Excerpts Erika Lance

24 A Well, I'm -- I'm over the legal area also. I --

25 at that time, I was over IT. I'm no longer over our IT

Page 7

1 area. It mainly had the division I spoke of earlier

2 underneath it and legal and stuff. Since then, I've also

3 taken on client relations as a division.

4 Q When you say you're over the legal department,

5 what -- what sort of operations is the legal department

6 involved in?

7 A Well, any legal notifications that we get or

8 questions. We have, of course, attorneys that handle

9 various aspects of things, but I -- most of the legal

10 questions that we get or like title companies having things

11 or attorneys and stuff are things that we can handle

12 in-house.

13 Q So are you an attorney?

14 A No, I'm not.

15 Q What type of educational training did you have

16 prior to being hired by Nationwide Title Clearing?

17 A Do you just want, like, whether I went to high

18 school or college, that kind of thing?

19 Q High school, college.

20 A I went to high school. I got a GED actually.

21 Q And then you started working after that?

22 A I was actually working previous to that. I

23 started working at 14.

24 Q Okay. What was your previous employer most

25 recent to Nationwide Title Clearing?

Page 8

1 A Consumer Sales Solutions.

2 Q What type of business is that?

3 A Telemarketing.

4 Q Did that company have anything to do with

5 mortgages, deeds?

6 A Not at all. They were gas and energy. I ran

7 their human resources area.

8 Q Have you had any particular -- any specific

9 training to -- for your present position as senior vice

10 president?

11 A Six and a half years of working at this company,

12 yes.

13 Q Okay. Have you been required to take any title

14 courses, real estate title courses?

15 A No. They're not required for this position.

16 Q Do any of the other employees of Nationwide Title

17 Clearing, are they required to take any type of title, real

18 estate title courses?

19 A No, because most real estate title courses don't

20 actually apply to what we do here on our side.

21 Q Okay. Why -- why don't you give me a broad

22 description then of what you do at Nationwide?

23 A We do the paperwork for mortgage companies. Most

24 especially we do Assignments of Mortgage, Lien Releases, and

25 document retrieval and research.

Page 9

1 Q So that's Assignments, lien retrieval?

2 A Lien Releases.

3 Q Releases.

4 A And document retrieval and research.

5 Q Does the research not involve title research?

6 A It can involve title research, but most title

7 courses have to do with the front end or being a realtor or

8 doing closings. And everything we do, is after a closing --

9 Q Okay.

10 A -- paperwork-wise.

11 Q So the people that work at Nationwide Title

12 Clearing prepare Assignments; is that correct?

13 A That is one of the functions that we do here.

14 Q Okay. And you -- they also prepare Lien

15 Releases?

16 A Yes.

17 Q Document retrieval, I'm not sure I understand

18 that term.

19 A Banks and mortgage companies can require certain

20 documents be in files usually referred to as a collateral

21 file, which usually has a -- like a certified copy of the

22 mortgage or the original mortgage, title policy, note,

23 et cetera. So sometimes we can do projects where we go and

24 retrieve copies of Assignments or mortgages or title

25 policies so they can fill out their file.

Page 14

19 Q Why is the document returned to Nationwide?

20 A One of the service -- the service that we did for

21 CitiMortgage had to do with the recording and the tracking

22 of Assignments. So we sent it to record at the county, and

23 then we have that so that it gets returned to us so we could

24 mark that it came back recorded image the document.

25 Q And when you say image it, you place it in -- in

15

1 a computer program?

2 A I do. In this particular case, this is an

3 electronically recorded Assignment which means that it was

4 sent via electronic recording and returned to us that way.

5 Q Is that inputted -- after it's recorded, is that

6 inputted into the oracle-based system that you referred to

7 earlier? You said you were imaging the documents?

8 A Yeah. I do image the documents. To answer your

9 question, we have an image repository where we keep track of

10 the documents being imaged.

11 Q Uh-huh.

12 A It's -- I don't understand the question about the

13 input. Do you mean just do we save a copy of the recorded

14 image?

15 Q Correct.

16 A Yes.

17 Q And is that in the image repository?

18 A Uh-huh.

19 Q Is there a name for that system?

20 A No.

21 Q You just call it the image repository?

22 A It's just where we keep our images. It's image

23 storing.

24 Q What is -- what type of system is that?

25 A It's a SAN.

16

1 Q Is that S-A?

2 A -N.

3 Q -N.

4 A And that is the extent of what I know about it.

5 It is called a SAN. It's a type of machine that keeps large

6 quantities of images so. . .

7 Q Do you know what S-A-N stands for?

8 A No idea

18 In this instance, how many did they ask you -- or

19 did they send over at one time?

20 A I don't have that number.

21 Q Would it be -- and I'm not asking you to guess,

22 but if you do have a ballpark, would it have been dozens or

23 hundreds?

24 A Hundreds to thousands but I don't know in this

25 particular case how many.

Page 17

1 Q So -- I'm sorry.

2 A I was going to say we've done over a hundred

3 thousand Assignments so. . .

4 Q So anywhere from a hundred -- from hundreds to a

5 hundred thousand, they would send a request?

23 Q -- there's an effective date. How -- how is the

24 effective date selected?

25 A It's given to us by the client

(p. 18)

1 Q So it's given to you by CitiMortgage?

2 A Uh-huh.

3 Q Is it given to you -- is -- is every Assignment

4 in that batch given the same effective date?

5 A Usually. It's usually because it's a transfer of

6 a grouping of loans from one entity to another.

7 Q So that is -- is that also the date that the

8 batch is transferred to Nationwide?

9 A No. We could prepare Assignments in advance of a

10 transfer date so that they're ready to be sent to record on

11 the transfer date is usually how it's done.

12 Q In anticipation of a transfer?

13 A No. Usually banks know that they're buying and

14 selling groups of loans to each other --

15 Q Uh-huh.

16 A -- and so based on whatever agreement they have

17 and what actions have to transpire previous to that, they

18 could tell us that, say, "x" loans, these 100 loans are

19 going to change hands on this date. They'll give us the

20 information so they can be ready and prepared to go out the

21 door on that date to go to recording.

22 Q And just below that, we have the title,

23 "Assignment of Mortgage: For good and valuable

24 consideration."

25 Are you -- do you have the information as to the

(p. 19)

1 consideration paid for this particular mortgage?

2 A Nope.

3 Q Do you know who does have that information?

4 A I would assume CitiMortgage and Bayview.

5 Q But you're not certain?

6 A No.

7 Q And then we have "CitiMortgage as successor in

8 interest by merger to CitiFinancial Mortgage Company, Inc.,"

9 whose address is 1000 Technology Drive in O'Fallon,

10 Missouri --

11 A Uh-huh.

12 Q -- assigning a mortgage together with a note to

13 Bayview Loan Services; is that correct?

14 A Yes.

15 Q Is this typically how Assignments of -- or

16 transfer of notes occur through Assignment of Mortgage?

25 A To answer your question, on this particular case,

(p. 20)

1 I don't know what occurred on it because I was not part of

2 the -- the sale or of the agreement between Bayview and

3 Citi. We were hired specifically to do Assignments.

4 Normally, this is an action recording at the

5 county to indicate a sale has taken place or a transfer of

6 loans has taken place from one entity to another.

7 Q (By Ms. Drysdale) So I'm not sure that -- that

8 answered the question that I was asking.

9 This document is apparently assigning a note?

10 A Yes.

11 Q Is that correct?

12 A Yes.

13 Q And is it your understanding that that's

14 generally how notes are transferred through Assignments?

15 A I'm trying to figure out how to answer this

16 question. It is my understanding that notes are transferred

17 through a sale agreement between mortgage entities. They

18 record Assignments to put on the record who the current

19 beneficiary is for that note and loan, that mortgage.

20 The -- the Assignment itself is not the, to my

(P. 20)

21 understanding, the actual sale of the loan. Does that make

22 sense?

23 Q Yes, ma'am.

24 A Okay. So that's why I'm saying this is to

25 indicate that that event occurred and to record it at the

(p. 21)

1 county recorder's office as having occurred.

2 Q And you said that you were not part of these or

3 privy to the details of the sale from CitiMortgage to

4 Bayview; is that correct?

5 A Correct.

6 Q That you were just asked to prepare a document?

7 A Prepare Assignments, yes.

20 Q When you and I spoke earlier, you indicated

21 that -- that you might be a better person to provide

22 information about this Assignment than Mr. Bly; do you

23 recall that?

24 A Yes.

25 Q And -- and why did you think that you rather than

(p. 22)

1 his supervisor could be explain what --

2 A Because the questions that you were asking in

3 your affidavit did not just have to do with him signing the

4 direct document. You -- the questions pertained also to our

5 overall procedure and our connection with CitiMortgage,

6 which are questions that he can't answer.

7 Q So then let's talk a little about what Mr. Bly --

8 what he actually does in executing an Assignment of

9 Mortgage. Can you go through that process with me?

10 A Yeah. He is what we refer to as a signer. He is

11 somebody at Nationwide who is designated to execute

12 documents.

13 Q So just can you give me a general idea of what

14 his -- his day-to-day activities would be?

15 A He signs and notarizes documents.

16 Q So when he comes in in the morning, he sat -- he

17 sits at his desk, and that's pretty much all he does all

18 day?

19 A Yes.

20 Q Is sign and notarize documents?

21 A Yes.

22 Q Assignments of Mortgage?

23 A Assignments of Mortgage, Lien Releases.

24 Q Does he actually research any of the information

25 contained in the Assignment of Mortgage?

(p. 23)

1 A No.

4 Q About how many documents, including Assignments

5 of Mortgage, would he sign in the average day?

6 A A couple thousand.

(p. 24)

8 THE WITNESS: This is a copy of the Corporate

9 Resolution signed by the board of directors of

10 CitiMortgage, and it appoints Nationwide Title

11 Clearing, "are appointed as assistant secretaries and

12 vice presidents of the corporation."

13 MS. DRYSDALE: Okay. So we will mark this as --

14 this Joint Consent of the Executive Committee as

15 Defendant's 3.

21 Q Okay. Do we have or is there located at

22 Nationwide Title Clearing the minutes of the meeting of the

23 executive committee of the board of directors when this

24 consent was created?

25 A No, it's not required.

(p.25)

1 Q It's not required?

2 A No.

3 Q And is that -- that's what your -- your legal

4 department --

(P. 25)

5 A Correct.

6 Q Okay. Do you know how they decided to name these

7 employees listed on the consent as assistant secretaries and

8 vice presidents of the corporation?

9 A Generally, we -- we provide them a list of the

10 employees that we'd like them to list.

11 Q Do you know how the -- they're -- because they're

12 basically being designated as officers of the corporation.

13 Do you know why that particular designation was chosen?

14 A You -- you have to name them as officers in order

15 to sign documents in certain counties. They're only

16 designated as officers in regards to the actual signing of

17 the documents. That's -- that's their limitation. If you

18 read the entire document, that's what it limits them to.

19 Q So they are -- they are nominated in these

20 positions for the -- I guess, for the sole purpose of

21 processing releases and Assignments; is that correct?

22 A Correct.

(p.26)

13 Q And so when Mr. Bly is executing the couple

14 thousand of Assignments a day, that is the extent of his --

15 that's the extent of his duties as vice president?

16 A Uh-huh -- yes, sorry, or assistant secretary. It

17 just depends on what's required at the county. He could be

18 listed as either or.

19 Q So does Nationwide have a chart of all the

20 counties in Florida to know whether or not Mr. Bly is

21 supposed to be a vice president or assistant secretary?

22 A We have a list of all the counties in the entire

23 United States that tells us that.

24 Q So Mr. Bly executes Assignments of Mortgage to be

25 recorded all over the United States?

(p. 27)

1 A And Lien Releases.

2 Q And Lien Releases.

3 Does he hold that position as vice president for

4 any other companies other than CitiMortgage?

5 A Yes.

6 Q What other companies?

7 A There are many, and I don't know if I can just

8 release all of the names of them.

9 Q Okay.

10 A But for all of our clients where we sign, he is

11 listed as one of the signers.

12 Q Previously you said that the consent of the

13 executive committee was the reason for the -- the address

14 being listed as a 1000 Technology Drive.

15 Could you expound upon that?

16 A Yeah. He's acting as the capacity as the vice

17 president for that company, and that is the address of that

18 company.

19 Q So he's not physically located in Missouri? He

20 just --

(27)

21 A No. He's physically located in Florida.

22 Q He just lists that as his address for purposes of

23 this Assignment of Mortgage?

24 A Correct.

Page 28

12 Q Down at the bottom of the Corey Assignment it

13 says that the document was prepared by Jessica Fretwell?

14 A Yes.

15 Q Do you know Ms. Fretwell?

16 A Yes.

17 Q And is she also an employee of Nationwide?

18 A Yes, she is.

19 Q And what is her job description?

20 A She works in our quality control division.

21 Q What are her day-to-day responsibilities?

22 A How to do with the establishment of the forms and

23 the county requirements.

24 Q When you say "the establishment of the forms,"

25 what do you mean by that?

(p. 29)

1 A This form is -- each form that we have is set up

2 for the county. They have margin requirements, what has to

3 be on it, like how many witnesses, who has to sign it, that

4 sort of thing. So she established the actual form that the

5 information that our enterers key in, gets fed into.

6 Q Did she prepare this document? And I'm referring

7 to the Corey Assignment.

8 A She prepared the form, and it printed out with

9 the information with -- from our data enterers.

10 Q So who generated the Corey Assignment, the actual

11 physical piece of paper?

12 A It came out of our printing area.

13 Q Did -- was a person responsible for that, or is

14 that something that's automated?

15 A It's automated.

16 Q And what is the name of the automated system that

17 creates the actual Assignments?

18 A Planat Press.

19 Q Can you spell that for me?

20 A P-L-A-N-A-T P-R-E-S-S.

21 Q And where does Planat Press get the information

22 needed to create the documents?

23 A The form is created in Planat Press as I

24 described by Jessica Fretwell in the quality control area.

25 They create the form that the document -- the information is

(p. 30)

1 fed in to, and our data enterers will enter the information.

2 It gets quality control checked, and once it's verified, it

3 then gets printed.

4 Q So a human enters the specifics, the dates and

5 the names of the entities?

6 A Yeah.

7 Q And the name of the signer?

8 A Yeah. And in this particular case, that document

9 did not get printed off as I explained earlier. That's an

10 electronic recording.

11 Q So this -- the document, the Corey Assignment,

12 was never a physical piece of paper that was manually

13 signed; is that correct?

14 A That is correct.

15 Q Okay. So Mr. Bly didn't actually sign the Corey

16 Assignment; is that correct?

17 A Well, he didn't physically sign it, but he --

18 that meets with the standards for electronic document

19 recording.

20 Q Okay. Are you referring to a specific state or

21 federal law?

22 A This -- no. Specific counties across the nation

23 have started setting it up, so part of like going more green

24 and not having as much paperwork that you can electronically

25 record documents. They have different settings anywhere

(p. 31)

1 from just feeding them information to feeding them like a

2 PDF or TIF version of the document that gets recorded, that

3 they record in their imaging bank, stamped electronically,

4 and then send back to us as having been recorded once it's

5 verified on their side. That document was one of those.

6 Q Yes, ma'am. I understand how it was recorded

7 electronically. I'm just trying to -- to determine whether

8 or not Mr. Bly actually signed a physical document or if

9 a -- his signature was created by Planat Press.

10 A The signature was included by Planat Press

11 because that document was never printed out.

12 Q So did Mr. Bly review the document before it was

13 sent for electronic recording?

14 A No.

15 Q So -- and I'm now -- I continue to refer to the

16 Corey Assignment.

17 Mr. Bly never saw the Corey Assignment prior to

18 it being recorded; is that correct?

19 A Correct.

20 Q Is there any way he has of checking to see what

21 documents are being recorded that contained his signature?

22 A Yes.

23 Q And how does he do that?

24 A He can run a report that would tell him which

25 documents. In this particular case, he could then look up

(p. 32)

1 and view the documents if he wanted to.

2 Q Is that something he does at the end of every

3 day?

4 A No.

5 Q Is that something he does at all?

6 A I'm not sure.

7 Q Is a part of his job description to review the

8 documents that he -- that contain his electronic signature?

9 A No. It's a part of somebody else's

10 responsibility.

11 Q And so somebody else checks all of the electronic

12 signatures at the end of the day?

13 A No. They check them before they go out for

14 recordation to make sure that the form is correct. It's a

15 document inspector.

16 Q Okay. Do you know who the -- is there anything

17 on the Corey Assignment that would identify who the document

18 inspector was?

19 A No.

20 Q About how long -- how long does that process

21 take? Let's say Nationwide received a request from

22 CitiMortgage to generate a -- 2,000 Assignments, how long

23 would it take from the time that request was made until you

24 had 2,000 Assignments like the Corey Assignment

25 electronically filed?

(p. 33)

1 A Well, the way you asked that question, it doesn't

2 work that way. Depending on where we can electronically

3 record and depending on whether or not we have clean files

4 in which to data enter if we need further information.

5 Generally, just say hypothetically we have perfect files and

6 we were recording them all in Duval County, Florida and we

7 were electronically recording them, maybe ten days at the

8 most.

9 Q Uh-huh.

10 A That's if everything was, like, perfect

11 alignment, if that makes sense, not --

12 Q When you say "perfect files," what do you mean by

13 that?

14 A In order for us to enter the information on this

15 file, we have to be supplied copies of documentation --

16 Q Uh-huh.

17 A -- such as the mortgage and any Assignment of

18 record, depending on if that's required, which I do not

19 believe it is in Florida, but I'm not a hundred percent sure

20 of that.

21 So we would have to be supplied the -- they give

(P. 33)

22 us an electronic download of the Assignments they want. We

23 verify the images usually that they give us versus the

24 download and enter in the appropriate information off of

25 those documents to create the Assignment of Mortgage.

(p. 34)

1 Q Do you mean like if they give you an image of a

2 mortgage, you'd check the public records to make that --

3 sure that image is correct? Is that what you mean?

4 A No, no. If it's a recorded mortgage, it usually

5 has a recording stamp, so we don't verify that that's

6 correct. We verify that, okay, if they said Bob Smith, the

7 loan was $100,000 on this date, we make sure -- and for this

8 property address, that that mortgage is the mortgage that

9 we're looking at.

10 Q So do you also prepare Affidavits as well or just

11 Assignments of Mortgage?

12 A No. We can also prepare a Lost Assignment

13 Affidavit.

14 Q Uh-huh. Under what circumstances do you do that?

15 A Normally they're only prepared when say, for

16 instance, we're doing a Lien Release and then -- or an

17 Assignment and the company that the Assignment -- like

(P. 34)

18 there's a break in what's called the "chain of title" and

19 the Assignment cannot be gotten because a company's out of

20 business.

21 Like more so in the last couple of years due to

22 our industry, there are a lot more companies where you can't

23 go get the Assignment signed.

24 Q Uh-huh.

25 A We have a service that does that, where we go

(p. 35)

1 find old companies to sign Assignments, to get them back.

2 But if they cannot be found or the lenders out of business,

3 you'd want to do a Loss of Assignment Affidavit indicating

4 that it was not included in the collateral file and that the

5 lender is out of business.

11 Q Okay. Just to go back to make sure that I

12 understand, I thought that previously you mentioned that

13 Mr. Bly signs a couple of thousands of Assignments and

14 releases a day?

15 A Yes.

16 Q So is there another group of documents where he

17 is actually physically signing?

18 A Yes.

(P. 35)

19 Q Okay. So we have two groups: One group that he

20 physically signs and then some that -- where his signature

21 is just electronically generated?

22 A Correct.

23 Q But with the Corey Assignment, you're saying this

24 one was electronically generated?

25 A Correct.

(P. 36)

1 Q And how can you tell that this -- that the Corey

2 Assignment was electronically generated?

3 A Because I looked it up before I came in here to

4 see how it was recorded, and it's in what we refer to as an

5 E-record, which is an electronically recorded document.

6 Q So you -- if it's E-recorded, it means it was

7 that it was generated by computer?

8 A Uh-huh.

9 Q And it was not actually signed?

10 A It was not actually physically signed, yes.

11 Q Okay.

12 A Those signatures are counted as signatures for

13 electronic recording.

(P. 37)

1 Q And I'm going to call this the M-E-S-S-I-C-A

2 Assignment.

3 Do you know why the signature was so different?

4 A Yes. Our signers have the ability -- one of

5 things we track is they two different site signatures. They

6 can have the long form signature, which is what you see on

7 the electronically recorded document, and they can also have

8 shorthand signatures.

9 Q Can you describe the difference between the two

10 for me?

11 A Generally, depending on the volume of loans that

12 we are executing documents for, the shortened signature

13 works to push the documents, to get more of them executed.

14 But we keep on record the file -- the names that they -- the

15 signatures that they sign under, like they have in their

16 employee file a record of their longhand and shorthand

17 signature.

18 Q So would Exhibit 4, he actually -- Mr. Bly

19 actually did sign this one?

20 A He signed this one.

21 MS. DRYSDALE: Okay. That's 4.

(P. 39)

24 Q Okay. In that -- the Assignment of Mortgage,

25 particularly the Corey Assignment of Mortgage, lists the

(p. 40)

1 note. Does Nationwide ever have possession of the original

2 notes?

3 A For Assignments of Mortgage?

4 Q Yes.

5 A No.

(p. 42)

25 Do you know if that's the -- the normal course of

(P. 43)

1 business for these -- these mortgages to be transferred

2 after they're in default?

3 A I have no idea.

4 Q Is that not the type of information that you'll

5 have to review prior to -- to preparing the documents?

6 A No, we don't.

12 Q Okay. And who does the -- is there any title

13 work done prior to the -- the preparation of the Assignments

14 of Mortgage?

15 A Not by Nationwide Title Clearing.

16 Q Who -- do you know if anybody else does any title

17 work?

18 A No, I don't know.

(P. 46)

1 Q And going back to the Corey Assignment, showing

2 you again -- this is Exhibit 2, the Corey Assignment, shows

3 Mr. Jones notarizing the document.

4 As I understand, Mr. Bly's signature was created

5 by Planat Press; is that correct?

6 A Uh-huh.

7 Q So was Mr. Jones' signature also created by

8 Planat Press as the notary?

9 A Yes.

10 Q Okay. And had Mr. Bly actually manually signed

11 the Assignment of Mortgage? How -- what's the process by

12 which that would be notarized?

13 A What do you mean? He would sign the document,

14 and then it would get notarized after he signed it.

15 Q How does that process work? Does he sign, you

16 said like 1,000 documents, and then they get sent to --

17 A It depends on how many are in a -- each batch.

18 But he would sign a batch of documents, and then he would

19 take them over to whoever the notary is that's signing for

20 him.

21 Q So they're located in -- in -- physically in

22 different parts of the facility?

23 A No. They're in very close proximity to each

24 other. They're in the same cubicle area.

25 Q Okay.

(p. 47)

1 A Yeah.

2 Q And -- but they're taken over from Mr. Bly to

3 Mr. Jones in batch?

4 A In that -- if that hypothetically was signed that

5 way, yes, that's how that would have occurred.

19 Q (By Ms. Drysdale) Okay. I'm looking at your

20 flow chart that you've put together, and starting at the

21 upper left hand corner we have "Client." And then it looks

22 like we have heading right a couple of -- it looks like

23 pictures of CPU's --

24 A Uh-huh.

25 Q -- is that correct?

(P. 48)

1 Can you describe what these are?

2 A That's -- I think graphically this was from my

3 marketing person. This is what we would send to a client to

4 see how our flow chart goes. It's just indicating there's

5 an electronic. It you look at the bubbles that are listed

6 on it, it indicates that electronic loan information to

7 NTC's IT department and how it can be sent.

8 Q Uh-huh.

9 A The other alternate route that doesn't have the

10 CPU says the client can ship loan files to NTC, or we can go

11 on-site and capture them.

12 Q What is -- what system is this with the CPU's

13 where information is obtained -- is sent by the client to --

14 A FTP, CDs, or hard drives or e-mails, secure

15 e-mail.

16 Q Okay.

17 A It says right there in the box.

18 Q I see. So if you could just briefly describe the

19 chart. I think that would probably make it --

20 A Okay. This is just indicating -- the first part

21 indicates that we can receive electronic or physical files

22 from the client. They go into our data entry area.

23 Depending on if there's an exception or a problem with the

24 file, it shows how it resolves it, but just data entry.

25 Then it goes to our quality control department.

(P. 49)

1 As you can see, if you look all the way on the left, it

2 indicates the electronic recording line that I was telling

3 you about, but then skips the print -- printing and

4 processing departments.

5 So it would go electronic recording. It goes to

6 scanning, and then we scan the documents. And they can

7 either get electronically sent, or sometimes the clients

8 require them to be physically sent to themselves or their

9 assignee.

10 But if it goes the physical route, it ends up

11 being printed out, goes into processing, and then it goes to

12 our signing department. Our document inspector quality

13 control checks them. It goes to our checks area, to our

14 mailroom, out to recording, and then when it comes back, it

15 gets logged in and scanned.

16 Q Okay. In two different sections, whether the

17 documents are provided to you -- or the requests are sent to

18 you electronically or by physical document, you've got a

19 quality control.

20 What -- what is -- specifically what is the

21 quality control looking for?

22 A The quality control is after our data entry

23 stuff, not whether or when we receive the files. Is that

24 what you're talking about?

25 Q Yes.

(P. 50)

1 A It just looks to make sure that the information

2 that was being entered is actually correct and that we're

3 assigning the correct loan and that the correct information

4 is on the Assignment to assign the loan, like the recording

5 information, the borrower's name, the address if that's

6 needed, any Assignment chains if needed, legal descriptions.

7 Q Now, is that something that is done based on

8 internal research or based upon the documents provided to

9 you by the client?

10 A It can be either or. If the -- if a client does

11 not give us enough documentation, then they have the option

12 of either providing or -- or we can go research it at the

13 county level.

14 Q And you said sometimes you find missing

15 Assignments in that process?

16 A It's possible to find a broken Assignment chain.

17 Q And what happens at that point?

18 A We ask the client how they want to resolve it,

19 and they can either resolve it by -- if sometimes they say,

20 oh, we can get that Assignment or they ask us to go get the

21 Assignment that's missing.

22 Q And how -- can you describe the process by which

23 you would go and obtain the Assignment?

24 A Well, we find out who it was -- went to, where

25 the break is, who needs to sign it, and we contact that

(P. 51)

1 lender if it's possible. They usually research on their

2 side to verify that that was -- that Assignment is correct,

3 and then we either generate an Assignment for them or they

4 will generate an Assignment to us.

5 Q But you said sometimes the companies are no

6 longer available?

7 A Yeah. It's -- if a company's out of business and

8 you can't -- sometimes even if they're out of business, you

9 can contact an officer of that company and have them sign

10 the document anyway.

11 But hypothetically, if they're totally gone, you

12 can't find them anywhere, then we report that back to the

13 client, and they can make the determination at that time if

14 they want to do a Loss Assignment Affidavit. And that is

15 also depending on whether the county will take a Loss

16 Assignment Affidavit. Some counties won't.

17 Q What happens if the county won't take the Loss

18 Assignment Affidavit?

19 A They have to do what is called a "Quiet Title,"

20 and I -- that's all I know about that.

21 Q Okay.

22 A It's just a procedure called Quiet Title.

(P. 53)

1 A Yes. There's a quality control division.

2 Q A whole division?

3 A Yes.

4 Q Okay. So every Assignment that gets prepared in

5 this company goes through the quality control division?

6 A Yes.

7 Q How many individuals do you have working in that

8 division?

9 A There are, I believe, nine.

10 Q Nine. So someone specifically goes through and

11 looks at the Assignment of Mortgage that was prepared by

12 you, looks at the mortgage, whether it's in hand or on the

13 internet as far as obtaining it from the client's website,

14 to double check that all of the information is correct?

15 A Yeah. They actually -- what they do is there's

16 two different steps. There's one where they review the

17 actual entry, and they do that based off of a review sheet

18 that indicates what are the required fields for that state

19 and county. And then they look at the images that were

20 provided to us or if it's a physical file, but I can say in

21 the last couple of years we do not really have physical

22 files in the buildings anymore.

23 And then the next step is after they've approved

24 the actual what was entered, it goes through the processing,

25 and then it goes through a second quality control check for

(P. 54)

1 the document inspector. Then that's the person that

2 physically looks at the document to make sure it's got all

3 the stamps and signers and if like a legal needed to be

4 attached to it or a cover sheet or something like that.

5 Q Okay. So they're reviewing for two things: One,

6 that it come complies with the county requirements --

7 A Uh-huh.

8 Q -- and two, that it contains all of the proper

9 information as far as borrower's name, legal description,

10 that kind of thing?

11 A Uh-huh.