Excerpts:

Q. Okay. And did it actually grant you
14 authority to sign as vice president anywhere in there?
15 A. The listing capacity on that assignment was
16 — is a clerical error. It needed to state “attorney in
17 fact.” This document grants the power as attorney in
18 fact.
19 Q. Okay. So —
20 A. But it does grant the authority to execute
21 the assignment of mortgage.
22 Q. Okay. So you are not vice president of
23 Wells Fargo Bank N.A.?
24 A. No.
25 Q. Okay. During your employment at Florida

1 Default Law Group, were there other companies that you
2 would execute assignments of mortgages on behalf of?
3 A. Yes. I believe there were others.
4 Q. And would you execute those assignments of
5 mortgages as attorney in fact or vice president?
6 A. I believe it varied. I do believe there were
7 other corporate resolutions that it did vary, the
8 capacity in which I signed.
9 Q. Okay. Do you recall specifically any of the
10 other entities that you would execute assignments of
11 mortgages on behalf of?
12 A. Mortgage Electronic Registration Systems,
13 known as MERS.
14 Q. MERS?
15 A. Yes.
16 Q. And what was your capacity as — what was
17 your signing authority on behalf of MERS?
18 A. I believe it was as vice president and
19 assistant secretary. I’m not positive, but I believe it
20 was as vice president.
21 Q. All right. Are you currently — this grants
22 you authority to act as attorney in fact for Wells Fargo
23 Bank until December 31st, 2010.
24 Do you still then execute documents as
25 attorney in fact for Wells Fargo Bank?

1 A. No, I don’t.
2 Q. Okay. And when did you stop doing that?
3 A. It would have been when I left Florida
4 Default in October of 2008.
5 Q. Okay. So was the sole basis of your actions
6 to sign documents as attorney in fact for Wells Fargo
7 Bank out of your employment for Florida Default Law
8 Group?
9 MS. HILL: Object to form.
10 MR. GANO: Objection to the form.
11 A. I’m sorry. Can you rephrase it?
12 Q. Outside of working as an attorney for Florida
13 Default Law Group, did you execute assignments of
14 mortgages for Wells Fargo Bank pursuant to this for any
15 other types of actions not related to Florida Default
16 Law Group?
17 A. No.
18 MS. HILL: When you say “this,” you pointed.
19 For record, you are referring to?
20 MR. IMMEL: This Limited Power of Attorney.
21 MR. GANO: Exhibit A.
22 MR. IMMEL: Exhibit A.
23 Q. And have you ever been to Wells Fargo Bank’s
24 headquarters or any of their offices?
25 A. No. I don’t believe I have.

1 Q. Okay. Are you aware — did you have to apply
2 for the limited power of attorney status with Wells
3 Fargo?
4 A. No.
5 Q. Are you aware of how you were chosen as a
6 limited — to be appointed the limited power of
7 attorney?
8 A. No, I don’t.
9 Q. Okay. Did Wells Fargo Bank provide you any
10 formal training or, I guess, any sort of detailed job
11 responsibilities, or was just this limited power of
12 attorney provided to you?
13 MR. GANO: I’m going to object as far as that
14 going into any specific instructions regarding
15 particular files that she was working while at
16 Florida Default on behalf of the Plaintiff.
17 Q. Without divulging privileged information, if
18 you would limit the answer to that.
19 A. Instruction from Wells Fargo, no.
20 Q. Okay. Did you receive any compensation from
21 Wells Fargo Bank for your duties as an attorney in fact,
22 limited power of attorney?
23 MR. SMITH: You’re asking about her
24 personally?
25 MR. IMMEL: Yes, her personally.

1 A. No.
2 Q. No. Okay. Did you ever attend any board
3 meetings or executive meetings for Wells Fargo Bank?
4 A. No.
5 Q. For that matter, with regard to your signing
6 authority on behalf of MERS, was there any difference
7 between how you carried out your authority with being
8 able to sign documents on behalf of MERS versus Wells
9 Fargo Bank?
10 MS. HILL: I’m going to object to the form.
11 A. I’m sorry. Rephrase, please.
12 Q. Okay. In executing an assignment of mortgage
13 on behalf of Wells Fargo Bank pursuant to the Limited
14 Power of Attorney, when you would do that, did that
15 differ in any way from when you would execute them and
16 an assignment of mortgage on behalf of MERS?
17 A. No.
18 MS. HILL: Object to the form.
19 Q. Okay. Are you still — do you still have
20 signing authority on behalf of MERS?
21 A. I don’t know.
22 Q. You don’t know?
23 A. No, sir.
24 Q. Okay. Did MERS pay you for executing
25 assignments of mortgages?

1 A. No.
2 Q. Okay. Approximately, how many assignments of
3 mortgages would you execute on behalf of Wells Fargo
4 Bank?
5 A. I have no —
6 MS. HILL: Object to the form.
7 A. I don’t know.
8 Q. Okay. Going back to Exhibit A, it says that
9 Mark Wooton, Vice President of Loan Documentation,
10 granted this Limited Power of Attorney.
11 Did you ever meet Mark Wooton?
12 MS. HILL: I’m going to object to the form
13 only to the extent that Mark Wooton signed the
14 Limited Power of Attorney, I don’t know if signing
15 it is the same thing as granting it or if there is
16 a distinction. But to that extent, I’m objecting
17 to the question.
18 Q. Mark Wooton signed the Limited Power of
19 Attorney. Did you ever meet Mark Wooton?
20 A. Not that I recall.
21 Q. Okay. Are you aware of whether he was
22 authorized to sign this Limited Power of Attorney?
23 A. No. I don’t know.
24 Q. Okay. Did you report to anyone directly at
25 Wells Fargo Bank?

1 A. No.
2 Q. Did you receive directions to execute an
3 assignment of mortgage directly from Wells Fargo Bank?
4 MR. GANO: I’m going to object base upon
5 attorney-client privilege, any specific
6 instruction she obtained regarding this case or
7 any other cases.
8 Q. Without divulging privileged information.
9 A. We did have a procedure that under certain
10 circumstances, yes, we were directed to prepare the
11 assignments.
12 Q. Okay. Could you, I guess, describe the
13 procedure for when you would be directed, without
14 divulging attorney-client privileges?
15 A. Yes. When our client referred in the
16 mortgage referral.
17 Q. Okay.
18 A. It could be the owner or it could be the
19 servicer. In this particular case with Wells Fargo,
20 they sent in the referral. They indicated that they
21 were the servicer for the new owner, which I believe was
22 HSBC, and indicated that HSBC was the proper owner and
23 holder of the note.
24 In that event of record, Wells was the last
25 of-record owner and holder of the note; therefore, we

1 were to effectuate the assignment of mortgage prepared
2 and executed on behalf of Wells Fargo.
3 Q. Okay. What type of documents would you rely
4 upon to determine that aside from just the referral
5 stating that HSBC Bank was, I guess, the owner of the
6 note; what other documents would you rely upon to
7 ascertain that?
8 A. That HSBC was the owner?
9 Q. Yes.
10 A. We relied on our client’s referral indicating
11 that they had sold it to HSBC.
12 Q. Okay. Was there any other information that
13 you can recall?
14 A. Not that I recall.
15 Q. Okay. So going back to the referral, the
16 determination to execute an assignment of mortgage then
17 would be sent to you by Wells Fargo in a case like this
18 — in this case?
19 MR. GANO: Object to the form.
20 A. I’m sorry. I don’t quite understand that
21 question.
22 Q. Okay. Wells Fargo directed you to execute
23 the assignment of mortgage in this case?
24 MR. GANO: Again, I’m going to object based
25 upon any specific information given as

1 attorney-client privilege.
2 Q. Without divulging attorney-client privilege.
3 A. Under the procedure we had, yes.
4 Q. Okay.
5 A. Correct.
6 Q. Okay. And how would the referral — how was
7 the referral sent?
8 A. I’m not positive. It varied. I believe it
9 was electronic.
10 Q. Okay. And in situations where the — would
11 you ever rely upon the note to determine who to execute
12 an assignment of mortgage to?
13 A. Rely upon the note?
14 Q. The note, the promissory note.
15 A. A copy or the original?
16 Q. Copy, original, any fashion, the promissory
17 note?
18 A. No.
19 Q. Okay. So whether or not the note was lost at
20 the time of the referral would not impact your execution
21 of the assignment of mortgage?
22 A. No.
23 Q. Okay. How would you receive a promissory
24 note then from the plaintiff or whoever referred the
25 case to you?

1 A. Typically, they would mail the original
2 documents to our office.
3 Q. Do you recall if it would be mailed by any
4 sort of certified mail or return receipt; would you sign
5 for anything?
6 A. I don’t know. It didn’t come to me directly.
7 Q. And in cases such as this where Wells Fargo
8 would send the referral to you and state that they were
9 the servicer, what type of information would you review
10 to ascertain that they were, in fact, the servicer?
11 MR. GANO: Object to the form, and object to
12 any specific information, again, on this
13 particular referral.
14 Q. Without divulging privileged information.
15 A. We just relied on them indicating that they
16 were the servicer —
17 Q. Okay.
18 A. — who the plaintiff was to be.

See Deposition/Transcript below

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