l·lectronically Fikd 09/27/20l3 04:42:4 I PM liT

RECE[VED. W27/20l3 |(r41 42. Ilïom» l). 1h11. ( IcrL Suprcme Court

IN THE SUPRE'viE COUR'I OF Fl.OklDA

(Before a Referee )

II: I 1.URIDA BAR, Supreme Court Case

No. Sci ¼;3
( omplainant.

I he l·lorida Har f ile No.

2010-51,725(171); 2011-50,154(171);
2011-50,213i 171); 2011-50,216(171);
201 1-50,51 1(171); 201 1-50,695(171);
DAvin JAMliS STHRN, 20]l-S0,85U(171); 2011-50,949(171):
201 l-5l,l92(171); 20[1-51,322(171);
Respondent 2011-51.320( l71); 201 l-51,369(17I);
20 I [,5 I,433(l 71): 20 I l-51,497(17I);
20 I l -5 l,6%(l 71); 20 I l-51,868(17I);
201 2-50, l 44 1 1 71).

MOTION BV KENNETH ERIC TRENT, ESQUIRE FOR I.EAVE

TO GIVE TESTIMONY AT FINAL IIEARING AND
Al.TERNATIVE MOTION TO INTE.RVENE

Comes now K.enneth Eric Trent, a Member in good standing of The Florida

Bar, (hereinafter "Movant"), and moves the Court w permit him to testify at the

inal 1learing in the above-styled cause or, in the alternative, to grant him leave to

ntervene. tn support of such requests, Movant shows unto the Court as follows:

Factual Basis

Mm ant H led a g:·icVance against Respondent. D:n id hmes Stern, on or about

July 2& 2010. alleging ra:npant fraud by Respondent and emplo-,ees olhis firm inthe

cremion of tblse and traudulent assignments of mortgage used and intended to be

used to establish the elements of plaintiffs' cases in residential foreclosure suits

throughout Florida. After some additional correspondence and documentation,

Movant's grievance was ultimately given Fla. Bar Case No.2011-50,216(17I), as

reflected in bold print in the case style above.

In support of his grievance, Movant cited to one emblematic assignment of

mortgage filed by Respondent's subordinate (also an attorney), in the foreclosure case

of Citimortgage, Inc. v. Dennis Brown, et al., Broward Circuit Court case no. 08­

011097. Movant was counsel for the defendants in that case, and received the

manufactured "evidence" from Respondent's firm after multiple motions to compel

discovery. It is attached hereto as Exhibit A.

Ultimately, this matter was assigned to Bar Counsel Randi Lazarus, (hereinafter

"Bar Counsel"), and the undersigned provided information to her, including the

annotated version of the assignment (Exhibit B) and the deposition of Respondent's

employee and close associate Cheryl Samons which is attached hereto as Exhibit C.

The undersigned also deposed Ms. Samons and is the only one known to have

deposed Shannon Smith, another Stern employee involved in the wholesale

manufacturing of such documentary evidence.

As reflected in emails attached hereto as Exhibit D, Movant furnished materials

to Bar Counsel in response to her inquiries. As further reflected in Exhibit D, on June

19* of this year, Bar Counsel wrote to Movant and 6-8 other persons who had filed

grievances against Respondent, stating that the addressees (including Movant) would

be needed as live witnesses at the final hearing set to begin September 30*. The June

19* email, among other points, emphasized that, "It is my opinion that your live

appearance is important to the Bar's case."

Regrettably, on August 14*, Bar Counsel wrote to Movant and reversed her

stance as to the necessity of Movant's testimony in this proceeding. (Exhibit D). The

basis for this change was, apparently, an idea that Movant's testimony would be

duplicative. While Bar Counsel has every legal right to exercise her discretion in this

regard, Movant must disagree. Although some overlap is to be expected, Movant

submits that it is in the best interests ofjustice that he be heard.

Movant is uniquely positioned to testify about the use of the fraudulent and

fabricated document in the Brown case. Further, by virtue of having brought and

litigated a class action complaint against Respondent arising from and relating to the

Respondent's use of such assignments in foreclosure proceedings to simulate

evidence and thereby induce foreclosures to which the plaintiffs, represented by

Respondent, were not entitled, Movant can provide useful information about the

scope of the practice and the damages sustained by numerous persons who were

members of the proposed class..

3
 Further, Movant has observed that these litigation tactics are often utilized by

Respondent and his representatives, in different contexts, to confuse the issues and

subvert the process. Movant is not motivated to file this Motion or to testify by any

prospect ofdirect financial gain or personal benefit. Instead, Movant simply believes

that the judicial system of our state is sorely in need of a fair and just public outcome

in this cause: one that may well deter future like conduct of others motivated to

subvert the process and the rules of evidence for their own selfish ends, and with

complete disregard for the rights of others.

The Legal Basis

Movant acknowledges Rule 3-7.6(k), which provides as follows:

(k) Complaining Witness. The complaining witness is not a party to the

disciplinary proceeding, and shall have no rights other than those of any other
witness. However, unless it is found to be impractical due to unreasonable
delay or other good cause, and after the complaining witness has testified
during the case in chief, the referee may grant the complaining witness the
right to be present at any hearing when the respondent is also present. A
complaining witness may be called upon to testify and produce evidence as any
other witness. Neither unwillingness nor neglect ofthe complaining witness to
cooperate, nor settlement, compromise, or restitution will excuse failure to
complete any trial. The complaining witness shall have no right to appeal.

While Movant does not have a right to the relief herein sought, it would appear from

this Rule that the complaining witness is generally expected to testify at the final

hearing.

4
 While time simply does not permit any further discussion of these matters

within this document, Movant submits that the interests of integrity and justice

strongly support the granting of the relief herein sought.

Respectfully submitted this 26* day of September, 2013.

KENNETH ERIC TRENT

831 East Oakland Park Blvd.

Fort Lauderdale, FL 33334

(954)S67-5877; (954)567-5872 [fax]

[email protected]

By
Kenneth Eric Trent
Fla. Bar No. 693601

Certificate of Service

I certify that copies of the foregoing were served by electronic mail, after

business hours on September 26, 2013, upon the following: [email protected],

[email protected], [email protected], and [email protected].

By:
Kenneth Eric Trent
Fla. Bar No. 693601
Exhibit A

CFN # 108396942, OR BK 45974 Page B87, Page 1 of 1, Recorded 02/10/2009 at

03:10 PM, Broward County Commission, Deputy Clerk 3075

rmar onmmmaso
$a "o This space is for rccording purposes only
o uomcm)

ASS]GNMENT OF MORTGAGE

1 T A H E PR E S:

Residing or located nt c/o P.O. BOX 790014, ST, LOUIS, MO 63179 , herein designaicò ns the assignor, for and in
considerationofthesi oFSit ODojl d.other. lan u I consideratiopherecci ictris.hgrcb
acknowfed lhaj ,t covern ]T1È ÑÒ.)cèidt rlacoredat:
P.O. DOX Di,4 OUr 6 ignee, n!pfts c2 e ÓE 0, BROWN
and JOYCE M'B reco in B i. Flo bliÈ 3J02ÌF"elíd pog mbering e property
more panlcularly described as follows:

LOT6 BLOCKG OFOARLAND ESTATES NORTH,SECOND SECTIONACCORDINGTOTHE PLAT THEREOF AS

RECORDED IN PLAT BOOK 67, PAGE 26 OF TIIE PUBLIC RECORDS OF BROWA RD COUNTY, FLOR1DA,

together with the note und cuch und every other obligdion described in said mortgage and the money disc imd to become disc thereon

TO HAVE AND TO HOLD the same unto lhe said assignec, ils successors and assigns forever, but v.idioti recourse the
undersigned.

In H7tnm H7tcreof ute said Assignor bus hereunto set his hanßnfÑal or caused th prescnLS lo bc Signcd by il5 prope orporate
oMcersandiLScorpomic5cullobcherclonfIlXe hs ayofFebnmry,200 uicifectiveaso ay truary,2008.

Signed in the presence of MORTGAGE .LE . 1C REG1ST N SYSTEMS, lHC.

ATTEST: DY:
.. . PR]NTNAMF' .HERYL SAMONS
WITNES. TITLE3'. STANTSECRETARY

PrintNdme. B

W1TNESS

Prín1Nome: 7'm

STATE OF FLOR1DA
COUNTY OF BROWARD

PERSONALLY APPEARED BEFORE ME, the undersigned outhority in and for the aforcsoid county innd stwe, on 1his
the. _ day ofFebmary, 2009 within my jurisdiction, the within named CHERYL SAMONS who is personany known so me and
who (teknowledged to me that (s)he is ASSISTANT SECRETARY onti that for and on behalf of MORTGAGE ELECTRONIC
REGISTRATION SYSTEMS, INC. and as its act and deed (s)hc executed the above and foregaing in ments wiur , aving been
duly auchorizeti by MORTGAGE ELECTRONIC REGlSTRATION SYSTEMS, INC. to do so.

WlTNESS my hand and official seal in the Coimty and Sinic inst oforesaid 1hls Ê ay ofFehnmry. 00 ,

NOTARYPU C

Notsy Pul*c stats or now

SMnna,4 Smitri
Com¼den0D77ain
ErNru uusN20t?
Exhibit B

 p 96942
RECOgo e9esea7-aa7
BROW 10'0915no:22
p CLERK30 5COMMlSSION

mum a v o rraiuuso
This space is for recording purposes only
u-mmcuo

ASSIGNMENT OF MORTGAGE

KNOW ALL MEN BY THESE PRESENTS:

THA T MORTGAGE ELECTRONIC REG TION SYSTEMS, INC.

Residing or located at c/o P.O. BOX 790014, ST, LOU15, MO 6317 herein ated as the assignor, arid in
consideration of the sum of 51.00 Dollar and other good and valuable considerat' he receipt of which is hercb
acknowledged, oes hereby grant, bargal IL ussign, transfer and set over unt ITlMORTGAGE, INC. residing or located at:
P.O. BOX 7 0014, , 1 OUlS. MD 63 179 herein designated as the assignec, lhe mortgage executed by DENNIS O. BROWN
and JOYCE . ROWN rec in BR ARD County, Florida ut book 33026 and page 1152 encumbering the property
more srcicularlydescribcdas ws:

LOT 6 BLOCX G OF OAKLAND ESTATES NORTH, SECOND SECTION ACCORDING TO TitE PLAT THEREOF AS
RECORDED IN PLAT BOOK G7. PA GE 26 OF THE PUBLIC RECORDS OF BROWARl) COUNTY, FLORIDA.

together with the no and each and every other obligation described in said mortgage and the money due and to become due thercon

HAVE AND TO HOLD the same unto the said assignec, its successors and assigns forever, but wi4k recourse the
undersigned

In Witness Where the said Assignor has hereunca s his hanfanil'scal aused tb resents to be signed by its prope o
ffice co rate seal to be hereto affix thi ny of Febru 00 ut effect ye as o ' ay ofF ru , 2008,

Signed in the presence of: MORTGAGE :.LECT SYSTEMS, (NC.

ATTEST: BY: .
PRfNTN ERYLSAMONS
WITNES T EE: A. 'ANT SECRl!TARY

Print me. i .

WfTNESS·

Prini Name:

STATE OF FLOR)DA
COUNTY OF BROWARD
RSONALLY APPEAR.ED BEFORE ME, he undersigned authority in and for the aforesaid county and state, on this
the of February, 2009 within my jurisdic c within named CHERYL SAMONS who is personaHy known to me and
who acknowledged to me that (s)hc is ASSISTANT SECRETARY and that for and on behalf of MORT'' GE ELECTRON1C
REGISTRATION SYSTEMS, (NC. and as its act and deed (s)he executed the above and Ihregoin ' in ment atler : aving been
duly authorized by MORTGAGE ELECTRONIC REOISTRATION SYSTEMS, INC. to do so,

WfrNESS my and and official seul in the County and Stule last aforesaid this ay of Febr y, 00 .
7
NA NOTARY I C

No te og prog
. , Shannon Sm|tn
My Commission 0077a12<
Expka& o4/13/2012
 INDEX TO CONTENTS OF TYPICAL STERN

ASSIGNMENT OF MORTGAGE

A) "Prepared by DAVID J. STERN"

As stated in my complaint to The Bar, I have a summary of a depo of Cheryl

Samons in which she said she acts on the instructions of David Stern in signing

assignments.

1) "Residina or located at c/o PO. BOX 790014. ST. LOUIS. MO 63179"

Mortgage Electronic Registration Systems, Inc., ("MERS"), is not located in

Missouri. It is located in Virginia. (Samons depo, p. 28). This sentence is intentionally

crafted for maximum ambiguity. Examples are: (1) the use of "or," between "residing" and

"located at," and (2) the use of "c/o P.O. BOX . . ." It is impossible to reside or be located

at a P.O. Box. Even ifthis is construed generously as a mailing address, which by its express

terms it is not, there is no such mailing designation as "c/o P.O. Box." It is common

knowledge that "c/o" or "care of" is used to designate a person who will process mail on the

addressee's behalf.

2) "for and in consideration of the sum of Sl.00 Dollar and other good and valuable
consideration"

In fact, no consideration whatsoever changed hands. Cheryl Samons, who testified

that she is the person with the most knowledge about this Assignment, also testified that

she had no knowledge of any consideration. (Samons depo, p. 26)

Page 1 of 5
3) "the receipt of which is hereby acknowledged"

Samons denied that she "acknowledged receipt of that one dollar and other good and

valuable consideration" by signing the Assignment, and could not show me "where, on [the

Assignment] any person signed" to acknowledge it. (Samons depo, p. 26). When asked if

this was an error, she responded, "I have no idea." (27).

4) "does hereby arant. bargain. sell. assian. transfer and set over unto"

The Assignment did not actually reflect any transfer of interest, and is simply a

fabrication made for the purpose offoreclosure litigation. Further, MERS, even ifconsidered

legitimate, could only act in a nominee capacity, and does not, based upon the language of

the Assignment, do so here. Further, the only interest transferred, according to Samons, was

"to be able to foreclose the mortgage." (Samons depo, p. 30).

5) "CITIMORTGAGE. INC. residina or located at PO. BOX 790014. ST. LOUIS.

MO 63179

This may actually be a P.O. Box used by an affiliate of Citimortgage, Inc.

Nonetheless, ifthe Assignment actually described a normal, commercial transaction between

two separate and distinct business concerns, one would expect the two parties involved to

have different addresses. In this instance the purported addresses of the assignor and

assignee are identical, with the exception of the use of"c/o" immediately prior to the alleged

assignor's address as described in item number 1, above.

Page 2 of 5
6) "Together with the note"

There is no provision in any of the loan documents, and there is no provision in the

MERS charter, which would allow MERS to assign the note. The mortgage contains MERS

provisions which purport to allow MERS to take certain actions relating to the mortgage as

"nominee."

7) Please disregard.

8) "In Witness Whereof'

Samons testified that she did not attest to the contents of the Assignment by

signing it. (Depo, p. 39-40).

9) "caused these presents to be siened by its proper corporate officers"

Samons did not act on the instruction of anyone at MERS in executing the

Assignment. David J.Stern, not MERS, "caused" the document to be signed. She is also not

a "proper corporate officer" of MERS, but instead has been given the title "assistant

secretary," solely to create the appearance of authority.

10) "its corporate seal to be hereto affixed"

No corporate seal is affixed.

11) "this___day"

Date is missing.

Page 3 of 5
12) "but effective as of the 19* day of February. 2008"

Samons testified that she did not know whether the 19* day ofFebruary, 2008 had any

significance. (P. 39). She testified when questioned by Mr. Ice that these "effective dates"

are the dates the foreclosure case file was received in Stern's office. The purpose of these

"effective dates" is to give the plaintiff in the foreclosure standing as of the time the

complaint was filed, as is required by law to avoid dismissal.

13) Sianature of Samons

This signature is almost identical to that of the notary/witness, Shannon Smith.

14) Sienature of Smith.

This signature is almost identical to the signature of Samons. When confronted by the

fact that Smith's signature on other assignments differs greatly from this one, Smith filed an

affidavit and testified, and Samons testified, that Smith had simply, on her own, one day

decided to change her signature. This was perjury, and since Smith testified that Mr. Tew

(Stern's counsel) gave her the affidavit to sign, it is likely this testimony was designed or at

least approved by Stern. Samons and Smith were revealed to be lying by, among other things, that

fact that Samons testiSed she and Smith discussed the alleged change of signature "this week," (p.

52) and Smith denied ever discussing with Samons her alleged decision to change her signature.

15) "PERSONALLY APPEARED BEFORE ME"

Tammie Kapusta testified generally that such was not the case. As to this Assignment, it is

obvious that Samons did not personally appear before any notary at the time she executed it. In fact,

it appears that Samons notarized it herself using Smith's stamp and name.

Page 4 of 5
16) "after first havina been duly authorized by MORTGAGE ELECTRONIC REGISTRATION
SYSTEMS. lNC. to do so"

Samons did not receive authorization from anyone at MERS to sign this Assignment. (Depo,

p. 18). Even the document allegedly appointing certain employees of the Stern firm as MERS

assistant secretaries did not constitute "due authorization," as the MERS by-laws require approval

of such appointment by the MERS board of directors. Based upon all available documentation no

such approval took place.

17) Smith's sianature

Virtually identical to that of Samons.

By Kenneth Trent.

Page 5 of 5
Exhibit C

 51
1 . DIRECT EXAMINATION

2 BY MR. GOLANT:

3 Good afternoon, Miss Samons. My name is

Jeffrey Glont and I represent the defendants Colby

S Cole, Franciso Rivera, Melanie Westbrook, and Mark

6 Moynihan, who are defendants in four separate

7 pending foreclosure lawsuits. You've already been

8 sworn, we don't need to do that again.

9 Earlier Miss Drysdale discussed how the

10 deposition works and do you remember that?

11 A. Yes.

12 Q. And do you have any questions at this point?

13 A. No, sir.

. 14 . Q. Also, earlier when counsel asked you, you

15 mentioned you'd given your deposition several times

16 before?

17 A. Yes, sir.

18 Q. How many times?

19 A. I believe twice.

20 Q. Twice before today?

21 A. Yes, sir.

22 Q. And one of them was last week?

23 A. Yes, sir.

24 Q. And when was the other?

25 A. It was several years ago, I don't remember

Boss Certified Realtime Reporting

954.4 67. 68 67
 52
2 the exact year.

2 Q. Okay. And that was in connection with what

3 type of a matter?

4 A. It was an internal matter.

5 Q. You gave a deposition in an internal matter?

6 A. A work related internal matter, yes.

7 Q. What was it, a lawsuit?

8 A. It was a lawsuit.

9 Q. Okay. And who were the parties to the

10 lawsuit?

11 A. David Stern and the other parties.

12 Q. Who were they?

13 A. It wasn't related to foreclosure -­

14 Q. Who were the -­

15 A. -- it was an employment dispute.

16 Q. An employment dispute?

17 A. Yes, sir.

18 Q. So employees and the Law Firm of David Stern

19 were involved in litigation?

20 A. Yes, sir.

21 Q. And you gave a deposition in that matter?

22 A. Yes, I did.

23 Q. Do you know what court that was pending in?

24 A. I'm sorry, I don't recall.

25 Q. Okay. All right. Can you tell me what

Boss Certified Realtime Reporting

954.4 67.6867
 53
MERS -- is MERS an acronym?

2 A. Yes, sir.

3 Q. What's does that stand for?

A. Mortgage Electronic Registration Systems.

5 Q. And I know you spoke about this earlier, I

6 just wanted to explore it a little further. How would

7 you describe your relationship with MERS?

8 MR. LEICHTLING: Object to form.

9 THE WITNESS: Um, I would describe it as a

10 business relationship.

11 BY MR. GOLANT:

12 Q. Okay. And what type -- what is your role in

13 that relationship?

14 A. My role is. to sign documents on their behalf.

15 Q. On behalf of MERS?

16 . A. Yes, sir.

17 Q. Okay. What documents do you sign?

18 A. Assignments of mortgage.

19 Q. Anything else?

20 A. No, sir.

21 Q. How did you come to enter into your business

22 relationship with MERS?

23 A. I am not familiar with that information. It

24 wasn't negotiated with me.

25 Q. How did you find out that you had a business

Boss Certified Realtime Reporting

954.4 67. 6867
 54
1 relationship with MERS?

2 A. I was given these corporate resolutions for

t 3 signing authority.

Q. Okay. And who gave them to you?

5 A. Mr. Stern.

6 Q. David stern?

7 A. Yes.

8 Q. And did he tell you anything when he gave you

9 those documents.

10 A. He told me that I could sign assignments for

11 MERS.

12 Q. And he didn't tell you anything else?

13 A. No, sir.

14 . Q. Okay. What is a mortgage assignment?

15 A. It's a document that is -- that transfers the

16 ownership of the mortgage.

17 Q. And it transfers it between who?

18 A. The parties.

19 Q. What parties, which parties?

20 A. The assignor and the assignee.

21 Q. Okay. Does MERS own mortgages?

22 A. No.

23 Q. So how does MERS assign mortgages that it

24 doesn't own?

25 A. I'm not familiar with all of the intricacies

Boss Certified Realtime Reporting

954.4 67. 68 67
 55
1 of the relationship and -­ with MERS and the lenders.

2 Q. So are you saying you don't know the answer

3 to my question?

A. Yes.

S MR. LEICHTLING: Object to form. Asked and

6 answered.

7 BY MR. GOLANT:

8 Q. Unfortunately, I didn't bring copies, so I'll

9 have to pass this one around. But I'm going to show

10 you a document that I will mark as Defendant's, and

11 it's also Counter Claim Plaintiff, Francisco Rivera,

12 Exhibit Number 1 to this deposition. Actually, I'll

13 pass it that way and then you'll get it.

14 MR. LEICHTLING: Can -­ can you do -.and I

15 don't know whether you want to do all of yours

16 · sequential or what - but maybe letters or pick up

17 with her numbering, so we don't have two exhibit

18 l's?

19 I don't know if you thought about that yet,

20 as to what's the least confusing way to do it.

21 MR. GOLANT: I'll go alphabetical, how's

22 that.

23 MR. LEICHTLING: Yeah, and -­

24 MR. GOLANT: Strike that. We'll mark this as

25 Defendant, Francisco Rivera -­ Defendant, Counter

Boss Certified Realtime Reporting

954.4 67. 6867
 56
1 Claim Plaintiff, Francisco Rivera's Exhibit A to

2 the deposition, A as and in apple.

3 MR. LEICHTLING: That's yours; right?

MR. GOLANT: No. Actually, that's Jim's but

5 he's not here.

6 MR. LEICHTLING: Oh, okay.

7 MR. GOLANT: And that -- that defendant is -­

8 that Plaintiff and counter claim Defendant is

9 represented by Mr. James Spanolios who had to

10 excuse himself. He appeared telephonically.

11 BY MR. GOLANT:

12 Q. Do you recognize that document?

13 A. This specific assignment, no.

)
14 Q. Is that your signature?

15 A. Yes, it is.

16 Q. And are there names of other individuals on

17 that document?

18 A. Yes, there are.

19 Q. And·signatures of other individuals?

20 A. Yes, there are.

21 �042 Q. And who are they?

22 A. Cindy Witt.

23 Q. Do you know Cindy Witt?

24 A. Yes, I do.
25 Q. How do you know her?

Boss Certified Realtime Reporting

954.4 67. 68 67
 57
A. We work together.

. 2 Q. So she works at the Law Offices of David

3 Stern?

A. Yes, she does.

5 Q. Okay. Anybody else?

6 A. Maggie Lascari (phonetic.)

7 Q. Do you know Maggie Lascari?

8 A. Yes, I do.

9 Q. How do you know her?

10 A. She works here. And Terry Rice.

11 Q. And do you know Terry Rice?

12 A. Yes, I do.

13 Q. And how do you know Terry Rice?

14 A. She works here.

15 Q. Okay. Can I have that back, please?

16 A. Sure.

17 Q. Now, this document says that, "Mortgage

18 Electronic Registration Systems, residing or located

19 at care of Wells Fargo Bank NA, 3476 Stateview

20 Boulevard, Fort Mill, South Carolina herein designated

21 · as the assignor."

22 I just read to you what the document says, but

23 can you tell me which entity is the assignor there?

24 A. MERS.

25 Q. MERS is the assignor. And what's Wells Fa go

Boss Certified Realtime Reporting

954.4 67. 68 67
 58
1 Bank's relationship to this mortgage?

2 A. They service the loan.

3 Q. Does Wells Fargo Bank own it?

A. No.

5 Q. Did Wells Fargo Bank ever own it?

6 A. I do not have that information.

7 Q. Okay. "For and in consideration of the sum \

8 of $1 and other good and valuable consideration, the

9 receipt of which is hereby acknowledged."

10 . . Who's acknowledging the receipt of consideration?

11 1 A. I don't know.

12 Q. But you signed it?

13 A. I did.

14 Q. Is it you?

15 A. No.

16 Q. Are you aware of any exchange of

17 consideration?

18 A. No.

19 Q. "Does hereby grant, bargain, sell, assign,

20 transfer and set over unto DLJ Mortgage Capital,

21 residing at care of America's Servicing Company, 347

22 Stateview Boulevard, Fort Mill, South Carlina."

23 That appears to be the same address, is it?

24 A. Yes, it is.

25 Q. Can you tell me why that is?

Boss Certified Realtime Reporting

954 . 4 67 . 6867
 59
1 A. On this particular case, I cannot tell you.

2 I don't have the file.

3 Q. Okay. Do you know the company DLJ Mortgage

Capital?

S A. I do know the name, yes.

6 Q. Okay. How do you know that?

7 A. They are in a lot of the foreclosure cases.

8 Q. And what is their role?

9 A. Um, plaintiff.

10 Q. So they serve as a foreclosure plaintiff.

11 A. They serve as foreclosure plaintiff, yes.

12 Q. Do they share office space with Wells Fargo?

13 A. I'm not sure.

14 Q. And now, it's your understanding correct,

15 that your signature on this document is for purposes

16 of transferring the mortgage from MERS to DLJ; is that

17 correct?

18 MR. LEICHTLING: Object to form.

19 MR. TEW: Same objection.

20 THE WITNESS,: Yes.

21 BY MR. GOLANT:

22 Q. But MERS doesn't own it; is that correct?

23 MR. LEICHTLING: Object to the form.

24 MR. TEW: Same objection.

2S THE WITNESS: I don't know.

Boss Certified Realtime Reporting

954.4 67. 68 67
 60

2 \ BY MR. GOLANT:

3 Q. Why did you sign the document?

4 A. Because I was instructed to sign the

5 document.

6 Q. Who instructed you to sign the document?

7 A. My bosses.

8 Q. Your bosses?

9 A. Uh-huh.

10 Q. Who was that?

11 A. David Stern.

12 ! Did David Stern tell you to sign this

13 document?

14 A. David Stern instructed me that I have signing

15 authority on behalf of MERS. And the files that are

16 given to me with assignments from MERS, on behalf of

17 the clients that we represent, I am to sign.

18 Q. Okay. Who gives you assignments?

19 A. Processors.

20 Q. How many processors are there?

21 A. A few hundred.

22 Q. There's a few hundred processors that give

23 you assignments?

24 A. Uh-huh.

25 Q. And your instructions are to sign them all?

Boss Certified Realtime Reporting

954.4 67. 68 67
 61
1 MR. LEICHTLING: Object to the form.

2 THE WITNESS: My instructions are to sign the

3 assignments of mortgage that are given to me from

4 MERS on behalf of our clients that we service.

5 BY MR. GOLANT:

6 Q. Who was your client in the case relating to

7 this assignment?

8 A. Wells Fargo.

9 Q. Wells Fargo. Do you sign every assignment

10 that you're given?

11 MR. LEICHTLING: Object to form. Asked and

12 answered twice.

13 THE WITNESS: If the assignment has the

14 information that I review, yes I do.

15 BY MR. GOLANT:

16 Q. And what information do you look for?

17 A. I look at the names, I make sure that I have

18 signing authority on behalf of the entity that I'm

19 signing for, and I sign the assignment.

20 Q. What names do you look for?

21 A. The borrower names on the mortgage.

22 MS. GLICK: I thought we weren't going to

23 be -­
24 THE WITNESS: Yeah, we -­

25 MS. GLICK: -­ repeating questions. I

Boss Certified Realtime Reporting

954.4 67. 6867
 62
1 thought that was the whole purpose of doing it the

2 way we were doing it.

3 MR. GOLANT: Well, just let me do my

4 examination ln sequence without interrupting,

S please.

6 MS. GLICK: Then I'm going to ask Lynn to

7 step outside, because she has nothing to do with

8 this because you're repeating, and it defeats the

9 whole purpose -­

10 MR. GOLANT: If you -­

11 MS. GLICK: -­ and she's not part of this

12 case.

13 MR. LEICHTLING: ·I have the same objection.

14 .. I mean, let's -­ I understand that you want to -­

15 MR. GOLANT: Do you want to take it up with

16 the judge, and then come back another day?

17 MR. LEICHTLING: On whether you can ask

18 questions that were already asked, by the counsel

19 �042 that we agreed that could ask questions for you

20 earlier in the deposition, and whether you can

21 . ' continually ask the same questions over and over?

22 MR. GOLANT: Well, I'm -­

23 MR. LEICHTLING: I'm okay with you asking a

24 few preliminary questions, but when you get to the

25 point where you're just going to repeat the same

Boss Certified Realtime Reporting

954.4 67. 68 67
 63
1 line of questions that we asked earlier in the

2 deposition, we object. And it's contrary to what

3 we'd agreed to at the beginning of the deposition.

4 MR. GOLANT: Well, why don't you have a

5 standing objection, so that -­

6 MR. LEICHTLING: I don'·t want a standing

7 objection.

8 MR. GOLANT: Well, are you going to tell her

9 not to answer?

10 MR. LEICHTLING: I'm -­ I'm going to request

11 that you not repeat questions that we all agreed

12 you weren't going to repeat, including you agreed

13 that you weren't going to repeat, that's what I'm

14 going to ask you to do.

15 MR. GOLANT: I'm not -­ I don't think I'm

16 repeating anything, and I'd just thank you to not

17 interfere with my examination.

18 MR. LEICHTLING: ·1'm not interfering.

19 MR. GOLANT: Okay. Could you read the last

20 question back, please.

21 I simply want to make sure I understand

22 clearly. Is it your testimony that if the

23 borrower's name matched and the assignor was MERS,

24 that was it your understanding that you were

25 instructed to execute an assignment of mortgage?

Boss Certified Realtime Reporting

954.4 67. 6867
 L

1 MR. LEICHTLING: Object to form.

2 THE WITNESS: If the assignor was MERS on

3 behalf of a client that I had a corporate

resolution for, then I would sign the assignment.

S I don't do any of the other review, that is not my

6 responsibility.

7 BY MR. GOLANT:

8 Q. A client that you had a corporate resolution

9. for?

10 A. Yes. Wells Fargo, GMAC, Litton, all of the

11 clients that -­

12 Q. So did you sign this document, Exhibit A, did

13 you sign that on behalf of Wells Fargo, or did you

14 sign that on behalf of MERS?

15 MR. LEICHTLING: Asked and answered.

16 MS. GLICK: You can answer.

17 THE WITNESS: I signed it on behalf of MERS,

18 but my signing authority is for Wells Fargo.

19 BY MR. GOLANT:

20 Q. You have signing authority for Wells Fargo?

21 · A. And I have signing authority for MERS, for -­

22 MERS is a nominee for certain servicers as I

23 understand it. If you read these, they say MERS for

24 Litton, MERS for GMAC, MERS for Wells Fargo; that's

25 what I sign.

Boss Certified Realtime Reporting

954.4 67. 68 67
 65
1 Q. So your authority to s1gn comes from MERS, or

2 it comes from Wells Fargo, in the case of Exhibit A?

3 A. These were given to me by MERS on behalf of

4 certain servicers that MERS has -­ whatever

5 partnership or relationship with it they have, but

6 it's not a blanket MERS anybody, anybody who's

7 servicing their loans. It's MERS, and then whoever's

8 servicing their loans. That's why we have separate

9 corporate resolutions.

10 Q, Okay. What was it your understanding of the

11 assignment of mortgage that's Exhibit A in this

12 deposition, what was that going to be used for?

13 A. It was going to be used for whatever purpose

14 was needed in the foreclosure.

15 Q. And what purpose is that?

16 A. I don't know.

17 --' MR. GOLANT: Mark that one A, please.

18 (Defendant's Exhibit A was marked for

19 identification.)

20 BY MR. GOLANT:

21 Q. And I'm going to show you another document

22 that we will mark as Exhibit B to the deposition on

23 behalf of the defendant, and this is Defendant

24 Counter Claim Plaintiff, Colby Cole.

25 (Defendant's Exhibit B was marked for

Boss Certified Realtime Reporting

954.4 67. 6867
 66
1 identification.1

2 BY MR. GOLANT:

3 Q. Do you recognize that document?

t
A, This specific document, no.

5 Q. Is that your signature?

6 A. Yes, it is.

Q. Do you recognize the other signatures?

8 A. Yes. They are the same exact signatures as

9 on the other assignment.

10 Q. Okay. Can I have that back, please?

11 And when you executed this document, who did you

12 execute it on behalf of.?

1 13 A. I'd have to look at the copy, I don't

14 remember. This was MERS, and the loan was being

15 serviced by Homecomings Financial,

16 Q. And you're signature is as a representative

17 of who?

18 A. MERS.

19 Q. Okay.

20 MR. LEICHTLING: Just so the record is clear,

21 we only have one copy of it, and the witness and

22 the counsel are passing it back and forth, that's

23 why there's -- I think that explains her last

24 answer, as to why she needed to see it before she

25 can answer the question. Go ahead.

Boss Certified Realtime Reporting

954.4 67.6867
 67
1

2 BY MR. GOLANT:

3 Q. And this document's dated the 19th day of

August. And it says on it, "but effective as of the

5 28th day of February, 2008," why is that?

6 A. There was a business decision made to add

7 that language in, I -- that I'm -- I don't know what

8 it was.

9 Q. Who made that decision?

10 A. It wasn't me; I don't know.

11 Q. How was that decision communicated to you?

12 A. I was just told that the assignment was being

13 changed -­

14 . Q. Who told you that?

15 A. --·format.

16 Q. Who told you that?

17 A. David stern.

18 Q. And when was that?

19 A. I don't recall.

20 Q. And what was it your understanding that this

21 document would be used for?

22 A. The same as any other assignment, whatever

23 purpose necessary to proceed with the foreclosure.

24 Q. And do you specifically know what those

25 purposes are?

Boss Certified Realtime Reporting

954. 4 67.6867
 ||

68
1 A. No.
2 MR. GOLANT: I can use that as Exhibit B.

3 BY MR. GOLANT:

4 Q. And now I will show you a document that we'll

5 mark as Exhibit C, to defendant Melanie Faye

6 Westbook's deposition.

7 (Defendant's Exhibit C was marked for

8 identification.)

9 MR. LEICHTLING: I'm sorry. You want to mark

10 this as Exhibit C -­

11 MR. GOLANT: C.

12 MR. LEICHTLING: -­ to somebody else's

13 deposition?

14 MR. GOLANT: That's right. Each document

15 corresponds to -­ there's one assignment -­

16 MR..LEICHTLING: Okay. I'm sorry that's -­

17 MR. GOLANT: -­ for each plaintiff -­

18 MR. LEICHTLING: -­ that's your -­ that's

19 your -­

20 MR. GOLANT: -­ each defendant -­

21 MR. LEICHTLING: -­ that's your other

22 borrower.

23 MR. GOLANT: That's one of my other

24 borrowers. Yes, sir.

2S MR. LEICHTLING: I just didn't know who that

Boss Certified Realtime Reporting

954.4 67. 6867
 69
1 person was.

2 MR. GOLANT: Gotcha.

3 MR. LEICHTLING: I wasn't sure if you were

talking about a different testifying witness and

5 you stated something.

6 MR. GOLANT: No.

7 MR. LEICHTLING: I understand what you mean

8 now.

9 BY MR. GOLANT:

10 Q. Do you recognize that document?

11 A. No, sir.

12 Q. Is that your signature?

13 A. Yes, it is.

14 Q. And do you recognize the other signature?

15 A. Yes, I do.

16 Q. And who are they?

17 A. Elisa Dubreucki Terece Bland, and Terece

18 Bland.

19 Q. Okay. And do you know those people?

20 A. Yes, I do.

21 Q. And how do you know Elisa Dubreuck?

22 A. She works here.

23 Q. And the other person Ter- -­

24 A. Terece.

25 Q. Terece Brand (sic)?

Boss Certified Realtime Reporting

954.4 67.6867
 70
A. She also works here.

2 Q, Okay. Can I have that back?

3 A. Sure.

4 Q. And like Exhibit A, this document was

5 executed -­ was an assignment from "Wells Fargo Bank

6 residing at 3476 Stateview Boulevard, Fort Mill, South

7 Carolina, for and in consideration of the sum of $1,

8 and other good and valuable consideration, the receipt

9 is hereby acknowledged, does hereby grant, bargain,

10 sell, assign, transfer and set over unto The Bank of

11 New York, As Trustee for BS Alt A 2005-7, residing at

12 or care of Americais Servicing Company, 3476 Stateview

13 Boulevard, Fort Mill, South Carolina."

14 Again, Wells Fargo and America's Servicing

15 Company and MERS appearing at the same address on

16 Statesville (sic) Boulevard.

17 MS. GLICK: Object to form.

18 BY MR. GOLANT:

19 Q. Do you know if America's Servicing Company

20 shares office space with Wells Fargo Bank?

21 A. I don't know.

22 Q. Okay. And who did you execute this document

23 on behalf of?

24 A. MERS.

25 Q. Okay. And do you have any knowledge of any

Boss Certified Realtime Reporting

954.4 67. 68 67
 71
1 exchange in consideration between MERS and any of the

2 parties to this assignment?

3 A. No.
4 Q. Okay. And did MERS own this loan?

5 A. No.

6 Q. Okay.

7 MR. LEICHTLING: Can I see that document just

8 to write down the name of your client?

9 MR. GOLANT: Sure.

10 BY MR. GOLANT:

11 Q. And the last document, which I'll mark as

12 Exhibit D on behalf of the defendant, Mark Moynihan.

13 I'll pass that around.

14 (Defendant's Exhibit D was marked for

15 identification.)

16 BY MR. GOLANT:

17 Q. And who did you execute this one on behalf

18 of?

19 A. MERS.

20 Q. Okay. And do you have any knowledge of any

21 exchange of consideration relating to this

22 transaction?

23 A. No.

24 Q. And who was the Law Offices of David Stern's

25 client in this transaction?

Boss Certified Realtime Reporting.

954.4 67. 68 67
 72
A. Homecomings.

2 Q. And this document was effective as to a date

3 prior to it's execution, was that pursuant to the same

4 policy you described in connection with my previous

S question relating to Exhibit B?

6 A. Yes.

7 Q. Now, we've discussed the term signing

8 authority a lot, what is signing authority?

9 �042 MR. LEICHTLING: Object to the form.

10 THE WITNESS: An authority to sign a

11 document.

12 BY MR. GOLANT:

13 Q. Anything else?

14 �042 A. Not to my knowledge.

15 Q. Does that include the authority to transfer

16 assets?

17 A. I - I am not equipped to answer that

18 question. I have no idea.

19 Q. Does that include the authority to incur

20 · liabilities?

21 MR. LEICHTLING: Object to form.

22 THE WITNESS: Incur liabilities?

23 BY MR. GOLANT:

24 Q. Okay -­
25 A. I'm -- I'm just a signer, that's it. I'm a

Boss Certified Realtime Reporting

954.4 67.6867
 73
1 signer. I don't make legal determinations about what

2 it encompasses. I sign documents, that's it.

3 Q. Do you sell property that belong to MERS?

A. I don't sell properties no, sir.

5 Q. Okay. Do you give MERS' property to other

6 people or entities?

7 A.. I sign documents that transfer -- however

8 those are used, are however those are used. I don't

9 make a legal determination how that gets used.

10 Q. And you don't have any decision over the

11 documents that you sign; is that correct?

12 A. I do not.

13 MR. GOLANT: I have no further questions.

14 THE WITNESS: Okay.

15 MS. GLICK: I have no questions.

16 MR. TEW: Nothing.

17 ' MR. LEICHTLING: Nor do I.

18 MR. TEW: Do you want to waive?

19 MS. GLICK: We'll waive.

20 (Thereupon, the deposition was concluded at

21 4:10 p.m., and the reading and signing were

22 waived.)

23

24

25

Boss Certified Realtime Reporting

954.4 67.6867
 CERTIFICATE OF OATH

3 STATE OF FLORIDA )

4 SS:

5 COUNTY OF BROWARD )

8 I, AMY LYON, Florida Professional

9 Reporter, Notary Public, State of Florida, certify that

10 CHERYL SAMONS personally appeared before me on June 3,
11 2009, and was duly sworn.
12

13 Signed this 3rd day of June, 2009.

14

15

1176

AMY LYON, FPR and

18 Notary Public, State of Florida

My Commission No: DD 805442

19 Expires: July 13, 2012

20

21

22

23

24

25

Boss Certified Realtime Reporting

954.467.6867

 75
1 CERTIFICATE OF REPORTER

3 STATE OF FLORIDA )

SS:

5 COUNTY OF BROWARD )

7 I, AMY LYON, Florida Professional

8 Reporter, do hereby certify that I was authorized to

9 and did stenographically report the deposition of

10 CHERYL SAMONS, that the review of the transcript was

11 not requested; and that the foregoing transcript, pages

12 1 through 75, is a true record of my stenographic

13 notes .

15 I FORTHER CERTIFY that I am not a

16 relative, employee, or attorney, or counsel of any of

17 the parties, nor am I a relative or employee of any of

18 the parties' attorney or counsel connected with the

19 action, nor am I financially interested in the action.

20

21 DATED this 15th of June, 2009, at

22 Broward County, Florida.

AMY LYON, FPR

25

Boss Certified Realtime Reporting

954. 467. 6867
Exhibit D

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Answer
FOLDERS and
Defenses
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2008
2009 Emails (123)
Good Morning,
2010 (21)
As you know, a Complaint was filed in the above in
2011-2012 Emails (999+) the Florida Supreme Court. An answer and
2013 Emails (8) affirmative defenses was filed and is below. On May
1, 2013, the Honorable Nancy Perez, a Palm Beach
3-13 Legal Assistant County Judge, was appointed as referee to preside
ADF (37) over this matter. The trial has been set to begin on
September 30, 2013 and conclude on October 11,
Alexis Audits
2013, and will most likely be held in the Broward
balkaran County Courthouse. It is my intention to present each
bbb adf
of you as a witness in my case.
Brad Davis (6) Please let me know if you have any conflict which
would interfere in your ability to serve as a live
Bradley J. Davis
witness in this proceeding between September 30,
Caridad 2013 and October 11, 2013. It is my opinion that
chinloy (35) your live appearance is import'ant to theBar's case.
TTe'Fa7s^office will coordinate with you for your
Citimortgage travel, hotel and all costs associated, all of which will
Class Action MERS be paid for by the Bar.

Deleted Items Additionally, Mr. Stern's counsel, Jeffrey Tew, may

seek to take your deposition, prior to your
ebanks
appearance at trial.
Employee
E..service addresses Please do not hesitate to contact me about the above
or with any other questions that you may have. My
Florida Bar extension number is 4144.
foreclosure class action... Your cooperation is greatly appreciated .
FRIDKIN
Thank you.
Heritage Web
Ichiban
Idaboy vs Atlantic
Insurance Randi Klayman Lazarus
Senior Bar Counsel
Julian The Florida Bar
Junk Lakeshore Plaza 11, Suite 130

1300 Concord Terrace

Jutz Sunrise, FL 33323

Keeler 954-835-0233
954-835-0133 fax
Lombardozzi [email protected]
Maggie Sherman
meer
mers friends

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Hi Ken,
I have been reviewing my proof and witnesses and
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have been working on streamlining the process. At
this point, I have determined that I will not be
FOLDERS
presenting you as a witness since allegations
1 Filing Receipts (73) contained in your complaint can be established
through another witness that will be testifying about
2008
items that only she can attest to. I do not want to
2009 Emails (123)
duphcate and prolong. I am sure you can understand.
2010 (21)
If, however, I change my mind, I hope that I can count
2011-2012 Emails (999+)
on you.
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Thank you for your assistance.
3-13 Legal Assistant

Randi Klayman Lazarus

ADF (37) Senior Bar Counsel

Alexis Audits The Florida Bar

Lakeshore Plaza 11. Suite 130

balkaran
1300 Concord Terrace

bbb adf Sunrise, FL 33323

Brad Davis (6) 954-835-0233
954~835-0133 fax
Bradley J. Davis [email protected]
Please note: Florida has very broad public records laws. Many written
Caridad communications to or from The Florida Bar regarding Bar business may
chinloy (35) be considered public records, which must be made available to anyone
upon request. Your e-mail communications may therefore be subjeci lo
Citimortgage public disclosure.
Class Action MERS
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1 Filing Receipts (73) Sent: June 19, 2013 10:52 AM

2008
To: tom.ice@icelegal,com, phanç[email protected],
trentlawoffice@yahoo,com, andersD2@!ive.com,
2009 Emails (123) mike@ricardo!awgom [email protected],
2010 (21) [email protected], [email protected].çom.
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Subject: The Florida Bar v. David Stern

2013 Emails (8)

3-13 Legal Assistant Good Morning.

ADF (37) As you know, a Complaint was filed in the above in the

Florida Supreme Court. An answer and affirmative

Alexis Audits
defenses was filed and is below. On May 1. 2013. the
balkaran Honorable Nancy Perez, a Palm Beach Couniy Judge, was
appointed as referee to preside over this matter. The trial
bbb adf has been set to begin on September 30, 2013 and
Brad Davis (6) conclude on October 11. 2013. and will most likely be held
in the Broward County Courthouse. JI is my intention to
Bradley J. Davis present each of you as a witness in my case.
Caridad Please let me know if you have any conflict which would
chinloy (35) interfere in your ability to serve as a hve witness in this
proceeding between September 30, 2013 and October 11,
Citimortgage 2013. 11is my opinion that your live appearance is
Class Action MERS important to the Bar's case. The Bar's office will coordinate
with you for your travel, hotel and all costs associated, all
Deleted items of which will be paid for by the Bar.
ebanks Additionally, Mr. Stern's counsel, Jeffrey Tew, may seek to
Employee take your deposition, prior to your appearance at trial
E-service addresses Please do not hesitate to contact me about the above or
with any other questions that you may have. My extension
Florida Bar
number is 4144.
foreclosure class action...
Your cooperation is greatly appreciated .
FRIDKIN
Heritage Web Thank you.

Ichiban
Idaboy vs Atlantic
insurance Randi Klayman Lazarus
Senior Bar Counsel
Julian The Florida Bar
Junk Lakeshore Plaza 11, Suite 130
1300 Concord Terrace
Jutz Sunrise, FL 33323
954-835-0233
Keeler 954-835-0133 fax
Lombardozzi [[email protected]
Maggie Sherman
meen
mers friends

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Dear Mr. Trent:

2010 (21)

Please see attached letter and Complaint filed with

2011-2012 Emails (999+)
the Supreme Court of Florida.
2013 Emails (8)

Letter to Complainant w/copy of Complaint

3-13 Legal Assistant
04/19/2013
ADF (37)
Alexis Audits Formal Complaint 04/17/2013
balkaran
bbb adf
Brad Davis (6) Maria Casco
Assistant to Adria E. Quintela,
Bradley J. Davis Randi Klayman Lazarus and Sheila Marie Tuma
Caridad The Florida Bar
Lawyer Regulation, Fort Lauderdale Office
chinloy (35) ph: 954-835-0233, ext 4149
Citimortgage fx: 954-835-0133
[email protected]
Class Action MERS
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Dear Ms. Lazarus:
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Trash I am in receipt of your letter of January 29th advising of the
committee's probable cause finding. Thank you very
FOLDERS much! The fact that i heard nothing for such an extended
period was disconcerting. and I amgreatly relieved that
1 Filing Receipts (73) you have moved the case forward,
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Of course it will be my pleasure to assist you in any way
2009 Emails (123) possible.
2010 (21) I anticipate that the Respondent will seek to arrange a
2011-2012 Emails (999+) consent judgment containing minimized findings and
admissions, as did Marshall Watson. I have some
2013 Emails (8) information and concems, on behalf of the public, which I
3-13 Legal Assistant would like to discuss with you regarding the terms of any
such consent judgment. I would appreciate the opportunity
ADF (37) to speak with you regarding these matters whenever it is
convenient. My office number is 954-567-S877 and my cell
Alexis Audits phone number (phone not working today, but soon
balkaran repaired) is 954-663-1424.
bbb adf Thanks again for your conscientious efforts in seeking to
Brad Davis (6)
uphoid the standards of our profession!

Bradley J. Davis Warmest professional regards,

Caridad

chinloy (35)

GRenneth GLnc Crent

Citimortgage
Kenneth Eric Trent. P.A
Class Action MERS 831 East Oakland Park Boulevard
Fort Lauderdale. Florida 33334
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FRIDKIN
Heritage Web
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Insurance
Julian
Junk
Jutz
Keeler
Lombardozzi
Maggie Sherman
meen
mers friends

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azarus
1NBOX coNTAcTS CALENDAR james beekma... RE: BAC v. Sal... The Florida Ba... David James S...

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Re: Davi... Feb 8

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Sent
1 Attachment 710.1K8
Spam (131)
PDF 710KB
Trash

samons a
FOLDERS
drysdale.p
1 Filing Receipts (73)
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2008

2009 Emails (123)

Got part of it! Hopefully more to come.
2010 (21)

Sincerely,
2011-2012 Emails (999+)

2013 Emails (8)

GKenneth �522ric
Crent
3-13 Legal Assistant

Kenneth Eric Trent. PA.

ADF (37)
831 East Oakland Park Boulevard
Fort Lauderdale. Florida 33334
Alexis Audits
(954) S67-S877
balkaran
(954) 567-S872 fax

bbb adf

--- On Thu, 2/7/13, Randi Lazarus <[email protected]>

Brad Davis (6)
wrote:
Bradley J. Davis
Caridad From: Randi Lazarus <[email protected]>

Subject: Re: David James Stern, file no. 2011-50.216(171)

chinloy (35) To: [email protected]

Citimortgage Cc: "Maria Casco" <[email protected]>

Date: Thursday, February 7. 2013, 10:23 AM

Class Action MERS

Deleted Items I also have a June 29, 2009 deposition of Cheryl

Samons Deutsche Bank v. Dixorj, et al. Sorry for the

ebanks multiple e-mails.

Employee Thank you.

E-service addresses Randi Klayman Lazarus

Florida Bar Bar Counsel

The Florida Bar

foreclosure class action... Lakeshore Plaza ll, Suite 130

FRIDKIN 1300 Concord Terrace

Sunrise, FL 33323

Heritage Web 954-835-0233

ichiban 954..835-0133 fax

rlazarus@flabar,org

Idaboy vs Atlantic
Insurance
Julian From: [email protected]

To: "Randi Lazarus" <[email protected]>

Junk
Date: 02/06/2013 o8:01 PM

Jutz Subject: Re David James Stern. He no. 2011-50,216(171)

Keeler
Lombardozzi
Maggie Sherman LookS like I have to go thru the reALLy big
meer box. Should have it to u by tomorrow.
mers friends
Meanwhile, do u have the depo of Samons
taken after the mass lavoffs at his firm7

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...aZarus
INBOX cONTACTS CALENDAR james beekman atto,,, SEARcH: lazarus RE: BAC v. Salecki, ... The Florida Bar v. D...

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inbox (391)

Re: Davi... Feb 1

Drafts (112)

Sent

Bear with me while I track that down.

Spam (131)

Sent via BlackBerry by AT&T

Trash

From: Randi Lazarus <[email protected]>

FOLDERs Date: Wed, 6 Feb 2013 13:14:38 -0500
To: Kenneth Eric Trent, PA<[email protected]>
1 Filing Receipts (73) Cc: Maria Casco<[email protected]>
2008 Subject: Re: David James Stern, file no. 2011-50,216(171)
2009 Emails (123) Good afternoon Mr. Trent,
2010 (21)
I was reviewing your grievance to The Florida Bar
2011-2012 Emails (999+) dated August 5, 2010. In it you state:
2013 Emails (8)
If there is any doubt as to Mr.
3-13 Legal Assistant
Stern's responsibility for these acts,
ADF (37)
consider this: I recently received from
Alexis Audits
another attorney a summary of a
balkaran deposition in which Ms. Samons
bbb adf indicated that
Brad Davis (6) she acts on the specific instructions of
Bradley J. Davis Mr. Stern in signing the assignments
Caridad
Can you please identify the deposition to which you
chinloy (35) refer.
Citimortgage
Thank you.
Class Action MERS
Deleted Items Randi Klayman Lazarus
Bar Counsel
ebanks The Florida Bar
Employee Lakeshore Plaza ll, Suite 130
1300 Concord Terrace
E-service addresses Sunrise, FL 33323
Florida Bar 954-835-0233
954-835-0133 fax
foreclosure class action... [email protected]
FRIDKIN
Heritage Web
ichiban
Idaboy vs Atlantic
Insurance
Julian
Junk
Jutz
Keeler
Lombardozzi
Maggie Sherman
meen
mers friends

of 1 9/26/2013 8:14 PM
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azarus
INBOX CONTACTS CALENDAR james beekma... SEARCH: lazar... RE: BAc v. SaL. The Florida Ba...

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inbox (391)

Re: Davi... Feb 1

Drafts (112)

Sent

Spam (131)
Looks like i have to go thru the reALLy big box. Should

have it to u by tomorrow. Meanwhile, do u have the depo of

Trash
Samons taken after the mass layoffs at his firm? Therein

she attributes her training and the design of the standard

FOLDERs practices to Stern.

Sent via BlackBerry by AT&T

1 Filing Receipts (73)

2008 From: Randi Lazarus <[email protected]>

Date: Wed, 6 Fe6 2013 13:33:34 -0500

2009 Emails (123) To: <[email protected]>

Subject: Re: David James Stem, file no. 2011..50.216(171)

2010 (21)
2011-2012 Emails (999+) Thank you.
2013 Emails (8)
Randi Klayman Lazarus

3-13 Legal Assistant Bar Counsel

ADF (37) The Florida Bar

Lakeshore Plaza ll, Suite 130

Alexis Audits 1300 Concord Terrace

balkaran Sunrise, FL 33323

954-835-0233

bbb adf 954-835-0133 fax

Brad Davis (6) [email protected]

Bradley J. Davis
Caridad From: [email protected]

chinloy (35) To: "Randi Lazarus"<[email protected]>

Date: 02/06/2013 o1.28 PM

Citimortgage subject Re: David James stem, file no. 2011-50,216(171)

Class Action MERS

Deleted Items
ebanks Bear with me while i track that down.

Employee Sent via BlackBerry by AT&T

E-service addresses
Florida Bar From: Randi Lazarus

foreclosure class action... <[email protected]>

FR1DKIN Date: Wed, 6 Feb 2013 13:14:38 -0500

To: Kenneth Eric Trent,

Heritage Web
P.A.<[email protected]>

Ichiban Cc: Maria Casco<[email protected]>

Idaboy vs Atlantic Subject: Re: David James Stern, file no.

Insurance 2011-50,216(171)

Julian Good aftemoon Mr. Trent,

Junk
Jutz I was reviewing your grievance to The Florida Bar
dated August 5, 2010. In it you state:
Keeler
Lombardozzi If there is any doubt as to Mr.
Maggie Sherman Stern's responsibility for these acts,
meert consider this: I recently received from
mers friends another attorney a summary of a

l of 1 9/26/2013 8: 15 PM
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azarus
INBOX CONTACTS cALENDAR james beekm... sEARCH: laz... RE: BAc v. S... The Florida ... David James . .

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Inbox (391)
Re: Davi... Feb 2
Drafts (112)
Sent 1 Attachment t6MB Slideshow
Spam (131)
Trash
FOLDERS

1 Filing Receipts (73)

Save
2008
2009 Emails (123) That one could be it. Who is the deposing atty? Don't
2010 (21) apologize. Please excuse ME for not locating that depo
outline immediately. I remember it, but it was a smaller
2011-2012 Emails (999+) document that ultimately had no relevance to the civil
2013 Emails (8) issues I was litigating. Must be buried somewhere in this
box (photo attached) or one of the other three like it. I'm
3-13 Legal Assistant determined to find it!
Sent via BlackBerry by AT&T
ADF (37)
Alexis Audits From: Randi Lazarus <[email protected]>
Date: Thu, 7 Feb 2013 10:23:00 -0500
balkaran To: <[email protected]>
Cc: Maria Casco<[email protected]>
bbb adf Subject: Re: David James Stern, r11e no. 2011-50.216(171)
Brad Davis (6)
I also have a June 29, 2009 deposition of Cheryl
Bradley J. Davis Samons Deutsche Bank v. Dixon, et aí. Sorry for the
Caridad multiple e-mails.
Thank you.
chinloy (35)
Citimortgage Randi Klayman Lazarus
Bar Counsel
Class Action MERS
The Florida Bar
Deleted Items Lakeshore Plaza 11, Suite 130
1300 Concord Terrace
ebanks
Sunrise, FL 33323
Employee 954-835-0233
954-835-0133 fax
E-service addresses
[email protected]
Florida Bar
foreclosure class action...
FRIDKIN From: [email protected]
To 'Randi Lazarus"<[email protected]>
Heritage Web Dale. 02/06/2013 o8:01 P M
Subject Re: David James Stem. file no. 2011-50,216(171)
Ichiban
Idaboy vs Atlantic
Insurance
Julian Looks like I have to go thru the reALLy big
Junk
box. Should have it to u by tomorrow.
Meanwhile, do u have the depo of Samons
Jutz taken after the mass layoffs at his firm?
Keeler Therein she attributes her training and the
Lombardozzi design of the standard practices to Stern.
Maggie Sherman
Sent via BlackBerry by AT&T
meen
mers friends
From: Randi Lazarus
<[email protected]>

) of 1 9/26/2013 8:15 PM