Case 1:05-cv-01483-JDB Document 33-21 Filed 06/21/2007 Page 1 of 10 EXHIBITS Case 1:05-cv-01463-JDB Document 33-21 00001 1 2 IN THE UNITED STATES DISTRICT COURT 3 SOUTHERN DISTRICT OF MISSISSIPPI 4 SOUTHERN DIVISION n) X 6 CAM FINANCIAL SERVICES INC., 7 Plaintiff, 3 -against- No. 1:01cv314BrR 9 GENERAL STAR NATIONAL INSURANCE COMPANY; GENERAL STAR INDEMNITY COMPANY; GENERAL 10 STAR MANAGEMENT COMPANY; GENERAL RE CORPORATION; GENERAL REINSURANCE 11 CORPORATION; CRUMP INSURANCE SERVICES OF MEMPHIS INC.; FEDERAL NATIONAL MORTGAGE 12 ASSOCIATION (FANNIE MAB), 13 Defendants. X 14 January 19, 2004 15 9:19 a.m. 16 Videotaped deposition of CRAIG J. OTT, 17 taken by Plaintiff, pursuant to notice, at 18 the offices of Dewey Ballantine LLP, 1301 19 Avenue of the Americas, New York, New York, 20 before Gail F. Schorr, a Certified Shorthand 21 Reporter, Certified Realtime Reporter and 22 Notary Public within and for the State of 23 New York. 24 25 ried 06/21/2007 Jan 19, 2004 - CAM of Craig Ott Page 2 of 10 Page 1 CONFIDENTIAL FNMA.MBW.004939 0000 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Case 1:05-cv-01463-JDB Document 33-21 Filed 06/21/2007 2 APPEARANCES: LUMPKIN & REEVES Attorneys for Plaintiff 160 Main Street Biloxi, Mississippi 39533 BY: JAMES R. REEVES, ESQ. BYRD & WISER Attorneys for Plaintiff 145 Main Street P.O. Box 1939 (39533) Biloxi, Mississippi 39530 BY: NICHOLAS VAN WISER, ESQ. McGLINCHEY STAFFORD PLLC Attorneys for Defendant FEDERAL NATIONAL MORTGAGE ASSOCIATION (FANNIE MAE) 643 Magazine Street New Orleans, Louisiana 70130 BY: GERARD E. WIMBERLY, JR., ESQ. ~and- CYNTHIA L. BROWNE, ESQ. DEWEY BALLANTINE LLP Attorneys for Defendant GENERAL STAR 1301 Avenue of the Americas New York, New York 10019-6092 BY: DAVID J. GRAIS, ESQ. Jan 19, 2004 - CAM of Craig Ott Page 3 of 10 Page 2 CONFIDENTIAL FNMA.MBW.004940 Case 1:05-cv-01463-JDB Document 33-27 ried 06/21/2007 Page 4 of 10 00014 1 CRAIG J. OTT 2 courses? 3 A. No, sir. 4 Q. Where is Pace University? 5 A. New York City. 6 Q. Allright. Did you attend 7 those at night while you maintained your 8 full-time job? 9 A. That's correct. 10 Q. Walk me forward with your work 11 history from the time that you graduated 12 undergraduate -- from the undergraduate 13 college in I think '68 you said. Tell us 14 the various jobs that you've held up to the 15 time that you went to work with the Gen Star 16 companies? 17 A. I worked for Aetna C&S in 18 Rochester, New York. 19 Q. Tl tell you, so we don't 20 interrupt you flow, I'll interrupt you here, 21 but as you go through this if you can tell 22 me generally what your job title was and a 23 brief description of what you did it will 24 save us from having to come back and ask 25 that question once you're through. Jan 19, 2004 - CAM of Craig Ott Page 14 CONFIDENTIAL FNMA.MBW.004952 Case 1:05-cv-01463-JDB Document 33-27 ried 06/21/2007 Page 5 of 10 00015 1 CRAIG J. OTT 2 A. Okay. I worked for Aetna C&S 3 in Rochester, New York, for an agency as an 4 underwriter, performing typical underwriting 5 duties. 6 I left there and moved 7 after -- that was after I was discharged 8 from the army in 1970. So I moved to New 9 Jersey in 1972 where I took a position with 10 Reynolds Securities, a New York Stock 1] Exchange firm as a registered 12 representative. I worked as a stock broker 13 there for two years. I left there and went 14 to -- took a position with General 15 Reinsurance Corporation as an underwriter. 16 Q. Approximately what year would 17 that have been? 18 A. 1973. 19 Q. You hired on there at Gen Re 20 as an underwriter? 21 A. Yes. 22 Q. Tell us in a very summary 23 fashion generally what an underwriter at Gen 24 Re, Gen Star Company does? 25 A. The position J held was Jan 19, 2004 - CAM of Craig Ott Page 15 CONFIDENTIAL FNMA.MBW.004953 Case 1:05-cv-01483-JDB Document 33-21 00016 1 CRAIG J. OTT 2 property facultative underwriter. I 3 entertained risk submissions from insurance 4 companies for the purpose of mitigating, 5 transferring, reducing risk on their part. 6 Facultative reinsurance is an 7 account-by-account acceptance, risk 8 acceptance process. 9 [left General Re in 1977, 10 '78, I'm not clear on that. °78, I believe. 11 Q. Why did you leave? 12 A. To start my own business. I 13 went to work as a broker at a small firm 14 called RFC Intermediaries. I worked there 15 for one year as a property facultative 16 reinsurance broker. | then left there and 17 started my own business called First 18 Manhattan Intermediaries in 1978. 19 First Manhattan Intermediaries 20 was a reinsurance brokerage firm. We had an 21 office in New York. A year later we opened 22 an office in Chicago. We had about 20 -- as 23 Irecall, 20 to 25 employees. We were 24 acquired by Alexander & Alexander in 198] -- 25 '83, 1983 I believe it was. ried 06/21/2007 Jan 19, 2004 - CAM of Craig Ott Page 6 of 10 Page 16 CONFIDENTIAL FNMA.MBW.004954 Case 1:05-cv-01463-JDB Document 33-27 ried 06/21/2007 Page 7 of 10 00017 1 CRAIG J. OTT 2 Q. Where did you go next? 3 A. That acquisition was -- we 4 were made part of a subsidiary of Alexander 5 & Alexander known as Thomas A. Greene & 6 Company. I worked there until 1988. I left 7 there to join another reinsurance brokerage | 8 firm called -- I don't remember what it was 9 called at the time. It was in a transition. 10 It became Aon Risk Services I believe was 11 the final name. 12 Q. Aon Risk Services? 13 A. I believe that was it. It was 14 not -- you cannot use the word reinsurance 15 in a brokerage name, so. And it wasn't Aon 16 Re. I believe it was Aon Risk Services. I 17 worked there for one year and I was 18 recruited away by another firm known as John 19 F. Sullivan Company in Philadelphia, 20 Pennsylvania. 21 Q. Sorry, backing up. What did 22 you do at Aon Risk Services? 23 A. Reinsurance broker, same as 24 Thomas A. Greene before that. 25 Q. Allright. We're up to Jan 19, 2004 - CAM of Craig Ott Page 17 CONFIDENTIAL FNMA.MBW.004955 Case 1:05-cv-01463-JDB Document33-21 Filed 06/21/2007 Page é of 10 00018 1 CRAIG J. OTT 2 Sullivan. What did you do there? 3 A. Reinsurance broker. I worked 4 there until 1995. During that time I was a 5 reinsurance broker and worked on information 6 systems based reinsurance projects. I 7 worked at General Star in 1995. I worked 8 there for five years until 2000, 2000. 9 Q. Did you hold the same job 10 title or position during your entire tenure? 11 A. At which? 12 Q. At Gen Star. 13 A. At Gen Star. No, I was 14 promoted once while I was there. 15 Q. What was your initial hire-in 16 title? 17 A. Second vice president. I was 18 promoted to vice president. 19 Q. When was that promotion? 20 A. JY would say it was perhaps in 21 1997. 22 Q. Were you second vice 23 president, vice president of any particular 24 division? 25 A. Yes. Jan 19, 2004 - CAM of Craig Ott Page 18 CONFIDENTIAL FNMA.MBW.004956 Case 1:05-cv-01463-JDB Document 33-27 ried 06/21/2007 Page 9 of 10 00019 1 CRAIG J. OTT 2 Q. What division? 3 A. I was responsible for the 4 operation of the property division of 5 General Star. 6 Q. From 1997 up until the time 7 that you left Gen Star in 2000, who was your 8 supervisor? 9 A. Kevin Brooks. 10 Q. Was he your supervisor during 11 the entire time that you worked at Gen Star? 12 A. That's correct. 13 Q. So there was no level of 14 supervisor between you and Kevin Brooks? 15 A. No, sir. 16 Q. Who did you supervise? 17 A. Thad five branch offices, 18 Atlanta, Dallas, Chicago, New York and Los 19 Angeles. So I supervised the managers of 20 the property department in those five 21 offices. 22 Q. Allright. Who were they? 23 A. Atlanta was Cliff Groover. 24 Dallas was Jerry Miller. Los Angeles, 25 Michael Denton. New York, Robert Wenzel. Jan 19, 2004 - CAM of Craig Ott Page 19 CONFIDENTIAL FNMA.MBW.004957 Case 1:05-cv-01463-JDB Document 33-21 ried 06/21/2007 Page 10 of 10 00020 1 CRAIG J. OTT 2 And Chicago, Bruce Wise. And there was some 3 turnover during that time, but those were 4 the original contacts in those five offices. > Q. Describe for us your duties 6 and responsibilities on a typical, routine 7 daily or weekly basis during this time 8 period at Gen Star. 9 MS. BERGIN: Object to the 10 form. 11 A. My responsibility was to 12 manage the affairs of those, the individuals 13 in those departments regarding their 14 direction of production, their focus on 15 products, and of course the goal was to 16 generate an underwriting profit. 17 Q. How often did you meet with 18 Mr. Brooks? 19 A. There was no -- we had monthly 20 meetings. Other than that, there were no 21 set pattern -- there was no set pattern of 22 meetings, but I would say that we met 23 intermittently perhaps once every other 24 week. And we would have an annual meeting 25 as well as an annual planning meeting. Jan 19, 2004 - CAM of Craig Ott Page 20 CONFIDENTIAL FNMA.MBW.004958