NOTE: Sue Barnes aka Sue Ethridge because she signed as Barnes

___________________________

Excerpts:

Q. Have you had any other titles in
3 your role with MERS?
4 MR. DEIGHTON: Objection. The
5 documents speak for themselves.
6 Q. Well, the mortgage assignments
7 indicate that you’re vice president. Have you
8 ever been secretary or any other title, when
9 you signed a document for MERS?
10 MR. DEIGHTON: I’m going to object.
11 I’m going to point to Exhibit B, the third
12 page, which states that the list of candidates
13 on the fourth page are appointed as assistant
14 secretaries and vice presidents of MERS; and
15 we’re willing to stipulate that pursuant to
16 this agreement, that she would be both an
17 assistant secretary and vice president.
18 MR. MILLIGAN: Okay.
19 Q. Have you been in a role other than
20 assistant secretary or vice president for MERS?
21 A. No.
22 Q. Do you consider yourself a
23 corporate officer of MERS?
24 MR. DEIGHTON: Objection.
25 A. No.

Q. Have you ever been paid by MERS?
2 A. No.
3 Q. Have you ever received any type of
4 compensation from MERS?
5 A. No.
6 Q. Have you ever visited MERS’
7 corporate offices?
8 A. No.
9 Q. Have you ever spoken with any
10 corporate officers of MERS?
11 A. No.
12 Q. Do you know where MERS’ corporate
13 offices are located?
14 A. No.
15 Q. Have you ever spoken to anyone at
16 MERS?
17 A. Yes.
18 Q. Who have you spoken to at MERS?
19 A. I don’t recall their names.
20 Q. Do you recall the last time you
21 spoke with someone from MERS?
22 A. Years.
23 Q. Years ago?
24 A. (Nodding.)
25 Q. Five years?

MR. DEIGHTON: Objection.
2 A. I don’t recall.
3 Q. Do you recall who that person was?
4 A. No.
5 Q. Do you recall what the conversation
6 was about?
7 A. No.
8 Q. Do you recall how many
9 conversations you’ve had with people affiliated
10 with MERS?
11 A. No.
12 Q. Can you give a ballpark?
13 A. I don’t know.
14 Q. A dozen?
15 MR. SANDY: Objection.
16 Q. A couple dozen?
17 A. I don’t know.
18 Q. But it’s been years since you’ve
19 talked to anyone at MERS?
20 A. Correct.
21 Q. Did you have any obligation to
22 report to anyone at MERS?
23 MR. DEIGHTON: Objection.
24 A. No.
25 Q. Did you ever report to anyone at
MERS?
2 A. No.
3 Q. Did anyone at MERS direct your
4 activities?
5 MR. SANDY: Objection.
6 A. No.
7 Q. And you mentioned that years ago,
8 you had talked to someone at MERS. Would that
9 have been on a weekly basis, daily basis?
10 What’s the frequency with which you would speak
11 to someone at MERS?
12 A. Random.
13 Q. And what would be the reason for
14 those discussions?
15 A. Assistance of their website
16 typically.
17 Q. Assist with their website?
18 A. Assistance for me with their
19 website.
20 Q. What type of assistance would you
21 need?
22 A. Maneuvering it. Sometimes it was
23 changed and I couldn’t find what I needed to
24 find.

[…]

Q. Does anyone from MERS have an
4 office at Carlisle?
5 MR. DEIGHTON: Objection.
6 A. No.
7 Q. Are there any employees of MERS
8 that you work with?
9 MR. SANDY: Objection.
10 A. No.

[…]

Q. Is the complaint and mortgage
2 assignment department part of the foreclosure
3 department?
4 A. Yes.
5 Q. Do you know what Samantha would do,
6 what was her job duties?
7 MR. DEIGHTON: Objection. Can you
8 clean it up by limiting the period of time that
9 you’re asking about?
10 Q. On or around when the mortgage
11 assignment in this case was executed.
12 A. I don’t recall. She has worked in
13 many departments at the firm.
14 Q. Were you present when Samantha
15 notarized this?
16 A. Yes.
17 Q. Was Samantha present when you
18 signed the document?
19 A. Yes.
20 Q. Do you recall whether you signed
21 any other documents on November 17, 2010 in
22 front of Samantha?
23 A. I don’t recall.
24 Q. Do you know who prepared this
25 particular mortgage assignment, Exhibit C?

A. No.
2 Q. Who instructed you to execute this
3 mortgage assignment?
4 A. No one.
5 Q. No specific individual instructed
6 you?
7 A. No.
8 Q. Is there a policy at Carlisle
9 related to execution of mortgage assignments?
10 MR. DEIGHTON: Objection. That
11 seeks proprietary information.
12 Instruct my client not to answer.
13 Q. Did anyone from MERS instruct you
14 to sign —
15 MR. SANDY: Objection.
16 Q. — the mortgage assignment?
17 A. No.
18 Q. When the mortgage assignment is
19 presented to you, how long does the process
20 typically take to review, sign and notarize?
21 A. Fifteen minutes.
22 Q. Just so we’re clear, you do not get
23 any compensation from MERS?
24 MR. SANDY: Objection, asked and
25 answered.

A. That’s correct.
2 Q. Do you recall reviewing any of the
3 loan documents related to the property that’s
4 the subject of the mortgage assignment that’s
5 been identified as Exhibit C?
6 A. No.
7 Q. Do you recall having reviewed the
8 mortgage that was assigned?
9 A. No.
10 Q. Do you typically review the
11 mortgage before signing the mortgage
12 assignment?
13 A. Yes

Exhibits

2070574-Exhibit-B-1-Sue Ethridge-1

2070574-Exhibit-C-1-Sue Ethridge

2070574-Exhibit-D-1-Sue Ethridge

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