Excerpts:
Q Do you have any knowledge of why American
Home Servicing, Inc. no longer does business with
DOCX?
A There were deficiencies in the documents
that they were producing.
Q What sort of deficiencies in general?
A They weren’t deficiencies. They weren’t
prepared correctly
Q Can you give me any more detail about that?
I’m not asking about this specific case yet. Just in
general what sort of deficiencies?
A Some of the assignments weren’t properly
conveying the assignor/assignee appropriate parties.
Q As to the present mortgage that we’re here
on today, do you know whether American Home
Servicing, Inc. has ever had any ownership of the
beneficial interest in the payments due under the
note and secured by the mortgage?
A No, we’re strictly the servicer.
Q So at no time has American Home Servicing,
Inc. actually owned any interest in the mortgage; is
that correct?
MR. COOK: Object to the form.
THE WITNESS: No, we have not.
[…]
Q Now, do you know a person by the name of
Tywanna Thomas?
A No.
Q Have you ever heard that name?
A Yes.
Q In what context have you heard or become
familiar with that name?
A I’ve seen her name on assignments that they
prepared.
Q That DOCX prepared?
A Yes.
Q Has it ever come to your attention that
there are some irregularities with assignments
allegedly signed by Ms. Thomas and prepared by DOCX?
Mr. COOK: Object to the form.
THE WITNESS: Yes.
BY MR. TRENT:
Q What about Korell Harp, K-O-R-E-L-L,
H-A-R-P? Same question. Do you know Korell Harp?
that particular assignment came about?
MR. COOK: Object to the form.
THE WITNESS: How it came about?
BY MR. TRENT:
Q Yes. Isn’t it a fact, ma’am, that this is
a DOCX assignment? I’ll just hand you the exhibit.
MR. TRENT: It’s Exhibit —
THE WITNESS: Two.
MR. TRENT: — two.
(Thereupon, Defendants’ Exhibit Number 2
was marked for identification.)
BY MR. TRENT:
Q It has the Notice of Filing in the front,
but skip that.
MR. COOK: Do you want some time to
review the document?
THE WITNESS: I forgot the question.
BY MR. TRENT:
Q Isn’t it a fact, ma’am, that this document
was prepared by DOCX?
A Yes.
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