Q. So if you didn’t review any books, records, and documents or computerized records, how is it that you had personal knowledge of all the matters contained therein?
A. Well, I have personal knowledge that my staff has personal knowledge. That is our process.
She doesn’t know anything…
She doesn’t even read ANYTHING!
She does the assignments, the verifications of complaint “under penalty of perjury” and amounts due and owing!
This deposition is even better that Jeffrey Stephan’s depo…
Is Chase up next for a Moratorium???
Excerpts from the depo…
21 A. Beth Cottrell.
22 Q. And your title.
23 A. My full title is an operation supervisor.
24 Q. And your employer.
25 A. Chase Home Finance.
19 Q. Can you describe your duties day to day
20 with Chase.
21 A. My duties are — at this point are
22 reporting for the document execution, reviewing
23 verbiage, reviewing questionable items on amount
25 Q. So can you describe what kinds of documents you sign?
2 A. I sign affidavits, deeds, assignments.
3 Q. And what else?
4 A. Allonges, lost note affidavits, lost
5 mortgage affidavits.
6 Q. And can you tell me in a given week how
7 many affidavits you might sign?
8 A. Can I tell you — I can tell you as a
9 group, as a whole.
10 Q. Sure.
11 A. Amongst all the management we sign about
12 18,000 a month.
13 Q. And that would include affidavits and
14 assignments and the other documents you listed?
15 A. Everything.
16 Q. And how many folks are on what you call
17 the management?
18 A. Let’s see, eight.
19 Q. Eight. For each document that you sign,
20 including all those that you listed, assignments,
21 et cetera, et cetera, how much time would you say you
22 take to review what’s on each document?
23 A. I take personally or what’s taken?
24 Q. Sure. What you take.
25 A. A lot of the review is done by the
1 employees, the staff. I rely on them to do their job
2 and look up the correct verbiage and amounts.
3 Q. So once you get it, how long on average
4 would you say you might take?
5 A. I don’t know.
6 Q. Can you estimate? Would you take five
7 minutes, would you take 30 minutes, or would you take
8 maybe a minute?
9 A. My review is more or less signing the
10 document unless it’s questionable.
11 Q. And how would you know if it’s
12 questionable? Would something be —
13 A. Somebody has a question and brings it to
14 me and says, Beth, can you take a look at this.
15 Q. So that would be the only time you would
16 actually review the entire document.
17 A. In depth, yes.
18 Q. You said the employees and the staff
19 prepare the documents. Can you, I suppose, first
20 describe their titles and what their job duties would
22 A. They are operation specialists, and
23 they’re actually using the system to look up
24 verbiage. They’re using the system to look up the
25 numbers. They spend a lot more time reviewing the
2 Q. Can you describe some instances or give me
3 some examples of when something might be highlighted
4 for you that would induce you to take some more time
5 to review a document?
6 A. When they can’t figure out the breakdown.
7 When it doesn’t balance. When you’re giving escrow,
8 then it’s brought to me to review. When the verbiage
9 doesn’t look right or one that we may not have a POA
11 Q. When you say the verbiage —
12 A. It could be a merger.
13 Q. So signing on behalf of I guess
14 J.P. Morgan before they merge or something like that.
15 A. Or Bank One or any entity that was a
17 Q. Who actually drafts, and I’ll ask
18 specifically about affidavits, before you sign them?
19 A. Who prepares — actually does the
20 writing — the attorney.
21 Q. And then it’s your — the operation
22 specialists who write in the numbers then.
23 A. Right.
10 Q. I’ll ask you if you recognize this
12 A. Yes.
13 Q. Can you tell me what it is?
14 A. It’s an amounts due affidavit.
15 Q. And on the second to last page of the
16 five-page document that I’ve given you, is that your
18 A. Yes.
19 Q. And I’ll ask you about the first page of
20 the affidavit. It states that upon oath you depose
21 on personal knowledge. Did you have personal
22 knowledge of everything that you testified to in this
24 A. My personal knowledge is based on what
25 they have put in here, what the staff put in here.
1 You’re talking about the numbers again?
2 Q. Well, just I’ll ask you in regards to the
3 entire affidavit. This was an introductory paragraph
4 I believe referring to the entire affidavit. It
5 stated you deposed on personal knowledge. As to
6 everything in the affidavit, did you have personal
8 A. My own personal knowledge, no.
9 Q. In paragraph 1 it’s stated that the
10 “Affidavit is submitted in support of plaintiff’s
11 motion for final judgment for the purpose of showing:
12 That there is no genuine issue as to any material
13 fact.” Did you have personal knowledge that there is
14 no genuine issue as to any material fact in this
16 A. Yes. They would have brought it to me
18 Q. And they being again —
19 A. The staff.
20 Q. — the staff, the operation specialists.
21 A. Correct.
22 Q. And did you do anything to verify that
23 there was no genuine issue as to any material fact in
24 this case?
25 A. No.
Check out the two depos below…