2 your -- I didn't want it not to make sense to 2 communication on my part because I did 3 you. 3 prepare, from time to time, updates about 4 In Fannie Mae DUS transactions, 4 things that were going on in the marketplace 5 often there is -- not often, but there is 5 with respect to insurance vis-a-vis the 6 always some level of risk associated with the 6 risk -- laying off of risk. 7 loan that's either being securitized or being 7 And I would -- and there were also 8 purchased. And the way that that risk breaks 8 a lot of issues pertaining to how certain 9 out is that the first level of risk belongs to 9 forms of collateral were perceived by 10 the Red Mortgage or the Lend Lease or whoever 10 regulatory -- regulatory entities. And so I 11 the DUS lender is, and then there is another 11 would try to keep my people up to date through 12 level of risk that is shared by Fannie Mae and 12 a newsletter or an e-mail or whatever, and I 13 by the DUS lender. 13 often did that. I just can't tell you exactly 14 And Fannie Mae had, at that time, 14 when the last time is I did that. 15 over $90 billion worth of DUS product. And I 15 Q. Do you have a recollection of any 16 had been asked by Red Mortgage and Lend Lease 16 specific communications with Red Mortgage 17 and others to try to come up with an insurance 17 Capital after 2000 or 2001? 18 that would, in fact, absorb that -- either the 18 A. No, I don't. 19 primary or the secondary level of risk for 19 Q. What was the time frame of your 20 those individuals. And ultimately what we 20 discussions with Lend Lease? 21 uncovered when we did our research was that 21 A. Let's see. I flew to Dallas to 22 the insurance companies would have preferred 22 meet with them 2001, I believe. 8 (Pages 26 to 29) Esquire Deposition Services MD - 1-800-539-6398 D.C. - 1-800-441-3376 VA - 1-800-752-8979 af779bd1-e112-4d83-87a0-2544073c0e93 Case 1:05-cv-01483-JDB Document 33-4 Filed 06/21/2007 Page 10 of 54 Marialice Williams Page 30 Page 32 1 Q. Do you remember when in 2001? 1 negotiation with Sid Gett from Aries Capital 2 A. It was in the summer, but I'm -- I 2 as recently as two years ago, I believe. 2004 3 believe it was August. 3 or '5. 4 Q. Is that the only communication you 4 Q. Did the nature of the business that 5 ever had with Lend Lease? 5 you were attempting to do with Aries Capital 6 A. No. I had daily contact with all 6 relate to Fannie Mae? 7 of these people. When you're doing product 7 A. I'm sorry? 8 development, you always have to -- it's very, 8 Q. Did the nature of the business that 9 you know, by the book. You have -- there are 9 you were attempting to do with Aries Capital 10 so many issues, so you're constantly dealing 10 relate to Fannie Mae? 11 with issues regarding their portfolio or their 11 A. Yes. 12 originating, what's going on in the insurance 12 Q. Explain that. 13 side, because there is no compatibility 13 A. My expertise is in product 14 between the insurance industry and the 14 development, and all investment banking firms 15 mortgage industry on that level. 15 and mortgage companies are looking for 16 Q. What was the time frame of your 16 solutions to the issue of risk associated with 17 daily communications with Lend Lease? 17 their portfolios. And most people -- a lot of 18 A. Probably through that same time 18 people were trying to find less expensive ways 19 through until 2001. Maybe some communication 19 to lay off that risk or not have to post, 20 in 2002. 20 quote/unquote, collateral that consisted of a 21 Q. Do you have a recollection of any 21 portion of their mortgage-backed securities or 22 specific communications after 2001 with Lend 22 their REMIC securities. Page 31 Page 33 1 Lease? 1 So I was always attempting to find 2 A. Not specifically, no. I can't 2 insurance companies that would work with these 3 recall a specific communication with them. 3 lenders to come up with products based in 4 Q. What was nature of RMS' 4 large part on what I had developed at Fannie 5 relationship with Aries Capital? 5 Mae. 6 A. I had a very close relationship 6 Q. In previous discovery and in some 7 with Aries Capital. I was invited on an 7 of the court papers there has been discussion 8 annual basis to their annual meeting which 8 of a May 2001 proposal. Do you understand 9 they generally held -- since they were from 9 what that term means? 10 Chicago, they generally held it someplace 10 A. I am just trying to remember -- no. 11 warm. And we stayed -- we're actually still 11 If you can give me a little -- I could -- 12 in contact with one another. 12 MR. DANIELS: I didn't hear the 13 Q. What type of business, if any, did 13 term. 14 you do with Aries Capital? 14 MS. BECKER: May 2001 proposal. 15 A. We tried to do DUS business. We 15 THE WITNESS: I don't know why I'm 16 tried to do some more generalized 16 blocking on it. I just -- I know that -- I 17 securitization transactions, but we did not 17 know that it's there. I know that I responded 18 close any deals at all. 18 to it. I'm just blanking right now on what it 19 Q. What was the time frame in which 19 is. So if you could tell me, I could tell you 20 you were attempting to do DUS business and 20 about it. 21 other business with Aries Capital? 21 (Deposition Exhibit No. 1 was 22 A. Let's see. I had lunch in 22 marked for identification.) 9 (Pages 30 to 33) Esquire Deposition Services MD - 1-800-539-6398 D.C. - 1-800-441-3376 VA - 1-800-752-8979 af779bd1-e112-4d83-87a0-2544073c0e93 Case 1:05-cv-01483-JDB Document 33-4 Filed 06/21/2007 Page 11 of 54 Marialice Williams Page 34 Page 36 1 BY MS. BECKER: 1 Mitigation Strategists, LLC; is that correct? 2 Q. I am going to hand you what has 2 A. I'm not certain if we were still an 3 been marked as Exhibit 1. Do you recognize 3 LLC then or not. I would have to see. 4 this document? 4 Q. If I could direct -- 5 A. I see what it is. 5 A. Unless we put LLC on it -- I mean, 6 Q. What is it? 6 we stopped using it after a while. 7 A. It's an e-mail, it appears, from 7 Q. If I could direct your attention to 8 Bob Jones at CAM Financial to Steve Noble at 8 the top -- 9 Zurich and myself and Danny Groves. 9 A. Yes, I see it. 10 Q. And what is it discussing? 10 Q. -- of the first page. Does that -- 11 A. It discusses a structure for 11 A. Risk Mitigation Strategists, LLC, 12 providing insurance that I really just 12 yes. 13 described to you about the mezzanine tranche 13 Q. Does that refresh your recollection 14 of risk associated with Fannie Mae's DUS 14 as to whether the May 2001 proposal was made 15 loans. 15 by Risk Mitigation Strategists, LLC? 16 Q. And what's the date of this e-mail? 16 A. Yes. 17 A. May 15, 2001. 17 Q. And was the proposal made by Risk 18 Q. There is an attachment to the 18 Mitigation -- 19 e-mail; is that correct? 19 A. It was made by Risk Mitigation 20 A. Yes. 20 Strategists, LLC, I believe. 21 Q. And what is the attachment? 21 Q. Did any of the discussions that you 22 A. The attachment is a description 22 had with Aries Capital relate to the May 2001 Page 35 Page 37 1 written by me, I believe, about how to 1 proposal? 2 actually -- it's a description of what Bob 2 A. Yes. 3 is -- it's a broader description of what Bob 3 Q. What was the time frame of the 4 is describing in the front of the e-mail. 4 discussions that you had with Aries Capital 5 MR. DANIELS: I'm sorry. How was 5 that related to the May 2001 proposal? 6 that marked for identification? 6 A. All of those individuals that I 7 MS. BECKER: Exhibit 1. 7 previously stated I was working with at the 8 BY MS. BECKER: 8 exact same time. When I would send a message 9 Q. Does this e-mail and the attachment 9 to Lend Lease, it would go to Red Mortgage, it 10 refresh your recollection as to your May 2001 10 would go to Aries, it would go to the cadre of 11 proposal to Fannie Mae? 11 people that were looking for relief. 12 A. Yes. I now know exactly what 12 Q. And what was the time frame of 13 you're talking about. 13 those discussions? 14 Q. Can you explain for the record so 14 A. From 1998 until the present time, 15 it's clear what your May 2001 proposal to 15 but not actively -- I mean, I am still now 16 Fannie Mae was? 16 working with not those lenders but other 17 A. I was attempting to assist DUS 17 lenders to look at those options as well. 18 lenders and others in their efforts to 18 That's still an ongoing thing that I do. But 19 eliminate the risk associated with selling or 19 not related to the DUS proposal because that 20 securitizing multi-family mortgage loans with 20 only affects DUS lenders. 21 Fannie Mae. 21 Q. When is the last time that you had 22 Q. This proposal was made by Risk 22 communications with Aries Capital relating to 10 (Pages 34 to 37) Esquire Deposition Services MD - 1-800-539-6398 D.C. - 1-800-441-3376 VA - 1-800-752-8979 af779bd1-e112-4d83-87a0-2544073c0e93 Case 1:05-cv-01483-JDB Document 33-4 Filed 06/21/2007 Page 12 of 54 Marialice Williams Page 38 Page 40 1 the DUS proposal? 1 forgot to tell you something earlier. You 2 A. I don't recall. 2 asked me a question and I left out something 3 Q. Would it be fair to say any 3 important. When I went to Fannie Mae, I went 4 communications that you had with Aries Capital 4 to the general counsel's office, so I was 5 relating to the DUS proposal would have been 5 there for just about six months, I think, 6 in the same time frame that you were having 6 before I transferred to the multi-family 7 communications with Fannie Mae regarding the 7 division. 8 DUS proposal? 8 Q. And you were practicing law while 9 A. Yes and no, because Fannie Mae does 9 you were at Fannie Mae? 10 not facilitate or work directly with -- was 10 A. I reviewed documents, so I guess 11 not working -- I was trying to come up with a 11 you could call that practicing law. But there 12 way to lay off cap -- to lay off risk with 12 was no courtroom or court appearances or 13 these -- with this group of people -- of 13 anything of that nature. 14 lenders. When I thought there was a need to 14 Q. Do you recall any communications 15 involve Fannie Mae further in the discussion, 15 that you had with Fannie Mae relating to Aries 16 we might contact them or say something to 16 Capital after 2001? 17 them, but it did not mean that we were not 17 A. I don't recall. I believe there 18 working on pursuing our end of the -- of the 18 were, but I do not -- I can't tell you the 19 deal. 19 exact date. 20 In other words, Fannie Mae was not 20 Q. Who were those communications with? 21 paying me to do product development for them. 21 A. When I talked to Fannie Mae, I 22 I had to develop the product and then go to 22 generally spoke to either Rhoda Newman or Page 39 Page 41 1 them. 1 Richard Lawch, or I spoke to someone in the 2 Q. When is the last discussion that 2 credit policy office or I spoke to someone in 3 you recall with Aries Capital relating to the 3 the counsel's office, just depending on what 4 DUS proposal -- 4 the issue was. 5 A. I really don't -- 5 Q. Who in the credit policy office did 6 Q. -- to Fannie Mae? 6 you talk to? 7 A. I don't remember. 7 A. I can describe him, but I am 8 MR. DANIELS: Can we go off the 8 blanking on his name -- yes, I can remember 9 record for a moment? 9 his name. His name was Jeff Arpin, I believe. 10 MS. BECKER: Sure. 10 Q. Who did you talk to in the 11 THE VIDEOGRAPHER: The time is 11 counsel's office? 12 11:25. We're going off the record. 12 A. It was usually Paul van Hook or 13 (Recess.) 13 David Kalinsky or Kathy Miles. Oh, and also 14 THE VIDEOGRAPHER: The time is 14 Dan -- I can't recall his last name, but he 15 11:36. We're back on the record. 15 was specifically assigned to handle insurance 16 BY MS. BECKER: 16 matters. 17 Q. Ms. Williams, when is the last time 17 Q. Is it fair to say that you don't 18 that you communicated with Aries Capital -- 18 recall any communications with anyone at 19 I'm sorry. When is the last time that you 19 Fannie Mae regarding Aries Capital after 2001? 20 communicated with Fannie Mae regarding Aries 20 A. No, that's not fair to say. I 21 Capital? 21 don't recall at this time. I just am not 22 A. I really don't recall. Oh, I 22 remembering when the last time is I spoke with 11 (Pages 38 to 41) Esquire Deposition Services MD - 1-800-539-6398 D.C. - 1-800-441-3376 VA - 1-800-752-8979 af779bd1-e112-4d83-87a0-2544073c0e93 Case 1:05-cv-01483-JDB Document 33-4 Filed 06/21/2007 Page 13 of 54 Marialice Williams Page 42 Page 44 1 them. 1 I have an appointment Friday, for 2 Q. So can you remember any specific 2 example, with someone who wants to look at the 3 communications with anyone at Fannie Mae 3 possibility of doing some variation on the 4 regarding Aries Capital after 2001? 4 insurance product and possibly use Fannie Mae. 5 A. I can't specifically remember them, 5 Q. Who is that appointment with? 6 no. 6 A. I cannot disclose that at this 7 Q. Do you have any documentation that 7 time. 8 would show any communications with Fannie Mae 8 Q. Can you tell me what the nature of 9 regarding Aries Capital after 2001? 9 your last communications with Fannie Mae 10 A. I don't think so. I don't -- it 10 regarding Aries Capital would have been? 11 would have been phone calls, and I didn't 11 A. No, I can't. I can't tell you. It 12 record phone calls. 12 would have been something related to 13 Q. Do you have any recollection of 13 attempting to either do the DUS business -- 14 with whom you might have spoken at Fannie Mae 14 some form of credit enhancement would have 15 regarding Aries Capital after 2001? 15 been what the discussion would have been 16 A. I think I answered that, which 16 about. 17 would have been all of those people I 17 Q. What business did you do with 18 described. 18 Washington Mortgage? 19 Q. Are you saying that you believe you 19 A. Washington Mortgage called me 20 spoke to all of those people? 20 almost immediately after I left Fannie Mae to 21 A. I may have spoken to them. I just 21 pursue the possibility of laying off their DUS 22 cannot remember the day, the time or the hour 22 risk. Page 43 Page 45 1 or anything like that. But we were ongoing 1 Q. That would have been in 1998? 2 with our attempting to do our product 2 A. That's correct. 3 development, and I believe I spoke with some 3 Q. How long were you in communication 4 of those people or one of those people or one 4 with Washington Mortgage? 5 or more of those people after 2001. 5 A. I don't recall. Months. Maybe a 6 Q. And what is your recollection based 6 year. Not long. Not very long. 7 on? 7 Q. Did you ever do any business deals 8 A. My own head. 8 with Washington Mortgage? 9 Q. Is there anything specific that 9 A. No, I didn't, because Richard Lawch 10 makes you believe that you had a conversation 10 called Shekar Narassiman and told him I was 11 with anyone at Fannie Mae regarding Aries 11 stupid or something like that. It was a 12 Capital after 2001? 12 very -- it was not a nice thing. And I 13 A. I never stopped pursuing the desire 13 stopped working with them. They were very 14 to do business with Fannie Mae. I never 14 thick. 15 stopped the desire to do additional and 15 Q. The time frame in which Mr. Lawch 16 further development of a concept which I was 16 would have made this statement would have been 17 solely responsible for and thought I would be 17 1998; is that correct? 18 making my living from pursuing with promises 18 A. No. I understand he repeated it 19 from people from Fannie Mae. So I was always 19 more or less frequently from that point 20 out there looking to do business that would 20 forward, probably through until this day. 21 specifically take me back to Fannie Mae 21 Q. What's the basis for your belief 22 portfolios and risk. 22 that Mr. Lawch referred to you in that way? 12 (Pages 42 to 45) Esquire Deposition Services MD - 1-800-539-6398 D.C. - 1-800-441-3376 VA - 1-800-752-8979 af779bd1-e112-4d83-87a0-2544073c0e93 Case 1:05-cv-01483-JDB Document 33-4 Filed 06/21/2007 Page 14 of 54 Marialice Williams Page 46 Page 48 1 A. What is the basis for it? I 1 and said, please do not disclose to Fannie Mae 2 overheard a conversation between Alan 2 that we are having these discussions. I asked 3 Greenwald and Shekar Narassiman in which the 3 you not to do that. 4 question of my intelligence was raised, and 4 And I immediately called that 5 that was prior to my departure from Fannie 5 person and said, I sincerely apologize. I did 6 Mae. 6 not mean to -- and I didn't mean to -- why 7 Q. Other than the conversation that 7 would I sabotage myself? I did not mean to 8 you overheard before 1998, do you have any 8 say anything -- did not mean to put the cc on 9 other basis for your belief that Mr. Lawch 9 there; it was an accident. And if you would 10 made comments about you? 10 like for me to call Fannie Mae and explain to 11 A. Yes. When I was dealing with Red 11 them, I will do that. 12 Mortgage Capital, they indicated that they had 12 Q. What was the time frame of that 13 had conversations with Mr. Lawch and they were 13 e-mail? 14 afraid to let him know the extent to which 14 A. I would think sometime in 1999 or 15 they were involved in doing some things 15 2000, perhaps 2001. 16 because -- and I don't know for what reason, 16 Q. Did anyone at Red Mortgage Capital 17 but I think there was some concern that they 17 tell you that Mr. Lawch had made disparaging 18 had that had to do with their relationship to 18 comments about you? 19 Richard Lawch. 19 A. Yes. That person I was just 20 Q. Who did you talk to at Red Mortgage 20 referring to. And I think that's -- I don't 21 Capital about the conversation between them 21 know if he spoke directly to David or not. 22 and Mr. Lawch? 22 Q. What disparaging comments were you Page 47 Page 49 1 A. I can't remember his name right 1 told that Mr. Lawch made about you? 2 now. I could probably find it, but it was 2 A. Just that I may or may not be able 3 through David -- David -- the person in 3 to do what it is I was attempting to do with 4 charge. I'm just blanking on his last name. 4 them and -- more innuendo than specifically -- 5 A very tall gentleman who is a vegetarian. 5 it wasn't as direct as what he said to Shekar. 6 And he had someone who he had assigned to me 6 It was not of that nature. But it was clear 7 to work on this project. And I had an 7 that he was discouraging them from doing 8 independent relationship, meaning I had worked 8 business with me. 9 directly with this person without Mr. Lawch's 9 Q. And when did you learn that 10 knowledge. And he assigned this other person 10 Mr. Lawch was discouraging Red Mortgage 11 to work with me on this -- in pursuing this 11 Capital from doing business with you? 12 type of situation. 12 A. Sometime between 1998 and 2001. 13 Q. When did you have this conversation 13 Q. What was the nature of the business 14 with David? 14 you did with Countrywide? 15 A. I didn't have it with David. I had 15 A. Hal Potter, who had been a 16 it with the person he assigned to me, and it 16 multi-family staff person -- actually, he was 17 was in an e-mail. And he said, I told you not 17 the director of multi-family, I believe, in 18 to -- I know what happened: I cc'd -- I did 18 the California region -- had gone to 19 not mean to cc Fannie Mae on an e-mail in 19 Countrywide to establish a multi-family 20 responding to more than one customer. And 20 program for them. You probably know that most 21 when I did -- and it was on there, and it was 21 of their business is single-family. 22 an accident. And this person e-mailed me back 22 And because the market -- 13 (Pages 46 to 49) Esquire Deposition Services MD - 1-800-539-6398 D.C. - 1-800-441-3376 VA - 1-800-752-8979 af779bd1-e112-4d83-87a0-2544073c0e93 Case 1:05-cv-01483-JDB Document 33-4 Filed 06/21/2007 Page 15 of 54 Marialice Williams Page 50 Page 52 1 everything is driven by the market and the 1 when you flew to California? 2 spreads were so narrow, Countrywide was 2 A. No. 3 looking for a cost-effective way to provide 3 Q. Can you identify the time frame any 4 for credit enhancement and do its own 4 more precisely than 1998 to 2001? 5 securitization so that it didn't have to rely 5 A. No. I can't. I just can't. I was 6 on Fannie Mae because there was so little 6 working every day, 10 hours, 11 hours, 7 profit and they did not want to sell to a 7 12 hours a day, trying to do this product 8 conduit as well. So they were attempting to 8 development. I was working with different 9 form their own program. 9 types of assets, different insurance 10 And I flew to California to meet 10 companies, different insurance brokers, 11 with Hal Potter to discuss it. And sometime 11 different insurance concepts, reinsurers, 12 thereafter Countrywide abandoned their 12 people who were holding automobile loans, 13 decision to do multi-family. I don't know if 13 people who were holding credit card loans, 14 they do it now, but they abandoned it. I 14 because securitization had become that much 15 believe Hal went to another company. 15 more pervasive in the marketplace. 16 Q. Did you ever do a deal involving 16 So that is why it is so difficult 17 Countrywide? 17 to say on March 1, 1998, I did one thing or 18 A. No. 18 another because my days were consumed by that. 19 Q. When did you fly to California? 19 I also relied heavily, mistakenly 20 A. Sometime between 1998 and 2001. I 20 perhaps, on my computer as the source of my 21 believe it was -- sometime between 1998 and 21 calendar. I've had two computer crashes of 22 2001. I flew to California several times. 22 major proportion from which I could not Page 51 Page 53 1 Q. And when did they abandon -- 1 retrieve any information since I left Fannie 2 A. Oh, I don't know that. I don't 2 Mae. And so it's very, very difficult for me 3 know that specifically. 3 to go back and recapture specific dates 4 Q. You said sometime after you flew to 4 associated with specific individuals. I have 5 California they abandoned their decision to do 5 some general idea. I know absolutely what I 6 multi-family; is that correct? 6 did, and I did it daily, as did 7 A. Yes. After I met with Hal, several 7 Mr. Hartsfield, but... 8 months, I believe, went -- and I'm not exactly 8 Q. What type of business did you do 9 certain when they made the decision that they 9 with First Atlantic? 10 were not going to move forward. I don't know 10 A. First Atlantic is a face amount 11 that. 11 certificate company. There are only three in 12 Q. When did you become aware that they 12 the country. And they have a very unique 13 made that decision? 13 structure which enables them to issue 14 A. Sometime after I went to 14 certificates backed by certain types of assets 15 California. I cannot tell you the specific 15 but unique to the certificate structure. Some 16 date. 16 of the limitations that apply to securities 17 Q. Would it have been within a couple 17 and to REMICs as well did not apply to the 18 of months of your traveling to California? 18 certificates. And it looked as if this was 19 A. No, I believe it was maybe as much 19 going to be -- and I still believe it is -- a 20 as a year later. I'm not certain, but it 20 major way to be able to do the types of 21 could have been up to a year later. 21 business with smaller companies so they don't 22 Q. Do you have any records indicating 22 get ripped off by conduits and to do business 14 (Pages 50 to 53) Esquire Deposition Services MD - 1-800-539-6398 D.C. - 1-800-441-3376 VA - 1-800-752-8979 af779bd1-e112-4d83-87a0-2544073c0e93 Case 1:05-cv-01483-JDB Document 33-4 Filed 06/21/2007 Page 16 of 54 Marialice Williams Page 54 Page 56 1 with people who have -- who lend in areas that 1 probably recall this -- when suddenly 2 are not popular, to do affordable mortgages 2 insurance companies, banks, lenders and 3 and that kind of thing, because you can remove 3 everyone began to work together to seek new 4 the asset from the pool and replace it with 4 ways to provide credit enhancement that did 5 something else, which you cannot do in a 5 not conflict or provide issues with respect to 6 mortgage-backed security, and only on a 6 the various aspects of the accounting 7 limited basis in a REMIC, and it has to be 7 regulations which had to be adhered to because 8 predetermined when you're going to make those 8 of the nature of the securities. 9 decisions. 9 And when those rules would change, 10 Q. Did you close any transactions 10 it would change the way you could do business. 11 involving First Atlantic? 11 So you had to constantly go back and look at 12 A. No. 12 new ways to modify, you know, your credit 13 Q. What was the time frame in which 13 enhancement vehicle. 14 you worked with First Atlantic? 14 Q. Did the communications you had with 15 A. I still work with them. I'm 15 Swiss Re relate in any way to RMS' May 2001 16 actually on their board. 16 proposal? 17 Q. Did you ever have any 17 A. Yes, absolutely. 18 communications with Fannie Mae about First 18 Q. What was the time frame of those 19 Atlantic? 19 communications? 20 A. Yes. 20 A. Actually, I had a continuing 21 Q. When was that? 21 dialogue with quite a few insurance companies 22 A. I believe it was between 2001, 22 from 1998 all the way through to the current Page 55 Page 57 1 2002. 1 time. I am meeting with an insurance company 2 Q. What was the nature of those 2 also this week. 3 communications? 3 Q. Which insurance company? 4 A. To inform them that I had yet again 4 A. I can't tell you that. I have a 5 discovered a product that I thought could be 5 confidentiality agreement. 6 helpful to Fannie Mae in fulfilling their 6 Q. When is the last time that you 7 mission to do affordable housing. I spoke 7 communicated to Fannie Mae about Swiss Re? 8 with Rob Levin. I spoke with Rhoda Newman, 8 A. Oh, goodness. Prior to 9/11. I do 9 Grace Huebscher about First Atlantic and the 9 know that because that part of Swiss Re, I 10 concept. 10 believe, was shut down after 9/11. 11 Q. Did these discussions relate to 11 Q. And by 9/11, you mean September 11, 12 RMS' May 2001 proposal? 12 2001? 13 A. No, not at all. It could have been 13 A. Yes. 14 adapted, but no, this was a new concept. 14 Q. What was the nature of the business 15 Q. What was the nature of the business 15 that you did with Marsh Mac? 16 that you did with Swiss Re? 16 A. I worked with Marsh Mac for several 17 A. To attempt to -- they had opened a 17 years trying to find an appropriate insurance 18 section of their company called something -- I 18 company to do the Fannie Mae business. 19 just can't remember the exact name, but it was 19 Q. What were those years that you 20 something associated with risk, almost like a 20 worked with Marsh Mac? 21 risk mitigation unit. And it was the time 21 A. From 1998 through, I believe, 2002. 22 when the insurance companies -- I am sure you 22 Q. When in 2002? 15 (Pages 54 to 57) Esquire Deposition Services MD - 1-800-539-6398 D.C. - 1-800-441-3376 VA - 1-800-752-8979 af779bd1-e112-4d83-87a0-2544073c0e93 Case 1:05-cv-01483-JDB Document 33-4 Filed 06/21/2007 Page 17 of 54 Marialice Williams Page 58 Page 60 1 A. Actually, I have to change my 1 concept would become clear. 2 answer. I still talk to Marsh Mac. But 2 And it was always -- there was 3 you're saying about the May 1 -- May 2001 3 always a regulatory issue involving the nature 4 proposal? 4 of being the owner of the captive insurance 5 Q. Yes. 5 company and the validity of that captive 6 A. I think that was probably around 6 insurance company. And that was clarified -- 7 the same time. September 11, 2001, created, 7 and I wrote a newsletter about that decision 8 as you know, a crisis in the insurance 8 once that decision was made. It was several 9 industry. And much negotiation and discussion 9 years after I left Fannie Mae. So that 10 with companies for that specific type of 10 concept, which had been tentative, then became 11 business was limited or stopped entirely after 11 a true possibility. 12 9/11. 12 Q. Did you ever have any 13 Q. And when you say that type of 13 communications with Pinnacle Mortgage about 14 business, what do you mean? 14 the May 2001 proposal? 15 A. You asked me about the May 2000 15 A. Oh, no. They were not a DUS 16 proposal, yes. 16 lender, yes. 17 Q. And just to clarify for the record, 17 Q. What is the nature of the business 18 you mean the May 2001 proposal? 18 that you did with the Thurgood Marshall 19 A. Proposal, yes. 19 Center? 20 Q. What is the name of the business 20 A. I was their point person for the 21 that you did with Pinnacle Mortgage? 21 coordination for their bond issuance. They 22 A. Pinnacle Mortgage was looking for a 22 got an industrial revenue bond issued by the Page 59 Page 61 1 way to come to Fannie Mae with its own credit 1 District of Columbia to complete financing for 2 enhancement rather than relying on Fannie Mae 2 their facility, which is the first 3 because of the cost. And so I went to Florida 3 African-American YMCA built in this country. 4 to meet with Pinnacle about the possibility of 4 Q. Did that work have anything to do 5 utilizing a captive insurance vehicle, renting 5 with Fannie Mae? 6 a captive cell, and providing their own credit 6 A. No. 7 enhancement so that they could come to Fannie 7 Q. What's the nature of the business 8 Mae with a full package rather than coming 8 that RMS did with Zurich? 9 just with their loans and being required to 9 A. Did with? 10 rely on Fannie Mae and paying the fee. 10 Q. Zurich. 11 Q. When did you go to Florida? 11 A. The same thing. It had to do with 12 A. I went with Tim Webb, and it was -- 12 the May 2001 proposal and also with respect to 13 I believe it was in 2002. 13 reinsurance for a potential captive insurance 14 Q. Did the meeting that you had in 14 execution. 15 Florida with Pinnacle Mortgage relate to the 15 Q. Who at Zurich did you deal with? 16 2001 May proposal? 16 A. I do not recall the names off the 17 A. Oh, no, not at all. It related to 17 top of my head. 18 a captive insurance concept which I had 18 Q. What is the time frame in which you 19 initiated with Fannie Mae prior to my 19 were in communications with Zurich about the 20 departure. And I actually had people who were 20 May 2001 proposal? 21 very knowledgeable about captives speak 21 A. We were in contact with most of 22 directly to Fannie Mae staff so that the 22 these insurers and reinsurers throughout the 16 (Pages 58 to 61) Esquire Deposition Services MD - 1-800-539-6398 D.C. - 1-800-441-3376 VA - 1-800-752-8979 af779bd1-e112-4d83-87a0-2544073c0e93 Case 1:05-cv-01483-JDB Document 33-4 Filed 06/21/2007 Page 18 of 54 Marialice Williams Page 62 Page 64 1 entire period of 1998 through 2001, 2002. 1 to the May 2001 proposal? 2 Q. Do you remember when the last 2 A. You said the date? The date? 3 contact that you had with Zurich related to 3 Sometime after May 2001. I know that. 4 the May 2001 proposal was? 4 Q. Can you be any more specific? 5 A. I don't recall. We're calling this 5 A. No, I can't. 6 the May 2001 proposal -- I think it's because 6 Q. Did you remain in communications 7 it's the first time someone saw it in writing, 7 with AIG for several months after May 2001? 8 but it started before I left Fannie Mae, so it 8 A. I am still in contact with them. 9 wasn't new in May 2001. 9 Q. Are you still in contact with them 10 Q. When is the last communication you 10 regarding the May 2001 proposal? 11 had with Fannie Mae regarding Zurich? 11 A. No. That's because I haven't had 12 A. It was sometime after May 15, 2001. 12 an opportunity to raise it with them, but I 13 Q. Can you be any more specific? 13 intend to try to raise it with them again. 14 A. No, because, as I said, you're 14 Q. When is the last time that you 15 constantly back and forth. Zurich has a 15 recall having a discussion with AIG regarding 16 question, then someone in their shop has a -- 16 the May 2001 proposal? 17 it's just -- it's -- product development in 17 A. Oh, about the May 2001 proposal? I 18 the securitization field is a very lengthy 18 just cannot remember. It would be probably 19 process and -- just takes a long time and a 19 December 2002 to -- I just don't know. I 20 lot of detail. 20 mean, I can't be absolutely certain when that 21 Q. Did you close any deals with 21 could have been. 22 Zurich? 22 Q. What makes you think it might have Page 63 Page 65 1 A. No. 1 been December 2002? 2 Q. What was the nature of the business 2 A. I'm just thinking about a trip that 3 that you did with AIG? 3 I made to New York, and I know that it was in 4 A. AIG was the insurer that was used 4 December of 2002, and I believe I spoke to -- 5 in the first multi-family credit risk 5 I know I spoke to AIG, but I don't know if I 6 insurance transaction and they were brought to 6 spoke to -- about the 9 -- about the May 7 Fannie Mae by Bob Jones and Danny Groves. And 7 proposal. I just don't recall. 8 once I left Fannie Mae, we resurrected a 8 Q. Who at AIG did you talk to in 9 relationship there to look at these other ways 9 December 2002? 10 of using their insurance, and I am in contact 10 A. I don't recall. But I may -- I 11 with them even now. 11 just remembered something else from earlier. 12 Q. Have you closed any deals with 12 So if that pops back in, I will write it down 13 AIG -- 13 definitely. And I believe he has a Hispanic 14 A. No. 14 name, and I will try to remember it. 15 Q. -- since you left Fannie Mae? 15 Q. When is the last time that you 16 A. No. 16 discussed anything relating to AIG with Fannie 17 Q. Did the communications that you had 17 Mae? 18 with AIG since you left Fannie Mae relate to 18 A. With Fannie Mae, I really don't 19 the May 2001 proposal? 19 remember. I really don't. I'm -- I don't 20 A. Yes. 20 recall discussing anything about AIG. You 21 Q. What was the time frame of the 21 don't do that. You don't go to Fannie Mae and 22 communications that you had with AIG relating 22 discuss what you're discussing with an 17 (Pages 62 to 65) Esquire Deposition Services MD - 1-800-539-6398 D.C. - 1-800-441-3376 VA - 1-800-752-8979 af779bd1-e112-4d83-87a0-2544073c0e93 Case 1:05-cv-01483-JDB Document 33-4 Filed 06/21/2007 Page 19 of 54 Marialice Williams Page 66 Page 68 1 insurance company unless you've got a deal 1 deal? It's -- you understand. They don't 2 that's hopping. You just don't do it. 2 realize their mortgages became a commodity; 3 Q. So would it be fair to say that you 3 they were no longer mortgages. 4 never had a deal that you considered to be far 4 Q. What is the nature of the business 5 enough along to make it appropriate for you to 5 that RMS did with Morgan Stanley? 6 discuss? 6 A. Morgan Stanley was very interested 7 A. Well, Fannie Mae would never 7 in looking at as many options as possible for 8 consent to its lenders -- or authorize them to 8 credit enhancement. It's always about credit 9 utilize the insurance for the May 2001 9 enhancement and laying off risk. So Liz 10 proposal. So it never -- there was never 10 Haberkorn Cowherd -- what a name -- and I used 11 any -- I mean, you can see on here there is no 11 to meet periodically in New York and talk and 12 one from Fannie Mae designated on this May 15, 12 e-mail and so forth about potential new 13 2001, message to Steve Noble at Zurich. You 13 transactions with -- I had done a number of 14 just don't -- you don't do it that way. 14 transactions with Morgan Stanley when I was -- 15 And Fannie Mae has to decide how 15 in fact, Morgan Stanley was the one that 16 they want to use the product. So you may 16 helped me to create the first -- what is known 17 have -- for example, I created the 17 in the marketplace as ACES. I named it ACES, 18 multi-family credit risk insurance 18 the alternative credit enhancement structure. 19 specifically to assist affordable lenders 19 Q. Did any of the discussions that you 20 because it works with them. When I left, 20 had with Morgan Stanley relate to the May 2001 21 Fannie Mae did not pursue that in that venue. 21 proposal? 22 They used it for their priority lenders in 22 A. No. Page 67 Page 69 1 their aggregation program and other places. 1 Q. What was the nature of the 2 Q. So would it be fair to say that 2 communications or business that you did with 3 after you left Fannie Mae you had no 3 Metropolitan Savings? 4 communications with Fannie Mae about AIG? 4 A. For quite some time after -- 5 A. No, that's not true. We did have 5 Metropolitan Savings is the institution for 6 some, but I think it was limited to a large 6 which -- for which I was essentially -- no, 7 extent by the disagreement I'm sure you're 7 that's not true. Let me start over. 8 aware of between AIG and Fannie Mae where 8 Metropolitan Savings was the first 9 Fannie Mae refused to provide certain 9 mortgage holder that utilized the multi-family 10 information and documentation which I knew 10 credit risk insurance. And because I had met 11 existed in a box in Tim Howard's office under 11 so many times with them, I continued my 12 somebody's desk. And ultimately it was 12 relationship with them far beyond my tenure at 13 compiled and put together, and some of it was 13 Fannie Mae because they had not only 14 disclosed. 14 additional business they wanted to do under 15 But there was a lot of conflict 15 the MCRI structure, they also had -- it was 16 between AIG and Fannie Mae over the concept of 16 kicking around at Fannie Mae at the time, but 17 multi-family credit risk insurance. Because 17 Larry Small didn't understand how Freddie Mac 18 insurers don't understand that real estate may 18 had been able to securitize some commercial 19 be thriving, but the market for a 19 loans along with some residential loans in a 20 mortgage-backed security may not be. 20 pool of securities. The REMIC was done 21 So, duh, why is this property not 21 outside of Freddie Mac. It was not issued off 22 defaulting but I'm not making more on this 22 the shelf or anything like that. It was 18 (Pages 66 to 69) Esquire Deposition Services MD - 1-800-539-6398 D.C. - 1-800-441-3376 VA - 1-800-752-8979 af779bd1-e112-4d83-87a0-2544073c0e93 Case 1:05-cv-01483-JDB Document 33-4 Filed 06/21/2007 Page 20 of 54 Marialice Williams Page 70 Page 72 1 issued by one of the major -- I think it was 1 MR. DANIELS: Excuse me. Are you 2 Morgan Stanley. 2 about to go in a different line? Because this 3 So when I left Fannie Mae, I 3 may be a good place for a lunch break. 4 believe Eric Rosenfield did close a deal with 4 MS. BECKER: Okay. Let's go off 5 Metropolitan Savings involving some 5 the record. 6 commercial, but they had a lot more because 6 THE VIDEOGRAPHER: The time is 7 they do the very small multi-family deals, 7 12:26. We're off the record. 8 between 5 and 50 units in the properties, 8 (Recess.) 9 which is not standard in the multi-family 9 10 business. 10 11 And so it's a little more 11 12 difficult -- it's kind of a hybrid mortgage, 12 13 and so I was working with them on different 13 14 ways to securitize their portfolio. 14 15 Q. Did the work you did with Morgan -- 15 16 I'm sorry -- with Metropolitan Savings relate 16 17 in any way to the May 2001 proposal? 17 18 A. No. They were not a DUS lender. 18 19 Or they weren't then. I don't know if they 19 20 are or are not now. 20 21 Q. Did the work that you did with Eric 21 22 Rosenfield relate in any way to the May 2001 22 Page 71 Page 73 1 proposal? 1 AFTERNOON SESSION 2 A. Eric Rosenfield was the investment 2 (1:34 p.m.) 3 banker whom Bob Jones and I used to test every 3 THE VIDEOGRAPHER: The time is 4 single theory that we had about potential new 4 1:34. We're back on the record. 5 structures. So Eric was very familiar with 5 Whereupon, 6 this May 2001 proposal as well as everything 6 MARIALICE BATHRUS WILLIAMS, 7 else we were doing. 7 was recalled as a witness and, having been 8 Q. Did you close any deals with Eric 8 previously duly sworn, was examined and 9 Rosenfield? 9 testified further as follows: 10 A. No. He closed deals I worked on, 10 EXAMINATION BY COUNSEL FOR THE DEFENDANTS 11 but he did not pay me. 11 BY MS. BECKER: 12 Q. Would it be fair to say that 12 Q. Good afternoon. 13 Mr. Rosenfield was acting in more of a 13 A. Good afternoon. 14 consulting capacity relating to the May 2001 14 Q. Before we broke for lunch, we were 15 proposal? 15 talking about the relationship between CAM and 16 A. No. He was just a business 16 Risk Mitigation Strategists, LLC. Has there 17 associate, and we just ran things by him. 17 ever been a formal relationship between those 18 Q. Has there ever been any 18 two entities? 19 relationship between Risk Mitigation 19 A. Before -- before I left Fannie Mae, 20 Strategists, LLC, and CAM Financial? 20 I was offered a job by CAM Financial. That is 21 A. No. No relationship in the formal 21 the reason I left Fannie Mae, to work with CAM 22 sense. Excuse me. I change that. 22 Financial and Fannie Mae. We had an 19 (Pages 70 to 73) Esquire Deposition Services MD - 1-800-539-6398 D.C. - 1-800-441-3376 VA - 1-800-752-8979 af779bd1-e112-4d83-87a0-2544073c0e93 Case 1:05-cv-01483-JDB Document 33-4 Filed 06/21/2007 Page 21 of 54 Marialice Williams Page 74 Page 76 1 understanding, we thought, with Lou Hoyes, who 1 ownership, and we did not have an interest in 2 was the then senior vice president for 2 each other's business. 3 multi-family, that we would just continue to 3 Q. Does this document refresh your 4 do business. And for one reason or another, 4 recollection as to whether the joint broker 5 it turned out that the best relationship -- I 5 agreement was between Risk Mitigation 6 then became an insurance broker myself, and 6 Strategists and CAM Financial Services? 7 signed a joint broker agreement with CAM. And 7 A. I'm certain -- listen to me. I am 8 then Fannie Mae asked me to write them a 8 almost certain that it was just between myself 9 letter that said I was not doing business with 9 because RMS can't be -- couldn't be a partner 10 CAM Financial -- in order to get business from 10 of anyone in a brokerage capacity because that 11 them, I would not be able to do business with 11 wasn't what Risk Mitigation Strategists was. 12 CAM Financial. 12 I was just a licensed broker. But my 13 And so I wrote a letter to Fannie 13 company -- I couldn't have done that legally, 14 Mae saying that -- which was true, I did not 14 I don't think. I don't think. 15 have -- I was not doing business with them. I 15 Q. I would like to direct your 16 was in a joint venture agreement in the event 16 attention to the third paragraph of the letter 17 that we did this insurance stuff together. 17 in the second sentence beginning, "However." 18 But that was the extent, up to that point, of 18 It states, "However, CAM and RMS have a broker 19 our relationship, although we still continued 19 agreement that is common in the insurance 20 to talk and dialogue and meet jointly with 20 business." 21 people, and I still had the expertise, and 21 Was that an accurate statement? 22 Bob's company had the cash to move forward 22 A. It's probably a misstatement of -- Page 75 Page 77 1 with the marketing. 1 I do have a copy of the agreement. I can 2 Q. Was there a joint broker agreement, 2 check it and I can let you know. I just am 3 then, between CAM Financial and Risk 3 not looking at it right now. It does say that 4 Mitigation Strategists, LLC? 4 there, but I don't think -- I don't think the 5 A. No, it was just between myself -- 5 agreement reads between -- I think it was 6 oops. I have to look at it, but I think it's 6 between CAM and Marialice Williams, I believe. 7 just between me and CAM. I don't think 7 But I think you all have a copy of it. 8 it's -- I'm just not remembering completely. 8 Q. So you believe that the letter you 9 And I think I gave it -- in the documents that 9 wrote to Ms. Huebscher mischaracterizes the 10 I provided, I believe I gave a copy of it. 10 nature of the broker agreement? 11 (Deposition Exhibit No. 2 was 11 A. No. I think that it does not say 12 marked for identification.) 12 RMS, LLC, first of all, and it doesn't say 13 BY MS. BECKER: 13 CAM, LLC, or whatever they are. So I would 14 Q. I am handing you Exhibit 2. Can 14 say it doesn't misrepresent. I don't think 15 you identify that document? 15 anybody had any question about it at the time, 16 A. Yes. This is the letter that I 16 and I'm -- I'm just -- I would have to look at 17 wrote to Grace Huebscher after I met with her 17 the agreement, and I could do that, but I'm 18 and I was told that Rhoda Newman was going to 18 not going -- no, I don't think I 19 be assigned to me. I think that's what this 19 mischaracterized anything. 20 was about. And describing some of the things 20 Q. Let me direct your attention to the 21 that we did, but also saying that CAM and RMS 21 last sentence of the first paragraph. It 22 do not have any connection with respect to 22 says, "I welcome the opportunity to clearly 20 (Pages 74 to 77) Esquire Deposition Services MD - 1-800-539-6398 D.C. - 1-800-441-3376 VA - 1-800-752-8979 af779bd1-e112-4d83-87a0-2544073c0e93 Case 1:05-cv-01483-JDB Document 33-4 Filed 06/21/2007 Page 22 of 54 Marialice Williams Page 78 Page 80 1 define the relationship between my company, 1 A. This is dated August 6, 2000, and 2 Risk Mitigation Strategists, LLC (RMS) and CAM 2 it is an unsigned and never was signed letter 3 Financial Services, Inc." 3 from Bob Jones to Marialice Williams about 4 Do you see that? 4 sharing commissions. 5 A. So are you asking me -- I mean, 5 Q. And who was this letter set up to 6 what's the question? Did I mischaracterize 6 be between? 7 it? I don't think so. I think it was 7 A. Risk Mitigation Strategists and CAM 8 referring to myself as RMS, you know -- I 8 Financial. 9 don't know. I don't know what happened in the 9 Q. Why was this letter never signed? 10 letter or why I wrote it that way. I have no 10 A. Because -- probably because I 11 idea, because I -- I will show you the joint 11 didn't want to sign it as Risk Mitigation 12 venture agreement, and I don't believe it's 12 Strategists and probably because there was so 13 between CAM and RMS. I think it's between CAM 13 much going on at the time that was 14 and Marialice Williams as a broker because I'm 14 conflicting, I didn't know who was telling me 15 the only one who could -- RMS was not a 15 the truth about anything, whether Bob was 16 broker. 16 telling me the truth -- I now know Bob wasn't 17 Q. Do you know what the time frame is 17 telling me the truth, too. And so I was 18 in which the letter to Ms. Huebscher was 18 reluctant to sign it. My -- I was reluctant 19 written? 19 to sign it and did not sign it. And if I did, 20 A. It was during the summer of 2000, 20 I don't remember. I don't. 21 2001 or 2002. I just really do not precisely 21 (Deposition Exhibit No. 5 was 22 remember. 22 marked for identification.) Page 79 Page 81 1 Q. Was it your understanding that 1 BY MS. BECKER: 2 Fannie Mae required you to clarify the 2 Q. I am handing you -- 3 relationship between RMS and CAM prior to your 3 A. This is not the one I was referring 4 doing business with Fannie Mae? 4 to. 5 A. Yes. 5 Q. I am handing you what's been marked 6 (Deposition Exhibit No. 3 was 6 as Exhibit 6 -- I'm sorry, 5. Do you 7 marked for identification.) 7 recognize this document? 8 BY MS. BECKER: 8 A. Uh-huh. 9 Q. I would like to hand you what's 9 Q. What is it? 10 marked as Exhibit 3. Does this refresh your 10 A. No -- actually, I don't recognize 11 recollection as to the time frame of the -- 11 this at all. I don't even recall seeing it. 12 A. Yes. 12 Q. Do you recognize -- 13 Q. -- correspondence? 13 A. Oh, I remember the scenario 14 A. It appears that I sent it on -- 14 perfectly. 15 sometime in May of 2001. 15 Q. Do you now recognize the document? 16 MR. DANIELS: This is 3? 16 A. I recognize the document. I don't 17 MS. BECKER: That was 3, yes. 17 recognize this particular e-mail. 18 (Deposition Exhibit No. 4 was 18 Q. I would like to direct your 19 marked for identification.) 19 attention to what's been marked as page 10547. 20 BY MS. BECKER: 20 Do you see that? 21 Q. I am handing you what has been 21 A. Uh-huh. 22 marked as Exhibit 4. What is that document? 22 Q. What is that? 21 (Pages 78 to 81) Esquire Deposition Services MD - 1-800-539-6398 D.C. - 1-800-441-3376 VA - 1-800-752-8979 af779bd1-e112-4d83-87a0-2544073c0e93 Case 1:05-cv-01483-JDB Document 33-4 Filed 06/21/2007 Page 23 of 54 Marialice Williams Page 82 Page 84 1 A. That is the -- 47 -- an 1 only signed by me. I believe that. I can 2 out-of-order page of -- it looks like it's out 2 check. 3 of order somewhere. 3 Q. So your testimony is that there is 4 THE VIDEOGRAPHER: The time is 4 a co-brokerage agreement -- 5 1:47. This is the end of tape number 1. 5 A. Uh-huh. 6 We're going to go off the record to change to 6 Q. -- between -- 7 tape number 2. 7 A. Was. 8 (Pause.) 8 Q. There was a co-brokerage agreement 9 THE VIDEOGRAPHER: The time is 9 between you, Marialice Williams, and CAM; is 10 1:49. This is the beginning of tape number 2. 10 that correct? 11 We're back on the record. 11 A. I believe that's the way it is. 12 BY MS. BECKER: 12 Q. And, separately, your testimony is 13 Q. Ms. Williams, can you identify the 13 that there was a limited joint venture 14 document marked 104 -- 10547 in Exhibit 5? 14 agreement between you, Marialice Williams, and 15 A. It appears to be page 2 of 2 of a 15 CAM? 16 proposed joint venture agreement between CAM 16 A. I'm sorry. I didn't understand -- 17 Financial Services and Risk Mitigation 17 what was the prior question? 18 Strategists. 18 Q. The first question was whether 19 Q. At the bottom of the page there is 19 there was a co-brokerage agreement between 20 a signature. Do you see that? 20 Marialice Williams and CAM? 21 A. Yes. 21 A. I believe it was called -- no. I'm 22 Q. Whose signature is that? 22 not sure whether it -- you know, I have to be Page 83 Page 85 1 A. That's Harvey Hartsfield. 1 honest with you, from 1998 in June until, as 2 Q. So Mr. Hartsfield is signing this 2 you can see, two -- several -- two years later 3 joint venture agreement on behalf of Risk 3 at least, we know that I was attempting to 4 Mitigation Strategists; is that correct? 4 work out something with CAM Financial. 5 A. Yes, he signed it on behalf of Risk 5 Nothing ever worked out that would have 6 Mitigation Strategists. He, too, is an 6 reflected anything that I would have 7 insurance broker. He is still actively 7 contemplated before I left Fannie Mae. 8 licensed. It was never consummated. No 8 But because we all kept going at 9 agreement was ever consummated with CAM. 9 trying to do this business, since I had 10 Q. So there never was a joint venture 10 created it, there was a point at which I 11 agreement with CAM; is that correct? 11 believe Bob actively had an insurance company 12 A. There was a limited joint venture 12 in Baltimore, and -- Fidelity, I believe it 13 agreement that is not these documents that we 13 was -- that wanted to hear a presentation 14 have been looking at. These are all attempts, 14 jointly -- jointly. And at that time, because 15 prior to the discussions with Fannie Mae 15 the relationship was with CAM, the -- 16 telling me not to do business with them. And 16 Fidelity's relationship was with CAM, in order 17 then after Fannie Mae said you can't do 17 for me to ensure, because Bob had not paid me 18 business with them directly, that is when -- 18 or shared -- and I didn't know until later how 19 or I guess we did wind up signing -- I believe 19 much money he was making from Fannie Mae until 20 it's three paragraphs, and it simply says that 20 I saw those tapes and stuff -- I thought the 21 we agree to share commissions if we both work 21 only way I could ensure that I could -- would 22 on the transaction. But I believe that one is 22 be on there was to get something signed. 22 (Pages 82 to 85) Esquire Deposition Services MD - 1-800-539-6398 D.C. - 1-800-441-3376 VA - 1-800-752-8979 af779bd1-e112-4d83-87a0-2544073c0e93 Case 1:05-cv-01483-JDB Document 33-4 Filed 06/21/2007 Page 24 of 54 Marialice Williams Page 86 Page 88 1 Because I've had the experience with Eric 1 signatory. 2 Rosenfield in Metropolitan -- you know, 2 BY MS. BECKER: 3 everybody seemed to be kind of not honoring 3 Q. I would like to direct your 4 what they were saying. 4 attention to the first paragraph of the mutual 5 So I believe that the small 5 non-disclosure agreement. Do you see where it 6 agreement was one to ensure that I would 6 says that, "This mutual non-disclosure 7 receive commissions if that company was used 7 agreement is made and entered into as of the 8 to do any Fannie Mae business or any other 8 date set forth below by and between Fannie Mae 9 business. That's why you don't see two 9 and the entity whose name and address are set 10 signatures on anything. 10 forth below (the Company)"? 11 Q. You believe that there were two 11 A. Uh-huh. 12 signatures on a co-brokerage agreement? 12 Q. Who is the entity whose name and 13 A. I believe there was on this one 13 address are set forth below? 14 document, but it's none of these -- there is 14 A. Mine. My company and -- RMS. 15 no language anywhere like this in the document 15 Q. The company that's identified below 16 I'm referring to. I believe it's just a 16 with their address is Risk Mitigation 17 little three-paragraph thing that says we will 17 Strategists, LLC; is that correct? 18 share the commissions in this deal or 18 A. That's correct. 19 something like that, and that happens all the 19 Q. Did Risk Mitigation Strategists, 20 time. 20 LLC, ever file tax returns? 21 Q. And is it your testimony that the 21 A. I don't remember -- no. No, I'm 22 three-paragraph document indicating that you 22 filing them now. I don't -- I mean, I'm not Page 87 Page 89 1 would share commissions with CAM is the only 1 even sure. I don't think so. We had no 2 formalized agreement between you and CAM? 2 income, so we didn't file any tax return. 3 A. I know that. And I now know why. 3 Q. Was the income from Risk Mitigation 4 Q. I would like to show you what will 4 Strategists, LLC, zero? 5 be marked as Exhibit 6. 5 A. Yes. 6 (Deposition Exhibit No. 6 was 6 Q. I believe you just testified that 7 marked for identification.) 7 you are currently filing tax returns for Risk 8 BY MS. BECKER: 8 Mitigation Strategists, LLC? 9 Q. Can you identify that document? 9 A. No, not for Risk Mitigation 10 A. This is a mutual non-disclosure 10 Strategists. Well, I guess we are to the 11 agreement. 11 extent that it's one of the noted companies 12 Q. What was your understanding of the 12 that I had during that time. I haven't seen 13 purpose of this document? 13 the new returns. You don't want to know the 14 A. The purpose of this document was to 14 story. 15 ensure that Fannie Mae did not take my ideas 15 Q. Did Risk Mitigation Strategists, 16 and go to another insurance company. 16 LLC, have any operating expenses? 17 Q. Who are the parties to the mutual 17 A. Yes. Yes, it did. 18 non-disclosure agreement? 18 Q. What were those? 19 MR. DANIELS: I'm sorry. I lost 19 A. They were typical office expenses 20 track of this. Is this 6? 20 that anyone would have that's in business: 21 THE WITNESS: Yes. Marialice 21 Rent, telephones and so forth. They were -- 22 Williams and Fannie Mae, Grace Huebscher 22 none of them were in the name of Risk 23 (Pages 86 to 89) Esquire Deposition Services MD - 1-800-539-6398 D.C. - 1-800-441-3376 VA - 1-800-752-8979 af779bd1-e112-4d83-87a0-2544073c0e93 Case 1:05-cv-01483-JDB Document 33-4 Filed 06/21/2007 Page 25 of 54 Marialice Williams Page 90 Page 92 1 Mitigation Strategists. They were just all in 1 correct? 2 my personal name. 2 A. Yes. 3 Q. Did Risk Mitigation Strategists, 3 Q. Where else did you search? 4 LLC, have a payroll? 4 A. That's the only place I searched. 5 A. No. 5 It's the only place I have documents. 6 Q. Were there ever any financial 6 Q. Did you contact Julia Williams? 7 statements for Risk Mitigation Strategists? 7 A. She's dead. 8 A. No. 8 Q. Do you have documents related to 9 (Deposition Exhibit No. 7 was 9 the CAM litigation? 10 marked for identification.) 10 A. You sent me a lot of documents from 11 BY MS. BECKER: 11 the CAM litigation. 12 Q. I am handing you what's been marked 12 Q. Other than documents that Fannie 13 as Exhibit 7. Do you recognize this document? 13 Mae has produced to you, do you have any 14 A. Yes. 14 documents in your possession related to the 15 Q. What is it? 15 CAM litigation? 16 A. It's a complaint filed in the 16 A. I don't think so, but I had a 17 District Court by me against Fannie Mae. 17 storage area -- unit on U Street, Northwest, 18 Q. Do you recognize this document as 18 the 1300 block, and I was traveling a lot and 19 Fannie Mae's request for production of 19 they changed the rate by $10, and by the time 20 documents directed to you in this litigation? 20 I got the notice, they had sold all the 21 A. Do I recognize it as -- 21 contents of that. And that's the only other 22 Q. Fannie Mae's request for production 22 place where I had documents in boxes and stuff Page 91 Page 93 1 of documents in this litigation. 1 like that, and a mink coat and, you know, 2 A. Oh, I don't -- I don't know. 2 things -- old stuff, but, you know, it's gone. 3 Q. Have you seen this document before? 3 I don't know where it is and I can't get it. 4 A. Yes. 4 Q. What documents do you believe were 5 Q. What is your understanding of what 5 in the storage area on U Street? 6 this document is? 6 A. I really -- I can't say. I would 7 A. It's a complaint. It's a complaint 7 have gone through it if it would have been 8 with these various -- oh, I'm sorry. I 8 available and I would have disclosed them to 9 apologize. I wasn't reading it. I was just 9 you. 10 seeing that. This is a request for production 10 Q. Do you have any recollection of 11 of documents to me. 11 putting documents in the -- 12 Q. Have you seen that document before? 12 A. No. 13 A. Yes. 13 Q. -- U Street storage facility? 14 Q. Did you search for documents in 14 A. No. I know that there were boxes 15 response to Fannie Mae's document requests? 15 that contained legal files and records of 16 A. I searched everything I had to 16 things that I no longer have. 17 comply with this. 17 Q. Do you have any reason to believe 18 Q. Where did you search? 18 that there were any documents in the U Street 19 A. My office. 19 storage facility related in any way to Fannie 20 Q. Where is your office? 20 Mae or to CAM? 21 A. 1922 First Street, Northwest. 21 A. You know, I remember when Bob Jones 22 Q. That's at your home; is that 22 filed the original complaint in his case, and 24 (Pages 90 to 93) Esquire Deposition Services MD - 1-800-539-6398 D.C. - 1-800-441-3376 VA - 1-800-752-8979 af779bd1-e112-4d83-87a0-2544073c0e93 Case 1:05-cv-01483-JDB Document 33-4 Filed 06/21/2007 Page 26 of 54 Marialice Williams Page 94 Page 96 1 the original case did not involve Fannie Mae. 1 on it. 2 And I know that I saw that complaint, and I am 2 Q. They were deposition transcripts? 3 pretty sure I had a copy of it, but I don't 3 A. Yes. 4 have it now. And then, later on, Fannie Mae 4 Q. There were four pages? 5 was added as a necessary party. 5 A. Just about four pages. 6 Q. Do you have any reason to believe 6 Q. And that's the only thing, to your 7 that you had documents in the U Street storage 7 knowledge, that Ms. Williams had relating to 8 facility related to Fannie Mae or CAM? 8 the CAM litigation? 9 A. I believe there may have been some 9 A. That's as far as I know. 10 there. 10 Q. You've previously testified that 11 Q. What do you believe that those may 11 you had reviewed the documents that Fannie Mae 12 have been? 12 produced, at least in large part; is that 13 A. Oh, I couldn't tell you. 13 correct? 14 Q. Other than Ms. Williams, did you 14 A. A lot of it, yes, watching the 15 work with anybody -- with any other lawyer in 15 videos. 16 connection with the CAM litigation? 16 Q. Based on your review of the 17 A. No. At my last deposition, Michael 17 documents that Fannie Mae produced, do you 18 Beasley, Harley Daniels and Brian Lederer 18 have any present intention of amending your 19 attended the deposition with me. 19 complaint? 20 Q. Do you know where Julia Williams' 20 A. Yes. My attorney has spoken to me 21 files are? 21 about that. 22 A. No. 22 Q. I am not going to ask you any Page 95 Page 97 1 Q. Have you made any effort to locate 1 questions about any conversations that you've 2 her files relating to the CAM litigation? 2 had with your lawyer, but I am going to ask 3 A. I'm sorry. I apologize. She had 3 you whether you currently have any intent to 4 nothing but some -- you know, when they send 4 amend your complaint? 5 you a copy of the deposition so you can check 5 A. I intend to follow my attorney's 6 it to see if that's what you really said, you 6 advice. 7 know, where you check through it after it's 7 Q. Do you intend to amend your 8 taken. That's all she had in a file. I do 8 complaint? 9 remember that. 9 A. I believe -- yes. 10 I did go to her office right after 10 Q. In what way do you intend to amend 11 her death. Her family had already boxed up 11 your complaint? 12 her entire office, and they did it in no order 12 A. I intend to amend my complaint to 13 that represented anything intelligent. And I 13 further clarify that I was denied business 14 did search through there, and I do remember 14 with Fannie Mae on the basis of my race. 15 there was a file and all it had in it were 15 Q. Is there any other respect in which 16 about four sheets of paper, and they were four 16 you intend to amend your complaint? 17 pages from a deposition, and that's all she 17 A. We really have not finished our 18 had. 18 discussions. 19 Q. Are you referring to what's known 19 Q. What do you intend to clarify with 20 as errata sheets? 20 respect to your allegation that you were 21 A. I don't know what they're called. 21 denied business with Fannie Mae based on your 22 No, they were actual -- they had my testimony 22 race? 25 (Pages 94 to 97) Esquire Deposition Services MD - 1-800-539-6398 D.C. - 1-800-441-3376 VA - 1-800-752-8979 af779bd1-e112-4d83-87a0-2544073c0e93 Case 1:05-cv-01483-JDB Document 33-4 Filed 06/21/2007 Page 27 of 54 Marialice Williams Page 98 Page 100 1 A. Until I saw certain documentation, 1 Fannie Mae, totally un -- have no clue, 2 I had been led to believe there was no 2 really, about Fannie Mae and its processes and 3 business going on between CAM and Fannie Mae 3 procedures, and yet they were given a great 4 after 1998, which turns out is incorrect. 4 deal of business using a product that I had 5 Q. What documents are you referring 5 created and had been told that I was going to 6 to? 6 be able to get business from once I left. 7 A. There is a -- let's see. 7 And it didn't make sense that Craig 8 Mr. Daniels' law clerk went to Mississippi and 8 Ott was an international broker because Fannie 9 obtained from the courthouse there, although 9 Mae wouldn't permit any of the insurance 10 it was difficult since it was part of Katrina, 10 business to be done with any international 11 the record in the -- public record in the Bob 11 firm. It had to be a firm that was from the 12 Jones case. And that was my initial -- the 12 United States and it had to be a triple A 13 beginning of when -- that was when I began to 13 rated firm, and Bob Jones and I had identified 14 understand that CAM Financial had made a great 14 and brought into Fannie Mae and had under 15 deal of money from Fannie Mae and I had made 15 confidentiality agreement every single firm 16 none, and I had done a great deal of work, 16 that had those standards at that time. 17 including creating the product itself. 17 So if Mr. Ott -- and I saw a copy 18 And then I discovered in the 18 of something that purported to be some kind of 19 depositions that what I was -- had seen 19 insurance policy or something that he wrote 20 represented only a portion of the business 20 that looked like something a third grader 21 that -- because we did not copy all the 21 would have written; I, on the other hand, had 22 records, absolutely every record, that there 22 written policy after policy -- I believe it Page 99 Page 101 1 were, in fact -- there was a substantial 1 was up to 50 versions of it, went through all 2 amount of business that continued to be done 2 the -- went through all the language, went 3 between Fannie Mae and Bob Jones. 3 through -- worked with lawyers from AIG and 4 Q. Assuming that business was done 4 Fannie Mae who were happy they were working 5 between -- 5 with a lawyer because Bob was not. And, you 6 THE VIDEOGRAPHER: Excuse me. I 6 know, I felt I had made such a significant 7 have to go off the record real quick. The 7 contribution to Fannie Mae's bottom line that 8 time is 2:12. We have to go off the record. 8 I should have been given the business, as 9 (Pause.) 9 were -- most white people who left Fannie Mae 10 THE VIDEOGRAPHER: The time is 10 usually left and got some kind of contract or 11 2:12. We're back on the record. 11 something. 12 BY MS. BECKER: 12 I was told over and over again 13 Q. Assuming that there was business 13 there wasn't going to be any contract for me 14 between CAM Financial and Fannie Mae after you 14 because we don't pay people to do marketing, 15 left Fannie Mae, how would that affect your 15 but if you can bring something in here that's 16 complaint that you were denied business with 16 decent, we will try to do it with you. And I 17 Fannie Mae based on your race? 17 brought lots of things in, and they did 18 A. Well, Mr. Ott whom Richard Lawch 18 nothing. It turns out they did do something; 19 bragged about being a, quote/unquote, 19 they just didn't do it with me. 20 international broker and Bob Jones both are 20 Q. So the new allegation that you 21 less educated, less knowledgeable about the 21 intend to bring in your complaint is that 22 financial markets, less knowledgeable about 22 Fannie Mae did business with Bob Jones instead 26 (Pages 98 to 101) Esquire Deposition Services MD - 1-800-539-6398 D.C. - 1-800-441-3376 VA - 1-800-752-8979 af779bd1-e112-4d83-87a0-2544073c0e93 Case 1:05-cv-01483-JDB Document 33-4 Filed 06/21/2007 Page 28 of 54 Marialice Williams Page 102 Page 104 1 of with you? 1 as the affordable housing program. 2 A. And Craig Ott. 2 I did not quit my job because I 3 MR. DANIELS: Yes, we have two 3 didn't think I was going to have a lot of 4 1981s. In other words, the -- Bob Jones will 4 work. I thought I was going to have a ton of 5 be recast as a 1981, together with Craig Ott, 5 work. 6 a person of inferior qualification. 6 Q. What are agg deals? 7 MS. BECKER: Do you intend to drop 7 A. Aggregation deals? That's a 8 your claim for tortious interference? 8 program -- it's a concept that I created, and 9 MR. DANIELS: I will state for the 9 it then became a way of Fannie Mae doing what 10 record that until we take Bob Jones' 10 conduits do on Wall Street with respect to 11 deposition, I can't tell whether the tortious 11 securitizing mortgages. In other words, 12 interference claims will survive. But it will 12 instead of having an investment banker come 13 in large part depend on his deposition because 13 in, such as Morgan Stanley, and give you one 14 I have reason to believe that he isn't fully 14 pool of mortgage loans that represents one 15 being truthful about what Fannie Mae told him 15 company, their company, because they're the 16 about doing business with Marialice. I don't 16 conduit, Fannie Mae decided instead to step 17 believe it. 17 into that role and aggregate those pools like 18 BY MS. BECKER: 18 a conduit would do and then issue one security 19 Q. What specific business did Fannie 19 backed by multi -- by different lenders, pools 20 Mae do with CAM Financial that you intend to 20 of mortgages. 21 raise in your amended complaint? 21 Q. How is an aggregation deal 22 A. All of the transactions that Fannie 22 different from a DUS deal? Page 103 Page 105 1 Mae did with Bob Jones after I left Fannie 1 A. DUS is -- it's no different. It's 2 Mae. I'm sorry. My chest... 2 just the size and difference of the structure. 3 MR. DANIELS: Hang in there a bit, 3 And it depends -- see, a lot of the DUS loans 4 Marialice. 4 are purchased; those were loans that were 5 THE WITNESS: Okay. 5 purchased by Fannie Mae as opposed to 6 MR. DANIELS: This is key. 6 securitized. Securitization is securitization 7 BY MS. BECKER: 7 is securitization. 8 Q. What are those transactions? 8 So when there was a securitization 9 A. I don't know because I wasn't 9 deal on the DUS side, it was just like one 10 involved. They're written in -- they're in 10 that we would do for any other lender. 11 the information that was provided by you that 11 Q. There are certain loans, as I 12 was stated by Bob. I didn't write it down. 12 understand it, that are characterized as DUS 13 It's in all those documents I went through 13 loans; is that correct? 14 from the Mississippi case. It's who the 14 A. Because they're done by the premier 15 people are and what they did. 15 group of lenders that Fannie Mae has ordained 16 And -- I believe that all of the 16 as fit to submit their loans without any prior 17 aggregation deals were done using the same 17 review in many instances. 18 concept because I had worked with Grace and -- 18 MR. DANIELS: Marialice, what does 19 before I left Fannie Mae on that issue, just 19 DUS mean? Maybe just for the -- 20 as I had worked with Wendell Johns and Chris 20 THE WITNESS: It means delegated 21 Tawa about the possibility of using insurance 21 underwriting and servicing, the notion being 22 for the equity program of Fannie Mae as well 22 that they're good enough to do it themselves, 27 (Pages 102 to 105) Esquire Deposition Services MD - 1-800-539-6398 D.C. - 1-800-441-3376 VA - 1-800-752-8979 af779bd1-e112-4d83-87a0-2544073c0e93 Case 1:05-cv-01483-JDB Document 33-4 Filed 06/21/2007 Page 29 of 54 Marialice Williams Page 106 Page 108 1 like a brokerage, if you will. 1 is that correct? 2 BY MS. BECKER: 2 A. Yes. 3 Q. And are those different from 3 Q. What were the dates of those 4 aggregation loans? 4 computer crashes? 5 A. Aggregation loans have already been 5 A. I don't recall exactly, but I can 6 originated, and they come to Fannie Mae -- 6 tell you that the one at the Watergate -- one 7 they could be anywhere between two-year 7 was while I still had an office at the 8 seasoned up to within three years prior to the 8 Watergate. So it had to be prior to, let's 9 termination of the loan document. So that's 9 see -- on 9/11 I was still at the Watergate, 10 why they called the section where I worked and 10 so it had to be in 2001. I believe it may 11 what I ran, until Richard Lawch came, the 11 have been in the summertime. 12 negotiated transactions section because you're 12 Q. Was it before 9/11? 13 negotiating with loans that have already been 13 A. I believe -- I believe it was 14 originated. 14 before 9/11. It was after the date of the 15 The DUS loans are all originated 15 e-mail that I received notifying me -- from 16 according to a standard set of underwriting 16 the -- I think it was -- yes, I'm pretty sure 17 practices that Fannie Mae has proscribed. 17 it was -- I'm pretty sure it was the summer of 18 Q. And how is that different from the 18 2001. 19 aggregation loans? 19 Q. What did you do when your computer 20 A. Because aggregation loans have 20 crashed? 21 already been originated. They could have 21 A. I cried. 22 been, let's say -- oh, I will give you a great 22 Q. Did you replace the computer? Page 107 Page 109 1 example. I am Fannie Mae. I am going to get 1 A. Yes. And they could not retrieve 2 50 loans from BB&T, 50 loans from PNC, 50 2 anything from the hard drive. 3 loans from Bank of America. I am going to 3 Q. When did you get a replacement? 4 aggregate them. But they have already been 4 A. Immediately. 5 originated, and I don't know necessarily under 5 Q. Would it have been within a month 6 what standards. But what I do, when I 6 of when the computer crashed? 7 negotiate the document that actually -- the 7 A. Definitely. 8 trust agreement in which the loans are 8 (Deposition Exhibit No. 8 was 9 described and so forth, the documentation, I 9 marked for identification.) 10 describe how those loans were done. 10 BY MS. BECKER: 11 In the DUS program, all you have to 11 Q. I am handing you what has been 12 do is hold up the multi-family guide and say, 12 marked as Exhibit 8. 13 this is how these loans are done, because 13 A. Right. 14 they're all done to the letter by a specified 14 Q. Do you recognize that document? 15 group of people who have applied for and been 15 A. I don't recognize it, but I see 16 accepted into this program. 16 that it is the complaint filed in 2003 -- no. 17 Q. Is there any other respect in which 17 This is my deposition -- my deposition in Bob 18 you intend to amend your complaint? 18 Jones' case. 19 A. We haven't finalized the discussion 19 Q. Dated March 17, 2003? 20 yet. To my knowledge, that's the major area. 20 A. Yes. 21 Q. Ms. Williams, you previously 21 Q. I would like to ask you to turn to 22 testified that you had two computer crashes; 22 page 42 of the deposition. Starting on 28 (Pages 106 to 109) Esquire Deposition Services MD - 1-800-539-6398 D.C. - 1-800-441-3376 VA - 1-800-752-8979 af779bd1-e112-4d83-87a0-2544073c0e93 Case 1:05-cv-01483-JDB Document 33-4 Filed 06/21/2007 Page 30 of 54 Marialice Williams Page 110 Page 112 1 line 21 you're talking about the computer 1 THE WITNESS: He doesn't need to 2 crash that occurred at the Watergate; is that 2 coach me. 3 correct? 3 MR. DANIELS: Go ahead, Marialice. 4 A. Uh-huh. 4 MS. BECKER: Then please don't. 5 Q. I would like to ask you to turn to 5 THE WITNESS: Well, no -- actually, 6 the next page which is page 43. Starting on 6 there is nothing in here that clarifies -- I 7 line 19, can you read that? 7 mean, I don't see -- would you like to help 8 A. "I have documents that I have 8 me? I don't know where to start. 9 accumulated since my new computer," yes. 9 This is just a bunch of argument by 10 Q. Can you read the whole -- 10 attorneys. I don't even see any substantive 11 A. "But at the time that I received my 11 question in here for me. 12 new computer, I had no further contact with 12 MR. DANIELS: Counsel, perhaps you 13 Fannie Mae, CAM or anyone interested in either 13 can save us time. Is there a reference to 14 of those two issues." 14 which -- that we can refer to that you're 15 Q. What were you referring to with 15 familiar with? 16 respect to "those two issues"? 16 MS. BECKER: I am asking the 17 A. I don't remember. 17 witness to clarify. 18 Q. Was this a true statement when you 18 THE WITNESS: Well, I can't. I'm 19 made it? 19 sorry. 20 A. It's out of context. I would have 20 BY MS. BECKER: 21 to look at the whole thing. I don't even know 21 Q. Okay. What did you mean by "I have 22 what it's about. 22 documents that I have accumulated since my new Page 111 Page 113 1 Q. Feel free to read whatever you 1 computer, but at the time that I received my 2 think is necessary to put it in context. 2 new computer, I had no further contact with 3 MR. DANIELS: Frankly, given -- 3 Fannie Mae"? 4 excuse me. Frankly -- 4 A. What did I mean by that? It's a 5 MS. BECKER: If you're going to 5 whole sentence and it says "of those two 6 testify -- 6 issues," and if I could find out what those 7 MR. DANIELS: Okay. Let's see how 7 two issues are, I could tell you why I had no 8 I can do this so we can -- I object to her -- 8 further contact with anybody about them. 9 MS. BECKER: If you're going to 9 Q. I would read it as saying that 10 make a speaking objection, I object to that as 10 those two issues are Fannie Mae or CAM in the 11 well. If you want to object for the record, 11 context of that sentence. But it's your 12 you can object. 12 testimony, so I am asking you to -- 13 MR. DANIELS: Okay. I object to 13 A. I don't think it refers to Fannie 14 the form of the question on the ground that 14 Mae and CAM. 15 the statement being referred to is extremely 15 Q. Okay. Was it true as of the date 16 vague, and that -- 16 of your deposition on March 17, 2003, that at 17 MS. BECKER: Counsel, you're making 17 the time that you got your new computer, which 18 a speaking objection, and I would like to ask 18 would have been sometime in the summer of 19 you to not do that, please. You're just 19 2001, that you had no further contact with 20 coaching the witness at this point. 20 Fannie Mae or CAM? 21 MR. DANIELS: I don't need to coach 21 A. Oh, no, that's not true. I have 22 Marialice. 22 given you documents on that. 29 (Pages 110 to 113) Esquire Deposition Services MD - 1-800-539-6398 D.C. - 1-800-441-3376 VA - 1-800-752-8979 af779bd1-e112-4d83-87a0-2544073c0e93 Case 1:05-cv-01483-JDB Document 33-4 Filed 06/21/2007 Page 31 of 54 Marialice Williams Page 114 Page 116 1 Q. Why would you have testified to 1 after 2001? 2 that? 2 A. I communicated and sent things and 3 A. I didn't. You're telling me that I 3 talked to CAM Financial, as far as I know -- 4 testified to that. I am telling you I didn't. 4 when was Katrina? That was in 2004, '5 -- 5 Q. You're saying that you didn't say, 5 2005. I can tell you that when I was on 6 "I have documents that I have accumulated 6 Martha's Vineyard -- that was 2005, I 7 since my new computer" -- 7 believe -- in the summer of 2005, I spoke with 8 A. You said. 8 Bob Jones about business. I know that. 9 Q. Excuse me. I would like to finish 9 Q. Did your discussion with Bob Jones 10 my question. 10 in 2005 relate to Fannie Mae? 11 Are you saying that you did not 11 A. Yes. 12 testify, "I have documents that I have 12 Q. In what way? 13 accumulated since my new computer, but at the 13 A. I was still speaking with people 14 time that I received my new computer, I had no 14 who had an interest in pursuing credit 15 further contact with Fannie Mae, CAM, or 15 enhancement. 16 anyone interested in either of those two 16 Q. Tell me specifically what you 17 issues"? 17 discussed with Bob Jones in 2005 relating to 18 A. "Those two issues" are not 18 Fannie Mae. 19 referring to Fannie Mae and CAM and, 19 A. How is the insurance business? Is 20 therefore, the conclusion that you are drawing 20 there any hope we're going to get back to 21 is not what I was saying nor is it what I 21 doing any of this stuff? You know, how is 22 intended to say. 22 your case going? Is there anything we can do, Page 115 Page 117 1 Q. What did you intend to say? 1 you know, to resurrect what we were trying to 2 A. Exactly what I said, "or anyone 2 do? Along those lines, generally speaking. 3 interested in either of those two issues," 3 Q. Were there any specific business 4 which must have been something else related to 4 discussions about specific deals or specific 5 something else that I can't find in this 5 proposals? 6 document while we're sitting here. 6 A. I did not discuss specific deals 7 Q. So you have no idea what you were 7 with anyone until I had a confidentiality 8 referring to in this? 8 agreement in place and knew that I was the 9 A. I have no idea. 9 sole representation of that individual. I 10 Q. What was the further contact that 10 just -- you just don't do that. 11 you had with Fannie Mae or CAM after the 11 Q. So is it fair to say that you did 12 summer of 2001? 12 not have any discussion with Bob Jones in 2005 13 A. I believe I supplied all the 13 about any specific deals related to Fannie 14 documentation to you indicating that I did 14 Mae? 15 have contact with Fannie Mae and that I did 15 A. I had about specific deals, but I 16 have other transactions and things I worked on 16 did not reveal the names of those specific 17 that I -- 17 people to Bob Jones. 18 Q. So it would be in the documents 18 Q. What were the specific deals that 19 that you produced? 19 you were discussing with Bob Jones where you 20 A. I believe so. 20 didn't reveal the names of them? 21 Q. What was the nature of the 21 A. Oh, I just can't remember right 22 communications you had with Fannie Mae or CAM 22 now. 30 (Pages 114 to 117) Esquire Deposition Services MD - 1-800-539-6398 D.C. - 1-800-441-3376 VA - 1-800-752-8979 af779bd1-e112-4d83-87a0-2544073c0e93 Case 1:05-cv-01483-JDB Document 33-4 Filed 06/21/2007 Page 32 of 54 Marialice Williams Page 118 Page 120 1 Q. What specific deals did you have 1 person to your deal is your reinsurer because 2 going related to Fannie Mae in the 2005 time 2 the rating of the reinsurer is what attaches 3 frame? 3 to the rating of the credit enhancement which 4 A. You don't have deals related to 4 relates to the rating of the securities 5 Fannie Mae. What you have is you have 5 themselves. 6 clients, and they're looking for a way to lay 6 So there were -- because I had an 7 off risk and they're looking at their various 7 entree to the insurance commissioner in the 8 options: Should I go this way? Should I go 8 District of Columbia -- I don't recall if he 9 that way? What's cheaper? What's better? 9 was in Washington; if he wasn't in Washington, 10 What will give me a better product? What kind 10 he was on the telephone with Larry to 11 of execution? 11 discuss -- when we were discussing Tom -- it 12 That's what you talk about. You 12 was Tom Hampton, Larry -- the former insurance 13 don't talk about, I want to go to Fannie Mae 13 commissioner; Tom Hampton is now the insurance 14 and I want to do it this way. That's not how 14 commissioner, and Dana -- I can't remember his 15 it works in the marketplace. 15 last name, but he was the counsel. And then 16 Q. So you weren't having a discussion 16 the head of the insurance side was a woman. 17 with Bob Jones in 2005 about any specific 17 They were all in a room with us, 18 business related to Fannie Mae? 18 and we were all discussing this whole concept 19 A. Potential business for Fannie Mae, 19 of trying to do affordable housing mortgage 20 yes. 20 loan securitization using captive insurance as 21 Q. And what was that specific 21 the credit enhancement, and we could not move 22 potential business that you were discussing 22 forward. We were working with -- I know Page 119 Page 121 1 with Bob Jones? 1 Pinnacle was one of them, but there were 2 A. I don't remember right now. 2 several other people. And there were some 3 Q. Other than the communication that 3 things that weren't even mortgage loan-related 4 you had with Bob Jones in 2005, what other 4 such as John Taylor at the NCRC, it's called. 5 communications did you have with CAM between 5 It's an organization that represents community 6 the summer of 2001 and the present? 6 housing organizations. And we were discussing 7 A. You said other than Fannie Mae? 7 the feasibility of using the captive. 8 MS. BECKER: Can you read the 8 We believed that at that time -- or 9 question back? 9 at least it appeared from the beginning that 10 (The reporter read the record as 10 that would be an appropriate utilization of a 11 requested.) 11 captive, a form of captive insurance. And 12 THE WITNESS: I had a lot of 12 that's -- you know, we just -- we continued to 13 conversations with Bob Jones. I probably 13 have those discussions. 14 spoke to him every week, every other week, 14 BY MS. BECKER: 15 about any number of insurance proposals. We 15 Q. Was there anytime between the 16 had a new -- in the District of Columbia, we 16 summer of 2001 and the present where you had 17 have one of the newest captive insurance -- 17 communications with Bob Jones relating to 18 we're one of the newest captive insurance 18 Fannie Mae? 19 jurisdictions. 19 A. Yes, I talked to Bob Jones about 20 And Bob Jones had the reinsurance 20 Fannie Mae every week or every other week or 21 contacts, and when you're doing a captive 21 every few days or whenever he called or 22 insurance transaction, the most critical 22 whenever I called him. 31 (Pages 118 to 121) Esquire Deposition Services MD - 1-800-539-6398 D.C. - 1-800-441-3376 VA - 1-800-752-8979 af779bd1-e112-4d83-87a0-2544073c0e93 Case 1:05-cv-01483-JDB Document 33-4 Filed 06/21/2007 Page 33 of 54 Marialice Williams Page 122 Page 124 1 Q. And what was the nature of those 1 had relating to Bob Jones, potential Fannie 2 discussions? 2 Mae transactions. I honestly cannot remember 3 A. Are we ever going to do this 3 all of -- or any right now of the -- I would 4 business again? Shall I -- you know, that 4 have to go back and make sure it was 2001. 5 kind of thing. 5 I wouldn't want to say something 6 MR. DANIELS: Asked and answered. 6 now on the record and then you come back and 7 THE WITNESS: Yes, I did answer 7 say, well, you said this and that's -- you 8 that, didn't I? 8 know, now you're changing it or whatever. So 9 BY MS. BECKER: 9 for me to answer that one, I mean, I would 10 Q. Do you need the question read back? 10 have to go back to records and look at them to 11 A. No. I said -- that's what I said. 11 answer that question to know the exact dates, 12 Q. Okay. What was the nature of the 12 which year and which specific things we talked 13 communications that you had with Bob Jones 13 about. I wouldn't be able to do that, sitting 14 related to Fannie Mae from the summer of 2001 14 here. 15 to the present? 15 Q. As you sit here today, do you have 16 A. They were personal in nature. 16 any recollection of any discussions with Bob 17 Fannie Mae we discussed. 17 Jones after the summer of 2001 relating to any 18 Q. And I am focusing you on Fannie 18 specific business proposals -- 19 Mae. 19 A. Yes, I believe I've answered 20 A. Fannie Mae. Fannie Mae. We talked 20 that -- 21 about Fannie Mae a lot. He had a major 21 Q. -- with Fannie Mae? 22 lawsuit against Fannie Mae. We talked about 22 A. -- several times, and said yes. Page 123 Page 125 1 it a lot. 1 Q. What were those proposals? 2 Q. Other than the lawsuit, what 2 A. I cannot remember -- 3 discussions did you have with Bob Jones 3 Q. What were the discussions? 4 relating to Fannie Mae from the summer of 2001 4 A. -- but I did provide that 5 to the present? 5 information as requested in this exhibit back 6 A. We talked about every client that I 6 here where you asked me for all of those 7 was -- every client I would get, I would 7 things I gave you -- and it was marked by the 8 pretty much discuss it with Bob Jones because, 8 numbers of each of your requests exactly what 9 again, he's the one that had a lot of the 9 they were. And it did include items that were 10 contacts that I didn't have and I had some 10 discussed with Bob Jones. 11 contacts he didn't have. So when something 11 And I believe at the very outset of 12 came in and it looked like it was viable, I 12 this conversation, if you go back in her 13 would call Bob. I thought he was my friend. 13 record, it says -- you know, I know Pinnacle 14 I thought he was my loyal business associate 14 was after 2001 and I know I discussed that 15 at that time. I now know that that is not 15 with Bob Jones. Any number of things. I'm 16 true. 16 just -- I'm just not feeling very well, and 17 Q. Between the summer of 2001 and the 17 that's not helping at all. 18 present, did you have any discussions with Bob 18 I can't -- it's -- you know. I can 19 Jones relating to any specific proposals with 19 answer it when I look back at the 20 Fannie Mae? 20 documentation. 21 A. Yes, and I have given you all of 21 Q. Do you feel, as you're sitting here 22 that information in my -- everything that I 22 right now, that you can answer questions with 32 (Pages 122 to 125) Esquire Deposition Services MD - 1-800-539-6398 D.C. - 1-800-441-3376 VA - 1-800-752-8979 af779bd1-e112-4d83-87a0-2544073c0e93 Case 1:05-cv-01483-JDB Document 33-4 Filed 06/21/2007 Page 34 of 54 Marialice Williams Page 126 Page 128 1 a full recollection? 1 CERTIFICATE OF NOTARY PUBLIC 2 A. No. 2 I, Deborah Larson Hommer, RPR, the officer 3 MS. BECKER: Let's go off the 3 before whom the foregoing deposition was 4 record. 4 taken, do hereby certify that the witness 5 THE VIDEOGRAPHER: The time is 5 whose testimony appears in the foregoing 6 deposition was duly sworn by me; that the 6 2:46. We're off the record. 7 testimony of said witness was taken by me in 7 (Discussion held off the record.) 8 stenotype and thereafter reduced to 8 THE VIDEOGRAPHER: The time is 9 typewriting under my direction; that said 9 2:46. That's the end of today's deposition. 10 deposition is a true record of the testimony 10 11 given by said witness; that I am neither 11 (Whereupon, signature not having 12 counsel for, related to, nor employed by any 12 been waived, the taking of the deposition 13 of the parties to the action in which this 13 adjourned at 2:46 p.m.) 14 deposition was taken; and, further, that I am 14 15 not a relative or employee of any attorney or 15 16 counsel employed by the parties hereto, nor 16 17 financially or otherwise interested in the 18 outcome of the action. 17 19 ________________________ 18 Notary Public in and for 19 20 the District of Columbia 20 My Commission Expires: 21 21 October 14, 2008 22 22 Page 127 Page 129 1 April 10, 2007 1 * * * 2 2 Harley Jay Daniels, Esquire 3 Law Offices of Harley Jay Daniels 3 ACKNOWLEDGMENT OF DEPONENT 5511 Second Street, N.W. 4 Washington, D.C. 20011 4 5 Re: Marialice Bathrus Williams v. Fannie Mae, 5 I, Marialice Bathrus Williams, do hereby 6 et al. 6 acknowledge I have read and examined the Deposition of Marialice Bathrus Williams 7 7 foregoing pages of testimony, and the same is 8 As requested at the time of deposition, your original deposition transcript in the 8 a true, correct and complete transcription of 9 above-captioned case is being held for thirty (30) days for review and signature. 9 the testimony given by me, and any changes 10 This task may be accomplished in one of two 10 and/or corrections, if any, appear in the 11 ways; either the deponent may appear at our 11 attached errata sheet signed by me. 12 office to read and sign the deposition transcript for which the deponent should make 12 an appointment at (202) 429-0014, or counsel 13 may provide the witness with a copy of the 13 __________________ _______________________ transcript, from which the deponent shall make 14 an errata sheet. 14 Date Signature 15 If the latter method is chosen and the witness 15 16 is provided with a copy of the deposition transcript for review, the deponent should 16 keep in mind that the purpose of review is 17 only to ensure accuracy and not to revise in 17 an editorial manner. If any changes or 18 corrections are necessary, the deponent should 18 prepare an errata sheet listing by page and 19 19 line numbers the change or correction made; i.e., page 15, line 8, change "he said" to 20 20 "she said." When the errata sheet is completed it should be signed by the deponent. 21 21 This signed errata sheet will subsequently be attached to the original deposition transcript 22 22 and be filed with the Court. 33 (Pages 126 to 129) Esquire Deposition Services MD - 1-800-539-6398 D.C. - 1-800-441-3376 VA - 1-800-752-8979 af779bd1-e112-4d83-87a0-2544073c0e93 Case 1:05-cv-01483-JDB Document 33-4 Filed 06/21/2007 Page 35 of 54 Marialice Williams Page 130 1 The original transcript will be held until May 4, 2007, at which time if the deponent has not 2 followed either of the above two steps for reading his deposition transcript, it will be 3 assumed that reading and signing are no longer desired, and the deposition will be filed. 4 5 Sincerely, 6 7 Deborah Larson Hommer, RPR 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 Page 131 1 Esquire Deposition Services 1020 19th Street, Northwest 2 Suite 620 Washington, D.C. 20036 3 (202) 429-0014 4 ERRATA SHEET 5 Case Name: Marialice Bathrus Williams v. 6 Fannie Mae, et al. Witness Name: Marialice Bathrus Williams 7 Deposition Date: March 28, 2007 Job No.: 179392 8 Page No. Line No. Change 9 10 11 12 13 14 15 16 17 18 19 20 21 ____________ 22 Signature Date 34 (Pages 130 to 131) Esquire Deposition Services MD - 1-800-539-6398 D.C. - 1-800-441-3376 VA - 1-800-752-8979 af779bd1-e112-4d83-87a0-2544073c0e93 Case 1:05-cv-01483-JDB Document 33-4 Filed 06/21/2007 Page 36 of 54 Marialice Williams Page 1 A 15:14 17:10 amending 96:18 asked 27:16 40:2 96:20 128:15 abandon 51:1 advice 97:6 America 107:3 48:2 58:15 74:8 attorneys 112:10 abandoned 50:12 advisory 10:10 amount 53:10 99:2 122:6 125:6 attorney's 97:5 50:14 51:5 affect 99:15 and/or 127:10 asking 26:20 78:5 August 30:3 80:1 able 18:22 26:3 affordable 54:2 annual 22:6 23:6 112:16 113:12 authorize 66:8 49:2 53:20 69:18 55:7 66:19 104:1 31:8,8 aspects 56:6 automobile 11:21 74:11 100:6 120:19 answer 21:1 27:1 asset 54:4 12:8,9 52:12 124:13 afraid 46:14 58:2 122:7 124:9 assets 52:9 53:14 available 93:8 above-captioned African-American 124:11 125:19,22 assigned 41:15 Avenue 4:2 9:6 129:9 61:3 answered 42:16 47:6,10,16 75:19 aware 51:12 67:8 absolutely 53:5 afternoon 73:12,13 122:6 124:19 assist 35:17 66:19 a.m 2:4 6:13 56:17 64:20 98:22 agg 104:6 anybody 20:13 assistant 13:20 aggregate 104:17 77:15 94:15 113:8 15:7 16:7,15,18 B absorb 27:18 accepted 107:16 107:4 anymore 20:17 16:20 back 17:16 18:21 accident 47:22 48:9 aggregation 67:1 anytime 121:15 associate 71:17 20:22 39:15 43:21 accomplished 103:17 104:7,21 apologize 48:5 91:9 123:14 47:22 53:3 56:11 129:10 106:4,5,19,20 95:3 associated 23:21 62:15 65:12 73:4 accounting 56:6 ago 11:13 24:12 appear 127:10 24:2 26:8 27:6 82:11 99:11 accumulated 110:9 32:2 129:11 32:16 34:14 35:19 116:20 119:9 112:22 114:6,13 agree 83:21 appearances 3:1 53:4 55:20 122:10 124:4,6,10 accuracy 129:17 agreement 5:17 40:12 association 1:10 125:5,12,19 accurate 76:21 57:5 74:7,16 75:2 appeared 121:9 3:11 6:18 18:11 backed 53:14 ACES 68:17,17 76:5,19 77:1,5,10 appears 34:7 79:14 assumed 130:3 104:19 acknowledge 127:6 77:17 78:12 82:16 82:15 128:5 Assuming 99:4,13 Baltimore 85:12 ACKNOWLED... 83:3,9,11,13 84:4 applied 107:15 Atlantic 24:22 53:9 Bank 11:1 107:3 127:3 84:8,14,19 86:6 apply 53:16,17 53:10 54:11,14,19 banker 25:10 71:3 acting 71:13 86:12 87:2,11,18 appointment 44:1 55:9 104:12 action 1:6 128:13 88:5,7 100:15 44:5 129:12 attached 127:11 banking 32:14 128:18 107:8 117:8 appropriate 57:17 129:21 banks 56:2 active 13:8,12 ahead 18:19 26:22 66:5 121:10 attaches 120:2 based 33:3 43:6 actively 14:8 17:8 112:3 approximately attachment 5:7 96:16 97:21 99:17 18:5 37:15 83:7 AIG 25:7 63:3,4,13 11:17 28:16 34:18,21,22 35:9 basically 12:2 85:11 63:18,22 64:7,15 April 129:1 attachments 5:15 basis 31:8 45:21 actual 95:22 65:5,8,16,20 67:4 area 92:17 93:5 attempt 55:17 46:1,9 54:7 97:14 adapted 55:14 67:8,16 101:3 107:20 attempting 24:8 Bates 1:8 added 94:5 al 1:10 3:11 5:8,12 areas 54:1 31:20 32:5,9 33:1 Bathrus 1:5,15 2:7 additional 43:15 129:6 131:6 argument 112:9 35:17 43:2 44:13 7:12,16 8:6 73:6 69:14 Alan 46:2 Aries 24:19 31:5,7 49:3 50:8 85:3 127:5 129:5,6 address 8:7,11,14 Alexander 3:21 31:14,21 32:1,5,9 attempts 83:14 131:5,6 8:19 9:9 88:9,13 allegation 97:20 36:22 37:4,10,22 attended 94:19 BB&T 107:2 88:16 101:20 38:4 39:3,18,20 attention 36:7 Beasley 94:18 adhered 56:7 alternative 68:18 40:15 41:19 42:4 76:16 77:20 81:19 Becker 3:19 5:4 adjourned 126:13 amend 97:4,7,10 42:9,15 43:11 88:4 6:22 7:1,22 8:3 administrative 97:12,16 107:18 44:10 attorney 14:15 20:22 21:4 28:9 amended 102:21 Arpin 41:9 17:13 20:2,12 33:14 34:1 35:7,8 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 33-4 Filed 06/21/2007 Page 37 of 54 Marialice Williams Page 2 39:10,16 72:4 69:12 brokerage 76:10 106:10 121:4,21 109:18 116:22 73:11 75:13 79:8 billion 27:15 106:1 121:22 129:9 131:5 79:17,20 81:1 bit 18:19 103:3 brokers 52:10 calling 62:5 cash 74:22 82:12 87:8 88:2 blanking 33:18 brought 17:12 63:6 calls 42:11,12 cc 47:19 48:8 90:11 99:12 102:7 41:8 47:4 100:14 101:17 CAM 10:1,4 25:17 cc'd 47:18 102:18 103:7 blew 12:3 Budget 13:22 14:19 34:8 71:20 73:15 cell 59:6 106:2 109:10 block 92:18 building 18:13 22:4 73:20,21 74:7,10 Center 25:6 60:19 111:5,9,17 112:4 blocking 33:16 built 61:3 74:12 75:3,7,21 certain 29:8 36:2 112:16,20 119:8 board 10:9,10 bunch 112:9 76:6,18 77:6,13 51:9,20 53:14 121:14 122:9 54:16 business 20:20 78:2,13,13 79:3 64:20 67:9 76:7,8 126:3 Bob 34:8 35:2,3 21:18 31:13,15,20 80:7 82:16 83:9 98:1 105:11 began 56:3 98:13 63:7 71:3 80:3,15 31:21 32:4,8 83:11 84:9,15,20 certificate 53:11,15 beginning 28:14 80:16 85:11,17 43:14,20 44:13,17 85:4,15,16 87:1,2 128:1 76:17 82:10 98:13 93:21 98:11 99:3 45:7 49:8,11,13 92:9,11,15 93:20 certificates 53:14 121:9 99:20 100:13 49:21 53:8,21,22 94:8,16 95:2 96:8 53:18 behalf 3:2,10 83:3 101:5,22 102:4,10 55:15 56:10 57:14 98:3,14 99:14 certified 6:16 83:5 103:1,12 109:17 57:18 58:11,14,20 102:20 110:13 certify 128:4 belief 45:21 46:9 116:8,9,17 117:12 60:17 61:7 63:2 113:10,14,20 chairman 15:8 believe 9:7 10:19 117:17,19 118:17 68:4 69:2,14 114:15,19 115:11 change 56:9,10 11:12 14:14 16:18 119:1,4,13,20 70:10 71:16 74:4 115:22 116:3 58:1 71:22 82:6 21:6 22:14,15 121:17,19 122:13 74:9,10,11,15 119:5 129:19,19 131:8 24:13 28:12 29:22 123:3,8,13,18 76:2,20 79:4 cap 38:12 changed 11:2 16:17 30:3 32:2 35:1 124:1,16 125:10 83:16,18 85:9 capacity 14:3 17:3 16:17 92:19 36:20 40:17 41:9 125:15 86:8,9 89:20 71:14 76:10 changes 127:9 42:19 43:3,10 Bob's 74:22 97:13,21 98:3,20 Capital 24:18,19 129:17 49:17 50:15,21 bond 60:21,22 99:2,4,13,16 26:6 28:11,21 changing 124:8 51:8,19 53:19 book 30:9 100:4,6,10 101:8 29:17 31:5,7,14 characterized 54:22 57:10,21 borne 26:13 101:22 102:16,19 31:21 32:1,5,9 105:12 59:13 65:4,13 bottom 82:19 101:7 116:8,19 117:3 36:22 37:4,22 charge 47:4 70:4 75:10 77:6,8 Bovis 25:4 118:18,19,22 38:4 39:3,18,21 cheaper 118:9 78:12 83:19,22 box 67:11 122:4 123:14 40:16 41:19 42:4 check 77:2 84:2 84:1,11,21 85:11 boxed 95:11 124:18 42:9,15 43:12 95:5,7 85:12 86:5,11,13 boxes 92:22 93:14 44:10 46:12,21 Cherouny 4:9 6:14 86:16 89:6 93:4 bragged 99:19 C 48:16 49:11 chest 103:2 93:17 94:6,9,11 break 72:3 C 6:1 captive 59:5,6,18 Chicago 31:10 97:9 98:2 100:22 breaks 27:8 cadre 37:10 60:4,5 61:13 chosen 129:15 102:14,17 103:16 Brian 94:18 calendar 52:21 119:17,18,21 Chris 103:20 108:10,13,13 bring 20:9 101:15 California 49:18 120:20 121:7,11 civil 1:6 14:20 15:1 115:13,20 116:7 101:21 50:10,19,22 51:5 121:11 16:15,21 17:6 124:19 125:11 broader 35:3 51:15,18 52:1 captives 59:21 18:3 believed 121:8 broke 73:14 call 28:1 40:11 car 12:2 claim 102:8 belongs 27:9 broker 74:6,7 75:2 48:10 123:13 card 52:13 claims 102:12 best 74:5 76:4,12,18 77:10 called 7:17 14:15 case 6:6,8 10:20 clarified 60:6 better 118:9,10 78:14,16 83:7 44:19 45:10 48:4 11:14 12:12 93:22 clarifies 112:6 beyond 28:22 99:20 100:8 55:18 84:21 95:21 94:1 98:12 103:14 clarify 58:17 79:2 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 33-4 Filed 06/21/2007 Page 38 of 54 Marialice Williams Page 3 97:13,19 112:17 45:3 62:10 119:3 55:10,14 59:18 contract 101:10,13 15:20,21 33:7 clear 35:15 49:6 communications 60:1,10 67:16 contribution 101:7 40:12 90:17 60:1 29:16 30:17,22 103:18 104:8 conversation 20:4 129:22 clearly 77:22 37:22 38:4,7 120:18 20:7 43:10 46:2,7 courthouse 98:9 clerk 98:8 40:14,20 41:18 concepts 52:11 46:21 47:13 courtroom 40:12 client 123:6,7 42:3,8 44:9 54:18 concern 46:17 125:12 courts 15:15 17:10 clients 24:16 25:19 55:3 56:14,19 conclusion 114:20 conversations Cowherd 68:10 118:6 60:13 61:19 63:17 conduit 50:8 46:13 97:1 119:13 co-brokerage 84:4 close 31:6,18 54:10 63:22 64:6 67:4 104:16,18 coordination 60:21 84:8,19 86:12 62:21 70:4 71:8 69:2 115:22 119:5 conduits 53:22 copy 75:10 77:1,7 Craig 100:7 102:2 closed 63:12 71:10 121:17 122:13 104:10 94:3 95:5 98:21 102:5 clue 100:1 community 121:5 Conference 2:12 100:17 129:13,15 crash 110:2 coach 111:21 112:2 companies 25:7 confidentiality Corporation 25:1 crashed 108:20 coaching 111:20 27:22 32:15 33:2 57:5 100:15 117:7 correct 9:12 10:1 109:6 coast 10:22 11:1 52:10 53:21 55:22 conflict 56:5 67:15 13:1 34:19 36:1 crashes 52:21 coat 93:1 56:2,21 58:10 conflicting 80:14 45:2,17 51:6 83:4 107:22 108:4 collateral 29:9 89:11 Connecticut 15:20 83:11 84:10 88:17 crazy 9:4 32:20 company 20:18 connection 75:22 88:18 92:1 96:13 create 68:16 Columbia 1:2 2:18 50:15 53:11 55:18 94:16 105:13 108:1 created 58:7 66:17 6:7 13:7,16 17:14 57:1,3,18 60:5,6 consent 66:8 110:3 127:8 85:10 100:5 104:8 22:8 61:1 119:16 66:1 74:22 76:13 considered 66:4 corrected 12:2 creating 98:17 120:8 128:20 78:1 85:11 86:7 consisted 32:20 correction 129:19 credit 41:2,5 44:14 come 26:4 27:17 87:16 88:10,14,15 constantly 30:10 corrections 127:10 50:4 52:13 56:4 33:3 38:11 59:1,7 104:15,15 56:11 62:15 129:18 56:12 59:1,6 63:5 104:12 106:6 compatibility consulting 71:14 correspondence 66:18 67:17 68:8 124:6 30:13 consumed 52:18 79:13 68:8,18 69:10 coming 59:8 compiled 67:13 consummated 83:8 cost 28:4 59:3 116:14 120:3,21 comments 46:10 complaint 90:16 83:9 cost-effective 50:3 cried 108:21 48:18,22 91:7,7 93:22 94:2 contact 30:6 31:12 counsel 6:19 7:17 crisis 58:8 commercial 69:18 96:19 97:4,8,11 38:16 61:21 62:3 7:21 13:21 16:18 critical 119:22 70:6 97:12,16 99:16 63:10 64:8,9 92:6 16:21 73:10 current 8:7 56:22 Commission 15:7 101:21 102:21 110:12 113:2,8,19 111:17 112:12 currently 6:13 13:3 128:20 107:18 109:16 114:15 115:10,15 120:15 128:12,16 13:8 21:10,17 commissioner complete 19:4 contacts 119:21 129:12 89:7 97:3 120:7,13,14 25:12 61:1 127:8 123:10,11 counsel's 40:4 41:3 customer 47:20 commissions 80:4 completed 129:20 contained 93:15 41:11 83:21 86:7,18 completely 75:8 contemplated 85:7 country 53:12 61:3 D 87:1 comply 91:17 contents 92:21 Countrywide 24:21 D 5:1 6:1 commodity 68:2 computer 52:20,21 context 110:20 49:14,19 50:2,12 daily 30:6,17 53:6 common 76:19 107:22 108:4,19 111:2 113:11 50:17 Dallas 29:21 communicated 108:22 109:6 continue 20:19 couple 8:22 9:1 Dan 41:14 39:18,20 57:7 110:1,9,12 113:1 74:3 51:17 Dana 120:14 116:2 113:2,17 114:7,13 continued 69:11 course 9:22 10:4 Daniels 3:3,8 7:11 communication 114:14 74:19 99:2 121:12 court 1:1 6:7,17 7:11 12:15 26:19 29:2 30:4,19 31:3 concept 43:16 continuing 56:20 7:14 11:8 15:16 26:22 33:12 35:5 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 33-4 Filed 06/21/2007 Page 39 of 54 Marialice Williams Page 4 39:8 72:1 79:16 decide 66:15 describe 41:7 discouraging 49:7 91:3,6,12,15 87:19 94:18 98:8 decided 104:16 107:10 49:10 106:9 107:7 102:3,9 103:3,6 decision 50:13 51:5 described 34:13 discovered 55:5 109:14 115:6 105:18 111:3,7,13 51:9,13 60:7,8 42:18 107:9 98:18 documentation 111:21 112:3,12 decisions 54:9 describing 35:4 discovery 33:6 22:19 42:7 67:10 122:6 129:2,3 defaulting 67:22 75:20 discuss 20:13 50:11 98:1 107:9 115:14 Danny 34:9 63:7 defect 11:22 description 34:22 65:22 66:6 117:6 125:20 date 6:11 29:11 Defendant 6:4 35:2,3 120:11 123:8 documents 5:19 34:16 40:19 51:16 Defendants 1:11 designated 66:12 discussed 65:16 19:14,15,19 20:9 64:2,2 88:8 3:10 5:18 7:18,21 designer 18:12 116:17 122:17 23:1 40:10 75:9 108:14 113:15 73:10 desire 43:13,15 125:10,14 83:13 90:20 91:1 127:14 131:7,22 define 78:1 desired 130:3 discusses 34:11 91:11,14 92:5,8 dated 5:8,12,14,16 definitely 65:13 desk 67:12 discussing 34:10 92:10,12,14,22 5:21 80:1 109:19 109:7 detail 62:20 65:20,22 117:19 93:4,11,18 94:7 dates 53:3 108:3 delegated 105:20 determined 12:7 118:22 120:11,18 96:11,17 98:5 124:11 denied 97:13,21 develop 38:22 121:6 103:13 110:8 David 16:16 41:13 99:16 developed 21:15 discussion 33:7 112:22 113:22 47:3,3,14,15 Department 14:11 33:4 38:15 39:2 44:15 114:6,12 115:18 48:21 14:13 15:2 24:7,7 development 16:6 58:9 64:15 107:19 doing 20:20 30:7 day 42:22 45:20 departure 20:21 30:8 32:14 38:21 116:9 117:12 44:3 46:15 49:7 52:6,7 46:5 59:20 43:3,16 52:8 118:16 126:7 49:11 71:7 74:9 days 52:18 121:21 depend 102:13 62:17 discussions 28:10 74:15 79:4 102:16 129:9 depending 41:3 dialogue 56:21 28:21 29:20 36:21 104:9 116:21 dead 92:7 depends 105:3 74:20 37:4,13 48:2 119:21 deal 19:20 38:19 deponent 127:3 difference 105:2 55:11 68:19 83:15 drawing 114:20 50:16 61:15 66:1 129:11,12,13,16 different 52:8,9,10 97:18 117:4 drive 109:2 66:4 68:1 70:4 129:18,20 130:1 52:11 70:13 72:2 121:13 122:2 driven 50:1 86:18 98:15,16 deposed 9:11,22 104:19,22 105:1 123:3,18 124:16 drop 102:7 100:4 104:21,22 10:5,12,14 106:3,18 125:3 duh 67:21 105:9 120:1 deposition 1:14 2:7 difficult 52:16 53:2 disparaging 48:17 duly 73:8 128:6 dealer 12:1 5:6,20 6:3,8,15,18 70:12 98:10 48:22 DUS 24:18 26:10 dealing 30:10 10:19 19:8,22 direct 36:4,7 49:5 dispute 18:12 26:12 27:4,11,13 46:11 20:13 26:17 33:21 76:15 77:20 81:18 district 1:1,2 2:17 27:15 31:15,20 deals 31:18 45:7 75:11 79:6,18 88:3 6:7,7 13:7,15 34:14 35:17 37:19 62:21 63:12 70:7 80:21 87:6 90:9 directed 90:20 15:19 17:14 22:8 37:20 38:1,5,8 71:8,10 103:17 94:17,19 95:5,17 direction 128:9 61:1 90:17 119:16 39:4 44:13,21 104:6,7 117:4,6 96:2 102:11,13 directly 38:10 47:9 120:8 128:20 60:15 70:18 117:13,15,18 109:8,17,17,22 48:21 59:22 83:18 division 14:21 15:1 104:22 105:1,3,9 118:1,4 113:16 126:9,12 director 16:15 16:22 17:6 18:4 105:12,19 106:15 death 95:11 128:3,6,10,14 49:17 40:7 107:11 Deborah 1:22 2:15 129:6,8,8,11,15 directors 10:10 document 34:4 D.C 1:17 2:13 3:5 6:17 128:2 130:7 129:21 130:2,3 disagreement 67:7 75:15 76:3 79:22 3:14 4:3 6:11 8:9 December 64:19 131:1,7 disclose 44:6 48:1 81:7,15,16 82:14 8:17 9:6 24:7 65:1,4,9 depositions 10:3 disclosed 67:14 86:14,15,22 87:9 129:4 131:2 decent 101:16 11:5 98:19 93:8 87:13,14 90:13,18 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 33-4 Filed 06/21/2007 Page 40 of 54 Marialice Williams Page 5 E errata 95:20 28:5 32:18 42:8,14 43:11,14 15:20 E 5:1 6:1,1 73:1,1 127:11 129:14,18 experience 86:1 43:19,21 44:4,9 fee 22:7 23:6 59:10 earlier 40:1 65:11 129:20,21 131:4 expertise 32:13 44:20 46:5 47:19 feel 111:1 125:21 east 15:19 Esquire 3:8,19,20 74:21 48:1,10 50:6 53:1 feeling 125:16 eastern 15:19 3:21 4:6 6:15,18 Expires 128:20 54:18 55:6 57:7 felt 101:6 ebecker@omm.c... 129:2 131:1 explain 32:12 57:18 59:1,2,7,10 Fidelity 85:12 3:16 essentially 69:6 35:14 48:10 59:19,22 60:9 Fidelity's 85:16 editorial 129:17 establish 49:19 extended 28:22 61:5 62:8,11 63:7 field 62:18 educated 99:21 estate 67:18 extent 46:14 67:7 63:8,15,18 65:16 file 88:20 89:2 95:8 effort 95:1 estimate 11:15 74:18 89:11 65:18,21 66:7,12 95:15 efforts 35:18 et 1:10 3:11 5:8,12 extremely 111:15 66:15,21 67:3,4,8 filed 90:16 93:22 Eighteen 15:3 129:6 131:6 Eye 2:11 3:13 6:10 67:9,16 69:13,16 109:16 129:22 either 27:7,18 Evelyn 3:19 6:22 e-mail 5:7,11,15 70:3 73:19,21,22 130:3 40:22 44:13 8:3 29:12 34:7,16,19 74:8,13 79:2,4 files 93:15 94:21 110:13 114:16 event 74:16 35:4,9 47:17,19 83:15,17 85:7,19 95:2 115:3 129:11 eventually 12:2 48:13 68:12 81:17 86:8 87:15,22 filing 88:22 89:7 130:2 everybody 86:3 108:15 88:8 90:17,19,22 finalized 107:19 eliminate 35:19 exact 37:8 40:19 e-mailed 47:22 91:15 92:12 93:19 financial 10:1,5 Elizabeth's 24:9 55:19 124:11 94:1,4,8 96:11,17 25:17 34:8 71:20 exactly 22:18 29:13 F 97:14,21 98:3,15 73:20,22 74:10,12 employed 128:12 128:16 35:12 51:8 108:5 F 73:1 99:3,14,15,17 75:3 76:6 78:3 employee 128:15 115:2 125:8 face 53:10 100:1,2,8,14 80:8 82:17 85:4 employees 23:17 examination 5:3 facilitate 38:10 101:4,7,9,22 90:6 98:14 99:14 employment 14:21 7:17,21 73:10 facility 61:2 93:13 102:15,19,22 99:22 102:20 15:1,6 17:7 examined 7:19 93:19 94:8 103:1,19,22 104:9 116:3 enables 53:13 73:8 127:6 fact 27:18 68:15 104:16 105:5,15 financially 128:17 enhancement example 18:8 44:2 99:1 106:6,17 107:1 financing 24:9 61:1 44:14 50:4 56:4 66:17 107:1 facts 11:14 110:13 113:3,10 find 32:18 33:1 56:13 59:2,7 68:8 excuse 71:22 72:1 fair 38:3 41:17,20 113:13,20 114:15 47:2 57:17 113:6 68:9,18 116:15 99:6 111:4 114:9 66:3 67:2 71:12 114:19 115:11,15 115:5 120:3,21 execution 61:14 117:11 115:22 116:10,18 finish 114:9 ensure 85:17,21 118:11 familiar 26:11,14 117:13 118:2,5,13 finished 97:17 86:6 87:15 129:17 exhibit 33:21 34:3 71:5 112:15 118:18,19 119:7 firm 6:15 100:11 entered 88:7 35:7 75:11,14 family 95:11 121:18,20 122:14 100:11,13,15 entire 62:1 95:12 79:6,10,18,22 Fannie 4:1 6:5 7:1 122:17,18,20,20 firms 32:14 entirely 58:11 80:21 81:6 82:14 7:4,7,10 10:19,20 122:21,22 123:4 first 5:18 8:8,16 entities 29:10 73:18 87:5,6 90:9,13 10:21 17:17 19:16 123:20 124:1,21 14:12 22:5 24:22 entity 21:16 88:9 109:8,12 125:5 20:19,20 21:15 129:5 131:6 27:9 36:10 53:9 88:12 Exhibits 5:6,22 24:18 25:16 27:4 far 66:4 69:12 96:9 53:10 54:11,14,18 entree 120:7 exist 20:17 21:10 27:12,14 28:4,5 116:3 55:9 61:2 62:7 Equal 15:6 existed 67:11 32:6,10 33:4 father 17:13,17 63:5 68:16 69:8 equity 103:22 existing 21:8 34:14 35:11,16,21 father's 18:2 77:12,21 84:18 Eric 25:9 70:4,21 exists 21:7,9 38:7,9,15,20 39:6 favor 18:10 88:4 91:21 71:2,5,8 86:1 expenses 89:16,19 39:20 40:3,9,15 feasibility 121:7 fit 105:16 expensive 12:9 40:21 41:19 42:3 federal 1:9 3:10 five 9:18 18:6 20:8 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 33-4 Filed 06/21/2007 Page 41 of 54 Marialice Williams Page 6 flew 29:21 50:10,22 43:16 73:9 97:13 73:12,13 105:22 happy 101:4 121:6 51:4 52:1 110:12 113:2,8,19 goodness 24:21 hard 109:2 Howard's 67:11 Florida 59:3,11,15 114:15 115:10 25:21 57:8 Harley 3:3,8 7:11 Hoyes 74:1 fly 50:19 128:14 governance 10:12 12:15 94:18 129:2 HUD 16:5,8 focusing 122:18 government 14:9 129:3 Huebscher 5:10 follow 97:5 G 15:13 22:8,20 harleydaniels@h... 7:2,4,7 55:9 75:17 followed 130:2 G 6:1 Grace 7:1,4,7 55:9 3:7 77:9 78:18 87:22 follows 7:20 73:9 general 11:12,18 75:17 87:22 Harris 16:8 hybrid 70:12 foregoing 127:7 12:1 13:21 16:18 103:18 Hartsfield 5:16 128:3,5 16:21 40:4 53:5 grader 100:20 21:22 23:12 53:7 I forgot 25:18 40:1 generalized 31:16 graduated 14:10 83:1,2 idea 53:5 78:11 form 44:14 50:9 generally 31:9,10 great 19:20 98:14 Hartsfield's 23:15 115:7,9 111:14 121:11 40:22 117:2 98:16 100:3 Harvey 21:22 ideas 87:15 formal 71:21 73:17 gentleman 47:5 106:22 23:12 83:1 identification formalized 87:2 Gett 32:1 Greenwald 46:3 head 43:8 61:17 33:22 35:6 75:12 formed 20:18 21:5 give 11:15 18:22 Griffith 4:6 7:9,9 120:16 79:7,19 80:22 former 120:12 33:11 104:13 ground 111:14 Health 24:8 87:7 90:10 109:9 forms 29:9 106:22 118:10 group 38:13 105:15 hear 33:12 85:13 identified 88:15 forth 62:15 68:12 given 11:4,7 100:3 107:15 heavily 52:19 100:13 88:8,10,13 89:21 101:8 111:3 Grove 5:16 held 2:8 6:9 31:9 identify 23:2 24:16 107:9 113:22 123:21 Groves 34:9 63:7 31:10 126:7 129:9 52:3 75:15 82:13 forward 45:20 127:9 128:11 Grundeman 3:20 130:1 87:9 51:10 74:22 giving 19:4 7:3,3 help 112:7 immediately 8:14 120:22 go 15:4 18:21 26:22 Guarantee 24:22 helped 68:16 9:2 44:20 48:4 four 9:19 95:16,16 37:9,10,10 38:22 guess 40:10 83:19 helpful 55:6 109:4 96:4,5 39:8 53:3 56:11 89:10 helping 125:17 important 40:3 frame 28:13 29:19 59:11 65:21 72:2 guide 107:12 hereto 128:16 include 125:9 30:16 31:19 37:3 72:4 82:6 87:16 Hispanic 65:13 including 98:17 37:12 38:6 45:15 95:10 99:7,8 H hold 107:12 income 89:2,3 48:12 52:3 54:13 112:3 118:8,8,13 Haberkorn 68:10 holder 69:9 incorrect 98:4 56:18 61:18 63:21 124:4,10 125:12 Hal 49:15 50:11,15 holding 52:12,13 independent 47:8 78:17 79:11 118:3 126:3 51:7 home 22:5 91:22 indicate 6:20 Frankly 111:3,4 going 8:4 28:5 29:4 Hampshire 9:6 Hommer 1:22 2:16 indicated 6:12 Freddie 69:17,21 30:12 34:2 39:12 Hampton 120:12 6:17 128:2 130:7 46:12 free 111:1 51:10 53:19 54:8 120:13 honest 85:1 indicating 22:20 frequently 45:19 75:18 77:18 80:13 hand 34:2 79:9 honestly 124:2 51:22 86:22 Friday 44:1 82:6 85:8 96:22 100:21 honoring 86:3 115:14 friend 18:10 97:2 98:3 100:5 handing 75:14 Hook 41:12 individual 26:9 123:13 101:13 104:3,4 79:21 81:2,5 hope 116:20 117:9 front 35:4 107:1,3 111:5,9 90:12 109:11 hopping 66:2 individuals 27:20 fulfilling 55:6 116:20,22 118:2 handle 41:15 Hospital 24:10 37:6 53:4 full 18:22 19:5 59:8 122:3 Hang 103:3 hour 42:22 industrial 60:22 126:1 Goldfrank 3:21 7:6 happened 47:18 hours 52:6,6,7 industry 30:14,15 fully 102:14 7:6 78:9 housing 16:5 55:7 58:9 further 38:15 good 8:1,2 72:3 happens 86:19 104:1 120:19 inferior 102:6 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 33-4 Filed 06/21/2007 Page 42 of 54 Marialice Williams Page 7 inform 55:4 115:3 128:17 Jones 5:7,13 34:8 70:19 77:2 78:8,9 123:2 information 19:12 interference 102:8 63:7 71:3 80:3 78:9,17 80:14,16 lawsuits 12:16,18 19:13 53:1 67:10 102:12 93:21 98:12 99:3 84:22 85:3,18 12:21 103:11 123:22 interior 18:12 99:20 100:13 86:2 87:3,3 89:13 lawyer 12:11,14 125:5 international 99:20 101:22 102:4,10 91:2 93:1,2,3,14 13:1 94:15 97:2 initial 98:12 100:8,10 103:1 109:18 93:21 94:2,20 101:5 initiated 59:19 introduce 6:19 116:8,9,17 117:12 95:4,7,21 96:9 lawyers 101:3 innuendo 49:4 investment 25:10 117:17,19 118:17 101:6 103:9 107:5 lay 28:6 32:19 instance 18:7 32:14 71:2 104:12 119:1,4,13,20 110:21 112:8 38:12,12 118:6 instances 105:17 invited 31:7 121:17,19 122:13 116:3,8,21 117:1 laying 26:8 29:6 institution 69:5 involve 38:15 94:1 123:3,8,19 124:1 120:22 121:12 44:21 68:9 insurance 25:7 involved 12:18,20 124:17 125:10,15 122:4 123:15 learn 49:9 27:17,22 29:5 46:15 103:10 Judge 1:8 124:8,11 125:13 Lease 25:4 27:10 30:12,14 33:2 involving 10:12 Julia 92:6 94:20 125:13,14,18 27:16 29:20 30:5 34:12 41:15 44:4 50:16 54:11 60:3 June 22:14 85:1 knowledge 47:10 30:17 31:1 37:9 52:9,10,11 55:22 70:5 jurisdictions 96:7 107:20 led 98:2 56:2,21 57:1,3,17 issuance 60:21 119:19 knowledgeable Lederer 94:18 58:8 59:5,18 60:4 issue 10:12 32:16 Justice 14:11,13 59:21 99:21,22 left 16:4 20:19 40:2 60:6 61:13 63:6 41:4 53:13 60:3 15:2 known 68:16 95:19 44:20 53:1 60:9 63:10 66:1,9,18 103:19 104:18 Kyra 3:20 7:3 62:8 63:8,15,18 67:17 69:10 74:6 issued 60:22 69:21 K 66:20 67:3 70:3 74:17 76:19 83:7 70:1 Kalinsky 41:13 L 73:19,21 85:7 85:11 87:16 100:9 issues 29:8 30:10 Kathy 41:13 L 3:19 99:15 100:6 101:9 100:19 103:21 30:11 56:5 110:14 Katrina 98:10 language 86:15 101:10 103:1,19 116:19 119:15,17 110:16 113:6,7,10 116:4 101:2 legal 6:16 93:15 119:18,22 120:7 114:17,18 115:3 keep 29:11 129:16 lapsed 22:9,17,21 legally 76:13 120:12,13,16,20 items 125:9 kept 85:8 23:3 24:3 legislative 16:7 121:11 i.e 129:19 key 103:6 large 33:4 67:6 lend 25:4 27:10,16 insure 28:1 kgrundeman@o... 96:12 102:13 29:20 30:5,17,22 insurer 63:4 J 3:17 Larry 69:17 120:10 37:9 54:1 insurers 61:22 Jay 3:3,8 129:2,3 kicking 69:16 120:12 lender 24:18 27:11 67:18 Jeff 41:9 kind 54:3 70:12 Larson 1:22 2:15 27:13 28:4,6 intelligence 46:4 job 1:21 73:20 86:3 100:18 128:2 130:7 60:16 70:18 intelligent 95:13 104:2 131:7 101:10 118:10 law 3:3 9:20 13:12 105:10 intend 64:13 97:5,7 John 1:8 121:4 122:5 14:7,10 15:22 lenders 26:10 33:3 97:10,12,16,19 Johns 103:20 knew 67:10 117:8 16:10 17:2,8,20 35:18 37:16,17,20 101:21 102:7,20 join 28:6 know 9:4 22:7,16 18:5 40:8,11 98:8 38:14 56:2 66:8 107:18 115:1 joint 74:7,16 75:2 25:14,14 26:1,11 129:3 66:19,22 104:19 intended 114:22 76:4 78:11 82:16 30:9 33:15,16,17 Lawch 7:2,5,8 41:1 105:15 intent 97:3 83:3,10,12 84:13 33:17 35:12 46:14 45:9,15,22 46:9 lengthy 62:18 intention 96:18 jointly 74:20 85:14 46:16 47:18 48:21 46:13,19,22 48:17 letter 5:9,13 74:9 interest 21:13 76:1 85:14 49:20 50:13 51:2 49:1,10 99:18 74:13 75:16 76:16 116:14 Jonathan 4:6 7:9 51:3,10 53:5 106:11 77:8 78:10,18 interested 68:6 jonathan_griffit... 56:12 57:9 58:8 Lawch's 47:9 80:2,5,9 107:14 110:13 114:16 4:5 64:3,19 65:3,5,5 lawsuit 122:22 let's 24:13 25:22 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 33-4 Filed 06/21/2007 Page 43 of 54 Marialice Williams Page 8 29:21 31:22 72:4 104:14 105:3,4,11 17:17 19:16 20:19 Mae's 34:14 90:19 MCRI 69:15 98:7 106:22 108:8 105:13,16 106:4,5 20:20 21:15 24:18 90:22 91:15 101:7 mean 9:16 36:5 111:7 126:3 106:13,15,19,20 25:16 27:4,12,14 major 11:22 52:22 37:15 38:17 47:19 level 27:6,9,12,19 107:2,2,3,8,10,13 28:4,6 32:6,10 53:20 70:1 107:20 48:6,6,7,8 57:11 28:3,8 30:15 loan-related 121:3 33:5 35:11,16,21 122:21 58:14,18 64:20 Levin 55:8 locate 95:1 38:7,9,15,20 39:6 making 43:18 66:11 78:5 88:22 licensed 13:3 76:12 long 8:10,18 9:8 39:20 40:3,9,15 67:22 85:19 105:19 112:7,21 83:8 11:13 14:2,22 40:21 41:19 42:3 111:17 113:4 124:9 life 9:16 15:9 17:19,21 42:8,14 43:11,14 management 13:21 meaning 47:8 limitations 53:16 20:7 28:10 45:3,6 43:19,21 44:4,9 14:19 15:18 means 33:9 105:20 limited 54:7 58:11 45:6 62:19 44:20 46:6 47:19 manner 129:17 medication 19:3 67:6 83:12 84:13 longer 21:7 28:17 48:1,10 50:6 53:2 March 1:16 2:3 meet 20:2,3 29:22 line 72:2 101:7 28:18 68:3 93:16 54:18 55:6 57:7 6:11 52:17 109:19 50:10 59:4 68:11 110:1,7 129:19,19 130:3 57:18 59:1,2,8,10 113:16 131:7 74:20 131:8 look 37:17 44:2 59:19,22 60:9 Marialice 1:5,15 meeting 31:8 57:1 lines 117:2 56:11 63:9 75:6 61:5 62:8,11 63:7 2:7 3:2 5:20 6:4 59:14 list 25:12 77:16 110:21 63:8,15,18 65:17 7:12,16 8:6 73:6 members 10:9 listen 76:7 124:10 125:19 65:18,21 66:7,12 77:6 78:14 80:3 Mental 24:8 listing 129:18 looked 53:18 66:15,21 67:3,4,8 84:9,14,20 87:21 message 37:8 66:13 litigation 10:1,5 100:20 123:12 67:9,16 69:13,16 102:16 103:4 met 51:7 69:10 12:5 90:20 91:1 looking 32:15 70:3 73:19,21,22 105:18 111:22 75:17 92:9,11,15 94:16 37:11 43:20 50:3 74:8,14 79:2,4 112:3 127:5 129:5 method 129:15 95:2 96:8 58:22 68:7 77:3 83:15,17 85:7,19 129:6 131:5,6 Metropolitan 25:9 little 8:12 18:19 83:14 118:6,7 86:8 87:15,22 marked 33:22 34:3 69:3,5,8 70:5,16 33:11 50:6 70:11 looks 82:2 88:8 90:17 92:13 35:6 75:12 79:7 86:2 86:17 lost 87:19 93:20 94:1,4,8 79:10,19,22 80:22 Mexico 11:11 live 8:18 9:8 lot 25:12 29:8 96:11,17 97:14,21 81:5,19 82:14 17:16 lived 8:10,20 32:17 62:20 67:15 98:3,15 99:3,14 87:5,7 90:10,12 mezzanine 34:13 living 43:18 70:6 92:10,18 99:15,17 100:1,2 109:9,12 125:7 Michael 94:17 Liz 68:9 96:14 104:3 105:3 100:9,14 101:4,9 market 49:22 50:1 Miles 41:13 LLC 20:16 21:9 119:12 122:21 101:22 102:15,20 67:19 mind 129:16 22:2,17,21 23:2,6 123:1,9 103:1,2,19,22 marketing 75:1 mine 8:21 88:14 23:11 24:1,3,15 lots 101:17 104:9,16 105:5,15 101:14 mink 93:1 24:15 36:1,3,5,11 Lou 74:1 106:6,17 107:1 marketplace 29:4 minutes 20:8 36:15,20 71:20 lower 6:12 110:13 113:3,10 52:15 68:17 mischaracterize 73:16 75:4 77:12 loyal 123:14 113:14,20 114:15 118:15 78:6 77:13 78:2 88:17 lunch 31:22 72:3 114:19 115:11,15 markets 99:22 mischaracterized 88:20 89:4,8,16 73:14 115:22 116:10,18 Marsh 25:2 57:15 77:19 90:4 117:14 118:2,5,13 57:16,20 58:2 mischaracterizes LLP 2:10 3:12 M 118:18,19 119:7 Marshall 25:6 77:9 loan 10:22 27:7 Mac 25:2 57:15,16 121:18,20 122:14 60:18 misrepresent 77:14 106:9 120:20 57:20 58:2 69:17 122:17,19,20,20 Martha's 116:6 mission 55:7 loans 26:9,12 34:15 69:21 122:21,22 123:4 matter 6:5 10:13 Mississippi 98:8 35:20 52:12,13 Mae 4:1 6:5 7:1,4,7 123:20 124:2,21 matters 10:6,8,15 103:14 59:9 69:19,19 7:10 10:19,20,21 129:5 131:6 18:15 41:16 misstatement 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 33-4 Filed 06/21/2007 Page 44 of 54 Marialice Williams Page 9 76:22 multi 104:19 negotiating 106:13 129:19 operating 89:16 mistakenly 52:19 multi-family 10:20 negotiation 32:1 N.W 2:11 3:4,13 opportunity 15:7 mitigation 20:15 35:20 40:6 49:16 58:9 4:2 129:3 64:12 77:22 23:11 36:1,11,15 49:17,19 50:13 neither 128:11 opposed 105:5 36:18,19 55:21 51:6 63:5 66:18 nervous 9:4 O options 37:17 68:7 71:19 73:16 75:4 67:17 69:9 70:7,9 Network 10:11 O 6:1 73:1,1,1 118:8 76:5,11 78:2 80:7 74:3 107:12 never 12:1 43:13 object 111:8,10,11 ordained 105:15 80:11 82:17 83:4 mutual 5:17 87:10 43:14 66:4,7,10 111:12,13 order 74:10 82:3 83:6 88:16,19 87:17 88:4,6 66:10 80:2,9 83:8 objection 111:10 85:16 95:12 89:3,8,9,15 90:1,3 Myers 2:10 3:12 83:10 111:18 organization 121:5 90:7 6:10 19:14 new 9:5 11:11 obtained 98:9 organizations modify 56:12 17:16 18:13 24:9 occasional 18:7 121:6 moment 39:9 N 55:14 56:3,12 occur 24:11 original 93:22 94:1 money 12:4 85:19 N 5:1 6:1 73:1,1,1 62:9 65:3 68:11 occurred 110:2 129:8,21 130:1 98:15 name 6:14,22 8:3,5 68:12 71:4 89:13 October 128:21 originated 26:10 month 22:13 109:5 11:2 25:22 41:8,9 101:20 110:9,12 offered 73:20 106:6,14,15,21 months 8:13 15:3 41:9,14 47:1,4 112:22 113:2,17 office 13:21 14:18 107:5 15:10 17:5,22 55:19 58:20 65:14 114:7,13,14 15:15 16:15 17:10 originating 30:12 18:1,3 40:5 45:5 68:10 88:9,12 119:16 17:15,18,20 18:2 other's 76:2 51:8,18 64:7 89:22 90:2 120:15 newest 119:17,18 22:4,5 40:4 41:2,3 Ott 99:18 100:8,17 Morgan 25:8 68:5 131:5,6 Newman 5:11 41:5,11 67:11 102:2,5 68:6,14,15,20 named 68:17 40:22 55:8 75:18 89:19 91:19,20 outcome 128:18 70:2,15 104:13 names 11:3 26:3 newsletter 29:12 95:10,12 108:7 outset 125:11 morning 8:1,2 61:16 117:16,20 60:7 129:11 outside 14:6 69:21 mortgage 1:9 3:11 Narassiman 45:10 nice 45:12 officer 128:2 out-of-order 82:2 24:17,20 25:5 46:3 Noble 5:8 34:8 officers 23:10 overall 9:16 26:6 27:10,16 narrow 50:2 66:13 offices 2:8 3:3 6:9 overheard 46:2,8 28:11,21 29:16 National 1:9 3:10 non-disclosure 22:3 129:3 owner 60:4 30:15 32:15 35:20 18:11 5:17 87:10,18 oh 9:5,15 10:18 ownership 76:1 37:9 44:18,19 nature 13:18 26:5 88:5,6 13:20 24:21 25:21 O'Melveny 2:10 45:4,8 46:12,20 31:4 32:4,8 40:13 Northwest 6:10 8:8 39:22 41:13 51:2 3:12 6:9 19:13 48:16 49:10 58:21 44:8 49:6,13 55:2 8:16 9:6 91:21 57:8 59:17 60:15 58:22 59:15 60:13 55:15 56:8 57:14 92:17 131:1 64:17 81:13 91:2 P 69:9 70:12 104:14 60:3,17 61:7 63:2 notary 2:17 7:19 91:8 94:13 106:22 P 6:1 120:19 121:3 68:4 69:1 77:10 128:1,19 113:21 117:21 Pacifica 10:11 mortgages 26:9 115:21 122:1,12 noted 89:11 Okay 72:4 103:5 package 59:8 54:2 68:2,3 122:16 notice 2:15 92:20 111:7,13 112:21 page 5:3,6 36:10 104:11,20 NCRC 121:4 notifying 108:15 113:15 122:12 81:19 82:2,15,19 mortgage-backed necessarily 107:5 notion 105:21 old 93:2 109:22 110:6,6 32:21 54:6 67:20 necessary 94:5 number 6:3,8 OMB 15:5 16:14 129:18,19 131:8 Motors 11:12,18 111:2 129:18 19:11,12 21:12 once 60:8 63:8 pages 1:19 95:17 12:1 need 38:14 111:21 26:10 68:13 82:5 100:6 96:4,5 127:7 move 22:10 51:10 112:1 122:10 82:7,10 119:15 ongoing 37:18 43:1 paid 18:16,18,18 74:22 120:21 negotiate 107:7 125:15 oops 75:6 22:6 23:5 85:17 moved 8:22 22:3,4 negotiated 106:12 numbers 125:8 opened 55:17 paper 95:16 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 33-4 Filed 06/21/2007 Page 45 of 54 Marialice Williams Page 10 papers 33:7 pervasive 52:15 118:22 124:1 procedures 100:3 provide 50:3 56:4,5 paragraph 76:16 phone 20:4 42:11 Potter 49:15 50:11 process 62:19 67:9 125:4 129:13 77:21 88:4 42:12 practice 13:4,9,12 processes 100:2 provided 19:13 paragraphs 83:20 Pinnacle 25:5 13:19,22 14:22 procure 24:8 75:10 103:11 pari 28:2 58:21,22 59:4,15 16:10 17:15 produced 19:15 129:15 part 29:2 33:4 57:9 60:13 121:1 practiced 14:7 18:5 92:13 96:12,17 providing 34:12 96:12 98:10 125:13 18:7 115:19 59:6 102:13 place 6:6 72:3 92:4 practices 106:17 product 21:14 public 2:17 98:11 particular 81:17 92:5,22 117:8 practicing 13:15 27:15 30:7 32:13 128:1,19 parties 26:13,14 places 67:1 15:22 17:2,6,8 38:21,22 43:2 purchased 27:8 87:17 128:13,16 Plaintiff 1:7 3:2 40:8,11 44:4 52:7 55:5 105:4,5 partner 76:9 7:12 precisely 52:4 62:17 66:16 98:17 purported 100:18 party 6:20 12:21 please 6:19 7:14 78:21 100:4 118:10 purpose 87:13,14 94:5 8:5 48:1 111:19 preclude 19:4 production 5:19 129:16 passu 28:2 112:4 predetermined 90:19,22 91:10 Pursuant 2:15 Patricia 16:7 PNC 107:2 54:8 products 33:3 pursue 20:19 21:14 Paul 41:12 point 45:19 60:20 preferred 27:22 Professional 2:16 44:21 66:21 Pause 82:8 99:9 74:18 85:10 premier 105:14 profit 50:7 pursuing 26:7 pay 71:11 101:14 111:20 prepare 19:7,21 program 49:20 38:18 43:13,18 paying 38:21 59:10 policy 41:2,5 29:3 129:18 50:9 67:1 103:22 47:11 116:14 payroll 90:4 100:19,22,22 present 4:8 37:14 104:1,8 107:11,16 put 25:18 26:3 36:5 people 18:9 21:14 pool 54:4 69:20 96:18 119:6 project 24:7 47:7 48:8 67:13 111:2 26:2 29:11 30:7 104:14 121:16 122:15 promises 43:18 putting 93:11 32:17,18 37:11 pools 26:8 104:17 123:5,18 properties 70:8 p.m 73:2 126:13 38:13 42:17,20 104:19 presentation 85:13 property 8:21 43:4,4,5,19 52:12 pops 65:12 president 23:14,16 67:21 Q 52:13 54:1 59:20 popular 54:2 74:2 proportion 52:22 qualification 102:6 74:21 101:9,14 portfolio 30:11 pretty 18:15 94:3 proposal 33:8,14 question 26:19 103:15 107:15 70:14 108:16,17 123:8 35:11,15,22 36:14 40:2 46:4 62:16 116:13 117:17 portfolios 32:17 previous 33:6 36:17 37:1,5,19 77:15 78:6 84:17 121:2 43:22 previously 37:7 38:1,5,8 39:4 84:18 111:14 perceived 29:9 portion 6:12 28:7 73:8 96:10 107:21 55:12 56:16 58:4 112:11 114:10 perfectly 81:14 32:21 98:20 primary 27:19 58:16,18,19 59:16 119:9 122:10 performed 15:18 position 14:6,12,17 prior 8:15 9:3 60:14 61:12,20 124:11 period 62:1 15:4,9,12 16:1,3,4 20:21 46:5 57:8 62:4,6 63:19 64:1 questions 8:4 18:20 periodically 68:11 16:11,13 59:19 79:3 83:15 64:10,16,17 65:7 97:1 125:22 permit 100:9 possession 92:14 84:17 105:16 66:10 68:21 70:17 quick 99:7 person 18:9 21:11 possibility 26:7 106:8 108:8 71:1,6,15 quit 104:2 21:20 47:3,9,10 44:3,21 59:4 priority 66:22 proposals 117:5 quite 25:8 56:21 47:16,22 48:5,19 60:11 103:21 private 13:22 119:15 123:19 69:4 49:16 60:20 102:6 possible 68:7 probably 30:18 124:18 125:1 quote/unquote 120:1 possibly 44:4 45:20 47:2 49:20 proposed 82:16 32:20 99:19 personal 90:2 post 32:19 56:1 58:6 64:18 proprietorship 122:16 potential 61:13 76:22 80:10,12 21:19 R pertaining 29:8 68:12 71:4 118:19 119:13 proscribed 106:17 R 6:1 73:1 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 33-4 Filed 06/21/2007 Page 46 of 54 Marialice Williams Page 11 race 97:14,22 99:17 recognize 34:3 81:7 region 49:18 41:8 42:2,5,22 required 59:9 79:2 radio 10:11 81:10,12,15,16,17 Registered 2:16 47:1 55:19 62:2 research 27:21 raise 64:12,13 90:13,18,21 regulates 22:8 64:18 65:14,19 residence 9:2 102:21 109:14,15 regulations 56:7 78:22 80:20 81:13 residential 69:19 raised 46:4 recollection 28:20 regulatory 29:10 88:21 93:21 95:9 respect 29:5 56:5 ran 71:17 106:11 29:15 30:21 35:10 29:10 60:3 95:14 110:17 61:12 75:22 97:15 rate 92:19 36:13 42:13 43:6 reinsurance 61:13 117:21 119:2 97:20 104:10 rated 100:13 76:4 79:11 93:10 119:20 120:14 124:2 107:17 110:16 rating 120:2,3,4 124:16 126:1 reinsurer 120:1,2 125:2 responded 33:17 reaching 28:2 record 8:5 21:2 reinsurers 25:8 remembered 65:11 responding 47:20 read 20:22 21:2 35:14 39:9,12,15 52:11 61:22 remembering response 91:15 110:7,10 111:1 42:12 58:17 72:5 relate 32:6,10 41:22 75:8 responsible 43:17 113:9 119:8,10 72:7 73:4 82:6,11 36:22 55:11 56:15 REMIC 32:22 54:7 result 12:5 19:14 122:10 127:6 98:11,11,22 99:7 59:15 63:18 68:20 69:20 resume 17:12 129:11 99:8,11 102:10 70:16,22 116:10 REMICs 53:17 resurrect 117:1 reading 91:9 130:2 111:11 119:10 related 37:5,19 remove 54:3 resurrected 63:8 130:3 124:6 125:13 44:12 59:17 62:3 Rent 89:21 retained 5:22 reads 6:13 77:5 126:4,6,7 128:10 92:8,14 93:19 rental 8:21 retrieve 53:1 109:1 real 67:18 99:7 records 51:22 94:8 115:4 117:13 renting 59:5 return 89:2 realize 68:2 93:15 98:22 118:2,4,18 122:14 repeated 45:18 returns 88:20 89:7 really 9:20 22:18 124:10 128:12 replace 54:4 89:13 34:12 39:5,22 Red 24:17 26:6 relates 120:4 108:22 reveal 117:16,20 65:18,19 78:21 27:10,16 28:11,21 relating 37:22 38:5 replacement 109:3 revenue 60:22 93:6 95:6 97:17 29:16 37:9 46:11 39:3 40:15 63:22 Reported 1:22 review 19:18 96:16 100:2 46:20 48:16 49:10 65:16 71:14 95:2 reporter 2:16 5:22 105:17 129:9,16 reason 18:21 46:16 reduced 128:8 96:7 116:17 6:17 7:14 21:2 129:16 73:21 74:4 93:17 refer 112:14 121:17 123:4,19 119:10 reviewed 19:11,20 94:6 102:14 reference 112:13 124:1,17 represent 6:21 7:1 40:10 96:11 recall 9:15 11:6 referred 45:22 relationship 31:5,6 12:11 revise 129:17 22:18 23:7,9 111:15 46:18 47:8 63:9 representation Rhoda 40:22 55:8 25:14,19 31:3 referring 21:21 69:12 71:19,21 117:9 75:18 38:2 39:3,22 48:20 78:8 81:3 73:15,17 74:5,19 representations Richard 7:2,5,8 40:14,17 41:14,18 86:16 95:19 98:5 78:1 79:3 85:15 18:17 41:1 45:9 46:19 41:21 45:5 56:1 110:15 114:19 85:16 represented 18:10 99:18 106:11 61:16 62:5 64:15 115:8 relationships 25:13 95:13 98:20 right 11:6 33:18 65:7,10,20 81:11 refers 113:13 relative 128:15 representing 7:4,7 47:1 77:3 95:10 108:5 120:8 reflected 85:6 relied 52:19 represents 104:14 109:13 117:21 recalled 73:7 refresh 35:10 36:13 relief 37:11 121:5 119:2 124:3 recapture 53:3 76:3 79:10 reluctant 80:18,18 request 19:14 125:22 recast 102:5 refused 67:9 rely 50:5 59:10 90:19,22 91:10 rights 14:20 15:1 receive 12:4 86:7 regarding 10:20 relying 59:2 requested 21:3 16:15,22 17:6 received 108:15 30:11 38:7 39:20 remain 64:6 119:11 125:5 18:3 110:11 113:1 41:19 42:4,9,15 remember 9:5 129:8 ripped 53:22 114:14 43:11 44:10 62:11 10:17,18 18:14 requests 5:18 91:15 risk 20:15 23:10 Recess 39:13 72:8 64:10,15 30:1 33:10 39:7 125:8 26:8,12 27:6,8,9 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 33-4 Filed 06/21/2007 Page 47 of 54 Marialice Williams Page 12 27:12,19 28:1,3,8 113:9 114:5,11,21 seek 56:3 120:16 special 15:7 29:6,6 32:16,19 says 77:22 83:20 seen 89:12 91:3,12 sign 80:11,18,19,19 specialist 6:16 34:14 35:19,22 86:17 88:6 113:5 98:19 129:11 specific 29:16 36:11,15,17,19 125:13 sell 50:7 signatory 88:1 30:22 31:3 42:2 38:12 43:22 44:22 scenario 81:13 selling 35:19 signature 82:20,22 43:9 51:15 53:3,4 55:20,21 63:5 schedule 14:16 send 37:8 95:4 126:11 127:14 58:10 62:13 64:4 66:18 67:17 68:9 school 14:10 senior 16:7 74:2 129:9 131:22 102:19 117:3,4,4 69:10 71:19 73:16 screen 6:13 sense 27:2 71:22 signatures 86:10 117:6,13,15,16,18 75:3 76:5,11 78:2 search 91:14,18 100:7 86:12 118:1,17,21 80:7,11 82:17 92:3 95:14 sent 79:14 92:10 signed 74:7 80:2,9 123:19 124:12,18 83:3,5 88:16,19 searched 91:16 116:2 83:5 84:1 85:22 specifically 31:2 89:3,7,9,15,22 92:4 sentence 76:17 127:11 129:20,21 41:15 42:5 43:21 90:3,7 118:7 seasoned 106:8 77:21 113:5,11 significant 101:6 49:4 51:3 66:19 RMS 22:16 23:2,19 second 3:4 28:3 separate 14:16 signing 83:2,19 116:16 23:22 24:3,6,14 76:17 129:3 separately 84:12 130:3 specified 107:14 24:16,17 25:20 secondary 27:19 September 57:11 simply 83:20 split 26:13 31:4 55:12 56:15 28:7 58:7 sincerely 48:5 spoke 40:22 41:1,2 61:8 68:5 75:21 Secretary 16:8 serve 14:2 130:5 41:22 42:20 43:3 76:9,18 77:12 section 14:21 15:2 Services 6:15,18 single 71:4 100:15 48:21 55:7,8 65:4 78:2,8,13,15 79:3 17:7 55:18 106:10 76:6 78:3 82:17 single-family 49:21 65:5,6 116:7 88:14 106:12 131:1 sit 124:15 119:14 Rob 55:8 securities 32:21,22 servicing 105:21 sitting 25:15 115:6 spoken 42:14,21 Robert 4:9 6:14 53:16 56:8 69:20 set 5:18 80:5 88:8,9 124:13 125:21 96:20 Roberts 16:8 120:4 88:13 106:16 situation 47:12 spreads 50:2 role 104:17 securitization sgoldfrank@om... six 9:10 40:5 St 24:9 room 2:12 120:17 10:21 31:17 50:5 3:18 size 105:2 staff 49:16 59:22 Rosenfield 25:10 52:14 62:18 105:6 share 83:21 86:18 small 69:17 70:7 standard 70:9 70:4,22 71:2,9,13 105:6,7,8 120:20 87:1 86:5 106:16 86:2 securitize 69:18 shared 27:12 28:3 smaller 53:21 standards 100:16 RPR 1:22 128:2 70:14 85:18 sold 92:20 107:6 130:7 securitized 27:7 sharing 80:4 sole 21:19 117:9 Stanley 25:8 68:5,6 rules 56:9 105:6 sheet 127:11 solely 43:17 68:14,15,20 70:2 securitizing 35:20 129:14,18,20,21 solutions 32:16 104:13 S 104:11 131:4 somebody's 67:12 start 69:7 112:8 S 6:1 73:1,1,1 security 54:6 67:20 sheets 95:16,20 someplace 31:10 started 62:8 sabotage 48:7 104:18 Shekar 45:10 46:3 sorry 13:20 14:1 Starting 109:22 Sarah 3:21 7:6 see 24:13 25:22 49:5 17:11 26:16 32:7 110:6 save 112:13 26:2 29:21 31:22 shelf 69:22 35:5 39:19 70:16 state 8:5 102:9 savings 10:22 11:1 34:5 36:3,9 66:11 shop 62:16 81:6 84:16 87:19 stated 37:7 103:12 25:9 69:3,5,8 70:5 78:4 81:20 82:20 short 24:20 25:13 91:8 95:3 103:2 statement 45:16 70:16 85:2 86:9 88:5 show 21:13 42:8 112:19 76:21 110:18 saw 62:7 85:20 95:6 98:7 105:3 78:11 87:4 source 52:20 111:15 94:2 98:1 100:17 108:9 109:15 shut 57:10 speak 59:21 statements 90:7 saying 42:19 58:3 111:7 112:7,10 Sid 32:1 speaking 111:10,18 states 1:1 6:6 76:18 74:14 75:21 86:4 seeing 81:11 91:10 side 30:13 105:9 116:13 117:2 100:12 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 33-4 Filed 06/21/2007 Page 48 of 54 Marialice Williams Page 13 station 10:11 sued 10:11 Taylor 121:4 42:16 46:17 48:14 77:15 78:17 79:11 status 22:16,20 suit 11:11 telephone 120:10 48:20 58:6 62:6 80:13 82:4,9 23:2 24:3 Suite 131:2 telephones 89:21 64:22 67:6 70:1 85:14 86:20 89:12 stayed 31:11 summer 30:2 78:20 television 6:13 75:6,7,9,19 76:14 92:19 99:8,10 stenotype 128:8 108:17 113:18 tell 29:13 33:19,19 76:14 77:4,4,5,7 100:16 110:11 step 104:16 115:12 116:7 40:1,18 44:8,11 77:11,14,18 78:7 112:13 113:1,17 steps 130:2 119:6 121:16 48:17 51:15 57:4 78:7,13 89:1 114:14 118:2 Steve 34:8 66:13 122:14 123:4,17 94:13 102:11 92:16 104:3 121:8 123:15 Stockman 16:16 124:17 108:6 113:7 116:5 108:16 111:2 126:5,8 129:8 stop 21:8 summertime 116:16 113:13 130:1 stopped 22:1 36:6 108:11 telling 80:14,16,17 thinking 10:16 times 9:14,18,19 43:13,15 45:13 supplied 115:13 83:16 114:3,4 65:2 18:4 50:22 69:11 58:11 Supreme 15:15 tentative 60:10 third 76:16 100:20 124:22 storage 92:17 93:5 sure 39:10 55:22 tenure 69:12 thirty 129:9 title 16:17,19,20 93:13,19 94:7 67:7 84:22 89:1 term 33:9,13 thought 10:22 23:13,15 story 89:14 94:3 108:16,17 termination 106:9 38:14 43:17 55:5 titles 16:17 Strategists 20:16 124:4 test 71:3 74:1 85:20 104:4 today 8:4 19:1,5,8 23:11 36:1,11,15 survive 102:12 testified 7:20 10:4 123:13,14 20:10 124:15 36:20 71:20 73:16 swear 7:14 12:17 73:9 89:6 three 8:13 9:18,18 today's 6:11 126:9 75:4 76:6,11 78:2 Swiss 25:1 55:16 96:10 107:22 24:12 53:11 83:20 told 45:10 47:17 80:7,12 82:18 56:15 57:7,9 114:1,4 106:8 49:1 75:18 100:5 83:4,6 88:17,19 sworn 7:19 73:8 testify 11:14 111:6 three-paragraph 101:12 102:15 89:4,8,10,15 90:1 128:6 114:12 86:17,22 Tom 120:11,12,13 90:3,7 testimony 11:4,7 thriving 67:19 ton 104:4 Street 2:11 3:4,13 T 19:1,5 84:3,12 Thurgood 25:6 top 36:8 61:17 6:10 8:8,16 22:6 T 73:1 86:21 95:22 60:18 tortious 102:8,11 91:21 92:17 93:5 take 43:21 87:15 113:12 127:7,9 Tim 24:6 59:12 totally 100:1 93:13,18 94:7 102:10 128:5,7,10 67:11 track 87:20 104:10 129:3 taken 6:4 95:8 theory 71:4 time 6:12 8:20 9:1 tranche 34:13 131:1 128:4,7,14 thick 45:14 11:13 13:11,16 transaction 63:6 structure 26:12 takes 62:19 thing 37:18 45:12 14:7 16:9 17:8,14 83:22 119:22 34:11 53:13,15 talk 41:6,10 46:20 52:17 54:3 61:11 17:14 23:5 24:14 transactions 27:4 68:18 69:15 105:2 58:2 65:8 68:11 86:17 96:6 110:21 24:15,20 27:14 31:17 54:10 68:13 structures 71:5 74:20 118:12,13 122:5 28:13 29:3,3,14 68:14 102:22 studies 15:19 talked 40:21 116:3 things 29:4 46:15 29:19 30:16,18 103:8 106:12 stuff 74:17 85:20 121:19 122:20,22 71:17 75:20 93:2 31:19 37:3,8,12 115:16 124:2 92:22 93:2 116:21 123:6 124:12 93:16 101:17 37:14,21 38:6 transcript 129:8,12 stupid 45:11 talking 35:13 73:15 115:16 116:2 39:11,14,17,19 129:13,16,21 submit 105:16 110:1 121:3 124:12 41:21,22 42:22 130:1,2 subsequently tall 47:5 125:7,15 44:7 45:15 48:12 transcription 127:8 129:21 tape 6:2 82:5,7,10 think 8:22 9:10,19 52:3 54:13 55:21 transcripts 96:2 substantial 99:1 tapes 85:20 11:1,2 12:7 14:15 56:18 57:1,6 58:7 transferred 40:6 substantive 112:10 task 129:10 15:11 18:8 22:6 61:18 62:7,19 traveling 51:18 suddenly 56:1 Tawa 103:21 22:12 23:4 25:16 63:21 64:14 65:15 92:18 sue 11:18 tax 88:20 89:2,7 25:18 40:5 42:10 69:4,16 72:6 73:3 tried 31:15,16 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 33-4 Filed 06/21/2007 Page 49 of 54 Marialice Williams Page 14 trip 65:2 understand 33:8 viable 123:12 116:12 118:6,8,9 129:13,15 131:6 triple 100:12 45:18 67:18 68:1 vice 23:16 74:2 118:14 woman 120:16 true 60:11 67:5 69:17 84:16 98:14 video 6:16 ways 32:18 56:4,12 Women 18:11 69:7 74:14 110:18 105:12 Videographer 4:9 63:9 70:14 129:11 words 38:20 102:4 113:15,21 123:16 understanding 6:2 7:13 39:11,14 Webb 24:6 59:12 104:11 127:8 128:10 74:1 79:1 87:12 72:6 73:3 82:4,9 Wednesday 1:16 work 17:21 21:22 trust 107:8 91:5 99:6,10 126:5,8 2:3 26:5 33:2 38:10 truth 80:15,16,17 underwriting videos 96:15 week 57:2 119:14 47:7,11 54:15 truthful 18:22 105:21 106:16 videotaped 1:14 119:14 121:20,20 56:3 61:4 70:15 102:15 unique 53:12,15 2:7 6:3 welcome 77:22 70:21 73:21 83:21 try 27:17 29:11 unit 55:21 92:17 Vineyard 116:6 Wendell 103:20 85:4 94:15 98:16 64:13 65:14 United 1:1 6:6 Virginia 15:20 went 14:10 15:6 104:4,5 101:16 100:12 vis-a-vis 29:5 16:5,14 40:3,3 worked 15:14 16:5 trying 10:18 18:14 units 70:8 Volume 1:20 50:15 51:8,14 16:6 17:16,17 32:18 33:10 38:11 University 18:11 vs 1:8 59:3,12 98:8 18:2,3 24:6,17,19 52:7 57:17 85:9 unsigned 5:9,13 101:1,2,2 103:13 24:19,21,22 25:1 117:1 120:19 80:2 W weren't 70:19 25:2,3,3,4,4,5,6,7 turn 109:21 110:5 updates 29:3 waived 126:12 118:16 121:3 25:9,11,16,17,21 turned 74:5 Urban 16:6 Wall 104:10 west 10:21 47:8 54:14 57:16 turns 98:4 101:18 use 44:4 66:16 want 21:14 27:2 we're 31:11 39:12 57:20 71:10 85:5 two 8:12 14:4 18:9 usually 41:12 50:7 66:16 80:11 39:15 62:5 72:7 101:3 103:18,20 28:12 32:2 52:21 101:10 89:13 111:11 73:4 82:6,11 106:10 115:16 73:18 85:2,2 86:9 utilization 121:10 118:13,14 124:5 99:11 115:6 working 17:9 21:12 86:11 102:3 utilize 66:9 wanted 69:14 85:13 116:20 119:18 37:7,16 38:11,18 107:22 110:14,16 utilized 69:9 wants 44:2 126:6 45:13 52:6,8 113:5,7,10 114:16 utilizing 59:5 warm 31:11 white 101:9 70:13 101:4 114:18 115:3 U.S 15:15 17:10 Washington 1:17 Williams 1:6,15 2:8 120:22 129:10 130:2 2:13 3:5,14 4:3 3:2 5:3,6,9,11,14 works 26:12 66:20 two-year 106:7 V 6:10 8:9,17 9:6 5:20 6:4,5 7:12,16 118:15 type 14:17 21:16 v 129:5 131:5 24:20 44:18,19 8:1,6 39:17 73:6 worth 27:15 31:13 47:12 53:8 vague 111:16 45:4,8 120:9,9 77:6 78:14 80:3 wouldn't 100:9 58:10,13 validity 60:5 129:4 131:2 82:13 84:9,14,20 124:5,13 types 52:9 53:14,20 value 12:8 wasn't 13:22 49:5 87:22 92:6 94:14 WPFW 10:10 typewriting 128:9 van 41:12 62:9 76:11 80:16 94:20 96:7 107:21 write 26:4 65:12 typical 89:19 variation 44:3 91:9 101:13 103:9 127:5 129:5,6 74:8 103:12 various 56:6 91:8 120:9 131:5,6 writing 62:7 U 118:7 watching 96:14 wind 83:19 written 35:1 78:19 U 92:17 93:5,13,18 vegetarian 47:5 Watergate 22:4,11 Wisconsin 4:2 100:21,22 103:10 94:7 vehicle 56:13 59:5 108:6,8,9 110:2 witness 7:14,17 wrote 60:7 74:13 Uh-huh 81:8,21 venture 74:16 way 27:8 38:12 12:18 26:20 27:1 75:17 77:9 78:10 84:5 88:11 110:4 78:12 82:16 83:3 45:22 50:3 53:20 33:15 73:7 87:21 100:19 ultimately 27:20 83:10,12 84:13 56:10,15,22 59:1 103:5 105:20 67:12 venue 66:21 66:14 70:17,22 111:20 112:1,5,17 X un 100:1 versions 101:1 78:10 84:11 85:21 112:18 119:12 X 1:4,12 5:1 uncovered 27:21 versus 6:5 93:19 97:10 104:9 122:7 128:4,7,11 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 33-4 Filed 06/21/2007 Page 51 of 54 1 Case 1:05-cv-01483-JDB Document 33-4 Filed 06/21/2007 Page 52 of 54 Case 1:05-cv-01483-JDB Document 33-4 Filed 06/21/2007 Page 53 of 54 Case 1:05-cv-01483-JDB Document 33-4 Filed 06/21/2007 Page 54 of 54