EXCERPT:

Q. Okay. And who would do the title search?
2 MS. HILL: Are you asking who did the title
3 search in this case?
4 MR. IMMEL: Yes.
5 A. Generally for the firm, again, the title
6 company that — that we’ve engaged to do the title
7 search and exam is New House Title.
8 BY MR. IMMEL:
9 Q. Okay. And what relationship does New House
10 Title company have to Florida Default Law Group?
11 A. New House Title is a —
12 MS. HILL: Well, I’m going to object to the
13 form of the question.
14 MR. IMMEL: Okay.
15 MS. HILL: He just said that the firm engages
16 New House Title, so —
17 MR. IMMEL: Right.
18 MS. HILL: — it would appear they have a
19 relationship of vendor and vendee, but your
20 question was objectionable.
21 MR. IMMEL: Okay.
22 A. It’s the title company we engage to provide
23 the service. And I believe what we are getting to is
24 the fact that the law firm owns the title company.
25 BY MR. IMMEL:

Q. Okay. That is reflected on — commonly on
2 affidavits and things of that nature. Does Florida
3 Default Law Group solely utilize New House Title as
4 their — to review — do title searches?

<SNIP>

22 Q. Okay. Okay. Do you personally know Lisa or
23 Erin Cullaro?
24 A. I do.
25 Q. You do. Okay. And as I’m sure you’re aware,

1 we’ve sought to take the depositions of Lisa and Erin
2 Cullaro in numerous cases and those affidavits were
3 withdrawn. Are you familiar with that issue within this
4 case?
5 MS. HILL: I’m sorry. Are you asking this
6 witness as to what — what transpired in this
7 particular case, this foreclosure case?
8 MR. IMMEL: Yes. Based on his personal
9 involvement.
10 MS. HILL: Okay. Then objection. You’re
11 assuming facts that have not been established.
12 You’re mischaracterizing his testimony. As far as
13 I can tell, the only fact that you’ve established
14 regarding his personal involvement is the
15 Assignment of Mortgage that is Exhibit A. And
16 whether that’s a part of this file or not a part of
17 this file are two different issues. But you have
18 not established that Mr. Wolfe individually has
19 served as an attorney with respect to the
20 prosecution of this foreclosure action, and so
21 asking him questions as to what may or may not have
22 transpired as part of the prosecution of this
23 foreclosure action is improper.
24 MR. IMMEL: Okay.
25 BY MR. IMMEL:

<SNIP>

14 Q. Are you choosing not to answer that you have
15 any personal knowledge as to whether or not affidavits
16 have been withdrawn by Lisa and Erin Cullaro?
17 A. Yes.
18 Q. You have no personal knowledge that —
19 A. I’m refusing to answer.
20 Q. You’re refusing to answer. Okay. Did you
21 ever discuss having their depositions taken with either
22 Lisa or Erin Cullaro?
23 MS. HILL: Same objection. Same instruction.
24 BY MR. IMMEL:
25 Q. And are you choosing not to answer based on

1 your attorney’s instructions?
2 A. Yes, I am choosing not to answer.
3 Q. Okay. Did you ever instruct Lisa Cullaro or
4 Erin Cullaro that Florida Default Law Group would
5 aggressively defend having their depositions taken in
6 this case or any other cases?
7 MS. HILL: Same objection. Same instruction.
8 BY MR. IMMEL:
9 Q. Are you choosing not to answer as to whether
10 or not you have any personal knowledge regarding the
11 Cullaro deposition, Lisa Cullaro or Erin Cullaro’s
12 deposition based on your attorney’s recommendation?
13 MS. HILL: That’s a different question. But
14 to that question, it’s the same objection and the
15 same answer.
16 A. I have —
17 MS. HILL: I mean, the same objection and the
18 same instruction.
19 A. Yes. I’m not going to answer. I have no idea
20 what — what deposition of Lisa Cullaro you’re
21 referencing.
22 BY MR. IMMEL:
23 Q. Do you — do you have any personal knowledge
24 that our office has sought the deposition of Lisa
25 Cullaro or Erin Cullaro?

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