patricia.berner 112911 mini
TRANSCRIPT
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IN THE CIRCUIT COURT OF THE 11TH JUDICIAL CIRCUIT
IN AND FOR MIAMI-DADE COUNTY, FLORIDA
CASE NO. 2009-20620-CA
DEUTSCHE BANK NATIONAL TRUST COMPANY,
AS TRUSTEE FOR HARBORVIEW MORTGAGE LOAN
TRUST MORTGAGE LOAN PASS-THROUGH
CERTIFICATE, SERIES 2007-5,
Plaintiff,
vs.
EIDA GAYON, et al.,
Defendants.
________________________________________/
DEPOSITION OF
PATRICIA BERNER
TAKEN ON BEHALF OF THE DEFENDANTS
November 29, 2011
2:09 p.m. - 2:47 p.m.
20801 Biscayne Boulevard
Suite 202
Aventura, Florida
Bonnie Schwartz, Certified Shorthand Reporter
3
1 INDEX OF EXAMINATION2 WITNESS PAGE
PATRICIA BERNER3
4 DIRECT EXAMINATIONBy Mr. Trent 5
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21 APPEARANCES OF COUNSEL2 For the Plaintiff:
GLADSTONE LAW GROUP, P.A.3 Jessica Serrano, Esquire,
Danielle DeLucca, Esquire,4 1499 West Palmetto Park Road
Suite 3005 Boca Raton, FL 33486
6 [email protected] For the Plaintiff:AKERMAN SENTERFITT
8 Jeffrey T. Cook, Esquire,One Southeast Third Avenue
9 25th FloorMiami, FL 33131
10 [email protected] For the Defendants:
KENNETH ERIC TRENT, P.A.12 Kenneth Eric Trent, Esquire,
831 East Oakland Park Boulevard13 Fort Lauderdale, FL 33334
[email protected] ALSO PRESENT:16 Osvaldo Gayon17
1819202122232425
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2 INDEX TO EXHIBITS3
Defendants'4 Exhibit Description Page5 1 Notice of Taking Deposition 66 2 document 257
(Exhibits were retained by Counsel.)8
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Patricia Berner November 29, 2011
Toll Free: 800.211.3376Facsimile: 305.493.3322
Aventura Corp. Center I, Suite 202
20801 Biscayne BlvdAventura, FL 33180
www.esquiresolutions.com
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1 DEPOSITION OF PATRICIA BERNER
2 November 29, 2011
3
4 THEREUPON:
5 PATRICIA BERNER
6 having been first duly sworn, testified as follows:
7 DIRECT EXAMINATION8 BY MR. TRENT:
9 Q Good afternoon.
10 A Hi.
11 Q State your name and business address,
12 please?
13 A Patricia Berner, 4875 Belfort Road,
14 Jacksonville, Florida 32256.
15 Q How do you spell your last name?
16 A B-E-R-N-E-R.
17 Q Who is your current employer?
18 A American Home Mortgage Servicing, Inc.
19 Q How long have you been employed by American
20 Home Mortgage Servicing, Inc.?21 A About 16 and a half months.
22 Q Let me just give you a little introductory
23 spiel. My name is Kenneth Trent. I represent the
24 defendant in this case, Eida Gayon. And we are here
25 pursuant today pursuant to a Notice Of Taking
7
1 A Right there.
2 Q Right there. Do you see that, deponent?
3 A Okay.
4 Q Are you the representative of the
5 plaintiff --
6 A Yes.
7 Q -- about the loan at issue in this case?8 A Yes.
9 Q Tell us what your relationship is or how it
10 is that you are representative of Deutsche Bank
11 National Trust Company as Trustee for the Harborview
12 Mortgage Loan trust?
13 A American Home Mortgage Servicing is the
14 servicing agent for the loan.
15 Q Right, but I'm asking how you are a
16 representative of Deutsche Bank National Trust
17 Company as Trustee?
18 A I am employed by American Home Mortgage
19 Servicing Inc., and we're the servicing agent for the
20 loan.
21 Q Well, you're still not telling me what your
22 relationship is, Ms. Berner, to Deutsche Bank
23 National Trust Company as Trustee. Would you please
24 tell me what your relationship is to Deutsche Bank
25 National Trust Company as Trustee?
6
1 Deposition which I do have three copies of
2 miraculously enough.
3 While I'm marking this as an exhibit, let
4 me just ask you whether you've ever had your
5 deposition taken before?
6 A Yes.
7 Q Approximately how many times?8 A Half a dozen or so.
9 MR. TRENT: First of all, Counsel, if
10 you could state your appearance and who it
11 is that you're representing here?
12 MR. COOK: Sure. My name is
13 Jeffrey Cook of Akerman Senterfitt. And I'm
14 making an appearance on behalf of the
15 plaintiff.
16 (Thereupon, Defendants' Exhibit Number 1
17 was marked for identification.)
18 BY MR. TRENT:
19 Q Ma'am, if you could take a look at this,
20Exhibit 1, and tell me whether you've seen that
21 before?
22 A Yes, I have.
23 Q Do you see where it says deponent about
24 two-fifths of the way down the page in the left-hand
25 column, deponent?
8
1 A We're the servicing agent for the loan.
2 Q You said you're employed by American Home
3 Servicing Inc. Are you also employed by Deutsche
4 Bank Trust Company as Trustee?
5 A No.
6 Q Do you have any contractual relationship
7 with Deutsche Bank National Trust Company as Trustee?8 MR. COOK: Object to the form. You can
9 answer.
10 THE WITNESS: American Home Mortgage
11 Servicing is the servicing agent for the
12 bank. We have power of attorney to act on
13 their behalf to service the loan.
14 BY MR. TRENT:
15 Q And do you, Ms. Berner, have any written
16 authorization that allows you to give testimony on
17 behalf of not American Home Servicing, but Deutsche
18 Bank as Trustee?
19 MR. COOK: Object to the form.
20 THE WITNESS: We have power of
21 attorney. We service the loan. We have
22 power of attorney.
23 BY MR. TRENT:
24 Q Ma'am, when you say we, you're referring to
25 American Home Servicing, correct?
Patricia Berner November 29, 2011
Toll Free: 800.211.3376Facsimile: 305.493.3322
Aventura Corp. Center I, Suite 202
20801 Biscayne BlvdAventura, FL 33180
www.esquiresolutions.com
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1 A Yes.
2 Q I'm asking about you, Patricia Berner.
3 Ma'am, the question is do you have any written
4 authorization from Deutsche Bank National Trust
5 Company as Trustee For Harborview Mortgage Loan
6 Trust, et cetera, that allows you to speak on behalf
7 of that entity or to give testimony in this case on8 behalf of that entity?
9 MR. COOK: Object to the form.
10 THE WITNESS: I don't understand what
11 you're talking about.
12 BY MR. TRENT:
13 Q How is it that you -- Ms. Berner, are you a
14 representative of the plaintiff named on Exhibit 1?
15 A We have power of attorney to act on their
16 behalf.
17 Q Did you speak with someone from
18 Deutsche Bank National Trust Company to learn what
19 Deutsche Bank National Trust Company's perspective is
20 on this loan or this litigation?21 MR. COOK: Object to the form.
22 THE WITNESS: No.
23 BY MR. TRENT:
24 Q I mean, my instinct is to go off the record
25 and discuss this with Counsel.
11
1 However, in the interest of since we have
2 everyone here, we will continue at this
3 point.
4 MR. COOK: Your objection is noted for
5 the record. And we will take it up with the
6 Court if needed.
7 MR. TRENT: Absolutely, thank you.8 BY MR. TRENT:
9 Q So, Ms. Berner, what is your position at
10 American Home Servicing, Inc.?
11 A I'm a Foreclosure Special Assets Specialist
12 II.
13 Q Foreclosure Special Assets Specialist?
14 A Um-hum.
15 Q II?
16 A Um-hum.
17 Q And what are your job duties as a
18 Foreclosure Special Assets Specialist II?
19 A We handle contested foreclosure files,
20assist the attorneys in resolution. We prepare for
21 depositions. We prepare for trials at court. We
22 work towards resolution.
23 Q I'm sorry, where is your office located?
24 A Jacksonville, Florida.
25 Q Who was your employer prior to American
10
1 MR. TRENT: If you want to have a
2 discussion on the record, we can have it on
3 the record.
4 MR. COOK: We can have it off the
5 record to start.
6 MR. TRENT: Okay, let's go off the
7 record.8 (Thereupon, a discussion was held off the
9 record after which the deposition continued:)
10 MR. TRENT: The defendants object to
11 Ms. Berner being designated as the
12 representative of the plaintiff with the
13 most knowledge in this matter. And by
14 continuing with this deposition, the
15 defendant does not waive a Motion to Compel
16 or other vehicle which it will seek again to
17 obtain the testimony of the representative
18 of the plaintiff with the most knowledge.
19 I think what we have here is a
20representative of a representative of the21 plaintiff. And that I don't believe is
22 within a well understood definition of a
23 representative when used in notices of
24 taking deposition nor is it within
25 contemplation of the Court's order.
12
1 Home Servicing, Inc.?
2 A I was unemployed for six months. And prior
3 to that I worked for a foreclosure trustee up in
4 Virginia for just about five years.
5 Q And who was that foreclosure trustee?
6 A It was Specialized Inc. of Virginia.
7 Q When you say foreclosure trustee, what do8 you mean?
9 A Virginia is a deed of trust state. And the
10 foreclosures go through a trustee rather than the
11 courts.
12 Q It's a non-judicial state?
13 A It's a non-judicial state, yes. So it's a
14 trustee office that did foreclosures.
15 Q Let me ask you this: When you first became
16 employed by American Home Servicing, Inc., what was
17 your title?
18 A We were default litigations specialists.
19 Q When you say we, what do you mean because
20 I'm asking about you in particular?
21 A Well, our whole department. And then they
22 changed our titles. The company, they changed our
23 title to Foreclosure Special Assets.
24 Q What training did you receive at the time
25 upon coming to work for American Home Servicing,
Patricia Berner November 29, 2011
Toll Free: 800.211.3376Facsimile: 305.493.3322
Aventura Corp. Center I, Suite 202
20801 Biscayne BlvdAventura, FL 33180
www.esquiresolutions.com
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1 Inc.?
2 MR. COOK: Object to the form.
3 BY MR. TRENT:
4 Q Just take me, if you could, briefly through
5 the process of orientation and training for your
6 position.
7 MR. COOK: Object to the form.8 THE WITNESS: Most of our training is
9 proprietary. I have been involved in the
10 title insurance and mortgage servicing of
11 the foreclosure business for almost 30
12 years.
13 BY MR. TRENT:
14 Q Well, unless your attorney instructs not to
15 answer, it is your responsibility. You're expected
16 to answer the questions that I asked.
17 So, if you could, please detail for me the
18 training you received from your employer upon first
19 coming to work for American Home Servicing, Inc.?
20 A Basically was about the company, who to go21 to for certain things, a little bit of their computer
22 system. I had previously had experience on most of
23 their software that we use for maintaining our
24 business records.
25 Q What else did your training entail?
15
1 Q When they taught you about your position,
2 did they teach you anything about assignments of
3 mortgages?
4 MR. COOK: Object to the form.
5 THE WITNESS: What do you mean teach?
6 BY MR. TRENT:
7 Q Did any part of your training or8 orientation with American Home Servicing, Inc.
9 involve the subject matter of mortgage assignments?
10 MR. COOK: Object to the form.
11 THE WITNESS: I don't recall.
12 BY MR. TRENT:
13 Q Do you have knowledge of the mortgage and
14 note that we are here on today?
15 A Yes.
16 Q Do you have knowledge of the foreclosure
17 litigation in which this deposition is convened?
18 A Yes.
19 Q Tell us your understanding of the course of
20the proceedings in this litigation.
21 MR. COOK: Object to the form.
22 THE WITNESS: The borrower signed a
23 mortgage and a note; subsequently defaulted.
24 A foreclosure action was brought. The issue
25 was contested. However, my understanding is
14
1 A We're updated periodically with training
2 from outside sources and kept apprised of changes in
3 the industry.
4 Q Well, first of all, what was the software
5 with which you previously had experience?
6 A Our whole servicing system, MSP, desktop,
7 you know, Microsoft Word, Office, Excel.8 Q Any DOCX software, D-O-C-X?
9 A I'm not familiar with that, no.
10 Q Are you able to create assignments of
11 mortgages on the software that is utilized, that you
12 utilized or have access to at American Home
13 Servicing, Inc.?
14 A No.
15 Q Are you able to create any kind of
16 documents with that software?
17 MR. COOK: Object to the form.
18 THE WITNESS: I'm not able to create
19 any kind of documents.
20 BY MR. TRENT:
21 Q I mean, do you still use this software?
22 A Yeah, we monitor the accounts. And like I
23 said, we provide information to the attorneys, copies
24 of documents, information that we have in our records
25 to assist in getting the litigation resolved.
16
1 that that part of it had been resolved and
2 that we obtained summary judgment.
3 BY MR. TRENT:
4 Q What issue was contested?
5 MR. COOK: Object to the form.
6 THE WITNESS: I don't recall
7 specifically.8 BY MR. TRENT:
9 Q Has anything transpired since summary
10 judgment as far as the litigation within the
11 litigation?
12 MR. COOK: Object to the form.
13 THE WITNESS: The depositions.
14 BY MR. TRENT:
15 Q What depositions?
16 A Mine and the deposition from the borrower.
17 Q Do you know why depositions are being
18 conducted?
19 A Yes.
20Q Why?
21 A You have issues with DOCX assignments.
22 Q Are you familiar with DOCX at all?
23 A A little.
24 Q What do you know about it?
25 A They were a third party vendor that
Patricia Berner November 29, 2011
Toll Free: 800.211.3376Facsimile: 305.493.3322
Aventura Corp. Center I, Suite 202
20801 Biscayne BlvdAventura, FL 33180
www.esquiresolutions.com
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1 American Home Mortgage had contracted with to prepare
2 assignments when needed.
3 Q Do you know whether American Home
4 Servicing, Inc. still has a business relationship
5 with DOCX?
6 A Yes, I do. And, no, we do not.
7 Q Do you know whether DOCX has changed its8 name?
9 A I'm not aware, no. I don't know.
10 Q Is there another vendor who has taken the
11 place of DOCX, to your knowledge, with regard to
12 American Home Servicing?
13 MR. COOK: Object to the form.
14 THE WITNESS: I believe that there is.
15 BY MR. TRENT:
16 Q And what's the name of that?
17 A I don't recall.
18 Q Do you have any knowledge of why American
19 Home Servicing, Inc. no longer does business with
20 DOCX?21 A There were deficiencies in the documents
22 that they were producing.
23 Q What sort of deficiencies in general?
24 A They weren't deficiencies. They weren't
25 prepared correctly.
19
1 A American Home Servicing, Inc. has not been
2 an owner or a holder of the note.
3 Q Tell me about American Home Servicing,
4 Inc.'s relationship with Deutsche Bank National Trust
5 Company as Trustee for the Harborview Mortgage Loan
6 Trust, et cetera?
7 A We're the servicing agent for the loan, the8 loan that's part of this trust.
9 Q And how do you know that?
10 A The loan schedule to the trust is part of
11 what's online at the SEC website. And I personally
12 went in and confirmed that this loan is listed on
13 that schedule.
14 Q Now, the loan schedule that you mentioned
15 is a part of what document on the SEC website?
16 A It's under the second listed FWP.
17 Q What is FWP?
18 A I don't remember what it stands for.
19 Q First of all, do you know whether there's a
20 pooling and servicing agreement that governs the
21 Harborview Mortgage Loan Trust Mortgage Loan
22 Pass-Through Certificate, Series 2007-5?
23 A Yes, there is.
24 Q Have you reviewed that pooling and
25 servicing agreement?
18
1 Q Can you give me any more detail about that?
2 I'm not asking about this specific case yet. Just in
3 general what sort of deficiencies?
4 A Some of the assignments weren't properly
5 conveying the assignor/assignee appropriate parties.
6 Q As to the present mortgage that we're here
7 on today, do you know whether American Home8 Servicing, Inc. has ever had any ownership of the
9 beneficial interest in the payments due under the
10 note and secured by the mortgage?
11 A No, we're strictly the servicer.
12 Q So at no time has American Home Servicing,
13 Inc. actually owned any interest in the mortgage; is
14 that correct?
15 MR. COOK: Object to the form.
16 THE WITNESS: No, we have not.
17 BY MR. TRENT:
18 Q But what I'm saying is correct, right?
19 MR. COOK: Object to the form.
20BY MR. TRENT:
21 Q I mean, I said is that correct and you
22 said, no, we have not?
23 A Right.
24 Q So I just want to make sure the record is
25 clear.
20
1 A I've skimmed over it, yes.
2 Q Let me ask you this: Does the pooling and
3 servicing agreement contain any requirements as to
4 the manner by which loans are transferred into the
5 trust?
6 MR. COOK: Object to the form.
7 THE WITNESS: That I don't recall.8 BY MR. TRENT:
9 Q Does the pooling and servicing agreement
10 contain any restrictive dates by which loans, if they
11 are to be part of the trust, must be transferred into
12 the trust?
13 MR. COOK: Object to the form.
14 THE WITNESS: There's the opening and
15 closing date of the pool. And the loans are
16 in the pool as of the closing date. And the
17 original documents under Section 2.01 under
18 Section 2, I think it is, Article 2 states
19 that upon the closing date the note and
20mortgages are delivered to the trustee on
21 behalf of the holders of the trust.
22 BY MR. TRENT:
23 Q You say the loans are placed in the pool by
24 the closing date, correct?
25 A Yes.
Patricia Berner November 29, 2011
Toll Free: 800.211.3376Facsimile: 305.493.3322
Aventura Corp. Center I, Suite 202
20801 Biscayne BlvdAventura, FL 33180
www.esquiresolutions.com
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1 Q Isn't it accurate to say that the loans are
2 required to be placed in the trust by the closing
3 date?
4 MR. COOK: Object to the form.
5 BY MR. TRENT:
6 Q If they are to be a part of the trust?
7 A My guess, you could say that.8 Q I understand your answer to my question
9 about whether there are requirements for the manner
10 in which loans are transferred into the trust which I
11 guess can also be described as a pool. You know what
12 I'm referring to, correct?
13 A Yes.
14 Q Just assume for the purpose of this
15 question there are requirements by which loans are
16 transferred into the trust. Do you know what happens
17 if those requirements are not met?
18 MR. COOK: Object to the form.
19 THE WITNESS: No, that's beyond the
20 scope of my knowledge.21 BY MR. TRENT:
22 Q Isn't it a fact, ma'am, that any and all
23 assignments prepared by DOCX are problematic and
24 subject to being questioned? Let me rephrase.
25 Of course, anything is subject to being
23
1 A No.
2 Q Have you heard, read or seen that name
3 before?
4 A Yes.
5 Q In what context?
6 A The same. I've seen the name on
7 assignments.8 Q And isn't it a fact, ma'am, it's widely
9 understood that documents containing Korell Harp's
10 signature are questionable?
11 MR. COOK: Object to the form.
12 THE WITNESS: Yes.
13 BY MR. TRENT:
14 Q And you're aware that the assignment in
15 this case contains the alleged signature of both
16 Korell Harp and Tywanna Thomas?
17 MR. COOK: Object to the form.
18 THE WITNESS: Yes.
19 BY MR. TRENT:
20Q Do you have any reason to believe that the
21 assignment in this case which contains the purported
22 signatures of both of those people is any less
23 problematic than the others of which you have general
24 awareness?
25 MR. COOK: Object to the form.
22
1 questioned including my vocabulary, but isn't it a
2 fact, ma'am, that there have been widespread
3 irregularities with assignments prepared by DOCX?
4 MR. COOK: Object to the form.
5 THE WITNESS: Yes.
6 BY MR. TRENT:
7 Q Now, do you know a person by the name of8 Tywanna Thomas?
9 A No.
10 Q Have you ever heard that name?
11 A Yes.
12 Q In what context have you heard or become
13 familiar with that name?
14 A I've seen her name on assignments that they
15 prepared.
16 Q That DOCX prepared?
17 A Yes.
18 Q Has it ever come to your attention that
19 there are some irregularities with assignments
20 allegedly signed by Ms. Thomas and prepared by DOCX?
21 MR. COOK: Object to the form.
22 THE WITNESS: Yes.
23 BY MR. TRENT:
24 Q What about Korell Harp, K-O-R-E-L-L,
25 H-A-R-P? Same question. Do you know Korell Harp?
24
1 BY MR. TRENT:
2 Q Yes, let me try that again.
3 We agree it's widely understood that --
4 MR. COOK: If I may interject?
5 MR. TRENT: Sure.
6 MR. COOK: It would be helpful to show
7 her any documents with respect to this8 specific assignment at issue.
9 MR. TRENT: You know, I'm quite aware
10 that that is within my quiver of arrows, if
11 I choose to deploy that particular tactic,
12 but thanks for reminding me.
13 BY MR. TRENT:
14 Q Have you looked at the assignment in this
15 case in preparing for this deposition?
16 A Yes, I have.
17 MR. COOK: Object to the form.
18 THE WITNESS: Yes, I have.
19 BY MR. TRENT:
20Q Do you have any knowledge of the
21 circumstances under which it was executed?
22 MR. COOK: Object to the form.
23 THE WITNESS: Can you repeat that?
24 BY MR. TRENT:
25 Q Yes. Do you have any knowledge as to how
Patricia Berner November 29, 2011
Toll Free: 800.211.3376Facsimile: 305.493.3322
Aventura Corp. Center I, Suite 202
20801 Biscayne BlvdAventura, FL 33180
www.esquiresolutions.com
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1 that particular assignment came about?
2 MR. COOK: Object to the form.
3 THE WITNESS: How it came about?
4 BY MR. TRENT:
5 Q Yes. Isn't it a fact, ma'am, that this is
6 a DOCX assignment? I'll just hand you the exhibit.
7 MR. TRENT: It's Exhibit --8 THE WITNESS: Two.
9 MR. TRENT: -- two.
10 (Thereupon, Defendants' Exhibit Number 2
11 was marked for identification.)
12 BY MR. TRENT:
13 Q It has the Notice of Filing in the front,
14 but skip that.
15 MR. COOK: Do you want some time to
16 review the document?
17 THE WITNESS: I forgot the question.
18 BY MR. TRENT:
19 Q Isn't it a fact, ma'am, that this document
20 was prepared by DOCX?21 A Yes.
22 Q Do you have any knowledge of how it came to
23 be prepared other than knowing that it was prepared
24 by DOCX?
25 MR. COOK: Object to the form.
27
1 Q Just give me any knowledge that you have
2 about this document other than what we've already
3 covered and what it already says by its language.
4 MR. COOK: Objection. Asked and
5 answered.
6 THE WITNESS: What it says is that
7 American Home Mortgage Servicing, Inc. is8 the assignor to Deutsche Bank. And American
9 Home Servicing, Inc. has never been an owner
10 or a holder of the note. And, therefore,
11 they shouldn't have been put in, ever
12 assigned the mortgage in the first place.
13 BY MR. TRENT:
14 Q You mean the assignment?
15 A Yes.
16 Q Yes, American Home Mortgage Servicing, Inc.
17 is not the proper party to be assigning the note or
18 the mortgage to the trust, is it?
19 A No.
20MR. COOK: Object to the form.
21 THE WITNESS: No.
22 BY MR. TRENT:
23 Q You agree with me that that's not the
24 correct party, right?
25 MR. COOK: Object to the form.
26
1 THE WITNESS: What do you mean how it
2 was prepared or --
3 BY MR. TRENT:
4 Q Well, let me ask you this: We've
5 established that this was a DOCX assignment, correct?
6 A Yes.
7 Q We've established that it contains the8 signatures of allegedly Korell Harp and
9 Tywanna Thomas, correct, among others?
10 A Yes.
11 Q Do you have any additional knowledge about
12 this assignment other than those two facts and what
13 the document says on its face?
14 MR. COOK: Object to the form.
15 THE WITNESS: I'm not really
16 understanding what you're really asking.
17 BY MR. TRENT:
18 Q I mean, tell us all the knowledge that you
19 have as representative of the plaintiff sitting here
20 giving your testimony about how this assignment came
21 to be executed.
22 A I wasn't there when it was executed. I
23 don't know. I don't know Korell. I don't know
24 Tywanna. I'm not understanding what you're trying
25 to --
28
1 THE WITNESS: I agree.
2 MR. TRENT: Then I have no further
3 questions.
4 MR. COOK: Let's take a quick break.
5 Just for five minutes or so.
6 MR. TRENT: You want to ask some
7 questions?8 MR. COOK: Yes.
9 MR. TRENT: Okay, sure.
10 (Thereupon, a short break was taken off the
11 record after which the deposition continued:)
12 MR. COOK: We have no questions.
13 THE COURT REPORTER: Read or waive?
14 MR. COOK: She'll read.
15 THE WITNESS: Yes.
16 (Whereupon, the deposition concluded at
17 2:47 p.m.)
18 (Signatures and formalities were not
19 waived.)
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Patricia Berner November 29, 2011
Toll Free: 800.211.3376Facsimile: 305.493.3322
Aventura Corp. Center I, Suite 202
20801 Biscayne BlvdAventura, FL 33180
www.esquiresolutions.com
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1 STATE OF FLORIDA )
2 COUNTY OF MIAMI-DADE )
3
4 I, the undersigned authority, certify that
5 PATRICIA BERNER, personally appeared before me and
6 was duly sworn.
7
8
9 WITNESS my hand and official seal this 11th day
10 of December, 2011.
11
12
13
14 ________________________
15 Bonnie L. Schwartz
Notary Public - State of Florida
16 My Commission No. EE 84919
Expires: August 11, 2015
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1
2 DEPOSITION ERRATA SHEET
3
4 Our Assignment No. 267488
5 Case Caption: Deutsche Bank National Trust Company
vs.
6 Eida Gayon, et al.,
7 DECLARATION UNDER PENALTY OF PERJURY
8 I declare under penalty of perjury that I
9 have read the entire transcript of my Deposition
10 taken in the captioned matter or the same has
11 been read to me, and the same is true and
12 accurate, save and except for changes and/or
13 corrections, if any, as indicated by me on the
14 DEPOSITION ERRATA SHEET hereof, with the
15 understanding that I offer these changes as if
16 still under oath.
17
18 Signed on the _______ day of
19 _______________, 20____.
2021 ________________________________
22 Patricia Berner
23
24
25
301 CERTIFICATE2 STATE OF FLORIDA )
COUNTY OF MIAMI-DADE )3
I, Bonnie L. Schwartz, Certified Shorthand4 Reporter, State of Florida at large, do hereby certify
that the aforementioned witness was by me first duly5 sworn to testify the whole truth; that I was authorized
to and did report said deposition in stenotype; and6 that the foregoing pages, numbered from 1 to 28,
inclusive, are a true and correct transcription of
7 my shorthand notes of said deposition.8 I further certify that said deposition was taken
at the time and place hereinabove set forth and that9 the taking of said deposition was commenced and
completed as the hereinabove set out.10
I further certify that I am not attorney or11 counsel of any of the parties, nor am I a relative
or employee of any attorney or counsel of party12 connected with the action, nor am I financially
interested in the action.13
The foregoing certification of this transcript14 does not apply to any reproduction of the same by
any means unless under the direct control and/or15 direction of the certifying reporter.16 IN WITNESS WHEREOF, I have hereunto set my
hand this 11th day of December, 2011.1718
________________________________
19 Bonnie L. SchwartzNotary Public - State of Florida20 My Commission No. EE 84919
My Commission Expires 8/11/20152122232425
321 DEPOSITION ERRATA SHEET2
Page No. _______ Line No. ______ Change to:_______________3
__________________________________________________________4
Reason for change:________________________________________5
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__________________________________________________________7
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8Page No. _______ Line No. ______ Change to:_______________
9__________________________________________________________
10Reason for change:________________________________________
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12__________________________________________________________
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15__________________________________________________________
16Reason for change:________________________________________
17Page No. _______ Line No. ______ Change to:_______________
18__________________________________________________________
19Reason for change:________________________________________
20
Page No. _______ Line No. ______ Change to:_______________21
__________________________________________________________22
Reason for change:________________________________________23
Page No. _______ Line No. ______ Change to:_______________24
__________________________________________________________25
Patricia Berner November 29, 2011
Toll Free: 800.211.3376Facsimile: 305.493.3322
Aventura Corp. Center I, Suite 202
20801 Biscayne BlvdAventura, FL 33180
www.esquiresolutions.com
-
8/3/2019 Patricia.berner 112911 Mini
9/18
33
1
Page No. _______ Line No. ______ Change to:_______________2
__________________________________________________________3
Reason for change:________________________________________4
Page No. _______ Line No. ______ Change to:_______________5
__________________________________________________________6
Reason for change:________________________________________
7Page No. _______ Line No. ______ Change to:_______________
8
__________________________________________________________9
Reason for change:________________________________________10
Page No. _______ Line No. ______ Change to:_______________11
__________________________________________________________12
Reason for change:________________________________________13
Page No. _______ Line No. ______ Change to:_______________14
__________________________________________________________15
Reason for change:________________________________________16
Page No. _______ Line No. ______ Change to:_______________17
__________________________________________________________18
Reason for change:________________________________________19Page No. _______ Line No. ______ Change to:_______________
20
__________________________________________________________21
22 SIGNATURE: ________________________ DATE: ________________23 Patricia Berner24
25
Patricia Berner November 29, 2011
Toll Free: 800.211.3376Facsimile: 305.493.3322
Aventura Corp. Center I, Suite 202
20801 Biscayne BlvdAventura, FL 33180
www.esquiresolutions.com
-
8/3/2019 Patricia.berner 112911 Mini
10/18
A
able
14:10,15,18
Absolutely
11:7
access
14:12
accounts
14:22
accurate
21:131:12
act
8:129:15
action
15:2430:12
additional26:11
address
5:11
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d
30:4
afternoon
5:9
agent
7:14,198:1,1119:7
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24:327:2328:1
agreement
19:20,25
20:3,9
AKERMAN
2:76:13
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23:15
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22:2026:8
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8:169:6
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27:2,3
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5:18,197:13,188:2,10,17,2511:10,2512:16,25
13:1914:1215:817:1,3,12,1818:7,1219:1,327:7,8,16
among
26:9
and/or
30:1431:12
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17:10
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8:913:15,1621:8
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appearance
6:10,14
APPEARANCES
2:1
appeared
29:5
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30:14
apprised14:2
appropriate
18:5
Approximately
6:7
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24:10
Article
20:18
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13:1627:4
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7:159:212:2018:226:16
Assets
11:11,13,18
12:23
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27:12
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27:17
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23:14,21
24:8,1425:1,626:5,12,2027:1431:4
assignments
14:1015:2,916:2117:218:421:2322:3,14,19
23:7
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27:8
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18:5
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BANK
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13:20
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1:156:148:13,179:6,8,1620:21
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10:1116:1721:24,25
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1:143:25:1,5,137:228:159:2,1310:1111:929:531:2233:23
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1:2429:1530:3,19
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23:15,22
Boulevard
1:202:12
break
28:4,10
briefly
13:4
brought
15:24business
5:1113:11,2417:4,19
Patricia Berner November 29, 201134
Toll Free: 800.211.3376Facsimile: 305.493.3322
Aventura Corp. Center I, Suite 202
20801 Biscayne BlvdAventura, FL 33180
www.esquiresolutions.com
-
8/3/2019 Patricia.berner 112911 Mini
11/18
C
came
25:1,3,22
26:20
Caption
31:5captioned
31:10
CASE
1:45:247:79:718:223:15,21
24:1531:5
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13:21
CERTIFICATE
1:619:2230:1
certification
30:13
Certified
1:2430:3
certify
29:430:4,8,10
certifying
30:15
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9:619:6
Change
32:2,4,5,7,8,
10,11,13,14,
16,17,19,20,
22,2333:1,3,4,6,7,9,10,
12,13,15,16,
18,19
changed
12:2217:7
changes
14:231:12,15
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24:11
CIRCUIT
1:2
circumstances
24:21
clear
18:25
closing
20:15,16,19,
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column
6:25
come
22:18
coming12:2513:19
commenced
30:9
Commission
29:1630:20
COMPANY
1:57:11,17,23,258:4,79:5,1812:2213:2019:5
31:5Company's
9:19
Compel
10:15
completed
30:9
computer
13:21
concluded
28:16
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16:18
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19:12
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30:12
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20:3,10
containing
23:9
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23:15,2126:7
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10:25
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11:1915:2516:4
context
22:1223:5
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continued
10:928:11
continuing
10:14
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17:1
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8:6
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30:14
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15:17
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18:5
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2:86:12,138:8,199:9,2110:411:413:2,714:1715:4,10,21
16:5,1217:1318:15,19
20:6,1321:4,1822:4,21
23:11,17,25
24:4,6,17,22
25:2,15,25
26:1427:4,20,2528:4,8,12,14
copies
6:114:23
correct
8:2518:14,18,2120:2421:1226:5,927:2430:6
corrections
31:13
correctly
17:25
COUNSEL
2:14:76:99:2530:11
COUNTY
1:229:230:2
course
15:1921:25
COURT
1:211:6,2128:13
courts12:11
Court's
10:25
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27:3
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14:10,15,18
current
5:17
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2:3
date
20:15,16,19,
2421:333:22
dates
20:10
day
29:930:1631:18
ddelucca@lgl
aw.net
2:6
December
29:1030:16
DECLARATION
31:7
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31:8
deed
12:9
default
12:18
defaulted
15:23
defendant
5:2410:15
Defendants
1:10,152:11
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4:36:1625:10
deficiencies
17:21,23,24
18:3
definition
10:22
delivered
20:20
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2:3
department
12:21
Patricia Berner November 29, 201135
Toll Free: 800.211.3376Facsimile: 305.493.3322
Aventura Corp. Center I, Suite 202
20801 Biscayne BlvdAventura, FL 33180
www.esquiresolutions.com
-
8/3/2019 Patricia.berner 112911 Mini
12/18
deploy
24:11
deponent
6:23,257:2
DEPOSITION
1:134:55:16:1,510:9,14,2415:1716:1624:1528:11,16
30:5,7,8,9
31:2,9,14
32:1
depositions
11:2116:13,15,17
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Description
4:4
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10:11
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14:6
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13:1718:1
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1:57:10,16,22,248:3,7,179:4,18,1919:427:831:5
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3:45:730:14
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30:15
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9:25
discussion
10:2,8
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4:619:15
25:16,19
26:1327:2
documents
14:16,19,24
17:2120:1723:924:7
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14:816:21,2217:5,7,11,20
21:2322:3,16,2025:6,20,2426:5
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14:8
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6:24
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18:9
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11:17
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2:12
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29:1630:20
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1:95:2431:6
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5:1711:2513:18
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13:25
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31:9
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9:7,8
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2:11,12
ERRATA
31:2,1432:1
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26:5,7
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1:99:6
19:6
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EXAMINATION
3:1,45:7
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14:7
executed
24:2126:21,22
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4:46:3,16,20
9:1425:6,7,10
EXHIBITS
4:2,7
expected
13:15
experience
13:2214:5
Expires
29:1630:20
F
face
26:13
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21:2222:223:825:5,19
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26:12
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14:916:2222:13
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16:10
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11:19
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25:13
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30:12
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follows
5:6
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1912:3,5,7,2313:1115:16,24
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15:4,10,2116:5,1217:1318:15,19
20:6,1321:4,1822:4,2123:11,17,25
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28:18
Fort
2:13
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28:230:8,10
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19:16,17
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GAYON
1:92:165:2431:6
general
17:2318:323:23
getting
14:25
give
5:228:169:7
18:127:1giving
26:20
GLADSTONE
Patricia Berner November 29, 201136
Toll Free: 800.211.3376Facsimile: 305.493.3322
Aventura Corp. Center I, Suite 202
20801 Biscayne BlvdAventura, FL 33180
www.esquiresolutions.com
-
8/3/2019 Patricia.berner 112911 Mini
13/18
2:2
go
9:2410:612:1013:20
Good
5:9governs
19:20
GROUP
2:2
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21:7,11
H
half
5:216:8
hand25:629:930:16
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11:19
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21:16
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1:57:119:519:5,21
Harp
22:24,2523:1626:8
H-A-R-P
22:25
Harp's
23:9
heard
22:10,1223:2
held
10:8
helpful24:6
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22:1424:7
hereby
30:4
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30:8,9
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31:14
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30:16
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5:10
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20:21
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5:18,207:13,
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I
identificatio
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II
11:12,15,18
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19:4
including
22:1
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30:6
INDEX
3:14:2
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31:13
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14:3
information
14:23,24
instinct
9:24
instructs13:14
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13:10
interest
11:118:9,13
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30:12
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24:4
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15:9
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s
22:3,19
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7:715:24
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Jacksonville
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2:86:13
jeffrey.cook@
akerman.com
2:10
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jserrano@lgl
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2:5
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16:2,10
JUDICIAL
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5:226:412:413:418:2,2421:1425:627:128:5
K
KENNETH
2:11,125:23
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14:15,19
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L
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16:10,11
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LOAN
1:5,67:7,12,14,208:1,13,219:5,20
Patricia Berner November 29, 201137
Toll Free: 800.211.3376Facsimile: 305.493.3322
Aventura Corp. Center I, Suite 202
20801 Biscayne BlvdAventura, FL 33180
www.esquiresolutions.com
-
8/3/2019 Patricia.berner 112911 Mini
14/18
19:5,7,8,10,
12,14,21
loans
20:4,10,15,23
21:1,10,15
located11:23
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5:19
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24:14
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20:421:9
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21:17
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29:1530:19
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15:14,23
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4:55:2525:13
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33:1,4,7,10,
13,16,19
pages
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18:530:11
party
16:2527:17,2430:11
Patricia Berner November 29, 201138
Toll Free: 800.211.3376Facsimile: 305.493.3322
Aventura Corp. Center I, Suite 202
20801 Biscayne BlvdAventura, FL 33180
www.esquiresolutions.com
-
8/3/2019 Patricia.berner 112911 Mini
15/18
PASS-THROUGH
1:619:22
PATRICIA
1:143:25:1,5,139:229:5
31:2233:23payments
18:9
PENALTY
31:7,8
people
23:22
periodically
14:1
PERJURY
31:7,8
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22:7
personally
19:1129:5
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9:19
place
17:1127:1230:8
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20:2321:2Plaintiff
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5:127:2313:17
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17:2521:2322:3,15,16,20
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13:2214:5
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21:2323:23
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15:20
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17:22
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27:17
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18:4
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13:9
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14:23
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29:1530:19
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23:21
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21:14
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5:25
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9:321:8,1522:2525:17
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23:10
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21:2422:1
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28:4
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24:9
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24:10
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2:5
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23:228:13,1431:9,11
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26:15,16
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15:1116:617:1720:7
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13:18
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9:2410:2,3,5,7,911:518:2428:11
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13:2414:24
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8:2421:12
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17:11
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7:9,22,248:617:419:4
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30:11
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19:18
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24:12
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24:23
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21:24report
30:5
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1:2428:1330:4,15
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5:23
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7:4,10,16
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6:11
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30:14
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21:2
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11:20,22
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14:2516:1
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24:7
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20:10
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4:7
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25:16
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19:24
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7:1,2,1518:18,23
27:24
Road
2:45:13
S
save
31:12
saying
18:18
says6:2326:1327:3,6
schedule
Patricia Berner November 29, 201139
Toll Free: 800.211.3376Facsimile: 305.493.3322
Aventura Corp. Center I, Suite 202
20801 Biscayne BlvdAventura, FL 33180
www.esquiresolutions.com
-
8/3/2019 Patricia.berner 112911 Mini
16/18
19:10,13,14
Schwartz
1:2429:1530:3,19
scope
21:20seal
29:9
SEC
19:11,15
second
19:16
Section
20:17,18
secured
18:10
see
6:237:2
seek
10:16
seen
6:2022:1423:2,6
SENTERFITT
2:76:13
SERIES
1:619:22Serrano
2:3
service
8:13,21
servicer
18:11
Servicing
5:18,207:13,14,198:1,3,11,17,25
11:1012:1,16,2513:10,1914:6,1315:817:4,12,
1918:8,1219:1,3,7,20,
2520:3,927:7,9,16
set
30:8,9,16
SHEET
31:2,1432:1
She'll
28:14
short
28:10
Shorthand
1:2430:3,7
show
24:6
signature
23:10,15
33:22
signatures
23:2226:828:18
signed
15:2222:2031:18
sitting
26:19
six
12:2
skimmed
20:1
skip
25:14
software
13:2314:4,8,11,16,21
sorry
11:23sort
17:2318:3
sources
14:2
Southeast
2:8
speak
9:6,17
Special11:11,13,18
12:23
Specialist
11:11,13,18
specialists
12:18
Specialized
12:6
specific
18:224:8
specifically
16:7
spell
5:15
spiel
5:23
stands
19:18
start
10:5
State5:116:1012:9,12,13
29:1,1530:2,4,19
states
20:18
stenotype
30:5
strictly
18:11
subject
15:921:24,25
subsequently
15:23
Suite
1:212:4
summary
16:2,9
Sure
6:1218:2424:528:9
sworn
5:629:630:5
system
13:2214:6
T
T
2:8
tactic
24:11take
6:1911:513:428:4
TAKEN
1:156:517:1028:1030:831:10
Taking
4:55:2510:2430:9
talking9:11
taught
15:1
teach
15:2,5
tell
6:207:9,2415:1919:326:18
telling
7:21
testified
5:6
testify
30:5
testimony
8:169:710:1726:20
thank
11:7thanks
24:12
therefore
27:10
THEREUPON
5:46:1610:825:1028:10
things
13:21
think
10:1920:18
Third
2:816:25
Thomas
22:8,2023:1626:9
three
6:1
time
12:2418:12
25:1530:8times
6:7
title
12:17,23
13:10
titles
12:22
today
5:2515:1418:7
towards11:22
training
12:2413:5,8,
Patricia Berner November 29, 201140
Toll Free: 800.211.3376Facsimile: 305.493.3322
Aventura Corp. Center I, Suite 202
20801 Biscayne BlvdAventura, FL 33180
www.esquiresolutions.com
-
8/3/2019 Patricia.berner 112911 Mini
17/18
18,2514:115:7
transcript
30:1331:9
transcription
30:6transferred
20:4,11
21:10,16
transpired
16:9
TRENT
2:11,123:45:8,236:9,188:14,239:12,2310:1,6,10
11:7,813:3,1314:2015:6,1216:3,8,1417:1518:17,20
20:8,2221:5,2122:6,2323:13,19
24:1,5,9,13,
19,2425:4,7,9,12,1826:3,1727:13,22
28:2,6,9
trentlawoffic
2:13
trials
11:21
true
30:631:11
TRUST
1:5,67:11,
12,16,23,258:4,79:4,6,18,1912:919:4,6,8,10,
2120:5,11,
12,2121:2,6,10,1627:1831:5
TRUSTEE
1:57:11,17,23,258:4,7,189:512:3,5,7,10,14
19:520:20
truth
30:5
try
24:2
trying
26:24
Two
25:8,926:12two-fifths
6:24
Tywanna
22:823:1626:9,24
U
Um-hum
11:14,16
under
18:919:16
20:1724:2130:1431:7,8,16
undersigned
29:4
understand
9:1021:8
understanding
15:19,25
26:16,24
31:15understood
10:2223:924:3
unemployed
12:2
unless
13:1430:14
updated
14:1
use
13:2314:21
utilized
14:11,12
V
vehicle
10:16
vendor
16:2517:10
Virginia12:4,6,9
vocabulary
22:1
vs
1:831:5
W
waive
10:1528:13
waived
28:19want
10:118:2425:1528:6
wasn't
26:22
way
6:24
website
19:11,15
went
19:12
we're
7:198:114:118:6,1119:7
weren't
17:2418:4
West
2:4
We've
26:4,727:2WHEREOF
30:16
Whereupon
28:16
whether
6:4,2017:3,718:719:1921:9
whole
12:2114:630:5
widely
23:824:3
widespread
22:2
within
10:22,24
16:1024:10
WITNESS
3:28:10,20
9:10,2213:814:1815:5,11,2216:6,1317:1418:1620:7,1421:1922:5,22
23:12,18
24:18,23
25:3,8,17
26:1,1527:6,2128:1,1529:930:4,16
Word14:7
work
11:2212:25
13:19
worked
12:3
written
8:159:3
Y
Yeah
14:22
years
12:413:12
1
1
4:56:16,209:1430:6
11
29:16
11TH
1:229:930:16
1499
2:4
16
5:21
2
2
4:620:1825:10
2.01
20:17
20
31:19
2007-5
1:619:22
2009-20620-
CA
1:4
2011
1:175:229:1030:16
2015
Patricia Berner November 29, 201141
Toll Free: 800.211.3376Facsimile: 305.493.3322
Aventura Corp. Center I, Suite 202
20801 Biscayne BlvdAventura, FL 33180
www.esquiresolutions.com
-
8/3/2019 Patricia.berner 112911 Mini
18/18
29:16
202
1:21
20801
1:20
2091:18
247
1:1828:17
25
4:6
25th
2:9
267488
31:4
2830:6
29
1:175:2
3
30
13:11
300
2:4
32256
5:14
33131
2:9
33334
2:13
33486
2:5
4
4875
5:13
5
5
3:4
6
6
4:5
8
8/11/2015
30:20
831
2:12
84919
29:1630:20
Patricia Berner November 29, 201142
Toll Free: 800.211.3376Facsimile: 305.493.3322
Aventura Corp. Center I, Suite 202
20801 Biscayne BlvdAventura, FL 33180
www.esquiresolutions.com